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IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
.~
STATE OF
BEVERl.Y A. WANNYN,
Pia lnt if f
VERSUS
RICKY L. WANNYN,
Defendant
PENNA,
\
No. 96-2771 CIVIL TERM
CIVIL ACTION - LAW
IN DI VORCE
DECREE IN
DIVORCE
A h~ ()l(~~.
AND NOW,
2001 IT ,S ORDERED AND
. -...---'
.
DECREED THAT
AND
BEVERLY A. WANNYN
_____, PI_AINTIFF,
RICKY L. WANNYN
__' DEFENDANT,
"'RE DIVORCED FROM THE BONDS OF MATRIMONY,
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
NONE
--.--___-'1-
r. J,
PROTHONOTARY
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3,
Further, the pl1rties agree to continue living separately and apm from the other at any
place or places that he or she may selectllS they have heretofore been doing. Neither pwty shall
mol.est, harass, IIMOY, injure, threaten or interfere with the other pwty in any matter whatsoever.
Each pwty may CWTY on and engage in any employment, profession, business or other activity as
he or she may deem advisable for his or her sole use and benefit. Neither pwty shall interfere
with the uses, ownership, enjoyment or disposition of allY property now owned wId not specified
herein or property hereafter acquired by the other,
4,
The consideration for this contract and agreement is the mutual benefit to be obtained by
both of the parties hereto and the covenants and agreements of each of the parties to the other,
The adequacy of the consideration for all agreements herein contained is stipulated, confessed,
and admitted by the parties, arid the parties intend to be legally bound hereby,
Each party to the Agreement acknowledges and declares that he or she, respectively:
a, is represented by counsel of his or her own choosing;
b, is fully and completely infonned of the facts relating to
the subject matter of this Agreement and of the rights
and liabilities of the parties;
c. enters into this Agreement voluntarily after receiving the
advice of counsel;
, d, has given careful and malUie thought to the making of this
Agreement;
e, has carefully read each provision of this Agreement; and
f, fully and completely understands each provision of this
Agreement, both as to the subject matter and legal effect.
This Agreement shall become effective immediately as of the date of execution,
2
<
5,
It is the purpose and intent of this Agreement to settle forever and ~ompletely the interest
and obligations of the pmies in all property that they own sepnrately, and all property that would
qualify as marital property under the Pennsylvania Divor~e Code, Title 23, Section 401(e), and
that is referred to in this Agreement as "Marital Property", as betwecn themselves, thei.r heirs and
assigns, The pmies have attempted to divide their Marital Property in a manner that conforms to
a just and fair standard, with due regnrd to the rights of each Party, The division of existing
Marital Property is not intended by the parties to ~onstitute in any way a sale or exchange of
assets, and the division is being effected without the introduction of outside funds or other
property not ~onstituting a part of the marital estate,
It is the further purpose of this Agreement to settle forever and completely any obligation
under the Pennsylvania Divor~e Code relating to spousal support or alimony,
6.
Ea~h party represents and warrants that he or she has made a full and fair disclosure to the
other of all of his or her property interests of any nature, including any mortgage, pledge, lien,
chnrge, security interest, encumbrance, or restriction to which any property is subje~l. Each party
further represents that he or she has made a full and fair disclosure of all debts and obligatiolls of
any nature for which he or she is currently liable or may become liable. Each further represents
and warrants that he or she has not made any gifts or transfers for inadequate consideration of
Marital ProlJerty without the prior consent of the other,
Each Party acknowledges that, to the extent desired, he or she has had access to all joint
and separate State and Fcderal Tax Returns tiled by or on behalf of either or both Parties during
marriage,
3
.
.
7.
REAL t:!TATE: The parties own real estate located at 550 Meals Road, South
Middleton Township, Gardners, Cumberland County, Pennsylvania 17324, Immediately upon
execution of this Agreement, WIFE shall be entitled to exclusive possession of the marital
residence and HUSBAND shall not be pennitted to enter the residence without the express
permission of WIFE, HUSBAND shall provide WIFE with any and all keys to the residence in
her possession or control, including the garage door opener, within fourteen (14) days of the
execution of this Agreement. WIFE agrees to refinance the mortgage with M & T Bank into her
c,wn name. WIFE will pay HUSBAND the sum of Sixteen Thousand and no/I 00 ($16,000,00)
Dollars for his interest in said real estate,
8,
DEBTS: HUSBAND will be solely responsible for his own debts. WIFE will be solely
responsible for her debts, WIFE agrees to pay to the Bankruptcy Trustee of HUSBAND'S
bankruptcy the sum of Two Thousand Five Hundred and no/IOO ($2,500.00) Dollars,
9.
SPOUSAL SUPPORT: It is the mutual desire of the parties that HUSBAND will not be
required to pay spousal support or alimony pendente lite to the WIFE for herself. WIFE will not
provide any financial spousal support or alimony pendente lite to the HUSBAND, The parties
also waive any right they have to recei ve alimony payments from the other following the entry of
the Divorce Decree in this matter.
10,
PERSONAL J.>ROPf;~TX: The parties agree that the personal property shall be divided,
as follows:
HUSBAND shall receive the following items:
a, The personal property in his possession.
4
,
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11.
.\J.!IQM9BI..,t:~:
a. HUSBAND agrees to waive any and all interest which he may
have in the automobiles in possession of the WIFE,
b, WIFE agrees to waive any and all interest which she may have
in the automobiles in possession of the HUSBAND,
They each waive any claim which they have in any automobile owned by the other party.
12.
INSURANCE AND EMfLOYEE BENEFlTS: The parties agree that any life
insurance policies on the life of HUSBAND or WIFE or any other employee benefits, including
but not limited to retirement, profit sharing or medical benefits of either party, shall be their own,
WIFE waives all right, title and claim to HUSBAND'S employee benefits, and HUSBAND
waives all right, title, and claim to any of WIFE'S employee benefits,
13.
