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$: IN THE COURT OF COMMON PLEAS *
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OF CUMBERLAND COUNTY
STATE OF '* PENNA.
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THOMAS R. WILSON,
N 94-5698 Civil
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Versus
CAROL J. WILSON,
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Defendant
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DECREE IN
DIVORCE
AND NOW, ",. ,fA fl'r.;,{",~,..,..,... 191'1.. it is ordered and
decreed that... ,.. .~~?~s. ~:, .I'!~~~?~,., . . ., . . , ..., ... .. ... .. plaintiff.
and. ... . .. .. ... .., . ~A.~qL. ~....I:I~~.~q~. .... . ,,, ... ... .. ....... defendant.
are divorced from the bonds of matrimony.
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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;
.. ~~;; 'TTHE~~O~Fl?' ,~H~,,.~EP?\~TIO,N ,'>:-G~.~EME~.~ .I??-~.E:l?, S~'p'~~~*',~:r;. ~.6.,.. ~~.94
""u "''' t' L",M"'lnAL Ac.REEMENT DATED Harch 31, 1997, ARE
., HJ,C:Q~PO.RATED, ,BUT, NOT, MERGED .INTO ,THIS .DECREE.. , . , " . . ,..... .. ...
Dy Th. Court: /7 fJ
tJA-, f/~ a < ("r ,.
AIt..t: "'~';")~'t<':1 {'6D~(,d ~.
(f~.(~K r y~{" J:J:jz
(/ pt{i~notary
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J:I.,il'-CII\.u...-..... (.at 40664-....01
THIS Agreement mede this
Iv
1994 by
day of
and between THOMAS R. WILSON, of 20 East Street, Mt. Hol y, Springs, Pennsylvania, hereinafter
referred to as HUSBAND, and CAROL J. WILSON, of P. O. Box 1064, Bowie, Maryland, hereinafter
referred to as WIFE,
WITNESSETH:
WHEREAS, the parties hereto are husband and wife, having been joined in marriage on
February 26, 1971, in Shermansdale, Pennsylvania; and
WHEREAS. the parties hereto are desirous of settling fully and finally their respective financial
and property rights and obligations as between each other, including, without limitation, the settling
of all matters between them relating to the ownership of real and personal property, and In general,
the settling of any and all claims and possible claims against the other or against their respective
estates.
NOW, THEREFORE, In consideration of these considerations, and the mutual promises and
undertakings hereinafter set forth, and for other good and valuable consideration, receipt and
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sufficiency of which is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE.
each intending to be legally bound, hereby covenant and agree as follows:
1. Advice of Counsel: The parties hereto acknowledge that each has been notified of
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his or her right to consult with counsel of his or her choice, and have been provided a copy of this
agreement with which to consult with counsel. HUSBAND is represented by Carol J. Undsay,
o.:\..pJl\.cJI\..u...~ f"- .w.cw-M-Ol
Esquire, and WIFE, has been advised that she may be represented by counsel of her choice. Each
party acknowledges anc accepts that this agreement Is, In the circumstances, fair and equitable,
and that it Is being entered Into freely and voluntarily, after having received such advice and with
such knowledge as each has sought from counsel, and that execution of this agreement Is not the
result of any duress or undue Influence, and that It is not the result of any Improper or illegal
agreement or agreements.
2. Divorce: Neither party wishes to file a Complaint for Divorce at the present time. If
either party, at some time In the future, files a Complaint in Divorce, the other party will cooperate
by signing an Affidavit of Consent to a divorce 90 days after the date of the filing of the Complaint.
3. Personal Property: The parties acknowledge that they have equitably and
satisfactorily divided all of their personal property as set out on Exhibit 'A' attached hereto and
incorporated herein. From the date of this Agreement. all such property shall be the sole and
individual property of the party to whom it Is assigned on exhibit 'A'. However, sald property will
remain at the residence of the HUSBAND until such time as WIFE requires those items assigned
to her on Exhibit 'A'. Further, In the event that one party files a Complaint in Divorce, WIFE will
remove her property from HUSBAND's residence within nine months of the date of the filing.
WIFE will retain the 1993 Dodge Spirit and make the payments of $280.00 per month
each and every month on or before the due date. When the car has been paid in full, HUSBAND
will execute any and all documents to transfer to WIFE all his right, title and interest In the Dodge
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c:lwpjl\c..'_...... na. .......lJr4..4l
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be sold. The townhouse may be listed for sale at the request of ether party, and the parties will
cooperate with one another In a listing agreement. The parties will equally dMde the costs of sale,
the proceeds, and, if a deficiency remains, they will equally split the deficiency balance.
