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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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PENNA.
STATE OF
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FRANCES L. TESLAR,
PLllINTIFF
No.
2000-5102 CIVIL TERM
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VERSUS
NICKOLl\S G. STA"IOS,
DEFENDANT
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DECREE IN
DIVORCE
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2000 IT IS ORDERED AND
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AND NOW,
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FRANCES L. TESLAR
, PLAINTIFF,
DECREED THAT
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NICKOLI\S G. STAMOS
, DEFENDANT,
AND
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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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;
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NONE
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PROTHONOTARY ~
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FRANCES L. TESLAR,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
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NO. 2000-5102 CIVIL TERM
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CIVIL ACTION - LAW
NICKOLAS G. STAMOS,
Defendant
IN DIVORCE
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MOTION FOR ENTRY OF A DOMESTIC RELATIONS
ORDER AND A QUALIFIED DOMESTIC RELATIONS ORDER
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AND NOW comes the undersigned, as attorney for Plaintiff, Frances L. Teslar, and
moves the Court to enter the following orders based upon the agreement of the parties:
1. A Domestic Relations Order, as required by Defendant's employer to continue
the health insurance coverage for the benefit of the Plaintiff in accordance with Paragraph
11 of the Property Settlement Agreement between the parties dated 6 November 2000, a
copy of which is attached hereto.
2. A Qualified Domestic Relations Order to make a distribution from Husband's
retirement account with the Teachers Insurance and Annuity Association - College
Retirement Equities Fund, as required by Paragraph 6 of the parties' Property Settlement
Agreement of 6 November 2000.
WHEREFORE, the undersigned moves this Court to enter the attached orders to
implement the terms of the parties' Property Settlement Agreement.
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Samuel L. A s
Attorney for Plaintiff
Supreme Court 10 17225
525 North 12th Street
Lemoyne, PA 17043
(717) 761-5361
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FRANCES L. TESLAR,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2000-5102 CIVIL TERM
NICKOLAS G. STAMOS,
Defendant
IN DIVORCE
Jt1ltfOMES~
AND NOW, this .f-=.t-- day of ~ ,2000, to implement a
provision of the parties' Property Settlement Agreement, this court makes the following
findings:
A. The Defendant, Nickolas G. Stamos is employed by Dickinson College in
Carlisle, Pennsylvania
B. As an incident and benefit of his employment, the Defendant is provided with
medical health insurance and, at the present time and during the marriage, the Plaintiff,
Frances L. Teslar was covered by such insurance.
C. The parties have agreed that Defendant shall continue the health insurance
coverage for Plaintiff that has been provided by his employer up to the date of divorce,
through June 30, 2001.
NOW, THEREFORE, based upon the above findings and the agreement of the
parties, we hereby order and direct as follows:
1. Defendant, Nickolas G. Stamos shall continue and maintain, for the benefit of
the Plaintiff, Frances L. Teslar, health insurance, as has been available up to the date of
divorce through his employer, through June 30, 2001.
2. The parties shall cooperate with each other and with Defendant's employer to
maintain such insurance coverage through that date and shall make, execute,
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acknowledge and deliver any and all documents necessary to assure the continuation of
such coverage pursuant to this order.
3. After June 30, 2001, Defendant shall have no further obligation to provide
health insurance for the benefit of Plaintiff.
BY THE COURT,
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THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
FRANCES L. TESLAR,
Plaintiff
vs.
NO. 2000-5102 CIVIL TERM
NICKOLAS G. STAMOS,
Defendant
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AND NOW, this _I ~
agreement of the parties, we hereby find as follows:
1. The parties hereto are husband and '1l~e and seek t
a final decree in divorce entered on the ~ day of
above-captioned action.
2. The Defendant, Nickolas G. Stamos (Social Security No. 206-38-9927),
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is order in conjunction with
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hereinafter referred to as "Participant" is presently employed by Dickinson College and is
a participant in the Teachers Insurance and Annuity Association - College Retirement
Equities Fund, hereinafter referred to as "TIAA CREF" having the following Retirement
Annuities:
A. TIAA RA Contract # B-257637-5
B. CREF RA Certificate # Q-257637-2
C. TIAA SRA Contract # K-638179-8
D. CREF SRA Contract # J-638179-0
3. Participant's current and last known mailing address is:
Nickolas G. Stamos
1 54 Lancaster Boulevard
Mechanicsburg, PA 17055
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4. The Plaintiff, Frances l. Teslar (Social Security No. 208-42-5376) is the
Alternate Payee hereunder and her current and last known mailing address is;
Frances l. T eslar
154 Lancaster Boulevard
Mechanicsburg, PA 17055
NOW, THEREFORE, to accommodate the marital property distribution between the
parties, IT IS HEREBY ORDERED AND DECREED AS FOLLOWS:
A. The TIAA CREF annuities referred to in Paragraph 2 above are marital property.
B. Subject to the finalization of the divorce and the execution of the documents
required by TIAA CREF and the terms of the said annuities, the following portions of
those annuities shall be awarded to the Alternate Payee, as sole and exclusive property,
to be applied to TIAA CREF annuities subject to the terms and limitations of said
annuities:
(1) A portion having a value, as of 19 June 2000, of $139,474.83,
increased or decreased by the investment results on such funds after 1 9
June 2000 and through the date of transfer or distribution.
(2) The values actually transferred will reflect interim interest and
dividend earnings in TIAA and investment experience in CREF until the
transfer is recorded by TIAA CREF.
All ownership rights in the newly issued annuities will belong to Alternate Payee, Frances
l. Teslar. All ownership and interest in the balance of the accumulations in all contracts
issued by TIAA CREF will belong to Participant, Nickolas G. Stamos.
C. The parties are directed to timely submit to TIAA CREF all documents, including
Releases that are required by TIAA CREF to finalize and implement this order.
D. This Order:
(1) Does not require any Plan to provide any type or form of benefit, or
any option, not otherwise provided under the Plan; and
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(2) Does not require TIAA CREF to provide increased benefits; and
(3) Does not require the payment of benefits to an alternate payee
which are required to be paid to another alternate payee under another Order
previously determined to be a Qualified Domestic Relations Order.
E. This court reserves jurisdiction to issue further orders as needed to execute,
implement, and enforce this order.
BY THE COURT,
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PROPERTY SETTLEMENT AGREEMENT
THIS AGREEMENT, made this 6;-::tt day of I\(Ove.....,.bGl./', 2000, is by and
between:
NICKOLAS G. STAMOS, of 154 Lancaster Boulevard, Mechanicsburg, Pennsylvania,
party of the first part, hereinafter referred to as "Husband"; and
FRANCES L. TESLAR, of 154 Lancaster Boulevard, Mechanicsburg, Pennsylvania,
party of the second part, hereinafter referred to as "Wife."
WITNESSETH:
WHEREAS, the parties hereto are husband and wife, having been married on 1 5 July
1984 in Camp Hill, Pennsylvania, and have no children born of this marriage; and
WHEREAS, certain difficulties have arisen between the parties hereto which have
made them desirous of living separate and apart from one another and Wife has initiated or
plans to shortly initiate an action in divorce against Husband; and
WHEREAS, the parties hereto have mutually entered into an agreement for the
division of their assets, the provision for the liabilities they owe, and provision for the
resolution of their mutual differences, after both parties have had full and ample
opportunity to consult with their respective attorneys, and the parties now wish to have
that agreement reduced to writing.
NOW, THEREFORE, the parties hereto, in consideration of the above recitals, the
mutually made and to be kept promises set forth hereinafter, and for other good and
valuable considerations, and intending to be legally bound and to legally bind their heirs,
successors, assigns, and personal representatives, do hereby covenant, promise, and agree
as follows:
1. REAL ESTATE. The parties hereto mutually covenant and agree that the real
estate they own jointly, as tenants by the entireties, and being known and numbered as
154 Lancaster Boulevard in Mechanicsburg, Lower Allen Township, Cumberland County,
Pennsylvania, shall be sold for the highest obtainable fair market price therefor. To
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accomplish such sale, the parties will list the property with a realtor which they select by
mutual agreement and they further agree that they will, each of them, cooperate with said
realtor and any other person showing or viewing said property, to effectuate the prompt
sale of the property for the highest reasonably obtainable sale price. The parties agree that
the proceeds of the sale of said real estate, after the payment of the expenses of said sale,
to include a reasonable realtor's commission, shall be applied to pay the mortgage on the
property and to pay any and all other liens or encumbrances of record, and pay all current
real estate taxes owed on the property, so as to give and deliver a good and marketable
title at the time of settlement. The net proceeds of sale of such settlement after the
payment of the expenses of the sale and of all liens and encumbrances on said property,
shall be divided equally between the parties. With regard to the property, the parties
further agree as follows:
A. The parties will cooperate and take whatever action is reasonably
necessary to remove the lien or any other cloud on the title of the property
resulting from a mortgage given to H.F.C. Finance in the past and paid off but
not yet satisfied. The parties agree that they owe H.F.C. no further payments
and that they will cooperate to resolve the matter of that mortgage.
