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SBPARATIOH AND PROPBRTY SBTTLBMBIIT AGRBBIIBH'l'
THIS AGRBBIIBHT, IlIAde this /? f!- day of Ootober /
1994/ by and between ROBERT E. FEIR/ hereinafter referred
to as "Husband", and PRISCILLA L. FEIR/ hereinafter referred to
as "Wife".
WITNESSETH I
WBBRBAS/ the partiee hereto are Husband and Wife, and
WBBRBAS/ the parties have no ohildren born of this
IlIArriage, and
WBBRBAS/ differences have arisen between Husband and Wife,
as a result of whioh it ie the desire of the parties amioably to
adjust, oompromise and settle all property rights and all rights
in, tOt or against eaoh other's property or estate/ inoluding
property heretofore or subsequently aoquired by either party/ and
to settle all disputes existing between them, inoluding any and
all olaims for maintenanoe, support/ alimony, equitable
distribution, counsel fees, and oosts, and
WBBRBAS, it is the mutual desire of Husband and Wife to
reduoe their agreement to writing; and
HOW, TBBRBFORB/ in oonsideration of the mutual promises,
oovenants/ and agreements hereinafter contained, eaoh of the
parties hereto, intending to be legally bound hereby promises,
covenants/ and agrees as followSI
1. P.r~i.. to Live Sea_rate and ADart
After the date of this Agreement, the parties mutually agree
to live separate and apart/ as though the parties had not been
married. Although the parties may share the same residenoe for a
period of timet they agree that their date of separation shall be
the date of this Agreement.
Neither party will molest the other, or oompel the other to
cohabit or in any way harass or malign the other, nor in any way
interfere with the peaoeful existenoe of the other.
2. Personal ProDerty
Husband and Wife have divided most personal property which
would oonstitute marital property and agree that Husband will
receive that property describeo in Sohedule A and Wife will
receive that property deeoribed in Schedule B. Items marked with
an asterisk on Sohedule A will remain at 109 North 30th Streett
Camp Hill. for one year or until, a mutually agreeable date prior
to the expiration of one year. Wife agrees that any other
property in the possession and oontrol of Husband at the time of
the signing hereof shall be the sole and separate property of
Husband, and Husband agrees that any other property in the
possession and oontrol of Wife at the time of the signing h.reof
shall be the sole and separate property of Wife.
Baoh of the parties does hereby speoifically waive, release,
renounoe and forever abandon whatever olaim., if any/ he or she
may have to the sole and separate property of the other.
3. Autn--bil..
HUlb.nd will ret.in the u.u .nd po..e..ion of the 1991 s.gle
Premier .nd .gree. to ...ume full rt.pon.ibility for the le..e
p.yment in the amount of $316.00 per month through J.nu.ry 1996
for thi. vehiola. Wife waive. any interest ahe may h.ve in thi.
l..aed vehiole.
Wife will ret.in ownership of the 1990 Volvo titled in her
~
name alone, a~ainst which there
"'''Y 11_,,' I,. "pJ vttf"dl.
4. S.vina. and Inve.tments
are no liens.
V,p;,
flu, t.ilrl,l w",i.", A"Y ,'",1''''1 J. 04,
A. Wife agrees that the following savings and investments
.hall be the sole and separate property of Husbandl
1. T. Rowe Price Capital Appreciation IRA - Bal.noe
$2/176.00.
2. T. Rowe Prioe Equity Inoome IRA - Balanoe $5/046.00.
3. T. Rowe Price New Horizons IRA - Balanoe $1/860.00.
4. Pennsylvania National Bank Certifioate of Depoait -
Matures September 1997 at $24/950.00.
5. Savings and Checking Acoounts in Husband's name.
B. Husband agrees that the following savings and
investments shall be the sole and separate property of Wifel
1. Fidelity Growth and Income Mutual Fund - Balanoe
$4/053.00.
