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HomeMy WebLinkAbout95-03826 'I ;J~ .,/.'1 '.1' ,! 'iill 1.111 ,I,I ,I' 'j'\" , "t' "'1 ;d '1' I'.' ", ,":' II I ,I , I I \.. 8 J I I , I , .., , ,,' .1 " I i\ " i. ";I';',(, 't:(l \,re ,I'~/ , 'I,', ,.11 )Ii 'Ii: Ii ~_,1 Lj,ft ,-,/1 ,II' ,f :.It!: ""1' 1.1ii 'dl!j "I " 'J" .~ I" t_"," ,jl;{ .,1/ tA \11;;"'t; ,I "'I " , :,1 d;::( l;~' 111 I';: '" ,~F .-.' I Il,lt :rH , 'iN r f : ~ ' " ,'I'" , I " , I } i'j I :~,;t 1_1t ["., Ii/'I ",:,11 1'(', . )~J- 'i1 ,::,,'H, J'-:\" ,.- '::t' I/',j 'I,,\":.\~l ,q(;';)n I),',:, ,',,~j4 .'1.1'1 " ":'1!~ ,\' '_'1f ~ dH rJ:\O- .:,,;{, '~ i ;~il~ ,:.'! /,'.;1' i"tj ,', :~:'.!~ ,;' '." h" If ,1:,1: ',I~; ~ip ii ,~;I '\' if Iii ,I I, ( I ~ J I I I I I '" ~ 1,1 " iI ,I " I' , , II:, , " , , " 'I , , I, ,', ,1,( , 'il I, " " .~.;. ':.' 'let' ,tet. 'II " t :~ , , PLEAS i: I~ I, ~ * * * * ~ * * * lij " * * * 1* I 'Iil I, !~ i* ;'8 t: :~ I"l ,j". I,~ ,., .:tt. .t<<. ,~.:. ':.: .,~, ~: . ,: , \ Ill: *i ..' ..., . .:... .: ~:' .;.; :.;. ,~.> ~.;, :.;. ,:.;.' .:.: ~. ':04;- ':.:. .:.:. .:.:- ':e:. ~ * .1 Ill: , I I!!t , * Bonnie L, Connor, * * * * lij * ~ Iil ~l *1 I . i * * * * * * * * ,Tl)~. p~9P~r~y p,e~tlel11ent ,f\<;!recmenl dal,e,d ,~a,~, 1~,1, ,19~,6, ,~!l, ,l]~~!",b'y * ) ) M ,incor,pora,ted, .but not mergadintothi.El ,c,le~,~ll"'..."",,,,,,,,,..,,, '~ . ,,/ i ~ ~ ,/: ~~ . Ilv T~," c,),../tl " '~ * ..,.N "I,M I __ or. AII.,.t, V, ,_ ' " ,j./././J ~ ~.1. ':' ~ ..K{~:'(L".y~ J(.~l! t'. /U<I'l';7J"/ ~1"',.,~.,...~~ ~ 8 '~'j/.11.L K ~4; d-ef ':: ~' .f ~Pl)lhnl1f1:nt'Y ~ .~ --~-~'.""~ . :~ . -~~..~.*~--,~,.~,~~,~~~,~~.*..*,~'~'~,.~,*"~.,~.~. .'e>' .:<<, ':.' .:.c, :.t. IN THE COURT OF COMMON COUNTY OF CUMBERLAND STATE OF I~~~~ ", .~/i!$~ PENNA, Plaintiff :\ II. J626 ClvllTerml~ 95 \'.'1'.-0,; frederick Paul Connor, Defendant DeCREE IN DIVORCE \ \ I);JJ. ) AND NOW, ' , ,..... , ' , , , . ir 19 . .,b" It 15 ordered and decreed that ' ,00nn.1.e. L.. Connor " , , . , " plaintiff, . , , . , , , , " defendant, and "r~'~~~'9~,~~~~,~op~?r. are divorced from the bond5 of matrimony. The court retaln5 lurl5dlctlon of the following clalm5 which have been raised of record In this action for which a final order has not yet been entered;\J'J~ :~ , ' I~ " ' :~ I, rl! I, , , , , , , ..... LAW o."c~.. . ;.J I MivE.-rSIol)E"'OA \410 OO"TH IlCOOO ""~~T " q, ION 10.' HA~~I"UIlO. "II. mo. . . '. ,1\ , , 'Iii I ,. il/; I \'i! I, I ,j >I' I l" . ,I ., . . r ..~- " I, , " I" II, j '. I' I' ',;- ....' .. , 1. lU.'lOR!,;JJll The parties ague that their marriage i irretrievably broken and that they mutually oonsent to a divoro and agree and have executed all necessary Affidavits required b the court for the entry of a mutual consent divorce. Bpth Husbsn! and Wife havo directed their respective counsel to immediately fil with the Court said Affidavits and file the appropriate document to request a Decree in Divorce from the bonds of matrimony unde Section 3301(c) of the Divorce Code. 2, INjERnaU;H.!;);; I Each party I3hall be free from interferenl1e authority, and contact by the other, as fully as if he or she wer single and unmarried except as may be nedessary to carry out th prOVisions of this Agroement. Neither party shall molest the othe or attempt to endeavor to molest the other, nor compel the other t cohabit with the other, or in any way harass or malign the othor, nor in any way interfere with the peaceful existence, separate an apart from the other. 