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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF ~.~ PENNA,
IUCHAEL C. WILLIAMS.
l\ll..~,..,..
,~~,\/~~".., 19 97
plaintiff
\,,'1'.";11.--;
Rl!HfIB L. WILLIAMS.
Defendant
DECREE IN
DIVORCE
AND NOW, ""~tti.,'~",. 19,~",. it is ordered and
decreed that.. , .. , ' , , ,"i~;J., ~.., "'iHi~.. , , , , .., , ..' .... , '. plaintiff,
and, .. .. ,~~~ ,~, ,~ql~~, .. , .. .. ' , , , , .. , , .. .. .. .. .. .. ,..,. defendant,
are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet
been entered;
,Pro~~tY,S~ttl~~~t,A9r~~~~t,~ate?,~2(?(~?,~~~~~~~~~e?!,~~~,~~~I,~~~~
,Di.vorce, Decree., ,
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PROPERTY SF.TTI,FMJi'.NT AGRF.F.MTo'.NT
nos AGREEMENT, made thl, ...5.... day of December, 1997, by and between
MICHAEL CRAIG WlWAMS, hereinafter called .HUJband., and RENNIE L YN WILLIAMS,
formerly known u Rennie Lyn Smith, hereinafter called .Wlfe.,
WITNESSETIlI
WHEREAS, Hulband and Wife were Ieplly married on 1une 27, 1993 In Cumberland
County, Pennsylvania.
WHEREAS, differences have arisen between Husband and Wife in consequence of which
they desire to live separate and apart from each other; and
WHEREAS, Husband and Wife desire to settle and determine their ri&hlJ and obliptlons.
NOW TIJEREFORE, in I:OIlsideration of the premises and covcnanlJ contained herein,
It Is qreed by and between the parties hereto that:
1. SEPARATION.
It shall be lawful for each party at all times hereafter to live separate and apart from each
other at Sl,'ch place as he or she from time to time shall choose or deem fit. The fore&o!n.
provision shall not be taken as an admission on the part of either party of the lawfulness or
unlawfulness of the causes leading to their living apart.
2. INTERFERENCES.
Each party shall be free from interference, authority and control by the other, u fully
as if he or she were single and unmarried, except as may be necconary to carry out the
provisions of this A&reement. Neither party shall molest or attempt to endeavor to moIeat the
other, or in any way harass or malian the other, nor in any other way interfere with the peaceful
existence, sepIlIte ar.d apart from the other,
3, DIVISION OF REAL PROPERTY.
The parties aaree to sell the marital home altuatcd at 201' Carlisle Road, Cumberland
County, Camp Hill, Pennsylvania (the "Property") and to list the Property with a mutually
aarccd upon real estate broker. From and after December I, 1997 and until the Property is
sold, the parties shall be equally responsible and shall equally pay (SO%-SO%) all mortgage
paymenu, taxes, utilities and other charges, liens, and maintenance cosu associated with the
Property, At closing and settlement on the sale of the Property, the parties agree to equally
share (SO%-SO%) all net proceeds from settlement, after deducting closing cosu attributable to
sellen; or, if the selling price is not sufficient to cover sellers' closing cosu and the parties, u
sellen, arc required to brina cub to closing, to equally pay sellers' closing cosu at settlement.
4. DIVISION OF PERSONAL PROPERTY.
The parties have divided between them to their mutual satisfaction, personal effecu,
household goods and furnishings and all other articles of personal property which have
heretofore been used in common by them, and neither party will make any claim to any such
items which arc now in the possession or under the control of the other,
S. AUTOMOBILES
The VW Golf shall become the sole and separate property of Husband. The Ford Festiva
shall become the sole and separate property of Wife.
-2-
6, MARITAL DEBTS.
Except u let forth elsewhere in this Aarecmcnt, the parties ..reo that they have no joint
liabilities, Each party represents that they have not heretofore incurred or contracted for any
debt or llablllty or obligation for which the estate of the other party may be responsible, Each
party agrees to indemnify, defend, and hold harmlesa the other party for and aplnst any and all
such debts, llablllties and obligations of evezy kind which may have been incurred by them,
inchiding those for necessities.
7. PENSIONS.
Husband waives any rights which he may have to any retirement accounts, stock plans
or pension plans of Wife, including Wife's PSERS pension. All other such accounts, if any,
shall be the sole and separate property of the party in whose name the account or plan is titled,
Each party agrees to execute all documents to give effect to this paragraph,
8. LIFE INSURANCE.
Each party shall retain any ownership interest they may have in life insurance policies
presently in their possession.
