HomeMy WebLinkAbout98-01232
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MARITAL SETI'LEMENT AGO;:EN'l'
THIS AGREEMENT is made this~Ot~ay of , 1998, by II1ld between
v'
REBECCA S. LAUGHLIN, ("Wife") and HARRY B. LAUGHLIN, II, ("Husband"),
WHEREAS, the parties were mllfried on October 31, 1996, and have remained
married since that time; and
WHEREAS, certain differences have arisen between the parties and, as II
consequence, they have lived separate II1ld apart from each other since December I,
1997; II1ld
WHEREAS the pllfties wish to set forth certain covenants and understll1ldings
regarding their separation and their respective property rights; and
NOW THEREFORE, in consideration of the mutual promlsosand undertakings
contained herein, the parties hereto, intending to be legally bound, covenant II1ld agree
as follows:
1. VOLUNTARY AGREEMENT: It is acknowledged by the parties that
this Agreement Is entered into voluntarily II1ld after due deliberation by each of them,
2. SEPARATION AND NON.INTERFERENCE: It shall be lawful for
Husbll1ld and Wife at all times hereafter to live separate and apart from each other
II1ld to reside from time to time at such place or places as they shall respectively deem
fit" free from any control, restraint, harassment or interference,indirect or direct, from
each other, The foregoing provisions shall not be taken to be an admission on the part
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of either party of the lawfulness or unlawfulness of the cuuses leuding them to live
apart,
3. DIVORCE ACTION: The parties acknowledge that an action for divorce
between them hus been filed by Wife on March 6, 1998, in t,he Court of Common Pleas
of Cumberland County, Pennsylvania, Laughlill I', Laughlin, No, 98.1232 Civil
Term, In Divorce. 'rhe partios hereby acknowlt1dge thoir intention and agreement to
proceed in said action to obtain a final decree in divorce by mutual consent on the
grounds that their marriage is irretrievably broken, and to settle, amicably and fully
hereby, all claims which might be raised by eitlwr party in the divorce action, 1'he
parties acknowledge that they will execute, simultaneously herewith, the necessary
Mfidavits of Consent for the entry of a final divorce decree in the pending action,
4. LEGAL ADVICE: The parties acknowledge that Wife has been
represented by Samuel W. Milkes, Esq" JACOBSEN & MILKES, as counsel in this
matter, and that Husband has been represented by Marilyn C. Zilli, Esq"
FETTERHOFF & ZILLI. Husband and Wife each acknowledge that she and he have
received, or have had the opportunity to receive independent legal advice from counsel
of her or his selection prior to the execution of this Agreement. Each party agrees
that, with or without representation, she or he each fully understands the facts, and
each has had the opportunity to be fully informed as to her 01' his legal rights and
obligations, Each party acknowledges and accepts that this Agreement is, in the
circumstances, fair and equitable, and that it is being entered into freely and
voluntarily alter Wife's consultation with her attorney and Husband's consultation
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with his attorney. 'rh(l execution of the Agreement is not the result of any duress or
undue influence, and it ill not the result of any collusion er improper illegal agreement
or agreements. The parties ucknowledge that euch has been fully informed of, or is
familiur with, the weulth, property, state, and income of the other, and each party is
hereby satisfied that such information is true and coneeL
5. REAL PROPERTY: Prior to the signing of this Murital Settlement
Agreement, the purties have already conveyed any and all of their interest in the real
property located at 812 Yorkview Drive, Grantham, PA, entirely to Hurry B. Laughlin,
II. Rebecca S. Laughlin relinquishes !lily and all of her interest in the real property,
in connection with this conveyance. Rebecca S. Laughlin hus received $12,000, as a
complete settlement of any lInd all financial claims which she may have relating to this
property or otherwise. Husband hasremortgaged the property at 812 Yorkview Drive
so that Wife's name is removed entirely from the loan instrument on the property, and
Husband is now solely responsible for any balance due on the mortgage.
6. PERSONAL PROPERTY: The purties have divided all personal
property and each is full owner of the personal property now in his or her possession.
7. PENSION, CHECKING, AND SAVINGS ACCOUNTS: The purties
agree that these assets ure fully owned by each purty in whose name they ure currently
held.
8. HEALTH INSURANCE: Effective upon the divorce of the purties, each
purty will be responsible for the purchllse and payment for individual health insurance
plans.
