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:1 IN THE COURT OF COMMON PLEAS :
8 OF CUMBERLAND COUNTY 8
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.' STATE OF '",.;'. ,.r. PENNA. 8
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· i\: II. 13B2"C.jy~~u It) 96 .
* MARK ,A. VOGELSONG ~
8. VL'!',ill:i 8
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* VERONICA K. VOGELSONG .
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(I DECREE IN 8
:1 D I V 0 R C E _,.., ~
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~ AND NOW, .. .. .. . ~. .I.. .. .. .. .. ". 19 ~.~.. '. it is ordered and S
, $
~ decreed that ......... .~~~ .~:. ~'l<?~!--.~'l~<?!..~~.'.. . .. .. .. . .. " plaintiff, 8
8 and.... .. .. .. .. . Y)::.~Q~;r~.J\. !<....\:'Q,,)::.~E!Qt'l9.. .. . .. .. .. .. . .. .... defendant, 8
~ are divorced from the bonds of matrimony. ~
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" The court retains I'urisdiction of the following claims which have '.i
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(I been raised of record in this action for which a final order has not yet ~
" been entered; "
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: . . . . . . . . . . . . . . . . . . . : : : : : : : : : ~:~~ : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : i:
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lite, and attorney fees and expenses.
The parties were married on November 20, 1976, and
separated March 1, 1996, They are the natural parents of two
children, one of the children is a student at Penn State
University and the another child is a student at Cumberland
Valley High School.
We are going to place an agroaelllent on the record in
the presence of the parties, The agreement as placed on the
record will be considered the substantive agreement of the
parties and will not be subject to any changes or modifications
except for correction of typographical errors. The Master's
court reporter will prepare a draft of the agreement to send
around to counsel to review for any typographical errors. After
any corrections are made, the parties and counsel will be asked
to sign the agreement as an affirmation of the terms of the
agreement as placed on the record at this time, There will be
no changes of a substantive nature to the agreement after we
leave this conference today.
After the agreement has been returned, the Master
will prepare an order vacating his appointment and counsel can
file a praecipe transmitting the record to the Court requesting
a final decree in divorce at the prescribed time they agree
upon.
The Master has been provided today with affidavits
of consent and waivers of notice of intention to request entry
of divorce decree which have been signed and dated by the
parties. The Master's office will file those documents with the
Prothonotary,
Mr. Bangs,
MR, BANGS: The parties agree to a division of the
marital assets and marital debts in accordance with the
following:
1, Defendant, Veronica Vogelsong shall retain the marital
residen~e at 81 Old willow Mill Road, Mechanicsburg,
Pennsylvania (WhiCh is made up of two parcels of land).
Mr. Vogelsong will agree to take any and all steps
necessary to insure that that property is transferred to
her within sixty (60) days of the date of this agreement,
2. Mrs. Vogelsong shall receive a rollover of $9,000.00
trom Mr. Vogelsong's retirement account through EXEL
Logistics. Mr. Vogelsong's attorney shall advise Mrs.
Vogelsong's attorney as to the steps necessary to insure
that this rollover takes place either in the form of a
direct rollover to an IRA or a rollover through a QDRO,
3, Mrs, Vogelsong is to receive $4,000,00 in cash from Mr.
Vogelsong, $2,000.00 shall be paid within thirty (30)
days of the date of this agreement. The remaining
$2,000,00 shall be paid within ninety (90) days of the
date of this agreement.
4, Mr, Vogelsong shall retain the remainder of his
retirement/savings account through EXEL Logistics, his
retirement account through Corestates, any and all
savings and checking accounts that are in his
possession, his gun collection, his 1991 Dodge Ram
pick-up truck, and any and all personal property that he
has removed from the marital residence.
5. Wife will retain any and all personal property that she
has in the marital residence, and her 1988 Buick Skylark,
6, The parties also agree to divid~ the marital debt.
