HomeMy WebLinkAbout96-01092
'~
1
J
J
~
I
,
~
"
'''4:1
'l.;'i\t~:o..
'^<.;
".
,
;
I
1
I
i
!
i
I
1
"i I
~~.~. i
" .....
,:
".
0--
.\
, ~i
f':
I
,
l
~~~~~~~~~__~~~~~~~~a.~_~a~a___~
a. -----..----.-.---- '-.'-- ..." '-' -".-' ..' . .--.- ....... ....... ...-....-....-- ...-. .-...--.----...i.
: i l.
~i l'
~I .*
*i IN THE COURT OF COMMON PLEAS *
~! OF CUMBERLAND COUNTY ~
81 *
a' ""~ ~
~i STATE OF ~~ PENNA, ~
~i ~
I
~! ~
~i GEORGE L, SITES '- 96-1092 CIVIL TERM ~
1 "" II. . I')
~ Plaintiff ~
~I \', r'''.. .
~ RENEE D. SITES .
a. ~
Defendant iI,I
a iI
,:, i~
~
x
~I
: I
~I
!I
8
(l
.
~
*
~
~
~
8
..
ill
~
~
$
8
~
~I
-;
'1__.-- "'.
-... ... {jOt. .>>t. .
DECREE IN
DIVORCE
ANDNOW,....j.~...'}.L..... 19.i~... it is ordered and
decreed that.. ....Georg~.L...S~tes........... .......... plaintiff,
and. . . . . . . . . . . . . . . . . . Re.n.et;!. D.,. . S it.es. . . . . . . . . . . . . . . . . . . . . '. defendant,
are divorced from the bonds of matrimony.
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; Nane. The Property Settlarent and Separation Agrearent
af the Parties dated DecartJer 10. 1997 attached hereto. as Exhibit "A" and
incorporated herein by reference shall have the sane farce and effect as
if' it had beeh' bri~lihallY Elnhlr'ed as 'an Or'detcjf .the 'COUrt 'provided; '1iD~Ver.
t:~t:. t:~. ~a,id.I\g;r~flt shp.ll, flo.t, ~r:ge .~i,tl"\ .tl1.i.!\ .Qt::cl€lrQ4t: .!\h4l.l. .J;"et:q.i.n. .
its constractual value.
./
n v Th e C" u r I :
. \--iJ. Uvf
Alle.I'..... . \., '.o'~ //;1/ -/
-tt.-.c-.!4J .,. .......--t.~fr. .<...~/.~'J.',..I.l"-y
:). . -' I./,.! "),, 7" :/
'I.-;i'( ".h f ,.~e::;.~" Prothonotary
~
.
.
.
lM
I.
.
.
8
.
l~
(.
I,;,
iil,l
I::,
/...
1 :
'~
.~
:~
, .
;~
, .
jl
J.
~
~
.~
.'.
- ~
~~~~.~.~.~,~,~.~.,~.~.~~..~.~..~..~.*.~..~
~
.
~
.
,
'. '.
(2) Except as herein otherwise provided, each party hereby
relea~es the other from any and all claims, or demands up to the
date of execution hereof.
(4) In the event that either party contracted or incurred any
debts since the date of separation in July 31, 1995, the party who
incurred said debt shall be responsible for the payment thereof
regardless of the name in which the account may have been charged.
Husband and Wife acknowledge and agree that they have no other
outstanding joint debts and obligations of the Husband and Wife
incurred prior to the signing of this Agreement, except as follows:
A. None,
Each party agrees to pay the outstanding joint debts as set
forth herein and further agrees to indemnify and save harmless the
other from any and all claims and demands made against either of
them by reason of such debts or obligations.
(5) The marital assets of the Parties consists of the
following:
A. Household furnishings and personal property
B, Bank. accounts in each parties name alone not in
excess of $1,000.00
C. 1986 Oldsmobile Sedan in Husband's name alone
D. 1983 Subaru in wife's name alone
E. A 401K retirement plan in Husband's name alone having
an approximate value as of March 31, 1997 in the
amount of $2,111.38, a statement of which is attached
and incorporated herein as Exhibit "A".
2
.
..
.
'1 t.
F. A WMX Technologies, Inc., Employee Stock Ownership
Plan in Husbands name alone havinq a vested value
as of March 31, 1997 in the Amount of $.00, a
statement of which is attached as Exhibit "C."
(6) Husband is currently employed at Waste Management of
Central PA and earns approximately $369.00 per week gross salary
not including overtime,
A statement of Husband's weekly pay is
attached and incorporated herein as Exhibit "B".
(7) Each party relinquishes any right, title and interest he
or she may have to any and all motor vehicles currently in
possession of the other party.
Each party shall execute any
documents necessary to have said vehicles properly registered in
the other party's name with the Pennsylvania Department of
Transportation. Each party shall assume full responsibility of any
encumbrance on the motor vehicle received by said party, and shall
hold harmless and indemnify the other party from any loss thereon,
The Parties agree that Husband shall retain as his sole and
separate property the 1986 Oldsmobile now in his name alone, and
Wife shall retain as her sole and separate property the 1978 Chevy
Caprice now in her name alone. The Parties acknowledge that the
1983 Subaru in Wife's name alone has been replaced by the 1978
Chevy Caprice set forth above.
(8) The parties hereto mutually agree that they have effected
a satisfactory division of the furniture, household furnishings.
appliances. tools and other household personal property between
them, and they mutually agree that each party shall from and after
the date hereof be the sole and separate owner of all such property
presently in his or her possession whether said propel.ty was
3
.
4.
.
.
heretofore owned jointly or individually by the parties hereto.
This agreement shall have the effect of an assignment or bill of
sale from each party to the other for such property as may be in
the individual possession of each of the parties hereto.
(9) Each party hereby relinquishes any right, title or
interest he or she may have in or to any intangible personal
property currently titled in the name of or in the possession ot
the other party, including, but not limited to, stocks, bonds,
insurance, bank accounts and retirement accounts. Husband shall
retain as his sole and separate property the 401K retirement plan
and WMX Technologies, Inc. Employee Stock Ownership plan both of
which are currently in Husband's name alone, statements of which
are attached and incorporated herein as Exhibit "Au and "C"
respectivaly. wife specifically waives any right, title or
interest that she may have in Husband's said 401K retirement plan
and said Employee Stock Ownership plan as a result of the marriage
or otherwise, Upon Husband's demand, Wife agrees to promptly
cooperated and provide any signatures or documentation necessary to
effect the above waiver.
(10) The parties agree that legal custody of their two (2)
minor children of the marriage, Rebecca Ann Sites and Cory Michael
Sites, shall be joint, with both parties having the right to make
major parenting decisions affecting the children's health,
education and welfare.
Wife shall have primary physical custody of the children.
Husband shall have partial custody for purposes of visitation.
Husband shall have liberal visitation rights at the times the
Parties may agree. In the event the Parties are unable to agree to
4
.
.
'.
reasonable visitation, either Party may apply to a court of
competent jurisdiction to enter an Order determining custody and
visitation rights of the Parties.
Neither party shall remove the child from the Commonwealth of
Pennsylvania for the purpose of relocating without first having
obtained the written consent of the other party. Both Parties
agree to promptly inform the other of any change in residence of
either party including address and telephone number. If either
party intends to travel with the child outside the Commonwealth of
Pennsylvania for vacation or other purpose, said parent shall
provide the other parent with written notice of the destination of
the child and the telephone number and specific address where the
child can be located.
(11) The Parties acknowledge and agree that the Support Order
entered to Cumberland County Court of Common Pleas Docket Number
1306-8-1995, as amended, shall remain in full force and effect
subject to the review and modification of same from time to time by
the Court or by application by the Parties to the Court for such
modification as provided by Pennsylvania Law. The parties
acknowledge and agree that the said Support Order requires Husband
to pay to Wife support for the care and maintenance of the parties'
minor children; namely, Rebecca Ann Sites and Cory Michael Sites as
well as Veronica Lynn Martin, being Wife's child to a previous
relationship. Husband disputes paternity of Veronica Lynn Martin.
(12) Husband currently maintains three li fe insurance po lie ies
through his place of work listing the parties minor children as
5
.
..
.. ..
insureds in the amount of $2,500.00 each. Husband shall continue
to maintain said life insurance policies as to each child and
continue to maintain wife as the beneficiary of the policies until
the child reaches 18 years of age, provided the policies are
continued to be offered to Husband through his employer at the
current rates.
(13) Except as otherwise provided herein, Husband shall not
pay to Wife nor Wife to Husband any sum whatsoever as alimony,
alimony pendente lite, or for his or her support or maintenance.
(14) Each party shall pay his or her own legal fees for all
legal services rendered or to be rendered on his or her behalf,
(15) Neither party shall contract or incur any debt or
liability for which the other party or r.is or her property or
estate might be responsible and shall indemnify and save the other
party harmless from any and all claims or demands made against him
or her by reason of debts or obligations incurred by the other
party,
(16) Each of the parties shall from time to time, at the
request of the other, execute, acknowledge and deliver to the other
party any and all further instruments that may be reasonably
required to give full force and effect to the provision of this
Agreement,
(17) The parties do hereby warrant, represent, acknowledge and
agree that each is fully and completely informed of, and is
familiar with, the wealth, real and personal property, estate and
assets, earnings and income of the other and that each has made a
6
..
.
..
full and complete disclosure to the other of his and her entire
assets and liabilities and any further enumeration or statement
thereof in this Agreement is specifically waived.
(18) Husband and Wife acknowledge that each of them has read
and understand his and her rights and responsibilities under this
Agreement and that they have executed this Agreement under no
compulsion to do so but as a voluntary act.
(19) It is further specifically understood and agreed by and
between the parties hereto that each party accepts the provisions
herein made in lieu of and in f~ll settlement and satisfaction of
any and all of said party's rights against the other for past,
present and future claims on account of support, maintenance.
alimony, alimony pendente lite. counsel fees. costs and expenses,
equitable distribution of marital property and any other claims of
each party. including all claims which have been raised or may be
raised in an action for divorce.
(20) Except as may be otherwise specifically provided in this
Agreement. Husband and Wife, for themselves. their hei....s.
representatives and assigns. each hereby forever releases. remises.
discharges and quitclaims the other, and such other's heirs.
representatives, assigns and estate, from and with respect to the
following:
A. All liability. claims, causes of action. damages,
costs, contributions, expenses or demands whatsoever in law or
in equity;
7
.
