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KENNETH F, LLOYD,
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PHYLLIS LLOYD,
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DECREE IN
DIVORCE
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AND NOW,...,..,.. m,'7" " /,~,,,.., 19.9,'-." it is ordered and
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are divorced from the bonds of matrimony.
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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; None, It is further ORDERED, ADJUDGED and DECREED that the
terms, provisions and conditions of a certain Property Settlement Agreement
between the parties dated April 1, 1996, and attached hereto, are incorporated
in' this' Decree' in' Divorce' by' reference'as' fUlly'as' if'the' same' were' set'forth
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jmb/ lloyd, sapsa
April 1, 1996
PROPERTY SETTLEMENT AGREEMENT
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THIS AGREEMENT, Made this J - day of ~
199~, by and between Kenneth F, Lloyd, hereinafter referred to as
"Husband", and Phyllis C, Lloyd, hereinafter referred to as "Wife",
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on
September 1, 1968; and
WHEREAS, three (3) children were born of this marriage,
namely, John, born December 3, 1969, Benjamin, born March 23, 1975,
and Daniel, born October 22, 1976; and
WHEREAS, certain differences have arisen between the
parties as a result of which they have separated and now live
separate and apart from one another, and 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 past, present and future support and/or
maintenance of Wife by Husband or of Husband by Wife; and in
general the settling of any and all claims and possible claims by
one against the other or against their respective estates for
equitable distribution of all marital property; and a resolution
of all mutual responsibilities and rights growing out of the
marriage relationship; and
WHEREAS, the parties hereto, after being properly advised
by their respective counsel, Husband by his attorney, John C.
Howett, Jr., Esquire, and Wife by her attorney, Sandra L. Meilton,
Esquire, have come to the following agreement,
NOW THEREFORE, in consideration of the above recitals and
the following covenants and promises mutually made and mutually to
be kept, the parties heretofore, intending to be legally bound and
to legally bind their heirs, successors and assigns thereby,
covenant, promise and agree as follows:
1, SEPARATION AND SUBSEOUENT RECONCILIATION:
hereafter to
or places as
It shall be lawful for each party at all times
live separate and apart from the other at such place
he or she may from time to time choose or deem fit,
shall not
The parties agree that the terms of this Agreement
be affected by their subsequent cohabitation or
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wife
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jrnb/lloyd,sapsa
April 1, 1996
resumption of marital relations unless the parties otherwise
specifically agree in writing,
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, Neither party shall molest the other
nor attempt to endeavor to molest the other, nor compel the other
to cohabit with the other, nor in any way harass or malign the
other, nor in any way interfere with the peaceful existence,
separate and apart from the other in all respects as if he or she
were single and unmarried,
3, WIFE'S DEBTS:
Wife represents and warrants to Husband that since
their separation on March 3, 1992 she has not, and in the future
she will not, contract or incur any debt or liability for which
Husband or his estate might be responsible and shall indemnify and
save Husband harmless from any and all claims or demands made
against him by reason of debts or obligations incurred by her.
4. HUSBAND'S DEBTS:
Husband represents and warrants to Wife that since
their separation on March 3, 1992 he has not, and in the future he
will not, contract or incur any debt or liability for which Wife
or her estate might be responsible and shall indemnify and save
Wife harmless from any and all claims or demands made against her
by reason of debts or obligations incurred by him,
5, OUTSTANDING JOINT DEBTS:
Husband and Wife acknowledge and agree that they
have no outstanding debts and obligations of the Husband and Wife
incurred prior to the signing of this Agreement, except as follows:
Debt
First Mortgage held by First Bank and
Trust in Mechanicsburg, Pennsylvania
Party Responsible
Second Mortgage held by Banc Boston
Mortgage Company
Wife
Wife agrees to pay the outstanding joint debts as
set forth herein and further agrees to indemnify and save harmless
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jmb/lloyd, sapsa
April 1, 1996
Husband from any and all claims and demands made against either of
them by reason of such debts or obligations.
In the event that either party contracted or
incurred any debts since the date of separation on March 3, 1992,
the party who incurred said debt shall be responsible for the
payment thereof regardless of the name in which the debt may have
been incurred,
6, MUTUAL RELEASE:
Subject to the provisions of this Agreement, each
party waives his or her right to. alimony and any further
distribution of property inasmuch as the parties hereto agree that
this Agreement provides for an equitable distribution of their
marital property in accordance with the Divorce Code of 1980.
Subject to the provisions of this Agreement, each party has
released and discharged, and by this Agreement does for himself or
herself, and his or her heirs, legal representatives, executors,
administrators and assigns, release and discharge the other of and
from all causes of action, claims, rights or demands whatsoever in
law or equity, which either of the parties ever had or now has
against the other, except any or all cause or causes of action for
divorce and except in any or all causes of action for breach of any
provisions of this Agreement. Each party also waives his or her
right to request marital counseling pursuant to 23 Pa,C.S,A.
Section 3302.
