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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
LAURA GOODMAN,
PLAINTIFF
No. 2000 5970
CIVIL TERM
VERSUS
ROBERT C. GOODMAN,
DEFENDANT
DECREE IN
DIVORCE
AND NOW,
.:r a.",~o.., IF .
LAURA GOODMAN
, z.t:JOI , IT IS ORDERED AND
DECREED THAT
, PLAINTIFF,
ROBERT C. GOODMAN
AND
, 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;
A PROPERTY SETTLEMENT AGREEMENT IS ATTACHED AND MADE A PART HEREOF FOR
PURPOSES OF ENFORCEMENT.
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~'"'---. ROTHONOTARY
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PROPERTY SETTLEMENT AGREEMENT
THIS AGREEMENT, dated the ~ day Of~ . 2000, by and between
Robert C. Goodman, residing at P.O. Box 789, Hanover, Adams County, Pennsylvania,
17331, Social Security Number 070-38-6195, hereinafter called the "Husband", and
Laura Goodman, formerly Helicher, residing at 427 Burnt House Road, Carlisle,
CUmberland County, Pennsylvania, 17013, Social Security Number 113-32-7054,
hereinafter called the "Wifell, who agree as follows:
WIT N E SSE T H
WHEREAS, the parties are Husband and Wife, having been married on May 17,
1986, in Chambersburg, Pennsylvania.
The parties separated August 5, 2000.
There are no children of this marriage.
WHEREAS, diverse, unhappy, and irreconcilable differences, disputes, and
difficulties have arisen between the parties, and it is the intention of Wife and
Husband to live separate and apart for the rest of their natural lives, and the
parties hereto 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 matters between them
relating to the ownership and equitable distribution of 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 estates.
NOW THEREFORE, in consideration of the promises and of the mutual promises,
covenants and undertakings hereinafter set forth and for other good and valuable
consideration, receipt of which is hereby acknowledged by each of the parties
hereto, Wife and Husband, each intending to be legally bound hereby, covenant and
agree as follows:
1. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS
This Agreement shall not be considered to affect or bar the right of Wife
or Husband to a limited or absolute divorce on lawful grounds if such grounds
now exist or shall hereafter exist or to such defense as may be available to
either party. This Agreement is not intended to condone and shall not be deemed
to be a condonation on the part of either party hereto of any act or acts on the
part of the other party which have occasioned the disputes or unhappy differences
which have occurred prior to or which may occur subsequent to the date hereof.
The parties intend to secure a mutual consent, no-fault divorce pursuant to the
terms of Section 3301(c) of the Divorce Code of 1980 as amended by Act No. 1990,
206 effective 3-19-91.
2. EFFECT OF DECREE. NO MERGER
It is further specifically understood and agreed that the provisions of
this Agreement relating to the equitable distribution of property of the parties
are accepted by each party as a final settlement for all purposes whatsoever.
Should either of the parties obtain a decree, judgment, or order of separation
or divorce in any other state, country, or jurisdiction, each of the parties to
this Agreement hereby consents and agrees that this Agreement and all of its
covenants shall not be affected in any way by any such separation or divorce; and
that nothing in any such decree, judgment, order, or further modification or
revision thereof shall alter, amend or vary any term of this Agreement, whether
or not either or both of the parties should remarry, it being understood by and
between the parties that this Agreement shall survive and shall not be merged
into any decree, judgment, or order of divorce or separation.
It is specifically agreed, however, that a copy of this Agreement may be
incorporated, by reference, into divorce judgment or decree. This incorporation,
however, shall not be regarded as a merger, it being the intent of the parties
to permit this Agreement to survive any such judgment, unless otherwise
specifically provided herein. and for this Agreement to continue in full force
and effect after such time as a final decree in divorce may be entered with
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respect to the parties. The parties agree that the terms of this Agreement may
be incorporated into any divorce decree which may be entered with respect to them
for purposes of enforcement only of any provisions therein, but shall survive
such decree.
That is, this agreement and all warranties and representations contained
herein shall survive the Divorce Decree and shall continue to be enforceable in
accordance with its terms.
Except with regard to child support and child
custody, no court may change the terms of this agreement, and it shall be binding
and conclusive upon the parties. In the event of a reconciliation, attempted
reconciliation, or other cohabitation of the parties hereto after the date of
this agreement, this agreement shall remain in full force and effect in the
absence of a written agreement signed by both parties expressly stating that this
agreement has been revoked or modified.
3. DISTRIBUTION DATE
Except for specific provisions herein the transfer of property, funds and/or
documents provided for herein shall take place simultaneously with the execution
of this Agreement.
