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Home My WebLink About00-00892 ,:;.:, ,-,;, ~< . " " " . . '" "'''' '" . ! . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. . Michele L. Donovan NO. 00-892 Civil Plaintiff . VERSUS Hank P. Donovan, Sr. Defendant . DECREE IN DIVORCE AND NOW, J"~ -* 9.'rs-~.A . Jcol , IT IS ORDERED AND II DECREED THAT Mi ('n~ 1 ~ T nnn(""'.T~n , PLAINTIFF, . . AND , DEFENDANT, l--I~n1r P TInnn'7!:1n C:T' , ARE DIVORCED FROM THE BONDS OF MATRIMONY, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE . BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . . Tno parties' Memorandum of Understanding entered into before the Master on March 28 2001 is incor orated into this Decree hut not mer ed . BYTH ATIE5T?J~ PROTHONOTARY . . . . "'''' '" '" . . " , J, . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~ . ! . . . . . . . . . . . . . . . . . . .' . ." , , , e, .' "" ~: .1 '< ':~ 7.~:df CwI. ~ ~--k 4.~ 7-1;1'0/ 71~ ~ 717 4 ,me ~. . ' , . ,J . ~ ., ,o'i'"i,T",,_' " -~~.~ ,~ ]..'l1"'~ -~ ~. -~ ~, Il!lI r '- _C<" " , ,,;,-, -~;:<i'Sl' " MICHELE L. DONOVAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v, : CIVIL ACTION - LAW HANK P. DONOVAN, SR., Defendant : NO, 2000-892 CIVIL TERM : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the court for entry of a divorce decree: 1, Ground for divorce: Irretrievable breakdown under ~3301(c) 33el(a)(1) eftlle Di'veree Ceae, (Strike out inapplicable section), 2, Date and manner of service of the Complaint: by certified mail, restricted delivery to Defendant, Hank p, Donovan, Sr" on February 19, 2000. 3, Complete either paragraph (a) or (b), (a) Date of execution of the Affidavit of Consent required by ~3301 (c) of the Divorce Code: by Plaintiff: March 14, 2001 by Defendant: March 14, 2001 (b) (1) Date of execution of the affidavit required by ~3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiffs affidavit upon the respondent: 4, Related claims pending: none 5, Complete either (a) or (b), (a) Date and manner of service of the notice of intention to file Praecipe to Transmit record, a copy of which is attached: (b) Date of plaintiffs Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: March 14,2001 Date defendant's Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: March 14,2001 It"""""'" . -".~ ".;~'" -". &:[-'f -j.-rr'pt,l "~~" ~iligj"l$li ,~- "''''''"",'M'' " G s;::; -<:::. ~~~: 21' G:!.- ~~., j;;E? ~ , -<C , , ,,' ~,,:, ,t r.::::l (~= J-"~ I G ).-,) :..n '-1 . '''''''"'<i .. MICHELE L. DONOVAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW HANK P. DONOVAN, Defendant : NO,~(\ -Jf.;u;IVIL : IN DIVORCE ~OTICE 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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 Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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, Cumberland County Bar Association Two Liberty Avenue Carlisle, Peunsylvania 17013 (717) 249-3166 ,oj , . I L_' " MICHELE L. DONOVAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, CIVIL ACTION - LAW HANK p, DONOVAN, Defendant : NO,o2&tm. 6'9oL.cIVIL : IN DIVORCE COMPLAINT IN DIVORCE COUNT I NO FAULT - CONSENT I, Plaintiff is Michele L. Donovan, an adult individual currently residing at 233 South Side Drive, Newville, Cumberland County, Pennsylvania. She has lived there approximately four (4) years, 2, Defendant is Hank p, Donovan, an adult individual currently residing at 11 Grove Road, Carlisle, Cumberland County, Pennsylvania, He has lived there approximately nine (9) months, 3, Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4, Plaintiff and Defendant were married on December 11, 1993 in Cumberland County, Pennsylvania, 5, There have been no prior actions for divorce or annulment between the parties, 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies, 7, Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling, ,~~ ~" ~ ..- I....... ~ 8, Plaintiff and Defendant are citizens of the United States of America, 9. The parties' marriage is irretrievably broken, 10, Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce pursuant to Section 3301 (c) of the Domestic Relations Code, COUNT II INDIGNITIES 11. Paragraphs 1 through 10 above are incorporated herein by reference as is set forth in their full text. 12, Defendant has committed such indignities upon the person of the Plaintiff, the innocent and injured spouse, as to make her condition intolerable and life burdensome, WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce pursuant to Section 3301 (a)(6) ofthe Domestic Relations Code, COUNT III EQUITABLE DISTRIBUTION 13. Paragraphs 1 through 12 above are incorporated herein by reference as is set forth in their full text. 14, The parties are owners of real estate located at 233 South Side Drive, Newville, Cumberland County, Pennsylvania, 15, Plaintiff and Defendant are joint owners of various items of personal property, furniture, and household furnishings acquired during their marriage which are subject to equitable distribution, - "'11IO;O - '. 16, Plaintiff and Defendant have incurred debts and obligations during their marriage which are subject to equitable distribution, WHEREFORE, Plaintiff requests your Honorable Court to equitably divide their marital property and equitably apportion their debts, COUNT IV ALIMONY. ALIMONY PENDENTE LITE. COUNSEL FEES AND EXPENSES 17, Paragraphs 1 through 16 above are incorporated herein by reference as if set forth in their full text. 18, Plaintiff is unable to provide for or afford her counsel fees, expenses, and costs during the pendency of this divorce action and through its resolution, 19, Plaintiff is without sufficient property and otherwise unable to financially support herself on her present income, 20, Defendant is presently employed and receiving a substantial income and benefits and is able to pay for counsel fees, expenses, and costs as well as alimony and alimony pendente lite for Plaintiff, WHEREFORE, Plaintiff requests your Honorable Court to enter an Order requiring Defendant to pay Plaintiff s counsel fees, expenses, and costs as well as providing for payment of appropriate alimony and alimony pendente lite to Plaintiff, Respectfully submitted, GRIFFIE & ASSOCIATES ~{\l..ot~cl ~QP'^ Kristen God Donsen, Esquire Attorney for Plaintiff 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 ~ ~ -.; ~- - - VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein made are subject to the penalties of 18 PA,C,S, Section 4904 relating to unsworn falsification to authorities, DATE:'dl\-{{) \,':~~~ D.Ol';'OV:h-~' ~ "~ ri~' "",,-...- Il~'" . ~ l'_" "'~ ,,~_.~(,;~" tliIiMli1lliil~>f"''''''ii.<<,.~_ ,,-, jfJ - 'iIIiIlmll'1 it... ~ J,-, '"d',.......' o C.; ," :ftY' 2:C V:",:" -z. ' r.~~ (~. ~~8 ~. "- ?: =< '" . "'" a 1,,'.::,) -., ",,, c;j o ~.n ()1 -,--,;.,-/ 1.:1 ',' c') ~~:~?;;~ :t" -< ~,..,~ (',.) 'D "....., MICHELE L. DONOVAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW HANK p, DONOVAN, Defendant : NO, 2000-892 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A. Complaint in Divorce under 93301 (c) of the Divorce Code was filed on February 15,2000, and served on February 19,2000, 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3, I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the decree, I VERITY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT, I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa,C,S, 94904 RELATING TO UNSWORN F ALSIFICA TION TO AUTHORITIES, DATE: "} / 111/ ~ ( X\~S{'/"o."--"'" MI ELE L. DO , Plaintiff ' i_~l'Wo_~I\H@b'irlrrJ~~~~>"'''''-'''''' ~-<~""'. "I~~...~:~~il~l&t;. ~.~" ~ C) [:: ~s: -va; 22m ::c t35: -<""- r-:~' :<:'.......1 ~C) j;:O f; .c.:. =< o f\) - <:::> c) -T] ::'l: :l:1. :-"" i::L"] ,- 'J:?8 if~ s; -< .i:'" " ::J!; c.v " ,",'>i' -,'.-- ~;, >-, --",1,':'~ 1_> ";'.' " - '__,~ -, -. -,;,-Cd."" '" ; MICHELE L. DONOVAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO.2000-892 CIVIL TERM HANK P. DONOVAN, Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 15, 2000. 2. The marriage of 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 in divorce, 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa, C, S. Section 4904 relating to unsworn falsification to authorities, Date: ~c. H / 'f, .2001 ~ p C2 _~ HANK P. DONOVAN Defendant 0 0 ", '-, c: -'n ~ :Jl: -0 GJ ~ -,~ mnl ;;V . z--,.^; ';1. ~~: ,,--! ~~ .'- c"c ! ~C -0 =j~ ~O ::!l; ~~~~ >2 C.~) (::sr'l .-1 ~ 0 ~ -< . ~ =" L ~. ", MICHELE L. DONOVAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW HANK p, DONOVAN, Defendant : NO. 2000-892 CIVIL TERM : IN DIVORCE WAIVER ON NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER ~330l(c) OF THE DIVORCE CODE I, I consent to the entry of a final decree in divorce without notice, 2, 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, 3. I understand that I will not be divorce 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 files with the . Prothonotary, I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT, I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa,C,S, 94904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES, DATE: :dl'1/,"q J , iI.~~.C'O~ MICHELE L. DONOVAN, Plaintiff '\ IiIIII ........11l;~__ .lii~i".. , ...,,_~~"""',.,_'''"-~ ,', '"" ~ ^ IIL~ml.'"""" ,;~. " "" o ~ 0 0 0 c: "Tl -offi ;:;J; )::w 5Pn, ;:;0 ,.2 :J:' Z:r;:' ^-;""\ C/)p C' :-:f:i~-? -<2~ "~, 1;2D -0 ~~~ P ~ " 2:0 =o{j; ('''') 2:! -0 .::;?-('; )>c; S'i' i:srn z: :::> c;:' =< ~ f'-' -< , ' - k "'-' " " _ __r. _,' "~ ,.>~o~ -'~ "1 MICHELE L. DONOVAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO.2000-892 CNIL TERM HANK P. DONOVAN, Defendant IN DNORCE WANER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DNORCE DECREE UNDER SECTION 3301(c) OF THE DNORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. 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, 3, 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 inunediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa, C.S. Section 4904 relating to unsworn falsification to authorities, Date: ~2001 ~f?u-~ HANK P. DONOVAN Defendant ,,',C"__,:,,"" '-.:--;,,':;";;; (") a f'"t1 c: $: - ,-- -'-'.. -OCT.> :L-q " mrn _"J Z:u "~ ," :--1' i:T.S; r- ,'iCJ ,~ '--,,_ 1 -<L. ::;J~f; !,<:C' ""!.J '~"Tl "'- " ""1t' ~~('5 ZC ~ >=2 w ern .. o;:;l :z 0 ~ :::t ! ", - ,-- ",,' . ~, ,,"^,:';'.' ',', ""'''''",'",,-,;,-1.;';:''-'::'--'__''''' , "-, -,J,,~ ,"' ~- .' , !\fiCHELE L. DONOVAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO.2000-892 CIVIL TERM HANK P. DONOVAN, Defendant IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1, I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2, I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3, Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa, C.S, Section 4904 relating to unsworn falsification to authorities, Date: /f~<u It/I-. .2001 ~p0_,~. HANK P. DONOVAN Defendant '.,"- ,,' ,~,,,. "',""C2'r",,", ""'" '" "' ",'h"'" .. .''-' .. 'A .... '.. CO, "',," ,x-, .'_1' () 0 ~~ C ~ :-E.: -OW l}."-~ '-,": 52~n :::D , "':"1 zc;,: .. ',~ ~,2;~ ,,' -;, ! r:CI '~~=5 r~) '< '.' , ~O =;r '--~"' C) =0 (..) C, i-Ii Pc: -. ~ 0 pc :0 -< ,--I ._~ ""0--, , . MICHELE L. DONOVAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY - ENNSYL VANIA vs, : CIVIL ACTION - LAW HANK p, DONOVAN, Defendant : NO. 2000-892 CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this dJ3.d day of F~, 2000, comes Kristen Goddard Donsen, Esquire, attorney for Plaintiff, Michele L. Donovan, and states that the Defendant, Hank P. Donovan, was served with a true and attested copy ofthe Complaint in Divorce by certified mail, restricted delivery on February 19,2000, Respectfully submitted, GRIFFIE & ASSOCIATES ~w~ Kristen Goddar onsen, Esquire Attorney for Plaintiff 200 North Hanover Street Carlisle, P A 17013 (717) 243-5551 (800) 347-5552 Sworn and subscribed to this rJ3td- day of ~~,2000, /I(~d~ Notary P~ic Notarial Seal Robin J, Goshorn. Notary Public Cartisle Bora, Cumberland CounIY My Commission Expl.... Apr, 17, 2003 ..I ...\ - ... Z 452 478 802 , CenifiedFee (/'1.::2. ~ "" Spedal OelivaJy Fee -..;; ~ Restricted Delivery Fee ~"' ~ g Retum ReceiptSho' to '\J"s..... Whom & Date '~'&RelumReteipt <( Date& \l<.> . ' 8 TOT-'\i.P """ CD ' ,~ (I) POStn'latk ,_ E "-If 0le ~ .... -I "ComIi~..itS,,,,,, 1 ""'or 2 lor additional 881\1I_, I also WIsh to receive the ii "Compteleliems 3, '!8;"and 4b, following services (for en tPrintyour,nameandaddressonthe~~t~.Jormsothatwecanretum'1h\B 1IIJrctm' -' -" -"" -,:mae:, ::-~rmtothefro~ofthemalIPie~,or~'thebackjf8pat:edDes~ :",',",_ -; ';,', ',', :' - ~,' ress ~ ~ ~r:i!Retum Rapt RsqueptBd.on the mallplcC8 betow Ihe article number. 2~;' J ; ~ery cI "'!lie Relum Receipt will&how III whOm thurtlcle Wll& _ and the date ':;rV'CnT'..'15. . c dehvered.' Co I postmaster fo, fee, - j 3, ArtIcls Addressed to: , ',4a,ArtiCle Number, J 'a. \ U, ,(\ \, \') "'O"^O' rTJ ., 461-- E E t1V1!V\~ '(. Vn\lVI,., 411, erviceType i 8 If\. {/>>,m 1,{ 111 riM ',,:; D Registered ~Cel1ffied '" v 'VI W'" \LV. D Express Mall 6 -Insured i (" \' \) I^ I .." D Relum R!ICOJpUorMsmhandlse D COD ,. U:i\{ ~S \e. \ VI I" 7, Date of sllve; i ./ ',2- ! 8, Addr . s's ,f8ss (OnlY If requested i and (ss Is paid) i= !l & .!II 1~97.e..o179 ......- d'".i."-,.'" 'il1i. ' ~,-" "'''''''' ~.~,' ".J_~ '""' ,~', "'c' ,d" , - <' '~;. ,~ " " " 0 c:} c= C:J .::-.:;',,c 'T1 gJ ~;~~ ;'T'j " i !::.,-;:; --~ ,- 7: "" -", CO (.L"::' ("') -' ',c ~ , ~6~ --.') C) "-1-, 7l,,~ {2?S ~Q c" i'>) i:5rn 2: 0'1 5;~ -' -< t,."') ::D -< ',c" " " 'I ~ I i --~..... ~~. ...l'''''''''''''~I'! ... GRIFFIE & ASSOCIATES Attorneys and Counselors At Law NOV 26 2~ - Bradley L. Griffie, Esquire Marylou Matas, Esquire 200 North Hanover Street C8dIsIe, PA 17013 (717) 243-5551 1(800)347-5552 Robin J. Goshorn LegalAs8istant Reply to: CarlWe 38 Norib MalnStroet Cluunben...... PA 17101 (717) 267-1350 Fa (717) 143-5063 November 21,2001 VIA FACSIMILE & U,S, MAIL Fax #: (717) 240-6462 The Honorable Edward E, Guido Cumberland County Courthouse One Courthouse Squa~e Carlisle, P A 17013 RE: Donovan v, Donovan No. 99-4748 Dear Judge Guido: Your calendar will reflect that there is a contempt hearing scheduled in the above captioned matter for Monday, November 26,2001, to begin at 8:30 a,m, Please be advised that the parties have resolved the issue that we intended to present to you along with other collateral issues that will allow us to withdraw the Petition for Contempt. I will file a Praecipe to Withdraw the Petition for Contempt so that the record is clear on that matter. If you wish to have me take any additional action, please advise, ) aIey:/~e BLG/kjl cc: Marcus A. McKnight, III, Esquire [Via Facsimile & u.s. Mail; Fax #: (717) 249-6354] Michele L. Donovan ~--~- .......- - 11-21-2001 12:53PM FROM GRIFFIE & ASSOCIATES TO : i , , , , " - ; I ~,..' > B~ L G~i1Oet Es4uhe :'1 ' ~~lou Matal!. ~ 'I ,,' 'I JIeidD,J.~: ' " Lotp>lAni_ ' I I ,I .1 "j ; I ;\ I 'I I I " , 'I , , . :) ,.I i :1 I I 'I 1" :"1 ',I ('i :\ :1 : i i I GRIFFIE & ASSOCIATES Atto17fi!Y$ tmd Counselors At Law , ~....'ca.- November 21, 2001 ... c"_ -, 2406462 P. 02 Z8(t N............er.... ~1.''''l'1el3 , ('717,)243-5551 l(ll1lO)34'1~ JlINaoIhMooim_ ,-'. L PA 1"7281 , .. , , (717) 24i7_1W , Poa<('71'7)2434!OII3 VIA FACSIMILE & U.S; MAIL , Fax#: (717)240-6462 The Honor~ble EdWard E. Guido , , CumbcrJ.an4 Coun1!Y Courthouse One CourthOuse Square Carlisle, PAt 1701:3 'RE;: DUllUVlUl V. DUiluvlUl No. 99-4748 Dear Judge O:wdo:, Your calerldar will reflect that there i~ a contempt hearing !\Cheduled in the above I , captioned njatter f~r Monday, November 26,2001, to begin at 8:30 a.m. Please be advised that the porties litllve re~olved the issue thot we intended to present to you' along with other colloterol is$1ies' that 'will aiIQw us to withdraw the Petition for Contempt.' 1 will file a Pralicipe to WithdraW the Petinon for Contempt so that the record is clear on that matter. If you Wish to have me tal\!e 'any additional' action, please advise, BLGllgl .,' J ' ;' ;/ ley ",It.: ~e I / cc: iMareus A. McKnight. III. Esquire ! :' [Via Facsimile & U.S. Mail: Fax #: (717) 249.6354J Michele L'Donovan , ' IUIHL 1-'.1<1<' 1 ' , : -.;. , , , :adlttYl t.. GtUfie. Bsquite Mut~1I Matas, ESqPire: ' Ii. i 1 " ~libia.J. Gosh!lJ1l ' ", ' ' , I' f.4"lJluUmm . 'l . , ! ~....... , " , , i: " ~J_ I ~ , ~, 11-21-2001 12:53PM FROM GRIFFIE & ASSOCIATES TO G.Kll:fJ:(L~ & ASSUCIAl'~S Aaorneys and Counselors At Law !::.:~. n..',: ~ ' . 