HomeMy WebLinkAbout03-3710
v.
: IN THE COURT OF COMMON PLEAS,
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. ,(/3 - 37/0 ~
: Crvn.. ACTION - DIVORCE
TODD A DUJ!'J!'lli,
Plaintiff
CHRIS K DUJ!'J!'lli,
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 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 request marriage counseling. A list of marriage
counselors is available in the Office of the Prothonotary, Cumberland County
Courthouse, One Courthouse Square, Carlisle, Pennsylvania.
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 RIGIIT TO CLAIM ANY OF
THEM.
YOU SHOULD TAKE TIllS 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
(717) 249-3166
TODD A DlJ~'~'lli,
Plaintiff
: IN THE COURT OF COMMON PLEAS,
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
.
: NO. 03 - 31/ 0
: CIVILACITON - DIVORCE
ClffiIS K DUn'lli,
Defendant
COMPLAINT UNDER SECTION 3301(c) or 3301(d)
OF THE DIVORCE CODE
1. The parties hereto are husband and wife and have entered into agreements
for the resolution of their divorce, custody, support and equitable
distribution issues through the collaborative process.
2. Todd A. Duffie (hereinafter "Husband") resides at 1168 Fleming Drive,
Mechanicsburg, Pennsylvania 17055.
3. Chris K Duffie (hereinafter ''Wife'') resides at 804 Allenview,
Mechanicsburg, Pennsylvania 17055.
4. Husband and Wife have been bona fide residents of this Commonwealth for
at least six months immediately previous to the filing of this Complaint.
5. Husband and Wife were married on October 21, 1995, in Cumberland
County, Pennsylvania.
6. Husband and Wife have been living separate and apart since on or about
January, 2003, a date prior to the filing of this Complaint.
7. There have been no prior actions of divorce or for annulment between the
parties.
8. Neither of the parties in this action is presently a member of the Armed
Forces on active duty.
9. Husband and Wife are both citizens of the United States.
10. Husband and Wife have been advised of the availability of marriage
counseling and of the right to request the Court to require the parties to
participate in such counseling. Being so advised, Husband and Wife have
waived the right to request that the Court require the parties to participate
in counseling prior to a Divorce Decree being issued by the Court.
11. Husband and Wife aver that the ground on which the action is based is that
the marriage is irretrievably broken and that the parties have jointly agreed
to seek this divorce.
WHEREFORE, Husband and Wife respectfully request that Your Honorable
Court enter a Decree of Divorce.
COUNT I
CUSTODY OF MINOR CIllLDREN
12. The prior paragraphs of this Complaint are incorporated herein by reference
thereto.
13. The parties are the parents of two minor daughters, Taylor Duffie, born
August 28, 1998; and Samantha Duffie, born December 10, 1999.
14. Through the collaborative process, the parties have agreed to terms for
coparenting of their minor daughters which are set forth in a Stipulation for
Custody which is being filed simultaneously with this pleading.
WHEREFORE, Husband and Wife respectfully request that Your Honorable
Court enter an Order pursuant to the terms of the parties' Stipulation for Custody.
Respectfully submitted,
DATKD tiJv 2q, -:' DD3
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Supreme Court ID 45513
5440 Jonestown Road
Post Office Box 6216
Harrisburg, PA 17112-0216
(717) 541-1428
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VERIFICATION
I verify that the statement made in the foregoing document are true and
correct to the best of my knowledge, information and belief. I understand that the
statements therein are made subject to the penalties of 18 Pa. CoSo S 4904 relating
to unsworn falsification to authorities.
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: IN THE COURT OF COMMON PLEAS,
: CUMBERLAND COUNTY, PENNSYLVANIA
TODD A DUJ!'J!'l..I!;,
Plaintiff
v.
.
: NO. 03 F 371t)
- .
CuvJ
CIffiIS K DUJ!'J!'l..I!;,
Defendant
: CIVIT.. ACTION - DIVORCE
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance as attorney for the Plaintiff in the above-
captioned case.
Respectfully submitted,
DATED: ., 1 <!.
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ra F. Blair
preme Court ID 45513
5440 Jonestown Road
Post Office Box 6216
Harrisburg, PA 17112-0216
(717) 541-1428
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STIPULATION FOR CUSTODY
B.I!:l'W~ CHRIS K DUFFIE & TODD A DUFFIE
The parties hereto, the parents of two minor daughters, having reached
agreement with regards to the best interest and welfare of their minor daughters,
hereby stipulate and agree as follows:
1. The parties agree to share legal custody of the parties' minor daughters,
Taylor Duffie, born August 28, 1998; and Samantha Duffie, born December
10, 1999. The parties agree that major decisions concerning their minor
daughters, including, but not necessarily limited to, the daughters' health,
welfare, education, religious training and upbringing shall be made by them
jointly, after discussion and consultation with each other, with a view
toward obtaining and following a harmonious policy in the daughters' best
interest. Each party agrees not to impair the other party's right to shared
legal custody of the minor daughters. Each party agrees not to attempt to
alienate the affections of the minor daughters from the other party. Each
party agrees to notifY the other of any activity or circumstance concerning
their daughters that could reasonably be expected to be of concern to the
other. The parties agree that day-to-day decisions shall be the responsibility
of the parent then having physical custody. With regard to emergency
decisions which must be made, the parties agree that the parent having
physical custody of the minor daughters at the time of the emergency shall
be permitted to make any immediate decisions necessitated thereby.
