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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
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MARXE, GLATFELTER
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S DALE R. GLATFELTER
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DECREE IN
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AND NOW, "" ,).~, "J:,(" 0'" 19,1'.1", it is ordered and
decreed that 0 0, , , , , ,l:'~,R,~ ,~:, ,~~~:r,~~~:r,E,~" , , , '0" '00' 0 0 0' 0', plaintiff,
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are divorced from the bonds of matrimony,
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$. The court retains jurisdiction of the following claims which have
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DIANE G, RADCLIFF
3448 TRINDlE ROAO
CAMP HilL. PA 17011
PHONE: 17171 737,0100
FAX: 17171975,0697
. ,
intention of HUSBAND and WIFE to live separate and apart for the
rest of their natural lives, and the parties hereto are desirous of
settling fully and finally their respective financial and property
rights and obligations as between each other including, without
limitation by specification: the settling of all matters between
them relating to the ownership and equitable distribution of real
and personal property; the settling of all matters between them
relating to the past, present and future support, alimony and/or
maintenance of WIFE by HUSBAND or of HUSBAND by WIFE; and in
general, the settling of any and all claims and possible claims by
one against the other or against their respective estates.
NOW, THEREFORE, in consideration of the premises and mutual
promises, covenants and undertakings hereinafter set forth and for
other good and valuable consideration, receipt of which is hereby
acknowledged by each of the parties hereto, WIFE and HUSBAND, each
intending to be legally bound hereby, covenant and agree as
follows:
1. INCORPORATION OF PREAMBLE:
The recitals set forth in the Preamble of this Agreement
are incorporated herein and made a part hereof as if fully set
forth in the body of the Agreement.
2. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS I
This Agreement shall not be considered to affect or bar
the right of HUSBAND and WIFE to an absolute divorce on lawful
grounds if such grounds now exist or shall hereafter exist or
to such defense as may be available to either party. This
Agreement is not intended to condone and shall not be deemed
Page 2 of 28
DIANE Q, RADCLIFF
3448 TRINDlE ROAD
CAMP Hill. PA 17011
PHONE: 1717) 737.0100
FAX: (7171975,0697
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to be condonation on the part of either party hereto of any
act or acts on the part of the other party which have
occasioned the disputes or unhappy differences which have
occurred or may occur subsequent to the date hereof.
3. DIVORCE DECREE.
The parties acknowledge that
their marriage is
irretrievably broken and that they will secure a mutual
consent no-fault divorce decree in the above captioned divorce
action, As soon as possible under the terms of said Divorce
Code, the parties shall execute and file all documents and
papers, including affidavits of consent, necessary to finalize
said divorce, If either party fails or refuses to finalize
said divorce or execute and file the documents necessary to
finalize the divorce, said failure or refusal shall be
considered a material breach of this Agreement and shall
entitle the other party at his or her option to terminate this
Agreement,
4. EFFECT OF DIVORCE DECREE.
Unless otherwise specifically provided herein, this
Agreement shall continue in full force and effect after such
time as a final Decree in Divorce may be entered with respect
to the parties,
5. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE.
The terms of this Agreement shall be incorporated into
any Divorce Decree which may be entered with respect to them,
Page 3 of 28
DIANE G, RADCLIFF
3448 TRINDLE ROAD
CAMP HILL. PA 17011
PHONE: 17171737-0100
FAX: 1717) 975,0697
. .
6. NON-MERGER I
This Agreement shall not merge with the Divorce Decree,
but rather, it continues to have independent contractual
significance and each party maintains their contractual
remedies as well as court remedies as the result of the
aforesaid incorporation or as otherwise provided by law or
statute.
7. DATE OF EXECUTION:
The "date of execution" or "execution date" of this
Agreement shall be defined as the date of execution by the
party last executing this Agreement.
8. DISTRIBUTION DATE.
The transfer of property, funds and/or documents provided
for herein shall only take place on the "distribution date"
which shall be defined as the date of execution of this
Agreement unless otherwise specified herein,
9. ADVICE OF COUNSEL,
The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective
counsel, MICHAEL 0, RENTSCHLER, ESQUIRE for HUSBAND, and DIANE
G, RADCLIFF, ESQUIRE, for WIFE. The parties acknowledge that
they have received independent legal advice from counsel of
their selection and that they fully understand the facts and
have been fully informed as to their legal rights and
obligations and they acknowledge and accept that this
Agreement is, in the circumstances, fair and equitable and
that it is being entered into freely and voluntarily, after
Page 4 of 28
DIANE G, RADCLIFF
3448 TRINDlE ROAO
CAMP Hill. PA 17011
PHONE: (717)737,0100
FAX: 17171 975,0697
- ,
having received such advice and with such knowledge and that
execution of this Agreement is not the result of any duress or
undue influence and that it is not the result of any collusion
or improper or illegal agreement or agreements.
10. FINANCIAL DISCLOSURE.
The parties confirm that each has relied on the
substantial accuracy of the financial disclosure of the other,
as an inducement to the execution of this Agreement and each
party acknowledges that there has been a full and fair
disclosure of the parties I mari tal assets which has been
provided to each party.
With respect to said disclosure the parties acknowledge
that the listing and valuation of the marital assets set forth
on Exhibit "A" attached hereto and made a part hereof
represents the full and fair disclosure of the parties'
marital estate and they further agree that the distributions
provided for in this agreement are intended to be in
accordance with the distributions set forth on Exhibit "A',
11. DISCLOSURE AND WAIVER OF PROCEDURAL RIGHTS,
Each party understands that he or she has the right to
obtain from the other party a complete inventory or list of
all of the property that either or both parties own at this
time or owned as of the date of separation, and that each
party has the right to have all such property valued by means
of appraisals or otherwise. Both parties understand that they
have the right to have a court hold hearings and make
decisions on the matters covered by this Agreement,
Both
Page 5 of 28
DIANE G, RADCLIFF
3448 TRINDLE ROAD
CAMP HILL, PA 17011
PHONE: (7171737,0100
FAX: (7171975,0697
parties understand that a court decision concerning the
parties' respective rights and obligations might be different
from the provisions of this Agreement,
Each party hereby acknowledges that this Agreement is
fair and equitable, that it adequately provides for his or her
needs and is in his or her best interests, and that the
Agreement is not the result of any fraud, duress, or undue
influence exercised by either party upon the other or by any
other person or persons upon either party,
Given said understanding and acknowledgment, both parties
hereby waive the following procedural rights:
a. The right to obtain an inventory and appraisement of all
marital and separate property as defined by the
Pennsylvania Divorce Code,
b. The right to obtain an income and expense statement of
the other party as provided by the Pennsylvania Divorce
Code, except in instances where said income and expense
statement is hereafter required to be filed in any child
support action or in any other proceedings pursuant to an
order of court,
c. The right to have any discovery as may be permitted by
the Rules of Civil Procedure, except discovery arising
out of a breach of this Agreement, out of any child
support action, or out of any other proceedings in which
discovery is specifically ordered by the court,
d. The right to have the court determine which property is
marital and which is non-marital, and equitably
Page 6 of 28
DIANE G, RADCLIFF
3448 TRINDlE ROAD
CAMP Hill. PA 17011
PHONE: (717) 737-0100
FAX: (717) 975-0697
distribute between the parties that property which the
court determines to be marital,
e. The right to have the court decide any other rights,
remedies, privileges, or obligations covered by this
Agreement, including, but not limited to, possible claims
for divorce, spousal support, alimony, alimony pendente
lite (temporary alimony), and counsel fees, costs and
expenses.
