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Home My WebLink About00-03287 .. . . . . . ",,-' ,or - J if. ;f.;f. if. if. '" ;t:;ti;F. . . . . iF.:!i:F. :f. :f. ;F.;f. . .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . . STATE OF . . STANLEY R. ROCKEY, . . Plaintiff . VERSUS . . Al1DA R. ROCKEY, . Defendant . . . . . . AND NOW, . PENNA. No. 00-3287 Civil Term DECREE IN DIVORCE :fUJ1<:" \ , 260 IT IS ORDERED AND DECREED THAT Stanley R. Rockey , PLAINTIFF, . . . AND AIda R. Rockey . . . , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. . . . THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED ,OF RECORD IN THIS ACTtON FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . The Property Settlement and Separation Agreement dated May 10, 2001, between the parties hereto is hereby incorporated herein but not merged. . . . . . . . . . "'if. :Ii if. if.:f. if. '" '*' '" '" :f.:f. '" :Ii :f.:f. ~ , , '0'" ,,,,- if. :f.~lf. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . , , , . . . . . , , , . . J. . . . . . . . . . . [. ~ , 7""', ~ .., , " ~, ilL, ~ItJ( (p J ' 01 M~~~a7f.~ ~ ~ -& .a:~ .~~ _1JII!IIl!!II!l _ ~ , ~ ,~_~IIII _ rp_IlIWdIlR~'.~~n _ <. __ _"nrf; -~~~- r \~~ . :~ , , SAlOIS SHUFF, FLOWER & LINDSAY A'ITORNEYS.AT-LAW 26 W. High Street Carlisle, PA , PROPERTY SETTLEMENT AND SEPARATION AGREEMENT THIS AGREEMENT made this /rflaay of ma v ,2001 between Stanley R. f Rockey of Cumberland County, Pennsylvania, hereinafter referred to as Husband, A N D Aida R. Rockey of Cumberland County, Pennsylvania, hereinafter referred to as Wife. RECITALS: R.1: The parties hereto are husband and wife, having been joined in marriage on, June 8,1985 in Harrisburg, Dauphin County, Pennsylvania and R.2: A Complaint for Divorce has been filed in the Court of Common Pleas of Cumberland County, Commonwealth of Pennsylvania, on May 30, 2000, to Number 00- 3287 Civil Term; and R.3: The parties' hereto desire to settle fully and finally their respective financial and property rights and obligations including, but not limited, of all matters between them relating to the ownership of real and personal property, claims for spousal support, alimony, alimony pendente lite, . SAlOIS SHUFF, FLOWER & LINDSAY A'ITORNEYS.AT-LAW 26 W. High Street Carlisle. PA ~'~ NOW THEREFORE, in consideration of the covenants and promises hereinafter to be mutually kept and performed by each party, as well as for other good and valuable consideration and intending to be legally bound, it is agreed as follows: (1) SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place or places as he or she from time to time may choose or deem fit, free from any control, restraint or interference from the other. Neither party will molest the other or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceeding. Each party shall be free of the interference, authority or contact by the other as if he or she was single and unmarried except as maybe necessary to carry out the terms of this agreement. (2) DIVORCE: The parties acknowledge that the marriage is irretrievably broken and that they will secure a mutual consent no-fault divorce decree in the above-captioned divorce action. Upon the execution of this agreement, the parties shall execute and file an Affidavit of Consent and Waiver of Notice Forms, necessary to finalize said divorce. If either party fails or refuses to execute and file the foregoing documents or if Husband fails to finalize the divorce within twenty (20) days after the date he/she makes the monetary payment to husband/wife aforesaid, said failure or refusal shall be considered a material breach of this Agreement and shall entitle the other party at his or her option to terminate this Agreement. (3) REAL PROPERTY: The parties are the owners of certain real estate with improvements thereon erected and known and numbered as 101 Pine Hill Road, Enola, Cumberland County, Pennsylvania. 2 SAlOIS SHUFF, FLOWER & LINDSAY AtTORNEYS-AT'LAW 26 W. High Street Carlisle. PA .- Wife agrees at the time of the execution of this Agreement to convey the real estate with improvements thereon erected at 101 Pine Hill Road, Enola, Cumberland County" Pennsylvania to Husband by special warranty deed. Said deed shall be held in escrow until such time as the affidavits of consent have been executed and filed and the property refinanced as set out below. Husband shall pay for all household expenses including, but not limited to, mortgages and liens of record, utility bills, insurance and real estate taxes in connection with said property. With regard to all such expenses, Husband hereby shall hold Wife harmless and indemnify Wife from any loss thereon. Husband shall refinance said mortgage obligation within 45 days of the date of this agreement at which time the escrow deed shall be released to him. At the time of the refinance, Husband shall pay to Wife the sum of $40,000.00, which shall represent her equity in marital property. (4) DEBT: MARTIAL DEBT: A. Husband and Wife acknowledge and agree that there are no other outstanding debts and obligations which are martial or for which the other might be liable incurred prior to the signing of this Agreement. B: Post Separation Debt: In the event that either party contracted or incurred any debt since the date of separation on December 27, 1997 the party who incurred said debt shall be responsible for the payment thereof regardless of the name in which the debt may have been incurred. 3 . . SAlOIS SHUFF, FLOWER & LINDSAY ATI'ORNEYS-AT'LAW 26 W. High Street Carlisle. PA .- 1;;" C: Future Debt: From the date of this agreement neither party shall contract or incur any debt or liability for which the other party or his or her property or estate might be responsible and shall indemnify and save the other party harmless from any and all claims or demands made against him or her by reason of debts or obligations incurred by the other party. (5) MOTOR VEHICLES: Each party relinquishes any right, title and interest he or she may have to any and all motor vehicles currently in possession of the other party. Within 30 days of the date of this agreement each party shall execute any documents necessary to have said vehicles properly registered in the other party's name with the Pennsylvania Department of Transportation. Each party shall assume full responsibility of any encumbrance on the motor vehicle received by said party, and shall hold harmless and indemnify the other party from any loss thereon. (6) TANGIBLE PERSONAL PROPERTY: The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, tools and other household personal property between them, and they mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such property presently in his or her possession whether said property was heretofore owned jointly or individually by the parties hereto. This agreement shall have the effect of an assignment or bill of sale from each party to the other for such property as may be in the individual possession of each of the parties hereto. (7) INTANGIBLE PERSONAL PROPERTY: Each party hereby relinquishes any right, title or interest he or she