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live separate and apart from each other; and
WHEREAS, on March 27, 1996 Husband commenced an action in
divorce docketed to No. 95-1641 in the Court of Common Pleas of
Cumberland County, Pennsylvania (hereinafter the "Divorce
Action"); and
WHEREAS, the parties agree that their marriage is
irretrievably broken; and
WHEREAS, the parties acknowledg~ that each has had the full
opportunity to be advised independently and represented by
separate counsel concerning their respective rights, duties and
obligations arising out of their marital status and with respect
to the terms and provisions of this Post-Nuptial Agreement and
the meaning and legal effect thereof, Husband by Keith O.
Brenneman, Esquire and Wife by Samuel L. Andes, Esquire.
WHEREAS, the parties having a full opportunity to be so
advised of their respective rights, duties and obligations
arising out of their marital status, and each having a full
opportunity to investigate and evaluate assets, liabilities and
all other aspects of each other's property and their jointly
owned assets and liabilities, have voluntarily come to an
agreement for the final settlement of their property and affairs,
which they believe to be fair, just and equitable.
LAW O"":C'
SNII..BAICER.
BRENNEMAN
at SPA.RE
NOW THEREFORE, in consideration of these presents and the
I,
mutual covenants, promises, terms and conditions h~reinafter set
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forth and to be kept and performed by each party hereto, and
intending to be legally bound hereby, the parties mutually agree
as follows:
1. INCORPORATION OF PREAMBLE. The foregoing preamble and
paragraphs are incorporated by reference herein in their
entirety.
2. MUTUAL SEPARATION. Husband and Wife shall be free from
constraint or control by the other as fully as if he or she were
unmarried. Neither shall disturb, trouble or interfere in any
way with the other or with any person for associating with the
other.
J. DECLARATION AS TO ASSETS AND WAIVER OF EVALUATION.
The parties declare and agree that they have, prior to the
execution of this Post-Nuptial Agreement, voluntarily agreed to
divide and have physically divided and distributed Uetween
themselves all assets which they acquired during the course of
their marriage, with the exception of those assets specifically
addressed, disposed of and/or distributed in accordance with the
terms of this Agreement below. Said division and distribution
has, or as the case may be, will occur as set forth herein
whether or not said property is or would be deemed to be marital
property under the Pennsylvania Divorce Code and subject to
equitable distribution.
....w OJfJflCCI
SNI~DAKI".
SRENNEMAN
a SPARE
The parties declare and acknowledge that they are fully
aware and familiar with all assets and real property that each
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has brought Anto the marriage and that has been obtained or
acquired separately or jointly by them during the course of their
marriage and therefore waive any valuation thereof. Each party
expressly releases the other of and from any and all right of
equitable distribution or claims to assets and property of any
kind or nature whatever possessed in accordance with the division
that occurred prior to the execution of this Agreement and
possessed as a result of this Agreement by the other party and
hereby declares and acknowledges that the voluntary division by
them of all property, whether marital or not, is fair and
equitable.
4. MARITAL RESIDENCE AT 1128 HIGHLAND DRIVE. FAIRVIEW
TOWNSHIP. YORK COUNTY.
Husband and Wife acknowledge that they acquired during their
marriage real property improved with a residence located at 1128
Highland Drive, Fairview Township, York County, Pennsylvania
(hereinatter the "marital residence").
"
Husband agrees to convey to Wife all of his right,
title and interest in the marital residence by executing and
delivering a special warranty deed for and to Wife, which
execution and delivery shall occur upon the execution by the
parties of this Agreement and all affidavits, consents and
waivers necessary to obtain a divorce decree in accordance with
Paragraph 10, infra. Upon execution of said deed by Husband,
l.AW o,,,cca
SNEL.BAICER.
aRCNNIMAN
a 5p"R!5:
Wife agrees to assume as her sole obligation any and all taxes,
insurance, utilities, repairs, water and sewer rents,
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claims, damages or other expenses incurred in connection with
said marital residence, and Wife agrees and covenants to hold
Husband harmless from any such liability or obligation, including
any attorney's fees incurred by Husband. Husband, however,
expressly agrees to pay to Wife or on account of Wife 50\ of the
cost to replace the existing roof on the marital residence.
5. CAMPER. Husband and Wife acknowledge that they acquired
a camper during their marriage. The parties agree that Husband
shall retain sole possession, ownership and use of the camper,
free of any claim of ownership or use by Wife.
6. AUTOMOBILES. The parties acknowledge that they acquired
during the course of their marriage various automobiles. Husband
shall retain sole possession, ownership and use of the 1993
Chevrolet Blazer, free of any claim of ownership or use by Wife.
Wife shall retain sole possession, ownership and use of the 1994
Chevrolet Blazer, 1986 Oldsmobile and 1967 Pontiac Le mans, free
of any claim of ownership or use by Husband.
LAW a,,'ICII:S
SNI.1.8AKER.
BRINNEMAN
a SPARE
7. FUTURE OBLIGATIONS. The parties agree that any and all
obligations incurred subsequent to February 26, 1996, shall be
the sole and separate liability and responsibility of the party
incurring the obligation and each party agrees that he/she will.
not incur or attempt to incur any obligations for or on behalf
the other party and will indemnify and hold harmless the othe~
party of and from any and all liability arising from such future
obligation.
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8. PENSION. 401K, RETIREMENT PLANS. BENEFITS AND
EMPLOYMENT BENEFITS.
Each party waives and forever releases the other of and from
any and all claims which either may have against the other's
pension, 401K Plan, retirement plan or any other retirement plan
benefit or employee benefit or benefits.
9. U.S. SAVINGS BONDS. Wife acknowledges that she has in
her possession and shall retain and own tree of any right, title
or claim of Husband, U. S. Savings Bonds valued in excess of
$4,000.00.
10. CEMETERY LOTS. Wife agrees to deliver and convey, if
necessary, to Husband the deed to and any interest she has in the
double cemetery lot at St. Johns Cemetery, Hampden Township,
Cumberland County, Pennsylvania.
11. RELEASE OF SUPPORT AND RIGHTS UNDER DIVORCE CODE.
Each party waives and forever releases the other party of
and from any and all claims which either may have against the
other for spousal support and except as otherwise set forth
herein, for all claims which either may have against the other
reason of and pursuant to the Pennsylvania Divorce Code (and
divorce law of any other jurisdiction) including, but not
to, alimotly, alimony pendente lite, equitable distribution
'-AW Q,.,.ICr:.
SNEL8.KIR,
BRENNEMAN
6. SPARE
marital property, counsel fees, costs and expenses, except
the performance of any obligation created hereunder may be
i enforced by any remedies under the Pennsylvania Divorce Code.
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12. DIVORCE. The parties agree to terminate their marriage
by mutual consent without counselling and each agrees to execute
the necessary affidavits, waivers and consents to procure a
consensual divorce under the provisions of the Pennsylvania
Divorce Code. Said affidavits, waivers and consents shall be
utilized f.or purposes of obtaining a divorce in the Divorce
Action.
13. ALIMONY/CHILD SUPPORT. Husband shall pay to Wife the
sum of $1,000.00 each month, payable on the first day of each
month up to June, 1999, said monthly payment shall be considered
allocated one-half (i.e. $500.00) toward support of the parties'
son, Richard O. Dayton, Jr. and one-half (i.e. $500.00) alimony
to Wife. Provided Richard O. Dayton, Jr. graduates from high
school as anticipated in June, 1999, Husband agrees to continue
to pay Wife the sum of $1,000.00 monthly from June, 1999 to May
2001, said amounts to be considered alimony only with no portion
allocated for child support. If Richard O. Dayton, Jr. does not
graduate from High School in June, 1999, Husband's monthly
pal~ents to Wife after June, 1999 shall be allocated as set forth
above as support and alimony until such time as Richard O.
Dayton, Jr. graduates, at which time all subsequent monthly
payments up to May 2001 shall be considered alimony in their
entirety.
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Nothing herein shall be construed as requiring Huab.~~[,
l.AW O"ICCS
SNELBAKIR.
BRENNEMAN
a SPARE
to pay Wife alimony and child support or alimony beyond May,
2001.
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In the event of the death of Wife, or in the event Wife
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remarries or regularly cohabitates with an individual of the
opposite sex not related to her, but in no other event, shall the
alimony payments cease.
It is the intention of the parties that all payments
made by Husband to Wife pursuant to this Paragraph as alimony
shall be periodic payments in discharge of a legal Obligation,
which, because of the marital relationship is imposed on or
incurred by Husband under a written instrument incident to a
divorce, all within the meaning of the Internal Revenue Code (..
Amended) as now in effect and of similar provisions of future
laws. Such payments will be includable in Wite's gross income
and will be deductible by Husband in determining their respective
taxable income.
14. LIFE INSURANCE. Husband agrees to maintain Wite's
portion Jf the whole life insurance policy obtained through
Nationwide Insurance until the earlier of Husband's retiremen~
from employment or January 1, 2004.
15. CUSTODY. Wife shall have full physical custody ot the
parties' two children.
16. GENERAL RELEASE. Husband relinquishes his inchoa~.
intestate right in the estate of Wife, and Wite relinquish..heri
inchoate intestate right in the estate of Husband, and each ot
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the parties hereto by these presents, for
himself or herselt, hl.s
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i"AW O....lce.
SNILBAKJ:ft.
BAINNEMAS
a SP.lRE
or her heirs, executors, administrators
II rem ise,
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release, quit-claim and forever
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l.AW oPPle<<,
SNELBAKEA.
BRENNEMAN
a SPARE
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hereto, his or her heirs, executors, administrators or assigns,
or any of them, of any and all claims, demands, damages, actions,
causes of action or suits at law or in equity of whatsoever kind
or nature, for or because of any matter or thing done, omitted or
suffered to be done by such other party prior to the date hereof,
except that this release shall in no way exonerate or discharge
either party from the obligations and promises made or imposed by
reason of this Agreement.
17, SURVIVAL OF AGREEMENT. It is the intention of the
parties that this Post-Nuptial Agreement shall survive any action
in divorce which may be instituted or prosecuted by either party,
and no order, judgment or decree of divorce, temporary,
interlocutory, final or permanent, shall affect or modify the
terms of this Agreement, but said Agreement may be enforced by
any remedy at law or in equity, inclUding enforcement proceedings
under the Pennsylvania Divorce Code. The parties agree to
incorporate this Agreement into a separate order of court to be
entered in the Divorce Action, but this Agreement shall not be
merged into said order or decree in divorce.
18. COOPERATION. The parties agree to cooperate with
other and to make, execute, acknowledge and deliver such
instruments and take such further action as may hereafter be
determined to be requisite and necessary to effect the purposes
and intention of this Post-Nuptial Agreement.
