HomeMy WebLinkAbout97-00288
MARGO CORBELLINI,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
VB.
WILLIAM R. CORBELLINI,
Defendant
NO.97-288
19
CIVIL
IN DIVORCE
STATUS SHEET
DATE:
ACTIVITIES:
due 7/28/97.
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Mr. DeLuca, Attorney at Law and Mr. corbellini, Defendant
25 June 1997
Page 2
if he remains unrepresented, to discuss the issues and, if
necessary, schedule a hearing.
Very truly yours,
E. Robert Elicker, II
Divorce Master
NOTE: sanctions for failure to file the pre-trial statements
are set forth in subdivision (c) and (d) of Rule 1920.33.
THE ORIGINAL PRE-TRIAL STATEMENT SHOULD BE FILED IN THE
MASTER'S OFFICE AND A COpy SENT DIRECTLY TO OPPOSING
COUNSEL.
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MARGO CORBELLINI,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - LAW
NO. '11.:J.N C<;,;J Ti..~
WILLIAM R. CORBELLINI,
Defendant
DIVORCE COMPLAINT
AND NOW, comes the Plaintiff, Margo Corbellini, by her
Attorney, Anthony L. DeLuca, Esquire, and seeks to obtain a Decree
in Divorce, from the above-named Defendant, upon the grounds
hereinafter more fully set forth:
1. Plaintiff is Margo Corbellini, who currently resides at
17 E. High Street, Apartment 403, Carlisle, Cumberland county,
Pennsylvania since November 1, 1996.
2. Defendant is William R. Corbellini, who currently resides
at 750 Lock Road, Apartment 103, Deerfield Beach, Broward County,
Florida since May 17, 1996.
3. Plaintiff has been a bona fide resident in the
Commonwealth for at least six months immediately previous to the
filing of this Complaint.
4. The Plaintiff and Defendant were married on October 1,
1978 at Hauppauge, New York.
5. There have been no prior actions of divorce or for
annulment between the parties in this or any other jurisdiction
except for a current Petition for Dissolution of marriage filed in
Broward county, Florida to No. 96018211, the service of which is
subject to attack.
6. Neither Plaintiff nor Defendant is in the military or
naval service of the United States or its allies within the
provisions of the Soldiers' & Sailors' civil Relief Act of the
Congress of 1940 and its amendments.
7. The Plaintiff has been advised of the availability of
marriage counseling and understands that she may have the right to
request that the Court require the parties to participate in
counseling.
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COUNT I
REQUEST FOR A NO-FAULT DIVORCE UNDER
SECTION 3301 (c) OF THE DIVORCE CODE
8. Paragraphs 1 through 7 of this complaint are incorporated
herein by reference as though set forth in full.
9. The marriage of the parties is irretrievably broken.
10. After ninety (90) days have elapsed from the date of the
filing of this Complaint, Plaintiff intends to file an affidavit
consenting to a divorce. Plaintiff believes that Defendant may
also file such an affidavit.
WHEREFORE, if both parties file affidavits consenting to a
divorce after ninety (90) days have elapsed from the date of the
filing of this Complaint, the Plaintiff respectfully requests the
Court to enter a decree in divorce pursuant to Section 3301 (c) of
the Divorce Code.
COUNT II
REQUEST FOR A FAULT DIVORCE UNDER
SECTION 3301 (a) (6) OF THE DIVORCE CODE
11. Paragraphs 1 through 10 of this Complaint are
incorporated herein by reference as though set forth in full.
12. Defendant has offered such indignities to Plaintiff who
is the innocent and injured spouse as to render Plaintiff's
condition intolerable and life burdensome.
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13. This action is not collusive as defined by section 303 of
the Divorce Code.
WHEREFORE, Plaintiff respectfully requests the Court to enter
a decree of divorce pursuant to Section 3301 (a) (6) of the Divorce
Code.
COUNT I II
EQUITABLE DISTRIBUTION
14. Paragraphs 1 through 13 of this Complaint are
incorporated herein by reference as though set forth in full.
15. Plaintiff and Defendant have acquired property, both real
and personal, during their marriage until July 16, 1996, the date
of their separation.
16. Plaintiff and Defendant have been unable to agree as to
an equitable distribution of said property.
WHEREFORE, Plaintiff prays for the entry of an Order
distributing all of the aforementioned property, real and personal,
as the Court may deem equitable and just, plus costs.
COUNT IV
ALIMONY
17. Paragraphs 1 through 16 of this Complaint are
incorporated herein by reference as though set forth in full.
lB. plaintiff is unable to sustain herself during the course
of litigation.
19. Plaintiff lacks sufficient property to provide for her
reasonable needs and is unable to sustain herself through
appropriate employment.
WHEREFORE, Plaintiff requests your Honorable Court to enter an
award of alimony pendente lite until final hearing and thereupon to
enter an Order of Alimony in her favor, pursuant to the Divorce
Code.
COUNT V
COUNSEL FEES, COSTS AND EXPENSES
20. paragraphs 1 through 19 of this complaint are
incorporated herein by reference as though set forth in full.
21. plaintiff has employed Anthony L. DeLuca, Esquire to
represent her in this matrimonial cause.
22. Plaintiff is unable to pay the necessary counsel fees,
costs and expenses and defendant is more than able to pay them.
