HomeMy WebLinkAbout04-5571
SAlOIS
SHUFF, FLOWER
& LINDSAY
ATIORNEYSoAToLAW
26 W. High Street
Carlisle, P A
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
KAREN M. GAGE,
Plaintiff
No. 2004 - 557/
v.
CIVIL ACTION - LAW
JAMES R. GAGE,
Defendant
(In Divorce)
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take prompt action. You are warned that if you fail to do so, the case
may proceed without you and a decree of divorce or annulment may be entered against you by
the Court. A judgment may also be entered against you for any other claim or relief requested in
these papers by the Plaintiff. You may lose money or property or other rights important to you,
including custody or visitation of your children. When the ground for 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 at the Cumberland County
Court House, High and Hanover Street, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DNISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DNORCE 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
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
Date: "ISlo~
By ~~~~;~~AY
Supreme Co~ # 87954
26 West High Street
Carlisle, P A 17013
(717) 243-6222
Attorneys for Plaintiff
SAlOIS
SHUFF, FLOWER
& LINDSAY
ATTORNEVS-AT-LAW
26 W. High Street
Carlisle, P A
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
KAREN M. GAGE,
Plaintiff
No. 2004 - )5'1 (
v.
CIVIL ACTION - LAW
JAMES R. GAGE,
Defendant
(In Divorce)
COMPLAINT UNDER SECTION 330l(c)
OR 330l( d) OF THE DIVORCE CODE
1. Plaintiff is Karen M. Gage, who currently resides at 597 Mountain Road, Boiling
Springs, Cumberland County, Pennsylvania.
2. Defendant is James R. Gage, who, at the time of filing of this Complaint, also
resides at 597 Mountain Road, Boiling Springs, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for
at least six (6) months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on December 17, 1994 in Cumberland
County, Pennsylvania.
5. Plaintiff and Defendant, although living in the same residence, have been living
separate and apart since October 1, 2004.
6. There have been no prior actions of divorce or for annulment between the parties.
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATTORNEYS-AT-LAW
26 W. High Street
Carlisle, P A
7, Plaintiff has been advised of the availability of marriage counseling and the
Plaintiff may have the right to request that the Court require the parties to participate in
counseling. Having been so advised Plaintiff does not desire the Court to order counseling. See
Plaintiff s Affidavit attached hereto as Exhibit "A" and incorporated herein by reference.
8, The marriage is irretrievably broken. The foregoing facts are averred under
Sections 3301(c) or 3301(d) of the Divorce Code of 1980, as amended.
WHEREFORE, Plaintiff requests Your Honorable Court enter a Decree in Divorce,
thereby divorcing Plaintiff and Defendant from the bonds of matrimony.
Respectfully submitted,
Date: 1l151D'-1
By:
Attorneys for Plaintiff
VERIFICATION
I, Karen M. Gage, verify that the statements made in this Complaint are true and
correct to the best of my knowledge, information and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to
unsworn falsification to authorities.
Dated: I 10 3/ {)I!
~~JJ1. sf6--e,t
fmJ~. Gage, Plaintiff /
AFFIDA VIT
I, Karen M. Gage, being duly sworn according to law, depose and say:
(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 m the
Prothonotary's Office, which list is available to me upon request.
(3) Being so advised, I do not request 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.
Section 4904 relating to unsworn falsification to authorities.
Dated: / rj 0.') /'0 'i
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
KAREN M. GAGE,
Plaintiff
No. 2004 - 5571
v.
CIVIL ACTION - LAW
JAMES R. GAGE,
Defendant
(In Divorce)
ACCEPTANCE OF SERVICE
1, James R Gage, Defendant in the above-captioned matter, hereby accept service of
the Complaint in Divorce, which was filed on November 5, 2004.
Dated: November 6. 2004
By:
f-
a es R Gage, Defendant
_ 7 Mountain Road
Boiling Springs, Pennsylvania 17007
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
KAREN M. GAGE,
Plaintiff
No. 2004 - 5571
v.
CIVIL ACTION - LAW
JAMES R. GAGE,
Defendant
(In Divorce)
PROPERTY SETTLEMENT AND SEPARATION AGREEMENT
../
THIS AGREEMENT is made this 20 day of ~ JO-r\~ .2005, BY
and BETWEEN Karen M. Gage of 597 Mountain Road, Boiling Springs, Cumberland
County, Pennsylvania, hereinafter referred to as Wife,
A
N
D
James R. Gage of 597 Mountain Road, Boiling Springs, Cumberland County, Pennsylvania,
hereinafter referred to as Husband.
RECITALS
R.l: The parties hereto are Husband and Wife, having been joined in marriage on
December 17, 1994, in Cumberland County, Pennsylvania; and
R.2: Differences have arisen between th<: parties, in consequence of which they
have lived separate and apart since on or about October 1, 2004; and
R.3: The parties have resolved that it is not possible to continue the marital
relationship between them for reasons known to them, in consequence of which they are
living separate and apart; and
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Page 1 of 24
JRG J 1..6:
R. 4: It is the desire and intention of the parties, after long and careful
consideration, to amicably adjust, compromise and settle all property rights, and all rights
in, to or against the property or estate of the other, including property heretofore or
subsequently acquired by either party, and to settle all disputes existing between them,
including any claims or rights that they may have under the provisions of the Pennsylvania
Divorce Code, as amended; and
R. 5: The parties also desire to settle their issues of counsel fees and costs, and the
settling of any and all claims and possible claims against the other or against their
respective estates; and
R.6: The parties desire to resolve all claims pending between them, including the
settlement of all of their respective property rights and other rights growing out of their
marriage relationship including, but not limited to, all matters between them relating to the
ownership of real and personal property, claims [,)1' spousal support, alimony, alimony
pendente lite, counsel fees and costs; and
R. 7: Husband and Wife declare that each has had a full and fair opportunity to
obtain independent legal advice of counsel of their selection; that Wife has been
independently represented by Lindsay Gingrich Maclay, Esquire, of Daley, Zucker &
Gingrich, LLC, and that Husband, has been ind1ependently represented by Michael A.
Scherer, Esquire, of O'Brien, Baric & Scherer; and
R.8: Both Husband and Wife each covenant that they have made full and
complete disclosure to the other of his and her r€:spective property holdings and income;
and
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Page 2 of 24
JRG Jt4
R.9: Each party has had an opportunity to v,~rify the financial disclosure of the
other. Discovery, if any, has been conducted to the satisfaction of each party. Each party
has had the opportunity to investigate further the financial disclosure of the other, and has
had access to any desired books and/or records to investigate further. Each party had an
opportunity to do an independent valuation of the assets, liabilities and income of the other
party. To the extent either party decided not to pursue further discovery and investigation,
he or she did so voluntarily and specifically waives the right to challenge this Agreement
based on the absence of fu1\ and fair disclosure.
