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HomeMy WebLinkAbout96-03408 r i 1j C5 ...jJ u -0 S H... ,J.., " . . () C) ., 1J >- (" 1.>) l;l ~ II; ~ .~ In ~:: @ lU~': to, ~ l..') tn' 0 g- O (.,.. , J r ()0 Y- r"" '. t.. ., - -. "f . "j 0: co f.'l ~ ~ 14 H - c; .J -. , -\ (L G:!c:-' :'j Ji"iJ U I:' :':'J ILL... ". In " C.. (:';' r.J M ., .. 0 Ul .. !:: ~ w ~ III < ~ .. ~ ;.<: < ~ .. " < 5 . ~ ~ ::; ...l M >< >< .. 0 tIl >-l " ~ ~ :r. :r. d It: ~ III III " ;.J ~ .. ~ .. III ~ 0 OJ' oL. -< Z ~ rJl n " 0 n 7- " .. ~ , i CLOYD A. BARRICK, JR,. ) IN TIlE COURT OF COMMON II Plaintiff ) PLEAS OF CUMBERLAND COUNTY, ) PENNSYLVANIA ) vs. ) CIVIL ACTION - LAW ) 96- 'J,4D~ ) NO. CIVIL TERM JOLENE N. BARRICK, ) Defendant ) IN DIVORCE NOTICF. TO DF.FFJlD AND CI,A 1M RIGIn'S 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 fail to do so, the case may proceed without you and a decree iu divorce or annulment may he entered against you by the court. A judgment may a)so 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 I IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOIl MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOll DO NOT HAVE A LAWYER OR I 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 ]70]3 Telephone: (717) 240-6200 :' -. ..',. I I l.11 , I" " l. I ( \ \';,' .' U. ". '"' L , I I' l ..' Ul ~ ~ I>l ~ !: ~ ~ . < .. i< z . -< !( = 16 ~ ....l a - ;.l >- >- ~ ~ III ..l '" Z Z Z I>l '" ~ 0 " ;J 0 ,; '" :<: ~ . 0 ,,' < " Z rJJ " ~ N " X " ... .' " ., , , CLOYD A. BARRICK, JR" Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, CIVIL ACTION. LAW JOLENE N. BARRICK. Defendant NO. 96-3408 CIVIL TERM IN DIVORCE I , I I , , I I 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on ! 18 June 1996 and was served upon the Defendant on or about 21 June 1996, AFFIDAVIT OF CONSENT 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant, 3. I consent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised. do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct and I understand that false statements herein are made subject to the penalties of 18 Pa. C.S, I 10 - s - '19 DATE I I , i I I I I I I ~>-) -' ".... c~01D: B~RRI&~jR'.:' ~. // , -- C'J ~ b; M -, >-, 5 :::J..: U!q (') -~ OZ ~~f:' :;: ~ ~L < (:l-:J -I. :,.~ "r)e. a:> .-(f) 8", )~ ~.' In Efl;.' l- e..> U)O- 0' 0 "> 1-.' a Ll, 0" e) O"l ~ N ~ M I- e 5s; lU~J o~ 0-., --( :r W<., 17::( ...: ':):>: Cl/'- !:.';>! (~:-' co -...U) -~% ::1: to- fi?E ct..:.! '-' ~~ I 0 " '" ::> Cl en U CLOYD A, BARRICK, JR.. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA i, vs, !j 'I ilJOLENE N. BARRICK, I: Defendant I , ,> Ii Ii " ii 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 18 Ii ~une 1996 and was served upon the Defendant on or about 21 June 1996, ,. II 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days ~,: ave elapsed from the date of filing of the complaint and the date of service of the complaint ~n the Defendant, 'i CIVIL ACTION. LAW NO, 96-3408 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 3. I consent to the entry of a final decree in divorce either after service of a Notice of ntention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention I .0 Request Entry of the Decree. I i ~he Court maintains a list of marriage counselors and that I may request the Court to require ty spouse and I to participate in counseling and. being so advised, do not request that the fourt require that my spouse and I participate in counseling prior to the divorce becoming ~inal. II I verify that the statements made in this Affidavit are true and correct and I understand I , ~hat false statements herein are made subject to the penalties of 18 Pa. C,S, Section 4904 ~elating to unsworn falsification to authorities, Ii Ii CJ I 7 ) 'I '1 ~ DATE I' I' I' 4. I have been advised of the availability of marriage counseling and understand that '~ roll"'" n, JOL E N. BARRICK .>:l '\ \ ) C\.. U...U' c.. ,- u' (:: l-~ '. - , - , .- ." L I .' , ~ , L_. " , , -,', " ,:p . I , C- , " W' .' .~ ,. <./: " en ~-) 0 d' :.:J ~T; r-. . " , , ; , , , , . , " C;'. ; '. I ; C... , .1 t.., ~ 1.\.. c,,: u ,7\ ., ( , '...;'''1 i) . VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 96-3408 CIVIL TERM IN DIVORCE CLOYD A. BARRICK, JR., Plaintiff/Respondent t JOLENE N. BARRICK, Defendant/Petitioner THIS Agreement made this ~ ~ day of Pr-~\., ,,>1' , 1999 by anti between JOLENE N. BARRICK, of R. R. 1, Box 902, Landlsburg, Perry County, Pennsylvania, hereinafter referred to as WIFE, and CLOYD A. BARRICK, JR.. of 6 Mountain View Drive, Mt. Holly Springs, Cumberland County, Pennsylvania, hereinafter referred to as HUSBAND, WITNESSETH: WHEREAS, the parties hereto are husband and wife, having been joined In marriage on August 27,1972, In Carlisle, Cumberland County, Pennsylvania; and WHEREAS, a Complaint for Divorce has been filed in the Court of Common Pleas of County, Pennsylvania, to No. 96 - 3408, Civil Term; and WHEREAS, the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as betWeen each other, Including, without limitation, the settling of all matters between them relating to the ownership of real and personal property, claims for spousal support, alimony, alimony pendente lite. counsel fees and costs, and In general, the settling of any and all claims and possible claims against the other or against their respective estates. I jollnl msa AuguIl18. 1999 NOW, THEREFORE, in consideration of these considerations, and the mutual promises and undertakings hereinafter set forth, and for other good and vaiuable consideration, receipt and sufficiency of which is hereby acknowledged hy each of the parties heroto, HUSBAND and WIFE, each Intending to be legally bound, hereby covenant and agree as follows: 1. Advice of Counsel: The parties hereto acknowledge that each has been notified of his or her right to consult with counsel of his or her choice, and have been provided a copy of this agreement with which to consuit with counsel. WIFE Is represented by Carol J. Lindsay, Esquire, and HUSBAND is represented by Samuel L. Andes, Esquire. Each party acknowledges and accepts that this agreement is, in the circumstances, fair and equitable, and that it is being entered Into freely and voluntarily, after having received such advice and with such knowledge as each has sought from counsel, and that execution of this agreement Is not the result of any duress or undue Innuence, and that It is not the resuit of any Improper or illegal agreement or agreements. 2. Divorce: The parties agree to the entry of a Decree in Divorce. The parties will execute, on the date of this agreement, Affidavits of Consent and Waivers of Notir,,: under Section 3301 (c) of the Divorce Code, consenting to the entry of a Decree in Divorce. 3. Personal Property: The parties acknowledge that they have equitably and satisfactorily divided all of their personal property, and that all personal property shall be the sole and individual property of the party in whose possession it is as of the date of this agreement. WIFE will retain the proceeds of sale of the parties' mobile home in the amount of $8,800.28, a 1993 Corsica automobile, $547.00 which has been escrowed in the Office of Samuel Andes, Esquire, from the sale of the parties' cabin, and her TIAAlCREF retirement account. WIFE will also retain the two cemetery lots of the parties'. HUSBAND will retain his Rose Metal System stock, and his Legg- Mason IRA, provided however that HUSBAND will transfer to WIFE $35,000.00 from said Legg- 2 jol'~. ms' Augusl18. 1999 Mason IRA through a Qualified Domestic Relations Order. The Order will be prepared by WIFE's CQunsel, and will call for the transfer as of the date of the Agreement with any gains or losses thereon, from that date to the date of actual transfer. HUSBAND will cooperate by providing any Information requested In order to prepare the Qualified Domestic Relations Order. 4. Alimony: The parties waive any claim that they may have one against the other for alimony, alimony pendente lite or spousal support. The parties acknowledge that each has sufficient assets with which to maintain themselves after divorce. The parties agreo that irrespective of the date of entry of the Decree in Divorce, HUSBAND's obligation for alimony pendente lite shall cease as of the date of this Agreement. Any arrearages due on the date of termination of alimony pendente lite shall be paid at the rate of $350.00 per month which shall continue to be wage attached until paid In full. 5. Marital Debt: The parties have, In their own names, certain credit card accounts which may Include soma marital debt. Each party will be responsible for the debt on the credit card accounts in his or her name. Each party will Incur no debt for which the other may be liable, and will Indemnify and hold the other harmless for any debt so Incurred. HUSBAND shall be solely responsible for the Members First account, the account with Blazer, the Sears account, the Consumer One loan, and the American General loan. WIFE will be solely responsible for the car loan taken for the purchase of the 1993 Corsica at Members First and a separate Members First loan. The parties each shall Indemnify and hold the other harmless on account of any loss as a result of the financial obligations each assumes In this paragraph. Each party will Incur no debt for which the other may be liable, and will Indemnify and hold the other harmless for any debt so incurred. 3 jolono "'.. AuguDI18, 1~99 6. Exchange of Information: The parties have requested from each other and received a{1Y information regarding t.l1eir assets, liabilities, income and expenses which the party requires prior to entering into the terms of this Agreement. The parties acknowledge that the terms of this Agreement are fair and equitable and constitute an equitable distribution of marital property and debt, taking Into account all of the ralevEmt factors set out In Section 3502 of the Divorce Code, 23 Pa. C.S.g3502 inclUding the length of the marriage; any prior marriage of the parties; the age, health, station, amounts and sources of income, vocational skills, employability, estate, liabilities and needs of each of the parties; the contribution by each party to the education, training or Increased eamlng power of the other; the opportunity of each party for future acquisitions of capital assets and Income; the sources of income of both parties, including but not limited to, medical, retirement, Insurance or other benefits; the contribution or diSSipation of each party In the acquisition, preservation, depreciation, or apprecfate of the marital property, including the contribution of a party as homemaker; the value of the property set apart to each party; the standard of living of the parties during the marriage; the economic circumstances of each party Including federal, state and local tax ramifications at the time of the division of the property, and whether the party will be serving as custodian of any dependent minor children. 7. Modification: No modification, rescission, or amendment of this agreement shall be effective unless in writing signed by each of the parties hereto. 8. Applicable Law: All acts contemplated by this agreement shall be construed and enforced under the laws of the Commonwealth of Pennsylvania. 9. Agreement Binding on Parties and Heirs: This agreement, except as otherwise expressly provided herein, shall bind the parties hereto, and their respective heirs, executors, administrators, legal representatives, assigns and successors in any Interest of the parties. 4 100Ino "~. Augusl 18, 1909 10. AgrelJment Not to be Merged: This agreement shall be incorporated Into the final dqcreB of divorce of the parties hereto for purposes of enforcement only, but otherwise shall not be merged Into said decree. The parties shall have the right to enforce this agreement under the Divorce Code of 1980, as amended, and In addition, shall retain any remedies In law or In equity under this agreement as an Independent ccntract. Such remedies In law or equity are specifically not waived or released. 11. Documents: The parties hereto agree that they will execute and deliver one to the other any documents necessary to give effect to the terms of this Agreement. 12. Full and Final Settlament: WIFE and HUSBAND each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, titles, Interests or claims In or against the property (Including income and gain from property hereafter accruing, of the other) or against the estate of such other, of whatever nature and wheresoever situate, which she or he now has or at any time hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other, or by way of dower or curtesy, or claims In the nature of dower or curtesy, or widows' or widowers' rights, family exemption or similar allowance, or under the Intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate In a deceased spouse's estate, whether arising under the laws of Pennsylvania, any other State, or any other Country, or any rights which either spouse may have, or at any time hereafter have, for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expanses, whether arising as a result of the marital relation or otherwise, except and only except, all rights and agreements and obligations of 5 vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96 - 3408 CIVIL CLOYD A. BARRICK JR., Plaintiff JOLENE N. BARRICK, Defendant IN DIVORCE RE: Pre-Hearing Conference Memorandum DATE: Friday, November 6, 1998 Present for the Plaintiff, Cloyd A. Barrick Jr., is attorney Samuel L. Andes, and present for the Defendant, Jolene N. Barrick, is attorney Carol J. Lindsay. A divorce complaint was filed on June 18, 1996, raising grounds for divorce of irretrievable breakdown of the marriage. No economic claims were raised in the complaint. On May 5, 1998, husband filed an affidavit under section 3301(d) of the Domestic Relations Code averring that the parties have been separated for a period in excess of two years. However, counsel have indicated that the parties will execute and file affidavits of consent and waivers of notice of intention to request entry of divorce decree prior to the hearing so that the divorce can be concluded under section 3301(C). On July 7, 1998, the Defendant filed a counterclaim raising the economic issues of equitable distribution and alimony. No claim for counsel fees and costs has been raised. with respect to the alimony claim, counsel for wife has indicated that she may withdraw that claim. If that is to be done, the Master directs that at least a month prior to the hearing to be scheduled that wife file a praecipe with the Prothonotary specifically withdrawing the alimony issue. The reason the Master has requested the withdrawal of the claim prior to the hearing is for the purpose of avoiding the need for either counsel to have to prepare for alimony testimony in the case. The parties were married on August 27, 1972, and separated April 15, 1996. There are three adult children of the marriage, all of whom are emancipated. Husband is 43 years of age and resides at 6 Mountain View Drive, Mt. Holly Springs, Pennsylvania, 17065 with a female friend. He is a high school graduate and works as a job superintendent in Rose Metal Systems, Inc. The support office on September 11, 1998, computed his net monthly income to be $2,587.00. There is an issue with respect to husband receiving $20,000.00 in Subchapter S Income as shown on the 1997 tax return. Husband claims that he actually does not receive any of those funds but they are reported on his return which represents profit in the company. Attorney Lindsay has questioned whether or not husband gete any payment from the company to pay the tax liability that is due on his having to report that money as income. Husband is currently under a court order to pay alimony pendente lite to wife in the amount of $350.00 per month. That order is on appeal. Husband has not raised any health issues. Wife is 47 years of age and resides at RD 1, Box 901, Landisburg, Pennsylvania 17014 with a male friend. She is a high school graduate and works as a custodian for Dickinson college. The support office computed her net monthly income to be $1,307.00. She has not raised any health issues. We believe both parties have health insurance benefits through their respective employers but if that is not correct, counsel can update this information at the hearing. The parties currently own a mobile home located at 21 Mountainview Terrace, Newville, Pennsylvania. The mobile home is listed for sale and hopefully it will be sold by the time of the hearing so we can use the sale price as a representative of the value of the home. There is a lien against the home which will be paid off out of the sale proceeds. Mr. Andes has raised a question with opposing counsel today regarding the repair or replacement of the heating system in the mobile home and counsel are going to address this before they leave today because it will be important that the heating system be in operating condition in order for the home to be sold. Husband received 15% of the stock in Rose Metal Systems, Inc., when he began his employment with the company and Mr. Andes has stated on his pre-trial statement a value of $5,000.00. Attorney Lindsay, however, is going to pursue having Mr. Barrick's interest in the company evaluated if the parties cannot agree to a value of the shares of stock. Husband has an IRA which he acquired through his prior employment which has a value in excess of $60,000.00. Counsel are going to update that value because it appears as if husband made no contributions since the date of separation so we can use the statement of the IRA to represent the date of hearing value. The parties had a savings account which the pre-trial statement noted had a value of $377.00 as of April 1996 which was held in the Member's 1st Federal Credit Union. Counsel believe that husband most likely received those funds. Wife has a retirement with TIAA-CREF and counsel are going to update the marital portion of that pension. Apparently TIAA-CREF will cooperate in assisting and providing a date of separation value and then update that value to the date of hearing based on the marital interest. The parties sold husband's interest in a hunting cabin and received proceeds in the amount of $6,805.32. Husband used a substantial portion of those proceeds to pay on account of marital debt leaving a balance in an escrow account currently in excess of around $1,200.00. There was also other marital debt which husband has paid since separation and Mr. Andes is going to provide substantiation of the debt husband paid so that husband can receive appropriate credit for assumption of marital debt which he has paid from his own funds. Mr. Andes does list an exhibit on his pre-trial statement showing the total amount of debt that husband apparently has assumed. wife is currently in possession of a 1993 Chevrolet Corsica automobile and she has valued that vehicle at $4,625.00. Both counsel have the right to have the vehicle appraised if they want to present testimony on the value; otherwise, counsel perhaps may be able to stipulate to the value at $4,625.00. Wife claims that she received a 1936 Hahn fire truck from her father as a gift in 1988. Husband has placed a value on the fire truck at $10,000.00. There is a question, however, as to whether or not we are dealing with a marital asset or the increase in value of a nonmarital asset. In any event, counsel are going to present their opinions as to value and we will then determine how we address the truck, namely, whether it is a marital or nonmarital asset. Mr. Andes has indicated that he will most likely have the truck appraised. The parties have each received certain items of household tangible personal property and counsel are going to determine if they can agree on the distribution and whether or not there should be an appraisal. If thore is an appraisal, then counsel can decide if we are going to have to use values in the equitable distribution computation for the property each of the parties received. There are cemetery lots and most likely each of the parties would like to have the other party receive the lots in CLOYD A. BARRICK, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96 - 3408 vs. CIVIL ACTION - LAW JOL~NE N. BARRICK, Defendant IN DIVORCE ORDER AND NOTICE SETTING HEARING TO: Cloyd A. [larrick, Jr. Plaintiff , Samuel L. Andes Counsel for Plaintiff , Jolene N. [larrick Defendant , Carol J. Lindsay Counsel for Defendant , You are directed to appear for a hearing to take testimony on the outstanding issues in the above captioned divcrce proceedings at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania on the 21st ___ day of January 1999, at q,OO a.m., at which place and time you will be given the opportunity to present witnesses and exhibits in support of your case. President Judge Date of Order and Notice: 11/10/98 By: Divorce Master Ir YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FOR1'H BELOW TO FIND OUT WHERE YOU CAN GET LEGAL f1ELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLl':. PA 17013 TELEPIIONI': uln 249-:1166 CLOYD A. BARRICK, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSiLVANIA NO. 96 - 3408 "s. : JOLENE N. BARRICK, Defendant CIVIL ACTION - LAW IN DIVORCE ORDER AND NOTICE SETTING HEARING TO: Cloyd A. Barrick, Jr. , Plaintiff Samuel L. Andes , Counsel for Plaintiff Jolene N. Barrick , Defendant Carol J. Lindsay , Counsel for Defendant You are directed to appear for a hearing to take testimony on the outstanding issues in the above captioned divorce proceedings at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania on the 22nd day of ,Tilly , 1999, at 9:00 a.m., at which place and time you will be given the opportunity to present witnesses and exhibits in support of your case. ~y, ~fir<. I. r9" ,. t:L Pres iden t ,Judge ,1 Date of Order and Notice: --1121/99 By: Divorce Master 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. CUMI3I':RLAND COUNTY BAH Assnc l^,l'lON 2 1.11ll-:HTY 1\ VENti E CAill.lSI.E. PA 1701 J TEI.E1'llllNE (/1"/) .',1')-;11,(, CLOYD A. BARRICK, JR., Plaintiff . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96 - 340B . . vs. CIVIL ACTION - LAW JOLENE N. BARRICK, De fendan t IN DIVORCE RESCHEDULED HEARING ORDER AND NOTICE SETTING HEARING TO: Cloyd A. Barrick, Jr. , Plaintiff Samuel L. Andes . Counsel for Plaintiff Jolene N. Barrick , Defendant Carol ,J. Lindsay , Counsel for Defendant You are directed to appear for a hearing to take testimony on the outstanding issues in the above captioned divorce proceedings at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania on the 21st day of September ,1999, at 9:00 a.m.. at which place and time you will be given the opportunity to present witnesses and exhibits in support of your case. 'f(t <go e. t~t. President Judge Uate of Order and Notice: 7/9/99 By: Divorce Master IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO eR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY DAH ASSOCIATION 2 LIBEhTY AVENUE CARLISLE, PA 17013 TEl.EPIlONE (717) 24')-316(, ~ OFFICE OF DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEAS 9 NOrlh Hanover Street Carlisle, PA 17013 (717) 240.6535 E. Robert Elicker, II Divorce Master Tr.cl Jo COlyer Office Manager/Reporter West Shore 697.0371 Exl. 6535 February 23, 1999 Samuel L, Andes, Esquire 525 North Twelfth Street P.O. Box 168 Lemoyne PA 17043 Carol J. Lindsay Attorney at Law FLOWER, MORGENTIIAL, FLOWER & L1NDSA Y II East High Street Carlisle, PA 17013 RE: Cloyd A. Barrick, Jr. vs, Jolene N. Barrick No, 96-3407 Civil Action In Divorce Dear Mr. Andes and Ms. Lindsay: I have reviewed the lelters/memorandums from counsel with enclosures and am going to set forth my impressions and findings with respect to the issue presented. That issue as defined by counsel is when we value the stock of Mr. Barrick in Rose Metal Systems, Inc. The courts use the date of separation as a benchmark date in detennining what pr'Jperty or interest in property can be characterized as marital. However,the date of valuation of the marital asset in question seems to me to be left to the discretion of the court. My first level of inquiry took me to the McNau~hton case, which was a case from Cumberland County. Although that case dealt with the valuation of real estate and the Superior Court detennined that the valuation date should be the aate of distribution since a substantial period of time passed between the date of separation and the date of distribution, some comments in that case I think are relevant to our present situation. The MeNau~hton case states that .....the lower court has it within its discretion to adopt a date for valuation whieh best works economic justice between the parties." The McNau~hton case cites for that proposition the case of Miller v. Miller 395 Pa. Super. 255, 577 A.2d 205 (1990), In looking at the Adelstein ease in relation to the Sutliff case, it appears to me that the Adelstein case refines the broad Propositions set forth in the Sutliffcase with respect to the date of valuation, Although the Adelstein case is initially dealing with what is marital property at the date of scpo ration, and in that case determined that husband's interest in the company was a one- halfinterest because he owned one of two shares at date of separation; nevcrtheless, the Court goes on to state the general Proposition in the Sutliffcase, lIolVever,the Court refin~s that broad Sutliff definition nnd directs us to look at what post separation contributions may have been made to the increase in value of the asset and states that that is a factor that c.ln be considered by the trial court in ordering distribution of marital assets between husband and wil~ in an equitable way. SAI'IlfEI. 1. ANDJo;~ A'J"TOHNEY AT LAW l\wn NORTIS TWr.I.l'"TJI HTIIRt;T P. O. BOX 11ttl LI!MOYNE, I:tENSS\.L"ANIA 170.l:l ftO,I!I'1tIlNK 11" 1111' n~lIl1 ,.. Pll' 1f1l-14:.1n 17 February 1999 E. Robert Elicker, II Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 RE: Cloyd A. Barrick, Jr. vs, Jolene N. Barrick Dear Mr. Elicker: I write In response to Carol Lindsay's letter to you of 8 February 1999, setting out her position regarding the proper date to value Mr. Barrick's Interest In Rose Metal Systems, Inc. First, I believe Ms. Lindsay misstates the facts as they were produced at the hearing before you, particularly from the testimony of Steven Rose. Mr. Rose made It clear that he would never have started Rose Metal Systems, Inc. without having Mr. Barrick "on board" with him, that the corporation would not have probably succeeded without t-Ir. Barrick's services, and would certainly not have grown but for Barrick's contributions. Rose testified that the company provided a service and that Its most Important commodity was Its reputation for producing that service in a reliable and timely fashion. Rose testified that, no matter how good a job Rose did In selling the company and Its services, Barrick's performance In getting the company's work done properly and promptly, Is what made for repeat business for the company. I believe Rose's testimony made it very clear that the corporation would not have grown, or even succeeded, had It not been for Cloyd Barrick's contributions. I believe Ms. Lindsay also misunderstands or mis-cites the significance of the Adelstein case. Adelstein was decided after the Supreme Court's decision In Sutliff v. Sutliff. 518 Pa. 378, 543 A.2d 534 (1988), and set out a clear exception to the general finding made In S..Y.tlill that assets should be valued as of the date of distribution. The Superior Court specifically stated: E. Robert Elicker, II 2 17 February 1999 In the Instant case, however, the corporation has appreciated In value since the separation and now has a value In excess of Seven Hundred Thousand ($700,000.00) Dollars. This has been accomplished In large measure because of the post-separation efforts of hU5band and his co-owner of the business. To these post-separation efforts, the wife-appellant has made no contribution. This, t'JO, may be corasldel'ed by the trial court In ordering distribution of marital assets equitably between Hartman and wife. Husl;land, who has already paid a part of his work product to the wife-appellant as support, should not be deprived totally of the fruits of his labor, (553 A.2d at 439). It Is difficult to Imagine a case which Is more precisely the same as that here. Cloyd Barrick is a part owner of a business that has grown significantly In value since the date of his separation. During the time of separation, he pa:d support to Jolene Barrick from his earnings from the corporation. Just as It would be unfair for Mr. Adelstein to have to make payment a second time from the fruits of his efforts, It would be equally unfair for Mr. Barrick. The appellate courts of Pennsyivania have reached similar conclusions In other cases Involving assets which have changed significantly In value since the date of separation. In a case which arose In Cumberland County, McNaughton vs, McNaughton 412 Pa. Super 409, 603 A.2d 646 (1992), the Superior Court, after finding the tilnl court erred in valuing the rt:al e!>tate at the date of separation, reversed so the trial court could value the real estate at the date of distribution. The Superior Court, however, specifically directed that the husband's interest In a business corporation be valued at the date of separation, not at the date of distribution, The court made It clear that the business corporation was to be treated differently than the real estate and the logic for that is very easy to see. Real estate Increases In value without any effort or contribution by Its owner. Business corporations, however, rise and fall in value :n large part because of the efforts and sacrifices of their owners. Just as a spouse Is not entitled to participate In post-separation contributions to bank accounts, pensions, and similar Investment assets, the spouse should not be entitled to share In the contributions made to a business corporation. E, Robert Elicker, II 3 17 February 1999 The Superior Cour~ reached a similar rE!sult In Benson vs. Benson, 425 Pa. Super 215,624 A.2d 644 (1993) albeit for what appear to be different reasons, In Benson, the trial court valued f>lr. Benson's business at the time of separation. On appeal, the Superior Court reversed the trial court and directed that the business be valued at the date of distribution. The trial court, after further proceedings, reinstated Its prior order, valuing the business at the date of separation, which was contrary to the direction given It by the Superior Court. On the second appeal, the Superior Court reconsidered Its earlier decision and determined that the trial court was entirely proper In valuing Mr. Benson's business at the time of separation. That decision appears to have been based upon a conclusion that the corporation decreased In value, presumably because of a lack of effort and contribution by Mr, Benson. The Superior Court concluded that It was not fair to penalize one spouse for the lack of contribution by the other, Logic would tell us that the converse Is equally true. Just as one party should not be penalized for the other party's lack of effort, they should not be rewarded for, or permitted to share in, efforts of that other spouse made after the date of separation. Read together, these three cases layout a very logical way to deal with the valuation of a business owned by a spouse going through a divorce. Where the evidence establishes that a business Increases In value because of the post-separation contributions of a spouse, or decreases In value because of the post-separation failure of the spouse to make such contributions, logic tells us the business should be valued at the date of sepGlratlon. Where the business Increases or decreases In value purely because of factors unrelated to the post-separation efforts or contributions of the spouse, the date of distribution would be appropriate, Our courts have made It clear that there Is no \\Iock-stp.p" method to determine the date of evaluation, but that every case must be considered on Its merits and facts. Sutliff Ibid. These cases make It clear that, In circumstances such as those present In the Instant case, the proper and logical date to value Cloyd Barrick's Interest In Rose Metal Systems, Inc, Is the date the parties finally separated. I believe Carol Lindsay and I have covered these points fairly well with our correspondence. I do not think further argument will be productive In helping you resolve the case. What both of us are looking for you to do Is tell us, formally or Informally, whether you will value Cloyd Barrick's IJIW OFFICI':S FLOWER, MORGENTHAL, FLOWER & LINDSAY ,\ I'IUWES:llc)N/\I. nWI'OI<t/\Tl(lN 11 r,AST 111011 Sm"I';T CARLl'3LE, PENNSYI.VANIA 17013-3016 lAMES D. I'LOWER RCKiER M. MOROENTlIAL IMWS 0 I'!.OWER, JR. CAROl. I LINDSAY {717IHl.HU FAX: (7171 H.l Mill E-IIl:l11:(;!\lrl.I.J.....rItJtlll.:tlll1 IlIETSl'Il"" MORGENTlIAI. (It"5.ll)tI~) 1'l.OWER, ~RAMER MORGENTII.\I."" FI.OWER II'J85-11)112) February 8,1999 E. Robert Elicker, II, Esquire 9 North High Street Carlisle, PA 17013 Re: Date of Valuation of Stock in a Closely Held Corporation Dear Bob: Thank you for the opportunity to respond to the issue raisArl by Mr, Barrick on the valuation date for his stock in the closely held corporation owned by him and Mr. Rose. Mr. Barrick contends that the proper valuation date is the date of separation, He cites the case of Adelstein v. Adelstein, 381 Pa.Super. 221, 553 A.2d 436 (1989), for this proposition. We, however, assert that the valuation date of marital property Is the date of distribution, as set down by the Supreme Court in Sutliff v. Sutliff, 518 Pa. 378,543 A.2d 534 (1988). This letter address Adelstein and the proper interpretation of that case as relates to the present one. Cloyd Barrick is a 15% stockholder in a contracting business run by Steven J. Rose, who owns the other 85%. Mr, Barrick supervises the work crews and oversees field operations. Mr. Rose makes business contacts, finds clients, and brings In the contracts. Both men have put in long hours over the life of the business and the value has grown substantially. Mr. Rose admits, however that the business would have been successful without Mr. Barrick and that someone else could have done his job, albeit not as well. Some of the growth is certainly due to the good economy In this region, and market forces over which neither Mr. Rose nor Mr. Barrick has control. Mr. Barrick ciaims that Jolene Barrick is not entitled to any of the Increase in value of the corporation since separation. He argues that because the stock is In a closely held corporation and Mr. Barrick was instrumental in increasing the value of the company after the separation, the valuation date for the stock should be the date of separation instead of the date of distribution, He cites the case of Adelstein v. Adelstein, 381 Pa.Super. 221, 552 A.2d 436 (1989), for this proposition, He mistakes the holding of Adelstein, however. The main issue of Adelstein with regard to stock was the date used to determine what is marital property. jQ, at 225, 438. On the date of separation, the husband, Mr. Adelstein and his co-owner in the corporation Mr. DeMuro, were equal shareholders, each 5,13 A,2d 5301 57 USLW 2011 (CIl. us: 518 I'u. 378, 543 A.2d 534) ~ (;regory L. SIITI.I...., Ap"elllllll, v. Curlell. SIITI......, AI'pl'llee. Supreme Court of Pcnnsylv:ll1ii\, Argued Jail. 20, 19M8, Decided JUlie I, 1988, Husballd liIed complaint III dlv",ce, Aner parties '1Ipulaled 10 blfurealed divorce alld I1l1al divorce decree was entereu, the COUft of Common PIC;IS, Cumberland County, Civil Divisillll, No, 33 Civil 1982, Sbeely, J.. entered judgmenl providing for equllable distribulion, Husbaod appellled and wife cross-appealed, 111e Superior COUrl. Nos. 3501 and 361 Harrisburg 1985, aflirmed in pari and remanded. 361 Pa,Super. 5Q.1, 522 A,2d 1101.1. and appeal was laken. The Supreme COUrl. No, 017 M,D, Appeal Doekel, 1987, Flaheny, J.. beld Ihal: (I) proper dale for valuing parties' marital asselS was dlstribulion dale, ralher lhan dale panic, separaled, aod (2) presumplion Ihal propeny acquired during marriage was marital properly could be rebulled by preponderance of Ihe evidence. Remanded. MeDermoll, I" tiled concurring opinion. Zappala, I.. liIed concurring and dissenting opinion In which Larsen, I., joincd. [I] IlIVORCE <!?253(3) 134k253(3) Proper dale Illr valuing panics' marital assels in making equitable di'lribution of property Iilllnwing divorce was dlslribulion dale, ralher Ihan dale panics separaled; eonsiderahle Ilnte had passed bel ween separallon and dislribulion of marital asselS, so lbal subslanlial Iluclualion in value of Ihose assels may have necurred, 23 P.S, ~~ I02(a)(6), 0I01(d, c). 12] D1VORct: <!?2S3(2) 1301k253(2) Presumplion Ihal propeny acqnired dnring marriage was marilal property could be rebulled by prcpomlcrancc of the evidence: showing hy clear IUlt..l convincing evidence was nol required III rehut presumplion, 23 1',5, ~ 0I0l(e, I), I'ag. I [31Il1VORCE <!?253(2) IJ.lk253(2) Evidence established lhal husballd's conveyance III his wife. iT: her sule 11;11111:, of line Imlf intcrc~1 In I11Milal residence. which previously had becn held as lenmlls hy Ihe cluirctics, Wt1S nn inlcrspuusal gift that was nut snlljecllo eqllilable dlSlribUlioll in divorce proceeding. despite husballd's claim Ihal transfer was mOlivaled for rcil:;ons or tax planning 10 rcuu!.:c federal CS\iltc tilX ralher lhan by "love alld affel'lioll" for his wife. 23 1',5, ~ 0I0I(e)(3), I4lll1VOltCE <!?252.3(3) 13,tk252,3(3} Divorce COlic docs not contemplale thai, uner gift h.ls been made. inquiry will be eOllducled Inro whelher reasons for gift were sufliciclltly "loving" as 10 warranl reeognllion, 23 1',5, ~ 0I0I(e)(3), [5J CONSTITlITIONAL I.AW <!?191 92kl91 Equitable distribulion provisions of divorce code cOllld be eonslillllionally llpplied 10 property rights which vesled prior In code's effeclive dale. 23 P.S. ~ 0I01(d. c), [5] IlIVORCE <!?4 1301kol E'Iuilable distribulion pmvisions of divorce cooe could be eonstitullonally llpplied 10 property rights which vested prior In code's effeclive dale. 23 1',5. ~ 0I01(d, c). ..S35 .380 Bonllie D. Menaker, for llppellant. Ronllld M. Katlman, Illr appellee. Be line NIX. MeDERMOTf. STOUT, JI. llnd LARSEN, FLAHERTY, ZAPPALA, PAPADAKOS alld OPINION OF THE COURT FLAHERTY,lu";.;e. This is an appeal from an order of lhe Superior Court which llmrmed In part, and remanded for furlher proceedings. wilh respect to un oruer of the Court of COllllllOU Pleas of Cllmberland Counly delermi.ling eqllilllble distribution of certaill pmperty following II divorce, 361 Pll.Super. 504, 522 A.2d 110I.