23. Reserving the right to apply to the Court for temporary
counsel fees, costs and expenses, prior to final hearing, Plaintiff
requests that, after final hearing, the Court order Defendant to
pay Plaintiff's resonable counsel fees, costs and expenses.
WHEREFORE, Plaintiff respectfully requests that the Court
enter an Order directing Defendant to pay Plaintiff's reasonable
counsel fees, costs and expenses.
1 verify that the statements made in this complaint are true
and correct. 1 understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn
falsification to authorities.
Date:
, .
.()
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Ant ony L.De
Attorney for laintiff
113 Front street
P.O. BoX 358
Boiling springs, PA 17007
(717) 258-6844
,
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MARGO CORBELLINI,
Plaintiff,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION,LAW NO: 97-288
vs.
WILLIAM R. CORBELLINI,
Defendant.
MOTION TO DISMISS
/
COMBS NOW Defendant, WILLIAM R. CORBELLINI, and moves to
dismiss Divorce Complaint and as grounds would therefore state as
follows:
1. Defendant, WILLIAM R. CORBELLINI, filed a Petition for
Dissolution of Marriage on December 20, 1996 which is currently
pending before the court in Broward County, Florida.
2. Defendant is a resident of Broward County, Florida.
3. Plaintiff and Defendant resided in Broward County,
Florida.
4. The parties separated in Broward County, Florida as
husband and wife until such time as Plaintiff/Wife left the
marital residence July 15, 1996.
5. Jurisdiction is proper in Broward County, Florida.
6. The court does not have subject matter jurisdiction
over this matter as the case is still pending in Broward County,
Florida.
WHEREFORE Defendant, WILLIAl1 R. CORBELLINI, moves to dismiss
the Divorce Complaint.
...,........-.
I HEREBY CERTIFY that a true and correct copy of the
foregoing has been mailed this ~b day of February, 1997 to
Anthony L. DeLuca, Esq. 113 Front Street, P.O. Box 358, Boiling
Springs, PA 17007.
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WILLIAM R. CORBELLINI
Pro Se
750 Lock Road #103
Deerfield Beach, FL 33442
(954) 426-3036
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After reasonable investigation, the Plaintiff is without
sufficient knowledge or information to form a belief as to the
truth or accuracy of the averment of Paragraph 2 of said Motion to
Dismiss, and accordingly, said averment is denied. Strict proof
thereof is demanded at the time of Hearing.
3.
Admitted in part.
It is admitted that the Plaintiff and Defendant resided in
Broward County, Florida for a short period of time in 1996. By way
of further Answer, the Plaintiff states that the parties resided
together in Broward County, Florida for not more than 7 to 8 weeks.
4.
Admitted.
5.
Denied.
It is specifically denied that Jurisdiction is proper in
Broward County, Florida. To the contrary, Defendant's service of
process upon Plaintiff in the Commonwealth of Pennsylvania on the
Divorce Action filed in Broward County, Florida was not valid and
was dismissed for Lack of Jurisdiction over the person pursuant to
the Order of Court attached hereto as Plaintiff's Exhibit "A". By
way of further Answer, the Plaintiff filed her own Divorce Action
in Cumberland County, Pennsylvania and had service of Process
validly completed on the Defendant on February 12, 1997 thus
creating jurisdiction in Cumrerland County, Pennsylvania. A copy
of Affidavit of Service is attached hereto, marked as Plaintiff's
Exhibit "B" and incorporated herein by reference.
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT OF FLORIO~, IN AND
,FOR BROWARD COUNTY, FLORIDA.
I CASE NO. 96018211
niCE 41 - 92
IN RE: THE MARRIAGE OF
WILLIAM CORBELLINI,
petitioner/Husband,
and
MARGO CORBELLINI,
Respondent/Wife.
/
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QVER ::~ ::R:~: ::Ei::~:J;C~~:~;::~ S::::;Ep::C::~CESS
,
THIS CAUSE came on to be heard upon the Respondent's Verified
Motion To Dismiss For Lack of Jurisdiction Over The Person And
Insufficiency Of service Of Pluce~D Or, tn The Alternative Motion
to Quash process and the Court having heard argument of counsel and
being otherwise fully advised in the premises, it is thereupon
ORDERED AND ADJUDGED that Respondent's veri tied Mot ion To
Dismiss For Lack of Jurisdiction over The person And Insuffic~ency
Of Service Of Process or,
hereby granted.
DONE AND ORDERED in Chambers, in Broward county, Ft.
day of February, 1997.
lAWRENCE \..1:...,\ ~.,.. r. EB ') 5 \aa1
ATRUECO;"/ r L n
Circuit Court Judge
Lauderdale, Florida, this
COPIES FURNISHED:
KA~aRYN M. BEAMER, ESQ.
1675 P.B. Lakes Blvd., .700
W.P.B., FL. 33401
JEROME L. ~EPP8, ESQ.
3411 powerline Rd., 8411
Ft. Lauderdale, FL. 33309
EXHIBIT II II
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AFtIDAVIT OF SERVICB
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Cdue Number: 97-288
.
Common Pleas Court
Plaintiff:
MARGO CORBELLIHI
vs.
Defendant:
lfILLIAH R. CORBELLIHI
For:
Anthony L.
ANTHONY L.
Deluca, Esq.
