HomeMy WebLinkAbout94-02811
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF .. PENNSYLVANIA
nONNIE M. SENfT,
II
I No. 2.8.IJ..., .."....",., 1994
I'lo,nt I ff
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Verslls
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.Dl!fl!!ldont
DECREE IN
DIVORCE
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AND NOW, .... ..l~t',4'7" .. ~.. , ..... 19.95.... It I, ordered and
decreed that" .~,!I.l!l.i.~, ~., .~\'P.r.t, .. . . ., . . . .', , , , . . "."" "'" plaintiff,
and,.. ,ql)lJr,g.~, !\....~\'!'.r.L............,.........".."........, 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: Nonl'
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hcreill II not IIIl>rgl'c\ hl'rl'lIlth.
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SAlOIS, GUIIlO,
slIun" &
MASLANIJ
26 W, IlIill SIre"
CIlIII.I"I'A
.
PROPERTY SETTLEMENT AND SEPARATION AGREEMENT
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I between GEORGE E. SENFT, of 327 Belaire Drive, Shiremanstown,
I Cumberland County, Pennsylvania, hereinafter referred to as
, HU6band,
THIS AGREEMENT made
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this <I"
day of (It, ,';(1.1 T, 1994
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BONNIE R. SENFT, of 327 Belaire Drive, ShiremanBtown, Cumber.land
..
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County, Pennsylvania, hereinafter referred to as Wife.r
WITNESSETH:
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Cll
WHEREAS, in consequence of disputlis and unhappy dttferences,
the parties have been living separate and np~rt fr0m Bach other;
and
I' WHEREAS, the p,'lrties desir.e to confirm their separation and
J make arrangementH therewith, including cUHtody of t~ejr minor
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I children, Brian K. i>enft ([I.O.B. September. 28, 197e) and Lindstly
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I M. Senft (D.D.B. December 6, 1981), the division of their marital
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~ property and other rights and obligations growing out of their
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I' marr ~a'le.
NOW THEREFOR~, in consideration 0f the covenant~ and
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~ promises hereinafter to be mutually kept and performld by each
party, as well as for other good and valuable conslderation and
! intend! ng to be lcg8 Dr bound it is agr.eed l1S fuUl)w5:
(1) it shull be lawful for each party at all ttmee
hereafter to live separate '-Iud apart from the other party at Buch
SAIPlS, IilIIllO,
Situ...' &
MASt,ANI!
2(, W llIih Sln'fl
CarUIIl'.I'A
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I pl... o. pl.... .. he o. .h. "0' tl.. to tl.. ..; .hoo.. o. de..
fit.
(2 )
Except ae herein otherwise provided, each party hereby
I releases the other from any and all claims, or demands up to the
,
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date of execution hereof.
(3 )
The partiee are the owners of certain real estate with
improvemente thereon erected known and numbered as 327 Belaire
Drive, Shiremanstown, Cumberland County, Pennsylvania.
Husband
agrees within thirty (30) days of the signing of this Agreement
to convey all his right, title and interest in said real estate
to Wife by deed of special warranty. Wife shall assume full
responsibility for all household expenses including, but not
limited to, the mortgage with Integra Mortgage Company/ liens of
record, utility bills, insurance and real estate taxes in
connection with said property. With regard to all such expenses,
Wife hereby agrees to hold Husband harmless and indemnify him
from any loss thereon. Nothing herein to the contrary
~ withstanding, Wife agrees that should she remarry or cohabitate
~ with a member of the opposite sex not within the degrees of
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j consanguinity she will take all necessary action to refinance the
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~ mortgage with Integra Mortgage Company for the purposes of having
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the lender remove Husband from any liability thereon. Wife
agrees that if she is unable to refinance, for any reason within
a reasonable timet not to exceed six (6) months, this provision
I will require her to sell the residence and satisfy the mortgage.
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(4) At the time of signing of this Agreement, Husband shall
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pay to Wife th& Bum of $IC,OOO.OO.
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II stock.
Ii equally all IBM stock owned by the parties.
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ji any debts since the date of the filing of the divorce, May 28,
II
Ii 1994, the party who incurred said debt shall be responsible for
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~ the payment thereof regardless of the name in which the debt may
!I have been incurred.
