HomeMy WebLinkAbout97-01156
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waivers of notice of intention to request entry of divorce
decree today and the Master's office will be provided those
signed waivers and consents and the Master's office will
file those with the Prothonotary. The divorce can then
conclude under Section JJ01(c) of the Domestic Relations
Code.
The complaint raised the economic claim of
equitable distribution. On September 16, 1999, the
Plaintiff filed a petition raising additional issues,
namely, alimony and legal expenses and counsel fees.
The parties were married on December 24,
1978, and have not agreed on the date of separation but it
is noted on the record that wife claims the separation
occurred in March 1997; husband contends the separation
occurred in April of 1996. Inasmuch as the economic issues
have been resolved by agreement which is going to be placed
on the record, it is not necessary for the Master to make a
finding as to when the parties were separated.
The parties are the natural parents of three
children. Michael, the oldest child, is in college and is
legally emancipated; the other two children are in the
custody of mother and are in grade school and high school.
An agreement is going to be placed on the
record in the presence of the parties. The agreement as
stated on the record will be considered the substantive
. .
,
3. Husband's IRA account at Delaware State Police with an
approximate value of $14,196.00 shall be the exclusive
property of husband.
4. The IRA account at Wilmington Trust which is in the
name of wife with an approximate value of $5,100.00 shall be
exclusive property of wife.
5. The IRA account at Wilmington Trust with an approximate
value of $55,530.00 which is in the name of husband, shall
be modified so that $28,000.00 is transferred into a
separate IRA to wife. This shall be done with paperwork as
approved by Wilmington Trust or, if necessary, a QDRO. In
the event the account is not transferred until after January
1, 2000, any interest earned on said $28,000.00 shall accrue
in favor of wife. The remaining monies in that account
shall be the exclusive property of husband.
6. The Wilmington Trust retirement account in husband's
name with an approximate value of $126,853.00 shall be the
exclusive property of husband.
7. The Dentsply 401(k) account with an approximate value
of $6,000.00 shall be the exclusive property of husband.
8. The Dentsply ESOP account with an approximate value of
$51,000.00 shall be the exclusive property of husband.
9. Husband's defined benefit retirement plan through
Ingersoll-Rand with an approximate value of $26,000.00 shall
be the exclusive property of husband.
10. Wife shall retain her jewelry.
11. Wife shall retain all items of personal property in the
home except for the following items of personal property
which shall be the exclusive property of husband:
Mahogany coffee table
Mahogany drop leaf dining table
A pair of small prints
Mahogany China cabinet
Set of three Swiss prints
12 x 18 Hawaiian print
Pair of Mahogany end tables
Swiss made TV cabinet
Mahogany triple dresser with mirror, bachelor
chest, and double bed
University of Delaware pictures
University of Delaware arm chair
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One large Swiss print
Louis 14th oak lady's desk
Tools from the garage and tool bench, except
yard tools
The personal property shall be available to Mr.
Salvaggio as he requests upon reasonable notice, but
pursuant to an agreement of the parties, he can leave the
personal property in the home until Mrs. Salvaggio sells the
home.
All personal paperwork of Mr. Salvaggio, including
military records, school records, work records, health
records, books and similar personal belongings shall be
available to Mr. Salvaggio.
12. Husband shall retain the Volkswagon and wife shall
retain the 1993 Audi.
13. Husband shall be entitled to all dividend payments he
has received to date on the various investments.
14. Wife warrants as part of the agreement that her
checking account at the Delaware State Police Federal Credit
Union currently does not have more than $500.00 in the
account and since April 1996 has not had a balance exceeding
$4,000.00.
15. Husband will, at his expense, continue to retain life
insurance under the existing AICPA trust fund policy in the
amount of $500,000.00. The beneficiaries shall be the
parties' three children. The provisions shall be for the
insurance to be payable to a trust or guardian who will
administer any proceeds for the support, education and
maintenance of the children in the event of husband's death.
The policy shall be retained at a value of $500,000.00 until
Michael attains the age of 22. At that time, husband may,
at his discretion, reduce the insurance value to $350,000.00
on the two other children. Upon Beth attaining the age of
22, husband may reduce the value of the policy to
$200,000.00. Upon Catherine attaining the age of 22,
husband's obligation to retain the insurance shall be
terminated.
Wife shall be provided with proof of insurance and
copies of any guardianship or trust papers. Wife
recognizes that she does not necessarily need to be named as
a guardian of those funds or trustee of those funds.
Husband's obligation to maintain this policy shall
,
,
continue as long as he is determined by the insurance
company to be insurable. In the event husband is determined
by AICPA to not be insurable and in the event husband cannot
obtain replacement insurance at a comparable premium rate
for whatever reason, husband's obligation on this insurance
will terminate.
16. In the event there are any Provident mutual insurance
policies involved that have Mr. Salvaggio as the named
insurer, wife will execute any and all documentation as
necessary to transfer ownership of those policies to
husband.
17. Both parties shall pay their own counsel fees and costs'
in this divorce case.
18. Wife waives any claim for alimony.
19. The parties agree that as further consideration for
this equitable property distribution, the parties will agree
to enter an agreement at the Domestic Relations Office for
support as follows:
a) Child support for Beth and Catherine shall be
calculated at $1,500.00 per month retroactive
to July 1 and continuing until December 31,
1999.
b) Child support for Beth and Catherine shall
commence January 1, 2000, at a rate of $1,100.00
per month. Upon Beth graduating from high school,
support will be set at $750.00 per month for
Catherine.
c) On or before January 15, 2000, husband shall make
a payment of at least $3,000.00 towards any
arrearage owing on the current support order.
d) Husband shall also be required to pay for child
care before and after school for Catherine on the
basis that such expenses are reasonable and fair.
e) Husband shall also pay babysitting/day care
expenses for Catherine during the summer subject
to said expenses being reasonable and fair.
f) Husband shall pay tuition for st. Pat ricks and
Trinity for the minor children. This obligation
shall include other private schools of a similar
tuition amount.
g) Husband shall be entitled to the dependency
deduction for all three children as long as
husband makes support payments as required by this
agreement and as required by applicable law.
Wife shall execute all documents as necessary to
insure that the husband can claim the dependency
deduction.
h) Husband shall pay health insurance coverage for
the three children. In the event that wife shall
obtain employment that provides for coverage at no
cost, husband's obligation shall be relieved.
Furthermore, if wife has employment that pays for
partial coverage or offers an opportunity for the
parties to obtain health insurance at reduced
rates, wife shall have the obligation of working
with husband to obtain that coverage to minimize
the insurance costs.
i) Husband shall pay 1/2 of all unreimbursed medical
expenses for the children subject to an initial
$250.00 deductable per year, per child. Wife
shall submit any claims on this directly to
husband no more than four times a year and she
will provide appropriate documentation as
required.
j) The terms of this support order are modifiable
in accordance with the law or upon a showing of a
change in circumstances.
21. This agreement is made with the understanding that the
parties have disclosed the various assets prior to
negotiation of the agreement as those assets related to
funds in existence on or about April 1997.
22. Except as herein otherwise provided, each party may
dispose of his or her property in any way and each party
hereby waives and relinquishes any and all rights he or she
may now have or hereafter acquire under the present or
future laws of any jurisdiction to share in the property or
the estate of the other as a result of the marital
relationship including without limitation, statutory
allowance, widow's allowance, right of intestacy, right to
take against the will of the other, and right to act as
administrator or executor in the other's estate. Each will
at the request of the other execute, acknowledge, and
deliver any and all instruments which may be necessary or
advisable to carry into effect this mutual waiver and
relinquishment of all such interest, rights, and claims.
MR. GILROY: Mrs. Salvaggio, you've been present
in the hearing room and you've heard all of the terms we
have set forth for the settlement; is that correct?
MRS. SALVAGGIO: Yes.
MR. GILROY: Do you agree with the terms?
MRS. SALVAGGIO: Yes.
MR. GILROY: Are you satisfied that you've had an
opportunity to consult with me as your attorney and to make
an intelligent decision concerning the terms of this
agreement?
MRS. SALVAGGIO: Yes.
MR. GILROY: And you understand that you're
waiving claims for alimony, counsel fees, and reimbursement
for costs by entering into this agreement; and that I have
advised you that I felt you could have achieved and received
some alimony if you pursued with litigating the case?
MRS. SALVAGGIO: Yes. That's correct.
MS. LINDSAY: Mr. Salvaggio, did you hear the
terms of this agreement as dictated by Mr. Gilroy and
amended by me?
MR. SALVAGGIO: Yes, ma'am.
MS. LINDSAY: And did you understand the terms
that we dictated and amended?
MR. SALVAGGIO: Yes, ma'am.
MS. LINDSAY: And are you in agreement with those
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CHRISTINE S. SALVAGGIO, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
.
.
v
: CIVIL DIVISION - LAW
MICHAEL R. SALVAGGIO,
Defendant
.