DELUCA, ATTORNEY AT LAW
-.......-..--..... ..--...-..----
Received by BLACKHAWK LBGAL SBRVICE INC on the 6th day of Pebruary,
1997 at 9:00 am to be served on lfILLIAM R. CORBBLLIHI, 750 Lock - APT. 10'3
Road, Deerfield Beach, FL. I, 10Pr\-TEl2.. -a.., who,
being duly sworn, depose and say that on the ay 0
F'E ~ , 19t1 at 2-: ~ ~.m., executed serv ce by delivering a
true copy of the Notice to De end and Claim Rights/Divorce
Complaint in accordance with state statutes in the manner marked
below:
,
()4 INDIVIDUAL SERVICB: Served the within-named person.
) SUBSTITUTE SERVICE: By serving as
.
( ) POSTED SBRVICB:
and on / at
described herein.
After attempting service on ___/___ at
to a conspicuous place on the property .
( OTHER SERVICE: As described in the Comments below by serving
as .
( ) NON SERVICE: For the reason detailed in the Comments below.
COMHBNTS: ~ '1 Pr'DnRr<,c::., ~ $\.0 ~'-\ P~. \)Av IE: =- :2.-\?--<\'1
NOT p,-r ~n~~~l}p,~((' ~~Ph~~F
I certify that I have no interest in the above action, am of legal
age and have proper authority in the jurisdiction in which this
service was made. r_ L .-- -
,~
Subscribed and Sworn to
before me on the ~ day of
fiiii ~ , \<=\" 1. by the
af ant who is personally
known to me.
PROCESS SERVER . J ~O
Appointed in accordance
with State Statutes
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BLACKIWtK LBOAL;SIRVICB .111C'
4521 P G A Boulevard "
Sul~~" 2~9. .;.', -_:,';/;..:~~f1io ..;,11\' "..,.. ~,. '1 '.
Pa!a'Beach"Gat4en8, n,":'33U8"
(561)" 743-1903 '~.,'
Our Job Serial NUmber: 97000799,
#'~~ Pit~ CHARlOm ETHeREDIE
· hCOUl.llIlION ,
~. . !X~I~U se~CC317739
"'-\l' "" Alllnt'c Iondl 21,1997
CIr '" 800. 7J2~?~g..rnc,
EXHIBIT 'n II
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW NO: 97-288
MARGO CORBELL IN I ,
Plaintiff,
vs.
WILLIAM R. CORBELLINI,
Defendant.
VERIFIED REPLY TO PLAINTIFF'S
ANSWER TO MOTION TO DISMISS
/
COMBS NOW Defendant, WILLIAM R. CORBELLINI, and files this
Reply to Plaintiff's Answer to Motion to Dismiss and states as
follows:
1. Defendant, WILLIAM R. CORBELLINI, filed a Petition for
Dissolution of Marriage on December 20, 1996 which is currently
pending before the court in Broward County, Florida.
2. The Broward County Circuit Court entered an Agreed
Order Granting Verified Motion to Dismiss for Lack of
Jurisdiction Over the Person and Insufficiency of Service of
Process Or In the Alternative Motion to Ouash on Februa~ 25.
~, a copy of which is attached hereto and incorporated by
reference herein as Exhibit A.
3. A subsequent Order Clarifying Order of February 25,
1997 was entered providing that Service of Process be Quashed and
an Alias Summons be issued. A copy of said Order is attached
hereto and incorporated by reference herein as Exhibit B.
4. The Florida Petition for Dissolution of Marriage was
never dismissed.
5. Jurisdiction remains proper in Florida as both parties
relocated to Florida and resided together in Broward County,
Florida at the time the marriage broke up.
6. DEFENDANT HAS NEVER RESIDED IN PENNSYLVANIA AND IS NOT
SUBJECT TO ITS JURISDICTION.
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MARGO CORBELLINI,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
VB.
WILLIAM R. CORBELLINI,
Defendant
NO. 97-288
Pre-trial Statement
1. List of Marital and Non-Marital Assets.
Marital Asset
Date of
Value Valuation
Liens and
I'hro """"'1Y'l<>Ct
Portion
Non Marital
a(1.)Furniture and
furnishinge
a(2.)Husband's IRA $96,452.00 7/96
rolled over from
Pension.
$12,170.00 7/15/96
-0-
-0-
-0-
-0-
a(3.)Money obtained $18,750.00
from employer of
Husband as severance
and consulting fees
-0-
-0-
a(4.)Motor vehicle of
Wife-1987 Toyota
camry
3,500.00 7/25/97
-0-
-0-
Non-Marital Asset
Date of
Valuation
Liens and
I'hromthr;olY'l<>Ct
Value
b(1.)proceeds from
settlement of
personal injury
matter by Wife
$14,000.00
7/16/96
-0-
2. Name and address of each expert Plaintiff intends to call at
trial as a witness.
a. Harry M. Leister, Jr., F.S.A.
Consulting Actuary
Conrad M. Siegel, Inc.
500 Nationwide Drive
P.O. Box 5900
Harrisburg, PA 17110-5900
b. Handwriting expert if necessary.
,
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,
::.
3. Name, address and short summary of the testimony of each
person, other than the Plaintiff, whom the Plaintiff intends
to call at trial as a witness:
P.J. Heyman, 619 Lerew Road, Boiling springs, PA 17007
Would testify to amount of IRA of Defendant and that Plaintiff
was the beneficiary.
4. List of all of the exhibits which the plaintiff expects to
offer in evidence:
A. Report of Harry M. Leister, Jr., F.S.A.
B. Merrill Lynch Direct Rollover Delivery Instructions,
including election and consent, for Individuals as
requested by the Defendant.
