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MARRIAGE SETTLEMENT AGREEMENT
V) 1~1 cl)
THIS AGREEMENT made this; day of .lL ; II , 1996,
and between John George Ferguson, (herei fter referred to
"Husband,") and Paula Sue Ferguson, (hereinafter referred to
"Wife").
WITNESSETH:
WHEREAS, the Husband and Wife were lawfully married on
September 23, 1978; and
WHEREAS, differences have arisen between Husband and Wife in
Consequence of which they intend to live apart from each other; and
WHERlIAS, one child was adopted by the HUsband and Wife,
Matthew Ian Ferguson, born on April 15, 1983; and
WHEREAS, Husband and Wife desire to settle and determine their
rights, obligations, support and custody of the child; and
NOW, THEREE'ORE, the parties intending to be legally bound
hereby do covenant and agree as follows;
1. SEPARATION
It shall be l.awful for each party at all times hereafter
to live separate and apart from the other party at such place or
places as he or she may from time to time choose or deem fit. The
foregoing provisions shall not be taken as an admission on the part
of either party as to the lawfulness or unlawfulness of the Causes
leading to their living apart.
2. INTERFERENCE
Each party shall be free from interference, authority,
and contact by the other as fully as if he or she were singlu and
unmarried except as maybe necessary to carry out the provisions of
the agreement. Neither party shall molest the other or attempt to
endeavor to molest the other, nor compel the other to cohabit with
the other, or in any way harass or malign the other, nor in any way
interfere with the peaceful existence, separate and apart from the
other, and each of the parties hereto completely understand and
agree that neither shall do or say anything to the child of the
parties at any time which might in any way influence the child
adversely against the other party.
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3. DIVISION OF PERSONAL PROPERTY
I . ", The parties have agreed to divide between them and
ah:e'ady have divided between them to their mutual satisfaction the
personal affects, household furniture and furnishings and all other
articles of personal property which heretofore have been used by
them in common. Neither party will make any claim to any such
items which are now in the possession or under the control of the
other.
4. AUTOMOBILES
The parties jointly own a 1994 Dodge Spirit and a 1973
Mercury Marquis. The Wife shall be sole owner of the 1973 Mercury
Marquis. Wife shall have all the rights and title to the vehicle.
Wife shall maintain separate insurance on her vehicle and be
responsible for any and all maintenance and/or related expenses.
Wife shall indemnify and hold Husband harmless for any claims
related to the vehicle. The Husband shall be the sole owner of the
1994 Dodge Spirit. Husband shall have all rights and title to the
vehicle. Husband shall maintain separate insurance on his vehicle
and be responsible for any and all maintenance, expenses and loan
payments related thereto. Husband shall indemnify and hold Wife
harmless for any claims related to the vehicle.
5. DIVISION OF REAL PROPERTY
The parties own no real property.
6. MARITAL DEBTS
Husband shall be responsible for the jointly incurred
debts with Circle One loan and CITIBANK VISA and all marital debts
solely in his name and Wife shall be responsible for the jointly
incurred CITIBANK MASTERCARD and all marital debts solely in her
name. Husband agrees to assume sole responsibility for the debt
with Chrysler Credit on the 1994 Dodge Spirit.
7. SHARED CUSTODY
The parties agree that they shall share legal custody of
their child. This means that the parties shall consult with each
other regarding the major parenting decisions affecting the child's
health, education and welfare.
Wife shall enjoy primary phys.ical custody of the parties'
minor. child subject to the liberal, temporary physical custody and
visitation of the Husband as follows:
2
a. During the months of September through May the 2nd
Friday through sunday of each month from after school on Friday
until the child is returned on sunday eVBning. The parties agree
that their son shall take the bus or other public transportation to
his Father's home in ohio after school on the designated Friday.
b. 'l'he sununer months shall be split wi.th Husband having
the child for the month of July each year.
c. Husband shall have the child in odd years from
.December 24 until December 28 at 2:00 p.m. and in even years from
December 28 until 2:00 p.m. January L
d. Husband shall have the child from after school
Wednesday the day beforo Thunksgiving until the Sunday evening
following Thanksgiving in even years.
e. Holidays supersede all other periods of physical
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custody.
f. At other times as the parties mutually agree.
g. Husband must notify Wife at least two (2) weeks
prior to his scheduled periods of Temporary Physical Custody if he
DOES NOT intend to exercise his rights to custody.
h. Husband and wife agree to share in the cost of the
public transportation for the trip to Ohio the second Friday of
each month during the school year. Husband shall be responsible
for and provide all other transportation for his periods of
Temporary Physical Custody.
i. Each of the parties acknowledges that the terms of
this Agreement regarding custody and visitation may be modified by
a court of competent jurisdiction upon the application or petition
of either Husband or Wife due to a change of circumstances.
