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HomeMy WebLinkAbout98-04408 1 i 1 I \ ..... ~ I ~ I ~ , j ~ I ~ . t .::s ~ I I ~ ~ ,I 1 . I . .') . .. CJ I c.. 'I ~, ~1 ~ ~ ~I \ \ \ \ i ; ! , ; / , . . -t ,/], 9f' ii./ (J1~V /I,;'J4, {:l3.<}f' ~r{~ /"",:...d/ 71; tt; d,d- iLh~~ ;7 . ,t,*)d;0-~ .. . ~ 'I "{.. '."', .J ~ . SEPARATION AND PROPERTYSE1TI.EMENT A (iREEMENT THIS AGREEMENT, made this /0/7 day of \/. .t..C- , 1999, by and between AI.ESI/A D. YOUN(,~ of 31 Water Street, Walnut Buttom, Cumberland County, Pennsylvania, 17266, party of the first part, hereinafter referred to as "Wife", AND DA VID L. YOUNG, of 1770 Walnut Bottom Road, Newville, Cumberland County, Pennsylvania, 17241, party of the second part, hereinafter referred to as "HusbtlnIJ", WITNESSETH: WHEREAS, Husband and Wife were married on June 17, 1983 in Newville, Cumberland County, Pennsylvania; and WHEREAS, Husband and Wife are residents of the Commonwealth of Pennsylvania and have been so for at least the past six months; WHEREAS, certain differences have arisen between the parties hereto which have made them desirous ofliving separate and apart from one another; and WHEREAS, Husband and Wife desire to settle and determine certain of their marital rights and obligations, and make an equitable distribution of their marital property, determine their rights to alimony and support and any other matters which ,may be considered under the Divorce Code; and WHEREAS, it is the intention and purpose of this Agreement to set forth the respective rights and duties of the parties while they continue to live apart from each other and to settle all financial and property rights between them; and '. ,', of income of both parties, including but not limited to medical, retirement, insurance or other benefits; the contribution or dissipation of each part in the acquisition, preservation, depreciation, or appreciation of marital property, including the contribution of a party as a homemaker; the value of the property set apart to each party; the standard of living of the parties established during their marriage; the economic circumstances of each party, including federal, state and local tax ramifications, at the time of the division of the property is to become effective; and whether the parties will be serving as the custodian of any dependent minor children, 3.2 The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets and the division is being effected without the introduction of outside funds or other property not constituting marital property, The division of property under this Agreement shall be in full satisfaction of all rights of equitable distribution of the parties. 3.3 Persollal Propertv. The parties acknowledge that they have divided their personal property, tangible and intangible, to their mutual satisfaction, The parties further acknowledge that they have the cash, accounts, or other tangible and intangible property in their possession that they wish to have an neither will make any claim whatsoever against the other party for any other items of personal property or assets that in other party's possession, 3.4 Life /1I.WlrIlIlce. Each party agrees that the other party shall have sole ownership and possession of any life insurance policies owned by the other party. Each party shall have the right to borrow against, cash in policies, change beneficiaries, and exercise any other incidents of ownership of the respective policies free of any right or claim by the other party, Each party agrees to sign any documents necessary to waive, relinquish, or transfer any rights on such policies to the respective party who presently owns such policies, 3.5 SubseIluent/v ACIIuired ProfJerlv. Husband and Wife agree to waive and relinquish any and all right that he or she may now have or hereafter acquire in any real or tangible personal property subsequently acquired by the other party, Husband and Wife specifically agree to waive and relinquish any right in such property that may arise as a result of the marriage relationship. 