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Home My WebLink About00-04656 , '. ~ ( . . . . . . IN THE COURT OF COMMON PLEAS . OF CUMBERLAND COUNTY . PENNA. STATE OF SHERI GOSSARD, No. 2000-4656 CIVIL TERM Plaintiff . CIVIL ACTION - LAW VERSUS IN DIVORCE LARRY GOSSARD, Defendant DECREE IN DIVORCE . Q. 4:st I''''' 2001 ,IT is ORDERED AND . ~/~ AND NOW, SHERI GOSSARD PLAINTiFF, DECREED THAT LARRY GOSSARD , DEFENDANT, AND ARE DIVORCED FROM THE BONDS OF MATRiMONY. . THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FiNAL ORDER HAS NOT YET BEEN ENTERED; .:, ~ NONE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . AITES(!~~ J, . . . i . PROTHONOTARY . . . . . . -;',."""'"7-'-" ."_ ' ',~' - ,., ~ , "-L.-', '-" ]~a-jIUillWlilliliil>j;jil1rllllMl~=-' ... r.!riiI~liiMIll~ifl~ ( ~~ 9, lI-eJ/ tJ -Oal .i,U~,,,,~,, .~ .~_.^ .0"',.,. ~"._"'".H'.' ,,,, . ".IliiIIII' __ . 'o~ . ~- . w,........',., -'1:; .-. J.~' , , W.~~~4-/U~ ~ ~Z~'dd~ , -. , , , .~ SHERI GOSSARD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLANDCOUNTY,PENNSYLVANIA v. CIVIL ACTION -LAW 2000-4656 CIVIL TERM LARRY GOSSARD, Defendant 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: I. Ground for Divorce: irretrievable breakdown under Section 330 I (c) of the Divorce Code. 2. Date and mauner of service of complaint: A certified copy of the Complaint in Divorce was served upon the defendant, Lany Gossard, on June 28, 2000, by certified, restricted delivery mail, addressed to him at 46 North East Street, Carlisle, Pennsylvania 17013, with Return Receipt Number P 492 355 974. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 330] ( c) of the Divorce Code: by plaintiff: August 29,2001; by defendant: August 29, 2001. (b)(l) Date of execution of the affidavit required by Section 330l(d) of the Divorce Code: (b )(2) Date of filing and service of the plaintiffs affidavit upon the defendant: 4. Related claims pending: NONE. 5. Complete either (a) or (b). (a) Date and mauner of service of the Notice oflntention to file Praecipe to Transmit Record, a copy of which is attached: (b) Date plaintiffs Waiver of Notice in Section 330l(c) Divorce was filed with the Prothonotary: August 29, 2001. ~.- :: Date defendant's Waiver of Notice in Section 3 Prothonotary: August 29, 2001. T, ill, ESQUIRE :1' . ,.,,- ",~,. - -;.(':";:'l- -:'-~-"---'~ 1, -?.'_O_"'_ -I' " ~. '~-" - ., -''''-1 . 1_, <. -," -'C.';'""', , ,~~ c_ ..,. ~_",~~ 'I"''"''. '---'''<>~''"'~''-~I,' "',< ';,0, "i"-' , 2 0 IJ -.t1 s: en -o~ m -ri (TIn -0 --gfiJ :z: I :Z:C 0 (j)-dL~: <.Jh -<~ ~o -0 '"33 ~o - r~) ..... 7?fi ~g ':? Q -,j ~ c:- ~ ~''''-9'''''''''~~__,'' -'P,,!.~ SOCIAL SECURITY INFORMATION SHEET PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1 (a) (3) ALL DIVORCES MUST INCLUDE THE PARTIES SOCIAL SECURITY NUMBER PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE PROTHONOTARY'S OFFICE DATE: September 10, 2001 DOCKET NUMBER: 2000-4656 Civil Term PLAINTIFF~ SS# 209-46-1542 NAME: Sheri L. Gossard DEFENDANT~ SS # 182-50-6611 NAME: Larry. E. Gossard ."-<., -'" , SHERI GOSSARD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO. 2000 ..q~CIVIL TERM LARRY GOSSARD, Defendant : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are wamed that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator - Fourth Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 Telephone (717) 240-6200 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. James J. Kayer, Esquire Attorney for Plaintiff 4 East Liberty Avenue Carlisle, P A 17013 (717) 243-7922 " , ," . ,-~" " I . SHERI GOSSARD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO. 2000 -.i,lt j-~CIVIL TERM LARRY GOSSARD, Defendant : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 330Hc) and 330Hd) OF THE DIVORCE CODE COMES NOW, Plaintiff Sheri Gossard, through her attorney, James J. Kayer, Esquire and avers as follows: COUNT I - DIVORCE I. Plaintiff is Sheri Gossard, an adult individual, whose current address is 46 North East Street, Carlisle, Cumberland County, Pennsylvania, 17013. 2, Defendant is Larry Gossard, an adult individual, whose current home of record is 46 North East Street, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on Augustl7, 1985 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce filed in this matter. 6. Plaintiff and Defendant are not members of the United States Armed Forces. 7. The marriage is irretrievably broken, and the parties are proceeding under Section 3301(c) and Section 3301(d) of the Divorce Code. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. ~ 1 '. -1'<~ '~-'T WHEREFORE, Plaintiff requests the court to enter a decree of divorce. Respectfully submitted, \, Date: June 28, 2000 -l ,. , ' VERIFICATION OF PLEADINGS The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. The language of the document may, in part, be the language of my counsel and not my own. I have read the statements made in this document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief, To the extent that the contents of the statements are that of counsel, I have relied upon counsel in making this Verification. I understand that false statements herein are made subject to the penalties of 18 P A. C.S. S 4904, relating to unsworn falsification to authorities. Date: r;~/~ / I ." ., ~ , , ~= ~,- "" J .. .. I! ~ " = " o J 3. Article A r; sse to: . i L/lfljV! GOSSQP-f) ~ ^llP V. Sctst ~~t ~~LP t"A- IlO{3 -Comp/ole It~ms 1 and/or 2 for additIOnal servicea. -Complete Items 3, 4a. and 4b. -PrInt your name and addloo8 on 1he raver.ae of this form so that we can return this cal'dtoyou. -Attach this fonn to the front of the mallp1ece. or on the back if space does not permit. -Wrtta-R6Ium R9CBipt Rsqusstsd. on the maifpieco below the article number. -The Relum Iptwift shOWl the article was d livered and1he date ""ivored. . . ILl I also wish 10 re..alve Ihe toIJowlng services (for an extre fee): ,. 0 A~e's Address ~ 2. ErJ:Iaslrlcted Delivery /J! Consult postmaster for fae. ii I umbe3S:::. 97 ,:;, 40. Service Type j o Registered ~d ~ o Ex~s MeR 0 Insured .6 ~lum Racelptfor Merchandise 0 COO ~ 7. Dale of 0 ivery .\i c/. ..,..,<9 r 8. Addressee's Address (Only If requsstGd ~ ~ and fas Is paid) !. ~ " o ... !!! 1=>..,.a,0179 Domestic Return Receipt --->- . , SHERI GOSSARD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO. 2000 - 4656 CIVIL TERM LARRY GOSSARD, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO Pa. R.C.P. 1920.4(a)(1)(ii) COMMONWEALTH OF PENNSYLVANIA : SS. COUNTY OF CUMBERLAND I, James J. Kayer, Esquire, being duly sworn according to law, deposes and says that he is the attorney for Plaintiff, SHERI GOSSARD, and that he did serve a true and correct copy of the Notice to Defend and Complaint in Divorce that was filed in the above matter, by U.S. Mail, postage prepaid, certified with restricted delivery, return receipt requested, unto the Defendant, LARRY GOSSARD, on July 1,2000. The return receipt is attached hereto. Sworn to and subscribed before me day of July 5, 200 . ': VY\ft~ N TARIAL SEAL DENISE ?INAMONTI. Notary Public Carlisle Borough, Cumberland County M Commission Expires Nov. 20, 2000 . - .. -"_- _<_ r. - ~ ~ q , ~ . . SHERI GOSSARD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. 2000-4656 CML TERM LARRY GOSSARD, Defendant CJ 0 v~ ~ .--, ITl rr; G-' ZT' ~ ~~. ~; r'C" ...,...., ~--' ~_CJ .,.. );: ~.~.~..! - :) ---- ;'::'j L-:" ....... ~ I. A complaint in divorce under Section 3301(c) of the Divorce Code was fiIl:d oo:Jun~ 29,2000. CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. I verify that the statements rnade in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. "",,\"iL t&: 2!1 .2001 ~onCZ11 -SHERI GOSSARD Plaintiff '>"--1 -~-. ";,_~:",":e;}~~'~~-'!':"-_""t"c,_., co,_", ~- ,-' .~ _, ~~___ye,_""_ ~, -0- ~. u ~ ~ ,_ ._ , . I SHERI GOSSARD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. 2000-4656 ClIVIL TERM LARRY GOSSARD, Defendant CIVIL ACTION - LAW IN DIVORCE o c <~ -or:, rnrT: ~f:; (f) ~i;.'. -< " kC >c z(O-;; >c::: S2 WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECIREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. D.'" ~ tf,d )1 .2001 ~:aL~ Plaintiff I'.'.'"'' ,- ':',' ,. :,';V", :'--'<'--~:'~'f:"'t'2'",_, "'''-'4', ,',.,,_,_,,!._<:-,wf"_';" '~,. ~,,,,~,""~ .c. _ . " ,~.,...,"'"__, ._~~ _ _ _ _ ~ _, .,. .' ._,_ ',~ '_ ,_ C) ;.'!~ .- :.S f'-' , tD ..C) (1"\ , :-;:1 :u -< , , ..II " . SHERI GOSSARD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. 2000-4656 CML TERM LARRY GOSSARD, Defendant CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT I. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 29, 2000. ~ c:, \1 :'S,.c "l:"lot ._, 2. The marriage of plaintiff and defendant is irretrievably broken and ninH~y~ii.av~c:, elapsed frorn the date of the filing of the complaint. v;C;: ;:;; -<;:~-- ,~ ~\.._: "'0 ~C) ~CI )> ('OC_ () 4. I understand that I may lose rights concerning alimony, division of prop~, I~er~ fees or expenses if! do not claim them before a divorce is granted. 3. I consent to the entry of a final decree in divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: _AI ') ~ rl. "f Jt~/ARDL-~ Defendant .2001 ---,',",.' ,":C"' . ._+_ ,.~, -'<''''=~' _,_.-;<l " -c~ -.j'_~"'f'7"i~,"-'- - '_,"'_"'""~"_ _'~ '_.m_"_~~ _ ',~,;. ,^,c,__,___,~~, _, , ,,_",' ~ ~ ~' . . . . .' ,. SHERI GOSSARD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. 2000-4656 CllVIL TERM LARRY GOSSARD, Defendant CIVIL ACTmN - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTliON TO REOUEST ENTRY OF A DIVORCE DEdREE UNDER SECTION 3301(c) OF THE DIVORCE CODE CJ C) o ,;' -1-; c: -.,tf ~ ... ::;:) I. I consent to the entry of a final Decree of Divorce without notice. g.: ~l '0 -7'-- " -' co-:;?" \1:' 2. I understand that I may lose rights concerning alimony, division of prop~~i lawyer's fees or expenses if! do not claim them before a divorce is granted. ~ g',:::. J'? c~.:, Z "'"' 3. I understand that I will not be divorced until a divorce decree is entered by ~ CotIit 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: Av <0 @? L~~ .2001 Defendant . -, ,-" ',,,,, ,c,. ,'"_'0:'1:""'--; _, -, ,-,-~-,- " ,. '- 'C'-,', ',,,,_,_, c,,- '-c-.-.", ',. -, -'--'.:1-'"~,, "_'.'" ,,_'r __~_,___ ",,, . ~.. ^ ~ . . . ., ...t .. SHERI GOSSARD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. 2000-4656 CllVIL TERM LARRY GOSSARD, Defendant CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT o 0 G <, """ -obJ :.:- fTllTi :-7) ~ :c r~.) L_C, r l. I have been advised of the availability of marriage counseling and undeI~i~ th~.iJ may request that the court require that my spouse and I participate in counseling. ~ c:' :';.' ==C1 _ PC:: :;-,.; ... =2 ()1 The~J:ft~g duly sworn according to law, deposes and says: (r1 2. I understand that the court maintains a list ofmmiage counselors in the Prothonotary's Office, which list is available to me upon request. ~~. :~~:J -< 3. Being so advised, I do not request that the court require that rny spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: Ii 1)(0 c;:!'l .2001 ~LJ Defendant "--, ~- <;-':f"'''- <-,''Co,.'i-'" .,- ~__-; ~ "~'i'>~"",,,,,,~__,_!,!,,"_,,,,,, 'l.' , - '_"_""-"-'_"~ _~",,,,,__,_,,,,__, . SHERI GOSSARD LARRY GOSSARD DATE: / 7 /17 ~o/ 0//1/[) .,e;.-- ~ 7.-1/14 dl - - ,,,,,.,_"C - ,-'" ,~- -', [' - - - '" ','e -Y',-' IN THE COURT OF...COMMON PLEAS OF CUMBERLAND COUNTY, ""PENNSYLVANIA Plaintiff CIVIL ACTION LAW VS. NO. 00 - 4656 CIVIL 19 IN DIVORCE Defendant STATUS SHEET ACTIVITIES: a.m. ~ ~~ b " ,. '~;': '0 '" 'C"',",,'.,-.,,, SHERI GOSSARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00 - 4656 CIVIL LARRY GOSSARD, Defendant IN DIVORCE TO: James J. Kayer Attorney for Plaintiff , Marcus A. McKnight, III Attorney for Defendant DATE: Tuesday, February 27, 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. d, _,,, ",e i__ ... (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. DATE COUNSEL FOR PLAINTIFF COUNSEL FOR DEFENDANT NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. ,,;>J...__ ~_-" C""':' ~ .'"'-"""""!'" . , I~ THE COURT OF COMMON PLEAS OF CtlMBElU.AND COUNTY, PENNSYL V AMIA CIVIL ACTION - LAW IN DIVORCE SHERI GOSSARD, Plaintiff vs. LARRY GOSSARD, Defendant NO. 2000 4n'iO 19 LARRY GOSSARD a master with respect to .the ( l{) Divorce ( ) Annulment ( ) Alimony ( ) Alimony Pendente }10TION FOR APPOINTl1ENT OF MASTER ~ (Defendant), following claims: moves the court to appoint Lite (x) ( ) (X ) (X) Distribution of Property Support Counsel Fees Costs and E."q)enses and in support or the motion states: (1) Discovery is complete as to the claims(s) for which the appointment Ot a master is requested. (2) The Plaintiff, (has) ~ appeared in (by his attorney, JAMES J. KAYER (3) The staturory ground(s) ror divorce (is) 330l(c) and 330l(d) (4) Delete the inapplicable paragraph(s): (a)' The action is not contested. (b) An agreement has been reached with respect to the following claims: Divorce, equitable distribution, costs, expenses and fees (c) The action is contested with respect to the following the action ~) ,Esquire). (are) claims : (5) The action ~ (does not involve) comple~ issues or law or fact. ~ (days). to the motion: (6) The hearing is expected to take (7) Additional infor-nation, if any. Date: FEBRUARY 22. 200] AND NOW is appointed master with ORDER APPOINTING :1ASTER ...... c:U, 19 oUql ~'~Ar-~j espect to t~e fol owing claims:' . 4.tL/ Esquire, ~..~ :)'v O~~~ IPJ '-'.:'"c.t ",",~ , , "C__;__ "=,o~ ,~~ VIN\f^lASNN3d ''''n'''~ .., 'J~"-"CI'''l'~ ll.l.)\ I,,;,) 1_.~,\\, ':::'_~r:,1r1 0 . ,,~, r U":, Hd ("'~ ,p 1 ' "" (,6 tL::JJ i~,J ASV-LO;'-';',jj" i 1!1~u~~(~ ,~ Jt;, ^ . ,~-- - i. ~"' ,_ _ _~_ .~' _',.0' ,~ '~~-","~, ',--".'~'"'< -,-", '"' C:) -" n-1 ~.):] 1'.,.; 1'\'- ;'-,) 'L;~F-; ~~i~~ -., ~~~?~ -'~ -< (') -fJ~~ S~:_~;.. ! Z'r- UJ _'..'- -,..- -- r;::c- -':'- <c:-;:c:. :t':c; _.~ C:: :;~ =< ~0 f'\J - o!).-t;9..3 -0 I ~~~~_~-!!O:"'l!4IFI1"fH,1!j^,"..n<"I'm\II~I!:~I)!_1i!8 ",_.,,~~l!lil~~~1$-:fI!I!