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IN THE COURT OF COMMON PLEAS
OFCUMBERLAND COUNTY
SNI
STATE OF PENNA.
' M1' 4
PATRICIA MUSKEY MERTLE,
Plaintiff I No. 99-5514
VERSUS
MICHAEL J. MERTLE,
Defendant 11
DECREE IN
DIVORCE
? J ?:3aA•?•
AND NOW, 1 200 ..r
IT IS ORDERED AND
DECREED THAT PATRICIA MUSKEY MERTLE
MICHAEL J. MERTLE
AND
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
PLAINTIFF,
, DEFENDANT,
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;
All claims have been resolved pursuant to the Marital Settlement
Agreement dated November 7, 2000 which shall be incorporated but
not merged into this Divorce Decree.
BY THE U
ATTEST: J.
1
ROTHONOTARY
In The Court Of Common Pleas
Of Cumberland County, Pennsylvania
Plaintiff Docket No. 99-5514
Patricia Muskey Mertle In Divorce
V.
Defendant
Michael J. Mertle
COURT ORDER AGCEPTAar F FOR PROCESSING
AND NOW, this I day of 3&^%4V 200 based on the findings
set forth below in items one through five,
IT IS HEREBY ORDERED, ADJUDGED AND DECREED
In items six through eighteen:
1. Parties: The parties hereto were husband and wife, and a divorce action is in
this Court at the above number. This Court has personal jurisdiction over the parties. The
parties were married on February 17, 1984.
2. Effect of This Order as a Court Order Acceptable for Processing: This
Order creates and recognizes the existence of a former spouse's right to receive a portion
of the employee's benefits payable under the Civil Service Retirement System
("CSRS"). Such benefits may represent a portion of the Employee Annuity, a Refund of
Employee Contributions or may award a Former Spouse Survivor Annuity to the former
spouse. It is intended to constitute a Court Order Acceptable for Processing under final
regulations issued by the Office of Personnel Management ("OPM"). The provisions of
this court order are drafted in accordance with the terminology used in Part 838 of Title 5,
Code of Federal Regulations. The terminology used in the provisions of this order that
concern benefits under the Civil Service Retirement System are governed by the standard
conventions established in that part.
3. Employee Information: The name, last known address, social security
number, and date of birth of the "Employee" are:
Name: Michael J. Mertle ("Employee")
CSRS (GOAP)
Address: 811 Brian Drive, #103, Enola, Pennsylvania 17025
Social Security Number: #196-36-8640
Birth Date: October 31, 1948
4. Former Spouse Information: The name, last known address, social security
number, and date of,birth of the "Fortner Spouse" are:
Name: Patricia Muskey Mertle ("Former Spouse")
Address: 8 Pamela Place, Mechanicsburg, Pennsylvania 17055
Social Security Number: #178-36-1046
Birth Date: January 4, 1947
The Former Spouse shall have the duty to notify the OPM in writing of any changes in her
mailing address subsequent to the entry of this Order.
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5. Identification of Retirement System: The Employee will be eligible for
retirement benefits under the Civil Service Retirement System based on employment with
the United States Government.
6. Pursuant to State Domestic Relations Law: This Order is entered
pursuant to the authority granted in the applicable domestic relations laws of Pennsylvania.
7. For Provision of Marital Property Rights: This Order relates to the provision
of marital property rights of the Former Spouse as a result of the Order of Divorce between
the Employee and Former Spouse issued on .
8. Providing for Payments to Former Spouse: The Former Spouse is entitled
to a portion of the Employee's Gross Monthly Annuity under the Civil Service Retirement
System as set forth below. The United States Office of Personnel Management is hereby
directed to pay Former Spouse's share directly to Former Spouse.
9. Amount of Former Spouse's Benefit: This Order assigns to Former Spouse
an amount equal to Thirty-Two and Twenty-Five One-Hundredths Percent (32.25%) of the
Marital Portion of the Employee's Gross Monthly Annuity determined as of the
Employee's date of retirement. For purposes of calculating Former Spouse's share of
DRAFTED: 11/27/00
I- ;jy
CMS- (00AP) -- --- ----- PAGE 3
Employee's benefit, the Marital Portion shall be determined by multiplying the Employee's
Gross Monthly Annuity by a fraction (less than 1.0), the numerator of which is the total
number of months of Creditable Service earned under the CSRS during the marriage
(from February 17, 1984 to March 29, 1998), and the denominator of which Is the total
number of months of the Employee's Creditable Service accrued under the Civil Service
Retirement System (including military service credited to the CSRS should the Employee
opt out of receiving his military retainer pay). The marriage began on February 17, 1984.
Further, any salary adjustments that occur after March 29, 1998 shall be incorporated into
the calculation of Former Spouse's share of the Employee Annuity.
10. Cost of Living Adjustments: When Cost of Living Adjustments are applied
to Employee's retirement benefits, the same Cost of Living Adjustment shall apply to the
Former Spouse's share.
