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years, il will then be sold with David Bellon receiving Ihe proceeds of any sale and
being responsible for any shortfnllto cover the existing mortgage on Ihal property.
3. The equity in the Pennsylvania house, aOer payment of costs associated with
the sale, will leave the parties with approximately $42,600, Husband's half of this
amount, 821,300 shall be reduced by one-half the equity of the North Carolina home.
The equity in the North Carolina home totals 822,751. (fhis is based upon the
combined amounl of the value of Ihe property, less real estate commission and lransfer
tax costs if the home were to be sold, and less the current mortgage on the home. The
bank account balance at 88&T is also included in Ihis value.) Deducting one-half
this amount, 811,375,lhe remaining balance to be credited to Husband, 89,925, shall
not be paid out by deduclion from Wife's half of distribution of Husband'1l40lk plan.
4. Husband's 401k plan will be divided as follows. The value of the plan as
of dale of separation was 853,260. The date of separation value has grown to
868,548, but 85,300 of Ihis renects employec and employer contributions since the
separation. The amount 10 be divided is therefore 863,248. Thill amount ill to be
divided equally by the partiell. Wife'lI half is therefore 831,624. To he off.et a88iMt
this amount, to be distributed to Wife, is $9,925. Also to be offset againstlhill amount
is 85,000, representing one-h. If of \l'ife's 401k. This leavetl Wife'. interett in the
4011. at 816,699, 10 tIC lrantferred 10 her OIl March 6, 1998 by 8 Qualified Domeslic
2
Relations Order. Husband shull he responsihle for tllking stepllneeessary toward Ihe
establishment of a proper QDlW.
5. Various cash assets exisl us followll:
a. Harris savings slock: 300 shares, currently valued al 85,850. Wife's
one-half interest and Husband's one.half inlcrest are each valued 82,925.
b. Pulnam IRA, currently valued al 82,386. Husband shall retain this
assel.
c. Delaware IRA, valued at 84,662. Husband shall retain this asset.
6. Husband will transfer to Wife all of his interest in the Harris Savings slock.
This will have the value of a cash transfer of 55,850. This amount will be offset
against Wife's one-half interest in the PP&L stock. The PP&L stock is currently
valued at 532,185. Wife's one-half interest of 816,092 will be reduced by 85.850,
leaving Wife wilh a value of 810,142 of PP&L stock, to be transferred to her on
March 6, 1998.
7. Each party will retain and be full owner of any savings, checking or other
cash accounts currently in his or her own name.
8. Each party will retain Ihe vehicle currently in hi. or her own poasealion,
and each party will maintain sole respOIljibility for payment of any finaneill!
connected with hi. or ber respective vehicle.
3
.
Any other items of personal property shall remain the sole possession of the
party currcnlly possessing Ihat property.
11. Husband shall pay Wife a lump 8um property selllemenl of 812,000. on
or before March 6, 1998. While this distribution is a property selllement, not
alimony, Wife agrees nol to assert any claim for alimony, in exchange for this
distribution.
12. On March 6,1998, Husband and Wife will each sign affidavits consenling
to a divorce.
13. The parties agree thai in the event of absolute divorce between them, they
shall nonetheless continue to be bound by all the tentls oflhis Agreement, and neither
this Agreement, nor the tentls hereof, shall be deemed to have been merged in any
decree or judgment granled in the divorce action, but shall survive and be forever
binding upon the parties.
14. Each of the parties shall, from time to time at the n.'quest of each other,
execute, aclmowled8C and deliver to the other party any and all further instrwnenla
that may reasonably be required in orner to give full force and elTeclto Ihe provi.ions
of this Apeement.
15. Each party hereto II"'" thai he or .he .hall individually be responsible
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for any and all counsel fees and expenses incurred by him or her in connection with
Ihe prepamlion of this Agreement and the divoree between the parties.