2406462 P.01 zooNo.<tll~_ Cu&k,PA t'1OU (111) 243-5551 1(800)347-5552 3i __s...... L"1NoM~.,'A 1720l (717) :167-1350 .",,(711)%0 ~ com:rDENTIALITX NOTICE : iua,.. c_ ,J . , I i j , I r r ; I !'( , , I : j , i , I · i ! , i , , . I , , , i , ! , ' , i I , , I , i ! I , i , ! i i , i 11 .i J , 1 I I : ! ; i : ' I , , ' " ' 1'1 , ' , i,! , ! , I ; 'j : i i i : t 1 i , I :., I' ! j i I ; I ! l " I j i : j , i : 1 "1 j: I' 'THIS FACSIMILE TRANSMISSION IS INTENDED ONLY FOR THE USE tiP, THE INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED, At'ID MAY CONTAIN CONFIDENTIAL INFORMATION BELONGING TO TIlE ,SENDER wmCH IS PROTECTED BY ATI9R.'iEY-CLIE:l'<1 PRIVli.EGE.' IF YOU ARE NOT THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISCLOSURE, COPYIl"G, DIST~I.mON. OR'THE TAKING OF ANY ACTION TNRF.TJANCR ON THE CONTENTS OF THIS INFORMATION IS STRICTLY PROHIBITED., IF YOUflA, VB RECEIVED THIS nANSMlSSION IN ERROR, PLEASE IMMEbIA TEL Y NOTIFY US BY TELEPHONE TO ARRA..'1GE FOR TIlE RETUR:N OF THE DOCUMENTS. FAX NO.:, ,', <J.40~ (g4(Pl- COMPA!IiY:, . ATTENT~ON: -iM DATE TRiANSMITTED: ~1'1 V,Ii\ IoLt \\\""l.\~II\ , '1 A wVYVt "7.. r..srAA reA 0 TIME TRA.'iSMlTIED: 11.', tP 1- Y> rug( , NUMBER OF PAGES (including cover page): SENIfER:i :.' ' \.LfA vJ'~ (-fVv bv:+G'J ", 7?~;~J STJBJECT/NifESSAGE: i' \2----<1 \- \)OVlovaV'\ 1,/ I DvV\wu,\ '1-10 - 40( - 4 74'( I' : , , Original documents ~~ follow by U.S. Mail M tk~-, v, OCT 2 9 2001 ~&- : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW MICHELE L. DONOVAN, PlaintifflPetitioner HANK p, DONOVAN, SR., : NO. 00-892 CIVIL TERM DefendantfRespondent : IN DIVORCE ORDER OF COURT AND NOW this s\.shaYOf D;:.,.r""L<:J , 2001, upon presentation and consideration of the within Petition, a Rule is hereby issued upon the DefendantfRespondent, Hank p, Donovan, Sf., to show cause, if any he has, as to why he should not be found in contempt of the Court's Decree in Divorce of July 11, 2001, incorporating the parties' Memorandum of Understanding in the aforesaid Order and Decree and why the additional relief requested by the PlaintifflPetitioner herein should not be granted, Rule returnable at a hearing to be held on mt!J,,'/ A Y , the ~ay of Nt) V t,."""i t./C ,2001, at B: 3d li.,m, in Courtroom # ~ of the Cumberland County Courthouse, Carlisle, Pennsylvania, Service to be made upon counsel of record for the DefendantfRespondent. BY THE COURT, "'" J.'~ ~\\ t- 'N ,~?, .::J ~\.,,-,, ~ t::,\ r ;y \\ \.' / "'----/ cc: Bradley L. Griffie, Esquire Attorney for Plaintiff/Petitioner Marcus A, McKnight, III, Esquire Attorney for Defendant/Respondent ~~~r iBMB'<IIli1I= ~ -~ -~" :U:~MMll!i_f~jli'!1itll1lW~ ~- ~":!i. --, ~, -- ,', ~" WI. ~* ilIii~.;!i!lmll~~-"".J~'-R:i!!ilkll.n ,~# . ~ ' L111'J 0 0 ('; C -1"1 <~ ----"" \JC:~: S~ r1'l n-, Z:::''L ZC -.1 ~t~ ~~ 2?:(~: -,,",,, " L('"-) ,~ ).~ C:: \.;-' .-', 7 ., -'"l ~ r. :-~. :::t ::0 N -< . k1l " , '-.... MICHELE L. DONOVAN, PlaintifffPetitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v, : CIVIL ACTION - LAW HANK p, DONOVAN, SR., : NO, 00-892 CIVIL TERM DefendantfRespondent : IN DIVORCE PETITION FOR CONTEMPT AND NOW comes Petitioner, Michele L. Donovan, by and through her counsel of record, Bradley L. Griffie, Esquire, and petitions the Court as follows: 1, Your Petitioner is the above named Plaintiff, Michele L. Donovan, an adult individual currently residing at 233 Southside Drive, Newville, Cumberland County, Pennsylvania. 2, Your Respondent is the above named Defendant, Hank p, Donovan, Sr., an adult individual currently residing at 11 Grove Road, Carlisle, Cumberland County, Pennsylvania, 3, The parties were previously married but divorced by Decree in Divorce dated July 11, 2001, which is incorporated herein by reference as Exhibit "A." 4. The parties Memorandum of Understanding that was incorporated in the aforesaid Decree Respondent was to take the following action: a,) Pursuant to paragraph one of the aforesaid Memorandum of Understanding, Respondent was to convey his interest in the real estate located at 233 Southside Drive, Newville, Cumberland County, Pennsylvania, which real estate included a mobile home that was jointly owned by the parties. """""~": b.) Pursuant to paragraph seven, the parties were to maintain sole title of the property that they had in their possession, including Petitioner's Ford Escort, c,) Pursuant to paragraph nine, the parties agreed to sign any document that needed to be signed in order to facilitate implementation of the Memorandum of Understanding, 5, Despite repeated requests by Petitioner to make arrangements to transfer his ownership in the mobile home that is located on the real estate of 233 Southside Drive, Newville, Cumberland County, Pennsylvania, which was to be conveyed either pursuant to paragraph one or pursuant to paragraph seven of the aforementioned Memorandum of Understanding, Respondent has failed and refused to assist in the transfer of the titles to property as required, 6, Counsel for Petitioner has written to counsel for Respondent on at least two occasions requesting that he have his client cooperate relative to the transfer of titles as required by the Memorandum of Understanding of the Court's Decree in Divorce entered July ll,2001. 7, Despite the various requests and demands made by Petitioner and her counsel, no response whatsoever has been forthcoming from the Respondent nor his legal counsel, Marcus A. McKnight, III, Esquire, 8, Counsel for Petitioner has advised counsel for Respondent that if cooperation is not provided to transfer the titles, there will be no alternative but for Petitioner to file a Petition for Contempt to which counsel for Respondent has failed to respond, - - -A 9, Petitioner has been required to retain the services of counsel to file the within Petition for Contempt in order to force Respondent's compliance with the parties with the Decree in Divorce dated July 11,2001. WHEREFORE, Petitioner requests your Honorable Court to enter a Rule upon the Respondent to show cause, if any he has, as to why he should not be ordered and directed to execute the title to Petitioner's Ford Escort and 1972 Atlantic mobile home, as well as why he should not be responsible for payment of attorney's fees and other such relief as the Court deems just and proper. Respectfully submitted, --- VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S, Section 4904, relating to unsworn falsifications to authorities, DATE:\D-':). :-,-<",\\ . \~'r-.~'~ ~,~c..~ MICHELE 1. DONOVAN, PlaintifflPetitioner I - .1 . . ,ji!+.!+.!+.;+; . . . !+. it. !+. ,..;t; it; !+. ..!+.!+. . .. . . . IN THE COURT OF COMMON PLEAS . . OFCUMBERLANDCOUNTY W~" STATE OF Sli' '/1''''' ,"", ... .. . . " -." - ~, . ~'- ,~., ' "'"-;,_.~~~ . PENNA. . Michele L. Donovan . . No. 00-892 Ci vil Plaintiff . . . . VERSUS . Hank P. Donovan. Sr, . . . Defendant DECREE IN DIVORCE . AND NOW, July 11. at 9:55 a.m. , IT IS ORDERED AND 2001 DECREED THAT Michele T.. Donovan , PLAINTIFF, AND H~nk P nnnov~nf ~r , DEFENDANT, . . ARE DIVORCED FROM THE BONDS OF MATRIMONY, THE COURT RETAINS JURISD'ICTION OF THE FOLLOWING CLAIMS WHICH HAVE . BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . . The Parites' Memorandum of Understandin~ entered into before the . . . !+. Ma~ter on March 28. 2001. is inc~rporated into this Decree. but not Mer~ed. . . . . By THE COURT: I s/Edward E. Guido . . ATTEST: /} ::if(;)~ r,.;J1.~ CERTIFIED COpy ISSUED JULY 12. 2001 PROTHONOTARY . . EXHIBIT "A" """",-, . . . ' . . . . , ,. . . . . J, . . (J . I . . ~ . . I . . . .. . z 0 . . '" '" . 0:: 0::+ ' U '" '" . '"' . < . Z .- "" '" . "" 0:: ,. 0 . . '" . '" ;> . "" '" u '" .. 0:: . . . . .. . I M!CHELE L. DONOVAN, Plaintiff IN THE COURT OF COMMON PL=~S OF CUMBE?I,;..ND COUNTY, PE."lNSy:,7AJ.\!I.~ Vs. NO, 00 - 892 C!V:~ ~~~~ P. QONOVAJ.\!, Defenda.."lt IN QIVORCE TSE M..;;'STSR: Todav is We~~es~=v Ma-~~?q ... .. ---' -... .....'--- -..../ 2001. Counsel have requested tha~ we have anc~her conference ~ith the parties in an effort to work out the cu~sc~~di~g economic issues, which is the reason for this meecing. This action was commenced by t:.~e filing of a divorce complaint on February 15, 2000, raising grounds for divorce of irretrievable breakdown of the marriage and indignities and the economic claims of equitable distribution, alimony, and counsel fees and expenses. With respect to grounds for divorce, the parties previously signed and filed affidavits of consenc and waivers of notice of intention to request ent~1 of divorce decree which were filed with the Prothonotary en March :4, 2001. The=efore, the divorce can be co~cludec u~de= Sec~~o~ 3301(c)of the ~ornestic Relacions Code, The parcies and cC~"lsel are going ~o place on ~ne record a memorandum of understa.."lding setcing forth ~heir intentions regarding the resolution of the economic iss~es which will requi=e some involvement by lending ~~stitut~ons to accomplish the pl~~ thac the parties want to pu~ into place. "r ilMiliW.',: Mr. HcKi.'"1ight. MR., ~cKNIGHT: ~~e ~0110W;-~ ,- ~~ --- - -. ~--~ _~ ~4~e u~derst~~ding of che parcies regarding the ac=;eme~t chac they have reached and are attempting to implement, MEMORANDUM OF UNDERSTANDING 1. ~usband will convey his inte=esc in c~e -~~: es~a~e located ac 233 Souths ide Drive, Newville, Per:_sy:v~~ia, ~o wi=e contingent upon her refin~'"1cing the fir5~ ~crtgage Nith M&~ Bank into he= name. 2. From this point forward, wife shall be solely responsible for payment of the mortgage due and owing to M&T Ba.'1.k. . 3. Husband shall, from this point forward. assume responsibility for making the Beneficial payments and upon receipt of a commitment letter from wife regarding the first mortgage, will then obtain a refinancing of the Seneficial second mortgage into his name alone. 4. Husband will also payoff the truck loar- which is currently in both names for his Ford Ra.~ger to ?ord Motor Credit and wife agrees to sign over title of the Ford Ranger to the husband. 5 . Wife shall assume sole responsibility the Sears and Visa charge cards a.~d shall a.~y responsibility for payments thereon. fer the pa1'111ent inda~ify husband of for 6. Upon the receipt of the commitment let~er from the i~scitu~ion refin~~cing the first mortgage ~~d a5 cart of the refinancing of the Beneficial loan, husband wi:: also oota~n an additional $1,200,00 which he will pay over ~o the wife as consideration for this settlement. 7. The Darties will maintain ar.c retain so:e ticle to, all _I'"' the property that they each have in their own ~ossession a.~d that includes the wife's Escort which is her sole property, all of the household furnishings which she has, a.~d each party will keep their own checking accounts and savings accounts in their own name. 8. Each party waives any right, citle, ~~d interest in the retirement proceeds of the other party. , -, 9. Each party agrees to sign any docw~ents Nhich need to be signed to facilitate the implementation of this ma~orandw~ of u.~derstanding. \ r 10. Each party will be responsible for any ~~d all obligaeions associated with their refinancing, whether cnac be costs of recording of the deed, sales tax, registration coses associated with the vehicles or the mobile home, ~~d similar coses. THE ~~STER: Parties and co~~sel are going to return later today to review the memorandum 0= unde~st~ding and to sign affirming the understanding with respect to the procedures to be employed in resolving the economic issues in this case. riffie or Plaintiff ':? /;Nil c , IDate ,\',,~ ,~ \.,\ \.).\ -: "7 '-- ""~~ ~ ~:.,\.__ Michele L. Do~ Plaintiff ~~0un-~ Hank P. Donovan De:end.ar:~ ,~ ;;G:, ''''''-=l~~ =,-"-',,. ~'"IlI~'lIW (') a C~ c ~11 ~: 0 -0 OJ C) --,''1 nlfT' ---I p :Z-:-::J:} 1'0 -,~ I.T1 Z r rUt CO,):~:: C~ " .'. <) r~;.cJ - , (? -~ 1) 0_ - ,;:..'"'>C-) - , C~,' ?:..C..;'j r:? CJ ~ ! J Pc ,-J z :I7 :< (::> -< - " MICHELE L. DONOVAN VB. Plaintiff HANKP,DONOVAN DATE: ~ ~~Ol --- Defendant n , ~.r_"" \ ; IN THE COURT OF CUMBERLAND COUNT~OMMON PLEAS OF , PENNSYLVANIA CIVIL ACTION - LAW NO. 00 - 892 CIVIL 19 IN DIVORCE STATUS SHEET ACTIVITIES: . L't~' , ...~,..I...... . J"......~J~-{.. t.t G~~ ~,~~ ,~,~,,'. .~ . "~' -II ~' 'rn'ltUtr~ L.DimWtfYJ ~ Rin'YItl ftf : VB. 11;rf)}l P ))LJY1OV /h1 ~~ ...- , ~, " - ~-~ IN, THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO:'lJij)- gqt CIVIL 19 IN DIVORCE STATUS SHEET ~ ftb ./ty '6) <r, I (y (1-<) O( .. - a.m' ...t.~ I ()-. CO t. . r11 . ?--J.9,,61;f"t \:61) l-'W" . A~d~,rfc..._.~-:n-..~ "V\A.w1 b-. u..;..p tul ~ ~ ~*,~.("J-<.;"LUi ~ ~/. y,')-b/lf\ 31-z- '6 ('P--t - .......;._.......,__~_""".-'C~'..',,'~N',~' """="_=<<'~-=--_""'..._...,..~"..,'-''''''''''O<....,.._._....___'''''''''*''''''~~,~_.,_... ll~' h~:.JA:" ','I - ~ ~ . , ' . I -~~. , , , ' . ~~~ ~~ ~~,IoiJ" ,- . , 1- " ~i ~ MICHELE L. DONOVAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000 - 892 CIVIL HANK P. DONOVAN, Defendant IN DIVORCE TO: Attorney for Plaintiff~ Bradley L, Griffie , Marcus A. McKnight Attorney for Defendan~ DATE: Thursday, July 6, 2000 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed, OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. . (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. DATE COUNSEL FOR PLAINTIFF COUNSEL FOR DEFENDANT NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. ,,- - ,I ^~.,; , ':$ijlj~', GRIFFIE & ASSOCIATES Auorneys and Counselors At Law Bradley L. Griffie, Esquire Marylou Matas, Esquire ZOO Nol1h Hanover Street CadIsIe, PA 17013 (717) 243-5551 1(800)347-5552 Robin J. Goshorn LegalAssistant Re~to: Carlisle 38 Nol1hMdn Street CbamhenJnnog, PA 17Z01 (717) 267-1350 Fo (717):143-5063 June 20, 2001 E, Robert Elicker, II, Esquire Divorce Master 9 North Hanover Street Carlisle, PA 17013 RE: Donovan v. Donovan No, 2000-892 Dear Mr, Elicker: Please be advised that the parties have implemented all of the terms of the Memorandum of Understanding that we put on the record with you back in March. By copy of this correspondence and subsequent confirmation from Attorney McKnight, which should be forthcoming, we ask that you close the file in this matter and have your appointment vacated, When we receive the notification of the vacating of your appointment, we will file a Praecipe to Transmit the Record and related documents to finalize the divorce. Your input in this matter was of great benefit to the parties and assisted us tremendously in resolving this matter. Your attention is appreciated, BLG/kjl cc: Marcus A. McKnight, III, Esquire Michele L. Donovan ',_ ~h -". "~" H"~"'~~- ,--~",,-,., ."~ _,. ,;" __ I~ I' ,- ,'--' ":--~'~,,"'_ - ,,-, -,' """,,-'_')_ "'" ~'>'''','''''''''O''- '- , 7_~ '- 0' ~, . . LAW OFFICES IRWIN McKNIGHT & HUGHES ROGER B. IRWIN MARCUSA. McKNIGHT. III JAMES D. HUGHES REBECCA R. HUGHES MARK D. SCHWARTZ DOUGLAS G. MILLER WEST POMFRET PROFESSIONAL BUILDING 60 WEST POMFRET STREET CARLISLE, PENNSYLVANIA 17013-3222 (717) 249-2353 FAX (717) 249-6354 E-MAIL: IMHLAW@SUPERNET.COM HAROLD S, IRWIN (1925-1977) HAROLD S. IRWIN, JR. (1954-1986) IRWIN, IRWIN & IRWIN (1956-1986) IRWIN, IRWIN &McKNIGHT (1986-1994) IRWIN. McKNIGHT&HUGHES (1994- ) June 25, 2001 E. Robert Elicker, II, Esquire Divorce Master 9 North Hanover Street Carlisle, P A 17013 Re: Donovan v. Donovan No. 2000-892 Dear Mr, Elicker: This letter is to confirm that the parties have implemented the terms of the Memorandum of Understanding put on the record in March, Upon closing the file and vacating your appointment, we will proceed with finalizing the divorce, Thank you for your assistance in this matter. Very truly yours, IRWIN, MAMlmln cc: Mr, Hank p, Donovan Bradley L. Griffie, Esq, ~ MICHELE L. DONOVAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 00 - 892 CIVIL HANK P. DONOVAN, Defendant IN DIVORCE NOTICE OF PRE-HEARING CONFERENCE TO: Bradley L. Griffie , Attorney for Plaintiff Marcus A. McKnight, III , Attorney for Defendant A pre-hearing conference has been scheduled at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 12th day of February, 2001, at 9:30 p.m., at which time we will review the pre-trial statements previously filed by counsel, define issues, identify witnesses, explore the possibility of settlement and, if necessary, schedule a hearing. Very truly yours, Date of Notice: 12/11/00 E. Robert Elicker, II Divorce Master Bradley L, Griffie, Attorney for Plaintiff, has not filed a pre-trial statement as of the date of this notice. Marcus A, McKnight, III, Attorney for Defendant, filed a pre-trial statement on November 22, 2000. "",- ~ ''''1 i'1~ lilill... " I,;..