C. Application for Cash-Out Distribution.
D. Letter dated March 22, 1996 from the Defendant to Mark
Levinson.
E. New York Thoroughbred Breeders, Inc. Profit Sharing Plan
employee benefit statement from 1/1/95 to 12/31/95.
F. summary Plan Description Merrill Lynch profit Sharing
Plan.
G. Letter from Defendant to Merrill Lynch dated March 25,
1996 authorizing Merrill Lynch to make a distribution for
Defendant.
H. Letter from Jack Kelly, Vice President Merrill Lynch to
Defendant authorizing the issuance of monthly checks of
$531.00 beginning on June 30, 1996.
I. Letter from Merrill Lynch to Defendant dated April 16,
1997 transferring $4,000.00 to Barrett Bank in Florida.
J. IRA adoption Agreement; Retirement Plan Beneficiary Form;
and monthly account statements from January, 1987 to May,
1997 from Merrill Lynch; copies of the IRA Adoption
Agreement and Retirement Plan Beneficiary form are
attached hereto but the monthly statements, which set
forth the status of the account, are not included because
they exceed three (3) pages.
K. Severance Agreement and Consulting Contract with New York
Thoroughbred Breeders, Inc.
INVENTORY AND APPRAISEMENT OF
MARGO CORBELLINI
Margo Corbellini files the following inventory and appraisement of
all property owned or possessed by either party at the time this
action was commenced and all property transferred within the
preceding three years.
Margo Corbellini verifies that the statements made in this
inventory and appraisement are true and correct. He Understands
that false statements herein are made subject to the penalties of
18 Pa. C.S. 54904 relating to unsworn falsification to authorities.
C_~~f2IL .
bellini, Plaintiff
ASSETS OF PARTIES
Plaintiff marks on the list below those items applicable to the
case at bar and itemizes the assets on the following pages. If an
item has been appraised, a copy of the appraisal report is
attached.
( ) 1. Real Property
(X) 2. Motor Vehicles
( ) 3. stocks, bonds, securities and options
( ) 4. Certificates of deposit
1
Checking accounts, cash
Savings accounts, money market and savings
certificates
() 7. Contents of safe deposit boxes
() 8. Trusts
(X) 5.
() 6.
(X) 9. Life Insurance policies (indicate face value, cash
surrender value and current beneficiaries)
() 10. Annuities
() 11. Gifts
() 12. Inheritances
() 13. Patents, copyrights, inventions, royalties
() 14. Personal property outside the home
() 15. Businesses (list all owners, including percentage
of ownership, and officer/director positions held
by a party with company)
(X) 16. Employment termination benefits -- severance pay,
workman's compensation claim/award
() 17. Profit sharing plans
(X) 18. Pension plans (indicate employee contribution and
date plan vests)
(X) 19. Retirement plans, Individual Retirement Accounts
() 20. Disability payments
(X) 21. Litigation claims (matured and unmatured)
() 22. Military/V.A. benefits
() 23. Education benefits
() 24. Debts due, including loans, mortgages held
(X) 25. Household furnishings and personalty (including as
a total category and attach itemized list if
distribution of such assets is in dispute)
() 26. other
2
LIABILITIES OF PARTIES
Plaintiff marks on the list below those items applicable to the
case at bar and itemizes the liabilities on the following pages:
Secured
( ) 1. Mortgages
( ) 2. JUdgments
( ) 3. Liens
( ) 4. other secured liabilities
Unsecured
(X) 5. Credit card balances
( ) 6. Purchases
(X) 7. Loan payments
( ) 8. Notes payable
( ) 9. Other unsecured liabilities
continaent or Deferred
( ) 10. Contracts or Agreements
( ) 11. Promissory Notes
( ) 12. Lawsuits
( ) 13. Options
( ) 14. Taxes
(X) 15. Other contingent or deferred liabilities
3
MARITAL PROPERTY
plaintiff lists all marital property in which either or both
spouses have a legal or equitable interest individually or with any
other person as of the date this action was commenced:
Item Number Description of property NameB of all
Owners
1. Furniture and furnishings Joint
2. Husband's IRA Rolled over Husband with
from Pension wife as
Beneficiary
3. Severance Agreement and Husband
Consulting Fee
4. 1987 Toyota camry Automobile Wife
NON-MARITAL PROPERTY
Plaintiff lists all property in which a spouse has a legal or
equitable interest which is claimed to be excluded from marital
property:
Item
Number
Description
of prODertv
Reason for
Exclusion
1.
settlement proceeds
from personal injury
case.
4
CERTIFICATE OF SERVICE
The undersigned does hereby certify that a true and correct
copy of the foregoing document was mailed this date by depositing
same in the possession of the United States Postal Service by first
class mail, postage prepaid, addressed to the following:
William R. corbellini
750 Lock Road #103
Deerfield Beach, Florida 33442
Dated: tlil! ..1cf", 1?f'1
(I f/ I
BY:
PA 17007
y
~
6/26/97
services Rendered
~
Drafting of letter and subpoenas to
Michael Flynn, Executive Director,
New York Thoroughbred Breeders, Inc.;
CUstodian of Records, Merrill Lynch;
CUstodian of Records, Barnett Bank;
letters to Jerome Teppe, Eequire, and
william R. Corbellini
7/8/97 Letter to Conrad M. siegel, Inc.
i
,
3.0
.1
7/8/97 Fax copies of documents to
Kathryn Beamer, Esquire
7/11/97 Faxes to Kathryn Beamer, Esquire
and Juanita Palacio, Barnett Bank
.1
.2
7/22/97 Letter to Michael Flynn, Executive
Director, New York Thoroughbred
Breedere, Inc.