Husband shall retain full responsibility for the debt
owed to Belco, which is currently a lien against the
house, He shall indemnify and hold wife harmless in the
event that he fails or refuses to pay that debt in full
on a timely basis, That debt was used for the purchase
of husband's vehicle,
Wife agrees to retain the responsibility for the debts ac
follows: Visa, Montgomery Ward, Stewart's, Sears,
Bon-Ton, BoscoV's, furance repair, repair to driveway,
the real estate taxes on the property, and any
outs~anding loan for the water hook-up and car repair,
7, Wife agrees to waive her claim for alimony, alimony
pendente lite, and counsel fees. In lieu thereof,
husband agrees to continue to provide medical insurance
coverage for Mark and Wesley until they graduate from
college as provided by his employer or until such time
as they are no longer in college and, therefore, not
eligible under the plan of the employer,
8, The parties agree that they shall cooperate to insure
that all claims that can be submitted are submitted to
the applicable insurance plan.
Husband specifically agrees that he shall provide wife
with any and all forms or medical cards necessary to
insure that wife and/or Mark or Wesley can submit the
claims for the two children to the appropriate carrier,
9, In the event that mother pays any of the unreimbursed
medical expenses for the children while they are enrolled
in college, father agrees to be responsible for 1/2 of
those medical expenses up to a maximum of $50.00 per
month, per child, for a cummulative total of $600.00 per
year, per child, which should continue on through the
time that they are in school,
Mother shall provide father with information as to
any and all payments she makes within thirty (30)
days and father shall make arrangements directly with the
providers to pick up his portion of those costs as
defined in this agreement.
10. In the event of a breach of this agreement by either
party, the nonbreaching party is entitled to bring an
action against the breaching party for any and all
damages as a result of the breach which shall include
but not be limited to all costs and attorney fees for
enforcement of the agreement.
11, Except as herein otherwise provided, each party may
dispose of. his or her property in any way and each party
.
MR, VOGELSONG: Yes.
MR. BANGS: Mrs. Vogelsong, you have sat here and
listened to me dictate what purports to be the agreement between
the two ot you?
MRS, VOGELSONG: Yes.
MR. BANGS: And did you understand allot the terms
and the conditions ot the agreement?
MRS. VOGELSONG: Yes,
MR, BANGS: Does the agreement, as I dictated,
accurately and completely retlect your understanding and your
agreement in this case?
MRS. VOGELSONG: Yes,
MR. BANGS: Do you have any questions at all about
the agreement?
MRS, VOGELSONG: No.
THE MASTER: Mrs, Vogelsong, do you understand that
when you leave here today that there will be no substantive
changes to this agreement; that the agreement that is stated on
the record is the tinal agreement except tor any correction ot
typographical errors?
MRS, VOGELSONG: Yes,
THE MASTER: Mr. Vogelsong, you heard the question
that I asked your wite, Do you understand that this is the
tinal agreement. When you leave here today, there are no
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 'l~ i J j~ l't<.d T~.",-
MARK A. VOGELSONG, SR.,
plaintiff,
CIVIL ACTION - LAW
VERONICA A. VOGELSONG,
Defendant.
IN DIVORCE
COIl1'LAIII'1' III DIVORC.
AND NOW, comes the Plaintiff, MARK A VOGELSONG, SR., by
and through his attorneys, MANCKE, WAGNER, HERSHEY' TULLY, and
files the following Complaint in Divorce:
1. The Plaintiff, MARK A. VOGELSONG, SR., is an adult
individual currently residing at 7180 wertzville Road, Carlisle,
cumberland county, Pennsylvania.
2. The Defendant, VERONICA A. VOGELSONG, is an adult
individual currently residing at 81 Old Willow Mill Road,
Mechanicsburg, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant have both been bona fide
residents of the Commonwealth of Pennsylvania for at l~ast six
(6) months prior to the filing of this Complaint.
4. Plaintiff and Defendant are husband and wife having
been married on November 20, 1976, in Harrisburg, Dauphin county,
Pennsylvania.
5. There have been no prior actions of divorce or
annulment between the parties in this or any other jurisdiction.
6. Neither Plaintift nor Defendant are members of the
Armed Porces of the united states or any of its Allies.
7. plaintitf has been advised of the availability of
counseling and that he has the right to request that the Court
require both parties to participate in counseling.
