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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
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VATR1HR T
VANN'nN'R
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VERSUS
GARY S. YANNONE.
Defeno,qnt
AND NOW,
DECREED THAT
AND
~Ar)' c;: V~nnnno
PENNA.
No.
nn_?~~a r~'r~l To~m
DECREE IN
DIVORCE
1vli
20
, 2061 , IT IS ORDERED AND
U~lQTi~ 1 Y~UUQU9
, PLAINTIFF,
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRtMONY.
THE COURT RETAtNS JURISDICTION OF THE FOLLOWtNG CLAIMS WHtCH HAVE
BEEN RAtSED OF RECORD tN THIS ACTION FOR WHtCH A FtNAL ORDER HAS NOT
YET BEEN ENTERED;
The narties' Separation And PrnpoTt)' C;:ottlomont agToomO~. d~tgd July '7
2001. is incornorated herf=linr hut not mOTgor!
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ATT T:
By THE COURT:
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SEPARATION AND PROPERTY SETTLEMENT AGREEMENT
THIS AGREEMENT made this (q'" day of f ~ ,2001, by and between
VALERIE L. YANNONE, of 1002 West Foxcroft Drive, Camp Hill, Cumberland County,
Pennsylvania (hereinafter referred to as "Wife"), and GARY S, YANNONE, of 1555 McClure's
Gap Road, Carlisle, Cumberland County, Pennsylvania (hereinafter referred to as "Husband").
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on November 16, 1996, III
Cumberland County, Pennsylvania.
WHEREAS, differences have arisen between Husband and Wife in consequence of
which they have chosen to live separate and apart from each other; and
WHEREAS, the parties acknowledge that they have had the opportunity to review the
provisions of this Agreement and further have had the opportunity to secure legal counsel and
advice relative to the legal effect of this Agreement. The parties acknowledge that they have
either received independent legal advice from counsel of their own selection or that they have
specifically chosen with full knowledge and on their own volition, to not seek legal advice
relative to this Agreement. They further acknowledge that they fully understand the facts that
are the basis of this Agreement. They acknowledge and accept that it is being entered into freely
and voluntarily, after having the opportunity to receive legal advice and with the knowledge that
execution of this Agreement is not the result of any duress or undue influence, and further that it
is not the result of the collusion or improper or illegal agreement or agreements.
NOW, THEREFORE, the parties hereto intending to be legally bound hereby do
covenant and agree:
Page 1 of7
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I. Sevaration: It shall be lawful for each at all times hereafter to live separate and apart
from the other party at such place as he or she may from time to time choose or deem
fit. The foregoing provision shall not be taken as an admission on the part of either
party of the lawfulness or unlawfulness of the causes leading to their living apart.
2. lnteiference: Each party shall be free from interference, authority, and contact by the
other, as fully as if he or she were single or unmarried except as may be necessary to
carry out the provisions of this Agreement.
3. Wife's Debts: Wife represents and warrants to Husband that she will not contract or
incur any debts or liabilities for which Husband or his estate might be responsible and
shall indemnify and save harmless Husband from any and all claims or demands
made against him by reason of debts or obligations incurred by her other than those
debts incurred pursuant to any sections of this Agreement.
4. Husband's Debts: Husband represents and warrants to Wife that he will not contract
or incur any debt or liability for which Wife or her estate might be responsible and
shall indemnify and save harmless Wife from any and all claims or demands made
against her by reason of debts or obligations incurred by him other than those debts
incurred pursuant to any section of this Agreement.
5. Real Estate: The parties are the joint owners of real estate located at 17 Grant Court,
Carlisle, Cumberland County, Peunsylvania. The property is encumbered with a
mortgage due and owing to First Horizon Home Loans requiring the monthly
payment of approximately $1,300.00. The parties shall sign a listing contract with
Page 2 of7
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B&H Agency to market the home for sale to a third party purchaser for value. Wife
alone shall have full and complete authority to address all matters relating to the
listing, prospective sale, negotiations, modifications in the listing contract and all
other aspects of the sale of the home. Husband hereby give his consent and authority
for Wife to handles all such matters. Upon the sale of the property, Husband and
Wife shall divide equally the net proceeds of the sale, if any. In the event the Grant
Court property is not ultimately sold and a mortgage foreclosure proceedings or other
loss of the property results in a deficiency judgment relating to the existing mortgage
lien on the property, the parties shall divide equally any such debt or deficiency
judgment with respect to the mortgage.
6. OutstandinfJ Joint Debts: Except for the debts described herein (specifically
described in paragraph 5 of this Agreement), neither party has incurred any debt or
financial obligation which creates an obligation on the other party's part. In the event
any such debt exists, the party contracting for such debt shall be solely and
exclusively responsible for the payment of such debt and shall indemnify and hold
harmless the other party from any demands for payment or collection activity of any
nature relative to any such debt.
7. Mutual Release: 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 causes of action, claims, rights or demands,
whatsoever in law or equity, which either of the parties ever had or now has against
Page 3 of7
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the other, except any or all cause or causes of action for divorce or any action to
enforce this Agreement.
8. Alimonv. Alimonv Pendente Lite. SDousal SUDDort and Maintenance: The parties
specifically are aware of, acknowledge and understand their right to demand alimony,
alimony pendente lite and support and hereby waive their right to these claims against
the other party now and in the future. Both parties agree not to make a claim for
alimony, alimony pendente lite or support now, during any future divorce proceeding
between the parties, or at anytime thereafter.
9. Division Q,l Personal ProDer(y: The parties have agreed to a division of their personal
property to their mutual satisfaction, including their personal effects, household
furniture, furnishings, appliances, and all other articles of personal property,
including automobiles, which have heretofore been used in common and neither will
make any claim to any such items which are in the possession of or under the control
of the other party, With re8~6et 18 ~r F",,~,u\n~l propp.~ ltp.m~ thHt hHVP. nnt )'Pt 1?~eR
distrilnHea, tfte fJaTtiS6 BRall rater 19 the uUuGhed Exhibit f\ Mld J2uftffiit B 'T,~eR are a
li3ti1'lg sf tke fJeFS8ReH prgp~t:t:,r itert"l(! \vhich shull bc.. l.GliLluvd by \.Iavll. J.\.I':)p\.lvl~vv
llaFt).. .
II. Insurance. Retirement, and Other Benefits: The parties agree that neither party shall
make any claim of any nature whatsoever concerning any insurance benefits,
retirement benefits, profit sharing accounts or other similar accounts or benefits that
are available to or accruing to either party.
Page 4 of7
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12. Waiver 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 have or hereafter acquire under the
present or future laws of any jurisdiction, to share in the property or the estate of the
other as a result of the marital relationship, including without limitation, dower,
curtesy, statutory allowance, widow's allowance, right to take in intestacy, right to
take against the will of the other, and right to act as administrator or executor of the
other's estate, and 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.
This Paragraph shall not affect either party's right or power to expressly include the
other party in any will or other document, whether written in the past or in the future.
13. Breach: If either party breaches any provision of this Agreement, the other party
shall have the right, at his or her election, to sue for damages for such breach, or seek
such other remedies or relief as may be available to him or her.
14. Counsel Fees: The parties agree that should a divorce action be maintained by either
of the parties to dissolve their marriage, neither party shall make a claim for counsel
fees from the other party. Both parties have been fully informed of and acknowledge
their right to make a claim for reasonable counsel fees in the presently pending
divorce proceedings, but hereby make a full, complete and voluntary waiver of that
right.
Page 5 of7
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15. Enforcement: The parties agree that this Agreement may be made a part of any final
divorce order or decree entered in this case. This Agreement may be incorporated in
but shall not be merged with any such order or decree. 1n the event either party fails
to comply with the terms of this Agreement, the other party may enforce this
Agreement by filing a Petition For Contempt if a party breaches this Agreement the
other party, in pursuing enforcement of the Agreement, shall be entitled to attorney's
fees from the breaching party.
IN WITNESS WHEREOF, the parties hereunto set their hands and seals the day and year
first mentioned above.
WITNESSES:
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V ALERlE 1. Y ANN
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Date
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COMMONWEALTH OF PENNSYL VANIA
COUNTY OF C V\.,VV\~-Q.[tDlJe!\.
On this q day of J LA \. J ' 2001, before me, the undersigned
officer, personally appeared VALERIE L. YANNONE, known to me (or satisfactory proven) to
be the person whose name is subscribed to the within Agreement and acknowledged that she
executed the same for the purpose therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
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Notarial S~gkry public
rlsaJ. Lehman, iIaniI co~
, ~!I\Sle ~fo'n ~ 1\1I9- 25, ..I
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COMMONWEALTH OF PENNSYL VANIA
COUNTY OF ~.,bel. 0' Q
On this ~... day of -:( ~
, 2001, before me, the undersigned
officer, personally appeared GARY S. YANNONE, known to me (or satisfactory proven) to be
the person whose name is subscribed to the within Agreement and acknowledged that he
executed the same for the purpose therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
_LSLJ L Crc..Jcv.J
Notary Publi<!'
Notarial Seal
Bridget Ann Corcoran, Notary Public
Carlisle Bora, Cumberland County
. - ~cC'1mission Expires June 10, 2002
Page 70f7
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V ALERlE 1. YANNONE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION - LAW
GARY S. YANNONE,
Defendant
: NO. 00-2339 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)
33Q1(d)(1) eflhe Divefee Cetie.
(Strike out inapplicable section),
2. Date and manner of service of the Complaint: by Acceptance of Service signed by Hubert
X. Gilroy, Esquire, on behalf of the Defendant on or about April 13, 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: July 9, 2001 by Defendant: July 6, 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: July 10, 2001
Date defendant's Waiver of Notice in ~3301 (c) Divorce was filed with the
Prothonotary: July 10, 2001
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VALERIE 1. YANNONE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs,
ctJJ)- ci33g
: NO. CIVIL TERM
GARY S. YANNONE,
Defendant
: IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in Court, If you wish to defendant 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 and a decree in divorce or annulment may be entered
against you by the Court, Ajudgment may also be entered against you for any other claim
or relief requested in these papers by the Plaintiff. You may lose money or property or
other rights important to you, including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is available
in the Office of the Prothonotary at Cumberland County Courthouse, Carlisle,
Pennsylvania, 17013,
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL
PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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 HA VB 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, pennsylvania 17013
(717) 249-3166
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VALERIE 1. YANNONE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO, 01J- 02337CIVIL TERM
GARY S. YANNONE,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
L Plaintiff is Valerie 1. Yannone, an adult individual currently residing at 1 002 West
Foxcroft Drive, Camp Hill, Cumberland County, Pennsylvania. Plaintiff has resided at
this residence since February 2000.
2, Defendant is Gary S, Yannone, an adult individual currently residing at 1555
McClure's Gap Road, Carlisle, Cumberland County, Pennsylvania.
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 November 16, 1996, in Cumberland County,
Pennsylvania.
5. A Complaint in Divorce was filed by Plaintiff on August 6, 1997, and was docketed in
Cumberland County at 1997-04232. A Praecipe to withdraw that Complaint in
Divorce was filed on December 18, 1997,
6, An additional Complaint in Divorce was filed by Plaintiff on June 28, 1999, and was
docketed in Cumberland County at 1999-3958, A Praecipe to withdraw that
Complaint in Divorce was filed on November 18, 1999.
7. There have been no other prior actions for divorce or annulment between the parties.
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8. The Defendant is not a member of the Unites States Armed Forces or its Allies,
9. 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,
10. Plaintiff and Defendant are citizens of the United States of America,
11. The parties' marriage is irretrievably broken.
12. Plaintiff desires a divorce based upon the belief that Defendant will, ninety days from
the date of service of this Complaint, consent to this divorce.