BENEfiTS AND BANJ< ACCOUNTS: WIFE agrees to waive all right, title and
interest which she may have in the savings or checking or any other bank accounts of the
HUSBAND. The HUSBAND agrees to waive all interest which he has in the bank accounts of
the WIFE,
14,
DIVORCE: The parties both agree to cooperate with each other in obtaining a final
divorce of the marriage, It is agreed that the parties will execute and file the consents necessary
to obtain the divorce on or before FI:...wy 16, 2001. Any party who fails to cooperate with
obtaining the Divorce shall pay all the costs and legal fees of the party who is seeking the
divorce,
6
IS,
BEACH: If either party breaches any provisions of this Agreement. the other plirt'j
should 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 available to him or her, and the party breaching this contract will be
responsible for payment of legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
16.
ADDITIONAL. INSTRUMENTS: Each of the parties shall from time to time, at the
request of the other, execute, acknowledge and deliver to the other party any and all further
instruments that may be reasonably required to give full force and effect to the provisions of this
Agreement.
17,
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, and that it is being entered into
voluntarily, and that it is not the result of any duress or undue influence, The provisions of this
Agreement are fully understood by both parties and each party acknowledges that the Agreement
is fair and equitable, that it is being entered into voluntarily, and that it is not the result of any
duress or undue influence.
18.
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.
7
, .
19,
APPLICA"LE LAW: This Agreement shall be construed under the laws of the
Commonwealth of Pennsylvania,
20,
flUOR Ar.Rt:EMENTS: It is understood and agreed that Wly Wld all property
sculement agreements which mayor have been executed prior to the date Wld time of this
Agreement are null Wld void and of no etfect.
21.
PAYMENT OF COSTS AND LEGAL FEES: The parties agree to pay for their own
costs and legal fees required to obtain and complete the divorce,
22,
WAIVER 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
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, courtesy, statutory allowance, widow's
allowWlce, right to take in intestacy, right to take against the Will of the other, and right to act as
administrator or executor of the other's estate, and 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 Wld claims.
8
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LAW OFFICES
IRWIN McKNIGHT & HUGHES
.OGEU, Wf/N
MA/lCUS A, M,IINIOIrr. 1/1
JAMES D, HUOHES
/fEIICC.1t HUOHES
MAM D, SCHWAIt77
DOl10US 0, MILLE.
WEST POMFRET PROFESSION"'L BUILDING
60 WEST POIo/FRE.,. STRE~"T
C,l,RLISLE, PENNSYLV"'NI'" '7013'3222
(717) 249-2353
FAA (717) 24/1-11354
E.W.IL: IMHUoWOSUPERNET.COM
/1.<ItOWS I.WIN I/91S.1911)
HAItOLDS IItWIN,IR, ms.-I WId)
IRWIN, IRWIN . IRWIN mS"'Wld)
IRWIN, IRWIN. M,KN/OIIT m...m,)
IRWIN, M,KNIOHT .WOHE3 /19'1<, )
February 6, 200 I
E, Robert Elicker, III, Divorce Master
9 North Hanover Street
Carlisle, PA 17013
Re: Wannyn v. Wannyn
96.2771
Dear Bob:
I have enclosed two (2) copies of the Marriage Settlement Agreement executed by'the
parties, Please vacate your appointment in order for the divorce to be completed,
Thank you for your excellent c\loperlltion,
Very truly yours,
MAM/mln
Enc\.
cc: Robert L. O'Brien, Esq,
Ms. Beverly AM WaMyn
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OFFICI OF DIVORCE MASTER
CUMBU1lANO COIINIV
COURT OF COMMON PI [AS
9 North HJnovcr Slrcnl
Carhslt!, PA 1701:1
(717) 2406535
I. Rob.rt IlIeker, II
Divorce Ma.ler
Treel .10 Colw.r
Office Manager/Reponer
w..t Shore
697.0371 Exl 6535
October 11, 2000
MQrcus A, McKnight, III, Esquire
IRWIN, McKNIGHT & HUGHES
60 West Pomfret Street
CQrlisle, PA 17013
Robert L. O'Brien, Esquire
O'BRIEN, BARIC & SCHERER
17 West High Street
CQrlisle, PA 17013
RE: Beverly A. WQnnyn vs. Ricky L, WQnnyn
No, 96 - 2771 Civil
In Divorce
DeQr Mr. McKnight Qnd Mr, O'Brien:
After receiving Q telephone CQII from Mr, O'Brien following receipt of
my letter of October 4,2000, I did Q further review of the file Qnd 10cQted
the .subsequent petition under Rule 1920.15(b)" filed by Qttorney Eshelman
on behQlf of the husband on December 10, 1998. In thQt petition Mr,
EshelmQn rQised Q clQim for equitQble distribution,
Consequently, even though I hQve not hQd contQct from Mr. McKnight
regQrding discovery. I Qm going to proceed with Q directive for the filing of
pretriQI stQtements,
In Qccordance with P,R,C.P, 1920.33(b) I am directing each counsel to
file Q pretriQI statement on or before Friday, November 3, 2000. Upon
receipt of the pretrial statements. I will immediately schedule a pre-hearing
V,
RICKY l. WANNYN
Defendant
CIVIL ACTION - LAW
NO, 96.2771
IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
Defendant moves the court to appoint a master with respect to the following claims:
() Divorce (X ) DI:5tributlon of Property
() Annulment () Support
() Alimony () Counsel Fees
() Alimony Pendente Lite () Costs and Expenses
and In support of the motion states:
(1) Discovery Is complete as to the claims(s) for which the appointment of a master
Is requested,
(2) 'The Defendant has appeared In the action by his allorney, Robert L. O'Brien,
Esquire,
(3)
two years ,
(4)
The statutory ground(s) for divorce are irretrievable breakdown/separation for
None.
Delete the Inapplicable paragraph(s):
(a) The action is not contested,
(b) An agreement has been reached with respect to the following claims:
of property,
(5) The action does not involve complex issLles of law or facl.