However, the parties further agree that the parent making the emergency
decision shall inform the other of the emergency and consult with the other
parent as soon as possible. The parties agree that each party shall be
entitled to complete and full information from any doctor, dentist, teacher,
other professional or authority and to have copies of any reports given to
either party as a parent.
2. Todd A. Duffie (hereinafter referred to as "Father") and Chris K Duffie
(hereinafter referred to as "Mother") agree to share physical custody of the
parties' minor daughters.
3. The parties agree that Father shall have physical custody as follows:
a. Alternating weekends from 5:00 p.m. Friday to 8:00 p.m. Sunday;
b. On opposing weekends, from 5:00 p.m. Friday to 1:00 p.m. Saturday
provided that Mother does not have plans with the children;
C. As long as Mother is not working full-time Monday through Friday,
for one month out of every three months, an additional full weekend
instead of the partial weekend set forth in paragraph 3.b. with fifteen
(15) days notice to Mother of the weekend to be taken;
d. Two evenings per week from 3:00 p.m. to 9:00 p.m. with the evenings
to be agreed upon by the parties; and
e. Such other times as the parties may agree.
4. The parties agree that Mother shall have physical custody for all times not
set forth in this Stipulation as times that Father has physical custody.
5. The parties agree that Father shall have custody on Father's Day each year
from Saturday at 1:00 p.m. until Sunday at 8:00 p.m. and Mother shall have
custody on Mother's Day each year from Saturday at 1:00 p.m. to 8:00 p.m.
on Sunday. If either party loses his or her weekend as a result of the time
set forth in this paragraph, the following or previous weekend shall be
exchanged.
6. The parties agree that Father shall have the parties' daughters for three (3)
overnights around the Fourth of July each year, Labor Day each year, and
Thanksgiving Day at 8:00 p.m. to Saturday after Thanksgiving at 1:00 p.m.
each year. Mother shall have the parties' daughters for Memorial Day each
year.
7. The parties agree that all Monday holidays not set forth otherwise in this
Stipulation when the parent is off from work shall be spent with the parent
who had the minor daughters for the Sunday immediately preceding the
Monday holiday. If the parties are unable to agree otherwise, the following
holidays shall be alternated with Father having Trick or Treat night in odd-
numbered years:
A. New Years Day from 10:00 a.m. to 8:00 p.m.
B. Easter from 1:00 p.m. Saturday to 1:00 p.m. Sunday;
C. Easter from 1:00 p.m. to 8:00 p.m. Sunday;
D. Halloween Trick or Treat night from after school to 8:30 p.m. (If
Halloween trick or treat night is different in the two municipalities
where the parties reside then both parents may have the daughters
for the trick or treat night in their local mUnicipality);
E. Thanksgiving from Wednesday after school to Thursday at 8:00 p.m.;
F. Christmas Eve at 1:00 p.m. to Christmas Day at 1:00 p.m.;
G. Christmas Day at 1:00 p.m. to 1:00 p.m. December 26.
8. The parties agree that the holiday schedule shall take precedence over the
regular custody schedule.
9. The parties agree that each party shall be entitled to have the minor
daughters for two weeks of uninterrupted time each year. The parent
wishing to take the time shall provide the other parent at least fifteen (15)
days written notice of the dates for the time with the minor daughters. First
notice takes priority.
10. The parties acknowledge that the provisions of this Stipulation were arrived
at though the collaborative law process and that this process this process
best serves their long-term and ongoing coparenting goals, which require
continued cooperation and communication. Therefore the parties agree that
if the parties are unable to reach agreement on their own, any issues that
arise regarding the terms of this Stipulation or changes needed to this
Stipulation shall be made by use of the collaborative process, pursuant to
the terms of the Collaborative Law Agreement entered into on May 29,2003.
11. The parties agree that the custody arrangements as set forth in this
Stipulation represent a sharing of physical custody and that this schedule
shall not be used by the parties for the purposes of establishing status quo
in the event of custody litigation.
12. The parties agree that if a party is away from home overnight with the
parties' daughters, that parent shall provide the other parent with an
address and telephone number where the minor daughters may be reached.
13. The parties agree that during any period of custody or partial custody the
parties to this Order shall not possess or use any controlled substance,
except under a doctor's care, and shall not consume alcoholic beverages to
the point of intoxication. The parties likewise agree to refrain from driving
with the children in the vehicle if the party is under the influence of alcohol
or a controlled substance. The parties agree to likewise assure, to the extent
possible, that other household members and/or house guests comply with
this prohibition.
14. The parties agree that each parent shall be entitled to reasonable telephone
contact with the minor daughters when in the custody of the other parent.
15. The parties agree to refrain from making derogatory comments about the
other parent in the presence of the minor daughters and to the extent
possible shall prevent third parties from making such comments in the
presence of the minor daughters.
16. The parties agree that either party may submit this Stipulation to the
appropriate Court for entry as an Order.
IN WITNESS WHEREOF, the parties hereto have entered into this
Stipulation on the dates indicated.
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Dated: 7/lo/o::!:,
~Y- (\All J)h 0
CHRIS K DUFtI}' VI. C1J
Dated: 1- ~O -03
TODD A DlIJ.<'J.<'u.;,
Plaintiff
: IN THE COURT OF COMMON PLEAS,
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. C3 r 37/0 ~
AUG' 0 4 2003 'lY
CIffiIS K DlIJ.<1"u.;,
Defendant
: CIVIL ACTION - DNORCE
ORDER FOR CUSTODY
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AND NOW, this -::> day of
~
, 2003, after review
of the attached Stipulation for Custody Between Chris K Duffie and Todd A
Duffie, it is hereby ORDERED AND DECREED that the terms of said Stipulation
incorporated into this Order for Custody as though set forth in full herein.
