HomeMy WebLinkAbout06-2781
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
KARL R. BECHTOLD,
Plaintiff
V.
KAREN L. BECHTOLD,
Defendant
No. U
IN DIVORCE
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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 divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is
available in the Office of the Prothonotary, Cumberland County Courthouse, One
Courthouse Square, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR
ANNULMENT IS GRANTED, YOU MAY LOSE THE 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, PA 17013
(717) 249-3166
1-8oo-99o-91o8
AVISO PARA DEFENDERY REC e?MAR DERECHOS
USTED HA SEDO DEMANDADO EN ILA CORTE. Si desea defenderse de las
quejas expuestas en las paginas siguientes, debe tomar acci6n con prontitud. Se le avisa
que si no se defiende, el caso puede proceder sin usted y decreto de divorcio o
anulamiento puede ser emitido en su contra por la Corte. Una decisi6n tambi6n ser
emitida en su contra por cualgwer otra queja o compensaci6n reclamados por el
demandante. Usted puede perder dinero, o propiedades u otros derechos importantes
para usted.
Cuando la base para el divorcio es indignidades o rompimiento irreparable del
matrimona, usted puede solicitar consejo matrimonial. Una lista de consejeros
matrimomales esta disponible en la oficina del Prothonotary, en la Cumberland County
Court of Common Pleas, One Courthouse Square, Carlisle, Pennsylvania.
SI USTED NO RECLAMA PENSION ALIIYIENTICIA, PROPIEDAD
MARITAI., HONORARIOS DE ABOGADO U OTROS GASI'OS ANTES DE
QUE EL DECREPO FINAL DE DIVORCIO O ANUI.AMIENTE SEA EMMDO,
USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE
ELLOS.
USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE
INMEDIATO. SI NO TIENE O NO PUEDE PAGAR UN ABOGADO, VAYA O
LLAME ALA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE
PUEDE OBTENER ASISTENCIA LEGAL.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
1-8oo-99o-91o8
AMERICANS WITH DISABILITIES ACT OF logo
The Court of Common Pleas of Cumberland County is required by law to comply
with the Americans with Disabilities Act of 199o. For information about accessible
facilities and reasonable accommodations available to disabled individuals having
business before the Court, please contact our office. All arrangements must be made at
least 72 hours prior to any hearing or business before the Court. You must attend the
scheduled Conference or Hearing.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17o13
(717) 249-3166
1-8oo-99o-9io8
Maryann Murphy, Esquire
PMB 246
4902 Carlisle Pike
Mechanicsburg, PA 17050
(717) 730-0422
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
KARL R. BECHTOLD,
Plaintiff
: No. o? -.217P1 el
V.
IN DIVORCE
KAREN L. BECHTOLD,
Defendant
COMPLAINT UNDER SECTION $3oi(c) and 3aoi(d)
OF THE DIVORCE CODE
AND NOW comes KARL. R. BECHTOLD, by and through his attorney,
Maryann Murphy, Esquire, who respectfully avers as follows:
1. Plaintiff/Husband is KARL R. BECHTOLD who resides at 172 Stone
Hedge Lane, Mechanicsburg, Cumberland County, Pennsylvania i7o55•
2. Defendant/Wife is KAREN L. BECHTOLD who resides at 505 Carol
Street, New Cumberland, Cumberland County, Pennsylvania 17o7o.
3. Husband and Wife have been bona fide residents in the Commonwealth
for at least six months immediately previous to the filing of this Complaint.
4. Husband and Wife were married on September 26, 1981 in Lebanon
County, Pennsylvania.
5. Husband and Wife separated on June 1, 2005.
6. There have been no prior actions for divorce or for annulment between
Husband and Wife.
7. Wife is not a member of the Armed Forces of the United States of America
or any of its Allies.
8. The marriage is irretrievably broken.
9. Husband has been advised of the availability of marriage counseling and
that he may have the right to request the court to require the parties to participate in
such counseling. Being so advised, Husband does not request that the Court require the
parties to participate in counseling prior to a Divorce Decree being handed down by the
Court.
10. Husband requests this Court to enter a Decree in Divorce from the bonds
of matrimony.
WHEREFORE, Plaintiff/Husband requests this Honorable Court to
enter a Decree dissolving the marriage between the Plaintiff/Husband and the
Defendant/Wife.
Respectfully submitted,
L
Maryan urphy, Esquir
PMB 246
4902 Carlisle Pike
Mechanicsburg, PA 17050
(717) 730-0422
I.D. # 61900
Attorney for Plaintiff/Husband
I, KARL R BECHTOLD, verify that the statements made in the foregoing
Complaint in Divorce 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 unworn
falsification to authorities.
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Date KARL R. BECHTOLD
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
KARL R. BECHTOLD,
Plaintiff
: No. o6-2781 Civil Term
V.
KAREN L. BECHTOLD,
Defendant
: IN DIVORCE
AFFIDAVIT OF SERVICE
I, Maryann Murphy, Esquire, depose and say:
1. That I am an adult individual residing in Cumberland County, Pennsylvania.
2. That on May 19, 2oo6, I mailed the Complaint in Divorce to Defendant's attorney,
Carol J. Lindsay, Esquire, at the following address:
Saidis, Shuff, Flower & Lindsay
26 West High Street
Carlisle, PA 17013
3. That Defendant's attorney, Carol J. Lindsay, Esquire, accepted service of the
Complaint in Divorce on behalf of Defendant and signed an Acceptance of Service dated
May 23, 2oo6. The Acceptance of Service is attached hereto.