5. Spousal Support: The parties waive any claim that they may hal/e one against the
other for spousal support or alimony pendente lite. The parties acknowiedge that each has
sufficient assets wlt.~ which to maintain themselves during separation. In the event that the parties
shall divorce, they acknowledge that each has sufficient assets with which to maintain themselves
attar divorce, and they waive any claim they might have one against the other for alimony.
6. Marital Debt: The parti~s have. in their own names, certain credit card accounts
which may include some marital debt. Each party will be responsible for the debt on the credit card
accounts In his or her name. Each party will incur no debt for which the other may be liable, and
will indemnify and hold the other harmless for any debt so incurred.
HUSBAND shall pay the automobile insurance on the parties' vehicles until a decree
of divorce, if any, Is entered. After said date, he will maintain the automobile insurance on the 1987
Dodge Raider and the 1984 Chevette. WIFE shall pay for the automobile insurance on the 1993
Spirit commencing 6 months from the date of this Agreement. The parties shall indemnify and hold
the other harmless against any loss on account of their failure to abide by the terms of this
Agreement.
7. Federal Income Tax: The parties will file a joint federal income tax return for 1994
and divide equally any refund they shall receive.
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8. Modification: No modification, rescission, or amendment of this agreement shall be
effective unless In writing signed by each of the parties hereto.
9. Applicable Law: All acts contemplated by this agreement shall be construed and
enforced under the laws of the Commonwealth of Pennsylvania.
10. Agreement Binding on Parties and Heirs: This agreement, except as otherwise
expressly provided herein, shall bind the parties hereto, and their respective heirs, executors,
administrators, legal representatives, assigns and successors in any interest of the parties.
11. Agreement Not to be Merged: In the event that the parties divorce, this agreement
shall be incorporated into the final decree of divorce of the parties hereto for purposes of
enforcement only, but otherwise shall not be merged into said decree. The parties shall have the
right to enforce this agreement under the Divorce Code of 1980, as amended, and In addition, shall
retain any remedies in law or In equity under this agreement as an independent contract. Such
remedies in law or equity are specifically not waived or released.
12. Reconclllatlorl: In the event the parties shall end their separation and again live one
with the other, the terms of this Agreement shall remain in full force and effect unless altered by the
written agreement of the parties.
13. Documents: The parties hereto agree that they will execute and deliver one to the
other any documents necessary to give effect to the terms of this Agreement.
II 14. Full and Final Settlement: WIFE and HUSBAND each do hereby mutually remise,
release, quitclaim and forever discharge the other and the estate of such other, for all time to come,
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and for all purposes whatsoever, of and from any and all rights, titles, Interests or c1alms In or
against the prop6rty Qncludlng Income and galn from property hereafter accruing, of the other} or
against the estate of such other, of whatever nature and wheresoever situate, which she or he now
has or at any time hereafter may have against such other, the estate of such other or any part
thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other,
or by way of dower or curtesy, or claims In the nature of dower or curtesy, or widows' or widowers'
rights, family exemption or similar allowance, or under the intestate laws, or the right to take against
the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other
rights of a surviving spouse to participate In a deceased spouse's estate, whether arising under the
laws of Pennsylvania, any other State, or any other Country, or any rights which either spouse may
have, or at any time hereafter have, for past, present or Mure support or malntenance, alimony,
alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital
relation or otherwise, except and only except, all rights and agreements and obligations of
whatsoever nature arising or which may arise under this Agreement or before the breach of any
thereof. It is the intention of HUSBAND and WIFE to give to each other by the execution of this
Agreement a full, complete and general release with respect to any and all property of any kind or
nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and
only except, all rights and agreements and obligations of whatsoever nature arising or which may
arise under this Agreement, or for the breach of any thereof, subject, however, to the
implementation and satisfaction of the condition precedent as set forth herein above.
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15. BREACH: In the event that either party breaches any provision of thls Agreement. he
or she shall be responsible for any and all costs Incurred to enforce the Agreement, Including, but
not limited to, court costs and counsel fees of the other part. In the event of breach, the other party
shall have the right, at his or her election, to sue for damages for such breach or to seek such other
and additional remedies as may be available to him or her.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year
first above written.
Witness:
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Thomas R. Wlaon, Husband
Q.O-J\'~ a, \.~'\_~
Carol ZWiison. WIfe
(Seal)
(Seal)
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IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 9....5698 CIVIL TERM
CIVIL ACTION. DIVORCE
TIlOl'..tAS R. WILSON,
V5.
CAROL J. WILSON,
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the ProthonoblrY:
Transmit the record, together with the following Information, to the court for entry of a divorce decree:
1, Ground for divorce: Irretrievable breakdown under Section (3301 (c)) (33911111(1)) of the Divorce Code,
(Strike oullnappllcable .ectlon).
