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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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STATE OF ~~ PENNA.
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JANET S. SGRIGNOLI,
Plaintiff
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RONALD R. SGRIGNOLI,
Defendant
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DECREE IN
DIVORCE
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AND NOWo ' , , , , . , , , , ,'J?~,~t-, . , //.~ '. 19. W-",. it is ordered and
decreed that.". J,ANET. ,s~. S~RIGN()LI"""""""."""". plaintiffo
and".""""" ,RON~LD. R,', .SG~,I~~~~I"""""""."",. defendant,
ore divorced from the bonds of matrimony.
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The court retains jurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet
been entered;
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. At.l . issues r.esol v:ed b.Y: Mar,rialli! ,~et,tl~~!!,~t ,~$I,z:~e!ll!~t;., !i,~~~~, , , ,
Nov:eabe,r . 8 ~, 1996, .whi.ch. is. .here.b~, i,~':~~!?,~~~~~,~ , ~!1,t,~~ , ~.~~ . ~~~ ,
aerged with this Decree
n y The Co u r I :/
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INOIl(
P.e
1. partie. to Live Separate and Apart 2
2. per.onal property 2
3. P.M.T. Sgrlgnoll. partnership !
4. Marital Debts !
5. Real Property 4
6. Alimony, Alimony pendente Lite, SpousalSupport 5
7. custody and Visitation 5
8. Internal Revenue Service Tax Deductions for the
Minor Children 7
9. Legal Representation 7
10. Mutual Discharge 7
11. Execution and Delivery of Documents 8
12. Breaching party Pays Costs 8
13. General Provisions 8
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MARRIAGE SmLEMENT AGREEMENT
THIS AGREEMENT, made Ihis day of , 1996, by and between
JANET S, SGRIG"lOLlo hereinafter referred 10 as ''WIFE''o and RONALD R. SGRIGNOLlo
hereinafter referred to as "HUSBAND",
WITNESSETH:
WHEREAS, the parties hereto are Husband and Wifeo having been married September
11, 1980; and
WHEREAS, the parties have three minor children born of this marriage, Thomas,
Taylor and Travis; and
WHEREAS, differences have arisen between Husband and Wifeo as a result of which
it is the desire of the parties after long and careful considerationo amicably to adjust,
compromise and settle all property rights and all rights in, to, or against each otheros
property or estateo including property heretofore or subsequently acquired by either party,
and to settle all disputes existing between themo including any and all claims for
maintenanceo supporto alimony, equitable distribution, custodyo counsel fees, and costs; and
WHEREAS, it is the mutual desire of Husband and Wife to reduce their agreement
to writing; and
NOW, THEREFORE, in consideration of the mutual promises, covenants, and
agreements hereinafter contained, each of the parties hereto, intending to be legally bound
hereby promises, covenantso and agrees as follows:
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1.
(Parties 10 live Seoarale and Aoartl
The parties mUlually agree 10 live separale and aparl as Ihough the parlles had not
been married. Neilher parly will molesllhe other, or compellhe other 10 cohabil or in any
way harass or malign the olher, nor in any way interfere wilh the peaceful existence of Ihe
other.
2.
(Personal Prooertvl
Husband and Wife have divided all personal properly, which would constilute
marital property. Wife agrees that any property in the possession and control of Husband
at the time of the signing hereof shall be the sole and separate property of Husband; and
Husband agrees that all property in the possession and control of Wife at the time of the
signing hereof shall be the sole and separate property of Wife.
Wife agrees to accept sole ownership of the parties 1993 Ford Aerostar Van which
constitutes marital property, In consideration for the Vano Wife will pay Husband the fair
market value at the time Wife disposes of the 1993 Ford Aerostar Van.
Each of the parties does hereby specifically waive, release, renounce and forever
abandon whatever c1aimso if any, he or she may have to the sole and separate property of
the other.
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3.
F .M. T. SeriID10Ii - PartnenhiD
The parties acknowledge that they are part owner in a general partnership identified
as F.M,T, Sgrignoli and that the apprdised vdlue exceeds $5000000:
(al Wife hereby agrees to accept $1200000 in her inlerest in lhe marilal portion
of lhe partnership,
(bl Wife hereby waiveso assigns and lransfers all of her rightso litle and interesl to
Husbandos inlerest in F,M.T. Sgrignoli,
(c) Husbdnd agrees to pay the Wife an initial paymenl of $70500.00 al time of
settlemenl on lhe sale of lhe parties mdrital home which is scheduled for Mondayo October
28, 1996; followed by monlhly pdymenls of $500.00 for lhe firsltwenty-four monlhs lhen
$1,000,00 for the monlhs twenty-five through one hundred and twenty six. Paymenl will
be made lhe first of every month following lhe entry of a final divorce and should lhe
monthly paymenl of S 1,000.00 be reduced for any reason 10 include an increase in child
support, lhen lhe monlhly payment to wife will be exlended to a period of time to complete
pdymenl of $1200000.
