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Home My WebLink About96-01567 ~ \ '",I,-.. ""-" / /' J J r.... ~ ~/ --s <;J"'; , j ~! <'I ! :0.- r'" ;:(~ (~ II,.(! ~? , (r-i! , c.., S" " J" , [ (1' r~. WI." ('J -~ LI:I- , " , r ,. c...c ". In '- 0 , (n i..) ;1 .... .... i ~ " .... C '" '... nl ~ .... 'tl M C J ~ ;:; ,,.j cz: ;:: ~ nl ~~ ~~ ;:;. ..... ll. '" i "'~ j>; ~ . ~ ~ s< ~ . . :: ~ I . I ~e:: u:~ .. ~~ > U1:j ~ e." ~~ ~j ~ C.l :3 ., r-- CIl ;1 ;1 '" III . . ~ Z ;:: ..... ..., u E I 0 '" I I H U ~ '" ~ ~ . ~ .,. .,"",,7 ..- ~...' oil ,,: .--." ...... ft ., .- . " . . .' . C< )NSTANCE p, BRUNT ArrllR,~FY AI' u.w __.-J _. ~. . . ,: ~ .. . J .' . , . parties being estranged due to such marital difficulties with no reasonable expectation of reconciliation; and the parties hereto are desirous of settling fully and finally their respeccive financial and property rights and obligations as between each other, including, without limitation by specification: the settling of all matters between them relating to the ownership of real and personal property; the settling of all matters between them relating to the past, present, or future support and/or maintenance of Wife by Husband or of Husband by Wife; and in general, the settling of any and a.ll claims and possible claims by one against the other or against their respective estate, particularly those responsibilities and rights growing out of the marriage relationship; and WHEREAS, both Husband and Wife have been fully, sepa- rately and independently advised of their legal rights and obligations, and each covenants that he and she has each made a full and complete disclosure to the other of his or her respec- tive property, holdings and income; and The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel. The Husband has employed and had the benefit of counsel of CONSTANCE P. BRUNT, ESQUIRE, as his attorney, The Wife has employed and had the benefit of counsel of KEITH B, DeARMOND, ESQUIRE, as her attorney, Each party acknowledges that he or she has received independent legal advice from counsel of his or her 2 . J . , . selection and that each fully understands the facts and has been fully informed as to his or her legal rights and obligations, Each party acknowledges and accepts that this Agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having receLved such advice and with such knowledge, and that execution of this Agreement is not the result of any duress or unrlue influence and that it is not the result of any collusion or improper or illegal agreement or agreements, In addition, each party hereto acknow- ledges that he or she has been fully advised by his or her respective attorney of the impact of the Pennsylvania Divorce Code, whereby the Court has the right and duty to determine all marital rights of the parties, including divorce, alimony, alimony oendente lite, equitable distribution of all marital property owned or possessed jointly or individually by either party, counsel fees and costs of litigation, and, fully knowing the same and being fully advised of his or her rights thereunder, each party hereto still desires to execute this Agreement, acknowledging that the terms and conditions set forth herein are fair, just and equitable to each of the parties, and waives his and her respective right to have the Court of Common Pleas of Cumberland County or any other court of competent jurisdiction make any determination or order affecting the respective parties' rights to a divorce, alimony, alimony oendente lite, equitable distribution of all marital property, counsel fees and costs of litigation, 3 . " ~ . " , NOW, THEREFORE, in consideration of the premises and of the promises, covena~ts and undertakings hereinafter set forth, and for other good and valuable consideration, the receipt of which is hereby acknowledged by each of the parties hereto, Husband and Wife, each intending to be legally bound hereby, covenant and agree as follows: 1. SEPARATION, It shall be lawful for each party at all times hereafter to live separate and apart from the other at such place and places as he or she may from time to time choose or deem fit, free from any control, restraint or interference, direct or indirect, by each other, Neither party shall molest the other or compel or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceedings, The foregoing provision shall not be taken to be an admission on the part of either party of the lawfulness or unlawfulness of the causes leading to their living apart, 2. SUBSEQUENT DIVORCE. The parties hereby acknowledge that Husband has filed a Complaint in Divorce in the Court of Common Pleas of Cumberland County, Pennsylvania, docketed to No, 96-1567 Civil Term, claiming that the marriage is irretrievably broken under the no-fault, mutual consent provisions of ~3301(c) of the Pennsylvania Divorce Code, The parties hereby express their agreement that the marriage is irretrievably broken and express their intent to execute contemporaneously with the execution of this Agreement any and 4 4 . oJ . . . \, . all affidavits or other documents necessary to obtain an absolute divorce pursuant to ~)301(c) of the Divorce Code, The parties hereby waive all rights to request Court-ordered counseling under the Divorce Code, Neither party to such action shall seek alimony or support contrary to the provisions of this Agreement, It is further specifically understood and agreed by the parties that the provisions of this Agreement relating to equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever, as contemplated by the Pennsylvania Divorce Code, Should a decree, judgment or order of separation or divorce be obtained by either of the parties in this or any other state, country or jurisdiction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be affected in any way by any such separation or divorce; and that nothing in any such decree, judgment, order or further modification or revision thereof shall alter, amend or vary any term of this Agreement, whether or not either or both of the parties shall remarry, it being understood by and between the parties hereto that this Agreement shall survive and shall not be merged into any decree, judgment, or order of divorce or separation, Notwithstanding the provisions of the Pennsylvania Divorce Code or of any law to the contrary, none of the terms and provisions of this Agreement shall be subject to modification by the Court or in any fashion other than as set forth hereinafter. 5 ~ . J... J . \, . It is specifically agreed, however, that this Agreement shall be subject to enforcement under the provisions of the Pennsylvania Divorce Code or, at the option at the aggrieved party, by a suit against the alleged breaching party either in law or in equity. 3. EFFECTIVE DATE, The effective date of this Agreement shall be the "date of execution" or "execution date", defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement, 4. DEBTS AND OBLIGATIONS. Husband represents and warrants to Wife that since the separation he has not, and in the future he will not, contract or incur any debt or liability for which Wife or her estate might be responsible, and he shall indemnify and save Wife harmless from any and all claims or demands made against her by reason of such debts or obligations incurred by him since the date of said separation, except as otherwise set forth herein, Wife represents and warrants to Husband that, since the separation, she has not, and in the future she will not, contract or incur any debt or liability for which Husband or his estate might be responsible, and she shall indemnify and save Husband harmless from any and all claims or demands made against him by 6 ~ . .. . . ~ reason of such debts or obligations incurred by her since the date of said separation, except as otherwise set forth herein, 5. MUTUAL RELEASES, Husband and Wife do hereby mutually remise, release, quit-claim or forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, from any and all rights, title and interest, or claims in or against the estate of such other, of whatever nature and wherever situate, which he or she now has or at any time hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or curtesy; or claims in the nature of dower or curtesy, or widow's or widower's rights, family exemption or similar allowance or under the intestate laws; or the right to take against the spouse's will; or the right to treat a lifetime conveyance bv the other as testamentary; or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory of the. United States, or any other country; or any rights which either party may now have or at any time hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except, and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise 7 , , ,,, . . .. under this Agreement or for the breach of any provision hereof. It is the intention of Husband and Wife to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except, and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision hereof. 6. DIVISION OF HOUSEHOLD AND PERSONAL PROPERTY. The parties hereto have divided between themselves, to their mutual satisfaction, all items of tangible and intangible marital property, Except as otherwise set forth hereinafter, neither party shall make any claim to any such items of marital property, or of the separate personal property of either party, which are now in the possession and/or under the control of the ether. Should it become necessary, the parties each agree to sign, upon request, any titles or documents necessary to give effect to this paragraph, Property shall be deemed to be in the possession or under the control of either party if, in the case of tangible personal property, the item is physically in the possession or control of the party at the time of the signing of this Agreement, and in the case of intangible personal property, if any physical or written evidence of ownership, such as passbook, checkbook, policy or certificate of insurance or other similar 8 , ...', .' ~ . writing is in the possession or control of the party, Anything to the contrary contained herein notwithstanding, Husband and Wifo shall be deemed to be in the possession and control of any pension or other employee benefit plans or other employee benefits of any nature to which either party may have a vested or contingent right or interp.st, apart from the provisions of the Divorce Code, at the time of the signing of this Agreement. 7. PROCEEDS OF MARITAL RESIDENCE, The parties acknowledge that they sold their marital residence at B2B Lewisberry Road, Lewisberry, Pennsylvania, in July, 1995, receiving total net proceeds of $72,674,25. The parties further acknowledge that the said net proceeds were distributed between them at that time with Wife receiving the sum of $43,604.55, and Husband receiving the sum of $29,069.70, Within thirty (30) days of the execution of this Agreement, Wife shall deliver to Husband's counsel on Husband's behalf the sum of $10,000,00 from the said proceeds she previously received, The parties agree that Wife shall retain the sum of $33,604,55 from the proceeds as her sole and separate property and that Husband shall retain the sum of $39,069,70 from the proceeds as his sole and separate property. The parties further agree that they shall each be responsible for claiming one-half of the capital gain realized upon the sale of the said martial residence, and that each shall 9 . ./.# .' '# pay any appropriate taxes, penalties or interest associated with their one-half of the capital gain, Each shall indemnify and save the other harmless from any liability for taxes, penalties or interest which may be assessed on the one-half of the capital gain for which he or she is responsible by the terms of this Agreement, 8. VEHICLES, Wife shall retain possession and ownership of the 1992 Buick Regal Custom Sedan, which is presently in her possession, free and clear of any claim, right, title or interest in said vehicle on the part of Husband, Husband shall retain possession and ownership of the 1985 Chrysler LeBaron convertible, which is presently in his possession, free and clear of any claim, right, title or interest in said vehicle on the part of Wife. The parties acknowledge that the 1987 Volkswagen Fox sedan was sold by Husband subsequent to separation for the sum of $1,500.00, They further agree that Husband shall retain the said proceeds as his sole and separ.ate property. 