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Home My WebLink About00-01238 ,"~1'"""'l1'" " " " " ;F. ;F. it! it! it! " " it!;F.;F. Of. " " ;F.;F. ff.ff.;f.Of. Of. Of. ;F.;F.;F. Of. Of.0f.0f. " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY " " " " " " STATE OF " nA'R'RTN .T()'RN 1MnT.T.~ Pl "i nt-i ff " " " VERSUS " DF.RRA T.F.A WAT.T.~ " " " Defendant " " " " " " " AND NOW, " " " DECREED THAT DARRTN ,TOHN WALLS , PLAINTIFF, " AND DEBRA LEA WALLS " " " " " " PENNA, NO. 1238 2000 DECREE IN DIVORCE Idw.,Ao , .:IS"''' , 2003 , IT IS ORDERED AND , DEFENDANT, 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; " " " Thp {Tlrrip!=: h;:l"TP PYPr'!llrPn ;:In ;:\limnny ;:IgrPP-TTlPnr. filpt=J FAhT11;:lry fi, 1001, " " " " " " " w1iiCh shall be incorporated. but not merqed into this decree. " " " " " " " " "" ,',-'--- ., O~R/t ;l (4; PROTHONOTARY " Of. Of. Of.0f.ff.:+::+:;F. " " " " :t.:f. Of.:f. :f. :f. ~- ~", :f.:f.;+;~lf. " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " J, " " " " " " " " " " " " " " ,,' ~""";, 1___..,._ ilti~!i>Ji!'.<illiljiti ;J' ..2[P 03 ,;) . ;:}/. 03 '" i.... ~ "-~.. ',." "(-'~ W-~;;~i;~7'~ 11~~?) d:f ~ ~ " " ." ," PETERJ.RUSSO,ESQUIRE Supreme Court ill: 72897 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 Attorney for Plaintiff DARRIN JOHN WALLS Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DEBRA LEA WALLS Defendant NO.2000-1238 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. Divorce Code, Ground for divorce: Irretrievable breakdown under Section 330l( c ) of the 2, Date and manner of service of the Complaint: Complaint served on DEBRA LEA WALLS by Certified Mail, with return receipt on March 6. 2000. 3, Date of execution of the plaintiff's affidavit required by Section 330l(c) of the Divorce Code: January 10. 2003, Date of service of plaintiffs affidavit on defendant: January 22. 2003, Date of execution of the defendant's affidavit required by Section 330l(c) of the Divorce Code: January 27. 2003, 4. Related claims pending: None C~~ Date: ?--/3-Q3 Peter J, Russo -""~, .'<--' ._",.?,,-,,',;,,- ";f'1 , .0." " ... ,~. .. ...... .. ~. ,,~ , "-, . ~, ..- ,,,;__,,,_,.c_~~_"C,,"-- ~- ,,,e """~ ,,~.. ,-~"-~~ '" (') a 0 C <..oJ "n ~ -., -~ V[T' -., -~;"I -Tj rnfT C;~.J Z:::r, .'---n ;2:: '~i i:;::) (;')> '-0 -< ...;::. ::';C) r:::c. v , S..._. 2 '. ~",., ~ c.. ;'-'. > C r-v ~ ;::: I',) --I ~, .< _ 1, ".~ _.I!\!IMll'!~"'~1 ..j ~ vs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO,2000 - JJiJ> CIVIL TERM : CIVIL ACTION - LAW DARRIN JOHN WALLS ' Petitioner DEBRA LEA WALLS, Respondent : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT, If you wish to defend against the claims set forth in the following pages, you must take prompt action, You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff, You may lose money or property or other rights important to you, including custody or visitation of your children. When the grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling, A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pelillsylvania, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator - Fourth Floor Cumberland COlmty Courthouse Carlisle, Pennsylvania 17013 Telephone (717) 240-6200 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990, For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office, All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. James J. Kayer, Esquire Attorney for Plaintiff Liberty Loft 4 East Liberty Avenue Carlisle, PA 17013 (717) 243-7922 I.~ . ,- "~- . -, . DARRIN JOHN WALLS Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs : NO,2000- /:l3Y : CIVIL ACTION - LAW CIVIL TERM DEBRA LEA WALLS, Respondent : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 330l(c) and 330l(d) OF THE DIVORCE CODE COMES NOW, PlaintiffDarrin John Walls, through his attorney, James J. Kayer, Esquire and avers as follows: COUNT I - DIVORCE 1. Plaintiff is Darrin John Walls, an adult individual, whose current address is: 1504 Terrace Avenue, Carlisle, Cumberland County, Pennsylvania, 17013, 2. Defendant is Debra Lea Walls, an adult individual, whose address is: R.D. #3, Box 78 New Florence, Westmoreland County, Pennsylvania, 15944. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4, The Plaintiff and Defendant were married on October 18, 1986, Dayton, P A. 5. There have been no prior actions of divorce filed in this matter, 6. Plaintiff or Defendant is not a member of the United States Armed Forces, 7, The marriage is irretrievably broken, and the parties are proceeding under Section 3301(c) and Section 3301(d) of the Divorce Code, 8, Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling, . WHEREFORE, Plaintiff requests the court to enter a decree of divorce. Respectfully submitted, J Li rty 4 ibe C lisle, A 17013 (717) 243-7922 Date: March 3, 2000 f" ,,_.~ - ,-- . I ... << VERlFICATION OF PLEADINGS The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action, The language of the document may, in part, be the language of my counsel and not my own, I have read the statements made in this document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the statements are that of counsel, I have relied upon counsel in making this Verification, 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: 3 / 3 I ,2000 ~ (7.IUJfl= / ~ , - ,",'-'.'~ .". "'- 1'"'" ~ C- og III ~. ::!.'< ~r- , CD CD ~- ;:p :j'-o -..J CD It -" I\)"~ ~Ulm W'S. " 1 '<r "'"'" Dl -- CO"U I'\) -, CD 1'\),Q,l ;:+ ~'< -,J)> 0< ~CD w" C CD >- a:: <' ~.~ (),;~;, ,-~,d;:!.~ iX!-i-!~,j _1.. h-. )>,::; ~Cl g,'o( CD (\) ~ ~ O' Cl i;i ::l -0. o Q OJ 1J ... o 0 ~:e g :l <:5 0) :t.r: O~ >- I:; :':':- --:.~ '-,-:..'-5. .~~'~ ,;'~L~ :':~ .::~ (,) ~-Ir' (1- ("> I 10''' ~. ::lit o C) ,. l't'.. h -...J ~ rt: .'.. ().' '.60 ...~. ~G i:? ~. ~~..~ 11 .~. .~ '" .~. ti. ., ....~ ~'.. R '4,,: , . . Kayer and Brown AProfessional Corporation Liberty Loft . 4 E. Liberty Avenue . Carlisle, PA 17013- (717) 243-7922 , _, _'___..",.,..-___"......".____~' .___~_~_..~.,.-_"~"__ _.~__ _~,___ - '._"-0',"_.--- ',',., j, - ~ (: .. . 4, "Iii ~11ll\1andlor2foraddmO~"rvl_, 'iI .ColilPliitell<i!ll8,S,40, arid 4b, "",:,;; II! -Prinf}iOur nBmEl and address on the r8lI8'rU ofthi8Jorm 80 that we can retum thi8 I!! card to you. "I .AttacI\thI*form to the tront at \he maUpIece. or on \he batk If apace does not . -=~86hJ~: Requsitstron themaiiplece.baipw 1he"article-number. a .TfIeRetum - ow to wtIom the artfcle waadeRvered and the date Ii delivllted, 11 3, Article res I U~<<~ l~~ \}Jt><.Ll<::' i ~U-'d"3 6D)(. \~ ~~1.0 ?\O~(\c,~ ~ '\ s::,q 'I '-/ I elso WlshtD re...1ve the~' foIlow1tlg services (for en extra fee): Ii 1, 0 Addressee's Address ~ i 2, .... ~cted Delivery Ul ' a ConsuR poslmester for fee, ii ~rIicle Number ii \--' S ~ 4b, Service e i o Registered ~fled a: Dl o Express.Mell " 0 Insured .5 ~ Recelptlor,COD ~ 7, Dal& 01 .alii" J! <9 ~ ,0 ~ 8, . ill ..~ Jl ii I 'j "! i :'1 ! 'I .-! 'Ii H i:i !j 1 1~ ~ ;'; ~ " ~ .!! 5. Received By: (PtinI Name) [I " 1 ':1 '''1 :) ,I I " 'I I - ~ - ,-," .. ,~ " <' ~ DARRlN JOHN WALLS Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANLA vs : NO.2000 - I J..3t' : CIVIL ACTION - LAW CIVIL TERM DEBRA LEA WALLS, Respondent : IN DIVORCE AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO ]>a. RoC.P. 1920.4(a)(1)(ii) COMMONWEALTH OF PENNSYLVANIA : SS. COUNTY OF CUMBERLAND I, James J. Kayer, Esquire, being duly sworn according to law, deposes and says that he is the attorney for Plaintiff, DARRlN JOHN WALLS, and that he did serve a true and correct copy of the Notice to Defend and Complaint in Divorce that was filed in the above matter, by U,S, Mail, postage prepaid, certified with restricted delivery, return receipt requested, unto the Defendant, DEBRA LEA WALLS, on March 6, 2000, The return receipt is attached hereto, Sworn to and subscribed before me day of Marc , 000, TARlAL SEAL DENISE PINAMONTI, Notary PUbllo arlisle Borough, Cumberland County "-~. .Commissi<?" Exptms...Nov....2O.-2000.. . . .. ~ . .""r~'!r ~ ,. ? ,- :>-c a: h'f ,~~: ~E2. "')~- '~~~$ ,_:i~:~~7 ~: 1,1..:... o c: 0' o Cl> )> "' ;:+;;li;, ~'< '::;",0) ~ 5: 'Q. '< ' -SO;:;o ~ (1) ':1 -u en, ~ -....J CD . a-.02 '-";::J ~ ':J ,::::s ~ ~ m ~-c. to'<. 0 ~ ~ c: '0 Jl" <D :J 0'" U ,.., 1\:)00" CD 0-,'0 '" '<;:+ "'c: -I. ,a < Cj ~ 0 ;:',' -" CD ::I toOl C Cl> w tn ,M ,~ f5< Q"", r -....,..-~ .~."" ,n:5 7:>- ;'i:;;;r;> _'-.J~ 0:2 iJ.JW .:no... :k: ::) (,) ::!t: 0- C;> n:: r,,~j~ :rc o o ,'" '",,>:' '" . ,.:...... Liberty Loft " Kayer and Brown A Professional Corporation 4 E. Liberty Avenue" Carlisle, PA (717) 243-7922 ~~.------:---~"~-""-~""""""-'-'-""~-~-~~---~-- E 17013 ... - PETERJ. RUSSO, ESQUURE Supreme Court ill: 72897 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 Attorney for Plaintiff DARRIN JOHN WALLS Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CML ACTION - LAW DEBRA LEA WALLS Defendant NO.2000-1238 CIVIL TERM IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO ENTER DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 3, 2000, 2, The marriage is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3, I consent to the entry of a Final Decree of Divorce without further notice. 4. I understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses if! do not claim them before a divorce is granted, 5, I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary's Office. 6, 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. I understand that the court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me on request. 7. Being so advised, I, DARRIN JOHN WALLS, do not request that the Court require my spouse and me to participate in counseling prior to a divorce decree being handed down by the Court, ~: - - '-~,~"" " ,- I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C,S, S 4904 relating to unsworn falsification to Authorities, I frcJ~3 DATE ~ '" " ~_, ""~~~ "_l" U,-,,; rnl'.. z:-:-;: ~t ""r'", _ Z;".;:: y;C: --;:.'" ~, --I -< .... () ~ c. ,,~~ -'!:> ['"'>.) '2 '_n \j) ~"- ...' _.....'_~ "-,,,,,,,'!'!Ilt'''''''''''~'''''Bf'';''~W;!'il'r''~Q.