8. The Plaintiff avers as grounds on which this action
is based are:
(a) that the marriage is irretrievably broken; and
(b) that as of March 1, 1998, the parties will have
lived separate and apart for a period of at least
two (2) continuous years.
WHEREFORE, Plaintiff prays this Honorable Court to
enter a Decree in Divorce.
COOHT I
.OUI~ABL. DI8TRIB~IO.
9. Paragraphs 1 through 8 above are incorporated
herein by reference and made a part hereof.
10. During the marriage, Plaintiff and Defendant have
acquired various items ot marital property, both real and
personal, which are subject to equitable distribution under
section 401 of the Divorce Code of 1980.
WHEREFO~E, plaintiff prays this Honorable Court:
(a) Enter a Decree in Divorce;
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IJOGILSONG ....NSlllA UG911DISK 1
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MARK A. VOGELSONG, SR.,
Plaintiff
vs.
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IN THE CDURT OF COMMDN PLEAS
DF CUMBERLAND COUNTY,
PENNSYLVANIA
VERDNICA K. VDGELSONG,
Defendant
CIVIL ACTIDN - LAW
NO. 96-1382 CIVIL TERM
IN DIVORCE
ANSWER WITH COUNTERCLAIM
1. Admitted.
2. Admitted.
3. Admitted.
4. Admitted.
5. Admitted.
6. Admitted.
7. Admitted.
8. Admitted.
9. Admitted.
10. Admitted.
COUNTERCLAIM
11. Answers to Paragraphs 1 through 10 are incorporated hsrein by
reference as though more fully set forth herein.
1
COUNT I - ALIMONY
12. The Defendant has not worked on a regular basis during much of the
marriage of the parties. but instead devoted herself to rearing the children of the
parties and to making a good and adequate home for the family.
13. The Defendant is unable to support herself and is dependent upon the
Plaintiff for financial support and maintenance.
14. The Plaintiff is employed and enjoys a substantial income and is well
able to contribute to the support of the Defendant.
WHEREFORE. Defendant pra~'s this Honorable Court to enter its Drder
awarding Defendant from Plaintiff permanent alimony in such sums as are
reasonable and adequata to support and maintain Defendant in the station of life to
which she is accustomed.
COUNT II-ALIMONY PENDENTE LITE AND COUNSEL FEES AND EXPENSES
15. Defendant is without sufficient funds to retain counsel to represent her
in this matter.
16. Without competent counsel, Defendant cannot adequately prosecute her
claims against Plaintiff and cannot adequately litigate her rights in this matter.
17. Defendant is without sufficient income to support and maintain herself
during the pendency of this action.
2
CERTIFICATE OF SERVICE
J HEREBY CERTIFY that J have this day servsd the foregoing Answer with
Counterclaim by depositing e copy of same in the United States mail, postage
prepaid, at Camp Hill, Pennsylvania, addrsssed to the following:
P. Richard Wagner, Esquire
Mancks, Wanger Hershey & Tully
2233 North Front Street
Harrisburg, PA 17110
DATE,rl~..tI711 ~i;!~~
'AO"' HAHCKI WAOH!A HIASHIY
,AlCI 23.,.S8
J."-2.... Wed 1,.,1
'All" 13
IWtX A. VOOILSOKG, Sit. , IN THI COURT or COMMON PLlA8
I CUMBIJtLAND COUNTY, plIQfSYLVAJlIA
plaintiff, I
v. I NO. U-U13
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I CIVIL ACTION - LAW ....., /
"
VatONICA J{. VOOILSONG, I /1".
I IN DIVORCE .. ' --
Defendant., I
UWID.vt'l' O. COlI.....
1. A Co.plaint. in Divorge under Seot.ion 3301(C) ot t.he
Divoro. Cod. wa. filed on ,j- 1.1. 9~ .
2. Th. .arriaga of plaintiff and Defendant 1.
irretrievably broken and ninety ('0) day. have alap.ed froa the
date of tiling and .ervica of tha Complaint.
3.
att.er servica
daoree.