(fI~~,IlI~m1i\l00!ffll _' _ , r " ,~- -~ ."' . SHERI GOSSARD, Plaintiff VS. LARRY GOSSARD Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW JUL 1 6 20~ : NO. 2000 - 4656 CIVIL TERM : IN DIVORCE PRE-TRIAL STATEMENT OF PLAINTIFF SHERI GOSSARD AND NOW comes the Plaintff, Sheri Gossard, by and through her Attorney, Jane E. Adams, Esquire, and files this Pre-trial statement as required by Rule 1920.33 of the Pa. Rules of Court, and sets for as follows: I. LIST OF ASSETS. A. REAL ESTATE. Item # Asset Value Valuation Date Lien i. Property at 46 N. E, St, Carlisle $59,000 11110/2000 $40,919 to PNC (as of 7/1/00) $14,438 to HFC (as of 7/1100) ii.Property at 48 N. E. St, Carlisle $57,000 11110/2001 $48,000 to J.zimmerman + $500 in back taxes (as of7/1I00) iii. Mobile Home at 15 Peiper Court $ 9,000 7/2001 Bought by Defendant in July 2001 along with household furnishings, prior to leaving the marital home. B. VEHIGLES. iv. 1997 Chevrolet Lumina Sedan $ 5,770 5/04/200 I v. 1994 Chevrolet S 1.0 Pickup $ 3,760 vi. 1994 Chevrolet Lwnina Minivan $ 2,940 C. OTHER PROPERTY. vii. 2 Cemetery Plots viiUewelry held by Plaintiff ix. Jewelry held by Defendant 5/04/200 I 5/04/2001 $ 2,050 5/17/200 I $ 6,600 to AllFirst (as of 7/1/2000) Clear Title to Defendant on 7/112000 Clear Title Jointly to Plaintiff & Defendant Defendant has ownership, Value obtained from cemetery quote. x. Household Goods with Plaintiff $5,000 (auction type estimate) approx value $ 1,000. approx value $ 1,000. xi.Household Goods with Defendant $5,000 (auction type estimate) xii. Coin Collection (Defendant) $1,000 (estimate) ,.,.,.., ," "'^' ~ . r xiii. Gun Collection of Defendant. $ 1,500 (estimate) includes one Rifle, Shotgun, 4 Handguns xiv. Comic Book Collection of Defendant $200 (estimate) xv. Several Large BOl>es of Antique / Depression glassware & bottles (Def.) unknown value xvi. Crystal Collection (Plaintift) $500 (estimate) D. CASH. xvii. Car Insurance Prepaid $600 712000 Defendant retained prepaid monies. xviii. Mutual Fund (VanGuard) $500 712000 Defendant cashed monies E. LIFE INSURANCE. lxx. State Life Insurance (Defendant) $40,000 No cash value, unknown beneficiary xx. State Life Insurance (plaintiff) $40,000 No cash value, Minor Children, beneficiary F. NON-MARITAL ASSETS. Plaintiff has no knowledge of any non-marital assets. G. PROPERTY TRANSFERRED. Plaintiff PeJlSion Fund from Previous 12 years of employment $19,383 Tax Fonn 1099R Plaintiff cashed retirement account and used to pay marital debt and house downpayment. II. EXPERT WITNESSES. Plaintiff does not plan on calling any expert witnesses at this time; however, reserves the right to supplment this list should llI1 expert be deemed necessary. III. OTHER WITNESSES. Plaintiff s only anticipated witness at this time is Sheri Gossard; however, Plaintiff reserves the right to supplement this list at a later date. IV. EXHIBI,TS. (To be provided at pre-trial conference.) A. Appraisals of Real Estate. B. Amoritization Schedules showing payoff value for Real Estate. ., !! 'I _.r f~ ~- . ,~.- ~ " C. Kelly Blue Book Values for Vehicles. D. Letter concerning state pension vesting at 5 years and approximate value of Defendant's pension. E. 2000 Statement of state pension for Plaintiff. F. List of Household Goods in Possession of each party, G. Gross Income and Expenses. V. PENSION / RETIREMENT BENEFITS Description Value Marital Portion Support for Valuation A. State Retirement for Defendant unknown 100% Estimated Statement of value from State Employee Retirement System. As of 5118/0 I 5 years of service is vested. Defendant has 9 1/2 yrs. Approx $20,000 Defendant input + state contribution B. State Retirement for Plaintiff $3,100 100% Yearly statement of value, Plaintiff is unvested untill/2004. $3100 is Plaintiff input VI. MARITAL DEBTS. Item # Description Amt. At SeDaration Liability Incurred Orieinal Amount Payment since Seoaration A. First Mortgage 46 N.E. St (PNC) $40,919 $400 / mo. $42,750 100% PlaintiffuntiJ 6/1/01 B. 2" Mortgage 46 N.E. St (HFC) $14,438 $200 / mo. $14,300 100% Plaintiff until 6/1/01 C. Mortgage 48 N. E. St $48,830 $450 / mo $52,000 Plaintiff wi rents until 6/1/01, then Defendant '. D. Car Loan - AllFirst Bank $6,600 $355 / mo $14,500 100% Plaintiff Ii:. Personal Loan (HFC)-joirtt $13,500?? $220 / mo $14,000 Defendant, but possibly partially by friend loan was signed for. F. MBNA (credit card)-plairttiff $10,968 $220 / mo revolving 100% Plaintiff G. Wachovia (credit card)-joint $4,505 $100/ mo revolving 100% Plaintiff H. Associates (credit card)-plairttiff $4,275' $IOO/mo revolving 100% Plaintiff I. Sears (credit card)-plairttiff $1,917 $50 / mo revolving paid off by Plaintiff J. Choice (credit card)-defendant $2,000?? $50/ mo revolving 100% Defendant K. Home Depot-defendant $1,000?? $50 / mo revolving 100% Defendant -,,,-- , _~!!!P!"" VII. PROPOSED RESOLUTION OF ECONOMIC ISSUES. Plaintiff has physical custody of the children and no longer resides in the marital home. Defendant currently resides in the couple's rental property, which is adjacent to the marital home. Defendant, after one year of separation, chose to move into the rental property although had already purchased an alternate residence. Plaintiff desires that the two properties should be sold and net proceeds divided. If Defendant wishes to retain possession of 48 N. East St property he must sell property at 46 N. East St and assume the loss of proceeds in the sale. (All equity is in the 48 N. East St. property). , Defendant removed marital property desired at time of departure from the marital home. Defendant removed most marital property worth any monetary value. Nonetheless, Plaintiff requests personal possessions to be divided as currently held in possession. Plaintiff would like to retain title and possession of the 1994 Chevrolet Lumina APV Van as well as the 1997 Chevrolet Lumina Sedan. Defendant may retain the 1994 Chevrolet S I 0 pickup. The 1994 Chevrolet Van as well as the 1994 Chevrolet SIO pickup are both paid off. Plaintiff has been paying off the loan on the 1997 Chevrolet Sedan since the date of separation and would continue to .do so. Plaintiff requests that Defendant's pension be divided 50% to Plaintiff, 50% to Defendant. Plaintiff would retain 100% interest in her pension benefits, which are of substantially less value than Defendants. . Debts would be assumed by parties as currently being paid, with joint debts to be refinanced into assuming party's name immediately. Date: 7/;C/01 Respectfully Submitted, ane Adams, Esquire 117S. Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ill No. 79465, ATTORNEY FOR PLAINTIFF SHERI GOSSARD o ~,'~ , ,'_T -1' ' r , " ,~ SHERI GOSSARD, PlaintifflRespondent : IN THE COuRT OF COMMON PLEAS OF , '2L1-6'1 (L : CUMBERLAND'COUNTY, PENNSYLVANIA v. 2000-4656 CIVIL TERM LARRY GOSSARD, DefendantlPetitioner CIVIL ACTION - LAW IN DIVORCE PRE-TRIAL STATEMENT AND NOW cornes the Defendant, LARRY GOSSARD, by and through his attorneys, IRWIN, MCKNIGHT & HUGHES, Esquires, and files this Pre-Trial Statement as required by Rule 1920.33 of the P A Rules of Court, setting forth as follows: I. REAL PROPERTY: A. Real Estate: The parties own two (2) real estate properties: I. 46 North East Street, Carlisle, P A Property Value ..............................................$59,000.00 Less First Mortgage....................................... -40,000.00 Less Second Mortgage .................................. -14.000.00 Equity ..............................................................$5,000.00 2. 48 North East Street, Carlisle, P A Sales Agreement ...........................................$57,000.00 Balance of Agreement................................... -50.000.00 Equity ..............................................................$7,000.00 B. Securities and Bank Accounts: I. Husband's Bank Account .................................................$50.00 2. Wife's Bank Account ............................................................. C. Furniture and Personal ProDertv: 1. Wife's Furniture ........................................................$30,000.00 2. Husband's Furniture ..................................................$10,000.00 D. Automobiles: I. Husband's 1994 S-IO Pick-up Tmck...........................$7,000.00 Less Loan .................................................................... -3.900.00 Total Equity.................................................................$4,400.00 2. Wife's 1997 Chevrolet Lumina Sedan .......................$8,000.00 Wife's 1994 Chevmlet Lumina Van............................$6,000.00 I ~h-._"~_,'_,__"'.,, '.,"', ""':'t.~N, -., .. ", ._,r.~-.,._ .;_'_~". ~;,"", ',,' "',",.', . __._"1"" , I , , E. Pension: 1. Husband's Pension ....................................................$20,000.00 2. Wife's Pension (State) ............................................................ F. Credit Cards: I. Joint - Wachiova .........................................................$4,300.00 2. Joint - HFC Loan ......................................................$15,963.00 II. EXHIBITS: Will be supplied. III. INCOME AND EXPENSES: See Attached Exhibit "A." IV. WITNESSES: Larry Gossard Respectfully submitted, IRWIN, McKNIGHT & HUGHES By: Ma cus A. Me t, Esquire 60 West Pornfret Str Carlisle, Pennsylvania 17013 (717) 249-2353 Supreme Court I.D. No. 25476 Date: May 24, 2001 2 - . ,~,~_'''''"'i'f:l'"'','" ,.'c' ,"', ,-~~,..~"t_;"'~,""',~.J,.,'T'"1.,_ . ~,-" <, ~'.-- . - '. ,,, - .- ~ ,~ , . In the Court of Common Pleas of CUMBERLt\ND County, Pennsylvania DOMESTIC RELATIONS P.O. BOX 310, CARLISLE, PA.17013 Phone: (717) 240-6225 Fax: (717) 240-6248 Plaintiff Name: Defendant Name: , Docket Number: PACSES Case Number: Other State ID Number: !'lease pote: AU correspoadeoce mll5l iDdude lIIe PACSES Case Number. , Income and EXIH'nse Statement , TInS FORM MUST BE FILLED OUT (If you are self-t:lllployed or if you are salaried by a business of which you are owner in whole or pan, you must also fill out the Supplemental Income Statement which appears on the last page of this income and expense statement.) INCOME STATEMENT OF LARRY E. GOSSARD I verify that the statements made in this Income and Expense Statement are true and correct. I understand that false statements herein are subject to the crimiDal penalties 0, f,I8 Pa. C.S. ~ ,4904r:::IT' rel.ring to falsification to authorities. n '. (1 ';/21/01 M~ ~ Dale Plamtiff or Defendant INCOME: Employer DEilARTMENT OF CORRECTIONS Address LitSBlJRN ROAD, CAMP HILL,<PA 1701D1 TypeofVVork CORRECTIONS OFFICER Payroll Nof,2l094 Gross Pay per Pay Period $1 ,641. 60 Pay Period ~., bi-wkly.,m) BI-WEEKLY Itemized Payroll Deductions: Federal Withholding $27l.8 Social Security ~25.00 Local VVage Tax $16.42 State Income Tax $ 45.9 Retirement $ 82. 08 Savings Bonds Lo- Credit Union $ -0- Life Insuran<:e Lo- Health Insurance Lo- Other Deductions (specify) Support Order-PA $+15.38 Bnion Dues $ 23.65 Net Pay per Pay Period $ 654.68 Service Type M' Form IN-GOS Worker ID 21205 !~,~ , , , . Income and Expense Statement , . PACSES Case Number 348100635 OTHER (Fill in Appropriate Column) INCOME WEEK MONTH YEAR Interest $ $ $ Dividends Pension Annuity Social Security Rents . RoYalties - - - . Expense Account Gifts UDCIIIployment Compensation Workmen's Compensation IRS Refund Other Other TOTAL $ $. $ TOTAL INCOME $ (Fill in Appropriate Column) EXPENSES WEEK MONTH YEAR Home MortgagelRent $ $320.78 $ Maintenance ?~ /1/1 Utilities Electric 40.00 Gas Oil 77 .67 Telephone 67.19 . Service Type M Page 2 of 6 Form IN-008 Worker ID 21205 - . . "U "~ .~~._,-"." , I ncome and Expense Statement PACSES Case Number 348100635 (Fill in Appropriate Column) EXPENSES (continued) WEEK MONTH YEAR Water $ $ $ Sewer Employment . PublicTIllIISpOftation $ $ $ Lunch . - - . . Taxes. Real Estate $ $ 31.25 $ Personal Property 41. 66 Income Insurance Homeowners $ $ 16.00 $ Automobile 1;1 nn Life Accident Health Other - Automobile Payments $ $157.80 $ Fuel 11;n nn Repairs 41. 50 Medical Doctor $ $ 16.20 $ Dentist , Onhodontist Page 3 of6 Fonn IN-008 Worker 10 21205 Service Type M Ii ~ ~~, _ _ ,-.""~~ _" i _ ~_ Income and Expeuse Statement . PACSES Case Number 348100635 (Fill in Appropriate Column) EXPENSES (continued) WEEK MONTH YEAR Hospital Medicine . Special needs (glasses, braces, orthopedic devices) Education . Private School $ $ $ Parochial School . . College Religious Personal Clothing .. $ $ 50 . 00 $ Food ,nn nn BarberlHairdresser 5.00 Credit Payments: Credit Card Charge Account 623.50 Memberships Loans - Credit Union $ $ $ Miscellaneous Household Help $ $ $ Child Care PaperslBooks/Magazine Entertainment Pay TV '\11.59 Vacation Page 4 of 6 Form IN-OOB Worker ID 21205 Service Type M '" Income and Expense Statement PACSES Case Number 348100635 (Fill In Appropriate Column) EXPENSES WEEK (continued) MONTH YEAR Gifts Legal Fees 150.00 Charitable Contributions Other Child Support Alimony Payments Other - , $ $ $ TOTAL EXPENSES $ $ $ PROPERTY Ownership * OWNED DESCRIPl'ION VALUE H W J Checking Accounts $ 23.00 X Savings Accounts ?? 1\1\ v Credit Union StockslBonds Real Estate . $9_ 000;00 X Other "".TI\ ~ "" '''''' "" X TOTAL $ INSURANCE COMPANY POLICY # Coverage * H W C Hospital BLUE r.RI\S" 94000000/;lS61 X Blue Cross Other Medical 1>,n" Blue Shield ~4())\>>!l!l())())())865 X Other * .' H - Husband W - WIfe C - Combmed J - Jomt Page 5 of 6 Form IN-008 Worker ID 21205 Service Type M i~" ,"_ ,~ ^ [ncome and !'lxpense Statement PACSES Case Number 348100635 Coverage . INSURANCE COMPANY POLICY # H W C Healthl Accident Disability Income Dental DRLTA DENTAL 03015-00001 x Other PEBTF VISION 013 02000 18250 6611 X * H - Husband W - Wife C - Combined J - Joint SUDDlemental Income Statement - . 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 jomt 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 sunilar 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 number: d. Nature of business (check one) (1) partnership (2) joint venture (3) profession (4) closed corporation (5) other e. Name of accountant, controller or other person in charge of financial records: f. Annual income from business: (1) How often is income received? (2) Gross income per pay period: (3) Net income per pay period: (4) Specified deductions, if any: Page 6 of 6 Form IN-008 Worker ID 21205 Service Type M APPRAISAL REPORT OF A SINGLE-FAMILY DWELLING I I I , I I I I I I I I I I LOCATED AT 46 NORTH EAST STREET CARLISLE, PENNSYLVANIA PREPARED FOR LARRY E. GOSSARD AS OF NOVEMBER 10, 2000 BY LARRY E. FOOTE DIVERSIFIED APPRAISAL SERVICES 35 EAST HIGH STREET, SUITE 101 CARLISLE, PENNSYLVANIA 17013 (717) 249-2758 1!V{!,__lf__u,__ ..."