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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF '* PENNA.
MICHELLE L. BEAM,
Plaintiff
N I), ...~.~.??......,... ~~.Y,~.L" 1994
V lll':-i1I:-i
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II
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RICHARD T. BEAM,
Defendant
DECREE IN
DIVORCE
AND NOW, ",1)~..},?...... 19.9~,.
It Is ordered and
decreed that. . \'l.I.GHJ::LJ,E. L., .aEM . . . .. , . . . . . . . , , , . , . . , , . .. ,.. pl(llntlff,
and. . . . , ,. .. ., .lHCtlARO. r.., .~EAM. . . . . , . . . , , , . .., . . . . . . .., , .. defendant,
are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which have
been raised of ~'GOId in this action for which a final order has not yet
been entered; \I\}~
T\1~.s. . ~~~.r:17~. ~,~,"o~p.orlil~,e.~ . ~!\.e. .~~:r.r:~~g~'j~.~~t):E!l]\~f'\.~ .Ag,r.~E!l]\!!,I\~. . , . .
dated November 3 1994. ,/'
, . . , , . . . , , , . . . . . .. "..,.........,...... ....,.., . ,..."..".,..".,..,.
ny
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MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT, made this 13'ilf.i day of lVoVJ;mtJEI'!. , 1994,
by and between MICHELLE L. BEAM, (horeinafter oalled "Wife") and
RICHARD T. BEAM, (hereinafter called "Husband").
WIT N E SSE T HI
"
WHEREAS, the parties hereto are Husband and Wife, having been
married on September 27, 1991 at Camp Hill, Cumberland county,
Pennsylvania, and further, there are no children as a result of
this marriage I 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 wall represented by R. Mark
Thomas, li:squire, 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 satisfied that they understand
the value and extent of all property which would be considered
"marital property" under the Pennsylvania Divorce Reform Act,
whether titled or owned separately or jointly as well as the value
and extent of nonmarital property held or expected to be held by
each other, and
NOW, THEREFORE, in consideration of the mutual promises and
undertakings set forth horein and intending to be legally bound
hereby, the parties hereto do agree as follows:
1. MUTUAL SEPARATIO~ - 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
Pennsylvania Divorce Code that are not specifically incorporated
herein are hereby expressly waived.
2
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. 94-4255 civil Term. Husband and Wife agree 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 wlth 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 p.'lrties. The Court
of Common Pleas, which may enter such divorce decree, 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.
7. PERSONAL PROPERTY - The parties have physically divided
and distributed their household goods and other tangible personal
property. The parties mutually agree that each shall hereafter be
3
the sole and separate owner of all such personalty now in their
respective possessions free and clear of all rights, olaims and
interests of the other party, except as previously set forth
herein. This Agreement shall constitute a bill of sale by and from
eaoh party to the other to document the individual full ownerships
by each party of the personalty now in their respeotive
possessions.
8. MARITAL RESIDENCE - Husband and Wife have no real
property and both are tenants under separate lease agreements with
separate landlords. Both parties agree to hold the other harmless
for any financial obligations arising under their respeotive lease
agreements.
9. DEBTS - During the course of the marriage, and following
the date of separation of the parties, Husband and Wife have
incurred certain bills and obligation and hav~ amassed a variety of
debts. It is heleby agreed, 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 bills,
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 rasult 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 olaim
regarding such debts. Both parties agree that, in the future,
4
neither shall oause or permit to be oharged to or against the other
any purohase or purohases whioh either may hereafter make and shall
not hereafter oreate any engagements, debta or obligations in the
name of or against eaoh other.
With the exception of a tax liability from 1992 which will be
addressed in the next paragraph the outstanding debts are divided
such that each party shall be solely responsible for all debts
which are inourred in their individual names. The parties hereby
state that there are no debts that are in the joint names of
Husband and Wife, but rather all debts are in individual names and
each assumes responsibility for the debts in their name alone.
There is an outstanding tax liability with reqard to the 1992
Federal Income Tax. This liability is in the amount of
Husband agrees to pay this obligation in full as though it was his
sole obligation and to hold wife harmless such that he will
indemnify her for any payment she is compelled to make on this tax
liability.
,
lO. 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 - There were no children born as a result of this
marriage and, therefore, custody of children is not an issue in
5
thi. Agreement.
12. CHILD SUPPORT - There were no children born as a result
of this marriage and, therefore, child support is not an issue in
this Agreement.
13. PENSIOtiS - Each party hereby relinquishes any right,
claim, title or interest with respect to the other party's pension.
14. 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 specific performance or
damages for the breach of this Agreement, and the defaulting party
dhall 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.