4.
(Marital Debts)
Husband and Wife each covenant, represenl and agree lhat each will now and at all
limes hereafler hold harmless and keep the other indemnified from all debtso charges and
liabilities incurred by the other prior 10 or afler lhe effeclive dale of lhis Agreemenlo except
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as may be otherwise specifically provided for by the terms of this Agreement.
Husband and Wife acknowledge that they have existing debt which will be satisfied
with the proceeds from the sdle iJf the marital home:
(a) 1993 Aerostdr Van car loan; account number 40020010397636with the PNC
Bank;
(b) Mdster Card; account number 528600281297515, current balance in excess
of $5,000;
(c) VISA; account number 4121741285282476, current balance in excess of
$1,900;
(d) J,c, Penney; account number 024111-786-0, current balance $300;
(e) Sears; account number 5484-103 543-857, current balance in excess of
$1,600; the parties agree that these debts will be satisfied with the proceeds from the sale
of the marital home.
(f) PP&L bill to be determined at time of closing.
(g) Horn Hospital bill.
5.
(Real Prooertvl
Husband and Wife agree that the said premises be listed for sale at a price acceptable
to both parties, Upon sale of the premises the net proceeds after deductions of all expenses,
fees and taxes in connection with the sale and after satisfaction of the line of credit with
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Harris Bank the proceeds shall be divided equally between the parties. In conjunction with
the prime line with the Harris Bank the F,M.T. Sgrignoli Partner~hip line of credit which is
approximately $360000 shall be satisfied before the proceeds are divided 50/50. Wife will
receive no less than $62,000.00 regardless of the net proceeds realized at time of closing
which is scheduled for Mondayo October 28, 1996,
6.
!Alimonv. Alimonv Pendente Lite and Soousal Support)
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Husband and Wife are presently employable and waive all claims against the other
for maintenanceo spousal support, alimonyo or alimony pendente lite which may arise out
7.
of the marital relationship.
(Custodv and Visitationl
The parties, believing that it is in the best interests of their children for the parties to
determine custody and visitation issues by agreement, have agreed to share legal and
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physical custody as follows:
The parties shall share physical legal and physical custody of the parties children.
The parties shall share as partial custody shall be ratified along a 50/50 split of the time and
that the children will spend approximately 50 percent of their time the mother and
approximately 50 percent of their time with the father. The parties further agree that the
above schedule may be adjusted between the parties to accommodate work or vacation
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schedules.
The parties' minor children, shall reside with the Wife. The parties agree that the
Husband shall have custody at mutually convenient times. The parties further agree that the
above schedule may be adjusted between the parties to accommodate work or vacation
schedules or family plans.
The parties agree that it is in the best interests of the children to work together and
to look primarily to the children's best interests in arranging temporary custody and
visitation. To that end the parties agree that this minimum schedule may be modified at any
time by either party with the consent of the other. Wife will provide health insurance
coverage when it is provided at no cost to wife through her present employer.
Husband agrees to pay Wife $500 per month for child support, commencing the 1"
month followins separations. Child support payments are due on the first of each month.
If Wife seeks an increase in child support then the increase will have a dollar for dollar
offset to the $ 1,000.00 per month Wife is receiving pursuant to paragraph three (3).
Husband retains the option to seek modification of the amount of support he pays
under this Agreement based on changed circumsta.lces, including but not limited to the
following: (1) an child attaining the age of eighteen (18); graduation from high school; or
the Husband having physical custOOy of one or more of the children for more than 50% of
the time.
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,...11
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8.
IIntemal Revenue Service Tax Deductions for the Minor Childrenl
The parties agree that the Plaintiff, Janet S. Sgrignoli, shall use Taylor Sgrignoli as a
tax deduction for each year beginning in 1996 and that the Husband, Robert R. Sgrlgnoli
shall be entitled 10 use the parties other minor children, Thomas and Travis Sgrignoli.
9.
(LeRal Reoresentationl
Husband and Wife declare that each has had a full and fair opportunity to obtain and
consult with legal counsel of his/her selection and that the parties, cognizant of their legal
rights, declare and express that:
a) Wife is represented by Austin F. Grogan, Esquire; and
b) Husband, is represented by Keith O. Brennenan, Esquire.
10.
