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Home My WebLink About96-02149 \ I \ I " ~ 1 ) " J , ~ , " , -,~ . MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this ~ day of ~lCl~d12oo'L.bY and between Bruce A. Janasik, hereinafter referred to as "Husband", and Lori Janaslk, hereinafter referred to as "Wife". WITNESSETH: WHEREAS, Husband and Wife were lawfully married on March 27, 1984; and WHEREAS, certain differences arose between the parties as a result of which they separated on April 3, 1996, and now live separate and apart from one another, and are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, Including, without limitation by specification: the settling of all matters between them relating to the past, present and future support 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 for equitable distribution of all marital property; and a resolution of all mutual responsibilities and rights growing out of the marriage relationship any provisions of prior agreement between them to the contrary notwithstanding; and WHEREAS, the parties hereto, after being properly advised by their respective counsel, Husband, by his attorney, Edward J. Weintraub, Esquire, and Wife, by her attorney, Carol J. Lindsay, Esquire, have come to the following agreement. NOW THEREFORE, in consideration of the above recitals and the following covenants and promises mutually made and mutually to be kept, the parties heretofore, Intending to be legally bound and to legally bind their heirs, successors and assigns thereby, covenant, promise and agree as follows: \u/' , / _I (Inilials) -f!--(lniliaIS) -""" 1, SEPARA TION: It shall be lawful for each party at all times hereafter to live separate and apart from the other as such place or places as he or she may from time to time choose or deem fit. 2. INTERFERENCE: Each party shall be free from Interference, authority and contact by the other, as fully as If he or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall harass the other nor endeavor to molest the other, nor compel the other to cohabit with the other nor In any way malign the other, nor In any way Interfere with the peaceful existence, separate and apart from the other In all respects as If he or she were single and unmarried. 3. WIFE'S DEBTS: Other than the debts Indicated In Paragraph 5 below Wife represents and warrants to Husband that since April 3, 1996, she has not, and In the future, she will not, contract or incur any debt or liability for which Husband or his estate might be responsible and 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. 4. HUSBAND'S DEBTS: Other than the debts indicated in Paragraph 5 below, Husband represents and warrants to Wife that since April 3, 1996, he has not, and In the future he will not, contract or Incur any debt or liability for which Wife or her estate might be responsible and 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. !S. OUTSTANDING MARITAL DEBTS: Husband and Wife acknowledge and agree that they have no outstanding marital debts and obligations of the Husband and Wife Incurred prior to the signing of this agreement, except as follows: J ~ ~"----ii-(Inilials) 2 4-<lnitiaIS) -.I> PERSON(S) NOW DESCRIPTION AMOUNT RESP_ONSlSl.E A. Keystone Financial loan $4,114 H B. Household Credit loan $3,273 H C. Wachovla Credit Card $6,358 H D. Fleet Credit Card $4,461 H E. MBNA Credit Card $3,116 H F. EDS Federal Credit Union loan $2,132 H The parties agree that Husband shall hereafter be responsible for paying debts A through F. Husband agrees to pay the outstanding Joint debts and further agrees to Indemnify and save Wife harmless from any liability for such debts or obligations. In the event that either party contracted or Incurred any debts, other than those specifically Identified herein since April 3, 1996, the party who incurred the debt shall be responsible for its payment regardless of the name In which the account may have been charged and agrees to indemnify and hold harmless the other for any liability for such debts. 6. MUTUAL RELEASE: Except as provided in this Agreement, each party waives his or her right to alimony and any further distribution of property because both agree that this Agreement provides for an equitable distribution of their marital property in accordance with the Divorce Code of 1980. Subject to the provisions of this agreement, each party has released and discharged, and by this Agreement does for himself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all causes of action, claims, rights or demands whatsoever In law or equity, which either of the parties ever had or now has against the other, except any or all cause or causes of action for divorce and except in any or all causes of action for breach of any provisions of this Agreement. Each party also waives his or her right to request marital counseling pursuant to 23 Pa.C.S.A. Section 3302. --1+(lniliaIS) 3 4--,,",.,.,., 7, EQUITABLE DISTRIBUTION: A. Contents of Wife's Residence: As of the date of the execution of this Agreement, the parties have equitably divided their personal property. Husband relinquishes his right, tille, claim and Interest In and to the furniture, fixtures, goods, appliances, equipment and personal Items In the possession of Wife. B. Contents of Husband's Residence: Wife relinquishes her right, title, claim and Interest In and to the furniture, fixtures, goods, appliances, equipment and personal Items In the possession of Husband. C. Motor Vehicles: With respect to the motor vehicles owned by one or both of the parties, they agree as follows: (1) Wife shall retain the 1994 Ford Escort or the procellds of selling It. (2) Husband shall retain the 1998 Mazda Pickup or the proceeds of selling it. (3) All automobile titles and insurance policies will be corrected to reflectlhe ownership of each vehicle. D. Individual Retirement Accounts, Pensions And Employment Benefits: Wife shall retain sole ownership and control of her Toys R Us 401 k. Husband shall retain sole ownership and control of his EDS pension. Upon the execution of this Agreement, Husband shall transfer to Wife the entire balance In his Vanguard Fund 401 k ($6,720.10 as of September 30, 2001) and shall execute any documents necessary to do so. Wife shall receive any appreciation In the Vanguard Fund from execution to transfer and shall bear any decline as well. Should a QDRO be required, It shall be prepared by counsel for Wife and reviewed by counsel for Husband. Husband warrants that he has not withdrawn any funds from the Vanguard Fund 401k since April 3, 1996. _l._l(lniliaIS) 4 i/.-<lniliaIS) E, Joint Bank and Charge Accounts: All Joint bank and charge accounts, credit card accounts and any other joint accounts shall be terminated and each party shall take those steps necessary to have the other removed as a responsible party from any such account. Wife shall retain all of the current balances in her curren\ savings and checking accounts. Husband shall retain all of the current balances in his current savings and checking accounts. F. Stocks Husband shall retain sole ownership and control of the EDS Stock account and the First Capital Stock Account. Wife waives and relinquishes any right or claim to these stock accounts. G. Property to Wlfa: The parties agree that Wife shall own, possess, and enjoy free from any claims of Husband, the property awarded to her by the terms of this Agreement. Husband hereby quitclaims, assigns and conveys to Wife all such property together with any insurance policies covering that property, and any escrow accounts relating to that property. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property from Husband to Wife. H. Property to Husband: The parties agree that Husband shall own, possess, and enjoy free from any claims of Wife, the property awarded to him by the terms of this Agreement. Wife hereby quitclaims, assigns and conveys to Husband all such property together with any insurance policies covering that property, and any escrow accounts relating to that property. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights In such property from Wife to Husband. I. Miscellaneous Property: All property not specifically addressed herein shall hereafter he ownEJd by the party to whom the property is titled, and If untitled, the party In possession. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights In such property from each to the other. -\_.lJllliliabl 5 J!-__llllilialsl J, Tax Liability: The parties believe and agree that the division of property heretofore made by this .A.greement 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 with respect to any other Issue which Is inconsistent with the position set forth In the preceding sentence on his or her Federal or State Income tax returns. 8, LIFE INSURANCE: Each party shall continue to own any life Insurance policies currently In effect, without restriction as to the designation of beneficiaries. 9. ALIMONY: Via wage attachment through Domestic Relations, pursuant to a Stipulation for An Agreed Order of Alimony prepared by counsel for Husband, Husband shall pay alimony to Wife In the amount of Eight Hundred Dollars ($800.00) per month commencing December 1, 2001 and ending September 30, 2003. In addition, Husband shall pay Fifty Dollars ($50.00) per month on his arrears until satisfied. Alimony shall terminate in the event of Wife's death, cohabitation or remarriage. For tax purposes, all alimony payments are intended to be deductible by Husband and includible as income to Wife. The parties shall execute any documents necessar/to convert their current alimony pendente lite order through Domestic Relations to an Agreed Order of Alimony. 10. HEALTH INSURANCE: Husband agrees to continue to provide and pay for Wife's medical and hospitalization coverage until entry of a final decree In divorce. Thereafter Wife shall be solely responsible for her own health care expenses and any unisured medical expenses, 11. ALIMONY PENDENTE LITE, COUNSEL FEES AN EXPENSES: Husband and Wife acknowledge and agree that the provisions of this Agreement providing for the equitable distribution of marital property of the parties are fair, adequate and satisfactory to them, Both parties agree to accept the provisions set forth in this Agreement in lieu of and in full and final settlement and satisfaction of all claims and demands that either may now or hereafter have against, the other for alimony pendente lite, counsel fees or expenses or any other provision for their support and maintenance before, (, _lrf __(Initials) I .t, (Initials) during and after the commencement of the proceedings for divorce or annulment between the parties. 12. INCOME TAX RETURNS: The parties have heretofore filed joint federal and state tax 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 and any loss or liability for any such tax deficiency or assessment and any Interest, penally and expense Incurred in connection therewith. Such tax, Interest. penalty or expense shall be paid solely and entirely by the Individual who is finally determined to be responsible for the actions, misrepresentations or failures to disclose separate income resulting in tax liability. The parties shall file separately in 2001 and thereafter. 13. WAIVERS OF CLAIMS AGAINST ESTA TES: Except as herein otherwise provided each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the present or future laws of any Jurisdiction, to share In the property or the estate of the other as a result of the marital relationship, Including without limitation, dower, curtsey, statutory allowance, widow's allowance, right to take Intestacy, right to take against the will of the other, and right to act as administrator or executor of the other's estate. Each will, at the request of the other, execute, acknowledge and deliver any and all Instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of ail such Interests, rights and claims and both parties will revoke prior wills or testamentary documents. 14. AGREEMENT NOT PREDICATED ON DIVORCE: It Is ~pecifically understood and agreed by and between the parties hereto and each of the said parties does hereby warrant and represent to the other, that the execution and delivery of this Agreement is not predicated upon nor made subject to any agreement for institution, prosecution, defense, or for the non-prosecution or non. defense of any action for divorce; provided, however, that nothing contained in this Agreement shall prevent or preclude either of the parties hereto from commencing, . I -.