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Home My WebLink About98-01662 I ! I I I ~l c;.! <ti I i ~I ! I \.j c::t! ~'", C"""-\J '" ~ \ I \ , \ \ \ \ , \ , } , i , , , {' \. ~ , . ~ .~I ,~ '-.J ri , ~I '-0 ........ . Cl.. ~ ~j \ " '. MARRIAG'E SETTLEMENT AOREEMENT THIS AGREEMENT made thisk~_ day of~_9/)sL:- ." 1999, by llnd between JENNII<'ER A. PEI.'n:R. (here!nufler referred to m: ItWJI1EIt) und JASON R. PEFFER, (hereinafter referrt,d to as "HlISBANOlt), WITNESSETH: WHEREAS, HUSBAND and WIFE were lawfully marricd on September 21, 1996, in the Cumberland County, Pennsylvania, HUSBAND filed a Complaint in Divorce in Cumberlund County, Pennsylvania, docketed u198-1662 Civil Term on Murch 25,1998, The purties hereto ugree and covenant us ftll1ows: I. The parties intend to maintain sl'parate and permllnent domiciles and to live apart from each other. It is the intent and purpose of this Agreement to set forth the respective lights and duties of the parties while they conti nile to live apm1 from each other, 2. The parties have attempted to divide their matrimonial property in II manner which eonfomls to u just and right stundard, with due regard to the rights of each party. It is the intent of the pal1ies thut such division shall be nnal and shall forever deteonine their respective rights, The division of existing marital properly is not intended by the parties to constitute in any way a sale or exchange of assets. ~. FUl1her, the Pllrties agree to continue living seplll'Utcly and IIpllrtlhlll1 the other utllny plllce or plllees thllt he or she may select as they hllve Iwretot(lre bel)/] doing, Neither party shall molest, harnss, annoy, injure, threaten or interlcre with the other party in any mlllll'r whutsocver. Each pllrty muy curry on ilnd \'ngage in any employment, prntt'ssion, business or other activity as he or she lIlay deelll advisable Ii,,' his or her sole use and bl'netit. Neither party shall interfere with the llses, ownershill, enjoyment 01' disposition of any pf(lperty now owned lInd not specltied herein or property 11l,realler acquired by the other. 4. The l'Onsideration Ihr this contract and agreement is the mutual blmetit to be obtained by both of the partics hereto 1I11(Ithe covenants and ilgreements of each of the Pllrties to the other. The udequuey of the consideration till' III/agrecments herein contained is stipulated, confessed, and admitted by the purtics, IInd the pm1ies intend to be legally bound hereby. Elich party to the Agreemcntaeknowledges and (k'c1arcs thllt he or she, respectively: (I) is represented by eounsd of his or her own choosing; (2) is tillly and completely inlimned of the filets relating to the subject mallcr of this Agreement und of the rights und liabilities of the par1ies; (3) enters into this Agreement voluntarily atler receiving the advice of counsel; (4) has given careful and mature thought to the making of this Agreement; (5) has carefully read each provision of this Agreement; and (6) fillly and completely understunds eueh provision of this Agreement, both us to the subject matter and legal effect. This Agreement shall become ef/i;dive immediately as of the dllte of execution. 2 5. It is the purpose and intent of this Agreement to scllle fhrevel' and completely thc intcrcst and ohligutions of thl1 pUl'tics in all ProlWI.ty that they own sl1Plll'ately, und all property that would quality us lIluritul property ul1der the P\'nnsylvania Divorce ('ode. Title 23, Section 401(e), and dlUt is rcfcrrcd to in this Agreemcnt as "Maritlll Property", us hetwl'cn themsdves, their heirs und assigns, The purties have attempted to dividc their Marital Property in a manllCI' thut eOllt<IITIlS to a just und lilir standard, with due regard to the rights of cach Purty. The division 01' existing Maritul P/'Operty is not intended by the parties to constitute in any way a sale 01' exehllnge of assets, and the division is being effected without thc introduction of outside tlmds or othcr , L ~ I I' ,}< !' property not constituting a part of the Illarital estatl1. It is thc further purpose of this Agrel111lcnt to settle tbrever and completely any obligation under the Pcnnsylvunia DivOl'ee Code relating to spousul support or ulimony. 