HomeMy WebLinkAbout95-02979
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.JO.L O. ..OIlRI.T
AT1'OlINIY AT LAW
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DECREE IN :
DIVORCE J:. 2-;O~PA'
AND NOWtJ~..~. 19 4'. ~. It i. ordered and :
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF * PENNSYLVANIA
Virgil H. Chambers
1'\ n.
95-2979 CIVIL II)
Vl'r~lI~
M~ry L. Chambers
d.cr.ed that.... Y.i.r:9P, .Il,. ~.I1~'!1P.~r:s,....................... plaintiff,
and. ...... .. ... . .l'!~H. .It.. ~.I1~'!1P.~r:!l... . .. . . .. , . . ... .. ....... defendant,
or. divorced from the bonds of matrimony.
ThwlCVUrtlfwt.Im<~"..iC)fion xlIk ""e lh:Itlowlnv dcIln1 I lWhhltt< trcMI
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The Agreement between the parties dated October 31, 1995, a
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case, is hereby incorporated into but not merged with the .
.Divor-ce. Dllcree........,.......,..,... ...............................
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AGREEMENT
THIS AGREEMENT made this:1 / JT day of 0 r M~
, 1995, by
and between VIRGIL H. CHAMBERS, hereinafter referred to as
"HUSBAND" and MARY L. CHAMBERS, hereinafter referred to as "WIFE".
WITNESSETH:
WHEREAS, the parties hereto are husband and wife; and
WHEREAS, certain differences have arisen between them, as a
consequence of which the said parties are living separate and apart
and therefore desire to enter into an agreement for the final
settlement of their property and affairs; and
WHEREAS, the parties, being fully advised as to their
respective rights, duties and obligations growing out of their
marital status, have come to an agreement as to each and all of
their said matters of property and relations; and
WHEREAS, HUSBAND has entered suit for abso1ut~.divorce from
WIFE.
NOW, THEREFORE, in consideration of the covenants and promises
hereinafter mutually to be kept and performed by each party, as
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well as for other good and valuable consideration, it is agreed as
follows:
1. SEPARATION: It shall be lawful for HUSBAND and WIFE to
live separate and apart from each other and to reside from time to
time at such place or places as they shall respectively deem fit.
2. INTERFERENCE: Each party shall be free from interference,
authority and contact by the other, except as may be necessary to
carry out the provisions of this Agreement. Neither party shall
molest the other nor attempt to endeavor to molest the other nor in
any way harass or malign the other, nor in any way interfere with
the peaceful existence, separate and apart from the other.
3. NAHES: It is understood that the terms HUSBAND and WIFE
are used throughout this Agreement solely as the method of
identifying the parties and such words shall not be construed to
have any special meaning or purpose for their use, and are not
dependent on their marital status with each other.
4. DIVORCE: HUSBAND has filed an action for divorce in
Cumberland County, Pennsylvania. The parties agree that upon the
passage of the ninety day waiting period after the filing of the
divorce complaint, they will both execute affidavits of consent so
that the divorce action can be completed. This Agreement shall
remain in full force and effect regardless of any change in the
marital status of the parties.
5. WIFE'S DEBTS: WIFE represents and warrants to HUSBAND
that she will not contract or incur any debt or liability for which
HUSBAND or his estate might be responsible other than those debts
assumed by the HUSBAND as a consequence of the Agreement herein.
6. HUSBAND'S DEBTS: HUSBAND represents and warrants to WIFE
that he will not contract or incur any debt or liability for which
WIFE or her estate might be responsible other than those debts
assumed by the WIFE as a consequence of the Agreement herein.
7. MUTUAL RELEASES: Subject to the provisions of this
Agreement, each party has released and discharged, and by this
Agreement does for himself or herself, and his or her heirs, legal
representatives, executors, administrators, and assigns, release
and discharge the other of and from all causes of action, claims,
rights or demands whatsoeverr in law or equity, which either of the
parties ever had or now has against the other except any or all
causes of action for divorce and except any or all causes of action
for the breach of any provisions of this Agreement or property
rights created and maintained in this Agreement.
B. WAIVER OF CLAIMS AGAINST ESTATE: 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 manner of thing
done, omitted, or suffered to be done by said other party prior to
and inclUding the date hereof.