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19. BREACH: INDEMNIFICATION. If either party hereto
breaches any provision hereof, then the nonbreaching party shall
have the right, at his or her election, to sue for damages for
said breach, or seek such other remedi.s or relief as may be
available to him or her, and the defaulting party shall b.
responsible for payment of all reasonable legal fe.. and costs
incurred by the other party in enforcing his or her rights under
this Agreement. Each party agrees and covenants to indemnify and
hold harmless the other party from any and all liability and/or
claims and/or damages and/or expense. (including attorneys' fees
and expenses of litigation) that the indemnitee may sustain or
may become liable or answerable in any way whatscever, or shall
pay upon, or in the consequence of, the indemnitor's breach of
any obligation, term or covenant of indemnitor under this
Agreement, including, but not limited to, indemnitor's obligation
to make any payment provided for herein.
LAw a"le..
SNILDAICIIt,
aRINNEMAN
a SPARK
20. VOLUNTARY EXECUTION. The parties declare and
acknowledge that they have had the opportunity to have the
provisions of this Post-Nuptial Agreement and their legal effect
explained to them by independent counsel of their choosing and
each party acknowledges that this Post-Nuptial Agreement is fair
and equitable, that it is being entered into voluntarily, with
full knowledge ot tho assste ot both parties, and that it is not
the result of any duress or undue influence. The parties
acknowledge that they have boon furnished with all information
relating to the tinancial affairs ot the other to the extent
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same has been requested by each of them.
21. ENTIRE AGREEMENT. This Post-Nuptial Agreement contains
the entire understanding of the parties and there are no
representations, warranties, covenants or undertakings other than
those expressly set forth herein. The parties acknowledge and
agree that the provisions of this Agreement with respect to the
distribution and division of marital and separate property are
fair, equitable and satisfactory to them based on the length of
their marriage and other relevant factors which have been taken
into consideration by the parties. Both parties hereby accept
the provisions of this Agreement with respect to the division of
property in lieu of and in full and final settlement and
satisfaction of all claims and demands that they may now have or
hereafter have against the other for equitable distribution of
their property by any court of competent jurisdiction pursuant to
the Pennsylvania Divorce Code or any amendments thereto. Each
party voluntarily and intelligently waives and relinquishes any
right to seek a court ordered determination and distribution of
marital property, but nothing herein contained shall constitute a
waiver by either party of any rights to seek the relief of any
court for the purpose of enforcing the provisions of this
Agreament.
22. WAIVER. The waiver of any term, conditions, clause or
LAW onlc.,
SNEL8AKI...
BRENNENAN
6 SPARI
provision of this Agreement shall in no way be deemed or
considered a waiver of any other term, condition. clause or
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provision of this Agreement.
23. APPLICABLE LAW. This Agreement shall be construed,
interpreted and enforced according to the laws of the
Commonwealth of Pennsylvania.
24. HEADINGS. The headings or titles of the numbered
paragraphs of this Agreement have been used only for the purpose
of convenience and shall not be resorted to for the purposes of
interpretation or construction of the text of this Agreement.
25. EFFECTIVE DATE. This Agreement shall be dated and
become effective on the date when executed by the latter of the
two parties.
IN WITNESS WHEREOF, the parties have hereunto set their
respective hands and seals intending to legally bind themselves
and their respective heirs, personal representatives and assigns.
WITNESSED BY:
~
iit.L$~~..l-'SEALJ
lchard O. Day~on, Sr.
Date:
J. 1 {, ,
"-f frt;{e{~ <.i I /t2/!f..i(.. (SEAL)
~atrlcia 3. ayton
Date: ~?Ir y
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6. Neither party is a member of the armed torce. of the
United states ot America.
7. The Plaintiff avers that the grounds upon which this
action J.s based is that the marriage between the parties hereto
is irretrievably broken.
8. The Plaintitt has been advised that counseling is
available and that Plaintiff may have the right to request that
the Court require the parties to participate in counseling.
9. The Plaintiff requests this Court to enter a decree of
divorce.
COUNT II - EOUITABLE DIVISION OF PROPERTY
10. The Plaintift and Detendant have legally and
beneficially acquired property both real and personal during
their marriage trom October 24, 1970.
11. The Plaintiff requests this court to equitably divide
all marital property pursuant to Section 3502 of the Pennsylvania
Divorce Code.
WHEREFORE, the Plaintift requests this Honorable Court to:
(a) enter a decree of divorce, divorcing the Plaintiff
from the bonds ot matrimony;
!.AW 0",.11:1:1i
SNIELBAKER
a
BRINNEMAN
(b) order equitable distribution of property; and
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(c) order such other reliet as this Court deems just
and reasonable.
SNELBAKER , BRENNEMAN, P.C.
Date:
March II, 1996
By:
I<e
44 West Main Street
Mechanicsburg, PA 17055-0318
Telephone: 717-697-8528
Attorneys for Plaintiff
Richard O. Dayton, Sr.
LAW O''''CI:6
SNEL8AKIR
a
aftENNIMAN
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RICHARD O. DAYTON, SR.,
vs,
CIVIL ACTION - LAW
PATRICIA J, DAYTON,
NO. 96-1641 CIVIL TERM
Defendant
IN DIVORCE
AIDDA Vrr OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 27
March 1996 and was served upon the Defendant on or about ~~ C: / i~"
2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days I
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have elapsed from the date of filing of the complaint and the date of service of the complaint on the !
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Defendant. I
3, I consent to the entry of a final decree in divorce either after service of a Notice of
Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to
Request Entry of the Decree,
4, I have been advised of the availability of marriage counseling and Wlderstand that the
Court maintains a list of marriage counselors and that I may request the Court to require my spouse
and Ito participate in cowlselillg an.t, being so advised, do not request that the Court require that
my spouse and I participate in counseling prior to the divorce becoming final,
I verify that the statements made in this Affidavit are true and correct and I Wlderstand that
false statements herein are made subject to the penalties of 18 Pa, C,S, Section 4904 relating to
unsworn falsification to authorities,
5/13/9tf
DATE .
~ltftna ~. ADay/;;r;
ATRICIA J, DA ON
RICHARD O. DAYTON, SR.,
Plaintitt
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96-1641 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
vs.
PATRICIA J. DAYTON,
Detendant
'UIIlTU'J" B WAIVBR OJ' IlOTICI OJ' IIITIIITIOIl
TO RIQUIBT IIITRY OJ' A DIVORCI DIC.II
UNDIR BICTIOIl 33011CI OJ' THI DIVORCI COOl
1. I consent to the entry ot a final decree of divorce
notice.
2. I understand that I may lose rights concerning alimony,
ivision of property, lawyer's fees, or expenses if I do not
laim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce
ecree is ente~ed by the Court and that a copy of the decree will
e sent to me immediately after it is filed with the
rothonotary.
4. I verify that the statements made in this affidavit are
rue and correct. I understand that false statements herein are
subject to the penalties of 18 Pa. C.S. S 4904 relating to
nsworn talsification to authorities.
rl~ If 11f1g
LAw O"IC,.
SNELBAKER.
BRENNEMAN
8t SPARE
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RICHARD 0, DAYTON, SR" ) IN THE COURT OF COMMON
) PLEAS OF CUMBERLAND COUNTY,
Plaintiff ) PENNSYLVANIA
)
vs, ) CIVIL ACTION. LAW
)
PATRICIAJ, DAYTON, ) NO, 96-1641 CIVIL TERM
)
Defendant ) IN DIVORCE
WAIVER OF NOTICE QF INTENTION TO REOUEST ENTRY
QF A DIVORCE DECREE UNDER SECTION 3301lc) OF TilE DIVORCE COD~
I, I consent to the entry of a final decree in 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 te me immediately after it is tiled 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, Section 4904 relating to
unsworn falsification to authorities,
~ //3/ C),~
DATE .
t.~tttflL~ ~ ).Orufan
ATRICIA j, DA TON
Domestic Return Receipt are attached hereto and incorporated by
reterence herein as "Exhibit B"; and that the foregoing facts are
true and correct to the best of his knowledge, intormation and
belief.
~,'~'tt{"~,,-
Keith o. Brenneman
Sworn to and subscribed before
me this
9d
day of April, 1996.
gz;,,-,,;~) Q: 'itJA-n~''-/
I Notary ubl c
NiJ!:!r;,JI S{~.11
PnlflcJJ J n1';rnscr; ;~otary Pu~1c
w,tJehdtlk'.sbur9 8oro, CIJmborfand County
!\.h :,.;lTlII1ISSJQf1 E"PHUo, Oac 3L '998
l\;,.;'TIbJl, ?ldlll~l~rrn~l.ANot::rteG
LAw O""IC..
SNEL.8AKER
Ii
BRENNEMAN
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live separate and apart from each other; and
WHEREAS, on March 27, 1996 Husband commenced an action in
divorce docketed to No. 95-1641 in the Court of Common Pleas of
Cumberland Ccunty, Pennsylvania (hereinafter the "Divorce
Action"); and
NHEREAS, the parties agree that their marriage is
irretrievably broken; and
WHEREAS, the parties acknowledge that each has had the full
opportunity to be advised independently and represented by
separate counsel concerning their respective rights, duties and
obligations arising out of their marital status and with respect
to the terms and provisions of this Post-Nuptial Agreement and
the meaning and legal effect thereof, Husband by Keith o.
Brenneman, Esquire and Wife by Samuel L. Andes, Esquire.
WHEREAS, the parties having a full opportunity to be so
advised of their respective rights, duties and obligations
arising out of their marital status, and each having a full
opportunity to investigate and evaluate assets, liabilities and
all other aspects of each other's property and their jointly
owned assets and liabilities, have voluntarily come to an
agreement for the final settlement of their property and affairs,
which they believe to be fair, just and equitable.
LAW Q"ICtl
SNE\.DAKER.
BRENNEMAN
a SPAR!;
NOW THEREFORE, in consideration of these presents and the
mutual covenants, promises, terms and conditions hereinafter set
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LAW 0..U:1:5
SNE1..QAKER.
BReNNEMAN
a: SPARE:
_..._ i __.i:
forth and to be kept and performed by each party hereto, and
intending to be legally bound hereby, the parties mutually agree
as follows:
1. INCORPORATION OF PREAMBLE. The foregoing preamble and
paragraphs are incorporated by reference herein in their
entirety.
2. MUTUAL SEPARATION. Husband and Wife shall be free from
constraint or control by the other as fully as if he or she were
unmarried. Neither shall disturb, trouble or interfere in any
way with the other or with any person for associating with the
other.