1 oonaent to t.he entry of a tinal decr.e of divorce
of not.ioe ot intention to raque.t. ent.ry ot ~e
4. I under.tend that. I aay 10.. right. concernlng
all.ony, divi.lon ot property, lawyer'. tea. or axpan.e. if I do
not olai. tha. batore a divorce i. granted,
I verity t.hat the .tat..ent. .ade in thi. attidavit. are
t.ru. and oorreot. I under.t.end that. tal.. .tata.ent. herein are
made sUbjact. to the penalti.. ot 18 Pa.e.s. sect.ion .904,
relating to un.worn falliticat.ion to aut.horitie..
DATE: /-j!- /c?tlf'
Wt:1~.~'onr ~ I
'.0"' "AMewl waG"'. HI_SHCY
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IIAU A. VOGELSONG, SI" I
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VIRONICA 1(, VOGBLSOIIG, I
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Detendant. I
IN TUB COtlltT 0' COIlKON PLBAS
CUIOlIRLAND COUIITY, PIllHSY10VAlfIA '
NO, 96-1383
CIVIL ACTION - LAW
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IN DIVORCB
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.:ann... .JIIIIIIY O. .a DI.,.O. D.mt.. tlfDD
.~!ftII ~JlDllal 0.,.. Dlvo.e. eon.
1. I oon..nt to the .ntry ot ~ final deore. ot divorce
without notice.
a, I understand that I .ay lose rights oonoerning
a1iaonY1 divi.ion of property, lawyer'. t.e. or expenses it I do
not cla . the. betor. a divorce is granted.
3. I understand that I will not be divoroed until a
divorce decree i. entered by the Court and that a copy of the
decree will be .ent to .e lamedietely efter it ie tiled with the
prothonotuy.
I verity that the state.ent. aade in this affidavit are
true and correct, I underetand that tel.e atate.ent. herein are
..de .Ilbject to the pena1tiee of 18 Pa,C,S, 54904 relating to
unsworn talsification to Authorities.
~~!)1~~7vi.
DATBI I-,J't - JlfCl?
.
OFF'C. 0' DlVOIIC. MASTIR
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle. PA 17013
(71 7) 240.6535
I. .....rt IUckor, ..
Dlvorc. Mast.,
Trae' "'. Colyor
OIfle. M."aga,/Raporla,
Wo.t lho...
697,0371 EAt. 6535
July 22, 1997
p, Richard Wagner, Esquire
MANCKE, WAGNER, HERSHEY & TULLLY
2233 North Front Street
Harrisburg, PA 17110
RE: Mark A, Vogelsong, Sr, vs, Veronica A, Vogelsong
No. 96 - 1382 Civil
In Divorce
Michael L. Bangs, Esquire
302 South 18th street
Camp Hill, PA 17011
Dear Mr. Wagner and Mr, Bangs:
By order of Court of President Judge Harold E. Sheely
dated June 2, 1997, the full-time Master has been appointed in
the above referenced divorce proceedings, The reason the Master
has delayed is getting a directive to counsel regarding the
filing of pre-trial statements is that the Master's office did
not receive the motion for appointment of Master form until JUly
22, 1997. Apparently the original form was lost or misplaced in
the prothonotary's office and we were provided a copy of the
motion and order by Mr, Bangs' office.
A divorce complaint was filed on March 13, 1996, raising
grounds for divorce of irretrievable breakdown of the marriage
and the economic ,claim of equitable distribution.
I am unabl& to tell from the pleadings whether or not
there is any issue with respect to grounds for divorce. I am
going to assume, however, that the parties are willing to sign
and file affidavits of consent so that the divorce can proceed
under Section 3301(c) of the Domestic Relations Code, Based on
that assumption, I am directing each counsel in accordance with
P,R.C.P, 1920,33(b) to file a pre-trial statement on or before
Friday, August 22, 1997, Upon receipt of the pre-trial
.
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96 - 1382 CIVIL TERM
MARK A, VOGELSONG, SR.,
Plaintiff
VERONICA K, VOGELSONG,
Defendant
IN DIVORCE
RE: Pre-Hearing Conference Memorandum
DATE: Monday, December 1, 1997
Present for the Plaintiff, Mark A, Vogelsong,
sr" is attorney P. Richard Wagner, and presQnt for the
Defendant, Veronica K. Vogelsong, is attorney Michael L, Bangs.
