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other party at such place or pi aces as he or she may lhlm time to time choose or deem lit.
B, Each party shall be free lTom interference, authority and control. direct or indirect, by
the otber. as fully as ifhe or she were single and unmarried Neither shall bother the other or compel
or endeavor to compel tbe other 10 cohabit or dwell with him cr her.
3. MUTUAL RELEASE
Subject to the provisions of this Agreement. each party has released and discharged, and by
this Agreement does for himself or herself. and his or her heirs. legal representatives. executors.
administrators, and assigns. release and discharge the other of and from all causes of action. claims.
rights, or demands whatsoever in law or equity. which either of the parties ever had or now has
against the other, except any or all cause or causes of action for
divorce,
4, FULL DISCLOSURE
The provisions of this Agreement and their legal effect are fully understood by each party to
this Aweement, and each party acknowledges that the Agreement is fair and equitable, that it is being
entered into voluntarily, and that it i9 not the result of any duress or undue influence. Husband and
Wife each represent and warrant to the other that he or she has made a full and complete disclosure
to the other of all assets of any nature whatsoever in which such party has an interest, of the sources
and amount of the income of such party of every type whatsoever, and of all other facts relatina to
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the subject mailer of this agreement HUSBAND represents that HUSBAND was represented by
JAN L BROWN. ESQUIRE in reaching this Agreement. and WIFE represents that WIFE was not
represented by counsel in reaching this Agreement Both panies represent that the terms of this
Agreement have been fully explained to them by their respective counsel. or that they had the
opportunity to obtain legal counsel and if legal counsel was not obtained the party without legal
counsel represents that he or she fully understand the contents of this Agreement
5. EOUITABLE DIVISION
By this Agreement, the panies have intended to effect an equitable division of their marital
propeny. This division is not intended by the panies to constitute in any way a sale or exchange of
assets,
6. SUBSEOUENT DIVORCE
A. AGREEMENT NOT PREDICATED ON DIVORCE - It is specifically understood
and agreed by and between the panies hereto and each of the said parties does hereby warrant and
represent to the other that the execution and delivery of this Agreement is not predicat.:d upon nor
made subject to any agreement for institution. prosecution. defense. or for the non-prosecution or
non-defense of any action for divorce; provided. however. that nothing contained in this Agreement
shall prevent or preclude either of the parties hereto from commencing, instituting or prosecuting any
action or actions for divorce. either absolute or otherwise, upon just, legal and proper grounds; nor
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to prcvent cithcr party from dclending any such action which has been, mayor shall bc instituted by
the othcr party. or from making any just or proper delense thcrcto It is warranty. covcnanted and
represcnted by Husband and Wile. cach to the othcr. that this Agrcemcnt is lawtill and enforceable
and this warranty. covenant and representation is made for the specilic purpose of inducing Husband
and Wile to execute the Agreement Husband and Wile each knowingly and understandingly hereby
waives any and all possible claims that this Agreement is. for any reason, illegal or lor any reason
whatsoever. unenforceable in whole or in part, Husband and Wite each do hereby warrant I covenant
and agree that, in any possible event. he and she are and shall forever bc estopped from asserting any
illegality or unenforceability as to all or any pl>rt of this Agreement
B ENTRY AS PART OF DECREE - It is t.he intention of the parties that the Agreement
shall survive any action for divorce which may be instituted or prosecuted by either party and no
order. judgment or decree of divorce. temporary. tinal or permanent. shall allect or modify the
linancial terms of this Agreement This Agrecment shall be incorporated in but shall not merge into
any such judgment or decree of final divorce. but shall be incorporated for the purposes of
enforcement only,
C MUTUAL CONSENT DIVORCE - The parties agree and acknowledge that their
maniage is irretrievably broken. that they do not desire marital counseling. and that they both consent
to the entry ofa decree in divorce pursuant to 23 PaCSA Section 33f'I(c) Accordingly, both
parties agree to forthwith exp.cute such consents. affidavits. or other documents and to direct their
respective attorneys to forthwith file such consents. atlidavits. or other documents IS may be
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necessary to promptly proceed to obtain a divorce pursuant 10 said 23 PaC,SA Section BOI(c)
Upon requesl. to the extent pemlitt~'<I by law and the applicable Rules of Civil Procedure, the named
defendant in such divorce action shall execute any waivers of notice or other waivers necessary to
expedite such divorce,
7, DIVISION OF PERSONAL PROPERTY
Wife agrees that all of the property in the possession of Husband shal: 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 specilically 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,
8. DIVISION OF MOTOR VEHICLES
With respect to the motor vehicles owned by one or both of the parties, they agree as follows:
1989 ORAND PRIX shall be the sole and separate property of HUSBAND subject to any
loan on the vehicle and HllSBAND agrees to assume responsibility for and indemnifY and hold WIFE
harmless therefrom.
