HomeMy WebLinkAbout04-6448
CANDACE J. CLARK,
Plaintiff
vs.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
; NO. 2004- lottl{f CIVIL TERM
JAYF. CLARK,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
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 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
marriage, you must request marriage counseling. A list of marriage counselors is avail-
able in the Office of the Prothonotary at
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR
ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF
THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLffiLE, PENNSY~:~
MAX J. SMITH, JR:., Esquire
JARAD W. HANDELMAN, Esquire
Attorney for Plaintiff
P.O. Box 650
Hershey, P A 17033
(717) 533-3280
CANDACE J. CLARK,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 2004- ~44r CIVIL TERM
JAYF. CLARK,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the Plaintiff, CANDACE J. CLARK, by her attorney, MAX 1.
SMITH, JR., Esquire, and seeks to obtain a Decree in Divorce upon the grounds hereinafter more
fully set forth:
1. The Plaintiff, CANDACE J. CLARK, is an adult individual and citizen of the
United States of America, whose address is 1315 English Drive, Mechanicsburg, Cumberland
County, Pennsylvania 17055.
2. The Defendant, JAY F. CLARK, is an adult individual and citizen of the United
States of America, whose address is 2159 Bordeaux Court, Harrisburg, Dauphin County, Penn-
sylvania 17112.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six (6) months immediately previous to the filing ofthis Complaint.
4. Plaintiff and Defendant were married on or about March 4, 1978 in Lakeland,
Florida.
5. Plaintiff avers that there are no children of the parties under the age of 18.
6. Neither Plaintiff nor Defendant is a member of the United States Armed Services.
7. Plaintiff and Defendant have both been advised of the availability of marital
counseling and that each may have the right to request that the court require the parties to
participate in counseling.
8. Plaintiff avers that there has been no prior action for divorce or annulment of
the marriage filed by either party in this or any other jurisdiction.
9. Plaintiff avers that the marriage is irretrievably broken.
WHEREFORE, Plaintiff prays your Honorable Court to enter a Decree of Divorce from
the bonds of matrimony.
COUNT II - EQUlT ABLE DISTRIBUTION
10. Paragraphs one (1) through nine (9) are incorporated herein by reference as though
set forth in full.
11. Plaintiff and Defendant have legally and beneficially acquired property, both real
and personal, during their marriage, which property is "marital property".
12. Plaintiff and Defendant may have owned prior to the marriage property, both real
and personal, which property has increased in value during the marriage and/or which has been
exchanged for other property, which has increased in value during the marriage, all of which is
"marital property".
13. Plaintiff and Defendant have been unable to agree as to an equitable division of
said property to the date of the filing of this Complaint.
WHEREFORE, Plaintiff requests the Court to equitably divide all marital property.
COUNT III - ALIMONY
14. Paragraphs one (1) through thirteen (13) are incorporated herein by reference as
though set forth in full.
15. Plaintiff lacks sufficient property to provide for her reasonable means and is
unable to adequately support herself through appropriate employment.
16. Plaintiff requests reasonable support to adequately maintain herself in accordance
with the standard of living established during the marriage.
WHEREFORE, Plaintiff requests the Court to enter an award of reasonable temporary
alimony and additional sums as they may become necessary from time to time hereafter until
final hearing and permanently thereafter.
COUNT IV - ALIMONY PENDENTE LITE, COUNSEL FEES AND EXPENSES
17. Paragraphs one (1) through sixteen (16) are incorporated herein by reference as
though set forth in full.
18. Plaintiff is without adequate funds to pay the costs and expenses of this litigation,
and is, likewise, without funds to maintain herself during the pendency of this litigation.
WHEREFORE, Plaintiff requests the Court to enter an Order requiring Defendant to pay
Plaintiff alimony pendente lite, counsel fees and expenses of the litigation.
Respectfully submitted,
Date: December tL-- , 2004
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MAX 1. SMITH, ;"(j Esqurre
J.D. No. 32114
JARAD W. HANDELMAN, Esquire
I.D. No. 82629
James, Smith, Dietterick & Connelly LLP
P.O. Box 650
Hershey, P A 17033
(717) 533-3280
I verify that the statements made in this Complaint are true and correct. 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.
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CANDACE J. CLARK,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 2004-6448 CIVIL TERM
JAY F. CLARK,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this 7th day of January, 2005, I, MAX J. SMITH, JR., Esquire, Attorney for
Plaintiff, hereby certify that I have this day sent a copy of Complaint in Divorce by depositing a
certified copy of the same in the United States mail, postage prepaid, certified mail #7003 2260
000565529152 at Hershey, Pennsylvania, addressed to:
Jay F. Clark
2159 Bordeaux Court
Harrisburg,PA 17112
Mailing and return receipt cards attached hereto.
an0~~oo,
I.D. No. 32114
JARAD W. HANDELMAN, Esquire
I.D. No. 82629
James, Smith, Dietterick & Connelly LLP
P.O. Box 650
Hershey, P A 17033
(717) 533-3280
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MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT made this2b ~ day of -.fjp (tL , 2006, by
and between JAY F. CLARK, 2159 Bordeaux Court, Harrisburg, Dauphin County,
Pennsylvania (hereinafter referred to as "Husband"), and CANDACE J. CLARK, 1315
English Drive, Mechanicsburg, Cumberland County, Pennsylvania (hereinafter referred
to as "Wife"),
WITNESSETH:
WHEREAS, the parties hereto are husband and wife, having been lawfully
married on March 4,1978 in Lakeland, Florida.