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MARITAL SETTLEMENT AGREEMENT
Dawn S. Sunday, Esquire
39 West Main Street ~ Suite #1
Mechanicsburg, P A 17055-6230
(717) 766-9622
Counsel for: Chris K. Duffie
BY AND BETWEEN
CHRIS K. DUFFIE
AND
TODD A. DUFFIE
Nora F. Blair, Esquire
5440 Jonestown Road
Harrisburg, PA 17112
(717) 541-1428
Counsel for; Todd A. Duffie
03-.31/0
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MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT made this I Co ~ day of .T ""'-1 ' 2003, by and
between CHRIS K. DUFFIE, of Mechanicsburg, Pennsylvania (hereinafter referred to as
"WIFE"), and TODD A. DUFFIE, of Mechanicsburg, Pennsylvania (hereinafter referred
to as "HUSBAND"),
WITNESSETH:
WHEREAS, the parties are Wife and Husband, having been married on
October 21, 1995 in Mechanicsburg, Pennsylvania;
WHEREAS, differences have arisen between Wife and Husband in consequence
of which they have decided to live separate and apart from each other and consent to a
mutual consent divorce; and
WHEREAS, Wife and Husband desire to settle fully and finally their respective
financial and property rights and obligations as between each other, including, without
limitation, the settling of all matters between them relating to the ownership of real and
personal property, the support and maintenance of one another and, in general, the
settling of any and all claims and possible claims by one against the other or against
their respective estates.
NOW THEREFORE, the parties, intending to be legally bound, agree as
follows:
1. ADVICE OF COUNSEL. Both parties agree and acknowledge that they
have had ample and sufficient time to carefully and fully review the terms and provisions
of this Agreement. The provisions of this Agreement and their legal effect have been
fully explained to the parties by their respective counsel. Wife has obtained legal advice
and representation from Dawn S. Sunday, Esquire.
2
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Husband has obtained legal advice and representation from Nora F. Blair, Esquire. Both
parties agree and acknowledge that they fully understand the facts upon which this
Agreement is based, that they believe this Agreement to be fair and equitable, that this
Agreement is being entered into freely and voluntarily by each of them, and that the
execution of this Agreement is not the result of any duress, undue influence, collusion or
improper or illegal agreement or agreements.
2. DISCLOSURE OF ASSETS. The parties warrant that they have given full,
complete and accurate disclosure of all assets, of any nature, whether or not the assets
were held jointly or in one name alone. The remedies available to either party for
violation of this provision shall be those remedies available pursuant to law and equity
including the right to punitive and compensatory damages.
3. PERSONAL RIGHTS. Wife and Husband may and shall, at all times
hereafter, live separate and apart. Each shall be free from all control, restraint,
interference and authority, direct or indirect, by the other. Each may reside at such place
or places as she or he may select. Each may, for her or his separate use or benefit,
conduct, carry on or engage in any business, occupation, profession or employment
which to her or him may seem advisable. Wife and Husband shall not molest, harass,
disturb or malign each other or the respective families of each other, nor compel or
attempt to compel the other to cohabit or dwell by any means or in any manner
whatsoever with her or him. Neither party will interfere with the use, ownership,
enjoyment or disposition of any property now owned by or hereafter acquired by the
other.
4. EQUITABLE DISTRIBUTION.
A. Real Estate.
(l). The parties acknowledge that during their marriage they held,
as tenants by the entireties, the fee simple interest in the marital
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residence located at 1168 Fleming Drive, Mechanicsburg,
Cumberland County, Pennsylvania. Wife shall transfer all her
right, title and interest in the marital residence to Husband as his
sole property in exchange for a lump sum payment from Husband
to Wife as provided in the following provision.
(2). Husband shall have Wife's name removed as mortgagor and
shall assume liability in his sole name on the existing mortgage on
the marital residence with ABN Amro Mortgage Group Inc., on
which the parties are currently listed as joint mortgagors. On or
before July 31,2003, Husband shall pay to Wife the lump sum of
$30,000. 00 in cash or money order.
(3). Wife shall sign the deed transferring the marital residence to
Husband's sole name upon receipt from Husband's counsel on the
condition that the deed is held by Husband's counsel until Wife's
name is removed as mortgagor from the existing mortgage and
Wife has received from Husband the lump sum payment of
$30,000. as provided in provision 4A (2) of this Agreement.
(4). Husband shall assume solely all encumbrances on the marital
residence and will hold harmless, release, and indemnify Wife for
any mortgage obligation, encumbrance or lien.
(5). Husband shall pay all financing and transfer costs or fees in
connection with the marital residence. Husband shall pay all past,
present and future obligations, expenses, taxes, maintenance and
costs relating to the marital residence.
4
(6). Wife shall have the right to reside in the marital residence until
such time as she purchases and takes possession of a separate
residence or until September 30, 2003, whichever occurs first.
B. Household and Personal Propertv
(1). Wife and Husband agree that the household property shall be
allocated between the parties in accordance with the distribution
listed on Schedule A of this Agreement. The parties agree that all
property allocated to each on Schedule A shall be considered to be
in that party's possession regardless of whether it has been
physically separated. Except as otherwise stated on Schedule A,
the parties agree that their personal property has been or will be
divided to their mutual satisfaction.
