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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND cOUNTY
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.JOSEI'll F. CIlVAI.I:SKI
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DECREE IN
DIVORCE
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AND NOW,
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.It1Hl'ph F. ('OVilICHki
plainliff,
defendant,
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ore divorced frolll Ihu blll1d~ of Illotrlllluny
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LAW OFFICE
EDW\RD J. WEINTRAUB
2650 NORTH THIRD SmEET
HARRISBURG. PENNSYLVANIA 17110
(7171238,2200 FAX 17171 238,9280
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~RAFT #3 - 9/2B/95
HARITAL SE'r'rLEMENT AGREEHENT
THIS AGREEMENT, made this
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day of Jl{ I( Iffh
hereinafter referred to
1995, by and between JOSEPH F. COVALESKI,
ae "Husband", and JEAN M, COVALESKI, hereinafter referred to as
IIWife. II
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on
December 31, 1990; and
WHEREAS, certain differences arose between the parties as
a result of which they separated on May 10, 1995, and now live
separate and apart from one another, and are desirous of settling
fully and finally their respective financial and property rights
and obligations as between each other, including, without
limitation by specification: the settling of all matters between
them relating to the past, present and future support and/or
maintenance of Wife by Husband or of Husband by Wife; and in
general the settling of any and all claims and possible claims by
one against the other or against their respect i ve estates for
equitable distribution of all marital property; and a resolution of
all mutual responsibilities and rights growing out of the marriage
relationship; and
WHEREAS, the partieB hereto, after- being pr-operly adviscd
by their respective counsel, Husband, by his attorney, Edward J.
Weintraub, Esquire, and Wife by her attorney, carol J. Li ndsay,
come to the following agreement.
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and all claims or demands made against him by reason of debts or
obligations incurred by her.
4, HUSBAND'S DEBTS:
Other than the debts indicated in Paragraph 5 below,
Husband represents and warrants to Wife that since May 10, 1995,
he has not, and in the future he will not, contract or incur any
debt or liability for which Wife or her estate might be responsible
and shall indemnify and save Wife harmless from any and all claims
or demands made against her by reason of debts or obligations
incurred by him.
5. OUTSTANDING JOINT DEBTS:
Husband and Wife acknowledge and agree that they
have no outstanding debts and obligations of the Husband and Wife
incurred prior to the signing of this Agreement, except as follows:
RESPONSIBLE
DESCRIPTION AMOUNT PARTY
A. Bank of America Visa $4,300 Husband
and PSECU Mastercard
B. PSECU Car Loan 5,BOO Husband
Chevy Blazer
C. Dr. Nester 500 Husband Ii Wife
The parties agree that Husband shall be solely
responsible for debts A, B, and C.
Each party agrees to pay the outstanding joint debts as
set forth herein and further agrees to indemnify and save harmless
the other from any and all claims and demands made against either
reason of such debts or
obligations,
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(Initials)
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In the event that either party contracted or incurred any
debts, other than thoae apecifically identified herein, since May
10, 1995, the party who incurred said debt shall be responsible for
the payment thereof regurdlosH of tho name in which the account may
have been charged.
6. !1!l.IUAL RELEASE:
Subject to the provisions of this Agreement, each
party waives his or her' dght to alimony and any further
distribution of property inaamuch as the parties hereto agree that
thia Agreement provides for" an equitable distribution of their
marital property in accordance with the Divorce Code of I9BO.
Subject to the provisions of thia Agreement, each party has
released and discharged, and by thia Agreement doos for himself or
herself, and his or her heir"s, legal representatives, executors,
administrators and assigns, release and discharge the other of and
from all causes of action, claims, rights or demands whatsoever in
law or equity, which either" of the parties ever had or now has
against the other, except any or all cause or cauees of action for
divorce and except in any 01 all causes of action for breach of any
provisions of this Agreement. Each pal'ty also waives his or- her
right to request mad ta 1 counseliny pursuant to 23 Pa. C. S. A.
