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HomeMy WebLinkAbout01-5654IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BRADLEY SANDERS, Plaintiff vs. ALISON SANDERS, Defendant NO. CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED 1N COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE PROMPT ACTION. YOU ARE WARNED THAT IF YOU FAIL TO DO SO, THE CASE MAY PROCEED WITHOUT YOU AND A DECREE OF DIVORCE OR ANNULMENT MAY BE ENTERED AGAINST YOU BY THE COURT. A JUDGMENT MAY ALSO BE ENTERED AGAINST YOU FOR ANY OTHER CLAIM OR RELIEF REQUESTED IN THESE PAPERS BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RiGHTS IMPORTANT TO YOU, INCLUDING CUSTODY OR VISITATION OF YOUR CHILDREN. WHEN THE GROUND FOR THE DIVORCE IS INDIGNITIES OR IRRETRIEVABLE BREAKDOWN OF THE MARRIAGE, YOU MAY REQUEST MARRIAGE COUNSELING. A LIST OF MARRIAGE COUNSELORS IS AVAILABLE IN THE OFFICE OF THE PROTHONOTARY AT THE CUMBERLAND COUNTY COURTHOUSE, I COURTHOUSE SQUARE, CARLISLE, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 BRADLEY SANDERS, ALISON SANDERS, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. Defcndunt CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE COUNT I 1. The Plaintiff is BRADLEY SANDERS, who currently resides at 2177 Merrimac Avenue, Meehanicsburg, Cumberland County, Pennsylvania 17055 since 1998. 2. The Defendant is ALISON SANDERS who currently resides at 2177 Merrimac Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055 since 1998, but who is believed to be moving on October 1, 2001, to an undisclosed location. Defendant, however, receives mail at P.O. Box 1244, Mechanicsburg, PA 17055. 3. Plaintiffand Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiffand Defendant were married on October 8, 1994, in Allegheny County, Pennsylvania. 5. There are no children of the parties under the age of eighteen. 6. There have been no prior actions of divorce or annulment between the parties. 7. Neither party is presemly a member of the Armed Forces on active duty. 8. The parties have not entered into a written agreement as to alimony, counsel fees, costs, and property division. 9. Phintiffhas been advised that com~eling is avalhble and that plaintiff may have the right to request that the court require the parties to participate in counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued by the Court. 10. The cause o f action and section o f Divorce Code under which Plaintiff is proceeding is § 3 3 01 (c). The marriage of the parties is irretrievably broken. 11. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, the Plaintiffrequests the Court enter an Order dissolving the marriage between the Plaintiff and Defendant. Dated: ~~ Respectfully submitted, WILEY, LENOX, COLGAN & MAJ~ZzACCO, P.C. ~hris~me J'~Taylor, ~ ~e -/~ 1 South Baltimore Street Dillsburg, PA 17019 (717) 432-9666 I.D. # 82204 VERIFICATION I, BRAD SANDERS, verify that the statements made in this document are tree and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to tmsworn falsification to authorities. BRAD SANDE~ ~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BRADLEY SANDERS, Plaintiff ALISON SANDERS, D~fendant NO. 01-5654 CIVIL ACTION - LAW IN DIVORCE CERTIIqCATE OF SERVICE I, Christine J. Taylor, Esquire hereby certify that on October 5, 2001, served Defendant with a true and corr~ copy of Plaintiff's Complaint for Divorce in the above-referenced matter by sending same to Defendant by certified mail, restricted delivery to addressee only, ~xwn receipt requested and by regular first class mail, postage prepaid, addressed as follows, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure. A copy of the return receipt signed by Defendant on October 5, 2001 is attached. Alison Sanders P.O. Box 1224 Mechanicsburg, PA 17055 By: WILEY, LENOX, COLGAN & MARZTACCO P.C. 3. Supreme Court I.D. #822ttY~~ 1 South Baltimore Stree~ Dillsburg, PA 17019 (717) 432-9666 (Attorney for Plainti~ ~ ~at we ~n ~um the ca~ to y~. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW AND DIVORCE BRADLEY SANDERS, Plaintiff, V. ALISON SANDERS, Defendant. No. FD: 01-5654 Civil Team Type of Pleading: ANSWER TO COMPLAINT IN DIVORCE AND COUNTERCLAIM Filed on behalf of.' ALISON SANDERS, Defendant Counsel of Record: D. SCOTT LAUTNER, ESQUIRE Pa. I.D. No. 80134 68 Old Clairton Road Pittsburgh, PA 15236 (412) 650-8820 IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA CIVIL ACTION LAW AND DIVORCE BRADLEY SANDERS, Plaintiff, v. AEISON SANDERS, Defendant. No. FD: 01-5654 Civil Team ANSWER TO COMPLAINT IN DIVORCE AND COUNTERCLAII~,i AND NOW COMES, Defendant, Alison Sanders, by and through his/her counsel, D. Scott Lautner, Esquire and files the within Answer to Complaint in Divorce and Counterclaim and avers as follows: COUNT I - DIVORCE 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. Admitted. 9. Paragraph 9 contains conclusions for which no response is required. 10. Paragraph 10 contains conclusions for which no response is required. However to the extent a response may be required Paragraph 10 is Specifically Denied. 11. Paragraph 10 contains conclusions for which no response is required. However to the extent a response may be required Paragraph 10 is Specifically Denied. WHEREFORE, Defendant prays this honorable court to deny the Plaintiff's request to dissolve the marriage between the Plaintiff and Defendant. COUNTERCLAIM COUNT I - EQUITABLE DISTRIBUTION 12. Paragraphs 1 through 11 are hereby incorporated by reference as if set forth at ler/gth, herein Counterclaim Count I - Equitable Distribution. 13. The Plaintiff and Defendant have legally and beneficially acquired property during their marriage from October 8, 1994 until the present time. 14. The Plaintiff and Defendant have been unable to agree as to the equitable division of said property and request that this Honorable Court equitably divide any and all marital properties. WHEREFORE, the Counterclaim Plaintiff, Alison Sanders, prays this Honorable Court to equitably divide, distribute, award or assign the marital property between the parties pursuant to Section 3502 of the Divorce Code of 1980, as amended. COUNTERCLAIM COUNT II - INJUNCTION FROM DISSIPATION OF MARITAL PROPERTY PENDING SUIT 15. Paragraphs 1 through 14 are hereby incorporated by reference as if set forth at length, herein Counterclaim II - Injunction from Dissipation of Marital Property Pending Suit. 16. The parties' own marital property as defined in the Pennsylvania Divorce Code, as amended. 17. The removal from this jurisdiction, disposal of, alienation, encumbering and/or dissipation of marital assets by the Plaintiff would be detrimental to the rights of the Plaintiff and would defeat the intent of the divorce code, all of which would irreparably harm the Defendant. WHEREFORE, Counterclaim Plaintiff, Alison Sanders, prays this Honorable Court to enjoin Counterclaim Defendant, Bradley Sanders, from disposing alienating, encumbering, or dissipating any and all marital assets COUNTERCLAIM COUNT III - COUNSEL FEES~ COSTS AND EXPENSE:; COUNT IV - COUNSEL FEES~ COSTS~ AND EXPENSES 18. Paragraphs 1 through 17 are hereby incorporated by reference as if set forth at length, herein Counterclaim Count III - Counsel Fees, Costs and Expenses. 19. The Counterclaim Plaintiff is financially unable to pay her counsel fees and the costs and expenses of prosecuting this action. 20. The Counterclaim Defendant is financially able to pay for the Counterclaim Plaintiff's counsel fees and the Counterclaim Plaintiff's costs and expenses of prosecuting this action. WHEREFORE, Counterclaim Plaintiff, Alison Sanders, prays this Honorable Court, to grant interim and final counsel fees, costs and expenses for the Counterclaim Plaintiff which are reasonably related to the above-captioned matter. COUNTERCLAIM COUNT IV - SPOUSAL SUPPORT AND ALIMONY PENDENTE LITE 21. Paragraphs 1 through 20 are hereby incorporated by reference as if set forth at length, herein Counterclaim Count IV - Spousal Support and Alimony Pendente Lite. 22. Ihe Counterclaim Plaintiff lacks sufficient property to provide for her reasonable needs during the pendency of this action.. 23. The Counterclaim Defendant is financially able to provide for the reasonable needs of the Counterclaim Plaintiff during the pendency of this action. WHEREFORE, Counterclaim Plaintiff, Alison Sanders, prays this Honorable Court, to grant spousal support and alimony pendente lite for the Counterclaim Plaintiff, which are reasonably-related to the above-captioned matter. COUNTERCLAIM COUNT V - PERMANENT ALIMONY 24: Paragraphs 1 through 23 are hereby incorporated by reference as if set forth at length, herein Counterclaim Count V - Permanent Alimony. 25. Counterclaim Plaintiff lacks sufficient income and property to provide for her reasonable needs and is unable to support herself fully through appropriate employment. 26. Counterclaim Defendant is financially able to provide for reasonable needs of the Counterclaim Plaintiff. WHEREFORE, Counterclaim Plaintiff, Alison Sanders, prays this Honorable Coytrt, to grant permanent alimony for the Counterclaim Plaintiff which are reasonably- related to the above-captioned matter. COUNTERCLAIM COUNT VI - INSURANCE AND OTHER BENEFITS 27. Paragraphs 1 through 26 are hereby incorporated by reference as if set forth at length, herein Counterclaim Count VI - Insurance and Other Benefits. 28. There exists certain contracts of policies of insurance insuring the life of the Counterclaim Plaintiff and Counterclaim Defendant and insuring coverage for health and medical expenses for the Counterclaim Defendant and Counterclaim Plaintiff as well as their minor child. 29: Counterclaim Plaintiff believes and therefore avers that she is the designated beneficiary of said life and health insurance policies. 30. Said contracts or policies of insur~ince and other benefits are vital to the Plaintiff to ensure her support, maintenance and/or alimony, and payment of other expenses should the Counterclaim Defendant die or if the Counterclaim Plaintiff should become ill. Counterclaim Defendant is financially able to provide for reasonable needs of the Counterclaim Plaintiff. WHEREFORE, Counterclaim Plaintiff, Alison Sanders, prays this Honorable Court, to grant insurance and other benefits for the Counterclaim Plaintiff, which are reasonably related to the above-captioned matter. R~fully su~bmitted, D. Sco~tt~ Attorney for Defendant VERIFICATION I Verify that the statements under this ~ ~ ~'--~e e~ ,4-,.,.J ~_ C,~ ~, .-' 4--t.c~ e. t/n, ~,, are true and correct. I understand that false statements herein are made subject to the penalties of l 8 Pa. C.S. 4904, relating to unsworn falsification to authorities. Date: IN THE COURT OF COMMON PLEAS OF CUMBERLANDCOUNTY, PENNSYLVANIA CIVIL ACTION LAW AND DIVORCE BRADLEY SANDERS, ) ) Plaintiff, ) ) v. ) ) ALISON SANDERS, ) ) Defendant. ) No. FD: 01-5654 Civil Team CERTIFICATE OF SERVICE I, D. Scott Lautner, Esquire, certify that a tree and correct copy of the within Answer to Complaint in Divorce via U.S. Mhil First Class Mail on the ] ~' .day of ~C~'¢0~ , 2001 to the following: CHRISTINE TAYLOR, Esquire Wiley Group One South Baltimore Street Dillsburg, PA 17019 D. Scott Lautner, ~squire Attorney for Defendant Bradley J. Sanders/2.6.02 Praecipe - Withdraw Appearance BRADLEY SANDERS, Plaintiff ALISON SANDERS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5652 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO WITHDRAW APPEARANC~ TO THE PROTHONOTARY OF THE SAID COURT: Please withdraw the appearance of Christine J. Taylor, Esquire, as attorney for the Plaintiff, BRADLEY SANDERS, in the above captioned matter. Respectfully submitted, Christine- ~--~-T~y~squire Dillsburg, PA 17019 - 1 - Bradley J. Sanders/2.6.02 Praecipe - Enter Appearance BRADLEY SANDERS, Plaintiff ALISON SANDERS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5654 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PRAECIPE FOR ENTRY OF APPEAPd%NC~ TO THE PROTHONOTARY OF THE SAID COURT: Please enter the appearance of Diane G. attorney for the Plaintiff, BRADLEY SANDERS, matter. Radcliff, Esquire, as in the above captioned Respectfully submitted, PHONE: (717) 737-0100 Fax: (717) 975-0697 Voice Mail: (717) 558-5518 I.D. No. 32112 Attorney for Plaintiff 3.5.02. Income & Expense Bradley J. Sanders BP~ADLEY SANDERS, ALISON S~LNDERS, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLA/~D COUNTY, PENNSYLVANIA : : NO. 01-5654 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE INCOME AND EXPENSE STATEMENT OF BRADLEY J. SANDERS I verify that the facts set forth in the foregoing Income and Expenses Form, including all attachments thereto, are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. ~~~ BRADLEY J. - 1 - 3.9.02. Income & Expense Bradley J. Sanders PART I. INCOME A. EMPLOYMENT INFORMATION: EMPLOYER: A. S McCreath & Sons, Inc. ADDRESS: P.O. Box 1453, Harrisburg, PA 17105 POSITION: Chemist PAYROLL NUMBER: 179664680 SANB PAY PERIOD: Bi-weekly B. EMPLOYMENT iNCOME: GROSS PAY PER PAY PERIOD 2,307.20 2,307.20 ITEMIZED DEDUCTIONS FICA OR SE TAX (176.50) (176.50) MEDICARE OR SE TAX FEDERAL TAX (287.36) (287.36) STATE TAX (64.60) (64.60) LOCAL TAX (23.07) (23.07) MANDATORY RETIREMENT UNION DUES HEALTH INSURANCE ~ VOLUNTARY RETIREMENT (138.43) ~ OTHER: APL (161.54) ~ TOTAL DEDUCTIONS (851.50) (551.53) NET PAY PER PAY PERIOD 1,455.70 1,755.67 NET PAY PER MONTH 3,154.02 3,803.95 3.9.02. Income & Expense Br&dley J. Sanders D. OTHER INCOME= DESCRIPTION MONTHLY YEARLY INTEREST 85.00 DIVIDENDS PENSIONS ANNUITIES SOCIAL SECURITY RENTS ROYALTIES EXPENSE ACCOUNT GIFTS UNEMPLOYMENT COMPENSATION WORKMAN'S COMPENSATION INCOME TAX REFUNDS SUPPORT OR ALIMONY COMMISSIONS TIPS OTHER SPECIFY: TOTAL OTHER INCOME $0.00 $85.00 3.9.02. Income & Expense Bradley J. Sanders PART II. EXPENSES DESCRIPTION WEEKLY MONTHLY ANNUAL AMOUNT AMOUNT AMOUNT Rent First Mortgage $407.19 $1,764.51 $21,174.12 $1,438.39 P&I $326.12 escrows ($40.50 ins.; $241.00 taxes; $48.04 PMI) Second Mortgage/Home Equity Loan Maintenance And Repairs $11.54 $50.00 $600.00 Electric $17.31 $75.00 $900.00 Gas $21.92 $95.00 $1,140.00 Oil Telephone $11.54 $50.00 $600.00 Water $3.75 $16.25 $195.00 Sewer $7.69 $33.33 $399.96 Trash $2.69 $11.66 $139.92 Public Transportation Lunches $10.00 $43.33 $519.96 Other Employment Expenses Real Estate Taxes $55.62 $241.00 $2,892.00 Personal Property Taxes $0.19 $0.82 $9.84 Per Capita/Occupation $5.84 $25.32 $303.84 Taxes 3.9.02. Income & Expense Br&dley J. Sanders DESCRIPTION Homeowners Insurance WEEKLY AMOUNT MONTHLY AMOUNT $4o. 5o ANNUAL AMOUNT $486.00 Automobile Insurance $11.75 $50.92 $611.04 Life Insurance Accident Insurance Health Insurance Other Insurance Specify: Payments $434.35 $100.23 $5,212.20 Fuel $23.00 $99.66 $1,195.92 Maintenance And Repair $9.62 $41.67 $500.04 $6.75 $1o.00 License And Registration Doctor $1.56 $2.31 $81.00 $120.00 Hospital Medicine $1.15 $5.00 $60.00 Special Needs/Therapy Private School Parochial School Dental Orthodontic Optical $1.92 $8.33 $99.96 3.9.02. Income & Expense Bradley J. Sanders DESCRIPTION College/Vocational Religious Training or Education Books/Fees And Supplies Other Educational Expen ses WEEKLY MONTHLY ANNUAL AMOUNT AMOUNT AMOUNT Clothing $15.39 $66.67 $800.04 Food $92.31 $400.00 $4,800.00 Barber And Hair Dresser $2.31 $10.00 $120.00 Memberships $0.69 $3.00 $36.00 Other Personal Expenses Specify: Household Help Child Care Newspaper/Magazines/Books Entertainment $11.54 $50.00 $600.00 Pay TV Vacations $19.23 $83.33 $999.96 Gifts $9.61 $41.66 $499.92 Legal Fees $76.92 $333.33 $3,999.96 Charitable Contributions - 6 - 3.9.02. Income & Expense Bradley J. Sanders DESCRIPTION WEEKLY MONTHLY ANNUAL AMOUNT AMOUNT AMOUNT Other Child Support (not the subject of this action) Other Spousal Support or Alimony (not the subject of this action) TOTAL EXPENSES $944.17 $4,091.39 $49,096.68 - 7 - 3.9.02. Income & Expense Bradley J. Sanders PART III. PROPERTY OWNED TYPE DESCRIPTION VALUE H W JT Checking PSECU $180.00 X Savings PSECU $24.86 X Credit Union Stocks/bonds Real Estate Other See Plaintiff's Inventory PART IV. INSURANCE TYPE COMPANY POLICY NO. ,H W C Hospital/Blue Blue Cross ABD179664680 X X Cross Group 601965000 Medical/Blue Blue Shield BS Plan 865 X X Shield BC Plan 361 Health Accident Disability Income Dental Vision Other-Specify *H=Husband; W=Wife; J=Joint; C=Child - 8 - 3.9.02. Income & Expense Bradley J. Sanders (a) (b) (c) (d) (e) (f) PART V. SUPPLEMENTAL INCOME STATEMENT [X] CHECK HERE IF NOT APPLICABLE This form is to be filled out by a person: (1) Who operates a business 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. Attach to this statement a copy of the following documents relating to the partnership, joint venture, business, profession, corporation or similar entity (check block to indicate the document is attached): (1) The most recent Federal Income Tax Return. [ ] attached (2) The most recent Profit and Loss Statement. [ ] attached Name of Business: Business Address: Business Telephone: Nature of Business (check one) [ ] 1. Sole Proprietorship [ ] 2. Partnership [ ] 3. Joint Venture [ ] 4. Professional [ ] 5. Corporation [ ] 6. Other Name of accountant, controller or other person in charge of financial records: Business Income: 1. Annual income from business: 2. How often is income received: 3. Gross income per pay period 4. Net income per pay period 5. Specify deductions, if any: 2.6.02 Inventory/Analysis, revised 2.27.02. AND 3.15.02. Bradley J. Sanders BRADLEY SANDERS, ALISON SANDERS, Plaintiff Defendant INVENTORY : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-5654 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE OF BRADLEY SANDERS © 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 falsification to authorities. 18 Pa.C.S. Section 4904 relating to unsworn 3448 T/3~l~ Road Ca~__~PA 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ~ #32112 Dated:~/~~ Page 1 2.6.02 Inventory/Analysis, revised 2.27.02. AND 3.15.02. Bradley J. Sanders ASSETS AND LIABILITIES OF PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets and debts on the following pages: (X) 1. Real property and Real Estate Mortgages (X) 2. Motor vehicles and Vehicle Liens ( ) 3. Stocks, bonds, securities and options { } 4. Certificates of Deposit (X) 5. Checking accounts, cash {X) 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 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 ( ) 21. Litigation claims (matured and unmatured) ( ) 22. Military/V.A. benefits ( ) 23. Education benefits ( ) 24. Debts due, including loans, mortgages held (X) 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution is in dispute} ( } 26. Other assets (X) 27. Loans (X) 28. Credit Cards (X } 29. Other Debts Page 2 I. MARITAL PROPERTY AND MARITAL LIABILITIES Plaintiff lists all marital property in which either or both spouses have a legal or equitable interest, individually or with any other person as of the date of separation and, all marital liabilities owed by either or both spouses, individually or with any other person as of the date of separation: NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION LIABILITY LIABILITY TO HUSBAND TO WIFE Mechanicsburg, PA FAIR MKT. VALUE Washington (213,500.00) Mutual Mortgage NET EQUITY 6,500.00 6,500.00 6,500.00 The above value is basea on 9/13/01 appraisal. Tax assessment value is $214,960.00 . husband contributs~ $~7,000,00 from his retirement plans £or this puruhass Wife values home at $226,000.00, HU~ba~ lalues ha at $220,000.~0. I A WIFE S 1995 2 02 3 500.00 Eagle vision TSI Loan for Wife's N/A Eagle vision NET VALUE 3,500.00 3,500.00 3,500.00 Sold b~' wifS ~n ~ebz~&ry o£ 2002 for $3,500.00 Page 3 NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED pROPOSED pROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION LIABILITY LIABILITY TO HUSBAND TO WIFE HUSBAND'S FORD 9.5.01 (15,846.38) OTOR CREDI VEHICLE LOAN NET VALUE 1,033 . 62 1,033 . 62 1,033.62 1 A Joint PSECU 9.10.01 31.45 31.45 31.45 account B Wife's checking Est. 2,900.00 2,900.00 2,900.00 account A Joint PSECU 9.14.01 217.00 217.00 117.00 100.00 savings account 1 A Husband s 9 30 01 12 028.82 Prudential 401K Plan Premarital value (2,678.68) of Husband' s retirement Marital Value of 9,350.14 9,350.14 9,350.14 husband's 401K Plan Page 4 NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED pROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION LIABILITY LIABILITY TO HUSBAND TO WIFE E Wife's Fidelity 6.30.01 14,620.90 14,620.90 14,620.90 401K Plan A Husband's EST. 4,980.00 4,980.00 4,980.00 Household Goods B wife's Household EST. 13,905.00 13,905.00 13,905.00 Goods A. Universal Card 9.10.02 (869.24) {869.24) (869.24) ~Sband Page 5 NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION LIABILITY LIABILITY TO HUSBAND TO WiFE D Discover Card 9.25.01 (179.84) (179.84) (179.84} E Wife's airline 2.02 (194.00) (194.00) (194.00) ticket charged on joint credit card A September 9.25.01 (1,753.15) (1,753.15) (1,753.15) Mortgage Payment B Husband's Truck 9.25.01 (285.40) (285.40) (285.40) Payment C Sewer bill for 9.25.01 (100.00) (100.00) (100.00) July - September UGI Balance 9.28 01 (44.69) (44.69} (44.69} TOTAL OF ASSETS ~ LIABILITIES 55,653.21 18,296.02 37,357.19 Page 6 NO DESCRIPTION OF DATE OF VALUE OF NET VALUE pROPOSED PROPOSED PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION LIABILITY LIABILITY TO HUSBAND TO WIFE Totals from above 55,653.21 18,296.02 37,357.19 Amount Due in 50/50 Division 27,826.61 27,826.61 Adjustment Figure 9,530.59 (9,530.59) Page 7 II. LISTING OF HOUSEHOLD GOODS AND CONTENTS VALUED IN SECTION I. Plaintiff lists all household goods and contents in which either or both spouses have a legal or equitable interest, individually or with any other person as of the date of separation, the total value of which is specified in Section I. above: 1 Engagement ring wife $7,015.00 Appraised value is $7,015.00 2 Futon Wife $300.00 $637.00 new value 3 Computer desk Wife $100.00 $250.00 new value and chair 4 Bookcase Wife $50.00 $200.00 new value 5 Jewelry armoire Wife $100.00 $200.00 new value 6 Full length Wife $90.00 $100.00 new value cheval mirror 7 Lingerie Chest Wife $450.00 $900.00 new value 8 Floor lamp Wife $50.00 $100.00 new value 9 Stereo rack Wife $500.00 $1000.00 new value system 10 Ail CD's Wife $150.00 $500.00 new value 11 TV from bedroom Wife $50.00 $200.00 new value 12 Ail Pfaltzgraf Wife $250.00 $500.00 new value dishes 13 Ail crystal Wife $100.00 $200.00 new value ware Page 8 %11 silverware wife $60.00 Ail glasses wife $20.00 Longaberger Wife $750°00 baskets 2 bakers racks Wife $125.00 $120.00 new value $40.00 new value $750.00 new value $250.00 new value Lcuum cleaner & bucket & broom Mirror - Home Interiors Wall decorations Paintings, prints, pictures, etc. Computer & monitor Color inkjet printer Wife $50.00 $200.00 new value Wife $5.00 20.00 new value Wife $60.00 $60.00 new value Wife $250.00 $500.00 new value Wife $200.00 $600.00 new value Wife $100.00 Camera Wife $100.00 Crystal vases Wife $100.00 Knives Wife $50.00 $200.00 new value $200.00 new value $300.00 new value $100.00 new value Printer stand Wife $40.00 $80.00 new value Iron & ironing Wife $20.00 $60.00 new value board Telephones (2) Wife $75.00 $150.00 new value Digital answering machine Wife $50.00 ble stereo Wife $40.00 pots & Wife $25.00 pans $100.00 new value $70.00 new value $100.00 new value Page 9 Household Wife supplies $100.00 $100.00 new value Electric mixer wife $30.00 Food processor Wife $50.00 Twin mattress Wife $150.00 All jewelry wife $2,250.00 (excluding engagement ring) Plum sofa, love seat, chair, end tables, and coffee table $80.00 new value $120.00 new value $300.00 new value; Used for guests only; 6 times 500.00 new value Wife N/A husband has not inserted a value since wife is paying purchase debt equal to value. SUBTOTAL FOR WIFE $13,905.00 39 Amish table & Husband $800.00 $2,187.00 new value chairs 40 Couch Husband $300.00 $800.00 new value 41 2 recliners Husband $300.00 $800.00 new value 42 Sunroom Husband $400.00 $1,252.00 new value furniture 43 Patio set Husband $100.00 $200.00 new value 44 Bedroom set Husband $800.00 $2,500.00 new value; 8 years old 45 Refrigerator Husband $500.00 $1,000.00 new value 46 Washer/Dryer Husband $400.00 $800.00 new value 47 Grill Husband $100.00 $525.00 new value 48 Lawn mower Husband $100.00 $400.00 new value Page 10 2.6.02 Inventory/Analysis, revised 2.27.02. AND 3.15.02. Bradley J. Sanders Pots & pans TV VCR Husband $50.00 Husband $100.00 $150.00 new value 600 new value; 8 years old Husband $30.00 $80 new value Weedwacker Husband $50.00 .180 new value; 3 years old; heavily used Husband $50.00 Husband $900.00 $1600 new value Garden accessories Rem. 700 Rem. SP12 Si9 Sauer P29 SUBTOTAL FOR I{USBA~D $4,980.00 Page 11 III. NON-MARITAL PROPERTY A/TD LIABILITIES Plaintiff lists all property and/or debts in which a spouse had a legal or equitable interest or owed as of the date of separation which is claimed to be excluded from marital property or debts by virtue of it being acquired before marriage, after separation or by way of gift or inheritance (for gifts also specify person giving gift): H Husband $100.00 H Husband $300.00 $400.00 new value; Pre-marital $450.00 new value; Pre-marital IV. PROPERTY TRANSFERRED Plaintiff lists all property which was transferred within 3 years of the date of the commencement of this action or was transferred since the date of separation: Wife's Eagle Vision Vehicle TBD 3,500.00 Page 12 2.6.02 Inventory/Analysis, revised 2.27.02. ~ 3.15.02. Bradley J. Sanders CERTIFICATE OF SERVICE AND NOW, this 26th day of March, 2002, I, DIANE G. P~ADCLIFF, ESQUIRE, hereby certify that I have this day served a copy of the within INVENTORY, upon the following set forth person, by mailing same by first class mail, postage prepaid, addressed as follows: Scott D. Lautner, Esquire 68 Old Clairton Road Pittsburgh, PA 80134 Respectfully submitted, DIANE G. RA~CLiP~', ESQUIRE 344_~.