2. Fidelity Magellan Mutual Fund - Balanoe $2/234.00.
3. Meridian Bank Certificate of Dsposit - Matures Janu.ry
1996 - Balanoe $9/270.00.
4. Savings and Checking Acoounts in Wife'. name.
5. ~ontrlbutlon. Toward Underaraduate Iduaation
Hu.b.nd .nd Wife .h.ll u.e the asset. li.ted in Paragraph
4.A.4. .nd Paragraph 4.B.l.-3. to pay undergraduate education and
related expen.es of wife's son/ Christopher J. Denioola. It i.
undexltood that the a.Bets in Paragraph 4.A.4. will be pledg~d as
ooll.teral for the loa" liBted in Paragraph 6.A.l. and these
...ets will not be available for eduoation expenses before
September 1997. Husband will not repledge the assets in
Paragraph 4.A.4. or extend the loan listed in Paragraph 6.A.1.
Beginning with the fall 1997 semester/ to the degree the
as.et. in Paragraph 4.A.4. are sufficient, Husband shall pay
tuition, room, board/ and fees directly to the oollege. In the
event Christopher J. Denioola is living off oampus or not eating
in oollage oafeterias/ Husband shall pay him directly at the
beginning of each month or eaoh semester an amount suffioient to
oover meals and housing. In addition, Huaband shall pay him $200
.pending money eaoh month from September 1997 until two months
following graduation.
Husband hereby agrees to pay Christopher J. Denioola the sum
of $110 per month for a period of one year commenoing on
September 1/ 1994.
6. Marita~ Debts
Husband and Wife eaoh covenant, represent/ and agree that
eaoh will now and at all times hereafter save harmless and keep
the other indemnified from all debts, charges and liabilities
inourred by the other prior to or after the effective date of
thi. Agreement, except as may be otherwise speoifioally provided
for by the term. of thi. Agreement.
A. Hu.band a..umes and agrees to pay and hereby agree. to
hold Wife harmle.. on the following debt. and obligation. I
1. Pennsylvania National Bank Loan/ aeoured by the a.set.
li.ted in Paragraph 4.A.4. - approximate balance of
$24/000.00.
2. Pennsylvania state Employees Credit Union per.onal
loan/ approximate balanoe of $9/000.00.
3. primerioa Bank Masteroard approximate balanoe
of $800.00.
4. Fir.t USA Visa, approximate balanoe of $3/600.00.
5. Nationsbank of Delaware Visa, approximate
balanoe of $200.00.
6. Chase Advantage Credit, approximate balance of $800.00.
7. First Bankcard Center Viea, approximate balance
of $200.00.
B. Wife aasumea and agrees to pay and hereby agrees to hold
Hu.band harmless on the following debt~ and obligational
1. John Wanamaker Credit Card, approximate balanoe of
$1/100.00.
2. Heaa'a Credit Card, approximate balanoe of $800.00.
3. Maoy'a Credit Card, approximate balanoe of $400.00.
4. Mid-Penn Visa, approximate balanoe of $1/000.00.
5. Joseph A. Banks Credit Card, approximate balanoe of
$300.00.
6. Bon-Ton Credit Card/ approximate balance of $1/000.00.
7. CitiBank Masteroard, approximate balance o~ $2,500.00.
fi1
B. Fidelity Mastercard, approximate balanoe of $1/500.00.
C. At the time this Agreement is signed Husband and Wife
agree to return to eaoh othur, and oease to use/ any credit cards
issued in the name of the other party, P/l(f,.~ I.. H.J~'" \ /'1_"..1 (.~iI)
Wilt. ~,'I( ...ti... "'" /1.y " /11r. .:' ...-'1>-:
7. Real Property ~
Husband and Wife agree that Wife shall have the exolusive
right to reside in the marital real estate at 109 North 30th
Street, Camp Hill, Cumberland County/ Pennsylvania on and after
Wit,'l~
the date of the signing of this Agreement.