(2). Within fifteen days after the date of execution of this
Agreement, Husband shall pay to Wife the sum of $1100.00 in
cash, representing a distribution of Wife's interest in the
refrigerator, washer and dryer which the parties agree shall remain
in the Husband's possession when Wife relocates from the marital
residence. The purpose of this payment from Husband to Wife is
to enable Wife to purchase a refrigerator, washer and dryer, for
Wife's separate residence.
C. Motor Vehicles.
(I). The parties agree that Wife shall retain possession of and
receive as her sole and separate property the 1998 Honda which
she drives, along with all rights tmder any insurance policy
thereon. Wife shall assume total responsibility for payment of any
loans and insurance premiums associated with the 1998 Honda.
5
Husband shall transfer title to the 1998 Honda to Wife's sole name
in order to effectuate this provision within fifteen days of the
execution date of this Agreement.
(2). The parties agree that Husband shall retain possession of and
receive as his sole and separate property the Ford Explorer which
he drives along with all rights under any insurance policy thereon.
Husband shall assume total responsibility for payment of any loans
and insurance premiums associated with the Ford Explorer.
D. Pensions and Retirement Benefits
(l). Husband shall retain as his sole and separate property, free
from any right, title, claim or interest of Wife, Husband's Reynolds
Construction Management Inc. Retirement Savings Plan (401k)
with a balance of$10,953.07 as of March 31, 2003.
(2). Wife shall retain as her sole and separate property, free from
any right, title, claim or interest of Husband, Wife's Vanguard
Group Individual Retirement Account with a balance of $ 6,768.25
as of December 31, 2002.
E. Children's Education Accounts
The parties agree to continue to jointly maintain the joint accounts
for the children's educational expenses which are currently held in
the Vanguard STAR Fund ($ 4,651.39 balance as of May 28, 2003)
and LifeStrategy Group Fund ($4,725.53 balance as of May 28,
2003). The parties agree to designate these funds to be used for
educational purposes only for Taylor and Samantha, unless agreed
otherwise between the parties.
6
F. Checking and Savings Accounts
The parties agree to retain in joint names their Pennsylvania State
Bank Gold Coin Checking Account (with a balance of
$ 8,084.42 as of May 20, 2003) and Gold Coin Savings Account
(with a balance of $ 1,577.05 as of May 20, 2003) until the day
before Husband's first payday after settlement on Wife's new
residence(which is also the day before Husband's first support
payment is due). On the day before Husband's first support
payment, the joint checking and savings accounts shall be
transferred to Husband's sole name, with the then current balances
being distributed sixty percent to Wife and forty percent to
Husband.
G. Life Insurance
Wife is the owner of Universal Life Policy No. 865344, with a
cash value of $345.96 (4/30/03) and Husband is the owner of
Universal Life Policy No. 865345, with a cash value of $572.11
(4/30/03). The life insurance polices shall be the sole and separate
property of the insured. Husband and Wife each agree to retain
each other, their daughters or a trust for the benefit of their
daughters as the beneficiaries of their life insurance policies with a
face value equal to or exceeding that currently in existence until
both of the parties' daughters are twenty-two (22) years of age.
Further the parties agree that if the face value of the party's life
insurance policies does not total One Hundred Thousand Dollars
($100,000.00), the party will name the other party, the parties'
daughters, or a trust for the benefit of the parties' daughters as the
beneficiary of the death benefit of the party's 401(k), Individual
Retirement Account (IRA), other retirement or pension account, or
other assets of the party's estate to reach a total death benefit for
the parties' daughters of One Hundred Thousand Dollars
7
($100,000.00), until both of the daughters are twenty-two (22)
years of age.
H. Tax Refund
The parties agree that any tax refunds for the 2002 tax year which
have not been deposited to the parties' joint checking or savings
accounts prior to the date of execution of this Agreement, shall be
equally divided between the parties.
I. Miscellaneous Property
Possession of any property not specifically addressed in this
Agreement shall be discussed and agreed upon by the parties and
shall be hereafter owned by the party to whom the property is
distributed by agreement. This Agreement shall constitute a
sufficient bill of sale to evidence a transfer of any and all rights in
such property from one party to the other.
5. DISTRIBUTION OF LIABILITIES.
A. Credit Cards.
Wife shall assume full responsibility for payment of the balance
($5,127.00) on the Boston Celtics MBNA America Credit Card
(No. 5490-9927-6102 XXXX). Neither party shall incur additional
charges on the Boston Celtics account and the parties shall close
the account promptly upon payment of the $5,127.00 balance. The
outstanding balances at the end of the July billing cycle on the
Chase Bank Toys R Us VISA Credit Card (No. 4253-3302-1053-
XXXX), the First North American National Bank Credit Card (No.
4104-1300-0810-XXXX) and the City U Promise Master Card
(No. 5424-1806-6262-XXXX) shall be paid from the parties' joint
checking account. Any amounts charged after the close of the July
billing cycle (mid to late July) on the Toys R Us, First North
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American and City U Promise accounts shall be the responsibility
of the party making the charge. All credit cards in joint names shall
be closed or transferred to the sole name of the party using the
account by July 31, 2003.
B. Landscaping Invoice.
Husband shall be responsible to pay the outstanding balance
($6,200.00) on the invoice from Davis Landscaping LTD.
c. Verification.
Upon request from the other party, each party agrees to promptly
provide documentation verifying satisfaction of any liability for
which that party assumes full responsibility under this Agreement.
