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negotiations the parties have reached an agreement with
respect to all of the outstanding economic claims. The
agreement is going to be placed on the record in the
presence of the parties. The agreement as placed on the
record will be considered the substantive agreement of the
parties not subject to any changes or modifications except
for correction of typographical errors which may be made
during the transcription. It is understood, however, that
the parties are going to have counsel use the agreement as
placed on the record today as the basis for preparing a
more formal agreement with additional language which will
not, however, change the substantive effects of the
agreement that we are entering into the record today. The
Master has been advised that he will be provided a signed
copy of the formalized agreement prepared by counsel;
however, if the Master does not receive a signed agreement
by both parties within thirty (30) days of today's date,
the Master is authorized to present to the Court the
document which is the transcript of today's proceedings as
the agreement of the parties which will be sufficient to
allow the Court to proceed to enter a final decree in
divorce and to resolve all of the economic claims in the
proceedings.
If the Master does receive the signed
agreement within thirty (30) days, he will prepare an order
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5. Husband shall retain ownership of the office building
located at 49 Brookwood Avenue, Carlisle, Pennsylvania,
subject to the following conditions:
(a) husband shall execute documents necessary to
modify the existing mortgage in favor of wife in the amount
of $250,000.00 up to a balance of a total of $307,000.00
with 5% interest to be additionally collateralized by the
holding of a deed by wife to be recorded based on certain
conditions set forth in this paragraph. In addition,
husband will provide a new note in the amount of
$307,000.00 providing wife with adequate security for the
balance due to her under the mortgage.
The deed to be held as collateral by counsel for wife
shall be recorded in the event of anyone of the following
events:
(a) Husband providing wife with six (6) months
notice of his intent to close his medical practice in that
building. During the six (6) months notice period, husband
shall be responsible for the payment of the mortgage and
all expenses relating to the property through and including
the six (6) months.
(b) In the event that husband closes his practice
due to an emergency, he will provide ninety (90) days
rather than six (6) months notice of said emergency. The
purpose of the emergency notice would be in the event that
husband is unable to continue in the practice of medicine
on an ongoing and continuing basis.
(c) Six (6) months notice by wife of her intent to
request that the building be sold. Husband shall continue
to be responsible, as previously stated, for the mortgage
payments and all expenses relating to the said building for
the six (6) months period.
(d) An institution of an action in foreclosure by the
first mortgage holder Orrstown Bank.
(e) Husband becomes thirty (30) days delinquent on
the payment of his first mortgage. Husband agrees that he
will sign a release prepared by counsel for wife permitting
her to check on the status of the mortgage payments with
Orrstown Bank.
In the event of death of husband, should wife be
able, she will have a right to record the deed previously
referred to collateralizing the financial obligation on the
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mortgage. In any event, death terminates husband's
continuing obligation to pay the mortgage and at that point
permits wife and the first mortgage holder to take steps to
sell the building securing payment of their mortgage
payments if applicable.
Reference under this paragraph to payment of the
mortgage refers to the payment of the first mortgage only
since the second mortgage provided herein does not require
continuing payments thereunder.
In the event the office building is sold and the
balance due to wife under her mortgage, including interest
is paid in full, any remaining proceeds shall be the
property of husband.
MR. HOWETT:
By way of example, if the property were to sell
for one million dollars and the first mortgage was
$500,000.00 and the second mortgage to Denise Hough was
$300,000.00, then the remaining $200,000.00 would belong to
Dr. Hough.
MR. CONNELLY:
Husband will continue to maintain any property
and causality insurance on the building and shall name wife
as additional insured thereunder after the first mortgage
holder Orrstown Bank.
6. Wife shall be entitled to access to th~ building with
reasonable notice for the purposes of inspection and a
review with a commercial realtor whether or not in
anticipation of sale.
7. Husband shall retain ownership of the proceeds from
the sale of the Piper Aztec airplane.
8. Husband shall retain his ownership interest in a
hunting cabin in Jefferson County, Pennsylvania.
9. Husband is presently the owner of a life insurance
policy with State Farm Insurance having a gross death
benefit of $105,581.52 and after policy loan a current net
death benefit of $58,174.08. Husband agrees that he will
continue to pay timely the policy loan and will designate
wife as irrevocable beneficiary on the policy. Husband
cannot cancel the said policy or further borrow against it.
He will cause to have the State Farm Insurance to receive a
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notice that they will issue duplicate premium default
notices and will further confirm the irrevocable
designation of the beneficiary. In addition, wife shall
provide the company with a portion of the property
settlement agreement necessary to put the company on notice
of the terms and conditions of this paragraph.
10. Husband agrees to pay to wife in the form of alimony
the sum of $500.00 per month until the month following his
65th birthday, March 2009. This amount shall not be
modified as to duration or amount and shall only terminate
in the event of the death of either party. The payment
shall not be includable as income to wife nor deductible to
husband. As far as the $500.00 alimony payments, the
current alimony pendente lite payments being made are being
made at a rate of $500.00 per month. Those payments will
convert to alimony upon the granting of the decree in
divorce and will continue per the terms of the agreement.
The alimony payments will continue through the Court of
Common Pleas of Cumberland County, Pennsylvania, Domestic
Relations division as have the continuing alimony pendente
lite payments.
11. In the event that there is any recovery from Clark
Dunkle for any acts of malpractice relating to the medical
practice, or restitution in the event criminal charges are
filed based on any thefts from the practice, wife shall
receive 50% of any recovery thereunder within ten (10) days
of receipt by husband. Husband agrees that in the event
any action is taken by him against Mr. Dunkle or husband
receives any information related to any restitution, he
will provide wife with a status update.
12. The parties acknowledge that the only marital debt is
an MBNA credit card for which husband has assumed
responsibility and indemnifies and holds wife harmless on
the said debt.
13. Except as specifically provided in the agreement each
parties waives any all claims under the divorce code for
counsel fees, costs, expenses, alimony, alimony pendente
lite, and equitable distribution of marital property.