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Date
WAIJ -01Y4
Maryann urphy, Esqui
PMB 246
4902 Carlisle Pike
Mechanicsburg, PA 17050
(717) 730-0422
I.D. # 61goo
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
KARL R. BECHTOLD,
Plaintiff
V.
: No. o6-2781 Civil Term
: IN DIVORCE
KAREN L. BECHTOLD,
Defendant
ACCEPTANCE OF SERVICE
I, CAROL J. LINDSAY, ESQUIRE, am the Attorney for Defendant, Karen L.
Bechtold, in the collaborative law process for resolution of her family law issues. In that
capacity, I am authorized to and have accepted service of the Complaint in Divorce, on this
the 7- day of 2oo6. As a part of the collaborative law process, I will
be unable to represent Karen L. Bechtold if the parties leave the collaborative law process
and proceed with litigation.
Attorney for lei
26 West High §tD
Carlisle, PA 17o13
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
KARL R. BECHTOLD,
Plaintiff
V.
:No. o6-2781 Civil Term
: IN DIVORCE
KAREN L. BECHTOLD,
Defendant
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
May 16,20o6-
2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (9o)
days have elapsed from the date of 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.S. Section 4904
relating to unsworn falsification to authorities.
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Date kA?RL R. BECHTOLD
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
KARL R. BECHTOLD,
Plaintiff
:No. o6-2781 Civil Term
V.
KAREN L. BECHTOLD,
Defendant
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this Affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
I -?Y-07
Date KARL R. BECHTOLD
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KARL R. BECHTOLD, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
NO. 06-2781 CIVIL TERM
KAREN L. BECHTOLD,
Defendant IN DIVORCE
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DEFENDANT'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on May 16,
2006.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. 1 consent to the entry of a final Decree in 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 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:
Karen L. Bechtold
DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDERS 3301 (c) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. 1 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. 1 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 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: _ a 1107 )/aaA v , A
Karen L. Bechtold
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MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT, made this(-A_day of 2007 by
and between KAREN L. BECHTOLD of Cumberland County, Pennsylvania
(hereinafter referred to as Karen), and KARL R. BECHTOLD of Cumberland County,
Pennsylvania (hereinafter referred to as Karl),
WHEREAS, Karen and Karl were lawfully married on September 26, 1981 in
Lebanon County, Pennsylvania; and
WHEREAS, two (2) children were born of this marriage, namely: Sara
Bechtold, born July 10, 1985; and Benjamin Bechtold, born July 25,1988; and
WHEREAS, Karen and Karl separated on June 1, 2005; and
WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen
between the parties and it is the intention of Karen and Karl to live separate and apart
for the rest of their natural lives, and 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 by specification: the settling of all matters between
them relating to the ownership and equitable distribution of real and personal property;
the settling of all matters between them relating to past, present and future support and
alimony; and in general, the settling of any and all claims by one against the other or
against their respective estates; and
WHEREAS, Karen and Karl and their respective counsel entered into a
Collaborative Law Participation Agreement dated March 9, 2006, and have used the
Collaborative Law Process in negotiating this Agreement.
NOW, THEREFORE, in consideration of the premises and of the mutual
promises, covenants and undertakings hereinafter set forth and for other good and
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valuable consideration, receipt of which is hereby acknowledged by each of the parties
hereto, Karen and Karl, each intending to be legally bound, hereby covenant and agree
as follows:
1. Separation: It shall be lawful for each parry at all times hereafter to live
separate and apart from the other party at such place as he or she may from time to time
choose or deem fit. The foregoing provision shall not be taken as an admission on the
part of either parry of the lawfulness or unlawfulness of the causes leading to their living
apart.
2. Interference: Each party shall be free from interference, authority,
and contact by the other, as fully as if he or she were single and unmarried, except as
may be necessary to carry out the provisions of this Agreement. Nothing in this
paragraph shall prevent Karen and Karl from having contact by their mutual agreement.
3. Subsequent Divorce: The parties acknowledge that Karl filed a
Complaint in Divorce in Cumberland County, Pennsylvania on May 16, 2oo6, claiming
that the marriage is irretrievably broken under the no-fault provision of Section 3301(c)
and (d) of the Pennsylvania Divorce Code. Both parties agree to execute Affidavits of
Consent and Waivers of Notice at the time of the execution of this Agreement.
The parties hereby waive all rights to request Court-ordered counseling under the
Divorce Code. It is specifically understood and agreed by the parties that the provisions
of this Agreement as to equitable distribution of property of the parties are accepted by
each party as a final settlement for all purposes whatsoever, as contemplated by the
Pennsylvania Divorce Code.
Should a decree, judgment or order of separation or divorce be obtained by either
of the parties in this or any other state, country or jurisdiction, each of the parties
hereby consents and agrees that this Agreement and all of its covenants shall not be
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affected in any way by any such separation or divorce; and that nothing in any such
decree, judgment, order or further modification or revision thereof shall alter, amend or
vary any term of this Agreement. It is specifically agreed that a copy of this Agreement,
or the substance of the provisions thereof, may be incorporated by reference, but not
merged, into any divorce, judgment or decree. It is the specific intent of the parties to
permit this Agreement to survive any judgment and to be forever binding and conclusive
upon the parties.
4. Date of Execution: The "date of execution" or "execution date" of
this Agreement shall be defined as the day upon which it is executed by the parties if
they have each executed the agreement on the same date. Otherwise, the "date of
execution" or "execution date" of this Agreement shall be defined as the date of
execution by the party last executing this Agreement.
5. Distribution Date: The transfer of property, funds and/or documents
provided for herein, shall only take place on the "distribution date" which shall be
defined as specified herein.
