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0 DOCKET NO. NNH FA 05-4009409 S SUPERIOR COURT

BARBARA HAMBURG JUDICIAL DISTRICT

v. AT NEW HAVEN

JEFFREY R. HAMBURG DECEMBER 23, 2009

STIPULATION

The parties hereby agree that:

1. The Judgment shall be opened and modified as follows:

a. Commencing February 1, 2010, for three years, the defendant shall pay to the
plaintiff the sum of three thousand dollars per month as alimony, which sum is
nonmodifiable for any reason;

b. The defendant shall pay to the plaintiff the sum of $245 per week $1,061.67 per
month for the benefit of the minor child Barbara Hamburg, and 67% of all
unreimbursed medical, dental, orthodontia, therapeutic and other health related
expenses. Defendant shall maintain both minor children on his health insurance
for so long as permitted under the health insurance policies and COBRA laws.

c. The plaintiff shall open an account for the benefit of the minor children. The
account shall be used to pay for the educational expenses of the minor children,
through post secondary school, excluding any graduate studies. Once both
children have graduated from college, the balance of any funds in the account
shall be divided between the children 50/50.
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d. The defendant shall pay to the plaintiff $a65OeC, plus 4% interest per annum,
until the sum is paid in full. Plaintiff shall deposit the payments received into the
account referenced above for the benefit of the minor children. The defendant
shall pay the $365060 plus interest at the following nonmodifiable rates:
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i. Commencing January 1, 2010, the defendant shall pay $1,938.33 per month
to the plaintiff for the account for the benefit of the children;
ii. In addition, if the plaintiff is receiving less than $1,061.67 per month in child
support, then the defendant shall pay the additional amount per month of the
difference between $1,061.67 and the child support paid per month;
iii. In addition, if the plaintiff is receiving less than $3,000 per month in alimony,
the defendant shall pay the additional amount per month of the difference
between $3,000 and the amount paid to the plaintiff in alimony per month;

e. All sums under a, b, and d, shall be the subject of a wage withholding.

-t-47 f. The1parties gree that tI'e mother is owecj $41,000 fo,peducationi expen!es she
pa,j for thy'minor chil9ien. The mothe/shall be e,ptitled to regburseient from
tçie accoynt establishpd for the benefi,rof the minpr children 9ereund9r, together
o 4° interest, to/be repaid to thó plaintiff rnbther from éaid acobunt at her
tith
N iscretion.
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g. The defendant shall transfer to the plaintiff any and all funds remaining in all
o accounts maintained for the benefit of the minor children including but not
limited to: UGMA and trust accounts. Defendant represents that there is a total
of $1,000. Defendant shall provide the plaintiff with statements for each account
from June 2009 to the closing of the accounts to account for the funds use. If
a defendant used any funds above $4,800 for personal use, then the additional
sum shall be added to the sum owed to the educational account under d
above. Plaintiff shall deposit the funds she receives into the account she is
establishing,Jøz- the benefit of the minor children. The defendant shall appear in
,.,2,court on Ja4Ø, 2010 to monitor his compliance with this order. Court
shall retain jurisdiction to audit the sum owed under d for sums used from July
31, 2009 under the minor children's accounts.

h. The defendant shall provide written authorization for the plaintiff and her agents
to obtain any and all information regarding cash values for life insurance policies.
The defendant shall borrow against all cash values to obtain as much money to
prepay the obligations set forth herein. The defendant shall appear in court on
2010 to monitor his compliance with this order.
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The defendant shall maintain, until all financial obligations to the plaintiff and
children under the judgment and orders of the courts are paid in full, life
insurance in the amount of $600,000, naming the plaintiff and the minor children
as irrevocable, equal beneficiaries. The defendant shall make timely payment of
all premiums on the policy. The defendant shall provide the insurer with written,

-a irrevocable authorization for the insurer to disclose any and all information to the
plaintiff. The defendant shall appear in court on Januety-, 2010 to monitor
his compliance with this order.

2. Defendant owes the plaintiff the following additional sums:

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a. $30,000 in child support arrears;
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b. $30,000 in attorney fees and costs;
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c. $25,000 toward unreimbursed medical and health related expenses; and,
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d. $25,000 toward the tuition costs for the parties' son for the payment due in
January.
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The defendant shall these sums as follows:
$25,000 on February 1, 2010;
$20,000 on March 1, 2010; °" wiG
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$20,000 on April 1,2010; `tjoç o'- e' io?O.
$20,0000nMayl,2010; U
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$25,000 on June 1, 201
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If the defendant fails to make any payment due hereunder, then the defendant shall
-J appear in court the first Wednesday after the payment is due to address his non-compliance.

.j-5-- 3.The defendant and his agents are restrained from pcssing. personal property the
U'defendant maintains in the Georgia facility. On or before J&! the defendant shall
pay the unpaid storage charges in full at the Georgia facility. The defendant shall provide to
the Georgia facility an irrevocable authorization for the plaintiff to have access and control of
the personal property. The plaintiff shall inventory and photograph the personal property. The
personal property shall be divided 50/50 between the parties. The defendant's 50% shall be
sold/auctioned and applied at the discretion of the plaintiff toward the defendant's financial
obligations hereunder, including prepayment of his obligations hereunder. The court shall
retain jurisdiction over the distribution and allocation of the personal property. If the plaintiff
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 c wants to retain personal property that exceeds her 50% share of the total value, then the
amount over her 50% shall be applied as an offset to the defendant's liabilities to the plaintiff
tt hereunder. The defendant shall appear in court on Jan'afy-.., 2010, to monitor his
compliance with this order.

4. Any remuneration received by the defendant in addition to his salary, whether a bonus
or commission, the net sum after applicable taxes and legal deductions, shall be immediately
delivered to the plaintiff to be applied toward the defendant's liabilities hereunder.

5. These orders are domestic support orders, and are in the nature of support, and are
non-dischargeable in bankruptcy. Defendant shall hold the plaintiff harmless and indemnify
the plaintiff for any and all expenses and fees she incurs to respond to any bankruptcy petition
by the defendant.

6. If the defendant violates the terms of this stipulation, and the plaintiff incurs and fees or
expenses to enforce this agreement, the defendant shall be responsible for her fees, costs,
o expenses, lost wages, and other consequential damages suffered by the plaintiff.
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7. A capias shall issue for the defendant with a cash bond in the amount of $25,000. The
capias shall be stayed. The capias shall issue upon an affidavit by the plaintiff that the
defendant has failed to comply with the terms of this agreement.
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Richard W. Ca ahan

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