{Mutual DischarJ!.el
Wife relinquishes her inchoate intestate right in the estate of Husband, and Husband
relinquishes his inchoate intestate right in the estate of Wife, and each of the parties hereto
for himself or herself, his or her heirs, executors, administrators or assigns does remise,
release, quitclaim 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 of law or in equity of whatsoever kind or nature for or because of
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a matter or thing done, omitted or suffered to be done by said party prior to and including
the date hereof, except that this release shall in no way exonerate or discharge either party
hereto from the obligalions and promises made and imposed by reason of this Agreement.
11.
lExecution and Delivery of Documents)
The parties hereto agree to execute and deliver all papers needed to effectuate the
terms and intentions of this Agreement.
12.
lBreachinR Partv Pays Costs)
If either party breaches any provisions of this Agreement, the other party shall have
the right, at his or her election, either to sue for specific performance or for damages for
such breach, and the party breaching this Agreement shall be responsible for reasonable
legal fees and costs incurred by the other in enforcing his or her rights under this
Agreement.
13.
lGeneral Provisions)
This Agreement shall be binding and inure to the benefit of the parties hereto and
their respective heirs, executors, administrators, successors and assigns.
This Agreement encompasses all agreements between the parties concerning the
matters set forth herein and may not be altered or omitted except in writing executed by the
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parties; the waiver of any term, condition or provision of this Agreement shall in no way
be deemed a waiver of any other term, conditions or provisions of this Agreement.
If any term, condition or provision of this Agreement shall be determined to be void
or invalid in law or otherwise, then only that term, condition or provision shall be stricken
from this Agreement, and in all other resJ)ects, this Agreement shall be valid and continue
in full force.
It is agreed by and between the parties hereto that this Agreement shall survive and
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shall not be merged into any decree, judgment, or order of divorce or separation. It is
specifically agreed, however, that a copy of this Agreement or the substance of the
provisions thereof, may be incorporated, by reference, into any divorce, judgment or decree.
This incorporation, however, shall not be regarded as a merger, it being the specific intent
of the parties to permit this Agreement to survive any judgment and to be forever binding
and conclusive upon the parties.
This Agreement shall be construed under the laws of the Commonwealth of
Pennsylvania.
This Agreement is executed in triplicate, and Husband and Wife, as parties hereto,
acknowledge the receipt of a duly executed copy hereof.
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IN WITNESS WHEREOf, the parties hereto have set their hands and seals the date
first above written.
( ):.t/4J.~1lblG
Janet s. Sgrignoli (
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Ronald R. Sgrign
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Keith O. Brennenan, Esquire
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COMMONWEALTH OF PENNSYLVANIA
55
COUNTY OF CUMBERLAND
On this, the ~ day of \1o........\a.w- . 1996, before me, the undersigned
officer, Janet S. Sgrignoli personally known to me (or satisfactorily proven) to be the person
whose name is subscribed to the within Agreement, and acknowledged that she executed
the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal.
~~
Nota blic
NOTARIAL SEAL
EUlABETH HALLETT. Nolary Public
Camp Hill illlro. Cumberland Cou~1y
My Commission Expires May 15, 2000
COMMONWEALTH OF PENNSYLVANIA
55
COUNTY OF CUMBERLAND
On this, the ,. tL day of ntIVC......L~, 1996, before me, the undersigned
officer, Ronald R. Sgrignoli personally known to me (or satisfactorily proven) to be the
person whose name is subscribed to the within Agreement, and acknowledged that he
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal.
C----;) .-r . . 0. --I"
..::-::rli.-OtU".u - . ~
Notary Public
Nnlm1:1ISoJ.1
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v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 'I (. (; alA C-J...;..;f Tt"",-
JANET S. SGRIGNOLI,
Plaintiff
RONALD R. SGRIGNOLl,
Defendant
IN DIVORCE
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim set
forth in the following pages, you must take prompt action. You are warned that, if you fail
to do so, the case may proceed without you and a decree of divorce or annulment may be
entered against you for any other claim or relief requested in these papers by the Plaintiff.
You may lose money or property or other rights important to you, including custody or
visitation of your children.
When the ground for divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counselling. A list of marriage counselors is available
in the Office of the frothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU
MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
LARRY WEI.KER, PROTHONOTARY
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
(717) 697-0371
"
JANET S. SGRIGNOLl,
Plaintiff
IN THE COURT OF COMMON PLEAS Of
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO <;1.. quI. C<"~'L~ TtL'~
.
RONALD R. SGRIGNOLl,
Defendant
IN DIVORCE
COMPLAINT
1.
The Plaintiff is JANET S. SGRIGNOLl, who currently resides at 22
..
SHERWOOD CIRCLE, ENOLA, Cumberland County, Pennsylvania 17025.
2. The Defendant is RONALD R. SGRIGNOLl, who currently resides at
22 SHERWOOD CIRCLE, Enola, Cumberland County, Pennsylvania 17025.
3. Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing
of this Complaint.