NOW THEREFORE, with the aforegoing recitals being hereinafter incorporated by
reference and deemed an essential part hereof and in consideration of the covenants and
promises hereinafter to be mutually kept and perfoffiled by each party, as wen as for other
good and valuable consideration, receipt of which is hereby acknowledged, and the parties,
intending to be legany bound, hereby agree as fo1\ows:
(1) SEPARATION: It shall be lawful for each party at all times hereafter
to live separate and apart from the other party at such place or places as he or she from time
to time may choose or deem fit, free from any control, restraint or interference from the
other. Neither party win molest the other or endeavor to compel the other to cohabit or
dwe1\ with him or her by any legal or other proC(~eding. Neither party shall disparage or
discredit the other in any way, nor in any way injufCl his or her reputation; nor shall either of
them act or permit anyone else to act in any way which might tend to create any disaffection
or disloyalty or disrespect between the members of the family of either party. Each party
shall be free of the interference, authority or contact by the other as if he or she was single
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Page 3 of 24
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and unmarried except as maybe necessary to carry out the terms of this Agreement or any
Custody Stipulation and Agreement and/or Order of Court.
(2) DIVORCE: The parties acknowledg/: that the marriage is irretrievably
broken and that they will secure a mutual consent no-.fault divorce decree. Simultaneous
with the execution of this Agreement, the parties agree to execute their respective Affidavits
of Consent and Waiver of Notice Forms necessary to finalize said divorce.
If either party fails or refuses to execute and file the foregoing documents, said
failure or refusal shall be considered a material breac:h of this Agreement and shall entitle
the other party at his or her option to terminate this Agreement.
(3) REAL PROPERTY: The parties acknowledge that they are joint
owners of the premises more commonly identified as 597 Mountain Road, Boiling Springs,
Cumberland County, Pennsylvania (hereinafter referred to as the "Marital Residence"). The
parties have agreed to list and sell the Marital Residence. The parties have entered into a
Sales Agreement for the sale of the Marital Residence through Realtor Steve Thompson of
Prudential Thompson Wood Real Estate for Three Hundred Ninety-Six Thousand
($396,000.00) Dollars.
The parties specifically agree that the net proceeds from the sale of the Marital
Residence, after deduction of all expenses, fees and taxes in connection with the sale; then
after satisfaction of the lien of the existing joint first mortgage through GMAC Mortgage
Corporation (the balance of this mortgage on or about October 5, 2004, was One Hundred
Seventy-Six Thousand Five Hundred Ninety-Eight and 00/100 ($176,598.00) Dollars), shall
be divided equally between the parties at the time of settlement.
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Page 4 of 24
JRG.J tv
The parties are also joint owners of the premises more commonly identified as 1420
Bradley Drive, Unit F-lll, Carlisle, Cumberland County, Pennsylvania (hereinafter
referred to as the "Rental Property"). The parties stipulate and agree that the fair market
value of the Rental Property is Forty-Four Thousand Two Hundred Fifty and 00/100
($44,250.00) Dollars and that the payoff on the joint mortgage obligation with Midwest
Loan Services is Twenty-Five Thousand Two Hundre:d Nineteen and 00/100 ($25,219.00)
Dollars. Husband shall become the sole owner of the Rental Property and Wife shall Deed
her interest in and to the Rental Property to Husband at such time as Husband pays to Wife
the sum of Nine Thousand Six Hundred Twenty-Five ($9,625.00) Dollars, for her interest in
the Rental Property. Husband is required to either assume the joint mortgage into his name
alone or to refinance the debt on the Rental Property within sixty (60) days of the date of
this Agreement. From the date of separation forward, Husband agrees to hold Wife
hannless with regard to any debts or obligations associated with the Rental Property,
including mortgage payments, taxes, homeowner's insurance, association dues and repairs.
It is specifically contemplated and understood that Wife plans to purchase a
residence in which she and the parties' minor child may reside. Wife has, during the
pendency of the drafting of this Agreement, made an offer on at least one (1) home.
Husband hereby agrees to waive and right, title or interest he may have, by virtue of his
marital relationship, in and to any home that Wife may purchase prior the parties' Divorce
being finalized. Wife shall be solely responsible for any encumbrance on any property she
may purchase under this Paragraph and she shall indemnify and hold Husband harmless
from any payments thereon. Husband agrees to execute any and all necessary documents to
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Page 5 of 24
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give full force and effect to this provision within three (3) days of a request by Wife to do
so.
It is specifically contemplated and understood that Husband may also purchase a
residence. Wife hereby agrees to waive and right, title or interest she may have, by virtue of
her marital relationship, in and to any home that Husband may purchase prior the parties'
Divorce being finalized. Husband shall be solely responsible for any encumbrance on any
property he may purchase under this Paragraph and he shall indemnify and hold Wife
harmless from any payments thereon. Wife agrees to execute any and all necessary
documents to give full force and effect to this provision within three (3) days of a request by
Husband to do so.
DEBT: Each of the parties hereto covenants and agrees that he or she has
not in the past and will not at any time in the future incur or contract any debt, charge or
liability for which the other of them, their legal replresentatives, or their property or estate
may become liable; and each of them further covenants at all times to keep the other free,
harmless and indemnified of and from all debt~l, charges and liabilities hereafter or
heretofore contracted by them, except as hereinafter provided.
A. MARITAL DEBT: Other tl1an those debts enumerated within this
agreement, Husband and Wife acknowledge and agree that there are
no other outstanding debts and obligations which are marital or for
which the other might be liable incurred prior to the signing of this
Agreement.
I.
Except as otherwise herein provided, each of the parties will
pay all current bills and outstanding bills incurred on or
before tbe date of separation of the parties, October I, 2004,
to the same extent that he or she has been paying them in the
past and neither party shall incur any unusual bill which will
bind the other party. Husband hereby agrees to return to
Wife any and all joint credit cards or charge plates that he
Page 6 of24 JRG<..\ l"
KMG :;{mlf
may have in his possession. The parties further agree that
any debts incurred on said joint credit cards or charge plates
subsequent to the date of separation, shall be the sole and
exclusive responsibility of the party who incurred said debts
and the debt-incurring flarty shall save harmless the other
party from any obligation or institutions of suit thereunder.
B: POST SEPARATION DEBT: In the event that either party
contracted or incurred any debt since the date of separation on
October I, 2004, the party who incurred said debt shall be
responsible for the payment thereof regardless of the name in which
the debt may have been incurred.
c: FUTURE DEBT: From the date of this agreement neither party
shall contract or incur any debt or liability for which the other party
or his or her property or estate might be responsible and shall
indemnify and save the other party hannless from any and all claims
or demands made against him or her by reason of debts or obligations
incurred by the other party.
(5)
MOTOR VEHICLES:
The parties acknowledge that Husband, individually,
holds title to a truck, which is currently in his possession. Said truck is currently
encumbered by a loan, solely in Husband's name. Wife hereby relinquishes any right, title
or interest she may have in and to the truck currently in Husband's possession. Husband
shall acquire and maintain separate insurance on the truck currently in his possession.
Husband specifically agrees to assume full responi,ibility for and pay in due course, any
encumbrance on the truck currently in Husband's possession. Husband shall hold Wife
harmless and indemnify Wife from any loss thereon.