8. CHILD SUPPORT
paid
each
Husband agrees to pay the wife $400.00 each month to be
$200.00 on the first of each month and $200.00 on the 15th of
month.
wife currently is providing medical coverage for the
child through her employer. wife will continue to provide the
medical coverage if such medical coverage is available at a
reasonable cost as part of her employment benefits, whether or not
such benefits are paid directly by the employer or by partial
contribution by wife. If wife is unable to provide medical
coverage through her employer, Husband agrees to cover the child
through his employer or to pay one half of the cost of providing
the child with independent medical coverage. Wife and Husband
3
agree to each pay one half of all un reimbursed and deductible
medical expenses related to their child.
The parties agree that in the event of a material change in
the cost of living or the financial circumstances of either party,
or of a change in the custody arrangements set forth herein, the
amount of the support payments shall be subject to an appropriate
adjustment by agreement or, if the parties are unable to agree, by
a Court competent jurisdiction.
9. PENSION AND RETIREMENT ACCOUNTS
Husband and Wife shall maintain their separate pension
and/or retirement accounts. Husband relinquishes any dnd all
rights he may have in Wife'S pension or retirement accounts and
Wife relinquishes any and all rights she may have in Husband's
pens~on or retirement accounts.
10. FILING OF IRS RETURN
Husband and Wife agree to file a joint tax return for tax
year 1995 and separate tax returns for all subsequent years.
11. DIVORCE
The parties, upon the expiration of the 90 day waiting
period, agree to eXf.lcute and file the necessary consents to obtain
a final Decree in Divorce under Section 3301(c) of the Pennsylvania
Divorce Code.
12. INCORPORATION INTO DIVORCE DECREE
This agreement is to be incorporated into any subsequent
Decree in Divorce.
13. CONTINUED COOPERATION
Each party agrees to execute such assignments, titles, or
other documents as may be necessary or desirable to put into full
effect the terms of this agreement and shall do so upon the
reasonable request of the other party.
14. BREACH
If either party 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, and the party breaching this
contract shall be responsible for the payment of legal fees and
costs incurred by the other in enforcing their rights under this
agreement or for seeking such other remedies or relief as may be
available to him or her.
4
15. VOLUNTARY AGREEMENT
The provisions of this agreement are fully understood by
both parties and each party acknowledges that the agreement is fair
and equitable, that it is being entered into voluntarily, and that
it is not the result of any duress or undue influence.
16. WAIVER OF CLAIMS AGAINST ESTATES
Except as herein otherwise provided, each party may
dispose of his or her property in any way, and each party hereby
waives and relinquishes any and all rights he or she may now have
or hereafter acquire under the present or future laws of any
jurisdiction to share in the property or the estate of the other as
a result of the marital relationship, including without limitation,
alimony, alimony pendente lite, counsel fees and expenses, and
right to claim equitable distribution of marital property.
17. BINDING AFFECT
This agreement shall be binding upon the parties' heirs,
s~ccesBors and assigns.
18. MODIFICATION AND WAIVER
Any modification or waiver of any of the provisions of
this agreement shall be effective only if made in writing and
executed with the same formalities as this agreement. The failure
of either party to insist upon strict performance of any of the
provisions of this agreement shall not be construed as a waiver of
any subsequent default of the same or similar nature.
19. PRIOR AGREEMENTS
It is understood and agreed that any and all prior
agreements which may have been made or executed or verbally
discussed prior to the date and time of this ~greement are null and
void and of no affect.
20. 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.
21. DESCRIPTIVE HEADINGS
The descriptive headings used herein are for convenience
only. They shall not have any binding affect whatsoever in
determining the rights or obligations of the parties.
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PAULA SUI PIRGUSON,
, P4AINTIPP
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IN THI COURT OP COMMON PLIAS
CUMBIRLAND COUNTY, PINNSYLVANIA
NO. 96 - 847 Civil Term
IN DIVORCE
v.
JOHN OIORGI PIRGUSON,
DIPINDANT.
