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I.
The parties intend to Illuintuin scpurute and pennunent domiciles and to live apart from
each other. It is thc intent and purpose of this Agreemcnt to set tbrth the respective rights and
duties of the parties while they continue to live llpati from each other,
2,
The partieH have attempted to divide their matrimonial property in a manner which
conforms to a just and right standard, with due regard to the rights of ellch party, It is the intent
ofthe parties that such division shall be final and shall forever detemline their respective rights,
The division of existing mllrital property is not intended by the parties to constitute in any way a
sule or exchange of assets,
3.
Further, the parties agree to continue living separately llnd apart from the other at any
place 01' places that he or she may select as they have hel'etotbre been doing, Neither party shall
molest, harass, annoy, injure, threaten or interfem with the other party in any matter whatsoever.
Each party may carry on and engage in any employment. profession, business or other activity as
he or she may deem lldvisable for his or her sole use and benefit. Neither party shall interfere
with the uses, ownership, enjoyment 01' disposition of any property now owned and not specified
herein or property hereufter acquired by the other,
4.
The consideration for this contruct and agreement is the mutual benefit to be obtained by
both of the parties hereto and the covenunts and agreements of each of the parties to the other,
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The adequacy of the considel'lltioll lor ull agreements herein contained is stipuluted, confessed,
und admitted by the parties, and the purties intend to be legally bound hereby,
Each party to the Agreement ueknowledges and deelurcs und lItlinns the lollowing
lnfonnation to be true und correct:
(I) WIFE is represented hy counsel of her own choosing, namely Hubert X,
Gilroy, Esquire of Broujos & Gilroy, p,c.;
(2) HUSBAND is represented by counsel of his own choosing, namely Daniel W,
DeAnnent, Esquire of Irwin, McKnight & Hughes;
(3) Each party is fully and completely intolmed of the facts relating to the subject
mlitter of this Agreement and of the rights und liabilities of the parties;
(4) Each party enters into this Agreement voluntarily aileI' receiving the advice of
counsel;
(5) Each party has given careful and mature thought to the making of this
Agreement;
(6) Each party has earcfully read each provision of this Agreement; and
(7) Each party fully and completely understands each provision of this
Agreement, both as to the subject matter and legal effect.
This Agreement shall become effective immediately us of the date of execution,
5.
It Is the purpose and intent of this Agreement to settle forever and completely the interest
and obligations of the parties in all property thut they own separately, und all property that would
qualify us marital property under the Pennsylvania Divorce Code, Title 23, Section 3301(e), and
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that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and
assigns. The parties have attempted to divide their Mnritall'ropel1Y in a manner that (:onfbnns to
a just and fuir standul'll, with due regard to the rights of ench i'urty, The division of existing
Maritnl Property is not intended by the parties to constitute in nny way a sllle or exchung(l of
assets, and the division is being effected without the introduction of outside funds or other
property not (:onstituting a pali of the mnritul estate,
It is the further purpose of this Agn~ement to settle forcver and completely any obligation
under the Pennsylvunia Divorce Code reluting to spousal support or alimony.
6.
Each party represents and warrunts that he or she hilS made a full and fair disclosure to the
other of all of his or her property interests of any lIlIture, including any mortgage, pledge, lien,
charge, security interest, encumbrance, 01' restriction to which any property is subject. Each
party further represents that he or she has made a full and fail' disclosure of ull debts and
obligations of any nature for which he 01' she is currently liable or may become liable, Each
further represents and warrants that he or she has not made any gifts or transfers for inadequate
consideration of Marital Propeliy without the prior consent of the other,
Each Party acknowledges that, to the extent desired, he or she has had access to all joint
and separate State and Federal Tax Returns filed by or on behalf of either or both Parties during
marriage,
7.
