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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF * PENNA.
ROXAN~E CONNOR
Nil, .,..~.~:::2..!j.B..~. """""""'" II)
VI'I'SIIS
GARY L. CONNOR
DECREE IN
DIVORCE
AND NOW, . . ~.~ ... .~. . . . " 19 .~~. . " it is ordered and
decreed that ,. ~.~~~!1!1,~ . c;!l.n.l'\<?r. . . . . . . . . . . . . . . . . , . . . . . , . . , . . " plaintiff,
and ,. Qil.r.y' .f,.'. .GQI1I1.qJ; . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . " 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; tJO"-t
,.., :\'J:1!!. .~~r!1l.6. .9f. .t.I1~.1".~H~.a.~~. ~,~~n~."1enj;. Mr~~.I1)~~j;. .~I)~!'!.r:~c;I. .i.11~0
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but ot merged. / ,/ ,/
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MARRIAGE SErTLEMEHT AGREEME~
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THIS AGREEMENT is made and entered into between Gary L. Connor
..d RD..... C. CO',or, h.r.i..ft.r ref,rr'd to .. "o.b"d ..d Wife.
Th. p'rti., w.r. "rri.d o. April 3, 1971 ..d tber. i. 0" cbild
born of their marriage, to wit, Matthew E. Connor.
As a Consequence of disputes and unhappy differences, the
The parties desire to confirm their
parties have separated.
the S.tt1....t of th.ir prop.rty rights, costody, ,upport, ..d ."
oth.r rigbt. ..d ob1ig,tioos .risi.q DOt of tb. '.rri.g.
relationship.
It is therefore agreed:
'.p.r.tio. "d "k. .rr.og....t. i. cO'..ctio. th.rOWitb, i.clodi.q
and agreement herein Contained.
The consideration for this Agreement is the mutual promises
1. CONSIDERATION
A. It will be lawful for each party at all times hereafter
to live "p.r,t. ,.d 'p'rt fr.. the other p.rty ,t 'och pl.c. or
p1.c.s .. h. or .b. "y fro. ti.. to ti.. cboo.. or d... fit.
2. SEPARATION AND NONINTERFERENCE
B. Racb porty .b'l1 b. free fro. i.terfer...., .Rthority "d
CO.trol, dir.ct or i.dir.ct, by tb. otb'r, ,. folly.. if b. or .b.
were single and unmarried. Neither shall bother the other or
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MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT is made and entered into between Gary L. Connor
and Roxanne C. Connor, hereinafter referred to as Husband and Wife.
The parties were married on April 3, 1971 and there is one child
born of their marriage, to wit, Matthew E. Connor.
As a consequence of disputes and unhappy differences, the
parties have separated. The parties desire to confirm their
separation and make arrangements in connection therewith, including
the settlement of their property rights, custody, support, and all
other rights and obligations arising out of the marriage
relationship,
It is therefore agreed:
1. CONSIDERATION
The consideration for this Agreement is the mutual promises
and agreement herein contained,
2. SEPARATION AND NONINTERFERENCE
A. It will be lawful for each party at all times hereafter
to live separate and apart from the other party at such place or
places as he or she may from time to time choose or deem fit.
B. Each party shall be free from interference, authority and
control, direct or indirect, by the other, as fully as if he or she
were single and unmarried. Neither shall bother the other or
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represented by Paul Esposito, Esq., in reaching this Agreement.
Both parties represent that the terms of this Agreement have been
fully explained to them by their respective counsel,
5. EOUITABLE DIVISION
By this Agreement, the parties have intended to effect an
equitable division of their marital property. This division is not
intended by the parties to constitute in any way a sale or exchange
of assets.
6. SUBSEOUENT DIVORCE
A. AGREEMENT NOT PREDICATED ON DIVORCE - It is specifically
understood and agreed by and between the parties hereto and each of
the said parties does hereby warrant and represent to the other
that the execution and delivery of this Agreement is not predicated
upon nor made subject to any agreement for institution,
prosecution, defense, or for the non-prosecution or non-defense of
any action for divorce; provided, however, that nothing contained
in this Agreement shall prevent or preclude either of the parties
hereto from commencing, instituting or prosecuting any action or
actions for divorce, either absolute or otherwise, upon just, legal
and proper grounds; nor to prevent either party from defending any
such action which has been, mayor shall be instituted by the other
party, or from making any ~ust or proper defense thereto. It is
warranty, covenanted and represented by Husband and Wife, each to
the other, that this Agreement is lawful and enforceable and this
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compel or endeavor to compel the other to cohabit or dwell with him
or her.