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CIVIL
: NO. 97 -
: IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in Court. If you wish to defend against the
claims set forth in the fOllowing pages, you must take prompt
action. You are warned that if you fail to do so, the case may
proceed without you and a decree of divorce or annulment may be
entered against you by the Court. A judgment may also be entered
against you for any other claim or relief requested in these
papers by the Plaintiff. You may lose money or property or other
rights impcrtant to you, including custody or visitation of your
children.
When the grounds for divorce is indignities or irretrievable
breakdown of the marriage, you may request marriage counseling.
A list of marriage counselors is available in the Prothonotary's
Office at the Cumberland County Courthouse, Carlisle,
Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES, BEFORE A DIVORCE OR
ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF
THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: 717 - 240-6200
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i 30 MIele Addressed to: 4a. Ar1IcIe NumbS' 1Il
:l Michael R. Salvaggio Z 221 292 344 ~
l.e 330 Union Hall Road 4b.Sarv\CeType il
II Carlisle, PA 17013 0 R811lslered g&l1Ifted ~
o Express Mall 0 Insured .!i
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8. Addressee'e Address (Only" i8ijijaoted i
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5. Received By: (Print NII1fIIJ)
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EXHIBIT
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CHRISTINE So SALVAGGIO
: CUMBERLAND COUNTY, PENNSYLVANIA
v
: 97.1156 CIVIL TERM
MICHAEL R. SALVAGGIO,
Defendant
: IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(e) OF THE DIVORCE CODE
I. A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on March 5,
1997.
2. Defendant acknowledges receipt and accepts service of the Complaint on or about March
10, 19970
3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the Complaint.
4. I consent to the entry of a final decree of divorce without notice.
50 I understand that I may lose rights concerning alimony, division ofpropcrty, lawyer's fees or
expenses if I do not claim them before a divorce is grantedo
6. I understa:Jd that I will not be divorced until a Divorce Decree is entered by the Court and
that a copy of the Decree will be sent to me immediately after it is filed with the
Prothonotary 0
70 I have been advised of the availability of marriage counseling and understand that I may
request that the Court require counselingo I do not request that the Court require counselingo
I verifY that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 PaoC oSo !l4904 relaling to unsworn
falsification to authorities.
Date: )Jt!JI JtJ, /9?t
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alvaggiolDefendant
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waivers of notice of intention to request entry of divorce
decree today and the Master's office will be provided those
signed waivers and consents and the Master's office will
file those with the Prothonotary. The divorce can then
conclude under Section 3301(C) of the Domestic Relations
code.
The complaint raised the economic claim of
equitable distribution. On September 16, 1999, the
Plaintiff filed a petition raising additional issues,
namely, alimony and legal expenses and counsel fees.
The parties were married on December 24,
1978, and have not agreed on the date of separation but it
is noted on the record that wife claims the separation
occurred in March 1997; husband contends the separation
occurred in April of 1996. Inasmuch as the economic issues
have been resolved by agreement which is going to be placed
on the record, it is not necessary for the Master to make a
finding as to when the parties were separated.
The parties are the natural parents of three
children. Michael, the oldest child, is in college and is
legally emancipated; the other two children are in the
custody of mother and are in grade school and high school.
An agreement is going to be placed on the
record in the presence of the parties. The agreement as
stated 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 during the transcription.
After the agreement
has been transcribed, counsel and the parties can review the
agreement for typographical errors and appropriate
corrections, if any, will be made.
However, it is noted
that the substantive parts of the agreement will not be
subject to any changes or modifications and even though the
parties and counsel do not later affix their signatures to
the agreement by way of affirmation of the terms of the
agreement, the parties are bound by the terms of the
agreement as stated on the record today.
After the agreement has been reviewed and
after the parties have affixed their signatures, the Master
will prepare an order vacating his appointment and counsel
can then file a praecipe requesting a final decree in
divorce. Mr. Gilroy.
MR. GILROY: The agreement of the parties, as
we understand it, is as follows:
1. The marital home at 330 Union Hall Road, Carlisle,
Pennsylvania, shall be conveyed to wife. Wife's counsel
will prepare a deed for execution by husband to accomplish
that conveyance within the next two weeks.
2. Husband shall make a cash payment to wife in the amount
of $30,000.00. This payment shall be made through
husband's attorney's office to wife's attorney on or about
January 15, 2000.
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3. Husband's IRA account at Delaware State Police with an
approximate value of $14,196.00 shall be the exclusive
property of husband.
4. The IRA account at Wilmington Trust which is in the
name of wife with an approximate value of $5,100.00 shall be
exclusive property of wife.
5. The IRA account at Wilmington Trust with an approximate
value of $55,530.00 which is in the name of husband, shall
be modified so that $28,000.00 is transferred into a
separate IRA to wife. This shall be done with paperwork as
approved by Wilmington Trust or, if necessary, a QDRO. In
the event the account is not transferred until after January
1, 2000, any interest earned on said $28,000.00 shall accrue
in favor of wife. The remaining monies in that account
shall be the exclusive property of husband.
6. The Wilmington Trust retirement account in husband's
name with an approximate value of $126,853.00 shall be the
exclusive property of husband.
7. The Dentsply 40l(k) account with an approximate value
of $6,000.00 shall be the exclusive property of husband.
8. The Dentsply ESOP account with an approximate value of
$51,000.00 shall be the exclusive property of husband.
9. Husband's defined benefit retirement plan through
Ingersoll-Rand with an approximate value of $26,000.00 shall
be the exclusive property of husband.
10. Wife shall retain her jewelry.
11. Wife shall retain all items of personal property in the
home except for the following items of personal property
which shall be the exclusive property of husband:
Mahogany coffee table
Mahogany drop leaf dining table
A pair of small prints
Mahogany China cabinet
Set of three Swiss prints
12 x 18 Hawaiian print
Pair of Mahogany end tables
Swiss made TV cabinet
Mahogany triple dresser with mirror, bachelor
chest, and double bed
University of Delaware pictures
University of Delaware arm chair
One large Swiss print
Louis 14th oak lady's desk
Tools from the garage and tool bench, except
yard tools
The personal property shall be available to Mr.
Salvaggio as he requests upon reasonable notice, but
pursuant to an agreement of the parties, he can leave the
personal property in the home until Mrs. Salvaggio sells the
home.
All personal paperwork of Mr. Salvaggio, including
military records, school records, work records, health
records, books and similar personal belongings shall be
available to Mr. Salvaggio.
12. Husband shall retain the Volkswagon and wife shall
retain the 1993 Audi.
13. Husband shall be entitled to all dividend payments he
has received to date on the various investments.
14. Wife warrants as part of the agreement that her
checking account at the Delaware State Police Federal Credit
Union currently does not have more than $500.00 in the
account and since April 1996 has not had a balance exceeding
$4,000.00.
15. Husband will, at his expense, continue to retain life
insurance under the existing AICPA trust fund policy in the
amount of $500,000.00. The beneficiaries shall be the
parties' three children. The provisions shall be for the
insurance to be payable to a trust or guardian who will
administer any proceeds for the support, education and
maintenance of the children in the event of husband's death.
The policy shall be retained at a value of $500,000.00 until
Michael attains the age of 22. At that time, husband may,
at his discretion, reduce the insurance value to $350,000.00
on the two other children. Upon Beth attaining the age of
22, husband may reduce the value of the policy to
$200,000.00. Upon Catherine attaining the age of 22,
husband's obligation to retain the insurance shall be
terminated.
Wife shall be provided with proof of insurance and
copies of any guardianship or trust papers. Wife
recognizes that she does not necessarily need to be named as
a guardian of those funds or trustee of those funds.
Husband's obligation to maintain this policy shall
continue as long as he is determined by the insurance
company to be insurable. In the event husband is determined
by AICPA to not be insurable and in the event husband cannot
obtain replacement insurance at a comparable premium rate
for whatever reason, husband's obligation on this insurance
will terminate.
16. In the event there are any Provident mutual insurance
policies involved that have Mr. Salvaggio as the named
insurer, wife will execute any and all documentation as
necessary to transfer ownership of those policies to
husband.
17. Both parties shall pay their own counsel fees and costs
in this divorce case.
18. Wife waives any claim for alimony.
19. The parties agree that as further consideration for
this equitable property distribution, the parties will agree
to enter an agreement at the Domestic Relations Office for
support as follows:
a) Child support for Beth and Catherine shall be
calculated at $1,500.00 per month retroactive
to July 1 and continuing until December 31,
1999.
b) Child support for Beth and Catherine shall
commence January 1, 2000, at a rate of $1,100.00
per month. Upon Beth graduating from high school,
support will be set at $750.00 per month for
Catherine.
c) On or before January 15, 2000, husband shall make
a payment of at least $3,000.00 towards any
arrearage owing on the current support order.
d) Husband shall also be required to pay for child
care before and after school for Catherine on the
basis that such expenses are reasonable and fair.
e) Husband shall also pay babysitting/day care
expenses for Catherine during the summer subject
to said expenses being reasonable and fair.
f) Husband shall pay tuition for St. Patricks and
Trinity for the minor children. This obligation
shall include other private schools of a similar
tuition amount.
g) Husband shall be entitled to the dependency
deduction for all three children as long as
husband makes support payments as required by this
agreement and as required by applicable law.