-",- , . SUMMARY OF IMPORTANT FACTS AND CONCLUSIONS LOCATION: 46 North East Street Carlisle, Pennsylvania TAX PARCEL NUMBER: 02-21-0318-280 PROPERTY RIGHTS: Fee simple interest. OWNERSHIP HISTORY: The subject property is presently deeded to Larry E. Gossard and Sheri L. Gossard. The property was purchased on July 22, 1996 for a reported consideration of $45,000 and ownership transferred on Deed Book 143, Page 91. SCOPE OF THE ASSIGNMENT: The scope of the assignment in- cluded an analysis of the sub- ject's area, an inspection of the subject property, an estimation of the property's highest and best use, consideration of all three approaches to value, and the application of those relevant to the valuation of the subject. OBJECTIVE: To estimate the market value of the subject property as unencumbered. EFFECTIVE DATE: As of November 10, 2000. HIGHEST AND BEST USE: Use as a single-family residence. COST APPROACH: $58,000 SALES COMPARISON APPROACH: $59,000 INCOME APPROACH: N.A. FINAL VALUE CONCLUSION: $59,000 2 'i)~::'," ~- - ,,,",,_n --7" ., APPRAISAL CERTIFICATE I hereby certify that upon application for valuation by: LARRY E. GOSSARD the undersigned personally inspected the following described property: All that certain tract of thereon erected, situate in the Carlisle, Cumberland County, described as follows: land, with the improvements First Ward of the Borough of Pennsylvania, bounded and Beginning at a point on the western line of 60 feet wide North East Street in the center line of 3 feet wide private alleyway between properties Nos. 46 and 48 North East Street, said line also coinciding with the center line of the partition wall on the second floor level between the two and one-half story dwellings known as Nos. 46 and 48 North East Street, which point at the place of beginning is l23.50 feet south of the southern line of 60 feet wide East Louther Street measured along the western line of said 60 feet wide North East Street; thence from said nail at the place of beginning along the western line of said 60 feet wide North East Street, South l8 degrees lO minutes West a distance of l7.40 feet to a quarter-inch drill hole in the center line of the partition wall between properties Nos. 44 and 46 North East Street; thence through the center of said partition wall between properties Nos. 44 and 46 North East Street and beyond, North 7l degrees 50 minutes West, a distance of 85.67 feet to a post on the eastern line of a l5 feet wide private alley; thence along the eastern side of said l5 feet wide private alley, Nofth l8 degrees lO minutes East, a distance of l7.40 feet to a post at corner of land~ now or formerly of Andrew Thalhofer; thence along said land now or formelry of Andrew Thalhofer; thence along said land now or formerly of Andrew Thalhofer, and passing through the center line of a three feet wide private alleyway between properties Nos. 46 and 48 North East Street, said line also coinciding with the center line of the partition wall on the second floor level between the two and one-half story dwelling houses known as Nos. 46 and 48 North East Street, South 7l degrees 50 minutes East, a distance of 85.67 feet to a nail on the western line of 60 feet wide North East Street, the place of beginning. To the contained in neither the compensation best of my knowledge and belief the statements this report are. true and correct, and that employment to make this appraisal nor the is contingent upon the value reported, and that 3 <'-'".~~--',- ~" ," - '-,~- ~,- ,- -< - , I I I I I I I I I I I I I I I I I I I I ~~,' . 0_ in my opinion the Market Value as of November 10, 2000 is: FIFTY-NINE THOUSAND DOLLARS $59,000 The property was appraised as a whole, subject to the contingent and limiting conditions outlined herein. ..,.~" ,.'J,'Y}1 '1 -~-;~.. ,::Y"'.,-"'~~, ,!:2Q~~!:)_. ..l~J \-~ s-' ~ '.\ :;- '''' '-7',_ ~~;':c :: ,,- ~' ~d" ;~ ::.4 ~r;;, ~ ",>1 ., ::!If" ..... ,. :;,~ :~ :.\~ <~ -;:.: "'_\"~ ~ / '~v.":, ";:Z.:~/ '\:{/' ':;'\,f't."." ~ ". ";?:':/i7i~ -! .~.~,~, ::.~j>: '"~~ilJ~9\( ..>~,. ~.i~l~'~' 4 ~~ '--, ~~~ Certified General Appraiser GA-000014-L PURPOSE OF THE APPRAISAL The purpose of this appraisal is to estimate the Market Value of the subject property as of November 10, 2000. Market Value, as defined by the courts, is the most probable price estimated in terms of money which a property will bring if exposed for sale in the open market, allowing a reasonable time finding a purchaser who buys with knowledge of all the uses to which it is adapted and for which it is capable of being used. Frequently, it is referred to as the price at which a willing seller would sell and a willing buyer would buy, neither being under abnormal pressure. HIGHEST AND BEST USE Highest and Best Use is defined by the Appraisal Terminology and Handbook, published by the Appraisal Institute, as "the most profitable likely use to which a property can be put". The opinion of such use may be based on the highest and most profitable continuous use to which the property 1S adapted and needed, or likely to be in demand, in the reasonable near future. However, elements affecting value that depend upon events or a combination of occurrences which, while within the realm of possibility, are not fairly shown to be reasonably probable, should be excluded from consideration. Also, if the intended use is dependent on an uncertain act of another person, the intention cannot be considered. Based on neighborhood, of the subject the above definition and after seeing the site, and area, it is my opinion that the present use is its Highest and Best Use. 5 "7'''" ~~~ ~ ,__ SITE DATA ADDRESS: 46 North East Street BOROUGH: Carlisle COUNTY: Cumberland STATE: Pennsylvania LOT SIZE: 17.4' x 85.67' SEWERS: Public utility WATER: Public utility ELECTRICITY: PP&L LANDSCAPING: Typical for the area, with a small rear lawn. DETRIMENTAL INFLUENCES None. Pride of ownership is evident throughout the neighborhood. DESCRIPTION OF IMPROVEMENTS GENERAL DESCRIPTION: Two-story dwelling containing approximately living area. atttached single-family 1,736 square feet of gross CONDITION: Exterior: Average Interior: Fair ROOMS: First Floor: Living room, dining room, kitchen, family room and one-half bathroom. Second Floor: Three bedrooms and a full bathroom. Basement: Full, with concrete floor. EXTERIOR: Foundation: Walls: Sash: Gutters: Roof: Storm units: Stone Vinyl siding over brick. Wood-framed. Aluminum, painted. Metal Combination throughout. 6 ~,-" '"'. < - ~ , "",,- Trim: Carpet, vinyl and painted wood. Plaster Plaster and suspended acoustical tile blocks. Wood, painted. INTERIOR, PRINCIPAL ROOMS: Flooring: Walls: Ceilings: KITCHEN: Cabinets: Counters: Walls: Flooring: Sink: Wood, natural finish. Formica Plaster, painted. Vinyl Double-bowl, stainless steel. BATHROOM: Flooring: Vinyl Walls: Plaster, painted. Bathtub: Built-in, with shower. Lavatory: Vanity Water closet: Two-piece Medicine cabinet: Wall-mounted CONSTRUCTION: Joists: Beams: Plumbing: Wood Wood Iron and copper. HEATING: Forced hot air, oil-fired. (Approximately 3 years old) HOT WATER: Electric, 50-gallon. ELECTRIC: Circuit breaker system, 200-ampere, with modern wiring. OTHER: There is the dwelling, and the dwelling. a concrete stoop located at the front of a porch and balcony located at the rear of GENERAL CONDITION: The improvements are considered to be in fair condition on the interior and average condition on the exterior. The vinyl flooring in the kitchen is torn; the kitchen walls and ceiling are in need of painting; the first floor family room has been drywalled, but the seams need sanded and the room needs painted; and there are holes in two of the bedroom walls. According to the property owner, the roof is in need of repair, but no leaks were observed during the inspection. 7 ~,l, '~f'- --:""-:" ---,' THE COST APPROACH The Cost Approach to value is based on the principle of substitution, which proposes that an informed buyer will pay no more than the cost of providing a substitute property with similar utility. ' In estimating the cost of providing a substitute, the following functions are completed. . The cost of the improvements, as if new, is estimated. Loss of value due to physical deterioration, functional obsolescence and external depreciation, if applicable, is deducted to represent the cost of a substitute depreciated. The land and the value of depreciated site improvements is added to obtain a value indication of the real estate. The cost new of the information from Marshall local area and verified with improvements was Valuation Service, local contractors. estimated using adjusted to the Dwelling: 1,736 sq. ft. @ $42.85 = Basement: 688 sq. ft. @ $12.53 = Porches, patios, etc.: Total Estimated Cost New: Depreciation: Depreciated Cost of Improvements: Site Improvements "as is": Estimated Site Value: Indicated Value by Cost Approach: Rounded to: $74,388 8,621 1.680 84,689 -42.345 42,344 1,000 15.000 $58,344 $58,000 8 ',_, ~. _ v ,_. <, _ ~. _ , SALES COMPARISON APPROACH In arriving at this conclusion of the value of the subject property, the appraiser made a survey of properties that have sold in the area of the subject property. Consideration was given and adjustments were made on each comparable sale as to time of sale, size, location, as well as all other factors that might affect value. A resume of some of the sales considered by the appraiser is as follows: SALE NO.1 Location: Date of Sale: Sale Price: Size: Unit Price: SALE NO.2 Location: Date of Sale: Sale Price: Size: Unit Price: SALE NO.3 Location: Date of Sale: Sale Price: Size: Unit Price: 19 N. East Street, Carlisle, Pa. August 30, 2000. $55,000 1,064 sq. ft. $51.69 per sq. ft. 214 N. East Street, Carlisle, Pa. September 15, 2000. $55,000 912 sq. ft. $60.31 per sq. ft. 416 N. East Street, Carlisle, Pa. August 30, 1999. $53,900 1,096 sq. ft. $49.18 per sq. ft. The appraiser, in addition to the sales listed, also considered several additional sales in arriving at his final opinion of value. After making all of the necessary adjustments, it is the appraiser's considered opinion that the indicated value of the subject property by the Sales Comparison Approach is $59,000. ~ - , -- ~- ,_,_ 'u_,~~~,' 9 . , ~ CORRELATION Correlation may be defined as "the bringing together of parts in a proper relationship." The parts of this appraisal report are the following approaches to value your appraiser used: Value Indicated by Cost Approach Value Indicated by Sales Comparison Approach $58,000 $59,000 These approaches are representative of the market value of the subject property. I have carefully reexamined each step in each method, and I believe the conclusions accurately reflect the attitude of typical purchasers of this type property in this neighborhood. It is my belief that this reexamination has confirmed the original conclusions. The Cost Approach will result in an excellent estimate if all elements are figured accurately, because no prudent person will pay more for a property than the cost to produce a substitute property with equal desirability and utility. Purchasers of the type of dwelling typical of the subject property are more concerned with amenities than with hypothetical replacement of the property. The value of the cost approach is not disregarded, but given less weight because more errors in judgement can be made in this approach. The Sales Comparison Approach was based on several recent sales of properties similar to that of the subject, all of which are located in the same general area. The adjusted sales prices are most consistent under comparison. This approach is the most reliable because it reflects the reactions of typical buyers and sellers in the market. Therefore, as a result of this appraisal and analysis, it is this appraiser's considered judgement and opinion that the Market Value of the subject property, as of November 10, 2000, is: FIFTY-NINE THOUSAND DOLLARS $59,000 10 i ~,"___ _'.""""" '._.' "__ . l UNDERLYING ASSUMPTIONS AND LIMITING CONDITIONS SUBJECT TO THIS APPRAISAL 1. I assume no responsibility for matters legal in nature, nor do I render any opinion as to the title, which is assumed to be marketable. The property is a~raised as though under responsible ownership. 2. The legal description used herein is correct. 3. I have made no survey of the property, and the boundaries are taken from records believed to be reliable. 4. I assume that there are no hidden or unapparent conditions of the property, subsoil or structures which would render it more or less valuable. I assume no responsibility for such conditions or for engineering which might be required to discover such factors. 5. The information, estimates, and op1n10ns furnished to me and contained in this report were obtained from sources considered reliable and believed to be true and correct. However, no responsibility for accuracy can be assumed by me. 6. This report is to be used in its entirety and only for the purpose for which it was rendered. 7. Neither all nor any part of the contents of this report (especially any conclusions as to value, the identity of the appraiser or the firm with which he is connected) shall be reproduced, published, or disseminated to the public through advertising media, public relations media, news media, sales media, or any other public means of communication, without the prior written consent and approval of the appraiser. 8. This appraisal was prepared for the exclusive use of the client identified on page five of this appraisal report. The information and opinions contained in this appraisal set forth the appraiser's .best judgement in light of the information available at the time.of the preparation of this report. Any use of this appraisal by any other person or entity, or any reliance or decisions based on this appraisal are the sole responsibility and at the sole risk of the third party. The appraiser accepts no responsibility for damages suffered by any third party as a result of reliance on or decisions made or actions taken based on this report. 