3, JflfE-'.lL-DE.B.'J:.I;! I Wife represents and warrants to Husban that since the separation, to wit, February 8, 1992, she has no and in the future she will not, contract or incur any debt 0 liability for which Husband or his estate might be responsible, an shall indemnify and save harmless Husband from any and all claim or demands made against him by reason of debts or obi igation ,. MEVI"'. DlI_ "'ONonTHSECONDSTAEET . PO B())(l()tj~ I HAAnISnURf.i, PA 1"08 11111l3e.0428' fAXI11711J6.iQ17 .. . incurred ~y her. 4. HU~AtlD~-DEBj~1 Husband repre8ent8 and warrante to Wif that eince separation, to wit, February e, 1992, he hae not and i the future he will not, contract or incur any debt or liability fo which Wife or her estate might be reeponeible, and ehall indemnif and save harmlee$ Wife from any and all claims or demands mad against her by reason of debts or obligations incurred by him. 5. tru.'l'!1/iIL...FJj;LfiAliIDlI subject to the provis.l.ons of thi Agreement, each party has released and discharged, and by thi Agreement does for himself or herself and his or her heire, lega representatives, executors, administrators and assigns, release an discharge the other of and from all causes of action, claims rights, or demands, whatsoever in law or equity, which either 0 the parties ever had or now has against the other, except any 0 all causes of action for termination of the marriage by divorce 0 annulment and except any or all causes of action for breach of an provisions of this Agreement. Husband and Wife specificall release and waive any and all rights he or she might have to rais claims under the Divorce Code of 1980, as amended in 198 inclUding, but not limited to claims for equitable distribution 0 marital property, support, alimony, alimony pendente lite, counse fees or expenses. The fact that a party brings an action t MIVlftl.ollrOll "'ONOHTltSFCONDSTI1flT . PO 80)(1001 . t-lARnI5BlJAO, PA "108 0111 1360ol1H . FAX 111'11 236-1al1 .. enforce the prcperty agreement IUI incorporated in the divorc decree, under the Divoroe Code of 1980, as amended in 1988, doe not give either party the right to raise other claims under th Divorce Code, specifically waived and released by this and all rights and obligations of the parties arising marriage shall be determined by this Agreement. 1\. RELF;AIilE_dOl"._'1'EI1TlIHENTARY!;I,^IHI31 Except as provided for i this Agreement, each of the partios hereto shall have the right t dispose of his or her property by Last Will and Testament 0 otherwise and each of them agree that the estate of the other, whether real, personal or mixed, shall be and belong to the perso or persona who would become entitled thereto as if the decedent ha been the last to die. This provision is intended to constitute mutual waiver by the parties of any rights to take against eac other I s Last Wills under the present or future laws of jurisdiction whatsoever and is intended to confer third-part beneficiary rights upon the other heirs and beneficiaries of each. 7. Uglb1LA!2Y_l&I'J/..YOL!m'l'hRLEXE.C!JTI.QHI The provisions of thi Agreement and their legal effect have been fully explained to th parties by their respective counsel. The Wife has employed and ha had the benefit of counsel of Laurie A. Saltzgiver, Esquire, as he attorney. The Husband has employed and has had the benefit 0 MIYlftl. DllfOft "'1) NOllTll Sf(ONIJ 5HIH' . PO no). 1067 . HMH\ISRlJRG. PA 11106 11l1lIJ6004m . FMi 11111131).'811 ~ oounsel of David Getz, Ellquire, as hh attorney, Each part aoknowledges that they have reoeived independent legal advice fro oounllel and that each party fully understands the facts and hav been fully informed of their legal rights and obligations, and eac party acknowledges and accepts that this Agreement is, under th oiroumstances, fair and equit!