3. DECLARATION AS TO ASSETS AND WAIVER OF EVALUATION.
The parties declare and agree that they have, prior to the
execution of this Post-Nuptial Agreement, voluntarily agreed to
divide and have physically divided and distributed between
themselves all assets which they acquired during the course of
their marriage, with the exception of those ass~ts specifically
addressed, disposed of and/or distributed in accordance with the
terms of this Agreement below. Said division and distribution
has, or as the case may be, will occur as set forth herein
whether or not said property is or would be deemed to be marital'
property under the Pennsylvania Divorce Code and subject to
equitable distribution.
The parties declare and acknowledge that they are fully
aware and familiar with all assets and real property that each
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has brought into the marriage and that has been obtained or
acquired separately or jointly by them during the course of their
marriage and therefore waive any valuation thereof. Each party
expressly releases the other of and from any and all right of
equitable distribution or claims to assets and property of any
kind or nature whatever possessed in accordance with the division I
that occurred prior to the execution of this Agreement and
possessed as a result of this Agreement by the other party and
hereby declares and acknowledges that the voluntary division by
them of al~ property, whether marital or not, is fair and
equitable.
4. MARITAL RESIDENCE AT 1128 HIGHLAND DRIVE. FAIRVIEW
TOWNSHIP. YORK COUNTY.
Husband and Wife acknowledge that they acquired during their
marriage real property improved with a residence located at 1128
Highland Drive, Fairview Township, York County, Pennsylvania
(hereinafter the "marital residence").
Husband agrees to convey to Wife all of his right,
title and interest in the marital residence by executing and
delivering a special warranty deed for and to Wife, which
execution and delivery shall occur upon the execution by the
parties of this Agreement and all affidavits, consents and
waivers necessary to obtain a divorce decree in accordance with
LAW O"lC:U
SNEI..DAKER.
BRENNEMAN
a SPARE:
Paragraph la, infra. Upon execution of said deed by Husband,
Wife agrees to assume as her sole obligation any and all taxes,
homeowners' insurance, utilities, repairs, water and sewer rents,
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claims, damages or other expenses incurred in connection with
said marital residence, and Wife agrees and covenants to hold
Husband harmless from any such liability or obligation, inclUding
any attorney's fees incurred by Husband. HUSband, however,
expressly agrees to pay to Wife or on account of Wife 50\ of the
cost to replace the existing roof on the marital residence.
5. CAMPER. Husband and Wife acknowledge that they acquired
a camper during their marriage. The parties agree that Husband
shall retain sole possession, ownership and use of the camper,
free of any claim of ownership or use by Wife.
6. AUTOMOBILES. The parties acknowledge that they acquired
during the course of their marriage various automobiles. Husband
shall retain sole possession, ownership and use of the 1993
Chevrolet Blazer, free of any claim of ownership or use by Wife,
Wife shall retain sole possession, ownership and use of the 1994
Chevrolet Blazer, 1986 Oldsmobile and 1967 Pontiac Le mans, free
of any claim of ownership or use by Husband.
7. FUTURE OBLIGATIONS. The parties agree that any and all
obligations incurred subsequent to February 26, 1996, shall be
the sole and separate liability and responsibility of the party
incurring the Obligation and each party agrees that he/she will
not incur or attempt to incur any obligations for or on behalf of
l.,Aw a'Il'IClrS
SNEI..DAKER.
8AENNlMAP~
a SPARE:
the other party and will indemnify and hold harmless the other
party of and from any and all liability arising from such future
obligation.
-5-
, .
8. PENSION. 401K. RETIREMENT PLANS. BENEFITS AND
EMPLOYMENT BENEFITS.
Each party waives and forever releases the other of and from
any and all claims which either may have against the other's
pension, 401K Plan, retirement plan or any other retirement plan
benefit or employee benefit or benefits.
9. U.S. SAVINGS BONDS. Wife acknowledges that she has in
her possession and shall retain and own free of any right, title
or claim of Husband, U. s. Savings Bonds valued in excess of
$4,000.00.
10. CEMETERY LOTS. Wife agrees to deliver and convey, if
necessary, to Husband the deed to and any interest she has in the
double cemetery lot at st. Johns Cemetery, Hampden Township,
Cumberland County, Pennsylvania.
11. RELEASE OF SUPPORT AND RIGHTS UNDER DIVORCE CODE.
Each party waives and forever releases the other party of
and from any and all claims which either may have against the
other for spou~al support and except as otherwise set forth
herein, tor all claims which either may have against the other by
reason of and pursuant to the Pennsylvania Divorce Code (and the
divorce law of any other jurisdiction) including, but not limited
to, alimony, alimony pendente lite, equitable distribution of
LAW O"ICC.
SNEL.BAlCER.
SAENNEto'''N
a SPARE
marital property, counsel fees, costs and expenses, except that
the performance of any obligation created hereunder may be
enforced by any remedies under the Pennsylvania Divorce Code.
-6-
. .
12. DIVORCE. The parties agree to terminate their marriage
by mutual consent without counselling and each agrees to execute
the necessary affidavits, waivers and consents to procure a
consensual divorce under the provisions of the Pennsylvania
Divorce Code. Said affidavits, waivers and consents shall be
utilized for purposes of obtaining a divorce in the Divorce
Action,
13. ALIMONY/CHILD SUPPORT. Husband shall pay to Wife the
sum of $1,000.00 each month, payable on the first day of each
month up to June, 1999, said monthly payment shall be considered
allocated one-half (i.e. $500.00) toward support of the parties'
son, Richard O. Dayton, Jr. and one-half (i.e. $500.00) alimony
to Wife. Provided Richard O. Dayton, Jr. graduates from high
school as anticipated in June, 1999, Husband agrees to continue
to pay Wife the sum of $1,000.00 monthly from June, 1999 to May
2001, said amounts to be considered alimony only with no portion
allocated for child support. If Richard o. Dayton, Jr. does not
graduate from High School in June, 1999, Husband's monthly
payments to Wife after June, 1999 shall be allocated as set forth
above as support and alimony until such time as Richard O.
Dayton, Jr. graduates, at which time all subsequent monthly
payments up to May 2001 shall be considered alimony in their
entirety. Nothing herein shall be construed as requiring Husband
to pay Wife alimony and child support or alimony beyond May,
LAW Q"ICII
SNILDAI((R.
BRENNEMAN
a SPARE
2001.
In the event of the death of Wife, or in the event Wife r
-7-
remarries or regularly cohabitates with an individual of the
opposite sex not related to her, but in no other event, shall the
alimony payments cease.
It is the intention of the parties that all payments
made by Husband to Wife pursuant to this Paragraph as alimony
shall be periodic payments in discharge of a legal obligation,
which, because of the marital relationship is imposed on or
incurred by Husband under a written instrument incident to a
divorce, all within the meaning of the Internal Revenue Code (as
Amended) as now in effect and of similar provisions of future
laws. Such payments will be includable in Wife'S gross income
and will be deductible by Husband in determining their respective
taxable income.
14. LIFE INSURANCE. Husband agrees to maintain Wife's
portion .f the whole life insurance policy obtained through
Nationwide Insurance until the earlier of Husband's retirement
from employment or January 1, 2004.
15. CUSTODY. Wife shall have full physical custody of the
parties' two children.
LAW o,.,.lcca
SNELDAKER.
BRENNEMAN
81 SPARE
16. GENERAL RELEASE. Husband relinquishes his inchoate
intestate right in the estate of Wife, and Wife relinquishes her
inchoate intestate right in the estate of Husband, and each ot
the parties hereto by these presents, for himself or her~elt, his
or her heirs, executors, administrators or assigns, does hereby
remise, release, quit-claim and forever discharge the other party
-8-
I
ii
. .
hereto, his or her heirs, executors, administrators or assigns,
or any of them, of any and all claims, demands, damages, actions,
causes of action or suits at law or in equity of whatsoever kind
or nature, for or t'l"cau8e" 'ny matter or thing done, omitted or
suffered to be done by such other party prior to the date hereof,
except that this release shall in no way exonerate or discharge
either party from the obligations and promises made or imposed by
reason of this Agreement.
17. SURVIVAL OF AGREEMENT. It is the intention of the
parties that this Post-Nuptial Agreement shall survive any action
in divorce which may be instituted or prosecuted by either party,
and no order, judgment or decree of divorce, temporary,
interlocutory, final or permanent, shall affect or modify the
terms of this Agreement, but said Agreement may be enforced by
any remedy at law or in equity, including enforcement proceedings
under the Pennsylvania Divorce Code. The parties agree to
incorporate this Agreement into a separate order of court to be
entered in the Divorce Action, but this Agreement shall not be
merged into said order or decree in divorce.
18. COOPERATION. The parties agree to cooperate with each
other and to make, execute, acknowledge and deliver such
LAW O"'ICCS
SNELBAtCEA.
BRENNEMAN
a SPARE
instruments and take such further action as may hereafter be
determined to be requisite and necessary to effect the purposes
and intention of this Post-Nuptial Agreement.
II
II
i
-9-
, .
LAW a'Pler.
SNELBAICIR.
BRINNEMAN
a SPARE
19. BREACH: INDEMNIFICATION. If either party hereto
breaches any provision hereof, then the nonbreaching party shall
have the right, at his or her election, to sue for damages for
said breach, or seek such other remedies or relief as may be
available to him or her, and the defaulting 9arty shall be
responsible for payment of all reasonable legal fees and costs
incurred by the other party in enforcing his or her rights under
this Agreement. Each party agrees and covenants to indemnify and
hold harmless the other party from any and all liability and/or
claims and/or damages and/or expenses (including attorneys' fees
and expenses of litigation) that the indemnitee may sustain or
may become liable or answerable in any way whatsoever, or shall
pay upon, or in the consequence of, the indemnitor's breach of
any obligation, term or covenant of indemnitor under this
Agreement, including, but not limited to, indemnitor's obligation
to make any payment provided for herein.
20. VOLUNTARY EXECUTION, The parties declare and
acknowledge that they have had the opportunity to have the
provisions of this Post-Nuptial Agreement and their legal effect
explained to them by independent counsel of their choosing and
each party acknowledges that this Post-Nuptial Agreement is fair
and equitable, that it is being entered into voluntarily, with
full knowledge of the assets of both parties, and that it is not
the result of any duress or undue influence. The parties
acknowledge that they have been furnished with all information
relating to the financial affairs of the other to the extent
-10-
i!
. ,
same has been requested by each of them.
21. ENTIRE AGREEMENT. This Post-Nuptial Agreement contains
the entire understanding of the parties and there are no
representations, warranti~s, covenants or undertakings other than
those expressly set forth herein. The parties acknowledge and
agree that the provisions of this Agreement with respect to the
distribution and division of marital and separate property are
fair, equitable and satisfactory to them based on the length of
their marriage and other relevant factors which have been taken
into consideration by the parties. Both parties hereby accept
the provisions of this Agreement with respect to the division of
property in lieu of and in full and final settlement and
satisfaction of all claims and demands that they may now have or
hereafter have against the other for equitable distribution of
their property by any court of competent jurisdiction pursuant to
the Pennsylvania Divorce Code or any amendments thereto. Each
party voluntarily and intelligently waives and relinquishes any
right to seek a court ordered determination and distribution of
marital property, but nothing herein contained shall constitute a
waiver by either party of any rights to seek the relief of any
court for the purpose of enforcing the provisions of this
Agreement.
