HomeMy WebLinkAbout96-04601
.Johnson. Dume. Stewart & Weidner
By: Keirslen W, Davidson
I.D, No, 78243
3lJ I Market Street
p, O. Box IlJ<J
Lel1loyne, Pennsylvania 17lJ43,lJ IlJ')
(717) 761-454lJ
Attorneys 1l1l'Iklcndanlil'etitioner
ROSEMARIE KAGANIS (FORMERLY,
ROSEMARIE KANGANIS),
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff/Respondent
NO, 96-4601
v,
CIVIL ACTION - LAW
GEORGE KANGANIS,
CUSTODY
DefendanUPetitioner
DEFENDANT / PETITIONER'S MEMORANDUM
The above referenced parties are the natural parents of two (2) minor children: Thomas George, age
15, whose date of birth is November 15, 1986; and Dean George, age 12, whose date of birth is October 27,
1989. The parties have shared legal and physical custody of their sons on a 50/50 basis since they
separated and divorced in May of 1997, pursuant to a loosely worded paragraph entitled "Custody" in their
Divorce Settlement Agreement.
On or about April 27, 2001, FATHER filed a Petition to Modify Custody seeking to establish a definite
holiday and vacation schedule with the children, and also to address problems that had arisen regarding his
telephone contact with the children when they were in MOTHER'S custody, The parties subsequently
attended a custody conciliation on or about June 4, 2001, At the conciliation, FATHER requested that
clearly defined holiday and vacation periods be added to the existing Custody Agreement, and more
importantly, that advanced notice regarding the specifics of any vacations with the children be given to the
non-custodial parent.
Following the agreement reached by the parties at the custody conciliation, an Order dated June 19,
2001, was generated containing the following language:
5, Vacation, Each parent shall have up to 21 vacation days to be used for the
purpose of vacation each summer, However, not more than 14 of these days shall be used
consecutively, The parties shall provide at least 30 days written notice to the other
parent of their vacation plans including the location of the vacation and a telephone
number where they can be reached, ...
A copy of this Order is attached hereto and marked as Exhibit "A", No mention was made at the
conciliation of either of the parties specific plans for vacation with the children for the summer of 2001.
Despite the above, just over a month after the conciliation MOTHER took the children on vacation to
Greece on or about July 25, 2001, without advising FATHER of anything in advance other than the dates of
her vacation, In fact, FATHER learned of MOTHER'S plans for the children when one of the boys
telephoned him from JFK airport in New York to say good bye,
FATHER attempted to speak with MOTHER regarding her travel plans prior to her departure,
however she refused to disclose any information whatsoever, and FATHER later learned from one of the
children, called the police to remove him from her property.
Subsequent to MOTHER'S departure, her counsel faxed a memo to FATHER'S counsel containing a
sparse itinerary authored by MOTHER. MOTHER failed to disclose any information other than the flight
times, dates and numbers (half of which were then moot), and the name of the hotel in which they intended
to stay during the initial part of their vacation,
After thoughtful consideration, FATHER filed for Contempt. A mere month and a half after the parties
attended a custody conciliation and agreed that they would give each other at least 30 days advance notice
of their vacation plans, MOTHER departed with the children for Greece with absolutely no notice to FATHER
whatsoever. MOTHER now claims that the "spirit" or the "intent" of the Custody Order was maintained in
that the children had daily contact with FATHER while in Greece and so FATHER was kept apprised of their
activities. FATHER acknowledges the daily contact, however respectfully suggests that MOTHER misses
the point. The parties prior difficulties with holiday and vacation periods lead FATHER to file his original
Petition for Modification of Custody, FATHER sought to eliminate future problems by creating an Order that
clearly set forth the parties vacation and holiday schedules and more importantly, clearly set forth each
party's notice obligations to the other during these times. The Custody Order clearly states that the parties
are to give each other 30 days written notice of the specifics of their vacation, including the location, It
cannot be a defense for MOTHER that the "spirit" of the Custody Order was maintained when she clearly
violated its terms by failing to provide FATHER llllI advance notice of the specifics of her trip.
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JUN 1 42001 fJO
ROSEMARIE KAGANIS,
FORMERLY ROSEMARIE KANGANIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs,
NO. 96.4601
GEORGE KANGANIS,
CIVIL ACTION - LAW
CUSTODY
Defendant
9RD EB_OEJ~,QJJ.RI
Hess, J, ---'..
AND NOW, this _J-9- fh _ day of June, 2001, upon consideration of the attached
Custody Conciliation Summary Report, It is hereby ordered and directed as follows:
1, l.nOtlL.CJ.L51~, The parties, Rosemarie Kaganis and George Kanganis, shail have
shared legal custody of the minor Children, George Kanganis, born November 15, 1986, and
Dean George Kanganis, born October 27,1989-, ,Each parent shall have an equal right, to be
exercised jointly with the other parent, tq make all major non-emergency decisions affecting
the Children's general well-being including, but not limited to, all decisions regarding their
health, education and religion. Pursuant to the terms of Pa, C. S, S 5309, each parent shall be
entltied to all records and information pertaining to the Children including, but not limited to,
medical, dental, religious or school records, the residence address of the Children and of the
other parent. To the extent one parent has' possession of any such records or information,
that parent shall be required to share the same, or copies thereof, with the other parent within
such reasonabie time as to make the records and information of reasonable use to the other
parent.
2, Ebyslcal Custody. The parties shall-have shared physical custody on a two-week
alternating basis arranged as follows:
A. Week One: From Tuesday at 3:00 p.m. until Friday at 3:00 p.m. the
Children shail be with Father, and from Friday at 3:00 p.m. until Sunday at
5:00 p,m. the Children shall be with Mother; from Sunday at 5:00 p.m until
Tuesday at 3:00 p,m the children shall be with Father.
B, Week Two: From Tuesday at 3:00 p.m. until Friday at 3:00 p,m. the
Children shall be with Mother, and from Friday at 3:00 p.m. until Sunday
at 5:00 p,m, the Children shall be with Father. From Sunday at 5:00 p.m.
until Tuesday at 3:00 p.m, the Children shall be with Mother.
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No. 96-4601
3. Christmas. Each year, the holiday time between Christmas and New Year's shall
be shared as follows:
A. Father shall have custody from December 24th at 9:00 a.m. until
December 25th at 3:00 p.m, and December 30th at 9:00 a.m. until the
moming the Children return to school following the holiday break.
, B. Mother shall have custody from December 25th at 3:00 p,m. until
December 30th at 9:00 a.m.
4. The Children's Birthdays. Each parent shall have access to the Children on their
birthdays, In the event that the birthday falls on a school day, the parent not in custody shall
have three hours of partial custody for that Child's birthday. In the event that the Child's
birthday falls on a weekend day, the non-custodial parent shall have six hours of custody for
that Child's birthday.
5. Vacation. Each parent shall have up to twenty-one vacation days to be used for the
purpose of vacation each summer. However, not more than fourteen of these days shall be
used consecutively. The parties shall provide at least thirty days'written notice to the other
parent of their'vacation plans including tHe location of the vacation and a telephone number
where they can be reached, In the event that thG parties have conflicting vacation plans, the
party first to provide written notice of their vacation plans shallliave choice of the vacation
time. The vacationing parent may provide a telephone card or a temporary cellular phone to
the Children and encourage the Children torcall the non-custodial parent during the vacation
time, The initial telephone call shall occur within forty-eight hours of arrival of the vacation
destination.
6. Neither party shall do or say anything which may estrange the Children from the
other parent, injure the opinion of the Children as to the other parent, or hamper the free and
natural development of the Children's love and respect for the other parent. Each parent shall
ensure that third parties also comply with this provision during his or her periods of custody.
7. The Children shall be allowed reasonable telephone contact with the non-custodial
parent. Due to the frequency of the custodial exchanges and the regularity of the contact
between the Children and both parents, calls from the non-custodial parent to the Children
should be the exception, rather than the rule. However, appropriate exceptions shall be made
for emergencies or issues that cannot wait to be addressed until the next custodial period for
the non-custodial parent. Moreover, the Children may initiate calls to the non-custodial parent.
J.
6. Counsel for the parties shall submit to the Court a brief memorandum outlining each
party's position on the sharing and/or alternating of holiday time for Thanksgiving and Easter
each year. These memoranda are due within thirty days of the date of this Order.
No. 96-4601
6, Counsel for the parties have agreed to submit a brief memo to the Court stating
each of their positions on the holiday schedule for the Court's determination of the
arrangements for these holidays.
Date
/P II () I
(j~_d~ -,
Melissa Peel Greevy, Esquire
Custody Conciliator
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Johnson, Duffic, StCWlII.t & Wcidner
By: Keirsten W, Davidson
l.D, No. 78243
301 Market Street
p, 0, Box 109
Lemoyne, Pennsylvania 17043,O!O,)
(717) 761-4540
^llorncys l'or Dclcndantll'ctitioncr
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 96-4601
ROSEMARIE KAGAN IS (FORMERLY,
ROSEMARIE KANGANIS),
v.
CIVIL ACTION - LAW
GEORGE KANGANIS,
CUSTODY
Defendant/Petitioner
DEFENDANT / PETITIONER'S MEMORANDUM
The above referenced parties are the natural parents of two (2) minor children: Thomas George, age
15, whose date of birth is November 15, 1986; and Dean George, age 12, whose date of birth is October 27,
1989, The parties have shared legal and physical custody of their sons on a 50/50 basis since they
separated and divorced in May of 1997, pursuant to a loosely worded paragraph entitled "Custody" in their
Divorce Settlement Agreement.
On or about April 27, 2001, FATHER filed a Petition to Modify Custody seeking to establish a definite
holiday and vacation schedule with the children, and also to address probiems that had arisen regarding his
telephone contact with the children when they were in MOTHER'S custody, The parties subsequently
attended a custody conciliation on or about June 4, 2001. At the conciliation, FATHER requested that
clearly defined holiday and vacation periods be added to the existing Custody Agreement, and more
importantly, that advanced notice regarding the specifics of any vacations with the children be given to the
non-custodial parent.
Following the agreement reached by the parties at the custody conciliation, an Order dated June 19,
2001, was generated containing the following language:
5. Vacation, Each parent shall have up to 21 vacation days to be used for the
purpose of vacation each summer, However, not more than 14 of these days shall be used
consecutively, The parties shall provide at least 30 days written notice to the other
parent of their vacation plans including the location of the vacation and a telephone
number where they can be reached, ,.,
A copy of this Order is attached hereto and marked as Exhibit "A", No mention was made at the
conciliation of either of the parties specific plans for vacation with the children for the summer of 2001.
Despite the above, just over a month after the conciliation MOTHER took the children on vacation to
Greece on or about July 25,2001, without advising FATHER of anything in advance other than the dates of
her vacation, In fact, FATHER learned of MOTHER'S plans for the children when one of the boys
telephoned him from JFK airport in New York to say good bye.
FATHER attempted to speak with MOTHER regarding her travel plans prior to her departure,
however she refused to disclose any information whatsoever, and FATHER later learned from one of the
children, called the police to remove him from her property,
Subsequent to MOTHER'S departure, her counsel faxed a memo to FATHER'S counsel containing a
sparse itinerary authored by MOTHER. MOTHER failed to disclose any information other than the flight
times, dates and numbers (half of which were then moot), and the name of the hotel in which they intended
to stay during the initial part of their vacation,
After thoughtful consideration. FATHER filed for Contempt. A mere month and a half after the parties
attended a custody conciliation and agreed that they would give each other at least 30 days advance notice
of their vacation plans, MOTHER departed with the children for Greece with absolutely no notice to FATHER
whatsoever. MOTHER now claims that the "spirit" or the "intent" of the Custody Order was maintained in
that the chiidren had daily contact with FATHER while in Greece and so FATHER was kept apprised of their
activities. FATHER acknowledges the daily contact, however respectfully suggests that MOTHER misses
the point. The parties prior difficulties with holiday and vacation periods lead FATHER to file his original
Petition for Modification of Custody. FATHER sought to eliminate future problems by creating an Order that
clearly set forth the parties vacation and holiday schedules and more importantly, clearly set forth each
party's notice obligations to the other during these times, The Custody Order clearly states that the parties
are to give each other 30 days written notice of the specifics of their vacation, including the location, It
cannot be a defense for MOTHER that the "spirit" of the Custody Order was maintained when she clearly
violated its terms by failing to provide FATHER illJY advance notice of the specifics of her trip.
The Order calls for 30 days advance notice of vacation plans. MOTHER failed to disclose any plans
until after she had left the country. The Order calls for advance notice of the vacation location. MOTHER
failed to disclose this until after she had ieft the country. The Order calls for the vacationing parent to
provide a telephone number where the children can be reached. FATHER concedes that he did have daily
contact with the boys as they called him from Greece, and therefore the "spirit" of this requirement may have
been met, however MOTHER nevertheless violated this portion of the Order as well by failing to provide
FATHER with any means of initiating a call to the boys, FATHER respectfully submits that MOTHER had no
intention of complying with the terms of the agreed upon Custody Order as evidenced by her disobedience
of its terms a mere month and a half after its creation, MOTHER intentionally and knowingly disobeyed the
Custody Order and should therefore, be found in Contempt and Ordered to pay all of FATHER'S reasonable
attorney's fees in connection with enforcing the Order of June 19'h, FATHER is the only witness expected to
testify on his behalf.
Date:
:'50575
la-3'-o\
Respectfully Submitted,
JOHNSON, DUFFIE, STEWART & WEIDNER
ft~ (A )~
Keirsten W. Davidson, Esquire
By:
m'P;o;*~'J"
. ::, .:,
yl .
ROSEMARiE KAGANIS,
FORMERLY ROSEMARIE KANGANIS,
Plaintiff
JUN 14 2001~
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 96-4601
GEORGE KANGANIS,
Defendant
CIVIL ACTION. LAW
CUSTODY
ORDER OF COURT
Hess, J. ----
AND NOW, this /9fh day of June, 2001, upon consideration of the attached
Custody Conciliation Summary Report, it is hereby ordered and directed as follows:
1. Leoal Custody. The parties, Rosemarie Kaganis and George Kanganis, shall have
shared legal cUi'?tody of the minor Children, George Kanganis, born November 15, 1986, and
Dean George Kanganis, born October 27, 1989-. ,Each parent shall have an equal right, to be
exercised jointly with the other parent, tq make all major non-emergency decisions affecting
the Children's general well-being including, but not limited to, all decisions regarding their
health, education and religion. Pursuant to the terms of Pa. C. S, S 5309, each parent shall be
entitled to all records and information pertaining to the Children including, but not limited to,
medical, dental, religious or school records, the residence address of the Children and of the
other parent: To the extent one parent has' possession of any such records or information,
that parent shall be required to share the same, or copies thereof, with the other parent within
such reasonable time as to make the records and information of reasonable use to the other
parent.
2, Physical Custod'l. The parties shall,have shared physical custody on a two-week
alternating basis arranged as follows:
A. Week One: From Tuesday at 3:00 p,m. until Friday at 3:00 p.m, the
Children shall be with Father, and from Friday at 3:00 p.m. until Sunday at
5:00 p.m. the Children shall be with Mother; from Sunday at 5:00 p.m until
Tuesday at 3:00 p.m the children shall be with Father.
8, Week Two: From Tuesday at 3:00 p,m. until Friday at 3:00 p,m. the
Children shall be with Mother, and from Friday at 3:00 p,m. until Sunday
at 5:00 p.m. the Children shall be with Father. From Sunday at 5:00 p.m,
until Tuesday at 3:00 p,m. the Children shall be with Mother.
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No. 96-4601
3. Christmas: Each year, the holiday time between Christmas and New Year's shall
be shared as follows:
A Father shall have custody from December 24th at 9:00 a.m. until
December 25th at 3:00 p.m. and December 30th at 9:00 a.m. until the
morning the Children return to school following the holiday break.
, B. Mother shall have custody from December 25th at 3:00 p.m. until
December 30th at 9:00 a.m.
4. The Children's Birthdays. Each parent shall have access to the Children on their
birthdays. In the event that the birthday falls on a school day, the parent not in custody shall
have three hours of partial custody for that Child's birthday. In the event that the Child's
birthday falls on a weekend day, the non-custodial parent shall have six hours of custody for
that Child's birthday.
5. Vacation. Each parent shall have up to twenty-one vacation days to be used for the
purpose of vacation each summer. However, not more than fourteen of these days shall be
used consecutively. The parties shall provide at least thirty days' written notice to the other
parent of their 'vacation plans including tHe location of the vacation and a telephone number
where they can be reached. In the event that the parties have conflicting vacation plans, the
party first to provide written notice of their vacation plans shall have choice of the vacation
time. The vacationing parent may provide a telephone card or a temporary cellular phone to
the Children and encourage the Children to'call the non-custodial parent during the vacation
time. The initial telephone call shall occur within forty-eight hours of arrival of the vacation
, destination.
6. Neither party shall do or say anything which may estrange the Children from the
other parent, injure the opinion of the Children as to the other parent, or hamper the free and
natural development of the Children's love and respect for the other parent. Each parent shall
ensure that third parties also comply with this provision during his or her periods of custody.
7. The Children shall be allowed reasonable telephone contact with the non-custodial
parent. Due to the frequency of the custodial exchanges and the regularity of the contact
between the Children and both parents, calls from the non-custodial parent to the Children
should be the exception, rather than the rule. However, appropriate exceptions shall be made
for emergencies or issues that cannot wait to be addressed until the next custodial period for
the non-custodial parent. Moreover, the Children may initiate calls to the non-custodial parent.
:/,
6. Counsel for the parties shall submit to the Court a brief memorandum outlining each
party's position on the sharing and/or alternating of holiday time for Thanksgiving and Easter
each year. These memoranda are due within thirty days of the date of this Order.
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No. 96-4601
6. Counsel for the parties have agreed to submit a brief memo to the Court stating
each of their positions on the holiday schedule for the Court's determination of the
arrangements for these holidays.
Date
ft;/I3/IJ!
(~~ -,
Melissa Peel Greevy, Esquire
Custody Conciliator
'of".'
"
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I Joh'lson, Duffie. Stewart & Weidner
. By: KCirstcn W. Davidson, Esquirc
J.D. No, 78243
301 Markct Strcct
P. O. Box 10')
LCl11oync, Pcnnsylvania 17043-0 I 0')
(717) 761-4540
Attorneys for Defcndant, George Kanganis
ROSEMARIE KAGAN IS,
FORMERLY ROSEMARIE KANGANIS,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96-4601
Plaintiff
v.
CIVIL ACTION - LAW
GEORGE KANGANIS,
CUSTODY
Defendant
MEMORANDUM
The above referenced parties are the natural parents of two (2) minor children, Thomas George, age
14, whose date of birth is November 15, 1986, and Dean George. age 11, whose date of birth is October 27,
1989. The parties have shared legal and physical custody of their children on a 50/50 basis since they
separated and divorced in May of 1997.
The parties attended a custody conciliation on or about June 4, 2001, before Melissa P. Greevy,
Esquire. At the conciliation, the parties were unable to agree on how the Easter and Thanksgiving holidays
should be handled. DefendanUFATHER suggested that the parties divide each holiday in half such that both
parents would be entitled to spend time with the children on Easter and Thanksgiving. Plaintiff/MOTHER
suggested that the holidays be alternated such that one party would enjoy Easter with the children and the
other party would enjoy Thanksgiving with them. Both parties agreed to submit memos to the Court for
resolution of this issue.
FATHER has reconsidered his position on the Easter and Thanksgiving holidays and is willing to
alternate those holidays per MOTHER'S suggestion. FATHER does request however, that he be able to
spend Thanksgiving with the children in the year 2001, as MOTHER had the children for Easter earlier this
year. The schedule as MOTHER proposes would then be as follows:
The children spent Easter with MOTHER in the year 2001 and would spend it with her in all odd
numbered years thereafter, and spend Thanksgiving with MOTHER in the year 2002 and in all even
numbered years thereafter. The children would spend Easter with FATHER in the year 2002 and in all even
numbered years thereafter, and Thanksgiving with FATHER in the year 2001 and in all odd numbered years
thereafter.
MOTHER represented at the conciliation that it was nearly impossible for her to visit with her family in
New York for half of the holiday, and have the boys back in Pennsylvania so they could be with their
FATHER for the other half of the holiday, hence her request that the holidays be alternated rather than
divided in half. Her dilemma was evident when she took the children to New York for Easter earlier this
year, and failed to return them to FATHER until approximately 9:30pm Easter Sunday. FATHER
understands MOTHER'S desire to be able to leave the Harrisburg area during these holidays to travel and
visit her relatives in New York. Therefore, he will agree to MOTHER'S proposal, however again, suggests
that the schedule start with him enjoying Thanksgiving with the children this year, as MOTHER already had
the opportunity to spend Easter with them. To deny FATHER'S request would give MOTHER both holidays,
which is not what either party contemplates.
Respectfully ~ubmitte~(
.~WC~ 'if IV/61
Keirsten W. Davidson
Counsel for DefendanUFATHER
I.AW ortlCES
JOHNSON, DUFFlE, STEWART & WEIDNER
A Professional Corporation
301 MARKET STREET
P. O. BOX t09
LEMOYNE, PENNSYLVANIA 17043.0109
WEBSITE: www.jdsw.com
IIORAC [ ^ JOHNSON
01 COl'N'l(l
IERRY R. DUFFIE
RICHARD W. STEWART
C. ROY WEIDNER. JR
EDMUND G_ MYERS
DAVID W. DLLUCE
RALPH H WRIGHT, IR
DAVID I LANZA
MARK C DUFFIE
KEIRSTEN WALSH DAVIDSON
MICHAEL r C~SIDY
ROBERT M WALKER
TELEPHONE 717.761....540
FACSIMILE 717.761.3015
E-MAIL mall@jJ~w.com
WItlTEIt'S EXT. NO, IH
E-MAIL kwd(tIjJdHW.l:OIll
July 17, 2001
The Honorable Edward E. Guido
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013-3387
Dear Judge Guido:
Pursuant to your Order dated June 19, 2001, enclosed please find a Memo reflecting
DefendanUFATHER'S position with respect to sharing the Easter and Thanksgiving holidays in
the above-referenced matter. Your insight into this matter is appreciated.
Very truly yours,
JOHNSON, DUFFIE, STEWART & WEIDNER
~iNfu1 W~
Keirsten W. Davidson
KWD:jlb:148172
Enclosure
cc: Kathleen Daley, Esquire
George Kanganis
Melissa Greevy, Esquire
a bricfmcmorandum conccming the position of their client on this issue. On that hasis, the counsel
for thc Plaintiff submits this docul11cnt in satisfaction of the tcrms of the Ordcr of Court.
A) Thc Mothcr requcsts that this Court ordcr that the holidays ofThanksgil'ing
and Eastcr bc altcrnatcd bctwccn thc partics.
B) Thc Mothcr of thcsc children residcs in Mcchanicsburg, in closc physical
proximity to thc home of thc Fathcr of thesc childrcn. As such, the sharcd custody
arrangcmcnt works well to providc thc childrcn the bcncfit ofacccss to each of their parcnts.
C) It is thc position of thc Mothcr, Rosemaric Kuganis, that the Ordcr of this
Court should providc that the holidays rclatcd to Eastcr and Thanksgiving bc altcrnated
bctwcen the partics.1t should bc noted that thc Eastcr holiday obscrvcd by these parties is the
Greek Orthodox Eastcr which docs not gcncrally fall on thc samc day as thc Eastcr holiday
celebratcd by thc majority of thc Ccntral Pcnnsylvania population.
D) Thc family ofthc Mothcr rcsides in thc grcatcr New York arca. Thc family
of the Father resides locally and thc childrcn havc acccss to thcir grandparents almost as
frequcntly as they have acccss to their Father. It is thc undcrstanding ofthc undcrsigncd that
the grandparents attcnd a grcat l11any school and sports events ofthesc childrcn and havc thc
bcncfit of thcir companionship on a "cry routine basis.
-2-
Unfortunatcly, the same is not true for the family of the Mother, as thcy are separatcd hy
substantial distancc. Additionally, thc matemal grandmothcr of these children is
bcing trcated for eanccr and has bcen somewhat limitcd in her ability to travel ,IS a
rcsull. It is the position of the Mothcr that by alternating thesc holidays, ncither family will
lose thcir ability to have aceess to thcsc childrcn and thcir Mothcr to havc an opportunity for
a full holiday with their cxtcndcd family of grandparents, aunts, unclcs and cousins that is
VCIY important to thcse individuals.
E) It is acknowledgcd that thc Fathcr has proposcd plans which call for him to
drivc grcat distanccs on Thanksgiving day so as to split this holiday. Howcvcr noblc that
offcr has bccn, it still rcsults in thc childrcn spcnding a grcat deal of timc and cncrgy bcing
transportcd from onc location to thc othcr which will intcrfcrc with thcir ability to enjoy a
full holiday with thcir cxtcnded family.
Thc Plainti ff/Mothcr, rcspectfully asks this Court to issuc an Ordcr directing that thc holiday
of the Orthodox Eastcr bc dctcnmincd to bcgin at thc cnd of school on thc Friday prcccding thc
holiday and cnding thc Monday moming following Eastcr day. This holiday should bc altcrnatcd
such that in evcn numbcrcd ycars, it is cnjoycd by the Mothcr and in odd numbcrcd ycars, it is
cnjoycd by thc Fathcr. ,
It is furthcr rcquestcd that thc Thanksgiving holiday bc dcemcd to bcgin Wcdncsday at thc
conclusion of school and cnd Tucsday moming at thc commcnccl11cnt of schoo\. It is requcstcd that
-3-
this holiday be enjoyed by the Father in even man be red years and by the Mother in odd numbered
ycars. The Mothcr notes she has not Iwd a Thanksgiving holiday with her family since the time of
separation and would greatly appreeiale an Orderdireeting that she can spend Thanksgiving with her
family during the 2001 Thanksgiving holiday.