3. MUTUAL RELEASE
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.
4. FULL DISCLOSURE
The provisions of this Agreement and their legal effect are
fully understood by each party to this Agreement, and each party
acknowledges that the Agreement is fair and equitable, that it is
being entered into voluntarily, and that it is not the result of
any duress or undue influence. 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, of the sources and amount of the
income of such party of every type whatsoever, and of all other
facts relating to the subject matter of this agreement. plaintiff
represents that she was represented by Marianne E. Rudebusch, Esq.
in reaching this Agreement, and defendant represents that he was
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warranty, covenant and representation is made for the specific
purpose of inducing Husband and Wife to execute the Agreement.
Husband and Wife each knowingly and understandingly hereby waives
any and all possible claims that this Agreement is, for any reason,
illegal or for any reason whatsoever, unenforceable in whole or in
part. Husband and Wife each do hereby warrant, covenant and agree
that, in any possible event, he and she are and shall forever be
estopped from asserting any illegality or unenforceability as to
all or any part of this Agreement.
B. ENTRY AS PART OF DECREE - It is the intention of the
parties that the 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 decree of final divorce, but shall be incorporated
for the purposes of enforcement only.
C. 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
330l(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
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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 de fondant in such divorce
action shall execute any waivers of notice or other waivers
necessary to expedite such divorce.
7. ~ISION OF PERSONAL PROPERTY
wife agrees that all of the property in the possession of
Husband shall be the sole and separate property of Husband; and
Husband agrees that all of the property in the possession of Wife
shall be the sole and separate property of Wife. The parties do
hereby specifically waive, release, renounce and forever abandon
whatever claims, if any, he or she may have with respect to the
above items which shall become the sole and separate property of
the other.
The parties agree that Husband shall pay to Wife at the time
of the execution of this document:
(a) For mortgage payments made by her
(b) As her share of the funds in
checking account #23-75079-0
$2,579
100
$2,679
B. DIVISION OF MOTOR VEHICLES
with respect to the motor vehicles owned by one or both of the
parties, they agree as follows:
Wife: Nissan Maxima
Husband: VW Cabriolet; Subaru Legacy
The titles to the said motor vehicles shall be executed by the
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parties, if appropriate, for effectuating transfer as herein
provided, on the date of execution of this Agreement or at any time
thereafter at the request of either party,
9. DISPOSITION OF PROPERTY
From and after tre date of the signing of this Agreement, both
parties shall have complete freedom of disposition 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,
conveyor 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.
10. DIVISION OF REAL PROPERTY
Husband and Wife hereby agree and acknowledge that they own
certain real property located at 20 Center Drive, Camp Hill,
Pennsylvania, as tenants by the entireties.
Husband hereby agrees to convey all his right, title and
interest in said property to \~ife. Husband agrees to execute a
deed or other instrument of conveyancing necessary to effectuate
this transfer at the time of the execution of this document,
The parties acknowledge that there is an existing mortgage
against this property held by Harris Savings Bank in the amount of
approximately $24,000. Wife agrees to obtain financing such that
she shall either satisfy said mortgage in total or shall assume
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total liability for the mortgage. wife shall hold Husband harmless
and indemnify him from liability for this obligation and other
obligations arising from this property.
11. PAYMENT OF SPECIFIED OBLIGATIONS
The parties agree that the following constitute joint marital
obligations which shall be paid by the following person:
A. WIFE - All debts incurred in her name alone since date of
separation.
B. HUSBAND - All debts incurred in his name alone since date
of separation.
12. LEGAL FEES
Each party shall pay his or her own attorneys fees.
13. ALIMONY
Both parties acknowledge and agree that the provisions of this
Agreement providing for equitable distribution of marital property
are fair, adequate and satisfactory to them and are accepted by
them in lieu of and in full and final settlement and satisfaction
of any claims or demands that either may now or hereafter have
against the other for support, maintenance, alimony pendente lite
or alimony. Husband and Wife further, voluntarily and
intelligently, waive and relinquish any right to seek from the
other any payment for support, maintenance, alimony pendente lite
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or alimony.
