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Home My WebLink About99-01852 ,~.:. .:.:. ) .=-;. ~ .~ .:<<. -=+:. .:.:. .~+:. .:+:- -=<<- '11 . ,. . . ...... . - --_._--,----_._- . 8 8 8 * 8 ~ ~ ~ .. , ~-~~-~~~*.~*-**-~~~ ..: ------------_.~-,--------.._.,_.._---..........--......_""-.........., ....,......". ~ ~ , ~ 8 ~i <- " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Wl'!r ..' . ,. . ~.., " ". ~,;..p'r PENNA, w " STATE OF ~, ~, 8 8 ,', ~ DANIEL R. KRUPER, Plaintiff, . It) 99 1\ 0, ..1852 $ " ~, \' ('I....;\l,.; w ,., FAHIMA B. KRUPER, 8 Defendant. ,', ~ .'. ~ '.' $ S DECREE IN D I va R C E ots~(DPI1 . .. .1.8.. . .. " 19Lfi., it is ordered and ~l '.' ~ ;.~ ,', ~ ,. ~ ~.~ ~.; ~ AND NOW, . decreed that....... ~~~~~~ .~,. .~li~~~. ... '''''''''''''''', plaintiff, and. . .. . . . .. .. . . . . . . . .1i'./UI.l:~. a... .~U~ER. . . . . .. . .. . . . . .. ..., defendant, are divorced from the bonds of matrimony, s ~ :.~ ,', ~ 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; ~ ..- ~ ~.. Further, the Property Settlement Agreement executed July 27, .......... ................. ......... ............ ...................... ..., ,', ~ ~ ~.~ ~ ~ f."4 ,', ~ ...1999.is,incorpoxated.in.this.Decree.by.~eference.and.~he.... parties are ordered to comply with it. p. ~ ~ ~ ~ ~ :>. ,...;. .~ .:to;- -:+ Prothonotary ~ ~ '.' ~ ~ '7 ,', ~ 8 ,', ~ ,; 8 ,', ~ 8 w ~.. S ~ ~~ 8 ; ~ ~ $ ~ $ 8 $ 8 ~ ~ s J. ~ ~ ~ ~ -"-"~-"'--------------"""""--"'~~",...-~.- ---''-'''-~'~'-~'-'~''~''~~,~-'-;.:. I~ I~ I'! ----@-~~~-**--**~~~~~~ n , . .', .-) 1;:J ~ Z ". . ~ I N !p Oi IJl " .... ;>::l ~ ;r: ill o "Cl ~ >< en to:! >-3 ~ ~ ~ 1!i gj ! Z >-3 "d ..... PI ,..., ::l rt ,.... ,.." ,.." . ~ :I: .... ~ C :0- Z .... to:! I;"" :.1 . J: ,. '" ~Ol ~~ ~ o ~ ~t'rl ~ ~,.., r:: _ ~ z 8;;iz 0 6\ z <5 en :; ;os ~ 0 o-j ;; ~ S 0 c >... () ~ ~ . :><: :.1 C "d to:! :.1 . < C/l , !;j C "d t>:I :.1 tl ro ,.." ro ::l n. PI ::l rt . ~ ~ () .'. " ., rJZrJH HOCZ <:. :;: H ~"3 I;"" \0 t>:I c: \0:.1 to:! fl'~rJ >-3 ZO .... .....cc o en :0 ZU1rJ>-3 "'0 I co rJZ":I C ,......, ....<><rJ <: ........ 0 0..... 3: :.1 "d3: rJ t>:IO t>:I ZZ Z :O-"Cl .1;"" t>:I :0- Ul .~ .' PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, madc this ~ uuy of ~ I., , , 1999. by and between DANIEL R. KRUPER, hereinaftcr called "Husband". and FAHIMA B, KRUPER, hereinafter called "Wife". WIT N E SSE T H: WHEREAS, Husband and Wife were legally married on October 13, 1979; WHEREAS, two children were born of this marriagc; WHEREAS, diffcrences have arisen between Husband and Wife in consequence of which they desire to live separate and apart from each other; and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations. NOW THEREFORE, in consideration of the premises and covenants contained herein, it is agreed by and between the parties hereto that: I. Seoaration - It shall be lawful for each party at all times hereafter to live separate and apart from each other at such place as he or she from time to time shall choose or deem fit. The foregoing provision shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of the causes leading to their living apart, 2. Interferences - Each party shall be free from interference, authority and control by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest or allempt .' .' . to endeavor to molest the other, or in any way harass or malign the other, nor in any other way interfere with the peaceful existence, separate and apart from the other, Each of the parties hereto completely understand and agree that neither shall do or say anything to the child of the parties at any time which might in any way inOuence the child adversely against the other party. 3, Division of Real Property. (a) Wife agrees to transfer all her right, title and interest in and to the real estate situated at 930 Emily Drive, Mechanicsburg, Pennsylvania, pow titled in the name of Husband and Wife and agrees to execute any and all deeds, documents or papers necessary to effect such transfer of title upon request. Wife further acknowledges that she has no claim, right, interest, or title whatsoever in said property and further agrees never to assert any claim to said property in the future. Husband agrees to indemnify and hold Wife harmless on the existing mortgage on the real estate, (b) Husband agrees to pay Wife $20,000,00 for her interest in the marital home as follows: $10,000.00 at the time the divorce becomes final and the remaining $10,000,00 to be paid within eighteen (18) months after the divorce is final. 