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9. LIFE INSURANCE: Concurrent with the signing of a Memorandum of
Understanding, dated April 17, 1998, the purties agreed that they had the right to
cuncellife insurance policies for which the other spouse was named beneficiury. Both
purties ure free to purchase life insurance in their own names, and to name whomever
they should choose as beneficiury.
10. AUTOMOBILES: Wifo shall retain and become the sole owner of the
1994 Ford Mustang Cobra automobile which is titled in her name and which is in her
possession. Husband shall retain and become the exclusive owner of the 1995 Jeep
Grand Cherokee automobile which is titled in his name and which is in his possession.
Husband shall be solely responsible for payment of the balance due on his cur loan.
He agrees to indemnify and hold Wife hurmleos on this debt. Concurrent with the
singing of the April 17, 1998 Memorandum of Understanding, each purty became
responsible for the purchase and payment of insurance for their vehicles.
11. WEDDING AND ENGAGEMENT RINGS: Wife shall retain the
engagement and wedding hands in her possession. Husband shall retain the wedding
band in his possession.
12. TAX DEBTS OF THE PARTIES: Husband agrees to pay the balance
due on the parties' 1996 tax debt. He agrees to indemnify and hold Wife hurmless on
this debt.
13. CURRENT TAX LIABILITIES: The purties agree to file a joint tax
return for 1997. Husband agrees to pay any tax due for 1997 and to indemnity and
hold wife hurmless on this obligation. Wife agrees that if any refund is made to the
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purties on this return, the total amount of refund due will become the sole and
exclusive possession of Husband, to d.ispose of as he sees fit, Wife a!,'l'ees to relinquish
all claim to any refund paid for 1997. 'fo effectuate this agreement, Wife agrees to
endorse and return to Husband, within three days of her receipt of a tax refund check,
any such check received. Return will be made by certified mail. Further, Wife agrees
to go to H & R Block in Carlisle, Pennsylvania, to sign the parties' 1997 tax return,
within three days of being notified by Mr. Laughlin that the return is ready for her
signature.
14. DEBTS OF TIlE PAR'fIES: Husband agrees to be solely responsible
for the balance due on the parties' joint debt to Good's Furniture Store, in the amount
of $848,00, the balance due ut the time of the filing of the divorce Complaint, and to
indemnify and hold wife hurmless on this debt, Husband shall take any and all steps
necessury to arrange with Good's Furniture to finance this debt in his name only,
rather than that of Wife. In the event he is unable to accomplish this transfer, and
in the event he is unable to pay this debt in full immediately, instead, husband will
pay directly to wife the sum of $25,00 on the first of each month for a total of thirty-
three months, commencing June 1, 1998, this being the minimal payment due on this
bill, which has been the customary payment urrangement of the purties in the past.
If the url'angement is that Husband is to pay Wife on this debt, Wife shall release and
hold Husband hurmless for the entire balance due on this debt, in consideration of his
continued payment to her of the monthly amount specified above. Wife agrees to
assume sole responsibility for the debt due to 1',J. Maxx & Co. and to indemnify and
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hold Husband hurmless on this debt. Wife shall contact 'r,J, Maxx & Co, to ensure
that statements and notices regurding this debt ure Bent directly to her address, The
purties certify and acknowledge that they have at this time no other joint debts or
liabilities,
Husband agrees to be solely responsible for any other debt in his name alone,
and to indemnify and hold Wife hurmlesB on any such debt"
Wife agrees to be solely responsible for any other debt in her name alone, and
to indemnify and hold Husband harmless on any such debt.
Wife agrees to be solely responsible for her school loan debt and to indemnify
and hold Husband hurmless on this debt,
The parties agree that they will not in the future contract or incur any debt or
liability for which the other purty, his or her property or estate, might, be responsible
and each further agrees t.o indemnify and save harmless the other purty against any
cialms that may be asserted by anyone against the other purty by reason thereof,
15. ALIMONY: Husband agrees to pay Wife alimony in the amount of
$666.66 per month for a period of twelve (12) months, the first payment having been
made on May 1, 1998, and each subsequent payment due on the first of the month
hereafter. 'l'hese payments will be taxable to Wife and tax deductible to Husband,
'I'he purties agree that there shall he no enlargement of the,erm of the alimony
payments, which shall cease effective with the April 1, 1999 payment and that neither
purty shall have the right to apply to the Court for either an extension or reduction
of the term. The purties further agree that there shall be no modification of the
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amount of the alimony during the twelve-month term thereof and that neither pw.ty
shall have the right to apply to the Court for either an increase 01' a decrease in the
amount to be paid. The parties agree finally that Husband's obligation to pay alimony
shall automatically cease upon Wife's death, remw'l'iage 01' co-habitation with another
not her spouse, Wife has withdrawn the Petitions for Alimony and Alimony Pendente
Lite which were filed with the Cumberland County Domestic Helations Office, and
proof of this has been provided to Hushand, The parties agree to execute any other
documents necessary to accomplish this withdrawal.