6. Mutual Release: Karen and Karl each do hereby mutually remise,
release, quitclaim and forever discharge the other and the estate of such other, for all
time to come, and for all purposes whatsoever, of and from any and all rights, title and
interests, or claims in or against the property (including income and gain from property
hereafter accruing) of the other or against the estate of such other, of whatever nature
and wheresoever situate, which he or she now has or at any time hereafter may have
against the other, the estate of such other or any part thereof, whether arising out of any
former acts, contracts, agreements or liabilities of such other or by way of dower or
curtesy, or claims in the nature of dower or curtesy or widow's or widower's rights,
family exemption or similar allowance, or under the intestate laws, or the right to take
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against the spouse's will; or the right to treat a lifetime conveyance by the other as
testamentary, or all other rights of a surviving spouse to participate in a deceased
spouse's estate, whether arising under the laws of (a) Pennsylvania, (b) any State,
Commonwealth or territory of the United States, or (c) any country, or any rights which
either party may have or at any time hereafter shall have for past, present or future
support or maintenance, alimony, alimony pendente lite, counsel fees, property division,
costs or expenses, whether arising as a result of the marital relations or otherwise,
except, all rights and obligation of whatsoever nature arising or which may arise under
this Agreement or for the breach of any provisions thereof.
It is the intention of Karen and Karl to give to each other by the execution of this
Agreement a full, complete and general release with respect to any and all property of
any kind or nature, real, personal or mixed, which the other now owns or may hereafter
acquire, except and only except all right and agreements and obligations of whatsoever
nature arising or which may arise under this Agreement or for the breach of any
provision thereof.
It is further agreed that this Agreement shall be and constitute a full and final
resolution of any and all claims which each of the parties may have against the other for
equitable division of property, alimony, counsel fees and expenses, alimony pendente
lite or any other claims pursuant to the Pennsylvania Divorce Code or the divorce laws
of any other jurisdiction.
7. Advice ofCounsel: The provisions of this Agreement and their
legal effect have been fully explained to Karen by her attorney, Carol J. Lindsay, Esquire,
and to Karl by his attorney, Maryann Murphy, Esquire.
Karen and Karl acknowledge and accept that this Agreement is, in the
circumstances, fair and equitable and that it is being entered into freely and voluntarily
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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 collusion or improper or illegal agreement or
agreements. The parties further acknowledge that, pursuant to their Collaborative Law
Participation Agreement, they have each made to the other a full and complete
disclosure of their respective assets, estate, liabilities, and sources of income and that
they waive any specific enumeration thereof for the purposes of this Agreement.
8. Subsequent Reconciliation: The parties agree that the terms of this
Agreement shall not be affected in any way by their subsequent cohabitation or
resumption of marital relations, unless the parties otherwise specifically agree in
writing.
9. Warranty as to Existing Obligations: Each party represents that he
or she has not heretofore incurred or contracted for any debt or liability or obligation for
which the estate of the other party may be responsible or liable except as may be
provided for in this Agreement. Each parry agrees to indemnify and hold the other party
harmless for and against any and all such debts, liabilities or obligations of every kind
which may have heretofore been incurred by them, including those for necessities,
except for the obligation arising out of this Agreement.
10. EXISTING DEBTS: Karen and Karl acknowledge that the following
is a complete list of their marital debts:
(a) The mortgage on the marital residence located at 505 Carol Street,
New Cumberland, Cumberland County, Pennsylvania with Eagleview Mortgage
Company, in joint names, with an approximate balance of $107,276.66 as of November
29, 2005;
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(b) The loan on the 2003 Nissan Altima with Nissan Motors
Acceptance Corporation, in joint names, with an approximate balance of $12,214.39 as
of February 11, 2oo6;
(c) The loan on the 1999 Volkswagen Beetle GLS Hatchback with
Members 1St, in Karen's individual name, with an approximate balance of $8,187.05 as
of March 7, 2oo6;
(d) The loan on the 1999 Nissan Maxima with Members 1St, in Karl's
individual name, with an approximate balance of $9333.99 as of March 7, 2oo6;
(e) The Visa Charge Card, in joint names, with an approximate balance
of $1,532.53 as of March 7, 20o6;
(f) The Chase MasterCard, in Karl's individual name, with an
approximate balance of $6,049.62 as of June 23, 2005;
(g) The Personal Service Loan (PSL) in joint names with an
approximate balance of $6,ooo.oo.
Karl agrees to be solely and exclusively responsible for the mortgage payments
until settlement on the marital residence; the balance of the loan on the 1999 Nissan
Maxima; the balance of the Chase MasterCard; and the balance of the Personal Service
Loan (PSL). Karl agrees that he shall pay the balance of the Personal Service Loan
within ten (1o) days of the execution of this Agreement, and he shall close the account.
Karl further agrees to indemnify Karen and hold her harmless from any and all liability
for same.
Karen agrees to be solely and exclusively responsible for the balance of the loan
on the 2003 Nissan Altima; and the balance of the loan on the 1999 Volkswagen. Karen
further agrees to indemnify Karl and hold him harmless from any and all liability for
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same. Both parties acknowledge that Karen reserves the right to transfer the title of the
1999 Volkswagen and the balance of that car loan to Sara.
The parties agree to pay the balance of the Visa Charge Card at the time of
settlement on the marital residence from the remaining net proceeds as per paragraph
number 12 below. In the event there are insufficient proceeds from the sale of the
marital residence to pay the balance of the Visa Charge Card, Karen and Karl agree to be
equally responsible for paying the remaining balance. The parties further agree to close
their joint Visa Charge Card within ten (lo) days of the payment of the balance.