16. Except as provided for in this Agreement, the parties hereby remise,
release, quit-claim and forever discharge each other and the estate of each other, for
all time 10 come, and for all purposes whatsoever, from any and every claim, including
alimony, alimony pendente lite, equitable distribution of marital property, counsel fees
or cosls under the Divoree Refonn Act or spousal support, or otherwise,lhat they make
or hereafter make in and to or against each other's estates or any parts thereof,
whether by way or dower or curtesy, or under the intestate laws, or the right to take
or elect against the other's will, except only such rights as accrue pursuant to this
Agreement.
17. The failure of either party to insist in anyone or more instances upon the
strict perfonnance of any of the tenns hereof in this Agreement shall not be construed
as a waiver or relinquishment of such tenn or tenns in the future.
18. In the event that either party breaches any provision of Ihis Agreement, he
or she shall be responsible for any and all costs incurred 10 enforce the Agreement,
including, but not limited to, court costs and counlSCl fees of the other party. In the
event of breach, the other party shall have the right, at his or her election, to sue for
damages for such breach or to seek such other and additional remedies al may be
6
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
On thiB, th~~y -:;J;;~cj
SS:
, 1998, before me, a Notary Public in and for
..
the aforeB8id Commonwealth and County, personally appeared B. DAVID BETTON,
known to me, or utiBfactorily proven, to be the person whose name iB Bubscribed to
the within inBtrument and acknowledged that he executed the same for the purpose
therein contained,
IN WITNESS WHE
to set my hand and official seal.
y. JC'f~
c.- -, ICIIO." JND co. N
lftCOlr1l1l C,,-.NOI- -t._
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ss:
On thia, the~daY of ~ 1998, before me, a Notary Public in and for
the aforesaid Commonwealth and County, penonally appeared MARTHA J. BETTON,
known to me, or aatiafactorily proven, to be the penon whose name is lubec:ribed to
the within inBtrument and acknowledged that ahe executed the aame for the purpoae
therein contained.
IN WITNESS WHEREOF, I hereunto aet my hand and official aeal.
My Commiaion Eapirea:
NlllA11lAl SlAl
SHEW 0 SlIT~ NllfAll'lPUalC
CAIllISlI llOIlO. ~ COUlI1Y
II1~N'l' ,mU'llllK.'.
\It!llOel, "'~ta AsIO(II1IIIIl III.......
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7, Alternall! Payee ~hall 1'l'l'L,jl'e :1,1/, ,hil' es 0(' t h.. 1'1'&1. ~tock held III the
Employ,." Stock Own"r~hip Plan.
8, Alternate Payee shall receive $16,Il!lU from the Employee Savings Plan, This
a1lluunt shall be placed in u ~..greguted account within the I'P&L Plan, in the
Alternate Payee's name und shall accrue any interest, dividends. and growth, effective
!'Ilarl'h G, 1!.l98, und 1'l'lIlain H'gl'l'l'alt.d frolll I h" ".'count of the Participant.
!l, The distrihuI ion 10 AllI'rnalt' I'an'e Ir"lll the 1';:-;01' and ESP shall he mad..
a~ ~o"lI as admilliHrati\'e1y 1Il""'!,,'a!'!,. ft.tl"wil1;' the I'lan's dl'tl'rllllllation that thi,
Order is a Qualified D01llestic Helations Order,
10, Participant's death shall haw no "''fect on payment of Alternate Payee's
hl'nefit under the ESOP or i':~;p.
11. In the event the Alternate Pay!'e dib ,"efore the Alternate Payee's henefit
is paid, the benefit shall be paid in accordance with the applicable Plan provisions
regarding payments to beneficiaries, including payments when no beneficiary is
designated. The Alternate I'uyee shall he 1'lIlitled to name a beneficiary (or
beneficiaries) to receive the unpaid balance of the benefits, The death of Alternate
Payee before the Plan determines that this is a (~ualified Domestic Relations Order
shall not effect the right of Alternate Payee's beneficiary to benefits from the Plan.