WHEREAS, the parties hereto are desirous of settling 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, and in general, the settling of any and all
claims and possible claims by one against the other or against their respective estates.
AND NOW, THEREFORE, in consideration of these premises, and of the mutual
promises, covenants, and undertakings hereinafter set forth, and for other good and
valuable consideration, receipt and sufficiency of which is hereby acknowledged by
each of the parties hereto, Husband and Wife, each intending to be legally bound
hereby, covenant and agree as follows:
1. ADVICE OF COUNSEL. The provisions of this Agreement and their legal
effect have been fully explained to the parties by their respective counsel, Debra D.
Cantor, Esquire, of McNees Wallace & Nurick LLC, for Husband, and Max J. Smith, Jr.,
Esquire of James, Smith, Dietterick & Connelly, LLP, for Wife. Each party
acknowledges that he or she has received independent legal advice from counsel of his
or her selection, and that each fully understands the facts and has been fully informed
as to his or her legal rights and obligations, and each party acknowledges and accepts
that this Agreement is, in the circumstances, fair and equitable, and that it is being
entered into freely and voluntarily, after having received such advice and with such
knowledge, and that 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. In addition, each party hereto acknowledges that he or she has been fully
advised by his or her respective attorney of the impact of the Pennsylvania Divorce
Code, whereby the court has the right and duty to determine all marital rights of the
parties including divorce, alimony, alimony pendente lite, equitable distribution of all
marital property or property owned or possessed individually by the other, counsel fees
and costs of litigation and, fully knowing the same and being fully advised of his or her
rights thereunder, each party hereto still desires to execute this Agreement,
acknowledging that the terms and conditions set forth herein are fair, just and equitable
to each of the parties, and waives his and her respective right to have the Court of
Common Pleas of Cumberland County, or any other court of competent jurisdiction,
make any determination or order affecting the respective parties' rights to a divorce,
alimony, alimony pendente lite, equitable distribution of all marital property, counsel fees
and costs of litigation.
-2-
2. DISCLOSURE OF ASSETS. Each of the parties hereto acknowledges
that he or she is aware of his or her right to seek discovery, including but not limited to,
written interrogatories, motions for production of documents, the taking of oral
depositions, the filing of inventories, and all other means of discovery permitted under
the Pennsylvania Divorce Code or the Pennsylvania Rules of Civil Procedure. Each of
the parties further acknowledges that he or she has discussed with counsel the concept
of marital property under Pennsylvania law and each is aware of his or her right to have
the real and/or personal property, estate and assets, earnings and income of the other
assessed or evaluated by the court of this Commonwealth or any other court of
competent jurisdiction. Husband and Wife represent and warrant that each has
disclosed to the other in full his or her respective assets, liabilities and income and that
this Agreement was negotiated and entered into on the basis of those disclosures. The
parties hereby acknowledge and agree that the division of assets as set forth in this
Agreement is fair, reasonable and equitable and is satisfactory to them. The remedies
available to either party for breach or violation of this provision shall be those remedies
available pursuant to law and equity. Each party retains the right to assert a claim
against the other for failure to fully and fairly disclose his or her income, assets and
liabilities, if it is later determined that there has been a failure to disclose, including but
not limited to a claim of constructive trust.
3. PERSONAL RIGHTS. Husband and Wife may and shall, at all times
hereafter, live separate and apart. Each shall be free from all control, restraint,
interference and authority, direct or indirect, by the other in all respects as fully as if he
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or she were unmarried. Each may reside at such place or places as he or she may
select. Each may, for his or her separate use or benefit, conduct, carry on or engage in
any business, occupation, profession or employment which to him or her may seem
advisable. This provision shall not be taken, however, to be an admission on the part of
either Husband or Wife of the lawfulness of the cause, which led to or resulted in the
continuation of their living apart. Husband and Wife 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
him or her. Neither party will interfere with the use, ownership, enjoyment or disposition
of any property now owned by or hereafter acquired by the other.
4. MUTUAL CONSENT DIVORCE. Wife has filed an action for divorce in
Cumberland County, Pennsylvania filed to No. 2004-6448. Said action shall be limited
to divorce and neither party may assert any ancillary economic claims otherwise
authorized by the Divorce Code, which are specifically waived by the terms of this
Agreement. Counsel for Wife shall execute a Praecipe withdrawing all such ancillary
claims now pending of record at or prior to the execution of this Agreement. The parties
agree that each shall sign and have duly acknowledged an Affidavit of Consent to a
divorce and a Waiver of Notice upon execution of this Agreement. Said Affidavits and
Waivers shall be promptly transmitted to counsel for Wife who will promptly file a
Praecipe to Transmit Record and Vital Statistics form to precipitate the prompt entry of a
decree of divorce.
-4-
5. EQUITABLE DISTRIBUTION.
5.1. Marital Home. The parties acknowledge that they were the joint
owners of that certain house and lot and all improvements thereupon situated at 608
Gale Road, Camp Hill, Cumberland County, Pennsylvania (the "Marital Home). The
parties sold the Marital Home on September 15, 2005, which yielded net proceeds of
$58,747.81. Approximately $46,600 of the net proceeds from the sale of the Marital
Home was used to purchase real property at 2159 Bordeaux Court, Harrisburg, Dauphin
County, Pennsylvania ("Husband's Home"), which is titled in Husband's name solely.