WHEREFORE, Plaintiff requests your Honorable Court to enter a decree III
divorce pursuant to Section 3301(c) of the Domestic Relations Code,
COUNT II
INDIGNITIES
11. Paragraphs 1 through 10 are incorporated herein by reference as if set forth in their full
text.
12. Defendant has committed such indignities upon the person ofthe Plaintiff, the innocent
and injured spouse, as to make her condition intolerable and life burdensome.
WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce
pursuant to 23 P,S. Section 3301(a)(6).
COUNT m
EOUITABLE DISTRIBUTION
13. Paragraphs 1 through 12 are incorporated herein by reference as if set forth in their full
text,
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14, Plaintiff and Defendant are joint owners of certain real estate located at 17 Grant
Court, Carlisle, 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,
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 enter a decree
equitably dividing the parties' property and equitably apportioning the debts incurred by
the parties,
COUNT IV
ALIMONY. ALIMONY PENDENTE LITE.
COUNSEL FEES AND EXPENSES
17, Paragraphs 1 through 16 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. Despite being employed, Plaintiff is without sufficient property and otherwise unable
to financially support herself
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 the Plaintiff.
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WHEREFORE, Plaintiff requests your Honorable Court to enter an Order of
Court requiring Defendant to pay counsel fees, expenses, and costs as well as providing
for payment of appropriate alimony and alimony pendente lite to Plaintiff,
Respectfully submitted,
GRIFFIE & ASSOCIATES
e, Esquire
or Plaintiff
o orth Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
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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 falsification to authorities.
DATE:J/aO~O
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VALERIE L. Y
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V ALERlE 1. YANNONE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION - LAW
GARY S. YANNONE,
Defendant
: NO. 00-2339 CIVIL TERM
: IN DIVORCE
AFFIDAVIT OF CONSENT
L A. Complaint in Divorce under 93301 (c) of the Divorce Code was filed on April
13,2000, and served on or about April 13, 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 VERlTY 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:
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V ALERlE 1. YANNONE,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
GARY S. YANNONE,
Defendant
: NO. 00-2339 CIVIL TERM
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A. Complaint in Divorce under 93301 (c) of the Divorce Code was filed on April
13,2000, and served on or about April 13, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date offiling 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 FALSIFICATION TO AUTHORlTIES.
DATE:
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VALERIE 1. YANNONE,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
GARY S. YANNONE,
Defendant
: NO. 00-2339 CIVIL TERM
: IN DIVORCE
W AIYER ON NOTICE OF INTENTION TO REQUEST
THE ENTRY OF A DIVORCE DECImE
UNDER ~3301(c) OF THE DIVORCE CODE
1. 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 ifI 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. ~4904 RELATING TO
UNSWORN F ALSIFICA TION TO AUTHORlTIES.
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V ALERlE 1. YANNONE,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
GARY S. YANNONE,
Defendant
: NO. 00-2339 CIVIL TERM
: IN DIVORCE
WAIVER ON NOTICE OF INTENTION TO REQUEST
THE ENTRY OF A DIVORCE DECREE
UNDER ~3301(c) OF THE DIVORCE CODE
1. 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! 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. ~4904 RELATING TO
UNSWORN FALSIFICATION TO AUTHORlTlES.
GARY S. Y
DATE:
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VALERIE L. YANNONE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
GARY S. YANNONE,
Defendant,
CIVIL ACTION - LAW
: NO. 2000-2339 CIVIL TERM
: IN DIVORCE
ACCEPTANCE OF SERVICE
I, Hubert X. Gilroy, Esquire, acknowledge that on or about
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2000, I received a certified and true copy of a Complaint in Divorce in the above
captioned action and further acknowledge that I am authorized to do so on behalf of my
client, Gary S. Yannone.
DATE~~7/o(
Attorney for
Sworn and SUbJred to
before me this J- day
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Notary P~c
Notarial Seal
Bridget Ann Corcoran, Notary Public
Carlisle Bora, Cumberland County
My Commission Expires June 10, 2002
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V ALERlE 1. YANNONE,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION - LAW
GARY S. YANNONE, NO. 2000-2339 CIVIL TERM
DefendantlRespondent : IN DIVORCE
ORDER OF COURT AND RULE TO SHOW CAUSE
ANDNOWthis 1.....J dayof M4\ ,2001, upon presentation and
consideration of the within Petition for Special Relief and Rule to Show Cause, a Rule is hereby
issued upon the Defendant, Gary S. Yannone, to show cause, if any he has, as to the following:
a. why the marital residence should not be listed for sale in accordance with the listing
contract executed by Petitioner and Respondent and B&H Agency;
b. why Petitioner should not be granted immediate access to the home;
c. why Respondent should not be responsible for any and all costs associated with preparing
the home for sale;
d. why any proceeds from the sale of the home should not be divided evenly between the
parties; and
e. why Respondent should not be responsible for Petitioner's attorney's fees, costs and
expenses incurred through the processing of this Petition.
The Rule is returnable at a hearing to be held on ~
day of ~ ,2001, at ",2: o() f .m. in Courtroom number
County Courthouse, One Courthouse Square, Carlisle, Pennsylvania.
, the g M
I of the Cumberland
BY THE COURT,
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Marylou Matas, Esquire
Attorney for PlaintifJ1Petitioner
Hubert X, Gilroy, Esquire
Attorney for Defendant/Respondent
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V ALERlE 1. YANNONE,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
GARY S. YANNONE, : NO. 2000-2339 CIVIL TERM
Defendant/Respondent : IN DIVORCE
PETITION FOR SPECIAL RELIEF
AND RULE TO SHOW CAUSE
AND NOW comes Petitioner, Valerie L. Yannone, by and through her counsel of record,
Marylou Matas, Esquire, and petitions the Court as follows:
1. Your Petitioner is the above named Plaintiff, Valerie L. Yannone, an adult individual
currently residing at 1002 West Foxcroft Drive, Camp Hill, Cumberland County,
Pennsylvania.
2. Your Respondent is the above named Defendant, Gary S. Yannone, an adult individual
currently residing at 1555 McClure's Gap Road, Carlisle, Cumberland County,
Pennsylvania.
3. The parties are parties to the above referenced divorce action, which was initiated by
Petitioner by filing a Complaint in Divorce pursuant to g3301(c) of the Divorce Code. A
copy of said Complaint in Divorce is attached hereto and incorporated herein by
reference as Exhibit "A."
4. Petitioner previously filed a Complaint in Divorce, which was docketed to No. 99-3958
Civil Term, in the Court of Common Pleas of Cumberland County, Pennsylvania. A copy
of said Complaint in Divorce is attached hereto and incorporated herein by reference as
Exhibit "R"
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5. The prior Complaint in Divorce filed by Petitioner was withdrawn. A copy of said
Praecipe withdrawing the Complaint is attached hereto and incorporated herein by
reference as Exhibit "C."
6. After several failed reconciliation attempts, the parties finally separated on October 24,
2000.
7. The former marital residence located at 17 Grant Court, Carlisle, Cumberland County,
Pennsylvania is a marital asset, which must be distributed.
8. Until a recent, unspecified date Respondent continued to reside at the former marital
residence.
9. The parties signed a listing contract on November 24,2000, agreeing to list the home for
sale with B&H Agency, which listing contract was forwarded to Respondent's counsel
on November 28, 2000. A copy of said listing contract and correspondence is attached
hereto and incorporated herein by reference as Exhibit "D."
10. In response to Respondent's proposal that the parties agree to have a third party refinance
the home, presumably instead of listing the home for sale, Petitioner, through
correspondence dated December 6, 2000, requested that the home be listed for sale as the
parties had agreed under the contract that both parties had signed previously. A copy of
which is attached hereto and incorporated herein by reference as Exhibit "E,"
11. Petitioner received notice on December 7, 2000, that the mortgage loan was in default
and that the October 1, 2000, and subsequent payments had not been paid.
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12. By copy of correspondence dated January 5, 2001, a copy of which is attached hereto and
incorporated herein by reference as Exhibit "F," Petitioner again requested that
Respondent cooperate with the real estate broker and list the home for sale according to
the listing contract that the parties had previously executed.
13. By copy of correspondence dated March 6, 2001, a copy of which is attached hereto and
incorporated herein by reference as Exhibit "0," Petitioner agreed to relinquish any
interest in the home to Respondent in an effort to have her name removed from the
mortgage as quickly as possible.
14. On April 16, 2001, Petitioner received notice from the mortgage company that
foreclosure proceedings were being instituted against the parties for failure to make
mortgage payments since October 1, 2000.
15. Despite repeated requests to do so, Respondent has not given indications that he will
cooperate with listing the home for sale as previously agreed by the parties or that he has
undertaken any steps to refinance the mortgage in his name individually, as also was
previously suggested by Petitioner.
16. The property at issue is believed to have sufficient equity to allow for the property to be
sold without financial loss to the parties.
17. Petitioner has been denied access to the home and does not know the condition of the
interior or what may need to be done to prepare the home for sale.
18. If the property is foreclosed upon, the parties will clearly incur a deficiency judgment in
those proceedings.
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19. Petitioner has incurred substantial attorney's fees, costs and expenses through the
processing of this Petition.
20. Respondent's counsel of record, Hubert X. Gilroy, Esquire, has been advised ofthe filing
of this Petition and he and his client do not concur.
WHEREFORE, Petitioner requests your Honorable Court to issue a rule upon Respondent,
Gary S. Yannone, to show cause, if any he has, as to the following:
a. why the marital residence should not be listed for sale in accordance with the listing
contract executed by Petitioner and Respondent and B&H Agency;
b. why Petitioner should not be granted immediate access to the home;
c. why Respondent should not be responsible for any and all costs associated with preparing
the home for sale;
d. why any proceeds from the sale of the home should not be divided evenly between the
parties; and
e. why Respondent should not be responsible for Petitioner's attorney's fees, costs and
expenses incurred through the processing of this Petition.
Respectfully submitted,
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Ma atas, Esquire
Attorney or PlaintifflPetitioner
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, P A 17013
(717) 243-5551
(800) 347-5552
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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: 'IP(p/{l/
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V ALERlE 1. Y A , PlaintifflPetitioner
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VALERIE L. Y AJ.'lNONE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V AJ.'ITA
('
vs,
Jcoo-;;(23Q
: NO. CIVIL TERM
GARY S. YANNONE,
Defendant
: IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in Court. If you wish to defendant against the claims set forth
in the foUowing pages, you must take prompt action, You are warned that if you fail to
do so, the case will proceed without and a decree in divorce or ~nnlllment may be entered
against you by the Court. A judgment may also be entered against you for any other claim
or relief requested in these papers by the Plaintiff. You may lose money or property or
other rights important to you, including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is available
in the Office of the Prothonotary at Cumberland County Courthouse, Carlisle,
Pennsylvania., 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF MARITAL
PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE IS
GRANTED, YOU MAY LOSE THE RlGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONe THE OffiCE SET FORTH BELOW TO Fll'<"D OUT WHERE YOU
CAJ.'l' GET LEGAL HELP,
Cumberland County Bar Association
Two Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
EXHIBIT "A"
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VALERIE L YANNONE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO, CIVIL TERM
GARY S. YANNONE,
Defendant
: IN DIVORCE
COMPLAINT IN DIVORCE
1, Plaintiff is Valerie 1. Yannone, an adult individual currently residing at 1002 West
Foxcroft Drive, Camp Hill, Cumberland County, Pennsylvania. Plaintiffhas resided at
this residence since February 2000.
2. Defendant is Gary S. Yannone, an adult individual currently residing at 1555
McClure;s Gap Road, Carlisle, Cumberland County, Pennsylvania.