Section 3302,
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7. EQUITABLE UISTRIaUTION:
A, Husband shall sign the Spousal Waiver attached
hereto as Exhibit A, releasing any interest he may have acquired by
marriage in Wife's separately owned property at 1259 Peggy Drive,
HUl1UT1elstown, Dauphin County, Pennsylvania 17036. Wife shall sign
the Spousal Waiver attached hereto as Exhibit B releasing any
interest she may have acquired by marriage in Husband's separately
owned property at 322 Beverly Road, Camp Hill, Cumberland County,
Pennsylvania. Each party shall continue to be solely responsible
for all mortgages, taxes and other costs associated with their
separately owned real estate.
B. CONTENTS OF THE FORMER MARITAL RESIDENCE:
As of the date of the execution of this
Agreement, Wife shall set over, transfer and assign to Husband all
of her right, title, claim and interest in and to the furniture,
furnishings, fixtures, goods, appliances, equipment and personal
items within the former marital residence at 322 Beverly Road, Camp
Hill, Cumberland County, Pennsylvania 17011, except for these items
which Husband will deliver to Wife:
NONE
Wife shall remove these items from 322 Beverly
Road, Camp Hill, Cumberland County, Pennsylvania 17011, on or
b.~.O r;t(~~y 10, 1997.
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I. MISCELLANEOUS PROPERTY;
All property not specifically addressed herein
shall hereafter be owned by the party to whom the property is
titled, and if untitled, the party in possession, This Agreement
shall constitute a sufficient bill of sale to evidence the transfer
of any and all rights in such property from each to the other.
J. TAX LIABILITY:
The parties believe and agree that the division
of property heretofore made by this Agreement is a non-taxable
division of property between co-owners rather than a taxable sale
or exchange of such property. Each party promises not to take any
position with respect to the adjusted basis of the property
assigned to him or her with respect to any other issue which is
inconsistent with the position set forth in the preceding sentence
on his or her Federal or State income tax returns.
K. Husband shall pay to Wife upon execution of this
Agreement the sum of Seventeen Thousand Five Hundred ($17,500.00)
Dollars.
B. LIFE INSURANCE:
Each party shall continue to own any life insurance
policies currently in effect, without restriction as to the
designation of beneficiaries.
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9. ALIMONY:
Husband shall pay directly to Wife as alimony the
sum of Five Hundred ($500.00) Dollars per month (in $250
installments due approximately the 1st and 15th of the month, from
each pay check) until December 31, 1997.
Upon ten ( 10) days
default, Wife may seek wage attachment through the Office of
Domestic Relations.
Alimony shall terminate upon Wife's death,
remarriage or cohabitation with a man, whichever shall occur first.
Husband shall maintain health insurance coverage for Wife with
benefits equivalent to those now provided by his employer. Said
benefits shall continue until May 10, 1997.
11. ALIMONY PENDENTE LITE, COUNSEL FEES AND EXPENSES:
Husband and Wife acknowledge and agree that the
. provisions of this Agreement providing for the equitable
distribution of marital property of the parties are fair, adequate
and satisfactory to them. Both parties agree to accept the
provisions set forth in this Agreement in lieu of and in full and
final settlement and satisfaction of all claims and demands that
either may now or hereafter have against the other for alimony
pendente lite, counsel fees or expenses or any other provision for
their support and maintenance before, during and after the
commencement of any proceedings for divorce or annulment between
the parties,
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estate.
Each will, at the request of the other, execute,
acknowledge and deliver any and all instruments which may be
necessary or advisable to carry into effect this mutual waiver and
relinquishment of all such interests, rights and claims and both
parties will revoke prior wills or testamentary documents.