2. Date and manner of service of the complaint: Certified Mall: Return Recelo!. sloned bv Defendan!. Carol
J, Wilson. and dated October 13. 1994,
3. (Complete either paragraph (a) or (b)),
(a) Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce
Code: by the Plaintiff March 31. 1997 ; by the Defendant March 31. 1997
(b) (1) Date of execution of the Plaintiff's affidavit required by Section 3301 (d) of lhe
Divorce Code:
(2) Date of service of the Plaintiffs affidavit upon the Defendant:
4. Related claims pending: None
5, Indicate date and manner of service of the notice of Intention to file praecipe to transmit record. and
attach a copy of said notice under sectlor. 3301 (d)(I)(I) of the Divorce Code,
Plaintiff
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c::\wpSl\cjl\divoru\_ilMJa.c:.cm rdo '4464-~1
THOMAS R. WILSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION. DIVORCE
. NO. 94. 5'"q8' CIVIL TERM
.
CAROL J. WILSON,
Defendant IN DIVORCE
NOIlCE
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 fall 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 property 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 Court House, Carlisle, Pennsylvania, 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS
FEES OR EXPENSES BEFORE A DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU
MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE 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, Fourth Floor
Cumberland County Court House
Carlisle, Pennsylvania 17013
(717) 240-6200
e:\wpJl'~jJ~""'*-'~. IUD' 4464-...0:
THOMAS R. WILSON,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVAN~
CIVIL ACTION. DIVORCE
Plaintiff
.
.
VI.
.
.
CAROL J. WILSON,
NO. M.
IN DIVORCE
CIVIL TERM
Defendant
COMf.L.AlNI
Thomas R. Wilson. Plaintiff, by his attorneys, FLOWER, MORGENTHAL, FLOWER &
LINDSAY, respectfully represents:
1. The Plaintiff Is Thomas R. Wilson, who currently resides at 20 East Street, Apt. 11, Mt.
Holly Springs, Cumberland County, Pennsylvania, for a period in excess of six months prior to the
filing of this Complaint.
2. The Defendant is Carol J. Wilson, whose current mailing address is P. O. Box 1064,
Bowie, Maryland, since September 10, 1994.
3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of
Pennsylvania for at least six months immediately prior to the filing of this Complaint.
4. The Plaintiff and Defendant were married on February 26, 19n, at Shermansdale,
Pennsylvania.
5. That there have been no prior actions of divorce or for annulment between the parties In
this or in any other jurisdiction.
6. The Plaintiff avers that he is entitled to a divorce on the ground that the marri8ge 18
irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the DivorcI
Code.
';\'*P'l\C)J\divOfCCl\lwibua.CGD. tuG 140&6+-~1
6. The Plaintiff avers that he is entitled to a divorce on the ground that the marriage Is
irretrievably broken and Plaintiff Is proceeding under Sections 3301 (e) and/or (d) of the Divorce
Code.
7. Plaintiff has been advised of the availability of marriage counseling and of the right to
request that the Court require the parties to participate in marriage counseling, and does not
request counseling.
8. Plaintiff requests the Court to enter a decree of divorce.
FLOWER, MORGENTHAL FLOWER & UNDSAY
Attorneys fer Plaintiff
By:
?31J
OIJ/ ' <;.~.
J. Und~. Esquire
10 # 44S93
11 East High Street
Carlisle, PA 17013
(717) 243-5513
Date: ~71 2-9;119,/
d:\di..urce\wioon,Jfr fiie # ~M-?4...Hl
THOMAS R. WILSON,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. DIVORCE
Plaintiff
va.
NO. 94. 5698 CIVIL TERM
CAROL J. WILSON,
Defendant
IN DIVORCE
~33m!dl.
OF TH~ DIVORCE CODE
1 . CHECK EITHER IAI OR IBI:
& I do not oppose the entry of the divorce decree.
(b) I oppose the entry of a divorce decree because: (CHECK III.IMI OR ....hl.
(i) The parties to this action have not lived separate and
apart for a period of at least two years; and
(ii) The marriage is not irretrievable broken.
2. CHECK EITHER IAI OR IBI.
(a)
I do not wish to make any claims for economic relief. 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 is granted
I wish to claim economic relief which maY include alimony, division of _ (1' ~II! ,
property, lawyer's fees or expenses or other important rights. ~$e'fK/ab~:::
~"'('!'~
VERIFICATJQN ( ~.
)
GY
I, the undersigned, hereby verify that the statements made herein are true and correct.
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. f 4904;
relating to unsworn falsification to authorities.
f1{~ 9 Lu~,
Date: I~ 73)9&
I I
~\dM:>rol\lVllson..{( file #'.w.,4.:94-01
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. DIVORCE
THOMAS R. WILSON,
VI.