4. Division of Personal Property - The parties have divided to their mutual satisfaction and in accordance with Exhibit "A" attached hereto, all personal property owned by them during the marriage including, but not limited to, household goods and furnishings, personal effects and other property used by them in common and neither party will make any claim to any of the personal property presently in the possession of the other. Should it become necessary at any time for either party to execute any titles, deeds or similar docu- - 2 - .' ments to givc effect to this paragraph, it shall be done immediatcly upon request of thc other party. 5. Vehiclc - The partics agrcc that the Husband will rctain the 1985 Mercury Cougar and thc 1989 Jeep Chcroke and they will become his sole rcsponsibility. The parties agrec that the Wifc will retain the 1989 Chevy Beretta and it will bccome hcr sole responsi- bility, 6, Pension Plan - Wife agrecs to rclinquish all rights, titlc, and intercst she may have in any of Daniel R. Krupcr's PC!1sion(s) or 401(k)'s or in any othcr monies Daniel R. Kruper is or may bc entitlcd to receivc now or in thc futurc. Husband agrees to relinquish any and all rights, title or intercst he may have in any pcnsions or other monies that Faye B. Kruper may be entitled to now or in the future. 7. Medical Insurance - Husband shall provide medical insurance and extended benefits as supplied by his employer for his minor children. 8. Spousal Support - Each party hereby agrees not to claim or demand any support for himself or herself, alimony pendente lite, permanent alimony, counsel fees or expenses from the other party, 9, Federal/State Income Tax - The parties have agreed that the Husband shall claim the children as dependents on all future income tax returns, 10. 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. The party breaching this contract shall be responsible for the payment of legal fees and costs incurred by the other in enforcing his or her rights under this Agreement, or seeking such - 3 - . .' .. other remedy or relief as may be available to him or her, II. Full Disclosure - Husband and Wife each represent and warrant to the other that he or she has made a full and complete disclosure to the othcr of 0111 assets of any nature whatsoever in which such party of every type whatsoevcr and all other facts relating to the subject matter of this Agreement. 12. Additional Instrument - Each of the parties shall on demand execute and deliver to the other any deeds, bills of sale, assignment, consents to change of beneficiary on insurance policies, tax returns and other documents and do or caused to be done any other act or thing that may be necessary or desirable to the provisions and purposes of this Agreement. If either party fails on demand to comply with this provision, that party shall pay to the other all attorneys' fees, costs and other expenses reasonably incurred as a result of such failure. 13. Wife's Debts - Wife represents and warrants to Husband that since the parties' separation she has not and in the future she will not contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save Husband harmless from any and all claims or demands made against him by reason of debts or obligations incurred by her. 14, Husband's Debts - Husband represents and warrants to Wife that since the parties' separation he has not and in the future he will not contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save Wife harmless from any and all claims or demands made against her by reason of debts or obligations incurred by him, 15. Waivers of Claims Against Estates - Except as herein otherwise provided, '- 4 - " . 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, curtesy, 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, to 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. Reoresentation - It is recognized by the parties hereto that the Husband is represented by Ira H. Weinstock, Esquire, It is fully understood and agreed that each party has the right to have advice of independent counsel prior to the signing of this Agreement. By the signing of this Agreement, the parties recognize that he/she fully understands the legal impact of this Agreement and waives his/her right to have the Agreement reviewed by an attorney of his/her choosing, and further intends to be legally bound by the terms of this Agreement. 