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Home My WebLink About02-6125 REAGER & ADLER, PC BY: DEBRA DENISON CANTOR, ESQUIRE Attorney J.D. No. 66378 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Plaintiff ROBERT S, PTASZEK, Plaintiff v, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0;2 - Go. 1..1.S eo L L ~ ~ DARLA PT ASZEK, Defendant CIVIL ACTION - LAW 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 important to you, When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling, A list of marriage counselors is available in the office of the Prothonotary at the Cumberland County 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 MA Y LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER A T ONCE. IF YOU DO NOT HA VE 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 A venue Carlisle, PA 17013 1-800-990-9108 REAGER & ADLER, PC BY: DEBRA DENISON CANTOR, ESQUIRE Attorney I.D, No, 66378 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attornevs for Plaintiff ROBERT S, PTASZEK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. DARLA PT ASZEK, Defendant CIVIL ACTION - LAW IN DIVORCE A VISO PARA DEFENDER Y RECLAIMAR DERECHOS USTED HA DlSO DEMANDANDO EN LA CORTE. Is desea defenderse de las quejas expuestas en las paginas siguientes, debar tomar acci6n con prontitud. Se la avisa que is no se defiende, el caso purde proceder sin usted y decreto de divorcio 0 anulamiento puede ser emitado en su contra por la Corte, Una decision puede tambien ser emitida en su contra por caulquier otra queja 0 compensaction rec1amados por el demandante, Usted puede perder dinero, 0 sus propiedades 0 otros derechos importantes para usted, Cuando la base para el divorcio es indignadades 0 rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Court of Common Pleas, Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania, SI US TED NO RECLAMA PENSION ALIMENTACIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DlVORCIO 0 ANULAMIENTO SEA EMITIDO, US TED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUlERA DE ELLOS. USTED DEBE LLEV AR ESTE PAPEL A UN ABOGADO DE INMEDlA TO. SI NO TIENE 0 NO PUEDO PAGAR UN ABOGADO, VA Y A 0 LLAME A LA OFICINA INDlCADA ABAJO PARA A VERIGUAR DONDE SE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty A venue Carlisle, PA 17013 1-800-990-9108 REAGER & ADLER, PC BY: DEBRA DENISON CANTOR, ESQUIRE Attorney I.D, No, 66378 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attornevs for Plaintiff ROBERT S, PTASZEK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, NO. (:Jti<. - (p/.}..:>- DARLA PT ASZEK, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(C) OR CD) OF THE DIVORCE CODE 1, Plaintiff is Robert S, Ptaszek, an adult individual who currently resides at 111 Adams Road, Carlisle, Cumberland County, Pennsylvania 17013, 2, Defendant is DarIa Ptaszek, an adult individual who currently resides at 245 Meals Drive, Carlisle, Cumberland County, Pennsylvania 17013, 3, Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4, The Plaintiff and Defendant were married on August 20, 1994 in Cumberland County, Pelillsylvania. 5, There have been no prior actions of divorce or for armulment between the parties, 6, Neither Plaintiff nor Defendant is in the military or naval services of the United States or its allies within the provisions of the Solders' & Sailors' Civil Relief Act of the Congress of 1940 and its amendments, 7, Plaintiff avers that there is one (1) child of this marriage under the age if eighteen, namely Mitchell R. Ptaszek, date of birth March 3, 1995, 8, The marriage is irretrievably broken, 9, Plaintiff has been advised that counseling is available and that Defendant may have the right to request that the court require the parties to participate in counseling, Plaintiff declines counseling, 10, After ninety (90) days have elapsed from the date of the tiling of this Complaint, Plaintiff intends to fIle an Affidavit consenting to a divorce, Plaintiff believes that Defendant may also fIle such an aftidavit. 11. In the alternative, Plaintiff will fIle a 330 1 (d) Affidavit and provide the appropriate notices two (2) years from the date of separation, WHEREFORE, Plaintiff respectfully requests this Court to enter a decree of divorce pursuant to Section 3301 (c) or (d) of the Divorce Code, COUNT I EOUlTABLE DISTRIBUTION 12. Paragraphs one (1) through eleven (11) of this Complaint are incorporated herein by reference, 13, Plaintiff and Defendant have acquired property, both real and personal, during their marriage. 14, The parties have acquired marital debt during their marriage, 15, Plaintiff and Defendant may be unable to resolve amicably the property issues in this matter. WHEREFORE, Plaintiff respectfully requests this Honorable Court to equitably divide all marital property and debt, Respectfully submitted, Dated: /2-/Z3/02--- By: REAGER & ADLER, PC ~ Attorney I.D, No, 66378 2331 Market Street Camp Hill, PA 17011 Telephone No, (717) 763-1383 Attorneys for Plaintiff VERIFICA TION I, Robert S. Ptaszek, verify that the statements made in this Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S, Section 4904, relating to unsworn falsification to authorities, Date: (2.. O<r. < 0 2. '~J<1Z,L Robert S, Ptaszek )::J ~ Q..; ~ ~~~~t - ......... '-? ' . ~~~8~ C) ~ J ~CY~:b ~~ ~ () C:i 0 C f......:.~ ~n :;::~ c:J , -ct.-I" .Tl ~ IT-if C) ry-',.., ..:;.....-..- !"o.) ....". I (11 0-' ~;: <.:.: ,~ ~'-". , :..) -' - F :C:J --.-, -, \0 ::< ROBERT S. PTASZEK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 02-6125 DARLA PTASZEK, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Debra Denison Cantor, Esquire of REAGER & ADLER, P.c. do hereby certify that I served a certified copy of the Divorce Complaint on the Defendant DarIa Ptaszek, by Certified Mail, Restricted Delivery on the 31st day of December, 2002, as is evidenced by the signature of the Defendant on the Return Receipt card attached hereto as Exhibit A. Said Complaint in Divorce was mailed to Defendant by depositing a true and exact ,copy thereof in the United States mail, first class, Certified Mail, Restricted Delivery, Return Receipt Requested postage prepaid, addressed as follows: DarIa Ptaszek 245 Meals Drive Carlisle, PA 17013 Date: '12-/05- (k - Itor, Esquire .. EXHIBIT A .. _..-<:i, . Complete items 1. 2. and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can retum the card to you. . Attach this card to the back of the mailpiece. or on the front if space permits. o Agent o Addressee OVes ONa ~~ ~e;;;tapt ",uK '( J JfS rljeffl> f)/<,'V( CPrP-lS/f, PA 17DI3 RESTI DELI 3.~ce Type rtlfled Mail 0 express Mail Registered "Ig Retum Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Pe\ivery'? (ExttB Fee) )( Ves Of? IS- ---,.~ 1()2585-00-" '~" .-' --:,."'.... - , (") 0 c: w ~;: '- "1:.' CD J:-. mPI Z Z-:-IJ zr- (j) )~ - -<..r.; r:C' :D' <- -,..~O :J 20 )>c j z =< c. ROBERT S. PTASZEK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 02-6125 DARLA PTASZEK, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE FOR WITHDRAWAl, OF APPEARANCE TO THE PROTHONOTARY: Please withdraw my appearance as counsel of record on behalf of Plaintiff Robert S. Ptaszek. Respectfully submitted, REAGER & ADLER, PC DATE: 5/11/0 > PRAECIPE FOR ENTRANCE OF APPEARANCE TO THE PROTHONOTARY: Please enter my appearance as counsel of record on behalf of Plaintiff Robert S. Ptazsek. Respectfully submitted, HOFFMEYER & SEMMELMAN DATE: ~(.$~ David C. Schanbacher 30 North George Street York, PA 17401 (717) 846-8846 Q c -0 f~~ IT!;'1 ~._' L.....-- ~L r~t" ~~( . ~c ...,..." -' or (': -:::: - (.-~'.' ......