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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
I'::f'
STATE OF 1~~~ PENNA.
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DECREE IN
DIVORCE
AND NOW IY),) ,1 7) 19 'I 'J" 't' d d d
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decreed that,. +,/,Q(I. i'\\:\:,. .~,l',n,..).[l.\.\,~. .,..,',."...,','".,.. plaintiff,
and,., . ,.,.. C.i,o.J.~ \!C R..S, .~t'>':")) h.~\'.:,.,..,..,.,.,.., defendant,
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ore divorced Irom the bondsol matrimony,
The court retains jurisdiction of the following claims which hove
been raised of record in this action for which 0 linal order has not yet
been entered;
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NOW TIIEREFORE, with the foregoing recitals beinghercinafter incorporated by
rcfcrcncc and deemed as an essential part hereof and in considcration of the prcmiscs and of thc
mutual promiscs, covenants and undertakings hereinafter set forth and for other good and valuable
consideration, receipt of which is hereby acknowledged by each ofthc parties hereto, Husband and
Wife. each intending to bc lcgally bound hcreby, covenant and agree as follows:
1. AGUEEMENT NOT A BAR TO DIVORCE Plill..CEEDING,
This Agreement shall not be considered to affect or bar the right of Husband
or Wife to a limited or absolute divon:e on lawful grounds if such grounds now exist or shall
hereafter exist or to such defense as may bc available to eithcrparly. This Agrecment is not intended
to condone and shall not be dcemed to be a condonation on thc pari of either pany hereto of any act
or acts on the part of the other party which ha\,c occasioned the disputcs or unhappy differences
which havc occurrcd prior to or which may occur subsequent to the date hereor The patties intend
to secure a mutual consent, No-Fault Divorce pursualllto the tCnl1S of Section 3301(c) of thc
Domcstic Relations Code of 1990 and to that cnd each is executing an Affidavit of Consent at the
time ofthc exccution of this Marital Settlemcnt Agrecmcnt.
~ EFFECT OF DIVOIKE..ll.Ef.Jlli.E.
The parties agrec that unless otherwisc spccifically providt~. herein, this
Agrecmel1l shall continuc in full forcc and effect after such timc as a Final Decrce in Divorce may
be entered ,,;'ith respect to the parties,
3, AGREEMENT TO DE INCORPORA TELUriDlVORCE DECREE.
111e parlies agr,'e that thc Icm1S oflhis Agreement shall bc incorporatcd but not
merged into :Iny DivO[c,' Decree \\hich may be t"ntered \\ith respect 10 them. Thc parties understand
such othcr. of whatcvcr naturc and whcrcsocvcr situatc. which hc or shc now has or at any timc
hcrcaftcr may havc against sllch othcr, thc cst.mc of such othcr or any party thcrcof. whcthcr arising
out of any formcr acts, cont.ract.s. cngagcmcnts or liabilitics of such fJthcr or by way of dowcr or
curtcsy, or claims in thc naturc of dowcr or curtcsy or widow's or widowcr's rights, family cxcmption
or similar allowancc, or undcr thc iJ1lcstatc laws, or thc right to t.akc against the spouse's will: or thc
right to treat a lifctimc convcyancc by thc othcr as tcstamcntary, or all other rights of a surviving
spouse to participatc in a dcccascd spousc's cstatc, whcther arising under thc laws of (a)
Pelmsylvania, (b) any State, Commonwcalth or Tcrrit.ory of the Unitcd Statcs, or (cl any other
Country, or any rights which cithcr party may havc or at any timc hcrcaftcr havc for past, prcscnt or
future support or maintcnancc, alimony, alimony pcndcnte lite, counscl fccs. cquitable distribut.ion,
costs or cxpcnscs, whcthcr arising as a rcsult of the marital rclation or otherwise, exccpt., and only
cxcept, all right.s and agrccmcnts and obligations ofwhatsocvcr naturc arising or which may arise
undcr this 'Agrccmcnt or for thc breach of any provision thcrcof, It is the intention of Husband and
Wife to give to cach othcr by the cxccution of this Agrccmcnt a full, complet.c and gcncral rclease
with rcspect to any and all propcrt)' of any kind or naturc, rcal, pcrsonal or mixed, which thc othcr
now O\\TIS or may hcrcafter acquir(', cxcept and only exccpt all rights and agreements and obligations
of whatsocvcr nature arising or which may arisc undcr this Agreement or for the breach of any
provision thcrcof',
II, PERSONAL PROP~~RTY,
111C parties make the following disposition and settlement "il11 respect to their
personal property:
al Husband agrecs that \\lifc may keep all oflhc fumitW'c, fUll1ishings,
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above, a profit-sharing plan and IRA of which she waives all rights and interest to, Husband
acknowledges that wife has an IRA of which he waives all rights and interest to.