11. Benefit Commencement Date: The Former Spouse shall commence her
benefits as soon as administratively feasible following the date this Order is approved as a
Court Order Acceptable for Processing, or on the date the Employee commences his
benefits, 'd later. Payments shall continue to Former Spouse for the remainder of
Employee's life-time; however, should Former Spouse predecease the Employee, then
such benefits shall be paid tc the estate of the Former Spouse.
The Employee agrees to arrange or to execute all forms necessary for the OPM to
commence payments to the Former Spouse in accordance with the terns of this Order.
12. Refund of Employee Contributions: If Employee leaves Federal service
before retirement and applies for a refund of employee contributions under the CSRS,
Former Spouse shall be entitled to a prorata share of the refund of such employee
contributions.
13. Former Spouse Survivor Annuity: Pursuant to Section 8341(h)(1) of Title 5,
United States Code, Former Spouse shall be awarded a former spouse survivor annuity
under the Civil Service Retirement System based upon a base amount of at least Thirteen
Thousand Six Hundred Dollars (S 13,600.00). Therefore, the Former Spouse shall be
entitled to a former spouse survivor annuity in the amount of at least the annual base
payment of Seven Thousand Four Hundred Eighty Dollars ($7,480.00) per year.
DRAFTED: 11/27/00
, CSRS (COAP)
4
Employee agrees to take all necessary steps to elect Former Spouse as the
designated beneficiary for purposes of establishing and sustaining such surviving spouse
coverage for Former Spouse.
14. Cost of Former Spouse Survivor Annuity: Both the Employee's arwuity
and the Former Spouse's share of the Employee's annuity will be reduced, in equal shares,
by the amount of the costs associated with providing the Former Spouse with a former
spouse survivor annuity as awarded in paragraph 13.
15. Transfer to FERS: In the event that Employee makes a one-time irrevocable
election to transfer into the Federal Employees Retirement Systems ("FERS") before his
retirement, then Former Spouse shall be entitled to a portion of the Employee's Basic
Annuity and/or a Refund of Employee Contributions under FERS calculated in a manner
similar to that which is enumerated in Sections 9 and 12 above for the CSRS annuity and
refund, respectively, and payable directly from FERS. Additionally, Former Spouse shall
be entitled to a Former Spouse Survivor Annuity payable under FERS and determined in
a similar manner to the survivor benefits set forth under Section 13 above. Further, such
Former Spouse Survivor Annuity shall be payable from FERS.
16. Savings Clause: This Order is not intended, and shall not be construed in
such a manner as to require the OPM:
(a) to pay a former spouse a portion of an employee annuity before
the employee annuity begins to accrue;
(b) to pay a former spouse any amounts that are in excess of an employee's
net annuity; or
(c) to pay a Former Spouse Survivor Annuity in excess of the maximum
permitted amounts under the CSRS and the FERS.
17. Constructive Receipt: In the event that the CSRS inadvertently pays to the
Employee any benefits that are assigned to the Former Spouse pursuant to the terms of
this Order, the Employee shall immediately reimburse the Former Spouse to the extent
DRAFTED: 11/27/00
CSRS (COAP) PAGE 5
that he/she has received such benefit payments, and shall forthwith pay such amounts so
received directly to the Former Spouse within ten (10) days of receipt.
18. Continued Jurisdiction: The Court shall retain jurisdiction with respect to this
Order to the extent required to maintain its status as a Court Order Acceptable for
Processing and the original intent of the parties as stipulated herein. =
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BY THE COURT:
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DRAFTED: 11/27/00
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THIS AGREEMENT, made this 7day of 2". LZ - 2000, by and
between MICHAEL J. MERTLE, hereinafter referred to as "HUSBAND", and PATRICIA M.
MERTLE, hereinafter referred to as "WIFE".
WITNESSETH, That:
WHEREAS, the parties hereto are husband and wife, having been lawfully joined in
marriage on February 17, 1984, in Coatesville, Pennsylvania;
WHEREAS, the parties adopted one (1) child during this marriage, namely Karen
Elizabeth Mary Mertle, born August 11, 1989;
WHEREAS, it is the intention of the parties to settle fully and finally their respective
financial and property rights and obligations as between each other arising out of the marriage
relationship or otherwise, including without limitation (1) the settling of all matters between
them relating to the ownership of real and personal property; (2) the settling of all matters
between them relating to the past, present and future support and/or maintenance of HUSBAND
and WIFE; (3) the settling of all matters between them relating to the past, present and future
support or maintenance of their minor child, and (4) the settling of all matters between them
relating to any and all rights, titles and interests, claims and possible claims in or against the
estate of the other.
NOW THEREFORE, with the foregoing recitals being hereinafter incorporated by
reference and deemed an essential part hereof in consideration of the foregoing recitals, the
mutual promises, covenants and undertakings herein set forth, and for good and valuable
consideration, receipt of which is hereby acknowledged by each of the parties hereto,
HUSBAND and WIFE, each intending to be legally bound hereby, covenant and agree as
follows:
1. ADVICE OF COUNSEI
HUSBAND and WIFE declare that they have each had a full and fair opportunity to
obtain independent legal advice of counsel of their selection. PATRICIA M. MERTLE has been
independently represented by Barbara Sumple-Sullivan, Esquire. MICHAEL J. MERTLE is
cognizant of his right to legal representation and declares that he has been independently
represented by Philip H. Spare, Esquire. Each party further declares that they are executing this
Agreement freely and voluntarily, having obtained such knowledge and disclosure of there legal
rights and obligations and that they acknowledge that this Agreement is fair and equitable and is
not the result of any fraud, coercion, duress, undue influence or collusion.