17. Effective Agreement - This Agreement shall bind the parties, their heirs, executors, administrators and assigns, 18. V oluntarv Execution - The provisions of this Agreement are fully understood by both parties and each party acknowledges that this 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. - 5 - 19. Entirc Allrccment - This Agrcemcnt contains thc entire undcrstanding of the partics and thcrc arc no rcprescntations, warrantics, covcnants or undertakings other than those expressly sct forth hcrcin, 20, Prior Allrccment - It is understood and agrecd that any and all propcrty selllement agreements which mayor have been executed prior to the date and time of this Agreement are null and void and of no effect. 21, Modification and Waiver - Any modification or waiver of any provision of this Agreement shall be effective only if made in writing and executed with the same formality 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. 22, Governing Law - This Agreement shall be governed by and shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 23, Indeoendent Seoarate Covenants - It is specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 24, Void Clauses - If any term, condition, clause or provision of this Agree- ment 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, 25, Entrv as Part of Decree - It is the intention of the parties that this Agreement shall survive any action for divorce which may be instituted or prosecuted by - 6 - .' COMMONWEALTH OF PENNSYLVANIA ) ) ss: COUNTY OF PCH4.t""" \ ) On this, the ,;n'" day of _+L~ ,1999, before me, a Notary Public, personally appeared Daniel R. Kruper, kno...:n to me to be the person whose name is subscribed to the within Property Settlement Agreement and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~(ld. 6- luifflV.A) - Notary Public COMMONWEALTH OF PENNSYLVANIA) ) ss: COUNTY OF J)~0f";n ) NOTARIAL SEAL I LINDA WITMER, Notary Public , . H~rrisburg, Dauphin County, PA '.' Commission Expires: 03-20..2000 ,,",-iI, . I. b On thIS, the~ day of ,lULL,. ,1999, efore me, a J J Notary Public, personally appeared Fahima B. Kruper, known to me to be the person whose name is subscribed to the within Property Settlement Agreement and acknowledged that she executed the same for the purposes therein contained, IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~ . .. 'flcl(L. (ULt7'YlUc.J - Notary Public - 8 - NOTARIAL SEAL LINDA WITMER, Notary Publlo Harrisburg, Dauphin County, PA . t,~" f;ommlsslon expires: 03.20..2000 I. (;' ~I K ."J .....r'--) (- J' r-.:' p,: 5j~:, 1:. t,:: i..jl f II .- o ~: u t1.. N ~ ,") ~ \~ ......... ....... -4 - .p ~ 'YI ~ ~ 'X"o., i " ...0 ...., ~ ...... ,... Z' ~ ~ ~d ~ ,. f~. (.; ( \~ ... ::0 > I !~ ; .SlI~RS;~i ~ ~~S~~ ~ ~ SOl: 8l ~.... 0 "i:j ~ IV . :-0 9 r n ;; 0 ::c ~?~1 ~ ... ;:. ~ z ... s: t'l ...' >'J tXf t"' ... t'l::c ..... ~ ~t'l ~ , '" !;j , ..... zrl ..... :><: ...' 00 :z c <: '" o c '" =' n~ t'l !II C 0 '" , '" 0 ..... . !:'l I co ~ 0 ..... Z"<l (1) '" . =' >'J '" .." ><rl n (1) ... . 0 t'l =' III 0 'tl~ .... .... Q. =' <: III ..... 0 t'l0 =' ZZ ..... .... 11 Z .." 0 . .." (1) ;:.'" . t"' . ~ tIl - " < - DANIEL R, KRUPER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. Plaintiff, vs, No, Cjf - /R{;~ ~ FAHIMA 8, KRUPER, Defendant. CIVIL ACTION - IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to dcfend against the claims set forth in the following pages, you must takc prompt action, You are warned that if you fail to do so, the case may proceed without you and a decrec of divorce or annulment may be entcred against you by the Court. A judgment may also bc entcred 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 rcqucst marriage counseling, A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, I Courthouse Square, Carlislc, Pcnnsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNUL- MENT 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, PA 17013 Phonc: 717-249-3166 , ~ Z r.:I ril U p. ~ .....0 ...,... :> ><:>H .,.,.jC' ZU D I ON U<nZ COO Q.....H Z ., ::51~ p:;ao rilao...:l p:j H :;: ,> DOH UZU to' to ....... ..,~ . ~ ril p. D p:; :><: "'" "'" ..... .j.J r: ..... III ..... P. N :l ~ u "'s II 0 ~~ U L.. V').J ;: ......8",. .. CI) _ z 'Z ~ 3~~~ j~'n;~ ;> 8" . '" ~ :r: ~ <l: J: e::: ...... .j.J r: III 't:l r: Q) .... Q) . Q p:; r.:I p. D ~ :><: u ~ ., Z r.:I tIl :z: o U i:&. o ., H ~ H r.. r.. 1<1: 1Il :> , ~ H r.:I H Z 1<1: Q o:l ~ H :I: ~ >- ,r: ...~ lU~": l._l ~. 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