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 November 16, 1996, in ,Cumberland County,
Pennsylvania.
5, A Complaint in Divorce was filed by Plaintiff on August 6, 1997, and was docketed in
Cumberland County at 1997-04232. A Praecipe to withdraw that Complaint in
Divorce was filed on December 18, 1997,
6, An additional Complaint in Divorce was filed by Plaintiff on June 28, 1999, and was
docketed in Cumberland County at 1999-3958, A Praecipe to withdraw that
Complaint in Divorce was filed on November 18, 1999,
7, There have been no other prior actions for divorce or annulment between the parties.
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8. The Defendant is not a member of the Unites States Armed Forces or its Allies.
9, 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.
10, Plaintiff and Defendant are citizens of the United States of America.
11. The parties' marriage is irretrievably broken.
12. Plaintiff desires a divorce based upon the belief that Defendant will, ninety 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 IT
INDIGNITIES
11. Paragraphs 1 through 10 are incorporated herein by reference as if set forth in their full
text.
12, Defendant has committed such indignities upon the person of the P1aintUI: the innocent
and injured spouse, as to make her condition intolerable and life burdensome.
WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce
pursuant to 23 P,S, Section 3301(a)(6).
COL"NT ill
EQUITABLE DISTRIBUTION
13. Paragraphs 1 through 12 are incorporated herein by reference as if set forth in their full
text.
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14, Plaintiff and Defendant are joint owners of certain real estate located at 17 Grant
Court, Carlisle, 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.
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 enter a decree
equitably dividing the parties' property and equitably apportioning the debts incurred by
the parties,
COUNT IV
ALIMONY. ALIMONY PENDENTE LITE.
COUNSEL FEES AND EXPENSES
17, Paragraphs 1 through 16 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, Despite being employed, Plaintiff is without sufficient property and otherwise unable
to financially support herself
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 the Plaintiff.
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WHEREFORE, Plaintiff requests your Honorable Court to enter an Order of
Court requiring Defendant to pay counsel fees, expenses, and costs as well as providing
for payment of appropriate alimony and alimony pendente lite to Plaintiff.
Respectful1y submitted,
GRIFFIE & ASSOCIATES
. e, Esquire
om for Plaintiff
200 rth Hanover Street
Carlisle, P A 17013
(717) 243-5551
(800) 347-5552
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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 falsification to authorities.
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c7 ::;0 'Co VALERIE L Y~NE
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VALERIE L. Y Ai'JNONE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION - LAW
NO. CIVIL 1999 ,- .J9 S' p G'u\.l
IN DIVORCE
GARY S. YANNONE,
Defendant
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 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 FTI..E A CLAIM FOR ALIMONY, DIVISION OF MARITAL
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR
At'INlJLMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM At~-Y 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 CAt'f GET LEGAL HELP,
Cumberland County Bar Association
Two Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
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VALERIE L YANNONE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUN1Y, PENNSYLVA,'1IA
v.
CIVIL ACTION - LAW
: NO, CIVIL 1999
GARY S, YANNONE,
Defendant
: IN DrvORCE
COMPLAINT IN DIVORCE
NO FAUL T
1. Plaintiff is Valerie L Yannone, an adult individual whose mailing address is the marita1
home at 17 Grant Court, Carlisle, Cumberland County, Pennsylvania. However, Plaintiff is in a
temporary residence pending the issuance of a Protection from Abuse Order, The temporary address is
1002 West Foxcroft Drive, Camp Hill, Cumberland County, Pennsylvania.
2. Defendant is Gary S. Yannone, an adult individual whose current residential address is
unknown but whose last known mailing address was 17 Grant Court, Carlisle, Cumberland County,
Pennsylvania.
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 November 16, 1996, in Cumberland County,
Pennsylvania.
5. A prior Complaint in Divorce was filed by Plaintiff on August 6, 1997, and was
docketed in Cumberland County at 1997-04232, A Praecipe to withdraw that Complaint in Divorce
was filed on December 18, 1997, There have been no other prior actions for divorce or annulment
between the parties,
6, Neither the Plaintiff nor the Defendant are members of the United States Anned Forces
or its Allies,
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7, Plaintiff has been advised of the availability of counseling and the right to request that
the Court requite the parties to participate in counseling. KnO\ving this, Plaintiff does not desire that the
Court require the parties to participate in counseling,
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 the filing of this Complaint, consent to this divorce,
WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S.
Section 3301 (c).
COUNT II
INDIGNITIES
11, Paragraphs I through 10 are incorporated herein by reference as if 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 Count to enter a divorce pursuant to 23 P.S,
Section 3301 (a) (6),
COUNT III
EOUlTABLE DISTRIBUTION
13, Paragraphs I through 12 are incorporated herein by reference as if set forth in their full
text.
14, Plaintiff and Defendant are joint oVvners of certain real estate located at 17 Grant
Court, Carlisle, 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.
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16, Plaintiffand Defendant have incurred debts and obligations during their marriage which are
subject to equitable distribution.
WHEREFORE, Plaintiff requests your Honorable Court to enter a decree equitably dividing the
parties' property and equitable apportioning the debts incurred by the parties,
COUNT IV
ALIMONY. ALIMONY PENDENTE LITE.
COUNSEL FEES, AND EXPENSES
17, Paragraphs 1 through 16 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 as she is working on only a part time basis,
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 the
Plaintiff,
WHEREFORE, Plaintiff requests your Honorable Court to enter an Order of Court requiring
Defendant to pay counsel fees, expenses, and costs as well as providing for payment of appropriate
alimony and alimony pendente lite to Plaintiff.
Respectfully submitted,
GRIFFIE & ASSOCIA TIS
~~-~~~~
Kristen Goddard en, Esquire
Attorney for Plaintiff
GRIFF1E & ASSOCIA TIS
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
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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: 6arJ!tf9
1MN~C2#/J~
VALERIE 1. Y ONE, Plaintiff
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Plaintiff
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:IN THE COURT OF COMMON PLEAS OF
: CUMBERLA1'<TI COUNTY - PENNSYL V A1'<1A
vs.
: CIVIL ACTION - LAW
GARY S. YANNONE,
Defendant
: NO. 1999-3958 CIVIL TERL\1
: IN DIVORCE
PRAECIPE TO WITHDRAW COMPLAINT IN DIVORCE
TO: THE PROTHONOTARY
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On behalf of the Plaintiff, please withdraw and discontinue the above-captioned divQrce
acti0n.
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Respectfully submitted,
~~~
Kristen Goddard D en, Esquire
Attorney for Plaintiff
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
EXHIBIT "e"
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Griffie & Associates
, ATTORNEYS AND COUNSELLORS AT LAW
0200 NORTH HANOVER STREET' CARLISLE. PA 17013' (717) 243-5551
038 NORTH MAIN ST' CHAMBERSBURG. PA 17201 . (717) 267.1350
TO: /-ILl h,(& (-;frd(
Date: i i/ L'C I CO
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The enclosed material is sent
FOR YOUR INFORMATION
FOR YOUR REVIEW
Re: /r, -1(!r,,1(
o AT YOUR REQUEST
o PLEASE CALL TO DISCUSS
lirhrj (oi.Jia cf
Please contact us with any additional questions''1>b''~' '1i0~r'
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EXHIBIT "D"
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LISTING CONTRACT
EXCLUSIVI~ RIGHT TO SIlLL RI~AL I)ROI'lmTY
rhis f"'IllI..,.""1m....lllh.11 ami ilPllrnvcd for, hut n(lll'cstriclcd tll nse hy, lhe IIlclJlhcrs llflhc PCllllsylvimill A~s"dilti"lIllfHEi\t;nllt"i'" (l'AHI
XLS
:~::~:,~~:~:,~::~')"'p,'I'tJ\).L,J,.:H~I~'~c ';t\:.,'~~t:I~,;;:.;:-~...- ".~._n
sJt:l,um (';/~~-"-'r 'c::,~1-'2Tl)' ___..Lj-T :l![.:yR-~--::;---~:;e---~--'----
_ , ." ",_,_ ~En__n__'n'nJ'='__,.._.,_,..,",.,_
1,1'l(f)I)I,:I(TY
Addu'ss ,. (0-1"\1,-\1 C'\ ("',-)l't 1':>14.2. \')\
t\ltllllllll.llll)': ICIlY, hllHlUgh tuwllsl!lp) t:::\\Z: n l .____~~~_~_,~~_-:.._____ ______ _ , u_ .. .
('tIHllly ~...........bt.r.",~ Lt__. SchOtIII)islricl,~ _~'~JLl
Intllll)! ,1Il111'1l'st'nl (lsl' k.:'A..Dl&-w......; tZJJ
IIil'nlifit.:allun Numhl'r Ihlll'X,Ulllllc, lax lllclllil'icalioll number; parcelnulIlhl.'r; del'd hook, pa~l', I'l'nutlill~ dall'}
IJSTlm "I(I('I~ $
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2. STAIHIN(; l\ ENUlN(; I);\TI~S OF 1,ISTlN(; ('ONTltACT (also l'al!i..'d "T('nu"l
A. Nil A.'isocialillll Ill' 1{J~AI:n)RSll\l has sel Of rccollllllcnded thc lerm oflhis conlracl. By law,the kll~11I III ll'l'tll 01 a Iislill1!, l'illl'
lracl Ulay 1l1lIl'Xl'Cl'd lllW ycar. Brokcr llnd ~kllci' havc disctlsscd and agreetl UpOIl Ihc lenglh or h.'nll of Ihi,'i nlllll lid ,
It Shll.till~ null': This {'oulml'! .~llllls wlwll Si1!,Ill.t1 hy Bmkcr anti Sdlcr, lInll~ss utl1l'l'wise .~Ial{'d lint'
(', I':ndill~ 1);lh': This COlllral'1 l'lltlS 011
J. l'UIU'OSE (WTIIIS CONTltA<.'T Selll'r i.'i hiriug Broker IOlllarkd Pmpel'ly and In fiud a huyl'l'. Sdkl willll~fcr ;jllllITct'.~ ;tlld
illqllirk,'i lu Bmker. Selin allow:-; Broker 10 use prillt and/or dcclrollk advertising. llroker is al'lin~ as Selin A~l'UI, liS Itcsnihl'd
illlhc('tlllSIIllll'r Nullee.
4, H1U)KElt'S FEE Nil Associalillll uf ItEAI~nmS(I() Ita.'i set yr fC71lllllllcm,I",d 1111: BftJkl~r's Fcc, Brokl'l' allll Sdkr haw llegoliah.'tJ
Ihe Ii.'l' Ihal Sellcr will pay Bmkcr. The Broker's Fec i.~ ____---1.J1!_K2____~ _a__ . IIJJfrolllllll' .'iak jlJ'll-C and paid hy Sellcr.
5. ('(IlJlllmATH)N WITlI CHlllm,IIIU)KEIlS l,kclIsec hasexplaincd IImker's l"OHljllllly policies all\lIll nlllJIl'I;ttin!! wilh llllll'r
hwkl~rs, Bl'Okl'l' anti Sl'Ilcl' "!!fec Ihal Broker will pay from nrnkcr's Fcc:
A. A Ih' tn llllnHlt'l' hl'n~l'l' who n'lln'sl'lIls Ihe S,",", 11'1' (Sl_~IJA,(, a.,:, NT),
[J No l:J Yl'S If Yl'S, amounl: _ __ 3'!.J;2 _, ,.. of/fmmlhc sltlc price.
B. A rei' to 111I01111'" hrokel' who 1'('111'1's(.'lIls 1Ilmyt'r (nLJYEI('S A(a~N'n. A nuyer's ^~cllI, t'vell if l'UIIIIJl'II.","led by nrukel'
HI" St'Ut'l" ",'i1II't'llI'~Sftlf Ihe illtel'e...."", Ill' Ihe Im)'cr....