16. NON-MERGER IN DIVORCE DECREE: The parties agree that in the
event of absolute divorce between them, they shall nonetheless continue to be bound
by all the terms of this Agreement, and neither this Agreement, nor the torms hereof,
shall be deemed to have been merged in any decree 01' judgment grantod in the divorce
action, but shall survive and be fOl'llver binding upon the purties,
17. EXECUTION OF DOCUMENTS: Each of the purties shall, from time
to time at the request of ellch other, execute, acknowledge and deliver to the other
purty any and all further instruments that may reasonably be required in order to give
full force and effect to the provisions of this Agreement,
18. MUTUAL REUJASE AND COUNSEL FEES: Except as provided for
in this Agl'eement, the purties hereby remise, release, quit-claim and forever dischurge
each other and the estate of each other, for all time to come, and for all purposes
whatsoever, from any and every e1aim, including alimony, alimony pendente lite,
spousal support" equitable distribution of marital property, counsel fees or costs under
7
the Divorce Reform Act, or otherwise, that they make or hereafter make in and to or
against each other's estates or any purts thereof, whether by way or dower or curt.esy,
or under the intestate law8, or the right to take or elect against the other's will, except
only such rights as accrue pursuant to t.his Agreement,
Each purty hereto agrees that h(l or she shall individually be responsible for any
and all counsel fees wId expenses incurred by him or her in connection with the
prepuration of this Agreement and the divorce between the purties.
19. NON.WAIVER: The failure of either party to insist in anyone or more
instances upon the strict performance of any of the terms hereof ill this Agreement
shall not be construed as a waiver or rlJlinquishment of suc;h term or terms in the
future.
20. RECONCILIATION: ,!'he purties agree that in the event of a
reconciliation between them, this AgTeement shall continue in full force and effect
unless terminated by mutual written consent.
21. BREACH: In the event that either purty breaches any provision of this
Agreement, he or she shall be responsible tor any and all costs incurred to enforce the
Agreement, including, but not limited to, court costs and counsel fees of the other
purty, In the event of breach, the other purty shall have the right, ut his or her
election, to sue for damages for such breach or to seek such other and additional
remedies as may be available to him or her, including equit.able enforcement of the
Agreement.
22. ENFORCEMENT: The purties agree that this Agreement or any purt
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or parts hereof may be enforced in any court of competent jurisdiction.
23. APPUCABLE LAW AND F..xECUTION: 'fhe purties hereto agree that
this Agreement shall be construed under the laws of the Commonwealth of
Pennsylvania, and shall hind the Pill'ties hereto, and t.heir respective heirs, executors
and assigns, This Agreement shall be executed as original in quadruplicate.
24. ENTIRE AGREEMENT: The purties acknowledge and agree that this
Agreement contains the entire understanding of the purties and supersedes any prior
agreement between them, There are no other representations, warranties, promises,
covenants or understillldings between the purties other thilll those expressly set forth
herein, 'l'he purtieB agree to have all aspects of this agreement completed within
ninety (90) days of the execution of this document,
25. AGREEMENT SUPERSEDES OTHER AGREEMENTS: The purties
specifically agree that the terms of this agreement supersede any other agreements
entered by the parties, whether orally or in writing, Specifically, !'his agreement
supersedes the Memorandum of Understanding previously executed by the parties.
26. INCORPORATION IN JUDGMENT FOR DIVORCE: In the event
that either Husband or Wife at any time hereafter obtain a divorce, this Agreement
and all of its provisions shall be incorporated into any such judgment for divorce,
either directly or by reference. The court, on entry of judgment for divorce shall retaln
the right to enforce the provisions and the terms of the Agreement.
