HomeMy WebLinkAbout01-07100
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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PENNA.
STATE OF
c:r.RI\lN .T _ (,J\PT.~N.r
No. 2001 7100
Plaintiff,
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VERSUS
BEVERLY L. CAPLAN,
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Defendant.
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DECREE IN
DIVORCE
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AND NOW,
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DECREED THAT Glenn J. Caplan
PLAINTIFF,
AN D Beverly L. Caplan
, DEFENDANT,
ARE DiVORCED FROM THE BONDS OF MATRIMONY.
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THE COURT RETAiNS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAiSED OF RECOf~.~lJ1jS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED; ~vc:.--
The Marital Settlement Aareement dated April
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incorporated but not merged
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ATTEST:
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PROTHONOTARY
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Michael S. Travis
ill No. 77399
4076 Market Street, Suite 209
Camp Hill, P A 17011
(717) 731.9502
GLENN J. CAPLAN,
Plaintiff,
In the Court of Common Pleas of Cumberland County,
Pennsylvania
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No. 2001- 7100
vs.
BEVERLY L. CAPLAN,
Defendant.
CIVIL TERM
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court for entry of a
divorce decree:
1. Ground for divorce: irretrievable breakdown under 9 3301(c)(1) of the Divorce
Code.
2. Date and manner of service of the complaint: Complaint was mailed December
20,2001, via United States certified mail, restricted delivery, return receipt requested to
Defendant, which was received by Defendant on December 21, 2001, Affidavit of service
attached hereto.
3. Date of execution of the affidavit of consent required by 9 3301(c) of the Divorce
Code: by Plaintiff on April 29, 2002; by Defendant on April 26, 2002.
4. Related claims pending: Economic claims are resolved by Marital Settlement
Agreement dated April 19, 2002, incorporated by reference hereto.
5.
prothonotary:
Date1lain~ft'S Waiver of Notice in 9 330l(c) Divorce was filed with the
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prothonotary:
DVDefendant1s Waiver of Notice in 9 3301(c) Divorce was filed with the
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~ Michael S. Travis
Attorney for Plaintiff
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~GESETTLEMrnNTAGREEMrnNT
TIllS AGREEMENT made this lqt1'day of~ ,2002, by and between Glenn J.
Caplan, (hereinafter referred to as "Husband,") and~ly L. Caplan, (hereinafter referred to
as "Wife").
WITNESSETH:
WHEREAS, the Husband and Wife were lawfully married on December 9,1999; and
WHEREAS, there were no children born of this marriage;
WHEREAS, differences have arisen between Husband and Wife in consequence of which
they intend to live apart from each other; and
WHEREAS, Husband and Wife desire to settle and determine their rights and
obligations; and
NOW, THEREFORE, the parties intending to be legally bound hereby do covenant and
agree as follows;
1. DEFINITIONS
(a) Date of Execution ofthis Agreement. The phrase "date of execution" or
"execution date" of this Agreement shall be defined as the date of execution by the parties ifthey
each have executed the Agreement on the same date. Otherwise, the "date of execution" or
"execution date" of this Agreement shall be defined as the date of execution by the party last
executing this Agreement.
(b) Distribution Date. The phrase "distribution date" shall be defined as fourteen
days following the entry ofa final decree in divorce and the filing of Waivers of Appeals by each
party. If the fourteenth day falls on a weekend or holiday, the distribution date shall be the next
business date.
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2. ADVICE OF COUNSEL
The parties have had an opportunity to review the provisions of this Agreement
with their respective counsel. Husband is represented by Michael S. Travis, Esquire. Wife is
represented by . Husband and Wife acknowledge that this Agreement is not the
result of any duress or undue influence and that it is not the result of any collusion or improper or
illegal agreement or agreements. The parties further acknowledge that they have each made to
the other a full accounting of their respective assets to the extent that it has been requested. Each
party agrees that he or she shall not at any future time raise as a defense or otherwise the lack of
such disclosure in any legal proceeding involving this Agreement with the exception of
disclosure that may have been fraudulently withheld.
3. SEPARATION
It shall be lawful for each party at all times hereafter to live separate and apart
from the other party at such place or places as he or she may from time to time choose or deem
fit. The foregoing provisions shall not be taken as an admission on the part of either party as to
the lawfulness or unlawfulness of the causes leading to their living apart.
4. INTERFERENCE
Each party shall be free from interference, authority, and contact by the other as
fully as ifhe or she were single and unmarried except as may be necessary to carry out the
provisions of the agreement. Neither party shall molest the other or attempt to endeavor to
molest the other, nor compel the other to cohabit with the other, or in any way harass or malign
the other, nor in any way interfere with the peaceful existence, separate and apart from the other.