9. DISTRIBUTION OF CASH ASSETS. STOCKS AND BONDS. The parties agree that they have satisfactorily divided the cash assets and savings bonds which they held at the time of their separation, Each shall retain as his or her sole and separate property any such cash assets, stocks or bonds which they have 10 .... -, . -, ., . heretofore received or which are currently in their possession, free from any claim on the part of the other party, 10. WIFE'S PUBLIC SCHOOL EMPLOYES' RETIREMENT SYSTEM PENSION, Wife shall retain as her sole and separate property her entire Public School Employes' Retirement System pension account, free and clear of any claim on the part of Husband, 11. HUSBAND'S CENTRAL PENNSYLVANIA TEAMSTERS PENSION PUND ACCOUNT, The parties acknowledge that Husband is a participant in the Central Pennsylvania Teamsters Pension Fund, which consists of both a defined benefit pension, designated Benefit Level I-Part I, and a defined contribution account, The parties agree that Wife shall receive a deferred distribution from the defined benefit portion of the pension equal to 50% of the vested monthly pension benefit of $414,15, payable in accordance with the terms of the Plan, The parties shall cooperate in the entry of a Qualified Domestic Relations Order directing distribution to Wife of 50% of each monthly pension benefit payment made to Husband following his commencement of receipt of benefits in accordance with the Plan, The parties further agree that Wife shall receive a distribution from the defined contribution portion of the pension fund in the amount of $23,108,19, which shall be distributed to her in accordance with the terms of the Plan, pursuant to a Qualified Domestic Relations Order, The parties shall cooperate in all necessary respects to 11 . . '. -, .. ... . obtain the entry of the QDRO's provided for herein as soon as practicable following the execution of this Agreement, Husband shall retain any balance of his defined benefit and defined contribution portions of the pension fund as is not distributed to Wife herein as his sole and separate property, 12. TAXES. By this Agreement, the parties have intended to effectuate and by this Agreement have equally divided their marital property, The parties have determined that such division conforms to a right and just standard with regard to the rights of each party, The division of existing marital property is not, except as may be otherwise expressly provided herein, intended by the parties to constitute in any way a sale or exchange of asaets, and the division is being effected without the introduction of outside funds or other property not constituting a part of the marital estate, As a part of the equal division of the marital property and the marital settlement herein contained, the parties agree to save and hold each other harmless from all income taxes assessed against the other resulting from the division of the property as herein provided, 13. ALIMONY, Husband shall pay to Wife alimony in amount of $250,00 per month for a period of 60 months, on November 1, 1996, The said alimony payments shall terminate upon the death of either party or upon Wife's remarriage or 12 . ~ . . ... .. ~ ~ cohabitation with a sexual partner of either gender. The said alimony payments shall be otherwise non-modifiable except in the event of Husband's partial or total disability or other involuntary reduction of income, The said alimony payments shall terminate following payment of the 60th payment as set forth above, except that Wife shall have the right to petition the Court for extension of the term of alimony on or before the date of its termination, solely in the event that her medical condition at that time prevents her from maintaining full-time employment of any nature, In the event that an extension of alimony is awarded by the Court upon Wife's petition as set forth herein, the parties agree that the amount of the alimony shall be determined by the Court based upon the circumstances at that time, provided that it shall in no event exceed $250,00 per month. Upon payment of the 60th payment without prior petition by Wife for extension as set forth herein, the termination of alimony shall be final, and r.o modification or extension shall be possible, regardless of a subsequent change in Wife's health or any other circumstances, The parties acknowledge and agree that the alimony payments provided for herein are intended to constitute taxable income to Wife and are intended to be deductible by Husband for federal income tax purposes, pursuant to Sections 62(a) (lO), 71 and 215 of the Internal Revenue Code, In the event that an alimony deduction by Husband for any payment made pursuant to 13 . . to;.. .- . .. this provision is disallowed for any reason, Wife shall indemnify and save Husband harmless from any additional tax liability, penalties or if'terest which may be assessed, The parties acknOWledge and agree that Husband has been paying spousal support in the amount of $97,00 per week pursuant to an Order dated September 22, 1995, by the Court of Common Pleas of York County, Pennsylvania, docketed to No. 241-SA-1995, DRO No. 57129, The parties shall execute all necessary documents and take all appropriate steps to modify the said Order of Court to delete the portion providing for payment of spousal support, effective November I, 1996, 14. ADDITIONAL INSTRUMENTS, 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 or documents that may be reasonably required to give full force and effect to the provisions of this Agreement. 15. MODIFICATION AND WAIVER, A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon the strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature, 14 ." .A .J -- " .. .., be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement, and in all other respects this Agreement shall be valid and continue in full force, effect and operation. 22. AGREEMENT BINDING ON HEIRS. This Agreement shall be binding on and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written, WITNESS: /1 ..' ,~1f.,/l:!-;- d:/~' /' Z j.. ~~<'~.... '/ J 7. ,..~7 WILLIAM J ;? STEWART (SEAL) ,t:~ " - ~~ ('\ C"' ;}s ~r"~ Cl >--... ~...__~_. ;:::::::,.\........-. ~ BALl BARBARA C, STEWART . 'j ,):~ 16 -' . - .. .. . . . ~ . COMMoNWULTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS. On this "(.I:~ day of ~/~,'I ,..'/ --' , 1996, before me, the undersigned officer, personally appeared WILLIAM J, STEWART, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Marital Settlement Agreement, and acknowledged that he executed the same for the purposes therein contained. /~o/ ///. II~' 1:""(.~/%~ 1-. Notary I?ublic NalBlIol SeoI Corool>o'" P. I!nJnl. NDlaIy P\JlIC ~"",a l'wp., 0""1'1;0 Co....., MycarvnWV1E4J1'81iO:,1 ..' '. 1 . . . . . . . . . . . . . . COMMoNWULTH OF PENNSYLVANIA coUNTY OF CUMBDLAND !s. IIP-. On this ~ day of 7')( (it 1ft I)(() , 1996, before me, the undersigned officer, personally appeared BARBARA C. STEWART, known to me (or satisfactor,ily proven) to be the person whose name is subscribed to the within Marital Settlement Agreement, and acknowledged that she executed the same for the purposes therein contained, ./ i ;' ( A ',( Notary , /II . / ( .{, j( c"/\. r-/ . . I' ......., I?ublic 17 IlOT AIIIAL lEAL CHl\IIlIllA.. .IIIllA, 110I'" ,..11e C..., HUI, ,,,,,,,'"'4 C.....,. P. Itt C........... I"''' ...... 1, 1'" it: o. ~r : ~F E!' 4:' r-.. ('0, r , . I l.j c...' l.J ,-) 1.;... (j ~= a~ f.. '" ~ Pol "" .0; ~ ~ I "" ~ ::l '..t ; ... ~ a: ;:-: Po 1:1 ~ Q:l ~ ~ = '-,- . '.. i~ ~- .. . :.II,... ~f~~ I III Q.,!;; ~:c z .,j illl !2 Po Po ~[:j l.t~ it >-4 .. u~ If .. ~ i :g . lI.l ~5 ~ 9 !.... III Po ~ El ! ~~ . > . 0') u Z 5" ~ I '0 '" a ~~ u ~ I-t 5 oi~ ~ I-t :. <:O;'\/"T.-\,,< <: I': P. BRIfNT .'rI1J......H ..I 1:\'-" , . WILLIAM J. STEWART, Plaintiff v. I IN THB COURT OF COMMON PLEAS OF I CUMBE~LAh~ COUNTY, PENNSYLVANIA I CIVIL ACTION - LAW BARBARA c. STEWART, NO. 96-1567 CIVIL TERM Defendant IN DIVORCE PRABCIPE TO TRANSMIT RECORD To Prothonotary: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1, Ground for Divorce: Irretrievable breakdown under Section 3301{c) of the Divorce Code, 2. Date and Manner of Service of the Complaint: certified mail, return receipt requested, restricted delivery, . March 27, 1996, 3(a) Date of execution of the Affidavit of Consent required by ~3301(c) of the Divorce Code: by Plaintiff on December 20, 1996, and by Defendant on December 16, 1996, (b) (1) Date of execution of the Plaintiff's Affidavit required by Section 3301(d) of the Divorce Code: MIA (b) (2) Date of Service of the Plaintiff's Affidavit upon the Defendant: MIA, "" '" .J ^' f'J .... -, C'. , " ; i ..J'1 i ..) '.() () , ...J 11,' \. ; ~ ,\) ~ \! \..--, (.:' {I: ....... ! --- , L; I I' ~, -...... , ' . ~ l,\-\ , , '- ...J ..., -'l '.. '-L., ~ "'J -- ,~ f, ~~'<J' - ~; ____J '.~_".,._' 0 < ~H enz f5~ ::E ~ ~ ~...:l H a..>t r.. E-< j ~ CIl r.. z ~~ H < U ~ ;:: Eo< .B ~~ go ";. ~re :z Cl 'H :z jl;:: ... o 31 E-<< E-<r.r.. < i:l.!;; .- z 8< ::J u><j ~i ~i:l CIl f CEo< ~~ ij d~ 31 31 z:c 00 I ~ ~ l>ll:l '0 0 E-< Eo< r.r..H ~~ ~ Eo<UZ en en ~O:: ll:: 0 . C Iii "<<' a OCHl>l > . E: OZ~U ,..., U 0 Z U~:Jll:: E-< 0 '" <0 < ~ l>l > 0:: l>l U a: ...:lH < U .. Eo<ri!~Cl l%l H ~ e-. Z::>HZ 0 H H " C()NSTk~CE P. BRUNT Arn )R~FY AT lAW " . WILLIAM J. STEWART, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . v. . CIVIL ACTION - LAW . . NO. 'h / ,'(. '7 L'<<.,...( -.---- . ;.l'o-- BARBARA C. STEWART , . . Defendant . IN DIVORCE . COMPLAINT IN DIVORCE AND NOW, comes the above-named Plaintiff, WILLIAM J. STEWART, by and through his attorney, CONSTANCE P. BRUNT, ESQUIRE, and seeks to obtain a Decree in Divorce from the above- named Defendant, BARBARA C. STEWART, upon the grounds hereinafter set forth: 1. Plaintiff is WILLIAM J. STEWART, an adult indivi- dual residing at 402 East Main Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is BARBARA C. STEWART, an adult indivi- dual residing at 2621 Market St., Camp Hill, CUmberland County, Pennsylvania 17011. '} 3. Plaintiff and Defendant have been bona fide resi- dents of the Commonwealth of Pennsylvania for at least six (6) months previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 26, 1963, in Florence, South Carolina. WILLIAM J. STEWART, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA v. I I CIVIL ACTION . LAW I BARBARA C. STEWART, I NO. 96-1567 CIVIL TERM I Defendant I IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 21, 1996, 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of the filing of the Complaint, 3. I consent to the entry of a final Decree in Divorce. 4. 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. ~4904 relating to unsworn falsification to authorities, DATED: /l.!l()/::'t.. /,' d//:" 'n () (-6:", r WILLIAM J, STEWART, PLAINTIFF c; , 'Uf ( I ~ f":' ~) ,;: " f~' r-. V. C.~ . - , . . :1 ,-~ L I. C. I- t:, ,~ ) .... o~ a~ ~il I ~ .. .~~ ~~ > o~"O ~!~~ ill E ~~ >Q~ ~ : r:::!:f ....... -- I"" - j .... .... ,,.; ~ Cl . ,,.; I~ ~ Cl III 'g . CIl i ~ , .. Ul en :> ~ CtI 8 rz.. o .. .... ~ .... rz.. ~ 3 ~' -, ~ " ... ~ ~ =: ;:" CQ" l! '" '.0. ~~ \~ \ ~ ~~ zi S,' t...: S 'i ~ " ~ .tj ::i Z o U " ':. . I") ~ .... :3 ~ . tJ ~ ~ 1 ,;,- _. ,...,. .... WILLIAM J. STEWART, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA v. I I CIVIL ACTION - LAW I BARBARA C. STEWART, I NO. 96-1567 CIVIL TERM I Defendant I IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 133011C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice, 2. 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, 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. 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, 54904 relating to unsworn falsification to authorities, DATE: /, /: /.. /.;'~/"--~'-~ /<';'. . " " -- / c;- . 1')- ~ ~ //.I/.J~w...,.." .. )/,;;"/~.ci4T WILLIAM J. ,STEWART, PLAINTIFF '.. Ii' (~j L: I' IIJ( (). (:' '1":' " r' , ~.< {} ....: {J.~' , ',-l '" (, I,. ~, HI (,.:) I L' t.) 'I ". ) '.J ~ Zi:Il O~~ r; jg ~ '" en .... ~ ""p" ~ ~ ~ .... I:: f;1CO " '... III "" ," ., ~ 'g H<~ = ;-" I:: U ~~ ~~ ;:: . '... . III p"p,,- ~~..:I j III E-t .... 00... "'<- w Q.!;; z .