D. Ongoing Liability.
Each party assumes the debts, encumbrances, taxes, and liens on
all the property he or she will hold subsequent to the date of this
Agreement.
6. LIABILITY NOT LISTED. With the exception ofjoint or family expenses
for which the parties agree to use the joint checking and savings accounts pending
Wife's purchase and relocation to a separate residence, each party represents and
warrants to the other that she or he has not incurred any debt, obligation or other liability
(other than those described in this Agreement) on which the other party is or may be
liable. A liability not disclosed in this Agreement will be the sole responsibility of the
party who has incurred or incurs it, and that party agrees to pay it, and to indemnify and
hold the other party and her or his property harmless from any and all such debts,
obligations and liabilities.
7. INDEMNIFICATION OF WIFE. If any claim, action or proceeding is
hereafter initiated seeking to hold Wife liable for the debts or obligations assumed by
9
Husband under this Agreement, Husband will, at his sole expense, defend Wife against
any such claim, action or proceeding, whether or not well-founded, and indemnify her
and her property against any damages or loss resulting therefrom, including, but not
limited to, costs of court and actual attorney's fees incurred by Wife in connection
therewith.
8. INDEMNIFICATION OF HUSBAND. If any claim, action or proceeding is
hereafter initiated seeking to hold Husband liable for the debts or obligations assumed
by Wife under this Agreement, Wife will, at her sole expense, defend Husband against
any such claim, action or proceeding, whether or not well-founded, and indemnify him
and his property against any damages or loss resulting therefrom, including, but not
limited to, costs of court and actual attorney's fees incurred by Husband in connection
therewith.
9. WARRANTY AS TO FUTURE OBLIGATIONS. Wife and Husband each
represent and warrant to the other that she or he will not at any time in the future incur or
contract for any debt, charge or liability for which the other, the other's legal
representatives, property or estate may be responsible, with the exception of joint or
family expenses incurred by agreement pending Wife's purchase of and relocation to a
separate residence. From the date of execution of this Agreement, each party shall use
only those Credit Cards/Accounts for which that party is individually liable and the
parties agree to cooperate in closing any remaining credit cards or accounts which
provide for joint liability. Each party agrees to indemnify, save and hold the other and
his or her property harmless from any liability, loss, cost or expense whatsoever incurred
in the event of breach hereof.
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10. CHILD SUPPORT, SPOUSAL SUPPORT, ALIMONY
A. Child Support and Spousal Support / Alimonv.
Beginning immediately upon relocation by Wife to a separate
residence and continuing for a period of two years, Husband shall
pay to Wife the amount of $1200.00 per month for the support of
the parties' two daughters, Taylor and Samantha, and $800.00 per
month for spousal support / alimony. In addition, Husband shall be
responsible to pay the total cost ofthe children's preschool and
50 % of all childcare. All costs of medical, vision and dental care
for the children and Wife which are not covered by insurance shall
be allocated between the parties with Husband being responsible
for 75 % and Wife being responsible for 25 %.
B. Continuing Child SuPPort.
After two years, Husband shall be responsible to pay support only
for the parties' children in the amount of $1400.00 per month or as
established by agreement of the parties, either independently or
through the collaborative law process. Thereafter, the parties agree
to review the child support amount at the end of April every year
and make any necessary adjustments based upon the parties'
incomes (including bonuses) and the children's needs. The parties
agree to provide each other with copies of their respective federal
income tax returns and W -2 statements for the preceding tax year.
C. Automatic Payment.
All support payments shall be made by automatic debit from
Husband's bank account and automatic deposit to Wife's bank
account on Husband's biweekly paydays beginning on the first
payday after Wife's relocation to a separate residence. The first
support payment shall be pro-rated to include the time period from
the date of Wife's relocation to the first payment date.
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D. Medical Insurance.
Husband shall maintain medical insurance coverage for the
children so long as it is available at a reasonable cost through his
employer, unless otherwise agreed by the parties. In the event
coverage is no longer available at a reasonable cost through
Husband's employer, Wife shall provide coverage for the children
through her employer's plan and Husband shall pay any premiums
incurred by the Mother for the coverage. Husband shall also
maintain medical insurance coverage for Wife until such time as
Wife obtains employment with paid health insurance benefits or a
divorce decree is entered terminating the parties' marriage. In the
event Wife's health insurance coverage is terminated due to entry
of a divorce decree, Wife shall be entitled to obtain COBRA
coverage through Husband's employer, for as long as she is
eligible. Wife shall pay the cost of COBRA coverage in the event a
divorce decree is entered at Wife's request. Husband shall pay the
cost of Wife's COBRA coverage in the event a divorce decree is
entered at Husband's request until such time as Wife remarries or
until September 1, 2005, whichever occurs first.
11. TAXES.
A. Prior Tax Years.
Wife and Husband warrant that they have heretofore paid all taxes
on prior returns including the calendar year ending December 31,
2002; that they do not owe any interest or penalties thereon; and
that no tax deficiency proceeding or audit is pending or notice
thereof received. Husband shall give Wife notice of any deficiency
assessment and Wife shall give Husband notice of any deficiency
assessment of which they individually or collectively become
aware. The parties agree that should it ultimately be determined
12
that any deficiency and/or penalty exists with respect to any jointly
filed returns, the party responsible for the erroneous preparation
and/or non-disclosure of information which has resulted in the
deficiency and/or penalty, shall be solely responsible for the
payment of the amount ultimately determined to be due, together
with interest, as well as expenses that may be incurred to contest
the assessment. If deficiencies or penalties become due as a result
of individually filed returns, the party who filed the return shall be
solely responsible for all sums due, and shall indemnify and hold
harmless the other party for any payment thereon.