...
B. All rights, title, interest or claims in or to any
property of the other, whether real, personal or mixed and
whether now owned or hereafter acquired;
C. All rights of curtesy and dower and all claims or
rights in the nature of curtesy and dower;
D. All widow or widower's rights;
E. All rights, title and interest or claims in or to
the other's estate, whether now owned or hereafter acquired,
including but not limited to all rights or claims:
(1) to take against the other's will;
(2) under the laws of intestacy;
(3) to a family exemption or similar allowance;
and
(4) all other rights or authority to participate or
intervene in a deceased spouse's estate in any way,
whether arising under the laws of Pennsylvania or any
other country, territory, state or political subdivision,
F. All rights or claims to any accounting;
G. All rights, claims, demands, liabilities and
obligations arising out of or in connection with the marital
relationship or the joint ownership of property, whether real,
personal or mixed;
H. All rights, claims, demands, 1 iabil i ties and
obligations arising under the provisions of the Pennsylvania
Divorce Code, Act 26 of 1980, as the same may be amended from
time to time, and under the provisions of any similar statute
8
..
..
enacted by any other country, state, territory or political
subdivision;
I. All rights, claims, demands, liabilities and
obllgations each party now has, or may hereafter have, against
or with respect to the other.
(21) This Agreement shall be construed under the law of the
Commonwealth of Pennsylvania. If any provision of this Agreement
is determined to be invalid or unenforceable, all other provisions
shall continue in full force and effect.
(22) A decree in divorce, entered by a court of competent
jurisdiction to either Party, shall not suspend, supersede or
affect the terms of this Agreement. Both Parties agree to enter a
Consent Order or orders concerning the provisions of this Agreement
in the Court of Common pleas of Cumberland County, Pennsylvania, or
any other Court of competent jurisdiction, as a part of a
resolution of any divorce action filed or to be filed. This
Agreement, and the terms and conditions contained herein, as well
as the enfercement of said terms and conditions, shall not be
contingent upon the granting of a Divorce Decree to either Party by
the Court of Common Please of Cumberland County, Pennsylvania, or
any other Court of competent jurisdi.ction. Furthermore, both
Parties hereto agree to timely execute the appropriate affidavits
and consents to secure a No-Fault Divorce as may be required by the
Divorce Code ef 1980, as amended. Both Parties hereto agree that
this Agreement may be incorporated into a separate court Order but
shall not merge in such order in the Court of Common pleas of
9
~.
Dauphin County, Pennsylvania.
(23) Husband and Wife acknowledge that Husband has instituted
a No..Fault Divorce Action docketed to No. 96-1092 in the Court of
Commo:! Please of Cumberland County, Pennsylvania, pursuant to
3301(c) of the Pennsylvania Divorce Code, Act 26 of 1980, as may be
amended (hereinafter referred to as the "Code"). The provisions of
this Agreement may be incorporated in any divorce decree that may
be entered granting a decree of absolute divorce.
(24) In the event that either party breaches any provision of
this Agreement, and the other party retains counsel to assist in
enforcing the terms thereof, the parties hereby agree that the
breaching party will pay all attorney's fees, court costs and
expenses incurred by the other party in enforcing the Agreement.
(25) This Agreement constitutes the entire understanding
between the parties and there are no covenants, conditions,
representations, or agreements, oral or wl:'itten, of any nature
whatsoever, other than those herein contained.
(26) This Agreement shall bind the parties hereto, their
respective heirs, executors and assigns.
(27) Husband has been independently represented by Karl M.
Ledebohm, Esquire, of the Law firm of Saidis, Guido, Shuff &
Masland, and Wife, cognizant of her right to legal representation
and having had full opportunity to obtain counsel, declares that it
is her express voluntary and knowing intention not to avail herself
of independent counsel and chooses instead to represent herself
with respect to the preparation and execution of this Agreement.
10
-.
,'. ....
Punt "Y Output
,16J5S1 'nRi NO 94090' SaE9'ji)
Capley D.vice rAPe J!lst
u.., WM990CLW
BSVl o J8 ~ 71111-:"8 HT-seR UOfiOBIU
,'a.M.
P.q. l
.. ~j 1: Hdl)t1L
i I; 1 Ii : Sl) ~ 1 . J ~ 1 ~ iJ 'j
HEO, To-Oat. I~1uiry
SITES IR, i~EI)H\;E L
HEO D.lcr lpt lan
001 R.EGUUA
Cl.J.rrent Honth QU.4=tU' \le4r
)69.00 1, \ 'S. 40 J,3.:').4Ij I J , ~ I ~ , 1:)
40.00 160.00 hlJ,lJ1; l.li8u ,00
11)0.'7 H....l 1."'Ll6 7,'jOLlI6
11.44 40.00 101), H H7.IU
.00 .00 .00 J,407.'H
.00 .00 .00 l'1!1.0
.00 .00 .00 ~. 26
.00 .00 .00 .00
.00 .00 .00 .00
.00 .00 .00 .00
Mel'
HOURS I
001 PREHIUM 1.S
U1t"
HOURS,
o La PREHIUM 1. (I
.\at a ,
HOURS_
048 INCENTIVE PAY
.wt"
HOURS I
060 BONUS
AIIt"
HOURS I
ENTER I JT-SCR Tax.. To-Date Inqulry
Prin~ Key Output
5763551 V3RIHO '''Qga~ SI~E9~O
P4QfJ
~~l=~:'n l':lC,:B
Di.play Cevic. TJUlCHSI
U..r WH9 ') OC LW
as'/:' Ola7 77877'8 HT-S.:a 180li081IH 1] 11111;' 11-25 1109
HEDIo To-Olt. Inqui.ry SoUl JR, GEORu[ to
HH' O~~n,ptlon
CGe BOIIU S ~urr.nt H,,'nth QU4L.ter )"lt4t"
.\IDtal .00 .00 .::11; .00
HaURSl .00 0' .1)0 . ,')0
07:.1 SPECIAL PAY
ut.al .00 .00 75.00 HO.OO
HOURS I .00 .00 .00 .00
080 REnO-PAY
Ut.Sl .00 .OC .00 52.11
HOURSI .00 .00 .00 .00
100 VACATION
Aalt., .00 71.92 29S .69 665.~8
HOURS I .00 8.00 12.00 72.00
110 HOLIDAY
Aaltal .00 .00 .00 367.20
HOURS' .00 .00 .00 40.00
[llyrR I JT..S'='R Tax.. To-Date Inqul ry
EXHIBIT "B"
. .
~D.S.
,s-
. ..
'.-
Pr ~nt !(",!
... "Ill ~ ~ '. lit .,40 ., I ,)'l Id
',. ,,-
";14'Jo!
l. ~ ; ; ! ; -I"
"""r""-
'>lrE'j'J
.:
.:'.;fr-~4Y rUt') ~,:;. rRpl~ )5:j1
:J:l'H '....,1'1.I'JCL;.j
BSV 1 (Jla: ii!j.'/ij HT-:}I;R 1 rjIJI)()llI a~ ~ J ; 1 : : J j ll-~'j :t,),)
rt.E::, r,)-DllIt.lt Inclli Lc I ',: ~E:. rll, ., H.;r; C
HI!:) De.':rlpt~,)n
:10 Hor.:::lAY ':'l~~" r en t. Month ~'..II t '1 r '''d''
AJlt"t ,f," ':I} " I, ,;'i
HOURS 1 .':!'J '1'; ."') I';,'},)
i,-I) ~rHF.A"'E fllNEIUL
NatSl ,i);) ,.)(J ,I)(} ,l)IJ
:tOUR51 .111) ,Vi) .lJlJ .00
IB ~U'Et: OAY OTHER
""'tit ,OIJ ,OIJ t:.bIJ ~),'H
HOURS I .00 .00 , (JO .00
1'0 PERSONAl. TINE
Mttl .00 .00 ,iJO l J. II
HOURSt .00 .00 .00 8,00
1<0 SAFETY AWARD
Mtll .00 ,00 .(1) .ou
HOURS: .00 .fJ(J .00 .Oll
IWT!R I rT-,qCR T4... rO...04t. Inqu 1 ry
pnnr. ".Y OutP'.;t
!. '6)S:i~ ....lR1J1(J Hf)9J'l 5::-::1'1'.'
P<1'l" I
:'-11':;1';2
~ 1 .: 'J 'i
Duplay O"~'lC. TRPClt;S:
U..r WJ1~'JO":L\oI'
BSVl 0)8: 7"'11778 H1 -seR 1901iOQ 1 8-1 1 j I: 1110 ll-r. 1109
ItLD. Tc-Date lnqlJiry SLTE.i JR, a(.CRJE ..
H~D D.~~r \P~ ..on
'i06 PRE!AlI: Li"fE IHS .:';ttent. Kl..rr.th ':l\~4:'':l;H' Ve4(
.\J1tSI 1. 28 ~. .: ll.=:' 6LH
.IJ() .n ,I;'; .iJfJ
6" "J,uJGUAP.:) L<1,,1I
AJrltil .00 .f)(\ .00 l'H,OO
.00 .QO .00 .00
.29 PRETAX HHO
Amtll 26.61 lOb.H 2l'LH 1.271.52
.00 .00 .00 .00
. J' W"' DENTAL
ut,l 1. 04 11.16 17,31) 14';,91
.00 .00 ,0<] .00
... OOT LIFE DEPEND
~tll .00 .CiO , ao .00
.00 .00 ,Ill) .00
rnrERI Jf-iCP :~~.~ r"-~dt~ :nqul~Y
. t
....
HbS.
c: 5
. .
.........
...
