The URL can be used to link to this page

Home My WebLink About96-06776 \ 'I 'I' '.., ~. ':I lC 'I, ~ " :s """ ,.::t ,Ct , I " 'II 'N. \ \ ~:( 'I: - . .. ") .. ',I ~ t'" C- I '" , ...J ()" 0 '- -**---~~---*--------'-*-------~ ~: . -" ".. . -, -- -' ,.,,' -' . - .'. - ' . . - . " . . - . , ~ , ' ;~ , - PLEAS .~ :~ I: :~ i~ I:' (-. (", \~ \~ i~ I~ (',f , , iI" : \ ~:, ~). ,)1 ~\ [ill ~I :1 :\ $ IN THE COURT OF COMMON OF CUMBERLAND COUNTY STATE OF I\~~< . C "'" 'Yi!.. ~ \, '~~.I- ..'r- PENNA, " " " " weNDA K. pAULUS, :\ o. 96 - 6776 11) Plaintiff CIVIL ACI'ION - IJ\W :\' ., " ., I "1 ~\ M! ~\ ',' ~\ ~ t. ~ $ $ w ., VI'I';..;\l:'; GEORGE W. PAULUS I oefendant DECREE IN DIVORCE .j).~,.1v,. 19'14,. it is ordered and AND NOW. ., , . ,.. plaintiff. , , , .. defendant. decreed that . ~'Pi\ K... PA~USJ. and _... .GEORGE .w. .PAULUS.. . are divorced from the bonds of matrimony. ~ w ., The court retains jurisdiction ot the following claims which have been raised of record in this action for which a final order has not yet been entered; ~ ~ <' ~ ..,.....,...,.,',.., . NONE. $ w ., ,..)),.." // / , I \e CfnJ&!- / Bv T~~-,,: ^ttt'!\t: _I."i' .' .I --. J, _v,.//A.''''HC, f'. !,>\"A, /-".z;[.:A'J'/(." ) <,..-' !-/ /' r 't,;~( /1., ~ -:.-~t,:, '~1>"r... ./ ,J /7I'rolholl"''''-' ~ ... ~ ~ w ., . 'I ~I ~I - .~. .z. .~:. .:.;. ~ ~ ~ ',' ~ i., (~ , I~ ( '.~ I.... , ~ , ;: , .~ '~ (',' '~ ~ ,~ '~ '~ ~ :~ , ~ ~ ~ ~ ~ ~ :~ . ,l~ .. . .~.~.~..~.,~.~.,-~..~.~.~.~..~~..~.~-'~.~.,~.,~.~:"~-~,~:.:~~ . ~ WONDA 1<. PAULUS, IN THE COURT OF COMMON PLEAS OF Plaintitt CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 96 - 6776 CIVIL GEORGE W. PAULUS, Defendant IN DIVORCE THE MASTER: Today is Thursday, December 11, 1997. This is the date that we had set tor a conference with the parties in the above captioned divorce case to discuss the pending economic issues. Present in the hearing room are the Plaintiff, Wonda 1<. Paulus, and her counsel Carol J. Lindsay, and the Oetendant George W. Paulus, and his counsel Hubert X. Gilroy. A divorce complaint was filed on December 13, 1996/ raising grounds for divorce of irretrievable breakdown of the marriage. Counsel are in the process of preparing affidavits of consent and waivers of notice of intention to request entry of divorce decree, and following the session here this afternoon, the parties are going to execute those documents which they will file with the Prothonotary. The divorce will, therefore, be able to be concluded under section 3301(c) of the Domestic Relations Code. The claim of equitable distribution was raised on August 8, 1997, by husband. The complaint raised the economic claim ot alimony and it is the Master's understanding that the alimony claim has been waived by the Plaintiff. The Master , ~ e~pects that the agreement that is going to be placed on the record will deal with the status of the economic claims, including alimony and counsel fees and expenses. The Master has been advised that an agreement has been reached today after negotiations and the agreement is going to be placed on the record in the presence of the parties and counsel. The agreement as placed on the record will be considered the substantive agreement and will not be subject to any changes or modifications subject to any correction of typographical errors which may be made during the transcription. consequently when the parties leave here today the agreement will be entered on the record and will be the agreement of the parties and not subject to any modifications. On occasion the Master requests that the parties return to affix their signatures by way of affirmation of the agreement that is being entered on the record; however, with the concurrence of counsel, we are going to dispense with the requirement of the signing of the document by the parties and counsel. Following the statement of the agreement on the record and the transcription thereof and the filing of the affidavits, the Master will prepare an order vacating his appointment after which counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. Mr. Gilroy. MR. GILROY: As I understand the agreement, we have a number of items with respect to resolution of the economic issues and the divorce and they are as follows: 1. The proceeds from the sale of the marital home, which are held in an escrow account with Broujos & GilroYi with an estimated value of $11,585.53 plus any interest, if any, accrued on that figure since the date of the last statement, shall be paid to attorney Carol Lindsay as attorney for Wonda K. Paulus and shall be the e~clusive property by Plaintiff, Wonda K. Paulus. Mr. Paulus shall have no claim on those monies. 2. Mr. Paulus has a defined pension plan through his employment with Carlisle syntec. Mr. Paulus shall have exclusive ownership of that plan and Ms. Paulus shall not have any claim or interest in the defined benefit retirement plan. 3. Ms. Paulus has an investment and savings plan through her employment. Ms. Paulus shall be exclusive owner of that plan and Mr. Paulus shall have no claim or ownership in the plan of Ms. Paulus through her employment. 4. A 1990 Chevrolet Blazer was titled in Ms. Paulus' name and was marital property. This vehicle has been sold. Mr. Paulus makes no claim from the proceeds from the sale and all proceeds from that sale of that vehicle shall be the exclusive and sole property of Ms. Paulus. 5. Mr. Paulus owns a 1987 Chevrolet Silverado in his own name. He shall maintain exclusive ownership of that vehicle and Ms. Paulus shall have no claim of ownership with respect to that vehicle. 