B. Current and Future Tax Years.
Except as indicated below, the parties agree that each shall claim
one of the parties' daughters as a dependent for federal income tax
purposes for so long as both may be claimed as dependents and
that when only one of the daughters may be claimed as a
dependent, the parties shall alternate the dependency exemption
with Husband having the first year. The parties agree to cooperate
with each other in filing federal income tax returns so that the
filing status used (joint or individual), the dependency exemptions
for the parties' daughters, and the amount of support to be claimed
as alimony are handled by the parties so as to create the greatest
tax benefit for both parties. If adjustments are made in the
dependency exemptions or the amount reported as alimony and
such that result in a combined overall tax savings, the parties agree
to equally share in said savings and ensure that neither party is in a
worse position financially as a result of the adjustment or filing
status that he or she would have been without the adjustment.
13
12. DIVORCE DECREE At such time as either party wishes to obtain a divorce
decree the parties agree to cooperate in filing all necessary documents with the Court,
including a Divorce Complaint, Acceptance of Service of the Divorce Complaint,
Affidavits of Consent, Waivers of Notice, Praecipe to Transmit the Records and Vital
Statistics Form.
13. MUTUAL COOPERATION. Each party shall on demand execute and
deliver to the other any deeds, bills of sale, assignments, consents to change of
beneficiary designations, tax returns, and other documents, and shall do or cause to be
done every other act or thing that may be necessary or desirable to effectuate the
provisions and purposes of this Agreement. If either party unreasonably fails on demand
to comply with this provision, that party shall pay to the other party all attorney's fees,
costs, and other expenses actually incurred as a result of such failure.
14. WAIVER OF INHERITANCE RIGHTS. Unless otherwise specifically
provided in this Agreement, effective upon the execution date, Wife and Husband waive
all rights of inheritance in the estate of the other, any right to elect to take against the Will
or any trust of the other or in which the other has an interest. Each party waives any
additional rights which that party has or may have by reason of their marriage, except the
rights saved or created by the terms of this Agreement. This waiver shall be construed
generally and shall include, but not be limited to, a waiver of all rights provided under the
laws of Pennsylvania, or any other jurisdiction, and shall include all rights under the
Pennsylvania Divorce Code.
15. WAIVER OF BENEFICIARY DESIGNATION.
Unless otherwise
specifically set forth in this Agreement, each party specifically waives all beneficiary
rights in and to any asset, benefit or like program carrying a beneficiary designation
which belongs to the other party under the terms of this Agreement, and each party
expressly states that it is her and his intention to revoke by the terms of this Agreement
14
.'
any beneficiary designations naming the other which are in effect as of the date of
execution of this Agreement. If the other party continues to be named as beneficiary and
no alternate beneficiary is otherwise designated, the beneficiary shall be deemed to be
the estate of the deceased party. However, in the event that either party specifically
designates the other party as a beneficiary after the date of execution of this Agreement,
then this waiver provision shall not bar that party from qualifying as such beneficiary.
16. RELEASE OF CLAIMS. Wife and Husband agree that the property
dispositions provided for herein constitute an equitable distribution of their assets and
liabilities pursuant to the Pennsylvania Divorce Code, and Wife and Husband waive any
right to division of their property except as provided for in this Agreement. Except as set
forth in this Agreement, each party hereby absolutely and unconditionally releases and
forever discharges the other and her or his heirs, executors, administrators, assigns,
property and estate from any and all rights, claims, demands or obligations arising out of
or by virtue of the marital relationship of the parties whether now existing or hereafter
arising. The above release shall be effective regardless of whether such claims arise out
of any former or future acts, contracts, engagements or liabilities of the other or by way
of dower, curtesy, 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
Pennsylvania, any state, commonwealth or territory of the United States, or any other
country. Except for the obligations of the parties contained in this Agreement and such
rights as are expressly reserved herein, each party gives to the other by the execution of
this Agreement an absolute and unconditional release and discharge from all causes of
action, claims, rights or demands whatsoever in law or in equity, which either party ever
had or now has against the other.
17. WAIVER OF PROCEDURAL RIGHTS. This Agreement constitutes an
equitable division of the parties' marital property. The parties have determined that the
division of this property conforms with regard to the rights of each party. The division
15
of existing marital property is not intended by the parties to constitute in any way a sale
or exchange of assets, and the division is being effectuated without the introduction of
outside funds or other property not constituting the marital estate. Both parties hereby
waive the following procedural rights:
. The right to obtain an inventory and appraisement of all marital and separate
property as defined by the Pennsylvania Divorce Code
. The right to obtain an income and expense statement of the other party as
provided by the Pennsylvania Divorce Code
. The right to have the Court determine which property is marital and which is
non-marital, and equitably distribute between the parties that property which
the Court determines to be marital
. The right to have the Court decide any other rights, remedies, privileges, or
obligations covered by this Agreement, or any possible claims not addressed
in this Agreement
18. PRESERVATION OF RECORDS. Each party will keep and preserve for a
period of four (4) years from the date of their divorce decree all financial records relating
to the marital estate, and each party will allow the other party access to those records in
the event of tax audits.
19. SEVERABILITY. If any provision of this Agreement is held by a court of
competent jurisdiction to be void, invalid or unenforceable, the remaining provisions
shall nevertheless survive and continue in full force and effect without being impaired or
invalidated in any way.