REAL ESTATE: WIFE hereby agrees to transfer to HUSBAND all right, title and
interest by virtue of a quit claim deed in the real property which comprises the marital residence
located at 901 Mount Rock Road, Carlisle, Cumberland County, Pennsylvania. HUSBAND
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hereby agrees to pay to WIFE the slim of Twenty.Five Thousand and 00/100 ($25,000.00)
Dollars, payment to be made directly to WIFE within Sixty (ClO) duys ITom the date of this
Agreement. HUSBAND fUl1her ugrecs to indemnify und hold hunnless WIFE fromuny and all
liability which may arise, subsequent to WIFE vucuting the promises, out of or occurring in
relation to the subject property, HUSBAND hereby ugrees to make reasonable elforts to remove
WIFE'S name fromuny and all mortgage and reluted documents within Three (3) months of the
date of this Agreement, and WIFE agrees to cooperate in the removal of her nume ITom said
mortgage and related documents,
8,
SUPPORT: It is the mutual desirc of the parties that HUSBAND wil1not be required to
pay support to the WIFE, WIFE wil1not provide any financial support to the HUSBAND. The
parties also waive any right they have to receive alimony or alimony pelldente lite payments
from the other following the entry of the Divorce Decree in this matter.
9,
PERSONAL PROPERTY: The partics hereby agree that all personal property acquired
during the marriage has been equitably divided between the parties to their mutual satisfaction
and agreement.
The WIFE hereby waives all right, title and interest which she may have in any personal
property herein designated as HUSBAND'S, HUSBAND likewise waives any right, title and
interest which he has in the personal property designated as WIFE'S, Henceforth, each of the
parties shall own, have and enjoy independently of any claim or right of the other party, all items
of personal property of every kind, nature and description and wherever situated, which are then
Page 5
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owned or held hy or which may hereafter belong to the HUSBAND or WIFE with full power to
the HUSBAND or the WIFE to dispose of sume us t\tlly and effectuully, in ull respects ami for ull
purposes as if he or she were llnmurried,
Each party agrees thutneither will incur ohligutions, licns 01' liuhilities on uceount of the
other and thut from the datc of this Agreement, neither party shall contract or incur ohligations,
liens or uny liability whatsoever on uecollnt of the other.
Further, WIFE does hereby release, waive und forever discharge HUSBAND from any
und all claims she has now, ever may have or can at any time have ugainst HUSBAND or his
estate or any part thereof, whether arising out of fonnal contracts, engugements or liabilities of
HUSBAND, arising by way of widower's right or under the intestate Law arising by any right to
take against the HUSBAND'S will.
HUSBAND does hereby rcleuse, waive und t(lre'ler discharge WIFE fi'om any und all
claims he hus now, evor may have or cunat any time huve against the WIFE or her estute or any
part thereof, whether urislng out of t(mnal eontructs, engagements or liabilities of WIFE, arising
by way of widower's right or under the intestute Law arising by uny right to take against the
WIFE'S will.
10,
ASSET ACCOUNTS I BANK ACCOUNTS: WIFE hereby waives all right, title and
interest which she may have in any and all asset accounts owned during the murriage and titled in
HUSBAND'S name alone or jointly titled in the namcs of HUSBAND and WIFE, Further,
WIFE hereby waives all right, title and interest which she may have in any and all asset accounts
owned jointly bctween WIFE and the parties minor daughter, Pamelyn S, Snyder, HUSBAND
herehy waives ull right, title und interest which he may have in any and all asset accounts owned
Page 6
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during the malTiage and titled in WIFE'S nume alone. WIFE hereby agrees to take any and all
action necessary to transfer legultitlc to any such IlCcounts which may cUlTently be titled in the
. joint names of HUSBAND and WIFE into HUSBAND'S numc ulone within thirty (30) days
from the date of this Agreemcnt. WIFE further ugrces to take any and all action neeessury to
transler legal title to any such accounts whicllmuy cUlTently be titled in the joint names of WIFE
and the parties' minor daughter, Pamelyn S, Snyder into the joint names of HUSBAND and
Pamelyn S, Snyder within thirty (30) days from the date of this Agreement.
The parties hereby agree that neither party shall take any action to withdraw funds, or in
any other way deplete, use, liquidate or otherwise intentionally diminish the valuc of any marital
asset accounts which havc not already been divided between the parties at or subsequent to the
date of separation, Further, the parties hereto agree thai in the event either party withdraws funds
or in any other way depletes, uses, liquidates or otherwise intentionally diminishes the value of
any such marital asset account, then the party so diminishing the value of said account shall be
responsible for the repayment of said moneys prior to tlnal distribution of property pursuant to
this agreement.