NO. 94. 5698 CIVIL TERM
CAROL J. WILSON,
Defendant
IN DIVORCE
AND now, this
I v day of
tJ ?Nt, ~H \Jv ,1996, I, Carol J. Undsay, Esquire,
of the law firm of FLOWER, MORGENTHAL, FLOWER & LINDSAY Attorneys, hereby certify that
I served the within COUNTER AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE
this day by depositing same in the United States Mail, First Class, Postage Prepaid, in Carlisle,
Pennsylvania, addressed to:
Ms. Carol J. Wilson
P. O. Box 1064
Bowie, MD 20718
FLOWER, MORGENTHAL FLOWER & LINDSAY, P.C.
Attorneys for Plaintiff
By:
C
/ C rol J. Lindsay, squire
( .....to # 44693
. 11 East High Street
Carlisle, PA 17013
(717) 243.5513
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11 EAST HlCH STUET. CAiLI5LE, PENN5'tL VANIA 170tJ..3016
THOMAS R. WILSON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 94. 5698 CIVIL TERM
IN DIVORCE
Plaintiff
VI.
CAROL J. WILSON,
AND now, this II
day of January, 1995, I, CAROL J. LINDSAY, Esquire, of the law
firm of FLOWER, MORGENTHAL, FLOWER & LINDSAY, Atturneys, hereby certify that I served the
Defendant, Carol J. Wilson, on October 13, 1994 with the Divorce Complaint by Certified Mail,
Return Receipt Requested, Restricted Delivery, Addressee Only, addressed to:
Carol J. Wilson
P. O. Box 1064
Bowie, Maryland 20718
and proof thereof, the signed Return Receipt Card, is attached hereto.
FLOWER, MORGENTHAL, FLOWER & LINDSAY
Attorneys for Plaintiff
By
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I. 10 11 44693
11 East High Street
Carlisle, PA 17013
(717) 243-5513
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THOMAS R. WILSON, . IN THE COURT OF COMMON PLEAS OF
.
plaintitf . CUMBERLAND COUNTY, PENNSYLVANIA
.
va. . NO. 94 - 56!t8 CIVIL
.
.
.
CAROL J. WILSON,
Defendant . IN DIVORCE
.
ORDER OF COURT
AND NOW, this I I 't- day of Af'lfJ.A....{/-
~ ~
1997, the parties having appeared at the Master's Office and
entered into a supplemental agreement dated March 31, 1997,
resolving all outstanding economic issues between them, and the
,
parties having signed affidavits of consent and waivers of
notice of intention to request entry of divorce decree so that
the divorce can conclude under section 330l(c) of the Domestic
Relations COde, the appointment of the Master is vacated.
BY THE COURT,
P.J.
H
cc:
Carol J. Lindsay
Attorney for Plaintiff
Carol J. Wilson
Pro Se
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THOMAS R. WILSON,
Plaintiff
IN THB COURT OF COMMON PLEAS OF
CUMBBRLAND COUNTY, PBNNSYLVANIA
v.
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CIVIL ACTION - LAW
CAROL 3. WILSON,
Defendant
NO. 94-5698 CIVIL TBRM
ORDER OF COURT
AND NOW, this 21SK day of March, 1995, upon consideration of
Plaintiff's Petition to compel Defendant to sign an affidavit of
consent to divorce, the Court being without authority to issue such
an order, the Petition is DENIED.
BY THE COURT,
"
+ley Oler,
/--
.
Carol 3. Lindsay, Esq.
11 East High Street
Carlisle, PA 17013
Attorney for Plaintiff
Edward Harker, Esq.
1 West High Street
Carlisle, Pa 17013
Carol 3. Wilson
P.Q, Box 1064
Bowie, MD 20718
Defendant
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THOMAS R. WILSON,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. DIVORCE
NO. 94. !S698 CIVIL TERM
IN DIVORCE
VI.
CAROL J. WILSON,
DefendantjRe.pondent :
AND NOW this
. 1995, upon consideration
day of
of the w~hln Petition, a Rule Is Issued upon Respondent to show cause, If any, why she should
not be compelled to sign and deliver an Affidavit of Consent to Divorce.
RULE returnable
days from the date of service hereof.
By the Court,
J.
&;\-snlMJtl.~p lUg' t464--jlf..Ql
.
THOMAS R. WILSON,
PlllntJff/Pltltlonlf
.
.
IN THE COURT OF COMMON PLEAS OF
CUMIERLAND (:OUNTY, PENNSYLVANIA
CML ACTION. DIVORCE
v..