~ ,~~.;'Brr _~~....~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE Defendant. ) ) ) ) ) NO, 2000-1238 CIVIL TERM IN DIVORCE DARRIN JOHN WALLS, Plaintiff, Vs, DEBRA LEE WALLS, AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENT TO REQUEST ENTRY OF DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under ~ 3301(c) of the Divorce Code, was filed on March 3, 2000, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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 without notice, 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted, 5, I understand that I will not be divorced until a divorce decree is entered by the court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Date: I - a r; - () 3 l)~ LA.Pu~o.... Ldo 0 }J:, DEBRA LEA WALLS ~ .. llII!ilM~_~....l"i"I ~,~ ~, ~~ "-'-, , ,~ ~-- """""" "'"U .-----111 () C;. 0 C <A) :?" -n -ad; .." gJcr ", OJ 55,i:~ I i"":':: n; --< :?~ 0-, c:: !",-c,' '~-,} ~~ ~o -.;:~ ~~i'-~ "',"~ .. .... ) ...~C: r:? ::5 ?? :z ~-;! =2 01 u, :':0 , ~, ll"<""'il\"!lll!!""~"-'\~-";i""ffi'!!~ilf!!J'__'1_~_~I!t<l~r""IliIIM'iIf!ElQ!llfIIi1'J~ DARRIN JOHN WALLS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V CIVIL ACTION - LAW NO. 00-1238 CIVIL TERM DEBRA LEA WALLS, Defendant IN DIVORCE IN RE: PETITION FOR BIFURCATION ORDER OF COURT AND NOW, this 4th day of December, 2002, in accordance with the agreement of the parties as announced in open court and in their presence, the petition for bifurcation is granted, and the decree in normal form will be signed upon its submission to the court. It is further directed that the spousal support order entered in the Court of Common Pleas of Westmoreland County at 00503 DR 2000 be converted to an order for alimony pendente lite, It is further directed that the plaintiff/petitioner pay to the defendant/respondent the sum of $125.00 per month for the next six months for the cost of insurance. By the Court, :bg ? l ~ aJ.J.. 1Y)RJ\s }~'6.0a. /ld- /Peter J. Russo, Esquire For the Plaintiff ) Ronald L, Chicka, Esquire For the Defendant I. , ,'0 ^ ." ~~~ iiIIiiiilIliidlii~"""" 11lIiiW~~lflti!Ijj~~~til~~i~~ I.~,,, ,",,'-" , ,- ,,"-- FILED-Or:HCE Or-- T" jr !,,\1',r,T' irV l(lTAR\I ;- ;~I~" ;..:~ )'.-.:;,.-I\.),f-\. 1 02 DEC -5 /\1110: [,2 GUMBEnut'io COUNTY PENNSYLVANIA ~," I, "'='-"~~., ~. ~~ '.' . DARRIN JOHN WALLS Plaintiff llN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DEBRA LEA WALLS Defendant NO.2000-1238 CIVIL TERM IN DIVORCE STIPULATED ALIMONY AGREEMENT AND EQUITABLE DISTRIBUTION This Agreement is hereby made and entered into this 7."'7u..day of JthIl . , 2003, by and between DEBRA LEA WALLS, "Wife," and DARRIN JOHN WALLS, hereinafter "Husband," Witnesseth: Whereas, the Parties hereto a re husband and wife, having been married on October 18, 1986; and Whereas, marital differences and difficulties have arisen between the Parties; and Whereas, Parties have separated physically and intended to continue to live apart and desire to forever completely settle, separation of their marital and non-marital, real and personal, belonging to either and/or both of the parties hereto and all other rights, entitlements, benefits, and privileges involved between the parties hereto arising directly or indirectly out of the marriage relationship; and Whereas, Parties have had adequate time and opportunity to consult with separate legal counsel of their own; and Whereas, both Parties acknowledge that they are satisfied with the legal advice they have received and understand the full importance ofthe Agreement they are entering into; and "', ." .-''C''., ,-, ,- . -" --f " - -~ Now, Therefore, the parties, in consideration of the foregoing premises, and the mutual promises and undertakings hereinafter set forth, agree as follows: 1. RIGHT TO LIVE SEPARATE It shall be lawful for Husband and Wife at all times hereinafter to live separate and apart from each other and to reside from time to time at such place or places as he and she shall respectively deem fit, free from any control, restraint or interference,"direct or indirect, by each other. The foregoing provisions shall not be taken to be any admission on the part of either Husband or Wife of the lawfulness or unlawfulness ofthe causes leading to their living apart, 2. FREEDOM FROM INTERFERENCE Each party shall be free from interference, authority and contact by the other as if he or she were single and unmarried except as necessary to carry out provisions of this Agreement. Neither party s haIl harass the 0 ther 0 r attempt toe ndeavor to harass the 0 ther, nor compel the other to cohabit with the other, or in any way malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 3. DISTRIBUTION AND RELEASE OF MARITAL DEBT The parties agree: a. Wife assumes full responsibility for any indebtedness that she has contracted or incurred in her name, alone or jointly, after the date of separation, Wife represents and warrants to Husband that, since the date of separation, she has not contracted or incurred any debt or liability, for which Husband or his Estate might be responsible, and shall indemnity and save Husband harmless from any and all claims or demands made against his or his Estate by reason of debts or obligations incurred by Wife and/or assumed herein, b, Husband assumes full responsibility for any indebtedness that he has contracted or incurred in his name, alone or jointly, after the date of separation, Husband represents - "~ . --- --=-=~'.' - <-~ - --,- ",,< ,--- and warrants to Wife that, since the date of separation, he has not contracted or incurred any debt or liability, for which Wife or her Estate might be responsible, and shall indemnify and save Husband harmless from any and all claims or demands made against her or her Estate by reason of debts or obligations incurred by Husband and/or assumed herein, 4, CONTENTS OF THE MARITAL RESIDENCE As of the date of the execution of this Agreement, the parties shall transfer and assign their rights, title, claim and interest in specific property, Wife shall have as her own, free and clear of any claims of Husband, all of the items, household goods, furniture, furnishings, appurtenances, and appliances presently in her possession, Husband shall have as his own, free and clear of any claims of Wife, all of the items, household goods, furniture, furnishings, appurtenances, and appliances presently in his possession, 5. MISCELLANEOUS PROPERTY - PERSONAL and MARITAL With the exception of the items set forth on Exhibit A, it is further agreed that both Husband and Wife shall retain as his or her own any and all personal effects, clothing, and personal jewelry, The parties further agree that any property not assigned in this Agreement as marital or non-marital property will be deemed the property of the physical possessor of said property, The parties agree to disbursement of said funds, within thirty (30) days of the signing of this Agreement, in the following manner: a, Wife shall receive i, 2002 Federal Tax Rebate of$600,OO; ii. 2001 Federal Tax Return of$5,241.00; and iii, $8,092.66 held in escrow from 2000 Federal Tax Return and the sale of the martial residence a, Husband shall receive $3,800.00 from Wife. "---, ~,. ,>^ 'I " , 6, RETIREMENT ACCOUNTS Husband shall provide Wife with a QDRO distributing one half (1/2) of the value of Husband's retirement accounts as of the date of the execution of this agreement. Wife shall be entitled to all increases or decreases in the value of the same between the date of the execution of this agreement and the actual date of distribution, 7, JOINT ACCOUNTS The parties further specifically agree that all bank, savings, cash and checking accounts shall become the sole property of party named on the account. 8, TAX LIABILITY The parties hereto believe and agree that the division of property heretofore made by this Agreement is a non-taxable division of property between co-owners rather than a taxable sale or exchange of property. Each party promises not to take any position with respect to the adjusted basis of the property assigned to him or her with respect to any other issue that is inconsistent with the position set forth in the preceding sentence on his or her Federal or State income tax return, 9, MUTUAL RELEASE Subject to the provisions of this Agreement, each party waives his or her right to alimony any further distribution of property inasmuch as the parties hereto agree that this Agreement provides for an equitable distribution of their marital property in accordance with Peunsylvania's Divorce Code, Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all caused of action, claims, rights or demands whatsoever in law or equity, which either of the parties ever had or now has against the other, except any or all causes of action for divorce and except any or all i^,~^,-._",~_, ,,,~_,,.~ '''''.,' , ~'"" - ,-~ < -. ~ I . ".R r:- .. caused of action for any breach of any provision of this Agreement. Each party also waives his or her right to request marital counseling pursuant to Pennsylvania's Divorce Code, 10, ALIMONY Husband shall pay Wife Four Hundred Fifty Dollars ($450,00) per month as alimony for a maximum of 24 months, Both parties acknowledge and agree that the provisions of this Agreement providing for alimony are fair, adequate and satisfactory based on actual need, ability to pay, duration of the marriage and other relevant factors taken into consideration by the parties, Although the approval of this Agreement by a court of competent jurisdiction in connection with this action in divorce filed by Husband or Wife shall be deemed an order of the court and may be enforced as such, this Agreement. Alimony shall be made payable through Wife's local Domestic Relations Office, Alimony shall commence and alimony pendente lite shall terminate on February I, 2003, II. ALIMONY PENDENTE LITE, COUNSEL FEES AND EXPENSES Both parties hereby acknowledge and accept that the provisions of this Agreement providing for the equitable distribution 0 f marital property are fair, adequate and satisfactory to them, Both parties agree to accept the provisions of this Agreement in lieu of and in full and final settlement and satisfaction of all claims and demands that either may now or hereafter have against the other for alimony pendente lite, counsel fees any expenses during and after the commencement of any divorce proceeding between the parties, The parties further acknowledge that the alimony pendente lite Order entered by the Honorable Kevin A, Hess on or about December 4, 2002, shall terminate upon the entrance of an alimony order that is expected to occur on or about February I, 2003. However that provision of the order that requires Husband to pay an additional $125.00 per month for six months for costs of I I :,1, . , ~,~,,'~ ~. ,- --,~ ,~ ^ - F" ~ insur!ll1ce shall remain in full force !Il1d effect !Il1d shall be in addition to the alimony provisions set forth herein. 