5. DIVISION OF PERSONAL PROPERTY
The parties hereto have divided between themselves, to their mutual satisfaction,
all items of tangible and intangible marital property. Excepting the list attached hereto as Exhibit
"A," neither party shall make any claim to any other such items of marital property, or to the
separate personal property of either property, which are now in the possession and/or under the
control of the other.
6. SPOUSAL SUPPORT/ALIMONY PENDENTE LITE
Each party agrees to relinquish any right to support, maintenance or Alimony
Pendente Lite.
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7. ALIMONY
The parties herein acknowledge by this Agreement they have respectively secured
and maintained substantial and adequate funds with which to provide for themselves sufficient
fmancial resources to provide for their comfort, maintenance and support, in the station of life
which they are accustomed. Husband and Wife do hereby waive, release and agrees to relinquish
the right to Alimony.
8. LIFE INSURANCE
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It shall not be necessary for either party to maintain a policy oflife insurance for
the benefit of the other party.
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9.
AUTOMOBILES
(a) The parties are the owners of two automobiles, a 1999 Plymouth Voyager
driven by Husband and a 1994 Ford Probe, driven by Wife. The Plymouth is encumbered by a
purchase money loan; the Ford is not encumbered by a purchase loan. Husband shall have sole
and exclusive possession of the Plymouth. Wife shall have sole and exclusive possession of the
Ford.
(b) Husband shall assume and hold Wife harmless for the purchase money loan on
his auto. Should any action be required to transfer title or other document of ownership, the
parties will take steps to transfer and reflect ownership as soon as possible after the distribution
date.
(c) Both parties agree to assume all responsibility and hold each other harmless
for any and all liability, including insurance, costs and expenses associated with ownership of the
above.
10. DIVISION OF REAL PROPERTY
Premises. Husband holds title to the premises identified as 1933 Chatham Drive,
Camp Hill, Cumberland County, Pennsylvania, 17011. (The Marital Residence). The property is
titled to Husband and Tammy Yinger. The parties agree as follows with respect to the Marital
Residence:
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The house shall be the sole and exclusive property of Husband. Husband shall be
solely responsible for all future costs, expenses or liabilities attributable and/or resulting from
Husband's and/or Wife's interests in the Marital Premises, and/or by reason of Wife's former
ownership thereof The property is encumbered by a purchase money mortgage with Waypoint
Bank. The property is believed to be worth approximately $85,000.00. Husband agrees to be
responsible for any and all encumbrances on the property and indemnify and hold wife harmless
for any claim thereon.
Wife waives the right to any equity in the marital residence. Should Husband
desire to refmance the mortgage on the property, Wife further agrees to cooperate in signing
documents which the lender may require to accomplish the later sale, assumption or refinance
which is consistent with this agreement.
11. PENSION RETIREMENT AND TRUST ACCOUNTS
Husband and Wife shall maintain their separate pension, IRA and/or retirement
accounts. Wife relinquishes any other rights, title, and interest she may have in all other existing
and future retirement assets or benefits of Husband' s pension or retirement plans, 40lK or other
account, including Stock Options, Savings and Cash balance plans. Husband relinquishes any
and all rights, title, and interest he may have in all existing or future retirement assets or benefits
of Wife's pension or retirement, 401K or other account.
Trust Account. Husband receives the benefit of a trust account payment
sometimes referred to as the "Meyer Freed Trust." This property is pre-marital in nature under
the divorce code and Wife makes no claim thereto.
12. MEDICAL INSURANCE
The parties shall be responsible for their own medical insurance.
13. MARITAL DEBTS
Husband agrees to hold Wife harmless for jointly filed taxes owed while married.
The parties represent that there are no joint marital obligations. Each of the
parties agrees to keep the other indemnified and saved harmless from all debts or liabilities
incurred by him or her prior to the date of this agreement and from all actions, claims and
demands whatsoever with respect thereto, and from all costs, legal or otherwise, and any counsel
fees whatsoever pertaining to such actions, claims and demands.
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Since separation, neither party has contracted for any debts which the other will
be responsible for and each party indemnifies and holds harmless the other for all obligations
separately incurred or assumed under this Agreement.
Husband has obligations for the following debts, People's Bank, American
Express, American Express Optima, Discover Card, First USA Visa and Kohl's. Husband
intends to file for bankruptcy protection. Payment of these obligations shall be his responsibility.
14. FILING OF IRS RETURN/TAXES
Husband and Wife agree to file separate tax returns for the tax year in which the
Decree in Divorce is entered.
15. DIVORCE
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The parties agree to cooperate with each other in obtaining a final divorce of the
marriage. It is agreed that the parties will execute and allow to be filed the necessary documents
to obtain a divorce under Section 330l(c) of the Divorce Code.
16. DEATH PRIOR TO DIVORCE
If either Husband or Wife dies before the entry of a final decree in divorce
between the parties, this Agreement is deemed to survive the death, and the parties, heirs or
assigns shall enter into the same status as after the Agreement was entered into.