2. PERSONAL RIGHTS
HUSBAND and WIFE may and shall, at all times hereafter, live separate and apart. Each
shall be free from all control, restraint, interference or authority, direct or indirect, by the other in
all respects as if she or he were unmarried, except as may be necessary to carry out the
provisions of this Agreement. Each may reside at such place or places as she or he may select. %
Each may, for his or her separate use or benefit, conduct, carry on and engage in any business,
occupation, profession or employment which to him or her may seem advisable. This provision g
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shall not be taken, however, to be an admission on the part of either HUSBAND or WIFE of the
lawfulness of the causes which led to, or resulted in, the continuation of their living apart.
HUSBAND and WIFE shall not molest, harass, or malign the other or the respective families of
each other, nor compel the other to cohabit or dwell in any manner with him or her, nor in any
way interfere with the peaceful existence, separate from each other.
3. DEBTS
Each party represents that they have not contracted any debt or liability for the other for
which the estate of the other party may be responsible or liable except as otherwise provided
herein, and that except only for the rights arising out of this Agreement, neither party will
hereafter incur any liability whatsoever for which the other party or the estate of the other party
will be liable. Each party agrees to indemnify and hold harmless from and against all future
obligations of every kind incurred by them, including those for necessities. The parties
acknowledge that the marital debts are as follows:
1) Key Equity Loan 13 - Approximate balance is $13,300 (Account 12251-Joint)
2) Key Equity Loan 14 - Approximate balance is $13,000 (Account 12251-Joint)
3) PSL Loan - (Account 12251 - Joint)
4) PSL Loan - (Account 24883 - Joint)
5) VISA credit card - Husband
6) VISA credit card - Wife
7) Second Mortgage - Joint - Paid off after separation by Wife
8) Cost of the Refinancing in June of 1998 - included in mortgage identified in
paragraph 6
a. Debts HUSBAND is Liable for. HUSBAND shall be solely liable and responsible
for the following debts:
w
1) Key Equity Loan 13 (Account 12251)
2) PSL Loan - Husband's name (Account 12251)
3) VISA credit card - Husband (Account 12251)
If any of these debts are held jointly with WIFE or constitute a lien against real estate to
be the sole property of WIFE, HUSBAND shall either refinance same to his name alone or
obtain a release of WIFE's liability no later than either the settlement of the sale of the marital
residence or the refinancing of same.
HUSBAND will indemnify and hold WIFE harmless from the non-payment of any debt
he is assuming pursuant to this Agreement. HUSBAND further agrees to be responsible for all
reasonable attorneys' fees incurred by WIFE in defense of any claim or suit brought against her
arising from any debt HUSBAND is assuming pursuant to this Agreement and/or to enforce this
indemnification.
b. Debts WIFE is Liable for. WIFE shall be solely liable and responsible for the
following debts:
1) Key Equity Loan No. 14 (Account 12251)
2) PSL Loan - Wife's name (Account 24883)
3) VISA credit card -Wife
If any of these debts are held jointly with HUSBAND or a lien on any separately titled
property owned by HUSBAND, WIFE shall either refinance same to her name alone or obtain a
release of HUSBAND's liability no later than either the settlement of the sale of the marital
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residence or the refinancing of same.
WIFE will indemnify and hold HUSBAND harmless from the non-payment of any debt
she is assuming pursuant to this Agreement. WIFE further agrees to be responsible for all
reasonable attorneys' fees incurred by HUSBAND in defense of any claim or suit brought
against him arising from any debt WIFE is assuming pursuant to this Agreement and/or to
enforce this indemnification.
4. WAIVER OF APPRAISAL AND INVENTORY
The parties acknowledge and agree that they have each had an opportunity to value or
have appraised any and all marital property, and they do hereby waive a formal appraisal and
inventory of same, and no statement or representation by either party as to value shall be deemed
a misstatement or misrepresentation to the other or be deemed fraudulent.
5. MARITAL. AND NON-MARITAL ARSM
HUSBAND and WIFE do hereby acknowledge that they have heretofore divided the
non-marital assets and marital assets including but without limitation, jewelry, clothes, furniture,
other assets wherever situated whether real, personal or mixed, tangible or intangible, and
HUSBAND agrees that all assets in the possession of WIFE shall be the sole and separate
property of WIFE; and, WIFE agrees that all assets in the possession of HUSBAND shall be the
sole and separate property of HUSBAND. Each of the parties does hereby specifically waive,
release, renounce and forever abandon whatever claims, if any, he or she may have with respect
to any of the above said items which are the sole and separate property of the other. This
document shall constitute a bill of sale for said sole property,
6. REAL ESTATE 8 PAMELA PLACE
The parties own real property as tenants by the entireties located at 8 Pamela Place,
Mechanicsburg, Pennsylvania which is subject to a mortgage with SunTrust (Crestar), Account
No. 0108201658, The balance of the mortgage as of the parties' separation was SEVENTY
FOUR THOUSAND THREE HUNDRED EIGHTY-FOUR DOLLARS and 87/00 ($74,384.87).