+ . ; c ~.., ~'. (;, " vs, :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA : NO, 02-6125 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE ROBERT S, PTASZEK, Plaintiff DARLA PTASZEK, Defendant REQUEST FOR PRODUCTION OF DOCUMENTS TO: David C, Schanbacher, Esquire Attorney for Robert Ptaszek Hoffmeyer & Semmel man 30 North George Street York, PA 17401 PLEASE TAKE NOTICE THAT pursuant to PaRC.P. 4003,3 and 4009, you are required to furnish at our office, on or before thirty (30) days after service hereof, a photostatic copy or like reproduction of the materials concerning this action or its subject matter which are in your possession, custody or control and which are not protected by the attorney/client privilege; or, in the alternative, produce the said matter at said time to permit inspection and copying thereof: SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS'AT'LAW 26 W. High Street Carlisle. P A 1, 2, W2 forms for Federal Income taxes for 1998 through 2003. Documentation from the civil service retirement system indicating your date of hire, benefit earned in the civil service retirement system as of July 1", 2002. Statement as of July 1", 2002 for any Thrift Savings Plan with the Federal Government and through the Naval Reserve, Documentation of your entitlement as of July 1'" 2002 in the Naval Reserve Pension Plan. 3, 4, SAlOIS, SHUFF, FLOWER & LINDSAY Attorneys for,Plaint' l, BY:J.,' ar I J, Lindsay, squire 44693 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAIDlS SHUFF, FLOWER & LINDSAY ATIORNEYSeATeLAW 26 W. High Street Carlisle, PA ROBERT S, PTASZEK, Plaintiff :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA : NO, 02-6125 CIVIL TERM : CIVIL ACTION - LAW vs, DARLA PTASZEK, Defendant : IN DIVORCE AND now, this CERTIFICATE OF SERVICE 1-7 day of ~ /M0f,~/ 2003, I, Carol J, Lindsay, Esquire, of the law firm of SAlOIS, SHUFF, FLOWER & LINDSAY, Attorneys, hereby certify that I served the within Request for Production of Documents this day by depositing same in the United States Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to: David C, Schanbacher, Esquire Hoffmeyer & Semmel man 30 North George Street York, PA 17401 SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for plaintiff By: Caro /J, indsay, Es ire 10# 4 3 26 West High Street Carlisle, PA 17013 (717) 243-6222 2 c. c: :-:::' -oi"; S2 ~.~. ;.:~: ,- (fJ -<, r-~' ~~;: b'(" ;:;, :::r -( ~ (";,) (A) C) -n ::~ ':.:"2 H) ~-:.'. : ---i ',~f) ()' .. :i:~; =< .::> (,.;> IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT S. PTASZEK, PLAINTIFF NO, 02-6125 v, DARLA PTASZEK, DEFENDANT CERTFICATE OF SERVICE I hereby certifY that I have on this date served the Plaintiff's Response to Defendant's Request for Production of Docwnents on the person and in the manner indicated below, which satisfies the requirements ofPa.R.C,P, 440. Service by United States first class mail, postage pre-paid as follows: CarolJ,Lindsay,Esquire 26 West High Street Carlisle, Pennsylvania 17013 DATE: ! 2-, /&,,0:3 Respectfully submitted, HOFFMEYER & SEMMELMAN, LLP BY: \~/l c, L. David C. Schanbacher, Esquire Attorney for Plaintiff 30 North George Street York, Pennsylvania 17401 Telephone #: (717) 846-8846 Supreme Court #: 48446 () .;:.:; ~: 2];;>' ~ . _.~ ~2;,-,,,. ~~7 :_ r-: \" ":"- ~'+-- , .. 1~' C_ -7 ...., =2 ,...., = = ...... c:> ~ o -n ..... ::c..,., "'hi "U~ :0 9=! . '-'1 ::c .,.., 40 ,,'-In c~~ ~~ -J :s -:0... s:: c::> <.n IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA ROBERT S, PTASZEK, : NO, 02-6125 PLAINTIFF v, : CIVIL ACTION - LAW DARLA PT ASZEK, DEFENDANT : DIVORCE NOTICE If you wish to deny any of the allegations set forth in this affidavit, you must file a counter-affidavit within twenty (20) days after this affidavit has been served on you or the allegations will be admitted, PLAINTIFF'S AFFIDA VII UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Th . thi' d 1hlod~ha 'd l' d ti . d f e parties to s actIOn separate on an ve conunue to lve separate an apart or a peno 0 at least two years, 2, The marriage is irretrievably broken, 3, I understand that I may lose rights concerning alimony, divisilon of property, attorney's fees or expenses if I do not claim them before a divorce is granted. 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 Pa, C,S" 4904 relating to unsworn falsifications to authorities. DATE: -.1jJ7)O'f A! ~ex.J. ~ ~S, PTASZEK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT S. PTASZEK, : NO, 02-6125 PLAINTIFF v, DARLA PT ASZEK, DEFENDANT CERTIFICATE OF SERVICE I hereby certify that I have on this date served the Plaintiff's Affidavit Under Section 3301(d) of the Divorce Code on the person and in the manner indicated below, which satisfies the requirements ofPa.R.C,P, 440, Service by first class, postage paid, United States mail addressed as follows: Carol 1. Lindsay, Esquire 26 West High Street Carlisle, Pa. 17013 DATE:~d9IDl( By:0-~['~ David C, SI~hanbacher, Esquire Attorney for Plaintiff 30 North George Street York, Pennsylvania 17401-1280 (717) 846-8846 Supreme Court No. 48446 ."0 c\) ..:,oJ' ~!) ~'': '~-.';" (-:.' '-<'~"'Cl >c Z; -J -- ,..., <= C:::l ...- L_ F; c..) C) o 'TI ::;:l n,::D -om -09 ~3o ~.r: =i~ 0-- .,.0 6rn "-' )13 :< -0 ::J: r;.? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT S, PTASZEK, : NO, 02-6125 PLAINTIFF v, : CIVIL ACTION - LAW DARLA PT ASZEK, DEFENDANT : DIVORCE NOTICE OF INTENTION TO REClUEST ENTRY OF DIVORCE DECREE TO: DARLA PTASZEK, Defendant Robert S, Ptaszek, Plaintiff, intends to file with the Court the attached Praecipe to Transmit the Record on or about August 24, 2004, requesting that a final decree in divorce be entered, DATE: 1J:l1Jotf , , BY: ~------^- L ~ David C. Schanbacher, Esquire Attorney for Plaintiff 30 North George Street York, Pennsylvania 17401-1280 (717) 846-8846 Supreme Court No, 48446 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT S, PTASZEK, : NO, 02-6125 PLAINTIFF v, : CIVIL ACnON - LAW DARLA PTASZEK, DEFENDANT : DIVORCE PRAECIPE TO TRANSMIT RE4CORD 1. Ground for divorce: irretrievably broken under 93301 (d)(1) of the Divorce Code. 2, Date and manner of service of the Complaint: December 31, 2002 by certified mail, restricted delivery, return receipt requested to Defendant, Affidavit of Service filed January 2, 2003, 3, (1) Date of execution of the Affidavit as required by 93301(d) of the Divorce Code: by Defendant: July 27, 2004 (2) Date of filing and service of the Dl:fendant's Affidavit upon the Respondent: August 2, 2004. 4. Related claims pending: The economic claims of equitable distribution, alimony, alimony pendente lite, counsel fees, costs and expenses remain pending, 5, Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached: ,2004, DATE: BY: David C, Schanbacher, Esquire Attorney for Plaintiff 30 North George Street York, Pennsylvania 17401-1280 (717) 846..8846 Supreme Court No, 48446 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT S, PTASZEK, : NO, 02-6125 PLAINTIFF v. DARLA PTASZEK, DEFENDANT CERTIFICATE OF SERVICE I hereby certify that I have on this date served the Notice of Intention to Request Entry of Divorce Decree on the person and in the manner indicated below, which satisjiies the requirements ofPa,R.C,P, 440, Service by first class, postage paid, United States mail addressed as follows: Carol J, Lindsay, Esquire 26 West High Street Carlisle, Pa, 17013 DATE: 11.}qJo~ I , BY: CL---.,v ~/1~ David C. Schanbacher, Esquire Attorney fc)r Plaintiff 30 North George Street York, Pennsylvania 17401-1280 (717) 846-8846 Supreme Court No, 48446 c s_~: =2 '" Ie:::> C7::) -4,'. , ~Z~ r....) C> o -n ::;J hi:D :.0.) fii "~, y 80 ,:;1: =fi , )-- ;j::tl ?:-1 "f:.'" :~ -r, :JJ: '::' , , O6IlSI04=3:23PM=ded=inv&appr ROBERT S, PTASZEK IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYL VANIA PLAINTIFF : NO, 02-6125 v, : CIVIL ACTION - LAW DARLA PTASZEK, DEFENDANT INVENTORY AND APPRAISEMENT OF ROBERT S, PTASZEK III Adams Road (plaintiff's Street Address Carlisle, Pa.170 13 (City, State, Zip Code) 245 Meals Drive (Defendant's Street Address) Carlisle, Pa, 17013 (City, State, Zip Code) David C. Schanbacher, Esquire (Attorney for Plaintiff) 30 North George Street (Street Address) York,Pa 17401 (City, State, Zip Code) (717) 846-8846 (Area Code) (Telephone Number) Carol ], Lindsay, Esquire (Attorney for Defendant) 26 West High Street (Street Addn~ss) Carlisle, Pa. 17013 (City, State, Zip Code) (717) 243-5513 (Area Code) (Telephone Number) Plaintiff files the folJowing Inventory and Appraisement of all property owned or possessed by either party at the time this action was commenced and all property transfermd within the preceding three years, Plaintiff verifies that the statements made in this Inventory and Appraisement are true and correct. Plaintiff understands that false statements are herein made subject to the penalties of 18 Pa.C.S, Section 4904 reI.... "'=- ""'"'~lioo '" '"'mri'~. ~-F-, ROBERT S. PTASZEK, Plaintiff .. 06ll5!()4<:.3:23PM"9kd=inv&appr ASSETS OF PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages, If an item has been appraised, a copy of the appraisal report is attached. Real property Motor Vehicles Stocks, bonds, securities and options Certificates of deposit Checking accounts, cash Savings accounts, money market and savings certificates Contents of safe deposit boxes Trusts Life insurance policies (indicate face value, cash surrender value and current beneficiaries) Annuities Gifts Inheritances Patents, copyrights, inventions, royalties Personal property outside the home Businesses (list all owners, including percentage of ownership, and officer/director positions held by a party with company) Employment termination benefits - severance pay, workman's compensation claim/award Profit sharing plans Pension plans (indicate employee contribution and date plan vests) Retirement plans, Individual Retirement Accounts Disability payments Litigation claims (matured and unmatured) MilitaryN.A. benefits Education benefits Debts due, including loans, mortgages held Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute) Other (X) I. (X) 2, (X) 3, ( ) 4, (X) 5, (X) 6, ( ) 7, ( ) 8, ( ) 9. ( ) 10, ( ) II. ( ) 12. ( ) 13. ( ) 14. ( ) 15, (X) 16, ( ) 17 (X) 18, (X) 19. ( ) 20. ( ) 21. (X) 22, ( ) 23, (X) 24, (X) 25, ( ) 26. '. 