-i i ~ Q F c "" i:Il>OM ~ ~I~ U~M ~i:i ...... H '" Uz ~ i!' 8zU Eo< E-t i &i~ ~~ iJ ,n en en ~~ Or- . I-'~ '" '" """'fj . III . E-tCO " ::J .., > U p,,~~U <Jl tj:!!lll :z ~ <,bg ~ I i~~i 8 "'- ..:I"''''' "" ~ "" Q ~ w > . ""iZ "" :i~c~ uu "" 3 ,- - --... -:-" ~ IN THE COURT OF COMMON PLEAS OF CUJI,fBERLAND COUNTY. PENNS YL VANIA William J Stewart, Plaintiff No. 96-1567 v CIVIL ACTION. LAW Barbara G. Stewart, Defendant IN DIVORCE AFFlDA VIT OF CONSENT 1. A Complaint in Divorce under Section 3301(4) of the Divorce Code was tiled on March 21,1996. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of Notice of Intention to request entty of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. I veritY 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.CS. Section 4904 relating to unsworn falsitication to authorities. Date: \..::i.. \1. .c~C ~~ . C'~. '" ~ c"'-'.u~ __~ - - ~..:Lt. .. ",-.....:: \ Barbara C Stewart, Defendant " r-. i IF , Itl " r , . I - <.... ~:. " ... , " G.::' f .'J ~ I, '- -,. ,. ,') U " . . , ~ - [Q~ ~~ ~ ;, ;:' Pol .... .jJ ... .... c:: ~ ;) ... III ex: '" I~~ .jJ 'tl c:: c:: III a:. ~" "- ... . III 8 ~ - . . Ill;:::' .. i III i .... Q. '< ~:;: Z .... 8 c ;!!. Po J: ~ ;oJiZ",,,: .. 0 U:r. ~ 1!' ~ ~ f< e- ~ ~ z ~ ;!l . 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C( );o.lST,';-.lCl;, 1'. BRl !N'r ;\nll\l:sf't' ,,\'l,",,~ ~ ~ '" ::l I- ~ "'~ ~" .:1 ~~ ~ Q.'<S~\~ ~. .."" "" Y~11 :a ~s ~i ~ z 8 ~ ~ ~ ~ ':;. ~ ~ . . .. . . . . .' . OFFICE OF DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEAS 9 North Hanover Street Carlisle, PA 17013 (717) 240'6535 I. Robert IlIcker, II Divorce Masler Tracl 010 Colyer Office Manager/Reporter Constance P. Brunt Attorney at Law 2941 North Front street Harrisburg, PA 17110 We.' Shore 697,0371 Ex!, 6535 June 18, 1996 Keith B. DeArmond, Esquire DeARMOND & DeARMOND 2BOO Market street Camp Hill, PA 17011 RE: William J. stewart vs. Barbara C. Stewart No. 96 - 1567 In Divorce Dear Ms. Brunt and Mr. DeArmond: By order of Court of President Judge Harold E. sheely dated June 14, 1996, the full-time Master has been appointed in the above referenced divorce proceedings. A divorce complaint was filed on March 21, 1996, raising grounds for divorce of irretrievable breakdown of the marriage. The Plaintiff also filed on the same date an affidavit under section 3301(d) of the Domestic Relations Code, stating that the parties have lived separate and apart since March 1, 1994, a period of at least two years. The Defendant filed a counter-affidavit indicating that she opposed the entry of a divorce decree because the parties have not lived separate and apart for a period of at least two years. The Defendant also stated that she wished to claim economic relief; however, no pleading has been filed in the action raising any economic claims. since grounds for divorce are apparently at issue, the parties not agreeing on the date of separation, I am writing to request that counsel contact my office so that a hearing can be scheduled to take testimony on the date of separation. If no economic claims have been raised, assuming that I find that the parties have been separated for a period in excess of two years, I will simply recommend the granting of a divorce decree. WILLIAM J. STEWART, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 96 - 1561 civil BARBARA C. STEWART, Defendant IN DIVORCE THE MASTER: Today is Friday, November 1, 1996. Present for a Master's hearing are the plaintiff, William J. stewart, and his counsel Constance P. Brunt, ~nd the Defendant, Barhara C. stewart, and her counsel Keith B. DeArmond, A divorce complaint was filed on March 31, 1996, raising grounds for divorce of irretrievable breakdown of the marriage. On the same date the Plaintiff filed an affidavit under Section 3301(d) averring that the parties have been separated since March 1, 1994, a period in excess of two years. Counsel have indicated, however, that the parties will sign and file affidavits of consent and waivers of notice of intention to request entry of a divorce decree so that the divorce can be concluded Under Section 3301(C) of the Domestic Relations Code. In response to the complaint, the Defendant filed an answer and counterclaim. The counterclaim raiRed the economic issues of equitable distribution and alimony. No claim for counsel fees and costs has been raised in these proceeding.. The Master has been advised that after continuing negotiations, the parties have come to a settlement with respect to the economic issues raised in the action. We are going to have counsel place on the record, in the presence of the parties, a stipulation setting forth the outline of the settlement terms. The purpose of not placing the specific agreement on the record today, as is our usual custom, is to allow counsel an opportunity to review some of the terminology used in the agreement with respect to certain issues. Counsel will then prepare an agreement in accordance with the stipulation to submit to the parties for review and signature. After that has been accomplished, the Master will request that a signed copy of the agreement be provided to him and he will then prepare an order vacating his appointment. At that time counsel can file a praecipe transmitting the record to the Court requesting that the Court enter a final decree in divorce. Ms. Brunt. MS. BRUNT: With regard to the distribution of the marital assets, the parties have agreed upon an equal distribution. 1. Mrs. Stewart will receive the 1992 Buick Regal Custom Sedan, her entire Public School Employees' Retirement System account, and two of the four $200.00 savings bonds, and the household furnishings and appliances which are presently in her possession. In addition she will receive the proceeds from the marital home that she had previously received in the amount of $43,605.00 with the exception that she will pay within thirty (30) days of the signature of the agreement the sum of $10,000.00 over to Mr. Stewart to equalize the distribution of the assets. 2. Mr. Stewart will receive the proceeds of $29,070.00, which he had received from the eale of the marital residence, plus the $10,000.00 to be paid to him by Mrs. stewart, the 1987 Volkswagen Fox Sedan, the 1985 chrysler LeBaron convertible, two $200.00 savings bonds in his possession, and the household furnishings and appliances which are currently in his possession. 3. The Central Pennsylvania Teamsters Pension Fund account will be divided equally between the parties by means of two Qualified Domestic Relations Orders to be submitted to the Court. The defined benefit portion of the pension, which is benefit level 1, will have a Qualified Domestic Relations Order requiring that 1/2 of all monthly benefits be paid to Mrs. stewart. As to the defined contribution portion of the pension or the 401(k) portion, the account as of March of 1994, which was a total of $46,216.37, will be divided equally between the parties with Mrs. stewart's half being segregated into a separate account for her benefit subject to the terms of the pension plan. 4. The parties will each report and pay any necessary taxes on 1/2 of the capital gain associated with the sale of their marital residence at 828 Lewisberry Road, Lewisberry, Pennsylvania. 5. with regard to alimony, Mr. stewart will pay alimony to Mrs. stewart in the amount of $250.00 per month for a period of five years. The alimony is subject to termination upon the death of either party, Mrs. stewart's remarriage, or Mrs. stewart's cohabitation with a sexual partner of either sex. It is also subject to modification in that five year period based on Mr. Stewart's disability, partial or total disability, or other involuntary reduction of income. The alimony will terminate at the expiration of five years unless Mrs. Stewart petitions the Court prior to the termination for an extension of the alimony based upon the sole issue of health problems which prevente her from full-time employment at that time. The amount of the alimony tor any extension would be set by the Court at that time but the maximum amount of alimony which could be granted is agreed to be $250.00 per month. 6. The parties will otherwise execute mutual waivers of any ts , \1. ts\ \\ \ . " \ \ . Co) \ . ~ . ~.\ \\ " i:; ~, e:; ::; i .- r;. ~...... ~~ '":"~ 3 0" ... o:.~ 1~ \~ ~\ \l ~~ r;,l:.ll ~. 8 l ~1 CONS"\'~"'-lCf.'P' \\RlIN'\' ~ "rrll,,~f... "r \]1."" WILLIAM J. STEWART, Plaintiff v. IN THE COURT OJ' COMMON PLEAS OJ' CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BARBARA C. STEWART, NO. 96-1567 CIVIL TERM Defendant IN DIVORCE PRE-TRIAL STATEMENT OJ' PLAINTIFF. WILLIAM J. STEWART I . MARITAL PROPERTY Item Nnmher DescriDtion of PrODertv Value 1. Proceeds of 828 Lewisber~y Road, Lewisberry, PA 17339 1992 Buick Regal Custom Sedan $72,674.25 3. 1987 Volkswagen Fox Sedan 1985 Chrysler LeBaron Convertible Wife's Public School Employes' Retirement System pension benefits (marital portion) $ 9,700.00 $ 1,500.00 $ 3,400.00 2. 4. 5. Unknown Date of Valuation Non-Marital Portion Liens 1. 7/95 -O- N/A 2. 9/96 -O- N/A 3. 3/10/96 -O- N/A 4. 9/96 -O- N/A 5, N/A -O- N/A Item Number O..criction ol Procertv Value 6, Husband's Central Teamsters Pension Fund Account (marital portion) $66,903.52 7. 4 $200.00 U.S. Savings Bonds $ aoo,oo a . Miscellaneous household furnishings and appliances (divided by agreement) Unknown Oat. of Valuation Non-Marital Portion Lien. 6. 9/96 -O- N/A 7, 9/96 -O- N/A a. N/A -O- N/A 2 II. NON-MARITAL PROPI!tTY Item N'I1m....r D..crlDtlon of PrOD.rtv Value 1. 1996 Dodge Ram Truck $18,000.00 2. Non-marital portion of Husband's Central Pennsylvania Teamsters Pension Fund Account Unknown 3. Husband's Members United Checking and Savings Accounts Minimal 4. Non-marital portion of Wife's Public School Employes Retirement System Pension Unknown Dat. of Valuation Lien. 1. 9/96 Members United FCU ($21,000.00) 2. N/A N/A 3. N/A N/A 4. N/A N/A III. BXPBRTS Plaintiff may call a pension evaluation expert as yet unidentified, concerning the value of his Central Pennsylvania Teamsters Pension Fund Account, if a stipulation as to that value cannot be reached, Defendant has not yet been able to obtain an evaluation of Defendant's pension because she has refused to supply necessary documentation of it. IV. OTHBR WITNBSSBS plaintiff will testify about the assets and debts of the parties, the date of separation, and other relevant information. No other witnesses have been identified at this time. plaintiff reserves the right,_ however, to call additional witnesses at trial. 3 V. BXHIBITS Exhibits have not yet been identified, but will be identified prior to trial. VI. PLAINTIPP'S INCOME See Plaintiff's Income and Expense Statement filed 6/6/96. VII. PLAINTIPP'S EXPENSES See Plaintiff's Income and Expense Statement filed 6/6/96. VIII. PENSION AND RETIREMENT BENEPITS plaintiff has been a truck driver for many years, during which he has participated in the Central Pennsylvania Teamsters Pension Fund. Prior to 12/31/86, the pension was a defined benefit pension, paying a monthly lifetime annuity upon retirement. As of 12/31/86, Plaintiff had a total accrued monthly defined pension benefit of $414.43. Although there has been and will be no increase in the defined benefit annuity, Mr. Stewart will receive that monthly benefit upon his retirement, As of 1/1/87, the Teamsters Pension Fund has been converted to a defined contribution plan, similar to a 401(k). As of 3/14/94, the date of separation, Mr. Stewart had a total fund balance of $46,216.37. Defendant participated in the Public School Employes' Retirement System during the marriage. Plaintiff is unaware of what benefits she accumulated, because Defendant has to date ignored Plaintiff's counsel's requests for information. IX. COUNSEL PEES Plaintiff has entered into an agreement with counsel to pay fees based upon time actually expended at counsel's regular hourly rate, which is subject to change from time to time. Initially, counsel fees were being charged at the hourly rate of $140.00, per hour. Effective 4/1/96, counsel's hourly rate increased to $160.00, Through 8/31/96, plaintiff has incurred counsel fees in the amount of $2,437,00 and costs in the amount of $229.19, Additional counsel fees billed at the hourly rate, and additional costs will be incurred through the completion of this matter. 