Whereupon, RODNEY K. HOUGH, having been duly
sworn, testified as follows:
BY MR. CONNELLY:
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Q Dr. Hough, you've heard the summary of the
agreement that I put on the record today?
A Yes.
Q And to your knowledge have we covered all of
the assets of the marriage?
A Yes.
Q As far as life insurance is concerned, is
the only life insurance policy you have with State Farm
what we referred to today?
A To the best of my knowledge, yes.
Q Did you have prior life insurance policies
that are no longer in existence?
A I had some term for a while.
Q And who were they with, do you recall?
A No.
Q Do you recall having policies with Mutual
Life?
A I don't recall that.
Q Protective Life?
A No.
Q Fidelity?
A No.
Q And, of course, State Farm that you have
acknowledged?
A The only one that I am aware of is State
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event that the second mortgage does not secure the entire
balance due to wife. We have agreed that in the event that
wife pursues a deficiency judgment over and above the
second mortgage in this matter in which case the second
mortgage did not satisfy the obligation due to her,
excluded from any deficiency judgment action, shall be any
inheritance received by husband subsequent to today's date.
It will be husband's burden to clearly segregate said
inheritance in order for it to be clearly identified as
excluded from any future action pursuing deficiency
judgment against him.
Husband further has agreed that he will
designate his three children as sole beneficiaries of his
estate. Also excluded from any deficiency judgment would
be the cabin previously referred to which will be either
left to his children or another family member as designated
by husband.
MR. HOWETT: Now, I just want to add a
clarification statement here on this deficiency judgment
that anything that Rod not only inherits after this but is
gifted, for example, if his mother or brother or somebody
would do a pre-death planning gifted scheme, anything that
would either be gifted to him or inherited by him is
excluded from this deficiency judgment; that is Rod's to
keep and it is his burden to trace it.
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(A discussion was held off the record.)
MR. CONNELLY: Wife also agrees that she
will name her three children as beneficiaries of her estate
at the time of her death.
(A discussion was held off the record.)
MR. CONNELLY: Denise, you've heard the
placing on the record of the agre~ment today?
MS. HOUGH: Yes, I have.
MR. CONNELLY: And have we had sufficient
time in your judgment over the last several days, including
phone calls, office meetings, and meeting today to satisfy
you that we have reviewed all of the assets here?
MS. HOUGH: Yes, we have.
MR. CONNELLY: And do you understand the
deal as it was placed on the record by me subject to
certain qualifications made by Mr. Howett?
MS. HOUGH: Yes, I do.
MR. CONNELLY: Are you under the influence
of any drugs, alcohol or any other substances that would
render you incapable of making a rational decision?
MS. HOUGH: No, I am not.
MR. CONNELLY: And do you agree that this is
the understanding and agreement reached by us?
MS. HOUGH: I do understand that.
MR. CONNELLY: Do you also understand that
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DENISE J. HOUGH,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
,
"
vs.
CIVIL ACTION - LAW
NO. 97. ~41 CIVIL TERM
IN DIVORCE
RODNEY K. HOUGH,
Defendant
,;
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims set forth in the
foregoing 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 in 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:
Office of the Prothonotary
Cumberland County Court House
Carlisle. Pennsylvania 17013
'i IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S
;: FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE
, THE RIGHT TO CLAIM ANY OF THEM.
"
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, 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
!i BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
I:
,
II Court Administrator, Fourth Floor
TRtJe COpy FROM RECORD Cumberland County. Court House
In Testllhon whereof' here unto set my hand Carlisle. Pennsylvania 17013
and t '~ Y 01 at Isle, Pa. Telephone: (717) 240-6200
fhl ' e 111 r7
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,1 DENISE J. HOUGH, I IN THE COURT OF COMMON
" Plaintiff ) PLEAS OF CUMBERLAND COUNTY,
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I, ) PENNSYLVANIA
"
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" vs. I CIVIL ACTION - LAW
i: I
) NO. 97- CIVIL TERM
i: RODNEY K. HOUGH, )
i! Defendant ) IN DIVORCE
"
NOTICE OF AVAILABILITY OF COUNSELING
; TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed in
, the Court of Common Pleas of Cumberland County. This notice is to advise you that in
accordance with Section 3302(d) of the Divorce Code, you may request that the court
, require you and your spouse to attend marriage counseling prior to a divorce being handed
" down by the court. A list of professional marriage counselors is available at the Domestic
1, Relations Office. 13 North Hanover Street. Carlisle. Pennsylvania. You are advised that this
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~; list is kept as a convenience to you and you are not bound to choose a counselor from this
, list. All necessary arrangements and the cost of counseling sessions are to be borne by you
,
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:, and your spouse.
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:i If you desire to pursue counseling, you must make your request for counseling within
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~i twenty days of the date on which you receive this notice. Failure to do so will constitute a
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II waiver 0 your fig t to request counse Ing.
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DENISE J. HOUGH, I IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND COUNTY,
, I PENNSYLVANIA
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!i V5. ) CIVIL ACTION. LAW
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,
, ) NO. 97. CIVIL TERM
RODNEY K. HOUGH, I
, Defendant ) IN DI'JORCE
,
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COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff. DENISE J. HOUGH, by her attorney,
, Samuel L. Andes. and makes the following Complaint in Divorce:
1. The Plaintiff is DENISE J. HOUGH, an adult individual who currently resides at
, 1215 Sadler Drive. Carlisle. Cumberland County, Pennsylvania.
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2. The Defendant is RODNEY K. HOUGH, an adult individual who currently resides at
, 1215 Sadler Drive. Carlisle, Cumberland County, Pennsylvania.
3. Both the Plaintiff and Defendant have been bona fide residents of the Common-
'. wealth of Pennsylvania for at least six months immediately previous to the filing of this
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:; 4. The Plaintiff and Defendant were married on 23 July 1971 in Pittsburgh.
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5. There have been no prior actions of divorce or annulment between the parties.
6. This marriage is irretrievably broken.
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17. Defendant enjoys a substantial income and is well able to bear the expense of
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,I Plaintiff's attorney and the expenses of this litigation.