22. WAIVER. The waiver of any term, conditions, clause or
LAW O"ICII
SNELBAKIR.
BRENNEMAN
a SPARE
provision of this Agreement shall in no way be deemed or
considered a waiver of any other term, condition, clause or
-11-
. .
provision ot this Agreement.
23. APPLICABLE LAW. This Agreement shall be construed,
interpreted and entorced according to the laws ot the
Commonwealth ot Pennsylvania.
24. HEADINGS. The headings or titles ot ~he numbered
paragraphs ot this Agreement have been used only tor the purpose
ot convenience and shall not be resorted to tor the purposes of
interpretation or construction of the text of this Agreement.
25. EFFECTIVE DATE. This Agreement shall be dated and
become effective on the date when executed by the latter of the
two parties.
IN WITNESS WHEREOF, the parties have hereunto set their
respective hands and seals intending to legally bind themselves
and their respective heirs, personal representatives and assigns.
WITNESSED BY:
-~
~~A'L /J
~u-.///r , ' ,"?,;,- _(SEAL)
Rlchard O. Dayton, Sr.
Date:
) 1 /,i ,
\...f/tfuel(~'-/ I ,d~IIl'?L.(SEAL)
!latrlcia J. .flay ton I
Date: .2/rr j'
LAW O"ICII
SNEL8AKIR.
BRENNEMAN
a SPARE
-12-
,
I
,
.
.
Mr. Brenneman and Mr. Andes, Attorneys at Law
37 March 1998
Paae 2
to discuss the issues and, if necessary, schedule a hearinq.
Very truly yours,
E. Robert Elicker, II
Divorce Master
NOTE: Sanctions for failure to file the pre-trial statements
are set forth in subdivision Cc) and Cd) of Rule 1930.33.
THE ORIGINAL PRE-TRIAL STATEMENT SHOULD BE FILED IN THE
MASTER'S OFFICE AND A COPY SENT DIRECTLY TO OPPOSING
COUNSEL.
SNElBAKER. BRENNEMAN S SPARE
A PIll.O'U~NAL C:ORrmt.AflON
^TTORNEYS AT LAW
44 Wf.~ r MAlN URfET
RICH^RD (" ~NELBAtcfR
KfITH O. 8RlNNlMAN
PHILIP H. ~rAR..E
MECHANICS8URG, PENNSYLVANIA 17055
11/ tiVI "~;JH
P 0 80)( JI8
f^C~IMJlf VI}) 60116HI
May 5, 1998
E. Robert Elicker, II, Esquire
Office of the Divorce Master
9 North Hanover street
Carlisle, PA 17013
Re: Dayton v. Dayton
No. 96-1641 Civil, Cumberland County
In Divorce
Dear Mr. Elicker:
I feel compelled to write in response to Mr. Andes' letter
to you of April 29, 1998.
First, Mr. Andes continues to state that he represents
patricia Dayton, yet he has consistently failed to enter his
appearance in this case. For that reason alone, his request to
further delay the disposition of this case should be refused.
You requested in your letter of March 27, 1998 that Mr. Andes
file an appearance and he has failed to do so.
With respect to Mr. Andes' representation that Mr. Dayton
made a settlement proposal "several months ago", I forwarded to
Mr. Andes a proposed Post-Nuptial Agreement on Mav 29. 1997. It
has been almost a year since he and his client have had that
Agreement. We now find out that his client is vacillating as to
whether or not to accept the proposal. Whatever problems the
parties' adult son is experiencing have no bearing on a proper
and prompt resolution of this case. My client directed me to
move this matter forward as quickly as I can. He is entitled to
a divorce and he is entitled to have the economic issues resolved
promptly.
Fi~ally, my client has repeatedly advised me that Mrs.
Dayton has advised him that she has already signed the Post-
Nuptial Agreement I sent to Mr. Andes in May of 1997.
Mr. Andes was notified to enter his appearance and he chose
not to. He was notified of the time period by which to have a
pre-trial memorandum submitted and he chose not to. My client
SAM UEL L. ANDES
ATTORNEY AT LAW
!\~!\ NURTII TWBLrrlf KTRBBT
P.O, "UX tou
UMU'L L.4NU,.
d. "".T D.WNa
LHMOYNK, PKNNRYL\'ANIA 170-a.:J
TIL.PHON.
l'lr) 1IU'IUfU
.AX
1 "" mi"".."
29 April 1998
E, Robert Elicker, II, Esquire
Office of the Divorce Master
9 North Hanover Street
Carlisle, PA 17013
RE: Richard Dayton vs. Patricia Dayton
96-1 641 Civil Term
Dear Mr, Elicker:
I represent the Defendant in the above matter. I was to have filed a Pre-
Hearing Statement with you on 20 April 1998, but have not yet done so. I write to
advise you of the reason for my delay and request additional time on behalf of'my
client.
The parties have been separated for two years and have been having some
negotiations during that time. Mr, Dayton made a settlement proposal several
months ago which was not acceptable to my client, However, she has given the
matter a great deal of thought and is now vacillating as to whether to accept his
proposal or not. Unfortunately, her decision has been greatly delayed by some
personal problems which have arisen in the family involving their teenage son. As a
result, she has not been able to make any final decision as yet,
If she does not accept her husband's proposal, we will raise a claim for
alimony and other economic relief and file It with the court, At that time I will
prepare my pre-trial statement and file It as quickly as possible,
Because of all of this, I request that you give me an additional thirty days, or
until 20 May 1998, to file the pre-hearing memo in this case, I expect that Mr.
Brenneman will oppose that, because his client wants to keep matters moving
forward, However, I think a little patience now may very well save us a lot of
dispute and hearing time later,
E. Robert Elicker, II, Esquire
2
29 April 1998
Thank you for your attention to this matter.
Sincerely,
S.a.'A'd-;'
Ie
cc: Keith O. Brenneman, Esquire
SNElBAJ<E.R. BRENNEMAN S SPARE
" rROfn"'ONAL l.:llItPOll.AttON
ArTORNEn AT LAW
44 WE'H ~IN 'HRfEr
MECHANICS8URG. PENNSYLVANIA 17055
RICHARD C )NELaA':fM.
KEITH 0 IAENNEMAN
PHll.IP H. ~PAJlE
"1,.tiO.l~'l;!H
POBOX 318
f.",C.!IIMllf (lIt') 60'"681
May 13, 1998
E. Robert Elicker, II, Esquire
Otfice ot the Divorce Master
9 North Hanover street
Carlisle, PA 17013
Re: Dayton v, Dayton
No. 96-1641 civil Term, Cumberland County
Dear Mr. Elicker:
Enclosed please find a copy of the executed Post-Nuptial
Agreement between Richard O. Dayton, Sr. and Patricia J. Dayton.
Please proceed with having your appointment vacated in
consideration of the settlement of all economic claims in the
case.
I thank you tor your assistance.
Yours truly,
K.~nn.man
KOB/sz
CC: Richard o. Dayton, Sr.
Samuel L. Andes, Esquire
~ C") ~
c
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CU:.'t:.' .,;' ;~LY
f-'~;,,;: .:l.l\:','-.r\
.... ..
RICHARD O. DAYTON, SR.,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96-1641 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
NOTIC.
vs.
PATRICIA J. DAYTON,
Defendant
If you wish to deny to deny any of the statements set forth
in this Affidavit, you must file a counter-affidavit within
twenty days after this Affidavit has been served on you or the
statements will be admitted.
AP.IDAVIT UNDER SECTION 3301141
O. THE DIVORCB CODE
1. The parties to this action separated on Februarv 26.
~ 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, lawyer's tees or expenses if I do not
claim them before a divorce is granted.
I verify that the statements made in this Affidavit are
true and correct. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. S4904 relating to
unsworn falsification to authorities.
LAW O""ICa:S
SNE"LB,A,KER.
6REN"",EMAN
a SPARE
/1 tic. ~ . g
" /).
.~ ~ L/A.. ~ . ~
~c ard 0.. yton, Sr.
Plaintiff
Date: f>1Mot I~, I'/"t.
-- .
CERTIFICAT~ OF SERVICE
I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have,
n the below date, caused a true and correct copy of the
oregoing Notice and Affidavit to be served upon the person and
n the manner indicated below:
FIRST CLASS MAIL. POSTAGE PREPAID. ADDRESSED AS FOLLOWS:
Samuel L. Andes, Esquire
525 N. 12th Street
P. 0, BOlC 168
Lemoyne, PA 17043
1~1~u,.t'<'<--
Keith O. Brenneman, Esquire
SNELBAKER, BRENNEMAN & SPARE, P. C.
44 West Main Street
P. o. Box 318
Mechanicsburg, PA 17055
(717) 697-8528
Attorneys for Plaintiff
Richard O. Dayton, Sr.
Date: March 17, 1998
LAW O,..,.ICla
SNELBAKER.
BRENNEMAN
& SPARE
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SNELBAKER. BRENNEMAN a SPARE
" 1'l'h_l""'IL1NAl l~llU'UkA'lllN
AITORNEn AT LAW
44 Wf'T MAIN !lofRHr
MECHANICSBURG, PENNSYLVANIA 17055
IlICH^ItD c ~NHIl^I(EFl
KflfH 0 a'UNNf~N
PHILIP U \PA'U
Il/flUI "',.~11
r 0 BOX JUt
r ^( 'iIMI!F. tltll fiD/-/ra",
April 27, 1998
E. Robert Elicker, II, Esquire
Ottice ot the Divorce Master
9 North Hanover street
Carlisle, PA 17013
Re: Dayton v. Dayton
No. 96-1641 Civil, Cumberland County
In Divorce
Dear Mr. Elicker:
As a supplement to the Pretrial statement submitted to you
on April 20, 1998 in the above matter, I am enclosing a copy of
Richard o. Dayton, Sr.'s Income and Expense statement.
I<OB/sz
Enclosure
CC: Richard o. Dayton, Sr. (w/enclosure)
Q/7J14.
INCOME AND EXPENSE STATEMENT OF
~/<.I-I r-H!i) C" f)/ly/"ZJ,.} ~I!.
SSN ,yJ . ~ " . ~i/19 DRN DATE t;.22-91
THIS STATEMENT MUST BE FILLED OUT
(It you are self.employed or if you are salaried by a business of which you are owner In whole or in part. you must
also fill oul the Supplemental Income Slatement which appears on the last page of this Income and Expense
Statement.)