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MARTHA J. BETTON,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
v.
BRUCE D. BETTON,
Defendant
:CML ACTION. LAW
:NO. 97-4218 CML TERM
:IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE
UNDER t SSOl(c) OF THE DIVORCE CODE
1. I consent to the entry of a fmal decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of
property, lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered
by the Court and that a copy of the decree will be sent to me immediately after it is
filed with the prothonotary.
I verifY that the statements made in this affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
t 4904 relating to unsworn falsification to authorities.
Date: ~(t h~
..,
......~;.#~!.
BRUCE D. BETl'ON
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MARTHA J. BETTON,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY. PENNSYLVANIA
v.
,
.
:CML ACTION. LAW
:NO, 97-4218 CML TERM
:IN DIVORCE
BRUCE D. BETTON.
Defendant
ADDENDUM TO SEPARATION AGREEMENT
We. BRUCE D, BETTON and MARTHA J, BETTON, ask that the attached
Qualified Domestic Relations Order be entered as an Order of Court.
Date~~d r~l4~
B. DAVID BETTON
~~
SAMUEL W. MILKES, ESQ.
Date:~fif ~~.-~~r
P&~ /J6~
I:"'" {? it,
J. HfS:~
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MARTHA J. BETTON,
Plaintifl'
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
v.
,
:CML ACTION. LAW
:NO. 97.4218 CML TERM
:IN DIVORCE
BRUCE D. BETTON,
DeCendant
QBDE.B
IT IS ORDERED, ADJUDGED, AND DECREED:
1. Bruce D. Betton, DeCendant, date oCbirth 4/2/47, (Social Security Number
165-38-0468), hereinafter reCerred to 88 "Participant" is a participant in the
Pennaylvania Power and Light Company benefit plans described below (hereinafter
reCerred to as the "Plan" or .Plans").
2. The current and last known mailing addresa oC Participant is 31 Big Spring
Avenue, Newville, PA 17241.
3. Martha J. Betton, P1aintifl', date oC birth 5/4/46, (Social Security Number
193-36-4602), hereinafter referred to as "Alternate Payee," il the lpOuae oC the
Participant and baa raised elaima Cor, inter aliL equitable distribution oC marital
property punuant to the Pennl)'lvania Divorce Code, 23 PLC.s. Section 3101, et sea.
.. The current and last mown mailing addreu oC the Alternate PlIJl!8 is 609
ColODW View Road, Mecbanicaburr. PA 17066.
6. Tbia order applies to the Collowing plana: Employee Stock Ownenbip Plan
(ESOP), and EIDfIlo1ee 8mDp Plan (ESP),
8. A portioe or Participant', account In the Plan it marital properll auItec:t to
clUtributioll b7 thfa Court.
7. Alternate Payee shall receive 348 shares of the PP&L stock held in the
Employee Stock Ownership Plan.
8. Alternate Payee shall receive $16,699 from the Employee Savings Plan. This
amount shall be placed in a segregated account within the PP&L Plan, in the
Alternate Payee's name and shall accrue any interest, dividends, and growth, effective
March 6, 1998, and remain segregated from the account of the Participant.
9. The distribution to Alternate Payee from the ESOP and ESP shall be made
as soon as Ildministratively practicable following the Plan's determination that thia
Order is a Qualified Domestic Relations Order.
10. Participant's death shall have no effect on payment of Alternate Payee's
benefit under the ESOP or ESP.
11. In the event the Alternate Payee diell before the Alternate Payee's benefit
ill paid, the benefit shall be paid in accordance with the applicable Plan provisions
regarding payments to beneficiaries, including payments when no beneficiary is
designated. The Alternate Payee shall be entitled to name a beneficiary (or
beneficiariell) to receive the unpaid balance of the benefits. The death of Alternate
Payee before the Plan determines that this i. a Qualified Domelltic Relation. Order
shall not elred the rilbt of Alternate Payee'. beneficiary to benelits from the Plan.