07l27104'i'9:S4AM=ded=inv&appr MARITAL PROPERTY LIST . Plaintiff lists all property in which either or both spouses have a legal or equitable interest, individually or with any other person, as of the following dates, NOTE: Liens are referenced behind each item on this list, with more specific detail itemized on the list entitled "Liabilities", Item Description Names of No, Of Property All Owners Value Comments I.a, I I I Adams Road, Carlisle, Pa. Joint 126,000.00 3/4/03 John S, Boswell appraisal I.b, Washington Mutual Mortgage Husband - 109,431.32 6/7/04 statement Loan #13380304-9 I.c, Equity Joint 16,568,58 2. 609 Southview Drive, Joint 0,00 Not exist at separation, Net sale Mechanicsburg, Pa. proceeds deposited into marital accounts, see Items #30-35 below 3, 1180 Rhoda Boulevard, Wife 0,00 Non-marital real estate. Not exist Mechanicsburg, Pa. at separation, $6,657,65 of proceeds from sale of Husband's non-marital real estate at 1385 Shuman Drive applied to payoof of mortgage in approximately February, 1995, 4,a, 245 Meals Drive, Carlisle, Pa, Wife 21,168.00 12/10/02 Janice B, Kimball appraisal 4,b, National City Mortgage Wife Unknown Wife to provide infonnation 5, Increase Value 50% interest in Wife and Unknown Wife to provide value at marriage Main Street, Churchtown, Pa, Brother & separation 6, Increase Value Plantation Island Husband 0,00 Non-marital, no increase Timeshare 7, Oak Plantation Joint Venture Joint 4,000.00 Husband's estimate 8, 1987 Chevrolet Cavalier RS Husband 4501,00 7/02 NADA Coupe 2 door 9, 1991 Chevrolet Cavalier RS Wife 1,076.25 7/02NADA Sedan 4 door 10, 1988 Plymouth Voyager SE Husband 90000 7/02 NADA Minivan II. 1985 Chevrolet S- 10 Pickup Wife 1,275,00 7/02 NADA Short Bed Truck 12, Members I ~ FCU #30266-00 Wife 3,540.53 7/1/02 statement balance Savings . 07/2S/OIlT9:S0AM=ded=inv&appr 13, Members I" FCU #30226-05 Wife 7,718.54 7/1102 statement balance Investment Savings 14, Members I" FCU #30226- I I Wife 1,309,13 7/1102 statement balance Checking 15, Members I" FCU #193893-00 Wife 1,407.58 7/1102 statement balance Savings 16, M&T #3740136548 Checking Wife & Unknown Wife to provide statement as of Mother date account opened and separation 17, PSECU #8403434312-01 Wife 0.00 Non-marital, opened after Regular Share separation 18, PSECU #84034343 I 2-04 Wife 0,00 Non-marital, opened after Moneyhandler separation 19, Members I" FCU #46544-00 Husband & 0,00 Non-marital, opened before Savings Father marriage, 20, Members I" FCU #46544- I I Husband & 0,00 Non-marital, opened before Checking Father marriage. 21. Members I" FCU #5217-00 Husband & 0,00 Non-marital, opened before Savings Father marriage. 22, Members I" FCU #52 I 7-05 Husband & 0,00 Non-marital, opened before Investment Savings Father marriage, 23, Members l't FCU #5217-1 I Husband & 0,00 Non-marital, opened before Checking Father marriage, 24, Members I" FCU # I 00725-00 Husband & 0,00 Non-marital, softball team funds, Savings James did not exist at separation Bollinger 25, 3 Shares Walt Disney Stock Wife Unknown Wife to provide infonnation regarding stock 26, Increase Value PNC #60092498 Husband 4,665,72 7/1102 statement (was #22682801) -2,825.14 9/30/94 statement 1,840,58 Increase value 27. Vanguard Index Trust - 500 Husband 10,715.30 5/28/04 statement Portfolio #99068 I 5 I 54 -2,300.00 Contributions 7/31102 - 5/28/04 Fund 40 $ I OO/mo x 23 months 8,415.30 Marital value 28, Vanguard 500 Index Fund Roth Husband 5,942,44 12/31103 statement IRA #992364635 I Fund 40 Husband to provide current statement 29, Increase Value Vanguard Health Wife 45,579.39 6/30/02 statement Care Fund #99151 18855 Fund -30,000,00 3/31199 statement pre-marital 52 15,759.39 Increase marital value 07127/0M=9: 16AM=ded09nv&appr 30. Vanguard Prime Money Market Wife 0,00 Not exist at separation Fund #009785346 Fund 30 31. Increase Value Vanguard 500 Wife 20,400,00 3/31/99 statement pre-marital Index Fund #009785346 Fund -20,000,00 6/30/00 statement withdraw 40 400,00 Non-marital portion 2,142,60 6/30/02 statement -400,00 Non-marital portion U'42,60 Increase marital value 32, Vanguard Life Strategy Wife 4,799,96 6/30/03 statement Conservative Growth Fund IRA Wife to provide current statement #009785346 Fund 724 33, Increase Value Janus Mercury Wife Unknown Current statement Wife to Fund #203286772 Fund #48 provide -12,000,00 3/9/99 statement of contribution Unknown Increase Value 34, Increase Value Janus Twenty Wife Unknown Current statement Wife to Fund #203524031 Fund #43 provide -2,500,00 4/27/99 statement of contribution Unknown Increase Value 35, Increase Value Janus Growth & Wife 0,00 No increase value Income Fund #203524031 Fund #40 36, Civil Service Retirement Husband 67,000,00 Harry Leister valuation NEED REPORT 37, Civil Service Retirement Wife Unknown Wife to provide information on amount received & disposition of funds 38, Marital Poriton Army National Husband 17,000,00 Harry Leister valuation Guard Retirement Defined NEED REPORT Benefit Plan 39, SERS Wife 914,76 3/5/03 letter from SERS with 6/20/02 value 40, Thrift Savings Plan TSP-8-B Husband 25,9111.78 3/31/04 statement - 5,0011.02 Contributions 7/2/02 - 3/31/04 20,910,76 Marital value 41. Thrift Savings Plan TSP-U-8 Husband 5,630,25 3/31/04 statement -4,84111 Contributions 7/3/02 - 3/31/04 789.12 Marital value 42, Members I"FCU#157321 Husband 0.00 Non-marital, son's account and Wife for son LIABILITIES Plaintiff lists all liabilities of either or both spouses along with any other person. . Item No, I. Description Of Liability See mortgage listed above Names of Debtors Amount 07/27J04~:16AM=ded=inv&appr Comments , 6/8/04=9:114 AM9Ied=incexp IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT S, PTASZEK, : NO, 02-6125 PLAINTIFF v. : CIVIL ACTION - LAW DARLA PTASZEK, DEFENDANT CERTIFICATE OF SERVICE I hereby certifY that I have on this date served the Income and Expense Statement on the person and in the manner indicated below, which satisfies the requirements ofPa,R.C,P, 440, Service by first class, postage paid, United States mail addressed as follows: Carol J, Lindsay, Esquin: SAlOIS, SHUFF, FLOWER & LlNDSA Y 26 West High Street Carlisle, Pennsylvania 17013.2922 Respectfully submitted, HOFFMEYER & SEMMELMAN, LLP DATE: 7J~J{)Y I BY: ,.~~LL--- David e:-Schanbacher, Esquire Attorney for Plaintiff 30 North George Street York,Pennsylvania 17401 Telephone #: (717) 846-8846 Supreme Court #: 48446 8 (') ~,::; !':,"- I , ~- =:< '" = 1..:.::;0 ~- ~ <- e- j'~:':': (...) o '.-< n:,T:"l'1 1_ r- -r;1nl -."6) c5 . ,'J( 1 -r i'i :ij cS~~ 5:;,' ':'" ==< -"0 3" N ...- 7/27/04=9:49 AM=ded=incexp ROBERT S, PTASZEK, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF : NO, 02-6125 v, : CIVIL ACTION - LAW DARLA PTASZEK, DEFENDANT INCOME AND EXPENSE STATEMENT OF ROBERT S. PTASZE][( III Adams Road (Plaintiffs Street Address Carlisle, Pa, 17013 (City, State, Zip Code) 245 Meals Drive (Defendant's Street Address) Carlisle, Pa. 17013 (City, State, Zip Code) David C, Schanbacher, Esquire (Attorney for Plaintiff) 30 North George Street (Street Address) York, Pa, 17401 (City, State, Zip Code) (717) 846-8846 (Area Code) (Telephone Number) Carol J. Lindsay, Esquire (Attorney for Defendant) 26 West High Street (Street Addr,ess) Carlisle, Pa, 17013 (City, State, Zip Code) (717) 243-5513 (Area Code) (Telephone Number) INSTRUCTIONS TO BOTH PARTIES: You are required by law 10 fill in this form completely and to attach to it copies of your most recent federal income tax return and either copies of your paystubs for the preceding six months or a statement from your employer(s) showing ,unounts of your grross pay, net pay and each category of withholdings for the preceding six months, You will also be required at the conference or hearing to document your income from all sources and your expenses and to explain your computations, If you fail to comply with any of these requirements, you might be denied support or alimony, be prevented from submitting evidence or testimony, or