4 , , WILLIAM J. STEWART, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 96 - 1567 Civil vs. . . BARBARA C. STEWART, Defendant IN DIVORCE RE: Pre-Hearing Conference Memorandum DATE: Thursday, September 26, 1996 This conference today was scheduled at the request of the Master. Present is Constance P. Brunt, counsel for William J. Stewart, and Keith B. DeArmond, counsel for Barbara C. Stewart. The parties are in the office but are not present in the conference room. This action was initiated with the filing of a divorce complaint on March 21, 1996. The complaint raised grounds for divorce of irretrievable breakdown of the marriage. Accompanying the complaint was an affidavit under Section 3301(d) of the Domestic Relations Code averring that the parties separated on March 1, 1994. On April 15, 1996, the Defendant filed a counter-affidavit indicating that she opposed the entry of a divorce decree because the parties have not been separated for a period of at least two years and further stated that she wished to claim economic relief. With respect to the issue of date of separation, counsel for wife has indicated that his client avers that the date of separation was September 1, 1994, and counsel tor . " husband indicates that in his opinion the separation oc:c:urre4.i~:Y March 1, 1994. A hearing has been scheduled for October 8'~,,':'8if;f; 1996, to take testimony on the issue of the date of separat.1Oft,':,;,*'; of the parties. Counsel are going to determine if that hear1~00 is necessary because of a valuation requested regarding th4t:',,)t+, pension. Otherwise, inasmuch as the parties have been .epara,..j' for two years using either of the party's dates, there i. no ,:,;' issue with respect to the grounds for divorce. Therefore, counsel will notify the Master and opposing counsel by Octo 2, 1996. At that time we will make a decision as to whether.' not we need to have the hearing on October 8, 1996, or whe that hearing can go forward on other issues, or we need to reschedule to take testimony on other issues raised. The need for additional testimony beyond the date ot separation issue arises out ot a counterclaim which was tiled by the Detendant on August 19, 1996, raising economic claims ot equitable distribution and alimony. No claim tor counsel tees has been raised by either party. Counsel tor husband has tiled an inventory ana appraisement and an income and expense statement and has today submitted a pre-trial stat~ment. Mr. DeArmond has indicated that he will tile a pre-trial statement by october 2, 1996; also, he will provide Ms. Brunt answers to the interrogatories which have been propounded by Ms. Brunt by October 16, 1996. HU3band is 51 years ot age and resides at 402 East Main street, Mechanicsburg, Pennsylvania, with a temale triend. He is employed as a truck driver with Roadway Express. He has reported on his income statement a net weekly income ot $696.00 He is currently paying wite $97.00 per week as spousal support and he is paying child support in the amount ot $153.00 per week. Husband has not raised any health issues. He is a high school graduate. Wite is 50 years ot age and resides at 2621 Market street, camp Hill, Pennsylvania, with two children ot the marriage. wite is currently employed with two part-time jobs, one with the Capital Area Intermediate Unit as a classroom monitor working with disturbed children and a part-time job at McDonald's. Her estimated net monthly income is between $600.00 to $700.00, and Mr. DeArmond is going to provide specitic income intormation to Ms. Brunt by October 2, 1996. Wite has rai.ed a health issue and sees a physician as needed tor Raynaud'. disease and lupus. wite is concerned about the maintenance of health insurance benefits and is not certain at this point whether those benetits are available with the intermediate unit, although Mr. DeArmond is going to determine the availability. In any event, wite would be entitled to COBRA benetit. through husband's employment and we need to know the cost ot tho.. benetits monthly. There is an issue also with respect to wif.'. employability on a continuing basis and the level ot inco.. which she may achieve, and husband may wish to have her evaluated by a vocational expert to see what employment may be available tor her at what wage level. This intormation would be helptul, ot course, with respect to wite's alimony claim. The parties have distributed the marital as.et. .. those assets were available tor distribution but neither party has been bound by any ultimate resolution with respect to the percentage of distribution that each party may be entitled to receive out ot the total value of marital assets determined by the Master. -. The pensions of the parties need to be reviewed and husband has requested information regarding wife's pension or the fund which wife may have had available to her when the parties separated based on contributions by wife and/or the employer. Husband has done an analysis of his pension and has provided that information to Mr. DeArmond who is going to review and verify those numbers before stating his position with regard to the value which husband has suggested for his pension. Counsel for husband has suggested that counsel for wife review her suggested values for the vehicles and perhaps those values can be stipulated to. The vehicles have been distributed, the Buick Regal Sedan to wife, the 1987 Volkswagen Fox Sedan and the 1985 chrysler LeBaron Convertible to husband. Husband has sold the Volkswagen Fox Sedan. The household tangible personal property has been distributed by the parties and counsel have agreed that there will be no need to have the property valued for purposes of including a value in the final computation for the equitable distribution of the other assets. * A hearing is scheduled for Friday, November 1, 1996, at 9:00 a.m. Notices will be sent to counsel and the parties. The hearing scheduled for October 8, 1996, is cancelled. E. Robert Elicker, II Divorce Master cc: Constance P. Brunt Attorney for Plaintiff Keith B. DeArmond Attorney for Defendant *After discussion, counsel concluded that they would not be ready for the hearing scheduled for October 8, 1996, on all the issues. Therefore, that hearing has been cancelled and a new hearing date set for November 1, 1996. WILLlAMJ STEWART, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA V. CIVIL ACTION. LAW NO. 96-1567 CIVIL TERM BARBARA C. STEWART, Defendant IN DIVORCE NOTICE TO PLEAD TO: Constance P. Brunt, Esquire 2941 N. Front Street Harrisburg, P A 17110 YOU ARE HEREBY NOTlf'lED to plead the enclosed Defendant's Answer and Counter Claim of Barbara C, Stewart within twenty (20) days from service hereof or a default judgement will be entered against you, DATE: ~~ Keith B. DeArmon , ire DeArmond & DeArmond Attorney to. #58878 2800 Market Street Camp Hill, PA 17011 (717) 730-9394 " BY: WILLIAM] STEWART, Plaintiff IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA V. . CIVIL ACTION - LAW NO. 96-1567 CIVIL TERM BARBARA C. STEW ART, Defendant . IN DIVORCE ANSWER AND COUNTER CLAIM AND NOW, comes the above named Defendant, Barbara C, Stewart, by and through her attorney, Keith B. DeArmond, Esquire, and represents as follows: I. Admitted, 2. Admitted, 3, Admitted, 4 Admitted, S, Admitted. 6, Admitted 7, Admitted. 8. After reasonable investigation, Defendant has no knowledge as to truth of the averments made in Paragraph 8 and therefore denies same. .- Page 3 COUNTER CLAIM COUNT III . INSURANCE PROTECTION 17. The averrnen13 contained in Paragraphs 1-16 are incorporated herein by reference as if set fonh at length. 18 Plaintiff has acquired existing policies of life/health insurance during the marriage over which the Plaintiff has effective control. 19 Defendant believes and avers that the Defendant and the children of the parties are the designated beneficiaries of said insurance policies. 20 Plaintiff has the exclusive power to cease maintenance or change the beneficiary of the insurance policy without the consent of the Defendant and/or the parties children. WHEREFORE, Defendant respectfully requests this Honorable Coun to compel the continued mlintenance of any life/health insurance policies which the Plaintiff has effective control and the continued designation of the Defendant and the parties children as the beneficiaries thereof Respectfully submitted, DeArmond &. DeArmond 4~~ Keith B. DeArmond, Esquire 2800 Market Street Camp Hill, PA 17011 (717)730-9394 10#58878 DATE tf/ce~ CERTII<'ICA TE 0..' SERVICE AND NOW, thisyi~ day of L1J.wat 1996,/, Keith B DeArmond, Esquire, do hereby cenil)i that 1 have served a copy ofthV~ f&eg01ng Answer and Counter Claim of Defendant, Barbara C. Steward on this date by depositing a copy of the same by I st Class United States Mail, postage prepaid in Camp Hill, Pennsylvania, addressed to E, Roben Elicker, II, Esquire Office of the Divorce Master 9 Nonh Hanover Street Carlisle, PA 17013 ~C' Keith B. DeArmond, E";qwe Attorney for Defendant 2800 Market Street Camp Hill, PA 1701 I (717) 730-9394 CERTIFICATE m'SERVICE AND NOW, thiS~~ day of1rf~~~. 1')ll6, I, Keith B DeArmond. Esquire, do hereby certify that I have served a copy of the ~re~oing Answer and Counter Claim of Defendant. Barbara C Stewart on this date by depositing a copy of the same by 1st Class United States Mail, postage prepaid in Camp Hill, Pennsylvania, addressed to Constance P Brunt, Esquire 2941 N Front Street Harrisburg, PA 17110 Keith B DeArmon, uire Attorney for Defendant 2800 Market Street Camp Hill, PA 17011 (717) 730-9394 I." III W ;5~ o:u We:: ~ ~ ~2 00 IloCU 2> -. ~ c.. E; ::>H "' ;;J ;) 2 c.. :z 0 ex: ;:- 0 H ..: E; ~~~ E; 0 HW ~~ to -- .2 .2 >:I: ::::: of "'~ E;H E;W ":E; Q",< -- z ug:s ~:s o:c.. 0 ~ < c ..:W Hc..W ~~ if if c..u ~llo ~o "'00 00 W CU '" 0 .n ~ ~ <-u ~~ ~ &-22 00 tI1 '1::J O::SO 00- 1;; ~ ~ o HCU > - ~ O&i~U ..., u "'0 Z <J '" U Uo: c..M 0:: gj<O ~ ..: HM 8 I'l > ~ ~ ~ :C:;)~H .... :z . ~ ~u....c o-l l%l HE; > o-l ~ ::S1d 2c......2 H ~OU~ ~ l%l ~tI1 -I ..-- C' ..... ,..~ .,;,- ..... -, CONSTAm:.r:P. BRUNT .uTOaN1Y Kf LAW L WILLIAM J. STEWART, Plaintitf IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA . , v. BARBARA C. STEWART, Defendant CIVIL ACTION - LAW NO.?G 15&.7 (lL~IL( JVl'HL IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you murt file a counteraffidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301ldl OF THE DIVORCE CODE 1. The parties to this action separated on March 1, 1994, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyers' 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. A4904 relating to unsworn falsification to authorities. DATE: '?-<<'i'/yt.- R/<t~;,"(:'<JZ::t<"/ WILLIAM J/ STEWART, Plaintiff . " r , " I 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, () I. Real Property ( ) 2. Motor vehicles ( ) 3. Stocks, bonds, securities and options ( ) 4. Certificates of Deposit ( ) 5 Checking accounts, cash ( ) 6 Savings accounts, money market and savings certificates ( ) 7 Contents of safe deposit boxes ( ) 8, Trusts ( ) 9. Life insurance policies (inciicate face value, cash surrender value and current beneficiaries) ( ) 10. Annuities ( ) II Gifts ( ) 12. Inheritances ( ) 13, Patents, copyrights, inventions, royalties ( ) 14, Personal property outside the home ( ) 15, Business (list all owners, including percentage of ownership, and officer/director positions held by a party with company) ( ) 16, Employment termination benefits - severance pay, worker's compensation claim/award () 17, Profit sharing plans (X) 18, Pension plans (indicate employee contribution and date plan vests) (X) 19. Retirement plans, Individual Retirement Accounts ( ) 20, Disability payments ( ) 2 ',', Litigation claims (matured and unmatured) ( ) 22, Military/VA benefits ( ) 23, Education benefits ( ) 24, Debts due, including loans, mortgages held ( ) 25. Household furnishings and personalty (include as a total category and attach itemized list as if distribution of such assets is in dispute) (X) 26. Other - Medical insurance } UABILlIIt.S 1- DcKrlptlon Names 01 Names of Amount Number lIUJ:gllUt1 All Credlton AIL Debton !hmI I Mortgage Meridian Mortgage William] & Barbara C Stewart $ 18,831.44 2 VISA Teamsters & Chau William] & FeU Barbara C Stewart $2,05928 3. Medical Martin] Pestuka, William I & DDS Barbara C Stewart $1,776.00 4 1992 Buick Regal Teamsters & Chauf William] & FCU Barbara C Stewart $1,165.51" Loan paid in full from proceeds from sale of house Page 2 of Income & Expense Employer: McDonalds Gross Pay Per Period (bi-weekly) $ 5Ul) Federal Withholding $ 3.1)2 Social Security $ 0 MC'dicare Tax: $ 0 Local Wage Ta.'