12. PERSONAL PROPERTY,
HUSBAND and WIFE do hereby acknowledge that they have
previously divided their tangible personal property including,
but without limitation,
jewelry,
clothes,
furniture,
furnishings,
rugs,
carpets,
household equipment and
appliances, tools, pictures, books, works of art and other
personal property and hereafter WIFE agrees that all of the
property in the possession of HUSBAND shall be the sole and
separate property of HUSBAND; and HUSBAND agrees that all of
the property in the possession of WIFE shall be the sole and
separate property of WIFE, The parties do hereby specifically
waive, release, renounce and forever abandon whatever claims,
if any, he or she may have with respect to the above items
which shall become the sole and separate property of the
other.
13. AFTER-ACOUIRED PROPERTY,
Each of the parties shall hereafter own and enjoy,
independently of any claim or right of the other, all
property, tangible or intangible, real, personal or mixed,
Page 7 of 28
DIANE G, RADCLIFF
3448 TRINDlE ROAD
CAMP Hill. PA 17011
PHONE: 1717) 737.0100
FAX: (717) 975,0697
acquired by him or her, since September 9, 1997, the date of
the parties' marital separation, with full power in him or her
to dispose of the same as fully and effectively, in all
respects and for all purposes, as though he or she were
unmarried and each party hereby waives, releases, renounces
and forever abandons any right, title, interest and claim in
and to said after acquired property of the other party
pursuant to the terms of this paragraph.
14. DIVISION OF VEHICLES.
With respect to the vehicles owned by one or both of the
parties, they agree as follows:
a. 1986 Honda Accord shall be the sole and exclusive
property of WIFE,
b. 1988 Honda Civic shall be the sole and exclusive property
of HUSBAND,
The titles to said vehicles shall be executed by the
parties, if appropriate, for effectuating transfer as herein
provided on the date of execution of this Agreement and said
executed titles shall be delivered to the proper party on the
distribution date. For purposes of this Paragraph the term
"title" shall be deemed to include "power of attorney" if the
title to the vehicle is unavailable due to financing
arrangements or otherwise, In the event any vehicle is
subject to a lien or encumbrance the party receiving said
vehicle as his or her property shall take it subject to said
lien and/or encumbrance and shall be solely responsible
therefor and said party further agrees to indemnify, protect
Page 8 of 28
DIANE G, RADCLIFF
3448 TRINDlE ROAD
CAMP Hill. PA 17011
PHONE: 1717) 737,0100
FAX: (717) 975,0697
and save the other party harmless from said lien or
encumbrance,
Each of the parties hereto does specifically
waive, release, renounce and forever abandon whatever right,
title and interest they may have in the vehicles that shall
become the sole and separate property of the other pursuant to
the terms of this Paragraph,
15. DIVISION OF REAL ESTATE.
The parties are the joint owners of a certain tract of
improved real estate known and numbered as 5243 Meadowbrook
Drive, Mechanicsburg, PA 17055 (hereafter referred to as "the
Real Estate"),
The Real Estate has an estimated value of
$130,000,00 and is subject to a mortgage owed to Continental
Capi tal Mortgage having an estimated balance of $50,232,31
(hereafter referred to as "the Mortgage"), With respect to
the Real Estate and the Mortgage, the parties agree as
follows:
a, Contingent upon HUSBAND'S payment to WIFE of the amount
of $78,866.21 as hereafter provided, WIFE shall make,
execute and deliver all documents in the usual form
conveying, transferring and granting to HUSBAND all of
her right, title and interest in and to the Real Estate
and agrees that upon said transfer and conveyance WIFE
shall specifically waive, release, renounce and forever
abandon all her right, title and interest therein,
b, The said conveyance shall be subject to the lien of the
Mortgage and shall be under and subject to any covenants
and restrictions of record,
Page 9 of 28
DIANE G, RADCLIFF
3448 TRINDLE ROAD
CAMP HILL, PA 17011
PHONE: 1717)737-0100
FAX: 17171975,0697
c, HUSBAND shall hereinafter be solely responsible for the
payment of the Mortgage and shall indemnify, protect and
save WIFE harmless therefrom, In the event HUSBAND
becomes more than 60 days delinquent in the payment of
the Mortgage, HUSBAND shall be required to sell the Real
Estate or to refinance the Mortgage so as to relieve WIFE
from all further obligation and liability thereunder.
d, Within 60 days of the date of this Agreement, HUSBAND
shall pay WIFE the sum of $78,866,21 representing her
interests in the Real Estate and the other assets to be
distributed pursuant to the terms hereof. In the event
HUSBAND should fail to make said payment within the sixty
(60) day period, then HUSBAND, immediately upon the
request of WIFE, shall be required to sell the Real
Estate so as to generate a fund from which said payment
is to be made,
16. EACH PARTY RETAINS OWN PENSION PLANS:
Except as hereafter provided each of the parties does
specifically waive, release, renounce and forever abandon all
of their right, title, interest or claim, whatever it may be,
in any Pension Plan, Retirement Plan, Profit Sharing Plan,
401-K Plan, Keogh Plan, Stock Plan, Tax Deferred Savings Plan
and/or any employee benefit plan of the other party, whether
acquired through said party's employment or otherwise, and
hereafter said Pension Plan, Retirement Plan, Savings Plan,
Tax Deferred Savings Plan and/or any employee benefit plan
Page 10 of 28
DIANE G, RADCLIFF
3448 TRINDlE ROAD
CAMP Hill. PA 17011
PHONE: 17171 737,0100
FAX: 17171975.0697
shall become the sole and separate property of the party in
which name or through whose employment said plan is carried.