be held in contempt of COlllt, I , 7/27104=9:49 AM=ded=incexp INCOME Employer: Department of the Navy * Employer's Address: 5450 Carlisle Pike, P,O, Box 2010, MechanicsbllJrg, Pa, 17055-0787 Job Title: Pay Period: Information Technology Specialist Filing status claimed for federal payroll withholdings: Single Nwnber of exemptions claimed for federal payroll withholding taxes: One GROSS PAY PER PAY PERIOD -Bi-weekly $2,749,60 ITEMIZED PAYROLL DEDUCTIONS: Occupational Tax Federal Withholding Social Security Local Wage Tax State Income Tax Unemployment Union Dues Health Insurance Retirement (mandatory payment only) Retirement (voluntary payment) Savings Bonds Credit Union Life Insurance Medicare Child Support TOTAL WITHHOLDINGS: TAKE HOME PAY PER PAY PERIOD: OTHER INCOME: $ .39 454.98 43,99 84.41 1.62 69,68 (Begins 9/19/04) 192.47 247.46 39,87 415.38 $1,550.25 $1,199.35 Monthly Yearly Interest Dividend Pensions Annuities Social security Rents Royalties Expense Account Gifts 229,00 132,00 * National Guard income ended on 6/15/04, Awaiting orders terminating National Guard affiliation, 2 7/27/04=9:49 AM=ded=incexp Unemployment Compensation Worker's Compensation Income tax refunds 2,455.00 Support or alimony Commissions Tips Bonuses or profit sharing distributions Auto allowances Other allowances (meals, housing, etc,) Monthly Yearly TOTAL OTHER INCOME: $ $2,816.00 WHAT CONTRIBUTION DO PERSONS OTHER THAN YOURSELF MAKE TO THE HOUSEHOLD'S EXPENSES? None, EXPENSES INSTRUCTIONS: All expenses must be converted into monthly amOlmts and totaled, To convert from weekly to monthly amounts, multiply by 4 1/3 (4.33), For fluctuating expenses like clothing or utilities, add up all bills for the last twelve months and divide by 12, PARTI: WORKRELATEDEXPENSES (list unreimbursed amounts only) TYPE Military Clothes MONTHL Y $25,00 TOTAL: $25,00 3 PART II: MONTHLY HOUSEHOLD EXPENSES (Number of people living in household: I) MortgagelRent Maintenance and repairs $986,32 40.00 Utilities Electric Gas Oil Water Sewer/Septic Garbage collection Telephone Cable TV 57.00 54.00 8.00 18.00 35.00 38.00 125,60 57,82 29,00 110,00 $1,558,74 Real estate taxes Timeshare Taxes & Maintenance Fees Homeowners or renters insurance Groceries and household supplies TOTAL HOUSEHOLD EXPENSES: PART III: OTHER MONTHLY EXF'ENSES Taxes Income (not withheld) Other (list) SELF Automobile Payments (balance owed $) Insurance Fuel Maintenance and repair License and registration 61.00 110,00 30,00 7,00 4 7127/04dJ:49 AM=ded=incexp Public Transportation Insurance Life Accident Health Other ( specify) Medical (expenses not covered by insurance) Doctor Dentist Orthodontist Hospital Medicine Special needs (glasses, braces, orthopedic devices) - list: Education (expenses not covered by scholarships, grants, loans, or other reimbursement) Private or parochial school tuition & fees College or trade school tuition & fees Room and board Religious training Books and supplies Lunches Loans (credit cards, charge accounts, credil unions, etc,) - list: Balance Owed Clothing Laundry/dryc1eaning Barberlhairdresser Household help Child care Memberships Warrant Officers Association 7/27/04==9:49 AM=ded=incexp SELF 7.15 See payroll deduction Unknown at this time Unknown at this time 10,00 92,00 40,00 9,00 3,33 5 Newspaper/magazineslbooks Entertainment Children's allowances Vacation Gifts and toys Charitable contributions Legal fees Other child support/APL Alimony Other (list) SELF 10,00 15,00 10,00 250,00 50,00 43.50 325.00 415.38 TOTAL EXPENSES FOR PART III: $1,488.36 PART IV: DIRECT CONTRIBUTIONS FROM PERSONS FROM WHOM SUPPORT IS REQUESTED 7/27/04=9:49 AM=ded=incexp List below any payments and which the person from whom support is requested makes on a regular basis which directly or indirectly benefit the people for whom support is being requested (for example, payment of health insurance for dependents), Proof of expenses and payments must be provided at the conference or hearing, Type of Payment Amount Paid Frequency of Payment (weekly, monthly, etc,) 6 6/8/04=9:04 AM=ded=incexp PROPERTY OWNED DESCRIPTION VALUE H W OWNERSIDP J Checking account Please see the Inventory and Appraisement filed simultaneously, Savings accounts Credit Union Stockslbonds Real Estate Other Total INSURANCE Blue Cross Other Medical Blue Shield Other Health! Accident Disability Income Dental Other COVERAGE COMPANY POLICY NO, Hospital H=Husband; W=Wife; J=Joint; C=Child VERIFICATION I, Rnh<>rt- S Pt-"",,,,k , veritY that the facts set forth in 1he foregoing Income and Expense Form, including all attachments thereto, are true and correct to the best of my knowledge, information and belief, I understand that false statements herein are made subject to the penalties: of 18 Pa. C,S. Subsection 494 relating to unsworn falsification to authorities. Date: 7/;17 Jol/ I , -~~,~ ROBERT S, PTASZ , amtiff 7 .,,~~ I , 13/ fcq ~O 21 0 00 0 c.,:-; 0 ;." 14 ) 00 15b () \')(, 16b 0 00 17 0 .:..)0 18 0 cc 19 0 00 20b 0 6,'.... 21 0 -ct 22 b c:.'f - I E 1040 Q~parimeJ'lt of, the Treasl"lry-tntemal Revenue Service ~@O3 1(1) " lJ.S; Individual Income Tax Return IRS Use Only...,.-Oo not write or staple In this space. ~ r For the year Jan. 1-Dec. 31, 2003, or other tax year beginning , 2003, endin9 ,20 " OMS No. 1545-0074' Label YRU~ ~r:t:+me ~d ~nitial Last name Your social security number (See L fTAS'ZE.k !fl 'f2; '6"f'f2 A instructions B If a joint return, spouse's first name and initial Last name Spouse's social security number on page 19.) E Use the IRS L Home addr~s (number ~J street). If you have a P.O. box, see page 19. I Apt. no. ... Important! ... label. H II' A "~lf K Otherwise, E please print R z~o;n~ pr~t Office'fit and liP 7o~e( 3Y~ ~;r; ~Oqign address, S~l page 19. You must enter or type. E I your SSN(s) above. Presidenlial ~ You Spouse Election Campaign "",,' Note~ CheCking "Yes" will not change your tax, or reduce your refund. (See page 19.) 00 you, or your spouse if filing a joinl relum, wanl $310 go 10 Ihis fund? , , ,.. DYes DNo DYes DNo 1 [gJ SIngle 4 0 Head of household (with qualifying person). (See page 20.) If 2 0 Married filing jointly (even if oniy one had income) Ihe qualifying person is a child but not your dependent, enter 3 D, Marri~ filing separately. Enter spouse's SSN. above this child'S name, here. .... and full name here, .. 5 0 Quaiifying widow(e~ with dependent child. (See page 20,) 6a, ,0 Y Ou rsel': If YO,ur parent (6r someo'ne ,Slse) can ~Iail" yo~ as a c~e~ndent pn his clr her lax } No. Of::b axes -', " ,- ," 'k' - check~o"" I ' return, do not chac box 6a . . . . . . . . . . . . . . . 6a arid-&b --.--.. b 0 Sp' , No, of ~hlldren on Go.Who: . lived with you . did not live with you due to dlvor<e orsepa..atkin (... page 21) De~onllc not .ntei'9cf aboVe .,...-- kkt ,numblrS [i] Ph llnes- , above ~ 'f5"("f3 ( 22'1 3 I T I Filing Status Check only one box. Exemptions If more than five dependents, see page 21. Income Attach Forms W-2 and W-2G here. Also attach Fonn(s) 1099-R jf tax was withheld, If you did not get a W-2, see page 22. Enclose. but do not attach, any payment. Also, please use Fonn 1040-V, Adjusted Gross Income ause, . , " l,lependenls: (2) Oepenilent's (3) O,penilenfs tWWqualilying 1-. soclatsecurity number relationship to Chil:l:rchlld~, (1) First nam. Last name , "ou credijseerialia21 0 0 , 0 , 0 0 ,-,-::-:::-::..>' c I ~ Cat. No. 113208 , ~ d TOlal number of exemptions c1all11ed . , , . 7 Wages. saiarles, lips, ete. Attach. ronn(s) W-2 Sa Taxable interest. Allach Schedule B if required ' , 1:i, :T~-~x.e:lri~ in~erest Do not include on line Ba., . 9a OrdinarY diVidends. Allach Schedule B if required b" Quaiified divideDds (see page 23) '.' ~ 0 0,,' 10 T<!J<able refunds, credits. or offsets of _~~~ and local income laxe" (see page 23) 11 Alimony received """.""", 12 Business Income or (ioss), Attach Schedule C or C-EZ , , , , . , 13<1 Capital gain or Ooss), Attach Schedule 0 if required. If nol required, check here ~ Ii If box on 13aischecked, enter post-Mey 5 capitai gain distributions 113b I 14 Other gains or (losses). Attach Form 4797. , . , , , , , . , , . , . 15a IRA dislril1utions , , ~ .?~ b TaxebiEl amount (see page 25) ,16a' Pe~SIQns. and annuilies l:!!!J . 0 LJ b TaxabiEl amount (see page 25) 17 . Renlal real estale, royalties. partnerships. S corporations, trusts, el", Allach Schedule E 18 ram, income ot (loss), Allach Schedule F , , . , 19 Unemployment compensalion , . . ..., 20a sciclal s"l'urity benefits , I 20a I C I 0 ~ I b TaxablEl amount (see page 27) 21 Other income, Lisl type and amounl (see page 27) ..,.., u...,. u.... u u u u. u.....' 22 Add the amounts in the far ri ht column for lines 7 through 21. This is, your total income ... 