The parties further acknowledge that they jointly hold title to a 2003 Ford Explorer,
which vehicle is currently in the possession of Wife. Husband relinquishes any right, title
and interest he may have in and to the Explorer (;urrently in possession of Wife. Within
thirty (30) days of the date of this agreement Husband shall execute any and all documents
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Page 7 of 24
JRG..! ;l'
necessary to have said vehicle properly registered solely in Wife's name with the
Pennsylvania Department of Transportation. Wife shall maintain insurance and assume full
responsibility for any encumbrance on the 2003 Ford Explorer received by Wife as a result
of this transfer, and shall hold harmless and indemnify Husband from any loss thereon.
Wife shall refinance the joint obligation on the 2003 Ford Explorer within forty-five (45)
days of the execution of this Agreement.
The parties further acknowledge that they jointly hold title to a 1984 trailer, title number
48963842701. Wife relinquishes any right, title and interest she may have in and to the
1984 trailer, currently in the possession of Husband. Within thirty (30) days of the date of
this Agreement, Wife shall execute any and all documents necessary to have said trailer
properly registered solely in Husband's name with the Pennsylvania Department of
Transportation. Husband shall hold Wife hannless and indemnify Wife from any loss on
the trailer.
(6) TANGmLE PERSONAL PROPERTY: Except as otherwise provided
herein, the parties hereto mutually agree that they have effected a satisfactory division of
the furniture, household furnishings, appliances, tools and other household personal
property between them, and they mutually agree that each party shall from and after the
date hereof be the sole and separate owner of alii such property presently in his or her
possession whether said property was heretofore owned jointly or individually by the
parties hereto. This Agreement shall have the effllct of an assignment or bill of sale from
each party to the other for such property as may be in the individual possession of the
parties hereto.
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Page 8 of24
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(i) All personal property listed on Exhibit" A" shall become the sole and
separate property of Husband; and
(ii) All personal property listed on Exhibit "B" shall become the sole and
separate property of Wife; and
(iii) All personal property listed on Exhibit "C" shall be divided as
equally as possible between Husband and Wife; and
(iv) It is contemplated that all personal property listed on Exhibit "D" be
sold and the proceeds from the sale of these items are to be divided
equally between the parties.
Exhibits "/1:', "B", "C", and "D" are incorporated herein by reference as if set out in
their entirety herein.
(7)
INTANGmLE PERSONAL PROPERTY:
Except as otherwise
herein provided, each party hereto hereby relinquish,~s any right, title or interest he or she
may have in or to any intangible personal property currently titled in the name of or in the
possession of the other party, including, but not limited to, stocks, bonds, insurance, bank
accounts, individual retirement accounts, employment benefits, including retirement
accounts, savings plans, pension plans, stock plans, 40lK plans, and the like.
Husband acknowledges that the marital property of the parties includes any marital
portion of Wife's ESOP through her employment with EDS. The approximate value of
Wife's stock with EDS as of October I, 2004 was Three Thousand Two Hundred Thirty
and 00/100 ($3,230.00) Dollars. Husband further acknowledges that he has been informed
of his right to obtain an independent appraisal of Wife's ESOP, and any marital interest
therein, and, notwithstanding same, Husband hereby forever waives and relinquishes any
right, title, interest or claim he might otherwise have in and to Wife's aforesaid ESOP with
EDS.
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Page 9 of24
JRG~a.~
Husband acknowledges that the marital property of the parties includes any marital
portion of Wife's IRA. The approximate value of Wife's IRA as of October 1, 2004 was
One Thousand Twenty-Five and 00/100 ($1,025.00) Dollars.
Husband further
acknowledges that he has been informed of his right to obtain an independent appraisal of
Wife's IRA, and any marital interest he may have therein, and, notwithstanding same,
Husband hereby forever waives and relinquisbes any right, title, interest or claim he might
otherwise have in and to Wife's aforesaid IRA.
Husband acknowledges that the marital property of the parties includes any marital
portion of Wife's 401K stemming from her employment with EDS. The approximate value
of Wife's 40lK as of October 1, 2004 was Thirty-Six Thousand One Hundred Eighty-Five
and 49/100 ($36,185.49) Dollars. Husband further acknowledges that he has been informed
of his right to obtain an independent appraisal of Wife's 401K, and any marital interest
therein, and, notwithstanding same, in exchange for Wife waiving her interest in and the
Rental Property, as well as for other good and valuable consideration, Husband hereby
forever waives and relinquishes any right, title, interest or claim he might otherwise have in
and to Wife's aforesaid 40lK through EDS
The parties specifically acknowledge and agree that their minor child, Jaden, has
seven (7) One Hundred ($100) Dollar Series EE savings bonds and two (2) Fifty ($50.00)
Dollar Series EE savings bonds, to which both Wif(~ and Husband have access. Both parties
specifically contemplate and agree that the minor child shall have these savings bonds to
cash in at the age of eighteen (18) years old. Additionally, the parties acknowledge that
they set up a stock account through Prudential for the benefit of their minor child, Jaden.
This m;;:~ be used for Jaden to pursue highl~r education.
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The parties agree that Wife
JRG -.\,2. C.
shall retain control of this account and shall ensure that the funds are available to Jaden if
and when she seeks to further her education.
The parties acknowledge that the marital property of the parties includes a jointly
owned account with Vanguard. The balance of this Vanguard account as of October 1,
2004, was Nineteen Thousand Three Hundred Twenty-Two and 30/100 ($19,322.30)
Dollars. The parties have agreed to equally divide this account.
Wife acknowledges that the marital property of the parties includes any marital
portion of Husband's 401K through his employment with Carlisle Syntec. The account
balance of Husband's 401K with Carlisle Syntec as of October 19, 2004 was One Hundred
Fifteen Thousand Nine Hundred Sixty-Eight and 39/100 ($115,968.39) Dollars. Wife
further acknowledges that she has been informed of her right to obtain an independent
appraisal of Husband's 401K, and any marital interest therein. In exchange for Wife
waiving her interest in and to Husband's 401K, Husband shall convey to Wife the sum of
Thirty-One Thousand Nine Hundred Thirteen and 16/100 ($31,913.16) Dollars from his
401K with Carlisle SynTec into a qualified account in Wife's name through the use of a
QDRO or otherwise, which sum of money shall become Wife's sole and separate property.
Husband shall, within thirty (30) days of the date of this Agreement, execute the necessary
paperwork to commence the roll-over process. Other than otherwise herein provided, Wife
hereby forever waives and relinquishes any right, title, interest or claim she might otherwise
have in and to Husband's aforesaid 401K.
The parties acknowledge that in addition to the accounts listed above, each of the
parties has a pension/retirement account through their respective current employers.
HUSb~~ledgeS that the marital property of the parties includes any marital portion
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of Wife's pension/retirement account stemming from her current employment with EDS.
Wife acknowledges that the marital property of the palties includes any marital portion of
Husband's pension/retirement account stemming from his current employment with Carlisle
Syntec. The parties acknowledge that he/she has been informed ofhislher right to obtain an
independent appraisal of their respective pension/retirement accounts, and, notwithstanding
same, each party hereunto the other, hereby waives and relinquishes any right, title, interest
or claim he or she might otherwise have in and to the other party's aforesaid
pension/retirement account with their respective current employer.