11 . i CERTIFICATE OF APPRAISAL Your appraiser hereby certifies that: 1. The statements of fact contained in this report are true and correct. 2. The reported analyses, opinions, and conclusions are limited only by the reported assumptions and limiting conditions, and are my personal, impartial, and unbiased professional analyses, opinions, and conclusions. 3 . that with I have no present or prospective is the subject of this report, respect to the parties involved. interest in the property and no personal interest 4. 1 have subject of assignment. no bias with respect to the property that is the this report or to the parties involved with this 5. My engagement in this assignment was not contingent upon developing or reporting predetermined results. 6. My compensation for completing this assignment is not contingent upon the development or reporting of a predetermined value or direction in value that favors the cause of the client, the amount of the value opinion, the attainment of a stipulated result, or the occurrence of a subsequent event directly related to the intended use of this appraisal. 7. To the best of my knowledge and belief, the statements of fact contained in this appraisal report, upon which the analyses, opinions, and conclusions expressed herein are based, are true and correct. 8. This appraisal report sets forth all of the limiting conditions (imposed by the terms of my assignment or by the undersigned) affecting the analyses, opinions, and conclusions contained in this report. 9. This appraisal report has been made in conformity with the Uniform Standards of Professional Appraisal Practice adopted by the Appraisal Standards Board of the Appraisal Foundation, and is subject to the requirements of the Code of Professional Ethics and Standards of Professional Conduct of the National Association of Real Estate Appraisers. 12 10. No one other. than the undersigned prepared the analyses, conclusions, and opinions concerning real estate that are set forth in this appraisal report. Y~7?~ Larry E. Foote Certified General Appraiser GA-000014-L 13 -"".., ," ~ -- ,-,- - , ~ SALES COMPARISON ANALYSIS These recent sa~_of properties are most similar. and proximate 10 subject and have been considered in the mark~t analysis. The descriplion includes a dollar adlustment reflecting market reaction tQlhose ilems ol.sig.nificanl variation between the sub!ect SI'),", cOmParable properties. If a significanl item in fhe comparable proPMy is superioc to. or rrrOre favorable than, the subject property, a minus (-) adjustment is made. thus reducing the indicated value of SUbject; if a significant item in the comparable is inferior to, or less favorable Ihan, the subject property, a plus (+) adjustment is made, thus increasing the indic<;lted value ollhe subject . Address Proximity to Subject Sales Price Price/Gross liv. Area Data Source VALUE ADJUSTMENTS Sales or Financing Concessions Date of Sale/Time location Site/View Desi n and Appeal Juality of Construction '.ge ;ondilion ";bove Grade loom Count .ross_living Area 'asement & Finished looms Below Grade iJnctional Utility ;aating/Coollng "age/Carport ~.t,;l1es. Patio, ;)OJs-. etc. 'leCial Energy ilcleill Items replac_e(s) c',., (e.g, kitchen !uip., remodeling) t Adj. (total) :l:iCdted Value Subject ~lffimeilts on Market Data ales co rison anal sis and ITEM 'l}11 SUBJECT 46 N. Eapt Carlisle CDMPARABLE ND. 2 214 N. East Street Carlisle 2 blocks CDMPARABLE NO, 3 416 N. East Street Carlisle 4 blocks . (.)5 Adluslmenl (2,000) 1,600 5 500 5 400) 5 500 Total I Bdrms I BalM 7 '3' I' 1 736 Sq. Ft. Tolal I BdffilS I Baths 5 ' 2' 1 1,064 -Sq. Ft, : I Sdlms I Baths 5 '2 '1 91.2 Sq. Ft. : I Bdlms I Balhs 5,000 13 400 5,000 16 500 5 '2 'l 5,000 1 096 Sq. Ft. : 12 800 Full bsmt. Avera e' Oil FHA None Stoop, porch, balcon . Typical for the r ion. None PartiallY remodeled. similar Similar Similar similar Similar Similar Similar Similar Similar similar Similar -: 2-car ara e 5 000 Stoop,cov. ~tio, 500 encl. rch.: 500 , : similar ~ Similar Similar Two stoo s Similar Similar' Similar similar , , " , ,. , 2 000 13 500 Remodeled $ fa .11 I $ 68,500 sales are acce table for of value of 59 000. 50,400 direct U.S. FORM$INC..;2 CEN.JRAF ~() r.;~""-1=T"""1 "... n."'....". ".. . ., -':. ~:'~:"':~:'i:~:': .- . -,.,:,:;::i~:i::*~~~::1:::f~~>{ , ':'\~~~?J':J!:':j-;'::'.'''~:N..l''; ..J~:::C::;;;I-- ::~ ~ .~:"_.,...__...._-. "-. ~~--. -~_::=:::=:::=:::::, ...~=:::::~ -^~---_..-.._._-~ ---"-_.._----) PHOTOGRAPHS OJ;' THE SI1B.:rF;C~r PROpmny LARRY E. FOOTE REAL ESTATE APPRAISER EXPERIENCE: 1979-Present: Chief Appraiser, Diversified Appraisal Services, Carlisle, Pa. Principal Broker, LaRue Development Co., Carlisle, Pa. 1976-1979: Associate Broker, Colonial Realty, Carlisle, Pa. 1972-1976: Realtor Associate, Jack Gaughen Realtor, Carlisle, Pa. Appraisal experience includes undeveloped land, farms, building lots, single-family dwellings, mobile home parks, medical centers, motels, apartment buildings and complexes, office buildings, service stations, veterinary clinics, rehabilitation centers, retail buildings, daycare centers, warehouses, and manufacturing facilities. EDUCATION: Bachelor of Business Administration, Pennsylvania State University, 1976. Associate Bachelor of Business Administration, Harrisburg Area Community College, 1974. Diploma, Carlisle Senior High School, 1965. Certificate, Pennsylvania Realtors Institute, GRI I, GRI II, GRI III. Certificate, Realtors National Marketing Institute, CI 101, CI 102, CI 103, CI 104, Cl105. Standards of Professional Practice,. American Institute of Real Estate Appraisers, Real Estate Appraisal Principles, American Institute of Real Estate Appraisers. Appraisal Procedures, Appraisal Institute. Residential Valuation, American Institute of Real Estate Appraisers. Principles of Income Property Appraising, Appraisal Instilule. Case Studies in Real Estate Valuation, Appraisal Institute. Report Writing and Valuation Analysis, Appraisal Institute PROFESSIONAL LICENSES: General Appraiser UGA-OOOOI4-L, Commonwealth of Pennsylvania. Real Estate Broker #RB-029729-A, Commonwealth of Pennsylvania. PROFESSIONAL DESIGNATIONS: GRI: Graduate of the Pennsylvania Realtors Institute, awarded by the Pennsylvania Association of Realtors. CRS: Certified Residential Specialist, awarded by the Realtors National Marketing Institute of the National Association of Realtors. CCIM: Certified Commercial Investment Member, awarded by the Realtors National Marketing Institute of the National Association of Realtors. PROFESSIONAL ORGANIZATION AFFILIATIONS: National Association of Realtors Appraisal Section. Carlisle Association of Realtors. Pennsylvania Association of Realtors. National Association of Realtors. Realtors National Marketing Institute. - PAST CLIENTS: Borough of Carlisle Keystone Financial Mortgage Cornerstone Federal Credit Union Pennsylvania State Bank Commerce Bank Harris Savings Bank Dauphin Deposit Bank Cumberland-Perry County Association for Retarded Citizens Carlisle Suburban Authority Commonwealth National Bank Pennsylvania National Bank Evans Financial Corporation Greenawalt & Company, CPA Smith's Transfer Corporation Carlisle Department of Parks and Recreation Farmers Trust Company Carlisle Area School District Messiah Homes, Incorporated ERA Eastern Regional Services Cumberland Valley Savings & Loan Association Chase Home Mortgage Corporation Defense Activities Federal Credit Union Pennsylvania State Employees Credit Union Meridian Bank B-H Mortgage Service Corporation Friendly Mortgage Services United Telephone Employees Federal Credit Union Cumberland County Commissioners' Allstate Enterprises Mortgage Corporation Dickinson College PPG Industries, Incorporated Gettysburg College Redevelopment Authority of Cumberland County Record Data Appraisal Service, Incorporated First United Federal Savings Association Washington Telephone Federal Credit Union Hill Financial Carlisle Building & Loan Association Sears Mortgage Corporation Provident Home Mortgage Corporation Fulton Bank United states Marshall Service Central Pennsylvania Savings Association Coldwell Banker Relocation Services, Inc. Maenner Relocation, Inc. CCNB Bank, N.A. GMAC Morgage Corp. First Bank and Trust Company Mellon Bank Orrstown Bank Letterkenny Federal Credit Union BancPlus Mortgage Corp. Various law firms and individuals " ~-~~.~ " -- -,-""" I I I I I I I I I I I I I ,,> -"" APPRAISAL REPORT OF A SINGLE-FAMILY DWELLING LOCATED AT . 48 NORTH EAST STREET CARLISLE, PENNSYLVANIA PREPARED FOR LARRY E. GOSSARD AS OF NOVEMBER 10, 2000 BY LARRY E. FOOTE DIVERSIFIED APPRAISAL SERVICES 35 EAST HIGH STREET, SUITE 101 CARLISLE, PENNSYLVANIA 17013 (717) 249-2758 '" SUMMARY OF IMPORTANT FACTS AND CONCLUSIONS LOCATION: TAX PARCEL NUMBER: 48 North East Street Carlisle, Pennsylvania 02-21-0318-281 Fee simple interest. The subject property is presently Zimmerman. The property was purchased on a reported consideration of $35,000 and on deed reference 35-S-1144. PROPERTY RIGHTS: OWNERSHIP HISTORY: deeded to John K. June 24, 1992 for ownership transferred SCOPE OF THE ASSIGNMENT: OBJECTIVE: EFFECTIVE DATE: HIGHEST AND BEST USE: COST APPROACH: The scope of the assignment in- cluded an analysis of the sub- ject's area, an inspection of the subject property, an estimation of the property's highest and best use, consideration of all three approaches to value, and the application of those relevant to the valuation of the subject. To estimate the market value of the subject property as unencumbered. As of November 10,.2000. Use as a single-family residence. $62,000 INCOME APPROACH: SALES COMPARISON APPROACH: $57,000 FINAL VALUE CONCLUSION: N.A. $57,000 2 APPRAISAL CERTIFICATE I hereby certify that upon application for valuation by: LARRY E. GOSSARD the undersigned personally inspected the following described property: All that certain tract of thereon erected, situate in Cumberland County, Pennsylvania, follows: land, with the improvements the Borough of Carlisle, bounded and described as Beginning at a point on the Western line of North East Street in the center line of the partition wall between properties Nos. 48 and 50 North East Street; thence in a Westerly direction through the center of said partition wall and beyond 85 feet 8 inches to a point; thence in a Southerly direction along a line parallel with North East Street, 18 feet to a point; thence in an Easterly direction along a line at right angles with North East Street and passing through the center line of a 3 feet wide private alleyway between properties Nos. 46 and 48 North East Street, said line also coinciding with the center line of the partition wall on the second floor level between the 2 1/2 story brick dwellings known as Nos. 46 and 48 North East Street, a distance of 85 feet 8 inches to North East Street; thence in a Northerly direction along the Western line of North East Street 18 feet, more or less, to the point or place of beginning. To the contained in neither the compensation in my opinion best of my knowledge and belief the statements this report are true and correct, and that employment to make this appraisal nor the is contingent upon the value reported, and that the Market Value as of November 10, 2000 is: FIFTY-SEVEN THOUSAND DOLLARS $57,000 The property was appraised as a whole, subject to the contingent and limiting conditions outlined herein. ../:y:'>Jt::i':"1j,:::',\ .'/~) .~ .;94'/; . _;' ".v ~,<.~1~: ; ,,.~ 0' ,s0J ""',. _.; ':';: l':} ....;.: '~",. -:? \~" ,0,' ~ ~;:<< ";:'", ::;y/;\,,,,\)\ --;,~{'.I" "~~'t';~~fitC-"j:.>; ~ @~oote Certified General Appraiser GA-000014-L 3 ~''':=_' .~- PURPOSE OF THE APPRAISAL The purpose of this appraisal is to estimate the Market Value of the. subject property as of November 10, 2000. Market Value, as defined by the courts, is the most probable price estimated in terms of money which a property will bring if exposed for sale in the open market, allowing a reasonable time finding a purchaser who buys with knowledge of all the uses to which it is adapted and for which it is capable of being used. Frequently, it is referred to as the willing seller would sell and a willing neither being under abnormal pressure. price at which a buyer would buy, HIGHEST AND BEST USE Highest and Best Use is defined by the Appraisal Terminology and Handbook, published by the Appraisal Institute, as "the most profitable likely use to which a property can be put". The opinion of such use may be based on the highest and most profitable continuous use to which the property ~s adapted and needed, or likely to be in demand, in the reasonable near future. However, elements affecting value that depend upon events or a combination of occurrences which, while within the realm of possibility, are not fairly shown to be reasonably probable, should be eXCluded from consideration. Also, if the intended use is dependent on an uncertain act of another person, the intention cannot be considered. Based on neighborhood, of the subject the above definition and after seeing the site, and area, it is my opinion that the present use is its Highest and Best Use. 4 - ~-"'- --.~.. "-,-" ~, c'_ ~, _ , SITE DATA ADDRESS: 48 North East Street BOROUGH: Carlisle COUNTY: Cumberland STATE: Pennsylvania LOT SIZE: 18' x 85'8" SEWERS: Public utility WATER: Public utility ELECTRICITY: PP&L LANDSCAPING: Typical for the area, with a sodded rear lawn. DETRIMENTAL INFLUENCES None. Pride of ownership is evident throughout the neighborhood. DESCRIPTION OF IMPROVEMENTS GENERAL DESCRIPTION: Two-story dwelling containing approximately living area. attached single-family 1,272 square feet of gross CONDITION: Exterior: Average Interior: Good ROOMS: First Floor: Living room with dining area, kitchen and toilet room. Second Floor: Three bedrooms and a full bathroom. Basement: Full, with concrete floor. EXTERIOR: Foundation: Walls: Sash: Gutters: Roof: Storm units: Stone Briick and vinyl siding over brick. Wood, double-hung. Aluminum, painted. Metal Combination throughout. 5 11 .