7, EOUITABLE DISTRIBUTION OF MARITAL PROPERTY:
The parties have attempted to distribute their
marital property in a manner which conforms to the criteria set
forth in 23 Pa.C.S,A, Section 3501 ~, ~, and taking into
account the following considerations: the length of the marriage;
the fact that it is the first marriage for both Husband and Wife,
the age, health, station, amount and sources of income, vocational
skills, employability, estate, liabilities and needs of each of the
parties; the contribution of each party to the education, training
or increased earning power of the other party; the opportunity of
each party for future acquisitions of capital assets and income;
the sources of income of both parties, including but not limited
to medical, retirement, insurance or other benefits; the
contribution or dissipation of each party in the acquisition,
preservation, depreciation or appreciation of the marital property,
including the contribution of each spouse as a homemaker; the value
of the property set apart to each party; the standard of living of
the parties established during the marriage; and the economic
circumstances of each party at the time the division of property
is to become effective,
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j mb/lloyd, sapsa
April 1, 1996
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
marital property, The division of property under this Agreement
shall be in full satisfaction of all marital rights of the parties,
A, DISTRIBUTION OF PERSONAL PROPERTY:
The parties hereto mutually agree that they have
effected a satisfactory division of the furniture, household
furnishings, appliances, and other household personal property
between them, and they mutually agree that each party shall from
and after the date hereof be the sole and separate owner of all
such tangible personal property presently in his or her possession,
except as set forth in Exhibit "A" attached hereto, which items
shall be distributed in accordance with Exhibit "A", and this
Agreement shall have the effect of an assignment or bill of sale
from each party to the other for such property as may be in the
individual possession of each of the parties hereto and as set
forth in Exhibit "A",
The parties hereto have divided between themselves,
to their mutual satisfaction, all items of tangible and intangible
marital property, Neither party shall make any claim to any such
items of marital property, or of the separate personal property of
either party, which are now in the possession and/or under the
control of the other, or which property will be distributed in
accordance with Exhibit "A" attached hereto, Should it become
necessary, the parties each agree to sign, upon request, any titles
or documents necessary to give effect to this paragraph, Property
shall be deemed to be in the possession or under the control of
either party if, in the case of tangible personal property, the
item is physically in the possession or control of the party at the
time of the signing of this Agreement and, in the case of
intangible personal property, if any physical or written evidence
of ownership, such as passbook, checkbook, policy or certificate
of insurance or other similar writing is in the possession or
control of the party, Husband and wife shall each be deemed to be
in the possession and control of his or her own individual pension
or other employee benefit plans or retirement benefits of any
nature with the exception of Social Security benefits to which
either party may have a vested or contingent right or interest at
the time of the signing of this Agreement, and neither will make
any claim against the other for any interest in such benefits,
From and after the date of the signing of this
Agreement, both parties shall have complete freedom of disposition
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jmb/lloyd,sapsa
April 1, 1996
as to his/her separate property and any property which is in their
possession or control pursuant to this Agreement and may mortgage,
sell, grant, convey, or otherwise encumber or dispose of such
property, whether real or personal, whether such property was
acquired before, during or after marriage, and neither Husband nor
Wife need join in, consent to, or acknowledge any deed, mortgage,
or other instrument of the other pertaining to such disposition of
property.
B, DISTRIBUTION OF REAL ESTATE:
Husband agrees to transfer to Wife immediately upon
the signing of this Agreement, all of his interest in and title to
their jointly-owned real estate at 1 Latchgate Lane, Mechanicsburg,
Cumberland County, Pennsylvania, with an approximate value of
$367,000 subject to the first and second mortgages, given to First
Bank and Trust in Mechanicsburg and Banc Boston Mortgage Company,
respectively, in exchange for which Wife agrees to be solely
responsible for the payment of all future mortgage payments, taxes,
insurance and utility bills relative to said real estate, Wife
covenants and agrees to pay and discharge the existing mortgage
obligation on said premises in accordance with its terms, until
such time as Wife has refinanced the real estate which refinancing
shall be pursued promptly by Wife and completed with due diligence;
the cost of which refinancing shall be shared by the parties with
Husband paying up to, but not more than, $2,000 of the refinancing
costs and with Wife being responsible for the balance. Husband
shall cooperate in all respects with wife's efforts to refinance,
In the event of her default, Wife agrees to indemnify Husband from
any loss by reason of her default in the payment thereof and agrees
to save Husband harmless from any future liability with regard
thereto.
C. MOTOR VEHICLES:
With respect to the motor vehicles owned by one or
both of the parties, they agree as follows:
(a) the 1994 Jeep Cherokee shall become the
sole and exclusive property of Wife subject to the lien held by
Farmer's Trust;
(b) the 1986 Toyota Celica shall become the
sole and exclusive property of Wife free and clear of all liens and
encumbrances;
(c) the 1990 Audi shall become the sole and
exclusive property of Husband free and clear of all liens and
encumbrances; and
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jmb/lloyd, sapsa
April 1, 1996
(d) the titles to the said motor vehicles
shall be executed by the parties, if appropriate for effecting
transfer as herein provided, on the date of execution of this
Agreement and the said executed title shall be delivered to the
proper parties on the distribution date.
D, TREASURY BONDS:
The parties have set aside Series EE Treasury Bonds
which had been purchased to help offset the children's education.
The parties agree that the Treasury Bonds, in Wife's possession,
shall become the property of Wife to help her offset the cost of
the 1994 Jeep, It is agreed that said Bonds have a current
surrender value under $5,200 and they specifically agree that Wife
is not entitled to Bonds totaling more than $5,200 in present
value.