14. PENSION PROGRAM
Husband agrees to transfer to wife the sum of $8,630 of his
retirement benefits with Donegal Mutual Insurance Company in a tax-
free rollover, to be uccomplished in accordance with a Qualified
Domestic Relations order (QDRO), prepared by Husband's counsel,
execut~d by the parties and entered as an Order of Court. Said
QDRO shall thereafter be submitted to the Plan Administrator for
approval pursuant to ERISA, Section 206 (d) (3) . Said transfer
through the use of a QDRO shall be done in such a fashion as to not
cause either party any tax, penalty, or interest. Husband hereby
releases any interest that he has in any retirement benefits wife
may have accumulated as the result of her employment at Health
Reach Homecare and any other additional benefits she may have
accrued. This waiver is a full and complete discharge of each
party's marital claim.
15. MISCELLANEOUS
All assets including, but not limited to, savings accounts,
checking accounts, certi.ficates of deposit and life insurance
policies shall be the sole and separate property of the title
holder of said asset.
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
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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.
The parties have heretofore filed joint federal and state tax
returns. 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,
penal ty 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.
A.
WARRANTY
16.
AS
GENERAL PROVISIONS
TO EXISTING OBLIGATIONS
Each
party
represents that they have 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 party agrees to indemnify or hold the
other party harmless from and against any and all such debts,
liabilities, or obligations of every kind which may have heretofore
been incurred by them, including thos~ for necessities, except for
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the obligations arising out of this Agreement.
B. WARRANTY AS TO FUTURE OBLIGATIONS - Wife and Husband each
covenant, warrant, represent and agree that each will now and at
all times hereafter save harmless and keep the other indemnified
from 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
and that neither of them shall hereafter incur any liability
whatsoever for which the estate of the other may be liable.
C. SEVERABILITY - 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 obligations under anyone
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.
D. OTHER DOCUMENTATION - \~ife and Husband covenant and agree
that they will forthwith execute any and all written instruments,
assignments, releases, satisfactions, deeds, notes or such other
writings as may be necessary or desirable for the proper
effectuation of this Agreement, and as their respective counsel
shall mutually agree should be so executed in order to carry out
fully and effectively the terms of this Agreement.
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E, 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.
F. 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.
G. 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 party any and all further
instruments and/or documents that the other party may reasonably
require for the purpose of giving full force and effect to the
provisions of this Agreement.
H. LAW GOVERNING - This Agreement shall be construed and
governed in accordance with the laws of the Commonwealth of
Pennsylvania.
I. BINDING EFFECT - Except as otherwise stated herein, this
Agreement shall be binding and shall inure to the benefit of the
parties hereto and their respective heirs, executors,
administrators, successors, and assigns.
K. NO WAIVER OF 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
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party to insist upon strict performance of any of the provisions of
this Agreement shall in no way affect the right of such party
hereafter to enforce the same, nor shall the waiver of any breach
of any provision hereof be construed as a waiver of any subsequent
default of the same or similar nature, nor shall it be construed as
a waiver of strict performance of any other obligations herein.
K, HEADINGS NOT PART OF AGREEMENT - Any heading preceding
the text of the several paragraphs and subparagraphs hereof are
inserted solely for convenience or reference and shall not
constitute a part of this Agreement nor shall they affect its
meaning, construction, or effect.
L. ADDRESS OF PARTIES - Each party shall at all times keep
the other informed of his or her place of residence, and shall
promptly notify the other of any change, giving the address of the
new place of residence.
M. WAIVER 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 have or hereafter acquire, under the
present or future laws of Pennsylvania or another jurisdiction, to
share in the property or the estate of the other as a result of the
marital relationship, including, without limitation, dower,
curtesy, their statutory equivalents, widow's allowance, homestead
rights, right to take in intestacy, right to take against the will
of other, and right to act as administrator or executor of the
other's estate, and each party will, at the request of the other,
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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.
N. ATTORNEY'S FEES FOR ENFORCEMENT - In the event that
either party breaches any provision of this Agreement, and the
other party retains counsel to assist in enforcing the terms
thereof, the parties hereby agree that the breaching party will pay
all reasonable attorneys' fees, court costs, and expenses incurred
by the other party in enforcing the Agreement.
IN WITNESS WHEREOF, and intending t'o be bound
parties have signed and sealed this Agreement on the
hereby, the
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~I day of
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, 1996 at Harrisburg, Pennsylvania.
In the presence of:
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/11 tc;,'lCt L.<.L-U! i2.cik J., 0..-( (/ t
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1I1l' t. "..,u. l , t,..". l' ,...A..J ( SEAL)
Roxanne C. Connor
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L U,UA.J()f.L
9 1./- ..;; S'J),.l. '
MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT is made and entered into between Gary L, Connor
and Roxanne C. Connor, hereinafter referred to as Husband and Wife.
