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IN THE COURT OF COMMON PLEAS
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,DEBORAH. ,LEE, ALBERT,
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Plaintiff
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..I.EIi:rS WIL.LIAM ALBERT, III,
Defendant
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PENNA.
No. 3399
..Civ:il 1998
DEe R EEl N-A- r, 8./J/A
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AND NOW, .., ,..,......,........" 19 ,~~..,. it is ordered and
decreed that", ,I?~,~'?~, ,I,ol??, .~I,o~?!l,~".""""",."""". plaintiff,
and ' .r.~:rI3, ,Wn:L,I;~, !\,I.~J;:~:r." ,:rJ:.I, , , , , , , , " " , , , , , , , , '" , , '. defendant,
are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet
been entered; None
The terms, provisions and conditions of a certain Separation
,&J:l9., ,P.:r:Op!'!,z:ty, S,ettl!'!rnent, Agreement, ,betwl'Ien, the ,pa:r:ties, ,dated. . ,
October 8, 1999, are hereby incorporated in this Decree by
'reference'as'fully'~s,though'~he'same'were'set'forth'herein 'at
length. Said Agreement shall not merge with, but shall survive
this De
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SEPARATION AND PROPERTY SElTLEMENT AGREEMENT
THISAGREEMENT,madethis ~'" day of ~mb-e..r ,1999,
by and between LEWIS W. ALBERT, III, (hereinafter referred to as "Husband") and DEBORAH
L ALBERT, (hereinafter referred to as "Wife").
WIT N E S SETH:
WHEREAS, Husband and Wife were lawfully married on September 22, 1979,
at Canisle, Pennsylvania; and
WHEREAS, there are no minor children to the marriage; and
WHEREAS, certain differences, disputes and difficulties have arisen between the
parties as a result of which they intend to live separate and apart for the rest of their natural
lives, and are desirous of settling fully and finally their respective financial and property rights
and obligations as between each other, including, without limitation by specification: the
settling of all claims between them relating to the ownership and equitable distribution of their
real and personal property; the settling of all matters between them relating to the past,
present and future support, alimony and/or maintenance of Wife by Husband or of Husband
by Wife; and, in general, the settling of any and all claims and possible claims by one against
the other or against their respective estate.
NOW, THEREFORE, in consideration of the mutual promises, covenants and
undertakings hereinafter set forth, Husband and Wife each intending to be legally bound and
to legally bind their heirs, successors and assigns hereby covenant, promise and agree as
follows:
1. SEPARATION
The parties acknowledge that they have been living separate and apart since on
or about June 9, 1998, and that they have the right to continue to live separate and apart from
each other and to reside at such place or places as they shall respectively deem fit, free from
any control, restraint or interference whatsoever by the other, subject to the further provisions
of this Agreement.
2. WARRANTY AS TO EXISTING AND FUTURE OBUGATIONS
Husband and Wife each warrant that neither has heretofore contracted for any
liability for which the other or the estate of the other may be responsible. The parties further
warrant that each will nowand.,at all times hereafter save harmless and indemnii'y the other
and the estate of the other from all liabilities incurred after the execution date hereof, as well
as from all liabilities of every kind which have been incurred heretofore by either party.
3. OUTSTANDING JOINT DEBTS
Husband and Wife acknowledge and agree that they have no outstanding debts
-2.
6. DIVISION OF PERSONAL PROPERlY
The parties have divided their separate and marital personal property to their
mutual satisfaction, and each of them shall own, independent of any claim or right of the
other, all items of personal property each now has in his or her possession, subject to the
further provisions of this Agreement.
More specifically, Husband hereby transfers to Wife, all of his right, title and
interest, in and to the following assets which shall be the sole and separate property of Wife:
(A) 1992 Chevrolet Lumina sedan; (8) Members First Federal Credit Union savings account
#76309-00; (C) Members First Federal Credit Union investment savings account #76309-05;
(D) Members First Federal Credit Union checking account #76309-11; (E) Members First
Federal Credit Union IRA #76309-15; (F) Members First Federal Credit Union savings account
#174670-00; (G) Members First Federal Credit Union investment savings account #174670-
05; (H) Ufe of Maryland, Inc. life insurance policy #01101085204; and (I) DriveKore, Inc.
Profit Sharing Plan #76309-16.