20. MODIFICATION / BREACH. No modification, rescission, or amendment
to this Agreement shall be effective unless in writing signed by each of the parties. If
either party breaches any provision of this Agreement, the other party shall have the right,
to sue for damages for such breach, or seek such other remedies or relief as may be
available to her or him. The non-breaching party shall be entitled to recover from the
16
breaching party all costs, expenses and legal fees actually incurred in the enforcement of
the rights of the non-breaching party.
21. COLLABORATIVE LAW PROCESS. The parties acknowledge that the
provisions of this Agreement were established through the collaborative law process and
that this process best serves the parties' long term and ongoing coparenting goals, which
require continued cooperation, communication and civility. Therefore, the parties agree
that any issues which may arise concerning subjects covered by this Agreement,
including modification and/or breach, shall be addressed through the collaborative
process (pursuant to the parties' May 29, 2003 Collaborative Law Participation
Agreement) ifthe parties are unable to resolve the issues independently.
22. WAIVER OF BREACH. The waiver by one party of any breach of this
Agreement by the other party will not be deemed a waiver of any other breach of any
provision of this Agreement.
23. APPLICABLE LAW. All acts contemplated by this Agreement shall be
construed and enforced under the laws of the Commonwealth of Pennsylvania in effect as
of the date of execution ofthis Agreement.
24. DATE OF EXECUTION. The "date of execution" or "execution date" of
this Agreement shall be defined as the date upon which the parties signed the Agreement
if they do so on the same date, or if not on the same date, then the date on which the
Agreement was signed by the last party to execute this Agreement. This Agreement shall
become effective and binding upon both parties on the execution date.
25. EFFECT OF RECONCILIATION. COHABITATION OR DIVORCE.
This Agreement shall remain in full force and effect and shall not be abrogated even if
the parties effect a reconciliation, cohabit as Husband and Wife or attempt to effect a
reconciliation. This Agreement also shall continue in full force and effect in the event of
17
the parties' divorce. There shall be no modification or waiver of any of the terms unless
made in writing by the parties.
26. HEADINGS NOT PART OF AGREEMENT. Any headings preceding the
text of the several paragraphs and subparagraphs are inserted solely for convenience of
reference and shall not constitute a part of this Agreement nor shall they affect its
meaning, construction or effect.
27. AGREEMENT BINDING ON PARTIES AND HEIRS. This Agreement
shall bind the parties and their respective heirs, executors, administrators, legal
representatives, assigns, and successors in any interest of the parties.
28. ENTIRE AGREEMENT. Each party acknowledges that she or he has
carefully read this Agreement, that she or he has discussed its provisions with an attorney
of her or his own choice and has executed it voluntarily. This instrument expresses the
entire agreement between the parties concerning the subjects it purports to cover and
supersedes any and all prior agreements between the parties. This Agreement should be
interpreted fairly and simply, and not strictly for or against either ofthe parties.
29. AGREEMENT TO BE INCORPORATED BUT NOT MERGED. This
Agreement shall be incorporated in a decree of divorce for purposes of enforcement only,
but otherwise shall not be merged into said decree. The parties shall have the right to
enforce this Agreement under the Pennsylvania Divorce Code, and in addition, shall
retain any remedies in law or in equity under this Agreement as an independent contract.
Such remedies in law or equity are specifically not waived or released.
18
.
IN WITNESS WHEREOF, the parties hereto set their hands and seals on the
dates of their acknowledgments.
a ~J- ~
WITNESS ~
4~
Chrz(
CHRIS K.
-~
~....M _ ",
~DD A. D ,us band
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND
BEFORE ME, the undersigned authority, on this day personally appeared
CHRIS K. DUFFIE, known to me to be the person who executed the foregoing
instrument, and who acknowledged to me that she executed same for the purposes and
considerations therein expressed.
IOF
GIVEN
day of
UNDER
.lVll1
MY HAND AND SEAL OF OFFICE this
,2003.
- J
Notarial Seal
Gail P. Minnich, Noti;W Public
M~~~l:S~:U,~~;_ Boro,,?~:'bEnj8'ld. ~unty
M~, Ceo r'. ,lb",lon EXpH~..:> Dec. 9, 2006
~1eml.;er, Pe~";s;1::'Bni~ Assoc.iaUon Of Not3rieS
Notar
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND
BEFORE ME, the undersigned authority, on this day personally appeared
TODD A. DUFFIE, known to me to be the person who executed the foregoing
instrument, and who acknowledged to me that he executed same for the purposes and
considerations therein expressed.
lOt-
GIVEN
day of
UNDER MY
~(1
HAND AND SEAL OF OFFICE this
,2003.
Notary pi:
P~l
(
19
Noiaia! Seal
Gait p, Minnicll, ~ot:lIY Public
Mechanlcsbur9 BOlO. CUillbellencl County
My Commission Expi(;j~; DSG. 9, 2006
f\.iernber, Pannsylva-niLj ~.r,;X:;:;iion Of Notaries
.
DUFFIE
MARITAL SETTLEMENT AGREEMENT
Schedule A
Distribution of Household Property
CHRIS DUFFIE
Engagement Ring
Small TV
Telephone with cord
Cell Phone
Sun Room Furniture
Kitchen Table
Guest Bedroom Furniture
Porch Furniture
Knick Knacks / Jewelry
TODD DUFFIE
Computer
Large TV
Video Camera
Stereo / radio
Refrigerators
Washer / Dryer
Telephone - cordless
Living Room Furniture
Bedroom Furniture
Computer Desk
Crafting Table
Children's Furniture
Treadmill
Outdoor Equipment
VCR
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TODD A. DUFFIE,
Plaintiff
: IN THE COURT OF COMMON PLEAS,
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO.