4. Plaintiff and Defendant were married on September 11, 1980 in
Cumberland County.
COUNT I - DIVORCE
5. Paragraphs 1 through 4 of this Complaint are incorporated herein by
reference as though set forth in full.
6. There have been no prior actions of divorce or for annulment between
the parties.
7. Divorce is sought pursuant to the provisions of the Divorce Code,
Sections B01(c), in that:
a) The marriage is irretrievably broken;
8. The Plaintiff has been advised of the availability of counselling and of
the Plaintiff's right to request that the Court require the parties to participate in counselling
and does not request same.
9. Defendant is nOl a member of the armed services.
WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in
Divorce, divorcing Plaintiff and Defendant.
COUNT II - EQUITABLE DISTRIBUTION
10. Paragraphs 1 through 4 of this Complaint are incorporated herein by
reference as lhough set forth in full.
11. Plaintiff and Defendant have acquired property, both real and personal,
during their marriage from September 11, 1980, unlil which property is "marital property".
12. Plaintiff and Defendant may have owned, prior to the marriage,
property which has increased in value during the marriage and/or which has been
exchanged for other property, which has increased in value dl.'ring the marriage, all of
which property is "marital property".
13. Plaintiff and Defendant have been unable to agree as to an equitable
division of said property prior to the filing of this Complaint.
WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all
marital property.
.COUNT III - ALIMONY PENDENTE LITE AND ALIMONY
14. Paragraphs 1 through 4 of this Complaint are incorporated herein by
reference as though set forth in full.
15. Plaintiff lacks sufficient property to provide for her reasonable means
and is unable to support herself through appropriate employment.
16. Plaintiff requires reasonable support to maintain herself adequately in
accordance with the standard of living established during the marriage.
WHEREFORE, Plaintiff requests your Honorable Court to enter an award of
alimony pendente lite until final hearing and thereafter to entel' an award for alimony.
COUNT IV - COUNSEL FEES AND COSTS
17. Plaintiff has retained the Law Offices of Austin F. Grogan but she is
unable to pay the necessary and reasonable attorneys' fees for said counsel.
18. Plaintiff may need to hire experts to appraise the marital property but
she lacks funds to pay the necessary and reasonable fees.
WHEREFORE, Plaintiff requests your Honorable Court 10 enter an award of
interim counsel fees, costs and expenses and to order such additional sums hereafter may
as may be deemed necessary and appropriate and at final hearing to award such additional
counsel fees, costs and expenses as are deemed necessary and appropriate.
Respectfully submitted,
.
Date:j~,,,, ,4t"
Austin F. Gro n,
24 North 32n . 5 et
Camp Hill, PA 17011
(717) 737-1956
Attorney for Plaintiff
Attorney #10 59020
VERIFICATION
I, JANET S. SGRIGNOLl, verify that the statement~ made in the foregoing
Complaint are true and correct to the best of my knowledge, Information and belief. 1
understand that false statements made herein are made subject to the penalties of 18 Pol.
C.S. Section 4904, relating to unsworn falsification to authorities.
~~~
NET S. SGRIG LI
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v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96-906 CIVIL TERM
JANET S. SGRIGNOLI,
Plaintiff
RONALD R. SGRIGNOLI,
Defendant
IN DIVORCE
ACCEPTANCE OF SERVICE
I accept service of the Complaint filed in the above matter
on behalf of Defendant Ronald R. sgrignoli and certify that I am
authorized to do so.
SNELBAKER & BRENNEMAN, P. C.
~
By:
Ke th O.Brenneman, Esqu re
44 West Main St~eet
Mechanicsburg, PA 17055
(717) 697-8528
Attorneys for Defendant
Ronald R. sgrignoli
Date: March 13, 1996
L-'W or"c[s
SNIELDAKER
&
BRENNEMAN
CORRECTION
Previous Image
Refilmed to Correct
Possible Error
. . .
. , . .
CERTIFICATE OF SERVICE
I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have,
on the below date, caused a true and correct copy of the
foregoing Acceptance of Service to be served upon the person and
in the manner indicated below:
FIRST CLASS MAIL. POSTAGE PREPAID. ADDRESSED AS FOLLOWS:
Austin F. Grogan, Esquire
24 North 32nd Street
camp Hill, PA 17011
J~e.qUir'
SNELBAKER & BRENNEMAN, P. C.
44 West Main street
P. o. Box 318
Mechanicsburg, PA 17055
(717) 697-8528
Attorneys for Defendant
Ronald R. Sgrignoli
Date: March 13, 1996
l,...4oW O'I'ICI':..
5NEL8A~ER
llt
BRENNEMAN
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