(6) The hearing Is expected to take,four hours,
(7) Additional Information, If any relevant to the motion: Plaintiff represented by
Irwin, McKnight and Hughes,
~,'
DATE: 7/20/2000 <. l2Di3~~~
Robert l. O'Brien, Esquire
(c) The action is contested with respect to the following claims: Distribution
ORDER APPOINTING MASTEB
AND NOW, this ~ day of(),l[Lv , 2000_, E, Robert Elicker, Esquire is appointed
master with respect to the following ~istribution of prooertv
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Atlol'D'Y 8' L8W
2108 Marko. S're<l
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BEVERLY A. WANNYN, I
Plaintiff/Respondent I
I
vs. I
I
RICKY L. WANNYN, :
Defendant/Petitioner I
IN THE COURT Of COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2771 CIVIL 1996
CIVIL ACTION - AT LAW
CUSTODY
ORDER
You, BEVERLY A. WANNYN, Respondent in the above-captioned
custody action, have been sued in court to obtain custody of the
following children: Amanda May Wannyn, Jeremy Lee Wannyn, and
Johnny Ranier Wannyn.
You are ordered to
('l',~
fO',rx ll",.M. for
~ a Conciliation or Mediation Conference.
a Pre-Trial Conference.
a Hearing before the Court.
If you fail to appear as provided by this Order,
custody may be entered against you, or the Court
warrant for your arrest.
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.
appear in person at
on the :? ~I ~ day
"go;) ') I~' I " ';,} ,
of "J"" M'.>L}- l'H",
at
an Order for
may issue a
OFFICE OF THE COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
ONE COURTHOUSE SQUARE
CARLISLE, PENNSYLVANIA 17013
(717) 240-6200
AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of ConunOI1 Pleas of Dauphin Clluntr is required by law to
,comply with the Americans with Disabilit es Act of 1990. For
information about accessible facilities and reasonable
acconunodations available to disabled individuals having business
before the court, please contact our office. All arrangements must
be made at least 72 hours prior to any hearing or business before
' the court. You must attend the scheduled conference or hearing.
FOR THE COURT I "}/l~ 1~,I((l , ,/ f ;",,~ I t '-'I DATE I I~ :J') ''f~
CUSTODY CONCILIATOR ,/
BEVERLY A. WANNYN,
Plaintiff/Respondent
I IN THE COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
I
VS.
No.
2771 CIVIL 1996
RICKY L. WANNYN,
Defendant/Petitioner
CIVIL ACTION - LAW
IN DIVORCE
Jm:nCB TO DBFBND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you must take prompt
action. You are warned that if you fail to do so, the case may
proceed without you, and a decree of divorce or annulment may be
entered against you by the court. A judgment may also be entered
against you for any other claim or relief requested in these papers
by the Plaintiff. You may lose money or property or other rights
important to you, inclllding custody or visitation of your children.
When the ground for the divorce is indignities or
irretrievable breakdown of the marriage, you may request marriage
counseling. A list of marriage counselors is available in the
Office of the Prothonotary at the Cumberland County Courthouse,
Carlisle, Pennsylvania.
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 TAKB THIS PAPBR TO YOUR LAWYBR AT ONCB. IF YOU DO
NOT HAVE A LAWYBR OR CANNOT AFFORD ONB, GO TO OR TELEPHONB TBB
OFFICB SBT FORTH BBLOW TO FIND OUT WHBRE YOU CAN GBT LBGAL HBLP.
COURT ADMINISTRATOR
CUMBBRLAND COUNTY COURTHOUSB
1 COURTHOUSB SQUARE
CARLISLE, PA 17013
(717) 240-6200
AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law
to comply with the Americans with Disabilities Act of 1990. For
informat~on about accessible facilities and reasonable
accommodations available to disabled individuals having busines8
before the court, please contact our office. All arrangements must
be made at least 72 hours prior to any hearing or bU8iness before
the court. You must attend the scheduled conference or hoaring. ,
BEVERL Y A. WANNYN, I IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respond~nt I CUMBERLAND COUNTY, PENNSYLVANIA
I
vs. I No. 2771 CIVIL 1996
I RICKY L. WANNYN, CIVIL ACTION - AT LAW
i Defendant/Petitioner CUSTODY
SUBSEOUENT PETITION UNDBR RULE 1920.15f~
AND NOW, the Petitioner, RICKY L. WANNYN, Defendant in the
I original action, through his attorneys, The Law Offices of Patrick
,I F. Lauer, Jr., makes the following Subsequent Petition Under Rule
1920.15(b) and in support thereof, avers the following:
1. The Petitioner, Ricky L. Wannyn, is an adult individual
, who currently resides at 75 Bonnybrook Road, Lot 12, Carlisle,
Cumberland County, Pennsylvania 17013.
I
I
2.
The Respondent, BEVERLY A. WANNYN, is an adult individual
whose current mailing address is 550 Meals Road, Gardners,
, Cumberland County, Pennsylvania 17324.
,
!
3. The Petitioner and the Respondent have been residents of
the Commonwealth of Pennsylvania for at least six months
immediately prior to the filing of the Complaint.
4. The Petitioner and the Respondent were married on
March 31, 1979 in Dillsburg, Pennsylvania.
5. The marriage is ir.retrievably broken.
6. The parties have been living separate and apart
continuously since July 29, 1993.
17. The Petitioner has not participated as a party or
witness, or in another capacity, in other litigation concerning the
custody of the children in this or another court.
18. The Petitioner has no information of a custody proceeding
concerning the children pending in a court of this Commonwealth.
19. The Petitioner does not know of a person not a party to
the proceedings who has physical custody of the children or claims
to have custody or visitation rights with respect to the children.
20. The best interest and permanent welfare of the children
, will be served by granting the relief requested because I
,
I,
I
Ii
I
I,
a). The Plaintiff can provide the children with a
home with adequate moral, emotional, and physical
surroundings as required to meet the children's needs;
b). The Plaintiff is willing to continue custody of
the children;
I
c). The Plaintiff continues to exercise parental
duties and enjoys the love and affection of the children.