Respectfully submitted,
Datc: ~4<-e- ;" tJ--~~L
DALEY LA W OF::ES y
By: -- ;;{lb~!:~~~c/r
K~~ Carcy Dalcy, ~irc \J
Attomcy No. 30078
1029 Sccncry Drive
Harrisburg, P A 17109
(717) 657-4795
Attomcy for Plaintiff
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C) 5' 2DlJt
DALEY LAW OFFICES
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In,!l) SUNEHY [}I{1\T . IlARltI."'HlIK(j,I'/\ I'I()<)' 1"'1 "1 (,,!' 1"1') . h\X f ']') (0') I.I'J')(,
July 2, 200t
Cumbcrland County Courthouse
Officc of Prothonotary
One Courthouse Square
Carlisle, P A 17013
Rc: Kaganis v, Kanganis
No. 96-460] - In Custody
Dear Sir or Madam:
Encloscd please find an original and thrce copies of a Memorandum which wc would like
to filc on bchalf of our client, Rosemaric Kaganis, thc Plaintiff in the abovc rcfcrenccd case,
Plcasc til11e-stamp the copics and rctum thcm to our officc in the encloscd self-addressed
stamped cnvelopc.
Thank you.
Very truly yours,
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Barbara J. Hoffman
Paralcgal
:bjh
Enclosurcs
cc: Rosel11aric Kaganis
ROSEMARIE KAGANIS (FORMERL Y
ROSEMARIE KANGANIS
PLAINTIFF
V.
GEORGE KANGANIS
IJEFENIMNT
IN 1I11,('(lIIIU(lI.('()MMON I'I.EASOI:
('lIMBERI.AND ('01 INTY. PI.:NNSY1.V ANIA
%-4f101
CIVIL ACTION LAW
IN ('IISlOIJY
OIWER OF ('01 :In
AND NOW,
Friday, April 27. 2001
. upon consideration or the attached Complaint.
it is hercby directed that parties and their respeclive ellullsel appear helllre Melissa P. Greevy. Esq.
at 214 Senate Avenue, Suite 105, Camp 1Iill,I'A 17011 1111 ,__--"lol1do)., May 21, 2001
, the conciliator.
at 1 I :00 a.m.
for a Prc.Hcaring Custody Conference. At such conlcrcllcc. a:1 errort will he made 10 resolve the issues in dispute: or
if this cannot be accomplished, to define and narrow the isslles to be heard by the court. and 10 cntl:r into a temporary
order. All children age five or oIl.kr may also he prL'scnt at thl.' conlcn..'llcc. Failure to appear at the conference may
provide grounds for entry of a temporary 01' permanent order.
The court hereby directs the parties to furuish auy aud all e,istin~ Proteetiou from Abuse orders,
Spceial Relief orders, aud Custody orders to the eoncilialor 48 hours prior to scheduled hearing.
FOR TilE COURT,
By: Isl
~C1i~S(Ll'~GLcrS)y,JiS1J' it
('ustmll' ('om:ilialor
The Court of C'0I111110n Pleas ol'Cul11berland County is required by law 10 comply witb Ihe
Al11erieans with Disabilites Act of 1990. For inl<lrl11ation about accessible l'leilities and reasonable
accommodations available to disahled individuals ha\'ing business hc.:forc the court. please contact ollr office.
All arrangements must be made at lenst 72 hours prior to any hearing or husiness before the court. You must
allend the scheduled eonferenee or hearing.
YOU SHOULD TAKE TillS PAPER TO YOllR A'ITORN!:Y AT ONC!:. IF YOI! DO NOT
HA VE AN ATTORNEY OR CANNOT AFFORD ON!:. (jO TO OR TELEPIIONE TilE OFFI('E SET
FORTH BELOW TO FIND OUT WHERE YOU CAN (i!:T 1.1'.( JAI. liEU'.
('tlmherland ('ollnly Bar Association
2 I ,ihcrly ^ venue
Carlisle. Pennsyl\'ania 17013
Telephone (717) 24'1-:11 !J(,
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5. The parties ability to communicate cordially has significantly deteriorated over the past
several months. For exarr.ple, MOTHER continuously leaves derogatory messages on FATHER'S
answering machine, often times criticizing him as a parent, at times when she knows the children are in
FATHER'S custody, and will very likely access these messages.
6. Furthermore, when the children are in MOTHER'S custody, FATHER has significant difficulty
speaking with them on the telephone.
7. FATHER believes that a) the parties inability to communicate cordially; and b) MOTHER'S
continued impediment to FATHER'S telephone communications with the boys is adversely affecting the
children.
8. Furthermore, while the shared physical custodial schedule is outlined in detail in the parties'
Agreement, the holiday schedule is not. Because of the parties inability to communicate in a cordial and
effective manner, numerous problems have arisen with respect to the holiday schedule. For example, on
two (2) consecutive Easter holidays, MOTHER took the children out of state and did not return them to
FATHER until approximately 8:00 p.m., there by spoiling the holiday plans FATHER and his family had,
9. Given this breakdown in communication, FATHER believes it is necessary to develop a
specific holiday schedule so as to avoid future confusion and confrontation.
10, Given the above, FATHER also believes it is necessary to address the concept of
reasonable telephone contact between the non-custodial parent and the children.
WHEREFORE, FATHER respectfully requests this Court to modify the existing custody agreement
to provide a specified holiday schedule and to address reasonable telephone contact between the non-
custodial parent and children.
JOHNSON, DUFFIE, STEWART & WEIDNER
BY:~ lJ'y~
Keirsten W. Davidson
145331
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03^1303~
ROSEMARIE KANGANIS,
PlaintitT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
v.
NO. 96-4601 CIVIL
GEORGE KANGANIS,
Defendant
IN DIVORCE
ELECTION TO RETAKE MAIDEN NAME
Notice is hereby given that the Plaintift: in the above matter, having been granted a Final
Decree in Divorce on the 3rd day of June, 1997, hereby elected to retake and hereafter use her
l11aidenname of Rosemarie Kaganis, and gives this written notice avowing hcr intention in accordance
with the provision of 54 Pa.C.S.A. s704(a).
'I ~
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't~" J. ,'(1.;1/ Ii n
RO EMARIE KANGANIS
Date:
'-3/:>10 l78
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TO BE KNOWN AS:
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ROSEMARIE KAGANIS
,~
GEORGE T. KANGANIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
v.
ROSEMARIE KANGANIS,
Defendant
NO. 96-4601 CIVIL TERM
ORDER OF COURT
AND NOW, this ~ tt day of June, 1997, upon relation of Mary
Kollas Kennedy, Esq., on behalf of Plaintiff, that an agreement as
to custody has been reached by the parties, the custody hearing
scheduled for August 25, 1997, is CANCELLED.
BY THE COURT,
,
r:
Mary Kollas Kennedy, Esq.
1104 Fernwood Avenue
Camp Hill, PA 17011
Attorney for Plaintiff
Kathleen Carey Daley, Esq.
1029 Scenery Drive
Harrisburg, PA 17109
Attorney for Defendant
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I. The settling of all matters between them relating to the ownership of real and
personal property including property heretofore or subsequently acquired by either party;
2. The settling of all disputes, rights and/or interests between them arising out of or
by reason of their marriage including but not limited to the past, present and future support,
alimony, counsel fees, costs or maintenance of Wife by Husband or of Husband by Wife;
3, In general, the settling of any and all actual and possible claims by each party
against the other or against their respective estates.
NOW TIIEREFORE, in consideration of the premises and of the mutual promises,
covenants and undertakings set forth in this Agreement and for other good and valuable
consideration, the receipt and adequacy of which is hereby acknowledged by each of the parties
hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as
follows:
1. Advice a/Counsel. The provisions of this Agreement and their legal effect have
been fully explained to the parties by their respective counsel, Kathleen Carey Daley, Esquire, of
Harrisburg, Pennsylvania, for Wife and William C, Kollas, Esquire, of Camp Hill, Pennsylvania,
for Husband. The parties acknowledge that each has received independent legal advice from
counsel of his or her own selection, tbat each has fully disclosed his or her respective financial
situations to the other including his or her property, estate, assets, liabilities, income and expenses,
that each is familiar with and fully understands the facts, including the property, estate, assets,
earnings and income of the other, and that each has been fully infoffiled as to his or her legal
2
rights and obligations. Each of the panies acknowledges and agrees that, after having received
such advise and with such knowledge, the Agreement is, in the circumstances, fair reasonable and
equitable, that it is being entered into freely, volWltarily, and in good faith and that the execution
of the Agreement is not the result of any duress, Wldue influence, coercion, collusion and/or
improper or illegal Agreement. The panies further acknowledge that they have each made to the
other a full and complete disclosure of their respective assets, estate, liabilities, and sources of
income and that they waive any specific enumeration thereoffor the purposes of this Agreement.
2. DefinitiollS.
(a) Divorce Code. The phrase "Divorce Code" shall be defined as Act No.
1990-206,23 Pa.C.SA ~ 3101 et seq.
(b) Date of Execution of this Agreement. The phrase "date of execution" or
"execution date" of this Agreement shall be defined as the date of execution by the panies if they
have each executed the Agreement on the same date. Otherwise, the "date of execution" or
"execution date" of this Agreement shall be defined as the date of execution by the pany last
executing this Agreement.
3. Effective Date of Agreement. This Agreement will become effective and binding
upon both panies upon execution of this Agreement by both of them.
4, Effect of Divorce Decree--Incorporatioll, No Merger. The panies agree that
Wlless otherwise specifically provided hcrein this Agrecment shall continue in full force and effect
after SlIch time as a final decision in divorce may be entcred with respcct to the panies. Husband
3
and Wife agree that the terms of this Agreement shall be incorporated but not merged into any
divorce decree which may be entered with respect to the parties and therefore Wife and Husband
agree and each of the parties does hereby warrant and represent to the other that should either of
them obtain a decree, judgment or order of separation or divorce in any state, country or
jurisdiction, that party will take all reasonable steps to have this Agreement incorporated as part
of any such decree, judgment or order. The parties further agree that the Court of Common Pleas
which may enter such divorce decree shall retain continuing jurisdiction over the parties and the
subject matter of the Agreement for the purpose of enforcement of any of the provisions thereof
Nevertheless, it specifically is understood and agreed by and between the parties
hereto and each of the said parties does hereby warrant and represent to the other that should
either of the parties obtain a decree, judgement or order of separation or divorce in any state,
country or jurisdiction, each of the parties agrees that all of the provisions of this Agreement shall
not be affected in any way by any such separation or divorce, it being agreed by the parties that
this Agreement shall continue in full force and effeet after such time as a final decree a divorce
may be entered and shall survive and not be merged into any such decree, judgment or order.
5. Effect all Divorce. The parties agree to take all legal steps (including timely and
prompt submission of all documents and the taking of all action including executing the
appropriate waivers of notice of the master's hearing, right to file exceptions, and right to file
appeal) necessary to assure that a divorce pursuant to Section 330 I of the Divorce Code is
entered as soon as possible, but in any cvent not later than three (3) weeks from the date of
execution of this Agreement. To that end, the parties have executed and agree to promptly file
4
the affidavits required to obtain a divorce pursuant to ~ 3301(c) of the Divorce Code,
If; after the execution of this Agreement, either party delays or contests the
obtaining of a final, unappealed divorce decree, that party shall be fully responsible for all
attorney's fees, costs and/or expenses incurred as a result of such delay in obtaining the decree.
6. Effect of No Divorce. This Agreement is predicated upon and made subject to the
attainment ofa final dccree in divorce under Sections 330l(c) of the Divorce Code and therefor,
except as otherwise provided for herein, this Agreement will be null and void if a fmal decree in
divorce is not obtained with three (3) months of the date of execution of this Agreement.
7. Warranty of Disclosure. Husband and Wife represent and warrant that they have
disclosed to each other the full extent of their assets, income and liabilities. Each party has had
ample opportunity to review the financial condition of the other and each party agrees not to
challenge the instant Agreement based on an allegation oflack of sufficient disclosure of assets or
income.
8. Equitable Distribution of Property.
(a) Premises. Husband and Wife hold title as tenants by the entireties of the
premises identified as 5275 Strathmore Drive, Mechanicsburg, Cumberland County, Pennsylvania
17055 (the "Marital Residence"). A legal description of the "Marital Residence" is attached
hereto as Exhibit "A." The Marital Residence is to be sold, with the proceeds to be applied as
follows:
5
(i) The mortgage on the Marital Residence through
NationsBank is to be satisfied, / I ~ ___'Il.. J I
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(ii) Wife will receive $25,000.00 after the sale of the horn, rerrdless {!:
of the selling price of the "Marital Residence." 1J-.ll?'I (lJ ~
(iii) Providing proceeds from the sale of the home remain, they
will be paid to Husband for satisfaction of the following debts:
a) The line of credit with Dauphin Deposit Bank and Trust,
balance $4,520.00, is to be satisfied.
b) The following marital credit card debt:
Visa
MCNisa
Boscov's
Hechinger's
John Wanamaker's
Montgomery Wards
$1,214.38
$2,458.85
$593.08
$211.48
$290.46
$1,085.98
(iv) Husband may retain any remaining proceeds from the sale of the
home. To the extent proceeds from the sale of the marital residence are
insufficient to pay the debts aforementioned, Husband agrees to assume the debts
and hold Wife harmless therefrom.
(vi) Husband agrees to pay the mortgage on the Marital Residence from
the date of execution of this Agreement as long as he resides in the marital
property. Husband shall not be required to pay any arrearages on the mortgage.
6
(b) Contents a/Marital Residence. As of the date of execution, Wife shall set
over, transfer and assign all of her right, title and interest in all of the contents of the Marital
Residence as of the date of execution of this Agreement, including but not n~cessarily limited to
all furniture, furnishings, rugs, carpets, household appliances and equipment, pictures, paintings,
books, decorations, works of art, silver, china, glassware and other items of tangible personal
property of whatever nature ("Contents") currently located in the Premises, except that Wife shall
receive the following items:
1. Lace tablecloth
2. Living room needlepoint picture
3. Small wooden table with contents
4. Balance ofFarberware pots
5. Two (2) green blankets from Greece
By these presents, each of the parties hereby specifically waives, releases,
renounces, and forever abandons whatever claims he or she may have with respect to any of the
above items which shall become the sole and separate property of the other from the date of
execution hereof.
Husband hereby releases and relinquishes all claims and demands whatsoever as to
the whole or separate part of the said items of personalty which are distributed to Wife.
(c) Medical Insurance. The Husband shall be responsible for the Wife's
medical insurance through June 30, 1997, Thereafter, the Wife shall make the necessary
provisions to insure herself.
(d) 40IK. The parties acknowledge that Husband has a pension plan in the
fonn ofa 401K through his employer and that a portion of that account has been identified as
7
marital property. Wife hereby specifically waives, releases, renOWlces, and forever abandons
whatever claims she may have with respect to Husband's 40lK plan and said plan shall become
the sole and exclusive property of the Husband from the date of execution hereof.
(e) Automobile. Upon execution hereof, Husband agrees that Wife shall retain
possession of and receive as her own property the 1989 Volkswagen Jetta for her own use and
disposition. Husband agrees to execute, acknowledge and deliver upon request of Wife any and
all instruments or documents necessary in order to effectuate the transfer of title of said
automobile to Wife. Wife shall be solely responsible for the payment of any sales or other tax that
might be incurred with respect to that transfer and for the payment of any expenses relating to the
automobile. Wife shall be solely responsible for all expenses associated with the automobile
including but not limited to insurance, maintenance, and any loan thereon, Wife shall be solely
liable and shall keep Husband indenmified and held harmless from any liabiliry, cost or expense,
including attorney's fees, due to any of the expenses set forth in the preceding sentence and shall
indemnifY and hold Husband harmless from any liability, cost or expense, including but not limited
to claims, damages and judgments, solely due to any accidents involving Wife prior to the transfer
of the title to Wife and Wife shall reimburse Husband for any increased premiums during the year
following the date of execution of this Agreement solely resulting from such accidents.
(f) The parties agree that Husband shall receive the entire refund due from the
parties joint Federal 1996 income tax return.
9. Alimony and Child Support.
(a) Commencing on the 16th day of June and for a period often (10) years
8
~ 0....
of the terms of this paragraph in a court of law or equity, it being understood that the foregoing
constitutes a final determination for all time of Husband's obligation to contribute to Wife's
support and maintenance. The parties agree for the purposes of income taxation that these
payments shall not be includable to Wife's income and shall not be deductible from Husband's
income, but shall have no tax consequences.
10. Credit. Wife and Husband represent that they have taken all steps necessary to
make sure that no credit cards or similar accounts exist which provide for joint liability. From the
date of execution of this Agreement, each party shall use only those cards and accounts for which
that party is individually liable.
II. CoulISe/ Fees. Husband and Wife agree each party shall be responsible for his or
her own legal fees and expenses, except that, in the event of a breach of this Agreement, fees shall
be recoverable by a non-breaching party in an action to enforce the provisions of this agreement.
12. Warrallty as to Future Ob/igatiollS. Wife and Husband each covenants,
represents, warrants, and agrees that, except as may be otherwise specifically provided for by the
terms of this Agreement, neither of them shall hereafter incur any liability whatsoever for which
the other or the estate of the other may be liable, and each now and at all times hereafter shall
indemnify and hold harmless the other party from and against any such liabilities, costs or
expenses, including attorney's fees, relating thereto incurred by the other party after the date of
execution of this Agreement.
10
13. Warranties as to Existing Ob/igatiollS. During the course of the marriage,
Husband and Wife have incurred certain liabilities and it is hereby agreed, without the necessity of
ascertaining for what purpose and for whose use each of the bills was incurred, that of those
liabilities that were incurred prior to the date of execution of this Agreement, Wife and Husband
each covenants, represents, warrants and agrees that, except as may be otherwise specifically
provided for by the terms of this Agreement, as of the date of execution of this Agreement, no
unpaid liabilities remain which were incurred by him or her or on his or her behalffor which the
other party may be deemed liable; and, if any such debts or obligations should be detennined to
have existed as of the date of execution of this Agreement, the party who incurred that debt shall
indemnifY and hold the other party hannless for and against any loss or liability and costs or
expense, including attorney's fces, incurred as a result of those liabilities.
14. Mutual Releases. Except, and only except, for all rights, agreements and
obligations of whatsoever nature arising under or which may arise under this Agreement or for the
breach of any part of this Agreement, Wife and Husband each do hereby mutually remise, release,
quitclaim and forever discharge the other and the estate of the other, for all time to come, and for
all purposes whatsoever, of and from any and all rights, title and interest, or claim in or against the
property (including income, and gain from property hereafter accruing) of the other or against the
estate of the other, of whatever nature and wheresoever situate, which he or she now has or at
any time hereafter may have against the other, the estatc of the other or any part thereot; whether
arising (a) out of any fonner acts, contracts, engagements or liabilities of such other, (b) by way
of dower or courtesy or claims in the nature of dower or courtesy or widow's or widower's rights,
11
(c) as family exemption or similar allowance, or (d) under tbe intestate laws, the right to take
against the spouse's will, 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 (i) Pennsylvania, (ii) any other State, Commonwealth or territory of the United
States, or (iii) any other country. Except, and only except for all rights, agreements and
obligations of whatsoever nature arising under or which may arise under this Agreement or for the
breach of any part of this Agreement, the parties agree that tltis Agreement shall be and constitute
a full and final resolution of any and all claims which each of the parties may have against the
other for equitable distribution of property, alimony counsel fees and expenses, alimony pendente
lite or any other claim pursuant to the Pennsylvania Divorce Code or the divorce laws of any
other jurisdiction. The parties further release and waive any rights which either party may have
now or hereafter against the other including but not limited to claims for past, present or future
support or maintenance, alimony, alimony pendente lite, property division (including but not
necessarily limited to equitable distribution), counsel fees, costs or expenses, whether arising as a
result of the marital relation or otherwise, whether under the Divorce Code or otherwise. Except,
and only except, for all rights, agreements and obligations of whatsoever nature arising under or
which may arise under this Agreement or for the breach of any part of this Agreement, it is the
intention of Wife and Husband to give to each other by the execution of this Agreement, and full,
complete and general release with respect to any and all property of any kind or nature, whether
real, personal or mixed, which the other now owns or may hereafter acquire.
15. Mutual Waivers. Wife and Husband acknowledge that by this Agreement they
12
each respectively have secured and maintained a substantial and adequate fund with which to
provide themselves sufficient resources for his or her comfort, maintenance and support according
to the standard of living to which the party is accustomed. Therefore, except as provided for in
this Agreement, Wife and Husband do hereby waive, release, and give up any rights that they may
respectively have, either at the present or in the future, against the other for equitable distribution,
alimony, support, maintenance, or for any other right resulting from their status as Wife and
Husband. Wife and Husband agree that neither party may apply to any court for a modification of
this Agreement, with respect to alimony, distribution of property, or otherwise, whether pursuant
to the Divorce Code or any other present or future statute or authority. Except as provided fol' in
this Agreement, it shall be the sole responsibility of Wife and Husband to sustain herself or himself
without seeking any support from the other party from the date of execution of this Agreement.
In the event that either of the parties shall nevertheless seek such a modification, that party shall
indemnifY and hold the other party harmless from and against any loss resulting therefore,
including counsel fees and costs.
16. Custody. The parties are the parents of two (2) children, Thomas George, born on
November 15, 1986, and Dean George, born on October 27, 1989. The parties agree that they
shall have shared legal and shared physical custody of the children on the following schedule:
Week One: Starting on Tuesday at 3:00 p.rn., Father shall have custody of the children
until Friday at 3:00 p,m. Mother shall have custody from Friday at 3:00 p.rn. until 5:00 p.rn.
Sunday. Father shall have custody from 5:00 p.m. Sunday night until 3:00 p.rn. on Tuesday.
Week Two: Mother shall have custody of the children from Tuesday at 3:00 p.rn. until
13
- -....
Friday at 3:00 p.rn. Father shall have custody of the children from Friday at 3:00 p.rn. until
Sunday at 5:00 p.rn. Mother shall have custody of the children from Sunday at 5:00 p,rn. until
Tuesday at 3:00 p,rn.
This two week schedule shall thereafter repeat itself and continue on an ongoing basis.
The parties agree that each will have three weeks of vacation with the children to be taken
in increments no greater than ten (10) days, The parties agree that each will provide the other
with at least thirty (30) days' written notice of these periods of vacation and shall provide the
other with the telephone number and address where the children will be during these periods of
vacation.
Holidays will be shared as the parties agree. Mother may have custody of the children
every Mother's Day. Father may have custody of the children every Father's Day.
The parties agree that Husband shall claim the children as exemptions on his returns for
the purpose offederal and state income taxation.
17. Waiver or Modification to be in Writing. No modification or waiver of any of the
terms hereof shall be valid unless in writing and signed by both parties and no waiver of any
breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the
same or similar nature.
18. Mutual Cooperation Each party shall, at any time and from time to time
hereafter, take any and all steps to execute, acknowledge and deliver to the other party any and all
further instruments and/or (within at least fifteen days after demand therefore) documents that the
other party may reasonably require for the purpose of giving full force and effect to the provisions
14
of this Agreement.
19. Law of Pel/I/sylval/ia Applicable. This Agreement shall be construed in
accordance with the laws of the Commonwealth of Pennsylvania which are in effect as ofthe date
of execution of this Agreement.
20. II/tegration This Agreement constitutes the entire understanding of the parties
and supersedes any and all prior agreements and negotiations between them There are no other
representations, terms, covenants, conditions, agreements or warranties, express or implied, oral
or written of any nature whatsoever, other than those expressly set forth herein.
21. Severability. If any term, condition, clause or provision of this Agreement shall be
determined or declared to be void or invalid in law or otherwise, then only that term, condition,
clause or provision shall be stricken from this Agreement and in all other respects this Agreement
shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to
meet her or his obligations under anyone or more of the Paragraphs herein, with the exception of
the satisfaction of the conditions precedent, shall in no way void or alter the remaining obligations
of the parties.
22. eOl/traetIl/terpretation For purposes of interpretation and for the purpose of
resolving any ambiguity herein, Husband and Wife agree that this Agreement was prepared jointly
by their respective attorneys.
23. Waiver of Liability. Husband and Wife each knowingly and IUlderstandingly waive
15
any and all possible claims that this Agreement is, for any reason, illegal or for any reason
whatsoever of public policy, Wlenforceable in whole or in part. Husband and Wife each does
hereby warrant, covenant and agree that, in any possible ever.!, he or she is and shall forever be
estopped from asserting any illegality or Wlenforceability as to all or any part of this Agreement.
IN WITNESS WHEREOF, the patties hereto have set their hands and seals the day and
year first above written.
&~~
William C. Kollas, Esquire
16
4. Related claims pending: None
5. (Complete either (a) or (b).)
(a) Date and manner ofserviee of the notice of intention to file praecipe to
transmit record; a copy of which is attached:
(b) Date Plaintiff's Waiver of Notice in g3301(c) Divorce was filed with the
Prothonotary: June 2, 1997
Date Defendant's Waiver of Notice in g3301(c) Divorce was filed with
the Prothonotary: May 14, 1997
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.. ,.
.. ,
ROSEMARIE KANGANIS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
v.
NO. (j&- 4&,(11
C ((L" C
GEORGE KANGANIS,
Defendant
: IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth
in the following pages, you must take prompt action. You are warned that if you fail to do so, the
case may proceed without you and a decree of divorce or annull11ent may be entered against you by
the Court. A judgment may also be entered against you for any other claim or relief requested in
these papers by the Plaintiff. You may lose money or property or other rights important to you,
including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the l11arriage, you
may request marriage counseling. A list of marriage counselors is available in the office of the
Prothonotary. Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania
17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
Cumberland County Courthouse
One Courthouse Square
Carlisle, P A 17013
(717) 240-6200
4. The Plaintiff and Defendant were l11arried on October 14, 1979, in Bronx, New York.
5. Neither Plaintiff nor Defendant is in the military or navai service of the United States
or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of ] 940
and its Amendments.
6. The cause(s) of action and section(s) of Divorce Code under which Plaintiff is
proceeding are:
A. Section 3301(c). The marriage of the parties is irretrievably broken.
After ninety (90) days have elapsed from the date of the filing of this Complaint,
Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that
Defendant may also file such an Affidavit.
S. Section 3301(d). The marriage of the parties is irretrievably broken.
The Plaintiff and Defendant separated on July 1,1995.
7. There have been no prior actions in divorce between the parties.
8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have
the right to request the parties to participate in counseling.
9. The parties may enter into a written agreement with regard to support, custody,
visitation of children, alimony and property division. In the event that such an agreement is executed
by the parties, the agreement may be incorporated by the Court into the final Decree of Divorce.
WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce,
divorcing Plaintiff and Defendant.
. --,-.....
.
~
COUNT II
EQUITABLE DISTRIBUTION
10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference as
though set forth in full.
11. Plaintiff and Defendant have acquired property, both real and personal during their
marriage from the date of their marriage until July 1, 1995, the date of their separation.
12. Plaintiff and Defendant have been unable to agree as to an equitable division of said
property.
WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital
property.
COUNT HI
ALIMONY
13. Paragraphs 1 through 9 of this Complaint are incorporated herein by r~ference as
though set forth in full.
14. Plaintiff lacks sufficient property to provide for her reasonable means and is unable
to support herself through appropriate employment.
15. Plaintiff requires reasonable support to adequately l11aintain herself in accordance with
the standard ofliving established during the marriage.
ROSEMARIE KANGANIS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
v.
NO. 96-4601 CIVIL
GEORGE KANGANIS,
Defendant
IN DIVORCE
AFFIDA VIT OF SERVICE
Kathleen Carey Daley, Esquire, being duly sworn according to law, deposes and says that she
is an attorney at law duly authorized to practice in the COl11l11onwealth of Pennsylvania, and that on
the 21st day of August, 1996, she did serve upon George Kanganis, the Defendant in the foregoing
case, a true and correct copy of the Complaint in Divorce by sending to him, by certified mail,
restricted delivery, to 3607 Rosemont Avenue, Camp Hill, Pennsylvania 17011. The receipt for said
COl11plaint is attached.
Said copy of the Complaint was duly endorsed with notice to Defendant to appear and answer
or the matter would proceed without him.
Sworn to and subscribed before me this
~dayof
ive.mL'/l
,1996
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athleen Carey Daley, ,sq. (
Attorney No. 30078__/
1029 Scenery Drive
Harrisburg, P A ] 7109
(717) 657-4795
Attorney for Plaintiff
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ROSEMARIE KANGANIS,
Plaintill.
IN TilE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
v.
NO. 96-4601 CIVIL
GEORGE KANGANIS,
Defendant
IN DIVORCE
AFFIDA VIT OF CONSENT
1. A Complaint in Divorce under Scction 3301(c) of the Divorce Code was filed on August
15,1996.
2. The l11aniage ofPlaintitTand Defcndant is irretrievably broken and nincty (90) days have
elapsed from the datc of filing and serviee ofthc Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request cntry of the decree.
[ verifY that the statements madc in this Affidavit are true and correct. I understand that false
statcments hcrcin are made subjcct to the pcnaltics of 18 Pa.C.S.A. ~4904 relating to unsworn
falsification to authorities.
Date: 9'(j1
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
v.
NO. 96-4601 CIVIL
GEORGE KANGANIS.
Defendant
IN DIVORCE
AFFIDA VIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August
15, 1996.
2. The maniage ofPlaintitTand Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of tiling and scrvice of the Complaint.
3. I conscnt to the entry ofa final decree of divorce after service of notice of intention to
request entry of the decrce.
I verity that the statements made in this Al11davit arc tme and corrcct. I understand that false
statements hcrein are madc subject to thc penalties of 18 Pa.C.SA ~4904 relating to unsworn
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OFFICE OF DIVORCE MASTER
CUMBER LANa COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240-6535
E. Robert Elicker, II
Divorce Master
Tracl .10 Colyer
Office Manager/Reporter
West Shore
697-0371 Ex!. 6535
November 14, 1996
Kathleen Carey Daley
Attorney at Law
1029 Scenery Drive
Harrisburg, PA 17109
Mary Kol1as Kennedy
Attorney at Law
KOLLAS & KENNEDY
1104 Fernwood Avenue
Camp Hill, PA 17011
RE: Rosemarie Kanganis vs. George Kanganis
No. 96 - 4601 civil
In Divorce
Dear Ms. Daley and Ms. Kennedy:
By order of Court of President Judge Harold E. Sheely
dated November 8, 1996, the full-time Master has been appointed
in the above referenced divorce proceedings.
A divorce complaint was filed on August 15, 1996, raising
grounds for divorce of irretrievable breakdown of the marriage.
According to the complaint, the parties separated on July 1,
1995; therefore, I assume that the parties are willing to go
forward with the divorce by filing affidavits of consent under
section 3301(c) of the Domestic Relations Code since they have
not been separated in excess of two years.
The motion for appointment of Master indicates that Mary
K011as Kennedy has appeared in the action; I do note that she
appeared in the custody proceedings but has not appeared in the
divorce proceedings. I request that Ms. Kennedy enter her
appearance in the divorce action if she intends to represent the
Defendant.
The complaint raised economic claims of equitable
distribution, alimony, alimony pendente lite, and counsel fees
and expenses. Assuming that grounds for divorce are not an
issue, I am directing each counsel to file a pre-trial statement
in accordance with P.R.C.P. 1920,33(b) on or before Monday,
December 9, 1996. upon receipt of the pre-trial statements I
,.
,
ROSEMARIE KANGANIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 96 - 4601 CIVIL
GEORGE KANGANIS,
Defendant
IN DIVORCE
RE:
pre-Hearing Conference Memorandum
DATE: Wednesday, March 5, 1997
Present for the plaintiff, Rosemarie Kanganis, is
attorney Kathleen Carey Daley, and present for the Defendant,
George Kanganis, is attorney William C. Kollas.
A divorce complaint was filed on August 15, 1996,
raising grounds for divorce of irretrievable breakdown of the
marriage. Counsel have advised that the parties will sign and
file affidavits of consent prior to the hearing to be scheduled
in these proceedings so that the divorce can be concluded under
section 3301(C) of the Domestic Relations Code.
The divorce complaint also raised economic issues
of equitable distribution, alimony, alimony pendente lite, and
counsel fees, costs, and expenses.
with respect to the alimony claim counsel have
indicated that there may be an issue with respect to marital
misconduct; however, counsel for wife is going to check with her
client to see if wife will stipulate that she was engaging in an
extra marital affair during the time that the parties were
married and living together. If wife will not stipulate to that
specific marital misconduct then the hearing that is scheduled
in this matter will be used to take testimony on that issue.
The Master has also been told that there may be an issue with
respect to the date of separation. The divorce complaint states
the date as July I, 1995; Mr. Kollas has indicated that his
client generally does not have a problem with that date although
that date may be an issue with respect to the utilization of a
sum of money in a savings account. Therefore, if we need to
take testimony on the date of separation we will take that
testimony at the same time that we take the marital misconduct
testimony.
The parties were married on october 14, 1979, and
are the natural parents of two children, Thomas, age 10 and
Dean, age 7. The parents have worked out an interim arrangement
with respect to custody of the children. Neither parent is
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receiving or paying child support.
wife is 36 years of age and presently resides at
5275 Strathmore Drive, Mechanicsburg, Pennsylvania, which is the
marital residence. Her counsel has indicated that she is
probably going to be moving from that premises in the next few
days and taking up residence in the neighborhood at another
address. Wife has a two year associates degree from thn
Harrisburg Area community College. She is presently working
part-time at Weight Watchers with an annual gross income of
$13,000.00. The Master asked about the issue of whethor or not
wife's income potential is more than the current income she is
reporting. Her counsel indicated that she probably could earn
additional money if she were working full-time but she works
part-time in order to be able to spend time as a caretilker for
the two minor children. Wife has not raised any heillth IB[llIen.
She is not receiving any spousal support or alimony pendente
lite at this time.
Husband is 41 years of age and resides ilt ~27~
Strathmore Drive, Mechanicsburg, Pennsylvania, in the marital
residence. He has a bachelor's degree and is presently a silles
representative for Teleflora, a florist delivery service. Ills
salary as reported on his income tax return for 1995 Includlnq
his regular pay and bonuses was $75,000.00. Husband has not
raised any health issues.
with respect to health insurance, wife is
attempting to obtain benefits through her employer rather thiln
using any COBRA benefits through husband's employment.
The parties own real estate where they hilve been
residing at 5275 Strathmore Drive, Mechanicsburg, Pennsylvania.
The house has not been appraised but the parties have qenerally
agreed that it will be listed for sale and counsel will attempt
to work out the details of the realtor to handle the transaction
as the listing agent. The market value will be established,
therefore, by the sale price. The house is subject to a
mortgage in favor of Eastern Mortgage Service with an
approximate payoff of $130,600.00. The house is also subject
to a lien in favor of Dauphin Deposit Bank on a line of credit
with a balance of around $4,500.00.
The parties own two vehicles, iI t9B9 VW Jetta and a
1990 Plymouth Voyager, Wife is qoinq to retain possession of
the Jetta and husband will retain possession of the Voyager.
The values of those vehicles will not lIsod in the equitable
distribution computation and the parties aqree that each will
retain the vehicle presently in his or her possession.
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wife obtained control of approximately $15,400.00
in a savings account which wife's counsel has agreed was a
marital account. However, wife is claiming that during the
period of 1995 to the present she has used some of those funds
for marital obligations. Therefore, wife's counsel is taking
the position that wife should not be charged with having
received all of those funds in the equitable distribution
computation. Wife's counsel is going to provide information
regarding how monies were expended for marital obligations.
Husband is a participant in a 401(k) plan through
his employment. The marital portion as of July 1, 1995, was
$5,284.26. That figure can be updated to the date of the
hearing adding an interest factor for the marital portion.
The parties have both provided a list of household
tangible personal property. They hope to be able to distribute
the property between them. There is a question, however, as to
whether we will use values for the property each party receives
in the equitable distribution computation. If the value of the
property and the possession of the property become an issue then
the parties agree to have an appraisal done of the property in
each of the party's possession. That appraisal will be one way
of establishing a value for that property.
Both parties have listed creditors on the pre-trial
statements. The marital debt statements need to be provided
showing the debt at the date of separation and the remaining
debt at the date of the hearing. The Master will also be
needing to know who made payments on account of the existing
obligations from the date of separation to the date of the
hearing so appropriate credits can be applied.
A hearing is scheduled for Wednesday, May 28, 1997,
at 9:00 a.m. As previously noted, the hearing will deal with
the issues of marital misconduct and the date of separation, if
necessary; otherwise, if counsel advise the Master that those
issues are resolved then the hearing will deal with economic
issues and the factors in the Divorce Code relating to those
issues other than marital misconduct. Notices will be sent to
counsel and the parties.
E. Robert Elicker, II
Divorce Master
1. The settling of all matters between them relating to the ownership of real and
personal property including property heretofore or subsequently acquired by either party;
2. The settling of all disputes, rights and/or interests between them arising out of or
by reason of their marriage including but not limited to the past, present and future support,
alimony, counsel fees, costs or maintenance of Wife by Husband or of Husband by Wife;
3, In genera~ the settling of any and all actual and possible claims by each party
against the other or against their respective estates.
NOW THEREFORE, in consideration of the premises and of the mutual promises,
covenants and undertakings set forth in this Agreement and for other good and valuable
consideration, the receipt and adequacy of which is hereby acknowledged by each of the parties
hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as
follows:
1. Advice ofCoullSel. The provisions of this Agreement and their legal effect have
been fully explained to the parties by their respective counse~ Kathleen Carey Daley, Esquire, of
Harrisburg, Pennsylvania, for Wife and William C. Kollas, Esquire, of Camp Hill, Pennsylvania,
for Husband. The parties acknowledge that each has received independent legal advice from
counsel of his or her own selection, that each has fully disclosed his or her respective financial
situations to the other including his or her property, estate, assets, liabilities, income and expenses,
that each is familiar with and fully understands the facts, including the property, estate, assets,
earnings and income of the other, and that each has been fully informed as to his or her legal
2
rights and obligations. Each of the parties acknowledges and agrees that, after having received
such advise and with such knowledge, the Agreement is, in the circumstances, fair reasonable and
equitable, that it is being entered into freely, voluntarily, and in good faith and that the execution
of the Agreement is not the result of any duress, undue influence, coercion, collusion and/or
improper or illegal Agreement. The parties further acknowledge that they bave each made to the
other a full and complete disclosure of their respective assets, estate, liabilities, and sources of
income and that they waive any specific enumeration thereoffor the purposes of this Agreement.
2. Defillitio1/S.
(a) Divorce Code. The phrase "Divorce Code" shall be defined as Act No.
1990-206,23 Pa.C.S.A. ~ 3101 et seq.
(b) Date of Execution of this Agreement. The phrase "date of execution" or
"execution date" of this Agreement shall be defined as tbe date of execution by the parties if they
have each executed the Agreement on the same date. Otherwise, the "date of execution" or
"execution date" of this Agreement shall be defined as the date of execution by the party last
executing this Agreement.
3. Effective Date of Agreement. This Agreement will become effective and binding
upon both parties upon execution of this Agreement by both of them.
4. Effect of Divorce Decree--/llcorporatioll, No Merger. The parties agree that
unless otherwise specifically provided herein this Agreement shall continue in full force and effect
after such time as a final decision in divorce may be entered with respect to the parties. Husband
3
and Wife agree that the terms of this Agreement shall be incorporated but not mergcd into any
divorce decree which may be entered with respect to the parties and therefore Wife and Husband
agree and each of the parties does hereby warrant and represent to the other that should either of
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them obtain a decree, judgment or order of separation or divorce in any state, COWltry or
jurisdiction, that party will take all reasonable steps to have this Agreement incorporated as part
of any such decree,judgrncnt or order. The parties further agree that the Court of Common Pleas
which may enter such divorce dccrce shall retain continuing jurisdiction over the parties and the
subject mailer of the Agreement for the purposc of enforcement of any of the provisions thereof.
Nevertheless, it specifically is understood and agreed by and between the parties
hereto and each of the said parties does hereby warrant and represent to the other that should
either of the parties obtain a decree, judgement or order of separation or divorce in any state,
country or jurisdiction, each of the parties agrees that all of the provisions of this Agreement shall
not be affected in any way by any such separation or divorce, it being agreed by the parties that
this Agreement shall continue in full force and effect after such time as a final decree a divorce
may be entered and shall survive and not be mergcd into any such decree, judgment or order.
5. Effect 011 Divorce. TIle parties agree to take all legal steps (including timely and
prompt submission of all documents and the taking of all action including executing the
appropriate waivers of notice of the master's hearing, right to file exceptions, and right to file
appeal) necessary to assure that a divorce pursuant to Section 3301 of the Divorce Code is
entered as soon as possible, but in any event not later than three (3) weeks from the date of
execution of this Agreement. To that end, the parties have executed and agree to promptly file
4
the affidavits required to obtain a divorce pursuant to ~ 330l(c) of the Divorce Code.
ll; after the execution of this Agreement, either party delays or contests the
obtaining of a fina~ unappealed divorce decree, that party shall be fully responsible for all
attorney's fees, costs and/or expenses incurred as a result of such delay in obtaining the decree,
6. Effect of No Divorce. This Agreement is predicated upon and made subject to the
attainment ofa final decree in divorce under Sections 3301(c) of the Divorce Code and therefor,
except as otherwise provided for herein, this Agreement will be null and void if a final decree in
divorce is not obtained with three (3) months of the date of execution of this Agreement.
7. Warranty of Disclosure. Husband and Wife represent and warrant that they have
disclosed to each other the full extent of their assets, income and liabilities. Each party has had
ample opportunity to review the financial condition of the other and each party agrees not to
challenge the instant Agreement based on an allegation oflack of sufficient disclosure of assets or
income.
8. Equitable Distribution of Property,
(a) Premises. Husband and Wife hold title as tenants by the entireties of the
premises identified as 5275 Strathmore Drive, Mechanicsburg, Cumberland County, Pennsylvania
17055 (the "Marital Residence"). A legal description of the "Marital Residence" is attached
hereto as Exhibit" A." The Marital Residence is to be sold, with the proceeds to be applied as
follows:
5
(b) Contents a/Marital Residence. As of the date of execution, Wife shall set
over, transfer and assign all of her right, title and interest in all of the contents of the Marital
Residence as of the date of execution of this Agreement, including but not necessarily limited to
all furniture, furnishings, rugs, carpets, household appliances and equipment, pictures, paintings,
books, decorations, works of art, silver, china, glassware and other items of tangible personal
property of whatever nature ("Contents") currently located in the Premises, except that Wife shall
receive the following items:
I. Lace tablecloth
2. Living room needlepoint picture
3. Small wooden table with contents
4. Balance ofFarberware pots
5, Two (2) green blankets from Greece
By these presents, each of the parties hereby specifically waives, releases,
renounces, and forever abandons whatever claims he or she may have with respect to any of the
above items which shall become the sole and separate property of the other from the date of
execution hereof.
Husband hereby releases and relinquishes all claims and demands whatsoever as to
the whole or separate part of the said items of personalty which are distributed to Wife.
(c) Medical Insurance. The Husband shall be responsible for the Wife's
medical insurance through June 30, 1997, Thereafter, the Wife shall make the necessary
provisions to insure herself.
(d) 401 K. The parties acknowledge that Husband has a pension plan in the
fonn ofa 40lK through his employer and that a portion of that account has been identified as
7
marital propeny, Wife hereby specifically waives, releases, renOWlces, and forever abandons
whatever claims she may have with respect to Husband's 401 K plan and said plan shall become
the sole and exclusive propeny of the Husband from the date of execution hereof.
(e) Automobile. Upon execution hereof; Husband agrees that Wife shall retain
possession of and receive as her own propeny the 1989 Volkswagen Jetta for her own use and
disposition. Husband agrees to execute, acknowledge and deliver upon request of Wife any and
all instruments or documents necessary in order to effectuate the transfer of title of said
automobile to Wife. Wife shall be solely responsible for the payment of any sales or other tax that
might be incurred with respect to that transfer and for the payment of any expenses relating to the
automobile, Wife shall be solely responsible for all expenses associated with the automobile
including but not limited to insurance, maintenance, and any loan thereon. Wife shall be solely
liable and shall keep Husband indemnified and held hannless from any liability, cost or expense,
including attorney's fees, due to any of the expenses set fonh in the preceding sentence and shall
indemnifY and hold Husband hannless from any liability, cost or expense, including but not limited
to claims, damages and judgments, solely due to any accidents involving Wife prior to the transfer
of the title to Wife and Wife shall reimburse Husband for any increased premiums during the year
following the date of execution of this Agreement solely resulting from such accidents.
(f) Thc panies agree that Husband shall receive the entire refund due from the
panics joint Federal 1996 income tax return.
9. AlimollY alld Child Support.
(a) Commencing on the 16th day of JWle and for a period often (10) years
8
of the terms of this paragraph in a court oflaw or equity, it being understood that the foregoing
constitutes a 1i.1al determination for all time of Husband's obligation to contribute to Wife's
support and maintenance. The parties agree for the purposes ofincome taxation that these
payments shall not be includable to Wife's income and shall not be deductible from Husband's
income, but shall have no tax consequences.
10. Credit. Wife and Husband represent that they have taken all steps necessary to
make sure that no credit cards or similar accounts exist which provide for joint liability. From the
date of execution of this Agreement, each party shall use only those cards and accounts for which
that party is individually liable.
II. Counsel Fees. Husband and Wife agree each party shall be responsible for his or
her own legal fees and expenses, except that, in the event of a breach of this Agreement, fees shall
be recoverable by a non-breaching party in an action to enforce the provisions of this agreement.
12. Warranty as to Future Obligations. Wife and Husband each covenants,
represents, warrants, and agrees that, except as may be otherwise specifically provided for by the
terms of this Agreement, neither of them shall hereafter incur any liability whatsoever for which
the other or the estate of the other may be liable, and each now and at all times hereafter shall
indemnifY and hold hannless the other party from and against any such liabilities, costs or
expenses, including attorney's fees, relating thereto incurred by the other party after the date of
execution ofthis Agreement.
10
13. Warranties as to Existing Obligations. During the course of the l11arriage,
Husband and Wife have incurred certain liabilities and it is hereby agreed, without the necessity of
ascertaining for what purpose and for whose use each of the bills was incurred, that of those
liabilities that were incurred prior to the date of execution of this Agreement, Wife and Husband
each covenants, represents, warrants and agrees that, except as may be othelWise specifically
provided for by the terms of this Agreement, as of the date of execution of this Agreement, no
unpaid liabilities remain which were incurred by him or her or on his or her behalf for which the
other party may be deemed liable; and, if any such debts or obligations should be detennined to
have existed as of the date of execution of this Agreement, the party who incurred that debt shall
indemn.ifY and hold the other party harmless for and against any loss or liability and costs or
expense, including attorney's fees, incurred as a result of those liabilities.
14. Mutual Releases. Except, and only except, for all rights, agreements and
obligations of whatsoever nature arising under or which may arise under this Agreement or for the
breach of any part of this Agreement, Wife and Husband each do hereby mutually remise, release,
quitclaim and forever discharge the other and the estate of the other, for all time to come, and for
all purposes whatsoever, of and from any and all rights, title and interest, or claim in or against the
property (including income, and gain from property hereafter accruing) of the other or against the
estate of the other, of whatever nature and wheresoever situate, which he or she now has or at
any time hereafter may have against the other, the estate of the other or any part thereof, whether
arising (a) out of any fonner acts, contracts, engagements or liabilities of such other, (b) by way
of dower or courtesy or claims in the nature of dower or courtesy or widow's or widower's rights,
11
(c) as family exemption or similar allowance, or (d) under the intestate laws, the right to take
against the spouse's will, 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 (i) Pennsylvania, (ii) any other State, Commonwealth or territory of the United
States, or (iii) any other country. Except, and only except for all rights, agreements and
obligations of whatsoever nature arising under or which may arise under this Agreement or for the
breach of any part of this Agreement, the parties agree that this Agreement shall be and constitute
a full and final resolution of any and all claims which each of the parties may have against the
other for equitable distribution of property, alimony counsel fees and expenses, alimony pendente
lite or any other claim pursuant to the Pennsylvania Divorce Code or the divorce laws of any
other jurisdiction. The parties further release and waive any rights which either party may have
now or hereafter against the other including but not Iil11ited to claims for past, present or future
support or maintenance, alimony, alimony pendente lite, property division (including but not
necessarily limited to equitable distribution), counsel fees, costs or expenses, whether arising as a
result of the marital relation or otherwise, whether under the Divorce Code or otherwise. Except,
and only except, for all rights, agreements and obligations of whatsoever nature arising under or
which may arise under this Agreement or for the breach of any part of this Agreement, it is the
intention ofWiie and Husband to give to each other by the execution of this Agreement, and full,
complete and general release with respect to any and all property of any kind or nature, whether
real, personal or mixed, which the other now owns or may hereafter acquire.
15. Mutual Waivers. Wife and Husband acknowledge that by this Agreement they
12
Friday at 3:00 p.m. Father shall have custody of the children from Friday at 3:00 p.rn. until
Sunday at 5:00 p,rn. Mother shall have custody ofthe children from Sunday at 5:00 p.m. until
Tuesday at 3:00 p.rn.
This two week schedule shall thereafter repeat itself and continue on an ongoing basis.
The panies agree that each will have three weeks of vacation with the children to be taken
in increments no greater than ten (10) days. TIle panies agree that each will provide the other
with at least thiny (30) days' written notice of these periods of vacation and shall provide the
other with the telephone number and address where the children will be during these periods of
vacation,
Holidays will be shared as the panies agree. Mother may have custody of the children
every Mother's Day. Father may have custody of the children every Father's Day.
The panies agree that Husband shall claim the children as exemptions on his returns for
the purpose of federal and state income taxation.
17. Waiver or Modification to be in Writing. Nl' modification or waiver of any of the
tenns hereof shall be valid unless in writing and signed by both panies and no waiver of any
breach hereof or default hereunder shall be decmed a waiver of any subsequent default of the
same or similar nature.
18. Mutual Cooperation. Each pany shall, at any time and from time to time
hereafter, take any and all steps to execute, acknowledge and deliver to the other pany any and all
funher instruments and/or (witllin at least fifteen days after demand therefore) documents that the
other party may reasonably require for the purpose of giving full force and effect to the provisions
14
of this Agreement.
19, Law of Pennsylvania Applicable, This Agreement shall be construed in
accordance with the laws of the Commonwealth of Pennsylvania which are ill effect as of the date
of execution of this Agreement.
20. Integration This Agreement constitutes the entire understanding of the parties
and supersedes any and all prior agreements and negotiations between them. There are no other
representations, terms, covenants, conditions, agreements or warranties, express or implied, oral
or written of any nature whatsoever, other than those expressly set forth herein.
21. Severability. If any tenn, condition, clause or provision of this Agreement shall be
determined or declared to be void or invalid in law or otherwise, then only that tenn, condition,
clause or provision shall be stricken from t1tis Agreement and in all other respects this Agreement
shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to
meet her or his obligations under anyone or more of the Paragraphs herein, with the exception of
the satisfaction of the conditions precedent, shall in no way void or alter the remaining obligations
of the parties.
22. Contract Interpretation For purposes ofinterpretation and for the purpose of
resolving any ambiguity herein, Husband and Wife agree that this Agreement was prepared jointly
by their respective attorneys.
23. Waiver of Liability. Husband and Wife each knowingly and understandingly waive
15
any and all possible claims that this Agreement is, for any reason, illegal or for any reason
whatsoever of public policy, unenforceable in whole or in part. Husband and Wife each does
hereby warrant, covenant and agree that, in any possible event, he or she is and shall forever be
estopped from asserting any illegality or unenforceability as to all or any part of this Agreement.
year first above written.
,
IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and
i.w([ i:/;(t
William c. KolIas, Esquire
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Ij tei/JI tl:.-t.J ~ C)ll(S' <;;:./--
Rosemarie Kanganis
\.. )
16
ADDENDUM
w
CUSTODY:
The parties acknowledge that husband's work schedule
requires him to travel away from home overnight. When husband
will be away from home during periods of custody as set forth
herein, husband will give at least 10 days notice of his travel
schedule to wife. The children shall reside with wife during
these periods unless wife requests otherwise due to her work
schedule. In the event wife and husband are unable to provide
care during these periods, provisions will be made to have
grandparental care.
The parties agree that the children will be provided
reasonable telephone access to the other parent. The parent
not in custody of the children shall be permitted at least one
telephone call per day to the children when the Child;:; are in
the custody of the other parent. L~J
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GEORGE T. KANGANIS,
Plaintiff
vs.