The parties acknowledge that there are no other marital debts.
11. Warranty as to Future Obligations: Karen and Karl each covenant,
warrant, represent and agree that, with the exception of obligations set forth in this
Agreement, neither of them shall hereafter incur any liability whatsoever for which the
estate of the other may be liable. Each party shall indemnify and hold harmless the
other party for and against any and all debts, charges and liabilities incurred by the
other after the execution date of this Agreement, except as may be otherwise specifically
provided for by the terms of this Agreement.
12. Marital Residence: The parties own, as tenants by the entireties,
real property located at 505 Carol Street, New Cumberland, Cumberland County,
Pennsylvania. Karen and Karl acknowledge that the marital residence has been sold,
with settlement to occur on or before October 1, 2007. Until settlement, Karl agrees to
be solely and exclusively responsible for payment of the mortgage, taxes and insurance,
and he further agrees to indemnify Karen and hold her harmless from any and all
liability for same. Until settlement, Karen agrees to be solely and exclusively responsible
for all other expenses associated with the marital residence, and she further agrees to
indemnify Karl and hold him harmless from any and all liability for same.
7
The parties agree that Karen will receive the first $1oo,ooo.oo from the net
proceeds on the sale of the marital residence; Karl will receive the next $16,ooo.oo from
the net proceeds on the sale of the marital residence; the balance of the joint Visa
Charge Card will be paid in full; and Karen and Karl will equally divide any remaining
net proceeds between themselves. The net proceeds shall be defined as the sale price
less the mortgage payoff and the costs of sale. In the event there are insufficient
proceeds from the sale of the marital residence to pay the balance of the Visa Charge
Card, Karen and Karl agree to be equally responsible for paying the remaining balance.
Both parties agree to clean out the house in advance of settlement.
The parties agree that Karl shall claim the taxes and the mortgage interest for the
marital residence on his income tax returns for 2007.
13. Personal Property: Karen and Karl agree that they shall divide all
of their household personal property between themselves. In the event they are unable
to do so, the parties agree to return to the Collaborative Law Process or participate in
mediation to resolve this matter.
Karen and Karl both waive their rights to have the personal property appraised.
Neither party shall make any claim to any such item of marital property, or of the
separate personal property of either party, except as provided for in this Agreement.
Should it become necessary, the parties each agree to sign, upon request, any titles or
documents necessary to give effect to this paragraph.
14. Bank Accounts: Karen and Karl acknowledge that they had the
following bank accounts at separation:
(a) A Members 1St checking account *3128211 in joint names with an
approximate balance of $2,487.38 on March 7, 2oo6;
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(b) A Members ist savings account #3128200 in joint names with an
approximate balance of $25.56 on March 7, 20o6;
(c) A Members 1st holiday club account #3128202 in joint names with
an approximate balance of $401.03 on March 7, 20o6;
(d) A Members 1st checking account #11868311 in joint names with an
approximate balance of $737.16 on March 7, 20o6;
(e) A Members 1st savings account #11868300 in joint names with an
approximate balance of $69o.14 on March 7, 2oo6;
(f) A Members 1st checking account #18460711 in Karl's individual
name with an approximate balance of $1,550.62 on March 7, 20o6;
(g) A Members 1St savings account #18460700 in Karl's individual
name with an approximate balance of $6,958.47 on March 7, 20o6.
The parties agree that Karen shall become the sole and exclusive owner of the
Members 1St checking account #3128211; the Members 1st savings account #3128200;
the Members 1st holiday club account #3128202; the Members 1st checking account
#11868311; and the Members 1St savings account #11868300. The parties agree to close
the above accounts and/or remove Karl's name from the above accounts within ten (1o)
days of the execution of this Agreement.
The parties agree that Karl shall become the sole and exclusive owner of the
Members 1St checking account #18460711 and the Members 1st savings account
#18460700.
Karen and Karl agree that there are no other marital bank accounts.
15. Pension/Retirement Benefits:
they have the following pension/retirement benefits:
The parties acknowledge that
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(a) Pinnacle Health 403(b) in Karen's name with a balance of
$43553.74 on December 31, 2005;
(b) Pinnacle Health pension in Karen's name;
(c) TIAA CREF with Hershey Medical Center in Karen's name with a
balance of $8,795.79 on October 26, 2006;
(d) Hitachi 401(k) in Karl's name with an approximate marital balance
of $199,482.65 on September 10, 2006;
(e) Hitachi pension with an account balance of $71,003.30 on May 17,
2006;
(f) Wachovia IRA in Karl's name with a balance of $29695.95 on
March 7, 2006;
(g) Unysis pension in Karl's name.
Karen and Karl agree that Karen shall receive $137,500.00 from Karl's Hitachi
401(k) plus any increase or decrease on that amount attributable to the investment
performance of Karl's 401(k) account between September 10, 2006 and the date of
distribution and which are not attributable to Karl's individual contributions after
September 10, 2006. The parties agree that Karl shall become the sole and exclusive
owner of the remaining funds in his Hitachi 401(k). Karen and Karl agree that Maryann
Murphy, Esquire shall promptly prepare a Qualified Domestic Relations Order (QDRO),
and they further agree to execute the QDRO and any and all other documents necessary
to effectuate the terms of this agreement.
The parties agree that Karl shall become the sole and exclusive owner of his
Hitachi pension, his Wachovia IRA and his Unysis pension; and that Karen shall
become the sole and exclusive owner of her Pinnacle Health 403(b), her Pinnacle Health
pension and her TIAA CREF with Hershey Medical Center. Both parties agree to
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execute, upon request, any and all documents necessary to effectuate the terms of this
agreement.