14. AGREEMENT NOT PREDICATED ON DIVORCE:
It is specifically understood and agreed by and
between the parties hereto and each of the said parties does hereby
warrant and represent to the other, that the execution and delivery
of this Agreement is not predicated upon nor made subject to any
agreement for institution, prosecution, defense, or for the non-
prosecution or non-defense of any action for divorce; provided,
however, that nothing contained in this Agreement shall prevent or
preclude either of the partie~ hereto from commencing, instituting
or prosecuting any action or actions for divorce, either absolute
or otherwise, upon just, legal and proper grounds; nor to prevent
either party from defending any such action which has been, mayor
shall be instituted by the other party, or from making any just or
proper defense thereto, It is warranted, covenanted and represented
by Husband and Wife, each to the other, that this Agreement is
lawful
and
enforceable
and
this
warranty,
covenant
and
representation is made for the specific purpose of inducing Husband
and Wife to execute this Agreement, Husband and Wife each
knowingly and
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understandingly hereby waives any and all possible
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into the Divorce Decree, shall not be merged in such Decree, and
shall not be modified, but shall in all reupects survive the same
and be further binding and conclusive upon the parties. This
Agreement shall be incorporated for the purposes of enforcement
only.
16. BREACH AND ENfORCEMENT:
If either pal"ty breaches any provision of this
Agreement, the other party shall have the right at his or her
election, to sue for damages for such breach, or seek such other
remedies or relief as may be available to him or her, and the party
breaching this Agreement shall be responsible for payment of legal
fees and costs incurred by the other in enforcing his or her rights
under this Agreement,
A. It is expressly understood and agreed by and
between the parties hereto that this Agreement may be specifically
enforced by either Husband or Wit e in Egu i ty, and the parties
hereto agree that if an action to enforce this Agreement is brought
in Equity by either party, the other party will make no objection
on the alleged ground of lack of jurisdictiun uf said Court on the
ground that there is an adequate remedy at law, The parties do not
intend or pUl"fJO!I. hel"euy tu impnl[HHly cunflH' jul'isdiction on a
Court in Equlty by this A(Jn~ement, but they agree as provided
herein for the forum of equity in mutual recognition of the present
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general jurisdiction of
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Courts in Equity over agreements such as this one.
B. Notwithstanding anything to the contrary herein,
Husband and Wife may also proceed with an action at law for redress
of his or her rights under the terms of this Agreement, and in such
event it is specifically understood and agreed that for and in
specific consideration of the other provisions and covenants of
this Agreement, each shall waive any right to a jury trial so as to
expedite the hearing and disposition of such case and so as to
avoid delay.
C. Each party further hereby agrees to pay and to
save and hold harmless the other party from any and all attorney's
fees and costs of litigation that either may sustain, or incur or
become liable for, in any way whatsoever, or shall pay upon, or in
terms or provisions of this Agreement by reason of any of the terms
or consequence of any default or breach by the other of any of the
terms or provisions of this Agreement by reason of which either
party shall be obliged to retain or engage counsel to initiate or
maintain or defend proceedings against the other at law or equity
or both in any way whatsoever, provided that the party who seeks to
recover such attorney's fees, and costs of litigation must first be
successful in whole or in part, before there would be any liability
for attorney's fees and costs of litigation.
It is the specific
agreement and intent of the parties that a breaching or wrongdoing
. party
11 bear the burden and obligation of any and all costs and
(Initials)
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14
expenses and counsel fees incurred by himself or herself as well as
the other party in endeavoring to protect and enforce his or her
rights under this Agreement.
17. ADDITIONAL INSTRUMENT:
Each of the parties shall from time to time, at the
request of the other, execute, acknowledge and deliver to the other
party any and all further instruments that may be reasonably
required to give full force and effect to the provisions of this
Agreement.
lB. VOLUNTARY EXECUTION:
The provisions of this Agreement and their legal
effect have been fully explained to the parties by their respective
counsel, and each party acknowledges that the Agreement is fair Bnd
,equitable, that it is being entered into voluntarily, with full
knowledge of the Bssets of both parties, and that it is not the
result of any duress or undue influence. The parties acknowledge
that they have been furnished with all information relating to the
financial affairs of the other which has been requested by each of
them or by their respective counsel.
19, ENTIRE AGREEMENT:
This Agreement contains the entire understanding of
the parties and there are no representations, warranties, covenants
or undertakings other than those expressly set forth herein.
Husb~l){)d wife acknowledge and agree that
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the provisions of this
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Agreement with respect to the distribution end division of merital
and separate property ere fair, equitable and satisfactory to them
based on the length of their marriage and other relevant factors
which have been taken into consideration by the parties.