,'. .-
Prlnt ".Y Output
5~.)5S1 V1RIMO 940909 StT[~~O
p.sqe 1
Ll ~~.'9; l'll~I00
O~.pl4Y Oev.ce tRPCJ5S1
V.., WH990CLW
BSVl 0)97 178718 HT-seR 18o~oalU 11:111J6 ~ L ..:! 'j 110'1
HfOt fo..Oatfr Inquiry & tT!5 Jil, ,~.E')RGE C
KED ('ll"lcrlptlon
6% OPT :.xn DIEPEUO "::uL"fent Month '~l',.,u.tfJr '!'t:.u
"-tal .(JG .00 .00 .(11)
.00 .00 .00 .ou
a~ HlSC-O~
ut., .00 .00 .00 10.00
.00 .00 .00 .00
811 WHX ER DENTAL
bt., .00 47.00 9LOO 1,6lS.aO
.00 .00 .00 .00
812 WHX A , S
bt" .00 24 ,02 <16.04 780.00
.00 .00 .00 .00
814 WHX LIF! INS.
Alat,l .00 12 ,00 204.00 428.00
.00 .00 .00 .00
ENTER I JT-SCR Tax.. To-Date Inquiry
Prlnt "ey output
5163551 V3R1HO 940909
51-:[990
25/9;
Pdglt 1
14111106
DiJplay Device
U.er
TRPC3SS1
WH990CLW
BSVl 0]81
718778 HT.SeR
180608184
1]111144 1l-~5 1109
HEoI To..Oate Inqu~ry
SITES JR, GEORGE L
HED Description
814 WH~ LIrE INS.
Amu:
Current
.00
.00
AmUI
5.28
,00
Honth QU4rttfr 'ie.lr
l.2 .00 14.00 428.00
.00 .00 .00
21.04 51.77 281. B6
.00 .00 .00
1".066.51 2,683.82 l",28B.23
.00 .00 .00
960 40lk
999 NET PAY
Amtat
HOURS t
268.90
.00
ENTER: JT-SCR T4xe. To-Date Inquiry
~R 0)'.
C:.5
::- c. I
S. 1,;",
,- (.~
U.IC;
")'"'
r~. ~
~,,: '-~)
\.0.1..... I
.....JI,L -
tr. c.i' "'-
I-
E. eX': ,J
0', :.J
,
,
-, (':')
i <..
I
1I~ .'
(,-j'
Li':'
,.
L..:'
I'
t'~
L_i'
.', (
l~
i' ~-
" ,
0 l. , , )
"
GIORGI L. SITIS, JR., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v.. . CIVIL ACTION - LAW
.
I NO. 96-1092
Rllfll D. SITIS, I
Defendant I IN DIVORCE
CIRTIFICATI OF SERVICI
I, SHARON R. KYLE, hereby certify that on this ~J7<1 day of
August, 1996, I served a copy of the foregoing Motion for Leave to
File Amended Complaint by first class united States mail, postage
prepaid, addressed as follows:
Renee D. sites
89 Autumn Lane
Enola, PA 1702~
By:
, J) l ) I
\ -'l 1,1',,'>/ /\ I)~I {!p
Sharon R. Kyle j
Paralegal - Legal Secretary
113 Locust Street
Harrisburg, PA 17101
(717) 232-2227
LAW OJfI"IC".
IL~N!OON ... Rl'UEN
8Un.. U07
JUO CIfE,.'r:'ll'tJT !!l'rrU:E"
U.\,RIUNUUHG. p,\. tJ'IOI
1'711'1 .....IIOUI
GIORGI L. SITIS, JR., I IN THI COURT OF COHNON PLIA8 OF
Plaintiff I CUMBI!lRLAJlD COUNTY, PINNSYLVAJlIA
I
v.. I CIVIL ACTION - LAW
I NO. 9t-1092
ROil D. SITIS, I
Defendant I IN DIVORCI
NOTIC. TO DIFINDAJlT
If you wish to deny any of the statements set forth in this
Affidavit, you must file a Counter-affidavit within twenty (20)
days after this Affidavit has been served on you or thfl statements
will be admitted.
PLAINTIFF'S AFFIDAVIT UNDIR
SICTION 3301ldl OF THI DIVORCI COOl
1. The parties to this action separated in April, 1994 and
have continued to live separate and apart for a period of more than
two (2) years.
2. The marriage is irretrievably broken.
3. 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 made
subject to the penalties of 18 Pa.C.S. S4904 relating to unsworn
falsification to authorities.
Date:
li0- i /9 1.
I ,
~~~li^.
Ge ge L. site/, Jr.
,.. ~~. J
l.: If:
,-'
:.'J'
,.
~; .1
,~, I
fJ."
~l (, . I
I, .-
I v:
. ') ,
<,' U
~. <'I
( l.4--.
i
lUI~
i :-.
t:;. ,
(,
tl: ~ :.\
.
~.J , C
...:
i to., '-
v'
" . .,
<. '- , ,
l.AI\' OJ-I,ll. fS
RICHARD C. RUBEN
IIH,\,X L~I '-'mEET
1l.\I,I<I',iiL.i<';, I'A 1711)1
\71::"i 21"2.22]7. FA\ \:'17) =j~-271!;--
GIORGI L. SITES, JR., I IN THE COURT OF COMMON PLIAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
va. I CIVIL ACTION - LAW
I NO. 911-1092
RlIIII D. SITES, I
Defendant I IN DIVORCE
NOTICI TO DIFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against
the claims 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 by the Court. A judgment may also be entered
against you for any oth~r 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 the divorce is indignities or irretrie-
vable breakdown of the marriage, you may request marriage
counseling. A list of marriage counselors is available in the
Prothonotary at Cumberland County Courthouse, One Courthouse
Square, Carlisle, PA 17013.
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.
Court Administrator, 4~ Floor
Court of Common Pleas for Cumberland county
One Courthouse square
Carlisle, PA 17013
GIORGI L. SITI8, JR., I IN THI COURT OF COMMON PLIAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
v.. I CIVIL ACTION - LAW
I NO. 96-1092
REI/IE D. SITES, I
Detendant I IN DIVORCE
TO THE HOI/ORABLE, THI JUDGES OF SAID COURT:
AND NOW COMES, GEORGE L. SITES, JR., Plaintiff, by his
attorney, Richard C. Ruben, Esquire, and states the following:
1. Plaintiff, George L. Sites, Jr. is an adult sui juris, who
currently resides at 160 Taylor Road, York county, Etters,
Pennsylvania 17319.
2. Defendant, Renee D. Sites, is an adult sui juris, who
currently resides at 89 Autumn Lane, Cumberland County, Enola,
Pennsylvania, 17025.
3. Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for at least six months
immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on August 3, 1985, in
Cumberland County.
5. There are two minor children born of this marriage.
6. There was a Complaint in Divorce under Section 3301(c) filed
on February 28, 1996 to this docket number.
GIORGI L. SITIS, JR., I IN THI COURT or COMMON PLIAS or
l'1aintiff I CUMBERLAND COONTY, PINNSYLVANIA
I
v.. I CIVIL ACTION - LAW
I NO. 91-1092
RI... D. .ITIS, :
Defendant I IN DIVORCI
DIFINDANT'S COUNTER-AFFIDAVIT UNDER
SICTION 3301ldl or THE DIVORCB COOl
1. Check either (a) or (b):
(a) I do not oppose the entry of a divorce decree.
divorce decree because (check
...-/ (b) I oppose the entry of a
(i), (il) or both):
./
(i) The parties to this action have not lived
separate and apart for a period of at least two years.
~ (ii) The marriage is not irretrievably broken.
2. Check either (a) or (b):
'(a) I do not wish to make any claims for economic relief.
I understand that I may lose rights concerning alimony,
di vision of property, lawyer's fees or expenses if I do
not claim them before a divorce is granted.
-L (b) I wish to claim economic relief which may include
alimony, division of property, lawyer's fees or expenses or
other important rights.
I verify that the statements made in this Counter-Affidavit
are true and correct. I understand that false statements herein
are made subject to the penalties of 18 Pa. C.S. 54904 relating to
unsworn falsification to authorities.
Dated:
~;k Nt
.//
, J
( ----;,' ,
/',L .4:_
Renee
/
,'/ f"" j'-
t! ' /." t" "/ //'-' ~
. \ k I I , _w _<I L1.. t' ... /
D. Sites, Defendant
NOTICE I Ir YOU DO NOT WISH TO OPPOSE THE ENTRY or A DIVORCE DECREI
AND YOU 00 NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELlEr, YO~ NEED
NOT FILE THIS COUNTER-AFFIDAVIT.
~ C'
.~~ \1", , .
.' c.; ., ,
tJJ9.
uoC ,
F ...
1:/ Go-
LJ" ' ,~)
\J " I
ct' ~ :;i 1;- I
.. .'< ~ ~-
\-- -, -
~ a.:l 'j
C' (,)
..... c>
t-, u:
I,. ,'':';
lJ.,l( ;
?;" -.
; ~ r. L_
8:' ,..,
, -',
':'1' I
U"
~-JL ' ' .. I
~-'~ ..... :: ::.::-
, -, ,
CO ,
t~ ()
(1 C1'
>- 0 "
r~ 1.1.
.,:
.... ~ "
U~~!
~.
Ie, w.. "
!'-l.
y,:, t;) "
f.h .,
I'.
, ,;;1".1
(tl.l ~ .
c;
r' ", '-
~ r.c -,
a- d
-- Cl ,'"
U. ...',
'- . "
t-- r:~
we,
C)~
r.~' ....
v~j ,
9}- 1,;") ,
c...1V' I
\....~ . ;;:: t-l
c~.
... ~~ ~.) u..
I .':
u., co :J
() <1' (...)
-,. c' -
~; u: (
, ~;1 "
l..W ~,.!
~'~i.";
I. . ;.1_ ,
~;- ~)
u..1'" ,
'::.!ll ,.U
u.. I "':1, .:~
r -,' ,
c:J ..0.:.,
~ ~
C1' 0
GEORGE L. SCTES, ,JR.,
PLaintiff
IN THE COURT Of COMMON PLEAS Of
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 96-1092
CIvrL
RENEE O. SCTES,
De fend an t
IN DIVORCE
ORDER AND NOTICE SETTING HEARING
-----.---
To: George L. Sites, Jr.
Richard C. Ruben
Renee D. Sites
Carrie A. Lumi, Certified
Legal Intern and
Robert E. Rains, Supervising
, Plaintiff
, Counsel for Plaintiff
, Defendant
, Counsel for Defendant
Attorney
You are directed to appear for a hearing to take
'"
testimony on the outstanding issues in the above captioned
divurce proceedings at the Office of the Divorce Master, 9 North
Hanover Street Carlisle, Pennsylvania, on the 21st
day of .January ,19~?, at 9:00 a.m, at which place and
tim~ you will be given the opportunity to present witnesses and
exhibits in support of your caSe.
By the Court,
~~ \:::
Harold E. Sheely,
.Jud<]9
Dat~ oE Ordar and
Notice: -1Q/28/96
By:
Divorce Master
If YOU DO NOT HAVE A LAWYER OR CANNOT AffORD ONE, GO TO OR
TELEPHONE THE OF'fICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
'"
Court Administrator
fourth Floor, East Wing
Cumberland County Courthouse
Carlisle, PA 17013
Telephone (717) 240-6200
Testimony will be limited to the issue of the date of
separation oE the parties.