The remainder of the net proceeds from the sale of the Marital Home was used to
satisfy marital obligations. Wife does hereby set over, transfer and assign to Husband
any and all of her right, title, claim and interest in and to all or any portion of Husband's
Home. Husband agrees to be fully responsible and to indemnify and hold Wife
harmless from any and all liability for or encumbering Husband's Home, including, but
not limited to any mortgage or home equity loan encumbering Husband's Home.
5.2. Contents of Wife's Residence, Contents of Husband's Residence
and Other Personal Propertv.
5.2.1. Husband shall and does hereby set over, transfer and assign
to Wife all of his right, title, claim and interest in and to all of the contents of the
residence at 1315 English Drive, Mechanicsburg, Cumberland County, Pennsylvania
("Wife's Home"), where Wife currently resides, including but not necessarily limited to all
furniture, furnishings, rugs, carpets, household appliances and equipment, clothes,
-5-
jewelry, personalty and other items of tangible property of whatever nature currently
located in Wife's Home as well as other jewelry and personal property in Wife's
possession as of the date of this Agreement.
5.2.2. Wife shall and does hereby set over, transfer and assign to
Husband all of her right, title and interest in and to all of the contents of Husband's
Home, including but not necessarily limited to all furniture, furnishings, rugs, carpets,
household appliances and equipment, clothes, jewelry, personalty and other items of
tangible property of whatever nature currently located in Husband's Home, as well as
other jewelry and personal property in Husband's possession as of the date of this
Agreement.
5.3. Marital Assets. The parties acknowledge that they are the owners
of the following marital assets:
PNC Money Market account # ending 1771 ($360.97);
100 Shares of MLNM common stock ($1,049.89);
Marital Interest in Husband's Advanced Fabrication Services, Inc. 401(k)
account ($34,108.73).
5.4. Wife shall and does hereby set over, transfer and assign to
Husband all of her right, title claim and interest in and to all or any portion of the above-
listed assets. Notwithstanding the above, Wife shall be named as the sole beneficiary of
Husband's Advanced Fabrication Services, Inc. 401 (k) and shall be assigned Husband's
100 shares of MLNM stock until such time as Husband provides insurance as outlined
in Paragraph 7 or completes his payment of alimony as required in Paragraph 6.1.
-6-
Thereafter, Husband may name any beneficiary he so desires. The assignment is
limited to the extent of Husband's obligations under this agreement at the time of his
death. Wife's Trust Fund. The parties acknowledge that Wife is the beneficiary of the
Jessie S. Darr Trust f/b/o Candice Clark (the "Trust Fund"). Husband does hereby set
over, transfer and assign to Wife any and all of his right, title, claim and interest in and
to all or any portion of the Trust Fund.
5.5. Husband's Interest in Advanced Fabrication Services, Inc. The
parties acknowledge that Husband is a one-fourth (1/4) partner in Advanced Fabrication
Services, Inc. Wife does hereby set over, transfer and assign to Husband any and all of
her right, title, claim and interest in and to all or any portion of Husband's interest in
Advanced Fabrication Services, Inc. Husband agrees to be fully responsible and to
indemnify and hold Wife harmless from any and all liability stemming from his interest in
Advanced Fabrication Services, Inc., including but not limited to the Chase Auto
Finance loan currently encumbering the 2003 H2 Hummer owned by Clark Sales
Company. Clark Sales Company is the obligor on said loan Notwithstanding the
above, should Husband die prior to the payment of alimony as outlined in Paragraph
6.1, and without the insurance coverage as outlined in paragraph 7, Husband hereby
assigns to Wife his accrued commissions from Advanced Fabrication Services as well
as his partnership equity in Advanced Fabrication Services. Said assignment is to the
extent of the alimony obligation at the time of Husband's death calculated by multiplying
$5,000 by the number of months remaining on the obligation
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In the event Husband has not paid his obligations to Wife and does not have life
insurance pursuant to Paragraph 7 and his interest in Advanced Fabrication Services,
Inc. is divested whether by sale, transfer, or resignation, Husband shall set aside an
amount equal to his obligation to Wife as security. Wife shall be named as the sole
beneficiary on said account.
5.6. Motor Vehicles. With respect to the motor vehicles, the parties
agree as follows:
5.6.1. 2002 Acura TL. The parties agree that the Acura TL shall
hereinafter be the sole and exclusive property of Wife, subject to any and all liens and
encumbrances, including but not limited to the American Honda Finance loan currently
encumbering the 2002 Acura TL. Wife agrees to be fully responsible and to indemnify
and hold Husband harmless from any and all liability for the 2002 Acura TL.
5.6.2. The parties agree to execute any documents necessary to
effectuate the provisions of this Paragraph on the execution date hereof as necessary to
make any conveyances on a tax-free basis if possible. The said document(s) shall be
delivered to the party entitled to receive same pursuant hereto on the execution date.
5.7. Marital Liabilities. The parties acknowledge that marital liability
existed in the following accounts:
MBNA MasterCard account which was transferred to Chase, an account
solely in Husband's name:
PNC Bank credit account # ending 0961 which has been transferred to an
account solely in Husband's name. ;
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Direct Loans account transferred to Great Lakes # ending 7889 solely in
Husband's name.