-~ , - ~,i GRIFFIE & ASSOCIATES Attorneys and Counselors At Law Bradley L. Griffie, Esquire Marylou Matas, Esquire 200 North Hanover Street CariIoIe, PA 17013 (717) 243-5551 1(800)347-5552 Rob.in J. Goshorn LegalA"istant Reply to: CarllsIe December 21,2000 38 North MaIn _ Chamhenhurg, PA 17101 (717) 267-1350 F.. (717) 243-5063 E, Robert Elicker, Esquire Office of the Divorce Master 9 North Hanover Street Carlisle, PA 17013 RE: Donovan vs. Donovan Dear Mr. Elicker: Mr. McKnight and I have recently received notification that a support appeal hearing in another matter where he and I are both involved has been scheduled for the same date as the pre-,trial,coliference in the above captioned action; that is, Monday, February 12, 2001 at 9:00 a.m, The support appeal hearing was previously continued and needs to be resolved. Because of this, I have suggested to Mr, McKnight that we consider continuing the Donovan pre-,trial to another time and date, I would appreciate if you could set aside another morning or afternoon close to February 12th that will allow us to conduct the Donovan pre-,tria1, presuming Mr. McKnight agrees with my request to continue that matter, I felt the earlier we set aside some time, the least delay will occur in reschedu1ing that matter, I will let you know as soon as I hear from Mr. McKnight or possibly he will correspond with you directly, BLGlIjg cc:" Michele L;Donovan Marcus A. McKnight, ill,' Esquire ~._------=-'.""''-'''''''''''''''''''''''-'''''''''-- ~- 1Iill!~~"_~I!I!fI8i11l!.'JiIiJ ('1 fJ~ ~'I:!<~"~'''-'''_"".;)ilJ>~",''_I,",'SIlI.""{,,,,"I~''''';,,--- ~o :'jM~i<l!_ M~ -z....t II' ( , erv ----------..----- c<(1i. Gj~3 ,I _ --''''''''- - J tJ. J > ;>-(1'0 _,__._,__, I ----~~~--\)~ - -, ( (l A ('\ ~_ 'ii, , , .1 U...N!... -~':-fJ&-;r- 4 : i ---IT! 0<N u,f GvvI (; CAA D (J~IA q a~ k (3ob i.o '\ " ~,.~ ~~f~~-~_=~ I'"U ~..-.." ."l u.- ~ ~ (4/ d---,---- ~~i I'i !:! ;'! --~-l I , , ; -+- -.k ~ vJ. h..o ( t\.. _ie:.. s _-7=E0~ ~ ~f~~ -~ -rJ'l tJ I , ~- 11. / ( " w /;4, J4^, ~~_ + '-1l t- "( 4$-':) ( c:JL.f- -- ~-cb<-~'L'ft'-1I;l.Q ___ _ _=-- -- m _'.'m...'_.."' J' lIi ~ '~ w'_ --'.' : - ---~:--, -" ,,- ,-:.-,---~,,:, ,,- -- . ,-- -:::;.I"'~ "--:;:~~."~~, ""_ -,',"", ~'o;;';,_'__::"F__ :'.'" - -":':'~'0~j_1 4 , OFFICE OF DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEAS 9 North Hanover Street Carlisle, PA 17013 (717) 240-6535 E. Robert Elicker, II Divorce Master Traci .to Colyer Office Manager/Reporter West Shore 697-0371 Ex\. 6535 October 25, 2000 Bradley L. Griffie, Esquire GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 Marcus A, McKnight, III, Esquire IRWIN, McKNIGHT & HUGHES 60 West Pomfret Street Carlisle, PA 17013 RE: Michele L. Donovan vs. Hank P. Donovan No, 00 - 892 Civil In Divorce Dear Mr. Griffie and Mr, McKnight: I am writing in response to Mr. Griffie's letter of October 24, 2000. I am going to proceed on the assumption that discovery is complete and that no discovery issues will be raised which would impede the progress of this case. Mr. Griffie has certified that discovery is complete; Mr. McKnight indicated that he would propound interrogatories by the end of July 2000. A divorce complaint was filed on February 15, 2000, raising grounds for divorce of irretrievable breakdown of the marriage and indignities. The complaint also raised the economic claims of equitable distribution, alimony, alimony pendente lite, and counsel fees and expenses. -",' '^ ' ~ I -,. " " -~^ --"', <'~~ i Mr, Griffie and Mr. McKnight, Attorneys at Law 25 October 2000 Paae 2 I am going to assume that grounds for divorce are not an issue and that the parties will either sign affidavits of consent or have been separated for a period in excess of two years, If, however, there is a problem with proceeding on no-fault grounds, please advise immediately and I will schedule a hearing on the alternative grounds of indignities, In accordance with P,R.C,P. 1920.33(b) I am directing each counsel to file a pretrial statement on or before Wednesday, November 22, 2000. Upon receipt of the pretrial statements, I will immediately schedule a pre- hearing conference with counsel to discuss the issues and, if necessary, schedule a hearing. Very truly yours, E. Robert Elicker, n Divorce Master NOTE: Sanctions for failure to file pretrial statements are set forth in subdivision (c) and (d) of Rule 1920.33. THE ORIGINAL PRETRIAL STATEMENT SHOULD BE FILED IN THE MASTER'S OFFICE AND A COPY SENT DIRECTLY TO OPPOSING COUNSEL. FAILURE TO FILE PRETRIAL STATEMENTS AS DIRECTED BY THE MASTER MAY RESUL TIN THE MASTER'S APPOINTMENT BEING V ACA TED. , ,','. 1,.-,---',,,, '., " .~ ~ihJ- "~- , ;,,;. MICHELE L. DONOVAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 00 - 892 CIVIL HANK P. DONOVAN, Defendant IN DIVORCE RESCHEDULED NOTICE OF PRE-HEARING CONFERENCE TO: Bradley L. Griffie , Attorney for Plaintiff Marcus A. McKnight, III , Attorney for Defendant A pre-hearing conference has been scheduled at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 23rd day of February, 2001, at 9:30 p.m., at which time we will review the pre-trial statements previously filed by counsel, define issues, identify witnesses, explore the possibility of settlement and, if necessary, schedule a hearing. Very truly yours, Date of Notice: 1/5/00 E. Robert Elicker, II Divorce Master ','; ~~"', GRIFFIE & ASSOCIATES Attorneys and Counselors At Law Bradley L. Griffie, Esquire Marylou Matas, Esquire zoo Norlb Hanover Street CarlIsle, PA 17013 (717) 243-5551 1(800)347-5552 Robin J. Goshorn LegalAasistant Reply to: CarlIsle 38 Norlb MaIn Street Chambenburg, PA 17201 (717) 267-1350 Fu(717)243-5063 October 24, 2000 E, Robert Elicker, II, Esquire Office of the Master in Divorce 9 North Hanover Street Carlisle, P A 17013 RE: Donovan v, Donovan No, 2000-892 (In Divorce) Dear Mr, Elicker: Several months ago a Petition for the Appointment of a Master was filed in the above captioned action, Upon your appointment and the forwarding of your notice to our office, I notified you that discovery was complete as far as we were concerned and we were ready to proceed in this case. I recently became aware from your office that apparently Mr. McKnight, who represents the Hank p, Donovan, indicated to your office that discovery was not yet completed and an interrogatories were being prepared, I understand this notification was given to you back in July, We have not been presented with any type of discovery from Mr, McKnight. Since three months have passed since he suggested discovery was forthcoming, I submit discovery is complete and there should be no further delays in this case, With this in mind, I would greatly appreciate if you could schedule a Pre-Trial Conference with counsel in this case so that we can begin advancing the case to a final conclusion through your assistance, BLG/kjl cc: Michele L. Donovan Marcus A, McKnight, III, Esquire '"~. "c ~ ~^ "",,_.,,-~ , """';'''-o",~ "_'""""...'F"'" , -,,- ,: '_.~'il' ;',,{J,,~ -,",;;,,~., _.-&';~",.c". LAW OFFICES IRWIN McKNIGHT & HUGHES ROGERB. IRWIN MARCUS A. McKNIGHT. III JAMES D. HUGHES REBECCA R. HUGHES MARK D. SCHWARTZ DOUGLAS G, MILLER WEST POMFRET PROFESSIONAL BUILDING 60 WEST POMFRET STREET CARLISLE, PENNSYLVANIA 17013-3222 (717) 249-2353 FAX (717) 249-6354 E-MAIL: IMHLAW@SUPERNET.COM HAROWS, IRWIN (1925,/977) HAROLD S. IRWIN, JR. (1954-1986) IRWIN, IRWIN & IRWIN (/956-1986) IRWIN, IRWIN &McKNIGHT (1986-1994) IRWIN, McKNIGHT & HUGHES (1994- ) July 21,2000 E, Robert Elicker, Divorce Master Office of the Divorce Master 13 North Hanover Street Carlisle, PA 17013 Re: Michele L. Donovan v. Hank P. Donovan 2000-892 Dear Bob: I have enclosed the Certification which you requested. I expect to serve the plaintiff with Interrogatories by the end of this month. Please contact me if you have any questions. Very truly yours, MAMtmln Enc!. cc: Mr. Hank p, Donovan ~ . ~~ . ~ . ' ~I , , , ~-I MICHELE L. DONOVAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000 - 892 CIVIL HANK P. DONOVAN, Defendant IN DIVORCE TO: Bradley L. Griffie , Attorney for Plaintiff Marcus A. McKnight Attorney for Defendant DATE: Thursday, July 6, 2000 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. 1. The defendant needs information regarding wife's financial accounts, life insurance policies, her retirement, and the value of her vehicles and the marital real estate and the personal property of the parties. -~ ~I -,,', '~' ", .'-.. " { (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. We will be serving Interrogatories by the end of the month. JULY 21, 2000 DATE ( ) (XX ) NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION, AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. '~kji """~--;r' ~I~~~~~~'_~'''''''-' -- , :.IIIlI." "'''''I''='~ ";"um...._;w "",' ~- ~~~~ P. \\'" '7'!""),' ',' ~,;,~ ~ . ~ ,J JUL 07 2000 d'" --"'lIiII.' , ",' ""''''Il! .fllM... M,.".w...v~ ' rt: U\'\rV.~lll~ mU\t'{.:.{J~;\~ ~ ~;,~<.,H,,~ ~, ,'" ., , .... I - ~, '11 V 200 North Hanover Street Carllsle, P A 17013 (717) 243-5551 1(800) 347-5552 FAX (717) 243-5063 GRIFFIE & ASSOCIATES Attorneys and Counselors At Law Bradley L. Griffie, Esquire 38 North Main Street Chambersburg, PA 17201 (717) 267-1350 Reply to: Carlisle Robin J. Goshorn Legal Assistant July 12, 2000 E, Robert Elicker, II, Esquire 9 North Hanover Street Carlisle, P A 17013 RE: Donovan v. Donovan No, 2000-892 Civil Dear Mr, Elicker: Enclosed herein please find our certification on behalf of Michele L. Donovan that discover is complete in the above captioned action. Your attention is appreciated, BLG/kjl Enclosure cc: Michele L. Donovan Marcus A. McKnight, III, Esquire 1iIIIiiilI~"'- ~~I , , "".:.~ , -'*""- . . '- MICHELE L. DONOVAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000 - 892 CIVIL HANK P. DONOVAN, Defendant IN DIVORCE TO: Bradley L. Griffie Attorney for Plaintiff Marcus A. McKnight , Attorney for Defendant DATE: Thursday, July 6, 2000 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is r hat is not complete in order t are the case for trial and indica e her there are any outstanding i gatories or discovery motions. ,~I~.........,-~ L ,1-- >,-,-' "~ ! . I ''''''- (b) Provide approximate when discovery will be complete and' 'cate what action is being taken to co e discovery. 7h/od , 'DATE C><; ( ) NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A P~~TY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. ~i , 'f '..", MICHELE L. DONOVAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, CIVIL ACTION - LAW ~~ : NO, 2000-'902 CIVIL TERM : IN DIVORCE HANK p, DONOVAN, Defendant CERTIFICATE OF SERVICE I, Bradley L. Griffie, Esquire, hereby certifY that I did, the 12th day of May, 2000, cause a true and attested copy of a Petition for Exclusive Possession and resulting Order of Court to be served upon the Defendant, Hank p, Donovan, by serving his attorney of record, Marcus A. McKnight, III, Esquire, by first class mail, postage prepaid, at the following address: Marcus A. McKnight, III, Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 DATE: .5- /:J.d)() . Ie, Esquire F & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 '~~-" ~'-' -, ~1~P"~ '"~ :., .,=_" ,~,~..O/< " _,=,._~ -~'..,."',--""' 'j"......'" .. ...,,' ,.' . , ",' " "'.'"," "", , I.I"'~ (') 0 C- O 0 lJ$: :Jl: ...., "'Q"J :;:1 nl_'"T" """ Z' . ~" :1) -< :ci'i::rJ zr-- f- ~5': t\..,) .;j(T1 ,JJ,? <C3 r) i:J :::.;0 ):>,--. ''1--r 2:'-:..;,) 3: o:ri ,]:;CJ r- ~ 70 ~ OITI - :;;! W ~ .I , "tel I " .'ut GRIFFIE & ASSOCIATES Attorneys and Counselors At Law Bradley L. Griffie, Esquire Reply to: CarlWe 200 Norlh Hanover Street CarlIsle, PA 17013 (717) 243-5551 1(800)347-5552 38 NorIhMaln Street Cbambenburg, PA 17101 (717) 267-1350 F.. (717) 243-5063 Marylou Matas, Esquire Robin J. Goshorn LegalA88istant January 25,2001 E, Robert Elicker, II, Esquire Divorce Master 9 North Hanover Street Carlisle, PA 17013 RE: Donovan v, Donovan No, 2000-892 Civil Term Dear Mr, Elicker: Enclosed herein please find a Pre-Trial Memorandum, an Inventory and Appraisement, and an Income and Expense Statement for my client, Michele L. Donovan, This information is being provided pursuant to your prior directive and in consideration of the Pre-Trial Conference scheduled for February 23, 2001. You will see that we have secured copies of classified ads, some pictures, and similar informatioQ to use as exhibits that caused us to have some delay in providing this information to you, I apologize for that delay, but based upon the fact that it will be another month until the Pre-Trial Conference, I do not think anyone is disadvantaged, Your attention is appreciated, BLG/kjl Enclosures cc: Marcus A. McKnight, III, Esquire Michele L. Donovan - ~ GRIFFIE & ASSOCIATES Attorneys and Counselors At Law Bradley L. Griffie, Esquire Marylou Matas, Esquire 200 North Hanover street CodIsI.. PA 17013 (717) 243-5551 1(800)347-5552 Robin J. Goshorn LegalAssistant Reply to: Carlisle 38 NoI1h Main Street Chambenlmrg, PA 17201 (717) 267-1350 Fax (717) 243-5063 January 11, 2001 E, Robert Elicker, II, Esquire Divorce Master's Office 9 North Hanover Street Carlisle, P A 17013 RE: Donovan v. Donovan No, 2000-892 Civil Term Dear Mr. Elicker: I previously corresponded with you and advised you of a conflict that I have in my schedule, which I believe Mr, McKnight likewise has in the scheduling of the Pre-Hearing Conference in the above captioned matter, I understand the Pre-Hearing Conference has been rescheduled for February 23, 2001, at 9:30 a,m, Your cooperation in rescheduling this matter is appreciated, Very truly yours, BLGlkjl cc: Marcus A, McKnight, III, Esquire Michele L. Donovan ~ I, _<;"'. ~'-~ .'~~ 'h,-' ", >"" .-, ",_,C__, -o..~ ~'i -<'-' -~'''J'' LAW OFFICES IRWIN McKNIGHT & HUGHES ROGER B. IRWIN MARCUS A. McKNIGHT, III JAMES D, HUGHES REBECCA 11., HUGHES MARK D, SCHWARTZ DOUGLAS G. MILLER WEST POMFRET PROFESSIONAL BUILDING 60 WEST POMFRET STREET CARLISLE, PENNSYLVANIA 17013-3222 (717) 249-2353 FAX (717) 249-6354 E.MAIL: IMHLAW@SUPERNET.COM HAROLDS IRWIN (1925-1977) HAROLD s, IRWIN, JR (1954-1986) IRWIN. IRWIN &IRWIN (1956-1986) IRWIN, IRWIN &McKNIGHT (1986-1994) IRWIN. McKNIGHT&HUGHES (1994- ) November 22,2000 E. Robert Elicker, II, Divorce Master Office of Divorce Master 13 North Hanover Street Carlisle, PA 17013 Re: Hank P. Donovan v. Michele L. Donovan Dear Bob: I have enclosed an original and one copy of the Pre-Trial Memorandum of my client, Hank P. Donovan. I have sent a copy by mail to Bradley L. Griffie, Esq., attorney for Michele L. Donovan, Please schedule this case for a Pre-Hearing Conference. Very truly yours, / MAMlmln Enc!. cc: Bradley L. Griffie, Esq. Mr. Hank P. Donovan "", .Mttllill~ MICHELE L. DONOVAN, PlaintifflPetitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA v, CIVIL ACTION - LAW HANK P. DONOVAN, : NO, 2000-892 CIVIL TERM DefendantfRespondent : IN DIVORCE ORDER OF COURT AND NOW this ~ day of M? , 2000, upon presentation and consideration of the within Petition a Rule is hereby issued upon the Defendant, Hank p, Donovan, to show cause, if any he has, as to why the Plaintiff, Michele L. Donovan, shall not be granted exclusive possession of the former marital residence pending a resolution of the economic aspects of the within divorce case, Rule returnable at a hearing to be held on wd. I lJ "" III t.. ,2000, at It): ..3 () o'clock /I ,m, in courtroom number , the /Aay of of the Cumberland County Courthouse, Carlisle, Pennsylvania, Petitioner is granted exclusive possession pending the hearing in this matter, ~ .5-16 -00 RKS Bradley L. Griffie, Esquire Attorney for Plaintiff o 0 I _ \iarcus A. McKnight, III, Esquire t "q' '> V": ~ tJ Attorney for Defendant 9 Cll)lf'\\~ I cc: ,- \:,-", ~,~,II!",; ,= J~P")'l , ".""",Im,.""_~~, , '. ,~, .,. >~ FllFO...l"1L'1;:ICC OF - ......I-r~1 f , TI-!': !1HOTHONOTAflY 00 ~1~,Y -9 PI'~ ?; ,., It;... t CUMBEHLh~O r'nu'lJTY PENNSYL\f,!\N:!1 I ", """,.,IJ~ ,'"~ ,~~,"*"!51!