Wife shall execute all documents as necessary to
insure that the husband can claim the dependency
deduction.
h) Husband shall pay health insurance coverage for
the three children. In the event that wife shall
obtain employment that provides for coverage at no
cost, husband's obligation shall be relieved.
Furthermore, if wife has employment that pays for
partial coverage or offers an opportunity for the
parties to obtain health insurance at reduced
rates, wife shall have the obligation of working
with husband to obtain that coverage to minimize
the insurance C0StS.
i) Husband shall pay 1/2 of all unreimbursed medical
expenses for the children subject to an initial
$250.00 deductable per year, per child. Wife
shall submit any claims on this directly to
husband no more than four times a year and she
will provide appropriate documentation as
required.
j) The terms of this support order are modifiable
in accordance with the law or upon a showing of a
change in circumstances.
21. This agreement is made with the understanding that the
parties have disclosed the various assets prior to
negutiation of the agreement as those assets related to
funds in existence on or about April 1997.
22. Except as herein otherwise provided, each party may
dispose of his or her property in any way and each party
hereby waives and relinquishes any and all rights he or she
may now have or hereafter acquire under the present or
future laws of any jurisdiction to share in the property or
the estate of the other as a result of the marital
relationship including without limitation, statutory
allowance, widow's allowance, right of intestacy, right to
take against the will of the other, and right to act as
administrator or executor in the other's estate. Each will
at the request of the other execute, acknowledge, and
deliver any and all instruments which may be necessary or
advisable to carry into effect this mutual waiver and
relinquishment of all such interest, rights, and claims.
MR. GILROY: Mrs. Salvaggio, you've been present
in the hearing room and you've heard all of the terms we
have set forth for the settlement; is that correct?
,
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MRS. SALVAGGIO: Yes.
r
MR. GILROY: Do you agree with the terms?
MRS. SALVAGGIO: Yes.
MR. GILROY: Are you satisfied that you've had an
opportunity to consult with me as your attorney and to make
an intelligent decision concerning the terms of this
agreement?
MRS. SALVAGGIO: Yes.
MR. GILROY: And you understand that you're
waiving claims for alimony, counsel fees, and reimbursement
for costs by entering into this agreement; and that I have
advised you that I felt you could have achieved and received
some alimony if you pursued with litigating the case?
MRS. SALVAGGIO: Yes. That's correct.
MS. LINDSAY: Mr. Salvaggio, did you hear the
terms of this agreement as dictated by Mr. Gilroy and
amended by me?
MR. SALVAGGIO: Yes, ma'am.
MS. LINDSAY: And did you understand the terms
that we dictated and amended?
MR. SALVAGGIO: Yes, ma'am.
MS. LINDSAY: And are you in agreement with those
terms?
MR. SALVAGGIO: Yes.
MS. LINDSAY: Do you have any questions or
concerns that have not been addressed that you believe need
to be addressed before we conclude these proceedings?
MR. SALVAGGIO: No, ma'am.
I acknowledge that I have read the above
stipulation and agreement, that I understand the terms of
settlement as set forth herein, and that by signing below I
ratify and affirm the agreement previously made and intend
to bind myself to the settlement as a contract obligating
myself to the terms of settlement and subjecting myself to
the methods and procedures of enforcement which may be
imposed by law and in particular Section 3105 of the
Domestic Relations Code.
WITNESS:
DATE:
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Hubert X. Gi
Attorney fo
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Michael . Salvaggio
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IN TilE COURT OF COMMON PLEAS OF CUMlIERLANIl COllNTY, PENNSYI.V ANIA
DOMlxnc Rt:I,ATlO~S SI:cnON
P. O.lIox320, CARI.ISI.I:, PA 17013
PIIONI:: (717) 240-6225
FAX: (717) 241).6248
November 29,1999
PlainlilTName:
Defendant Nome:
Docket Number:
PACSES Cose Number:
Olher Stole ID Number:
Please nole: All correspondence must inelude Ihe PACSES Cose Numbero
Christine Salvaggio
Michadll. Salvaggio
INCOME ANO EXPI:NSE ST A TEMI:NT
nlls FORM MUST BE FILLED OUT
(If you are self-employed or if }OU are salarie,l by a b,uiness of which }OU a,e owner in whole or patt. }OU mwt a/so fill out the
Supplemental Income Statement which appears on the llut page of this income and expense statement,)
INCOME STATEMENT OF Michael R,Salvaggio
I verify that the statement made in this Income and Expense Sllltement Dre true and correct, I understand that false statements herein arc
subject to the eriminal penahies of IS Pa, C.So ~4904, relating to unsworn falsification to authorities,
Dote
Michael R, Salvaggio, Defendant
INCOME:
Employer MRlnc
Address
4600 Big Tree Way, Greensboro, NC
Type of Work Management Services
Payroll No. Gross Pay per Pay Period S
(Annual199S S 63,45S,OO)
Pay Period (wklyo, bi.wkly" etc,)
Itcmizcd Pavroll Deductions
Fedetul Withholding S II,OSS,oo Social Security S Local Wase Tox S 635,00
Slllte Income Tox S 1,777,00 Rctirement S Savings Bonds S
Credit Union S Life Insurance S Health Insurance S
Other Deductions (Specify) PSEA Union Dues S Opti-WsseTox S
Nct Pay per Pay Period S 40163,00
Service Type
Pagc I of6
Fonn IN.ooS
Worker ID
...
INCOME AND ExPENSE STATI'MI'NT
PACSES CASE NUMIlER
OTHER (Fill ill Appropriate Colllmll)
INCOME
WEEK MONTH VEAR
Interest $ S $ 893.00
Dividends 440.00
Pension
Annuity
Social Securily
Rents
Royalties
Expense Aecount
Gills
Unemployment
Compensation
W orlemen's
Compensation
IRS Refund
Other
Other
TOTAL $ $ $ 1,333000
TOTAL INCOME $
EXPENSES
(Fill ill Appropriate Colllmll)
WEEK
MONTH
YEAR
HOME
MOr1gagelRent
s
$ 680.00
$
Maintenance
Utilities
Electric
Gas
75.00
Oil
Telephone
Service Type
Page 2 of 6
Fonn 1N-008
WorkerlD
INCOME ANll EXPENSE STATEMENT
PACSES CASE NUMIIER
EXPENSES (Fill in Appropriate CO/Il111n)
(<onllnued)
WEEK MONTII YEAR
Woter S S S
Sewer
EMPLOYMENT
Public Trnnsportlltion S S S
Lunch
TAXES
Reol Eslale S S S
Personal Property
Income
INSURANCE
Homeowners S S S
AUlomobile 81.00
Life 176.83
Accident
Health 303.40
Other
Automublle
Poyments S S S
Fuel 158.00
Repoirs 1/0,00
Medkal 807,50
Doclor S S 807.50 S
Dentist
Orthodontist
Service Type
Pogc 3 of 6
Fonn 1N-008
Worker 10
INCOME AND EXPENSE STA TEMI'Nf
I'ACSES CASE NUMIlER
EXPENSES (Fill III Appropriate Colllmll)
(continued)
WEEK MONTII VEAR
Hospital $ $ S
Medicine
Special needs (glasses,
braces, orthopedic df!Vlccs)
EDUCATION
Private School S S S
Parochial School 527,28 6,327.40.
CoUege 1,940.00 23,280,00"
Religious
PERSONAL
Clothing S S 100,00 S
Focod 217,00
BarbcrlHairdrcsser 14,00
C,edit Payments:
Credit Card
Charge Account
Memberships
LOANS
Credit Union S S S
Miscellaneous
Household Help S
Child Care
PapcrslBookslMagazine
Entertainment
Pay TV
Vacation
ServIce Type
Pugc 4 of 6
Fonn IN'()()8
Worker ID
. Purochial School TUition: 4627.40 (Trinity) , 1700.00 (51. Pat's)" 60327.40
.. College Tuition, Room, lIoard, Esp.: 160700,00' 6580.00 (computc,o cxp) K 23.280.00
INCOME AND EXPENSE ST ^ TEMENT PACSES C^SE NUMBER
EXPENSES (Fill in Appropriate Column)
(cont/nurd)
WEEK MONTH YEAR
Gills S S S
Legal Fees
Chnrilable Contributions
Other Child Support
Alimony Payments
nllowanceso clothing and 276000
supplies
OTHER
Laundromat S 26.00 S
TOTAL EXPENSES S 5,492,00 29,607.40
PROPERTY Ownenblp'
OWNED DESCRIPTION VALUE
II W J
Checking Accounts x
Savings Accounts x
Credit Union
StocksIBonds x
Real Estntc
Other
TOTAL S
INSURANCE COMPANY POLICY # CoveraKe .