~ (7) Each party relinquishes any right, title and interest
II he or she may have to any and all motor vehicles currently in
II possession of the other party. Wife releases all of her right,
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i' title and interest to the 1989 Dodge Colt to Husband and Husband
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~ releases all of his right, title and interest to the 1988 Pontiac
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Ii 6000 SE Station Wagon to Wife.
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:i documents necessary to have said vehicles properly registered in
Ii the other party's name with the Penndylvania Department of
(5)
Husband and Wife are the owners of 40 shares of IBM
The parties agree to sell, transfer or otherwise divide
(6 )
In the event that either party contracted or incurred
Each party shall execute any
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~ Transportation within ten (10) days of the execution
I,
I Agreement.
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of this
Husband agrees to assume full responsibility of the
encumbrance with Chicago First Bank on said vehicles and shall
hold Wife harmless and indemnify her from any loss thereon.
SAlOIS, GUJJlO.
SIIU.... & (8) Wife hereby relinquishes any right, thle and interest
MASI.ANIl
26W,llIihSI",,1 she may have to Husband's corporation, GETS, INC. and also his
C.,lblc,I'A
interest in UNISHIPPERS ASSOCIATION FRANCHISE. This release
shall include all assets and inventory of the business and
Husband shall hold Wife harmless and indemnify her from any debts
)jl.l)/
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and liabilities thereof. By separate agreement, Husband agrees
to lease the garage and storage space located at 327 Belaire
Drive for a period of three (3) years at the rate of Two Hundred
Dollars ($200.00) psr month. The corporation shall lease the
garage on terms and r:onditions o~ a lease to be separately IJ i /
. I }1/."l 11)((111'" ,111,1/ flO~ lJ,- ,f)owf::
negotiated between the parties. ,f! /,1), [~ '., I/1,:V/llf' (v," pl'rf,(">('';;, of w-
,'"./ c.U I,~ '''.j ~;. 'ff'lNf' .
(9) The parties hereto mutually agree that they have ;
effected a satisfactory division of the furniture, household
,
!. furnishings, appliances, tools and other household personal
property between them, and they mutually agree that each party
shall from and after the date hereof be the sole and separate
owner of all such property presently in his or her possession
whether said property was heretofore owned jointly or
individually by the partJes hereto. This agreement shall have
the effect of an assignment or bJll of sale from each party to
the other for such property as may be in the individual
posseBsion of each of the parties hereto.
(10) Each party hereby relinquishes any right, title or
interest he or she may have in or to any intangible personal
propert.y currently titled in the nlllll!! of or in t.he possession of
the other party, including, but not limited to, stock&, bonds,
insuranr:e, bank accounts, 401 K accounts and retlrement accounts.
SAIDIS, GUIDO,
SIIUFF& This provision apec\.fically includes Wife'S f.'elp..,ue of
MASI.AND
26W.llIlhSlreel Hu!;band'a IIlH f.'Elt.\.niment and hio 401 K accounl: t1n:ou.;h I!ll~ and
Carlisle,I'A
Husbond's relesse of Wife's relirewont by reason of ner
employment by the New Cumberland Army Depot and participatJon in
Federal Service System Retirement. Each party agrees to execute
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SAIDIS, GUIDO,
SIIUFF &
MASI.ANU
26 W. llilh SI",e'
Carll.le,I'A
any documents necessary or desirable to effectuate this
provision.
(11) The parties agree that they shall have shared legal
afta pkysieal custody of their minor children, Brian K. Senft and
Lindsey M. Senft. Both parties shall have the right to make
! major parenting decisions affecting the childrens' health,
education and welfare.
fnfl1rcrLj
Wife shali have A physical custody of the children during
school terms subject to Husband's periods of physical custody on
the first and third weekend of every month from 5:00 p.m. Friday
~d'(l.1
until 8:00 p.m. on Sunday. Extended periods ofAphysical custody
by Husband during the summer months shall be negotiated between
Husband and Wife after taking into consideration the childrens
desires. Holidays will be alternated between Husband and Wife
with the other party having custody the day and night preceding
the holiday. Holidays shall include Labor Day, Thanksgiving,
Christmas, New Year's Day, Easter, Memorial Day and the Fourth of
July. HolidaYB Bhall commence with Husband's custody on Labor
Day, 1994. Additional periods of Husband's custody shall be
mutually agreed to by the parties.