12. INCOME TAX RETURNS Husband and Wife agree to file individual tax returns for each year beginning in 2002. The parties specifically agree that Husband shall be entitled to claim Christopher John Walls on his federal, state and local tax returns in each year Christopher John Walls is eligible to be used as a deduction, Mother shall have the same right with respect to the remainder of the children, 13, WANER OF CLAIMS AGAINST ESTATES Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the martial relationship, including, without limitation, dower, courtesy, statutory allowance, widow's allowance, right to take intestacy, right to take against the will of the other, and right to act as administrator or executor of the other's estate. Each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims and both parties will revoke prior wills or testamentary docwnents, 14, AGREEMENT NOT PREDICATED ON DIVORCE It is specifically understood and agreed by and between the parties hereto and each of the said parties does hereby warrant and represent to the other, that the execution and delivery of this Agreement is not predicated upon nor made subject to any agreement for institution, prosecution, defense, or for the non-prosecution or non-defense of any action for divorce; provided, however, that nothing contained in this Agreement shall prevent or preclude either of the parties hereto from connuencing, instituting or prosecuting any action or actions for divorce, either absolute or I" -,7 - ,- -" ~ . . otherwise, upon just, legal and proper grounds; nor to prevent either party from defending any such action which has been, mayor shall be instituted by the other party, or from making any just or proper defense thereto, 15. SUBSEOUENT DIVORCE There has been a divorce proceeding commenced by Husband against Wife in Cumberland County, The parties hereby mutually consent to a divorce and the entering of a divorce decree on the no-fault grounds that their marriage is irretrievably broken pursuant to g3301(c) of the Pennsylvania Divorce Code, Parties herein shall execute Affidavits of Consent and a final decree in divorce will then be obtained, 16, BREACH AND ENFORCEMENT If either party hereto breaches any of the provisions of this Agreement, the other party shall have the right to bring any actions or actions in law or equity for such breach, and the breaching party shaH be responsible for the payment of all costs and reasonable legal fees incurred by the other party in enforcing his or her rights under this Agreement. It is expressly understood and agreed by and between the parties hereto that this Agreement may be specifically enforced by either party in Equity, and the parties hereto agree that if an action to enforce this Agreement is brought in Equity by either party, the other party will make no objection on the alleged ground of lack of jurisdiction of said Court on the ground that there is an adequate remedy at law, The parties do not intend or purport hereby to improperly confer jurisdiction on a Court in Equity by this Agreement, but they agree as provided herein for the forum of equity in mutual recognition of the present state of the law, and in recognition of the general jurisdiction of Courts in Equity over agreements such as this one, 17, RE-ACKNOWLEDGMENT -, -",. ,._~ , , ., - -~_. . _ c, Each party acknowledges that it may be appropriate and required that this Agreement be re- acknowledged at some time in the future before the Clerk of the Commonwealth Court, Clerk of Orphans Court or some other Court, and each party agrees that they will re-acknowledge their signature before the Clerk of such Court upon request of the other party so that this Agreement may comply with the acknowledgment rules and provisions of any such Court. 18. ADDITIONAL INSTRUMENTS Each of the parties hereto agrees that he or she will join in the execution, acknowledgment and delivery of any deed or other document which may be reasonably necessary to carry out the intent of this Agreement, and, in the event either of the parties hereto would not join in the execution, acknowledgment and delivery of such instrument, then such party does hereby irrevocably appoint the other party hereto as his or her Attorney-in-Fact to execute, acknowledge and deliver such instrument hereby ratifying all that such other party hereto may do by virtue hereof with a copy 0 f t his Agreement to be a sufficient Power of Attorney to carry out the intent and purpose of this paragraph. Nothing contained in this section shall affect the right of one party to expressly include or exclude, as the case may be, the other party as beneficiary in any will, insurance policy or other document whether the same is presently in effect or would become effective in the future. 19, VOLUNTARY EXECUTION The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective legal representatives, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, with full knowledge of the assets of both parties, and that it is no the result of any duress or undue influence, The parties acknowledge that they have been furnished with all information relating to the financial affairs of the other which has been requested by each of them or their respective counsel. - ,,-'" 20, ENTIRE AGREEMENT This Agreement contains the entire understanding of the parties and there are not representations, warranties, covenants or undertakings other than those expressly set forth herein, 21. DISCLOSURE Each of the parties hereto aclmowledges that there has been full disclosure of all relevant matters of each party to the other party, that each of the parties is fully cognizant of his and her legal rights and liabilities with respect to the terms and conditions of this Agreement, that he and she understand the legal effect of this provisions of this Agreement and aclmowledge that this Agreement is fair and equitable to each of the parties hereto, and that this Agreement was entered into voluntarily and without any undue influence or duress upon either party hereto. 22, MODIFICATION AND WANER This Agreement shall constitute a full, complete, and total binding Agreement between the parties concerning support, maintenance, alimony and property settlement, and is precluded from modification EXCEPT ifthe parties specifically agree to modify this Agreement. Any and all modifications to this Agreement shall only be by written agreement containing the same formalities as this Agreement and shall exhibit the notarized signatures of both parties, along with two witnesses. The parties specifically agree that they may rescind this Agreement only by written agreement containing the same formalities as this Agreement which shall exhibit the notarized signatures of both parties, along with two witnesses. Any waiver of a breach of any provision of this Agreement shall not constitute an ongoing waiver, - ~ ,,~ '-f,L ,f',;'-m' Co "~ , <-_<7, . ~, ", 23. PRIOR AGREEMENTS This Agreement constitutes the entire understanding and agreement between the parties hereto, and there are no other representations, warranties, covenants, understandings or agreements other than those expressly set forth herein. 24, lNCORPORATION INTO DECREE OF DNORCE Unless as otherwise provided herein, this Agreement shall be incorporated in and made a part of any Decree that might be entered in any dissolution proceeding between the parties hereto upon the filing by either or both parties of an executed copy of this Agreement in such al;tion and same may be incorporated by reference into any such Decree or court order, 25, DESCRIPTNE HEADlNGS The descriptive headings used herein are for convenience only, They shall have no effect whatsoever in determining the rights or obligations of the parties. 26. INDEPENDENT AND SEPARATE COVENANTS It is specifically understood and agreed by and between the parties hereto, that each paragraph shall be deemed a separate and independent covenant and agreement. 27, APPLICABLE LAW This Agreement shall be interpreted in accordance with the laws of the Commonwealth of Pennsylvania. 28, VOID CLAUSES If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects, this Agreement shall be valid and continue in full force, effect and operation '',--r ' ,- ." -" ~,-"":"- ,,.,.-- . 