Series EE Treasury Bonds in Husband's possession
(in the names of the children with Husband as beneficiary) in the
amount of $9,000 shall be retained by Husband and used by him for
the sole purpose of the children's college education,
E, BANK ACCOUNTS:
During the marriage, the parties had an account with
PNC Bank, Wife has continued to use this account since the
parties' separation and this account shall become her sole and
separate property, Husband shall retain the separate account with
PNC Bank which was opened after the parties' date of separation.
Each party waives all right, title and interest, if any, to the
accounts being retained by the other party,
F, INCENTIVE SAVINGS PLAN:
Wife shall receive $50,000 from Husband's Incentive
Savings Plan with Aetna Insurance Company, The funds shall be
transferred to her through the use of a Qualified Domestic
Relations Order to be prepared by Wife and paid for by Husband to
assure that there shall be no penalty or tax consequence to Husband
or Wife as a result of the transfer, Husband shall retain the
balance of his Incentive Savings Plan and Wife agrees to waive all
of her right, title and interest to the balance of the Incentive
Savings Plan and to sign any and all documents necessary to enforce
this provision.
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jmb/lloyd. sapsB
April 1, 1996
G, PENSION:
Husband shall retain his pension with his employer,
Aetna Insurance company, and Wife agrees to waive all of her right
title and interest to Husband's pension and to sign any and all
documents necessary to enforce this provision,
H, STOCK OPTIONS:
It is further understood between the parties that
Husband had stock options which were acquired during the marriage
and all of said options have been exercised, The proceeds from
those options have been utilized for the children's school, Since
the parties' date of separation, Husband has redeemed stock options
in the amount of $24,000, all of which options were acquired as a
result of work performed after the date of the parties' separation,
The proceeds from these stock options acquired after the date of
separation are currently held in a $23,000 Certificate of Deposit
with PNC Bank and shall be utilized to ensure funding for
Benjamin's undergraduate schooling.
I, DISTRIBUTION:
The parties agree that the distribution set forth
in this Agreement represents and was intended to effectuate
approximately a 57%-43% division of the marital assets in Wife's
favor and each party hereby acknowledges that this Agreement
accomplishes said intent,
J, TAX LIABILITY:
The parties believe and agree, and have been so
advised by their respective attorneys, that the division of
property heretofore made by this Agreement is a non-taxable
division of property between co-owners rather than a taxable sale
or exchange of such property, Each party promises not to take any
position with respect to the adjusted basis of the property
assigned to him or her or with respect to any other issue which is
inconsistent with the position set forth in the preceding sentence
on his or her Federal or State income tax returns,
8. LIFE INSURANCE:
Husband shall hereafter own all life insurance
policies insuring his life, Husband agrees to continue to maintain
in full force and effect sufficient life insurance coverage to
equal seventy-five percent of his outstanding obligations under
this Agreement, Husband's ownership of the policies shall be
subject to the following conditions:
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jmb/lloyd, sapsa
April 1, 1996
(a) He shall maintain the insurance in full
force and effect, paying all premiums due thereon and shall not
borrow against, assign, pledge, or otherwise encumber the
insurance, nor surrender it to obtain its cash value, if any, if
such actions would reduce the death benefit to an amount less than
is required to be provided hereunder;
(b) He shall immediately designate Phyllis C,
Lloyd, his Wife, as irrevocable beneficiary of so much of the
insurance as is necessary to provide the death benefit required
hereunder; and
(c) Within thirty (30) days after the
execution of this Agreement, Husband shall deliver to Wife or her
attorney satisfactory proof that the irrevocable beneficiary
designation has been properly endorsed on each insurance policy
and that the insurer has received notice of restrictions placed
upon Husband's ownership of the insurance by the terms of this
Agreement, Husband shall request that the carrier provide
'duplicate notice of premium default to Wife,
9, ALIMONY:
Husband agrees to pay Wife the sum of $2,500 per
month effective with the month of February 1996 and continuing
through and including the month of June, 2004. Payments shall be
made on or before the 15th day of each month,
A, Modification: If, prior to June, 2004,
Husband's salary decreases to an amount less than ninety percent
(90%) of his 1995 salary of $147,500 (i,e" to an amount less than
$132,750) through no voluntary action on Husband's part, the
alimony obligation shall be reduced to a monthly amount equal to
20% of Husband's revised annualized salary. Salary shall be deemed
to include payments received from W-2 income (excluding bonuses),
1099's and any other earned income, disability insurance proceeds,
workman's compensation insurance proceeds, or unemployment
proceeds.
Once Husband's salary decreases in an amount
sufficient to warrant a modification as defined above, the alimony
shall remain at that level unless Husband's salary increases by
10% or more, In that event, Husband's alimony obligation shall be
increased to a,monthly amount equal to 20% of Husband's revised
annualized income, In no event shall the alimony increase above
$30,000 per year.