( $ .51 State Income Tax: $ 1.43 Unemployment $ 0 Disability $ .02 Net Pay Per Period (bi-weekly): $ 4531 Child support/Spousal support $ 255.00 Weekly II. EXPENSES Rent (Monthly): Utilities (Monthly): Electric Telephone Cable Gas Storage $ 500.00 $ $ $ $ $ 25.00 60,00 19.98 7100 42.00 Page 30flncome & Expense Insurance (Monthly) Automobile Renters s s 4700 8.73 Automobile (Monthly) Fuel S 87.00 Maintenance S 4500 Personal (Monthly) Food S 17300 Clothing/shoes S 100,00 Household/personal S 50.00 Entertainment/school activity fees S 50.00 Medical S 20.00 Barberlbeauty shop S 80.00 Phone expense for retarded son to call home S 15.00 Charitable Contributions S 12.00 Legal Fees: S 100,00 I, Barbara C, Stewart, veritY that the statements made in this Income and Expense Statement are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa, C,S, Section 4904 relating to unsworn falsitications to authorities ~<'.....J.!.........._ 0_ c::-'::)~ Barbara C. Stewart, Defendant DATE \c. \ -"'Ie. . . .' , Page 2 6 A listing of the expenses of the Defendant The Income and Expense Statement includes this information 7. The valuation of pensions or retirement bene tits and a calculation of the marital portion thereof and the facts and documentation upon which the party relies to support the valuation' The Plaintiff has evaluated his pension using a computer program The Defendant may employ an Actuary to evllluate both Plaintiffs pension and her own. 8 Marital debts: See Defendant's Inventory 9. The Defendant proposed that she receive 60% of the net marital estate. She has received 600/0 of the proceeds for the sale of the marital home and is satisfied with the distribution of the tangible and intangible personality. Additionally, Defendant requests permanent Alimony in an amount similar to that indicated by applying the Support guidelines and/or continued health insurance coverage. Respectfully submitted, Dei\rmond & DeArmond DATE~/'l J::.~ / Keith B, DeArrnon~re Sup. Ct. 10, # 58878 D.:i\rmond & Dei\rmond 2800 Market Street Camp Hill, PA 1701 I (717) 730-9394 f 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, () I. Real Property ( ) 2, Motor vehicles ( ) 3, Stocks, bonds, securities and options ( ) 4. Certificates of Deposit ( ) 5, Checking accounts, cash ( ) 6, Savings accounts, money market and savings certificates ( ) 7, Contents of safe deposit boxes ( ) 8, Trusts ( ) 9, Life insurance policies (indicate face value, cash surrender value and current beneficiaries) ( ) 10, Annuities ( ) 11. Gifts ( ) 12. Inheritances ( ) \3, Patents, copyrights. inventions, royalties ( ) 14,' Personal property outside the home ( ) 15, Business (list all owners, including percentage of ownership, and officer/director positions held by a party with company) ( ) 16, Employment termination benefits - severance pay, worker's compensation claim/award () 17, Profit sharing plans (X) 18, Pension plans (indicate employee contribution and date plan vests) (X) 19, Retirement plans, Individual Retirement Accounts ( ) 20, Disability payments ( ) 21. Litigation claims {matured and unmatured) ( ) 22, MilitaryN.A. benetits ( ) 23, Education benefits ( ) 24. Debts due, including loans, mortgages held ( ) 25. Household fumishings and personalty (include as a total category and attach itemized list as if distribution of such assets is in dispute) (X) 26, Other - Medical insurance f LIABILlTIIlS Item DacrlpcloD Names of Namesof Amount Number of Pmpem All Credllon All Debton 0lUlI 1. Mortgage Meridian Mortgage William 1. & Barbara C, Stewart $18,831.44 ., VISA Teamsters & Chau William 1. & -, FCU Barbara C. Stewart $2,059.28 3. Medical Martin 1. Pestuka, William 1. & DDS Barbara C, Stewart $1,176,00 4, 1992 Buick Regal Teamsters & Chauf William 1. & FCU Barbara C. Stewart $7,765,51" Loan paid in full from proceeds from sale of house , . ., , WILLIAM J STEWART, Plaintiff v. BARBARAC STEWART, Defendant I. INCOME Employer: Gross Pay Per Period (bi-weekly): Federal Withholding: Social Security: Medicare Tax: Local Wage Tax: Slate Income Tax: Unemployment .... . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW NO. 96-1567 CIVIL TE~t : IN DIVORCE INCOME AND EXPENSE STATEMENT OF BARBARA C. STEW ART Capitol Area Intermediate Unit $ 3Z6,24 S 0 $ 20,23 S 4.74 '$ 3.26 $ 913 S .10 Net Pay Per Period (bi-weekly): s 268.40 . , . . ~ Page 2 of Income & Expense Employer: McDonalds Gross Pay Per Period (bi-weekly) S 5119 Federal Withhol~ing S J.9:! Social Security S 0 Medicare Tax: S 0 Local Wage Tax $ .51 State Income Tax: $ 1.43 Unemployment S 0 Disability S ,02 Net Pay Per Period (bi-weekly): S 45.31 Child support/Spousal support S 255.00 Weekly U. EXPENSES Rent (Monthly): Utilities (Monthly): Electric Telephone Cablll Gas Storage $ 500.00 s s s s s 25,00 60.00 19.98 71.00 42.00 . . , ., . . Page 3ofIncome & Expense Insurance (Monthly)' Automobile Renters s s 4700 8.73 Automobile (Monthly): Fuel S 8700 Maintenance S 4500 Personal (Monthly): Food S 17300 Clothing/shoes $ 100.00 Household/personal S 5000 Entertainment/school activity fees S 50.00 Medical S 20.00 Barberlbeauty shop $ 80.00 Phone expense for retarded son to call home S 15.00 Charitable Contributions S 12,00 Legal Fees: S 100.00 I, Barbara C, Stewart, veritY that the statements made in this Income and Expense Statement are true and correct. I understand that false statements made herein are made subject to the pena1ti~ of 18 Pa, C,S, Section 4904 relating to unsworn falsitications to authorities ~c:.......Q.............._ C'~ c::-:::l\....""'--...:i Barbara C. Stewart, Defendant DATE: \c- \ - "'\ :.... " CERTIf'ICATE 01' S~;RVICE AND NOW, thiS~:~ day ot\f1:.1L~ 1996, I, Keith D. DeArmond, Esquire, do hereby certitY that I have served a copy of the tBregoing Answer and Counter Claim of Defendant, Barbara C. Stewart on this dale by depositing a copy of the same by I st Class United States Mail, postage prepaid in Camp Hill, Pennsylvania. addressed 10 Constance P Brunt, Esquire 2941 N, Front Slreet Harrisburg, PA 17110 Keith B. DeArmon, uire Attorney tor Defendant 2800 Market Street Camp Hill, PA 1701 J (717) 730-9394 ~ I ~ ~ ~ ! ., I I .. . ;;:- 1":1 a:' H Q "- S = = i .1 I ' "'~ .. Q. '< g ~ ~ J: ;oJjz .t"', '" . . . . ~~ ~ 1":1 > u ~~Ji "' I I :!l ~ <;> M MI ~ I .. z ~ ;;:- !O. . ~ 8 ~ i!l i . CONSTANCE p, BRUNT "Tn)R~EY AT LAW WILLIAM J. STEWART , . IN THE COURT OF COMMON PLEAS OF . . CUMBERLAND COUNTY, PENNSYLVANIA . Plaintiff . . . CIVIL ACTION - LAW . v. . . . . BARBARA C. STEWART, : NO. 96-1567 CIVIL TERM . . Defendant . IN DIVORCE . INVENTORY Qf: WILLIAM J. STEWART Plaintiff files the following Inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Plaintiff verifies that the statements made in this Inventory are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa.C.S. 14904 relating to unsworn falsification to authorities. Dated: 5' /4- /7~ d~t;;;'~r;cj:.ri.a/ WILLIAM ~~ STEWART, Plaintiff (X) 19. ( ) 20. ( ) 21. ( ) 22. ( ) 23. ( ) 24. (X) 25. ( ) 26. Retirement plans, Individual Retirement accounts Disability payments Litigation claims (matured and unmatured) Militar)'/V.A. benefits Education benefits Debts due, including loans, mortgagos held Household furnishings and personalty (include as a total category and attach itemized list it distribution ot such assets is in dispute) Other 3 PROPERTY TRANSFERRED Item Nt1l1lher DescriDtion of ProDertv Date of Transfer 1. 828 Lewisberry Road Lewisberry, PA 17339 1987 Volkswagon Fox Sedan 7/27/95 2. 3/10/96 3. Teamsters and Chauffeurs Federal Credit Union Account Post-separation Consideration Person to WhOIll Transferred 1. $100.000.00 Clyde B. , Joan R Fry 2. 1,500.00 Kevin Zimmerman 3. N/A Divided between parties or used to pay marital obligations " 6 LIABILITIES It.. Description Na.es of Names of Nu1llber of ProDerty All Creditors All Debtors 1. Mad tal residence Meridian Mortgage Husband and Wife 2. Teamsters and Teamsters and Husband Chauffeurs Chauffeurs Federal Federal Credit Credit Union Union VISA Account No. 4604-5100-0004-3426 3. Dental bille Martin J. Pastuka, DDS Husband and Wife 4. Car loan for Teamsters and Husband and wit. 1992 Buick Regal Chauffeurs Federal CUstom Sedan Credit Union 7 li: r- ;:; cf. Lf) .~_ 1~ i<1 '~~ 'c;; .... '):'/, .i ~- -.: :1: c'- '"i"-1 t--- . >~ C' '.'f'iJ .0.\,. :i 1,:Z U-! :J.'~ i.' llL) "1 :;-..J , ,~u... F -,. ~ ~ (3 @J I ~ ~ ! ~ ... I ;) I ~ ;;:- I 1%1 ~ eo ~ i - :s "= ... . '" ~ I @J .; Q. '< ~:; ~ J: ;oJjz .t"', '" . u~ ~ f @J~ ,., . . ~ i > u i ~ ~ ~~ 8 I ... II ::l Z ... ;;:- ~ 8 ~ "- ~ ... _. . " .. . ... . . . -. CONSTANCE p, BRUNT A"rroll."EY ..-r LAW WILLIAM J. STEWART . . IN THE COUJ<T OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY. PENNSYLVANIA . . . v. . CIVIL ACTION - LAW . : : No. 96-1567 CIVIL TERM BARBARA C. STEWART. . . Defendant . IN DIVORCE . INCOME AND EXPENSE STATEMENT Qf WILLIAM J. STEWART I verify that the statements made in this Income and Expense statement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 14904 relating to unsworn falsification to authorities. DATED: .j1t.At. , INCOME: Employer: Address: Type ot Work: Pay Period: Roadway Express, Inc. 100 Roadway Drive, Carlisle, PA Road Driver Weekly (1996 Average through 5/2/96) Gross Income Per Week $961,04 Itemized Payroll Deductions: Federal Withholding FICA $145.98 59.58 Medicare 13.94 Local Wage Tax 9.61 State Income Tax 8.31 Total Deductions 264.33 lI_~L NET INCOME PER MeMH $696.71 2 lfeeklY. MonthlY. yearlY JXPENSES: )JgU: Rent $670.00 $8,040.00 $154.61 utilities: Electric Gas Telephone 900.00 432.00 384.00 17.30 8.31 7.38 75.00 36.00 32.00 1axeSl personal 225.00 4.32 18.75 }nt!lurance: 150.00 1,272.00 117.00 Homeowners Automobile Life 2.88 24.46 2.25 12.50 106.00 9.75 E1\\nlovment: 2,400.00 46.15 200.00 Lunches Automobile: 27.69 $589.00 120,00 $7,072.00 Payments Fuel $136.00 1,440.00 Repairs, Registration, Inspection 1. 78 21.46 93.00 Medical: Special Needs (contacts) .96 4.16 50.00 Personal: Clothing 9.61 41.66 500.00 Food 23.07 100.00 1,200.00 Barber/Hairdresser 6.92 30.00 360.00 Credit payments 18.46 80.00 960.00 Miscellaneous: Entertaimnent 10.00 43.33 520.00 Pay TV 4.50 19.50 234.00 Child Support 160.00 693.33 8,320.00 Charitable Contributions 1.00 4.33 52.00 TOTAL EXPENSES $658.04 $2,906.77 $34,721.00 4 SUPPLEMENTAL INCOME STATEMENT N/A (a) This form is to be filled out by a person (check one): [ J (1) who operates a busine6s or practices a profession, or [ ] (2) who is a member of a partnership or joint venture, or [ ] (3) who is a shareholder in and is salaried by a closed corporation or similar entity. (b) Attached to this statement a copy of the following documents relating to the partnership, joint venture, business, profession, corporation or similar entity: (1) the most recent Federal Income Tax Return, and (2) the most recent Profit and Loss Statement. (c) Name of business Address and Telephone Number: (d) Nature of business (check one) [ ] (1) partnership [ ] (2) joint venture [ ] (3) profession [ ] (4) closed corporation [ ] (5) other (e) Name of accountant, controller or other person in charge of financial records: (f) Annual income from business: (1) How often is income received? 1-', 5 --','___..t . CERTIFICATE OF SERVI~ I, CONSTANCE P. BRUNT, ESQUIRE, do hereby certify that on "1-"-- :t the 7 day of . ",,.,j ,- ,1996, I served a true and correct copy of the IN ME AND EXPENSE STATEMENT OF WILLIAM J. STEWART, by depositing same in the United States Mail, first- class postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: Xeith B. DeArmond, Esquire DEARMOND & DEARMOND 2800 Market Street Harrisburg, PA 17011 Attorney for Defendant / ,/ /. /. / ',' , ' / ->-,v-:;---i-' - -/I.~;j ."".... ~ I/' /\.. ...., ' CONSTANCE P. BRUNT, ESQUIRE Attorney 1.0. No. 29933 2941 North Front Street Harrisburg, PA 17110 (717) 232-7200 Attorney for Plaintiff 7 (361361) ; 1040 .. LIIbeI =...0... .npogoll.) 11M 1M lfIe - ~V "lIf II ,.... - See II, fling Slelue (See pogo 11.) c_ .nIy one bo... Exemption. (See pogo 12.) nmor.lI1en.. ~ _pogo 13, Income A..... c...., . of,..... F_ W-J, W-2Q, IIId I_A ..... II you dld nol gel I W-2, _ pogo 14, E_. bul do not lIlIaCh. your poymont end =::See pogo 33, Ad/Ullmenl. 