\. The ilction for equiHlhlc distribution arose from the divorce of appellanr, Gregory L. SlIlliff. and appellee, Copr, ':' Wesl 199') No Claim 10 Orig, U ,S, GOVI. Works 543 A.2d 534 (Clt.Il~: 518 I'll. 378, "3Hll, 543 ,\.2d 534, "535) Carlene SUlliff. afler lheir marriage of nearly 25 years, Appellant liIed a eomplaim in divorce in 1982, and. aflet numerous hearings were held hcforc 11 masler, a report was liIed in 1984, Suhse'foelllly, in Decemher, 1984. lhe parties liled a slipulalion providing lur, inter alia. a bifureilled divorce, A Iinal divorce decree was Ihen inunediillely elllered, On May 7, 1985, Ihe Court of Common Pleas liIed an order providing for e'fuirable dislribUlion, An appeal and cross appeal were laken In lhe Superior Court. whereupon certain elemellls of lbe e'fuirahle distribution scheme Were ilffirmcd ma! others were remanded It)c further uc(crnlinatiollS ilnd/llc modiliealinns to be made. The inslanl appeal ensued. II J The lirsl issue 10 be addressed is whelher lhe Superior Court erred in ilS seleclion of a I'alualion date for the marital assets. The Court of Common Picas ulilized Octoher 2 I. 1981, lhe dare when lhe parties separaled. as lhe valualion dale. The Superior COUrl concluded, however, lhat valualion of Illarilal assels should rellect values as of lhe dislribulion dale, "536 ralher than Ihe sep.ration dare, and, accordingly I lhe case WlIS remanded for revaluation of "381 certain business interem, including aUlolllobile dealerships, lhal were subjecl 10 dislribulion. The basis for lhe Superior Court's aClion was thaI, because lhere had been a considerable passage of lime between separarion of the parlies and dislribulion of Iheir Illarllal assels, subslamial /Iuelualions in Ihe values of those assels may have occurred, whieh, from an equilable slandpoint. should be rellecled in lhe distribulion order. We agree. The Divorce Code conlains no express provision governing lhe seleelion of a dale 10 he used Ii" valualion of marital property. where e'fuirahle distribulion is concerned. While the Code clearly slares Ihat property aC(iuired afler sepamlion is nor 10 be considered marilal property, 23 p.S. * 401(e). lhe queslion presented here is nOl whelher particular assels arc 10 be deemed mariral, as opposed III individually owned. bUl ralher whelher assels given 10 be marilal in nalure arc 10 be valued 'II one level or anolher. Il is implicil, however, in lhe stalulory provisions governing equirable dislribution lhat a valuation dalc ,"asonably proxima Ie to Ihe dale of dislribulion musl, in lhe usual ease. he ulilized, Specilically. 23 P,S. * 401(d) provides: In a proceeding for divorce or annulment. the Court shall. upon request of either party, e(luilahly divide. dislribule or assign lhe Illarilal property bel ween lhe parties without regard 10 maril;,1 misl:onducl in such proportions as the court deems just ilner cOllsillcring HII n:lL'villU fm.:tors including: (I) The lenglh of Ihe marriage, (2) Any prior marriage or ehher pany, (3) The age, heallh. sl:llion, :U11111nll and sources of income, vocatitlllal skills, c:mplo)';lhilily, estale, liahililies and needs of each of lhe panics, H) The eOlllrihuliol1 hy one party to lhe eduealion. trilining, or hu.:rei.ISeU earning power of Ihe other party, (5) The opponunity of each parry lur fUlure ilctjuisitiollS of capilal assels illld income. "3H2 (6) The sources of income of bolh panics, including hut not limited In medicnl, relirement, insurilllce or olher bellenls. (7) The COUlribuliou or dissipalion of each party in the ::icquisilion. preservmiol1, deprecialion or apprecialion of Ihe marllal propeny, inclUding Ihe conlribUlion of a party ;.IS a hOl11el11ilker. (8) 111e value of lhe properly sel aparllo each parly. (9) 111e slandard of living of lhe panics eSlablished during the marriage. (10) 11le economic circumslances of each pany al lhe lime lhe division of property is 10 become effeclive, E,xaminalion of lhis slalulOry proVIsion reveals numerous grounds for an inference lhat marilal property musl be dimibuled whh reference 10 hs value al the date of dislrlbulion. Indeed, il is inconceivable thai the requiremenl lhal the dislribution be made in such proportions as the eoun deems "jusl" could be salis lied Wilhoul reference 10 the eurrelll values of Ihe assels. The slatule, in hs enumeralion of laelors 10 be considered in making a dislribulion of marilal propeny. sels lunh a numb~r of faelors which IllCUS on IIle preselll needs and linancial situations of lhe parties, including lheir "amounl and sources of incol11c," "employability." "eslale, liabilities and needs." chances for "rulure acquisitions of capiral asscls nnd incomc," "sources of income," the "value of lhe propeny sel apart" as non-marilal propeny, "slandard nf living." and lhe "economic circumslanees or each party allhe lime lhe division of propeny is 10 becumc effective." In view of these t~lclors, and with particular reference 10 1I1e lasl one which encompasses generally all of lhe Ilmncr, and which expressly focuses on the parties I linanchll circumslances at the lime when marilal propeny is 10 he dislribuled, il is inconceivable Ulal lhe legislalure illlended marilal property 10 he vnlued ill some olher time. Grilllled, Ihere Ill"y be SilUi.llions where rmlril:ll :Isseis have hcen consumed or disposed of by one of thc parties, thus rcndering " current Villu.lliol1 impossihle i.1I1d making it nccessary 10 rely on d:ua 111<11 "3H3 would olherwise Copr. " Wesl I ~9~ No Claim 10 Orig, U ,5, Gov!. Works 1'1I~e 2 543 A,2d 534 (Clle lIS: 5181'". 378, .383, 543 '\.211 534, "536) be considered slale, but such is nul the case here. See "537 generally Sergi v, Sergi, 351 Pa.Super, 588. 5lJ.l, 506 A.2d 928, 931. 931 (1986) (discussion of valuation where mariH11 property is 110 lunger in c:dstcllcc). In the usual easc. 1100\'c\'cr. givclllh.lllhc parties' present nceds and circull1s[.uu.:cs nee 10 he a major factor in distributing marital iISSCIS. ic would he impossible to construct a distrihutiun scheme Ihat would be fully responsive 10 Ihose needs amI circumstances if (he court \\Iere 10 act \l.:ilhout laking cognizance of the current valUl:s of the "sse IS hcing distribuled. As slaled in Oacchella v, Oaechella, 498 Pa. 227. 232,445 A,2d 1194, 1197 (1982), "By providing lilr lhe distribulion of properly aClluired during Ihe marriage. lhe Divorce Codc permits the correction of ,.. economic injustices...." See also 23 P,S. !i 102(a)(6) Oegislillive imem of Ihe Divorce Code is to "[eJffeclUille ccooomic justice belween parties who arc divorced ... and insure a fair and jusI delerlllinalion and sClllemem <If Iheir properly righls,") Yel, one can readily imagine Ihe economic injuslices thaI would be inflicted by dislributing properly wilhout regard 10 ilS value. It eannol be said thaI dislributions bascd upon stale valuations are based on value, lilC value is by no means a conslan!. If, as bas been suggesled, marilal properly values were 10 be lixed as of dIe dale of Ihe parlies' separalion, or as of the dale of lillng a complaint in divorce, severe injustices would al times be inllieled upon lhe parlies concerned. Volalile markcl conditions and changing economic circumstances cnD render assels Ihat had been valuable months or years earlier virtually worlhless in dIe present. and vice versa. Publicly Iraded securilies may be worth a fOrlune one day, and a pillance lhe nexl. PrivalCly owned business imerests may be valued as a gold mine, or as a scrimptiont depending on the times. Automobiles thaI were once of considerable WOrlh may, through abuse or neglecl. rapidly hecome valueless. Other examples too numerous to mention scarcely rcquire enumeralion. In vieIV of lhcse commonly .384 recognized aspeels of valualion. iI is diflicult 10 conceive juslilication Ii" Ihc vieIV that slale valuation dala, Le.. data thaI docs nnt rellect values reasonably proxinlille III Ihe date of dislrihulion. should be used by the courl in seuiog a dislrihulion scheme, S~e Sergi v. Sergi, 351 Pa,Super. al 594, 506 A.2d al 932 ("IElquilahle resulrs willmosllikely llow from providing the court with the most recent Informalion availahle"., "), l'age 3 The present CilSC prCSCl1lS a prime CX:lltlflh: of circumstances where reliam:c upon stale Villu;\litm d..ta could lead to ao unjust diSlrihUlion of property, Th~ parties sCll'lralcd in OCloher of 1981. a complaint in divorce was liIed in Fehruary of 1982. and dislrihulion of marilal assels IVas ordered hy Ihe Court of COlllmon Pleas in MayoI' 1985, Clearly. lhe lime lapse helween lhe Ii'rmer dales and 1I1e laller dal:, when dislribulion was ordcred. is such lhal highly signilkam vuIue lluctu.ullll1s may have occurred. Tn dislrihllle property without regard to those Iluclualions would he illogical. nnd would undermine the legislalive huenl of making th~ equilahle dislrihution process responsive to the COl1lcl11flonmcous necds ond linancial sitmllions of the p.uries. We conclude, Iherefore, lhal the Superior COUrl properly rClllanded this t:i1SC for determination of revised asset valuations, therehy negaling Ihe COUrl of COlllmon Pleas' reliance upon values lixcd as of the dale of separalion, 121 The next issue presemed concerns dIe classilicalion of property as marilal. or non.marilal, undcr provisions sel limh in 23 P.S. !i 401. A slatulllry presumplion is eSlabllshed in favor of classifying properly as marilal when iI was acquired during marriage: All property, wh~lher realnr personal. acquired by eilher party during lhe marriage is presumed 10 be nmrilal properly regardless of whcther title is held individually or by Ihe parties in some form of co- ownership such as juim lenancy, lenancy in common or lenancy by the emirety. 111e presumption of marilal property is ovcrcome .385 by a showing Ihal Ihe properly was acquired by a melhod lis led in subseclion (c). 23 P.S, !i 401(1). Thus, properly is deemed marilal unless iI was a~quired hy one 01 "538 dIe methods enumeratcd in 23 P.S, !i 401(e), as, for example, property acquired in exchange for property held prior to the marriage. propCrlY excluded hy agrcement of the parlies, property acquired by gift. properlY 'Icquired after separalion. elc. 111e specinc issue rais~d in lhis uppeal, however. is whclher rebullal of the presumplion as 10 maritul properly requires a showing by clear and convincing evid~nce, or whedler il is suflicielll III r~but the presumption by a preponderance of the ~vidcnee, In Ihe procecdings below. belilrc Ihe masler and the Courl of Commoll Picas, l\ rC1luircmcnl of clear and cunvincing evidence wus imposed, Thc Superior Court uflinned as 10 lhal rCllUircll1L'l1l. \Vc reverse. In t1ftirming the slandtlru of Ch.'itT lUlLl convincing cvidcm:c, the Superior Court rcnsnllcLl that because Copr, ,., WCSl 19~9 No Claim 10 Orig, U,S. Gov\. Works Sol3 ,\,2d '34 (Cite IL~: SI8 I'u. 378, .J8S, S43 A.2d S.14, "S.1H) Ihal slandard Is applied In eerlain olher civil eases, il should be applied in Ihis eonle>! as well. For example, Ihe Superior Courlnoted lhat Ihe slandanl is applicable where frand is 10 he proved. e,g" Mollneux v. Reed. '16 I'a, 31)8, '32 '\.2d 792. 79.1 (1987), where one alleml'ts 10 rehlll the prcsumption Ihal properlY purchascd by a hushand or wife and expressly lilled in lhe names of Ixuh Ihe hushand and wife conslilules a compleled gin and an eslate hy Ihe emlrelies, see lIolmes ESlale, 414 I'a. .IOJ, 21X) /\,2d 74' (19601), and where parcmal righls in children are 10 be severed, e,g.. In re T,R,. 502 Pa, 165, 167, ,165 /\,2d 6012, M2-M3 (1983), See aim 3!/\ C.J,S, Evidence ~ 1023 Iclear lInd eonvilleing evidence required in a limiled number of eivil cases), In shorl, the Superior Cuurt fucused unly UPUIl those civil emiL'S where Ihe more demanding slandard of prlXlf has hccn applied. ratller IIl1m u(lOn Ihe predominam numher of civil CllSCS where Ihe evidenllllry hurden requires only proof by II preponderance of Ihe evidence, It is lIIU apparenl whal conneclion is III he perceived in comparing Ihe presenl case 10 Ihose ciled, Iilr Ihe Issucs presemed :md consideralions .386 involved are clearly diSlincI. Indecd, Ihc presem case is one where Ihe presumplion in queSllon was created hy an express sla!ulllry provision In the Divoree Code, and where Ihe "showing" necessary 10 rebullhe presumplion hilS likewise been referenced by slalUle, 23 P.S, ~ 401(1). The basis for imposing Ihe slllndard of clear and convincing proof was Indlcalcd in Ihe dccision below 10 be lhal Ihe wisdom of experience has demonslraled a need for grealer eerlalmy when dealing wilh IIIlS subjecl maller, due 10 Ihe facI Ihut cerlain social consequences and harsh ur far. reaching effects un Individuals may ensue from a delerminalion lhal any given properlY is 1101 marilal in nalure. Yel, in any case where economic interests of the parti~s arc tn he adjudlcaled, as is lhe case where righls It) marilal properly arc 10 be delCrmlned. il is obvious Ihal lhe parlies Involved will Incur lhe el"fecls of Ihe adjudicallon. II is nol clear. however, Ihm Ihe effeelS arc any grealer In Ihis realm Ihan when olher economic and properlY ImereslS arc m slake, and, Ihus, il docs nol appear lhal a higher swndard of proof is. of neeessily, required. 131141151 Indeed. If Ihe legislalure had imended II higher Sllllldllrd of proof 10 be applied in rehunal of the SIQIUwry presumption regarding nmriHl1 prupcny. Ihe sllllulory hmguage would surely have so Indiealed, Instead, Ihe legislature crcillcd a ruh.' of suhstanti,,'c law Ihal properly acquired during marriage Is In he deemed marital in nature, ahsellt n "shuwing" that the l'uNe 4 properlY was ou:quirctl by one of the methods enumeraled in suhwelion Ie), 23 ('.5. ~ 4(111), Cl'r1;linly, lhe mere I'm: I Ih.ll a sl.lttllory presumption hilS hl'en en.u:tell, ,\.'ilh provision fur the presumption tn he rehulh:ll upon .1 proper showing, is not llasis In itself for inferring Ihat clear muJ convincing cvidence is needed to rehut the presul11ption. Sec. e.g.. Fawcell ESlale, 4.1l) Pa. 497, 297 1\.2d 799 (1972), We pereeive nil hasls. In Illgic. puhlic p"licy, Ilr 1l1herwise, III Infer Ihal Ihe "showing" required under Ihe Inslanl sl:IlUle was imended by the legislalllre III he .111 cnhanced nile. rcquiring l1lore than the usual prcpondcnmcc of evidl.'nce It) I.'stahlish the -3H7 necessary prollf. Thus, inasmuch as an Improper evillellliary slandard was applied hy Ihe courlS 1.cIIlW, 01 rcnmnd is ncccss.lry 10 --.539 permit reconsideration Ilf Ihe case inlighl of lhe appropriale slandard, IFNII FNJ. Thl' n.'II1Olininl: is!\ucs r"bed hy appcllanllllay he addrl'!\!\l'd in SUl1l1uary fashiun. Appellant challcnges 11l1' ma!\h:r's 1l1'ICrminaliol11hal ollc-half uf Ihe marital re!\iJcllcc wali Ihe !\eparate pruperl)' uf appellalll's \I.'ife, ill1d, hcm:e. th,,1 !\uch one-half interc~H was Jlill suhjccI In elluilahle dio.lrihuliull. Thl' ma!\lcr's delerllliml:illl1 was hased upnll a tindilll: of an interspnus;11 gill in 11I1' Ii.JrIIl uf a conveyance IIIJJe in 197K hy i1ppellalU In his wife. in hcr snle name, tlf a une.hillf inle:n:sl in lhl' marilal rc.",hJcncc, whkh. ulllil Ihen. had he:en held as lel1allls hy Ihe ellllrcties. Sce Sema!'lck v. Semasd, 509 POI. 2K2, 502 A.211 109 (I9K5) (prnpert)' can he renJerl.'lI nlllt.marltal via an inlcr!'lptJu!'Ial l:in, !'Ice Divorce Cud..:, 23 P.S. ~ 401(e)(3)). AppellalU clHuends thai Ihe cllnvcyance was made fur re:a~(lns (If lax. planning In fL"lIuce federal e~lale la"-es, UptUl the n.'Cul1l11u:ndalinn uf a law linn Ihal a gili he: maJe fur Ihal purpose. and Ihil1, hccau!\e appellanl WilS not lIIutivalL'\I hy "Inve and alTccliun" fur his will', Ihe cnn\'cyancc: :'ihllUhJ I1tll CllullI as a gift I'llI' purpllses \If Ihe Divorce Cnlle. Ul.lllali\'C il\lel\l is. of cuur"'e, an eSM:lllial c1cmelll tlf.. valid gili. Id, al 2K6, 502 A,2d al III, DUlnnce II is delerlllined thai dlll1ali\'e illtelll was presenl, irotlulr)' illln Ihe rea!\llll or lIlutive: I'llI' a l:ili hl-colllcs llleanin!;lcss. ^ Iransler lIlotivated by all allempt In avnid inheritilllce laxes is "UIII incol1!\islCIll with a donath'e illlel1l. hUl ralher pusilh'cly su~gests such an illlelll." ClilY v. Kcber, 460 Pol. 620. 626. 627 n. 3, 334 ,\.2d 263. 266 II, 3 (1975), II calUxll he said Ihal Ihe: lllil!\lcr errl.'d in lilldin)J an illlcr~ptlu!\al gili IUlhis ca...e, and e:\cn appellalll dOl's Ikll deny Ihal Ihe wme)'ance shuuld he regarded as;1I1 cfll'clh'c gin IiiI' fclll..'ral la\ purpo!\cs. In es...e:nCe, ap(lCllanl reqUl'sls Ihilt IWII caleguries tlf gins he rccngnil.l.'\I. Le., Ihn...e made !ilr rea",ol\\ uf "Im'e and allectiulI," and Ihme lIlade: fur (Hher reasons, Sll Ihal, lIl'pe:nlling un Ihe IlCca!\iun presented. .lp(lCllalll clluld a...'crt ur deny a gih ilS he'll SUilS his il1lcrc\ls. Such a position is Cllpr. t', Wesl 1999 Nil Claillll\l Orig, U,S, Go,,!. Works S43 A,2d S34 (Cite us: 518 Pu. 378, 0387, 543 '\.211 534, "539) dearly ulIlcnahlc. The Divorce ('II\Jc dne... mil contemplate Ihal, ~licr a Mill ha, Ill'ClI madc, .1Il inquiry will he wlllIucu:d into whether Ihe n:a'itJllS lilT the gift were suflicicllIly ~Jtlvillg" iI'" Itl w"rrlllll TL't:ucnillun. l\ppcllal1l further illh.'gc... that llle l'IlUWi hduw crrulIL"\lusly ittlcrprctcll a !ollipulalitlll of Ihe partie... in a manner Ihal pn.'cludL,'J them frul1l cuw'IklL'rillt; Ihe alleged dislincllull hcl\H'1.'11 "'uvillg" gin... illlJ tllh~'r types ur gilis. InJMIIUeh as Ihe alll'cell dhlinclioll j... without hasi.li, Ihe quest!un nl' whether the slipulillinl1 was prnJK.'rly ImcrprclcJ h of 1111 cllmClllIL'IICC. Finally, appcllalll ClIllh:nds Ih;1l lilt.' clJuilahlc dhtrihulinn pruvbitll1s nf the Divorce Cndc call1lot conslitutionally he applied hi properly rights .....hkh vesled prim In July 1. 19liO, Ihl.' effc\:llvc \Jail.' Ill' till.' CudI.'. Such a clllltelllillll h:ls alreillly heel1 wlI~iJcred anll rej~'Clell hy a majorilY of this Cuurl. nUlwithManlllng vigoruus L1is.~ents. BlI\:chella \'. naCCllclla, 498 Pa, 227.445 A,2J 1194 (1982) (Mr, Juslicc:. now Chief Juslke. Ni..... lIisscnting. anll Mr. Juslice Flahcrty. di\selllinJ;. juincll 111' Mr. Juslkc Larsen). See also Krcllzclak v. I\rellzclak. .503 Pa. 373. 469 A,2J 987 (1983) (Jue process c'ccplion In relroaclive applicatiun tlf equilahle lIblrlhulitJlI pruvisiUll'i whcre riGlns of a third p:lrty Irallslcrcc are cuncerned). 0388 Case remanded In Ihe Court of Common Pleas for proceedings consislelll with lhis opinion. McDERMOTf, J., joins in the majorily opinion and liIes u separate concurring opinion, ZAPPALA, J.. liIes a concurring and disseming opinion in which LARSEN, J.. joins. STOUT. J.. did not parlicipale in lhe consideralion or decision of this maUer. McDERMorr. Joslice, concurring. I join in lhe opinion of Mr, Justice F1ahcrty, However, I write separalely to emphasize lhar the dislribulion dale is the datc the common pleas courr elllers an order of distriburion, and lhat the disposilion dale of post-lrial motions or appeals docs 1ll1l nni:cl lhe use of that original date as lhc valualion poin!. Thcrefurc. a Iiligant cannut contest the relalive value of assels on lhe grounds lhal they subslamially changed while the case WaS being fUrlhcr Iitigarcd, ZAPPALA, Justicc. concurring and dissellling. While I join the majority Opinion with rcspecl 10 lhe burden of proof rcquired 10 delcrmine a marilal asset, I'uge 5 and Ihe issue sunul1arily disposed of in footnllle no. I, I mil>! dissenl flllm lhal parl of the majority Opinion n:ganJing the valuation dale or the m;uit<ll property. Under Section .1I)3(b) of lhe Divorce Code. IXlth parries mils I sllbmit a delailcd invclllory and appraisal of illl property uwned ill the time the action is commenced. likewise, undcr Pa,R,Civ.P, 1920,33, we relluire each parlY who seeks distribution of plllperl)' 10 lile a delailed inventory, listing the marital plllperly valued as of the date "540 of lhe complailll, within sixty dilYS aftl,.'r service of a ple:lding containing a chlim tin distribution of property. Pn.R.Civ.P. 1920,33(a)(.l), 0389 Therefore, it is clear 10 me Ihat lhe aJlpropriale <laIC for valuiog nUlrital properly is Ihe uiile the action was cOl1ullcnced. It wuuld seem somewhat or an anomaly to require the parties to set values as or a cert;:lin uale, yet ignore that valuation at lhe time of distrihulion, Nowhere else in lhe Divorce Code arc lhe parti.,s required to set fOrlh lhe valoes of lhe properly III a differenr lime, Furthermore. using lhe date that Ihe aClion was commenced as Ihe time for valualion nm only provides certaimy, bUI is also consistem wilh lhe Divorce Code's aUempl to expedile an otherwise emotioIH11 or cxplosive period, I disagrce with lhe majorily's reasooing U161 using lhe dare of liIing lhe complaim will result in severe injusticcs, Eilher parlY can liIe a complaim 01 any lime. TIlerefore, each party has Ihe equal opportunity of setting the lime for which the property will be valued, Once a complainl is liIed, both parties can mutually agree 10 lerminare Ihe marriage and expedile properly dissolotion. Using the lime requirelllems set 1<>rIh in our Rules will result in an orderly procedure and limely distribution of properly. TIle Iluclunrions in values lhlll the majority is trying to avoid will nol occur. I ndmit that in a case such as the one now before this Court, using values us of Ihe liIing dale of the complainr when lhe property is dislrihuled lIlore lhan three years laler may resull in slale values, TIlls docs nol appcar 10 me to he lhe falllt of Ihe Rule or Ihe Court. but uf the parties themselves, To prevem this occurrence, bOlh p:lrties could have agrced to a divorce undor Scction 201(c) of lhe Divorce Code nnd expedilcd propcrly distribulion in accordance with lhe Rules. lIo\l,'c\'cr, fwm the numher of uppenls that have bcen liIed hy these parlies (see Sutliff v. SOlliff, 361 Pa,Super. 