6. Mr. Paulus has an employees' incentive savings plan through his employment with Carlisle Syntec. The parties agree that a Qualified Domestic Relations Order will be prepared whereby a portion of that employees' incentive savings plan shall be assigned to Ms. Paulus. The portion assigned shall be equal to a value of $40,000.00 in said plan as of December 11, 1997, plus any interest accruing on the said value of I . $40,000.00 between the date of December 11, 1997, and the date of the actual allocation of those funds into Ms. Paulus' name. The attorney for Mr. Paulus will prepare the Qualified Domestic Relations Order and all associated documents pertaining to the transfer of the fund into Ms. Paulus' name and, after approval of that Qualified Domestic Relations Order by the attorney for Ms. Paulus, the documents shall be submitted to the Court and Carlisle syntec. All remaining monies, which includes stocks and mutual funds in the employees' incentive savings plan shall remain the sole and exclusive property of Mr. George W. Paulus. It is anticipated that it will rollover into a tax sheltered plan for Ms. Paulus with no tax consequences to either party. 7. The parties own jointly real estate located on Potato Road in Upper Frankford Township. The property is currently listed with a realtor for sale. The parties shall continue to maintain the property as listed for sale and, upon sale of the property and payment of customary closing costs, the parties shall split equally the proceeds from the sale of that real estate. The parties will consult one with the other in any reduction in the offering price of the property and will agree upon the sale price. 8. The above distribution of assets shall constitute a distribution of marital assets of the parties and each party wavies any further claim against the other party in connection of further equitable distribution of marital assets and also in connection with any claims for alimony, counsel fees, reimbursement for costs, or any other claims under the divorce action. Each party agrees to incur their own attorney fees. 9. There is currently an alimony pendente lite order entered against Mr. Paulus in favor of his wife, Wonda K. Paulus, at the Cumberland County Domestic Relations Office at DR No. 26194. Upon the payment ~ . of the mentioned $11,585.53 in the Broujos & Gilroy escrow account to attorney Carol Lindsay, the alimony pendente lite order shall be terminated with the effective date to be the date the said monies were paid to attorney Carol Lindsay. Mr. Paulus shall have no further obligation for alimony pendente lite or support of his wife pending consummation of the divorce. 10. The parties shall equally divide the cost of the court reporter's fee for the Master. 11. Ms. Paulus' counsel will file the necessary documents to finalize the divorce action. 12. Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship including without limitation, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate. Each will at the request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights, and claims. MR. GILROY: Mr. Paulus, you've been present here while I've dictated the proposed agreement in front of your wife and her attorney and the Master; is that right? MR. PAULUS: Yes. MR. GILROY: Are you satisfied with the terms of that agreement and are you willing to enter into a total settlement of all claims with your wife pursuant to the terms of that agreement? MR. PAULUS: Yes HR. GILROY: Are you satistied that you've had the opportunity to obtain information concerning allot your marital assets and including allot your wife's assets? HR. PAULUS: Yes. HR. GILROY: And have you disclosed, to the best of your ability, all of the assets that are in your name to your wite and her attorney? HR. PAULUS: Yes. MR. GILROY: And are you in consent to have an order issued by the Court incorporating all of the terms that we have just set forth? MR. PAULUS: Yes. MS. LINDSAY: Ms. Paulus, did you hear the terms ot the agreement dictated by Mr. Gilroy? MS. PAULUS: Yes. MS. LINDSAY: And are those terms satisfactory to you? HS. PAULUS: Yes. MS. LINDSAY: Are you satisfied that you have received all of the information to enable you to come to an agreement today from Mr. Paulus and his attorney? MS. PAULUS: Yes. MS. LINDSAY: Have you provided to them all intormation regarding any marital assets which you have d:\paululi\l"(lmphlint.div rile' 5151-WI-lJl WONDA K. PAULUS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE Plaintiff VB. GEORGE W. PAULUS, NO. 96. (( ))1., IN DIVORCE CIVIL TERM Defendant NQIlCf 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. YOl. are warned that if you fail to do so. the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you. including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage. you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY. DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF DIVORCE OR ANNULMENT IS GRANTED. YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR, FOURTH FLOOR CUMBERLAND COUNTY COURT HOUSE CARLISLE. PENNSYLVANIA 17013 (717) 240-6200 FLOWER. MORGENTHAL FLOWER & LINDSAY. P.C. Attornevs for Plaintiff By: {~/l;('\/()..f' , /~~Iol J. lindSey, Esquire _ 10 /I 44693 11 East High Street Carlisle, PA 17013 (717) 243.5513 Date: I' / 2 L' /1./ 'I { r ~ -. :~ &r- 0.- \~ ,~ t5J .Jr.. - -"i: .