-T-r-i~l e) Road ~ 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID ~32112 Page 13 /? BRADLEY SANDERS, Plaintiff ALISON SANDERS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-5654 : : CIVIL ACTION - LAW : DIVORCE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 - 1 - ?/ BRADLEY SANDERS, Plaintiff Vo ALISON SANDERS, Defendant : NO. 01-5654 : · CIVIL ACTION - : DIVORCE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMENDED COMPLAINT Plaintiff, BRADLEY SANDERS, by his attorney, LAW , 2002, comes the DIANE G. RADCLIFF, ESQUIRE, and files this Complaint in Divorce of which the following is a statement: 1. The Plaintiff is Bradley Sanders, an adult individual residing at 2177 Merrimac Avenue, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is Alison Sanders, an adult individual residing at 208 Louisa Lane, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and/or Defendant have been bona fide residents of the Commonwealth for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on October 8, 1994 at Allegheny County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. - 2 - // 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The Plaintiff avers that the grounds on which the action is based are: a. That the marriage is irretrievably broken; Or in the alternative, b. That the parties are now living separate and apart, and at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. Or in the alternative, c. That Defendant has offered such indignities to the person of the Plaintiff, the innocent and injured spouse, as to render his condition intolerable and life burdensome, and that this action is not collusive. d. The Defendant has committed and is committing adultery entitling Plaintiff to a divorce in accordance with 23 Pa. C.S.A. 3301(a) (2). // WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. COUNT II= EOUITABL~ DISTRIBUTIO~ 9. Paragraphs 1 through 8 are incorporated by reference hereto as fully as though the same were set forth at length. 10. Plaintiff and Defendant have acquired property and debts, both real and personal, during their marriage until the date of separation, all of which is "marital property". 11. Plaintiff and/or Defendant have acquired, prior to the marriage or subsequent thereto, "non-marital property,, which has increased in value since the date of marriage and/or subsequent to its acquisition during the marriage, which increase in value is "marital property". 12. Plaintiff and Defendant have been unable to agree as to an equitable division of said property as of the date of the filing of this Complaint. - 4 - /? WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital property and debts of the parties. Respectfully submitted, Camp Hill, PA 17011 Supreme Court ID #32112 Phone: (717) 737-0100 Fax: (717) 975-0697 Attorney for Plaintiff - 5 - // VERIFICATION statements made in this Complaint are true I verify that the 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. ?/ P~ADCLIFF, ESQUIRE, hereby certify that I have this day served a copy of the foregoing document upon the following named person, by mailing same by first class mail, postage prepaid, addressed as follows: Scott Lautner, Esquire 68 Old Clairton Road Pittsburgh, PA 80134 Respectfully submitted, Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 - 7 - 3.9.02/Revised $.25.02/Revised %.12.02/Income & Expense Bradley.J. Sanders BRADLEY SANDERS, ALISON SANDERS, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-5654 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE AMENDED INCOME AND EXPENSE STATEMENT OF BRADLEY J. SANDERS I verify that the facts set forth in the foregoing Income and Expenses Form, including all attachments thereto, are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. BRA-DL~Y J. '~D~S - ~ 3.9.02/Revised 3.25.02/Revised 4.12.02/Income & Expense Bradley J. Sanders D. OTHER INCOME: DESCRIPTION MONTHLY YEARLY INTEREST 7.08 85.00 DIVIDENDS PENSIONS ANNUITIES SOCIAL SECURITY RENTS ROYALTIES ~EXPENSE ACCOUNT GIFTS UNEMPLOYMENT COMPENSATION WORKMAN'S COMPENSATION INCOME TAX REFUNDS 175.66 2,108.00 SUPPORT OR ALIMONY COMMISSIONS TIPS OTHER SPECIFY: TOTAL OTHER INCOME $182.74 $2,193.00 - 3 - 3.9.02/Revised 3.25.02/Revised 4.12.02/Income & Expense Bradley J. Sanders PART I. INCOME A. EMPLOYMENT INFORMATION: EMPLOYER: A. S McCreath & Sons, Inc. ADDRESS: P.O. Box 1453, Harrisburg, PA 17105 POSITION: Chemist PAYROLL NUMBER: 179664680 SA/qB PAY PERIOD: Bi-weekly B. EMPLOYMENT INCOME: GROSS PAY PER PAY PERIOD 2,307.20 2,307.20 ITEMIZED DEDUCTIONS FICA OR SE TAX 176.50) (176.50) MEDICARE OR SE TAX FEDERAL TAX 287.36) (287.36) STATE TAX (64.60) (64.60} LOCAL TAX {23.07) (23.07) MANDATORY RETIREMENT UNION DUES HEALTH INSURANCE VOLUNTARY RETIREMENT (138.43} OTHER: APL (161.54) TOTAL DEDUCTIONS (851.50) (551.53) NET PAY PER PAY PERIOD 1,455.70 1,755.67 NET PAY PER MONTH 3,154.02 3,803.95 3.9.02/Revised 3.25.02/Revised 4.12.02/Income & Expense Bradley J. Sanders PART II. EXPENSES DESCRIPTION WEEKLY MONTHLY ANNUAL AMOUNT AMOUNT AMOUNT Rent First Mortgage $407.19 $1,764.51 $21,174.12 $1,438.39 P&I $326.12 escrows ($40.50 ins.; $241.00 taxes; $48.04 PMI) Second Mortgage/Home Equity Loan Maintenance And Repairs $11.54 $50.00 $600.00 Electric $17.31 $75.00 $900.00 Gas $21.92 $95.00 $1,140.00 Oil Telephone $11.54 $50.00 $600.00 Water $3.75 $16.25 $195.00 Sewer $7.69 $33.33 $399.96 Trash $2.69 $11.66 $139.92 Public Transportation Lunches $10.00 $43.33 $519.96 Other Employment Expenses Real Estate Taxes $55.62 $241.00 $2,892.00 Personal Property Taxes $0.19 $0.82 $9.84 Per Capita/Occupation $5.84 $25.32 $303.84 Taxes - 4 - 3.9.02/Revised 3.25.02/Revised 4.12.02/Income & Expense Bradley J. Sanders DESCRIPTION WEEKLY MONTHLY ANNUAL AMOUNT AMOUNT AMOUNT Homeowners Insurance $9.35 $40.50 $486.00 Automobile Insurance $11.75 $50.92 $611.04 Life Insurance Accident Insurance Health Insurance Other Insurance Specify: Payments $100.23 $434.35 $5,212.20 Fuel $23.00 $99.66 $1,195.92 Maintenance And Repair $9.62 $41.67 $500.04 License And Registration $1.56 $6.75 $81.00 Doctor $2.31 $10.00 $120.00 Optical Dental $1.92 $8.33 $99.96 Orthodontic Hospital Medicine $1.15 $5.00 $60.00 Special Needs/Therapy Private School Parochial School College/Vocational Religious Training or Education 3.9.02/Revised 3.25.02/Revised %.12.02/Income & Expense Bradley J. Sanders DESCRIPTION WEEKLY MONTHLY ANN~AL AMOUNT AMOUNT AMOUNT Books/Fees And Supplies Other Educational Expen ses Clothing $15.39 $66.67 $800.04 Food $92.31 $400.00 $4,800.00 Barber And Hair Dresser $2.31 $10.00 $120.00 Memberships $0.69 $3.00 $36.00 Other Personal Expenses Specify: Household Help Child Care Newspaper/Magazines/Books Entertainment $11.54 $50.00 $600.00 Pay TV Vacations $19.23 $83.33 $999.96 Gifts $9.61 $41.66 $499.92 Legal Fees Charitable Contributions (not Other Child Support the subject of this action) $76.92 $333.33 $3,999.96 3.9.02/Revised 3.25.02/Revised 4.12.02/Income & Expense Bradley J. Sanders DESCRIPTION WEEKLY MONTHLY ANNUAL AMOUNT AMOUNT AMOUNT Other Spousal Support or Alimony (not the subject of this action) TOTAL EXPENSES $944.17 $4,091.39 $49,096.68 - 7 - 3.9.02/Revised 3.25.02/Revised 4.12.02/Income & Expense Bradley J. Sanders PART III. PROPERTY OWNED TYPE DESCRIPTION VALUE H W JT Checking PSECU $180.00 X Savings PSECU $24.86 X Credit Union Stocks/bonds Real Estate Other See Plaintiff's Inventory PART IV. INSURANCE TYPE COMPANY POLICY NO. H W C Hospital/Blue Blue Cross ABD179664680 X X Cross Group 601965000 Medical/Blue Blue Shield BS Plan 865 X X Shield BC Plan 361 Health Accident Disability Income Dental Vision Other-Specify *H=Husband; W=Wife; J=Joint; C=Child $.9.02/Revised 3.25.02/Revised 4.12.02/Income & Expense Bradley J. Sanders (a) (b) PART V. SUPPLEMENTAL INCOME STATEMENT [X] CHECK HERE IF NOT APPLICABLE This form is to be filled out by a person: (1) Who operates a business 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. Attach to this statement a copy of the following documents relating to the partnership, joint venture, business, profession, corporation or similar entity (check block to indicate the document is attached}: (1) The most recent Federal Income Tax Return. [ ] attached (2) The most recent Profit and Loss Statement. [ ] attached (c) Name of Business: Business Address: Business Telephone: (d) (e) Nature of Business (check one) [ ] 1. Sole Proprietorship [ ] 2. Partnership [ ] 3. Joint Venture [ ] 4. Professional [ ] 5. Corporation [ ] 6. Other Name of accountant, controller or other person in charge of financial records: (f) Business Income: 1. Annual income from business: 2. How often is income received: 3. Gross income per pay period 4. Net income per pay period 5. Specify deductions, if any: orm 1040 u.s. Individual Income Tax Return 2001 <gg) IR~useonly--DonotwriteorstapleinUqissbece Label Use the IRS label. Otherwise, please print or ~pe, Presidential Election Campaign Filing Status Check only Exemptions For the }~ar Jan I - Dec 31, 2001, or other tax year beginning Your First Name MI Last Name Bradley J Sanders If a Joint Refum~ Spouse's First Name Mr Last Name Home Address (number and street). If You Have a P.O. Box, See Instn~ctions. 2177 Plerrimac Ave r'lechani csburg ,2001, ending PA 17055 OMB No. 1545-0074 179-66-4680 192-56-5174 · Important! · You must enter your social security number(s) above. Note: Checking 'Yes' will not change your tax or reduce your refund. You Spouse Do you, or ~/our spouse if filing a joint return, want $3 to 9o to this fund? ........ ~' ~ Yes I~ No ~ Yes ~ No I ~ Single 2 Married filing joint return (even if only one had income) 3 Married filing separate return. Enter spouse's SSN above & full name here .. ~ Al ~ son M Sander s 4 Head of household (with qualifTing person). [See instructions.) If the qualitying person is a child but not your dependent, enter this child's name here ~' 5 r~l Quali~in~ widow(er) with dependent child (,year spouse died ~' ). [See instructions.) 6a IXI Youreolf. If your parent (or someone else) can claim you as a dependent on his or --I No. ~f her tax return, "0 not check box 6a .......................................... ~-- ~ .e~dlm~:~.. * 1 _ _ ('2) Dependent's (3) Dependent's (4) ~/ c uepanaents: social security relationship I ~u?i~n~ · nv~ number to ~/ou I child for chdd If more than six dspendenta, see insti'uctiens. d Total number of exemptions claimed .................................................... 7 Wages, salaries, tips, 'etc. Attach Form(s) W-2 ...................................... 7 5b, 303. Income sa Taxable interest. Attach Schedule B if required ....................................... Ga! 1 2 3, Attach Forats bTax-~x~mpt interest. Do not include on line 8a .......... I 8bi W-2 aml~Y-2G hem. ,.~.,,a[ta. ch 9 Ordinary dividends. Attach Schedule B if required ................................ 9 Form(q~"~-R if 10 Taxable refunds, credits, or offsets of state and local income taxes (see instructions) ..... 10 tax?a~_ithh~ld. 11 Alimenyreceived ................................................................. 11 1;' Business income o¢ (loss), Attach Schedule C or C*EZ ........................... 12 If you did not get a W-2, see 13 Capital gain or (10ss). Attach Schedule D if required. If not required, check here ......... ~ [] 13 instructions. 14 Other gains or (losses). Attach Form 4797 .......................................... 14 15a Tota~ IRA distributions ..... 15a I b Taxable amount (see instrs) 16a Tote pens ons& annu t es . 16aI b Taxable amount (see instrs) ., 17 Rental real estate, royalties, partherships, S corporations, trusts, etc. Attach Schedule E ,. 17 Enclose, but do 18 Farm income or (loss). Attach Schedule F ............................................ 18 not attach, any 19 Unemployment compensation ..................................................... 19 payment. Also, please use 20s Social security benefits ..... I 20al J b Taxable amount (see instrs) 20b Form 1040-V. 21 Other income 21 22 Add the amounts in the far ric~ht column for ~ines 7 through 23. This Is ~/our total i~come ~ 22 50,426. 23 IRA deduction (see instructions) ........................... 23 Adjusted 24 Student lean interest deducfion (see instructions) ........... 24 Gross ~ Archer MSA deduction, Attach Form 8853 ................. 25 Income 26 Moving expenses. Attach Form 3903 ...................... I 26 27 One-half of self-employment tax. Attach Schedule SE ...... Z7 28 Self-employed health insurance deduction (see instructions) 28 29 Self-employed SEP, SIMPLE, and qualified plans ........... 29 30 Penalty on early withdrawal of savings ..................... 31aAlim0nypaid bR~c~prentsSSN .... 192-56-5174 .. 31e 572. ~2 Add fines 23 through 31a ............................................................... 3;2 572. 33 Subtract line 32 from line 22. This is ~/our adjusted ~ress income . ~ 33 49,854. BAA For Disclosure, Privacy Act, and Paperwork Reduction Act Notice, see instructions. FDIA0112 12/10/01 Form 1040 (2001) Bradle .f Sanders 179-66-4680 Page2 34 Amount fTom line 33 (adjusted gloss income) 34 49,8 5'4, Tax and Credits ~ Checkif: [] You were 65/older, [] Blind; [] Spouse was 65/older, [] Blind. Add the number of boxes checked above and enter the total here .... · ~Sa L Standard b If you are married filing separately and your spouse itemizes deductions, O~duction or you were a duaFstatus alien, see instructions and check here ....... · 3~b [] tot - · Peopte who --36 Itemized deductions (from Schedule A) or your standard deduction (see left margin) 3~ 1 9,4 5 0, checked any box -37 Sub,'act line 36 from line 34 ................................... 37 30,404 on line 35a or 35b or who can 38 If line 34 is $99,725 or less multiply $2 900 by the total number of exemptions ciaimed be claimed as a om ~ine 6d1 ~t line 3A ie ov~' $99,725, see the worksheet n the instructions 38 2,900 dependent, see 39 Taxable Income. Subtract line 38 from line 37. If line 38 is more than line 37, enter -0- ............. 39 2 7,5 04 instructions. 40 Tax (see instrs). Check it any tax is from a [] Form(s) ~14 b [] Form 4972 ............... 40 4,744 · All others: 41 Single: 41 Alternative minimum tax (see instructions). Attach Form 6251 $4,550 42 Add lines 40 and 4t ~" 42 4,744 I Head of 43 Foreign tax credit. Attach Form 1116 if required 43 household, 44 Credit for child and dependent care expenses. Attach Form 2441 ..... 44 $5,650 45 Credit for the eiderly or the disabled. Attach Schedule R 45 Married fi~ing 46 Education credits. Attach Form 8853 46 ointty or Quaflfying 47 Rate reduction credit. See the worksheet ........... 47 widow(er), 48 Child tax credit (see instructions) 48 $7,600 49 Adoption credit, Attach Form 8839 ................... 49 Married filing 50 Other credits from a ~] Form 3800 b [] Form 8396 separately, c [] Form 8801 d L.J Form (specify) 50 ~31~0 51 Add lines 43 through 50. These are your total credits 51 52 Subffactline5t from line 42.1f line 51 is more than line 42, enter-0- . .......... · 52 4,744 53 Self*employment tex Attach Schedule SE ............................................. 53 Other 54 Social security and Medicare tax on tip income not reported to employer. Attach Form 4137 54 Taxes SS Tax on qualified plans, including IRAs, and other tax-favored accounts. Attach Form 5329 if required ...... 55 56 Advance earned income credit payments from Form(s) W-2 ..................... 56 5-7 Household employment taxes. Attach Schedule H 5'7 58 Add lines 52-57. This is your total taa · 58 4,744 Payments 59 Federal income tax withheld from Forms W-2 and 1099 .... 59 6,852. if you have a I 60 ~0t estimated tax payments and amount applied from 2000 return ...... 60 qualifying -- 61 a Earned income credit (EIC) ................... 61 n child, attachF b Nontaxable earned income .... I 61 bf Schedule EIC. 62 Excess social security and RRTA tax withheld (see instrs) . 62 63 Additional child tax credit. Attach Form 8812 ......... 63 64 Amount paid with request for extension to fdo (see instructions) ....... 64 ~ Other payments. Check if from a [] Form 2439 b [] Form 4136 65 FDIA0112 12J10101 ~ Add lines 59, 60, 61a, and 62 through 65. These are your total ~ayments ................................ ~i 66 E,g52 Re'fund 67 if line 66 is more than line 58, subtract line 58 fram line 66 This is the amount you overpaid ......... 67 2, 1 08 Direct depostt7 68a Amount of line 67 you want mfund~:t to you ............................... · 68a 2,108 See instructions .~ b Routing number ..... 231381116 ~ cType: ~]Checking []Savings and fill in 68b, .- d Account number ..... 0451384341 68c, and 68d. 69 Amount of line 67 you want applied Amount 70 A~on.t yon owe. Subtract line 66 from line 5g, For details on bow to pay, see instructions .............. ~1 70 You Owe 71 Estimated tax penalb/, Also include on line 70 ............ I Third Party Designee Sign Here Joint retum? See instructions. Keep a copy for your records. Paid Preparer's Use Only Do you went to allow another person to discuss this return with the IRS (see instructions)? ....... [] Yes. Complete the following. [] No Designee's Phone Personal Identifica0on N~me ~' No. ~" Number (PIN) ~' ~=~S ~. Da. IChe~u if self-emplOYed n I Predator's SSN °r PTIN Firm*$Nameor ~umir Self-Prepared P,o,e No se ~Cmp oye~).k EIN Form 1040 (2001) 2001 Schedule A I Itemized Deductions ~ Attach to Form 1040. See Instructions for Schedule A (Form 1040). 07 Bradl. e J' Sanders 179-66-4680 Medical Caution. Do not include expenses reimbursed or paid by others1 and 1 Medica~ and dental expenses (see instructions) Dental Expenses 2 Enter amount from Form 1040, bne 34 ! $ Multipty line 2 ab.ore by 7.5% (.075) .............. 3 4 Subtract line 3 trom line 1. If line 3 is more than line 1, enter -0- ................ 4 Taxes You 5 State and local income taxes ................ 5 2,032. Paid 6 Real estate taxes (see instructions) ............... 6 1,422. (See 7 Personal property taxes ............................ 7 343. instructions.) 8 Other taxes. List type and amount ~' ............. 8 9 ~d-d I~n-e~'g-th-r~ug-h-8-.7. ~ i i i i ~ ~ ~7.1.7 7.T.7.7.7 7. 7 ~ 7~ ..................... s 3,797, Interest 10 Home mtg interest and points reported to YOu on Form 1098 .......... 10 14,883. You Paid 11 Home mortga{~e interest not repoded to you on Form 1098. If paid to the person from whom you bought the home, see instructions and show that person's name, identifying number, and address "' (See .............. instructions.) ................. Note. 11 Personal 1Z Points not reported to you on Form 1098. Sos instrs f0r upcl rules ......... 12 interest is not 13 Investment interest. Attacb Form 4952 if required, decluctible. (See inutrs,) 13 14 Add lines l0 through 13 .......................................................... 14 14,883 Gifts to 15 Gifts by cash or check. If you made any gift of $250 or more, Charity see instructions 15 350. )f you made 16 Other than by cash or check. If any gift of $250 or a gift and more. see instructions. You must attach Form 8283 if got a benefit over $5O0 16 420. for it, see instructions. 17 Carryover from prior year 17 18 Add lines 15 throu~jh 17 18 770 Casua~y-~ Theft Losses 19 Casualty' or theft loss(es). Attach Form 4684. (See instructions./ .................. 19 Job Expenses 20 Unreimbursed employee expenses - ob travel, union dues, arld~ job education, etc. You must attach Form 2106 or 2 06-EZ Other Miscellaneous if required. (See instructions,) Deductions 20 21 Tax preparation fees 21 4.5. Z2 Other expenses - investment, safe deposit box, etc. List (See instructions type and amount for expenses Hisce!.taneous ~_p~-e-s ........... ~(~0-. 22 500. to deduct ........................... here.) 23 Add lines 20 through 22 ............................ 23 $45. 24 Enter amount frDm Form 1040, line34 .... I. = 49. 854. 25 IV~ltiply line 24 above by 2% 002) ......................... 25 997. 26 Subtract line 25 from ~ine 23. ~f {ine 25 is more than line 23. enter -0- . .................. 26 0, Other 27 Other - trom list in the instructions, List type and amount ~' ................ Miscelleneous Total 28 Is Form 1040, line 34, over $132,950 (over $66,475 if MFS)? Itemized Deductions [] No, Your deduction is not limited. Add the amts in the far right col for lines 4 through 27. Also, enter this alt on Form 1040, line 36.~- ,~ 28 19,450, E~ Yes. Your deduction may be limited. See instructions for the amount to enter. __ BAA For Paperwork Reduction Act Notice, see ForTn 1040 instructions. FDIA0301 01107~)2 Schedule A (Form 1040) 2001 a co.~o~ .~m~ Copy B To Be Filed With Employee's SANB OMB No. ;s45-0008 FEDERAL Tax Return b Emplo3~' ;~.,,&'.~..~ number I w~s, Ups, ~ c~n~on 2 Federal income ~x withheld 23-15199~ ~ R5 ~R5~.~1 P 0 ~OX , 1453 s Medicare wages a~ tips 6 Medicare tax w~ld 5351~.2e 775.91 ~R~SBURG, PA 171~5-1453 7 S~l~ud~Ups 8 AIIocatedtips e Employ~'s fi~ na~ and inl~l Last ~me 11 Nonquafifl~ plans ~ 2a See instructions for box 12 B~LEY J S~DERS D ~ 32~8.35 2177 MERRI~C AVE ~4 ~r " INS 38.4~ ~C~ICSBURG, PA 17~55 ~2d I Statement 2001 Department of the Treasur~--lnternal Revenue Se~ice This information is being furnished to the Internal Revenue Service. BRADLEY J. SANDERS SANB UUDUU I 179-66-4680 Regular 80.00 2,307.20 FICA FED-M PA PEUC LOCAL K 6 176.50 2,855.23 318.05 4,615.29 64.60 1,044.99 0.00 0.00 23.07 373.22 138.43 Y-T-D PAY 35,083.06 Period: 08/27/01 - 09/09/01 Check #: BRADLEY J. SANDERS SANB Regular 80.00 2,307.20 6001 FICA FED-M PA PEUC LOCAL K 6 Net Pay: $1,586.55 006021 179-66-4680 176.50 3,031.73 318.05 4,933.34 64.60 1,109.59 0.00 0.00 23.07 396.29 138.43 Y-T-D PAY 37,251.83 Period: 09/09/01 09/22/01 Check #: BRADLEY J. SANDERS SANB Regular 80.00 2,307.2~ FICA FED-M PA PEUC LOCAL K 6 6021 Net Pay: $1,586.55 006041 179-66-4680 176.50 3,208.23 318.05 5,251.39 64.60 1,174.19 0.00 0.00 23.07 419.36 138.43  Y-T-D PAY 39,420.60 Period: 09/23/01 10/06/01 Check #: 6041 Ne% Pay: $1,586.55 i~ICA FED-R ~EUC LOCAL P: 2/2 ,006041 179-~6-468~ 176,5~ 3,2eS.a~ 318.