Husband agrees to be fully responsible and to indemnify and hold Wife harmless
from any and all liability for the above-listed obligations.
5.8. Lump Sum Payment to Wife. Beginning in July 2006, Husband
shall pay $53,300 to Wife in annual installments of no less than $15,000 per annum.
Said payments are for equitable distribution of the marital assets and shall be made no
later than July of each year. Wife shall grant a reasonable extension of time if
necessary. Should Husband die prior to the payment of these funds, Husband's
assignment of his Advanced Fabrication Services 401(k), MLNM stock and earned
commissions from Advanced Fabrication Services and American Wood Dryers, Inc.
shall apply to those outstanding payments unless Husband has sufficient insurance
benefits under Paragraph 7 to pay Wife the balance owed in this Paragraph.
5.9. Propertv of Husband. The parties agree that Husband shall own,
possess, and enjoy, free from any claim of Wife, the property awarded to him by the
terms of this Agreement. Wife hereby quitclaims, assigns and conveys to Husband all
such property, and waives and relinquishes any and all rights thereto, together with any
insurance policies covering that property, and any escrow accounts relating to that
property. This Agreement shall constitute a sufficient bill of sale to evidence the transfer
of any and all rights in such property from Wife to Husband.
5.10. Propertv of Wife. The parties agree that Wife shall own, possess,
and enjoy, free from any claim of Husband, the property awarded to her by the terms of
-9-
this Agreement. Husband hereby quitclaims, assigns and conveys to Wife all such
property, and waives and relinquishes any and all rights thereto, together with any
insurance policies covering that property, and any escrow accounts relating to that
property. This Agreement shall constitute a sufficient bill of sale to evidence the transfer
of any and all rights in such property from Husband to Wife.
5.11. Assumption of Encumbrances. Unless otherwise provided herein,
each party hereby assumes the debts, encumbrances, taxes and liens on all of the
property each will hold subsequent to the date of this Agreement, and each party
agrees to indemnify and hold harmless the other party and his or her property from any
claim or liability that the other party will suffer or may be required to pay because of
such debts, encumbrances or liens. Each party in possession of property to be
awarded to the other party warrants that all dues, fees, assessments, mortgages, taxes,
insurance payments and the like attendant to such property are Gurrent, or if not current,
notice of any arrearage or deficiency has been given to the receiving party prior to the
execution of this Agreement.
5.12. Taxes. By this Agreement, the parties have intended to effectuate
and equitably divide their marital property. The parties have determined that such
division conforms to a right and just standard with regard to the rights of each party.
Except as may be otherwise expressly provided herein, the division 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 effected without the introduction of outside funds or
other property not constituting a part of the marital estate. As a part of the division of
-10-
the marital property and the marital settlement herein contained, each party shall
receive each item of property at the tax basis that existed for the item immediately
before the execution of this Agreement, and that this Agreement is not intended to affect
the tax basis or tax status for the property received by the party. The parties agree to
save and hold each other harmless from all income taxes assessed against the other
resulting from the division of the property as herein provided.
The parties acknowledge that they have filed various joint income tax
returns during the course of their marriage. In filing each such return, each party has
relied exclusively upon the other party to provide truthful and accurate information
relating to the other party's employment income, business income or deductions, or
income from any other source. In the event that any additional taxes, penalties or
interest are assessed as a result of any such joint return, the party responsible for
under-reporting income or claiming any improper deduction shall indemnify and save
the other party harmless from such tax liability, penalties, interest, attorney's fees or
accountant's fees.
For calendar year 2006 unless otherwise agreed, each party shall report
the year 2005 earnings on the assets distributed to them on their respective federal,
state and local tax returns for 2006.
The parties agree to file a joint tax return in 200S. Husband agrees to be
solely responsible for all tax liability in 2005 and to indemnify and hold Wife harmless
from such obligation.
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5.13. Liabilitv Not Listed. Each party represents and warrants to the
other that he or she has not incurred any debt, obligation or other liability, other than
those described in this Agreement, on which the 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 may hereafter incur it, and each party agrees to pay it as the same shall become due,
and to indemnify and hold the other party and his or her property harmless from any and
all such debts, obligations and liabilities.
5.14. Indemnification of Wife. If any claim, action or proceeding is
hereafter initiated seeking to hold Wife liable for the debts or obligations assumed by
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 attorney's fees incurred by Wife in connection therewith.
5.15. 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 attorney's fees incurred by Husband in connection
therewith.
5.16. Warrantv as to Future Obliqations. Except as set forth in this
Agreement, Husband and Wife each represents and warrants to the other that he or she
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has not in the past or will not at any time in the future incur or contract any debt, charge
or liability for which the other, the other's legal representatives, property or estate may
be responsible. From the date of execution of this Agreement, each party shall use only
those credit cards and accounts for which that party is individually liable and the parties
agree to cooperate in closing any remaining accounts that provide for joint liability.
Each party hereby 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.