- ~J c:c.. J~ -. ff: M -';~ l'2 C-: r...:: 1,.1 ! C;l L!.; \0 ._) en U - ., , , , WONDA K. PAULUS, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v , 96 - 6472 CIVIL T~RH . . GEORGE W. PAULUS, . . Defendant I IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF IN'l'ENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 fa) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on December 13, 1996. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final decree of divorce without notice. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. 6. I have been advised of the availabili ty of marriage counseling and understand that I may request that the Court require counselling. I do not request that the Court require counselling. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. $4904 relating to unsworn falsification to authorities. Date: ~t'{' J I. Jr; C} ''} , , U) (J.J~, It {o. }( t~/ 1'1.,') Wonda K. Paulus/Pla nti! . , . WONDA K. PAULUS, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v . 96 - 6472 CIVIL TERM . . . GEORGE W. PAULUS, . . Defendant . IN DIVORCE . DEFENDANT'S AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF IN'l'ENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 330l(C) of the Divorce Code was filed on December 13, 1996. 2. Defendant acknowledges receipt and accepts service of the Complaint on or about . 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 6. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counselling. I do not request that the Court require counselling. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S4904 relating to unsworn falsification to authorities. Date: J::Z ,../1- q 7 Ggfl;f!f.u~~~ -. .,:" l~.' \~. t ~.!; LIl'.- <. ) ~ r.::; 1..,'., y, r', (..:" ' C': ll;' , i U. 1'1... r " f.: u (.: ., . , .."... WONDA K. PAULUS, IN THE COURT OF COMMON PLEAS OF' Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA I I CIVIL ACTION - LAW I vs, I NO. 96-6776 CIVIL 19 GEORGE W. PAULUS, I Defendant I IN DIVORCE STATUS SHEET DATE I 7/15/97 ACTIVITIES: Pretrial statements due 8/11/97 1'-/"/11 (~,..\ .~ . OFFICE OF DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEA3 9 North Hanover Street Carlisle, PA 17013 (717) 240.6535 I. Robert IlIeker, II Divorce Master Treel Jo Colyer Olllee Man80erlReporler we.' Shore 697-0371 Ext. 6535 July 15, 1997 Hubert X. Gilroy, Esquire BROUJOS & GILROY, P.C. 4 North Hanover street Carlisle, PA 17013 carol J. Lindsay FLOWER, MORGENTHAL, FLOWER & LINDSAY, P.C. 11 East nigh street carlisle, FA 17013 RE: wonda K, paulus vs. George W. paulus No. 96 - 6776 civil In Divorce Dear Ms. Lindsay and Mr. Gilroy: By order of court of president Judge Harold E. Sheely dated July 11, 1997, the full-time Master has been appointed in the above referenced divorce proceedings. A divorce complaint was filed on December 13, 1996, raising groundS for divorce of irretrievable breakdown of the marriage. The complaint alsO raised the economic issue of alimony. No claims have been raised for equitable distribution or counsel fees and costs. I am going to proceed on the basis that groundS for divorce are not an issue and that each of the parties will sign and file an affidavit of consent prior to the hearing. Based on that assumption, 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, August 11, 1997. upon receipt of the pre-trial statements I will immediately schedule a pre-hearing conference with counsel to discuSS the issues and, if necessary, schedule a hearing. I note that the motion for appointment of Master indicates that equitable distribUtion has been raised; however, no pleadings have been filed raising that claim, and althOugh the motion for appointment of Master indicates that there is an issue with respect to equitable distribution, if the Master is WONDA K. PAUI,US, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96 - 6776 CIVIL vs. GEORGE W. PAULUS, Defendant CIVIL ACTION - LAW IN DIVORCE ORDER AND NOTICE SETTING HEARING TO: Wonda K. Paulus , Plaintiff Carol J. Lindsay , Counsel for Plaintiff George W. Paulus , Defendant Hubert X. Gilroy , Counsel for Defendant You are directed to appear for a hearing to take testimony on the outstanding issues in the above captioned divorce proceedings at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania on the 19th day of Mllr"h , 1998, at 9:00 a.m., at which place and time you will be given the opportunity to present witnesses and exhibits in support of your case. By the Court, ~~ \== Harold E. Sheely, .Iud'I" Date of Order and Notice: 11/14/97 By: Divorce Master IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR FOURTH FLOOR, EAST WING CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 TELEPHONE (717) 240-6200 . WONDA K. PAULUS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96 - 6776 CIVIL vs. GEORGE W. PAULUS, Defendant IN DIVORCE RE: Pre-Hearing Conference Memorandum DATE: Friday, November 14, 1997 Present for the Plaintiff, Wonda K. Paulus, is attorney Carol J. Lindsay, and present for the Defendant, George W. Paulus, is attorney Hubert X. Gilroy. A divorce complaint was filed on December 13, 1996, raising grounds for divorce of irretrievable breakdown of the marriage and the economic claim of alimony. Counsel have advised that the parties will sign and file affidavits of consent so that the divorce can conclude under Section 3301(c) of the Domestic Relations Code. On August 8, 1997, husband filed a claiM for equitable distribution. Attorney Lindsay has indicated that her client will waive her alimony claim but that she does intend to file a claim for counsel fees and expenses. The parties were married on August 4, 19B9, and