may have in or to any intangible personal property 4 SAlOIS SHUFF, FLOWER & LINDSAY AlTORNEYS'AT'LAW 26 W. High Street Carlisle, PA currently titled in the name of or in the possession of the other party, including, but not limited to, stocks, bonds, insurance, bank accounts, individual retirement accounts, employment benefits including retirement accounts, savings plans, pension plans, stock plans, 401K plans and the like, specifically Husband's pension in IBM savings plan. the IRA held by Husband at Americhoice Federal Credit Union, and Wife's pension with the Commonwealth. (8) ALIMONY: WAIVER OF ALIMONY: The parties acknowledge that each has income and assets satisfactory to his and her own reasonable needs. Each party waives any claim he or she may have one against the other for alimony, spousal support or alimony and alimony pendente lite. (9) ADVICE OF COUNSEL: The parties hereto acknowledge that each has been notified of his or her right to consult with counsel of his or her choice, and have been provided a copy of this agreement with which to consult with counsel, Husband is represented by Johnna J. Kopecky, Esquire, and Wife is represented by Andrew Norfleet, Esquire, and has been advised that he or she may be represented by counsel of choice. Each party acknowledges and accepts that this agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge as each has sought from counsel, and the execution of this agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal agreement or agreements. Each party shall pay his or her own attorney for all legal services rendered or to be rendered on his or her behalf. 5 SAlOIS SHUFF, FLOWER & LINDSAY ATIURNEYS'AT-LAW 26 W. High Street Carlisle. PA .,- ,~ , (10) ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. (11) BANKRUPTCY: The parties hereby agree that the provisions of this Agreement shall not be dischargeable in Bankruptcy and expressly agree to reaffirm any and all obligations contained herein. In the event a party files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party shall have the right to declare this Agreement to be null and void and to terminate this Agreement in which event the division of the parties' martial assets and all other rights determined by this Agreement including alimony shall be subject to court determination the same as if this Agreement had never been entered into. (12) COMPLETE DISCLOSURE: The parties do hereby warrant, represent, acknowledge and agree that each is fully and completely informed of, and is familiar with, the wealth, real and personal property, estate and assets, earnings and income of the other and has made any inquiry he or she desires into the income or estate of the other and received any such information requested. Each has made a full and complete disclosure to the other of his and her entire assets, liabilities, income and expenses and any further enumeration or statement thereof in this Agreement is specifically waived. (13) RIGHTS AND RESPONSIBILITIES: Husband and Wife acknowledge that each of them has read and understand his and her rights and responsibilities under this Agreement and that they have executed this Agreement under no compulsion to do so but as a voluntary act. 6 . . SAlOIS SHUFF, FLOWER & LINDSAY ATI'ORNEYS-AT'LAW 26 W. High Street Carlisle, PA . ~ ," ~< (14) FULL SETTLEMENT: Except as herein otherwise provided, each party hereby releases the other from any and all claims, or demands up to the date of execution hereof. It is further specifically understood and agreed by and between the parties hereto that each party accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all of said party's rights against the other for past, present and future claims on account of support, maintenance, alimony, alimony pendente lite, counsel fees, costs and expenses, equitable distribution of marital property and any other claims of the party, including all claims which have been raised or may be raised in an action for divorce. (15) RELEASE OF ALL CLAIMS: Except as may be otherwise specifically provided in this Agreernent, Husband and Wife, for themselves, their heirs, representatives and assigns, each hereby forever releases, remises, discharges and quitclaims the other, and such other's heirs, representatives, assigns and estate, from and with respect to the following: A All liability, claims, causes of action, damages, costs, contributions and expenses or demands whatsoever in law or in equity; B. All rights, title, interest or claims in or to any property of the other, whether real, personal or mixed and whether now owned or hereafter acquired; C. All rights of curtesy and dower and all claims or rights in the nature of curtesy and dower; D. All widow or widower's rights; E. All right, title, interest or claim in or to the other's estate, whether now owned or hereafter acquired, including but not limited to all rights or claims: 7 II SAlOIS SHUFF, FLOWER & LINDSAY ATI'ORNEYS.AT.LAW 26 W. High Street Carlisle, PA ~-;,-, (1) to take against the other's will; (2) under the laws of intestacy; (3) to a family exemption or similar allowance; and (4) all other rights or authority to participate or intervene in a deceased spouse's estate in any way, whether arising under the laws of Pennsylvania or any other country, territory, state or political subdivision. F. All rights or claims to any accounting; G, All rights, claims, demands, liabilities and obligations arising out of or in connection with the marital relationship or the joint ownership of property, whether real, personal or mixed; H, All rights, claims, demands, liabilities and obligations arising under the provisions of the Pennsylvania Divorce Code, as the same may be amended from time to time, and under the provisions of any similar statute enacted by any other country, state, territory or political subdivision; I. All rights, claims, demands, liabilities and obligations each party now has, or may hereafter have, against or with respect to the other. (16) GOVERNING LAW: This Agreement shall be construed under the law of the Commonwealth of Pennsylvania. If any provision of this Agreement is determined to be invalid or unenforceable, all other provisions shall continue in full force and effect. (17) INCORPORATION INTO DECREE: In the event that either of the parties shall recover a final judgment or decree of absolute divorce against the other in a court of competent jurisdiction, the provisions of this Agreement may be incorporated by 8 Ii Ii . " SAlOIS SHUFF, FLOWER & LINDSAY AlTORNEYS.AT-UW 26 W. High Street Carlisle. PA .- c -~,,': ....