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HomeMy WebLinkAbout98-01600 ~ ~I ... "'-l ~I ~ j; ~ J / . . I .il ./~ ;r-_r I " t .... ~I -I .~ I dl f' ~I I ().. 1:3" U l.plUttlo "001"", " AGRBEHBN'1' THX8 AGRlIMIlN'.r, made this <:,'f> ..:..~ day of ~J.')v\ Vl1 l,~,'l- , 1998, by and between CAROLYN A. LITTLE, (hereinafter referred to as "Wife"), and GEORGE E. LITTLE, (hereinafter referred to as "Husband") I Iii I '1' N E SSE '1' H: WHBREAS, Husband and Wife were lawfully married on July 9, 1994, and WHBRlAB, no children have been born of this marriage. NON THBRlrORl, in oonsideration of the premises and of the mutual promises, oovenants and undertakings hereinafter set forth and for other good and valuable oonEideration, reoeipt of whioh is hereby aoknowledged by each of the parties hereto, Wife and Husband, eaoh intending to be legally bound hereby, oovenant and agree as follows I 1. Disclosure of Asssts. Eaoh party asserts that he or she has made II full and fair disolosure of all of the real and personal property of any nature whatsoever belonging in any way to eaoh of them of all debts and enoumbranoes incurred in any manner whatsoever by eaoh of them, of all souroes and amounts of income received or reoeivable by eaoh party, and of every other fact rel~ting in any way to the subjeot matter of this agreement. These disolosures are part -1- of the consideration made by eaoh party for entering into this agreement. 2. Advioe of Couns~. Eaoh party has been represented by an independent attorney, who was seleoted by the party whom he represents, in the negotiation and preparation of this agreement. This agreement hae been fully explained to each party by that party's attorney. Each party has oarefully read this agreement and is oom- pletely aware, not only of its contents, but also of its legal effeot. 3. Lawfulne.. of Ssparation. It shall be lawful for eaoh par.ty at all times hereafter to live separate and apart from the other party at such plaoe as he or she may from time ~o time choose or deem fit. ~he foregoing provisions shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of the oauses leading to their living apart. 4. Freedom from Interferenos. Eaoh party shall be free from interference, authority, and contact by the other, as fully as if he or she were single and unmarried exoept as may be necessary to carry out the provisions of this agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to oohabit with the other, or in any way harass or lnalign the other, nor in any way interfere with the peaceful exis- tence, separate and apart from the other. 5. Relea.. of Claims. Wife and Husband each do hereby mutually remise, release, quit-olaim and forever discharge the other and the estate of suoh other, for all time to come, and for all purposes whatsoever, of and from any and all rights, titles and -2- , . interests, or claims in or against the property (inoluding inoome and gain from property hereafter aocruing) of the other or against the estate of suoh other, of whatever nature and wheresoever situate, whioh she or he now has or at. any time hereaft.er may have against lIIuch other, the estate of such other or any part thereof, whether arising out of Any former acts, contracts, engagements or liabilities of such other or by way of dower or curtesy, or claims .in the nature of dower or ourtesy of widow's or widower's rights, fanlily exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's willI or the right to treat a li.fetime oonveyanoe by the other as testamentary, or all other rights of a surviving spouse to partioipate in a deoeased spouse's estate, whether arising under the laws of (a) Pennsylvania, (b) any state, commonwealth or territory of the United States, or (c) any other country, or any rights whioh Wife may have or at any time hereafter have for past, present or future support or maintenanoe, alimony, alimony pendente lite, counsel foes, oosts or expenses, whether arising as a result of the marital relation or otherwise, exoept, and only exoept, all ri.ghts and agreements and obligations of whatsoever nature arising or which may arise under this agreement or for the breach of any thereof. It h the intention of Wife and Hueband to give to eaoh other by the execution of this agreement a full, complete and general release with respeot to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter aoquire, except and only except all rights and agreements and obligations of whatsoever nature arising or -3- . , which may arise under this agreement or for the breaoh of any thereof, subject, however, to the implementation and satisfAction of the conditions precedent as set forth herein above. 6. Karrantv as to Future Obliaation.. Each party repre- sents that they have not eontracted any debt or liability for the other for which the eatate of the other party may be responsible or liable, and that except only for the rights adsing out of this agreement, neither party will hereafter incur any liability whatsoever for which the other party or the estate of the other party, will be liable. Eaoh party agrees to indemnify or hold,the other party harmless from and against all future obligations of every kind incurred by them, i.ncluding those for neceasities. 7. A.sumDtion of Debts. Husband assumes and agrees to pay and hold the Wife harmless against the following debts and obliga- tionsl Husband will continue to pay the balance due for Wife's gall bladder surgery, the original amount having been $382.00 until paid in full. If any olaim, action or proceeding is hereafter brought seeking to hold the Wife liable on acoount of such debts or obligations, the HUsband will, at his sole expense, defend the Wife against any such olaim, aotion or prooeeding, whether or not well founded, and Husband will indemnify and hold Wife harmless from and against such olaim, action or proceeding. 8. Personal ProDerty. .. -IUIIII' akall nGlvi..v tb.g QIl.1'io-C a ~ ~rAn~faB~ls gl-ek. Otherwise, Wife and Husband do hereby acknowl- edge that they have heretofore divided the marital property including, -4- but without limitation, jewelry, olothes, furniture and other person- alty and hereafter Wife agrees that all of the property in the possession of Husband shall be the sole and separate property of Hus- band; and, Husband agrees that all property in the possession of Wife shall be the sole and separate property of Wife. Eaoh of the parties does hereby speoifically waive, release, renounce and forever abandon whatever claims, if any, she or he may have with respect to any of the above items which are the Bole and separate property of the other. 9. ~. All cash presently in the pOBBession of either party shall be and remain their separate property, free and olear of any olaim whatsoever on the part of the other. 10. Automobile to Husband. The Husband shall be the sole owner, free and olear from any olaim on the part of the Wife, of the Chevrolet Lumina. 11. Automobile t.o Wife. The Wife shall be the sole owner, free and olear from a.,y n1/l,im on the part of the Husband, of the 1986 Buick. 12. ProDertv Not Provided For. The parties hereto agree that they have, by the terms of this agreement, settled, to their mutual satiSfaction, all rights that either may have in their proper- ty, whether owned by them jointly or separately, real and personal, and wheresoever situated. Any property not speoifioally provided for in this agreement, which the Husband or Wife owns or has the right to -5- e,,~':I1 ~ " ~"o~ ".e~e'" "e" ~~ 0" ~,,\.. ~"e ,,\.. ot t~ ~l\o\.'" ~"e'" ~,,~'i 'o\,e ~",o. 0. ". 