HomeMy WebLinkAbout97-00565
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Footed dough tray with modern legs
Oak Sideboard with mirrored back
Zenith Portable Color Television with remote
3. The remaining items are to become the sole and separate
property of Husband and are designated as follows:
Oak Library Table with drawer
White marble top stand
Oak Washstand with modern towel rack
Oak Chest of Drawers with mirror and pine top
Sunbeam Gas Grill
Wall kerosene bracket lamp
By the Court,
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The Plaintiff had previously filed a complaint in divorce in this
jurisdiction at 1875 Civil 1992, which had, however, been
discontinued.
7
In accordance with Section 3301(c) of the Divorce Code, the
marriage between the parties is irretrievably broken.
8
Plaintiff has been advised that counseling is available and that
Plaintiff may have the right to request that the Court require the
parties to participate in counseling.
WHEREFORE, the Plaintiff requests your Honorable Court to decree
that the Plaintiff be divorced from the Defendant.
COUNT II - EQUITABLE DISTRIBUTION
9
Paragraphs 1 through 4 of the Complaint are incorporated herein by
reference as though set forth in full.
10
Plaintiff and Defendant have acquired property, both real and
personal during their marriage from October 24, 1981, until
November 29, 1996, the date of their separation.
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I verify that the statements in the foregoing pleading are true and
correct. I understand that false statements herein are made
subject to the penalties of 18 paCS 4904 relating to unsworn
falsification to authorities.
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VICKIE A. MENTZER
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VICKIE A. MENTZER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
CIVIL DIVISION - LAW
GARY L. MENTZER,
Defendant
97-565 CIVIL TERM
IN DIVORCE
AMENDED COMPLAINT
Plaintiff, Vickie A. Mentzer, by her attorney, Christopher C.
Houston, Esquire, sets forth the following:
1
Plaintiff, Vickie A. Mentzer, is an adult individual residing at
163 Conodoguinet Mobile Estates, Newville, Cumberland County,
Pennsylvania.
2
Defendant, Gary L. Mentzer, is an adult individual residing at 505
Shippensburg Road, Newville, Cumberland County, Pennsylvania.
3
The parties were married on October 24, 1981, in Newville,
Cumberland County, Pennsylvania.
4
Plaintiff and Defendant have lived continuously in the Commonwealth
of Pennsylvania for at least six months prior to the commencement
of this action.
5
This action is not collusive.
6
The Plaintiff had previously filed a Complaint in Divorce in this
jurisdiction at 1875 Civil 1992, which had, however, been
discontinued.
7
In accordance with Section 3301(c) of the Divorce Code, the
marriage between the parties is irretrievably broken.
8
Plaintiff has been advised that counseling is available and that
Plaintiff may have the right to request that the Court require the
parties to participate in counseling.
WHEREFORE, the Plaintiff requests your Honorable Court to decree
that the Plaintiff be divorced from the Defendant.
COUNT II - DIVORCE PURSUANT TO 3301(a) (6)
9
Paragraphs 1 through 6 of the Complaint are incorporated herein by
reference as though set forth in full.
10
The Defendant has offered such indignities to the Plaintiff, the
injured and innocent spouse, as to render her condition intolerable
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GARY L MENTZER
505 SHIPPENSBURG RD
NEWVILLE PA 17241
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VICKIE A. MENTZER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. CIVIL ACTION - LAW
NO. 97-565 CIVIL II)
GARY L. MENTZER, .
.
Defendant IN DIVORCE
ORDER AND NOTICE SETTING HEARING
To: Vickie A. Mentzer
Christopher C. Houston
Gary L. Mentzer
, Plaintiff
, Counsel for Plaintiff
, Defendant
Counsel for Defendant
You are directed to appear for a hearing to take
testimony on the grounds for divorce of indignities to
the person at the Office of the Divorce Master, 9 North
Hanover Street Carlisle, Pennsylvania, on the 23rd
day of September , 19.2], at 9:00 a .m, at which place and
time you will be given the opportunity to present witnesses and
exhibits in support of your case.