9. DISPOSITION OF RESIDENTIAL PROPERTY: The parties are
joint owners of a tract of improved real estate located in West
Hanover Township, Dauphin County, Pennsylvania, and known and
numbered as 7761 West Skyline Drive, Harrisburg, Pennsylvania. The
property is subject to two mortgages, one being a mortgage held by
Pennsylvania St4te Employees Credit Union with a current balance of
approximately $67,000.00 and the other being a second mortgage held
by First Federal of Harrisburg, Pennsylvania with a current balance
of approximately $6,000.00. In regard to the mortgage held by
First Federal of Harrisburg, HUSBAND shall make the payments as
they come due until December of 1999 at which time he will satisfy
this obligation in full. In regard to the Pennsylvania state
Employees Credit Union mortgage, HUSBAND make the payments on this
obligation as they come due until December 6, 2001. At that time,
HUSBAND shall convey all of his right, title and interest in the
premises to WIFE by way of a special warranty deed, at which time,
WIFE shall become responsible for the balance then due and owing on
the Pennsylvania State Employees Credit Union mortgage. Also at
that time, WIFE shall cause HUSBAND to be removed from
responsibility for said mortgage either by securing his release
from the Pennsylvania State Employees credit Union or refinancing
and satisfying the Pennsylvania State Employees Credit Union
mortgage or by selling the premises and satisfying the Pennsylvania
State Employees credit Union mortgage.
10. REAL ESTATE TAXES: HUSBAND shall be responsible for
payment of the real estate taxes on the property set forth in
Paragraph 9 above until December 6, 2001, at which time this
obligation shall cease. In regard to the real estate taxes which
are levied during the year 2001, said taxes shall be prorated until
December 6, 2001, on a fiscal year basis.
11 . MOTOR VEHICLES: HUSBAND shall retain as his sole and
separate property the 1982 Volvo automobile and the 1979 Saab, and
WIFE shall waive any claim which she may have to these vehicles.
WIFE shall retain as her sole and separate property the 1986
Chevrolet automobile and the lease for the 1995 Ford Windstar motor
vehicle and HUSBAND waives any claim which he may have to these
vehicles.
12. BANK ACCOUNTS: The parties have previously divided to
their mutual satisfaction any and all bank accounts. Henceforth,
any bank accounts in the name of HUSBAND shall remain his sole and
separate property and any bank accounts in the name of WIFE shall
remain her sole and separate property.
13. PERSONAL EFFECTS: Each party shall retain as his or her
own property, free and clear of any claims of the other party, his
or her respective, individual and personal clothing, jewelry, and
personal effects.
14. PERSONAL PROPERTY: HUSBAND shall retain all items of
personal property currently in his control and possession and WIFE
waives any claim thereto. In regard to items of personal property
located at 7761 West Skyline Drive, Harrisburg, Pennsylvania,
HUSBAND agrees that these items of personal property shall remain
the separate property of WIFE; provided, however, that WIFE, in her
sole discretion, may release certain items of personal property to
HUSBAND, and if she does so, HUSBAND shall remove said items from
the premises located at 7761 West skyline Drive, Harrisburg,
Pennsylvania, within one month after the execution of this
agreement. If HUSBAND does not remove the items within one month
after the date of the execution of this Agreement, WIFE shall have
the right to remove and dispose of such items of personal property
as she sees fit.
15. STOCKS AND BONDS: Neither party has any interest in or
control of any stocks or bonds.
16. RETIREMENT/PENSION PLANS: WIFE owns a 401(k) retirement
plan through her employer, the Harrisburg Diocese of the catholic
Church. WIFE shall retain this asset as her sole and separate
property and HUSBAND waives any claim which he may have thereto.
HUSBAND is a member of the State Employees Retirement System
and as an employee of the Conunonwealth of Pennsylvania, has a
retirement program through PSERS. WIFE recognizes that this is a
substantial asset and that she has the right to have this asset
evaluated. WIFE is satisfied that she is being adequately provided
for by virtue of other assets which she is receiving under the
terms of this Agreement, and agrees that HUSBAND shall retain the
aforementioned retirement program as his sole and separate
property. WIF'E waives any claim which she may have thereto. WIFE
further agrees to execute any and all documents necessary to
evidence her waiver of any claim to HUSBAND's pension/retir.ement
plan.