29, AGREEMENT BINDING ON HEIRS This Agreement shall inure to the benefit of and shall be binding upon the parties hereto, their heirs, executors, administrators, successors and assigns, 30, EFFECTIVE DATE This Agreement shall be considered to be effective at 12:01 a,m. on the date set forth on page one of this Agreement. In Testimony Whereof, witness the signature of the parties hereto this ~ 7 fAday of _ Jan Vell V ( ,2003, (1 b vlc ~ Cl L<Ju 0 !LA DEBRA LEA WALLS ~~~. Witness for DEBRA LEA WALLS .hra~ ~tness for DARRIN OHN WALLS ,",--,. ,."". - t \ -, STATEOF ~ COUNTYOF tJ~ SS. On this, the .:11ddayof ~ ,2003, before me, a Notary Public, personally appeared DEBRA LEA WALLS and in due form of law acknowledged the foregoing Property Settlement Agreement to be her act and deed, and desired that the same might be recorded as such, Sworn to and subscribed before me this1i, day Of~2003, ~~~ Notary Public NotariaISlllII DIane e, HewItt. NcIaJy PICIIc '\= we.r.,...elandCouoly EJPlaOct.17.:!l105 ~''''._~''Illlj liIli.nOfNDtaries II ,-, " ~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. )". ~'" ~ On this, the ~ day of ~ ~1II","" ~ ' 2003, before me, a Notary Public, personally appeared DARRIN JOHN WALLS and in due form oflaw acknowledged the foregoing Property Settlement Agreement to be his act and deed, and desired that the same might be recorded as such, Sworn to and sub~bed before me this ~ Gay of Sj;IoN. ,2003. ~~~~ Notarial Seal Kanln L BlJII'h, NotaJy Public Mec!1anicsburg Boro, Cumberland County My Commission Expires Nov, 24, 2005 Member, Pennsylvania ASSOOIation Of Notaries 1-- "', ,,-~.._, ,",,,'"- , -r,,-. EXHIBIT A Items to be returned to Mr, Walls: 1. All war photos ofMr, Walls 2, All other documents of a personal nature belonging to Mr. Walls, .t' ~ -,' . . '" ' " ., ' ~ - , I~ ,_ _, ," ",- ~..,.., . ,~ -" '^- ~~ "^' '-~-'-",-- ~"p ~ ~-..- -"~,-".~ ~'_..,.,,!l1~'~~ 0 CO' ~ C c. ~,-; -.' ~, ----11 t}l}J f'"""! .. mr D.J -;::.',--- -"----.--, I ~::J ~i~:r CT. T r<= C) C) -';'", - :r" -::y Z(? ;~4 ;t;i=! !'>-) ~ ':.51 en ... ~ ~~~~ J'-, ,lW' DARRIN JOHN WALLS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, 00-1238 CIVIL DEBRA LEA WALLS, Defendant CIVIL ACTION - LAW ORDER AND NOW, this /(, r day of September, 2002, in consideration of the plaintiff's petition for bifurcation and following review of the answer filed thereto, hearing herein is set for Monday, December 2, 2002, at 9:30 a,m, in Courtroom Number 4, Cumberland County Courthouse, Carlisle, P A, BY THE COURT, Peter 1. Russo, Esquire For the Plaintiff . Ad Ronald L. Chicka, Esquire For the Defendant . ~ ~ 9./1>.0.2.- ~, :rlm " ". .- '-'. , .- ~ ~,~ " ,-" . . . , ~b-"~'~~'''''_~SIIIllj~I__~'~_''''''''-#lOiil;w,.O&,~'Wlnlllilil. -"",0-','. J -Iblb-'= PI c'I,\-,"j'F-'CC, l I....L,-, "'" 1.1.. ""'1':':' 'r- """,,,..,...,., ',"'.' I^~~~'RY lh- ;-. ~< '~.I' .--'\....WL) lh. rl" S-P I 7 \.,/. .t. Pi~ 2: 31 ~u.'n... "'J" ('{'U"1V v 1'}l0ttkd\ U uU IVil PENNSYLv'~NiA ., . .-- ,I II! DARRlN JOHN WALLS, Plaintiff vs, DEBRA LEA WALLS, Defendant AND NOW, this IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-1238 CIVIL CIVIL ACTION - LAW ORDER Z '" day of October, 2002, because of a scheduling error, hearing in the above matter set for December 2, 2002, is continued to Wednesday, December 4, 2002, at 2:00 p,m, in Courtroom Number 4, Cumberland County Courthouse, Carlisle, P A. Peter 1. Russo, Esquire For the Plaintiff Ronald 1. Chicka, Esquire For the Defendant :rlm "'0 ",-" BY THE COURT, . /-1J- , -J,., - ~~ Ib.O.J..()J; 9-. "~-,-~-,~,-~''"-''',.... ", ,JUl ,.;j].., '.. 'I "''1',,," .._~"~ ~~~ ',"," . -'-00. H :;1'C' . ,-^ ~ .p_~ rr~ '_>,,~_,' '" .'A'_"~_,,~ 'or' " ~ F!L~C-O~i~lCE n,- 'p ,," t':"-,r'T' f'I\""ITlt1Y ...Ii~ :rT J ,',' _i:!'~',,_'I,i:')IN'1 02 OCT -2 A~1 ifl: :;4 CUMr, ''''C'' " ", Y', J'I'r\' otl'~,lhdi_i CA.J....I\ I { PENNSYLVN\IIA " -'-~, . ~, .-" ~" , - =--,~- In the Court of Common Pleas of WESTMORELAND County, Pennsylvania DOt'vlESTIC RELATIONS SECTION DEBRA L. WALLS ) Order N umher 00503 DR 2000 Plaintiff ) YS. ) P A CS ES Case N umher 747102094 DARRIN J, WALLS ) Docket N umher 00503 DR 2000 Ddendam ) Other State ID Number ORDER OF COURT o Final ~ Interim 0 Modified AND NOW, 11TH DAY OF MAY, 2000 ,based upon the Court's and the Payor's determinati.on that the Payee's monthly net income is $ o. monthly net income is $ 3,128.00 , it is hereby ordered that the Payor pay to the Pennsylvania State Collection and Disbursement Unit EIGHTEEN HUNDRED FORTY THREE Dollars ($ 1,843.00 ) a month payable MONTHLY as follows: first payment due BY THE 15TH DAY OF MAY 2000. The effective date of the order is 03/15/00 . Arrears set at $ 2486,00 as of MAY 11, 2000 are due in full LvlMEDIA TEL Y. All terms of this Order are subject to collection and/or enforcement by contempt proceedings, credit bureau reporting and tax refund offset certification and will not be initiated as long as obligor does not owe overdue support. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all the means listed above. For the Support of: Name DEBRA L, WALLS JESSE G. WALLS CHRISTOPHER J. WALLS DARRIN L, WALLS Birth Date 12/27/67 10/01/88 07/13/91 04/27/95 Service Type M Fonll OE-518 Worker 1D 65314 . WALLS V. WALLS PACSES Ca,e Numher: 747102094 The defendant owes a total of $ 1,843.00 MONTHLY 51,743,00 per month payable for current support and $ 100,00 for arrears. The defendant must also pay fees/costs as indicated below, This order is allocated and monies are to be applied as follows: hc:qucncy Cl1dcs: Paytll~m Amount! Frequency S 593 .00 1M 5383,33 1M 5383.33 1M S383.34 1M 50.00 I 50.00 I 50.00 I 50.00 I 50,00 I 50,00 I So,oo I So,oo I 50,00 I 50,00 I So,OO I 50,00 I So.OO I SO.OO I 50,00 I SO.OO I [ =()lIC Time H =RiWcckly 2 =Bi-Mlllllhly 5 =Scrni.I\nnually S =Scmi-Monlhly A = Annu:lily M -= Mouthlv W =Wct:ldy. Q = QU<Jrtcrly nehr Type nt'"criprinn Rt"nt"~i{"i~ry SP & CHILD ALLO DEBRA L, WALLS CHILD SPT ALLOC JESSE G. WALLS CHILD SPT ;~LOC CHRISTO?HER J. WALL CHILD SPT ALLOC DARRIN L. WALLS Said money to be turned over by the Pa SCDU to: DEBRA L. WALLS . Payments must be made by check or money order. All checks and money orders must be made payable to Pa SCDU and mailed to: Pa SCDU P,O. Box 69110 Harrisburg, Pa 17106-91lO Payments must include the defendant's PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. 5ervice Type M J',.> Page 2 of 4 Fl1nll OE-5I8 Worker lD 65314 . . , WALLS v, WALLS PACSES Case Numner: 747102094 Unreimbursed medical expenses that exceed $250,00 annually per child and/or spouse are to be paid as follows: 100 % by defendant and o. % by plaintiff. The plaintiff is responsible to pay the first $250.00 annually (per child and/or spouse) in unreimbursed medical expenses, 0 DefendantO Plaintiff 0 Neither party to provide medical insurance coverage. Within thirty (30) days after the entry of this order, the OPlaintiff o Defendant shall submit to the person having custody of the child(ren) written proof that medical insurance coverage has been obtained or that application for coverage has been made. Proof of coverage shall consist, at a minimum, of: 1) the name of the health care coverage provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims should be made; 5) a description of any restrictions on usage, such as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and co-payments; and 8; five copies of any claim forms. O[her Conditions: Defendant shall pay the following fees: Fee Toral SO.oo So,oo Fee Descrintinn Payment Frequency Payable at So, 00 Payahle at So, 00 Payable at So. 00 Payahle at So. 00 Payahle at So. 00 per for for per ') 0 . 00 fOf per ') 0.00 SO.DO for per li)r per Service Type N Page 3 of 4 FornI OE-518 Worker ID 65314 "'_ a" WALLS v, WALLS PACSES Case Number: 747102094 IMPORTANT LEGAL NOTICE PARTIES MUST WiTHIN SEVEN DAYS INFORM THE DOMESTIC RELATIONS SECTION AND THE OTHER PARTIES, IN WRITING. OF ANY MATERIAL CHANGE IN CIRCUMSTANCES RELEVANT TO THE LEVEL OF SUPPORT OR THE ADMINISTRATION OF THE SUPPORT ORDER, INCLUDING, BUT NOT LIMITED TO, LOSS OR CHANGE OF INCOME OR EMPLOYMENT AND CHANGE OF PERSONAL ADDRESS OR CHANGE Of' ADDRESS Of' ANY CHILD RECEIVING SUPPORT. A PARTY WHO WILLFULLY FAILS TO REPORT A MATERIAL CHANGE IN CIRCUMSTANCES MAY BE ADJUDGED IN COlVTEMPT OF COURT, AND MAY BE FiNED OR IMPRISONED, PENNSYLVANIA LAW PROVIDES THAT ALL SUPPORT ORDERS SHALL BE REVIEWED AT LEAST ONCE EVEI3-Y THREE (3) YEARS IF SUCH REVIEW IS REQUESTED BY ONE OF THE PARTIES, IF YOU WISH TO REQUEST A REVIEW AND ADJUSTMENT OF YOUR ORDER, YOU MUST DO THE FOLLOWING: CALl. YOUR ATIORNEY, AN UNREPRESENTED PERSON WHO WANTS TO MODIf'Y (ADJUST) A SUPPORT ORDER SHOULD CONTACT THE DOMESTIC RELATIONS SECTION. A MANDATORY INCOME ATIACHMENT WILL ISSUE UNLESS THE DEFENDANT IS NOT IN ARREARS IN PAYMENT IN AN AMOUNT EQUAL TO OR GREATER THAN ONE MONTH'S SUPPORT OBLIGATION AND (1) THE COURT FINDS THAT THERE IS GOOD CAUSE NOT TO REQUIRE IMMEDIATE INCOME WlTHHOLDING: OR (2) A WRlTIEN AGREEMENT IS REACHED BETWEEN THE PARTIES WHICH PROVIDES FOR AN ALTERNATE ARRANGEMENT. UNP AID ARREARAGE BALANCES MAY BE REPORTED TO CREDIT AGENCIES. ON AND AFTER THE DATEI:r IS DUE, EACH UNPAID SUPPORT PAYMENT SHALL CONSTITUTE. BY OPERATION OF LAW, A JUDGMENT AGAINST YOU, AS WELL AS A LIEN AGAINST REAL PROPERTY. IT IS f'URTHER ORDERED that, upon payor's failure to comply with this order, payor may be arrested and brought before the Coun for a Contempt hearing; payor's wages, salary. commissions, and/or income may be attached in accordance with law; this Order will be increased without funher hearing by 15 % a month until all arrearages are paid in full. Payor is responsible for coun costs and fees. Copies delivered to parties Date Consented: Plaintiff Plaintiffs Attorney Defendant Defendant's Attorney BY THE COURT: Page 4 of 4 curA~ok .I / 'I Judge Form OE-518 Worker ID 65314 Service Type g " ,. ~- ~ ...' In the Court of Common Pleas of WESTMORELAND County, Pennsylvania DOMESTIC RELATIONS SECTION PACSES Case Number: Docket Number: Other State ID Number: 747102094 00503 DR 2000 Plem;e note: All correspondence must include the PACSES Ca.'iC ~uPlhcr. MAY 11,2000 SUMMARY OF TRIER OF FACT Plaintiff Information Defendant Information DEBRA L. WALLS DARRIN J, WALLS Address: RR 3 BOX 78 NEW FLORENCE PA 15944-9747-78 Address: 1504 TERRACE AVE CARLISLE PA 17013-9369-04 Employer: N/A Employer: RALSTON PURINA CO, 6509 BRANDY LN MECHANICSBURG PA 17055-2817-09 Attorney: JAMES J, KAYER, ESQUIRE Attorney: C-lICKA RONALD L [Xl Complaint for Support 03/15/00 0 Petition for Modification Filed o Other Reason for Conference: SPOUSE AND (3) THREE CHILDREN Dependent(s) 10/01/88 07/13 /n 04/27 /95 536-21-5309 535-23-9564 JESSE G, WALLS CHRISTOPHER J. WALL DARRIN L. WALLS 169-76-3229 Current Order: $ 0 . 00 / per month Service Type N Form CM-022 Worker lD 65314 ~ ~ "~~,",,'~".