H W C
How,ilal Cumberland Enr, Nose & Thront x
B ue Cross
Other
Medical Cumberland Eor. Nose & Thronl x
Blue Cross
Other
OH . Husband W - Wire C. Combined J. Joint
Service T~'Pc
Page 5 or 6
Fonn IN-oog
WorkerlD
v
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYVLANIA
: NO: 97 -1156 CIVIL
CHRISTINE SALVAGGIO
Plaintiff
MICHAEL Ro SALVAGGIO
Defendant
: IN DIVORCE
LQJllj{'r
PLAINTIFF'S LISTING OF MARlT AL ASSETS:
HUSBAND WIFE
1. Real Estate - 330 Union Hall Road
Carlisle, PA 17013 (jointly owned) $170.000000
2, Husband's IRA account at $ 14,196091
Delaware State Police (9/30/99)
30 Husband's retiremcnt account at
Wilmington Trust - IRA(9/30/99) $ 55,530.00
40 Wifc's Retircment Account-
Wilmington Trust (9/30/99) $ 5,174018
50 Husband's Rctiremcnt Account -
Wilmington Trust (9/30/99) $126,853,73
60 Husband's Dcntsply 401 K (9/30/99) $ 6,007052
7. Husband's Employcc Stock Owncrship Plan at Dcntsp1y $ 51,287.20'
80 Husband's dcfined bcnefit rctircment plan through Ingersoll Rand $ 22,2170142
90 1996 incomc tax refund which Husband
claimed as crcdit on his 1997 tax rctum
which was filed individually $ 6,660000
10, Jcwelry in wife's posscssion $ 1,660000
100 Pcrsonal propcrty in wifc's posscssion $ 5,110000
II. Husband's car - 1996 VW Cabrio / Wifc's car - 1993 Audi $12,255000 $ 6,405000
I Subject 10 verificatiun upon further infonnalion from Dentsply
1 Subject to verification by wife's pension appraiser
.'
DRAFT
"
,:
HUSBAND WIFE
""7 .
120 Payment received by husband in May~o
Payment represented reimbursement on expenses
which were paid from joint funds and also represented
compensation earned that is marital property, $ 62,000000
13. Dividends Received $ 6,439.00 $ 500.00
14. Rental value -
1997 August through December 4x$1.050000 = $4,200000
1998 12 x $1,125.00 = $13,500000
1999 II x $1,200000 + $13,200000 - Total $30,900000
One half allocated to Wife based upon use of property $ 15,450,00
CHRISTINE S. SALVAGGIO,
Plain tiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97 - 1156
.
.
vs.
CIVIL ACTION - LAW
MICHAEL R. SALVAGGIO,
Defendant
IN DIVORCE
ORDER AND NOTICE SETTING HEARING
TO:
Christine S. Salvaggio
Hubert X. Gilroy
. Plaintiff
, Counsel for Plaintiff
Michael R. Salvaggio
Carol J. Lindsay
, Defendant
, Counsel for Defendant
You are directed to appear for a hearing to take
testimony on the outstanding issues in the above captioned
divorce proceedings at the Office of the Divorce Master, 9
Hanover Street, Carlisle, pennsylvania on the 31st and 1st
of May and June ,2000, 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.
North
days
Hoff r, President Judge
Date of Order and
Notice: 11/18/99
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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE. PA 17013
TELEPHONE (717) 249-3166
...~
CHRISTINE S. SALVAGGIO,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97 - 1156
vs.
MICHAEL R. SALVAGGIO,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
RESCHEDULED HEARING
ORDER AND NOTICE SETTING HEARING
TO: Christine S. Salvaggio , Plaintiff
Hubert X. Gilroy , Counsel for Plaintiff
Michael R. Salvaggio , Defendant
Carol J. Lindsay , Counsel for Defendant
You are directed to appear for a hearing to take
testimony on the outstanding issues in the above captioned
divorce proceedings at the Office of the Divorce Master, 9 North
Hanover Street, Carlisle, Pennsylvania on the 30th day
of November , 1999, 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.
, '~f1r'.
rgo ,. tt.
President Judge
Date of Order and
Notice: 7/20/99
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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
TELEPHONE (717) 249-3166
JUl-12-99 HJN 02:23 FH vE~TSPlV
::AX 1100 71784602E6
~
DINTSPlY Inlemll1ionDl
~70 Will ColIQg. Avenue
P.O. BOJC 872
York, PA 1740S.o872
1717) 84S7511
fax 17171 8S4.2343
July 12. 1999
Ms. carel J. LIndsay
Flower, Flower Bl1d Undsay
11 Ensl High Slreet
Cllrlisle, PA 17103
Dear Ms. Lindsay,
DENTSPL Y Intemationallnc. requlres the s8rvices of Mr. Michael Salvaggio in Munich,
Gcnllllny allcastlhrough September 1999. The assignments for which we have contracted Mro
Salvaggio are time critical and DENTSPL Y will need Mro Salvaggio's services on a full lime
basis In Munich through the end of this project '.
Sincerely,
f!:::i~~A
Corporate Controller I)
.
lAW OFFICI,S
FLOWER, MORGENTHAL, FLOWER & LINDSAY
A PROfESSIONAL CORI'ORATION
11 EAST HIGH STREET
CARLISLE, PENNSYLVANIA 17013-3016
JAMES 0, FLOWER
ROGER M, MORGENTIIAl.
lAMES O. Fl.OWER. JR.
CAROl.I, l.lNOSAY
(717) 24).SStJ
FAX: (7171 24).6SII1
E-mail: I:MFLl..aw@aul.!;u!n
DIETSClI &< MORGENTlIAl.
(l97S-198S)
Fl.OWER. KRAMER
MORGENTlIAl. &< Fl.OWER
(I'18S-I9'12)
October 15, 1998
E. Robert Elicker. Divorce Master
9 North Hanover Street
Carlisle, PA 17013
RE: Salvaggio v. Salvaggio
No. 97 -1156
Dear Bob:
Enclosed please find the Defendant's Pre-Trial Statement in the above caseo
Very truly yours.
FLOWER, MORGENTHAL, FLOWER & LINDSAY, P,C,
c~/!ri-
Carol Jo Lindsay
CJL:tjb
cc: Hubert X. Gllroyo Esquire
Michael R. Salvaggio
JOHN H, DROUIOS
HUSERT X, GILROY
BROUlOS & GILROY, p, c.
ATTORNEYS AT LAW
4 NORTIl HANOVER STREET
CARLISLE, PENNSYLVANIA 17013
TElEI'ltONE: (717) 243-1574
FACSIMILE: (717) 243.8227
INTI:RNF.T: brgiJ roypcOal1J.com
NON-TOLL FOR HARRISUURG AREA
717-766-1690
October J 2, J 998
E. Robert Elicker, 1/
Divorce Mash:r
Cumberland County Courthouse
Carlisle, P A ] 70 J 3
Re: Salvaggio v Salvaggio
Dear Bob:
Enclosed is the Plaintiff's Pre-Hearing Memomndum in the above case.
Even if Carol Lindsay does not file her Pre-Hearing Memorandum in a timely fashion, I request
that you proceed with scheduling this matter for a conference in order to move the case alongo
There is a great deal of frustration on my client's par< in connection with the delay that has heen
associated with (his case to dateo
I look forward to hearing from you on this maller,
dch
Sincerely yours.
~nroY
Enclosure
cc: Carol Lindsay, Esquire
Christine Salvaggio
, .
V8.
//1, k' I??
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION. LAW
NO. 97 .1156 CIVIL TERM
IN DIVORCE
t
r
CHRISTINE S. SALVAGGIO,
Plaintiff
MICHAEL R. SALVAGGIO,
Defendant
PRE.TRIAL STATEMENT
The parties were married on December 24, 1978, The dates of separation are disputedo
Husband avers the parties separated in May, 19960 Wife avers the parties separated in March,
19970 The parties are the parents of three children: Michael Do Salvaggio, age 17 years;
Elizabeth Jo Salvaggio, age 14 years; and Catherine Co Salvaggio, age 6 year'lo
Husband is a free-lance consultant who works for corporations, often out of town,
sometimes over seaso His work income is sporadico Until recently, he has not had work since
February, 19980 Wife was a homemaker who has returned to the job market.
Discovery in the case is not complete, The parties attempted to settle their case to no
avail, and on September 11, 1998, Husband served Wife with a set of Interrogatories and
Request for Production of Documents in an attempt to obtain necessary values,
I. MARITAL ASSETS
10 Marital Home - value $225,000,00 - no lien
20 Personal Property - to be appraised
3, 1996 Volkswagen Cabrio and 1993 Audi 100 - neither automobile is Iiened
4. Husband's IRA, Wilmington Trust - value to be provided
50 Husband's IRA, Wilmington Trust - value to be provided
60 DentSply 401-K Plan - value to be provided
o.~rttMnl of 1M y,..1lrt - Infe""'l R.ven~ S.rv.,.