~Ii,JW)!iiW~~~~1W<II~~lll~ J......... ~I - '-~-'''i'n>;'1 MICHELE L. DONOVAN, Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW HANK p, DONOVAN, NO, 2000-892 CIVIL TERM DefendantfRespondent : IN DIVORCE PETITION FOR EXCLUSIVE POSSESSION AND NOW comes Petitioner, Michele L. Donovan, by and through her counsel of records, Bradley L. Griffie, Esquire, and petitions the Court as follows: 1, Your Petitioner is the above named Plaintiff, an adult individual currently residing at 233 Southside Drive, Newville, Cumberland County, Peunsylvania, 2, Your Respondent is the above named Defendant, an adult individual currently residing at 11 Grove Road, Carlisle, Cumberland County, Pennsylvania, 3. Petitioner is represented by Bradley L. Griffie, Esquire, and the law fIrm of Griffie & Associates and Respondent is represented by Marcus A, McKnight, III, Esquire, and the law firm of Irwin, McKnight & Hughes, 4, The parties separated on several occasions in 1999 with Respondent vacating the marital residence where Petitioner and her two minor children have continued to reside, 5, On several occasions when Respondent vacated the marital residence he moved in with his girlfriend with whom he was having an affair while married to Petitioner. 6, During this period of time and at the time of the final separation in July 1999, Petitioner was caring for the parties five year old son and was approximately six months pregnant with the parties second child, - .1 ~d - 7, Since the parties separation, Petitioner has maintained all debts on the former marital residence including a first mortgage and a second mortgage as well as utility payments and the like, 8, Petitioner has been required to seek gainful employment and did so promptly after the birth of her second child in order to maintain the home for herself and her children as well as maintain other joint debt in current status, 9, Respondent's financial assistance relative to joint debts and particularly relative to the payment of the Debt associated with the former marital residence has been limited to his Court ordered child support obligation. 10. Petitioner must maintain full time employment if she is going to be able to meet her financial needs and the financial needs of her children, 11, Respondent has recently made comments and threats to the effect that he is going to return to the former marital residence and remove items of personal property from the former marital residence, 12, In the recent past, Respondent has demanded that he be provided with possession of certain items of personal property that he either deems to be non-marital property or deems to be marital property that should be in his possession. 13, Both parties are engaged in negotiations in an attempt to resolve not only the divorce proceedings, but also the collateral issues of equitable distribution and other economic aspects ofthe case, . '_~i -- ~" "- .' ~~~'" 14, Despite the parties ongoing limited negotiations relative to property, no agreement was reached relative to the distribution of personal property. 15, Despite the fact no agreement was reached Respondent, his father, his girlfriend's step-father, and several unknown males came to Petitioner's residence on Monday evening, May 1, 2000, and removed a wide array of personal property from the residence, all of which personal property has not been appraised and is considered marital property by Petitioner. Comments made by Respondent and the group of gentleman who accompanied him on the property have led Petitioner to believe that Respondent will return to the property to remove additional items of personal property from the residence, Petitioner has no means of protecting her home including her and her children's personal property while she is at work or otherwise, 16, Petitioner was assaulted by Respondent when he was removing marital property from the marital residence on Monday evening, May 1,2000, Efforts to gain cooperation in this regard from Respondent and from Respondent's counsel have been fruitless, 17. Respondent resides with his girlfriend at the address set forth above, 18, Petitioner has made no attempts nor will she make any attempts to enter upon the property where Respondent resides thereby granting him the quiet enjoyment of his home, 19. Petitioner has requested of Respondent that he agree to enter into a stipulation to provide for Petitioner to maintain exclusive possession of her residence so that she can likewise have the quiet enjoyment of her home, - ..."'--, 20, To date, Respondent has failed to consent to the entry of an Order providing for exclusive possession of the marital residence to Petitioner, 21, Petitioner is concerned daily relative to what she may find when she returns to her home from her place of employment and has great concern that Respondent may return to the residence and remove personal property item, which will then not be available to be appraised, valued, or discussed in negotiations of property distribution, 22, Petitioner has seen Respondent in Petitioner's neighborhood on other occasions for no apparent reason other than what appears to be surveillance on Petitioner and the residence. 23, Respondent and his counsel ofrecord do not concur in this request. WHEREFORE, Petitioner requests your Honorable Court to enter a Rule upon Respondent to ~how cause, if any he has, as to why Petitioner shall not be granted exclusive possession of the marital residence pending final resolution of the Divorce case, Respectfully submitted, , e, Esquire for intiffIPetitioner GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, P A 17013 (717) 243-5551 (800) 347-5552 '- ~~ 1,--. - , ,~:...~ -\ ""e." VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C,S, Section 4904, relating to unsworn falsifications to authorities, DATE: S" ~- rc"\ '-- ~ ""-"'-"- "-- --L~ ~ r-v--.., MICHELE L. DONOVAN, Plaintiff/Petitioner -",,~--~ j;, ~"""'lii~!l!:~d__.';1 !i-~;;r.'Wij~\,j~_.<J~ ,~~ iIi .''II._~-_i " .'.,--. U~'~-'- ,,-~, 0 0 6 ~- C) -'T1 '---,. :::! ?;:, :r:- ulD "" "-oJ r'fll'1'j -< i-'-l1p- Z-J I ..,.....to zt; i:~6 U),",~- C,.o) --< /..-..- r:::C) ~:B -0 -'- ~o ::ii: <;].0 -rn reO .c.:: ~ ;;>c:: ~ ~ ~ ~ U1 "~ . d_ - ~"~" MICHELE L. DONOVAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs, : CIVIL ACTION - LAW : NO, 2000-892 CIVIL TERM HANKP, DONOVAN, Defendant, : IN DIVORCE ORDER APPOINTING AND NOW, this Z 2 ",cl.day of STER 2000, r;~Ql..~J:I....1J- , Esquire, is appointed Master with respect to the following claims: cJ1 BY THE COURT, 1. 0, r) Ii 1\1 r,., V'-'\...\ (,v :":: f)! C'Jf"'.' ",,' ,",......,. ' \ '1''''- ". ',,~I ' ,-,' I " , 'I" / ~' 'v l' L;'~.J ,,_,"',. \J...,I .j,jl~ ~ I I PENNSYLV/\!\lJA ,~---- JH 1,~ .".". ,OOfl>.~~~ ~ m_ ,~","",I!!~ ~""'", _ i~ ~; """-",,",,,",_,.#I;\I;'!1Ifi"I_~1Nf,.~,1f 1,.-, ' -- ~ ~, ," ,.. ': c - MICHELE L. DONOVAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. CIVIL ACTION - LAW : NO, 2000-892 CIVIL TERM HANK p, DONOVAN, Defendant, : IN DIVORCE MOTION FOR APPOINTMENT OF MASTER AND NOW, comes Plaintiff, Michele L. Donovan, by and through her attorney of record, Bradley L. Griffie, Esquire, and moves the Court to appoint a Master with respect to the following claims: (X) Divorce ( ) Annulment (X) Alimony (XI) Costs and Expenses (X) Distribution of Property ( ) Support (X) Counsel Fees (X) Alimony Pendente Lite and in support of her Motion states: 1, Discovery is complete as to the claims for which the appointment of a Master is requested, 2, The Defendant has appeared in this action by his attorney, Marcus A. McKnight, III, Esquire. 3, The Statutory grounds for divorce are 23 Pa,C,S.A. ~3301(c) and ~3301(A)(6), 4, This action is contested with respect to the claims: All of the above except divorce, 5, The action does not involve complex issues oflaw or fact. 6, The hearing is expected to take one day. - . 7. Additional information, ifany, relevant to the motion: None, Respectfully submitted, GRIFFIE & ASSOCIATES o ..........'._h '~"~I - ili.ili,~s~~r""",r , ~ '", " " '. "~,,~ '''~~ ~LL rO C, Z -r:,}(/i ITI", Z::~i 2(" ~S: Zt) PC: Z ::;! o CJ L_ ~~;; C) -n -; N o 'D l-l'1 ,-:-) c; "0 =+~ ~:i r-~~ ,-, -I 1> ::~ -.1"" lJ' ~" ~~. "~"' ~'" '" " tollill.,;.,;,' MICHELE L. DONOVAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. CIVIL ACTION - LAW ~.1. : NO, 2000-9tl1 CIVIL TERM : IN DIVORCE HANKP.DONOVAN, Defendant CERTIFICA TE OF SERVICE I, Bradley L. Griffie, Esquire, hereby certity that I did, the 26th day of July, 2000, cause a true and attested copy of a Notice to Plead and Answer to Rule to Show Cause and New Matter to be served upon the Defendant, Hank p, Donovan, by serving his attorney of record, Marcus A. McKnight, III, Esquire, by first class mail, postage prepaid, at the following address: Marcus A. McKnight, III, Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 DATE: 7(2<. I ()~ ~11!iIiliilo -- ~ ~~>'Wili!lljl;~~t"""WJil_'il_~~I\,N~~~IIJilII~tldIIlIlI!I ~ - ; , . ~"- ~, ,I ~~ ~ J:,.-~- C CJ (::::;. c c:} <~ v ;~;-: r;--1 q -~ ~- L.::' j--' ;--,) U;! m' eJ , , ~ \~.- " C) ;? '-''0 ::.;; ( -, ':;~ C) () <- ,on )> (::'~ (:) Z ::::> :y;:! -j ~a -<. (J1 -< '._~'.i -<'J' , -~",^- _"",_"', ,,, '. ",c; ~" ,~,-, . <, MICHELE L. DONOVAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 00-0892 CIVIL TERM HANK P. DONOVAN, Defendant IN DIVORCE IN RE: AGREEMENT OF THE PARTIES ORDER OF COURT AND NOW, this 14th day of June, 2000, by agreement of the parties, it is hereby ordered and directed as follows: 1. Plaintiff is awarded exclusive possession of the marital residence at 233 Southside Drive, Newville, Cumberland County, Pennsylvania. 2. Plaintiff shall timely pay all mortgage payments due on the first mortgage to Keystone Financial. 3. Plaintiff shall see to it that the second mortgage with Beneficial Associates is not allowed to go into foreclosure. If foreclosure proceedings are filed by or on behalf of Beneficial Associates, she shall be deemed to have violated this provision of our order. 4, In the event that Plaintiff fails to comply with paragraphs 2 and 3 above, the marital home shall be immediately listed for sale at a mutually agreeable price with a mutually agreeable realtor. If the parties cannot agree upon a realtor or a price, the Court '" "~ . _~,.- 'h..' C ^ t o~'I.. __~ ' _ "-,~,__.'- -",'ri_';'".',- "--,'''-' , '. shall, upon petition, resolve those issues, By the Court, Edward E. G~'~ t-/5-00 1?KS Bradley Griffie, Esquire For the Plaintiff Marcus McKnight, Esquire For the Defendant :mae '!1 0_. f' ,"-, ,nrFlCE -':~ -(""I"~^""Y )' --:,,}l': )Ir\ll 00 JU.J IS i\i1 8: :is '-" ':'----.." ,', :~\ '-'I-,i 'N1V ,1,'-:'---:''''-:' /'_"'-'1 , vUUI i 1 V...qVIl,.'~., L,,_ ,j h,l PENNSYLVANiA ,. . '"""""! """'-~ r IT ~l~!lr~~J, ''''''~'-"'1'''' -- ~" ~ ->, ~"~ -"~--~.-.- ,"",>~M~I~ll!~ ~ .- ,,' ~ ,--, I - L~~ 0; MICHELE L. DONOVAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 00 - 892 CIVIL HANK P. DONOVAN, Defendant IN DIVORCE CONFERENCE WITH COUNSEL AND THE PARTIES TO: Bradley L. Griffie Michele L, Donovan , Counsel for Plaintiff , Plaintiff Marcus A. McKnight, III Hank P. Donovan , Counsel for Defendant , Defendant A conference has been scheduled at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 14th day of March, 2001, at 10:00 a.m., with counsel and the parties to discuss the outstanding economic issues to determine if there is a basis of settlement of claims. If issues remain after the conference a hearing will be scheduled at another date. Very truly yours, Date of Notice: February 23, 2001 E. Robert Elicker, II Divorce Master "'0....- ~_, - ~, , lIiiIi1M,,"C_, '(0 ,:7,:::~:- '-':'\,,:,':{>~11 . ,,:)<:1 . ",: : ~ ~:~:.J! '. ," .,-,','.' ,-: ' "'"'''' ~", ::':);::'::-/1:,;>; , ""<,\(j. <: (b '<</) ~D \ \ \L\. ?DY'6-~ Do\\S \S' .-Cf-.-:J:hnJeJ I'VI0/ ~n Se-\:S Ho, Z- Y7, C2-) -\we r<. (hn 18, 3:J ~L . ----.---------. , .-;.",-,,";-7".', ,',:.::,- ):;'~ .iC.> '.',-,'.' :,-:'.'<:?8) , ~; ,....::i~:: ~ ::)':!.n~~ ;::,,, CS' ., ,', ,,-- ,', ,-"""', .....::'::,,:jt~ ""'-....tW' }.;\\~~:; 10 Q.f' w(cd.e.o..kr \, 2.- )-1ux> At('Co(lcL:h ~f\E'..rS Q1., rm(\(~ S~ev:s and Cb'~ <L,< 4 ,~c.R ~s '. ! '.'."~J",, ',~ 5 ~u.lh ~ ~hR. w,+Mrew ~ -+v,f ~~ ~~i~~'G~i:~~11i111i~i.~;~2~11i~1 ~. ~, -- - --;-,", ~i I I . , . MICHELE L. DONOVAN, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2000-892 CIVIL TERM HANK P. DONOVAN, DEFENDANT IN DIVORCE I. MARITAL ASSETS TO BE DIVIDED Item # Prooerty Descriotion Owners Name Date Acquired Value 1. 22 Southside Drive Joint 1995 Original Newville, PA $27,500,00 2. 1996 Ford Ranger Joint (Husband) 09/96 $4,500,00 (Less loan) -4.000,00 $500,00 3, 1995 Ford Escort Joint (Wife) 11195 $4,000.00 4, Household furnishings and appliances All divided 5, Retirement Plan Husband Vested at 114 face value w/Pennsy Supply $575.00 6. Prior retirement acct. Wife $750.00 Pennsylvania Dutch Candies 7. Monumental Life Husband Insurance Co, 8, pru~ential Life Husband Ins rance Co. 9. Insurance Policy Wife ~ I ~' Iiili!\[,j ( .... II. NON-MARITAL ASSETS Item # Property Description Owners Name Date Acauired Value 1. 1973 Volvo Husband Gift 2, 1977 Dodge Truck Husband Pre-Marital 3, 1972 Trailer Husband Pre-Marital Special Construction 4, 1982 Trailer Husband Gift Special Construction 5. 1994 Trailer Husband 07/94 Gift Special Construction 6. Race Car Club Ford Husband Pre-Marital 7. Tools, automobile and Husband Pre-Marital race car parts 2 -- ~I < ,-- lA,,,, . .... III. PROPOSED DISTRIBUTION OF HUSBAND WIFE: 1. Wife retains the marital real estate if she refinances the mortgage and home equity loan into her own name. 2. Wife retains her 1995 Ford Escort, her retirement, insurance policy and all the furniture and appliances. 3. Wife retains all the furniture and appliances. 4. Wife retains her charge card balances which purchased the furniture and appliances. HUSBAND: 1. Husband retains his 1996 Ford Ranger and refinances the auto loan into his own name. 2. Husband retains his life insurance, his pension and personal items. Respectfully submitted, IRWIN, McKNIGHT & HUGHES By: Lj us A. Me . t, III, Esq. 60 est Pomfret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Supreme Court J.D. No. 25476 Attorney for Defendant, Hank P. Donovan Date: February 22,2001 DOCSIFAMILYlDlVORCEIDONOV AN ASSETS 3 ,.,....-. ~--~ - ,-_ _", ~_,,' "I~' ,.". 0_'__' "'~"~"___,,_~._"_"', _"'~__~~. ~" .U~~> _",' ,'" -.-, MICHELE L. DONOVAN, PLAINTIFF N" (f'{. 'J-} '061:- IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2000-892 CIVIL TERM HANK P. DONOVAN, DEFENDANT IN DIVORCE PRE-TRIAL MEMORANDUM AND NOW comes the defendant, Hank P. Donovan, by and through his attorneys, Irwin, McKnight & Hughes, Esquires, and files this Pre-Trial Memorandum as required by Rille 1920.33 of the PA Rilles of Court, setting forth as follows: I. MARITAL ASSETS: A. Real Estate: 1. 233 Southside Drive Newville, Pennsylvania 17241..........$50,000.00 B. Personal Property: 1. Vehicle ofHusband.............................$4,210.00 1996 Ford Pickup Truck 2. Wife's Automobile and Personal Property..............................$15,000.00 II. EXPERT WITNESSES: 1. Real Estate Appraisal if necessary. III. WITNESSES: 1. Hank P. Donovan _ "~M ~.., ." -, , ,,~., '''__.C',." ',' -~, v. .'. " ". 'U'" ,~ ,',I_~ _"'",,' _ ';.--. ..' -,..",~,.~~,,--j ;;,.;.",'<;t;.,_. ."";'", <--~,~.",~~,,, " ",,',H.'- ''-'i IV. EXHIBITS: A. Inventory and Appraisement (See attached) B. Income and Expense Statement will be supplied. (See attached) C. Appraisals as necessary. V. INCOME AND EXPENSES: A. Income and Expense Statement (See attached) VI. PROPOSED RESOLUTION: Husband seeks to have the real estate sold and any outstanding debt paid if Wife is not willing to pay Husband his portion of the equity in the property. Respectfully submitted, IRWIN, McKNIGHT & HUGHES By: L~ Date: November 22, 2000 2 "'~,~, -,. ~-^, .--.~ .. ~" '0 " "-~"-_,,, ,~_.-'__'_ ~"'; O_~',__"~_ _,--",_.. "--,,.,"<',_' ,______._,~."",.___,--, ""--o~,,,' 'I,~';;'v""'="-^'';'"'' --_---ro,'~.'ci- .----~ --"-~'_-,...-'- ".,,'_~_, 'c ,~-_,~,,~,,~- MICHELE L. DONOVAN, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2000-892 CIVIL TERM HANK P. DONOVAN, DEFENDANT IN DIVORCE INVENTORY and APPRAISEMENT of HANK P. DONOVAN L REAL ESTATE 1. Marital Residence 233 Southside Drive Newville, Pennsylvania 17241..................................$50,000.00 II. PERSONAL PROPERTY 1. Vehicle of Husband 1996 Ford Pickup Truck .............................................$4,210.00 2. Wife's Automobile and Personal Property ...............................................$15,000.00 III. PENSIONS AND RETIREMENT 1. Husband's 40 1 (k) ........................................................$2,692.88 IV. DEBT 1. 