By the Court,
~~ \::::
Harold E. Sheely,
,Judge
Date of Order and
Notice: 6/3/97
By:
Divorce Master
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Court Administrator
Fourth Floor, East Wing
Cumberland County Courthouse
Carlisle, PA 17013
Telephone (717) 240-6200
VICKIE A. MENTZER,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97 - 565 CIVIL
GARY L. MENTZER,
Defendant
IN DIVORCE
MEMORANDUM OF UNDERSTANDING
Friday, January 23, 1998
THE MASTER: Present for the pre-hearing conference
today is attorney Christopher C. Houston, who represents Vickie
A. Mentzer, and attorney H. Anthony Adams, who represents Gary
L. Mentzer.
On September 23, 1997, we had a hearing at which
time testimony was taken on the grounds of indignities. After
that hearing, the Master directed pre-trial statements be filed
by October 24, 1997. Mr. Houston filed a pre-trial statement on
behalf of wife; Mr. Adams has not filed a pre-trial statement.
After discussing the case today, the Master has
been advised that counsel have reached some understanding with
regard to a resolution of the economic issue of equitable
distribution, which is the only economic claim raised in the
action. The Master is going to allow counsel to put on the
record their understanding of what the parties have resolved as
far as the distribution of assets and the allocation of debt,
and also state on the record vhat the remaining issues are with
respect to certain items of property and how we may go about
trying to resolve those issues.
The Master also inquired of Mr. Adams if his client
would be willing to sign an affidavit of consent so that the
Master did not have to make findings on the claim of
indignities. The affidavit of consent by both parties would
expedite the proceedings and avoid the possibility of exceptions
to the Master's findings on the indignities issue. Mr. Houston.
HR. HOUSTON: The parties have reached an agreement
on the following items:
1. The Plaintiff, Vickie Mentzer, would receive, by way of
equitable distribution, her State Employees' Retirement
System pension benefits; a 1991 Cadillac, and any debt,
if there is any, associated with that vehicle; 1/2 of the
parties' 1996 tax refund, which I believe was $2,854.00
(total amount of check). She would receive from Mr.
Mentzer $15,000.00 in cash at such time as he refinances
the mortgage on the marital residence at 505 Shippensburg
Road, Newville, Pennsylvania.
The parties still have to come to an agreement as far as
the time period within which this refinancing is to be
accomplished, but the parties do have an understanding
that if a refinance is not feasible, that the house will
be listed for sale and that at such time as the property
is sold, Mrs. Mentzer would receive $15,000.00 in cash.
Wife would also assume a visa credit card obligation.
2. The agreement further is understood that the Defendant,
Gary Mentzer, would receive the marital residence with
the deed of conveyance from wife to be at such time as
the home is refinanced or at such time the house is sold,
the later of either of those dates.
He would also receive the 2-horse stall barn; a 1986
Chevrolet Suburban; and a Chevrolet Jimmy and any debt
associated with either of those vehicles; 1/2 of the 1996
tax refund; and a cabin located on Oak Drive in Newburg.
He would assume the liability on a Sears charge card.
There are some contingent liabilities for legal
services rendered by Bradley L. Griffie, Esquire, and for
a drywall supplier, Mr. Kuntz, which is a liability
associated with husband's business; he will assume the
liability for those two items. And as indicated
previously, he will refinance the mortgage to remove
wife's name from the obligation thereon.
3. What is left oustanding is the issue of distribution of
the household contents. The parties have had discussion
concerning distribution of those contents and wife had
provided a list of items she wanted from the house and it
is yet to be decided how those items are to be
distributed.
THE MASTER: Toward that end, we are going to ask
the parties and counsel to return on Wednesday, February 4,
1998, at 8:30 a.m. for a conference/hearing. If the parties are
prepared to offer testimony on the valuations and distribution,
we may consider taking that testimony at that time; however,
counsel and the parties are not bound to consider that time a
hearing date as such because we may simply only be able to use
that time to discuss the outstanding issues regarding the
household tangible personal property.
VICKIE A. MENTZER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97 - 565 CIVIL
vs.
.
.
GARY L. MENTZER,
Defendant
IN DIVORCE
NOTICE OF FILING MASTER'S REPORT
The report of the Master has been filed this date and
copies have been sent with this notice to counsel of record and
the parties.
In accordance with P.R.C.P. 1920.55 within ten (10) days
after the mailing of this notice and report exceptions may be
filed to the report by any party. If no exceptions are filed
within the ten (10) day period, the Court shall receive the
report, and if approved, shall enter a final decree in
accordance with the recommendations contained in the report.