ADVICE OF COUNSEL
wife and Husband declare that each has had a full and fair opportunity to
obtain independent legal advice of counsel of her and his selection; that Wife
has been independently represented by counsel and that husband, cognizant of his
right to legal representation, declares that it is his express, voluntary and
knowing intention not to avail himself of his right to counsel and chooses
instead to represent himself with respect to the preparation and execution of
this Agreement.
This Agreement has been prepared by Ruby D. Weeks, Esquire, the attorney
for Wife. Said attorney at the commencement of, and at all stages during the
negotiation of this Agreement, informed Husband that she has acted solely as
counsel for Wife and has not advised or represented Husband in any manner
whatsoever.
Husband, at the commencement of, and all stages during the
negotiation of this Agreement, has been informed by Ruby D. Weeks, Esquire, that
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he has a right to be represented by his own counsel and has encouraged him to
seek the advice of counsel. Husband has read this Agreement carefully and
thoroughly, fully understanding each of its provisions, and therefore signs it
freely and voluntarily.
4. FINANCIAL DISCLOSURE
The parties confirm that each has relied on the substantial accuracy of the
financial disclosure of the other as an inducement to the execution of this
Agreement, and that neither party wishes to exercise their right to have
appraisals by experts as to the value of the various interests of the other
party. They understand that such appraisals would be necessary to fix the fair
market value of these interests for purposes of equitable distribution.
S. WARRANTY OF DISCLOSURE
The parties warrant and represent that they have made a full disclosure of
all assets and their valuation prior to the execution of this Agreement. This
disclosure was in the form of an information exchange of information by the
parties' attorneys and this Agreement between the parties is based upon this
disclosure.
6. OBTAINING INFORMATION ON FINANCES
Each party acknowledges that they have been informed they may have the
right, as provided by statute and Pennsylvania Rules of Civil Procedure, to
obtain information regarding the parties' finances. Such information would
include, without limitation, their present and past income; and the identity and
value of assets both presently owned and transferred previously. Such
information may be obtained by one or more of several methods including
depositions upon oral examination, written interrogatories, production of
documents or entry upon property for inspection. The parties agree to waive any
further discovery.
7. PERSONAL RIGHTS
Wife and Husband may and shall, at all times hereafter, live separate and
apart. They shall be free from any control, restraint, interference or
authority, direct or indirect, by the other in all respects as fully as if they
were unmarried. They may reside at such place or places as they may select.
Each may, for his or her separate use or benefit, conduct, carryon and engage
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in any business, occupation, profession or employment which to him or her may
seem advisable. However, each party shall make best efforts to maintain
employment with comparable benefits and salary as they now hold or for which they
are in training.
8. NO MOLESTATION
Husband and Wife shall not molest or interfere with each other, nor shall
either of them attempt to compel the other to cohabit or dwell with her or him,
by any means whatsoever. Neither party shall harass or be verbally or
physically abusive to the other.
9. MUTUAL RELEASES
Husband and Wife each do hereby mutually remise, release, quitclaim and
forever discharge the other and the estate of such other, for all time to come,
and for all purposes whatsoever, of and from any and all rights, 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 or 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 (cl 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, equitable distribution, 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 the execution of this Agreement a full,
complete and general release with respect to any and all property of any kind or
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nature, real, personal or mixed, which the other now owns or may hereafter
acquire, 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.
10. EQUITABLE DISTRIBUTION OF PROPERTY
It is specifically understood and agreed that this Agreement constitutes
an 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 Act of April 2, 1980 (P.L. 63, No. 26) known
as liThe Divorce Code," 23 P.B. 3101 et. seq. of the
Commonwealth of
Pennsylvania.
And further, that the parties have attempted to divide their marital
property in a manner which conforms to the criteria set forth in 3502 of the
Pennsylvania Divorce Code, and taking into account the following considerations:
the length of the marriage, the prior marriages of the parties; the age, health,
station, amount and sources of income, vocational skills, employability, estate,
liabilities and needs of each of the parties; the contribution of one party to
the education, training, or increased earning power of the other partYi the
opportunity of each party for future acquisition of capital assets and income;
the sources of income of both parties, including but not limited to medical,
retirement, insurance or other benefits; the contribution or dissipation of each
party 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 the marriage; and the economic circumstances of each party at
the time the division of property is to become effective.