(8) LIFE INSURANCE: The parties ackn.owledge that Wife has a $282,000.00
term life insurance policy through her employment with EDS. Husband will be removed as
beneficiary of this life insurance policy upon entry of a Final Decree in Divorce and Wife
shall list Jaden, the parties' minor child, as irrevocable beneficiary under the policy. At no
time will Jaden's interest in the policy be less than Fi:lty (50%) Percent.
The parties further acknowledge that Wife, has a $50,000.00 whole life policy
through International Order of Foresters. Husband will be removed as beneficiary of this
life insurance policy upon entry of a Final Decree ill Divorce and Wife shall list Jaden, the
parties' minor child, as irrevocable beneficiary under the policy. At no time will Jaden's
interest in the policy be less than Fifty (50%) Percerlt.
The parties further acknowledge that Husband has a $180,000.00 life insurance
policy through United of Omaha Life Insurance. It is specifically contemplated and agreed
that Husband will retain this policy, specifically understanding that Husband may reduce
the coverage limits by up to Ninety Thousand ($90,000.00) Dollars, and will list Jaden, the
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Page 12 of24
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parties' minor child, as irrevocable beneficiary under the policy. At no time will laden's
interest in the policy be less than fifty (50"10) percent.
(9)
DMSION of BANK ACCOUNTS:
The parties acknowledge that
the balances of the parties joint checking and savings ilccount with Member's First Federal
Credit Union have been divided equally between the parties prior to the execution of this
Agreement. The joint checking and savings accounts are to be closed or transferred solely
into Husband's name within ten (10) days ofthe execution of this Agreement.
The parties further acknowledge that they have a joint checking and savings account
with Member's First Federal Credit Union, which account is used solely for the Rental
Property. Simultaneous with the execution of this Agreement, the parties agree to equally
divide the balances in these accounts, subtracting out the Five Hundred ($500.00) Dollar
tenant security deposit. The joint checking and savings accounts are to be closed or
transferred solely into Husband's name within ten (10) days of the execution of this
Agreement.
The parties further acknowledge that the minor child, laden, has a savings account
through Member's First Federal Credit Union. This account has been established for the
benefit of the parties' minor child. Both parties and the child have access to this account.
The account balance as of October 1, 2004 was Two Hundred Fifty ($250.00) Dollars. As
part of this settlement, Husband agrees to provide a minimum of One Hundred ($100.00)
Dollars per month to laden's account until she reached the age of 18 or graduates from high
school, whichever occurs last, for purposes of her pursuing a higher education. Husband
shall provide these payments to Wife no later than the 151h of the month and Wife shall
deptmis from Husband into laden's account.
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Wife will retain control of this
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account with the parties' minor child and Husband will be removed as an authorized
signatory on this account.
The parties further acknowledge that Wife has an additional savings account, on
which Husband is an authorizes signatory, with Member's First Federal Credit Union,
which as of October 1, 2004, had a balance of Four Hundred Eighty ($480.00) Dollars.
Husband hereby waives any right, title or interest he may have in and to said savings
account. This joint savings account is to be closed or transferred solely into Wife's name
within ten (10) days of the execution of this Agreement.
The parties further acknowledge that Husband has a savings account, which, as of
October I, 2004, had a balance of Two Thousand Four Hundred Eighty-One ($2,481.00)
Dollars. Wife hereby waives any right, title or interest she may have in and to this savings
account.
The parties further acknowledge that Wife opened a new checking and savings
account in anticipation of this separation. The balance of Wife's savings account as of
October 1, 2004 was Fifteen Thousand Nine Hundred ($15,900.00) Dollars and the balance
of Wife's checking account as of October 1, 2004 was One Thousand ($1,000.00) Dollars.
Husband hereby waives any right, title or interest he may have in and to Wife's checking
and savings account.
(10) WAIVER of ALIMONY: The parties acknowledge that each has income
and assets satisfactory to meet his and her own reasonable needs. Each party waives any
claim he or she may have, one against the other, for alimony, spousal support or alimony
pendente lite.
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(11) ATTORNEY'S FEES: Except as otherwise provided herein, each of
the parties waives the right to receive a payment for counsel fees from the other, and each
shall be responsible for his or her own counsel fees, costs and expenses, if such fees or
expenses are incurred.
(12) ADVICE of COUNSEL: The parties hereto acknowledge and declare
that each has had a full and fair opportunity to obtain independent legal advice of counsel of
their selection; that Wife has been independently repr,esented by Lindsay Gingrich Maclay,
Esquire, and that Husband has been independently represented by Michael A. Scherer,
Esquire.
Each party acknowledges and accepts that this agreement is, under the
circumstances, fair and equitable, and that it is being entered into freely and voluntarily
after having received such advice and with such knowledge as each has sought from
counsel, and the execution of this agreement is not the result of any duress or undue
influence, and that it is not the result of any improper or illegal agreement or agreements.
(13) ADDmONAL INSTRUMENTS: Except as otherwise herein provided,
each of the parties shall from time to time, at the request of the other, execute, acknowledge
and deliver to the other party, within five (5) days of any request to do so, any and all
further instruments that may be reasonably required to give full force and effect to the
provisions of this Agreement.
(14) INCOME TAX: The parties hereto agree to file a joint tax return for
2004, if it is in their best interest to do so, Should the parties file a joint return in 2004, the
parties hereby specifically agree to equally divide the tax return or liability, if any. Except
KMG~
Page 15 of24
JRG~
as otherwise herein provided, the parties hereto specificaIly foresee filing separate income
tax returns for all ongoing years, specifically including 2005 and 2006.
(15) TAX MATTERS: The parties have negotiated this Agreement with the
understanding and intention to divide their mutual property. The parties have determined
that such division of existing marital property is not, except as may otherwise be expressly
provided herein, intended by the parties to constitutt: in any way, a sale or exchange of
assets. It is understood that the property transfers described in this Agreement fall within
the provisions of Section 1041 of the Internal Revenue Code, and as such, will not result in
the recognition of any gain or loss upon the transfer by the transferor.
(16) BANKRUPTCY: The parties hereby agree that the provisions of this
Agreement shall not be dischargeable in Bankruptcy and expressly agree to reaffirm any
and all obligations contained herein. In the event a plUty files such banlcruptcy and pursuant
thereto obtains a discharge of any obligations assuml~d hereunder, the other party shall have
the right to declare this Agreement to be null and void and to terminate this Agreement in
which event the division of the parties' marital assets and all other rights determined by this
Agreement, including alimony, shall be subject to court determination the same as if this
Agreement had never been entered into.
(17) COMPLETE DISCLOSURE: The parties do hereby warrant,
represent, acknowledge and agree that each is fuHy and completely informed of, and is
familiar with, the wealth, real and personal property, estate and assets, earnings and income
of the other and has made any inquiry he or she desires into the income or estate of the other
KMG~'.
Page 160f24
JRG~
and received any such information requested. Each has made a full and complete disclosure
to the other of his and her entire assets, liabilities, inc:ome and expenses and any further
enumeration or statement thereof in this Agreement is specifically waived.
