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HomeMy WebLinkAbout07-0976JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. VALERIE C. TAYLOR Defendant IN DIVORCE NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, 1 Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 SAIDIS, FLOWER & LINDSAY SAIMS, LINDSAY AnUaNEVS.Al:?W 26 West High Street Carlisle, PA Mary`ibu atas, Es4dire Supre Court ID No. 84919 26 West High Street Carlisle, PA 17013 717-243-6222 r JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW VALERIE C. TAYLOR NO _ q 7L ?? (+c.., Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Jeffrey C. Taylor, an adult individual residing at 135 Rodney Lane, Camp Hill, PA 17011. 2. The Defendant is Valerie C. Taylor, an adult individual residing at 334 East Meadow Drive, Mechanicsburg, PA 17055. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 20, 1985 in Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that he has the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. SAMIS, LINDSAY ZMEWMA?r uw 26 West High Street Carlisle, PA WHEREFORE, Plaintiff requests entry of a divorce decree in his favor in accordance with §3301 of the Pennsylvania Divorce Code. COUNTI EQUITABLE DISTRIBUTION 8. The averments in paragraphs 1 through 7 are incorporated hereto as if fully set forth herein. 9. During their marriage, the parties have acquired certain property, both personal and real. WHEREFORE, Plaintiff requests this Court to equitably divide the marital property. Respectfully submitted, FLOWER ? LINDSAY errow?exs•,v uw 26 West High Street Carlisle, PA Dated 4 2016 SAIDIS, FLOWER & LINDSAY Marylou atas, Esquire Attorney Id. 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff U VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsifications to authorities. Date: Jeffs aylor FLOWER ? LINDSAY n? ?otav?ts eruw 26 West High Street Carlisle, PA .? ? O C A 44 Y C; Cz, P 0 n c C? C fl l N d i -1 ' JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 07-976 VALERIE C. TAYLOR, CIVIL ACTION -LAW Defendant IN DIVORCE PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY OF SAID COURT: Please enter my appearance as attorney for the Defendant in the above-captioned matter. Respectfully submitted, Catherine A. Boyle, Esquire Attorney I.D. 76328 Meyers, Desfor, Saltzgiver & Boyle 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717)236-9428 Attorney for Defendant MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX(717)236-2817 r, -% JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 07-976 VALERIE C. TAYLOR, CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I hereby certify on this day of /tk4LA- 0 ?1 , 2007 a copy of the foregoing Praecipe to Enter Appearance was sent via U.S. Mail, postage paid to: Jeffrey C. Taylor c/o Marylou Matas, Esquire SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA 17013 Respectfully submitted, MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 l Catherine A. Boyle, Esquir Attorney for Plaintiff -TI t :t C r JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 07-976 VALERIE C. TAYLOR, CIVIL ACTION -LAW Defendant IN DIVORCE To: Jeffrey C. Taylor c/o Marylou Matas, Esquire SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA 17013 NOTICE TO PLEAD You are hereby notified to file a written response to the enclosed Defendant's Answer to Plaintiff's Complaint in Divorce and Counterclaims within twenty (20) days from service hereof or a judgment may be entered against you. "ot - - &X Catherine A. Boyle, Esquire Attorney for Defendant MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 07-976 VALERIE C. TAYLOR, : CIVIL ACTION -LAW Defendant : IN DIVORCE DEFENDANT'S ANSWER TO PLAINTIFF'S COMPLAINT IN DIVORCE AND COUNTERCLAIM AND NOW, comes Defendant, Valerie C. Taylor, by and through her attorneys, Meyers, Desfor, Saltzgiver & Boyle, and files this Defendant's Answer to Plaintiff's Complaint in Divorce and Counter Claims, and avers as follows: 1. Admitted. 1 2. Admitted. 1 3. Admitted. 1 4. Admitted. 5. Admitted. 6. This averment contains conclusions of fact or law to which no answer is required. 7. This averment contains conclusions of fact or law to which no answer is required. WHEREFORE, Defendant, Valerie C. Taylor, respectfully requests this Honorable Court deny Plaintiffs request for entry of a Divorce Decree in his favor. MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 COUNTI EQUITABLE DISTRIBUTION 8. No answer required. 9. Admitted. By way of further answer, said property, both personal and real is subject to equitable distribution under the Divorce Code. WHEREFORE, Defendant, Valerie C. Taylor, respectfully requests this Honorable Court equitably distribute all property, both personal and real, tangible and intangible, acquired by the parties during their marriage. COUNTERCLAIM COUNTI INDIGNITIES 10. Paragraphs one through nine of the Complaint are incorporated by reference as if fully forth herein. 11. The grounds upon which this action is based are indignities pursuant to Section 3301(a)(6) of the Divorce Code. During the marriage, the Plaintiff has committed such indignities against the Defendant so as to make her life burdensome and intolerable. 12. Defendant requests the Court issue a decree in divorce based upon indignities pursuant to section 3301(a)(6) of the Divorce Code. WHEREFORE, Defendant, Valerie C. Taylor, respectfully requests this Honorable Court to issue a Decree in Divorce divorcing her from the bonds of matrimony pursuant to Section 3301(a)(6) of the Divorce Code. 2 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 COUNT II ALIMONY PENDENTE LITE, SUPPORT, COUNSEL FEES, AND EXPENSES 13. Paragraphs one through twelve of the Complaint are incorporated by reference as if fully set forth herein. 14. By reason of this action, Defendant will be put to considerable expense in the preparation of this case, in the employment of counsel, and the payment of costs. 15. Defendant is without sufficient funds to support herself and to meet the costs and expenses of this litigation, and unable to appropriately maintain herself during the pendency of this action. 16. Defendant's income is not sufficient to provide for her reasonable needs and pay her attorneys' fees and the costs of this litigation. 17. Plaintiff has adequate earnings to provide support and alimony pendente lite to the Plaintiff and to pay his counsel fees, costs and expenses. WHEREFORE, Defendant, Valerie C. Taylor, respectfully requests this Honorable Court ! compel the Plaintiff to pay Defendant alimony pendente lite, support, counsel fees, costs and expenses of this action. COUNT III ALIMONV 18. Paragraphs one through seventeen of the Complaint are incorporated by reference as if fully set forth herein. 19. Defendant lacks sufficient property to provide for her reasonable needs. MEYERS, DESFOR, SAL7ZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 20. Defendant is unable to sufficiently support herself through appropriate employment. 21. Plaintiff has sufficient income and assets to provide continuing support and to pay alimony to the Defendant. WHEREFORE, Defendant, Valerie C. Taylor, respectfully requests this Honorable Court compel Plaintiff to pay alimony to Defendant. COUNT IV APPRAISAL AND ACCOUNTANT FEES 22. Paragraphs one through twenty-one of the Complaint are incorporated by reference as if fully set forth herein. 23. By reason of this action, Defendant will be put to considerable expense in the computation and estimation of the value of the parties' residence and various other assets acquired by the parties during the marriage. 24. In order to ascertain the value of the residence and other marital assets, Defendant requires the services of an appraiser and a certified public accountant. 25. Defendant is without sufficient funds to meet the costs and expenses of these services is unable to comply with the Rules of Court requiring the filing of various income and inventory statements without the services of the above experts. 26. Plaintiff has adequate earnings to provide for these costs and expenses. WHEREFORE, Defendant, Valerie C. Taylor, respectfully requests this Honorable Court 4 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX(717)236-2817 grant Defendant sufficient funds from Plaintiff to pay the expenses of an appraiser and a certified public accountant. Respectfully submitted, atherine A. Boyle, Esquire Attorney I.D. 76328 Meyers, Desfor, Saltzgiver & Boyle 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717)236-9428 Attorney for Defendant MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 VERIFICATION I, Valerie C. Taylor , verify that the statements made in this Defendant's Answer to Plaintiff's Complaint in Divorce and are true and correct to the best outs erc aim . of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: 3/7/2007 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 (X ) Defendant JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 07-976 VALERIE C. TAYLOR, CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I hereby certify on this day of a-t-c- ? , 2007 a copy of the foregoing Defendant's Answer to Plaintiff's Complaint in Divorce and Counterclaims was sent via U.S. Mail, postage paid to: Jeffrey C. Taylor c/o Marylou Matas, Esquire SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA 17013 Respectfully submitted, ?/? - _ ?? L_? Catherine A. Boyle, Esquir Attorney for Defendant 6 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 G C u W 1? .x,11 w : C n) :.c JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 07-976 VALERIE C. TAYLOR, CIVIL ACTION -LAW Defendant IN DIVORCE PETITION FOR ALIMONY PENDENTE LIM COUNSEL FEES, COSTS AND EXPENSES AND NOW, comes the Petitioner, Valerie C. Taylor, by and through her attorneys, Meyers, Desfor, Saltzgiver & Boyle, and files the following Petition for Alimony Pendente Lite, Counsel Fees and Expenses and in support thereof avers as follows: 1. Petitioner is Valerie C. Taylor, an adult individual who currently resides at 334 East Meadow Drive, Mechanicsburg, Pennsylvania (hereinafter known as "Wife"). 2. Respondent is Jeffrey C. Taylor, an adult individual who currently resides at 135 Rodney Lane, Camp Hill, Pennsylvania (hereinafter known as "Husband"). 3. The parties were married on April 20, 1985, at Harrisburg, Pennsylvania. 4. A Complaint in Divorce was filed by Husband on February 21, 2007. 5. Wife filed an Answer and Counterclaim simultaneously with a Petition for Alimony Pendente Lite, Counsel Fees, Costs and Expenses. 6. Wife's Counterclaim contains a count requesting Alimony Pendente Lite, Support, Counsel Fees, Costs and Expenses. 7. Since the date of separation, Wife has received little to no money from Husband. 2 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 8. By reason of this action, Wife will be put to considerable expense in the preparation of her case, in the employment of counsel and the payment of costs and expenses. 9. Wife is without sufficient funds to support herself and to meet the costs and expenses of this litigation and is unable to appropriately maintain herself during the pendency of this action. 10. Wife's income is not sufficient to provide for her reasonable needs and to pay attorney's fees and the costs of this litigation. 11. Husband has adequate earnings to provide support and alimony pendente lite for the Wife and to pay her counsel fees, costs and expenses. WHEREFORE, the Petitioner, Valerie C. Taylor, respectfully requests this Honorable Court award her Alimony Pendente Lite. Respectfully submitted, Catherine A. Boyle, Esquire,/ Attorney I.D. 76328 ?? Meyers, Desfor, Saltzgiver & Boyle 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717)236-9428 Attorney for Petitioner 3 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 VERIFICATION I, Malerie C. Taylor verify that the statements made in this Petition for Alimony Pendente Lite, Counsel Fees, Costs and Expenses are true and correct to the bes of my knowledge, information and belief. I understand that fals statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: 3/7/2007 (X ) Defendant MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 07-976 VALERIE C. TAYLOR, CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that on thi day of &A_a- , 2007, a copy of the attached Petition for Alimony Pendente Lite, Counsel Fees, Costs and Expenses was mailed, postage prepaid, to: Jeffrey C. Taylor c/o Marylou Matas, Esquire SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA 17013 Catherine A. Boyle, Esquire Attorney for Petitioner 4 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX(717)236-2817 c ? T 77 t ? y z JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 07-976 VALERIE C. TAYLOR, CIVIL ACTION -LAW Defendant IN DIVORCE EMERGENCY PETITION FOR SPECIAL RELIEF AND FOR COUNSEL FEES, COSTS AND EXPENSES AND NOW, comes the Plaintiff, Valerie C. Taylor, by and through her attorneys, Meyers, Desfor, Saltzgiver & Boyle, and files this Emergency Petition for Special Relief and for Counsel Fees, Costs and Expenses and in support thereof avers as follows: 1. Defendant is Valerie C. Taylor, an adult individual currently residing at 334 East Meadow Drive, Mechanicsburg, Cumberland County, Pennsylvania (hereinafter referred to as "Wife"). 2. Plaintiff is Jeffrey C. Taylor, an adult individual residing at 135 Rodney Lane, Camp Hill, Cumberland County, Pennsylvania (hereinafter referred to as "Husband"). 3. The parties are husband and wife, having been lawfully married on April 20, 1985. 4. Husband filed a Complaint in Divorce on February 21, 2007. Wife filed an Answer and Counterclaim on or about March 8, 2007. 5. Since 1995, the parties have owned and operated the Mermaid Carwash in Mechanicsburg, Pennsylvania (hereinafter referred to as the "Carwash"). 6. The Carwash is made up of five (5) self-service bays and two (2) automatic bays. The automatic bays contain a counter of the vehicles that use the bays. One of the two automatic bays was only installed two (2) years ago. There are no counters in the self- service bays. Wife believes that there is no means to count the majority of the vehicles MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX(717)236-2817 that use the Carwash. Wife is also uncertain as to the ability to re-set the counters or whether the counters have been re-set since installation in 1995. 7. Additionally, the Carwash owns and operates islands for vending, containing the vacuums, air and other car related items 8. Gross revenue for the Carwash is generated solely by payment of cash. During the marriage, Husband was responsible for emptying the cash generated by the bays. A vault vacuum system empties the coins into a central location, but does not count them. Cash generated by the island was emptied by Husband, by hand, at least once per month. All collected cash was counted by Husband personally. 9. During the marriage, Husband was and is currently, solely in control of all revenues generated the business. Wife is not sure as to Husband's practices for collection of the cash at this time and he has been doing so without Wife's knowledge or participation. 10. During the marriage, Husband also managed and maintained the books and records for the Carwash. Since separation, Husband has taken sole responsibility of management and bookkeeping, to the exclusion of Wife. 11. Wife believes that Husband withholds cash from the business prior to preparing the books and records, which are used for tax return preparation. 