'! WHEREFORE, the Plaintiff respectfully requeste that this
Honorable Court enter an Order granting cu~tody of the children to
the Petitioner and natural Father, RICKY L. WANNYN, in accordance
, with any Stipulation of the parties, or in the event the parties
are unable to execute such a Stipulation, to enter an Order
granting custody, partial custody, or visitation of the childron
the Petitioner.
'.
BBVERLY A. WANNYN, I IN THE COURT OF COMMON PLEAS OF
Plaintiff/Re8pondent I CUMBERLAND COUNTY, PENNSYLVANIA
I
V8. I No. 2771 CIVIL 1996
I
RICKY L. WANNYN, I CIVIL ACTION - LAW
Defendant/Petitioner I IN DIVORCE
CERTIFICATB OF SBRVI~
I hereby certify that I am this day serving a copy of the
I
'i foregoing Subsequent PeU tion upon the person, and in the manner,
I indicated below, which service satisfies the requirements of the !
Pennsylvania Rules of Civil Procedure, by depositing a copy of the
same with the United States Post Office at Camp Hill, Pennsylvania,
through first class mail, prepaid and addressed as follows I
Datel
IZ t lG
,
Rebecca R. Hughes, Esquire
60 West Pomfret Street
Carlisle, PA l7013
Attorney for Plaint{:ff/Respondent
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Matthew J. Eshelman, Esquire
2108 Marko Street, A,ztec Building
Camp Hill, Pennsylvania 17011
ID* 46430 Telephone (7l7) 763-1800
I
.
INRE
RICKY LEE W ANNYN
UNITED STATES BANKRUPTCY COURT 1\ ,'\\1r~iil~An'y
MIDDLE DISTRICT OF PENNSYLVANIA 11'~\0 ,,.' Jhl1\1;,~. ,.~t
Debtor(s)
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CASE NO.: 1-99-00932
LEON P. HALLER. TRUSTEE
ADVERSARY NO.: 1.00-00270A
Plalntiff(s)
vs.
CHAP
FILED .,.H3rrl;curll, PA
r",,~__A.M..P,M,
~ I 4 i!lIIII
Clerk, U,S, E"r,kruptcy Court
Oepu CI.rI<
BEVERLY W ANNYN
Defendant(s)
SUMMONS
To the above-named defendant:
You are hereby sununoned AND REQUIRED TO SERVE upon plaintiff's attorney, whose name
. and address is LEON p, HALLER ESQ., 1719 NORTH FRONT STREET, HARRISBURG, PA. 17102-2392,
A MOTION OR AN ANSWER. to the complaint which is herewith served upon you, ON OR BEFORE
OCTOBER 16, 2000 AND TO FILE THE MOTION OR ANSWER WITH THIS COURT, IF YOU FAIL TO
DO SO, JUDGMENT BY DEFAULT MAY BE TAKEN AGAINST YOU for the relief demanded in the
complaint. . , ,
YOU ARE HEREBY NOTIFIED THAT TRIAL of the proceeding conunenced by this complaint shall be set
upon receipt of the answer,
ARLENE BYERS
Clerk of the Bankruptcy Court
BY Susan Morrow
Case Administrator
Date of Issuance: September 14, 2000
.u'you make a mOllon as you may', In accor::lance wlln uanKruptcy KUle 1012, that rule governs that time within
whIch your answer must be serveil.
(Instiudrona 0'; Rllvel'1")
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ATTORNEYS (Finn Nam., Addrul. IIIld T.I.phon. No,) ATTORNEYS (II Knownl ,
LEON P. HALLER, ESQU I RE
1719 NORTH FRONT STREET
HARRISBURG, PI'. 17102-2392
,~,.,\"",_A'7q - .
PARTY (Cnock one box only) G$ 1 U.S, P'-"INTlFF o 2 U.S. OEFENDANT o 3 U,S. NOT A PARTY
CAUSE OF ACTION (WRITE A BRIEF STATEMENT OF CAUSE OF ACTION,INCLUDING ALl U,S, STAT\JTES INVOLVED)
NATURE OF SUIT
(CnlCk tno one mOltlpproprilto box only,)
0 454 To RICOYII Monoy or Property o 455 To r"okl an ordll 0' contlnnlllon o 415e To obllln . deelor.lory ludgmonl
0 43& To Dellnnlno V.lldlly, Priority. or 01 I Chip. " or Chap, 13 Plan 1IIIIIng 10 any 01 loragolng causu
E.llnl 01 I Lion or Othlllnlllut In o 428 To d"onnlno In. dl.cnsrgublllly ollctlon
Properly 01 0 doblt, U,S,C, !623
:[l 415e To obllln Ippro..1 lor Ino 1110 0' 0 434 To obtlln on Injunction 0' olnll 0 4sa To dOlonnln. . claim or cau.. 01
boln Ino Intll081 01 tno 011110 and squllablo 11111' Ictlon IImoYed 10 . bankruplCY
0' I C<Hlwn.r In property 0 4S1 To lubOfdlnat. any IIlowsd clllm courl
0 424 To obj..1 or '0 rovol<. . dll.horge or Intll08' ..c.pt wh... luch
, t U.S,C, 5127 lubordlnallon II plOYldad In . plan o 498 Olnll (Ipeclfy)
ORIOIN OF III t Original 0 2 Removed o 4 R.lnlllled o 5 Tranlllrrtld
PROCElDINOS Procttdlng P,ocHdlng or Reopened 'rom Anotnll o CHECK IF THIS IS A CLAU
(C"..k on. box only,) Bankruptcy ACTION UNDER '.R.C,', 23
Courl
DEMAND I~EARESTTHOUSAND I OTHER RELIEF SOUGHT I 'JURY
o DIMAND
IANKIIUPTCY CAli IN WHICH THIS ADVlllSARY PIlOCIIDINO AIIIIIM .,
NAME 0' DEBTOR BANKRUPTCY CASE NO, 1-99-0lJ,832
RICKi' LEE WANNi'N
DISTRICT IN WHICH CASE IS PENDING I DIVISIONAL OFFICE HARRISBURG N~'2>~~d~~. WOODSIDE
MIDDLE
I IIE'-"TED ADVERSARY PROCEEDINO n' ANY)
"'-"INTIFF I DEFENDANT ADVERSARY PROCIIDINO NO,
DISTRICT IDIVISIONAL OFFICE -' NAME OF JUDGE
FILING (Cneck onl box only,) o FEE ATTACHED o FEE NOT REaulRED o 'ElISDI'IIIRIC
FEE
DATE 9/12/00 PRINT NAME SIGNATURE OF ATTORNEY (OR "'-"INTI'Fl
LEON P. HALLER
.'