(18) WAIVER of APPRAISALS: The parties acknowledge that they are
aware of their respective rights pursuant to the Pennsylvania Divorce Code to obtain formal
valuations or appraisals of the real estate, the personal property, the vehicles, retirement
accounts and businesses, some or all of which wen: acquired during the marriage and
therefore constitute marital property. However, the parties have determined that they will
not undertake the expense to have these items appraised and/or valuated, and that the
division of property as set forth in this agreement, represents a fair and equitable
distribution.
(19) RIGHTS and RESPONSmILITIES:: Husband and Wife acknowledge that
each of them has read and understand his and her rights and responsibilities under this
Agreement and that they have executed this Agreement under no compulsion to do so but as
a voluntary act.
(20) FULL SETTLEMENT: Except as herein otherwise provided, each
party hereby releases the other from any and all daims, or demands up to the date of
execution hereof. It is further specifically understood and agreed by and between the
parties hereto that each party accepts the provisions herein made in lieu of and in full
settlement and satisfaction of any and all of said party's rights against the other for past,
present and future claims on account of spousal support, maintenance, alimony, alimony
KMG~
Page 17 of24
JRG~
pendente lite, counsel fees, costs and expenses, equitable distribution of marital property
and any other claims of the party, including all claims which have been raised or may be
raised in an action for divorce.
(21) RELEASE of ALL CLAIMS: Except as otherwise provided herein,
each party releases and discharges completely and forever the other from any and all right,
title, interest or claim of past, present or future spousal support, division of property,
including income of gain from property hereafter accruing, right of dower or curtesy, the
right to act as administrator or executor of the estate of the other, the right to a distributive
share of the other's estate, any right of exemption in the estate of the other, or any other
property rights, benefits or privileges accruing to either party by virtue of their marriage
relationship, or otherwise, whether the same are conferred by statutory or common law of
the Commonwealth of Pennsylvania, or any other state, or of the statutory or common law
of the United States of America. Except as provided herein, the parties specifically waive
any and all rights that they may have to equitable distribution of marital property and/or
alimony and counsel fees, except those counsel fees sought in the event of a breach of this
Agreement, or any other marital rights as provided in the Pennsylvania Divorce Code, Act
26 of 1980 or any amendment thereto.
It is further specifically understood and agreed by and between the parties hereto,
that each party accepts the provisions herein made in lieu of and in full settlement and
satisfaction of any and all of said parties' rights against the other for any past, present and
future claims on account of spousal support; maintenance; alimony; alimony pendente lite;
counsel fees, costs and expenses, except those coullsel fees, costs and/or expenses sought in
KMG t(mJj
Page 18 of24
JRG~_
the event of a breach of this Agreement; equitable distribution of marital property and any
other claims of each party, including aU claims raised by them in the Divorce action to be
filed between the parties.
(22) SEPARABILITY of PROVISIONS:
The parties agree that the
separate obligations contained in this agreement shall be deemed to be interdependent. If
any term, condition, clause or provision of this agreement shaU be determined by a court of
competent jurisdiction to be invalid or unenforceable, then the parties agree that the
agreement may be reviewed and re-negotiated in order to fulfill, as closely as possible, the
purpose of the invalid provision. Notwithstanding any releases contained herein, the parties
intend that they may reinstate previously pleaded economic claims to the extent permitted
by the Divorce Code.
(23) GOVERNING LAW:
All matlers affecting the interpretation of this
Agreement and the rights of the parties hereto shall be governed by the laws of the
Commonwealth of Pennsylvania.
(24) INCORPORATION into DIVORCE DECREE: The Parties agree that
this Agreement shall continue in full force and effi:ct after such time as a final Decree in
Divorce may be entered with respect to the parties. Upon entry of the Decree, the
provisions of this Agreement shall be incorporated by reference or in substance, but they
shall not be deemed merged into such Decree. The Agreement shall survive any such
Decree in Divorce, shaU be independent thereof, and the parties intend that all obligations
contained in this Agreement shaU retain their contractual nature in any enforcement
proceedings, whether enforcement is sought in an action on the contract itself at law or in
equity, or in any enforcement action filed to the Divorce Caption.
KMG ~ mid--- Page 19 of 24
JRGA
(25) BREACH: In the event that either party breaches any provision of this
Agreement, he or she shall be responsible for any and all costs incurred to enforce the
Agreement, including, but not limited to, court cost and counsel fees of the other party. In
the event of breach, the other party shall have the right, at his or her election; to sue for
damages for such breach or to seek such other and additional remedies as may be available
to him or her.
(26) ENTIRE UNDERSTANDING:
This Agreement constitutes the entire
understanding between the parties and there are no covenants, conditions, representations,
or agreements, oral or written, of any nature whatsoever, other tl1an those herein contained.
(27) AGREEMENT BINDING on PARTIES and HEIRS: It is understood
and agreed that not only the parties hereto, but also their heirs, administrators, executors and
assigns, shall be bound by all the terms, conditions and clauses of this Agreement.
IN WITNESS WHEREOF, the parties hereto, intending to be legally bound
hereby, have hereunto set their hands and seals to this Agreement the day and year first
above written.
WITNESS:
~~.~_.
!t1&r tt /i1,
.
~~7JJ
Karen . Gage
~_ f 0'1
!a s R. Gage
;;7)
KMG ~21i--
Page 20 of 24
JRGL-
Exhibit "A::
Oak Computer Desk (in den)
Oak 2-Drawer Filing Cabinet (in den)
Computer and Printer (in den)
Washer and Dryer
Oak Bar Stools (if the prospective buyer of the Marital Home does not want)
Toaster Oven
Kitchen Cabinet Counter-Top Microwave
Family Room Couch/Sleeper Sofa
Family Room Orange ReclinerlRocker
Family Room Coffee Tables (2)
Family Room Oak Entertainment Center
Stereo Equipment in Entertainment Center
Television in Entertainment Center
Waterbed in Front Bedroom
Bookcase in Front Bedroom
Television in Front Bedroom
Back Bedroom Desk
VCR in Master Bedroom
Entertainment Center in Basement
Majority of Tools/Work Bench in Basement (see Exhibit "B" for clarification)
Hand-Pushed Lawnmower
Scaffolding
Lawn Blower/Weed Wacker - CII,4,~ Sllr..:>J,l (;. f(JA.JA
Floor Safe
Ping Pong Table
Jewelry (each shall retain their own jewelry) ....v.. t~
~ and W Extension Ladders ~ '(I J l c.. fV"''''
John Deere Snowblower
Kabota Tractor (LA 350A Model) with Lawn Desk, Front-End Loader, Spreader
and Various Other Implements
- (.. ~ B', 10' -r I),' -5 f?1 (.I4PIkYJ.1JR-(.1~
- lC(,J,- SI-zr ~l'llL ~ f6rt.()
- A-u........,........... j1~- J..y' -;(}1t.4.