( I Nil M Yl'S If Yes, alllUlllll: 3'10 ollfnllll Ihl' sail' lll'in'
c. 1\ fec tu 1II1ulll("1' hp~.cl' "hu (lues nol l'elu'cscnl cithl','jlw Sl'Iler 01' II buyel' (TI(AN~'\(' nON LIt 'J-:NS":EI,
o No ll'-Ycs If Yes, amounl: ~~ of/from the sale price.
6. I"A\'I\,IJt:NT (W HROKI':I('S Flm
A. Seller lUust I)IIY IIl'nkel"s Fee lI'III'OIICI'.y, or IIlIy ownership interest In ii, is sold orexclulIlgcd dudn" the length or tenll
ul' Ihis Cuulnlt'1 h)' Uruker, nl"Okel"'s lI~t'lIls, Sl~lIel; or by 1111)' fllh~1" lu'rsoll III' hroker, al Ihe Iish'd 'ldl'l' UI" 1111)' Ill'il'e
OIl'l'Cllhlhle 10 Sl'Ilt,..,
H. Seller will pay Broker's h'c if m~gHtialiulls Ihal arc jlclllling allhe Ending Dale Ill' Ihis CUlllrad 'l'sull it!;1 .~atl'
(- Sl'lkr will pay Bnlkl'r's l;l'C "fieI' Ihc I~lllling I)alc Ill' this Ctlnlracl II;:
(II A sail' t1cnlrs wilhin . LD-- days of Ihc Ending Dille, AND
':'1 Till' huyn wa.~ showll or lIcgulialcd In hllY the Ilmllcr.y dllrin~ Ihc IeI'm uf lhi.... ~Olltral.1.
Sl'ih'J' nill nol IIWt. Ill"Ukl........ .,'1'(.' If tilt' l'nllll'I'tl' Is Ibh'cI undl'l' 1m "l'Xl'lnslve I'Ighllo Sl'lll'UlIll'IIl'l" \\ ilh IIlmlh"I' hrukl'f
III the lillII' ul'the snll',
7, IlI<oKlm's l'Im II' SAI,I<: OUl,S NOT OCClIll
A St'lIt'I' willl.lll' Urukl'f'S Jit't' iI'II n'ud.v. willin~, !lull Ilhlt, hll.Yl'" i.... I"mllld hy Umkl'r lJI' h.}' :1II.r1llU', iudmlillg St'lIt'I', A
II'IlIill.l: "",.,,/ i:-.oul' witt I willl)ay lhl' lisll'd jllin' HI tllll!'C 1'111' IlIl' I'mjll'tly, "I Wll' wllu hll.~ .\Uhtlltlh'd all nlh'l m"l'l'I'It'd hy
St'II~'r.
B. If 11ll' 1'lJ-ljIl'I'ty lll' allY pm'l of it is luken hy ,lilY gnvcrnmcnt for puhlic 1t.~C (Elllinl'1l1 DOlllainl. Seller \~ill pay Umkl'r
,_ (PIlI) ol/fmm UllY lllOlley paid hy the governmcnt.
('. If" hUYl'r :-.i)!t1S all agn'l'llll'lllllf Sille Ihell rcftl.~l'S III huy lhl~ Pmpcrty, or ir a huycr is unahk In huy il hl'l'.I1t.\l' Ill' j';lillll~ hi do
:1111111' lhin~_s n',tl)lin'd Ilf thc huyer in Ihe al:!rl~clll(,lllllf sale, Sellcr will pay Brukcr:
II) (.1 0' Ie ulllrolll huycr':-; dcplIsil lIl11llics, OJ(
l!1 Ill\' III'1Ikl'I"S (o'l't. ill l'i1mgntjlh 4, whidlcvl~r is lcss.
H. InIAl. Afa:N( 'Y Sdkl' agre~s Ihal nmkcr ',nay abol'CprCscllt Ihe Imycf(s) or lhe I'fUPt'fly. IIrnkl'r i:-. a I H lAI. Al iFNT wlwlI
'l'pl'l'SI'llllll~ bolh .I\dk.- ;tllll the 11IIycr in Illl' suk tlf u IImperly.
l) 'Si~Ultlcd A~I'Ul'l:
NuIA'llllkllllll'.
1 '1'1'111':11111' 111.,1"1 :\. II1\' l)lIal.-\!~I'IlI. Ill:l}' dl'_\iguall' lil't'I1.~l'l'S 1\1 H'Pll'Wllllhc .~l~pmall' illll'I\'\I:-. 01 Sdkl :111<1 Ihl' Illl)'I'1.
l.in'l1sc\~ (itkulified "hove) is Ihe I)l'sigllal~d Agenl, who will ad CXdllsivcly as Ihc Seller Agl'lll. If I'Hlj1I.rty is llllllldun'd In
11\1' hltYl'r hy a lin'lls\~e ill IIII' Company whu is lIul represcnling Ihc hUYI'f.IIIl'lllhallil'cIlSCI.' is allll1~ui/l'd 10 Will\.. tltl hdlall
of Seller. II' l.in'u:-.el' is al.~llthl' Buyer Agl~nl, Ihl'n_I,it:e!lsl'c is iI DUAL MiI~NT.
I', UIU)lU:WS S~(n\,I('E TO IUI\,II:lt UfOkl'1 lIIay providc servin's 1\1 a huyer 1'01' whit:h Broker limy aen'pl a kl.'. SIll'h \l'I\'ln'~
Illay illdmll', hUI an' llllllilHill'lI 10, dC":111 dul'tltllt'lll pll'lmralioll; onl..:riug l'crlifklllinfls requirl'd for dll~ill!!: liuiuwi:ll ~1'I\'in'~: lilk
11':lIlskr allll Ph'j1:Uilliuu Sl'f\'in's; ul'Lkring ins\ll'alln'. nlllslrtldillll. Il'pail'. llf illSpl'l'liulI sl'.vin'~, IlIol.l't \\'111 ,Ii\l'lll\l' 10 Sdln il
allY In'S ale 10 hI' paul hy IhlYl'r,
10, OTIli':lt l'IUWEnTIES Sl'Ikr a~ll'c.~ Ihal Broker lllay li.~1 tither propel'lies fur .'iulc and Ihal IIlukn Illay \110\\ ullwl' propl'llics
hi pnJ.~llcetivl' huyel's.
II. ('ONFLH'T OF INTI':ltI':ST A {'olllliel (!(illlf'W~1 is wht'n Bmkl'f III' I.in'nscl' has a financial tll' IWI:-'llJlallllkli'\1 Whl'l'l' IllUkl'l
01 I.il'l'n:-.l'l' ~'alllllll pUI Sl'lkr'~ Inlt,'II'sls hd'ull' any ullll'r. If Illl' Uruh'r, 01 auy ur 1I1l1~l'. \ sak~ll\'opk. lIa\ a, olll/i. I tlf ill/f'II'H.
1I111l.n willnolily Selll'l ill It liml'iy I1UlIlIll'/'.
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21. IlEI'()SIT MONEY
^, lhll~\'l, lII' IIIlY pCISOlI Sdlt'r 1I1l1111ll' buyer nat11l' inlhc ^g.I"('I~lIlCIlI of SOlie, will kl'l'P all t1l'IH1Sillllllllil'" paid h}' Ill' fill' Ilw hllYl'r
ill an ('Sl"fll\V aCl'Ollll1. II held hy Broker, this CSCf(lW lll'cuunl will he held ns required hy It'all'stak lil'l'lIsillJ:! law,s and n'J:!llla
j;um. ."idler "PH'I','; Ilia' JIlt' /wr..wn kt't'piu!1lllt' 111.'1'/0,\;;1 ill/miL's may W;l;' In dt'PHS;1 :1II)' I/Ilc<l,\IIt,tl d<<'d.- ,'',,' h Il'{'{';n'd :I.~
1I,'p"<';11 1ll1l1l\'Y wild .'idler has an'l'plcll an \lfk!'.
1\ If Sdkf iuills Broker or Lkcll,scl' ill a Inwsuil for the rcllIrJ1 of deposit lIIonics, Seller will pay Brllker's and l.kl'IISl'I"S alllll
m'ys' fees and eosls.
22. ItI<:( 'OVEn\' FlINIl I'clltl.sylviUlia has a Ih.-al I\slulc Ikcuvcry FlInd (Ihe Fund) In rcpay any persun whll has rn"l'lVnl a fill,]1
nllltl mtiug lcivil illdgrlll'1l0 i1~ainSI a l'ellHsylvallill rcul cslale liccllsl'e heciltlsc of fraud, llli.SH'PI'l'Sl'lllaliulI, or dn:l'il in a 1'1'011
(";lah'llilll,\atlillll -I hI' huulH'pays pl'ISUlIS \\'ho haw Ilollll'l'll ahk III l"lllll','llhl' .illdgUl\.lll illh'lll)'illl~ illllaw!"ul ways III tltI SII.
1,'01' nllllpkll' dl'lails ahnUllhc 1'lInd, nlll (717) 7XJ-.\h5H, m (HOll) Hll.211.\ (Wilhin I'ellll.syl\'allial alld 171'/) 7ln .IX5,llolllsilll'
"l'lIl1sylvania).
2.t 'I"ItANSI'EII OI'TIIIS ('ON'I'ItM'T
A. Ihuh.l will unlify Sl'Ik'r illllllcdiall'ly in Il,.Tiling if llrukcr 1l"illlsli.'l'.s Ihis ('olllrlld III anolhl'r hlukel wlll'u:
( t I Bnlkt~r slops dlliug hu.sincss. 01{
i21 Bnlh'l' ftll'IllS a new rClIl eslale Imsincss, OR
(.\) BlOker juiu.s his hllsilU~SS with illlllUlCl'.
SI'I"'r a!!rc('s Ihal Uwkl~r liIay Imnsfer Ihis ('ulllraclln unulhcr hrukcr. Bwker willlltllify SellL'r illlllll'dialely ill wl'ilillg whell
a Inllls!i.'l tlf,'llr" 01 1I1'1Ih'l' willlusc Ihl' righlto llOllI,,,fcl' Ihis ('Ilulmct. St'lkl' will fllllllw alll"quil'l'lll"IlLs of Illis ('olllla,'1 with
lhe nl'W hill!,;,'!'.
II, Slulllld Sl'Ill'.- giw Ill' l.-amfct' Ih(' Properly, Ill' Ull oWllcrship inleresl in il. 10 anY"IlC during Ihl' 1l'l'1IJ .,1' Ihi,s ('olllrad, all UWll-
t'l~ willllll!.t\\' lilt' It''llIil'I'lIll'nl~ Ill" Ihis ('n!lllad.
24, NOTI("I.:"I'O l'EnSONS (WFI<:IlIN(; To SEI.I. Olt IU~N'I' 1I0USIN(; IN l'I';NNS\,I.VANIA h'd,'lal allll ,slall' I<lW,~ 11m",.
il ilk~al fill' Selin, lInlkt't', 01' anyone III II.Sl' R^( 'I':, ('ell,(>R,I~E1.I(iION ur HEI,lClIl)1IS ('RI\Ell, SI\X, I HSABII.ITY lphysical
01 menial). I;^MII.I^'- STATlIS h:hildrcll ulIlk.. IX ycal's uf age), Mm (40 nr older), N/\TIONAI. ORICiIN, lISE OR "^NDI..
