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Home My WebLink About99-00301 possession or control of the other. Husband has received sufficient funds to pay all of the capital gains tax due to the IRS In connection with the sale of this property, and he shall be solely responsible for payment of such capital gains taxes. Husband shall indemnify and hold wife harmless for the capital gains tax obligation to the IRS reletlve to the sale of this real estate. ii. 17 Ashburg Drive, Mechanicsburg, Pennsylvania. Wife purchased this property in her name alone on May 14,1999, using funds from the sale of the Stone Harbor, N.J. residence. Husband hereby releases any right, title or interest he may have in 17 AShburg Drive, Mechanicsburg, Pennsylvania, and he agrees that wife is the sole owner of this real estate. B. WAIVER OF RETIREMENT BENEFITS: Each party shall waive any and all retirement benefits which have accrued to the other party. C. WAIVER OF OTHER FINANCIAL INTERESTS: Wife waives any interest she may have in husband's KnowledgeSoft options, the Lain and Anderson partnership and the GRLlC options. D. INTANGIBLE PERSONAL PROPERTY: Husband shall become the sole owner of the parties' mutual funds totaling approximately $19,000.00, including the (two) Evergreen Funds, PSI Net Fund, the Delaware Trend Fund and the Massachusetts Investment Fund; provided, however, that husband shall retain these funds for the education of the children as set forth in paragraph 22.D. below. Wife shall release her ownership interest In these funds to Husband, and Husband shall be permitted to invest 5 1\(<" '. /~ 7!lA obligation to pay alimony shall terminate after the payment husband makes in August, 2000, The parties agree that the provision for alimony herein is not modifiable, regardless of wife's re-employment, remarriage or cohabitation, except that husband's obligation to pay alimony shall terminate in the event of wife's death, The payment of alimony shall be enforced pursuant to 23 Pa,CSA section 3703, In addition to the above, husband shall pay for health insurance coverage for wife until August, 2001, llnd husband shall pay, until August, 2001, any unreimbursed medical , ! ~xpense of wife for any necessary medical treatment, including eye care, prescription medicines and dental bills; orthodontia and cosmetic type surgery excluded, 22. PROVISIONS AS TO CHILDREN A CHILD SUPPORT Hus~and shall pay wife child support through a wage attachment from the Cumberland County domestic relations section or any other domestic relations section where wife may reside, in the amount of $1,200,00 per month, ($600,00 per child per month), which shall be paid at $600 on thE> 7th of each month and the remaining $600 on the 22nd of each month, Husband's obligation to pay shall child support shall remain in the amount set forth above without modification until August, 2001, at which time either party may choose to have the child support recalculated by a court of competent jurisdiction using current income information from the parties, Husband and wife agree to share equally in the cost of any child care needed for the children pending any modification in the amount of child support owed in this case according to Pennsylvania law, Husband's portion of the child care costs shall be paid to 11 )"J\C).:~",. . -"--,\,-' c")HA wife no later than twenty-four hours prior to the tuition due date, In addition to the obligations set forth above, Husband shall pay the mutually acceptable costs of both children's extracurricular activities, including activity fees and costs of equipment, uniforms, lessons and musical instruments, until the children are emancipated, 8, MEDICAL EXPENSES: Husband shall be responsible to provide health insurance coverage for the children until their emancipation, In addition, husband shall pay all unreimbursed medical expenses, Husband shall be solely responsible to pay for all medical, eye care, dental and orthodontia expenses and costs of prescriptions, to the extent any of these bills are not covered by a health insurance plan, C, LIFE INSURANCE: Husband agrees to maintain life insurance on himself for the benefit of the children, in the amount of $390,000,00, with wife named as beneficiary of that polley, Husband shall also maintain the life insurance policies Insuring the lives of wife and children, which coverage is currently through Nationwide Insurance, in the amount of $90,000,00 until the children are emancipated, Husband shall furnish wife proof of the maintenance of such life insurance coverage each quarter of each year, Husband shall keep a disability insurance policy in effect on himself with benefits payable to husband in an amount no less than $90,000,00 per year until both children are emancipated, D, POST-SECONDARY EDUCATION: Husband agrees to pay the costs of any post-secondary education of the children, including tuition, room, board, books and 12 ry~~-"y.- (r;:-: TVI is' IV' - S) \,- c,o \'-~ \'-~ ~ ,,,,'<- ~.." 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M o t, <( ;; <, > ,: '" z z ~ '-~ " ;;i ,,. u ,~ t 1 ., ~J 8, Plaintiff avers that the marriage between the parties Is irretrievably broken, 9, The Plaintiff has been advised of the availability of counseling and that she may have the right to request that the court require the parties to participate in counseling, WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree in divorce, COUNT II-DIVORCE: ADULTERY 10, Plaintiff hereby incorporates by reference paragraphs 1 through 9 above, 11, The Plaintiff a!leges that in violation of his marriage vows, the Defendant has committed adultery, 12, This action in divorce is not conclusive, WHEREFORE, Plaintiff prays your Honorable Court to enter a decree in divorce, COUNT III -EQUITABLE DISTRIBUTION 13, Plaintiff hereby incorporates by reference paragraphs 1 through 12 above, 14, The parties have acquired real and personal property, including automobiles, bank accounts ar'ld other items of miscellaneous property during the course of their marriage, some of which is marital property, WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree which effects an equitable distribution of mantal property, '," C'l i:',~ r.r;; ...:.1 .~~ .. :;~; CI - ",).,'~ ~Jll~:> - (;,h. ~l"!." 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