12, AFTER-A..QllIJRED PERSONAL I'IWI'Elny.
Each of the parties shaH hereaftcr 0\\11 and enjoy, indcpendently of any claim
or right of the other, all items of personal property, tangible or imiUlgiblc. hereafter acquired by him
or her, with full power in him or her to dispose of the same as fully and effectively. in all respects
and for all purposes, as though he or she were not married.
13. REAL ESTATE.
Husband and Wife agree to split by SO/50 percent. all equity in the home located at
76 Greenmont Drive, Enola, Cumberland County, Pennsylvania, Husband agrees to continue
making the primary monthly mortgage payments until. June 30, of the year the youngest daughter,
Jenny. born March 8,1990, tums 18 years of age (10 years). At the end of the period. wife shall
either sell the property 91: refinance the property and distribute fifty' (50%) per~ent of the equity to
husband, Ifit is necessary to sell/transfer the property prior to ten years. illUlropriate monthly ehild
support will he paid by husband to wife,
Husband agrees to be solely responsible lor the following liabilities associakd with
said property: taxes. insurance, Ulld mortgage payments. Wife agrees to be solely r,'sponsible for
utility costs. Debt obligations are outlined in a previous section and arc incorporated herein.
Husband and wife agree to the following tax distribution. saiJ distribution may be
subject to changedepending upon future tax considerationsof the parties. modifieJ in "Titing,
through mutual consent: Husband shall take the primary l1lortgagl' inlele~t d,'duction and the
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the parties agree that the said accounts shall be closed and all cards either surrendered to the creditor,
orin the alternative. transferred into the sole name of the party who primarily used said credit card,
within 60 days o(ruto:.1!Ltbe final divorce decree. Neither party shall make any further charges'
on said accounts for which the other may be lia~le and shall indl'mnify, protect and save the other
party hannless therefrom.
17, Q,1STODV. CHILD SUPPORT OnLlGAI.l~
A) CUSTODY
Husband agrees that the minor children of this marriage will remain with the
wife and that she will have sole custody of minor children. Wife agrees that husband will have
visitation as frequently as possible. givcn schedules of both husband and wife, as well as the
schedules of said minor children for their activities. Husband agrees that wife shall have legal
cllftody and may make health and welfare decisions as necessar\'" \JJ', C'" oS >-.C;C/.l 4-hc:JJ
H 0':;,\::/:'''1'0. n--C'~ l'0<c,JcQ \\~c-~ltJ", ~T\cl wc\->,o,,...(, <411..CIS\6Yr, <:.0- ()(>~{>~O-~
B) CHILD SUPPORT (;JJJ- \.
Husband agrees to provide health insurance for minor children, Husband
agrees to pay fifty (50%) percent of all un-reimbursed medic.11 and dental expenses, Husband agrees
to pay fifty (50%) percent of all school, sport, social or any other activity costs and fees for activities
in which the minorchildll'l) desire (0 take part. in the course of their minor years, Husband agrees
to assist wile with clothing expenses as well as any other expenses, ordinary or extraordinary. as may
be needed. from time to time, for the minor children, Wife understands that she will be the primary
caretaker and that childcarc is not necessary. with the exception of summer programs, Husband
agrees to pay fifty (50%) pcn:ent of any summer program in which the minor children are enrolled,
Husband undersl~lIlds thai if any time he shall fail 10 make the primary' mortgage
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