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jmb/lloyd, sapsa
April 1, 1996
B, Extension of Alimony Beyond 2004: In and only
in the event that Husband is employed after June, 2004 and
continues to earn a comparable salary but not less than $130,000,
he shall continue to pay alimony to Wife in an amount calculated
in accordance with the formula set forth in this paragraph, If
Husband is not earning at least $130,000 as of June, 2004, alimony
stops. If Husband is earning $130,000 or more, alimony continues
based upon the formula set forth herein,
C, Conditions of Enforcement: Notwithstanding any
rights or remedies otherwise existing hereunder or at law, the
parties agree that in the event of any action by Wife to enforce
Husband's alimony obligations hereunder, Husband's assets, either
those awarded by the terms of this settlement or accumulated
thereafter, shall not be subject to attachment, encumbrance or
alienation or in any other manner removed from Husband's sole
possession and control. Husband's salary, as defined in this
paragraph 9, shall be subject to attachment,
D. Tax Status: Alimony payments required by this
paragraph shall be deductible to Husband and taxable to Wife and
shall terminate absolutely upon the death of either party, wife's
remarriage, or Wife's cohabitation with a person of the opposite
sex who is not a member of Wife's immediate family within the
degrees of consanguinity,
E, W-2 and 1099 Forms, etc,: If there has been
a modification of the amount of alimony as provided for in this
Agreement then, and in that event, Husband shall provide copies of
his W-2 forms, 1099 forms and listing of any other earned income
to Wife on or before April 15 of each year to determine the
accuracy of the alimony payments,
F, Acknowledqement: Wife acknowledges and agrees
that the provisions of this Agreement providing for the payment of
alimony to her by her Husband are fair, adequate, and satisfactory
to her and are based upon her actual need, her Husband's ability
to pay, the duration of the parties' marriage and other relevant
factors which have been taken into consideration by the parties.
The approval of this Agreement by a court of competent jurisdiction
in connection with an action in divorce or annulment filed by
Husband or Wife shall be deemed an order of the court and, except
to the extent limited by this Agreement, may be enforced as
provided in 23 Pa,C,S,A, ~3701,
Husband acknowledges and agrees that the
provisions of this Agreement providing for equitable distribution
of marital property are fair, adequate and satisfactory to him and
are accepted by him in lieu of and in full and final settlement and
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jrnb/lloyd, sapea
April 1, 1996
satisfaction of any claims or demands that he may now or hereafter
have against Wife for support, maintenance or alimony, Husband
further voluntarily and intelligently waives and relinquishes any
right to seek from Wife any payment for support or alimony,
10, DISABILITY INSURANCE:
Husband agrees to purchase disability insurance for
Wife, The disability coverage shall be sufficient to provide Wife
with $1,400 per month net income and shall be provided by Husband
for eight and one-half (8 1/2) years from the date of the signing
of this Agreement, The disability coverage shall have a waiting
period not in exceos of ninety (90) days, Husband shall be
entitled to claim the premium payments for the disability insurance
as alimony, deductible to Husband and taxable to Wife, but shall
reimburse to Wife the additional federal, state or local income tax
which Wife is required to pay as a result of her having to claim
the disability insurance premium payments as income.
Notwithstanding the foregoing, Husband's obligation hereunder shall
not exceed a policy cost of $1,000 per year, and in the event the
premium exceeds said amount, Husband shall be excused from any
responsibility hereunder unless Wife agrees to pay any additional
premium necessary to obtain the above-described policy, Any
obligation of Husband hereunder shall terminate on the first to
occur of the death of either party or the termination of alimony
for any other reason under paragraph 9 hereinabove.
11, ALIMONY PENDENTE LITE:
Husband and Wife acknowledge and agree that the
provisions of this Agreement providing for the equitable
distribution of marital property of the parties are fair, adequate
and satisfactory to them, Both parties agree to accept the
provisions set forth in this Agreement in lieu of and in full and
final settlement and satisfaction of all claims and demands that
either may now or hereafter have against the other for alimony
pendente lite or any other provision for their support and
maintenance before, during and after the commencement of any
proceedings for divorce or annulment between the parties.
12. WIFE'S COUNSEL FEES:
Husband agrees to pay wife's counsel fees and
expenses,
13. INCOME TAX RETURNS:
The parties agree to file joint federal and state
tax returns for tax year 1995. Further, the parties have
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jmb/lloyd, sapsa
April 1, 1996
heretofore filed joint federal and state tax returns and both
parties agree that in the event any deficiency in federal, state
or local income tax is proposed, or any assessment of any such tax
is made against either of them, each will indemnify and hold
harmless the other from and against any loss or liability for any
such tax deficiency or assessment and any interest, penalty and
expense incurred in connection therewith, such tax, interest,
penalty or expense shall be paid solely and entirely by the
individual who is finally determined to be the cause of the
misrepresentations or failures to disclose the nature and extent
of his or her separate income on the aforesaid joint returns,
14, WAIVERS OF CLAIMS AGAINST ESTATES:
Except as herein otherwise provided, each party may
dispose of his or her property in any way, and each party hereby
waives and relinquishes any and all rights he or she may now have
or hereafter acquire, under the present or future laws of any
jurisdiction, to share in the property or the estate of the other
as a result of the marital relationship, including without
limitation, dower, curtesy, statutory allowance, widow's allowance,
right to take in intestacy, right to take against the will of the
other, and right to act as administrator or executor of the other's
estate, Each will, at the request of the other, execute,
acknowledge and deliver any and all instruments which may be
necessary or advisable to carry into effect this mutual waiver and
relinquishment of all such interests, rights and claims.