23 Educator expenses (see page 29) 23 00 24 IRA ctectuction (see page 29) . 24 0 0 n 25 stUdent loan interest deduction (see page 31). 25 ..": 0' 28 Tullion and fees deduction (see page 32) , 26 0 Q:) 27 Moving expenses, Attach Fonn 3903 27 ":; C (I 28_, One-half bf self-employment tax. Attach Schedule SE 28 0 C {) 29 Self;..employed health insurance deduction (see page 33) 29 ,-" C' 30 Self~enjployed SEP, SIMPLE, and qualified plans 30 - .....,.'- 31 Penalty on early withdrawal of savings. . . .. 31 .., ,'.1 '::: 32a Alimonypaid b Recipient's SSN ~ 'lOr: 4'1. : '+'13' 32a -;: (.2 C ,or 33 Add lines 23 through 32a , , . , , 34 Subtract line 33 from line 22. This is your adjusted gross income For Disclosure, Privacy Act, and Paperwork Reduction Act Notice, see page 77. L_ C-, i:c -':1 41 +1'-1' :n Form 1040 (2003) Form. 1 040 (2003) Tax and Credits Standard Deduction for- . People who 37 checked any box on line 38 36a or 36b or-39 who can be claimed as a dependent, see page 34. . All others: Single or Married filing separately, $4,750 Married filing jointly or Qualifying widow(er), $9,500 Head of household, $7,000 Other Taxes Payments If you have a qualifying child, attach Schedule EIC. 53 54 Amount frolTl line 34 (adjusted gros~income) . . . ..;.. ~:heck { 8 ;:~u::r:::;:~f~:~o~:~~:~a~ ~~~~39, 8 :::::::} ::k:~ 36a b If you are married filing separately and your spouse ~emizes deductions, or 0 YQUW~re~dual-s~~usalien, seepage 34 ~ndcheckh~~~;.. .......; .... ... ... .... .... ~:36~ Itemized deductions (from Schedule A) or your $tandard ded"'ction (see left margin) , , Subtract line 37 from line 35 , , , If line 35 is $104,625 or less, multiply $3,050 by the total numbe" of exemptions claimed on line 6d:'lf line 35 is over $104.625, see the worksheet on page ~15, , , , Taxable Income, Subtract line 39 from line 38, If line 39 Is mom than line 38, enter -0- Tax (see page 36). Check II any tax is from: a 0 Form(s) 8814 b 0 Form 4972 A1temative minimum tax (see page 38), Attach Form 6251 , Add lines 41 and 42 , , , , , , . , , , Foreign tax cred~, Attach Form 1116 II required , , , Cred~ for child and dependent care expenses, Attach Form 2441 Cred~ for the elderly or the disabled, Attach Schedule R , EducatiOn credits, Attach Form 8863 , . , , , , Retirement savings contributions credit. Attach Form 8880 Child tax cred~ (see page 40), , , . , , . Adoption credit. Attach Form 6839 , , Credits from: a 0 Form 8396 b 0 Form 8859 , Other credits, Check applicable box(es): a 0 Form 3800 b 0 Fcrm 8801 c 0 Specify Add lines 44 through 52, These are your total credits Subtract tine 53 from line 43. If line 53 is more than line 43, entl~r~O';;;. Self-employment tax. Aitsch Schedule SE """,."" Social security and Medicare tax on tip income not reported to emplarer, Attaeh Form 4137 Tax on qualified plans. including IRAs. and other tax-favored accounts, Att8ch Forrn 532gl1 required Advance earned Income cred~ payments from Form(s) W-2 , Household employment taxes, Attach Schedule H . , , Add lines 54 through 59, This is your total taX , , . , Federal income tax withheld from Fo s W: and' 099' ~~ , 2003 estimated tax payments and amount applied from 2002 return Earned lne<>me credn (EIC) . . . . , , , , , Excess social security and tier 1 RATA tax withheld (see page 58) Addijiom;1 child tax credit Attach Form 8812 , , ... , Amount paid. wijh request for extension to file (see page 56) Other piy,nents from: 0 0 form 2439 b 0 Form 4136 c 0 Form 8885 , Add lihes 61 thrQlJgh 67, These are your total payments ! i 73'f 31 nq 13 'f0 35 38a 40 41 42 43 44 45 46 47 48 49 50 51 62 44 47 48 49 50 51 J 05"0 00 L3' 2 'to :%~ 00 o 00 5'1 {;G 00 o 00 H' 00 o 00 o 00 o 00 000 o 00 ., GG 00 (;,+21 )"0 2'1, ,0 2'1-<;, ,0 Refund 69 If line 68 Is more than line 60. subtract line 60 from line 68, This ill the amount you overpaid Direct deposit? 70a AmOunt of fine 69 YQIJ wam refunded to yo", , , , , . , . , . ... See page 56 .. b Routing number .. c Type: 0 Checking 0 Sa~ngs ;~, f~~~ Jg~' .. d Account number :r=o=IIJ 71 Amount of line 69 you want applied to your 2004 estimated tax .. I 71 0 0 72 Amo",nt you owe, Subtract line 68 from line 80, For details on how to pay. see page 57 .. 73 Estimated tax penalty (see page 58), , , , , , , , I 73 Do you want to allow another person to discuss this ratum with the IFlS (see Page 58)? 0 Yes. Complete the following. jgJ'~o ~~~'e'~ ~~~ne ~.. () ~~~~~tffi~~on~,cItfIj Under~8ItiM;...Qr ~u:ry,.I~lare th~I..hav~exam~this .rettJmand aecornparlyingscheclu48$ 8nd'~,:.an~'tQt~:bW,otfTIYkric)WI~~'~~' belief, they are true, correct; and compl8te, Oeclaration of pre parer (other than taxpayer) is basedOrl IIlf1i'ifoltnaUOn of whichprepai"ei'has anyknow:l<<fgEl" Your signature Date Your occupation Daytime phone number ~ Spouse's signature. If a ioint return, both must sign. Date Spouse's occupation Amount You Owe Third Party Designee Sign Here Joint return? See page 20. Keep a copy for your records. Paid Preparer's Use Only 52 .. 55' 68 57 68 59 60 61 62 63 64 65 88 67 88 61 62 63 64. 65 88 67 ........ ..... ...... Preparer's ~ signature , Finn's name (or ~ yours if self-employed), address, and ZIP code Date FOI1l1 1040 (2003) Department of the Treasury Internal Revenue Service (1) Narnelslshownon~o:b~~+ S, fTe1$uk Medical . Caution, Do not include expenses reimbursed or paid by others. and 1 Medical and dentai expenses (see page A-2) Dental 2 Enteramount from Fonn 1040, line 35 2 Expenses 3 Multiply line 2 by 7,5% (,075), . . , . , 3 4 Subtract line 3 from line 1. If iine 3 is more than line 1, entllr -0- . 5 State and local income taxes 5 6 Real estate taxes (see page A-2) 6 7 Personal property taxes . , , . . , , , " 7 8 qlher tax"s. List type and amount ~ ..Qj,.':.....!(l,... .l,:/: ,.":1'::.."...,.""""""""".."..",,.., ,( ~'" ~,o Add lines 5 throu h 8 . . , , , . . , , , , , Home mortgage interest and points reported to you on Form 1098 Home mortgage interest not reported to you on Form 1098. If paid to the person from whom you bought the home, see page A-3 and show that person's name, identifying no., and address ~ ~"".'~'" SCHEDULES A&B (Form 1040) Taxes You Paid (See page A-2.) Interest You Paid (See page A-3.) -Note. Personal interest is not deductible. Gifts to Charity If you made a gift and got a benefit for it. see page A-4. Casualty and Theft Losses 19 Job Expenses 20 and Most Other Miscellaneous Deductions 21 (See 22 page A-5.) 23 24 25 26 Other 27 Miscellaneous Deductions Total 28 Itemized Deductions - Schedule A-Itemized Dedluctions OMS No. 1545-0074 (Schedule B is on back) ~(Q)03 Attachment Sequence No. 07 Your social security number 18 r: '(-2: g't'f2 ~ Attach to Fonn 1 040. ~ See Instructions for Schedl.des A and B (Form 1040). 9 10 11 o Do '1-73) aii' 12 Points not reported to you on Form 1098. See page A-3 for special rules , . , , , , . . , , , .. 12 Investment interest. Attach Form 4952 if required, (See page A-4.) , , , . . . , , , . , , , " 13 Add lines 10 through 13 , , , , . . , , , , , Gifts by cash or check, If you made any gift of $250 or more, see pageA-4 , ,..",'.", Other than by cash or check, If any gift of $250 or more, see page A-4, You must attach Form 8283 if over $500 Carryover from prior year Addlines15through17 , , . . , , , , . . . +3 1)'0 6 13 14 15 16 17 18 Casualty or theft loss(es), Attach Form 4684, (See page A-S,) . Unreimbursed employee expenses-job tr1\vel, union dues, job education, etc, Attach Form 2106 or 21 06-EZ if required. (See page A-5,) ~ ......,....,..,.............. o 00 Tax preparation fees. . . , , . . . , , . . Other expenses-investment, safe deposit box, etc, List type and amount ~........,..........,..,................., Add lines 20 through 22 , , . . Enter amount from Fonn 1040, line 35 24 Multiply line 24 by 2% (.02) . , , .:15 Subtract line 25 from line 23. If line 25 is more than line 23, enter -0-'. , , , Other-from list on page A-6, List type and amount ~ ,.........................,.., o 00 .----------.--..-.-.-----------....------...------.....--------...---------......-------....... o 00 Is Form 1040, line 35, over $139,500 (over $69,750 if marriEld filing separately)? IRl No. Your deduction is not limited. Add the amounts in the far right column } for lines 4 through 27. Also, enter this amount on Form 1040, line 37, D Yes, Your deduction may be limited. See page A-a for the amount to enter. Fot Paperwork Reduction Act Notice, see Form 1040 instructions. Cat. 1\10. 