2. Mortgage - Keystone.................................................$33,000.00 Loan - Beneficial.........................................................$5, 788. 76 TOTAL ASSETS FOR DISTRIBUTION.....................................$33,114.12 Respectfully submitted, Date: November 22, 2000 - ", , , ,.",:.; In the Court of Common Pleas of . CUMBERLAND County. Pennsylvania DOMESTIC RELATIONS P.O. BOX 320,CARLlSLE, PA. 17013 Phone: (717) 240-6225 Fax: (717) 240-6248 Plaintiff Name: Defendant Name: . Docket Number: P ACSES Case Number: Other State ID Number: Please Dote' An <o"",pond""e most iDdDde Ibe PACSES.case Nomber. . Income and Exoense Statement -...-. . . TInS FORM MUST BE FILLED OUT (If you are self-employed or if you are salaried by a business of which you are owner in whole or part, you must also fill out the Supplemental Income Statement which appears on the last page of this income and expense statement. ) INCOME STATEMENT OF HANK P. DONOVAN I verify !hat the statements made in this Income and Expense Statement are true and correct. I understand !hat false statements herein are subject to the criminal. peualties of 18 Pa. C.S. fi 4904; relating to unswom falsification to authorities. d~ t17 // NOVEMBER 20. 2000 ~~~ Date Plaintiff or Defefulant INCOME: Employer PENNSY SUPPLY INC. Address 1001 jJAXTON STREET. P. O. BOX 3331. HARRISBURG. PA 17103 Type of Work Payroll No.lO!i92 Gross Pay per Pay Period $ 570.92 Pay Period (wkly., bi-wkly., etc.) Weekly Itemized Payroll Deductions: Federal Withholding $93.00 Social Security $35.76 Local Wage Tax ~5~85 State Income Tax $r6.15 Retirement $ 5.85 Savings Bonds $ -0- Credit Union $ -0- Life Insurance $ -0- Health Insurance $ 8.50 Other Deductions (specify) FICA MEn $ 8.36 $198.54 Net Pay per Pay Period $ 213.26 Service Type M' Form 1N-008 Worker ID 21205 ~ ~- ~ Income and Expense Statement PACSES Case Number 348100635 --,- OTHER (Fill in Appropriate Column) INCOME WEEK MONTH YEAR Interest $ $ $ Dividends Pension Annuity Social Security Rents Royalties - . ~ Expense Account Gifts Unemployment Compensation Workmen's Compensation IRS Refund Other Other TOTAL $ $ $ TOTAL INCOME $ (Fill in Appropriate Column) EXPENSES WEEK MONTH YEAR Home MongagelRent $ $ 200.00 $ Maintenance Utilities Electric 40.00 Gas Oil <n nn . Telephone 25.00 Page 2 of 6 Form IN-OD8 Worker ID 21205 Service Type M " ~ ~.- -. - _lk-' Income and E.xpense Statement PACSE.S Case Number 348100635 (Fill in Appropriate Column) EXPENSES (continued) WEEK MONTH YEAR Water $ $ $ Sewer Employment Public Transponation $ $ $ Lunch . - . . Taxes Real Estate $ $ $ Personal Propeny 19.19 Income Insurance Homeowners $ $ $ Automobile 48.15 Life Accident Health Other - Automobile Payments $ $ 313.95 $ Fuel 120.00 Repairs on nn Medical Doctor $ $ $ Dentist Onbodontist I. Page 3 of6 Form IN-008 Worker ID 21205 Service Type M \3=__'__ ~"' . . Income and Expense Statement PACSES Case Number 348100635 (Fill in Appropriate Column) EXPENSES (continued) WEEK MONTH YEAR Hospital Medicine Special needs (glasses, braces, onhopedic devices) Education Private School $ $ $ . Parochial School College Religious Personal Clothing $ $ 100.00 $ Food I~n no BarberlHairdresser 20.00 Credit Payments: Credit Card Charge Account Memberships - Loans Credit Union $ $ $ Miscellaneous . . Household Help $ $ $ Child Care . PaperslBookslMagazine 50.00 Entertainment 100.00 . 20.00 Pay TV Vacation ?n.nn II " ,', Ii II I !\ ~!~ :,: , 'Ii 'I, W il: " !i " iii , .I f r 'i l' :i' Page 4 of6 Form IN-008 Worker lD 21205 Service Type M ;,,~.. ~~~ -,~ Income aIid Expense Statement PACSES Case Number 348100635 . . (Fill in Appropriate Column) EXPENSES . (continued) WEEK MONTH YEAR Gifts Legal Fees ~400.00 Charitable Contributions Other Child Suppon Alimony Payments Other .. $ $ $ TOTAL EXPENSES $ $1,691. 29 $ 1'1 '(1 Ii " " , PROPERTY Ownership * DESCRIPrION VALUE OWNED H W J Acct # 110000-00 -7- X Checking Accounts Acctll 186224' $150.00 X ~::;~ H9229::H -?- X Savings Accounts ,<n' nn X Credit Union Slocks/Bonds Real Estate . Other TOTAL $ Coverage * INSURANCE COMPANY POLICY # H W C Hospital BLUE CROSS NCAS 027041009, X Blue Cross Other BLUE SHIELD Medical Blue Shield Other ON DRUGS PCS 0003 X * H - Husband W - Wife C - Combined J - Joint Page 5 of6 Form IN-008 Worker ID 21205 Service Type M . . . ",~ . . . Income and Expense Statement PACSES Case Number 348100635 Coverage .. INSURANCE COMPANY POLICY # H W C Health! Accident.. NCAS -,.- BLUE CROSS BLUE SHIELD Disability IncomeNCAS BLUE CROSS BLUE SHTELD X Dental NCAS BLUE CROSS BLUE SHIELD X Other * H - Husband W - Wife C - Combined J - Joint SUDDIemental Ineome Statement ~ c. This form is to be filled out by a person (1) who operates a business or practices a J.lrofession, or (2) who is a member of a partnership or jOint venture, or (3) who is a shareholder in and is salaried by a closed corporation or similar entity. Attach to this statement a copy of the following documents relating to the partnership, joint venture, business, profession, corporation or similar entity: (1) the most recent Federal Income Tax Return, and (2) the most recent Profit and Loss Statement Name of business: Address and telephone number: d. Nature of business (eheck one) (1) partnership (2) joint venture (3) profession (4) closed corporation (5) other e. Name of aceountant, controller or other person in charge of financial records: a. b. f. Annual income from business: (1) How often is income received? (2) Gross income per pay period: (3) Net income per pay period: (4) Specified deductions, if any: Page 60f6 Form IN-OOB _ Worker ID 21205 Service Type M W kbb.com - guiding the car buyer 'Used Car Values i New Car Pricing , Motorcydes i f Buy a New Car ' Buy a Used Car i Sell Your Car :. Financing : Insurance ; Lemon Check ' Warranties : Car Reviews Car Previews ' Decision Guide - About kbb ; Home; . . .~ ~~"-",,.' ,,~ 0_ ! BUILD l YOUR CAR A I . " 1 J~ MAKE LOCATE DEALER'S COMPARJ~ YOUR DEALER BEST PRICE . Click on the image above to visit this advertiser Blue Book Trade-In Report Pennsylvania' November 20, 2000 1996 Ford Pickup Ranger Super Cab Engine: 4-Cyl. 2.3 Liter Trans: 5 Speed Manual Drive: 2 Wheel Drive Mileage: 94.000 Local Dealer Price - Used Car Local Dealer Price - New Car Ways To Buv a New Car List Your Car For Sale Online Financino Quote Insurance Quote Warrantv Quote Pavment Calculator Equipment XLT Air Conditioning Power Steering AM/FM Stereo Cassette Premium Wheels Consumer Rated Condition: Fair "Fair" condition means that the vehicle probably has some mechanical or cosmetic defects, but is still in safe running condition. The paint, body and/or interior need worK to be performed by a professional in order to be sold. The tires need to be replaced. There may be some repairable rust damage. The value of cars in this category may vary widely. A clean title history is assumed. Even after significant reconditioning this vehicle may not qualify for the Blue Book Suggested Retail value. Trade-In Value $4,210 Trade-in value represents what you might expect to receive from a dealer for this consumer owned vehicle. Keep in mind that the dealer must then absorb the cost of making the vehicle ready for sale, advertising, sales commissions, arranging financing and insurance and standing behind the vehicle for any mechanical or safety problems. Copyright e 2000 by Kelley Blue Book Co.. All Rights Reserved. Nov-Dec 2000 Edition. The infonnation in Ihis report was printed from the Kelley Blue Book Web sne (www.kbb.com) and is intended lor lhe pen;onal use of lhe cust<mer only and may not be sold or transmllled 10 another party. We assume no responsibility for errors or omissions. http://www.kellybluebook.com/kb/ki.dll/kw.kc. ur?kbb;088825&;t&39&5;FT;G7 & ~ < 'wi 11/20/2000 ~ ~ . ~' . ". ,,~ - ~'~~ In the Court of Common Pleas of Cumberland County, Pennsylvania Domestic Relations Section P.O. Box 320, Carlisle, PA 17013 Phone: (717) 240-6545 Fax: (717) 240-6248 Plaintiff Name: MICHELE 1. DONOY AN Defendant Name: HANK P. DONOY AN Docket Number: 00387 S 1999 PACSES Case Number: 212101067 Other State ID Number: Please note: All correspondent mnst include the PACSES Case Number. Income and Expense Statement THIS FORM MUST BE FILLED OUT (If you are self-employed or if you are salaried by a business of which you are the owner in whole or part, you must also fill out the Supplemental Income Statement which appears on page two of this income and expense statement. ) INCOME STATEMENT OF Michele 1. Donovan INCOME: Section I: Ineome and Insuranee Employer Carlisle Hospital Address Type of Work Cashier Payroll No. 03127 Gross Pay per Pay Period $ 767.75 Pay Period (wkly., bi-wkly., etc.) bi-weekly Itemized Payroll Deductions: Federal Withholding $ Social Security $ Local Wage Tax $ State Income Tax $ Retirement $ Savings Bond $ Credit Union $ Life Insurance $ Health Insurance $ Other Deductions (specify) $ $ $ $ Net Pay per Pay Period $ OTHER (Fill in Appropriate Column) INCOME WEEK MONTH YEAR Interest $ $ $ Dividends Pension Annuity Social Security Rents Royalties Expense Account Gifts Unemployment Workman's Compensation Other Other TOTAL $ $ $ I TOTAL $ INCOME Service Type PROPERTY Ownership * OWNED DESCRIPTION VALUE H W J Checking Accounts Members 1" $200.00 X Savings Accounts Members 1st 200.00 X Credit Union Stocks/Bonds Real Estate Other TOTAL $ * H = Husband; W = Wife; J = Joint Form IN-ODS Worker ID ,-~ "l!\iir~nIPl,;f!r;, , Income and Expense Statement PACSES Case Number 212101067 Coverage * INSURANCE COMPANY POLICY # H W C Hospital Blue Cross Other Medical Blue Shield Other Health! Accident Disability Income Dental Other . * H ~ Husband; W ~ Wife; C ~ Child Section II: Supplemental Income Statement a. This form is to be filled out by a person (1) who operated a business or practices a profession, or (2) who is a member of a partnership or joint venture, or (3) who is a shareholder in and is salaried by a closed corporation or similar entity b. Attach to this statement a copy of the following documents relating to the partnership,joint venture, business, profession, corporation or similar entity: (1) the most recent Federal Income Tax Return, and (2) the most recent Profit and Loss Statement c. Name ofbusiness: Address and telephone number: d. Nature of business (check one) (1) partnership (2) joint venture (3) profession (4) closed corporation (5) other e. Name of accountant, controller or other person in charge of financial records: f. Annual income from business: (1) How often is income received? (2) Gross income per pay period: (3) Net income per pay period: (4) Specified deductions, if any: Service Type Page 2 of3 Form IN-ODS Worker ID ~ < ~.,~ y Income and Expense Statement -- 1...,__" I>."ol._k'. PACSES Case Number 212101067 Seetion III: Expenses Instructions: Only show extraordinary expenses in this section unless you filled out Section II on page two. The categories in BOLD FONT are especially important for calculating child support. Jfyou are requesting Spousal Support/APL or if you assert your case cannot be determined according to the guideline grids or formula, this section must be fully completed. (Fill in Appropriate Column) EXPENSE WEEK MONTH YEAR Home Mortgage/Rent $ $514.68 $ Maintenance 45.00 Utilities Electric $ $90.00 $ Gas Oil 66.67 Telephone 60.00 Water Sewer Emulovrnent Public Transportation $ $ $ Lunch 130.00 Taxes Real Estate $ $25.00 $ Personal Property 22.42 Insurance Homeowner's $ $22.33 $ Automobile 47.00 Life 27.30 Accident Health Other Automobile Payments $ $ $ Fuel 86.67 Repairs 41.67 Medical Doctor $ $5.00 $ Dentist Orthodontist Hospital Medicine 8.33 Special needs (glasses,braces 16.67 orthopedic devices) EXPENSES (Fill in Appropriate Column) (continued) WEEK MONTH YEAR Education Private School $ $ $ Parochial School College Lunches 33~OO ~ Clothing $ $58.33 $ Food 300~OO Barberi Hairdresser 25.00 Credit Payments Credit Card 130.00 Charge Memberships """'"' Credit Union $ $ $ Miscellaneous Household Help $ $ $ Child care 368.33 Paperslbooks Magazines Entertainment 40~00 Pay TV 17.05 Vacation 40.00 Gifts Legal fees 200.00 Charitable Contributions Other Child Support Alimony Payment Other Trash $ $12.34 $ Total Expenses WEEK $ MONTH $ YEAR $ I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa~C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: \~~-a\ \~~.~"C~~,--"" r--..-----.... Form IN-008 Worker ID Service Type Page3 of 3 . ,.~~= ~~~._"" . '. ~-""'- MICHELE L. DONOVAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW HANK P. DONOVAN, Defendant : NO. 2000-892 CNIL TERM : IN DIVORCE INVENTORY AND APPRAISMENT OF PLAINTIFF. MICHELE L. DONOVAN Michele L. Donovan, Plaintiff, files this inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Michele L. Donovan, Plaintiff, verifies that the statements made in this inventory are true and correct. Defendant further understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. - ~~~ '~(,'-"'::::,Gv--..., Michele L. Donov ., laintiff ASSETS OF PARTIES Michele L. Donovan, Plaintiff, marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. (X) 1. (X) 2. ( ) 3. ( ) 4. ( ) 5. ( ) 6. ( ) 7. ( ) 8. (X) 9. ( ) 10. ( ) 11. ( ) 12. ( ) 13. (X) 14. ( ) 15. ( ) 16. Real property Motor vehicles Stocks, bond, securities and options Certificates of deposit Checking accounts, cash Savings accounts, money market and savings certificates Contents of safe deposit boxes Trusts Life insurance policies (indicate face value, cash surrender value and current beneficiaries) Annuities Gifts Inheritances Patents, copyrights, invention, royalties Personal property outside the home Business (list all owners, including percentage of ownership, and officer/director positions held by a party with company) Employment termination benefits-severance pay, worker's compensation claim/award ,-._- 1;- () 17. (X) 18. () 19. () 20. () 21. () 22. () 23. () 24. (X) 25. () 26. ,IJ,~ "' ~-~ ...... "~~_<l>i:an:f, Profit sharing plans Pension plans (indicate employee contribution and date plan vests) Retirement plans, Individual Retirement Accounts Disability payments Litigation claims (matured and unmatured) MilitaryN.A. benefits Education benefits Debts due, including loans, mortgage held Household furnishings and personalty (include as a total category and attach itemized list of distribution of such assets is in dispute) Other LIABILITIES OF PARTIES Michele 1. Donovan, Plaintiff, marks on the list below those items applicable to the case at bar and itemizes the liabilities on the following pages. SECURED (X) 1. () 2. () 3. () 4. UNSECURED (X) 5. ( )6. () 7. () 8. () 9. Mortgages Judgments Liens Other Secured Liabilities Credit Card Balances Purchases Loan Payments Notes Payable Other Unsecured Liabilities CONTINGENT OR DEFERRED () 10. () 11. () 12. () 13. () 14. () 15. Contract or Agreements Promissory Notes Lawsuits Options Taxes Other Contingent or Deferred Liabilities -~" i I~ "-ililJ '""l",..jlilo"'_~.,' MARITAL PROPERTY Michele L. Donovan, Plaintiff, lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other persons as of the date this action was commenced: Item Deseription Name of Date Cost! Aequisition No. of Propertx All Owners Aequired Value 1. 233 Southside Drive Joint 1995 $27,500.00 Newville, PA 17241 2a. 1996 Ford Ranger Joint Sept. 1996 $12,275.00 2b. 1995 Ford Escort Joint Nov. 1995 $12,000.00 2c. 1973 Volvo Husband May 1997 unknown 2d. 1977 Dodge Truck Husband Oct. 1992 unknown 2e. 1972 Special Construction Husband May 1997 unknown Trailer 2f. 1982 Special Construction Husband Nov. 1996 unknown Trailer 2g. 1994 Special Construction Husband July 1994 constructed by husband Trailer 2h. Race Car Club Ford Joint 1995 unknown 9a. Monumental Life Husband unknown Premiums paid for Insurance Policy several years 9b. Prudential Life Husband unknown unknown Insurance Policy 14a. extensive tools, automobile joint various vanous parts, race Car parts, etc. 14b. Household furnishings and joint varIOus vanous appliances 18a. Husband's retirement plan Husband vanous various wi Pennsy Supply, Inc. 18b. Plaintiff s Prior retirement Wife various various account wlPennsylvania Dutch Candies ~_"l> Item Valuation Nature of Non-marital Number Value Date Lien Portion 1. $30,000.00 Present 1" mortgage due and none owing to M&T Bank 2nd mortgage due and owing to Beneficial 2a. $7,000.00 Present Loan due to none Ford Motor Credit 2b. $4,000.00 Present Lien to Ford Motor none Credit paid in full by Wife 2c. $50.00 Present none none 2d. $8,000.00 Present none none 2e. $50.00 Present none none 2f. $1,200.00 Present none none 2g. $500.00 Present none none 2h. $6,500.00 Present none none 9a. $500.00 (est.) DOS (Date of Separation) none none 9b. unknown N/A none none 14a. $10,000.00 Present none none 14b. $750.00 Present none none 18a. $2,692.88 DOS none none 18b. $707.48 Nov. 1999 none minimal, post separation earnings - - I~ ,~ - ~.' , "' ~- . '.'