The parties were married on April 3, 1971 and there is one child
born of their marriage, to wit, Matthew E. Connor.
AG a consequence of disputes and unhappy differences, the
parties have separated. The parties desire to confirm their
separation and make arrangements in connection therewith, including
the settlement of their property rights, custody, support, and all
other rights and obligations arising out of the marriage
relationship.
It is therefore agreed:
1, CONSIDERATION
The consideration for this Agreement is the mutual promises
and agreement herein contained.
2, SEPARATION AND NONINTERFERENCE
A. It will be lawful for each party at all times hereafter
to live separate and apart from the other party at such place or
places as he or she may from time to time choose or deem fit.
B. Each party shall be free from interference, authority and
control, direct or indirect, by the other, as fully as if he or she
were single and unmarried. Neither shall bother the other or
represented by Paul Esposito, Esq., in reaching this Agreement.
Both parties represent that the terms of this Agreement have been
fully explained to them by their respective counsel.
5. EOUITABLE DIVISION
By this Agreement, the parties hav~ intended to effect an
equitable division of their marital property. This division is not
intended by the parties to constitute in any way a sale or exchange
of assets.
6, SUBSEOUENT DIVORCE
A. AGREEMENT NOT PREDICATED ON DIVORCE - It is specifically
understood and agreed by and between the parties hereto and each of
the said parties does hereby warrant and represent to the other
that the execution and delivery of this Agreement is not predicated
upon nor made subject to any agreement for institution,
prosecution, defense, or for the non-prosecution or non-defense of
any action for divorce; provided, however, that nothing contained
in this Agreement shall prevent or preclude either of the parties
hereto from commencing, instituting or prosecuting any action or
actions for divorce, either absolute or otherwise, upon just, legal
and proper grounds; nor to prevent either party from defending any
such action which has been, Inay or shall be instituted by the other
party, or from making any just or proper defense thereto. It is
warranty, covenanted and represented by Husband and Wife, each to
the other, that this Agreement is lawful and enforceable and this
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compel or ondeavor to compel the othor to cohabit or dwell with him
or her,
3. MUTUAL RELEASE
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,
4, FULL DISCLOSURE
The provisions of this Agreement and their legal effect are
fully understood by each party to this Agreement, and each party
acknowledges that the Agreement is fair and equitable, that it is
being entered into voluntarily, and that it is not the result of
any duress or undue influence. Husband and \~ife 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, of the sources and amount of the
income of such party of every type whatsoever, and of all other
facts relating to the subject matter of this agreement. Plaintiff
reprenents that she was represented by Marianne E. Rudebusch, Esq.
in reaching this Agreement, and defendant represents that he was
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warranty, covenant and representation is made for the specific
purpose of inducing Husband and Wife to execute the Agreement,
Husband and wife each knowingly and understandingly hereby waives
any and all possible claims that this Agreement is, for any reason,
illegal or for any reason whatsoever, unenforceable in whole or in
part, Husband and Wife each do hereby warrant, covenant and agree
that, in any possible event, he and she are and shall forever be
estopped from asserting any illegality or unenforceability as to
all or any part of this Agreement.
B. ENTRY AS PART OF DECREE - It is the intention of the
parties that the 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 decree of final divorce, but shall be incorporated
for the purposes of enforcement only.
c. 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
330l(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
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obtain a divorce pursuant to said 23 Pa.C.S.A. Section 3301(c).
Upon roquest, to the extent permitted by law and the applicable
Rules of Civil Procedure I the named defendant in such divorce
action shall execute any waivers of notice or other waivers
necessary to expedite such divorce.
7. DIVISION OF PERSONAL PROPERTY
\~ife agrees that all of the property in the possession of
Husband shall be the sole and separate property of Husband; and
Husband agrees that all of the property in the possession of Wife
shall be the sole and separate property of Wife. The parties do
hereby specifically waive, release, renounce and forever abandon
whatever claims, if any, he or she may have with respect to the
above items which shall become the sole and separate property of
the other.
The parties agree that Husband shall pay to Wife at the time
of the execution of this document:
(a) For mortgage payments made by her
(b) As her share of the funds in
checking account #23-75079-0
$2,579
100
$2,679
B. DIVISION OF MOTOR VEHICLES
With respect to the motor vehicles owned by one or both of the
parties, they agree as follows:
Wife: Nissan Maxima
Husband: VW Cabriolet; Subaru Legacy
The titles to the said motor vehicles shall be executed by the
.