.1
7/22/97 Copy records received from
Merrill Lynch for client
7/22/97 Review and provide client with
letter dated 7/22/97 from Attorney
Tepps,
7/23/97 Review of Records received from
Merrill Lynch
7/25/97 Conference with client
Re: Pre-trial statement
1.0
.1
1.3
1.0
7/27/97 Preparation of Pre-trial statement
7/28/97 Conference with client
1.4
~
Total number of hours
20.3
20.3 hours @ $100.00 per hour
$2,030.00
...... ',.
-
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~ ON JUL\' 1'5', 199C.
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June 19, 1997
Con"'~ M. Si<I<1. F,S A.
H.lT)' M. L<iller. Jr,. FS A.
8ri.. S. S..n. F.S.A.
Clyde E. Oinlrich. F.S.A.
!:ori L. Mumm<n. E.A.
Robtn J. Dol... ....S.A,
D.vld F. Slirllnl. ....S,A.
Robtn J. Mnuik. F.S.A.
Dovi~ H. Killick. F.S.A.
J<ffrey S. My<n. F.SA,
Thom.. L. Zimmc:rm... FSA
Ol<nn .... H.fer. F.S,....
K<vin A. Erb. F.S.A.
F...nk S. Rhod... F,S.A.. A.C.A,S,
Chori.. 8 F,,<~I.n~er. F.S.A,
Holly A. Ross. F.S,A.
John W. Jeffrey. A.S.A.
DeRlst M. Polin. A.S.A.
Richor~ C. Smilh. A.S.A,
ColI<<n J. Ric<. A,S.A.
Thom:u W Rt('se. A_SA
Conrad M. Siegel, Inc.
Actuaries/Benefits
500 Nalionwide Drive
P. O. Box 5900
Harrisburg, P.-\ 17110.5900
(717) 652-5633
Fa.. (717) 510-9106
Anthony L. Deluca, Esquire
113 Front Street
P.O. Box 358
Boiling Springs, PA 17007
RE: Corbellini
Dear Mr. Deluca:
Pursuant to your request I reviewed the various materials you provided concerning this
case.
I have th~ following comments:
1. It appears that Mr. Corbellini already had an IRA account with Merrill Lynch
into which $73,364.61 was transferred from the New York Thoroughbred
Breeders, Inc. Profit Sharing Plan on or about March 25, 1996. Since June 30,
1996, Mr. Corbellini has been receiving $531 per month from the IRA account.
You provided me a statement of the IRA account indicating a value as of
December 31, 1996, of $92,735. In my opinion, the appropriate value for
marital dissolution purposes would be $96,452 (the value of the IRA account
as of December 31,1996, plus $3,717 paid to Mr. Corbellini during 1996). This
is an approximation since it does not take into account interest on the
payments nor does it take into account any interest on the account from
December 31, 1996, until the current date.
You provided me with information indicating that Mr. Corbellini had made an
offer of $25,000. This appears to be a good faith offer if there are no other
asst!ts and if the assets are to be split 50/50. However, it would appear that a
more appropriate figure would be $48,226 or 50% of the estimated IRA account
value of $96,452.
2. I note that Mr. Corbellini commenced his employment with the New York
Thoroughbred Breeders, Inc. on December I, 1981. On that date he was 48
years of age. The reason for mentioning this is that I wonder whether
Mr. Corbellini might have accrued pension benefits for employment before
December I, 1981. If so, the portion of any benefits earned before December I,
1981, that were earned during the marriage would be marital property for
divorce purposes.
~ MerriULynch
DIRECT ROLLOVER DELIVERY INSTRUCTIONS
For Individuals
-
PLAN PARTICIPANTS: Complllle tills lorm <1nd give It to your Employer/PI<111 Administrator/Plnn Trustee
TO: Ne~ York ThorouRhbred ~reeders, ~nc.
Employer/Plan AdmlnlslraloriPlan Trustee
New Y~rk ThorouRhbr~d Breede~s,.!nc.. Profit Sharing Plan
NamH 01 Plan
287 Hempstead Turnpike, Elmo.nt , NY 1.1003 ...
Employe(S Addtuss
New York ThorouRhbred Breeders, Inc.; (516) 3~~-7600; Susan Leisen
Namu and Telephone Number ot Employer/Plan Contacl
RE:.~ 'j?M,Jt( Gk--/(I~I'
Name 01 Pa~iclpant
586-05653. _.
Pn~iclpanl Plan Account Number (i' appliCilble)
. i ~.'il-rJ.tJ- 9:3.(2,0
Social security Number
Dear EmployerlPlan Adminislratorrrrustae:
Plcasc deliver the cd~h wId/or securities eligible fordirecl rollover Ul0tI l10ve requesled be dislnbuted from the plan referenced above
as a direct rollover to my account at Mornll Lynch as described below:
)if Merrill LynclllRA Accounl
U Merrill Lynch Retirement Selector Account (RSA 403(b)(7))
My Merrill Lynch IRNRetiremenl Seloctor Account Number referenced below and my Soclal Security Number must be Indlcatod
on any check or security to be transrerred in a direct rollover to Merrill Lynch. and the clleck must be made payable 10:
MLPF&S as Custodion FPO ~ IRA
U 403(b)(7)
_W///'('m ~nall Gkl/;,,',
FBO PanicipanvSpousal Benelic'1'Y Name
Me"i11 Lync/l Account Num/)or:
5.<;(la - ;)3 S 'fr / . .