~;, reference or in substance but shall not be merged into such judgment or decree and this Agreement shall survive any such final judgment or decree of absolute divorce and shall be entirely independent thereof. (18) BREACH: In the event that either party breaches any provision of this Agreement, he or she shall be responsible for any and all costs incurred to enforce the Agreement, including, but not limited to, court cost and counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election; to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. (19) ENTIRE UNDERSTANDING: This Agreement constitutes the entire understanding between the parties and there are no covenants, conditions, representations, or agreements, oral or written, of any nature whatsoever, other than those herein contained. (20) AGREEMENT BINDING ON PARTIES AND HEIRS: This Agreement shall bind the parties hereto, their respective heirs, executors and assigns. IN WITNESS WHEREOF, the parties hereto intending to be legally bound have ds and seals the day and year first written above. !?a~o~ J( ~ Ov>> ~. ~~ Aida R. Rockey 9 .'..'. ,. '" ~n']dui~.-"-.cilll~ fIWl~~lllUltllii.i:Ujj~~'..'.'--'O"\ -~ ......,;~ u._ ,. - ~I .'1 , ',. () =\ (~ :::-:;e -; r]"'; i-- .. ~ .,-;/ r".,) 2J::! u r":: v,.() '~- - "~'. L: '>~ . , '-..- ~ ~"...; ,-.f.' -j , D -] -< ~ " SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS'AT'LAW 26 W. High Street Carlisle, P A " STANLEY R. ROCKEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. ALDA R, ROCKEY, Defendant NO. 00-3287 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 Section 3301(c) of the Divorce Code, 2. Date and manner of service of the Complaint: Certified mail, return receipt requested attached hereto as Exhibit "A", postage prepaid, 3, (a) Date of execution of the Affidavit of Consent required by Section 330l(c) of the Divorce Code: By the Plaintiff: May 10, 2001 By Defendant: May 10, 2001 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 the Record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in ~ 3301(c) divorce was filed with the Prothonotary: May ~, 2001 Date Defendant's Waiver of Notice in ~ 3301(c) divorce was filed with the Prothonotary: May ~, 2001 Date: III - ..... ~ ~--..- ~:I .""",,,,,,_~...u-."""1lIl - Z 332 1'147 1'183 us Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Do not use for International Mail See reverse Se~'l.da R',:?-,Rockey Street & Number " P<><l! ce.$lal., t:noJ.a, ~od~ 7025 $ ,5-- Postage Certified Fee Special Delivery Fee .~ -3 1i Gl 1! ~ l! 'Gl ,:.1: ,i ~~&~Q!S 1 81idlQr 2 ,f9_r~ddittQliial u.Niees. I also wish to receive the JllComJ)iete-itliims,.3; 48:. and At).. foDowing services (for an .Print your ilama~,!)_~ address on the reverse ofthis'form 80 that we can return this extra fee): card to you. ' -Attach this form to the front of the mailpiece, or on the back if space does not 1. 0 Addressee's Address permit. ~ -Write"Retum Recsipt Requested" on the mailpiece below the article number. 2. Restricted Delivery .The,Retum Receipt will show to whom the article was delivered and the date delivered. Con ult postmaster for fee. .., 3. Article Addressed to: 40. Miele Number ~ ; 5 g, E o u l:l w a: c c c z a: ::I Iii AIda R. Rockey 101 Pine Hill Road Enola, PA 17025 4b.';ervice Type o Registered ~ Certified o Express Mail ~sured , 0 Return Receipt for Merohandlse 0 COD 7. Date of Delivery , 5. Received By: (Print Name) 8. Addressee's Address (Only If requested and fee is paid) !5 6. Signatu 2. Xl:: ,!II ! P;~Ip'orin DiJmfiill6fteturAl'Ieceipt f~ \r\'~ D\-\- ')1" ~~~...... " !i 'e Gl, rn 'S.i "3 : Gl' a: ". ~ , :0. ~ Gl' a:' l!' ";;: :0 ~ . o - . 5: >0' ",' ". IV J: I- ~~l:i;,;lIl!&cl.i"'i~,,~_d&"~",-"":1S~iilM! ~ - ." -- " .... "''',",ij;.~~'''~~",'''-'''. r'" ,j ; , ......;~, -~lIiDr T. ~_.. ,~ fliilH'f o c ~ Ur_;~ ~fn ?r--- 0~~~ r;':::;~ "'-I......~ )-';-:-r. 7,." 59 ,.- :z --i -< j'glIJ' ,~....... ~:;, c' ~~::;; ~-< f'-.cJ eJ") -~:: -~ ~~~' ::..J ,'-> (:J , ~- :.c ~~rn '::,.-::-.: ~ ~ SAlOIS, SHUFF & MASLAND ATrORNEYS-AT-LAW 26 W. High Street Carlisle, PA , I , ~ , ." '~J'; STANLEY R. ROCKEY, Plaintiff :IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO, ro -3.)<67 CIVIL TERM ALDA R. ROCKEY, Defendant IN DIVORCE NOTICE 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 ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Street, Carlisle. 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. I YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU I 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, I II II II II Ii Ii Ii I Cumberland County Bar 2 Liberty Avenue Carlisle, PA 17013 (717) 249- Association obert~~C. Saidis, Esq, Attorney for. Plaintiff il SAlOIS, SHUFF & MASLAND A'ITORl\JF..YStoATeLAW 26 W. High Street Catlisle, PA . -, -" . - -~ _ ~ c; , .,' ~ .. _" - .., :i".".-' -:J}~-'-""~-'-'-'''''''< STANLEY R, ROCKEY, Plaintiff :IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 0-0..3 ;J f7 CIVIL TERM ALDA R. ROCKEY, Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(dl OF THE DIVORCE CODE 1. Plaintiff is Stanley R. Rockey, who currently resides atl0l pine Hill Road, Enola, Cumberland County, Pennsylvania 17025. 2. Defendant is Alda R. Rockey, who currently resides at 101 pine Hill Road, Enola, Cumberland County, pennsylvania 17025. . 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for 'at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 6, 1985 in Harrisburg, Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties, 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Having been so advised Plaintiff does not desire the Court to order counseling. 7. The marriage is irretrievably broken. it II II II II ;11 'L., SAlOIS, SHUFF & MASLAND ATI'ORNEYS.ATlLAW 26 w. High Street Carlisle. PA , . - '" :.- .O"'''''-'''-:'''~"'''__''_<_,i~_, WHEREFORE, Plaintiff prays Your Honorable Court to enter a decree of divorce. ~obert C, Saidis, Esq. ~ttorney for Plaintiff I II ~, SAID IS, SHUFF & MASLAND ATrORNEYSIATlLAW 26 W. High Street Carlisle, PA DATED: COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND :SS ,_;"....:_" ','e",,,_',-, ,_ _,-,'c_' I verify that the statements made in this Complaint 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. 5-jr:t - Do Stanley 'I ~-'fi,"I1Ii"""" ': ........~ .-~o,....tl !lII!IlIMilhmI!!I~_ "<""llIiIlIill" '-' ",' ~ ..; ~, " \~ ~ &, ~ ~ '" \$ ..........L-J.Ili " ~ fA \~ \ , ~ , .'~ ....... V\ ;v , 1 '" ~ ,\ \~ , . ~ g ;:!.l.~ ZrTl Z;;!2 ~~ 1<:0 jQ ~ (:E CD,. ~ 0:- <0 , I o C> ::t: - -< W (:) ~~ :'lJ hi::!J r L!Cq :i] ~.? C?o __j1-. -.... --M o~ ~.C) '..;...Im ~ -< ... SAlOIS SlllJfti.~WER &Lll~USAY """""""'- :l/iW.BlghS_ Carllsle, PA ..,c ""c STANLEY R. ROCKEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. ALDA R. ROCKEY, Defendant : NO, 00-3287 CIVIL TERM : IN DIVORCE PETITION FOR EQUITABLE DISTRIBUTION AND NOW comes the Petitioner, Stanley R. Rockey, by and through his attorneys, Saidis, Shuff, Flower & Lindsay, and hereby files the following Motion: 1. A Divorce Complaint was filed to the above term and number on May 30, 2000. 2. There remains certain property, real and personal, which need to be divided. WHEREFORE, the Petitioner respectfully requests Your Honorable Court to enter an Order awarding equitable distribution pursuant to the Divorce Code. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Yho./lC/I... :t, ;;l.O{) J BY: Jo ~, , SAlOIS SHllffi.!!OWER &LlNuSAY AImIINEYlMToJAW 26 W. High Street ClUtisJe, PA -,-"~ .