B. Until such time as settlement is held on the sale of the residence,
Husband shall continue to reside in and occupy the residence and shall be
responsible to pay any and all expenses arising out of the ownership or
occupancy of the house, including, but not limited to, the installments of
interest and principal on the first mortgage, owed to Members First Federal
Credit Union, and the homeowners insurance, sewer, water, and other utility
rents, charges, or assessments, and any and all other expenses arising out of
the property. Further, Husband shall indemnify and save Wife harmless from
any loss, cost, or expense caused to her by his failure to make such
payments.
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C. Husband shall be responsible to pay any unpaid real estate taxes for
the residence for the municipal tax year 1999 and for the school tax year
1999-2000. Municipal taxes due for the tax year 2000 and school taxes for
the tax year 2000-2001 shall be divided equally by the parties by paying them
from the proceeds of settlement.
The parties shall cooperate with each other, their attorneys, and the real estate agent to
complete the sale of the property, and the distribution of the proceeds, as promptly as
possible after the date of this agreement. Further, in the event that the property is not
under an agreement of sale within ninety (90) days of the date of this agreement, the Court
of Common Pleas of Cumberland County shall, upon the petition of either party, appoint a
master or other court representative to oversee, manage, and control the prompt sale of the
property and the division of the proceeds in accordance with this agreement and such court
representative shall have full authority to conduct the sale of the property.
2. WIFE'S REAL ESTATE. The parties acknowledge that Wife, together with her
mother, Gladys E. Teslar, and her brother, Stephen D. Teslar, are the owners of land in
Fairview Township, York County, Pennsylvania, and that Wife's interest in said property
was a gift from her family. Husband does hereby waive, release, relinquish, and terminate
absolutely any and all interest in or claim to said property, its value, or any increase in its
value during the time that Wife has held it and agrees that he shall make, execute,
acknowledge and deliver any quitclaim deed or other document necessary to confirm that
he has no interest in or claim against such property.
3. TIMESHARE UNIT. The parties acknowledge that they own, in joint names, two
weekly units in the Williamsburg Plantation Timeshare Project in Williamsburg, Virginia.
With regard to such timeshare units, the parties specifically agree as follows:
A. The parties will sell both units as promptly as possible after the date
of this agreement and will divide equally between them the net proceeds of
sale of each unit, after paying the expenses of such sale and any liens or
obligations that they jointly owe for such units. To effectuate such sale, the
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parties shall take any and all action that they mutually deem appropriate,
including listing the property for sale with a realtor or otherwise engaging a
representative to assist them in the sale of the property.
B. Until such time as both units are sold, the parties will share equally
the use and occupancy of the timeshare units with each of them having one
week per year as long as they own both units and, if one unit is sold and they
continue to own the other, with Husband and Wife alternating the annual use
so that Wife has the use in odd-numbered years and Husband has the use in
even-numbered years.
C. Husband and Wife shall share all expenses and costs of the units,
including their maintenance and any service or other fees, equally and both
parties will contribute and pay their share of such expenses within thirty (30)
days of the date they receive an invoice or statement for such services.
The parties shall make, execute, acknowledge and deliver any and all documents necessary
to complete their obligations under this paragraph and shall cooperate with each other and
their respective attorneys, real estate agents, or other representatives assisting them in the
sale of the timeshare units.
4. WIFE'S RETIREMENT ACCOUNTS. The parties acknowledge that Wife owns
benefits in the Sprint retirement savings plan, which had a vested value as of 31 March
2000 of approximately $27,000.00, in the Intellex Corporation 401 (kl plan, which had a
value as of 30 September 1999 of approximately $1,200.00, and in the Stroehmann
Bakeries, L.C. savings plan which had a value as of 31 March 2000 of approximately
$10,000.00, and that her interest in these plans were all earned during the marriage and
are, therefore, marital assets subject to equitable distribution. Being aware of all of that,
Husband does hereby waive, release, relinquish, and terminate absolutely any and all
interest in or claim against Wife's interest in such retirement accounts and confirm the
same to be the sole and separate property of Wife from and after the date of this
agreement, free of any further claim by Husband. Husband agrees that he shall make,
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execute, acknowledge and deliver any and all documents necessary to confirm and verify
such assets to be the sole and separate property of Wife promptly upon her request.
5. WIFE'S OTHER ASSETS. The parties acknowledge that Wife holds
approximately $27,000,00 which she holds for the benefit of her mother and, although it is
held in an account titled in Wife's name, such money belongs to her mother, Gladys E.