11. Real ProoertVl
The parties recognize that they own as tenants by the entirety real
property known as 427 Burnt House Road, Carlisle, Cumberland CO\lllty,
Pennsylvania. For the mutual promises and covenants contained in this Agreement,
Husband agrees to convey to Wife all right, title, claim, or interest he may have
by equitable distribution or otherwise in and to this property. This conveyance
shall take place upon issuance of decree in divorce. Wife shall have the right
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to exclusive possession of the marital residence until such time as the deed
transfers title to her. It is recognized that this conveyance is subject to an
existing first mortgage naming 1st Nationwide as mortgagee and having an
approximate balance of $97,218.00. Wife agrees to indemnify husband for any
loss, including counsel fees, that he might suffer as a result of default upon
this mortgage.
It is further agreed that the parties will divide equally the costs of Deed
preparation, notary and recording fees and the usual costs of sale. The Wife's
attorney shall prepare the Deed.
12. Distribution of Personal Property:
The parties hereto mutually agree that they have effected a satisfactory
division of the furniture, household furnishings, appliances, and other household
personal property between them as per Appendix "A" attached hereto and made a
part hereof, 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, and this Agreement shall have the effect of
an assignment or bill of sale from each party to the other for such property as
may be in the individual possession of each of the parties hereto.
The parties hereto have divided between themselves, to their mutual
satisfaction, all items of tangible and intangible marital property. Neither
party shall make any claim to any such items of marital property, or of the
separate personal property of either party, which are now in the possession
and/or under the control of the other. Should it become necessary, the parties
each agree to sign, upon request, any titles or documents necessary to give
effect to this paragraph. Property shall be deemed to be in the possession or
under the control of either party if, in the case of tangible personal property,
the item is physically in the possession or control of the party at the time of
the signing of this Agreement and, in the case of intangible personal property,
if any physical or written certificate of insurance or other similar writing is
in the possession or control of the party. Husband and Wife shall each be deemed
to be in the possession and control of his or her own individual pension or other
employee benefit plans or retirement benefits of any nature with the exception
of social security benefits to which either party may have a vested or contingent
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right or interest at the time of the signing of this Agreement, and neither will
make any claim against the other for any interest in such benefits.
From and after the date of the signing of this Agreement both parties shall
have complete freedom of disposition as to their separate property and any
property which is in their possession or control pursuant to this Agreement, and
may mortgage, sell, grant, convey, or otherwise encumber or dispose of such
property, whether real or personal, whether such property was acquired before,
during or after marriage, and neither Husband nor Wife need join in, consent to,
or acknowledge any deed, mortgage, or other instrument of the other pertaining
to such disposition of property.
13. GENERAL:
(1) Husband hereby waives all interest in Wife's property including but
not limited to all accounts, certificates of deposit and securities.
(2) Wife hereby waives all interest in Husband's property including but
not limited to all accounts, certificates of deposit, and securities.
14. MOTOR VEHICLES:
With respect to the motor vehicles owned by one or both of the parties,
they agree as follows:
(a) The 1993 Explorer, 1987 Celcia titled to Husband, shall become and
remain the sole and exclusive property of the Husband. There is no debt against
these vehicles.
(b) The 1997 Explorer, titled to Wife, shall become and remain the sole
and exclusive property of the Wife. There is no debt against this vehicle.
15. GENERAL:
(1) Husband hereby waives all interest in Wife's property including but
not limited to all accounts, certificates of deposit, securities and the three
dogs.
(2) Wife hereby waives all interest in Husband's property including but
not limited to all accounts, certificates of deposit, and securities.
(3) Husband and Wife agree that Husband shall pay all costs, including
attorney fees, of transferring any property necessary to be titled from joint
ownership to that of either party.
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16. FILING INVENTORIES AND APPRAISEMENT
The parties further acknowledge their understanding that they each have the
right to file Inventories and Appraisement with the Court and to require the
other party to do so.
Such Inventories and Appraisement require a party to
indicate, under oath, information regarding all marital property in which either
party has an interest as of the date the action was commenced. Fully knowing the
same, each party nonetheless waives their respective rights to request additional
discovery be conducted, to file Inventories and Appraisement with the Court, or
to require the other party to do so.
17. AFTER-ACQUIRED PERSONAL PROPERTY
Each of the parties shall hereafter own and enjoy, independently of any
claim or right of the other, all items of personal property, tangible and
intangible, subsequently acquired by the other party.
18. CASH PAYMENTS
Husband and Wife agree, as part of the consideration for all of the
agreements entered into pursuant to this final Property Settlement Agreement,
including the transfer of all real and personal property as set forth in this
agreement, that Husband shall pay to Wife the sum of twenty thousand dollars
($20,000.00), evidenced by a note he will give Wife payable starting March 1,
2001 at $833.33 per month for 24 months. Husband agrees to pay interest of 1 1/2
percent on any payment not timely made by the tenth (lOth) of each month for each
month it is late or overdue.