A divorce complaint was filed on March 13, 1996,
raising grounds for divorce of irretrievable breakdown of the
marriage and the economic claim of equitable distribution.
Counsel have advised that the parties will sign and file
affidavits of consent and waivers of notice of intention to
request entry of divorce decree prior to the hearing to be
scheduled in these proceedings,
On August 20, 1997, wife filed a counterclaim
raising the additional economic issues of alimony, alimony
pendente lite, and attorney's fees and expenses. Counsel have
indicated that there may be some testimony regarding the alimony
claim factor of marital misconduct as that factor affects wife's
alimony claim, The basis of that testimony would be husband's
alleged relationship with a female prior to the parties'
separation and also alleged physical abuse against wife by
husband. Mr, Wagner is going to talk to his client to see if he
can stipulate that his client was involved with a female friend
prior to the separation, and Mr. Bangs is going to present Mr.
Wagner medical verification of the alleged physical abuse, If a
stipulation can be reached on that issue, then no testimony will
be offered at the hearing; otherwise, counsel are directed to
advise each other within a month of the date of the hearing as
to what witnesses will be testifying on that issue.
The parties were married on November 20, 1976,
and separated March 1, 1996, They are the natural parents of
two children. One of the children is a college student at
Bloomsburg University where he is a sophomore. The other son is
a senior at Cumberland Valley High School. Both children live
with the mother,
Husband is 38 years of age and resides at 7180
~
Wertzville Road, Carlisle, Pennsylvania, where he lives with a
female friend, He is a high school graduate and is a forklift
operator for Keen Transport, His net monthly income husband
reported on the support evaluation is $2,218,00, Husband has
medical insurance coverage through his employment, He is
currently paying $40.00 per week spousal support and $100.00 per
week for the minor child, He has not raised any health issues
except high blood pressure,
Wife is 38 years of age and lives at 81 Old
willow Mill Road, Mechanicsburg, Pennsylvania, where she resides
with the two children of the marriage, She is a high school
graduate and works as a secretary for an insurance company,
Black, shue, and Davis, According to the support information
used to enter a support claim, the support office determined her
net monthly income to be $1,305.00, Mr. Bangs is going to check
on the status of her medical insurance coverage, and if she does
not have any through her employment, whether or not she will be
able to claim COBRA benefits through her husband's employment,
Wife has not raised any health issues.
The parties own a property at 81 Old Willow Mill
Road, Mechanicsburg, which includes a home and two acres of
unimproved land which is in the flood zone. Counsel have agreed
that the property has a value for purposes of equitable
distribution of $38,700,00. There is a lien against the
property which has a payoff of around $5,700.00. This lien
arises out of a loan which has been used to purchase husband's
Dodge pickup truck. Husband has been making the payments on
account of the loan,
Husband has a retirement account with his prior
employer, EXEL Logistics, and the value as of March 31, 1996,
was $41,499.44, Counsel are going to provide an updated
statement as of the date of the hearing so we have a current
value for that account.
Husband also had a retirement account with
Core States , and counsel for husband believes that he closed out
that account and received a sum in excess of $2,800,00, Mr,
Wagner is going to provide information as to what amount husband
received from that account and when the money was withdrawn,
The parties have listed various savings and
checking accounts with BELCO and PNC Bank, and we will use the
values which they have provided on the pretrial statement and
interrogatories, None of the accounts have any substantial
amounts. There is an IRA at Corestates which had a balance of
around $450.00 on April 30, 1996.
.
Husband has a 1991 (wife indicated a 1994) Dodge
Ram pickup truck. Exclusive of the loan, husband says that the
truck has a net value of $2,000.00. Mr, Bangs is going to take
a look at the blue book to see if he can agree with that
suggestion as to value,
Wife has a 1988 Buick Skylark vehicle which wife
claims has a negative value based on her appraisal of the car of
$1,000.00 and a debt of around $1,950.00. Husband has placed a
value on the vehicle as $2,000.00 but was not aware of the debt;
however, husband would agree that if there was a debt of around
$1,950.00, the car would have no value for purposes of equitable
distribution, Mr, Bangs is going to provide information to Mr.