Both
parties hereby accept the provisions of this Agreement with respect
to the division of property in lieu of and in full and final
settlement and satisfaction of all claims and demands that they may
now have or hereafter have against the other for equitable
distribution of their property by any court of competent
jurisdiction pursuant to 23 Pa.C.S.A. Section 3501 ~ J!!liL. or any
other laws. Husband and Wife each voluntarily and intelligently
'waive and relinquish any right to seek a court ordered
determination and distribut ion of marl ta 1 propert y, but nothing
herein contained shall constitute a waiver by either party of any
rights to seek the relief of any court for the purpose of enforcing
the provisions of this Agreement.
20. DISCLOSURE:
Husband and Wife each represent and warrant to the
other that he or she has made a full and complete disclosure to the
other of all assets of any nature whatsoever in which such party
has an interest, the sources and anmunt of the income of such party
or every type whatsoever and of all other facts relating to the
subject matter of this Agreement.
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21. MODIFICA'rION AND WAIVER:
A modification or waiver of any of the proviaiona of
thia Agreement ahall be effective only if made in writing and
executed with the same formality as this Agreewent. The failure of
either party to incict upon ctrict performance of any of the
proviaions of this Agreement shall not be construed as a waiver of
any subsequent default of the same or similar nature.
22. PRIOR AGREEMENT:
It is understood and agreed that any and all
property settlement agreements which mayor have been executed
prior to the date and time of this Agreement are null and void and
of no effect.
23. DESCRIPTIVE HEADINGS:
The descriptive headings uaed herein are for
convenience only. They shall have no effect whataoever in
determining the rights or obligations of the partiea.
24. INDEPENDENT SEPARATE COVENANTS:
It ia specifically understood and agreed by and
between the partiea hereto that each paragraph hereof ahall be
deemed to be a separate and independent covenant and agreement.
25. APPLICABLE LAW:
This Agreement shall be construed under the laws of
the conunonwealth of Pennsylvania.
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JOSEPH F. COVALESKI,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v,
No, 96,2909 CIVIL TERM
JEAN M. COVALESKI,
Delendant
CIVIL ACTION, LAW
IN DIVORCE
PRAECIPE TO TRANSMIT RECORQ
To the Prothonotary:
Transmit the record, together with the lollowing inlormatlon, 10 the court lor
entry 01 a divorce decree:
1, Ground lor divorce: irretrievable breakdown under Section 3301 (c) 01 the
Divorce Code,
2, Date and manner 01 service 01 the complaint: Certilied Mail to Defendant
received June 12, 1996,
3, Date 01 execution 01 the allidavit 01 consent required by Section 3301 (c)
01 the Divorce Code:
by plaintlll: January 19, 199B;
by defendant: February 24, 199B,
4, Date plaintill's Waiver 01 Notice in Section 3301 (c) Divorce was liled
with the Prothonotery: January 27, 199B,
Date delendant's Waiver 01 Notice in Section 3301 (cl Divorce was liled
with the Prothonotary: February 27, 199B,
6, Related claims pending: Nono,
6, Date end menner 01 service 01 the notice of intention to lile praecipe to
transmit record, 1I copy 01 which is lI\1l1ched, il the decree is 10 be entered under
Section 3301 (d)( 1)(1) of tho Divorce Code, N/A__,____ ,_______________
7, Plaintill and Delendllnt hove signed 0 Separation and Property Solllemont
Agreement dllted July 12, 1996,
WHEHEFORE, the COUlt is requosted 10 ontnr 1I Final Docree in Divorce in
compliance wilh Section 3301 (c) of tho Divnrce Code lInd Po, R,C,P. 1920,42(1I)( 1}
lInd to incorporate tho terl11S ollho Seporallon lInd Propnrly Setllol11onl Agreement in
lICCOrdllnce with Secllon 301 (a)( 111lnd (411lnd 401 (bl 01 tho [)Ivorcfl Code,
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I.dword ,). Weintrauh, [squire
A\llHnllY for I'lulJlllff
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LAW OFFICE
EDW\RD J. WEINTRAUB
2650 NORni THIRD S11IEET
HARRISBURG, PENNSVLVANIA 17110
17171238,2200 FAll 17171 238,9280
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JOSEPII F. COVALESKI,
Plaintiff
IN TilE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO.