~$ 5,251.3~ 64.6~ lrl?4,~ 23.07 ~19,36 138.43 Y'T-D PAY 10/96/9I Check BRADLEY J. SANDERS SANB UUbUb'l 179-66-4680 Regular 80.00 2,307.20 FICA FED-M PA PEUC LOCAL K 6 176.50 3,384.7~ 318.05 5,569.44 64.60 1,238.7~ 0.00 0.0~ 23.07 442.4~ 138.43 Y-T-D PAY 41,589.37 Period: 10/07/01 10/20/01 Check #: 6061 Ne% Pay: $1,586.55 BRADLEY J. SANDERS SANB 179-66-4680 Regular 80.00 2,307.20 FICA FED-M PA PEUC LOCAL K 6 176 50 3,561.2~ 318 05 5,887.47 64 60 1,303.3E 0 00 0.0¢ 23 07 465.5~ 138 43 Y-T-D PAY 43,758.14 Per~od: 10/22/01 11/04/01 Check #: BRADLEY J. SANDERS SANB Regular 80.00 2,307.20 6081 FICA FED-M PA PEUC LOCAL K 6 Ne% Pay: $1,586.55 006101 179-66-4680 176.50 3,737.7~ 318.05 6,205.5l 64.60 1,367.9! 0.00 0,0~ 23.07 488.5' 138.43 Y-T-D PAY 45,926.91 Per~od: 11/05/01 11/18/01 Check #: 6101 Net Pay: $1,586.55 UUOI/I BRADLEY J. SANDERS SANB_i ~-~- ~:..'. -. -_~.~ "S~- Regular 80.00' 2,307.20 FICA !75 FED-M PA PEUC LOCAL 23 K 6 SUP 2,914.2 1,432~5 ~I1. f, Y-T-D PAY 48,095.68 Period: 14 /~ ' ~' ~ ~ ' · ~ ~9/¢1 ~=,. ¢~,, ¢~ Check #: 6121 '' 331.17 BRADLEY J. SANDERS SANB 006140 179-66-4680 Regular 80.00 INS 2,307.20 FICA 179.44 4,093.67 FED-M 328.42 6,852.01 PA 64.60 1,497.19 PEUC 0.00 0.00 38.40 LOCAL 23.07 534.71 K 6 138.43 SUP 205.38 Y-T-D PAY 50,302.85 Period: 12/03/01 - 12/16/01 Check #: 6140 Net Pay: $1,367.86 BRADLEY J. SANDERS SANB 179-66-4680 Regular 80.00 2,307.20 FICA FED-M PA PEUC LOCAL K 6 SUP OPT Y-T-D PAY 2,168.77 Period: 12/16/01 12/29/01 Check #: 6161 176 50 318 05 64 60 0 00 23 07 138 43 161 54 10 00 Net Pay: 176.50 318.05 64.60 0.00 23.07 S~,415.01 UUbl UU Regular 80.00 2,307.20 FICA 176 FED-M 318 PA 64 PEUC 0 LOCAL 23 K 6 138 SUP 161 50 353.00 05 636.10 60 129.20 00 0.00 07 46.14 43 54 Period 12/31/01 - 01/1~/02 ~ ' Check #: BRADLEY J. SANDERS SANB 6180 Net Pay: $1,425.01 0061 99 179-66-4680 Regular 80.00 2,307.20 FICA FED-M PA PEUC LOCAL K 6 SUP 176.50 529.50 287.36 923.46 64.60 193.80 0.00 0.00 23.07 69.21 138.43 161.54 Y-T-D PAY 6,506.31 Period: 01/14/02 01/27/02 Check #: ANDREW S, McCREATH &SON, INC, HARRISBURG, PA 17105 BRADLEY J. SANDERS SANB 6199 Net Bay: $1,455.70 006218 179-66-4680 Regular 80.00 2,307.20 FICA FED-M PA PEUC LOCAL K 6 SUP 176.50 706.00 287.36 1,210.82 64.60 258.40 0.00 0.00 23.07 92.28 138.43 161.54 Y-T-D PAY 8,675.08 Period: 01/28/02 02/10/02 Check #: 6218 Ne% Pay: S1,455.70 ANDREW S. McCREATH & SON, INC. HARRISBURG, PA 17105 ,006271 179-66-4680 ' Regula : 80.00 2,307.20 [ FICA 176.50 1,235.50 FED-s 142.91 1,639.55 PA 64.60 452.20 PEUC 0.00 0.00 LOCAL 23.07 161.49 K 6 138.43 SUP 161.54 Y-T-D PAY 15,181.39 Period: 03/11/02 - 03/24/02 Check #: 6271 Net Pay: $1,600.15 T~EMENT OF EARNINGS AND DEDUCTIONS ' DETACH AND RE~IN FOR YOUR RECORDS ANDREW S. McCREATH & SON, INC. HARRISBURG, PA 17105 BRADLEY J. SANDERS. , 006290 179-66-4680 ' Regular 80.00 2,307.20 FICA FED-s PA PEUC LOCAL K 6 SUP 176.50 1,412.00 142.91 1,782.46 64.60 516.80 0.00 0.00 23.07 184.56 138.43 161.54 Y-T-D PAY 17,350,16 6290 Period: 03/25/02 - 04/07/02 Check #: '~EMENT OF EARNINGS AND DEDUCTIONS ' DETACH AND RETAIN FOR YOUR RECORDS Pay: $1,600.15 SANDERS .UUSFS/ 179-66-4680 ' ReC~ i,~I ~0 "2,307:20 FICA 176.50 882.50 FED-s 142.91 1,353.73 PA 64.60 323.00 PEUC 0.00 0.00 LOCAL 23.07 115.35 K 6 138.43 SUP 161.54 Y-T-D PAY 10,843,85 6237 Ne% Pay: $1,600.15 Period: 02/10/02 - 02/23/02 .. Check #: ANDREW S. McCREATH & SON, INC. HARRISBURG, PA 17105 BRADLEY J. SANDERS ........ ~'~' ,:'~ .006252 179-66-4680 Regular 80.00.:;: 2,307.20 FICA 176.50 1,059.00 · FED-s 142.91 1,496.64 PA 64.60 387.60 PEUC 0.00 0.00 LOCAL 23.07 138.42 K 6 138.43 SUP 161.54 Y-T-D PAY 13,012.62 6252 Net Pay: $1,600.15 Period: 02/24/02 - 03/09/02 Check #: FEMENT OF EARNINGS AND DEDUCTIONS · DE'CH AND RETAIN FOR YOUR RECORDS 3.25.02. BRAD SANDERS. PRE-TRIAL STATEMENT./ REVISED 4.9.02./ REVISED 4.16.02. · Oimm BRADLEY SANDERS, Plaintiff Vo ALISON SANDERS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-5654 : : CIVIL ACTION - LAW : DIVORCE PLAINTIFF' S PRE-TRIAL STATEMENT Plaintiff, BRADLEY SANDERS, by his attorJey, Diane G. Radcliff, files this Pre-Trial Statement. TABLE OF CONTENTS I. BACKGROUND INFORMATION 2-4 II. LISTING OF MARITAL ASSETS AND DEBTS 5-8 III. LISTING OF PERSONAL PROPERTY 9-13 IV. LISTING OF MARITAL DEBTS 14-15 V. PENSIONS 16 VI. LISTING OF NON-MARITAL ASSETS AND DEBTS 17 VII. INCOMES AND EXPENSES 18-22 VIII. COUNSEL FEES AND COSTS 23 IX. EXPERT WITNESSES 24 X. OTHER WITNESSES 24 XI. PROPOSED RESOLUTION 25 XII. PROPOSED EXHIBITS 26-END Esquire DATED: Respectfully_~ul!bmitted, 34~8 Trindle ~oad Ca'l~J~=~_~, 17011 Phone: (~7) 737-0100 Supreme Court ID # 32112 Attorney for Plaintiff Page 1 3.25.02. BRAD SANDERS. PRE-TRIAL STATEMENT REVISED 4.9.02. I. BACKGROUND INFORMATION A. P~TIES: Mechanicsburg, PA 17055 ~AT~ ~ ~R~ March 29, 1970 Alamogordo, NM 179-66-4680 Good A.S. McCreath Since 3 months of age BS in Biology from Clarion University NAM Alison M. Sanders ADDRESS 208 Louisa Drive Mechanicsburg, PA 17050 AGE 31 DATE OF BIRTH December 27, 1970 PLACE OF BIRTH Elizabeth, PA SOCI~ SECURITY NUMEE~ 192-56-5174 HEALTH , Good EMPLOYER Simplex Time Recorder Co. OCCUPATION Office Supervisor LENGTH OF RESIDENCY IN PA All life EDUCATIONAL BACKGROUND BS in Business Administration from Clarion University Page 2 3.25.02. BRAD SANDERS. PRE-TRIAL STATEMENT/ REVISED 4.9.02. B. CHILDREN OF THIS MARRIAGE: None C. MARRIAGE INFORMATION: September 25, 2001 Wife left; Wife has been having an affair D. PRIOR MARRIAGES: i HUDB~ None E. CHILDREN OF OTHER RELATIONSHIPS/MARRIAGES: None Page 3 3.25.02. BRAD SANDERS. PRE-TRIAL STATEMENT/ REVISED 4.9.02./ REVISED 4.16.02. F. PROCEEDINGS INFORMATION: PLAINTIFF: Bradley J. Sanders DEFENDANT: Alison M. Sanders DATE ACTION COMMENCED: September 27, 2001 DATE OF SERVICE OF COMPLAINT: October 5, 2001 MANNER OF SERVICE OF COMPLAINT: Certified Mail, Restricted Delivery ISSUES RAISED IN DIVORCE COMPLAINT: 3301(c) divorce DATE OF FILING OF AMENDED COMPLAINT: March 28, 2002 ISSUES RAISED IN AMENDED COMPLAINT: 'Divorce on grounds of no-fault; indignities; adultery; and Equitable Distribution DATE OF FILING OF ANSWER AND/OR ANSWER AND October 22, 2001 COUNTERCL4~IM: ISSUES RAISED IN COUNTERCLAIM: Equitable Distribution, Injunction from Dissipation of Marital Property, Counsel Fees, Costs and Expenses, Spousal Support, Alimony Pendente Lite, Permanent Alimony, Insurance and Other Benefits DATE OF FILING OF ANSWER TO AMENDED COMPLAINT IN DIVORCE AND COUNTERCLAIM ISSUES RAISED IN ANSWER TO AMENDED COMPLAINT Equitable Distribution, IN DIVORCE AND COUNTERCLAIM Injunction from Dissipation of Marital Property, Counsel Fees, Costs and Expenses, Spousal Support, Alimony Pendente Lite, Permanent Alimony, Insurance and Other Benefits TYPE OTHER PLEADING RAISING ECONOMIC CLAIMS: None DATE OF FILING OF OTHER PLEADING RAISING None ECONOMIC CLAIMS ISSUES RAISED IN OTHER PLEADING RAISING None ECONOMIC CLAIMS: BIFURCATION AND DATE OF DECREE None PREVIOUSLY RESOLVED ISSUES None Page 4 3.25.02. BRAD SANDERS. pRE-TRIAL STATEMENT/ REVISED 4.9.02. II. MARITAL ASSETS AND DEBTS THE FOLLOWING IS A LISTING OF THE MARITAL ASSETS AND DEBTS OF THE PARTIES: NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION LIABILITY LIABILITY TO HUSBAND TO WIFE Ave., Washington Est. (213,500.00) Mutual Mortgage NET EQUITY 6,500.00 6,500.00 6~ 500.00 A Wife's 1995 2.02 3,500.00 Eagle Vision TSI Vehicle loan 0.00 Net value 3,500.00 3'500'00 I I 3,500.00 B Husband's 2000 3.10.02 16,880.00 Ford F-150 4x4 Husband's Ford (15,846.38) Motor Credit Vehicle Loan Net value 1,033.62 1,033.62 I 1,033.62 I Page 5 3.25.02. BRAD SANDERS. PRE-TRIAL STATEMENT/ REVISED 4.9.02. NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION LIABILITY LIABILITY TO HUSBAND TO WiFE A Joint PSECU 9.10.01 31.45 31.45 31.45 account B Wife's checking Est. 2,900.00 2,900.00 2,900.00 account A Joint PSECU 9.14.01 217.00 217.00 117.00 100.00 savings account A Husband's 9.30.01 12,028.82 Prudential 401K Plan Pre-marital 12.31.94 (2,678.68) value of 401K Net value 9,350.14 9,350.14 I 9,350.14 I B Wife's Fidelty 6.30.01 14,620.90 14,620.90 14,620.90 401K Plan Page 6 3.25.02. BRAD SANDERS. PRE-TRIAL STATEMENT/ REVISED 4.9.02./ REVISED 4.16.02. NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED PROPERTY OR VALUE ASSET OR DiSTRiBUTION DISTRIBUTION LIABILITY LIABILITY TO HUSBAND TO WIFE A Husband's Est. 4,980.00 4,980.00 4,980.00 Household Goods C~en~S: The B wife's Household Est. 13,905.00 13,905.00 13,905.00 Goods A Universal Card 9.14.01 {869.24) (869.24) (869.24) B UniVerSal card 10 12 01] (195.02) (195.02) (195.02) c Discover Card 9.25.01I (36.29)I (36'29)I (36'29)I ~ wife's airline 3.1.02. (194.00) (194.00) (194.00) tickets charged on joint credit card Page 7 3.25.02. BRAD SANDERS. PRE-TRIAL STATEMENT/ REVISED 4.9.02./ REVISED 4.16.02. NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION LIABILITY LIABILITY TO HUSBAND TO WIFE A September 9.25.01 (1,753.15) (1,753.15) (1,753.15) mortgage payment B Husband's truck 9.25.01 (285.60) (285.60) (285.40) payment C Sewer bill for 9.25.01 (100.00) (100.00) (100.00) July - September 9.28.01 I (44.69) (44.69) (44.69) D UGI balance TOTAL OF ASSETS AND LIABILITIES 55,653.01 18,296.02 37,357.19 Totals from above 55,653.01 18,296.02 37,357.19 Amount Due in 50/50 Division 27,826.51 27,826.51 Adjustment Figure 9,530.49 (9,530.69) NOTES: 1. Page 8 3.25.02. BRAD SANDERS. PRE-TRIAL STATEMENT/ REVISED 4.9.02. III. LISTING OF PERSONAL PROPERTY ~WING IS A LISTING OF THE PERSONAL PROPERTY OF THE PARTIES: 1 Engagement Wife $7,015.00 Appraised value Appraisal ring is $7,015.00 2 Futon Wife $300.00 $637.00 new Estimate value 3 Computer Wife $100.00 $250.00 new Estimate desk and value chair 4 Bookcase Wife $50.00 $200.00 new Estimate value 5 Jewelry Wife $100.00 $200.00 new Estimate armoire value 6 Full length Wife $90.00 $100.00 new Estimate cheval value mirror 7 Lingerie Wife $450.00 $900.00 new Estimate Chest value 8 Floor lamp Wife $50.00 $100.00 new Estimate value 9 Stereo rack Wife $500.00 $1000.00 new Estimate system value 10 All CD's Wife $150.00 $500.00 new Estimate value 11 TV from Wife $50.00 $200.00 new Estimate bedroom value 12 All Wife $250.00 $500.00 new Estimate Pfaltzgraf value dishes 13 All crystal Wife $100.00 $200.00 new Estimate ware value Page 9 3.25.02. BRAD SANDERS. PRE-TRIAL STATEMENT/ REVISED 4.9.02. 14 Ail Wife $60.00 $120.00 new Estimate silverware value 15 All glasses Wife $20.00 $40.00 new Estimate value 16 Longaberger Wife $750.00 $750.00 new Estimate baskets value 17 2 bakers Wife $125.00 $250.00 new Estimate racks value 18 Vacuum Wife $50.00 $200.00 new Estimate cleaner value 19 Mop & bucket Wife $5.00 $20.00 new Estimate & broom value 20 Mirror - Wife $60.00 $60.00 new Estimate Home value Interiors 21 Wall Wife $250.00 $500.00 new Estimate decorations value Paintings, prints, pictures, etc. 22 Computer & Wife $200.00 $600.00 new Estimate monitor value 23 Color inkjet Wife $100.00 $200.00 new Estimate printer value 24 Camera Wife $100.00 $200.00 new Estimate value 25 Crystal Wife $100.00 $300.00 new Estimate vases value 26 Knives Wife $50.00 $100.00 new Estimate value 27 Printer Wife $40.00 $80.00 new Estimate stand value 28 Iron & Wife $20.00 $60.00 new Estimate ironing value board 29 Telephones Wife $75.00 $150.00 new Estimate (2) value Page 10 3.25.02. BRAD SANDERS. PRE-TRIAL STATEMENT/ REVISED 4.9.02. 30 Digital Wife $50.00 $100.00 new Estimate answering value machine 31 Portable Wife $40.00 $70.00 new Estimate stereo value 32 Some pots & Wife $25.00 $100.00 new Estimate pans value 33 Household Wife $100.00 $100.00 new Estimate supplies value 34 Electric Wife $30.00 $80.00 new Estimate mixer value 35 Food Wife $50.00 $120.00 new Estimate processor value 36 Twin Wife $150.00 $300.00 new Estimate mattress value; Used for guests only; 6 times 37 Ail jewelry Wife $2,250.00 $4,500.00 new Receipts and (excluding value estimate engagement ring} 38 Plum sofa, Wife N/A husband has not Receipts love seat, inserted a chair, end value since tables, and wife is paying coffee table purchase debt equal to value. SUBTOTAL FOR WIFE $13,905.00 Page 11 3.25.02. BP~AD SANDERS. PRE-TRIAL STATEMENT/ REVISED 4.9.02. 39 Amish table Husband $800.00 $2,187.00 new Estimate & chairs value 40 Couch Husband $300.00 $800.00 new Estimate value 41 2 recliners Husband $300.00 $800.00 new Estimate value 42 Sunroom Husband $400.00 $1,252.00 new Estimate furniture value 43 Patio set Husband $100.00 $200.00 new Estimate value 44 Bedroom set Husband $800.00 $2,500.00 new Estimate value; 8 years old 45 Refrigerator Husband $500.00 $1,000.00 new Estimate value 46 Washer/Dryer Husband $400.00 $800.00 new Estimate value 47 Grill Husband $100.00 $525.00 new Estimate value 48 Lawn mower Husband $100.00 $400.00 new Estimate value 49 Pots & pans Husband $50.00 $150.00 new Estimate value 50 TV Husband $100.00 $600 new value; Estimate 8 years old 51 VCR Husband $30.00 $80 new value Estimate 52 Weedwacker Husband $50.00 $180 new value; Estimate 3 years old; heavily used 53 Garden Husband $50.00 Estimate accessories Page 12 3.25.02. BRAD SkNDERS. PRE-TRIAL STATEMENT/ REVISED 4.9.02. 54 Guns: Husband $900.00 $1600 new value Estimate Rem. 700 Rem. SP12 Sig Sauer P29 SUBTOTAL FOR HUSBAND $4,980.00 Page 13 3.25.02. BRAD SANDERS. PRE-TRIAL STATEMENT/~REVISED 4.9.02./ REVISED 4.16.02. IV. MARITAL DEBTS THE FOLLOWING IS INFORMATION PERTAINING TO THE PARTIES' MARITAL DEBTS: Universal Credit card 2001 869.24 869.24 869.24 Card Universal card Credit card 2001 195.02 195.02 195.02 Discover Credit card 2001 36.29 36.29 36.29 Card Discover Card Wife's airline tickets Credit card 2001 179.84 179.84 179.84 Credit card 2.02 194.00 194.00 194.00 Washington Mortgage 10.1/01 Mutual against marital home 213,500.00 213,500.00 Husband paying $1,764.51 per month since separation Page 14 3.25.02. BRAD SANDERS. PRE-TRIAL STATEMENT/ REVISED 4.9.02./ REVISED 4.16.02. I 10 UGI Gas bill 8/29/01- 44.69 44.69 Husband paid for 9/28/01 this bill. 8/29/01- 11 PP&L Electric 8/14/01- 58.56 58.56 Husband paid bill from 9/13/01 this bill. 8/14/01- 12 Wells Fargo Mortgage 9/01 1V53.iS 1753.iS Husband paid payment for this bill. September Page 15 3.25.02. BRAD SANDERS. PRE-TRIAL STATEMENT/ REVISED 4.9.02./ REVISED 4.16.02. V. PENSIONS AND RETIREMENT BENEFITS THE FOLLOWING IS A LISTING OF THE PENSIONS AND RETIREMENT PLANS OF THE PARTIES: Page 16 3.25.02. BRAD SANDERS. PRE-TRI_AL STATEMENT/ REVISED 4.9.02. VI. NON-MARITAL ASSETS AND DEBTS THE FOLLOWING IS A LISTING OF THE NON-MARITAL ASSETS AND DEBTS OF THE PARTIES: S&W shotgun H H H H 100.00 Pre-marital; $400.00 new value REM 30.06 rifle 300.00 Pre-marital; $350.00 new value Page 17 3.25.02. BRAD SANDERS. PRE-TRIAL STATEMENT/ REVISED 4.9.02. VII. INCOME AND EXPENSES THE FOLLOWING IS A LISTING OF THE INCOMES AND EXPENSES OF THE PARTY (PARTIES): A. EMPLOYMENT INFORMATION: EMPLOYER: A. S McCreath & Sons, Inc. ADDRESS: P.O. Box 1453, Harrisburg, PA 17105 POSITION: Chemist PAYROLL NUMBER: 179664680 SANB PAY PERIOD: Bi-weekly GROSS PAY PER PAY PERIOD 2,307.20 2,307.20 FICA OR SE TAX 176.50) {176.50) MEDICARE OR SE TAX FEDERAL TAX 287.36) (287.36) STATE TAX (64.60) (64.60) LOCAL TAX (23.07) {23.07} MANDATORY RETIREMENT UNION DUES HEALTH INSURANCE VOLUNTARY RETIREMENT 138.43) OTHER: APL 161.54) TOTAL DEDUCTIONS 851.50) (551.53) NET PAY PER PAY PERIOD 1,455.70 1,755.67 NET PAY PER MONTH 3,154.02 3,803.95 Page 18 3.25.02. BRAD SANDERS. PRE-TRIAL STATEMENT/ REVISED 4.9.02./ REVISED 4.16.02. D. OTHER INCOME: INTEREST 7.08 85.00 DIVIDENDS PENSIONS ~uNNUITIES SOCIAL SECURITY RENTS ROYALTIES EXPENSE ACCOUNT GIFTS UNEMPLOYMENT COMPENSATION WORKMAN'S COMPENSATION INCOME TA3( REFUNDS FOR 2001 TAX YEAR 175.66 2,108.00 SUPPORT OR ALIMONY COMMISSIONS TIPS OTHER SPECIFY: TOTA~ OTHER INCOHE $182.74 $2,193.00 Page 19 3.25.02. BRAD SAArDERS. PRE-TRIAL STATEMENT/ REVISED 4.9.02. PART II. EXPENSES DESCRIPTION WEEKLY MONTHLY ANNUAL AMOUNT AMOUNT AMOUNT First Mortgage $407.19 $1,764.51 $21,174.12 $1,438.39 P&I ~326.12 escrows ($40.50 ins.; $241.00 taxes; $48.04 PMI) Second Mortgage/Home Equity Loan Maintenance And Repairs $11.54 $50.00 $600.00 Electric $17.31 $75.00 $900.00 Gas $21.92 $95.00 $1,140.00 Oil Telephone $11.54 $50.00 $600.00 Water $3.75 $16.25 $195.00 Sewer $7.69 $33.33 $399.96 Trash $2.69 $11.66 $139.92 Public Transportation Lunches $10.00 $43.33 $519.96 Other Employment Expenses Real Estate Taxes Personal Property Taxes $0.19 $0.82 $9.84 Per Capita/Occupation Taxes $5.84 $25.32 $303.84 Homeowners Insurance Automobile Insurance $11.75 $50.92 $611.04 Life Insurance Accident Insurance Page 20 3.25.02. BRAD SANDERS. PRE-TRIAL STATEMENT/ REVISED 4.9.02. DESCRIPTION WEEKLY MONTHLY ANN~AL AMOUNT AMOUNT AMOUNT Health Insurance Other Insurance Specify: Payments $100.23 $434.35 $5,212.20 Fuel $23.00 $99.66 $1,195.92 Maintenance And Repair $9.62 $41.67 $500.04 License And Registration $1.56 $6.75 $81.00 Doctor Optical Dental Orthodontic Hospital Medicine Special Needs/Therapy Private School Parochial School College/Vocational Religious Training or Education Books/Fees And Supplies Other Educational Expense s Clothing Food Barber And Hair Dresser Memberships $2.31 $10.00 $120.00 $1.92 $8.33 $99.96 $1.15 $5.00 $60.00 $15.39 $92.31 $2.31 $0.69 $66.67 $800.04 $400.00 $4,800.00 $10.00 $120.00 $3.00 $36.00 Page 21 3.25.02. BRAD SANDERS. PRE-TRIAL STATEMENT/ REVISED 4.9.02. DESCRIPTION WEEKLY MONTHLY ANNUAL AMOUNT AMOUNT AMOUNT Household Help Child Care Newspaper/Magazines/Books Entertainment $11.54 $50.00 $600.00 Pay TV Vacations $19.23 $83.33 $999.96 Gifts $9.61 $41.66 $499.92 Legal Fees $76.92 $333.33 $3,999.96 Charitable Contributions Other Child Support (not the subject of this action) Other Spousal Support or Alimony (not the subject of this action) TOTAL EXPENSES $879.21 $3,809.89 $45,718.68 Page 22 3.25.02. BRAD SANDERS. PRE-TRIAL STATEMENT/ REVISED 4.9.02. VIII. COUNSEL FEES THE FOLLOWING IS A LISTING OF THE COUNSEL FEES AND EXPENSES INCURRED BY THE FILING PARTY IF A CLAIM HAS BEEN MADE FOR COUNSEL FEES AND COSTS: costs are billed at actual cost Hourly rate for estimated 15 hours and actual cost for any pending appraisals NO CLAIM HAS BEEN RAISED BY PLAINTIFF FOR COUNSEL FEES AND THEREFORE NO INFORMATION IS PROVIDED. Page 23 3.25.02. BRAD SANDERS. PRE-TRIAL STATEMENT/ REVISED 4.9.02. IX. EXPERT WITNESSES THE FOLLOWING IS A LISTING OF THE EXPERTS W'HO THE PARTY INTENDS TO CALL TO TESTIFY IN THIS CASE: **Experts who may be There is a reservation of notification to the other and retained. called to testify are not known at this time. the right to call expert witnesses upon proper party once those expert witnesses are identified X. OTHER WITNESSES THE FOLLOWING IS A LISTING OF THE ANTICIPATED WITNESSES OTHER THAN EXPERTS WHO WILL BE CALLED TO TESTIFY IN THIS CASE: **Additional witnesses who may be called to testify are not known at this time. There is a reservation of the right to call additional witnesses upon proper notification to the other party once those witnesses are identified and agree to testify. Page 24 3.25.02. BRAD SANDERS. PRE-TRIAL STATEMENT/ REVISED 4.9.02./ REVISED 4.16.02. XI. PROPOSED RESOLUTION THE FOLLOWING IS THE PLAINTIFF'S POSITION REGARDING RESOLUTION OF THE ECONOMIC ISSUES PRESENTED IN THIS CASE: DIVORCE: A divorce decree should be entered divorcing the parties. EOUITABLE DISTRIBUTION: The parties' marital assets and debts should be divided and distributed in accordance with the schedule set forth on Section II of this Pre- Trial Statement. ALIMONY: Wife's claim for alimony should be length of marriage and cohabitation. denied in light of her earnings, INS~CE ~ OTHER BENEFITS: Wife's claim for insurance and other benefits should be denied. Page 25 3.25.02. BRAD SANDERS. PRE-TRIAL STATEMENT/ REVISED 4.9.02. XII. PROPOSED EXHIBITS THE FOLLOWING IS A LISTING THE PROPOSED EXHIBITS TO BE SUBMITTED AT THE HEARING IN THIS CASE. EXHIBITS ARE ATTACHED OR TO BE SUPPLIED AS INDICATED BELOW. THERE IS A RESERVATION OF THE RIGHT TO SUBMIT ADDITIONAL EXHIBITS UPON PROPER NOTIFICATION TO THE OTHER PARTY. X X X X X X TO be supplied by wife X X To be supplied by wife X X X X 9.30.01 statement to be supplied by wife X Appraisal to be performed if values are in dispute X 3.25.02. BRAD SANDERS. PRE-TRIAL STATEMENT/ REVISED 4.9.02. 