IN(ifrRAININ(i ()I: SIJI'I'(m,T OR GlJIIlE ANIMAI.S, Ill' Ihl~ FACT 01: REI.ATI()NSIIIP IlR ASSe l{ .11\"1'11 IN T() AN INI>I
VIIH 'AI, KNO\VN 'f'(l "AV'~ ^ fHSAIHI.lT\' as 1'(,ll,~lms fur rcfilsinl!- 10 self, show. Ill' l"l'ul pl'UPl'rlics. Ill:llllllllm.y. 01' ~l"l,kpll"il
;llllUlllll.~, III as H'aSOIl.S for any dl'dsillll rdalillg III Ihl' ,sale "I' prupl~lly,
25. NO OTllIo:lt ('ONTltACI'S Sclkr will not 1'II1('f illln llllulhcr lisling agrt.'clIlt.'llt wilh anolher hroh'l Ihal 1Jt'J!ill~ Ill'lni't' llil'
EllIlill~ flail' of Ihis CUlllrad.
2fl. AIlUlTI()NAI, (WI"lmS ON( 'I~ SI]J,Im ENTERS INTO AN ACiIH~nMENT' 01" SAI,I~, B1H)I\I':I~ IS N(lT RI~()IIIRI;.I) T()
I'RI~SI~NT(rl'lll;R ()('VlmS,
21. ENTinI': ('ONTnACI' This Cnnlnlcl is lht.' l~lllirc agl'eclllcnl hclw("l.'n Bmkcr and Sdlcr. Any wrhalul' wrillt'll al!fl'l'llll'Uh Ihal
\\'1'H' lllollk hdllll' an' 1101 :t parlor Ihis ('onlml'l.
2M, ('IIAN(;ES Tt) TillS l'()NTItAl:T .AII l'hallges \nlhis l'()lllnld lllllSllw ill wriliug illlIl.siglll.d hy Ilt'lt...el ;lIId Sdkl
29, SPECIAl. INSTIUJC'J'IONS 'rhe Office of Atlorney Genernl has Ilul pre-llppmvcd rillY special t"t)lJt.lilitlllS or adtlilinllllllcnns
mlllt'.1 hy allY jlill-lil's. ^ny spcdall.undilillllS Ill" additiollllllenlls in Ihe t'Ulllral.ll11usl l:tIlllply wilh Ih,' I'('llllsylvilllia I'laiul.augullgl'
('UlISlJllIl'f ('ulllrat'l Al'l
AIlIllTIONAI.INHlRMATION {OI'I'IONALI
.10, TAXI':S.lITnLlTIES. & ASSOCIATION n:ES
A, AI Sl'lIll'IlU'lll, Sl'Ikl will !luy onc,IUllf nf the Inial Relll E.~lalc Transfer Tilxes, unless illlwrwisc s!illl'd here:
n Real Eslale Properly Tax Assessmcnl $ __,____ Yenrly Taxes $ __~__~
Wagdlllt'OllIt'Tax ..____________.._ Per CallHa Tax $ _~___
('. !':,slilllnletllllilili('s Uiil,sh, Wl\ler, sewer, eleclric, gas, nil, elc.)~.____.
Include.
1>. Associalion Fees $
E Olllt.'r
.\1. IUJ\'lm FINANClN(; Seller will Ul.'l:cpllhc following lIrfallgenwllls fill" huycl' 10 pay fOf IIU' l'ropl'llY:
'to-Cash
i? BIlYI~I' will apply for u mortguge. Typl'l.s) of Illorlgages ilt't'cptahk 10 Seller lire:
~Yt'S 0 No ('unvcnliunal 0 Yes ~NtI HIA
~~Ycs 0 Nil VA 0 Yes 0 No
n Sdlt'l \ h\'lp I.. ImYt'r lilaIlY):
St'llt,.. hus I"l':ulllw << 'HIlSUllll'l" Nnllt-c us udOI)h'd hy Ihe Slnte Relll E.'illlh,' ('olllluissiulllll 49 I'll, ('mil' ~J5.,Ut,.
All Sl'lll'l".'i must si~1I Ihis CUlllrud.
N()llt ')I: nmt'()ltI';SIt;NIN(;: IF SEI,LER liAS l.ltGAI.QUESTI()NS,SI~LI,ER IS ADVISEU'I'<<) {.()NSlll:r AN ATTORNEY,
SI':I.I,I':U
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12. SETTI.I';MENT & l'OSSI':SSION
A. ,1,-ch'ln'lI ,()(~IIIt'IIICllll):lte:
B, SeliN will g.ive posscssioll (If lhe Properly 10 Uuycr at seUlemcnt or Oll~~~-=--=-=~,--~~
C (II If th,' I'WPNty, or any partnf iI, is rented, Scllcr will give llny k.l.~cS to Ilruker he fore Si!-:llill!-: lhis ('UllIHll'i.
(11 If any leases al'e oral, Scllcr will providc a wriuen sUlIllllary of the lCHlIS, including amollnt uf rcut, elldill!-: dall" awl
Tenant's rcspllllsihililies.
(1) St'lkr will lint enter illln or rcnew <IllY Icas,~ during Jill' tcrlll of this ('olllmct except as lllllllws:
1.1, TITI.E
^,
1\,
AI sl'llklll~'lIl. Sdk.. will give flllll'ights of t1wlwrship (fce simpld to a hllyer ('xn'ptl1s follows:
(I) Mincmt Rip,hts Agrcclllcnls m____~..._.___.._ _,.._.-
(2) Other
Seller has:
\i-. Yes D Ntl
Mmlgage with F_I t:10rJ:g~ COf(le:::~7.u- "'___ "_,,
Mires' r,o.r;o~att....:rL'Lin~ ,.-a63I'h"nc fQa::.J~'/-ZJ,.
^ccl. #DQlL'ld.q'l5,53u_~_,__,_...,_1I'mouul ,,[halance $ \;J,'h '61u1.. 1'1,
I~qllily Illall wilh,___,_,~_._ .._____,__.~~,________
Address ~"_.,__
An:1.1I
Scller llllthuri"es BrokcI
kmlcr.
I'a,~t I )(u.' 'llllr.I~!> AlIl\lIll1t llwed $..
Judgments Amount $
'I'ypc _____~______~_~_______'___
Municipnl AsscSSlllelll.~ Amoullt $_~_....____________
Othcr_ ._.____~~______
AIlllltlllt $ _______________~_____________
C. If Sellcr. al UIl)' lime 011 or sim:c January I, I (NH, has becn obligalctllu pay support umlt-r an nukl Ihat is 011 recol'd in allY
l',~nllsylvanja cOllnty, IiSlthe Cllllllty and the Dnmeslic Relations Number or Docket Numhcr:
14. MVL'I'JI'U~ J"STIN(; SEUVJCJ~ (MLS) (Coml)lelc jf Broker is Jl member of 1111 MLS)
o Umkcr willusc 11 Multiple I.i.~ting ServiCl~ In udvertise lhe Prnpl~rly III olher renl eslillc snlesjlel'snlls, whll,'an tdllh~~il' dil'llls
and custOllll'l'S ahotll it SelIcI' agrees thai the MI.S, the Broker, nnd the I,kellsee arc lint rc,~p(lll,~ihlc fur lllislil"\',~ ill Ihe MI.S
lkscriptillllllf Ihe 1'l'upl.'rlY,
[J Ilwh, willunt us~' a Mullipk 1J.~ting Sl'I'vil'e 10 advcrti,~~~ the Propt'rty In llUu'l"l'l'al ~'slal(~ .~aksp(,NII1-~
IS, l'UIlLlt'ATION (W SALE PIUCE
^, Seller is nWllfC Ihatnewspllpcrs lllay publish the lInal sale price lifter selllelllClll.
B. Seller wiI~ l~lllW publishing nf the sale jIl'ice lifter Seller llccepts an Agreement of Snle,
o Yes ~No
16. Slj:NS & KIC\'S Seller allows (where permilled):
~Xe,~ 0 Nil Sak Sign i9:.. Yes
o Ye,~ ~H Key ill Office )ilL Yes
DYes 0 Nn ..,...___~__.__~_~____
17, ITEMS INCUII)EIl IN TilE I"IUCI~ OI<'TIlIC l'IUU'ElrfV
A. Included ill Ihe sale and purchase price arc all existing ilems permanently inslallcd in the Property, free of licns, illclutling
phUllhill/!: IleOlling.; Iighlillg fixtures (indudillg challtlcliers anti ceiling rans); Wilier treatmelll sysh'ms; ponl ami spa (~quipllll'nl;
l!.afa!\,' dulll' olwllef~ antltmuslIlillers; tdevision antetlllllS; shruhhery, plantings, ami UlIpollcd trc,'s; any f~'I\lailling IWllling ami
L'tJllking fuds Shlll'tl ollthc Property althe time of sclllelllcnl; walllu wall cllrpeting; winduw L'tJvl'rin~ hanlwillc, shadc,~, allll
Illitllls; hllill.ill air l'lllldilitIIlCrs; huilt,jn uppliall!:!'s, lI111lthe filllgchlVcn, ^Istl illl'ludc\l:
[] YI'S
o Nil
[] Yt'S
o No
_._'.,___.______~_'"'_____ III\I)IIC
^lllnUlll 'lfhalalll'I' $
In receive mortgage payoff uud/or etluily luall paYlllf InhlllllllliulI hum Ihe
U Y\'S
o Y(:s
LI Nt!
o No
dYes
DYes
o No
o No
o No
o No
Suld Sign
I ,tick !lox
B. 0 See uHadll'd shed for additional items included in the sale.
IH. ITEMS NtH IN( '1,IJBEI) IN TIlE IIIUCI'; ()F 'I'IIE l'IUWleRT\'
The llllluwiuv. ili'lII.~ alC 1101 induded in the plll'cIlase und pdcc Ill' the I'mpcrlY:
^,
II, Itl'llls n'lIt\'tl hy 1111' S,'llef _____.~~_' _~__~___________
(', 0 Sl'l' Illlitdll'd Shl~eI for addiliollal items lIut iudmlccl in Ihe sale,
1'). SEU,I';U, WII.L IU:VEAI.IlEFloTTS & I';NVIIU)NMENTAI.IIAJ',AI{I)S
A. Sdle,. (jlldlNlill~ St'''I't',~ l',WIIII'I l'rullllhc Helll E~Wlc Sdk'f'S DisduSIlfC At'l) wjlJ ili.~dllSI~ all kUIIWlI milledaJ ddl'l'ls luul/Ol
Cllvimlllllclll..1 hawnls 011 a Sepilnlte disclosure stalcmenl. ^ mutcrial defect is a pruhlem or l'lllldiliolllhal:
(I) is a po,~sihlc danger tll lhuse living onlhe Prupcrty, or
1:'\ has a si~lIinl'allL adwrse errc"t nu Ihe vahll'uf IlIe "rupefly,
II If Sellel' fails III 11..'11 of known nmleriill defeLls ancl/ur environlllental hal.ard,~,
tl) Seller willnol hold Broker or Licensee respol\sible in ilny way;
tl) Sdlcr will pmkcl Bwker and Licensee from any duims, lawMlits, llml m:tinlls thai result;
ell SelicI' will pay all of Broker's and I.ke'l,~ec's w,~ls t1wtl'esUIL This includes illlorneys' kes ,md VOHll-uuil'n'tl paYlll~'lIls
Of scHklllellls (molley Broker or Licensee pays 10 end il Jawsllil or claim).