)
)
)
)
)
)
)
)
CIVIL ACTION - LAW
IN DIVORCE
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 96-4601 CIVIL TERM
ROSEMARIE KANGANIS,
Defendant
ORDER
AND NOW, this
2t]~
, 1997, upon receipt
1M~1
day of
of the Conciliator's Report, it appearing that a hearing in this matter is necessary, it
is hereby ordered and directed as follows:
A hearing is scheduled for the ,::;JS'.:O{, day of
(21.-<-7./Al1 ,1997, at-.!Z:OQ o'clock~.M.. in Court
Room Number ~ of the Cumberland County Court House, Carlisle,
Pennsylvania. Both parties, through counsel, will provide each other
and the court with a list of witnesses ten (10) days prior to the date of
the hearing along with a statement as to their expected testimony.
Additionally, both parties will submit their proposal for a resolution of
the matter.
BY THE COURT,
William C. Kennedy, Esquire
Kathleen Carey Daley, Esquire
~.,J.. '-rlt.(~~'''<lL<-
mlb
~-j
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GEORGE T. KANGANIS,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
NO. 96-4601 CIVIL TERM
ROSEMARIE KANGANIS,
Defendant
CIVIL ACTION -LAW
IN DIVORCE
JUDGE PREVIOUSLY ASSIGNED: None
CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the
following report:
1. The pertinent information concerning the child(ren) who is(are) the
subject of this litigation is as follows:
NAME
BIRTHDATE
CURRENTLY IN
CUSTODY OF
Thomas George Kanganis
Dean George Kanganis
November 15, 1986
October 27, 1989
Plaintiff and Defendant
Plaintiff and Defendant
2. A Conciliation Conference was held on May 6, 1997, and the following
individuals were present: the Plaintiff and his attorney, William C. Kennedy,
Esquire; the Defendant appeared with her attorney, Kathleen Carey Daley, Esquire.
3. Items resolved by agreement: None.
4. Issues yet to be resolved: An ultimate custody schedule.
5. The Plaintiff's position on custody is as follows: Plaintiff believes he
should be provided more time with the children and that he should be the primary
custodial parent. Father indicated that he has been actively involved in the
children's lives and that Mother's alleged infidelity is an issue that should be
explored as it relates to her fitness to care for the children.
6. The Defendant's position on custody is as follows: Mother has been the
primary care taker of the children. Furthermore, since the parties separated in
March, 1997, they have been working on a schedule that dove-tails with the
parties' work schedules. Under that schedule, they have been essentially
alternating weekends with Mother having the children slightly more often than the
Father. In addition, Mother reports that she has the children when the Father goes
on his trips away.
7. Need for separate counsel to represent child(ren): Neither party
requested.
8. Need for independent psychological evaluation or counseling: None
requested and the Conciliator does not believe any is necessary.
9. A hearing in this matter will take one-half day.
10. Other matters or comments: The parties were unable to reach an
agreement at the conciliation conference because there are many pending issues
related to their divorce. They are scheduled for a Master's hearing in May and
counsel relates to the Conciliator that there is a possibility that once the parties get
beyond that hearing, the custody may resolve itself. In any event, they requested a
hearing in case a resolution is not forthcoming.
Date: May 19, 1997
" ) f'
F ~j-A L {c, j:?
Mic ael L. Bangs
Custody Conciliator
ROSEMARIE KANGANIS,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
v.
NO, 96-4601 CIVIL
GEORGE KANGANIS,
Defendant
IN DIVORCE
ANSWERS TO INTERROGATORIES
TO: George Kanganis, Defendant
Mary Kollas Kennedy, Esquire
1104 Fernwood Avenue
CampHiIl,PA 17011
Plaintiff, Rosemarie Kanganis, files the following Answers to Interrogatories as propounded
by the Defendant, George Kanganis, in the above-captioned divorce action.
Plaintiff verifies that the statements made in this Answers to Interrogatories are true and
correct. Plaintiff understands that false statements herein are made subject to the penalties of 18
Pa,C.S,A, ~4904 relating to unsworn falsification to authorities,
Date:
K' );,' /'/' If 1
"-__, J
r/)
o ,Y .
By: ( <j~~i'l;n '>11....1 j\ /l// i~' ---'
R SEMARIE KANG~~intiff
1. State the following information with rcspcct to any position you hold as an employec
(in contrast to that of an owner, partncr, or sharcholder in a fictitious cnterprise):
a) current cmployer;
b) address of employer's principal office;
c) addrcss of your principal place of employment;
d) frequency of pay period;
c) gross pay per pcriod;
f) anticipated date of change in salary; and
g) gross pay rcccived from employer in the past twelve months,
See W-2 information - remains accurate
2. If you rcceive any additional compensation or prerequisite by reason of your
cmploymcnt other than that described in response to the preccding intcrrogatory, check
the appropriate box and describc the bencfit (including thc frequency it is given) below:
a) (X) Commissions - reflected on W-2 total
b) ( ) Bonuses
c) ( ) Overtime pay
d) ( ) Gratuities
e) ( ) Gifts
f) ( ) Vacation allowance
g) ( ) Travel allowance
h) ( ) Pension plan
I) ( ) Profit sharing plan
j) ( ) Stock option plan
k) ( ) Stock purchase plan
I) ( ) Life insurance plan (if you are named beneficiary)
m) ( ) Health insurance plan ( ) employee only
( ) family covercd
n) ( ) Del1tal insurance ( ) employec only
( ) family covered
0) ( ) Disability insurancc
p) ( ) Expensc account
q) ( ) Automobile: Model
Ycar
Usc the space below to complete answers describing thc benefits checked in
conjunction with Interrogatory No.2. You may attach copies of relevant documents
(copies ofpensiol1 plans, cct.) in lieu ofanswcring a given intcrrogatory.)
6. Indicatc by namc and branch address each commercial bank, savings and lending
institution which is currently holding funds in which you have a legal or equitable
intcrcst, identifYing the account or instrument number, the fornl of the deposit
(chccking, savings, money market, certificate of deposit, etc,), thc maturity date (if
applicable), the amount on deposit and the names of any co-owncrs,
a) name and address ofinstitution;
b) form of deposit;
c) idcntifying number of account or certificate;
d) amount of deposit;
e) maturity date; and
f) names of thc co-owners.
Dauphin Deposit Bank
Savings Account
Rosemarie Kanganis
No. 4935722134
7. If you are a legal or equitable owner of any common or prcferred stock, indicate:
a) namc ofissucr:
b) cxchange:
c) datc of purchasc;
d) numbcr ofsharcs hcld; and
e) purchase date.
No.
8. If you hold bonds or other forms ofsccurities evidencing debt (e.g. dcbentnres,
cquipment mortgagcs, sinking fimds, govcrnment bonds, U.S. Savings bonds) indicate
the following:
a) namc ofissuer;
b) exchange traded;
c) maturity date;
d) date pnrchased;
e) purchase price, and
f) value upon maturity.
No.
9. If you have sold any bonds or othcr fOllns of security evidcncing dcbt in the three
years preceding thcse Interrogatories, indicate:
a) name ofissuer;
b) sale price;
c) transferec's name;
d) interest rate;
e) maturity date;
f) purchase price; and
g) datc of sale.
No.
11. If you have madc or rcceived any gift to or from any pcrson other than your spouse in
cash or in kind having the valne offive hWldrcd dollars ($500,00) or greatcr in thc last
two years, identifY the person who was given or reccived and the value of such gift,
No.
12. List all outstanding debts which you are obligatcd to pay having a balancc in cxcess of
$300.00 for cach debt, and identifY any dcbt which you claim to bc a marital debt.
See No. 10
CERTIFICATE OF SERVICE
I, Kathleen Carey Daley, Esquire, hcreby certify that on the date indicated below, I served a
true and correct copy of the foregoing Answers to Interrogatories on the Dcfendant, George
Kanganis, by and through his attorney, Mary Kollas Kennedy, Esquire, by First Class United States
Mail to 1104 Fernwood Avenue, Camp Hill, PA 17011.
DALEY LAW OFFICES
Date:
~-/,-~D/17
I
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Kat een Carey Daley, E q . re
Att rney No. 30078
1029 Scenery Drive
Harrisburg, P A 17109
(717) 657-4795
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MARY KOLLAS KENNEDY
TELEPHONE NO, (717) 731.1600
FAX NO, (717) 763.8442
May 22, 1997
Robcrt E. Elicker, II
Divorce Master
9 North Hanovcr Street
Carlisle, PA 17013
RE: Kanganis v. Kanganis
Docket No. 96-4601
Dear Mr. Elicker:
Pursuant to our tclephonic conversation of today, I am rciterating what transpired in the
above-referenced case. COllllscl for both partics have rcached a tentative agrecment and will
bc cxecuting thc same at your office on May 28, 1997, at 9:00 a.m. In thc evcnt we are not able
to finalizc the agreement on that datc, I will request a continuance at that time to reschedule the
hearing so that I might subpocna the appropriate witnesses.
I'm looking forward to seeing you on that date.
Very truly yours,
KOLLAS AND KENNEDY
{v . (0, /.I.et---
William C. Kollas
WCK/den
cc: Kathleen Carcy Dalcy, Esq.
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ROSEMARIE KANGANIS.
PlaintitT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 96-4601 CIVIL
GEORGE KANGANIS,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
CERTIFICATE OF SERVICE
I, Dawn E. Nace. ofthc Law Officcs ofKollas and Kcnnedy, hereby ccrti/y that I have
this 2nd day of April, 1997, scrvcd a truc and correct copy of a PETITION TO TRANSM IT
RECORD FOR CUSTODY CONCILIATION along with thc signed ORDER, by depositing same
in the United States mail, first class, postage prepaid, addressed to the following:
Kathleen Carey Daley, Esquire
I 029Sccnery Drive
Harrisburg, PA 17109
LAW OFFICE OF KOLLAS AND KENNEDY
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GEORGE KANGANIS.
Petitioncr
IN TilE COURT OF COMMON PLEAS OF
CUMBERI.AND COUNTY, PENNSYLVANIA
v,
NO, 96-4601 CIVIL
ROSEMARIE KANGANIS,
Respondcnt
CIVIL ACTION - LAW
IN DIVORCE
PETITION TO TRANSMIT RECORD
FOR CIISTODY CONCILIATION
I. 'Ille Petitioner is GEORGE T, KANGANIS, Defcndant in the abovc divorce
action is currcntly residing at 5275 Strathmorc Drive. Mechanicsburg, Pennsylvania 17055,
2, TIle Rcspondcnt is ROSEMARIE KANGANIS, Plaintiff in the above divorce
action is currently rcsiding at 5145 South Dcerfield. Mechanicsburg, Pcnnsylvania 17055.
3, On Septcmber 3, 1996, Pctitioner filed a Petition for Custody with this Court, at
which time conciliation was schednled beforc Michael L Bangs, Esquire, on October 17, 1996,
4. Afler being reschcdnled, a conciliation confcrence was held, at which time no
agreement was rcached by thc parties and thc pal1ies then both resided in thc marital home, A
second confercncc scheduled for December 19. 1996. was cancclcd because the partics both thcn
residcd in the marital home,
5, On or about March 7, 1997, Respondent moved from thc marital home to the
addrcss at which shc currently resides,
6. 111C issue ofcnslody of the two minor childrcn of the p:n1ies is now right for
dctermination.
ROSEMARIE KANGANIS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
v.
NO, 96-4601 CIVIL
GEORGE KANGANIS,
Defendant
IN DIVORCE
PRE-TRIAL STATEMENT
On behalf of Rosemarie Kanganis, the Plaintiff in the above-captioned action, Kathleen Carey
Daley, Esquire, does hereby file the following pre-trial statement for consideration of the Court:
I. Marital Assets - Attached hereto please find a listing of all marital assets including
their value, date of valuation, determination of whether any portion is non-marital and any liens or
encumbrances thereon, and a listing of non-marital assets, their value, date of valuation, and any liens
or encumbrances thereon,
2, The names and addresses of each expert whom the Plaintiff intends to call at trial
includes the following:
N one yet identified, In the event Plaintiff decides to call any experts, the
names and addresses of the cxpert will be provided to Defendant prior to trial.
3. The Plaintiff intends to testify at trial. If any additional witnesses are identified, their
narnes and addresses will be provided to Defendant prior to trial.
4, A list of all exhibits which the Plaintiff imcnds to offer into evidence:
A. The Inventory of Plaintiff, Wife, with supporting documentation,
B. The Income and Expense Statement of Plaintiff, Wife,
C. Any additional exhibits will be forwarded to Defendant prior to trial.
5, The gross income of the Plaintiff from all sources inclucing payroll dcductions, recent
state and fcderal income tax returns and pay stubs:
Wife is employed on a part-time basis with Weight Watchers, Her annual
income is approximately $13,000,00,
6, A listing of the expenses of the Plaintiff:
Income and Expense Statement will include this information,
7. The valuation of pension or retircment benefits and a calculation of the marital portion
thereof and the facts and documentation upon which thc party relies to support the valuation:
401(k) value is $5,284 as stipulated by thc parties as of July 1,1995,
8, Claim for counsel fees:
The Plaintiff claims $2,000,00 in counsel fees,
9. Tangible personal property values:
The Plaintiff will testify as to the values of all tangible personal property in
question.
10. Listing of marital debts:
Since separation, the Defendant, Husband, has indicatcd a monthly debt
payment of$223,00 per month for the following accounts:
Visa - Dauphin Deposit
MastcrCard/Visa - Mellon Bank
Boscov's
Hechinger's
John Wanamaker's
Montgomery Ward
11. The Plaintiff makcs the following proposed resolution of the economic issues:
Wife shall be awarded the marital residence, her 1989 Volkswagen Jetta and
the cash savings of$15,400,00. She shall indcmnifY and hold Husband harmless from
the mortgage liability of approximately $133,000,00 due to Eastern Mortgage
Services, Inc, She will obtain financing within twenty-four (24) months from
settlement to eliminate Husband's obligations under this mortgage.
Husband shall receive the sum of $15,000.00 from Wife at settlement, the
Plymouth Voyager (subject to a loan) and his 40l(k) balance, He shall assume the
obligation for the Dauphin Deposit credit line balance and for the credit accounts as
follows:
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ROSEMARIE KANGANIS.
Plaintiff
v,
GEORGE KANGANIS,
Defendant
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96-4601 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
DEFENDANT'S PRE-TRIAL STATEMENT
DATE: / 2(i. 'II.'
BY:
BY:
RESPECTFULLY SUBMITTED:
i{~C~U
William C. Kollas, Esquirc
Altomcy LD. No. 06341
KOLLAS AND KENNEDY
1104 Fcmwood Avcnue
Camp Hill, PA 1701 I
Phonc: (717)731-1600
ATTORNEYS FOR DEFENDANT
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TABLE OF
CONTENTS
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EXHIBIT 1
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List of Assets (Marital)
Description Valuation Datc
I. Rcal Property 7/1/95
5275 Strathmore Drive
Mechanicsburg, PA 17055
YiI1lli:
$167,000,00
*Nct Equity $ 31.880.00
2. Motor Vehicles
a. 1989 Volkswagen Jetta
b. 1990 Plymouth Voyager ($8,275.00)
5. Taken by Rosemarie Kanganis
17/18. Pension Plans 401(k)
7/1/95
25. Household Furnishings (See Attached Exhibit 3-A)
TOTAL MARITAL ESTATE
$ 4,700.00
4,275.00
$ 15,400.00
$ 5,284,00
$61,459,00
,
Liens or
Encumbranccs
Mortgagc -$130,600.00
Line of Credit - $4,520.00
None
$4,000.00
None
"
EXHIBIT 2
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EXHIBIT 3
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GEORGE & ROSEMARIE KANGANIS - HOUSEHOLD AND PERSONAL
l~ocatinnlItem Purchase Date Pllrcha~e Price Cnrrpnt Vallie
Basement.
Office desk 1981 $ 300.00
File cabinet - 2 draw 1981 50,00
Kitchen table w/4 chairs 1983 300.00
Water purifier & softener 1987 1,800,00
Stereo w/2 amplifiers 1984 700,00
Treadmill 1992 500,00
First floor'
Washer 6/29/95 439,00
Dryer 6/29/95 379,00
Kenmore vacuum cleaner 3/18/96 329,00
Garage'
Kraftsman 5.5HP lawnmower 6/95 250,00
McCullough leaf blower 6/95 85,00
Tore 3HP snow blowcr 10/95 550,00
Grass feeder 6/95 20,00
Kraftsman 16" weed wacker 6/95 80.00
18" Black & Decker shrub
trimmer 1990 30.00
Kitchen'
Whirlpool electric range/oven 6/29/95 669,00
Amana 20,2 cubic ft. refrig. 9/15/86 921.00
Spacesaver RCA TV 6/29/95 275.00
Miscellaneous plates, glasses,
utensils, pots & pans 6/29/95 500,00
Venetian blinds 9/95 400,00
Kitchen table w/6 chairs 8/95 1,000,00
Screened Porch'
Glass top table w/4 chairs 1990 400.00
13" ReA color TV 1983 250.00
EXHIBIT
A
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GEORGE & ROSEMARIE KANGANlS - HOUSEHOLD AND PERSONAL
Front entrance way'
Grecian throw-rug 1986 200,00
Dinina room'
Dining table w/6 chairs
and leaf extension &
hutch 1/14/87 1,891.00
Crystal & china-Noritake
Ivory - 3 lenox serving
trays, 12 place silver
service set. 1987 4,000,00
Portable brass glass bar 1979 150,00
Living room'
Husband/wife lIadro 1983 gift
Cherub lIadro 1981 gift
Woman holding lamb lIadro 1990 gift
Womanlbasket & lamb lIadro gift
3 lennox candy dishes gift
Lennox flower vase gift
Plant stand - wicker 1979 100.00
Couch, lovc seat, 2 chairs,
glass top coffee table. lamp
table, lamp, 2 book shelves 1979 6,000,00
Family room'
Standing glass lamp 1979 N/A
CD tape deck w/2 speakers
(pioneers) 1990 500,00
25" Sony color TV 1992 800,00
TV stand 1992 300,00
Panasonic VCR 1984 200,00
L-shaped 4 piece sectional
couch w/fold out bed 9/25/86 1,431.00
Fireplace accessories 8/95 75,00
GEORGE & ROSEMARIE KANGANIS - HOUSEHOLD AND PERSONAL
Guest bedroom'
Qucen size bed
Lamp table & lamp
Rocking chair
Panasonic boom box
9/24/86
1979
1986
1979
Study/office'
IBM PS-I computer, laser
jet Hewlett-Packard printer,
computer work station
Electrolux vacuum cleaner
1996
5/24/96
Boys' bedroom'
Kenmore 2-spccd upright
vacuum cleaner
2 boys' beds
Dresser
Dresser/changing table
N/A
1988/1991
1980
1986
Master bedroom'
Bureau, dresser w/mirror,
2 night stands, 2 lamps, King
size bed
Phone answering machine
20" RCA color TV
VCR RCA
1979
1993
6/29/95
1994
Total
365.00
150,00
45,00
100,00
gift Grandfather to Grandson
636,00
gift
500,00
200,00
200,00
5,000,00
180,00
264.00
gift
$ 33,514,00
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PROFESSIONAL OBJECTIVE
A full-time management position, perbaps In Sales or Customer Service, with an
organization In need of an articulate professional with much experience- and success- In
leading groups of Weight Watchers and promoting numerous public relations events that
kecp the company's name before the public in a positive fashion.
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HIGHLIGHTS OF QUALIFICATIONS
· More than seven m years, on-goIng experience with Weight Watchers, giving lec-
tures, promoting fund raising events, and otherwise providing the leadership that show
the company in a positive UghL
· A creative problem solver, combined with equally strong Interpersonal skills, with
experience In dealing with a wide variety of customers from housewives to corporate
executives.
· Excellent oral and written communications skills, with experience being interviewed
on both television and radio (on behalf of Weight Watchers).
· Additional business and sales experience as the Office Manager for a travel agency
and the Co-OwnerlMaoager for a I8rge flower shop with 11 employees.
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· Well-developed management skills, with the leadership ability to take charge oC a
faltering grou.P and breathe liCe aodexcitement back into it and make It successful._
from Ii' comPany profitability and individual participant point oC view.
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,:! · AA,rBUSInl:ss Management, Harrisburg Area Community College, 1995... with an
t.~_. ',." -' .' ,. ~.r,... ""',- . '-',' ' ""." r.' , . .
'{"" ;{ ./~;O!~mu ~rA.:of 3,68..,:,!~~e raising two childreu and working part-time for Weight
. ':~"f":' ;,1, .~:,{~'.~~.:.~. '-:.;'l:W~~~~\~rf'?;~~)~:~~~~::~~~~~~di~~>:' ..' "/':'
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.i " -; ~'.\:, .' ';'r~:i" _~~~'..7~:~.,\,'\~~.io.g.!f, i.~.'~~",;.:.i'('~~~.":'''ivlji'' t.'. ~. .' ..\"..... ~..:' ~,
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i [ · A .caring P.~l~!~@.~.d~~~ ~etithe job d~De,without fuss or hesitation... a strong
; success rate~,~jfe~klng a loogterm, mauagement challenge.
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PROFESSIONAL EXPERIENCE
LECl'URER
Weight Watchers of Central PA, Harrisburg, PA
5/88 - Present
. Prcparc and givc Iccturcs on a wcckly basis that combines thc Wcight Watchcrs' philo-
sophy of behavioral, psychological, and nutritionally upbeat activities to groups as largc as
100... with a,success rate or over 75% attendance at each lecture.
. Additional activities includc public relations and fund raising cvcnts, such as:
-in 1988, '89, '90, and '95, actcd as thc Team Captain for thc March of Dimes Walkathon
in Carlislc, PA;
-in 1994, assisted in a Healthy Cooking scrics to bencfit thc Ronald McDonald House
in Hershey, PA;
-in 1994, was intervicwed on thc Chit Chat Show, WHP - 580 AM, on thc issue of "How
To Control Your Holiday Eating." (Tape available for review.);
-in 1988, featurcd on PM Magazine, WNBC- TV, a 10 minutc tape (that is availablc);
-in 1988, participatcd in a fashion show at thc Harrisburg Forum to bencfit the Hcrshcy
Ronald McDonald House;
-also in 1988 (through 1995), assisted and promoted events for the March of Dimes, the
Ronald McDonald House, Bcthcsda Mission, and Breast Cancer Awarcness.
omCE MANAGER
Mr. Good-Bye Travel Agency, Camp Hill, PA, 1983 - 1985
. Responsible for all Accounting arid Bookkceping activities, such as Payroll, Gencral Led-
gcr, Accounts Payablc, and Bank Reconciliations, plus the overall managcmcnt of six (6)
Sales Associates.
. Heavy cmphasis on good customcr rclations, as well as the set up and installation of a
computer system to book travel arrangemcnts for customcrs and integratc thc Accounting
function. ,': -
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CO-OWNER/MANAGER - ", ','
The Flower Barn, Inc., Carlisle, PA, 1980;;'''1983
. As thc Co-Owncr!Manager of a family oWned, retail flower shop, managcd the ovcrall
activities of eleven (11) employees, pbi~"I~kcare of thc financial rccords, the purchasing
of merchandise, and all computer actixiti~.,
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. References AviziJable Upon Request
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EXHIBIT 4
. ,
CO. FILE OEPT, CLOCK VCHR. NO,
HHV 8021.5 006024 V 0000480031
TELEFLORA
12233 WESTOLYMP'C BLVD,
LOS ANGELES, CA 90064
SocIal Security Number. 089.50.5538
Taxable Marital Status Marned
ExempIIOn:i/Allowances
Federal. 3
Slale.
EarninQ. rate hours this period year to date
Regular 2500,00 2.500,00 59,42308
Bonus 6.500,00
Relro 1,384,61
Groo. Pay $2,500.00 67,307,69
Deductions Statutory
Federal Income Tax .359,30 9,475,12
MedIcare Tax -36.25 975,96
PA State Income Tax .70,00 1,884,62
PA SUI/SDI Tax -0.75 20,19
SOCial Security Tax 3,887,40
Other
eking .2,033,70 38,226,26
Medlnd 1,430,00
401K 4,361.54
Not Pay $0.00
Your federal taxable wages thIS period are
$2.500,00
Earnings Statement
~
..
I, ~~~~..(~j~~~!f,;\':!i:<::f~l?fi;':Y';~';'?'f"~~:'S/ii'Z\l}:!:?~-{:'1'i';?;'$~~*~S"f:~~,*(r/l.(\1i.'fft'~(."'011;Y::;',";'f.;f>;ji':G.~t ;~~'.:!;i%'~'~,'
;f}~~iU'kmll!h.U~itih,:;'iII:f/Jfu!b" ~~{jJ.M<~I"\tj!>;<'J!;ijJ'bi;!i;1'!JLi,,,,I,;'1i'{.iJj?'.,LI .,(t!ff'.,;r&:t!'~AJl 0'Mii.;.<Uit:.. :1;lJd..:~Ja::r-J:!'I?.;,l!!r <
, ~,~:. r;,Y:~'~~~:ar~LE,~~OfiA~~~:~~~. ;':::~:-"';<;_""':l"'I,.-\-.,:::.~.:.;~,~~:.~.-t'~:>'f ,,:;~~"';::~~~r~':.:"::;Ad'Vi~"'~mr~?~'~~"i.:'::i1'~;.f~'~ ,~~!;:':'~;>~"}.~~~i':;'~ r
: lJtl!;:"':I'~'Nr&"'l'{!1"""~'''WE",''1$r1 ,"t>..i.~ ;, ,r"~~"':<;;(":: I,:' /1,",.'.,:,:,'"""';<'..',, ,9~,':" ,r\,:;;;,Z',d',fr"~':l ':'~N~;"':{""I;I,'.{,'
, :':{('~~':";\.~:E~~l3~~~&~;~:J~'ci%~ ./"',,:' '~'/",,'" <;:' l'ay~cliJle:'" '/ <,""Jf/g?1'},6" ".'f\'//rJ\::;i'''!
De osited to the account of
GEORGE T. KANGANIS
.