Supplied by Merrill Lynch Financial Consullanl
.
o
U
Give Ul.., chuck to me for delivery 10 Merrill Lynch
Deliver checks and securities to Merrill Lynch by lollowlng tho Instructions printed on the
back 01 this lorm.
vv.,e~ -.
f~vSpousal BellHficin'Y Signature
~C1.~~
K- 3-21-n
Dale
To Employer/Plan AdmlnlstratorfTrustee
TIle above mentioned Merrill Lynch custodial account Is established lor recelpl of a direct rollover 01 an englble rollover
CISlnbulion 10 Ihe porticipanVspousal beneficiary namod above. Merrilll.ynch's acceptance of this dlrecl rollover dlstribuUon is
conlingent upon our review of lire asset5 dislribUled Irom the plan and thair compalibilily wilh our operational and procedural
gUidelines.
')!1.~qL
Dale
~v~-
Merrill Lynch AulhOrized Signnlure
--,
SUMMARY PLAN DESCRIPTION
MERRILL LYNCH PROFIT SHARING PLAN
Plan Sponsor: New York Thorouohbred Breeders. Inc.
Address: 2B7 HemDstead TPKE Elmont. NY 11003
Telephone Number: (516) 354-7600
Plan Sponsor's Taxpayer 1.0. Number: 11-258B501
.Plan Identi fication #: 001
The plan officials listed below have the same address and telephone number
as the sponsor.
Trustees.
Plan Administrator: New Yor~ Thorouohbred Breeders. Inc.
Agent for Service of Legal Process: same as above
.Please indicate present trustee.
PURPOSE OF THE PLAN
As an employee of our Company, you are eligible or will become eligible to
participate in our Retirement Plan. The purpose of the Plan Is to provide
retirement income for you so that you can have a better standard of living
after retirement than you could have from Social Security and from your
s~'lngs alone. The effective date of adoption was 7/1/B8
Benefits under the Plan are being invested by Trustees appointed by the
Plan Sponsor. The plan Is being maintained at the Company's own expense.
There Is no cost to you.
This booklet provides information regarding the Plan. The terms of the
Plan are stated In and will be governed in every respect by the Plan and
Trust Agreement. A copy of the Agreement is available for your inspection.
ELIGIBILITY REOUIREMENTS
A. An eligible Employe.. must ,ileet tile following requirements to beccme a
PartiCipant (select one):
(1) Performance of one Hour of Service
X (2) Attainment of age 21 (maximum 21) and completion of
--1-- (not more than 3) Years of Service
B. "Entry Date" shall mean the first day of Julv and the first
day of the month following the six-month anniversary thereof.
CONTRIBUTION AND ALLOCATION
A. Allocation of Non-Integrated Employer Contributions shall be credited
with a portion of that contribution equal to the ratio that your
Compensation from the contributor for the Plan Year bears to such
Compensation of all Participants entitled to share in the contribution.
B.' Allocation of Integrated Employer Contributions
Your share will be allocated as follows:
1. First, in the ratio that your Compensation for the Plan Year bears to
the Compensation of all Participants for the Plan Year. Not more than 31
of your Compensation, however, will be allocated to your account.
Moreover, your employer also maintains a money purchase pension plan or a
target benefit plan no contribution will be allocated under this
paragraph;
2. Second, the remaining contribution will be allocated to your account
in the ratio that your Compensation for the Plan Year in excess of the
Integration Level (defined below) bears to the Compensation for that Plan
Year of all eligible Participants In excess of that Integration Level.
(however, the amount allocated cannot exceed the product of 5.71" times
your compensation in excess of the Integration Level.); and
3. Third, any remaining contributions will be allocated to your account
in the ratio that your compensation for the Plan Year (whether or not you
received an allocation under the preceding paragraphs) bears to all such
Participants' Compensat10n for the Plan Year.
C. Integration Level -- The Integration Level for allocation purposes shall
be the Taxable Wage Base in effect as of the first day of the Plan Year
for which the allocation is to be made or $ 26.000
VESTING AND MISCELLANEOUS
A. A Participant shall have a vesting percentage of his or her Employer
Contributions Account In accordance with the following vesting schedule:
(1) 1001 Immediately upon participation
(2) 1001 after (no more that 3) years of Vesting Service
X (3) 20 1 (not less than 201) after 2 years of Vesting Service
40 1 (not less than 401) after 3 years of Vesting Service
60 1 (not less than 601) after 4 years of Vesting Service
80 1 (not less than 801) after 5 years of Vesting Service
1001 after 6 years of Vesting Service
(4) The prior election shall not apply with respect to Key
Employees, who shall be 1001 vested after 10 years of Vesting
Service
PARTICIPANT ACCOUNTS
X 1. Contributions paid Into the Tru~t shall make up a fund which shall be
Invested and administered as a unit. Records will be kept as to the amounts
accumulated In your account and you shall have added to or subtracted from
your account any fund earnings or losses which may occur during a Plan Year.