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total liability for the mortgage. Wife shall hold Husband harmless
and indemnify him from liability for this obligation and other
obligations arising from this property.
11. PAYMENT OF SPECIFIED OBLIGATIONS
The parties agree that the following constitute joint marital
obligations which shall be paid by the following person:
A. WIFE - All debts incurred in her name alone since date of
separation.
B. HUSBAND - All debts incurred in his name alone since date
of separation.
12. LEGAL FEES
Each party shall pay his or her own attorneys fees.
13. ALIMONY
Both parties acknowledge and agree that the provisions of this
Agreement providing for equitable distribution of marital property
are fair, adequate and satisfactory to them and are accepted by
them in lieu of and in full and final settlement and satisfaction
of any claims or d~mands that either may now or hereafter have
against the other for support, maintenance, alimony pendente lite
or alimony. Husband and \~ife further, voluntarily and
intelligently, waive and relinquish any right to seek from the
other any payment for support, maintenance, alimony Fendente lite
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or alimony.
14. PENSION PROGRAM
Husband agrees to transfer to wife the sum of $8,630 of his
retirement benefits with Donegal Mutual Insurance Company in a tax-
free rollover, to be accomplished in accordance with a Qualified
Domestic Relations order (QDRO), prepared by Husband's counsel,
executed by the parties and entered as an order of Court. said
QDRO shall thereafter be submitted to the Plan Administrator for
approval pursuant to ERISA, section 206 (d) (3) . Said transfer
through the use of a QDRO shall be done in such a fashion as to not
cause either party any tax, penalty, or interest. Husband hereby
releases any interest that he has in any retirement benefits wife
may have accumulated as the result of her employment at Health
Reach Homecare and any other additional benefits she may have
accrued. This waiver is a full and complete discharge of each
party's marital claim.
15. KISCELLANEOUS
All assets including, but not limited to, savings accounts,
checking accounts, certificates of deposit and life insurance
policies shall be the sole and separate property of the title
holder of said asset.
The parties believe and agree, and have been so advised by
their respective attorneys, that the division of property
herotofore made by this Agreement is a non-taxable division of
property between co-owners rather than a taxable sale or exchange
8
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.
The parties have heretofore filed joint federal and state tax
returns. 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,
penal ty 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.
16. GENERAL PROVISIONS
A. WARRANTY AS TO EXISTING OBLIGATIONS Each party
represents that they have 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 party agrees to indemnify or hold the
other party harmless from and against any and all such debts,
liabilities, or obligations of every kind which may have heretofore
been incurred by them, including thos~, for necessities, except for
9
the obligations arising out of this Agreement.
B. WARRANTY AS TO FUTURE OBLIGATIONS - Wife and Husband each
covenant, warrant, represent and agree that each will now and at
all times hereafter save harmless and keep the other indemnified
from 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
and that neither of them shall hereafter incur any liability
whatsoever for which the estate of the other may be liable.
C. SEVERABILITY - 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 obligations under anyone
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.
D. OTHER DOCUMENTATION - Wife and Husband covenant and agree
that they will forthwith execute any and all written instruments,
assignments, releases, satisfactions, deeds, notes or such other
writings as may be necessary or desirable for the proper
effectuation of this Agreement, and as their respective counsel
shall mutually agree should be so executed in order to carry out
fully and effectively the terms of this Agreement.
10
E. 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.
F. 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.
G. 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 party any and all further
instruments and/or documents that the other party may reasonably
require for the purpose of giving full force and effect to the
provisions of this Agreement.
H. LAW GOVERNING - This Agreement shall be construed and
governed in accordance with the laws of the Commonwealth of
Pennsylvania.
I. BINDING EFFECT - Except as otherwise stated herein, this
Agreement shall be binding and shall inure to the benefit of the
parties hereto and their respective heirs, executors,
administrators, successors, and assigns.
K. NO \'/AIVER OF 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
11
party to insist upon strict performance of any of the provisions of
this Agreement shall in no way affect the right of such party
hereafter to enforce the Game, nor shall the waiver of any breach
of any provision hereof be construed as a waiver of any subsequent
default of the same or similar nature, nor shall it be construed as
a waiver of strict performance of any other obligations herein.