IN WITNESS WHEREOF, the purties hereto have Bet their hands and BealS
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REBECCA S, LAUGHLIN,
Plaintiff
v.
: IN TIH) COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO,C){ PiStIL TERM
HARRY B. LAUGHLIN II,
Defendant
; IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court, If you wish to defend against the claims set
forth in the following pages, you must take prompt action. You ure warned that if
you fail to do so, the case may proceed without you and a decree of divorce or
annulment may be entered against you by the Court, A judgment may also he
entered against you for any other claim or relief requested in these papers by the
Plaintiff. You may lose money or property or other rights important to you,
including custody or visitation of your children,
When the ground for the divorce is indignities or irretrievable breakdown of
the murriage, you may request murriage counseling, A list of mW'I'iage counselors
is available in the Office oCt he Prothonotary, Cumberland County Courthouse,
Curlisle, Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM "'OR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR
ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM
ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER OR CANNOT AI<'FORD ONE, GO '00
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LffiERTY AVENUE
CARLISLE, PA 17018
(717) 249.3166
counseling.
8. Neither the Pluintiff nor the Defendant is a member of the military or
naval service of the United States or its allles within the provisions of the Soldiers
and Sailors Relief Act of the COnb'l'eSS of 1940 and its amendments,
9. The purties havo been separated sil,ce December 1, 1997.
WHEREFORE, Plaintiff requests the Court to enter a decree of divorce based
upon the sepuration of the pllI'ties and the irretrievable breakdown of the murriage.
COUNT II . EQUITABLE D1STRmUTION
10. The averments set forth above llI'e incorporated herein,
11. The plll'ties have incurred vurious murital debts, which ure subject to
equitable distribution between them all marital debts,
12. The purties have accumulated vurious cash assets and material
possessions which ure murital property and as such, are subject to distribution
between them,
WHEREFORE, the Plaintiff requests the Court to equitably divide such
marital debt betweell them,
COUNT III . COUNSEL FEES, COSTS, EXPENSES AND ALIMONY
13. The averments set forth above ure incorporated herein.
14. Plaintiff is not in a financial position to meet the costs and expenses of
prosecuting this action and to pay reasonable counsel fees to her attorney, and she
is in need of alimony,
WHEREF'ORE, the Plaintiff requests the Court to assess counsel fees, costs,
expenses and alimony against the Defendant,
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HEBECCA S. LAUGHLIN,
Plaintiff
: IN THE COllHT OF COMMON PLEAS or
: CUMBEHLAND COUNTY, PENNSYLVANIA
: NO,ij"6/25lCIVIL TEHM
v.
HARRY B, LAUGHLIN 11,
Ddendant
: IN DIVOHCI':
CEHTIFICATE OF SEI{ VICE
I, Erin L, PlulI'ris, herchy certify Ihal a true and COI'I'cct copy of Ihe Complainl Undel'
Section 3301(c) 01' 3301(d) or The Divorce COdll in thc ahove enpljoned molleI' was duly
served upon the Defendunt, Hurry n. Lnughlin, 11, by depositing it in the U.S. Mnil, eel.tined,
restricted delivery, relul'll I'eceipt rcquestcd, on Mureh 6, 1998, uddressed us follows:
Harry B. Laughlin, 11
B12 Yorkview Drive
Granthum, PA 17027
1 hereby verify that Ihe statcnwnts mudI' in the foregoing IIrc 11'IW und eorreot. I
undcl'Htand thut fulse statements herein ure mudc subjeet to thc pcnulties of 18 Pa.C.S,
Scotian 4904, reluting to unswol'l\ falsifieation to uuthol'ilics,
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EHIN L. PHAlmlS
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In thc Court of COlUmon Plca~ of CIJMRERL^ND County. I'cnnsylvanla
nOMESTIC RELUIONS SECTION
RF.BF.CCA S, LAUGHLIN ) Docket Numher 98-1232
Plaintiff )
\IS, ) P ACSES Case Numher 307100068
HARRY B, LAUGHLIN ) ;271{1S
Defendant ) Other Slale ID Numher D~
CONSENT ORDER
AND NOW, to wit on thlg
30TH OAY OP' ArnII., 1999
IT IS HEREBV
ORllI~Rlm Ihat the 0 Complaint for Support or 0 Petition to Modify or IXJ Other
pn I t Ion for AP!.. filed on March 19, 1999 in the above captioned
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1lI1i1Il'r i.\ dismisscd ~rcjudice due to:
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fJ The Complaint or Petition may be reinstated upon written application of the plaintiff
f'elitioner, if filed within one year from date hereof.