These additions or subtractions will be based upon an annual valuation of the
Plan assets at the end of each Plan Year. The total amount allocated to your
account Is known as your accrued benefit.
2. The plan permits you to direct your own Investment account through
your Merrill Lynch Financial Consultant. Thus your accrued benefit will
depend upon your Investment results.
PLAN YEAR
The plan year for accounting purposes Is the consecutive 12 month period
beginning on the first day of Julv
NO~MAL RETIREMENT DATE
Your Normal Retirement Date will be the later of:
1) The date of your 65th birthday, or
2) Completion of 10 years of Participation in Plan
NORMAL RETIREMENT BENEFIT
At your normal Retirement Date, you will be entitled to 100% of your accrued
benefit with respect to the Plan Year in which you retire.
DESIGNATED BENEFICIARY
If you are married for at least a year your designated beneficiary at death
must be your spouse, unless he or she waives their right in favor of another
beneficiary. Your plan administrator can supply you with a waiver form.
DEATH BENEFIT
Should you die prior to attaining your Normal Retirement Date, your designated
beneficiary will be entitled to 100% of your accrued benefit with respect to
the Plan year in which your death occured.
DISABILITY
Should you become disabled, so that you no longer can continue with the
Company, you will be entitled to 1001 of your accrued benefit.
BENCFIT OPTIONS
If the amount of your accrued benefit is less than $3,500 It may be paid to
you In one lump sum by the Trustee. If it Is greater than #3,500 the Trustee
will hold the money for you until your normal retirement date unless you elect
to receive it before, and the Plan Administrator agrees.
With the consent of the Trustees, the Participants shall have the fOllowing
options available under the Plan:
1) Lump Sum
2) Equal installments (not to exceed 15 years)
3) Any other form of benefit approved by the Administrative Committee.
BREAK IN SERVICE
If you complete 1.000 hours during the 12 month period beginning after a break
in service, you will commence participation as your date of re-employment.
For purposes of computing your vested accrued benefit should you again
terminate employment, your years of service prior to the first break In
service will only be counted if the aggregate number of years in which you had
breaks in service are less than the aggregate number of years of active
participation In the Plan. A break in service is any Plan Year in which you
have completed less than 500 hours of service with the Company.
LEAVES OF ABSENCE
If you are absent because of sickness, accident or other authorized leave of
absence. you will be eligible to continue as a Participant in the Plan.
AMENDMENT AND TERMINATION
Your Employer reserves the right to amend the Plan. However, no amendment can
deprive you of any benefits previously accrued. Although your Employer
expects to continue the Plan permanently, it necessarily reserves the right to
terminate the Plan. Under such circumstances, you will be entitled to all
amounts standing to your credit under the Plan. In no event can any funds
which have been paid into the Plan revert to the employer unless they arise as
,a result of an actuarial error and only upon termination of the Plan.
PROCEDURE ON DENIAL OF CLAIM FOR BENEFITS
Your benefits under the Plan can only be forfeited in whole or in part as a
result of termination of employment prior to your Normal Retirement Date. The
right of appeal regarding a denial of benefits under the Plan is afforded to
you. If you wish to appeal a benefit determination, a request of the Plan
Administrator, in writing, should be made within 60 days of receipt of your
written notice of benefits. Th~ Plan Administrator will review the decision
concerning your claim. and you will be advised of the results of the review
within 60 days of rece1pt of your request.
As a participant in the Plan you are entitled to certain rights and
protections under the Employee Retirement Income Security Act of 1974
(ERISA). ERISA provides that all plan participants shall be entitled to:
Examine, without charge, at the plan administrator's office, all plan
documents, insurance contracts, if any, and copies of all documents flIed
by the plan with the U.S. Department of Labor, such as annual reports and
plan descript10ns.
Obtain copies of all plan documents and other plan information upon
written request to the plan administrator. The adm1nistrator may impose
a reasonable charge for the copies.
Receive a summary of the plan's annual f1nancial report. The plan
administrator is required by law to furnish each participant with a copy
of this Summary Annual Report.
Obta1n, once a year, a statement of the total benefits accrued and either
the nonforfeitable benefits, or, the earliest date on which benefits will
bec~me nonforfeitable. Th~ plan may require written request for this
statement, but it must provide the statement free of charge.
File suit 1n a federal court if any materials requested are not received
w1thin 30 days of the participant's request, unless the materials were
not sent because of materials beyond the control of the administrator.
The court may require the plan administrator to pay up to $100 for each
day's delay unt11 the materials are rece1ved by you.
In add1tion to creating rights for plan participants, ERISA imposes
obligations upon the persons who are responsible for the operation of the
Plan. These persona are referred to as "fiduc1ar1es" in the law. Fiduciaries
must act soley in the interest of the plan participants and they must exercise
prudence in the performance of their plan duties.. Fiduciaries who violate
ERISA may be removed and required to make good any losses they have caused the
plan.
~
~
March 25, 1996
New York Thoroughbred Breeders, Inc.
W.R. Corbelllnl. EztICtJlNe OIntCIDr
. otnce~ .
Louis M. Sliemo. Pr.sldtinl
nrrolhy Boyan. \-1", Pr.sldsnl
Jill P. RIch. S#arlI1II)fl",lSlJIfIr
. Dll1lClors -
Sarilall Bl1IWUr
Ronald J. Davis, Esq.
Michael O. Aynn
Thomas J. Gallo. III
Carl Uua. Jr.
Karen A. Murphy. Esq.