19. DEBTS.
Marital Debts: Husband agrees to pay the mortgage on the marital residence
and the following utilities: phone up to $50.00 per month, but not including
Wife's cell phone bill; trash, Agway propane and GPU for September, October,
November and December 2000. There are no other unpaid marital debts.
20. SUBSEOUENT PERSONAL DEBTS:
Husband and Wife agree from time of the signing of this Agreement that each
party shall be responsible for their own debts and hold each other harmless from
same.
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21. FUTURE DEBTS:
Husband and Wife hereby mutually agree that subsequent, to the execution of
this Agreement neither party shall incur any debts which will obligate the other
to make payment for same. Husband and Wife hereby acknowledge that there are no
outstanding bills or other indebtedness which have been incurred by either for
the liability of the other, and both parties hereby covenant and agree that
neither shall have any financial obligation to pay any financial obligations
which are solely the financial obligation of the other and which have been
contracted by either party solely for their own benefit and without the knowledge
or consent of the other party. Husband and Wife further agree that they will
indemnify the other from any and all claims or demands made against the other by
reason of any debts or obligations contracted in violation of this Agreement.
22. WARRANTY AS TO EXISTING OBLIGATIONS:
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 which may have
heretofore been incurred by them, including those for necessities, except for
the obligations arising out of this Agreement.
23. WARRANTY AS TO FUTURE OBLIGATIONS:
Wife and Husband each covenant, warrant, represent and agree that each will
now and at all times hereafter save harmless and keep the other indemnified from
all debts, charges and liabilities incurred by the other after the execution
date of this Agreement, except as may be otherwise specifically provided for by
the terms of this Agreement and that neither of them shall hereafter incur any
liability whatsoever for which the estate of the other may be liable.
24. ASSUMPTION OF LIABILITIES.
This provision sets forth the method for the payment and assumption of the
debts and liabilities of the parties. since the assumption is not binding on the
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creditor, the party assuming the debt agrees to indemnify the other party in the
event the creditor seeks to hold such other party liable. should the parties
wish to bind the creditor and relieve the original debts from all liability, a
novation should be executed.
25. TAX INDEMNIFICATION
A. Should any payments made by Husband to Wife be deemed as taxable
income to Wife by either the Internal Revenue Service or any other taxing agency,
the Husband shall make payment of any taxes, interest or penalties as may be due
and owing as a result thereof. Notwithstanding the foregoing, in the event that
Wife makes such payments of taxes, interest or penalties, then Husband will
reimburse Wife for said payments, within ten (10) days of written notice ot same.
B. If any tax payments made or owed by Husband under this paragraph,
are additionally determined to be taxable income to Husband, then Husband also
indemnifies Wife for any taxes, interest and penalties thereon that Husband may
have to pay as a result thereof.
26. INCOME TAX PRIOR RETURNS
The parties have heretofore filed joint federal, state and local income tax
returns. Husband agrees that in the event any deficiency in federal, state, or
local income, real estate or personal tax is proposed, or any assessment of any
such tax is made against Wife by reason of Husband having joined in the filing
of said joint returns or by reason of Husband prior omission to file returns or
pay such, Husband will indemnify and hold Wife harmless from and against any loss
or liability for any such tax deficiency or assessment and any interest, penalty,
and expense incurred in connection therewith, and such tax, interest, penalty or
expense shall be paid solely and entirely by Husband, unless said tax, interest,
penalty or expense is finally determined to be attributable to Wife's
misrepresentations or failures to disclose the nature and extent of Wife's
separate income on the aforesaid joint returns.
27. 2000 INCOME TAX RETURN
Husband and Wife agree that they shall file jointly for Federal, State and
Local Income Tax Returns for the year 2000 and Husband agrees to assume
responsibility for the payment of any tax due, including any interest or penalty,
for the year 2000. Husband shall indemnify and hold Wife harmless from same. Any
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tax refund, if one is received, shall be equally divided between the parties, and
Husband agrees to provide Wife copies of the returns.
28. WAIVER OF SPOUSAL SUPPORT, ALIMONY PENDENTE LITE. AND ALIMONY
The parties herein acknowledge that by this Agreement they have each
respectively secured and maintained a substantial and adequate fund with which
to provide themselves sufficient financial resources to provide for their
comfort, maintenance and support, in the station of life in which they are
accustomed. Wife and Husband do hereby waive, release and give up any rights
they may respectively have against the other for alimony, alimony pendente lite,
support or maintenance. It shall be from the date of this Agreement the sole
responsibility of each of the respective parties to sustain themselves without
seeking any support from the other party.