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WHEREFORE. Plaintiff prays this Honorable Court to order Defendant to pay the legal
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,; fees and expenses incurred by Plaintiff in the litigation of this action.
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I verify that the statements made in this Complaint are true and correct. I understand
that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904
, (unsworn falsification to authorities).
, DATE:
d./6)q7
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N~ 1\'/'V
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DENISE J. HOU
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A ttorney for Plaintiff
Supreme Court ID 17225
525 North 12th Street
Lemoyne. PA 17043
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DENISE 1. HOUGH, ) IN THE COURT OF COMMON "
Plaintiff ) PLEAS OF CUMBERLAND COUNTY,
) PENNSYLVANIA
)
vs. ) CIVIL ACTION - LAW
)
RODNEY K. HOUGH, ) NO, 97-649 CIVIL TERM
Defendant )
) IN DIVORCE
ACCEPTANCE of SERVICE
The undersigned John C. Howell, Jr., Esquire, hereby enters his appearance on behalf of the Defendant,
. Rodney K. Hough, and hereby accepts service of the Divorce Complaint on behalf of the said Defendant and
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acknowledges receipt of a certified copy of the said Complaint.
Date
<Y/li/17
Jo . Howell, Jr.
Allomey for Defendant
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
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CIVIL ACTION - LAW
NO. ~11(P11 CIVIL 19
IN DIVORCE
"
STATUS SHEET
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ACTIVITIES:
DENISE J. HOUGH,
Plaintiff
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
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vs.
NO. 97 - 649 CIVIL
RODNEY K. HOUGH,
Defendant
IN DIVORCE
TO: Samuel L. Andes
Attorney for Plaintiff
John C. Howett, Jr., Attorney for Defendant
DATE: Thursday, July 6, 2000
CERTI FICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a)
Outline what information is reqllired
complete in order to prepare th
and indicate whether there are
interrogatories or discovery mo
that is not
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7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff
may have the right to request that the Court require the parties to participate in counseling.
COUNT I
8. The Plaintiff requests this Court to enter a Decree of Divorce.
WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to the
Divorce Code of Pennsylvania.
COUNT II . EQUITABLE DISTRIBUTION
9. During the course of the marriage, the parties have acquired numerous items of
property, both real and personal, which are held in joint names and in the individual names of
each of the parties hereto.
WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the
Defendant, to equitably divide the property, both real and personal, owned by the parties
hereto as marital property.
COUNT III . ALIMONY
10. Plaintiff lacks sufficient property to provide for her reasonable needs in
accordance with the standard of living of the parties established during the marriage.
11. Plaintiff is unable to support herself in accordance with the standard of living of
the parties established during the marriage through appropriate employment.
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12. The Defendant is employed and enjoys a substantial income from which he is
able to contribute to the support and maintenance of Plaintiff and to pay her alimony in
accordance with the Divorce Code of Pennsylvania.
WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding Plaintiff
from Defendant permanent alimony in such sums as are reasonable and adequate to support
and maintain Plaintiff in the station of life to which she has become accustomed during the
marriage.
COUNT IV - ALIMONY PENDENTE LITE
13. Plaintiff is without sufficient income to support and maintain herself during the
pendency of this action.
14. Defendant enjoys a substantial income and is well able to contribute to the
support and maintenance of Plaintiff during the course of this action.
WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her
reasonable alimony pendente lite during the pendency of this action.
COUNT V - COUNSEL FEES AND EXPENSES
15. Plaintiff is without sufficient funds to retain counsel to represent her in this
matter.
16. Without competent counsel, Plaintiff cannot adequately prosecute her claims
against Defendant and cannot adequately litigate her rights in this matter.
5
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DENISE 1. HOUGH, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND COUNTY,
) PENNSYLVANIA
)
vs. ) CIVIL ACTION - LAW
)
RODNEY K. HOUGH, ) NO. 97.649 CIVIL TERM
Defendant )
) IN DIVORCE
ACCEPTANCE of SERVICE
The undersigned John C. Howell, Jr" Esquire, hereby enters his appearance on behalf of the Defendant,
Rodney K. Hough, and hereby accepts service of the Divorce Complaint on behalf of the said Defendant and
acknowledges receipt of a certified copy of the said Complaint.
Date
0.-/ I ~fq7
Joh ,Howell, Jr,
AlIorney for Defendant
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Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DENISE J. HOUGH
VS.
NO.
IN ?lIVBi?CE
CIVIl.
19
RODNEY K. I'IOUGH
Defendant
STATllS SIIEET
DATE:
ACTIVITIES:
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DENISE J. HOUGH,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 97 - 649 CIVIL
RODNEY K. HOUGH,
Defendant
IN DIVORCE
TO: John J. Connelly, Jr.
Attorney for Plaintiff
John C. Howett, Jr.
Attorney for Defendant
DATE: Tuesday, June 26/ 2001
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
t
r.
I.W,O'"('1~UI
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1I0WETT. KISSINGER & CONLEY, I).C.
I)!) W,ILNIIT STREET
I~)ST OFFICE BOX Kill
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JOliN (' IIOWElT. JR,
llONAI.1l T, KISSINGER
CINDY S CONLEY
DARREN J 1I0LST
,~
DEDR,I M SIIIMI'
I.c)!aIAv.i..lanl
October 15, 2002
(117) 234.2616
FAX (717) 234.5402
VIA FAX & MAIL (240-6248)
E. Robert Elicker, II, Esquire
Office of Divorce Master
9 North Hanover Street
Carlisle, PA 17013
Re: Hough I'. Hough
No, 97-649 Civil / Divorce
Dear Bob:
At the conclusion of the July 26, 2002 pre-trial conference, you requested
that counsel provide you with a letter by October 15, 2002 as to the issues
remaining to be tried in this case. Unfortunately, opposing counsel, John J.
Connelly, Esquire, and myself have not had an opportunity to speak conceming
settlement of this case. However, based upon previous conversations, I remain
optimistic that in the end the case will settle. However, in the event that the case
docs not settle, it is my understanding that all issues raised in the divorce, along
with the support issues described in my pre-trial statement are to be heard by you
at the October 29, 2002 master's hearing.