Wife shall be solely
responsible for the cost of the PSECU mortgag~ payments/ taxes/
utilities, and all other household expenses/ effeotive August 1/
1994. Husband agrees to pay the eleotrio bill for eleotric
servioe provided to 109 North 30th Street for one year trom
September 1/ 1994.
Immediately upon the signing of this Agreement/ Husband and
Wife agree to oonvey to Wife a General Warranty Deed conveying
the marital property described above to Wife. Husband agrees to
pay all costs involved with the transfer of this property to
Wife. Wife further agrees to remove Husband's name from the
first mortgage of this property so long as PSECU will allow this
and so long as Husband pays all oosts inoident to the removal of
his name from the mortgage. If, however, PSECU will not allow
this or if Husband does not/will not pay the oosts inoident to
this removal, then the mortgage shall remain in both names and
Wife shall indemnify and save Husband harmless from any and all
liability with regard to this debt.
Husband and Wife acknowledge that the home equity loan
previoully held at Pennlylvania National Bank has been latilfied.
They further aoknowledge that in order for Husband to latilfy
that loan, he wa. oompelled to ule the property .et forth in
paragraph 4.A.4. a. collateral for a new loan. However/ al
pr.vioully .et forth in Paragraph 5/ Hu.band agree. that laid
alletl will not be re-pledged nor will he extend the torm. or
time fra~nte of this new loan. It is therefore expeoted that the.e
a..et. will be made available by no later than September 1997.
Wife .hall maintain exclusive right and title to the
approximately one aore of real estate situate in Saylor.burg,
penn.ylvania, whioh she uwned at the time of the marriage, and
Hu.band waives any interest whioh he may have in this property by
virtue of the marriage.
8. Al1mnnv and Sup~ort for Self
Husband and Wife are presently employable and waive all
olaims against the other for maintenanoe, support/ alimony, or
alimony pendente lite whioh may arise out of the marital
relationship.
9. Waiver of Interest in Retirement
Hu.band and Wife expressly waive and relinquish any right,
olaim, title or interest in any pension, profit~sharing,
retirement, oredit union or any other employment-related plan. in
which the other has any interest, whether vested or unvested,
matured or unmatured. Specifioally, Husband waives any intere.t
in Wife'. Publio Sohool Employees' Retirement System Pension and
Wife waives any intereat in Husband's pensions with the State
Employees' Retirement System/ the Public School Employee.'
Retirement System, and TIAA-CRBF.
10. ~aal Representation and Mutual Disclosure
The parties oonfirm that they have relied on the
completeness and substantial aocuraoy of the finanoial disolosure
of the other as an induoement to the exeoution of this Aqreement.
Ths parties acknowledqe that there has been no formal disoovery
conducted in their pendinq divoroe aotion and that neither party
has filed an Inventory and Appraisement as roquired by the
Pennsylvania Divoroe Code, 23 Pat C.S.A. 53505. Notwithstanding
the foregoing, the riqhts of either party to pursue a olaim for
equitable distribution, pursuant to the Pennsylvania Divorce
Cod~, of any interest owned by the other party in an asset of any
nature at any time prior to the date of exeoution of this
Aqreement that was not disolosed to the other party or his or her
counsel prior to the date of the within Agreement is expressly
reserved. In the event that either party/ at any time hereafter,
disoovers suoh an undisoloeed anet/ the party shall have the
riqht to petition the Court of Common Pleas of Cumberland County
to make equitable distribution of said asset.
Husband and Wife deolare that each has had a full and fair
opportunity to obtain and consult with legal oounsel of his/her
eelection and that the parties, oognizant of their legal rights/
declare and express thatl
a) Husband is represented by Debra K. Wallet, Bsq., and
b) Wife has oonsulted with Mada P. Cognetti/ Bsq.