29. INSURANCE BENEFITS
Wife agrees to cover Husband under her health insurance benefits through
November 30, 2000 or until Husband has health insurance coverage through his
employer until a divorce is finalized. Husband agrees to reimburse Wife the
equivalent of the premium for a single person each month.
30. RETIREMENT FUNDS
A. The Husband, who has been employed by Eckerd Drug Company, has
accumulated benefits in his retirement account. It is agreed by the parties that
the Wife shall waive any interest she may have in any of the benefits, including
retirement, which the Husband may have as a result of his employment.
B. The Wife, who is not currently employed, also has retirement benefits.
It is agreed by the parties that the Husband shall waive any interest he may
have in any of the benefits, including retirement, which the Wife may have as
a result of her past or future employment.
31. LIFE INSURANCE
Both parties shall continue to maintain the current Reliastar life
insurance policies on their lives even in the event their employment changes,
naming the other party solely as irrevocable beneficiary of such policies for
a period of two (2) years from the date of agreement or through date of repayment
to Wife of monies due under this agreement, which ever occurs last. They shall
each provide a written list to the other setting forth the insurance company(s),
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policy number(s), and principal amount(s) of such insurance as provided above
with proof of beneficiary. They also agree not to borrow against or assign said
policies without prior written consent of the other party. Both Parties agree
to make payment of premiums on the policies on their individual lives so as to
continue said coverage as long as required to keep other party as beneficiary.
32. DIVORCE
Husband and Wife agree that Wife shall file a Complaint in divorce seeking
a divorce on the basis of mutual consent. Husband and Wife both agree that
ninety (90) days following the filing of a Divorce Complaint by Wife that both
parties will execute the required Affidavits of Consent to be filed with the
Court to allow the Court to grant a divorce on the basis of mutual consent.
AND the parties hereto state and agree that this Agreement shall not in any
way be construed as a collusive agreement
33. ATTORNEY FEES
The parties agree that Husband shall pay the first one thousand dollars
($1,000.00) of Wife's attorney fees and costs and one-half (1/2) of any amount
in excess of one thousand dollars ($1,000.00) in connection with the negotiation
and preparation of this Agreement and the granting of a divorce decree.
34. BREACH OF AGREEMENT
If either party fails in the due performance of obligations under this
Agreement at their election, the non-breaching party shall have the right to sue
for damages for breach of this Agreement or to rescind same and seek such legal
remedies as may be available to them. The breaching party will be responsible
for actual legal fees and costs incurred by the non-breaching party necessary to
the enforcement of this Agreement.
35. LAW OF PENNSYLVANIA APPLICABLE
This Agreement shall be construed in accordance with the laws of the
Commonwealth of Pennsylvania which are in effect as of the date of execution of
this Agreement.
36. AGREEMENT BINDING ON HEIRS
This Agreement shall be binding and shall inure to the benefit of the
parties hereto and their respective heirs, executors, administrators, successors
and assigns.
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37. SEVERABILITY
If any term, condition, clause 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 her or his
obligations under anyone or more of the paragraphs herein, with the exception
of tne satisfaction of the conditions precedent, shall in no way avoid or alter
the remaining obligations of the parties.
38.INTEGRATION
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.
39. NO WAIVER OF DEFAULT
This Agreement shall remain in full force and effect unless and until
terminated under and pursuant to the terms of this Agreement. The failure of
either party to insist upon strict performance of any of the provisions of this
Agreement shall in no way affect the right of such party hereafter to enforce
the same, nor shall the waiver of any breach of any provision
hereof be
construed as a waiver of any subsequent default of the same or similar nature,
nor shall it be construed as a waiver of any subsequent default of the same or
similar nature, nor shall it be construed as a waiver of strict performance of
any other obligations herein.
40. WAIVER OR MODIFICATION TO BE IN WRITING
No modification or waiver of any of the terms hereof 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.
41. SUBSEQUENT DIVORCE
It is contemplated that Wife will proceed with a Complaint in Divorce
against Husband in the near future.
Husband and Wife each agree to sign an
Affidavit of Consent and an Affidavit waiving counseling to be filed in said
divorce action. In the event such divorce action is concluded, Husband shall be
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entitled to receive a copy of the Decree in Divorce for the normal fee charged
by the Prothonotary and shall not be assessed any costs of the proceeding, except
as previously agreed to herein in Paragraph 33. In the event such divorce action
is concluded, the parties shall be bound by all the terms of this Agreement,
which shall not be incorporated by reference into the Divorce Decree, and this
Agreement shall not be merged in such Decree, but shall in all respects survive
the same and be forever binding and conclusive upon the parties.