12. Wife also believes that Husband pays all of his personal expenses through the Carwash, including all expenses associated with the parties' forty-five (45) foot Benetau Sailboat. 13. The parties' Sailboat was acquired during the marriage for approximately $195,000.00, 8 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 and Wife estimates the monthly maintenance, storage and usage expenses for same at $3,500.00. 14. Wife has no recent business records for the Carwash and has no access to same. Moreover, Wife is uncertain whether the business records maintained by Husband accurately reflect the revenue generated by the Carwash. 15. Husband also owns several business interests with his family. Husband is a 9.63% shareholder and an officer in Taylor Enterprises, Inc. Wife believes the only other shareholders are Husband's parents and siblings. Taylor Enterprises is heavily involved in the purchase, sale and development of real estate. The business owns numerous properties and companies associated with all aspects of real estate. For example, Taylor Enterprises owns and operates a sewer company that provides services to a mobile home park it developed and sold in prior years. Additionally, Taylor Enterprises owns Country Manor Farms, a community for individuals aged fifty-five (55) and older, located in West Hanover, Harrisburg and several other commercial and residential properties. 16. In 2004, Husband received a distribution of at least $20,000.00 from Taylor Enterprises. In 2005, Husband's Form 1120S Schedule K-1 indicates $53,920.00 in business and interest income. Wife has no knowledge of when or if these funds were received or how same were expended. 17. Husband and his siblings also own an interest in the Charles J. Taylor Trust. Among the holdings in said trust is the CJSPT Limited Partnership. In 2005, the Partnership sold a property on Limekiln Road for approximately $11,500,000.00. Husband's 2005 9 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 Grantor Letter indicates that the Partnership reported a gain on the sale of at least $1,865,339.00. Wife has no information concerning the particulars of the sale. She is aware that he received at least one distribution of $89,145.00. She does not know if additional monies were ever paid to Husband. The Trust also reports in excess of $1,000,000.00 in interest and dividend income in 2005. 18. Wife believes that the Charles J. Taylor Trust owns several other commercial properties, including the Fairview Summit Business Park, which is currently under construction, and is located on Lewisberry Road, New Cumberland. 19. Wife believes that Husband may hold other business interests with his family. 20. Wife has no access to information concerning Husband's family business interests. Wife believes that these interests are in Husband's name alone and if left unprotected, Husband may transfer or dissipate same. 21. Moreover, Wife's health insurance is provided through Taylor Enterprises. She is concerned that Husband may terminate her health insurance or decrease her coverage. 22. Further, Husband is currently employed as a commercial real estate agent with Keller Williams. Wife believes that Husband may be placing listings in other agent's names as well as delaying closings to avoid the payment of support. Husband may also be the agent for the family businesses and the Trust, and have intimate involvement with the aforementioned and other sales. 23. Other than the Carwash, from which Wife is now excluded, Wife has no other means of support. Wife has both a support action and Petition for Alimony Pendente Lite pending. 10 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 24. At separation, Husband abandoned the marital residence and moved into his parents' home in Camp Hill where he lives without expense. Husband's parents spend the majority of the year in Paradise Valley, Arizona. Wife was left to support the marital residence with little to no assistance from Husband. 25. Also since separation, Husband informed Wife that he will be receiving a rollover from a Profit Sharing Plan with Taylor Enterprises. Wife was not aware of Husband's interest in the Plan. While Husband informed Wife of the intended location of the funds, Wife is currently unsure as to whether the funds were deposited or the identity of the named beneficiary. Wife believes that Husband may dissipate said funds or identify a beneficiary other than her, thereby placing her interest in same at risk. 26. Wife also believes that Husband maintained life insurance policies during the marriage. Wife believes that Husband may cancel said policies and/or change the named beneficiary. 27. Husband also maintains a Will and Wife believes that Husband will change his named beneficiary to someone other than her, defeating her interest in the marital estate were Husband to pass away prior to equitable distribution. 28. By reason of the this action, Wife will be put to considerable expense in the preparation of her case, employment of counsel and other professionals and payment of costs and expenses. 29. Wife anticipates extensive legal fees and costs in the preparation of her case for a final equitable distribution hearing. Wife anticipates extensive discovery and depositions of Husband and various others involved with his business interests. 11 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 30. Wife is in the process of retaining Bruce Brown, CPA/CVA, to evaluate the Carwash and prepare cash flow for Husband's income. Her accountant will also value the business and Husband's family business interests. Wife will require funds for the payment of her accountant's fees. 31. Wife also anticipates the need for real estate appraisers, both commercial and residential. 32. Wife anticipates incurring at least $25,000.00 in counsel fees, costs and expenses. 33. To date, no judge has been assigned to this matter and no prior rulings have been issued. 34. Due to the emergency nature of this Petition, prior concurrence of opposing counsel was not sought. WHEREFORE, Defendant, Valerie C. Taylor, respectfully requests this Honorable Court grant her Emergency Petition for Special Relief and for Counsel Fees, Costs and Expenses and issue an Order stating that: 1. Neither party shall transfer, encumber, sell, dissipate or otherwise diminish the value of any asset held in his or her name alone or held jointly with another, without the express written consent of the other party or Order of Court; 2. Plaintiff shall not transfer, encumber, sell, dissipate or otherwise diminish the value of any business interest held in his name alone or jointly with another, without express written consent of Defendant or Order or Court; 3. Plaintiff shall be permitted, at her expense, to change the locks on the coin receptacles on the vault vacuum system and on the vending islands at the 12 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 Mermaid Carwash. Defendant shall maintain the keys and the parties shall coordinate a schedule for both to be present for the removal and counting of any monies collected from the vault vacuum system and the vending islands; 4. Plaintiff shall maintain any and all life insurance policies and Defendant shall be named as beneficiary; 5. Plaintiff shall indicate to Defendant where any money received from his Profit Sharing Plan with Taylor Enterprises is deposited and Defendant shall be named as beneficiary; 6. Plaintiff shall maintain any and all other retirement and/or pension accounts and Defendant shall be named beneficiary on same; 7. Plaintiff shall maintain a Will naming Defendant as beneficiary in same; 8. Plaintiff shall supply to Defendant's counsel an accounting of all assets and liabilities in which he holds an interest and/or for which he has signatory authority, within five (5) days of the date of this Order; 9. Plaintiff shall supply to Defendant's counsel, within five (5) days of the date of this Order, any and all documents and itemized account statements for his pension any retirement and/ or pension accounts he holds in his name alone, including but not limited to, statements concerning the rollover and/or withdrawal from his Profit Sharing Plan with Taylor Enterprises; 10. Plaintiff shall supply to Defendant's counsel proof of beneficiary on all life insurance policies and retirement and/or pension accounts, within five (5) days of the date of this Order; 13 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 11. Plaintiff shall supply Defendant with a copy of his Will, within five (5) days of the date of this Order; 12. Plaintiff shall continue to maintain Defendant's health insurance at the same level of coverage as maintained during the marriage until further Order of Court; and, 13. Plaintiff is hereby ordered to pay to Defendant $25,000.00 toward her legal counsel fees, costs and expenses. Respectfully submitted, 4i?? - A -, F2?x Catherine A. Boyle, Esquire I.D.#76328 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717) 236-9428 Attorney for the Defendant 14 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 VERIFICATION I, Valerie C. Taylor , verify that the statements made in this Emergency Petition For Special Relief and For Counsel Fees, Costs and Expenses are true and correct to the best of my knowledge, information and belief. I understand that fals( statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: 3/12/2007 MEYERS, DESFOR, SALTZGNER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 (X ) Defendant JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 07-976 VALERIE C. TAYLOR, CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I hereby certify on this - day of , 2007, a copy of the foregoing Emergency Petition for Special Relief and for Counsel Fees, Costs and Expenses was sent U.S. Mail, postage pre-paid to: Jeffrey C. Taylor c/o Marylou Matas, Esquire SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA 17013 Catherine A. Boyle, Esquire Attorney I.D. #76328 Attorney for Defendant MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 '; rri JEFFREY C. TAYLOR, THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 07-976 CIVIL TERM VALERIE C. TAYLOR, IN DIVORCE Defendant/Petitioner PACSES CASE NO: 622109022 ORDER OF COURT AND NOW, this 12th day of March, 2007, upon consideration of the Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shaddav on April 2, 2007 at 10:30 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11© (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you. If you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, Edgar B. Bayley, President Judge Copies mailed to: Petitioner Respondent Catherine A. Boyle, Esq. Marylou Matas, Esq. Date of Order: March 12, 2007 J. r, dday, Conference Officer YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 cc361 ?'' ? ?_? ? ?? - ! .?.. - -x- ' ?' =?? ;?, ?, .::: - ?._, w , ,: ?s _. ._,? -? ?m > *: ?_.: _:;_ `P -ate ..? ?. ? ^? JEFFREY C. TAYLOR, Plaintiff V. VALERIE C. TAYLOR Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 07-976 IN DIVORCE ACCEPTANCE OF SERVICE SAIDIS, FWVVER & LINDSAY nrrofwexs er uw 26 West High Street Carlisle, PA I, Catherine A. Boyle, Esq. accept service of the Divorce Complaint in the above-I captioned matter. Zo ;z- e Date Catherine A. Boyle, E uire t7 ra 0 ?" c« ash rn --? JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 07-976 VALERIE C. TAYLOR, CIVIL ACTION -LAW Defendant IN DIVORCE ACCEPTANCE OF SERVICE OF DEFENDANT'S ANSWER TO PLAINTIFF'S COMPLAINT IN DIVORCE AND COUNTERCLAIMS I, Marylou Matas, Esquire, counsel for Jeffrey C. Taylor, Plaintiff in the above- captioned matter, certify acceptance of service on behalf of Plaintiff of a copy of Defendant's Answer to Plaintiff's Complaint in Divorce and Counterclaim filed by Defendant, Valerie C. Taylor on March 9, 2007, and that I am authorized to do so. Date: 1 vcq? " Ma tas, Esquir - Attorney D #84919 Saidis, Flower & Lindsay 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiff MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 0 C+ 9 ? a 1 fir- m ! r . te ?V Ln r " JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW VALERIE C. TAYLOR, Defendant NO. 07-976 CIVIL TERM ORDER OF COURT AND NOW, this 20`h day of March, 2007, upon consideration of Defendant's Emergency Petition for Special Relief and for Counsel Fees, Costs and Expenses, a hearing is scheduled for Thursday, June 7, 2007, at 9:30 a.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. PENDING SAID HEARING neither party shall dissipate, transfer, encumber, or otherwise decrease the value of any marital property, absent court order or mutual agreement. Marylou Matas, Esq. 26 West High Street Carlisle, PA 17013 Attorney for Plaintiff VC-a'therine A. Boyle, Esq. 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 Attorney for Defendant S :rc BY THE COURT, Nnn 1 6 S :Z Wd i Z M L04Z hUVt J ilO IHI A© 3J1 --??o--aP4 JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 07-976 VALERIE C. TAYLOR, CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I hereby certify on this ?_ day of , 2007, that the foregoing Request for Production of Documents was sent via facsimile and first-class mail, postage pre- paid to: Jeffrey C. Taylor c/o Marylou Matas, Esquire Saidis, Flower & Lindsey 26 West High Street Carlisle, PA 17013 Attorney for Defendant a "ab atherine A. Boyle, Esquire 12 MEYERS, DESFOR, SAL7ZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 _ -? 7T: Cj _ _A_ ? in=s VALERIE C. TAYLOR, Plaintiff/Petitioner VS. JEFFREY C. TAYLOR, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 07-976 CIVIL TERM IN DIVORCE PACSES Case Number 622109022 ORDER OF COURT AND NOW, this 23rd day of April, 2007, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $1334.00 and Respondent's monthly net income/earning capacity is $8234.00, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $3223.00 per month payable as follows: $3223.00 per month for alimony pendente lite and $0.00 per month on arrears. First payment due: on or before the 10`h day of each month commencing on May 10, 2007. Arrears set at $5660.12 as of April 23, 2007. The effective date of the order is March 9, 2007. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C.S.