10 Income O.,.,tJIIWlI of 'fl. ""'''')1< In'I'"I' "''''1'''''' "'''I~' U.8. Inchlduel Income To Rllurn 1995 DB IRS Ut. Onl . Oe "at writ, 0' .......1fI 1t11.tplCl. . t. 0". Ho. ,......00,1 Yo.., locl,I"curlt)l'"'''''''' '0I1"''''''.JiM. tNO... ", 11II,.r ot..... tuy.., II."""''', ,''''.'''11I", t I WILLIAM J. STEWART BARBARA C. STEWART 402 E. MAIN STREET MECHANICS BURG , PA 17055 10 IhlI flJnd1 , . 2 :I 4 x -..,,,I,d 1I11"",p""1 "tu,n. In'lff .pou..', latlal."ell,I,., "0. lbovl ,nd full"''''' h.,.. . . .. .._... ,See ~~~ ~:~:: ::: ~~. :.: : : J (2) C,,"'dent'. .ncl,1 (3) O.,fllderlt'1 I::~::cf l..:urllY'ltu"'b", If lito," ,,""on,"" ta rn YO.",',,,on.. III 'HI . I' 111 is 190-68-6968 au hter 12 189-58-6619 on 12 191-68-0799 on 12 It . UllllncIMtII: (1) ,tr......... UI' N..... KATIE E STEWART JEFFREY R STEWART CHRISTIAN STEWART d If yow child ctdn't Iv. ..tll you bull. c"'md u you, dttp.,.d...1 under. p'....l.15 .....m.nt, oll.eII; It.... .. . r.lII...... ., ..... dlllrred. , . , , . . . , . , . . . . . . . . . . . . . . . . . , 7 W_.III_.IIpo..... AnlCh FlIm1(o) W-2, , , , , . , , , , , , , , .. T_ _Incomo 1_ pogo Ie), AnlCh Schldulo B n._ $400 , , , , , , . . . , , It Tu-.......lnllrllll (_ pogo le), DON'T Include.n lno 81 .. . DMdond Incomo, A"""h Schldulo B n .ver $400 , , , . , . , , , . , , 10 r.._ roIIInde. CfIdIII, or .1IIIIs., at... Ind Iocollncome ,_ (_ page le) .. Alrmny_, . . , , , . . , , . , , , , , , . . , . , , , . , .2 SU_lncomo or (1010). AnlCh Schldule C ., C-(2 . , . , , , .3 Cop/IoI geln or (l01I), n roqufl'ed. onlCh SchedUlo D (_ page 18) .4 on-galnoOf(lo_~AnlCh Form 4101 , , , , , . , , . ,. , ... r.loIlRA dIolIlbu..... , , . , ,l.!!!J lit ro,"bIe """",nl 1_ pogo 18) ... r.loI........... end ennu/llol, ,IJ!!] It r,,"bIe ormunl 1- PIgllI8) 17 RInCoI rill 1lIl.... roy_. p_hlp'. S corporlllono. tru.... lie, Anoch Schldulo E . II Form Incomo Of (l01I), AIIlCh Schldulo F , , , , , , , , , . , , , , , , . .. U_loymonl co""*",,,llon I-pogo 11), , " . " , , , " , , , , , , 2lIISodol...rtty_", , ,~ lit T"'"bIe omounl(Mlpogo 18) 2. on-Incomo, Uoll'jpl and ormunl- MI pogo ,8 _.'n_...__._______ __._ .____..__. 22 Add "" """"'nil In !hi I. hI """mn 10' 1_ 7 Ihr.u h 21, mllo'''''' _ . . .. _ Your IRA deduction 1_ pogo 18) , , , , , , , 23Il It Spou.'IIRA _n (MI pogo 18) , , , , , 23b 24 Movtng _,_, AIIlCh Form 3803 Of 3803-F 24 :Ill O.....hlll .'Illl-lI'r'4lloyrnonl tu , , , , , . , , :Ill 21 SoII-...,toyod hoIIlh lneuronal deduction (..... poge!!l; 21 27 Koogh & 1III-lI'r'4lloyed 9EP pllne. 119EP. checll .. U 27 21 Ponony.nurfy_owol.'oovtngs , , , , , . , , , , , " 21 21 Almany pold, RocIplonl'o 9SN . 21 :10 Add_ZlI h2ll. T1_.. _ Ul_,.",."."".,. ,. ultld 3. Su 30 lom"" 22. ThIo "'.~ -..-..- _ P iIIIlhon i2lI813 end Oro.. Income """ (IooIlI1ln ~,230 n .. cl1lld ctdII'l ... """ I'OU). _ "E.nid (nc:omI , .. . .. , ,. .. ..,. "",.. ,. . . I 10 .. 12 t:J I" I" I. 11 II II - 2. 172-36-1361 S"ou..'. .ad.l..evrlly rlumHr 20'1-34-7036 s=~ .. rtilt No _ 7 V.. No .: eft".'''' .............rlol X oil..... you, ta. X Of ,.dllll. yauf '.'utI" No..' M... ."eel..Cla.... "'''tb ~ No. or yo'" "111.....,.0...., ",ho: . 'v." with yau 3 · d1t..'.!'S.l!!" 11LA:.II;n.r::: ,.,,-'41 _ 0.,.......10... to rlol...'.....IIo". 6 4. 60 807. 1_ WILLIAM J. STEWART' BARBARA C. STEWART 3:1 _ntfrnm...3f(odJU_,,01lIncome) , , , , , , , , , . , , , , , , . , . , , 33a Chedllf= 0 You .....5 Of 014....0 'drull; 0 SpouM ..... IS lirolder. DI*nd. Add !he nu_ 0' bo_ c_eel ._ Ind 111"" !he 10'11 her., . ,. 33e It. """ pll'" (01 _Ill _I can dtlm you .. . dep<ondenf, C_ her.. .,._ a . you .. monied lllna 1Ip1l"" on<! yotlf _II _ -.ctIona Of you II' . dull-Ila1iJI ....., _ page 2:l and c_ her.. . , . , , . .. ,. 330 34 E....1 "::'111" ~I 1u'1IaI.. ~om Schedule A.... 2tI, OIl !he It.do... ., t,._ lhown _w rot your lllna "WI, But II you _eel ...... !!"Y boa on _ 33a Of It, go 10 p_ 23 10 trnd your stand.d -.ctIon, . you c_eel Iooa 33c, your Ilandlrd daduc:1lon II zero, of . lItntfe-U,1OO . ,...,',.4f1.nlllolnlly.rOU.J1frt"'.....dO'IfIIIC.')-..,SISO your. . H..d af hOUI.Ilold - 11,150 . ...."I.d IllnGl..t).,.I.I., - n,ns 31 SubtrlCf I:1a 34 ~om'" 32 ' , , , , . , . , , . , " """"""."" 31 . ... 3a II sae,02ll or _, mulllply S2.!lOO by lhe 10111 00_ 0' .......,lIona cfalmad on I... la, . IIlI 32 II 0_ ",O2ll, _ !he worfll_ on page 2:l rot !he amounllo anlar. , 37 T_ _ SublrlCf I... 38 ~om IIlI 3!l, III... 3110 mora thin IIlI 38, _ -0-, , 31 TIX. Check.. from . 00 Tu fable, b 0 ~:;::~T.., 0 D C.pl~1 a.ln 'u Worll.h.I' Old D '0',""'1("",,, alJ, Amll"nt"lI""ormf.,Ut. ,.... 31 A_nlll_,C_.~om aD Form4970 II 0 Form4912 ' , , , , , , , FOIII1 1040 P 2 807. Tu Compu- IelIon (Seapl!l'l 2:),) 6,550. 54 257. 31 12 500. 37 41 757. 6 627. 6 627. "youwanl !he IAS 10 llgura your '-I ... page 31, ....................................-...................................--.................... 40 Add I... 38 and3ll , , . , , , , , , , . , , , , . , . , , , , , . . . . , , , , , , , . , , ,. 4. c,.dtt for chlll'lnd ...,..d"" ur. ..,..,.... Anle" '0'1'1I 14.4t 4. a e'.dlt'o'.....ld..lyort".dl..bl.d.AltaeItSch.dt.lI... . . . , . a 43 FOIeIgn I.. CIIdII, Anach Form It II . , . . ' , . , , , , 43 44 0IIw c:radIIII (....... ..~ Chacll W ~om!O Form 3_ b 0 '0"" 1311 0 0 'In", IfIllt d Dr.:'.':.,y. ... C,tdlt. (Sea page 24.) .--......-...--......-..--................-..................-.-.--..... 41 Add.... 411hrough 44 , , , , , , , , , , , , . , , , , , , , , , , .. SUbtract'" 4lI ~om ... 40, If I... 4lI11 mor. than IIlI 40, an... -0- 47 SaII.....,...,_~..., Anach Schedule SE, , , , , , , , , , , , , , 41 _n__mlax,AnachFormll2S1 , , ,. . , , , , , , , , . . ... R8CllplUre...... Ct.::k If from I D '0'1'1I42115 bD '0'''' 1111 a 0 Fau" 112. . 10 _aacurfty and MadIcara 'ax on lip Income nol reported 10 .....,Ioyar, Anach Form 4137, " Tax on qu....... ...._ plana, Including IRAa, If raquh", ltIach Fann!!329 . 12 Advance _nad Income crd poymanll ~om Form W-2 , 13 ~""""ymant'_,AnachSchaduIeH...".".""", 41 .. .. 47 41 41 10 .t 12 12 637. Oth... Tu.. (Sea page 29.) I, ...................._...._....__............._-_.~.__...--.............. 14 Add....4lI h!!3.TI1IaIa r..taI....",.". .. FedIw..1nc:ome fa wtlhheld. Ir.", I. ",,"' 'orlft(.) lOll, eh.c_. II 17 6 627. ..'.. .. 7 771. P8yIIl.. . \J Anach F"..,.. ',"I W-2, W-2G, and 1ClllO-R , 10 page I, hC"'lOdIIMCUrlty"'dAA'AiI...lttlh.ld("''''O'32). . . . . . . OthlfP''''lntLC''fdU',olll .0 Far'" 24:J. b D FO,"'4131. .....-............-....-----.....--..-...--.----..--.--....--.-....-...- It Add....M heo. ~lIa urlOtaI . . , , . . . . , . , . , , . , , , ,. 12 .... II Ia Il'Or.",an Hili 54, S1Jb~1Cf H... 54 Itom IIlI II, TI1Ia II !he amount you OVI!RPAlO . 13 Almunto'...82youwlInfREFUNDI!DlOYOU, , , , , , , , , , , , , , , , , , " , . ,. 14 ....r,.'....."'._'APPlIEDlOYOUlll...I!STIMAnDTAX M 41 . IIlI 5410 mora II1ln IIlI II, S1Jb~1Cf I... 11 ~om H... 54, TI1Ia 10 !he AMOUIfT YOU DWI!. Fo< dol. on how 10 pay Ind UII F_ 10000V. Payment Voucher, _ page 33, , , , . , .. EIIInwI8d I.. .",. '3). AIM I"c"''', on In. IS . . . . . .. .. Und.. ,.".111.. of p")ury, I d.e.....tll.1I 11111' ..../111'''4 Ii'll' ,."',,, IIld Iceo"'panyf"g lIIlII.dul.. and ".t..,.lnta....1f to U.......o ."... be..', tll.y., tru., CO",lCt, 11Ift COlltp'.t.. Decler.tlnn n' pflll.'''fat''., han tup'.,.,ll..,...d "1IIIn'Ofl'llltlO" a' wille" "'............,...... ~ .....,......" 0... "~~";~L DRIVE ~ ........~......",'''I"'"...."'",BD'H..."...'...' 0... ;~~~-;.-;'ID ......... ~ Olt. ,..,.,...............,.... C"ectl I' ..,,- .......... 2-11-96 ......,.. 224-86-4344 JAKES H HESS CPA ~ ~~~~~r~t@~:r::::::::::::::::::::::::::: 7 771. . R.fund 0' Amount You Owe 144. Sign H.... I<aap a copy 01 1hIII IfllUrn for your ,-.da. P.Jd p,.,.,', U.. Only I'N 23-1744869 Z1'....17111-1141 >--.-1 OMB No, 1114&-0074 poge 2 n_ non poge , _ ~ iiiiiiIiir WILLIAM J. STEWART' BARBARA C. STEWART 172-36-1361. ' Schedule B - Interest and Dividend Income 08 _I In_ - _:" h8d _1400 In __ _ _, ......... PII1I1I. 1 UlII_ 01 p6yOt, II Iny _11I11 ~om I _-"nlllCld mol1g0g0 Ind IhI bu~ ulllld IhI P-'Y _ I _n.. rwoIdon<e. ... pogo B-Iond 1Iol1hll1_IIIIlm, Aloo, lhow 11111 buyor'l ...... 0M:UrlIy nu"- Ind Iddr_ . ENT FED. CR. UN. ENT' FED:" CR:' 'UN: .... -. -.. ...... ..... .""... , . ..."". -"., ...." ."""" pi; 'sTATE' 'EKPL:" "CR:' "UN:.,...........".. .-. _..."""""......""""- KEKBERS - UNITEfj..':c.:U.:"... -""""....."."..""."".. _..""........- STATE - FAn;, "LIfE- INS: -..-...".."."". - -........."". -.. ......."." PRUDENTiAL' -iNs':' eel:' oF" .AMERicA."...."..".".... -.".."....- ~; ~;: :~~yx~~~: :~~H::::::::::::::::: :::::: ::::::::::::::::::::::: ~ (SIe p_UI InCI B-1.) ~::J:'j I Fonn ,_INT, Fonn lOllI-OlD, or ..- .....,...~ from I _oge IIrm, IMIhe _I __Ihe poyer ond _ Ihe__ _onll111 Iom\ 1 ~...-_._---_._..._..........-..._._._........._._-------.....-...-.-..-. _._---_.__.__...............-...._-_..._._.....~.-_._.----........-.---. .-.-.-.--....-............-.-..-.-..........-.--.............~--_._....- .__.........._~~-._.-.---_.__._......_...~..-.-........._~~--_._._...._~ ......~_...-.--.._--_..__......._..._.-.-_..._........_.------_......._~ -----.......--..-.....-.--..--------.......-.--.------.__.~~.-.-.---.._. ...........---..----..--..............--.------.-.......-..-----...-..-. -......__..---~----_.__._...............-._-----_.........-----.-......- 2 _0 - 1- 2 Addlhe_ntlronlnel".,.""".,.,..,.""",.......,., 3 __ __ on _ EE U,S, lIVIngs bendo _ 1ft<< 1988 hom Form eelS, I.. 14. You MUST IlllCh Fonn 88'S 10 Form 1040 ,.....""",....".,..,.. . SU,*lCllne 3 from lne 2, EntIr 1he....1I hore end on Form 1040, 1..1Ia. . . , , . . . . . . .. _: II h8d _ $400 In .. _lI1dIor other _buIIolll on _, must.... . UlII_ 01 poyer, Include gro.. dMdonde Ind/or Olhlr _bullolll on stock hlrl. Any cepl1aI geln __Ill end nonlo..bIe cIs1rtbullo.. wtI be deducted on I.. 7 Ind 8 . AmMnI 3 . PII1I11. --...----..-----..........-...--------..---....-....-.----.--..---....-- (See p_'8 InCI B-1,) ~::f-'! I Fonn I_DIY or ..- "__from 1_- IIrm,IMii;' Irm'e .... . Ihe poyer ond _1hI_ ....Idetldl _ on 11111 IIlrm. 8 Pert III ~:....~ ond T_ (SIe pogo B-2.) . AddIhe_nlaonlneS.""",..,."...,..""....."",.. 7 Cepit.. geIn _11011I, E_ herl Ind on Schedule D.. , , . ., 7 . No_ _bullolll. (See "'" lnot. lor Form 1040, I.. 9.), , " . . Add I.. 7 end 8, . , , , ' , , , , , , . , , , , . , . . , . . . , , . . . , . . . . , . , . . . to SU'*ICII.. 8 ~om 111I 8, Enhlr the II!lUft hlrl Ind on Form 1040. 1..8 . , . , . . . . , . . .. .11 you cia nol .- Schedule D 10 report "llY olher g.... or 10_, ... Ihe lM1nJc1lona lor Fenn 1040. ,,,. 13. on pege 18. o you hid 0_1400 011_ or clvtdonde or hid olorelgn aa:oun' or _I I grlntor 01, or I tonot""" to, I foreign 1IUIl, mull lhle lI1. 1 II Aleny'" dur1ng 1995, did you h... In Interool In or I slgnllUrl or other IUthortty OYll' I "nlnd.. ICICOUnt In IlDreIgn counlly. ouch .. I blnk ICCOUnl. IIICIJrttlelI aa:ounl, or olher "nand" aa:ounl1 see pege B-2 lor _11011I ondllng """lrerrentll lor FormTD FIIO-22,1. , , . , , , , , , , , , , . "" ,. , . . . , .. It 0 '"Y." _ IhI n.... ollhllDrelgn counlly . 12 Were you the grllnlor 0', Of .enol.or 10, llorelg~ iN~" ti,~ i~j.;," .;;~,;g iti9~:';';';ti,i;' OJ;;;;i you hM - - - - - - -- benelIdotI__tn 111 II '"Y.,' h...1O IIIe Form 3S2O, ~A. or 828 . . , , . . ., .,..... 8. 2. 518. 19. 32. 22. 29. 630. 630. o. o. [361361 ) FOITIl 2119 0.,.,1...., 0' ,ft, T,....." In..... AftWtU. s.-.t. Sale of Your Home . A_to'......I_""_of-. . 1M....... Ina_ . ....... print Of Iype. OMS No, I~ 1995 YIN' flf........ and......... If . 11M",' r.tu,n..1ao p,.epou.... nam. Iftd Inlttll. l."t".",. 20 Y_- _Ullly_ 172-36-1361 st>ouM'._~- 207-34-7036 WILLIAM J. STEWART' BARBARA C. STEWART '"",y.."Addr Oft.., " You Ar. '1I1",n.I. '0'." City, to... or po.1 o"'~. ...t',lfld liP 'ode """...11 Mot"''''' Your f.. ".... Oeln on 18.. I D...yaur_......._..ooIdlmomh,day.ya.)",...",.."".",."."",.. 2 H...youbauqhlOl'bu....-......._1"",,""'" ."""""".".""" :I """'J parl.,_....... _.. _ ,_ad oul Of uaad 10, buol.-. c_ hat.. 0 .nd _ page 3. 4 SalIng pttca .,_. Do nollncluda _nol P'-'Y Ilanw you IOld wfth YOU' _, , . 4 100 000. . Ellparwa.'....I_page3) . , , , , . , . 10 349. . SUblracl.... Hom.... 4 ""'.',, '" ." .,."""" . 89 651. 7 A~b.....I_ooIdl_page31. , " , " """,..', 7 15 902. . _...-.SUblr.cll...711om....." , '" " ..""""'.'"""",, . 13 749. I ::= ~ I Y- - " .... 