\ble., 611d that it is being entere< into freely and voluntarily after having received such advice an with such knowledge, and that execution of this Agreement is no the result of any duress or undue influence and that it is not th result of any collusion or improper or illegal agreement 0 agreements. Also, each party hereto acknowledges that he or sh has been fully advised by his or her respective attorney of th ourrent Pennsylvania uivorce Law, and his or her rights thereunder each party hereto still desires to execute this Agreemen acknowledging that the terms and conditions set forth herein ar fair, just, and equitable to each of the parties and waives thei respective right to have the Court make any determination or orde ' affecting the respective parties' right to a divorce, alimony alimony pendente lite, equitable distribution of all marita property, counsel fees and costs and expenses. 8. DIVISIQH OF p~R~QnA1-RRQF~RT.XI The parties have divide between them, to their mutual satisfaction, the personal effects household furniture and furnishings, and all other articles 0 MIVI"I. PllroIl 410NOIHttSI:CONDSIIUET . PO BOX 1062 . HARRISBURG. PA 17108 1I11ln60418 . FAX 11l712J6.2~17 .. . personal property which have heretofore l:leen used l:ly them i common. Should it l:lecome necessary, the parties each agree to Big any titles or documents necessary to give effect to this paragraph 9 . m:~'p.Q.sU.I9tLQrnJlJ'JMd)RQPfiR'J,''i I A. ~!~'s-TQWnbQY~ - Wife presently resides in a townhous located at 420B Nantucket Drive, Mechanicsl:lurg, Pennsylvania 17055 said townhouse is presently held by the parties in joint names Husl:land does hereby set over, transfer, and assign to wife all 0 his right, title, and interest in said townhouse. The townhous shall be the sole property of the wife, and the husband agrees t execute a Quitclaim Deed which transfers said townhouse into wife' name alone. Wife agrees that she shall be responsible for th mortgage on said townhouse, and shall indemnify, and save harmles husl:land any and all claims or demands made against said mortgage B. Husband's Townhouse - The hushand presently resides in townhouse at 576 Valley Road, summerdale, Pennsylvania. Sai townhouse shall be the sole property of the husband. The townhous is presently in the name of husband and the parties I daughter Cheri Swaim Uhrinek. Wife does hereby set over, transfer, an assign to husband all of her right, title, and interest in sai townhouse, and agrees that she shall execute a Quitclaim Deed t that effect if husband so desires. Husband agrees that he shall b responsible for the mortgage on said townhouse, and shall indemnif MIYl~1 . DllfOll 410 NORTH SECOND STAHT . POBOX 1062 . HARRISBURG, PA 17108 111112'31}942B . FAX11171236-2BI7 . and save harmless wite ft'om any and all claim. at' denuU')dlS mad against said mot'tgage. 10, EQUITAJlLfL.D.IH'l'.Bl.BID'IQN I A. lllit9Jl}gJ211~J!l.1 Wife shall keep as het' sole pt'operty, th 1990 300ZX Automobile presently in her possession. Husband agre~ to execute any all documentation necossary to givo effect to thi paragnph. The husband shall presently keep as his sole an exclusive property, any automobile or leased automobile presentl in his possession, Wife agrees to execute any documentatio necessary to give effect to this paragr.aph. B. ~~lgn-E1~LB~~~m~nt_~~s/IRABI Wife shall keep a her sole property any pension plans or IRAs in her name. Husban IShall keep as his sole property any pension plans or IRAs in hi name, The ownership of these pension plans or IRAs shall be fre and clear of any interest of their respective spouse now or at an time in the future. C. ChecklnQ AccQ~Savin~~n~1 Wife shall keep a het' sole and exclusive possEssion any all checking accounts 0 savings accounts presently titled in her name, Husband shall kee as his sole and exclusive property any checking accounts or saving accounts presently in his name. The ownerShip of these ban accounts shall be free and clear of any interest of thai respective spouse now or at any time in the future. MIVIRI . DllrclII "10NOfHHSf.CONO~THEET . PO BO)(l06~ . liARAI58URG. PA17108 11"113&0'1" , FAx 11"113&1811 '" D. r.J.mnlilJll....,M51.