17 Universal Card statement X 18 Discover Card statement X 19 Discover Card statement X 20 Wife's airline ticket statement X 21 Mortgage payment statement TO be supplied if in dispute 22 Truck payment statement To be supplied if in dispute 23 Sewer bill X 24 UGI bill X 25 PP&L bill X 3.25.02. BRAD SANDERS. PRE-TRIAL STATEMENT/ REVISED 4.9.02. SANCTIONS Under Rule 1920.33(c) it is provided that if a party fails to file either an Inventory as required by subdivision (a) or a Pre-Trial Statement as required by subdivision (b), the Court may make an appropriate Order under Rule 4019(c) governin§ sanctions. Under Rule 1920.33(d) (i) a party who fails to comply with the requirement of subdivision (b) of this Rule (the filing of a Pre-Trial Statement with the information set forth in subparagraph (b)) shall, except upon good cause shown, be barred from offering any testimony or introducing any evidence in support of or opposition to the claims for the matters not covered therein. Under Rule 1920.33(d) (ii) a party shall, except upon good cause shown, be barred from offering any testimony or introducing any evidence that is inconsistent with or which goes beyond the fair scope of the information set forth in the Pre-Trial Statement. Page 2 8 3.25.02. BRAD SANDERS. PRE-TRIAL STATEMENT/ REVISED 4.9.02. CERTIFICATE OF SERVICE AND NOW, this¢ x , day of ~ 1%h this RADCLIFF, ESQUIRE, hereby certify that ave ' day served a I, DIANE G. copy of the within Pre-Trial Statement, by mailing same by first class mail, postage prepaid, addressed as follows: Scott Lautner, Esquire 68 Old Clairton Road Pittsburgh, PA 80134 Phone: (717) 737-0100 Fax: (717) 975-0697 Page 29 3.9.02/Revised 3.2$.02/Revzse~ 4.12.u~/£n¢0me a ~xpense Bradley J. Sanders BRADLEY SANDERS, ALISON SANDERS, AMENDED Plaintiff Defendant NO. 01-5654 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE INCOME AND EXPENSE STATEMENT OF BRADLEY J. SANDERS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA I verify that the facts set forth in the foregoing Income and Expenses Form, including all attachments thereto, are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. BRADLEY J. SANDERS Plaintiff's Exhibit 1 Husband's Income & Expense Statement 3.9.02. Income & Expense Bradley J. Sanders PART I. INCOME A. EMPLOYMENT INFORMATION: EMPLOYER: A. S McCreath & Sons, Inc. ADDRESS: P.O. Box 1453, Harrisburg, PA 17105 POSITION: Chemist PAYROLL NUMBER: 179664680 SANB PAY PERIOD: Bi-weekly B. EMPLOYMENT INCOME: GROSS PAY PER PAY PERIOD 2,307.20 2,307.20 ITEMIZED DEDUCTIONS FICA OR SE TAX (176.50) (176.50) MEDICARE OR SE TAX FEDERAL TAX (287.36) (287.36 STATE TAX (64.60) (64.60) LOCAL TAX (23.07) (23.07) MANDATORY RETIREMENT UNION DUES HEALTH INSUP_ANCE ~ ~ VOLUNTARY RETIREMENT (138.43) ~~ l OTHER: APL (161.54) l TOTAL DEDUCTIONS (851.50) (551.53) NET PAY PER PAY PERIOD 1,455.70 1,755.67 NET PAY PER MONTH 3,154.02 3,803.95 - 2 3.9.02/Revlsed 3,25.02/Revlsed 4.12.02/Income & Expense Bradley J. Sanders D. OTHER INCOME: DESCRIPTION MONTHLY YEARLY INTEREST 7.08 85.00 DIVIDENDS PENSIONS A/qNUITIES SOCIAL SECURITY RENTS ROYALTIES EXPENSE ACCOUNT GIFTS UNEMPLOYMENT COMPENSATION WORKMAN'S COMPENSATION INCOME TAX REFUNDS 175.66 2,108.00 SUPPORT OR ALIMONY COMMISSIONS TIPS OTHER SPECIFY: TOTAL OTHER INCOME $182.74 $2,193.00 3.9.02. Income & Expense Bradley J. Sanders PART II. EXPENSES DESCRIPTION WEEKLY MONTHLY ANNUAL AMOUNT AMOUNT AMOUNT Rent First Mortgage $407.19 $1,764.51 $21,174.12 $1,438.39 P&I $326.12 escrows ($40.50 ins.; $241.00 taxes; $48.04 PMI) Second Mortgage/Home Equity Loan Maintenance And Repairs $11.54 $50.00 $600.00 Electric $17.31 $75.00 $900.00 Gas $21.92 $95.00 $1,140.00 Oil Telephone $11.54 $50.00 $600.00 Water $3.75 $16.25 $195.00 Sewer $7.69 $33.33 $399.96 Trash $2.69 $11.66 $139.92 Public Transportation Lunches $10.00 $43.33 $519.96 Other Employment Expenses Real Estate Taxes $55.62 $241.00 $2,892.00 Personal Property Taxes $0.19 $0.82 $9.84 Per Capita/Occupation $5.84 $25.32 $303.84 Taxes 3.9.02. Income & Expense Bradley J. Sanders DESCRIPTION WEEKLY MONTHLY ANNUAL AMOUNT AMOUNT AMOUNT Homeowners Insurance $9.35 $40.50 $486.00 Automobile Insurance $11.75 $50.92 $611.04 Life Insurance Accident Insurance Health Insurance Other Insurance Specify: Payments $100.23 $434.35 $5,212.20 Fuel $23.00 $99.66 $1,195.92 Maintenance And Repair $9.62 $41.67 $500.04 License And Registration $1.56 $6.75 $81.00 Doctor Optical Dental $2 .31 $1.92 $10.00 $120.00 $8.33 $99.96 Orthodontic Hospital Medicine $1.15 $5.00 $60.00 Special Needs/Therapy Private School Parochial School - 5 - 3.9.02. Income & Expense Bradley J. Sanders DESCRIPTION WEEKLY MONTHLY ANNUAL AMOUNT AMOUNT AMOUNT College/Vocational Religious Training or Education Books/Fees And Supplies Other Educational Expen ses Clothing $15.39 $66.67 $800.04 Food $92.31 $400.00 $4,800.00 Barber And Hair Dresser $2.31 $10.00 $120.00 Memberships $0.69 $3.00 $36.00 Other Personal Expenses Specify: Household Help Child Care Newspaper/Magazines/Books Entertainment $11.54 $50.00 $600.00 Pay TV Vacations $19.23 $83.33 $999.96 Gifts $9.61 $41.66 $499.92 Legal Fees $76.92 $333.33 $3,999.96 Charitable Contributions - 6 - 3.9.02. Income & Expense Bradley J. Sanders DESCRIPTION WEEKLY MONTHLY ANNUAL AMOUNT AMOI/NT AMOUNT Other Child Support (not the subject of this action) Other Spousal Support or Alimony (not the subject of this action) TOTAL EXPENSES $944.17 $4,091.39 $49,096.68 - 7 - 3.9.02. Income & Expense Bradley J. Sanders PART III. PROPERTY OWNED TYPE DESCRIPTION VALUE H W JT Checking PSECU $180.00 X Savings PSECU $24.86 X Credit Union Stocks/bonds Real Estate Other See Plaintiff's Inventory PART IV. INSURANCE TYPE COMPANY POLICY NO. H W C Hospital/Blue Blue Cross ABD179664680 X X Cross Group 601965000 Medical/Blue Blue Shield BS Plan 865 X X Shield BC Plan 361 Health Accident Disability Income Dental Vision Other-Specify *H=Husband; W=Wife; J=Joint; C=Child - 8 3.9.02. Income & Expense Bradley J. Sanders (a) (b) (c) PART V. SUPPLEMENTAL INCOME STATEMENT [X] CHECK HERE IF NOT APPLICABLE This form is to be filled out by a person: (1) Who operates a business 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. Attach to this statement a copy of the following documents relating to the partnership, joint venture, business, profession, corporation or similar entity (check block to indicate the document is attached): {1) The most recent Federal Income Tax Return. [ ] attached (2) The most recent Profit and Loss Statement. [ ] attached Name of Business: Business Address: Business Telephone: (d) Nature of Business (check one) [ ] 1. Sole Proprietorship [ ] 2. Partnership [ ] 3. Joint Venture [ ] 4. Professional [ I 5. Corporation [ ] 6. Other (e) Name of accountant, controller or other person in charge of financial records: (f) Business Income: 1. Annual income from business: 2. How often is income received: 3. Gross income per pay period 4. Net income per pay period 5. Specify deductions, if any: - 9 - ~'~'~ ~. o~u~um~ SANB 179-66'4680 Regular 80.00 2,307.20 FICA 176.50 2,855.23 FED-M 318.05 4,615.29 PA 64.60 1,044.99 PEUC 0.00 0.00 LOCAL 23.07 373.22 K 6 138.43 Period: 08/27/01 - 09/09/01 Check #: 6001 Net Pay: $1,586.55 006021 BRADLEY J. SANDERS SANB ...... ' ............. 179-66-4680 Regular se.ce 2,3~?.2~ FICA Z76.5e 3,031.73 FED-M PA PEUC LOCAL K 6 318.05 ' 4,933.34 64.60 1,109.59 0.00 0.00 23.07 396.29 138.43 Y-T-D PAY 37,251.83 Period: 09/09/01 - 09/22/01 Check #: 6021 Net Pay: $1,586.55 006041 BRADLEY J. SANDERS SANB 179-66-4680 Regular 80.00 2,307.20 FICA 176.5e 3,208.23 FED-M PA PEUC LOCAL K 6 318.05 5,251.39 64.60 1,174.i9 0.00 0.00 23.07 419.36 138.43 ~~ Y-T-D PAY 39,420.60 Period: 09/23/01 10/06/01 Check #: 6041 Net Pay: $1,586.55 EXHIBIT 2 Husband's Pay Stubs ~IDREW $ MoCREATFI & ~ON, INC. ............ ' HAIIIRI~BURG laA 171~ Regula=I' , . ~9.90.. 2,397.20 FZCA LOCAL .006041 179-~6-468~ 176,5~ 318.05 5,251.3~ 64.60 lr174.~ 23.07 419.3~ 138.43 39,42~.6~ Pay: BRADLEY J. SANDERS SANB Regular 80.00 2,307.20 FICA FED-M PA PEUC LOCAL K6 179-66-4680 176.50 3,384.72 318.05 5,569.44 64.60 1,238.7E 0.00 0.0~ 23.07 442.4~ 138.43 Y-T-D PAY 41,589.37 Period: 10/07/01 - 10/20/01 Check #: 6061 BRADLEY J. SANDERS SANB Net Pay: $1,586.55 Regular 80.00 2,307.20 FICA FED-M PA PEUC LOCAL K 6 179-66-4680 006081 176.50 3,561.2S 318.05 5,887.47 64.60 1,303.3f 0.00 0.0¢ 23.07 465.5~ 138.43 Y-T-D PAY 43,758.14 Period: 10/22/01 - 11/04/01 Check #: 6081 Net Pay: $1,586.55 BRADLEY J. SANDERS SANB 179-66-4680 Regular 80.00 2,307.20 FICA 176.50 3,737.71 FED-M PA PEUC LOCAL K 6 318.05 6,205.5~ 64.60 1,367.9! 0.00 0.0( 23.07 488.5' 138.43 ,~ '~'<¢ ' Y-T-D PAY 45,926.91 Pertod: 11/05/01 11/18/01 Check #: 6101 Net Pay: $1,586.55 Regular 80.88 2,~07.20 FICA !78 FED-H ~'~. ~' ~,,[2'3.~ PEUC LOCAL - ---!1 .: SUP Y-T-D PAY 48,895.68 Period: l~..l:;01 ~/ -,, ~, 8,,.0~ Check #: BRADLEY J. SANDERS SANB 179-66-4680 Regular 8~.~ 2,3~7.2~ FICA 179.44 4,~93.67 38.40 INS FED-M PA PEUC LOCAL K 6 SUP 328.42 6,852.81 64.60 1,497.19 0.00 0.00 23.07 534.71 138.43 205.38 -T-D PAY 58,302.85 Per~od: 12/03/01 - 12/16/01 Check 6140 Net Pay: $1,367.86 006161 ~,, ~ ~.~. ,. .... 688 Regular 88.08 2,3¢?.20 FZCA 176.50 176.50 FED-M 318.85 318.85 PA 64.60 64.60 PEUC 0.00 0.80 LOCAL 23.07 23.07 K 6 138.43 SUP 161.54 OPT 10.00 Y-T-D PAY 2,168.77 Period: 12/16/01 12/29/01 Check #: 6161 Ne% Pay: Sl,415.01 Regular 80.00 2,307.20 FICA FED-M PA PEUC LOCAL K 6 SUP 176.50 353.00 318.05 636.10 64.60 129.20 0.00 0.00 23.07 46.14 138.43 161.54 , ~P~: 12/31~01 ~ 01/ 02 "Check 6180 Net Pay: $1,425.01 BRADLEY J. SANDERS Regular 80.00 2,307.20 SANB FICA FED-M PA PEUC LOCAL K 6 SUP 179-66-4680 176.50 287.36 64.60 0.00 23.07 138.43 161.54 0061 99 529.50 923.46 193.80 0.00 69.21 Y-T-D PAY 6,506.31 Period: 01/14/02 - 01/27/02 Check #: ANDREW S, i~cCREATH & SON, INC. HARRISBURG, PA 17105 BRADLEY J. SANDERS SANB Regular 80.00 2,307.20 6199 FICA FED-M PA PEUC LOCAL K 6 SUP Pay: $1,455.70 006218 179-66-4680 176.50 706.00 287.36 1,210.82 64.60 258.40 0.00 0.00 23.07 92.28 138.43 161.54 Y-T-D PAY 8,675.08 Period: 01/28/02 - 02/10/02 Check #: 6218 Net Pay: $1,455.70 Regular 80.00 2,3( 20 FICA FED- s PA PEUC LOCAL K 6 SUP 176.50 142.91 64.60 0.00 23.07 138.43 161.54 1,235.50 1,639.55 452.20 0.00 161.49 Y-T-D PAY 15,181.39 Period: 03/11/02 - 03/24/02 " Check #: 6271 Net Pay: $1 600.15 ~JDREW S. McCREATH & SON, INC. HARRISBURG, PA 17105 BRADLEY J. SANDERS. .,~ ' ..... SANB~.. ........ 006290 179-66-4680 Regulam 80.00 2,307.20 FICA 176.50 1,412.00 ' FED-s 142.91 1,782.46 PA 64.60 516.80 PEUC 0.00 0.00 LOCAL 23.07 184.56 K 6 138.43 SUP 161.54 Y-T-D PAY 17,350.16 Period: 03/25/02 - 04/07/02 Check #: 6290 Net Pay: $1,600.15 Regular 2,30~ 20 FICA FED- s PA PEUC LOCAL K 6 SUP 176.50 142.91 64.60 0.00 23.07 138.43 161.54 882.50 1,353.73 323.00 0.00 115.35 Y-T-D PAY Period: 02/10/02 - 02/23/02 10,843.85 Check #: 6237 Net Pay: $1,600.15 NT OF EARNINGS AND DEDUCTIONS - DETACH AND RETAIN FOR YOUR RECORDS DREW S. McCREATH & SON, INC. HARRISBURG, PA 1710S BRADLEY J. SANDERS. ..... · 006252 179-66-4680 Regular 80.00. 2,307.20 FICA 176.50 1,059.00 FED-s 142.91 1,496.64 PA 64.60 387.60 PEUC 0.00 0.00 LOCAL 23.07 138.42 K 6 138.43 SUP 161.54 Y-T-D PAY 13,012.62 ?eriod: 02/24/02 03/09/02 Check #: 6252 Net Pay: $!,600.15 Bradtey J Sanders 2177 Merrimac Ave Mechanicsburg, PA 2001 U.S. INDIVIDUAL INCOME TAX RETURN SUMMARY Adjusted Gross Income $ 49,854 Taxable Income $ 27,504 Total Tax $ 4,744 Total Payments $ 6,852 Refund $ 2,108 Effective Tax Rate 9.52 % INSTRUCTIONS FOR FILING YOUR RETURN ELECTRONICALLY If you file electronically, make sure to follow the Electronic Filing Instructions to complete your tax return. Come back to TurboTax in 24 to 48 hours to check the status of your return. TurboTax will let you know if your return has been accepted or rejected by the IRS. If the IRS accepts your tax return, TurboTax will walk you through the final steps of electronic filing. It may involve printing and maiting some etectronic filing forms.(DO NOT maita printed copy of your tax return to the IRS. They already received an electronic copy of your tax return.) If your return is rejected due to an error, you have two options. You must fix the error and retransmit your return electronically, or you can mail a printed copy of your return to the IRS. To mait your printed return, follow the mailing instructions below. INSTRUCTIONS FOR FILING YOUR RETURN BY MAIL Your federal Form 1040 shows a refund of $2,108. Please mail your return to the following IRS address postmarked by Monday, April 15, 2002. Internal Revenue Service Center Philadelphia, PA 19255-0002 Be sure to s'ign and date your return and include the proper amount of postage on the envelope. ATTACHMENTS Attach the first copy or Copy B of Form(s) W-2 to the front of your Form 1040. KEEP THIS PAGE FOR YOUR RECORDS -- DO NOT MAIL. EXHIBIT 3 H's 2001 Federal & State Income Tax Returns ~orm I 040 u.s. Individual Income Tax Return 2001 ~9.~) les ..... ,y- ~notwrde orstapie in ~,s space Label ~e the iRS tabel, Otherwise, please print or type. Presidential Election Campaign r0r the year Jan 1 - Dec 31, 2~1, or other tax year beginning Bradley J Sanders ,2001, ending ,20 Your Social Secudty Number 179-66-4680 Spmuse's Sociar Security Number 192-56-5174 Home Address (number and street) if You Have a P,O. Box, See Instructions Apartment No. · Important! · 2177 He r r i mac Ave You must enter your social security number(s) above, City, Town or Post Office. If You Have a Foreign Address, See Instructions. Mechanicsburg PA 17055 ~. Note: Checking 'Yes' will not change your tax or reduce your refund. You Spouse Do you, er your spouse if fibng a ioint return, want $3 to go to this fund? ........ ~' ~ Yes ~-~ No ~--] Yes ~ No 1 ~ Single F'ili ._...n= Status 2 LJ Married filing joint return (even if only one had income) $ ~'~"1 Married filing separate return. Enter spouse's SSN above & full name here .. ~ At i son M Sanders Check only 4 LJ Head of household (with qualifying parson). (See instructions.) [f the qualifying person is a c~itd-but not you------~ one box. dependent, enter this child's name here ~' 5 Ivl Qualif/in~ widow(er) with dependent child fCear spouse died ~' ). (See instructions.) Exemptions 6a ~ Yourself, If your parent (or someone else) can claim you as a dependent on his or -~ No. d her tax return, do not check box 6a ............................................ checked o~ F--t ' F Ga a#d eb .... 1 b Spouse -- No. of your (Z) Dependent's (3) Dependent's if 6c who: C Dependents: social security relationship · ita.d number to you tax creeit with you (1) First name Last name Cs~ instrs) did not SiX dependents, see instructions. 7 Wages, salaries, tips, etc. Attach Form(s) W-2 ....................................... 7 50,303, Fncome 8a Taxable interest. Attach Schedule B if required ........................................ 8a '1 2 ~. Rttach Forms b Tax-exempt interest. Do not include on tine 8a .., I N-2 a~_~IW-ZG .......... .. 1ere, ,~..attach 9 Ordinary dividends. Attach Schedule B if required .................................. 9 rorm(~l{HI-R ii' 10 Taxable refunds, credits, or offsets of state and local income taxes (see instructions) ax W~a~/l~hheld. 11 Alimony received 11 f you did not 12 Business income or (loss). Attach Schedule C or C-EZ ................................ let a W-2, see 13 Capital gal0 or (lose). Attach Schedule D if required, if not required, clffick here ........... ~' [] 13 qs~uctions. 14 Other gains or (losses). Attach Form 4797 ............................................ 14 15a Total IRA distributions ..... 15a I b Taxable amount (see instrs) .. 15b 15a Total pensions & annuities . 16aI b Taxable amount (see instrs) ,, 16b 17 Rental real estate, royalties, partnerships, S corporations, trusts, otc. Attach Schedule E .. 17 nclose, but do 18 Farm income or (loss). Attach Schedule F ............................................ 18 et attach, any 19 Unemployment compensation 19 ~yment.ease usuAlS°' 20a Social security benefits ..... J 20al J b Taxable amount (see instrs) .. 20b }tm 1040-V. 21 Other income 21 22 Add the am;u~t; i~ ~-f~rTic~h~-c~l~rr~n~o~ I~n~'s~ ~hTo~gf~ ~'17~i; tis ~o~r- CoGITn~o-m~ -¢ 22 5 0, 4 2 6. 23 IRA deduction (see instructions) ........................... I 23 djusted 24 Student loan interest deduction (see instructions) ........... 24 ross 25 Archer MSA deduction. Attach Form 8853 ................. 25 come 26 Moving expenses. Attach Form 3903 ....................... 26 27 One-half of self-employment tax. Attach Schedule SE ....... 27 28 Self-employed health insurance deduction (see instructions) 28 29 Self-employed SEP, SIMPLE, and qualified plans ........... 29 30 Penalty on early withdrawal of savings .................... 30 33 a Alimony paid b Recipient's SeN .... ~' 192 - 5 G - 5 1 74 .. J 33 a 5 7 2. I ~2 Add linee23thr0ugh31a ................................................................ 1~ 572. 33 Subtract line 32 from line 9-2. This is your adjusted gross income ~'133 '4 9, 85 4. '! otice, see instructions. Form 1040 (2001) Credits 85 a Check if: You were 65/older, Bfind; Spouse was 65/older, E~lind. Add the number of boxes checked above and enter the total here ~' 85a Standard Deduction b If you are roamed fihr- ~arately and your spouse itemizes deductions, or - or'you were a duabst allen, see ~nstruct~ons and check here ..... 85 b [] ' · People who 36 Itemized deductions (from Schedule A) or your standard deduction (see left margin) 36 ][ 9,4 $ 0 ,ecked any box --~7 Subtract line 36 from hue 34 ................ ~'/ 30,404 .n hne 35a or 35b or who can 38 If line 34 ~s $99,725 or less, mulbp~ $2,900 by the total number of exemptions clmmed be dammed as a on line 6d f [ ne 34 s over $99,725, see the worksheet n the ,r~sfrucbons 38 2,900, dependent, see 85 Taxabta income. Subtract line 38 from ime 37 ~nstructions. If line 38 ~s more than I,le 37, enter -0. 39 2 7,5 04. 48 Taa(seemstrs).O~eckdanytaxlsfrom a I-1Form(s)gg14 b~-~Form4972 40 4,744. · All others: /Single: 41 Alternative minimum tax (see instructions), Attach Form 625] 41 /~-,550 42 Add lines 4O and 41 ~'- 42 4,744. JHead of 43 Foreign tax credit, Attach Form ] i ]6 if required | househoM, 44 Credit for chitd and dependent care expenses. Attach Form 2441 ....... 44 $6,650 45 Credit for the elderly or the disabled. Attach Schedute R 45 jMarried filing 46 Education credits. Attach Form 8863 46 |jointlX or |Quahfying 47 Rate reduction credit, See the worksheet ............. 47 ~widow(er), 48 Child tax credit (see instructions) ................... 48 J$7,600 I 49 Adoption credit. Attach Form 8839 ................... 49 I Married filing 50 0thel credits from a ~Form3800 b E~Form8396 1$3,800Jseparately' c [] Form 880] d LJ Form (specify) 50 51 Add lines 43 through 50. Theee urn your total credits ............................................ 51 52 Subtract line 5] from line 42. I1 line 5] is more than line 42, enter .0- , ............... ~ 5Z 4,744. 63 Self-employment tax. Attach Schedule SE ................................................ 53 Other 54 Social security and Medicare tax on tip income not reported to employor. Attach Form 4137 .............. 54 Taxes 55 Tax ou qualified plans, including IRAs, and otPer tax*favored accounts. Attach Form 53~ if required ......... ~ 55 56 Advance earned income credit payments from Form(s) W-2 .......................... 56 57 Household employment taxes. Attach Schedule H ................................... , 57 58 Add lines 52*57. Thiaisyourtotultaa .................................................. ~ 58 4,744. Payments 59 Federa~ imcome tax withheld from Forms W-2 and 1099 ...... 59 6,85 2 If you have a I 60 2001 estimated lax payments and amount applied from 2000 return ........ 60 ~lifying ~ 61 a Earned income credit (EIC) ........................ 61 a ~d, attachF b Nontaxable earned income ...... I 6'1 bt 5 chedule EIC. - 62. Excess social secul'i~ and RRTA tax withheld (see instrs) I 62 63 Additional child tax credit. Attach Form 88]2 .............. 63 64 Amount paid with request for e~eesion to file (see instructions) .......... 64 65 Other payments. Check if from .... a [] Form 2439 b [] Form 4136 ........................................ 65 Pi^ell2 ~2/]0~)1 66 Add lines 59, 60, 6la, and 62 ~hrough 65. These are your , total payments ............. . ~ 66 ~, ~5 2 . {eTund 67 If line 66 is more than fine 58, subtract Ih~e 58 from line 66, This is the umonnl you onerpaid ............. 67 2,108. )irect deposit? 68a Amount of line 67 you want refunded to you ....................................... ~ 68a 2, ] 08. ,eeinst/uctions ~' bRoutingnurnber ...... 231381116 "c Type: []Checking J~]Savings nd fill in 68b, 8c, and 68d. d Account number ...... 045]384341 69 Amounl of line 67 you want applied to,your Z002 estimated tax ~'J 69 J [mount 70 Amount you owe. Sub~ract line 66 from line 58. For details on how to I~Y, see instructions ............... "70 'OU Owe 71 Estimated tax penalty. Aisc include on line 70 ........ [ 71 J 'bird Party )esignee ;ign lore oint return? ee ins~-uctions. oep a copy m your records. Do you want to allow another person to discuss this return with the fRS (see instructions)? ........ [] Yes. Complete the folJowing. [] No 'aid *'~parer's ; Only Serf-Prepared EINphone No. FO~T~ 1040 (2001) zOol g, epar~,em of the Treasury "See Instructions for Schedule A (Form 1040). 07 Bradley 3' Sanders ]79-66-4680 dica[ Caution. Do not include expenses reimbursed or pa~d by others. .,d 1 Medical and dental expenaee (see ~nstructions) 1 Dental Expenses 2 Enter amount from Form ]040, hne 34 [ 2 3 Mulhpty In~e 2 above by 7.5% (.075) 4 Subtract line 3 from tine 1. If line 3 is more than hne 1. enter ~0. 4 Taxes You 5 State and local income taxes 5 2, 032. Paid 6 Real estate taxes (see rnstrucbons) $ 1,422. (See 7 Persolqal pnoperty taxes 7 343. mstructior~s.) 8 Other taxes. List type and amount ~' ............. 9 Add lines 5 through 8 9 3,797. Interest 10 Home mig interest and points reported to you on Form 1098 .............. 1 0 1 4,8 8 3 You Paid 11 Home mortgage interest nol reported lo you on Form 1098. If paid to the person from whom you bought the home, see instructions and show that person's name, identifying number, and address '~ (See ............................... instructions.) Note. 11 Personal 1Z Points not reported to ~u en Form 1098. Se~ instrs for spcl rules ........ 12 interest is not 15 Investment interest. Attach Farm 4952 if required. deductible. (See instrs.) ......................................... 15 14 Add lines l0 through 13 ............................................................. 14 14,883. Gifts to 15 Gifts by cash or check. If you made any gift of $250 or more, Charity see instructions 15 350. If you made 16 Other than by cash or check. If any gift of $250 or -iff and more, see instTuctions. You must attach Form 8283 if a benefit over $500 ........................................... 16 42 0. instructions. 17 Carryover from prior),ear ............................... 17 18 Add lines 15 throu,dh 17 ................................................... 18 770. Casuat~ anti Theft Losses 19 Casualty or theft loss(es). Attach Form 4684. (See instructions.) .......................... 19 Job Expenses 20 Unreimbursed employee expenses - job travel, union dues, ~m&~Jlest job education, etc. You must attach Fanta 2106 or 2106-EZ 3ther ~iscellaneous if required, (See instructions.) :)eductions 2O 21 Tax preparation fees ........................................ 21 45. 22. Other expenses - investTnent, safe deposit box, etc. List ~See E_ n_ ---- -- -- - - $_o_0_. = 500. :o deduct ~ere.) 23 Add lines 20 through 22 ................................. 23 545 24 Entm amount from Form 1040, line34 ..... I 24 I 49,854. ~5 Multipty line 24 above by 2% (.02) ............................ 25 997. z6 Subtract line 25 from line ~3. If line 25 is mere than line 23, entel' -0- . .............. 26 0. )ther 27 Other - from list in the instructions. List type and amount ~liscellaneous ~eductions ............................................. 27 'otal 28 Is Form 1040, line 34, over $132,950 (over $66,475 if MFS)? emized ~eductions [] No. Your deduction is not limited. Add the amts in the far right col for lines 4 through 27. Aisc, enter this amt on Form t040, line 36. "28 19,450. [~ ¥e$, Your deduction may be limited. See instructions for the amount to enter, 1AA For Paperwork Reduction Act Notice, see Form 1040 instructions. FDIA030] 0],97/02 ScheduJe A (Form 1040) 2001 OMB No. IS45-0008' ' ' ~'~'v r ~l ~= ~=. ,=,=-u~= ~ee Notice to EmpIo iee~oh backdoor C, opy B ) b Employer identification numbe~ I Wages, tips, other compensation 2 Federal income [ax'withheld 23--1519989 50302 . 85 6852 . c Employer's name, "Hdr~s, and ZIP c~e 3 Social security wages 4 Social security tax withheld ANDREW S. McCREATH AND SON, INC. 53511.20 3317.76 P O BOX 1453 s Medicare wages and tip5 6 Medicare tax withheld 53511.20 775.91 HARRISBURG, PA 17105-1453 ? Social securfiy tips fi Aflocatedtips d Employee's social secudt~ number 9 Advance EIC payment 10 Dependent care benefits 179-~-4680 e £mp~oyee's first name and initial Last name ., 11 Nonqualified plans 12a See inslTuctions for box 12 S D ,E¥ J SANDERS i D I 3208.35 2177 MERRIMAC AVE 14 Oth6r lZc MECHANICSBURG, PA 17055 ~ 12d Employee's address and ZIP code 15 sta~ Employer's state ID number 16 State wages, Ups, ~c 17 State income tax 18 Local wages, tips, otc, 19 Local income tax 20 Locality name ~-A---]..-..~-3.-~.5..1_9.-9-.8._9. 53472 80 ~497 [9 53472 80 534 71 LOCAL I o,~ Statement This information is being furnished to the Internal Revenue Secvice If you be imposed on you if this income is taxable and you fail to report it sUMMARY OF SALIENT FEATURES PA NIA PRIVATE ROBERT lC ~Akl2D'iOF F SEPTEMBER 13, 2001 EXHIBIT 4 Appraisal of Marital Home UNIFORM RESIDENTIAL APPRAISAL REPORT CIy MECHANICSBURG '~N ~' CUM~R~ND ~CE NO. T~ 2001 BE, ?~ ~ 2,62[ BRAD Pu~. (aylo) D R",'W.~..L Adve~i~ environ~ c~ond~b~ ~u~h as, h~t net irJt,ted lo, PAZ~ w~tm, Io~ mJb~, e~,,) ~ln h ~ ~ ~ ~, ~ ~ ~ IINtFORM RESIDENTIAL APPRAISAL REPORT 1,035 al. t't, @$ 2e,.u0 DeF~la~i Vd.e ef ~l~v~,nats ........................ 88, t4 A~MT EEC OR Q Sra~ I.~/A GENT! A~MT REOOR0$/ML~/AGEN TI .4E AC .25 AC AVERAGE 2,5 +O,O00 DECK FP NONE (InC~ilg Ire ~ubl~t ~ ~am~l~ll? to ~ I1~, ~t :,): ~lea at'~ad addenda. WITHIN t YEA~ OTHER TH.N~ USTED ABOVIE OTHER'rHAN LISTED ABOVEJ OTHER THAN LISTE0 ABOVE ,-']~ I~sp~t ~ope~ ~plemen~l Addmtd~um_. ~ pRIVATE ~ TN)O _ ffOTAL 2000 f~ Window, ~;I a~am ~/al~ me~ !re.-- 1-80g-~LAM~DE DEFINITION OF MARKET *~ ~ ~ STATEMENT OF LIMITING CONDITIONS AND APPRAISER'S CERTIFICATION CONTINGENT AND LIMITING CONDITIONS: 1~ a~Fal~.