~~__ _e~ WALLS V, WALLS PACSES Case Numher: 747102094 Other Information (continued): Facts Agreed Upon: ,- ,,{ c,~ -:z.... \~">s, c= ~ ,,-\- '\ C\ r -eJ r \ --"- \ () 0 () . '-"" ~____ 6 \ <--Q.. c.. '\- (.:(y Y"'\ ~ Facts in Dispute and Contentions with Respect to Facts in Dispute: Guideline Amount: $---e-:-mJ \ ) y ?, ! 0, c, DRS Recommended Amount: ~ i J Li '-, I fY\ 0 DRS Recommended Order Effective Date: ~! ( ," ) 0(' Parties to be Covered by Recommended Order Amount: ~,=r~ ~~, C"'r-\'<""'-'Q\~ '----d. D,->---rr""-"" , Guideline Deviation: 0 YES ~O Reason for Deviation: Submitted by: TIMOTHY M CAWOSKI Date Prepared: MAY II. 2000 Page 3 of 3 FornI eM-On Worker ID 65314 Service Type M WALLS v, WALLS PACSES Case Numher: 747102094 Defendant Information ~~,\d~,C\l m(L Plaintiff Information Current Income: -CJ~ Tax Return: Medical Coverage: ~ '-,-';-v--r--.....'- ~\\-"" Q\o.r-... <:) Child Care/Tuition: Additional Obligations: Other Information: Page 2 of 3 Form eM-On Worker ID 65314 Service Type N ~~ ,r ,< :1 " :, "i 'I :i I I , ;1 ;1 q n ;i q " I q ,! i:i ~'~ ;,~ i I I : ~ hj , , iJ iP .,! ~ i t.~ ~';, ':, ., I 'j: ;i, ',,, .' " ., 'I " ;:'.~", " PETERJ.RUSSO,ESQUlRE Supreme Court ill: 72897 5010 E. Trindle Road Suite 200 Mechanicsburg, P A 17050 (717) 591-1755 Attorney for Plaintiff DARRIN JOHN WALLS Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DEBRA LEA WALLS Defendant NO.2000-1238 CML TERM IN DIVORCE ENTRY OF APPEARANCE OF COUNSEL Kindly enter my appearance on behalf ofDarrin John Walls, Plaintiff in the above matter. ~~ Peter 1. Russo 5010 E, Trindle Road Mechanicsburg, P A 17050 (717) 591-1755 Dated: ~ /' .. PETER J. RUSSO, ESQUIRE Supreme Court ill: 72897 5010 E, Trindle Road Suite 200 Mechanicsburg, P A 17050 (717) 591-1755 DARRIN JOHN WALLS Plaintiff v. DEBRA LEA WALLS Defendant Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.2000-1238 CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I, Melissa M. Mehaffey, hereby certify that I am on this day serving a copy of the ENTRY OF APPEARANCE upon the person (s) and in the manner indicated below, service by First-Class Mail, Postage Prepaid, and Addressed as Follows: Date: ~-{o -0 ( Ronald L. Chicka, Esquire 12 East Otterman Street Suite 200 Greensburg, PA 15601 ~ ~ ,"i.-'" ~ ~1-," , ~ "",,' ,c.. "''', ~"'-' l'(,ll,~~"'Jfl".J!.~~ .. . ~'l~~ ,,~.._..,.. " '->!,.," 1..1._1 "''''I'M. '" .. 0 0 0 C -1"1 5: :0- ""Om <= T, !;2q:' C'> F: I ~i~ zr; .-.J ~:;::": !;='C "1J -'-:'1 ';')~l >'8 :1';: .~?( ) Z ..- :,,,,,,m PC: '-' '--I ~ 0 .". :u 'D -< ~"....... , ~,. ~~""'~"'! _" ~._ ",...!i0 , . , IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL LAW - DIVORCE I I I ii ~ i i Ii u " I I' II i ! Ii ~~ 11 I~ M I.! ~ \ I" , " II H DARRIN JOHN WALLS, PLAINTIFF, VS DEBRA LEA WALLS, DEFENDANT, ~j ~,) ~1 f.'l [.] ~;J r If '::1 ;" Ii ii II F I'" ~ J, t, [:1 :'~ ~:,: i-I li'l 'I t.; I;,: I., ~" tij t, h , I',j i'l i:,j '.:1 .1 .'1 J ;l 'j ., , - ,,, ,._, ,- ,. - -,~- -- . ,_ __~'C.h_'_, ) ) ) ) ) ) ) NO. 2000 -1238 CIVIL TERM Type of Pleading: ANSWER TO COMPLA COUNTERCLAIM Filed on behalf of: DEBRA LEA WALLS, DEFENDANT, COUNTERCLAIM PLAI Date Filed: Counsel for Record: RONALD L. CHICKA ATTORNEY AT LAW 12 E. OTTERMAN STREET SUITE 200 GREENSBURG, PA 15601 (724) 838-0250 PA 1.0.# 33398 ,'.' ~, .c- C" , . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL LAW - DIVORCE DARRIN JOHN WALLS, PLAINTIFF, VS DEBRA LEA WALLS, DEFENDANT, ii " fj " I' [_l l " I, !) I " p I II :j !) ~:i !! i~ l1 ,~ (i, ij ) ) ) ) ) ) ) ) ) ~,~ ",~ :'~, c;;:.1 ! I I I NO, 2000 -1238 CIVIL T~RM ' ! . ! -"" .;;::- NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation privileges of your children. When the ground for the divorce is indignities or an 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. PA 17013 . !~ :4 W <" i,.,','!',.' " " I, 1! 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, ,,; "i I ';1 ~~ :;1 w. Ii f;j YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Court Administrator - Fourth Floor Cumberland County Courthouse Carlisle. PA 17013 iZ111 240-6200 'ii I?, :ij "., :"J ~ ij iii ;:,; !:~ ,.!- ': If; :;-! ~_:i M i,:J ~ , il -';~J '" ~ .., ~ ,., . " ~,. , IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL LAW - DIVORCE DARRIN JOHN WALLS, PLAINTIFF, VS DEBRA LEA WALLS, DEFENDANT, I, II ,I ~. I! Iii I:, I" .,Ii I' Iii ,II i'i I' II 1',' !' .1 Ii Iii ;1' "I I" II!! , " i! I',",:,' !i Ii! Ii; li1 ~I !il , II",; I,' ,:' I,' i'! !:j ~j " I" II I' Ii! !i\ ) ) ) ) ) ) ) ) ) NO, 2000 -1238 CIVIL TERM ANSWER TO COMPLAINT AND COUNTERCLAIM ANSWER 1, Admitted. 2. Admitted. 3, Admitted. 4, Admitted, 5. Admitted. ,- C) 6. Admitted. 7, Admitted, 8, Admitted, WHEREFORE, Defendant requests the court to enter a decree of divorce. COUNTERCLAIM 1 , Counterclaim-Plaintiff is Debra lea Walls, Defendant in the above captioned matter, !j ! lij I,~ I:, I,", !i Ii' ;; " I!i 1i"1 1"",',1 i! (;'/'..'" 2. Counterclaim-Defendant is Darrin John Walls, Plaintiff in the above captioned matter, ." ~~,~,__ '>ft'" ~ _,e,"" " _'" ~_ , , , , 3. Counterclaim-Plaintiff and Counterclaim-Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of the divorce complaint. 4. The Counterclaim-Plaintiff and Counterclaim-Defendant were married on October 18, 1986, Dayton, Pennsylvania, 5. There has been a Complaint in Divorce filed in Cumberland County at Number 2000-1238. 6. Counterclaim-Plaintiff avers that the marriage of the parties is irretrievably broken, 7, The Counterclaim-Plaintiff avers that this action is not collusive. 8. The Counterclaim-Plaintiff acknowledges that she has been advised of the availability of counseling and that she may have the right to request that the Court require counseling in certain instances. WHEREFORE, Counterclaim-Plaintiff requests this Honorab a decree of divorce, COUNT 11- EQUITABLE DISTRIBUTION i~, b l; H Ii r, i !i [' [I ~ Ii Ii l; [-] II f~ n i; !i l: Ii l! c: rp:I?rateiI (II .1:- :0 herein by reference thereto as though herein more fully set forth at length. 9. 10. Counterclaim-Plaintiff and Counterclaim-Defendant have legally and beneficially acquired property, both real and personal, during their marriage. 11, Counterclaim-Plaintiff and Counterclaim-Defendant have been unable to agree to equitable division of said property as of the date of the filing of this Complaint. i:.__, ," ~,,_" '_d~~-"~ '~d_",_~,.x_~ ","~,~_ ~- "q - - - . '.'- . ~- - WHEREFORE, Count~rclaim-Plaintiff requests this Honorable Court to equitably divide all marital property in accordance with the provisions of the Divorce Code. i I l I I , I Ii: i ~ i !i ~ ~ ;1 t~ ;1 l Ij COUNTER-CLAIM COUNT III - CUSTODY 12. Paragraphs 1 through 11 of this Counterclaim are incorporated herein by reference thereto as though herein more fully set forth at length, 13. Counter-Claim Plaintiff and Counter-Claim Defendant are parents of three (3) minor children, namely Jesse Guy Walls whose date of birth is :~I :;;:;; _: c.;;; j'an<t" -,C'_"" " , October 1, 1988, Christopher John Walls whose date of birth is July 13f 1 Darrin Lee Walls whose date of birth is April 27, 1995. i ! 14, The children were born in wedlock, i (" __ I t; (3 15, The children presently are in the custody of the Co t r-0Iaim::. :0 (...."1 Plaintiff who resides at RD #3 Box 78, New Florence, Westmoreland County, Pennsylvania. g' ;1! 1~ >: !'. ." fi~ ;~i iiJ !~ ,,, m (l: ,:! , (,' "I I~ ;',; " , 16, The children resided with the following persons and at the following ',c' \l1 ':, :fl I ;i) ;::1 ,n 'i'i ;t! :;1 r:1 addresses: (a) From birth to February 15, 2000: 1504 Terrace Avenue, Carlisle, Cumberland County, Pennsylvania with mother and father; and (b) February 15, 2000, to present: with the mother RD 3, Box 78, New Florence, Westmoreland , d ,I j I :1 1 ,'j p~ County, Pennsylvania. 17. The mother of the children is currently residing at RD 3, Box 78, - ,'. ,"-' - ~ _ ;~, _~___~ -y;_c.. _,-,,",,_~_, _~ ,~_ _.. ,"'_'_ __~,,' "0,"" "'~_ " _ >~_ '0',.', ,V'..- ". ,-~'r New Florence, Westmoreland County, Pennsylvania. 18, The father of the child is currently residing at 1504 Terrace Avenue, Carlisle, Cumberland County, Pennsylvania. 19. The relationship of the Counter-Claim Plaintiff to the child is that of I, ~ il I i II I ~ " li"I.. Ii Ii I~ III ( ~I ,e I 11 I: I ~ l~ Ii ~ ~:I I,ll 'J h 1'1' Ii 'I I" iil '" I!: u ii! "I ill i,ll' '_I n ;:: ;:i "l Ii ,I ti Ii U H II t'l !il " III iii L, i:i: ~,,~.~ mother. 20, The relationship of Counter-Claim Defendant to the child is that of father, 21. The Counter-Claim Plaintiff believes it to be in the minor cTI~en'~ best interest and welfare to grant primary physical custody of the said or child; ':;;'_J WHEREFORE, the Counter-Claim Plaintiff, Debra Lea Wall , to Counter-Claim Plaintiff, her with reasonable visitation privileges to the Counter-Claim Defendant as the parties may agree. COUNTER-CLAIM COUNT IV - ALIMONY/ALIMONY PENDENTE LITE COUNSEL FEES. COSTS AND EXPENSES 22. Paragraphs 1 through 21 of this Pleading are incorporated herein by reference thereto as though herein more fully set forth at length. 23. Counter-Claim Plaintiff lacks sufficient property to provide for her reasonable means and is unable to adequately support herself through employment. .h. ,,_ _.._,~_ ._ ., , ---- -,. , , ," _"H~~'" , , I I I I I, Ii II 11 II I I 11 !j II 11 II !1 II ~ I, 'I 11 ii', , f:! I " n I' I, i-: I I' I I:i /i ,,, I,: I;'! I~ [I i"l 1;1 1",1 " I, ~ II II [,.,1,'[' I ii ,,, f':i i,,1 '1.,' I:, " Iii " 1'.1 1',:'1 " I '1,'11 " I" fII 1',Ijl I" !; i,H i"} ~_ " 24, Counter-Claim Plaintiff requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage of the parties hereto, 25. Although Counter-Claim Plaintiff is unaware of Counter-Claim Defendant's actual annual earnings, she believes and therefore avers that he has assets and is well able to support the Counter-Claim Plaintiff. 26, Counter-Claim Plaintiff has employed RONALD L CHICKA, Esquire, as her counsel, but is unable to pay the necessary and reasonable attorney fees for said counsel. WHEREFORE, Counter-Claim Plaintiff requests your Honorable Court to enter an award of reasonable temporary alimony until a final ," permanently thereafter along with counsel fees, costs and expenses. ", t.Fi Ro a L Chicka Attorney for Counterclaim Plaintiff " . - , "" ~~" ~ .