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DECREE IN :
D'V~R~ s.. ~,.oSPM.:
AND NOW,l9.~~",." 19.""" It is ordered and .
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF '* PENNA.
TERRY LIN CALDERON,
N 0. H~2.~~HHH"" ,,,,9.~,~,~~ 1994
Plaintiff
Vl'I':'IIS
. FELIX ALBERTO CALDERON,
.., II
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Defendant
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decreed that, ,r.E.IWY, q~ GA!"O!':RQij. , , , , , , " , . , , , , , " , , , , , , " plaintiff,
and, . . , , . , , , , , ,F:J::l..IX .AL/3,E;W\.'P, ,G~W).':,I\Qtl, , , " , , , , , , ., , , , , , " defendant,
are divorced from the bonds of matrimony.
The court retains iurisdlction of the following claims which have
been raised of record in this action for which a final order has not yet
been entered;
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1/' /)~y
MARITAL SETT,l&MENT AGREEMENT
THIS AGREEMBNT, made this l' I.!I day of ;tJ.,Ve".f~e.;', 1994,
by and between TERRY LIN CALDERON, (hereinafter called "Wite") and
FELIX ALBERTO CALDERON, (hereinafter called "Husband").
WIT N E SSE T HI
WHEREAS, the parties hereto are Husband and Wife, having been
married on July 28, 1978 at Carlisle, Cumberland county,
Pennsylvania, and are the parents of two minor children, namely
ADRIANA LOREN CALDERON, born October 14, 1981; and GARRETT LOGAN
CALDERON, born March 28, 19891 and
WHEREAS, difficulties have arisen between the parties as a
result of which they now desire to live separate and apart and by
this Agreement to settle all financial and property rights between
theml and
WHEREAS, in preparing this Agreement and negotiations
contemporaneously therewith, Wife was represented by R. Mark
Thomas, Esquire, and Husband was not represented by counsel,
however, each of the parties is satisfied with the terms of this
Agreement, a full explanation of the Agreement having been made to
them, and Husband, by signing this Agreement, acknowledges that he
knew and understood that he had the right to have his own attorney
review this Agreementl and
WHEREAS, Husband and Wife are satistied that they understand
the value and extent of all property whioh would be considered
"marital property" under the Pennsylvania Divorce Reform Aot,
whether titled or owned separately or jointly as well aa the value
and extent of nonmarital property held or expected to be held by
each otherl and
NOW, THEREFORE, in consideration of the mutual promises and
undertakings set forth herein and intending to be legally bound
hereby, the parties hereto do agree as follows:
1. MUTUAL SEPARATION - Husband and Wife shall be free from
constraint or control by the other as fully as if he or she were
unmarried. Neither shall disturb, trouble and interfere in any way
with the other or with any person for associating with the other.
2. MUTUAL RELEASE Husband relinquishes his inchoate
intestate right in the estate of Wife, and Wife relinquishes her
inchoate intestate right in the estate of Husband, and each of the
parties hereto by these presents, for himself or herself, his or
her heirs, executors, administrators or assigns, does remise,
release, quit claim and forever discharge the other party hereto,
his or her heirs, executors, administrators or assigns, or any of
them, of any and all claims, demands, damages, actions, causes of
action or suits at law or in equity, of whatsoever kind or nature,
for or because of any matter or thing done, admitted or suffered to
be done by said other party prior to and including the date hereof,
further, the parties acknowledge that all rights under the
2
Pennsylvania Divorce Code that are not specifically incorporated
herein are hereby expressly waived.
3. DIVORCE - Wife filed a Complaint in Divorce on July 29/
1994, in the Cumberland county Court of Common Pleas, which is
indexed at NO. 94-4254 civil Term. Husband and Wife agren that
contemporaneously with the execution of this Agreement, they will
each execute an Affidavit of Consent to the entry of a final
divorce decree in this case.
4. EFFECT OF DIVORCE DECREE - This Agreement shall continue
in full force and effect after such time as a final decree in
divorce may be entered with respect to the parties.
5. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE - The
terms of this Agreement shall be incorporated into any divorce
decree which may be entered with respect to the parties. The Court
of Common Pleas, which may enter such divorce decreer shall retain
continuing jurisdiction over the parties and the subject matter of
the Agreement for the purpose of enforcement of any of the
provisions thereof.
6. DATE OF EXECUTION - The "date of execution" or "execution
date" of this Agreement shall be defined as the date upon which it
is executed by the parties if they have each executed the Agreement
on the same date. Otherwise, the "date of execution" or "execution
date" of this Agreement shall be defined as the date of execution
by the party last executing this Agreement.