Karen and Karl waive their respective rights to obtain current values of the
pension/ retirement benefits and determine the marital portion.
16. Waiver ofBeneficiaru Designations: Unless otherwise specifically
set forth in this Agreement, each party hereto specifically waives any and all beneficiary
rights and any and all rights as a surviving spouse in and to any asset, benefit or like
program carrying a beneficiary designation which belongs to the other party under the
terms of this Agreement, including, but not limited to pensions and retirement plans of
any sort or nature, deferred compensation plans, life insurance policies, annuities, stock
accounts, bank accounts, final pay checks or any other post-death distribution scheme.
The parties by the terms of this Agreement specifically waive the rights of spouse
beneficiaries established by federal or state statute including ERISA. Each party
expressly states that it is his or her intention to revoke by the terms of this Agreement
any beneficiary designations naming the other party which are in effect as of the date of
execution of this Agreement. If the other party continues to be named as beneficiary
and no alternate beneficiary is otherwise designated, the beneficiary shall be deemed to
be the estate of the deceased party. Not withstanding the foregoing, however, in the
event that either party hereto specifically designates the other party as a beneficiary
after the date of execution of this Agreement, then this waiver provision shall not bar
that party from qualifying as such beneficiary.
17. Motor Vehicles: The parties agree that Karen shall have sole and
exclusive ownership and possession of the 2003 Nissan Altima. Karen agrees to be
solely and exclusively responsible for the balance of the joint loan on this vehicle, and
she further agrees to indemnify Karl and hold him harmless from any and all liability for
W 11 W
same. After the loan is paid in full, Karl agrees to transfer the title of the 2003 Nissan
Altima to Karen's individual name. Upon request, Karl agrees to sign a Power of
Attorney for Karen to use to transfer the title of the Nissan Altima when the car loan is
paid or the vehicle is traded.
The parties agree that Karl shall have sole and exclusive ownership and
possession of the 1999 Nissan Maxima. Karl agrees to be solely an exclusively
responsible for the balance of the loan in his individual name, and he further agrees to
indemnify Karen and hold her harmless from any and all liability for same.
Karen and Karl agree that Karen shall have sole and exclusive ownership of the
1999 Volkswagen Beetle, currently titled in Karen's individual name and driven by Sara.
Karen agrees to be solely and exclusively responsible for the balance of the loan on the
1999 Volkswagen, and she further agrees to indemnify Karl and hold him harmless from
any and all liability for same. The parties acknowledge that Karen reserves the right to
transfer the title of the 1999 Volkswagen and the balance of that car loan to Sara.
Karen and Karl agree that Karl shall have sole and exclusive ownership of the
1998 Honda, currently titled in Karl's individual name and driven by Ben. The parties
agree that there is no loan on the 1998 Honda. The parties acknowledge that Karl
reserves the right to transfer the title of the 1998 Honda to Ben.
18. After Acquired Personal Property: Each of the parties shall hereafter
own and enjoy, independently of any claims or right of the other, all items of personal
property, tangible or intangible, hereafter acquired by him or her, 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.
19. Applicability of Tax Law to Property Transfers: The parties
hereby agree and express their intent that any transfers of property pursuant to this
12
Agreement shall be within the scope and applicability of the Deficit Reduction Act of
1984 (herein the "Act"), specifically, the provisions of said Act pertaining to transfers of
property between spouses or former spouses. The parties agree to sign and cause to be
filed any elections or other documents required by the Internal Revenue Service to
render the Act applicable to the transfers set forth in this Agreement, without
recognition of gain on such transfer and subject to the carry-over basis provisions of
said Act.
20. Income Tax ReturnsZDependency Exemptions: The parties
agree that Karl shall claim the taxes and the mortgage interest for the marital residence
on his income tax returns for 2007.
The parties further agree that, for so long as they are able by law to do so, Karen
shall claim Ben as a dependent on her income tax returns, and Karl shall claim Sara as a
dependent on his income tax returns.
21. Legal Fees: The parties agree that each of them shall be responsible for
paying her/his own attorney's fees.
22. Spousal SupportJAlimonu Pendente Lite/AIimony: Karl agrees to
pay Karen $2,500.00 per month in maintenance/spousal support/alimony pendente
lite/alimony for a total of one hundred twenty (120) months commencing September 1,
2007 and ending on August 31, 2017.
The amount and duration of the payments shall be nonmodifiable, and shall
completely terminate upon the first of the following conditions: the death of either
party; Karen's cohabitation with a member of the opposite sex who is not within the
degree of consanguinity; Karen's remarriage; or August 31, 2017.
01J 13 W
The parties acknowledge that, through the Collaborative Law Process, Karl has
been paying spousal support to Karen in the amount of $2,500.00 per month under a
Support Agreement since January 1, 2007.
In consideration for Karl's voluntary and conscientious payments of spousal
support to Karen since their date of separation, Karen agrees that alimony payments
shall be paid directly from Karl to Karen by the tenth (loth) day of each month, and shall
not be wage attached through the Domestic Relations Section. Only in the event of Karl's
failure to make monthly alimony payments by the tenth (loth) day of each month shall
Karen reserve the right to have this agreement enforced through the Domestic Relations
Section.
Maintenance/spousal support/alimony pendente lite/alimony shall be includible
as income to Karen and deductible to Karl on their tax returns.
23. Life Insurance: The parties acknowledge that Karl currently has life
insurance in the amount of $50,000.00 through his employer, Compellent
Technologies, Inc. Within two (2) weeks of the execution of this Agreement, Karl agrees
to name Sara and Ben as beneficiaries of this life insurance policy for so long as it is
available to him through his employer.