11330X Schedule A (Form 1040) 2003 !.i..,d H..... iljl~ :~~ ~".I DEFENSE FINANCE AND ACCOUNTING SERVICE MILITARY LEAVE tlND EARNINGS STATEMENT 10 NAME (LAST. FIRST. Mil PTASZEK ROBER STANL Y ENTITLEMENTS TYPE AMOUNT A BAS I C P Y 1 .30 B C D E F G H I J K L M N o DEDUCTIONS TYPE INC AX FICA TAX STATE INC TAX SGU TSP CONTRIBUTION AMOUNT 74.2 54.72 18.20 7.15 64.38 TYPE PERIOD COVERED HK T 0 06 SUMMARY AMOUNT +AMT FWD +TOT ENT 71 30 -TOT OED B. -TOT ALMT =NET AMT 4 6.5 -CR FWD =EOM PAY RET PLAN TAX YTD 56 47 TAX YTD 3 CURRENT 0% .00 TOTAL Bf LEAVE FICA TAXES PAY DATA 71 BAa TYPE Thrif1 BASE Savings Plan (TSP) 9% REMARKS YTD ENTmE 19964 ~o YTD DEDUCT 7'06 85 YOUR CHECK WAS SENT TO: MEMBERS 1ST FCU 2313B2241 MECHANICSBURG PA 17055-4B AMOUNT: $496.5B ACCOUNT NUMBER: 5217000 ACCOUNT TYPE: SAVINGS COM~ANY CODE: C04059 DIRECT DEPOSIT DATE: 06/15/04 * AS OF 01 .~UL 03, 153 HIGH TEMPO DEPLOYMENT DAYS ACCRUED SINCE 1 OCT 00 (OR SINCE ENTERING MILITARY SERVICE) TOTAL PERFORMANCE FY 04: UTA OB AFTP 00 ET 00 ATA 00 ~PT 00 AAUTA 00 AANT 00 RMA 00 SUP lOT TNG 00 MCOFT 00 RMAM 00 AT/ADT lBO FHDA 000 INACTIVE DUTY TRAINING 04 ~UN 04 2 05 ~UN 04 1 05 ~UN 04 2 INACTIVE DUTY TRAINING 06 ~UN 04 1 06 ~UN 04 2 YOUR CURRENT STATE CLAIMED IS: PENNSYLVANIA SERVICEMEM8ER GROUP LIFE INSURANCE COVERAGE: $110,000 PLEASE VERIFY YOUR STATE OF LEGAL RESIDENCE FOR STATE INCOME TAX PURPOSE. CONTACT YOUR PAYROLL OFFICE TO FILE A NEW 00 FORM 205B TO CHANGE/ESTABLISH THE CORRECT STATE IMMEDIATELY. -ALL RESERVISTS ARE REQUIRED BY LAW TO PROVIDE AND ANNUALLY UPDATE THEIR CIVILIAN EMPLOYMENT RELATED INFO. USAR SOLDIERS CAN ENTER THEIR DATA AT: WWW.HRC.ARMY.MIL. ARNG SOLDIERS SHOULD REPORT THEIR DATA AT: HTTPS: WWW.DMDe.OSD. Mt L/G~ARD-RESERVEPORTAL. DFAS Form 702, Jan 02 www.dfas.mil DEPARTMENT OF DEFENSE I. PAY PERIOD END 06/12/04 CIVILIAN LEAVE AND EARNINGS STATEMENT 2. PAY DATE Visit the DFAS Web Site at www,dfas.mil 06/18/04 3. NAME 4. PAY PLANIGRAD€{STEP 5_HOVRtV/llAllYRATE 6. BASIC OT RATE 7,BASICPAV lOCALITY "'OJ ADJUSTEl> BASICP...Y PTASZEK ROBERT S GS 12 07 34,37 34,37 71729,00 ._socSECNO 9. LOCAlITV "I. 10. FLSA CATEGORY 11. sea LEAVE 12 MAX LEAVE CAJIf!Y DYEl'l r]' LEA;lv;A~~;05 8442 10,90 E 10/31/77 240 I.. F1NANCIAlINSTITI,JTION - NET W 15. FINANCl.o.llNSTITUTION - ALLOTMENT.! 16 FINANCIAL INSTITUTION. AlLOTMENT U MEMBERS 1ST FCU 17. TAX MARITAL EXEMPTIONS "'CO"L IB,TAX MAflITAL EXEMI'TIONS AOO"L TAXING AUT_,T'I 19. CUMULATIVE RET,AliMENT 20_ MiliTARY DEl'OSIT STATUS STATUS FEO S 1 422446 S S MIDDLETON TS CSRS: PA S 25432,06 " CURRENT YEAR TO DATE " GROSS PAY 2749,60 17256,90 TSP DATA TAXABLE WAGES 2502,14 16103,46 9% NONTAXABLE WAGES -337,08 TAX OEFERRED WAGES 247.46 1490,52 DEDUCTIONS 1478,56 7259,39 AEIC NET PAY. 1271.04 9997,51 CURRENT EARNINGS TYPE ~OURS/DAYS AMOUNT TYPE HOURS/DAYS AMOUNT TYPE HOURS/DAYS AMOUNT REGULAR PAY 80.00 2749,60 DEDUCTIONS TYPE CODE CURRENT YEAR TO DATE TYPE CODE CURRENT YEAR TO DATE CHLD SUP,GRN 415.38 1246.14 FEHB -280.90 MEDICARE 39.87 255.11 PRE FEHB COL -56.18 RETIRE, CSRS 1 192,47 1207.98 TAX, FEDERAL 454,98 2594,00 TAX, LOCAL 422446 43..99 219.95 TAX, LOCAL 421080 38.47 TAX,LOC OCC 421080 10.00 TAX, STATE PA 84,41 534,30 TSP SAVINGS 247.46 1490.52 LEAVE TYPE PRIOR YR ACCRUED ACCRUED USED USED DONA TED/ CURRENT USE-LOSE! BALANCE PAY PO YTO PAY PO YTO RETURNED BALANCE TERM DATE ANNUAL 36,46 8,00 45,00 20.00 61.46 SICK 739,98 4,00 23.00 4.00 758.98 MILITARY 120,00 120,00 HOLIDAY 16,00 36,00 LWOP 10.00 MIL LWOP 430,00 REMARKS YOUR PAYROLL OFFICE IDENTIFICATION NUMBER IS 97380600, ENROLL IN TSP - DEADLINE FOR OPEN SEASON IS JUNE 30, BUY US SAVINGS BONDS. FERS EMPLOYEES: TSP LIMIT FOR 2004 IS a13,OOO, CHECK YOUR TSP YTO TO ENSURE YOU DO NOT LOSE MATCHING CONTRIBUTION, NEXT TSP OPEN SEASON IS 4/15-6/30/04, I 'h...............__............. ......u.__...._...............................____....__.__.u........_..............__...__.__.........__.__........___._._._._._________..._, THIS REPORT CONTAINS INFORMATION SUBJECT TO THE PRIVACV ACT OF 1974 AS AMENDED ...mnm__...............mmmnu.u..........u.......nn.nmmnm.................................mn......_.._.................. Dl'AS FORM I (It€V 11tH l 07127/04""9: 16AM=ded=inv&appr IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT S, PTASZEK, PLAINTIFF : NO, 02-6]25 : CIVIL ACTION - LAW v. DARLA PTASZEK, DEFENDANT CERTIFICATE OF SERVICE I hereby certifY that I have on this date served the Inventory and Appraisement on the person and in the manner indicated below, which satisfies the requirements ofPa,R.C,P, 440, Service by first class, postage paid, United States mail addressed as follows: Carol], Lindsay, Esquire SAlOIS, SHUFF, FLOWER & LINDSAY 26 West High Street Carlisle, Pennsylvania ]7013-2922 Respectfully submitted, HOFFMEYER & SEMMELMAN, LLP DATE: '7/J q /0 If I . BY:C'\-...pC{ , J.... David C, Schanbacher, Esquire Attorney for Plaintiff 30 North George Street York, Pennsylvania] 7401 Telephone'#: (717) 846-8846 Supreme Court #: 48446 ". ;;~.. =2 ':':' .:::- ", ((~~ ~- ( t;~".; (,~) o \".l ~ o '11 ::;:J J~'h ;IJ 'T; r:;:J ~~) "1':,1 ~~'5 rTl IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA ROBERT S, PTASZEK, : NO. 02-6125 PLAINTIFF v, : CIVIL ACTION - LAW : DIVORCE DEFE~~T : COUNTER-AFFIDAVIT UNDER 93301(>>) OF THE DIVORCE CODE DARLA PT ASZEK, 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree, (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two (2) years. (ii) The marriage is not irretrievably broken, 2, Check either (a) or (b): (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted, /(b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights, I understand that in addition to checking (b) above, I must a~so file all of my economic claims with the Prothonotary in writing and serve them on the other party, IfI fail to do so before the date set forth on the Notice ofIntention to Request Divorce Decree, the divorce decree may be entered without further delay, I verifY that the statements made in this Counter-Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S, &4904, relating to unsworn falsification to authorities. DATE: 6' / s I O~ I ~q,p~~ DARLA PT ASZEK, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ~Y CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. r-' "'" c,;:;:1 ..,.. ~' C:. u") o L. ~ pi" ::':~::: o -n .-1, '''r:.-n f.iT'.....:: rr1 -n~ ;~~<~J, :"1:-1';' 'J-" ~;c...C) ;<'SCn <\ ~2: (,,) (..n ROBERT S. PTASZEK, Plaintiff THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 02 - 6125 CIVIL DARLA PTASZEK, Defendant IN DIVORCE TO: David C. Schanbacher , Attorney for Plaintiff Carol J. Lindsay , Attorney for Defendant DATE: Monday, August 9, 2004 CERTIFICATION [ ] I certify that discovery is complete as to the claims for which the Master has been appointed, OR IF DISCOVERY IS NOT COMPLETE: la) 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. (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. Discovery will be complete by September 1, :W04 as Plaintiff is providing Defendant with the pension documents as requested per Defendant's Certification of Discovery. JJ 11'1 / t/<j DATE {~ c., j /l--. COUNSEL FOR PLAINTIFF (>() COUNSEL FOR DEFENDANT ( ) David C. Schanbacher, Esquire #48446 PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. NOTE: AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IM~1EDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. xc: Carol J. Lindsay, Esquire Divorce Master Elicker (') .d';:'_ :.",:'1 t,:;) I',: !",,) C'.) 1"1 (,...:.' SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS.AT.LAW 26 W. High Street Carlisle, PA II ROBERT S. PT ASZEK, Plaintiff :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 02-6125 CIVIL TERM : CIVIL ACTION - LAW DARLA PT ASZEK, Defendant : IN DIVORCE NonCE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action, You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, CUMBERLAND COUNTY BAR ASSOCIA nON 32 BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for Defendant ) I By: L SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS.ATeUW 26 W. High Street Carlisle, PA II ROBERT S. PTASZEK, Plaintiff vs, DARLA PT ASZEK, Defendant :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-6125 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE ANSWER AND COUNTER CLAIM TO COMPLAINT IN DIVORCE Now comes Daria Ptaszek, Defendant above and answer the Complaint in Divorce with new matter as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. Admitted. 9. Admitted. 10. Denied. 11. No answer required. WHEREFORE, Defendant respectfully prays this Honorable Court to Divorce Plaintiff from Defendant. 2 SAIDIS SHUFF, FLOWER & LINDSAY ATIORNEYS.AToLAW 26 W. High Street Carlisle, PA COUNT 1 EQUITABLE DISTRIBUTION, 12. Admitted, 13. Admitted. 