1':'7'
UN:TED STA~ES BANKRUPTCY ~OURT
.OR THE MIDDLE DISTRICT OF PEtlNSYLV~~r.~
IN RE:
RICKY LEE WAN'NYN
"I
CASE NO. 1-99-0~t32
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CHAPTER 7
LEON P. HALLER, Trustee
Plaintiff
ADVERSARY !J'.. 0 {} .. 0 0 2 7 r) A
vs.
BEVERLY WANNYN
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COM P L A I N T
AND NOW comes Leon p, Haller, Trustee in the above case,
and represents as follows:
1. This is an adversary proceeding brought pursuant to
Bankruptcy Rule 7001 and Section 547(b) of the Bankruptcy Code.
2. Jurisdiction of this Court is based upon 28 U.S.C.
51334 (b) . This is a core proceeding within the meaning of 28
U.S.C. S157(n). Venue is proper pursuant to 28 U.S.C. 51409 (a).
3, Plaintiff, Leon P. Haller, is the duly acting and
qualified Trustee with an office located at 1719 North Front
Street, Harrisburg, pennsylvania 17102-2392
4. Defendant I Beverly wannyn, is an adult indivicSu.l'
residing or formerly at 550 Meals Road, Gardners, Pennsylvania
17013,
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A. Every other weekend from Saturday at 9:00 a.m.
until Sunday at 4:00 p.m. Mother shall provide the
transportetlon for the beginning of this weekend schedule, and
Fether shall provide the transportation for the end of the
weekend schedule. This alternating weekend schedule shall
begin on April 12, 1997.
B, During the school year, on Tuesday and Thursday
evenings from after school until 9:00 p,m, During the
summer months, Father shall keep the child overnight on
Tuesdays and Thursdays and deliver the child back on the
following morning.
C, During baseball season, Father shall have access to
the child on Saturdays so that he may take the child to and
from his baseball practices or games,
4, The parties shall alternate the major holidays, those holidays
being defined as Memorial Day. Fourth of July, Labor Day,
Thanksgiving, and Easter, This alternating schedule shall begin with
Father having M41morial Day in 1997, and shall alternate thereafter.
5, The Christmas hOliday will be broken into two segments.
Segment A shall be from 12:00 noon on Christmas Eve until 12:00
noon on Christmas Day, and Segment B shall be from 12:00 noon on
5. The Plaintiff's position on custody Is as follows: See attached Order.
6. The Defendant's position on custody Is as follows: See attached Order.
7. Need for separate counsel to represent chlld(ren): Neither party
requested.
8. Need for Independent psychological evaluation or counseling: None
requested and the Conciliator does not believe any Is necessary.
Date: April 24, 1997
,
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Michael L. Bangs
Custody Conciliator
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.IAN 1 4 19getP.
A. Every other weekend from Saturday at 9:00 a,m.
until Sunday at 4:00 p,m, Mother shall provide the
transportation for the beginning of this weekend schedule, and
Father shall provide the transportation for the end of the
weekend schedule, This alternating weekend schedule shall
begin on April 12, 1997,
B, During the school year, on Tuesday and Thursday
evenings from after school until 9:00 p.m. During the
summer months, Father shall keep the child overnight on
Tuesdays and Thursdays and deliver the child back on the
following morning.
C, During baseball season, Father shall have access to
the child on Saturdays so that he may take the child to and
from his baseball practices or games.
4, Thfl parties shall alternate the major holidays, those holidays
being defined as Memorial Day, Fourth of July, labor Day,
Thanksgiving, and Easter. This alternating schedule shall begin with
Father having Memorial Day in 1997, and shall alternate thereafter,
5, The Christmas holiday will be broken into two segments.
Segment A shall be from 12:00 noon on Christmas Eve until 12:00
noon on Christmas Day, and Segment B shall be from 12:00 1100n on
Christmas Day until 12:00 noon on December 26th. Father shall have
Segment A in 1997 and all odd-numbered years thereafter and
Segment B in 1998 and all even-numbered years thereafter. Mother
shall have Segment A in 1998 and all even-numbered years thereafter
and Segment Bin 1997 and all odd-numbered years thereafter.
6. Each party shall be entitled to three (3) uninterrupted weeks
of vacation to be used over the course of the year. Both parties agree
that they may exercise one period of time to include two consecutive
weeks. The parties shall provide eac.h other with thirty (30) days
advance notice as to when they intend to exercise these weeks of
vacation.
7, Mother shall have the children on Mother's Day and Father
shall have the children on Father's Day, These periods of partial
custody and visitation shall be at times to be agreed by the parties.
8. Such other times as the parties may agree.
BY THE COURT,
...L.S I -/J.'l\1 c ?
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.1.
Rebecca R. Hughes, Esquire
Matthew J. Eshelman, Esquire
TRUE COpy FROM RECORD
In T'lSf'mony 'IIh~rtof, I h~,r: unto set my hand
and rlie seal of s!id Court !r C.r1isle, Pa,
This .j...,J.t doy of-r/,l,' '9 <1'1.