Thank you for your continued assistance in this matter.
Sine 'e1y,
~l
JCH/dld
ce: John J. Connelly, Esquire
Rodney K. Hough
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JO/lN C. /I0WElI. JR,
IX1NAI.ll r. KISSINGER
CINIlY S,CONI.EY
IMRREN J, /I0l.ST
(717)234.2616
FAX (717)234.5402
IlEIlMA M, SlUMP
tepl AlSislarll
July 13. 2001
E. Robert Elicker. II, Esquire
Office of Divorce Mastcr
9 North Hanovcr Strcct
Carlislc, P A 17013
Rc: /lOll!!" 1'. /lOll!!"
Dcar Mr. Elickcr:
I am in rcccipt of a Icllcr from Johll Connclly which providcd mc a copy
ofthc "Discovcry Ccrtification" filcd by him with which I am in agrcemcnt. My
ccrtification so noting is cncloscd.
Sinccrcly,
~--
John C. HowCll. Jr.
JCH/dms
Enclowrc
cc: John J. Connclly. Jr., Esquirc (w/cncl)
Rodncy K. Hough. M.D. (w/cncl)
l\\lI~S\lIII1Dt 1<~1,,&Cll'''111\ lit'
Juhn J ('tlnndl)'. Jr
JJqrll/J\llk~al'lllll
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July 11,200\
"
E. Robcrt Elickcr, III, Esquirc
Cumbcrland County Divorcc Mastcr
9 North Hanovcr Strcct
Carlislc, PA \7013
Rc: Hough v. Hough
No. 97 - 649 Civil Tcnn
Dcar Mr. Elickcr:
Encloscd you willlind thc signcd Discovcry Ccrtilication in thc abovc-rcfcrcnccd
mallcr.
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JOliN l'. IIUWFI'J'. JR,
IXlNAI.Il r. KISSING/;R
CINDY S, CONU:Y
DARREN J, IIUI.5T
DOWElT, KISSINGER & CONLEY, P.C.
110 WALNUT STREET
POST OffiCE BOX 810
H.uaJSlUJo, ~snvA"'IA 17108
(717) 234.2616
fAX (717) 2)4.'402
DFIlRA M, SlUMP
I.tpl Assistanl
Scptcmber 7. 200 I
E. Robcrt Elickcr. II, Divorcc Mastcr
Cumbcrland County Court of Common Picas
9 North Hanovcr Strcct
Carlislc, PA 17013
Re: /Iollgh v, /Iollgh
No. 97-649 CIVIL/IN DIVORCE
DcaI' Mr. Elickcr:
Encloscd plcase find Dcfcndant's Prctrial Statcmcnt Pursuant to Pa. R.C.P.
1 920.33(b) which I have forwardcd to the Cumberland County Prothonolary for
filing on this datc. Thank you for your continucd assistancc in Ihis malleI'.
Sincerelyll ,. 0 )
'---- -)!2 e,;~<../jJ 0\
John C. Howcll, Jr.
JCH/djk
Enclosurc
cc: John J. Connclly, Jr., Esquirc (w/encl)
Rodney K. Hough, M.D. (w/cncl)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DENISE J. HOUGH,
Plainliff
v.
)
)
)
)
)
)
)
CIVIL ACT/ON. LA W
DIVORCE
NO. <)7.649
RODNEY K. HOUGH,
Defendant
DEFENDANT'S PRETIUAI, STATEMENT 1'l1RSl1ANT TO l'o.ltC.l'. 1920.331bl
I. ASSETS.
A. MARITAL ASSETS
# ASSET VALVE DATE OF ANY LIENS OR
VALVA TfON PORTION ENCUMBRANCES
NON-
MARITAL
I Proceeds of Sale of 515.000 7/5/00 No No
1215 Sadler Drive (ad,'anced to W
(fonner Marilal 522,130,22 (in
Residence) escrow)
2 Office Building $524.400 FMV Currelll No Y cs, mortgage
49 Brookwood Ave. 5437.393 (mon)
Carlisle, PA $ 87.007
3 1/6 ownership ill!eresl 55.000 Currell! No No
in Hunting Cabin
Jefferson Coull!y
4 1/5 ownership interest Approx. 513.000 Currell! No No
in 1974 Piper Aztec of which $6.000
Airplane sales proceeds was used 10
repair Ihc
Corvelle and the
remainder used
10 purchase 2
computers for
sons
5 Increase in value in H's $4.000 3/96 dale of Yes No
1969 Corvette separation
II ASSET VAWE DATE OF ANY LIENS OR
VALUATION PORTION ENCUMBRANCES
NON.
MARITAL
6 1991 Isuzu Trooper SO . proceeds
proceeds used 10 purchase
vehicle for
Manhew and
bike for Eric
7 1992 Chevy Truck SO N/A Nol included in No
used by parties' marilal eslale
son Adam
8 1994 Jeep Cherokee S N/A Nol included in Yes, H pays
used by parties' marilal eslale
son Eric
9 1985 Dodge Ram Van SO N/A No No
became
inoperable afler
separation
10 H's 401(K) Plan $264,137.09 9/4/01 No No
II John Alden Fixed S35,890.00 12/97 No No
Annuity
12 Weinken & Assoc. $60.500.00 1998 No. bUI nol to No
InveSlment Funds (Wife has had be included in
sole use of lhis martial estate
fund so Husband beeause used
is unaware of for education of
current slalus) children
13 H's Medicall'raclice No value Currenl No Yes
14 Wife's Jewelry Appraisal N/A No No
Needed
15 Personal Property Appraisal N/A No No
Needed
16 Life Insurance S6,369,00 1/19/99 No Yes, outstanding
Joan
B. NON.MARITAL ASSETS
u ASSET V AI.UE DATE OF LIENS OR ENCUMBRANCES
V AUJATlON
II's Gun Colleclion $3,000,00 Cnrrenl No
2 II's 1969 Corvelle $7,000,00 N/A No
3 lI's I'ost Separalion To be provided N/A No
conlribulions 10 401(K)
plan
4 lI's 1994 Ford Taurus To be provided N/A No
II. WITNESSES.
A. Expert Wilnesses. (fnecessary Husband will present the testimony ofa business
evaluator to rebut Wife's evaluation of his medical practice. Moreover, it may be necessary for Husband
to present the testimony of a pcrsonal property/jewelry appraiser.