14. Admitted. 15. Admitted. WHEREFORE, Defendant prays this Honorable Court to equitably divide the parties' property, COUNTER CLAIM - ALIMONY 16. Defendant is without income sufficient to provide for her reasonable needs. WHEREFORE, Defendant prays this Honorable Court to enter an award of alimony. SAlOIS, SHUFF, FLOWER & LINDSAY Attorneys for efendant 7 I ./ By: e 3 Carol.f. IO#4M 26 West High Street Carlisle, PA 17013 (717) 243-6222 ire ~i-~ ~1 "lq. (;-\ l.) -- Y0 -- 1 IV 'l 'b C). ~ ----' 11:- () -- " a: _. CY I'::) -- .>-.J ~ c, \l'- 0 r- - OJ .t::: ~ Q ~ "'-J C> "'---'-.. SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS-ATeLAW 26 W. High Street Carlisle, PA ROBERT S. PTASZEK, Plaintiff vs. DARLA PT ASZEK, Defendant AND now, this :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-6125 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE 7 day of '/tta1/ctf 2005, I, Carol J. Lindsay, Esquire, of the law firm of SAlOIS, SHUFF, FLOWER & LINDSAY, Attorneys, hereby certify that I served the within Answer and Counter Clairn to Complaint in Divorce this day by depositing sarne in the United States Mail, First Class, Postage Prepaid, in Carlisle, PEiflnsylvania, addressed to: David C. Schanbacher, Esquire Hoffmeyer & Semmel man 30 North George Street York, PA 17401 SAlOIS, SHUFF, FLOWER & LINDSAY Attorney~. fo Defendan1 "I / 141) Car J. indsay, Esquire 10 93 26 West High Street Carlisle, PA 17013 (717) 243-6222 By: ~ r ~l 4 ;.~) -<>\ 03/15/2005 11:53 SAlOIS ;HUFF, FLOWER & LINDSAY ^'T'TnRNr.'f1:.tATflflUl 2Ci W, HitkSltttl C.uli,lc,l'^ 71 72435510 SAIDIS SHUFF FLOWER PAGE 02 ROBERT 5, PTASZEK, Plaintiff :IN-HE COURT OF COMMON PLEAS :CUI'1BERLAND COUNTY, PENNSYLVANIA VS, : NC. 02-6125 ClVIL TERM : CIVIL ACfrON ' LAW DARLA PTASZEK, Defendant : TN DIVORCE PLAINTIff'S AFI:IDAV!T OF CONSENT y"NDER &330l(c) OF THE DIVORCE CODE AND WAIVH: OF COUNSELING ). A Complaint in Divorce under ,?3.301 (c) or the Divorce Code was filed _Q",'i C ~_i;) 'iA- ~, k/ .l (/0 ~ 2. The marriage of p1i:lintirr and (Jefelldal)'l: is irretrievably bmkell and nirl(~lY day:.; Ilave elapsed from the date of filing 211lc1 serVice of thl= Curnplamt, 3, t consent to the entry of ~ fin~1 Decrl~e in Divorce ~fl:p:r <;PNlce of notice of Intent\on to request cntl'V of I:he Deuee. ] vwfy tllat the 5(al'emenl'S made 111 I.hls Affid~vit arc true and correel'. t.o the best or my knowledge, IMormatlon and belief. ] understand that false SI.ill:ements herein are made subject to rhe pena~:t:o~~a:Sa:90~;ling 10 I)n)"'orn:~~~ Robert S. Pta5zck PLAINTIFF'S WAIVER Of' NOTICE OF lli!.EJ:lTION TO REOUEST ~LOJ:..A..I)IVORCE DECREE UNDER ~ 330l (c) .OF THE DIVORCE CODE 1. I consent to the entry of a Fin,'/ Decree or Divorce withoul: notice 1. , understand that I may lose rights corl,:errrinq alimony, c1ivi~;ion of property, l(1wt't'r'~) fee_~~ or expense:; if I do no!: deJim them befure f} l,livon;e. is gr;:mlp.d 3. I IJr'detsu~n(J t.hat I will not be divorced until a Divolce Decree is entered by the Court <:1lid that a copy of the Decree will be :;enl: 1:c) me I'flrtre('Ji01,e1y Ml:er it i5 mea wlrh rhe Prothonotary, 1 verify that tliestatements made III thii AffidaVit Clre truE: ~nd correct to the best of my knowledge, Information and belief. r understand that Folse statements here.:n are m~d~ 'Ullje(ll::~: p:n:,tl:o::s :a$~S 4904 relal n9 t~~:;Ztles ~obert S. Pta~7.ek 83/15/2885 11:53 SAlOIS SHUFf, flOWER & LINDSAY I\!iORNUSo^ftl^", 2r.W_ Hi!;" SlrtCl C,HII:'l.le, P^ 7172435518 SAIDIS SHUFF FLOWER PAGE 83 ROBERT S, PTASZEK, Plai ntiff :IN THE COURT OF COMMON PLEAS :CUHBERLAND COUNTY, PENNSYLVANIA VS, : NC. 02-6125 CIVIL TERM : CIVIL ACTION - LAW DARLA PTASZEK, Defendant : IN DIVORCE DEFENDANT'S AHIDAVIT OF CONSENT UNDER &3301(c) pF THE DIVORCE CODE AND WAIVEr;. OF COUNSElING A Comploinlln Divorce under 93301 (c' of the Oivorc8 Code wa$ filed ~ Z~-, 'lot! Z-- I 2 The marriage of plaintiff and defe.ndal": 1$ irretrievobly broken end ninety d^y5 have el^psed from the dale of filing and service of tile Complaint. .1. .1 consent t() the entry of il fln01 Decre€ in Dlvorc~ Clfter service of nonce of Irllentlon to request entry of rile Decree I veriry that the Qatem<2nts rn~de III [Ilis Affidavit Me true and r.orrect to the best of my knowledge, Information and belief. ) lIndersti'nd that false statement, Ilerell' ere made subjeo to the pellalties of lR Pa.C.S, 4904 reliltlng to un"Norn fillSlflciltlon to authoritlcs. Date:~~i\P\OS,_ Qit~ ~ Daria pt":7ek . ....:. . QfFEI'WIlNT'S WAIVER <iF NOTICE OF I.NTENTlON 'to REQUEST ENTRY OF A.DIVORCE DECREE UNDER ~ 3301 (c'l OF THE DIVORCE CODE 1. I consent to tIle entry Or a final Deere:. of Divorce wi~hout notic<e. 2 I understand tllat f may lose riohts cOl\cemlllg al,muny. divISion of property, IJwyer's fees or expenses if 1 dOllot claim them befoft:: ~ divorce Is granted. 3. ] undel'staneJ that] Will nOI: be dlvorc:d until a Divorce D~rret: i.s cllterc-rJ by the CJUI"t and thal a copy of the Decree:: will be sent to me immed:atcfy dn:er It is {:Ied wil:h th<2 Protllonotary. 1 verify that the statements mode in tillS Affidavll' arp true and correer to the t)ec;r:: of my knowledge, information and belief. I understand that false statE:ments h~rein are made :;ub)ect to the penalties of 18 PCl,C.S. 4904 reli::ting to un~worn falSification 1:0 3utllontlcs Dal:p: ~9~_ @Jt fl._ P~_f--. DarlC'l PI:8s/ek ROBERT S. PTASZEK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 02 - 6125 CIVIL DARLA PTASZEK, Defendant IN DIVORCE ORDER OF COURT day of 4 ()/1-j a./ I , 2005, the parties and counsel having entered into an agreement AND NOW, this 8f11 and stipulation resolving the economic issues on March 16, 2005, the date set for a conference, the agreement and stipulation having been transcribed, and subsequently signed by the parties and counsel, the appointment of the Master is vacated and counsel can conclude the proceedings by the filing of a praecipe to transmit the record with the affidavits of consent of the parties so that a final decree in divorce can be entered. BY THE COURT, Geo~ cc: David S. Schanbacher Attorney for Plaintiff It . , lc~;j ~L-tL 4-. ~-{)'J }JS- Carol J. Lindsay Attorney for Defendant 'L/ A.lNrhi": ;'-, '<",1';:;) s ~ : I lid 8- lJd~ SaUl A', 'C'" ..' . ~'-ll .^ ~"\11 ,:.1; -'.",'1' .)....,., ~., ...,IV" W't.l.. .1, ~.......i .vl.,;.... -II .... :KJl.:UO-Q3ll:J ROBERT S. PTASZEK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 02 - 6125 CIVIL DARLA PTASZEK, Defendant IN DIVORCE THE MASTER: Today is Wednesday, March 16, 2005. This is the date set for a conference with counsel and the parties. Present are the Plaintiff, Robert S. Ptaszek, and his counsel David C. Schanbacher, and the Defendant, Darla Ptaszek, and her counsel Carol J. Lindsay. This action was commenced by the filing of a complaint in divorce on December 26, 2002, raising grounds for divorce of irretrievable breakdown of the marriage. Although an affidavit under Section 3301(d) was filed on July 30, 2004, averring a period of separation in excess of two years, nevertheless, counsel have provided affidavits of consent and waivers of notice of intention to request entry of divorce decree today. The affidavits and waivers will be signed today by the parties and filed by the Master's office with the Prothonotary. Therefore, the divorce can conclude under Section 3301(c) of the Domestic Relations Code. The complaint also raised the economic claim of equitable distribution. At that time no claims were '. raised for alimony or counsel fees. However, on March 7, 2005, the Defendant filed a counterclaim raising the 1 " economic claim of alimony. No claims have been raised by either party for counsel fees and costs. The parties were married on August 20, 1994, and separated July 1, 2002, They are the natural parents of one child who is in the custody of wife. After negotiations this morning, the Master has been advised that the parties have reached an agreement with respect to the outstanding economic issues, The agreement is going to be placed on the record in the presence of the parties. The agreement as stated on the record will not be subject to any changes or modifications except for correction of typographical errors which may be made during the transcription, After the agreement has been transcribed, the agreement will be sent to counsel for review for typographical errors. The corrections will be made, if necessary, and the parties will be asked to affix their signatures to the agreement affirming the terms of settlement as stated on the record. However, the parties