-
-~
'"
Period EndIng:
Pay Dale
11/29/96
11/27/96
GEORGE T. KANGANIS
4902 CARLISLE PIKE
#412
MECHANICSBURG PA 17055
Other Benefits and
Information
Outmem
this period
total to dall
2.180.77
2,180.77
4,361,54
24,00
448.00
114,94
Matytd
401Ytd
Per Bal
Sick Bal
Vac Bal
O"N'A:lP .",
,:. .
transit ABA
0313 0083
amount
$2.033.70
NON-NEGOTIABLE
CO, FILE OEPT, CLOCK VCHR. NO,
HtlV 802115 000024 V 0000460003 1 '
TELEFLORA
12233 WESTOL YMPIC BLVD.
LOS ANGelES, CA 90U64
Social Security Number: 089.50.5538
Tfl.ICsble Mantal Status: Married
Exemptlons/AHow8nces:
Federal: 3
Stale:
Earnlnqs rale hours this period yoar to date
Regular 2500,00 2,500,00 56,923,08
Bonus 6.500,00
Retre 1.384,61
Gross Pay $2,500.00 64.807,69
Osducl!!?!!!L._ _!t.'!~u.!e.!'L
Federal Income Tax .359,30 9, I 15,82
Social Security Tax .24.32 3,887,40
Medicare Tax .36,25 939,71
PA State Income Tax .70,00 1,814,62
PA SUI/SOl Tax .0,75 19,44
Olher
eking .1.944,38 36.192,56
Medlnd -65.00 1.430,00
40lK 4.361,54
Nel Pay $0.00
Your federal taxable wages this period are
$2.500,00
Earnings Statement
. JAZj).
'"
Penod Ending:
Pay Date,
11/15/96
11/15/96
GEORGE T. KANGANIS
4902 CARLISLE PIKE
#412
MECHANICSBURG PA 17055
Othsr Benellts and
Inlormatlon
Outmem
this period
total to data
2,180,77
2,180,77
4.361,54
24,00
448.CO
110.32
Malyld
401Ytd
Per 8al
Su;;k Sai
Vac Sal
}~~r;\~~!P'?f::f0~{rt~~~~;fJl~!f~~'~~~:~;~'~J rj~~~\lf'::fP:t;(~f r?/J~~~i~;i:~J;Jf(- I~1?t!\\~ '~~"f'j~"1), ,t?{:;'r'~~"'f<~~'~! 'n;rJ~~;',;:~\r~9
~{1JJ~~"lt:;;:~'I(;;.:,U;;:!JJ ,~-;;,.:li~.'..'.l:k/ ~;llif~.J.l;;-:,....,.l-,.. 1-1;':::";':J:,;:::l.l.~;",Jl.1 ::;<l.li "jl;o:~-",~.~~,-::,;",} ~.~~.i._~. i.oil:~.::lj..:;,,), ;"/-"';~!~"';";~l>'~ ~li~';:'''''' ~ d,j :;;'..u~l;.: it.k'1l
~.':~'-':",~';':',_'" ~~";.1"<""'~ <<",--'::.u;;....~i~..., ..."~~__".~'r.. ....~;....,.....~....~...;.-..':'.,"'". '. ~.' ....--;:,':'-',.1..<'. "~<' ....;,~:,...' <:"....,...:' '-...'.," '_"" ,'......:. ,_" <'r-"""" ..-,' .'.,'" ...,....
":'-;;-~1 r:''':''~-:l:-i;.'~''' 't;>._[f;t;e;:Fi.-OM~"".!:':-''':'';i:'~~-;)o';'''' ......., ':f~! t"'"'li{''''' l~"/_ ['':''-:JA." ;.; ;" "~~.).)'''~Advfc9'';huttib'f... ,'- r" "~"". '()()OC)()4Goo33 8..",... ~ . {"h; ,...t" ;..'~. jl
,~'r~t1~; :lr~J?ir~-~:(j~..~~_3:~ :V~E"~f:t3n~M~i6 :~~CVb':\~) ~~.Y"}}-! ,~'UJ~.(}/}(;: ~.<f[p~y: i1~ie;.-"::J}i:~ .~, t }/ r!11 If 5/96,1 :;~ '._'- !)::'J :,"~ ~t fY;' '.~;j \\ 1j
. ,.<;<." ,;: ;i.()~ANGELES, '0"-'. .90064 . rJr'~' , II
- "' ~
- I
i
De ositod to the account of
GEORGE T. KANGANIS
-,
transit ABA
03130083
amount
$1,944,38
II
"
NON-NEGOTIABLE
CO. FILE DEPT. CtOCl( VCHIt NO.
HIlV 802115 0011024 V 0000440031 1. .
Earnings Statement
~
'"
TELEFLORA
t 2233 WEST OL YMPIC BL VD,
LOS ANGELES, CA 90064
Perrod Ending:
Pay Dale:
11/01/96
11/01/96
I
I
I
1
I
I
I
I
i
,
I
I
I
I
I
I
SOClsl Securlly Number: 089.50.5536
Taxable Manlllol Slatus: Married
ExemptIons/Allowances:
Federal: 3
SltUe:
GEORGE T. KANGANIS
4902 CARLISLE PIKE
#412
MECHANICSBURG PA 17055
* Excluded from federal taxable wages
EarnlnQs ,.t. hours this period year to date
Regular 2500.00 2,500,00 54,423,08
Bonus 6,500,00
Relro 1,384,61
Gro.s Psy $2,500.00 62.307,69
Deduct!ons St~tutory
Federal Income Tax .310,30 8.756,52
Social Security Tax .155,00 3.863,08
Medicare Tax .36,25 903,46
PA Slale Income Tax .70,00 1,744,62
PA SUI/SDI Tax .0,7S 18,69
Olhor
Cking .1,687,70 34,248,18
Medlnd .65,00 1.365,00
401K .175,00' 4,361,54
Not Pay SO.oo
Other Benefits and
Information
Oulmem
this period
87,50
totll to date
2,180.77
2,180.77
4,361,54
24,00
448,00
105,70
Matyld
401Yld
Per Sal
Sick Sar
Vac Sal
Your federal taxable wages thiS period are
$2.325,00
, .
O';j,j'ACI>,.",
, ,
. O' '" .
I ......\k". ..',.y..~,.-.i'~ .. ~ ~............"".~!~,.". ~~" ....1. Y~~""''':'fl'o:.<...''o,j,,, <:"i. ....<..J~':A ,""', 'li. "'''. ..'" .,......,_ '.. :<1, "'... '., .,'l,<!'....,.t. "'<.:. ~~,,' .. ~.,~"\. .~:"\. ...,~~,~':.;:. '~....:..~...
"\:1)' ~\r\~ !.' ~d ,";'~T~ ~~'ir':-''';'11 ~ ~'{r"'~~'J '~~)'\, -:..1 '..j:v~':,;\ .'~,(,\:\ H '';;,r''l~:'" ;""'j'l ;:: ',';/'\';" 11 r j" ~;' i;'-:'" ''r>~'... >'.1 ~~~'r 1\'{ 1 ';.~;~,
",f'Jic!.; 1.,1;; ;jl'::'::~'~;~1 ~QJ r .,dl':fU'I~;' .1::",-:::",'~J', '11,1:, '..'J.;:: .1 ~~ I.~. ~l,r,r'"l,., ;<" '.,:.. :,1., ",'~,":;.....:. ...). _,:...l~<. ~, "'I' ,>:::;~ 1,,('" ,;~J. ~;.....~l... tl':,~,
"'.. ....:.....'-I'..:,~ " R~.V-'.X~...,<I,....,.".V',....... ,'.......,."~.... . ......,.~ ..~:rf I' ;;.;..;..:: to. .....'. .." ,. ......... f'" .....',....
.'" , '> fl' ''''''1 l:>'.", '1 ;-;.r..... ""~r-.,,)'.. r' "'.~.'''' )".. (", I" .". .' ,.'., ~ ".. r:wV CB l)UIlJUGrt. 1'1 ,:;". .' :'1 ..... j"':" r ,..-,( ......'
. 1'",,:,', 1" r t.....I, ~'f;\ ",'.. '~, k'r'....,IO':. "'~'..l, ~1 r.',:! ,;(1:. t ; 1 ,:-,' ,~ l' ,v,, .r' "';-, 11 ", '~ '. r -j ". _' ,~ " ... ~ ' ' J ''\:-1 \, ','\ ,~
,I.: ;.", 'JI('~2233\~,E"" LYMF'IO,,,L' 01,:, ""'" ",'> '. Pay'date''';'iil'' ,;, 11101/96 '.f, :"..;" :':
';,':: .. -'/'L08 ANGELES,'CA:,gb064' , , '..' ~..:. .: , '.' . j
,. "',:'.., ; '.. ,""". <,:'. ,. ."~ "'$0- :
~
-~
'\
amount
$1,687.70 I
Do osltod to tho account of
GEORGE T. KANGANIS
Iransll ABA
0313 0083
NON-NEGOTIABLE
,
i
;
I
I
I
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I
,
I
I
I
I
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Earninqs
Regular
Bonus
Retro
Deductlonll
CO. FILE DEPT, ClOCK VCHR. NO.
Iffiv 802115 ooeo24 V 0000420032 1. .
TELEFLORA
12~3WESTOLYMPICBLVO
LOS ANGELES, CA 90064
Soctal Security Number: 069.50.5538
Taxable Marllal Stalus: Married
ExemptIons/Allowances:
FederaL 3
Slale:
rite hours
2500. 00
this poriod
2.500,00
Earnings Statement
~
..
Period Ending:
Pay Date:
10/18/96
10/18/96
~:$:~~':i~l ~'~~ '''1,lJ~~~~~SJ~~~~<t'!J~;:~~~~:tf'''''~",~''''~~'':'''~!!'~~'4~~":.,!;~,...~~o( ,.:~%"u}~~<"'~:t~~~~~~~~~~j!R.~~~:r.~:,,"~::..<;rI, ~:""
:r~\.rr;:~~. ;1 ;~;:PI'iJJ:l'fJl' ',', Irull~~M' rl'il'ilUilllb1!t1rr~l~tjlfJff{.?:' iIU'ftU!1 i\!j.,Wl::(}?1T~'. i11f,J,ill&;'jj!~fJ.wP;~,11~~J '~~. '1rth:~'1 t<,."i;~lji'$;f)Jf~ I'~
...",~-:....~~,;>;::.:~~.. > ~~5 :;. ''''~'''~~''' ~~. ';.~~~:~".;-,~3"z:'~~kf;~~'I~~~~rM:~uti~:-:~~;:.. ~~~~2'-"" 1:;S ",
:1~~::~!li0?!}ff!~~~fA~G~~rW~~~~;~/2ft~:1X}; !\\fJJ'C''WI '~t~~i~~~;!~~i""'" i~;?~r~9ri:~iJ~;i~!~!::':~~f~!i~!~
Grol. Pay
$2,500.00
S Iltulory
Federal Income Tax
Social Securily Tax
Medicare Tax
PA Stale Income Tax
PA SUI/SOl Tax
Olhar
eking
Medind
401K
NIl Pay
.310,30
.155.00
.36,25
.70,00
.0,75
.1,687,70
.65,00
,175,00.
$0.00
. Excluded from federal taxable wages
Your federal taxable wages this period are
$2,325.00
..
GEORGE T. KANGANIS
4902 CARLISLE PIKE
#412
MECHANICSBURG PA 17055
year to date
51 ,923.08
6,500,00
1,384,61
59,807,69
Other Benefits and
Information
Outmem
thls plllod
87,50
total to date
2.093.27
2.093.27
4,186,54
24.00
448,00
101,08
Matyld
401Ytd
Per Ba!
SIck Bal
Vac Bal
8,446,22
3,708.08
867,21
1,674,62
17,94
32.560,48
1.300,00
4.186,54
O';g'ADP,lrlC
,. . ,. . t" '" .
, .
De osJted to the account of
GEORGE T. KANGANIS
-~
~
w.
"
transit ABA
0313 0083
amount
$1.687.70
NON-NEGOTIABLE
.. ~... ~
co, FILE OEPT, CLOCK VCHR NO,
H)lV 802115 006024 V 0000400034 l' '
TELEFLORA
12233 WEST OL YMPIC BL va.
LOS ANGELES, CA 90064
SOCllsl Securlly Number: 089.50.5538
Taxable Manlal Slatus. MtlTned
Exempllon5/Allowances
Federal 3
Slate.
EarninQs raUI hours this poriod yoar to dato
Regular 2500,00 2.500,00 49,423,08
Bonus 6.500,00
Ratro 1.384,61
Groes Pay $2,500.00 57.307,69
Deduetl"n! ~t~tlltnry
Federal Income Tax -310,30 8,'35,92
Social Secunty Tax -155,00 3,553,08
Medicare Tax -36,25 830,96
PA Slate Income Tax -70,00 1.604,62
PA SUI/SOl Tax -0.75 , 7,' 9
Other
Cklng -1,687, 70 30.872,78
Medlnd -65 ,00 , .235,00
401K -'75 .00. 4,0' 1,54
Net Pay $0.00
.. Excluded from federal taxable wages
I
~
F=
,
,
!
i
I
!
,
,
Your federal taxable wages thiS penod are
$2.325,00
Earnings Statement
f4J
~
,
,
,
,
,
__."..Il~'l'C<"'''I'..r~''''''''];'''''''':<";I']''''''']""]"""""';"'lI:;I"":<.T~rn'l"'''']',,,,j(..m'JI''''''''''j],''rl~''''j;]''l;''a;i:ll'''.'''J''illI''',''j]'''~
! TELEFLORA Advice number: 00000400034 \
I 12233 WEST OLYMPIC BLVD. Pay date: - 10/04/96
\ LOS ANGELES, CA. 90064 -
De osltod to tho account of
GEORGE T. KANGANIS
%~
"
Penod EndIng:
Pay Date,
10/04/96
10104196
GEORGE T. KANGANIS
4902 CARliSLE PIKE
#412
MECHANICSBURG PA 17055
Other Benefits and
Information
Outmem
thiS period
87,50
total to date
2,005,77
2,005,77
4,011.54
24,00
448,00
96,46
Malytd
40,Ytd
Per Bal
Sick Bal
Vac Bal
;',,'A"O.,
transit ABA
0313 0083
amount
$1,687,70
NON-NEGOTIABLE
F"m 1 040
O.panment of the Treasury - - Internal Revenue Ser/ice
U.S. Individual Income Tax Return
(99) IRSU..Onl ..OonoIWfIIIO'lliI 1.lnlhlsl ell
1995
Forth. ..tJiln, 1.0ec.ll.1995,OfOlh.'tlX ..,
Innl
11tS.....
,19 OMS No, 154S-0074
Your locllllecurlty number
089-50-5538
U.. L
the A
IRS B
label. E
Othe,. L
~r~:s. ~ 5275 S RATHMORE DRIVE (~(..::-\ j"':'" C\Ji
~~'~p.~ MECHANiCSBURG PA 17055 V. \)!i;-,:; 'I Vee No
Pr..'dential ... 00 you wanl $3 to go to this fund? . . . . >..-: . . . . . , . . . . . . X
Election Campaign' II a 'oinl return, doss our s aus. want $3 to 010 this lund? . . . . . . . . X
1 Single For Privlcy Act and Paperwork Reduction Act Notice, se. page 7.
2 X Married filing joint relurn (even if only ono had income)
3 M.rrled filing $Oplrale ,.Iurn. Enle, ,polne', SSN Ibove& full name her.,..
4 Head of household (with qualifying person). (See page 12.) II qualifying person is a child but nol your dependenl.
enter child's name here. ...
Quali i widow(erl with de endent child ( r. souse died""9 ). (Sea a a 12.)
X Yourself. II your parent (or someone elso) can claim you as a dependent on hislher laX} No.ofbollllS
return. do not check box 6a. But bo sure to check box on line 33b on page 2. ~~~~edlJn~
b X Souse.............,...............................................
C Dependents: 2 Dependent's social 3 Dependent's No. of No. of your
secUltty number It born relalfonshlp to mo. "hed In children on 6c
(1) First name Laslname InI995.Sl}ft~ge'J. you '19::r19~~ who;
THOMAS G KANGANIS 199-66-0857 SON 12
Ifmor.'hansixDEAN G KANGANIS 204-70-1689 SON 12
dependents.
see page 13.
GEORGE T KANGANIS
ROSEMARIE KANGANIS
/ ~oll: .' 1.;", \ 'I
. l...~. I \ .
'.1./ i'-' ..... :\'
........ 4....... '... :_' ., ~
Spouse', loclAllKurlty no.
131-38-4200
Note: Checking
"Yes" will not change
your lax or reduce
your refund.
Filing Status
(See page 11.)
Check only
one box.
5
6a
Exemptions
IS.. page 12,)
2
. u...od with you
. dldn't U...e wJlh
you due 10 dl...orce
orseparaUon{see
pagel",
2
o
~;I":n~~:sa~~~ 0
d
e
7
Income
8a
Attach b
Copy B of your
Forms W-2, 9
W-2G, and 10
1099-R he... 11
If you did not 12
get a W-2. see 13
page 14. 14
15a
Enclose. but do 16a
not attach, your 17
payment and 18
payment 19
voucher. See
page 33. 20a
21
If your child dldn't IIvewlth you but Is claimed as yeur dependent under a pre.1985 agreemenl.ch&Clc here ...
Total number of exem lions claimed.
Add numbers
Dnle,oden
llne~above ...
Wages, salarIes, lips. etc. Attach Form(sIW.Z
7
8a
65
142.
26.
Taxable interest income {see page 15). Attach Schedule 8 il over $400. . . . . . . . . .
Tax-exempt interest (see pg. 15). DON'T include on line Sa 8b
Dividend income. Attach Schedule 8 il over $400 .
Taxable refunds, ctedits. or offsels of stale and local income taxes (see page 15)
Alimony tecei."ed . . . . .
Business income or(loss). Attach Schedule C or C-EZ, . .. . . .
Capital gain or (loss). If required, attach Schedule 0 (see page 16) . .
Other gains or (losses). Attach Form 4797. . . .. . . . . . . . . . . . . . . .. . . ..
Total IRA dislributions .. ~ I b Taxable amount (see pg. 16)
Tolalpenslomandannufll,". ~ b Taxable amount (see pg. 16)
Rental teal eslate, royalties. partnerships. S corporations. trusts, etc. Attach Schedule E . . .
Farm income or (loss). Attach Schedule F. , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Unemployment compensation (see page 17). . . . . . . . . . . . . . . . . . . . . .
Social security benefits. ~I I b Taxable amount (see pg. 18)
Other income.
9
10
11
12
13
14
15b
16b
17
18
19
20b
65 168.
Form 1040 (1995)
Adjustments
to Income
22 Add the amounts in the far ri ht column lor lines 7 throu h 21. This is our totallncom8. ...
23a Vour IRA deduction Ise. page 19)" " " , , , , " , , , " '" 23a
b Spouse's IRA deduction (see page 19). .. .. . . .. . . . . , .. 23b
24 Moving expenses. Attach Form 3903 or 3903-F. . . . . . . . .. 24
25 One-half of self-employment tax. .. .. . 25
26 Sell-employed health insurance deduclion (see page 21). 26
27 Keogh & self-employed SEP plans. If SEP, check. . . ... 0 27
28 Penalty on early withdrawal of savings. . . . . . , . . . . . . , . . . 28
29 Alimony paid. Recipient's SSN'" 29
65 168.
30 Add lines 23a throu h 29. Those are our lotalad ultmenb . . . . . . . . . . .
Ad . Gr. Income 31 Sublract line 30 from line 22. This is our ad Ulted r018 I"coma .
CM 104012 NTF 1378
Copyright Form3 SeflwareOnly, 1995 Neice, Inc. N9510"01
.......
.........
Preparers Edition
Tax
Compu-
tation
Form 1040 (1995)
32
33a
(Sf. page
23)
If you wanl
the IRS 10
ligureyour
lax, see
page~.
Credits
(S8"! page
24,)
Other
Taxes
(See
pa9.25,)
Payments
Attach
Forms W-2.
W-2G. and
10SS-R on
page 1.
Refund or
Amount
You Owe
Sign
Here
Keep a copy
of this return
for your
records.
and type'" 57
Amount paid with Form 4868 (extension request) . , . 58
Excess social security and RRTA lax withheld (see page 32). 59
Other payments. Check if from aD Form2439 bO Form4136. 60
Add lines 55 throu h 60. These are ourlotal a ments ....... ......... . .. ...
If line 61 is more than line 54. subtract line 54lrom line 61. This is the amount you OVERPAID.
Amount of line 62 you want REFUNDED TO YOU. . . , . . . . , . . , . . . . . . . . . . . . . . . . . ...
Amount of lin. 62 you want APPLIEO TO 1996 EST. TAX" ,~ 64
If line 54 is more than line 61, subtract line 61lrom line 54. This is the AMOUNT YOU OWE.
For details on how to pay and use Form 104o-V. Payment Voucher, see page 33 . . . . . . . . . .
66 Estimated tax pena (see a e 33). Also include on line 65. .. 66
Under penalties 01 perjury, I declare that I have examined this relurn and accompanying schedules and stalements, and to Ihe best
of my knowledge and belief, they are true, correct, and complele. Declaration of preparer (olher lhan taxpayer) is based on all
information of which preparer has any knowledge.
Iil... Your signature Date Your occupalion
,.. ALES
~ Spouse's signature. If a joint relurn, BOTH must sign.
KANGANIS
089-50-5538
Amountlrom line 31 (adju~ted gross income) .
Check if: 0 You were 65/older, 0 Blind; 0 Spou.. was 65/01der,
Add the number of boxn checkod above and enter (he lolal here.
b If your parent (or someone else) can claim you as a dependent. chock here
C If you are married filing separately and your spouse Itemizes deductIons or you
are a dual-status alien, see page 23 and check here. ..... . .... .
EnllJr {itemiZed deduc:tlors from Schedule A, line 28, OR }
the Sund.rd deduction ~hown below lor your flhng status. Bullf you checked
largor Iny box on IIn. 33. or b, go to page 23 10 lind your sland. ard deduction
If you checked box 33c, your slanoard deducllon is zero
01 . Single __ $3,900 0 Married filing jointly or Qualifying widow(er) -- $6.550
your: . Head of household -- 55,750 . Married filmg separately -- $3.275
Subtract line 34 horn line 32.
If line 32 is $86,025 or lass, multiply $2,500 by Ihe lolal number of exemplions claimed on
line 6e. It line 32 is over 586,025, seo the worksheet on page 23 lor the amount 10 enter. .
TaxJlble Income. Subuactline 36 Irom lin!! 35. II line 36 is more than line 35, enler -0- .
Tax. Check if Irom a 181 Tax Table, b 0 Tax Rate Schedules. C 0 Capital Gain Tax Work-
sheet, or dO Form 8615 (,eepg Z",) Amountlrom Forms) 8814'" e
AdditIonal taxes. Check It from a 0 Form 4970 b 0 Form 4972
Add lines 38 and 39. . . . . . . , . . . . .
Credit lor child & dependent care expo Attach Form 2441 .,. .
Credit for the elderly or tho disabled. Attach Schedule R '
Foreign tax credit, Attach Form 1116 . . . .. . . . .
Other credits (see page 25). Check if from a 0 Form 3800
b 0 Form 8396 C 0 Form 8801 d 0 Form
Add lines 41 through 44.
Sublract tine 45 from line 40. II line 45 is more than line 40, enter -0-.
Self-employment tax. Attach Schedule SE.
Alternative minimum lax. Attach Form 6251 .
Recapture taxes. Check if from a 0 Form 4255 b D Form 8611 cD Form 8828.
Social security and Medicare tax on lip income not reported 10 employer. Attach Form 4137 .
Tax on qualified relirement plans, including IRAs. If required, attach Form 5329 .
Advance earned income credit payments from Form W-2.
Household employment taxes. Attach Schedule H. . . . . . . . . . .
OShnd
~33.a
~ 33b
o 33c
34
35
36
37
38
39
40
41
42
43
44
41
42
43
44
45
46
47
48
49
50
51
52
53
54 Add Jines 46throu h 53. This is our lotallax. . . .
55 Federal Inccme lax withheld. If any Is ham Form(s} 1099, ch~k ...
56 1995 estimaled tax payments & amt. applied from 1994 relurn ,
57 Earned Income credit. Attach Schedule EIC Ifycu have a qualifying
child. Nontaxable earned Income: amI. ... I
.......
8 658.
58
59
60
61
62
63
64
65
Date
Pa e 2
65 168.
,~
34 10 839.
35 54,329.
36 10 000.
37 44 329.
38 7 341.
39
40 7 341.
,0
45
46
47
48
49
50
51
52
53
7 341.
7 341.
62
63
8 658.
1 317.
1 317.
,..,""""
:i:ii!:ii:i:!
:i:l!::%:
:JH1d!::1
Spouse's occupalion
ECTURER
Preparar's social security no.
121-22-7089
Preparer's" ,-f) I / / D~li 1/
signature' 'IU..., t....'-l\.L. ali.. t. at.u{ , )..; I.:-~
Firm's name (or yours.. THOMAS G KANGANIS CPA
ffs.W-.mployed) ,..3607 ROSEMONT AVENUE STE 203
and address CAMP HILL PA
CM 104012 NTF 1379
Ccpyrlghl FcrlrQ Soflwllre Only, 1995 Nelco,lnc, N9510"'OZ
Paid
Preparer's
Use Only
Check if
self-em 10 ad
EIN
ZIP code
17011-
Pre parers Edition
SCHEDULE A
(Form 1040)
Schedule A -- Itemized Deductions
OMB No, 1545-0074
.. Attach to Form 1040. .. 5.. Inltructlon. for Sch.dul. A (Form 1040).
1995
Attachment
S. uence No. 07
Your loclal security no.
089-50-5538
O.partl'l'llnt of Treasury
Inl.rnal Rev. Service (99)
Name(s) shown on Form 1040
GEORGE T & ROSEMARIE KANGANIS
Medical Clutlon: 00 not include expenses reimbursed/paid by olher!.
and 1 Medical and dental expenses (5'ol8 page A-l) . .
Dental 2 Enter amL 'rom Form 1040. line 32 2
Expenses 3 Multip~ lin. 2 abo'. by 7,5% (.075) , ,
4 Subtractlin. 3 from line 1. If line 3 is more than line 1. enler -0- .
5 Slate and local income talCes. . . . . . .
6 Real estate taxes (see page A~2l. . . . .
7 Personal property taxes. .
8 Other taxes. List type and amount ..
SEE STMT
,..1';
1
3
5
6
7
1 996.
2 197.