3
7. PERSONAL PROPERTY - The parties have physically divided
and distributed their household goods and other tangible personal
property. In addition, the parties agree that Wife shall be sole
owner of the 1988 Honda Accord LX and that Husband shall be the
sole owner of the 1986 Pontiac 6000. The parties agree to execute
transfers of title to accommodate this provision of the Agreement.
Also, there is a trailer located in the driveway of the marital
residence which will belong to Husband as a result of this
Agreement, provided Husband removes the trailer from the property
at 1116 Redwood Drive, Carlisle, PA, no later than April 30, 1995.
The parties mutually agree that each shall hereafter be the
sole and separate owner of all such personalty now in their
respective possessions free and clear of all rights, claims and
interests of the other party, except as previously set forth
herein. This Agreement shall constitute a bill of sale by and from
each party to the other to document the individual full ownerships
by each party of the personalty now in their respective
possessions.
8. MARITAL RESIDENCE - Husband and Wife are tenants of the
leasehold premises located at lll6 Redwood Drive, Carlisle,
Cumberland County, Pennsylvania 17013 (the Umarital residenceU).
The parties agree that Wife shall have sole and exclusive rights
under any lease agreement with the landlord with respect to the
marital residence. The Husband is denied any access whatsoever to
the leasehold premises except as herein after set forth.
4
9. DEBTS - During the course of the marriage, and following
the date of separation of the parties, Husbal,d and Wife have
incurred certain bills and obligation and have amassed a variety of
debts. It is hereby agreod, without the necessity of ascertaining
for what purpose and to whose use each of the bills was incurred,
that each party hereto shall be solely responsible for all bille,
obligations and debts that have been assigned to them by the terms
of this Agreement. Each party agrees to hold the other free and
harmless from any and all liability which may arise as a result of
debts assigned to the other party by the terms of this Agreement,
but not fully satisfied by the party to which they were assigned.
Each party agrees to indemnify and defend the other from any claim
regarding such debts. Both parties agree that, in the future,
neither shall cause or permit to be charged to or against the other
any purchase or purchafles which either may hereafter make and shall
not hereafter create any engagements, debts or obligations in the
name of or against each other.
The outstanding debts are divided as followSI
A. Husband shall assume and take sole responsibility
for any obligations, debts or loans at the AFB Federal credit
union.
B. Husband shall be solely responsible to pay the
outstanding debts, loans, and obligations to Lowe's, Hechinger's,
Associates National Bank Master Card, and King's Jewelry credit
cards. Each of the above debts or credit cards are in the
5
Husband's name alone and he is solely responsible for all debts
from these cards, both prior hereto and hereafter.
C. Wife shall assume and take sole responsibility for
any obligations, debts or loans at the Member's 1st Federal Credit
Union.
D. Wife shall be solely responsible to pay the
outstanding debts, loans and obligations to Sear's, Bon-Ton, and
Sunoco credit cards. Each of the above debts or credit cards are
in the Wife's name alone and she is solely responsible for all
debts from these cards, both prior hereto and hereafter.
10. ALIMONY - This Agreement does not provide for the payment
of alimony to either party. Wife hereby acknowledges that she will
not receive any alimony pursuant to this Agreement and hereby
agrees not to seek any alimony or additional spousal support in any
form whatsoever from the Husband as of the date of the execution of
this Agreement.
11. CUSTODY - The parties hereto agree that legal custody of
the children will be shared. With respect to physical custody of
the children, the Wife shall have primary physical custody of the
children and the Husband shall have the following periods of
partial custody:
a. Every other weekend starting at 3:00 p.m. on Friday
and ending at 4:00 p.m. on Sunday.
b. During the school year, Husband agrees to care for
Garrett at l1l6 Redwood Drive, from 6:45 a.m. until Husband takes
6
him to school at l2130 p.m., Monday through Friday (following the
school schedule).
c. During the summer of 1994, Husband will care for
both Garrett and Adriana at l1l6 Redwood Drive, from 8130 a.m.
until llOO p.m., Monday through Friday. (Any changes in this
arrangement must be coordinated with the Wife.)
12. CHILD SUPPORI - Husband agrees to pay $520.00 per month
fo!;" child support. said payments are to be made on a weekly basis,
in cash, every Thursday, in the following amounts: First week -
$ll0.001 Second week - $150.001 Third week - $ll0.001 Fourth week -
$l50.00. If Husband falls behind by more than one week in any of
his support obligations, then Husband hereby agrees that wife may
attach Husband's wages and all legal costs incurred to obtain this
attachment will be paid for by Husband.