20, II' 1'lUWlmTY \VAS nllll:.. IHWOIU: 197H The Fksillcnlial Lead"Bllsed Painl lIal.anl Uedll{'lillll Al'l "ay,~ Ihal IHlY Sl'Iln of
p"llwlly huill hd"ol'l' 19-,X lIlusl v.ivc the huycr an EI'A pamphlet tillctl/'mfj't'/ lill/,.I'"w"ilv 1,'//111I 1,/'/1//;/1 J;'I/I IImll/' Th~' Sdkl
abu llul.~llclllhc hu)'l'f and Ihe IImker whatlhc Seller knows ahout kltll.b;lscd painl "lid Icatl,hils~d li,Jilll h,muds Ih,,' all' iUlll un
Ihl' property heing sold. SelicI' lllusttcllthc huycr how the Sdtcr knows that lead-hased painl and lead hase(( pililll h,uanls all' llll
Ihe property, where thl.' Icad-hilsed paiullllUlleild-hascd painl hawJ'(l.~ arc, Ihe condition of the paiuted SHrj';l~'l'S, ami "ny ollll'r illlOl"
Illaliun Sdl~'l knuws aholll kad-hased painl illllllcad.lms~d jlailll hanu-ds Withe pmpcrly. AllY Sdkl' of a plI'- PUX .~llm'llUl' 1II11~1
abn givc Ihe huycI allY rcnlul.~ allll rcpmts Ihilllht~ S"I\I.'r has Ill' call gel "bolll lcad,hasl'tl paint 01 kad hil,~~'d pailll h,II,lld.~ 1II111
annllltllhc pmperty heing snld, thc Cnllllll(lll areas, Ill' olher dwellings in lllulti-family hnll~ing. ^u:oldilll! !lIthe Aet. a Sdln mll~1
j-:i\'l' a hllyt'l 10 day,~ (lI11k_~s Sdkr all\llll\' huyt" agn'l' hI a difh'n'Il1 Iwdud of lillll') fWlIIllw Ilull' alll\!,-I\'l'lll"lll 01 Sakis ...i"lJ('d
III ha\'~' a "Ii\h a~~~'~~IIlI'H'" IIi' iHSP\'\'lillll for pu,~sihk lI'ad !.ms\'tt paillt ha/ill'lls .hul!' lllllhl' 11l111H'II~ IluYI'I~ 1I1.1}' l'h'UN' llol III
'h:,,', i!;;- i,,'I, L '''1,'111 "I ;,,-.p'" rinll (i" 1...,,1 f\ "", II" "".r, .I"",' U' n" 1.11' " ,),,,,,,,,, II'" /,,),,' oj" ,r ,', I,,,,,
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Single Family Detached- Input Sheet
OE1'ACHEO
ttDTRAL renD mutn.u51', IlK. n c.JC~n\ Lc, \..l_,tt- Cc~v~(, 1)<-
Property Addles&;.. \. '1CI ~
\ I( , \ 4
Agent Name: vt""'-'-v1.. 'r.i. - I """_'."'-l.A.-_ Date Listed: Listing #:
I
'Sub 1'ype (spn ill SF - Detached OT-Other I "List Type (Ln , , , , ERS . Exclusive Right to Sell EA . Exclusive Agency
MH - Mobile Home I RP - ERS with Reserved Prospect OTH . Other
FR. - Farm/Ranch I VR.C. ERS with Variable Rate Compensation
"List Date (lO) , , ,I , 1 ,I, I , "Expire Date (XO) , , ,I, , ,/, , , "List Price (lP) ,I;; ,~c.:,l:.'<~1 , ,
~ub Agent (SAC) I~ I , I , ~Suyer's Agent (SAC) l:::::t I ] ] , Other (OAe) I I I ] ] I ] ] ] , I Transaction licenses Fee (TlC) I , ,
,
"County Code (CCO) lll~4_~'-\1::: "Property \0 No. (P'N) , , , , , , I , , , , I , , , , , , , , , , , , , , , , , , ,
"List Office (LO) .tc{ , "List Agent (LA) ,1-(77..,1, L( I
If If. -III , I , , ,
List Agent 2 (lA2) , , , , , , , , ,
List Agent 2 Name (lA2N) , , , , , , , , , , , , , , , , , , , , , LA 2 Phone (lA2P) , , , , , , , , , , , , ,
Owner Name (OWN) ,y,?,L',i-.;('("U( , , , , , , , , , , , , I Owner Phone (OWNP) , , , I , , , , , , , , ,
Direction to Property (DIR) ,lid ,10-1 , I'L. ,Il..vC.,il,T, i , 1)/1 \(1 l-\.I oC>,o. , -r, , , , , , , , ,
, , , , , , , , , , , , , , , , , , , , , , , , , , , , , , ,
Directions 2 (DlR2) , , , , , , , , ,
Possession (POS) , , , , , , , , ,
"Disclosure Form (Y/N) (DISC) u
Address , , , , d~, LL.l ,&r~l~r1\" , , , , , , , , , , , , , , , U, , ,
Slroet No (STN) Slroet Ojr iSTO) . Street (STR) ;i?,~'). S_ Type (STt)
City (C1Y) CL1,K., L ,I f> ,L, e, , , , , , , , State (Sn "ZIP Code (ZIP.Z4) " ,1,017,,-, , , , ,
Subdivision (SDV) II.-rt, i4't,--zj.. '\~L' ,~ ,U,(, i'''PhT~ , , , "Area (AR) , , 1],
Map Page (MPAG) , , , , , Map Coordinate (MCRD) , , , , , , ,
"Municipality (MUN) ,(\ "IL,Tli~ I )...j...\ I".6C~1 ~lr-ll" ~-'"'\ , , , , ,
Road Frontage (RDF) , , , , , , , , , , , I , , , , , 1 , , ,
Remark5 1, Gu.., ,('.... T, , ,",~\, 1;4. r; ,(, r; ,A i~c., ,.. tLf\-"" ,Cudl, 1t')(".1 r Show Instructions
l'"::':f
, I 'iJ.. I Ii n oUl I G ~ fr /~ ;L , L. eY1I Sub Agent (SASHO) Buy Agent (!!ASHQ)
(RM1) ,,::, G. I~\I-r-I)..l.l , , , , , I ,
Citc/e all that apply. Circle all that apply.
Remark' 2 r .lot , 1'7.p It\. II.? I It.-IU \\') ,;, I~Tt( ,1":1'(, 1101...1 III ~~ In, I~' 1\ a . Call List Office a ~-Call Ust Office
\ C . Call Owner C . Call Owner
(RM2) ,t"'f' ICI~I l":l P"\I( 'H- , , , 1 , , , , , , I I , , , I , I , o . Call Wst Agent o - Call1..ist Agent
e . Call Tenant E . Call Tenant
Remark' 3;1\~ I C.. '\:1 V-'l{:7H 12,f"J4,12, ,G('1(11-;:;~ IC~ If.l~ 1;.,\ltrlC"I.....l Ti F - Key in Office F . Key in Office
G . Shaw Ao,! T'tme G . Shaw Any Time
(RM3) ,0, {,v,s. , , , , , , , , , , 1 , , , , I , , 1 , 1 , , , , I ~,t"eomoanY Show H , ~=moany Show
.''Appointment Required c:G.APpointment Required
Remark. 4, ~ Ii j;!":; A .\. Ii", ,"'f rd r; T , 1\6 l~"..f\..1 ILl t~ {"~. m..:.Vl. j . Sign-in Sheet Required J - Sjgn~in Sheet ReQuired I
't , , ,
(RM4) ,T,C, " '6- Ie Ac:i ! 'It ,;r (..1 P <;', k?r tl:: J1 , I , , , , , , , , I
,14'=::,1':'. t I Lock Box Description (LBD)
RemarkS 5 I , , , , , I , , , , , , , , 1 , , , , , , , , , 1 , 1 , , I ,(j7JV, L. , I I I I I I I
(RM5) , , 1 , I , , , I , , , , , , , I , , , , , , , , , , , , , ,
Occupied (OCP) G
RemarkS 6 I , 1 I I , I I , , , I I I , I , , , I , , , , , , , , , , , O. Ov./ner
, I , I , , , , , I , I , , , , , , I , , T. Tenant
(RM6) , , I I , , , , , , V. vacant
.Photo Code (PHO) ~ A. Take primar{ photo C. No phOto requested 1. Submitted
Instructions (PI)! , , , , 1 , , , , , , , I , I , , , , , , , , , , , , , , , I , I , , , , , , , ,
, , , , , I , , ,
f.doc 11/8/99
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"
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~
Property Address:
, ,
'Total Square Feet (TSQF)
Lot Dimension (LOTOM)
New Construction (NCO) '-1
Number of Rooms (RM5)
'Number of Bedrooms (BR)
Year Built (YBL) (+/-)
Number of Stories (5TO)
Lot Square Ft. (L50F)
Acres (ACR)
, ( Above Ground, f'inished )
1 I 1 I
,I,.,L,
'Square Ft.Source (SSQF) W
A. Appraiser
a. Public record
C. Owner
O. Measured
E. Acoroximate
f I I I I
r r I I !
u. Under Construction
C. Completed
M. Model
, ",(,',
~
, ',Ci,ci1'>l.
, ,:;h ",
, 'Full Baths (FBA) L:l1J !
Half Baths (HBA) ,eil,:
Other Baths (OBA) L...LJ '
Total Baths (T8A) ,I -, '2,,;
Full Bath Level (FBL),
Half Bath Level (HSL) I
Parking Spaces Covered (CSPC) L...LJ
Number of Fireplaces (F?L)
Warranty ryvAR)
Handicao Modified (HMOQ)
Uncoventd(USPC1L-l-j
iCLJ
y"w
NOW
No~
Y'3$L.j
, ,
Room Name Dimension Level Room Descripti,on (Maximum of 7 codes per Unit)
, 'I ' -' b ,I(.'), ,
Living Room , 11\../1 lL.ff I I ~'i 'I Jr , , , , , A - Fireplace J ' Window Treatment
LIVDM L.IVL L.IVC
3" ,,>;,',.; 1,(),I,3 ~ ,I<;:'r;.,\"..', D B ' Wood/Coal Stove K - Wall to Wall Carpet
Dining Room Ii I I , ,
OINDM OINL DINO C - Skylight L - Bay/Bow Windows
Family Room , , , , , , , , , , w , , , , , , , , D ' Ceiling Fans M - Dining Area
FAMDM FAML FAMO E - Walk,in Closet N - Balcony/Deck
Den , , , , , , , , , , W I , , , , , I , F . Cedar Lined Closet o - I ntenor Balcony
DENOM OENL DENC
Kitchen , i ,3, ; , ~.x 1,1, I,L( ~ tl-\rll , , , , , G - Wood Floor P - Hot Tub/Spa
KITDM KITO H - Ceramic Tile Floor Q - Pantry
Master Bedroom ,t ,C,',<J,:>4I,I'" M~L ,\(:r; , , , , , I ' Vinyl Flooring R - Steam/Sauna
MBAOM MeRC 1 ' Gas Fireplace
Bedroom 1 , i,'," ,~,:I,i ,'2,' ,,,\, & ,<'51 , , , , , 2 . Fireplace Insert
SAlaM eR1L BRiO
Ii I I i I ,"1,,(, L'~' ':{ is- ,<),' * Other Room Names
Bedroom 2 1....1 I , , , , 1 ,
SA2DM aR2L eR20
Bedroom 3 , , , , I I , , w , , , 1 , , , , LIB - Library LOF - Loft
3R3DM BR3L BR30 DEN ' Den FOY - Foyer
Bedroom 4 , i , , , I , , , u , , , , , , , , GRM - Game Room SUN - Sunroom
3A4DM BR41. eR40
PLY , Play Room WRK ' Workshop
OR1*, , , , , , , , , , , , , u , 1 , , , , I , MED - Media Room BED - Bedroom
,
OR1NM QA10M OR1L ORiD
OR2*, , , , , , , , w , , , , , , , , OFC -Office BTH . Bathroom
, , I , , ,
OR2NM QA2DM OR2L OR2D LAW -In-Law Apartment OTH - Other
OR3*, , I , , , , , , , , , , , 01<iL , , , , , , I I, KIT - Kitchen LAU - Laundry
OR3NM OA3DM OR3D
Homeowners' Association (HOA) y"w
Homeowners' Association Fee (HF) , , , ,
Include (M, a, Y) After Fee
NOi.Cj
Association Fee Includes (AFI)
A ~ Insurance E . Pool Service
B - Accounting/Legal F - Grounds
C - Mana~ement G - Pest Control
o - Salalies;PayroU H - Security
Circle all mat apply.