II.
AUTOMOBILES: The parties hereby agree that WIFE shall retain the 1989 Pontiac
Gl'and Prix which is currently in her possession, and the HUSBAND shall retain the 1992
Chevrolet Lumina and the 1968 Chevrolet Pick-up Truck which are cUlTently in his possession.
WIFE hereby waives all right, title and interest in the 1992 Chevrolet Lumina and 1968
Chevrolet Pick-up Truck cUlTently in possession of HUSBAND. HUSBAND shall hold WIFE
Page 7
harmless for any and all liability associated with the purchasc, use and ownership of the 1992
Chevrolet Lumina, 196R Chevrolet Pick-up Truck and any vchlclc hc may now 01' in the future
own, and shall be solely rcsponsible for all insurance und other Hllandal responsibility associated
with said vehicle.
HUSBAND hereby waives all right, title and interest in the 1989 Pontiac Orand Prix
which is currently in possession of WIFE. WIFE shall hold HUSBAND harmless for any and all
liability associated with thc purchase, use and ownership of thc 1989 Pontiac Grand Prix and any
vehicle she may now or in the future own, and shall be solely responsible for all insurance and
other financial responsibility associated with said vehicle,
The parties shall cooperate in the transfer of titlc of thc respective vehicles into individual
names, WIFE agrees to take any action necessary to transfer title to the 1992 Chevrolet Lumina
into to HUSBAND'S name alone within sixty (60) days from the execution of this Agrcement,
or within seven (7) days from the earliest date upon which posscssion of the physical title to said
vehicle may be procured from the cllrrent lienholder and is available for the parties signature to
effectuate said transfer of title in association with HUSBAND's sale or refinance of the vehicle,
whichever occurs first. Likewise, HUSBAND agrees to take any actioll necessary to transfer title
to the 1989 Pontiac Grand Prix into to WIFE's name alone within sixty (60) days from the
execution of this Agreemeni, or within seven (7) days from the earliest date upon which
possession of the physical title to said vehicle may be procured from the current lienholder and is
available for the parties signature to effectuate said transfer of title in association with WIPE's
sale or refinance of the vehicle, whichever occurs first.
Page 8
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12,
MARITAL DEBTS: It is mutuully ugl'eed hy und hetwcen the purties thut WIFE shall
assume ull liability for und pay and indemnify the HUSBAND uguinst ull debts incurred by
WIFE after the date of separation, WIFE represents ul1d wUl'rants to HUSBAND thut sin4:e the
parties' maritlll separation she has not contructed 01' incurred any deht or )inbility for which
HUSBAND or his estate might he responsible und WIFE further represents und warrunts to
HUSBAND that she will not contract 01' incur any debt or liability uller the execution of this
Agreement, for which HUSBAND or his est ute might be responsible, WIFE shall indemnify and
save HUSBAND harmless fhllll any and all claims or demnnds made against him hy reason of
debts or obligations incurred by her.
HUSBAND shall nssume all liability for and puy and indemnify the WIFE against all
debts incurred by HUSBAND aileI' the dute of separation, HUSBAND represents and warrants
to WIFE that since the palties' marital separation he has not contracted or incurred any deht or
liability for which WIFE or her estate might be responsible and HUSBAND further represents
and warrants to WIFE that he will not contract or incur any deht or liahility aileI' tbe execution of
this Agreement, for which WIFE or her estate might be rcsponsible, HUSBAND shall indemnify
and save WIFE harmless from any and all claims or demands made against her by reason of
debts or obligations ineun'ed hy him,
13,
INSURANCE AND EMPLOYEE BENEFITS: The parties agree that any life
insurance policies on the life of HUSBAND or WIFE or uny other employee henefits, including
but not limited to retirement, pension, profit shuring or medical benefits of either party, shall be
Page 9
their own. WIFE wllives ull right, litle und elulm to HUSBAND's employee benefits, und
HUSBAND wuives ull right, litle, und cluim to any of WIFE'S employee benefits,
IIUSBAND ugrees to luke uny und ull uction necessllry IInd to cooperute, within thirty
(30) duys li'om the dute of this Agreement, in the removul of his nume us II beneficiary or owner
from any und ull pension, protit shuring or other retirement uccounts which WIFE may currently
possess, Similurly, WIFE ugl'ees to luke uny and 1111 uction necessary and to cooperate, within
lbirty (30) duys from the date of this Agreement, in the removul of her name as a beneficiary or
owner from uny and all pension, pl'Otlt shul'ing or othcr retirement uccounts which HUSBAND
muy currently possess,
14,
CUSTODY: The purties hereto, being the nutural pUl'ents ofPumelyn S, Snyder, born
June II, 1994, and desiring to set forth the rights and obligations I'elating to the e\lstody of
Pamelyn, hereby agree as follows:
A. The parties shall enjoy shured legal custody of the minor child, Pamelyn S. Snyder;
B. The HUSBAND I FATHER shull cnjoy primary physical custody oflhe minor child,
Pamelyn S, Snyder:
C, The WIFE I MOTHER shall enjoy periods of visitation with the minor child subject
to the following schedule:
I. On alternuting weekends, WIFE I MOTHER shall enjoy custody of the minor
child each Suturday and Sunduy beginning ut 9:00 a,m, und continuing until
9:00 p.m" at which time the minor child will be returned to the custody of the
HUSBAND / FATHER.