15, MUTUAL CONSENT DIVORCE:
The parties agree and acknowledge that their
marriage is irretrievably broken, that they do not desire marital
counseling, and that they both consent to the entry of a decree in
divorce pursuant to 23 Pa.C,S,A, Section 3301(C), Accordingly,
both parties agree to forthwith execute such consents, affidavits,
or other documents and to direct their respective attorneys to
forthwith file such consents, affidavits, or other documents as may
be necessary to promptly proceed to obtain a divorce pursuant to
said 23 Pa.C,S,A, Section 3301(c), Upon request, to the extent
permitted by law and the applicable Rules of Civil Procedure, the
named defendant in such divorce action shall execute any waivers
of notice or other waivers necessary to expedite such divorce.
It is the intention of the parties that this
Agreement shall survive any action for divorce which may be
instituted or prosecuted by either party and no order, judgment or
decree of divorce, temporary, final or permanent, shall affect or
modify the financial terms of this Agreement, This Agreement shall
be incorporated in but shall not merge into any such judgment or
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jmb/lloyd, sapsa
April 1, 1996
decree of final divorce, but shall be incorporated for the purposes
of enforcement only.
16, BREACH AND ENFORCEMENT:
If either party breaches any provision of this
Agreement, the other party shall have the right, at his or her
election, to sue for damages for such breach, or seek such other
remedies or relief including, but not limited to set-off, as may
be available to him or her, and the party breaching this Agreement
shall be responsible for payment of legal fees and costs incurred
by the other in enforcing his or her rights under this Agreement,
17, ADDITIONAL INSTRUMENTS:
Each of the parties shall from time to time, at the
request of the other, execute, acknowledge and deliver to the other
party any and all further instruments that may be reasonably
required to give full force and effect to the provisions of this
Agreement,
18, TAX ADVICE:
Both parties hereto hereby acknowledge and agree
that they have had the opportunity to retain their own accountants,
certified public accounts, tax advisor, or tax attorney with
reference to the tax implications of this Agreement, Further,
neither party has been given any tax advice whatsoever by their
respective attorneys, Further both parties hereby acknowledge that
they have been advised, by their respective attorneys, to seek
their own independent tax advice by retaining an accountant,
certified public account, tax attorney, or tax advisor with
reference to the tax implications involved in this Agreement,
Further, the parties acknowledge and agree that their signatures
to this Agreement serve as their acknowledgment that they have read
this particular paragraph and have had the opportunity to seek
independent tax advice,
19. VOLUNTARY EXECUTION:
The provisions of this Agreement and their legal
effect have been fully explained to the parties by their respective
counsel, and each party acknowledges that the Agreement is fair and
equitable, that it is being entered into voluntarily, with full
knowledge of the assets of both parties, and that it is not the
result of any duress or undue influence, The parties acknowledge
that they have been furnished with all information relating to the
financial affairs of the other which has been requested by each of
them or by their respective counsel.
- 12 -
jrnb/lloyd, sapsa
April 1, 1996
20. ENTIRE AGREEMENT:
This Agreement contains the entire understanding of
the parties and there are no representations, warranties, covenants
or undertakings other than those expressly set forth herein,
Husband and Wife acknowledge and agree that the provisions of this
Agreement with respect to the distribution and division of marital
and separate property are fair, equitable and satisfactory to them
based on the length of their marriage and other relevant factors
which have been taken into consideration by the parties, Both
parties hereby accept the provisions of this Agreement with respect
to the division of property in lieu of and in full and final
settlement and satisfaction of all claims and demands that they may
now have or hereafter have against the other for equitable
distribution of their property by any court of competent
jurisdiction pursuant to 23 Pa,C,S,A, Section 3501 ~. ~ or any
other laws, Husband and Wife each voluntarily and intelligently
waive and relinquish any right to seek a court ordered
determination and distribution of marital property, but nothing
herein contained shall constitute a waiver by either party of any
rights to seek the relief of any court for the purpose of enforcing
the provisions of this Agreement,
21. DISCLOSURE:
Husband and Wife each represent and warrant to the
other that he or she has made a full and complete disclosure to the
other of all assets of any nature whatsoever in which such party
has an interest, the sources and amount of the income of such party
or every type whatsoever and of all other facts relating to the
subject matter of this Agreement.
22. MODIFICATION AND WAIVER:
A modification or waiver of any of the provisions
of this Agreement shall be effective only if made in writing and
executed with the same formality as this Agreement, The failure
of either party to insist upon strict performance of any of the
provisions of this Agreement shall not be construed as a waiver of
any subsequent default of the same or similar nature.
23, PRIOR AGREEMENT:
It is understood and agreed that any and all
property settlement agreements which mayor have been executed
prior to the date and time of this Agreement are null and void and
of no effect.
- 13 -
.
jmb/lloyd. sapliIa
April 1, 1996
24, DESCRIPTIVE HEADINGS:
The descriptive headings used herein are
only. They shall have no effect whatsoever
the rights or obligations of the parties,
for
in
convenience
determining
25, INDEPENDENT SEPARATE COVENANTS:
It is specifically understood and agreed by and
between the parties hereto that each paragraph hereof shall be
deemed to be a separate and independent covenant and agreement,
26, APPLICABLE LAW:
This Agreement shall be construed under the laws of
the Commonwealth of Pennsylvania.
27, VOID CLAUSES:
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,
28, AGREEMENT BINDING ON HEIRS:
This Agreement shall be binding and shall inure to
the benefit of the parties hereto and their respective heirs,
executors, administrators, successors, and assigns.