CAROL J. WILSON,
Defendant/R..porldent :
NO. 94. 5698 CIVIL TERM
IN DIVORCE
fEIlIlQN
NOW comes Thomas R. Wilson, Plaintiff above, by and through his attorneys, FLOWER,
MORGENTHAL. FLOWER & LINDSAY, and petitJons this Honorable Court as follows:
1. The parties hereto are husband and wife, having been Joined :n marriage on February
26. 1977.
2. The parties separated, and on September 16, 1994 executsd a Separation
Agreement. A copy of said Separation Agreement is attached hereto as Exhibit 'A'.
3. Paragraph 2 of the Separation Agreement required each party to sign an Affidavit of
Consent 90 days after the filing of a Complaint, should one or the other of them wish to go forward
with a divorce.
4. On or about October 5, 1994, Petitioner filed a Complaint and served it on
Respondent. A copy of the Complaint and the Certificate of Service are attached hereto as exhibit
NB",
5. Respondent retained counsel, Edward W. Harker, Esquire, of Carlisle, Pennsylvanla,
to whom Petitioner sent an Affidavit of Consent on February 3, 1995, requestJng that he Instruct
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THIS Agreement made this
/1/
, 1994 by
and between THOMAS R. WILSON, of 20 East Street, Mt. Hal ,Springs, Pennsylvania, hereinafter
referred to as HUSBAND, and CAROL J. WILSON, of P. O. Box 1064, Bowie, Maryland, hereinafter
referred to as WIFE,
WITNESSETH:
WHEREAS, the parties hereto are husband and wife, having been joined In marriage on
February 26, 1977, In Shermansdale, Pennsylvania; and
WHEREAS, the parties hereto are desirous of settling fully and finally their respective financial
and property rights and obligations as between each other, including, without limitation, the settling
of all matters between them relating to the ownership of real and personal property, and in general,
the settling of any and all claims and possible claims against the other or against their respective
estates.
NOW, THEREFORE, in consideration of these considerations, and the mutual promises and
undertakings hereinafter set forth, and for other good and valuable consideration, receipt and
sufficiency of which Is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE,
each intending to be legally bound, hereby covenant and agree as follows:
I'
1.
Advice of Counsel: The parties hereto acknowledge that each has been notified of
his or her right to consult with counsel of his or her choice, and have been provided a copy of this
agreement with which to consult with counsel. HUSBAND is represented by Carol J. Undsay,
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Esquire, and WIFE, has been advised that she may be represented by counsel of her choice. Each
party acknowledges and accepts that this agreement Is, In the circumstances, fair and equitable,
and that It Is being entered Into freely and voluntarily, after having received such advice and with
such knowledge as each has sought from counsel, and that execution of this agreement Is not the
result of any duress or undue influence, and that it Is not the result of any Improper or Illegal
agreement or agreements.
2. Divorce: Neither party wishes to file a Complaint for Divorce at the present time. If
either party, at some time In the Mure, files a Complaint In Divorce, the other party will cooperate
by signing an Affidavit of Consent to a divorce 90 days after the date of the filing of the Complaint.
3. Personal Property: The parties acknowledge that they have equitably and
satisfactorily divided aU of their personal property as set out on exhibit 'A' attached hereto and
incorporated herein. From the date of this Agreement, all such property shall be the sole and
individual property of the party to whom it Is assigned on Exhibit 'A'. However, said property will
remain at the residence of the HUSBAND until such time as WIFE requires those items assigned
to her on Exhibit 'A'. Further, in the event that one party files a Complaint In Divorce, WIFE will
remove her property from HUSBAND's residence within nine months of the date of the filing.
WIFE will retain the 1993 Dodge Spirit and make the payments of $280.00 per month
each and every month on or before the due date. When the car has been paid In full, HUSBAND
will execute any and all documents to transfer to WIFE all his right, title and Interest in the Dodge
2
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Spirit. WIFE will pay the balance of the loan for the purchase of said property, and shall Indemnify
and hold HUSBAND harmless against any loss as a result of salaloan.
HUSBAND shall retain the 1981 Dodge RaIder and the 1984 Chevette. WIFE shall
execute any and all documents necessary to transfer all her right, title and Interest in the said
vehicles to HUSBAND.
HUSBAND shall retain his gun collection and WIFE shall retain her collection of Avon
products. Each party will retain his or her own individually titled IRAs, 401 Ks, or other employment
benefits, and each waives any interest he or she may have In the employment benefit of the other.
The parties are purchasers of a time-share with Outdoor World, Inc. On the condition
that WIFE pays one-half of the outstanding balance to purchase the time-share, HUSBAND will
provide the other half of the balance due, excluding membership fees. WIFE shall make her one-
half payment within six months of the date of this Agreement. In the event WIFE cannot pay for
one-half of the balance due on the time-share within six months of the date of this Agreement, the
parties shall sell the time-share and equally split any deficiencies owed for the purchase of the time-
share after all of the proceeds of sale are applied to the debt.