15. EXECUTION OF DOCUMENTS - The parties agree to execute
all documents, including but not limited to, deeds of title that
are reasonably necessary to effectuate the purpose of this
Agreement. In the event that either party shall refuse or fail to
execute and/or acknowledge 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 of his or her choosing as
attorney-in-fact for the other party to so execute and acknowledge
such documents.
6
16. ,PNTRACT INTERPRETATION - For purposes ot oontraot
interpretation and tor the purpose ot rllsolving any ambiguity
herein, Husband and Wite agree that this Agreement was prepared
jointly by their respeotive attorneys.
17. AFTER-ACQUIRED PROPERTY - Each ot th.. parties shall
hereatter own and enjoy, independently of any claim or right ot the
other, all items ot property, be they real, personal or mixed,
tangible or intangible, whioh are acquired by him or her atter
execution of this Agreement, with tull power in him or her to
dispose ot the same as fully and ettectively, in all respeots and
tor all purposes, as though he or she were unmarried.
18. 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 subjeot matter.
There are no representations, agreements, arrangements or
understandings, oral or written, between and among the parties
hereto relating to the subjeot matter of this Agreement whioh are
not tully expressed herein.
B. This Agreement may not be amended, modified, altered
or revoked except in writing executed by both the parties hereto.
C. This Agreement may not be assigned by either party
without the prior written consent ot the other party.
7
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MICHELLE L. BEM, I IN THE COURT OF COMMON PLEAS OF
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plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I 1994 - Y J, '35
v.. I CIVIL TE'.UI
I
RICHARD T. BEAM, I DIVORCE
I
Defendant I
KOTIC. TO DlrlKD AHD CLAIK RIGHTS
You have been sued in court. If you wish to defend
against the claims set forth in the fOllowing pages, you must take
prompt action. You are warned that if you fail to do so, the case
may proceed without you and a decree of divorce or annulment may be
entered against you by the court. A judgment may also be entered
against you for any other claim or relief requested in these papers
by the plaintiff. You may lose money or prOPQrty or other rights
important to you/ including custody or visitation of your children.
When the ground for the divorce is indignities or
irretrievable breakdown of the marriage, you may request marriage
counseling. A list of marriage counselors is available in the
Office of the prothonotary at the Cumberland County Courthouse,
First Floor, Carlisle, Pennsylvania 170l3, Telephone I (717)-240-
6195.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT
IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
Court Administrator
Cumberland County Courthouse
Fourth Floor
Carlisle, Pennsylvania l70l3
Telephone (7l7)-240-6200
MICHELLE L. BEAM, I IN THE COURT OF COMMON PLEAS OF
I
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I 1994- LI;;.:;'j
VB. I CIVIL TERM
I
RICHARD T. BEAM, I DIVORCE
Defendant
COHl'LaIII'1' IN DlVOIOI
The plaintiff, by her attorney, R. MARK THOMAS, ESQUIRE,
brings this action in divorce for a Decree of Divorce from the
bonds of matrimony and respectfully represents I
1. The plaintiff is MICHELLE L. BEAM, an adult individual,
who currently resides at 25 Old Depot Road, New Cumberland,
Penneylvani~ 17070.
2. The defendant is RICHARD T. BEAM, an adult individual,
who currently resides at 317 W. Main street, Apt. U,
Mechanicsburg, PA 17055.
3. Plaintiff and defendant have been bona fide residents of
the Commonwealth for at least 6 months immediately previous to the
filing of this Complaint.
4. The plaintitf and defendant were married on
September 27, 1991, in Camp Hill, Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for
annulment between the parties.
6. The marriage is irretrievably broken.
7. The plaintiff requeste the court to enter a Decree of
Divorce.
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MICHELLE L. BEAM, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
v.. I 1994 - 4255 CIVIL TERM
I
RICHARD T. BEAM, I DIVORCE
Defendant I
ArrIDAVIT or CONBlIlI'1'
1. A complaint in Divorce under section 3101 (c) of the
Divorce Code was 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.
5. I have been advised of the availability of marriage
oounseling and I understand that I may request that the oourt
require that my spouse and I participate in counseling.
6. I understand that the court maintains a list of marriage
counselors at its Domestic Relations Office, which list is
available to me upon request.
7. Being so advised, I do not request that the court require
my spouse and I participate in counseling prior to a divorce decree
being handed down by the court.
8.
Complaint
certified
I acknowledge that I received a copy of the Divorce
on August 9, 1994, that Complaint was sent to me by
mail.
I, RICHARD T. BEAM, 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 18 Pa.C.S.14904,
relating to unsworn falsification to authorities.
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HARD T. BE:
1/ -..3 '1'1
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USE TO AVOID PAYMENT
Of POllTAGE, 1300
Print vour neme, addrees end ZIP Code hell
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R. MARK THOMAS, ESQUIRE
54 E. MAIN STREET
MECHANICSBURG, PA 17055
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