B. Non.Exnert Witnesses. Other than the partics themselves, Husband docs not anticipate
calling any non-cxpert witncsscs. However, Husband reserves the right to call unidentified rebuttal
witnesses.
III. EXHIBITS.
I. Marital Residence Settlement Documents
2. 7/5/00 Escrow Account Statement
3. Current Escrow Account Statement
4. Mortgage Statcment re: 49 Brookwood Avenue
5. Paragraph 6 of Jefferson County Cabin Partnership Agreement
6. Statement evidencing amount owed on 1994 Jeep
7. Statement of 401(K) balance
8. Current Statement for John Alden Fixed Annuity
9. Current Statement for Weinken & Assoc Investment Funds
10. Current Statement of Life Insurance value
II. Documents evidencing any post separation contributions to 40 I (K) plan
12. Business Evaluation Report, if necessary
13. Personal Property/Jewelry Appraisal, ifnecessary
14. Tax Returns for 1995 to 2000
IS. Documents evidencing expense paid by Husband since separation toward Wife
and children's expenses
16. Documents evidencing Husband's entitlement to reimbursement from educational
fund for expenses he paid toward children's education.
17. Omce building refinancing documents.
18. Documents evidencing transfer of 40 I (K) plan to OrrstoWll Bank.
19. Documents evidencing withdraws from 401(K) plan and use of proceeds.
Husband reserves the right to introduce unidentified rebuttal exhibits.
IV. DEFENDANT'S GROSS INCOME.
Scc Tax Rcturns
V. DEFENDANT'S EXPENSES.
Dcfcndant's Expcnsc Statcmcnt will bc provided prior to trial.
VI. RETIREMENT BENEFITS.
Sce Marital Asscts Chart.
VII. COllNSEL FEES.
Dcfcndant has not raised a claim for counsel fces.
VIII. PERSONAL PROPERTY DlSPllTE.
Scc Marital Asscts Chart.
IX. MARITAL DEBT..
AMOUNT
AND EVIDENCE
INITIAL DATES OF OFFERED
AMOUNT DEBT AS DATE DEBT AMOUNT PURPOSE PYMT. IN
DEBT OF DEBT OF D,O,S. INCURRED OF DEBT OF DEBT SINCE SUPPORT
D,O,S. OF CLAIM
Mongagc: S437.393 To be When To be Mortgage To be Statements
associ:ucd as or Bill I provided bUilding provided prov,ded
with office purchased
building
loan against Approx, Approx. When Approx, To buy To be Statements
Life S2ll.llllll S21.llll0 airplane S24.llllll airplane provided
Insurance interest interest
purchased
Business Approx, To be During To be Business Paid when Statements
Line or S25,000 provided marriage provided office
Credil building
refinanced
Business Approx, To be During To be Business Paid when Statements
Working S49.00ll provided marriage provided office
Capilal buildlOg
Loan refinanced
.Significant crcdit card and othcr dcbt existcd as ofthc datc ofscparation and was paid from the
proeccds of thc post-scparation salc of thc marital residcnec and post-scparation withdraws from
Husband's 401(K) plan pcr thc agrccmcntofthc partics. Those dcbts havc not bccn sct forth abovc.
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April 9. 2002
E. Robcrt Elickcr, III, Esquirc
Cumbcrland County Divorcc Mastcr
9 North Hanovcr Strcct
Carlislc. PA 17013
Rc: Hough v. Hough
Dcar Mr. Elickcr:
It is my undcrstanding that Dr. Hough has now rctumcd to his practicc in Carli sic
and wc arc rcqucsting that you rcschcdulc thc sclllcmcnt confcrcncc as soon as possiblc.
I trust your officc will bc in touch with Mr. Howcll and mysclfto schcdulc thc mallcr.
Thank you in advancc for your allcntionto this rcqucst.
JJC:jlk
cc: John C. HOWCll, Jr., Esquirc
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DENISE J. HOUGH,
Plaintiff
SEP 1 0 200~
: IN TIlE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97 - 649 CIVIl. TERM
RODNEY K. HOUGII,
Defendnnt
: CIVIl. ACTION - LAW
: IN DIVORCE
PLAINTIFF'S PRE-TRIAL STATEMENT
Date of Marriage:
Date of Separation:
Divorce Complaint filing date:
July 23, 1971
February, 1997
February 10, 1997
I. ASSETS
A. Marital Property
Aml:I
Value/Date of Valuation
Non-Marital
Portion
LIwL
Encumhroncrs
I. 49 Brookwood A venuc, $530,000,00 as of 1999 - No Mortgagc balance
Carlislc, Pcnnsylvania - Nccds to bc updatcd 1999
location of Husband's medical approximatcly
practicc $325,000.00 with
OITstown Bank -
Nccds to be
updatcd
2. Procccds from salc of $37,000.00 - Approximatcly No Nonc
marital rcsidcncc, 1215 Sadlcr $22,000.00 hcld in cscrow by
Drivc, Carlislc, Pcnnsylvania, Thomas O. Williams, Esquirc
$15,000.00 advanccd to Wifc
3, Hunting Cabin Approximatcly $5,000.00 - No Nonc
CUITcnt valuc to be
dctcnnincd
5. Various Motor Vchiclcs To Bc Dctcnnincd No Nonc
including 1992 Chcvrolct
Truck, 1994 Jccp Cherokcc,
1991 Isuzu Troopcr
Am1a ValuelDate oe Valuation Non-Marital Llwl
Portion Encumbrances
5. Cessna Airplane Sold - Estimated proceeds No None
$15,000.00
6. Life Insurance Cash Value Approximately No None
$6,300.00
7. Husband's Medical Approximate Value 1999 No None
Practice Pension Plan $695,000.00 - Needs to be
Updated
8. Husband's Medical Value to Be Determined No Business Loan
Practice including Medical with Orrstown
and Omee Equipment, Bank -Balance to
Accounts Receivable and Be Determined
Goodwill
9. Personal Property of the Value to Be Determined Husband alleges a None
Parties including Jewelry and portion of his gun
Gun Collection collection is non.
marital
10. John Alden Investment $36,000.00 - 1999 Value No None
II. 1969 Corvette -Increase Value to Be Determined Yes None
in value of non-marital
property
B. Non-marital Property
Aum
ValuelDate oeValuatlon
Lien!lEneumbranecs
I. A portion of Husband's
Gun Collection
Value to Be Determined
None
2 1969 Corvette -Increase in
value of non-marital property
Value To Be Determined
None
YERIFICATION
I verify that the statements made in this 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.