Ie HEADINGS NOT PAH'r OF AGHEEMENT - Any heading preceding
the text of the several paragraphs and subparagraphs hereof are
inserted solely for convenience or reference and shall not
constitute a part of this Agreement nor shall they affect its
meaning, construction, or effect.
L. ADDRESS OF PARTIES - Each party shall at all times keep
the other informed of his or her place of residence, and shall
promptly notify the other of any change, giving the address of the
new place of residence.
11. WAIVER 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 have or hereafter acquire, under the
present or future laws of Pennsylvania or another jurisdiction, to
share in the property or the estate of the other as a result of the
marital relationship, including, without limitation, dower,
curtesy, their statutory equivalents, widow's allowance, homestead
rights, right to take in intestacy, right to take against the will
of other, and right to act as administrator or executor of the
other's estate, and each party will, at the request of the other,
12
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ROXANNE CONNOR,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
NO.
GARY L. CONNOR,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE UNDER
SECTION 3301(c) OR SECTION 3301(d)
OF THE DIVORCE CODE
AND NOW comes the above Plaintiff, Roxanne Connor, by her
attorney, Marianne E. Rudebusch, Attorney at Law, and seeks to
obtain a decree in divorce from the above-named Defendant, upon the
grounds hereinafter set forth:
1. The Plaintiff, Roxanne Connor, is an adult individual who
resides at 20 Center Drive, Camp Hill, Cumberland County,
Pennsylvania, 17011.
2. The Defendant, Gary L. Connor, is an adult individual who
resides at 20 Center Drive, Camp Hill, Cumberland County,
Pennsylvania, 17011.
3. The Plaintiff has been a bona fide resident of the
Commonwealth of Pennsylvania for at least six (6) months
immediately prior to the filing of this Complaint.
4. The Plaintiff and Defendant were married on April 3, 1971,
in Camp Hill, Cumberland County.
5. The Plaintiff and Defendant are both citizens of the
United States of America.
. '
6.
parties.
7. The Plaintiff and Defendant are not members of the Armed
Services of the United states or any of its allies.
8. Plaintiff has been advised of the availability of
counseling and that she may have the right to request that the
Court require the parties to participate in counseling.
9. The causes of action and sections of Divorce Code under
which Plaintiff is proceeding are:
A. Section 3301(c). The marriage of the parties
is irretrievably broken. After ninety (90) days have
elapsed from the date of the filing of this Complaint,
Plaintiff intends to file an Affidavit consenting to a
divorce. Plaintiff believes that Defendant may also file
such an Affidavit.
B. Section 3301(d).
is irretrievably broken.
separated on May 12, 1994.
WHEREFORE, the Plaintiff prays your Honorable Court to enter
a Decree in Divorce from the bonds of matrimony.
There have been no prior actions in divorce between the
The marriage of the parties
The Plaintiff and Defendant
COUNT II
EOUITABLE DISTRIBUTION
10. Paragraphs one (1) through nine (9) of this Complaint are
incorporated herein by reference as though set forth in full.
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DOMESTIC RETURN RECEIPT
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4. Plaintiff and Defendant were married on April 3, 1971 in
Cumberland County, Pennsylvania.
5. The Plaintiff and Defendant are both citizens of the
United states of America.
6. There have been no prior actions in divorce between the
parties.
7. The Plaintiff and Defendant are not members of the Armed
services of the United States or any of its allies.
8. Plaintiff has been advised of the availability of
counseling and that she may have the right to request that the
Court require the parties to participate in counseling.
9. The cause of action and sections of Divorce Code under
which Plaintiff is proceeding are:
A. Section 3301(c). The marriage of the parties is
irretrievably broken. After ninety (90) days have elapsed from
the date of the filing of this complaint, Plaintiff intends to
file an Affidavit consenting to a divorce. plaintiff believes
that Defendant may also file such an Affidavit.
B. Section 3301(d). The marriage of the parties is
irretrievably broken. The Plaintiff and Defendant separated on
May 12, 1994.
COUNT II
EOUITABLE DISTRIBUTION
10. Paragraphs 1 through 9 of this Complaint are
incorporated herein by reference as though set forth in full.
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MARIANNE E. RUDEBUSCH, Esquire .,_
845 Sir Thomas Court, Harrisburg, PA 17109 J lJl~ C G j996
(717) 657-0~32 ,h,J
the marital home on July 12. 1995, however, the parties had been living separate and apart
within the household since on or about May 12. 1994. On October 14. 1995.