Form 1 040 u.s. Individual Income Tax Return
For the ear Jan 1 . Dee 31. 1997. or 01 her tax ear be Inn in
YOUt Fu,1 NMne "'1 lul NoImt
21
22 Addlhe 8';0';;nlsjn-thefa~;; ht-c~h;-m~ 70711;,;5 7":' 2'~ThiS is -ou;-t;bi ;;.;o~;.~ - -. 2Z
23 IRA deduction Isea Instrucllons) . . , . . . . . . . . . . . . 23
24 Medical savings account deduction. Attach Form 8853. '... 24
25 Moving expenses, Attach Form 3903 or 3903.F 25
26 One,half of selt,employmenttax. Attach Schedule SE. . 26
27 Selt,employed heatth ,nsurance deduction (see ,nstrucllons). 27
2B K~ 'nds~l.emp/oyed SEP.nd SIMPLE plans 2B
29 Penally on early w,thdrawal of sav,ngs . 29
3De AJ,"""Y p.lld, b Rec'plenl's SSN .. 301
31 Addlines23.30a. ...'......
32 Subtract line 3' from line 22. ThiS IS out ad ulted rclslncome.
BAA For Prlvlcy Act Ind Plperwortc R.duction Act Notlc.o see Instructions,
rolAOlI~ '012ol197
Label
(s.. If'Illtucttonl.)
Usa the
IRS Ilbll.
OtherwISe.
plel" print
or type,
Pmldlntlll
EllCtfon
Campelgn
($H If'ISltucllonl.)
Filing Status
Check only
one box.
Exemptions
It more Ihan
six dependentso
see instruclions,
Income
Al1Ich
Copy B of
your Fonns
W.2, W.2G. &
1D99-R h....o
If you did not
get a W,20 see
Instructions.
Encloseo but do
not attach, any
payment. Also,
please use Form
1IJ4G.Vo
Adjusted
Gross
Income
It line 32 is
under $29,290
(under $9,770 "
a child did not
live w,th you),
:::.ee EIC In the
instructions.
Greensboro N( 27409
~ Do you wlnt $3 10 go to Ihis fund?......,.".,...."",.............,.."..".,...,.,..
If a oint return. does our s use want $3 to 0 to this fund?.. ........ ...... . ...........
1 ~ Single
2 ' Merrled filing ,oint relurn (even" only one had income)
3 ~ Married filing separale relurn, Enter spouse's SSN above & full nama here.. , .. (h r 1st 1 ne ( 5 a 1 va lZ lZ 1 0
4 '- Head of household Iwith qualifying person), ISee instructions,) It Ihe qualifying person is a child but not your
dependenlo enler this child's name here, . , ..
5 Ouall In widow et with de endent child ear s use died . 19 ee instructions.
6a ,X. Yoursaltolt your parent (or someone else) can claim you as a dependent on his or l- .....,""- r--;
= h., ta. return, do not check box 6a,......... .,..,....,..". .,..", ,....,.. ..,..,.. ~...Oft.. ..L-J!
b! S ule ..................................................................,......_ No.oIW'OUf"
o (2) Dependent's (3) Dependent's (4) No, of = on Cj
c D.pendlnllo social security relalionship .....1Ils I,ved .....
number 10 you i."""home -.... '.0.. 3!
,.,991 .""'.......
wfUlyou_eo
12 -...- c=
-- I
12 "==1..
12
1997
M1chael
II a Joinl R.twn. SPOUM'I Futl Name
R
MI
Salva
la.lNamt
10
Home Addr." (""""* andII1Ml). II You tu..... po. 80_, S..ln,tn.lCbonl.
..,.".........
4600 81
9E
Sill. ZIP COOt
First name
Michae 0 Sa va
Elizabeth J Salva
(atherine ( Salva
Last name
10
10
10
084-66-6302
221-70-6250
163-74-0246
Son
Dau
Dau
hter
hter
d Tolal number of exem tions claimed. . . . . .. . .
7 Wages, salaries, lips. etc, Attach Form(s) W,2 .. . . , . . . . . . , , . .. .. . . . . . . , , .. . , . . .. ,.. , . . .
BoT_bl.interesl. Attach Schedule B if required..,.. ..,.... ....."...."..... ....,......
b T....x....pt inleresl. Do not include on line Sa.,.......,.... 8b
9 Dividends, Attach Schedule B if required,."...,..,............,.,........ ,..........,.
10 Taxable refunds. credits. or oNsets of state and local income taxes (see instructions).....
11 Alimony received ,. ....,.., .................................... .......... ............
12 Business incume or Qoss). Attach Schedule C or C,EZ..... .....,.,......"...,.........
13 Cap,tal gain or (lass), Attach Schedule 0 ". .........".........,......"..,..,.,.,...,
14 Other gains or (losses), Attach Form 4797.. ........,......"............,...,.,...
15. Total IRA distributions....,' ~ I b Taxable amount (see Inslrs),.
160 TOUI penllons .nd...wbes . . . . . []!!J b Taxable amount (see inslrs) . .
17 RenUI real esUIe, roy.lbes. p.lrtners"ps, S Corpor.hons, trusts, elt, Altach Schedule E . , . . , . . . . . , , , , . . , , , .
18 Farm Income or (loss). Attach Schedule F. . . . . . . . , .. . . .. . . , . . .. . .. . . . .. , . , . .. , . , .. . . . , .
19 Unemployment compensation..........."....,........,........ .......,.. ..,.., '.,."
20. Soc"lsecurlty benefits,. I 20.1 1 b Taxable amount (see instrs).,
21 Other income. List type and amount _ see instructions
3 8570
2 2940
6 6170
-Oooot\lllfII.OI'llaQl'll'llhol~.
302-48-5336
,-N', ...... '-'ty No.
222-38-1270
For help flndlng line
Inltruetfonl, ...
lnlltuctlon,'n the bookllL
YH No
X
-'~
.,.....lMIInoI~
.to&M' ra.r 01 fICa.a
-_.
t'.pUL....b.
=~....CJ
--
_Oft..
--.
7
Bo 1 489,
9 1 892,
10 2260
11
12 54 5860
13
14
15b
16b
17
18
19
20b
58 193,
31
.... 32
12 7680
45 425,
Form 1040 (1997)
5 6
Form 1040 11997) Michael R 5alvaQQio 302-48- 33 Paoe 2
Tax 33 Amount trom.Jine 32 (adlusted gross.!ncome) . ~_~.. ............ .... ......"......... 33 45,425,
Computation 34. Check ,I: You w." 6\/~dero - Blind; . _ Spouse was 6\/0Ider, ~- Blind 34.L
Add tha numbar of boxes checked above and enler the total here, . ... ......' ..
b If you Ire married filjn~ separately and tour spouse itemizes deductions -
or you were a dual.sta us ahen, see 105 ructions and check here.... ......... ... 34b -
a... t -'" '~"~oo""m ,..... ,. ,,~ ~. 0, }
::Oilier Sundlrd daductJon shown below for your fIIin~ status, But
01 see the inslruct'ons If you checkad any box on ,ne 34a or 34b
your: or someone can claim you as a dependent. _
. Slngla - $4,150 . Married f,ling jointly or Qualifying w,dow(er) - $6,900 35 3 450,
. Head 01 household - $6,050 . Marriad filing separataly - $3,450
36 Sublract line 35 from line 33..,......,. ............." ,..'"" ,.........' ,............ 36 41 975,
If you wanl ~ If line 3J is $9J0900 or lOIS, mulbply $206\0 by the loUl number of exemptoons cl.,"lOd on 1100 6cj, If 110. 33
the IRS to II OYef$SO.900,seetheWOfksheetln l!\11OstnlCbons for the IlI10Ilnt to enter .",. ,.... ,. ,... ,........... ~ 100600,
figure your 38 Taxabl.lncoml. Subtract line 37 from lina 36. If IIna 37 is more than line 36. enter ,0" , , 38 11 3750
tax. see Tax. See insln, Check ,I... IaI from .,' FormCsl8811 b ,- Form 1972 .... .... ... ... ........ .. 39 60107.