Teslar, for whom Wife holds the money. In addition, the parties acknowledge that Wife
owns approximately 100 shares of stock in Sprint Corporation, which has a market value at
this time of approximately $35.00 per share and approximately 10 shares of stock in
Verizon, also known as 360 Corporation, which has a value at this time of approximately
$41.50 per share. Husband, being aware of such assets, hereby waives, releases,
relinquishes and terminates absolutely any and all interest in or claim against Wife's interest
in such assets and confirms the same to be the sole and separate property of Wife from
and after the date of this agreement, free of any further claim by Husband. Husband
agrees that he shall make, execute, acknowledge and deliver any and all documents
necessary to confirm and verify such assets to be the sole and separate property of Wife
promptly upon her request.
6. HUSBAND'S RETIREMENT ASSETS. The parties acknowledge that Husband
holds an account in the Teachers Insurance and Annuity Association - College Retirement
Equities Fund (hereinafter "TIAA-CREF') which had a balance, as of June of 2000, of
approximately $345,000.00 and which had a value, as of 31 July 1984, of $6,305.68.
The parties acknowledge and agree that the difference between those two balances is
marital property subject to equitable distribution by them or by the court. With regard to
such retirement account, the parties hereby agree as follows:
A. Husband shall transfer to Wife, by a tax-free rollover obtained
pursuant to a Qualified Domestic Relations Order, assets having a value, as of
19 June 2000, of $139,474.83, plus or minus the investment results on such
assets after 19 June 2000.
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B. The parties shall cooperate to obtain and implement and enforce a
Qualified Domestic Relations Order to make such transfer as promptly as they
can after the date of this agreement and will share equally the expense of
such an order.
C. After the transfer made pursuant to the Qualified Domestic Relations
Order described above, the remaining assets in Husband's account with TIAA-
CREF shall be and remain Husband's sole and separate property, free of any
claim by Wife, and Wife agrees that she shall make, execute, acknowledge
and deliver any and all documents necessary to confirm and verify those
assets t(lbe the sole and separate property of Husband promptly upon his
request for such documents.
7. AUTOMOBilES.
A. The parties agree that Wife shall become the owner of the 1999
Nissan Pathfinder vehicle currently titled in joint names. Husband shall make,
execute, acknowledge and deliver any and all documents necessary to transfer
the title to Wife. Husband does hereby waive, release, and relinquish any and
all claim to or interest in said motor vehicle.
B. The parties agree that Husband shall become the owner of the 2000
Mazda 626 vehicle currently titled in joint names and the 1994 Nissan 300ZX
vehicle currently titled in joint names. Wife shall make, execute, acknowledge
and deliver any and all documents necessary to transfer the titles to Husband.
Wife does hereby waive, release, and relinquish any and all claim to or interest
in said motor vehicles.
C. The parties acknowledge that the 1999 Nissan Pathfinder, the 2000
Mazda 626 and the 1994 Nissan 300SX are subject to debts owed to
Members First Federal Credit Union which encumber the titles to those
vehicles. Husband hereby agrees to pay and satisfy, in strict accordance with
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their terms, the said obligations and to indemnify and save Wife harmless from
any cost, loss or expense caused to her by his failure to do so.
8. DEBTS. The parties acknowledge that they have various debts that were
created by them during the marriage and they agree to pay and satisfy those debts as
follows:
A. The joint account owed to Beneficial Finance Company, which
carries a balance of approximately $4,000.00 at this time, and the personal
loan owed to Members First Federal Credit Union by both parties, which
carries a balance of approximately $3,000.00 at this time, shall be paid from
the joint proceeds of the sale of the house prior to the time those proceeds are
divided between the parties. Until such time as they are paid in that fashion,
the parties will each pay one-half of the monthly installments due on those
loans in a timely and prompt fashion.
B. Wife owes an educational loan to PSEAA which has a balance of
approximately $7,000.00, and on which Wife, alone, is liable. Wife shall pay
and satisfy such loan, in strict accordance with its terms, and shall indemnify
and save harmless Husband from any loss, cost, or expense caused by her
failure to do so.
C. The parties acknowledge that each of them has credit card
obligations in their separate names, for which the other party is not liable.
Each of the parties shall pay and satisfy, in strict accordance with their terms,
the credit card debts owed by each of them as of the date of this agreement
and shall indemnify and save harmless the other party from any loss, cost, or
expense caused to the other party by their failure to pay and satisfy such
debts in accordance with their terms.
D. The parties acknowledge that they currently owe real estate taxes
for the current tax year for the residence at 1 54 Lancaster Boulevard in
Mechanicsburg. They will pay the balance owed on those taxes, and any real
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estate taxes owed for subsequent tax years, from the proceeds of settlement
on the sale of the said residence, before those proceeds are divided, at the
settlement on such sale.