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Scrvkc TyJIC M
Pnrm OE-505
Wnrker ID 21201
In fhe Court or COll1mon Pleas or CUM8ERI.AND COllnty, Penllsylvanla
1l0MESTIC RELATIONS SECTION
prmRC'ClI s. IJlUGHLIN ) Dockel Numhel' 00184 S 1998
Plainliff )
\'''i. ) PArSES Case Nnlllhel' 272100057
III1RPY B. LAUGHLIN ) rl.n("
Defendalll ) Olher Stale ID Nnlllher D~
!';.ill'lSENT ORUE.R
AND NOW, to wit on thl!
30'l'lt DJI'{ O\l' APRIl" 1998
IT IS HEREBY
ORI>ERED that the IXl Complaint for Support or 0 Petition to Modify or 0 Other
filed on
March 5, 1998
in the above captioned
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mallcr is dismissed wil~{1U1 prejudice due to:
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IX) Thc Complaint 01' Petition may be reinstated upon wrilten application of the plaintiff
pClilillncr. If filed within one year from date hereof.
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BY THE COURT:
.lUum:
Set vice Type M
flurm Ofl-~05
Wnrker In 21201
III the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
REBECCA S. lJ\UGHLIN ) Docket Number 00194 S 1999
Plaintiff )
\IS. ) P ACSES Case Number 272100057
fI/lRP.Y B. lJ\UGHLIN )
Defendant ) Otber Slale ID Number Dr-.. ;).r .~1{,.,
CONSENT ORDER
AND NOW, to wit on this --" 30'l'!l Oll't 01' APRIl., 1999
IT IS HEREBY
ORllERED that the !XI Complaint for Support or 0 Petition to Modify or 0 Other
filed on
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mnlter is dismissed wil.llo.uI prejudice due to:
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March 5, 199B
in the above eaptioned
[Xl The Complaim or Petition may be reinstated upon wriltcn application of the plaintiff
pet il ioncr. if filed within one year from date hereof,
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BY THE COURT:
Juom:
Sel vice Type M
Form OR-505
Worker ID 21201
'"lhe Court or Common PleM or CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
RESF.CCA S, LAUGHLIN ) Docket Number 00194 S 1995
Plainliff )
\IS. ) PACSES Case Number 272100057
flIIRP.'l S, LAUGHLIN )
Defendam ) Olber Slale 10 Number D~ J7.-37(,.,
CONSENT ORP.E,~
AND NOW, to winm this "'" 3o'tll DAY OP APRIL, 1999
IT IS HEREBY
OROERED that the [XJ Complaint for Support or 0 Petition to Modify or 0 Other
filed on
March 5, 1999
in the above capt ioncd
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mnller is dismissed ~ prejudicc due to:
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IX! The COlllplni11t or Petition may be reinstated upon written application of the plaintiff
petitioner. if filed within one year from date hereof.
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BY THE COURT:
JUDGE
Sel vlw Type M
Form ()E-~O.s
Worker ID 21201
In the Court 01' COll111lon l'lells 01' ClIMBERLANI>
DOMIISTIC RELATIONS SECTION
JUN 0 1 1998
County, l'ennsylvlInlll
REBECCA S, LAUGIlLIN ) Docket Nllmher 9S-1232
Plalmiff )
vs. ) PACSES Case Nllmhor 307100069
IlARRY B. LAUGIlLIN ) ,27tfl 9
Defendant ) Other SllIte ID Nllmher bl!..
CONSENT ORDER
AND NOW, to wit 011 thi,;
3GTH DAY OF APRIL" 1990
IT IS HEREBY
ORDERED that thc 0 Complaint for Support or 0 Petition to Modify or IXI Other
Pl'ltition for APL . filed 011 March 18, 1999 in the above captioned
matter is dismissed ~rejUdiCC due to:
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o The Complaint or Petition may be reinstated upon written application of the plaintiff
petitioner, if filed within one year from date hereof,
Consented:
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5-23-Ci6
Date
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BY THE COURT:
lID: R. J. Ehrl:l3y
cea plaintiff cn:l Marlrlt
JUDGE
Service Type M
Form OE-50~
Worker ID 21201