5.17. Release of Claims. Wife and Husband acknowledge and agree
that the property dispositions provided for herein constitute an equitable distribution of
their assets and liabilities pursuant to Section 3502 of the Divorce Code. Wife and
Husband hereby waive any right to division of their property except as provided for in
this Agreement. Furthermore, except as otherwise provided for in this Agreement, each
of the parties hereby specifically waives, releases, renounces and forever abandons
any claim, right, title or interest whatsoever he or she may have in property transferred
to the other party pursuant to this Agreement or identified in this Agreement as
belonging to the other party, and each party agrees never to assert any claim to said
property or proceeds in the future except as set forth herein. The parties hereby
expressly release and relinquish, each to the other, every claim, demand, right and
interest he or she may have in or against the other, or against his or her estate, together
with any income or earnings thereon, arising from and during the marriage and of or
from any other reason growing out of the marital relationship. However, neither party is
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released or discharged from any obligation under this Agreement or any instrument or
document executed pursuant to this Agreement. Husband and Wife shall hereafter own
and enjoy independently of any claim or right of the other, all items of personal property,
tangible or intangible, acquired by him or her from the date of execution of this
Agreement with full power in him or her to dispose of the same as fully and effectively,
in all respects and for all purposes, as though he or she were unmarried.
6. ALIMONY.
6.1. Monthlv Payments. Commencing January 1, 2006, Husband shall
pay Wife alimony in the sum of $5,000 per month. Said alimony payments shall be due
by the 151 day of each month. However, Husband's obligation to make such payments
shall terminate upon the first to occur of the following events: (a) Wife's death; (b)
Wife's remarriage; (c) Husband's death; or (d) January 31,2013, whichever comes first.
Notwithstanding the foregoing, if Wife cohabits with a member of the opposite sex for a
period in excess of thirty (30) consecutive days within a twelve-month period, then
Husband's obligation to make such alimony payments shall terminate. Alimony shall be
modifiable only in the event of Husband's disability or an involuntary loss of employment
with American Wood Dryers, Inc..
6.2. Tax Consequences. It is the intention, understanding and
agreement of the parties that the cash payments Husband makes to Wife as described
in Section 6.1 of this paragraph shall constitute spousal support or alimony as those
terms are defined in the Internal Revenue Code of 1986, as amended, and any
successor thereto, and that, accordingly, all such payments shall be includable in Wife's
-14-
gross income and deductible by Husband for federal income tax purposes pursuant to
Sections 71 and 215 of the Internal Revenue Code.
6.3. Releases. The parties acknowledge that by this Agreement they
have each respectively secured sufficient financial resources to provide for his or her
own comfort, maintenance and support. The parties do hereby acknowledge that
inflation may increase or decrease, that their respective incomes and assets may
substantially increase in value, that either may be employed or unemployed at various
times in the future, and that notwithstanding these or other economic circumstances,
which may be changes in circumstances of a substantial and continuing nature, the
terms of this Agreement are just and reasonable. Therefore, except for the provisions
of this Agreement, the parties hereby expressly waive, discharge and release any and
all rights and claims which they may now or hereafter have, by reason of the parties'
marriage, to alimony, alimony pendente lite, support or maintenance, and they further
release any rights they may have to seek modification of the terms of this Agreement in
a court of law or equity, it being understood that the foregoing constitutes a final
determination for all time of either party's obligation to contribute to the support and
maintenance of the other. Except as provided for in this Agreement, it shall be, from the
execution date of this Agreement, the sole responsibility of each of the respective
parties to sustain himself or herself without seeking any additional support from the
other party. In the event that either of the parties shall seek a modification of the terms
of this paragraph, or in the event that Wife makes any claim for spousal support or
alimony other than as provided for by the terms of this Agreement, that party shall
-15-
indemnify and hold the other party harmless from and against any loss resulting
therefrom, including counsel fees and costs.
7. LIFE INSURANCE. The parties agree that Husband shall maintain a life
insurance policy on which he shall be the insured and Wife shall be the irrevocable
beneficiary the with an initial benefit amount of $420,000 until Husband's obligation to
pay alimony to Wife as set forth in Paragraph 6.1 of this Agreement terminates.
Husband shall have the right to decrease the value of the life insurance policy by
$60,000 as of February 1 of 2007 and each year thereafter. Husband agrees to apply
for life insurance no less than once a year and shall purchase insurance as provided
herein as long as the premium is not in excess of $300 per month.
, ,Should Husband die without life insurance coverage as outlined in this
provision, Husband hereby assigns to Wife the accrued commissions with American
Wood Dryers at the time of his death. Wife shall also be paid the value of 100 shares of
MLNM stock at the time of Husband's death.
Wife's entitlement to the insurance proceeds and/or assets identified in
Paragraphs 5.3, 5.5 or 5.6 in lieu of insurance shall be limited to the outstanding
alimony obligation at the time of Husband's death. Said obligation shall be calculated
as $5,000, multiplied by the number of months remaining on the alimony term. To the
extent necessary, Wife shall execute any documentation necessary to decline
beneficiary amounts in excess of this obligation. In all cases, Husband shall list
successor beneficiaries.
-16-
8.
COUNSEL FEES, COSTS AND EXPENSE~. Each party shall be
responsible for his or her own legal fees, costs and expenses incurred in connection
with their separation and/or the dissolution of their marriage.
9. WAIVER OF INHERITANCE RIGHTS. Effective upon the signing of this
Agreement, Husband and Wife each waives 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, and each of the parties waives any additional rights which said
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.
10. MODIFICATION. No modification, rescission, or amendment to this
Agreement shall be effective unless in writing and signed by each of the parties hereto.
11. SEVERABILITY. If any provision of this Agreement is held by a court of
competent jurisdiction to be void, invalid or unenforceable, the remaining provisions
hereof shall nevertheless survive and continue in full force and effect without being
impaired or invalidated in any way.