Karl agrees to permit Karen to purchase an insurance policy on his life and shall
cooperate by promptly completing and mailing the application, answering any questions
required regarding his health, submitting to any medical examinations, and providing
any medical documents necessary to complete the application. Karen agrees to be solely
responsible for any costs incurred by Karl in complying with the insurance company's
requirements.
24. Children's Needs: Karl agrees to pay Sara's and Benjamin's college
tuition, room and board, and college loans taken out by the children individually or by
?ti3 14 K«8
Karl. It is anticipated that Sara will graduate in June of 20o8 and Ben will graduate in
June of 2010.
25. Full Disclosure: Karen and Karl each represent and warrant to the
other that, through the Collaborative Law Process, he or she has made a full and
complete disclosure to the other of all assets of any nature whatsoever and of every type
whatsoever in which such party has an interest, and of all other facts relating to the
subject matter of this Agreement.
26. Disclosure and Waiver of Procedural Rights: Each party
understands that he or she has the right to obtain from the other party a complete
inventory or list of all of the property that either or both parties own at this time or
owned as of the date of separation, and that each party has the right to have all such
property valued by means of appraisals or otherwise. Both parties understand that they
have the right to have the Court hold hearings and make decisions on the matters
covered by this Agreement. Both parties understand that a Court decision concerning
the parties' respective rights and obligations might be different from the provisions of
this Agreement.
Both parties waive the following procedural rights:
(a) The right to obtain an Inventory and Appraisement of all marital
and separate property as defined by the Pennsylvania Divorce Code;
(b) The right to obtain an Income and Expense Statement of the other
party as provided by the Pennsylvania Divorce Code;
(c) The right to have the Court determine which property is marital and
which is non-marital and equitably distribute between the parties that property which
the Court determines to be marital;
1z 3 15 KRe
(d) The right to have the Court decide any other rights, remedies,
privileges, or obligations covered by this Agreement, including but not limited to,
possible claims for divorce, spousal support, alimony, alimony pendente lite, counsel
fees, costs and expenses.
27. Waiver or Modification to be in Writing: No modification or
waiver of any of the terms hereof shall be valid unless in writing and signed by both
parties and no waiver of any breach hereof or default hereunder shall be deemed a
waiver of any subsequent default of the same or similar nature.
28. Mutual Cooperation: Each party shall, at any time and from time to
time hereafter, take any and all steps and execute, acknowledge and deliver to the other
parry any and all further instruments and/or documents that the other parry may
reasonably require for the purpose of giving full force and effect to the provisions of this
Agreement.
29. Applicable Law: This Agreement shall be construed in accordance with
the laws of the Commonwealth of Pennsylvania which are in effect as of the date of
execution of this Agreement.
30. Agreement Binding on Heirs: This Agreement shall be binding and
shall inure to the benefits of the parties hereto and their respective heirs, executors,
administrators, successors and assigns.
31. Integration: This Agreement constitutes the entire understanding of the
parties and supersedes any and all prior agreements and negotiations between them.
There are no representations or warranties other than those expressly set forth herein.
32. Other Documentation: Karen and Karl covenant and agree that they
will forthwith execute any and all written instruments, assignments, releases,
_JU3 16 --
satisfactions, deeds, notes or such other writings as may be necessary or desirable for
the proper effectuation of this Agreement.
33• No Waiver on Default: This Agreement shall remain in full force and
effect unless and until terminated under and pursuant to the terms of this Agreement.
The failure of either parry to insist upon strict performance of any of the provisions of
this Agreement shall in no way affect the right of such parry hereafter to enforce the
same, nor shall the waiver of any default or breach of any provisions hereof be construed
as a waiver of any subsequent default or breach of the same or similar nature, nor shall
it be construed as a waiver of strict performance of any other obligations herein.
34• Severabilitu: If any term, condition, clause or provision of this
Agreement shall be determined or declared to be void or invalid in law or otherwise,
then only that term, condition, clause or provision shall be stricken from this Agreement
and in all other respects this Agreement shall be valid and continue in full force, effect
and operation. Likewise, the failure of any party to meet his or her obligation under any
one or more of the paragraphs herein, with the exception of the satisfaction of the
conditions precedent, shall in no way void or alter the remaining obligations of the
parties.
35• Enforcement of Agreement: If either party believes that the other
party has breached any provision of this Agreement, the parties agree to return to the
Collaborative Law Process or seek mediation to resolve the issue. If the parties are
unable to resolve the issues through the Collaborative Law Process or mediation, a 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 parry breaching this
contract shall be responsible for payment of reasonable legal fees and costs incurred by
the other in enforcing their rights under this agreement.
(C -D 17
36. Headings Not Part o,?'Acnreement: Any heading preceding the text of
the several paragraphs and subparagraphs hereof are inserted solely for convenience of
reference and shall not constitute a part of this Agreement nor shall they affect its
meaning, construction or effect.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals
this day and year first above written.
?r- 6rol J. Lindsay, Esquire
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Maryann urphy, Esquir
KAREN L. BECHTOLD
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN'T'Y, PENNSYLVANIA
CIVIL ACTION -- LAW
KARL R. BECHTOLD,
Plaintiff
:No. o6-2781 Civil Term
V.
IN DIVORCE
KAREN L. BECHTOLD,
Defendant
PRAECIPE TO TRANSMIT RECORD
To The Prothonotary:
Transmit the record, together with the following information, to the Court for entry
of a divorce decree:
1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the
Divorce Code.