~-- "--- -,., , INTERIOR, PRINCIPAL ROOMS: Flooring: Hardwood, carpet and vinyl. Plaster Plaster Wood, painted. Walls: Ceilings: Trim: KITCHEN: Cabinets: Counters: Walls: Flooring: Sink: Wood, natural finish. Formica Plaster, painted. Vinyl Double-bowl, stainless steel. BATHROOM: Flooring: Vinyl Walls: Plaster and vinyl. Bathtub: Built-in, with shower. Lavatory: Vanity Water closet: Two-piece Medicine cabinet: Wall-mounted CONSTRUCTION: Joists: Beams: Columns: Plumbing: Wood Wood Wood Iron, plastic and copper. HEATING: Forced hot air, gas-fired. HOT WATER: Gas-fired, 3D-gallon. ELECTRIC: Circuit breaker system, lOO-ampere, with modern wiring. OTHER: There is a concrete stoop located at the front of the dwelling, and a concrete patio and balcony located at the rear of the dwelling. GENERAL CONDITION: The improvements are considered to be in good condition on the . interior and average condition on the exterior. According to the property owner, the roof is in need of repair, but no leaks were observed during the inspection. 6 f I t I. i . ~ , ~ -,"-- , "-'''<~ " THE COST APPROACH The Cost Approach to value is based on the principle of substitution, which proposes that an informed buyer will pay no more than the cost of providing a substitute property with similar utility. In estimating the cost of providing a substitute, the following . functions are completed. The cost of the improvements, as if new, is estimated. Loss of value due to physical deterioration, functional obsolescence and external depreciation, if applicable, is deducted to represent the cost of a substitute depreciated. The land and the value of depreciated site improvements is added to obtain a value indication of the real estate. The cost new of the information from Marshall local area and verified with improvements was Valuation Service, local contractors. estimated using adjusted to the Dwelling: 1,272 sq. ft. @ $42.85 = Basement: 636 sq. ft. @ $12.53 = Porches, patios, etc.: Total Estimated Cost New: Depreciation: Depreciated Cost of Improvements: Site Improvements "as is": Estimated Site Value: Indicated Value by Cost Approach: Rounded to: 7 ,c-~<;(, , ",~" ",,. , 'r> , , $54,505 7,969 2.520 64,994 -19.489 45,505 1,000 15.000 $61,505 $62,000 SALES COMPARISON APPROACH In arriving at this conclusion of the value of the subject property, the appraiser made a survey of properties that have sold in the area of the subject property. Consideration was given and adjustments were made on each comparable sale as to time of sale, size, location, as well as all other factors that might affect value. A resume of some of the sales considered by the appraiser is as follows: SALE NO.1 Location: Date of Sale: Sale Price: Size: Unit Price: SALE NO.2 Location: Date of Sale: Sale Price: Size: Unit Price: SALE NO.3 Location: Date of,Sale: Sale Price: Size: Unit price: 19 N. East Street, Carlisle, Pa. August 30, 2000. $55,000 1,064 sq. ft. $51.69 per sq. ft. 214 N. East Street, Carlisle, Pa. September 15, 2000. $55,000 912 sq. ft. $60.31 per sq. ft. 416 N. East Street, Carlisle, Pa. August 30, 1999.' $53,900 1,096 sq.ft. $49.18 per sq. ft. The appraiser, in addition to the sales listed, also considered several additional sales in arriving at his final opinion of value. After making all of the necessary adjustments, it is the appraiser's considered opinion that the indicated value of the subject property by the Sales Comparison Approach is $57,000. c ~_1'_', ,'" " .-_e. _. 8 0' I' CORRELATION parts report used: Correlation may be defined as "the bringing together of in a proper relationship." The parts of this appraisal are the following approaches to value your appraiser Value Indicated by Cost Approach Value Indicated by Sales Comparison Approach $62,000 $57,000 These approaches are representative of the market value of the subject property. I have carefully reexamined each step in each method; and I believe the conclusions accurately reflect the attitude of typical purchasers of this type property in this neighborhood. It is my belief that this reexamination has confirmed the original conclusions. The Cost Approach will result in an excellent estimate if all elements are figured accurately, because no prudent person will pay more for a property than the cost to produce a substitute property with equal desirability and utility. Purchasers of the type of dwelling typical of the subject property are more concerned with amenities than with hypothetical replacement of .the property. The value of the cost approach is not disregarded, but given less weight because more errors in judgement can be made in this approach. The Sales Comparison Approach was based on .several recent sales of properties similar to that of the subject, all of which are located in the same general area. The adjusted sales prices are most consistent .under comparison. This approach is the most reliable because it reflects the reactions of typical buyers and sellers in the market. Therefore, as a result of this appraisal and analysis, it is this appraiser's considered judgement and opinion that the Market Value of the subject property, as of ~ovember 10, 2000, is: FIFTY-SEVEN THOUSAND DOLLARS $57,000 9 .~- ~ ,~ UNDERLYING ASSUMPTIONS AND LIMITING CONDITIONS SUBJECT TO THIS APPRAISAL 1. I assume no responsibility for matters legal in nature, nor do I render any opinion as to the title, which is assumed to be marketable. The property is appraised as though under responsible ownership. 2. The legal description used herein is correct. 3. I have made no survey of the property, and the boundaries are taken from records believed to be reliable. 4. I assume that there are no hidden or unapparent conditions of the property, subsoil or structures which would render it more or less valuable. I assume no responsibility for such conditions or for engineering which might be required to discover such factors. 5. The information, estimates, and op2n2ons furnished to me and contained in this report were obtained from sources considered reliable and believed to be true and correct. However, no responsibility for accuracy can be assumed by me. 6. This report is to be used in its entirety and only for the purpose for which it was rendered. 7. Neither all nor any part of the contents of this report (especially any conclusions as to value, the identity of the appraiser or the firm with which he is connected) shall be reproduced, published, or disseminated to the public through advertising media, public relations media, news media, sales media, or any other public means of communication, without the prior written consent and approval of the appraiser. 8. This appraisal was prepared for the exclusive use of the client identified on page five of this appraisal report. The information and opinions contained in this appraisal set forth the appraiser's best judgement. in light of the information available at the time of the preparation of this report. Any use of this appraisal by any other person or entity, or any reliance or decisions based on this appraisal are the sole responsibility and at the sole risk of the third party. The appraiser accepts no responsibility for damages suffered by any third party as a result of reliance on or decisions made or actions taken based on this report. 10 CERTIFICATE OF APPRAISAL Your appraiser hereby certifies that: 1. The statements of fact contained in this report are true and correct. 2. The reported analyses, oplnlons, and conclusions are limited only by the reported assumptions and limiting conditions, and are my personal, impartial, and unbiased professional analyses, opinions, and conclusions. 3. that with I have no present or prospective is the subject of this report, respect to the parties involved. interest in the property and no personal interest 4. I have subject of assignment. no bias with respect to the property that is the this report or to the parties involved with this 5. My engagement in this assignment was not contingent upon developing or reporting predetermined results. 6. My compensation for completing this assignment is not contingent upon the development or reporting of a predetermined value or direction in value that favors the cause of the client, the amount of the value opinion, the attainment of a stipulated result, or the occurrence of a subsequent event directly related to the intended use of this appraisal. 7. To the best of my knowledge and belief, the statements of fact contained in this appraisal report, upon which the analyses, opinions, and conclusions expressed herein are based, are true and correct. '" , 8. This appraisal report sets forth all of the limiting conditions (imposed by the terms of my assignment or by the undersigned) affecting the analyses, opinions, and conclusions contained in this report. i: i. 9. This appraisal report has been made in conformity with the Uniform Standards of Professional Appraisal Practice adopted by the Appraisal Standards Board of the Appraisal Foundation, and is subject to the requirements of the Code of Professional Ethics and Standards of Professional Conduct of the National Association of Real Estate Appraisers. !.: " ). -~ . 11 "~ .,' j<<;' < ~"" ~.__." ~~ ,,'I!-- ~!<:",. 1 0 . No one conclusions, forth in this , ,-, other than the undersigned prepared the analyses, and opinions concerning real estate that are set appraisal report. ~ . 0, eJ*Z~ Certified General Appraiser GA-000014-L 12 ~,C, '1 ::: , ,> , ~, i~ .,~. " ,. ':~ !~; :~ Address ','; l Proximity to Subject _ ., : ~ Sales Price :i ',..- Price/Gross liv. Area ,:" ,')' Data Source '1 VALUE ADJUSTMENTS x: Sales or Financing ;~ Concessions ;~ Date of Sale/Time Location SiteIView Design and Appeal auality of Construction Age Condition Above Grade .:~ . Room Count p'. Gross Living Area ::~. Basement & Finished ~ Rooms Below Grade ,~ Functional Utility Healing/Cooling Garage/Carport Porches, Patio, Pools, ete. Special Energy ElflCi""t hems Rreplace(s) Other (e.g. kitchen equip., remodeling) Net Adi.. (total) Indicated Value of Subject $ 56,700 . Comments on Market Dala With ad 'ustrnents, all three co sales co arison anal sis and confirm final " ',; .' SALES COMPARISON ANALYSIS These recent sales of properties are most similar and proximate to subject <:Ind have been considered In the market analy:;lis. The description Includes a dollar adjustment rclleclll"l9 market reaction to those items 01 significant variation between the SUbject afld comparable properties. II a sigmflcant item in the comparable property is superior' to, or rr.ore favorable lhan, lhe Sl.Jbjecl property, a minus (-J adjus1menl is made, lhus reducing the indicated value of subject if a significant ile!l'l in lhe comparable is inferior 10. or less favqrable Ihan, lhE: SUbject properly, a plus (+) adjustment is made, thus increasing the Indicaled yalue of lhe subject. ITEM COMPARABLE NO.2 4 N. East street Carlisle 2 blocks FHA As of 11-10-00 8-30-00 Avera e Simi~ar 18' x 86' 14' x 148' ,2-st . att. Similar Brk. &vin 1 Stone & brk. 110 ears 120 ears Av.- od similar' Tolal I Bdrms I Baths Tolal I Bdrrns I Balhs I B<lIms I Baths Tolal I Bdrms' Baths 5 '3 ' I' 1 272 SQ. FI. 5 ' 2 912 5 '2 1, 096 , 1 SQ, Ft. : 5 '2 ' 1 1 064 SQ, Ft. .500 6,200 1 SQ. Ft. 500 10 800 + (-)S Adjustmenl . , 2,000) 1,600 5,000) 3,000) 1,000 500 5,300 Full bsmt. Avera e Gas FHA None Stoop, patio , baleon . Typical for the r ion. None Similar Similar Similar Similar Similar Similar Similar Similar Similar Similar Similar 2-ear ara e: 5,000) Stoop,eov. p<iltio, encl. rch. , ,. Similar Two stoo s. 500 , ," , , , Similar Similar Similar Similar Similar Similar R~odeleci. Similar ~.-m $ 1 700 11 800 $ 66 800 arable sales are acce table for o inion of value of 57,000. u.s. FORMS INC" 2-CENTRAL sa., GRAFTON. MA..Q1~U~.Q.t46_ 1.800.225.9583. 1.839.4417 500) 7 100 46,800 direct ,-"-~._--~- .t. t:;~ ..------_._~,,_..- -,--_:_--_.........---~ _._-.,-----~- .,,_.__.-_.~ ...-..--..-.-..-.--- "'"------.-- ..-------.---- .-.----.-.-.--.--. ~,._-~,..__._--- PHOTOGRAPHS OF 'l'IlE SUBJEC'l' PROPER'l'Y LARRY B. FOOTE REAL ESTATE APPRAISER EXPERIENCB: I 979-Present: Chief Appraiser, Diversified Appraisal Services, Carlisle, Pa. Principal Broker, LaRue Development Co., Carlisle, Pa. 1976-1979: Assoclllte Broker, Colonial Realty; Carlisle, Pa. 1972-1976: Realtor Associate, Jack Gaughen Realtor, Carlisle, Pa. Appraisal experience includes undeveloped land, farms, building lots, single-family dwellings, mobile home parks, medical centers, motels, apartment buildings and complexes, office buildings, service stations, veterinary clinics, rehabilitation centers, retail buildings, daycare centers, warehouses, and manufacturing facilities. I I I I , , , " I ~ I 'I I , , I , I I I , ! , I i I , ! EDUCATION: Bachelor of Business Administration, Pennsylvania State University, 1976. Associate Bachelor of Business Administration, Harrisburg Area Community College, 1974., Diploma, Carlisle Senior High School, 1965. Certificate, Pennsylvania Realtors Institute, GRI I, GRI II, GRI III. Certificate, Realtors National Marketing Institute, CI 101, CI 102, CI 103, CI 104, CI 105. ' Standards of Professional Practice, American Institute of Real Estate Appraisers. Real Estate Appraisal Principles, American Institute of Real Estate Appraisers. Appraisal Procedures, Appraisal Institute. Residential Valuation, American Institute of Real Estate Appraisers. Principles of Income Property Appraising, Appraisal Institute. Case Studies in Real Estate Valuation, Appraisal Institute. Report Writing and Valuation Analysis, Appraisal Institute PROFESSIONAL llCBNSES: General Appraiser HGA-OOOOI4-L, Commonwealth of Pennsylvania. Real Estate Broker #RB-Q29729-A, Commonwealth of Pennsylvania. PROFESSIONAL DESIGNATIONS: GRI: Graduate of the Pennsylvania Realtors Institute, awarded by the Pennsylvania Association of Realtors. ' CRS: Certified, Residential Specialist, awarded by the Realtors National Marketing Institute of the National Association of Realtors. CCIM: Certified Commercial Investment Member, awarded by the Realtors National Marketing Institute of the National Association of Realtors. PROFESSIONAL ORGANIZATION AFFILIATIONS: National Association' of Realtors Appraisal Section. Carlisle Association of Realtors. Pennsylvania Association of Realtors. National Association of Realtors. Realtors National Marketing Institute. "~ - PAST CUBNTS: Borough of Carlisle Keystone Financial Mortgage Cornerstone Federal Credit Union Pennsylvania State Bank Commerce Bank Harris Savings Bank Dauphin Deposit Bank Cumberland-Perry County Association for Retarded Citizens Carlisle Suburban Authority Commonwealth National Bank Pennsylvania National Bank Evans Financial Corporation Greenawalt & Company, CPA Smith's Transfer Corporation Carlisle Department of Parks and Recreation Farmers Trust Company Carlisle Area School District Messiah Homes, Incorporated ERA Eastern Regional Services Cumberland Valley Savings & Loan Association Chase Home Mortgage Corporation Defense Activities Federal Credit Union Pennsylvania State Employees Credit Union Meridian Bank B-H Mortgage Service Corporation Friendly Mortgage Services United Telephone Employees Federal Credit Union Cumberland County Commissioners Allstate Enterprises Mortgage Corporation Dickinson College PPG Industries, Incorporated Gettysburg College Redevelopment Authority of Cumberland County Record Data Appraisal Service, Incorporated First United Federal Savings Association Washington Telephone Federal Credit Union Hill Financial Carlisle Building & Loan Association Sears Mortgage Corporation Provident Home Mortgage Corporation Fulton Bank United States Marshall Service Central Pennsylvania Savings Association Coldwell Banker Relocation Services, Inc. Maenner Relocation, Inc. CCNB Bank, N.A. GMAC Morgage Corp. First Bank and Trust Company Mellon Bank Orrstown Bank , Letterkenny Federal Credit Union 1 BancPlus Mortgage Corp. I Various law firms and individuals i I 1 I , 1 -j c_,~ - \ p', , \ I I , SHERI GOSSARD, PlaintifflRespondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. 