PRAECIPE TO TRANSMIT RECORQ
To the prothonotary:
Please transmit the record, together with the following
information, to the Court for the entry of a divorce decree:
1. Ground for divorce : irretrievable breakdown under Section
3301(C) of the Divorce Code.
2. Date and manner of service of the complaint:
February 20, 1996, by certified U.S. Mail, restricted delivery, on
the Defendant.
3. Date of eKecution of the affidavit of consent required by
Section 3301(c) of the Divorce Code: by plaintiff June 27, 1996;
by defendant June 24, 1996.
4. Related claims pending:
None, the Property Settlement
Agreem~nt dated June 27, 1996 is to be incorporated into the Decree
in Divorce.
'1hcrrJfll () ~LJ".u(&'
Thomas D. Gould
Attorney for Plaintiff
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PAULA SUI 'IROUSON,
PLAINTI"
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IN THE COURT or CONNON 'LIAS
CUMBIRLAND COUNTll', 'INI/SYLVANIA
Y.
NO. 96 -
CIVIL TERN
JOHN GIORGI rIRGUSON,
DEFENDANT
IN DIVORCE
COMPLAINT UNDER SECTION 3301(c) OR
3301(d) or THE DIVORCE CODE IN DIVORCE
1. The Plaintiff is Paula Sue Ferguson who resides at 460
Brook Circle, Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. The Defendant is John George Ferguson who resides at 7
South Street, P.o. Box 23, Berlin Heights, Ohio 44814.
3. The Plaintiff has been a bona fide resident of 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 September 23,
1978 in Fayette County, Pennsylvania; however, the marriage license
was issued from Dauphin County #S-10-274.
5. There have been no prior actions of divorce or annulment
between the parties in this or any other juriSdiction.
6. The marriage is irretrievably broken.
7. The Defendant is not a member of the Armed Services of
the United States or any of its Allies.
8. The Plaintiff has been advised of the availability of
counseling and that Plaintiff may have the right to request that
the Court require the parties to partiCipate in counseling.
........ )
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II. Plaintiff reque.t. the court to enter a decree of divoroe.
.,
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"1.' ,1111"'-' /) i.. )(1/".( "
Thomas D. Gould
Attorney for Plaintiff
I.D. # 36508
2 East Main Street
Shiremanstown, PA 17011
(717) 731-1461
Fax 761-1974
I verify that the statements made in this complaint are true
and correot. I understand that false statements herein are made
,
subjeot to the penalties of 18 Pa. C.S. 4904, relating to unsworn
falsification to authorities.
Dater '/ I' III ,
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1 PS Fo,m . Doc.mbe, 1881 OtJ,I,OI'Qo '........."T"
DOMESTIC RF.TURN RECEIPT
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IN THI COURT OF COMMON P~IAS
CUMBIRLAHD COUNTY, Pf:NNSY~VAIlIA
NO. 96 - U7 Civil Term
IN DIVORCE
PAULA SUI PIRGUSON,
PLAINTIFP
JOHN GIORGI FERGUSON,
DIFINDAIlT
AFPIDAV~T OF CONSlH7
1. A Complaint in Divorce under Section 3301 (c) of the
Divorce Code was filed on September 13, 1995.
2. The marriage of plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of the
filing and serve of the Complaint.
3. I consent to the entry of a Final Decree of Divorce after
service of notice of intention to request entry of the decree. I
acknowledge that pursuant to Rule 1920.42(e) I have waived the
requirement that I receive notice of intention to request entry of
the decree.
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 subject
to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
DATED:
fA /J?/'1J.
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Paula Sue P guaoD .
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'AULA SUI ,IRGUSON,
PLAINTIrr
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IN THE COURT or COMMON PLIAS
CUMBIRLAND COUNTY, PINNSYLVANIA
NO. 96 - 847 Civil Term
JOKl GIORGI FIRGUSON,
DIPENDANT
IN DIVORCE
AFFIDAVIT or CONSENT
1. A Complaint in Divorce under Section 3301(c) of the
Divorce Code was filed on September 13, 1995.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of the
filing and serve of the Complaint.
3. I consent to the entry of a Final Decree of Divorce after
service of notice of intention to request entry of the decree. I
acknowledge that pursuant to Rule 1920.42(e) I have waived the
requirement that I receive notice of intention to request entry of
the decree.
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 subject
to the penalties of 16 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
DATED I
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