\ly.n.!a' I Wife shall keep as her aole I\n .~clusive posseaaion any finanoial aooounts or inveatment aocount presently in her name. sp~cifically Prudential Securities Accoun H044"267424-18, which is presently titled in wife's name, shall remain her sole and excluaive property. Husband shall keep aa his aole and exclusive property an financial accounta or inveatment accounts presently in his name. The ownership of these financial accounts or investment account ahall be free and clear of any interest of their respective spoua now or at any time in the future. E. Y!uu:ly_..Er.QP.!lrtY........Qntl.!lm~n.t._I'f!ym!lnt t Husband agreea pay wife an annual Property Settlement Payment by February lat 0 each year. Said payment ahall be in the amount of $500.00, an shall be payable by husband to wife on or before February lat 0 each year. 11, COUNTRX~VlLHEM>>~HIEt Husband agreea that he ahal transfer the partiea joint country Club membership at Country Clu of Harrisburg to the wife. Said country Club membership shall b placed in the wife's name alone, and wife shall be responaible fo all future fees and dues related to this membership. 12. FUTURE AUTOliQHlLE-EAlMEHTt The partiea acknowledge tha wife'S automobile, the 1990 300ZX ia now almost aeven years old, MIVlftl. DlI_ "'()NOIlTHSfCON[)~Tf\HT . PO BOX 1001 . HARRISBURG, PA 17108 1111l/360A1H . FAX [7111236.2817 , and tnat wite may need a neW automol:lile in tne near tuture. Husl:land agrees that in tne event wite must purcnase a automol:lile, that he is willing to discusS with wite a possil:ll additional payment to her, in the form of an additional alimon payment, to assist her with her car payment. 13. H~AllrJi_IIUl!lF.Allgl'it Husband agrees that he shall maintai wife on his healtn insurance plan through his employer, or shal maintain hor on a similar plan. Husband agrees tnat he shal maintain said health insurance and medical l:lenefits for th duration of wife's lifetime, or until her remarriage, or until sh is oligible for medicare coverage. 14. lIIf.IL1;I'!~JJFJili!;;X:;t Husband agrees that wife shall be th beneficiary of life insurance with a total death benefit 0 $525,000.00. Husband shall maintain and pay the premiums on sai life insurance, and wife shall be the irrevocable beneficiary, thereof. Husband shall provide wife with annual statement evidencing that the premiums are paid in fUll and up to date. Huspand agrees that wife shall. remain the beneficiary of insurance, and, if, for any reason, husband removos her a beneficiary, she has the right to bring an action against hi estate to collects sums due her under his life insurance poll.cy. If wife predeceases husband, then these policies shall terminate, MlVlftl.OIII011 "H1NonniflfcONDsmHl . pO 80X1067 . HARAISAlH'G, PA \"1\08 III 1) ".lenA'S . FAX 111 11236-1817 " or the husband shall have the right to rename a living benefioiary. 