21a "'f.," you - go to Parlll., Parllll. .hIc_ app...., II.... 21a "No," go 10 .... .. ,.....7 " No _lhop._LouonltaSalaofY__.npagel, . "youhavan1,epf8lllldyaurhome,doyouplanlo dooowtthlnlhe"",ulmanl,*"",l_page 1)1 , .', ,I:K]Y. DNo ." .... . Ia "'f.,' IIop twa, Itlach IhIa Iorm 10 YOU' ,.lUrn, .nd _ A J ........I'IIlntI.._,,_ta .n page \, .".....Ia"No. _ "ParlIlOl'Parlll'__ n... TIme Exclullon of O8In for People .........._ _ 2." ..not 10 Who..ageIlll0l'_.nlha_0I....1. " . ,. ..., ,.'" , '" You You,_ I I DId Iha _n who ..Illl 01' _ own If1d usa !he p"",""" . hie or hat main honw lor a 10101 ., 111011I 3 ,... .r Iha 11-,.. pIftod __ Iha ....1 1M Iha Inotruc1lona lor _Ilona. ""No," go to Parlll' now , , , . . , . 12 AtIha.....r....,whoownadlhahoml1. ... ..,. ". ...", . ,. DY.u Dy.u,_ t3 SocIoIlKUltIy..- 01 _1I1ha _.r...." you hod. -.nt opou.. ~om Iha ....IboYl, "you _. nol_IlIha_.r.......,.."No.... ."",."",....".'""""""" ,. 13 14 -. E",", Iha _.r.... I Of "25,000 (_.!lOll' _1IIng lip.... .....'n). ......111. , ..... ,. . .., , ,. . , " , .. , , . . . . . . . . . . , ., . . , , .. .. , . ., 14 ua<<... .. Prlc Dab.. Gm end Ad uatect Bale of N_ Home II ".... 141a _, _Iha 1mOunt Il'om ....11, Olharwtoa, IUblracl'''' 14 110m .... a, . . . , , , , , . , , . , , . e" ....,1l1a !Inl,1Iop andltlach IhIa form to yaur _rn, ." .... 11110 ...... than !Inl and .... a Ie "'f.," go to .... II now, ." you .. rIpOI1ng IhIa .....n Iha Inot_ ....ho,j. alvp and _ page 4, 'AI.1hara.1Iop and _ Ita _........ II OIl Ie/lid".. D, 001. (g),'" 4 Of... 11 II Fbdng-up__(_page41or__1 " , " , " , , , , . . . 17 WI... 141a blank, _ II11OUnllIom .... II. OIheo _, odd ,.... 14 and II , , , . , , , , II ~_prloa.SUblracl''''I7tom....a, , , , , , . , , , ' , , , , , , . , , III Dill you movad Inlo .- _ .1 I b eool 0''- _ (_ page 41 all SUblracl.... lib 110m.... II, " !Inl 01' _, ..... -0- , , , , , , , , , , 21 T_...... E",", Iha _ .,.... 15 Of.... 20, , , " """",.", eN.... al Io!lnl. 90 10 .... 22 and ll1Iach 1hIlo form to you, ,aIUrn, ." YOU.' rapor1lng 1hIa.....n Iha InoI_n1....hod, _Ihe.... 151notnJcllono and go 10 I... 22, eAl.1hara' _ Ita _........ 21 on _.. D,.... (1I~ 1In. 4..... 12, and go 10'''' 22, 22 PoaIponacl gain, SUblracl....:ll ~om.....5 , , , , , , , , , , , , , , , , , , , , , ' . , , , , , , , , , , , " 22 22 bulaof__SUblracl....22~om.""tlb""....,.,"',..,',.,....,' 22 SIgn .... ~~:ut:.nI" or ...ju'Y,1 d~'-'. U~.t IIt,wI .....In.d 11111 fouw,.ncludl",.'taehNetlll, MlI to ,". bl,l of My IInQ...d....'......, hie .............. Only It You AN :'\y Your "",aM' O,le !pou.... '1.'''''1 a.. TNa Fonn __110I .. _YowTa , ..alum Pt..-I Idd,... (no., ''''''. wut IiPt. M., rvrll row'.. 0' ".0. Ita. "0.11 "'Mil. "ot d.I.....r.d to "''''Idd,...) _of,.,.. BY. 0'" Both of,.,.. 1111'11" . II' .' I, 1'1:1 Ji. LII;' I"" I (361361) LIST or w-;! FORMS INCWDED IN RETURN WILLIAM J. STEWART , BARBARA C. STEWART 173-36-1361 . flDfIlAL IIGflAL "CA "CA "CA IIAIl SlAIl LOCAL LOCAL AOYANCf OleAU TI _LOTI. IMGII. IAll WIIH. IMGII. TIPS TAlI WIIH IlAGI. IAll WIIH. IlAGlS IAll WIT lie TAll T _YIlIl'llUS "0 1614 51 011 J 161 "0 IUD " 011 " 141 S CAPIIAL MIA INT 11I11 1614 24 1 614 504 . 121 221 I 121 I II S COMfY Of IL 'AIO III 1] III all JO IJ 'AlPATlI.S TOTAL ........ 51 011 J 161 " 011 " 011 " 0 141 IPOUII" TOIAL .......... 1425 504 a 9J2 I III I 0 1Jl [J III J 61 ) POfl PIMlIYLVNlIA "1!I11leHTS 0IlL V PA-40R INCOME TAX RETURN OFflC.IAl USE aNt y 1 9 "....au MUlt' 'ILr IV MIDNIGHT MOHOAV, APRIL IS, 1'''- 9 .0 "eNIV.., '1'" .......,.. . "'S !"dln. . tI" 5 c......,.,.."" of """'".... PA O",,,hun' of R....onu. TVPI FIL I R eChlclll Only On.. sO "0 SINGLE MAAAU!D Fllnl Slplratafy Ch.ck Hlf' Onl., U. P.rt-V.... ....hlettl FroM ,IHSlo ot"Q HAMI OF THI SCHOOL QISTfUCT '\&1,,-,. you bid DKI",bet 31,111' 8TEW~RT, WILLIAM J. , BARBARA C. 403 E. MAIN STREET MZCIIANICSBURG, PA 17055 MAllJI COIl"ICTlOIlI _lOW 'YMf ....., .....lIfHu..... m 0 00 "'UII', SOcii' SecufllyHu"'ll.,-.~."1I fllnl l.pu."I., m In.I ~ WEST SHORE . J[!J JOIN' '0 'IHAL SCHOOL DISTRICT COOl t:;!190q 5953800 59900 00 00 1374900 00 00 00 7388 00 20 900 168700 00 GO 00 168700 :II. t7 00 II .. .. X ~lIau..'. ,Ignltuft o,to NG HAUL DRIVE AID CHlCKIFYOU WILL NOTNIID A "tI'A TAX 800KLIT INDICATI HOWUAHV OF IACH FORM OR SCHIOUt.! ISA"ACHID . of For., Wo-a . 0' So"',,,,, UI . o' Seh,du". A . a. Seho.lId.. . . or Sott..... C . d. ISo"."'" RItooo I . of I.h......' . of I......... c...' . of Sa"'''''' 0 ... Sc:....... o..u .0..........,.... ... ........... . of .......... oJ . of .......... D-t 00 o II GROSS PlNNSYLVANIA COMPENSATION, , , . . . , , , . . , . ., tl 600 00 lit UNREIMBURSED IMPLOYE BUSINESS EXPENSES, , . , , , , , ., tit 472 00 10 TAXABLE PA COMPENSATION, SUblrOCl Uno Ib ~om Une II . . . . . . . , , .. 1. I TW8LEINTlREST.eon"JalePASChaduIeAWover.l.000".... . ., . " 2 I T W8LE DIVIDENDS, c:on..,loM PA Schadule B W over '1,000 . . . . . . . . . , . . . " 3 4 NIT INCOME Of (LOS9) ~om 1M OPERATION ., I BUS" PROFESSION or FARM . . , . 4 . NIT GAIN Of (LOSS] ~om 1M SALE, EXCHANGE or DISPOSmON ., PROPERTY . . . " · II AMOUNT 01 GAIN EXCLUDED on PA Schedule PA-tO , . , . , . , ,. III 00 . NIT INCOME Of (LOSS) ~om RENTS, ROYALTIES, PATENTS.r COPYRIGHTS . . , , I 7 ISTATE and TRUST INCOME, , , . . , , . . , . . . , , . , . , . . . . . . , , . , , 7 I GAMBLING Ind LOmRY WINNINGS, , , , , . , . . . , . , . . . . . , . , , . . , , I INCOME. Add Lift.. I J:I 4 I' hnd'. DONaT DEDUCT LOSSES. . .. . Mu UneO 2,11% 0,0128 . . , . . . . , . . . . . . , . . . , , . 0 II TOTAL PA TAX WlTllHELD . , . , , . . . . . . . , . . . . , . . , , , . , . . . t 11M IITIMATml PAYMlHTS AIIO CllEDlTS. "lid Inllructlona. . . , , . 121 CREDIT~omII1l14PATAXRETURN.,..""."..,..,. Ia. t_ ESTIMATED INSTALLMENT PAYMENTS , . . . . . , , , . . . . l:ao PAYMENT willi 1_ VCTENSION REQUEST, , . . , , , . . , , , , . lid TOTAL ESTIMATED CREDIT. Add u.. 121, 12b Ind 120 , . . . , . . TAX POflOI'ftNlII _ PA lICHEDULI! SP, "lid 1n11Ncllon1.. , , , , . 1:11 HOUSEHOLD MEMBERS ~om Uno 4, Part II, PA Schedule SP. . . ,. t:ll I. ELIGIBILITY INCOME ~om Una t, Part III, PA Schadule SP .' , . ,. t3l> 00 1:10 YOUR TOTAL INCOME ~om Une 2t, Step 5. SP WORKSHEET . , " t:lO 00 13d TAX 'ORGIVENESS .om Una 8, P.IIII, PA Schadule SP .'.... , 3d II TOTAL CREDIT lor TAXES PAID 10 OTHER STATES or COUNTRIES , . 4 II EMPLOYMENT INCENT1VE PAYMENTS CREDIT . , , , . , , , , , , . , , , , I . CREDITS and PAYMENTS, Add U.... 11 12d 13d t4lnd 15 . . . . . I t7 TAX IIUlE CfIUM to Ie ...... lhInUM tl, _10 _ 2t and ....."p.te PA Peyment V...- on II OWRPAVM!lf1'(Unl1l1e ...........Une to) , . . . . . . . . . . . , . . , . . . . " II III AMOUNT 01 UNE 1810 III REFUNDED . . . , . . . . . . , , . . . , , . , , . . , , . . , , , . . . I" AMOUNT 01 UNE 1810 III CREDITED 10 your 1988 ESTIMATED TAX ACCOUNT , , . , . . , . . . , tll AMOUNT 01 UNE 1110 III DONATED 10 WILD RESOURCE CONSERVATION FUND , , . . , , , . . lid AMOUNT 01 LINE 1110 III DONATED 10 U,S, OLYMPIC COMMITTEE, PA DIVISION " , , , , , . . l1te TOTAL of U.... III "'rouah tOcl MUST Equal Una lL lION YOUR A. TURN. U"d" penelll.. of p"-lu'.,., I I""If 111110101"".,.) d.cla'llh.t II....) h.v. ...mlnld thl. fllurn.lllcludlnO.II.ccompanyln'.ch.du......d .tltI......d "U.. b..,.t ..,.lou'l bl..r, III. bu., cortlct .nd COlli'''''' t211 ta. t20 00 00 00 2d You, 1lI...h." o.t. X IIIURI YOU (AND YOUA SPOUSE) SiaN. CHECttALl MAnt.AnACH All 5CHIDUlU"ND FO....S O.ytlm. hl'Phon. Numb.' 717-795-6222 Pr..,.,.,..N....: Pr",,,.,.. hl",l'Io"1 Numb., h....,...,. IC.....lllllyN....... .... to ""~....... I.r ......... Q I ~ ........ W B . . . . [36);361 ~ ':::I~Ai~r:T:AIVINUI ALLOWABLE EMPLOYE BUSINESS EXPENSES N...olT"""oywrCl..-mg~ . , , , STEWART. WILLIAM J. E~. N... ~.,.... Addr... ROADWAY EXPRESS INC. .0.8. 471 _ Iha DutIl 01 Iha Job In WhIch You Incurred _ "-"- RVER PART A: UNlOIlllUU N... end II11OUI11 ME B R 0 PART B: WORK a.antES AND UNIFORMS R Ired II a co_n 01 end no'",lIabla 10. PART C: lIMAIJ. TOOU AND SUPPlIU R ad II . condlllon 01 10 end nol _ Iha PART D: I'tIDRSSKlHAL t.JCeHSe FEES, MAlJ'RACTlCI! IHSURAHCE AIlD FIDElITY IONllI'tIEMIUMS II' co_n 01 PART E: TIlAVIL AND MlL!AOI! From _ ,.. 21. or PA Schedule UE-l - See I_Ill EXPENSES Add P_ A IIvo h E, Enler hont Il1d on Une Ib 01 PA-_ 1995 Sod.. Secur1ly Numblr 172-36-1361 . . AKRON OR 44309 E....,roy.... ToIopholll Numblr UII A 2 110 I 110 C 110 D 52 110 I! 110 1b 472 1995 'A40~'fIIlK-") filA OI'AIUMINT 0' ".VINUI Nomo(.) II shown on your PA T.. R8IU.n: PA SCHEDULE SP __ you can COI'I1lIa1a lI1iIochedule, you MUST """,,Iola ... SP WORKSHEET. PART I, c.tltlca..... of I!Iglblllly: I (ond my SpouIa) how road 1ha_o:1IoIII .nd cerlIIy 11111111I1 (0. we .e) oIgIble lot Tox For~: SeaIloll A: FlIng II "S',1IIngIoo Of...., Manted FlIInIJ ~e A_ I, 0 I C<W1IIy I peroonllly provided 11_ o....hlll of my own TollI Support In 1995 .nd 10m oIIgIbIa lot Tox Forglve_. " a.g Y, Monied fling Sap... RlI\Jm, e_ YOU' opouoe'. N... Sodll Secur1ly _ , 2. 0 I C<W1IIy IhoI 10m. dependent 01. peroon who II oIgIbIa 10. Tox Fo.~, 10m belng c1_ II . dependent on ... PennoyI\I..... PononoI Income T.. RalUrn o~ N... .nd Sodll Secur1ly Numblr SeaIlollI: FlIng.. ""', _ _ -.... Ta F~_ JoIn1Iy 3. 0 1_ my OPOU" C<W1IIy .hllwe.e _ oIIgIbIa lot Tox Fo.~ .nd _10 tile . JoII11 PA Schedule SP, AIeo uee 1I1iI1IIIUa. you" JoIntlY but only one opouoe qu_ "" T.. Fo~ end Iha 0_ opouoell a dependen1_ no ....bIa Income. SeaIloll C: fling.. "F", FlnaI PA R_Ior. d., I nod __ Road Iha I_Ill lot Ihla .-ng oletUI, I C<W1IIy that .!....O Tho -.... In oIgIbIa Cl_ or In oIIgIbIa Dependen1 "" T.. F~ purpo-. PART II, _ of f&oo .oId __.Ior T.. ForgIv.._..........: 1." .. ble lor T.. F _ .1.. If AIlD oe .elO'TM ble .nd .- - s-mty - " you .. cIeIrrIng your IpOUIlI II YOU' dependel11, """,,Iola Una 2. "IO'TM of you .. ........ ..... you ..fling JoIntlY, DO NOT CX*PlnI! UHI! 2. :z. a. E_1ho It..........." Ior_ PlEASE PRINT Il1d D JIP u...-r. NInMt Alii AeIolGnohlp NO chid c1_ _, Enler... numbIr _ twe, 110 110 110 110 110 NO NO NO NO NO 4. TolII N~ 01 Houoehold M..,Ibot.. Add U_ 1,2 .nd 3, En.. here .nd on Une 13. of you. PA-_, See InotruclIone. PART III, CoIcuII1Ing Vow Tu ForgIven_~: o I. EUGIBllITY INCOME 110m Une 1201 you. SP WOIlKSHEET, II uSlng IIIIng stllU. 'J" .nd c101m1ng T.. Fo/~ jolntly,ll1Ier ... TOTAL (JoInt ColrJmn) EllglbII!y Income for You and You. Spauoe, II uSlng IIIIng st.lu. oS. Slngfa, or "M" MIITIId FlIng Sap.."", Re!U.,,", or "F", Decoooed, Flnll RllIum, Il1Ier ... ElIgIbility Income 110m YOUR CoIrJmn. AIoo, enfIr on Una 13b 01 YOU' PA-<lOR, 1 :z. TAX lIABIlITY .om Una 1001 YOU' PA-_, 2 a. LESS RESIDENT CREDIT 110m Une 1401 you. PA-<lOR, 3 4. NET TAX UABllITY, Sub.ocl Une 3 110m UIII 2 end en'.'" reouft here, 4 I. PERCENTAGE OF TAX FORGIVENESS .om tile EIIgIbllIty Income T-. See lnolructlons, . .. AMOUNT OF TAX FORGIVENESS CREDIT. MuHlplyllrt.. byll'" Sandtttt.,ttt.,.",H Pt....".) Gnlln, I'dof )'Out PA-40A. Q . . . . r. . W 2 FAfltltNnS IAU:w;h W 2 ~I 2 EMPlO'l'FI! 8IJSIUfs..Q EXFENSES /Att;Jch Slllle 5dtllrlul. VI:. t Aro1 R'Quilfld Artl\Chmenllll I IAXAIlIF W'Jr"'ltllN(i~t<:lJt'll,wlllll..'I,nrtll'''p II .. "tHFn 'AllAm IE FARNED INCOf.<<: rNn Itl'8f"~I.~' (}t V~w~1 BII"ltMs AlIlIdl ';llJIPOlIJ"1J [)o(ulllotltl'l l\ fOrM U,lIAOLF FAHlIFO IHCX.....'" RHonE tlH f'norlT!\ Illl~\l'I~1 HIO,", fin r FMf'1 ()''''''FNf l^,ltlllf'''' ],111lf.l, fl flFf tOM rnOM SElF El.lPlovFO BUSINESS. rROf'ESf'IQN, OR rAm.. ItJ~.. I... 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I PAE!';Em ---. ...~ ,---_...- ----- :=-==Ilrr.tID__ -- =~~- !'MI "((OlIOS lOCAl' JH";-;; AM . III_Nt Of' I~ THE COURT O~ CO~lMON PLEAS OF CL~ER~~D COUNTY. PE~NSYLV~~IA WILLIAM J. STEWART , Plaintiff vs. BARBARA C. STEWART , Defendant :010. 96 - 1567 Civil Term 19 William J. Stewart a master with respect to the (X) Divorce ( ) Annulment ( ) Alimony ( ) Alimony Pendente MOTION FOR APPOI~TME:oIT OF MASTER (Plaintiff) (~). moves the ~ourt to appoint following claims: Lite ( ( ( ( ) ) ) ) Distribution of Property Support Counsel Fees Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claims(s) for which the appointment of a master is requested. . . (2) The defendant (has) ~ appeared in the action (personally) ~~.:._.::::::::::::::..-" _...