separated August 19, 1996. They are the parents of a minor child, Cassandra, born November 1B, 1989, This is wife's first marriage and husband's third marriage. Husband has emancipated children to a prior relationship. wife is JJ years of age and resides at 249 Neil Road, Shippensburg, Pennsylvania, where she lives with the daughter. Wife is a high school graduate and works for Reeves-Hoffman doing labor type work. Her net monthly income is $998.00. Currently wife is receiving $40.00 per week as alimony pendente lite and child support of $98.00 per week. Wife has not raised any health issues, Medical insurance is available through her employment. Husband is 61 years of age and resides at 1760 Sterrets Gap Avenue, Carlisle, Pennsylvania, where he lives alone. He is a high school graduate and does labor work for Carlisle syntec. His monthly net income is $2,166,00. He has not raised any health issues. . The parties OWned real estate at 2268 Pine Road, Newville, Pennsylvania, which was sold. The net proceeds from the sale of that real estate are being held by attorney Gilroy in an escrow account, The balance of that account is approximately $11,660.00. Husband has a lot on Potato Road, Upper Frankford Township in his name only which is a marital asset. The lot is currently listed for sale and hopefully that will establish, when the lot is sold, the market value for purposes of equitable distribution. Otherwise, husband has suggested that the lot is worth $5,000.00. The lot is currently listed for $10,000.00. Husband has a pension with Carlisle Syntec and attorney Lindsay indicated that she is going to have that pension evaluated by an expert. Husband is also a participant in a 401(k) with Carlisle Syntec. Mr, Gilroy is going to provide the date of marriage value in the account, the date of separation value in the account, and the current value in the account. Attorney Lindsay will then hopefully be able to arrive at a suggested marital value for that asset. With respect to the household tangible personal property, counsel perhaps will not raise any issues nor place any values on any household tangible personal property. Mr. Gilroy indicated that he needs to confer with his client before being certain that that iR the position that he is going take. There are two vehicles, a 1990 Chevrolet Blazer which wife has possession of, and a 1987 Chevrolet Silverado which is in husband's possession. Counsel agree that the Blazer is worth $5,000.00; however, there is a disagreement as to the value of the Silverado and attorney Lindsay is going to have that vehicle appraised or use a blue book value. Husband says the value of the Silverado is $500.00 and he bases that value apparently on the fact that the vehicle has high mileage. Mr. Gilroy has indicated that he will ask his client to have the vehicle appraised by a local Chevrolet dealer. Counsel agree that wife has an investment savings account which is marital, which has a value of around $395,00. There is an issue with respect to any credit which husband should be entitled to receive for payment of marital debt. The issue arises out of hUSband'S payment of mortgage payments from the withdrawal of funds from his 401(k). The question that is being raised is whether or not he needed to withdraw that money to specifically pay the mortgage payment or whether he used those funds for other purposes. There are some ,,,"IT.>:IA,.... " n" I,; I" 'I ! f' .., . r',~.,\~'fii:t.~~.rj'i"if,jl.th!e'l ~ \~: '~'J\ '(t.J~,i.I~~";I':\III';~!~~II} .,1,,:' '!,;i,,~,\j' .,' '/ :\" /'fL't ')I1;"l;~II~IJ9iIt~~1J;1 ", .,' ....\..(,'"'I',..'.~\ . -n. ,.~''''j;' i.'.'.:.,', ..1' "', :./..'/lfr. 'ifl'l I" ,..", ( , . j ~ I I \ I, ,11 J 'I 'J ~ t, 11 . ,lr,'ll!l, ~ , r I " , ~ ' I" I'" J l. I ,d,. , I' ',j Ilf( "I, j11Jr?t'll ,;~)l"1 'I . ' I "I" . ...... .. /l" ,,/1,\1,., If ' " 'IVI;;'\"~" "",..\'..,,, . ,. A.ll ,.Ip.f> ~ ,.' ',' . '\'. "',~" ~"',":,..r1~'1. 11"':'(,(""" r.1",'~'I,i""""1 ,..--aMrlD.. ,', I,','.,"t."jll,j!.r,r,'ir" , . !'l' "' , ,....,..-... I . l ,\ .' >"'il' J,(., " , . . i*=r' . . '*-"! ' I 1',\. I.. It' \ 1/~I.&.t \. 'I ,- II III' (I!i' "CI \ . 1 ! . "\ f U; , _, "I j;"'r ~ I I I.' " !' I ,I) ~ ~ t . , . 't ., ; I ,', "", I , I , f'" , ' I, \ r_'ff.l~")!t".:I,t,If'1 \ I ....~ I, I, t;, ,f I II, ,I I;' ,I,! I I, II I""'r', 'r~Jl!.(.'r".,I...tll;,.~'_J', /; \'" _.' ,', .',1.'.;1.... -nil',. 11'... ,~,.._i..,'....JI. ' ,''', , I ", 'I . \.' WONDA K. PAULUS, : IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . VS . NO. 96 - 6776 CIVIL TERM . . . GEORGE W. PAULUS, . . Defendant : IN DIVORCE PRE-TRIAL STATEMll:NT Defendant, George W. Paulus, by his attorneys, Broujos & Gilroy, PC, sets forth the following in accordance with Pennsylvania Rule of Civil Procedure 1920.33(b): 1 Defendant George W. Paulus resides at 1760 Sterrets Gap Avenue, Carlisle, PA. He was born on October 30, 1936. He married Plaintiff Honda K. Paulus on August 3, 1990. The Wife is 33 years old. The parties separated in August, 1996 when the wife left the marital home. 2 The parties are the natural parents of Cassandra A. Paulus born November 18, 1989. The minor child is in the custody of the Wife. Husband is paying $98.00 per week in support for the minor child and $40.00 per week in alimony. 