Husband will provide health coverage for both children and
continue to pay current life insurance policies for each child.
Husband hereby agrees to continue to support his children
beyond the age of 18 years provided that said child is enrolled in
a school and will share the cost of undergraduate education with
Wife.
l3. INSURANCE - Husband and Wife will each designate the
other liS primary beneficiaries in trust for the benefit of the two
children with respect to the $50,000.00 11 fe insurance pol icies
from prudential that the parties now own. Both policies will
provide that the monies be held in trust for the benefit of the two
7
ch1ldren and that no one elee shall share any part. of the monies
obtained through these life insurance policies.
14. INCOME TAX DEDUCTIONS - It is hereby agreed between the
parties that Wife shall be able each year to claim both children as
exemptions on her Federal and State Income Tax Returns.
15. COSTS - Although this Agreement is being drawn up for and
on behalf of these parties by Wife's attorney, and the Husband is
not represented by legal counsel, Husband hereby agrees to
reimburse Wife for one-half the costs of obtaining the divorce.
16. PENSIONS - Both parties hereto have a pension with their
respective employers as of the date of this Agreement. Each party
hereby relinquishes any right, claim, title or interest with
respect to the other party's pension.
l7. ENFORCEMENT - If either party defaults in the due
performance of any of the terms, conditions and covenants of this
Agreement on his or her part to be performed, the non-defaulting
party shall have the right to sue for specif10 performance or
damages for the breach of this Agreement, and the defaulting party
shall pay the reasonable legal fees for any services rendered by
the non-defaulting party's attorney in any action or proceeding to
compel the defaulting party's due performance hereunder as well as
costs for bringing the action or proceeding.
l8. EXECUTION OF DOCUMENTS - The par.ties agree to execute
all documents, including but not limited to, deeds of title that
are reasonably necessary to effectuate the purpose of this
8
Agreement. In the event that either party shall refuse or fail to
exeoute and/or aoknowledge any such document, then the other party
shall have, and is hereby granted, the right and power to appoint
one or more times any person or persons ot his or her choosing as
attorney-in-tact tor the other party to so execute and acknowledge
such doouments.
19. CONTRACT INTERPRETATION - For purposes of contract
interpretation and for the purpose ot resolving any ambiguity
herein, Husband and Wife agree that this Agreement was prepared
jointly by their respective attorneys.
20. AFTER-ACOUIRED PROPERTY - Each of the parties shall
hereatter own and enjoy, independently of any claim or right of the
other, all items of property, be they real, personal or mixed,
tangible or intangible, which are acquired by him or her after
execution of this Agreement, with full power in him or her to
dispose of the same as fully and effectively, in all respects and
for all purposes, as though he or she were unmarried.
2l. MISCELLANEOUS
A. This Agreement constitutes the entire agreement
between the parties, being the final and complete settlement of all
matters between them and supersedes any prior written or oral
agreements between them respecting the within subject matter.
There are no representations, agreements, arrangements or
understandings, oral or written, between and among the parties
9
her.to relating to the .ubj.ct .att.r ot this A9r..m.nt which are
not tully .xpr....d her.in.
B. Thi. Agreement may not be amended, modiUed, alt.r.d
or revoked except in writing executed by both the partie. her.to.
c. This Agreement may not be assigned by either party
without the prior written consent of the other party.
D. This Agreement may be executed in multiple
counterparts, each of which shall be deemed an original for all
purposes, and all of which together shall constitute one and the
same instrument.
E. This Agreement shall be binding upon the parties
hereto, their heirs, executors, administrators and assigns.
F. This Agreement shall be interpreted under the laws
of the Commonwealth of Pennsylvania.
G. The failure to strictly enforce any part of this
Agreement shall not be deemed a waiver of any other part of this
Agreement.
H. Titles are for convenience and ease of reference
only and are not to be considered part of the Agreement for
purposes of interpretation.
10
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vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
94 - t/;)..<)L! CIVIL TERM
LAW - DIVORCE
TERRY LIN CALDERON,
plaintiff
FELIX ALBERTO CALDERON,
Dftfendant
COKPLAIMT
The plaintiff by her attorney, R. MARK THOMAS, ESQUIRE, brings
this aotion in divorce for a Deoree of Divorce from the bonds of
matrimony and respeotf.ully represents I
1. The plaintiff is TERRY LIN CALDERON, an adult individual,
who currently resides at 1116 Redwood Drive, cumberland county,
CarliSle, PA 17013.