The foregoing notwithstanding, it is agreed that the
marital portion of HUSBAND'S Gannett Fleming pension shall be
equally divided between the parties. WIFE's 50% shall be
determined by multiplying by ,50 the product of the gross
monthly benefit multiplied by the marital coverture fraction,
A Qualified Domestic Relations order shall be approved and
executed by the parties to carry forth in intent of this
Paragraph,
17. DIVISION OF B~ ACCOUNTS/STOCK/LIFE INSURANCE I
The parties acknowledge and agree that they have
previously divided to their mutual satisfaction all of their
bank accounts, certificates of deposit, IRA accounts, bonds,
shares of stock, investment plans and life insurance cash
value and hereafter WIFE agrees that all said bank accounts,
certificates of deposit, IRA accounts, bonds, shares of stock,
investment plans and life insurance cash value in the
possession of HUSBAND shall become the sole and separate
property of HUSBAND; and HUSBAND agrees that all the said
bank accounts, certificates of deposit, IRA accounts, bonds,
shares of stock, investment plans and life insurance cash
value in the possession of WIFE shall become the sole and
separate property of WIFE, Each of the parties does
specifically waive, release, renounce and forever abandon
whatever right, title, interest or claim, he or she may have
in any bank account, certificates of deposit, IRA accounts,
Page 11 of 28
DIANE G, RADCLIFF
3448 TRINDLE ROAO
CAMP HILL. PA 17011
PHONE: (717)737-0100
FAX, 17171975,0697
bonds, shares of stock, investment plans and life insurance
cash value that is to become the sole and separate property of
the other pursuant to the terms hereof.
lB. WAIVER OF INHERITANCE I
Each of the parties hereto does specifically waive,
release, renounce and forever abandon any right, title,
interest and claim, if any, either party may have in and to
any inheritance of any kind or nature whatsoever previously or
in the future received by the other party,
19. WIFE'S DEBTS.
WIFE represents and warrants to HUSBAND that since the
parties' marital separation she has not contracted or incurred
any debt or liability for which HUSBAND or his estate might be
responsible and WIFE further represents and warrants to
HUSBAND that she will not contract or incur any debt or
liability after the execution of this Agreement, for which
HUSBAND or his estate might be responsible,
WIFE shall
indemnify and save HUSBAND harmless from any and all claims or
demands made against him by reason of debts or obligations
incurred by her,
20. HUSBAND'S DEBTS.
HUSBAND represents and warrants to WIFE that since the
parties' marital separation he has not contracted or incurred
any debt or liability for which WIFE or her estate might be
responsible and HUSBAND further represents and warrants to
WIFE that he will not contract or incur any debt or liability
after the execution of this Agreement, for which WIFE or her
Page 12 of 28
DIANE G, RADCLIFF
3448 TRINDlE ROAO
CAMP Hill. PA 17011
PHONE: (717)737,0100
FAX: (7171975,0697
estate might be responsible. HUSBAND shall indemnify and save
WIFE harmless from any and all claims or demands made against
her by reason of debts or obligations incurred by him,
21. MARITAL DEBT.
It is acknowledged and agreed by the parties that there
are no marital debts for which the parties, either jointly or
individually, are responsible with the exception of the Real
Estate Mortgage governed by the provisions of Paragraph 15
herein.
Any liability not disclosed in this agreement shall be
the sole responsibility of the party who has incurred or may
hereafter incur it, and the party incurring or having incurred
said debt shall pay it as it becomes due and payable. From
the date of this Agreement, each party shall only use those
credit card accounts or incur such further obligations for
which that party is individually and solely liable and the
parties shall cooperate in closing any remaining accounts
which provide for joint liability.
22. BANKRUPTCY:
The parties hereby agree that the provisions of this
Agreement shall not be dischargeable in bankruptcy and
expressly agree to reaffirm any and all obligations contained
herein,
In the event a party files such bankruptcy and
pursuant thereto obtains a discharge of any obligations
assumed hereunder, the other party shall have the right to
terminate this Agreement in which event the division of the
parties' marital assets and all other rights determined by
Page 13 of 28
DIANE Q, RADCLIFF
3448 TRINDlE ROAO
CAMP Hill, PA 17011
PHONE: (7171 737,0100
FAX: (7171975,0697
this Agreement shall be subject to court determination the
same as if this Agreement had never been entered into.
23. SOCIAL SECURITY BENEFITS I
The parties agree that subject to the rules and
regulations of the Social Security Administration, each of the
parties shall continue to be eligible for Social Security
benefits to which he or she would ordinarily be qualified as
a party to a divorce after a marriage of ten (10) years or
more in duration, if the parties' marriage is determined to be
of ten (10) or more years in duration.
24. INCOME TAX PRIOR RETURNS.
The parties have heretofore filed joint federal and state
returns. Both parties agree that in the event any deficiency
in federal, state or local income tax is proposed, or any
assessment of any such tax is made against either of them,
each will indemnify and hold harmless the other from and
against any loss or liability for any such tax deficiency or
assessment therewith, Such tax, interest, penalty or expense
shall be paid solely and entirely by the individual who is
finally determined to be the cause of the misrepresentations
or failures to disclose the nature and extent of his or her
separate income on the aforesaid joint returns,
25. FINAL EQUITABLE DISTRIBUTION OF PROPERTY I
The parties agree that the division of all property set
forth in this Agreement is equitable and in the event an
action in divorce is commenced, both parties relinquish the
right to divide said property in any manner not consistent
Page 14 of 28
DIANE Q, RADCLIFF
3448 TRINDlE ROAD
CAMP Hill. PA 17011
PHONE: 17171737,0100
FAX: 17171975,0697
with the terms set forth herein. It is further the intent,
understanding and agreement of the parties that this Agreement
is a full, final, complete and equitable property division,
26. ~IVER OF ALIMONY. SPOUSAL SUPPORT AND COSTS.
Except as hereafter provided the parties hereto agree and
do hereby waive any right and/or claim they may have, both now
and in the future, against the other for alimony, alimony
pendente lite, spousal support, maintenance, counsel fees and
costs,
Commencing with the date of this Agreement and continuing
monthly thereafter through and including the month of June
2002, or until the death of either party or WIFE'S
Cohabitation or remarriage, whichever shall first occur,
HUSBAND shall pay WIFE alimony in the amount of $750,00 per
month, which amount shall be prorated for any partial month.