17. INCORPORATION
This agreement is to be incorporated for the purposes of enforcement, but not
merged into any subsequent Decree in Divorce.
18. CONTINUED COOPERATION
The parties agree that they will, after the execution of this Agreement, execute
any and all written instruments, assignments, releases, deeds or notes or other such writings as
may be necessary or desirable for the proper effectuation ofthis Agreement.
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19. COUNSEL FEES
Except as otherwise provided for in this Agreement, each party shall be
responsible for his or her own legal fees and expenses.
20. BREACH
If either party breaches any provision of this Agreement, the other party shall have
the right, at his or her election, to sue for damages for such breach, and the party breaching this
contract shall be responsible for the payment of legal fees and costs incurred by the other in
enforcing their rights under this Agreement or for seeking such other remedies or relief as may
be available to him or her.
21. VOLUNTARY AGREEMENT
The provisions of this Agreement are fully understood by both parties and each
party acknowledges that the Agreement is fair and equitable; that it is being entered into
voluntarily; and that it is not the result of any duress or undue influence.
22. W AlYER OF CLAIMS AGAINST ESTATES
Except as herein otherwise provided, each party may dispose of his or her
property in any way, and each party hereby 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, dower, curtsey, statutory allowance, widows allowance, right to take in intestacy, right
to take against the will of the other and the right to act as administrator or executor of the other's
estate.
23. BINDING EFFECT
This Agreement shall be binding upon the parties' heirs, successors and assigns.
24. MODIFICATION AND W AlYER
Any modification or waiver of any of the provisions of this Agreement shall be
effective only if made in writing and executed with the same formalities as this Agreement. The
failure of either party to insist upon strict performance of any of the provisions of this Agreement
shall not be construed as a waiver of any subsequent default of the same or similar nature.
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25. PRIOR AGREEMENTS
It is understood and agreed that any and all prior agreements which may have
been made or executed or verbally discussed prior to the date and time of this Agreement are null
and void and of no effect.
26. ENTIRE AGREEMENT
This Agreement contains the entire understanding of the parties and there are no
representations, warranties, covenants or undertakings other than those expressly set forth herein.
27. DESCRIPTIVE HEADINGS
The descriptive headings used herein are for convenience only. They shall not
have any binding effect whatsoever in determining the rights or obligations of the parties.
28. APPLICABLE LAW
This Agreement shall be construed under the laws of the Commonwealth of
Pennsylvania.
IN WITNESS WHEREOF, the parties set their hands and seals the day and the
year first written above.
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EXIDBIT A
Items of personalty to be delivered to Beverly Caplan:
None.
Items of personalty to be delivered to Glenn Caplan:
None.
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Commonwealth of Pennsylvania:
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County of Will 'oe(\c.n~\
PERSONALLY APPEARED BEFORE ME, this ~ day of ~ AJ. Q ,2002, a
notary public, in and for the Commonwealth of Pennsylvania, Glenn J. Caplan, known to me (or
satisfactorily proven to be) the person whose name is subscribed to the within agreement and
acknowledged that he executed the same for the purposes herein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
Notarial Seal :~ 11 -fllaib
Hope A. Mattos, Notary Public Notary Pubhc
Camp Hili BolO, Cumberland County
My Commission Expires Oct, 11, 2004
M~llQf, PennsyJvanta A6SOCl8UOn ot Notanas
Commonwealth of Pennsylvania:
County of \fVPotue--
PERSONALLY APPEARED BEFORE ME, this l ~y of ~ ,2002, a
notary public, in and for the Commonwealth of Pennsylvania, Beverly L. Caplan, known to me
(or satisfactorily proven to be) the person whose name is subscribed to the within agreement and
acknowledged that she executed the same for the purposes herein contained.
ss:
Notary Public
NOTARIAL SEAL ..
WALTER L. WINCH, Notary Public
Susquehanna Twp., Dauphin County I
My Commission expires July 9, 200S .
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BEVERLY L. CAPLAN,
Defendant.
In the Court of Common Pleas of Cumberland County,
Pennsylvania
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No.2001-7100
GLENN J. CAPLAN,
Plaintiff,
vs.
CIVIL TERM
IN DIVORCE
AFFIDAVIT OF SERVICE
I, Michael S. Travis, attorney for Plaintiff, in the above captioned action for divorce,
hereby state that a conformed and certified copy of the Complaint in Divorce was served upon
the Defendant by Certified Mail No. 7000 1670000089540069, return receipt requested, by
depositing the same in the United States mail on December 20, 2001, pursuant to Rille 1920.4 of
the Amendments to the Pennsylvania Rules of Civil Procedure relating to the Divorce Code. As
indicated by the green return receipt card attached hereto, the Complaint was received by the
Defendant on December 21, 2001.