.....,-:.,."",,,"' LIABILITIES OF PARTIES Item Name of DOS Present Paid By Number Description Creditor Balanee Balanee Whom la. Mortgage M&T Bank $33,000.00 $31,000.00 Wife lb. Home Equity loan Beneficial $6,000.00 $6,000.00 Wife (est.) (est.) 5a. credit card VISA $1,589.00 $1,500.00 Wife 5b. credit card Sears $3,400.00 $3,000.00 Wife ~._~ ~ ~" MICHELE L. DONOVAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW HANK P. DONOVAN, Defendant : NO. 2000-892 CIVIL TERM : IN DIVORCE PRE-TRIAL STATEMENT OF PLAINTIFF, MICHELE L. DONOVAN The above named Plaintiff, Michele L. Donovan, through her counsel Bradley L. Griffie, Esquire, files the following Pre-Trial Statement pursuant to Pennsylvania Rules of Civil Procedure No. 1920.33(b): L LIST OF ASSETS Plaintiffs Inventory and Appraisment, in compliance with Pennsylvania Rules of Civil Procedure, is filed contemporaneously with the filing of this Pre-Trial Statement. All assets and debts known to the Plaintiff at this time are identified therein. IL EXPERT WITNESSES It is not anticipated that expert witnesses will be necessary in this case. Plaintiff reserves the right to name expert witnesses following receipt and review of Defendant's Pre-Trial Statement and following the Pre-Trial Conference in this matter. IlL WITNESSES Plaintiff does not anticipate calling. additional witnesses other than herself at this time. Plaintiff reserves the right to name additional witnesses at the time of or following the Pre-Trial ." q Conference in compliance with any directives issued by the Master. It is particularly noted that in the event there is a discrepancy or disagreements over the values of personal property items, witnesses may be necessary for purposes of at least identifying such items of personal property if not actually providing appraised values for those items. IV, EXHIBITS Plaintiffs Inventory and Appraisment will be an exhibit as will an Income and Expense Statement in the form used by the Domestic Relations office. In addition, though, attached hereto are the following exhibits that will be presented at trial: Exhibit "A" statement of value ofPennsy Supply Retirement Account Account Number 180666386 Exhibit "B" statement of cash value of Monumental Life Insurance Police Account Number 002275890 statement of Retirement Benefits received from Plaintiffs prior employer copy of advertisement for three consecutive months placed in Hemmings Motor News by Defendant claiming the fair market value of the parties' race car to be $6,500.00 Two (2) pictures of race car Exhibit "C" Exhibit "D" Exhibit "E" It is anticipated that additional exhibits may be necessary depending upon the position taken by the Defendant at the time of the Pre-Trial Conference. In particular, Plaintiff is securing statements reflecting the balance of all loans in existence at the time of the parties' separation and their current balance. Further, in the event the parties are unable to stipulate to a value of the mobile home and lot owned by the parties, an appraisal may be necessary, which will result in a written appraisal to be used as an exhibit in the case. - V. GROSS INCOME See attached Income and Expense Statement VI. EXPENSES See attached Income and Expense Statement. VII. PENSION As set forth In exhibits hereto, the pensIOn or retirement benefit available to the Defendant is through Pennsy Supply Inc. and invested with Charles Schwabb Trust Company with a value of approximately $2,367.33. Plaintiff's only retirement was the benefit she received in the amount of $707.48 at termination of her employment with her prior employer, which whom she was employed during the marriage. VIII. COUNSEL FEES While both parties have incurred counsel fees, it has been necessary for Plaintiff to file formal discovery in order to secure information regarding marital assets and determine any position on values that the Defendant was taking relative to these assets. In addition, Defendant surreptitiously removed a large volume of personal property from the former marital residence, which Plaintiff wished to have appraised prior to its removal so that an appropriate accounting and valuation could be performed. Defendant removed those items of personal property and has not only failed to make them available for appraisal, but has also disposed of a wide variety of those items making it next to impossible to have an accurate evaluation of those items. ---~" - "~ I I -~~. Further, Plaintiff has borne the responsibility for paying extensive marital debt while the parties have been separated despite the fact that she is the custodian for the parties' two minor children and has a dramatically lower income and earning capacity than the Defendant. For all of these reasons, and other reasons that will be set forth at trial, Plaintiffs position is that Defendant should be responsible for paying her attorney's fees. IX PERSONAL PROPERTY As stated above, Plaintiff s position regarding personal property is that there was a wide variety of tools, car parts, and other items that were removed by the Defendant without allowing Plaintiff the opportunity to have those items appraised. The personal property within the home, which primarily remains with the Plaintiff, is nothing more than "old furniture." To date, the personal property has not been appraised. It may be necessary to make arrangements to appraise what items of personal property remain in the Defendant's possession, which clearly had value, and obviously had enough value to the Defendant for him to remove it from the former marital residence before an appraisal could be performed. While Defendant may demand an appraisal of the personal property in the Plaintiffs possession, it is her position that the valuation that would result would hardly cover the cost ofthe appraisal. X MARITAL DEBT Marital debt that was In existence at the time of separation is listed on Plaintiff s Inventory and Appraisment. To Plaintiffs knowledge she is the only one who had paid on the marital debt since the date of separation. ,''''' - -"-~..~ ~- - ~~, XI. PROPOSED RESOLUTION OF ECONOMIC ISSUES It is the Plaintiffs position that the marital assets should be divided on a 65/35 basis. Based upon the parties' disparate income, the parties' disparate skills, and Plaintiff being the primary custodian of two young children, as well as additional factors that will be outlined at trial. In addition, the Defendant should be responsible for Plaintiffs attorney's fees associated with these proceedings. Respectfully submitted by, Date: ~)/) \ ffie, Esquire Tor Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, P A 17013 (717) 243-5551 (800) 347-5552 '~. - "' <.1'-. '';'' , ~ ^" Pennsy Supply, Inc. 401(k) And Profit Sharing Plan (Charles Schwab Accounts) HANK P DONOVAN 180-66-6386 PENNSY Vesting Pct: 0 % For the Period 04/01199 through 06/30/99 . . YOUR .ACCOUNTS .... . .. . . Beginning Fund Investment Loan Repay/ Ending Ending Money Type Balance Transfers Contributions Gain/Loss Distributions Other Activity Balance Units Salary Reductions 51,554.85 50.00 5100.43 5151.64 50.00 50.00 51.806.92 51.3000 Company Match 419.67 0.00 25.12 40.33 0.00 0.00 485.12 14.2830 Company Profit Sharing 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.0000 Rollover 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.0000 Total Dollar Value 51,974.52 50.00 5125.55 5191.97 50.00 50.00 $2,292,04 .. . ........... ..... .... YOUR . Ft.FNbs ... ......... ................. .. . .>. .. ............. ...... .. Beginning Fund Investment Distributions/ Loan Repay/ Ending Ending Investment Fund Balance Transfers Contributions Gain/Loss New Loans Other Activity Balance Units Morley Stable Asset 5286.90 $0.00 $62.85 54.62 $0.00 $0.00 $354.37 17.2670 PIMCO Total Return 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.0000 Vanguard Wellington 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.0000 Mutual Discovery 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.0000 Vanguard Index 500 843.72 0.00 0.00 59.06 0.00 0.00 902.78 7.1180 Brandywine 843.90 -869.69 0.00 25.79 0.00 0.00 0.00 0.0000 Vanguard Int'! Growth 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.0000 FAM Value 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.0000 Dreyfus Midcap Index 0.00 869.69 62.70 102.50 0.00 0.00 1,034.89 41.1980 ST Investment Int'l 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.0000 CRH Stock 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.0000 Loan Ft.:nd 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.0000 Total Dollar Value 51.974.52 50.00 $125.55 5191.97 50.00 50.00 S2,292.04 CRH STOCK DETAILS Beginning Fund Investment Distributions/ Loan Repay/ Ending Ending Balance Transfers Contributions Gain/Loss New Loans Other Activity Balance Units CRH ADRs 0.0000 0.0000 0.0000 Market Value 50.00 $0.00 $0.00 50.00 50.00 $0.00 50.00 0.0000 Temp. Money Mkt. Fund 50.00 50.00 50.00 50.00 50.00 50.00 50.00 0.0000 Every effort has been made to ensure the accuracy of these figures. If you believe that there is a discrepancy in the information provided on this statement, please report it promptly to the Pk1n Administrator. EXHIBIT HAil l' ~- -'.1 .','c. MllrumentaL 1, Fe INSURANCE Charles & Chase Str..;" m COMPANY Baltimore. Maryland 21202 INSURED HANK P DONOVAN $50,000.00 INITIAL FACE AMOUNT POLICY NO. I I farm 1300 (PA) 002275890 JUNE 28, 1995 POLICY DATE Under the Provisions of this Policy Monumental Life Insurance Company Conll'acts to Pay: - The Death Benefit to the Beneficiary. if the Insured dies before the Maturity Date; or - The Net Cash Value to the Owner, if the Insured is living on the Maturity Date. This policy is a legal conll'act between you. the Owner, and us, Monumental Life Insurance Company. "We", "us" and "our" refer to Monumental Life Insurance Company. "You" and "your" refer to the Owner of this Policy. READ YOUR POLICY CAREFULLY TWENTY DAYS TO EXAMINE POLICY. If for any reason you are not satisfied with this policy, you may return it to us or to your agent within 20 days after you receive it. If you do so, we wlH cancel the policy and refund all premiums paid. Signed for Monumental Life Insurance Company at Baltimore, Maryland. N~~~ iliJ 4~~ L' , ---' EXHIBIT "B" Adjustable De"th Benefit Death Benefits Payable at Death of Insured before the MatUrity Date Flexible Premiums Pavable to MatUrity Date Nonparticipating - No Dividends Flexible Pr~miwn<\.9justal;le I,.if~ policy ;--.i,!,. "- Pag '.. 7 ,.. 6 .. 7 .. 6 .. 6 .. 6 .. 6 .. 6 .. 6 .. 6 .. 6 ,. 5 . 5 '. 5 . 8 . 8 . 8 . 8 10,1 . 3 . 2 . 2 .1 "" POLICY SPECIFICATIONS ISSUE AGE 21 JUNE 28, 2069 MATURITY DATE INSURED HANK P DONOVAN $50,000.00 FACE AMOUNT POLICY NO. 002275890 JUNE 28, 1995 POLICY DATE MINIMUM FACE AMOUNT IS $50,000 DEATH BENEFIT OPTION B CONTINUATION PERIOD 7 YEARS MINIMUM MONTHLY CONTINUATION PREMIUM $20.83 SCHEDULE OF BENEFITS AND PREMIUMS PREMIUMS PAYABLE QUARTERLY BENEFIT EFFECTIVE DATE AMOUNT FLEXIBLE PREMIUM ADJUSTABLE LIFE INSURANCE - STANDARD NON-SMOKER PREMIUM CLASS F ACE .~OUNT $50,000.00 JUNE 28, 1995 ADDITIONAL BENEFITS MONTHLY COST OF INSURANCE PAYABLE FOR WAIVER OF MONTHLY CHARGES RATED PREMIUM CLASS * 39 YEARS * SEE ATTACHED SCHEDULE CURRENT PLANNED PERIODIC PREMIUM $75.00 PAYABLE TO THE MATURITY DATE ANNUAL ALTERNATE MODES SEMI-ANNUAL QUARTERLY MONTHLY MONU-MATIC $300.00 N/A $25.00 $150.00 $75.00 IT IS POSSIBLE THAT COVERAGE WILL EXPIRE PRIOR TO THE MATURITY DATE CHOSEN WREN EITHER NO PREMIUMS ARE PArD fOLLOWING PA~VT OF THE INITIAL PREMIUM OR SUBSEQUENT PREMIUMS ARE INSUFFICIENT TO CONTINUE TO SUCH DATE. PAGE 1 10248E ,!IIlliIl'it-. , . MINIMUM NONFORFEITURE VALUES BASED ON THE PLANNED PERIODIC; PREMIUM OF $75.00 PAYABLE QUARTERLY AND A FACE AMOUNT OF $50,000.00 FOR A MALE AT ISSUE AGE 21 END OF GUARANTEED NET CONTINUATION OF INSURANCE PAID UP YEAR CASH OR LOAN VALUE YEARS DAYS OPTION 1 .00 0 0 .00 2 .00 0 0 .00 3 .00 0 0 .00 4 .00 0 0 .00 5 24.84 0 180 139.11 6 229.42 2 330 1,240.64 7 442.51 7 300 2,309.79 8 651. 60 9 0 3,281.63.. 9 868.99 10 60 4,221.68 10 1,093.58 11 90 5,123.83 11 1,758.70 12 90 7,946.41 12 1,954.27 13 60 8,514.60 13 2,156.03 13 300 9,058.57 14 2,363.95 14 180 9,578.40 15 2,577.83 14 330 10,074.37 16 2,797.48 15 120 10,546.58 17 3,021.75 15 180 10,992.58 18 3,250.48 15 240 11,413.60 19 3,483.45 15 240 11,810.31 20 3,719.47 15 240 12,181.01 AGE 60 4,581. 09 5 300 8,478.79 65 2,673.81 2 90 4,404.23 ItATURITY DATE 95 .00 0 0 .00 ------------------------------------------------------------ THE VALUES SHOWN ARE BASED UPON THE FOLLOWING ASSUMPTIONS: (A) CURRENT PLANNED PERIODIC PREMIUM BEING PAID UNTIL MATURITY DATE. (B) COST OF INSURANCE BASED ON MAXIMUM CHARGES. (C) FACE AMOUNT OF INSURANCE NOT CHANGED. (D) INTEREST ASSUMED AT 4.5%. (E) NO SURRENDERS OR LOANS HAVE BEEN MADE IF YOU PAY THE PLANNED PREMIUM AND INTEREST IS CREDITED AT THE GUARANTEED INTEREST RATE AND THE MAXIMUM COST OF INSURANCE IS CHARGED, YOUR POLICY WILL CEASE TO BE IN EFFECT ON JUNE 28, 2042. IN THIS EVENT, YOU MAY CONTINUE IT IN FORCE BY PAYMENT OF A GREATER PREMIUM. IF THE ACTUAL PREMIUM PAID DIFFERS FROM THE PLANNED PERIODIC PREllIUM OR IF A PREMIUM PAYMENT IS SKIPPED, THE ACTUAL CASH VALUES WILL DIFFER FROM THOSE SHOWN ABOVE. VALUES FOR DURATIONS NOT SHOWN WILL BE SUPPLIED ON REQUEST. POLICY #002275890 POLICY DATE JUNE 28, 1995 INSURED - HANK P DONOVAN ........""-0_,,1 -- .-' -- I',. -- :. ,~ i i " , ......J .-&~~,; "'-it ~ ..." , P'SmnVD'~ DUTCI CD..IIC. 408 N. Baltimore S1reet . Mt. Holly Springs, PA 17~128 . USA Phone (717) 486-3496 . (SOOi 233-7082 . Fax (717) 486-4678 Pennsylvania Dutch Co. Pension Trust Application for Withdrawal from Fund To: Pennsylvania Dutch Co. Pension Trust \i: Ii " i: ii 11 Ii 'I " !i 'I ~! Ii I ,I Ii ij I, I' ,I " I Ii !i " . ~7~/~' I hereby acknowledge receipt of ..) '" . as full payment of my interest in the Pennsylvania Dutch Co. Pension Trust and release the Trust of any further liability. I authorize the taxable portion of /11C. ~ eLf: f)O>-J<JI.iA j 2."1. ~~ to be paid directly to (Name) (Address) The non-taxable amount of T '7 or;. ~2 is paid to me directly. Name\'\\\<."'.', C:~i0("""(". "-, Address ~"'J~ ~'-"-"'\, Sc\.c~r- " - , "\ ,,-->-. '\-\":1 ,-'\'1, "'\..'~,\. \..,\'\. \\~ _--' v _ , Social Security # dO-I- lc. c - lc 11 ~ I / Date \ ~'d~q EXHIBIT "e" Manufacturer and Distributor of Fine Candies. Snacks and Food Specialties Hector Hinkle is a regi~~~ v.?q~m~rk of ~@nn~yjvW1i~ DutCh Co.. Inc. -~ I for details, interesting trades y. Shelton Sports Can, factory ealer, 9S-l.-493-S111, Ft Laud. Turbo Cup faclOry built ..l.ce car. ed new from Parsche Motorspon nine. immaculate. documented. aU 0,,>;1"<1'. Wnlrc. rrever meed. dama2ed or decaled. 16.000 tniie5. twO sets factoI)' magnesiwn. wheels. 550.000. Paul Allen. 513.870-8553, OH; pallen@cnmw.com (DEC) 100 race cars photos & specs o~ (j .f::-<:1J v'" ~'(j ~'9 ~.$ or call 973.316.8444 RENAULT: 19i7 Alpine A310, V6 with"5.speed, whire with red interior. runs well_SlJ,MO. Octagon Auto. 7l7-Z~669, PA. RE.lo,JAULT: 1985 R5 Turbo 2. red with taIl. stock." fOf- tnet ~elebrity owner. 24.000 km. $16.000 abo. Paul All~n. 513-870-8553. OH: paUen@cnri:lw.comrDEC) REYNARD: 1997lndy car. tub with fuel' cell. Valvoline Te:w. build your own dream car. $12.000. Bill. 317-831- j869.1N. ROV ALE:: 197.1 RP17 sports racer. wlFT_!OO. wlo en- gine, unrestored, available as is now at $30,000 firm; untestored but" with, installed new 2 liter Cosworth YBM or 1600cc Lotu.'i Twin eam at $46,0&0; com-- pl~tely restored by original manufacturer to.better than new mechanical. cosmetic condition without lID- gine at 560,000; with choice of either engine. fUlly race pr~-pped and track tested at 578,000; can be bought on a pay as restored basis or other; restoration start- int NovlDec unless soId,:as is: - prices -are for'-pr:e-work purch.ase. wjJJ be higher:wben done.lloyaJe"Racing-& R~toration Ltd. 706.896.2446, G"( (DEC) ROYALE: RP-16 CF FF. vintage SCCA. 1ogbook. S91lJes. 56.500. PH: 717-486-8690. PA. ClAN) . SADLER: 1959,spons rncing'Wlt. one of 33' Sadlers built, very ilis[Qric racin-g car. documenmtion by,newspaper. magazines of numerous wins. complete reuoration T~ACO. small, block Chevy Doreci stroked six. Stromberg carburetor; .roller C3tI1. 