0 ." ~ 0"'.): "o"e . ~\\ ~'" t ~". ~l>" V ~o'" "'.. ). '0. ~ 0 . "ee \\e"e ~\.o'" \,'" -""'). ,\?l\o" · ).eVi ~. ",eO ~",o. .. ,~". 'oe.o "co. '" 00'" e"'~ I ~o ~.e 01\ ~ . \.\. ~\\e ~ \,.: .e~ eO~ '\?O ~\.'" "'~ 0. 0 ~"e ~~" e.'\? ' 0' , 0'.- ,..~ . ., 0' .'. ". ' ,0 000,,0 o~ .' ~ . 0' .. ,.. ..0' 0" ,.. ,.'O'l "'. ," ,>, ..0... 'O'l ,'0' ... . .. 0'. ,.. 0'" ,..' ,'0' ..'" ,.0. ,..' .,.. .." ". It \. ~ ~i: 0. El e\; ~..., o.e~ 0: :s: ..,.. ,.' ....0 .' . 'o' "..' ." ,... \ 0". '" , 0 , '0" .0. ,. "" .. .' .,. ,~. ,." ,.' ... ". " ..' . . · .,- .' .. 00 .. .. ,0' ,.. " · ,.0 .'. '0' .0' ,"'. .' . . ..,. ,. ,.' 0" .0' · .. ..' ..' ,0 . .,." ,'." ." "..' ..". ..,,'0 .,'0' .". dO · ..0 .", .e< ..' . . ." . . .." · '" - ",e o~ .>.'1\'0 a. <>_O..i:... ,,, ,'0" , ,.. "" ,.~' '0'" ." ""'_ ,.0- .'" . 0 . ' ,.0 . . ,.. "" "". 0"" 0,0 '0' · \ , " _.. ,0 ' ,," .>.\."z _0. e1\. 0 0" .,. . "'8 ". ~ t1." ." ." .. .. . ,0 ,.. ..' ..' ..' .', .. '0<" >.. .... .' ,0 ...... ,.. ,. .,. .. oO..e __t\> e9 '':I 'Co e" ... ".. .....,.' ,.'... .".. ).0 to: ~ o.eC ~\.e ee ').':1 .,\\~ 0: 0 0. OO~ o:~" 'f,...... """ .. .' ..' ,.,. ,..,. "...' .'" ," ,." ,,, 0' , .0 "" ,." 00 -"'. ,. ,.' ....." .. OV;.- ~ ~'Co a';'" "..eel "'0 0: ~.. ~",v "," 'Co" e.' J.eO'Co j:'Co\.e i.9 0: e\.' '(.0 e\\"P ) ,\?e. 'Co\\ \\1\8 q,\\~ · 'Co" 'CoO 00 ..:'(I.O~ O ~" " "PO ft \.1\ .:t..1\'Co '1\0.' " 'Co 0'" e"'" e1\V< 'f." ~\\"e ~\,1\~ 'Co\.e. 'to1\~, ",o.e~ e.1\':1 0. ~e. e\.e. \,).\; '0' t ~ ot e.1\ "\.e.'o e 0 e99 t\\\. 1\0. \. 0."z\'0 0.\\" oe."e 0: 0: 0" 1\ 'Co"e \,0'" <;)."ze · "z\.1\~ oe"O \\e.1!o e" 0 "eO 1\oe I t,\.\).e \,'" t"ee ."'0. 'Co ~e1\ "ee e.~ O. t\).\.\. ':I oo:"e \\e.9 "el ~q - :'(I.\.. ot ~ ).0'" \.9 f.o"z 0" ~ 0. ell' "eO: 'Co,,~,9 ot 'Co' ~.1\ ee 0:<;" 0.' ..El~ 1\'Co' ~e e. Fully and oompletely understands each provision of thie agreement. 15. He.dinq.. The headings or captions preoeding the paragraphs in this agreement are inserted for convenience of reference only And shall not be construed in interpreting this agreement. 16. Mutual C90p.~ation. The Husband and the Wife shall each ooncurrently herewith, or at any time hereafter on the demand of the other, exeoute any other doouments or instruments, and do or oause to be done any other acts and things as may be necessary or oonvenient to oarry out the intents and purposes of this agreement. 17. Sever.ability. If any provision in this agreement is held by a oourt of oompetent jurisdiotion to be invalid, void, or unenforoeable, the remaining provisions shall nevertheleBB continue in full force and effeot without being impaired in invalidated in Any way. 18. Reoonciliation. If there should be a reconciliation of the parties after the date of execution of this agreement, this agreement shall nevertheless continue in full force until it is modified or abrogated by another written instrument to that effect signed by eaoh of the parties hereto. 19. lYtu~e !arninqs. All income, earnings or other property reoeived or acquired by either party to this agreement on or after the date of execution of this agreement shall be the sole and separate property of the reoeiving or aoquiring party. Each party, as of the effective date of this agreement, does hereby and forever -7- .. waive, release and relinquish all right, title and interest in all such inoome, earnings or other property so reoeived or aoquired by the other. 