9. PERSONAL PROPERTY. The parties acknowledge that there are numerous
items of tangible personal property at the Mechanicsburg residence which are owned by
Wife's mother and brother. Wife shall arrange to remove those items from the property
within twenty (20) days of the date of this agreement. Otherwise, the parties hereto
mutually agree that they have effected a satisfactory division of the furniture, household
furnishings, appliances, and other household and personal property between them and they
mutually agree that each party shall, from and after the date hereof, be the sole and
separate owner of all such tangible personal property presently in his or her possession,
whether said property was heretofore owned jointly or individually by the parties hereto,
and this agreement shall have the effect of an assignment or receipt from each party to the
other for such property as may be in the individual possessions of each of the parties
hereto, the effective date of said bill of sale to be contemporaneous with the final decree in
divorce entered in the action contemplated to be filed herein.
10. ALIMONY. Husband shall pay alimony to Wife as follows:
A. From the month following the execution of this agreement and
continuing through the month in which settlement is held on the sale of the
Mechanicsburg residence, Husband shall pay Wife alimony in the amount of
Five Hundred ($500.00) Dollars. Neither the term nor the amount of alimony
under this sub-paragraph shall be subject to modification.
B. Commencing with the first month following settlement on the sale
of the Mechanicsburg residence, and continuing for sixty (60) consecutive
months thereafter, Husband shall pay Wife alimony in the amount of One
Thousand ($1,000.00) Dollars. The amount of alimony to be paid shall not be
subject to modification at any time for any reason. The term of the alimony
due under this paragraph, however, shall terminate upon Wife's death or
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remarriage, if either of those events occur before the 60 months. Otherwise,
the term of alimony shall not be subject to modification or termination.
C. The payments shall be made by Husband directly to Wife and shall
be due on the first day of each month commencing with the first month
following the date of this agreement, and continuing on the first day of each
consecutive month thereafter, in accordance with sub-paragraphs A and B
hereof. Payments may be made through, and enforced by, the Domestic
Relations Office at Cumberland County, at Wife's election and, if Wife so
elects, the parties will cooperate to have an alimony order entered and
administered by the Domestic Relations Office.
D. Both parties agree that such payments shall be deemed to be
alimony and treated by both of them as such. Husband shall be entitled to
deduct the payments from his income for federal income tax purposes and
Wife shall include such payments on her income for federal income tax
purposes.
The parties agree that they will make, execute, acknowledge and deliver any and all
documents necessary to implement the terms of this agreement and further agree that, at
Wife's election, the terms of this paragraph may be made the subject of an order of court
and the payments may, again at Wife's election, be made through the Domestic Relations
Office of Cumberland County, pursuant to such order.
11 . HEALTH INSURANCE FOR WIFE. Husband agrees that he shall maintain Wife
on the health insurance coverage currently provided to her through his employment as long
as she is eligible for such coverage because she is still his wife. Husband further agrees
that he shall obtain a Domestic Relations Order to maintain the coverage on Wife as is
available through his employer through 30 June 2001, regardless of whether the parties
are divorced or not and that Husband shall pay any and all fees or costs necessary to
continue the health insurance on Wife through that date, provided, however, that in the
event Wife obtains comparable insurance as a result of her employment prior to that date,
9
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Husband's obligation to provide that insurance at his expense shall terminate when such
other insurance is available to Wife.
12. WAIVER OF FURTHER ALIMONY. SUPPORT AND ALIMONY PENDENTE LITE.
The parties acknowledge that they are aware of the income, education, income potential,
and assets and holdings of the other or have had full and ample opportunity to become
familiar with such items. Both parties acknowledge that they are able to support and
maintain themselves comfortably, without contribution from the other beyond that as
provided for in this Property Settlement Agreement, upon the income and assets owned by
each of them. The parties hereby accept the mutual covenants and terms of this
Agreement and the benefits and properties passed to them hereunder in lieu of any and all
further rights to support or alimony for themself, counsel fees, and alimony pendente lite at
this time and during any and all further or future actions of divorce brought by either of the
parties hereto and the parties do hereby remise, release, quit claim, and relinquish forever
any and all right to support, alimony, alimony pendente lite, counsel fees and expenses
beyond those provided for herein, during the pendency of or as a result of any such
actions, as provided by the Divorce Code of Pennsylvania or any other applicable statute, at
this time and at any time in the future.