[)ZLt~~
Date: 3/11/98
E. Robert EliCker, II
Divorce Master
NOTE: If exceptions are filed, file the original with the
Prothonotary and a copy with the Master's office. At
that time, the party filing the exceptions should notify
the court reporter in the Master's office so arrangements
can be made for a transcript. Upon completion of the
transcript and receipt of payment, the entire filed will
be returned to the Prothonotary's office for transmittal
to the Court at time of argument on the exceptions.
If no exceptions are filed, counsel shall prepare an
order of Court consistent with the recommendations and
provide a proposed order of Court to the Master.
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PROCEDURAL HISTORY
A divorce complaint was filed on February 4, 1997,
raising grounds for divorce of irretrievable breakdown of the
marriage and the economic claim of equitable distribution. The
additional ground for divorce of indignities was raised in an
amended complaint filed on May 19, 1997.
The Master was appointed on May 21, 1997, and because
husband would not sign an affidavit of consent for the divorce
to proceed under Section 3301(c) of the Domestic Relations Code,
the Master scheduled a hearing on indignities for September 23,
1997. That hearing went forward, and following the close of
testimony, the Master directed that pre-trial statements be
filed on October 24, 1997. A pre-hearing conference was then
set for January 23, 1998.
At the pre-hearing conference on January 23, 1998,
counsel appeared and after discussion, placed a memorandum of
understanding on the record with respect to various issues
raised in the case. The parties were not present at that time
and the memorandum was transcribed to allow everyone an
opportunity to review the content.
On February 4, 1998, at a conference/hearing, the parties
and counsel appeared at which time the parties affirmed the
memorandum of understanding that had previously been placed on
the record as their agreement with respect to resolution of the
various matters addressed therein. The only matter left open
for further review and decision was the matter involving the
disposition of certain items of tangible personal property of
the parties.
Testimony was presented by both parties with regard to a
list of items, which were prepared by the parties and have been
entered as an exhibit in the proceedings.
FOllowing the conclusion of the testimony, the parties
agreed to have the list of items appraised, after which the
Master was requested to file a report making his recommendations
as to which of the items were to be distributed to each of the
parties.
The Master received a final appraisal of all of the items
on the list (the original appraisal omitted the wall kerosene
bracket light) on March 9, 1998. The list consists of nine
items which were appraised and which the Master, after hearing
the testimony of the parties and looking at the appraisal, will
address in his report and make recommendations on the
distribution of the items.
The Master has not made any findings or recommendations
with regard to the testimony offered at the hearing on September
23, 1997, on the ground for divorce of indignities inasmuch as
both parties on February 4, 1998, signed affidavits of consent
and waivers of notice of intention to request entry of divorce
decree to permit the divorce to proceed under Section 3301(c) of
the Domestic Relations Code rather than proceeding under Section
2
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JJOl(a) (6).
CONCLUSION OF LAW
The counts for divorce raised in the action are
irretrievable breakdown of the marriage and indignities. The
Master did not need to consider the testimony offered on
indignities as an alternative ground inasmuch as both parties
have filed affidavits of consent and waivers of notice of
intention to request entry of divorce decree. Therefore, the
divorce can be concluded under Section 3301(c) of the Domestic
Relations Code.
DISCUSSION AND RECOMMENDATIONS
During the testimony, the parties arrived at an agreement
as to the disposition of two blue print comforters and lawn
ornaments at the marital residence. Testimony was offered on
the remaining nine items which are set forth on the appraisal
report of Dennis L. Gotshall, with Mr. Gotshall's opinion as to
value set forth after the item.
The parties testified that a number of items were
purchased while they were seeing each other prior to the
marriage and were then used by both parties in the marital home.
The items that were purchased prior to the marriage, husband
testified, were purchased with his funds.
Wife testified about certain items she used in the home
3
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for storage of her clothes and also specifically addressed the
oak sideboard which she testified belonged to her aunt and uncle
prior to the item being purchased. She indicated that the item
meant a lot to her since it belonged to members of her family
although husband disputed that there was any endearing
relationship between wife and the aunt and uncle.
Husband indicated that he has a collection of kerosene
lamps and that the lamp that was in dispute was one of the items
which he particularly liked as part of his collection.