12. BREACH. If either party hereto is in breach of any provision hereof, the
other party shall have the right, at his or her election, to sue for damages for such
breach, or seek such other remedies or relief as may be available to him or her. The
non-breaching party shall be entitled to recover from the breaching party all reasonable
-17-
costs, expenses and legal fees actually incurred in the enforcement of the rights of the
non-breaching party.
13. 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 provision of this
Agreement.
14. NOTICE. Any notice to be given under this Agreement by either party to
the other shall be in writing and may be affected by registered or certified mail, return
receipt requested. Notice to Wife will be sufficient if made or addressed to the following:
1315 English Road
Mechanicsburg, PA 17055
and to Husband, if made or addressed to the following:
2159 Bordeaux Court
Harrisburg, PA 17112
Each party may change the address for notice to him or her by giving notice of that
change in accordance with the provisions of this paragraph.
15. APPLICABLE LAW. All acts contemplated by this Agreement shall be
construed and enforced under the laws of the Commonwealth of Pennsylvania.
16. 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.
-18-
17. EFFECT OF RECONCILIATION OR RECONCILIATION ATTEMPT. This
Agreement shall remain in full force and effect even if the parties effect a reconciliation,
cohabit as Husband and Wife or attempt to affect a reconciliation. This Agreement shall
continue in full force and effect and there shall be no modification or waiver of any of the
terms hereof unless the parties in writing execute a statement declaring this Agreement
or any provision of this Agreement to be null and void.
18. HEADINGS NOT PART OF AGREEMENT. Any headings preceding the
text of the several paragraphs and subparagraphs hereof are inserted solely of
convenience of reference and shall not constitute a part of this Agreement nor shall they
affect its meaning, construction or effect.
19. AGREEMENT BINDING ON PARTIES AND HEIRS. This Agreement,
except as otherwise expressly provided herein, shall bind the parties hereto and their
respective heirs, executors, administrators, legal representatives, assigns, and
successors in any interest of the parties.
20. ENTIRE AGREEMENT. Each party acknowledges that he or she has
carefully read this Agreement, including other documents to which it refers; that he or
she has discussed its provisions with an attorney of his or her own choice, and has
executed it voluntarily and in reliance upon his or her own attorney; and that 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 of the parties.
-19-
21. MUTUAL COOPERATION. Each party shall on demand execute and
deliver to the other any deeds, bills of sale, assignments, consents to change of
beneficiaries of insurance policies, 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 these provisions, that party shall pay to the other party
all attorney's fees, costs, and other expenses reasonably incurred as a result of such
failure.
22. AGREEMENT NOT TO BE MERGED. This Agreement shall remain in full
force and effect in the event of the parties' divorce. This Agreement shall not be
merged into said decree. The parties shall have the right to enforce this Agreement
under the Divorce Code of 1980, as amended, 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 not waived or released by this Agreement.
IN WITNESS WHEREOF, the parties hereto set their hands and seals on the
dates of their acknowledgments.
WITNESS
UJ
-20-
. .
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF l)~~I'V)
BEFORE ME, the undersigned authority, on this day personally appeared JAY F.
CLARK, 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.
GIVEN UNDER MY HAND AND SEAL OF OFFICE this ~ +h. day of ~
2006.
~ ~.R,OD~~
Notary Public .
..~~ NOTARiAL SEI\L
i MICHELE S. BEERY, Notary NlIic
I City 01 HllfTisburg, PA Dauphin County
! My CommlsSlOl1 Expires July 6 2006
__""_,., _,,_~._, _.~~..,._".__ I
-21-
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF
{j~v..rV"\
BEFORE ME, the undersigned authority, on this day personally appeared
CANDACE J. CLARK, 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.
GIVEN UNDER MY HAND AND SEAL OF OFFICE this ~.A..s~ day of ~:
2006.
~.-J.~
Notary Public
, NOTARIAL SEAL
I illllCHELE S. BEERY, Notary PlbIic
I City of Hanisburg, P,~ Dauphin County
i My Coml!'issi~ Expires July 6, 2006
-22-
McNEES WALLACE & NURICK LLC
BY: DEBRA DENISON CANTOR, ESQUIRE
Attorney 1.0. No. 66378
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108-1166
(717) 232-8000
(717) 237-5300 facsimile
dcantor@mwn.com
CANDACE J. CLARK,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2004-6448
JAY F. CLARK,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed
on December 22, 2004.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of the filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of
intention to request entry of the decree.
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.SA Section 4904
relating to unsworn falsification to authorities.
/7
Dated: t>Y;><-/ c/6 c fi-'l-"
/-? ;?%/-
(' k~~..~
Candace J. Clark .
McNEES WALLACE & NURICK LLC
BY: DEBRA DENISON CANTOR, ESQUIRE
Attorney 1.0. No. 66378
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108-1166
(717) 232-8000
(717) 237-5300 facsimile
dcantor@mwn.com
CANDACE J. CLARK,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2004-6448
JAY F. CLARK,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed
on December 22, 2004.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of the filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of
intention to request entry of the decree.
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 Pn.C.SA Section 4904
relating to unsworn falsification to authorities. II
Dated: 1/ z-<, (I:? ro
Jay F. Clark
McNEES WALLACE & NURICK LLC
BY: DEBRA DENISON CANTOR, ESQUIRE
Attomey I.D. No. 66378
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108-1166
(717) 232-8000
(717) 237-5300 facsimile
dcantor@mwn.com
CANDACE J. CLARK,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2004-6448
JAY F. CLARK,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER li3301(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 divorce decree is entered by
the Court and that a copy of the decree will be sent to me immediately after it is filed
with the Prothonotary.