Date: 09- 0 1- OJ
JJ"';~.""h
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MONTHLY YEARLY
(Fill in appropriate column)
Employment
Public Transportation $ 75.00 $ 900.00
Lunch $ 100.00 $ 1,200.00
Taxes
Real Estate
Personal Property
Income
Insurance
Homeowners $ 16.67 $ 200.04
Automobile $ 55.00 $ 660.00
Life
Accident
Health
Other
Automobile
Payments $ 357.05 $ 4,284.60
Fuel $ 30.00 $ 360.00
Repairs
Medical
Doctor
Dentist $ 16.67 $ 200.04
Orthodontist
Hospital
Medicine $ 20.83 $ 249.96
Special Needs (glasses,contacts, $ 25.00 $ 300.00
braces, orthopedic devices)
c".,. ~omtf adoresti 'I"',umbc' D~d ~;l"~tsl). 1f you "'lave tl P 0 be". !fOO page 1 S.
.i.. 310BA RUSSE~~ RDA::>
JlIUIe C:t'J, tow'" or cost offjce
ptlMe. I
'/0' AL:XAf;::>R'A VA 22305
P,uldlnllll ... NOTE, C~ecktrg "Yes" Wi:1 ~Ol change you' lax 0' reduce your re(urd,
511,1I0n ClmPII;n" ::>0 you, or your SPOU,f ,i' filln.; a joi~t r8lurn, wOnt 53 to ;0 to this (und'
1 ' Single
-..,
2 !...-...1 Me'ned filing JOlr: ralum (aver It only ore had inco",a)
3' r Mamac filing lop.rale rahir" Enler spaUR', SSN at:ove .and fut' "Imu I'1ere, .,.
4 Xi Haac of nousanolc (Wlln oua"fylr'5 person), (Sae page 19) I~ Ihe qualifying person 19 a chile but rot your
I
C^eck only ceper,denl, enler !hle ch:ld's ram. here, ~ SSN'
-
Dno bo< 5 I I aualll'l,no w:dpw(er) With deper,denl Ch.ld (voor spouse diad ~ ISoe pace 19,)
68 I]]YoUrulI. I' your parenl (or someone else) car clai." YOu a9 a ceperde",:
Exemptions 0" h,s or ner:ax retum, DO NOT check bOX 6a "
b 0 Spau.., ' """" , , , , . , ,
c Dependonts:
22 Add the amcuntllr. tt'll far 11 'l: CQrurr.n fer :mts 7 throJ '" 21. "~IIIS
23 IRA deduct,on Isoe page 27)
24 Student 108e ieter.st deou:tlo~ (seo poge 27)
25 Meoica' savings account deduclto". Attach Form BS53
25 Moving expe~ses, Attach Fo'm 3903 , , ' ,
27 One-halt of self.er-,p!oyme~t lax, Attach Schedule SE
26 Self.employed heall~ ,nSUlllnc. deduction (.ee page 29)
29 Solf-employed SEP, SIMPLE, end qunl'~ed plans
30 Penalty on early wlthdraWllI ot savi~gs
31" Al'Tony paid b Recipl.n:'s SS:\ ~
32 Add lines 23 :h'ough 31a , '
33 S"btrac\ hne 32 Irom line 22, 7h,S IS vour ADJUSTED GROSS IN::OME
For Olltlolu,.., Prlvll:)' Act. and Plplrwork ReducUon Act N01Iel, .,. p.g. 5e. I4TA:
11040
Label
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... page 20,
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Attach
Forml W.2 b
and W.2G !'l.ra 9
Allo Itllch Formf.) 10
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WI> w1l!lh.ld, 11
12
13
14
150
16.
17
16
19
20.
21
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U.S. Individual Income Tax Return 2000
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~o~the DlrJon '.Ote 31 2000 orl'l~"ltrtn
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::lENISE
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Spouse', .0:18' Jc:'"rr, "0
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IMPORTANTI
A
Ya.., M~ST ,,'1,,'
SIOle
ZI" coda
VOl,)' SSf\/.s\ 8oc...e
You
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Spouu
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HOUGH
. 86.6B.9834
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~
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Add "",mbers
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Ilfles IIbolJe
~
D
W~ges, salaMS, t,ps, etc. A:tach Fol'm(s) W-2
T AXAe~" inlerest. Attach SchedUle B If recuired
7AX-EXEM"T Intere~t, DO NOT inc,uce On linn 6e . ,
Ordinary divl:onos, A::ac~ So"edule i3 I' recwed , , .
TaKable refunc(, credl:9 O' cf!sels 0: state and looellncome taxes (see pa." 22)
AIIn,cny received . , , .
BUSiness income or (1059) Altac~ Schadule C or C.EZ
::aOI!al gai" or (1095) At:ach Scl'., 0 " requi'ed, If nol requored. check nore ~ 0'
Olner gains or (lo~se9), Allacn "orrn4797 . , , , , ,
Total IRA dist'ioutions, , 115a: U b 7axoble amoJnl
T~la: pensions and a,nu,t'es ,115a! CJ b Taxable amount
R,ntHl rell eslate, rCyi1lt1es. part"'lI~shlps. S ccrpcra~Qna, t1'\j6l0, ele. An~er Schedule E
"orm :r.come 0' (loss) Attach Sc,edule F
~'e"1ployment co"'pensa:,on ".,.