-:t___~_(lniliaIS) 7 __Jif____(lniliaIS) ,,)1 Instituting or prosecuting an action or actions for divorce, either absolute or otherwise, upon Just, legal and proper grounds; nor to prevent either party from defending any such action which has been, mayor shall be Instituted by the other party, or from making any Just or proper defense thereto. It Is warranted, covenanted and represented by Husband and Wife, each to the other, that this Agreement is lawful and enforceable and this warranty, covenant and represontatlon is made for the specific purpose of inducing Husband and Wife to execute this Agreement. Husband and Wife each knowingly and understandingly hereby waives any and all possible claims that this agreement Is, for any reason illegal or for any reason whatsoever, unenforceable in whole or In part. Husband and Wife each do hereby warrant, covenant and agree that, in any possible event, he and she are and shall forever be estopped from asserting any Illegality or unenforceability as to all or any part of this Agreement. 15. SUBSEQUENT DIVORCE: Husband at his cost by his counsel has filed an action for divorce under Section 3301(cj of the Divorce Code. Simultaneously with the execution of this Agreement, both parties will execute Affidavits of Consent and Waivers of Notice to enable counsel for Husband to proceed with a no-fault divorce as soon as possible, providing counsel for Wife with a duplicate decree. The parties further agree that each of them shall be responsible for their own attorney's fees. The parties shall be bound by the terms of this agreement, which shall be incorporated by reference into the Divorce Decree, shall not be merged in such Decree, but shall In all respects survive the same and be further binding as an enforceable contract, conclusive upon the parties. 16. BREACH AND ENFORCEMENT: If either party breaches any provision of this Agreement, the other party shall have the right at his or her election, to sue for damages for such breach, or seek such other remedies or relief as may be responsible for payment of legal fees and costs incurred by the other in enforcing his or her rights under this Agreement. Reasonable Interest shall be assessed from the date of breach. _~+(lnitiaIS) ,., -Ai (Initials) 8 / / / A. This Agreement may be specifically enforced by either Husband or Wife In Equity, and the parties hereto agree that If an action to enforce this Agreement Is brought In Equity by either party, the other party will make no objection on the alleged ground of lack of Jurisdiction of said Court on the ground that there Is an adequate remedy at law. The parties do not intend or purport hereby to Improperly confer jurisdiction on a Court in Equity by tl1is Agreement, but they agree as provided herein for the forum of equity In mutual recognition of the present state of the law, and In recognition of the general Jurisdiction of Courts in Equity over agreement such as this one. B. Notwithstanding anything to the contrary herein, Husband and Wife may also proceed with an action at law for redress of his or her rights under the terms of this Agreement, and In such event it Is specifically understood and agreed that for and In specific consideration of the other provisions and covenants of this Agreement, each shall waive al1Y right to a jury trial so as to expedite the hearing and disposition of such case and so as to avoid undue delay. C. Each party further hereby agrees to pay and to save and hold harmless the other party from any and all attorney's fees and costs of litigation that either may sustain, or incur or become liable for, In any way whatsoever, or shall pay upon, or in terms or provisions of this Agreement by reason of any of the terms or provisions of this Agreement by reason of which either party shall be obliged to retain or engage counsel to Initiate or maintain or defend proceedings against the other at law or equity or both In any way whatsoever, provided that the party who seeks to recover such attorney's fees, and costs of litigation must first be successful in whole or In part, before there would be any liability for attorney's fees and costs of litigation. It is the specific agreement and intent or the parties that a breaching or wrongdoing party shall bear the burden and obligation of any and all costs and expenses and counsel fees incurred by himself or herself as well as the other party in endeavoring to protect and enforce his or her rights under this Agreement. 17. ADDITIONAL INSTRUMENT: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further Instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. 9 #--_(lnilialS) -\ ~(Inilials) 18. VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, and each party acknowledges that the Agreement Is fair and equitable, that it is being entered into voluntarily, with full knowledge of the assets of both parties, and that It is not the result of any duress or undue Influence. The parties acknowledge that they have been furnished with all information relating to the financial affairs of the other which has been requested by each of them or by their respective counsel. 19. ENTIRE AGREEMENT: This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. Husband and Wife acknowledge and agree that the provisions of this Agreement with respect to the distribution and divisions of marital and separate property are fair, equitable and satisfactory to them based on the length of their marriage and other relevant factors which have been taken into consideration by the parties. Both parties hereby accept the provisions of this Agreement with respect to the division of property in lieu of and In full and final settlement and satisfaction of all claims and demands that they may now have or hereafter have against the other for equitable distribution of their property by and any court of competent jurisdiction pursuant to 23 Pa.C.SA Section 3501 at, seC!. or any other laws. Husband and Wife each voluntarily and intelligently waive and relinquish any right to seek a court ordered determination and distribution of marital property, but nothing herein contained shall constitute a waiver by either party of any rights to seek the relief of any court for the purpose of enforcing the provisions of this Agreement. 20, DISCLOSURE: Husband and Wife represent and warrant to the other that he or she has made a full and complete disclosure to the other of all assets of any nature whatsoever In which either party has an interest, the sources and amount of the Income of such party of every type whatsoever and of all other relevant and material facts relating to the subject matter of this Agreement. , +Jlnilials) 10 ~ (Initials) 21, MODIFICA TION AND WAIVER: A modification or waiver of any of the provisions of this Agreement shall be effective only If made In writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance on any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 22. PRIOR AGREEMENT: It Is understood and agreed that any and all property settlement agreements which mayor have been executed prior to the date and time of this Agreement are null and void and have no effect. 23. DESCRIPTIVE HEADINGS: The descriptive headings used herein are for convenience only. They have no effect whatsoever in determining the rights or obligations of the parties. 24. INDEPENDENT SEPARA TE COVENANTS: It Is specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 25. APPLICABLE LAW: This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 26. VOID CLAUSES: 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 be valid and continue In full force, effect and operation. 27. AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors, and assigns. ~~([niliaIS) 11 11 ;] _-Bi.f--.(lniliaIS) I MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this \~~~l clay of ~(htl120at..bY and between Bruce A. Janaslk, hereinafter referred to as "Husband", and Lori Janaslk, hereinafter referred to as "Wife". WITNESSETH: WHEREAS, Husband and Wife were lawfully married on March 27, 1984; and WHEREAS, certain differences arose between the parties as a result of which they separated on April 3, 1996, and now live separate and apart from one another, and are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation by specification: the settling of all matters between them relating to the past, present and future support 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 for equitable distribution of all marital property; and a resolution of all mutual responsibilities and rights growing out of the marriage relationship any provisions of prior agreement between them to the contrary notwithstanding; and WHEREAS, the parties hereto, after being properly advised by their respective counsel, Husband, by his attorney, Edward J. Weintraub, Esquire, and Wife, by her attorney, Carol J. Lindsay, Esquire, have come to the following agreement. NOW THEREFORE, In consideration of the above recitals and the following covenants and promises mutually made and mutually to be kept, the parties heretofore, intending to be legally bound and to legally bind their heirs, successors and assigns thereby, covenant, promise and agree as follows: C-#(lniliaIS) .f---<lnitiarS) 1, SEPARA TION: It shall be lawful for each party at all times hereafter to live separate and apart from the other as such place or places as he or she may from time to time choose or deem fit. 2. INTERFERENCE: Each party shall be free from interference, authority and contact by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall harass the other nor endeavor to molest the other, nor compel the other to cohabit with the other nor In any way malign the other, nor In any way interfere with the peaceful existence, separate and apart from the other In all respects as If he or she were single and unmarried. 3, WIFE'S DEBTS: Other than the debts Indicated In Paragraph 5 below Wife represents and warrants to Husband that since April 3, 1996, she has not, and In the future, she will not, contract or incur any debt or liability for which Husband or his estate might be responsible and 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. 4. HUSBAND'S DEBTS: Other than the debts Indicated in Paragraph 5 below, Husband represents and warrants to Wife that since April 3, 1996, he has not, and in the future he will not, contract or incur any debt or liability for which Wife or her estate might be responsible and 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. !S. OUTSTANDING MARITAL DEBTS: Husband and Wife acknowledge and agree that they have no outstanding marital debts and obligations of the Husband and Wife incurred prior to the signing of this agreement, except as follows: C4<lniliaIS) 2 . f-('.';'") PERSON(S) NOW OESCBJe.TION t\MQU~ BESfQ~SlSLE A. Keystone Financial loan $4,114 H B. Household Credit loan $3,273 H C. Wachovla Credit Card $6,358 H D. Fleet Credit Card $4,461 H E. MBNA Credit Card $3,118 H F. EDS Federal Credit Union Loan $2,132 H The parties agree that Husband shall hereafter be responsible for paying debts A through F. Husband agrees to pay the outstanding Joint debts and further agrees to indemnify and save Wife harmless from any liability for such debts or obligations. In the event that either party contracted or Incurred any debts, other than those specifically Identified herein since April 3, 1996, the party who Incurred the debt shall be responsible for its payment regardless of the name In which the account may have been charged and agrees to indemnify and hold harmless the other for any liability for such debts. 6. MUTUAL RELEASE: Except as provided in this Agreement, each party waives his or her right to alimony and any further distribution of property because both agree that this Agreement provides for an equitable distribution of their marital property in accordance with the Divorce Code of 1980. Subject to the provisions of this agreement, each party has released and discharged, and by this Agreement does for himself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all causes of action, claims, rights or demands whatsoever In law or equity, which either of the parties ever had or now has against the other, except any or all cause or causes of action for divorce and except in any or all causes of action for breach of any provisions of this Agreement. Each party also waives his or her right to request marital counseling pursuant to 23 Pa.C.S.A. Section 3302. ~\(-l ~(Inillals) J 4-11""1'1 7. EQUITABLE DISTRIBUTION: A, Contents of Wife's Residence: As of the date of the execution of this Agreement, the parties have equitably divided their personal property. Husband relinquishes his right, title, claim and Interest In and to the furniture, fixtures, goods, appliances, equipment and personal Items In the possession of Wife. B. Contents of Husband's Residence: Wife relinquishes her right, title, claim and Interest In and to the furniture, fixtures, goods, appliances, equipment and personal items In the possession of Husband. Motor Vehicles: With respect to the motor vehicles owned by one or both of the parties, they agree as follows: (1 ) c. Wife shall retain the 1994 Ford Escort or the proceeds of selling it. (2) Husband shall retain the 1998 Mazda Pickup or the proceeds of selling it. (3) All automobile tilles and Insurance policies will be corrected to reflect the ownership of each vehicle. 