Robert J. Sugarman - Page 3

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          property in Pineville, Pennsylvania (Pineville property), which             
          they owned jointly.  At some point in the relationship, marital             
          difficulties arose.  In January 1989, petitioner and Colleen                
          entered into a separation agreement (the agreement).  The                   
          agreement includes, inter alia, custody provisions, support and             
          alimony provisions, and property distribution provisions.  The              
          property distribution provisions provide, in part, for the sale             
          of the Pineville property.  Those provisions also provide for               
          Colleen to receive specified amounts from the sale and contingent           
          possibilities if no sale is completed.  The agreement further               
          states that it "shall be binding and shall inure to the benefit             
          of the parties hereto and their respective heirs, executors,                
          administrators, successors and assigns."  Pursuant to its terms             
          and the subsequent divorce decree, the agreement was incorporated           
          into, but not merged with, the divorce decree.  Approximately 1             
          month later, petitioner and Colleen were divorced pursuant to a             
          decree dated February 10, 1989.                                             
               On May 11, 1989, petitioner offered to pay Colleen, in                 
          return for her interest in the Pineville property, a lump sum of            
          $20,000, and $20,000 over 2 years in equal monthly installments             
          of $833.33.  In July 1989, petitioner and Colleen entered into an           
          agreement entitled "Addendum to Property Settlement Dated January           
          11, 1989 Between Robert J. Sugarman and M. Colleen Sugarman" (the           
          addendum), which modified the agreement.  The addendum was                  
          written expressly to replace the provisions of the agreement                




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