~ (:ed~a~o~ U~ app~ ~n ~ ~pn~ ~BpoK is sul~'~ ~o Um ~lW, wlng 9. The t~F~aa~ has I~ Ms or Mr ~p~aJsal mpmt md valLm~ ~m~k~on ~ an al~qbd If~ is sub~t to sa~/ ~m~Ooe, ra~ or alis~on~ mt ~ a~amplk~ II~ Gomp4e~n d ~e Irt~ v,tl be ~m~med I~ a wdm~vll~ mature, ~1D/2 Famis Mae Form t0048 ~ C~ ~ AW n~,~e, I~:, (717) A~PRAISER'$ (~ERTIFI~,,~'~ ,' Tha~,~ser~e~a~,at: SUPERVISORY APPRAISER'S CF.R'IIFICATION: [f ~ s~,dsmy ~,~fatw dgned me qopm~ ~ he or she COK~ afl~ ~rm II~ ADDRESS OF PROPERTY' APPRAI~'ErI:,,~2177 MEE~RIMAC A~NUE, ~CH~ICBBU~Qs pA t?~5 APP~ISER: ~ ~//// SUP~VISORY APP~IBER Iofl~ if required): ~ ~o~r ~.~HO~ ~ F,~ Mm F~ 436 6-93 Emro ACR -- 'TOT.~L 2~0 ~r Wkd~ awxa~ semrau by a I~ rdo~ klC.-- 1.SiXN/~MODE APPIO, I~ER CEP.'i II~'iCATION APPRAISEK STANDARDS I acknowledgo and ocrt~ t~hat (l) my ~pr{isal of thc above r~o~d pr~ ~y used. ~ a ~d~a~ ~d ~ ~ou m~t [o ~e rc~ of ~1~ ~ of · e F~d ~flon R~ ~o~ md ~r~emmt A~ of 1989 ('~"); ~le apprai~ ~ co~ ~ m~ ~e ~p~bh ~ns ~g Title ~ ofF.es; ~d (ii0 ~ ~ppra~ w~ cO~ ~ a~or~c~ ~ U~, A~PRAISEK GOIV~ETENGY I ~ th~ I om fully quali~t and competes by tr,{-~-~, lmowiedg~, md ex:perlmee to potfotm this spprslsa{. APPRAISEK INDEPE'NDE1VC~ I r0~reseat artd certify that (i) tltu appraisal at,~gumeat was not based ou a r~u~d ~s not con~tion~ ~on ~e a~ ~a,,~.8 a ~c v~ or a ~lue ~ a ~m r~ge; (~) ~ fu~ ~]o~t ~ not ~d~t ~ ~ apparel pmdu~g a ~cc~c value; (N) my mplo~t, c~msafio~ md ~ ~t ~c not not aw~e of~ ~s ~ wo~d ~u~ mo ~m be~ c~ ~ ~ondent DA~: sulileet Phete Page I~, !,,~ SANDERS~BI~N~ s 21TTM I A~'EHUE linty f,~ECI.IA~ICSBURG CF, J~Y CUMBEi:U. AND I,e~ pRIVATE Sadie PA ~r) Code 17056 SuNeot Front ~bleBt Rear ~nower/Cl~ SANDERS, BP,,~D Sue PA Comparable 1 2~93 &t~DFOR0 ~JV1E R~. tg ~ 0.79 miles Compm'able 2 tZ2 ROUND RIOGE ROAD IFm~tvA~r~s~ 2177 MEERINt~AVENIJE I£ender pRIVA'T~ ,, Sta~ PA ~C~ I?0B~ 22.0* 34.6' J TOTAL LNABLE (mu~ 20~ 6 ~s TO~I (mun~e~ 2072 ~Ood, Customer Service - (800) 736-9090 : "!:"-~ :~D - _For the Hcermg Impaired,- (~800) 735-2922 mort - l~ri 6:00 am - 8:00 pm Cev Time Sat 8:00 am - 1:00 pm Ce: Time w'ww.WaMuHomeLoans.com Statement Date Loan Number: 0054384227 BRADLEY d SANDERS 3,o4o 2177 HERRZMAC DR MECHANICSBURG PA 17055-9303 See Reveme Side For Additional information Property Address: 2177 Merrimac Dr Mechanicsburg PA 17055 Principal Interest 0.00 Escrow 6.00 1,390.36 Total Amount Received $1,390.30 Escrow Balance Intnrest Rate 7.12500% Next Payment Due Date Current Payment 12/01/01 1,764.51 Tatal Amount Due $1,754.51. ~roperty Taxes Paid nsurance Paid $0.00 To avoid late charges of $71.92, we must receive your payment by 12/16/01 during our business hours. Principal Paid $0.00 Real Estate Taxes Paid $0.00 Insurance Paid $0.00 $0.00 return boffom ~ion with your Payment. (Allow 7-10 days for Postal delivew.) 908-B EXHIBIT 5 Washington Mutual mortgage stmt. Kelley Blu~ Book The Trusted Resource New Car Pricing Build a Car' Incentives My Cads Value Used Cam' Retail Buy a New Car' Buy a Used Car Sell Your Car Motorcycles Financing Lemon Check Warranties Accessories Car Reviews Car Previews Decision Guides Advice ~ ~u:e ~o(>k Trade-in Report Pennsylvania · March 10, 2002 2000 Ford F150 Super Cab Short Bed 4D Buy a New Car Buy a Used Car List Your Car For Sale Online Financing Quote Insurance Quote Warranty Quote Payment Calculator About kbb Home Engine: V8 5.4 Liter Trana: Automatic Drive: 4 Wheel Drive Mileage: 33,029 Equipment Off-Road Group XLT Air Conditioning Power Steering Power Windows Power Door Locks Tilt Wheel Cruise Control AM/FM Stereo Compact Disc Dual Front Air Bags ABS (4-Wheel) Sliding Rear Window Bed Liner Two-Tone Paint Alloy Wheels Consumer Rated Condition: Good "Good" condition means that the vehicle is free of any major defects. The paint, body and interior have only minor (if any) blemishes, and there are no major mechanical problems. In states where rust is a problem, this should be very minimal, and a deduction should be made to correct it. The tires match and have substantial tread wear left. A clean title history is assumed. A "good" vehicle will need some reconditioning to be sold at retail; however major reconditioning should be deducted from the value. Most recent model cars owned by consumers fall into this category. Trade-In Value $16,880 Trade-in value represents what you might expect to receive from a dealer for this consumer owned vehicle. Keep in mind that the dealer must then absorb the cost of making the vehicle ready for sale, advertising, sales commissions, arranging financing and insurance and standing behind the vehicle for any mechanical or safety problems. Click to vi~ hAp://www.kbb.com/kb&i.dll&w v° "ovhh'eqm 2n~'t~2o'~'vnno~vo~ qn~ ~:FT;D9... 3/10~002 EXHIBIT 6 Kelley Blue Book Valuation of Ford F-150 PLAINTIFF'S EXHIBIT 7 Sales or Trade-in documents for 1995 Eagle Vision [to be supplied by wife] 2000 F150 08/16/2001 09/05/2001 $15.846 38 For ar' ' "ss changes or other communication, feel to contact us.  cUSTOMER SERVICE CENTER 1-800-727-7000 Mo~- Sat 7 ~m- 8 p~ CST WEBSITE ADDRESS www.fordcredit.com TRANSACTIONS SINCE LAST STATEMENT Transaction Date Description Amount 08/05/2001 Payment received PAYMENT(S) DUE Due Date Description Amount 09/05/2001 Payment due $137.00 Personalize your vehicle with genuine Ford, Lincoln or Mercury Accessories! These accessories are designed enginee ed and tested specifically or your vehicle. Be sure o ask your local dealer for deta. i s on the complete JJne of accessories. EXHIBIT 8 Ford Credit loan statement EXHIBIT 9 Joint PSECU account statement r3r' .uu~uurg, r~ I / iuD-/U I ~ (~UU) Z3/-/328 ('4olionwkJe) website - http://www, psecu.com USE THE SELF-SE, .CE TELEPHONE= -FOR BALANCE INQUIRIES -TO TRANSFER FUNDS -TO RAKE LOAN PAYMENTS -AND MUCH, MUCH MORE h,,llh.,llh,.,hh,hhhh,,.Ihlh,,.,Ihh.lh,,h.lhl BRADLEY J SANDERS 2177 HERRIMAC AVE NECHANICSBURG PA 17055-930S JOINT OWNER 090101109S001 ' PAGE 1 09/05 NITHDRANAL ADJUSTMENT ATN REBATE-AUG 254.75 2.75 157.50 00- 217.50 AT~ SOOO LOUISE DRIVE HECHANZC$~URGPA TERM TRTB97 09/12 HITHDR~HAL ACCOUNT AD~US~NE~ × 117 50- 0 0 09/12 JFO - ADJUST NEH HEHBERSH~P CHARGE 09/12 H~THDRAHAL AT AT~ ~000010~5 ~00 00- !6 50 BASED ON AVERAGE DAILY BALANCE OF 87,85' - 09/30 ENDING aALA~CE * ~ 16 70 09/0~ N~THDRAHAL POS ~000014q2 ......................................... 10. 09/05 CHECK 001088 09/05 CHECK 001095 SSS. 20- 18q9.68 / ::0c~/~:~.: : ~gP; 001091 1695.88- 15S. 80 0 .................. 9/19 CHECK 001089 .............................................. : 09/i9 CHECK 001098 50.00- 2220.56 09/Z1 CHECK 001099 869.2q- 1~51 I2 O ~, .q ...................... ~ ~::::: ........................................... ~:~:::::::::::::::~ .............. 58 56- --- CONTINUED EXHIBIT 1 1 : Joint PSECU savings account stmt. rDr web$ite - hffp://www, psecu.com USE THE SELF-SEk.zCE TELEPHONE~ -FOR BALANCE INQUIRIES -TO TRANSFER FUNDS -TO HAKE LOAN PAYHENTS -AND HUCH, HUCH HORE BRADLEY J SANDERS JOlT OWNER 0179XXXXXX 090101095001 PAGE 2 09/2~ CHECK 001100 ......................... I.:.~.,:.~:~ .::i i:::::::::J 09/Z5 CHECK 001102 179. B4- 1091.77 11. OZ- 1080.75 09/30 ENDING BALANCE 2668. DIVIDEND YTD~ YEAR TO DATE 26.13 001091~ 29.77 00~095 1695.~8 001099 58.56 00~092 450.00 00~096 ~3.62 DOllO0 ~ ASTEriSK NEXT TO NUHBER [ND[CATES SKiP [~ NUHBER SEQUENCE ................... ~0~: ~ ...... ::'"' :"::' '::: ........................................... ~:::~::~"~$ ~ .................... ...................... EXHIBIT 12 H's Prudential 401K stmts, as of date of marriage & separation Benefit Certificate FOR: BR3%DLEY J SA/~DERS SSN: 179-66-4680 AS OF: 12-31-95 ANDREW S. MCCREATH & SON, INC. 401(K) SAVINGS PL~ > < FIXED EQUITY INCOME TOTAL $ 0.00 $ 2678.68 $ 2678.68 Employee Contrib. 798.07 798.07 1596.14 E'er Match Contrib. 399.04 399.04 798.08 E'er Basic Contrib. 266.04 266.04 532.08 Investment Results 873.97 246.62 1120.59 Transfers 4388.45 -4388.45 0.00 At 12-31-95 $ 6725.57 $ 0.00 $ 6725.57 Vested Amount $ 4891.42 $ 0.00 $ 4891.42 401(K) EMPLOYEE CONTRIBUTIONS TO DATE: $ 3060.99 however, in the event of a discrepancy, actual benefits will be determined according to the Plan provisioas. SIMPLEX TIME RECORDER CO. RETIREMENT SAVINGS PLAN c./o T. Rowe Prim, PO Box 17343 8al~nore MD 21297-1349 Alison M. ,~nder$ 2177 Merrimae Ave. MeGhanic~burg PA 17055 Aila~en M. 5andem Retirement ,e ,unt Seminar/ Apdi 1, 2001 te June 30, 2601 Review your account online: http://rps.troweprJca .~om or call: 1-800-922-994$ To change your name or address, pl~se contact your ?lan Administrator. Please review your statement and report any errors to T. Rowe Price within 60 days. Account At m GLance Begilniug Balance $13,251.16 + C~h In $791,86, · ~aeh Out - $4,051.25 * Gain/Loss $629.10 Endtsg Balal~ee $10,620 + Outstanding Loan Balance $4 Tntal A~.ount Value $14,620.90 Vested Balance $10,620.90 Change this Period - $2,630.26 Account Alteration 1.100.0% Growth Cash In ~ the to~l of all con~butio~ or payment~ made to your a~coun~ Cash Out i$ the total of all amounts taken out, ~ain/Lo~s ~ the total of Incr~s~ and/or r~uc#o~s in value for all investments in y~ur accoon£ A,c¢ount AIIoca#on shows bow the money you've pr~u~l! inve~ted i~ distrllmted over ll/Eerent Inv~l'nerd categories. ~t~t~ ln.vestme,,,r~,, (showl~ ill ~Jl~e~le#t modg/~) $6ow~ h~w any nev¢ utlans will ce distrtbutu~. Account Growth S7,200 $4,800 ~.,400 06/30/99 Nmat Your ReUrement PLa~' In antioiPsfion of the Plan's ~onversipn t~ Fidelity Investments on August 1,2001, your investment in the T. ROWe Price Stable vaue Fuhd liquidated on July 6, 2001 and transferred to the T. Rowe Pri~ Prime Reserve Fund. A~ I'gture contributions aJlocatod to the S~ will also be invesled in the PRF pending the Plan'e conversion. ~ Ending 6a[ance --~-- Employee + Employer C~lribulions ~b ¢~ t~ the gro~ o~r time of your Inv~tma~ ;~ ~ri~s. Any ~lan~ ~ ~m a p~u$ re~o~eep~ ~1 be $~wn ~ a EXHIBIT 13 Wife's Fidelity 401k Plan Statement Year-to-Date Statement Janmu*y I, :20OI .June 30, 2001 .... iiiiiiiiiiiiiiI I II I PUT NAM INYESTMEN S ALISON M SANDERS 2177 MERRIPIAC AVE MECHANICSBURG PA 17055-9303 Investment firm; i~MOND JAMES FINANCIAL SERVICE~ MR. CHP,~TOPHER FRAPIFTON · Repm.~ntadve phone number:. I 71 ?,777.2500 For Pumam ~l~an~ wve~.pumaminvestment~com Wha~ opporramltles exist now for Investors ~ the sideline,; In the summer issue of Putnam EDGE, Jefkey Kn i&.ht. Senior Asset AIIoca~on Strva~st. points to some compellln~ values a~d sa~escs ways :o get bad( in. Al~o in EDGE, read about Pumam's new IRA Center at www.put, namin vestmenr~.oom. Te~l fer the ql.~,eer $2,074.69 (Apr~; -June .~o) lIRA for tau~ year 2000 $0.00 IRA ~mtrib~;o~ for f~x y~tr 20(I I F2,331,29 $8.00 EXHIBIT 14 Wife's IRA statement PAGE I O~ 2 BRADLEY SANDERS, Plaintiff ALISON SANDERS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5654 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE HUSBA/~D'S LISTING OF HOUSEHOLD GOODS MARITAL ITEMS IN WIFE'S POSSESSION 1 Engagement Wife $7,015.00 Appraised value is ring $7,015.00 2 Futon Wife $300.00 $637.00 new value 3 Computer desk Wife $100.00 $250.00 new value and chair 4 Bookcase Wife $50.00 $200.00 new value 5 Jewelry Wife $100.00 $200.00 new value armoire 6 Full length Wife $90.00 $100.00 new value cheval mirror 7 Lingerie Chest Wife $450.00 $900.00 new value 8 Floor lamp Wife $50.00 $100.00 new value 9 Stereo rack Wife $500100 $1000.00 new value system 10 All CD's Wife $150.00 $500.00 new value 11 TV from Wife $50.00 $200.00 new value ~bedroom 12 All Pfaltzgraf Wife $250.00 $500.00 new value dishes 13 All crystal Wife $100.00 $200.00 new value ware 14 All silverware Wife $60.00 $120.00 new value 15 All glasses Wife $20.00 $40.00 new value 16 Longaberger Wife $750.00 $750.00 new value baskets EXHIBIT 15 H's listing of household goods 17 2 bakers racks Wife $125.00 $250.00 new value 18 Vacuum cleaner Wife $50.00 $200.00 new value 19 Mop & bucket & Wife $5.00 $20.00 new value broom 20 Mirror - Home Wife $60.00 $60.00 new value Interiors 21 Wall Wife $250.00 $500.00 new value idecorations Paintings, prints, pictures, etc. 22 Computer & Wife $200.00 $600.00 new value monitor 23 Color inkjet Wife $100.00 $200.00 new value printer 24 Camera Wife $100.00 $200.00 new value 25 Crystal vases Wife $100.00 $300.00 new value 26 Knives Wife $50.00 $100.00 new value 27 Printer stand Wife $40.00 $80.00 new value 28 Iron & ironing Wife $20.00 $60.00 new value board 29 Telephones (2) Wife $75.00 $150.00 new value 30 Digital Wife $50.00 $100.00 new value answering machine 31 Portable Wife $40.00 $70.00 new value stereo 32 Some pots & Wife $25.00 $100.00 new value pans 33 Household Wife $100.00 $100.00 new value supplies 34 Electric mixer Wife $30.00 $80.00 new value 35 Food processor Wife $50.00 $120.00 new value 36 Twin mattress Wife $150.00 $300.00 new value; Used for guests only; 6 times 37 All jewelry Wife $2,250.00 $4,500.00 new value (excluding engagement ring) 38 Plum sofa, Wife N/A husband has not love seat, inserted a value chair, end since wife is paying tables, and purchase debt equal coffee table to value. SUBTOTAL FOR WIFE $13,905.00 MARITAL ITEMS IN HUSBAND'S POSSESSION 39 Amish table & Husband $800.00 $2,187.00 new value chairs 40 Couch Husband $300.00 $800.00 new value 41 2 recliners Husband $300.00 $800.00 new value 42 Sunroom Husband $400.00 $1,252.00 new value furniture 43 Patio set Husband $100.00 $200.00 new value 44 Bedroom set Husband $800.00 $2,500.00 new value; 8 years old 45 Refrigerator Husband $500.00 $1,000.00 new value 46 Washer/Dryer Husband $400.00 $800.00 new value 47 Grill Husband $100.00 $525.00 new value 48 Lawn mower Husband $100.00 $400.00 new value 49 Pots & pans Husband $50.00 $150.00 new value 50 TV Husband $100.00 $600 new value; 8 years old 51 VCR Husband $30.00 $80 new value 52 Weedwacker Husband $50.00 $180 new value; 3 years old; heavily used 53 Garden Husband $50.00 accessories 54 Guns: Husband $900.00 $1600 new value Rem. 700 Rem. SP12 Sig Sauer P29 SUBTOTAL FOR B-USBAND $4,980.00 EXHIBIT 16 Universal Card statement '~ Y°ur AT&T Univ.-sa/Crud Statement August 25 - September 25, 2001 BRADLEY J SANDERS ALISON M SANDERS Account 5396 47B0 0120 5056 Calling Card 0421B23566+PIN No Annual Fee/Platinum Card Minimum Payment Due .............................................. $20,00 Due Date* .................................................. October 15, 2001 Credit Line .............................................................. $5,500.00 Availabre Credit ...................................................... $5,304.00 Cash Advance Limit ............................................... $5,000.00 Available Cash Advance Limit .............................. $5,000.00 Previous Balance $322,39 Payments and Adjustments -869.24 MasterCard Activity 706.66 AT&T Services 35.21 New Balance $195.02 Note: Detailed activity starts on page 3. Universal Appreciation Program Credit Amount ............................................................... $3.82 Total Credit Earned ....................................................... $3.82 P eto, 5 AT&T How to Reach Us Account Online: www.u niver salcard.co m Account OnCarl: 1 800 636-8330 (For Aulomated Service Only) Customer Service: 1 800 423-4343 or write Universal Card Services Corp., PO Box 44167 Jacksonville, FL 32231-4167 Use :your AT&T Universal Calling Card& Save! Domestic interstate and intrastate calls are $.35 a min. with no monthly fee. Dial 1-800-CALL-A'I-I', enter your AT&T Universa} Calling Card number & PIN. Pay phone calls are subject to a $.30 per call fee. Save on AT&T Long Distance With Universal Appreciation, you can save even more on your AT&T residential long distance charges simply by using your AT&T Universal Card for every day purchases. (Details page 2) Get Award-Winning Internet Access! Only $4.95 a month from the AT&T WorldNet(R) Service i495 SM Offer. Call 800-787-3900 ext.7977, or visit www.download.att.net/ucsmsg for details. Terms and conditions apply. Montefiore Pens Bobley-Harmann offers AT&T Univeral Card members fine writing instruments. See page 2 for details Great Savings from Hertz! You need a credit card when renting a car. Enjoy great savings from Hertz with your AT&T Universal Card. See page 2 for details. Payment Record Amount Paid: Date Paid: Check Numben EXHIBIT 17 Universal Card statement Closing Date: October 12, ' '1 page I of 3 Discover Platinum Card Acc..ant Summary acceuntnumber 6011 0023 1010 5044 previouebelance $179 84 payment due date November 11, 2001 payments and credits 179.84 minimumpaymentdue $10,00 pum, haees + 36.29 credit limit $13,500 credit available $13,463 cash advances + 0.0h cash credit limit $6,750.00 balance transfers + 0.00 cash credit available $6,750.00 FINANCE CHARGES + 0.00 newbalance -- $36.29 You maybe able to avoid Periodic Finance Charges, see the reverse side for details. about this Cash Advance check. BRADLEYJSANDERS ALISON M SANDERS 2177 MERRIMAC AVE MECHANICSBURG PA17055-9303 PAYTOTHE ORDEROF DISCOVER BANK DATE 8475 62-G4 311 $ EXHIBIT 18 Discover Card statement ~ D!"¢-nYer Platinum Card Account Summary '~ac~ountnumber 601; 0023 . .J 5044 "--' payreent due date October 11, 2001 ~ reinireurepaymentdue $10.00 ,~ credit lirn# $13,500 ,.,--m. credit available $13,320 ~ cash credit lireit $6,750.00 =---- cash c~edit available $6,750,00 ,, D : September 12, 2001 a~e I o~4 Closing ~ ~ previous balance $1,097.04 payreents and credits 1,695.RR purchases + 778.(:;R cash advances + 0.00 balance transfers + 0 O0 FINANCE CHARGES + n~n ~ ~ew balance '~ '~79, P,~ -~ You may be able to avoid Pedod/c Finance Charg~ reverse side for deta/Is. Use thru Dmcover(R) Pl.~tlnum Check... the quick, easy way to ge cash. See back of seconct page of ~a{ement for Impo~la~t Information about this Cash Atfvance check ' BRADLEYJSANDERS ALISON M SANDERS 2177 MERRIMAC AVE MECHANICSSURG PA 17055-9303 8272 DA TE . g2-$4 PA Y TO THE 311 ORDER OF$ Mer~o: ':02, & ~,OOr. h ql.' 22, ? 2?5,42,2, 22, 2,' r-. ~,,4 2? 2 EXHIBIT 19 Discover Card statement BRADLEY d SANDER8 acoountnumber 6011002310105044 J BuyThe Home You Wan...ow With a Discover ® Home Loan Buy the home you've alw;~.ys wanted with a Discover ~ first mortgage, brought to you by Morgan Stanley Dean Witter Credit Corporation. Whether you are buying your first home or upgrading to a larger home, its important.to choose a name you trust as a part of your total financial strategy. As a Cardmember, you can be assured cfa simple and convenient process. We offer 15 and 30-year fixed rate, fixed-term mortgages at competitive rates. And applying for a Discover first'mortgage is easy and can be completed by phone or online. Simply call 1-800-325-6280 (Cardmember Reference Number 43040). Or, if you prefer, apply online art Discoverhomeloans.com and receive e-mail updates as your application moves forward. You'll get ar preliminary credit decision within 24-hours so you can go shopping ~ for your new home todayl Travel/Entertainment Supermarkets Medical Services Govomment ServJusa Closing Date: August 12,2000 Jul 24 Jul 24 ARC 89081116308564 ARUNGTON VA WORLD WIDE TRAVEL CAMP HILL PA Jul 24 Jul 24 USAIR 03771079799631 WASHINGTON DO $150,000 FMGHT INSURANCE WORLD WIDE TRAVEL CAMP HILL PA Jul 24 Jul 24 USAIR 03771079799642 WASHINGTON DC $150,000 FLIGHT INSURANCE WORLD WIDE TRAVEL CAMP HILL PA Jul 28 Jul 25 GIANT, FOOD #120 8la MEOHANICSRURGPA Jul 15 ,Jul 15 STERLING OPTICAL CAMP HILL PA Aug 1 Aug 1 USPS 4134870] 15 HARRISBURG PA page 2 of 3 194.oo 194.00 NO COST 109.62 84.00 33.00 Effective A ugual I, EO00, Greenwood Trust Company, the bank that issues your Discover Card, will begin operating under the name Dim=over Bank. Please note that this =hangs will have no effect on your account(a). Eat out ofton ? Well, Dine Out with Discover(R) Card for a rdtanco to winl Du~g the month of September, your meal could be on us when you use your Discover Classic Oard at ;ny of your favorite restaurants that acoopt Discover Card. See the onclused Explore Newsletter for further deteiisl Go bank to school and beat the heat with Spencor GIf~l Decx~rate your room with the famous aingth9 Travis Trout. Cool off with a Squeeze Breeze misting fan. Shop online at v,',,.,w, eponco~gl#~.eorn to get a 10% savfngs. Just enter rode DISCO VER and use your Discover Card when you shop. Offer ends 12/31/00. Cannot be combined with other offers. Average Dally ANNUAL Periodic Fee Dally Periedio PERCENTAGE FINANCE FINANCE Rate Balar~on Rates RATES CHARGES CHARGES Plan ~urrent billing period: 31 da~ Pun~haaea $0 0.05340% 19.49% $0 none vadable ~ash Advances $0 0.06025% 21,99% $0 $0 fixed previous J~lling parted: 30 days Pu,'ehasss $0 0.05340% 19.49% $0 none vadable Dash Advancoe $0 0.06025% 21.99% $0 none fixed .QussUnns? Call 1-800-DISCOI/;" ....................... *tahOe, see r-=verse side. EXHIBIT 20 Wife s airline ticket statement PLAINTIFF'S EXHIBIT 21 Mortgage payment statement [to be supplied if in dispute] PLAINTIFF'S EXHIBIT 22 Truck payment statement [to be supplied if in dispute] UPPER ALLEN TOWNSHIP 100 GETTYSBURG PIKE MECHANICSBURG, PA 17055-5~98 717-768-075§ HOURS MON, THRU FRI. 8A.M. TO 4;30P.M. SEWER BILLING SERVICE LOCATION= MERRIMAC AVENUE 2177 ACCOUNT NUMBER : 6110276113 BILLING PERIOD : 3RD QTR PREVIOUS BALANCE : .00 CURRENT CHARGES : 100.00 IF PAID BY 10~31~01 lO0.O0 11/30/01 105.00 12/31/01 105.53 EXHIBIT 23 Sewer Bill Billing Summary for Service to: BRADLEY J SANDERS 2177 MERRIM^C AVE MECHANICSBURG PA 17055 Rate ClaeaiRcation: Residectia[ Heating Billing Period: 08/29/2001 to 06/28/2001 (30 days) Estimated Read ' Your current UGI charges include State taxes totaling $1.44. ~ast Bill Information. UGI rhe account balance on your last bill was ................ Thank you for your Payment of ..................................... Your balance as of 10/02/2001 ................................... -' Current Bill Information - UGI Customer Charge .............................................................. Commodity Charge ( 30 CCF at $0.73967) .............. Distribution Charges (F rst 30 CCF at $0,46867) ... Pipeline Surcharge ........................................................... PAStata Tax 3umharge .................................................. Total Current Charges (due by 10/24/2001) ............ ' Total Charges Due. UGI ............................................... Total Amount Due · ~ 40.22 ~- ,~ ,,,~; ~ -40.22 203 705 3040 10 0.00 if you have any questions, please call us at 717-232-18 t 1, or write to POBX 13009, Reading, PA 19612-3009. Please 8,55 contact us by October 24. 22,19 -0,04 44.69 /October29' 2001 $ 44.69 $ 44.69 NPN 203 705 3040 10 1 5.00 4.50 4.00 3.50 3.00 2.50 2.001 1.50 1.00 ' 0.50 0.00 2000 Months 2001 · = Estimated Usage Last This Average Year Year CCF/day 1.03 1.00 Daily temperature 66oF 65OF Meter Reading Information ,;:=;ar Number Previous Reading Present Reading CCF Used 1270412 1559 (company) 1589 (estimated) 30 Messages from UGI · Your current pdce to compare is $ 0.73529/CCF · Your total annual usage is 75 I. Your average monthly usage is 62. · We can make your energy costs easier on your budget with oar 12 month EMP plan. Your monthly payment would bo approximately $ 86.00, For more information about this plan call UGL · Help prevent pip~line damage, accidents and service disruptions. If you see someone digging near your home please call UGL if you pay at a Payment agent please take your entire bill. Make check payable to UGI, Keep this part for your records. Important information is on the back of this bill. EXHIBIT 24 UGI bill PPL Electric Utilities Dpl Page 3 i Your BillAceom~t Nut,bet 01290-76017 USe when calling' ~' Writing Electric Service 2i 77 MFA{RIMAC AYE PPL Electric Utilities Customer Service 827 Hausman Rd. Allentown, PA 18104-9392 1-800-342-5775 www.pplweb.com Total from Last Bill Pa?tne- nt Received Sep 4 - Thank You ! $74.79 $ 74.79 Billing Details Balance as of Sep 13, 2001 $ 0.00 Current Charges RCehar, ges lbr - PPL ELECTRIC U. TILITIES siaential Rate: RS for Aug 14 - Sep 13 Distributiou Charee: Customer Charge 6.47 200 KWH at 1.79600000¢ per KWH 3.59 397 KWH at 1.59400000¢ per KWtt 6.33 Transmission Charge: 597 KWH at 0.37700000¢ per KWlt 2.25 Transition Charge: 200 KWH at ~1.88700000¢ per KWI. I 3.77 397 KWH at 1.67400000¢ per KWIt 6.65 Generation Charge: Cal~acltv and Euergv --00 KWH at 4.8'4600000¢ per KWIt 9.69 PA T3ax97AdKiuWsH at 4.25600000¢ I~er KWH 16.90 .... ~ stment Surcharge af-0.73000000% -0.41 r~. ~aies ~ax 3.32 Total PPL ELECTRIC UTILYFIES Charges $ 58.56 Account Balaflce $ 58.56 General Information readin~ on or a'boul Oct 12 Gen.eration. prices ~d c,,ha, rges_a.r.e..set by the.electric generation sup )lief you nave Chosen I ne runnc Uti ~ty Comnnssion rec, ulates distrilSutiou prices and services. The Federal Energy Regulatory-Commission regulates transnfission prices aud services: PPL Electric Utilities uses about $5.46 of this b to var state taxes. In addition, about $2.43 of this bill pays the PA Cross Re&ipts Tax. The Transition Charge inclndes all I l angible Transit on Charee I'ITC) and [he applicable gross receipts tax which to,eether amouut to 5;8 '3' TbS ITC' ~ p~,r usage c.