1993 SUNBIRD shall be the sole and separate propeny of WIFE subject to any loan on the
vehicle and WIFE agrees to assume responsibility for and indemnifY and hold HUSBAND harmless
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therelrom
The litle$ to lhe said motor vehicles shall be exe~uted by the parties. if appropriate. for
ellectuating transler as herein provided, on the date of execution of this Agreement or at any time
thereafter at the request of either party, If there is any loan. lien or en~umbrances against the 1989
Grand Prix, HUSBAND is solely responsible for such and indemnitY WIFE against for the Grand
9. DISPOSITlOO_Qf PROPEIITY
From and after the dale of the signing of this Agreement. both parties shall have complete
freedom of disposition as to his/her separate property and any property which is in their possession
or control pursuant to this Agreement and may mortgage, sell. grant. conveyor otherwise encumber
or dispose of such property, whether real or personal, whether such property was acquired before.
during or after marriage, and neither Husband nor Wife need join in, consent to, or acknowledge any
deed. mortgage, or other instrument of the other pertaining to such disposition of property,
10. DIVISION OF REAL PROPERTY
Husband and Wife hereby agree and acknowledge that they own certain real pro perty located
at 17 AL TONNA AVENUE, ENOLA. CUMBERLAND COUNTY, PENNSYLVANIA, as tenants
by the entireties
WIFE hereby agrees to convey all WIFE's right, title and interest in said property to
HUSBAND, WIFE agrees to execute a deed or other instrument of conveyancing necessary to
effectuate this transfer at the time of the execution of this document.
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Both parties acknowledge and agree that the provisions of this Agreement providing for
equitable distribution of marital property are fair, adequate and satisfactory to them and are accepted
by them in lieu of and in filII and tinal seulement and satislaction of ally claims or demands that either
may now or hereafter have against the other lor support. maintenance. alimony pendente lite or
alimony, Husband and Wife furthcr. voluntarily and intelligently. waive and rclinquish any right to
seek from the other any "ayment for support. maintenance, alimony pendente lite or alimony,
14, PENSION PROGRAM
Each party hereto shall maintain sole ownership over his or her individual pension plan. profit
sharing or similar retirement plan acquired individually or as the result of contributions by his or her
employer. Wife hereby releases any interest that she has in the retirement benefits of Husband
accumulated as the result of his employment by DDRE and any other additional benefits he may have
accrued, Husband hereby releases any interest that he has in the retirement benefits of Wife
accumulated as the result of her employment by PA BLUE SHIELD and any other additional benefits
she may have accrued, This waiver is a full and complete discharge of each parties' marital claim,
IS. MISCELLANEOllS
All assets in.:luding. but not limited to, savings accounts, checking accounls., certiflcll" of
deposit and life illsurance policies shall be the sole and separate property or the litle holder ofllicl
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asset.
The parties believe and agree. and have been so advised by their respective attorneys, that the
division of property heretotore made by this Agreement is a non-taxable division of property between
co-owners rather than a taxable sale or exchange of such property. Each party promises not to take
any position with respect to the adjusted bas:.' of the property assigned to him or her or with respect
to any other issue which is inconsistent with the position set forth in the preceding sentence on his
or her federal or state income tax returns,
The parties have heretotore tiled joint federal and state tax returns, Both parties agree that
in the event any deficiency in tederaJ, 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 lax ueficiency or assessment and any interest. penalty and
expense incurred in connection 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.