I.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
KMG '1>>ij
Page 21 of24
JRG -JJ2h
Exhibit "B~
1. Dining Room Furniture (includes table w/ Ilmves, 6 chairs, buffet, china cabinet,
pictures, china and silverware)
2. Oak Roll-Top Desk
3. WoodTable(inDen)
4. Round Oak Kitchen Table and Chairs
5. Oak Ice Box
6. Oak Chair in Kitchen (desk)
7. Kitchen Aid Mixer and Stand
8. Coffee Maker and Miscellaneous Kitchen Gadgets (hand-held mixers, etc.)
9. Canister Set/Kitchen Decorations
10. Wood Foyer Tables (2)
11. Mirror (in Foyer)
12. Plant (in Foyer)
13. Persian Rug (in Foyer)
14. Oak Curio Cabinet and Contents Thefeof(in Foyer)
15. Family Room Beige ReclinerIRocker
16. DVDNCR Player in Entertainment Center
17. Small Oak Video/Curio Cabinet (in Family Room)
18. Comer Desk in Front Bedroom
19. Sewing Machine in Front Bedroom
20. Victrola in Front Bedroom
21. Jaden's Bedroom Furniture, including lamps and pictures
22. Television and Stand in Jaden's Room
23. Back Bedroom Furniture, including lamps and pictures
24. Master Bedroom Furniture, including lamps and pictures
25. Master Bedroom Jewelry Armoire
26. Master Bedroom Television and Stand
27. Nordic Track in Front Bedroom
28. Christmas Decorations and Lights (except 9' artificial tree)
29. Tools (good drill, electric hand saw, tool box with basic tools - hammer,
screwdrivers, etc.)
30. Black Shelves in Pool Area
31. Picnic Table and Benches
32. Gas Patio Grill
33. Bumper Pool Table
34. Carpet Cleaner
35. DVD Camera
36. Refrigerator in Garage
37. Jewelry (each shall retain their own jewelry)
38..&'- and l%" ladder and Kitchen Step Stool ~
KMG~
Page 22 of 24
JRG:JjL
Exhibit "c::,
I. Pots & Pans
2. Dishes
3 . Glasses
4. Silverware
5. Round Tables Used for Nightstands in the Front Bedroom
6. Jaden's Toys (It is contemplated that her toys be split between the 2 houses per
Jaden's request)
7. Oak Unfinished Bookcases in Basement (2)
8. Lawn Chairs
9. Garden Tools
10. Pictures
11. Artificial Plants and Trees
12. Towels
13. Blankets
14. Sheets
15. Lamps not specifically previously included in other Exhibits
KMG
Page 23 of 24
JRGDK
'. .
."
Exhibit "D"
1. Mailer Bedroom King-Sized Ben (th;S item L~ tv b" sOld and th" 1'10""..d~ flOm lh~
sale di, i.ied c.:J.t1ally \!et';;eell ~e patties) ~ (l Co
2. Althnin:t1~d Plank ifl Peal ANa ~tb;1 itsm ~ag ~e iSE!lwded in IiUIlp. of ,house if
ad ,.....h.e;"""~' ~viSll, sllll ami dj,<iQe jlf6(;{,c:ds) J tc
KMdilM
Page 24 of24
JRG$
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
KAREN M. GAGE,
Plaintiff
No. 2004 - 5571
v.
CIVIL ACTION - LAW
JAMES R. GAGE,
Defendant
(In Divorce)
AFFIDAVIT OF CONSENT
COMMONWEALTH OF PENNSYL VANIA )
SS.
COUNTY OF CUMBERLAND
)
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
November 5, 2004.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final Decree in Divorce after service of the Notice of
Intention to Request Entry of a Divorce Decree.
I verify that the statements made in this Affidavit are true and correct to the best of my
knowledge, information, and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C. S., Section 4904 relating to unsworn falsification to
authorities.
Date:
--6/11/05
~ Ji
(jyLL'7'-m.. .
Karen . Gage, Plaintiff J
fl
-
Sworn to and subscribed before me this
1\ c\\ day of ,\ ,.\ \C" , 2005.
\ \'Y" \ . \,'~ \. '\ 'i: ~ \",-;-, {~.~\ '\'-;<;'1-.'-
, Notary Public
COMMONWEALTH OF PE SYLVANIA
Notarial Seal
Michelle M. Bross, Notary Public
Derry Twp., Dauphin County
M Commission Ex ires Se t. 23, 2006
Member. Pennsylvania Association of Notaries
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
KAREN M. GAGE,
Plaintiff
No. 2004 - 5571
v.
CIVIL ACTION - LAW
JAMES R GAGE,
Defendant
(In Divorce)
AFFIDAVIT OF CONSENT
COMMONWEALTH OF PENNSYL VANIA )
SS.
COUNTY OF CUMBERLAND
)
I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
November 5, 2004.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date offiling and service of the Complaint.
3. I consent to the entry of a final Decree in Divorce after service of the Notice of
Intention to Request Entry of a Divorce Decree.
I verify that the statements made in this Affidavit are true and correct to the best of my
knowledge, information, and belief I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S., Section 4904 relating to unsworn falsification to
authorities.
Date: '5./7. oS-
rt-I!J/~c
s R. Gage, Defendant
Sworn to and subscribed before me this
_day of ,2005.
, Notary Public
-
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
KAREN M. GAGE,
Plaintiff
No. 2004 - 5571
v.
CIVIL ACTION - LAW
JAMES R GAGE,
Defendant
(In Divorce)
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY
OF A DIVORCE DECREE UNDER 113301(d OF THE DIVORCE CODE
I. 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 I further understand 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 to the best of my
knowledge, information, and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities.
Date: 3 .,..,.~s--
J
IN mE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
KAREN M. GAGE,
Plaintiff
No. 2004 - 5571
v.
CIVIL ACTION - LAW
JAMES R. GAGE,
Defendant
(In Divorce)
PRAECIPE TO TRANSMIT RECORD
TOTHEPROmONOTARY:
Please transmit the Record, together with the following information, to the Court for
entry of a Decree in Divorce:
1. Ground for Divorce: irretrievable breakdown under Section 3301(c) of the Divorce
Code.
2. Date and manner of service of the Complaint: Defendant Accepted Service of the
Complaint, which had been filed on November 5, 2004, by signing an Acceptance
of Service on November 6, 2004. Said Acceptance was filed at the above-
referenced docket number on January 26,2005.
3. As required by Section 3301(c) of the Divorce Code, Plaintiff executed her
Affidavit on March 11, 2005 and filed same on March 15, 2005. Defendant
executed his Affidavit on March 17,2005 and filed same on March 18,2005.
4. Related claims pending: None. A Property Separation and Settlement Agreement
was executed on January 20, 2005 and filed on January 26,2005.
5. As required by Section 3301(c) of the Divorce Code, Plaintiff executed her Waiver
of Notice of Intention to Request Entry of Divorce Decree on March 11,2005, and
filed same on March 15,2005. Defendant executed his Waiver on March 17, 2005
and filed same on March 18,2005.
Date: ~
By:
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IN THE COURT OF COMMON PLEAS
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OFCUMBERLANDCOUNTY
KAREN M. GI\GE
PENNA.
STATE OF
No.
2004-5571
VERSUS
.JAMES R. GI\GE
DECREE IN
DIVORCE
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AND NOW,
, IT is ORDERED AND
Karen M. Gage
DECREED THAT
, PLAINTIFF,
James R. Gage
AND
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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;
The Property Settlement and Separation Aqreement dated January 20, 2005,is
incor
Divorce.