Wife shall imme~iately take all steps necessary to effectuate the removal of
Husband's name from the Members First accounts numbers 76309-00 and 76309-05. Wife
shall provide the requisite forms to facilitate this change in ownership.
Wife hereby transfers to Husband, all of his right, title and interest, in and to the
following assets which shall be the sole and separate property of Husband: (A) 1996 Ford F-
-4-
250 pickup truck; (8) Members Rrst Federal Credit Union savings account #76089-00; (C)
Members Rrst Federal Credit Union investment savings account #76089-05; and (D)
Members Rrst Federal Credit Union checking account #76089-11.
In order to effectuate an equal division of all of the aforementioned Members
Rrst Federal Credit Union accounts, and Wife's Ufe of Maryland. Inc. life insurance policy and
DriveKore, Inc. Profit Sharing Plan, Husband shall pay to Wife the sum of Rve Thousand Six
Hundred Rfty-Eight and 88/100 ($5,658.88) Dollars immediately upon execution of this
Agreement.
The parties acknowledge that, in addition to the foregoing assets and accounts,
some or all of the following accounts or assets constitute marital property: (A) Sun Ufe of
Canada account contract #77 -77000-335727; (8) Phoenix Investment Partners, Umited IRA
account #50-4662529; (C) Phoenix Investment Partners, Umited IRA account #84-5282535;
and (D) 515 shares common stock Venator Group (fonnerly Woolworth Corporation); (E)
Venator Group retirement plan; and (F) Venator Group 401(k) plan.
The parties hereby agree that Husband shall retain the Venator Group retirement
plan and Venator Group 401k plan which has heretofore been held in his name alone.
Husband shall assign and transfer to Wife a total of 258 shares of the common stock of
Venator Group and shall transfer and assign to Wife, via a Qualified Domestic Relations Order
to be prepared by Husband's attomey, the full value of The Phoenix Investment Partners
Umited IRA accounts and, simultaneously, shall assign to Wife a portion of the Sun Ufe of
-5-
9. TAX RETURNS
Husband shall deliver to Wife complete copies of all of their joint federal and
state income tax retums which they filed for the years 1993 and thereafter, to include all
supporting materials such as W-2 forms and 1099 forms.
10. MEDICAL AND HEALTH INSURANCE
Husband hereby agrees to pay to Wife the sum of One Thousand Eight Hundred
and 00/100 ($1,800.00) Dollars immediately upon execution of this Agreement, said sum to
be applied to Wife's future health and medical insurance premium costs. Husband shall have
no further obligation to provide health and medical insurance coverage for Wife, nor shall he
be obligated to contribute to the cost of Wife's premiums for said coverage.
11. DATE OF EXECUTION
The "date of execution" or "execution date" of this Agreement shall be defined
as the date upon which it is executed by the parties if they have each executed the Agreement
on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement
shall be defined as the date of execution by the party last executing this Agreement.
12. ADVICE OF COUNSEL
The provisions of this Agreement and their legal effect have been fully explained
to the parties by their respective counsel, Paul J. Esposito, Esquire, for Wife, and Bruce F.
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Bratton, Esquire, for Husband. The parties acknowledge that each has received independent
legal advice from counsel of their selection and that they have been fully informed as to their
legal rights and obligations, including all rights available to them under the Pennsylvania
Divorce Code of 1980, as amended, and other applicable laws. Each party confirms that he
or she fully understands the terms, conditions and provisions of this Agreement and believes
them to be fair, just, adequate and reasonable under the existing circumstances. The parties
further confirm that each is entering into this Agreement freely and voluntarily and that the
execution of this Agreement is not the result of any duress, undue influence, collusion or
improper or illegal agreement or agreements.
13. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE
The parties hereby agree that the terms of this Agreement shall be incorporated
into any divorce decree which may be entered with respect to them, however, this Agreement
shall not be deemed merged into such judgment or decree. This Agreement shall survive any
such final judgment or decree of divorce, shall be entirely independent thereof, and the parties
intend that all obligations contained herein shall retain their contractual nature in any
enforcement proceedings.