11. Mutual Discharoe
Hu~band relinquishes hi. inchoate intestate riqht in the
estate of Wife, and wife relinquishes her inohoate intestate
right in the estate of Husband, and eaoh of the parties hereto
for himself or herself, his or her heirs, exeoutors/
administrators or assigns does remise, release, quitolaim and
forever discharge the other party hereto, his or her heirs,
executor., admini.trators or assignu, or any of them, of any and
~ll olaims, demand., of whatsoever kind or nature for or beoause
of a ~tter or thing done, omitted or suffered to be done by said
party prior to and inoluding the date hereof/ exoept that this
relea.e shall in no way exonerate or disoharge either party
hereto from the obligations and promises made and imposed by
reason of this Agreement.
12. No-Fault Divoroe
Hu.band has instituted an action for divoroe in the Court of
Common Pleas of Cumberland County alleging that the marriage is
irretrievably broken and requesting a no-fault divoroe under
Section 3301(0) of the Divoroe Code.
It is hereby agreed that the marriage is irretrievably
broken and that immediately after the expiration of the ninety
day period, both parties will exeoute affiuavits of oonsent to
the entry of a Decree in Divoroe under Seotion 3301(0) of the
Divoroe Code.
If Wife fails to sign her affidavit of oonsent to the entry
of a Deoree in Divoroe under Section 3301(0) of the Divorce Code
when it is presented to her after the ninety (90) day period,
this Agreement shall be null and void and of no further foroe and
effeot.
13. BKeaution and Deliverv of Dooll....\1t.
The partiee hereto agree to exeoute and deliver all paper.
needed to effeotuate the terms and intentione of this Agreement.
14. BreachinG Party Pay. Co.te
If any party breaohes any provieion of this Agreement, the
other party shall have the right, at hie or her election, either
to eue for .peoifio performanoe or for damage. for such broaoh,
and the party breaohing this Agreement shall be responsible for
reaeonable legal fees and costs incurred by the other in
enforoing his or her ri9hts under this Agreement.
15. General provisions
This Agreement enoompaeses all agreements between the
partie. oonoerning the matters set forth hsrein and may not be
altered or omitted except in writing exeouted by the parti3.'
the waiver of any term/ oondition or provision of this Agreement
.hall in no way be deemed a waiver of any other term/ oonditions
or provisions of this Agreement.
If any term/ oondition or provision of this Agreement shall
be determined to be void or invalid in law or otherwise, then
only that term/ condition or provision shall be strioken from
this Agreement, and in all other respects/ this Agreement shall
be valid and oontinue in full foroe.
It is agreed by and between the parties hereto that this
Agreement shall survive and shall not be merged into any deoree/
jUdgment, or order of divoroe or separation. It is speoifioally
agreed, however, that a oopy of this Agreement or the substance
of the provisions thereof, may be inoorporated, by referenoe,
..."
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IN THB COURT OF COMMON PLBAS
CUMBBRLAND COUNTY, PBNNSYLVANIA
RODBRT B. FBIR, I
Plaintiff I
I No.
v. I
I IN DIVORCB
PRISCILLA L. FBIR, I
Defendant I
DIVORCE COMPLAINT
1. The Plaintiff is Robert E. Feir, who currently
r..ides in Cumberland County, with an address of 109 North 30th
Street, Camp Hill, Pennsylvania 17011.
2. The Defendant is priscilla L. Feir, who currently
resides in Cumberland County, with an address of 109 North 30th
Street, Camp Hill, Pennsylvania 17011.
3. Plaintiff and Defendant have been bona fide
residents of the Commonwealth of Pennsylvania for at least six
(6) months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on August 24,
1986 at Bethlehem, Pennsylvania.
5. There have been no prior actions of divorce or for
annulment between the parties.
6. Divorce is sought pursuant to the provision of the
Divorce Code, Section 3301(c), in that the marriage is
irretrievably broken.