17. HEALTH INSURA~ Upon termination of the marriage, each
party shall be responsible for obtaining and maintaining his or her
own health insurance ben~fits. Each currently has health insurance
benefits provided by his or her respective employer. HUSBAND
agrees to continue to provide health insurance coverage for the
parties' children until they are no longer considered dependents for
Federal Income Tax purposes.
lB. LIFE INSURANCE: HUSBAND agrees to maintain one or more
life insurance policies which will provide for satisfaction of the
mortgages addressed in Paragraph 9 herein, in the event that
HUSBAND should die prior to the end of his obligation in regard to
the mortgages. By way of clarification, he shall maintain a policy
which would satisfy the First Federal of Harrisburg mortgage if he
were to die prior to December 1999, and he shall maintain Q life
insurance policy which would satisfy the Pennsylvania state
Employees Credit Union mortgage if he were to die prior to December
6, 2001. The obligation to maintain this policy or these policies
shall terminate on the respective dates set forth in the preceeding
sentence.
If the parties son, sethr is still condsidered a dependent of
wife for income tax purposes, HUSBAND shall maintain a life
insurance policy on which he is the insured and on which Seth is
the beneficiary with a death benefit amount of not less than
$20,000.00, this obligation to run from December 6, 2001 until
December 6r 2005, or when Seth is no longer a dependent of WIFE,
whichever event occurs first.
19. DEBTS AND OBLIGATIONS: The parties have a personal loan
through PSECU with a current balance of approximately $5700.00.
HUSBAND agrees to assume this obligation and to satisfy it upon his
retirement from his current employment by \lse of accumulated sick
leave and annual leave. However, if this sum is not sufficient to
satiSfy this obligation, HUSBAND will assume it as a personal
installment loan and shall hold WIFE harmless in regard thereto.
The parties have credit cards which are in their individual
names alone. Each shall be responsible for his or her credit card
obligations.
20. CUSTODY: The parties have one minor child, Seth, born
December 6, 19S3. The parties agree that they shall have joint
legal custody of Beth and the WIFE shall have majority physical
custody of Seth. HUSBAND shall have reasonable and liberal
visitation rights as shall be agreed upon by the parties.
The parties specifically agree that in all matters of
importance relating to seth's health and education, they shall
consult and confer with each other with a view toward adopting and
following an harmonious policy. WIFE reserves the right, as
majority custodial parent, to have final decision making powers in
matters of conflict with HUSBAND.
The parties recognize that for the well-being of Seth, it is
essential that his affections for both parents be preserved.
Accordingly, both parties agree not to attempt to alienate the
affections of Seth for either parent, but instead to foster and
encourage those affections.
21. NOTIFICATION OF RESIDENCE: The parties shall keep each
other informed of his or her place of residence, including the
specific address until Seth reaches the age of eighteen years at
which time this obligation shall end.
22. SUPPORT: HUSBAND shall pay to WIFE for the support of
Seth the sum of $500.00 per month until Seth graduates from high
school in June 2002. It is specifically understood and agreed that
so long as HUSBAND's support obligation is current, these payments
shall be made directly to WIFE by ordinary check in ordinary mail,
or through direct deposit into WIFE's cheCking account. However,
if HUSBAND misses two consecutive months of child support, the
parties agree that WIFE may, at her sole optionr apply to the
appropriate Domeat!c Relations Office and have the above cited
support payment made through that office. It is specifically
understood and agreed by and between the parties that the child
support obligation of HUSBAND of $500.00 per month takes into
consideration the disparate earnings and abilities to earn income
of the parties and WIFE's expenses associated with raising Seth.
Thus, there shall be no abatement in this child support obligation
in the event that Seth resides with HUSBAND during vacations or
summer months; provided, however, that this obligation to pay
support shall terminate if WIFE is no longer the majority custodial
parent of Seth.
The parties acknowledge that they have a joint obligation to
provide for any extra curricular activity expenses associated with
activities in which Seth participates, such as sporting teams and
lessons. The parties will consult with each other regarding such
expenses.
HUSBAND's obligation provided for herein shall terminate upon
high school graduation in June 2002. Any payments toward Seth's
college expenses shall be discussed by the parties.