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BEVERLY A. WANNYN,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
)
)
)
)
)
)
)
)
NO. 96-2771 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
RICKY L. WANNYN,
Defendant
JUDGE PREVIOUSLY ASSIGNED: None
CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8(b). the undersigned Custody Conciliator submits the
following report:
1. The pertinent information concerning the child(ren) who is(are) the
subject of this litigation is as follows:
NAME
BIRTHDATE
CURRENTLY IN
CUSTODY....QE
Amanda M. Wannyn
Jeremy L. Wannyn
Johnny R. Wannyn
November 18, 1980
July 13, 1982
Octob,er 31, 1988
Defendant
Defendant
Plaintiff
2. A Conciliation Conference was held on April 3, 1997, and the following
individuals were present: the Plaintiff and her attorney, Rebecca R. Hughes,
Esquire; the Defendant appeared with his attorney, Matthew J. Eshelman, Esquire.
3. Items resolved by agreement: See attached Order.
4, Issues yet to be resolved: See attached Order.
BEVERLY A. WANNYN,
l'Iointil1'
IN TIlE COllRT OF C(}MMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs,
)
)
)
)
)
)
)
NO. 1996-2771 CIVIL TERM
CIVIL ACTION - LAW
RICHARD L. WANNYN,
Defendant
~ ()
AND NOW, this ~ day of,
, 1998, upon receipt of the
Conciliator's Report. it appearing thlltthe parties hllvc lIgreed to the terms and provisions of this
Order which was dictated in their presence and lIpproved by them and their counsel, it is hereby
ordered and directed as lollows:
I. The Order of May 1. 1997, shall be vacated.
2. The Pllrties shall share legal custody of their minor children. Amanda
M,. d.o.b, November 18. 1980: Jeremy L.. d,o,b, July 13. 1982; and Johnny R..
d,o.b. October 31, 1988.
3, Mother has primllry physical cust(ldy of Amanda and Jeremy subject to
periods of partial custody and visitation with Father as agreed upon by the parties.
The parties Llcknowledge thlltthis custodial arrangement as itl'e1ates to these two
children is subject to the children's discretion upon consultation with the parties.
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4, Mother shall have primary physical custody of Johnny subject to
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periods of partial custody lInd visitation with Father as lollows:
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PATRICK F. LAUER, JR.
Allornty a\ Law
21r~MUlkefSlrttl
^"h~, 8uitdlng
Culllp 11111. PA 1711 II
1117) 76,1.18IX)
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.
BBVERLY A. WANNYN, I IN THB COURT OF COMMON PLEAS OF
Plaintiff/Respondent I CUMBERLAND COUNTY, PENNSYLVANIA
I
vs. I No. 2771 CIVIL 1996
I
RICHARD L. WANNYN, I CIVIL ACTION - LAW
Defendant/Petitioner I IN DIVORCE
NOTICE TO DEPEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you must take prompt
action. You are warned that if you fail to do so, the case may
proceed without you, and a decree of divorce or annulment may be
entered against you by the court. A judgment may also be entered
against you for any other claim or relief requested in these papers
by the Plaintiff. You may lose money or property or other rights
important to you, including custody or visitation of your children.
When the ground for the divorce is indignities or
irretrievable breakdown of the marriage, you may request marriage
counseling. A list of marriage counselors is available in the
Office of the Prothonotary at the Cumberland County Courthouse,
Carlisle, Pennsylvania.
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 PAPBR TO YOUR LAWYER AT ONCE. IP YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONB TBB
OPPICE SET FORTH BELOW TO PIND OUT WHERE YOU CAN GET LEGAL HBLP.
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 240-6200
AMERICANS WITH DISh!UJJTIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law
to comply with the Americans with Disabilities Act of 1990. For
information about accessible facilities and rea.onable
accommodations available to disabled individuals having bu.ine..
before the court, please contact our office. All arrangemente mu.t
be made at least 72 hours prior to any hearing or bu.ine.. before
the court. You must attend the scheduled conference or hearing.
BY THE COURT I
Datel
, ....A \
BEVBRLY A. WANNYN, I IN THE COURT OF COMMON PLBAS OF
Plaintiff/Respondent I CUMBERLAND COUNTY, PENNSYLVANIA
vs. No. 1996 - 2771 Civil Term
RICHARD L. WANNYN, CIVIL ACTION - LAW
Defendant/Petitioner IN DIVORCE
ORDER OF COURT
AND NOW, this
,)/~-':r / " /
,
, upon consideration of the
complaint filed December 20, 1996, it is hereby directed th6t the
parties and their respective counsel appear before Michael L.
Banas. Esa., the conciliator,
~, on the lrJ..
at 302 South 18th Street. Came Hill.
day of Apr:/ ,1997, at.f
~.M., for a prehearing Custody Conference.
At such
conference, an effort will be made to resolve the issues in
dispute I or if this cannot be accomplished, to define and narrow
the issues to be heard by the court, and to enter into a temporary
order. Either party may bring the child who is the subject of this
custody action to the conference, but the child/childxen's
attendance is not mandatory. Failure to appear at the conference
may provide grounds for entry of a temporary or permanent order.
FOR THE COURT:
l)y: ~ 111't1l~ ~, (t'1<5)
Custody Conciliator
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCB. IP YOU DO IIOT
BAVE A LAWYBR eR CANNOT AFFORD ONB, GO TO OR TBLEPHOIlB TBB ORICK
SIT FORTH BBLOW TO FIND OUT WBBRE YOU CAN GET LEGAL BBLP.
OFFICE OP THE COURT ADMINISTRATOR
COURTHOUSB, FOURTH FLOOR
CARLISLE, PA 17013
(717) 240-6200
BBVERLY A. WANNYN; I
Plaintiff/Respondent I
I
VB. I
I
RICHARD L. WANNYN, I
Defendant/Petitioner I
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2771 CIVIL 1996
CIVIL ACTION - AT LAW
CUSTODY
SBCOND PBTITION FOR CONCILIATI03
SUBSBOUENT PETITION UNDBR RULB 1920.l51bl
AND NOW, the Petitioner, RICHARD L. WANNYN, Defendant in the
original action, through his attorneys, The Law Offices of Patrick
F. Lauer, Jr., makes the following Subsequent Petition Under Rule
1920.15Ib) and in support thereof, avers the followingl
1. The Petitioner, Richard L. Wannyn, is an adult individual
who currently resides at 73 Bonnybrook Road, Lot 12, Carlisle,
Cumberland County, Pennsylvania 17013.