4. Real propertyi,J f The parties are owners of a townhouse at Bowie, Maryland.
-rrw.P/fJ'I!.5~ 1t~
Presently, the time 31'lare Is leased, and a monthly rental amount Is paid by tenants. Sald monthly
amount Is presently $200.00 less than that amount required to service the loan on the property.
WIFE will make the mortgage payments in a timely manner using the rent from the tenants and
funds from her own Income. WIFE will make said payments until such time as the townhouse can
3
II
;,\""JI'.c:J.l\,nbc..ln.. tu. 446409+41
be sold. The townhouse may be listed for sale at the request of ether party, and the parties will
cooperate with one another In a listing agreement. The parties will equally divide the costs of sale,
the proceeds. and. If a deflcJency remains, they will equally split the deficiency balance.
5. SPOUII' Support: The parties waive any claim that they may have one against the
other for spousal support or alimony pendente lite. The parties acknowledge that each has
sufficient assets with which to maintain themselves during separation. In the event that the parties
shall divorce, they acknowledge that each has sufficient assets with which to maintain themselves
after divorce, and they waive any claim they might have one against the other for alimony.
6. Marital Debt The parties have, In their own names, certain credit card accounts
which may Include some marital debt. Each party will be responsible for the debt on the credit card
accounts In his or her name. Each party will Incur no debt for which the other may be liable, and
will Irldemnify and hold the other harmless for any debt so incurred.
HUSBAND shall pay the automobile insurance on the parties' vehicles until a decree
of divorce, if any, Is entered. After said date, he will maintain the automobile Insurance on the 1987
Dodge Raider and the 1984 Chevette. WIFE shall pay for the automobile Insurance on the 1993
Spirit commencing 6 months from the date of this Agreement. The parties shall Indemnify and hold
the other harmless against any loss on account of their failure to abide by the terms of this
Agreement
7. Federal Income Tax: The parties will file a joint federal Income tax return for 1994
and divide equally any refund they shall receive.
4
('\..,'I\cll\....."* nil ~~I
B. Modification: No modification, rescission, or amendment of this agreement shall be
effective unless In writing signed by each of the parties hereto.
9. Applicable Law: All acts contemplated by this agreement shall be construed and
enforced under the laws of the Commonwealth of Pennsylvania.
10. Agreement Binding on Parties and Heirs: This agreement, except as otherwise
expressly provided herein, shall bind the parties hereto, and their respective heirs, executors,
administrators, legal representatives, assigns and successors in any Interest of the parties.
11. Agreement Not to be Merged: In the event that the parties divorce, this agreement
shall be Incorporated into the final decree of divorce of the parties hereto for purposes of
enforcement only, but otherwise shall not be merged into said decree. The parties shall have the
right to enforce this agreement under the Divorce Code of 1980, as amended, and in addition, shall
retain any remedies in law or In equity under this agreement as an Independent contract. Such
remedies in law or equity are specifically not waived or released.
12. Reconciliation: In the event the parties shall end their separation and again live one
with the other, the terms of this Agreement shall remain in full force and effect unless altered by the
written agreement of the parties.
13. Documents: The parties hereto agree that they will execute and deliver one to the
other any documents necessary to give effect to the terms of this Agreement.
14. Full and FInal Settlement: WIFE and HUSBAND each do hereby mutually remise,
release, quitclaim and forever discharge the other and the estate of such other, for all time to come,
s
'",I.-pJl\cil\....."- r~ 4464-~1
and for all purposes whatsoever, of and from any and all rights, titles. Interests or clalms In (lr
against the property Oncludlng Income and gain from property hereaftar accruing, of the other) or
agalnst the estate of such other, of whatever nature and wheresoever situate, which she or he now
has or at any time hereafter may have agalnst such other, the estate of such other or any part
thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other,
or by way of dower or curtesy. or claims In the nature of dower or curtesy, or widows' or widowers'
rights, family exemption or similar allowance, or under the Intestate laws, or the right to take against
the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or ail othsr
rights of a surviving spouse to participate In a deceased spouse's estate, whether arising under the
laws of Pennsylvania, any other State, or any other Country, or any rights which either spouse may
have, or at any time hereafter have, for past, present or Mure support or maintenance, alimony,
alimony pendente /lte. counsel fees, costs or expenses, whether arising as a result of the marital
relation or otherwise, except and only except, all rights and agreemsnts and obligations of
whatsoever nature arising or which may arise under this Agreement or before the breach of any
thereof. It is the intention of HUSBAND and WIFE to give to each other by the execution of this
Agreement a full, complete and general release with respect to any and aU property of any kind or
nature, real, personal or mixed. which the other now owns or may hereafter acquire, except and
only except, all rights and agreements and obligations of whatsoever nature arising or which may
arise under this Agreement, or for the breach of any thereof, lubJect, however, to the
Implementation and satisfaction of the condition precedent as set forth herein above.