13. WAIVER OF EQUITABLE DISTRIBUTION. The parties acknowledge that each
of them have had a full and ample opportunity to consult with counsel of their choice
regarding their claims arising out of the marriage and divorce and that they have specifically
reviewed their rights to the equitable distribution of marital property, including rights of
discovery, the right to compel a filing of an Inventory and Appraisement, and the right to
have the court review the assets and claims of the parties and decide them as part of the
divorce action. Being aware of those rights, and being aware of the marital property
owned by each of the parties, the parties hereto, in consideration of the other terms and
provisions of this agreement, do hereby waive, release and quitclaim any further right to
have a court or any other tribunal equitably distribute or divide their marital property and do
hereby further waive, release and quitclaim any and all claim against or interest in assets
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now currently in the possession or held in the name of the other, it being their intention to
accept the terms and provisions of this agreement in full satisfaction of all of their claims to
the marital property of the parties and the equitable distribution of the same.
14. WAIVER OF ESTATE RIGHTS. Husband releases his inchoate intestate rights
in the estate of Wife and Wife releases her inchoate intestate rights in the estate of
Husband, and each of the parties hereto by these presents for himself or herself, his or her
heirs, executors, administrators, or assigns, does remise, release, quit claim, and forever
discharge the other party hereto, his or her heirs, executors, administrators, or assigns, or
any of them, of any and all claims, demands, damages, actions, causes of action or suits of
law or in equity, of whatsoever kind or nature, for or because of any matter or thing done,
omitted, or suffered to be done by such other party prior to the date hereof; except that
this release shall in no way exonerate or discharge either party hereto from the obligations
and promises made and imposed by reason of this agreement and shall in no way affect
any cause of action in absolute divorce which either party may have against the other.
15. WAIVER OF PROPERTY CLAIMS AND ESTATE CLAIMS. Except as herein
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otherwise provided, each party hereto may dispose of his or her property in any way, and
each party hereby expressly waives and relinquishes any and all rights he or she may now
have or hereafter acquire, under the present or future laws of any jurisdiction, to share in
the property or the estate of the other as a result of the marital relationship, including,
without limitation, the right to equitable division of marital property, alimony, alimony
pendente lite, and counsel fees, except as provided for otherwise in this Agreement,
dower, courtesy, statutory allowance, widow's allowance, right to take in intestacy, right
to take against the will of the other, and right to act as administrator or executor of the
other's estate, and each will, at the request of the other, execute, acknowledge, and
deliver any and all instruments which may be necessary or advisable to carry into effect
this mutual waiver and relinquishment of all such interests, rights, and claims.
16. REPRESENTATION AS TO NO DEBTS. The parties hereto mutually represent
to the other than neither of them has incurred any debts in the name of the other not
11
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previously disclosed or provided for in this agreement. Each of the parties hereby
represents to the other that neither one of them have incurred or contracted for debts in
the name of the other or for which the other is or would be legally liable from and after the
date of the parties' separation. Both parties hereto mutually agree and promise that neither
will contract or otherwise incur debts in the other's or joint names without the prior
permission and consent of the other party hereto. Both parties hereto represent and
warrant to the other party that they have not so contracted any debts unbeknownst to the
other up to the time and date of this Agreement.
1 7,. DISCLOSURE. Both of the parties hereto represent to the other that they have
made full disclosure of the assets and income and income sources owned, controlled, or
enjoyed by either of them and that neither party hereto has withheld any financial
information from the other. Each of the parties represents that they have reviewed such
information, as well as the law of Pennsylvania as it relates to their rights, obligations, and
claims arising out of their marriage and of any divorce action which has or may be filed
between the parties with an attorney of their choice, or had the opportunity to review such
matters with an attorney of their choice and voluntarily decided not to do so. Further, the
parties each acknowledge that they are aware that they have the right to compel the other
party to provide full financial information about all assets owned by either party and all
liabilities owed by either party and have the right to have a court force such disclosure in a
divorce action. Being aware of those rights, the parties expressly waive the right to further
disclosure or discovery regarding marital assets, liabilities, incomes, and finances and agree
that they are satisfied with their understanding of their legal rights and obligations. Being
so aware and satisfied, the parties mutually accept the terms and provisions of this
agreement in full satisfaction of any and all rights or obligations arising of their marital
status or the divorce action now pending or to be filed between them.
18. CONCLUSION OF DIVORCE. The parties agree that they shall, promptly upon
the request of Wife's attorney, make, execute, acknowledge, and deliver unto said
attorney, consents and waivers pursuant to Section 3301 (c) of the Pennsylvania Divorce
12
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Code and any and all other documents reasonably necessary to conclude a divorce action.
The parties agree that they shall take any and all action necessary to conclude a divorce
pursuant to Section 3301 (c) promptly after the execution of this agreement.