INCOME
f..c. /1 l' <. ,j.C;-z;'
(I A- (It p Hi { l. /1:J .
,
I Ie II
lal Wages/Salary _ ,
. Employer & Address i:>~tll'. C~ Clc,(2fr;(/lot-'(
Job TIllS/Description _ (1 (l ~I 111L.
Pay Penod (WeekIY(bl.weekJY) monthly)
Gross Pay per Pay Penod .................................................................................................................... 5
Payroll Deductions:
Federal Withholding ..................$
Social Security ...........................$
Local Wage Tax ..........................$
Slate Income Tax .......................$
Retirement ..................................$
Health Insurance ........................$
Olher (specily) ............................$
See 5l.:5LL!2.u.....r..o..IC......$ '? 'r z;;
L~ N lOA) ~.~&,L...........$ .a<;,-. ,~
Net Pay per Pay Period ........................................................................................................................ $ /} I!,J
Joc::'.bl
/ I' L. . .~ 'i
;~ . 1(,
~ .-^
Lj ( I o~
'7..".Y'c.
37
(bl Other Income Week
Interest/Oividends ......................5
Pension/Annuity ,........................5
Social Security ...........................5
Rents/Royalties ..........................5
Expense Account .......................$
Gifts ................,............................$
Unemployment Compensation .5
Workmen's Compensation ........$
Total. Other Income .......................$
Month Year
$ S
S $
S S
$ $
S $
$ $
S $
S $
S S
INCOME .NO EXPENSE STATEMENT OF
I verify Inat tne 5talc'renls macJe ItllnlS Income and EaDense Slale,
menl are true anc corrp.\:: r un13erSlanc lMat t31se statemenlS nereln
are maue '51.:~leCI 10 f"t- ~enallles 01 . 8 Pa.C.S. 4904 f81allng to
ul"sworn '3lslllca'lcn I' ~utnOrllle5 -~, h :..: /.;/ t .'
"I . ,- :-.,. j ( '< I
Oa:e ,. .2',2 >-/ _~t"-:' -' L:t','1 -\,. ~,
---. .---- ~Ialntlll cr Oilfencanl ~
Household Child Household Child
Week Week Month Month
EXPENSES
Home
Mortgage/Rent $ $ $ 7'(0 ,1,) $
........................................
Maintenance ........................................... $ $ $ ~O. ,,,. $
Utilities (telephone, heating
electric. etc.) ........................................ $ S $ ,510, N $
Employment (transportation.
lunches) ............................................... $ S $ If) , l~ $
Taxee
Real Estate ,............................................. $ S $ $
Personal Property................................... $ $ $ ?e>. b'V $
Income ..................................................... $ S $ $
Insurance
Homeowners ........................................... $ $ $ $
Automobile .............................................. $ S $ ~-().c,;.' $
Life/Accident/Health .............................. $ S $ / c , cc $
Other ........................................................ $ $ $ $-
Automobile (payments. luel.
repairs) ................................................. $ $ $ j{l(), tt.:' $
Medical
Doctor. Dentist. Orthodontist ................ $ $ $ 'Ie. C;C $
Hospital ................................................... $ $ $ $
Special (glasses, braces. etc.) ............... $ $ $ $
Education
Private. Parochial School....................... $ $ $ $
College..................................................... $ $ $ iji (; e" $
Personal
Clothing ................................................... S $ $ ~~-.a, S
Food ......................................................... $ $ $ lIce ,,'C S
Other (household supplies,
barber, etc.) .......................................... $ $ $ ..,--C. ','=,. $
Credit payments and loans .................... S $ S ~ .,', ,'..., $
Miscellaneous
Household help/child care .........,........... S S $ S
Entertainment (Inc. papers.
bOOks. vacation. pay TV. etc.) ............ S S $ 1L'c' c:: S
Gilts/Charitable contributions '............. S S S It . ~ , S
It
Legal Fees ............................................... $ S S '>c ,c: S
Other child Support/alimony ~
payments .....,... ....,................,........ ...... S S $ L"(C. i.'~' S
Other (specily) ............................................... S S S $
Total Expenses ............................................. S S $ S
.
Ownlllhlp.
H W J
PROPERTY OWNED
Checking Accounts ........
D..crtptlon
Value
....................
$
$
$
$_
$
$
S
S
S l.lNJ.( NOWrJ =
$
l-
S
S
--
Savings Accounts ...........
--
--
Credit Union ....,...............
--
--
Slocks/Bonds ..................
--
--
..................
Real Estate ......................
......................
Other ................................
--
................................
Total, Property.....................
--
INSURANCE
Coverave.
H W
- --
--
C
Complny
(I ,(!OS':;
SI-I,I!t../)
Polley No.
~fl,blc;J.H.NI.;
l?P I) 1'1 ~ ~(, 1<1/9
Hospital...........................
Medical............................
tJ.Lu.c
fit u <:
-
-
--
HealthlAccldent ..............
Olsablllly Income ............
Olher (dental, etc.) .......... i\ G l- r 1+ 1'><."' /1, -;-,U..
(OH . Husband, W . Wile, J . Joint, 0 . Child)
3c',,- - CC;J.':;
-
--
SUPPLEMENTAL INCOME STATEMENT
A, this form must be filled out by a person who (check one):
- (1) operates a business or practices a profession; or
- (2) Is a member of a partnership or joint venture; or
- (3) Is a shareholder In and Is salaried by a closed corporation or similar entity.
B. Attach to this statement a copy of the following documents relating to the business, profession. partnership
joint venture, corporation or similar entity.
(1) the most recent Federsllncoms Tax Return, and
(2) the most recent Profit and Loss Statement.
C, Name and Address of business:
Telephone Number
0, Name and Address (If dlllerent than OJ 01 accountant. controller or other person In charge of IInancla
records:
E. (llAnnuallncome from business ............................................................................................. S
(2) How alien Is income received? .....................................,...................................................... S
(3) Gross Income per pay period ............................................................................................... S
(4) Net Income per pay period ................................................................................................... S
(5) Specillc deductions II any ,..............,............,....................................................................... S
LAW O"I"IC:'"
SNELDAKER.
BRENNEMAN
6: SPARE
III. Id.ntlfloatlon of .itn..... and T..tlaony.
Plaintift identifies the following witnesses he may utilize
at time of trial in the above case:
a. Karen Darney (address above). Testimony will
concern tair market value ot the marital residence.
b. Harry M. Leister (address above). Testimony will
concern value of Plaintiff's State Employes' Retirement
System retirement account.
c. Individual who appraises personalty (identity and
address presently unknown). Testimony will concern value
of marital personal property.
Plaintift reserves the right to identify and call
additional witnesses at time of trial, pending completion of
expert reports and valuations. This shall be done by
supplementary pretrial statement.
IV. Id.ntlfloatlon of Bxbi~lt..
Plaintiff identifies the following documents he may utilize
at time of trial:
a. Personal tax return for Plaintitf tor 1997, with
all relevant schedules and attachments;
b. Pay stubs noting period pay and deductions
relating to compensation from employment.
c. Deposit slips noting payments made to Detendant
since separation.
d. Reports/valuations ot all experts identitied and
to be identified as well as any and all financial and other
documentation utilized to formulate such expert opinio~.
Plaintiff reserves the right to supplement this pretrial
-2-
statement pending completion of expert reports.
V. Gro.. Inoo.. and D.duation..
Plaintiff's gross income and all deductions theretrom,
Plaintitt's net pay and most recent pay stubs are attached
hereto in a group ot documents identified and incorporated by
reterence herein as "Exhibit B". Plaintift's most recent
foderal income tax return is attached hereto and incorporated by
reference herein as "Exhibit C".
VI. Exp.n....
Plaintiff's current expenses will be set forth in an income
and expense statement form which will be provided in supplement
to this Pretrial statement.
VIII. p.n.ion/R.tire..nt B.n.fit..
Plaintiff has a retirement account with the state Employes'
Retirement System ("SERS") by virtue of his employment with the
Commonwealth of Pennsylvania. The value ot that account will be
determined by an expert (See II, above). Documentation upon
which a value will be based will include, inter aliA, annual
statement a of account issued by SERS. Facts upon which
Plaintiff will rely for the valuation will be contained in the
report to be prepared and the annual statements.
LAW O.....CE.
SNELBAKER.
BRENNEMAN
8: SPARE
Defendant has a pension benefit from her employment, the
value of which is unknown by Plaintiff.
-3-
COI\I\ONWEALTH OF PA - EIIPLOYE STATEIIENT .;. .u, ,.. .... ... no .... .. ....
Gillon URIII NCS 1,1.6.00 ......00
'AY 'IIIOD INOIMG: OJ-01-" "'t DAn: Ol.lO-" MINUS DEDUCTIONS
YI,: "IIOIAOOOOO DIJI, 011 CDC: J"'O FlD NT" U S DO Jot." 1.216.4.
soe 51C ,. '.lD0D0'4 106.lt .u.,.
"." 01'0'11 PO$l: 012"1 SU: .'J-)6-141' IDC SIC, MID IX 1..~ ,.... tf."
I'U: HI PAY RA.aI: ,. SUP: l LlYEL: JO SUU NTH TX .. l. ._ 'I.O'! Itl.20
COIIIClIOIIS ICI C_ MILL LOCMG !l-IIS ,& n fl4 1.- 11.1' .....
au P/U COM UAn iMP ,.- "..0 lU.20
UM DUn AFlCMI - 13 ,.., lS.l4 10l."
RICHARD 0 OA'TON
11' W. MAIN STREET
SHIREMANSTOWN PA 1101 t
NIT IARNIIIGS. 1.101,17
SIAII 'AID .ENf'lll 'LUS REIMIURSfMINIS
MIALlM IlNHITS CA'IIAL .LUE ClOSS
L I FE 1NSl.tillC E
_oEU CDMI'
SOCIAL SlCUllIIY
MCDIC.AC
IITIIIMIII SIAIE EMPLOYES AEI SYS
I... . ..... ..... r.."~.. .' ro.. ..' ".
"10 LIIVE SIIIEMEII fOTAl CHECK AMOUNT . 1.101.31
SIIVICE CREDIT: lS 'A , "
"fNO LflYf USIGf AEJORIED HAUlS "ENO .RfAKDONR GROIS flRI MClUIIS IIn GROSS
02-07-" IIG UL 10.DO 21." l,ll'.DO
lOllL GlOSS flRNIIGS THIS 'IY S 1.716.00
LUVI AClIVII' ~IINfD Slot PEISOIfAL SfllORITY II'DIMIIIOI
IILINCE LASI SIAIIMflT no. 12 '12.n
acCRUAL IMIS " 10.11 l."
LV Ai'OIIID TnlS F' .DO .DC Y!O .'"
IDJUSIMEIIS .DO .00
IALAOCE IHIS SIMT 301.SO .n."