Instructions. 39
Credits 40 c..elit for chid .nd dependent car. eJjleflIOI, Al1ath Fotm 2411 ,..',."., 40
41 Credit for Ihe eldarly or the disabled, Attach Sch R, . . , , " , , , 41
42 Adoption credit. Attach Form 8839 . , . , . . , , . . , . , . . . . , , , , . . , , 42
..., Foreign tax credit. Attach Form 1116, ...........,.... .,.,.. 43
44 Other, Check If from,... a n Form 3800 b U Form 8396
c [ Form 8801 d [] Form (specify). , , . . . 44
45 Add IInas40 through 44,..,..,.. ,...., ,. ,.,...., ,. ,......, ..,... . . . . . . . . . . . . . . . . . . . . . 45
46 Subtract lina 45 from line 39, If lina 45 is mora Ihan line 39, antar ,0, . .. ....... .. 46 60107,
Other 47 Salf,amployment tax. Attach Schedula SE , . .. , .. , . . .. , .. , . . . .. . , , .. . . . , , . . . . .. , . .. . . .. 47 7 7130
Taxes 48 Altarnativa minimum tax. Attach Fo,m 6251 .............,..,.,.,........,.,.....,...... 48 0,
49 SS.nd MlIl1Icarelalon bplOCome notrejXlrted to empIoyet, Attach FOrm 1m ,.".....".............,. 49
50 T.. on qUJlilied retirement plans (IOdud11lllIRAs).nd MSAs, Attach Form \3Z9,f required.,."..",..."". 50
51 Advance earned Incoma credit payments from Form(s) W,2,.,.,..,.,...",....,..,...., 51
52 Household employment taxas, Attach Schedula H....,..,' ..,... ,.........."...,., ,... 52
53 Add Ins 16 ' 12, This II vour to\J1 \JI ................................. ...... .............. .. 53 13 820,
Payments 54 Federal incoma tax w,thheld from Forms W,2 and 1099.,.." 54
55 1997 estimated tax payments and amount appliad
from 1996 return......... ,.,....... ,..... ..,. ..,.., ,. ,.,.', 55 18 6600
56. E4mod Income credit Attach Sdledul. Ele " you 11M. qUJIo/r1no
child. b Nonla1abl. earned ,ncome: .mount .. ..
Attach Forms .nd type ,.. .. 56a
W.20 W02G, ----------------------
and 1000.R ~ Amounl paid w,lh Form 4868 (requesl for extension} . . . . , . , . ~
to paga 1. 58 Excess social security and RRTA tax will:Cheld (sea instrs}". 58
59 Olher payments. Check if from. . . . , a , Form 2439
,- .-
bi Form 4136. ...."..... ,..............,..,..."....,. 59
'-
60 ~ft~~,lines 54, 550 56ao 570 58, and 59. These Dra your "" lR,660.
tu ~ .. .. .... ... ..
Refund 61 If IIOeliO is ""'. than 110. \30 subtract line \3 from line 1iO. TluSllthe .lI1OIlnt you DYtrp.id , .............. 61 4 840,
Have it directly 621 Amount of lina 61 you want Rlfundad to You,. ......,.............................. .. 62a 0,
deposited!Sae -
instructions and .. b Routing number , . cType: _ Checking _ Savings
lill in 62b, 62c, .. d Account number. . ..163
and 62d. 63 Amounlol line 61 vou want Aoolled 10 YOllr 19'31 EsUmatod Tal. . 1 4 840,
Amount 64 If line 53 is more than line GO, sublract line GO from lina 53, This is Iha Amount You
You Owe Owe. For details on how to pay. see Instructions.. .. ....... , , , . , . . . . , , , . . . . .. 64
65 Estimated lax oenallY. Also ,nclude on lina 64 .... 165 1 -+1!. I:<''ll.4
lJndet Pf~ltl" 01 Pf'Iur)'. I ded," tnlll n..... e'lmlr.eG thl, If",...n anct .ccom~nyll'lQ scnedul,s'l'ld slAt.ments..na 10 the blst 01 my ~ and
belief. thty .t. lrue. correct. ar'ICI compt.le. Oeclar.11()r't 01 prepl'" (other INn III_payer) ., bas.d on.1l *"101'",'1001'1 of l'Whtctl prfPWet' nas any knowIedOt.
YOUI SIl~n'lur. 0.1. YOUI ()ccuo.abon
~ accountant
Spc)UM' 5'gnllur.. II . Jolnl R.lurn. BOrn Mvsl 519"1 0..1. SPD\AI' IIOtI
~
Sign
Here
Keep a copy
of this return
for your records.
0,1.
Paid
Preparer's
Use Only
~;'PI:~~' ..,
Firm', fUme
((It)'OUf,d
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Chodo "
sell'IlmP
E'N
liP Code
P,e~'. Sooat $ecwlty No.
Form t040 (1997)
H1cha,~1 R Salva
Profit or Loss from Business 0MIl No ''''0()7'
(Soil Propriltorshlp) 1997
~ Partnlrshlps, \olnl vlntur... ItC. must 1111 Form 1065.
~ Attach to Form 1040 or Form 04t, ~ So Instructions lor Schtdull C (Form 1040) 09
__-(ISH)
302-48-5336
B Enter_...........,.......,
~ 7286
D ..............(IIN).N....,
10
Schedule':
(Form 1040)
~nlOllher''''l#'t
."..",..R........ :,1"'1(1
Heme of P'OQrltlc'
A PFlntJPlI tMiMI' Of Pr*won, InctudlnQ PtOOUd 01 Sv.a (Mf .",trvchonll
mana ement services
C eu..n.. ~, It No SeoIr.telNllnnl Ntmt. L'.YII BivoII.
HR tNC
E ~'_pIO"~:':;:p~no) ~ ~!!Q.O_ !!i.&.!!:.e..Uii!.Y.1_~,L_9j:___ _ _ ___ ______ __ ____________,
, ...... ... , Greensboroo NC 27409
F Accounllng method: (1) X: Cash (2) ~ Accrual (3) _ Olher Ispeclly) ~ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
G Did you 'malerlally part,c'pateO in Ihe operallon at this bUSiness during 19917 II 'No,' see Instructions tor Iimll on losses" :xr Y.. _ No
,~H_. '!.\1'..!\ slarted or acqUlled Ihls business dUllng 1997, check here. .. ...., . .... .. ....... .....,....... ~ t1
B!!GIII Income
Gross receipls or sales, Cautlon: /I this inCDme was reported /0 you on Form W02 and the -,
'Sla/u/ory employee' box on that lorm was checl<ed, sae the ins/ructions and check here, , , , . .. , , . ~ ~ 1 107 920 0
2 Relurns and allowances ..""..,....,... ....,..""....." ...... ..........,..",....' ...,..", ......,.. 2
3 Subtract line 2 tram line 1 .......................................,........,......,..................,.., 3 107 920,
4 Cost of goods sold Ilrom line 42 on paga 2),........ ......,..,......,....,......,..,..,..'"..",....,.., ..
5 Gross profit. Sublract line 4 from line 3.. .. , , , .. , .. , , . . . .. , . .. , .. .. .. , .. .. . .. .. , . .. . .. , , . .. .. , .. , .. .. .. .. 5
6 Other Income. including federal and state gasoline or fuel tax credit or refund. . . . . . . . . . . . . . . . . . . . . . . . . . .. . . 6
107 920,
7 Grosslncoml, Add lines 5 and 6.. , .. . .. .. .. .. .. . . .. .. . .. .. . .. .. .. . .. .. . .. . .. .. .. . .. .. .. .., ~ 7
Ex enses. Enter ex "S8S for business use of ur home on on line 30.
e Advertising...........,........ 8 19 Pension and profit.sharing plans........, 19
9 Bad debts from sales or 20 Renl or lease (see Instructions):
services (see instructions), , , , , , 9 I Vellaes, mKl1lneoy, .nd eqUlpmollt . . , . , , , , , , , " 201
10 Cor and !ruck O%jleflSes (see ,nslrs).... 10 4 015, b Other business property..............,.. 20b
11 Commissions and fees,........ l' 21 R~pairs and maintenance...... ......... 21
12 Depletion.,...,....,.."".." 12 22 Supplies (not Included in Part III).....,.. 22
13 DepreCiation and section 23 Taxes and licenses..................... 23
179 expense deduction
(not Included in Part III) 24 Travel, mealso and enlertainmanl:
(see instructions)..,..,..,..... 13 11 433. I Travel......"......,...."",......,.. 24.
t 4 Employee benefil pr'1Qrams b Meals and
(olher than on line 19)........, 14 1 203, enlertainment.......... 1 4270
15 'mur.nc,(olllerlllanl'all!l)......... 15 7 151. cEn",~".ofhneZ.bsub,
16 Inlerest: leeI to hmlabons (seelnslrs), 40,
a Mortoaoe (paid to banks, eft) ,. . . , , ., 161 d Subtract line 240 from line 24b , . , , , , , . " 24d
bOlhor................,........ 16b 2S Ulllilies............"..,......... ...... 25
17 Leoal.nd profesSlonals"""es ,...... 17 120626, 26 Wages (less employment credils)......" 26
18 OHlcee.cense ................ t8 27 OIller"penses(fromhne48on Z) ......... 27
28 Tolalexponstl belore expenses for bUSIness use of home, Add linos 8 Ih,ough 27 In columns, . . , , , , , , , , ,~ 28
107 9200
168,
4 531.
206,
7 614,
1 387.