- ~! CERTIFICATE OF SERVICE 5-H;;;y of ~ (Jvl ~ ) - - On this , 2001, I, hereby certify that I served a true and correct copy of the foregoing Petition for Equitable Distribution on the following persons via United States Mail, postage prepaid, addressed as follows: Andy Norfleet, Esquire 3211 North Front Street P,O, Box 5300 Harrisburg, PA 17110 Attorney for Defendant Ii SAIDIS, SHUFF, FLOWER & LINDSAY By: ,. .. ,,' liliaI' '.,~.h'" '+h', ,', "'" .. >",;., , ~'- """, .','1-,",0, , , {, , , \ , .... ~ ~ ~ 0 ,~ \..~".. (:: Ci\ -~ ;:-)(.:. ; ~![~-=: ,., & :-J ii.s~-~ ! 0- 0 b c~ ,,-; -<: "',,-' r-', . ~ ~r'- '-.' ~ ~ )3;,--. =;;:~ V ;E~~ ~ pt: ~-"- J - r-- 2: --..... -.-/ :".) ~ -< ( ,. SAlOIS SHUFF, FLOWER & LINDSAY AlTORNEYS-AT-LAW 26 W. High Street Carlisle, PA u___ - . . . STANLEY R, ROCKEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, ALDA R, ROCKEY, Defendant NO. 00-3287 CIVIL TERM IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREEE UNDER SECTION 3301(0) OF THE DIVORCE CODE 1, A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on May 30, 2000 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint, 3. I consent to the entry of a final decree 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. Section 4904 relating to unsworn falsification to authorities, DATED: /heMj /0, ~()O/. b+~~t R ~~ Stanley R, Rockey Plaintiff it ,0., ..j..' ~_~;"""'_'_''':_"'''j;''~'-'_k_,.,;;._'"" ,.-" -~ ~--.>' '~~-' ,~ ,- ' '1lIid,' ., " ,~ "'-:i:li.:ii.:t8fi .~;. '~"lliII'-' "~A>~~1lW. ~iIll ~. ,.,..u. C) uf~ nlr,-., z- -7('''' Cr}'< -<,. '--1'- :,....- "_. ~f:) -i -< , . ',~~ '--' () .. 1~:: f';..) en -'C1 ,,') <0 l_-' "71 =< li:.b.t SAlOIS SHUFF, FLOWER & LINDSAY AlTORNEYS-AT-LAW 26 W. High Street Carlisle. PA . . t ~. ~,! i I . . STANLEY R. ROCKEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, ALDA R, ROCKEY, Defendant NO. 00-3287 CIVIL TERM IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREEE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on May 30, 2000. 2. Defendant acknowledges and accepts service of the Complaint on June 22, 2000, 3, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4, I consent to the entry of a final decree of divorce without notice, 5, I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted, 6. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary, 7. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling, I do not request that the court require counseling. 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, Section 4904 relating to unsworn falsification to authorities. DATED: ~~~ ( , !ljd!J- 'f(. ~. Alda R. Rockey Defendant mllliWilll' ., ,.,,~" '"'~' . , ~Ia-~ - "~_.,_.~- ~, '.. ~ ~ ."<n' ~ _,,' ,? J,JIiiia'll.Qiil/Illl . ~ .., o ~; ~~; -<".::-- ;:: l.:) ~~~~ ~( -7 :::l -< r'-' ~ ~::.~" .< i'-) U: ""'1:] S'? ~; -< \0 ~ ~" ~~-~- " --"" _0- ....,.1 ~...w..~_~. ~~~ """""~7'""'~'~""" J'~Jlll<!\\lil&w._,j STANLEY R. ROCK;EY : IN THE COURT OF COMMON PLEAS OF CUMBE.RLAND COUNTY. PENNSYLVANIA Plaintiff : CIVIL ACTION - LAW VS. NO. 00 - 3287 CIVIL 19 ALDA R. ROCKEY IN DIVORCE Defendant STATUS SHEET DATE: , ~ -~ -.\'" Ii; STANLEY R, ROCKEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, NO, 00 - 3287 CIVIL ALDA R. ROCKEY, Defendant IN DIVORCE TO: Johnna J, Kopecky Attorney for Plaintiff Andy Norfleet Attorney for Defendant DATE: Wednesday, March 14, 2001 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed, OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions, (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery, ~~I . I i , , I I I I I , , - DATE COUNSEL FOR PLAINTIFF COUNSEL FOR DEFENDANT NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION, AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION, HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY, THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT, IN THE COURT OF CO~lMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jf':€:, (:,;' /~~., STANLEY R. ROCKEY, Plaintiff vs. ALDA R. ROCKEY, Defendant NO. 00-3287 19 Stanlev R. Rockey a master yith respect to the ( ) Divorce ( ) Annulment ( ) Alimony ( ) Alimony Pendente MOTION FOR APPOIN'rMtNT OF MASTER (Plaintiff) ~lltt~, following claims: moves the court to appoint Lite (x ) ( ) ( ) ( ) Distribution of Property Support Counsel Fees Costs and ~~penses and in support of the motion states: (1) . Discovery is complete as to the claims(s) for which the appointment of a master is requested. (2) The defendant (has) (kK2~) appeared in (by his attorney, Andv Norfleet. Esquire (3) The stat~rory ground(s) for divorce (is) irretrievable breakdown (4) Delete the inapplicable paragraph(s): (a) The action is no~ contested. (b) An agreement has been reached with respect to the the action ~ftlly) ,Esquire). (are) 3301 ( c) following claims: none (c) The action is contested with respect to the following claims: equitable distribution (5) The action (involves) (does not involve) complex issues of law or fact. Date: to take 4 (hours) if any. relevant to the motion: .,,,~~ ' (JDli1ti ORDER APPOINTING MASTER , AND NOW 7n~ !;;-" ,~.:lO{)/, ~ ~ ~M , is appointed master w1~~~espect to th~~Wing claims: ~ ~C 0 \ By the Court: ~ ~-~~~ (6) (7) The hearing is expected Additional information, none (xlJqts) . 3/5/01 Esquire, I.J CUMBERLAND 44 1-'-,._ '.0 >- ("'-- r~" 3;% '-..} ~-:::, .;--=1 ~- ~ Eo .,Z h~j& .::.~~ --, D '-', .;,,- ':..~ '- ~ ,~~ - -"~ ,!I" n/;f-iY "_! r1;,~ ~ -.:; . ;. 'I' CUJ\<2~~.i::,}_:'''' i~:'CUNrv' J""'-N!\I\2;\{'l\f/'.r:',', I _I ,,"\,~ L,:,"",:\;i/"\ "w, "v. ';Q .,~ ", ','~ ,_o>-!" ..~t<';;,."~-"~'"--";b,.(""~"" <Ii..1",'""':~" ." ',~." ,_~ ,~~!!ll'l~~~~~",~~~~","~~~~~l'!i'L"'jliF#i"!f''B';;;'1i',W,)j;!'<;~\j~~~. ~, . " , ,;;. ;- ,^,.~...I-- -" ",-",.-. ",i.." - i'," .;--_~", "","\'-;"<\. ~"~." ~h ~ "[ STANLEY R, ROCKEY, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-32SiCIVIL TERM ALDA R. ROCKEY, Defendant IN DIVORCE AFFIDAVIT I, Stanley R. Rockey, being duly sworn according to law, depose and say: (1) I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling, (2) I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request, 3) Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court, 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. ~7ho , s~f::hcE~R~ SAlOIS, SHUFF & MASLAND D ted: ATIORNEYS'AT'LAW 26 W. High Street Carlisle, PA II .;," - ...........QilUWil:l~~l!IIlI~_~~~,mlj~:Mt1,Wdt-JiJj~jll"I,!;~li!Oi,lffii,j'!jli!'li!>;L1!i~ .- ~.~ . -~~. .- ~WitWlll\i.l!!;Ili8lIlI::m~ RECEIVED HAY 3 0 2000 '"= . ~"~" ~~.-,-~.->.}\.-~.-" ","..~ .c... .,~, 8 0 ~ 0 ':"C).$: L. "--! !e.ffJ c= LT' Z .'i1 ::n ~S;; I ~ ',.-n1 ~e ;tJ6 ?lo :r. '7tL,.. :::: ?.:>::D >8 - .,. () - ~fI'l ~ " j .. 0 , -< E ~ I ..- , ~~ ~-, ,',. JAMES D. FLOWER JOHN E. SLIKE ROBERT C. SAlDlS GEOFFREY S. SHUFF JAMES D. FLOWER, jR. CAROLj. LINDSAY jOHNNA j. KOPECKY KARL M. LEDEBOHM JOSEPH 1. HITCHINGS THOMAS E. FLOWER LAWOFFlCFS SAIDIS, SHUFF, FLOWER & LINDSAY A PROFESSIONAL CORPORATION 26 WEST HIGH STREET CARLISLE, PENNSYL VANIA 17013 TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486 EMAIL: atlorney@ssfl-law.com www.ssfl-Iaw.com WEST SHORE OFFICE: 2109 MARKET STREET CAMP HILL, P A 17011 TELEPHONE: (717)737-3405 FACSIMILE: (717)737-3407 REPLY TO CARLISLE March 15, 2001 Robert Elicker Divorce Master Domestic Relations Office 13 North Hanover Street Carlisle, PA 17013 Re: Stanley Rockey v. AIda Rockey No,: 00-3297 civil Dear Mr, Elicker: Enclosed please find Certification that discovery has been completed and this can be listed immediately for a Master's Pre-Hearing Conference. Sincerely, OWE?