I verify that the statements made in this affidavit are true and correct.
understand that false statements herein are made subject to the penalties of 18 Pa.
C.S. 94904 relating to unsworn falsification to authorities.
Dated: 4J .Y"t:.. c;?ot::
~1o/cA:~~5
CANDACE J. C ARK
McNEES WALLACE & NURICK LLC
BY: DEBRA DENISON CANTOR, ESQUIRE
Attomey I.D. No. 66378
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108-1166
(717) 232-8000
(717) 237-5300 facsimile
dcantor@mwn.com
CANDACE J. CLARK,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2004-6448
JAY F. CLARK,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER li3301(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 divorce decree is entered by
the Court and that a copy of the decree will be sent to me immediately after it is filed
with the Prothonotary.
I verify that the statements made in this affidavit are true and correct.
understand that false statements herein are made subject to the penalties of 18 Pa.
C.S. 34904 relating to unsworn falsification to authorities.
Dated:
1/u'/ClC:.
--------
CANDACE J. CLARK,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 2004-6448 CIVIL TERM
JA Y F. CLARK,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the Court for entry of a
divorce decree:
I. Ground for divorce: irretrievable breakdown under Section (X) 330 I (c)
( ) 330 I (d) of the Divorce Code. (Check applicable section).
2. Date and manner of service of the complaint: Bv certified mail on Januarv 8, 2005.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by Section 3301 (c) ofthe
Divorce Code: by Plaintiff April 26, 2006 ; by Defendant April 26, 2006
(b)(l) Date of execution of the Plaintiffs affidavit required by Section 3301 (d) of the
Divorce Code:
; (2) date of service of the Plaintiffs affidavit upon the
Defendant:
4. Related claims pending: None
Attorney for (X) Plainti
( ) Defendant
+:+':+:++++:+:'f:f.'f:+:+
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++++'f++++++++++++'f+++~
IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
STATE OF
PENNA.
CANDACE J.
CLARK,
Plaintiff
No.
2004-6448
VERSUS
JAY F.
CLARK,
Defendant
DECREE IN
DIVORCE
AND NOW, -----JJ,.J-Plt ~
2006 IT IS ORDERED AND
,
DECREED THAT
CANDACE J.
, PLAINTIFF,
CLARK
AND
JAY F. CLARK
, 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;
\)O~
Marital Settlement Agreement dated 26 April 2006,
is
hereby
incorporated into the Final Divorce
mmt. ..~
~ PROTHONOTARY
J.
,
77'~.p ?;?C'/ g .niT' '-",,, 77~ ';{.:l /1 /;
7[;;s:'j!v-;Z /1e7'vr.V ~ ';::7f) ;Jc? /'S
f .'
-: "
-err. RY
13 ;;1 3 06
n ?.
uUN
Constance P. Brunt, Esquire
Supreme Court ID #29933
Beaufort Professional Center
1820 Linglestown Road
Harrisburg, PA 17110
(717) 232-7200
FAX (717) 232-0255
c brunt CPBruntLaw.com
Attorney for Plaintiff
CANDACE J. CLARK, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
NO. 2004-6448 CIVIL TERM
JAY F. CLARK,
Defendant IN DIVORCE
ADDENDUM TO MARRIAGE SETTLEMENT AGREEMENT
DATED APRIL 26, 2006
ADDENDUM TO MARITAL SETTLEMENT AGREEMENT
DATED APRIL 26, 2006
THIS ADDENDUM, made this day of 2010, by and
between JAY F. CLARK, hereinafter referred to as "HUSBAND"
- AND -
CANDACE J. CLARK, hereinafter referred to as "WIFE",
WITNESSETH:
WHEREAS, the parties were formerly Husband and Wife, having been divorced
on May 2, 2006, by decree of the Court of Common Pleas of Cumberland County,
Pennsylvania, docketed to No. 2004-6448; and
WHEREAS, the parties entered into a Marital Settlement Agreement dated April
26, 2006, whereby they resolved all economic claims arising from their marital
relationship; and
WHEREAS, the parties desire to modify the terms of the aforesaid Marital
Settlement Agreement in certain respects; and
WHEREAS, Husband and Wife declare that each has had a full and fair
opportunity to obtain independent legal advice of counsel of his or her selection; that
Wife has been independently represented by counsel, CONSTANCE P. BRUNT,
ESQUIRE, and that Husband, cognizant of his right to legal representation, declares
that it is his express, voluntary, and knowing intention not to avail himself of his right to
counsel and chooses instead to represent himself with respect to the preparation and
execution of this Agreement. The parties acknowledge that they fully understand the
facts and they acknowledge and accept that this Agreement, is, in the circumstances,
fair and equitable, and that it is being entered into freely and voluntarily, with such
knowledge and that 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.
NOW, THEREFORE, in consideration of the premises and of the promises,
covenants and undertakings hereinafter set forth, and for other good and valuable
consideration, the receipt of which is hereby acknowledged, the parties hereto, each
intending to be legally bound hereby, covenant and agree as follows:
1. HUSBAND'S INTEREST IN ADVANCED FABRICATION SERVICES
INC. Paragraph 5.5 of the aforesaid Marital Settlement Agreement dated April 26,
2006, is hereby modified to read as follows:
"5.5. Husband's Interest in Advanced Fabrication Services Inc.