ATT"T~~
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PROTHONOTARY
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KAREN M. GAGE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 2004-5571 CIVIL TERM
JAMES R. GAGE,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
ORDER OF COURT
AND NOW, this
of
, 2005, upon consideration of the
within Stipulation for Entry of a Qualified Domestic Relations Order, the following is
hereby entered as a Qualified Domestic Relation Order:
CARLISLE CORPORATION EMPLOYEE INCENTIVE SAVINGS PLAN
I
I
I
I
I
I ~ 1.1. Account - The Participant's entire interest in the Plan whether or not
i i vested.
il
QUALIFIED DOMESTIC RELATIONS ORDER
~ 1. Definitions. For the purposes of this section 1 and the following sections 2
through 4 of this domestic relations order, the following terms, when used with initial
capital letters, shall have the following meanings.
~ 1.2. Alternate Payee - The following person:
Name:
Last Known Mailing Address:
Karen M. Gage
397 Chestnut Street
Boiling SorinQs. PA 17007
Social Security Number:
Date of Birth:
296-64-7907
AUQust 17. 1959
II
- \'
~ 1.3. Distribution Date - Distribution will be made as soon as administratively
feasible after the Plan Administrator formally and finally determines that this domestic
relations order constitutes a qualified domestic relations order and all appropriate time
for appeals under the claims procedure of the Plan applicable to domestic relations
orders has expired.
~ 1.4. Participant - The following person:
Name:
Last Known Mailing Address:
James R. Gaae
P.O. Box 21
Grantham. PA 17027
Social Security Number:
Date of Birth:
Employee Number:
168-54-3663
October 18. 1960
6601
~ 1.5. Plan - The qualified defined 401(k) plan: Carlisle Corporation Employee
Incentive Savings.
~ 1.6. Plan Administrator - The following:
Wachovia Retirement Services
1525 West W. T. Harris Blvd.
Building 3C5
Charlotte. NC 28288
I
I
II ~ 2.
I
II
I
Award To Alternate Payee.
~ 2.1. Time and Amount of Payment. As soon as may be administratively
feasible after the Distribution Date, the Plan Administrator shall cause the trustee of the
Plan to distribute to the Alternate Payee $ 25,000.00 of the Account irrespective of the
Participant's Vested Account as of the Distribution Date. The amount awarded to the
Alternate Payee shall not be adjusted for investment gains and/or losses from the date
of this Order to the Distribution Date.
~ 2.2. Form of Payment. Distribution from the Account to the Alternate Payee
shall be made in a single lump sum payment in cash. The Alternate Payee shall not be
permitted to elect any other form or time of distribution even if it would be otherwise
available under the Plan. Upon the completion of this distribution to the Alternate
Payee, the Plan shall have no further obligation to make any further distributions from
the Account to the Alternate Payee.
II
~ 2.3. Limitation Rules. The value of the Participant's Account as of the
Distribution Date shall be determined excluding: (I) any portion which has been, before
such Distribution Date, distributed from the Plan to (or with respect to) the Participant,
and (ii) any portion which has been awarded to any other alternate payee under any
other domestic relations order which was determined to be a qualified domestic
relations order before the date this domestic relations order is determined to be a
qualified domestic relations order. The value of the Participant's Account shall be
determined as of the Distribution Date including all amounts which are then accrued for
contribution to the Account (whether from contributions of the Participant or a sponsor
of the Plan) under generally accepted accounting principles (whether or not such
contributions have in fact been received by the trustee of the Plan as of such
Distribution Date).
~ 3. Miscellaneous Substantive Provisions. The Alternate Payee shall not be
deemed or considered to be a spouse, former spouse or surviving spouse of the
Participant for any purpose of the Plan. The Plan Administrator may, but shall not be
required to, cause the trustee of the Plan to segregate in a separate account under the
Plan the amount awarded to the Alternate Payee under this domestic relations order
pending its actual distribution to the Alternate Payee. To the extent that the Account of
the Participant consists of monies coming from different sources or monies that have
been divided for investment purposes into different classes or categories of
investments, the Plan Administrator shall cause the trustee to withdraw the monies for
distribution to the Alternate Payee in reasonable proportion to such sources and
investments as they exist on the Distribution Date (if the amount awarded to the
Alternate Payee has not been previously segregated). Except as hereinafter provided,
the distribution shall be made only to the Alternate Payee. If the Alternate Payee dies
after this order is entered but before the date actual distribution is made to the Alternate
Payee, distribution of the benefit awarded to the Alternate Payee under this order shall
be made in accordance with the Plan provisions. If the Plan Administrator has actual
knowledge of the appointment by a court of competent jurisdiction of a guardian,
conservator or similar court appointed fiduciary having responsibility for the Alternate
Payee's financial affairs, the distribution shall be made only to such court appointed
fiduciary. For all purposes of the Plan, the Participant's Account (and all benefits
payable under the Plan which are derived in whole or in part by reference to the
Participant's Account) shall be permanently diminished by the portion of the
Participant's Account which is awarded to the Alternate Payee.
II
I ,~ ..
~ 4. Miscellaneous Procedural Provisions. Upon entry of this domestic relations
order, the Alternate Payee shall deliver to the Plan Administrator a certified copy of this
domestic relations order and shall simultaneously furnish the Participant with evidence
of such delivery. The Alternate Payee shall be responsible for the payment of all state
and federal income taxes on amounts awarded to and paid to the Alternate Payee
under this domestic relations order. The Alternate Payee shall file all elections,
applications or other forms required by the Plan Administrator in connection with the
distribution contemplated by this domestic relations order. The Participant shall
cooperate fully with the Plan and the Alternate Payee in executing such documents and
taking all other actions which may be necessary or required by the Plan Administrator
for the purpose of causing the distribution to the Alternate Payee which is contemplated
by this domestic relations order. The Participant and the Alternate Payee may notify
the Plan Administrator in writing that copies of notices to the Participant or the Alternate
Payee, as the case may be, should be sent to a designated representative. Upon
receipt of such notice, the Plan Administrator shall give copies of notices sent by the
Plan Administrator to the Participant or Alternate Payee, as the case may be, to that
representative. To the extent the Plan makes a reasonable and good faith effort to
observe the terms of this domestic relations order in making the distribution to the
Alternate Payee contemplated by this domestic relations order, the Plan, the Plan
Administrator and every fiduciary of the Plan shall be deemed to have fully satisfied
their obligations to the Participant and the Alternate Payee (and their successors and
assigns) and shall be fully discharged from any further liability to the Participant and the
Alternate Payee (and their successors and assigns) with respect to such distribution.
BY THE COURT,
J.
:1
STIPULATION
Karen M. Gage, through her counsel, Lindsay Gingrich Maclay, Esquire, and
James R. Gage, through his counsel, Michael A. Scherer, Esquire, stipulate to the
foregoing being entered as a Qualified Domestic Relations Order.
mi~fVL-
Michael A. Scherer, Esquire
Attorney for James R. Gage
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Date:
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Date:
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RECtl'lED MAY 18 2~~
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2004-5571 CIVIL TERM
KAREN M. GAGE,
V.