Taxes You
Paid
(5.0
page A,l,)
538.
8
4 731.
Interest
You Paid
(S8e
page A-2,)
9 Add lines 5 throu h 8 .
10 Home mortg. interest & points reported to you on Form 10ge . .
11 Home mortgage interest not reported to you on Form 1098. II
paid to the person from whom you bought the home, see page
A-3 & show that person's name. identifying no.. and address'"
5 973.
Nole: 11
Personal 12 Points not reported to you on Form 1098. See page A-3 lor
interesl is special rules. . . . 12
nol 13 Investment interest. 11 required. attach Form 4952. (See page 131
deductible.
A-3,) , .........
14 Add lines 10 throu h 13. 5 973.
Gifts to 15 Gifls by cash or check. II you made any gilt of $250 or more.
Charity see page A.3. . . . . . . 15 135.
II you made a 16 Other than by cash or check. " any gifl 01 $250 or more, see
gifl and got a page A-3. II over $500. you MUST attach Form 8283 . . . 16
benefit lor it, 17 Carryover lrom prior year. . ...,..,.. 171
see page A-3. 18 Add lines 15 throu h 17. . . . 135.
Casualty and
Theft Losses
Job
Expenses
and Mosl
Other
MIscellaneous
Deductions 21
22
19
19 Casual or theflloss(esl. Attach Form 4684. (See a e A-4.).
20 Unreimbursed employee expenses n job travel, union dues,
job education, etc. If required. you MUST attach Form 2106 or
2106-EZ, (S.. page A-5,) ~
.'1!:ii:::I'
',:\1miH:
[il\I;!\liH::
;)dil':i1:
:l\lli:!i:i'i:
'i'\-':"(I'
iitli:ii;ii:
'il'i'li!I:li
!ii\!il:P!i
lill!!!I!:!:
ii'il!!!!!!:!!
"1'lil'IIII:1
!i:ii1ii!I!H
1,11 l1HI:\:1
,II'II:,;llli
26
"111",1",:11
1'llill!l::
'li\I:!::I!:
27
Tax preparilotion fees. . , . . . . . . . . . . . . . , . . . , . . , .
Other expenses _w investment. safe deposit box. etc. list
type and amount ...
(Se.
page A-S for
expenses to
deduct here.)
23
24
25
26
27
Add lines 20 through 22. . . . . . . . . . . . , . . . . . . . . . . . . . . . 23
Enter ami. Irom Form 1040. line 32 24 U;ii;::\:
Multiply lin. 24 above by 2% (.02), . ' , ' , ' . , , ' , , ' , , . , ' . . ' , 25
Subtract line 25lrom line 23. If line 25 is more than line 23. enter -0-..
Other _w from list on page A-S. List type and amount'"
Other
Miscel-
laneous
D uctl ns
Total
Itemized
Deductions
28 Is Form 1040.lino 32. over $114.700 (over $57.350 if married filing separately)?
NO. Your deduction is not limited. Add tho amounts in the lar right COlumn}
for lines 4 through 27. Also. enter on Form 1040. line 34. the larger of . . . , . ...
this amount or your standard deduction.
YES. Your deduction may be limited. See page A-S for the amount to enter.
For Paperwork Reduction Act Notice, see Form 1040 Instructions. Co~u18r Official Edition
CM A10 NTF 1Z70
I
Schedul. A (Form 1lJ.40) t995
CopyrIght Forms Softwlfe Only. 1995 Nelco.lnc. N950A 1
Sale of Your Home
OMB No, 1545-0072
1995
Anachment
s. uence No. 20
Your social security no.
OB9-50-553B
Spou.... SSN
131-3B-4200
Form 2119
~ Attach to Form 1040 for y..r 01 III..
... S.. Ilparl'slnstrudlons. .. Pion. print or type.
Oepartment 01 Treasury
Internal Rev, Service
Your first name and initial. If a )oint return, also give spous.s name and initial. Last name
GEORGE T & ROSEMARIE KANGANIS
FIliI" Your Addr... Present address (no.,slI.... &.pt. no. fUf.1 foule, 01 PO box no. II mlllts noH:~.lIv.rlKllo sUHudd,,,sl
Only II You Are Filing 2 7 5 STRATHMORE DRIVE
This Form by Itself , .
Ind Not WIth Your CIty, town or post OHIC8. state, and ZIP codo
Tex Return ECHANICSBURG
PII't~ I.! Gain on Sale
1 Date your former main homo was sold (month. day. year) . .
2 Have you bought or built a new main home? .
3 \I any part of either main home was ever rented out or used tor business, check here. .
4 Selling price of home. 00 not include personal property items you sold with your home .
5 Expense of sale (see page 3). . . . . .' , .
6 Subtract line 5 from line 4, .. . , . . . ... .
7 Adjusted basis 01 home sold (see page 3) . . .
8 Gain on sale. Sublract line 7 from line 6 .
PA
17055
~
1
No
.. 0 and see page 3.
4
5
6
7
8
117 000.
9 697.
107 303.
95 B05.
11 49B.
Is lineS
more than
zero?
Yes -to' If line 2 is ~Yes.~ you must go to Part II or Part III. whichever applies. If line 2 is
"No,~ go to line 9.
No ~ Stop; see Loss on the Sale of Your Home on page 1.
D No
DYes
If you haven't replaced your home, do you plan to do so within the replacement period (see page 1)? .
. II line 9 is "Yes: stop here. attach this form to your return, and see Additional Filing Requirements on page 1.
. If line 9 is "No: au must 0 to Part II or Part Ill, whichever a lies.
Pae1:1I One-Time Exclusion of Gain for People Age 55 or Older -- By completing this part. you are electing to take the
one-time exclusion (see page 2). If you are not electing to take the exclUSion, go 10 Part III now
Who was age 55 or older on the date 01 sale? . You Your spouse
Did the person who was 55 or older own and use Ihe property as his or her main home lor a total of at least 3 years of
the 5.year period before the sale? See page 2 for exceptions. II "No: go to Part III now. .
At the time 01 sale. who owned the home? . . . . . . . . . 0 You
Social security number 01 spouse al the time of sale if you had a different spouse Irom the one above.
If you were not married althe time 01 sale. er.ter "None"
14 Exclusion. Enter the smaller of line 8 or $125.000 ($62.500 if married filing separate return).
Then, 0 to line 15 . . . . .. . . .
Partin Ad'usled Sales Price, Taxable Gain, and Ad'usled Basis of New Home
15 If line 14 is blank, enter the amount from line 8. Olherwise, subtract line 14 from line 8.
. If line 15 is zero, stop and attach this form to your return.
. If line 15 is more than zero and line 2 is 'Yes: go to line 16 now.
. If you are reporting this sale on the installment method, stop and see page 4.
. All others, stop and enter the amount from line 15 on Schedule O. col. (g), line 4 or line 12.
16 Fixing-up expenses (see page 4 for time limits). .........,.............
17 If line 14 is blank. enter amount from line 16. Otherwise. add lines 14 and 16 . . .... . .. , . 17
18 Adjusted sales price. Subtract line 17 from line 6. .........,...... ..... ......... 18
19a Oate you mov,d into newhorM" ~ I 06/20/95 Ib CostolnewhorM(seepage4)"",,, 19b
20 Subtract line 19b from line 18, If zero or less, enter -0- . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
21 Taxable gain. Enter the smaller 01 line 15 or line 20 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . 21
. If line 21 is zero, go to line 22 and attach this form to your return. ilil)!!!i!i!\
. If you are reporting this sale on the installment method, see the line 15 instructions and go to line 22. :::!!i!I!IU1
. All others, enter the amount from line 21 on Schedule 0, col. (g), line 4 or line 12, and go to line 22. '1:1:::i:\:I:
22 Postponed gain. Subtract line 21 from line 15 .. . . . . . .. .. . . . .. , . . .... .. .. . ..... , . . ... .. .. . 22
23 Ad usted basis of new home, Subtract line 22 from line 19b .. . . . . . . . .. .. ., . . . . 23 161 370.
Sign Here Under p'en~lt!es of perjury, I declare that I have examined this form. including attachments, and to the best of my knowledge
Only If You and belief, It IS true, correct, and complete.
Are Filing Your signature Date Spouse's signature Date
This Form by
ltse" and Not .
With Your Tax
Return It a' int return, bolh must si n.
For Paperwork Reduction Act Notice, see .aparale Instructions.
CM 21191 NTFZ986
9
10
11
Both of you
12
13
o Your spouse
8 Yes D No
Both of you
~
13
14
107
172
303.
B6B.
.
Form 2119(1995)
Copyright Forms Sef{wlre Onty. 1995 Neice, Inc. N9521191
089-50-5538
-------------------------------------------------------------------------------
-------------------------------------------------------------------------------
SCHEDULE A, LINE 8: SUPPLEMENTARY SCHEDULE OTHER TAXES
Other taxes:
PASUI
PASUI
PA INCOME TAXES PAID
LOCAL WAGE TAX PAID
IN 1995.
IN 1995
Amount:
70.
6.
1.
461.
538.
-------------------------------------------------------------------------------
FOR PENNSYLVANIA RESIDENTS ONLY
PA-40R INCOME TAX RETURN
..*YOU MUST FILE BY MIDNIGHT MONDAY, APRIL 15. 1996".
o Fiscal Year File, Beginning .1995 End ,1996
Commonwealth 01 Pennsyl....ania PA Oepat1monf 01 Revenue
OFFICIAL USE ONLY
tR
TYPE FILER (Check Only One)
'SO MD JILl FO
SINGLE FIIt~~.~I~~l!lty JOINT FINAL
Check Here Only II a Part. Year Resident
From .1995 10 .1995 0
NAME OF THE SCHOOL DISTRICT
Whllll' you livid December J 1, 1995
CUMBERLAND VALLEY
MAKE CORRECTIONS BELOW
Your Social Securi Number
S OUSlt's SSN .. even illllin 58 <lratel
089-50-5538
Name (Last. First and Middle Inj(jaJ)
KANGANIS GEORGE T &
Slreet Address (Including Number)
5275 STRATHMORE DRIVE
City Slale
MECHANICSBURG PA
la GROSS PENNSYLVANIA COMPENSATION"""", la
lb UNREIMBURSEO EMPLOYE BUSINESS EXPENSES, lb
1c TAXABLE PA COMPENSATION. Subtract Line lb from line 1a. . . . . . . . . . . . .
2 TAXABLE INTEREST. Complete PA Schedule A il over $1.000.,.
3 TAXABLE DIVIDENDS. Complete PA Schedulo 8 jf o\ler $1,000.
4 NET INCOME or [LOSS] !rom OPERATION 01 a BUSINESS, PROFESSION or FARM,
5 NET GAIN or [LOSS] I,om Ihe SALE, EXCHANGE or DISPOSITION of PROPERTY.
Sa AMOUNT of GAIN EXCLUDED on PA Schedule PA-19 . Sa
6 NET INCOME or [LOSS I from RENTS, ROYAL TIES, PATENTS or COPYRIGHTS,
7 ESTATE and TRUST INCOME, , " '
8 GAMe LING and LOTTERY WINNINGS, , , ,
9 TOTAL PA TX8L. INCOME. Add Lines 1c. 2. 3, 4. 5, 6. 7, & 8. Do Not Oeduct Losses
10 PA TAX LIABILITY. Multi I Une 9 b 2.8% (0,0281.
11 TOTAL PA TAXWITHHELO"",,,, """'"
1995 ESTIMATED PAYMENTS AND CREDITS. Read theln.truet;on. on a. 20.
12a CREOIT !rom 1994 PA TAX RETURN, , , , , , 12a
12b 1995 ESTIMATEO INSTALLMENT PAYMENTS, , ' , , , , , 12b
12e PAYMENT wnh 1995 EXTENSION REOUEST, , " , 12e
12d TOTAL ESTIMATED CREDIT, Add Lines 12a, 12b and 12c . . . . . . . , . . . , . . . . . .
TAX FORGIVENESS from PA SCHEOULE SP. Read the Instructions innln on
13a HOUSEHOLO MEMBERS !rom Line 4. Part II, PA Seh, SP" 13a 2
13b ELIGIBILITY INCOME from Line " Part III. PA Seh, SP "" 13b 81 148. 00
13e YOUR TOTAL INCOME from Line 21. SIep 5, SP WKSHT, 13e 00
13d TAX FORGIVENESS from Line 6, Part III, PA Schedule SP.. . . . ,. . . . , . 13d 00 II of Schedules G
14 TOTAL CREOITfor TAXES PAlO 10 OTHER STATES or COUNTRIES, , , , , , , , , , , 14 00 # 01 Schedule. W
15 EMPLOYMENT INCENTIVE PAYMENTS CREOIT. " , . " ",," , " , , " , , , " , , , , 15 00
16 TOTAL CREDITS and PAYMENTS, Add Line. 1,. 12d, 13d, 14 and 15 ' 16 1 940. 00
17 TAX DUE (If Line 10 is mare than Line 16, refer to page 21 & complete PA Payment Voucher on a e 38.) 17
18 OVERPAYMENT (Line 16 is more than Line 10), . , . " . "., .. . ,. . . . , . , . . ., . . . .. 18 00
19a AMOUNT of LINE 18to be REFUND EO , , " , , , , , " , , , """ , , , , , " , , , , " , ' " , , , , " , , " ' " , 19,
19b AMOUNT 01 LINE 16to be CREDITEO to your 1996 ESTIMATED TAX ACCOUNT. . "" , '" , , , " , '" ' , '''' 19
1ge AMOUNT 01 LINE 18to be DONATED to WILO RESOURCE CONSERVATION FUNO, , , , '" , ' , , , ' , " , , , ", 1ge
19d AMOUNT of LINE 1810 be OONATED to U,S, OLYMPIC COMMITTEE, PA DIVISION, , , " '" ' " , ' . , , , , , '" 19d
The TOTAL of Line. 19a through 19d MUST Equal L1n.1B.
it~~\9~n R ~~r ~1~~11~ffr~lIggr?ur1I:Blol~wl~I~~llIng 10Inlly)d&Clare thall (wel ha....e examined this relurn,lncfudlng all accom~nylng KhedulllS and statements, and to
Your Signalure Dale Your Occupation
X ALES
131-38-4200
Spouse's
ROSEMARIE
Apt. No
Rural Aoute or p, O. 80x No.
SCHOOL DISTRICT CODE
I 21160 I
CHECK IF YOU WILL NOT NEED A 1996
PA TAX BOOKLET
Zip Code
17055
69 624.
81
2
1
148.
272.
940.
X
INDICATE HOW MANY
OF EACH FORM OR
SCH, IS ATTACHEO
00 # 01 Forms W-2 2
00 II ot Schedules UE
00 II of Schedules A
00 II of Schedules 8
00 # of Schedulos C
II at ScMdules RK-1
00 # 01 Schedules F
00
00
00
00
00
# of Schedules C-F
II of Schedules 0
II 01 Schedules 0- 71
# of Schedules F'1\-19 ---r-
II of Schedules E
II 01 Schedules J
# of Schedules 0-1
00
00
Ie
69 624.
26.
11 498.
00
00
00
120
a e25,
00
Schedule SP.. D
(Check only jf claiming
lax forgiveness)
332.
00
DO
00
00
00
Spouse's Signature
X
Date
BE SURE YOU (ANO YOli!l SPOUSE) SIGN. CHECK ALL MATH.
ATTACH ALL SCHEDULES AND FORMS
Spouse's Occupation
ECTURER
Daytime Telephone Number
717-975-3343
Preparer's Telephone Number
717-575-1850
Preparer's Name:
THOMAS G KANGANIS CPA
NTF 9969A CopyrIght Form3 SOltwareOnly, 1995 Nelco,lnc. N95PA 1
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF REVENUE
SALE OF RESIDENTIAL PROPERTY
See Instructions
PA-II(10-1")
Anach a se arale PA-1910 lorm PA-40R or PA-40NR lor each sale
Name(,) a' ,hown on PA-40R or PA-40NR
KANGANIS GEORGE T & ROSEMARIE
Please Prinl or T . alllnlormalion
Your Social Security Number
089-50-5538
Addres, of residence sold:
Slreet Number
5275 STRATHMORE DRIVE
City
MECHANICSBURG PA 17055
GENERAL INFORMATION
1a, Dale properly wassold, 06/20/95
Your Spouse's Social Security Number
131-38-4200
Slate
Zip Code
Filing stJItus (check appropria1e box)
o Single
Qg Married, Filing Joint Relurn
b, Dalo properly was acquired, 10/03/86
c. Percentage ownership inlerest in property 1 0 0 _ 0
o Married, Filing Separate Return
% (calculated to Iwo decimal places)
o Joinl claim for Tax Forgiveness
D OeceasedlFinal Return
d. Enter the face amoun1 of any mortgage. note or other financial instrumenl on which you will
receive eriodic a ments of rinci al and/or inleresllrom this sale: $
PART I i'ill.I'iil,COMPUTATION: OFi GAIN lOR LOSS
Date of Death
iiiiii:i::i:nHli:
To dotermlne your residential Use factor. answer questions 2a and b. During the 5 years preceding the sale or disposition of your residence.
did you use:
2a. Any of Ihe property surrounding the residence for business, commercial. industrial. rental. inveslment. or other
nonresidential purposes lor more than 2 years? . . . . . . . . . 0 YES Qg NO
b. Any part of the residence itself for business. commercial, rental. or other nonresidential purposes for more than
2 years? , . . . . . . . . . . . . 0 YES ~ NO
If you answered "No" to both questions, enter "100-/." on line 2c.lf you answered "Yes" to eilher or both questions. com lete the
Resldentlll Use Factor Worksheet to compute your factor before proceeding to I1ne 2c.
c. Residential use factor. Complete worksheet lor line 2c. 2c. 100 . 0 %
3, Gross proceeds less expenses of sare for entire property (including property used for nonresidential purposes).
(See line instructions.) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3,
107 303.
4. Line 3 x residential use factor Wne 2c) . . .
4,
107 303.
5. Line 3 lass line 4. If you answered -NO. to both 2a and 2b, enter zero here.
5,
6. Adjusted basis of entire property (including property used for nonresidential purposes) . . .
6,
95 805.
7, Adjusted basis of property used for nonresidential purposes (enter zero if not applicable) . . .
7,
8. Line 6 less line 7. . . . , . . . . . . . . . . . . . . . . . . . , . . . . .
8,
95 805.
. 9. Alternative basis of enlire property (including property used for nonresidential purposes). . . . . . . . . . . . . . . . . . . . 9.
. 10. Alternative basis of property used for nonresidential purposes. If you answered ~NO' to both 2a and 2b, enter
zero here. . . .. . .. .. . . . . . . . . . . . . . . .. .. .. . ... . . . . ... .... . . . . ... . . , . . .. .. . .. . .. ,..... 10.
. 11. Line 9 loss line 10. . . .. . . . . . . . . ... . . . . . .. , . .... .. .
11.
12. Not gain [loss] on residential property (see instructions).
12,
11 498.
13. Net gain [lossJ on nonresidential property (see instructions).
13,
14, Combined ain loss (line 12 + line 13), , , , , " ' '" , , , , , , , , "" , , , , , " , , , , ' 14, 11 498.
If you have a [loss] on line 14 or if you are not electing the principal residence one-time gain exclusion, enler the gain [loss] shown on your PA.40R
or PA.40NR. If you are electing the one-time exclusion, proceed to Part 11.
'Complet. only R property was acqulrod boror. June 1. 1971. Obtain and complete PA Schodule 0-71, REV-1742.
PA191 NIF'....
CopyrIght FormsSallwar. Only, 1995 Nelco, Inc. N95PA191
GEORGE T & ROSEMARIE
,'I
,lil:il,::il:ilji::r!I:':!Hiillll:! llil!: I ': I ,!,I:I~!II!I!lllq!ll! :'1, I:III!! li
DYES
DYES
DNO
DNO
Sec1lons A through 0 -- Complete only the ONE Section that applies 10 you.
!II '1 Thl'lectlon must be used by the 'ollowlng Individuals. (Check appropriate box.)
Single at the time of the electing salo.
Married at the lime of the electing sale BUT who owned the principal residence solely in own name.
Married alth,lime 01 the electing sale AND has chosen to We a separate return and make a separate ejection.
15a. Dale of sale (It before July 1. 1987. you may not claim Ihe 55 or over exclusion.)
b. Were you at least 55 years old on dale of sale? .... .,... . .. . . . . . . . . . .. .
c. Did you own and use the property as your princiDal residence lor a tolal at at least 3 years (except for certain short
absences ~~ see instructions) of the 5~year period before its sale or disposition? . . . . . . . . . . . . . . . . . . . . . . .
d. 00 you elect the one-timo gain exclusion? (II "YES", complete Section E.) . . . .
I'SEcrTl.ONirBij This section must be ,,,sed by married Individuals who jointly own their principal resldeneal AND are flllng a joint return.
16a. Were you at least 55 years old on date of sale? . . . . . . . .
b. Was your spouse at least 55 years old on date of sale? .
c. Old the spouse who answered ~YES~ to 16a or b own and use the property as his principal residence for a total 01 at
least 3 years (except for certain short absences -~ see instructions) of the 5-year period before the sale? . . . .. .
d. Do you and your spous~ elect the one-time gain exclusion? (If '"YES~ block is checked. a joint olection has been made.
Also complete Section E.) .. . . . . . . . . . . . . . . . ... . .. . . . . . . ..
DYES
DYES
DNO
DNO
DYES
DYES
DNO
DNO
ISECTION:;'C:1 This section must be used by widows or widowers whose spouse died after the electing sale and who have NOT
remarried (widows or widowers who owned the principal residence sold in their own name may be eligible 10 maka
an election under Section A).
17a. Were you at least S5 years old on date of sale? .... .
b. Did the decedent own and use the property as his principal residence for a total 01 at least 3 years (except for certain
short absences -- see instructions) of the 5-year period before his death? .. . .. . . .. . . . . . .. . .... . . . . . ... . . . .. . .
c. Do you elect the one-time gain exclusion? Of '"YES~, also complete Section E.)... . . . .. . . ..
IiSlSO'tIONiiP:1 This section must be used on thellnal return 0' a decedent.
18a. Was the decedent at least 55 years old when he entered into the sales agreement? . . . . .
DYES
DNO
DYES
DYES
DNO
DNO
DYES
DNO
b. Did the docedent own and use the property as his principal residence lor a tolal of at least 3 years (except for certain
short absences _4 see instructions) of the 5~year period before his death? . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . .. 0 YES
19,
Percentage ownership ir. property (line lc of PA~19) x $100,000. . . .
(If you are married tiling separate returns, see instructions)
DNO
DNO
c. Do you elect the one~time gain exclusion on behalf of the decedent? (If ~ES~, also complete Section E.), .. ..... ... .. 0 YES
I.SECTIONi:!5i'l II you have elected the SS or over one-time gain exclusion In Seelion A. B, C or 0, completeUne. 19 through 21.
20. Allowable exclusion (smaller of line 12 or line 19), Enler the amount here and on PA-40R or PA-40NR. . . .. .... . .. $
21. Gain after exclusion (ljne 141e5s line 20). If line 14 is greater than line 20, enter the difference as a gain here and on
your PA-40R or PA~40NR. Otherwise, enter a zero on PA-40R or PA~40NR . . . . . . . . . . . . . . . . . . . . . . . . . . .. $
PAI92
NTF4100A
CopyrIght Form Software Only, 1995 Nelco, Inc. N95PA 192
$
11,498.
f'OR PENNSYLVANIA RESIDENTS ONLY
PA-40R INCOME TAX RE"rURN 1
...YOU MUST FILE BY MIONIGHT MONOAY, APRIL 15, 1996 '" \ M Rf:1-
o Fiscal Year Filer Beginning .1995 End. J ~l ~. 1 I' :'9
Commonwea~h of Penns Jvania PA De art lb{ ~~.we ' ::IS!
OFFICIAL USE ONLY
.-
TYPE FILER (Check Only Onel
sl!J MD JD FD
SINGLE FIII~"r.~~~.1v JOINT FINAL
Chock Here Only II a Part-Year Resident
From ,1995 10 ,1995 D
_n..- ......~:
/,-, .-., ;-" - "
~(Q)~) '\J
MAKE CORRECTIONS BELOW
Your Soci<:.l Secur Number
I Spouse's SSN - - e,en if Hlinq separ"elt
Spouse's
NAME OF THE SCHOOL DISTRICT
Wh.f. you ltv~ December 31,1995
CUMBERLAND VALLEY
199-66-0857
Name (Lasl. First and Middle Initial)
KANGANIS THOMAS G
Slreet Address (including Number)
5275 STRATHMORE DRIVE
City Stale
MECHANICSBURG PA
la GROSS PENNSYLVANIA COMPENSATION, , , ' la
lb UNREIMBURSEO EMPLOYE BUSINESS EXPENSES, ' lb
1c TAXABLE PA COMPENSATION. Subtract Line lb from Line 1a.