The alimony shall be reported by WIFE as income on her
applicable income tax returns and deductible by HUSBAND on his
applicable income tax returns. For all purposes, including
income tax treatment purposes, the payments shall be deemed to
be a periodic payment of alimony between HUSBAND and WIFE
associated with a dissolution of their marriage and pursuant
to a written marital agreement.
It is further understood and agreed that WIFE shall not
owe HUSBAND any child support during the period that alimony
payment is due her, the alimony payments set forth above
having taken into consideration the child support obligation
of WIFE to HUSBAND, In the event HUSBAND seeks and obtains
Page 15 of 28
DIANE Q, RADCLIFF
3448 TRINDlE ROAO
CAMP Hill. PA 17011
PHONE: 1717) 737,0100
FAX, (717) 975.0697
child support during that period that alimony due WIFE from
HUSBAND, the alimony amount heretofore provided shall be
increased by the amount of child support due HUSBAND from WIFE
during the period the child support is owed.
It is further understood and agreed that HUSBAND shall
not owe WIFE any child support during the period that alimony
payments are due WIFE,
27. CUSTODY:
The parties shall share and have joint legal custody of
their minor children, SALLY L. GLATFELTER, born August 2, 1981
and DAVID G, GLATFELTER, born July 27, 1983, (hereinafter
referred to as "the CHILDREN"), Each party shall be entitled
to participate, jointly with the other party, in all major
non-emergency decisions affecting the CHILDREN'S health,
education, religion and general well being. Pursuant to the
foregoing the following shall apply:
a, Each party shall be entitled access to any and all
information,
entities and documentation
persons,
regarding the same so that informed decisions can be
made.
b. Non-major decisions involving the CHILDREN'S day to day
living shall be made by the party then having custody,
but to the extent possible, the parties shall attempt to
make such rules and follow such schedules as would
provide the CHILDREN with continuity in their lives
regardless of the party with whom they are then residing,
Page 16 of 28
DIANE G, RADCLIFF
3448 TRINDlE ROAO
CAMP Hill, PA 17011
PHONE: (717) 737,0100
FAX: 17171975,0697
c, Emergency decisions regarding the CHILDREN shall be made
by the party then having physical custody, but that party
shall communicate to the other party the nature and
extent of the emergency within a reasonable period of
time and shall provide that other party with all
information pertaining to the treatment so that the other
party may be involved in the decision making process at
the earliest possible time,
d. Upon receipt by a party, copies of the CHILDREN'S school
schedules, special events notifications, report cards and
the like shall be provided to the other party, Each
party shall share with the other party any other
information and documentation, or copies thereof, that
each party possesses regarding the CHILDREN within such
reasonable time as to make the records and information of
reasonable use to the other party,
e, Each party shall provide the other party with at least 48
hours advance notice of school or other activities
whenever possible.
f, Neither party shall utilize the CHILDREN for purposes of
conveying information or inquiries pertaining to the
CHILDREN to the other PARENT,
g, Each party shall notify the other party of any medical,
dental, optical and psychological appointments and/or
treatment for the CHILDREN sufficiently in advance
thereof so that the other party can attend.
Page 17 of 28
OlANE G, RADCLIFF
3448 TRINDlE ROAO
CAMP Hill. PA 17011
PHONE: (717)737.0100
FAX: (7171975,0697
h, Both parties shall be afforded reasonable telephone
contact with the CHILDREN while in the other party's
custody, For purposes of this Paragraph the term
"reasonable" shall be defined as meaning any times the
CHILDREN desire to initiate telephone contact and a
minimum of two (2) times per week for telephone calls
initiated by a party.
HUSBAND shall have primary custody of the CHILDREN, subject
to liberal and reasonable rights of partial custody at such
times as the CHILDREN and WIFE shall mutually agree,
28. CHILD SUPPORT,
There shall be no child support owed by WIFE to HUSBAND,
WIFE'S support obligation having been taken into consideration
in fashioning the amount of alimony set forth in Paragraph 26
herein, incorporated by reference hereto. Further there shall
be no child support owed by HUSBAND to WIFE during the period
that alimony payments are due WIFE pursuant to the terms of
Paragraph 26 herein,
29. PERSONAl, RIGHTS,
HUSBAND and WIFE may and shall, at all times hereafter,
live separate and apart, They shall be free from any control,
restraint, interference or authority, direct or indirect, by
the other in all respects as fully as if they were unmarried,
They may reside at such place or places as they may select,
Each may, for his or her separate use or benefit, conduct,
carryon and engage in any business, occupation, profession or
employment which to him or her may seem advisable, HUSBAND
Page 18 of 28
DIANE Q, RADCLIFF
3448 TRINDLE ROAD
CAMP HILL, PA 17011
PHONE: 1717)737,0100
FAX: (717)975,0697
and WIFE shall not molest, harass, disturb or malign each
other or the respective families of each other nor compel or
attempt to compel the other to cohabit or dwell by any means
or in any manner whatsoever with him or her,
30. MUTUAL RELEASEB.t
HUSBAND and WIFE each do hereby mutually remise, release,
quitclaim and forever discharge the other and the estate of
such other, for all time to come, and for all purposes
whatsoever, from any and all rights, title and interests, or
claims in or against the property (including income and gain
from property hereafter accruing) of the other or against the
estate of such other, of whatever nature and wheresoever
situate, which he or she now has or at any time hereafter may
have against such other, the estate of such other or any part
thereof, whether arising out of any former acts, contracts,
engagements or liabilities of such other or by way of dower or
curtsey, or claims in the nature of dower or curtsey or
widow's or widower's rights, family exemption or similar
allowance, or under the intestate laws, or the right to take
against the spouse's will; or the right to treat a lifetime
conveyance by the other as testamentary, or all other rights
of a surviving spouse to participate in a deceased spouse's
estate, whether arising under the laws of (a) the Commonwealth
of Pennsylvania, (b) State, Commonwealth of territory of the
United States, or (c) any other country, or any rights which
either party may have or at any time hereafter have for past,
present or future support or maintenance, alimony, alimony
Page 19 of 28
DIANE G, RADCLIFF
3448 TRINDlE ROAD
CAMP Hill. PA 17011
PHONE: (7171737,0100
FAX, (7171975,0697
pendente lite, counsel fees, equitable distribution, costs or
expenses, whether arising as a result of the marital relation
or otherwise, except, any only except, all rights and
agreements and obligations of whatsoever nature arising or
which may arise under this Agreement or for the breach of any
provision thereof, It is the intention of HUSBAND and WIFE to
give to each other by the execution of this Agreement a full,
complete and general release with respect to any and all
property of any kind or nature, real, personal or mixed, which
the other now owns or may hereafter acquire, except and only
except, all rights and agreements and obligations of
whatsoever nature arising or which may arise under this
Agreement or for the breach of any provisions thereof,
31. WAIVER OR MODIFICATION... TO BE IN WRITING.
No modification or waiver of any of the terms hereof
shall be valid unless in writing and signed by both parties
and no waiver of any breach hereof or default hereunder shall
be deemed a waiver of any subsequent default of the same or
similar nature,
32. MUTUAL COOPERATION:
Each party shall, at any time and from time to time
hereafter, take any and all steps and execute, acknowledge and
deliver to the other party, any and all further instruments
and/or document that the other party may reasonably require
for the purpose of giving full force and effect to the
provisions of this Agreement.