'- _T
C. t',
.'
. i-';
tC
~: ~- -';...J
, , ,-0, ..
Ei::, .'-'
e;U' .... "'-'j
(, ' ...
I- e.;
(.!.. c ,
'1) :,)
0 c-.
Support payments: $14O/wk plus $IO/wk in arrearages,
Disability payments: $364,40 for child's disability
Unemployment compensation and supplemental benefits: n/a
Workman's compensation: nia
Public Assistance: $66/month - WIC
Other:
(d) Other contributions to household support
Name:
If your (wife)(husband) is employed, state
Employer:
Salary or wages per month:
Type of work:
Contributions from children: n/a
Contributions from parents: n/a
Other contributions: n/a
(e) Property owned
Cash: n/a
Checking account:
Sa v ings account: $1
Certificates of deposit: n/a
Real estate (including home): n/a
Motor vehicle: Make Subaru GL, Year 1983
Cost, Amount Owed $ 0
Stoclu; bonds: n/a
Other:
(t) Oeblll and obligations
Mortgage: n/a
Rent: SSlO/month
Loans: n/a
Other: Car Insurance: $48/month
Food and child care needs: $3S0/month
Phone: $30/month
Electric: $120-$ISO/month
Clothing: $lIO/month
Activity e~penses for children: $200/year
Medical: $4S/month
(g) Persons dependent upon you for support
Children. if any:
Name: Age:
Veronica Lynn Martin 12
Rebecca Ann Sites 10
Corey Micheal Sites 2
Victoria Phoebe Sites I week
4, I understand that I have a continuing obligation III inform the court of
improvement in my linancial circumstances which would permit me to pay the costs incurred
E .;:0 -
. . C-v
. C1
~(? ,j, ~
ff! ' "
?f ,j
EJ,I Vl '!
C'-
~U' >- "u
'-." "J
. , ~l..
c:..:
,," ....;.-, -)
U G\ ','"
,
."
U.1'- .
("J '
{'"
..
11. i
l.,J,
O'
Ui.~
~l
1--;
I'
()
--
j-
r:,
c.;
" .
C' ';
-' ~
"'"
, .., i
OJ' , -'
I(.\~~o:" ,...... 1:'"11I.'
Hl"ll' :1117
lOll C'IIL~d:'" .. ...rllI:1 I'
II.\.UHI""III Ill.. I.,\. t tllll
~
~~
~
~
.-j
"
I'
~
<;;~
(j/
GEORGIl L. SITIlS, JR., I IN THIl COORT OF COMMON PLIlAS OF
Plaintiff I COMBIlRLANDCOONTY, PIIfNSYLVANIA
I
v.. I CIVIL ACTION - LAW
I NO. U-l092
RI)f1lll D. SITIlS, I
Defendant I IN DIVORCJI
ORDER
AND NOW this 3 day of I~
, 1996 in consideration of
the Motion of Plaintiff George L. Sites, Jr. to amend his Complaint
to add allegations of separation for greater than two years and to
request a divorce pursuant to 3301(d) of the Divorce Code.
IT IS HERIlBY ORDIR AND DECREED that leave is hereby granted to
Plaintiff to file an Amended Complaint.
BY THE COURT,
-7 /
/ ..
',,--/:j({
J.
GIORGI L. SITIS, JR. , . IN THI COURT 0' COIOlON PL.lAB OF
.
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
v.. I CIVIL ACTION - LAW
. NO. 96.1092
.
RlNI.I D. SITIS, I
Defendant IN DIVORCE
MOTION FOR LIAVE TO FILE AMENDED COMPLAINT
AND NOW comes Plaintiff George L. Sites, Jr. by and through
his counsel Richard C. Ruben, Esquire and states the following in
support of his Motion:
1. Plaintiff is George L. Sites, Jr. who currently resides at 160
Taylor Road, York County, Etters, Pennsylvania 17319.
2. Defendant is Renee D. sites who currently resides at 89 Autumn
Lane, Cumberland county, Enola, Pennsylvania 17025.
3. That Plaintiff tiled a Complaint in Divorce under section
3301(C) on February 28, 1996 to the above Docket Number.
4. That neither Defendant Renee D. Sites, nor any counsel have
entered an appearance on her behalf.
5. That Plaintiff filed his Complaint pursuant to forms provided
for Pro Sa Divorces without the assistance of counsel.
6. That Plaintiff was unaware that due to the length of
separation that he was entitled to a divorce undel' Section
3301(d) of the Divorce Code.
7. That Plaintiff was under the impression that his wife Renee D.
sites would be willing to consent to a SJ301(c) divorce.
8. That in fact Renee sites has refused to execute a consent to
the divorce.
GIORGIl L. SITIS, JR., I IN THIl COORT 0., COMMON PLlAS OF
Plaintiff I CUNBIRLANDCOUNTY, PIHlfSYLVANIA
I
va. I CIVIL ACTION - LAW
I NO. U-l092
RDlJII D. SITU, I
Defendant : IN DIVORCB
NOTICI TO DIl.,1l1fD AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against
the claims 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 by the Court. A judgment may also 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 tha ground for the divorce is indignities or irretrie-
vable breakdown of the marriage, you may request marriage
counseling. A list of marriage counselors is available in the
Prothonotary at Cumberland County Courthouse, One Courthouse
Square, Carlisle, PA 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER I 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.
Court Administrator, .~ Floor
Court of Common Pleas for Cumberland County
One Courthouse square
carlisle, PA 17013
EXHIBIT
J
" /1
/-("
- '
GIORGIl L. SITIlS, JR., I UI THIl COURT OF COMMON PLEAS OF
l'1aintift CUMllERLAND COON'l'Y, PENNSYLVANIA
I
va. I CIVIL ACTION - LAW
I NO, 96-1092
RIll.. D. SITIlS, I
Defendant I IN DIVORCI
TO THB HONORABLB, THIl JUDGIlS OF SAID COURTI
AND IIOW COMBS, GEORGE L. SITES, JR., plaintiff, by his
attorney, Richard C. Ruben, Esquire, and states the following:
1. plaintiff, George L. Sites, Jr. is an adult sui juris, who
currently resides at 160 Taylor Road, York County, Etters,
Pennsylvania 17319.
2. Defendant, Renee D. Sites, is an adult sui juris, who
currently resides at 89 Autumn Lane, Cumberland County, Enola,
Pennsylvania, 17025.
3. Plaintiff and Defendant have been bona fide residents of the
C~mmonwealth of Pennsylvania for at least six months
immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on August 3, 1985, in
Cumberland County.
5. There are two minor children born of this marriage.
6. There was a complaint in Divorce under Section 3301(c) filed
on February 28, 1996 to this docket number.
.M- .
GEORGE L. SITES, JR., I IN THE COURT OJ' COMMON PLUS OF
Plaintiff I CUMBERLAND COUNTY, PBNNSYLVANIA
I
v.. I CIVIL ACTION - LAW
I NO. 96-109~
RBNBE D. SITES, I
Defendant I IN DIVORCE
CERTIPIC~TE 01' SERVICE
I, SHARON R. KYLE, hereby certify that on this L?~~ day of
October, 1996, I served a copy of the foregoing Motion to Appoint
Master by first class United States mail, postage prepaid,
addressed as follows:
Carrie A. Lumi
Family Law Clinic
45 North pitt St.
Carlisle, PA 17013
By:
J~
L~i~;~"R:)'KYle .l<
Paralegal - Legal Secretary
113 Locust Street
Harrisburg, PA 17101
(717) 232-2227
ASSETS OF PARTIES
Defendant marks on the list below those items applicable
to the case at bar and itemizes the assets on the following
pages. If an item has been appraised, a copy of the appraisal
report is attached.
Real property
Motor vehicles
( ) 1.
( ) 2 .
( ) 3.
( ) 4.
( ) S.
( ) 6.
( ) 7 .
( ) 8.
~ 9.
( ) 10.
( ) 11.
M 12.
( ) 13.
( ) 14.
( ) 15.
Stocks, bonds, securities and options
Certificates of deposit
Checking accounts, cash
Savings accounts, money market and savings certificates
Contents of safe deposit boxes
Trusts
Life insurance policies (indicate face value, cash
surrender value and current beneficiaries)I.'d..,,'/o,' r rlUi fl~ t
line,v ,i,I/" r
Annuities
Gifts
Inheritances!)d""IIIl,lf Ir"I\It! 'Ii/Ol) I,(f,', "'I.'~h"r's (/~(,HI",19t,l),
r,ltli,.y "fr'flf 1'L'llliljr tC"j Y l!l \ l<:'
Patents, copyrights, inventions, royalties
Personal property outside the home
Businesses (list all owners, including percentage
of ownership, and officer/director positions held by
a party with company)
( ) 16. Employment termination benefits-severance pay, workman's
compensation claim/award
( ) 17. Profit sharing plans
()) 18. Pension plans (indicate employee contribution and date
Plan vests) \:" ',;I 1', .' ,\ "I' t I ,
. ',: '. I 1,1 r - .. I';', t 11/! ,l ," ~ 1 <-i r'.: I:J '-it
'! ~
( ) 19.
( ) 20.
( ) 2l.
( ) 22.
( ) 23.
( ) 24.
( ) 25.
Retirement plans, Individual Retirement Accounts
Disability payments
Litigation claims (matured and unmatured)
Military/V.A. benefits
Education benefits
Debts due, including loans, mortga~es held
Household furnishings and personalty (include as a
total category and attach itemized list if distribution
of such assets is in dispute)
( ) 26. Other
~
41 e
'l:l41
......
0..1
~ :c
0
>.
... III
... >
. ...
::J ..
'l:l U
... 11I11I
> .. ...
... ....
'0 ~""
e
...
..
.. III
III Q,
~ >.
III ""
..
e
...
e
41 41
... ...
.J:i> -l
. .....
.. ..
... e
::J ::l
0" 0
41 ~
~
0 41 e
..0
... ....
. ~..
llll u
III 4IcC
... ::l
......
. .0
>
III
>
. 41
.c "III
. ::J
.. .c... ..
41 V. ..c'
III ~> ..
::J ::l ..;
0 .... ~ ,-
Q, .