HUSBAND agrees to convey all his rights, title and interest in this real estate to WIFE.
WIFE agrees to assume responsibility for the payment of the unpaid balance of the mortgage, all
taxes, insurance and any other real estate assessments or expense together with any interest, and
hereby agrees to hold HUSBAND harmless from any and all liability incurred by him as a result
of non-payment of the mortgage by her. HUSBAND agrees to execute a deed simultaneously
with the execution of this Agreement wherein he assigns, conveys and transfers to WIFE all of
his interest, right and title in the marital residence.
In order to obtain HUSBAND's release from the mortgage associated with this property,
WIFE shall either list this property for sale at a reasonable price or commence the refinancing of
the mortgage within eighteen (18) months from the execution of this Agreement and move
toward a prompt and reasonable conclusion of the transaction. If WIFE elects to list the real
estate for sale at a reasonable price, HUSBAND, if necessary, shall execute any documents
necessary to facilitate this sale. In the event of sale, WIFE shall be entitled to all of the proceeds
from the sale of this property, WIFE shall solely determine the list price and the eventual sale
price for this real estate provided same is reasonable.
If, at the time of refinancing of the mortgage, the lender requires that a debt assumed by
HUSBAND pursuant to Paragraph 3 of this Agreement be paid, HUSBAND agrees that he shall
satisfy said debt prior to settlement.
WIFE shall have exclusive possession of the real estate to the exclusion of HUSBAND.
Any unauthorized entry to said property by HUSBAND shall be in violation of this Agreement.
7. REAL ESTATE - I AKE LOT
The parties own property as tenants by the entireties an unimproved lot located at Map
No. 08-39-2223-008, 0000 Pine Grove Road, Dickinson Township, Pennsylvania. There is no
mortgage associated with this property. HUSBAND agrees to convey his interest in this real
estate to WIFE. WIFE agrees to assume responsibility for the payment of any taxes, insurance,
assessments or other expenses associated with this property and hereby agrees to hold
HUSBAND harmless from any and all liability as a result of non-payment of the same by her.
HUSBAND agrees to execute a deed simultaneously with the execution of this Agreement
wherein he assigns, conveys and transfers to WIFE all of his interest, right and title in said real
estate.
g, REAL ESTATE - HUSBAND's CONDOMINIUM
HUSBAND owns a condominium located at 811 Brian Drive, #103, Enola, Pennsylvania
17025. Said property was purchased by HUSBAND individually, after the parties' separation.
HUSBAND warrants that the mortgage for said property is in his name alone, and hereby agrees
to hold WIFE harmless from any and all liability associated with this property as a result of non-
payment by HUSBAND.
9. MOTOR VEHICLES
WIFE shall have sole title and ownership of the parties' Buick Skylark. After separation,
WIFE traded in her vehicle and all proceeds realized on the transfer of the Skylark shall be the
sole property of WIFE. HUSBAND waives any claim to WIFE's subsequently titled 1991
Toyota Tercel. HUSBAND shall have sole title and ownership of the parties' Chevrolet Wagon.
These vehicles are not encumbered. After separation, HUSBAND traded in his Chevrolet truck
and all proceeds realized on said transfer shall be the sole property of HUSBAND.
10. PENSION - WIFE'S .MPI OYMF.NT F.TIR_F.MENT BENEFITS
As a result of WIFE's employment with the federal government, she is entitled to
numerous employment benefits. HUSBAND hereby waives any and all claims that he has
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against WIFE to any pension, employee saving or other stock benefit program, if applicable, or
any other employment related benefit including but not limited to her Thrift Savings Plan (TSP)
and any benefits she may be entitled to under the Civil Service Retirement System or CSRS.
11. PENSION - HCI4BAND'C FMPi OYD'FNT/RFTIRFb Fp?T HF11 FFITS
a. Thrift Savings Plan and Other Employment Benefits. As a result of HUSBAND's
employment with the federal government, he is entitled to numerous employment benefits.
Except as provided in the following paragraph concerning HUSBAND'S CSRS benefits, WIFE
hereby waives any and all claims that she has against HUSBAND to any other pension,
employee saving or other stock benefit program or any other employment benefit, if applicable,
including his Thrift Savings Plan (TSP).
b. Civil Service Retirement System (or CSRS) Benefits. The parties acknowledge that
the marital estate includes HUSBAND's pension interest under CSRS. The parties agree that
WIFE shall be entitled to 32.25% of the marital portion of this benefit as determined by the
following fraction:
The numerator of this fraction is the number of months of HUSBAND's
participation in the Plan earned during the parties' marriage and the denominator
is the total number of months of HUSBAND's participation in the Plan through
the date of his retirement.