3 000,
53 334,
29 Tentalive profit Ooss), Subtraclline 28 Irom hne 7. ......"."..."........... ......,.., . .......,.., 29
30 Expenses lor business use 01 your home, Allach Form 8829. . . . . . . . .. .. . . .. . . . . . . . . .. . . . . . .. , . . . .. , . .. , ..' 30
31 Not profit or OOIS~ Subtract line 30 from hne 29.
I If a profit, enler on Form t04O,lIne 12, and .110 on Schedull SE.llno 2 (stalutory
employees, see instructions). Estates and trusts, enter on Form 1041.li"e 3. ..... . . 1
. If a loss. you must go on to line 32.... ............ ........,.. .........
32 If you have a loss. check the box that deSCribes your Investment in this activity (see instructions). _
. If ~ou checked 32a, enler the loss on Form 1040.lIno t2, and alia on Schedule 5E.lln12 IstatutorYl
emp oyees, see Instrucbons). Estales and trusls, enler on Form' 0410 line 3. . . . . . . . . . , . . . . .. . . . . , ,.. r
. If you checked 32b, you musl allach Form 6198. ,. . . .:-
BAA For Paperwork Reduction Act Notlclo s.. Form 1040 Instructions,
54 586.
31
54 5860
321
_NII__IS
.lnsll.
_ Somt ,_tment
32b I1no1atmk.
Schedule C (Fonn 1040) 1997
F'DIZOI12 07125197
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Plainliffdid not work during most oflhe years of the marriage pursuant 10 an agreement between
Plainliff ood Defendant. Upon separation. Plaintiff hus obtained employment as a receptionist
with Cumberlood Eor Nose and Throat. She receives an hourly wage of $9025 per hour with
approximately 38 hours per week. Medical coverage is provided for Plaintiff only, but Plaintifi'
hus obtained coverage for Ihe 3 children and her husband with the underslanding Ihat Ihe
husband shall pay the ditlerence in the coverage and that understooding is confirmed in Ihe
Support Order, Plaintiff hus a 40 I K and retirement plan through her employer. She has only
been working there approximately 15 months and any interest she hus in those plans will be
minimal.
6
Throughout the marriage. Defendant was employed with Ingersall Rand as a CPA and he worked
there us an employee for approximately II yearso Defendant stopped working as 00 employee
with Ingersall Rood but then developed a contractual arrangemenl with Ingersall Rood, ood other
eompooies, where he would act a CPA or as a consultant. Defendant's consultant work took him
out of the country on a number of occasions for 00 extended period of timeo Defendant's wages
have varied over the past few years but have consistently been in excess of $100,000.00 on an
oonual basiso
7
PlaintilT's position is that the parties separated when the Plaintiff instituted the divorce action in
March of 1997. Defendant had moved out of the property prior to that time, but Defendant's
relocalion from the property was as a result of an investigation from a county agency. Even
though the Defendant was living out of Ihe property. Defendant's earnings were coming into a
jointly managed account and Plaintiff was paying numerous bills on behalf of the Defendoot,
Inking care of the Defendant's Income Tax obligations, pension deposits, charge cord accounts
ood similar matterso PlaintitT would also type Defendant's monthly invoices on billing to
companies even though Defendant was not technically living under the same roof as the Plaintiff.
The parties continued to function as husband and wife in all economic ways but they did not live
under the same roof. In the event the Defendant disputes Ihe date of separation, additional
testimony on that issue will be produced at the hearingo
8
The parties own the real estate at 330 Union Hall Roado There is no mortgage on the property.
There have been a number of appraisals on the propertyo Defendant obtained appraisals from
uncertified realtors who suggested the value was in excess of $200,000.00. Plaintiff has obtained
appraisals from 2 certified realtors with those appraisal amounts being $165,000.00 and
$175.000.00. There is confusion with respect to disposition of the marital real estaleo Defendant
has suggested he wants to buy the property, but Defendant has not come forward with a
methodology to conclude that matter, Plaintiff would be satisfied to allow Defendant to buy the
LA W OI'I'/Cf:5
.'LOW.JR. PLOWER &- L.NJ)/SAV
^ rJl.(}n~'i!ilO,,".u Cllll.rORAl1(),'l
IMlES 0, FLOWER
lAMES O. FLOWER,IR.
CAROLlo UNOSA Y
II EASTlI/GII STREET
CARLISLE, PENNSYLVANIA J70Jj,JOl6
July 1, 1999
(1J1)m,'m
FAX. (1J11m.."o
""LE.qo..,--
E. Robert Elicker, II, Esquire
9 North Hanover Street
Carlisle, PA 17013
Dear Bob:
RE: Salvaggio v. Salvaggio
No. 97-1156
The M...." hoad"" "h"'a"" In ~I, "''' . "f r", ""''''' ". "00 'f "00 '.m.
My dien' · on '''''om'''l. Gann.ny. M,. SaI"OOh adW,.. ~., ha Will not be ''''Uabla
funh. head"" on ""'"" "" doa to ~I, w'o" "'mmltmenl. H. "","men! "'me, to an
"'d In Ia!a S''''mba,. Woo'd 'h.... be . tim. . 0_, Wh", ~. M",,,,, hoad"" "'a~
b. "''''''dal'd to P'nnll him no only fa b. P'e"nf bot el,o fa help me In P"'''''",lIon ..
;1.
Thank yoU very mUch for Your consideration of this request.
Very truly YOurs,
FLOWER, FLOWER & LINDSAY, PoCo
k
CJUYb
Carol Jo Lindsay
CC: Michael Salvaggio
Hubert X, Gilroy, Esquire
NLry )'0
Off IW0, )0
v
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 97-1156 CIVIL
:'
,
CHRISTINE S. SALVAGGIO,
PlaIntiff
MICHAEL R. SALVAGGIO,
Defendant
: IN DIVORCE
PETITION FOR SPECIAL RELIEF
Petitioner, Christine S. Salvaggio, by her attorneys Broujos & Gilroy, P.c., sets forth the
following:
Petitioner has in her possession a variety of checks that have been received as dividends on
various financial accounts that are held in the name of the Defendant.
2
All of the financial accounts in question are marital property and are subject to distribution
by the Master in this case. The Master's Hearing is scheduled for December I, 1999.
3
Since the financial accounts are marital property, the income earned on said accounts
consists of marital property even though the checks are issued in the name of the
Defendant alone.
4
Plaintiff desires to have the checks negotiated and deposited into a joint escrow account to
be held pending resolution of the distribution of these assets by the Master. Defendant has
refused this request.
"
~ 0
INCOME AND EXPENSE STATEMENT OF
~L- C'\ 0
11 ( i'6 \ ; ,,-e, ~ oj C\ '5J~1 0
SSN deB. . 'C!h. \d':\O
III" \_r-.
DRN DATE~
THIS STATEMENT MUST BE FILLED OUT
(If you are self-employed or iI you are salaried by a business 01 which you are owner in whole or In part, you musl
also fill out the Supplemenlallncome ,Statement which appears on the last page 01 this Income and Expense
Statement.)
(a) WageslSalary
Employer & Address
Job Title/Description 51;
Pay Period (weekly, bl.weekly. monthly) ~,
Gross Pay per Pay Period ...............,...............,......,........................................................................,.... $ "\'2.,"1. ' .S(,
Payroll Deductions:
Federal Wllhholdlng ..................$
Social Securlly ......................,....$
Local Wage Tax .....,.......,..,..,......$
State Income.Tax ..................,....$
Retirement ..........'..00......0..'..'......$
Health Insurance ..,.................'..0$
Other (specily) o~~.',~^L~..,..$
.............,......,....$
........,..,..'(o...o....-J.: 0 t' '5-~ 1 CQ.
Net Pay per Pay Period ..09.\:?I.?.L~1.:::.......I.\~3:.~~]:.................0.....,....................................0.... $
INCOME
(b) Other Income
Interesl/Dlvldends ......................$
POnslonlAnnully .........................$
Social Securlly ........,..,.......... ..
Rents/Royallles .........,....' ,........$
Expense Account ...... ...............$
Gills ...0.................0 ..........,.......,..$
Unemployment ompensatlon 0$
Workmc"l's mpensalion .....,..$_
Total,Oth
t:\rT~ ,~'<l."",
i'\ "'S\ ,00. ( \'6\\
;~~~
l.?~
~?C . (c,
t:;()-
,0,\ \
Week
Month Year
$
$
$ /"
$
$
$ $
$ $
$ $ ._-_.~
$ $
,.
(. ~ INCOME AND EX~E ST A TEMEN~ OF .