~SAY ;~ - JJK:tdm Enclosure Cc: Stanley Rockey Andy Norfleet, Esquire - c, ,~ ~- - ""\if, "'. - ... - STANLEY R. ROCKEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO, 00 - 3287 CIVIL ALDA R, ROCKEY, Defendant IN DIVORCE TO: Johnna J, Kopecky Attorney for Plaintiff Andy Norfleet Attorney for Defendant DATE: Wednesday, March 14, 2001 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed, OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions, - - , '-" '0 (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery, 7ha/'lcA I if, ;)C(j I DATE co CO NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION, AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION, HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY Ta~T DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY, THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT, 'c.'" ". "'''.$ ~'ii;~' ^,-- <<-~ - ~.. , -' . -"~' ~.->'.....~' '-'-, ~lOj~l_lidilUtit~ '".~~~ 12ilIi'"- '~, -" MAR 1'1 20m '" -". ~ ,-; .'k! JAMES D. FLOWER JOHN E. SLIKE ROBERT C. SAIDIS GEOFFREY S. SHUFF JAMES D. FLOWER, jR. CAROLj. LINDSAY jOHNNA j. KOPECKY KARL M. LEDEBOHM JOSEPH L. HITCHINGS THOMAS E. FLOWER LAW OFFICES SAIDIS, SHUFF, FLOWER & LINDSAY A PROFESSIONAL CORPORATION 26 WEST HIGH STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486 EMAIL: attorney@ssfl-Iaw.com www.ssfl-law.com WEST SHORE OFFICE: 2109 MARKET STREET CAMP HILL, P A 17011 TELEPHONE: (717)737-3405 FACSIMILE: (717)737-3407 REPLY TO CARLISLE March 27, 2001 Robert Elicker Divorce Master Domestic Relations Office 13 North Hanover Street Carlisle, PA 17013 Re: Stanley Rockey v. AIda Rockey No,: 00-3297 civil Dear Mr. Elicker: Enclosed please find a clocked-in copy of the Income and Expense Statement regarding the Plaintiff in the above- captioned matter, Sincerely, JJK:tdm Enclosure Cc: Stanley Rockey (w/encl Andy Norfleet, Esquire (w/encl "" ~. ...- .-. , c . IN THE COURT OF CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION 'CARLISLE, PA 17013 PHONE: (717) 240'6225 FAX: (717)240-6248 March 27, 2001 Plaintiff Name: Stanley Rockey Defendant Name: Aida Rockey Docket Number: 00-3287 PACSES Case Number: Other ID Number: Please Note: All correspondence must include the PACSES Case Number INCOME AND ExPENSE STATEMENT 2 C> 9, <' :1: THIS FORM MUST BE FILLED OUT lti ff::o f'J ~/(:: ~,) ,,-,::::,.11 (IF YOU ARE SELF-EMPLOYED OR IF YOU ARE SALARIED BY A BUSINESS OF WHICH YOU ARE OWNER IN WHOLE OR PART, ~f{;}AUSr\.ii;SO Fi~~ tibT THE SUPPLEMENTAL INCOME STATEMENT WHICH APPEARS ON THE LAST PAGE OF THIS INCOME AND EXPENSE STATEMENT.) '< c -nj.! ~ INCOME STATEMENT OF, STANLEY ROCKEY ~2 :~ ~~ I VERIFY THAT TaE STATEMENTS MADE IN THIS INCOME AND EXPENSE STATEMENT ARE TRUE AND CORRECT. I ~ERffi.w:o ~T FALSE STATEMENTS HEREIN ARE SUBJECT TO THE CRIMINAL PENALTIES OF 18 PA. C. S. 54904, RELATING TO UNSWORN FALSIFICATION TO AUTHORITY. ./I11<Ar 1- ::2 " , , ::Zoo ~t-~OI)<' ~Gl~M PLAINTIFF l DATE INCOME: EMPLOYER : RETIRED ADDRESS: TYPE OF WORK: PAYROLL NO. GROSS PAY PER PAY PERIOD $ 51.631.50 (WKLY, BI-WKLY., ETC.) MONTHLY ITEMIZED PA YROLL DEDUCTIONS FEDERAL WITHHOLDING 186.73 SOCIAL SECURITY LoCAL WAGE TAX 16.32 STATE INCOME TAX 45.69 RETIREMENT SAVINGS BONDS CRED!.T UNION LIFE INSURANCE HEALTH INSURANCE OTHER DEDUCTIONS UNION DUES OPTI-WAGE TAX (SPECIFY) TOTALS NET PAY PER PAY PERIOD $ $1.382.76 Service Type Page 1 of6 Form IN - 008 Worker ID -- ~. ~ .' ~ ".-.. to' Income and Expense Statement PACSES Case Number: Other (Fill in Appropriate ColUllltl) Income WEEK MONTH YEAR INTEREST Dividends $20.00 $80,00 quarterly Pension Annuity Social Security Rents Royalties Expense Account Gifts Unemployment Camp. Workmen's Compensation IRS Refund Other Other TOTAL INCOME EXPENSES (Fill in Appropriate ColUllltl) WEEK MONTH YEAR HOME Mortgage/Rent 451.38 Maintenance 15.10 Utilities Electric 72.09 Gas 72.66 Oil Same Telephone 48,45 Cellular phone 24,04 Service Type Page 2 of 6 Form IN - 008 Worker ID , ,'",-".~-,. ~, Income and Expense Statement PACSES Case Number: EXPENSES ( Fill in Appropriate Column) continued WEEK MONTH YEAR Water . Sewer EMPLOYMENT Public Transportation Lunch . TAXES Real Estate Personal Property Income INSURANCE Homeowners Automobile 39.61 Life 110.00 Accident Health Other AUTOMOBILE Payments Fuel 100.00 Repairs 60.35 MEDICAL Doctor 80.00 Dentist Orthodontist Service Type Page 3 of6 Form IN - 008 Worker ID ~.. ~ Income and Expense Statement PACSES Case Number: EXPENSES (Fill in Appropriate Column) continued WEEK MONTH YEAR Hospital Medicine Special Needs (glasses, braces I orthopedic devices) EDUCATION Private School Parochial School College . Religious PERSONAL Clothing/Laundry 80.00 Food 120.00 Sarber/Hairdresser Credit payments: Credit Card Charge Account Memberships LOANS Credit Union MISCELLANEOUS Household help Child Care Papers/Books/Magazine s Entertainment Pay TV 29.00 Vacation Service Type Page 4 of 6 Form IN - 008 Worker ID .,.~'" , .[ "';" " i:: I"~ Income and Expense Statement PACSES Case Number, !.; (I i' !'-I k EXPENSES (Fill in Appropriate Column) Continued WEEK MONTH YEAR Gifts Legal Fees 100.00 Charitable Contributions 275.00 Other: Alimony Payments OTHER: Total Expenses 1677 . 68 [,:: '-I i eO! l:i , F: :j i'i I" , '-" j" \: i' c: :1 ',j " ;"1 ~'! ., :i ~ ! [.; 1"1 " ,. ;i I.! Property Ownership * Owned Description Value H W J Checking Account(s) Savings Account(s) Credit Union Nominal Nominal Stocks/Bonds 150 shares IBM stock X Real Estate 101 Pine Hill Road X Other - IRA 11,000.00 X Total Ii I: I:! I"~ ::- " 1'1 \: Insurance Company . Coverage * Policy # H W J Hospital, Medical: ! Service Type Page 5 of6 Form IN - 008 Worker ID . .--~ , Income and Expense Statement PACSES Case Number: Insurance Company Coverage * Policy # H W J Health/Accident Disability Income Dental . Other: *H-Husband W-W/fe J-Joint SUPPLEMENTAL INCOME STA TEMENT ,. A. THIS FORM IS TO BE FILLED OUT BY A PERSON: 1. WHO OPERATES A BUSINESS OR PRACTICES A PROFESSION, OR 2. WHO IS A MEMBER OF A PARTNERSHIP OR JOINT VENTURE, OR 3. WHO IS A SHAREHOLDER IN AND IS SALARIED BY A CLOSED CORPORATION OR SIMILAR ENTITY. B. ATTACH TO THIS STATEMENT A COpy OF THE FOLLOWING DOCUMENTS RELATING TO THE PARTNERSHIP, JOINT VENTURE, BUSINESS, PROFESSION, CORPORATION OR SIMILAR ENTITY: 1. THE MOST RECENT FEDERAL INCOME TAX RETURN, AND 2. THE MOST RECENT PROFIT AND Loss STATEMENT C. NAME OF BUSINESS: ADDRESS AND TELEPHONE # OF BUSINESS D. NATURE OF BUSINESS (CHECK ONE) (1) PARTNERSHIP (2) JOINT VENTURE (3) PROFESSION (4) CLOSED CORPORATION (5) OTHER E. NAME OF ACCOUNTANT, CONTROLLER OR OTHER PERSON IN CHARGE OF FINANCIAL RECORDS: F. ANNUAL INCOME FROM BUSINESS: 1. How OFTEN IS INCOME RECEIVED? 2. GROSS INCOME PER PAY PERIOD? 3. NET INCOME PER PAY PERIOD? 