9, TAXRIl.
Husband hereby agrees to pay all income taxes as.'ieSsed against him, if any, u a result
of the division of the property of the parties hereunder, Wife hereby agrees to pay all income
taxes asltssed against her, if any, as a result of the division of the property of the putiea
hereunder, The parties agree that they shall file joint federal and state tax returns for the 1997
tax year and further agree that any refund or taxes due shall be shared equally (SO~ -SO").
.J-
10, BREACH.
If either party breaches any provision of thI. A,reement, the other party shall have the
rI,hl, at hi. or her c1cction, to SUCI for dama&es for .uch breach. The party breachin, this
contract shall be raponsible for the payment of reasonable leaal fees and costs incurred by the
other In enforeln, his or her rlahts under this Apecment, or sccldna .uc:h other remedy or relief
as may be avallable to him or her.
11. FULL DISCLOSURE.
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 suc:h party
of every type whatsoever and all other facts relatin, to the subject matter of this Agreement.
12. ADDmONAL INSTRUMENr.
Each of the parties shall on demand execute and deliver to the other any deeds, bllls of
sale, assianment, consents to change of beneficiary on insurance policies, tax returns and other
documents and do or caused to be done any other act or thing that may be necessary or *Rrable
to the provisions and purposes of this Agreement, If either party fails on demand to comply with
this provision, that party shall pay to the other all attorneys' fees, costs and other expenses
reasonably incurred as a result of such failure,
13, WIFE'S DEBTS.
Wife represents and warrants to Husband that since the parties' separation she
has not and in the future she wll1 not contract or incur any debt or liability for which Husband
or his estate mi&ht be responsible and shall indemnify and save Husband harmless from any and
all claims or demands made against him by reason of debts or obli&ations Incurred by her.
-4-
14, HUSBAND'S DHBTS.
Husband represents and wllrants to Wife !hat since the partlCI' separation he ha.s not and
In the future he will not contract or Incur any debt or liability for which Wife or her estate might
be responsible and shalllndcmnlfy and save Wife harmlw from any and all claims or demands
made aaainst her by reason of debts or obllg~t1OC\s inclll'm1 by him.
15. WAIVERS 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 any and all rights he or she may now
have or hereafter acquire, under the present or future laws of any jurisdiction, to share In the
property or the estate of the other as a result of the marital relationship, including without
limitation, dower, curtesy, statutory allowance, widow's allowance, right to take In Intestacy,
right to take aaainst the Will of the other, and right to act as administrator or executor of the
other's estate, and each will, to the request of the other, execute, acknowledge, and deliver any
and all Instruments which may be necessary or advisable to carry into effect this mutual waiver
and relinquishment of all such interests, rights and claims,
16. VOLUNTARY EXECUTION.
The provisions of this Agreement are fully understood by both parties and each party
acknowledges that this Agreement is fair and equitable, that it is being entered into voluntarily,
that it is not the result of any duress or undue influence, and that each party ha.s hid die
opportunity to consult with an attorney of his or her own choosing and to be informed as to their
legal rights and obligations.
-5-
17. ENTIRE AGRF.F.MENT,
This AgRiCment contains the entire undcnIanding of the parties and there are no
representations, warranties, COVClW\ts or undertakings other than those expressly set forth
herein ,
18. PRIOR AORF.F.MPm
It is undenlood and a&reed that any and all property settlement qreements which may
or have been executed prior to the dale and time of this Aan:ement are null and void and of no
effect,
19. MODIFICATION AND WAIVER: SUBSEOUENT RECONCILIATION.
Any modification or waiver of any provision of this Agreement shall be effective only
if made in writing and executed with the same formality u this Agreement, The failure of either
party to insist upon strict performance of any of the provisions of this Agreement shall not be
construed U I waiver of any subsequent default of the lame or similar nature. The parties
further agree that the lerms of this Agreement shall not be affected by any subsequent
cohabitation or resumption of marital relations, unless the parties otherwise specifically agRiC
in writing,
20, GOVERNING LAW.
This Agreement shall be governed by and shall be construed in accordance with the laws
of the Commonwealth of Pennsylvania,
21. INDEPENDENT SEPARATE COVENANTS.
It is specifically understood and agreed by and between the parties hereto that each
Jl&I1I&raph hereof shall be deemed to be a separale and independent covenant and agrcemcnL
-6-
22, VOID CLAUSES.