3.6 Real Estate. The parties are the joint owners of real estate located at 1770 Walnut Bottom Road, Newville, Cumberland County, Pennsylvania which property is currently held in the parties' joint names. The property is encumbered with a mortgage due and owing to Dauphin Deposit Bank and Trust Company, or its successors, Wife shall execute a special warranty fee simple Deed conveying all of her right, title and interest in the aforesaid real estate to Husband within fifteen (15) days of being presented with a Deed to be prepared by counsel for Husband. That Deed, which shall be appropriately signed, witnessed and notarized, shall then be held in escrow by counsel for Wife until such time as Husband has refinanced the aforementioned jointly held mortgage, Husband must lite for refinancing of the aforesaid mortgage within fifteen (15) days of execution of this Agreement by both parties, In the event that his refinancing is not approved, he must reapply for refinancing with an appropriate financial institution, at least, every six (6) months until refinancing occurs such that Wife is then removed as an obligor on the loan and mortgage due and owing on the aforesaid real estate, Pending the aforesaid refinancing, Husband shall be solely and exclusively responsible for repayment of any and all amounts due and owing to Dauphin Deposit Bank and Trust Company as well as any and all other debts due and owing due to ownership of the aforesaid real estate, including, but not limited to, real estate taxes and hazard insurance, Upon confirmation that Husband has refinanced the aforesaid mortgage, counsel for Wife is authorized and directed to provide counsel for Husband with the original, signed, witnessed and notarized Deed conveying Wife's interest in the property to Husband. The parties are also the joint owners of real estate located at 634 Walnut Bottom Road, Shippensburg, Cumberland County, Pennsylvania, which is currently held in the parties' joint names, This property is encumbered with a mortgage due and owing to Dauphin Deposit Bank and Trust Company, Husband shall execute a special warranty fee simple Deed conveying all of her right, title and interest in the aforesaid real estate to Wife within fifteen (15) days of being presented with a Deed to be prepared by counsel for Wife. That Deed, which shall be appropriately signed, witnessed and notarized, shall then be held in escrow by counsel for Husband until such time as Wife has refinanced the aforementioned jointly held mortgage, Wife must lite for refinancing of the aforesaid .~. mortgage within fifleen (15) days of execution of this Agreement by both parties, In the event that his refinancing is not approved. he must reapply for refinancing to an appropriate financial institution. at least. every six (6) months until refinancing occurs such that Husband is then removed as an obligor on the loan and mortgage due and owing on the aforesaid real estate. Pending the aforesaid refinancing, Wife shall be solely and exclusively responsible for repayment of any and all amounts due and owing to Dauphin Deposit Bank and Trust Company as well as any and all other debts due and owing due to ownership of the aforesaid real estate, including, but not limited to, real estate taxes and hazard insurance, Upon confirmation that Wife has refinanced the aforesaid mortgage, counsel for Husband is authorized and directed to provide counsel for Wife with the original, signed, witnessed and notarized Deed conveying Husband's interest in the property to Wife, 3.7 Pension. Retirement, Profit-SltarinI!. Wife agrees to waive, relinquish or transfer any and all of her right, title and interest she has or may have in her individual capacity or as Husband's Wife in the profit-sharing account established by Steel Building Erectors, Inc, through Marlin Gibb, Cadaret Grant and Company, Inc. Said account has been established through Husband's employment with Steel Building Erectors, Inc, Wife hereby waives, relinquishes and transfers any and all right. title and interest she has in this specific retirement account as well as any other accounts that Husband may have in his individual name or which he may have secured through his present or prior employment. Husband agrees to waive, relinquish or transfer any and all of his right, title and interest he has or may have in his individual capacity or as Wife's Husband in any and all pension, retirement, profit-sharing, stock option, or similar accounts which Wife may have established individually or through her present or past employers, 3.8 Vehicles. The parties acknowledge that they have several vehicles which are