The parties acknowledge that Husband is a one-fourth (1/4) partner in
Advanced Fabrication Services, Inc. Wife does hereby set over, transfer
and assign to Husband any and all of her right, title, claim and interest in
and to all or any portion of Husband's interest in Advanced Fabrication
Services, Inc. Husband agrees to be fully responsible and to indemnify
and hold Wife harmless from any and all liability stemming from his
interest in Advanced Fabrication Services, Inc., including but not limited to
the Chase Auto Finance loan currently encumbering the 2003 H2
Hummer owned by Clark Sales Company. Clark Sales Company is the
-2-
obligor on said loan. Notwithstanding the above, should Husband die
prior to the payment of alimony as outlined in Paragraph 6. 1, and without
the insurance coverage as outlined in Paragraph 7, Husband hereby
assigns to Wife his accrued commissions from Advanced Fabrication
Services, Inc., as well as his ownership interest in the said corporation.
Said assignment is to the extent of the remaining alimony obligation owed
by Husband at the time of his death, calculated by multiplying $5,000.00
by the number of months remaining on the obligation through September
30, 2010, plus the remaining balance due on the total sum of $70,000.00
in alimony owed effective as of October 1, 2010.
In the event Husband has not paid his alimony obligations to Wife
pursuant to Paragraph 6.1 and does not have life insurance pursuant to
Paragraph 7 and his interest in Advanced Fabrication Services, Inc., is
divested, whether by sale, transfer, or resignation, Husband shall set
aside an amount equal to his remaining alimony obligation to Wife as
security. Wife shall be named as the sole beneficiary on said account."
2. ALIMONY. Paragraph 6.1.1 of the aforesaid Marital Settlement
Agreement dated April 26, 2006, is hereby modified to read as follows:
"6.1.1 Monthly Payments. Commencing January 1, 2006, and
continuing through September 30, 2010, Husband shall pay Wife alimony
in the sum of $5,000.00 per month. Thereafter, Husband shall pay Wife
additional alimony in the total amount of $70,000.00, payable in monthly
payments in the minimum amount of $3,000.00 and the maximum amount
of $5,000.00 per month. Such monthly payments shall commence
October 1, 2010, and continue until such time as the total amount of
-3-
$70,000.00 has been paid to Wife. All alimony payments provided herein
shall be due by the first day of each month. However, Husband's
obligation to make such payments shall terminate earlier upon the first to
occur of the following events: (a) Wife's death; or (b) Husband's death.
Wife's remarriage or cohabitation with a member of the opposite
sex for any period of time shall not terminate or modify such alimony
payments in any respect. Except as otherwise set forth herein, alimony
shall not be subject to termination or modification."
3. LIFE INSURANCE. Paragraph 7 of the aforesaid Marital Settlement
Agreement dated April 26, 2006, is hereby modified to read as follows:
7. Life Insurance. The parties agree that Husband shall maintain
a life insurance policy on which he shall be the insured and Wife shall be
the irrevocable beneficiary with an initial benefit amount of $420,000.00
until Husband's obligation to pay alimony to Wife as set forth in Paragraph
6.1 of this Agreement terminates. Husband shall have the right to
decrease the value of the life insurance policy by $60,000.00 as of
February 1, 2007 and each year thereafter. Husband agrees to apply for
life insurance no less than once a year and shall purchase insurance as
provided herein as long as the premium is not in excess of $300.00 per
month.
Should Husband die without life insurance coverage as outlined in
this provision, Husband hereby assigns to Wife the accrued commissions
with Advanced Fabrication Services, Inc. at the time of his death. Wife
shall also be paid the value of 100 shares of MLNM stock at the time of
Husband's death.
Wife's entitlement to the insurance proceeds and/or assets
identified in Paragraphs 5.3, 5.5 or 5.6 in lieu of insurance shall be limited
-4-
to the outstanding alimony obligation at the time of Husband's death.
Said assignment is to the extent of the remaining alimony obligation owed
by Husband at the time of his death, calculated by multiplying $5,000.00
by the number of months remaining on the obligation through September
30, 2010, plus the remaining balance due on the total sum of $70,000.00
in alimony owed effective as of October 1, 2010."
4. RATIFICATION OF MARITAL SETTLEMENT AGREEMENT DATED
APRIL 26. 2006. In all other respects and except as modified herein, the parties
hereby ratify and confirm the Marital Settlement Agreement dated April 26, 2006.
IN WITNESS WHEREOF, the parties have hereunto set their hands and seals
the day and year first above written.
WITNESS:
(SEAL)
DACE J. CLARK
JAY F. CLARK
(s,FAL)
-5-
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
. SS.
On this day of 2010, before me, the
undersigned officer, personally appeared CANDACE J. CLARK and JAY F. CLARK,
known to me (or satisfactorily proven) to be the persons whose names are subscribed
to the within Addendum to the Marital Settlement Agreement, and acknowledged that
they executed the same for the purposes therein contained.
COMMONWEALTH OF PENNSYLVANIA Notary Public
Notarial Seal
Constance P. Brunt, Notary Public
Susquehanna Twp., Dauphin County
M Commiaalon EVres Oct. 20, 2013