12 GENERAL PROVISIONS
A. WARRANTY AS TO EXISTING OBLIGATIONS. Each party represents that they
have not heretofore incurred or contracted tor any debt or liability or obligation for which the estate
of the other party may be responsible or liable except as may be provided tor in this Agreement. Euh
party agrees to indemnitY or hold the other party harmless trom and against any and a1lsucb debts,
liabilities. or obligations of every kind which may have heretofore been incurred by them, inl:1udlna
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those lilr necessities, except Iilr the obligations arising out of this Agreement.
B WARRANTY AS TO FUTURE ODU(iATIONS . Wile and Husband each covenant,
warrant, represent and agr~'C that each will now and at all times hereafler save harmless and keep the
other indemnified from all debts, charges, and liabilities incurred by the other after the execution date
of this Agreement, except as may be otherwise specifically provided for by the terms of this
Agreement and that neither of them shall hereafter incur any liability whatsoever for which the estate
of the other may be liable
C. SEVERABILITY -Ifany term, condition. clause. or provision of this Agreement shall
be determined or declared 10 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 be valid and continue in full force, ell'cct, and operation. Likewise, the failure of any party to
meet his or her obligations under anyone or more of the paragraphs herein, with the exception of the
satisfaction of the conditions precedent, shall in no way void or alter the remaining obligations of the
parties
D, OTHER DOCUMENT AnON. Wife and Husband covenant and agree that they will
forthwith execute any and all written instruments, assignments. releases, satisfactions, deeds, notes
or such other writings as may be necessary or desirable lilr the proper ellectualion of this Agreement.
and as their respective counsel shall mutually agree should be so executed in order to carry out fully
and etfectively the terms of Ihis Agreement.
E, ENTIRE AGREEMENT. This Agreement contains the entire understanding oralie
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parties. and there lire no representations, warranties. covenants. or undertakings other than those
expressly setlorth herein.
F. WAIVER OR MODIFICATION TO BE IN WRITING. No modilication 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,
G. 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 instrum.;nts and/or documents that the other party may reasonably require fo~ the purpose of
giving full force and elfectto the provisions of this Agreement.
H, LAW GOVERNING. This Agreement shall be construed and governed in accordance
with the laws of the Commonwealth of Pennsylvania.
I. BINDING EFFECT - Except as otherwise stated herein. this Agreement shall be
binding and shall inure to the benefit of the parties hereto and their respective heirs. executors.
administrators. successors. and assigns.
K. NO WAIVER OF DEFAULT" This Agreement shall remain ill lull force and eITect
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 breach of any
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provision hereof be constmed as a waiver of any subSCtjuent delilUlt of the same or similar nature. nor
shall it be construed as a waiver of strict perlormance of any other obligations herein
K HEADINGS NOT PART OF AGREEMENT - Any heading preceding the text of the
several paragraphs and subparagraphs hereof are inserted solely tor convenience or reterence and
shall not constitute a part of this Agreemcnt nor shall they allect its meaning. construction. or effect.
L ADDRESS OF PARTIES" Each party shall at all times keep the other informed of
his or her place of residencc, and shall promptly notifY the other of any change. giving the address
of the new place of residence
M, WAIVER OF CLAIMS AGAINST ESTATES - Except as herein otherwise provided,
each party may dispose of his or her property in any way. and each party hereby waives and
relinquishes 3ny and all rights he or she may have or hereafter acquire. under the present or future
laws of Pennsylvania or another jurisdiction, to share in the property or the estate of the other as a
result of the marital relationship. including, without limitation. dower. curtesy. their statutory
equivalents. widow's allowance. homestead rights. right to take in intestacy. right to take against the
will of other. and right to act as administrator or executor of the other's estate. and each party will,
at the request of the other, execute. acknowledge. and deliver any and all instruments which may be
nec:essary or advisable to carry into effect this mutual waiver and relinquishment of all such interests.
rights and claims.
N. ATTORNEY'S FEES FOR ENFORCEMENT -In the event that either party breaches
any provision of this Asreemcmt. and the other party retains counsel to assist in enforclnll the terms
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