-9-
A. Each party hereby absolutely and unconditionally releases and forever
discharges the other and his or her heirs, executors, administrators, assigns, property and
estate from any and all rights, claims, demands or obligations arising out of or by virtue of the
marital relationship of the parties or otherwise, whether now existing or hereafter arising. The
above release shall be effective regardless of whether such claims arise out of any former or
future acts, contracts, engagements or liabilities of the other or by way of dower, curtesy,
widow's rights, family exemption or similar allowance, or under the intestate laws, or the right
to take against the spouse's will, or the right to treat a lifetime conveyance by the other as
testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's
estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory
of the United States, or any other countJy.
B. Except for any cause of action for divorce which either party may have or
claim to have, and except for the obligations of the parties contained in this Agreement as such
rights as are expressly reserved herein, each party gives to the other by the execution of this
Agreement an absolute and unconditional release and discharge from all causes of action,
claims, rights or demands whatsoever, in law or in equity, which either party ever had or now
has against the other.
15. WAIVER OR MODIFICATION TO BE IN WRITING
No modification or waiver of any of the terms of this Agreement shall be valid
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DEBORAH LEE ALBERT,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLANDCOUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
LEWIS WILLIAM ALBERT, Ill,
Defendant
NO. 3399 Civil 1998
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the Court for entry of a
divorce decree:
1. Ground for divorce: irretrievable breakdow'l under ~ 3301 (c) of the Divorce Code.
2. Date and manner of service of the Complaint: certified mail. return receipt
reouested. restricted deliverv on June 24. 1998.
3.
(a)
Date of execution of the affidavit of consent required
by ~ 3301(c) of the Divorce Code: by Plaintiff
10/6/99 ; by Defendant 10/8/99.
(b)(1) Date of execution of the Affidavit required by ~ 3301(d)
of the Divorce Code:
(2) Date of filing and service of Plaintiff's Affidavit
upon the Defendant:
4. Related claims pending: All economic claims have been settled bv the Darties
in their Separation and ProDertv Settlement Al!reement dated October 8. 1999.
5.
(a)
Date and manner of service of the notice of intention to file praecipe to
transmit record, a copy of which is attached:
(b) Date Plaintiff's Waiver of Notice in ~ 3301(c) Divorce was filed with the
prothonotary: 10/27/99.
Date Defendant's Waiver of Notice in ~ 3301(c) Divorce was filed with the
prothonotary: 10/27/99.
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Attorney,for f,laintiff
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6. Plaintiff has been advised of the availability of
counseling and that Plaintiff has the right to request that the
court require the parties to participate in counseling.
7. The Defendant in this action is not presently a member of
the United states Armed Forces or of any of its allies.
8. plaintiff requests the court to enter a decree of
divorce.
COUNT I
9. The averments of Paragraphs 1 through 8 herein are hereby
incorporated by reference thereto.
10. The marriage is irretrievably broken.
COUNT II
11. The averments of paragraphs 1 through 10 herein are
hereby incorporated by reference thereto.
12. plaintiff and Defendant have acquired property, during
their marriage until the date of their separation, which property
is marital.
13. Plaintiff requests this Court to preserve her right to
have all marital property of the parties equitably distributed.
COUNT III
14 . The averments of paragraphs 1 through 13 herein are
hereby incorporated by reference thereto.
15. Plaintiff lacks sufficient property to provide for her
reasonable means and is unable to adequately support herself
through appropriate employment.
16. Plaintiff requires reasonable support to adequately
maintain herself.
17. Plaintiff requests this Court to preserve her right to
seek an award of reasonable temporary alimony and additional sums
as may become necessary from time to time hereafter until final
hearing and permanent alimony thereafter.
COUNT IV
18. The averments of Paragraphs 1 through 17 herein are
hereby incorporated by reference thereto.
19. Plaintiff has employed the firm of GOldberg, Katzman and
Shipman, P.C. as counsel but is unable to pay the necessary and
reasonable attorney I s fees for said counsel.
20. Plaintiff is in need of hiring a real estate appraiser
and other experts and does not have the funds to pay the necessary
and reasonable fees.
21. Plaintiff requests the Court to allow her reasonable
counsel fees, costs and expenses, costs of experts and appraiser
pursuant to section 3502 of the Divorce Code and RUle of Civil
Procedure 1920.31 and to order such additional sums thereafter as
may be deemed necessary and appropriate, and at final hearing, to
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DEBORAH LEE ALBERT,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLYANIA
v.