§ 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the PA SCDU to: Valerie C. Taylor. Payments must be made by check or money order. All checks and money orders must be made payable to PA SCDU and mailed to: PA SCDU P.O. Box 69110 Harrisburg, PA 17106-9110 Payments must include the Respondent's PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. cc360 r -l The monthly support obligation includes cash medical support in the amount of $250.00 annually for unreimbursed medical expenses incurred for each spouse. Unreimbursed medical expenses of the oblige that exceeds $250.00 annually shall be allocated between the parties. The parry seeking allocation of unreimbursed medical expenses must provide documentation of expenses to the other party no later than March 31St of the year following the calendar year in which the final medical bill to be allocated was received. The unreimbursed medical expenses are to be paid as follows: 0% by Respondent and 100% by Petitioner. () Respondent () Petitioner (X) Neither party to provide medical insurance coverage. Within thirty (30) days after the entry of this Order, the () Respondent () Petitioner shall submit written proof that medical insurance coverage has been obtained or that application for coverage has been made. Proof of coverage shall consist, at minimum, of 1) the name of the health care coverage provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims should be made; 5) a description of any restrictions on usage, such as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms. This Order considers that the Petitioner is responsible for the first mortgage only. The parties are to submit the total amount of credit that should be credited to the Alimony Pendente lite account since the date of filing on March 9, 2007. The credit will not exceed the current retroactive arrearage amount. This Order shall become final twenty (20) after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary for a hearing de novo before the Court. Consented: Petitioner Respondent Petitioner's Attorney Respondent's Attorney BY THE COURT, J. V,fj?esley Oler, Jr., -/ J. Mailed copies on: APR 2„ 7 2007 to: Petitioner Respondent Catherine A. Boyle, Esq. Marylou Matas, Esq. DRO: R.J. Shadday n ? p r • ? ni *a. G i? ' C_ w Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 JEFFREY C. TAYLOR, : IN THE COURT OF COMMON PLEAS Plaintiff, V. VALERIE C. TAYLOR, Defendant : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 976 : CIVIL ACTION -LAW DIVORCE PRAECIPE TO WITHDRAW APPEARANCE Please withdraw my appearance on behalf of JEFFREY C. TAYLOR in the above-captioned matter. Dated: 5 , 2007 Respectfully submitted, Marys, Esquire SAIDIS, F O ER & LINDSAY 26 West High Street Carlisle, PA 17013 (717) 243-6222 Supreme Court I.D. PRAECIPE TO ENTER APPEARANCE Please enter my appearance on behalf of JEFFREY C. TAYLOR in the above-captioned matter. Dated: v '2007 (717) 774-1445 Supreme Court I.D. 32317 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 ? ? C c W --' .-t ,?' r.» c:. s ? A. I% JEFFREY C. TAYLOR, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs : CIVIL ACTION - DIVORCE NO. 07-976 CIVIL TERM VALERIE C. TAYLOR, : IN DIVORCE Defendant PACKS Case No. 622109022 PETITION TO REQUEST A DE NOVO HEARING 1. Petitioner is Valerie C. Taylor, an adult individual currently residing at 334 East Meadow Drive, Mechanicsburg, Pennsylvania (hereinafter known as "Wife"). 2. Respondent is Jeffrey C. Taylor, an adult individual currently residing at 135 Rodney Lane, Camp Hill, Pennsylvania (hereinafter known as "Husband"). 3. The parties are husband and wife having been married on April 20, 1985 and subsequently separated on or about October 16, 2006 when Husband vacated the marital residence. 4. Husband filed a Complaint in Divorce on or about February 21, 2007, requesting a no- fault divorce and equitable distribution. 5. On March 9, 2007, Wife filed an Answer and Counterclaim, requesting, among other things, a fault divorce based upon Indignities, alimony pendente lite, alimony and fees. 6. At about the same time as Wife filed her Answer and Counterclaim, she initiated a support action and filed a Petition for Alimony Pendente Lite, Counsel Fees, Costs and Expenses. 7. Thereafter, on April 23, 2007, a conference was held and an order issued requiring MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 Husband to pay to Wife monthly alimony pendente lite. 8. However, Wife believes the conference officer improperly calculated Husband's income and expenses. 9. Wife believes the conference officer improperly failed to note a payment toward arrears. 10. Wife believes that the conference officer improperly characterized the payments as alimony pendente lite. The payments should properly be characterized as spousal support. 11. Wife believes that the conference officer improperly credits Husband for payments made to Wife or on her behalf. WHEREFORE, Defendant, Valerie C. Taylor, respectfully requests this Honorable Court schedule a De Novo Hearing regarding the matters of support and alimony pendente lite. Respectfully submitted, a,&,- e?^' 9/?- Catherine A. Boyle, Esquir Attorney I.D. 76328 Meyers, Desfor, Saltzgiver & Boyle 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717)236-9428 Attorney for Defendant MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 VERIFICATION I, Valerie Taylor , verify that the statements made in this Petition to Request a De Novo Hearing are true and correct to the bes of my knowledge, information and belief. I understand that fal statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: 5/17/07 (X ) Defendant MEYERS, DESFOR, SALTZGIVER 3 BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 - FAX(717)236-2817 ( ) Plaintiff JEFFREY C. TAYLOR, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs : CIVIL ACTION - DIVORCE NO. 07-976 CIVIL TERM VALERIE C. TAYLOR, : IN DIVORCE Defendant : PACSES Case No. 622109022 CERTIFICATE OF SERVICE I hereby certify on this 11"I-day of1k., 2007, that a copy of the foregoing Petition to Request a de novo hearing was sent via facsimile and mailed, first-class, postage pre-paid to: Jeffrey C. Taylor C/o Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 4?- - ?.' Catherine A. Boyle, Esquire Attorney for Petitioner MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 C) C ?` ? -s "'? ", f"?l ...? '.."" ---! iTl _?G , _-? ? .". '? '??i'1 H " ?. ?? W .+"}? - In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION VALERIE C. TAYLOR ) Docket Number 07-976 CIVIL Plaintiff ) VS. ) PACSES Case Number 622109022 JEFFREY C. TAYLOR ) Defendant ) Other State ID Number ORDER OF COURT You, VALERIE C. TAYLOR plaintiff/defendant of 334 E MEADOW DR, MECHANICSBURG, PA. 17055-5187-34 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the JULY 16, 2007 at 9: ooAM for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income Statement and the appropriate Expense Statement, if required, attached to this order, completed as required by Rule 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. information relating to professional licenses 7. other: Service Type M Form CM-509 Rev. 1 Worker ID 21302 TAYLOR v• TAYLOR PACSES Case Number: 622109022 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest and/or enter an interim support order. If paternity is an issue, the court shall enter an order establishing paternity. THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD TO WHICH PARTY INITIATED THE SUPPORT ACTION. BY THE COURT: Date of Order: ??' ^ o c, 7 J//WESLEY @dR, JR. , JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE-HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 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 at: (717) 2 4 0 - 6 2 2 s . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Rev. Service Type M Worker ID 21302 -? r '°> ? -- _ ?=?.? n -- - - _i _ t1rr'^ _ ?.y , t._?"y ? ? -? + ? ? . - t - ?.?. -^,` ?; In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION VALERIE C. TAYLOR ) Docket Number 07-976 CIVIL Plaintiff ) vs. ) PACSES Case Number 622109022 JEFFREY C. TAYLOR ) Defendant ) Other State ID Number ORDER OF COURT You, JEFFREY C. TAYLOR plaintiff/defendant of PO BOX 131, GRANTHAM, PA. 17027-0131-31 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the JULY 16, 2007 at 9 : ooAM for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income Statement and the appropriate Expense Statement, if required, attached to this order, completed as required by Rule 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. information relating to professional licenses 7. other: Service Type M Form CM-509 Rev. 1 Worker ID 21302 if N TAYLOR PACSES Case Number: 622109022 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest and/or enter an interim support order. If paternity is an issue, the court shall enter an order establishing paternity. THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD TO WHICH PARTY INITIATED THE SUPPORT ACTION. BY THE COURT: Date of Order: 4_)_00? Jr/WESLEY O R, JR., JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE-HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. v• TAYLOR CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 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 at: (717) 240-6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Rev. 1 Service Type M Worker ID 21302 n? -r, T-TI G3 ] ?? Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. VALERIE C. TAYLOR, Defendant NO. 2007 - 976 CIVIL ACTION -LAW DIVORCE REPLY TO THE EMERGENCY PETITION FOR SPECIAL RELIEF FOR COUNSEL FEES, COSTS AND EXPENSES 1 2. Admitted. Admitted with the clarification that this is Husband's parents' home address. It is averred that Plaintiff has leased a rental property. 3. Admitted. 4. Admitted. 5. Admitted. I 6. Admitted in part. Denied in part. The averments of the paragraph are admitted as they relate to configuration of the carwash. The remainder of the paragraph is denied since Respondent is without knowledge as to the beliefs of Wife. 7. Admitted. 8. Admitted in part. Denied in part. It is admitted that this is a cash business. It is denied that Husband was solely responsible for emptying the cash generated bays. Wife was also involved and provided counting. 9. Denied. It is denied that Husband was solely in charge of revenues during the marriage. Wife had been participating in the operation of the car wash although Husband was charged with its primary operation. 10. Admitted in part. Denied in part. It is denied that Wife was not involved in the bookkeeping and records for the car wash. It is admitted that since separation, Husband has had the sole responsibility of managing and bookkeeping. It is further averred that Husband has taken no action to exclude Wife's participation in the business. 11. Denied. This paragraph is denied since Husband is without information as to the beliefs of Wife. By way of further answer, it is averred that as a part of the 2 support proceedings, Husband has admitted that it was the parties' practice to take some non-recorded cash for reserve. This "reserve" has now been included in the calculation of support for Wife as income for Husband. 12. Admitted in part. Denied in part. This paragraph is denied since Husband is without knowledge as to the belief of Wife. By way of further answer, Husband denies paying his personal expenses through the car wash. However, Husband does admit that he has paid the parties' expenses through the car wash. This includes the boat and house expense. Any monies expended by Husband have been consistent with the parties' handling of the cash during the marriage and same has been included in the support proceedings. It is admitted that the monies borrowed against the business building were used for acquisition of a boat. It is also averred that significant other liens exists on the building which includes in excess of a $600,000.00 Note to Husband's parents and debt owed Adams County National Bank. 13. Admitted in part. Denied in part. It is admitted that the boat was purchased for approximately $195,000.00. It is denied that the monthly maintenance, storage and usage expenses are $3,500.00. Husband avers that these costs are approximately $2,700.00 per month and continue to be a marital debt. 3 V 14. Denied. Wife has been provided with documentation and income incident to the discovery process. The most latest of these documents continue to be with the parties' accountant and full access to these most recent records will be provided to Wife once the tax return preparations are completed. 15. Admitted in part. Denied in part. It is admitted that Husband has a non-marital interest of 9.63% in Taylor Enterprises, Inc., a family business. This minority stock interest is not a marital asset. The income purportedly generated by this interest has already been included in the calculation of support. It is denied that Taylor Enterprises, Inc. owns and operates a sewer company that provides services to a mobile home park it developed and sold in prior years. It is admitted that Taylor Enterprises owns Country Manor Farms. It is denied that they own several other residential properties. 16. Admitted in part. Denied in part. It is admitted that income was received. It is further noted that this income was disclosed as part of the support process. It is denied that WIFE is unaware of how these funds were received or how they were expended. These funds were deposited into the Merrill Lynch joint account. 17. Admitted in part. Denied in part. It is admitted that Husband has a non-marital interest in the Charles J. Taylor Trust. The description of the Trust property is accurate. The remainder of the averments are denied since Plaintiff is without 4 information necessary to form a belief as to the truth of the averment. By way of further answer, this is a non-marital asset. 18. Denied. It is denied that the Charles J. Taylor Trust owns these properties. It is noted that this property is owned by CJSPT and no other properties are owned. The property is not under construction. 19. Denied. After reasonable investigation, Husband is unaware of what Wife believes. It is denied that Husband has any other family business interests. 20. Admitted in part. Denied in part. It is admitted that Wife has no access to information concerning Husband's family business except that all records relating to the Trust are located in the marital home in the sole and exclusive possession of Wife. It is also asserted that to a large extent, Husband does not have access to significant information concerning the business because he is no longer within the employee of the family. It is noted that these interests are non-marital as a gift from the family to Husband alone. The only potential claim that Wife may have on any of these family business interests is the increase in same from the date Husband acquired the asset to the date of separation on October 17, 2006. 21. Admitted in part. Denied in part. Admitted that Wife's health insurance was covered by Taylor Enterprises. It is denied that Husband took any action to 5 terminate the coverage. It is denied that since the date of filing of this petition, Wife sought support and this issue has been ruled upon by the court since Wife has been awarded Alimony Pendente Lite. Wife has now become employed. The support order requires Wife to maintain her own coverage. 22. Admitted in part. Denied in part. It is admitted that Husband is currently working two jobs to meet the expenses of the parties. There is absolutely no basis for Wife to believe that Husband would falsify his sales records or avoid closing sales. Husband is not an agent for family business transactions. 23. Denied. It is denied that Wife has no other means of support. There is an existing Alimony Pendente Lite Order and she is presently employed. 24. Denied. It is denied that Husband abandoned the marital home. The parties' separated with mutual consent. Husband did move into his parent's home to avoid conflict and had insufficient funds to immediately secure alternate housing. Husband then was locked out of the marital home and continues to be excluded. During that time and until Wife filed for support, Husband was making all necessary payments and contributing to the joint Merrill Lynch account from which Wife withdrew. The living arrangements of Plaintiff's parents are irrelevant. 