500+ I1p. all aluminum Jxuiy, fue1.celL fire sysrem. independent' rear suspension. I irom disc br.uces. rear drum. inboard finned aluminum. roil 'oar. a very exciting. faSt r'd.ce car. ariginafphotos-of ~~r when It'Was'new. 16" pin drive' Halibrand Mag IVneels. Dunio-p ..!.cing tires. right hand drive. original in. I teo-IOr. very excItIng. sure vintage racer. known as Meyer. S!)CClal. dnven m vintage event by Bob Bondurdllt. ask. :!\l1 5135.000. PH: 316-931.1188. FAX; 816-931...194.3. ~O <DEe\ SCARAB: conversion., 1975 Datsun 160Z, origmm car \~ith Sc:arab paper work; Corvette 327 ci, 365 hp, 4- Speed. alc, new tires. brakes and ignition, 36,000 miles. excellent condition. $15.000. Jjm, 912.965-5625 ~ays. 9124691_0198 nights, GA; (DEe) SHRIKE: 1964 Halibrand Indy car project. 2 tubs. :1 off- ~:t suspenslons. I road race suspension, 1 fiberglass iJcdy. I magnesium body, many, many, many spares, ~noui!h far: falling chasS1S cars. i,iO with 255 Offv or 4 1,,1,": '<.m Ford. :hese c;rs were histoncally very significant, ~9.500 for everything. 503-43 1.5954 eves. NH. (NOV) SIA TA: 1954 Daina GS alloy coupe by Sti Farina, complete, straight. stripped-to bare'alloy, good origi- nal interior. needs restoration. 520.000. PH: 323-656- ~3; FAX: 323~S4-8788. CA. .1.,.' SPRINT: 1930s car. flat tail. .1...:;viinder. beautiful. teady ~vintage !"'dcing. $19.500. John:~13-S84-42to. MA: SPRINT: 60s car. Hank Henrv SHC. Hilborn, front >\:Iring, rear cross torshm. exc~lIent, $25,000; Sprint Mid~et and offy parts, for list. send SASE_ WBJ, 1789 Doolittle Ct._Daytona Beach. FL 32124, PH: 9()4.76D- ~6.mEC) SPRINT c:<r: Edmunds chaSSIS. ':-DmpJete body, seat. kank. also addItional pans. S4.ooo; car in lowa~ 248_651. 0687.MI ~IN~ER: 1933 Ray Kuns design, V8 flathead, ~ranklin steering, steel body, ready to race. 91" ~'''Ibas~ Sl1.500. PH, 904-077-8035, FL. ~lI\llL..'",~,,_ 1llI............... STUDEBAKER: 1953 D/Gasser (Bernstein's first hoc rod). detailed to 1963-4 configuration. small Chevy. T- to. Englewoods. museum worthy, $50,000. PH: 806-i47- 4848. n. . S:VAl~OW: 1954 Doretti vintage i.l.Ce car. long. history or US vtntage lllcing, many Class wins. Second OA 1995 Monterey. Historic Races, fast, reliable: and, rare. with spares. 539.000. Vintage Racing Services Inc. 203-3n- 6745. FAX: 203.j86-Q486, CT. . THEODORE: 1982 F-1, #lY001"superb, condition, interesting trades considered. John Levy, 954-493- 5211,i954-779-319~, Fort I,.audeJ'daJe.- FL. 19sj Toyota uij.ruild -trod. tln~ ui fWO prl!P3red inr TOy{)lil hy P?I. alrnust curn.olel~l~ ori!lin~t lasl rilc!!l! MOrllreal Stadium 1986. In dry 'stOrage 5mc:~. located East CUilst.US. new l!rIgl~e. exo:ellem body and paint.'rf\any 5par1:;'mcludl!d. lelllClr $9:500: PH: 908-781.9390 ur FAX: 908-i1 9-0447, NI. . TRIUMPH: 1956 TR3, Devin- bodierl. running. needs . restoration. deliveI)' possible, $3.700. PH.: .71.7-389.1422 FA. (DEC) TRIUMPH: 1962 TR4; ex-worlcs road r'.dC:e and r.d.lly-cm'. fmished in lighr blue with. black interior. roll-bar. hardtop. alloy wheels. FlA Dunlops. interesting.history, $16.750. Fant'd.SY Junction. 1145 P:uk: -Ave. Emeryviile-; CA 94608. 'PH: 510-653-7555. FAX: 510-651-9754; www.1U em.com TRIUMPH: 1976 pro rally TRS, the actual John Buf- fum -Libra racing car that dominated the.197S.1979 Series" Road and Track magazine cover car~- Novem- ber 1980; mind 'numbing' performance and,liandling, will-sacrifice for 516,000;" interesting trades_ consid- ered. John Levy, 954-493-5211. 95'1(.:7-79-3198, _l"ort Lauderdale. FL. TRIUMPH: 1976 Pro Rally1'R8, lhe.actUaiJohn Buffum Libra racing: canh,ar dornimlred tne 1978-1979 Series. Road and 'Track magazine cover car.' November 1980. mind llwnbing performance and handling, will sacrifice for $16,000, interesting trades considered. John Levy, 954-493.5211.954-779-3198, Fan Lauderdale, FL: TROJAN: 1973 T.103 Formula One. Tauranac design. driven-by Tim Schenken. fresh restoration, DR; Hew- land; tested and ready,to tace. $150.000. Fanwy Junction. lT45 Park Ave, Emeryville. CA 94608, PH: 510-653- 7555: FA-V(: 510.653-9754; www.famasyjuncticm.com. TURNER: 1959 Mk 1. freshly rebuilt race 948cc en- gine,. rebuilt tr:ans., !Jew pajnt, wire wheeJs. 1'011 bar. rust~free, 15" wire wheels, sway bar, .new-brakes. ready for, VSCCA racing, and easily made road going, $18,000; The- New England Classic Car Co, 203.377. 6746. Stratford, CT. TURNER: 1963 Mk, n. fresbly rebuilt 1500cc Cos- worth. -twin.Webers. Quaife close ratio transmission. Minilites, "roll cage. fuel cell, adjustable Kanis, sway bars, all aluminum Inner panels, 150 bp and weighs 1,1S0 pounds, super competitive SVRA eligible racer with road equipment, $20,000. The' New England Classic Car Co,1.03.371.6746,.cT. TURNERS: four 950s, two Climax 'powered \1k Is, two Ford lS00cc powered Mk Ills, excelltnt VSCCA and/or. SVRA eligibfe racers. The New England elas. sic Car Co. 203-377~6746, CT. -, "".""", -_:' '.x;Y"''''-7:'"';i>,iT1~ '~;;,~" ,_ __, ",_, ; '1%5 TVR Griffith Series 200. #2005063. red elttenor with white Circles. black"interior. Mag .....heels. one cf only loo built. Ford hi-po 289 V8._ aOr'll-Warner alummum' T -10 4--Speed. Sal- i~bury limited ~Iip differential, frame-up restoration. stteel: legal or historiC rao:e c:ar. Grand Prix Classics Inc, 619-459-3500; FAX:c19-459-351:Z..CA. TVR: 1967 Tusean V8 SE, swb, (hd. 24th of 28 built, extensive nut and bolt 6 year restoration to concours street and vintage racing specifications, finished in white with black cloth sunroof, red leather interior and red wu.~- _R"''''''~'__ ~__::":-,..~ !-L_~ ":89, now 307 cu in and' 10 transm~. EXHIBIT "D" "~tiIil~liiJ~i" ~ ~I ~ HMN, Nov. '98, p~GE~5jl .:1 " I .1 ~j i I >b~ " sion. Jaguar 3:5S ltd slip differential. disc brakes. fUlly adjustable Heim jointed coilover suspension, 15"x7" Panasport lights. fuli moly roll cage and cus. tom fuel cell. undlJubtablv the best Tuscan/Griffith anywhere, awesome acceleration and' handling, over $iS.GOO spent on restoration alone, price, $52.500 and or partial trade, call for package. Ed, 435.049-1992. UT. (NQY) TYRRELL: 1979 009fl. F/One. complete mechanical restoration, fresh Reilly OF motor. $'offers. 626-792- 7130. FAX: 626~O-5984. CA. lJNIPOWER: 1966 GT, believed to bt one of 3 facto" racing cars, wide fenders. brake cooling ducts, et~ needs restoration, divorce. must sell, asking $15.000 Qr make offer. 941.481.6313, 941-54946329, Fort Myers,FL. YANDIEMAN: 1982 RF82 Fonnula Ford. two races on new 1600cc:. Lovnitll!. head and carburerion. custom ooen tr.uler. many spares.~ professionally mamtained. current SCCA annual tech. beautifUl car. 57.000. Jem-. 520~S22- 0695. AZ, " VIKING:'spons i.l.Cer prototype. built by Boh Erikson. one-off. street 1egaJ, very exotic. Bi.l.bham s.lls.QenSlOn. aH steel Caswanh crossflow. Hewiand gearbox. $22.900. PH: 56J-595-3000. FL www.wirewheel.com VIOTTT/OSCA: 1959 one-off? 2-Qoor' o:oupe. with Fiat/OSCA 1500cc lwin eam, Dunlop' wheels. Alfin drum.". solid West Coast car. needs some restordtion. vin- tage eligible. offers. 401-578-7624. RI: e'.mai[: tldin- ri401-737-87600Lcom VOLVO: 19S8 544 Rally car. superbly prepared by Sven- Erik Bjoerk in'Srockholm. Class winner 1996 La Carrera Pari Americana (4th OA), Louis Vunon China Rally 1997. 2nd in Class..r'.l.ce ready, quick. reliable & allr.1c- rive. $29.000. Vintage Racing Services In<:, 103.j77.- . 6745. FAX: 203.386-0486. cr~ VOLVO::1981 ,2-<loor with 350 Chevy VB. 5-speed.1PD suspension, Recaros. more, 59.800. John. 413-584-4210. MA, . WESTFIELD: Sprint car. new, single seater. open whee!. ,hottest class in England. 1600FF, 4--spd; trick suspension, only one -USA. great for,trja1$.-billc:limb. sprint, dirt. manufacturer's show car, retail $18,990, special: 59.750: in Oregon. 818.709.1776. CA. ZINK:' ]971 21 SuperVee, reCent rebuilt: $7;100, free track days at-Ginger Man Raceway' with purchase. 616-253_5, Ml. (JAN) 'ii' RACING &HIGH PERFORMANCE PARTS, LIT, SERVICES &c For Sale CLASSIFIED ads in parts sections ,are sorted by first full word, first abbreviated word or letters pertaining toa model. A RESTORATION and rJ.ce prep shop Tor your vintage British and other sportS or racmg car: SCCA. Vintage prep. award winning restord.tions; between Philadelphia aDd New York City._Ragtops & Road:m:rs. .215.257. 1202. PA: www.r-.tgtops.com(NOV) A CAN AM McLaren bJb Cbev fuel injection system, Jac:kson.Kinsler with tanks. lines, etc, best offer over $5.000. PH: 613-476-5000. ON. Canada. (DEe) AC COBRA parts specialist since 1973. full line of OEM; plus 'Complete chassis and alloy bodies. exact 'as original-specs. 847-84Z.s335 eves, FAX: 847..487-0107, lL.(JAN) AIR condition :your flathead or dress-up YOtJr nail- head Buick with chrome goodies. There is one catal~ that has an rOOt needs. air conditioning, rebuilding, high.perlormance. dress-up, home of Smithy muf- flers. Jahn's pistons. Mallory ignition. Offenhauser products; Isky cams, Shoebox disc brake kits and en. gine swap kits. If you're building a traditional stylI; rod or custom vou'lIlove our c:ataiog, 54.95. Hoc Rod & Custom SUP'ply, 1304 SE 10th St, Cape Coral, FL 33990, PH: 941.574-7744. .. What's in it for you? International Exchange! 1 . SEE PAGE 8518 ~ ll..il .....1:.11'. '1';,.'.i.'1 '--I; ..j'! "-:i :1 "11 I': I'>, '.'.1 ';'1 :il. .1:,1 :! !:il :'1' I ,. ':" :.jl-:p 1:, ~' " ";' .....' " '::!, >"'1 "'<'1:::: ''', iii, Hij , I~: iil! il: f'!!i 1.,'1 !.,:i!'li:: ;1:"1 l~; j' (III '1!' i~ "1,.1..j.", "'''1'' .'~1iflirt' ':ii :'lr '1'1" ,~.i i'~;i ::~:_ !.: I!. )~tlij '-". ':1, '" d, :~; i',~i "'Iii; '.11. :r i, " 'I" ;.I!: HI!. i:: 1.ll. '"I: I:U; Iii! il'.I' 'i l ,I 11 [I 11.:.1 I I': I 1 I , 1'1.'.'1 H ;, "li ,'!'! i \:t PAGE 9312. HMN, Dec. '98 RACING & HIGH PERFORMANCE Cars For Sale' . continued MG: 193i Midget. Elto 4/60 flat taiL restored: rilCin!!, his~ tory. 512:":00. PH: 515-684-8390:-1A. - MG; 1939 Midget. older restoration, much chrome. al- loys. in/out box. Volvo powered, some history-known. 58,500. trades welcome. i70-640-6464, GA. MGA: 1960' roadster. rebuilt rront end, front disc brakes, professional bodywork, perfect s'tage to finish as race car, no time, lost storage. must_s,uI. can deli'\'. er, $6.900 US without engine. rebuilt 1800cc available. 403-234-3102. AS. Canada; bhunt@westaim.com (JAN) . MG: 1970 Midget. EdmundslSesco, 95% restored, beautiful paint. indentical to Bowes Seal Fast car, HaJibrand quickchange. Schroeder steering, new chrome. lots of histo~, ready for competitive vintage and shows. 516.000. PH: 925-612-3983 or 925-295- 1019. CA. MG: 1982 Midget. Stanton VW. formerly driven by Ken-Schrader on Swims tour in early 19805. 151 cu in. good-condition. as raced. this jear, some spare wneels, axle. etc..S7.500 abo. 317-892--4149. IN. MILLER:' 1962 sports mcer, fuily restored as origi- nal. 145 hp. 1600ce Ford crossnow with steel crank and Webers. one- mce since total engine andlHew:land, rebui~d. new paint, suspension, very comp.etitive, inex- pensive entry to sports racer catag9iY."S26.000. Terry, 303--976-0100 days. 303494-8558 eves; CO. {DEq" MOORLAND: 1959 Formula Junior. ,the .very firSt Gemi'ni ever built. winner at, August 1959 Brands Hatch roce, restored to concours condition and ready to. race. The New En~and Classic' Car' Co, Z03-377- 6746. 'CT. MORGAN: 1962 ,i/4. fresh i500cc Ford. ConcoulS win- ner:-ncw blue paint.. chrome wires.. fusundj~liabI~YerY well p,repnred. 520.000.- PH: 757..423~5985. VA~(DEC) . MOSS Midget,' 1/2 Midgets: #1 car. Jimmy' Bryan. George S~l!l!lnct.~...p~f!~o__car, 'Kohler'motor. 'lie!,.. paint,:: chrome. interior, ett:, SOw;, ,ifi..I.IiI_~, l,u<::Lal .C.:iI SpJ Mac W" chaJnsaw motOI", very, gOOil as ran 'condi- tion;_ both cars have been. stored since 70s;' #2, car;. $2.200. PH: 562.634-9672, 561-866.3404 eves, CA. MUSTANG": 1965 notchback, SCCA' race history. 1974.89'. AlS~ GT':'l.. T/A,. fillly documented. SVRA:- Group 10 eligible, 58,.500 roller wlo engine. choice_ of engines available. 360-35S.888&. CT. " MUSTANG: 1966. ,~hopped top. fiberglass front end and doors. setuo for s/b/c. tubbed. ca.!!e. 4.57s. 51A50. PH: 43.5..477-8213 daytime. UT. - MUSTANG:. 1966 Shelby. GT 356 (651514), original California car. red/white. stripes. vintage: race.'car, total restoration- and- race ready,?new. Dave- Dralle built'306'ci;,~56--hp (36o-,fpt)~ original GTi40'C6FE; heads and black, custom crank (steel), Carillo rods; custom exhaust b"i DAH Headers. Lincoln front brakes', full comp c:ige. Butler built r3_ce seat, 2Z gpm fuel cell. the best of e,verything,.y ARA:Jogbook. 365,000. PH: ~13~-0300' dar.s. 310-395...9.131. eves. CA. (DEC) MUSTAN.G: 1966 Shelby. GT 350H; 6S,1484-. bought from .he original l)Wner 20_ ye:lrs ago. setup for,vint:lge r.lCin!!'. de:lnest BPl C:lr around. still street']egal. 1 h:1ve every- origlnal pan l ever changed. wlttnhe cargoes: extra mO[QlS. trans ~nd even :In extra: fastback body; build a repro pl~s have an originat. never hi!; this'car ':""ins races :md car shows. John. -:"60-398-0147 or 760.568~8t4, CA MUSTANG: 1969 Shelby deMexico. totally_ restored. one of3 cm manuiactured 10 compete in Tr:ms.Am Race Circuit. S22.000. W:lyne, Frost. .610-717-8439. Sinking Spring. PA. (FEB) GIFTS OF FLAWLESS RESTO Vintage &: Modem Name Brand Watches See color page 9096. NASC..1.R: Boss 429. dry ~ump oil pan system. excdient original condition. .::omplete with pressure pump and drive; 5850. PH: ';'04-875.3673'days. 704-892-.:.857 nightS; Ne. (DEe)' NISSAN: 19883002.."< GTP. 1988 Champion~hip car driven by Monon & Brabham. ready ror the Thunu.er Se- ries. SI95.000. SymooUc. J 10-652-1300. CA. ~ I "h",~~I. PACKARD: 1937 Twelve Fakon roadster. one-9ff Bohman & Sons body. r:lce. prepared. special eam. three Stromberg #:97s. duaL he:lders. very ~pecial custom suit- :lble for \<lille :mo';rJ.ck r:lcing events. for s:lle or trade. CCJ1"s. 626--447-03'27. CA. PANTERA: 73. red, wing, immaculate. detailed en- gine compartmenLS33,OOO. PH: 316-788-5967. KS. PEUGEOT: 1984 ?o05 T-16 4-wd Group 6 rally c:1I"..eX- Jon Woodner. US roJly history. spare wheels. engine. <:tc. 575.000: FantaSv Junction. 1145 Park Ave. Emervville. C.~ 94608. PH; 51 0.653~ 7555. F..1.X: :s 1 0-653:9754=: www.1llcars.com PL 'Y;\40UTH: 1964 Valiant nostalgic drag car. glass nose, doors. Halibrands. chrome, straight axle. oar. rowed, Dana 60, chopped top. 383 Fairbanks, $7,000 or 55.000 rolling. street' rod. muscle car trades want. cd. 860-584-8696, CT. PL YMOUTHS: Fury Is police. incredibly fast. de- pendable; two.1968 2-door Nebraska State Patrol. 383 auto. ps, pdb, :1Ic; 1968 l.-door 318 auto, ps, ale; 1967 2-door' bogus Nebraska Safety Patrol. 440' auto, origi:' nal California car;. 1967 <kIoor Washington State:, 383 :luto. mag'netic badges included, Nebraska cars. Rocky. 888-946-2282: or memories@cconline.net PONTIAC: 1963 Swiss Cheese. 1 of 15 built, 5125.000:. PH: 615.822-1401.9-5 CST, TN. (DEC) PONTIAC: 1976- Tr:ans Am. tubbed. ladder bar, fiberglass front dip. doors. Le:-t:an. lSd2 centerlines~ roll ca~e. narrowed rear end, Strange. 2,700 lbs,: never raced, 33.000. PH: 407-296-6876, FL . 1989 Pontiac Firebird 5CCA.American sedan, West" CoasT win- 'neroidozensorevenu. always a race car. is nice as they get, race ready, lots oi spar'es. never bent. owned by Schmidt, Ward. ward, 512.500. PH: 915_837.5090. southwestern TX. PONTIAC: Can Am. World_Spons CM Bennett 11. small '6lock injected Chevy. March Hewland'trnnsaxle. campiete . body molds. 535.000. Rod Bennett. 408-395-59n. CA. -, PORSCHE: 1959 4.cam Carrera GSGT...speedster red/black. correct alloy doors and trunk with lou~ vered deck. filllY known history. Motor Classic & Competition. 914-997-9133, FAX: 914..991a9136~ NY. PORSCHE: 1974 RSR, 911 .u)O 906Z,..Tebernoit team car. quickest RSR in the world, 3.6 litre engine, 935 suspension. roll cage. gear change, Viper. green. beats aU 993 GTs. SI60,000. John Starkey, 619-272-8627. CA:.: PORSCHE; 1977 934.,#;9307700959. updated.immedi- ately to 935 specs for IMSA rocing. unbelievably' strong running C:ll'. lots of history. compare cmfully at our price of 5135.000. Fantasy Junction. 1145, Pnrk Ave; Emeryviile. CA.94608. PH: 51O.653~7S55.