23. MEDICAL. VISIONr AND DENTAL EXPENSES: The parties shall
share in the responsibility for extraordinary, un reimbursed
medical, vision, dental and prescription expenses on behalf of
their dependent children, commensurate with their means.
24. TAX EXEMPTIONS: HUSBAND agrees that WIFE shall be
entitled to claim Kristie, Alex and Seth as exemptions/dependents
in the filing of her Federal and/or state income tax returns.
25. TAX DEDUCTIONS: WIFE agrees that HUSBAND shall be
entitled to claim as deductions on his income tax returns, the
interest which he pays on the mortgages provided for in Paragraph
9 herein and the real estate taxes as set forth in Paragraph 10
herein.
26. PAYMENTS TO WIFE: HUSBAND agrees to pay to WIFE the sum
of $100.00 per month until December 6, 2001, at which time this
obligation shall terminate. It is the intention that these
payments be used by WIFE for investment in her 401(k) plan through
her employer.
27. WAIVER OF APPRAISEMENT AND INVENTORY: The parties
acknowledge and agree that they have had an opportunity to value or
have appraised any and all marital property, and they do hereby
waive a formal appraisal and inventory of same/ and no statement or
representation by "lither party as to value shall be deemed a
misstatement or misrepresentation to the other or be deemed
fraudulent.
28. EXECUTION OF DOCUMENTS: The parties hereto agree to
execute any and all documents necessary to effect the terms of this
Agreement.
29. INCORPORATION: This Agreement may be incorporated into,
but shall not be merged with, a Decree in Divorce between the
parties.
30. LAW OF AGREEMENT: This Agreement shall be construed
under the laws of the Commonwealth of Pennsylvania.
31. ENTIRE AGREEMENT: This Agreement contains the entire
understanding between the parties. There are no representations,
warranties, covenants or understandings other than as expressly set
forth herein.
32. LEGAL ADVICE: WIFE understands that the within Agreement
has been prepared by HUSBAND's attorney, Joel O. Sechrist, Esquire.
WIFE has been advised to retain her own attorney to advise her
prior to the execution of this Agreement. The parties to this
Agreement hereby acknowledge that they have carefully examined its
contents and that they are satisfied that they understand the
Agreement and further that the Agreement is fair and equitable.
IN WITNESS WHEREOF, the parties have hereunto set their hands
and seals the date first above written.
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ATTOftNIY AT LAw
... OL.D VONK ROAD
ITTI..,. ~A 171'.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
NQTlCE TO DEFEND AND CLAIM RIGHTS MANDATED BY R.C.P. 1920.71
VIRGIL H. CHAMBERS
civil Action - Law
VS.
No.
MARY L. CHAMBERS
Action in Divorce
AVISO PARA DEFENDER Y RECLAMAR DERECHOS
US TED HA SIDO DEMANDADO EN LA CORTE. si desea defenderse de las
quejas expuestas en las pAginas siguientes, debe tomar acci6n con
pronti tud. Se Ie avisa que si no se defiende, el caso puede
proceder sin usted y decreta de divorcio 0 anulamiento puede ser
emitido en su contra por la Corte. Una decisi6n puede tambien ser
emitida en su contra par cualquier otra queja 0 compensac16n
reclamados por el demandante. Usted puede perder dinero, 0
propiedades u otros derechos importantes para usted.
Cuando la base para el divorc1o es indignidades 0 rompimiento
irreparable del matrimonio, usted puede solic1tar consejo
matrimonial. Una lista de consejeros matrimoniales estA disponible
en la oficina del Prothonotary, en la Cumberland County Court of
Common Pleas, 1 Courthouse Square, carlisle, Pennsylvania, 17013.
BI UBTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL,
HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL
DE DIVORCIO 0 ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL
DERECHO A RECLAMAR CUALQUIERA DE ELLOS.
US TED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO
TIENE 0 NO PUEDE PAGAR UN ABOGADO, VAYA 0 LLAME A LA OFICINA
INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL.
Office of the Court Administrator
Cumberland County Courthouse
4th Floor
1 Courthouse Square
Carlisle, Pennsylvania 17013
Telefono No. (717) 240-6200
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
VIRGIL H. CHAMBERS
civil Action - Law
VS.