6 25. Admitted. It is further admitted that said property was rolled over and deposited into a Merrill Lynch IRA (Acct. No. 872-71613). Copies of these statements were provided to Wife in discovery. 26. Denied. There were no life insurance policies for these parties in existence at the time of separation. Prior policies had lapsed due to Wife's non-payment in 2002. 27. Denied. Paragraph 27 is denied as a conclusion of law to which no responsive pleading is due. The PEF Code and the Divorce Code are in effect to cover this situation. The assets of the parties are predominantly jointly titled. There are no minor children of this marriage. Wife is presently working and can provide for herself. 28. Admitted in part. Denied in part. It is admitted that each party will bear expense to conclude the divorce, especially if costs are escalated by petitions of this nature. 29. Denied. After reasonable investigation, Husband is without knowledge to form a belief as to the truth of Wife's beliefs. It is averred that the marital assets of the parties are nominal and conclusion of this case is not complex. 30. Denied. After reasonable investigation, Husband is without knowledge to form a belief as to the truth of the matter. Wife can expend as much money as she desires 7 in litigation, but these funds should be paid by her own separate monies. Husband does not have the means to pay for such evaluation. 31. Denied. After reasonable investigation, Husband is without knowledge to form a belief as to the truth of the matter. Husband does not have the ability to pay for Wife's fees. 32. Denied. After reasonable investigation, Husband is without knowledge to form a belief as to the truth of the matter. It is denied that such fees are reasonable for a case of minimal asset value. 33. Admitted with the clarification that Judge Oler was subsequently assigned to this matter. 34. Denied that any emergency exists. The only emergency created is that Wife sought support and an order was entered. Wife received less than what Husband had voluntarily been paying. Since that time, Wife has not made house payments on the marital home in which she solely resides. Foreclosure notice for the property have been received. Husband requests that an order be entered requiring Wife to make the necessary payments on the home to avoid foreclosure. It is also learned that monies in the form outstanding water and other bills exist. Husband 8 desires that those liabilities be changed to Wife's name and paid by her. In the event no payment is made, then the house should be listed for sale. WHEREFORE, Husband requests this honorable court deny Wife's Petition for Emergency Relief. Dated: June 7, 2007 Respectfully submitted, Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Plaintiff 9 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. VALERIE C. TAYLOR, Defendant : NO. 2007 - 976 CIVIL ACTION -LAW DIVORCE VERIFICATION I, Jeffrey C. Taylor, hereby certify that the facts set forth in the foregoing Answer are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Date: 7 ? -_ i TAYLOR Barbara Sample-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2007 - 976 VALERIE C. TAYLOR, CIVIL ACTION -LAW Defendant DIVORCE CERTIFICATE OF SERVICE I, BARBARA SUMPLE-SULLIVAN, ESQUIRE, do hereby certify that on this date, I served a true and correct copy of Plaintiff's Reply to the Petition for Special Relief, in the above-captioned matter upon the following individual by hand delivery at a hearing held this date, addressed as follows: Catherine A. Boyle, Esquire Meyers, Desfor, Saltzgiver & Boyle 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 DATED: June 7, 2007 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 Supreme Court I.D. No. 32317 (717) 774-1445 Attorney for Plaintiff 7i, c . ? -TI r _ ?r V JEFFREY C. TAYLOR, Plaintiff v VALERIE C. TAYLOR, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007-976 CIVIL TERM DIVORCE IN RE: EMERGENCY PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 7th day of June, 2007, upon consideration of Defendant's Emergency Petition for Special Relief for Counsel Fees, Costs and Expenses, and following an initial period of hearing, which has not yet been completed, the record shall remain open, and counsel are requested to contact the Court's secretary for purposes of scheduling an additional day of hearing. It is noted that at the time of adjournment on today's date only one witness had been called on behalf of the moving party. This witness was Plaintiff, Jeffrey C. Taylor, who was called as of cross. His testimony has been completed as Defendant's witness. It is further noted that at the time of adjournment on today's date Defendant's Exhibits 1, 2, 3, 4, 5, 6, 7, 8, and 9 had been identified and admitted, and Plaintiff's Exhibits 1, 2, 3, and 4 had been identified and admitted. No other exhibits had been identified or admitted. i r .Ll ;i r'i+ni 7 to 0 Both counsel have requested that the stenographer prepare and file the notes of testimony from today's proceeding. Pursuant to an agreement of counsel, the provision of the Order of Court dated March 20, 2007, requiring that neither party dissipate, transfer, encumber or otherwise decrease the value of any marital property absent court order or mutual agreement shall remain in full force and effect. By the Court, Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 For Plaintiff Catherine A. Boyle, Esquire 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 For Defendant :mae JEFFREY C. TAYLOR, Plaintiff V. VALERIE C. TAYLOR, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-976 CIVIL TERM IN RE: DEFENDANT'S EMERGENCY PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 13th day of June, 2007, a further hearing is scheduled in the above matter for Monday, October 1, 2007, at 1:30 p.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. Barbara Sumple-Sullivan, hsq. 549 Bridge Street New Cumberland, PA 17070-1931 Attorney for Plaintiff Catherine A. Boyle, Esq. 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 Attorney for Defendant 4- 13 - 7 :rc BY THE COURT, yy !?S j n ? ??? ???Q ut .,/f1 G b ila 1 1 L1 G I? } -1 ; Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. VALERIE C. TAYLOR, Defendant : NO. 2007 - 976 CIVIL ACTION -LAW DIVORCE TO THE HONORABLE JUDGES OF SAID COURT: MOTION TO COMPEL RESPONSES TO INTERROGATORIES AND DOCUMENT PRODUCTION REQUESTS AND NOW, this 29th day of June, 2007, comes the Plaintiff, Jeffrey C. Taylor, and respectfully moves this Honorable Court to Compel Responses to Interrogatories and Document Production Requests. In support thereof he avers the following: 1. The above-captioned matter involves failure of Defendant to respond to Interrogatories and Document Production Requests propounded by Plaintiff. 2. Interrogatories and Document Production Requests were initially served by Plaintiff's counsel on May 24, 2007. A true and correct copy of same is attached hereto as Exhibit A. 3. Responses were due within thirty (30) days in accordance with 42 Pa.R.C.P. 4006 and 4009.12. 4. On June 25, 2007, the day response was due, Defendant's counsel advised Plaintiff's counsel that she would not provide answers to any Interrogatory because the total number exceeded the amount provided for in the Cumberland County local rules. Also, Defendant's responses to Document Production Request were not fully answered as she responds "No documentation will be provided as the request references Plaintiff's Interrogatories, which have not been answered because the number of interrogatories propounded by the Plaintiff exceeds the limit set by Cumberland County Local Rule 4005-1." 5. There were only eighteen (18) Interrogatories with subparts to organize Defendant's responses. However, in order to avoid dispute, Plaintiff's counsel advised that if Defendant's counsel felt response beyond forty (40) requests was incorrect, she could simply answer the first forty (40) allowed by the local rules. Plaintiff's counsel then extended the deadline to respond to June 28, 2007. 6. Defendant's counsel has not provided her answers to any Interrogatories nor has she provided complete responses to Document Production Requests. 7. A hearing on Defendant's APL claim is scheduled for July 16, 2007 and Plaintiff's counsel believes that Defendant's lack of response is motivated by her desire not to provide required information prior thereto. 8. Plaintiff requests Defendant shall be ordered to answer the Interrogatories and complete the Document Production Requests within five (5) days from the date of this Motion. 9. Pa. R.C.P. 4019 provides as follows: 4019 (a)(1) The court may, on motion, make an appropriate order for sanctions if (i) a party fails to serve answers, sufficient answers or objections to written interrogatories under Rule 4005. 4019 (c) The court, when acting under subdivision (a) of this rule, may make (1) an order that the matters regarding which the questions were asked, or the character or description of the thing or land, or the contents of the paper, or any other designated fact shall be taken to be established for the purposes of the action in accordance with the claim of the party obtaining the order; (2) an order refusing to allow the disobedient party to support or oppose designated claims or defenses, or prohibiting such party from introducing in evidence designated documents, things or testimony, or from introducing evidence of physical or mental condition; (3) an order striking out pleadings or parts thereof, or staying further proceedings until the order is obeyed, or entering a judgment of non pros or by default against the disobedient party or party advising the disobedience; (4) an order imposing punishment for contempt, except that a party may not be punished for contempt for a refusal to submit to a physical or mental examination under Rule 4010; (5) such order with regard to the failure to make discovery as is just. 10. The Honorable J. Wesley Oler, Jr. was assigned to this matter previously. 11. Defendant does not concur with the filing of this motion. WHEREFORE, it is respectfully requested that Defendant be compelled to respond to the Interrogatories and Document Production Requests referred to in this Motion within five (5) days of the order. Dated: June 29, 2007 Barbara Sumple-Sul iTvan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ID #32317 Attorney for Plaintiff Exhibit A Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2007 - 976 VALERIE C. TAYLOR, CIVIL ACTION -LAW Defendant DIVORCE INTERROGATORIES PROPOUNDED BY PLA NTlE'F TO BE ANSWERED BY DEFENDANT TO: Ms. Valerie C. Taylor c/o Catherine A.. Boyle, Esquire Meyers, Desfor, Saltzgiver & Boyle 41-0 North Second Street P.O. Box 1062 Harrisburg, PA 17108 PURSUANT TO THE PROVISIONS of Pa. R:C.P.4005 and 4006, as amended, you are required to file the original, and serve a copy on the undersigned, of your Answers and Objections, if any, in writing and under oath, to the following Interrogatories, within thirty (30) days after service of the Interrogatories. The Answers shall be inserted in the spaces provided following each Interrogatory. If there is insufficient space to answer an Interrogatory, the remainder of the Answer shall follow on a supplemental sheet. These Interrogatories shall be deemed to be continuing in nature, in accordance with the provisions of Pa. R C.P. 4007 as amended. If between the time of filing your original to these Interrogatories, and the time of trial of this matter, you or anyone acting in your behalf learn the identity and location of additional persons having knowledge of discoverable facts and the identity of persons expected to be :called as an expert witness at trial not disclosed in your Answers, or if you or an expert witness obtain information upon the basis of which you or he knows that an Answer was incorrect when made, or knows that an Answer thought correct en made is.no longer true, then you shall promptly supplement your original Answers un.o to ' u such information :thereafter acquired, and promptly fiunish such as Suppl n the dersigned. Dated: May, 24, 2007 Barbara Sumple-Sullivan, Esquire 549. Bridge Street New Cumberland, PA 17070 (717)774 -145 1. Please state your full name, address and telephone number. ANSWER: . 2. Are you employed` If so, for each employment which you hold, state: a. Name and address of employer; b. Date of commencement of employment; C. Nanie title and address of your immediate supervisor, d. Your job title and description of duties; e. Your hours and rate of pay on earnings, specifying gross average weekly salary, wages, commission, overtime pay, bonuses. 1) Identify the formula used by the employer to determine your specific bonuses or commissions. f. Expense and drawing accounts and allowances for transportation and other accommodation and expenses; and g. Your salary for the last five years.. ANSWER 2 3. Please list all employment held by you since 1985, the date ofmarriage. For each employment please identify the following: a. The dates you were employed; b. The reason for ,leaving; and c., The compensation received ANSWER: ] 1 4. For each employment which you hold or held during the marriage, state whether you participate, or have a right to participate, or have in the past participated in any of the following employment related benefits: a. Defined benefit retirement plan; b. Defined contribution retirement plan; C., Deferred compensation; d. Money purchase pension plan; e. Any other ;type of employee pension plan; f Savings or.th rift plan; g. Cash or, deferred plan (401K); h. Profit sharing plan; i. Employee stock ownership (including tax credit or payroll tax credit employee stock ownership plan; j. Stock bonus plan; k Tax deferred; 40'3,.(b) annuities i. Non-qualified, deferred compensation plans, including excess benefit plans, whether or not refunded; M. Executive stock option plan, including incentive stock option plans; n. Welfare or imurance plans including group term life insurance and medical insurance; o. Voluntary employees' beneficiary association (VEBA); and p. Any other -employment related benefit not disclosed in your Answers to these Interrogatories. ANSWER. 5. For each benefit identified in Interrogatory No. 4 above in which you participate, identify: a. Your date of hire for the employment through which the plan is offered. b. The nature and amount of any contributions that you have made in such plans as of (1) the date of marriage, (2) the date of separation, and (3) current value; C. The nature and amount of any contributions to the plan made by your, employer as o f(l) the date of marriage, (2) the date of separation, and (3) current value; d. The date you began to participate in the plan; e. The date upon which your benefits in the plan are vested; f. The amount of vested benefits _in the plan as of the separation date and currently; g. The amount of non-vested benefits in the plan as of the separation date and currently; h. The name(s) of the person(s) other than yourself who has information relative to the details and amounts of your pension plan benefits; and i. Please provide all documents to support your responses to this Interrogatory in accordance with the request for production of documents served simultaneously herewith. ANSWER: oil believe this date ?andwhyy se a on from the separatiOD the seParation s ?ur? oe State the date of y°? the c? sep?'