2. The Respondent, BEVERLY A. WANNYN, is an adult individual
who currently resides at 1480 Goodyear Road, Gardners, York County,
Pennsylvania 17324.
3. The Petitioner seeks cUBtody, partial cUBtody, or
viBitation of the following children I
HAm!!. ~ent ReBidence Iml
Amanda M. Wannyn 73 Bonnybrook Road Lot 12 11/18/80
Carliele, PA 17013
Jeremy L. Wannyn 73 Bonnybrook Road Lot 12 07/13/82
Carlisle, PA 17013
Johnny R. Wannyn 1480 Goodyear Road 10/31/88
GardnerB, PA 17324
4. The children, Amanda May Wannyn and Jeremy Lee Wannyn are
currently in the cUBtody of the Petitioner, RICHARD L. WANNYN.
5. The child, Johnny Ranier Wannyn, is currentl}. in the
cU8tody of the ReBpondent, BEVERLY A. WANNYN.
6. During the past five years, the children have resided
with the following persons and at the following addresses I
* through 7/29/93, Richard, Beverly, Amanda, Jeremy, and
Johnny Wannyn resided at 1480 Goodyear Road, Gardnere,
Pennsylvania 173241
* 7/29/93 - present, Richard, Amanda, and Jeremy Wannyn reside
at 75 Bonnybrook Road, Lot 12, Carlisle, Pennsylvania 170131
* 7/29/93 - present, Beverly and Johnny Wannyn reside at 1480
Goodyear Road, Gardners, Pennsylvania 17324.
7. The mother
currently residing at
, She is married.
8. The father of the children is
currently residing at 75 Bonnybrook Road,
Pennsylvania. He is married.
9. The relationship of the Petitioner to the children is
that of Father. The Petitioner currently resides with the
following persons: NONE.
10. The relationship of the Respondent to the children is
that of Mother. The Respondent currently residee with the
following persons: NONE.
11. The Petitioner has not participated as a party or
witness, or in another capacity, in other litigation concerning the
custody of the children in this or another court.
12. The Petitioner has no information of a custody proceeding
concerning tho children pending in a court of this Commonwealth.
13. The Petitioner does not know of a person \lot a party to
the proceedings who has physical custody of the children or claims
to have custody or visitation rights with respect to the children.
14. The best interest and permanent welfare of the children
will be served by granUng the relief requested because:
of the children is BEVERLY A. WANNYN,
1480 Goodyear Road, Gardners, Pennsylvania.
RICHARD
Lot 12,
L.
WANNYN,
Carlisle,
a). The Plaintiff can provide the children with a
home with adequate moral, emotional, and physical
surroundings as required to meet the children's need.,
b). The Plaintiff is willing to continue custody of
the children 1
BBVBRLY A. WANNYN, I IN THE COURT OF COMMON PLBAS OF
Plaintiff/Respondent I CUMBERLAND COUNTY, PENNSYLVANIA
I
VS. I No. 2771 CIVIL 1996
I
RICHARD L. WANNYN, I CIVIL ACTION - LAW
Defendant/Petitioner I IN DIVORCE
ATTORNEY VERIFICATION
The undersigned, Matthew J. Eshelman, Esquire, hereby verifies
and states th\tl
1. He is the attorney for the Defendant/Petitioner, Richard
L. Wannyn.
2. He is authorized to make this verification on his behalf;
3. The facts set forth in the foregoing SECOND PETITION FOR
CONCILIATION SUBSEQUENT peTITION UNDER RULE 1920.15(b) are known to
him and not necessarily to his client;
4. The facts set forth in the foregoing SECOND PETITION FOR
CONCILIATION SUBSEQUENT PETITION UNDER RULE 1920.15(b) are true and
correct to the best of his knowledge, information and belief; and
5. He is aware that false statements herein are made subject
to the penalties of 18 Pa. C.S. S 4904, relating to unsworn
falsification to authorities.
Respectfully submitted,
~~). -
--2bk
"i /. '1
Date I - I,Ct.
Matthew J. Eshelman, Esquire
Law Offices of Patrick F. Lauer, Jr.
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
lOll 72655 Tel. (717) 763-1800
I
t
f
I
I
I'
jl
I
I
BBVBRLY A. WANNYN,
Plaintiff/Respondent
I IN TH2 COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I No. 2771 CIVIL 1996
I
CIVIL ACTION - LAW
IN DIVORCE
vs.
RICHARD L. WANNYN,
Defendant/Petitioner
CERTIFICATE OF SERVICE
I hereby certify that I am this day serving a copy of the
foregoing Subsequent Petition upon the person, and in the manner,
indicated below, which service satisfies the requirements of the
Pennsylvania Rules of Civil Procedure, by depo~iting a copy of the
same with the United States Post Office at Camp Hill, Pennsylvania,
through first class mail, prepaid anu addressed as follows I
Date I
';, II.-
.1
Rebecca R. Hughes, Esquire
60 West Pomfret Street
Carlisle, PA 17013
Attorney for Plaintiff/Respondent
I~--
Matthew J. Eshelman, Esquire
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011
lOt 46430 Telephone (717) 763-1800
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KNOUSE
FOODS
Knous" Foods Cooperalive, Inc,
800 Peach Glen. Idavllle Road
Peach Glen, Pennsylvania 17375.000t
Tel: (717) 677-8181
Fax: (717) 877.7069
lWx: (910) 997.0548
IhoIIL ~
October 18, 2000
Bevcrly A, Wnnnyn
RD 2 Box 183A
GnrdncrK,l'A 17:124
To Whom It Mny Conccm:
Beverly A, Wllnnyn (SSIII S9.S11-2101) is a vcsted mcmbcr of the Knouse Foods Non-Union
Factory Empluyees I{etiremenl Plnn, Shc recently requestcd that wc providc hcr with the currcnt
value llfher pCllxiun henetit, Beverly's normal rctirement date is March 1.2026, Based on
cllrrentllccl'unh, at her nunnal retircmcnt date, Bcverly will be entitled to a $182.4 7 monthly
benctit, TIll: hellctit amuunt hilS hecn clIlculatcd undcr the tcrms of a singlc life sixty month
certuin IIl1d cuntinuuus limn ufpaymcnt. Othcr fonns of payment will be lIvailable for Beverly
10 elcctlltthc time uf her rctirement, The single life sixty month certain and continuous form of
payment will provide Bevcrly with the 11Irgest monthly benefit. If you have any additional
qUestiollx or need any additionlll inlonnlllion you are welcome to contact me.