194, S22 A,2d 80 (1987); Slllliff v, SUlliff, Sl5 Pa, 393. S28 A,2d 1318 (1987\; SUllilTv. SUllilf, 326 Pa,Super, .1%, 017.1 A.2d S99 (1984)), II is dear that it swift resolve W:IS not their highest Copr." Wesl 1999 No Claimtll Orig, U ,S. GlIVl. Works 553 A,2u 436 (Clle us: .IHII'u.SUpH. 221, 55.\ '\.2d 4.1(.) Murgurcl ,\IlEJ.STt:IN. '\pp<'lIUIII, v. Sheldllll AIlEJ.STEI:IO, App<'lle,'. SUllCriur CtlUrl (If PCl1nsyl\'ill1ia. Suhmiueu Sepl. 9, 1988, Filed Jail, 26. 1989, Actiun WOlS brought fur eJivon.:c, The Court or Cllmmllll Pleas. Lackawalllla COllmy. Civil Divisioll. Nil, 81 of 4412. Walsh, J.. elllereu dccree III' e'luitahle distrihulillll alld appeal was lakell, The Superior Coull, No, 572 Philadelphia 1988. Wicalld. J.. held Ihal: (I) lrial coun did mn ahuse its discretiun in awarding wife alimony at nile of 550 per week for olle year; (2) Irial coun did not abuse lIs discretion in orderillg ea.:h pany lU pay Iheir 11'1'11 legal ICes; alld (3) Imercst ill busilless tll he dlstribuleu as marital properlY was olle.half illlelest held by husballu al time III' scpar.nillo, Reversed and remandcd. [1) mVORO: €:=>247 134k247 Trial coun did nol abuse its discretion III awarding alimony 10 wife at rate of S50 per week for one year; evldellce dlselosed no Impediment, whelher physical, menIal, or edU':aliollal, lhal would prevelll wife from supporling herself. [2J mVORCE €:=>224 134k224 Spouse's separale eSlale is legitimale cllnsideratilln ill trial court's determination of rC<lucsl for counsel fees in divorce action. [.IJ IlIVORCE €:=>223 134k223 Trial court did nol abuse its discretiun ill di\'on.:c action in uClcrmining that cat.:h spouse h:ld sullidcnt <Isseis to pay his or her own cuunsel fees. [4J IlIVORCE €:=>252.5(\) 134k252.5(1 ) Trilll court did not abuse its discretion in distrihuting proceeds from sale or lll.nil,,1 home in al1loUI11 of .$35,000 equally between spouses in divorce "clion. [51 DIVORCE €:=>252..1(1) 134k252,3( I) One-half inlen.:st in corporulion owned hy hushilllll :.II l'U~l' I time of marit:ll sl'lwr:lIion WilS suhject 10 dislrihutiol1 as maril;\1 propl'rty llot\\'ithsl;lIldinp. fu!,,;t that while lIivon.:e :1I.:tiol1 was pending tJK slwres uf Ireasury l'i1t1l.:Ker Wl'rc issucd, wilhmll mldili\)llill ~t1llsidcratitlU paid, 10 l.:tHIWller or husiness: liltl'r issu:IIlCl' of trCi\sury SltH.:k without nev,' cunsidl'r:lliol1 did 1I0t Ch:ll1gl' inleresl which hushand uwned at time or sl'lli1rtltiol1 iIIuJ which w:as suhjecl to distribution in diHlrn' pHl\:eeuillgs. ((,I COIU'ORATIO:lOS €:=>(,29 IDlk(,2,} \Vhl'rc t\\"o shareholders OW lied ont.' share e:u.:I1, vulue of each shme W:IS Clluiv:llcnl 10 one Imlf uf l.:orpor:lte assels ilvitilahlc for Iilluid:atioll purposes. (71 III VORCE €:=>252.3(1) 13.lk252,3(1 ) In division of maril:11 assets, nonsh:ueholdcr's spouse is emilled III participale in lhal which shareholder spouse would have realized if his or her interest in curpor:lliol1 had hel'n liquidated, [HIIlIVOIICE €:=>252..I(1) 134k252.3(1) Wife was Ilol emllled to appreciarioll in value of corporation due 10 postsepararioll effons of husballd nnd CO-(}\\'l1er of business, "4.16.222 William R, Lee, SCnnlloll. Il>r appellant. David p, Posatko, Public Defend,:r, Tunkhalllloek, lor appellee. llefore WIEAND, McEWEN and ~1ELlNSON, JJ. "437 WIEAND, Judge. The tri:ll court, m:ling upon reconunendmions made by a maSler. emered a decree of e'lUllable dislrlbulion which (I) .22.1 awarded alimony to Ihe wile III the rale of lifry (S50) dollars per week Il>r olle year; (2) direcled each party 10 pay his or her own counsel fees allu e,'penses; (3) directed thaI the proceeds derived from lhe sale 01 lhe nHlrilal home be divided equally; .\Ild (01) uwardeu wire u olle-hulf ( 1/2 ) illleresl ill II single sh:ue or stock owned by husband and representing a nne nne-hul1l1redlhs interest in :l closely held husiness cllrpllrutillll, The wire appeuled. In every respect, she coutl'nils, the awurds made to her were inadelluall', \Vc Iind mcrit in the 1:15t uf her l.:llI\IClllhIllS: and. therefore, we reverse :md rem:lI1u hlr funhl'r ctlllsideralitm. Cllpl. " Wesl I')I)'} Nil Clui\lllll Orig, 1I,S, GIII'1. Works f\targaret :1I111 Sheldon Adelstein were married 011 553 A,2d 436 (Clle us: 3HI Pu.Suprr. 221, .223, 55.1 '\.2d 43(1, ..4.17) April 25. IW>1. Fllllllwing marriage. Mar!':lrel tJiscolltinuCll her c,'mplnymcnt ilnd for Ihe Ill,,'.\t eighteen )'L'ars hcc:unc :1 hOIllc,'llIakcr .1I1U mother. IFN II Shel~lln was line llr tWll sharehlll~ers in NEPp Wire produclS. Ine,. a c111sely hcl~ cllrporalilln cngagl.'d in the husiness or m;lI1ufilf.:luring hUllp sh:ll.k's and lamp Cllltlpllnenls, The panies separaled in I ~82. and a divorce uClion followed, Prinr to llu.' 11l..':lring hcfnn: u maSh..'r I most ih:II1S Ill' personal property had hcen dislrihllle~ by allll hel'H'cn the panics, The master, after laking (l'Slimony, l11;lllc .Hhliliollal rCl.:oltlmclluillions \vhkh the coun, dl'spitl.' l'XCC!lliollS by bOlh spouses. incorporalc:d inlo U final dl'~rcc. FN 1, Twu chilJn:n were horn of lilt.' lIIarriage. AI the lime Ill' 1111: Ifiill court's I.kcbiull, Ihc)' were 21 lint..! 19 years old. Thcir support is IItl! in h,ul.'. 11112113) 111e lrial Cllun's llrder regarding 1Ilimllny must be cvnluated againsl an abuse of discretion slandard, Mazzei v. Mallei. 331 Pa,Super, 432, 437, 480 A,2d 1111, 1113 (I~8.1), "IIII' a party receiving 1Ilill111ny is lIhle III provi~e fllr [herl reasonable needs lhruugh employment, the court is to fashion lIn alimony order 10 he in eflect only umil such ell1ploYll1elll has been ohlained or the party has develope~ an lIpprupriate employable skill." I~, al 443.480 A.2d at 1116. quoting Geyer v, Geyer, 310 PlI.Super. 456, 46<1. 456 A,2d 1025,1029 (198.1), Here, lhe husband-lIppellce has suppllrted the wiiC- lIppellllnl during .224 lhe pen~ency of the divorce proccedings. and the trial court louud Ihal wife- uppellalll. in an addilillulll year. shoul~ be ahle III become selr-supporting, Tbe record discloses nll impedill1elll. whether physical, l11emal, or eduealiooal, thllt would prevelll lIppellant from suppllning herself, Under these circumstances, thL're is 110 basis in this case lor linding an abuse of the trial court's discretion in lhe thing or 1Ilimony. 10 delermining lhe prupriely or an award of counsel fees, we also utilizc an abuse of discretion stmuJan.l of review. Miller v, Miller, 352 Pa,Super. 432. 44.1. 508 A,2d 550. 556 (1986); PlIngallll v, PlIngallll, 32~ Pa,Super, 25. 31. 477 A.2d 885, 888 (I~84); ProLZoly v, Pronoly, .127 Pa,Super. 326, 331. 475 A,2~ 820,823 (1984); RUlh v, RUlh. 3111 PlI.Super, 282. 285. 462 A,2d 1351, 1352-135.1 (ItJ83). However, counsel fees :Ire not awarded tn either spouse autllln.ukally. Di.lIl1ontl v. Dimnund, 1360 Pa.Super. 101. 116. 51~ A,2d 1012. IO!') (1987) J, "Aemal nee~ l11usl he showu in order III justiry an award," Deell v, Deeh. 3.12 Pa,Super. 17. 23. 4~2 A.2~ 41. 44 (1~85). citiug II110ver v, Hoover, 288 Pa,Super, 15~. 101-102, 4.11 A,2~ "1IJ:<<.' 2 .1.17, .1.18 (1')81), CounscliCes arc appropriale when IH,,'ce,sary hI put the p"rtiL's "011 a par" in defending IIlL'ir rights or in llllowing a dCJlendcnt spouse to l1Iaintain or defend .111 m:tiun fur divon:e. See: ~Iiller v, Miller. supra .152 1'.1. Super, at ,142. 508 ,\,2d 'II 55(>; Oech v, Dech. supra; Yllung v. Yllung. 27,1 Pa,Super. 2~8. 302, 41H '\.2d .115, .117 (I')SO!. Johnson v, Jllhnson. 305 Pa,Super. 409. .115, 529 '\,2~ 112.1. 1126 (I~871. in the inslanl case, the coun delerl11irlL'd lhilt the dislribution of properly was sufficiellt to n.'lluire hoth spouses In pay their own legal fees. A spousc's separate esl:lte is a Icgitimate cOllsideration in the Iri:.ll coun's ....38 determin:.lliun of a rcqucst f()r counsel fees. Fitl.putrick v. Fil/P:llrick, 377 Pa,Super. 268. 271. 547 t\.2d 362. 369 (1~8H). We lind no abnse of discretion in lhe Irial coun's delerminalioo lhm each pllrly had sufliciclll :Isseis to pay his or her own counsel fecs. .225 H I The I11l1ril31 home WllS sol~ during Ihe divorce procee~ings Il>r lhiny-live thousand (S35,OOO) dollars, The lrial coun dislrihute~ these proceeds elJnally helween the parlies. Ahhllugh we lind no ahusc uf di!icretioll in lhe coun's equal division of the procceds. we ohservc that some revision may he necessary in or~er to correcl Ihe error l11ade hy lhe CllUrl in dislribuling husblln~-appellee's illleresl in NEpp Wire Products, Inc., a c111Sely held husiness corpor.llion. NEPp Wire Pro~ucts. Ine, was organized in 1979 hy Ihe hush.ll1d-appellee and Gene DeMuro, Irs inilial capilali/alion \Vas rllrlY lbousand ($-l0,()()(J) dollllrs. or Ihis 1II110unt, husband. appellee cOlllrihuled lwelve Ilwusand live hun~red (SI2.500) dollars, len lhousan~ or which bad bcen borro\Ved rrom DeMuro, The balance of the inilial Cllpillll was cOlllribuled by DeMuro, Alrbough line hundred (100) shares of slOck had heen aUlhori/ed. nnll' two shares were issue~. One share \\'HS issued tu DeMuro, and one sharc \Vas issucd III the hnsban~-appellee. Tbis \l'lIS inlen~ed 10 \'Cst an cqual interest in the cnrponlle owners. The remaining ninety-eight (98) sllilres were held as Ireasury slOck. IS) The exislence and nalure or marilal propeny lire dClcrmined as of the l.hue of separation. Divorce Code llf April 2. 1~80, p.L. 63. Nll, 26. * 401(e)(4), 23 P,S. * 401(e)(,I), When Margaret and Sheldon Adelstein sepanllell in 1982, Sheldon owned a 0111.'. half il1lcrest in NEPP \Virc Products, Inc. This one- hall' illleresl \l'as l11aril:ll properly, IFN21 Ctlpr. I' \\'CSI IlJlJlJ No CI.llm tll Ol'ig, U.S. GO\1. Wllrk"i 553 A.2<1436 (Cite us: 3811'u,Super. 221, "225, 553 '\.2<1 436, "4.18) FN2. On Ihal Jillt:. Ill' \:llursc, ShdJolI AJchlclll WOlS also il1l.khh.:J lU DeMuro ill Ihe amount Ill' lell Ihou'JT1!J ($10,000) "ollm, In 1983. while lhe divorcc aClion was pending. lhe ninety-eight shares or treasury Sind' were issued to DeMuro. There was no m.lditional i:onsidcrution p.dd for Ihese shares of slock, The issuance of the stock, aCl.:onling to the testimony. was intcl1~h:d to compensate DeMuro for his greater capital contribution alld also to repay the initial loan ur lell thousand ($IO.(XXl) dollars which he had made to Ihe husband-appellee, The I:ller issue of Ireasury stock without neW cunsidcratiun did not change the interest whieh lhe "226 husband-appellee owned nt the time "I' sepuralion and which was subject III dislribulion in Ihe divorce proeeedings, That interest could not be diluled by the issuance of lreasury stoek 10 DeMuro wilhoUl consideration, When the court held thaI only husband-appellee's one.one hundredth ( 1/ IIX) ) interesl constituled marital property, Iherefore, it erred, [6117J The anempl by Ihe shareholders inter se 10 rearrange their respective interests in the corponllion did not aiter Adelstein's obligation 10 accoUIll in the divorce aClion for his inlerest in lhe eorporalion on lite date when he and his wife separaled. IFN3) On Ihat date, only two shares of stock were outslanding, and the husbund owoed one of them, If the corporal ion had been Iiquidaled on Ihe date of separalion, its assels would have been dislribuled equally belween its authorized stockholders, 18 C.J.S, Corporations ~ 212. See also: Commonwealth v. Aja, Melal Co.. 29 Dauph. 4. 8 Pa.D, & C, 30 (1925), Ahhough 98 shares Were then in the corporale treasury, these shares had no Iiquidaling value and could nol have parrieipaled in the dislribulion; lhey would not have been a faclor in distributing the corporate assels, Henn. The Law of Corporalions (2d edition) al 291. See also, Nott', The Legal Sial us of Treasury Shares. 85 U.Pa,L.Rev. 622. 626 (1937), Where. as here. two shareholders owned one slu1rc each, the \falue of l'uUe 3 cal:h share was cquiv.llcnt tu one.half of the corporall.' assets availahle for liquidation purposes. In a division of marital assets, the llon-slmn:llIlhJcr spouse is entitled to parlicipale in Ihat which the shareholder ....39 spouse would have rcnlilcu if his or her interest iu the corporation had been Iiquidaled, fletcher, Cyclopedia of Corporations, Slock & Stockholders. 9 5102, al 116, Therefore. when a!,!,ellam and appellee scparatcll, the interest ill the husinl'ss In he dislributed itS 111arilal property was .1 0111..'.half ( 1/2 ) interest therein. FN3. It is Ilhvlous lhal appdlcc.hu'ihanJ cnm-iJcn:J hill1~dr lIIore than " tine pcrcl.'1It owner of the CllrpnrJliulI. fur the "ctlllsidcraliol1" fur the Irall~rCr of Ihe remaining share'i uf slOd from the corporatilln's treasury was, ill part, appcllt:c's pcrslIffill debt uf 510,000 10 DeMuro. Appellee was, in fat.:I, using (Urporah: assets, i.e., Ireilsury Slllt.:k, 10 satisfy a pcrsllllal t.h:ht. "21.7 181 The Supreme Coun of Pennsylvania has held lhatmarital propeny is 10 be evaluated atlhe dale of dislribution, Sutliff v, SUlliIT. 518 Pa. 378, 543 A,2<.1 534 (1988). In the inslam ease. however, the eorporation has apprecialed in value since lhe separation and now has a value in excess of seven hun<.lred thousand ($700.000) dollars, This has been accomplished in large measure beeause of the post. separation effons of husband and his co-owner of the husiness. To these posl-separUlion efforts, lhe wife- appellam bas made no contribution, ntis. too. rnuy be considered by the lrial coun in ordering distribulinn of marital assets equitably between husound and wife, Husband. who hus already paid a pan of his wnrk product to the wire-appellant as sllpporr, sbould not be deprived totally of the fruits of his labor, Reversed and remanded Ill( furlher consideralion in ut;cor~ance with the foregoing opinion. Jurisdiction is not retained. END OF DOCUMENT Cupr. t' \Vest l(jtJt) No Clail1110 Orig. U.S. Govt. Works 621 A,2d 659 (Clle us: 42.1 l'u.Super. 5.10, 621 ,\.2d 65'1) ,. Curul E. IIliTI.ER, ApJlellee. v. l.eulIl. IIFI'I.ER, ,\ppellulIl. Curul E. IIFI'U:R, Apllelllllll, v. 1.l11J\ I. IIFI'I.ER, Apllellee. Superior Court (If Pennsylvania. Arglled JUlIe.1, 19'12, Filed March 2, 19'J)' In divorce proceedings, the Cuurt III' Cumlllon Picas, York CUlImy. Civil No, 84 S 63, Duruey, J.. emered un order of cquil:.lhlc distribution. Appcal :Ull1 (,:ross appeal were laken, The Superior CUUrI, Nos, 1i80 and 69.1 Harrisburg 1991. Kelly, J.. held Ihul: (I) lhe value of Ihe husband's share of uwuership in an accounting practice as of the dilt~ of equitahle distribution, not as of the date of separatiun. was commlling: (2) Ihe value sel in a buy-sell agreemem for lhe husband's share in lhe praelice was nol commlling; (3) goodwill iu lhe praeliee was a marilal assel subject 10 equhable distributiun; (4) the trial court did nut abuse hs discretion ill awarding the wife alimony pendeme lite and auorney rees and CUSlS: and (5) the fair remal value of lhe marilal residence should not have been included in lhe marilal estllle, Order vaealed and remanded. [I) DIVORCE <F>150.1(2) 134kl50, 1(2) Master's recommendations on mailers related to equhable dislribulion. alimony pendellle lite, alimony, attorney fces. and costs arc entitled tu great consideration by trial court. hut arc not binding upon trial cour!. 23 Pa,C.S.A, ** 3101 el seq" .1102(a)(6), 3502(a), [2] DIVORCE <F>25.1(.1) 134k253(3) Value of marhal properlY is 10 be delermined m dme of equhable distrihulioll. ahhough slalUS of properlY as marital is idcntilicd at date of separation. 23 Pa.C,S,A, * 3501. (31 DIVORCE <F>252..1(1) 1J4k252.3( I) EllUil<lblc distrihution scheme WilS (0 he hased on hushand's 50% ownership of accounting firm ;IS of dale of clluilahlc distribution, rather 111;111 hb lIne-thinl l'uMe 4 \harc \)1' tl\\'I1\.'f\hip as of \Iah." of lIlil.'ill:r's hcaril1~ 011 e1llliwhle dhlnlllll'"l1 nlalll''', H l'a,C,S,"\, ~ .15111, HIIJI\'ORO: <F>2~.I(.I) Illk25.ll.1) Valu\,.' !'iel in huy-~L'l1 ilgn.'cl1lcnl for hll.'ihallll's sharI.' of ill:cllullling pnll:lh.:c \\w. 1I1111.:lll1lrulling in \'i1IUiltitlll of accounting practkl.' whl'rc huslmnd WU!i 1l1U: Ill' two shan:holdcrs III praclkc at lime of rimal sL'IJanllinn, illlll where agrn'l1ll:nl did 1I0t p,i\L' c1eaf valuation or hu,<hanll's illleresl. 23 l'a,C,S,A, ~ 3102(a)(()), [51 DIVORCE <F>25.1(.I) I J.Ik25.1()) Goodwill value of acclIuming linn of which hushand \\';15 ol1c~lml r owner WOIS husiness asset suhject to cquil:lhlc distrihUlion where linn I1mj heen ongoing bdilre hushand juined it and where Iinll eUlllinued to exist even aflcr ils original owner had died; husband's pracliee cOllld nor be equaled with sole proprietorship. 23 Pa.C.S,A. * .1I02(a)(6), [61 J>IVORCE <F>209 134k209 Purpose of alimony pendeme Iile is to sus(ain dependem spouse on equal basis with (Jlher spouse while he or she lllnintains or defends divorce aClion. [7] OIVORCE <F>212 134k212 Mere fael Ihlll one spouse carns more lhan the oilier docs nol autol1lalically emille spouse with lesser income to receive alimony pendente lite: rather, spouse seeking such alimony must need relief to defend his or her righls adeqUinely, IHI J>IVORCE <F>214(.1) 1J4k214(3) Evidence supported trial court's nnding that wife was emitled 10 alimony pendenle lile. giv,," subslamial disparil)' between incol11e levels of parties and evidellce that wife had resorted to selling her jewelry in order In maintain divorce proceedings. 19) DIVORCE <F>221 134k221 Purpose of award of atlnrney fees is 10 ensure that linancially dependenl spollse will he ahle to maimain or defend divon.:c actitm, as well :'IS 10 elfectuate economic justice. [Wi J>IVOI{CE <F>212 1J.lk212 Copr. (' \VI.'.~l 1')I)l) Nu Claillllll Orig. u.s. GO\'!. WtJrk~ 621 A,2d 659 (Clle us: 42J l'u.Suller. SJO, (,21 A,2d6S'J) Financially depcn~elll sp"use nHlY he enlitled III h"th alimony pendente lite mid lIttorney fees in llnkr 10 muinlain or defend di\'OTI.:C proceeding. [IOIIlIVORCE ~224 1J4k224 financhllly dcpcmh:nt SpU\lSC milY h,,' elltitled III holh nlimuny pendente Iilc.' mul ullorm,'j' ICl:~ in order Itl Il1lliulain ur d,,'fcnd divon:c pn1\:cL'lling. [II) IlIVORCE ~22.\ 1J.lk223 Trial court did 1101 nhusl.' its L1isl.:n:linn in awarding wife ullorncy fees illld ClIsts in divun.:c action, even Ihuugh she wuuld alsl) receive .Ilimony pCl1dCIIIC lite .lOd S5'}t of l1l.1rilal estate; IlSSCSSlIlclll of fel.'s ilIlll costs ulluwed wife 10 dcl't.'nu herscH' in l1ivon:c lIclinn and effectuated economic justice. [12] IlIVORCt: ~2S2.S(J) 134k252,5(3) Equilable dislributions may inclu~e award to nonpossessing spouse of one half of relllal value of marital residence if marital residence is possessed exclusively by the olher spouse during panics' separalion and divorce procee~ings. 23 Pa,C.S,A, * 3502(a)(7). [IJ] DIVORCE ~252.S(J) 134k252.5(3) Award 10 nonpossessing spouse of one half of relllal value of marilal residence occupied exclusively by lhe other spouse during divorce proceedings is not mandatory, 23 Pa,C.S,A, * 3502(a)(7). [14] DIVORCE ~252.S(J) 134k252.5(3) Fair markel relllal value ui' marilal home occupied by wife should nol have been included in marilal eslale for equilable dimibulion purposes; ralher. husban~ should have been grallled credil tl>r his share of l'oregone fair market relllal value hy deducling his shure of foregone revenues I'rlHll wife's ullim:tlc dislribulion of marital eslale, 23 Pa.C.S,A, * 3502(a)(7). [14] DIVORCE ~2SJ(J) 1J4k253(J) F::lir market rCl1t~tl \'O\luc or Il1l1rit;:t1 hOllll: occupied hy wife should nol h;I\'C been included in marital estate fur equitahle distribution pur(lo:\l's; mther. hushand shout..! have been granted credit I~Jr his sh;irc of foregone fair m;:arkcl renlal value hy dculu:ling llis share of furcgonc revellUl'S from wilt."s ultimalc IJUI:C 5 distrihlltilln llf lI1aril:l1 estate, 23 l'a,C,S.A. * 3502(a)(7). ..MI .S.!.