0, Individual Retirement Accounts, Pensions And Employment Benefits: Wife shall retain sole ownership and control of her Toys R Us 401k. Husband shall retain sole ownership and control of his EDS pension. Upon the execution of this Agreement, Husband shall transfer to Wife the entire balance In his Vanguard Fund 401k ($6,720.10 as of September 30, 2001) and shall execute any documents necessary to do so. Wife shall receive any appreciation In the Vanguard Fund from execution to transfer and shall bear any decline as well. Should a aDRO be required, It shall be prepared by counsel for Wife and reviewed by counsel for Husband. Husband warrants that he has not withdrawn any funds from the Vanguard Fund 401 k since April 3, 1996. ~(-1 ~(Initi:.\IS) 4 Jj--llniliaIS) E, Joint Bank and Charge Accounts: All Joint ba'1k and charge accounts, credit card accounts and any other Joint accounts shall be terminated and each party shall take those steps necessary to have the other removed as a responsible party from any such account. Wife shall retain all of the current balances in her current savings and checking accounts. Husband shall retain all of the current balances in his current savings and checking accounts. F. Stocks Husband shall retain sole ownership and control of the EOS Stock account and the First Capital Stock Account. Wife waives and relinquishes any right or claim to these stock accounts. G. Property to Wife: The parties agree that Wife shall own, possess, and enjoy free from any claims of Husband, the property awarded to her by the terms of this Agreement. Husband hereby quitclaims, assigns and conveys to Wife all such property together with any Insurance policies covering that property, and any escrow accounts relating to that property. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property from Husband to Wife. H, Property to Husband: The parties agree that Husband shall own, possess, and enjoy free from any claims of Wife, the property awarded to him by the terms of this Agreement. Wife hereby quitclaims, assigns and conveys to Husband all such property together with any Insurance policies covering that property, and any escrow accounts relating to that property. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property from Wife to Husband. I. Miscellaneous Property: All property not specifically addressed herein shall hereafter be owned by the party to whom the property Is titled, and If untitled, the party In possession. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property from each to the other. I " ~-=4-(IniliaIS) 5 -#_(lniCiaIS) J. Tu Liability: The parties believe and agree that the division of property heretofore made by 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 with respect to any other Issue which is Inconsistent with the position set forth In the preceding sentence on his or her Federal or State Income tax returns. 8. LIFE INSURANCE: Each party shall continue to own any life insurance policies currently In effect, without restriction as to the designation of beneficiaries. 9. ALIMONY: Via wage attachment through Domestic Relations, pursuant to a Stipulation for An Agreed Order of Alimony prepared by counsel for Husband, Husband shall pay alimony to Wife in the amount of Eight Hundred Dollars ($800.00) per month commencing December 1, 2001 and ending September 30, 2003. In addition, Husband shall pay Fifty Dollars ($50.00) per month 011 his arrears until satisfied. Alimony shall terminate In the event of Wife's death, cohabitation or remarriage. For tax purposes. all alimony payments are intended to be deductible by Husband and includible as Income to Wife. The parties shall execute any documents necessary to convert their current alimony pendente lite order through Domestic Relations to an Agreed Order of Alimony. 10. HEAL TH INSURANCE: Husband agrees to continue to provide and pay for Wife's medical and hospitalization coverage until entry of a final decree in divorce. Thereafter Wife shall be solely responsible for her own health care expenses and any unlsured medical expenses. 11. ALIMONY PENDENTE LITE, COUNSEL FEES AN EXPENSES: Husband atld Wife acknowledge and agree that the provisions of this Agreement providing for the equitable distribution of marital property of the parties are fair, adequate and satisfactory to them. Both parties agree to accept the provisions set forth in this Agreement In lieu of and in full and final settlement and satisfaction of all claims and demands that either may now or h>.lreafter have against the other for alimony pendente lite, counsel fees or expenses or any other provision for their support and maintenance before, (~.(InitialS) 6 -4}-(IniliaIS) . during and after the commencement of the proceedings for divorce or annulment between the parties. 12. INCOME TAX RETURNS: The parties have heretofore filed joint federal and state tax 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 deflcienc:y or assessment and any loss or liability for any such tax deficiency or assessment and any interest, penalty and expense incurred In connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the Individual who Is finally determined to be responsible for the actions, misrepresentations or failures to disclose separate income resulting in tax liability. The parties shall file separately In 2001 and thereafter. 13. WAIVERS OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided each party may dispose of his or her property in any way, and each party hereby waives and relinqlJishes any and all rights he or she may now have or hereafter acquire, under the present or future laws of any Jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, Including without limitation, dower, curtsey, statutory allowance, widow's allowance, right to take intestacy, right to take against the will of the other, and right to act as administrator or executor of the othe~'s estate. Each will, at the request of the other, execute, acknowledge and deliver any and all Instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such Interests, rights and claims and both parties will revoke prior wills or testamentary documents. 14. AGREEMENT NOT PREDICATED ON DIVORCE: It Is specifically understood and agreed by and between the parties hereto and each of the said parties does hereby warrant and represent to the other, that the execution and delivery of this Agreement Is not predicated upon nor made subject to any agreement for Institution, prosecution, defense, or for the non-prosecution or non- defense of any action for divorce; provided, however, that nothing contained in this Agreement shall prevent or preclude either of the parties hereto from commencing, (~~~ l . ~~(Initials) 7 ~_<lniliaIS) Instituting or prosecuting an action or actions for divorce, either absolute or otherwise, upon just, legal and proper grounds; nor to prevent either party from defending any such action which has been, mayor shall be instituted by the other party, or from making any just or proper defense thereto. Ills warranted, covenanted and represented by Husband and Wife, each to the other, that this Agreemenlls lawful and enforceable and this warranty, covenant and representation Is made for the specific purpose of Inducing Husband and Wife to execute this Agreement. Husband and Wife each knowingly and understandingly hereby waives any and all possible claims lhatthis agreement is, for any reason Illegal or for any reason whatsoever, unenforceable In whole or In part. Husband and Wife each do hereby warrant, covenant and agree that, In any possible event, he and she are and shall forever be estopped from asserting any illegality or unenforceablllty as to all or any part of this Agreement. 15. SUBSEQUENT DIVORCE: Husband at his cost by his counsel has filed an action for divorce under Section 3301(c) of the Divorce Code. Simultaneously with the execution of this Agreement, both parties will execute Affidavits of Consent and Waivers of Notice to enable counsel for Husband to proceed with a no.fault divorce as soon as possible, providing counsel for Wife with a duplicate decree. The parties further agree that each of them shall be responsible for their own attorney's fees. The parties shall be bound by the terms of this agreement, which shall be incorporated by reference into the Divorce Decree, shall not be merged In such Decree, but shall in all respects survive the same and be further binding as an enforceable contract, conclusive upon the parties. 18. BREACH AND ENFORCEMENT: If either party breaches any provision of this Agreement, the other party shall have the right at his or her election, to sue for damages for such breach, or seek such other remedies or relief as may be responsible for payment of legal fees and costs Incurred by the other in enforcing his or her rights under this Agreement. Reasonable interest shall be assessed from the date of breach. c,~1 ~(lnitials) 8 +-(lnitiIlIS) A. This Agreement may be specifically enforced by either Husband or Wife In Equity, and the parties hereto agree that If an action to enforce this Agreement Is brought In Equity by either party, the other party will make no objection on the alleged ground of lack of jurisdiction of said Court on the ground that there is an adequate remedy at law. The parties do not Intend or purport hereby to Improperly confer jurisdiction on a Court in Equity by this Agreement, but they agree as provided herein for the forum of equity In mutual recognition of the present state of the law, and in recognition of the general jurisdiction of Courts In Equity over agreement such as this one. B. Notwithstanding anything to the contrary herein, Husband and Wife may also proceed with an action at law for redress of his or her rights under the terms of this Agreement, and In such event it Is specifically understood and agreed that for and in specific consideration of the other provisions and covenants of this Agreement, each shall waive any right to a Jury trial so as to expedite the hearing and disposition of such case and so as to avoid undue delay. C. Each party further hereby agrees to pay and to save and hold harmless the other party from any and all attorney's fees and costs of litigation that either may sustain, or incur or become liable for, In any way whatsoever, or shall pay upon, or in terms or provisions of this Agreement by reason of any of the terms or provisions of this Agreement by reason of which either party shall be obliged to retain or engage counsel to Initiate or maintain or defend proceedings against the other at law or equity or both in any way whatsoever, provided that the party who seeks to recover such attorney's fees, and costs of litigation must first be successful In whole or In part, before there would be any liability for attorney's fees and costs of litigation. It Is the specific agreement and intent or the parties that a breaching or wrongdoing party shall bear the burden and obligation of any and all costs and expenses and counsel fees incurred by himself or herself as well as the other party In endeavoring to protect and enforce his or her rights under this Agreement. 17. ADDITIONAL INSTRUMENT: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further Instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. ~\,- \--- .. - >t. (fmllals) 9 J:1--(lniliaIS) . 18. VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, with full knowledge of the assets of both parties, and that it is not the result of any duress or undue Influence. The parties acknowledge that they have been furnished with all Information relating to the financial affairs of the other which has been requested by each of them or by their respective counsel. 19. ENTIRE AGREEMENT: This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. Husband and Wife acknowledge and agree that the provisions of this Agreement with respect to the distribution and divisions of marital and separate property are fair, equitable and satisfactory to them based on the length of their marriage and other relevant factors which have been taken Into conslderaUon by the parties. Both parties hereby accept the provisions of this Agreement with respect to the division of property In lieu of and in full and final settlement and satisfaction of all claims and demands that they may now have or hereafter have against the other for equitable distribution of their property by and any court of competent jurisdiction pursuant to 23 Pa.C.S.A. Section 3501 et. seq, or any other laws. Husband and Wife each voluntarily and intelligently waive and relinquish any right to seek a court ordered determination and distribution of marital property, but nothing herein contained shall constitute a waiver by either party of any rights to seek the relief of any court for the purpose of enforcing the provisions of this Agreement. 