4. SPECIFIED DEDUCTIONS, IF ANY: Service Type Page 6 of6 Form IN - 008 Worker ID , ~ " "~~ ',::,. IN THE COURT OF CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION 'CARLISLE, PA 17013 PHONE: (717) 240-6225 FAX: (717)240-6248 March 27, 2001 Plaintiff Name: Stanley Rockey Defendant Name: AIda Rockey Docket Number: 00-3287 PACSES Case Number: Other ID Number: Please Note: All correspondence must include the PACSES Case Number INCOME AND ExPENSE STATEMENT THIS FORM MUST BE FILLED OUT (IF YOU ARE SELF-EMPLOYED OR IF YOU ARE SALARIED BY A BUSINESS OF WHICH YOU ARE OWNER IN WHOLE OR PART, YOU MUST ALSO FILL OUT THE SUPPLEMENTAL INCOME STA TEMENT WHICH APPEARS ON THE LAST PAGE OF THIS INCOME AND EXPENSE STATEMENT.) INCOME STATEMENT OF: STANLEY ROCKEY I V1::;RIFY THAT THE STATEMENTS MADE IN THIS INCOME AND EXPENSE STATEMENT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STAT~MENTS HEREIN ARE SUBJECT TO THE CRIMINAL PENALTIES OF 18 PA. C. S. ~4904 I RELATING TO UN"SWORN FALSIFICATION TO AUTHORITY. /Y!W'.L~ :2" , , 200 j)!~OI )('~6T~~ DATE INCOME: EMPLOYER: RETIRED AnDRESS: TYPE OF WORK: PAYROLL NO. GROSS PAY PER PAY PERIOD $ 51.631.50 (WlCLY 1 BI-WKLY. I ETe. J MONTHLY ITEMIZED PAYROLL DEDUCTIONS FEDERAL WITHHOLDING 186.73 SOCIAL SECURITY LOCAL WAGE TAX 16.32 STAlE INCOME TAX 45.69 RETIREMENT SAVINGS BONDS CREDIT UNION LIFE INSURANCE HEALTH INSURANCE OTH~R DEDUCTIONS UNION DUES OPTI-WAGE TAX (SPECIFY) TOTALS NET PAY PER PAY PERIOD $ $1 .382.76 Service Type Page 1 of6 Form IN - 008 Worker ID ~ Ii: H J u .^ - -~. '~,'": Income and Expense Statement PACSES Case Number, Other (Fill in Appropriate Column) Income WEEK MONTH YEAR INTEREST Dividends $20.00 $80.00 quarterly Pension Annuity Social Security Rents Royalties Expense Account Gifts Unemployment Compo Workmen's Compensation IRS Refund Other Other TOTAL INCOME EXPENSES (Fill in Appropriate Column) WEEK MONTH YEAR HOME Mortgage/Rent 451.38 Maintenance 15.10 Utilities Electric 72,09 Gas 72.66 Oil Same Telephone 48.45 Cellular phone 24,04 Service Type Page 2 of6 Form IN - 008 Worker ID Income and Expense Statement PACSES Case Number: EXPENSES (Fill in Appropriate Column) continued WEEK MONTH YEAR Water Sewer EMPLOYMENT Public Transportation Lunch TAXES Real Estate Personal Property Income INSURANCE Homeowners Automobile 39,61 Life 110.00 Accident Health Other AUTOMOBILE Payments Fuel 100.00 Repairs 60.35 MEDICAL Doctor 80.00 Dentist Orthodontist Service Type Page 3 of6 Form IN - 008 Worker ID '-.".- """~~- C~'ci'-f Income and Expense Statement PACSES Case Number: EXPENSES (Fill in Appropriate Column) continued WEEK MONTH YEAR Hospital Medicine Special Needs (glasses, braces, orthopedic devices) EDUCATION Private School Parochial School College Religious PERSONAL Clothing/Laundry 80.00 Food 120.00 Barber/Hairdre~ser Credit payments: Credit Card Charge Account Memberships LOANS Credit Union MISCELLANEOUS Household help Child Care papers/Books/Magazine s Entertainment Pay TV 29.00 Vacation Service Type Page 4 of 6 Form IN - 008 Worker ID Income and Expense Statement PACSES Case Number: EXPENSES (Fill in Appropriate Column) Continued WEEK MONTH YEAR Gifts Legal Fees 100.00 Charitable Contributions 275.00 Other: Alimony Payments OTHER: Total Expenses 1677,68 Property Ownership * Owned Description Value H W J Checking Account(s) Savings Account(s) Credit Union Nominal Nominal Stocks/Bonds 150 shares IBM stock X Real Estate 101 Pine Hill Road X Other - IRA 11,000.00 X Total Insurance Company Coverage * Policy # H W J Hospital: Medical: Service Type Page 5 of6 Form IN 008 Worker ID "~~ - I ~ '"- '-~ e. Wh , Income and Expense Statement PACSES Case Number: Insurance Company Coverage * Policy # H W J Health/Accident Disability Income Dental Other: *H-Husband W-Wife J-Joint SUPPLEMENTAL INCOME STA TEMENT A. THIS FORM IS TO BE FILLED OUT BY A PERSON: 1. WHO OPERATES A BUSINESS OR PRACTICES A PROFESSION, OR 2. WHO IS A MEMBER OF A PARTNERSHIP OR JOINT VENTURE, OR 3. WHO IS A SHAREHOLDER IN AND IS SALARIED BY A CLOSED CORPORATION OR SIMILAR ENTITY. B. ATTACH TO THIS STATEMENT A COPY OF THE FOLLOWING DOCUMENTS RELATING TO THE PARTNERSHIP, JOINT VENTURE, BUSINESS, PROFESSION, CORPORATION OR SIMILAR ENTITY: 1. THE MOST RECENT FEDERAL INCOME TAX RETURN, AND 2. THE MOST RECENT PROFIT AND Loss STATEMENT C. NAME OF BUSINESS: ADDRESS AND TELEPHONE # OF BUSINESS D, NATURE OF BUSINESS (CHECK ONE) (1) PARTNERSHIP (2) JOINT VENTURE (3) PROFESSION (4) CLOSED CORPORATION (5) OTHER E. NAME OF ACCOUNTANT, CONTROLLER OR OTHER PERSON IN CHARGE OF FINANCIAL RECORDS: F. ANNUAL INCOME FROM BUSINESS: 1. How OFTEN IS INCOME RECEIVED? 2. GROSS INCOME PER PAY PERIOD? 3. NET INCOME PER PAY PERIOD? 4. SPECIFIED DEDUCTIONS, IF ANY: Service Type Page 6 016 Form IN - 008 Worker 1D -~. n - e__ JAMES D. FLOWER JOHN E. SLlKE ROBERT C. SAIDlS GEOFFREY S. SHUFF JAMES D. FLOWER, JR. CAROLJ. LINDSAY JOHNNA J. KOPECKY KARL M. LEDEBOHM JOSEPH L. HITCHINGS THOMAS E. FLOWER LAWOFFlCFS SAIDIS, SHUFF, FLOWER & LINDSAY A PROFESSIONAL CORPORATION 26 WEST HIGH STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486 EMAIL: attorney@ssfl-law.com www.ssfl-law.com WEST SHORE OFFICE: 2109 MARKET STREET CAMP HILL, P A 17011 TELEPHONE: (717)737-3405 FACSIMILE: (717)737-3407 REPLY TO CARLISLE May 18, 2001 Robert Elicker Divorce Master Domestic Relations Office 13 North Hanover Street Carlisle, PA 17013 Re: Stanley Rockey v, Alda Rockey No,: 00-3297 civil Dear Mr, Elicker: The parties to this matter have reached an agreement and we are now in a position to finalize this divorce; Please vacate the Master's appointment in the above-captioned case, Thank you for your prompt attention to this matter, Sincerely, SAIDIS, SHUFF, FLOWER & LINDSAY J~~ ~ JJK: tdm ,!: ~ """.l!ijJ" ~ '" STANLEY R, ROCKEY, Plaintiff vs, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 00 - 3287 CIVIL ALDA R. ROCKEY, Defendant IN DIVORCE ORDER OF COURT AND NOW, this cJ;<~ day of ~,,~ in the proceedings having 2001, the economic claims raised been resolved in accordance with a property settlement and separation agreement dated May 10, 2001, the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce, BY THE COURT, ,J, G cc: Johnna J, Kopecky Attorney for plaintiff Andy Norfleet Attorney for Defendant y @~ ~~- ~. a. n"""""",,_.'~ -'w;1IIt 111 . ."-~ lliW;' "'",:,:liw;r"""".- !:', . . .' -,," -< PROPERTY SETTLEMENT AND SEPARATION AGREEMENT THIS AGREEMENT made this Jrflaay of "frJcJ 7 ,2001 between Stanley R. Rockey of Cumberland County, Pennsylvania, hereinafter referred to as Husband, A N D Aida R. Rockey of Cumberland County, Pennsylvania, hereinafter referred to as Wife. i RECITALS: , , i I ! I R.1: The parties hereto are husband and wife, having been joined in marriage i j on, June 8, 1985 in Harrisburg, Dauphin County, Pennsylvania and I R,2: A Complaint for Divorce has been filed in the Court of Common Pleas of I , Cumberland County, Commonwealth of Pennsylvania, on May 30, 2000, to Number 00- 3287 Civil Term; and SAlOIS R.3: The parties' hereto desire to settle fully and finally their respective financial SHUFF. FLOWER . & LINDSAY and property rights and obligations including, but not limited, of all matters between A1TORNEYS.AT.Lt\W 26 W. High Street Carlisle. PA them relating to the ownership of real and personal property, claims for spousal support, alimony, alimony pendente lite, ." -< SAIDIS SHUFF, FLOWER & LINDSAY A1TORNEYSeAT.u..W 26 W. High Street Carlisle. PA ,~","",~~iII-"ii~" ~~~- ~ ~ ~._' WIiilIilil ~.... - ="~~,~~ . ~ '<kI\MI;Iii."