IN WITNESS WHEREOF, the parties hereto have set their
Hands and Seals the day and year first above written,
cJL r /J+
(SEAL)
Ke
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pE1h. Ll~901L (SEALI
- 14 -
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jmb/lloyd.sapaa
April 1, 1996
Husband shall retain the following items:
Pool table
Family and personal photos:
Husband shall have the right to copy, at his sole
expense, such family and personal photos (presently in
Wife's possession or control) as he shall, in his sole
discretion, desire, Wife shall cooperate in allowing
Husband access to said photos for the purposes herein set
forth,
EXHIBIT "A"
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ~~
On this, the I * day of
)
(
)
SS:
~
, 199~, before
me, a Notary Public, the undersigned officer, personally appeared
Kenneth F. Lloyd, known to me (or satisfactorily proven) to be the
person whose name is subscribed to the foregoing Property
Settlement Agreement and acknowledged that he executed the Game
for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
NOTAI\:Al SEAL
OEDRA M fH;!~P, Notary Public
Htr:ll<;~ro, Ct3u~hl~ County, PA
My Comr::isslor. Expires Augu5123, 11187
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.
COMMONWEALTH OF PENNSYLVANIA )
( SS:
COUNTY OF DAlJPH IN )
On this, the I -tlt day of
~
, 199~, before
me, a Notary Public, the undersigned officer, personally appeared
Phyllis C. Lloyd, known to me (or satisfactorily proven) to be the
person whose name is subscribed to the foregoing Property
Settlement Agreement and acknowledged that she executed the same
for the purposes therein contained,
Notarial Seal
Jacquelyn A. Zenlemoyer, Notery Public
Harrisburg. Dauphin County
My Commission Expires Jan, 29. 1999
MembeI. Pennsytvar1aAssoc:iaron c1 NoIatfes
IN WITNESS WHEREOF, I hereunto set my hand and official seal,
~Q.~
Notary ublic
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KENNETH F. LLOYD, )
Plaintiff )
)
v, ) NO, 1294 CIVIL 1994
)
PHYLLIS LLOYD, ) CIVIL ACTION - LAW
Defendant ) 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:
1. Ground for divorce: Irretrievable breakdown under
(Xl section 3301(cl ( I section 3301(dl of the Divorce Code,
(Check applicable section).
2. Date and manner of service of the complaint: Service bv
certified mail, restricted deliverv, return receipt reauested,
sianed for bv Defendant Phvllis Llovd on March 19. 1994, as per
the Affidavit of Service filed contemporaneouslv herewith.
3. Date of execution of the affidavit of consent required
by section 3301(c) of the Divorce Code: by plaintiff,
April 29, 1996; by defendant, April 1, 1996.
4. Related claims pending: No claims filed: no claims
pendina.
I
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Date:
4--)1 ,-q~
ohn
OWE , KISSINGER
1 Walnut Street
P,O. Box 810
Harrisburg, PA 17108
Telephone: 717/234-2616
Counsel for Plaintiff
Kenneth F. Lloyd
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KENNETH F. LLOYD, ) IN THE COURT OF COMMON PLEAS OF
plaintiff ) CUMBERLAND COUNTY, PENNSYLVANIA
) NO. f.J f/4
v. ) CIVIL 1994
)
PHYLLIS LLOYD, ) CIVIL ACTION - LAW
Defendant ) IN DIVORCE
NOTICE TO DBPEND AND CUZM RZGHTS
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 counselling.
A list of marriage counsellors is available in the Office of the
Prothonotary, Dauphin County Courthouse, Front & Market streets,
Harrisburg, Pennsylvania, 17101.
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.
Lawyer Referral Service
Cumberland County Courthouse
Court Administrator, 4th Floor
1 Courthouse square
Carlisle, PA 17013
Telephone: (717) 240-6200
,.
KENNETH F. LLOYD, ) IN THE COURT OF COMMON PLEAS OF
plaintiff ) CUMBERLAND COUNTY, PENNSYLVANIA
)
v. ) NO. 1.:.1. f'l CIVIL 1994
)
PHYLLIS LLOYD, ) CIVIL ACTION - LAW
Defendant ) IN DIVORCE
COMPLAXNT XN DXVORCB
Plaintiff Kenneth F. Lloyd, by and through his counsel,
Howett, Kissinger & Miles, P.c., hereby files this Complaint in
Divorce and in support thereof avers the following:
1. Plaintiff is Kenneth F. Lloyd, an adult individual
who currently resides at 1119 Nanroc Drive, Mechanicsburg,
Cumberland County, Pennsylvania, 17055.
2. Defendant is Phyllis Lloyd, an adult individual
who currently resides at 1 Latchgate Lane, Mechanicsburg,
Cumberland County, Pennsylvania, 17055.
3. Both the Plaintiff and Defendant have been bona
fide residents in the Commonwealth of Pennsylvania for at least
six (6) months immediately previous to the filing of this
Complaint.
4. The Plaintiff and Defendant were married on
September 1, 1968 in Reading, Pennsylvania.
5. There have been no prior actions for divorce or
for annulment of the marriage between the parties instituted by
either of them in this or any other jurisdiction.
6. Neither Plaintiff nor Defendant is in the military
or naval service of the United States or its allies within the
~
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provisions of the Soldiers' and Sailors' civil Relief Act of the
congress of 1940 and its amendments.
7. plaintiff has been advised that counselling is
available and that plaintiff may have the right to request that
the court require the parties to participate in counselling.