Even though husband claims that wife did not have any
special relationship with the aunt and uncle from whom the oak
sideboard was PUrchased, the Master is going to respect wife'S
request and recommend that she receive that item which came from
her side of the family. The Master also considered that wife
indicated that she used the doughtray throughout the marriage
for her personal items. Also, she stated that she would like to
have the portable color television since she only has a 12 inch
portable television at the present time and could use another
television.
After reviewing the appraised values, the Master is
satisfied that upon wife's receipt of the three items referred
to above, she would have a fair distribution of value and items
which she could use and/or upon which she places a certain
sentimental value. The balance of the items the Master would
leave with husband and, in particular, the kerosene lamp, and
4
the other items of household furnishings, including the gas
gr ill.
Therefore, the Master recommends that the following items
of tangible personal property should become wife's sole and
separate property and that arrangements should be made for her
to remove said property from husband's residence within two (2)
weeks of a final order in these proceedings.
The items distributed to wife are as follows:
Footed doughtray with modern legs
Oak sideboard with mirrored back
Zenith portable color television with remote
The remaining items are to become the sole and separate
property of husband and are designated as follows:
Oak library table with drawer
White marble top stand
Oak washstand with modern towel rack
Oak chest of drawers with mirror and pine top
Sunbeam gas grill
Wall kerosene bracket lamp
Respectfully submitted,
rJ2.L~trtk~
E. Robert Elicker, II
Divorce Master
5
and waivers of notice of intention to request entry of divorce
decree signed and dated by both parties. The Master's office
will see that these documents are filed with the Prothonotary.
Therefore, the divorce will be able to be concluded under
Section 3301(c) of the Domestic Relations Code, and the Master
will not need to make any findings or recommendations with
respect to the grounds of indignities which were raised at a
hearing on September 23, 1997.
Mr. Houston, if you would make some statement on
the record with respect to this memorandum and then we will have
the parties sworn and we will have their affirmation on the
record as to what they have agreed to.
MR. HOUSTON: Included in the memorandum of
understanding was information that I had set forth at that time
concerning what counsel had understood as being the agreement of
the parties with respect to most of the items involved in this
case concerning issues of equitable distribution.
I have had an opportunity to review with Mrs.
Mentzer the memorandum of understanding for purposes of
confirming that. Indeed that is her agreement on the items that
are set forth in the memorandum of understanding, and she is in
a position today to confirm that on the record.
Whereupon,
VICKIE A MENTZER and GARY L. MENTZER,
having been called as witnesses, testified as follows:
BY MR. HOUSTON:
Q Mrs. Mentzer, would you state your name for the
record, please?
A Vickie Ann Mentzer.
Q And you are the Plaintiff in these proceedings?
A Yes.
Q Have you had an opportunity to review the
memorandum of understanding dated January 23, 1998, with me?
A Yes.
Q And it is your understanding that the agreement
that is set forth in that memorandum of understanding is, in
fact, the agreement that are you are in agreement with?
A Yes.
Q And that the only issue for the Master to determine
is, as forth in that memorandum, the distribution of certain
items of personal property?
A Yes.
(A discussion was held off the record.)
(Whereupon, Joint Exhibit No. 1 was
marked for identification.)
MR. HOUSTON: What we have before us is a joint
exhibit marked Exhibit No.1, which is a two-page document which
sets forth a list of items of personal property. Next to some
of the items there is an X which denotes that those are items
which the parties have agreed that Mrs. Mentzer shall receive
which are currently located at the marital residence. There are
certain items which are marked with an H which the parties have
agreed that Mr. Mentzer shall be retaining.
The items that do not have a mark next to them are
items which are still in dispute as far as distribution. It
should be noted that the item marked as a blue print comforter,
there will have to be testmony from the parties. Apparently
there may be an issue as to whether there are, in fact, more
than one blue print comforter, so there will have to be further
testimony as to that item.
So that's our understanding as to the items that
still need to be resolved.
THE MASTER: Mr. Adams.
BY MR. ADAMS:
Q Mr. Mentzer, have you had an opportunity to review
the memorandum of understanding this morning?
A Yes.
Q Do you confirm and agree with the distribution and
the facts set forth in that memorandum?
A Yes.
Q And you've also had an opportunity to review the
list that you just heard Mr. Houston testify to that's been
marked as an exhibit?
A Yes.