19. BREACH. In the event that any of the provisions of this agreement are
breached or violated by either of the parties, the other party shall be entitled to enforce this
agreement by an appropriate action in law or in equity or to take any other action to which
they are lawfully entitled to enforce this agreement or otherwise protect their rights. In the
event that such action is commenced by one of the parties and the other party is found to
have breached or violated any of the terms and provisions of this agreement, the party
having so violated or breached the agreement, shall be responsible for and shall promptly
pay upqn demand the reasonable attorney's fees incurred by the other party to enforce
their rights hereunder.
20. RELEASE. The parties acknowledge that the purpose of this agreement is to
divide all of their marital property, resolve all of the economic claims between them, and
terminate and conclude any and all claims one party may have against the other. The
parties acknowledge that each of them has had ample opportunity to consult with an
attorney of their choice and to obtain legal representation with regard to this agreement
and to the claims which they are terminating hereby. Consequently, each of the parties,
for themselves, their heirs, successors, and assigns, does hereby accept the terms and
provisions of this agreement in full satisfaction of any claims, of any nature, they may
have, or may ever have had, against the other party and each of the parties does hereby
waive, relinquish, release, and surrender forever any claim they have against the other
party, arising out of their marital relationship, or any other dealing between the parties prior
to the date of this agreement, provided, however, that this release shall not exonerate
either of the parties from the obligations they expressly make in this agreement, which
shall survive the date of this agreement until such obligations are fully performed.
21. CHOICE OF LAW. This Agreement shall be interpreted, applied and enforced
in accordance with the laws of, and by the courts of, the Commonwealth of Pennsylvania.
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22. SEVERABILITY. If for any reason whatsoever any part of this Agreement shall
be declared void or invalid, only such part shall be deemed void and in all other respects
this Agreement shall remain valid and fully enforceable.
23. NON-WAIVER. The waiver of any term, condition, clause, or provision of this
Agreement shall in no way be deemed or considered a waiver of any other term, condition,
clause or provision of this Agreement.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day
and year first above written.
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FRANCES L. TESLAR
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COMMONWEALTH OF PENNSYLVANIA )
( 55.:
COUNTY OF CUMBERLAND )
On this, the (,.;t-. day of !VoVf-/VI8c:R.. , 2000, before me, the undersigned officer,
personally appeared NICKOLAS G. STAMOS known to me (or satisfactorily proven) to be
the person whose name is subscribed to the within instrument, and acknowledged that said
person executed same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
My c~s=e:
ll:riHRf8Z~SfAL
My COMl.l/ffsYf~ cI/3:~:uu8l)c
PIRES AI/G. 1~ CIl
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
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( 55.:
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On this, the b*' day of NOVe;IV\IS~ ,2000, before me, the undersigned
officer, personally appeared FRANCES L. TESLAR known to me (or satisfactorily proven) to
be the person whose name is subscribed to the within instrument, and acknowledged that
said person executed same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
My CO!~iO~
Lr:g/HRfg!~~A~ SEAL
My COMM7fsrJ:ra i:1/~Jg[A~~8L1C
PIRES AUG 17 CO.
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FRANCES L. TESLAR,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2000-5102 CIVIL TERM
NICKOLAS G. STAMOS,
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
o THE PROTHONOTARY:
Transmit the record, together with the following information, to the Court for entry of a
ivorce decree:
1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c)..
2. Date and manner of service of the Complaint: Acceptance of Service filed by
Plaintiff's counsel indicating service on or about 28 July 2000.
3. Complete either Paragraph (a) or (b):
(a) Date of execution of the Affidavit of Consent required by
Section 3301 (c) of the Divorce Code:
By Plaintiff: November 6, 2000
By Defendant:
November 6, 2000
(b) (1) Date of execution of the Affidavit required by Section 3301
(d) of the Divorce Code: (2) Date of filing and service of
the Plaintiff's Affidavit upon the Respondent:
4. Related claims pending:
None.
5. Complete either (a) or (b):
(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 Section 3301 (c) Divorce
was filed with the Prothonotary: Dated November 6, 2000, filed
contemporaneously herewith. Date Defendant's Waiver of Notice in
Section 3301 (c) Divorce was filed with the Prothonotary: dated
November 6, 2000, filed contemporaneously herewith.