ICtIIIIL IIn: IJUIUAL 13.' SlOt J.on
"USAGE UNTil: LOCAL MAGE IAI COUNTY/MUNICIPALITY: CUMBERLAND COUIITV SHIR(MAHSJOKN laRa
COMVEISIOM 'IV LIAIILII.: 10..10 FMI fAX GROSS: I.UO.lO
A "Healthy" Sick Leave Balance is Like Money in the Bank. . .
It Makes "Cents" to Save Sick Leave!
EXHIBIT B
COIIIIONWEALTH OF PA - EIIPLOYE S TA TEIIENT ..... 'N" DO' no .... ,. n."
GROSS UflNINliS 1.IIA.OO 1."0.00
PAY PIRIOD IOOING: oa-al'" PA't OATf: Ql~Q'~" MINU~ OEDUCTIONS
yr.: "1101'.0000 DIP! : 011 COCo Juao FED NTH n S 00 10.." 1.!3J.0!
sac SlC u A ,1??oo", IDA.J' 'll.'!
I"": 0,.0" P05l: OJa., I S5N: 1'1-]'-]41' SOC SEe/MfD T. 1.dOOO\ l~.U U.. .0
I'U: HI PAY RANGE: U 51(P: K lIYU: 4'0 SUT( NTH U PA 2.100c)()"". ".OJ a.o.u
CORRlCIIONS sel CAMP Hill LOC WG JX-RU 'A 11 924 1.00000"4 11.a 15.10
In P/U COM SUfi (MP ,. ??oo0\ ".10 .a..oo
UN DUll Of SCMI - \J a.., 25.14 UI./O
RICHARD 0 DAyTON
111 w. MAIN STREET
SHIREMANSTDWN PA 1701 t
Nil EARNINGS: 1.101.31
,IAIE PAID IENE'IIS PLUS RIIMlUISIMINIS
MEALlH IINHITS CAPIIAL ILUE CROSS
LIFE IN,""AIICI
_us COHP
sac UL S1CUII IIY
H(OiCl\iIi
IIIIIIMINI SIAIE IMPLOYIS III SYS
... . "... ".Y' CONTlNU' " 'Ull ..'u..
PAID LEAYE srA,IMINI TOTAL CHiCK AMOUNT , 1,101.J1
SUYICE ClEOIl: U YR I"
" END LIAYE USAGE RIPORIEO MClUIlS "ENO IIEAlDOHN GlOSS EAIN MOUIS IAIE GIIOSS
oa-21-'1 COHIINIO LIAYE PRESCHIDUlEO 1.00 01-21-'1 REG lAL 10.00 21..' 1,716.00
lOIAL GlOSS EAINIIIClS TltIS PAY S 1.116.00
LEAVE ACTlYIlY C_INID UCIC PlIlONAL SINIOIITY INFORMAl ION
IAUNCE un STAlEMENI JOl.'O '14.'.
ACClIUAL IMIS " 10.11 1."
LV ""ORTlD TNn pp l.w~ .(10 VlO .00
AOJUS IMINIS .00 .00
'ALAMeI IMIS SIHI 111.21 tJ7.A!
ACCIlU.\L IATI. A1111UAL n.." SIClC 3._
MIlSAGE CENI II: LOCAL MAGE TAX COUNTY/MUNICIPALITV: CUMBERLAND COUNTY SHIRfMAMsrONN lORD
CONYEISION PAY LIAIILIIY; 101.10 F.., TAl GROSS: I.uo.ao
POLITICAL ACTIVITY GUIDELINES
[mplo~es in ti.il service positions are subject 10 Ihe pro,'i.ion, 01 Ihe Ci,i1 Servke Act 01 19~1.IP.L 75~. No. ~86) as
amended. [mployushould rder to the C;,i1 S"',ite Cummission', ~Polilital Atti,ity Guidelines lor Chil Servin
[mplo~es" pamphlelwhith was issued wilh earninRs slalemenl' in Otlober. 1997. The pamphlet also i. available
Irom eath agent~' penonnel ornce. Queslions re2arding the prohibitions 01 Ihe Federal HaIth .-\tl. whICh is
applkablelo .mplo~es ..hose ,alaries are Federall~ On anted. ,hould be relerred 10 your agenq personnel omte.
."ny' questions regarding polilkal atti\il~ prohibiliuns should bt addresstd 10 the Oi\ i.ion 01 In\e.ligalions and
Inlormatlon Senites, Bureau 01 Audit and Teehnital Se....ites. Slale Ci,il Senice CommlS.ion. 3'. Floor. Slrawberry
Square Cumpln. 310 Market Street. P.O. Bo\ ~69. lIarrisburg. P'\ 17108.0569; or tall ('PI '87-~516.
COMONWEAL TH OF PA - EMPLOYE STATEMENT -., , ,." ... "' I.... Ta .....
Glon lA..IIIGS 1./1'.00 10.296.00
'AY '1'100 INOING: OJ-07-" PAY OAII: 03-10-.. MINUS OlouellOlll
YT.. 7'110171OODO 01": 011 CDC, JU10 FED NT" ,. I 00 J06.6I I.'''.''
IOC IIC " '.1_ I~.H U'.l'
IIIP.. 071M. '011: Olllf I II.: 1'3-Jl-3'1' SOC $IC/MEO n I."""'" 1.... 'St.lI
I/Ut HI PAY .....1. JI III': . LEVIL: 10 SfAn IIlTH r.c PA 1.1_ ".011 JII.JO
COUICTlOlII lei C_ HILL Lac HG '1-IlS PA 11 '1. 1.- 17.11 102."
oce PlIY fI 11 .u 10.00 10.00
IIET P/U COli lUll IIIP ~.- 1f.'0 "'.10
WI DUES A""'I - U Htf U.7S I.....
AleH'AO 0 aAVTON
'" W. "AIN STAEET
SHIAE"ANSTOWN P, 1701 I
'IT IA..INGI: 1.0tl.37
STAT' 'AID 'I.I'IIS PLUI AIIMIU.IIMEMTI
MlAlTM 111111 TS CA'ITAL 'LUI C'Oll
1I11 IlIuaA1C1
-US C_
SOCIAL S1CU1ITY
MIDICAI'
'ITUIMlIf ITATI IIIPLOYII .11 IVI
.11 ,..un ..... 'T lID' v.""
'AID LIAYI ITATIMI.T lOUL CHICK _T 1,otl.31
SlIVICI C.IDIT' l' .. .IP
".11I LUYf USAGE .IPOITm HOUII "INO '.IAKDONN GIOIS IA" HOUII UII GIIOIS
03-01_ CDMlI.ID LIAYI '.ISCMlOUlIO '.00 03-07-" UG SAL '0.00 n." 1,711.00
TOTAL GlOSS U..INGS TIllS PAY S 1,111.00
lIAn ACTIVITY COIlII.ID SICK ""DlAL II.IOIITY I"OIMA'IO'
1Al1NC. LAST IIATIMI,T 311.1' 937."
ACC_ TMn " 10.7' 1."
LY .IPOITID THII " '.00 .00 YTD .00
AIlJUSTNIITS ,00 .00
'ALINCI THIS STNT 3U.~ 'H.tI
ACCIUAL IATI: - 12.'" SlClC J.on
MlnAGI ClNTU. LOCAL MAGI TAl COUNTV/MUNICI'ALITY: tUNIIALAND COUNTY SHIRlMAlfsrONN 'OlIO
CONVI.IION 'AY LI'IILITY: 101.10 FMT T.U GROSS: l,UO.lO
-----------------------.--- CUT HEAE IF RECEIPT REQUIRED ----------------------
COMMONWEALTH 0' PENNSYLVANIA OCCUPATIONAL PRIVILEGE TAX
EMPLOYE NAIIE. ADDRESS CERTI'ICATE 0' DEDUCTIUN TAX COLLECTOR NAIIE, ADDRESS
. 0 DAYTO' GREATER Nlsr SHORE WAGE TA. .
LII M. "I. IT.IIT 10.1 .,.
SHI.I".IIOMN 'A 17011 CAMP HIll Pi 17011
SOCIAL SECURITY NUMIER: lU-,U-;J4l'
DATE 0' DEDUCTION: OPT DEDUCTION AMOUNT: MUNICIPALITY CODE: lUll
03-10-" 10.00 lONER AlUN fNfl
'u.
,
COMONWEALTfI OF PA - EMPLOYE SUTEMENT .u,. ... 'ft ....
GIOU U'IINGS 1.11'.00 II.OU.OO
'AY '1'100 lIOING, OJ-lI-" PAY DAn: O.-OJ-" llOUS olDUCTIONS
YT', "1101&1000O OIIlTI 011 COCo J"~O FfO MTH fl I 00 JCM.II ~.I...n
SOC IIC 10 I.~- 106." 1...11
IMP', o"on POI,: OJ~" I 5SN: l'J-J6-)4I' SOC SlC/llo 10 1.'- H." 116.11
IIUI HI PAY UNGI: l6 IJI': . llyn: 20 Sr.,E WIM U 'A ~ .- ".Of Jl6.H
COIIICT 100S lei C.... HILL LOC lOG 10-111 ,. Jl U. 1.- 11.11 UO.II
All , IU COI lUll IMP ,.- ".10 100.10
UlIllUll AlleMl - !J z.t5 25." 110.1'
RICHARD 0 DIY TON
III \I. MA IN STREET
SHIREMANSTO\lN PA .7011
III UIIIIlGI: 1.101.11
ITATI 'liD 1111'111 'LUS '1IMluaIIIIITS
HULTH IUIIITS CA'IIAL ILUI C'OSS
Llfl IIWlIIICI
_lIS C_
IOCIAL lICUIUlY
1I0lCAII
'1fI.IMUT STIli IMPLOYIS AIT SYI
I." . unn ...u. C""1ll1 U 'ULL v,. ".
'liD LIIVI STITINE.T IOTAl CHICK AHlIlIIIT 1.101.31
SI.VICI ClIolI, 25 Y' 10 "
"111I LlAVE UUGI IlPOITm _S "111I 111_ GIIlISS W' _5 IAn _5
0:1-11-91 .IG ilL 10.00 1l.6t 1,111.00
IOTAl _5 lAIl1I1GS THIS PlY , 1,111.00
uln ACTIVITY CIlIIlIIIID SICK 'I'SOIIAL SI.IOITTy I"OIMATIOI
IALIleI LAST STITIMIII 1!J.llA n..OI
ACCIUAI. IHIS " 10.1' ~...
LV 'iPOlJlD THIS" .00 .00 YTO .00
IllJUSIHUTS .00 .00
IALIleI THIS IIMT 321." '62.31
- 1AII, AllIIJAI. 13.6 ~ nac I.on
MlllAGI CUTU I LOCAL MAGE TAX COUNTY/MUNICIPALITY I CUMIIILIMO CDUlIY lNl.EIAISTOHI 101O
COIYI.SIO. 'AY LIIIILIIY: 701.10 f.1 IIX GlOSS I 1.'.1O.~O
.
o
.