Sincerely,
KNOUSE FOODS COOPERATIVE. INC,
/IC2. 4 /b
hn H, Eisele
enetits Administration
JHE
"
hll:ome and ExpellSC Stalemenl
PACSES Case Number 348100635
OTHER (Fill in Appropriale Column)
INCOME
WEEK MONTH YEAR
Inlerest $ $ $
Oivldeods
PeosioD
Annuity
Social Security
Renu
Royalries .
Expeose Account
Gifts
UlICIIIploywnt
COmpeDSlliOD
WOrkmeD'S
COlJJlleosadOD
-
IRS Refund
Other SUPPORT iSBO.OO
Other
TOTAL $ $580,00 $
TOTAL INCOME $ (J08 - $1.193.1]) (SUPPORT - $580,00) TOTAL $1.773.17
(Fill in ApplOptUle Column)
EXPENSES
WEEK
MONTH
YEAR
Home
Mon..aefReDt
MainleDlllCe
Ulilitles
Electric
Gas
011
Telephone
S (DOUSE ROOF)
S 72.08
S
45.00
-
37.00
75.00
60.00
thrill IIODt 8
Service Type M
PI.e 2 of6
Form IN.DOS
Worker 10 21205
In~ume and Expense SlItemcm
PACSES Cue Number 348100635
(Fill In Allpropriale Culumn)
EXPENSES
(conllnued) WEEK MONTH YEAR
-
Waler S $ $
Sewer
Emplo)'lllenl
Public Transporwlon S $ S
Luncb
TUet
Real Esllle S $ 41.30 S
Personal Propeny 17,25
Income
lnIurance
HomeoWllers S $ 15.00 $
AutolllObUe 274.64
Life
AccideDl <A nn
Healm
Other
Automobile
Payments S $236.23 + 149.04-$385.27 S
Fuel I,n nn
-
Repairs 100.00
Medical
Doclor S $ 20.00 S
Dendsl
Onhodoolisl
Service Type M
Page 3 of 6
Form IN'()()8
Worker 10 21205
Incume: and Eapcnse StateRICnt
PACSES Case Number 348100635
(Fill in Appropriare Column)
EXPENSES
(continued) WEEK MONTH YEAR
Hospital
Medicine $25.00
Special needs (1Iasses,
bmes. onhopcdic
devices)
Eduwlon
-
Prlvatc School $ $ S
. .
Paroc:blaI Scbool
Collelc
RcllsIous
Penonal
--
Clothlnl $ S 40.00 S
Food 180.00
BarberlHainlRsscr
Credit Payments:
Credit Card
Charle AccoUDt 100.00
-
Memberships
-
1.011III
Credit Union $ S S
MIsceIllUIeoUl
HOll.lebold Help S S S
Child Care
PapenlBookslMalazine -
EntenailllllCnt 2~.OO
Pay TV
~ -
Vacadon
Service Type M
Page 4 of 6
Form 1N'()()8
Worker 10 21205
111l:0l11ll and Expense StalCmcnt
EXPENSES
(conllnued)
Gifts
Le,a1 Fccs
Charitable COlllrlbudons
Omer Cblld Suppon
A1lmollY Paymcll1S
Other
TOTAL EXPENSFS
PROPERTY
OWNED
Cbecldll' AccOUll1S
Savill'S AccolllllS
Credit UniOll
Slocks/Roads
Real Esule
Omer
TOTAL
tNSURANCE
Hospilal
Blue Cross
Other
WEEK
$
$
PACSES Case Number HBl00635
(Fill in A ropriate Colunm)
MONTH
$
$
DESCIUPI'ION
M&T 1349325
M&T 3781679679
QBD 159 58 2101
QAC 198 52 2432
COMPANY
Medical SAME AS ABOVE
Blue Shield
Other
· H - Husband W - Wife C. Combined J - Joint
Pa,e 5 016
Sorvice Type M
YEAR
$
$
Ownenhlp ·
VALUE
H W J
$ 1,350.66 X
1,617.28 X
$
POLICY #
ConR.1 ·
H W C
][
X
FOnD IN-OOS
WorkerlD 21205
.
....
BEVERLY A, WANNYN,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO, 96-2771 CIVIL TERM
IN DIVORCE
DEFENDANT'S PRE.HEARING MEMORANDUM
RICKY L. WANNYN,
Defendant
1. The Defendant has recently relocated to the vicinity of Syracuse, New
York. His companion, who works for the Federal Government, transferred to a position
In that area. The Defendant is currently seeking employment in that area, and it Is
anticipated that he will find a job working in a factory setting, The Defendant has
worked as a laborer since finishing high school.
2. The Plaintiff works as a laborer also. The parties went before the
Domestic Relations office in February, 2000 and that information has been submitted,
3. Thp, parties have three children. The oldest, who is finished with her
schooling, a middle child, who is a senior in high school and a third child who Is twGlve
years of age. All three of the children have been living with the Plaintiff for the past
several years, The parties residence had been paid off at the time of the separation.
An appraisal done by Susan A. Stewart on February 5,1997, indicated the fair market
value of the property as $44,000,00, Since the Plaintiff has resided In the property
since the parties' separation, one of the claims the Defendant makes is for the rental
value of the property. The other property owned by the parties consists of some home
furnishings and retirement accounts.
4. The Trustee who administered the Defendant's bankruptcy has filed and