20. DISCLOSURE: Husband and Wife represent and warrant to the other that he or she has made a full and complete disclosure to the other of all assets of any nature whatsoever in which either party has an interest, the sources and amount of the Income of such party of every type whatsoever and of all other relevant and material facts relating to the subject matter of this Agreement. ! (-::,,'-1 JT' r (Initials) 10 +(Inilials) 21, MODIFICA TlON AND WAIVER: A modification or waiver of any of the provisions of this Agreement shall be effective only If made In writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance on any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 22. PRIOR AGREEMENT: It Is understood and agreed thai any and all property settlement agreements which mayor have been executed prior to the date and time of this Agreement are null and void and have no effect. 23. DESCRIPTIVE HEADINGS: The descriptive headings used herein are for convenience only. They have no effect whatsoever in determining the rights or obligations of the parties. 24. INDEPENDENT SEPARA TE COVENANTS: It Is specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and Independent covenant and agreement. 25. APPLICABLE LAW: This Agreement shall be construed under the laws of the Commonweaith of Pennsylvania. 26. VOID CLAUSES: 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 be valid and continue In full force, effect and operation. 27. AGREEMENT BINDING ON HEIRS: 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. /'1 ~4_(Inilials) It T_(lniliaIS) --..-.. LAW omCl: EDWI\RD J. WEINTRAUB lhf,lI NOHnt HIIHIl ~mH.T IIAHHISIlUH(;. PFNN.SYLVANIA 171111 17171 l:IK lltlll FAX 17171 ~:IK '1lKlI BRUCE ,\. JANASI" PIIllntU'I' . . . 1;1\ Till-: COllIn OF COl\ll\lO:'l PLEAS ('l!~IIJEIU.A~U COlfNH', PA "S. · 1'10,9(1-2149 ('IVII. TEW\I . I.OIU JANASI" · CI\'II. ACTION. LA W · IN U1VOIK'1-: Ucfcndllllt IlRAEClI'(o; TO TRANSMIT IU:COIUJ To the Prulhullotllry: Trunsl11it the recurd. tugethcr with thc 1l1lluwing infmlllUliun. to the cuurt tor cntry of II divurce dccrce: I. Ground t'lr dilOrce: irrctricvable brcll"duwnundcr Scctiun 330 I(c) oflhc Divorcc Codc. 2. DlItc lInd I11l1nncr uf scrvice uf thc cUlllplainl: MlIY 10. 1'il)6 vill Ccrliticd Mail, Restricted Dclivery, Aflidllvit ofScrvicc tiled May 16,1')96. 3. DlIte uf c.\ccutiun uf thc lIflidllvit uf cunscnt rcquircd by Sccliun 3301(c) of thc Divorce Codc: by plllintiff: March 14,2002; by defendllnl: MlIrch 5, 2002. 4. Dute plllintitfs WlIivcr of Noticc in Scction 3301(c) Divorce was tilcd with thc Prolhonotary: by pllliJ1tiIT: silllultllllcuusly with this pruccipe; by defelldant: sil11ultllllcously with this pruccipe. 5. RcllIlcd c1l1irns pending: :-.Julie. 2002. 6. Plaintiff lIlId lktcndanl hllI'C signcd II Marital Scttlel11cnt Agrcclllcnl dllted March 14, WIIEREFORE, lhc Court is rcqucstcd tu cntcr II Final Decrcc in Divorcc in complillncc wilh Scclioll 3301(c) uf thc Divurcc Cude and Pa, R,CP. 1'i20.42(lI)( 11~IIU incorpurule thc lcrms of t~e MlIrillll Agreel11enl in accord'lI1ce \\llh Scctiun 301~d <4' lInd_~OI(~? ut' the Divurce (ude. L/ --/ // ~,. _// ~.-' f f -- ~ --. -- . ----- --- E ar . \Iv' ub, ES(IUir DlItcd: ?; 'J- ( 0 '""2..----- or I'llIlI1ti _ CoP -- _ cr <. "r'l 1;1.11 ,. I:, -, ,. BRUCE A. JANASIK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVil ACTION .. lAW LORI JANASIK, Defendant NO. 96. oJ( 41 IN DIVORCE CIVIL TERM N.QJICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the foregoing pages, you must take prompt action. You are warned that If you fall to do so, the case may proceed without you and a decree in 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: Office of the Prothonotary Cumberland County Court House Carlisle, Pennsylvania 17013 IF YOU DO NOT FilE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, lAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY lOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A lAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET lEGAL HELP. Court Administrator Fourth Floor, Cumberland County Court House Carlisle, Pennsylvania 17013 Telephone: (717) 240-6200 1 - . I I I ~ I' f.: I " I ... 7, Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. The Plaintiff requests this Court to enter a Decree of Divorce in this , ~ . matter pursuant to Section 3301 (c) of the Divorce Code. WHEREFORE, Plaintiff requests this Court to enter a decree in divorce , . pursuant to Section 3301 (c) of the Divorce Code. I verify that the statements made In this Complaint are true and correct, I , understand that any false statements in this Complaint are subject to the penaities of 18 Pa. C.S. Section 4904 (unsworn falsification to authorities). i //7/'?' Date f ' IJt"v. ff~-' BRUCE A. JAN S K ~." .' 1 ",' ,/,/ I HA~;L:. ~N ..- ) Attorney for Plain ff 302 South 18th Street Camp Hill, PA 17011 (717) 730-7310 Supreme Court ID #41263 4 EXHIBIU i 'CclmpioI,~ I -.. 2 "" -- -.., '1110 WI"" 10 '-'weihe ' 'ComciloIo ,- 3, ". ..... 4l), fcltowlng ..Nlcet (lor III I '::::1.0UI nwntl ~ ~r... on lh, rl\!"" III U'\L.llloon 10 Ihlll \lte can retum IhI, IXlr. fee,: '''OCIll:ionn '0 ,.. .... or ,.. ....."...,., Of on ,...".'" ""'''' - not 1. 0 Add"_'t Add....i ' .ll::'!ilOllHn R_ptR<</_'on,... ma""..", boIow th, '.'<:lo_. ~Aettnc1Itd DiN~... 'The Aetum FI~PI Will thow 10 whom I"" ertk::le,," a,lIl1erect Ind the dlfll 5 dlIttvlrtd, poii....I~. 'VI ,_. _ , Lo~,Addr~j:~N~\( :.A::~N~or G0 i]S AM Go Rtg/tlorad .l3::Ctrtlftad j 1 A ^ ,\. 'I 0 ElIp.... Mill 0 1.lured f l.l~.t ___ "..-{. 0 R.lum RoooipllorMtrt:hanclllf 0 C~ ~ ],'8' .. 'vtry 'r- :- .-:": ;'v I .... (Only 1/ roqUlfIld J e. Rectlvad By: (Prtnt NRmtI I \ e. SlgnaN 'X , · PSI'""" 11. il " I " i, /; I',' , I I ~, ~ '. i' I I' "I , BRUCE A, JANASIK. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VI, , . : NO. 96.2149 : CIVIL ACTION. lAW : IN DIVORCE LORI JANASIK, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 53301(c) of the Divorce Code was filed on April 19, 1996. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 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 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. ..----:'\~~~Janal~:~.~n~~ Date: 3/5/0 :l SAlOIS SHUff, FLOWER .. LINDSAY ATmaNlY5-^Tet,AW 16 w, Hllh Sir,.. C.,lIllt, PA " .-J\ . C.: r I,d 'I), '.1:1 '.'J t' ;'1 -. " LAW OFtlCf. EDW\RD J. WEINTRAUB 2600 NORm TltlRO STREET ItARRISIlUR(;, P~"~!~':~VANIA 17110 /7171 2:1lI221KI FAX 1717/ 2:IlI'12HO DRUCE A. JANASIK . IN nlE COURT OF COMMON Pl.EAS Plaintiff . CUMBEIU.ANU COUNTY, PA . \'S. . No, 96.2149 CIVil, TERM . 1.0RI JANASIK . CIVIl. ACTION. LAW Defendant . IN DIVORCE AFFIDAVIT OF CONSENT I. A Complainl in Divorce under Section 3301(c) oflhe Divorce Code was filed on April 19, 1996. 2. The marriage of Plainliff and Defendanl is irrelrievably broken and ninely (90) days have elapsed from the date of the filing and service of lhe Complaint. 3. I conscnlto the enlry of a final decree In divorce aner service of nOllce of inlenlion 10 requesl entry of the decree. I verify lhalthe slalements made in lhis aftidavil are true and correct. 1 undersland lhal false slalemenls herein are made subjeclto the penalties of 18 Pa.C.S. Seclion 4904 relaling to unsworn falsificalion 10 aUlhorilies. l. , , Date: ~ _ /'f - c..J l. .-L Brucc A. lan ,I 'I , , , , , -, . ...... ~. ,,-.. Wf:J ~~ -.--......- c '. -, , P:I r - , 'I, " -. i , I I' ,I I! ! I ~ r I, I I , , . , I , \:, \ , LAW OffiCE EDW\RD J. WEiNTRAUB 261\0 NORnt TIIIRD STRE,T IIARRISBURG. PENNSYl.VANIA 171111 17171 2:1X.2201l FAX 17171 2:1X'l21il1 - , BRUCE A. JANASIK Plalntlrf · IN TilE COURT OF COMMON PLEAS · CUMDEIUANI> COUNTY. PA . VI. · No, 96-2149 CIVIL n:RM . LORI JANASIK Defendant · CIVIL ACTION . LAW · IN lllVOIKE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY Of' A DIVORCE DECREE UNl>t:R SECTION 3301(c) OFnn: I>IVOIKE CODE 1. I consenllo the enlry of a tinal decree of divorce wilhoUl notice. 2. lundersland thaI I may lose righls concerning alimony, division of property, lawyer's fees or expenses if I do nol c1aimthcm before a divorce Is granted. 3. lundersland thaI I will not be divorced unlll a divorce decree is enlered by lhe Court and lhal a copy of the decree will be senl to me immediately aner il is filed with lhe prolhonotary . I verify thallhe stalemenls made in this aflidavil arc lrue and eorreel. (understand lhat false slalemenls herein arc made subject 10 the penalties of 18 Pa.C.S. Section 4904 relaling to unswom falsification to authorities. Dale: ?~IY-() c If~ ~ ,. . -, ... - .... '--. " ..r., ..... ...... ,. i i I 1 t. I I I ~ I. I " i 1 I,' ~ t~ -\.. L, '-t: r-. (~ 1 " " "' 'C .,. ,':l ~ :r; >- '-J '" 1- lA , " .. \j. ,: i ,; : ~ l~ I>) .c ~ " I i 8' ~. , ,,' ~ "- "- , J ' , 'I. . ~ l'lJ 9 4: , ::j '. Ii,'... -It ':J :~j ".) \.-) u ~ ~ ~U ~ e~~~ ~ I:: ~ ~ ~ ;'2 -1 i:i: ~ Ii ~ ~ ei ;~~~ ~~ :1g = tIl ~ e < tIl ~ :: ~l ~ ~ ~H ~ ~. .... ::c 0.; ~ ~ '" uJ - - :: ::J ~!:: I;; ~ ':: ';' [:l ;~ " -:J -< ~ < ;P. f.J "" WHEREFORE, Defendant prays this Honorable Court to equitably divide the parlles' property. COUNT III. ALIMONY 11. The averments In Paragraphs 1 through 10 above are incorporated herein by reference. 12. Defendant is without means to provide for her reasonable support. WHEREFORE, Defendant prays this Honorable Court to enter an Order of alimony. COUNT IV. COUNSEL FEES 13. The averments in Paragraphs 1 through 12 above are Incorporated herein by reference. 14. Defendant Is without means to pay her reasonable attorney's fees which have been exacerbated by Plaintiffs refusal to respond to requests for settlement. WHEREFORE, Defendant prays this Honorable Court to Order reasonable counsel fees. SAlOIS, SHUFf, FLOWER & liNDSAY, P.C. Attorneys for Defendant SAlOIS SHUFF, FWWER " LINDSAY ~",'T""W 16 W, Hllh SIr"' C.rh.lr. PA ~::.. '.~ Carol . Lindsay, Esquire ID#<l4693 26 West High Street Carlisle, PA 17013 (717) 243-6222 :, , By: "\.0 ~.. . .....1 . BRUCE A. JANASIK PlaintIff * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY, PA I I I I' * vs, * No. 96.2149 CIVIL TERM * LORI JANASIK Odendant * CIVIL. ACTION. LAW * IN DIVORCE AND NOW, this E f!d~ ~) ORDER ) 'l ./ ,<.:. day of (J;'~__ , is hereby appoinled Mas~ in DI orce. , 2001, BY THE COURT: IH .<\~ ~~~\ ~ V C\.~ r ~ I, I' I~ " ." '- I.~.. l"\..1 " " - .... ..J't " I I. I I I, I , .i -I -.' .' BRUCE A. JANASIK * IN THE COURT OF COMMON PLEAS Plaintiff * CUMBERLAND COUNTY. PA * n. * No. 96-2149 CIVIL TERM * LORI JANASIK * CIVIL ACTION. LAW Defendant * IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Bruce A. Janasik, Plaintiff/Pelilioner, moves lhe Court to appoinl a master with rcspecllo the following claims: (,/ ) Divorce ( ) Annulmenl (,/ ) Alimony ( ) Alimony Pendente Lite and in support of the MOllon stales: I. Discovery is complele as 10 the claims for which the appointment of a master is ( ) Distribulion of Property ( ) Support ( ( ) Counsel Fees ) Cosls and Expenses requesled. 2. The Defendanl has appeared in the action by counsel. 3. The slalulory ground for divorce is the two (2) year separation as of April 3, 1996. 4. The action is nol conIes led and no agreement has been reached wilh respect to the disputed claims. //---~ 5. The aclion does nol involve complex' sues of I _QI' flict. " ---- ~ 1 A 6. The hearing is expected 10 take _ L Date: {; li Edward J. Weintraub, Esquire Attorney for Plainlifli'Petilioner ~ L" -.I> BRUCE A. JANASIK, Plaintiff JUL I' 20mr!- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 96 - 2149 CIVIL LORI JANASIK, Defendant IN DIVORCE TO: ],;dwa!-d ,J, Weintraub Attorney for Plaintiff Carol J. Lindsay Attorney for Defendant DATE; Monday~ July 9. 2001 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate wh~ther there are any outstanding interrogatories or discovery motions. There ia no formal discovery outstanding, Plaintiff may need data on Defendant's 401K and her progress toward graduation. but these sho'.'ld be produced without the need for formal discovery. j , , ! ~ t ~ t I. ~ " '. 