?on- Describe ?ny?tuted fir- ?S?R. 7. Identify any and all real estate which you have any interest in, whether it be for personal use or business use. For each piece of real estate, please identify: a. How the interest was acquired and the cost of same; b. The identity of any lien holder on said real estate and the present amount of said lien; c. Who has paid the. lien since October 17, 2006 and your stated date of separation, if different from October 17, 2006; d. Your present estimate of value of said property, and e. Current tax assessment. ANSWER: 8. Please identify each vehicle owned by you. For each vehicle, please provide: a. The year, make and model; b. Your estimate of value as of October 17, 2006 and your stated date of separation, if different from October 17, 2006; and c. Any Hen's encumbering each vehicle and the value of the lien as of October 17, 2006, your stated date of separation, if different from October 17, ` 2006, and currently. ANSWER: 9. Please identify by account number and bank name or financial institution, each and every bank or financial account, whether savings, share or checking, that you have or had an interest in during the marriage. For each, please provide: a. The name and address of the institution; b. The account number; c. The balance as of October 17, 2006, your stated date of separation, if different from October 17; 2006, and presently; and d. The names, addresses and relationship of all owners or authorized users of each account. ANSWER: 1 10. List all cash you had in safekeeping as of October 17, 2006, your stated date of separation, if different from October 17, 2006, and presently. ANSWER: 11. As of October 17, 2006, your stated date of separation, if different from October 17, 2006, and presently, list the value of any and all Certificates of Deposit and/or IRA accounts in your name, held for your benefit, or over which you have ownership or signature power over. ANSWER: 1 1 12. Please advise if you are or were you the owner or beneficiary of any policies of life insurance as of October IT 2006 and your stated date of separation, if different from October 17, 2006. For each such policy, state: a. The name of each owner of such policy; b. The name of the beneficiary of,each such policy; c. The face. amount of each such policy, d. The accrued cash value. of each such policy presently, as of October 17, 2006 and your stated date -of separation, if different from October 17, 2006; e. The date each policy was purchased; f. Whether the policy was whole life or term life; and g. The nature and amount of any loan against any policy and the date any loan was incurred. ANSWER: I 3. Are you the grantor, beneficiary or holder of a power of appointment for any trust created by you, any member of your family or by any corporation? If so, for each such trust, state: a. The date of the trust instrument; b.. The name of the settlor of each trust; C. The name of the beneficiary of such trust. d. The amount of each trust corpus; e. Any restrictions on alienation to which such corpus is subject; and f The terms of each trust instrument. ANSWER: 15. Do you own stocks, bonds, mutual funds or fund shares? If so, for each please state a. The name of the corporation or the issuer; b. The number of shares and the base amount of such security; C. The date(s) such securities were purchased; d: The maturity date(s) of such securities, if applicable, e. The market value of such securities as of October 17, 2006 and your stated date of separation, if different from October 17, 2006; f. The current market value of such securities; and g. The dividends paid by each such securities for each year for the last five (5) years. ANSWER. 16, List all personal credit cards, debts, liabilities or claims against you individually or jointly with another person as of October 17, 2006 and your stated date of separation, if different from October 17, 2006. For each such debt, state: a. The name of the creditor of such obligation b. The amount of credit line for each obligatof; C. Any current balance owned upon each such obligation; and d. The balance as of October 17, 2006 and your stated date of separation, if different from October 17, 20062 and whether you believe said obligation is marital debt. ANSWER: I i 1 17. For each, r a. b. C. d. e. ANSWER: Identify any safety deposit box or similar depository which you have or are utilizing. lease include: The location; The owners, custodians or registered owners and renters; The number or designation; The contents thereof including date, acquisition and value; and The identity of all persons with access thereto. 18. Please provide an inventory of the contents .of the safe and the firebox located at the marital home. Please identify whether you took any items from those boxes since October 17, 2006 or your stated date of separation, if different, to the present and how you disposed of same. ANSWER: Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2007 - 976 VALERIE C. TAYLOR, : CIVIL ACTION -LAW Defendant : DIVORCE CERTCATE OF SERVICE L 13AF:BARA SLTWLE-SULLIVAN, ESQUIRE, do hereby certify that on this date, I served an original and two (2) copies of the foregoing INTERROGATORIES, in the above-captioned matter upon the. following individual by first class mail, postage prepaid, addressed as follows: Catherine A Boyle, Esquire Meyers, Desfor, Saltzgiver & Boyle 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 t' Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 3EFFIZ.EY C. TAYLOR, IN TEE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 2007 - 976 VALERIE C. TAYLOR, CIVIL ACTION LAW Defendant DIVORCE PRODUCTION OF DOCUMENTS REQUEST TO DEFENDANT TO: Ms. Valerie C. Taylor c/o Catherine A. Boyle, Esquire Meyers, Desfor, Saltzgiver & Boyle 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 Plaintiff Jeffrey C. Taylor, by his undersigned counsel, hereby propounds the foll owing request for production of documents and tangible things pursuant to Rule 4009.1 et seq. of the Pennsylvania Rules. of Civil Procedure. The documents and tangible things requested herein must. be produced at the law office of Barbara Sumple-Sullivan; 549 Bridge Street, New Cumberland, Pennsylvania within thirty days. Each of the following requests is intended as a separate request. Where a request has subparts, please respond to each subpart separately and in full. Do not limit any response to the numbered request as awhole: If you have any objection to any request, please state your objection fully and set forth the factual basis for your objection in lieu of production of the documents. You must file and serve a written response to these requests within thirty days of service of these requests upon you, s ? ? y regardless of the time set for production of the documents and things requested herein. You are reminded that any objection not raised within the thirty day period provided for by Pa.R. C.P. 4009.12 will be deemed to have been waived by you. These requests are not only for documents and tangible things that are owned by you, but also for documents and tangible things that are in your possession, custody, or control. This means that you must produce all documents and tangible things that are responsive to a particular request and that are in your possession (regardless of whether they are your property), or over which you have control even if they are not in your possession. It also means you must produce documents and tangible things that are in the possession, custody, or control of your agents, employees, and/or attorneys. Before responding.to these requests you are required to make a diligent search of your files and records to ascertain whether you have documents that would be responsive to a given request. Your agents, employees, and attorneys must do the same. To avoid any possibility of confixsion with respect to these requests, please note that the following terms have the following meanings in these requests, unless a particular request clearly indicates otherwise: "You" or "your" refer to the person to whom these requests have been addressed. "Person" means .any natural person, corporation, unincorporated association, trust; partnership, and/or any other legally cognizable entity.. It is contemplated that any corporation or other business entity acts only through its. agents, officers, employees, and attorneys, and requests, that apply to any such legal entity should he construed accordingly. "Plaintiff" means the plaintiff or plaintiffs named in this action i a 41 "Defendant" means the particular defendant or defendants in this section to whom this request is addressed, as set forth above. "Document", "record", "file", and "report all refer to and contemplate all written, recorded,,or graphic information, whether preserved in writing, on magnetic tape, by electronic means, in photographic form, on microfilm or microfiche, computer disc, or by any other means of information retrieval or.storage. "Identify" when used to reference to an individual means: (i) To state lis/her full name: u) Present residence or last known residence. The request is as follows: I) A copies of your most current pay stub, showing year-to-date income, or any other documentation ofincome received from any source for the time period of January I, 2006 to the present. 2) A copy of your current resume. 3) Copies of all business records including but not limited to, documentation of your commissions received, mileage records, and telephone records, for your employment with Thomas and AFLAC East and West for the period of 2002 to the present. 4) Copies of all personal financial statements or loan applications prepared by you or for you by another, for the time period, of January 1, 2003 to the present. $) Copies of all employment, retirement, pension, or other employment benefit such as 401 (k)s, :Savings Plans, IRAs, etc. as identified in your Answers to Interrogatories. 6) Copies of any deferred compensation agreements identified in your Answers to Interrogatories. 7) Copies of all deeds, mortgages, settlement sheets and appraisals for any real estate you have any interest in, including the marital home and Mermaid Car Wash . 8) Copies of all, monthly statements for all mortgages, loans, lines of credit, etc. that encumber the marital home and Mermaid Car Wash from the period of January 1, 2003 to the present. 9) Copies of any documents evidencing the liens against the vehicles and/or values of said vehicle provided in your Answers to Interrogatories. 10) Copies ofall itemized monthly statements, including .account number, of alljointor individual IL 1 a checking, savings, brokerage and securities accounts, or any other account held in any financial institution by you or for your benefit or that you hold for the benefit of another for the time period of January 1., 2003 to the present. 11) Original and copies of all check registers, including -account number, for all checking accounts held by you, jointly or individually, or for your benefit, or that you hold for the benefit of another, or that you have signatory power over for the time period of January 1, 2003 to the present. 12) Copies of all itemized monthly statements, including account number, of all checking, savings, or any other account held in any financial institution by Mermaid Car Wash, or by you oryour husband on behalf of Mermaid Car Wash for the time period of January 1, 2003 to the present. 13) Copies of the policies for the life insurance identified in your Answers to Interrogatories, together with any statements evidencing the cash value of these policies. 14) Copies of any and all statements evidencing the receipt and disposition of any inheritance identified in your Answers to Interrogatories. 15) Documentation of all expenses, including but not limited to bills, statements, checks, incurred in the construction of the Mermaid Car Wash in 1995, which are in a manila envelope in the basement of the marital home. 16) Copies of any and all accounting sheets in your possession prepared by you or plaintiff upon counting the gross receipts at the Mermaid Car Wash. 17) Documentation of all expenses incurred for the Benetau boat, including but not limited to slip fees, storage costs, maintenance costs, improvements, racing fees and any other cost, fee or expense, for the time period of January 1, 2005 to the present. 18) Copies of any and all documentation of any safe deposit box in your name or maintained for your use or any safe or firebox located in the marital home. 19) Copies of any and all monthly itemized credit card account statements for any credit cards held by you or for your benefit or that you have use of or control over, or hold for the benefit of another, for the time period of January, 1, 2003 to the present 20) Copies of any and all monthly itemized credit card statements of any credit cards held by you. or by you or your husband on behalf of Mermaid Car Wash for the time period of January 1, 2003 to the present. 21) Copies of documentation of any loans received by you from another person or entity, including but not limited to when the loan was given, the source of the funds, use of such funds; repayment schedule, documentation of payments made, and interest rate charged, for the time period of January 1, 2003: 22) Copies of all of your monthly telephone statements for all telephones, including cellular telephones, for January 1, 2005 to the present. 23) A copy of your personal calendar maintained by you from January 1, 2005 to the present. 24) A printout of the internet. use history from your personal computer from January 1, 2005 to the present: 25) An itemization` and accounting of any and all items purchased by you with any money transferred, redeemed or received from the use of marital assets or from the proceeds therefore since October 17; 2006 or your stated date of separation, if different, to the present. Please include documentation of the cost and date of purchase of each item. 26) Copies of any expert reports you plan to submit at trial. 27) Attach all exhibits you plan to submit at trial. 28) Any other writing which is necessary to establish any values set forth in any of your Answers, to Interrogatories. Respectfully submitted, y DATE: May 24, 2007 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Plaintiff Barbara Sumpie-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 JEFFREY C. TAYLOR., IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. NO..2007 - 976 VALERIE C. TAYLOR, CIVIL ACTION -LAW Defendant DIVORCE CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing PRODUCTION OF .DOCUMENTS REQUEST TO DEFENDANT, in the above-captioned matter upon the following individual(s) by first class mail, postage prepaid, addressed as follows: Catherine A_ Boyle, Esquire Meyers, Desfor, Saltzgiver & Boyle 410 North Second Street P.O. Box 1062 uav-,46kvrrev 13A 17102 'L t ' 66 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2007 - 976 VALERIE C. TAYLOR, CIVIL ACTION -LAW Defendant DIVORCE CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served the Motion to Compel Response to Interrogatories and Document Production Requests to this Honorable Court, in the above-captioned matter upon the following individual via United States Mail: Catherine A. Boyle, Esquire Meyers, Desfor, Saltzgiver & Boyle 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 / DATE: June 29, 2007 h,-a'rbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney For Plaintiff ?? ??? u ._ _ .n,.?.? f rt t?