\ Rehecca N, Torlllrid. Yllrk, fllr Carol Bllller. "1It1rew B Brown, Yor~, i'llr LellnBlltler. Belt>re MONTEMlJRO, IFNI I KELLY ami CHlCONE. Jj, rN l. r\hhougll Judge Mnllh..'lIIlltll parlll:lpllll'tJ in Ihe Illiliill dl'l:i'iillll n:lltlcrc:tl 11\ 11I1"i L'a"C,', rc:ClllI,itkraliull Ill' Ih,1I lki:I'iillll \"'11' "iuh'iC{IIll.'lltl)' ~raUll.'l1 h)' Ihc 1"11 rCl11illllill~ p.lnd IIIl:mlxol''''l ,Iflcr JW'IIII':C MtllIIClIIIIW','i ;1"'l'L'lhiulIlu the PCIII1,,)'I...illIl;1 SU(Jn.'IlIC Courl. Thus, JU"Ih:l.' r-.tnllll'IIIUfn Jill 11111 parlh:lpalc in the rt:l,;lIn..hJcr;lllllllllt' IlIb \.:....c. KELL Y, Ju~ge: In this opininn, we arc called upon to determine whcther ti,e lrial courl cnrnmiued error by apportioning the nUlrital lISScIS, including an iU.:counling nrm in which Ihe husband is a shareholder, by lheir value on the hearing dale inslCad of lheir value Oil the scparalion dale when Ihe husband's ownership inleresl in lhe aceourning firm decreased from a one-half interest at thc time of sepamtiun to a one-thinJ interest on the he.uing dute. In addilion, we arc called upon 10 delermine wbether the Irial coun properly ascribed lhe going concern value 10 lhe husban~'s shares in the accounting firm ralher lhan valuing lhem in accordance 10 lhe accounting !irm's shareholders buy-sell agreement, For Ihe reasons 11m follow, we v.eale the order of equitable distribulion and remand l'or arc- delermination eonSiSlenl Wilh the principles Slare~ herein, The relevant faels and procedural hislOry of Ibis case arc as t'ollows. Carol BUller and Leon Butler were married 011 May 10, 1964, In lhe early years of lheir marriage. the wife worked as a school teacher. but later stayed at homc to care for the parties' three children, In 1980, lhe wife re-enlered .SJ4 Ihe job market as a retnil sales clerk and brielly oWlled a gifr shop. Leon Butler is employed as " partner in a l..:ertilicu puhlic accounting linn. In MayoI' 1983. after ninctecn ycars of m;:uri.lge, the partil:s scparmeu, A hricf reconciliation from May III December 198.1 ende~ whell lhc parties finally separated. The wife remained in the marital rcsidcm:c with the couple's children, When the parties were Copr. I', West (1)1)1) Nil Claim hi Orig. U.S. Gu\'1. \Vorks 621 A,2d 6j1) (Clle ll!J: 423 l'u.Super. 530, 0534, 621 A.2d (,Sf), "(,61) divureed by a decree elllered on t'pril 12. 1')M8, Ihe issue of clluitahh: distrihutiun of (he maril;.'1 property remained unn:su)vcu. A clIun'ilPlluinh,:d master Ill'll! hC;lrings alld rCI.:I..'ivl...d c:vidence on maltefs rchllcu In equitable Ji!'itrihulilln. .llimuny pCnUCnll.' lite. illillltll1}', I.:OUlIsL'l fees, ilnd emus. The illlcrim IItjlSh,'r's report of Dl'cL'lI1hcr II. 11)8M recommended lhal lhe wile recelY<' $-IlKI.1Kl per \\leek of ulimony pt.'lldcI1IC lite. retroactive III ~tlY I, 11)88, Evidence pn:sclIlcU before the master shm".cu Ihill ill the lime uf Ihe panics scptlr:alillll. the husband was :l tifty percent oWller in the certified public m,:clHlllting Iinll of Einhorn, BUller alld Gingerich. In 11)86, Ihe finll acquired all addilional partner, reducing lhe husb:lI1d's inleresl in the lirm to one. third, According 10 lhe wilC's expefl, lhe linll had a value of $546,881),00. TIle husband assefled lhal the value of his illleresl in the linn was aelually S2..150.IKI. Ihe sale price of the husband's shares. as determined in the buy/sell agreemenl, TIle master also heard evidence lhal the wite was I'u"e 6 \\orking in retail Silh:s ;.1m) carning a ~fIISS monthly salary III' Sl,lKl8.42 per Illllnth, The wife inlrlllluced Cl,'idl.'llJ.:l.' Ihat hl'r monthl)' expenses iU1l011l1ll'd 10 $I,2J7,lKl. The wife le'lified thaI Illllnelary ao\'anCl.'lIll.'l1t would rcquirl' .111 additional sh 10 Sl.'VI..'h )'cilrs of work 1.'.'pl.'ricl)(.'c. Al Ihc lime III' till' hc:arluH. lhc' parties' y"ungesl child wu' 'lill living in lhe marilal rC'siul'nce with thl.' wifc, lInd Ihe c1dC:f childrC:II, who were :away ul t.:llllcge, would rclUrn In the marital reshlclll:c liming lheir school vw,:atilllls. From Ihc time of Iinal scpar;llioll ill Ol,,'ccmher of 11)8,1 unlil Oewher IIf 1')88, Ihe hu,hand Illainlained the Illalilal residence 05.15 an~ paid child suppurl. During this lillle, "(,(,2 lhe hllshand Illade Ihe Illolllhly Illllrtgage paYlllenls, a. well a. repair hills, insurance, utilities, ano ulher costs ussocil.llcll with the nminlcllilllcC of the m;trital fcsicJcncl', The masler deterlllined thai the 1111:11 value of lhe Illarilal assets was $-1.14,411).25 and reelllllmended that the wile receive fifty. five percent of rIle value of Ihe Illarilal assets. The masler delermined lhal lhe fulluwing were Illarital assets rClained by the husband: 1. 200 East Market Street.. ..., ....,.... ... ......... $107,092.99 2. 1 1/3 interest in Einhorn, Butler and Gingerich... 141,148.16 3. Stocks as follows 140 shares W.L. Morgan ....... ..... 1,558.00 761,86 shares Mellon Bank ..... ,., 20,379.00 44 shares Figgie . ......"."..,.,. 1,903.00 75 shares William Home Products ... 3,023.00 4. Dividends on stocks............,.................... 8,456.00 5. O.K. Corral,....................................... 10,000.00 6. Life insurance.......................,.............. 5,210.00 7. Aut.omobiles Mercedes Az t ec ,............................................ 2:2 I 500 . 00 8. Husband's pension ....... ....... ... ......... ......... 7,800.00 9, Orandfather clock ...,.,.......,'....,.,.....,.,.... 10,000.00 10. Bank accounts Community National,. .,. .,.."..,....'..", ..,.., ...". 44,46 York Federal .,..,....,......"...."..,.,'."...",.. 250.00 York Bank and Trust ..,.,.........,.,."...".,....,... 60.00 11. B.E.G. Associates..,........,..................,........ 0,00 12. Cash Management Account. ........ '.. ,.,..,., ......, $25,120,72 Total $364,545.33 Husband to pay the loan he made to fund "All Tied Up" ..,... 16,000.00 and to pay the Einhorn Est..,.... .. .. .. .. .. .. .. .. .. , .. .. ,.. 141,791. "7 and to pay his loan from Sheldon Lipsity ,....",...",.",...."".,.,..,."".,..." 6,765.00 Total $199.988,66 COpf. c \Vl.'SI I t)l)tJ Nt) Claim 10 Orig. U.S. GnvL \Vorks 621 A,2d 659 (Clle u.~: oI2J l'u.Super. SJO, .SJS, 621 '\.211 6~'), "Ml2) The master .tlso rCCllJllI1lCIU.h:lI Ih;1I the hU.'ih;lIlu "uue 7 shollld lake Ihe ollke hllildillg suhjecl 10 lhe ellclllllhrallce in favor of Ihe York lJallk, In addilion, the master Jctcl'mincu Ihal the wife ouglu to retain lhe following marital assels: 1, 60 Tyler Run Road ......"............,...,........,....,..,.., $15..035,25 2. Fixtureo, furniture, allver-w.lre, c1hltteln ,It 60 Tyler Run Road Inot including the gl'andfilthel' c10ckl ........,........,.. 20.000,00 3 . J ewe 1 ry ",.".,',..,.,",.""",.".""""."."",.",."." 1 3 , 0 0 0 , 0 0 4, Renault ,1utomobile ,.".,"',.."."".",."""""...,.."".., 4,500,00 5. 551.39 ahareD Continental Bilnk .",.", ,", ,.". ,. ,." ,.",..,." 21,996,06 6. 222 shares Drovero Dank CQrporation .............................. 8,880.00 7. Caoh-.Caoh Management account.,. ....,.......... ,................ 32,514.28 9. Stock dividendo......,..,........,..,........,....,....,..,...... 2,272,00 9. Life InDuranee (Penn. National) "."",." ,.", ,. ,.,. ,..,..".". 1,000.00 Total.. $258,187.59 Wife to pay Dauphin Depooit Loan..................,....,........ 13,757.00 "(,6J .SJ6 The maSler alslI recomlllended lhal the wife lake lhe marital residence suhjcctto a Illongage and lhal she pay a $1,000.00 credit card debl. Master's ReJlOrt of 5112/88 ar25-27. Alier delermining that lhe fair remal value of lhe marital home was $1,500,00 per month. the llIaster recommended mal the husband receive a eredil for one half of Ihe fair relllal value for lhe period of May. 1983 until November, 1988. when the wife occupied Ihe home renl-free. In addilion, lhe master further recommended mallhe wile receive $300,00 per week in alimony. Finally, lhe mmter delermined that lhe wife should be awarded counsel lees of $7,500.00 and expenses of $1,750.00. Both the wife and husband liIed exceptions to the master's reporl. On October 2. 1991. lhe lrial court issued ilS opinion and order aflirming mosl of lhe master's recommendations, thereby dismissing the majority of the parties' exceptions. However. the trial t;llurt modi lied lhe master's recommended alimony pendenle lite award of $400.00 per week relroaclive 10 I\lay I. 1988 10 an alimony pendellle lile award of $400,00 per week for the period of l\J,iy 1. 1988 lhrough June 15, 1989 and $300,00 per week for the period of June 16, 1989 lhrough the date of the elllry of lhe trial court's order. The lrial court also direeled lhal Ihe husband pay $300,00 per week in alimony 10 the wife Ii" a period of lilliI' years, The wife tiled lhis timelv appeal and lhe husband liIed a cross.appeal. - Total.. $244,430,59 On appeal. lhe wife raises lhe following issue Ii" our review: .S37 I. THE TRIAL COURT IMPROPERLY DETERMINED THAT THE IIUSBAND OWNED ONE- THIRD OF HIS ACCOUNTING PRACTICE FOR EQUITABLE DISTRIBUTION PURPOSES WHEN HUSBAND OWNS FIFrY PERCENT OF THE PRACTICE FOR EQUITABLE DISTRIBUTION PURPOSES. Wife's Brief at 5. In a cross.appeal, lhe husband raises the following issues for our review: I. DID THE LOWER COURT ERR IN ESTABUSHING HIE VALUE OF THE PROFESSIONAL CORPORATION PARTLY OWNED BY THE HUSBAND, AND PARTICUL,\RLY THE "INTANGIBLE" VALUE OF THE CORPORATION? 2. DID TilE LOWER COURT ERR IN AWARDING COUNSEL FEES TO THE WIFE IN ADDITION TO AWARDING AUMONY PENDENTE UTE TO HIE WIFE? J, DID HIE LOWER COURT ERR BY FINDING THAT TilE HUSBAND WAS DUE A CREDIT FOR ONE-IIALF OF THE FAIR RENTAL VALUE or THE MARITAL RESIDENCE IJETWEEN DECEMIJER, 1984 AND OCTOIJER, 1988 AND TIIEN FMUNG TO INCORPORATE SAID CREDIT INTO TilE FINAL EQUITAIJLE DISTRIBUTION ORDER! lIushand's IIrief nr I, COpT. (' \Vest Jl)tJl) Nll C1ailllltl Orig. U.S. Gtl\'t. \V(lrks 621 A,2d 659 (Cite u.': 423 "a.Super. 530. .537, 6; I '\.2<1659, "M.I) (II The hushillllJ .mtl the wife raise various issues Oil .ll>pc;\1 ,hallcnging the trial cuun's arnrmatiun of lhe m..lstcr'.1 rccommcndillilll1S. Initially. WI.' note lhal our slumhlru of review is a limited one. We m.'ell determine whether the trial court. hy misapplication of lhe law or failure lu fulluw pTllper legal pTl>cedure. ahused ils discreliun, Zullars v, Zullars. 3'J7 Pu,Super. 21~1. 579 ,\,2d 1328 (19'~1). allue, denied. 527 Pa, 603. 589 ,\,2d 693 {IWI); ~Iahe,'d v, Malseed. 388 Pa,Super, 214, 565 ,\,2d ,153 (1')8')1; Johnson v. Juhnson. 365 Pa.Super. .IlN, 521) ,\.1d 1123 (1987). alllle, dellied, 517 Pa, T12J, 538 ,\,2d 877 (19H8L Mnfco\o'cr, "all ahml.' Ill' di'il.:rclioll is 11111 fuund lightly. hut unly upon a showing of drar ami !;ollvim::ing cvidcru.:c." .!JH Zollars, supra, .1tJ7 Pa,Super. al 208. 579 ,\,2d at 1330. qUilling Sergi v, Sergi, 351 Pa,Super, 588. 591. 506 ,Ud 928, 930 (1986), Specitkally, we measure the eireumstauees uf the case am! the coru.:lusions drawn therefrom by the trial euun againsl lhe provision uf 23 Pa,C,S,'\, * 3502('1), [FN21 lInd lhe avowed illlellliolls ..M..! of the Divorce Codc. mUllcly to "effectuate CCllllmnic juslice between [lheJ pllrlies ..' and iosure a fair and jusl delerminalion of their pTllpeTly righls," 23 Pu,C,S,A. * 3102(a)(6), [FN3[ A mllsler's repoTl is enlilled 10 greut consideTliliuns by. bUl is nol binding upon, the Irial courl. Morsehhauser v. Morschhauser. 357 Pa,Super, 339. 349. 516 A.2d 10. 15 (/986) (Cillllions omined), FN2, 23 1',5. * 40t (repealed). The Divorce Cnde, 2) Pa.C.S,A. 9 3LOI Cl seq., replaced the c.,bting cooc. 23 P.S. ~ 101 cl scq. Thus. we will refer IU the seclinn Ilumhcrs under Ihe new cudc. FN3, 23 1',5, ! 102 (rcpcaled), 12J The wife argues lhal lhe lrial COUTl erred in amrming lhe masler's lindings that Ihe husband owned one'lhird of lhe aeeounling pracliee. The wife eOnlends that Ihe lrial couTl misapplied lhe law when ir used the day of Ihe hearing as a benchmark for hoth idenlifying and valuing the marilal assels, The wife argues that the husband's interest in the accounting nrm must be identitied as of the date of separation or distribution because either of those dales \\.'ould provide most adequately for economic juslkc. We agree in part, and we linll that the trial court misapplied Ihe law in looking lU Ihe hearing dale 10 dctcrminc the hushand's shiue of the m:coullling practice. OUf courls distinguish tla.' dale for h.Jcntifying marital property from the do\te hy whkh hI phil':!.' H \'HllIe Oil "alle 8 marital assets for Cl{Uit;lhlc distrihution. Sce Adelstein v, '\delsleill, 381 Pa,Super, 221. 553 ,\,2d 436 1198'!); Sergi v, Sergi, .151 l'a,Super, 588. 506,\,2d 928, 930.31 (1986), The Divuree ('"de mandales Ihe our ~1I11r1S eXilminc thc rank's' properl)' ilS of the uate of tillal ~cparathlll in order to identify which Hssets me marilal propeny, See 23 l'a,C.S,'\, l 3501, In lhe 'iann: vein, this ('ourt has stiltcU lIull Ihe Mlc)xistem:e and nature uf mariwl properlY un: determined liS of Ihe dale of '1.'llilraliol1," .~.l'J ,\dc1slcill. !Iupra, 381 l'a,Super, at 225. 55.1 ,\,2,1 'II ,1.18, ,\lIhough maril:!1 propl.'r1y is hlelllilkd al Ihe dale of M:llilralioll, thl.' \alul.' of lhe PWIH.:rty is dell.'r1uiIlL'd ill Ihl.' datI.' of d"lnhulinll, ildelslein, supra; SUlliff v, SUlliff. 518 Pa, .178, 5.U ,\,2d 5.1.1 (1')88), 131 \Vheu Ihe panies Iinally separaled in Deeemher of 1984. lhe hushand owned a Ulu:.half imerest in lhe uccountillg praclice, At the lime of the master's hearing in Oeluher of 1988, lhe lIeCDunling linn had acquired an addilional parlner (thos reducing lhe hushand's share 10 one-Ihird), lIowever. the dedsive date Oil which to determille which of tile parlies' assets were nmrital assets available for equilable division was the date of Ihe tinal separation. Therefore, on remand. lhe equilable dislribulion seheOle mllst be based on lhe husband's Iifty percelll ownership of Ihe accouming linn of Einhorn. BUller and Gingerich. In his cross-appeal, Ihe husband argues thar the trial court errcd in aflirming the master's conclusion that lhe value or Ihe accoullling lirm was $423.+l0.50. Specilically, the husband comends Ih;1l goodwill W;tS improperly included ill Ihe valuation of the linn and thaI Ihe valuc uf the linn is controlled by lhe buy/sell agreement, \Vc c.1I1nol agree. AUl1linedly. placing a valuation un a spouse's illleresl in a small business is a diflicult task. lIowever, our courts hllve addressed Ihe faclors to be considered, In Buckl v, Buekl, lhis Coun slaled thar inilial consideralion must be givcn to an agreement governing the value of an ownership illlereSI. 373 Pa,Super, 521. 532. 542 A.2d 65, 70 (1988) (en hanel, lIo\\'ever, Ihe Buekl court noted thaI il was mindful lh"l "it is mosl unlikely lhat Ihe agreelllelll will ul.'al with v.llu.lIion of a partncr1s inlerest vis a vis equit<lhlc distributiun upon dissolution of the martial rel:lliOllshi"." and lhal it "muslluuk 'II the relllilies of the situation mid avoid all Unrl.'aliSlic valuation," Id. Thus, olhl.'r factors must he cOllsidereu, namely. "the Itlonelary \I,.'nrth of the professional partnership diminished by lhe anmunt of aCCllunts pnyahlc ... Copr. to Wl.'st It)t)t) No Claillllo Orig. U,S, uovt. \Vorks 621 ",2d 659 (Clle us: 423 !'a.Super. 530, '53'1, 621 A.2d 659, "(,(H) landl any mher liabilities nllt rellected 1111 the partnership bUllks," Id, The '540 Buckl ellurt further slaled that 1Il1.' partllcrship's fI1()lIl'tary worth ..66! \':()I1SiSllsJ of the pllrtlll.'rS' ~apil;1I ;u.;COUllls, aCClJUlUs rc\:d\'ilhlc, the \rHlue of \\ork in progfl.",'i, any apprl'dullon in the Irm,' \\,(}rlh of lilllglhh: PWIk.'rty O\ier ilUll i1hoH.' hOtlk valtu:. together with g..>dwill, ,hlluld lh,'re he allY, Id, This Court hilS dcfilll'd 'l1-\tlodwlll" ,Pi "thl' !'.lvor which the mllnilgement or a 11I1SlIIl'S" llils WllII fwm 1111: public, an" prubahilily Ihal Ill" C'''llIlII''" wIll cUlllinue thdr palrollage." lIuLk!. SlIP"1. al 5.111, 5,12 A,2" al fl'), The !luckl cuurt cllrrcLlly IU'lc" Ihat "the concept of gootlwill b nebulous ill hest ami consequently, Ihe placing or a dollar \'illuillion is IlIl1st dimcull." Iluck!. supra. al 52'). 542 A,2" al 68, We ha\c also dl:scrihcd the considerations in deciding whether to include goodwill in the \'ollul: or a husiness as li,lIows: If the nalUrc of the c\:onomic good will is purely pcrsomll 10 the professional spouse, it is not alienable; hcnce, ir cannol aClually he realize" an" may nO! be indude" intbc equilable "islrihulion, II'. however. a portion of Ihe economic goud will is auributable separUlcly 10 the corpuraliol1 '" busincss ~n" can be realize" by sale 10 another (by selling the enterprise in whole or in pari, buy-in's an" bUY-OUl'S induded). lhen to that eXlent, tltere is good will value subjeClto equitable distribulion, Fexa v, Fexa. 396 Pa.Super. 481, 487. 578 A.2" 1314, 1317 (1990), \Vbclher lhere is goodwill subjeCl 10 equitable dislribulion ultimalely depends upon 1I1e faCls of each particular case. Id. [4J The husban" alleges lhal lhe lrial courl erre" in nnt relying solely on lhe buy-sell agreemenl in placing a value on his interest in the accounting practkc. In sUPPOrl of this argumcm. the husband eires our Supreme COUrl'S "ecision in McCabe v, McCabc. 525 Pa. 25, 575 A,2d 87 (1990), Husban" argues ,hat MeCabc man"ales a valualion base" on the buy-sell agreement alone. '541 In McCabc. supra. our Supreme Court held ,hat Ibis Court properly reman"e" the case to ,he lrial court to rc.dctcrmil1c lhe distribution award based on lhe value of Ihc busban"'s partnership interesl as liste" in the partnership agn:clllcl1t I mlher than the going concern value ascribed by the trial courl. Id. aI 31. 575 ",2" aI 89, Thc Supreme COUrl del ermine" Ihal it would be illcquilahh: 10 apply a going cnnccrn value to the husband's partnership inh.:n,:sl where the going PUJ:C 9 concern value could IICVt:f he n.'aliLcd by the hushaluJ hcc;lu.'il.' the hushand's slliln:s could nul be puhlidy or privalely traded (thus there W.IS 1111 market fllr cSlahlbhing the value of the pilrlllership il1lcfesll, the firm \.:(}(lld lIot he .'\olJ Ilf li1luidall:J at a partner's lJin:L'lion, anti, under the parlllL'rship Hgn:L'I11CltI, 1I parlner cOlIlJ nut: relllme fWIlI 1111: lirlll II prupClrlitln.t1c share uf the llL'Cllllllls n..'ct,'iv ilhlL', \\'()rk- in.pnlgn:s"i m:ClIlllll.lJ, or 11I11I:r ;1l:COllIII.'i inclulled In the 'going concern' value (;1 .., retchc it prOpOrlilllliltL' shan: uf the linll's lolill \'"hlL', illduding e1luiplllelll, i1Cl.'lIlJllls fn'l'jvahlL', ell,:; ." ~dl his illh..'re,'it 10 i111t1ther individual: '" IlIrl rClin' from Ihe firm ;lIld cllluinuc hI rl'cl'i\L' a ,11iIfC of tl1(.' linn's prolllS. hI. Thc hu,hand argues lhal McCahe is ",elually HlHllngous to the l.'i1'l' .It hand and mawJ:ues that the Iriall.'llurt valul.' his illll.'rcsI in the accounting practice al $2.4~O,tX), as lixe" t,y lhc buy-sell agrcemelll entered itllo by lhe hushand an" his fellow sharcholucr, We Uti nllt agree. The faels in McCabe arc dislinguishable in "everal respects. First. Ihc husban" iu McCabe was one of many parrners in a largc law firm. 525 Pa, at 28, 575 A,2" at 88. Hcre, the husband was one of' lwo shareholders at the lime of Ihe parties' final separalinn, Secon". the parrnership agreemelll in McCabe limile" the parrner's recovery upon leaving the firm 10 bis share of lhe capilal aceOUIll. less in"ebtedness 10 the firm an" his share of undislribute" profits, i".. an" provi"ed lilal the same sum was payable upon the death of a parlner. Id. al n, I. flere. lhc buy-scll agreemelll sped lies lbat upon lerlllinalion of' employmenl or "isabililY, the company '542 waul" purchase the husban"'s sbares for $10.00 cacho or a IOlal of $2,450.00, However. "6<.6 in thc cl'elll lhe busballd "ied owning shares, the company woul" purchase lhem for $100.000.00. Tbus, in contrast to ~IcC3hc. the agreemcnt here tJocs not give a dear valu.ltion for the husband's illlCreSI. In Bcasley V. beasley, 3~9 Pa,Super. 