'I BRUCE A, JANASIK ... * IN THE COURT Of" COMMON PLEAS PlaIntiff * CUMBERLAND COUNTY, PA * \'1. * No. 96.2149 CIVIL TERM * LORI JANASIK * CIVIL ACTION - LAW Derendant * IN DIVORCE INVENTORY AND APPRAISEMENT OF BRUCE A. JANASIK. PLAINTIFF Plainliff Bruce A. Janasik, tiles the following Invenlory and Appraisemcnt of all propcrty owncd or possessed by eilher parly althe time the parties were separated. and correct. PlainlifTvcrilies thallhc stalemenls made in this InvcnlOlY and Appraisemcnl arc lrue Plainliff undcrstands thaI falsc stalements herein are made subject to lhe penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsilicalion to aulhorilies. Ll~.i~~ Bruce A. Jana?ik. Plaintiff J Date: -S/1 lu I ASSETS OF PARTIES Bruce A. Janasik, Plaintill\Defendant, marks on the list below lhose items applicable to the case at bar and ilemizes lhe assels on the following pagcs. If an item has been appraised, a copy of the appraisal report is attached. ( ) I. (.I) 2. (.I) 3. ( ) 4. ( ) 5. ( ) 6. ( ) 7. ( ) 8, ( ) 9. ( ) 10. ( ) II. ( ) 12. ( ) 13. ( ) 14. ( ) 15. ( ) 16. ( ) 17. (.I) 18. (.I) 19. ( ) 20. ( ) 21. ( ) 22. ( ) 23. (.I) 24. ( ) 25. ( ) 26. Real property Motor vehicles Slocks, bonds, securilies and options Certificales of deposll Checking accounts, cash Savings accounls, money market and savings certificates Conlents of safe deposit box Trusls Life insurance policies (indicale lace value, cash surrender value and current beneficiaries) Annuilies Gifts Inherilances Palenls, copyrighls, inventions, royalties Pcrsonal property oulside lhe home Businesses (list all owners, including percentage of ownership and officer/direclor posilions held by a party Wilh company) Employmentltemlinalion bene filS . severance pay, worker's compensalion claim/award Profil sharing plans Pension plans (indicale employee contribution and date plan vesls) Reliremenl plans. Individual Retirement Accounls Disabilily paymenls Liligalion claims (malured and unmatured) Mililary/V.A. bene filS Educational benefits Debls due. including loans, mortgages held Household furnishings and personalty (includes as a lotal category and attach ilemized lisl if distribution of sueh assets is in dispule) Olher LlABILlTlESOF PARTIES Plaintiff, Bruce A. Janasik, marks on the Iisl below those items applicable to the case al bar and itemizes the Iiabililies on the following pages. SECURED ( ) ( ) ( ) ( ) UNSECURED ("I) s. ( ) 6. ("I) 7. ( ) 8. () 9. 1. 2. 3. 4. Mortgages Judgmenls Liens Olher secured liabililies Credit card balances Purchases Loan payments Noles payable Olher unsecured Iiabililies CONTINGENT OR DEFERRED ( ) 10. Contracls or agreemenls ( ) 11. Promissory noles ( ) 12. Lawsuits ( ) 13. Oplions ( ) 14. Taxes ( ) 1 S. Other conlingenl or deferred liabilities i ~ ... .~ 0 l t 5 ~ !l ~ ;; ~ oS j ~ .~ 8. ~ ~ ~ 5 ..... ... ~ - - ~ ;;; b ... ... g ~ '" ';; l!] ] i ,5 :>< .1! , ~ .1;; i:: .~ ....~ =' 0< ~ 5 5~'O a. } ~!~ .j i a. .. ..l " < ;> , ~ J! l 1 ~ < ... 0 ] ~.~ a ~ ';j = ..c: < ipl t i ~ I 11 h 'i,i - ! J !~ .... II ~ - "'.M J ~ ]... ... ~ 0. 0 J - lQ ~ QC i j ~ ~ I!l ~ ! '" ... u.l ~ ..; ..; .-i ,.; ,.; ,.; . , . .,. BRUC.~ A. JANASIK . IN THE COURT OF COMMON PLEAS Plaintiff . CUMBERLAND COUNTY, PA . n. . No. 96-2149 CIVIL TERM . LORI JANASIK . CIVIL ACTION - LAW Defendant . IN DIVORCE INCOME AND EXP.~NSE STATEMENT OF PLAINTIH, BRUCE A. JANASIK AND NOW,lhis,;.:);.r day ofJ, 1\..( , 200 I, Plainliff, Bruce A. Janasik, by and lhrough his altomey. Edward J. Weinlraub, Esquire, files the wilhin Income and Expense Slatemenl. Res lTysiiD~ed: E ward 1. Wcinlraub, Esquire 2650 North Third Slrcel Harrisburg, P A 17110 (717) 238-2200 ID #17441 ATTORNEY FOR PLAINTIFF <.:..-: --. ~. 11I':1I1l1~ "lid E'r~lIs" Slal~lII"lIl PACSES Cas~ NUlllh(r OrtlER (Fill III Arpmprlale Columll) INCOME WEEK MONTH YEAR 11I1(r(SI S S S Oivid(lIds - P~lIslllll Anllulty Sodal Sc.:urilY Rellls Royahics -- Expellse ACCllulIl Gifts Unemplllymem Compensalloll Workmen's Compensation IRS Refund Other Olher TOTAL S S S TOTAL L'ICOME S 11I~1I1l1~ ~nd E'p<lIS~ SI.Il~IlI~l1l PACSES l'as~ NUlllb~r EXPENSES (Fill ill Appn>prlal~ COIUlIIll) (conllnued) \\'EE" MONTlI YEAR Wal~r S S S S~w~r Employmenl Public Tr~lIspllrlalillll S $ S lunch 3'0 Taus R.al ESlal~ S $ S PersolL'l1 Propcny 300 fncllm. 1-07$ 7L/ 't-r Insurance Homeowners $ S $ AUlomobil. SS life Accidcm Heallh III.( Other Aulomoblle Paymellls S $ :Z-Q1 s Fuel LfO Repai rs ~SD , - Medical Doclor S $ $jj.i> DemisI la~ Onhodllllli." roO Service T)'pe Pagc 3 uf 6 FlIrlll IN-OOS Wurkcr 10 - , 111<11111. alld E'p.lIl. S,a'.'II<1\I PACSES Cas. NUlUh.r EXPENSES (Fill ill ApPl\lprial. CUIUIUII) (conllnlled) \\'fi E 1\ 1\I0NTlt \'EAR Hospi'al M.dicill. l'-> Sp.,ial 1I..ds ISI3ss.s. hra\.'c:~. Otthllpc:dh: So d.v;.;.s} - Educallon Privaee Schuul S S S Parochial S<:huul ColI.g. Religious Personal Cloming $ S $ -350 - Food , ~- ;J.. DO - ~,J.J--' Barber/Hairdrm.r fo~ Credit Paym.llls: Credie Card - Charge A<:<:uulll ~)UV Memberships Loans Credie Uniun S S S - Mi!cellaneous - Household H.lp S S S Child Car. Pap.rs/BI1\'ks/Masazi II. Emerrainl\lC.'11C I DO Pay TV Lf!J Va<.;ilioll S.rvic. Type Page 4 of 6 Form IN .008 Wnrk.r ID BRUCE A. JANASIK . IN 'l'IIE COUR'I' Of' COMMON Pl.EAS Plalntlrr . CUMO.:RI.ANI> COlJN'I'Y,. PA . VI. . No. 96-2149 CIVIL n:RM . LORI JANASIK . CIVil, ACTION - LAW I>dendant . IN mVOIKE CER'I'IFICATE Of' SERVICE I, Wendy L. Shive, Legal Assistallllo Edward J. Weinlraub, Esquire, hereby certify that on July 6, 200 I, I served a true and correct copy of the MOlion for Appointment of a Master, Plaintiffs Income and Expense Statement, and Inventory and Appraisement upon Carol J. Lindsay, Esquire, counsel for the Derendunt, by depositing same, postage pre-paid, Certified Mail, Return Reccipl Requcsted ill the United States Mail, Harrisburg, Pennsylvania, addressed as follows: Carol J. Lindsay, Esquire II East High Street Carlislc, P A 17013 Date: 7/U/ot (.-'I .J BRUCE A, JANASIK, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION. lAW NO. 96-2149 CIVIL TERM CIVIL ACTION. lAW IN DIVORCE ~ VI. LORI JANASIK, DEFENDANT'S PRE.TRIAL STATEMENT I. BACKGROUND: The par1ies were married March 27, 1984 at Bay City, Michigan and were separated on April 1, 1996. They are the parents of two children Nathan Bruce Janasik, born January 16, 1988 and Jonathan Thomas Janasik, born November 7, 1991. Husband has a bachelor's degree and for many years worked for EDS. He Is now employed by IBM. Wife has an associates degrees and is attending college to I .J complete her bachelor's degree so that she can teach in elementary schools. Since ! prior to the parties separation she has been employed by Toys-R-Us. II. Martial and Non-martial Assets: The martial assets are summarized on an asset lis! attached hereto as Exhibit i I I I A. Exhibit A does not list any non-martial assets, nor are there any. I h I" III. WIJNESSES, LAY AND EXPj:RT: SAIDIS SHUFF, FLOWER " LINDSAY 'T1'OINIII"'T~ l6 W. Hllb S".., C.rll"I, PA The case does not require expert witnesses if the parties can stipulate to the value of the husband's EOS Pension. Wife intends to testify in her own behalf. IV. eXHIBIT~: Attached hereto are the most recent statements for all martial assets in a I" plaintiffs or defendants or in wife's possession. Negotiations in this case have taken place over several years and updated statements are required for the EOS 401 K ~~ Plan value presently. Attached hereto in addition are all statements of all martial debt In wife's possession. V, INCOME and EXPENSES: Presently, wife Is attending school and working part-time. By order of Court of July 12, 2001, attached hereto as Exhibit A, from which an appeal was not taken, the Court determined that her net monthly Income Is $773.57. Her Income Is not sufficient to meet her reasonable needs. Wife's income and expense statement and a tax return for the year 2000 will be provided at pre-hearing conference. Her pay stub Is attached. VI. PERSONAL PROPERTY: Personal property has been satiSfactory divided. This includes the vehicles. VII. PROPOSED RESOLUTION: Wife seeks sixty (60%) percent of the martial estate and alimony In the amount of present support, $799.00 per month, through December 31, 2003, six months after wife's anticipated graduation date. Wife seeks payment of a portion of the martial estate in cash and the balance fee rolled over from the EOS 401 K. SAlOIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff SAlOIS SHUFF, FLOWER " LINDSAY A~\'S-AT.uw 26 W, HIKh 61'"' Cnll.I.. PA By: "I " .', I r ,!I/I l[ r. Carol J.tindsay,'Esquire ID# 44693 26 West High Street Carlisle, PA 17013 (717) 243-6222 . ~ ~ 2- ~ ...:.i "" 8 -- -T-- --1-- - --- --'-T --'1-- -- ---~- --- --- --r- -. - -- -- '" .'" J '''' - '8. -- - -- -- m <: " ~ '" ~ I'i '- ~ ~ ~ a ,.. f, ;; ~ ." 0 ~ "" W ~ , Ie g ~ , ,.., c ;;l ;; e. .2 E. , " ~ , - O<l ;.. :g , 8 -- f-- --- 1---- I----- l ._-~ -._- _1_ - ---'----. --. -.- --- a 1il '3 . = :::' ;; -; ~ ,.. ,.. '" '" --f-- - .__...._1.. . l .. :" '" -" O<l ;.. '''' '" ~ '" :" <l 8 --- .-- - --- --- - -- ----- :", '" '-" ~ . ___ __1 '" ~l g ~ - N '" 8 "r---- --r-' --- - " 1-- - 1--- .-- - - z 0 @. f is s: '-" N 0 ~ ..- i-- ." m Ql " " ~. 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Bmc .1041: Sandy, C'I'M4tJfH..1041 Oallne" In' f1nanu c:ha,.1S Currf/11r hrlfmfPflrJorl P"""'ml! bIIlr"RP.t'''"rl 6"/"n(, b'J/,,'j-/' pUff-h"lU ,,,,h,JrlwlncfI! f1t1n1!.r1 "(dllrll,,,,,,! purrhtJJu ""It dill/11m" tr.m,." A "'trllll D.uly D.\II1nCft 10 10 JI,d9M8 10 10 10 S/,JOfU1 Daily PCrio1.1l1: Rilflll .Old/tI"1. ,tJU1J% .rJttl/d% .oonoo% ,O/llltS~~J ,OU}j% .00d/d% Day~ in 91thnl Penol! ;. ;. ." ;. '" 4. 4' PcnQdit: fl~ANCf. ctUIG[S 10 10 Jl.9" 10 10 10 l/J.U -r'l1n8,11:t1on Fu "I~ANCI: CIIAKGlS IIm'" 10 ~,"'. n"lfe /llItll lion. nnllll' ^,~,NUAL PERCr.NTACF.IlATI'5 ,1.9W'~, /9.110% j.90':~ O,(lfJ'! ~ .1,90% J~.IJO% 5.9fJ% AOo50,90 1m lJSE~. T/;,ffl' , { I~ --... ..,............1fNII retum N u"., ....1N'I.tth pur............,..,. Thank YOU for shoDDlna at Hecht's MAR J.3 075-0:Lu7 2'1 :L42 JR CAREER SEPARATES J.LI.'I'ICR MAR 2A Ob:L-:L525 2'1 24'1 JOCKE Y FOR HER :L5.57 APR IJb 032-"l1l'l0 2'1 '1'1'1 PAYMENT RECEIVED-THANK YOU 40.00CR APR Db Ob:L-2D77 2'1 24'1 JOCKE Y FOR HER :L5.57CR ........... ........... . . . t Hecht's Account Summary D-00424"l A ACCOUNT INQUIRY CALL (1l001 allo 311A ~ '12,'13 , :L5.57 """~;:.~.~".". ".'I__""~..:-~~~".,,_...'T-_._._;.;.~~~., I """10 r account numMr whttn "'Ikl In ull1.. Thll blll oontalnllfMMCtIonI fl -C!5.00 I FLEX 140-81'1-'175 05/05/.... NOT1el!: S.. mira. lid, lor Impor1anI1nlormltlon. .-.... ' , 'lW\Ilal.lInl1 Dolt 05/20 05/U 05/20 03/22 03/21 u5122 03/22 03122 04/05 04/08 04/15 04/15 04/15 trrrt'IIl.'l!' Mrn.:hllm Nalllr: IJr Tr,lll~il~lI1111 [~\~'nplllln ('m) Nl!'1olo Pun:huM.'!\, f'tll', Paymenlll &. 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UNIONDALE. /IV 11553-0999 Illlhl.' e...enluf II hilfiny elnu pltli.lht wnle tn the adll~SIl i.Ih!I"'<< I f"r~":,~'~rq;;'~~'~l~~~~,49 ],- 5A~~;;:;9b-7200 [I' c;wd i~ Jll~1 ur ~Iolcn, plell~c ~'llll: C"m!inenlul U.S" Puen" Ri~n, V1rllin l~hlllr.IH: 1.1I01l,IIl'll,IJ.15l'l. ,\11 .)Ihet [UI.'U1Ull1~ ~ull ~(Jllecl: 70K. "KII.Mon, , I I , I , l ,r / ",., .._-_..~,~.... ---.-...-.....--. ---'. ~.. . .---~.. ,~'~"" ~1._~W?~i': . , ' ',' ~~ j "" ',~:', .: u. i ~;" ::;;' ".. .. "^'^" ,""""",- ",.,,,, "'" ';~;;;': ;',,~', ';j ~1J.:i96 29~ · ON . _ 0 1 96 $ 'i; '1'0\1 M"" ^"'oIU Ai)DIIION"!. III\^'" ~ lll.\MloUt D'r' 1'^,'jNU \Ill: /IoLW MI.ANU I)V ,,^\,~"Nr 1)\(1. ..It .;) O l'h.~k bill _,11,1\ QnJ 11lJI~"C: new M^IU: UIl(~ 1'^\'^~I,JU,W"'ljO'J.,~ :.ri':" ~ "hhcn unLt/I.lI' phoue numher 1111 bQ..k, . . .; : ',~t\.' I, ; I '~Jl , " . II ~ ,'. . .' I' .1 .~ Ilt..;',1 " f.-I";' "" \., '..';,,-t:;.' \;1 . . . r~, l', ", w k . 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AGENCY INC. 311,:: 24 t' HARRISBURO PA 7321 274001356010000740460116 1 11 1 10 CASH ADVANCE IUD: DO 'I.,<M' 1565217/RT 114 : , ',-', MECHANICSBURG PA 6011: 2~"~3,,,0~,866011000190051997 1 121 11 CASH ADVANCE 100,,:00 , 1069A120/UPPER ALLEN '~j.' :, MECHANICSBURG PA 6011 i rl~.~ " , . w.,---- --- PAYMENTS AOJUSTMENTS AND OTIlERS _..--,.---..--------~-- ,j:~7t327006005;4~00505778\ 1 05 1 05 lAYMENT R~CEIVED, T~ANK YOU 2000: OOCR ~.~\' '.. GET OVER YOUR IlIGH RATE CREDIT CARDS, USE T'IE FREE I ~1[~j.;:;: W!.~OVIA_!RANSF.~~~_H:CK~.~.E:V.:.-!~ClOSED! I ~J,r~ 't ~, 1".,.... , '." ",1 i' , "J,'" ,'i\.t;~, :, '~r'f'" ,,',1' ,,~. ~', . '; '/',: '. ~ ";".~ ; ~;.: !.',\'.. i:~:"'i" ~r'~~.' l1tt~,,\'i", ,~".M~(;. Il.o\IlY Ml^/'<l~. 'Ely1llI!O.I~""l~(II^MI,t"l ~Ir.,\'(;---j-.- I ~~It ~HIlIIJI!. ~ll 11\11101' .~IJ"'-\"lll + ~ III' ","I ,'" ~1l"MI"; (II~H'" "I''''''''''''~! .. ,. ,'HK'I" 5 21JHI -'ti~j3 _RfU9L_ ~ ~~~ ,.~~, ,', 1'1~~~~'I\~I'll "',," , "'""",' ,,',.. I{\II U'I I . 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'j Credit Curd Trullsuctillll SUlIIlllury Account NumMr ClOSing Oal. 5437 0307 002~ 0005 01/16196 Relerera Number 'b~t,';~ TJIr'61.