Said share shall also include any increase due to a cost of living increase or other interest
granted by the Plan and not be reduced by any other costs or elections made by HUSBAND.
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WIFE's interest shall be transferred to WIFE through the vehicle of a Qualified Domestic
Relations Order, the provisions of which shall include the following:
1. WIFE shall be entitled to the aforementioned pension benefit based upon
HUSBAND's election of a survivor annuity. HUSBAND can elect less than the
maximum survivor annuity but shall be obligated to provide an election to result
in WIFE's receipt of an annual survivor annuity not less than SEVEN
THOUSAND FOUR HUNDRED EIGHT DOLLARS ($7,480.00) per year. By
example, HUSBAND can elect a less than maximum annuity of not less than
THIRTEEN THOUSAND SIX HUNDRED DOLLARS ($13,600.00). Under the
current plan regulations, this will result in a fifty-five percent (55%) payment to
WIFE, resulting in the annual base payment of SEVEN THOUSAND FOUR
HUNDRED EIGHT DOLLARS ($7,480.00).
2. The actual benefit shall be determined to be the earliest to occur of the following:
a, The participant's separation from service; or
b. The participant's death.
3. If HUSBAND elects early retirement and if there is an early retirement incentive
beyond what is presently available under the plan, the alternate payee shall be
entitled her proportionate share as defined in Paragraph I I b. of any early
retirement incentive that may become available.
4. If the plan provides for a cost of living increase or any other post-retirement
benefit increase, the alternate payee will receive her proportionate share as
defined in Paragraph I 1 b. of such increase. This increase shall apply also to the
survivor annuity specified in paragraph 1. above.
5. WIFE, as alternate payee, shall be entitled to her proportionate share as defined in
Paragraph 1 I b. of any pre-retirement pension benefit which may result from the
death, before retirement of HUSBAND, of the plan participant.
6. In the event of WIFE's death prior to HUSBAND's retirement or during
HUSBAND's retirement, WIFE's named beneficiary or in the absence thereof,
her estate, shall be entitled to her payments as alternate payee.
7. If HUSBAND leaves federal service prior to retirement and applies for a refund
of employee contributions from the Office of Personal Management. WIFE shall
be entitled to her proportionate share as defined in Paragraph I I b. of said
refunds as calculated by CSRS.
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8. WIFE shall be entitled to any and all benefits through the plan's Former Spouse
Survivor Annuity based upon HUSBAND's election of a survivor annuity as set
forth in subparagraph 1 above. WIFE's proportionate interest shall supercede the
right of any future spouse's survivor annuity, HUSBAND's options for future
spouse are not limited except to the extent they may adversely effect WIFE's
interests granted herein or by the QDRO.
9. The parties shall equally share the cost of the preparation of the Qualified
Domestic Relations Order necessary to allocate WIFE's monthly benefit under
this paragraph and any other costs necessary to effectuate :he terms of Paragraph
I lb.
12. BANK ACCOUNTS AND 1NV1FRTM1F.NTS
Each party shall have sole possession of the bank accounts and investments in their own
names.
13. INSURANCIF,
Each party shall retain ownership of any life insurance policy in his or her name.
HUSBAND agrees to name WIFE as irrevocable beneficiary of his life insurance policy through
his employment for as long as he has an obligation to pay alimony pursuant to Paragraph 16 of
this Agreement. In the event his employment terminates, he shall be required to secure a life
insurance policy in the amount of ONE HUNDRED THOUSAND DOLLARS ($100,000.00)
until the alimony obligation ceases.
14. MUTUAL WAIVER ND RELEASE OF RIGHTS AND AIMS
CONFERRED By THE. PENNSYLVANIA DIVORCE ACT OF 1980, AS
AMENDED
HUSBAND and WIFE acknowledge and agree that the provisions of this Agreement are
fair, adequate and satisfactory to them. Both parties agree to accept the provisions set forth in
this Agreement in lieu of and in full and final settlement and satisfaction of all claims and
demands that either may now or hereafter have against the other for equitable distribution,
alimony, alimony pendente lite, counsel fees, costs and expenses or other provisions for their
support and maintenance before, during and after the commencement of any proceeding for
divorce or annulment between the parties.
15. AFTER ACQUIRED PERSONAL PROPERIYZEUTURE EARNING
Each of the parties shall hereafter own and enjoy independently of any claim or right of
the other, all items of personal property, tangible or intangible, hereafter acquired by HUSBAND
or WIFE, with full power in him or her to dispose of the same as fully and effectively, in all
respects and for all purposes, as though he or she were unmarried.
16. ALIMONY, SUPPORT AND MAINT .NAN
Presently, WIFE is being paid the sum of FIVE HUNDRED FORTY-FIVE DOLLARS
and 53/00 ($545.53) per month as spousal support through the Domestic Relations Section of the
Court, Docket No. 01054 S 1999, PACSES No. 660101805. The parties agree that this spousal
support shall be converted to alimony effective the date of the parties' divorce. This amount in
non-modifiable in amount or term except as provided herein. Said payment shall terminate upon
the first to occur of one of the following events:
(1) Death of Wife or Husband; or
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(2) The receipt by Wife of her first payment, as alternate payee, of the CSRS
retirement benefits as identified in Paragraph I Lb. of this Agreement.