20. Waiver of Riahts. Eaoh of the parties hereby irrevooa- bly walve all rights whioh he or she may have to request any oourt to equitably distribute the marital property of the parties or to have alimony, alimony pendente lite or oounsel fees awarded to either party, it being the express intention of the parties hereto to fully settle all cla,ims whioh they have with respeot to each other in this agreement. Eaoh of the parties further agree to oonsent to the entry of a Decree in Divoroe. 21. ~er of Breaoh. The waiver of any term, oondition, olause or provision of this agreement shall in no way be deemed or oonddered a waiver of any other term, oondition, olause or prov.i.sion of this agreement. 22. Su~iva~ of Aareement. If any term, oondition, olause or provision of this agreement shall, by its reasonable interpreta- tion, be intended to survive and extend beyond the termination of the marriage relationship presently existing between the parti.es hereto, said term or terms, condition or oonditions, olause or olauBes, provision or provisions, shall be so oonstrued, being the express intention of both parties hereto to have this agreement govern their relationship now or hereafter, irrespective of their marital status. 23. ~sdiotion. This agreement shall be oonstrued under the laws of the Commonwealth of Pennsylvania, and both parties oonsent -6- . ., And agree to the jurisdiction of the Court of Common Ple88 of Cumber- land County, Pennsylvania, on aocount of any suit or action brought with respect to this agreement or any provisions or matters referred to in any provisions thereof. 24. Aare.ment Bin4~~a on Partie. and Heire. This agreement shall be binding in all its terms, conditione, clauses and provisions of the parties hereto and their respeotive heirs, administrators, executors and assigns. 25. Hu.band'. Retirement. Wife shall receive through the entry of ~ Qualified Domestic Relations Order the total sum of Eleven Thousand Three Hundred Twelve and 84/100 ($11,312.84) Dollars of Husband's pension and profit sharing plan with Husband's employer, Exel Logistics, subjeot to all terms and oonditions of the Plan Administrator with respeot thereto. Husband and Wife shall cooperate in having an appropriate Qualified Domestic Relations Order submitted to the Plan Administrator at the earliest possible date. 26. Divorce. Husband and Wife agree to execute all, Affidavits of Consent and other documentation necessary to have a divorce decree entered pursuant to Section 3301(c) of the Divorce Code of the Commonwealth of Pennsylvania on the ground that the marriage i. irretrievably brOKen simultaneously with their execution of this agreement. -9- " . , 0"., 1./) CC '(.": 'j-!-. " we- <" ~ {-- ' ."" h- : c\.~ () ~ C>,l 51' , ! tl~ I ' ' ::--" i.'J c \(1 r :0. 1,1 ~ 01 ':1 C;J 0\ l.) , . f. '''\. m;ORm: ~;. l.ITT['~:, (S8# 181,-26-1,439) Plaintifl' IN TilE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL DIVISION CAROLYN A. LITTLg, (88# 21.1,-56-4898) Dol'end8,nt NO. 98-1600 CIVIL TERM : PRAECIPE TO TRANSMIT REC~ To the Prothonotary: Transmit the record, together with the following information to the court for entl~ of a divor.ce decree: 1. Ground for divorce: irretrievable breakdown under 53301(c) 11'~~<<13 of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the oomplai,nt: Maroh 27, 1998, US Mall, Certil'ied, Restrioted Dslivery, postage prepaid. 3. Complete ei ther paragl'aph (a) or (b). (a) Date of execution of the affidavit of consent required by 53]01(c) of the Divorce Code: by plaintiff November 5,1998 by defendant November 5, 1998 (b)(l) Date of execution of the affidavit required by S3301(d) of the Divorce Code: ; (7.) Date of filing and service of t.he plaintiff's affidavit upon the raspondent: 4. Related claims pending: No olaims raised. 