3 The assets of the parties are as follows: A. The marital home of the parties was sold with various loans paid off at settlement. TJle remaining proceeds from the sale are being held in an escrow account with Broujos & Gilroy, PC with the aurrent balance being $11,660.06. B. Husband has a defined pension benefit through his employment with Carlisle Syntec. This Plan has aTl estimated current fair market value for marital property purposes of $11,180.99. C. The parties own an unimproved lot on Potato Road along the Conodoquinet Creek. This was purchased by Husband after marriage and was purchased for $5,000.00. D. Husband has a 401K Plan through Carlisle Syntec. The Plan had a value at separation of approximately $70,000.00. The Plan was started in January 1986, and 3.75 years of the Plan is pre-marital and 10 years would be marital. 65% of the Plan is marital property which suggests a marital property value of $45,500.00. E. Wife has in her possession a 1990 Chevrolet Blazer which is marital property and had a value at separation of $5,000.00. F. Husband has in his possession a 1987 Chevrolet Silverado with mileage of 106,000 which has a separation value of $500.00. G. Wife has an investment and savings plan which has a separation value of $395.00. 4 Husband works at Carlisle Syntec. An Income and Expense Statement is attached. Husband has worked with Syntec for 27 year. and, at 60, anticipates retirement very soon. 5 This is Husband's second marriage. He has 3 children from his prior marriage. Husband's net monthly earnings are approximately $2,l66.00(as per November 1996 DRO conference). 6 Wife works at Reeves Hoffman. Her net monthly earnings are approximately $967.00 (as per November 1996 DRO conference). 7 Husband is prepared to sign a Consent Affidavit for the divorce, and Wife has indicated through counsel her willingness to do the same. 8 Husband has filed a claim at the above term and number raising the issue of equitable distribution in accordance with the July 15, 1997 letter from the Master. 9 Husband does not anticipate that expert witnesses will be needed at the hearing at this time. If they are needed, they will be providing testimony on pension evaluations. 20 Husband asserts that his age, anticipated retirement in 1998, the short length of the marriage and other factors suggest that he is entitled to more than 50% of the marital property. Husband's proposal for resolution of this case is as follows: A. Wife would receive the proceeds from the sale of the home which proceeds are held in the escrow account. Wife would a.lso receive hr:>r pension account, her vehicle and B. $20,000.00 from Hr.Paulus' 401K Plan through a ODRO. Husband would retain the remaining monies in his pension account and 401K Plan. Husband would also retain his I i vehiale. c. The Potato Road property would be listed for sale with the proceeds split between the parties. i :1 , I i , , , I ! Respectfully submitted, G lr, re BROUJOS & GIL OY, P.C. 4 North Hano er Street Carlisle, PA 17013 717-243-4574 INCOME AND EXPENSE STATEMENT OF ~(J#-.J" ()J -r:iJulu (, SSN 19V .211.9622 DRN,;) (, 1ft{- DATE$/vz-- \ THIS STATEMENT MUST BE FILLED OUT (If you are self.employ'ed or It you are salaried by a business 01 which you are owner In whole or In pari, you must also fill out the Supplemenllllncome Stltement which appears on the last page 01 this Income and Expense Stltement.) INCOME , (a) Wages/Salary 1 I 11 IPA Employer & AddressCteLsl.<: Sy'/Tec - 1,Z(J()-;(,1K~~ Ikv!/ (N.Rkflt!' Job Tille/Description L III '1lVJR . Pay Period (weekly, bl.weekly, monthly) 'y.lt:!'e. KUj Gross Pay per Pay Period .................................................................................................................... $ t..-' fi. o.~ Payroll Deductions: 81. SS" Federal Withholding ..................$ _ Social Security ...........................$ If'/. 30 Local Wage Tax ..........................$ t: ,2"1 State Income. Tax .......................$ 'i:1'~ Reliremenl ........... ......................$ ..;z.O Heaith Insurance ........................$f, ,<7 OtheL(specllYISlJffO~t.............$ ~. ~O ~~ltt ~~~:::::::::::::::::::::::: 3~~~. .2.(.0.''1 Net Pay per' Pay Period ...........................".........................;................................................................. $----. (b) Other Income Wsek Interest/Dividends ......................$ Pension/Annuity .........................$ Social Securlly ...........................$ Rents/Royallles ..........................$ Expense Account .......................$ Gifts ... ........................................$ Unomployment Compensation .$ Workmc..,'s Compensation ........$_ Total, Other Income .......................$--11. Month Year $ S $ S $ S $ S .-- --".- $ $ $ $ S S S $---- $ S 4 INCOM~~2:T~TEMENT OF I verify Ihat e statements made In this Income and bpense Stalt. ment a"lru and correct I understand thaI 'alse stalements tleretn a,e made sublecl to the penallles of 18 PaC S "90~lnO 10 unsworn talslflcatlulllO aU'hOrlll~' ~ Date 2'::"2r~l . .... I I I 0 etendanl EXPENSES Home Mortgage/Rant ................................"...... Maintenance ..,...,.......,.."....,............, ",... Utllltlas (telephone, heating electric, etc.) ........................................ Employment (transportation, lu nches) .. ....., ..................... ................,. Taxes Real Estate .............................................. Personal Property................................... Income ,.,............ ".......,........,....., ,... ,. .,.,.., Insurance .Homeowners ............................,..."....,..., Automobile .............. ..".................,.....,.,., L1le/Accldent/Health ...............,..........".. Aut~;:~I;~.;~~~~'~~;~:..;~~;~;~~:.J:.W.. repairs) ...'...'