11
Filing Status
ChICk only
an. boll.
Exemptions
rf more than sax
doIl"'-".
_ll8g.'O,
d
Income 7
..
Altach b
Copy 8 of your I
,""". W.2, 10
W.2G, _
I_A here, 11
~ you did not 12
get a W.2. 13
_ page 12. 14
lSa
Ie.
Enclose but do 17
no. atlach any ,.
payment. Also.
please use 11
"'"" I_V. -
21
Adlusted
Gross
Income
If line 32 IS under
$29,290 lundOl
19.170 ,I a chdd
did not !lvI wllh
YOUI. s.. EIC I"Sf.
an o.g. 21.
~.. of the f..- p ."'~ A...... ~ <1iO\97
U.S. Indlvlduallncome Tax Return iIA U@
IRSIJU o,.~lel:"" "'""<71 'It..", IP\tI~.
SIngle
1.1_ ftllnQ jOint ''''''' (..... W only one /llId incom.1
""""1IIng __.-. Ellle/_'. _ IeCUII1y no. _Ifld I\A __ .
Heed O'~("'"'~ _I. (Seell8ll.10,) ~1I1.quallfylng _..acno/d but nol'fO'Jldependenl.
Infer tnia child'.. name her.. ...
QuoJ n WIdowI_' "'"" d t Ch"d .eI. died. 19 . See . 10.
YouneIf. I' your paren. (or IOmIOf'te atM. can ctaam you as . dependent on hiS ar her tax }
'alum, cia hot c/lICk box 6&. . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . .
III~. II . ,II _
SOCIIISlCWlfynumw r~1O _II""
I
-
I
10
11
12
13
14
lllb
Illb
17
,.
11
20ls
J ...., ...
~
.
.
.
~
M
.
R
.
22 Add the amO\,ll'lt11n the 'ar" ht column for lines 1 throu 21 Thlls IS our totallncorne .
23 IRA deductIon 1_ page 161. . . . . . . .
24 Medical ..."n9' acc""". deducbon. Attach Form 8853
as Mew,ng ..pen.... Attach Form 3903 01 3903.F ,
:ze One-half 01 .elf.emoloymen. lax, Attach Schedul. SE
27 Son.employed h.alth ",SUlanco deduction IS.. pag. 11)
28 Keogh and ,,,'.employed SEP and SIMPLE olan.
n Penalty on .any wllt'tdrawal or savIngs
3011 Alimony pMd ~ Rec:I~llIlt's SSN ..
31 Add IIn.. 23 Ihrough 30. ,
32 Subtract line 31 'rom liMe 22. Th'5 15 ou, ad u.ted ra"lncom.
'or Pn..c:y Act _ Po_ork AeduD1lon Act Notlc.. He p.g. 38.
For IN.,.., JM1. 1-0.:. 31. . 1911. ...of'lq
taU!' fi,s. n.",. M'd >1111111
;, Ie Jr, ~ ~
t, '10ffl1 r.'unt, ~..', hrsI ~ ""'" II\lbai
Mome .MkI,... (nurnlW MICS SfrMQ. I' you ".. . P O. DO.I. Me De9tI 10. Act no.
III IY/. ,. f'
'0 II1Is fund? .
I
..
b
o Olpnldenla:
IIIR"'......
UII......
TOlat number ot ..em tiQf\S clamed
Wag... salan... tip.. .Ic. Al1ac/l Form(.) W-2 .
T_ in.lIIOOl. AllacII Schedul. B if leqUlred
T............ mtlllOOl. 00 "'OT ,nclud. on lin. S. .
DMdenda. Attach Schedul. B ",eqUited . . . . . . .
T_. reMda. CledU.. 01 olfuts 01 .t.t. and local ",com. ..... 1_ page 12)
AlimonYllCOl\/ed . . . . . . . . . . .
IlualIItlIII incom. 01110Sll1. Attach Schedula C 01 C.ez
CapotaJ gelI1 or 110SlI~ AllacII SchedUI. 0 .
01l1et g_ 01110....). AttacI1 Form 4797. . . . . . . . . . . . . .
Total IRA dlainbubons . ~I LJ b T_a amount I'" paga 13)
TollII_ "'" __ i..!!!J L.J b Taxable amount I... ~ago 13)
Aental real ..tal.. loyalti... p_...",ps. S corporation.. truats. etc. Attach Schedul. e
Farm 1I1COIn. 01 II..a). Attacn 3cnedul. F . . . . . . . . . .
Unemployment compensabon . . . . . . . . . . .
SocIal SlCUII1y benefits . 120. I I b Taublt amount I'" page 14)
Dlhtl ",com., W'llypa and amount-s.. page 15....................................
i Sb I
.........................................................................................
23
24
21
21
27
28
21l
JOe I
.
C.1. No. 140870
EXIIIBi'l' C
. 19 OM8 No. 15118-0014
v____
,q.".Y_; ~4f19
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,0<,....,1n......... ...
inelruotIoM, _ .....
2_31n...--,
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''''''' 1040 1'18"
'orm IIUG 11.7'1
Tax
Compu-
tation
If you ....,1
tf'IelASIQ
tiqurl y04Jl
la. ,..
_'8,
Credits
Other
Taxe.
Payments
Anach
Forms W.2.
'N-2G. iIIId
I099-R on
rnllronl.
Refund
HIVe 'I
-Ily It
_'ldl ·
500 _ 21
and IIU In 62b.. d
82c. ond 82d. 83
Amount ..
You Owe
Sign
Here
Keeo II CODy
o'In.,r"Utn
for your
r6.:lltds.
Paid
Preparer's
Use Only
J:I
3>ta
Amount from lme J2 (adluated gt'OU *"Com.. ., . . . . . . . .
Checl& ot 0 v... __ 65 01 __, 0 SIlnd: 0 ........ ... 85 01 _. 0 Blind.
Add !he numD. af bolln d\eCk1ld ~. and em. tnllotal .,.., .. lilt *
.... a
t:y .
III I' you .... mamtd filing HQaraI*y It'd 'fOJI SDOUU Item'la dMiudtane 01
yo. __ . dUill-sta.... _. _ p_ '81lld cnocll "UI . . . _ CJ
1- ...... ~-.. Ifom ScnIduIe A. h". 28. 011 )
Entll I&andanf tMdualtaft snown bItOw for yOUl filing status. ....
the ptIIge 18 If you ch<<Ked ~ Do. on lin8 34a 01 ~ or aam.....
.... .... clam you .. . _....
~ I ~S4. 1~ I lolamedlllinQ...,.uy 01 0ueltIytng WIdow(err-M.!lOO
. Hud 01 ~,O~ . lolarnodllllng _0tt--$3.450
SuIlIrK'h""351tom',,,.J3 , . . . . . . . . . . . . . . . . . .
IIIlno J3 oS SBO.!lOO 01 IMI. mulllply 12.650 by "'" 'OlalnumllOl 01 .....p.- clltimld on
lonolld, n Iino J3 oS ..., S80.9OO, _ "'" ..- on _ 19 '01 "'" 1IIIOUl1l10 ontlt .
T_ _ Sulltrac.1Ino 311rom '''''' 36. W line 31 is mOIl ",..Iino 36. ontot .0-
T... 500 19 C/Iock ~ ... Itom I 0 Form,s 8814 It 0 F.,m 4912 . ,.
Ctodol ,., C/lid and ~idInl.... -. AIloc/I F",," 2441 40
CtOdlIIOl "'" oIdorty 01 "'" _Id. _ _ R . .,
~CIIdil.A1IocIlFonn8838.. ...... 41
FOIe>gn ... a_. _ F",," 1111 ...... 43
0thII. Chock 01 Itom . 0 F",," 3800 It 0 Fonn II39lI
00 Form 8801 d 0 Form ISjlOCltf)
Add_40lfwouc1I44 . . . . . . . . . . .
Subtract line 4S from line 39. " line 4S is more thM 11M 39, en'. -0- .
"".omploym..' ,ax. Anach ScJlodul. se. , , . . . . . .
AltematNe minmum I... Attad'l Fann 6251 . . . . . . . .
Soc&aI """"'Y iIIId -.... on Up.- no.1OpOIt1d 10 1IIll'iOYW. _ Fonn 4131
Till on qUIM'" rll......1 p,.... ~nc:Jud1ng 1RAa) and IolSAo. AttacIl Fonn 53290' roqUl'Od
Advancl __ _I aodrt paym_1rom FonnlO) W.2 .
Hou_ Wllplclyt.lonl ...... AItOCI1 ScIloduIe H. . .
Add linea 46 52. Thia os _ ... . . , . .
F_ ;ncom. Iu WI'- from F..... Wo2 ..., Il1l1ll. .
1991111lrN11d ... -,sn ........ oppIIad """' 1_""" .
_ __..- A_ 5cl1odolII EIC ~ you"",". quIiIjlng
_.____.1 I I
and Iypo . .................................................. !IlIII
Amount poid WIth Form 4868 (_, let "'_1. .. 57
Eac... _ oocurIIy ..., RATA Iu _ (aoo p_ 21) !III
OtlllllllymontS. C110Ck ~ """' . 0,."" 2439 It 0 Form 4138 !III
Add Ilnos 54, 55. 560. 57, 58. and 59, ",.. .....- , . . . ..
W IIno 60 i. m...lhan IIno 53. subtrocllino 531rom line 60. Thia os "'" Illl..... yo. OVUlPAlD
Amoun'01 lin. 81 y<IU ..... R!PUNDED TO YOU. . . . . . . . . . . ..
Routong numblt crrrr::o:::r::o . co Tvp.: 0 ChocJong 0 Sa\I1ngo
36
+1 ~Q -
.. .., ~~~ .
311
37
.
-
311
311
40
.,
41
43
44
<!:i
-
44
-0-
..
..
.7
..
..
60
51
sa
83
54
.
!IlIII
.
-
,:...
.
-
'"
S1
!III
H
80
.,
-
,
';f
-
AccOU1t numblt
Amounl " lin. 11 DU _ Al'I'lIfD TO TOUR I. lST1MAnD TAl . 83
II line 53 .. more ",."Iine 60. subtrac.l;.,. 60 ~om "'" 53. This ..thl AMOUNT YOU OWL
FOI details on how 10 pay, s.. page 27. . . . . . . . . . . . . . ..
II ESllmaled tax penalty. Also IfW:lude on line 64. . . .. 15
UN.,. oenMbn of~. I cMCllla ttlatl ~.....~ U\I.I tttl/.m iIf'Id Kcampanytnq sc:htdUIeI M'ld stalements. Ind to _ DIll 01 ""............