~arge approved by the Pub3 c Utility Comm~:~' x~l~';~-I~- ~ ,~ * F~ctnc l Jr,Jmes collec.ts, a.s ageut for PPI. Electr c I. Jt,ht es Trans on Dona Lompany LLC and wh ch that compauv uses to service dc ~ incurred to recover a portio ~ of PPL Electric Uti[itms'%trnnded costs. The cross receipts tax. which s collected for the £ ommonwe..I,h ..c r, ...... ,~ · · equa to ,4 4¥0 or the 11 For your couvenience, you can uow pay your bill us/ne, your Visa, MasterCard Discover or Americm~ E>/press Card Ca'll'BillMatrix *it 1-800-672-]413 Billl~atrix will charge your credit card a service fee for making this payment. Dish w~hers~use about 13 Izallons of hot water per load. ~l'~at's less than washing dishes by hand. ATways use tull loads o ~ ~e shortest crc e When washing dishes by baud, don't let the hot water run continhously. Save postage and late charges - sign up for Automated Bill Payment. EXHIBIT 25 PP&L bill IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW AND DIVORCE BRADLEY SANDERS, Plaintiff, ALISON SANDERS, Defendant. ) ) ) ) ) ) ) ) ) No. FD: 01-5654 Civil Team Type of Pleading: ANSWER TO AMENDED COMPLAINT IN DiVORCE AND COUNTERCLAIM Filed on behalf of.' ALISON SANDERS, Defendant Counsel of Record: D. SCOTT LAUTNER, ESQUIRE Pa. I.D. No. 80134 68 Old Clairton Road Pittsburgh, PA 15236 (412) 650-8820 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW AND DIVORCE BRADLEY SANDERS, ) ) Plaintiff, ) ) v. ) ) ALISON SANDERS, ) ) Defendant. ) No. FD: 01-5654 Civil Team ANSWER TO COMPLAINT IN DIVORCE AND COUNTERCLAIM AND NOW COMES, Defendant, Alison Sanders, by and through her counsel, D. Scott Laumer, Esquire and files the within Answer to Amended Complaint in Divorce and Counterclaim and avers as follows: COUNT I - DIVORCE 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8.a. Specifically denied. 8.b. Specifically denied. 8.c. Specifically denied. Moreover, specific proof is demanded thereof. 8.d. Specifically denied. Moreover, specific proof is demanded thereof. WHEREFORE, Defendant, Alison Sanders, prays this Honorable Court to equitably divide, distribute, award or assign marital property between the properties pursuant to Section 3502 in the Divorce Code of 1980, as amended. COUNT II - EQUITABLE DISTRIBUTION 9. Paragraph 9 incorporates prior paragraphs by reference and as such, no response is required. 10. Admitted. 11. Admitted. 12. Admitted. WHEREFORE, the Defendant, Alison Sanders, prays this Honorable Court to equitably divide, distribute, award or assign the marital property between the parties pursuant to Section 3502 of the Divorce Code of 1980, as amended. COUNTERCLAIM COUNT I - INJUNCTION FROM DISSIPATION OF MARITAL PROPERTY PENDING SUIT 13. Paragraphs 1 through 12 are hereby incorporated by reference as if set forth at length, herein Counterclaim I - Injunction from Dissipation of Marital Property Pending Suit. 14. The parties' own marital property as defined in the Pennsylvania Divorce Code, as amended. 15. The removal from this jurisdiction, disposal of, alienation, encumbering and/or dissipation of marital assets by the Plaintiff would be detrimental to the rights of the Plaintiff and would defeat the intent of the divorce code, all of which would irreparably harm the Defendant. WHEREFORE, Counterclaim Plaintiff, Alison Sanders, prays this Honorable Court to enjoin Counterclaim Defendant, Bradley Sanders, from disposing alienating, encumbering, or dissipating any and all marital assets COUNTERCLAIM COUNT II - COUNSEL FEES~ COSTS AND EXPENSES COUNT IV - COUNSEL FEES~ COSTS~ AND EXPENSES 16. Paragraphs 1 through 15 are hereby incorporated by reference as if set forth at length, herein Counterclaim Count II - Counsel Fees, Costs and Expenses. 17. The Counterclaim Plaintiff is financially unable to pay her counsel fees and the costs and expenses of prosecuting this action. 18. The Counterclaim Defendant is financially able to pay for the Counterclaim Plaintiff's counsel fees and the Counterclaim Plaintiff's costs and expenses of prosecuting this action. WHEREFORE, Counterclaim Plaintiff, Alison Sanders, prays this Honorable Court, to grant interim and final counsel fees, costs and expenses for the Counterclaim Plaintiff which are reasonably related to the above-captioned matter. COUNTERCLAIM COUNT III - SPOUSAL SUPPORT AND ALIMONY PENDENTE LITE 19. Paragraphs 1 through 18 are hereby incorporated by reference as if set forth at length, herein Counterclaim Count III - Spousal Support and Alimony Pendente Lite. 20. The Countemlaim Plaintiff lacks sufficient property to provide for her reasonable needs during the pendency of this action. 21. The Counterclaim Defendant is financially able to provide for the reasonable needs of the Counterclaim Plaintiff during the pendency of this action. WHEREFORE, Counterclaim Plaintiff, Alison Sanders, prays this Honorable Court, to grant spousal support and alimony pendente lite for the Counterclaim Plaintiff, which are reasonably related to the above-captioned matter. COUNTERCLAIM COUNT IV - PERMANENT ALIMONY 22. Paragraphs 1 through 21 are hereby incorporated by reference as if set forth at length, herein Counterclaim Count IV - Permanent Alimony. 23. Counterclaim Plaintiff lacks sufficient income and property to provide for her reasonable needs and is unable to support herself fully through appropriate employment. 24. Counterclaim Defendant is financially able to provide for reasonable needs of the Counterclaim Plaintiff. WHEREFORE, Counterclaim Plaintiff, Alison Sanders, prays this Honorable Court, to grant permanent alimony for the Counterclaim Plaintiff which are reasonably- related to the above-captioned matter. COUNTERCLAIM COUNT V - INSURANCE AND OTHER BENEFITS 25. Paragraphs 1 through 24 are hereby incorporated by reference as if set forth at length, herein Counterclaim Count V - Insurance and Other Benefits. 26. There exists certain contracts of policies of insurance insuring the life of the Counterclaim Plaintiff and Counterclaim Defendant and insuring coverage for health and medical expenses for the Counterclaim Defendant and Counterclaim Plaintiff as well as their minor child. 27. Counterclaim Plaintiff believes and therefore avers that she is the designated beneficiary of said life and health insurance policies. 28. Said contracts or policies of insurance and other benefits are vital to the Plaintiff to ensure her support, maintenance and/or alimony, and payment of other expenses should the Counterclaim Defendant die or if the Counterclaim Plaintiff should become ill. Counterclaim Defendant is financially able to provide for reasonable needs of the Counterclaim Plaintiff. WHEREFORE, Counterclaim Plaintiff, Alison Sanders, prays this Honorable Court, to grant insurance and other benefits for the Counterclaim Plaintiff, which are reasonably related to the above-captioned matter. Respectfully submitted, Attorney for Defendant CATION arc [ruc~' aild con-eot. I understand/hat false statements herein m*e made subjecl to the penalties of 18 Pa. C,S 4904, relati ~g to cmsworn falsificalion lo authorities. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW AND DIVORCE BRADLEY SANDERS, ) ) Plaintiff, ) ) v. ) ) ALISON SANDERS, ) ) Defendant. ) No. FD: 01-5654 Civil Team CERTIFICATE OF SERVICE I, D. Scott Laumer, Esquire, certify that a true and correct copy of the within Answer to Amended Complaint in Divorce and Counterclaim via U.S. First Class Mail on the [9 day of t~ c', \ ,2002 to the following: DIANE G. RADCLIFF, ESQUIRE 3448 Trindle Road Camp Hill, PA 17011 D. Scott Laut~, Esquire Attorney for Defendant Bradley Sanders/4.23.02/Motion for Sanctions BRADLEY SANDERS, Plaintiff ALISON SANDERS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-5654 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE pLAINTIFF'S MOTION FOR SANCTIONS pURSUkNT TO RULE 4049 AND NOW, this~ay of April, 2002, comes the Plaintiff, Bradley Sanders, by his attorney, DIANE G. RADCLIFF, ESQUIRE, and files this Motion for Sanctions and in support thereof represents the following: 3 o The parties hereto are husband and wife having been married on October 8, 1994 and separated on September 25, 2001. The within action was commenced by the filing of a complaint on October 5, 2001. In the complaint a request for divorce under Section 3301(c) was requested. The aforesaid complaint was served upon the Defendant by certified mail, restricted delivery on October 5, 2001. 22, 2001 the Defendant, Alison Sanders, filed an Answer and complaint, in which counterclaim equitable distribution, counsel fees, On October Counterclaim to the she raised claims for injunction from dissipation of marital property, - 3 Bradley Sanders/4.23.02/Motion for Sanctions costs and expenses, spousal support, alimony pendente lite, permanent alimony, insurance and other benefits. On March 28, 2002 Plaintiff filed an Amended Complaint raising a claim for divorce on the basis of no-fault, indignities and adultery and additionally raising a claim for equitable distribution. The Amended Divorce Complaint was served upon Defendant's legal counsel under cover of letter dated April 1, 2002 On March 25, 2002 Plaintiff filed his Income and Expense Statement and Inventory which were served upon the Defendant's legal counsel under cover of letter dated March 25, 2002. A true and correct copy of the March 25, 2002 letter is attached hereto, marked Exhibit "A" and made a part hereof. On April 16, 2002 Plaintiff filed an Amended Income and Expense Statement to include his 2001 income tax return and pay stubs which were inadvertently deleted from the prior filing, which was served upon Defendant's legal counsel under cover of letter dated April 16, 2002. By letter dated April 1, 2002, Plaintiff's legal counsel requested Defendant's legal counsel to have the Defendant file her Income and Expense Statement and Inventory. A true and correct copy of the April 1, 2002 letter is attached hereto, Bradley Sanders/4.23.02/Motion for Sanctions - marked Exhibit nB" and made a part hereof. By letter dated April 16, 2002, Plaintiff's again requested Defendant's legal Defendant file her Income and Expense legal counsel counsel to have the Statement and Inventory within one (1) week of the date of that letter. A true and correct copy of the April 16, 2002 letter is attached hereto, marked Exhibit "C" and made a part hereof. 10. By letter dated April 16, 2002 Plaintiff's legal counsel advised Defendant's legal counsel that unless Defendant's Inventory and Income and Expense Statement was filed within one (1) week of the date of that letter that she would proceed with requesting the imposition of sanctions against the Defendant. 11. The Pennsylvania Rules of Civil Procedure require that each party file an Inventory and Income and Expense Statement within sixty (60) days of the date of filing of a complaint in divorce or other pleading in which a claim for economic issues have been raised. 12. More than sixty (60) days has elapsed since the filing of the 13. Answer and Counterclaim to the Divorce Complaint which includes claims for economic matters. To date of this filing no Inventory or Income and Expense Bradley Sanders/4.23.02/Motion for Sanctions 14. 15. 16 17 18 Statement has been filed by Defendant. Despite numerous demands for such filing as aforesaid, Defendant has failed and refused to Income and Expense Statement. Plaintiff has incurred attorney's fees file her Inventory as the result the and of this Defendant's failure to file her Inventory and Income and Expense Statement and claim is made therefor. A copy of this Motion was provided to Defendant's legal counsel on April 24, 2002 in which it was inquired as to whether or not he would agree to the relief requested therein. A true and correct copy of the letter dated April 24, 2002 is attached hereto, marked Exhibit "D" and made a part hereof. Defendant has not responded to this inquiry and it is therefore assumed that Defendant opposes the requested relief. No prior judge has been assigned to this case. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an Order that: A. The Defendant be ordered to file her Income and Expense Statement and Inventory within fifteen (15) days of the date of this Order. B. If the Defendant fails to file the Income and Expense Bradley Sanders/4.23.02/Motion for Sanctions Statement Inventory and Inventory within the fifteen (15) day time period, the Defendant be denied the right to present any testimony or evidence regarding any matter that would have been revealed by her Income and Expense Statement and including, but not limited to, any testimony, exhibits or evidence regarding her income and expenses or any testimony regarding the identification or valuation of any marital assets. The Defendant be ordered to pay the reasonable attorney's fees and costs incurred by the Plaintiff in bringing this action. Respectfully submitted, ~LL~--~R~JDC~ F F, ESQUIRE ~_~448 T~_~dle Road a~Hill, PA 17011 Phone: (717) 737-0100 Attorney for Plaintiff Bradley Sanders/4.23,02/Motion for Sanctions CERTIFICATE OF SERVICE RADCLIFF, ESQUIRE, hereby certify that I have this day served a copy of the foregoing document upon the following named person, by mailing same by first class mail, postage prepaid, addressed as follows: Scott Lautner, Esquire 68 Old Clairton Road Pittsburgh, PA 80134 Respectfully submitted, D~E ~.~_R~~SQUIRE 3448 Trindle Road Camp Hill, PA 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 DIANE G. RADCLIFF, ESQUIRE Attorney at Law 3448 Trindle Road Phone: (717) 737-0100 Camp Hill, Pennsylvania 17011 Facsimile: (717) 975-0697 March 25, 2002 D. Scott Lautner, Esquire 68 Old Clairton Road Pittsburgh, PA 80134 RE: Sanders v. Sanders Dear Scott: I am enclosing with this letter copies of the Plaintiff's Income and Expense Statement and Inventory which were filed with the Court on March 25, 2002. Also enclosed are copies of the documents that I have in my possession which verify the values set forth on this Inventory. I would like you to note that it is my intention to file an Amended Complaint in Divorce, raising claims for divorce on the basis of adultery and indignities. I will also be raising a claim for equitable distribution. I have prepared the amended complaint and forwarded it to my client today. I anticipate filing the same with the Court by the end of this week. A certified copy of that document will be forwarded to you upon filing. Upon that filing it is my intention to file a Motion for Appointment of Master to hear the addition divorce claims as well as the economic issues that may be raised in this case. It is, of course, your obligation to file your client's Inventory and Income and Expense Statement. I trust that you will do so in the near future. EXHIBIT "A" March 25, 2002 Letter Page 2 Should you have any questions or comments or if you would like to advise me of your client's willingness to consent to the divorce, please advise me. Very truly yours, DGR/rzg Enclosure cc: Bradley J. Sanders DIANE G. RADCLIFF, ESQUIRE DIANE G. RADCLIFF, ESQUIRE Attorney at Law 3448 Trindle Road Phone: (717) 737-0100 Camp Hill, Pennsylvania 17011 Facsimile: (717) 975-0697 April 1, 2002 D. Scott Lautner, Esquire 68 Old Clairton Road Pittsburgh, PA 80134 RE: Sanders v. Sanders Dear Scott: I am enclosing with this letter a certified copy of the Amended Divorce Complaint which was filed with the Prothonotary of Cumberland County, Pennsylvania, on March 28, 2002. I am also enclosing with this letter a copy of the Motion for Appointment of Divorce Master which was filed on April 1, 2002. Should your client desire to discuss settlement of this case, do not hesitate to contact me. Otherwise I will anticipate the filing of your client's Inventory and Income and Expense Statement. Very truly yours, DGR/rzg Enclosure cc: Bradley J. Sanders DIANE G. RADCLIFF, ESQUIRE EXHIBIT "B" April l, 2002 Letter DIANE G. RADCLIFF, ESQUIRE Attorney at Law 3448 Trindle Road Phone: (717) 737-0100 Camp Hill, Pennsylvania 17011 Facsimile: (717) 975-0697 April 16, 2002 D. Scott Lautner, Esquire 68 Old Clairton Road Pittsburgh, PA 80134 RE: Sanders v. Sanders Dear Scott: In reviewing my file I noted that when I filed my Income and Expense Statement I did not include the required pay stubs and income tax returns as required by the Rules of Civil Procedure. I have corrected that oversight by filing an Petition for Appointment of Master on Additional Claims, a copy of which is enclosed with this letter. I again must remind you that the Rules of Civil Procedure require that a full Income and Expense Statement, together with pay stubs and tax returns, be filed by both parties within sixty (60) days of the date of filing of the Divorce Complaint. Obviously that time period has long passed. I had previously requested that you file such a document on behalf of your client. To the date of this letter, however, no such document has been filed. This letter is to advise you that unless your client files her Inventory and Income and Expense Statement within one (1) week of the date of this letter, I will proceed with requesting the imposition of sanctions against her. I, therefore, assume that you will comply with this last request. Very truly yours, DGR/rzg Enclosure cc: Bradley J. DIANE G. P~ADCLIFF, Sanders EXHIBIT "C" April 16, 2002 Letter ESQUIRE DIANE G. RADCLIFF, ESQUIRE Attorney at Law 3448 Trindle Road Phone: (717) 737-0100 Camp Hill, Pennsylvania 17011 Facsimile: (717) 975-0697 April 24, 2002 D. Scott Lautner, Esquire 68 Old Clairton Road Pittsburgh, PA 80134 RE: Sanders v. Sanders Dear Scott: I am enclosing with this letter a copy of the Pre-Trial Statement which is being forwarded to the Prothonotary for Filing on behalf of my client, Bradley Sanders. Attached as part of this Pre-Trial Statement are all of the documents Brad and I have in our possession regarding my client's income and the parties' marital assets and debts. I know of no other documents which have any relevance in this case. If you, however, have any specific requests please advise me and I will attempt to secure those documents for you within one (1) week. I am in receipt of your letter dated April 19, 2002 directed to the Divorce Master advising him that it is your opinion that discovery was not complete and that you anticipated it would not be so completed until June 30, 2002. You further stated that you have not been afforded an opportunity to take the Plaintiff's deposition, serve Requests for Production of Documents and/or Interrogatories to the Plaintiff. I take exception to these statements made to the Divorce Master based on the following: On February 15, 2002, I forwarded the enclosed letter providing you with my Analysis of the Marital Assets and Debts and Proposed Distribution Schedule. In that letter I requested that you respond to me within two (2) weeks of the date of that letter regarding this proposal. To date you have not responded to this letter. EXHIBIT "D" April 24, 2002 Letter Page 2 5 o On February 22, 2002, I forwarded to you the enclosed letter indicating that I had been advised by my client that his wife was not agreeable to our settlement proposal. I further stated that to keep the momentum going in the case I requested that you advise me of any documentation or appraisals that you required to be able to move the case forward including, if necessary, information pertaining to the name, address and phone number of the appraiser you wanted to use. Again I requested a response from you within two (2) weeks of the date of that letter. To date you have not responded to this letter. On February 28, 2002, I forwarded to you a letter advising you of your client's sale of the Eagle automobile for the sum of $3,500.00 and based thereon provided you with a revised analysis form. I again requested your response to my prior correspondence regarding any documents or appraisals that you needed to evaluate the case. To date you have not responded to this letter. On March 8, 2002, I forwarded to you the enclosed letter again requesting that you inform me of any documentation, information or appraisals that you required to evaluate the case and further advising you that upon receipt of any documentation that I had in my possession that were set forth on my analysis I would provide the same to you. To date you have not responded to this letter. On March 25, 2002, I forwarded to you the enclosed letter providing you with a copy of my client's Inventory and Income and Expense Statement which were filed with the Court on March 25, 2002. In that letter I provided you with copies of all the documents that I had in my possession which verified the values set forth on my Inventory. In that letter I reminded you of your obligation to have your client file an Inventory and Income and Expense Statement. To date you have not responded to this letter. On April 1, 2002, I forwarded to you the enclosed letter Page 3 providing you with a copy of my Amended Divorce Complaint which was filed with the Prothonotary on March 28, 2002. I also provided you with a copy of the Motion for Appointment of the Divorce Master which I filed on April 1, 2002. In that letter I also stated that you should contact me if you wanted to discuss any settlement. I again reminded you of the necessity to file your client's Inventory and Income and Expense Statement. To date you have not responded to this letter. On April 16, 2002, I forwarded to you the enclosed letter providing you with an Amended Income and Expense Statement. I again reminded you of the necessity of filing an Income and Expense Statement with pay stubs and tax returns as required by the Rules of Civil Procedure. I also reminded you of the necessity of filing your client's Inventory. To date you have not responded to this letter. On April 18, 2002, I forwarded to you the enclosed letter advising you that I was going to amend the Motion for Appointment of Master to include the claims previously raised by you for alimony pendente lite, alimony, counsel fees, costs and insurance. Except for being copied on the letter that you directed to the Divorce Master on April 19, 2002, you have not forwarded to me any correspondence nor responded to any of the letters outlined above. It would appear that you have had in your possession all of the relevant and all available documents that my client had since March 25, 2002. There are no other documents that can be provided to you since all of the documents were previously provided in that letter and are again being provided to