2000-4656 CIVIL TERM LARRY GOSSARD, DefendantIPetitioner CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached document was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: James J. Kayer, Esquire Kayer & Brown 4 East Liberty Street Carlisle, PA 17013 IRWIN, McKNIGHT & HUGHES By: Marcus 1\. McKni E 60 West Pomfret Street Carlisle, P A 17013 (717) 249-2353 Supreme Court I.D. No. 25476 Date: May 24, 2001 3 , ,- T__: f'''' '.'-"J:-'''' "_' ;"C":~,,:,o~, '~_r ~'~ 0,,_, ~~">--".,,,,"_' ,,., c. _."..' "~"C-_~_,~_. ,''-__ 0 _"~..,, '__'_.'. ,.' ',.,.". 'c- ~_ ,__~n ""_,.,,,-' ",.n,.,.,,_ _ _."" __,~ ," _ _ . _ SHERI GOSSARD, PlaintifflRespondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. 2000-4656 CIVIL TERM LARRY GOSSARD, DefendantIPetitioner CIVIL ACTION - LAW IN DIVORCE PETITION FOR ECONOMIC RELIEF AND NOW, this 22nd day of February 2001, comes the Defendant/Petitioner, Larry Gossard, by his attorneys, IRWIN, McKNIGHT & HUGHES, and makes the following Petition for Economic Relief against the Plaintiff/Respondent, Sheri Gossard, as follows: 1. The petitioner is Larry Gossard who is the defendant in a divorce action filed at 2000-4656 in Cumberland County, Pennsylvania. His address is 15 Peipers Court, Carlisle, Cumberland County, Pennsylvania 17013. 2. The respondent is Sheri Gossard who is the plaintiff in this divorce action. Her address is 46 North East Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The petitioner seeks the following relief from the Court: a. Equitable distribution of the marital assets; b. Costs and expenses; and c. Counsel fees. 1 "- ,-. '--.~ -'~""""'9?_","/"""~,,.~, .~",.~;^,~~_~,,~ ,,,.,,,,.~,,,,,,,, ,P_'__,,,._~_","q,,,._,<_,___~.;_,,,,_,.,_. "r'~._ -',-, . ,'- ~-~"--"-= .- WHEREFORE, the petitioner, Larry Gossard, requests the relief set forth above. Respectfully submitted, IRWIN, McKNIGHT & HUGHES Date: February 22, 2001 2 '- '" -', ,._--:;",,,'?,!-','",'C',;;<!f:-,'r--:-:- ~':r{"',__ ';- , ,'''_i'''--'-. c "<;""',v_,>~_. '''-.".._ .,~ "c.. ,'-,,"_' ,~' , ."_'<'" " _~ "~'_ VERIFICATION The foregoing Petition for Economic Relief is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. ~fGOJb.j Date: February 22,2001 t,.. , -, "i:'.P ;~,"--~','~n""'<,^,-", " CO'" ~<.~~,~,~, ,-,; '_ ; < . -'-n''''.. . ,_,_~, . ". ~ ,-- ~ SHERI GOSSARD, PlaintifflRespondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. 2000-4656 CIVIL TERM LARRY GOSSARD, DefendantIPetitioner CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached Petition for Economic Relief was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: JAMES J. KA YER, ESQUIRE KAYER & BROWN 4 East Liberty Street Carlisle, PA 17013 IRWIN, McKNIGHT & HUGHES By: Date: February 22,2001 ".'lJ"i!_1lll,> . ^, ,,'. J ~"_'". -, '''\ !)'i:}l'::-_~'__,,~ ~,O,I'-",.._",."c",,______, _~""":,'"",,,,-,r;",', ,_ '_"'._'''''''', '-.; "," '''-,~,';''~ ',f- ~" d. ," _ ,_ ,,__~.,. _,~,_ ",~__:~_ _., _ , -- -..' ~ ~ t C\ ~ &; 8 '" ~ ~ ""'-J ~f? ~J ~ c;-, ~-". . . " ,--~ " " "' . ~- .'" . . '-~..-".o _.,~ "" (") ~Lf :f':-~ .>--- ~";:J ~ ~F~~ ;:;;;; -; -< , 1:.1. o ;~ 0) r,} 1'_" '~J ~l'l ~c: i:'} "" . ::m~ ~ -.'. SHERI GOSSARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 00 - 4656 CIVIL LARRY GOSSARD, Defendant IN DIVORCE RESCHEDULED CONFERENCE WITH COUNSEL AND THE PARTIES TO: Jane Adams , Counsel for Plaintiff Sheri Gossard , plaintiff Marcus A McKnight, III , Counsel for Defendant Larry Gossard Defendant A conference has been scheduled at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 29th day of August 2001, at 9:30 a.m., with counsel and the parties to discuss the outstanding economic issues to determine if there is a basis of settlement of claims. If issues remain after the conference, a hearing will be scheduled at another date. Very truly yours, Date of Notice: July 17, 2001 E. Robert Elicker, II Divorce Master I"~ ". ' ^- ..":""'- " ,/ - SHERI GOSSARD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO. 2000 - 4656 CIVIL TERM LARRY GOSSARD, Defendant : IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Please withdraw my appearance as counsel of reco d for the above-captioned Plaintiff. Date: C (2/ I (j 7 , Date: f- (, ~ J )~) /~-~______I "'~. c.... r- . . 1'0 - '~. "-=, --'," -,.~' ~"''''' " J Q]t:~ - -<'<., en i-:; ;-:; ;;.-...-- "".- j;~ o c:: -.'.7 " ...... .c:'::-' \.:::: :::0 ""....,.'" ~r~~_IJ{W~ .Q.n!ft!!lt'Wb,il!LW,rn _", ~~~~_"'~~ ." -,-- :',III'RI ("lSSi\RU, Plaintiff : IN TilL' ('C'URT 01 COM!\ION PLY\S Ul : CUlv1Bl'RIANU CotKTY, l'I'NNSYI.\ /\NL\ \.':~ . : CIVIL (\('T!ON . L\ W : NO. 2000 - 465() CIVil ITRill .\1'.1( y (,( lSSARD. IJ"k,nduI11 : IN DIVOR('r PRAECIPE 10 TlfL PROrfl()NOT\R'i, Pie",,,,, \\ithdraw my apP"1H'HIlCt1 n;; counsel o['rec9"d tbr the ahov".capliond PLlitllilT. L)jl("' ( /?! /;, ) ....t.,__....,....><..,.)..... l'k,!'-,: "JJt,'J 111~ "I'Pg.mmy'" a:, ClIl!t1,eI uf f>:cor:d f~)J' the ah.;vc;:"j,JlhliWd Pl.lIf1tlll I ... '\ ," (~...__ ':7' ,/ )--1 / I;....' -. ' ( ./r ____:;.>' DJ.k. ~'// I~/_......~)/ ~,.__.3:}{::_..:.:i_....__""_~~_~__--~ / I' I , Kayer and Brown Attorneys At Law A Professional Corporation Liberty Loft 4 E. Liberty Avenue Carlisle, Pennsylvania 17013 e-mail: jkayer@epix.net Telephone: (717) 243-7922 FAX: (717) 243-0946 February 28, 2001 E. Robert Elicker, III Divorce Master 9 North Hanover Street Carlisle PA 17013 RE: Gossard VS. Gossard - In Divorce Dear Mr. Elicker: I have received your request for Certification that discovery has been complete in the above referenced matter. I am returning that certification to you. Very truly yours, JJK/vjg Encls. cc: Sheri Gossard .,'_",,' v.,. ~;- ,c..:,o,.", ".'" ;:-" _N_," '_":'_~:_. __',", ',<"""~A._";, .x-- -;~'Y~'- e' -'cO:>" "''7'5 !' ~,__ -e ,'" - ".O,,?,"_',."_ -r.' ,'. . .:.' I _~" - _ _-,.".^."" - ~- - "., SHERI GOSSARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00 - 4656 CIVIL LARRY GOSSARD, Defendant IN DIVORCE TO: James J. Kayer Attorney for Plaintiff Marcus A. McKnight, III Attorney for Defendant DATE: Tuesday, February 27, 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. ?--( 2/5/ () I DATE NOTE: PRETRIAL DIRECTIVES WIL E 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. ,:' -~-,~ .--,- ,-. - -', .- ".- ~n ~,~' . OFFICE OF DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEAS 9 North Hanover Street Carlisle, PA 17013 (717) 240-6535 E. Robert Elicker, II Divorce Master Traci do Colyer Office Manager/Reporter West Shore 697-0371 Ext. 6535 April 23, 2001 James J. Kayer, Esquire KAYER & BROWN 4 East Liberty Avenue Liberty Loft Carlisle, PA 17013 Marcus A. McKnight, III, Esquire IRWIN, McKNIGHT & HUGHES 60 West Pomfret Street Carlisle, PA 17013 RE: Sheri Gossard vs. Larry Gossard No. 00 - 4656 Civil In Divorce Dear Mr. Kayer and Mr. McKnight: Mr. Kayer returned the document regarding certification of discovery on February 28,2001, indicating that discovery is complete. Mr. McKnight has not returned a certification document; however, I am going to assume that there are no outstanding discovery matters which need to be addressed in this case and that we will be able to proceed with a directive for pretrial statements. A divorce complaint was filed on June 29, 2000, raising grounds for divorce of irretrievable breakdown of the marriage. No economic claims were raised in the complaint. On February 22, 2001, the Defendant filed a petition for economic relief raising the economic claims of equitable distribution and counsel fees and expenses. No claim has been raised by either party for alimony. In accordance with P.R.C.P. 1920.33(b) I am directing each counsel to file a pretrial statement on or before Tuesday, May 29,2001. Upon receipt of the pretrial statements, I will immediately schedule a pre-hearing conference with counsel to discuss Ib ,,,. I,."..: "., ~\''''''''7-''.~''_._-","_._" ,'-"_'_'~'"" ",._''_, _ ,,'-, >.-" ,. _~ ;N. 'O~ .c" " ',,_ __~_~_ "- ,-' ,. ,_,0 . Mr. Kayer and Mr. McKnight, Attorneys at Law 23 April, 200 1 Page 2 the issues and, if necessary, schedule a hearing. Very truly yours, E. Robert Elicker, II Divorce Master NOTE: Sanctions for failure to file the pretrial statements are set forth in subdivision (c) and (d) of Rule 1920.33. THE ORIGINAL PRETRIAL STATEMENT SHOULD BE FILED IN THE MASTER'S OFFICE AND A COPY SENT DIRECTLY TO OPPOSING COUNSEL. FAILURE TO FILE PRETRIAL STATEMENTS AS DIRECTED BY THE MASTER MAY RESULT IN THE MASTER'S APPOINTMENT BEING VACATED. 0;:~,,"'1 . , '. .,_ ~__"c '0_ "' " -~ ~ -~-< . . ~ ~, SHERI GOSSARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 00 - 4656 CIVIL LARRY GOSSARD, Defendant IN DIVORCE NOTICE OF PRE-HEARING CONFERENCE TO: James J. Kayer , Attorney for Plaintiff Marcus A. McKnight, III , Attorney for Defendant A pre-hearing conference has been scheduled at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 17th of July, 2001, at 9:30 a.m., at which time we will review the pre-trial statements previously filed by counsel, define issues, identify witnesses, explore the possibility of settlement and, if necessary, schedule a hearing. Very truly yours, Date of Notice: 6/7/01 E. Robert Elicker, II Divorce Master James J. Kayer, Attorney for Plaintiff, has not filed a pre-trial statement as of the date of this notice. Marcus A. McKnight, III, Attorney for Defendant, filed a pre-trial statement on May 24, 2001. ><("~~ ---,,' " "'" ~,-_.( ,,, , SHERI GOSSARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 00 - 4656 CIVIL LARRY GOSSARD, Defendant IN DIVORCE CONFERENCE WITH COUNSEL AND THE PARTIES TO: Jane Adams Sheri Gossard , Counsel for plaintiff , Plaintiff Marcus A McKnight, III Larry Gossard , Counsel for Defendant Defendant A conference has been scheduled at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 22nd day of August 2001, at 9:30 a.m., with counsel and the parties to discuss the outstanding economic issues to determine if there is a basis of settlement of claims. If issues remain after the conference, a hearing will be scheduled at another date. Very truly yours, Date of Notice: July 17, 2001 E. Robert Elicker, II Divorce Master I"," ~ f-"" "'_' " ~,..... SHERI GOSSARD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO. 2000 - 4656 CML TERM LARRY GOSSARD Defendant : IN DiVORCE ELECTION TO RESUME PRIOR NAME To the Prothonota'Y: Pursuant to the Act of the General Assembly of the Commonwealth of Pennsylvania, of April 2, 1980, P.L. 63, I, SHERI L. GOSSARD, Plaintiff, in the above-captioned case, in which a Decree in Divorce from the bonds of matrimony was entered on September 12, 2001, do hereby avow my intention and do hereby elect to resume my prior name of: SHERI L. DOVE. .1 I:b~ COMMONWEALTH OF PENNSYLVANIA ) ):ss COUNTY OF CUMBERLAND) On this, the ~ day of ~ ,2001 before me, the undersigned officer, personally appeared SHERI L. GOSSARD, known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I here -. SEAL NOTARIAL SEA!.. JANE E. ADAMS. Notary Public Carlisle Boro, Cumbsdand County My Commission ExplI'llS Sept. 6, 2004 .. _ .. ^'~ w',' ~~~ o o_'~,~~~ ,.",,_' "._ ''''V. - ~ 0 C,) c: "vet; C) j ~ ~ ("? ~ lil I '1' 1 --I .7":::::,,:; ~. ?~J~~ (:::1 --- ~~~~, " :[.:'.." '!:, .. "- :-:t :;~~ & ~"2: C) ,~t --<. 11___- .. _:,ij!QjIl\fii>._ i\ '0 ',:\ ";"I"l'_' >,,' ,~. "', FEB 2 7 2002 }Jl-- SHERI 1. DOVE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA v CIVIL ACTION - LAW LARRY GOSSARD, Defendant NO. 00 - 4656 CIVIL IN CUSTODY COURT ORDER AND NOW, this )7~day of February, 2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The following temporary custody order is entered: A. Mother shall have primary physical custody of the two minor children, James Scott Gossard, born February 25, 1990; and Sarah C. Gossard, born December 14, 1995. B. Father shall have temporary physical custody of the minor children on Saturday, March 2, 2002 and Saturday, March 9. 2002 from 1:00 p.m. until 7:00 p.m. and on Sunday March 10, 2002 from 1:00 p.m. unti16:00 p.m. Exchange of custody shall take place at a public location which shall be the McDonald's on Walnut Bottom Road in Carlisle unless agreed otherwise by the parties. C. Legal counsel for the parties may contact the conciliator to schedule a telephone conference call to discuss implementing further periods of temporary custody for the Father after the above mentioned visitation has taken place. It is contemplated that Father will receive additional time assuming everything goes well between the Father and the children. 