5. Complete either (a) or (b). (a) Date and manner of service of t~e notice of intention to file praecipe to transmit rocord, a copy of which is attached: (b) Date plaintiff's filed with the Prothonctal'Y: Date defendant's filed with the Prothonotary: Waiver of Not.ioe in 53301(c) Divorce was /lId~-<.....~-- jJ, /~r0 , Waiver of Notice in 5330l(c) Divorce was /l/t~\h-r- !)L/ff6 , .-.~-:r:--- -.~ ~ " ;--;- or (Plaintiff)(JI14a:~U -- GEORGE E. LITTLE, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96 - /lA;( I CIVIL TERM CIVIL ACTION - LAW IN DIVORCE CAROLYN A. LITTLE, Defendant NOTICE TO DEFEND Am> CLAJK..lUGHTa You have been sued in ccurt. If you w1.nh to defend IlIJa.ln8t the claims set forth in the following pages, you muot take prompt /lotion. You are warned that if you fail to do so, the 0400 m/lV proDDed without you and a Decree of Divorce or annulment may be entered against you by the Court. A jUdgment may also be entered aga.i.nst you fur any other olaim or relief requested in these papers by the pla1nHff. You may lose money or property or other rights important to you, including oustody or visitation of your ohildren. When the ground for the divorce is indignities or irrotrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Offioe of the Prothonotary at the Cumberland County Courthouse, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPIRTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMINT II GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THIN. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCI. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TILIPHONI THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAI QIT LEGAL HELP. Qyrober1Aug_CQ~Q~4L_Atlociatio~ L~t.y_J\y,.QJlIa g.l!illlifL.._J'~_l1.!!U ~~1!WlwllgL1Ll,1L...2JJ!::1ll.fi. fl\div\littl..oom\J-" . GEORGE E. LITTLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF CU~~ERLAND COUNTY, PENNSYLVANIA . . v. NO. r; j, I(,vt! C(ud 1j..<~' CAROLYN A. LITTLE, Defendant CIVIL ACTION LAW IN DIVORCE COMPLAIN~ 1. The Plaintiff in this action is George E. Little, an adult individual, who currently resides at 5322 Oxford Drive, #103, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant in this action is Carolyn A. Little, an adult individual, who currently resides at 3262 Wakefield Road, Apt. C, Harrisburg, Dauphin County, Pennsylvania 17109. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this oomplaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on July 9, 1994, in Churohtown, Pennsylvania. 5. There have been no prior actions of divorce or for. annulment between the parties hereto in this OI:' any other jurisdir.:tion. 6. The Plaintiff avers as the grounds upon whioh this aotion is based is that the marriage between the parties hereto is irretrievably broken. -1- ~ C;) ~~~ ..:l 1--- .. r.,) ~I\;> ('I . , ~1i:; :[C; , ')1: (L C', i':;'~ el. I '-I.L n fJ. .J, (1"- u::: -.~ ' (:>,. ,r:l r(j r' ,:.,',; Cfl C\->- .- :L: ~l-~ u. (fj C) en I:,) ".f" .';'..-.' , " ~ ~.. C) , tG -~ r:,: t~ N ::5 c.., r.) ~u." h~('~ .., , ffi" .._~. l'.i... ') 0(': C' ~ tf) co,,;. C'') "1:< ~' ,.' --~ "'tit (!~; :'.!f[1 :.1.. lit:', inCl., 1-- .-.:. -' ..l.. ":5 ~ t~ en 0 . ,., ,"1' 2:: r~': 4.',-; t~ .. '"?j e IJ./ '~ , ( ). '.) .- F'" ". i...-, L\. (:1.;( . ~-! '.' ., 't; (" '(,') IT;" - ?~,;~ , G~ , : ~, -, 'IIIJ C. 1-] I.\.. i' ;-j: , /1. CO '":j C) (.n l) fl\div\oon..nt..ff GEORGE E. LITTLE, I IN THE COURT OF COMMON PLFoAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v. I NO. 98-1600 CIVIl, 'l'ERM I CAROIJYN A. LITTLE, I Defendant I CIVlL ACTION - IN DIVORCE APPIDAVIT OP CONSENT 1. A oomplaint in divoroe under S 3301(0) of the Divorce Code was filed on March 24, 1996. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the d&te of filing the oomplaint and service of the oomplaint. 3. I oonsent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I understand that I may lose rights ooncerning alimony, division of property, lawyer's fe~s or expenses if I do not claim them before a dlvorce is granted. I verify that the statements made in this aff.!davit are true and correot. I understand that false statements herein are made subjeot to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsifioa- tion to authorities. 11/;- /ff/ Ii j L, fI ' ,( . t:' ,J, 'td.l GEOR E. LITTLE, Plaintiff Date ~ .:I' ;",.. "' C'..; r:: ,~,:'.: ., In:,-' ~;- Cl' ~C'; tC!, l~~ i~j I,j'r; ! Oc ",. l ... '~'J t!) 1-)1., ',1 lllf.- , . .,,' II! ..." U to n: (h I c~. 'r- .--, , , [: :-.L L~.. CO ~~~ ,C) Q'i . \' ll\Il1.\UtUo,qdr\Q.\U ( v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-1600 GEORGE E. LITTLE, l'laintiff CAROLYN A. LITTLE, Defendant I CIVIL ACTION DIVORCE QUALIFIED DOMESTIC RELATIONS ORDBR AND NOW, this -1:ir J day of ~,t"... 6 u ing to the Court thatl , 1996, it appear- 1. The parties hereto are husband and wife ln a divorce aotion presently pending in this Court to the above term and number. 2. Plaintiff, George E. Little, Social Seourity No. 184-26-4439, date of birth, February 6, 1936, (hereinafter referred to as "Partioipant") is employed by Exel Logistios, and is a partioipant in the Exel Logistios Profit Sharing Plan (the "Plan"). 3. Defendant, Carolyn A. Little, Social Seourity No. 244-56- 4698, date of birth, August 31, 1937, (hereinafter referred to as "Alternate Payee") has raised a claim for equitable distribution of marital property in the above captioned proceedings. 4. Participant's current and last known mailing address is 5332 Oxford Drive, #103, Heohanicsburg, PA 17055. 5. Alternate Payee's current and last known mailing address is ,~C1Y A l,u,<\..tSdc\ ~(~.J , ~Clv"I'J"k~1 I QA 1/ IU'l -1- ., I IT 18 ORDERED, ADJUDGED, and DECREED as followsl 1. A portion of the Participant's account under the aforesaid plan is marital property subjeot to distribution by this Court. 2. This Court. finds that it has jurisdiction over the parties and the Plan subject to this Ord~r. This Court further specifically retains jurisdiction over the parties and Plan to establish or main- tain this Order as a Qualified Domestic Relations Order. 3. It is intended by this Court for this Order to oonstitute a "Qualified Domestic Relations Order," as defined in seotion 414 (p) of the Internal Revenue Code of 1986, section 206(d) (3)(B) of the Employ- ee Retirement Inoome Security Aot of 1974, and the Retirement Equity Act of 1984, as amended. 4. From the benefits whioh would otherwise be payable to the Participant, the plan shall pay to the Al t.ernate Payee the anlount of $11,750.00 as of December 31, 1997, of Participant's vested aocount balance under the Plan. The amount determined pursuant to this paragraph shall provide a benefit for the Alternate Payee under the Plan to be paid directly to the ,Alternate Payee. 5. The Alternate Payee may apply for the balance of the award at the earliest date permitted under the Plan, and in any event no later than the earlier of the date the Participant's interest in the Plan becomes fully vested, or the date the Partioipant becomes entitled to a distribution. The Participant's respeotive vested account balances under the Plan shall be reduced by tha amount required to be paid to the Alternate Payee as herein set forth. -2-