Q And you will agree that the distribution of those
items that are still in the home can be made according to the
list? As far as the items that are already marked, that those
items marked with an X are items that will go to your wife and
the items marked with an H are items that you will be retaining.
The items that are not marked are items still in dispute; that's
your understanding?
A That's correct.
THE MASTER: You also want to address the matter of
the financing on the record, please.
BY MR. ADAMS:
Q We also have spoken this morning concerning the
financing of the property that you are going to receive?
A Yes.
Q And as far as the monies that are listed in this
memorandum, that you would pay, for the transfer of that
property, to your wife, $15,000.00; is that money available to
you?
A That's correct.
Q And you also understand that part of the
responsibility would be to have the financing in your name only
when the property is placed in your name?
A Yes.
Q Have you made any arrangements to have that done?
A I've talked to Frank Koser at Orrstown Bank and he
told me -- now this is back some time ago -- that whoevers name
is on the home equity loan would have to be the same name as on
the deed.
Q And did he relate to you that he would give you a
loan in your name if you had the deed in your name?
A Yes. That's the understanding I had with him, yes.
I don't have anything in writing.
Q Are you intending after today to go forward and
attempt to have all of the financing placed in your name?
A I will, yes.
(A discussion was held off the record.)
BY MR. ADAMS:
Q It is also, Mr. Mentzer, your understanding that we
will, pursuant to this memorandum of understanding, immediately
seek to have your wife's name removed from the financing on the
property and that must be accomplished within a two month
period, or the language herein saying that the home will be
listed for sale, would come into play?
A I understand that.
Q So all the financing would have to be in place
within two months.
A I understand that.
MR. HOUSTON: April 4, 1998?
MR. ADAMS: Yes.
THE MASTER: Mr. Houston, you and your client are
agreeable to that two month period?
concerning appraisals of marital assets, if it appears at the Pre-
Trial Conference that there is a dispute as to any valuations of
marital assets.
(3) TESTIMONY OF OTHER PERSONS
None contemplated at this time, other than Plaintiff. Plaintiff
reserves the right to call others that may be identified as being
necessary at the Pre-Trial Conference.
(4) LIST OF EXHIBITS
A. Pension Appraisal
B. List of personal property (including marital and pre-marital)
C. Appraisal of property at 505 Shippensburg Road (to be
completed)
D. Appraisal of cabin and mountain land at Oak Road, Newville, PA
(to be completed)
(5) and (6) INCOME AND EXPENSE STATEMENT
Attached hereto is the Plaintiff's Income and Expense Statement.
(7) PENSION VALUATION
The Plaintiff has had her Pennsylvania State Employee's Retirement
System Pension appraised, a copy of which is attached, showing a
valuation for equitable distribution purposes of $55,775.37.
(8) COUNSEL FEES
N/A
(9) DISPUTED VALUATIONS OF
TANGIBLE PERSONAL PROPERTY
Plaintiff is not aware, at this point in time, as to any
dispute as to the identity of marital and non-marital assets or as
to any dispute as to valuation of any marital/non-marital assets.
Plaintiff is, however, having appraisals performed on the
marital residence and on a pre-marital recreation property owned by
Husband. It is submitted that the increase in value of that
recreational property is a marital asset. With respect to the two-
horse stall barn, Plaintiff's proposal, which would be more
particularly outlined below, will provide that this item be sold.
It is a movable piece of property.
With respect to the household furnishings, attached to this
Pre-Trial Statement is a list of personal property which the
Plaintiff wishes to receive from the residence. Upon receipt of
those items, Plaintiff will consider the distribution of household
belongings as complete without the need for any appraisals to be
performed.
Plaintiff will be proceeding with obtaining appraisals of the
marital property and the increase in value of the pre-marital
recreational property. Plaintiff seeks Defendant's cooperation in
sharing in the cost of these appraisals. If cooperation is not
obtained, then Plaintiff may seek to amend the Divorce Complaint so
as to add a request for costs.