8. The marriage of the parties is irretrievably
broken.
9. The parties have lived separate and apart since on
or about February, 1992.
10. plaintiff requests the court to enter a decree of
divorce.
Respectfully submitted,
Date:
0}f
e~
John . Howett, Jr., squire
HOWETT, KISSINGER & MILES, P.C.
130 Walnut street
P.O. Box 810
Harrisburg, PA 17108
Telephone: 717/234-2616
Counsel for Plaintiff
Kenneth F. Lloyd
.'
,
VERIFICATION
I, KENNETH F. LLOYD, hereby swear and affirm that the facts
cOI~ained in the foregoing COmPlaint in Divorce
are true and correct to the best of my knowledge, information and
belief and are made subject to the penalties of 18 Pa.C.S. S4904
relating to unsworn falsification to authorities.
Date:
March 14, 1994
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KENNETH F. LLOYD, )
Plaintiff )
)
v. ) NO. 1294 CIVIL 1994
)
PHYLLIS LLOYD, ) CIVIL ACTION - LAW
Defendant ) IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA )
) SS,
COUNTY OF DAUPHIN )
John C, Howett, Jr., being duly sworn according to law,
deposes and says that he is an attorney at law duly authorized to
practice in the Commonwealth of Pennsylvania, and that on the
17th day of March, 1994, he sent the original of the attached
letter, with which was enclosed a certified, time-stamped copy of
the Complaint in Divorce in the above-captioned matter, properly
endorsed, to the Defendant, Phyllis Lloyd, by certified mail,
postage prepaid, return receipt requested, restricted delivery,
pursuant to Pa.R.C.P. 1930.4, to 1 Latchgate Lane, Mechanicsburg,
Pennsylvania, 17055, the Defendant's last known address, and that
the return receipt card which was signed by Phyllis Lloyd, marked
as having been delivered to her on March 19, 1994, is attached
hereto and made a part hereof,
C. Howett, J Esquire
HOWETT, KISSINGER & MI , P.C.
130 Walnut street
P. O. Box 810
Harrisburg, PA 17108
Telephone: (717) 234-2616
Attorney I.D. #20092
SWORN TO AND SUBSCRIBED
before me this ~~
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IOHN C. HOWITT, Jll.
DONALD T, K1SSINOEll
'A TI\ICIA A. MIW
CINDY S. CONLIY
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HOWErr. KISSINGER & MILES, P.C.
m WALNUT STl\EIT
POST orncl DOX liD
HAIlIlISBUIlO, PENNSYLVANIA 17108
March 17, 1994
(117) Ill.UI.
FAll 1117) 111-1101
CERTIFIED MAIL NO. P089536315
RESTRXCTED DELIVERY
RETURN RECEIPT REOUESTED
Mrs. Phyllis Lloyd
1 Latchgate Lane
Mechanicsburg, PA 17055
Re: Llovd v. Llovd
Dear Mrs. Lloyd:
Enclosed for service upon you is the divorce
action which I have initiated on Ken's behalf. I
understand that Ken advised you that this would be
coming by certified mail.
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Enclosure
cc: Kenneth F. Lloyd (w/encl)
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KENNETH F. LLOYD, )
plaintiff )
)
v. ) NO. 1294 CIVIL 1994
)
PHYLLIS LLOYD, ) CIVIL ACTION - LAW
Defendant ) IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
AND WAIVER OF COUNSELING
1. A complaint in divorce under ~3301(c) of the
Divorce Code was filed on March 16, 1994, and served upon
Defendant on March 19, 1994.
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. I consent to the entry of a final decree in
divorce after service of notice of intention to request entry of
the decree.
4. I have been advised of the availability of
marriage counseling, and understand that I may request that the
Court require that my spouse and I participate in counseling. I
further understand that the Court maintains a list of marriage
counselors in the Prothonotary's Office, which list is available
to me upon request. Being so advised, I do not request that the
Court require that my spouse and I participate in counseling
prior to a divorce decree being handed down by the Court.
.....
. ,
I 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.A. ~4904, relating to
unsworn falsification to authorities.
Date: April 29, 1996
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KENNETH F, LLOYD,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 1294 CIVIL 1994
v,
PHYLLIS LLOYD,
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 March 16, 1994.
2, The marriage of Plaintiff and Defendant is
irretrievably broken and ninety (90) days have elapsed from the
date of the filing of the Complaint.
3. I consent to the entry of a final Decree in Divorce.
4, I understand that I may lose rights concerning
alimony, division of property, lawyer's fees or expenses if I do
not claim them before a divorce is granted,
5. I verify that the statements made in this affidavit
are true and correct. I understand that false statements herein
are made subject to the penalties of 18 Pa.C.S, Section 4904
relating to unsworn falsification to authorities,
Date: v-I-q{.,
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KENNETH F. LLOYD, )
Plaintiff )
)
v. ) NO. 1294 CIVIL 1994
)
PHYLLIS LLOYD, ) CIVIL ACTION - LAW
Defendant ) IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
~3301(cl 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. ~4904 relating to
unsworn falsification to authorities.
Date:
April 29, 1996
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1294 CIVIL 1994
CIVIL ACTION -- LAW
IN DIVORCE
. ' , .
KENNETH F, LLOYD,
Plaintiff
PHYLLIS LLOYD,
Defendant
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.