"'0 -." _'4
41 '0 ....J '- ~
s:. V 41
.. e .. \0 S"- ~
0 41 III ~ '-
.J:i> I .c I ~ '"
u '.~ ~
~ ~ '--.J ~
0 V ::l . .- -
'~ ...
.... 0 <.0 ~ c.
~ III
III III 41
.c 31 ...
.. III
... e ~
41 0 i---'; ~
... ',"
.c.. .' -+-
vu .. "-
...11 ~ ~.
'1'
s:. 41 "..,
31" e
... ~ -' 1-:::
e.c
... .. .. "
... 0""0
>.41 - '"
.... cC -::
~. L ...
41'0 '-..J r-.::;:
Q,
041
~.c
Q,..
......
.0
..
... .. ... .:J
~ . 0 ...j.. --
; ~ ,-,
e .... .-
0
... III ...
... ~ 0
. III
>. Q, e
.... 0
..... ~ ...
III" 41 ..
Q,... .c Q,
0'" .. ... ,.
... 0 ...
....... <J
.... >. ..
...... e III
... '" ~
..e -:. "
.,........c, S
...... III
"'...... w
:1;....31 ... ("~ I....: .,
~
41 =
'alii
......
0..1
:c
!
~ III
... >
...
'0 ...
41 U
'" 41 III
::J ......
... II'"
<J ~""
)4
III
41
.&J 41
Q,
0 >.
.. ""
'0
~ =
... 41
II ...
... ..I
u .....
..
.. c
... ::J
0
,r. ~
u
...
.c 41 c
31 ...0
II'"
.. ~...
.. u
41 41cC
~ ::l
41 ......
.. .0
c:: :>
...
41 41
... .. 41
.J:i> . :l
III ,r....
.. <J III
... ~:>
:l ::l
0" ....
41
~ '0
0 41
II
... .
III .c
llC U
Qj ~
.... ::l
....
.
III
.. ..
II II
.c ~
41
III
::J ..
0 ...
Q, 41
.. ~
.
.c ...
u ...
... cC
,r.
31
c::
...
>.
... Q,
~ 0
41 ...
^ '"
0
... ...
Q, 0
>.
...... e
~... 0
Q,I 10 .. ...
Q, >. ..
0.... Q,
......... ...
......41 ~
...Q, u
...... 0 .. -~..._-.. .
. ... 41
.......... ~
......
~......
~"'II
C::...
I...... S
C.... 41
0'" III ...
:z;....X ....
~
41
'Oc:
...41
0...
:.c..J
41
>
...
>. ..
e U
. $ 41
.....
s:. II'"
.. ~""
...
31
~ 41
0 Q,
>.
>. i-'
...
...
II
::J
'a e
... 41
> ...
... ..I
'0 .....
e:: ...
... e
::I
.. j
.
41
~
41
..
e ~
... 41 $
......
41 ..
... ~e::
.J:i> .
III 41 ~ '-'
.. :Ii-' C
... ... ~
::I III'"
0" .. :>0 "f\
41.
~
~ III
041
>. 41'"
.... ::10
11$ ... 41
llll41 11I4111
III~ :>..11I
...s:. .....1IIs:. .::..,. "-,
.. ...~ U '-' ':-J
II .. ... '" ::,
llll 0...::1 \t'
'Oc t.l II.... -'"
III'"
J:'a
41 ~
.. 41 "'41
$U 0'"
.. 41 . c-l 'L
:I~ 41 C
OQ, "'11I c:::- eo
Q, III~ --
.. $ ~i-' u..-
s:. ~
s:....
... 41 ,.j
oe ... III 0-
.J:i>'" 011I -,
c- L'
s:. s:. ~J..,...
~... G1U -:::-- 0--
0... ...~
31 11I::1
~ ~....
G1'a
s:.G1 1----, \...::-
...~
...... f' 'J'
GI 41 . ';. 'L "",- 'J'
... ... -+- ..... ... '-
s:... GI -+- ..l-
ue:: e -.I' v'
'''11I ~ '-.[' ....../'
s:.... .....l ,.
31'" .- -' c::
... ...
e:: C .... '.-. ~-, 'L.
'- '-;-"'-1
...1Il cC .. '.
III ., -
..
>'.J:i> ~-r~ L. L
.. VC~
"'11
G1111
Q,.I: .:.. '"
0 0
....1: ... ,...
Q,U .... ..
'0 ...
G1_.I: ...
...... 31 0 u ...
~ III
GI '0 e:: -
.....e 0
.....11I ... "
e .. ...
Ill'" C Q, 'L -
...... 0 ... .l.-J
i-' .. ... L
...~ U -
>.... III .. ,.
...... Q, 41
...... ~ :t..
G1e... '-...-J
Q,... GI S , ._"--J '--.'
o 1llJ: III ~ ,,,-..
...-... .. "- c::>
........0 ...
II
41
00
II
Q.
00
C
...
31
0
...
...
0
....
41
..:
..
e
0
II
GI
...
..
...
...
...
.J:i>
.
...
...
41
..:
..
II
41
N
...
S
41
..
...
'0
C
II
~
III
.J:i>
...
III
41
III
III
U
41
..:
...
0
...
41
...
.J:i>
III
U
...
...
Q,
Q,
III
III
S
41
...
...
III III
III III
0 ...
.c ..
.. ...
-
31 ...
0 .J:i>
... .
III ...
.J:i> ...
... '0
III III
... ...
... ~
1111 U
1111I G1'" GI
G1": lllle II
- w III GI
... llllSIIl...
... e:: wOlle:: Q;
110 ... '0 III..:
.... o ::::J.......,
II X.,..JO
.......
0'"
'" . . . .
II S l""4NM~
41
...... ""
....... -..............- GI
...... r-- ...
..ow ::J
-e:: tJ
.J:i>- GI
III '" CO
....... e
..J.... ::J
III
GI
...
...
...
-
...
.<:l
as
...
-
"':l
GI
III ...
41 ...
... GI
w .. ....
... ... GI
.... e 'tl
... GI
II .J:i> S ...
GI '" III 0
U ... GI
e:: .... ... .. ...
Q oOGI e
.... "" cCw GI
'" III 0 OIl
.J:i> .. GI ... ...:z; c
.. _ ::J 0 ....
:: C.J:i> u >. ...
.., - 'U - ~
III .. ~>'1Il w 011 0
U GI as C "" u .... II U
.. '" Q,::J CU\ll....C
will Q, ...""'....:10 II ...
.....: .. ... ......, S 1:1''''' GI GI
""u C GI III IIIC03lw..t:
III ... "'.....: ..... 0 ... lIS o..lIl__
Iool::::JOOU 1IIt.l......JOl-oO
t.l......J:z;O !:l
~\Q"""COQ'\
----
.....,---
....N~~~
.........................
-----
----.....,
.. .
'0
CI ...
u =
= l
CI
I ...
....C
U :I
II ~j
II
31 '8
... '0
C ...c
0 CI "
... ....
..
u
III
II
...
.I:
..
41
.. GI
II U
'0 =
III 41
41 _::J
.c "'~
.. III
..
.... G1...
0 ...
'"
III ~
III
'0
C >. GI
0 ....., U
III ... =
~ _'0 GI
41 -G11
Q, .<:l~
"'~
>. ...:It.>
C ..lU
III e::lIl
.......'"
.c 0 31
.. III
... .....e
31 ="'0
::I~...
~ 0 ...
0 ~cu
OcC
41
C
0 >.
... ...
'" ... '0
....Ill
II -~
III .<:l~
III "'::J
::I ...u
0 ..lC
Q, ....
III III
...11
.c "''''
... ~31
0
.J:i>
~
0
~
GI
.I:
.. III
... ~
III 0
...
... _.J:i>
0 _Ill
cC~
III .....
GI ...~
... 00
... ...
... .....
... G1'tl
... Sill
.J:i> "'~
'" :z;t.>
...
...
...
...
'" >.
e::",
III 0'"
... ......
III ......
... Q,.J:i>
Ill'" ... '"
GI ~...
...... U..l
..... ..
...... Ill'"
...... ~o
...c
.J:i>... S
"'''' GI
...... ...
..J.... ...
. ,. ..
I.CONl AID 11'1.1. ITATIKII7 0'
(' ',( ,
""" .. _. \:). ....)1 q ...0.;'
SSN 'J:.:.L - "I 'i: -' i -:; '; :I
ORt
OAT!
TBII ITATlHZHT MOST 81 'ILLID OOT
(If you are s.lt-employ.d or it you are salaried by a busin.ss of
which you are owner in whole or in part, you must also till out
the lupple.ental Inco.. atatement which app.ars on the last page
of this Inco.. and Ixp.n.e Itate..nt.)
II1COMl
(a) wages/salary
Employer , Address
Job Title/Description
Pay Period (weekly, bi-weekly, monthly)
Gross Pay p.r Pay period....................... $
Payroll Deductions:
rederal withholding.....$
Social S.curity.........$
Local Wag. Tax..........$
State Incom. Tax........$
Retirement. . . .......... . $
H.alth Insuranc.........$
Other (specity) .......... $
.............. .$
........ 1.......$
Net Pay per Pay Period....................... $
(b) Other Income Week Month
Interest/Dividends......$ $
Pension/Annuity.........$ $
Social s.curity.........$ $
Rents/Royalti.s.........$ $
Expense Account.........$ $
Gifts... . . . . . . . . ... ... . . $ $
Unemploy. Compensation..$ $
Workers comp.nsation....$ $
~!:J{ll i~l'L....\;i~, .,~"\.' tr~.,I't;'._I..JJ..I.o...r~C $
I 'Gh.U" i~'I..,,~.t ", ~l'i t'h.ttl . $ S '~~l!J.\.Cu
Total Other 'Income.1ooI.l~c.......$ $ (.1.. Ie,
1.:,(.1, ,,,,,$ as '-\l
INCOME AND EXPENSE STATEMENT OF
Year
$
$
$
$
$
$
$
$
$
$
$
I verity that the statements made in this Income and Expense
Statement are true and correct. I understand the talse
statements herein are made subject to the penalties ot 18 Pa.C.S.
54904 relating to unsworn falsifications to authorities.
Date n/'l..J{i{" , ;("1' )LJ "...(&.\\
~in ore:fen~ant.'
Oecllllllon~
liIil-~
0:0::0 -[j]
IAS U,. On' -001101 writ, or It.al'''I Ih'l 'OU'.
Form 8453
UII thl
IRS '"b"'.
Otherw1le.
pi....
prinlor
lyp..
Your n"l n""", .nd Inl11..