D. The parties shall shure or alternule custody of the minor child on holidays in
accordance with the following
Page 10
I. . Ch!istm~s: During the Christmas holidays custody shall alternate between
parties, with one parcnt enjoying custody beginning on Christmas Eve at
12:00 noon and continuing until 12:00 noon on Christmns Day, and the other
parent enjoying custody bcginning on Christmas Day at 12:00 noon and
continuing until 12:00 noon on the day tollowing Christmas, This schedule
shall alternate on an annual basis,
2. The holidays of Easter, Memorial Day, FOUl1h of July, Labor Day and
Thanksgiving shull be ulternated bctween the parties from holiday to holiday,
with custody on each holiday beginning at 9:00 a,m, and continuing until 9:00
p,m.
3, HUSBAND / FATHER shall enjoy custody of the minor child on Fathers Day
and WIFE / MOTHER shull enjoy custody of the minor child on Mothers
Day, with custody on each holiday beginning at 9:00 a,m, and continuing until
9:00 p,m,
4. The parties hereto agree to equally share transportation for the applicable
transfers of custody as outlined herein,
5, HUSBAND / FATHER shall claim the minor child, Pamelyn S. Snyder, as a
dependent for any and all tax filings which he may be required to make to any
governmental or municipal Ilntity.
15.
DIVORCE: The parties both agree to cooperate with each other in obtaining a final
divorce of the marriage, It is agreed that the parties will execute and tile the consents necessary
to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all
the costs and legal fees of the party who is seeking the divorce,
Page I J
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16.
BREACH: If either party brellches IIny provisions of this Agreement, the other party
shall have the right, at his or her ele,.tion, to sue lor damllges for such brellch or seek such other
remedies or relief as may be IIvailllble to him or her, and the party brellching this contract should
be responsible for payment of legal fees and costs incurred by the other in cnlorcing their rights
under this Agreement.
17,
ADDITIONAL INSTRUMENTS: Each of the parties shall /Tom time to timo, at the
request of the other, execute, acknowledge and deliver to thc other party any IInd all further
instruments thllt may be reasonably required to give full force and effect to the provisions of this
Agreement.
18,
VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect
have either been fully explained to the parties by their respective counsel, or have been fully
reviewed and understood if not represented by counsel, and ellch party acknowledges that the
Agreement is fair and equitable, and that it is being cntered into voluntarily, and thllt it is not the
result of any duress or undue influence, Thl. Pllrties agree that unless otherwise specificlllly
provided herein, this Agreement shall continue in full lorce and elTect after such time as a final
Decree in Divorce may be entered with respect to thc parties, The p1ll1ies further agree that the
tenns of this Agreement shall be incorporated into IIny Divorce Decree which may be entered
with respect to them, It is the plll1ies' Intent that this Agreement docs not merge with the Divorce
Decree, but rather shall continue to have independent contractual significance. Each party
Pagel2
maintains his 01' her contractulll remedies as well as court ordered remedies as the result of the
aforesaid incorporation or liS otherwise provided by luw or statute, Those remedies shall include,
but not be limited to, damuges rcsulting from breach of this Agreement, specific enfbrcement of
this Agreement und remedies pertaining to fililure to comply with un order of court or agreement
pertaining to equitable distribution, ulimony, alimony pendente lite, counsel fees and costs as set
forth in the Pennsylvaniu Divorce Code 01' other similar statutes now in effect and as amended or
hereafter enucted,
19,
ENTIRE AGREEMENT: This Agreement contains the entire understanding of the
parties and there ure no representations, warranties, covenants or undertakings other than those
expressly set forth herein,
20.