2. The defendant is FELIX ALBERTO CALDERON, an adult
individual, who currently resides at 101 E. Green street,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
3. plaintiff and defendant are both bona fide residents of
the Commonwealth of. Pennsylvania and have been for at least six (6)
months immediately previous to the filing of this Complaint.
4. The plaintiff and defendant were married on July 28, 1978
in carlisl~, Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for
annulment between the parties.
6. The plaintiff avers that the marriage is irretrievably
broken.
7. The plaintiff requests the Court to enter a Decree of
Divorc..
8. plaintiff has been advised of the availability of
marriaqe counselinq and that she may have the riqht to r.equest the
court to require the parties to pa~ticipate in such counBelinq.
B.inq so advised, plaintiff does not request that the court require
the parties to participate in counselinq prior to a Divorce Decree
beinq handed down by the c04rt.
WHEREFORE, the plaintiff prays that a Decree in Divorce be
entered divorcinq Plaintiff from the bonds of matrimony heretofore
existinq between Plaintiff and Defendant.
Respectfully submitted,
x?/~42I--
R. Mark Thomas, Esquire
Attorney for plaintiff
54 E. Main street
Mechanicsburq, PA 17055
(717) 697-4650
I.D.* 41301
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TERRY LIN CALDERON, I IN THE COURT OF COMMON PLEAS OF
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Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
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VB. I 94 - 4254 CIVIL TERM
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FELIX ALBERTO CALDERON, I LAW - DIVORCE
Defendant
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the
Divorce Code waB filed on July 29, 1994.
2. The marriage of plaintiff and defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing of
the Complaint.
3. I consent to the entry of a final decree of divorce.
4. 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.
I, TERRY LIN CALDERON, verify that the statements made in this
Affidavit are true and correct. I understand that false statements
herein made are subject to the penalties of l8 Pa. C.S. 14904,
relating to unsworn falsification to authorities.
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TERRY LIN CALDERON, I IN THE COURT OF COMMON VLEAS OF
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plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
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vs. I 94 - i/.;;sl-l CIVIL TERM
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FELIX ALBERTO CALDERON, I LAW - DIVORCE
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Defendant I
AFFIDAVIT OF CONSENT
1. A Complaint in Divorca under g 3301(C) of the Divorce Code
was filed on ~<-'o ,J,/, /9'1'1 .
2. The marriaqe of plaintiff and defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filinq of
the Complaint.
3. I consent to the entry of a final decree of divorce.
4. I understand that if a claim for alimony, alimony pendente
lite, marital property or counsel fees or expenses has not been
filed with the oourt before the entry of a final decree in divorce,
the riqht to claim any of them will be lost.
5. I have been advised of the availability of marriaqe
counselinq and I understand that 1 may request that the court
require that my spouse and I participate in counselinq.
6. I understand that the court maintains a list of marriaqe
counselors at its Domestic Relations Office, which list i.
available to me upon request.
7. Beinq so advised, I do not request that the court require
my spouse and I participate in counselinq prior to a divorce decree
beinq handed down by the court.
8. I acknowledqe that I received a copy of the Divorce
complaint on .f/r../tf'l which Complaint wall deliv.ry by
certified mail, restricted delivory.
I, FELIX ALBERTO CALDERON, verify that the statements made in
this Affidavit are true and correot. I understand that fal..
statements herein made are subject to the penalties of l8
Pa.C.S.t4904, relatinq to unsworn falsification to authorities.
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IFELI ALBERTO CALDERON
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I R. MARK THOMAS, ESQUIRE I
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I 54 E. MAIN STREET I ,I,
I MECHANICSBURG, PA 17055 I I.'
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TBRRY LIN CALDERON, I IN THE COURT OF COMMON PLEAS OF
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Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I 94 - If.,ij,-f
ve. I CIVIL TERM
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FELIX ALBERTO CALDERON, I LAW - DIVORCE
Defendant
AFrIDAVIT or SIRVICI
I, R. MARK THOMAS/ ESQUIRE, being duly sworn according to law,
depose and say that on C1.~.d .f, /99-1 , I mailed by certified
mail, restricted delivery, a true copy of the Divorce Complaint
filed by TERRY LIN CALDERON, to the defendant, FELIX ALBERTO
CALDERON. A receipt was returned to me which indicates that the
Complaint was received by FELIX ALBERTO CALDERON, on i/~/91
Said receipt is attached hereto.
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R. MARK THOMAS, ESQUIRE
Sworn to and subscribed
before me this 7 iJI day
of f/lltNndlvvt) , 1994.
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