~FAX: .sH~; 653-97"54: www;1 UC:ll'S.com .' . PORSCHE: 1985 962.C, #107. factory built. Let'dans and ISMA history, 2 owners, cosmetically pet1ect (5 years in Collier Museum), mechanically superb, Cresh Frans 81am motor. calf fot'l,details;..ioteresting trades considered. John Levy, Shelton SportsCar,s"{factory authorized Fer-rari dealer}, 95449J.5211~.Fort Laud. erdali!'. FL. . PORSCHE: 1987944 Turbo Cup f:1ctory.buil~~'#atl original owner. 'purchased new from Por.sche'M"lili'iiisPutl NoTth.America.. one of nine. irnrTlllcul.:1te.. documented.: all. original: white. never raced. d:lm:lgcd or decaled. 16.000 miies, twO'sets.factorv mllsmesium wheels.-S50.000. P:1.U1 Ailen~ 513.870;8553: OH:-pallen@cnmw-.com{DEC) . PORSCHE:' 1996 Twin Turbo. arena/black sports seats. In dash CD. 6,500 miles. front to.....er.strut brace. perfect in/out. 513-792..7445, 513.2n-~151, OM. 100 race cars photos & specs o-t$' '" ~ .~ c. ~'IJ' ~'9 ~~ orcall 973.316.8444 ..; ,'.- t ' "~'~J~ .J RENAULT: 1985 R5 Tur~Q,2. red with t:ln. stock. io celebrity owner. 24.000 km.,SI6.000 obo. P~ul A~ 513-8iO-S553.0H; pallen@cnmw.com(DEC). . ~\ RILEY:. 1934 Midnight dirt. track face C:ll'W/1932' F- Model. B engine w/4--port Riley heads. won 1975 Iii ~l'd. award at Hershey :md wen S~nior in Delaw:lI'e. S3~: Reilly Classics. 7]7-288."7822. Wilkes-Barre. PA_ . R&T inspired: 1960. one-off project rac: car for LeM~ fi~~ias: body w/rolllng :ube ch~sis. 530.000. PH: 6'1~: 5.L.,J!J4..J.:vIN. ROYALE: 197::!. RPli sports r:tcer, wIFT ~OO, w/o;: gine. unrestored. available as is now at 530,000 licin. llnrestored but with insUllled new 2 liter COSWOrth YBM or 1600cC' Lotus Twin Cam at 546.000; com_ pletely restored by original manufacturer to better than new mechanical. cosmetic condition without' en. ginl! at 560.000: with choice of either engine. fullv race prepped and track tested at 578.000; cn be bou~t on a pay as restored basis or other:, restoration. starting NowDec unless sold-as is: prices are for pre-work pUr. chase. will be higher when done. Royale Racing & R.estoration Ltd. 71)6,;896.2446, GA~ (DEC) ROYALE: RP.16 CF l"F. vintage SCCA. logbook: spares, 56.500. PH: 717~86-8690. PA. (JAN) ROY:l,LE: RP-4spons r:lcer.;;16 of II built. incoD"e!:te gine. 525.000 firm.;.937-6.J.3-1 :::23. OH. SADLER: 1959 spons r..c:ng car. one: of 3J-Sadlers built. very historic racing car. documentallon by newspaper. magazines of numerous wins. complete restor:llion TRACO. smalrblock Chevy bored stroklld SIx.. Slromberg carburetor. roller cam. 500+ rap. all :lluminum body. fuel ce!L fire system. indepencient rear ~uspension. front disc brakes. rear drum. inbo:m:i finned aluminum. roll bar. a very exciting. f:lSt r:1Ce c:1I". original photos.of car when it was new. 16" pin drive Halibrnnd Mag wheels. Dunlop rucing tires. rfght lumd drive. original interior. very excit. ing. sure vinmge racer. known as Meyer Special driven in vint:1ge evenrby Bob Bondurant. asking SI35;OOO. PH: 816-931.1188. FAX: 816--931-4943. MO. (DEC) SCARAB: conversion, 1975 Datsun J60Z, original car with Scarab paper work,: Corvette 327 d. J65 hp, 4- speed, a1c~ new tires; brakes and ignition. 36.000 miles,- excellent condition. $15-,000. Jim, 912.965.5625 days. 912.691-0198 nights. GA. (DEC) SIATA: 1954 Daina GS alloy coupe by SU Farina, complete. straight. stripped. to bare alloy. good origi- naL interior, needs, restocation, $20,000. PH: 323-636- 7483; FAX: 32J..6S4-8788.CA. SPRJNT c.:lJ'S: 1946. barn fresh. compJ~te car with 3 Ilat- head r:lcing motors. in/out box. & many wire wheels. k.nown hislory. $9.500: :liso. incomplete 1939 Sprim car. good rails, re:ll' body & fr;: axle. S 1.500. tmdes welcome. nl)..64()--6464. GA. SPRINT: 60s car, Hank Heney SHC, Hilborn, front spring, rear cross: torsion, excellent. 525.000; Sprint Midget and olTy parts. for list. send SASE~' WBJ. 1789 Doolittle Ct~ Daytona Beach. F-L 3211.4, PH: 9tM-760- 6176. (DEC) ", ): :1 ;'. :i " n l ., I Ii 1.1 !:~ I: ;:' i: n " H ;:~ n i'! I" if '. i.! I' I:: Ii I:: Ii !i !! I' i i ~ k 1%0- Tara5chi FOrn'lllla I'. :omolete-reslor.llion and origin.al. 20year(lWn~, 1089 F;;1l.:;n'l,n<lIWeberl".llorrani5.lelc. Ji~o included are 20 years oi ~:;Iares. engines. whl:l!'ls. suspeI1slOn parls.cJrns,elc.m1Ilntseil:);ll"lssetlJralely.Jlso-lolsoiFial(,QO p;lrts. Dave DuBnd, 802.653-,:056: FAX: 80Z-{,;a.060). vT, TRACK roadster 50s Z"i T. an"steel, ~ercury flathead. ~x2s, headers. shown, in American Redder. May 1993. pa~e 74 with Zora r\rkus-Duntov, superior example. race ready, SI2.900.-Jerry Duncan. j17-8434230. PA. TRIUMPH: 1956 TR3..LJevin bodicd._ running. needs restomtion. delivery possible. 53.700. PH: i17-389-1:21:2. PA. iDEe) -'. tRIUMPH: 1962 TR4. ::.o;:.works rood met and rally car. finished in light blue wttn blxk interior. roil b:ll'. h:1rdtop. ~lIov wheels. FIA Dunioos. interesting history. 516.i50. Fantasy Junction. 1145 P::ri:. Ave. Emeryville. 'CA 94608. PH: 510-653-;555. FAX: ':10-653.9754: www.Illc:m.t:om TRIUMPH: 1970 pro r:lily TR8. the actual John Buf. fum Libra racing car that dominated the 1978-1979 Series. Road and Track magazine cover car Novem- ber 1980. mind numbin~ performance_and handlin~. will sacrifice Cor 516.0011. interesting trades consid- ered. John Le,'y, 9544'}J-S211. 95~-779-3198. Fort Lauderdale. FL. ....... 89 Parse"e 9h~ .w;>, ~b;'C.C7 C:""3cman lub, iienie HertzoG oi SwOlzc.ian(1 '''^. ,1\ J~ >Ii.. C-,lf1 :~,_ ~1,m1 hone..comb ;id!S and bollom, ;n..~O<J-. ~uman ",nCI, _"SC'-'OI!'C:i by "..v;n Jenene and '<V<lll..' ~",rner ,,,,:e[111'. ::::t'm<,- '.1010' SPOrts. engine ha5 3 ~,l JOOli ~nor; "''', ::~..: <:'e"'~~' ...,nl:l. lie,",' lign!. 3"2 air 10 Jlt . 4 1.10Iro~,( 'nC'~3r '\.i "t''' -:5 np, Janermelsl\!,liverv. S:;C.'JOO. Dale La;rQ. ~,;:'~.~: 4.' :;.:iu, UR. PORSCHE: 199& Twin Turba, 8l'enalblaek sports $eats. in dash CD. ri,SOO miles. from tower strut brace. jJerfect in/out. .513- 792-7 ..j.45, 513.272-1151. OH. iFEB) , QUARTER: :Vlicgel r::{.:e c:;.r. Furd flathead V8. white. lotaH)' origin:J.i. S 15.000. PH: 306-j76.9999 evenings ::md eariy mummgs. TX: or 602-3 15.15j2 anytime. AZ. ~LT: 1978 RT.l. e....Tom GI(lY Lane Sports, cham- pionship winning car. fresh tub. new plaling, chr08 mate gearbox. 2. sets of wh~els. less engine. 529,500 000. 973.J76.1255. ~J. ROYALE: RP-16 CF FF. Vlnta2e SCCA. lO!!.'Dook. spares. 56.500. PH: - I ~ ":'86.8690. PA. (JAN) . SCHREE LOLA: n}2C CJon Am car HU5S. restored, Chevy. Luc::s. W~3\-er. Hewbnd DG300. historv, 564.900. PH: :,1";'.227-:959. MO. . SrATA: 195* Daina GS aHoy coupe by SU Farina. complete. straight. stripped to bare alloy, good origi. , , _~J, ~jj;,h." J""""~; nal interior, needs restora[ion, $20,000. PH: 323-656- H83; FAX: 32J.654~8788, CA. SPR1NTER: 1959 Sw,pp. driven.;y Rurherford. Congdon. Snider, Coy. Ruddennan, Ting\~stad. sm",n block Chev. Hibom injectors. Halibmnd tear "'nd wheels. V ene;( mllg. spares, fire Syslem. excelhmt_ $28~OOO. PH: 91..;..234. 6494. FAX: 9[4-23.1.,11 17. NY. STANGUELLINI: 1959 Junio., #00154, ready to race/show. aU original. very fast, spares. needs n~th. ing, priced to' sell. 97:.247.6767, FAX: 972-484-5574, TX. (MARl ' T960 Taraschi f'ormu(a Ir, ,amplele restoralion and original. lOvearawner.l089Fial.anginaIWebers. Borranis.elc.a_lso In,tuded are 20 ~ear.s oi spates.-eng;nes. wheels, suscenSIOI1 partS.'arln,~c.mjghtselliJal1Ssepar;ueiy.alsolatsofl'iat600 parts. Dave OuB1"\I1, 80:2~58-10S6: FAX: 802.658.0603. vT. T-BOLT rtlirlane: nice uncut arigin.:!.l c.:zr. aJl previous owner history and photos. this car is correct and nice. Randy. 315-946.5025. J 15-923-J671 evenings. NY. THEODORE: 1982 F.1. #TY001. superb l:ondition. Interesting trades considered. John Levy, 954-493. 5211. 9548119.3198. Fort Lauderdale. FL. TRIUMPH: 1962 TR.4. ex"works road mce:md rally cur. finished in light blue with black. interior. roll bar. hardtop. aHoy wh=ls. FIA OunlopS. interesting history. $16.750. F:mtasy Junction, 1145 Pnrk Ave. Emeryville. CA 94608. PH: 510.,653.7555. FAX: 510..653.9754; www.lllcars. oom TRIUMPH: 1964 alloy ixx:I.y LeM:lIlS coupe. #ADU .18. the C:ll' th:lr. finished 1st in ClaSs and 13th overoll, entered by the works "driven by Thurner & Lmlpignon in the 1%5 LeMans. one of threebuilr.ADU #48 is inexc:eption:llorigirullcondition 3lldsriU in its original ,greenIyellow worlcs livery. ADU 48 is vin~ae 1.ICe ready with a fresh 137 hp all sn:e113COcc engine, eltlUl CR p. box. new bushes and <ill. brokesIsUspension, items in perfect order. the complete original marching: project drivett:lin is in good'cOn- diaon:md supplied with me vehk:1e. d1e roost signific:mt of post. ~ll HM."., Jan. '99. ?'GE 229 'liar Triumpn :md ;'..,::,,,m\; r~'l~ n)()~t cesuabie :./ '''''orks. comoeU- lion.::ars with fun dcc:.:.rr:enL1l1on :md sup::m :usrory." $100.00::1. ~ff;:;'~.:s... Vlnmge Racing S~r;'lc~s~ 21J3-;36-lm.6. FAX: .;.O~-.JII-or4::l.CT.. TRIUMPH: 1916 pro rally TR8. the actual John Buf. fum Libra racing car that dominated the 1978.1979 series Road and Track maeazine. COVel" car ~ol"emher 1980. mind numbing performance and handling, will sacrifice for $16.000. inrerestin~ trades considered. John Levy. 95......j.93-5211. 95.....719-3198. Fort Laud8 erdale. FL. TRIUMPH: e~-Works Vilesse Trans Am. Triumpn's only factory entry in the original Thlns Am $erles. constructed 0'1 TriumlJh's lIS ;amoeriljon direClOr. K.:ls Kastner. his. IOnC Tr:J.ns Am cr::J.mp'lOn, l!S all Trwmpn :":lce champi. on. 2.5L. 6-c)'1. 5-;;oeec. he:lv\' dUlY c:omc__IRS. ~-wheei discs. $4'2.500, PH: 328-5:'6-197:. Hignl!J.~ds. ~C TROJAN: 19,3 T-103 Formul:l One. 7auranac design. driven bv Tim Sc::enken. fresh restor::Hion. DFV. Hew- land. les;ed :lna ~ead\' !C_ ~:lce. S 1;0.000. F:ml:J.Sv JUnc- tion. 1145 Park A'~: EmCf\'viHe. CA, 94608. PH: 510. 6.53-7555; FAX: SiO.653-975..;.: wW"'"::lntasyjunction. oom TURNER: 1957 9505. beautiful. first class restoration of a roadworth~' Turner. red with hlack interior, strong potential for VSCCA preservation class. asking $28.000. Doug Fraser. 603_..j.69_33:20. :-.IH; doug.fl'aSoo .er@danmouth.o:du (JAN) TURNER: 1958950 Amocrosser. Dares. cage. Mazda 12A. 52.800; 198~ Red Devil i=.wO. $2.600; Indy CM body. ex-Me:lrs. ?enske. comp\c:te with undenrny. wings.. 51.500. PH: 417.886.]1O\. MO. (FEBl TURNER: 1963 Mk II. freshly r~built 1500cc Cos-- worth, twin Webers. Quaife close ratio transmission, Mlnilites, roll cage. fuel celt, adjustable Konis, sway bars. all aluminum inner panels. 150 hp and weighs 1.250 pounds. super competitive SVRA eligible racu with :"oad tquipment. $:20.000. The ~ew England Classic Car CO. :03.J77-6746. CT. TURNERS: four ~50s. two Climax powered Mk Is. two Ford lS00cc powered Mk Ills. excellent VSCCA and/or SVRA eligible racers. The New England Clas. sic Car Co, 203.377.6746. CT. .' <, lliIl t ~: ! t~. ;:; r 1';+ I I I I I~ 1 f I j I ',I 'i, , j I ! -- EXHIBIT "E" ,1:-- M '1 L.' ,< &.;,:,)~i .. MICHELE L. DONOVAN, Plaintiff IN THE COURT OF COMMON PLEAS OF ~UMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00 - 892 CIVIL HANK P. DONOVAN, Defendant IN DIVORCE ORDER OF COURT AND NOW, this J 7 1'&0... day of 2001, the parties and counsel having entered memorandum of understanding resolving the economic issues on March 28, 2001, the date set for a four-party conference, the memorandum of understanding having been transcribed, and subsequently signed by the parties and counsel, the appointment of the Master is vacated, and counsel can conclude the proceedings by the filing of a praecipe to transmit the record with the affidavits of consent of the parties so that a final decree in divorce can be entered. BY THE COURT, Ge cc: Bradley L. Griffie Attorney for plaintiff ~?;,~ Marcus A. McKnight, III Attorney for Defendant ~ i"" ... , <"'""''''-r -~ ~ -~f' f~,:~ "':""J;T'\RY o!JUr~?7 ~~H;2:08 CUMt~t::r:\i.j >-:1) COd!\rrY PENNSYLVN\iiA ". "".', !lI' "'~'6WJi!!mr-,_ "'-' T"S' ." .. ~""I """""Ill' .. I "1,__ " '. ~ " MICHELE L. DONOVAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 00 - 892 CIVIL HANK P. DONOVAN, Defendant IN DIVORCE THE MASTER: Today is Wednesday, March 28, 2001. Counsel have requested that we have another conference with the parties in an effort to work out the outstanding economic issues, which is the reason for this meeting. This action was commenced by the filing of a divorce complaint on February 15, 2000, raising grounds for divorce of irretrievable breakdown of the marriage and indignities and the economic claims of equitable distribution, alimony, and counsel fees and expenses. With respect to grounds for divorce, the parties previously signed and filed affidavits of consent and waivers of notice of intention to request entry of divorce decree which were filed with the Prothonotary on March 14, 2001. Therefore, the divorce can be concluded under Section 3301(c)of the Domestic Relations Code. The parties and counsel are going to place on the record a memorandum of understanding setting forth their intentions regarding the resolution of the economic issues which will require some involvement by lending institutions to accomplish the plan that the parties want to put into place. - , ~" .... Mr. McKnight. MR. McKNIGHT: The following is the understanding of the parties regarding the agreement that they have reached and are attempting to implement. MEMORANDUM OF UNDERSTANDJ:NG 1. Husband will convey his interest in the real estate located at 233 Souths ide Drive, Newville, Pennsylvania, to wife contingent upon her refinancing the first mortgage with M&T Bank into her name. 2. From this point forward, wife shall be solely responsible for payment of the mortgage due and owing to M&T Bank. 3. Husband shall, from this point forward, assume responsibility for making the Beneficial payments and upon receipt of a commitment letter from wife regarding the first mortgage, will then obtain a refinancing of the Beneficial second mortgage into his name alone. 4. Husband will also payoff the truck loan which is currently in both names for his Ford Ranger to Ford Motor Credit and wife agrees to sign over title of the Ford Ranger to the husband. Wife shall assume sole responsibility the Sears and Visa charge cards and shall any responsibility for payments thereon. for the payment indemnify husband 5 . of for 6. Upon the receipt of the commitment letter from the institution refinancing the first mortgage and as part of the refinancing of the Beneficial loan, husband will also obtain an additional $1,200.00 which he will pay over to the wife as consideration for this settlement. 7. The parties will maintain and retain sole title to all the property that they each have in their own possession and that includes the wife's Escort which is her sole property, all of the household furnishings which she has, and each party will keep their own checking accounts and savings accounts in their own name. 8. Each party waives any right, title, and interest in the retirement proceeds of the other party. - . . r ~""" I~ .. 1']' 9. Each party agrees to sign any documents which need to be signed to facilitate the implementation of this memorandum of understanding. 10. Each party will be responsible for any and all obligations associated with their refinancing, whether that be costs of recording of the deed, sales tax, registration costs associated with the vehicles or the mobile home, and similar costs. THE MASTER: Parties and counsel are going to return later today to review the memorandum of understanding and to sign affirming the understanding with respect to the procedures to be employed in resolving the economic issues in this case. riffie for Plaintiff 5bJifCd 'Date ~"'~.~~~~ Michele L. Donovan Plaintiff ~~I Da e ~/d~~ Hank P. Donovan Defendant --"""""",~.- MICHELE L. DONOVAN, Plaintiff v. HANK P. DONOVAN, Defendant TO THE PROTHONOTARY: - , : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2000-892 CIVIL TERM : IN DIVORCE PRAECIPE Please withdraw the Petition for Contempt previously filed in the above captioned matter Respectfully submitted, fi, squire Jor aintifJ GRIFF ASSOCIATES 200 orth Hanover Street Carlisle, P A 17013 (717) 243-5551 (800) 347-5552 -.....d~>4.-.>IIfiII~!iimi!%M'"\~\!:8@'M~,'illiL~ll'''.fim!k~~~MW,''''i'-,<fJl!",\''"...1W1.i..~~'fM,;,,:~U1~~lf ~llIlliJllJ ill -~~'i:J~Hil.t~\ii'lr~ .. "',' 0 0 (j C -(1 ~ :;e: -ace Cl ~Ti !:DO' ;C:: Jf-:'-...v' N ~:,:~~ :ZC;;: (f) ".:.. '~<=J -<L:.. Gel :s " 'J;; C):D ZO -"" "yO ~.-rn -0 "1;-:" ~ :J>c ~ '> :n N -< .