If any term, condition, clause, or provision of this Agreement shall be determined or
declaml 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 respccU this Agreement sIwll
be valid and continue in full force, effl.:ct and operation,
23, ENTRY AS PART OF DECRP.R
It is the intention of the parties that tbiJ A&reement shall survive any action for divorce
which may be instituted or prosecuted by either party and no order, judgment or decree of
divorce, temporary, final or permanent, shall affect or modify the financial terms of this
Aareement. This Agreement shall be made a part of any such judgment or decree of final
divorce,
24, DIVORCE ACTION.
The parties shall, at the time of the execution of the Agreement, execute doc:umenu
~ssary to fmalize a divorce action including, but not limited to, the entry of a divorce decree
to be filed in the Court of Common Pleas, Dauphin County, Pennsylvania, U well u the
Acceptance of Service of the Divorce Complaint, Affidaviu of Consent and Waivers of
Counseling and Waivers of Notice of Intention to Request Entry of a Divorce Dec~'CC, Husband
shall pay the cost of filing the Divorce Complaint.
2S, DOMESTIC REf ATlONS CODE OF THE COMMONWEALTH OF
PENNSYLVANIA.
Except u specifically provided in this Agreement, each party waives any claim they may
have lI&ainst the other under the Domestic Relations Code of the Commonwealth of Pennsylvania
-7.
COMMONWEALTH OF PENNSYLVANIA
:u.
COUNTY OF DAUPHIN
On thil, the 5#1 day of December, 1997, before me, a Notary Public, personally
appeared MICHAEL C. WILLIAMS, known to me 10 be the pcmxI whole name II lIIbacrlbed
to the within PJupo;tty Settlement Agrecmentllld acknowledged that he executed the aame for
the purpoICI therein contained.
IN WITNESS WHEREOF, I hereunlO let my hand and offidal seal,
~4L-In~~
NOTARY PUBUC
COMMONWEALTH OF PENNSYLVANIA
: SSe
COUNTY OF DAUPHIN
On thil, the .!i!!2. day of December, 1997, before me, a Notary Public, penonaIly
appeared RENNIE L YN WILLIAMS, known to me to be the penon whose name is subscribed
to the within Property Settlement Agreement and acknowledged that she executed the same for
the purpoICI therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
~Lfh~
NOTARY PUBUC
1414011.I
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MICHAEL C. WILLIAMS,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
Plaintiff
v,
CIVIL ACTION. LAW
RENNIE L. WILLIAMS,
NO, 5888-1997
IN DIVORCE
Defendant
PRAECIPE TO 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 ~ 3301(c) of the Divorce Code,
2, Date and manner of service of the Complaint: Acceptance of Service dated
12/5/97 and filed 12/10/97
3,
(a)
Date of execution of the affidavit of consent required by ~
3301(c) of the Divorce Code: by Plaintiff 1/23/98 ; by
Defendant 1/23/98,
(b)(I) Date of execution of the Affidavit required by ~3301(d) of the
Divorce Code: Ill/a
(2) Date of filing and service of Plaintiff's Affidavit upon the
Defendant: N/A
4, Related claims pending: No related c1aill1.9 pending. Settlement
Agreement incorporated, not merged, into Decree.
S, (a) Date and manner of service of the notice of intention to file praecipe to
transmit record, a copy of which is attached: Not applicable; parties
have executed attached Waiver of Notice,
(b) Date Plaintiff's Waiver of Notice in ~ 3301(c) Divorce was filed with the
prothonotary: . Filed contemporaneous \lith
filing of this Praecipe To Transmit Record.
Date Defendant's Waiver of Notice in ~ 3301(c) Divorce was filed with the
prothonotary: . Filed contemporaneous \lith the
filing of this Praecipe To Transmit Record.
.~~~~~-
A~0~;'P1aintiff
John R. Kachur, Esquire ..
Supreme Court 1.0. 158141 ~
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ECKERT SEAMANS CHERlN rIt MELLorT
. p,o, B(jX 12..
HAIlIUS8UIlC. PA 17101
..
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: No, q7- ~"i f r (I,v.1 -re,,,,,
: CIVIL AcrlON - LAW
: IN DIVORCE
MICHAEL C. WILLIAMS,
Plaintiff
RENNIE L. WILLIAMS,
Defendant
COMPLAINT FOR DIVORCE
The Plaintiff, Michael C. WlIIiams, hereby seeks a divorce from the Defendant, Rennie
L, Williams, and in support thereof makes the following averments:
COUNT I-IRRETRIEVABLE BREAKDOWN
1. The Plaintiff is an adult individual residing at 2015 Carlisle Road, Camp HlII,
Cumberland County, Pennsylvania.