15. ALnm.N1r Husband shall pay to wife alimony in the amount ot $3,700.00 per month. Said alimony payments shall be owed by the husband to the wife for the rest of her 1J. fetime, or Ul1t 11 her remarriage, or cohabitation with a member of the opposite sex who is not a family member, or the death of either party. The amount of said alimony payments can be modified by either party when the husband retires, so long as he does not retire prior to age sixtY-five. At the time of husband I s retirement at age sixtY-five, both parties income, including any social security benefits will be conaidered in calCUlating a new amount of alimony. Addi tional.ly, it is the t!!xpress intent of the parties, tha the amount of alimony shall only be mOdifiable, prior to husband's retirement at age sixtY-fivt!!, in the event of Unforeseen oircumstances occurring to the hUsband, SUch as a diaability or an empl.oyment cutback which is beyond husband' control. It is the express intent of the parties that the alimon payments shall only be modified at the occurrence of an unforesee or severe event which will cause a detriment to husband's capacity, and, thus, his ability to pay alimony in the amount to the wife. It is further agreed by the parties, that suc an event may warrant a downward modification of the amount 0 alimony paid by the husband, but will not delete his obligation MIVlft.. DllfOfI "'ONORIHSECONOSfREEI . po 130X '06~ . HARRISBURG, PA 11108 11171136.0.418 . fAX 111711:J15'~8' 1 .. pay alimony altogether. The parties agree that these alimony payments will be made through the Domestio Relations ottioe at cumberland county. 16. >>BEACHI If either party breaches any provision of thi Agreement, the other party shall have the right, at his or he eleotion, to sue for damages for such breach or seek such othe remedies or relief ae may be available to him or her, and the part breaGhing this contract shall be responsible for payment of lega fees and costs incur.red by the other in enforcing their right under this Agreement. 17, MBE.EMJ;;NT TO COlITINUE Ili....E.YElf'l'......Qf-D.IYJ)BC.f;1 The failure 0 either party to insist upon str.ict performance of any of th provisions of this Agreement shall not be construed as a waiver 0 any subsequent default of the same or similar nature. In the even that the marriage of the parties hereto is terminated by divorce, this Agreement shall nevertheless remain in full force and effect, and shall survive such decree and shall not in any way be affecte thereby, except as provided for herein. 18, ADDITIONAL INSTRUME~: (A) Each of the parties shall from time to time, at th request of the other, execute, acknowledge, and deliver to th MIYI~.. DU_ "'ONOATHSfCONOSTREEr . PO BOX 1061 . HARRISBURG. PA 11108 11111 :1JI)-!}.42H . fAX l11112J6.2811 . other party any and all further inatrumentB that may be reaaonably required to give full force and effeot to the provisions of this Agreement. (B) This Agreement shall be incorporated into a Divorce Deoree but not merged therein. 19. KOOIFIC6n911....AHlLHAIYEB: A modification or waiver of an of the provisions of this Agreement shall be effective only if mad in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance 0 any of the provisions of this Agreement shall not be conatrued a a waiver of any subaequent default of the same or aimilar nature. 20. DIDlCRIPTIVE HEA.!UJI.Jm: The descriptive headings uae herein are for convenience only. They shall have no effec whatsoever in determinirg tho rights or obligations ot the parties. 21. y'QID CI.Allirnlll If any term, condition, clause 0 provision of this Agreement shall be determined or declared to b void or invalid in law or otherwise, then only that condition, clause or proviaion ahall be stricken tram thi Agreement and in all other respects, this Agreement shall be vali and continuo in full torce, effect, and operation. MIYI~I. 0111'01I 410NORtH SfCONO SlIlEET . POBOX 1061 . HAFlAISBURG, PA 17108 III 7) nft.94,8 . FAX 17171 :1315.1811 ,. VII. IN THIil COUR'r Oli' COMMoN PLIUIS CUMBERLAND COUN'l'V, PI!:NNSYlNAN IA j d 2 V fll L"l eJul 11',' NO, .,.) H". BONNIE L. LAU CONNOR Plaint iff, FRIiJDERICK PAUL CONNOR CIVIL ACTION - LAW IN OIVORCr;: Defendant, NO'rICI!: YOU HAVE BI!:EN SUBO IN COURT. I f you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice arc served, by entering a written appeal:ance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that, if YOII fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or reHef requested by the Plaintiff. You may looe money or property or other rights important to you. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counselling. A list of marriage counselors is available at I Thf.! Office of the Prothonotary, Dauphin County Courthouse, Front and Market Streets, Harrisburg, Pennsylvania 17101. IF YOU 00 NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL OECREE OF OIVORCE OR ANNULMENT IS ENTERED, YOU MAY LOSE THE RIGHT TO CJ.,AIM 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 Tl!:Ll!lPHONE THE OPPICE SET PORTH BELOW TO PIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator, cumberland county One Courthouse Square Carlisle, PA 17013 (717) 240-6200 MIYI~I' DllfOIl <lONORI" SECOND STREET . PO BO' 1061 . "ARRISBURG. PA 17H18 11I111360'IB . fAX 1717'138.1B17 BONNIIll L, LAU CONNOR I IN THill COURT OF COMMON PLIEAS I CUMBERLANP COUNTY, PENNSYLVANIA Plaint iff, I I Viii. I NO. I FREDERICK PAUL CONNOR I CIVI L AC'l'ION . LAW I Defendant, I IN DIVORCIE COMPLAINT IN DIVO~ 1, plaintiff is Bonnie L. Lau connor, an adult individual who ourrently resides at 4208 Nantucket Prive, Meohanicsburg, Cumberland County, Pennsylvania 17055. 2, Pefendant is Frederick Paul connor, an adult individual who currently resides at P.O. Box 1B1, Enola, PA 1702$. 3, Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4, Plaintiff and Pefendant are husband and wife having been married on January 6, 1962 in Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. MIYI~I' DlUOlI "0 NORtH SECOND SlREET . PO BO"OOI . HARRISBURG. PA. 11101 1717,IJB.Q.l18 . fA>l7111238-1817 Court oompel defendant to pay alimony to plaintiff. Respeotfully submitted, MllJyn:RS & PES FOR BYI ''"' · .. :,q ,,4., , , Attorney I.D. No. 61382 410 North Second Street J?,O. Box 1062 Harrisburg, PA 17108 (717) 236-9428 Attorney for Plaintiff " MIVI~'I DI'~ "0 NORTIi SECOND STREET . POBOX 1000l . HARRISBURG, "" mOll 17171138~IB . FAX 11171138.1811 ( v-- . 'I " . .......~...I ~~ ~~ ~Po o . ~~ ~ ~8 ~ 1:3~ Hr..l ~~ ...:~ ~ .:~~ e~ua1 r.' ,,'I kF1~ ;', ::'-.: '. . ''1, 1\' , '-J ','-' . 'H 'H 'M . ~ ~ ~ o 'M ~ ~ o Po U P ~ . H ~ H ~ 1" ..... \~..., l,', \r~,~ '\) \0'~ '...... ."\ ....... ;;:-.. .t~ .,) "-!d, "\...!. - . III P I +J ~ . nl ~ 'tl o ~ 1:a ~ 8 ~ tJ ...: Po tJ ~ r.1 ~ ~.j , .) ,'j '/'1 I, I.) .:,... " ~. ") r"'l, .. I'{ \ ..:::j.. ...., '~ .... .~' ('< ...' r'" ..'c) '-.!.J '" .,.. I"'l, , "", ''v'';) '--~ :( ''1,... \ ... ,.", I. . --.".-. \; .-" ~ iY. g H Q 2j ~ ~ ~~i~~ ~ .., d ~ ~ ! p ~ 2 ~ y x iii H ~ H ~ ~ o u , ,. 7, plaintiff has been advisod that counseling is available and that plaintiff may have tho right to request Lhe court requl.re the parties to part icip,ate in counseling, plaintiff waives that right. Being so advised, 8. plaintiff requests the Court to enter a Decree of Divoroe. WHEREFORE, plaintiff, Bonnie L, connor, respectfully requestlil this Honorable Court enter a Pecree in pivorce. COUN'l' I ~OUITABLE DISTRIBUTION 9. ParagraphS one through B of the complaint are incorporated herein by reference as if set forth in full. 10. During the marriage, plaintiff and defendant have acquired various items of marital property, both real and personal, which are subject to equitable distribution under the Divorce Code. MIVI~I . 0111'01I <10 NORTH SECOND 5TREET . POBOX 1llel . HARR,S8URG, PA 17108 1111,138.0'18 . FAX 11171 23ll-1B17 fH ~ ::0:: n.... t;; 'Yj .-,-) !1 , ..