owned in their joint or individual names, including a Ford pick up truck, a pizza truck, motorcycle, a Dodge Caravan, and various other vehicles that are presently retained by Husband. The parties stipulate and agree that Wife presently has sole possession of the parties' Dodge Caravan and she shall retain sole and exclusive ownership and possession of the aforesaid vehicle, Husband will execute any and all documents necessary to waive, relinquish and transfer any and all of his right, title and interest in the aforesaid vehicle within fifteen (15) days of being requested to do so by Wife or Wife's representative, All of the vehicles that remain on which Wife is a joint owner with Husband, or which Husband owns in his name alone. are and shall be Husband's sole possession, Wife shall execute any and all necessary documents to waive, relinquish and transfer all of her right, title and interest in the aforesaid vehicles within fifteen (15) days of being requested to do so by Husband, In the event that there are any encumbrances, whatsoever, on any of the aforesaid vehicles, the encumbrances shall be the sole and exclusive responsibility of the party retaining sole ownership and possession of the respective vehicles. Esquire for Husband and Bradley L. Grime, Esquire for Wife. The parties acknowledge that they have either received independent legal advice from counsel of their own selection, that they Illl!y understand the 1;1cts and have been fully informed as to their legal " " rights an obligation or otherwise understand those legal rights and obligations. They acknowledge and accept that this Agreement is, in the circumstances, fair an equitable, that it is being entered into freely and voluntarily, after having received such advice an with such knowledge that execution of this Agreement is not he result of any duress or undue influence, and further that it is not the result of any collusion or improper or illegal agreement or agreements, 6.2 FetlerallllCIJlIIe Tax EXelll/lt;oIlS. It is agreed that from this point forward, as long as either of the parties' children, namely, David L. Young, II, or Joshua R, Young, are minors or otherwise available to be claimed as tax dependents for federal income tax purposes, Wife shall claim the child David L. Young, II as a federal income tax dependent ,. and Father shall claim Joshua R, Young as a federal income tax dependimC This shall be the case whether the present arrangements on custody are modified or remain the same. In the event either party must execute any documents including Internal Revenue Service forms to allow for the claiming of the child as a dependent, they will do so within fifteen (15) days of being requested to do so by the other party or the other parties' representative, 6.3 emll/.\'et rl!l!,~. Each party agrees to be responsible for his or her own legal fees and expenses, and each party hereby agrees to waive any claim for alimony, alimony pendente lite, counsel fees, expenses or costs. 6.4 Mull/III Relea.\'e. Husband and Wife each do hereby mutually remise, release, quitclaim, and forever discharge the other and the estate of such other, for all times to come and for all purposes whatsoever, of and from any and all right, title and interest, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against such other, the estate of such other, or any part thereof, whether arising out of any former acts, contracts, engagements, or liabilities of such other as by way of dower or curtesy, or claims in the nature of dower or curtesy or widow's or widower'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 (a) Pennsylvania, (b) any state, commonwealth or territory of the United States, or (c) any other country, or any rights which either party may have or at any time hereafter have for past, present, or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof, It is the intention of Husband and Wife to give to each other by execution of this Agreement a full. complete, and general release with respect to any and all property of any kind or nature, real or personal, not mixed, which the other now owns or may hereafter acquire, except and only except, all rights and agreements and obligations of whatsoevei nature arising or which may arise under this Agreement or for the breach of any thereof 6.5 IllmkrufJtcv. The parties agree that any