2. The parents Sheri 1. Dove and Larry Gossard shall, essentially, have a shared legal custody arrangement such that medical providers, school providers, counselors and other entities are hereby authorized to provide to both parents any and all information concerning the health, education and welfare of both minor children. More specifically, such entities may also provide such information to legal counsel for the parties as requested, and both parents are directed to sign any necessary releases in conjunction with the furnishing of this information. ~ 0.' - _, .""''''k~_.'' I I i I I I t. ,'~' <, 9"""" , _ . " "t. 3. Legal counsel for the parties shall between themselves select a family counselor who shall work with the parties and the minor children with the focus being to facilitate better relationships between the children and the Father in the hopes that future custody arrangements will include more expanded time between the Father and the children. cc: ..Marylou Matas, Esquire ,-Marcus A. McKnight. Esquire J. topw> .rn~ 7 o.2.:<r.6:1.l ~S c~-___1ffi!"'> 'ci.=cu~." J_n. '-'~I!ID91~~- '--~~i~~~!k*,)jllli~l*,r~~Qlill"'''''''''''''' ~_.,.;""___o.it'"' . " ...' ~"~~--q -~-~ l;iil.jwE~ "...~"~- ("'r- ,- '-,' t:li~ED''''Cti:F!GE ,,(. ["r~~rT ~{~'NOTAFtY 02 FEB 28 Ail 8: :is CUMB!J1L!\f\u COUNTY PENNS'i1.VANIA ~.- - ~~ ~, !'-~ . .' ... ' SHERI 1. DOVE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW LARRY GOSSARD, Defendant NO. 00 - 4656 CIVIL IN CUSTODY Prior Judge: CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: James Scott Gossard, born February 25, 1990; and Sarah C. Gossard, born December 14, 1995. 2. A Conciliation Conference was held on February 21,2002, with the following individuals in attendance: The Mother, Sheri L. Dove, with her counsel, Marylou Matas, Esquire; and the Father, Larry Gossard, with his counsel, Marcus A. McKnight, Esquire. 3. The parties agree to the entry of an order in the form as attached. ~ eX.! ::n/ (f~ DATE' Hubert X. Gilroy, Esqu' e Custody Conciliator -_',7 - ~- '. - .,. .- -.~ .- SHERI GOSSARD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. 2000-4656 CIVIL TERM LARRY GOSSARD, Defendant CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 29, 2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: 2001 'dr.; HER! G SS Plaintiff r~__,""",",. _ _ ---:-''(-':''''':O-'''''''<~_''__'"''-''':''___'''_': ."_M.'.':_,;,"',;",'" <;,','_'<: _,~,~i,,,,_,\,,",,_..,A.,,.~_"~~_.,,_> ,_ _" "':"'^C', '"'~"'-!:' ,,' _ ~"_,,, ",. _ ,~ " _ ,~,_ ,__I,~ ..'"' _ _ _ "~', ".,''''. ",' ',< _ ,,_,. .' ,r,' ^ '." ,~ r~"__ .. '""", ,~ , ',~~"-~ t:~H "-, c ~ ~tf' 2T ~~--.-: I.~ ~ _, '!fit. - :~~ ::r:-~ ::,:"') r....) I.,C, c:- cn -~--" _.,'L",,~ SHERI GOSSARD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. 2000-4656 CIVIL TERM LARRY GOSSARD, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: (L ^ -vJ J-1. .2001 no I ~~ ~ SHERI GOSSARD Plaintiff ~'1,~!:-1): ~ C"'".,"''''!: _"'__"~<~'_,_,' ., ,'",.c:, """"__,~,,, _,,<.,.. ,~_,- '"""--,,___",,,O_~-""_ ~, ,_". _,__~ ___""__" _,__ "~,__ ".'_"_,,, _0,., n _."" _~"O_,.,_ ~"_._'o "'.',_ '~ " ~- , ~~ C) c ~!~ ~~~, :;-;8 2': =< " ,. ,,"^, 0'. _"0" ~, ',,-' ==~ ",) ~ c-___ :::;J ;-'-) t.,D ',-I': '.0 (J'] .,." "',~,," '" ~ ,"~ -'~_',,_\, SHERI GOSSARD, Plaintiff : IN TaR COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. 2000-4656 CIVIL TERM LARRY GOSSARD, Defendant CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT ct~JfVt- The ptmI/ttff, being duly sworn according to law, deposes and says: I. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: fkJ0 rV1 .2001 b:t!ARDU Defendant !:~'~j ""'->"_",_,,;,-_-,~-._f;, -,_ "-.-,c,,,~,_,,,~'_; ,-- -, ,,-~_- "-~ ..~~___, ~~_"'__' ,-," . ,.",', "'-~-'--' , -~, " !il c.cc, -~--' .", .. . ,. "- "^"_-c'-' ",~, '_" ---:1 He ,_ ."" ,." o ~ uti: rnj'1'; -;-i"-I' 7r-"- 0?::- r:::c, '- ~~! ;:.: =<' ~~" -- ,.~ ,..-'-' ~<-"-, ~ ,:;'") r',.) \,D c:- (,,-f1 -, -,~~- -.;' '-, --,-, '-.) -.1 - ";-1 =< SHERI GOSSARD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. 2000-4656 CIVIL TERM LARRY GOSSARD, Defendant CIVIL ACTION - LAW IN DIVORCE W AlVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: 1~)(.0 0.9 .2001 ~fA LARRY SSARD Defendant J I: Ii li~:", _" '_ ., I ,. ~ ;,.,-,"-"-,< t,! ,'~-' ~- ~,"",' ,,~." " ~" >., - - ." .J. .~. .UJlIlll!!!JlPl ~" ~ (') s -or:c: n'1r', ~~~. r:: c- ~;;: "-, ~~': "r_~ -, -< -'., ~ >"- -' _'''M ," __.~. .__,___,.' . c,,:; ~ T'.) l.D fC- C" ~ , ~~j ::'>:J --'. -,""," <', SHERI GOSSARD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. 2000-4656 CIVIL TERM LARRY GOSSARD, Defendant CIVIL ACTION - LAW IN DNORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 330 1 (c) of the Divorce Code was filed on June 29,2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date ofthe filing ofthe complaint. 3. I consent to the entry of a final decree in divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: ..BlX? a.9 .2001 -A rJ1J LARR~SSARD Defendant ""V'(f'," - ", "-<'! ',~,-"-",;_ -."l1'._".",", _ _-"" _ .J ,_ """,'"' ."",'1' ,-___~,_,7, ''f' ~__,_",,__ -1-,-' _,,, _ _ .,,_~ _ ,>. -'Or'._ ',,'_"~__'~' .-__ - .~ " ~~-~~ '_ '" m~_~_ .~, _', _ <. -,- ,"~- "'''-7' _~~ , _0 , .," -' _"_",,,.""_~Jl1!lI!l -;. () C <- ""t.l\:,'L rnr~'~ 2:1 ~1~:', c;(~~; ~~~: 2-= -J -<.. ;::... , o,*,. _<""~',,_, "'" . _ -" ~., ::;-) ;"-)- \.i::; ""\1 ~~~ r.:- "- ~."'~ :iJ -< ~-"-,-:,,,~--" ,- \, , " " " il Ii f~ " f; Ii ie i;i !j :1 , ::i ~:I ,,, " ~;! ~ :: (-i ;-J iIi (I i" L<:, l" i(1 ,-: '; j 'I I ,I :.,1 ,j ,'I ',I :;.-1 I;:i '-I ;:i , '~i ':~_n, W -. ~"_ ~- '. -,,~" SHERI GOSSARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00 - 4656 CIVIL LARRY GOSSARD, Defendant IN DIVORCE ORDER OF COURT AND NOW, this f) f1lv day of ~t?HAr-- fl having entered into an 2001, the parties and counsel agreement and stipulation resolving the economic issues on August 29, 2001, the date set for a four-party conference, the agreement and stipulation having been transcribed, and subsequently signed by the parties and counsel, the appointment of the Master is vacated, and counsel can conclude the proceedings by the filing of a praecipe to transmit the record with the affidavits of consent of the parties so that a final decree in divorce can be entered. BY THE COURT, P.J. cc: Jane E. Adams Attorney for plaintiff /~ ~ f'/OO/Ol Marcus A. McKnight, III Attorney for Defendant '"',-", . ',"-- L _C' ;~' ",~~ ",;;;- ~iMi!~~ili~$llD~-!OI!>\tii<'5i$l4R.;mL~11l'lad~~J""~"'"'" "' .-".~ , " ,; i ,~. ')0 r,_..- ., ,'I" ::"1:" . .'J''''-'''' GUMBt.'f\L;\\\;-.....; (),) \\ll \ '-'N'\'SY'I'(,\llt ~Clll' l.-h\lv.il. " ~-,",'~::~J.J~)L:r5!(J::.L,lt{~~,:~,'~Jt~,~h,-_:h_ I.} ",r:, H" _, <, _,~, ' ",.' .- 1 '\. - \ '"T "~, , ..' ; ',' ~.- ~~- """,' <, '" ~ SHERI GOSSARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 00 - 4656 CIVIL LARRY GOSSARD, Defendant IN DIVORCE THE MASTER: Today is Wednesday, August 29, 2001. This is the date set for a conference with counsel and the parties. In the hearing room are the Plaintiff, Sheri Gossard, and her counsel Jane E. Adams, and the Defendant, Larry Gossard, and his counsel Marcus A. McKnight, III. This action was commenced by the filing of a divorce complaint on June 29, 2000, raising grounds for divorce of irretrievable breakdown of the marriage. No economic claims were raised in the complaint. On February 22, 2001, the Defendant filed a petition for economic relief raising the economic claims of equitable distribution and counsel fees, costs and expenses. The Master has been provided affidavits of consent and waivers of notice of intention to request entry of divorce decree and Defendant's marriage counseling affidavit signed by the parties and dated today. The affidavits and waivers will be filed by the Master's office with the Prothonotary's office and the divorce will be able to proceed under Section 3301(c) of the Domestic Relations Code. ''W~Y''''e ..", __".___,~_,_,""_ ,e' ,v. I 1 ~ . " The Master has been advised that after negotiations today, the parties have reached an agreement with respect to the outstanding economic issues. The agreement is going to be placed on the record in the presence of the parties. The agreement as placed on the record will be considered the substantive agreement of the parties not subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. The parties are going to return later this morning to review the draft for typographical errors, make any corrections as necessary, and then sign the agreement affirming the terms of settlement as stated on the record at this time. When the Master has been provided a completed copy of the agreement, he will prepare an order vacating his appointment and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. Mr. McKnight. MR. McKNIGHT: 1. The parties own real estate at 46 North East Street, Carlisle, Pennsylvania. wife agrees to convey, by deed, her interest in said property to husband, Husband agrees to hold harmless and indemnify wife from the first mortgage at PNC and from the second mortgage at Household Finance. He will make all payments and will indemnify wife if any claim is made against her. He further agrees to either refinance or sell this property within three (3) years from today's date thereby ending wife's obligation for those two loans. -%!Ie!"", -~ c' , ""~ _, _,_e-_ " . '_., ",- , :-' , c, '1 :1 '[ '! 1 II " , r-:1;~,'ll! 2. The parties also have an equitable interest in the property at 48 North East Street, Carlisle, Pennsylvania. Wife agrees to convey immediately her interest in said property to husband waiving all right, title, and interest in said property provided that husband provides to her an agreement with the legal owner of the property that she is no longer obligated on the outstanding agreement of sale. With regard to the property at 48 North East Street, Carlisle, Pennsylvania, since the parties only have an equitable interest, husband will provide for the wife a release from the legal owner saying that he will release her from any obligation on this agreement and that it will be the sole responsibility then of the husband to complete the agreement for the purchase at 48 North East Street, Carlisle, Pennsylvania. 3. Husband agrees to be responsible for the following debt and to hold wife harmless from said debt: A) The personal loan at Household Finance, and again, he would agree to have that paid off or refinanced within three (3) years from today's date; B) He also agrees to be responsible for the wachovia credit card that is currently in joint names; C) The Choice credit card; D) The Home Depot credit card; E) First USA credit card. 4. Wife agrees to be responsible for the MBNA credit card and the Associates credit card, and she hereby states that she has already paid off the Sears credit card. All of those are her responsibility and she would hold harmless the husband from any claims made on those credit cards which are believed to be in her sole name. 5. both pays sign The 1997 Chevrolet Lumina Sedan currently titled in names will be titled to wife in her sole name when she off the outstanding AllFirst car loan. Husband agrees to the title over to wife when it is available at that time. 6. The 1994 Chevrolet Lumina Minivan will be immediately signed over to wife and become her sole property, There is no obligation outstanding on that. 7. Husband's Chevrolet S10 pickup truck is currently in his name. There is no obligation outstanding on that vehicle. ~, ,- ~,,-"'., ~ "-'-' . ~~_. Wife waives all right, title and interest in said 810 pickup. If there is any loan outstanding on the 810 pickup truck, it is husband's sole responsible and he will indemnify wife for any claim made thereon. 8. Each of the parties have agreed that they will keep their retirement in their own names without any obligation to the other. Therefore, wife's retirement with the Commonwealth of Pennsylvania will be her sole pension and husband will make no claim against it. Husband's pension with the Commonwealth of Pennsylvania will be his sole property and wife makes no claim against it. 9, All of the personal property which each party currently has in their possession will remain their own and the other party waives all right, title and interest to said personal property. 10. Either party can in the future, if they choose to do so, file personal bankruptcy, but that in no way, shape or form will end the obligation to indemnify on these loans to the other as set forth in this agreement. If one party files for bankruptcy and the other does not, the other party still has to honor their agreement to indemnify if a claim is made against them and they have chosen not to go bankrupt. 11. Husband agrees that with regard to the minor children in this case that if they choose to go on to college or some other education after high school that he will pay at that time one-half of their room, board, and tuition for such college or other program beyond high school which they would be eligible for enrollment, 12. Husband agrees to pay within thirty (30) days from today's date the sum of $2,500.00 to wife through counsel in consideration for all of the other provisions of this agreement. 13. Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship including without limitation, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate. Each will at the request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this '-";*f,,,,. -"",'-' _, 'c ,T ~ mutual waiver and relinquishment of all such interest, rights, and claims. 