I verify that the statements made in this Affidavit are true and correct. I understand that
false statements herein are subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn
falsification to authorities.
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4076 Market Street, Suite 209
Camp Hill, P A 17011
(717) 731-9502
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
GLENN J. CAPLAN,
Plaintiff,
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No.2001- 7/UlJ ~ I..L<--
CIVIL TERM
IN DIVORCE
vs.
BEVERLY L. CAPAAN,
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 ofthe 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 Courthouse
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 TillS PAPER TO YOUR LA WYERAT ONCE. IF YOU DO
NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, P A 17013
(717) 249-3166
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
GLENN J. CAPLAN,
Plaintiff,
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No.2001- 71 fJ1J
vs.
BEVERLY L. CAP.6AN,
Defendant.
CIVIL TERM
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant ina Complaint in 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.
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Michael S. Travis
ill No. 77399
4076 Market Street, Suite 209
Camp Hill, P A 17011
(717) 731-9509
In the Court of Common Pleas of Cumberland County,
Pennsylvania
BEVERLY L. CAPLAN,
Defendant.
)
)
)
)
)
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No. 2001 - 11d7J
CIVIL TERM
IN DIVORCE
GLENN J. CAPALN,
Plaintiff,
vs.
COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR
3301(d) OF THE DIVORCE CODE IN DIVORCE
Plaintiff, by his attorney Michael S. Travis, respectfully represents:
1. Plaintiff is Glenn J. Caplan, who resides at 1933 Chatham Drive, Camp Hill,
Cumberland County, Pennsylvania, 17011, since 1996.
2. Defendant is Beverly L. Caplan, who resides at 1079 B Michigan Drive,
Harrisburg, Dauphin County, Pennsylvania, 17111, since September 8, 2001.
3. Plaintiff has bee~ a bona fide resident of the Commonwealth of Pennsylvania
for at least six months immediately previous to the filing ofthis Complaint.
4. The plaintiff and defendant were married on December 9, 1999, in St. Lucia,
United States Virgin Islands.
5. There have been no prior actions of divorce or annulment between the parties in
this or any other jurisdiction.
6. The marriage is irretrievably broken.
7. The parties have been living separate and apart. At a subsequent time, plaintiff
may submit an Affidavit that the parties have lived separate and apart for at least two (2) years.
8. 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.
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9. Neither plaintiff nor defendant are in the Military Service in the United States
Armed Services. Neither plaintiff nor defendant are within the provisions of the Soldiers' and
Sailors' Relief Act of Congress of 1940 and its amendments.
10. Plaintiff requests the court to enter a decree of divorce.
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. S 4904, relating to
unsworn falsification to authorities.
Date:
~ 1...-\."\-0\
L~
Glenn J. Caplan, Plaintiff
~
Attorney for Plaintiff
LD. # 77399
4076 Market Street, Suite 209
Camp Hill, PA 17011
(717) 731-9502
Fax 731-9511
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
GLENN J. CAPLAN,
Plaintiff,
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No. 2001 - 7100
CIVIL TERM
IN DIVORCE
vs.
BEVERLY L. CAPLAN,
Defendant.
AFFIDAVIT OF CONSENT
1. A complaint in divorce under S 3301(c) ofthe Divorce Code was filed on
December 19,2001.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days
have elapsed from the date of filing and service ofthe Complaint.
3. I consent to the entry of a fmal decree of divorce after service of notice of
intention to request entry of the decree.
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. S 4904 relating to unsworn
falsification to authorities.
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
GLENN J. CAPLAN,
Plaintiff,
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No. 2001 - 7100
vs.
BEVERLY L. CAPLAN,
Defendant.
CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
I. A complaint in divorce under 9 3301(c) of the Divorce Code was filed on
December 19,2001.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days
have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a fmal decree of divorce after service of notice of
intention to request entry of the decree.
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. 94904 relating to unsworn
falsification to authorities.
DATED: tf./afe/n J.-
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Pennsylvania
GLENN J. CAPLAN,
Plaintiff,
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No. 2001 - 7100
CIVIL TERM
IN DIVORCE
vs.
BEVERLY L. CAPLAN,
Defendant.
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF
A DIVORCE DECREE UNDER 6 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a [mal decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if! 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. S 4904 relating to unsworn
falsification to authorities.
Date: '-\--l... ~~o L-
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
GLENN J. CAPLAN,
Plaintiff,
)
)
)
)
)
)
No. 2001-7100
CIVIL TERM
IN DIVORCE
vs.
BEVERLY L. CAPLAN,
Defendant.
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF
A DIVORCE DECREE UNDER 6 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! 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. 9 4904 relating to unsworn
falsification to authorities.
Date: (/-11., (01
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