_,?,y • } t? L,a1 ?..'C... ?,.,,,,.. ,.t? JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW VALERIE C. TAYLOR, : Defendant NO. 07-976 CIVIL TERM ORDER OF COURT AND NOW, this 10th day of July, 2007, upon consideration of Plaintiff's Motion To Compel Responses to Interrogatories and Document Production Requests, a Rule is hereby issued upon Defendant, to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. BY THE COURT, Barbara Sumple-Sullivan, Esq. 549 Bridge Street New Cumberland, PA 17070-1931 Attorney for Plaintiff Catherine A. Boyle, Esq. 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108-1062 Attorney for Defendant rc sno 61 Z W8 0 1 TIF LOU JEFFREY C. TAYLOR, Plaintiff VS. VALERIE C. TAYLOR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-976 CIVIL ACTION -LAW IN DIVORCE DEFENDANT'S ANSWER TO PLAINTIFF'S MOTION TO COMPEL RESPONSES TO INTERROGATORIES AND DOCUMENT PRODUCTION REQUESTS AND NOW, comes Defendant, Valerie C. Taylor, by and through her attorneys, Meyers, Desfor, Saltzgiver & Boyle, and files this Answer to Plaintiff's Motion to Compel Responses to Interrogatories and Document Production Requests, and in support thereof avers as follows: 1. Denied. The captioned matter involves a divorce action and other associated claims. 2. Admitted. 3. No answer required. The Rules of Civil Procedure speak for themselves. 4. Admitted in part. Denied in part. Plaintiff fails to indicate that documents responsive to the Request for Documents, were supplied in a timely manner on June 25, 2007. It is admitted that Defendant did not answer the Interrogatories, which exceeded the amount permitted by Cumberland County Local Rule 4005-1. Defendant's Interrogatories consisted of over two hundred (200) requests, including multiple questions and subparts. The Cumberland County Local Rule 4000-5 limits Interrogatories to forty (40) in number. Defendant's Interrogatories exceeded the permitted amount by more than five (5) times. It is denied that full and proper answers were not supplied. MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 5. Denied. Defendant's Interrogatories were more than two hundred (200) in number, approximately five (5) times the amount permitted by Cumberland County Local Rule 4000-5. Subparts are counted as a separate question for purposes of numbering Interrogatories. See Cumberland County Local Rule 4005-1. Prior to responding to Plaintiff s voluminous discovery, Defendant's counsel contacted the Cumberland County Deputy Court Administrator, who inquired of the then discovery Judge as to the requirement to answer Interrogatories that did not comply with Cumberland County Local Rules. Defendant's counsel was advised that Defendant may object to the Interrogatories in their entirety. However, as a courtesy to Plaintiff and his counsel, on June 26, 2007, Defendant's counsel issued a letter to Plaintiff's counsel, indicating Defendant's objection to the inappropriate Interrogatories and offering Plaintiff the opportunity to designate which forty (40) Interrogatories Plaintiff would like to have answered, and that Defendant would comply with the request. No response was received to Defending counsel's correspondence of June 26, 2007. 6. Denied. Defendant has provided appropriate answers to the Document Production Request and provided Plaintiff the opportunity to designate which forty (40) Interrogatories he wished to have answered in compliance with Cumberland County Local Rule 4005-1. Plaintiff has yet to respond to Defendant's counsel's correspondence. 7. Denied. The hearing for Defendant's claim for alimony pendente lite is currently MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 being rescheduled. It is also denied that the answers sought are relevant to the pending claim. Defendant did not respond to Plaintiff's inappropriate discovery because same was served to harass Defendant and cause her to incur unnecessary legal fees. This averment contains a request for relief to which no answer is required. 9. The Pennsylvania Rules of Civil Procedure speak for themselves. Moreover, in addition to the Pennsylvania Rules of Civil Procedure, Defendant is required to comply with the Cumberland County Local Rules of Civil Procedure when serving discovery. 10. Admitted. 11. Admitted. By way of further answer, Defendant seeks payment of attorney's fees incurred as a result of having to answer Plaintiff's frivolous Motion. 4 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 WHEREFORE, Defendant, Valerie C. Taylor, respectively requests this Honorable Court deny Plaintiff's Motion to Compel Responses to Interrogatories and Document Production Requests and order Plaintiff, Jeffrey C. Taylor, to pay Defendant's attorney's fees incurred as a result of answering his Motion. Respectfully submitted, Catherine A. Boyle, Esquire Attorney I.D. 76328 Meyers, DEsfor, Saltzgiver & Boyle 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717)236-9428 Attorney for Defendant 5 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX(717)236-2817 VERIFICATION I, Valerie C. Taylor verify that the statements made in this Defendant's Answer to Plaintiff's Motion to Compel Responses to Interrogatories and Document are true and correct to the best Production Requests of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: 7/31/07 ( X) Defendant MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 ( ) Plaintiff JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 07-976 VALERIE C. TAYLOR, CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I hereby certify on this3 l*r day of July, 2007, that a copy of the foregoing Defendant's Answer to Plaintiff's Motion to Compel Responses to Interrogatories and Document Production Requests was sent via facsimile and first-class mail, postage pre-paid to: Jeffrey C. Taylor c/o Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 Attorney for Plaintiff Catherine A. Boyle, Esquire Attorney for Defendant 6 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 N D A~ ?. _,. X11 -7r Q CJl or In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION VALERIE C. TAYLOR ) Docket Number 07-976 CIVIL Plaintiff ) VS. ) PACSES Case Number 622109022 JEFFREY C. TAYLOR ) Defendant ) Other State ID Number ORDER OF COURT You, VALERIE C. TAYLOR plaintiff/defendant of 334 E MEADOW DR, MECHANICSBURG, PA. 17055-5187-34 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the SEPTEMBER 24, 2007 at 8: 3 OAM for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income Statement and the appropriate Expense Statement, if required, attached to this order, completed as required by Rule 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. information relating to professional licenses 7. other: Service Type M Form CM-509 Rev. I Worker ID 21302 r" ) TAYLOR v• TAYLOR PACSES Case Number: 622109022 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest and/or enter an interim support order. If paternity is an issue, the court shall enter an order establishing paternity. THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD TO WHICH PARTY INITIATED THE SUPPORT ACTION. BY THE COURT: Date of Order: ?? C) I J//WESLEY OL R, JR. , JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE-HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 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 at: (717) 240-6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Rev. 1 Service Type M Worker ID 21302 c? ? o 43 cri 3 C JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW VALERIE C. TAYLOR, : Defendant NO. 07-976 CIVIL TERM ORDER OF COURT AND NOW, this 9th day of August, 2007, upon consideration of Plaintiff's Motion To Compel Responses to Interrogatories and Document Production Requests, and of Defendant's Answer to Plaintiff's Motion To Compel Responses to Interrogatories and Document Production Requests, a discovery conference is scheduled before the undersigned judge on Monday, October 1, 2007, at 1:30 p.m. BY THE COURT, J. esley Ole-r,,-Jrr..,, T arbara Sumple-Sullivan, Esq. 549 Bridge Street New Cumberland, PA 17070-19-^ Attorney for Plaintiff atherine A. Boyle, Esq. 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108-1062 Attorney for Defendant :rc t t , d; !r?_., ..i f ! -,C YJ 6- OFIV LODZ Ab (1v lv ! ? , o ??11 JO 3101 _40-(ITT ? -w In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION VALERIE C. TAYLOR ) Docket Number 07-976 CIVIL Plaintiff ) vs. ) PACSES Case Number 622109022 JEFFREY C. TAYLOR ) Defendant ) Other State ID Number ORDER OF COURT You, JEFFREY C. TAYLOR plaintiff/defendant of PO BOX 131, GRANTHAM, PA. 17027-0131-31 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the SEPTEMBER 24, 2007 at 8: 3 OAM for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income Statement and the appropriate Expense Statement, if required, attached to this order, completed as required by Rule 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. information relating to professional licenses 7. other: Service Type M Form CM-509 Rev. 1 Worker ID 21302 IF/ .y TAYLOR V. TAYLOR PACSES Case Number: 622109022 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest and/or enter an interim support order. If paternity is an issue, the court shall enter an order establishing paternity. THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD TO WHICH PARTY INITIATED THE SUPPORT ACTION. BY THE COURT: Date of Order: ?., _ ) aa'7 J/ WESLEY OLE , J . , JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE-HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 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 at: (717) 240-6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Rev. 1 Service Type M Worker ID 21302 C? O Q ?-- n om n ,, .: rn C, JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 07-976 PACSES No. 622109022 VALERIE C. TAYLOR, CIVIL ACTION -LAW Defendant IN DIVORCE PETITION TO WITHDRAW AS COUNSEL 1 Movant is Meyers, Desfor, Saltzgiver & Boyle who is presently counsel of record for Valerie C. Taylor in the above-captioned action. 2. 3. Respondent is Valerie C. Taylor, a parry in the above- captioned action. Movant, Meyers, Desfor, Saltzgiver & Boyle has represented Valerie C. Taylor pursuant to the above docketed action since February 26, 2007. 4. 5. 6. 7. 8. There has been a breakdown in the attorney/client relationship. Further, at the time Respondent retained Movant, the Respondent signed a Retainer Agreement agreeing to pay for Movant's hourly fee on an ongoing basis. At present, Movant has completed work for Respondent for which Respondent has not paid Movant. Movant has requested payment from Respondent and Respondent has refused to remit payment. The pending litigation involves various issues and the Movant estimates that the counsel fees, and costs incurred will be significant. Movant has no reason to anticipate that Respondent will pay for any future incurred MEYERS, DESFOR, SALTZOIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 238.9428 • FAX (717) 236-2617 i fees and/or costs. WHEREFORE, Movant, Meyers, Desfor, Saltzgiver & Boyle, respectfully requests that this Honorable Court grant them leave to withdraw as counsel for Valerie C. Taylor. Respectfully submitted, atherine A. Boyle, Esquire MEYERS, DESFOR, SALT GIVER & BOYLE Attorney I.D. #76328 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717) 236-9428 4 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 T • JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 07-976 PACSES No. 622109022 VALERIE C. TAYLOR, CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Catherine A. Boyle, Esquire, Attorney for Plaintiff in the above-referenced action, hereby certify that on this 9446 day of , 2007, a copy of the Petition to Withdraw as Counsel was placed in the United States mail, postage prepaid, addressed as follows: Valerie C. Taylor 334 East Meadow Drive Mechanicsburg, PA 17055 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (Attorney for Jeffrey C. Taylor) Respectfully submitted, Z?? ZL Catherine A. Boyle, Esquire Meyers, Desfor, Saltzgiver & oyle Attorney I.D. #76328 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717) 236-9428 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O5 BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 ril - t ? ,; JEFFREY C. TAYLOR, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 07-976 : PACSES NO. 622109022 VALERIE C. TAYLOR, CIVIL ACTION -LAW Defendant IN DIVORCE AMENDMENT TO PETITION TO WITHDRAW AS COUNSEL AND NOW, comes Meyers, Desfor, Saltzgiver & Boyle and files this Amendment to Petition to Withdraw as Counsel and support thereof avers as follows: 1. Judge Oler has been assigned to this matter. No final orders have been issued to date. 2. Movant contacted Plaintiffs attorney on two separate occasions and Plaintiff's attorney has refused to respond. WHEREFORE, Movant, Meyers, Desfor, Saltzgiver & Boyle, respectfully requests that this Honorable Court grant them leave to withdraw as counsel for Valerie C. Taylor. Respectfully submitted, s Fa-&-rine A. Boyle, Esquir MEYERS, DESFOR, SAL GIVER & BOYLE Attorney I.D. #76328 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717) 236-9428 oYl MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX(717)236-2817 fw . JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 07-976 PACSES NO. 622109022 VALERIE C. TAYLOR, CIVIL ACTION - LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Catherine A. Boyle, Esquire, Attorney for Plaintiff in the above-referenced action, hereby certify that on this day of _ t4, , 2007, a copy of the Amendment to Petition to Withdraw as Counsel was placed in the United States mail, postage prepaid, addressed as follows: Valerie C. Taylor 334 East Meadow Drive Mechanicsburg, PA 17055 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (Attorney for Jeffrey C. Taylor) Respectfully submitted, Catherine A. Boyle, Esquire Meyers, Desfor, Saltzgiver & Attorney I.D. #76328 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717) 236-9428 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET - P.O. BOX 1062 - HARRISBURG, PA 17108 (717) 236-8428 - FAX (717) 236-2617 C`.l c?'''-a {j 4 p? r. . J ?? f'i_tl?' ` ? r+ ? ?.?' J J ? ? ?? ?? ?? I a ?? . ?:? ®?: Y ?a.c ?? : c..,? tv ? JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW VALERIE C. TAYLOR, Defendant NO. 07-976 CIVIL TERM ORDER OF COURT AND NOW, this 6 h day of September, 2007, upon consideration of the Petition To Withdraw As Counsel and the Amendment to Petition To Withdraw As counsel, a Rule is hereby issued upon Defendant Valerie C. Taylor to show cause why the relief requested should not be granted. RULE RETURNABLE within 14 days from the date of this order. Barbara Sumple-Sullivan, Esq. 549 Bridge Street New Cumberland, PA 17070-1931 Attorney for Plaintiff Catherine A. Boyle, Esq. 410 North Second Street PO. Box 1062 Harrisburg, PA 17108-1062 Attorney for Defendant Valerie C. Taylor 334 East Meadow Drive Mechanicsburg, PA 17055 l.