Wagner as to the existence of the debt against the Skylark,
There has been no specific value suggested for
the household tangible personal property, and we may have to
have some testimony by the parties as to what amount each of the
parties received. Counsel suggests perhaps that each of the
parties may keep what each has in his or her possession without
using a value for equitable distribution purposes; however,
there is a gun collection which was appraised at $1,590,00 and
the issue arises as to whether or not that amount should be
included in the property which husband received or whether or
not that should be considered as a separate item for valuation
and inclusion in the equitable distribution computation to
arrive at the total value of the marital estate,
Wife claims that husband's mother has a farm
which she intends to transfer an interest to her son, the
husband herein, as well as to another son, The mother has
already apparently transferred a one-third interest to husband's
sister. The question arises as to mother's intentions with
" regard to the disposition of the farm and whether or not this
value can be considered as a separate estate for husband and
should be considered as a factor with respect to his opportunity
and ability to acquire an asset in the future, Counsel for
husband will need to present the position that the issue is too
speculative to be considered, and Mr. Bangs, on the other hand,
will attempt to show that there is a very real intention by
husband's mother to transfer the interest in the farm, perhaps
as soon as these divorce proceedings have been all resolved. In
any event, we can take testimony on this issue separately if
counsel think that is an appropriate way to appr~ach the case;
otherwise, we will include it in the testimony on all of the
other issues that have been identified.
wife has listed various items of marital debt on
her pretrial statement, and we will need to have the date of
e! Savings and Checking accounts (Wife)
Belco Less than $100.00
f) Camper Unknown
gl Gun Collection (HI $1,590.00
$1,575.00
(Husband's appraisals)
hI Husband's car Unknown
1994 Dodge Ram Pickup Truck
il Wife's car $1,000.00
19B8 Buick Skylark (debt owed on car to
Belco. $1.948.88 as
of separation)
jl Personal property in marital residence $500.00
kl Personal property removed by Husband $1,000.00 + /-
including extensive tool collection and
other property
I) Personal property stored at in-laws' house Unknown
(antique bed frame; refrigerator; tools)
ml Husband's interest in Mother's farm Unknown
2. LIABILITIES
al Husband's list of liabilities
Belco account #419160 $10,03B.88 (2/29/96)
Belco VISA #419160 $1,634.84 (2/29/96)
1995 tax bill paid to I.R.S. $403.00
.Wife does not acknowledge that these are
marital liabilities since the she does not know
how they were incurred
b) Wife's list of liabilities
Loan for water hook-up and car repair $1,674.82
2
ASSETS OF PARTIES
Plaintiff 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 anached.
(xl 1. Real property
(x) 2. Motor vehicles
( ) 3. Stocks, bonds, securities and options
( ) 4. Certificates of Deposit
( ) 5. Checking accounts, cash
( ) 6. Savings accounts, money market
( ) 7. Contents of safe deposit boxes
( I 8. Trusts
( ) 9. Life insurance policies (indicate face value, cash
surrender value and CUHent beneficiaries)
() 10. Annuities
( ) 11. Gifts
( ) 12. Inheritances
( I 13. Patents, copyrights, inventions, royal'lles
( ) 14. Per::lonal property outside the home
( ) 15. Businesses (list all owners, including percentage
of ownership, and officer/director positions held
by a party with a company)
( ) 16. Employment termination benefits. severance pay,
workman's compensation claim/award
(xl 17. Profrt sharing plans
(xl 18. Pension plans (indicate employee contribution and
date plan vests)
(x) 19. Retirement plans, Individual Retirement Accounts
( I 20. Disability payments
( ) 21. Utlgatlon claims (matured and unmatured)
( I 22. MilltaryN.A. benefits
( ) 23. Education benefits
(xl 24. Debts due, including loans, mortgages held
(xl 25. Household furnishings and personalty (Include as a
total category and anach itemized list if
distribution of such assets is in dispute)
( I 26. Other
,
Mark A. Vogelsong, SrJ ?~a.':';1t:;,~~
:~ ~S! ~~ca~ Cl C:~_~ON ?~Z~3
==ON~!, ?!~TNS~~'AN:A
7 .