~ p, e 12: ~ O":E-< ~ PI ,..; ~~:~j O'llI E-IUNZ ~I~~[j 8 MJI>: "''':0 ~ ~ .; ~~ ~B~u~ . ~ o ~ o U . H fil H ~ ~ . 4-< 4., '... +l I'l .... <1l .4 p, . IJ) p p: o ~ o u . ., I'l <1l 'tl I'l <.l 'H <.l Cl S ..: Po tl :il i>l ~ ~ ~ H j[j PIP: )~ 0 Sf:: Cl ! .o! It t: ~ [ ., ~ ~ C ~ \ ~ I , . . , ~ I:: ~ .!: , .., ~ 0: :J ~ ~ 0: 0: ., :t 110NN rm L, r"AtI CONNOH Plaintif f, IN '1'111;; eOl/WI' OJi' COMMON PI,I,:1\I1 Cl/MUW~L^NlJ CotJN'l'Y, PIENNf/YJ,vAN L^ VtJ, NO. 9~' 3Ji ~ (ll~f-~t ,J II. 1~IU;;oJ!HHCK PAUL. CONNOH Pof'Gl1diltlt. crvn. ^C'I'ION - r,^w IN rHVORC~: lliITl~ YOU HAVE: J31;:I,N SlJlm IN COlJH'J'. If YCIl winh to defend against tho claims sot forth in th.) fClllowing pil <JEl 11 , you must take action within twenty (;lO) daY:J aftot" thl.u Complaint and Notice aro nerved, by entering a wrH:ton ,;Jppe,ll.anco penJon,}.L.ly or by attornoy and filing in writing wIth tho COllt'l; your def"!nllOS or Clbject iOll/) to tho CJlaimll 1101: forth il'la innt you, You at.-.} wanlOd that, if you [ail to 00 130, the calle llIay proc'~ed without you ano a jud<jlllonl: llIay be tJntenld against you by the COUt..t without tln'thor noUC(1 for any money onteJ.'ed a<Jairwt YOII by the COUt.'t without f:l1l.-tlWI: not ic(~ for any llIo\Joy cla.ill\ed in th.. Complaint ot.' for ilny otlwr claim OJ: nlli,~f reqUtJeit,od by t.h'1 Plaintiff, You llIay lO/H' mOlHlY or property or other rightlJ important to you, When thel ~lrollnd [or divot.'c'.l !.n indiqnit.:i'l/J or !.rretl:ievabl'1 breakdown of the lUan,-iaqe, YOII llIay 1:"l'IU()/Jt lUan:!.ago c:ounsl)l.llnq, A lJ.ot of marriage c:ollno,'lorn ilJ ilvaJ.labllJ at t The Office Clf thll Prothonotary, Dauphin County CourtlloUSG, Prant olnd Market iJtt.'eut:l, Harrir;bul:g, Penlwylviln!..\ 17101.. IF YOl! f)O NOT I'[[.!.; ^ ('J,ArM I'OH M.fMONY, ~IArn'l'M, P/(OPEH'1'Y, COtJNSI.:r, FE';;S OJ( r';>:PEN:il':S m:I'OHI'; 'I'llI': F LNA/, I:JJ':CHI';I': OF DIVO/(Cl': <lI< ANNULMENT I.'i 1':NTI-:RI.:iJ, YOl! MAY J,O:il': '1'111,; 1<1(;11'1' TO ('J,A 1M ANY (lJ.' 'I'III':~1. YOU SHOUI,D TAKE THIS PAPER TO YOUR LAWYBR AT ONCE. IF YOU DO NOT HAVB A LAWYER OR CANNOT AFFORD ONE, GO TO OR 'l'ELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT mlERE YOU CAN GET LEGAL HELP. ArllI1illi:llJ:oIlfl;., ("lIllb"I:lolnrl County 0111' (\)\1] fhl)\l:lI_~ Sqll.ll'e Co'lI'l 1.1; I", "A I '1 Ii I. .I ('/1'1) ;HO 1;;'00 MlnRS . DurDR 410NflfllJI'lll'I)WJ';I'IIf"T . PO flOXIOfi1 . IIAllnl'illLJnCi, PA 1710R Ulll).llllJ.t)U . 'All. 1I1JlJJtj.JUlJ . II , I I , , , I , , I' ., '1 .' i. t 'I ,,' "1 " ",I,) , I"..", , , '. I' Ii , ~ ,I .1 . \ , I 1 I.AWO"'CIe MEYER. & DESrOR .10 HO"'.. IlCOIrIID .,,.Ilf ~. 0 100 '0" HAA"'HUIIO. ~A. 171.,. o ~T~fz!!~~I:X. J~W'U~:"" "UD IN lHIUCT~ O~II ~ . IV J UN 21.1996 Ar rJlV '" . . f - Defendant. I IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANI I I I NO. 9~"3826 civil Term I t CIVIL ACTION " LAW I IN DIVORCE I BONNIE L. CONNOR Plaintiff I va. FREDERICK PAUL CONNOR And now thi. STIPULATION FOR ALIMONY ORDER ~ day of :J'~' f'/V'f , 1996, the partie through their undersigned attorneys hereby IiItipulate and agree a follows I 1. The parties were formerly married, and were divorced b Deoree in Divoroe, dated June 5, 1996. 2. Prior to the partielilt divorce, they exeouted a propert Settlement Agreement, dated May 14, 1996, which disposed of al olaimlil between the parties regarding equitable distribution alimony, and all other issues purliluant to their divoroe. 3. Pursuant to paragraph fifteen of said Property Settlemen Agreement of May 14, 1996, the parties agree that husband would pa alimony to wife in the amount of $3,700.00 per month. Said alimon payments are to be paid through the Domestio Relations Office 0 Cumberland county. 