are bound by the terms of settlement as stated on the record when they leave the hearing room even though the agreement is not subsequently affirmed by signature. Upon receipt by the Master of a completed agreement, the Master will prepare an order vacating his appointment and counsel can then file a praecipe transmitting the record to the Court requesting a final 2 decree in divorce, Ms. Lindsay, MS, LINDSAY: The parties have agreed to divide their property as follows: 1. Husband will receive the property at III Adams Road, which is deeded in his name. Husband avers, and the parties believe, that the mortgage on the marital home is in husband's name only and a refinance is not required. Husband will also retain the Oak Plantation vacation condominium time-share. With regard to both assets, husband will pay all taxes, insurance and charges thereon and indemnify and hold wife harmless on account of any loss from the two pieces of realty or interest in realty, In addition to the Florida time-share, husband has a pre-marital Florida time-share which will be his sole and exclusive property and wife waives any interest she has in that time-share, 2. Wife will retain the mobile home on Meals Drive and also her interest in a home in which her mother resides in Boiling Springs, Pennsylvania. With regard to those properties, wife will pay all costs associated thereon and will indemnify and hold husband harmless on account of any loss related to those two properties, 3. Husband will retain the 1987 Chevrolet Cavalier and the 1988 Plymouth Voyager. Wife will retain the 1991 Chevrolet Cavalier and the 1985 Chevrolet S-10 short bed pickup. The parties will execute any documents required with regard to these vehicles in order to secure possession and ownership but the parties believe that these vehicles are separately titled at this time. 4. Wife will retain her Member's 1st Bank accounts and husband will retain his Member's 1st Bank accounts. Each waives any interest which he or she may have in the bank accounts of the other. 5. With regard to retirement benefits, husband will retain his CSRS pension and wife waives any interest she may have in that pension. Wife will also waive any entitlement or interest to any spousal survivor annuities by virtue of husband's retirement benefits. " 6. Husband will also retain the thrift savings plans which 3 he has not only with the federal government but also through the Army National Guard. Husband will retain his Army National Guard pension and his Vanguard Roth IRA. 7, Wife will retain her State Employees Retirement System pension, 8. With regard to all retirement benefits, the parties hereby waive any interest they may have of any kind in the retirement benefit each is retaining including survivor benefits. 9. Wife will retain the three shares of Walt Disney stock. Furthermore, wife will retain all of her Vanguard and Janus accounts including a pre-marital IRA and funds which she received from the proceeds of sale of a pre-marital home of hers. 10, Today or tomorrow husband will cash out the Vanguard Index 500 fund which he anticipates has a value of approximately $12,600,00 and a PNC Investment which he anticipates has a value of approximately $6,000.00 and pay the proceeds of the cash out of those two accounts directly to wife. At the time of the cash out, husband will not permit any reduction in the proceeds for capital gain taxes and he will be solely responsible for the capital gain taxes, if any, on those two investments. Husband will provide, along with a check from the proceeds for those two accounts a statement showing the value of the accounts at the time of the cash out or liquidation, That statement is to be provided within 15 days subsequent to the liquidation. Wife is accepting from the Vanguard and the PNC Investment IRA whatever value is as of the time of their liquidation but is not accepting any charges assessed to liquidating them or any taxes due on those accounts. 11. Within 120 days of the date of this agreement, husband will pay to wife $66,000.00 in cash. 12. Husband waives any interest he might have in a M&T account for which wife is the representative payee for her mother, the PSECU account which she opened subsequent to separation, and a Member's 1st account, account No. 1573210 which is an account which belongs to Mitchell, the parties' son; that account will be transferred into wife's name only as custodian for Mitchell. " 13. Wife waives any claim which she may have for alimony effective the date of the entry of the divorce decree, 4 Spousal support shall terminate on the date of the divorce decree. 14. The parties acknowledge they have satisfactorily divided their household tangible personal property and that such property shall be the sole and exclusive property of the person in whose possession that it is as of the date of this agreement. 15. The parties warrant one to the other that there are no marital debts to which the other might be liable, Heretofore, each party will be solely and exclusively responsible for any debt which he or she incurred after the parties' separation on July 1, 2002. 16, 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. MS. LINDSAY: Ms. Ptaszek, have you heard the agreement as I have dictated it here today? MS. PTASZEK: Yes, I have. MS. LINDSAY: And is it the agreement you wish to make? MS. PTASZEK: Yes, it is. MS. LINDSAY: Do you have any questions or concerns about that agreement? " MS. PTASZEK: Not at this time. THE MASTER: Do you understand it? 5 MS. PTASZEK: Yes. THE MASTER: Do you also understand that you are bound by it when you leave here today even though you do not subsequently affirm the agreement by signature? MS. PTASZEK: Correct. MR. SCHANBACHER: Mr, Ptaszek, have you heard the agreement that has been placed on the record here today? MR. PTASZEK: Yes, I have, MR. SCHANBACHER: Do you understand it? MR. PTASZEK: Yes, I do. MR. SCHANBACHER: Do you enter into it voluntarily as of this date? MR. PTASZEK: Yes, I do. MR, SCHANBACHER: You understand that you are bound by it as of this date? MR. PTASZEK: Yes. MR. SCHANBACHER: Do you have any questions concerning the agreement? MR. PTASZEK: No questions. THE MASTER: Thank you. '0 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 6 . imposed by law and in particular Section 3105 of the Domestic Relations Code. WITNESS: DATE: (-'~'--'L- j.J'- J /JO!iJ,J ~,' I fJ;t;' /' 'J:V/1 liv\.. Jobert S. Ptaszek 1 I . I ; ,5 OJ' CC)tlk f'L'fJ DarIa Ptaszek 7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSY VANIA ROBERT S. PTASZEK, : NO. 02-6125 PLAINTIFF v. : CIVIL ACTION - LAW DARLA PTASZEK, DEFENDANT : DIVORCE PRAECIPE TO TRANSMIT RECORD 1. Ground for divorce: irretrievably broken under !l3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: December 31, 2002 by certified ail, restricted delivery, return receipt requested to Defendant, Affidavit of Service filed January 2,2003. 3. Date of execution of the Affidavit of Consent required by !l3301(c) of the Div rce Code: by Plaintiff: March 16,2005, filed March 17,2005; by Defendant: March 16,2005, filed March 17, 005. 4. Related claims pending: There are no economic claims pending, All claims have een resolved via a Property Settlement Agreement entered into between the parties before Robert E, Eli ker, Esquire, Divorce Master dated March 16,2005. 5. Date of execution of Plaintiff's Waiver of Notice in !l3301(c) Divorce: March 1 2005, filed: March 27, 2005, Date of execution of Defendant's Waiver of Notice in g330 1 (c) Divorce: M ch 16,2005, filed: March 17,2005. DATE: 1-f1iJ. Jos , , BY: David C. Schanbacher, Esquire Attorney for Plaintiff 30 North George Street York, Pennsylvania 17401-1280 (717) 846-8846 Supreme Court No, 48446 L u_-<.-<:;'- C.":>. -- (-~I c~ :"",,,' C::) ,-_~.:J ,.:,..1 ';".':-> V ~,J ", Ui -.I . . . . . . . . . . . . . . . . . '+,::t':+;:+;:+; . .. +'0+':.:;'': . ,., Of. Of Of . .. ~?'+'+'+'+'+.+ +<+::t::+. .. +.:++++++ :+::+:t' + + +:t'+:t: '" +:+;:+: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY PTASZEK PENNA, STATE OF IROBERT S. ~ I No, 02-6125 VERSUS iDARLA PTASZEK DECREE IN DIVORCE f\~ 2'E 7-/lD('IT IS ORDERED AND AND NOW, Robert S. Ptaszek DECREED THAT , PLAI NTI FF, Darla Ptaszek AND , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . . . . . . . . . . . . . ATTE PROTHONOTARY . . . . ++++++++~+++++++++++++++++~ .. +++++:t.:++++ . .. ++++++'+' . 'fi'+:'j;++++++'I';f. + :+: :+; '+ ;;; + +:+. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~~. ' .f':v~" """""'.>V-V71 "711.':;' J- "r ~ H' ~, /i/, .r'V,",.>O CS' ~r7"Y !f::" "Z ~ ~ /~))?, cy . ' ~ ." ~5'- &c