- its M21&, :rc BY THE COURT, d Lot ?o 00 JEFFREY C. TAYLOR, Plaintiff VS. VALERIE C. TAYLOR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-976 CIVIL ACTION -LAW IN DIVORCE PRAECIPE TO WITHDRAW APPEARANCE TO THE PROTHONOTARY: Please withdraw the appearance of Catherine A. Boyle, Esquire as counsel for Valerie C. Taylor, Defendant in the above-captioned matter. Date: 2007 atherine A. Boyle', Esquire I.D. No. 41 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108-1342 (717) 236-9428 PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Max J. Smith, Jr., Esquire, as counsel for Valerie C. Taylor, Defendant in the above-captioned matter. Date: ?t ? t I , 2007 1?vu? Max J. Smith, Jr., E;quVe I.D. No. 32114 Jarad W. Handelman, Esquire I.D. No. 82629 James, Smith, Dietterick & Connelly LLP P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 r--- (20 elk CP %12 3 "'c < tn - 0 C JEFFREY C. TAYLOR, Plaintiff V. VALERIE C. TAYLOR, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-976 CIVIL TERM IN RE: PLAINTIFF'S MOTION TO COMPEL RESPONSES TO INTERROGATORIES AND DOCUMENT PRODUCTION REQUESTS and DEFENDANT'S EMERGENCY PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 28" day of September, 2007, upon consideration of the attached letter from Max J. Smith, Jr., Esq., attorney for Defendant, the above-captioned matters are continued generally. Counsel are directed to contact the court if they desire a hearing on these matters or if a settlement is reached. a4arbara Sumple-Sullivan, Esq. 549 Bridge Street New Cumberland, PA 17070-1' Attorney for Plaintiff Iax J. Smith, Jr., Esq. J P.O. Box 650 Hershey, PA 17033 Attorney for Defendant :rc BY THE COURT, J./Wesley Oler, JrV, J. j 7 3 7 i `;'n l L' Ci ?i;17 ? 4 JAMB SMITH DIE TRICK & CONNELLY LLP Max J. Smith, Jr. Email: misgisdc.com FAX 717.533.2795 September 26, 2007 FAX TRANSMISSION The Honorable J. Wesley Oler, Jr. Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 In re: Taylor v. Taylor No. 2007-976 In Divorce Dear Judge Oler: Confirming my earlier discussion with your secretary, please be advised that I now represent Valerie Taylor in the above matter. Attorney Barbara Sumple-Sullivan continues to represent Jeffrey Taylor. A hearing had been set for October 1, 2007. Please accept this letter as the mutual request of the Taylors to generally continue the hearing on October 1, with either side reserving the right to reschedule the hearing in the event settlement negotiations break down. We hope to notify the court of a comprehensive settlement agreement shortly, thereby altogether eliminating the need for a hearing. Thank you for your kind consideration. Very truly yours, JAMES ?Ml r ETT R1 K & CONNELLY LLP I Max J. Smith, Jr. MJS,Jr.:ams cc: Barbara Sumple-Sullivan, Esquire via fax Valerie C. Taylor P.O. BOX 650 HERSHEY, PA 17033 Courier Address. 134 SIPE AVENUE HUMMELSTOWN, PA 17036 TEL. 717533.328C VVWW JSDC.COM GARY L. JAMES MAX J. SMITH, JR. JOHN J. CONNELLY, JR. SCOTT A. DIETTERICK JAMES F. SPADE MATTHEW CHABAL, III SUSAN M.KADEL JARAD W. HANDELMAN DONNA M. MULLIN NEIL W. YAHN COURTNEY K. POWELL KIMBERLY A. BONNER JEFFREY M. MCCORMICK KAREN N. CONNELLY JOHN M. HYAMS OF COUNSEL: GREGORY K. RICHARDS BERNARD A. RYAN, JR. JEFFREY C. TAYLOR, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA V. DOMESTIC RELATIONS SECTION VALERIE C. TAYLOR, : PACSES NO. 622109022 Defendant/Petitioner : DOCKET NO. 07-976 CIVIL TERM ORDER OF COURT AND NOW, this ?16- day of November, 2007, this matter having been scheduled for a hearing de novo before the Support Master on the Petitioner's claim for alimony pendente lite, and the parties having reached an agreement on all outstanding issues, it is ordered and decreed as follows: A. The interim order entered April 23, 2007 is affirmed as a final order. B. Said order of April 23, 2007 is suspended effective October 31, 2007. C. Any arrearages or credit remaining on said case are remitted. By the Court, es y Oler Jr., Cc: Valerie C. Taylor Jeffrey C. Taylor Max J. Smith, Jr., Esquire For the Plaintiff Barbara Sumple-Sullivan, Esquire For the Defendant ^' ? -;,` ? ? t °,te ??,. =_, rc >.r: ?? ?? .?' r..? a7- R7( MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT made this L-- day of December, 2009 by and between Valerie C. Taylor (hereinafter referred to as "Wife") of 334 East Meadow Drive, Mechanicsburg, Cumberland County, Pennsylvania and Jeffrey C. Taylor (hereinafter referred to as "Husband") of 110 Pennsylvania Ave, Camp Hill, Cumberland County, Pennsylvania 17011. WITNESSETH: WHEREAS, Husband and Wife were lawfully married on April 20, 1985 in Dauphin County, Pennsylvania; 9 o WHEREAS, no children have been conceived of this marriage; WHEREAS, diverse differences and difficulties have arisen between the parties respecting their interests, rights and title in and to certain property, real and/or personal, owned by or in possession of the said parties to either of them; WHEREAS, Husband and Wife desire to settle and determine their rights and obligations and to amicably adjust, compromise and forever settle all property rights and all rights in, to or against each other's property or estate of any kind or nature whatsoever, including property heretofore or subsequently acquired by either party and to settle all disputes existing between them, including any and all claims for Wife's and/or Husband's rights to equitable distribution, maintenance and/or support, alimony, alimony pendente lite, counsel fees and costs; 164?? i ?%c- WHEREAS, the parties acknowledge and agree that in entering into this Agreement, including foregoing waivers, they are each relying on truth and completeness in all material respects as to all information provided by the other party hereto regarding the assets of such person; and NOW THEREFORE, in consideration of the mutual promises, covenants and agreements hereinafter contained, each of the parties hereto intending to be legally bound hereby promises, covenants and agrees as follows: 1. DIVORCE: The parties agree that their marriage is irretrievably broken and that they mutually consent to a divorce. The parties agree that they shall conclude their divorce on a no- fault basis by filing Consents and Waivers with the court on or about December 31, 2009, so to allow for a decree to be entered prior to January 15, 2010. Consents and Waivers of Notice forms shall be executed simultaneously with the execution of this Agreement and held by Husband's counsel for completion of the divorce in accordance with the time directives set forth in this paragraph. 2. FULL FORCE AND EFFECT: This Agreement shall continue in full force and effect until such time of final Decree in Divorce is entered and shall survive the entry of the decree. 3. AGREEMENT TO CONTINUE IN EVENT OF DIVORCE: In the event that the marriage of the parties hereto is terminated by divorce, this Agreement shall nevertheless remain ?1-75- 2 in full force and effect, and shall survive such decree and shall not in any way be affected thereby, except as provided for herein. 4. INTERFERENCE: Each party shall be free from interference, authority, and contact by the other, as fully as if he or she were single and unmarried except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 5. WIFE'S DEBTS: Wife represents and warrants to Husband that since the date the divorce was filed, to wit, February 21, 2007, she has not and in the future she will not, contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save harmless Husband from any and all claims or demands made against him by reason of debts or obligations incurred by her. Wife confirms to the best of her knowledge that, except as specifically identified in this Agreement, no joint debts exist. 6. HUSBAND'S DEBTS: Husband represents and warrants to Wife that since the divorce was filed, to wit, February 21, 2007, he has not and in the future he will not, contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. He confirms to the best of his knowledge that, except as specifically identified in this Agreement, no joint debts exist. 3 7. DISCOVERY/FINANCIAL DISCLOSURE: The parties agree and acknowledge that they have each had the opportunity to conduct discovery and investigation of the assets of both parties. Wife acknowledges that she has issued various requests for information from Husband. Husband acknowledges that he has issued various requests for information from Wife. The parties agree and acknowledge that they have made full and fair disclosure of all of their assets and income to the other party. The parties acknowledge that they have both been given the opportunity to conduct investigation into all assets, whether separate or marital, prior to entry into this Agreement. Both Husband and Wife acknowledge they have had full and fair disclosure of all assets prior to execution of this Agreement. Furthermore, the parties acknowledge that they have both had full disclosure as to both parties' income and financial condition. 8. MUTUAL RELEASES: Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all causes of action, claims, rights, or demands, whatsoever in law or equity, which either of the parties ever had or now has against the other, except any or all causes of action for termination of the marriage by divorce or annulment and except any or all causes of action for breach of any provisions of this Agreement. Husband and Wife specifically release and waive any and all rights he or she might have to raise claims under the Pennsylvania Divorce Code and all subsequent amendments, but not limited to claims for equitable distribution of marital property, support, alimony, alimony pendente lite, counsel fees or expenses. The fact that a party brings an action to enforce the property agreement as incorporated in the divorce decree, under 71-- 4 /I-PY? the Pennsylvania Divorce Code and all subsequent amendments, does not give either party the right to raise other claims under the Divorce Code, specifically waived and released by this paragraph and all rights and obligations of the parties arising out of the marriage shall be determined by this Agreement. 9. RELEASE OF TESTAMENTARY CLAIMS: Except as provided for in this Agreement, each of the parties hereto shall have the right to dispose of his or her property by Last Will and Testament or otherwise and each of them agree that the estate of the other, whether real, personal or mixed, shall be and belong to the person or persons who would become entitled thereto as if the decedent had been the last to die. This provision is intended to constitute a mutual waiver by the parties of any rights to take against each other's Last Wills under the present or future laws of any jurisdiction whatsoever and is intended to confer third-party beneficiary rights upon the other heirs and beneficiaries of each. 10. AGREEMENT BINDING ON HEIRS: The parties acknowledge that except as provided for in this Agreement, each of the parties shall have the right to dispose of their respective property by Last Will and Testament, and that each party waives the right to take under the Will of the other. This Agreement shall be binding on the respective heirs, executors, administrators and assigns of the parties thereto. 11. ENTIRE AGREEMENT: This Agreement represents the entire agreement between the parties. There are no representations, promises, agreements, conditions, or warranties between the parties other than those set forth herein. 12. LEGAL ADVICENOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel. The Wife has employed and has had the benefit of counsel of Max J. Smith, Esquire, as her attorney. The Husband has employed and has had the benefit of counsel of Barbara Sumple-Sullivan, Esquire, as his attorney. Each party acknowledges that they have received independent legal advice from counsel and that each party fully understands the facts and have been fully informed of their legal rights and obligations, and each party acknowledges and accepts that this Agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge, and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. Also, each party hereto acknowledges that he or she has been fully advised by his or her respective attorney of the current Pennsylvania Divorce Law, and his or her rights thereunder, each party hereto still desires to execute this Agreement acknowledging that the terms and conditions set forth herein are fair, just, and equitable to each of the parties and waives their respective right to have the Court make any determination or order affecting the respective parties' right to a divorce, alimony, alimony pendente lite, equitable distribution of all marital property, counsel fees and costs and expenses. 13. DISPOSITION OF PERSONAL PROPERTY: The parties have divided between them, to their mutual satisfaction, the personal effects, household furniture and furnishings, and all other articles of personal property which have heretofore been used by them in common. 6 Should it become necessary, the parties each agree to sign any titles or documents necessary to give effect to this paragraph. 14. DISPOSITION OF REAL ESTATE PROCEEDS: The parties jointly owned real estate located at 334 East Meadow Drive, Mechanicsburg, Cumberland County, Pennsylvania. The property has been sold and all debts related to the property paid in full. The net proceeds of One Hundred Thousand, Ninety-one Dollars and 381100 ($100,091.38) are currently in the possession of Wife's counsel. Upon execution of this Agreement, said check shall be released to Wife, and Husband releases any and all claims to receive any part of said proceeds. 15. DISPOSITION OF RETIREMENT ASSET: Husband has an existing IRA account with Merrill Lynch, #877-71613. Wife shall receive the entire remaining balance of Husband's IRA pursuant to a tax free rollover from Husband's Merrill Lynch account into a qualified account for Wife pursuant to an IRA directive or other qualified Domestic Relations Order. It is further acknowledged by both parties that this IRA account had a larger balance at the time of separation. However, at the mutual agreement of the parties, Forty-five Thousand Dollars ($45,000.00) in funds were liquidated after separation to pay a marital debt due and owing to Adams County Bank to satisfy a lawsuit filed against both parties by the bank. The parties confirm that the current balance for distribution was approximately Thirty Thousand Dollars ($30,000.00). After the sale of the marital home, Husband withdrew Sixteen Thousand Five Hundred Dollars ($16,500.00), and provided to Wife the sum of Fifteen Thousand Dollars ($15,000.00) in cash for a down payment on a future home. Husband shall have the right to retain One Thousand Five Hundred Dollars ($1,500.00) to pay income tax he will incur as a 7 result of the liquidation of his retirement funds. Wife shall receive any remaining balance. Counsel for Wife shall be responsible for drafting the IRA directive or completing other documents required to effectuate the transfer. Both parties certify that no other marital retirement assets exist. 16. DISPOSITION OF CASH ACCOUNT: A. Money Market: The parties acknowledge that there is a joint account with Merrill Lynch #872-36186 with a current balance of One Hundred Fifty-eight Dollars and 36/100 ($158.36). This account shall be closed or transferred and the funds given to the Wife. B. Checking/Savings Accounts: Wife shall keep as her sole and exclusive possession any and all checking and savings accounts in her name alone. Husband waives any and all right or claim to said checking and savings accounts. Husband shall keep as his sole and exclusive possession any and all checking and savings accounts in his name alone. Wife waives any and all right or claim to said checking and savings accounts. 