4. Said alimony payments are only modifiable as specificall stated in paragraph fifteen of the Property Settlement of May 14 1996, attached hereto alii Exhibit "A". MIVIIIIa DUI'OII <10 NO~TH 5!CONO ST~UT . PO lOX 1011 . HAA~I5BU~Q, M. mOl 111111...11 . ,All 171111.1117 11 or the hUHband ohull hnVQ tho right \0 ronama u livJng bonotlelury, J.5. hW:MQI'l.YI llul3lJ/lnd uhull );lny to \011/:0 alimony .1.11 \)1<' IImollllt at: $3,/00.00 per month. Baid nlJ.mony puymtlntn I;hul.l ho owod by tl10 hUl;lband to tho Wifo for tho rant of )wr Ufflt.l.ml1, 01: lJ/lt11 hcr romnrriage, or cohnbitution with a mO~Jor of tho opposito /lOX ~ln is 110t a fflmJ.ly member, or the doath at ,lithol: );lUl:ty. Tho amolJnt of tilllid ,\1 Ll\ony pnYII\<l11ts cnn be mocu' flod by Cl.l. th'll: narty whon tho husband roth'03f!, 80 10n\1 on hll doos not );otirCl prior to Ilgo f;ixty..fJ.vo. At tho t.1'I10 of l'lIlfJb,tnd'll re\:J.nlll\ont. at llgo r;ixtY-fJ.vo, b,,1:11 rJl\t'U."13 i.ncomo, 1/101u<l'\'ll'1 !lny nociRl nocllrll:y benefit8 w111 ha CO/lsidorod ill cnlcu1nt.l.ng a now Hmuunt of alimony, AdditionalJ.y, it in tho CXpr13fHl InhJl1t of tho ptlrtiel3, that the amount of alimony shall only bo modIfiable, prior to husband'n retirement at ago sixtY-fivo, In the ovont of unfot.'esoen 01: BeVf1r( circumstancos occurring to tho husband, such as a medical disability or an employment clltbnck which is beyond husband I control. It is the expross intent of the partios that the alimony payments shall only be modified at the occurrence of an unforoseel or severo evont which will cause a detriment to husband's earnin~ capacity, and, thus, his abJ.lity to pay al.i.mony in the present amount to the wife. It is f~~thot.' agreed by the parties, that Duel , , an event may wart.'ant a downward modiE.ication of the amount o. imony paid by the husband, but will not delate hia obligation t MfYfRUDUFO~ "lONOrHHSECOtlOSlnHT . 1',0 flOX IOUl . HARriISDUnG. PA 17100 (117'1360'18 . '/01. 17171130-1017 PRY alimony nltogath~r, Tho pf\rtie~l nq~'oo that theflO nlimony flllymunhi w.1.ll. IHI 11I0I,j" i.:lll::oll\lh the Domrmt.1.c llo11.\t.ionli OH .ioe of C1llnborl.nnd e:'lllllt".y, 1.6. mmA.mH If oItha!: pnrty brenchf3rl IlIlY pl.'IlV 1.ld.OIl fir III \,' AgreaIH<lnt, tho o\:h13l: party rihall have t,hll 1'1'111 t"., lit 11 III ')J' j,.. I alectJ.on, to flue fOI: rlllmagas for r:uch bt'OHdl Ill' """)( 1\\1,'11 lit II' J l'emadiefl 0):' rnl i(,f no may be av;\ilablo \:0 ldm or 11<11', ,IIJr.\ Iii.. I'" 1" I breaching thIH cunt.!:act flhall. be !:eElponsiblo for rmymntlt". of' I,"", I toes and cost.s IncllrJ:od by tho other in onl:orc.il\<1 tho {I: I: I '1ill t undF,ll: this Jlgreemant. 17. llGREllliBlf'),'-'HLt;:9NUliJlU1LEYJ;;1t.r...Q),"..DW9H!i}i11 'L'hll /:,dlIlI:II oJ oIther parts' t.o Insist upon strict performllnco of: /lny 01' till provisions of this Agreement shall not be confltl'lIad IIn II wn.1.vol: of any'subsequent default of the same or oimilnr nature. In the ovpnl that the marriage at the partiofl heroto 1.~1 termlnlltl1d by d{vol.'c/" , this Agreement shall nevortholmll, I'omnin in f\J\.I f'ol'!'!n 1111<1 nfl'nct., and shall survive Duch c!OC):(Je <lilt! nll.\l.l IlOt'. 111 /lilY WI.IY bo lI(I'OCtP-l. thereby, except as prov.irlod fot' 110)'0111. (A) Each of t.ho pm:l'.ioll uhl'l.lJ I~l'()m timo to timo, at th I I I I f... 18. lillRT.noNMdlll1J'H!.l/il':1.l',I,'f!: request of the othel', oxecuta, /ICkllow!.odqn, IIlld 11aliver to th MnVERB' DIB'O~ "10 NORTH SECONO STREET , fl. O.1I0X 10M . ('\ HJ {~ l' ~n :d "ni~1 t ..I (ta 11)' ' 'In i1l11 ~ r,\ '" 'I'~ t, "I ~;:) r'i ..,~ .1.. ,t~ . ',::;.: .! ~r ~. ~f i " ~~, ;. r , . ,I .. ::I ,., ~';! ...'. .- " ~ ~ ~ ~ ~..o .'1' "/)' .