~~"O~ 02-02 1/15.302/U""CI4141' Credillimlt $5000 Descnphon * * 'LEASE SEE THE ENCLOSED IHPORTANT INFORHATlON ABOUT CHANGES TO YOUR UH CARD. fOR ADDITIONAL INFORHATION. 'lEASE CAllI 100 119-9505. * * HAPPY NEN YEARI EVERY TIHI YOU HAKI A PURCHASE NITH YOUR GH CARD. YOU CAN REcnVE UP TO I~ EARNINGS TONARD THE PURCHASE OR lEASE OF A NEN UH CAR OR TRUCK I NI lDOlC FORNARO TO SERVIHU YOU THROUGHOUT 19"_ 1 '., ~ <'''-I " ';\ ~.f 'I 'r' ,:1 l~ I ., , .\ ..1 ,.) ,-_.J _.. '. _' .. I, , [.j i':: ' '1 /;"'1;:~ /-.., , \ I ;.: r 'J!,{ '; i' \- .. \) :..! f' ( .".. ~4 ~ . )" ,'; '. ',.., , , ' I ,( ,~ I " ,.j " 9 . 51. 74 .0.69 Credil Curd SUllIllllll'Y - . A_OoIl_ DIll . ~~~I IlINUALP1RCEIIIAIIIlIAR P.-Ail, I F.lhaProd PUIlt:HASE P.J/dII",APR CoilllR t512.65 0.0511~ 1I.90~ 17.97 lI"D~J 11. 90~ 11.90% CASH "00.00 O. 0511~ ".52 1 0", ,"'.,c"" '_IPR 30 13221.59 021121.. .U... Ayallable Credit H774.41 Amount Account SlImm.IY luulill.nc. Pu~nlln . C.lnldmm . Ctldl~ hymln~ o~.,cn,,," . IInIRcICiIlIII . ezU.M nO:M." 12...... ' ..... , no. IOCR ..... '17.2' ,\,.,' .~ '... _.',i . - ,......... ...~--...._--'"'.....'-------- ---.. 01-02 1/11610:1,"",1~1401 Credit Curd Tl'UlIsurlillll SlIIlIIll111')' Alxoonl Number CIGllngDoie 5431 0307 0025 0003 01/16/96 Ref.rence Number Phl.l;;g 1"OW,hUll _gescrp~~n 77~Z5"IUU"1967001" 12/19 12/17 TEXACO INC 14UI4U.... LEI10YNE ~A 7l~117S1111<llnIl0211120 12121 12119 GIANT fOOD IU SIO HEtHANICsaUR" 70~"21IS17177011704116 12/26 12/22 ~HAR-HOR 100117 HECHANICSIURO~A 714111<llnSOI7U~6?I~"'1 12126 12122 ILOCUUSIU VIDEO nos HE~HANICSOURO~A 71~1171.IIIIOII0021101~ 12/26 12/21 GIANT fOGO III SIO HECHANICSOUR ~A 71~1II<l1116107~IIOll"116 12/21 12/26 OLOCKOUSTER VIDEO 1'01 HltHANICSOURO~A 77Ul"ISUS2I771UI~"7 lUU 12120 SHEETZ INC. 195 HECHANICIURG ~A 70~IMlnU17~I~U62719 01/02 1212'. ILOCKIUSTU VIDEO nos HICHANICSIURG~A 71431411$61'"112041662 01/02 12110, UK KAY OU' INt 1656 CAH~ HILL ~A 7l~IMl"0107US219"".. 01102 121U, ILOCKIUSTU VIDIO nos HECtlANICSIURO~A 77~Ulll"SS2I771UIIOS 01/0~ 01102' SHElTZ INC. Its HICHANICIURG fA 70~1II<l1110107~1~12146.1 01/00 01/07' ILOCXIUSTER VIDEO "01 HICHANICSIURO~A 711<l1100....0211000l0504 01/01 01/00 BUll II/EARNINGS CK IOSOl 0002020,.6 7l~1I7S"0Ilnl012711" 01/09 01/07 GIANT fOOD 119 SI' HECHANICSBUR PA 71Ulll..0112Il.,,1002,. 01/09 01/07" SHIITZ INC 201' HICHANICSIURG~A 71~1II<l1111003l11'021150 01/11 01/09 IJ'S IIHDLESALE 121 SSX HARRISIURG ~A 70UI21..12Z070.,,65ID51 " 011124'01/11 't ElECTS 10UTIQUE 1125 CAH~ lULL ~A 70~n2"0I220706~"10" 101112':01/11 : ElECTS IOUTIQUE IUS ,CAH~ HILL,. ~A. 77U4U..UII6I09S76550' 01/11 !;.'0I/12 i 1lO0IL OIL' 01340157' HUA' ' AI' IM17S4101~"0141011070' 01/11 II 01112 NIIA' AIR 0l2~4"77542U ' HIDOLETOIlN I ~A" 70U~UIOlUIO"127Sl11'. 01/15~0I/15 . DILLARDS SU~USTITN 'HUA , AZ "~U~"0l~124U12001S4 01/15 01/15 JC~ENNEY CO 12U9 HESA") AZ Credll Umll HOOO Avolloble Credit U714.41 Amoonl In... I~O,27 114." UI." "7.U ...60 112.75 ...17 Ill. 7~ 114.2' In.n ..... 12000.00 ..~.04 112.1$ I~O .11 142.59 ".n U5,OO "'4.00 120,02 125.62 .......... .............~...._.... __u~ NO,__ ~ PA.YMENT":; I ADJUSTHENT:\ AND onlUIS n~~" n_.. u_~_ n...... -.. u .............. 7121$00"01620514421066 OlIOS OlIOS ~AYHENr - THANK YOU 130.00CI __.___._____...__._ ~ARTNEI 10HUS AND OTHER OK EARHIHGS ACTIVITY IHIS ~UIOO --...----.......- KAY DE 01/02 01/02 KAY BEE AS OF 01/02 0.6' f1ltR!! lIIiUIlPlRCEiTIGERAn AcCGUnl.SUmmltY CH ff1 n.s Pm P~Ir.hUtl ,lJ'R I;,,'IPR "..IOUI111IllCI Pu"hllll . CllhAllVllKl1 . IDIJ'lnlltam;C!t'l fl![mx01jJl~ Crtdlll paym.n11 Olh.,Chl~11 . --- ,iIIIm_ . PI,mtnl~u~"llidO'1 <OM Curd ElIl'I1ill~S SlIlIlIlIaI'Y Previoul GM Card GtA Card ~arri-liiQ5- M~tloniJfarw\gs'- '"In : n Rece!~ed ThiS Pellod Received Thlsl!!!QL --o-'hilTciil,iT E fOi:iiGij Cald _~IS PllIIO.~_, :J.!..~n5 ThiS Pewld Cl'edil Curd SlIlIIlIlill'~' ;. ~ilIII- DOll PmkRalt Pliillt_ MvwMP,,,*,1lIIo N.tRallnCI . ----..-----..-- ------.. New Earmngs 10lal _Soo_"'~_ _'~""J"plnocI, Wltl'l\ YOU'J'(' l'I'iI(l~ [0 1'1,,11"'11\ your I;M Cilrd Eill'llill!ls 10 huy Of Il'llSl' iI JIl'W (,1\1 1'111' III' II'UI'I\, I'illlus ill I HIlIl !J.I7. \000, .' --...........---..---- .' ,.....-----..,.- .~_._--_.__. . . -_I , , Hi r HIf f f f 0"' iJ I~J It. II" . I .5 51, ... I II - ~ I .;, .. I :: ~ -;:1 t '" - ~ ~'; ~~ :i -" ~ h. :-O....P""'f'oi ....;1'.0'" ... .... ~t..... i 1 1'- I - ~ " 8 - I . a. ;; 8 ... I . I .... '*"..-: I' - - ILl .~ ~ t: I f . ~ ~ ~<I :i OJ 3:;;/ ~ j ~FlhHI Ii f II J~-. f f ~ f" " w ~ ::: ::: j i ~ .. .. !r~ : ~ ~ w ~ t: _ a --wOQo..a 2 :;;t~U8=!l ~ ~ i~J .. .. it a O::)COOQOQ 8 , 8 83UUU ; .. .. i ~ w w \!l ~, ~:::~Q!=,!O!OC .. 83e88883 .. ~ .. .. i . .. .. ~a e -. e....o....:cr;:;;:~ ... ~ ~=8~~~e! II ,..J) .. > 2 C:CIl >c: 1113: <~ -- . > -lll J< ,0 3:'" >> llll"l Qg .~~ j . . iinf nUf f iilT a -<<-<r I n ~. fJfif fffii f - t ! I f .!~I~ r ~ -fl "if I _ _ w J~l> ~-:' 1 .....,., ~ ..........- -.. ~~=~ ;':~e~ =:!! " I "" '" III" > I l>. -f i!'1 - - N it .:11=':" .........""'f.... "" -3 ~~~~ ~~ ::!l:~ Itl..~ :,' I.- ::D i! _~ j l ~. ~ ;;:~~ P ...Q:~ - f~ i ~.o-.... -~ Q. '. ~ ~ ~~- ... JII ~~ _ ~ ,'/; ~ 111.1 ,., .. Ii' .. I , . i' I ~: Q=~ht fli i -,.""w . ;- ~~~~ - i:~~ ;....,f = "'1.1 ::: i .. I J ." ! 1 f ! " ~ 1 ~ i, f 1 ~ iHnr{ n inf I qHfi ~ 1"~ It l' .. ! l:- j"> Ii! JJ :!l "".......- ;i' :;; :.......;...io" -......... '. . . . . - N: . . . - > Ii f~ ~ -,0: :;; -..3'<1.0 -.,t ~ ~~~li: .. 1- ~: J'.- ~.- h i ~ l: . ;: =;:;~..., iI !I. :;; ::::;ii~ ~ ! . ,'I,' ::: : . i " i!' . 3~ " - - N ~ .... IV .. ,,.It - :c :~a~ - 3 . 1,'11 .. ~: .i!- " lpl . :! - - w 3~'f "'.........". ~ e~ ~::: ~ : Ill,' C, 1"'; ;; r4.j " - -- ~ 'JI-.... .. 231:J1Qo. j ....... : . ,';/' .- = N . ~ f : ! .. '" i I ; 3 1 f 1 ~, ! . - ;r , ~ ~ : ~ ! ! ~ " ~ => , , f ~ ~ ,. - ~ i . ~ f , . 0: 2. ~ I ! 3 ~ " .~ if ] . ~ 3 . . . f . 5' ! . ; !I. I ~ i-- iH itif 1~a- "~ if ~l ! ."i, l~! , ~~ H 3' i- n Ii ;l it .. jl ~~ j-= "3: I- ~3: ~ll~ it:!.o j"'! 3: ""1 .. > >n I "8 ~ g~ i!. ''''2 :: .:-... ! - J J ~ ,- f ~ t * * II * f 1- "T1 C) ~ * * * . .. . i-.'Il 1:1" - :II 'I. . vi oi tI l'l ~ ~ t :J~ II :: III III -;l~ ~: a ~o~~~~ i ~~~ ~8 n ~~~ n [i!'" 1) ~ Gill -j t'):II 0" 0 :z ~~a 1'1'l~ 0" iiI ~ r; f [J ~ Clr.l .~I Il ~ ~~ i oj !'" ~ ~~l ~~ ;:D~ H III -: ~~I ~i; ... o. C ,. .l it ~~ ~ .... ~ cl ~ I i~ 1) ~ l i II ... !~~ii H B I .,j e ~ r.o"~ Q' ~ lj .. a .oj I "ilIo~ -( -- ...~"'z , ~ 0 I I I \Jl Cl , ~ :~ - ". II .. I ' .. , ~U8! .. .. 'l'Cl I , Il i ~ Ii ~ ! ~ I ! I Il' ~ I ~ .. - Cl ~ '" ~ g ~ ~ '" II ~ ~ 0 0 ..0 0 ~ L!.. II <.e. I ~ ~ '" " Ul i ~ 5 ~ ~ .. ~, i _I .. '/I .. I I 0 , "l t.. /I II lA -. - ~ I~) , . ~U II ~i FIR~,.. ~.!, lY.1\li ~i - ~ n~i ~ n!r ilit i { i ~ f # I' ; ,'i ' " . , , BRUCE A, JANASIK. Plaintiff, · IN THE COURT OF COMMON PLEAS · CUMBERI.ANll COUNTY, PENNS\' L VANIA . VI. · No, 96-2149 CIVIl. TERM . LORI JANASIK, Defendant. · CIVIL ACHON l.AW · IN DIVORCE PRETRIAL STATEMENT OF I'I.AINTIH BRUCE A. JANASIK I. Li~tofMarilal A~scl~: See Plaintiffs Inventory and Appraisement attached. 2. ExpcrtWitncsses: None. 3. Other W itncsses: None () 4. Exhibil5-o f Plaintiff: . .. " A. EDS Stock . B. First Capital Stock C. EDS Pension D. Vanguard Fund 40lk E. Toys-R-Us F. Keystone Financial Loan G. Fleet Credit Card H. Household Credit Loan I. Wachovia Credit Card J. MBNA Credit Card K. EDS Federal Credit Union Loan L. Tax Returns from 1996 through 2000 S. Plainlitr~ Income: See Plainti ffs Income ,lnd Expense Statement and pay stub attached. '.. , 6. Plaintiff's E,xpcnscs: See Plaintiffs incomc and cxpcnsc statcmcnt attachcd. 7. Valuation of PlaintifCs pcnsion: Husband's EDS Pcnsion Statcmcnt attachcd, 8. Counsel fees: Plaintiff proposcs that both partics bc rcsponsible for his/hcr own counsel fees. 9. Personal Property: It is belicved that the parties should be ablc to divide thc personal propcrty without Court intervcntion. 10. Marital Debts as of the purties ,date of sepamtion: Scc No. 11 below. 11. Proposed Resolution of Economic lssu~s: ASSF.TS .:STIMAH:J) TO TO VAl.UE IIUSBANJ) WIFE Vehic1c~ 94 Ford Escort Wash 0 0 92 Chevy Corsica Stock:i, Bonds, Securities EnS Stock (H) H'l'l H'l'l First Capilal Slock (H) 457 457 Pen:lion EDS Pen~ion (H) 13.563 13,563 Vanguard Fund (II) 7.604 7.604 IRA. Relirement Plans Toys R lis (W) 1.2.17 , ,237 Household Properly IOO'~,;) 50n~1 50% TOTAl. ,\SSF.'fS 2.1,760 22.523 1,237 lIAHILlTIES ESTIMATED TO TO V,\I.V.: IIUSIMNU WIFE Olher loans Keystone Financial (J'f) 4.114 4.114 Household Credil (JTI .1.27.1 .1.27.3 Credi~Cards Wachovia (JT) 6,.15X 6,.158 Fleel (Jr) 4,461 4.461 MBNA (J'f) 3.116 .1.116 Pension/Ins Loans EDS FCU (H) 2.1.12 2.1.12 TOTAl. UAHIl.ITIES $23,454 $23,454 NET MARITAL F:STATE: $.106 PERCENTAGE D1STRI8UTIO'l TO II or W 30% 30.% . Credits 10 Husband: $9,000 paid on marilal debts lJy Husband between 1996 and I <J'l'I. Alimony: Husband has paid spousal support since the parties separated in 1996. The were married in 1984. Wife will graduate in May 2003. Husband proposes continuing as alimony the monthly suppart of$450 until Wife graduates,terminable ifshe dies, eohabitates or remarries. R~L.r submitted: a-~)~_ Edward j. Weintraub, Esquire 2650 North Third Slreet lIarrisburg. P A 17 I 10 (717) 23M-220n (D#17441 ATTORNEY FOR Pl.AINTIFF - ASSEISOE fARTlES Bruce A. Janosik, Plainlifl\Defendant, marks on the list below those items applicable tu the case at bar and itemizes the assets on the following pages. If an item has been appraised, II cupy of the appraisnl report is auached. ( ) I. (,/) ., .. (,/) 3. ( ) *. ( ) 5. ( ) 6. ( ) 7. ( ) 8. ( ) 9. ( ) 10. ( ) II. ( ) 12. ( ) 13. ( ) 14. ( ) IS. ( ) 16. ( ) 17. (,/) 18. (,/) 19. ( ) 20. ( ) 21. ( ) 22. ( ) 23. (,/) 24. ( ) 25. ( ) 26. Real property Motor vehicles Stocks, bonds, securities and options Certificates of deposit Checking accounts, cash Savings accounts, money market and savings certificates Contents of safe deposit box Trusts Life insurance policies (indicate face value, cash surrender value and current beneficiaries) Annuities Gins Inheritances Patents, copyrights, inventions, royalties Personal property outside the home Businesses (list all owners, including percentage of ownership and oflicer/director positions held by a party with company) Employmenlltennination benefits - severance pay, worker's compensation claim/award Profit sharing plans Pension plans (indicate employee contribution and date plan vests) Retirement plans, Individual Retirement Accounts Disability payments Litigation claims (matured and unmatured) MilitaryN.A. benefits Educational benefits Debts due, including loans, mortgages held Household furnishings and personalty (includes as a total categay and allach itemized list if distribution of such assets is in dispute) Olher '~,I LIABILLllES..Qff'ARllES Plaintiff, Bruce A. Janasik, marks on Ihe list below those items applicable to the case at bar and itemizes the liabilities on the lollowing pages. SECURED ( ) I. Mortgages ( ) 2. Judgments ( ) 3. Liens ( ) 4. Other secured liabilities UNSECURED (wi) 5. Credit card balances ( ) 6. Purchases (wi) 7. Loan payments ( ) 8. Notes payable ( ) 9. Other unsecured liabilities CONIlliQENIJ:>RDEE.ERRED () 10. () II. () 12. () 13. () 14. () 15. Contracts or agreements Promissory notes Lawsuits Oplions Taxes Other contingent or deferred liabilities '. ........ I . ~ ~ ... '" 0 lii I 1 < '5. ~ II >> 70l !ij > ~ -S I ~ j .,. ~ '" .. 8 ~ "- ~ ...... ::! ~ ~ ~ '" '" iA g ~ :'Sl > ~ I ] ~ 8 ~ ll. g ..tl .5 ><c... u j :~ ~ l '08' :l: < ~ a a~'" 0 ], ~!j.~ ~ ~ "- .. ..J ~ ~ , ..2 :i - I QIi ~ < - .. ... '" 0 1 l~ ~ 0 ~ ~ " .... ~rj .- I I ~ ~ , la ii ~~ ~ - ~ l ~~ ] ... -::~ t <Il i ]... ffi J ... :s "- 0 ] J j ~ "" u ~ <C [ ! ~ ~ '" ~ ~ ~ '" ~ 1 .... "-l i.lJ ...; j ~i ...; .., ,~ , . ~ t J I i j ~ jJj .8 s 1 :Ii u ,~ ... ~ :. 5 ~ i jU ~ ~ '-l A. .5 i " ~ ~.j A. ~ , -i 'S , , . ~ 8" :1 - a III <( j i.~ :E , l: " 0 .2 l: I " jJ ... ~ ~ ': .S I h il .~ 'i1 ] l::: j A- i dJ i Ii i e :!: i=! 00 :<; '"' 1"' '" '" e ;au - I"l "'I. "f. a 3 ;:r; .., '"' ~. ..; '" '" '" i(/ ~q OJ Q.!!! is .'" ~ ,"" ] " oS o~~ " ~:.:l ~ !~d ~ " oS ... 0 i(/ f~ = Sl .. & . ~ ;., ~~ ~ = co i: :; - i$ ..J ;; .. ~ 0 .... " :l = .... 0 ij -;:; ~ 7.j~ 8- '" oS ~~ .8 .. 0 .. ~~ " .-:; .u ... 0 '" h .,g ~ .. :!l ~ ::: .", = I .;; i it ~ ... u ~ :ll .13 ~ j '" ~ ~ ~ j 'll '" :.! ..!j a:l 0 :.: = ~ "- :; uJ ..; ..; ..; ..; ..; - , , " In 'he COUI'\ of ConullolI Picas of . CIJI\I.!lErH.MW CoulIly, I'elllisylvania IlO\lt:snc RHATlO\S I'.ll. IIll.' Jlll. CARI.ISI.E. J'A. I rOil Phont: (11'7) 140.612$ Fas: (111) 240.6148 Plaintiff Name: Defcndalll Name: Docket Number: PACSES Case NIJmbcr: Olher Stale ID Number: prca.~t UlIlf.'1 AU cnrre\poIlLl(,DC" U1UH InC'lud~ Iht: PACSES CA&.~l: .