Social security beneVIs , . , ,120a'
Olher :r.coma, Lisl type ano amour,l (see pege 25)
52,34"
37
Bb
3
U b iBXO'bj~ l!I~c'unt
....-..- - -.. '$- ......... -.....
~.....~................................................................~.........
52.3BO
23
24
25
28
27
i 2B
29
30
31a i
. "i
52,3BO
Form 10~O (2000)
~o'm 1040 (20~:Jl
Tax and
Credits
',-"
: Sl.nd.rd
~D.ductlo"
I for Moat
i P.upl.
,Slngla.
'$4,400
i~ Hood of ,
I noul.hold; i
,S6,450 '
j Marnld ~I,"g I
JJOlnllyor
,Oull!fyir:g
Iwldowl.r)'
i S7,J50
,
/Mlrrtldfilr'1g
IOperal"iy;
153.675 ,
Other
Taxes
'--'
Payments
III)'Cllhlv" I
ICU.llfti~; -
I C:~'ld, altAeh ~Oa
15ehldui. EIC., b
Refund
~'''''u!\
ll'rUj~
Ilnll..~.~1
S.OIl';'~
''1~ I,. iI"l!7t-,
'k,r;f'J7Il.
Amount
You Owe
Sign
Here
JC'''III\,,;'T'''I
5"1=1011'
I(II:IC4t',
~.V1l....rUo'l!t
~
Paid
Preparer's
U5e Only
!:lE'IIS:: J "10LJGI-i 1e6.42-154~
34 '''T10~nt I'orr line :;3 (adjusted graM Income) , , , , " ,,',',' 34
35a Ch.c~ :f: ~YOU....nl 55 Dr o'd.r.: : Blind: :J5~ouse wU 55 cr a'dO!, ...; Blind. 'I"
Acd tho r,umber of boxes checked oeova and enle/tne :otal hero , , , , ' ~ 350 ~
b If 'yOU D'a rnll~lIld "Foil IIpA,.,.ly and your ,oewla ItD",~OS daducbonll, __ ~'~
er YOl. W.'. I du.,.satuI II' un, !lie page 31 a~d checll: ~erft .. 3513
38 En'.. )'Cur ITEM'Z~O O~:JUCTIONS fro,!, acned.', A, hnD 2.. OR STAN:lAR:J :leOUO~'ON
shew,. or 1"0 left. aUr IIDI Dage 31 to fnd your f.ifando1ra clIlducUon If you
e~eekcd any bOx Cr1 hne 35u C' 35~ OR If G:meone con eJa!m YOJ I. 8 cepsr.den:
37 $ubtrac: line 38 f'om "nO 34
38 If 11M J4 II $D5,700 or Ion. mUi~ply $2,800 Elt thl'! tot~l r'lumbor af alCDm,cI~C1na claimed
cn I'no 6d I' I~n. 341. ovor S!lG,7CO. ...,h. W''''"h.., On page 32 Icr tn. amount to .nl.r
39 TAXAB,E INCOMe, Sublnlcll'no 36 Irer' In. 37, ""n. JB II ",ore tl10n IIn. 37, .',1.: .0. . ,
- -..
40 TAX (Iue cg 32; :l'1l1lck If eny IIJ( II from Q -JFCl~(') De14 b ~ ~cr~ 491:
41 Alternatve minimum tax, A::acn corm 625~ ,
42 Ado ',nes 40 and 41 , , , , , ' , ,
43 Foreign laX credit, A:tocn Form 111E II reou:rod .
44 Credit for cruc or,d aependllnr ClrSlum.rll" Attach Fom 2441
45 Credl: fer tho elaeroy or tho diuoled, Attach Scheoule R
46 Educabon cred,ll:, Altach corm a8G3
47 Ch'ld tox crealt (aee page 35) , , ,
48 Adoption credit Attach Form Be3R
49 C:her, Cnec~ If~rom a...J Fo''Tl 3800 b...J Form 839B
c LJ corm 6601 d ..J Form (specify)
50 Acd lines 43 through 45, These are your TOTAL CRECITS
51 170'3
52 Se:f.emp'oym ent tax, Attacn Schedule SE , . ,
53 SocIal 'Icunty Bnd MedlCB'e tu: c" t:p lnccr'le no1 recorted to Im;:ltoye~ Attactl Fcrr"l 4137
54 Ta. on IRAs. olher ",Iirem.hl plans, and ~SA., AtfII:h For", 5329 ,'requlr.c ,
55 Aovance earned Income croc't paYMents from Form(.) W.2
58 Household employmont taxes, Attacn SChedUle Lj
57 Aco lOne. 51 th,ou h 56 ':'his " our rOTA. TAX
S8 Foceral incomel1lx withheld from Forms W-2 and ~ 099
59 2000 esu""al.. tax paym.n:' and .mount o"I:cd '''''''' 1 ee. rolurr
Earn.d incom. crcd,l (EIC) , . . , . . . . . .
Nonl1lxnble oornod Incorre: amount " ~
end type ~, ............... '. .. .....,...,........"..._ .",....., no'
61 Exces. social secu~ty and RRTA laxvdr,neld (see pege 50)
82 Add~;onal ch,ld lDx credi: Altacn ::orrr 8812 ' , . '
63 AmOunt oalc wilh reaues: for extenslor to n'e (aee pa@liO)
64 Olr'lOr Dlymenta, Cl'1ac\( irfrom a ~ =orm 2435 b U earrr 4138
65 ACd lin.. sa, 59 60a. and Bllh'lluch 64 Th..c are ycu' TOTAL PAYMEN~S
66 IIlIn. 65 IS more In.n line 07. GublnlC1l1ne 57 'rom I:no fE, Tn" IG lh. amcu"1 you OVERPAID,
87n Amount of line BO yo~ want REFUNDED TO YOU. ..,,'.'