I . Taxes
J . Mobile Home Pafic Fees
Y -Other
I I I
"Tax Amount (TAX)
I I I I I
"Tax Year (TX YEAR)
1~11C:ll-;
'School District (50151) ,(;\. [,7 I -'
x
X
Agent
x
X
Agent
Date
'::-~~~ ~
Property Address:
Acceptable
Financing (AFIN)
~ Conventional
€VA
C. FHA
~
,0. Cast!
E:'Prlllate
F, Assumable
H. Lease Purchase
J. Trad~Exchange
J. Contract
1. Adjustable
2. Sales Agreement
3. Other
Amenities (AMN)
A. Park
B. PlaY!1round
C. Pool
O. TenniS Courts
E. Golf Course
F. ShoppinglMall
G. Healtt'l Club
H. LibraiY
I. Medical Facility
J. PubliC Transportation
K. Gated Community
L Club House
M. Elevator
Y. Other
CNOne
, Appliances (APPL)
'A:':Range
. Countertop Range
C. Wall oven
D. Indoor GriU
~E. Microwave
-;:";. Dishwasher
G. iSpoSal
. ComJ'actor
l. ,Refrigerator
~""'Freezer
~,Ice MaChine
~Washer
M/Dryer
N. Water Softener
Y. Other
Z. None
Basement (BSMl)
A~ Full
. Partial
C. Crawl space
O. Finished
Eo Partially finished
F. Unfinished
H. Interior access
I. Garage access
J. Bulkhead
K. Sump pump
L Dirt floor
.';OOdetel\oor
None
posedlWalkout
erior Access
r~onstruction (CNS)
( A_Jrame
's. Log
C. Block
O. Wood
E. Brick
F. Stone
G. Metal
H. Concrete
Y. Other
1. Modular
2. Masonry
Cooling (COOL)
A.... Heat pump
:".zS. Central Air
-C. Window Units(s)
O. Attic Fan
e. Ceiling Fan
F. Zcned.
G. Wall Unit(s)
Y. Other
Z. None
-~
, ,I )
CIRCLE ALL THA T APPLY.
_ Exterior Feat. (EXTF)
/"
( A. Porch
'-e. Patio
(C. Deck
'---rf.' Balcony
G. GaS/Propane Grill
\oi. \ngrouna Pool
I. Aboveground Pool
J. Hot Tub
K. Sprinkler System
t.. Storage Shed/Out Bldg
M. Barn
N. Landscaped
O. Gazebo
P. Cabana
O. Outside Lighting
Y. Other
t.--Tennis Court
;/ ;.. -Existing Storm Windows
<-(:. Existing Storm Ooors
Fence (FEN)
A. Chain Link
B. Wood
C. Rail
O. Full
e. Partial
F. Privacy
Y. Other
Z. None
Electricity (ELEC)
A.110Volts
,~
i e. 220 Volts
''f:': Fuses
1t":Clrcuit Breakers
~ 60 Amps or less
F. 100 Amps
G. 150 Amps
(60. Amps r Flooring (FlOR)
"--r. Other lA. Wall to Wall Carpet
~ood
Equipment (EapT) ~ParqUel
A. Central Vacuum O. Ceramic Tile
/eCSmoke Detectors / e:-Vinyl
'--e.' 'Nhil1pooUHot Tub 1..,( 'Tile
O. Security System G. Slate
E. Sauna/Steam Room H. Concrete
F. Humidifier I. Plywood
I ~arage Door Opel1er Y. Other
l.w. Intercom
/~ Water ~ilter
-- J:.,. Ceiling Fan
'1<. Attic Fan
L.- Air Filter
M. Ca'c-le Read'j
,/''N.-Cable Available
'yo Other
(1 ~ 'jatemte Dish
--r.- Dehumidifier
Exterior (EXl)
A. Aluminum
B. Asbestos Siding
C. Block
O. Brick
E.. Cedar
F, Wood
G. Hardboard
H. Shakes
41tucco
J./~r.YI '
. Stone
Y. Other
1. Shingle
..RedwOOd
Foundation (FNO)
A. Slab
B. Piling
C. Footing
O. Wood
h Stone
C~, Concrete
G. Metal
H. Brick
I. Slock
J. Masonl'(
y, Other
Heating (HEAT)
A. Heat Pump
d?central Heat
, C;;FOrced Air
. Radiators
E. Wall Unit(s)
F. Baseboards
G. S~ace Heatet(s}
H. Zoned
I. Gravity
WaterlSewer(WTS
a. P!'Tvate Sewer
C. Sewer in Sl:reet
O. Seotic
F. Pl1vate water
G. Welt
H. Retaming Pond
Y.O!t!er
k Water Treatment
, 1-:-P'Johc Sewer
13,/P'JoliC Water
", _Park/Garage (PRKG) '-'
Interior Features (INTF) A. Att
A. Wet Bar -- 8. Oet
B. Walk.ln Closets C. , Car Gar
C. 6eameQ Ceilings :P---C: 2 Car Gar
O. Skylight(S) ',-- E. 3+ Car Gar
E. All Window Treatments F. Off Street
F. Some Window Treatments G. CaJ1:Iart
G. Vaulted Ceilings H. Garage
H. 9 foot+ Ceilings t. RVlSaat Pad
(lYaster Bath J. Integra!
J. Rough-j(l Bath K. Street
K. Walk-up Attic Y. Other
~(L."Gas stove connection Z. None
- . ~ lectric stove connection 1. 3 Car Gar
~ N. Washer connection 2. Pvd Dr
O. Gas dryer connection
P. Electric dryer connection
Q. lcemaker connection
Y. Other
1. Patio Doors
2. Fireplace. Gas
3. Fireplace Insert
4. Stove, Wood/Coal
5. Free Standing
Heating CON11NUEO
J. Radiant
K. Floor heaters
L Geothermal
M. Electric
/'N:- Gas
L..c: Hot Water
P. Oil
Q. Propane
R. Wood
S. Solar
T. Steam
Y. Other
Z. None
1. Coal
~ot Desc (l TOS)
A. Comer
(8;., Wooded
C. Easements
D. Water frontage
E. Golf course frontage
F. Level
6".-SIOPing
H. Additional land available
1. Fiood plain
J. Views
~Zero Lot Line
Ki. Cui de Sac
'1( No Outlet Street
N. Commons
Y. Other
1. Stream
Miscellaneous (MiSe)
S. Fixer Upper
C. Guest House
O. Probate
Other Rooms (OTRM)
A. Great Room
S. Family Room
C. L9ft
O. Library/Study
--
Other Rooms CONT.
E. Offl~Comp~rRoom
F, ReclPlay Room
G Foyer
H. Formal Dining Room
I. Breakfast Nook
J. Pantry
K. Laundry/Utility Room
L Breezeway
M. FloMa Roam
N. Sun Room
O. Worxsnop
P. In-law
Y. Other
Roof (ROOF)
C. Wood Shingles
O. Slate
e. Tile
F. Shake
~ Tar/Gravel
CH)compOSitiOn
I. Rubber
J. Built Up
K. Concrete
I.- Metal
Y. Other
1. ,j),sphaltlFiberglass
" Styie (STYl)
A. Split Level
C. Contemporary
O...-Eancn
('''''""e._TraditiOnal
"---r. Raised Ranch
K. A-Frame
M. Cape Cod
U. Farmnouse
Y. Other
1. ai-Level
.
-"-'~'"-"
"
~
Waterfront ('/'JTFT)
O. LaKe
E:. P-:nd
F. ;::!,i'Jer
G. F,omage
H. VI&N
l. Walk.to
J. Access
K. DockJMooring
1... Beach
Y. Other
Z. None
Zoning (ZON)
A. Agriculture
B. Apartment
C. Commercial
o Office
~eSidential
~~None
G. Other
Farms (FMS)
A. Darry
B. Farmette
C. Grarn
O. Hog
E. Horse
F, Livestock
G. Nursery
H. Orchard
I. Poultry
J. Produce:
K.Ot"er
Outbuildings(OBLO
A. Bank Barn
B. Bleel< Barn
C. Cattle Bam
D. C:ear Span Bam
E. Hog 8am
F. Horse Bam
G. Mil'K Parlour
H. Pole Bam
1. Poultry Bam
J. Com CrtbS
K. Free Stalls
\... Grain Sin
M. Mise. Sheds
N. Silo
O. Other
"Internet y/n
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Designated Agency:
In designated agency. the employing broker may. with your consent. designate one or more licensees from the rea! ~state
company to represent you, Other licensees in the company may represent another party and shall not be provi with any conti,
dential information. The designated agent(s) shall have the duties as listed above under s ~ uyer agency,
In designated agency, the employing broker will be a dual ~ ave the additional duties of:
Taking reasonable care to protect anv - ntlal information disclosed to the licensee.
Taking responsibility to d' supervise the business activities of the licensees who represent the seller and buyer
while taking no' . t at is adverse or detrimental ro ~ither party's interest in the transacTion.
Th eSlgnarion may take place ,l[ the time that the parties enter into a written agreement. but may occur a[ a later time.
Regardless of \vhen the designation takes place. the ~mploying broker is responsible for ensuring that confidential information
is not disclosed,
Transaction Licensee:
A transaction licensee is a broker or salesperson who provides communication or document preparation services or performs
other acts for which a license is required WITHOUT being the agent or adv' andlord or the buyer/
tenant. Upon signing a written agreement or disclosure st ,ansaction licensee has the additional duty of limited confI-
dentiality in that the following informati ot disclosed:
The selIer/landlor' pt a price less than the asking/Iisting price.
, nant will pay a price greater than the price submitted in a written offer.
The sellerllandlord or buyer/tenant will agree to financing terms other than those offered,
Other information deemed contidential by the consumer shall not be provided to the transaction licensee.
OTHER INFORJ\1ATION ABOUT REAL ESTATE TRANSACTIONS
The following are negotiable and shall be addressed in an agreement/disclosure statement with the licensee:
The duration of the employment, listing agreement or contract.
The fees or commissions.
The scope of the activities or practices,
The broker's cooperation with other brokers, including the sharing of fees. ,
Any sales agreement must contain the zoning classification of a property except in cases where the property is zoned solely or primarily
to pertnit single family dwellings.
A Rea! Estate Recovery Fund exists to reimburse any person who has obtained a fmal civil judgment against a Pennsylvania real estate
licensee owing to fraud, misrepresentation, or deceit in a rea! estate transaction and who has been unable to collect the judgment after
exhausting all legal and equitable remedies. For complete details about the Fund, call (71 7) 783,3658.
ACKi'lOWLEDGMENT
I acknowledge that I have received this disclosure.