42. MUTUAL COOPERATION
Each party shall, at any time and from time to time hereafter, take any and
all steps and execute, acknowledge and deliver to the other party any and all
further instruments and/or documents that the other party may reasonably require
for the purpose of giving full force and effect to the provisions of this
Agreement.
43. AGREEMENT BINDING ON HEIRS
This Agreement shall be binding and shall inure to the benefit of the
parties hereto and their respective heirs, executors, administrators, successors
and assigns.
44. OTHER DOCUMENTATION
Wife and Husband covenant and agree that they will forthwith (and within
at least ten (10) days after demand therefore) execute any and all written
instruments, assignments, releases, satisfactions, deeds, notes, or such other
writings as may be necessary or desirable for the proper effectuation of this
Agreement, and as their respective counsel shall mutually agree should be so
executed in order to carry out fully and effectively the terms of this Agreement.
45. TAX REFORM ACT
The parties acknowledge that the Tax Reform Acts of 1984 and 1986, and all
amendments thereto, created dramatic changes in the tax law as it affects the
dissolution of marriages, including but not limited to the tax consequences of
support payments and all taxes associated with the division of property. Ruby
D. Weeks, attorney for the Plaintiff, does not hold herself out as being an
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expert in tax related matters and, therefore, has recommended that the parties
obtain competent tax advice from an independent source. By execution hereof, the
parties have acknowledged such recommendation and, if they so desire, have sought
and obtained advice with regard to matters of concern to them, as contemplated
herein.
46. BANKRUPTCY
In the event that either party becomes a debtor in any bankruptcy or
financial reorganization proceedings of any kind while any obligations remain to
be performed by that party for the benefit of the other party pursuant to the
provisions of this Agreement, the debtor spouse hereby waives, releases and
relinquishes any right to claim any exemption (whether granted under state or
federal law) to any property remaining in the debtor as a defense to any claim
made pursuant hereto by the creditor-spouse, and the debtor-spouse hereby
assigns, transfers, and conveys to the creditor-spouse an interest in all of the
debtor's exempt property sufficient to meet all obligations to the creditor-
spouse as set forth herein, including all attorneys' fees and costs incurred in
the enforcement of this Paragraph or any other provision of this Agreement.
No obligation created by this Agreement shall be discharged or
dischargeable, regardless of federal or state law to the contrary, and each party
waive@ any and all right to assert that any obligation hereunder is discharged
or di@chargeable.
47. Hl!:ADINGS NOT PART OF AGREEMENT
Ally headings preceding the text of the several paragraphs and subparagraphs
hereof are inserted solely for convenience of reference and shall not constitute
a pare of this Agreement nor shall they affect its meaning, construction or
effect.
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IN WITNESS WHEREOF, the parties hereto have set their hands and seals the
day and year first above written.
Er^j 11"", \)
Robert C. Goodman
21?~ ~
Witnese
Laura Goodman
COMMONWEALTH OF PENNSYLVANIA
ss
COUNTY OF CUMBERLAND
On this, the ~day of
~ ~ITJ'&r, 20~
before me, a Notary
Public, the undersigned officer, personally appeared Robert C. Goodman, known to
me to be the person whose name is subscribed to the within Property Settlement
Agreement, and acknowledged that he executed
NOTARIAL SE.I\L
LORI A, RENOLI-.
ItAl-lC
Public
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HANeV!H.. PA. YO,. ~ ~C'UNTY .~
MV COMMISSION E:XPUI;;:S MAY l~ 2003
COMMONWEALTH OF PENNSYLVANIA
ss
COUNTY OF CUMBERLAND
on this, the ~
day of
~oph!rhiJ U) , 20.aL, before me, a Notary
personally appeared Laura Goodman, known to me
Public, the undersigned officer,
to be che person whose name is subscribed to the within Property Settlement
Agreement, and acknowledged that she executed the same for the purposes therein
contained.
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LAURA GOODMAN,
Plaintiff
VB.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
NO.2000-5970 CIVIL TERM
ROBERT C. GOODMAN,
Defendant
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)
2. Date and manner of service of the complaint: Certified mail, restricted delivery, number
70993400000452152647. Mailed on August 29,2000, service accepted on August 30,2000.
3. Date of execution of the affidavit of consent required by Section 330l(c) of the Divorce
Code: by the plaintiff 1/12/01; by the defendant 1/9/01.
4.
Related claims pending:
None
5. Date plaintiff's Waiver of Notice in ~ 330l(c) Divorce was filed with the prothonotary:
January 15,2001.
Date defendant's Waiver of Notice in ~ 330 I (c) Divorce was filed with the prothonotary:
January 15, 2001.