\'uwh('r. Income and Expense SlalemeD! THIS rOR~1 MU~T HE f'lLI.ED OUT (It' you art s~lf.eOlployed or it' you are saJ.1ried Ill' a husiness ot' \\hkh you are owner in whole or parc. )'OU muse also fiJl DUIll1e Suppkmemallocollle Srarelllenl which appears lnl rh~ lasl page of Ihis if,,;ome and expense slalemCIII.) INCOME STATEMENT OF I:l r ,,'; e .J.,^ VJ,( , I verify lhalehe Slaren/elllS nude in Ihis Incollle and Expellse Srarelllene are lrue and correce. I undersland Ihar false Slalemenrs heroin are subjecllO the nilllinal pelullics of 18 PJ. C.S. ~ 4904. relating 10 unswom falsificaeion 10 aurhoriries. l. / If'! u ( Dale I r.\'CO~fE: -c tJ 1,/ Employer - /_ 4...~. /~ 1 Plaimiff ~r, t;1cfendam !J Address 5' L l 7 -.r Of Type of Work r. J/",..Jl,._ I j" . j' /It:' (' I -i ' ~ f Gross Pay per Pai' Period S ) /71,; , F. //1 j It.! A~~I.""'(,JL.~ j /',</ PayroJl No, Pay Period (wkly.. hi.wkl)'.. eec.) D1-,vttt:Jy lIemized Pa)'roll Deducrillns: Federal Withholding Olher Deducrinn.s (spedfy) rv\lL\'~"" oL - s /9'i Local Wage Tax $32 , S S3vings BOlld~ $ S ~kalih Insural";e 557 S 5 s 4. S iJ &c' Sod,l Securil)' S f,l Relir~lllelll Slale Income Tax Credil Union S Uk IlIsurall"e Nel P.y per P3)' Perind S J,Qr 7 co bd0(d:.l1/ r/ Service Type FOllIIIN.OO8 Worker to ,:...A 111":111111: allll E-rl:lI,'il: Sral~Il1t:11C PACSES Ca,,~ NUl1lh~r OTIIER (Fill ill Appruprial~ Colul1IlI) I....COME \\EEK MONTlI YEAR IlIlr:rr:~c S S S Diyiuolllh PtllSitll1 AllJluilY SueiaIS<euril)' Rellls R~yalri~s -- ExpelLle A",uunc Gifts UnemploYl1lenr Compensalioll , Workmen's Compensaliun IRS Refund Other Olher TOTAL S S S TOTAL l"'COME S -J (Fill ill Appropriale Colullln) "~ II' " ~' /. 1,' il , .. EXPENSES WEEK MO:-.iTtI \'EAR Home Morrg.g~/R~lIt Mai""el1.lnc~ I,f(.. s s s i;i " Utililies . I Elemic I ',' , ill , ~\ ~. " f.:) ~l Gas Oil " " ii. . Tekplr"M LI() __-1____.__ Sel'\'k~ Typo PaRo 2 of 6 Form IN .008 Work~rlO In~lIl1l~ ~lId Exp.n,. SI"I.IlI.11l PACSES C"s~ NUIlIII.r - (Fill In Appruprl"l. ColullIn) EXPENSES (Lonllnued) WEE" MONTII YEAR W"I~r S S S - S.wa - Ernploymelll Pulll ic TranSI'''r1''li,," S S $ Lunch ..., '0 ,") Ta._es Real Est"t. S $ $ PersOlul Pr"pert)' .3 i't) fnCllme 1..;.1/5 7 '-I .7'-t.. Insurance Homeowners S $ $ Automobile ,~.S life Accident Health II 'i OIlier AUlomoblle Paymellls $ S ~.J?1 S ruel '-{O Repai rs ;;z, oS ,~ Medical D"cwr $ S ~ Deneisl - Or/hod""I;" ~ V Servie. Typ< P"g. J "r 6 F"rlll 1:-1 008 IV"r,., ID "U,:IIIl1~ am' ExrC:lIsc: Slilh:lIIC:1I1 P,\CSES Ca,~ NUlllh~r (Fill in Appruprial~ ClllulIIlI) EXPENSES (conllnned) \\' I, E" MONTtI nAil Ho"piral M..Jicill~ .i ,-' Sp~dalll~eds (sla"~,. hr31,."~S:. llrllulrc:Lfil.' So d~, k~s) Educallon - Pri,ale SChlllll S S S Parochial SChllOI College Religious Penonal Clolhi ng S $ S .sSe Food , ~ ). (),.:.; -' - Barber lHai rdress~r c'a~ Credi! Paymenrs: Credil Card - Charge Accoum ..)~/O:.) Memherships Loall3 - Credil Uniun S S S MIscellaneou5 Household H~lp $ S S Child C3r~ Papersl Bll. ,ksl:'-I agazi lie ElIlmainmelll I 00 r---- LfS Pay TV - V;u.:ui(lII 501'\1" Typo r;.s~ .a of 6 Fllrm IN .008 Worker 10 1111':111111: illll.J E,"j1C:lbl,' 5r,I((IIII:1I1 PACSES Cas~ J';ulIIl,., E.'<PE.'iSES (COlli Inned) (Fill ill Arrrllprial~ ClIlulIIn) MONTlI \EM{ WEEK (i,I'I.\ ~~T L<gal F<~s Charilahk CI','lIrihulillns I c-' U Oll'~r ChilLI SUppllrl AI;'IIIIIl)' PaYlll~'lIs )0 j'7 Y~'CI Olher s S s TOTAL EXPENSES J{i//7'i S 5'~eQ Ownership' II IV J '\ \; X S s "ROPERTY OWNED DESCRlI'TION VALUE Ch~ckins Ac<:oums Savings Ac<:oulICs C' Ii. I. J'~.~,..' t ...J{ $ So .z..S ,'"' "".I"/CfJ ... Credil Uluon ~ /1-( Slocks/Bonds Real ESlal~ Olh~r TOTAL s --- 1,'iSL'RA:';CE Co'erage' COMPANY l'Ol.l(;Y # ~!e.11J!1 /',_".. "., If W C Hospi,al Blu. e",ss Olh~1 M.dical Blue ShklJ II I " , Ollll:r "'Jr'!' t..f'~ P I, V (A . H . f;ushanJ W. Wile C . Cnmnined J . }oifll .s ! L N'I?l'J' -i.' 1 ~ n ).( ./.j S-{ ,'1 S.rvi,~ T)pe Pag~ 5 ,,16 Fllr'" J~.008 W\lrk~r ID " x Name. JANASIK,BA Serial HI 6A2336 Social Sacurity H. 382-7f-4358 <lROSS IIlARNIN<lS ~._--------_._--------------------------._-_._-----._----------..-..-..-..-------- Net Payment. $1,185.82 tor Period Ending. 06/30/2001 CUrrent Ytlsr to Dmte 06/30/2001 RE<lULAR SALARV TOTAL GROSS EARNINGS (*) .......................> .............. --........... --...- -..............- $3,176.25 $3,176.25 $38.456.25 TAXES Bxmpt Alloc Add'l Prior .................. .....-.............. ....-................--.. rlCA-MBD $0.00 $45.32 $548.63 rlCA-OASDI $0.00 $193.76 $2,345.85 FRO INC TX S DO $0.00 $679.64 $8,248.90 PA STATE S 00 $0.00 $87.34 $\,057.60 CAIlP SO o S 00 $0.00 $0.00 $10.00 HAMPDIIlN S 00 80.00 $31.82 $356.29 PA UNEMPL S 00 $0.00 $0.00 $0.00 TOTAL TAXBS ....................> $0.00 $1,037.88 $12,567.27 DEDUCTIONS TDSP401(k) (') (4.00t) HEALTH CARE PREMIUM (') SUPPORT ORDER TOTAL DEDUCTIONS ...............> $0.00 $0.00 $0.00 $0.00 $127.05 $57.00 $768.50 $952.55 $1,309.65 $684.00 $9,222.00 $11,215.65 NiT EARNINGS ..................................> $1,185.82 TOTAL NET PAYMENT (transml tted vi.. EFTS. ) ----------........-----....-----...-..--------......------....-------..-..------..----------.. $1,185.82 OTHER W-2 GROSS EARNINGS 06/30/200\ GLI IMPUTED EARNINGS TOTAL OTHER W-2 GROSS EARNINGS (*) .........~..> $5.90 $5.90 $64.05 TOTAL W-2 GROSS EARNINGS ......................> $2,998.10 $36,526.65 .ee Of Estimate rs 09/02/1QQ8 . ,. . Based On The information You !lave [lro,iided, Name SSN Date at Birth Date Of EDS Employmen~ Date Of Expecr.~d Retirement Ma rt ta 1 Statu... Spouse Date of llirth FICA Average Bruce J,:musik 3B2-74-41'iil 11/26/1959 11/04/1;85 12/01/2024 Married 08/26/1963 $ 48,042.24 At The Tim~ Of Your Expected Retirement On 12/01/2024 Age At Retirement will Elf- 65 8Dtimated EDS And Applicable GM YearR Of Service 11 Monthly Estimated Final Average Earnings Maximum Offset .--. ------- $ 4.00) . 52 Retirement Benefits Are Estimated To Be AD Fnllows: Single Life Annuity Present Value Of Single Life Annuity 50\ Joint And Survivor Annuity 75t Joint And Survivor Annuity loot Joint And Survivor Annuity 5 Year Certain And Life Annuity 10 Year Certain And Life Annuity $ 521.12 $ $ $ $ $ 455.46 4<l8.36 404 91 509.17 480.01 . --.a I . . Annuli lly ....--.......... $ 48,042.24 $ 3.435.0.1 $ 6.253.44 $ 13,526.57 $ 5,465.52 $ 5,140.32 $ 4,858.92 $ 6.110.0~ $ 5,760.12 The Benet ~t9 Stated Are Only Estimates And Are Provided !"or Information Purposes Only. All Benefits rayable From The EDS Retirement Plan Are Based On rinal Average Earningn, Years Of Credited Benefit Service And The M<lximum Offset Allowance As Of Your Date Of $eparation/Retir~ment From EO$, ~heBe Estimates Do Not Include Any Benefits Payable From A Prior Retiromcnt Plan. ....,. . BRUCE A. JANASIK, * IN TilE COURT OF COMMON PLEAS Pllllnllrr. * CUMBERLAND COUNTY. PENNSYLVANIA * VI. * No. 96.2149 CIVIL TERM * LORI JANASIK. * CIVIL ACTION LAW Defendant. * IN DIVORCE PRETRIAL STATEMENT OF PLAINTIFF BRUCE A. JANASIK 1. List of Marital Assets: See Plaintiffs Inventory and Appraisement attached. 2. Expert Witnesses: None. 3. Oilier Witnesses: None 4. Exhibit:; of Plaintiff: A. EOS Stock B. First Capital Stock C. EOS Pcnsion O. Vanguard Fund 40lk E. Toys-R-Us F. Keystonc Financial Loan G. Flcct Crcdit Card H. Houschold Crcdit Loan I. Wachovia Credit Card J. MBNA Credit Card K. EDS FCdcral Crcdit Union Loan L. Tax Rcturns from 1996 through 2000 S. Plaintiffs Income: See Plaintiffs Incomc and Expense Statement and pay stub allached; 6. Plaintiff's Expenses: See Plaintifrs income and expense statement attached. 7. Valulltion of Plaintiffs pension: Husband's EDS Pension Statement attached. 8. Counsel fees: Plaintiff proposes that both parties be responsible for his/her own counsel fees. 9. Personal Property: It is believcd that the parties should be able to divide the personal property without Courl intervention. 10. Marital Debts as of the parties date of separation: See No. 11 below. 11. Proposed Resolution oi Economic Issues; ASSETS ESTIMATED TO TO VALUE HUSBAND WIFE Vehicles 94 Ford Escort Wash 0 0 92 Chevy Corsica Stocks, Bonds. Securities EDS Slock (1I) 899 899 , Firsl Capi~11 Slock (II) 457 457 I I ~ Pension I EDS Pension (tl) 13,563 1.1.563 Vangua"t Fund (II) 7.604 7.604 IRA. Reliremcnl Plans ToysRlls(W) 1.237 1.237 lIousehold Properly IOO'~';1 50'~';1 SO% TOT A L ASSE...S 23.760 22.523 1.237 , , UABIUTIt:S ESTIMATED TO TO V AU!E IIUSDAND WWE Other l.uuns Key'lune I'lI1ane",1 UT) 4.114 4.114 lIuu,dlOl<ll're"n (JT) 3.27.\ 3.273 Cre<litCar<l, Wachuvia (H) 6.358 6.358 Fleet (H) 4,461 4,461 MIINA UT) 3.116 3.116 Pensiun/lns Loans EllS FCU (II) 2.1.12 2.132 TOT AI. UABII,rr..:S $23,454 $2.1A54 NET MARITAl. ESTATE: $306 PERCF.Nl'A<a: IlISTRlHlITlON TO II or W SO% SOo/._ Cre<lit< to Hushan": $9,000 pai" un marital debls by Husband between 1996 an<l1999. Alimony: Husband has paid spousal support since the parties separated in 1996. The were married in 1984. Wife will graduate in May 2003. Husband proposes continuing as alimony the monthly support 01'$450 until Wife graduates, terminable ifshe dies, cohabitates or remarries. R~ submitted: C-;.---~ ce-~0- Edward J. Weintraub, Esquire 2650 North Third Street ~"\rrisburg. P A 17110 (717) 238-2200 ID#1744\ ATTORNEY fOR PLAINTIFF --.-'. .. ASSETS OF PARTIES Bruce A. Janasik, PlaintiffiDefendant, marks on the list below those items applicable tu the case at bar and itemizes the assets on the following pages. If an item has been appraised, a CUPy oflhe appraisal report i~ attached. ( ) I. (.I) 2. (.I) 3. ( ) 4. ( ) 5. ( ) 6. ( ) 7. ( ) 8. ( ) 9. ( ) 10. ( ) II. ( ) 12. ( ) 13. ( ) 14. ( ) 15. ( ) 16. ( ) 17. (.I) 18. (.I) 19. ( ) 20. ( ) 21. ( ) 22. ( ) 23. (.I) 24. ( ) 25. ( ) 26. Real property Motor vehicles Stocks, bonds, securities and optiuns Certificates of deposit Checking accounts, cash Savings accounts, money market and savings eertiticates Contents of safe deposit box Trusts Life insurance policies (indicate face value, cash surrender value and current beneficiaries) Annuitics Gins Inheritances Patents, copyrights, inventions, royalties Personal property outside the home Businesses (list all owners, including percentage of ownership and officer/director positions hcld by a party with company) Ell1ployment/t~mlination benefits - sevcrance pay, worker's compensation claim/award Profit sharing plans Pension plans (indicate employee contribution and date plan vests) Retirement plans. Individual Retiremenl Accounts Disability payments Litigation claims (matured and unmatured) MilitaryiV.A. benefits Educational benefits Debts due, including loans, mortgages held Household furnishings and personalty (includes as a total o:ategIlIy and allilch itemized list if distribution of such assets is in dispute) Othcr . , , dJ 1i ~ f~ .., ~ ~ - ... N - ~ - '" ~ -:. "'L ,." ~ -. - ~ t;l ~ "" t;l ci ~ ,~ - iJ m~] ~ " .a ~ .... 0 :4 n i >. <II ; ~ i: oS - 'ij -l - 5 JJ III < ~ - -l I ] jj 5 ~ 'il .... 0 ~ II 'Q '" '. :2 :; ~ ] '3 ] 1 i Q., ~ i I j i ~ s :c : ! ...; ...; - - ...; ...; , FILE COpy DRUCE A. JANASIK * IN nlE COURT OF COMI\ION PLEAS Plalntlrr * CUMBERLANU COUNTY, PA * VI. * No. 96-2149 CIVIl. TERM * LORI JANASIK * CIVil, ACTION -I.AW Odllndant * IN DIVORCE INCOME ANU EXPENSE STATEMENT OF PLAINTIFF, BRUn: A. JANASIK AND NOW, lhis~ day of ,lud ,2001, Plaintiff, Bruce A. Janasik, by and through his attorney, Edward J. Weintraub, Esquire, files the within Income and Expense Statement. Resjlectfull ysU5milled: ./ '. t;" ,-1//ll ) ---- L ,l ~ '--" E ward J. Weintraub, Esquire 2650 North Third Street Harrisburg, PA 17110 (717) 238-2200 JD #17441 ATTORNEY FOR PLAINTIFF .Inthe COllrt of COIllJllon Picas of . CIJ.I\.lDERLAND County, Pe'lIlsylvania 1l0\ff:STIl: Kn,nIO~S 1'.lI.nllX JlO.l:AKl.ISI.E. I'A. 170lJ Phone: (117) 240.62l~ Fa~: (717) 240.6248 Plaillliff Name: DefendalH Name: Docket Number: PACSES Case Number: Other Stare 10 Number: pr(,lL~t DUll.': All rorrC'\poudl'uct' 11I11" Includl.' che PACSES CiI.'C! ~lIwhc:r. Income and Expense Statement THIS FORM MUH iJE r;IL!.ED OUT (It you are self-employed nr it ynu are salaried by a husiness ot "hidl you are o\Vner in whole ~r pari. )'OU mUSI also fill oUllhe Suppkmelllallncol1le Sralemelll "hkh appears olllhe lasl page of lhis illeome alld expense slalemenl.) INCOME STATEMENT OF 13 y I,./C c..'J L"C/J,( I verify Ihallhe SlalemelllS made inlhis IlIeome anu Expense Slalemelll are lrue and correel. I undersland lhar false stalemelllS herein are subjecllO lhe <liminal pel13lries of 18 Pa. C.S. ~ 4904. relaling In unswom (alsificalion 10 aUlhorilies. 11 II . , l- / { ,y / 0 I / /J '" -t. /.. Dale I Plaillliff ori efendanl l:IICOME: -r Employer ~ tJ ~ Addrm ~ 1 t 7 Type of Work ! I F. //1 -f Payroll No. f: .fJ" ..,'JI",.... f JA'(:1f: i f Gross Pay per Pay Period $3 17l.v , Pay Period (wkly.. hi-wkly.. ecc.)