:~ 3cr?;oCR~
Veronica K. Vogelsong, :let i1nc!ant:
96-1382
nrcom: ~ D:i'~S1!: S':A~~
SU!UIZ'l!':!1l 3!:
Ma.r:k Alan VogelsollQ Sr.
?ull "alii. of E'laintit~
38
do...
7180 t>>9r~~j lIe R~ri. Carlislej PA 17013
?~.~..ne! =.s~~: ?~~~:~-~
717-7960-0349
:a~a;non. ~umc.~
r~ exc~~ for hiah blnnn oressure
3~ac~.s ~.. ?:'J.':"..'1::..:=15 :.a.l.:.."1 (3. 3gec:'::"':J
17013
~.ng~~ ~ Sa~7~C8
.~:~ :~is ~~91Qye=
~ hrs. ;;eek S550.00 oft varies
]_4~~:~.:_ls :~=IQC :;c~..
4C~~S !.=~.d Z~~;m.
?~= ?1.~' ;;/e.:<':'''' :-!onc.~.!. ., !aa:l~'
-
projected
$617.81 $617.81 $2',468.00 ~~?.nR.4 nn
~r~ss crQe..~ed :~cQm.
:~e~L G~~ss ~cQme
617.81
$617.81
$2,468.00
$32,084.00
Deduc1:ioQ.S :
?de~a':'
5104.69 per week
31:1:. :.;1c. !u
17.28
38.31
10.38
?:. :..\.
3o"9/l1ec! :;1.5.
CERTIFICATE OF SERVICE
I, Debra K. Spinner, Secretary in the law firm of
MANCKE, WAGNER, HERSHEY, & TULLY, do hereby certify that I am
this day serving a copy of the foregoing document to the
following person and in the manner indicated below, which service
satisfies the requirements of the Pennsylvania Rul~s of Civil
Procedure, by depositing the same in the United States Mail,
Harrisburg, Pennsylvania, with first class postage, prepaid, and
addressed as follows:
Michael L. Bangs, Esquire
302 South 18th Street
Camp Hill, PA 17011
J '
By lLlt.l t... .r: " \ ill-') V)U.J
Debra K. Spinner; Secretary
MANCKE, WAGNER, HERSHEY' TULLY
2233 North Front Street
Harrisburg, PA 17110
P. Richard Wagner, Esquire
Attorneys for Plaintiff
DATE: /1j.,f<jN'7
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(I)
to 81 Old Willow Mill Road, Mo:chanicsburg. Po:nnsylvania. 17055. unless otherwise notitied by
Altemate Payee,
6. Mo:mber's Plan accounts arc marital property suhject to distrihution by thc court and
has been distributed by the court as hcreinano:r described.
7. Aitemate Payee shall receive Nine Thousand and 00/100 (S9.000.00) Dollars. adjusted
for earnings and losses. from January 28. 1998. until the date of distribution. The Plan
Administrator. in its sole discretion, shall determinc the applicable arnount of earnings and losses
that shall be allocated from Member's plan to Alternate Payee's account.
8. In the event that the Plan Administrator cannot segregate the sums stated in Paragraph
7 above. then Member shall designate Altemate Payee as an irrevocable beneficiary for the
amount set forth in Paragraph 7 above, which is $9.000.00, adjusted for earnings and losses, from
January 28. 1998, until Member enters pay status and shall complete and execute all the
paperwork and authorization necessary to accomplish same.
9. Altemate Payee may begin receiving her benetits in noy form permitted under the Plan
at any time after the Plno Administrator approves this Order as a Qualified Domestic Relations
Order nod noy applicable appeals period expires. In the event Alternate Payee predeceases
Member, payment shall be made to Altemate Payee's designated benet1ciary.
10. The parties intend nod agree that the terms of this Stipulation be approved. adopted,
and entered as a Qualified Domestic Relations Ordo:r.
..,