20. 518 A.2d 545 (1986), Ihis Coun condu"e" that a sole proprielorship "id nol have goo"will for equilable "istribution, The Beasley court sla'ed: lal sole proprielorship can be "islinguishe" from a partl1crship, or a profcssiolltll l.'Orpllri.uiol1, to which :111 :lscertainahle value com he ast.:riheu for the purpose of huying into Of withdrawlIlg from the rclilliollship; hut it is the associatillll, or slime share of ii, lhal is valued HIIU not the individual p:lnller Copr. {' We't I~'N No Claim 10 Orig, lJ,S, GOI'1. Works 621 A,2d 659 (Clle...<: 423 ('u.Super. 530. '542, (.21 '\.2<1 (,59, "(i6(, upon whil.:h Ihe \';lllIe is ptu.:cd. See Gccshrq~ht ..... G~eshreglll, 570 S,W,2d -127 (T~"Civ,'\pp,I'i781. Till': prodm.:ti\.ity llr work effort of the partlll:r j" often not the measure uf thL.' shim.' )lllsscsscd hy variuus mcmhcrs of the asso..:iatiol1. That '1harc is a mCHsurahlc und m:arkctahh..' l:OllullllcJity and b g~nerally d~r.n~d hy culllrac!. Wh~n a sule propriclOr terminalI.'"' his w.:livil}'. the Iiglu.s gtl '1111. (he value (If the sllle propril'lt1rslup is c:\lingublu,.'ll ,lIld i~ llllll.trilllsfcrahh:; the chellis in (he lilW firm 1.:.1111101 he sold. thc~ l.::Ul only he trallsfl'rrL'lI and Ihl.'Y Imvc the i1hSllhllC flghl It) sch:d Ihcir 1\\1.:11 hllml' rcprcsclllalion: nothing rCl1mins in n:siduc \\ hh.:h l.:uuld be determined III' value ;aside from lallgihlc physkal property. ur wurk perf,IfIllcd ull partially cumpleted caSC~i. whkh milY elllillc 1111.' lawYc"r or hb heirs to Il tlUamuml11cruil pilymen!. Id, 359 Pa,Super. 'II 35. 518 ",2d at5~!, Thcr~, Ih~ hushand. a sule proprietor. illone generated husiness, Th~ cliem, patronil~d the hushand. 1101 Ihe nrm, Thus, goodwill was nlll includ~d in Ihe eljUilahle dislributiulI of marilalp"'peny, Similarly. ill D~Masi v, DeMasi. 366 Pa,Snper, 19, 530 A,2d 871 (1987). thi, Coun did nlll illclude goodwill when valuing :. SptlUSC'S business for ~quilahle disrribution. Th~re, a' in Beilsley, lh~ cnurl ~onsid~r~d the hushand, a medical dllclOr with a ,pedalty in rheumatology. 10 be a sole practililln~r. The DeMasi coun reason~d Iltat b~~aus~ Ihe husband did not '543 share c1i~lIls wilh his partn~r. the goodwill of the hushand's praclice was m~rc\y personal and had no "pr~sclll value" (0 be dislribuled, Id. at +1-015,530 A,2d a188.J. On !he orher hand. lllis Court has d~lermined llta! goodwill ought to be illcluded in th~ value of a spouse's business, In F~'a, supra, we cnnelud~dlhal Ihc value of th~ hush,md's illl~resl in a d~lIlalpra~tice ~olllain~d goodwill subject 10 equitable dislrihUlion. There, w~ 1I0led thai ahhough Ihe d~lIlal praclice experienced several changes in its panm:rship mak~up, [tJIlt: form of the business :md its \"'mk cot1linued unchanged. ..' llter~hy demonstrating Ihal lh~ good will of ,h~ c1iems of the husiness IOwardlh~ busin~ss was not tied cxclusivcly to the pn'sclH':C or skills uf particular individuals but W<lS tied to some extc,'nt 10 lite servic~ lhal could he pro\'id~d hy any of a numher or delllists.... The gt10U will was capahle uf being v.tllled for the purpose of huying into or withdrawing frnmlhe partnership ibelf. making II an assct It) lhe husiness, ralhcr Ihan :1 purely personal asset. ('u~e 10 Fe".. supra, 3'i1> l'a,SIlp~r, al .189. 578 ",2d al 1.l18, 1511nslamly, we find Ihal th~ gouuw.1I \'alu~ 01 t11~ ;Il,,:coUllling firm of Einhorn, BUller, .1I1J Gingerich is a husil1l.:ss assel suhjCL:l Itl c.'ljuilahle dblrilmtion. ,\ close ,crulin)' of tit"" rCL:llHl rc\.'e;tls Ihill the facls in lhis case an.' more similar to FC,',.1 th.1l1 to Beasley ilJ1d Ilc~la", II~", II", hushand's f,"her ~slahlish~<I th~ .1\':l.:ounlill~ prill.:lic.'e, mltl Ihe hushalld jllint.'d Ihe liflll :liter ~rj\lIu;alin~ from c"lllli,.'gc. Fllllnwinf.( Ihe hush;llId's f;i1hcr's llcalh, il Itunl shilreholdl.'r C:lmL' Illllllh~ Iirm an<l was suhseljUenlly hllnghllllll, y~llh~ linn slill rl'lIlilined. Iherchlre, the hushill1\I's pral.:tke Cilllllot he I.'llU;ltctl with a stile proprietorship ilS in Beasl~y and ()~/.lasi. Morelller. the Itnsh,m<l himself aClluircd dil.'l1ls from his father, w:lrralllil1lt all inferelll:l.' Ihat the dients h:ld SOllie loyalty 10 the linn ralher 111iI1l a partiL:ular acclllmtilnl's skills. "(11.7 Th~ hushand n~'1 raises lh~ issu~ of whelh~r lhe trial court may award hOlh alimony {lend~nte lil~ and counsel fees :ll1d t.:osls. The hush~Ulu '{lnlends lhm Ih~ trial court erred in awarding lh~ \\'if~ tiny. tiv~ p~rc~lll of lh~ marilal asselS, '5+1111gelher Wilh alimony pend~lll~ lile. and couns~1 fc~s, We cannol agree, The rel.:ommendalions of the masler in a divorce pro"e~ding. although ~Illir\cd 10 careful consideralion, arc advisory only; Ihe trial court is required 10 review the master's reporl, del~rmine if his or her reconunemlations arc appropriate. and enter a tinal decr~e, Reed v, R~ed, 3501 Pa,Super. 284, 511 A.2d 8701 (1986). However. Ihe del~rminalion of th~ amount of alimony pendellle lil~ warrallled rem in !he tirst instance on the Irial cuurt' s exercise of sound discretion, absent an abuse of discretion. a trial court's award of alimony pendenle Iil~ will not DC disturh~d. Miller v, Mill~r. 352 l'a,Supcr. 0132. 508 ",2d 550 (1986). 161171 Th~ purpose of alimony pcnd~lll~ lile is to sustain the dependent spouse on an equill basis with 11t~ olh~r spous~ while h~ or sh~ ll1ainlaills or defellds a divorce action. Krakovsky v. Krakovsky, 400 "a,Super. 260.583 A,2d 485 (1990), The simple facl that 0111.' spousc carns lI10rc than the other spousc docs nnt automatically entitle the other spouse tn alimony pcnuel1lc,' lite. Rather. Ihe spousc sl.'cking alimony pendcntc lite musl nl.:cd SUl.:h relief to adequately lIcfcnu his nr her ri&hls in the prindpill Iilig:llioll, SUlliff \" SUllilf, 326 l'a,Sop~r, 01%. 47,1 '\,2<1 599 ( 198.1), Copr. " W~SI I")')') Nu Claim to Orig, U,S, Ciml. Works 621 A.2~ 659 (Cite 11.,; oI23I'u.Super. 530, .S+I, 621 ,\.2d 65'), "(,(17) 181 luslanrly. the lrial coun reviewed Ihe master's rCl.:U1umCndaliul1s thai the wife receive alimony pen~enre lite and wncu"ed Wilh the reporl. The lrial cuurt weighed the rclcvuI\t fill.:!mS necessary 10 uclcTminc an awaru of alimony pendellte lite ami dCh.'rl11inl.'u that the wire WilS c:ntith:,) 10 alimony pcndcl\Il: iiiI.'. Our review "I' thl.' n:conl rl'veals that there \\'as u great displlrity hClwcCI1 the income 1cwls of the panies, with the hnshaml enjoying a suhslululally hiltlll:r im.:lll11c. Also. the n:ctlul ~htlws thai Ihe wife resorted to selling. 11I.:r jl.'wl.'lry hI 1I1.linlilin the divnn':L' prm:cc,lil1gs. I\cctlnlingly, \\'1,.' lind amp"': c\'idcm:c ill the rcnmlltl support the trial c.;uun's Iinding Ihilt the wife \VilS entitled to alimon)' pen~enle Iile. .SoIS 1911101 The purp",e of an awanlof counsd kes is III ensure dUll the financially dcpcmh:1ll spouse ,..'ill be able In mainHlin or defcnd ug:ainst .Ul iu.:tion for lIivon.:e, as well as tn effcctmlle eCOIuJlllic justicc. Schuberl v, ~chuberl, 398 Pa.Super, 28,1. 580 A.2~ 1351 (1990), Counsd fees in a ~ivoree proceeding arc not awarded automatically; the petitioning spouse must show aClllal nee~ before soch an award is justilie~, Kohl v, Kohl, 387 Pa.Super, 367, 56-1 A.2~ 222 (1989), Moreover, a "~epen~ent spouse may he emilled to alimony pendente lite an~ counsd fees bocause both are necessary 10 maintain the divorce procee~ing," DeMasi, supra at 530 A,2d at 88J. The amount of ;.\11 award for counsel fees, costs, ilnd expenses awarded in a divorce action is within the discretion of lbe lrial court and is subjeet to an abuse of discretion slandar~ on appeal. Williamson v, Williamson. 402 Pa,Super, 276. 586 A,2d 967 (1991). [IIJ Here, the trial courl a~opted the masler's recommendations thaI, due to the greal disparity in lhe parties incomes, the wife was entitled to have the husband pay a portion of her counsd fees and coslS, Simply beeause lbe wifc will reedve alimony pen~eme lile an~ lifly-live percent of the marital estate ~ues not predu~e an award 01 counsd fees an~ costs. Our review of the record reveals thm Ihe assessment of the wife's counsel fees and costs to the hushan~ allows the wife to defell~ hersell' in lhis divorce action and effectuates economic justice. Accor~ingly. we lind no abuse of diserelioll ill Ihe trial court's adoption of the muster's recollullemJ:atillll thaI the hushand be "'~ere~ 10 pay a pOri ion of Ihe wife's counsel fees and COSts. Finally, the hush:md asserts Ihat the trial court impmpt.'rly credited him with the fair rental valuc Ill' I'u~e II thl.' marilal rcsidcltcL'. The hushand nrgucs tlHIt the trial court erred in including the fair rent.11 villue of Ihe marilal residence. S301,500,(X}, in the ..668 marital e~tate, then crcLliling the wife ilS Imving rel.:ch'cd h....r ~hare tlf the fair rental vOIlue. \Vc ;Igrcc. 1121 A court eugilge,1 iu e'luitahly dislributiug lhe marital e~tilte l1Iust consider the erforts c:lch spouse ..."p....mh:lI 10 .~4(. pn:~er\'e lI1arital assets. Sec 23 1'i1,C.S,A, ~ .1502(:1)(7), Thus. au elJuilahle di'ilriluuiun SdlCIllL' mOlY include UIl ~1\\'arLl, to the non. ptlsses~ill1t SptlllSl', of onc-half of the rentul vuluc of Ihe marital resideuce, when possessed exclusively by the lither spuusc during the (Hlnies' scpar:l1iol1. I'owcll v, Powell. 395 Pa,Super. 3015. 577 A,2d 5i6 (l91){)); Gruver v. Gruver. 372 l'a,Super, 1901, 200, 5.19 A,2~ 395, 398 (1988): IIUIUik v. lIulllik. 369 PiI,Super, 263, 270. 535 A.2d 151, 154 (1987): Gee v, Gee. 314 Pa,Super. 31. .160 A.2d 358 (1983), IIm,,"ver, we have also uphold deduclious from relllal v<lllle av,:ards for: Ihe nun-possessing spausc's share of expenses re)atetllo preserving the marit:11 residence (i.e. morlgage, insurance, laxes, maintenance), see Powdl; lIutnik: Gee, and for amoums owed by the non-possessing spouse 10 the possessing spouse's parents, See Gruver, supra, 372 Pa.Super. at 200, 539 A.2d "I 398. (131 While we have aflirmed the lrial eourl's :lwarding one spouse u portion of the rental valuc of the maritul home. when possessed exclusively by lhe olher spouse, an award of rem is nOlmandatory. In Sutliff v. Sutliff, supra, we aflirmed an equitable distribution schemo which lacked an award for rom I'lt the non-possessing spouse. 361 Pa.Super. 5lJ.l, 522 A.2d 11401 (1987), reversed on other grounds, 518 Pa. 378. 543 A.2d 534 (1988). See also King v. King. 332 Pa,Super. 526. 481 A,2d 913 (1984). In declining to mandate such a pnlctice. we stated in Sutliff Ihal; 'allthough an award of rent is permissible. we dUIlOl t1eem it un ahuse uf discretion by the court to refuse to take such un actiun in this casc.... \Ve cvuluate the court's ~ecision iu light of the IOlality of lhe drcumstances an~ the equitable distribUlion order as a wholL'. 361 Pa.Super. at 525, 522 A.2d at 1154, Likewise, in Powdl, supra. we st:\led; "(iln the trial court's diseretion. he Ithe nOIl-pnssessor spousel may be cntitled to a portion of the fair market rental vulue of Ihe marital home." 395 Pa,Super, al 361.577 A.2d:\l 58.1 (emphasis udlJcd). This is cunsislent wilh nur opinioo in lIutnik, supra, where we held thaI lhe ~pOll:jC who is uul of possession lUust he compens:ltelJ Copr, " \Vest I'}')') Nil Claim 10 Orig, U,S, Gov\. Works 621 A.2d 659 (Clle us: 423 J'u.Super. 530, .547, 621 A.2d 659, ..66H) for his or her .547 rigllls and inlerests in lhe marilal properly, and Ihal an award of fair markel rental value of the marital resident;c, while in 1111..' ex.clusive possession of the otlll:r spouse. w;\s one proper means of compensating the IltHl.posscssur. See also Gce, supra (renlal payments, lhough 11111 specilieally n:qucslcLl, cnJ11)lcnsmcd lhe 11011~pOSscssur spouse for righls and interest inland and nol ahuse of discretion). 114) /Iere, lhe hnshand lenthe marilal residence and lhe wife remained in Ihe home wilh Ihe wuple's youngest child and lheir older children. who would return (() the mnrilill home 1111 school vlIciuions. Although he was not in possession of lite mariwl residence, the husband preserved Ihe marital residence by paying the mOrlgage paymellls. insurance. bills and ulilities from lhe lime of separalion until Ocwber, 1988. The lrial courr included the fair markel rental value of the marital residence as nn asset in the marilal eslale. Having included the fair markel rental value intbe marilal estate. the Irial eourlthen erediled Ihe wife as bavlng received her one-half of Ihe rental value, We lind Ihe methodology employed by lhe trial court of adding in lhe entire fair markel rental value into the marilal eslale as a marital assel before lhe division of the marital estate. lhen multiplying lhe emire marital eSlale by wife's liny-live percelll share and graming the husband a eredll from this ligure of one. half the fair markel value of rhe marilal home 10 be incorreCI for the following reasons. The fair markel relllal value of lhe marilal residence eannol be considered a marital assel subjecl 10 equitable distribution as it repre5ems revenues Ihal were foregone by the marilal estale due 10 the wife's residence in the properlY afler lhe parlies separated. Therefore, Ihe fair markel remal value of lhe marilal home was improperly "669 deemed a marital assel by the Irial court. lhereby arliliclally inl1ating lhe value of lhe marital eslalC. As Ihe wife's share of lhese foregone potemial revenues, whkh would have been part of the aggregate nmrita) estate, were consumed during her tenure in the marital home; she l'UAe 12 is nol entitled to receive ;;any portion of these foregone revenues, Aewrdingly, lbe plllper melhodolugy li>r .54H granling lhe hushand a eredll fur his share of the foregone fair market fClllal value of the m.lritill residcm.:c is In dedw,,:t his ~hare of the foregone revcnucs from the wife's ultimilte distrihution of the marilill estatc. In mltlition. wc ntlle Ihal Ihc trinl eoun incurreclly cilh.:ulaled the f;lir rCIlI:!1 \'ulue hased on rurty.t\\'O nlillllhs, The hu,ha11l1 Iinancially mainlainell lhe marital resilience while Ihe wife enjoyed exclusive !ll)sscsshll1 1(lr l()rty.sc\'ell I1lllllths, IUIt forty-two m(lIl1hs. Thus, Ihe trial coon should have used the forty-scvcn month Iigure in its cah.:uli\tion uf the fair rentill vHlue of the marilill home. lu lighl of nor determination thatlhe lrial eoun erred by using the hearing dale in its valualion of Ihe hushand's husiness ralher than the date of separalion, and both ils improper inclusion of the fair markel remal value of lhe marilal home inlo the marital estate and its failure to calculate the fair markel renlal of lhe marital home based upon lhe forry-seven months thaI the wife exclusively possessed it. lhe order of equilable dislribulion must be vaealcd and Ihe mailer is remanded for fUrlher proceedings. Addllionally, as the Irial coun's usage of Ihe separation dalC for the valualinn of the husband's business will subslantially change lhe economic posilions of lhe panics and upsel the original carefully era lied scheme of Ihe trial coun's order concerning alimony pendcnle Iile, counsel fees and cOSIS, Ihe dislribution of rhe marilal estate, ilml the wife's alimony award, we arc constrained to vacate entirely the trial court's onJ~r and rcmand lhe case for proceedings eonsislclll wilh this opinion. so that economic justice between the parties may he achieved. Order vaealed and remanded. relinquished, Jurisdielion END OF DOCUMENT Copr. I" Wf:~1 JI)l)I) r\ll (,(;dlll hi Ori!L U,S. Cill\'1. \\'lIcks 6,16 Po. 62~ ATLANTIC REPORTEIl, 2d SERIES on dalll that would otherwise he consid. ered slllle," Sutliff'" Sut/if/. 518 Po. at 38, 54:1 A,2d at 536, Thus. we (jnd the December :U, 1987 ralue to be more ap- propriate in this particular case, BerulOn {, ,i81 A.2d 967 (Table). Benaon { was Ciled on Aug"Kt 8, 1990. remanding the case to the trial court (or proceedings consistent with ita holding, On August 10, 1990, the trial court remand. ed the matter to the master (or red'Ktrib. ution and ordered the parties to submit a valuation of M & D as of August 10, 1990, Neither party complied with the order and on August 19. 1991, the trial court entered an order adopting the master's recommen. dation that the court reinsbte ita original order, again valuing the business as of the date of separation. The master reasoned that since Dean was the sole proprietor of M & D Truck Lines and had the ability to direetly control the business's assets, the date of separation better worked economie justice between the parties. Dean filed exceptions to the new order, claiming that the trial court was obliged to follow the Superior Court's order in Benson I and value the business as of 1987, His excep. tions were denied on March 3, 1992. [1.2) In ita opinion supporting ita denial of Dean's exeeptions, the trial court cites McNaughton, supra, for the proposition that the trial judge has diGcretion to ehoose valuation dates of marital ass eta in sueh a way that will work justice between the parties. McNaughton held that it was not an abuse of discretion for a trial judge to value, as of the date of s.paration, a elose. Iy held bu.iness which is largely under the eontrol o( one spouse to the exclusion o( the other. A (amlly business warranta a deviation (rom the Keneml rule that asseta should be valued U8 o( tbe date of diKtribu. tion because o( the Kreat innuellce that the controllillg spouse may huvo upon tho busi. ness's aKKl!ta, .lfCNIIUghtclII at 41:1, 60:1 A,2d at 1;411, Wo hold thut whilo a trial court may nut .r1menllly be excu,lwd erom eomplyinK with 1111 ardor (rom tho Ilppollate court, tht! triut judl{c's e{(orl to comply with tlw l)rdl~r and tlw e41uitahlu nuluro lIt the Vivort'l! Cllllt~ wurrnlll uJlJllkuliulI of ,1(cNllughton in this case, The trial jUdi did not abuse his diKcrotion in valuinK ~II. o us of the date the purties separated. W. there(o:-I! affirm the trial court's order. We recoKnizo that Kenerally a trial cour may not rail to rollow an order rrom tho appollaw court. In Hllcftle t'. Davi3. :lE( Pa. 94, 110 A.2d 233 (1955), uppellant ar gued thut tho triul court erred whea it refused to hear "additional evidence" thaI supported his contention that the lower court lackod 8ubjeet muller jurisdiction. In an earlier appeal in the 8ame case, the Supreme Court held that appellant did Oat meet his burden in eSlllblishing that the lower court lacked jurisdictiun. On sub... quent appeal to the Supreme Court, appel. lant urgued that sinco subject mailer juris. diction cannot be waived, the lower court erred in refusing to permit him to introduce the "additional evidence" after the flnt remand. The Supreme Court sbted: Here the question o( jurisdietion was raised in this Court and determined. A lower court is without power to modif}', alter, amend. set aside, or in any manner disturb or depart (rom the judgment of the reviewing court as to any matrer decided on appeal. Under any other rule, litigation would never cease and finality and respect (or orderly processes of law would be overcome by chaos and con. tempt. One trial o( an issue is enough. {d. at 95, 110 A.2d at 235 (dbtions omit. ted); see also. Stymiller t'. Blleeanli, 236 Pa,Super, 211, 344 A.2d 680 (1975); Pa. R.A,P. Rule 259I(n). In this case. tho Benson I panel consid. ered the argumenta made by both parties and determined that the trial judge abused his di8cretion by valuing the business on tho dato o( sepumlion. However, the B'n. 6011 { parwl, in ("d.ring the trial court tD valuo M & /J on th. dat. clooe8t to the date ol distribution, t.1xprvlIKed It..s preference tor th. 1087 valuution, tho most recent valua. liun lw{ure it. Since the CBSl! was not r.,"lInd.