7. The Plaintiff has been advised of the availability
of counselling and of the Plaintiff's right to request that the
IN THB COURT OF COMMON PLBAS OF
CUMBBRLAND COUNTY, PENNSYLVANIA
ROBBRT E. FEIR, I
plaintiff I
I No. ,
v. I
I IN DIVORCB
PRISCILLA L. FEIR, I
Defendant I
VERIFICATION
I verify that the statements made in the foregoing
Complaint are true and oorrect to the best of my knowledge,
information, and belief. I understand that falme statements
made herein are made subjeot to the penalties of. 18 Pa. C.S.
Seotion 4904, relating to unsworn falsifioation to authoritiea.
I,i.. IL
ROBERT E. FEIR
Datel July Z{, 1994
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IN THB COURT OF COMMON PLBAS
CUMBBRLAND COUNTY, PBN~SYLVANIA
ROBBRT B. FBIR, I
Plaintiff I
I No. 94-4241 CIVIL TBRM
I'. I
I IN DIVORCB
PRISCILLA L. FEIR, I
Defendant I
AFPIDAVIT OP SIRVICI
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBBRLAND
Debra K. Wallet, being duly sworn according to law, deposes
and says that she is the attorney for Plaintiff, Robert E. Feir,
and that she did mail a true and correot copy of the Complaint in
divorce in the above matter, by certified mail, return receipt
requested, to the Defendant, priscilla L. Feir, on August 1,
1994, at her last known address I 109 North 30th Street, Camp
Hill, PA 17011, which satisfied the requirements of service by
mail pursuant to Pa. R.C.P. 403. The signed reoeipt
aoknowledging reoeipt on August 4, 1994 is attached hereto 4S
Exhibit "A".
\..Ot..... ~. WL\.W""
Debra K. Wallet, Esquire
Sworn to and subscribed before me
this t')jl day of August, 1994
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Kalhleen oNolarlal Seal
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M C roug ,Cumbarland County
y ommlaalon E,plrll Juna 9, 1998
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IN THB COURT OF COMMON PLBAS
CUMBBRLAND COUNTY, PBNNSYLVANIA
ROBBRT B. FBIR,
Plaintiff
v.
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I
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I
No. 94-4241 CIVIL TBRM
IN DIVORCE
PRISCILLA L. FBIR,
Defendant
AFFIDAVIT OF CONSENT
1. a. A Complaint in Divorce under Section 3301(c) of the
Divorce Code was filed on July 28, 1994.
b. I her.eby acknowledge receipt of a copy of same.
2. The marriage of Plaintiff and Defondant is irretrievably
broken and ninety (90) days have elapsed from the ddte of filing
the Complaint.
3. I consent to the entry of a final decree of divorce.
4. I have been advised of the availability of marriage
counselling, I understand that the Court maintains a list of
marriage counselors in the Prothonotary's Office, which list is
available to me upon request, and being so advised, I do not
request that the Court require marriage counselling.
5. I understand that I may lose my rights concerning
alimony, division of property, lawyer's fees or expenses if I do
not claim them before a divorce is granted.
I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein are made
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IN TUB COURT OF COMMON PLBAS
CUMBBRLAND COUNTY, PBNNSYLVANIA
ROBBRT B. FBIR,
Plaintiff
No. 94-4241 CIVIL TBRM
IN DIVORCR
v.
PRISCILLA L. FBIR,
Defendant
AFFIDAVIT OF CONSBNT
1. a. A Complaint in Divoroe under Seotion 3301(0) of the
Divoroe Code was filed on July 28, 1994.
b. I hereby aoknowledge reoeipt of a oopy of same.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing
the Complaint.
3. I oonsent to the entry of a final decree of divoroe.
4. I have been advised of the availability of marriage
oounselling, I understand that the Court maintains a list of
marriage counselors in the Prothonotary's Offioe, whioh list is
available to me upon request, and being so advised, I do not
request that the Court require marriage counselling.
5. I understand that I may lose my rights oonoerning
alimony, division of property, lawyer's fees or expenses if I do
not claim them before a divorce is granted.
I verify that the statements made in this Affidavit are true
and oorreot. I understand that false statements herein are made