}y.,"f:;!,~.tr.,f!if.-:..@.r,..,.... Medical' (""1'oJ Doctor, Dentist, OrthodonlistO:<.1..f..m..f'f HospJtal ...,...", ....... ..................... ......, ,. ,... ...._~!lclal (glasses, braces. etc.) ISS.fAA.rC EdUtallon Private, Parochial School....................... College ......,.... ..,........,.,.............. .... .......... Personal Clothing ............. ........................ "..."....... Food .........................,........................"..... Other (household supplies, barber, elc.) .......................................... Credit payments and loans .................... Miscellaneous Household help/child care ..................... Entertainment (inc. papers, books, vacation, pay TV, etc.) ............ GlftslChalltable c9,,}rlbullo s .............. Legal Fees .....~.../+6.. ..iJL..... Other child suppo~ alimony , payments ............................................. Other (specify) .............................................. Total Expenses ............................................. Household Week $ $ $ $2.75 $ $ $ $ $ 'f.tR $ $ $ $ $ $ $ $ $ j{ ()C $ ~ ()() $ $ ~ S $ ~s: (JQ $ $ $ :;"00 $ $l13, Ib Child Week HCJusehold Month Child Month $~ $ $ $ $ $ $ $ ,jb6. 'f() $ ---- $ $ $ $ $ $ $_ $ I- $ $ $ $ $ $ $ $ tt3 DO $ $__ $ $_. $ $ $ $ $ \0.00 $ . $ $ .:;) I. O() $ $ $ la.dO $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $_, $ dlf CO $ $ $ $ $ $ $ ---- ---- $ $ $ $ $ "-~7-CO $ ---- $ $ $ S $ $ $ $ - S s %50 $ Sf!;!., 90 $_. :j'l " : ; ", '1,', 'i,."I)' \:11'" , '.~.'... c."..-oY.~,~ , , "''nOII,.vaATUW'' " . ',', '''lall'tII~..-n ',~, "'~Y~lAt1OII' ,171ft...,.,. ,....' .' ',' "'or' ,.t';li,jj{\'~~W'If,~l j'~"',r;J,~'crm'~'iI),f#I,r,. . , : ,J,' ;.'---"'l~;:;,'Jtf*'~\ri',"!;r':"~'A~;' "I '. ~":_' . ,; 'J.I -' >.r/'ll c\ .)d.l,""/IJ 'rt'L"., "I 'I' J i ;1'"lq'J'\' ',Jo;; ;,; 1':,trl\\"J,"4IhN'. ";" .' ~'\';.l'! P'I"'- ,'" "II,,,. ",,\.L'r1.I...,l; I ,'-'f ;/,", "'.;'.,' ,'" i, ',,' '," ,}":.,": ,'-':':':\'i,:'}:Ati+,~"__~1 (j' i,,'. " " 'l'-"I!t"'!~:lt'f\ltt ,:....-......, "', " "'I ,J~'" 1 ,,- '" ''''''<', -'" ,':i:",.~:tIJ;:,'f\'l;.I,\!i,:ilft i~'~'J:~1 '" d"" i ). '''''''1 lIe' ---.. ',,';"W' i'(!, li,',,:/i\!'-'_/J'lj:~,!,")fl, ~ : 11 " \. .~_~'I WONDA K. PAULUS, . IN THE COURT OF COMMON PLEAS OF . Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA : VS I NO. 96 - 6776 CIVIL TERM I GEORGE W. PAULUS, I Defendant . IN DIVORCE . CLAIM FOR EQUITABLE DISTRIBUTION Defendant George W. Paulus hereby requests your Honorable Court to consider in the d.l.vorce action claims between the parties with respect to equitable division of marital property. re ~ 2 '.. '" I ~.. 1- r<) ,~; Lf: 0- ...... i : ,.....; q - ~ I J I ('~, ..~. ~ C?/ .-.. I' . (Jq _I: ;.; In ] ~ "1, .-:.:> - "<- 0', I ',' ., LJ)' !,' '. c) _,II 'Ii': l-L-, > .;",- ,. ..... ;',j u 0" , , :, ~ t\1 '- c: .. ~b .. .- - '-; ~' :r.: ),. J;;: u.. 12} ~. C'") ..~ b.. - ~tfj I" (..) ..'<<, i!.:: L,J r"Bf ~ ,".1 ::;.; m -'. '~) l.) 0'U~ r-lr-l 0 n~OHUlIJlO ~ n~H::O<:UlIJlO ~ ,."..... ~~ &;) S HZC::~'U ~ I;'" ~OOC:~'U ~ 10 ' <010 t'l ~ o 1;"'1;"'''' l11 ~ n\lJ ' Ul HO'tlHZ ~ Ul t1J1;"'~'1lHZ ~ ::rlJl I;"'Ul Z...", Ul HUlO~I;"'OH ~ HUlE:jO I;"'nH ~ 1010 r-l 00 rr:: Cl z~tI Z ~ Z"l < ~ Z ~ ::r n() <:< G1t'l ~G"l ~ G"lt>:!Ult1J!:; "'G"l ~ n(1)~. :1>' el~ () ~ ~r-l::O 0 ~ CXlJl ., H~~ ~ lJl~en r-lOl ~ HO~ ~~ '1~ Hen l;"''<Ul r-lC: ~ H O:J> ~ ~ " r-l Ot>:! I;"'lJ}o gjt1J ~ ~ ~~~~ ZO"'~~ IO"'~ Z() t>:! nzo - i:lD - G1~ I;'" . O~"'" I;'" nlD n :00 ~ o [J)~G111 0 o ~ -...no 0 'n ~i '00E'j t>:! I I~ '< t'J H~OOt>:! r< Orf.., :I>~:I> r-lO t1J Ol~""~ t1J ill::rt1J c: ~ g~r;, ::0 ~ ~();q ~ t>:! 1-I.....;.tI .... t1J en IOlJl t>:! ... ~ ~ :l> HO-H :l> D ,~ :0 N 0 Z () 0 0 O~ OlO 0 0.00 ...... ... "l EG1liJ"l 0 "l Z 8~"l 0 illrf::l .... t>:! 0 0 "ill 0 0.... en 0 ~ 0 H~Ha ~ rf ....... III 008~~ III Ol 0... '2103 N gj "- ::O~H' "- ~H~ 3" W H 00 w ill 10'<; VI ~ 0 ~ Z.... ~ 0 HOl .... .. I1D '" "- H "- ~ "- ~~ "- .. en rt rt ,~. . .... OOl .... .. .... .... .. I ~ 10 P .... III oo~ III ~ III H III .. l1~n 0 III III .. III 0 III .. . ..... ... '" H '" .. '" Z '" .. 1;"'0 , 0.': '" 0 .. .. ~~ '::1. Z ~ ~ " ,0 "l gj~ 10 H '0,.,. >< H 0:;'- t1J ;;J enn [ 11'0 ~~ :l>Ul rf <J) 0 <: In ww .... N .... 3: Hn illrf Illlll W "'''' '" "''''N ZO PO ~~ ....OO~Ol11~ ltJOWoal'lV1~O () 0 G1:O '<:0 . ... . . . . . . . . ... 0 ... en '0 ~ ~ (Xl (Xl mOOl11O~O"'\ No~oo~~rv ~ "- a co III III WOO-...JOO'\O ma~oammo 0 ~~ ~ ".~ .... :I: I1l: "- o~ ~ .... H "':I. III HO ij (Q III ::1Z ,:I. ~~ '" r1t .. t>:!0 0< <J) c5 en"l = f" 00 0000000 00000000 ~~ . '<: ,1. . . .. . . . . . . . . . . . III 01'1 00 ooooooc 00000000 0 r:: ~.1 ~"l"l0 00 0000000 00000000 III ~~ i "':I. HHH() "- :000:1> H w H' 'tn' Ult'lt>:! ZG1 0 'On co ,- r-Jl;"'t-en en 0:0 "- ~:I> 11!:. HHc5 ~ 00 .... mOl ~:;j:;jo ~~ III 0 III 5~ r-J ~~ t'l <J) {J: '" HG1 00 ooooooc 00000000 ~~ co'" 0:0 '0 . . .. . . . . . . . . ... i-' ~~~ :0 00 ooooooc 00000000 't' H 00 0000000 OOOOOQOO 0>; n con. t>:! '"C <: ~R'~ en 0 III ,. () "e.' ~ :I> nc ;>lH ~~ 30 Z co ,- on 0 <J) 0 p..... ~o "l 00 0000000 00000000 n 3: 0 . . .. . . . . . . . . . . . " .. E txlt'l 0 00 0 000000,-.,; 0000.0000 ;>l rr~. 0 III 00 0 0000000 00000000 Ul "- m~ c5 w Ul ""<, 0 ~ on z "- "u, .... COn ~ III <Mn 00 r-l IV III ww Ul .... <f) l\J .... 0 no, CN-..JN '" III III W "'''' '" "''''N r-l ::r CJ')CDI1'!CD ...... t-Jao~C)lJ1~ WOLo.IOOl11l1ll.O ~ cor: r-J. , . . . .. . . . . . . . . . . . p. trJl.OOCD 0000 O'IOOl1lo~m NOI-'OO~~t-.J COtl tr]CDl1llD 'D'" wOO..Joma ~a~oo~"'o P-- 0.. EXHIBIT ._-_.