Defendant
CIVIL ACTION-LAW
IN DIVORCE
JAMES R. GAGE,
ORDER OF COURT
AND NOW, this ,) j
of
fYLj
, 2005, upon consideration of the
within Stipulation for Entry of a Qualified Domestic Relations Order, the following is
hereby entered as a Qualified Domestic Relation Order:
CARLISLE CORPORATION EMPLOYEE INCENTIVE SAVINGS PLAN
QUALIFIED DOMESTIC RELATIONS ORDER
~ 1. Definitions. For the purposes of this section 1 and the following sections 2
through 4 of this domestic relations order, the following terms, when used with initial
capital letters, shall have the following meanings.
~ 1.1. Account - The Participant's entire interest in the Plan whether or not
vested.
~ 1.2. Alternate Payee - The following person:
Name:
Last Known Mailing Address:
Karen M. Gaae
397 Chestnut Street
Boilina Sorinas. PA 17007
296-64-7907
Auaust 17. 1959
Social Security Number:
Date of Birth:
11
~ 1.3. Distribution Date - Distribution will be made as soon as administratively
feasible after the Plan Administrator formally and finally determines that this domestic
relations order constitutes a qualified domestic relations order and all appropriate time
for appeals under the claims procedure of the Plan applicable to domestic relations
orders has expired.
~ 1.4. Participant - The following person:
Name:
Last Known Mailing Address:
James R. GaQe
P.O. Box 21
Grantham. PA 17027
Social Security Number:
Date of Birth:
Employee Number:
168-54-3663
October 18. 1960
6601
~ 1.5. Plan - The qualified defined 401 (k) plan: Carlisle Corporation Employee
Incentive Savings.
~ 1.6. Plan Administrator - The following:
Wachovia Retirement Services
1525 West W. T. Harris Blvd.
Building 3C5
Charlotte, NC 28288
I
I ~ 2.
:1
I
II
I
I
Award To Alternate Payee.
~ 2.1. Time and Amount of Payment. As soon as may be administratively
feasible after the Distribution Date, the Plan Administrator shall cause the trustee of the
Plan to distribute to the Alternate Payee $ 25,000.00 of the Account irrespective of the
Participant's Vested Account as of the Distribution Date. The amount awarded to the
Alternate Payee shall not be adjusted for investment gains and/or losses from the date
of this Order to the Distribution Date.
~ 2.2. Form of Payment. Distribution from the Account to the Alternate Payee
shall be made in a single lump sum payment in cash. The Alternate Payee shall not be
permitted to elect any other form or time of distribution even if it would be otherwise
available under the Plan. Upon the completion of this distribution to the Alternate
Payee, the Plan shall have no further obligation to make any further distributions from
the Account to the Alternate Payee.
II
~ 2.3. Limitation Rules. The value of the Participant's Account as of the
Distribution Date shall be determined excluding: (/) any portion which has been, before
such Distribution Date, distributed from the Plan to (or with respect to) the Participant,
and (ii) any portion which has been awarded to any other alternate payee under any
other domestic relations order which was determined to be a qualified domestic
relations order before the date this domestic relations order is determined to be a
qualified domestic relations order. The value of the Participant's Account shall be
determined as of the Distribution Date including all amounts which are then accrued for
contribution to the Account (whether from contributions of the Participant or a sponsor
of the Plan) under generally accepted accounting principles (whether or not such
contributions have in fact been received by the trustee of the Plan as of such
Distribution Date).
~ 3. Miscellaneous Substantive Provisions. The Alternate Payee shall not be
deemed or considered to be a spouse, former spouse or surviving spouse of the
Participant for any purpose of the Plan. The Plan Administrator may, but shall not be
required to, cause the trustee of the Plan to segregate in a separate account under the
Plan the amount awarded to the Alternate Payee under this domestic relations order
pending its actual distribution to the Alternate Payee. To the extent that the Account of
the Participant consists of monies coming from different sources or monies that have
been divided for investment purposes into different classes or categories of
investments, the Plan Administrator shall cause the trustee to withdraw the monies for
distribution to the Alternate Payee in reasonable proportion to such sources and
investments as they exist on the Distribution Date (if the amount awarded to the
I Alternate Payee has not been previously segregated). Except as hereinafter provided,
[I
I the distribution shall be made only to the Alternate Payee. If the Alternate Payee dies
II after this order is entered but before the date actual distribution is made to the Alternate
1'1 Payee, distribution of the benefit awarded to the Alternate Payee under this order shall
be made in accordance with the Plan provisions. If the Plan Administrator has actual
I knowledge of the appointment by a court of competent jurisdiction of a guardian,
II conservator or similar court appointed fiduciary having responsibility for the Alternate
I Payee's financial affairs, the distribution shall be made only to such court appointed
I fiduciary. For all purposes of the Plan, the Participant's Account (and all benefits
I payable under the Plan which are derived in whole or in part by reference to the
Participant's Account) shall be permanently diminished by the portion of the
Participant's Account which is awarded to the Alternate Payee.
II
.
~
I'
~ 4. Miscellaneous Procedural Provisions. Upon entry of this domestic relations
order, the Alternate Payee shall deliver to the Plan Administrator a certified copy of this
domestic relations order and shall simultaneously furnish the Participant with evidence
of such delivery. The Alternate Payee shall be responsible for the payment of all state
and federal income taxes on amounts awarded to and paid to the Alternate Payee
under this domestic relations order. The Alternate Payee shall file all elections,
applications or other forms required by the Plan Administrator in connection with the
distribution contemplated by this domestic relations order. The Participant shall
cooperate fully with the Plan and the Alternate Payee in executing such documents and
taking all other actions which may be necessary or required by the Plan Administrator
for the purpose of causing the distribution to the Alternate Payee which is contemplated
by this domestic relations order. The Participant and the Alternate Payee may notify
the Plan Administrator in writing that copies of notices to the Participant or the Alternate
Payee, as the case may be, should be sent to a designated representative. Upon
receipt of such notice, the Plan Administrator shall give copies of notices sent by the
Plan Administrator to the Participant or Alternate Payee, as the case may be, to that
I representative. To the extent the Plan makes a reasonable and good faith effort to
observe the terms of this domestic relations order in making the distribution to the
I Alternate Payee contemplated by this domestic relations order, the Plan, the Plan
Administrator and every fiduciary of the Plan shall be deemed to have fully satisfied
their obligations to the Participant and the Alternate Payee (and their successors and
I assigns) and shall be fully discharged from any further liability to the Participant and the
Alternate Payee (and their successors and assi with respect to such distribution.
I
'I
,I
!i
J.
STIPULATION
Karen M. Gage, through her counsel, Lindsay Gingrich Maclay, Esquire, and
James R. Gage, through his counsel, Michael A. Scherer, Esquire, stipulate to the
foregoing being entered as a Qualified Domestic Relations Order.
mAr.~f0-
Michael A. Scherer, Esquire
Attorney for James R. Gage
.~
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Date:
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Date: .s/u,los:
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