<I until (mil), the trial court proper' ly ordered tlJlI parULis to tilt! current valuA' tions, A lrilll court l{en.rally eannot be rllult..d (or ,"o'<linl{ un order dcoil{ned tD irnlllt'llll'nt thl' al'lll'lIuw court's dL'cision. DENSON Y. liENS ON ell. AI 'l4 A.Jd .... (PLSUpet. I"JI S.. lacoponi v. Pliska, 419 Po. 398. 214 by the discriminatinK exercise or judicial A.2d 504 (1966) (trial court may creaw an power. onter which is within the scope of an appel. Burke I'. Pi/I.tburgh /.imcs/one Corp" 376 late court's order). When neilher Dean nor Pa. 390, 393, 100 A,2d 696, 598 (1953), Joann~ responded to, the trial court's orde~, We find that the equilable considerations the trIal court was In the uneavlable POSI' , ' f 'lh I' th b' 'f of McNaughton Rhould apply to thIS case. tion 0 el er YO umg e USlneS8 In ruB" I... tra" f B I (b I' th b . McNaughton s prem..e IS the SImple propo- ...on 0 enson y va ulng e USI. . . . . th d t f t') I"t sltlon that whea one spouse main tams con. ness on e a e 0 separa Ion or va umg I . in f strat' f th D' C d (b trol over the assets of a closely held busl' ru Ion 0 e Ivorce 0 e y us- . . . '-1 I t' ) S' ""./ ness to the exclaslOn or the other, lhere IS 109 a R~ e va ua Ion. mce ",cHaug" on d" 'b'l' h h was decided before the trial judge ruled on a Istmct pOSSI II~y t at t e spouse, may Dean's exceptions to valuing the business exert that coatrol !n a.n effort to gam fa. as of the date of separation we can h dl vorable treatment m dIvorce court. Thus, , ar Y. h . . 't i t b f fault him for reRolving his dilemma by rely- m sue a SItuatIon, I s no an a use 0 ing on it. discretion to deviate from the general valu. . ation rules. To require the excluded (3,41 Moreover" we note that smce the spouse to show actual proof of his or her B.naon I panel deCIded that M & D should spouse's improper finagling, as the B.nson be ~alued ~n ~ da~ closest to lhe date of I panel would, defies McNaugh/on's prem- eqUItable dIstributIon, w~, ~ould no~alJy ise. Thus, we would be working a paten- be ~.recluded from "revlslt.mg the. ~ssue. tial injustice to Joanne under the pretense The law of the case doctrine prohIbIts an 01 protecting finslity sppellate court from revisiting an issue . . '. that has been decided in an earlier appeal The DIvorce Cod~ seeks ~ attam a lair in the same case between the same parties. result lor both partIes ~ a. dIvorce. Here, lYra Indus/n'es v. Wood, 418 Pa,Super. the master and th. trial Judge, whJ are 296, 614 A.2d 279 (1992). However, Our best situated to lormulate an e'luitable dis. Supreme Court has indicated that the law tribution scheme, have twice held that a of the case doctrine does not have absolute more fair result would be achieved by valu. preclusive effect: ing M & D Truck Lines at the date the The doctrine of "the law of the case" is parties separated. This is the precise sce- that, when an appellate court has consid- nario sanctioned by, A/cNaugh/on. . To ig. ered and decided a question submitted to nore !rlcNaugh/on m favor of an Illusory it upon appeal, it will not, upon a subse- interest in finality (the case has already quent appeal on another phase of the been in the courts for yea.. beyond what caae, reverse its previous ruling even should be necessary to fashion an e'luitnble though convinced it was erroneous, This distribution), would be anomalous. rule has been adopted and frequentiy Judgmenl affirmed. applied in our own Stnte, It is not, how. ever, Inflexible. It does not have the finality of the doctrine of rts judicata, "The prior ruling may have been fol- lowed as the law of lhe case butlhere is · difference between such adherence and ..." judicata; one directs discretion, and the other supercedes it and compels jUdg. ment. In other wonls, in one it is a question of power, in the other or sub. miaslon." The rule of the "law or the casell is one larKely DC convenience and public policy, both of which ore served hy liability in judicial decision., and it mUDt be accommodated to the needs or justice Pa. 6.&7 Concurring stntement by WIEAND, J. WIEAND, Judge, concurring: I concur. The date of seporntion, in my judgment, was lhe date contemplated by the legislature for the evaluotion or mariUlI IlSI:H!ts in divorce IIctions. See: 23 Pa.C,S. f 3501(n), This is purticularly so in cases whert! one sJlouse owns and operates n business. The other sJlouse should ncitllt~r benerit from nor be prejudiced by lhe indi. vidual activity of the business.operotinK spouse after separntiun. To lu.!rmit the volup of Uw business tn he inCfl'UHl'd or fJ n ~ (/I " 0 '" ~ 14 . Q ~ . < < " ~ z .. . -r: ... 0: = ~ < 5 ~ ;; -l M )0 )0 " 0 ~ ... '" ~ " ~ ~ ~ 14 0: d '" ;.J 0 ;:: .: ll. :r. ~ . 0 .j < < . ~ rn " " 0 " 7- '" .. EXHIBIT A - MARITAL PROPERTY DATE OF MARITAL AMOUNT OF ASSET VALUE VALUATION PORTION LIENS LIEN Double-Wide mobile $25,000.00 6/98 100% Purchase $14,000.00 home situate at 21 (est'd) loan (approx.1 Mountsinview Terrace, owed to Newville, PA PNC Bank, N.A. Husband's stock in Rose Unknown but 4/96 100% as None N/A Metal Systems, Inc. believed to be of that (15% of total stock less than date outstanding) $5,000.00 Husband's IRA with $60,983.22 3/31/98 100% None N/A Legg Mason Wood and Walker, Inc. Wife's retirement $22,657.53 9/30/96 100% None NIA benefits (Husband plus earnings believes this is an after date of account with T1AA- separation CREF) Two cemetary lots Unknown 6/98 100% None N/A Cash proceeds from sale $6,805.32 12/96 100% None N/A of Husband's interest in hunting cabin Savings account at $377.00 4/96 100% None N/A Members First Federal Credit Union Wife's 1993 Chevrolet Unknown 4/96 100% None N/A Corsica automobile 1996 Hahn Fire Truck $10,000.00 4/96 Unknown None N/A at this time Household furnishings $5,000.00 4/96 100% None N/A and appliances . c.;ulIl.ot uUfllhv' OMU NQ, 1546.0008 b ElllplOV"', ldenUhcauon flUItlbM 25-1'/55542 D lmporet'. nam.. Idd,..., "'" liP cod. RODe Metal Syotems, Inc. 1412 Trindle Road, Suite E Carlisle, ~A 17013 d fmpklV.... aoc:laJ HCUflly number 20B-42-695B . EmpklV"" nama, .dd'..., Ind ZIP cod. Cloyd A. Barrick Jr. 6 Mountain View Drive Mt.llo11ySpringe, PA 17065 II IlaI, Emplov.,'. .111. 1.0. No. 17 1IIf, ...... lit.. tic. . .~~..I..~.~.~.~.?.?. ~.~ ..........., ....~.~.~.~~.:.~. ~ W-2 Wage and Tall Statement 1997 INFORMATION RE1'URN For Slate CII or Em 10 er File Co 0 WtOI.. IIpI. au. tompIflllUon a fld.,lllncom. t.. wlthhlAd 39350.0B 5571.33 . Boclll 'Kurllv ..~. 4 Social 'tcUfU,;, 'I. .llhh.1d 393 O.OB 2439.94 8 M.diCI,. .10" and IIpI I MedIC.... 'I' wllhhl6d 39350.0B 570.71 , Social IICUIU,;, lipl . AIlor:lltd lip. 0.00 I AdvAne. Ele pavm.nl 10 Dependtnl call benehl. 0.00 11 Nonqullili.d plan. 12 Bln"il' included In bo. 1 13 S.. 1n,1l.. 'Of FOfm W.2 14 Othlr $10.00 0Pl' 15SIjllJtory DcuUN ""'101I LtG" 'mpIo}u ~ It, ".... .... Od'lItd COIIIft"'...,. 11 SUI, Income III 1101.6 11 Loc.IiIV f\atM 20 loul wlft. I.... lie 39350.0 21l.._"""u. 393.7 ............... .................... .................. o.pll1m.nl of thl T"..ury-Int.,,,., R....enue Semel for Plp.twO'''' n.ductlon Acl Nallel, ,.. l'p"I'e InlltucUonl. '. Exhibit f) . Conlla' number Cap, C 'or .UPLOY.... "_CORD. IS.. ~lC. On PAC" 04 COII'Y'1 or O,,"INu n<tsOOOG Cap.. :110 ho Flied Wllh Elllflloyoo', Slnlo, elly or loc"" IlIcome fila Allum - . WIO'I. lip., oIher tOIll*l..hon 2 htJI.lllotom. II. wllhhlkJ 915.00 b EII1pkJYIf" 6denllllClllon number 25-1755542 a EmpIo)'tf" nam.. ....dr.... and liP code ROSE Mm'1\L SYS'l'EMS, INC. 1412 TRINOIE RanO, SUI~~ E ClIRLISLE P1I 17013 d Employ..', .~I" 'ecUftly w'.mbll 208-42-6958 , Emp60v,,', "~, addl.... 8nd liP cod. CIDYD 11. DARRICK JR. 6 mum'1IIN VIEW DRIVE Mr. IIOLLYSPRINGS P1I 17065 .1 ..... EII1ptQy.,'. ,'11. 1.0, No, ,..~.~..l...) ),7.rm~.... ........ 17 Itllt .1011. IIpUk I W.2 Wage and Tn Statement 1997 3 Soc"l 'OCUllt., WIO" 4 SocIaJ MCUllly II. wIU-.h,kJ 915.00 I Mldk". wig.. 'I'd Up. I M~k;.,. lu wllhheld 915.00 I Social 'OGUllly Up, I .Alkx:lltd lip. I AdYlnCI EIC Ply",'", 10 o.pmdenl CIII b~llII, 11 NonqUIUllld plan. 12 Oln,llll Includ,d In boll 1 915.00 13 5" In'lIl. 101 boll 13 14 0111., "SlallolIGly Otmud PlltUOft l'V. tnlplor" plln '" H.... ."" O.I,"M COIf\9fnu11Olll ,. $1,1. Incoml lu 111 LOCalilV NmI 20 hul w,o...I.... tiC ...................?J.!?,!!9...... 21 hullft(omtlh OIptl1mlnl 01 the Tllnury-Inlemll A'YIf'RJI SIMeI ThI.lnlotmlllOt'l II btlna lurnlthld 10 an. tnl,mll AlYlr1U41 S,rvlct. II 'tOll If. llqu1f.d to fll., I'. IIluI!'Z . n.Olrg,nc. p.".lly Dr DIIl.r ..nctlon m.V bllmpolld on VUU If Ihl. IncDmlI.I..... and yuu lallD report II. . EXPENSE STATEMENT WORKSHEET Please complete this document as best you can using the monthly expense column. The columns headed "week" and "year" should only be used to calculate the average monthly expenses. Please list the average monthly expense for each item. EXPENSE WEEK MONTH YEAR HOME Mortgage/Rent $ $682.51 $ Maintenance $ $ $ Utilities $ $ $ I Electric $ $45.00 $ I ! Gas $ $ $ , Oil $ $20.00 $ Telephone $ $40.00 $ Trash $ $9.50 $ Water $ $12.50 $ Sewer $ $11.00 $ Other $ $ $ EMPLOYMENT Public Transportation $ $ $ Lunch $ $75.00 $ TAXES Real Estate $ $ $ Personal Property $ $ $ Income $ $ $ Personal Tax $ $ $ INSURANCE EXPENSE WEEK MONTH YEAR Homeowners $ $ $ Automobile $ $ $ Life $ $ $ Accident $ $ $ Health $ $ $ Other $ $32.00 (Boat) $ I AUTOMOBILE i Payments $ $241.23 $ $ $120.00 (boat) $ r Fuel I i Repairs/Maintenance $ $ $ i , MEDICAL Doctor $ $ $ Dentist $ $ $ Orthodontist $ $ $ Hospital $ $ $ Medicine $ $ $ Special needs (glasses, $ $ $ braces, orthopedic devices) EDUCATION Private School $ $ $ Parochial School $ $ $ College $ $ $ Religious $ $ $ PERSONAL Clothing $ $75.00 $ Food $ $300.00 $ EXPENSE WEEK MONTH YEAR Barber/Hairdresser $ $7.00 $ Credit Payments: Charge $ $100.00 $ Card Cherge Accounts Memberships $ $66.00 $ I.OAN.S PNC $321.57 (trailer) Lot Rent $160.00 Members First $ $222.00 $ Bleyer $90.00 MISCELLANEOUS Household Help $ $75.00 $ Child Care $ $ $ Papers/Books/Magazines $ $13.00 $ Entertainment $ $75.00 $ Pay TV $ $30.00 $ Vacation $ $ $ Gifts $ $25.00 $ Legal Fees $ $ $ Charitable Contributions $ $ $ Other: Child support $ $ $ Alimony Payments $ $ $ OTHER $ $ $ $ $ $ TOTAL EXPENSES $2,848.31 .. :~ . , .' - . , I L , '. f , " , II 1;. .' < , r,:' C'l tJl .. g ~ W ~ I::l j ~ < .. ~ Z ~ z ~ ~ 5 ~ ~ o.l ....i >- ~ >- 0 CIl .< "' ~ ~ z Z :i Z W II: "' :.J 0 ;:: 0: " :'i: ~ ~ or 0 < z ~ 1fl ~ N 0 ~ :>: OJ o.l . . . . CLOYD A. BARRICK, JR., ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND ) COUNTY, PENNSYLVANIA vs. ) ) CIVIL ACTION. LAW JOLENE N. BARRICK, ) Detendant ) NO. 96.3408 CIVIL TERM ) ) IN DIVORCE NQIlCE TO DEFENDANI If you wish to deny any of the statements set forth in this Affidavit, you must file a Counter Affidavit within twenty (20) days after this aftidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on 15 April 1996 and have continued to live separately and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses It I do not claim them before a divorce is granted. I verity that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: J c. y.. ~.., if" TRUE COpy ROFi1 RECORD In Tostlmony whoreof, I here unto set my hand and the seal of said Court at Car1lsle, ~..) Thl .;;.. y I (!l v , t9 .. '-~ ~'~\~h~ (l /~J.',}V~ I J ~')cF' Piolhonolary .r / //) ,,/' ..'..,/// 4!t, Cloyd A. Barrick, Jr. .;./'l ; ~ " ,0 CLOYD A. BARRICK, JR.. ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND ) COUNTY, PENNSYLVANIA vs. ) ) CIVIL ACTION. LAW JOLENE N. BARRICK, ) Defendant ) NO. 96.3408 CIVIL TERM ) ) IN DIVORCE NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a Counter Affidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on 15 April 1996 and have continued to live separateiy and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: ,r- :Y - '7 f?' ~ //) ~-. . /"-'~ ./ (/ /~"f.. < Cia d A. Barrick, Jr. ..... en (: iT. U~ ~:,; .. . lJ.I ~.: I '.-; '__I- <.) -". .- J' l-": ~:,! :.:;: ..., ;:j I~r 0.. fri?l ~,n n .'.., I ! , .::. ;:... , 'i: ,j tL: I. ~~ .q::.... \. :i: u. en '..5 () ('J'" 0 .::\wp.Sl\jnh:nc\.Inh\\-cr July 1.111IM. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYlVANIA CLOYD A. BARRICK, JR., vs. CIVIL ACTION. LAW NO. 96.3408 CIVIL TERM JOLENE N. BARRICK, Defendant IN DIVORCE ANSWER AND COUNTER-CLAIM Now comes Jolene N. Barrick, Defendant above, by and through her counsel, FLOWER, MORGENTHAL, FLOWER & LINDSAY, P,C., and answers the Complaint in Divorce as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. No answer required. 8. No answer required. WHEREFORE, Detendant requests this Honorable Court to enter a Decree in divorce divorcing Plaintiff from Defendant. COUNTER-CLAIM COUNT I: EQUIT^BLE DISTRIBUTION 9. The averments of Paragraph 1-8 are incorporated herein by reference as though set out in fl.ill. ~';\wr.~I\jlllc;"c;\t'1lunlc;r.d," Ilk '."i.\'1H.'JN-lIl \1;1) I!.\'J')N CLOYD A. BARRICK, JR., Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 96.3408 CIVIL TERM JOLENE N. BARRICK, Defendant/Petitioner IN DIVORCE ANSWER AND COUNTER-CLAIM. TO COMPLAINT IN DIVORCE Now comes JOLENE N. BARRICK, by and through her counsel, FLOWER, MORGENTHAL, FLOWER & LINDSAY, P.C., and answers the Complaint in Divorce filed by Plaintiff as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. Admitted. WHEREFORE, Defendant/Petitioner prays this Honorable Court to enter a Decree in Divorce divorcing Plaintiff from Defendant. COUNTER-CLAIM 9. The averments in Paragraphs 1-8 are incorporated herein by reference as if set out in full. ~';\wf1.sI\jtlh:nc\ilnlo""[!r July},jlJ')Ii. CLOYD A. BARRICK, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 96.3408 CIVIL TERM YS. JOLENE N. BARRICK, Defendant IN DIVORCE ANSWER AND COUNTER-CLAIM Now comes Jolene N. Barrick, Defendant above, by and through her counsel, FLOWER, MORGENTHAL, FLOWER & L1NDSA'{, P.C., and answers the Complaint in Divorce as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. No answer required. 8. No answer required. WHEREFORE, Defendant requests this Honorable Court to enter a Decree in divorce divorcing Plaintiff from Defendant. COUNTER.CLAIM COUNT I: EQUITABLE DISTRIBUTION 9. The averments of Paragraph 1-8 are incorporated herein by reference as though set out In full. f;, r' ( C ..~ '-"l Ie: -. u..19 - , C,2t-, .- ; . .~ .'- It: " ...r: .., ",', Cl)\. .. ~r} - { . 6' 1 --~ 'oj. C'>l W'" .-::Z ;.Jl' . "" '.~JI U a:::( U.J rqO.. .... I./'j .- \5 c;:l ::J CI' CJ . Q) III r.> .<:: 7..... o 0 ~ ~ @ '... ..... ~!;l.... !il$~ 7. o ~~ >A. tII!;l $1$ ..: ~ u 0 ..... ~ III ~ ~ '" 0 0 0 ::e 0 ~ N III ...... "" 0 0 .... It! C!l tl 7. = 'ooi 0 0 I-< III Ii: :J: It! I-< ...... 0 Oi! C!l Q) t) .... = t) 'ooi Q) '" ~ .0 tl '" Q 0 '" ~ N .... 7. 0 t;; ~"" ~C a::~ 7. C t;; ~..: "'''-I "'ell ~I$ \D '" " ..VII J.ISIHX3 N '" on o '" \D \--"i ) -. u , <J .-' )) , }fi (1 .~ () ,J ~ <': ~ 0- -p...;:J g:: . ... .3 P f ~- c) Jl fXJ 0 ~1 --r ~ Q') j j ..... 1) -' J (:.. \.. ~ -':J ~~ C\- ?: -0 ~ '" lJ G: .1 '"2 " , <:. 006481 DJ!FENOANTS E.XnIIfTNQ~ fOlllo<HTlfICAnOH{)2.. <:. DATL4bltf,/m,r "/ N~m~SmEllS,llC. NAME CIo d A. Barrick Jr. DEPARTMENT Hourl 006481 . . . . Salary 173.08 5.000 865.38 Federal WH 167.4 00006481 J Soc Sec WH 53.6 Mcare WH 12,5 ., ,- State1 WH 24.2. Local1 WH 8.6 12/31/98 .. Fm: 12/20/9 To: 12/26/9 Memo: , . '. 48826.85 865.38 208-42-6958 266.49 ,- , . . 0.00 9438.74 3027.22 707.98 1367.13 488.22 ROSE METAL SYSTEMS, INC, PAYROll ACCOUNT 1412 TRINDlE ROAD. SUITE E CARLISLE. PA 17013 (717) 2~5.0883 FULTON BANK Hood Olflco: Laneutor, Ponnsylvanla 17604 006481 [.""'~'~:"'''''''''l lItil;Ut;4II:1IJ,1,I;;I:U i ~ 0006481 ~ ! I I , : (FIVE HUNDRED NINETY EIGHT DOLLARS AND 89/CENTS) DATE -""'IlIIl~ 12/31l91*.:::~":::-=-8. 89 PAY TO THE ORDER OF Cloyd A. Barrick Jr. 6 Mountain View Drive Mt.HollySprings, PA 17065 ,\ :c COPY NOT NEGOTIABLE lI'OObl,a~II' I:O:lUO~I,22I: 25~ 'lbb ?:lO 21" In the Court of Common Pleas of County, Pennsyl~ania PIIont: Fa~: Plainriff Name: Defendanr Name: Docket Number: PACSES Case Number: Other S~te ID Number: PltAH 0011'1 AU (orrespoadmc:r IDwllDcludr tbt PACSE../ii ClUe Sumbtr. Income and E:I(pense Statement THIS FORM MUST DE FILLED OUT (If you are self-employed or If you are salaried by a business of which you are owner in whole or pan. you must also fill out the Supplemental Income Statement which appears on the IISI page of this Incmne and expense stalement.) INCOME STATEMENT OF ("-trGf cl . 611,a~L fh I ~erify wtthe stalements made in this Income and Expense Statement are lrue and correct. I undersrand that false statel1lCnlS herein arc subJcctlo the criminal penahies of 18 Pa. C.S. ~ 4904, relating 10 unsworn falsification 10 authorities. Dale 4;Plaintlff or DefeDdant INCOME: '~/1 f71d' t2 Employer -1'-' 0 - 'r-tE....t' 'tlt;rlf).. '1\,,( Address ,1../1,). .7i3t,n..//' 6..,./, A{~ l e lirld:J. ~. 17rJl..3 Type of Work Payroll No. t'1::JJ.... Gross Pay per Pay Period S '?(,,'5 3'.:f Pay Period (wkly.. bl.wkly.. etc.) ~ hemiud Payroll Deductions: Federal Withholding S(t/J.-II Social SecurilY S 5:%::' Local Wage Tax S'i'.')' Stale Iocome Tax ~" .2 Rerlremenr S 0 Saviogs Bonds S 0 Credit Union S Life Insurance S Heahh Insurance S OilIer Deducti.lns (specify) f'lIc..o.'-'<- W 1-\ SIl.S' S Net Pay per Pay Period S .jqCJ.:r? Service Type DEFENDANTS EXIlIIITNQ. ~ FOR IDlNTlflCATlOH DA"'4Isr~pe.S Foml1N.OO8 Worker ID I II" "lie all~ Exp<:n'e Slnmelll PACSES Case Sumher OTHER (Fill ill Appmpriale Culumll) INCOME WEEK MONTH VEAR IlIleresl $ $ S Divi~en~s Pe,!>;;un Annuily SlIciaJ Security Rems Royahles Elpense A'COUDI Gifts P.>.>4\,0A,\} .5l5. C,O ;. .""< UnemplDymem Compensalion Workmen's CompensalioD IRS Refund Olher Olher TOTAL $ $ $ TOTAL INCOME S (Fill In Appropriate Column) EXPENSES WEEK MONTH YEAR Home Mongage/ReDl Malmenaru:e Ulilities s $ 8=:' J1 s Eleclric gr.- Gas 011 - / 6;0. ~ 50. ell Teiephone C-RJLlL Service Type Page 2 of 6 FumIIN.OO8 Worker ID hl."OI< ami EX(lCIl'" Sr.lemenl P,\CSES CJse Sumher (Fill ill Apprupriale C"lumn) EXPENSES (conllnued) WEEK MONTII YEAR Waler $ $ .~O. - - 100. - .3...,,,1/, S Sewer ~I,.- " ~,,'>\\ ~"1 ~" ,. Employmenl Puhlic Transpnnalion $ $ S Lunch 60. tit! '- Tua ,rl-' / Real ESlale $ ~ / ,n.v w1.r' "'.'- $ _~<"~~ {-.'-'It ~~ .Il>'~ V ~4,1,~" 11.60 - ~ .1'5 ~. s><./ Personal Pmpuly Income \,,/ ~,"H.DOL (, ......IUI"~ Insurance Homeowners $ $ $ Automobile Life Accldenl Health Other ~cAo\. T .or. ...A~, 0 ...."'1 - A~' ou 3~3. - Aulomoblle Payments $ $ $ Fuel \ A.l...., - 'D~~ Repairs ?_+ Po. . \ ri'-\.\ J.~ . Medical \ . - ^ Doclor ( -ru,,-I-\ $ $ {)..'t ~{:<),<"r,-Ly..;.S/ $ 4'd .00 . Dentisl Onhooontisl Page 3 nr 6 FornI IN.Q08 WorkerlD Service Ty(lC 10"'''"'0 allll EX!,<Jl'o SlalomOll1 PACSES C.,o :'>IunI~or (Fill ill Approprialo C"lullllIl EXPENSES (conllnued) WEEK MOmtl VEAR HllSpi~1 Mcdi~11l&: S!,<cial noolls (alas.ses. hra,os, onhu!,<dk d~vkes) EdlKatlon Privale School S S S Parochial School Colleae ReUa10us Personal Clolhing S S S Food ( Barbe""r7.Haircltcs.scr 10. (lu Credit PaymenlS: Credit Card Charge Account Memberships c..\",~ ..;-:50 1,,'/. - ',-- Loans Credit Union M...\- \\\ S S 111. .- s 0-.\ ~_ dJ> Qc, - Miscellaneous Household Help S S S Child Care Papers/Books/Magazine EmonailUllem 56 00 Pay TV 31. "'~ Vacalillll ~. . < (\.. ", \:" Pago 4 of 6 Fom. IN.DOS Worker ID Sorvke Type 1I.."me allll Expt:ll,e Slalemem PACSES Ca,e Numhe, (Fill in Apprupriale C"lunul) EXPENSES WEEK ((onUnued) MONTlI VEAR \ .LA\-O",",."0~ Gitis :q~7 l.' ....,. :>'..........,c n. , .."