- NOW THEREFORE, in consideration of the covenants and promises hereinafter to be mutually kept and performed by each party, as well as for other good and valuable consideration and intending to be legally bound, it is agreed as follows: (1) SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place or places as he or she from time to time may choose or deem fit. free from any control, restraint or interference from the other. Neither party will molest the other or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceeding, Each party shall be free of the interference, authority or contact by the other as if he or she was single and unmarried I ! except as maybe necessary to carry out the terms of this agreement. , II il !I !I " ii i (2) DIVORCE: The parties acknowledge that the marriage is irretrievably broken and that they will secure a mutual consent no-fault divorce decree in the above-captioned divorce action. Upon the execution of this agreement, the parties shall execute and file an Affidavit of Consent and Waiver of Notice Forms, necessary to finalize said divorce. If either party fails or refuses to execute and file the foregoing documents or if Husband fails to finalize the divorce within twenty (20) days after the date he/she makes the monetary payment to husband/wife aforesaid, said failure or refusal shall be considered a material breach of this Agreement and shall entitle the other party at his or her option to terminate this Agreement. (3) REAL PROPERTY: The parties are the owners of certain real estate with improvements thereon erected and known and numbered as 101 Pine Hill Road, Enola, Cumberland County, Pennsylvania, 2 ....=-"_.~ , . SAlOIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-f..AW 26 W. High Street Carlisle, PA - ... ~ ~ " -.'~~i:li!~':j.i!lildltij.tL_"'""'"""J<:i.9,> - ~ ," Wife agrees at the time of the execution of this Agreement to convey the real estate with improvements thereon erected at 101 Pine Hill Road, Enola, Cumberland County" Pennsylvania to Husband by special warranty deed, Said deed shall be held in escrow until such time as the affidavits of consent have been executed and filed and the property refinanced as set out below, I I I and liens of record, utility bills, insurance and real estate taxes in connection with s. aid II Husband shall pay for all household expenses including, but not limited to, mortgages property. With regard to all such expenses, Husband hereby shall hold Wife harmless i ! i i II II 'i Ii I " i! U U 'I II II II !I II if " I' II II II I' I I I I I I I I and indemnify Wife from any loss thereon. Husband shall refinance said mortgage obligation within 45 days of the date of this agreement at which time the escrow deed shall be released to him, At the time of the refinance, Husband shall pay to Wife the sum of $40,000.00, which shall represent her equity in marital property. (4) DEBT: MARTIAL DEBT: A. Husband and Wife acknowledge and agree that there are no other outstanding debts and obligations which are martial or for which the other might be liable incurred prior to the signing of this Agreement. B: Post Separation Debt: In the event that either party cont~acted or incurred any debt since the date of separation on December 27, 1997 the party who incurred said debt shall be responsible for the payment thereof regardless of the name in which the debt may have been incurred, 3 .,'~'''''''~ - . . . SAIDIS SHUFF, FLOWER & UNDSAY A~AT-t.AW 26 W. High Street Carlisle. PA ~.~ ~~ , ~,..~,. . I -"" ~~~1il}i',"~~ID'~e' ~" - C: Future Debt: From the date of this agreement neither party shall contract or incur any debt or liability for which the other party or his or her property or estate might be responsible and shall indemnify and save the other party harmless from any and all claims or demands made against him or her by reason of debts or obligations incurred by the other party. (5) MOTOR VEH1CLES: Each party relinquishes any right, title and interest he ,I !I or she may have to any and all motor vehicles currently in possession of the other party, II Within 30 days of the date of this agreernent each party shall execute any documents ![ II necessary to have said vehicles properly registered in the other party's name with the Pennsylvania Department of Transportation. Each party shall assume full responsibility ;j " Ii of any encumbrance on the motor vehicle received by said party, and shall hold l\ ;! harmless and indemnify the other party from any loss thereon. :i .! it i! :i that they have effected a satisfactory division of the furniture, household furnishings, ii q :1 il I' i ! I , , i (6) TANGIBLE PERSONAL PROPERTY: The parties hereto mutually agree appliances, tools and other household personal property between them, and they mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such property presently in his or her possession whether said property was heretofore owned jointly or individually by 'the parties hereto. This I. agreement shall have the effect of an assignment or bill of sale from ~ach party to the II Ii II II II II ! I I other for such property as may be in the individual possession of each of the parties hereto. (7) INTANGIBLE PERSONAL PROPERTY: Each party hereby relinquishes any right, title or interest he or she may have in or to any intangible personal property 4 --- . . SAlOIS SHUFF, FLOWER & LINDSAY ATI'ORNEY'S-AT.LAW 26 W. High Street Carlisle. PA ~ ~~, - 4:di'-~~ ~>>-~-~~i&~;; < ~ . ~ currently titled in the narne of or in the possession of the other party, including, but not limited to, stocks, bonds, insurance, bank accounts, individual retirement accounts, employment benefits including retirement accounts, savings plans, pension plans, stock plans, 401K plans and the like, specifically Husband's pension in IBM savings plan, the IRA held by Husband at Americhoice Federal Credit Union, and Wife's pension with the Commonwealth, (8) ALIMONY: WAIVER OF ALIMONY: The parties acknowledge that each has income and assets satisfactory to his and her own reasonable needs. Each party waives any claim he or she may have one against the other for aiimony, spousal support or II alimony and alimony pendente lite. :1 !I I, II II II l' (9) ADVICE OF COUNSEL: The parties hereto acknowledge that each has been notified of his or her right to consult with counsel of his or her choice, and have been provided a copy of this agreement with which to consult with counsel, Husband is represented by Johnna J. Kopecky, Esquire, and Wife is represented by Andrew Norfleet, Esquire, and has been advised that he or she may be represented by counsel of choice. Each party acknowledges and accepts that this agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge as each. has sought from counsel, and the execution of this agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal agreement or agreements, Each party shall pay his or her own attorney for all legal services rendered or to be rendered on his or her behalf. 