(12) Husband agrees to pay to Wife for the use, benefit,
support and maintenance of their minor children, the sum of Five
Hundred and 00/100 ($500.00) Dollars per month payable on the
first day of each month. Husband shall provide medical insurance
.for .jl,o!.. (""dnll'
and dental inBurance^ ~ described in the IBM Insurance Plan.
Husband and Wife agree ~o divide equally any noncovered or
extraordinary medical, dental and orthodontic expenses. Husband
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Ii and Wife also agree to share equally any post secondary education
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Ii of the children, after all grants, loans and scholarehips of the
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II children are taken into consideration.
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~ The parties agree that in the event of a material change in
!: circumstances of either party, or a change in the custody
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i, arrangements Bet forth herein, the amount of support payments
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shall be subject to an appropriate adjustment by agreement or, if !
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I' the parties are unable to agree, by order of a court of competent I
,
: jurisdiction. . I J I
ii 71,;;. 81r I,~I'J t<y,vl! -Iv -S'!JII A((,cliI1J~ d" G'II5t",1 I/IIMI!.JIti.~/Y b.lt
~; (13) lIt1sbBI}B aRB Wife agre~at HlHffia.nd-&haU se eRUtlea
ii -10 lid :'Jl!.ek a. I"vi! MC1"*,02 In b,~("(.'e &.NIt// Jinv.1.ryI9'1S",71,e f'ar7/~
ii te take beth ekilarsR 3S SlleRlptisnfl--f~ 199~ fer IRS fltl~aeB llfta-
)>I'll {;'r#,tJr agra. -Iv (,/~ .j(l/,,f ")1.dt! and f)dt'l-al-ia)l. ,rlv.-ns to, Jo/i'l.
~ j: Wife li9reell. to execute aR~' a99\1lRsRts R~eeesBIjY er aesirable ee 1 _
.: /lmi. -ra.IC i't/lld -tv lJe (l4,1,n!J N.!. any nf(,.)'ld ftifJ.I1'COIl(It/C( 5h~11 oe.
II 8R~i tIs HassBRa te aa.:.a e)[e.mpti~n~. The parties fl:1rt.~l' agr~c
i' cJll;,d~d 1/f},IJi(o/I'{ bl(' '1('4' j)t1,tII'S.
Ii that H\l8~Ra lfhalI Be e !'I In tlea ts Eke IRtel]ra mertgage ifttereet
I:
.,
II Q9Qu9tisR fsr 199i. Commencing in 1995 and thereafter, subject
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~ to a change in custody arrangements, the parties agree that they
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!i shall each be entitled to one exemption with Husband receiving
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Ii the exemption for son, Brian K. Senft and Wife receiving the
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ii exemption for daughter, Lindsey M. Senft. The parties agree that
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I if appropriate, they will sign IRS form 8332 at the time of the
signing of thie Agreement.
SAIDIS, GUmo,
SIIU.... &
MASI.ANU
26 W. IlIlh 51",e'
Carllde,I'A
(14) Except as otherwise provided herein, Husband shall not
pay to Wife nor Wife to Husband any sum whatsoever as alimony,
alimony pendente lite, or for hie or her support or maintenance.
(15) Each party is now represented by counsel of his and her
own choice, and each shall pay his or her own attorney for all
legal services rendered or to be rendered on hiB or her behalf.
SAIDIS, GUIDO,
SIIUFF &
MASI,AND
26 W. llilh 51",el
CllfJill..I'A
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II Wife is represented by Maria P. cognetti, Esquire and Husband is
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ii represented by Robert c. Saidis, Esquire.
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(16)
Neither party shall contract or incur any debt or
for which the other party or his or her property or
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i. liability
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Ii estate might be responsible and shall indemnify and save the
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:1 other party harmless from any and all claims or demands made
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II against him or her by reason of debts or obligations incurred by
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II the other party.
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Ii (17) Each of the parties shall from time to time, at the
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ii request of the other, execute, acknowledge and deliver to the
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!I other party any and all further instruments that may be
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Ii reasonably required to give full force and effect to the
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II provision of this Agreement.