Gus Schoonbom. Jr.
PhIUp J. Trowbridge
2B7 Hempstead Tpke
Elmonl, NY 11003
(516) 354.7600
(516) 35B.9426 Fax
Merrill Lynch
One Galleria Tower, 7th Floor
13355 Noel Road
Dallas, Texas 75240
To Whom It May Concern:
This letter authorizes Merrill Lynch to make a distribution for William Ronald
Corbellini in the amount of $73,364.61. Please make a direct transfer to William Ronald
Corbellini's IRA Account #58623581. There is no reason to withhold taxes since this will
be a direct transfer to an Individual Retirement Account.
As Trustee for New York Thoroughbred
Breeders Profit Sharing Plan
(Account #586-0563),
'Z(/./f'.
W.R. Corbellini
Executive Director
WRC:sl
Original sent via US Mail
t
Mlrrlll Ly. . Pllr.o, Flnnlr a Smllh In..
3900 South Tollor
Llkowood. Colorado 80235
~Merrlll Lynch
June 11, 199B
ReI: Account 586-23581
MLPF& S CUST FPO
WILLIAM RONALD CORBELLlNIIRA
FBO WILUAM RONALD CORBiLLlNI
750 LOCK RD APT 103
DEERFIELD BEACH FL 33442
Dellr Client:
This letter will conllrm that you have authorized automatic distributions as described below,
from the above referenced retirement account.
You have authorized Merrill Lynch to automatically Issue checks on a monthly basis, beginning
OB/30/9B,ln tho amount of $531.00 to the following name and address:
WILLIAM RONALD CORBELLlNI
750 LOCK RD APT 103
DEERFIELD BEACH FL 33442
For Faderallncome Tax purposes these checks will be reported as annultlzed distributions from
your retirement plan account. Our records Indicate that your tax Identification number Is
122-24-9320. For federal Income taxes, you have elected to withhold 10% and no dollar
amount.
You have established no expiration date for this Periodic Installmenllnslructlon.
Please contact your Financial Consultant If the IboVI Informltlon dOli not loourltlly
confirm your Instructions. A corracted confirmation letter will be lint to you.
Sincerely,
~~
,
Jlck KoUy
VlCI Pros/dint - Clllnf Account SllVIcIS
Prlvale Cllenl Group
Weslern Service Operallons
3840 Soulh Wadsworth Boulevard
Lakewood. Colorado 80235-
~ Merrill Lynch
04/16/1997
MLPF& S CUST FPO
WILLIAM RONALD CGRBELLINI IRP.
FBO WILLIAM RONALD CORBELLINI
750 LOCK RD # 103
DEERFIELD BCH FL 33~42
Dear Customer:
In compliance with your instruc~ions, a federal funds wire
transfer in the amount of $4,000.00 has been made to the
following bank account: BARNETT BANK
CREDIT W. R. COR3ELLINI A/C 3625475789
from account n~~er: 5B6-23591
Very truly yours,
Merrill Lynch, Pierce, Fenner & Smith, Inc.
t
.'
~
i
W.A. CoItloIili. &clINo DndDt
New York Thoroughbred Breeders, Inc.
287 Hempstead Turnpike
Elmon!, New Vork 11003
(516) 354.7600
Fax: (516) 358.9428
;'"
SFVERANCE AGREEMENT AND CONSULTING CONTRACT
Whereby, William R. Corbellini, (herelnafte. "WRC") has had his employment relatlonlhip wllh the
New York Thoroughbred Breeders, Inc. (hereinafter 'N.Y.T.B.") levered. and whereby the N.Y.T.B.
wishes to retain WRC as a consultant to the N.Y.T.B. Ills therefore agreed to between the panles as
follows:
1. That WRC's employment relationship shall be severed with N.YT,B. on April B. 1996.
2. That during the period from April B, through April 19, 1996, WRC Ihall alllltln the orderly
translUon from the position of Executive Dlreclor 10 that of consullantto N.Y,T.B.
3. That during the period April 8, 1996. through April 19. 1996, WRC Ihall advise N.Y.T.B. or its
designee as to all mailers of business pertaining 10 Ihe opera lion of the N.Y.T.B. Including the
corporate books, records, accounts. Insurance policies and luch other recordl and documents
which pertain to the activities and affairs of the N.Y.T.9.
4. That from April 22, 1996, through September 30, 1996, WRC Ihall be a consullant to the
N.Y.T.B. during which period of time he shall perform the following lervlces:
(a) Consult dally with the newly appointed Executive Director for a pllrlod of three (3)
weeks form his date of appolnlmenllo aid In the tranlltlon process.
(b) Consult periodically wllh the newly appointed Executive Director on all matters
penalnlng to N.Y.T.B. bualness
(c) Consull periodically with N.Y. T.B or lis designee with regard to the New York Stallion
Stakes and the New York. Bred Showcale Day.
5. That WRC shall receive the sum of elghleen thousand seven hundred ftfty (S1B,750) dollars in
payment for the above referenced services and such other good and valuable consideration.
Agreed to on behalf of
William R. Corbelllnl:
WilliAM R. CORBElLlNI
Agreed to on behalf of
New York Thoroughbred Breeders, Inc.:
lOUIS M SALERNO. President
Dated: March 25. 1996
," ".rrill Lyuah
--
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Locator EN1AAAACOI0104 P.3
R.Urement Plan Beneflciery Form
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