5 , , . - '"... ~~" _.~ -~--- . """ ."""~.""'- I I I SAlOIS I SHUFF, FLOWER I & LINDSAY ATrORNEYS-AT-f.,AW 26 w. High Street Carlisle, PA ~ "~" '- . I ,. -'"~~~=~lMiMlllIIlIlili lI'l1!t.rki-, ~ ~~~ (10) ADDITIONAL INSTRUMENTS: Each ofthe parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. (11) BANKRUPTCY: The parties hereby agree that the provisions of this Agreement shall not be dischargeable in Bankruptcy and expressly agree to reaffirm II any and all obligations contained herein, In the event a party files such bankruptcy and I I II I I, Ii I! :1 if i.\ :1 i pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party shall have the right to declare this Agreement to be null and void and to terminate this Agreement in which event the division of the parties' martial assets and all other rights determined by this Agreement including alimony shall be subject to court determination the same as if this Agreement had never been entered into. (12) COMPLETE DISCLOSURE: The parties do hereby warrant, represent, I acknowledge and agree that each is fully and completely informed of, and is familiar I il II I I I with, the wealth, real and personal property, estate and assets, eamings and income of the other and has made any inquiry he or she desires into the income or estate of the other and received any such information requested. Each has made a full and complete disclosure to the other of his and her entire assets, liabilities, income and expenses and any further enumeration or statement thereof in this Agreement is spec;ifically waived. (13) RIGHTS AND RESPONSIBILITIES: Husband and Wife acknowledge that each of them has read and understand his and her rights and responsibilities under this Agreement and that they have executed this Agreement under no compulsion to do so but as a voluntary act. 6 --- , ,-. SAlOIS SHUFF, FLOWER & LINDSAY ATI'ORNEYSeATlLAW 26 W. High Street Carlisle. PA ,.__..~ - -~ - i"" ,'w ;'"""""';llll:lllllllllli,"llilbi~l'liilir-lil~ <IiII~"-~j.i: ~ ~ ~ ~ - ~ (14) FULL SETTLEMENT: Except as herein otherwise provided, each party hereby releases the other from any and all claims, or demands up to the date of execution hereof, It is further specifically understood and agreed by and between the parties hereto that each party accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all of said party's rights against the other for past, I present and future claims on account of support, maintenance, alimony, alimony I ! , i i I II " " Ii \1 , ;! " iI ., il :i ;1 " " 'I il ~ I " " H ii " 11 :1 II Ii II I I , I I I I II II ! pendente lite, counsel fees, costs and expenses, equitable distribution of marital property and any other claims of the party, including all claims which have been raised or may be raised in an action for divorce, (15) RELEASE OF ALL CLAIMS: Except as may be otherwise specifically provided in this Agreement, Husband and Wife, for themselves, their heirs, representatives and assigns, each hereby forever releases, remises, discharges and quitclaims the other, and such other's heirs, representatives, assigns and estate, from and with respect to the following: A. All liability, claims, causes of action, damages, costs, contributions and expenses or demands whatsoever in law or in equity; B. All rights, title, interest or claims in or to any property of the other, whether real, personal or mixed and whether now owned or hereafter acquired; c. All rights of curtesy and dower and all claims or rights in the nature of curtesy and dower; D. All widow or widower's rights; E. All right, title, interest or claim in or to the other's estate. whether now owned or hereafter acquired, including but not limited to all rights or claims: 7 - '. , . , SAlOIS SHUFF, FLOWER & UNDSAY A~ATeJ..AW 26 W, High Street , Carlisle, PA " ~_" Jlil. iJi:oi1,: (1) to take against the other's will; (2) under the laws of intestacy; (3) to a family exemption or similar allowance; , , , , and (4) all other rights or authority to participate or intervene in a I deceased spouse's estate in any way, whether arising under the laws of Pennsylvania I , , I I I , i I ; I I i I " il II 'I l- i! ., II :i il 'I Ii I. il II ~ I I I or any other country, territory, state or political subdivision. F. All rights or claims to any accounting; G, All rights, claims, demands, liabilities and obligations arising out of or in connection with the marital relationship or the joint ownership of property, whether real, personal or mixed; H. All rights, claims, demands, liabilities and obligations arising under the provisions of the Pennsylvania Divorce Code, as the same may be amended from time to time, and under the provisions of any similar statute enacted by any other country, state, territory or political subdivision; I. All rights, claims, demands, liabilities and obligations each party now has, or may hereafter have, against or with respect to the other. (16) GOVERNING LAW: This Agreement shall be construed under the law of the Commonwealth of Pennsylvania. If any provision of this AgreemE?nt is determined to be invalid or unenforceable, all other provisions shall continue in full force and effect. (17) INCORPORATION INTO DECREE: In the event that either of the parties shall recover a final judgment or decree of absolute divorce against the other in a court of competent jurisdiction, the provisions of this Agreement may be incorporated by 8 .:'~ V..:I i ".~"~~ . -" -~ . . . SAlOIS SHUFF. FLOWER & LINDSAY A'l"I'ORNEYS-AT-LAW 26 W. High Street Carli,l.. PA '~.~ " - .- -. -. -' ..-_ ' . '. ......~= ~ ,- ~~-~- =-'-'i'eV , . reference or in substance but shall not be merged into such judgment or decree and this Agreement shall survive any such final judgment or decree of absolute divorce and shall be entirely independent thereof. (18) BREACH: In the event that either party breaches any provision of this Agreement, he or she shall be responsible for any and all costs incurred to enforce the Agreement, including, but not limited to, court cost and counsel fees of the other party, In the event of breach, the other party shall have the right, at his or her election; to sue I', I',: for damages for such breach or to seek such other and additional remedies as may be available to him or her. (19) ENTIRE UNDERSTANDING: This Agreement constitutes the entire i I il understanding between the parties and there are no covenants, conditions, ,. II II representations, or agreements, oral or written, of any nature whatsoever, other than I I those herein contained. i I (20) AGREEMENT BINDING ON PARTIES AND HEIRS: This Agreement shall i I I bind the parties hereto, their respective heirs, executors and assigns. I I IN WITNESS WHEREOF, the parties hereto intending to be legally bound have ds and seals the day and year first written above. ..ot..~ O~ J(, J1 - P " Stanley R. ockey "}--:" . - .;7// .. J // / / .L',y-- /... ?'.L. / ./:/::/ . /./ ~-] () . j! ~q /-<'.I"..~~~tA . iJ..A.;)..J X- WitnesS" ,(' ~/ Aida R. Rockey 'KfRN-I..,j/' U 9