~---_._-_._~--- I liB" 13: :I~ FPC~ 8f>O'Jr0'5 a I LPC', KlJ3TOII TO 2~:bO!J p,o~ Ij ~"'.... l:: ~ :ll <l ... 8 ... ~~'ri!', ~~~, . ~ "' ~ '" "'.... ": l;j ~""'i ..lr''.4;~l\' ~ ~ .. '..J'" .,; '" '"'! " u"'''' ~ .., ~ '" :il ~ ..; ~ w.' i ... ~ on ~;:it"1 ~ '" ~ ~ "Q.Q() ~ ;; '" I '" .... ~ 15 ZIL '. .... ~ .., .. z .... M ;; U :i - ".~I'.'!I. , '" >-31' ~ ~ ,'.'It.o, ,.. ~ n <II ~ .. .. ?:,.;./~!.:',')M ...'" "(~ J1 .., ~ ~ e '-"- '"Iio., ( ... ~ '" ;. ~' " ..:' ',".. . , , " c ~ ~ - ~ .. ... 8 ~ !:! '" ~ :til , .... .... '-" .. ": g <! ~ ~ -;; I~ ~ a r; ... .... 0 "' I ~ - ~ ~ :;( .... ... ~ - ... 0 0 c ... ... ~ ~ ;; ~ " '" - 9 .. .. " .. g .. .. ~ .. ... .. .. v u u .. .: ;: cE w I ... u ~, "" '" .. g 8 ~ 8 ~ Ii ~ 8 8 S <; III ~ a 0 :il a .; a " ... ... 'J 8 ~ ~ ~ .. ... ~ .; 00 " ... ~ ~ .; '" ;; e ... ~ - ~ 8 .... ~ ~ l!! " - .... ~ '" II - ~ .; ~ :il IR ~ S ~ ... ... ~ " a - - ~ :il I 0 ... .. ... " hi ~ ~ 0 ~ . - .. . , - ,., .. I ~ ~ < ~ ~ 8 a 8 ~ ~ f .. ~ 0 .. e a ~ .; ~ - .. ~ a :il sc ~ - ... .. <J ... V w ~ r ~e ~ ~ ~l "'- .. , ~ ~ .. 0 8 8 r... ~ on ... - ,^ I ... ~ - '" ~ I " :il a a - ~ f ~ ' . ... ... - = - .. P II ... . ... '" ~ ... .. C _e ..~ " ~ .' "'1 " I .. .. ,,- .... .. - v It; i! ~ ~ 8 8 ~ 8 g Ii ... ~ ! -- II :il a ~ '" :if a a ;; -'" ... CD .. o . " l: .. ~~ - ~ ~ w__ .. = ..- > " - .. >> ~~ . < <0 ,,"0 '" Ifl 0 ... ~ g t~ - .... Z ~ M -'" 0 ... .... , . z <:> '" - '" I ... $l o , .... .... 5 ... .... '" - 0 ~ r- i ~ " , 'J ... <:> - z ~ 8 ~ >- , '" .. II'> - .... 0 .. .. ... ! ::) '" Il< g; - .. .. - ~ .., 0 ... 0- -- '" - - ...J VI , V .. u Ow 0- Il< .... - ,., ... ~ .... CZ ..J ~ '" >- Z 0 ~ -oJ ~ - .. - ... ~ ... ~ - .... .... v ~ .,'" - - - ~ '" <II I . v ~ r CC '" . ..J ..J >- ~ ~ .. i - ! '" ; ~ "" " '" - ::) ~ W Vl 0 r ... .. ~ ~- C7 - ..J i z .. .. - .. . ~ - it ... '" '" '" ~ .... ~ c1 - .. ~~ c:> ... - - 0 i V'l c1: ;, - '" , - - '" Ill) ..J Z - - '" ... " " ~" - '. .., .:J or or > .. i! >. .. t: c .. .. '. Z ~ 0 <5 .. - Z " - ., .." .... >- "" 0 :s w ~ a; .. ~ ~ .. ::: CD .. .."..., - - -'. -'_-_0. EXHIBIT I "c" 11I1"1 U'l1I01oO-'" - t-elI Nr-...U'lN ":)- C Q(II "'U'l0,,0 ~ 1(11 "1"1(11 \II 00 -"'.. - t- . m 1U'l - ~ ~i lIC- C -- III ";1 >- 1"1 ..(11"'(11..... :;;1 t-- COllOaa-o z 11I1"1 0"- .. M lICO "'1"1- i ~ lIC" If. :;) u ~~ ui i ~~ ...~ III In z ]: CI) ~ (/) C .. .. .. .. 0 u........... Gl: ...:J:J(/):J i: U I&....(/)OU ~ 01"1 ONOI/I 0_ ONI/I,," 01/1..... I ell III Ill.. ...... (\1- ...N ....Ill I I&.Gl:lI: IIIC'" III(/) z~~... lICGl: III ::lGl: %% :":UUIII CCIII:> 00 1-:>Gl:O 00 U&:II i 011I CIII ..- :>::lGl: Gl:% &:IU", I-<JIII II >CI- Ill'" C I lICO III -0- - , to L() o L() L() ..-l 2 i ". Iol. 1/10.""" .. ,,"0--"" I- I . . . . '"J'J't ""_ 1/1 \II'" . r ~... ~ 'C':;: ~ ~~ '" mil> ~ ~ ~ '-, .. .. .. .. ..OU~U C1Z(/)~:> III::)C::lCl) E...lIl cil Z lIC>-&:I&:IO :;)CIIIIII'" lII:J)()(CI) Z ........... ...::l I&. I&. :> .\- 0;,,) ~ - '" ~ ~ expects that the agreement that is going to be placed on the record will deal with the status of the economic claims, including alimony and counsel feee and expenses. The Master has been advised that an agreement has been reached today after negotiations and the agreement is going to be placed on the record in the presence of the parties and counsel. The agreement as placed on the record will be considered the substantive agreement and will not be subject to any changes or modifications SUbject to any correction of typographical errors which may be made during the transcription. Consequently when the parties leave here today the agreement will be entered on the record and will be the agreement of the parties and not subject to any modifications. On occasion the Master requests that the parties return to affix their signatures by way of affirmation of the agreement that is being entered on the record; however, with the concurrence of counsel, we are going to dispense with the requirement of the signing of the document by the parties and counsel. FOllowing the statement of the agreement on the record and the transcription thereof and the filing of the affidavits, the Master will prepare an order vacating his appointment after which counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. Mr. Gilroy. MR. GILROY: As I understand the agreement. we have a number of items with respeat to resolution of the economic issues and the divorce and they are as follows: 1. The proceeds from the sale of the marital home, which are held in an escrow account with Broujos & Gilroy, with an estimated value of $11,585.53 plus any interest, if any, accrued on that figure sinae the date of the last statement, shnll be paid to attorney Carol Lindsay as attorney for Wonda K. Paulus and shall be the exclusive property by Plaintiff, Wonda K, Paulus, Mr. Paulus shall have no claim on those monies. 2. Mr. Paulus has a defined pension plan through his employment with Carlisle Syntec. Mr. Paulus shall have exclusive ownership of that plan and Ms. Paulus shall not have any claim or interest in the defined benefit retirement plan. 3. Ms. Paulus has an investment and savings plan through her employment. Ms. Paulus shall be exalusive owner of that plan and Mr. Paulus shall have no claim or ownership in the plan of Ms. Paulus through her employment. 4. A 1990 Chevrolet Blazer was titled in Ms. Paulus' name and was marital property. This vehicle has been sold. Mr. Paulus makes no claim from the proceeds from the Dale and all proceeds from that sale of that vehicle shall be the exclusive and sole property of Ms, Paulus. 