\.....:...-\-\ ( \ ~\ , 0\'" -:J\\ Jc.~, u
I verily that the statements made In this Inco nd Elpense Stale-
ment are true Ind couect.J understand thai talse statements herein
are mado .ublocl 10 Iho penallio. 01 18 Pa.C.S. 4!Xl4 relaling 10
uns~o~~ lal'~\C~I~n 10 aUlho,allosC ~~ ~<( l\
Dale,_~_,D, ,_ , ____~
Pla,nll" or Delendat),)
Household
Week
EXPENSES
Home
MortgBge(Rent ........................................ $
Maintenance ........................................... $
UtllltlBS (telephone~atlng '1Y
electric, etc.) ~.~~,..~.r.:t..~'.....o~.~~ $
Employment (transportation, 0
lunches) ..........................:............,....... $
Taxes
Real Estate .............................................. $
Personal Property................................... $
Income ..................................................... $
Insurance
Homeowners ........................................... $
Automobile .............................................. $
L1le/AccldenIlHeallh ....,......................... $
Other .~.~-:s:~.................................. $
Automo~~
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Doctor, Dentist, Orthodontisl ................ $
Hospital............................,...................... $
Special (glasses, braces, etc,).........,..... $
Education
Private, Parochial School....................... $
College ..,.................................................. $
Personal
Clothing ................................................... $
Food ...................0..................................... $
Other (household supplies,
barber, etc.) ..........................,.....,......... $
, Credit P!lYments and. loans 0.....'............. $
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Entertainment (I~S,
books, vacation, pay TV, etco)............ $
Gilts/Charitable contributions ..,........... $
Legal Fees ..........................................'.... $
Other child support/alimony
payments ........,..................'....,............ $
Olher (specify) ..J::Y:.6..~.i.\.f.\-&.............. $
Tolal Expenses .........,................................... $
Child
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PROPERTY OWNED
Description
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SUPPLEMENTAL INCOME STATEMENT
A, This form must be lilled out by a person who (check one):
_ (1) operates a business or practices a profession; or
_ (2) Is a member of a partnership or joint venture; or
_ (3) Is a shareholder In and Is salaried by a closed corporation or similar entlly.
B, Allach to this statement a copy of the following documents relating 10 the business, profession, partnership,
joint venture. corporation or similar enllly.
(1) Ihe most recent Federal Income Tax Return, and
121 the most recent Prolll and Loss Statement.
C. .Name and Address of business:
Telephone Number
D. Name and Address (II different than C) of accountant, controller or other person In charge 01 financial
records:
E, 111 Annual Income from business .............................,........,..................,................................... S
(2) How oHen Is Income received? ...............'..0..............................,.............,............................ S
(3) Gross Income per pay period .................'...........0..........'..............,......,................,.....,......... S
(4) Nellncome per pay period ..........................,..'...._....0........'..................,.............................. S
(5) Specific deductions II any ................,...............................................................................,... S
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 97-1156 CIVIL TERM
CHRISTINE S. SALVAGGIO,
Plaintiff
MICHAEL R. SALVAGGIO,
Defendant
IN DIVORCE
RE: Pre-Hearing Conference Memorandum
DATE: Wednesday, February 3, 1999
Present for the Plaintiff, christine S. Salvaggio
is attorney Hubert X. Gilroy, and present for the Defendant,
Michael R. Salvaggio is attorney Carol J. Lindsay.
This case was commenced by the filing of a
divorce complaint on March 5, 1997, raising grounds for divorce
of irretrievable breakdown of the marriage. Counsel have
advised that the parties will sign and file affidavits of
consent and waivers of notice of intention to request entry of
divorce decree prior to the hearing so the divorce can be
concluded under section 330l(c) of the Domestic Relations Code.
The complaint also raised the economic claim of
equitable distribution. Mr. Gilroy advised that he intends to
file on behalf of his client a claim for alimony and counsel
fees. Mr. Gilroy is directed to file the appropriate pleadings
within the next two weeks. with respect to the alimony claim,
counsel are going to see if they can stipulate to events which
occurred involVing husband and his daughter to avoid having to
take any tes~imony. There is also some question as to whether
or not the conduct of husband constituted marital misconduct,
although the Master pointed out that it may under the law of
indignities have constituted an indignity to the wife.
The parties were married on December 24, 1978,
and separated, according to husband, April 15, 1996. Wife
claims the separation occurred at the time that she filed the
divorce complaint, March 5, 1997. The significance of the date
of separation involves the valuation of certain assets and the
treatment of funds which were received by husband as a result of
reimbursement for payment due him from an employer in the amount
of $62,000.00. The question is whether we handle those payments
as marital or non-marital. Counsel also are looking at how
those funds were used, and there is at least some agreement that
$18,000.00 of those funds were used to reimburse husband for
.
expenses which were paid out of the joint account for his
business activities. In any event, counsel are going to attempt
to document how the funds were expended, although attorney
Lindsay points out that the use of those funds specifically may
not be as important as actually when those funds were earned;
i.e., before or after the date of separation.
The parties are the natural parents of three
children, Michael, born August 21, 1981; Elizabeth, born
September 16, 1983; and catherine, born May 15, 1992. The
children are in the custody of the mother. Husband is paying
$500.00 per month for each child, for a total of $1,500.00 per
month for child support. He is not currently paying any spousal
support, but that matter can be revisited in May 1999.
wife is 46 years of age and resides at 330 Union
Hall Road, Carlisle, Pennsylvania, where she lives with the
children. Wife has a Bachelor's degree and is currently a
receptionist with Cumberland Ear, Nose and Throat. She works 38
hours per week and is paid $9.25 per hour. Wife is directed to
file an income and expense statement and provide a copy of her
income tax return by April 1, 1999, to opposing counsel. Wife
has not raised any health issues.
Husband is 47 years of age and resides at 4600
Big Tree Way, Apartment 9-E, Greensboro, North Carolina 27409,
where he lives alone. He has a Bachelor's degree and has passed
his CPA exam but works as a business troubleshooter and
consultant. His income for 1997, as reported on his tax return,
was $58,193.00. Husband is directed to file an income and
expense statement and provide a copy of his 1998 tax return to
opposing counsel by April 1, 1999. Husband is currently
undergoing significant psychiatric counseling and consults with
a therapist in San Francisco. The reason husband uses a
therapist in San Francisco is because he travels constantly
throughout the world with his employment. He also takes
medication for his psychiatric problems. Mr. Gilroy has
suggested that Ms. Lindsay provide him with a report regarding
husband's psychiatric issues, which he may be able to stipulate
to and avoid the need for taking testimony.
wife had two appraisals of the parties' real
estate at 330 Union Hall Road, Carlisle, Pennsylvania,
performed, showing a value of $165,000.00 to $175,000.00.
Husband had a market analysis showing a value of around
$225,000.00. In any event, the parties have agreed to list the
property for sale, and Mr. Gilroy has stated that the listing
agreement proposed will list the house at $206,000.00. The
house is not subject to any mortgage. Husband is claiming he be
reimbursed for rental value for the property, and it has been
suggested by his counsel that the monthly rental value is
$1,200.00. There is a question as to whether or not wife should
be entitled to any credit for payment of taxes and insurance.
Counsel should provide the necessary documentation to show
whether or not a credit should be allowed.
There was a joint checking account with
$6,500.00, which wife claims was used to pay marital expenses.
Husband is disputing that claim. Mr. Gilroy says that he has
provided evidence and documentation to Ms. Lindsay regarding
that account, but Ms. Lindsay's client apparently does not agree
with all of the information that has been provided. Therefore,
we need to determine whether or not any or all of the $6,500.00
should be distributed as a part of the equitable distribution
claim as opposed to having been used for payment of marital
expenses. The claim regarding the $6,500.00 is based on using
Mr. Gilroy's date of separation, which was the date of the
filing of the divorce complaint.
There is an issue with regard to an income tax
credit. wife claims that the parties were entitled, based on
the filing of a joint return, to a refund of $6,000.00, and that
instead of receiving those funds, husband had those funds
applied as a credit for his 1997 tax return which he filed
separately. We need to have verification that that transaction
occurred in the way described and, if so, wife would be entitled
to credit on account of the income tax refund.
The parties own a 1996 VW Cabrio and a 1993 Audi
100. Counsel are going to have those vehicles appraised or
provide a stipulated book value.
The following items are going to be valued using
current statements which counsel are going to provide:
husband's IRA with Wilmington Trust;
another IRA that husband has with Wilmington
Trust;
husband's IRA with Delaware state Police Federal
Credit Union;
Dentsply 401K plan;
Dentsply stock.
, '
-~. --..-
,-- ..
BROUJOS & GILROY, P.C.
ATIORNIlYll ^T LAW
. NORTH H~OVER STREET
C^RUSLB. 1'''''N~llVANI^ 17013
717"2~574 766-1690
~-='
~
.
v
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 97-1156 CIVIL
CHRISTINE S. SALVAGGIO,
Plaintiff
MICHAEL R. SALVAGGIO,
Defendant
: IN DIVORCE
PETITION RAISING ADDITIONAL ISSUES
Plaintiff, Christine S. Salvaggio, sets forth the following:
Plaintiff has incurred legal expenses in connection with the divorce and Plaintiff is unable to
pay said legal expenses.
2
Plaintiff has incurred various appraisal expenses in connection with the divorce.
3
Plaintiff desires alimony to be awarded upon the entry of any divorce decree.
WHEREFORE, Plaintiff respectfully requests that the Master address the issue of counsel
fees, reimbursement of expense and alimony.
Respectfully submitted,
~.Qr
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00
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