EORGE L. SITES JR
U.S. Individual Income Tax Declaration
for Electronic Filing
For th. .11 Jlnu 1 -- December 31 1995
LUln""'"
OMS No. U,U-nt3'
O'O",,,,,,,,,'ItI, r'...lllY
In",,,,1 A..,nu. hf"WIU
1995
City. town or post oItlC.. st.I., Ind ZIP cod.
SUMMERDALE PA 17093
Palrt I Tax Return In'ormatlon hol. dolllt. ani
Tal.. Income (Form 1~, Iln. 22; Form I~A. IIn. 14; Form 1040EZ.lln. 4)
TolllI..(Form 1040, IIn.S4: Form 1040",lIn. 28; Form 1040EZ.lln. 10) .
F.d....lncomel..wtthh..d (Form 1~.lIn. 8S; Form 10401\.lIn.2ge: Form 1040EZ.lln. 7),11
Inyl. lrom Form(.) lOU9. check h.r. . 0 ' . , . , . , . , , . . , ,
4 R.rund (Form 1040, IIn.83: Form 1040".lIn.31; Form 1040EZ.lln.'1) ,
I Amounl ouowe Forml~ IIn.8S'Forml040" IIn.33'Forml040EZ IIn.12
Part II Direct De ollt of Refund 0 lion" - Soeln.trucllon..
AltlIoh . N""",o'"nlncl..ln.UlUllonlnd.llappllclbl..brlnchn""", . BENEFI IAL
Copy B
01
Forml
W-2.
:~2a. . Oepolllor locounl number (OAN)
109!-R . Typ.olaccount: Checking
h.r.. 10 Own...hl olaccount: Sell
Part III OeelarBtlon 0' Tax a II SI non
11 I con"nll"a' my "'und Ot dlfUlly d'lIolltld I' d"lGn'tld '" fl." II, 'lid dull,eU,,, trlll"'.,m,Uo" .".""" an Ii"u' t"rauGn 10 II cau,ct.
If I "IVI t11ld Ilolnl "turn, 11'11,1, an 1",voColO" IClPo,"lm,,,, of Ii'll Olh., .pou.... ,n 10lnllo "U"'.. th, '.fund.
L
A
B
E
L
H
E
R
E
II Ilolnl rllUrn. .pou.... "'.1 n""", Ind In!II"
RENEE D. SITES
Home Iddrl.. (number Ind .ooe,), III PO, bo.. ....In.lNcnono.
PO BOX 305
LISt n""",
ApI. no,
Your loclallecurlty numbe,
180-60-8184
Spou.e'. lachll ..curtty no.
207-48-9553
Tllephon. number (opllonal)
For Plplrwork Rlduo"on
Act NoUa., ... fnltRlctlanl.
I
2
3
1 0 42
2 204
3 1,50)
4 2,522
5
AT 0 AL BANK
7 Routing oln.~ number (RTN)
TIl. nrlt two numblr. ollh. RTN mu.t
b. 01 through 12 or 21 through 32.
Selllnd 5 OU.I
o '110 not w.nt direct d'OOllt 0' Illy ,,'und Ot 1m not ,.e'I..I",. "'und.
If .....,. ru.d. b.llftu dUI """".' ""d'''''"d thlllf t",IAS dati nol r'ClI'" fulllnd IIm,ly o,,;,,tle"' of my '11Il1,bUlly, 1...,11 '.M,ln Illbl, 'or 'h, '"
""tIHy ,nd .U.opllclbl,uU.,U' 'nd 0'"111I... If I "....III'd 'Ioint "d,r",nd It.l. ,.."tu'" al\d 1""'11 In '''0' on my It.t. ,.tu,,,.1 "nlllf".nd my
',d."I,.lu," WIll b. "I.ct.d.
Unll., D,n,ltl" of 1I"lu,y, I d.el." '....11". infO"ftltlon I "''''IIIV'" Illy IAQ .nll U.. Imounl"n .."t I,bov, .g,.. ""'I" Ih, 'IIIoun'l an 11'., ca"'!oondlno
"".. of "tI ,/,CI,onIC lIonlon of Illy 1tU "d."llncom,,,. "Iu'''. To tit. belt olmy ll"Owl'dOI ""d bll".. ",y "tu'" I. t,u" CO"'cl, ""d COIIIIII"I, I
CO"U", 10 lilY (RQ u"di"O lIIylth,,".lhl, dICI",ttO", 1"0' 'CCO"'''lnY''''I'CIl'duI.. '"d ",t'''',ntlIO th.,AS. 1,1'0 CO"..,.. 10 11'1, IRS ""dinl my IRO
I"d/o. t'lnlmltlll "n tellnOwl'do."'''t' 01 'ICI11I' oll"n'''''''IO'' "nd anlndlc.aUon 0' ...1'1'11'1.,., no' "'y 'el~'n II ,ce.plld, .nd, It "I,ct'd, 1111"'10"(1)
10' tho '01""0.. J.J..
~ Vo..
Dee/aratlon of E/ectronlc Return OrIgInator (ERa) and PaId Preparer (Soeln.trucllon..)
. d,cI.It 11'111' "'IV' ".......d Ille Ibove l'lp,.,.,., "tur" .nd th., 'h. In"lu on '0'''''''5:1." comlll,,, and COUlct to till DII' o. M., "no...,.dU, 1'11",
only. coll'cto',I,,,, not "''IonllDI, '0' ',vle..,n, tll. ,,,~'" Ind only dicit" 1111' thll hI'''' 'CC~"'.IY'lfI'cII '1'11 d.,. on th. "'u,,,,11 PI"~ n', co"'pl"'d.
I d'CI"" IIt., 11'1,.. wlt,'I'd "" '.''IIY''''II'ool ot Iccount 'n4 It 10'''' ....lltt Iltl "'ml .hown on Iltl.'o,,,,. The "''11.,,, will ttlV' tlon'd Ihlt '0"" D"o,.
t '~."Ii' 11'1. "Iurn.l wtllllv, Ihe "...,,,,, COllY 0' "II '"'''' end In'o''''.llon 10 bl tII'd ....It" "" IRS, Ind ",w.lollow'd IIIIIIh" ',qul""',nt'ln Pub. 1345,
H'''dDooll hit EI,ct,onIC FIl,,, oll"dlllidu"llncom, Ta. R'lu'''lrr,. ..,.., 1115).111"". .110 tit. P.'d p".""" undef 1I1",m.. 01 P"IU'y, 1 d,cl"e th""
ItIW' "."'In'4 t", Ibo'" '",."ylt IIIIU'" Ind IccomlllnyuIOlc",'ulu '''d 1I11e",.nlt. Ind 10 'he bnt 0' ".y Ilno....lldo, and beller, Ihe., "el,ue, ca"ect,
""d como lit.. 'IUI dleta'lllo"" b..ed on IUlnla''''luc" 01 W",ctt I "aw. Iny _"a....ltdOI.
I1lq(p
01'.
~ 0.11
lAO',
ERa's "."".,. 2/7/96 046 -64 -6080
Use "'~'",~'l",..,o R BLOCK EIN 43 -1632899
I ""''''~O'.'''' ~ JONES TOWN R HARRI URG P~
On ",.,..... n SB n ZIP".. 17112-0000
V","' PI"altlll a' 1Ilflllly,I dICI." !l'lIt I have I.a,"''''d Ih. Ico",la.ol.,If'lf"U'" I"d ICCo,"Olny,nOlC:".'ul., and Ital'''',,,II, and 10 '''e blsl at my ,nowl.dql
Ind DIIIII. ttll"'" Itu.. CO",.cl, .nd CO"'II'I". 1'hll dlcla"Uon 'I blUe. 0" IlIln'''''''auon 0' w"IC" I "'IVI a"y 1l"0,,,11"01.
Yout Saclal S,cu,lty "u"'bl'
Paid
Preparer's
Use Onl
PrICl.II'1 L
"0"111,1" ,
fHmlll''''llor ,/,01,111
,1111'.""'01'1'1"'1)
I'" Idd,.,s
0...
Pr',,"If'1 '''<':1.11 "CUfll'l'''''.
..itA
Form 8453 flg9S)
r.._" .11..'..., r.,,'J'" "l'l_ ""'1 n
FDB4SJ'1
Form 8453 ("J95)
010295 17 OMB NO. 1545-1309
1995 1040t'C FORMAT U.S. INDIVIDUAL INCOME TAX RETURN PAGE 01 OF 02
GEORGE L JR & RENEE D<SITES
t'O BOX 305
SUMMERDALE t'A 17093
180-60-8184 36
207-48-9553 43
t't'ECF N SPE2F N FS 2 6A-SELF X 6B-SPOUSE X
DEP RES 03 6E-TOTAL 05
DEt'D INFO
6C1--VERONICA<MARTIN--
6C3--------187-64-8493
6C4--DAUGHTER---------
6C5-----------------12
6C1--REBECCA<SITES----
6C3--------202-66-5313
6C4--DAUGHTER---------
6C5-----------------12
6C1--COREY<SITES------
6C3--------203-74-0012
6C4--S0N--------------
6C5-----------------12
1040 t'AGE 1
7----------------20423
22---------------20423
31---------------20423
1040 t'AGE 2
TOTAL INCOME LINE 22
TOTAL t'AYMENTS LINE 61
32---------------20423
34----------------6550
35---------------13873
36---------------12500
37----------------1373
38A------------------X
38-----------------204
40-----------------204
46-----------------204
54-----------------204
55----------------1503
57W1---------------218
57W2-DEFERRED COMt'ENSA
-TION-------------
57----------------1223
61----------------2726
62----------------2522
63---REFUND-------2522
t'REt'-HEDI DEEO--------
FIRM-H AND R BLOCK----
ADD--5072 A JONESTOWN-
-RD---------------
20423
2726
TOTAL TAX
REFUND
CSZ--HARRISBURG t'A 171
-12-0000----------
SSNt'-------046-6<l-6080
PEIN--------43-1632899
t'OCC-LOADER-----------
SOCC-HOMEMAKER--------
SCHEDULE EIC - 43
1A---COREY<SITES------
2A------------------94
4A---------203-74-0012
5A---SON------------__
6A------------------12
1B---REBECCA<SITES----
2B------------------86
4B---------202-66-5313
5B---DAUGHTER---------
6B------------------12
ADD INFO
LINE 54
LINE 63
204
2522
Under penalties of perjury, I declare that I have examined this return and
accompanying schedules and statements, and to the best of my knowledge and
belief,they are true, correct, and complete.If applicable, I consent that my
refund be directly deposited. If joint return and refund is to be directly
deposited, this is an ~rrevocable appointment of the other Spouse as an
agent to receive the refund. Declaration of preparer (other than taxpayer)
is based on all information of which preparer has any knowledge.