2 TAXABLE INTEREST. Complete PA Schedule A if over $1.000..
3 TAXABLE DIVIDENDS. Complete PA Schedule B jf over $1,000.
4 NET INCOME or [LOSSj from OPERATION of a BUSINESS, PROFESSION or FARM,
5 NET GAIN or [LOSSI from .he SALE. EXCHANGE or OISPOSITION of PROPERTY
Sa AMOUNT of GAIN EXCLUDED on PA Schedule PA-19 . Sa
6 NET INCOME or [LOSSjfrom RENTS, ROYAL TIES, PATENTS or COPYRIGHTS
7 ESTATE and TRUST INCOME, , , , , , , . , , , , , , , , , , , ,
8 GAMBLING and LOTTERY WINNINGS, '
9 TOTAL PA TXBL. INCOME. Add Lines 1c, 2. 3.4.5.6.7. & 8.
10 PA TAX LIABILITY. Mult; I Line 9 b 2.8% (0.028L
11 TOTAL PA TAX WITHHELO""",,, "" " " " "
1995 ESTIMATED PAYMENTS AND CREOITS. Read the instruction. on a e 20.
12a CREOIT from 1994 PA TAX RETURN, , , , ' , , , ' 12a
12b 1995 ESTIMATED INSTALLMENT PAYMENTS, ' , 12b
12c PAYMENT with 1995 EXTENSION REQUEST", 12c
12d TOTAL ESTIMATED CREDIT, Add Lines 12a, 12b and 12c
TAX FORGIVENESS from PA SCHEDULE SP. Read the Instructions
13a HOUSEHOLO MEMBERS from Line 4. Pan II, PA Sch, SP, 13a
13b ELIGlelLITY INCOME from Line 1, Pan III. PA Sch, SP "', 13b 00
13c YOUR TOTAL INCOME from Line 21, SIep 5, SP WKSHT " 13c 00
13d TAX FORGIVENESS ftom Line 6, Part III, PA Schedule SP. . . . 13d 00 # of Schedules G
14 TOTAL CREDIT for TAXES PAlO '0 OTHER STATES or COUNTRIES" , , , , , , ,14 00 # of Schedules W
15 EMPLOYMENT INCENTIVE PAYMENTS CREOIT. , " , , , , , , , ' 15 00
16 TOTAL CREDITS and PAYMENTS, Add Lines 11, 12d, 13d. 14 and 15. 16 00
17 TAX DUE (If Line 10 Is more than Line 16, refer to page 21 & complete PA Payment Voucher on a e 38.) 17
18 OVERPAYMENT (Line 16 is more than Line 10), , , , , . , , , 18 00
19a AMOUNT of LINE 18'0 be REFUNOEO ' " , , , , , , , , , , , , 19a
19b AMOUNT of LINE 18'0 be CREOITEO 10 you, 1996 ESTIMATED TAX ACCOUNT.,. , , 19
19c AMOUNT of LINE 18'0 be DONATEO to WILO RESOURCE CONSERVATION FUND, , 19c
19d AMOUNT of LINE 18'0 be DONATEO to U,S, OLYMPIC COMMITTEE. FA DIVISION, 19d
The TOTAL 01 Line. 19. throu9h 19d MUST Equll Line IS.
~~~e';.?~~ A ~~r t:e1P.~I'~.rrl~j~U~~r~ur1~ol~W~I~~lIlng Jointly) docllfethAtl (we) h.veeXlmlned this return. Including IU AccompAnying SChedules Ind stltements, Ind to
Your Signature Dale Your OccupaHon
X INOR
SCHOOL OISTRICT CODE
I 21160 I
CHECK IF YOU WILL NOT NEEO A 1996
PA TAX BOOKLET
Apt. No.
Rural Route or P. Q. Box No.
Zip Code
17055
X
INDICATE HOW MANY
OF EACH FORM OR
SCH, IS ATTACHED
00 /I of Forms W-2
00 # of Schedules UE
00 /I of Schedules A
00 # of Schedules B
00 /I 01 Schedules C
00
00
10
20.
450.
167.
637.
18.
# 0' Schedule, RK-1
00 # of Schedules F
00 # 01 Schedule, C-F
00 # of Schedules 0 -r-
00 # 01 Schedules 0-71
00 I /I 0'SChedUresPA.19=
00 # of Schedules E
# of Schedules J
lnnin on a
00
00
00
12d
e 25.
Schedule SP.. D
(Check only if claiming
lax forgiveness)
# 01 Schedules 0.1
00
18.
00
00
00
00
00
Spouse's Signature
X
Data
Spouse's Occupation
BE SURE YOU (AND YOUR SPOUSE) SIGN. CHECK ALL MATH.
ATTACH ALL SCHEOULES AND FORMS
Oaylimo Telephone Number
717-975-3343
Propare,!! Tolephone Number
717-975-1850
NTF 9969A CopyrIght Forms Soflwaf. Only, 1995 Nelco, Inc. N95PA I
Pre parer's Name:
THOMAS G KANGANIS CPA
p
PA-40R AIB (09-95)
PA OEPARTMENT OF REVENUE PA TAXABLE INTEREST and DIVIDENDS 1995
Name as shown on PA-40R Social Security Number:
KANGANIS THOMAS G 199-66-0857
PA SCHEDULE A -- TAXABLE INTEREST PA SCHEDULE B -- TAXABLE DIVIDENDS
II your Pennsylvania taxable Interest income is over Sl,OOO.
complete this schedule. See the instructions in your 1995 PA-40R
booklet for what must be reponed as taxable Interest income. If
additional space is needed. attach separale sheels.
Nllme o' the Payer Amount
II your Pennsylvania taxable dividend income is over $1,000,
complele this schedule. See the instructions in your 1995 PA-40R
booklellor what must be reported as taxable dividend income. If
additional space is needed. attach soparate sheets.
Name a. the Pa .f Amount
Totallnter.'1 Income
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00 Total Dividend Income
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
PA SCHEDULE D
SALE OR EXCHANGE OF PROPERTY 1995
PA-40R 0 (09-95)
PA DEPARTMENT OF REVENUE
Name as shown on P A -40R
KANGANIS THOMAS G
Social Security Number:
199-66-0857
Enter all sales. exchanges or other dispositions of real or personal u:nglble and Intangible property.
Amounts from Federal Schedule 0 may not be correct for Pennsylvania Personal Income Tax purposes.
Read alllnstruc1Jons in the PA.40R booklet.
SPOUSES SHOULD FILE SEPARATE PA SCHEDULES D UNLESS SELLING JOINTLY OWNEO PROPERTY
(I) (b) (c) (d) (oj
Describe the property sold Month/DayNr. Month/DayNr. Gross Sales Price Cost or Adjusted
(Example: 100 shares of -ABC. the property the property for the property Basis of the
cO":lmon stock or house at was sold was purchased less expenses 01 property sold
123 Main St.. Anywhere. PA 99999) or acquired sale
l.ADAMS EXPRESS 06/22/9508/05/94 2 535.
ADAMS EXPRESS 10/03/9508/05/94 2 101.
2 50L
1 968.
2. Net Gain or Loss from above sales
3. Gain from PA Schedule(s) 0-1. Installment Sales
4. TalCable Return of Ca ital Distributions. Enter total distribution $
Minus Ad'ustod Basis $1
5. Net Gain or Loss from PA Schedule 0-71. Sale of 6-1-71 Pro e
6. Net Gain from PA Schedule PA-19. Sale of a Personal Residence, If a (Loss) enler (0),
7. Net Gain or Loss from PA Schedulo RK-1
8. Total Net Gain or Loss. Add Lines 2 throu h 7. Enter the result here and on Une 5 of our PA-40R.
You ma offset on our own ains and losses. ENTER NET LOSSES IN BRACKETS
PAABD12 NTF997JA
Copyright Forms Soflwa,. Only. 1995 Nelco, Inc. N95PMD1
2,
3,
00
00 J = 4,
5,
6,
7,
8,
(I)
GAIN ~r [LO(S~J
(d) minus e)
ENTER [LOSSES]
IN [BRACKETS]
34. 00
133. 00
00
00
00
00
00
00
00
00
167. 00
00
00
00
00
00
167. 00
FbR PENNSYLVANIA RESIDENTS ONLY
PA-40R INCOME TAX RETURN
"'YOU MUST FILE BY MIONIGHT MONDAY, APRIL 15. ,996'"
o Fiscal Vear Filer Beginning . 1995 End.
Commonwealth of Penns Ivania PA De ar1me
OFFICIAL USE ONLY
204-70-1689
PE FILER (Check On~ Onel
sILl MD JD
SINGLE MARRIEO JOINT
r. .,.... i""~~. FllIooSeOltlllll1Y
(. .-~jl .,\""', ", ~ '( Check Here Only If a Part-Year Resident
,~~ ~ If' "om .199' to ,199' 0
Ispouse's SSN - - even if lilinq separatelj NAME OF THE SCHOOL OISTRICT
wl"l.,rllYou lI~ed Oecember J 1.1995
CUMBERLAND VALLEY
Spouse's
FD
FINAL
MAKE CORRECTIONS BELOW
Your Social Securi Number
Name (Last. First and Middle Initial)
KANGANIS DEAN G
Slreet Address (including Number)
5275 STRATHMORE DRIVE
City Stale
MECHANICS BURG PA
'a GROSS PENNSYLVANIA COMPENSATION, , ' , , , " , , , " la
lb UN REIMBURSED EMPLOYE BUSINESS EXPENSES, , , " lb
lc TAXABLE PA COMPENSATION. Subtract Line lb from Line 1a. .. .. . . . .. . .
2 TAXABLE INTEREST. Complete PA Schedule A il over $1.000......
3 TAXABLE DIVIDENDS. Complete PA Schedule B if over S1.000....
4 NET INCOME or [LOSS] from OPERATION 01 a BUSINESS. PROFESSION or FARM,
5 NET GAIN or [LOSS] Irom the SALE. EXCHANGE or OISPOSITION 01 PROPERTY '
Sa AMOUNT 01 GAIN EXCLUDEO on PA Schedule PA.l~ ' Sa
6 NET INCOME or [LOSSjlrom RENTS. ROYALTIES. PATENTS or COPYRIGHTS
7 ESTATE and TRUST INCOME, ,
8 GAMBLING and LOTTERY WINNINGS, , , ' ,
9 TOTAL PA TXBL INCOME. Add Lines 1c, 2. 3. 4. 5, 6. 7, & a. 00 Not Deduct Losses
10 PA TAX LIABILITY, Multi I Line 9 b 2,8% 100281, , , '
11 TOTAL PA TAX WITHHELD, ' , , , , , , , , ' . , ,
1995 ESTIMATED PAYMENTS AND CREDITS. Read the in.truction. on pa e 20.
12a CREOIT from 1994 PA TAX RETURN 12a
12b 1995 ESTIMATED INSTALLMENT PAYMENTS"""" 12b
12c PAYMENT with 1995 EXTENSION REQUEST, ' , , , , , ' , " 12c
12d TOTAL ESTIMATED CREDIT, Add Line, '2a, 12b and 12c , , , '" " ,
TAX FORGIVENESS from PA SCHEDULE SP. Read the Instructions be innln on
13a HOUSEHOLD MEMBERS from Line 4. Part II, PA Sch. SP.. 13a 1
13b ELIGIBILITY INCOME Irom Line ,. Part III, PA Sch, SP , , " 13b 166 . 00
13c YOUR TOTAL INCOME from Line 21. Step 5. SP WKSHT " 13c 00
13d TAX FORGIVENESS Irom Line 6. Part III, PA Schedule SP.. ,.... .......... 13d 5. 00 # of Schedules G
14 TOTAL CREOIT for TAXES PAlO to OTHER STATES or COUNTRIES, ' " " , '" " , 14 00 # 01 Schedule, W
15 EMPI_OYMENT INCENTIVE PAYMENTS cREOIT. " , , " , , " '" , " ' , 15 00
16 TOTAL CREOITS and PAYMENTS, Add Line. 11, 12d, 13d, 14 and 15 , 16 00
17 TAX DUE (if LIne 10 Is more than Line 16. refer to page 21 & complete PA Payment Voucher on 17
18 OVERPAYMENT (Line 16 is more than Line 10). . .. , . . . . . , . .. ... . . . . . .. . ... . .. 18 00
19a AMOUNT 01 LINE 18to be REFUNOEO . , ., , , , , " , , " " "" " , , , , ' " ' '" " " "'" " ' ". '"'' , , " 19a
19b AMOUNT of LINE '8 to be CREOITED to your '996 ESTIMATEO TAX ACCOUNT" , , ,,"', , , '" ,"'" , ,., 19b
19c AMOUNT 01 LINE 18to be OONATED to WILO RESOURCE CONSERVATION FUNO, '" " ' , '" , ,9c
19d AMOUNT of LINE 18 to be DONATEO tu U,S, OLYMPIC COMMITTEE. PA DIVISION, ,"" , , ' , " , "'" , '" 19d
The TOTAL 01 Line' 19a through 19d MUST Equal Line 18.
~~~~~~~ R ~~r l;'eM,'r.Wlffru~llgJr?urllmbln\W~l~~lllng JOintly) deelarelhat I (we) haveeumlr.ed this feturn,lncludlng all accompanying schedules and stillerMnts, and to
Your Signature Oato Your Occupation
X INOR
Apt No.
Rural Roule or P. Q. Box No.
SCHOOL OISTRICT CODE
I 21160 I
CHECK IF YOU WILL NOT NEEO A 1996
PA TAX eOOKLET
Zip Code
17055
00
00
Ie
2
3
4
5
001
61
71
81
91
101
11
20.
146.
X
INDICATE HOW MANY
OF EACH FORM OR
SCH IS ATTACHEO
00 1# of Forms W-2
00 # 01 Schedules UE
00 # of Schedules A
00 # of Schedules B
00 # 01 Schedules C
# of Schedules RK-1
# 01 Schedules F
166.
5.
00
00
00
100
100
00
# 015checlulesC-F
# of Schedules 0
# of Schedules 0-71
# of Schedules PA-19
00
00
00
12d
a e 25,
# of Schedules E
# of Schedules J
# 01 Schedules 0-1
00
Schedule SP.. D
(Check only jf claiming
tax forgiveness)
5.
00
00
00
00
00
Spouse's Signaturo
X
Date
Spouse's Occupation
BE SURE YOU (AND YOUR SPOUSE) SIGN. CHECK ALL MATH.
ATTACH ALL SCHEDULES AND FORMS
Daytime Telephone Number
717-975-3343
Pre parer's Telephone Number
717-975-1850
NTF 9969A Copyfl;hl Forn.:; Software Only, 1995 Nelco,lnc. N95PA 1
Preparer's Namo:
THOMAS G KANGANIS CPA
---
W.2 EARNINGS jAllolCh W.2'5)
2 EMPL.OYEE BUSINESS EXPENSC:S (Anactl SlatQ $chedulo UE.j and R~'red Attachments)
TAXABLE W.2 EA<:tNINGS 15ublracl Llno 2 110m Lmo 1)
4. OTHER TAXABLE EAANED INCOME (No InlortlSI, OIVldonds or unemploY1cnl Bonefl13 Anach SuppQf1Jng Documol1tsl
TOTAL TAXABLE EARNED INCOME BEFORE NET PROFITS (Lossesl FROM SELF.EMPLOYMENT
(Add unos:land 4)
8 NET LOSS FROM SELF.EMPLOYED BUSINESS, PROFESSION. OR FARM
(Use lmo 6 for any NOI PrOmS) (Attach AppropnlJle IRS SchOOulo,) I
" SUBTOTAL (Sublracl una 6 Irom Line 5l ~F LESS THAtl ZERO, ENTER ZERO
8. NET PROFIT FROM SElF.EMPLOYED BUSINESS. PROFESSION. OR FARM
(Use Uno 8 for any Net Lossos) (Alt8ctI Appropn1ltll IRS Schooules) l
9 TOTAL TAXABLE EARNED INCOME AND NET PROFITS (Add L.no 7 ,1M 81
10 TAX LIABILITY 1"'. OF LINE 9 (MultIply Line 9 by ,01)
I I CREDITS A. ENTER TOTAL 10. TAX WITHHELD BY EMPLOYER
B ENTER QUARTERLY ~AYMENTS MADE TO THIS BUREAU
'_::iI~II:n.I'Ir."RI_I'" .":I~'II""'IIIr.r..IJ''''I'II:i'IIIr.r'.lul'
'0:'; J.' ;;7
2
;5i'(
b t;f) Ii'
6
~ ifl....' f
I,:
L,'" ('
'6+0
-'
....
I"
12, IF LINE 11C IS LARGEA THAN LINE 10 ENTEA REFUND DUE HEAE
(II LOS5lhan $1,00, Enter Zero)
13 IF LINE 10 IS LARGER THAN LINE!:C PAY :.mp,\ID EMLAtjCE BY APRIL 15
fIf Less than $1 00 Enter Zerol
,"
"
;..-.
14 ADD INTEAEST AND PENALTY OF ,.. PER MONTH OF LINE 13 AFTER APRIL 15
,15 PAY BALANCE DUE WITH THIS RETURN (Line 13 plU's Line 141
OLD MAILING ADDFlESS w'ST ~,10VI~~G INFORM,Hlml l"OR l<)<)'i ~,\:~ 'EAR BELC'," TWD BeAO
/:'C'v;'.,,'" 0'/'" ....:.;'-d~....1 ~,7,:"':.', ,1'-1. -~' ~.,I_
H
'5: _... _ r
PE"tOO,..,',';;[) '1Ef<E _ __
/ ;0 '- '/ .....,:1 -.
';WP aORO
-',J~, " , ,_ I,
'._/,1~l ~ .,..---....
/~
PQESi:JjT
:' :O-5~-5538
WESTAB FORM 531 (REV. l1f95)
10:, AMOUNT
*......... CAR-,T SORT .. CCc9
FIN N
GEORGE T
15 HONE SUCKLE DR
MECHANICSBURG PA
K~NG,NIS
2-1,:'J-1C'2
,
OURAECOROSINOtCA1l:TrtUYQUAIIE.AESlOE!lTOF;
17)55
:74
,ILV€R SPRNG T~P
(J
EXHIBIT 5
EXPENSES
HOME
Monthly
Mortgage
1,311.00
Maintenance
Vacuum Finance
Terminex
Utilities
Electric
Telephone
Water & Sewer
29.95
32.00
140.00
200.00
45.00
PERSONAL
Car Payment
Credit Cards
Boscov's
Montgomery Wards
DD
Mellon
Bon Ton
Sears
282.00
223.00
25.00
33.00
50.00
50.00
40.00
2500
223.00
MISCELLANEOUS
Boys' Clothes
Boys' Lunch Money
Boys' Instrument Rental
Groceries
Cable
Insurance (Umbrella policy for car, home, and life)
*Health Ins., Dental, Vision & Prescription
paid for out of George's wages for all four.
100.00
52.00
18.00
300.00
22.00
200.00
EXHIBIT 6
401(k)
Retirement Benefits
Marital Portion
George Kanganis
$ 5,284.26
ROLL GROUP 401CKl
PROFIT SHARING PLAN
SM 41356
GEORGE KANGANIS
5275 STRATHMORE DRIVE
MECHANICS BURG. PA 17055-3166
STATEMENT PERIOD
JAN 01. 1995 THRU JUL 31. 1995
SSN I 089-50-5538
ACTIVITY THIS PERIOD
EHPLOYEE
DEFERRAL
EPfPLCYER
HATCH
TOTAL
ACCOUNT
PRIOR ACCOUNT BALANCE
SO.OD
$0.00
$0.00
CONTRIBUTION
DIVIDEND
TRANSFER our
INVESTMENT GAIN/LOSS
807.72
40.40
2,646.83
27.94
403.86
20.20
1,323.40
13.91
*1,211.58
$60.60
$3,970.23
41.85
TOTAL ACCOUNT BALANCE
$3,522.89
$1,761.37
$5,284.26
SUMMARY OF CONTRIBUTIONS
EHPLOYEE
DEFERRAL
EHPLOYER
HATCH
TOTAL
ACCDUfT
PLAN QUARTER-TO-DATE
PLAN VEAR-TD-DATE
PLAN LIFE-TD-DATE
$807.72
$807.72
$807.12
$403.86
$403.86
$403.86
$1,211.58
$1 ,211.58
$1,211.58
SUMNUlRY OF MARKET VALUE
VALUE ON 07/31/95
FLtltl
SHARES
HARXET VALUE
RfT. GOV"r l'IJNEy tl<.T
tuNlGED INCDtIE PORT.
PURITAN
2359.410
2363.610
33.627
$1. 00
$1. 00
$16.69
$2,359.41
$2,363.61
$561.24
TOTAL MARKET VALUE OF ACCOUNT
$5,284.26
EMPLOYEE DEFERRAL
RET. GOV'T HONEY HKT HAHAGED nl:ctlE PORT. PUlUTAN
SHARES AHDlM" SHARES - SHARES AIlOUNT
PRICE PER SHARE $1. DO $1.00 $14.81
BEGltftItG BALANCE O.OOD SO.OD 0.000 $0.00 O.oOD $0.00
CllNTRIBUnON 363.480 363.48 363.480 363.48 4.963 80.76
DIVIDEND 18.760 18.76 19.830 19.83 0.113 1.81
TRANSFER OUT 1,190.720 1,190.72 1,192.410 1.192.41 17 . 345 263.70
INVESTMENT GAIN/LOSS 0.00 0.00 27.94
ENDltc BALANCE 1,572.960 $1 ,572.96 1,575.720 $1.575.72 22.421 $374.21
PRICE PER SHARE $1.00 $1.00 $16.69
RGLL GROUP 4DICKl
PROFIT SHARING PLAN
PAGE 3
SM 41356
GEORGE KANGANIS
5275 STRATHMORE DRIVE
MECHANICSBURG. PA 17055-3166
STATEMENT PERIOD
JAN 01. 1995 THRU JUL 31. 1995
SSN, 089-50-5538
TRANSACTION HISTORY
SOURCE I FUND DATE TRANSACTION TYPE AIO..tlT PRICE SHARES
EMPLOYEE DEFERRAL
05/01/95 TRANSFER IN $1,190.72 $1,00 1190.720
05/31/95 DIVIDEND $5.&2 $1. 00 5.620
06/13/95 CONTRIBUTION $60.58 $1. 00 60.580
06/16/95 CONTRIBUTION $60.58 $1. 00 60.580
06/16/95 CONTRIBUTION $60.58 $1.00 60.580
06/28195 CONTRIBUTION $60.58 $1,00 60.580
06/30/95 DIVIDEND $6.03 $1.00 6.030
07/12/95 CONTRIBUTION $60.58 $1.00 60.580
07/25/95 CONTRIBUTION $60.58 $1. DO 60.580
07/31/95 DIVIDEND $7.11 $1.00 7.110
TOTAL ENDIN:; BALA.HCE 1572.960
HANAGED Itl:ot1E PORT. BEGINNING BALANCE 0.000
05/01/95 TRANSFER IN $1,192.41 Sl.0o 1192.410
05/31/95 DIVIDEND $5.89 $1. 00 5.890
06/13/95 CONTRIBUTION $60.58 $1. 00 60.580
06/16/95 CONTRIBUTION $60.58 $1.00 60.580
06/16/95 CONTRIBUTION S60.58 $1.00 60.580
06/28/95 CONTRIBUTION $60.58 $1.00 60.580
06/30/95 DIVIDEND $6.38 $1.00 6.380
07/12/95 CONTRIBUTION $60.58 $1. 00 60.580
07/25/95 CONTRIBUTION $60.58 $1. 00 60.580
07/31/95 DIVIDEND $7.56 $1. 00 7.560
TOTAL ENDIt<<i BALANCE 1575.720
PURITAN BEGINNING BAL6~E a.OGO
05/01/95 TRANSFER IN $263.70 $15.74 17.345
06/13/95 CONTRIBUTION S13.46 $Ii). 06 0.83B
06/16/95 CONTRIBUTION $13.46 S16.07 0.B3B
06/16/95 CONTRIBUTION $13.46 $16.07 0.838
06/16/95 DIVIDEND $1.81 $16.07 0.113
06/28/95 CONTRIBUTION $13.46 $16.16 0.833
07/12/95 CONTRIBUTION $13.46 $16.68 0.807
07/25/95 CONTRIBUTION $13.46 $16.64 0.809
TOTAL ENDING BALANCE 22.421
INVESTHENT HIX PERCENTAGES
AS OF 09/06/96
20 r. RET. COY'T HONEY HKT 20 % MANAGED INCOHE PORT. 30 %' PURITAN
30 % HAGEL LAN
EMPLOYER MATCH
RET. GrN'T HONEY f'!(.T BEGINNING BALANCE 0.000
05/01/95 TRANSFER IN $595.34 Sl.oo 595.340
05/31/95 DIVIDEND S2.81 $1.00 2.810
06/13/95 CONTRIBUTION $30.29 $1. 00 30.290
06/16/95 CONTRIBUTION $30.29 $1.00 30.290
06/16/95 CONTRIBUTION S30.29 S1.00 30.290
ROLL GROUP 401(K)
PROFIT SHARING PLAN
PAGE 4
SM 41356
GEORGE KANOANIS
5Z75 STRATHMORE DRIVE
MECHANICSBURG, PA 17055-3166
STATEMENT PERIOD
JAN 01. 1995 THRU JUL 31, 1995
SSN. 089-50-5538
TRANSACTION HISTORY
SOURCE / FIMD DATE TRANSACTION TYPE AI1lJlJIlT PRICE SHARES
EMPLOYER MATCH
RET. GDV'T HONEY HKT 06/28/95 CONTRIBUTION $30.29 $1.00 30.290
06/30/95 DIVIDEND $3.01 $1.00 3.010
07/12/95 CONTRIBUTION $30.29 $1.00 30.290
07/25/95 CONTRIBUTION $30.29 $loDD 30.290
07/31/95 DIVIDEND $3.55 $1.00 3.550
TOTAL ENDlOO BALANCE 786.450
IUNAGED INCDt1E PORT. BEGINNING BALANCE 0.000
05/01/95 TRANSFER IN $596.23 $1.00 596.230
05/31/95 DIVIDEND $2.94- $1.00 2.940
06/13/95 CONTRIBUTION $30.Z9 $1.00 30.290
06/16/95 CONTRIBUTION $30.29 $1.00 30.290
06/16/95 CONTRIBUTION $30.29 $1.00 30.290
06/26/95 CONTRIBUTION $30.29 $1.00 30.290
06/30/95 OIVIDEND $3.20 $1.00 3.200
07/12/95 CONTRIBUTION $30.29 $1.00 30.290
07/25/95 CONTRIBUTION $30.29 $1.00 30.290
07/31/95 DIVIDEND $3.78 $1.00 3.780
TOTAL ENDIt-G BALANCE 787.890
PURITAN BEGINNING BALANCE 0.000
05/01/95 TRANSFER IN $131.83 $15. 74 8.669
06/13/95 CONTRIBUTION $6.73 $16.06 0.419
06/16/95 CONTRIBUTION $6.73 $16.07 0.419
06/16/95 CONTRIBUTION $6.73 $16.07 0.419
06/16/95 DIVIDEND $0.3'1 ~l';.07 0.057
06/28/95 CONTRIBUTION $6073 $16.16 0.416
07/12/95 CONTRIBUTION $6.73 $16.68 0.403
07/25/95 CONTRIBUTION $6.73 $16.64 0.404
TOTAL ENDING BALANCE 11 . 206
INVESTMENT MIX PERCENTAGES
AS OF 09/06/96
2D r. RETo GOY'T HONEY HKT 2D % HANAGED INCOHE PORT. 3D % PURITAN
3D % MAGELLAN
EXHIBIT 7
Counsel Fees
NOT REQUESTED BY DEFENDANT
EXHIBIT 8
GEORGE & ROSEMARIE KANGANIS - HOUSEHOLD AND PERSONAL
Location/Item Purchase Date furchase Price Current Vallie
Basement.