;Date: IS cDe.c... 2.000
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Attorney for Plaintiff
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Plaintiff
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NICKOLAS G. STAMOS,
Defendant
NO. 2000- O/tJd-. CIVIL TERM
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
foregoing 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 in divorce 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, including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the Office
of the Prothonotary at:
Office of the Prothonotary
Cumberland County Court House
1 Courthouse Square
Carlisle, Pennsylvania 17013
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
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FRANCES L. TESLAR,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2000- $1/)2/ CIVIL TERM
NICKOLAS G. STAMOS,
Defendant
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed in
the Court of Common Pleas of Cumberland County. This notice is to advise you that in
accordance with Section 3302(d) of the Divorce Code, you may request that the court
require you and your spouse to attend marriage counseling prior to a divorce being handed
down by the court. A list of professional marriage counselors is available at the Domestic
Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this
list is kept as a convenience to you and you are not bound to choose a counselor from this
list. All necessary arrangements and the cost of counseling sessions are to be borne by you
and your spouse.
If you desire to pursue counseling, you must make your request for counseling within
twenty days of the date on which you receive this notice. Failure to do so will constitute a
waiver of your right to request counseling.
2
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FRANCES L. TESLAR,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2000- .sltJ.z.,
CIVIL TERM
NICKOLAS G. STAMOS,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, FRANCES L. TESLAR, by her attorney,
Samuel L. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is FRANCES L. TESLAR, an adult individual who currently resides at
154 Lancaster Boulevard, Mechanicsburg, Cumberland County, Pennsylvania.
2. The Defendant is NICKOLAS G. STAMOS, an adult individual who currently
resides at 154 Lancaster Boulevard, Mechanicsburg, Cumberland County, Pennsylvania.
3. Both the Plaintiff and Defendant have been bona fide residents of the Common-
wealth of Pennsylvania for at least six months immediately previous to the filing of this
Complaint.
4. The Plaintiff and Defendant were married on 15 July 1984 in Camp Hill,
Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. This marriage is irretrievably broken.
3
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7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff
ay have the right to request that the Court require the parties to participate in counseling.
8. The Plaintiff requests this Court to enter a Decree of Divorce.
WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to the
Divorce Code of Pennsylvania.
I verify that the statements made in this Complaint are true and correct. I understand
that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904
(unsworn falsification to authorities).
DATE: / fj :TV( L '1 2-000
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FRANCES L. TESLAR
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Sa ue . Andes
Attorney for Plaintiff
Supreme Court ID 17225
525 North 12th Street
Lemoyne, PA 17043
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FRANCES L. TESLAR,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2000-5102 CIVIL TERM
NICKOLAS G. STAMOS,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
20 July 2000 and served upon the Defendant on or about 28 July 2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing of the complaint and the date of service of the
complaint on the Defendant.
3. I consent to the entry of a final decree in divorce either after service of a Notice of
Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of
Intention to Request Entry of the Decree.
4. I have been advised of the availability of marriage counseling and understand that
the Court maintains a list of marriage counselors and that I may request the Court to require
my spouse and I to participate in counseling and, being so advised, do not request that the
Court require that my spouse and I participate in counseling prior to the divorce becoming
final.
I verify that the statements made in this Affidavit are true and correct and I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904 relating to unsworn falsification to authorities.
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CIVIL ACTION - LAW
NO. 2000-5102 CIVIL TERM
NICKOLAS G. STAMOS,
Defendant
IN DIVORCE
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AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
20 July 2000 and served upon the Defendant on or about 28 July 2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing of the complaint and the date of service of the
complaint on the Defendant.
3. I consent to the entry of a final decree in divorce either after service of a Notice of
Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of
Intention to Request Entry of the Decree.
4. I have been advised of the availability of marriage counseling and understand that
the Court maintains a list of marriage counselors and that I may request the Court to require
my spouse and I to participate in counseling and, being so advised, do not request that the
Court require that my spouse and I participate in counseling prior to the divorce becoming
final.
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understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904 relating to unsworn falsification to authorities.
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Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2000-5102 CIVIL TERM
NICKOLAS G. STAMOS,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER SECTION 3301 ICI OF THE DIVORCE CODE
1. I consent to the entry of a final decree in divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees, or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
court and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this Waiver are true and correct. I understand
that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating
to unsworn falsification to authorities.
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Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2000-5102 CIVIL TERM
NICKOLAS G. STAMOS,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER SECTION 3301 ICI OF THE DIVORCE CODE
1. I consent to the entry of a final decree in divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees, or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
court and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this Waiver are true and correct. I understand
that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating
to unsworn falsification to authorities.
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
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vs.
CIVIL ACTION - LAW
::>IO;;L,
NO. 2000-~ CIVIL TERM
NICKOLAS G. STAMOS,
Defendant
IN DIVORCE
ACCEPTANCE OF SERVICE
The undersigned, NICKOLAS G. STAMOS, does hereby accept service of the
Divorce Complaint filed against him in this matter and acknowledges receipt of a
certified copy of that Complaint.
Date: 7cJ ~ d 0
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