For Information Only - Do Not File
Your Signature Date
t'reparer's Signature
For Paperwork Reduction
For Information Only - Do Not File
Spouse's Signature Date
020796
Date
Act Notic-=:
IRS USE ONL'{
Stat~m~~:, S~~ Taxpayer
PAG::: 01 OF 02
Notice 374
010295 17
ffO~)Ja(\'y_~'lt~!:'rr .r:r::tliliT NHLi:i.E ~ ABJ>.nml N ,R '" EME~:r
'11 b s.
(,"J
Out.-'I:l.(y
THIS AGREEMENT made this lQ.f:i::. ddY of S;j~t;jAll:Jl-P, 1997 betw'~ell
GBORGB L. SITBS, of 160 Taylor Road, Etters, York County,
pennsylvania, hereinafter referred to as Husband,
A
N
D
RENE! D. SITES, of 201 Wayne Avenue, P.O. Box 305, Summerdale,
CUmberland County, PA, 17093, hereinafter referred to as Wife.
WITNESSETH:
WHERF~, in consequence of disputes and unhappy differences,
the parties have been living separate and apart from each other;
and
,..
~RE~S, the parties desire to confirm their separation and
make arrangements therewith, including custody of their minor
children, Rebecca Ann Site's, born on April 10, 1986 and Cory
Michael Sites, born on April 12, 1994, division of their marital
property and other rights and obligations growing out of their
marriage.
NOW THEREFORE, in consideration of the covenants and promises
hereinafter to be mutually kept and performed by each party, as
well as for other good and valuable consideration and intending to
be legally bound it is agreed as follows:
(1) It shall be lawful for each party at all ti.mes hereafter
to live separate and apart from th,e other p.lrty at such place or
plilC(~~; ..lS he or oht-: Er"fJH1 t ill\t' ro t inl(~ rn..-~y ('hoonf~ or (.k~em fit.
1
EXHIBIT "A"
releases the other from any and all claims, or demands up to the
(2) Except as herein otherwise provided, each party hereby
date of execution hereof.
(4) In the event that either party contracted or incurred any
debts since the date of separation in July 31, 1995, the party who
incurred said debt shall be responsible for the payment thereof
regardless of the name in which the account may have been charged.
Husband and Wife acknowledge and agree that they have no other
outstanding joint debts and obligations of the Husband and Wife
incurred prior to the signing of this Agreement, except as follows:
A. None.
Each party agrees to pay the outstanding joint debts as set
forth herein and further agrees to indemnify and save harmless the
other from any and all claims and demands made against either of
-'
them by reason of such debts or obligations.
(5) The marital assets of the Parties consists of the
following:
A. Household furnishings and personal property
B. Bank accounts in each part ies name alone not in
excess of $1,000.00
C. 1986 Oldsmobile Sedan in Husband's name alone
D. 1983 Subaru in Wife's name alone
E. A 401K retirement plan in Husband's name alone having
an approximate value as of March 31, 1997 in the
amount of $2,111.36, a statement of which is attached
and incorporated herein as Exhibit "A".
2
r, A WMX Technologies. [nc" Employee Stock Ownership
Plan in Husbands name alone having a vested value
as of March 31, 1997 in the Amount of $.00, a
statement of which is attached as Exhibit "C."
(6l Husband is currently employed at Waste Management of
Central PA and earns approximately $369.00 per week gross salary
not including overtime.
A statement of Husband's weekly pay is
attached and incorporated herein as Exhibit "B".
(7) Each party relinquishes any right, title and interest he
or she may have to any and all motor vehicles currently in
possession of the other party,
Each party shall execute any
documents necessary to have said vehicles properly registered in
the other party's name with the Pennsylvania Department of
Transportation. Each party shall assume full responsibility of any
encumbrance on the motor vehicle received by said party, and shall
...
hold harmless and indemnify the other party from any loss thereon.
The Parties agree that Husband shall retain as' his sole and
separate property the 1986 Oldsmobile now in his name alone, and
Wife shall retain as her sole and separate property the 1978 Chevy
Caprice now in her name alone. The Parties acknowledge that the
1983 Subaru in wife's name alone has been replaced by the 1978
Chevy Caprice set forth above.
(8) The parties hereto mutually agree that they have effected
a satisfactory division of the furniture, household turnishings,
appl iances, tools and other household personal property between
them, and they mutually agree that each party shall from and after
the date hereof be the sole and separate owner of all such property
presently in his or her possession whether said property was
1
heretofore owned jointly or individually by the parties hereto.
This agreement shall have the effect of an assignment or bill of
sale from each party to the other for such property as may be in
the individual possession of each of the parties hereto.
(9) Each party hereby relinquishes any right, title or
interest he or she may have in or to any intangible personal
property currently titled in the name of or in the possession of
the other party, including, but not limited to, stocks, bonds,
insurance, bank accounts and retirement accounts. Husband shall
retain as his sole and separate property the 401K retirement plan
and WMX Technologies, Inc. Employee Stock Ownership Plan both of
which are currently in Husband's name alone, statements of which
are attached and incorporated herein as Exhibit "A" and "C"
respect.ively.
.;,
wife specifically waives any right, tttle or
interest that she may have in Husband's said 401K retirement plan
and said Employee Stock Ownership Plan as a result of the marriage
or otherwise.
Upon Husband's d.emand, Wife agrees to promptly
cooperated and provide any signatures or documentation necessary to
effect tile above waiver.
(10) The parties agree that legal custody of their two (2)
minor children of the marriage, Rebecca Ann Sites and Cory Michael
Sites, shall be joint, with both parties having the right to make
major parenting decisions affecting the child.ren's health,
education and welfare.
Wife shall have primary physical custody of the children.
Husband shall helve partial cu,,;tody for purposes of visitation.
Husband shall haw, liberal vi"itdtion rights at th.., times the
Parties may agree. In the event the Parties are unable to agree to
1
reasonable visitation, either Party may apply to a court of
competent jurisdiction to enter an Order determining custody and
visitation rights of the Parties.
Neither party shall remove the child from the Commonwealth of
Pennsylvania for the purpose of relocating without first having
obtained the written consent of the other party.
Both Parties
agree to promptly inform the other of any change in residence of
either party including address and telephone nuw~er.
If either
party intends to travel with the child outside the Commonwealth of
pennsylvania for vacation or other purpose, said parent shall
provide the other parent with written notice of the destination of
the child and the telephone number and specific address where the
child can be located.
".
<HI The Parties acknowledge and agree that the Support Order
entered to Cumberland County Court of Comnon pleas Docket Number
1306-S-1995, as amended, sllall remain in full force and effect
subject to the review and modification of same from time to time by
the Court or by application by the Parties to the Court for such
modification as provided by Pennsylvania Law.
The parties
acknowledge and agree that the said Support Order requires Husband
to pay to wife support for the care and maintenance of the parties'
minor children; namely, Rebecca Ann Sites and cory Michael Sites as
well as veronica Lynn Martin, being Wife's child to a previous
relationship. Husband disputes paternity of Veronica Lynn Martin.
(12) Husband currently maintains three life insurance policies
through his place of work listing the parties minor children as
5
insureds in the Jm~unt of $2.~OO,OO each, Husband shall continue
to maintain sa id 1 i fe insurance po 1 ic ies as to each ch i.ld and
continue to maintain wife as the beneficiary of the policies until
the child reaches 18 years of age, provided the policies are
continued to be offered to Husband through his employer at the
current rates.
(13) Except a~ otherwise provided herein, Husband shall not
pay to Wife nor Wife to Husband any sum whatsoever as alimony,
alimony pendente lite, or for his or her support or maintenance.
(14) Each party shall pay his or her own legal fees for all
legal services rendered or to be rendered on his or her behalf.
(15) Neither party shall contract or incur any debt or
liability for which the other party or his or her property or
estate might be responsible and shall indemnify and save the other
..,
party harmless from any and all claims or demands made against him
or her by reason of debts or obligations incurred by the oeher
party.
(16) Each of the parties shall from time to time, at the
request of the other, exe~ute, acknowledge and deliver to the other
party any and all further instruments that may be reasonably
required to give full force and effect to the provision of this
Agreement.
(17) The parties do hereby warrant, represent, acknowledge and
agree that each is fully and completely informed of, and is
familiar with, the wealth, real and personal property, estate and
assets, earnings and income of the other and that each has made a
(,
full and complete disclosure to the other of his and her entire
assets and liabilities and any further enumeration or statement
thereof in this Agreement is specifically waived.
(18) Husband and Wife acknowledge that each of them has read
and understand his and her rights and responsibilities under this
Agreement and that they have executed this Agreement under no
compulsion to do so but as a voluntary act.
(19) It is further specifically understood and agreed by and
between the parties hereto that each party accepts the provisions
herein made in lieu of and in full s~ttlement and satisfaction of
any and all of said party's rights against the other for past,
present and future claims on account of support, maintenance,
alimony, alimony pendente lite, counsel fees, costs and expenses,
equita~Je distribution of marital property and any other claims of
each party, including all claims which have been raised or may be
raised in an action for divorce.
(20) Except as may be otherwise specifically provided in this
Agreement, Husband and Wife, for themselves, their heirs,
representatives and assigns, each hereby forever relea~es, remises,
discharges and quitclaims the other, and such other's heirs,
representatives, assigns and estate, from and with respect to the
following:
A. All liability, claims, causes of action, damages,
costs, cont r ibut ions, expenses or demands whatsoever in law or
in equity;
-,
B. All rights, title, inter-est or- cLaims in or- to any
pr-oper-ty of the other-, whether- r-eal, penlOllal or mixed and
whether now owned or hereafter acquir-ed;
C. All r-ights of curtesy and dower- and all claims or-
rights in the natur-e of curtesy and dower;
D. All widow or widower's rights;
E. All rights, title and interest or claims in or to
the other's estate, whether now owned or hereafter acquired,
including but not limited to all rights or claims:
(1) to take against the other's will;
(2) under the laws of intestacy;
(3) to a family exemption or similar allowance;
and
(4) all other rights or authority to partic:lpate or
intervene in a deceased spouse's estate in any way,
whether arising under the laws of Pennsylvania or any
other country, territory, state or political subdivision.