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Date: January ji, 2001
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LAURA GOODMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
"'v>V'lO 5070
# orCA." - CIVIL TERM
ROBERT C. GOODMAN,
Defendant
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 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 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 the Cumberland
County Court House, 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
717-249-3166
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LAURA GOODMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
ROBERT C. GOODMAN,
Defendant
# tJtJ.597(} CIVIL TERM
AFFIDAVIT OF MARRIAGE COUNSELING
I, Laura Goodman, being duly sworn according to law, depose and say:
1. I have been advised of the availability of marriage counseling and
understand that I may request that the Court require that my spouse and I
participate in counseling.
2. I understand that the Court maintains a list of marriage counselors in the
Prothonotary's Office, which list is available to me upon request.
3. aeing so advised, I do not request that the Court require that my spouse
and I participate in counseling prior to a divorce decree being handed
down by the Court.
I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities.
Dated:
1/;>'5 Joo
qoCUNlA.~
Laura Goodman, Plaintiff
Sworn and SUbSC~~,~ et t<o
befoTl' me this OJC,Tr--
of Ull~'-o J
~ LvY\Ov\hOi.J
Notary Public
day
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MOrAIIAL ..
MIOL A. .d/It:IN. Maay PublIc
QIIIIIe IIont, o..abe1IlIIld County
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LAURA GOODMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
ROBERT C. GOODMAN,
Defendant
# (j1J.5tJ11J CIVIL TERM
COMPLAINT IN DIVORCE
TO THE HONORABLE, THE JUDGES OF SAID COURT:
AND NOW COMES, Laura Goodman, Plaintiff, by her attorney, Ruby D. Weeks,
Esquire, who avers as follows:
1.
Plaintiff, an adult sui juris, is Laura Goodman, a U. S.
citizen, who
currently resides at 427 Burnt House Road, Cumberland County, Pennsylvania
17013, since 1989.
2. Defendant, an adult sui juris, is, aU. S. citizen, who currently resides
at P.O. BOX 789, Hanover, Pennsylvania 17331, since August 5, 2000.
3. Plaintiff and Defendant have been a bona fide resident(s) in the
Commonwealth of Pennsylvania for at least six months immediately previous
to the filing of this Complaint.
4. The Plaintiff and Defendant were married on May 17, 1986 in Charnbersburg,
pennsylvania.
5. There have been no prior actions of divorce or for annulment between the
parties in this or any other jurisdiction.
6. Neither party is a member of the Armed Forces of the United States.
7. The marriage is irretrievably broken.
8. Plaintiff and Defendant have lived separate and apart since August 5,
2000.
9. Plaintiff has been advised that counseling is available and that Plaintiff
may have the right to request that the Court require the parties to
participate in counseling.
10. Plaintiff requests the Court to enter a decree of divorce.
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COUNT I (A)- INDIGNITIES
3301 la) (6) of the Divorce Code
1. Paragraphs 1 through 6 are hereby incorporated by reference and made a part
hereof.
2. The averments under this Count are not collusive.
3. Defendant has offered such indignities to Plaintiff, the innocent and
injured spouse, as to render her condition intolerable and life
burdensome.
COUNT II - IRRETRIEVABLE BREAKDOWN
3301 Ic) of the Divorce Code
4. Paragraphs 1 through 9 are hereby incorporated by r~ference and made a
part hereof.
5. The marriage is irretrievably broken.
a. Plaintiff and Defendant have lived separate and apart since
August 5, 2000.
6. Plaintiff has been advised as to the availability of counseling and that
she may have the right to request that the Court require the parties to
participate in counseling.
7. Plaintiff requests the Court to enter a decree of divorce.
WHEREFORE, plaintiff prays that a decree in divorce be entered divorcing
plaintiff from the bonds of matrimony between the said plaintiff and defendant.
8.
a.
As to Count I, that a decree in divorce be entered divorcing
Plaintiff from the bonds of matrimony between the said Plaintiff and
Defendant.
b. As to Count II, in the alternative, should Defendant execute an
Affidavit consenting to a divorce because the marriage is
irretrievably broken, that a decree in divorce be entered divorcing
Plaintiff from the bonds of matrimony between the said Plaintiff and
Defendant.
c. Such other additional relief as the Court deems necessary and
appropriate.
I verify that the statements made in this Complaint are true and correct.