Office desk 1981 $ 300.00
File cabinet - 2 draw 1981 50.00
Kitchen table w/4 chairs 1983 300.00
Water purifier & softener 1987 1,800.00
Stereo w/2 amplifiers 1984 700.00
Treadmill 1992 500.00
First floor'
Washer 6/29/95 439.00
Dryer 6/29/95 379.00
Kenmore vacuum cleaner 3/18/96 329.00
Garage'
Krallsman 5.5HP lawnmower 6/95 250.00
McCullough leaf blower 6/95 85.00
Toro 3HP snow blower 10/95 550.00
Grass feeder 6/95 20.00
Krallsman 16" weed wacker 6/95 80.00
18" Black & Decker shrub
trimmer 1990 30.00
Kitchen'
Whirlpool electric range/oven 6/29/95 669.00
Amana 20.2 cubic ft. refrig. 9115/86 921.00
Spacesaver RCA TV 6/29/95 275.00
Miscellaneous plates, glasses,
utensils, pots & pans 6/29/95 500.00
Venetian blinds 9/95 400.00
Kitchen table w/6 chairs 8/95 1,000.00
Screened Porch'
Glass top table w/4 chairs 1990 400.00
13" ReA color TV 1983 250.00
,
. . .
GEORGE & ROSEMARIE KANGANIS - HOUSEHOLD AND PERSONAL
Front entrAnce WHY'
Grecian throw-rug 1986 200.00
Dining room'
Dining table w/6 chairs
and leaf extension &
hutch 1/14/87 1,891.00
Crystal & china-Noritake
Ivory. 3 lenox serving
trays, 12 place silver
service set. 1987 4,000.00
Portable brass glass bar 1979 150.00
I.iving room'
Husband/wife lIadro 1983 gift
Cherub lIadrc 1981 gift
Woman holding lamb lIadro 1990 gift
Womanlbasket & lamb lIadro gift
3 lennox candy dishes gift
Lennox flower vase gift
Plant stand - wicker 1979 100.00
Couch, love seat, 2 chairs,
glass top coffee table. lamp
table, lamp, 2 book shelves 1979 6,000.00
Family room'
Standing glass lamp 1979 N/A
CD tape deck w/2 speakers
(Pioneers) 1990 500.00
25" Sony color TV 1992 800.00
TV stand 1992 300.00
Panasonic VCR 1984 200.00
L-shaped 4 piece sectional
couch w/fold out bed 9/25/86 1,431.00
Fireplace accessories 8/95 75.00
"
.~ -.....
. '
GEORGE & ROSEMARIE KANGANIS - HOUSEHOLD AND PERSONAL
Quest bedroom'
Queen size bed
Lamp table & lamp
Rocking chair
Panasonic boom box
Study/office'
IBM PS-I computer, laser
jet Hewlett-Packard printer,
computer work station
Electrolux vacuum cleaner
Boys' bedroom'
Kenmore 2-speed upright
vacuum cleaner
2 boys' beds
Dresser
Dresser/changing table
Master bedroom'
Bureau, dresser w/mirror,
2 night stands, 2 lamps, King
size bed
Phone answering machine
20" RCA color TV
VCR RCA
Total
9/24/86
1979
1986
1979
365.00
150.00
45,00
100.00
1996
5/24/96
gift Grandfather to Grandson
636.00
N/A
1988/1991
1980
1986
gift
500.00
200.00
200.00
1979
1993
6/29/95
1994
5,000.00
180.00
264.00
gift
$ 33,514.00
-----
---
.
.. ,
.
EXHIBIT 9
.
Marital Debt as of .July I. 1995
1. Eastern Mortgage SelVices, Inc. $133,600.00
2. VISA - Dauphin Deposit 1,214.38
3. MCNISA - Mellon Bank 2,458.85
4. Boscov's 593.08
5. Hechinger's 211.48
6. John Wanamaker's 290.46
7. Montgomery Ward 1,085.98
.-
ROSEMARIE KANGANIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUN1Y, PENNSYLVANIA
v.
NO. 96-4601 CIVIL
GEORGE KANGANIS,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
NOTICE OF ENTRY OF APPEARANCE
TO THE PROTHONOTARY
Please enter my appearance for the Defendant in the above-captioned matter for the
purposes of the Master's determinations. Thank you.
BY:
BY:
.1 deL (}jiL
William C. KoUas, Esquire
Attorney I.D. No. 06341
KOLLAS AND KENNEDY
1104 Fernwood Avenue
Camp Hill, PA 17011
Phone: (717) 73 1-1600
ATTORNEYS FOR DEFENDANT
DATE: November 26, 1996
5.
The action does not involve complex issues of law or fact.
6.
The hearing is expected to take I day.
7.
Additional information, if any, relevant to the motion:
Date:
lo/~4b
I
AND NOW, h,\{; \i ('\ , 1996,
Master with respect to the following claims:
/(F'
( J
! , Esquire, is appointed
J,,~
, (
l '>'~ .
.....\...
c""~ CLt_J (C<-- t\- i f'" ,)
,
BY THE COURT:
U/l, L) J~-' ~/' ,-.-----
!(:}L" 7 .. . /" /~-- -..
, .- f?
. 1.
\.:~"'~':';i-' \(::<~ ~7~ 1,,,,_ 1"":
I"~
. 1 . 1\ t T' ~
t.ioI.\ .01
~ ," ~':':
lJ- lIUI, -,'-'
. ,.. ,__. " c')
)J....~\..I.\'~" L.I..I_..:._~,. l. -
381:l:10-(:I i:~
George and Rosemarie
Kanganis
5275 Strathmore Drive
Mechanicsburg, P A
6/95 to present
4. The mother of the children is respondent, currently residing at 5275 Strathmore
Drive, Mechanicsburg, P A.
She is married, but has filed for divorce.
5. The father of the children is petitioner, currently residing at 5275 Strathmore
Drive, Me~hanicsburg, P A.
He is married.
6. Petitioner has not participated as a party or witness, or in another capacity, in
other litigation concerning the custody of the child in this or another court.
Petitioner has no information of a custody proceeding concerning the children
pending in a court of this Commonwealth.
Petitioner does not know of a person not a party to the proceedings who has
physical custody of the children or claims to have custody or visitation rights with respect to the
children.
7. The best interests and permanent welfare of the children will be served by granting
the relief requested because:
a. Petitioner has been and continues to be the primary caregiver to his
sons; and
b. petitioner is the parent best able to provide a stable, loving, and
nurturing environment for the children; and
c. petitioner is the parent most likely to facilitate visitation between the
non-custodial parent and the children; and
d. petitioner is the parent most likely to facilitate the continuing
relationships between the children and both their extended families.
VERIFICATION
I, GEORGE T. KANGANIS, verify that the statements made in the foregoing
COMPLAINT FOR CUSTODY are true and correct to the best of my knowledge, information
and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.
C.S.A. !l4904, relating to unsworn falsification to authorities.
'. .
BY:
DATE: ~ ~2/ lq0 (p
tj)
ROSEMARIE KAGAN IS ,
FORMERLY ROSEMARIE KANGANIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
NO. 96-4601
vs.
GEORGE KANGANIS,
Defendant
CIVIL ACTION - LAW
CUSTODY
ORDER OF COURT
Hess, J. ------
AND NOW, this / qth day of June, 2001, upon consideration of the attached
Custody Conciliation Summary Report, it is hereby ordered and directed as follows:
1. Legal Custody. The parties, Rosemarie Kaganis and George Kanganis, shall have
shared legal custody of the minor Children, George Kanganis, born November 15, 1986, and
Dean George Kanganis, born October 27,1989. Each parent shall have an equal right, to be
exercised jointly with the other parent, to make all major non-emergency decisions affecting
the Children's general well-being including, but not limited to, all decisions regarding their
health, education and religion. Pursuant to the terms of Pa. C. S. S 5309, each parent shall be
entitled to all records and information pertaining to the Children including, but not limited to,
medical, dental, religious or school records, the residence address of the Children and of the
other parent. To the extent one parent has possession of any such records or information,
that parent shall be required to share the same, or copies thereof, with the other parent within
such reasonable time as to make the records and information of reasonable use to the other
parent.
2. Physical Custody. The parties shall have shared physical custody on a two-week
alternating basis arranged as follows:
A. Week One: From Tuesday at 3:00 p.m. until Friday at 3:00 p.m. the
Children shall be with Father, and from Friday at 3:00 p.m. until Sunday at
5:00 p.m. the Children shall be with Mother; from Sunday at 5:00 p.m until
Tuesday at 3:00 p.rn the children shall be with Father.
B. Week Two: From Tuesday at 3:00 p.m. until Friday at 3:00 p.m. the
Children shall be with Mother, and from Friday at 3:00 p.m. until Sunday
at 5:00 p.m. the Children shall be with Father. From Sunday at 5:00 p.m.
until Tuesday at 3:00 p.m. the Children shall be with Mother.
/
No. 96-4601
3. Christmas. Each year, the holiday time between Christmas and New Year's shall
be shared as follows:
A. Father shall have custody from December 24" at 9:00 a.m. until
December 25'h at 3:00 p.m. and December 30lh at 9:00 a.m. until the
morning the Children return to school following the holiday break.
B. Mother shall have custody from December 25'h at 3:00 p.m. until
December 30'h at 9:00 a.m.
4. The Children's Birthdays. Each parent shall have access to the Children on their
birthdays. In the event that the birthday falls on a school day, the parent not in custody shall
have three hours of partial custody for that Child's birthday. In the event that the Child's
birthday falls on a weekend day, the non-custodial parent shall have six hours of custody for
that Child's birthday.
5. Vacation. Each parent shall have up to twenty-one vacation days to be used for the
purpose of vacation each summer. However, not more than fourteen of these days shall be
used consecutively. The parties shall provide at least thirty days written notice to the other
parent of their vacation plans including the location of the vacation and a telephone number
where they can be reached. In the event that the parties have conflicting vacation plans, the
party first to provide written notice of their vacation plans shall have choice of the vacation
time. The vacationing parent may provide a telephone card or a temporary cellular phone to
the Children and encourage the Children to call the non-custodial parent during the vacation
time. The initial telephone call shall occur within forty-eight hours of arrival of the vacation
destination.
6. Neither party shall do or say anything which may estrange the Children from the
other parent, injure the opinion of the Children as to the other parent, or hamper the free and
natural development of the Children's love and respect for the other parent. Each parent shall
ensure that third parties also comply with this provision during his or her periods of custody.
7. The Children shall be allowed reasonable telephone contact with the non-custodial
parent. Due to the frequency of the custodial exchanges and the regularity of the contact
between the Children and both parents, calls from the non-custodial parent to the Children
should be the exception, rather than the rule. However, appropriate exceptions shall be made
for emergencies or issues that cannot wait to be addressed until the next custodial period for
the non-custodial parent. Moreover, the Children may initiate calls to the non-custodial parent.
~ Counsel for the parties shall submit to the Court a brief memorandum outlining each
party's position on the sharing and/or alternating of holiday time for Thanksgiving and Easter
each year. These memoranda are due within thirty days of the date of this Order.
.
No. 96-4601
~
.J~
~~{)~
LY],!
Kevin A. Hess
Dis!:
Kathleen C. Daley, Esquire, 1029 Scenery Drive, Harrisburg, PA 17109
Keirsten W. Davidson, Esquire, 301 Market Street. Lemayne, PA 17043
TRUE COrY OM RECORD
. "\ f I here unto set my hand
In leitlmany lerea .
and the seal of id aurt at Carlisle, Pa,
d of ........
lh's a......................,
I ..................
...............................
.....................................--
Prothonotary
ROSEMARIE KAGAN IS,
FORMERLY ROSEMARIE KANGANIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 96-4601
GEORGE KANGANIS,
CIVIL ACTION - LAW
CUSTODY
Defendant
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the subject of this
litigation is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
George Kanganis
Dean George Kanganis
November 15, 1986
October 27, 1989
Mother and Father
Mother and Father
2. A Custody Conciliation Conference was held on June 4, 2001, with the following
individuals in attendance: the Mother, Rosemarie Kaganis, and her counsel, Kathleen C.
Daley, Esquire; the Father, George Kanganis, and his counsel, Keirsten W. Davidson,
Esquire.
3. The last Order entered in this matter was May 28, 1997, at which time the Order
was entered pursuant to an a9reement of the parties as part of the Comprehensive Marital
Settlement Agreement. Father filed a petition on April 24, 2001, seeking modification of the
existing Custody Order. The parties were seen for the Conference and reached an agreement
on everything except the holiday schedule for Thanksgiving and Easter.
4. Mother's position on these holidays is that they should be alternated. Mother would
like to alternate these holidays because much of her family is located in New York. Therefore,
the travel time between Pennsylvania and her family in New York makes it logistically difficult
for the holiday time to be split between two families.
5. Father's position on the holidays is to divide the time on each holiday. For example,
Father proposes on Thanksgiving that the parties alternate periods of custody with one party
having custody from 9:00 a.m. until 3:00 p.m. on Thanksgiving Day and the other party having
custody from 3:00 p.m. until 9:00 p.m. on Thanksgiving Day.
6. FATHER requested the conciliation in order to address holiday and vacation periods, and
more specifically to request that those time periods be ciearly defined, and that advanced notice regarding
the specifics of any vacations with the children be given to the non-custodial parent.
7. After the above-referenced custody conciliation, an Order dated June 19, 2001 was
generated, and includes the foilowing Paragraph: "No.5. Vacation. Each parent shail have up to twenty-
one (21) vacation days to be used for the purpose of vacation each summer. However, not more than
fourteen (14) of these days shail be used consecutively. The parties shail provide at least thirty 130\ days
written notice to the other carent of their vacation clans including the location of the vacation and a
telephone number where they can be reached In the event that the parties have conflicting vacation plans,
the party first to provide written notice of their vacation plans shail have choice of the vacation time. The
vacationing parent may provide a telephone card or a temporary ceilular phone to the children and
encourage the children to cail the non-custodial parent during the vacation time. The initial telephone cail
shail occur within forty-eight (48) hours of arrival of the vacation destination." A copy of this Order is
attached hereto and marked as Exhibit "A".
8. The parties agreed to the above language at the conciliation.
9. Despite the above, MOTHER took the children on vacation on or about Wednesday, July 25,
2001, without advising FATHER of any specifics regarding the trip.
10. FATHER attempted personaily and through counsel to obtain an itinerary from MOTHER prior
to her departure, however none was disclosed to him.
11. When FATHER attempted to speak with MOTHER regarding her travel plans, she closed the
garage door on him and cailed the police to remove him from her property.
12. At approximately 4:00 p.m. on Wednesday, July 25, 2001 , FATHER received a telephone cail
from one of the children who told FATHER that he was at JFK airport in New York and MOTHER was taking
him and his brother to Greece.
13. At approximately 10:30 a.m. on Thursday, July 26, 2001, (after MOTHER and the children
had already left) MOTHER'S counsel faxed a memo to FATHER'S counsel containing a sparse itinerary
authored by MOTHER. This memo is attached hereto and marked as Exhibit "B".
JUN 1 '1 2001 t;O
ROSEMARrE KAGAN IS,
FORMERLY ROSEMARIE KANGANIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 96-4601
Defendant
CIVIL ACTION - LAW
CUSTODY
GEORGE KANGANIS,
ORDER OF COURT
Hess, J. ------
AND NOW, this /9fh day of June, 2001, upon consideration of the attached
Custody Conciliation Summary Report, it is hereby ordered and directed as follows:
1. Le~JaI Custody. The parties, Rosemarie Kaganis and George Kanganis, shall have
shared legal custody of the minor Children, George Kanganis, born November 15,1986, and
Dean George Kanganis, born October 27,1989.. .Each parent shall have an equal right, to be
exercised jointly with the other parent, to make all major non-emergency decisions affecting
the Children's general well-being including, but not limited to, all decisions regarding their
health, education and religion. Pursuant to the terms of Pa. C. S. S 5309, each parent shall be
entitled to all records and information pertaining to the Children including, but not limited to,
medical, dental, religious or schooi records, the residence address of the Children and of the
other parent. To the extent one parent has' possession of any such records or information,
that parent shall be required to share the same, or copies thereof, with the other parent within
such reasonable time as to make the records and information of reasonable use to the other
parent.
2. Physical Custody. The parties shall. have shared physical custody on a two-week
alternating basis arranged as follows:
A. Week One: From Tuesday at 3:00 p.m. until Friday at 3:00 p.m. the
Children shall be with Father, and from Friday at 3:00 p.m. until Sunday at
5:00 p.m. the Children shall be with Mother; from Sunday at 5:00 p.m until
Tuesday at 3:00 p.m the children shall be with Father.
B. Week Two: From Tuesday at 3:00 p.m. until Friday at 3:00 p.m. the
Children shall be with Mother, and from Friday at 3:00 p.m. until Sunday
at 5:00 p.m. the Children shall be with Father. From Sunday at 5:00 p.m.
until Tuesday at 3:00 p.m. the Children shall be with Mother.
..
No. 96-4601
3. Christmas. Each year, the holiday time between Christmas and New Year's shall
be shared as follows:
A. Father shall have custody from December 24th at 9:00 a.m. until
December 25th at 3:00 p.m. and December 30th at 9:00 a.m. until the
morning the Children return to school following the holiday break.
B. Mother shall have custody from December 25th at 3:00 p.m. until
December 30th at 9:00 a.m.
4. The Children's Birthdays. Each parent shall have access to the Children on their
birthdays. In the event that the birthday falls on a school day, the parent not in custody shall
have three hours of partial custody for that Child's birthday. In the event that the Child's
birthday falls on a weekend day, the non-custodial parent shall have six hours of custody for
that Child's birthday.
5. Vacation. Each parent shall have up to twenty-one vacation days to be used for the
purpose of vacation each summer. However, not more than fourteen of these days shall be
used consecutively. The parties shall provide at least thirty days written notice to the other
parent of their vacation plans including tHe location of the vacation and a telephone number
where they can be reached. In the event that the parties have conflicting vacation plans, the
party first to provide written notice of their vacation plans shall have choice of the vacation
time. The vacationing parent may provide a telephone card or a temporary cellular phone to
the Children and encourage the Children to'call the non-custodial parent during the vacation
time. The initial telephone call shall occur within forty-eight hours of arrival of the vacation
destination.
6. Neither party shall do or say anything which may estrange the Children from the
other parent, injure the opinion of the Children as to the other parent, or hamper the free and
natural development of the Children's love and respect for the other parent. Each parent shall
ensure that third parties also comply with this provision during his or her periods of custody.
7. The Children shall be allowed reasonable telephone contact with the non-custodial
parent. Due to the frequency of the custodial exchanges and the regularity of the contact
between the Children and both parents, calls from the non-custodial parent to the Children
should be the exception, rather than the rule. However, appropriate exceptions shall be made
for emergencies or issues that cannot wait to be addressed until the next custodial period for
the non-custodial parent. Moreover, the Children may initiate calls to the non-custodial parent.
6. Counsel for the parties shall submit to the Court a brief memorandum outlining each
party's position on the sharing and/or alternating of holiday time for Thanksgiving and Easter
each year. These memoranda are due within thirty days of the date of this Order.
ROSEMARfE KAGANIS,
FORMERLY ROSEMARIE KANGANIS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 96-4601
GEORGE KANGANIS,
CIVIL ACTION - LAW
CUSTODY
Defendant
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the subject of this
litigation is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
George Kanganis
Dean George Kanganis
November 15, 1986
October 27, 1989
Mother and Father
Mother and Father
2. A Custody Conciliation Conference was held on June 4, 2001, with the following
individuals in attendance: the Mother, Rosemarie Kaganis, and her counsel, Kathleen C.
Daley, Esquire; the Father, George Kanganis, and his counsel, Keirsten W. Davidson,
Esquire.
3. The last Order entered in this matter was May 28, 1997, at which time the Order
was entered pursuant to an agreement of the parties as part of the Comprehensive Marital
Settlement Agreement. Father filed a petition on April 24, 2001, seeking modification of the
existing Custody Order. The parties were seen for the Conference and reached an agreement
on everything except the holiday schedule for Thanksgiving and Easter.
4. Mother's position on these holidays is that they should be alternated. Mother would
like to alternate these holidays because much of her family is located in New York. Therefore,
the travel time between Pennsylvania and her family in New York makes it logistically difficult
for the holiday time to be split between two families.
5. Father's position on the holidays is to divide the time on each holiday. For example,
Father proposes on Thanksgiving that the parties alternate periods of custody with one party
having custody from 9:00 a.m. until 3:00 p.m. on Thanksgiving Day and the other party having
custody from 3:00 p.m. until 9:00 p.m. on Thanksgiving Day.
. .
iUL-26-01 10:27 AM
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ROSEMARIE KAGANIS (FORMERLY,
ROSEMARIE KANGANIS),
Plaintiff/Respondent
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
v.
: NO. 96-4601 CIVIL
GEORGE KANGANIS,
Defendant/Petitioner : IN CUSTODY
ANSWER TO THE PETITION FOR CONTEMPT OF CUSTODY ORDER
1. Admitted.
2. Admitted.
3. Admitted.
4. Admitted.
5. Admitted.
6. The Respondent
cannot admit or deny the reason that Father requested the
conciliation, but does acknowledge that the issues concerning holiday and vacation periods were
addressed at the time of the conciliation.
7. Admitted.
8. Admitted.
9. Admitted, '.'Iith clarification. It is admitted that Mother took the children on a vacation
on or about Wednesday, July 25,2001. Mother had provided written notification to Father of when
she wanted to begin and end her vacation and Father failed to cooperate in that schedule, withholding
the children from Mother until Tuesday, July 24. Il was Mother's belief that Father did this with thc
intention of trying to ruin Mothcr's vacation plans and delay her departure. Since Mother's plans
involved a trip to Greece with a number of other family members, il was necessary for Mother to
have the children returned to her so that Father would not cngage in lltrther interfering conduct
regarding her periods of vacation.
10. Admitted, with clarification. It is admitted that botb Father and Father's counsel had
discussed the itinerary of Mother's vacation. However, this was incident to calls from Mother's
counsel to Father's counsel requesting that the children be retumed, pursuant to Mother's requested
vacation periods. Reprcsentations were made 10 Father's counsel that an itinerary of Mother's trip
would be furnished to her. The day following Mother's departure, said itinerary was fumished.
II. Admitted, with clarification. Father appeared at Mother's residence and was engaged
in obnoxious and outrageous conduct such that she fell she needed the assistance of the police.
Mother closed the garage door and summoned the police and Father, upon seeing the police, decided
to leave the premises.
12. Admitted. The children used their mother's calling card and placed a call to their
father from JFK Airport to infonn him that they were going to Greece with thcir cousins and other
relatives.
13. Admitted, with clarification. Il is admitted that this information was furnished to
Father. However, the definition of the itinerary as being "sparse" is denied.
-2-
14. Denied. It is denied Mother is in contempt of the Custody Order for the following
reasons:
I.) Motherdid not fail to provide thirty (30) days notice to Father ofthe vacation
plans. Notice was given well in excess of thirty (30) days, and attempts at clarifying the
vacation period were met with Father's usual obstreperous and obnoxious conduct.
2.) Denied. By Father's own admission, he was advised of the location of the
vacation. It was believed that Father would take actions to interfere with the vacation plans
and the current Petition eonfinn those beliefs.
3. ) Denied. It is denied that Mother failed to provide Father with a telephone
number for the children on vacation. The arrangements that were made at the custody
conciliation were, at Father's request, that the children be pennitted to have a cell phone with
them, supplied by Father, so that Father could communicate with the children. By way of
further answer, the itinerary that was faxed to Father indicates the location of the children
during this vacation, as well as an affirnmtion that the children would call their father while
they were away. The children made calls to their father every evening fornl Greece at
mother's sole expense.
15. The actions of Mother arc not in contempt of this Court Order. Father's actions in
making the vacation process as difficult as he possibly can, have resulted in Mother having to incur
additional attorney's fees.
-3-
VERIFICATION
Upon my personal knowledge, infonnation and belief, t, Rosemarie Kaganis (fonnerly
Rosemarie Kanganis), do hereby verify that the facts averred and statements made in the foregoing
Answer to the Petition for Contempt of Custody Order are true and correct.
I understand that false statements or averments therein made will subject me to the criminal
penalties of 18 Pa.C.S.A. ~4904 relating to unsworn falsification to authorities.
Date:
gf1}O!
. ,
"t-/
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ROSEMARIE KAGAN IS,
vs.
NO. 96-4601
Defendant
CIVIL ACTION - LAW
CUSTODY
GEORGE KANGANIS,
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the subject of this
litigation is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
George Kanganis
Dean George Kanganis
November 15,1986
October 27, 1989
Mother and Father
Mother and Father
2. A Custody Conciliation Conference was held on September 10, 2001, with the
following individuals in attendance: the Mother, Rosemarie Kaganis, and her counsel,
Kathleen Daley, Esquire; the Father, George Kanganis, and his counsel, Keirsten Davidson,
Esquire.
3. The parties were seen to address Father's Petition for Contempt. Father alleges
Mother was in contempt of the Custody Order for failure to provide notice of her vacation
plans, failing to advise Father of the location of the vacation until after the date of the
departure, and failing to provide Father with a telephone number where the Children could be
reached during the vacation time. Father and Mother attended a Conference with the
Conciliator on June 4, 2001. The trip in question took place beginning July 25, 2001.
Because of the close proximity in time to the date of the Conference, it is Father's belief that
Mother had planned this trip or was planning to take this trip at the time of the Custody
Conciliation and did not divulge it at the Conference.
4. Mother's position on the contempt: Mother alleges that prior to the Conference she
had given Father notice of her intent to take ten days of vacation time and that subsequent to
the Conference she had notified him that she would increase those ten days to fourteen days
and faxed this information to Father in a memo dated July 20,2001. During the vacation she
alleges that the Children had daily telephone contact with Father and that a schedule provided
to counsel after their departure would satisfactorily meet the intent of the notice provisions
which the parties had agreed to at the time of the June 10lh Custody Conference. Therefore,
Mother denies any contemptuous behavior on her part.
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