6. Each purty represents and warrants that he 01' she has made u fllllllnd fair disclosure to the other of ull of his or her property interests of any nuture, including any mortgage, pledge, lien, charge, security interest, eneumbrunce, 01' restliction to which uny property is subject. Each party further represents that he 01' she has lIlud\1 a tllll and fuir disclosurc of all debts and obligations of any nuture for which he or she is currently liable 01' may become Iiuble. Each tilrther represents und wun'unts that he or she hus not made uny gills 01' transfers for inadequate consideration of Marital Property without the prior consent of the other. Each Party ucknowledges that, to the extent desired, he 01' shc has had uecess to all joint and separntc Stute and Federul Tax Rctul'J1s filed by 01' on behalf of either 01' both Parties dUring marriugc, 3 b,) WIFE ngrees to wnive nny lInd nil interest which she may hl1ve in the l1ulomobiles in possession of the HUSBAND, They cach wl1ivc nny claim which they have in any automohile owned by the other pm1y. 12, INSURANCE AND EMPLOYEE B1~1I!.EFIT~: The parties agree thnt any lite insurance policies on the life of HUSBAND or WIFE or any other employee henefits, including but not limited to retirement, profit sharing or medical benelits of either party, shall be their own. WIFE waives all right, title und elnim to HUSBAND'S employee benefits, amI HUSBAND waives ull right, titl\l, and claim to any of WIFE'S employee benefits, 13. BENEFITS AND BANK ACCOUNTS: WIFE ngrees to WaiV\l ull right, title und interest which she may huve in thl' savings or dlceking or uny other bunk accounts of the I1USBAND. The HUSBAND agrccs to waive all interest which he has in the hank accounts of the WIFE, 14. DIVORCE: The parties both agree to cooperate with eueh other in obtaining u final divorce of the marriugc. It is ugrecd that the parties will execute and tile the consents necessary to obtain the divorce. Any party who fails to coopernte with obtaining the Divorce shall pay all the costs and legultees of the party who is seeking the divorce, 15. BRI<:ACH: If either purty brcaches any provisions of this Agreement, the other party should hnve the right, at his or her election, to sue till' clamugcs for such breach or seek such other remcdies 01' relief as may be nvailahle to him or her, und the pm1y breuching this contract will be responsible for payment of Icgal fees and costs incurred hy the other in enforcing their rights undcr this Agrcement. (> JASON R, PEFFER, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v, : CIVIL ACTION - LAW JENNIFER A. PEFFER, : NO, 98- IGot.ilCIVIL TERM : IN DIVORCE Defendant NOTICE You have been sued in court. If you wish to defcnd against the claims set forth in the following pagcs, you must takc prompt action. You are warned that if you fail to do so, the case may proceed withollt you and a decrec of divorce 01' annulment may bc entercd against you by the court. A jUdgment may Iso be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property 01' other rights important to you, including I;ustody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may rcquest marriage counseling, A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Streets, Carlisle. IF YOU DO NOT FILE A CLAIM FOR 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 AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Bar Associntlon 2 Liberty A venue Carlisle, PA 17013 Phone: (717) 249-3166 1 verify thut the ~tuten\ents mude in this Complaint are true and correct. I understand that false statements herein lire Illude subjccttll the penultics of 18 Pu,C.S, ~ 4904, relating to unsworn falsification to authorities. Date: 3/32-{ 91 a~ ~( ~~ Jason R, Peffer, Plaintif --' By: ?2 Paul Bl'adford 0 I' Attorneys for Pluintiff 78 W. Pomfret Street Car1\sle, P A 17013 (717) 258-8558 t1'~~lJ ()~S:: r-:-~-r'" :i5'U ~,' (-:) ~F-~ ~'j ~~,.:; ,..,';0" -:'"1 ~ ~":O .,,\1: ':')) ~1l I" r-) q ;1 ~ f.; it h,',; " R \h j-) '" ",1 (,,- , " " 'l!'fi ,-. -'1 11 f" I::~ , ".. ?';i"-) r..., ,11 I: ;1 ill_":' t/.;l " ,J~) r~i' '~l ;. ; :u ::Jr.: .~'," ",... <. ; i I I /.;",:, :;:1 .. ~ C) :l:! "...- ..- .', I 1(,1 'r fI, '11 i) l\' Q Vl I c.,c: U..'i I i , ,\'".. I "",I <]\ .,) I f'~ , , c." I ! C , ~~l , , ::~., " i c () I) :,'.' I..! I , \ I' I ~~] 1..1 ~0 I'" :'q .... ..~. In the Court of Common Pleas of C\JMBERLAND County, PennsylvanIa DOMESTIC RELATIONS SE:CTION JENNIFER A, PEFFER ) Dockel Number 98 1662 CIVIL PlahUlff ) VS. ) PACSES Case Number 651100767 !b.ilr:ssl" JASON R. PEFFER ) Defendanl ) Other Slate ID Number Qrllilr AND NOW to wit, this MARCil 23, 1999 it is hereby Ordered that: PETITIONER'S REQUEST FOR ALIMONY PENDEm'E LITE IS DENIED PURSUANT TO THE PARTIES' INCOMES AND DEFENDANT HAVING A CHILD SUPPORT OBLIGATION FOR THE PARTIES' ONE SON, DROI RJ Shadday xc I defendant platntHf 8, Gttflte, Esq, M. McKntght, Esq, ~~'-'\ N6\..1.-U 2.(3/)1'1'1 Edwilrd E. Guld0 -- JUDGE Service Type M Porm OE.DOI Worker ID 21005