Page 20 of 28
DIANE G, RADCLIFF
3448 TRINOlE ROAD
CAMP HilL. PA 17011
PHONE: 17171 737-0100
FAX: (7171975-0697
33. AGREEMENT BINDING ON HEIRSI
This Agreement shall be binding and shall inure to the
benefit of the parties hereto and their respective heirs,
executors, administrators, successors and assigns.
34. INTEGRATION:.l.
This Agreement constitutes the entire understanding of
the parties and supersedes any and all prior agreements and
negotiations between them, There are no representations or
warranties other than those expressly set forth herein.
35. OTHER DOCUMENTATION.
WIFE and HUSBAND covenant and agree that they will
forthwith (and within at least twenty (20) days after demand
therefor) ,
execute any and all written instruments,
assignments, releases, satisfactions, deeds, notes, stock
certificates, or such other writings as may be necessary or
desirable for the proper effectuation of this Agreement, and
as their respective counsel shall mutually agree should be so
executed in order to carry out fully and effectively the terms
of this Agreement,
36. NO WAIVER OF DEFAULT.
This Agreement shall remain in full force and effect
unless and until terminated under and pursuant to the terms of
this Agreement, The failure of either party to insist upon
strict performance of any of the provisions of this Agreement
shall in no way affect the right of such party hereafter to
enforce the same, nor shall the waiver of any subsequent
default of the same or similar nature, nor shall it be
Page 21 of 28
DIANE Q, RADCLIFF
3448 TRINDLE ROAD
CAMP HILL. PA 17011
PHONE: 17171737,0100
FAX; 17171975,0697
construed as a waiver of strict performance of any other
obligations herein,
37. BREACH.
If for any reason either HUSBAND or WIFE fails to perform
his or her obligations owed to or for the benefit of the other
party and/or otherwise breaches the terms of this Agreement,
then the other party shall have the following rights and
remedies, all of which shall be deemed to be cumulative and
not in the alternative, unless said cumulative effect would
have an inconsistent result or would result in a windfall of
the other party.
a. the right to specific performance of the terms of this
Agreement, in which event the non-breaching party shall
be reimbursed for all reasonable attorney's fees and
costs incurred as the result of said breach and in
bringing the action for specific performance,
b. the right to damages arising out of breach of the terms
of this Agreement, which damages shall include
reimbursement of all attorney's fees and costs incurred
as the result of the breach and in bringing the damage
action.
c. the right to all remedies set forth in Section 3502(e) of
the Pennsylvania Divorce Code, 23 Pa. C,S.A, 3502(e), and
any additional rights and remedies that may hereafter be
enacted by virtue of the amendment of said Sections or
replacement thereof by any other similar laws.
d. Any other remedies provided for in law or in equity.
Page 22 of 28
DIANE Q, RAOClIFF
3448 TRINDlE P.OAD
CAMP Hill. PA 17011
PHONE: (717) 737.0100
FAX: 17171975,0697
38. LAW OF PENNSYLVANIA APPLICABLE.
This Agreement shall be construed in accordance with the
laws of the Commonwealth of Pennsylvania.
39. SEVERABILITY:
If any term, condition, clause or provision of this
Agreement shall be determined or declared to be void or
invalid in law or otherwise, then only that term, condition
clause or provision shall be stricken from this Agreement and
in all other respects this Agreement shall remain valid and
continue in full force, effect and operation. Likewise, the
failure of either party to meet his or her obligations under
this Agreement under anyone or more of the paragraphs
hereunder, with the exception of the satisfaction of a
condition precedent, shall in no way avoid or alter the
remaining obligations of the parties.
40. HEADINGS NOT PART OF AGREEMENT.
Any headings preceding the text of the several paragraphs
and subparagraphs hereof, are inserted solely for convenience
of reference and shall not constitute a part of this Agreement
nor shall they affect its meaning, construction or effect,
BY SIGNING THIS AGREEMENT, EACH PARTY
ACKNOWLEDGES HAVING READ AND UNDERSTOOD
THE ENTIRE AGREEMENT, AND EACH PARTY
ACKNOWLEDGES THAT THE PROVISIONS OF THIS
AGREEMENT SHALL BE AS BINDING UPON THE
Page 23 of 28
DIANE G. RADCLIFF
3448 TRINDLE ROAD
CAMP HILL. PA 17011
PHONE: (717)737.0100
FAX: (7171975.0697
. . . .
..
DISTRIRUTION OF MARITAL ASSETS AND DERTS
DESCRIPTION TOTAL VALUE HUSBAND VALUE WIFE VALUE
REAL ESTATE
5243 MEADOW BROOK DR. 130,000.00 130,000.00
MECHANICS BURG PA
CONTINENTAL CAPITAL -50,232.31 -50,232.51
MTG. ON MARITAL HOME
212 N. HIGHLAND DR. UNKNOWN UNKNOWN
SHREWSBURY PA.
(1/5TH INTEREST)
VEHICLES
1986 HONDA ACCORD TO BE TO BE
OFFSET OFFSET
1988 HONDA CIVIC TO BE TO BE OFFSET
OFFSET
BANK ACCOUNTS
PNC JT. CHECKING 1,599.07 1,599.07
ACCOUNT
HARRIS H'S CHECKING 3,191.57 3,191.57
ACCOUNT
PNC W'S CHECKING 4,546.50 4,546.50
ACCOUNT
PENSION AND RETIREMENT
PLANS
H' S GANNETT FLEMING TO BE TO BE DIVIDED TO BE
PENSION DIVIDED EQUALLY AT DIVIDED
EQUALLY AT RETIREMENT EQUALLY AT
RETIREMENT BASED ON RETIREMENT
BASED ON MARITAL BASED ON
MARITAL COVERTURE MARITAL
COVERTURE FRACTION COVERTURE
FRACTION FRACTION
Page 27 of 28
DIANE G. RADCLIFF
3448 TRINDLE ROAD
CAMP HILL. PA 17011
PHONE: (7171737.0100
FAX: (7171975.0697
l . . .