- -.- . ,~,. . ' . , VERIFICA liON I, Barbara Jean Smihula, verify that the statements made in the within Answer to Complaint and Counter-Claim are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa, C.S, Section 4904 relating to unsworn iJ " ,! Ii I:f :1 !J I: ii II hi 11 l! 11 [I fl II I'; ( : [I~ ~ m-t::" DEBRA LEA WALLS, DEFENDANY-"1 falsification to authorities, DATED: Ii ~, ,-; ~ i:: !;i H I..' I:! Hi i'i i-i ti I,; i 1:1 i'j " (I !:i ," tJ H " '" ;1 n Ii 1,1 'u',,' ~'__~~_.._',__',~ _~ _". ,,_:, "'~'~_i__'~__,U=" ,-, .,-- --- ",' " ",. . , ,,' ~~, -.~, ,~ -','-Co^'. ~- f(""""",... ~"~,,,. '.1"-' _' ~-"". ~-~~-~ " ~~; - l ~ ~:::: .-':1 0."'\" (; <J.."~~ L.. - II' n c:::: -< c" G ~ ~".,~ 1::-. (Y"l 06,_ ."rJ.-""""'-'-lt:'llU: '" '::,,:.1 -<c ["'P,-f" " _, 1l!~~F ,,....., -,-' .... " - IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL LAW - DIVORCE DARRIN JOHN WALLS, PLAINTIFF, VS ) ) ) ) ) ) ) ) ) NO. 2000 - 1238 C Vlt ~R~ \ ;? \ -'I DEBRA LEA WALLS, DEFENDANT, TYPE OF PLEADING: ENTRY OF APPEARANCE FILE ON BEHALF OF: DEBRA LEA WALLS, DEFENDANT DATE FILED: COUNSEL OF RECORD: RONALD L CHICKA ATTORNEY AT LAW 12 EAST OTTERMAN STREET SUITE 200 GREENSBURG, PA 15601 (724) 838-0250 PA I.D. # 33398 . , I'", ., - _, _" ,,~_, .0/" ":",<. ,'F'",_,,~ _.'''', .<. _."_, . ~ '" _ ,. . ,,~,. . '0" ...---~ -.. ~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL LAW- DIVORCE DARRIN JOHN WALLS, PLAINTIFF, VS DEBRA LEA WALLS, DEFENDANT, ) ) ) ) ) ) ) ) ) NO. 2000 - 1238 CIVIL TERM ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of Debra Lea Walls, d ~ the above captioned matter. Date: b C/ ~ '2eJ()~ -"_r_~ _.,' - ". . _ ., _ "=, ".. _, -.I Ronal . Chicka, Attorney for Defendant 12 East Otterman Street Suite 200 Greensburg, PA 15601 (724) 838-0250 PA 1.0. #33398 I.. J ---- ."'!( , _":HI_.-.-,.".j~~ ~ 0 C) r :?' :"I':: ~" j-: rl"i t ~ -/ ~;: ","- (i~1 ;:::{ ~ (' )> (.1 " ~~ <- -"I :.'_J ..< en -0;:: . < <~ ,. -~~. ~ "'.-..... e" , \, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DARRIN JOHN WALLS, Vs. DEBRA LEA WALLS, " ,~" - - - ~_:' .-___,_ 0",_' CIVIL DIVISION - DIVORCE Plaintiff, ) ) ) NO. 2000 ~ 1238 CIVIL TERM ) ) Defendant. Type of Pleading: ANSWER TO PETITION FOR BIFURCATION/RULE TO SHOW CAUSE Filed on Behalf of: DEBRA LEA WALLS, DEFENDANT Counsel For Record: RONALD 1. CHICKA ATTORNEY AT LAW 12 EAST OTTERMAN STREET SUITE 200 GREENS BURG, PA 15601 (724) 838-0250 P A ID# 33398 :1 I J i I I I '1 ;i ,i- "'- , IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL LAW - DIVORCE DARRIN JOHN WALLS, PLAINTIFF, ) ) ) ) ) ) ) ) ) NO. 2000 - 1238 CIVIL TERM VS DEBRA LEA WALLS, DEFENDANT, ANSWER TO PETITION FOR BIFURCATION/RULE TO SHOW CAUSE AND NOW comes Respondent Debra Lea Walls by and through her attorney, Ronald L. Chicka and files this Answer to Petition for Bifurcation/Rule to Show Cause averring as follows: 1. Admitted. 2. Admitted, 3, Admitted. 4. Admitted. 5, Admitted. 6. Admitted. 7. After reasonable investigation, Respondent is without sufficient information to form a belief as to the truth of the averments in paragraph #7. By way of further answer, Respondent has learned that it would cost more than $400 per month to secure hospitalization coverage equivalent to that coverage which she now enjoys that Petitioner provides through his employment 1 " - ~- '. 8. Admitted. 9. Denied and to the contrary the Petitioner has been unreasonable in attempting to settle this divorce action. Specifically, the parties marital residence was sold on July 31, 2000, and deducted from the proceeds of the sale was $4,779.23 which sum represented monies that Petitioner owed to Respondent as a result of Petitioner being in arrears on his support order. (A copy of the HUD settlement statement is attached hereto, marked exhibit "A" and incorporated herein by reference.) Were it not for said monies being deducted for Petitioner's support arrearages, the parties would have received $9,332.36 rather than the $4,553.13 that is currently being held in Respondent's attorney's trustee account. Despite the obviousness that Respondent should receive the balance of the money from the sale of the house, Petitioner disagrees as per letter from his counsel dated October 20, 2001. (A copy of said letter is attached hereto, marked exhibit "8" and incorporated herein by reference.) It is believed and therefore averred that Petitioner will continue to delay the final resolution by making unreasonable demands and that this divorce action would never be completed due to the prohibitive cost of having a master appointed. 10. Denied and by way of further answer refer to answer to paragraph #9. 11. Petitioner, as a result of his arrearages being paid through the proceeds from the sale of the marital residence, has already received that to which he is entitled, Respondent has not. As a result, Petitioner 2 '\ ',"- ",-.y, ..___'_~L_ .' "_,'" , _,'" 1~ , '" ,.-,~ . " will continue to obstruct and delay in reaching a settlement in this matter which prolongs an unequal economic status quo. Additionally, and more importantly, there exists a current spousal support order in which Petitioner is ordered not only to provide hospitalization coverage for Respondent but is also ordered to pay spousal support to Respondent in the amount of $593.00 per month, which will cease upon entry of a divorce decree. (A copy of the order dated May 11, 2000 is attached hereto, marked exhibit "C" and incorporated herein by reference. 12. (i) It is denied that a speedy resolution of the divorce would allow the parties to restructure their personal lives. To the contrary, a bifurcation of this divorce action would ultimately delay and possibly prevent a final resolution. (Ii) Respondent does not understand the averments of paragraph #12(ii) therefore the same is denied and strict proof thereof is demanded at trial. (iii) It is denied that the bifurcation takes into primary consideration of the welfare of the family rather than the vindication of private rights. Clearly, the Petitioner has not negotiated or attempted to negotiate the end of his divorce in a fair manner. It is believed and therefore averred that Petitioner is merely attempting to prevent Respondent from receiving that to which she is obviously entitled. 3 ,-' ~,' ' - ..<-. - , -1-'- - (iv) It is denied that the parties' personal lives are being held hostage to economic demands. To the contrary, the Respondent is entitled to the proceeds from the sale of the marital residence as above described and Petitioner is holding Respondent hostage to Petitioner's economic demands. (v) Denied and to the contrary, a bifurcation would certainly diminish or impair Respondent's economic claims under the divorce code as then it would become necessary for Respondent to have a master appointed and to be responsible for the cost of a master's hearing when all parties involved and their attorneys recognize that Respondent is entitled to the sums of money being held by Respondent's attorney. (In addition to the house proceeds, Counsel for Respondent is holding an additional $3,791.00 in his trustee account which sum represents the parties income tax refund.) WHEREFORE, Respondent prays that the Petition for Bifurcation be denied and that Petitioner be ordered to pay Respondent's attorney's fees, RESPECTFULLY SUBMITTED Ronald . Chi , Esquire Counsel for Respondent 4 .,,---. ,-" "" .~,."., '" " . ,~.- .. .-" , c A,H,U,D. SETTLEMENT STATEMENT B,LOAN TYPE: FHA Fixed OUR FILE #: REOO-148 Loan #0012332177 LENDER: Cendant Mortgage Corporation C.This form. is furnished to give you a statement of actual settlement costs. Amounts paid to and by the settlement agent are shown. Items marked P.O.C. were paid outside closing. 0, NAME OF BORROWER: E, NAME OF SELLER: Steven I. Kaczur, Jr. Darrin J. Walls Debra Lea Walls G, PROPERTY LOCATION: H, SETTLEMENT AGENT: I. SETTLEMENT DATE: 1504 Terrace Ave., Carlisle, PA 17013 DUNCAN & HARTMAN, P.C. Monday 31 -Jul-OO 1 IRVINE ROW Carlisle Borough, Cumberland Co. CARLISLE, PA. 17013 1:00p.m, J. SUMMARY OF BORROWER'S TRANSACTION K. SUMMARY OF SELLER'S TRANSACTION 100 GROSS AMOUNT DUE PROM BORROWER 400 GROSS AMOUNT DUB .0 SELLER 101 Contract Sal.. Prioe $105.000,00 401 ContreClt- aal.. price $105,000,00 10' Personal Property 0,00 40. Per80nal Property 0.00 103 SettlolUlnt Charges (l.iae 1400) 5272.63 403 104 0,00 000 105 Adjuatments items prepaid by seller I Adjustments items prepaid by Beller: 405 Local tax.. to 31-Deo-OO 229.87 100 Local taxes to 31-D80-00 229,87 400 Asses.ment. 107 Assessments to 407 School taxe. to 30-Jun-Ol 1157.50 lOB School taxes to 30-Jun-Ol 1157.50 40B 100 400 120 GROSS DUE FROM BORROWER 111660.00 420 GROSS DUE TO SELLER 106387.37 '00 AMOUNTS PAI:D BY OR FOR BORROWER 500 REDUC'1IOBS IN AMOUNT DUB '0 SBLLBR '01 Deposit or Earnest Koney 1000,00 501 Bxcess deposit 20. New Mortgage Amountr Cendant 104141.00 so. Settlement. charg.. 13747,33 .03 Existing loans taken subject to 503 Existing loans taken '04 SO, Mort payoff U 7151190 BODlGside 88086,91 .05 50S '00 500 .07 507 Adjustments for items unpaid by .eller SOB "0 Local 'raxes to 31-Jul-OO 0,00 Adjustments for items unpaid by Seller .11 Assessments to 510 Local taxes 31-Jul-OO 0.00 212 School Tax.. to 3l-Jul-OO 0,00 511 Assessments to .,5 512 School taxes to 31-Jul-OO 0,00 no 513 217 514 2.0 TOTAL PAID BY BORROWER 105141.00 5'0 TOTAL REDUCTIONS SELLER 101834,24 300 CASH PROM/TO BORROWER 000 CASH TO/PROM SELLER 301 Gros. amount duo from borrower 111660,00 001 Gross amount. to seller 1 06387.37 30. Less amounts paid by/for borrower 105141.00 00. Reductions to seller 101834,24 ~9~i::iA'$H..FROMttQjjfjgRRPWE8;}I......?...'.'.'.'