MARY L. CHAMBERS
No.
Action in Divorce
COMPLAINT
1. Plaintiff is virgil II. Chambers, an adult individual, who
currently resides at 132 Prowell Drive, Camp Hill, cumberland
county, Pennsylvania, 17011.
2. Defendant is Mary L. Chambers, an adult individual, who
currently resides at 7761 West Skyline Drive, Harrisburg, Dauphin
County, Pennsylvania, 17112.
3. The Parties have been bona fide residents in the
commonwealth of Pennsylvania for at least six months immediately
previous to the filing of this complaint.
4. The Plaintiff and the defendant were married on January
16, 1971, a~ Alleghany, New York.
5. There have been no prior actions of divorce or for
annulment between the parties.
6. The marriage is irretrievably broken.
7. The Parties separated on August 30, 1993, and have
continued to live separate and apart continuously since that date.
B. The Plaintiff has been advised of the availability of
counseling and that the Plaintiff may have the right to request
that the court require the parties to participate in counseling.
9. Plaintiff requests the court to enter a decree n~ divorce.
to, ~~
o.
Old
It tars
supreme
sechri t
York Road
PA 17319
Court 1.0.
815609
I verify that the statements made in this complaint are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn
falsification to authorities. _ ~
DATE: r/;O/7T 1Jt,~~iI ~
! Vir 1 II. ch
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
VIRGIL H. CHAMBERS
CIVIL ACTION
LAW
VS.
MARY L. CHAMBERS
NO. 95-2979 civil Term
ACTION IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under section 3301 (c) of the
Divorce Code was filed on June 1, 1995.
2. The marriage of plaintiff and defendant is irretrievably
broken and ninety 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
division of
them before
understand that I may lose
property, lawyer's fees or
a divorce is granted.
rights concerning alimonr'
expenses if I do not cIa m
I verify that the statements made in this affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. C . ss4904, relating to unsworn
falsification to authorities. ., ~I
1/ 0' /0, I
DATE: 10(' f 9J '1./1 11 c '{(~ '-ha../
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
VIRGIL H. CHAMBERS
CIVIL ACTION
LAW
VS.
NO. 95-2979 civil Term
MARY L. CHAMBERS
ACTION IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (cl of the
Divorce Code was filed on June I, 1995.
2. The marriage of plaintiff and defendant is irretrievably
broken and ninety 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 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 verify that the statements made in this affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. ss4904, relating to unsworn
falsification to authorities.
DATE: ilj!Jt!'.r
h' ~ I 1
~"-O--I.' . "" '- iLL J>~ Ic.~ ,lL-
Mary L. ~hambers
Nov \li j 29 PH '9li
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JOG" O. BUCIIIl18T
ATTORNEY AT LAW
ae8 01-0 YORK ROAD
nUll.. PA 17118
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTYr PENNSYLVANIA
Virgil H. Chambers
CI VI J, ACT ION - (,AW
vs.
NO. 95-29'/9 CIVIl.
Mary L. Chambers
ACTION IN DIVORCE
AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
S5:
COUNTY OF YORK
Personally appeared before me, the undersigned officer, a
Notary Public in and for said County and Commonwealth, Joel O.
Sechrist, Esquire, who being duly sworn according to law, doth
depose and say that he caused a true and correct copy of the
Complaint in the above cited case to be served upon the defendant,
Mary L. ChamberEo, by personal service, her acknowlegment of service
being attached hereto and incorp9rated herei~n.
I j'7(L(O Z_ - L
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SWORN and SUBSCRIBED to
before me, this31~r day
of Oo-rt> 6~ , I'll".,;"
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Not.rlal ~ti81
Lindl J . MeOlnill. Notlry Publlo
Falrv'ew Twp.. York County
My Commlulon E.plrel Fib. 23. 1 ggg
MoImar. Poml\i'Ma lion 0/ NowM
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
VIRGIL H. CHAMBERS
VS.
Civil Action - Law
No.
MARY L. CHAMBERS
Action in Divorce
I, Mary L. Chambers, hereby acknOWledge that I received a true
and correct copy of the Complaint in the above cited divorce action
from Joel O. Sechrist, Esquire, on June 5, 1995.
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