03-3710 Civil
CHRIS K. DUFFIE,
Defendant
: CIVIL ACTION -- DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under section 330I(c) ofthe Divorce Code was
filed on August 1, 2003, and served on August 29, 2003.
2. The marriage of Plaintiff and Defendant is irretrievably broken and
ninety (90) days have elapsed from the filing of the Complaint and service of the
Complaint on Defendant.
3. I consent to the entry of a final Decree of Divorce after service of
Notice of Intention to Request Entry of Divorce Decree or at any time after the
signing of this Consent if I have also signed a Waiver of Notice of Intention to
Request Entry of a Divorce Decree Under Section 3301(c) of the Divorce Code.
I verify that the statements made in this Affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18
Pa.C.S. ~4904 relating to unsworn falsification to authorities.
DATED: 1- /r 0 h
"__"L-~~
/"TODD A.
Plaintiff
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TODD A. DUFFIE,
Plaintiff
: IN THE COURT OF COMMON PLEAS,
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 03-3710 Civil
CHRIS K. DUFFIE,
Defendant
: CIVIL ACTION -- DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER SECTION
3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of
property, lawyer's fees or expenses if I do not claim them before a divorce is
granted.
3. I understand that I will not be divorced until a Decree of Divorce 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. H904 relating to unsworn falsification to authorities.
DATED: 1//1 jot,.
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CHRIS K. D
Defendant
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TODD A. DUFFIE,
Plaintiff
: IN THE COURT OF COMMON PLEAS,
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 03-3710 Civil
CHRIS K DUFFIE,
Defendant
: CIVIL ACTION -- DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER SECTION
3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of
property, lawyer's fees or expenses if I do not claim them before a divorce is
granted.
3. I understand that I will not be divorced until a Decree of Divorce 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 Waiver are true and correct. I
understand that false statements herein are made subject to the penalties of 18
Pa.C.S. H904 relating to unsworn falsification to authorities.
DATED: 1- /, - bit,
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TODD A. DUFFIE,
Plaintiff
: IN THE COURT OF COMMON PLEAS,
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO.
03-3710 Civil
CHRIS K DUFFIE,
Defendant
: CIVIL ACTION -- DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under section 3301(c) of the Divorce Code was
filed on August 1, 2003, and served on August 29, 2003.
2. The marriage of Plaintiff and Defendant is irretrievably broken and
ninety (90) days have elapsed from the filing of the Complaint and service of the
Complaint on Defendant.
3. I consent to the entry of a final Decree of Divorce after service of
Notice of Intention to Request Entry of Divorce Decree or at any time after the
signing of this Consent if I have also signed a Waiver of Notice of Intention to
Request Entry of a Divorce Decree Under Section 3301(c) of the Divorce Code.
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. H904 relating to unsworn falsification to authorities.
DATED: / /1 Iou
c-o
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: IN THE COURT OF COMMON PLEAS,
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 03-3710 Civil .
TODD A DUl"l"lli,
Plaintiff
CHRIS K DUl"l"lli,
Defendant
: CIVIL ACTION - DIVORCE
ACCEPTANCE OF SERVICE
I, Dawn S. Sunday, Esquire, am the Attorney for Wife, Chris K Duffie, in
the above-captioned matter. In that capacity, I am authorized to and have
accepted service of the Complaint in Divorce, as of this the d-q'+1.- day of
ftvgu-o;;t-
, 2003.
Da&~~~
Attorney for Wife
39 West Main Street
Mechanicsburg, PA
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TODD A. DUFFIE,
Plaintiff
: IN THE COURT OF COMMON PLEAS,
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO.
03-3710 Civil
CHRIS K. DUFFIE,
Defendant
: CIVIL ACTION -- DIVORCE
PRAECIPE TO TRANSMIT RECORD
UNDER ~ 3301(c) OF THE DIVORCE CODE
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 ~ 3301(c) of the Divorce Code.
2. Date and manner of service of the complaint:
(a) Date of service: August 29,2003.
(b) Manner of service: Acceptance of Service by Counsel for Defendant
3. Date of execution of the Affidavit of Consent required by ~ 3301(c) of the Divorce Code:
(a) By the Plaintiff: January 6,2006
(b) By the Defendant: January 11, 2006
4. Date of execution of Waiver of Notice ofIntention to File Praecipe to Transmit Record:
(a) By the Plaintiff: January 6, 2006
(b) By the Defendant: January 11, 2006
Related claims pending: NONE
5.
)
DATED: January 18,2006
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IN THE COURT OF COMMON
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STATE OF
TODD A. DUFFIE
03-3710 Civil
Plaintiff
No.
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VERSUS
CHRIS K. DUFFIE
Defendant
DECREE IN
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DIVORCE
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:Mb, IT IS ORDERED AND
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DECREED THAT 'T'Onn A nTTFFTF.
, PLAINTIFF,
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CHRIS K. DUFFIE
c' DEFENDANT,
AND
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ARE DIVORCED FROM THE BONDS OF MATRIMONY. TheM.aritalSettlementAgreement
dated July 10, 2003, is incorporated into but not merged into this Decree in Divorce.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS
YET BEEN ENTERED; ~~
ACTION FOR WH ICH A FI NAL ORDER HAS NOT
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