6
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15. BREACH: In the event that either party breaches any provision of this Agreement, he
or she shall be responsible for any and all costs Incurred to enforce the Agreement, Including, but
not limited to, court costs and counsel fees of the other part. In the event of breach, the other party
shall have the right, at his or her election, to sue for damages for such breach or to seek such other
and additional remedies as may be available to him or her.
IN WITNESS WHEREOF, the partJes hereto have set their hands and seals the day and year
first above written.
Witness:
.u:~ /T ~.$;J
Thomas R. WlIOfI, Huaband
Q(\,'\,~ <1. \.J..)~
Carel JJnson, WIfe
(Seal)
(Seal)
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THOMAS R. WILSON,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CML ACTION. DIVORCE
Plalntm
v..
NO. M.
CML TERM
CAROL J. WILSON,
Defendant
IN DIVORCE
COMaAlNI
Thomas R. Wilson, Plaintiff, by his attorneys, FLOWER, MORGENTHAL, FLOWER &
UNDSAY, respectfully represents:
1. The Plaintiff Is Thomas R. Wilson, who currently resides at 20 East Street, Apt. 11. Ml
Holly Springs, Cumberland County, Pennsylvania. for a period In excess of six months prior to the
filing of this Complaint.
2. The Defendant is Carol J. Wilson, whose current mailing address is P. O. Box 1064,
Bowie, Maryland, since September 10, 1994.
3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of
Pennsylvania for at least six months Immediately prior to the filing of this ComplaJnt
4. The Plaintiff and Defendant were married on February 26. 19n. at ShermansdaJe,
Pennsylvania.
5. That there have been no prior actions of divorce or for annulment between the par1les In
this or in any other jurisdiction.
6. The Plaintiff avers that he is entitled to a divorce on the ground that the marnage Is
irretrievably broken and PlaJntiff Is proceeding under Sections 3301 (e) and/or (d) of the DIvorce
Code.
'I
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FILE r.9Pi
THOMAS R. WILSON,
IN THE COURT OF COMMON PlEAS OF
CUMBERlAND COUNTY, PENNSYLVANIA
CIVIl AcnON . DIVORCE
Plaintiff
va.
.
,
: NO, M. IU8 CML TERM
CAROL J. WILSON,
,
.
'--
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:.:
Defendant
IN DIVORCE
'"
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AND now, this
J.t--
/ / day of January, 1995, I, CAROL J. UNDSAY, esquire, of:he law
firm of FLOWER, MORGENTHAL, FLOWER & UNDSAY, Attorneys, hereby certify that I served the
Defendant, Carol J. Wilson, on October 13. 1994 with the Divorce Complaint by Certlfiod Mall,
Retum Receipt Requested, Restricted Delivery, Addressee Only, addressed to:
Carol J. Wilson
P. O. Box 1064
Bowie, Maryland 20718
and proof thereof, the signed Return Receipt Card, is attached hereto.
FLOWER, MORGENTHAL, FLOWER a UNDSAY
Attorneys for Plaintiff
By
Carol J. Undsay, esquire
10/144693
11 East High Street
Carlisle, PA' 17013
(717) 243-5513
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THOMAS R. WILSON,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYlVAN~
CIVIL ACTION. OWORCE
I
II
va.
NO. 84. 5698 ''':IVil TERM
CArlOl.. J. WILSON,
Defendant/Respondent :
IN DIVORCE
AND now, this
CEBILEICAI~
Y.? day of 'llu d \ .1995, I, Carol J. Undsay,
Esquire,of the law firm of flOWER, MORGENTHAL, FLOWER & liNDSAY Attomeys, hereby certify
that I served the within Petition this day by depositing same in the Ul"it~d States Mall. First Class,
Postage Prepaid, in Carlisle, Pennsyi'.ania, addressed to:
Carol J. Wilson
P. O. Box 1064
Bowie, MD 20718
Edward W. Harker, Esquire
One West High Street
Carlisle, PA 17013
FLOWER, MORGENTHAi. FLOWER. UNDSAY
Attorneya for Plallrtlff/Pflt"'Oner
J! ~(' {i.
By: (0 ' .... fit_
. -' Carol J. Undsay, Esquire
~ 10 11 44693
11 East High Street
Carlisle, PA 17013
(717) 243-5513
J
VS.