NO. 3399 Civil 1998
--
LEWIS WILLIAM ALBERT, III,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA:
Kindly withdraw the following claims contained in the Complaint in
Divorce filed in behalf of Plaintiff in the above-captioned action: Count II for equitable
distribution of marital property, Count III for alimony and alimony pendente lite and
Count IV for counsel fees, costs and expenses.
GOLDBERG, KATZMAN & SHIPMAN, P.C.
By
;Ze.{;' '~I, 'l-itt ~ '
PAUL(d. E POSITO, ESQUIRE
320 Market Street
Post Office Box 1268
Harrisburg, PA 17108-1268
Supreme Court ID #25454
Attorneys for Plaintiff
SECT~ON 3. Wife shall hereafter be deemed to be an "Alternate
Payee" within the meaning of Code Section 414 (p) (8) and ERISA
Section 206 (d) (3) (K) and Husband has been a "Participant" in such
IRAs which were held in his name alone,
SECTION 4. The name, current mailing address, Social Security
number and date of birth of Husband/Participant are as follows:
Lewis W. Albert, III
89 pine Street
Dillsburg, PA 17019
Social Security No, 202-42-5849
Date of Birth: September 5, 1952
The name, current mailing address and Soci~l Security number
of Wife, hereinafter sometimes referred to as the "Alternate
Payee", are as follows:
Deborah L, Albert
2522 Interstate Drive
Harrisburg, PA 17110
Social Security No. 187-44-9592
Date of Birth: August 20, 1955
SECTION 5. Husband hereby assigns to Wife/Alternate Payee all
of his right, title and interest in and to the Phoenix Investment
Partners, Ltd, IRA account Nos, 50-4662529 and 84-5282535, Wife,
as the Alternate Payee, hereby accepts the assignment of such IRA
accounts and agrees that she will be solely and exclusively liable
for any taxes, penalties, interest or anything of like or similar
nature as the result of any distributions from such individual
retirement accounts hereafter.
2
SECTION 6. The change of title to such individual retirement
accounts shall become effective as soon as administratively
possible after acceptance of the Order as a QDRO by the Plan
Administrator or IRA Account Holder. After the Plan Administrator
or IRA Account Holder has confirmed the establishment of the
separate account for Wife/Alternate Payee, all payments from such
IRAs thereafter shall be at the election and direction of
Wife/Alternate Payee.
SECTION 7. This Qualified Domestic Relations Order shall not
require the IRA Account Holder to provide any type or form of
benefit or any option not otherwise provided unde~ the terms of the
existing IRA account except as expressly herein provided, nor will
it require the IRA Account Holder to provide any increase in
benefits whatsoever.
SECTION 8. This QDRO shall be deemed to be issued pursuant to
state domestic relations laws to enforce marital property rights of
the Wife/Alternate Payee who was heretofore the spouse of the
Participant. This QDRO shall relate to the period starting with
the entry hereof by the Court and ending when all benefits assigned
to Wife/Alternate Payee have been transferred or distributed by the
IRA Account Holder i.n conformity with the provisions hereof,
SECTION 9. It is intended that this QDRO will qualify as a
Qualified Domestic Relations Order. The provisions of this Order
shall be administered and interpreted in conformity with ERISA and
the Internal Revenue Code. The Court shall retain jurisdiction to
3
amend this Order only for purposes of establishing or maintaining
its qualification as a Qualified Domestic Relations Order and
either party may apply to the Court for such amendment, consistent,
however, with the terms of the Separation and Property Settlement
Agreement heretofore executed by the parties to this divorce
action.
SECTION 10, The Wife/Alternate Payee shall hold the plan
Administrator/IRA Account Holder harmless from any liabilities
which arise from compliance with this QDRO, including all
reasonable attorneys' fees which may be incurred in connection with
any claims which may be asserted because the IRA Account Holder
honors this QDRO. The IRA Account Holder shall not, however, be
responsible for any attorneys' fees or other costs incurred by the
Husband or by the Wife/Alternate Payee in connection with obtaining
or enforcing this QDRO,
SECTION 11. The Husband shall furnish a copy of this QDRO to
the IRA Account Holder when it has been entered by this Court. The
Husband shall inform the IRA Account Holder of the parties'
intention that this Order is intended to constitute a "Qualified
Domestic Relations Order". If the Wife/Alternate Payee, within
thirty (30) days of the entry by the Court of Common Pleas of this
Order, does not receive written notice at the address hereinabove
specified from the IRA Account Holder that the IRA Account Holder
has received a copy of this Order, then the Wife/Alternate Payee,
at her discretion, may provide such notice.