. "
H'S GANNETT FLEMING 17,511.99 17,511.99
401 KPLAN
H'S .JACKSON NATIONAL 18,779.66 18,779.66
LIFE IRA ACCOUNT NO.
003667700
LIFE INSURANCE AND
ANNUITIES
H' S PENN MUTUAL LIFE 23,509.77 23,509.77
INS. POLICY NO.
7150215
H'S JACKSON NATIONAL 20,551. 20 20,551.20
LIFE ANNUITY POLICY
NO. 0031746660
WIFE'S JACKSON 2631. 63 2631.63
NATIONAL LIFE INS.
POLICY NO 0007847730
HOUSEHOLD GOODS
H'S HOUSEHOLD GOODS DIVIDED BY DIVIDED BY
AGREEMENT AGREEMENT
W'S HOUSEHOLD GOODS DIVIDED BY DIVIDED BY
AGREEMENT AGREEMENT
DEBTS I
NONE
TOTALS EXCLUSIVE OF 172089.08 164910.75 7178.13
PENSION
AMOUNT DUE BASED ON -86044.54 -86044.54
50/50 DIVISION
CASH ADJUSTMENT 78866.21 -78866.41
NECESSARY FOR 50/50
DIVISION
Page 28 of 28
.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MARY E. GLATFELTER,
Plaintiff
NO. 97-2899
CIVIL ACTION - LAW
IN DIVORCE
V.
DALE R. GLATFELTER,
Defendant
PRAECIPE OF TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the
court for entry of a divorce decree:
1. Ground for divorce:
Irretrievable breakdown under Section 3301 (c)of the Divorce Code.
2.
Date
a.
b.
and manner of service of the complaint:
Date: 6/4/97
Manner: Certified, Restricted Delivery
3.
Date
3301
a.
b.
of execution of the affidavit
(c) of the Divorce Code:
Plaintiff: 1/14/99
Defendant: 1/4/99
of consent required by Section
OR
Date of execution of the Plaintiff's affidavit required by Section
3301(d) of the Divorce Code and date of service of the Plaintiff's
3301 (d) affidavit upon the Defendant:
a. Date of execution: n/a
b. Date of filing: n/a
c. Date of service: n/a
4. Related claims pending: No issues are pending. All issues have been
resolved pursuant to the Marriage Settlement Agreement between the
parties dated 1/4/99 which Agreement is to be incorporated into but
not merged with the Divorce Decree.
5. Date and manner of service of the Notice of Intention to file
Praecipe to Transmit Record, a copy of which is attached, if the
decree is to be entered under Section 3301(d) (I) (i) of the Divorce
Code:
a. Date of Service: n/a
b. Manner of Service: n/a
OR
Date Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary:
a. Plaintiff's Waiver: 1/15/99
b. Defendant's Waiver: 1/15/99
, ESQUIRE
le Road
Cam . PA 17011
reme Court ID # 32112
Phone: (717) 737-0100
Fax: (717) 975-0697
Attorney for Plaintiff
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AtTORNEY-AT-LAW
,... TRINOI.E ROAD
CAMP lUll.. PA 17011
"
annulment between the parties.
6. Plaintiff has been advised of the availability of
counseling and the right to request that the Court require
the parties to participate in counseling.
7. The Defendant is not a member of the Armed Services
of the United States or any of its Allies.
8. The Plaintiff avers that the grounds on which the
action is based are:
(a) That the marriage is irretrievably broken.
Or in the alternative,
(b) That the marriage is irretrievably broken and
the parties are now living separate and
apart, and at the appropriate time, Plaintiff
will submit an Affidavit alleging that the
parties have lived separate and apart for at
least two (2) years and that the marriage is
irretrievably broken.
WHEREFORE, Plaintiff requests this Honorable Court to
enter a decree in divorce, divorcing the Plaintiff and
Defendant.
COUNT II: EOUITABLE DISTRIBUTION
9. Paragraphs 1 through 8 are incorporated by
reference hereto as fully as though the same were set forth
at length.
10. Plaintiff and Defendant have acquired property and
DIANE G. RADCLIFF
AtTORNEY,AT,LAW
'ffA TRINOLE ROAD
CAMP 11I1.1., PA 17011
"
debts, both real and personal, during their marriage from
July 16, 1977 until the date of separation, all of which is
"marital property".
ll. Plaintiff and/or Defendant have acquired, prior to
the marriage or subsequent thereto, "non-marital property"
which has increased in value since the date of marriage
and/or subsequent to its acquisition during the marriage,
which increase in value is "marital property".
l2. Plaintiff and Defendant have been unable to agree
as to an equitable division of said property as of the date
of the filing of this Complaint.
WHEREFORE, Plaintiff requests this Honorable Court to
equitably divide all marital property and debts of the
parties.
COUNT III: ALIMONY PBNDBNTB LITB. ALIMORY
l3. Paragraphs 1 through 12 are incorporated by
reference hereto as fully as though the same were set forth
at length.
l4. Plaintiff lacks sufficient property to provide for
her reasonable means and is unable to support herself though
appropriate employment.
l5. Plaintiff requires reasonable support to adequately
maintain herself in accordance with the standard of living
established during the marriage.
WHEREFORE, Plaintiff requests this Honorable Court to
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DIANE G, RADCLIFF
3448 TRINDLE ROAD
CAMP HILL. PA 17011
PHONE (717)737.0100
ID # 32112
, -
'.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MARY E, GLATFELTER,
Plaintiff
V.
DALE R, GLATFELTER,
Defendant
NO,97-2899 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
QUALIFIED DOMESTIC RELATIONS ORDER
')~ "" ~.. . .-
AND NOW, this (T day of -fJ'" , 1999, upon
consideration of the within Stipulation of the parties and their
Marriage Settlement Agreement dated January 4, 1999, pertaining to
Dale R, Glatfelter's interest in the Gannett Fleming, Inc" Pension
Plan, the following is HEREBY ORDERED AND DECREED.