De6Ief. trIey ....tru.. carrCI." complete. ~ o. ~\OItI.ltI...ta.p.r,er1IID1Md on IlIIlIIfDrmaDon 01 Wf'ICI'I~....,b.. .
~V.: ~"m(
, 'ipQuse-, "Ql"l.IW'~_ It .. 101/\1 r. ,
0...
VOUI oct
on
j-"r: 97
O.at.
. IAJT""e
SQOYH" occupatIon
p.wo.,-III' , ~ .j /.
S1q1lall,;,,' r.",1 b./
F.rm '$ r1~ le',eur" ~
"Wlf-ofIT"C10'tttdl.1f';C:
addrltn
0<11e
I - ':'1- /~
C"<<_ ,f
s.el1'~OIOV<<J Kl
..
,.
<'1.
-.
ZlP ~Od'
c_.../....... ~( ,'. __~(.;r:
, 10- ...
~l1i):I~..~~..,Qft..."c..,......,
"j 5 G.:...,.~....I P.......1Q!f.c. ,,., - 4'.5068
$UMMARf OF EMPLOyE PAYAO~L OEOUCTIONS
FOR CA~ENOAA Y!AA 19q7
Your ,:layrOII r-.cord for tn. calend4r I..r 1991
snows tl'lat you had tne fOl10\lll"g deduCt'on~ froom
your gross ,:lay. The amounts '!'lawn are a year-to-Qat.
total 'or ..en deduct ton type listed.
DeDUCTION
TYpe
FED WTH TX
SOC SEC/IIEO rx
LOC wG r..oes
Rn P/U CON
INSTIIUCTIONS (C"",, "u.d , ""m back
", C""Y 8)
lo. 1. ... l"le' ''',t amount on tl'le ",a,.. "",
~f 'OUI ta. ,.IUI".
10. J. .. Int.' trill amoun, Oft tM 'ed.ral
..".... ,.. wlt"".lf Ion. af .,our ta. .etu'n.
10. .. - Int., Ii'll" MlOWU on tn. ad',.,.c.
,.,Md Inca,", c'ed,t ...,m,n,. J,,,. af "OUl'
la. "IUln.
to. 10. ... TI'l., amount ., 1-' 10tal "...ndenl
c.... ".n"ll.. 'tour .1ftD10...., hi. 10 YOU or
,ne",,," an 'Ololr D,nalf ""ClulI.n, amOlolnl1
.,0Ift a "chon IlS D'.nI. _"" *"aun. aver
UOOO ,110 .s. "'lClucMd In DO. ,. 'I'au "",,,t
(0nt011" SCI'lI"UI, 1 IFo,", 1040AI or 'o.m
a"1 to com""1 .n, la_aDII ..... nCNu..eola
tnlOu'Ut
Ia. 11. - T"" .mount " a dl'UU.ll,Illon mU'
10 ,ou fram . nOftQ~hf.,o d.t..-r.d
comMn'.lion or t'Ct,CHI "57 D'*' 4tftd .,
."C...... 1ft bO_ ,. 0, ,t mol" D. a Con'"OI.lI.O"
I)'" 'aUI' emttla.,., tlJ a f1onctUa"'..d .ele",.
Compen'''IQfI PIII'I Ifta' .t ,"CIWO." ." 00. ]
.,.010' 5.
YEAQ-TO~O'TE
AMOUNT
6.191. 11
635,40
436,29
2.179.27
oeOUCT/ON
r,pe
SOC SEC r.
SUTE WrH r.
OCC POlv n
UN DUeS
10.. U. ... Thl' amouftt .. Ih. ....1114 f""",,
0'""'1'1 '''c'l,Id"o ." box 1 'fay mol... tte iIOl.
to d,OI,lCI '''M"'et U"" .... ,.I".d '0 h.n,.
b.nlhll. ,.. tne ."ttruct.ont for 101,1' ...
'e"If".
10.1 1). ... Tl'lo fOllow.n, 11'1 ..Ola.", II'l' e04..
"Iown ," 00. 1 J. You may "..ct Ut.,
''''a,'''.ho" 10 comOI", .,0W' ... IIlurn.
t ... Ilac'lv. ...t."an. to a '.CIlon "OJIDI
'.1.'... ndl,jC'lon .,r..m.nl
G - Il.Cllv. .nd "on,I.c"y. ..f.,,.I, to .
,.ctlon 4'571ttl d,t,"ed compen'allon Pl*,.
, ... f &elu".OI. ",o....n, ..D.n...
,..mOUl"elTl,nlt ,"0' .nC'ua,d .n DO. 1/
Q ... M.ltl.,.., .mOlo..... D....e QUart.,t.
lUOllar.nea_ ."CI comOa' 10". cOn\Da,.,.hO"
lu., Uh' ''''oun1 of .,01.1 qua"'" 101' IIC/.
YEn-rO'OAre
AMOUNT
2.7'7. '2
t.2.27 14
10.00
653,75
10. 15. ... It I". ....1'111011 ".M~ ... it
1:1'I....ca. I."C.a. 11m.., may.....,. ,. IN
.mOY/II of '"A conl"eutu"tI "OU "'tW .-...e.
It '1'1. "O'~.".d CO"'""..I'....' H_ I.
ePl.n.". 11'1. .I.ct.v. ..t.".lt ".. ..-. 13
lead.. O. I. ,. G. .... ..... $I If., .n
"mOIO....", an.. 'Of .al tufA 1'811' to _I'"
...ou O.lon" ar. ,.nerally IImll_ I. .......
Ilact.v. doll."", 101' Mellon 4GJtltl ..........
... ..mltad to '1.'500 1112.WO ". In,..,,,
CHeunu',"eu. ... .ub. 5711. fhe I...,it ..
..cIoOft .57101 Ollftt ., I1,lao. o\mcMIM.......
I"... I,mn. muSI o. ."ell..d 1ft......... ...
'hi F~rm 1040 ,n,"",CI.Q"a.
Mote: H.." CODY C of ~o,.'" W.I 'Or.
.r I...sr J y..,,., ./r.,. tile clUe ".t.-
'0" ,~ lIng you,. ,ncom. t.. ~.rU~ft~
SUMMARY OF EMPLO'E PAYROLL OEOUCTIONS
FOR CALENOAR YEAR '991
Your payroll record for tne calendar year t997
shOWI tnlt you nad tne foltowtng deduct10ns from
your gross pay. Tne amountt .nown are a y..r~to.dat.
tot.l for elch deductton type ltlted.
OEOUCTION
TYPE
FEO wTH Tx
SOC SEC/MEO TX
LOC wG TX-RES
RET P/U CON
INSTRUCTIONS (CO"" ".0<1 "om bock
0' Copy B)
I.. 1. - Inte, UU. emOYl'lt Oft ,". w.,.. line
a' vo," I.. r'1U11\.
10. 2. .. Int.r Hu. .mount on th. "d.,.1
Incom' 1.. wIINt.,1I IIn. ot your I'. ,.t",n.
101 .. ... Int., ,hi. *"oun, on ,". .d..nc.
",.r".1I Incom. cr.dll p,ym.ntl IIn, 0' 'lOW
If_ ,.'",n.
10. 10. ... TtuI amO"'1 '1 t'" 101.1 d.p.nd.nt
ell' b.n.t"1 your .moIO.,., 11'10 10 YOU 0'
IIIC.f.eI on YOUf b.n-It hncludl'" .mounu
from. .,Chon 12' pt~. An., amount ov.,
11,000 ,1'0 .1 .ftcIUM" ,n bO. ,. You mu.1
compl.t. Se".dul. 2 IIOlln 1040"'1 or 'orm
2U1 10 aom...,'. any unbl. ....d nontu'bl,
amauntl.
Io. U. - ThiS amount I. . 4,.nlbut,an mid.
to you from , nDnClU41li'lH 4et''',4
campens,tion 0' ..ction 457 pi... en4 'I
,ncl..d In 110. t. 0,. It m,., ., a .ont'lbullon
ty your ....10.,.' 10 , lIonqu,hti.d de,.",d
..,..ns,IIOf'1 ,Ien that II Incl&Jll.d tn 110. J
_dlo, ..
YEAR-TO'OATE
AMOUNT
6.191,' I
635.40
438.29
2.119.21
OEOUCTlON
TYPE
SOC SEC TX
SUTE WTH Tx
occ PRIV TX
UN OUES
101 12. ... Thls .mount il th. la..bl' 'Flnt.
b,nsfiu Includ.4 .n bOlt 1. You mlY bs abl.
to d'duct 'lII""'" t".t If' "Ia,.d to 'un,.
b.n."t.. ". 'the .nlnu'tlon, to' .,our t..
r,lurn.
to. 13. ... Tn. 'ollowlng lilt ..plllnl the Cad"
,,.aWft In 1I0lll 13. You mlY n..d tt'll'
,nlormat,on to campi... your f.. "turn.
( .. (I.etlv, d,',r,.l. to , IIctlon 6031111
ulary redueflon ..,.,m,nl.
G .. (I,et,v' an4 non,l,cuv, d",rr.11 to .
"Cllon 41Ulbl d.l.tr.d compenU'lon plan.
P .. I.cludelll, moving '.Pln..
,.Imbur"mlnt. lnOI "'Ieludld In ball 11.
o ... Milllll"t .moloy.. '''11: Q~tI.".
'ubllu.ne., ,nd camilli lone compln.".on
lu.1 n"l amounf It you QUlllly 'Of IICI.
YEAR-TO-OATE
AMOUNT
2.111.12
1.221. 14
'0.00
853.75
tal 15. - If th. "P.nl'on PI...... .... I,
cnull.ct. .,.c.,. limns .....y ",y t. lite
amolll'it of U'. cant"butl.., y.... .., ......
If the ooDeI.rr,ct compen.'tion" .... la .
e"IC..4. "t. .1"f'V' ..t.,'II. In ... "
Icodll D. I, '. Go He and .. If. III
Imploy",. ,n4 lor ,II heft "1M ,. ",.1Il
.,ou D'lon" ar, ",,"'11'1' ..",ItM .. .......
II"tI'" h,..,,11 'Of ...U.., 40* ....,....
.... IIm.tld to I'.eoo 1112.100 lft 1I",1t"
CIfC","""C". ... '\lb. 171>>. 'he ..,.... ..
UChon .Sllbl pi.., ., 17.100. .............
t"'" IIml" "",If .. tnChMI,ct ifll ........ ...
Uti Fo,m 10.0 t""'UCtlonl.
10'.: IC.." Copy C 0' '0"'. W..~ ,.,..
.t ,..sr 3 y..,.s .'t.,. U.. c1U. ..'.,;,U
'or'i , j"O you" , "COIN ta ,..rur,..- .