The alimony payments WIFE receives pursuant to this paragraph shall be includable as
income to WIFE and deductible by HUSBAND and includable as income for WIFE for child
support purposes.
17. CUSTODY AND VISITATION
HUSBAND and WIFE shall have shared legal custody of the parties' minor child.
Primary physical custody of the child shall be in WIFE. HUSBAND shall have flexible rights of
physical custody, as the parties can agree.
18.
The parties acknowledge that there is an Order dated October 6, 2000 for child support
wherein HUSBAND was directed to pay the sum of ONE THOUSAND ONE HUNDRED
THIRTY-TWO DOLLARS and 47/100 ($1,132.47) per month for the support of one child. This
Order is filed to the same docket number as the spousal support obligation in paragraph 16.
Either party may seek a review, as appropriate.
19. SUBSEQUENT DIVORCE
A decree in divorce, entered by a court of competent jurisdiction to either party, shall not
suspend, supersede or affect the terms of this Agreement. Both parties agree to enter a Consent
Decree concerning the provisions of this Agreement in the Court of Common Pleas of
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Cumberland County, Pennsylvania, or any other Court of competent jurisdiction, as a part of a
resolution of any divorce action filed. This Agreement, and the terms and conditions contained
herein, as well as the enforcement of said terms and conditions, shall not be contingent upon the
granting of a Divorce Decree to either party by the Court of Common Pleas of Cumberland
County, Pennsylvania, or any other Court of competent jurisdiction. Furthermore, both parties
hereto agree to timely execute the appropriate affidavits and consents to secure a No-Fault
Divorce as may be required by the Divorce Code of 1980, as amended. Both parties hereto agree
that this Agreement may be incorporated for purposes of enforcement into a separate Court
Order but shall not merge in such order in the Court of Common Pleas of Cumberland County,
Pennsylvania.
20. OTHER DOCUMENTATION
HUSBAND and WIFE covenant and agree that upon request of the other party, they will
forthwith execute and deliver to the other party, 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.
21. MUTUAL WAIVER AND RELEASE OF RIGHTS AND CLAIMS IN
ESTATE
Each party hereby releases, waives and relinquishes any and all rights which he or she
may now have, or may hereafter have, against the other party under the present or future laws of
any jurisdiction (a) to share in the estate of the other party upon the other party's death and (b) to
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act as executor/rix or administrator/rix of the other party's estate,
22, MUTUAL RELEASE
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 interests, 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 she or he 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
equitable distribution, dower or curtesy, or claims in the nature of dower or curtesy of 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 (c) any other country, or and rights which HUSBAND or WIFE may have
or at any time hereafter have for the past, present or future support or maintenance, alimony,
alimony pendente lite, counsel fees, 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.
15
Each of the parties hereto further covenants and agrees for himself and herself and his or
her heirs, executors, administrators and assigns, that he or she will never, at any time hereafter,
sue the other party or his or her heirs, executors, administrators and assigns, for the purpose of
enforcing any of the rights relinquished under this paragraph. Each of the parties further
covenants and agrees that he or she will permit any will of the other to be probated and allow
administration upon his or her personal, real or mixed estate and allow effects to be taken out by
the person or persons who would have been entitled to do so had HUSBAND or WIFE died
during the lifetime of the other. Each of the parties hereby releases, relinquishes and waives any
and all right to act as executor or executrix or administrator or administratrix of the other's
estate.
It is the intention of HUSBAND and WIFE to give to each other by the execution of this
Marital Settlement Agreement a full, complete and general release with respect to any and all
property of any kind or 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.
23. C[I( CF. OR'C Ri( HTC AND IABIi IT
This Agreement shall, except as otherwise provided herein, be binding upon and inure to
the benefit of the parties hereto, their respective heirs, executors, administrators, successors or
16
assigns.
24. SEVERARIIITV
If any provision in this Agreement is held by a court of competent jurisdiction to be
invalid, void, or unenforceable, the remaining provisions shall nevertheless continue in full force
and effect without being impaired or invalidated in any way.
25. ENTIRE. A RF M NT
HUSBAND and WIFE do hereby covenant and warrant that this Agreement contains all
of the representations, promises and Agreements made by either of them to the other for the
purposes set forth in the preamble hereinabove; that there are no claims, promises or
representations not herein contained, either oral or written, which shall or may be charged or
enforced or enforceable unless reduced to writing and signed by both of the parties hereto.
26. BINDIN FF T OF A RFFM NTlWAIVFR
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 the provisions of this Agreement shall not be construed as a waiver of any
subsequent default of the same or similar nature, nor shall such failure be construed as a waiver
of any other term, condition, clause or provision of this Agreement.
17
27. 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 or seek such other remedies or
relief as may be available to him or her, and the party breaching this contract shall be responsible
for payment of reasonable legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
28. CONTROIJJN LAW
This Agreement shall be construed and governed in accordance with the laws of the
Commonwealth of Pennsylvania.