F. All rights or claims to any accounting;
G. All rights, claims, demands, liabilities and
obligations arising out of or in connection with the marital
relationshj.p or the joint ownership of property, whether real,
personal or mixed;
H. All rights, claims, demands, liabilities and
obligations arising under the provisions of the Pennsylvania
Divorce Code, Act 26 of 1980, as the same may be amended from
.;,
time to time, and under the provisions of any similar statute
B
enacted by "lilY other country. 3tate. t.erritory or political
subdivision;
1. All rights, claims, dem.:lf'.ds, liabilities and
obligations each party now has, or may hereafter have, against
or with respect to the other.
(21) This Agreement shall be construed under the law of the
commonwealth of Pennsylvania.
If any provision of this Agreement
is determined to be invalid or unenforceable, all other provisions
shall continue in full force and effect.
(22) A decree in divorce, entered by a court of competent
jurisdiction to either Party, shall not suspend, supersede or
affect the terms of this Agreement. Both Parties agree to enter a
Consent Order or orders concerning the provisions of this Agreement
in the Cpurt of Common pleas of Cumberland County, Pennsylvania, or
.~
any other Court of competent jurisdiction, as a part of a
resolution of any divorce action filed or to be filed.
This
Agreement, and the terms and conditions contained herein, as well
as the enforcement of said terms and conditions, shall not be
contingent upon the granting of a Divorce Decree to either Party by
the Court of Common Please of Cumberland County, Pennsylvania, or
any other Court of competent jurisdiction.
Furthermore, both
Parties hereto agree to timely execute the appropriate affidavits
and consents to secure a No-Fault Divorce as may be required by the
Divorce Code of 1980, as amended. Both Parties hereto agree that
this Agreement may be incorporated into a separate court Order but
shall not merge in such order in t.h" Court of Common Pleas of
'J
Dauphin County, Pennsylvania.
(23) Husband and Wife acknowledge that Husband has instituted
a No-Fault Divorce Action docketed to No. 96-1092 in the Court of
Common Please of Cumberland County, Pennsylvania, pursuant to
3301(C) of the Pennsylvania Divorce Code, Act 26 of 1980, as may be
amended (hereinafter referred to as the "Code"). The provisions of
this Agreement may be incorporated in any divorce decree that may
be entered granting a decree of absolute divorce.
(24) In the event that either party breaches any provision of
this Agreement, and the other party retains counsel to assist in
enforcing the terms thereof, the parties hereby agree that the
breaching party will pay all attorney's fees, court costs and
expenses incurred by the other party in enforcing the Agreement.
(~~) This Agreement
constitutes
the entire
,.. .
understandlng
between the parties and there are no covenants, conditions,
representations, or agreements, oral or written, of any nature
whatsoever, other than those herein contained.
(26) This Agreement shall bind the parties hereto, their
respective heirs, executors and assigns.
(27) Husband has been independently represented by Karl M.
Ledebohm, Esquire, of the Law firm of Saidis, Guido, shuff &
Masland, and Wife, cognizant of her right to legal representation
and having had full opportunity to obtain counsel, declares that it
is her express voluntary and knowing i~tention not to avail herself
of independent counsel and chooses instead to represent herself
with respect to the preparation and execution of this Agreement.
10
. '
,
.
",'..,-
", .-
Print "Y Out.put
H6lSS 1 "lRIHO ttOtOt Strt:HO
D~.pl.)I Device TRPC)'!.51
User WH990CLw
aSVl Oal ".," HT~$CR 18060U8t
P")_ I
Il/J\/'J1 14;10:)1
lJ:lO:!:J6 11.2S 1109
HEDs To.Oate l~qu1ry
51Tt, JR, GEORGE L
HED O..ctiptlon
001 REGULAR
Current Honth Quartet Yur
)". liO 1,.471.40 l,lU.tO 11, :n9. 21
40.00 160.00 J6U.OQ 1. 11I0.00
IS'. ~1 5S4.U l,tH.16 1,SU.U
11." 40.00 10'. ]6 St1.1U
.00 .00 .00 1,t01."
.00 .00 .00 175.41
.00 .00 .00 ~. :u
.00 .00 ,00 ,00
.00 .00 .00 .00
.00 ,00 .00 .00
.lat'l
HOURS I
001 PREMIUM I.S-
.\at'l
HOURS.
010 PREHIUM 1.0
AIIt..
HOUllS ,
0.1 IHCrwrlVl PAY
Mtal
HOURS.
060 BONUS
.lat. I
HOURS.
ENTEAI JT-SCA Tax.. To-Date Inquiry
'.,)
Prin: liay Output
SlUSSl V)RIHO 940'O~ SItE990
P4qe
~1/~5/'7 1411~:)9
Display Deyice
Un,
TRPC1~SI
WH"OCLW
85'''' l Oli1
1187-:'1 NT-SeA
1):11:11 11-25 1109
180'08184
Hros To-Date Inquiry
SIfts JR, GEOAut L
"EO De~rlpt10n
eGG 80"'" t:urrent Honth Quarte, 'ieac
....t..t .00 .00 .00 .00
HOURS . .00 .0(- .00 ,00
07:;, SPEC IAI. PAY
'JIlt. I .00 .00 1'i.00 HO.OO
HOURS I .00 .00 .00 .00
0'0 RETRO...PAY
Aat.: .00 .00 .00 ')2.11
HOURS I .00 .00 .00 .00
100 VACATION
Aat'l .00 1).92 29').68 66S.n
HOURS. .00 '.00 l2 .00 12.00
110 HOLIDAY
"-tal .00 .00 .00 }61.20
HOURS , .00 .00 .00 40.00
E~~ERI JT...~R Taxes To-D4te rnqui.ry
EXHIBIT "s"
~D,S.
,..
,5"'
. '
D~'p1.,y DeY~~1t
UUl
Pont Iley lJlitput
\:':Sil VJR1HO 140~O' Slr[~'lll
'~d;i; I
11.!'l!'}1 11:1!):t'l
U5Vt 0]81
1181 HI H'r-seA
H!O. To-Dale InqUiry
KED OescrLptlon
110 HOL:DAY
"'-tll
HOURS I
140 BIREAVEirUHIRAL
Mt"
HOURS:
14~ SPEC PA1 OTHER
Mtll'
HOURS:
lS0 'IRSOHAL TIMI
AIIt.:
HOURS I
HO SAFlTY "NIUD
_tal
HOURS I
fIlPC.J"J',1
WH'J 'Nt: LW
1II06081lH
11:1.:11 ll~l') :10'1
5J1'E:, Iii, lO(ORGE L
Current Honth Q\~.U'tar Vue
,00 .00 ,00 16;.20
,00 .00 .00 .0.00
.00 .00 ,00 ,00
,00 , CO .00 .00
.00 .00 11.60 41.'5
.00 ,00 .00 .00
.00 ,00 .00 1 J. 11
.00 .00 .00 8.00
.00 ,00 ,00 .00
.00 .00 .00 ,00
rHl'lAI JT-SCR Taxes To-Dote Inqu.iry
'.
.~
,..
Print Key Output
~16]S51 V]RIHO 940,a9 SI~~9~1
Pc1Q'J 1
:1/2,/9' 14:10:S1
Display Ollvi.;. TRPe 3!lSl
U..r WKnOCLW
8SVl 0)81 178178 NT-$CA 1806081 U lJ;11: ]0 11-2!:l 1109
Hi:Ds Tc...D4te Inqui.ry SlTES JR. GCOP-GE :.
NED Descrip:'1on
GOG PRETAX LIFE INS Current Month QUdi:"t.1" Y84.[
.\ats: 1. 211 !:l.ll 11. ~ 1 61.4t
.00 .00 .CO .00
624 VAHCU.\RO LOAIl
A.IItSI .00 .00 ,00 ]')4 .00
.00 .00 ,00 .00
'18 PRETAX KHO
utal 26.'1 106.44 2J'J.n 1,211.52
.00 ,00 .00 .00
,n WHX DENTAL
ut't ).04 12.16 21. )6 145.'2
.00 .00 .00 .00
a"~ OPT LIrE DEPEND
,\at'l .00 .00 ,00 .00
.00 .00 .00 .00
ENTER: JT~SCR ~5xe~ t~-04te roqul~Y
-,
K .1).5 .
C s
~
, .
-'~ ..'
P....J<! I
II / ~ '1/1; I": Ii : 00
PI' ant "Y Output
\1. J5'i1 VIMIHO HQ'lO' !.J':'[UO
Dllplay D.v~c. TRPC1'iSl
User WHHOCLW
OSlJl o liP J ,.n. HT~SCR 1806001"
H(D, to-Oat. Inquiry
H[O Oelcnpt ~on
.,. OPT ~lrE DEPEND
Mtl'
,,.. "15C-O~
UUI
I" WW' IR DENTAL
btll
.11 WKX A , 5
UUI
114 WKX LIrE INS.
bUI
Current
,00
.00
.00
.00
.00
.00
.00
.00
.00
.00
"
rlfTUs JT"SCA Tu.. To-D.to Inquiry
III 11:l~ 1 L -1'1 1101
5IT[~ JH. ,~[OR~E ~
Honth ~,HHt.r Ye..,r
.00 .00 .00
.00 .00 .00
.00 .00 10.00
.00 .00 .00
41.00 H.OO l,61S.00
.00 .00 .00
H.Ol 41t.04 180.00
.00 .00 .00
11.00 24.00 421.00
,00 .00 .00
pnnt ..y Output
!l161SS1 VIRUM 9fO~Og SI'!U90
Dhphy D.\'11:. TRPCHSl
Uur WH990CLW
85Vl 0181 118111 NT-SCR 1 B0608184
HEOs to-Date Inquiry
HEIi Ducription
114 WH~ LirE INS.
t, Mtll
"0 40U
oUitll
'" NET PAY
Mtll
HOURS I
Current
.00
.00
S.2S
.00
168. '0
.00
ENTER: JT-SCR Tuu To-O",t. Inquiry
Paqa 1
11.'lS191 14:11106
1l:1l:44 Il-H 1107
SITES JR, GEORGE l
Honth Quart~r Year
12.00 24 .00 U8.00
.00 .00 .00
21.04 "ii.77 287.86
.00 .00 ,00
LOU.!.1 2,681.82 14,28B.2l
.00 .00 .00
,..
K/))'.
(.5