APPLICABLE LAW: This Agreement shall be construed under the Laws of the
Commonwealth of Pennsylvania.
21.
PRIOR AGREEMENTS: It is understood and agreed that any and all property
settlement agreements which mayor have been executed prior to the date and time of this
Agreement are null and void and of no effect.
22.
PAYMENT OF COSTS: Elich pllrty shall be responsible for their own attorneys fees
incun'ed in the settlement of the divorce and economic issues surrounding this divorce.
. Page 13
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TERESA E. SNYDER, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
v I CIVIL DIVISION - LAW
I
SAMUEL J. SNYDER, I NO. (I L .2/ it.,. CIVIL 1998
Defendant I
I IN DIVORCE
NOTICE TO DErEND AND CLAIM RIGHTS
You have been eued in Court. If you wish to defend against the
olaims set forth .i.n the following pages, you must take prompt
aotion. You are warned that if you fail to do so, the oase may
prooeed without you and a deoree of divoroe or annulment may be
entered against you by the Court. A judgment may also be 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, inoluding oustody or visitation of your ohildren.
When the grounds for divoroe .115 indignities or irretrievable
breakdown of the marriage, you may request marriage oounseling. A
list of marriage oounselors is available in the Prothono'tary' s
Offioe at the Cumberland County Courthoufle, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM rOR ALIMONY, DIVISION or PROPERTY,
LAWYER'S rEE8 OR EXPENSES, BErORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THIM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELBPHOIIE THE
OFrICI SKT FORTH BELOK TO FIND OUT KRERE YOU CAN GET LEGAL
HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
717-249-3166
~
TERESA E, SNYDER, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
v I CIVIL DIVISION - LAW
I
SAMUEL J. SNYDER, I NO. 9 f' ;J 1ft" CIVIL 1998
Defendant I
I IN DIVORCE
Q2HPLAINT
Pl&intiff, Teresa E, Snyder, by her attorneye, Broujos , Gilroy,
P.C" sets forth the followingl
1
Plaintiff, Teresa E. Snyder, is an adult individual residing at 901
Mt. Rook Road, Carlisle, Cumberland County, Pennsylvania.
2
Defendant, Samuel J. Snyder, is an adult individual residing at 901
Mt. Rock Road, Carlisle, Cumberland County, Pennsylvania.
3
The parties were married on December 9, 1989, in Newville,
Cumberland County, Pennsylvania.
4
Plaintiff and Defendant have lived continuously in the Commonwealth
of Pennsylvania and in Cumberland County for at least six months
prior to the commenoement of this action,
5
There have been no prior actions for divorce or annulment in this
or any other jurisdiction within the knowledge of the Plaintiff.
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TERESA E. SNYDER,
Plaintiff
: IN TIm COURT (W COMMON PU:AS OF
: CUMBERLANI) COUNTY, PENNSYI,V ANIA
v.
CIVIL ACTION - LAW
SAMUEL J. SNYDER,
Defendant
98-2186 CIVIL TERM
IN DIVORCE
DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT
The defendant, being duly sworn according to law. deposes and says:
I. I have been advised of the availability of marriage counseling and understand that I
may request that the court require that my spouse and I participate in counseling,
2, I understand that the cOllrt maintains a list of marriage counselors in the Prothonotary's
Office, which list is available to me upon request.
3. Being so advised, 1 do not request that the court require that my spouse and
participate in cOllnseling prior to a divorce decree being handed down,
I verilY that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa, C.S. Section 4904 relating to
unsworn falsification to authorities,
Date: February n_. 1999
~~JlULQ~ Q_g1~.k--.../ _
SAMUEL J. SNYD .
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