Defendant/Respondent made a paymem of $2,231.10 on the parties' mortgage with the intention
of satisfying the payments due for August and October.
Upon her unilateral depanure from the home. Plaintiff/Petitioner refused to make
any commitmem to the payment of the mortgage, real estate taxes or any other related
obligations, including responsibility for the parties' son, leaving them instead to
De fendam/ Responde m.
The parties have. since the filing of the instant Petition. reached an imerim
agreement whereby Defendam/Respondent will vacate the marital residence by December I,
1995, and Plaimiff/Petitioner will assume occupancy and responsibility for all obligations
relating to the home as of that date.
6. Denied. Defendam/Respondem has no intention of encumbering or alienating
this marital asset. nor can he do so in light of the panies' ownership as tenants by the entireties.
7. Denied, for the same reasons as set forth in paragraph 6 of this Answer.
8. The avermem of paragraph 8 is a legal conclusion to which no response is
required.
9. Denied, for Ihe reasons set forth in paragraphs 6 and 7.
10. The averment of paragraph 10 is a legal conclusion to which no response Is
"
'.
..
ROXANNE CONNOR
Plaintiff/Petitioner
:IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
:CIVIL ACTION - LAW
v.
GARY L. CONNOR
Defendant/Respondent
:NO. 94 - 2582 CIVIL TERM 1994
: IN DIVORCE
PETITION FOR SPECIAL RELIEF
PURSUANT TO SECTIONS 3104(a) AND 3505(a) OF THE DIVORCE CODE
AND PA RULE OF CIVIL PROCEDURE 1920.43
TO THE HONORABLE JUDGES OF THE SAID COURT:
Plaintiff/Petitioner, Roxanne Connor, by her attorney, Marianne
E. Rudebusch, files this Petition for Special Relief in order to
preserve and protect the parties' mar! tal property and, in
support of the Petition, respectfully represents that:
1. Plaintiff/Petitioner, Roxanne Connor, is the Plaintiff
in this divorce action and currently resides at 206 Beacon
Drive, Harrisburg, Dauphin County, Pennsylvania.
2. Defendant/Respondent, Gary L. Connor, is the Defendant
in this divorce action and currently resides at 20 Center Drive,
Camp Hill, Cumberland County, Pennsylvania.
3. The parties are husband and wife, having been married on
April 2, 1971.
4. This action was commenced with the filing of a Complaint
in Divorce on May 13, 1994, in which the Plaintiff/Petitioner,
Roxanne Connor, included a claim for a divorce on the grounds
set forth at Sections 3301(c) of the Divorce Code.
Page 1 of 4
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5, During the course of the marriage, the parties acquired
assets, including real and personal property, which constitute
marital property within the meaning and intent of the
Pennsylvania Divorce Code and which are subject to equitable
distribution.
The parties purchased the marital home, located at 20 Center
Drive, Camp Hill, Cumberland County, Pennsylvania, and own it as
tenants in the entireties. The Plaintiff/Petitioner moved out
of the marital home on July 12, 1995. The Defendant/Respondent
remains in the marital home. The Defendant/Respondent refused
to make payments on the mortgage to Harris Bank in the amount of
$1,088.34 per month, beginning with the August 1, 1995 payment.
Plaintiff/Petitioner, Roxanne Connor, has offered
D~fendant/Respondent, Gary Connor to move into the marital home
and take over the mortgage payments. The Defendant/Respondent
has refused this offer.
6. Upon information and belief, Defendant/Respondent, Gary
Connor, will encumber or alienate this marital property without
regard to Plaintiff/Petitioner, ROKanne Connor's, interest
therein or her claim for equitable distribution.
7. Upon information and belief, if Defendant/Respondent,
Gary Connor, disposes of, or encumbers this asset in his sole
Page 2 of 4
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control, the remaining marital assets will be insufficient to
adequately protect the Plaintiff/Petitioner, Roxanne Connor's,
right to equitable distribution of the parties marital property.
8. Pursuant to Section 3323(f) of the Divorce Code, this
court has full equity power and jurisdiction and may issue
injunctions or other orders which are necessary to protect the
interest of the parties or to effectuate the purposes of this
act, and may grant such other relief or remedy as equity and
justice require . .
9. The relief sought by Plaintiff/Petitioner, Roxanne
II
Connor:
a. is necessary to protect her interests in the marital
property;
b. is necessary to effectuate the purposes of the
Divorce Code;
c. is required by equity and justice.
10. Plaintiff/Petitioner, Roxanne Connor, has no adequate
remedy at law.