I IN THE COUlT 01 COMMON PLEAS or
I CtlMJ3ERLAHD COUNTY, PENNSYLVANIA
I CIVIL ACTION - LAW
THOMAS R. WILSON,
Plaintiff
.
.
NO. 94 - 5698
CAROL J. WILSON,
Defendant
IN DIVORCE
CONfERENCE
WITH COUNSEL AND PARTIES
TO: Carol J. Lindsay
Thomas R. Wilson
, Counsel for Plaintiff
, Plaintiff
---------------
, Counsel for Defendant
, Defendant
Carol J. Wilson
A conference has been scheduled at the Office of
the Divorce Master, 9 North Hanover street, Carlisle,
Pennsylvania, on the
31st
day of
March, 1997, at 10:00
a.m., with counsel and the parties to discuss the outstanding
economic issues to determine if there is a basis of settlement
of claims.
If issues remain after the conference a hearing
will be scheduled at another date.
Very truly yours,
Date of Notice: 2/6/97
E. Robert Elicker, II
Divorce Master
THOi\l-\S R. WILSON,
Plalntlll'
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNT\', PENNSYLVA.."'l!A
n.
NO. 94-!O98 CIVIL TERM
CIVIL ACTION. DIVORCE
CAROL J. WIL..'10N.
Dellendant
IN DIVORCE
MOTION FOR APPOINTMENT Of: MASTER
THOMAS R. WilSON. Plaintiff above. mOV9S the court to appoint a master with respect to the following claims:
(0) Divorce
() Annulment
() , Alimony
() Alimony Psndenle Lite
( )
( )
( )
( )
Distribution of Property
Support
Couneef Feee
Coets and ElCpenSB8
and in support of the motion stales:
Date:
(1)
(2)
(3)
(4)
Discovery Is complete as 10 the clalm(s) for which the aJlllOlntment of a master Ia requeeted,
The Defendant hes not appeared In the action personally/by his attorney, Carol J. Undsay, Esquire
The Slalutory grour<l(s) for divorce Is 3301 (d) of the Divorce Code,
Delele the Inapplicable paragraph(s),
(a) The acllon Is not contested,
(b) An agreement has been reached wtth respect to the follOWing claims: nla
(c) The acllon Is contestee with respect to the following claims:
nla
The action does not Involve complex Issues of law or fact.
The hearing Is eX[JllCted to take one.half day
Addltlonallnformalion, If any, relevant to the moll:ln:
The pert/es entered a Mar//al Sell/emen/ Agreaman/ on September 16,
1994. Plain/Iff flied a 3301 (d) Affidavit and Defendant flied a Coun/e,.
Affidavit See attached copy Pla/ntlff believes, given /tle Coun/e,-
Affld~vlt. that a Mester's hearing is required,
(5)
(6)
(7)
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IN /1/;'
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1'/1/'...,1 l.,' - --.
Allom~.y for Plaintiff
ORDER APPOINTING MASTER
AND NOW. this :).....l- day of I ^ l \, u, '\ . 1992-, I:'. 1<.( ~fe0..
Esquire, Is appointed maste' wtth rsspect to the following claims: NONE
By the CO?/ Q L.
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. DIVORCE
NO. 94. 589a CIVIL TERM
IN DIVORCE
THOMAS R. WILSON,
Plaintiff
VI.
CAROL J. WILSON,
,
O.N.S.ENI
Thomas R. WIlson, Plaintiff, being duly sworn according to law, deposes and says:
1. That a Complaint In Divorce under Section 3301 {c} of the Divorce Code was filed on
October 5, 1994.
2. That my marriage with Carol J. Wilson, Defendant, is irretrievably broken.
3. That I consent to the entry of a Decree in Divorce on the grounds that the marriage is
irretrievably broken.
4. That I understand that I may lose rights concerning alimony, division of property,
counseling 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 corroct to the best of my
knowledge, information and belief. I understand that false statements herein are made subject to
the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authoriti&S.
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Thomas R. WIlson, Plaintiff
Date: ~(,11-r
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-5698 CIVIL TERM
CIVIL ACTION. DIVORCE
THOMAS R. WILSON,
VI.
CAROl.. J. WILSON,
Defendant
IN DIVORCE
1, A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
October 5. 1994,
2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing the Complaint.
3, I consent to the entry of a Final Decree of Divorce without service of Notice of
Intention to Request Entry of the Decree.
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1. I consent to the entry of a Final Decree of Divorce without Notice.
2. 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 is granted.
3, I understand that I will not be divorced until a Divorce Decree is entered by the Court
and that a copy of the Decree will be sent to me immediately after it is filed with the PrOthonotaly.
I verify that the statement made in this Affidavit are true and correct. I understand that hIlse
statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unswom
falsification to authorities,
Date:
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Carol J, Wilson
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