I understand that false statements herein are made subject :to the penalties of
18 Pa. C.S. ~4904, relating to unsworn falsification to authorities.
Date:
f /2 s I~
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Laura Goodman, Plaintiff
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Attorney for Plaintiff
10 West High Street
Carlisle, PA 17013
(717) 243-1294
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COMMONWEALTH OF PENNSYLVANIA
ss
COUNTY OF CUMBERLAND
The above named, Laura Goodman, being duly sworn according to law, deposes
and says that the facts contained in the foregoing Complaint are true and
correct, and the Complaint is not made out of levity or by collusion between her
and the said Defendant for the mere purpose of being freed and separated from
each other, but that it is brought in sincerity and in truth for the cause
mentioned in the said Complaint.
~~~
Laura Goodman, Plaintiff
Sworn and sw:sc~~ to
befo}f me, th~s ~"daY~n'
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LAURA GOODMAN,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
IN DIVORCE
ROBERT C. GOODMAN,
Defendant
NO.2000-5970 CIVIL TERM
AFFIDAVIT OF SERVICE BY MAIL
PURSUANT TO PA R.C.P. 1920.4 tal (1) (ii)
COMMONWEALTH OF PENNSYLVANIA
ss
COUNTY OF CUMBERLAND
I, RUBY D. WEEKS, ESQUIRE, Attorney for Laura Goodman, being duly sworn
according to law, depose and say that a true and correct copy of the Divorce
Complaint, was served on Robert C. Goodman, at P.O. Box 789, Hanover,
Pennsylvania, 17331, by mailing the same to him by certified mail, restricted
delivery, No. 7099 3400 0004 5215 2647, on August 29, 2000 Service was
accepted on August 30, 2000.
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LAURA GOODMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - LAW
IN DIVORCE
ROBERT C. GOODMAN,
Defendant
NO.2000-5970 CIVIL TERM
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed
on August 29, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
,
(90) days have elapsed from the date of filing and service of the
Complaint.
3. I consent to the entry of a final decree of divorce after service of
notice of intention to request entry of the decree.
4. 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.
I verify that the statements made in this Affidavit are true and correct.
I understand that false statements herein are made subject to the penalties of
18 Pa. C.S. ~4904 relating to unsworn falsification to authorities.
Dated:
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Laura Goodman, Plaintiff
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Sworn and
befo~ me
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subscr;!:R.ed to
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MOfAIIAL ~ Public
CAROL'" ~~~and CDut\1Y
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LAURA GOODMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
,
CIVIL ACTION - LAW
IN DIVORCE
ROBERT C. GOODMAN,
Defendant
NO.2000-5970 CIVIL TERM
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF DIVORCE DECREE UNDER S 3301 (c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of 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 affidavit are true and correct.
I understand that false statements herein are made subject to the penalties of
18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities.
Date:
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MOrAllAl seAL
CAROl. A. NCI/IIDNj NoIaJy PublIc
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Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
IN DIVORCE
ROBERT C. GOODMAN,
Defendant
NO.2000-5970 CIVIL TERM
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed
on August 29, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of filing and service of the
Complaint.
3. I consent to the entry of a final decree of divorce after service of
notice of intention to request entry of the decree.
4. 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.
I verify that the statements made in this Affidavit are true and correct.
I understand that false statements herein are made subject to the penalties of
18 Pa. C.S. ~4904 relating to unsworn falsification to authorities.
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befor~ this ~ day
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LAURA GOOPMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VB.
CIVIL ACTION - LAW
IN DIVORCE
ROBERT C. GOODMAN,
Defendant
NO.2000-5970 CIVIL TERM
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY
OF DIVORCE DECREE UNDER S 3301 (e) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of 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 affidavit are true and correct.
I understand that false statements herein are made subject to the penalties of
18 Pa.C.S. 5 4904 relating
Rob
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LAURA GOODMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
IN DIVORCE
ROBERT C. GOODMAN,
Defendant
NO.2000-5970 CIVIL TERM
NOTICE OF ELECTION TO RETAKE MAIDEN NAME
Notice is hereby given that the Plaintiff in the above matter, having been
granted a Pinal Decree in Divorce from the bonds of matrimony on the
date day
of
,2001, hereby elects to retake and hereafter use her
previous name of LAURA HELICHER.
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TO BE KNOWN AS:
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COMMONWEALTH OF PENNSYLVANIA
ss
COUNTY OF CUMBERLAND
I '-IIi ~1 J J)t 1.
On che (J? day of ;~._-
, 2001, before me a Notary Public,
personally appeared LAURA GOODMAN (HELICHER). known to me to be the person whose
name is subscribed to the within document and acknowledged that she executed the
foregoing for the purpose therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
..a"" -
CMlL A. fIIJI/IIt1III. NoiIeIY PublIc
CaaIIIIe IIoro. Cumbedand CountY
tItt c::.J._.;il!I~ 11!xp1tei June 28, 2003
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Notary Public
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