29. CONDITION PRF D NT TO TH A EEMENT'C F?FFCTIVFD FCC
The parties acknowledge that this Agreement shall become effective when actually
signed by both parties.
1
MICHAEL . LE
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AT IA M. MERTLE
18
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF / ) SS.
Before me, the undersigned officer, a Notary Public in and for said Commonwealth and
County, personally appeared MICHAEL J. MERTLE, who being duly affirmed according to
law, deposes and says that the facts and matter set forth in the within and foregoing Marital
Settlement Agreement are true and correct to the best of his knowledge, information and belief.
and subscribed to before me this "'?ay o? A;:z Gj000.
My commission expires:
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
LN;Wland PbtaAal Meet
a Borth curi?he71s
asio n Expires No?smer , 2ooa
) SS. Before me, the undersigned officer, a Notary Public in and for said Commonwealth and
County, personally appeared PATRICIA M. MERTLE, who being duly affirmed according to
law, deposes and says that the facts and matter set forth in the within and foregoing Marital
Settlement Agreement are true and correct to the best of her knowledge, information and belief
to before me this 7 day of//%?, 2690
NOTARY PUBLIC
My commission expires: (SEAL)
Barbera Sinpl 3uei war,,
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PATRICIA MUSKEY MERTLE,
Plaintiff
V.
MICHAEL J. MERTLE,
Defendant
To the Prothonotary:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5514
IN DIVORCE
Transmit the record, together with the following information, to the court for entry of a
divorce decree:
1. Ground for divorce: Irretrievable breakdown under §3301(c) of the Divorce Code.
2. Date and manner of service of the complaint: United States Mail, Certified Mail,
Restricted Delivery on September 23, 1999.
3. Date of execution of the affidavit of consent required by § 3301(c) of the Divorce
Code: by Plaintiff. November 7, 2000; by Defendant: November 7, 2000.
4. Related claims pending: All claims have been resolved pursuant to a Marital
Settlement Agreement reached by the parties dated November 7, 2000 and incorporated,
but not merged into the Decree.
5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with Prothonotary:
November 29, 2000. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with
Prothonotary: November 29, 2000.
Dated: Decembera?, 2000
Barbara Sumpie-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070-1931
(717)-774-1445
Supreme Court ID #32317
Attorney for Plaintiff
..
PATRICIA MUSKEY MERTLE,
Plaintiff
V.
MICHAEL J. MERTLE,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5514
IN DIVORCE
I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true
and correct copy of the foregoing Plaintiff's Praecipe to Transmit Record, in the above-
captioned matter upon the following individual by first class mail, postage prepaid, addressed
as follows:
Philip H. Spare, Esquire
44 W. Main Street
Mechanicsburg, PA 17055
DATED: December ?, 2000
Barbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
Supreme Court I.D. No. 32317
Attorney for Plaintiff
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PATRICIA MUSKEY MERTLE, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. qq- 55
MICHAEL J. MERTLE, CIVIL ACTION - LAW
Defendant IN DIVORCE
PLOTICE TO DFFFNn et?n rr . rw,r RTC
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. Ajudgement 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 and visitation of your children.
When the grounds for a divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the Domestic
Relations Office at the County Courthouse.
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
PATRICIA MUSKEY MERTLE, : IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO.
MICHAEL J. MERTLE, : CIVIL ACTION -LAW
Defendant : IN DIVORCE
AFFIDAVIT REGARDING O NS ..IN
.
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 Domestic
Relations Office, which list is available to me upon request.
3. Being so advised, I do not require 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.A
Section 4904 relating to unworn falsification to authorities.
Dated: c ? Ctq
Patricia Muske Mertl
PATRICIA MUSKEY MERTLE, : IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO.
MICHAEL J. MERTLE, CIVIL ACTION -LAW
Defendant : IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Patricia Muskey Mertle, an adult individual residing at 8 Pamela Place,
Mechanicsburg, PA 17055.
2. Defendant is Michael J. Mettle, an adult individual residing at 811 Brian Drive #013,
Enola, PA 17025.
3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six (6) months prior to filing this complaint.
4. The Plaintiff and Defendant were married on February 17, 1984 in Chester County,
Pennsylvania.
5. There is one (1) minor child who was adopted during this marriage being: Karen
Elizabeth Mary Mertle, born August 11, 1989.
6. The parties separated on March 29, 1998.
7. There have been no prior actions for divorce or annulment between the parties.
8. Neither Plaintiff nor Defendant is in the military or naval service of the United States
or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940
and its amendments.
9. Plaintiff has been advised that counseling is available and that Plaintiff has the right
to request that the court require the parties to participate in counseling.
10. The averments in paragraphs 1 through 9, inclusive, of Plaintiffs Complaint are
incorporated herein by reference thereto.
11. The marriage is irretrievably broken and no possibility of reconciliation exists.
WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with
§ 3301 of the Pennsylvania Divorce Code.
12. The averments in paragraphs I through 11, inclusive of Plaintiffs Complaint are
2
incorporated herein by reference thereto.