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Bradley L Griffie, Esquire
Marylou Matas, Esquire
200 North :BaIiOver Street
CarlloIe, PA 17013
(717) 24J-SSSl
1(800)347-SS52
Robin J. Goshorn
Legal Auistal'JI
Reply to: Carlisle
December 6, 2000
38 N_M.alR_
ChambonllarJ. PA 17101
(717) 267-1356
You (717) 2~5063
Hubert X, Gilroy, Esquire
4 North Hanover Street
Carlisle. P." 17013
RE: Yannone v, Yannone
Dear Hubert:
I am in receipt of your correspondence dated December 1, 2000. Valerie agrees [hat after the
holidays, a set custody Order should be agreed upon. As for Christmas this year, Valerie agrees to
Gary having a period of partial custody from 3 :00 p.m. on Christmas day until 3 :00 p.m. on the 26th
At this time, Valerie does not agree to the settlement proposal that has been made, Valerie is
not comfortable with Jeff Kottmeyer merely refinancing the mortgage. Valerie feels that given the
potential sale price and the balance on the mortgage, there will be proceeds fr{)m the sale of the
home, Please list the home for sale under the contract that both parties have already signed.
Valerie would prefer an appraisal of all of the personal property that is in the home. This
includes all of the furnishings, window treatments, decorations, etc. Valerie would prefer that this is
appraised and sold with the proceeds going equally to the parties, This should be done as soon as
possible, Please advise whether your client objects to William Rowe, of Lindon Hall Antiques in
Carlisle. completing this appraisal
Valerie does not agree to the offered amount of child support. As rec,ently as three weeks
ago, Gary's salary was 524,000.00 per year. His current salary appears to be 514,400,00 per year,
Gary's offer of 5250,00 per month does not even cover half of the daycare and insurance expenses,
11'5250,00 per month is Gary's final offer, Valerie will wait until the support hearing,
Because it does not appear that the parties will settle the property disputes quickly. Valerie
would like to bifurcate the matter to finalize the divorce. Considering this, I would appreciate if you
could review your files to determine if you accepted service of the April Divorce Complaint, I will
then forward a Stipulation to Bifurcate for your client to review and sign.
Please advise me of your client's position at your earliest convenience.
Very truly yours,
MlVl/kjl
cc: valerie L. Yannone
Marylou Matas
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GflFFIE & ASSOCIA Tf'i
Attorneys and Counselors At Law
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200 North Ballover Stroot
Carible, PA 17013
(711) 243-5551
1(800)347-5552
Robin J. Goshorn
ugalA.ui3tQnt
Reply to: CaribIe
38 North M.ain Street
Clwnbe"burt. PA 17201
(717) 267-1350
Fu (717) 2-3-5063
January 5, 2001
Hubert X. Gilroy, Esquire
4 North Hanover Street
Carlisle, PA ]7013
RE: Yannone v. Yannone
Dear Hubert:
I have reviewed your January 2,2001, letter with my client. Valerie answers as follows:
1. It is not acceptable for Gary to assume the mortgage on the home and remove
Valerie's name from the Deed without sharing any of the equity in the home with her.
Quite frankly, Valerie questions the likelihood of the bank allowing Gary to assume
the mortgage in his name individua11yconsidering his prior bankruptcy and repeated
delinquent mortgage payments, Furthermore, Valerie finds it hard to believe that Gary
is financially capable of paying a $1,300.00 per month mortgage while at the same
time claiming at the recent support conference that he is earning approximately
$1,200,00 per month gross income.
Valerie previously signed a listing contract that Gary forwarded to her. At this time,
Valerie wants the home listed for sale immediately. It is certainly possible that a sale of
the home will occur far before any foreclosure sale caused by Gary's continued
attempts to avoid his responsibility to pay the mortgage on the home in which he is
living.
If, for some reason, Gary is not satisfied with selling the home now, Valerie only will
entertain a proposal that includes a payment to her which represents a portion of the
equity in the home. The home was purchased in 1998 for approximately $135,000,00,
The balance on the mortgage at this time is approximately $125,000,00. The home
was recently appraised for tax purposes at approximately $165,000,00, Also, Valerie
believes, based upon statements Gary has made, that Gary had the home appraised as
recently as June 2000 for approximftely $180,000.00. Furthermore, Gary attempted
to list the home for sale at $175,000100 Considering all of these figures, it is very likely
that the home could sell for between $]60,000.00 and $170,000,00. Valerie
anticipates an approximate $35,000.00 to $45,000.00 profit from any sale of the home,
If Gary prefers to make the payments to Valerle for approximately half of that amount,
Valerie will not force the sale of the home.
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Additionally, it has come to our attention that the home was recently appraised by
Doug Heineman. I would appreciate it if you would forward a copy of the appraisal
report that he submitted to you.
2. Valerie proposes that Gary retain Anthony's complete bedroom set. Valerie left this
bedroom set in the home so that Anthony would have this available to him. However,
if Gary insist that she take it, she will. As for the rest of the items, Valerie is willing to
accept them.
3. Agreed.
4, Agreed.
5, Agreed.
6. Valerie is not familiar with a three inch skeleton of a reptile. She agrees to search
diligently for it, however, it would be of great assistance if Gary could inform us as to
where this item was kept in the home and where he thinks it may be now.
I look forward to hearing from you.
Very truly yours,
Marylou Matas
MM/kjI
cc: Valerie L. Yannone
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Attorneys and Counsel()fs At Law
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Bradley L Griffie, Esquire
M~Matas, Esquire
200 North Hano.er Street
CarlIoIe, PA 17013
(717) 243-5551
1(800)347-5552
Robin J. Gosborn
Legal Assistant
Reply to: CarilsIe
38 North Main Street
Chambenburr, PA 17201
(717) 267-1356
Fax (717) 243--5063
March 6, 200 I
VIA FACSIM1LE & (J,S, MAIL
Hubert X. Gilroy, Esquire
-1- ~ orth Hanover Street
Carlisle. PA 17013
Fax;o: (717) 2-1-3-8227
RE: Yannone v, Yannone
Dear Hubert:
Valerie agrees to relinquish any interest in the home to Gary. Please urge your client to
do whatever necessary, as quickly as possible, to have her name removed from the mortgage,
Valerie does .not agree to the proposal that Gary gather up items of personal property that
he believes Valerie is requesting. Valerie would prefer to go through the home and collect the
items herself. She would prefer to do it this way because she is not certain of each specific item
and wants to be sure that there is nothing overlooked.
Finally, Valerie does not believe there are any further economic issues that have to be
settled, but she is reviewing her own records at this time, She does inform me that the vehicle in
her possession is titled in her name individually and she is making the payments for that vehicle,
while the vehicles in Gary's possession are titled in his name individually and are paid off. Also.
she believes that any credit card debts have been divided already. She is making substantial
credit card payments and believes that Gary is doing the same. If you have additional
information regarding the parties' tinancial issues and joint obligations that must be determined,
please advise me of that as quickly as possible,
Your attention is appreciated.
Very truly yours,
Marylou Matas
MM,kjl
cc: Valerie L Yannone
EXHIBIT "G"
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VALERIEL. YANNONE,:
Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION - LAW
GARYS. YANNONE,
Defendant
NO. 00-2339 CIVIL TERM
ORDER OF COURT
AND NOW, this 30th day of May, 2001, upon consideration of Plaintiffs Petition
for Special Relief, filed April 27, 2001, and following a conference in chambers in which
Plaintiff was represented by Marylou Matas, Esq" and Defendant was represented by
Hubert X. Gilroy, Esq., and counsel for Defendant having indicated his unavailability for
the hearing scheduled for Friday, June 8, 2001, and both counsel having indicated that if
they are unable to resolve the petition amicably a hearing will be requested, and the court
having indicated that a brief hearing will be promptly scheduled upon request, the hearing
scheduled for Friday, June 8, 2001, is cancelled.
BY THE COURT,
Marylou Matas, Esq.
200 North Hanover Street
Carlisle, PA 17013
Attorney for Plaintiff
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Hubert X. Gilroy, Esq.
4 North Hanover Street
Carlisle, PA 17013
Attorney for Defendant
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VALERIE L. YANNONE, :
Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION - LAW
GARYS. YANNONE,
Defendant
NO. 00-2339 CIVIL TERM
ORDER OF COURT
AND NOW, this 5th day of July, 2001, upon consideration of the attached letter
from Marylou Matas, Esq., attorney for Plaintiff, a hearing is scheduled for Monday,
September 24, 2001, at 1:30 p.m., in Courtroom No.1, Cumberland COlmty Courthouse,
Carlisle, Pennsylvania.
BY THE COURT,
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Marylou Matas, Esq.
200 North Hanover Street
Carlisle, PA 17013
Attorney for Plaintiff
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Hubert X. Gilroy, Esq.
4 North Hanover Street
Carlisle, PA 17013
Attorney for Defendant
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Bradley L. Griffie, Esquire
Marylou Matas, Esquire
200 North Hanover Street
CorlIsIe.PA 17013
(717) 243-5551
1(800)347-5552
Robin J. Goshorn
Legal Assistant
Reply to: CadIsIe
38 Norfh MaIn_
Cham_burg, PA 17201
(717) 267-1350
Fax (717) 243-506J
July 5, 2001
The Honorable J, Welsey Oler, Jr.
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
RE: Yannone v. Yaunone
No. 2000-2339
Dear Judge Oler:
I represent the plaintiff/petitioner, Valerie 1. Yannone, in the above captioned matter.
Hubert X. Gilroy, Esquire, representing the defendant/respondent, Gary Yannone, and I met with
you in chambers several weeks ago to discuss a possible resolution to Ms. Yannone's request for
special relief.
Unfortunately, the matter has not been resolved, despite ongoing attempts to negotiate a
fma1 settlement. Mr. Yannone did sign a listing contract to sell the parties' former marital
residence, as Ms, Yannone had requested in her Petition for Special Relief. He then contacted the
realtor in an attempt to withdraw his consent to the listing of this property. I have confirmed this
with the realtor.
I am sorry to have to take the Court's time for such a matter, but I request that a brief
haring be scheduled to determine those issues raised in Ms. Yannone's Petition for Special
Relief. I anticipate that one half of a day will be sufficient.
Thank you for your attention.
Very truly yours,
3;i~::t.lwo
MM/kjl
cc: Hubert X. Gilroy, Esquire
Valerie 1. Yannone
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Plaintiff
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GARY S. YANNONE,
Defendant
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
NO. 00-2339 CIVIL TERM
ORDER OF COURT
AND NOW, this 12th day of July, 2001, upon consideration ofilie attached letter
from Marylou Matas, Esq., attorney for Plaintiff, ilie hearing previously scheduled for
September 24, 2001, is cancelled.
Marylou Matas, Esq,
200 North Hanover Street
Carlisle, P A 17013
Attorney for Plaintiff
Hubert X. Gilroy, Esq.
4 North Hanover Street
Carlisle, PA 17013
Attorney for Defendant
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GRIFFIE & ASSOCIATES
Attorneys and Counselors At Law
Bradley L. Griffie, Esquire
Marylou Matas, Esquire
200 NOI'th Baoover Street
CarliBIe, PA 17013
(717) 243-5551
1(800)347-5552
Robin J. Goshorn
LegalAaaiatant
Reply to: Carlisle
38 North MaIn Street
Chambersburg, PA 17201
(717) 267-1350
F.. (717) 143-5063
July 11,2001
The Honorable J. Wesley Oler, Jr.
Cumberland County Courthouse
One Courthouse Square
Carlisle, P A 17013
RE: Yannone v. Yannone
No. 00-2339
Dear Judge Oler:
A hearing in the above captioned action is scheduled for Monday, September 24,2001, at
1:30 p.m. The parties to this action have resolved the matter between themselves by signing a
listing contract and a Separation and Property Settlement Agreement. Petitioner, therefore,
withdraws her request for a hearing and asks that the matter be discontinued.
Thank you for your attention.
Very truly yours,
~1r ?Yt.kn
MM/kjl
cc: Valerie 1. Yannone
Hubert X. Gilroy, Esquire
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1 2 2001