!3t "J(.I/..tl~ A:, 1",.. '('J L,-~ J /rJ /',4 Irentized Payroll DeduclilllLl: Federal Withholdillg $lJ &'U Sodal SecurilY $/9'1 Local Wage Tax $32- Slale Income Tax $ En Redr.melll $ Savings BOllds $ Credic Union $ Lit'r: InsuriJlll,.'!t $ ~kalrh Insurallce $57 Olher D.duclion.s (specify) rv\H\I~l\.1 (,. $ 45 s Nel Pay per Pay Periou $ _~B 7, CO bl- ~\Jult.l". /! Service Type Form IN.OOS Work(r ID , . "'~"llIe ~lIU E'rellse Sl31tllltlll PACSES Case NUllIhtr OTIIER (Fill ill Arrru(lrialt COIUIllII) I:-.'COME WEEK MONTH YEAR flU~rf:s. $ S S Diviuellu, Pf:llSillll AIUIUilY Sodal Se~uril)' Rt'US Royahies - -- -- '- Expellse Ac~"ul1l GiflS Unemplllymem COmpel15arioll Workmen's Compensaliun IRS Refund Olher Ocher TOTAL S S S TOTAL L'iCOME S .. III~Olll~ ~IId E'p.II'~ 51,11.111.11. PACSES Ca,~ NUIII~.r EXPENSES (Fill ill Appruprial. COIUIIIII) (conllnued) wn:" MONTtI YEAR Wal.r S S S - S.w.r Employmtlll . -- Pu~lic Tr'"spOrlalioll S S S lUllch 3D Tues R.al Esw. S $ S Personal Prop.ny 3 {It;> In~om~ 1.1)75 7 Lf N:.- - Il150rance Homeowners S $ S AUIOOIobil. S.s life Accid.1II II 'I -- Healrh Olher AOlomoblle Paymellls S $ ~J(1 S Foel '-10 Repairs d-.SiJ Medical - Doctor S S S I j ~ - DemisI It} ~ OrchodllllliSl ~ 0 . Servk. TIP. Pag. J of 6 FlIrllll:'l-008 Work.r 10 l"<lIl1le an" Expe"se Slal~n'elll PACSES Case NUllIher EXPENSES (Fill ill Apprupriale CUIUlIlIl) (conlfnlle") \lEEK MONTI I "EAlI Hospilal -- Medicine 3'--' Sped.l "eeds (glass.s. hral.:c:i. tlrllltlpt:uk Sc) ".skes) Edllcalfon Prisale Schuul S S S Parochial Schuul - College - Religious Personal Clolhing S $ $ .350 Food ~LL ...~ ;.2.. 0<-) Barber/Hairdresser tal Credit PaymelllS: Credit Ca,d Charge ACCOUlll <-)1..)0 M~mherships LoalU - Credil Uniun S $ S .- Mlscellaneoll5 Household 'klp S $ $ Child Care Papers/BullkslMagali lie Encc:rrainnlt.'11t I 00 Pay TV L(5 Vac.:atioll Service Type Page 4 of 6 Form IN.OO8 Wnrker 10 I"~olllc ."d E"pc",c S"","I'''1 EXPE:-iSES (concl,,"cll) Gilh LcgJI FCel Ch.rit.hk Co"crihuli""s Othcr Chilli Support Alilll""y Paymc,"s Ocher TOTAL EXPENSES $ PROPERTY OWNED ChcckinB Acmums Savings ACCOUlHS Crellil Union Slocks/Bonds Real ESla'c Ocher TOTAL INSURA:-;n: Hasp;,al Blue C"'" Olhcr Medic.1 Blue Shicld Orhcr . H . Hushand W . Wik Servicc T) pc WEEK s DESCRIPTION A lL I.- l... v~'''.io.~ ",' ~ -....I{ C),t., ,~.l'/C,J "iOI COMPANY ~!c:.JfI" I i~r..I-" ,r6' I '..J ft, f' I, (A C . Cllmhined J . Joinl Pa,q, ~ "f 6 $ $ PACSES Cas, I'lllllh<< (Fill ill Appwprialo C"lullln) MONTI I o J" 7 '-nO J 'f I.") Y VALUE $ So ..t.s $ l'OLley /I ,s fJ. JsfVfjt. 0 I 1 fL N ~/.J s-t t' I n:,\R "1 c.'(,-~G iii ~ $ S ~~bC) O\\'nenhfp · II W J ~ '< Co'erale · H W C x Form IN.OO8 WlIrkr,ID . H....' o1ANASIK.BA Seriel .. &A2336 Soci.l Security" 382-74-4358 OROSS IlAR/lIHOS ..------------...-------.-..--------------------------------------------------- Het p.yment. $1.185.82 for Period Inding, 06/30/2001 CUrrent Year to Date 0&/30/2001 RIOULAR SALARY TOTAL GROBS EARNINGS (.) ......................> -.--------..-- -------------- $3.176.25 $3.176.25 $38.456.25 TAXIS Bxmpt Alloc Add'l Prior ........ --........ --..---..-...... ..--..-.................. PICA-MID $0.00 $45.32 $548.n PlCA-OASDI $0.00 $193.76 $2. J4!;. 85 PID IHC TX S 00 $0.00 $6" ,64 $8,248 . 90 PA STATI S 00 $0.00 $87. J4 $1.057. &0 CAMP SO 0 S 00 $0.00 $0.00 $10.00 HAMPDIH S 00 $0.00 $31. 82 $35&.29 PA UNIMPL S 00 $0.00 $0.00 $0.00 TOTAL TAXIS ....................> $0.00 $1.037.88 $12,567.27 DIDUCTIOHS TDSP 401lkl (", (4.00') HIALTH CAlli PREMIUM (.) SUPPORT ORDER TOTAL DEDUCTIONS ...............> $0.00 $0.00 $0.00 $0.00 $127.05 $57.00 $7&8.50 $952.55 $1,309.&5 $684.00 $9,222.00 $11.215.&5 NIT IARNINGS ..................................> $1.185.82 TOTAL NET PAYMENT (tran.mitted vi. IFrS. ) ----------------------------..--..------..--------------..-------------..---------- $1,185.82 OTHIR W-2 OROSS EARNINOS 06/30/2001 OLI IMPUTED EARNINOS TOTAL OTHER W-2 GROSS 8ARNINGS (.) ............> $5.90 $5.90 $64 . 05 TOTAL W-2 GROSS IARNINGS ......................> $2,998.10 $3&.5~&.&5 .ce ot BBtimac~ fa 09/02/1998 , .. , Based On The lnformat ion You !lave fJr<"lIl1'd,id: . .. . Name SSN nate or Birth Date Of EDS Employment Date Of Expected Retirement Marital Statua Spouse Date Of Hirth FICA Average Bruce J':ll1uaik 382-74-41'i8 1l/26/1959 J.:I./04/1985 12/01/2024 Married 06/26/1963 $ 48.042.24 At The rime Of 'lour Expected Ret 1 remont On 12/01/2024 Age At Retiremont will np Estimated EDS And Applicable GM YearA Of Sarvice 65 11 Monthly Annually Eetimated f'inal Average Eaminys Maximum Offaet . - .. . - . - - ..- $ 4.00J.~2 $ 48,042.24 $ 3,435.0.1 Retirement BenefitR Are Eslimated To Be As ~ollows. Single Life Annuity Present Value Of Single Life Annuity $ 521. 12 $ 6,253.44 $ 13.526.57 $ 5,465.52 $ 5,140.32 $ 4,859.92 $ 6,110.04 $ 5,760.12 0;0\ Joint And Survivor Annuity 75\ Joint And Survivor Annuity :1.00\ Joint And Survivor Annuity S Year Certain And Life Annuity 10 Year Certain AmI Life Annuity $ $ $ $ $ 455.46 428.36 404.91 509.17 480.01 the Benetlts Stated Are Only Estimates And Are Provided For Information Purpoaes Only. All Benefice I'ayable From'I'he EDS Retirement Plan Are Based On Final Average EarningA, Years Of Credited Benefit Service And The Maximum Offset Allowance As OE Your Date OE Separation/Retirement From EDS. These Estimates Do Not Include Any Benefits ~ayah1e From A Prior Retiroment Plan. 1.,Al}.)',i, Lf\\\! lH.llU.,S JAMES D. H.llIVER )OIlN E. SLlKE IlOH~ln C SAIDIS GEOfHlEY S. SIIUFF JAM~S D. ROWEll, JR. CAROL). LINDSAY JOHNI-;A). KOPECKY KARL M. I.ED~BOIIM )OSEPII \.. HITCHINGS TllmIASE. fLOIV~R SAlOIS, SHUFF, FLOWER & LINDSAY A I'I{lll'FSSlll:"AJ. CllHl'lll{'\ III lN 2l> \VEST IIIGII STlm'.l CAIU.lSI.E, I'ENNSYJ.\'Ai'>I,\ 170D TELEPIIONE: (717) 24~-b222 -"'\CSI\III.E: (717) 24~-""llb E~I/\Il.: dUllrnl.'\"{~'~~f1-I.\w.,:um , \-~wW,Sl>>tl-l.tw",:om W~ST SHORE OFFICE: 2109 \It\llKET STREET CA\lI' HILL. PA 17011 TELEPHONE: (717)737.30/05 FACSIMILE: (717)737.>107 REPLY TO CARl.ISl.E November 16,2001 E. Robert Elicker, II, Esquire Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 RE: JANASIK v. JANASIK NO. 96.2149 CIVIL Dear Mr. Elicker: Mr. Weintraub and I believe that the case is essentially settled, and we request a general continuance of the Pre-Trial Conference scheduled for November 16, 2001. Thank you for your assistance. Very truly yours, SAlOIS, SHUFF, FLOWER & LINDSAY . - I /1 /' ) C..{l/l( f~~ Carol J. nds y CJUljb cc: EdWard J. Weintraub, Esqulra Lori Janaslk -' \ I " VI, * IN Tin: eOlIR'1' m' ('OI\lI\lON PU:AS * CUMRt:RI.ANI) ('OlINH'."A * * No, 96.1149 ('IVII. n:RI\I BRUCr. A, JANASIK "Ialntlrr * LORI JANASIK Derendont * ('IVII. ACTION. LAW * IN mVORO: CER'I'IFICATF. m'st:RVln: I. Wcndy L. Shive, Lcgul Assistuntto hlwunl J. Weintrauh, Esquire, hcrcby certifY that on April II, 2002, I servcd u truc und correct copy of the certitiell Muritul Sclllclllcnl Agrcement and Decrce in Divorce on ('urol J. !.ilHlsuy. Esquire, counscl till' the llelcllIlunl, by depositing same, postugc prc-puid. in the United Stulcs Muil, lIurrisburM. I'cnnsylvlllliu. addressed us follows: Curol J. Lillllsuy, ESlluirc 26 West High Street Curlisle,l'A 17013 Date: 1/1/ d L .~. , I, . .:, (' /.liLf.f...L..i.L.~.._ / on ',,, 'Wcndy l../Shive , /"~> l.,f S l1';' 0 '" ." "" i:W" -0 t. ~u ;..0 lol' ;~C "" '!) .\ r::;i. '-;"J ;:,:, l,;C' -.. ~..--: ( .. r::" '.'1 ;.t, C. , '.. , :;! :)1 ,. 'J1 ~~ ". BRUCE A. JANASIK , : IN THE COURT OF COMMON PLEAS OF : CUMBERLKAND COUNTY, PENNSYLVANIA : CIVIL ACTION. DIVORCE : NO. 96.2149 CIVIL TERM Plaintiff YS. LORI JANASIK, Defendant : IN DIVORCE QUALIFIED DOMESTIC BE.LATLONSOBDfB THIS order creates and recognizes the oxistoncll of on allernato payee's right to receive a portion of the participant's benefits payahlll llndur nn employer-sponsored defined benefit plan, which is qualifiod under Section 4011lf tho Intornal Revenue Code (the "Code"). This order is intended to constitute a Qllaliflod Domostlc Relations Order ("QDRO") under Section 414(p) of the Code Soctlon 200(d) of the Employee Retirement Income Security Act of 1974 ("ERISA") find shall be Interpreted and administered in conformity with such law. This order is entered pursuant to the i1uthority granted under the applicable domestic relations laws of the State of Pennsylvania. 1. PLAN This order applies to the EDS Defined Contribution Plan indicated below (the "Plan"). Any successor to tt-is Plan shall also be sub/ectto the terms of this order. EDS 401(k) Plan 2. PARTICIPANT eamlngsllosses from the liquidation date to the date the benefit is paid. The alternate payee will have the opportunity to roll over this distribution Into an IRA or another qualified plan. 7. COMMENCEMENT The alternate payee shall receive payment as soon as administratively reasonable following the determination that this order Is a Qualified Domestic Relations Order. 8. DEATH PROCEDURES If the participant predeceases the alternate payee prior to payment of the alternate payee's assigned benefits under the Plan, the alternate payee's benefits will not be affected. In the event of the participant's death, the account balance which remains the property of the participant, will be payable to the participant's designated beneficiary or in accordance with Plan provisions. This order does not require the participant to name the alternate payee as the beneficiary for the benefits not assigned to the alternate payee. In case of the death of the alternate payee prior to distribution of the alternate payee's benefits from the Plan, the c:ssigned benefits will be paid to the alternate payee's designated beneficiary or, if none, in accordance with Plan provisions. ._,-.,,~... 4 9. RETENTION OF JURISDICTION This matter arises from an action for divorce or legal separation in the court under the case number set forth at the beginning of this order. Accordingly, this court has Jurisdiction to issue this order. In the event the Plan Administrator determines that this order is not a Qualified Domestic Relations Order, both parties shall cooperate with the Plan Administrator in making any changes needed for it to become qualified. This includes signing all necessary documents. For this purpose, this court expressly reserves jurlsd!ction over the dissolution proceeding involving the participal')t, the alternate payee, and the participant's interest in the Plan. 10. LIMITATIONS Pursuant to Section 414(p)(3) of the Code and except as provided by Section 414(p)(4), this order: (i) Does not require the Plan to provide any type or form of benefit, or any option, not otherwise provided under the Plan; (ii) Does not require the plan to provide increased benefits; and (ill) Does not require the payment of benefits to an alternate payee that are required to be paid to another alternate payee under another order previously determined to be a Qualified Domestic Relations Order. 5 ._A \ } l. I tl' ~ ~" II ,\. '11'1 , _; I .. f" rl )'.~' ;;'I.r. CF ], " i'I' '. ':\fjy 02 Wr: ? j PIi 4: /2 CUI'lr" . "'''1'( ,.\..J,L,'."l 1,,'.,}I.,'l't f'r:N~~SYLVN::A P- ~ !l1 ;,!II e . d3r11 t1; , '.1') " ""~. N ",11 :C:J ~6 ' ' :y ,'':' ; k.' .,1, . ~;.') , - rll ;POl'" ; .J .. ,<,I ~ ',.) ,~ :.q -< - t ','" . Payments must be made by check or money order. All checks and money orders must be made payable to Lori A. Janasik or her fonner name Lori Arnold should she elect to resume it and so notify Domestic Relations and PASCES. Other Conditions: All payments received by Plaintiff shall be reported by her as income and deductible by Defendant for tax purposes. Defendant shall pay the following fees: w_Iotal Fllc Description $3.00 for Judicial Computer Fee $25.00 for Court Costs l'aymcntFlcqucncy Payable at $5.00 per one time Payable at $25.00 per one time. IMPORTANT LEGAL NOTICE Parties must within seven days infonn the Domestic Relations Section and the other parties, in writing, of any material change in circumstances relevant to the level of support or the administration of the support order, including, but not limited to, loss or change of income or employment and change of personal address or change of address of any child receiving support. A party who willfully fails to report a material ,'hallge ill circumstallces may be adjudged il/ COlllempt of COllrt, alld may be filled or imprisolled. Pennsylvania law provided that all support orders shall be reviewed at least once every three (3) years if such review is requested by one of the parties. If you wish 10 request a review and adjustment of your order, you must do the lollowing: call your allorney. An unrepresented person who wants to modify (adjust) a support order should contactlhe domestic relations section. ~ " 0 (..' ~ ~Tl " '" 8 1,'1. ...... ',1) -t .... ~ .... lS ~ ',' 1<1 ,.