14. The Defendant, husband, agrees to waive any claim for costs and counsel fees against the plaintiff, wife. It has already been stated that there is no pending claim for alimony or support between the parties. THE MASTER: If you will go on the record with your client MS. ADAMS: My client agrees to the settlement as stated on the record. THE MASTER: Let me ask her a few questions, if I may. You have been present, Ms. Gossard, during the statement of the agreement on the record? MS. GOSSARD: Yes, THE MASTER: Do you understand the agreement as stated on the record? MS. GOSSARD: Yes. THE MASTER: Do you have any questions about it? MS. GOSSARD: No. THE MASTER: And you understand that this is a complete and total resolution of all of the economic issues in your divorce case? MS. GOSSARD: Yes. THE MASTER: You understand that when you leave here today, this hearing room, you are bound by the '.",-"-- ,-_o,~ -.' - terms of this agreement even though there has been no signatures affixed to any document? MS. GOSSARD: Yes. MR. McKNIGHT: Mr. Gossard, you have been here to hear all of the terms of this agreement? MR. GOSSARD: Yes. MR. McKNIGHT: Do you understand those terms? MR. GOSSARD: Yes, I do. MR. McKNIGHT: Do you agree with these terms? MR. GOSSARD: Yes, I do. MR, McKNIGHT: And you are willing to honor those terms and carry them out as they have been stated? MR. GOSSARD: Yes, I will. MR. McKNIGHT: And you have no questions about any of these terms? MR. GOSSARD: No, sir. 1 acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by -j '1__,.,.". - ,'- ~~ ~ 1- :>1 " :~i '"I i 'I -:! i ,j 'i "I , ,;i ''I , 'I] u :~~ -:1.,","",. _ law and in particular Section 3105 of the Domestic Relations Code. WITNESS: DATE: ~~~\Ol ~~ ,..1,7' ,)t;Ol &vtP j~ Larry Gossard ~ , SHERI GOSSARD PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 00-4656 CIVIL ACTION LAW LARRY GOSSARD DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, January 07, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq, , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, January 31, 2002 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing, FOR THE COURT, By: Isl The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Oisabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ,,~ "' . ,~"~"_.,,_. ~,' .L~_j~~~m.'~;';'~;'(';;,""",",-B:,;a.",~';~'t,'l,""'-"fIiiL!ilci!fI;,0~"if<l<,''illil:.@WJIiII!~IliliIllUItI<~~~~lWlI!lIj /,~ ~02 / .~ -?Jd / ?z?,) 02.'/111 ,.8 F'i'1 2: I 4 CUlv'!~~F~i.i\ND COUNTY PENNSYLVANIA &:t-~~ ~rn~Z ~~--- .t_ ~-I"'''~.iGII--- {jllti.~r1 --. ~ji ~ ;? df,m~ ~, #. ~ :J:& - -, . DEe 2 '( 2001 V' SHERI GOSSARD, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 2000-4656 LARRY GOSSARD, DefendantIPetitioner IN CUSTODY ORDER OF COURT AND NOW, this day of . 200-----, upon consideration of the attached petition, it is hereby directed that the parties and their respective counsel appear before Esquire, the conciliator, at . on the day of , 2002 at . M. for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at this conference may provide grounds for entry of a temporary or permanent order. By the Court, By: Custody Conciliator 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 TIlE OFFICE SET FORTH BELOW TO FIND OUT WIlERE YOU CAN GET LEGAL IlELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 1-800-990-9108 t'c"'~<~n' ,,' '.' -'~'''' -, ~,A_"_,~,_ '~7:~"""._' ~_,~_ ''-..,-<<_,,'0''''' ~"'- -.,"'- ^.. .,"-'," _,_ """ .'. .'.,c,." - "". -" ,,"'~--' .~~--"", - ^,--.- ~ w AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduling conference or hearing. ~~~''',. ' .~ ~ -,- '~--,-;--':'_ ~,-_;,_,~-" :-,_,- ,,_~~__':?,1"~}', ',.'--0"- "::e!~~__ __!_ ". s',' _~~_'_,Pc_+,"-" "" "'__"""_~_ ___"om ~, ,~u_"__,~_ _ ,," SHERI GOSSARD, lPlaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION- LAW NO. 2000-4656 LARRY GOSSARD, ][)efendantIPetitioner IN CUSTODY PETITION FOR CUSTODY AND NOW, this 26th day of December 2001, comes the Petitioner, Larry Gossard, for, by his attorneys, Irwin, McKnight and Hughes, and presents the following Petition for Custody. 1. The petitioner is Larry Gossard, an adult individual residing at 46 North East Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The respondent is Sheri Gossard, an adult individual residing at 62 West Ridge Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties are the natural parents of two minor children, namely, James Scott Gossard, born February 25, 1990, and Sarah C. Gossard, born December 14,1995. 4. The petitioner desires temporary physical custody of the children and joint legal custody of them. Petitioner's custody would be as mutually arranged between the parties or on petitioner's days off from work ifno agreement can be reached by the parties. \~, , -,"--",,-, ,-" ,- c_",,__.. - ",---~,?<~.~,_,p_'P _"k'!_~ ,", ,__':1.,__,,,,,. ,>,r., , _,' ',' ,. h._ _ _, ~ ~_ 5 The best interest of the children requires that the court grant the petitioner's request as set forth above. WHEREFORE, petitioner respectfully seeks the entry of an Order of Court seeking temporary physical custody of the children and joint legal custody with petitioner's custody mutually arranged between the parties or on petitioner's days off from work if no agreement can be reached by the parties. Respectfully submitted, By: e Date: December 26,2001 ,-_""". ~" ~_", ,?"<"-',T>:-,,, "'_.' :,,,,~,,,,:_._"__'q.;-i'__-'-- _",,,_~_~_,,__, _ '," ,,')~_r_,_, VERIFICATION The foregoing Petition for Custody is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. &G~~ Date: December 26,2001 !'~- ',' -,' ~ -.,,-.' ',,~!"'_'}~,-~"'b'j)'i'l_,~"'c - ., ,"1""" _'_~"'_ .<"_~"..o ___~_ '2';>""~-- _ ~~_' - l:7j , <~ ~-'-' ,<-"" ",", .~- - ,,~, ~ '-' """c '___,_.~*_' ~."",".., "'~' .".",'~,"">-_, ,'.', _';_'c._ __ - ,'," ^__ -"--'--''-'''- - ~'" ".~ ',-~ ,--'-\ '-", () 0 0 c: -n ~ 0 s: CJ ---1 ~ ~tD mrtl r<1 hi fTI ~ Z::u c-> 6;5; N -ofT! g 0' ,';0 -<....r:., 0"- -... ~ ~o _._"t.) "'" ~~ ~ 0 \) ~o ::!l: -l;) ~ -0 ~ C> ~c: 'P. ':4 Z ~ =< U1 55 <tr (1\ -< ~ ? - , c::::S:l :s- +- "', ~,~~~~. I!I!:~ ~ ~ .y ..... ,-,' SHERI GOSSARD (DOVE), Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. LARRY GOSSARD, Defendant : CIVIL ACTION -LAW : NO. 00-4656 CIVIL ACTION : IN CUSTODY PRAECIPE TO THE PROTHONOTARY: Please enter my appearance on behalf of the above referenced Plaintiff, Sheri Gossard (Dove). DATE: II Zto/6 l. I f 'YY1~/~ MaryloU' , Esquire GRIFFIE & ASSOCIATES 200 N. Hanover Street Carlisle, P A 17013 ,~ ~, , '~""'.' , ~- I I I I I 1\; ~~~ .. !'?!I"Ij'l!il\f" , (') C) C) C N <'" "1-1 "'Om ~.- """ 52 en ;;:;::;: :I' i-- ze N 1:-n (D~~ '.0 '_~Ct -<<~, .... ,1 !<r.:.:~ --~ ,"-. -u 'j ~_.' ~() - ~.,- ,:....< ::I: ~E~. ;;;c., i~~j:'T: C Z :.'1 j;~ ::;,? :XJ .r. -< _T _ ,""",",..,!- L ./J_~!l!iM&l~~~4iH~;1*"_Wm;;#ll;0i~~fffl1>-~'Wt<~"'_NPl:'l0"'1'~"'i'W~~~~'[tl~M:!i'1'1'Jffl!~~.. ~ 2002 SHERI L. DOVE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW LARRY GOSSARD, Defendant NO. 00 - 41656 CIVIL IN CUSTODY COURT ORDER AND NOW, this ~tPf day of Iil~ , 2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that this Court's prior Order of February 27, 2002 shall remain in effect subject to the following modifications: 1. Father shall continue to have periods of temporary physical custody with the two minor children on every Saturday that Father is off work. The timeframe shall be from 1:00 p.m. until 7:00 p.m. Legal counsel for the Father shall notify Mother's counsel in writing with respect to which days Father will exercise custody on Saturdays. 2. Father shall also enjoy temporary custody of the minor children on one evening per week to be arranged between the parties. The timeframe shall be from 4:00 p.m. until 7:00 p.m. Father shall give Mother at least 24 hours notice as to when he intends to exercise custody on a weekday evening. 3. It is understood that Mother needs to encourage both minor children to go with Father at times of temporary custody. It is also understood that Father recognizes the minor child James Scott Gossard may demonstrate some reluctance to visit with the Father, and the Father will need to be flexible in exercising temporary custody with the minor child James depending upon James' preference. 4. Legal counsel for the parties shall conduct another telephone conference conciliation with the conciliator on Friday, May 31,2002 at 8:30 a.m. BY J. cc: /Marylou Matas, Esquire "Marcus A. McKnight, Esquire Edward E. Guido 7~~ ~-63-0f( .,~ O'."~_~~ -- "'''', '-'''"'i.:'- ~_,_,- - <_'''0' ""-,- -^", " -~.' ii.i8i ." ~'~""" "'-"~""Llii. '''"', . tM"Ililllll!Dilii:~~1if "^~--~'-'-~-_N~"=~~-l 1:1 ,-~ - )~'~i I ! r' ",. l'~~' I,} 1 f l ,.. '.( 1 I., (~. I,. 9: 2! -;,., i\l"; C'" ',',,' -'~UN"v ul'v\tj~.:.i~Lh\!U \..AJ ' q I PENNSYD/ANi!\ ~ SHERI L. DOVE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW LARRY GOSSARD, Defendant NO. 00 - 4656 CIVIL IN CUSTODY Prior Judge: Edward E. Guido CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. Counsel for the parties conducted a telephone conference call with the conciliator, and the conciliator recommends the attached order in accordance with the agreement reached during the telephone conference call. 'fl3rOdl DATE f/lktJ Hubert X. Gilroy, squire Custody Conciliat r :~,-~ . "':_-'~-~f,,,:<'TI-:,,-_,\, " " ~""""-'- ,'~,~ "'__-_~_. ,. ,~,_ "'_,_ _ ,--., " "."., ..,....,.,. , JUL~ 2002 SHERI L. DOVE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV ANlA v CIVIL ACTION - LAW LARRY GOSSARD, Defendant NO. 00 - 4656 CIVIL IN CUSTODY COURT ORDER AND NOW, this Ji)). day of July, 2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that this court's prior orders of February 27, 2002 and May 3, 2002 shall remain in effect subject to the following conditions: 1. The Father shall have overnight temporary custody with the minor children from Friday, August 16, 2002 at 5:30 p.m. until Saturday, August 17, 2002 at 7:00 p.m. and from Friday, August 30, 2002 at 5:30 p.m. until Saturday, . August 31, 2002 at 7:00 p.m. 2. The Father's evening temporary custody during the week pursuant to Paragraph 2 of the May 3, 2002 Order sll1all be modified to be from 5:30 p.m. until 8:00 p.m. 3. Upon the conclusion of the two mentioned overnight periods of temporary custody, counsel for the parties shall exchange a proposed schedule between each other in writing with respect to future temporary custody for the Father. If the parties are unable to work out an agreement, counsel for either party may contact the conciliator to schedule a custody conciliation conference via a telephone conference call with the two attorneys and the conciliator, with no requirement for the parties to be in attendance. It shall be the responsibility of the Father through his attorney to present a written schedule to Mother's counsel to initiate a resolution of a permanent schedule. J. cc: Marcus McKnight, Esqnire Marylou Matas, Esquire ~ ~1J~~/o~, ,,2,."'f> . Of'_~ -. . '0' - ~- -",' " '-, 7\'- , ___ "" . .-~ . ,- '," 'W~ ~. , '-iC'""'"""-'unlilill! "",,- ,~ ~- r"';-~~-~[~-iM!1f1il'~" - -,--" - ~.~ '~ FllElH)ITfCE OF TH-: P?,=~:;I-:C\()T/!IRY 02.JUl22 pj'i I?: S2 CUM8EfiiJt'iU COUNTY PENNSYLVANIA ,,1, '", 'c' , '" , SlfIERI L. DOVE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBEkLAND COUNTY, PENNSYLV ANlA v CIVIL ACTION - LAW LARRY GOSSARD, Defendant NO. 00 - 4656 CIVIL IN CUSTODY Prior Judge: Edward E. Guido CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The conciliator met with counsel for the parties and the Plaintiff, Sheri L. Dovl1 in a custody conciliation conference which was the third conference in this case. Based upon tlnat conference, the conciliator recommends the entry of an order in the fonn as attached. r"J!I?!(J.J, DATE alf-KJ Hubert X. Gilroy, Esquire Custody Conciliator ~"~,,',r~ . ~ "".,-,,~,,- ,__'''"!':-''~ _."'''''_',.1','__" --" -"','-", ., ".,-. _. ~, ,W "u-, . APR 2 3 Z003 \\ SHERI L. DOVE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v CIVIL ACTION - LAW LARRY GOSSARD, Defendant NO. 00 - 4656 CML IN CUSTODY COURT ORDER AND NOW, this J~~ day of April, 2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that the prior custody orders entered in this case are vacated and replaced with the following order: 1. The Mother, Sheri L. Dove, shall enjoy legal and physical custody of James Scott Gossard, born February 25, 1990 and Sarah C. Gossard, born December 14,1995. 2. The Father, Larry Gossard, shall enjoy periods of temporary physical custody with the minor children at such times and under such circumstances as agreed upon by the parties. 3. In the event either party desires to modify this order and, more specifically, in the event Father desires to seek a specific visitation schedule with the minor children, that party may petition the conrt to have the case again scheduled with the conciliator for a custody conciliation conference and may also request that the case be schednled before the court for a hearing after the custody conciliation conference. 4. This order is entered subject to the understanding that the parties have reached a separate agreement between themselves relative to support obligations for the minor children, and legal counsel for the parties can file with the Cumberland County Domestic Relations Office appropriate documentation to implement that agreement. J. cc: EdwardE. Gui~~ :~.... ~ ~aryIOU Matas, Esquire ~ ~ ~ )larcus A. McKnight, Esquire) L-- -\"\ ~t? lb,6? D~'~ ",~'"'l""''':''!r-_'''"__"_~"c. c- ,0""'_" ,-~' _, ~,,_,;> ~,,- - ,- ~- - -,-- 'O'~m- ~.~ ~-~lWliir""""'" ~~- ~""~"-""<j!j]~_lOMlrW~101H; :&i8.~~ "":"",,~'[-7".~_,"'i_'F'_,,,_~, ~,' ~~_ _r__ 1::.1, r'::I,",-('Ji-:'FJf'E i ,,~:..,. ",-" n.1 OF i,\;-:'(':T,L,,'fJ>!~)T/!J1Y 03~PR28 PH 9:3! CUMBEhU/iLi COUNTY PENNSYLVANIA W-".-ff''''''''- '~'_::---O ,.~- 1'" - il!W~ '( . SHERI L. DOVE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERlLAND COUNTY, PENNSYLV ANlA v CIVIL ACTION - LAW LARRY GOSSARD, Defendant NO. 00 -4656 CIVIL IN CUSTODY Prior Judge: Edward E. Guido CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CML RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent infonnation pertaining to the children who are the subject of this litigation is as follows: James Scott Gossard, born February 25, 1990 and Sarah C. Gossard, born December 14,1995. 2. A Conciliation Conference was held on April 22, 2003, with the following individuals in attendance: The Mother, Sheri L. Dove, with her counsel, Marylou Matas, Esqnire; and the Father, Larry Gossard, with his counsel, MarclJls A. McKnight, Esquire. 3. The parties agree to the entry of an order in the fonn as attached. Y!;J3/0 j DATE , " :1 I '," _,'N~ ' - - -' ""'-"""'':'-~'''~~~-'"''''';' "'-, .",-" "," ~~:n~,~'r""'~" _ ,'" -'" ,-"-' .,. ,'--