A, Background Information:
1. Plan Participant:
Name:
Address:
Date of Birth:
SSN:
2, Alternate Payee
Name:
Address:
Date of Birth:
SSN:
3, Name of Plan/Retirement
Account to which this
Order Applies:
Dale R, Glatfelter
5243 Meadowbrook Drive
Mechanicsburg, PA 17055
March 23, 1952
183-42-1224
Mary E, Glatfelter
104 South 16~ Street
Camp Hill, PA 17011
April 30, 1953
158-44-6770
Gannett Fleming, Inc,
Pension plan
DIANE G, RADCLIFF
3448 TRINDLE ROAD
CAMP HILL. PA 17011
PHONE (717)737.0100
ID#32112
, -
"
2,
The foregoing has been acknowledged and agreed upon by
the parties to represent the Alternate Payee's interest
in the marital portion of the Plan Participant's pension
accruing from the date of marriage to the date of the
parties separation,
The Plan Participant shall be entitled to all other
retirement benefits remaining after the payment to the
Alternate Payee of her distributive share in accordance
with the provisions of Paragraph 1 above,
The Plan Participant and the Alternate Payee shall each
be required to pay any and all taxes associated with the
payment and receipt of his or her portion of the
retirement benefits and shall be subject to all
applicable withholding taxes,
The above payment shall commence as of the date the Plan
Participant retires and first becomes eligible for
payments under the Plan and, except as otherwise herein
provided, shall continue until the death of the Plan
Participant,
In the event the Alternate Payee shall predecease the
Plan Participant, any sums due the Alternate Payee
hereunder shall be paid instead to her personal
representative or heirs,
This is a property distribution order made in and under
the Divorce and Equitable Distribution statutes of the
Commonwealth of Pennsylvania, and in accordance with the
provisions of such statute, the portion being distributed
to the Alternate Payee has been determined to be her
property.
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RECEIVED APR 151005
Mary E, Glatfelter, now by resumption of
former name, Mary E, Lodge,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CilllBERLAND COUNTY. PENNSYLVANIA
CIVIL ACTION - LA \V
v,
Dale R, Glatfelter,
Defendant ,.
NO, !l7,2R!l!J
QUALIFIED DOMESTIC RELATION!; ORDER
1. This Order relates to the provision of marital property rights to the Alternate Payee as
a result of a Marriage Settlement Agreement between the Participant and the Alternate Payee
entered into on .January 4, 1!l9!l.
2. 'rhis Order creates and recognizes the existence of on Altemate Payee's right to r~ceive
a portion of the Participant's benefits payable under an employer sponsored defined benefit plan
which is intended to be qualified under Internnl Revenue Code of 1986 ("Code") ~40l(a). The court
intends this order to be a Qualified Domestic Relations Order ("QDRO") within the meaning of
Code ~4l4(pl. The Court enters this QDRO pursuant to its authority under the 23 P,C.S,A. ~3502,
3. This QDHO applies to the Gannett Fleming, Inc. Pension Plan ("Plan"), Further, this
Order shall apply to any successor plnn to the Plan or any other plan(s) to which liability for
provision of the Participant's benefits described below is incurred, Any benefits accrued by the
Participant under a predecessor plan of the employer or any other defined benefit plan sponsored
by the Participant's employer. whereby Iinbility for benefits accrued under such predecessor plan
or other defined benefit plnn has been transferred to the Plan, shall also be subject to the terms of
this order, Any changes in Plan Administrator, Plan sponsor, or name of the Plan shall not affect
Alternate Payee's rights as stipulated under this Order.
4. Dale R. Glatfelter ("Participnnt") is a participant in the Plan. Mary E. Glatfelter
("Alternate Payee"), the former spouse, is the alternate payee for purposes of this QDRO,
5. The Participant's nome, mailing address, social security number and date of birth are:
Dale R. Glatfelter
5243 Meadowbrook Dl'ive
Mechanicsburg. PA 17055
Social Security #: 183-42-1224
Date of Birth: March 2:1, 1952
6. The Alternate Payee's name, mailing address, social security number and date of birth
arc:
Mary E, Lodge
2208 Goldenrod Street
Ferndale, WA 98248
Social Security #: 158'44-6770
Date of Birth: April 30, 1953
QDHO
Puge 2
The Alternute Puyee shull huve the dut)' to notify the Plun Administrator in writing of
uny changes in this muiling nddress subsequent to the entry of this Order,
7. This Order assigns to Alternute Puyee un IImount equnl to the IIctuarinl equivalent of
50% of the marital portion of the Pllrticipllnt's accrued benefit under the Plan liS of the earlier of
his dllte of cessation of benefituccrunls or the dute thnt the Alternate Pllyee commences her
benefits hereunder, '{'he maritlll portion of the Pnrticipnnt's IIccrued benefit shall be determined
by multiplying the Pllrticipnnt's accrued benefit by a frnction <less thlln or equal to 1.0), the
numerator of which is the totlll number of months of the Participllnt's purticipation in the Plan as
of September 9, 1997, the date of sepllration, and the denominutor of which is the totul number of
months of the Purticipant's participation in the PI un us of the curlier of his date of cessation of
benefit accruals or the dllte thut the Alternate Payee commences her benefits hereunder,
In addition to the IIbove, the Alternute Puyee shllll receive II pro ruta share of any
postretirement cost,of-living adjustments or other economic improvements mude to the
Purticipant's benefits on or ufter the date of his retirement. Such pro rnta shure shall be
calculated in the same manner us the Alternute Payee's shllre of the Participant's retirement
benefits is calculated pursuant to this Section 7,
Notwithstanding the lunguage set forth in this Section 7, in the event that the
Alternate Payee becomes entitled to a quulified preretirement survivor annuity under Section 9 of
this Order, then the Alternate Payee's right to a share of the Participunt's benefits as called for
under this Section 7 shall be terminated as of the date of the Participant's death, and the
Alternate Payee shall receive her designated portion of such preretirement death benefit in lieu of
any other benefits to which she may be entitled under the terms of this Order,
8. The Alternate Payee may elect to commence her benefits under the Plan at aay time on
or after the date the Participant attains the earliest retirement age as defined by Code
9414(p)(4)(B). Further, in the event the Participant becomes eligible to commence benefits at an
earlier date as the result of a disability retirement, the Alternate Payee shall ulso be entitled to
commence her share of the benefits at such earlier dute, Notwithstunding the above, the
Alternute Payee shall commence her shure of the benefits no lute I' thun the Participant's uctual
dute of benefit commencement, The Plan Administrator is instructed to provide any required
notice and election forms in a timely manner to the Alternate Payee before such date of benefit
commencement.