- Legal Fees 1~~.lndO , o 0 -L.L.L-: I <j -/ -'i''i Charil.1hle CUnlribulions allier Child Suppun Alimuny Paymenrs Other S S S TOTAL EXPENSES $ $ .2/5',-/. (p Y $ '1Uo. f<lJ Ownership · ,,/rh'/VALUE H W J .. OCl, - ChecldDg ACCOUDlS S 5/. elll 'f. Savings Accounts ~ L/ 37. ;21., CrecUr Union Stocks/BoDds Real Estate Other TOTAL $ INCOME AND EXPENSE SrATE~IENT I' ACSES C\SE NI \1:II'R OTlIER (Fill m ApProf1rllllt' ('OIWIlII) INCOME WEEK MONTH YEAR IOCl."fcst S S S DlVidco<lS Pension Annuity Social Security Rents Royahies Expense Account Gifts Unemployment Compensation W orkmen's Compensation I RS Refund Other Other TOTAL S S S TOTAL INCOME S EXPENSES (FiII;1/ Appropril/te ('0/1/1111') WEEK MONTII YEAR HOME Mong.ge/Rent s S 150.00 s Maintenance: UtilitIes Eleelrie 35,00 10,00 300.00 Gas Oil 20,00 Telephone Semee T) pe 008 Page :! of (, Ftlnn IN- Worker ID INCOME AND EXPENSE S r A rE~lrN r j'ACSES elSE Nl',IIUI'R EXPENSES (Fill ill Al'pmprtlllt.. ('ollllm.) (contlnned) WEEK MONTJI \'E,\R IValer S S S Sewer EMPLOYMENT Public Transponallon S S S lunch 10.00 TAXES Real Estale S S S Personal Propcny Income 289.56 INSURANCE Homeowners S S S AUlomobile 50,00 Life Accidenl .44 Hcahh 27.02 Other Automobile Payments S S S Fuel 20.00 Repairs 200,00 Medlc.1 Doctor S S S 100,00 DemiSI Onhodontisl Service Type 1);Jgt: J of h ",,""IN.OIJS \\'urJ..cr 10 INCOME AND EXI'ENSE Sf A fEMEN r PACSES Clsr NI',\IIlEK EXPENSES (Fill ill Appropriatt! ('ol"'"IJ) (eoallnued) WEEK MONTI! YEAR Hospital S S S Medicine 10.00 Special nceds (g/lUseS. bracL's, orthopl!Jic tlf!~I;ces) EDUCATION Private School S S S Parochial School College Religioos PERSONAL Clothing S S S 200.00 Food 40.00 Barber/Hairdresser Credit Payments: Credit Card Charge Account 40.00. Memberships 25.00 LOANS Credit Union S S 140,00" S Mlseellloeou. Household Help S Child Care Papers/Books/Magazine Entertainment \5.00 Pay TV 28.69 Vocation .FdShlOn Bug JO.()(); Fmg.:r IIUI JO.UtJ .. PaymC!l1I em Hl1ill'l1Iccd ","r;(al dt.'bt Service Type PilgC ~ of 6 FomlIN-OOS IV orker ID INCOME AND EXPENSE Sf ^ TI'~IE~T PACSES C.\SE NUMIlER EXPENSES (coolinued) (Fill ill Appropriate Colllmn) WEEK MONTH \'EAR Gifts s s S 400,00 Legal Fees Chwiloble Contribullons 2000,00 unpUld I"gal rccs Other Child SUppol1 Alimony PaymL'tlts OTHER s s s TOTAL EXPENSES S PROPERTY Ownership' OWNED DESCRIPTION VALUE H IV J Checking Accounts 100.00 . Savings Accounts 30.00 . Credil Union Slocks/Bonds Reol Estale Other TOTAL S INSURANCE COMPANY POLICY # Coverage .. II W C Hosr,ilUl B uc Cross Olher Health Amll1ca . Medical Blue Cross Other 'II . Husband W - IV,f. C. Combll1cd J - JOin' Scrvlce T)-pc Page 5 of 6 Funn IN.OOg Worker ID ,- c> ...- ~.~ <v L; ,'- , ) , I ,', -" , (, '; '. " Ll. ! :-:-! (~) , ,. ....") , .. ,. " '. .1, , "D II. -. I,L , , r l, 0'1 ~:J U ~n ,-> 'Jolene msa August 18. 1999 NOW, THEREFORE, in consideration of these considerations, and the mutual promises and undertakings hereinafter set forth, and for other good and valuable consideration, receipt and sufficiency of which is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE, each Intending to be legally bound, hereby covenant and agree as follows: 1. Advice of Counsel: The parties hereto acknowledge that each has been notified of his or her right to consult wilh counsel of his or her choice, and have been provided a copy of this agreement with which to consult with counsel. WIFE is represented by Carol J. Lindsay, Esquire, and HUSBAND is represented by Samuel L. Andes, Esquire. Each party acknowledges and accepts that this agreement is, In the circumstances, fair and equitable, and that it is being entered into freely and voluntarily, after having received such advice and with such knowledge as each has sought from counsel, and that execution of this agreement is not the result of any duress or undue Influence, and that it is not the result of any improper or illegal agreement or agreements. 2. Divorce: The parties agree to the entry of a Decree in Divorce. The parties will execute, on the date of this agreement, Affidavits of Consent and Waivers of Notice under Section 3301 (c) of the Divorce Code, consenting to the entry of a Decree in Divorce. 3. Personal Property: The parties acknowledge that they have equitably and satisfactorily divided all of their personal property, and that all personal property shall be the sole and individual property of the party in whose possession It is as of the date of this agreement. WIFE will retain the proceeds of sale of the parties' mobile home in the amount of $8,800.28, a 1993 Corsica automobile, $547.00 which has been escrowed in the Office of Samuel Andes, Esquire, from the sale of the parties' cabin, and her TIAAlCREF retirement account. WIFE will also retain the two cemetery lots of the parties'. HUSBAND will retain his Rose Metal System slock, and his Legg- Mason IRA, provided however that HUSBAND will transfer to WIFE $35,000.00 from said Legg- 2 . Jolono ms. Augusl18. 1999 Mason IRA through a Qualified Domestic Relations Order. The Order will be prepared by WIFE's counsel, and will call for the transfer as of the date of the Agreement with any gains or losses thereon, from that date to the date of actual transfer. HUSBAND will cooperate by providing any Information requested In order to prepare the Qualified Domestic Relations Order. 4. Alimony: The parties waive any claim that they may have one against the other for alimony, alimony pendente /ite or spousal support. The parties acknowledge that each has sufficient assets with which to maintain themselves after divorce. The parties agree that irrespective of the date of entry of the Decree In Divorce, HUSBAND's obligation for alimony pendente /ite shall cease as of the date of this Agreement. Any arrearages due on the date of termination of alimony pendente lite shall be paid at the rate of $350.00 per month which shall continue to be wage attached until paid In full. 5. Marital Debt: The parties have, in their own names, certain credit card accounts which may include some marital debt. Each party will be responsible for the debt on the credit card accounts in his or her name. Each party will Incur no debt for which the other may be liable, and will indemnify and hold the other harmless for any debt so Incurred. HUSBAND shall be solely responsible for the Members First account, the account with Blazer, the Sears account, the Consumer One loan, and the American General loan. WIFE will be solely responsible for the car loan taken for the purchase of the 1993 Corsica at Members First and a separate Members First loan. The parties each shall indemnify and hold the other harmless on account of any loss as a result of the financial obligations each assumes In this paragraph. Each party will incur no debt for which the other may be liable, and will indemnify and hold the other harmless for any debt so incurred. 3 . lolon. maa August 18. 1999 6. Exchange of Information: The parties have requested from each other and received any information regarding their assets, lia!Jilities, income and expenses wh!ch the party requires prior to entering Into the terms of this Agreement. The parties acknowledge that the terms of this Agreement are fair and equitable and constitute an equitable distribution of marital property and debt, taking Into account all of the relevant factors set out in Section 3502 of the Divorce Code, 23 Pa. C.S.~3502 including the length of the marriage; any prior marriage of the parties; the age, health, station, amounts and sources of Income, vocational skills, employability, estate, liabilities and needs of each of the parties; the contribution by each party to the education, training or Increased eaming power of the other; the opportunity of each party for future acquisitions of capital assets and income; the sources of income of both parties, Including but not limited to, medical, retirement, Insurance or other benefits; the contribution or dissipation of each party In the acquisition, preservation, depreciation. or appreciate of the marital property, Including the contribution of a party as homemaker; the value of the property set apart to each party; the standard of living of the parties during the marriage; the economic circumstances of each party including federal, state and local tax ramifications at the time of the division of the property, and whether the party will be serving as custodian of any dependent minor children. 7. Modification: No modification, rescission, or amendment of this agreement shall be effective unless in writing signed by each of the parties hereto. 8. Applicable Law: Ail acts contemplated by this agreement shall be construed and enforced under the laws of the Commonwealth of Pennsylvania. 9. Agreement Binding on Parties and Heirs: This agreement, except as otherwise expressly provided herein, shall bind the parties hereto, and their respective heirs, executors, administrators, legal ropresentatives, assigns and successors In any Interest of the parties. 4 'Jolono ms. August 18. 1999 10. Agreement Not to be Merged: This agreement shall be incorporated Into the final decree of divorce of the parties hereto for purposes of enforcement only, but otherwise shall not be merged Into said decree. The parties shall have the right to enforce this agreement under the Divorce Code of 1980, as amended, and in addition, shall retain any remedies in law or in equity under this agreement as an independent contract. Such remedies in law or equity are specifically not waivl:ld or released. 11. Documents: The parties hereto agree that they will execute and deliver one to the other any documents necessary to give affect to the terms of this Agreement. 12. Full and Final Settlement: WIFE and HUSBAND each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, titles, interests or claims in or against the property (Including income and gain from property hereafter accruing, of the other) or against the estate of such other, of whatever nature and wheresoever situate, which she or he now has or at any time hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other, or by way of dower or curtesy, or claims In the nature of dower or curtesy, or widows' or widowers' rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviVing spouse to participate in a deceased spouse's estate, whether ariSing under the laws of Pennsylvania, any other State, or any other Country, or any rights which either spouse may have, or at any time hereafter have, for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether ariSing as a result of the marital relation or otherwise, except and only except, all rights and agreements and obligations of 5 CLOYD A. BARRICK, JR., Plaintiff/Respondent vs, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 96.3408 CIVIL TERM IN DIVORCE JOLENE N. BARRICK, Defendant/Petitioner THIS Agreement made this ~ ~ day of T.1,~\_, '" '}- , 1999 by and between JOLENE N. BARRICK, of R. R. 1, Box 902, Land'isburg, Perry County, Pennsylvania, hereinafter referred to as WIFE, and CLOYD A. BARRICK. JR., of 6 Mountain View Drive, Mt. Holly Springs, Cumberland County, Pennsylvania, hereinafter referred to as HUSBAND, WITNESSETH: WHEREAS, the parties hereto are husband and wife. having been joined In marriage on August 27,1972, in Carlisle, Cumberland County, Pennsylvania; and WHEREAS. a Complaint for Divorce has been filed in the Court of Common Pleas of County, Pennsylvania, to No. 96 - 3408, Civil Term; and WHEREAS, the parties hereto are desirous of settling fully and finally theIr respective financial and property rights and obligations as between each other, including, without limitation, the settling of all matters between them relating to the ownership of real and personal property, claims for spousal support, alimony, alimony pendente life, counsel fees and costs, and in general, the settling of any and all claims and possible claims against the other or against their respective estates. JoIono mo. Auguol18, 1999 NOW, THEREFORE, In consideration of these considerations, and the mutual promises and undertakings hereinafter set forth, and for other good and valuable consideration, receipt and sufficiency of which is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE, each Intending to be legally bound, hereby covenant and agree as follows: 1. Advice of Counsol: The parties hereto acknowledge that each has been notifIed of his or her right to consult with counsel of his or her choice, and have been provided a copy of this agreement wilh which to consult with counsel. WIFE Is represented by Carol J. Lindsay, Esquire, and HUSBAND Is represented by Samuel L. Andes, Esquire. Each party acknowledges and accepts that this agreement Is, In the circumstances, fair and equitable, and that ills being entered Into freely and voluntarily, after having received such advice and with such knowledge as each has sought from counsel, and that execution of this agreement Is not the result of any duress or undue Influence, and that it Is not the result of any Improper or Illegal agreement or agreements. 2. Divorce: The parties agree to the entry of a Decree in Divorce. The parties will execute, on Ihe date of this agreement, Affidavits of Consent and Waivers of Notice under Section 3301 (c) of the Divorce Code, consenting to the entry of a Decree In Divorce. 3. Personal Property: The parties acknowledge that they have equitably and satisfactorily divided all of their personal property, and that all personal property shall be the sole and Individual property of the party In whose possession il Is as of the date of this agreement. WIFE will retain the proceeds of sale of the parties' mobile home in the amount of $8,800.28, a 1993 Corsica automobile, $547.00 which has been escrowed In the Office of Samuel Andes, Esquire, from the sale of the parties' cabin, and her TIAAlCREF retirement account. WIFE will also retain the two cemetery lots of the parties'. HUSBAND will retain his Rose Metal System stock, and his Legg- Mason IRA, provided however that HUSBAND will transfer to WIFE $35,000.00 from said Legg- 2 JOI.~. me. Auguel 18. 1000 Mason IRA through a Qualified Domestic Relations Order. The Order will be prepared by WIFE's counsel, and will call for the transfer as of the date of the Agreement with any gains or losses thereon, from that date to the date of actual transfer. HUSBAND will cooperate by providing any Information requested In order to prepare the Qualified Domestic Relations Order. 4. Alimony: The parties waive any claim that they may have one agalnstlhe other for alimony, alimony pendente lite or spousal support. The parties acknowledge that each has sufficient assets with which to maintain themselves after divorce. The parties agree that Irrespective of the date of entry of the Decree In Divorce, HUSBAND's obligation for alimony pendente lite shall cease as of the date of this Agreement. Any arrearages due on the date of termination of alimony pendente lite shall be paid at the rate of $350.00 per month which shall continue to be wage attached until paid In full. 5. Marital Debt: The parties have, in their own names, certain credit card accounts which may include some marital debt. Each party will be responsible for the debt on the credit card accounts In his or her name. Each party will Incur no debt for which the other may be liable, and will Indemnify and hold the other harmless for any debt so incurred. HUSBAND shall be solely responsible for the Members First account, the account with Blazer, the Sears account, the Consumer One loan, and the American General loan. WIFE will be solely responsible for the car loan taken for the purchase of the 1993 Corsica at Members First and a separate Members First loan. The parties each shall Indemnify and hold the other harmless on account of any ioss as a result of the financial obligations each assumes in this paragraph. Each party will Incur no debt for which the other may be liable, and will Indemnify and hold the other harm!ess for any debt so incurred. 3 jm.n. mo. Augu.118.1999 6. Exchange of Information: The parties have requested from each other and received any Information regarding their assets, liabilities, Income and expenses which the party requires prior to entering into the terms of this Agreement. The parties acknowledge that the terms of this Agreement are fair and equitable and constitute an equitable distribution of marital property and debt, taking Into account all of the relevant factors set out In Section 3502 of the Divorce Code, 23 Pa. C.S.~3502 Including the length of the marriage; any prior marriage of the parties; the age, heaith, station, amounts and sources of Income, vocational skills, employability, estate, liabilities and needs of each of the parties; the contribution by each party to the education, training or Increased eaming power of the other; the opportunity of each party for future acquisitions of capital assets and Income; the sources of income of both parties, Including but not limited to, medical, retirement, Insurance or other benefits; the contribution or dissipation of each party In the acquisition, preservation, depreciation, or appreciate of the marital property, Including the contribution of a party as homemaker; the value of the property set apart to each party; the standard of living of the parties during the marriage; the economic circumstances of each party Including federal, state and local tax ramifications at the time of the division of the property, and whether the party will be serving as custodian of any dependent minor children. 7. Modification: No modification, rescission, or amendment of this agreement shali be effective unless in writing signed by each of the parties hereto. 8. Applicable Law: All acts contemplated by this agreement shall be construed and enforced under the laws of the Commonwealth of Pennsylvania. 9. Agreement Binding on Parties and Heirs: This agreement, except as otherwise expressly provided herein, shall bind the parties hereto, and their respective heirs, executors, administrators, legal representatives, assigns and successors in any Interest of the parties. 4 . J~I.n. "lSa August lB. 1999 10. Agreement Not to be Merged: This agreement shall be incorporated into the final decree of divorce of the parties hereto for purposes of enforcement only, but otherwise shall not be merged into said decree. The parties shall have the right to enforce this agreement under the Divorce Code of 1980, as amended, and In addition, shall retain any remedies In law or In equity under this agreement as an Independent contract. Such remedies in law or equity are specifically not waived or released. 11. Documents: The parties hereto agree that they will execute and deliver one to the other any documents necessary to give effect to the terms of this Agreement. 12. Full and Final Settlement: WIFE and HUSBAND each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, titles, interests or claims In or against the property (Including income and gain from property hereafter accruing, of the other) or agalristthe estate of such other, of whatever nature and wheresoever situate, which she or he now has or at any time hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other, or by way of dower or curtesy, or claims In the nature of dower or curtesy, or widows' or widowers' rights, family exemption or similar allowance, or under the Intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any other State, or any other Country, or any rights which either spouse may have, or at any time hereafter have, for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a resuit of the marital relation or otherwise, except and only except, all rights and agreements and obligations of 5 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION JOLI!NB N. BARRICK ) Do.;ket Numhcr 96-3409 CV Plaintiff ) vs. ) PACSES Case Numhcr 155100BO CLOYD A. BARRICK JR ) ,n71o~ Defenualll ) Other Sl~le ID Number b~ Order AND NOW to wit, this it is hereby Ordered SEPTEMBER 29, 1999 that: THB ABOVE CAPTIONED ORDBR OF ALIMONY PENDENTB LITE IS TERMlNATBD, EFFBCTlVE AUGUST 30, 1999, PURSUANT TO AN AGREEMENT OF THE PARTIES. THB REMAINING BALANCI! OF $2,795.97 OWED TO THE PETITIONER AND $3.42 IN REMAINING SERVICB FBB OWBO TO THE DOMESTIC RELATIONS SBCTION IS TO BB PAID WITH THE EFFBCTlVE WAGB ATl'ACHMBNT AT $350.00 PER MONTH. BY THE COURT: DRO. CCI CCI CCI R.J. Shadday plaintiff and defendant Carol Lindsay, Esq. Samuel L. I\ndes, Esq. Service Type M \- !'n!J<U. r:rr !:lay ley, JUDGE ~. III ... ",--' -,' .. .................-~. /0. ?'-'i9 ..,~ Form OE-OO I Worker ID 21005 ,. ~) r~ r-~ \,-' , , OJ , I , , .1 '-. L., I 1-' I, j , '. ! . ~. c: ~~j I ,n () ()' '-'