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~ (lB) The parties do hereby warrant, represent, acknowledge
~ and agree that each is fully and completely informed of, and is
i! familiar with, the wealth, real and personal property, estate and
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I: assets, earnings and income of the other and that each has made a
il full and complete disclosure to the other of his and her entire
I' assets and liabilities and any further enumeration or statement
thereof in this Agreement is specifically waived.
(19) Husband and Wife acknowledge that each of them has
read and understand his and her rights and responsibilities under
': this Agreement and that they have executed this Agreement under
no compulsion to do so but as a voluntary act.
(20) It in fur.th~r specifically under.ntood and agreed by
. and between thB parties hereto that Bach party accepts the
prov18ion~ herein wade in lieu of bnd in full Battlemont and
SAIDIS, GUIDO,
SIIUFF &
MASI.ANU
26 W. IlIlh 51"'''
Carll"e,I'A
satisfaction of any and all of said party's rights against the
. other for past, present and future claims on account of support,
,
! maintenance, alimony, alimony pendente lite, counsel fees, costs
~ and expenses, equitable distribution of marital property and any
other claims of each party, including all claims which have been
raised or loay be raised in an action for divorce.
(21) Except as may be otherwise specifically provided in
; this Agreement, Husband and Wife, for themselves, their heirs,
ii representatives and assigns, each hereby forever releases,
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il remises, discharges and quitclaims the other, and such other's
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Ii heirs, representatives, assigns and estate, from and with respect
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il to the following:
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A.
All liability, claims, causes of action, damages,
costs, contributions, expenses or demands whatsoever in law
or in equity;
B.
All rights, title, interest or claims in or to
any property of the other, whether real, personal or mixed
and whether now owned or hereafter acquired;
c.
All rights of curtesy and dower and all claims or
rights in the nature of curtesy and dower;
D. All widow or widower's rights;
E. All rights, title and interest or claims in or to
the other's p.state, whether now owned or hereafter acquired,
including but not limited to all rights or claims:
(1) to take against the other'A will;
(2) under the laws of intestacy;
(3) to a family exemption or similar allowance;
SAlOIS, GUmO,
SIIUFF &
MAS,,^NU
26 W. IlIlh 51"'''
Carli.le,I'A
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and
(4) all other rights or authority to
participate or intervene in a deceased spouse's
estate in any way, whether arising under the laws of
Pennsylvania or any other country, territory, state or
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political subdivision.
F. All rights or claims to any accounting;
G. All rights, claims, demands, liabilities and
obligations arising out of or in connection with the marital
relationship or the joint ownership of property, whether
real, personal or mixed;
H. All rights, claims, demands, liabilities and
obligations arising under the provisions of the Pennsylvania
Divorce Code as the same may be amended from time to time,
and under the provisions of any similar statute enacted by
any other country, state, territory or political
subdlvision;
T. All rights, claims, demands, liabilities and
obligations each party now has, or may hereafter have,
against or with respect to the other.
(22) This Agreement shall be construed under the law of the
Commonwealth of Pennsylvania. If any provision of this Agreement
is determined to be invalid or unenforceable, all other
provisions shall continue in full force and effect.
(23) In the event that either of the parties shall recover a
final judgment or decree of absolute divorce against the other in
a court of comput~nt jurisdiction, t.he provisions of this
SAIUIS, GUIIlO,
SIIlWF &
MASI.ANI>
26 W. llilh 51",rl
CarliLlr.I'A
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'i Agreement may be incorporated by reference or in substance but
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': shall not be merged into such judgment or decree and this
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Agreement shall survive any such final judgment or decree of
absolute divorce and shall be entirely independent thereof.
(24) 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 attorney's fees, court coste and
expenses incurred by the other party in enforcing the Agreement.
(25) This Agreement constitutes the entire understanding
,
I between the parties and there are no covenants, conditions,
,
,
: representations, or agreements, oral or written, of any nature
! whatsoever, other than those herein contained.
!
(26) This Agreement shall bind the parties hereto, their
I respective heirs, executors and assigns.
i
I IN WITNESS WHEREOF, the parties hereto intending to be
I legally bound have hereunto set their hands and seals the day and
,
,
I ye6r first written abuve.
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Witness
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Witness (
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Shirclllanstown, Cumbcrland County, Pcnnsylvania.
14. It is appropriate thnt PlaintifTand thc partics' childrcn bc pcnnitted to havc
cxclusivc posscssion of the marital residcnce.