13. Plaintiff is the innocent and injured party, and Defendant has offered such indignities
to the person of the Plaintiff and has been mentally cruel to her so as to make her life burdensome and
her condition intolerable, in violation of the marriage vows and of the laws of the Commonwealth.
WHEREFORE, Plaintiff requests this Court to enter a decree in divorce in accordance with
the Pennsylvania Divorce Code.
14. The averments in paragraphs 1 through 13 of Plaintiffs Complaint are incorporated
herein by reference thereto.
15. The Plaintiff requests the Court to equitably divide, distribute or assign the marital
property between the parties in such proportion as the Court deems just after consideration of all
relevant factors.
WHEREFORE, Plaintiff requests this Court to equitably divide said property in accordance
with Section 401(d) of the Pennsylvania Divorce Code.
16. The averments in paragraphs 1 through 15, inclusive, of Plaintiffs Complaint are
incorporated herein by reference thereto.
17. Plaintiff requires reasonable support to adequately sustain herself with the standard
of living established during the marriage.
WHEREFORE, Plaintiff requests an award of Support, Alimony and Alimony Pendente Lite.
COUNT IV
AITORNE3CS FEES AND COSTS
18. The averments in paragraphs I through 17, inclusive, of Plaintiffs Complaint are
incorporated herein by reference thereto.
19. Plaintiff is unable to sustain herself during the course of this litigation and has
employed Barbara Sumple-Sullivan, Esquire as counsel, but is unable to pay the necessary and
reasonable attorney's fees for said counsel, and the necessary and reasonable costs and expenses.
WHEREFORE, Plaintiff requests an award of counsel's fees and expenses.
WHEREFORE, Plaintiff, Patricia Muskey Mertle, prays this Honorable Court to enter
judgment:
A. Awarding Plaintiffa decree in divorce;
4
B. Awarding Plaintiff support, alimony and alimony pendente lite;
C. Awarding Plaintiff counsel fees, costs and expenses;
D. Equitably distributing the marital property; and
E. Awarding other relief as the Court deems just and reasonable.
Dated: September 8, 1999
Barbara Sumple-Sullivan, Esquire
Attorney for Plaintiff
549 Bridge Street
New Cumberland, PA 17070-1931
(717) 774-1445
Supreme Court I.D. No. 32317
PATRICIA MUSKEY MERTLE, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO.
MICHAEL J. MERTLE, CIVIL ACTION - LAW
Defendant IN DIVORCE
I, Patricia Muskey Mertle, hereby certify that the facts set forth in the foregoing
COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and
belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A.
Section 4404 relating to unworn falsification to authorities.
Dated: 1 `_ 1?°I ?GJ ?//ion
Patricia Muskey Afertle
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PATRICIA MUSKEY MERTLE,
Plaintiff
V.
MICHAEL J. MERTLE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5514
CIVIL ACTION - LAW
IN DIVORCE
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
September 9, 1999.
2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days
have elapsed since the 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.
5. I verify that the statements made in this affidavit are true and correct. I
understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904
relating to unswom falsification to authorities.
DATE:,//-741' 2 ? C?ir ? ?-t // 1 ? (' ??
Patricia M. Mertle
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PATRICIA MUSKEY MERTLE,
Plaintiff
V.
MICHAEL J. MERTLE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO: 99-5514
CIVIL ACTION -LAW
IN DIVORCE
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 statement herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom
falsification to authorities.
DATE: 2000
Patricia M. Mertle
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PATRICIA MUSKEY MERTLE,
Plaintiff
V.
MICHAEL J. MERTLE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 99-5514
CIVIL ACTION - LAW
IN DIVORCE
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
September 9, 1999.
2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days
have elapsed since the 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.
5. I verify that the statements made in this affidavit are true and correct. I
understand that false statements are made subject to the penalties of 18 Pa. C.S.P Section 4904
relating to unswom falsification to authorities.
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PATRICIA MUSKEY MERTLE,
Plaintiff
V.
MICHAEL J. MERTLE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO: 99-5514
: CIVIL ACTION -LAW
: IN DIVORCE
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 statement herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn
falsification to authorities.
DATE: !/ -7 ya , 2000
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PATRICIA MUSKEY MERTLE,
Plaintiff
V.
MICHAEL J. MERTLE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5514
CIVIL ACTION - LAW
IN DIVORCE
I, Barbara Sumple-Sullivan, Esquire, do hereby certify that I served a copy of the
Complaint In Divorce in the above-captioned matter by United States Mail, Restricted Delivery,
Certified No. Z 143 612 071, Return Receipt Requested, on the above-named Defendant,
Michael J. Mertle, on September 23, 1999, at Defendant's last known address: 811 Brian
Drive, #103, Enola, PA 17025. The original receipt and return receipt card are attached hereto
as Exhibit "A".
I hereby certify that the facts set forth above are true and correct to the best of my
knowledge, information and belief. I understand that any false statements made herein are subject
to penalties of 18 Pa. C.S.A. §4904 relating to unswom falsification to authorities.
Dated: September 27,1999
Barbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070-1931
(717)-774-1445
Supreme Court ID #32317
Attorney for Plaintiff
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