(10) MARITAL DEBTS
INITIAL DATE
llID:1 AMOUNT DEBT INCURRED
1. Orrstown Bank 12/1/96 9/29/94
Mortgage on 78,375.41
Marital Residence 10/20/97
74,574.37
2. Sears Charge Card-H Approx. Revolving Charge
670.00
3. VISA Credit Card-w Approx. Revolving Charge
3,388.00
4. Griffie & Assocs.- Approx. Unknown
Contingent Liability 13,000.00
For Legal Fees for
Husband's Business
5. Kuntz - Drywall 14,000.00 Unknown
Supplier - Contingent
Liability from
Husband's Business
AMOUNTS/DATES
OF PAYMENTS
PURPOSE SINCE SEPARATION
1. Refinance of Mortgage Unknown
2. Charge Cards Unknown
3. Charge Cards Unknown
4. Legal Fees Associated
w/Husband's Business.
it is not known whether
in fact Mr. Griffie is
pursuing collection of
these fees.
Unknown
5. Contingent Liability
for Drywall Work
Supplied to Husband
for his Business. It
is not known whether
in fact this claim is
being pursued.
Unknown
AMOUNT OF
INITIAL DEB!'
80,000
Revolving
Charge
Revolving
Charge
Unknown
Unknown
EVIDENCE IN
SUPPORT OF
CLAIM
None
None
None
None
None
(11) PROPOSED RESOLUTION OP ECONOMIC ISSUES
A. Equitable Diatribution - Wife is seeking a 50/50 equitable
distribution of marital property. Wife wishes to retain her
pension, the 1991 Cadillac, and receive the items of household
furnishings, as set forth on the attached list. Wife will also
assume the VISA credit card balance.
Wife proposes that Husband would retain the marital residence,
the 1986 Chevrolet Suburban, and 1986 Jimmy. Husband would
refinance the mortgage on the marital residence and assume the
Sears credit card, and any contingent liabilities for Mr. Griffie
and Mr. Kuntz.
Based on appraisals for the marital residence and marital
value portion of the recreation property, it is anticipated that
there will be due and owing a cash payment to Wife. In the event
that Husband cannot refinance the loan on the marital residence,
Wife proposes that the marital residence would be sold and that
distribution of the net sales proceeds would be made so as to
accomplish a 50/50 distribution of all marital assets, including
the net sales proceeds.
In addition, with respect to the two-horse stall barn, Wife
would propose that this item be sold and the net sales proceeds
divided equally between the parties and that the value of this item
not be included in the valuation of other marital assets so as to
simplify a distribution of the net sale proceeds of this asset.
INCOME AND EXPENSE STATEMENT OF
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DR'
DATE
THIS STATEMENT MUST BE FILLED OUT
(If you are self-employed or if you are salaried by a business of
which you are owner in whole or in part, you must also fill out
the Supplemental Income Statement which appears on the last page
of this Income and Expense Statement.
INCOME
(a) Wages/Salary
Employer & AddressPA Fish & Boat Commission 1704 Pine Road, Newville, PA 172'
Job Title/Description Clerk Tvoist III
Pay Period (weekly, bi-weekly, monthly) Bi-week1v
Gross Pay per Pay Period...........................$ 1251.00
Payroll Deductions:
Federal Withholding....$ 186.69
Social Security........$ 77.56
Local Wage Tax.........$ 12.51
State Income Tax.......$ 35.03
Retirement.............$ 62.55
Health Insurance.......$
Other (specify)........$ 12.51
Soc.Sec/Med Tx . . . . . . . . $ 18.14
Credit Union . . . ., . . . $ 225.00
Net Pay per Pay Period.............................$ 621.01
(b) Other Income Week Month Year
Interest/Dividends.......$ $ $
Pension/Annuity..........$ $ $
Social Secur i ty. . . . . . . . . . $ $ $
Rents/Royalties..........$ $ $
Expense Account. . . . . . . . . . $ $ $
Gifts. . . . . . . . . . . . . . . . . . . . $ $ $
Unemployment Compensation$ $ $
Workmen's Compensation...$ $ $
Total, Other Income. . . . . . . . . . . $ $ $
I verify that the statements in the foregoing pleading are
true and correct. I understand that false statements herein
are made subject to the penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
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Gamge at house - Fountain w/motor
Upright freezer
Ice Cream Freezer
Gas Grill w/side burner, propane tank
Lawn ornnaments
Back gamge area - Push mower-red w/snfety bar
Wood glider - 2 seat (On patio) w/cushions
Patio set - glass table lop - Chairs/Chaises w/cushions
Snow blower - walk behind
All personal items belonging to Joey and myself - 10YS -trucks - wagon - bicycles
bowling ball - luggage and all other personal belongings.
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