15. Plaintiff lacks sufficicnt property to provide for hcr rcasonable nccds.
16. Plaintiff is unablc to sufficicntly support hcrself through appropriatc cmploymcnt.
17. Defcndant has sufficicnt ineomc and asscts to providc continuing support for the
Plaintiff.
18. By rcason of this action, Plaintiff will bc put to considerablc cxpcnsc inthc
prcparation of hcr casc in the cmploymcnt of counsel and the payment of costs.
19, The Plaintiff is without suffieicnt funds to support herself and to mcctthc costs
and expenscs of this litigation and is unable to appropriately lIlaintain hcrself during the
pcndency of this action.
20, Plaintifrs income is not sufficicnt to provide for hcr reasonable needs and pay her
attorncy's fccs and thc costs of this litigation.
21. Defcndant has adequate comings to provide for thc Plaintiffs support and to pay
hcr counscl fccs, costs and cxpcnscs.
22. There are two children born to this marriage, namely Brian Senft, born September
28, 1978, and Lindsey Senft, born December 6, 198 I:
23. Plaintiff desires the custody of the minor children and is capable of giving said
children the necessary parental care and a proper and healthful environment.
24. The Plaintiff avers that she is a fit person to raise the minor children and that by
awarding her legal custody, the best interest and pennanent welfare of the children will thereby
be promoted.
25. The parties' minor children have resided at 327 Belaire Drive, Shiremanstown,
Cumberland County, Pennsylvania for the last eight (8) years.
26. Plaintiff has not participated in any other litigation concerning the custody
proceedings in a cOUlt of this or any other state, nor docs she know of any person not a party to
these proceedings who has had physical custody of the children or claims to have custody or
visitation rights.
27. The Plaintiff requests that a reasonable visitation schedule be set up by the Court
regarding visitation of the parties' minor children by Defendant.
COUNT IV . INJUNCTIVE RELmF
28. The Plaintiff believes that the Defendant intends to remove from this jurisdiction,
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dispose of, alienate, encumber and/or dissipate such marital assets for the purpose of and/or
with the intent of defeating Plaintiffs right as prayed for hereinabove, all of which would
irreparably hannthe Plaintiff.
29. The removal from this jurisdiction, disposal of, alienation. encumbering and/or
dissipation of said marital assets by the Defendant would be detrimental to the rights of the
Plaintiff and would defeat the purposes of the Divorce Code, all of which would irreparably
hann the Plaintiff,
WHEREFORE, Plaintiff requests this Ilonorable Court:
(A) Enter a decree of divorce;
(8) Equitably distribute all property, both personal and rcal, owned by the parties;
(C) Compel the Defendant to pay alimony pendente lite to Plaintiff;
(D) Grant PlaintilT attomey's fees and costs;
(E) Compel the Defendant to pay alimony to PlaintilT;
(F) Compel the Defendant to maintain unencumbered said insurance contracts or
policies for the benefit of Plaintiff IInd the children, during thc pcndcncy of this action, and to
order the Defcndantto pcnnanently so maintain such policics thereafter;
(G) Pursuant to Scction3502(c) of the Divorce Code, award the Plaintiff the right
to live in the family home for a reasonable pcriod of time;
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Ihrli,htJl~, 1~'ll"\\hilJlll 171111'11.hH'l
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BONNIE R. SENFT,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
94 - 2811 CIVIL TERM
GEORGE E. SENFT,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
(1) A Complaint in divorce under Section 3301(c) of the
Divorce Code was filed on May 25, 1994.
(2) Defendant acknowledges that service of the Complaint was
made by certified mail on June 2, 1994.
(3) The marriage of Plaintiff and Defendant is irretrievably
broken and ninety days have elapsed from the date of filing the
Complaint.
(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 1s granted.
(5) I consent to the entry of a final decree of divorce.
(6) I understand that if a claim for alimony, alimony
pendente lite, marital property or counsel fees or expenses has
not been filed with the court before the entry of a final decree
in divorce, the right to claim any of them will be lost.
(7) I have been advised of the availability of marriage
counselling and understand that I may request that the court
require that my spouse and I participate in counselling. Being so
advised, I do not request that the Court require that my spouse
and I participate in counselling 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. Section 490 relating to
unsworn falsification to authoriti
DATED: January 4, 1995