Date: </ - /-q&
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Kenneth F, Lloyd
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS,
Phyllis C, Lloyd
Defendant
NO, 1294 C 1994
QUALIFIED DOMESTIC RELATIONS ORDER
1. The Court intends this Order to be a Qualified Domestic Relations Order ("QDRO")
within the meaning of ~414(p) of the Internal Revenue Code of 1986 ("Code"),
2, This Order creates and recognizes the existence of the Alternate Payee's right to
receive a portion of the benefits payable with respect to the Participant.
3, This QDRO relates to the provision of marital property rights to the Alternate
Payee as a result of a Marriage Settlement Agreement between Participant and Alternate
Payee entered into on Jlpril I, 1996, ,
4, This QDRO applies to the Aetna Life and Casualty Company Incentive Savings
Plan ("Plan") and any successor thereto, Kenneth F, Lloyd ("Participant") is a Participant in
the Plan. Phyllis C, Lloyd ("Alternate Payee") is the Alternate Payee for purposes of this
QDRO,
5, The Participant's name, mailing address, Social Security number and date of birth
are:
Kenneth F. Lloyd
609 Whitetail Drive
Lewisberry, PA 17339
Social Security No,: 168-34-0649
Date of Birth: July 7,1942
6, The Alternate Payee's name, mailing address, Social Security number and date of
birth are:
Phyllis C, Lloyd
One Latchgate Lane
Mechanicsburg, PA 17055
Social Security No,: 181-32-1375
Date of Birth: January 16, 1943
It is the responsibility of the Alternate Payee to keep a current mailing address on
file with the Plan at all times,
7, The portion of the Participant's plan benefits payable to the Alternate Payee under
this QDRO is $50,000,
"
.
...
QDRO
Page 2
8, The amount designated in Paragraph 7 shall not be paid directly to the Alternate
Payee but, as soon as administratively possible, such amount shall be paid to CoreStates
Hamilton Bank to be applied to the following individual retirement account which is
represented to be eligible to receive this transfer,
IRA Account for Phyllis C, Lloyd
Account #105751357
CoreStates Hamilton Bank
Attn: Roberto Penny
3037 N, Front Street
Harrisburg, PA 17110
The Alternate Payee intends to complete the withdrawal forms of the Plan Sponsor
to eITectuate any such transfer.
9, This QDRO does not require the Plan to provide any type or form of benefit the
Plan does not otherwise provide,
10, This QDRO does not require the Plan to provide increased benefits,
11, This QDRO does not require the Plan to pay any benefits which another order
previously determined to be a Qualified Domestic Relations Order requires the Plan to pay to
another Alternate Payee,
12, On and after the date this Order is deemed to be a QDRO, but before the Alternate
Payee receives her distribution under the Plan, the Alternate Payee shall be entitled to all of
the rights and election privileges that are afforded to active participants, including, but not
limited to, the rules regarding withdrawals and distributions and the right to direct her Plan
investments to the extent permitted under the Plan,
13, All payments made pursuant to this Order shall be conditioned on the certification
by the Alternate Payee and the Participant to the Plan Administrator of such information as
the Plan Administrator may reasonably require from such parties,
14, It is the intention of the parties that this QDRO continue to qualify as a QDRO
under Code H14(p), os it may be amended from time to time,
15, In the event that the Plan inadvertently pays to the Participant any benefits that
are assigned to the Alternate Payee pursuant to the terms of this QDRO, the Participant shall
immediately reimburse the Alternate Payee to the extent that he has received such benefit
payments, and shall forthwith pay such amounts so received directly to the Alternate Payee
within ten days of receipt, In the event the Plan inadvertently pays to the Alternate Payee any
benefits that are not assigned to her pursuant to the terms of this QDRO, the Alternate Payee
shall immediately reimburse the Participant to the extent she has received such benefit
payments and shall forthwith pay such amounts so received directly to the Participant within
ten days of receipt.
16, After payment of the amount required by this QDRO, the Alternate Payee shall
have no further claim against the Participant's interest in the Plan,
17. The Alternate Payee assumes sole responsibility for the tax consequences of the
distribution under this QDRO,
<It
..
-
QDRO
Page 3
18, Until the Plan completes payment of all benefits pursuant to this QDRO, the Plan
shall treat the Alternate Payee as a surviving spouse for purposes of Code AA401{a){ll) and 417.
but the Alternate Payee shall receive, as surviving spouse, only the amount described in
Paragraph 7 of this QDRO, The sole purpose of this Paragraph 18 is to ensure payment to the
Alternate payee in case of Participant's death prior to payment by the Plan of the amount
described in Paragraph 7 of this QDRO, In ~ase of the Alternate Payee's death prior to
payment by the Plan of all benefits pursuant to this QDRO, the Plan shall pay the remaining
benefits under this QDRO to the estate to Phyllis C, Lloyd,
19, The Plan Administrator promptly shall notify the Participant and the Alternate
Payee of the receipt of this QDRO and shall notify the Participant and the Alternate Payee of
the Plan's procedures for determining the qualified status of this QDRO, The Plan
Administrator shall determine the qualified status of the QDRO and shall notify the
Participant and the Alternate Payee of the determination within a reasonable period of time
after receipt of this QDRO,
The court retains jurisdiction over this matter as provided by law,
Signed:
1'1119 Y
I 'f . ,f'i (,
,
BY THE COURT:
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