you by way of the filing and service of this Pre-Trial Statement. You have been officially involved in this case since October 22, 2001 and have yet to serve upon my client any requests for discovery or to schedule any deposition. I have indicated my willingness to provide you with any information that you may request as of February 22, 2002. No response has been received Page 4 from you since that offer was made. I, therefore, believe that the certification to the Divorce Master that discovery is not complete and you have not been afforded the opportunity to have discovery was made in bad faith for no other reason than to delay the matter so your client can continue to receive spousal support. If your client wants to engage in discovery I would expect to receive your discovery requests within one (1) week of the date of this letter. There is no reason to delay the matter to June 30, 2002 as you have indicated to the Divorce Master. If you want to take a deposition we are willing to comply. It must, however, be scheduled immediately. Very truly yours, DGR/rzg Enclosure 2/15/02 letter 2/22/02 letter 2/28/02 let~Z~ 3/8/02 letter 3/25/02 leitter 4/1/02 letter 4/16/02 letter 4/18/02 letter cc: Bradley J. Sanders DIANE G. RADCLIFF, ESQUIRE Bradley Sanders/4.23.02/Motion for Sanctions BRADLEY SANDERS, Plaintiff ALISON SANDERS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-5654 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE RULE RETURNABLE PLAINTIFF'S MOTION FOR ORDER FOR SANCTIONS AND NOW, this /9~ day of ~ , 2002, upon consideration of the within Motion, a Rule is entered upon the Defendant, Alison Sanders, to show cause why the relief requested in the within Motion should not be granted. Rule returnable ~O days after service hereof. THE DISTRIBUTION TO: Diane G. Radcliff, Esquire 3448 Trindle Road Camp Hill, PA 17011 Attorney for Plaintiff D. Scott Lautner, Esquire 68 Old Clairton Road Pittsburgh, PA 15236 Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW AND DIVORCE BRADLEY SANDERS, Plaintiff, V. ALISON SANDERS, Defendant. No. FD: 01-5654 Civil Team Type of Pleading: INCOME AND EXPENSE STATEMENT Filed on Behalf of: Alison Sanders, Defendant Counsel of Record for this Party: D. SCOTT LAUTNER, Esquire Pa. I.D. no. 80134 68 Old Clairton Road Pittsburgh, PA 15236 (412) 650-8820 PART I. INCOME A. EMPLOYMENT INFORMATION: 4PLOYER: ~,ESS: POSITION: =.OLL NUMBER: PAY PERIOD: ~nell 45 Limekiln Road Suite 100 New Cumberland, PA 17070 Manager B. EMPLOYMENT INCOME: GROSS PAY PER PAY PERIOD $3,750 Monthly TEMIZED DEDUCTIONS FICA MEDICARE OR SE TAX FEDERAL TAX STATE TAX LOCAL TAX MANDATORY RETIREMENT UNION DUES HEALTH INSURANCE $17.00 Dental VOLUNTARY RETIREMENT OTHER: APL TOTAL DEDUCTIONS NET PAY PER PAY PERIOD NET PAY PER MONTH 32,234.46 C. OTHER INCOME: DESCRIPTION MONTHLY YEARLY INTEREST DIVIDENDS PENSIONS ANNUITIES SOCIAL SECURITY RENTS ROYALTIES -'XPENSE ACCOUNT SIFTS UNEMPLOYMENT COMPENSATION WORKMAN'S COMPENSATION INCOME TAX REFUND ;UPPORT OR ALIMONY $320.00 COMMISSIONS TIPS OTHER SPECIFIY: TOTAL OTHER INCOME PART II. EXPENSES DESCRIPTION WEEKLY AMT. MONTHLY AMT. ANNUAL AMT. --irst Mortgage Mortgage/Home Equity Loan Maintenace and Repairs Electric ;5.00 )hone 'ublic Tranportation Lunches ;100.00 i.00 I Other Em ~ment Real Estate Taxes Persoanl Property Taxes Taxes Homeowners Insurance ,mobile Insruance Life Insurance Insurance ~lth Insurance Other Fuel Maintenance and Repair License and istration ;75.00 i$100.00 $700.00 ,ntic licine NeedsFFhera DESCRIPTION WEEKLY AMT. MONTHLY AMT. ~,NNUAL AMT. =rivate School Parochial School College/Vocational P, eligious Training or Education Books/Fees and Supplies Clothing $250.00 Food $200.00 3arber and Hair Dresser $50.00 Memberships No. ~ Creditor: Real Estate Taxes Persoanl Property Taxes Household Help ~,hild Care Newspaper/Magazines/Books Entertainment $100.00 Pay TV Vacations Gifts Legal Fees $2,935.00 Charitable Contributions Other Child Support ( not the subject of this action) Other Spousal Support or Alimony TOTAL EXPENSES PART III. PROPERTY OWNED TYPE DESCRIPTION H / W / JT Checking H / W / JT Savings H / VV / JT Credit Union H / W / JT Stocks / Bonds H / VV / JT Real Estate H / W / JT Other H / W / JT PART IV. INSURANCE TYPE COMPANY POLICY NO. H / W / C Hospital/Blue Cross Medical/Blue Shield Health Accident Disability Income Dental Vision Other Specif}t * H=Husband; W=Wife; JT= Joint; C=Child PART V. SUPPLEMENTAL INCOME STATEMENT [ ] CHECK HERE IF NOT APPLICABLE (a) This form is to be filled out by a person: (1) Who operates a business 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) Attach to this statement a copy of the following documents relating to the partnership, joint venture, business, profession, corporation or similar entity (check block to indicate the document is attached): (1) The most recent Federal Income Tax Return [ ] Attached (2) The most recent Profit and Loss Statement [ ] Attached (c) Name of Business: Business Address: Business Telephone: Alison Sanders PO Box 1224 Mechanicsbur~l (717) 877-1252 (d) Nature of Business (check one) X] 1. Sole Proprietorship ] 2. Partnership ] 3. Joint Venture ] 4. Professional ] 5. Corporation ] 6. Other (e) Name of accountant, controller or other person in charge of finacial records: (f) Business Income: 1. Annual income from business: 2. How often is income received: 3. Gross income per pay period: 4. Net income per pay period: 5. Specify deductions, if any: ISporatic $2,083.10 $1706.06 y/t/d $377.04 05/t7/200~ 1~:0! FAX ~Y~O~-200~ ~?]9 01:~1 PM ~IMPL.cX 05/17/~002 12;01 FA1 FF~ NO, 7i7~816807 ~ 00~ 03/12 [~FiV-08-~O0;~ IJED 01:3~ P~I ~!~I?LEX FP~X ;~0, 717~91~807 ?. O4/l~ o~t~m o! I~ T'm~..zPi/~ Iffi~m~f ~e',~Ru& U.~ Irld~¥Jdul~ IiI~Q,I~ 1'iix Koenn 1 Ill ?i~¢m I~ltrti~t ~ ~cl-,~t~ B ~ m~ulmd ................................... 42 42 111. 42. 05/17/2002 12:02 FAX P, 05/12 /u~um,~omU~a.~ (~juma~,~.~ mcor~) ..................................... ~4L - 42 ~ 866. 7.58?. G7 soo m'~. d ~n~ fit ,n asP, e e~. *nd eed. ~ Amount ~0 Yo~ Owe 7t 900. 6,07G. 16'2., 810. ~48. 648. 05/:L7/2002 12:03 FAX NO, ~" ~ ~ 06/12 (Form N~) ~ on ;arm Schedule A -- Itemized Deductions ~ to Poo~ 10~0, P, mmm )n., .'aJ~/~'ll? f)rj.34jlmdulm A (Fe~ lO4Ok, M~JloJ{ ~en~l 5 (~ 7 ~lft~ to T~tml Itemized tlOr~ Foe Psp(,~v,~rk RMIuetlaR ~ N~M, ~ ~ ~ ~O~, OMB No, 2001 ~ueqG~ NO. 07 L9~-5~ ,L74 "104(1: lite ~l-, aver $1~,,E,GeO lover $61i,475 if mJnied fdlr,8 #RirMMy.' ? ¥=~r de~Juc~tle~ id; ,~at I~. Add 1]~ .~r~l twa in i:hu ~m ~*igb/ tm' [i:lee · tt~,ugh ~'}'. A~a. r~t~'lh~ er~okml on Porto 1040. '/our ~u=~, ~ be li~ed. See I~*t~ tX ~ _a~ourn 05,17/2002 12:04 FAX ~Y-~-2002 WE~ 01;35 ~H ~i~?LEX ~I7o,~2~07 Net Profit From Bu~lnea8 ~lpe, ~lm vM~lrM, eta,, ~ ~ FE~ tM$ ~ t~ ,~ OendIml I~fOmtWon o~ ff You: Cleaninj~ j{-l. MIr mndl ~m ~nu iO BJlN~uyir ID Iq: (EJe4), It an)' k't~l:)lWlMlOq I~ Y(~r V~lll(~l. Carn~ed~ th~ par~ Oldy f ~ou ll~ ~4~r~h~ o~' or ,tru~ exper~,~ on In~ 8, O~ SCHEDULE SE i Serf-Employment Tax {~o~m t~o. ,~s-~ WTto MU~t File S~l~e(lule GE Y~j n~mt I~ $O~aLie ~B~ {: · i) Ql S~ or ~. ~n ~ ~ h~ E ~n ~ I ~ ~nt oi ~ ~m M~GT~ k ~ ~ m ~; ~ ~ ~ ~ ~ and u~ May I Oee &hoR ~e~ {E or Mu~ I ~ ~ng Schedule S~ { ~L.)~_:on A -- ~l~ort Odqeclule BE. (~utiOn. Reed ~ m, ~ ,~ you :an um ~hofi ~=M=um 3E. 2 ~ne t~ .............................................................................. line ~ Mo'~ than ~, 592. 84. 42 ~le $1E (l~rm lodma) ~9ol lltlY-08-~02 WED 01:36 PM SIll?LEX PLEASE I BO NOT U~E YOUR CABBI. SANDER~ BOX 1224 FAX ~, 7]789!6807 2001 ~A~ ~ oF · ~79-6~-46~ i EX ~ AL~ON m FY XX PN 'rA 42974,0D 5 D,rl§ 8 O,OO ~009 r' R~ R 0 L_ O.gO 1¢ 4~474.00 O.O0 4 SqE,O§ O.Og 7 O.OO IggO-OO ~LO Peele ALO~ 'm~ J~ t, mamf~l ['l-~m~ (Mat 'n~ Sp~.~) Omea Gornpeeaetien, ~o the irlated~gne ........ , ........ ,, .............................. la 592, 43,566. 1~220. 05~17/~002 12:0~ h1AY-08-~¢02 I~D 0i:37 P~ ~I~iPLEX ~!~ ~0. 71769:6B07 ~OlO P, IO/~ Z,220~ .......... P~ ~ .... ~ Jeff SC~bleffeld Acct. ~vcs. ~{27/2~02~1'7-652-1485 L 0100E~6~6 ~ P~ .~;~,,c 0100~tA6B6 05/'17/2002 12:07 FAX I~Y-~8-~O0~ WF.~ 01:37 ?N 27.2; ~50 - 05/17/200~ 12:07 I1~Y-88-2002 ~101 ;~ P. 12/I2 PA S~'le~lUle C pA-4o c ~'~) _. _ Oo VERIFICATION are l~'t~e and correcI. ~ m~derstand tL'at false statements herein are made su~iecl: to the penalties of 18 Pa. C,S. 4904~ relating to unswom falsS~calion to authorities. BPJkDLEY SANDERS, Plaintiff ALISON SANDERS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-5654 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 2 o 3 o A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 27, 2001. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the decree. 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. BRADLEY SANDERS BRADLEY SANDERS, Plaintiff ALISON SANDERS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-5654 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE 2 o 3 o WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c~ OF THE DIVORCE CODE I consent to the entry of a final decree in divorce without notice. 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 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. Section 4904 relating to unsworn falsification to authorities~~ ~~ Dated: 5/~I~D - J~~ ~ ' BRADLEY SAN~RS' ~ ~ 217 BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT BRADLEY SANDERS, Plaintiff ALISON SANDERS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-5654 : : CIVIL ACTION - LAW : DIVORCE MARITAL AGREEMENT BETWEEN BRADLEY J. SANDERS AND ALISON M. SANDERS BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT TABLE OF CONTENTS INTRODUCTION ............................................. 1 SECTION I General Provisions ....................................... 3 SECTION II Distribution of Property ................................. 20 SECTION III Distribution of Debts ................................... 29 SECTION IV Counsel Fees And Costs, Alimony, Spousal Support ......... 34 SECTION V Closing Provisions and Execution ......................... 36 BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT INTRODUCTION THIS AGREEMENT made this ~'~ day of 2002, by and between ALISON M. SANDERS ("Wife") of 208 Louisa Drive, Mechanicsburg, PA 17050 and BRADLEY J. SANDERS ("Husband") of 2177 Merrimac Avenue, Mechanicsburg, PA 17055. W I TNE S E TH : WHEREAS, the parties hereto are husband and wife, having been married on October 8, 1994 in Elizabeth, Pennsylvania and separated on September 25, 2001. WHEREAS, There were no children born of this. WHEREAS, diverse and unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Husband and Wife to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property - 1 - BP~ADLEY SANDERS/5.21.02. M~LRITAL AGREEMENT rights and obligations as between each other including, without limitation by specification: the settling of all matters between them relating to the ownership and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present and future support, alimony and/or maintenance of Wife by Husband or of Husband by Wife; and in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. NOW, THEREFORE, in consideration of the premises and mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: THIS SPACE INTENTIONALLY LEFT BLANK - 2 - BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT SECTION I GENERAL PROVISIONS 1 . 01 . INCORPORATION OF PREAMBLE The recitals set forth in the Preamble of this Agreement are incorporated herein and made a part hereof as if fully set forth in the body of the Agreement. 1.02. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS This Agreement shall not be considered to affect or bar the right of Husband and Wife to an absolute divorce on lawful grounds if such grounds now exist or shall hereafter exist or to such defense as may be available to either party. This Agreement is not intended to condone and shall not be deemed to be condonation on the part of either party hereto of any act or acts on the part of the other party which have occasioned the disputes or unhappy differences which have occurred or may occur subsequent to the date hereof. 1.03 . DIVORCE DECREE The parties acknowledge that their marriage is irretrievably - 3 - BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT broken and that they will secure a mutual consent no-fault divorce decree in the above captioned divorce action. Upon the execution of this Agreement, the parties shall execute and file all documents and papers, including affidavits of consent, necessary to finalize said divorce. If either party fails or refuses to finalize said divorce or execute and file the documents necessary to finalize the divorce, said failure or refusal shall be considered a material breach of this Agreement and shall entitle the other party at his or her option to terminate this Agreement, in which event the parties shall be restored to the same legal position each had been immediately prior to the execution of this Agreement, and either party may then proceed with the litigation of any claims heretofore raised in this divorce action the same as of this Agreement has never been executed by the parties. 1.04. EFFECT OF DIVORCE DECREE Unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final Decree in Divorce may be entered with respect to the parties. BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT 1.05. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE The terms of this Agreement shall be incorporated into any Divorce Decree which may be entered with respect to them. 1.06. NON-MERGER This Agreement shall not merge with the Divorce Decree, but rather, it shall continue to have independent contractual significance and each party shall maintain their contractual remedies as well as court remedies as the result of the aforesaid incorporation or as otherwise provided by law or statute. 1.07. DATE OF EXECUTION The "date of execution", "execution date" or "date of this Agreement" shall be defined as the date of execution by the party last executing this Agreement. 1.08. DISTRIBUTION DAT~ The transfer of property, funds and/or documents provided for herein shall only take place on the "distribution date" which shall be defined as the date of execution of this Agreement unless otherwise specified herein. - 5 - BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT 1.09. ADVICE OF COUNSEL The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, Diane G. Radcliff, Esquire for Husband, and D. Scott Lautner, Esquire, for Wife. The parties acknowledge that they have received independent legal advice from counsel of their selection and that they fully understand the facts and have been fully informed as to their legal rights and obligations. They acknowledge and accept that this Agreement is, under the circumstances, fair and equitable and that it is being entered into freely and voluntarily after having received such advice and with such knowledge, and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. 1.10. FINANCIAL DISCLOSURR The parties confirm that each has relied on the substantial accuracy of the financial disclosure of the other, as an inducement to the execution of this Agreement and each party acknowledges that there has been a full and fair disclosure of the parties' marital - 6 - BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT assets and debts and the parties' respective incomes, which has been provided to each party. 1.11. DISCLOSURE AND WAIVER OF PROCEDURAL RI~TS Each party understands that he or she has the right: (1) to obtain from the other party a complete inventory or list of all of the property that either or both parties own at this time or owned as of the date of separation; (2) to have all such property valued by means of appraisals or otherwise; (3) to compulsory discovery to assist in the discovery and verification of facts relevant to their respective rights and obligations, including the right to question the other party under oath; and (4) to have a court hold hearings and make decisions on the matters covered by this Agreement, which court decision concerning the parties' respective rights and obligations might be different from the provisions of this Agreement. Each party hereby acknowledges that this Agreement is fair and equitable, that it adequately provides for his or her needs and is in his or her best interests, and that the Agreement is not the result of any fraud, duress, or undue influence exercised by either BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT party upon the other or by any other person or persons upon either party. Given said understanding and acknowledgment, both parties hereby waive the following procedural rights: a. Inventory: The right to obtain an inventory of all marital and separate property as defined by the Pennsylvania Divorce Code. b. Income and Expense Statement: The right to obtain an income and expense statement of the other party as provided by the Pennsylvania Divorce Code, except in instances where such an income and expense statement is hereafter required to be filed in any child support action or any other proceedings pursuant to an order of court. c. Discovery: The right to have any discovery as may be permitted by the Rules of Civil Procedure, except discovery arising out of a breach of this Agreement, out of any child support action, or out of any other proceedings in which discovery is specifically ordered by the court. - 8 - BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT do Determination of Marital and Non-Marital Property: The right to have the court determine which property is marital and which is non-marital, and equitably distribute between the parties that property which the court determines to be marital. Other Rights and Remedies: The right to have the court decide any other rights, remedies, privileges, or obligations covered by this Agreement, including, but not limited to, possible claims for divorce, spousal support, alimony, alimony pendente lite (temporary alimony) , counsel fees, costs and expenses. 1 . 12 . BkN-KRUPTC¥ The parties hereby agree that the provisions of this Agreement shall not be dischargeable in bankruptcy and expressly agree to reaffirm any and all obligations contained herein. In the event a party files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party shall have the right to declare this Agreement to be null and void and to terminate this Agreement in which event the division of the parties' marital assets and all other rights determined by this - 9 - BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT Agreement shall be subject to court determination the same as if this Agreement had never been entered into. 1.13 . PERSONAL RIGHTS Husband and Wife may and shall, at all times hereafter, live separate and apart. They shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if they were unmarried. They may reside at such place or places as they may select. Each may, for his or her separate use or benefit, conduct, carry on and engage in any business, occupation, profession or employment which to him or her may seem advisable. Husband and Wife shall not molest, harass, disturb or malign each other or the respective families of each other nor compel or attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with him or her. 1.14 . MUTUAL RELEASER Except as other wise expressly provided in this Agreement, Husband and Wife each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from the - 10 - BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT following: a. Claims Aqainst Property or Estate: title, party, C 0 Any and all right, interest and/or claims in or against the other the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against such other party, the estate of such other party or the property of the other party or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other. Dower, Curtesy, Widows Rights: Any and all rights and claims 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; Life Time Conveyances: The right to treat a lifetime conveyance by 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 (1) - 11 - BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT do eo the Commonwealth of Pennsylvania, (2 or Territory of the United States, country; Marital Rights: Any rights which either party may have or at any time hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, equitable distribution, costs or expenses, whether arising as a result of the marital relation or otherwise. Breach Exception: The foregoing shall not apply to all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. 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 State, Commonwealth or (3) any other - 12 - BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT Agreement or for the breach of any provisions thereof. 1.15. WAIVER OR MODIFICATION TO BE IN WRITINC No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 1.16. MUTUAL COOPERATION Each party shall, at any time and from time to time hereafter, take any and all steps and execute, acknowledge and deliver to the other party, any and all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. 1.17. AGREEMENT BINDING ON ~.IRS This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 1.18. INTEGRATION This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and 13 BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT negotiations between them. There are no representations or warranties other than those expressly set forth herein. 1 . 19 . OTHER DOCUMENTATION Wife and Husband covenant and agree that they will forthwith, (and within at least twenty (20) days after demand therefor) , execute any and all written instruments, assignments, releases, satisfactions, deeds, notes, stock certificates, or such other writings as may be necessary or desirable for the proper effectuation of this Agreement, and/or as their respective counsel shall mutually agree should be so executed in order to carry out fully and effectively the terms of this Agreement. 1.20. NO WAIVER OF DEFAULT This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same in the future, nor shall it be construed as a waiver of strict performance of any other obligations herein, nor shall it be 14 - BRADLEY SANDERS/5.21.02. 5U~RITAL AGREEMENT construed as a waiver of any subsequent default of the same or similar nature. 1.21. BR~.AC~ If for any reason either Husband or Wife fails to perform his or her obligations owed to or for the benefit of the other party and/or otherwise breaches the terms of this Agreement, then the other party shall have the following rights and remedies, all of which shall be deemed to be cumulative and not in the alternative, unless said cumulative effect would have an inconsistent result or would result in a windfall of the other party: a. Specific Performance: The right to specific performance of the terms of this Agreement, in which event the non- breaching party shall be reimbursed for all reasonable attorney's fees and costs incurred as the result of said breach and in bringing the action for specific performance. b. Damages: The right to damages arising out of breach of the terms of this Agreement, which damages shall include reimbursement of all reasonable attorney.s fees and costs incurred as the result of the breach and in bringing the 15 BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT eo damage action. Divorce Code Remedies: The right to all remedies set forth in Section 3502(e) of the Pennsylvania Divorce Code, 23 PA. C.S·A. 3502(e), and any additional rights and remedies that may hereafter be enacted by virtue of the amendment of said statute or replacement thereof by any other similar laws. Other Remedies: Any other remedies provided for in law or in equity. Considerations for Reasonable Attorneys Fees: Any award of "reasonable attorneys fees" as used in this paragraph shall be based on consideration of (1) the hourly rate charged; (2) the services rendered; and (3) the necessity of the services rendered. Determination of reasonableness shall not take into consideration the amount or nature of the obligation sought to be enforced or any possibility of settlement for less than the obligation sought to be enforced by the non-breaching party. - 16 - BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT 1.22. LAW OF PENNSYLVANIA APPLICABLF, This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 1.23 . SEVERABILITY If any term, condition, clause or provision of this Agreement shall be determined or declared to 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 remain valid and continue in full force, effect and operation. Likewise, the failure of either party to meet his or her obligations under this Agreement under any one or more of the paragraphs hereunder, with the exception of the satisfaction of a condition precedent, shall in no way avoid or alter the remaining obligations of the parties. 