an all financial obligations assumed herein shall not be subject to discharge through bankruptcy proceedings, This includes, but is not limited to, all financial obligations assumed under Paragraph 3.6, 3.8, 4.2 and 5.1 of this Agreement. In the event either party attempts to avoid financial obligations described herein through bankruptcy proceedings the other party shall have an independent claim against the party claiming bankruptcy for any and all sums that the other party assumes or is required to pay due to the actions of the party claiming bankruptcy. Further, all rights available to the other party provided for in Paragraph 6,14 hereinafter shall be available to the party not filing bankruptcy, 6.6 Warranties. Each party represents that they have not heretofore incurred or contracted for any debt or liability or obligation for which the estate of the other party may be responsible or liable, except as may be provided for in this Agreement. Each party agrees to indemnify or hold the other party harmless from and against any and all such debts, liabilities or obligations of every kind, including those for necessities, except for the obligations arising oul of this Agrccmcnt. Husband and Wifc cach warrant, covcnant, rcprcscnt and agrcc that cach will, now and at alltimcs hcreaftcr, savc harmlcss and kccp thc othcr indcmnificd from all dcbts, chargcs. and liabilities incurrcd by thc othcr aftcr thc execution date of this Agrccmcnt, cxccpt as is othcrwisc spccifically providcd for by the terms of this Agrccmcnt and that ncithcr of thcm hcrcafter incur any liability whatsoever for which the estatc of the othcr may bc liable, 6.7 No waiver or modification of any of the terms of this Agreemcnt shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature, 6.8 Husband and Wife covenant and agree that they will forthwith execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper implementation of this Agreement, and as their respective counsel shall mutually agree should be so executed in order to carry fully and effectively the terms of this Agreement. 6.9 This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date of the execution of this Agreement. " 6./() This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 6./1 This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them, There are no representations or warranties other than those expressly set forth herein, 6.12 Sel'erl/hilitv. If any term, condition, clause, section, or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement, and in all other respects, this Agreement shall be valid and continue in full force, effect, and operation. Likewise, the failure of any party to meet his or her obligation under anyone or more of the articles and sections herein shall in no way void or alter the remaining obligations of the parties. 6.13 It is specifically understood and agreed that this Agreement constitutes and equitable distribution of property, both real and personal, which was legally and beneficially acquired by Husband and wife, or either of them, during the marriage as contemplated by the Divorce Code of the Commonwealth of Pennsylvania. '. 6. J.I I)j,~clo,mre. The parties each warrant and represent to the other that he or she has made a full and complete disclosure to the other of all assets of any nature whatsoever in which party has an interest, of the sources, and amount of the income of such party of every type whatsoever, and all other facts relating to the subject matter of this Agreement. 6.15 Enforceahilitv ami Consideration. This Agreement shall survive any action for divorce and decree of divorce and shall forever be binding and conclusive on the parties; and any independent action may be brought, either at law or in equity, to enforce the terms of the Agreement by either Husband or Wife until it shall have been fully satisfied and performed. The consideration for this contract and agreement is the mutual benefits to be obtained by both of the parties hereto and the covenants and agreements of each of the parties to the other. The adequacy of the consideration for all agreements herein contained in stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound hereby, In the event either party breaches the aforesaid Agreement and it is determined through appropriate legal action that the alleged party has so beached