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limitation: the ownership and equitable distribution of all property owned by the parties;
and the settling of all related economic claims including but not limited to spousal support,
alimony and alimony pendente lite; and in general the settling of any and all claims or
possible claims of one against the other or against their respective estates; and,
WHEREAS, each party is fully familiar with the all of the property owned by the
parties and each party acknowledges having sufficient opportunity to investigate and
evaluate the property owned by the parties, and both parties now desire to settle and
determine his and her property rights and claims under the Divorce Code,
NOW, THEREFORE, in consideration of the mutual promises hereinafter set forth
and for other good and valuable consideration, receipt of which is hereby acknowledged
by each of the parties hereto, the parties, intending to be legally bound hereby, do
covenant and agree as follows:
1. DIVORCE
The parties agree to the entry of a Decree in Divorce pursuant to Section 3301(c)
of the Divorce Code. Both parties shall execute and file the requisite Consents and
Waivers with the Court contemporaneously with the execution of this Agreement. Wife
shall change her last name to her maiden name upon the issuance of a Decree in Divorce
in this mailer.
2. INCORPORATION BUT NOT MERGER INTO DIVORCE DECREE
This Agreement shall be incorporated but not merged into the Divorce Decree.
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3. TANGIBLE AND INTANGIBLE PROPERTY
Husband shall return to Wife the "Monopoly" game and the dart board case. In
addition, Husband shall pay Wife $500,00 after he receives his federal income tax refund,
Aside from the foregoing, the parties have divided between thom to their mutual
$atisfaction all items of tangible personal property and intangible property which they had
heretofore owned together. Neither party shall make any claim to such tangible or
intangible property in the possession of the other.
4. DEBTS AND OBLIGATIONS
Each party represents that they have not heretofore incurred or contracted any debt
or liability or obligation for which the other may be held responsible or liable, Each party
agrees to indemnify and hold harmless the other from and against all such debts, liabilities
or obligations of any kind which may have heretofore been incurred betwee" them, except
the obligations arising out of this Agreement.
5. MUTUAL RELEASES
Husband and Wife do hereby mutually release, remise, quitclaim and forever
discharge the other and the estate of the other from any and all claims either party has
now, ever may have or can at any time have against the other or the other party's estate
or any part thereof, whether arising out of formal contracts, engagements or liabilities of
the other party, arising by way of widower's right or under the Intestate Law, arising by any
right to take against the Will of the other party, arising out of the Divorce Code, Act No. 26
of 1980, as amended, including, alimony, alimony pendente lite, counsel fees and
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expenses, arising as a right to spousal support or arising from anything of any nature
whatsoever, excepting only those rights accorded to the parties LInder this Agreement.
8. BREACH
If either party to this Agreement resorts to a lawsuit or other legal action pursuant
to the provisions of the Divorce Code or otherwise to enforce the provisions of this
Agreement, the successful party shall be entitled to recover his or her reasonable attorney
fees, actually incurred, from the other as part of the jUdgment entered in such legal action,
whether in law, in equity, pursuant to the provisions of the Divorce COde or otherwise as
the same shall be determined by the Court.
7. WAIVER OF ALIMONY
Husband and Wife do hereby waive, release and give up any rights which either of
them may have against the other to receive alimony or other Post.divorce spousal
maintenance or support.
8. PROVISIONS AS TO CHILDREN
The parties agree that Husband shall claim Danielle Irene DiMemrno as a
dependent for federal income lax purposes in all even years, while Wife shall claim
Danielle Irene DiMemrno as a dependent for federal income taxes in all odd years,
provided the current shared custody arrangement remains in effect.
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1;1'1 (.)
JEFFREY B, DIMEMMO,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
\ ~- c c
NO, 98-_) [.t' (,
CIVIL TERM
STACEY K DIMEMMO,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
COMPLAINT UNDER SECTIONS 3301(Cl
AND 3301(0) OF THE DIVORCE CODE
1, Plaintiff is Jeffrey B. DiMemmo, an adult individual who currently resides
at 2 Raspberry Drive, Mechanicsburg, Cumberland County, Pennsylvania.
2. Defendant is Stacey K. DiMemmo, an adult individual who currently
resides at 103 North East Street, Apt 2, Carlisle, Cumberland County, Pennsylvania,
3, Plaintiff and Defendant have been bona fide residents 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 March 27,1993, in
Cumberland County, Pennsylvania,
5, There have been no prior actions of divorce or for annulment between the
parties.
6, The marriage is irretrievably broken.
7, The Plaintiff has been advised of the availability of counseling and that
she may have the right to request that the court require the parties to participate in
Counseling.
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c:\wp51\dlmcmmo\'ltipulalion,cus file /,/54JO.\).,.01 JUlll'IO,II)l).'
Father will provide to Mo/her any and allin/ormation whlGh hi) rooelvoB trom the sohool,
12. Neither party shall do anything whloh wlllllllunuto tho ohlld from the other,
13, Both parties shall havo Ulloml tolophollo contact with tho ohlld.
14. The terms of this Stipulation may ho olllorod as un Order of Court,
Witness:
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