.... $6,519.00 JIQ~epHTQtl1ROM)~eIIFB;} $4,553.13 I have carefully reviewed the BUD-l Settlement Statement and to the best of my knOWledge and belief, it is a true and accurate statement of all receipts and disbursements made on my account or on my behalf and I have received a copy O.;.J_;'8~i~~~i_!2I Steven I. Kaczur, Jr. Darrin J. Walls ;lIiIi_I".lIi111;I;t.l Debra Lea Walls EXHIBIT \\/1 il - "",I'~I -~, ^". >.' , ' PAGE #2 HUD DISCLOSURE/SETTLEMENT STATEMENT PAID BY BORROWER PAID BY SELLER 700 TOTAL REAL TOR'S COMMISSION 7% X $105,000.00 7350,00 701 Listing Agency: 702 Selling Agency: 703 Commission paid at settlement Jack Gaughan Realtor ERA $7350,00 0,00 800 ITEMS PAYABLE IN CONNECTION WITH LOAN 801 Origination Fee ,250% Cendant Mortgage Corporation 254.63 802 Loan Discount POC$375,00 Cendant Mortgaae Corporation -375,00 803 Appraisal Fee STARS 325,00 804 Credit Report First American/Credco 70,00 805 Underwriting Cendant Mortgage Corporation 806 Document Preparation Fee 807 Flood Certification Fee FDSI/STARS 19.50 808 Tax Service Fee 1st Amer Realty Svcs/STARS 75,00 809 lender Administration fee: 810 Overnight Mail/Wire Charges: Duncan & Hartman, P,C, 15,00 15,00 900 ITEMS LENDER REQUIRES TO BE PAID IN ADVANCE . 901 Interest @ $23.90 trom 31-Jul-00 to 31-Jul-OO 23.90 902 Mortgage insurance to Department of HUD 2291.63 903 Hazard insurance 904 0,00 1000 RESERVES DEPOSITED WITH LENDER Escrows collected: # mos, due: X$ permo,: 1001 Hazard insurance 3 20.00 60.00 1002 Mortgage insurance 0 0,00 0,00 1003 County/Local taxes 8 45,70 365.60 1004 School taxes 2 105,41 210,82 1005 Aggregate Adjustment (Initial Escrow Deposit $636,42) -294.20 1100 TITLE CHARGES 1101 Settlement or closing fee: t 1 02 Abstract or title search: 1103 Transaction Fee Jack Gaughan Realtor ERA 75,00 75,00 1104 Home Owners Protection Jack Gaughan Realtor ERA 365,00 1105 Document preparation: Jack Gaughan Realtor ERA 75,00 t 106 Notary tees: Notary 6,00 1107 Attorney's fees: 0,00 0,00 (includes above item numbers): 1108 TiUe Insurance: WilLIAM A. DUNCAN, AGENT FOR FIDELITY NATIONAL TITLE 1003,75 (includes above item numbers):1101-1104 Endorsements 100 300 8,1 $150,00 1109 Owner's coverage $105,000.00 $853,75 1110 Lender's coverage $104,141.00 1111 Oisbursemantfee 0.00 1200 GOVERNMENT RECORDING AND TRANSFER CHARGES 0,00 1201 Deed 25.50 Mortgage 35,50 61,00 1202 Release/Satisfaction 14,00 AssignmenVStip 0,00 0,00 14,00 1202 County/local transfer tax (1 %) 1050,00 1203 Pa, State transfer tax (1%) 1050,00 1300 ADDITIONAL SETTLEMENT CHARGES 1301 Radon testing: 1302 Pest inspection: Penn Pest, Inc, 35,00 1303 ORO Westmoreland Cty PASCDU 4779,23 1304 Final water/sewer Acct. #700-64n-01 Carlisle Borough 24,10 140li.toi'AllIsbll,lilit!MENTfdAARGEafII.i........,...,' . 5272.63 13747.33 (also entered on line t 03 for Borrower; line 502 for Seller) r;;__;IIIII~I_II"!lil!~~.,- ~~...~ \,~"'O""""""""'''''''''''''''''!~,'~1']'''!~_ ,.,.,..~..---." . " , . : ,~i!'!'1"~r!~" '0'" ,. '_'ffi!'WI"lW!m]~~l~~ml!!~t1!!f1lJlll;!I!W~ ," --, ',", ,i"',,:.,~ ~~~ ATTORNEY AT LAW Suite 200. 5010 East Trindle Road Mechanicsburg, PA 17050 PHONE: (717) 591-1755 FAX: (717) 591-1756 Offices ill Carlisle, FA Tuesday, October 02, 2001 Ronald L. Chicka, Esquire 12 East Otterman Street Suite 200 Greensburg, PA 15601 RE: Walls v. Walls Dear Mr, Chicka: After reviewing the changes proposed by Mrs, Walls, Mr. Walls has several additional changes to be made to the proposed stipulations, Paragraph #4: Mr. Walls is willing to give Mrs, Walls Y:z the value of the swing set, only on the condition that he be reimbursed for half the value of items Mrs, Walls removed from the marital home, The items are as follows: Stereo turntable system Camcorder 8 Track tape system, plus tapes Refrigerator Washer Air conditioner Two hutcheS 27" television Entertainment center Sofa, loveseat, chair & end tables $ 200,00 800.00 100,00 500,00 200,00 250,00 250,00 200.00 200,00 750,00 $3,450,00 -1,000,00 $2,450.00 Paragraph #6: Mr. Walls has provided a copy of Form 00214, He has indicated that Block 18 indicating any benefits is blank thus he is not entitled to any benefits, EXHIBIT ! \\B" P/ea~ G OFFICE :~"'" .., ~ ,--' " Paragraph #10: Mr. Walls will not agree to change the $300,00, The couple's minor children reside with her mother, so Mr. Walls does not believe that they prevent her from seeking adequate employment. Moreover, she is currently a full-time student at Indiana University of PA and will be graduating in February, Her degree will provide an advantage allowing her to obtain more lucrative employment. We will not agree that alimony be terminated only upon the wife's remarriage or death, If the language "involvement in a meretricious relationship" is not agreeable, we can modify it to include "co-habitation" or limit alimony payments to a term of years, Regarding the money you are holding in the trust account, Mr. Walls believes that he is entitled to half, $4,046,33, Mr. Walls will not agree to pay Mrs, Walls' attorneys fees. I look forward to your response. Very truly yours, r---~ /' ./ )1, '-- .,~\) .--- "- '''-~\....''--' Peter J, Russo, Esquire In the Court of Common Pleas of WESTMORELAND County, Pennsylvania DOMESTIC RELATIONS SECTION DEBRA L, WALLS ) Order Numher 00503 DR 2000 Plaintiff ) vs. ) PACSES Case Numher 747102094 DARRIN J. WALLS ) Docktt Number 00503 DR 2000 Defendant ) Other State ID Number ORDER OF COURT o Final W Interim 0 Modified AND NOW, 11TH DAY OF MAY, 2000 ,based upon the Court's and the Payor's determination that the Payee's monthly net income is $ o. monthly net income is $ 3,128.00 , it is hereby ordered that the Payor pay to the Pennsylvania State Collection and Disbursement Unit EIGIITEEN HUNDRED FORTY THREE Dollars ($ 1, B43 ,00 ) a month payable MONTHLY as follows: first payment due BY THE 15TH DAY OF MAY 2000. The effective date of the order is 03/15/00 . Arrears set at $ 2486.00 as of MAY 11, 2000 are due in full IMMEDIA TEL Y. All terms of this Order are subject to collection and/or enforcement by contempt proceedings, credit bureau reporting and tax refund offset certification and will not be initiated as long as obligor does not owe overdue support, Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all the means listed above, For the Support of: Name DEBRA L. WALLS JESSE G. WALLS CHRISTOPHER J, WALLS DARRIN L, WALLS Birth Date 12/27/67 10/01/88 07/l3/n 04/27/95 EXHIBIT \\t II b " " Ii Form DE-5i8 Worker ID 65314 Service Type M --. . . '. WALLS V. WALLS PACSES Caso Numhor: 747102094 The defendant owes a total of $ l, 843 ,00 MONTHLY $l,743.00 per month payable for current support and $ lOO. 00 for arrears. The defendant must also pay fees/costs as indicated below, This order is allocated and monies are to be applied as follows: rrcquency Codes: Paynlent AnUlum/ Freq\\t~n{'y 5593.00 1M 5383,33 1M 5383,33 1M 5383.34 1M 50,00 I 50.00 I 50,00 I 50,00 I 50,00 I 50.00 I SO.OO I So.OO I 50.00 I 50,00 I So.OO I 50.00 I 50,00 I 50,00 I 50,00 I So.OO I I = One Time B = BiWeekly 2 = Hi-Monthly 5 =Scmi-Annually S =Scmi-Mollthly A :::Annually M =Monthlv W = Weekly Q = Quarterly Oeht Type OesCTiptinn Rendll'l::!ry SP & CHILD ALLO DEBRA L. WALLS CHILD SPT ALLOC JESSE G, WALLS CHILe SPT ALLOC CHRISTOPHER J. WALL CHILD SPT ALLOC DARRIN L. WALLS Said money to be turned over by the Pa SCDU to: DEBRA L. WALLS . Payments must be made by check or money order. All checks and money orders must be made payable to Pa SCDU and mailed to: Pa SCDU P,O. Box 69110 Harrisburg, Pa 17106-9110 Payments must include the defendant's PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. Service Type M ;-1ID . Page 2 of 4 FornI DE-518 Workor rD 6531.4 ". WALLS y, WALLS PACSES Case Numher: 747102094 Unreimbursed medical expenses that exceed $250,00 annually per child and/or spouse are to be paid as follows: 100 % by defendant and o. % by plaintiff. The plaintiff is responsible to pay the first $250.00 annually (per child and/or spouse) in unreimbursed medical expenses, @ DefendantO Plaintiff 0 Neither party to provide medical insurance coverage. Within thirty (30) days after the entry of this order, the o Plaintiff @ Defendant shall submit to the person having custody of the child(ren) written proof that medical insurance coverage has been obtained or that application for coverage has been made. Proof of coverage shall consist, at a minimum, of: 1) the name of the health care coverage provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims should be made; 5) a description of any restrictions on usage, such as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and co-payments: and 8) five copies of any claim forms, Other Conditions: Defendant shall pay the following fees: Fee Total Fee Description So,oo for So,oo for So.oo for So.oo lor S 0 _ 00 for Payment Frequency Payable at So, 00 per Payable at So. 00 per Payable at So. 00 per Payahle ut So. 00 per Payahle at SO. 00 per Page 3 of 4 Form OE-518 Worker ID 65314 Service Type ~I WALLS v. WALLS PACSES Case Number: 747102094 IMPORTANT LEGAL NOTICE PARTIES MUST WITHIN SEVEN DAYS INFORM THE DOMESTfC RELATIONS SECTION AND THE OTHER PARTIES. IN WRITING. OF ANY MATERIAL CHANGE IN CIRCUMSTANCES RELEVANT TO THE LEVEL OF SUPPORT OR THE ADMINISTRATfON OF THE SUPPORT ORDER, INCLUDING, BUT NOT LIMITED TO. LOSS OR CHANGE OF INCOME OR EMPLOYMENT AND CHANGE OF PERSONAL ADDRESS OR CHANGE OF ADDRESS OF ANY CHILD RECEIVING SUPPORT, A PARTY WHO WILLFULLY FAILS TO REPORT A MATERIAL CHANGE IN CIRCUMSTANCES MAY BE ADJUDGED IN CONTEMPT OF COURT, AND MAY BE FINED OR IMPRISONED, PENNSYLVANIA LAW PROVIDES THAT ALL SUPPORT ORDERS SHALL BE REVIEWED AT LEAST ONCE EVEll.Y THREE (3) YEARS IF SUCH REVIEW IS REQUESTED BY ONE OF THE PARTIES, IF YOU WISH TO REQUEST A REVIEW AND ADJUSTMENT OF YOUR ORDER, YOU MUST DO THE FOLLOWING: CALL YOUR ATTORNEY, AN UNREPRESENTED PERSON WHO WANTS TO MODIFY (ADJUST) A SUPPORT ORDER SHOULD CONTACT THE DOMESTIC RELATIONS SECTION, A MANDATORY INCOME ATTACHMENT WILL ISSUE UNLESS THE DEFENDANT IS NOT IN ARREARS IN PAYMENT IN AN AMOUNT EQUAL TO OR GREATER THAN ONE MONTH'S SUPPORT OBLIGATION AND (1) THE COURT FINDS THAT THERE IS GOOD CAUSE NOT TO REQUIRE IMMEDIATE INCOME WITHHOLDING: OR (2) A WRITTEN AGREEMENT IS REACHED BETWEEN THE PARTIES WHICH PROVIDES FOR AN ALTERNATE ARRANGEMENT, UNPAID ARREARAGE BALANCES MAY BE REPORTED TO CREDIT AGENCIES, ON AND AFTER THE DATEI:r IS DUE. EACH UNPAID SUPPORT PAYMENT SHALL CONSTITUTE, BY OPERATION OF LAW. A JUDGMENT AGAINST YOU. AS WELL AS A LIEN AGAINST REAL PROPERTY. IT IS FURTHER ORDERED that. upon payor's failure to comply with this order, payor may be arrested and brought before the Court for a Contempt hearing; payor's wages. salary. commissions, and/or income may be attached in accordance with law; this Order will be increased without further hearing by 15 % a month until all arrearages are paid in fulL Payor is responsible for court costs and fees. Copies delivered to parties Date Consented: Plaintiff Plaintiff's Attorney Defendant Defendant's Attorney BY THE COURT: /d p11lU<~O ~ Judge Page 4 of 4 Form OE-SI8 Worker ID 65314 Service Type M " -~ In the Court of Common Pleas of WESTMORELAND County, Pennsylvania DOMESTIC RELATIONS SECTION PACSES Case Number: Docket Number: Other State ID Number: 747102094 00503 DR 2000 Please oote: All correspondence Ulllst ulclude the PACSES Cal;jc 7'iumhcr. MAY 11. 