5. Mr. Paulus owns a 1987 Chevrolet silverado in his own name. He shall maintain exclusive ownership of that vehicle and Ms. Paulus shall have no claim of ownership with respect to that vehicle. 6. Mr. Paulus has an employees' incentive savings plan through his employment with Carlisle Syntec. The parties agree that a Qualified Domestic Relations Order will be prepared whereby a portion of that employees' incentive savings plan shall be assigned to Ms. Paulus. The portion assigned shall be equal to a value of $40,000.00 in said plan as of December 11, 1997, plus any interest accruing on the said value of $40,000.00 between the date of December 11, 1997, and the date of the actual allocation of those funds into Ms. Paulus' name. The attorney for Mr. Paulus will prepare the Qualified Domestic Relations Order and all associated documents pertaining to the transfer of the fund into Ms. Paulus' name and, after approval of that Qualified Domestic Relations order by the attorney for Ms. Paulus, the documents shall be submitted to the Court and Carlisle Syntec. All remaining monies, which includes stocks and mutual funds in the employees' incentive savings plan shall remain the sole and exclusive property of Mr. George W. Paulus. It is anticipated that it will rollover into a tax sheltered plan for Ms. Paulus with no tax consequences to either party. 7. The parties own jointly real estate located on potato Road in Upper Frankford Township. The property is currently listed with a realtor for sale. The parties shall continue to maintain the property as listed for sale and, upon sale of the property and payment of customary closing costs, the parties shall split equally the proceeds from the sale of that real estate, The parties will consult one with the other in any reduction in the offering price of the property and will agree upon the sale price. 8. The above distributi.on of assets shall constitute a distribution of marital assets of the parties and each party wavies any further claim against the other party in connection of further equitable distribution of marital assets and also in connection with any claims for alimony, counsel fees, reimbursement for costs, or any other claims under the divorce action. Each party agrees to incur their own attorney fees. 9. There is currently an alimony pendente lite order entered against Mr, Paulus in favor of his wife, Wonda K. Paulus, at the Cumberland county Domestic Relations Office at DR No. 26194. upon the payment of the mentioned $11,585.53 in the Broujos , Gilroy escrow account to attorney Carol Lindsay, the alimony pendente lite order shall be terminated with the effective date to be the date the said monies were paid to attorney carol Lindsay. Mr. Paulus shall have no further obligation for alimony pendente lite or support of his wife pending consummation of the divorce. 10. The parties shall equally divine the cost of the court reporter's fee for the Master. 11. Ms. Paulus' counsel will file the necessary documents to finalize the divorce action. 12. Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship including withol~t limitation, statutory allowance, widow'S allowance, right of intestacy, right to taKe against the will of the other, and right to act as administrator or executor in the other's estate. Each will at the request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights, and claims. MR. GILROY: Mr. Paulus, you've been present here while I've dictated the proposed agreement in front of your wife and her attorney and the Master; is that right? MR. PAULUS: Yes. MR. GILROY: Are you satisfied with the terms of that agreement and are you willing to enter into a total settlement of all claims with your wife pursuant to the terms of that agreement? MR. PAULUS: Yes MR. GILROY: Are you satisfied that you've had the opportunity to obtain information concerning all of your marital assets and including all of your wife's assets? MR. PAULUS: Yes, MR. GILROY: And have you disclosed, to the best of your ability, all of the assets that are in your name to your wife and her attorney? MR, PAULUS: Yes, MR. GILROY: And are you in consent to have an order issued by the Court incorporating all of the terms that we have just set forth? MR. PAULUS: Yes. MS, LINDSAY: Ms, Paulus, did you hear the terms of the agreement dictated by Mr. Gilroy? MS. PAULUS: Yes. MS. LINDSAY: And are those terms satisfactory to you? MS. PAULUS: Yes. MS, LINDSAY: Are you satisfied that you have received all of the information to enable you to come to an agreement today from Mr. Paulus and his attorney? MS. PAULUS: Yes, MS. LINDSAY: Have you provided to them all information regarding any marital asset~ which you have In the Court of Common Pleas of CIJMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION WONDA K. PAULUS ) Dl..ktl NUllIllt' 96-6776 CV Plaillllff ) vs. ) PACSES Cast NUllIllt' 707000051 GEORGE W. PAULUS ) DK ~~ I'1L/ Dttclldalll ) Olht' Slalt ID NUIlIh<:, CONSENT ORDER AND NOW, to wit, on this 11TH DAY OF DECEMBER, 1997 IT IS HEREBY ORDERED that the support order in this case be 0 Vacated or 0 Suspended or (i] Terminated without prejudice. effective December 11, 1997 , due to: A,(({tjrt1J .tJ?fllo(Hl{'.C~ I((;/Ulllk)g~-r Consented: '/.. W Q1t\.C'lo -1(( f1.uJ) (1/) Plaintiff x /' .--~ Defendant Attorney/Witness DRa. R.J. Shadday CCI plaintiff and defendant ",,,CLI;,,I rl...t...,:Jo. ~I\l'l'" JUDGE January 29, 1998 Date S.rvkt Typt M h"," OE.~O.1 WlI,kc' ID 21201 ,. ) , .. , '. I I. , " ..... , (' " (.} ',:1 U