b Routing numbsr I.. C TYPo':--:Checklr.g USo\ll"lgs
d Acecl,!!,t number
68 AmOUh' or rh. 05 vou wanl APPLIED TO YOUR 2001 eSTI-.1ATEO TAX ~i 68
89 III,no 57 ;a more lhan IIn. 55, .ublr.Olllro 651roll', :rno 5,. Tn's I. tno AMOUN7 YOU owe,
1"0' detail. on how to poy, see page 51, "",. ~
70 Estimafed tax enal A!so InclUde On I'ne B9 , , . " 70 i !
Una.. g.".:~" Cl~ p.fjllry. I "'.tlllro \ret I ~.v. ex.m,l'leci 1,",1. rdl'Tl ."d ,teerr.plnYIl'l1l 5ch.aIlJ.. Inu It.t.m.r,ta, and to 1t111 but of rTTi ~nawMICIIII Ind
billet lh-r I,. tnlll, ec,..el, .1\0 campllt.. OUI.,.tlon ~ el'lp.rer taLhlrlhl., tu~l)'.,} re auod 01\ all In'om.tJa,, c'whlch p"pI"r hi. '''Y lC"cw1.dlll
~ "foltr IlgnJlture :011. IVou' occl.iDallor i Oay~ma j:lh01., no
, SpCUOO'O 8'gnefure, 'f 11 Jo,n1 rel.nn, 90T~ rr.UlIt algn, i :Jlte I S:lOU.II', occupa\iQr'l i Mom. Dhgno nc
43 I
44
45
46
47
45 '
m
49
58
59
, 80n
I,:. ~,. ,l;
~...-..,'
61
82
63
64
May the IRS dl<cuss Ih,s relu'n with the oreparer shown oolow (see oage 52)? -"VII
Prono'.f, ,0.1. I Chack "
slgr1ature B'~2/2001 Ilalf.emploYld X;
Fir",', n.m (or LL SERVICE I E'N
your, If I8lf.emD!eylt~), j Pf'1Cr11 no
addfl!8l, IIrd ZiP COco
Sial. PA
Plg.2
52,360
..,'
;....~~
30
.' 37
, " '11J
I_~
i 38
I 39 i
! 40
i4i"""
~, 42
It, .. .~ t
' 1"-' ,.~.
':W ,;1
II
"
fJ
._..1
e,..,,;,"!
45,930
5.C00'
40,330
6,722
6,722
, .1 50 !
~, 51
52
53
54 ,
55 I
56
57 I
6.722,
.1
,
. .1
...~
0.7671
6.722'
6,757:
75~
'5'
-
WNo
i Prap""fl SSN or pm.
11"00056641
23.2933776
717.24e;.B66~
17013
Form 1040 (2000)
ZIP tod.
& Otto in the amount of $23,488.42 us of the statement of July 5, 2002, shall be turned over in its
entirety to the Plaintiff, Denise J. I lough, upon receipt of the Order attached hereto.
2. Husband's IRA account with Orrstown Bank, account no. 1400 1181 073, in the
amount of approximately $130,000.00 shall be fro7.cn with no further distributions to be made Irom
the said account. Orrstown Bank shall be directed to provide duplieate copies of monthly
statements to the said account to Plaintiff, Denise J. Hough, at 4406 South 36111 Street, Arlington,
VA 22206.
3. The joint tenant account with American Funds, account no. 58336205, in the
amount of approximately $58,000.00 shall be immediately transferred to Plaintiff, Denise J. Hough.
TIle Plaintiffshall be responsible for all tax liability on the said account in the year 2002 and shall
also be responsible for the payment of the balance ofany college education expenses for the parties'
son, Eric I-Iough.
4. All life insurance policies held by the Defendant at the time of the entry of the
attached Order, shall designate the Plaintill' us beneficiary pending the outcome of the divoree
aetion.
5. The Defendant agrees that he shall execute immediately upon presentation, a
mortgage in favor of the Plaintiff on his business real estate loeated at 49 Brookwood Avenue,
Carlisle, Pennsylvania, in the amount of $250,000.00. The said mortgage shall secure any balance
duc to the Plaintiff which may be detennined by the Divorce Muster through the course of the
divorce litigation.
TO ___.
YOU AAt tlERrll' Not.,.rO TO I"LlAD TO
THE ENCLOSED WITHIN
TWUHY '~Ol OATS 0.. .[ItVler HIMro, Oil
... OIrfAULt JUDGMENT WAY BE [Nfl'UO
AOAINIiT YOU
LAW OFFICii
JAMES. SMITH, DURKIN & CONNELLY, LLP
.--
I~ 0. JlOX h\(l
lIIiKSllliY. 1'liNNSYLVANIA 11lUH16\(1
W[ HUlay CUllin', THAT THI WITHIN II
Ar, TRU! AND CORllrCT COI"' 0' THE
~_~~OIN"'L 'ILlD IN THIS ACTION
.,
.,
""ON'.,.
.nOlll....lf
0.'-"_'-;'
DENISE J. HOUGH,
PLAINTIFF
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY . PENNSYLVANIA
v.
: NO. 97 - 649 CIVIL TERM
RODNEY K. HOUGH.
DEFENDANT
: CIVIL ACTION - LAW
: IN DIVORCE
NOTICE OF ELECTION TO RETAKE FORMER NAME
Notice is hereby given that the PlaintitTin the above matter. hereby elects to retake and
hereafter use her fonner name 0.1' Denise A. Johnsto.ne and gives this written notiee avo.wing her
intention in accordance with the provisions 0.1'54 Pa.C.S.A. * 704(a).
DATED: ~..3C?'''3
lith ~
Denise J. Houg
TO BE KNOWN AS
_i!)l.n;...t-A. JDhnSotolU
Denise A. Johnstone
Sworn to and subseribed
before me this !iJi1day
of r/JJ~a.JU])J . 2003.
~~. ~.1u.Ju
NOT AR' UBU
NOTARIAL SEAL ~.
Jean L. Kosier. Notary Public
City of Hummelstown,County of Dauphin
My Commission Expires Feb. 9. 2004
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