2. Date and Manner of service of the Complaint: Sent by U.S. first class mail,
postage prepaid on May 19, 2oo6 to Carol J Lindsay„ Esquire, counsel for Karen L
Bechtold, at Saidis. Shuff. Flower & Lindsay, 26 West High Street, Carlisle, PA 17013.
Acceptance of Service signed by Carol J. Lindsay, Esquire dated May 23, 2oo6. Affidavit of
Service filed on June 6.20o6.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the
Divorce Code: by Plaintiff, September 24, 2ooz: by Defendant, September 21, 2007.
(b)(1) Date of execution of the Plaintiff's Affidavit required by Section 3301(d) of the
Divorce Code: -NA
(2) Date of filing and service of the Plaintiffs Affidavit upon Defendant: -N LA.
4. Related claims pending: All claims have been resolved by the Marital
Settlement Agreement dated September 94, 200Z
5. Complete either paragraph (a) or (b).
(a) Date and manner of service of the notice of intention to file Praecipe to
Transmit Record, a copy of which is attached: N/A.
(b) Date Plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with
the Prothonotary: October 2,_200'7.
Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with
the Prothonotary: October 3, 2007.
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Maryann Murphy, Esquire
PMB 246
4902 Carlisle Pike
Mechanicsburg, PA 17050
(717) 730-0422
I.D. #61900
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
KARL R. BECHTOLDS
Plaintiff
NO. 06-2781 Civil Term
VERSUS
KAREN L. BECHTOLD,
Defendant
DECREE IN
DIVORCE
AND NOW,
Ockdoes 0.
2007 , IT IS ORDERED AND
DECREED THAT KARL R. BECHTOLD , PLAINTIFF,
AND KAREN L. BECHTOLD 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 Marital Settlement Agreement, dated September 24, 2007, is
hereby incorporated, but not merged, into the Divorce Decree
BY THE COURT:
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A PEST: J. I ') rA . '-.0 1 C? I PROTHOi('ll OTARY
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.s JAN 15 2008
Maryann Murphy, Esquire
PMP 246
4902 Carlisle Pike
Mechanicsburg, PA 17o5o
(717) 730-0422
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
KARL R. BECHTOLD,
Plaintiff
V.
KAREN L. BECHTOLD,
Defendant
:No. o6-2781 Civil Term
IN DIVORCE
01 AL FIEn DOME MC RELATIONS ORDER
For the Hitachi Data Systems Retirement and Savings Program
AND NOW, this ?day of 2007, upon the representations and
stipulations of Plaintiff and Defendant in the above-captioned matter, it is ordered and
decreed as follows:
1. This Order creates and recognizes the existence of an Alternate Payee's right
to receive a portion of the Participant's Benefits accumulated under an employer sponsored
Plan which is qualified under Section 401 of the Internal Revenue Code of 1986, as
amended (the "Code") and the Employee Retirement Income Security Act of 1974, as
amended ("ERISA" ). It is intended to constitute a Qualified Domestic Relations Order
("QDRO") under Section 414(P) of the Code and Section 2o6(d) (3) of ERISA, as amended.
2. The name, address, birth date and Social Security number of the "Participant"
are:
Participant:
Birth Date:
Social Security Number:
Address:
Karl R. Bechtold
to/1/196o
177--52-3712
3oo A 3rd Avenue N.W.
Conover, N.C. 2861.3
3. The name, address, birth date and Social Security number
of the "Alternate Payee", former spouse, are:
Alternate Payee:
Birth Date:
Social Security Number:
Address:
Karen L. Bechtold
05/11/1961
200-52-0106
600 Yale Street, Unit 16o8
Harrisburg, PA 17111
4. The name of the Plan to which this Order applies is Hitachi Data Systems
Retirement and Savings Program (hereinafter referred to as the "Plan").
The Plan Administrator of the Plan is:
c/o Retirement Committee
Attn: Susan Ramirez
750 Central Expressway
MS 32/66, P.O. Box 54996
Santa Clara, CA 95056
Further, any successor plan to the Plan shall also be subject to the terms of this
Order.
5. The Plan, Participant and Alternate Payee are ordered to keep one another
and the Plan Administrator timely apprised of their current address for receipt of notices.
6. Subject to the limitation of the Plan, Participant and Alternate Payee shall
have maximum choice and discretion in dealing with their respective benefit entitlements
without interference by or to the other.
7. This Order is entered in accordance with the Internal Revenue Code of 1986,
as amended.
8. This Order relates to the provision of marital property rights to the Alternate
Payee under the Pennsylvania Divorce Code, 23 Pa.C.S. §§3301 et seq.
9. Alternate Payee's interest in the Plan shall be an amount equal to $137,500.00
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(Alternate Payee's Interest).
10. Upon Alternate Payee's request for an immediate distribution, as soon as
administratively feasible after the date this Order is determined to be a QDRO by the Plan
Administrator, the Plan shall distribute Alternate Payee's Interest plus the investment
earnings/losses attributable to such amount from September 10, 2006 to the date
distribution is made to the Alternate Payee, in a single lump sum payment directly to
Alternate Payee, or at the direction of Alternate Payee, to an Individual Retirement
Account. The Alternate Payee shall complete such distribution forms as may be required
under the terms of the Plan.