the Agreement, the breaching party shall be responsible for any and all attorney's fees as well as costs and expenses associated with litigation incurred by the non-breaching party to enforce this Agreement against the breaching party. In the event of breach, the non- breaching party shall have the right, at his or her election, to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her including equitable enforcement of this Agreement. IN WITNESS WHEREOF, thc partics hcrcto havc sct thcir hands and scals thc day and ycar first abovc writtcn, WITNESSED BY: {;vf!Jl{ /JdlfA1/'CA/L '>,'j -"-> X'~S:s---- ./ zitd.L XJ - <~v ALESHA D. YOU (I DA VID L. YOUNG, Plaintiff IN TI-IE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. NO. 98- 4408 CIVIL TERM ALESI-IA D. YOUNG, Defendant 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 breakdown under Section 3301 (c) of the Divorce Code. 2, Date and manner of service of the Complaint: Filed July 21, 1998 and reinstated March 19, 1999. Served by U.S. Mail to Defendant's attorney. Acceptance of Service dated March 23, 1999, 3, Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code: By Plaintiff: August 12, 1999; by Defendant: August 12, 1999. 4, Related claims pending: None. 5, Date Plaintiff's Waiver of Notice in !l3301(c) Divorce was filed with the Prothonotary: f'./2.. qq Date Defendant's Waiver of Notice in !l3301(c) Divorce was filed with the Prothonotary: ~. n_ . 9"1 indsay Dare ird, Esquire Allorney for the Plaintiff .,~,.-,j:,;;:' j. . ~,l" i"':'~:~~:"''';-'''''.'':'''~::'':':'~' _ '; _''' . - ,_ ,._', ",_ '.; - ., -l:'::,',:.-;:;:'.; ~,:::". ~:.~:-.'-\.::';.~:::'.~;~'_ :~,_~"~,_~_'~:':.:l.~~:~',.~'''''~, :'-~ ,,~,'- :,~, ~.: ~"".:'~~;~~;~~~'\~~.~'~'t ..:- .t,- .:;,~ ..:..:.. - . ..' ~.. ~ ': . {~~:\{~~~f.~;1~f.~:~~~~~~'(Jt:qf:7(.:~~'~}~;~f~::,;[.;;;'~;t<~-~;:~?:i~;~'-~I:);!\5~:) ~~t~~~fJfD(t:IV:'~}:. ~t;;i.:,Lj.':\~'~?,r~{;r}}i.~:;:~{.~::?J,:,:,':F;ti~._~-i;~.,3~?}':~,~t~;;.:~j~~#~iYi::~~~B~w:f~. ~If~~;o/.'l~ ~~:.!I;,i~~....E..~u.~;;.,&.;.,....\.t:~tL'i,J:!....t.-;r.{...:;.;tr~-!L.i.\:.~'::.>;~.~ ~;. ~:;,.: .~, :t::s.:~,::..!j,~,;~'.LJtJDSAY ~D~E 'BAIRD. l' ;~".i.' ,;6i~t; rp j.:';" ~i"':r\':~~ ,;", i;";~"'."iJ(' ..~.. ~;';t'~~":(;~'~.' ~~:~.,j..l1'4ttit~'~~t:'1~;1~';~rt'~'1 ~:}:""~~~~"11P~'::;;':-.l;-;.~"~;~-r;: ~F..:!.r:;~:~~~~:,:~,.l..tt::,,';t:,~.:.~,~ :;..~:::t~;; t:t"",:(::,:';~ri."."":~'" ,~1 ,~" "; ,,"~.", -" J' '" -'. 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",' :..:,/ ;:;;i ~ ,~' ';'~;,~,""i;:/;~':;;.o;'r."';;';"f;' '.'~~, 1':~j~' ~..~ 1:';.:;::'\WiJi.:~,rl~~~'.'"4 ~@;.:~!'i~~.-,:J~?~(:~;,~:~~Y+.~j~J'~1:.k~(i..t~' ~~'?i.if}~\{$.r>::(i.\':.'.'; :~,j,.,,~._:,:.:'::"':' :'I:,'~.:CAtiLi8L~;'~E~N8Y~V~~n~~i 7.' Q,~ 3';8. ,,~~tr;:r';.';~!'~:~.~/;::~I~~'r.{1.~~~!.::,;:/~\;? '_~:,~~~~~.~~~;}f.,~}}:.'~:~?' ;i~':(fb~,;t:~:,,'i,ft,;:~'.~~5~:t{~ "" "'I.'.'d'I".r,eJ',<;""',,,,-,A,;.""""'.""""\'" ''',,'1'','. '(717)'24.357.32"''''(71'')''243.8110./'''' '"" I.'.' ""'''''''''''>')'' "N~,,, -'1",(. ,..,,' "!",, ".r-,,,,,,, \l.\.>; vi;:'-' '~~',.)'" ;4~lu:r.l'fM"r:''J'~(7~:,' ~'t -:l.:'-' '," "';~ ',~ .;:; '":<. -) ~ ',- '>,'", "<it: i ;'.,1:., . ':' -;FM, , . ",~. "J,~..<.I,.:',' .~:,~.,.,";'~ J;:' ,':;; \~~, ,1.\. ';'.l~,...l;"J'.l".. ;\'''f,;~:,'''\;fY'l'~ l;.ft}('ll:t1-.~ ;~.(.,t..f,.I;..}','I;"!o~,'tr~./~'i.tr'-' ':(; ~~"),i; ~",,:"::.:'~ ,~: ~.~.~ ,":'f:,\:~":,'..";'> .", -: ,'."" ~':.': ;:':',.:;. '~"',:',' ",_,' :,~-:'A:":" -':':"i,:!:"'~,',.;-,'<!\;:.~p~~::",;::~fi,:"!~'./~ ",,,:,:,..,.,-:-?~..;..:;;...-..:.; \: :~' . ~','-~'~ >,),:;':'~;'~":"<'(j';:r"1'~'~ -, ::~~:~ '_;.?M:'Nil~ DA VID L. YOUNG, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v, NO. 98. /.jJ.;cP CIVIL TERM ALESHA D. YOUNG, Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court, A judgment may also be entered against you for any other claim or reiief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Cariisle, Pennsylvania, 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 ASSOCiATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 &o)~ ~~~5 1~ J~~ --: : 0:: i~ c. -....l- ! .~~ . tfS i I h" .~.1 ' 6".J~.-;. ." " ~ l.~;- . c-r- '.c. ,. , ~ 'l_. (.i;' ; , 1.., .~.. tJ~ i",'" r.._~ !: ,-- 1'_ Cl ,..) F;: ~~~ .~:.~~ '-./'" "1:% '~ ltU _.qC'- ::j U c... C": ;::~ (t, (.n ~~ ~ --.J ~ r.t!. 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