The Alternate Payee shull be entitled to receive her benefits in any fonn available
under the terms and provisions of the Plan, other than a quulified joint and survivor unnuity with
u subsequent spouse as the survivor annuitunt. The Alternute Payee shull execute any fonns
required by the PI un Administrutor.
The form of benefits paid to the Alternute Payee shull be based on the life expectuncy of
the Alternate Puyee. Any actunrial reduction thut might be necessary to convert Alternute
Payee's benefits to one based on the Alternate Payee's lifetime shall be borne by the Alternate
Puyee. Further, should any curly commencement reduction be necessury in the event that the
Alternate Payee commences her benefits prior to Participant's Nonnal Retirement Dute, then
such reduction shall be applied to Alternate Payee's benefits.
Qono
Puge 3
The Alternate Payee shull be entitled to a pro rata share of any enrly retirement
subsidy (including any tempornry or supplemental benefits) provided under the Plnn to the
Pnrticipant on the date of his retirement, and in the e\'ent the Alternnte Payee has already
commenced her share of the benefits on the dnte of the Pnrticipnnt's retirement, then the nmounts
payable to the Alternate Payee shall be recnlculnted in nccordnnce with the Plan Administrator's
pructices nnd the Plan's actunrinl principles in ordel' to pl'llvide the Alternate Pnyee with the pro
rutn share of such early retirement subsidy, Such pro mtn share shull be cnlculnted in the snme
mnnner ns the Alternnte I'nyee's share ofthc Pnrticipnnt's retirement bencfits is calculated
pursuant to Section 7 of this Order.
9, In the event the Pnrticipnnt predeccases the Alternnte Payee, and neither the
Participant nor the Alternate Payee hns commenced their benefits under the Plan, the Alternate
Payee shall be designated as the surviving spouse of the Partici pant for the purposes of
establishing the Alternate Payec's entitlement to receipt of her proportionate share of the
preretirement survivor annuity as set forth herein, For purposes of determining the eligibility for
such surviving spouse benefit, the Alternate Payee and the Participant havc satisfied the one (1)
year marriage requirement as enumerated in Codc **401(a)(11) and 417(d) and as may be
required under the provisions of the Plan.
Alternate Payee's share of any preretirement survivor nnnuity shall be calculated
according to the formula as sct forth in Section 7. In the event that the costs associated with
providing the Alternate Payee's share of the preretiremcnt survivor annuity benefit are not fully
subsidized by the Participant's employer, the Participant must make an affirmative election for
such preretirement survivor annuity benefit coverage in a timely manner and in accordance with
the Plan's election procedures,
Further, if the Plan provides for any death benefit in excess of a qualified preretirement
survivor annuity, the Alternate Payee shall be designated as the beneficiary with respect to the
Alternate Payee's share of the excess death benefit payable.
10, If Alternate Payee predeceases Participant before her benefit commencement date, her
assigned share of the benefits shall revert to the Participant, but only to extent permitted under
the terms of the Plan. Should the Alternate Payee predecease the Participant after her benefit
commencement date, then such remaining benefits, if any, will be paid in accordance with the
form of benefit elected by such Alternate Payee,
11. On and after the date that this order is deemed to be a QDRO, but before the Alternate
Payee receives her distribution under the Plan, the Alternate Payee shall be entitled to all of the
rights and election privileges that arc afforded to active participants.
l2. All payments made pursuant to this order shull be conditioncd on the certification by
the Alternate Payee and the Participant to the Plan Administrator of such information as the
Plan Administrator may rensonnbly require from such pnrties, including the information the Plan
Administrator requircs to muke thc necessnry culculntion of the benefit amounts contained
herein.
13. It is the intcntion of the pnrties thut this Order continue to quulify us u Qono under
Code *414(p), as it may be umendcd from time to time,und thnt the Plnn Administrntor shnll
..
QORO
Page 4
reserve the right to reconfirm the qualified stntus of the order at the time benefits become payable
hereunder,
14. In the event that the Plnn inndverlenlly pn~'s 10 the Participant any benefits thnt nre
assigned to the Alternute Payee pursunnt to the terms of this order. the Pnrticipnnt shull
immediately reimburse the Alternnte Payee to the extent thnt he hns received such benefit
payments and shull forthwith pny such amount so received directly to the Alternnte Payee within
ten (10) days of receipt.
In the event that the Plan inadvertently pays 10 the Alternate Puyee any benefits that
arc assigned to the Participant pursuant to the terms of this order, the Alternate Payee shall
immediately reimburse the Participnnt to the extent that she hus received such benefit payments
and shall forthwith puy such amount so received directly to the Purticipant within ten (10) days of
receipt.
15. The Participant shall not tuke any uctions, affirmative or otherwise, that can
circumvent the terms and provisions of this QORO, or that could diminish or extinguish the rights
and entitlements of the Alternate Puyee as set forth herein, Should the Participant take any
action or inaction to the detriment of the Alternute Payee, he shall be required to make sufficient
payments directly to the Alternate Payee to the extent necessary to neutralize the effects of his
actions or inactions and to the extent of the Alternate Payee's full entitlements hereunder,
16. In the event that the Purticipunt's benefits, or uny portion thereof, become payable to
the Participant as u result of Plun termination or partial Plun termination, then the Alternate
Puyee shall be entitled to commence her benefits immediately in accordance with the terms of this
QORO and in accordance with the termination procedures of the Plan and the Pension Benefit
Guaranty Corporation ("PBGC"), Further, should the Participant's benefits be reduced as a result
of such termination or purtial terminntion, then the amounts otherwise payable to the Alternate
Payee under this QORO shall be reduced to the same extent and in the same ratio as the
Participunt's benefits arc reduced.
17, After payment of the amount required by this QORO, the Alternate Payee shall have no
further c1nim against the Participunt's interest in the Plan or the Plnn.
18. The Alternute Pnyee assumes sole responsibility for the tax consequences of the
distribution under this QORO.
19. This QORO docs not require the Plan to provide any type or form of benefit the Plan
docs not otherwise provide.
20. This QORO docs not require the Plnn to provide increased benefits determined on the
basis of actuarial value.
21. This QORO docs not require the Plan to pay any benefits which another order
previously determined to be a qualified domestic relntions order requires the PI un to pay to
another alternate payee.
22. The Plan Administrator promptly shall notify the Pnrticipant and the Alternate Puyee
(lfthe receipt of this QOHO nnd shall notify the Purticipuntand the Alternnte Puyee of the Plan's
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