11. In the event Alternate Payee does not request an immediate distribution, as
soon as administratively feasible after this Order is determined to be a QDRO by the Plan
Administrator, the Alternate Payee's Interest plus the earnings/losses attributable to such
amount from September 10, 2oo6 to the date of separation, shall be separated from the
Participant's interest in the account and will be held by the Plan in a separate account for
the Alternate Payee until distribution. Such separate account will be credited with its
allocable share of the income and losses of the Plan but shall not be credited with any future
contributions or forfeitures. Alternate Payee shall have the same ability to designate the
investment of the amounts in the separate account as the Participant would otherwise have
had with respect to those amounts. In accordance with the Plan, as soon as administratively
feasible after Participant's Normal Retirement, death or termination of employment with
Hitachi Data Systems and any Related Company or Subsidiary covered by the Plan, or at
such earlier time as Alternate Payee may request in writing, the Plan shall distribute the
amount in Alternate Payee's separate account to Alternate Payee in a single lump sum
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payment directly or, at the direction of the Alternate Payee, to an Individual Retirement
Account. The Alternate Payee shall complete such distribution forms as may be required
under the terms of the Plan.
12. With respect to Alternate Payee's Interest in the Plan, the Alternate Payee may
designate a beneficiary on the appropriate form provided by the Plan Administrator. In the
event that Alternate Payee dies prior to payment of benefits pursuant to this Order, such
benefits shall be paid to Alternate Payee's designated beneficiary, if any, otherwise to
Alternate Payee's estate. If the Participant dies before the payment of benefits, payment of
the amount in Alternate Payee's separate account shall nonetheless be made under the
terms of this Order to Alternate Payee.
13. For purposes of Sections 402(a) (2) and 72 of the Internal Revenue Code, any
Alternate Payee who is the spouse or former spouse of the Participant shall be treated as the
distributee of any distribution or payments made to the Alternate Payee under the terms of
this Order, and as such, will be required to pay the appropriate federal income taxes on such
distribution. The Plan shall withhold taxes as required by law at the time of distribution.
The Alternate Payee shall have the right to roll over the benefits distributed to her pursuant
to the terms and provisions of this Order to an eligible retirement plan such as an
Individual Retirement Account. Subject to the conditions imposed by ERISA and the
Internal Revenue Code, such transfer shall be considered a tax-free rollover of the benefits
distributed.
14. From the date of this Order and thereafter, the Participant shall have no
further right or interest in any portion of the Plan benefits which are assigned to the
Alternate Payee pursuant to this Order. Except as provided in this Order, Alternate Payee
shall have no further right or interest in any portion of Participant's Plan benefits.
15. The Plan shall not be required by the terms of this Order to provide any type
or form of benefit, or any option, not otherwise provided under the Plan, nor to increase the
amount of any benefits the Plan provides. The Order shall not require the Plan to provide
benefits to the Alternate Payee which are required to be paid to another Alternate Payee
under another order previously determined to be a QDRO, within the meaning of Section
414(p) of the Code and Section 2o6(d)(3) of ERISA. In the case of a conflict between the
terms of this Order and the Plan, the terms of the Plan shall prevail.
16. This Order shall not constitute a QDRO until such time that the Plan
Administrator determines that the Order is qualified under Section 414(p) of the Code and
Section 2o6(d)(3) of ERISA. In the event the Plan Administrator or its Agent does not
approve the form of this Order, then each party shall cooperate and do all things reasonably
necessary to devise a form of Order acceptable to the Plan Administrator.
17. Each party shall, upon receiving a request, perform any act reasonably
necessary to carry into effect or verify the carrying into effect of the terms of this Order.
18. Any reasonable costs incurred by the Plan Administrator to effectuate the
terms and provisions of the Qualified Domestic Relations Order shall be assessed against
the parties such that the Alternate Payee pays 50% of the costs and the Participant pays
50% of the costs.
19. Participant and Alternate Payee shall hold the Plan, its sponsors and
fiduciaries harmless from any liabilities which may arise regarding this Order, including all
costs and reasonable attorneys' fees that may be incurred in connection with any claims
asserted because the Plan honors this Order. The Plan shall not be responsible for attorneys'
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fees incurred by Participant or Alternate Payee in connection with obtaining or enforcing
this Order.
20. It is the intention of the parties that this QDRO continue to qualify as a QDRO
under Section 414(p) of the Code and Section 203(d)(3) of ERISA, as amended, and that the
Plan Administrator shall reserve the right to reconfirm the qualified status of the Order at
the time benefits become payable hereunder.
21. The Court shall retain jurisdiction with respect to this Order to the extent
required to maintain the original intent of the parties as stipulated herein.
22. The parties shall promptly submit this Order to the Plan Administrator for
determination of its status as a Qualified Domestic Relations Order.
23. A Decree in Divorce was entered by the Honorable M.L. Ebert, Jr. on October
17, 2007. Counsel for Plaintiff and Counsel for Attorney concur that this Qualified Domestic
Relations Order be entered by this Honorable Court.
IT IS INTENDED that this Order shall qualify as a Qualified Domestic Relations
Order and its provisions shall be administered and interpreted to conform within the
meaning of Section 414(p) of the Code and Section 203(d)(3) of ERISA, as amended. The
Court retains jurisdiction to amend this Order as might be necessary to establish or
maintain its status as a Qualified Domestic Relations Order within the meaning of Section
414(p) of the Code and Section 203(d)(3) of ERISA, as amended.
BY THE COURT:
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We hereby consent to the form and entry of the within Order:
41 1 .7
KARL R. BECHTOLD Date
KAREN L. BECHTOLD Date
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Mary a& Murphy, Esqui e
PMB 246
4902 Carlisle Pike
Mechanicsburg, PA 17050
(717) 730-0422
Carol J. Lin ay, quire
Saidis, Shufk F'lo er & Lindsay
26 West High Street
Carlisle, PA 17013
(717) 243-6222