2000 SUMMARY OF TRIER OF FACT Plaintiff Information Defendant Information DEBRA L. WALLS DARRIN J. WALLS Address: RR 3 BOX 78 NEW FLORENCE PA 15944-9747-78 Address; 1504 TERRACE AVE CARLISLE PA 17013-9369-04 Employer: N/A Employer: RALSTON PURINA CO. Attorney: CHICKA RONALD L 6509 BRANDY LN MECHANICSBURG PA 17055-2817-09 Attorney: JAMES J, KAYER, ESQUIRE IXI Complaint for Support 03/15/00 0 Petition for Modification Filed o Other Reason for Conference: SPOUSE AND (3) THREE CHILDREN Dependent(s) JESSE G, WALLS CHRISTOPHER J. WALL 10/01/88 07/13/91 04/27/95 536-21-5309 535-23-9564 169-76-3229 DARRIN L. WALLS Current Order: $ 0,00 / per month Service Type N Form eM-022 Worker lD 65314 , ." WALLS v, WALLS PACSES Case NUIllh~r: 747102094 Other Information (continued): Facts Agreed Upon: '\ "c c,~ ~ ).~~I \)Q~-\ ,\-" <'eJ,.--<-. \nO().c..", ~_____ ~\r--<2...c..\. \i>yY"\~ 0= Facts in Dispute and Contentions with Respect to Facts in Dispute: Guideline Amount: $-v:-e-o \ ) Lj '2, / 0, r~ DRS Recommended Amount: ~ (J '-1 "'-, I f\'\ 0 DRS Recommended Order Effective Date: ----:, 1(,"'0 ) ()(, Parties to be Covered by Recommended Order Amount: \::k...,O,........ ~S-<... , L...>f"'.r-\S. "" Q \-....r v--c?" D ""vI" v--., . Guideline Deviation: 0 YES ~O Reason for Deviation: Submitted by: TIMOTHY M CAWOSKI Date Prepared: MAY II. 2000 Pag~ 3 of 3 Form CM"022 Work~r ID 65314 Service Typ~ M ~- " -~ '. WALLS v, WALLS PACSES Case Numher: 747102094 Plaintiff Information Current Income: -o~ Defendant Information ~ ?', \ d ~ ,c\j mc), Tax Return: Medical Coverage: ~"",~ ~\",~Q\~ q Child Care/Tuition: Additional Obligations: Other Information: Page 2 of 3 fonn CM.()22 Worker ID 65314 Service Type M . ,.1, -~-~<, 'I! ~ - ~ ~~ ~ '<<,- "-",-, ,-~,--~ - ~- " -,' ,.~~ ~~"",,'-"'MI_~,Y"~'-__J1 "- : . (") 0 0 C r...) -Tl <" <- -Om c:: =' fTlrn r- _L" 2:1:) f11F -". c;: -CifT1 ..:,.. ~~~ tv ~3~~9 ~C'J -0 c:::i6 '> ~, :I::::H ~o ~. C'I--- ~8 -:;;;0 w c5m ~ -I :,.) ::> :D tv --< ,- .,~~f~1W~~~'''''~,",la\1l~!Il!r!l!!!J'lllll'Ml~~IWi~~ . . JUN 2 0 2002 ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DARRIN JOHN WALLS, PLAINTIFF No. 2000-1238 v. CIVIL ACTION-LAW DEBRA LEA WALLS, DEFENDANT IN DIVORCE RULE AND NOW, this /- 2002, upon consideration of 9'""; day of Plaintiff, Darrin John Walls's Petition for Bifurcation, a Rule is hereby ISSUED upon the Defendant, Debra Lea Walls, to show cause why the relief requested should not be granted. "Z,C> RULE RETURNABLE withinje1Iays of service. BY THE COURT: Distribution list: Peter 1. Russo, Esquire Ronald 1. Chicka, Esquire d- J. 7, tJ;J. O~ ~~ ~. '. Will .11IiIiilll'~ -'~lj~,io!*,-~,jJ_.1W"'~~'""'. ,-,". ''''.' F!LEU-()t~FiCi: OF" !''CJITIARY 02 JUL ..1 Pi'i I: 21~ CUi'v1B~:;.~'~L':J'~U COUNTY PENNSYLV,ANI,t.\ , . -~.~ ." ,- ',' ,., '- , --~ " ~"~ "~"'~ -~.~..[~~" '''M 'I I . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DARRIN JOHN WALLS, PLAINTIFF No. 2000-1238 v. CIVIL ACTION-LAW DEBRA LEA WALLS, DEFENDANT IN DIVORCE DECREE AND ORDER AND NOW, this day of , 2002, upon consideration of Plaintiffs Petition for Bifurcation, it is hereby ORDERED and DECREED that: 1. The divorce action is bifurcated from the pending ancillary economic claims, 2, The Court retains jurisdiction of any pending economic claims raised by either party, 3, The parties are enjoined from encumbering, dissipating, selling, or otherwise alienating any and all marital assets. BY THE COURT: J. ,-' ~, - . ,.",,, _, _._, "r ,. , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DARRIN JOHN WALLS, PLAINTIFF/PETITIONER No. 2000-1238 v. CIVIL ACTION-LAW DEBRA LEA WALLS, DEFENDANTffiESPONDENT IN DIVORCE PETITION FOR BIFURCATION AND NOW, COMES, Petitioner, Darrin John Walls, by and through his undersigned counsel, and respectfully requests that this Honorable Court grant the Petition for Bifurcation, and in support thereof avers as follows: L Petitioner is Darrin John Walls, the Plaintiff in the above-captioned divorce action, 2, Respondent is Debra Lea Walls, the Defendant in the above captioned divorce action, 3. Petitioner and Respondent were married on October 18, 1986, in Dayton, Armstrong County, Pennsylvania. They have (3) three children under the age of eighteen (18). 4, On or about March 3, 2000, Petitioner commenced a divorce action by filing a Complaint in Divorce as ofthe above docket number. 5. On or about May 1,2000, Defendant filed an Answer and Counterclaim to the Complaint in Divorce seeking, inter alia, equitable distribution of marital property, custody, alimony/ alimony pendente lite, counsel fees, costs and expenses, cO ~. ~-- 6, Both parties are in good health and there is little likelihood of a shortened lifespan. 7. Petitioner agrees to keep all insurance policies in effect in order to cover all persons he was directed to insure by the Court. 8. Based upon the economic status ofthe parties, there is no likelihood that either will file for bankruptcy, 9, Neither party's property rights would be affected in any way by a bifurcation of the divorce from the pending economic issues. 10. The parties have maintained an economic status quo during the separation that Petitioner has no intention of disturbing, 11 , Bifurcation would not disturb that economic status quo. 12. Petitioner believes and avers that the advantages of bifurcation of this divorce action are substantially greater than the disadvantages for the following reasons: (i) A speedy resolution ofthe divorce issue would allow the parties to restructure their personal lives, (ii) Bifurcation will accelerate the dissolution ofthe parties' which is clearly irretrievably broken. (iii) Bifurcation will further the policy behind Pennsylvania's Divorce Code in making the legal dissolution of marriage effective for dealing with the reality of matrimonial experience by taking into primary consideration the welfare of the family rather than the vindication of private rights, 23 Pa, C,SA 3102 (a). (iv) Bifurcation of this divorce action will also separate the .'0; ~ dissolution from the distribution of property so that the marriage and each party's personal life are not held hostage to economic demands, (v) Bifurcation of the divorce action will in no way prejudice, diminish or impair Respondent's economic claims under the Divorce Code, WHEREFORE, Petitioner respectfully requests that this Court grant his Petition for Bifurcation, reserving jurisdiction on the economic claims raised by the parties, C ~"-i Peter J. Russo 5010 E. Trindle Road Mechanicsburg, P A 17050 (717) 591-1755 ~ Date: (,.. '~-O~ ~' , , . " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DARRIN JOHN WALLS, PLAINTIFF/PETITIONER No. 2000-1238 v. CIVIL ACTION-LAW DEBRA LEA WALLS, DEFENDANTffiESPONDENT IN DIVORCE VERIFICATION I, Darrin John Walls, 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, 9 4904 relating to unsworn falsification to authorities. t:./I.)/O;). Date' ~~ Q. lI\J~ Danin John wad's , ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DARRIN JOHN WALLS, PLAlNTIFF/PETITIONER No. 2000-1238 v. CIVIL ACTION-LAW DEBRA LEA WALLS, DEFENDANT~SPONDENT IN DIVORCE CERTIFICATE OF SERVICE I, Melissa M, Mehaffey, hereby certify that I am on this day serving a copy of the PETITION FOR BIFURCATION upon the person (s) and in the manner indicated below, service by First-Class Mail, Postage Prepaid, and Addressed as Follows: Ronald L. Chicka, Esquire 12 East Otterman Street Suite 200 Greensburg, PA 15601 11uPL~A;rnf!/i L~ Melissa M, Mehaii;p; r Date: tg -I') ~ ~~ . ! , ~, ",' -'"-<'l'1'~- -' ,..,.~,~-" . ~~. ._ , _~n7_~ _ 'eo, 0> ".C rF.~'~}W1l!lJI!ftfR~~" '~.'" ~~-, <="""'""--- ~ ,"-,,-~"" " "ofl 0 c:> 0 C f'-v " s: := ::,,-j "1J OJ nlrp :E: ~-:~;i ;Q Z::ti ~3? 4r::---: Q;) ~:;;,.;. "30 c:::::c; -u ~.,...., "'")", 50--; :::m: ;52] 2:0 --~,..... -=0 6rn )>-c: -, :z; ::> S'; =< J:" -< " , ,."...,~~~,.)llO. ! ~"'I ,P '" PETERJ. RUSSO, ESQUIRE Supreme Court ill: 72897 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 DARRIN JOHN WALLS Plaintiff Attorney for Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CML ACTION - LAW DEBRA LEA WALLS Defendant NO.2000-1238 CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I, Melissa M. Mehaffey, hereby certifY that I am on this day serving a copy of the Plaintiff s Affidavit of Consent and Waiver of Notice of Intention to Enter Divorce Decree upon the person (s) and in the manner indicated below; Service via Telecopier as Follows: Debra Lea Walls, c/o Ronald L. Chicka, Esquire (724) 836-3828 Date:J-J.d--03 '<, ,'~. ,,0 ~ I, <, >~ ~-I"-'""~" ~," ". "" ,'^ .~. .-~-" ~ ,~-,- ~, &' ~,. - -, -"~ ~~, ~- '"~ ,',''''.- o c: s: -00' tTir';:' &:i' Ll-- W> ~~S ~r--, ~ ".' ~8 ~ .~ ",... t:::;::r C0 Q .. ""1 fTl CO I en -0 :2 po..:.: -,--;;'; -;'-~6 , " ;)l5 c'5r-n ?& -< 1'0 ;:.n en _.,..".._.~~.,..."'~_;""m"",~W';;;~Ii~~~~HII!I~~ ~flI!llI'l~~