CIVIL ACTION - LAW
JEAN M. COVALESKI,
Defendant
IN DIVORCE
COMPLAINT UNDER SECTION 3301
OF THE DIVORCE CODE
1. Plaintiff is Joseph F. Covaleski who currently
resides at 32 Argali Road, Mechanicsburg, Cumberland County,
Pennsylvania 17055.
2. Defendant is Jean M. Covalseki, who currently resides
at 322 Beverly Road, Camp lIill, Cumberland County, Pennsylvania
17055.
3. Plaintiff has been a bona fide resident of the
Conunonwealth of Pennsylvania for a period of more than six (6)
months inunediately preceding the filing of this Complaint,
4. The Parties were married on December 31, 1990, in
Mechanicsburg, Pennsylvania.
5. Neither Plaintiff nor Defendant is in the military or
naval service of the United States or its a llies within the
provisions of the Soldiers' and Sailors' civil Relief Act of the
Congross of 1940 and its amendments.
6. There has been no prior action for divorce or
annulment instituted by either of the parties in this or any other
jurisdiction.
7. The Plaintiff has been advised that counseling is
available and that Plaintiff may have the right to request that the
Court require the parties to participate in counseling.
COUNT I.
REQUEST FOR A NO-FAULT DIVORCE UNDER
SECTION 3301 ( c l OF THE DIVORCE CODE
B. The prior paragraphs of this Complaint are
incorporated herein by reference thereto.
9. The marriage of the parties is irretrievably broken.
10. After ninety (90) days have elapsed from the date of
the filing of this Complaint, Plaintiff intends to file an
affidavit consenting to a divorce.
Plaintiff believes that
Defendant may also file such an affidavit.
WHEREFORE, if both Parties file affidavits consenting to
a divorce after ninety (90) days have elapsed from the date of the
filing of this Complaint, Plaintiff respectfully requcsts the Court
to enter a Decree of Divorce pursuant to Section 3301(c) of the
Divorce Code.
COUNT I I .
REQUEST FOR A NO-FAULT DIVORCE UNDER
SECTION 3301(dl OF THE DIVORCE CODE
11. The prior paragraphs of this Complaint are
incorporated herein by reference thereto,
12. The marriage of thc Parties is irretrievably broken.
13. The parties are living separate and apart and at the
appropriate time, Plaintiff will submit an affidavit alleging that
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JOSEPH F, COVALESKI.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. 95-2909 CIVIL TERM
v.
CIVIL ACTION ,,- LAW
JEAN M, COVALESKI.
Defendant
IN DIVORCE
AFFIDAVIT OF CONSflli
1, A Complaint in Divorce under Section 3301 lcl of the Divorce Code
was filed on May 30, 1995,
2, The marriage of Plaintiff and Defendant is irretrievably broken and
ninety (901 days havo elapsed from the dete of the filing of the Complaint.
3, I consent to the entry of 0 finol decree in divorce ofter service of
notice of intention to request entry of the decree,
I verily that the statements made in this affidavit are true and correct.
I understand that folse statemunts heroin !lIO mode subject to the penalties of 1 B
Pa,C.S, Section 4904 relating to unsworn falsilicotlonlo authorities.
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JrlSoph F, Covoleski
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JOSEPH F, COVALESKI,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO, 96-2909 CIVIL TERM
v.
CIVIL ACTION.. LAW
JEAN M, COVALESKI,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1, A Complaint in Divorce under Section 3301 (c) of the Divorce Code
was filed on May 30, 1995.
2, The marriage of Plaintiff and Defendant is irretrievably broken and
ninety (90) days have elapsed from the date of the filing of the Complaint.
3. I consent to the entry of a final decree in divorce alter service of
notice of intention to request entry of the decree,
I verify that the statements made in this affidavit are true and correct.
I understand that false statements herein are made subject 10 the penalties of 18
Pa.C,S. Section 4904 relating to unsworn falsification to authorities,
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Jllsoph ~. Covaleski
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