17. DISPOSITION OF BUSINESS INTERESTS: A. Mermaid Car Wash: Husband shall retain as his sole and exclusive property the business interest in Mermaid Car Wash, together with the real estate, and any and all benefits and/or liabilities derived therefrom. Wife does hereby waive any and all claims to the business and real property. Husband shall be responsible for payment of all liabilities and any and all other liabilities, costs, or expenses associated with the Mermaid Car Wash. Husband shall indemnify and hold Wife harmless from same. The parties acknowledge that the Mermaid Car Wash is encumbered by the following liabilities: (1) Adams County National Bank Note #3600124576 with an approximate outstanding balance of approximately One Hundred Fifty-six Thousand, Four Hundred Twenty-three Dollars and 07/100 ($156,423.07). (2) Note dated December 1, 1995, executed by the parties and Husband's parents in the amount of Six Hundred Thousand Dollars ($600,000.00), and interest due thereon. (3) Loan from Husband's mother in the amount of One Hundred Twenty-five Thousand Dollars ($125,000.00) and interest due thereon. Husband has been approved to refinance the Adams County National Bank loan and shall secure Wife's release from the liabilities due and owing Husband's parents within thirty (30) days of the execution date of this Agreement. Incident to the closing of the refinance, Husband shall additionally pay to Wife a cash payment of Ninety-seven Thousand Five Hundred Dollars ($97,500.00). At the 9 settlement and in exchange for the payment of Ninety-seven Thousand Five Hundred Dollars ($97,500.00) set forth above, Wife shall execute a deed transferring the real estate into Husband's name alone, with liens in favor of Charles J. Taylor and Suzanne P. Taylor with amounts as stated in paragraph 17A (2) and (3) above. Said deed shall be prepared by Husband's attorney, executed by Wife, and held by Wife's attorney pending completion of the refinance settlement. Any escrow funds refunded after the settlement shall be the sole and separate property of Husband. (B) Taylor Group: Husband shall keep as his sole and exclusive property any interest he holds in Taylor Group and any benefits and/or liabilities derived therefrom. The parties are not aware of any liabilities associated with Husband's interest, but to the extent same exist, Husband shall be responsible for payment of same and shall indemnify and hold Wife harmless from same. (C) CJSPT Limited Partnership: Husband shall keep as his sole and exclusive property any interest he holds in CJSPT Limited Partnership and any benefits and/or liabilities derived therefrom. The parties are not aware of any liabilities associated with Husband's interest, but to the extent same exist, Husband shall be responsible for payment of same and shall indemnify and hold Wife harmless from same. (D) Spinnaker Development, LLC: Husband shall keep as his sole and exclusive property any interest he holds in Spinnaker Development, LLC and any benefits and/or liabilities derived therefrom. The parties are not aware of any liabilities associated with 10 Husband's interest, but to the extent same exist, Husband shall be responsible for payment of same and shall indemnify and hold Wife harmless from same. (E) Auto Sport Direct, LLC: The parties acknowledge that there exists another entity in Wife's name known as Auto Sport Direct, LLC. Wife shall assign all her rights, title and interest in said entity to Husband. Husband shall be responsible to pay any and all fees outstanding and due to the Commonwealth of Pennsylvania, Department of State for said entity. Husband shall also indemnify and hold Wife harmless for any and all other costs related to said entity. (F) Harrisburg Corporate Limousine Services, Inc.: Other than set forth herein, Wife shall keep as her sole and exclusive property any interest she holds in Harrisburg Corporate Limousine Services, Inc., and any benefits and/or liabilities derived therefrom. Wife shall file on behalf of Harrisburg Corporate Limousine Services, Inc., an out of business affidavit and indemnify and hold Husband harmless for any liabilities arising out of his association with said corporation. 18. DISTRIBUTION OF VEHICLES: A. Automobiles: Wife shall keep the 2001 Mercedes automobile as her sole and exclusive property free of any claim or demand by Husband. From Wife's Ninety-seven Thousand Five Hundred Dollars ($97,500.00) cash payment set forth in paragraph 17(A) of this Agreement, the closing agent shall directly pay Wife's car loan with an approximate balance of Seven Thousand Dollars ($7,000.00) due and owing Members sc 11 Federal Credit Union. When the title is received by the lender, the Husband shall sign off on the title as the Seller so the Wife can have the vehicle in her sole name. Husband shall keep the 2002 Mercedes automobile as his sole and exclusive property, free and clear of any and all claim or demand by Wife. Husband shall be responsible for payment of the lien against same and shall indemnify and hold Wife harmless from same. (B) Boat: The parties own a 1992 Beneteau forty-five foot (45') Auxiliary Sailboat, Serial No. BEYJA1836192, which shall be Husband's sole and exclusive property. The parties acknowledge that there are no liens against the boat. Wife agrees to transfer title from joint names into Husband's name alone and execute all documents necessary to transfer the title to Husband. Wife shall execute the title upon execution of this Agreement. Husband shall be solely responsible for any insurance, maintenance, slip and storage fees and any other costs or expenses associated with said boat. Husband shall indemnify Wife for said expenses and hold her harmless from same. 19. BANKRUPTCY: The parties acknowledge that neither of them has filed or intends to file for bankruptcy. The parties further acknowledge that the provisions herein relating to alimony are interdependent with the provisions relating to property distribution and payment of debt and that Wife will necessarily rely upon receipt of the assets and debt payments in order to maintain a reasonable standard of living. Moreover, it is acknowledged that failure to receive the assets distributable to Wife pursuant to this Agreement will seriously impair Wife's ability to 12 /AC? meet her reasonable needs and that the alimony payments would have been significantly higher, but for the reliance of Wife upon receipt of the assets and payment of debt by Husband. Accordingly, Husband acknowledges that, in the event of any bankruptcy or insolvency proceedings, the property distribution and debt payments required by this Agreement should be recognized as non-dischargeable obligations and should survive any such proceeding in order to affect the intention and agreement of the parties herein. 20. TERMINATION OF LITIGATION: It is intended that this Agreement shall constitute full and final completion of all litigation and claims between the parties If not already completed, Husband shall withdraw his pending Motion to Compel filed on June 29, 2007, Docket #2007-976. Wife shall withdraw any pending appeals or motions filed and docketed to PACSES Case #622109022, Docket 07-976. 21. INCOME TAX RETURNS: The parties agree that they shall file joint federal and state income tax returns for the years 2005, 2006, 2007, 2008 and 2009. Husband agrees that he shall pay any tax liability due to the United States Government and the Commonwealth of Pennsylvania as well as tax liability, penalty and interest for 2005, 2006, 2007, 2008, and 2009. Wife agrees to promptly execute the returns for filing. Wife shall be solely responsible for her local and per capita taxes for 2005, 2006, 2007, 2008, and 2009. All accounting fees for federal and state returns shall be paid by the Husband. 13 f I 22. WAIVER OF RIGHT TO ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT, COUNSEL FEES, COSTS AND EXPENSES: The parties hereby acknowledge and do hereby fully waive any claim or right to alimony, alimony pendente lite, spousal support, counsel fees, costs and expenses from the other. 23. BREACH: If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as may be available to him or her, and the party breaching this contract shall be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement. 24. ADDITIONAL INSTRUMENTS: a. Each of the parties shall from time to time, at the request of the other, execute, acknowledge, and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. b. This Agreement shall be incorporated into a Divorce Decree but not merged therein. 25. MODIFICATION AND WAIVER: A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any ??V? 14 M("' of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 26. DESCRIPTIVE HEADINGS: The descriptive headings used herein are for convenience only. They shall have no affect whatsoever in determining the rights or obligations of the parties. 27. VOID CLAUSES: If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects, this Agreement shall be valid and continue in full force, effect, and operation. 28. EXECUTION DATE: The execution date shall be defined as the date both parties have signed this Agreement. In the event that the parties do not sign this Agreement at the same time, the execution date shall be the date the last party has signed. 29. APPLICABLE LAW: This Agreement shall be construed pursuant to the laws of the Commonwealth of Pennsylvania. 15 917- f IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above-written. wak Max J. Smith, Esquir Taylor Sumple-Sullivan, Esquire Je . Taylor 16 COMMONWEALTH OF PENNSYLVANIA ) ) SS. COUNTY OF ) Before me, the undersigned officer, a Notary Public in and for said Commonwealth and County, personally appeared Valerie C. Taylor, who being duly affirmed according to law, deposes and says that the facts and matter set forth in the within and foregoing Marital Settlement Agreement are true and correct to the best of her knowledge, information and belief. o before me this day of???? My commission expires: COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ....,.vVt:ALTlq OF P New ENNSYLVgN1, Notarial Barbara S?Ple-SWIi van, Notary Public MY Comm ? Boro• Cumbeland 7ember, Penns E xpo, Nov. 15, z011n Ylv rlon O/? No ar ) SS. Before me, the undersigned officer, a Notary Public in and for said Commonwealth and County, personally appeared Jeffrey C. Taylor, who being duly affirmed according to law, deposes and says that the facts and matter set forth in the within and foregoing Marital Settlement Agreement are true and correct to the best of his knowledge, information and belief. tffi an subscribed to before me this day of AQ?0t39- COMMONWEALTH OF PENNSYLV?ANlF NOTARY PUBLIC _ Notarial seal. My commission expires: Barbara Sumple-Sullivan, `VM&L01- New Cumberland Boro. Cumberiand County MY CommiS,11on Emires Nov 15, 2011 Member. Penns.,,ivan,a ?association of Notaries 17 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 t)F 1-W 549 Bridge Street THE PT?rmy New Cumberland, PA 17070 1??0 717) 774-1445 ." "S' 4H + JEFFREY C. TAYLOR, IN THE COURT OF COM PLEAS Plaintiff, : CUMBERLAND COUN3 V. NO. 2007 - 976 VALERIE C. TAYLOR, CIVIL ACTION -LAW Defendant DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 21, 2007. 2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days have elapsed since the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unworn falsification to authoritie DATE: Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 0717)774-1445 OF THE M }TMy 2D10 JAN _5 AN 11 r 51 JEFFREY C. TAYLOR, Plaintiff, V. VALERIE C. TAYLOR, Defendant : IN THE COURT OF CO S : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2007 - 976 CIVIL ACTION -LAW DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 33301(c) OF THE DIVORCE CODE I . 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 statement herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. DATE: Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNS VA&A V. NO. 2007 - 976 VALERIE C. TAYLOR, CIVIL ACTION -LAW Defendant DIVORCE a AFFIDAVIT OF CONSENT rn Q 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 21, 2007. 2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days have elapsed since the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unworn falsification to authorities. DATE: Z o C. Ta Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 r tF THE NARY 2010 JAN -5 AM 1 t: 5p JEFFREY C. TAYLOR, Plaintiff, V. VALERIE C. TAYLOR, Defendant : IN THE COURT OF COMM : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2007 - 976 CIVIL ACTION -LAW DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 33301(c) OF THE DIVORCE CODE 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 statement herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. DATE: l.g D . Taylor Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street 2010 JAN -5 AM 11: 52 New Cumberland, PA 17070 (717) 774-1445 ri &AFF;: jjri III JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLE 'rYWA Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2007 - 976 VALERIE C. TAYLOR, CIVIL ACTION -LAW Defendant DIVORCE PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for Divorce: Irretrievable breakdown under 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Acceptance of Service dated March 14, 2007. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: by Plaintiff December 18, 2009; by Defendant December 18, 2009. 4. Related claims pending: All matters have been resolved between the parties pursuant to the Marital Settlement Agreement dated December 18, 2009 and incorporated, but not merged, into the Decree. See paragraph 8, page 4. 5. Date Plaintiff s Waiver of Notice in 3301(c) Divorce was filed with Prothonotary: January 5, 2010. Date Defendant's Waiver of Notice in 3301(c) Divorce was filed with Prothonotary: January 5, 2010. DATE: January 4, 2010 Joy tsnage street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Plaintiff .. 4e Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 JEFFREY C. TAYLOR, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. VALERIE C. TAYLOR, Defendant : NO. 2007 - 976 : CIVIL ACTION -LAW : DIVORCE CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing Praecipe to Transmit Record in the above-captioned matter upon the following individual(s) by first class mail, postage prepaid, addressed as follows: Max J. Smith, Jr., Esquire James Smith Dietterick & Connelly, LLP 134 Sipe Avenue Hummelstown, PA 17036 DATED: January 4, 2010 Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 JEFFREY C. TAYLOR V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VALERIE C. TAYLOR : NO 07 - 976 DIVORCE DECREE AND NOW, O 2 . I v L c>, it is ordered and decreed that JEFFREY C. TAYLOR plaintiff, and VALERIE C. TAYLOR , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None. All matters have been resolved between the parties pursuant to the Marital Settlement Agreement dated December 18, 2009 and incorporated, but not merged, into the Decree. By the Court, ri vu iui iuum y C? 1