2, The Defendant is an adult individual residing at 2015 Carlisle Road, Camp Hill,
Cumberland County, Pennsylvania,
3. The Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania
for at least six months immediately previous to the filing of this Complaint,
4, The Plaintiff and Defendant were married on July 27, 1993, in Cumberland County,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
I
6, Neither Plaintiff nor Defendant is in the military or naval service of the United
States or iu allies within the provisions of the Soldiers & Sailors Civil Relief Act of the Congress
of 1940 and iu amendments.
7, Plaintiff avers that there are no children to the parties,
8, The marriage is irretrievably broken,
9, Plaintiff has oo:n advised of the availability of counseling and that Plaintiff or
Defendant has the right to reques: the Court to require the parties to participate in such
counseling,
WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce, divorcing
Plaintiff and Defendant.
Respectfully submitted,
~~~
John ,Kachur, Esquire
Supreme Ct, I,D. No. 58141
ECKERT SEAMANS CHERIN & MELLO'IT, LLC
One South Market Square Building
213 Market Street
Harrisburg, PA 17101
(717) 237-6000
DATED: 6:.-r. '3~.l""7
Attorney for Plaintiff
2
v,
: IN THB COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: No, q?- 5f.f'f ~
MICHAEL C, WILLIAMS,
PlalnUff
RENNIB L, WILLIAMS,
Defendant
: CIVIL ACTION - LAW
: IN DlVORCB
ACCEPTANCE OF SERVICE
I, Rennie L. Williams, hereby accept service of the within Complaint in Divorce this 5-
daYo~, 1997. ~)
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I IN TIlE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 97-5888 Civil
MICHAEL C. WILLIAMS,
PIalntllf
.
.
RENNIE L WILLIAMS,
Defendant
CIVIL ACTION. LAW
IN DIVORCE
AFF1DA VIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code wu filed on
October 24, 1997,
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days
have elapsed from the date of filing the Complaint.
3, I consent to the entry of a final decree of divorce,
4, 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.
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. Section 4904 relating
to unsworn falsification to authorities.
Date:J .<2,3 '{8'
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MICHAEL C. WILUAMS,
Plaintiff
: IN TIlE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY , PENNSYLVANIA
Y.
NO. 97-5888 Civil
.
.
RENNIE L. WILLIAMS,
Defendant
: CIVIL ACTION. LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUFST ENTRY OF A
DIVORCE DECREE UNDER 1330Hc) OF TIlE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
Iawyer'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, C4904 relating to unsworn
falsification to authorities,
Date: \ - 2. ~ R.g-
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I IN TIlE COURT OF COMMON PLEAS
I CUMBElU..AND COUNTY , PENNSYLVANIA
I
I NO. 97-5888 Civil
I
I CIVIL AcrION . LAW
I IN DIVORCE
MICHAEL C. WILUAMS,
PIalatUT
RENNIE L. WILLIAMS,
Delelld.nt
AFFID.~ VIT OF CONSENT
1. A Complaint in Divorce under Section 330 1 (c) of the Divorce Code wu filed on
October 24, 1997,
2. The marria&e of Plaintiff and Defendant is irretrievably broken and ninety days
have elapsed from the date of filing the Complaint.
3, I consent to the entry of a final decree of divorce,
4. 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,
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 Pi, C.S, Section 4904 relating
to unsworn falsification to authorities.
Date:-1, cd 3 >1 B-
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Rennie L. WiUiarils
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I IN nlE COURT OF COMMON PLEAS
I CUMBF.RLAND COUNTY, PF.NNSYLV ANIA
I
I NO. 91-5888 Civil
I
I CIVIL ACTION. LAW
I IN DIVORCE
MICHAEL C. WILLIAMS,
PIalnurr
RENNIE L. WILLIAMS,
Defendant
WAlvrr~ OF NOTICE OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER IJJOlIcl OF TIlE DIVORCE CODE
1. I consenllO the entry of a Onal decree of divorce wlthoul notice,
2, I understand thai I may lose rlahu concemlna alimony, division of propeny,
lawyer'. fees or ellpense. if I do not claim them before a divorce Is aranted,
), I understand thai I will not be divorced until a divorce decree is entered by the
Coun and thai a copy of Ihe decree will be senl 10 me Immediately after it Is filed with the
Prothonotary .
I verify thai the .tatemenl. made in Ihl. arndavlt are lrue and correcl, I understand that
false statements herein are made .ubject 10 Ihe penal lie. of 18 Pa.C.S. 14904 relalina 10 unsworn
falslficalion 10 authorities.
Date: \ . :) ~ (i.K:-
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