4
WHEREAS, Husband and Wife have, by the aforesaid Separation
and Property Settlement Agreement, settled all issues relating to
their interests in such assets of the Husband, including certain
Phoenix Investment Partners, Ltd. Individual Retirement Account
Nos. 50-4662529 and 84-5282535 held in the name of or for the
benefit of Husband alone heretofore;
NOW, THEREFORE, in consideration of the foregoing premises,
the parties do hereby stipulate and agree as follows:
SECTION 1. The parties request that this Court enter an Order
to constitute a "Qualified Domestic Relations Order" as defined in
Section 414 (p) (1) of the Internal Revenue Code of 1986, as amended
(the "Code"), and Section 206(d) (3) (B) of the Employee Retirement
Security Act of 1974, as amended ("ERISA").
SECTION 2. The parties intend that said Qualified Domestic
Relations Order shall apply to the following individual retirement
accounts or plan:
A. Phoenix Investment Partners, Ltd. Indi vidual
Retirement Account No, 50-4662529; and
B. Phoenix Investment Partners, Ltd . Individual
Retirement Account No, 84-5282535.
SECTION 3. The parties agree and stipulate that Wife shall
hereafter be deemed to be an "Alternate Payee" within the meaning
2
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SECTION 6. The change of title to such individual retirement
accounts shall become effective as soon as administratively
possible after acceptance of the Order as a QDRO by the Plan
Administrator or IRA Account Holder. After the Plan Administrator
or IR.A Account Holder has confirmed the establishment of the
separate account for Wife/Alternate Payee, all payments from such
IRAs thereafter shall be at the election and direction of
Wife/Alternate Payee.
SECTION 7. The parties agree that the Qualified Domestic
Relations Order requested herein shall not require the IRA Account
Holder to provide any type or form of benefit or any option not
otherwise provided under the terms of the existing IRA account
except as expressly herein provided, nor will it require the
IRA Account Holder to provide any increase in benefits whatsoever,
SECTION 8. The QDRO herein requested shall be deemed to be
issued pursuant to state domestic relations laws to enforce marital
property rights of the Wife/Alternate Payee who was heretofore the
spouse of the Participant. The QDRO shall relate to the period
starting with the entry thereof by the Court and ending when all
benefits assigned to Wife/Alternate Payee have been transferred or
distributed by the IRA Account Holder in conformity with the
provisions hereof.
SECTION 9. It is intended that the proposed QDRO will qualify
as a Qualified Domestic Relations Order. The provisions of such
Order shall be administered and interpreted in conformity with
4
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ERIS^ and the Inter'na 1 Revenue Code.
The Court shall retain
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jurisdiction to amend the Order only [or purposes of establishing
or maintaining its qualificctLion as a Qualified Domestic Relations
Order and either party may apply to the Court for such amendment,
consistent, however, with the terms of the Separation and Property
Settlement Agreement heretofore executed by the parties to this
divorce action.
SECTION 10.
The Wife/Alternate Payee shall hold the Plan
Administrator/IRA Account Holder harmless from any liabilities
which arise from compliance with the proposed QDRO, including all
reasonable attorneys' fees which may be incurred in connection with
any claims which may be asserted because the IRA Account Holder
honors the proposed QDRO.
The IRA Account Holder shall not,
however, be responsible for any attorneys' fees or other costs
incurred by the Husband or by the Wife/Alternate Payee in
connection with obtaining or enforcing the proposed QDRO,
SECTION 11. The Husband shall furnish a copy of the QDRO to
the IRA Account Holder when it has been entered by the Court, The
Husband shall inform the IRA Account Holder of the parties'
intention that the Order is intended to constitute a "Qualified
Domestic Relations Order".
If the Wife/Alternate Payee, within
thirty (30) days of the entry by the Court of Common Pleas of an
Order incorporating the terms of this Stipulation, does not receive
written notice at the address hereinabove specified from the
IRA Account Holder that the IRA Account Holder has received a copy
5
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