11. Upon information and belief, Plaintiff/Petitioner,
Roxanne Connor, will suffer irreparable harm and lose forever
her rights to equitable distribution of marital property unless
Defendant/Respondent, Gary Connor, is enjoined from dissipating
marital assets in his control.
Page 3 of 4
MARITAL PROPERTY
PLAINTIFF LISTS ALL MARITAL PROPERTY IN WHICH EITHER OR BOTH
SPOUSES HAVE A LEGAL OR EQUITABLE INTEREST INDIVIDUALLY OR WITH ANY
OTHER PERSON AS OF THE DATE OF THE SEPARATION OF THE PARTIES,
ITEM
NO.1
ITEM
NO.2
1990 Nissan Maxima
DESCRIPTION
OF PROPERTY
Marital Home
20 Center Dr.,
Camp Hill,PA
NAMES OF
ALL OWNERS
Roxanne C. Connor
Gary L. Connor
Roxanne Connor
VALUE
$110.000
$9,000
VALUATION
DATE
8/94
5/94
ADDITIONAL
LIENS OR
EHCUMBRANCES
outstanding mortgage for
$40/000 held by Harris Savings
Bank
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INCOME AND EXPENSE STATEMENT
OF
ROXANNE CONNOR
INCOME
Employer: Capital Health System
Address: 205 South Front Street, Harrisburg, PA 17105-8700
Type of Work: Home Care Registered Nurse
Payroll Number: Dept. 9410 Emp. 2925
Pay Period (Weekly, ai-weekly, etc.): Bi-weeklYi paid hourly basis.
Gross Pay Per Pay Period: Figures given per month, based on past
six month $3,044.30 per month.
Itemized Payroll Deductions:
Federal Withholding $323.00
Social Security $229.00
Local Wage Tax $ 30.00
State Income Tax $ 85.00
Unemployment $ 1.00
Medicare Tax $
Retirement (401K) $304.00
Savings Bonds $
Credit Union $
Life Insurance $
Health Insurance $ 52.00
Pension Contribution $
Net Pay Per Pay Period $2,020/month
OTHER INCOME:
MONTHLY ANNUAL
Interest $ $
(C.D. & Mun. Bonds)
Dividends $ $
Pension $ $
Annuity $ $
Social security $ $
Rents $ $
Royalties $ $
Expense Account $ $
Unemployment Compo $ $
Workmen'R Camp. $ $
Gifts $ $
Other Capital Gains $ $
Total $ $
TOTAL INCOME: $2,020 $24,240
EXPENSES
MONTHLY ANNUAL
HOME:
Mortgage/Rent $1,088 $13,056
Maintenance & Lawn $ 50 $ 600
utilities:
Electric $ 75 $ 900
Gas $ $
oil $ 66 $ 792
Sewer & Refuse $ 24 $ 288
Telephone $ 40 $ 480
Water $ 25 $ 300
Refuse City $ $
EMPLOYMENT:
public Transportation $ $
Lunch $ $
TAXES:
Real Estate $ 100 $ 1,200
Personal Property $ 8 $ 96
INSURANCE:
Homeowners $ 21 $ 252
Automobile (s) $ . 52 $ 624
Life $ $
Accident $ $
Health $ $
Other $ $
AUTOMOBILES:
Payments $ $
Fuel (all vehicles) $ 60 $ 720
Repairs $ 80 $ 960
MEDICAL:
Doctor $ 4 $ 48
Dentist $ $
Orthodontist $ $
Hospital $ $
Medicine $ 38 $ 456
special needs $ 4 $ 48
(glasses, braces,
orthopedic devices, etc. )
EDUCATION:
Private School $ $
Parochial School $ $
College $ $
Religious $ $
PERSONAL:
Clothing $ , 50 $ 600
Food $ 180 $ 2,160
Barber/Hairdresser $ 50 $ 600
Credit Payments $ $
Credit Card $ 50 $ 600
Charge Accounts $ $
Memberships $ $
LOANS:
Credit Union $ $
MISCELLANEOUS:
Child Care/Babysitting $ $
Papers/Books/Magazines $ $
Entertainment $ $
Pay T.V. $ $
Vacation $ 125 $ 1,500
Gifts $ $
Legal Fees $ 132 $ 1,584
Charitable Contributions $ 100 $ 1,200
Other Counselling $ $
Tax Preparation $ $
TOTAL EXPENSES $ 2,422 $29,064
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