1.24. HEADINGS NOT PART OF AGREEM~.NT Any headings preceding the text of the several paragraphs and subparagraphs hereof, are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. - 17 - BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT 1.25. INCOME TAX MATTERS With respect to income tax matters regarding the parties the following shall apply: a. bo Prior Returns: The parties have heretofore filed joint federal and state returns. Both parties agree that in the event any deficiency in federal, state or local income tax is proposed, or any assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failure to disclose the nature and extent of his or her separate income on the aforesaid joint returns. Current Returns: The parties shall file individual tax returns for the current tax year and for every tax year hereafter. - 18 - BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT 1.26 · PRESERVATION OF RECORD~ Each party will keep and preserve all records pertaining to any jointly filed tax returns for the period of time as required by the Internal Revenue Service, and each party will allow the other party access to those records as may be reasonably necessary from time to time. 1.27. MANNER OF GIVING NOTICe. Any notice required by this Agreement shall be sent to a party at the address listed on page 1 above, or such other address as that party may from time to time designate. 1.28. EFFECT OF RECONCILIATION This Agreement shall remain in full force and effect even if the parties reconcile, cohabit as Husband and Wife or otherwise, or attempt a reconciliation. This Agreement shall continue in full force and effect and there shall be no modification or waiver of any of the terms hereof unless the parties, in writing, signed by both parties, execute a statement declaring this Agreement or any term of this Agreement to be null and void. - 19 - BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT SECTION II DISTRIBUTION OF PROPERTY 2.01. FINAL EQUITABLE DISTRIBUTION OF PROPERTY The parties agree that the division of all property and debts set forth in this Agreement is equitable and in the event an action in divorce has been or is hereafter commenced, both parties waive and relinquish the right to divide and distribute their assets and debts in any manner not consistent with the terms set forth herein and further waive and relinquish the right to have the court equitably divide and distribute their marital assets and debts. It is further the intent, understanding and agreement of the parties that this Agreement is a full, final, complete and equitable property division. 2.02. AFTER-ACQUIRED PROPERTY Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all property, tangible or intangible, real, personal or mixed, acquired by him or her, since September 25, 2001, the date of the parties' marital separation, with full power in him or her to dispose of the same as - 20 - BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT fully and effectively, in all respects and for all purposes, as though he or she were unmarried and each party hereby waives, releases, renounces and forever abandons any right, title, interest and claim in and to said after acquired property of the other party pursuant to the terms of this Paragraph. 2.03. WAIVER OF INW~RITANC~ Each of the parties hereto does specifically waive, release, renounce and forever abandon any right, title, interest and claim, if any, either party may have in and to any inheritance of any kind or nature whatsoever previously, or in the future, received by the other party. 2.04. _AS IS CONDITION Except as otherwise specifically herein provided, and with respect to the transfer of any tangible assets provided for in this marital Agreement, the parties acknowledge that he or she have had the opportunity to inspect and view the assets that he or she is to receive as his or her sole and separate property and he or she is fully aware of the condition of such tangible asset and is receiving those assets in "as is" physical condition, without 21 BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT warranty or representation by or from the other party. 2 . 05. pERSONAL PROPERTY With respect to the tangible personal property of the parties including, but without limitation with specific reference to, jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, tools, pictures, books, works of art, family pets and other personal property ("the Personal Property"), the parties agree as follows: a. Division: Husband and Wife do hereby acknowledge that they have previously divided the Personal Property. Hereafter Wife agrees that all of the Personal Property in the possession of Husband shall be the sole and separate property of Husband; and Husband agrees that all of the Personal Property in the possession of Wife shall be the sole and separate property of Wife. b. Dog: it is specifically understood and agreed that the foregoing provision is intended to grant sole ownership of the Weimaraner dog to Husband. c. Waiver: The parties do hereby specifically waive, release, renounce and forever abandon whatever claims, if 22 - BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT do any, he or she may have with respect to the Personal Property which shall become the sole and separate property of the other. Documents: to the extent necessary the parties will execute and deliver any and all documents necessary to carry forth the provisions of this Section 2.05, including but not limited to, the transfer of legal ownership of the Weimaraner dog to Husband. 2.06. VEHICLES, BOATS AND THE LIKE With respect to the vehicles, boats, snowmobiles, motorcycles and the like owned by one or both of the parties, or the trade in value thereof, ("the Vehicles") if the Vehicles have been sold or traded in prior to the date of this Agreement, the parties agree as follows: a. Wife's Vehicle(s}: The 1995 Eagle Vision shall be the sole and separate property of Wife. b. Husband's Vehicle(s}: The 2000 Ford F-150 4x4 Pick-Up Truck shall be the sole and separate property of Husband. c. Identification: Identification of a Vehicle herein shall include not only the Vehicle, but also the sale or trade- - 23 - BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT fo in value thereof if it had been sold or traded in prior to the date of this Agreement. Transfer of Titles: The titles to the Vehicles shall be executed by the parties, if appropriate, for effectuating transfer as herein provided on the date of execution of this Agreement and said executed titles shall be delivered to the proper party on the distribution date. Title and Power of Attorney: For purposes of this Paragraph the term "title,, shall be deemed to include "power of attorney,, if the title to the Vehicle is unavailable due to financing arrangements or otherwise. Liens: In the event any Vehicle is subject to a lien or encumbrance the party receiving the Vehicle as his or her property shall take it subject to said lien and/or encumbrance and shall be solely responsible therefor and said party further agrees to indemnify, protect and save the other party harmless from said lien or encumbrance. Waiver: Each of the parties hereto does specifically waive, release, renounce and forever abandon whatever right, title and interest they may have in the Vehicles 24 BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT that shall become the sole and separate property of the other party pursuant to the terms of this Paragraph. 2 . 07 . REAL ESTATm. Husband is the sole owner of a certain tract of improved real estate known and numbered as 2177 Merrimac Avenue, Mechanicsburg, PA ("the Real Estate") which is encumbered with a mortgage owed to Washington Mutual ("the Mortgage") . With respect to the Real Estate and the Mortgage the parties agree as follows: a. Waiver: Wife specifically waives, releases, renounces and forever abandons whatever right, title and interest she may have in the Real Estate, which hereafter shall be the sole and separate property of Husband free and clear of all claims of Wife. to the terms of this Paragraph. b. Documents: Wife shall make, execute and deliver all documents requested by Husband to effectuate the terms of her waiver set forth in subparagraph a. above. c. Liens, Encumbrances and Expenses: The Real Estate shall be subject to all liens and encumbrances including, but not limited to, the lien of the Mortgage, real estate taxes and any other municipal liens, and shall further be - 25 - BR3~DLEY S~NDERS/5.21.02. MARITAL AGREEMENT under and subject to any covenants and restrictions of record. Husband shall hereinafter be solely responsible for the payment of the Mortgage, real estate taxes, other municipal liens and any and all other expenses associated with the Real Estate, whether incurred in the past, present or future, and shall indemnify, protect and save Wife harmless therefrom. 2.08. RETIREMENT AND PENSION PLANS Each of the parties does specifically waive, release, renounce and forever abandon all of their right, title, interest or claim, whatever it may be, in any Pension Plan, Retirement Plan, IRA Account, Profit Sharing Plan, 401-K Plan, Keogh Plan, Stock Plan, Tax Deferred Savings Plan, any employee benefit plan and/or other retirement type plans of the other party, whether acquired through said party's employment or otherwise, ("the Retirement Plans"). Hereafter the Retirement Plans shall become the sole and separate property of the party in whose name or through whose employment said plan or account is held or carried. If either party withdraws any sums from the Retirement Plans distributed to him or her pursuant to the terms of this Paragraph, that party shall be solely 26 BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT liable for any and all taxes and penalties resulting from that withdrawal. Pursuant to the foregoing terms, it is agreed that Wife shall retain her Fidelity 401K Plan and her IP~A account and Husband shall retain his prudential 401K Plan. 2.09. The BANK ACCOUNTS/STOCK/LIFE INSURANCE parties have previously divided to their mutual satisfaction all of their bank accounts, certificates of deposit, bonds, shares of stock, investment plans and life insurance cash value,, ("the Accounts"). Hereafter Wife agrees that all the Accounts held in the name of Husband shall become the sole and separate property of Husband; and Husband agrees that all the Accounts held in the name of Wife shall become the sole and separate property of Wife. Each of the parties does specifically waive, release, renounce and forever abandon whatever right, title, interest or claim, he or she may have in the Accounts that are to become the sole and separate property of the other pursuant to the terms hereof. - 27 - BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT 2.10. MONETARY PAYMENT In consideration of the division of the marital assets and debts herein provided, Husband shall pay Wife the sum of $5,000.00. Said payment shall be made in a single lump sum payment upon execution of this Agreement. 2.11. TAX PROVISIONS The parties believe and agree that the division of property made to be made pursuant to the terms of this Agreement is a non- taxable division of property between co-owners rather than a taxable sale or exchange of such property. Each party promises not to take any position with respect to the adjusted basis of the property assigned to him or her or with respect to any other issue which is inconsistent with the terms of this Paragraph on his or her applicable federal or state income tax returns. THIS SPACE INTENTIONALLY LEFT BLANK 28 - BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT SECTION III DISTRIBUTION OF DEBTS 3.01. WIFE'S DEBTS Wife represents and warrants to Husband that since the parties' marital separation she has not contracted or incurred any debt or liability for which Husband or his estate might be responsible. Wife further represents and warrants to Husband that she will not contract or incur any debt or liability after the execution of this Agreement for which Husband or his estate might be responsible. Wife shall indemnify and save Husband harmless from any and all claims or demands made against him by reason of debts or obligations incurred by her. 3 · 02 · HUSBAND ' S DEBTS Husband represents and warrants to Wife that since the parties' marital separation he has not contracted or incurred any debt or liability for which Wife or her estate might be responsible. Husband further represents and warrants to Wife that he will not contract or incur any debt or liability after the execution of this Agreement for which Wife or her estate might be - 29 - BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT responsible. Husband shall indemnify and save Wife harmless from any and all claims or demands made against her by reason of debts or obligations incurred by him. 3.03. MARITAL DEBT During the course of the marriage, Husband and Wife have incurred certain bills and obligations and have amassed a variety of debts, ("the Marital Debts"), and it is hereby agreed, without ascertaining for what purpose and to whose use each of the Marital Debts were incurred, the parties agree as follows: a. General Provision: Any debt herein described shall be deemed to include the current balance owed on the debt. Unless otherwise herein specifically provided, there shall be no adjustment for the payment of any portion of the Marital Debts that a party may have made prior to the execution of this Marital Agreement, whether or not that debt is specifically referenced in this Paragraph. b. Wife's Debts: Wife shall be solely responsible for the following bills and debts: 1. Any vehicle loan for Wife's Vehicle(s) as required and set forth in Paragraph 2.06 herein. 30 - BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT Co 2. Any and all taxes resulting from her withdrawal of funds from her Retirement Plans set forth in Paragraph 2.08 herein; 3. Any and all other debts, liabilities, obligations, loans, credit card accounts, and the like incurred in Wife's sole name, and not otherwise provided for herein. Husband's Debts: Husband shall be solely responsible for the following bills and debts: 1. The Universal Card; 2. The Discover Card; 3. Any vehicle loan for Husband's Vehicle(s) as required and set forth in Paragraph 2.06 herein; The Mortgage set forth in Paragraph 2.07 herein; Any and all expenses associated with the Real Estate set forth in Paragraph 2.07 herein; Any and all taxes resulting from his withdrawal of funds from his Retirement Plans set forth in Paragraph 2.08 herein; Any and all other debts, liabilities, obligations, - 31 - BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT do eo f o loans, credit card accounts, and the like incurred in Husband's sole name and not otherwise provided for herein. Indemnification: Each party agrees to hold the other harmless from any and all liability which may arise from the aforesaid bills which pursuant to the terms herein are not the responsibility of the other party. Cancellation of Joint Debts: Any joint debt shall be canceled so that neither party can make any further charges thereunder, and if said charges are made in violation of this Agreement, then the party incurring said charge shall immediately repay the same. Non-Disclosed Liability: Any liability not disclosed in this Agreement shall be the sole responsibility of the party who has incurred or may hereafter incur it, and the party incurring or having incurred said debt shall pay it as it becomes due and payable. No Further Joint Debt: From the date of this Agreement, each party shall only use those credit accounts or incur such further obligations for which that party is - 32 - BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT individually and solely liable and the parties shall cooperate in closing any remaining accounts which provide for joint liability. 3 . 04 . INDEHNIFICATION Any party assuming an obligation pursuant to the terms of this Agreement shall indemnify, protect and hold the other party harmless from and against all any and all liability thereunder, including, but not limited to, any attorney's fees and costs incurred by the other party as the result of defending against the obligation and/or enforcing the provisions of this indemnification. THIS SPACE INTENTIONALLY LEFT BLANK 33 BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT SECTION COUNSEL FEES, AND SPOUSAL IV AL I MONY, SUPPORT 4.01. WAIVER OF COUNSEL FEES The parties hereto agree and do hereby waive any right and/or claim each may have, both now and in the future, against the other for counsel fees, costs and expenses. 4.02. ALIMONY AND SUPPORT The parties hereto agree and do hereby waive any right and/or claim they may have, both now and in the future, against the other for alimony, alimony pendente lite, spousal support and maintenance. With respect to the existing spousal support order entered in the support action docketed to No. 00807 S 2001, Pacses No. 091103873, the following shall apply: a. Termination of Order: The existing spousal support order shall be terminated as of the date of the entry of the divorce decree but in no event any later than June 15, 2002, whichever shall first occur. - 34 - BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT Cancellation of Arrears: Any remaining arrears on said spousal support order as of the date of termination shall be paid in full by Husband within five (5) days of the date of the entry of the divorce decree. THIS SPACE INTENTIONALLY LEFT BLANK 35 BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT SECTION V CLOSING PROVISIONS AND EXECUTION 5 · 01 . COUNTERPARTS This Agreement may be executed in counterparts, each of which shall be deemed to be an original, but all of which shall constitute one and the same agreement. 5.02. FACSIMILE SIGNATURE Each party agrees to accept and be bound by facsimile signatures hereto. 5.03. BINDING EFFECT BY SIGNING THIS AGREEMENT, EACH PARTY ACKNOWLEDGES HAVING READ AND UNDERSTOOD THE ENTIRE AGREEMENT, AND EACH PARTY ACKNOWLEDGES THAT THE PROVISIONS OF T~{IS AGREEMENT SHALL BE AS BINDING UPON THE PARTIES AS IF THEY WERE ORDERED BY THE COURT AFTER A FULL HEARING. IN WITNESS W-~EREOF, the parties hereto, intending to be legally bound hereby, have signed sealed and acknowledged this Agreement in various counterparts, each of which shall constitute 36 - BRADLEY SANDERS/5.21.02. MARITAL AGREEMENT an original. WITNESS: ALISON M. SANDERS Date: ~-J~ - ~L~.~ a. S~- Date: ~--~-- 0~ (SEAL) (SEAL) 37 - BRADLEY SDJqDERS/5.21.02. MARITAL AGREEMENT COMMONWEALTH OF PENNSYLVANIA COUNTY OF _~Jl/F~&~-'~ On this the .~%4 day of SS. : , 2002, before me the undersigned officer, personally appeared, ALISON M. SANDERS, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that ALISON M. SANDERS executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and notarial seal. Notafia~ ~% Public Deborah L. Donle , . ? County Camp Hill Boro, C My CommissiOn E> : ~.~ ~.~.. 23, 2003] Iv;ember, Pennsyivam.~., ,~u~,~..,.,~ ol Notaries NOTARY PUBLIC / My Commission Expires: COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND On this the~___~day of /~0~-~ , 2002, before me the undersigned officer, personally ip~eare~ BRADLEY J. SANDERS, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that BRADLEY J. SANDERS executed the same for the purposes therein contained. seal. IN WITNESS WHEREOF, I have hereunto set my hand and notarial -- ~ N~TA~P C ~ ~ My Commission ~,xpires: I Notarial Seal Robin Z, Gonzalez, Notary Public Hlghliplre Bom_, Dauphin County I ~ras June 21, 2004 BRADLEY SANDERS, Plaintiff Vo ALISON SANDERS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-5654 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 2 o A Complaint in Divorce under Section 3301(c of the Divorce Code was filed on September 27, 2001. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the decree. 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. Dated: ALISON SANDERS BRADLEY SANDERS, Plaintiff Vo ALISON SANDERS, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : · NO. 01-5654 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE 2 o o WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c~ OF THE DIVORCE CODE I consent to the entry of a final decree in divorce without notice. 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 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 hereih are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: ~ ~' D ~ ALISON SANDERS BPJ~DLEY SANDERS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-5654 CIVIL TERM ALISON SANDERS, : CIVIL ACTION - LAW Defendant : IN DIVORCE PRAECIPE OF TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, entry of a divorce decree: cD C~urt~for Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. Date of filing and manner of service of the complaint: a. Date of filing of Complaint: September 27, 2001 b. Manner of service of Complaint: Certified Mail Restricted Delivery c. Date of Service of Complaint: October 5, 2001 Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: a. Plaintiff: May 24, 2001 b. Defendant: May 28, 2001 OR Date of execution of the Plaintiff.s affidavit required by Section 3301(d) of the Divorce Code and date of service of the Plaintiff's 3301 (d) affidavit upon the Defendant: a. Date of execution: N/A b. Date of filing: N/A c. Date of service: N/A Related claims pending: No issues are pending. Ail issues have been resolved pursuant to the Marriage Settlement Agreement between the parties dated May 24, 2002, which Agreement is to be incorporated into but not merged with the Divorce Decree. under Section 3301(d) (1) (i) a. Date of Service: N/A b. Manner of Service: N/A Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached, if the decree is to be entered of the Divorce Code: 0__R Date Waiver of Notice in Section 3301 (c) Divorce was filed with Prothonotary: a. Plaintiff's Waiver: May 24, 2001 b. Defendant's Waiver: May 30, 2001 34~FS--Tl~indle Road Camp Hill, PA 17011 Supreme Court ID # 32112 Phone: (717) 737-0100 the iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF BRADLEY SANDERS~ Plaintiff VERSUS ALISON SANDERS~ Defendant PENNA. No. 01-5654 CIVIL TERM DECREE IN DIVORCE AND NOW, ~3'{4~~ ti , IT IS ORDERED AND DECREED THAT BRADLEY SANDERS , PLAINTIFF, AND ALISON SANDERS , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; No issues are outstanding. All issues have been resolved and settled by the parties' Marriage Settlement Agreement dated May , 2001, filed and /~~ of record incorporated, erged, ATTEST: into this Decree. Jo PROTHONOTARY