~. . . (3) The staturory ground(s) for divorce (is) (are) 81101 It'll (4) Delete the inapplicable paragraph(s): 1xi The action is not contested. lMX An agreement has been reached with respect to the follOWing claims: claims: Di vnrr.p (c) The action is contested with respect to the following or fact. (5) The action ~IlQc (does not involve) complex issues of law (6) (7) The hearing is expected to take 2 (hours) ed.J_~. Additional information. if any. relevant to the motion: d;t.:u$ Attorney for (Plaintiff) Date: ('/(d9~ I r \ . / ORDER APPOINTI~G MASTE,R, r r-.... L- ,- AND NOW ~ (Y ,19 {/C,. ( ""q..-3. L f. _ He..--c........ Esquire, is appointed master with respect tcithe following claims :...Lt-<<? L\:ct.L~ ( jB.(_~.,.I_-Ld ~;' " I Jet C~~;;>-:~.Sl___ Fll[o-rJFRce "'- T' ,. '"~-, ~"iT''''' t.}r .1" , " '.. ',<ltH 95JUNIlI r,ijl':~O (;, ,', . .. . l ' "r' 1""I'.,I...i...i .,.'", ,iJ . _I ....\. FEN:,;S'{LV.~.'jlA I - '- M ,-' N .;~ "')- I~ :r: J~ 0- )~ N 7~ 1(5 ~. ;i; ~ C'\o.. .'-.:: .... '" ::i 0 en U 0e- rCXthl.lHld g..0e- ~PWnd ATTORNEYS AT LAW 2800 MAR~ET STREET CAMP HILL, PENNSYLVANIA 11011 (111) 130-9394 KEITH 8, DeARMOND JACKIE J. DeARMOND September 6. 1996 E, Robert Elicker, II. Esquire Office of the Divorce Master 9 North Hanover Street Carlisle. PA \'7013 RE: Stewart v, Stewart Dear Mr, Elicker: Enclosed please find a file stamped copy of Defendant. Barbara C, Stewart's Answer L'Id Counter Claim in the above referenced divorce action, Very truly yours, DeArmond & DeArmond f(ib/~ f?f)~'~uL --'!.' Keith B, DeArmond. Esquire KBDllm Enclosure cc: Barbara C, Stewart '.. o- r, ,-'. ,",: U,l C,. tt - 9 '.J 1:1, I :-', '-- -'j u.. , '- , ..... " .. '"~ . t. 0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WilliamJ Stewart. No 96-1567 Plaintiff v. CIVIL ACTION. LAW Barbara G Stewart Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330lCdl OF THE DIVORCE CODE 1. I consent to the entry of a tinal Decree of Divorce without notice 2 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. 3. I understand that I will not be divorced until a divorce decree is entered by the CDurt and that a copy of the decree will be sent to me immediately after it is tiled with the Prothonotary. I veritY 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 CS. ~4904 relating to unswom falsification to authorities. Date: \ \'~L\-''1I# ~c..&.., ..~ St.~ Barbara G Stewart, Defendant . ,. f C . , lUI. ~.; O. ~: c: .J ." 6' : " " , G.:l , ( I : ~. I' , . ( - "- .J - ....:.'1;. ~~ ...... -.3 ...... "t 1 .~ @ ~ !lot ~ ~~ U "'" ... ~ ~ -IJ ! ~ ~ c ~ I~ a '-i ~ r. +J ::1 C ;: '-i IIJ ~~ t~ '" I'd .... c..Sl . .-t . ! .. . VI.... z ~!~~ ! ll< ... 0"," ~~ ~< 0 i c.. ::: ><"'" I'lj:; ...,,: .. ~::al UiiP' .n ~ ZU ... ~Q~ ~~ ~i :!I tIl en <;> 00 .. 0,.. . ~., ~ ::1 "'"10 . > . ~Sltll ~ ~~ I") U Z ;: ...z 0 E. z~s U ~ ..:I'" o ... "'" ","ll< ~. "'" ~uui ... CONSTANCE P. BRUNT AITPH;\iEY ,\I" lAW if . '. .. NILLIAM J. STBNART, 1 IN THB COURT OF COMMON PLBAS OF Plaintiff I CUMBBRLAND COUNTY, PENNSYLVANIA v. I I CIVIL ACTION - LAN I BARBARA C. STBNART, I NO. 96-1567 CIVIL TERM I Defendant I IN DIVORCB QUALIFIED DOMESTIC RELATIONS ORDER AND NON, this I, ~ day of Fw",,"7 hereby ORDERBD and DECREED as follows: , 1997, it is 1. The parties hereto were formerly husband and wife, having been divorced by Decree entered December 30, 1996, by this Court, docketed to the above-captioned term and number. 2, PLAINTIFF, WILLIAM J. STEWART (Social Security No. 172- 36-1361; Date of Birth: June 29, 1945), hereinafter referred to as "Participant", is a participant in the Central Pennsylvania Teamsters Defined Benefit Plan (hereinafter known as the "Plan"). 3. DEFENDANT, BARBAR~ C. STEWART (Social Security No. 207-34-7036; Date of Birth: October 14, 1945), hereinafter referred to as "Alternate Payee", has raised a claim for equitable distribution of marital property in the above-captioned proceedings. . . ... Paragraph 2 above as a portion of her equitable distribution of marital assets. The Plan Administrator is hereby directed to pay the said equitable distribution portion to Alternate Payee directly, which payment shall commence as soon as administratively feasible following Participant's commencement of the receipt of benefits, in accordance with the terms of the Plan and the elections made by Parcicipant upon his retirement. 4. Nothing herein shall limit or restrict Participant's right to make any elections of the form or time of commencement of benefits available to him under the Plan. 5. Alternate Payee shall be solely responsible for the payment of such taxes as might be owing on funds distributed to her pursuant to this Order. 6. The parties shall promptly submit this Order to the Plan Administrator for determination of its status as a Qualified Domestic Relations Order and shall submit any additional documentation or information as is required to effectuate the distribution made to Alternate Payee herein as soon as administratively practicable. 3 WILLIAM J. STEWART, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I I CIVIL ACTION - LAW v. I I NO. 96-1567 CIVIL TERM BARBARA C. STEWART, I Defendant I IN DIVORCE MOTION FOR ENTRY OF STIPULATED QUALIFIED DOMESTIC RELATIONS ORDER AND NOW comes the Plaintiff, WILLIAM J. STEWART, by and through his attorney, CONSTANCE P. BRUNT, ESQUIRE, and moves this Honorable Court as follows: 1. The parties to this action were divorced by Decree of this Honorable Court dated December 30, 1996. 2. On December 20, 1996, the parties executed a Marital Settlement Agreement, pursuant to which they resolved all of their various economic claims against one another arising from their marriage, including, without limitation, equitable distribution of marital property. 3. In the aforesaid Agreement, the parties agreed to the equitable distribution of Plaintiff's pension through the Pennsylvania Teamsters Defined Benefit plan (the "Plan"), resulted from his employment during the marriage, and agreed to cooperate in the entry of a Qualified Domestic Relations Order 1,"1'" ;,,,,,,...__~.~....,'.:-:i:'<, directing the distribution of the retirement plan. 4. Attached hereto is a proposed Qualified Domestic Relations Order applicable to the Teamsters Defined Benefit pension, which has been signed and consented to by both parties. 5. The said proposed Qualified Domestic Relations Order has also been submitted to the plan for preliminary approval of its language. WHEREPORE, plaintiff respectfully moves this Honorable Court to enter an Order in the proposed form attached hereto making distribution of the plaintiff's defined benefit pension as set forth therein. Respectfully submitted, jJt:~j1Jr CONSTANCE P. BRUNT, ESQUIRE Supreme Court 1.0. No. 29933 2941 North Front Street Harrisburg, PA 17110 (717) 232-7200 Attorney for plaintiff 2 CERTIFICATE OF SERVICE I, CONSTANCE P. BRUNT, ESQUIRE, do hereby certify that Cln the ~fL- day of :;: Jl<.().'j , 1997, I served a true and correct copy of the foregoing Motion For Entry of Stipulated Qualified Domestic Relations Order by depositing same in the United States Mail, first-class postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: Keith B. DeArmond, Esquire DeArmond & DeArmond 2800 Market Street Camp Hill, PA 17011 Attorney for Defendant ~ /Y';J ('--'Ii-. 'ii..f kf, CONSTANCE P. BRUNT, ESQUIRE 2941 North Front Street Harrisburg, PA 17110 (717) 232-7200 Attorney for Plaintiff 3 u ~~ ...; .. III ... .. j ~ ~ ... j II<CIl ...; '" !I I .. ::l r:: =: '" ...; ...11 ~ ~ ~ ~ ;;:. ", ... - .... . ! 0,,,; '" . "'... a ~~~ I II< I ... i:l. ~ 8 < e""; J: ~~IO ....... "'iZ .::",: .. ..",Gl ~~ 11 r:: &'0 ,n Gl ... ~5 ~ ~ .. CIl ... 11 0 " ! !r- '" . ::l 10110 . > . o III CIl ~~ l-.l tJ "'~a z ;::: 0 ~ ~ ~ r::....'..; ! ..:I~ 0::1.. U ~ 101 ...; c.", ~ .. ...; .... ~. S"Gl :II Oil ti: III ... 101 CONSTANCE p, UlurNT .\rl\ 1k.~.t'i\T LAW , b- . WILLIAM J. STEWART, I IN THB COURT 011' COMMON PLns 011' Plaintiff I CUMBBRLAND COUNTY, PBNNSYLVANIA v. I I CIVIL ACTION - LAW I BARBARA C. STEWART, I NO. 96-1567 CIVIL TBRM I Defendant I IN DIVORCB QUALIII'IED DOMESTIC RELATIONS ORDER AND NOW, this ". day of 1I'~u.., , 1997, it appearing to the Court that: 1. The parties hereto were formerly husband and wife, having been divorced in the above-captioned proceedings by Decree dated December 30, 1996. 2. Plaintiff. WILLIAMJ, STEWART, (Social Security Number 172-36-1361; Date of Birth: June 29, 1945), hereinafter referred to as "Participant", is a participant in the Central Pennsylvania Teamsters Retirement Income plan (Defined Contribution portion) , hereinafter known as the "Plan". 3, Defendant, BARBARA C. STEWART, (Social Security Number 207-34-7036; Date of Birth: October 14, 1945), hereinafter referred to as "Alternate Payee", had raised a claim for equitable distribution of marital property in the above-captioned proceedings, 0- 4. Participant's current mailing address is 402 East Main Street, Mechanicsburg, PA l7055. 5. Alternate Payee's current mailing address is 2621 Market Street, Camp Hill, PA 17011. Alternate Payee shall be re6ponsible for maintaining a current mailing address on file with the plan at all times. IT IS ORDERED, ADJUDGED AND DECREED as follows: 1. A portion of Participant's account under the aforementioned Plan is marital property, subject to distribution by this Court. 2. The sum of $23,108.19 from Participant's account under the said Plan is awarded to Alternate Payee. This amount shall be segregated for her and shall be thereafter subject to all Plan gains and losses. 3. The entire remaining balance of Participant's account after segregation of the amount of $23,108.19 for the benefit of Alternate Payee as set forth herein is awarded to Pa~ticipant. 4. The Alternate Payee shall be entitled to receive payment of the amount held for her benefit under the Plan as provided above following the earliest of: (i) the date on which the Participant attains retirement age under the Plan, (ii) the date of Participant's death, (iii) the earliest date at which the 2 . . Participant is entitled to a distribution under the Plan, or (iv) the earliest date as provided under the Plan (or under any amendment to the Plan) for payments to alternate payees. 5. Payment of the amount held for Alternate Payee's benefit under the Plan shall be made in any form of payment available to an alternate payee in accordance with the terms of the Plan, as the Alternate Payee (or her beneficiary, if applicable) may elect at her sole option. 6. The right of the Alternate Payee to select payment dates and forms of payment shall be independent of whether the Participant has actually retired or become separated from service and shall be independent of the form of payment selected by the Participant with regard to his portion of the Plan, 7. Any reasonable costs incurred by the Plan Administrator to effectuate the terms and conditions of this Order shall be assessed against the Alternate Payee if permissible under applicable law. B. Alternate Payee shall be solely responsible for the payment of such taxes as might be owing on funds distributed to her pursuant to this Order. 9. The parties shall promptly submit this Order to the Plan Administrator for determination of its status as a Qualified Domestic Relations Order and shall submit any additional documentation or information as is required to effectuate the 3 WILLIAM J. STEWART. I IN THE COURT or COMMON PLEAS or plaintiff I CUMBERLAND COUNTY. PENNSYLVANIA I I CIVIL ACTION - LAW v. I I NO. 96-1567 CIVIL TERM BARBARA C. STEWAR'f, I D.eandant I IN DIVORCE " ," .....~..:. MOTION rOR ENTRY or STIPULATED OUALIFIED DOMESTIC RELATIONS ORDER AND NOW comes the plaintiff, WILLIAM J. STEWART, by and through his attorney, CONSTANCE P. BRUNT, ESQUIRE, and moves this Honorable Court as follows: 1. The parties to this action were divorced by Decree of this Honorable Court dated December 30, 1996. ~. On December 20, 1996, the parties executed a Marital Settlement Agreement, pursuant to which they resolved all of their various economic claims against one another arising from their marriage, including, without limitation, equitable distribution of marital property. 3. In the aforesaid Agreement, the parties agreed to the equitable distribution of Plaintiff's pension through the Central pennsylvania Teamsters Retirement Income plan (the "plan"), which resulted from his employment during the marriage, and agreed to cooperate in the entry of a Qualified Domestic Relations Order