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part of either HUSBAND or WIFE of the lawfulness or unlawfulness
of the causes leading to their living apart.
2. INTERFERENCE: Each party shall be free from
interference, authority, and contact by the other, as fully as if
he or she were single and unmarried, except as may be necessary
to carry out the provisions of this Agreement. Neither party
shall molest the other or attempt to endeavor to molest the
other, nor compel the other to cohabit with the other, or in any
way harass or malign the other, nor in any way interfere with the
peaceful existence, separate and apart from the other, and each
of the parties hereto completely understands and agrees that
neither shall do or say anything to the children of the parties
at anytime which might in any way influence the children
adversely against the other party, it being the intention of both
parties to minimize the effect of any such separation upon the
children.
3. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS: This
Agreement shall not be considered to affect or bar the right of
HUSBAND or WIFE to a divorce on lawful grounds as such grounds
now exist or shall hereafter exist or to such defense as may be
available to either party. This Agreement is not intended to
condone and shall not be deemed to be il condonation on the part
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of either party hereto of any act or acts on the part of the
other party which have occasioned the disputes or unhappy
differences which have occurred prior to or which may occur
subsequent to the date hereof.
4. SUBSEOUENT DIVORCE: The parties hereby acknowledge that
HUSBAND has filed a Complaint in Divorce in Cumberland County to
Docket No. 97-3614, claiming that the marriage is irretrievably
broken under Section 3301(c) of the Pennsylvania Divorce Code.
Should a decree. judgment or order of divorce be obtained by
Both parties hereby express their agreement that the marriage is
irretrievably broken and express their intent to execute any and
all Affidavits, Waivers or other documents necessary for the
parties to obtain an absolute divorce pursuant to Section 3301(c)
of the Divorce Code at the same time as they execute this
Agreement. The parties hereby waive all rights to request court
ordered counseling under the Divorce Code. It is further
specifically understood and agreed by the parties that the
provisions of this Agreement as to equitable distribution of
property of the parties are accepted by each party as a final
settlement for all purposes whatsoever, as contemplated by the
Pennsylvania Divorce Code.
either of the parties in this or any other state, country or
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widow's or widower's rights, family exemption or similar
allowance, or under the intestate laws, or the right to take
against the spouse's will, or the right to treat a lifetime
conveyance by the other as a testamentary gift, or all other
rights of a surviving spouse to participate in a deceased
spouse's estate, whether arising under the laws of (a)
Pennsylvania, (b) any State, Commonwealth or territory of the
United states, or (c) any country or any rights which either
party may have or at any time hereafter shall have for past,
present or future support or maintenance, alimony, alimony
pendente lite, counsel fees, division of property, costs or
expenses, whether arising as a result of the marital relationship
or otherwise, except, all rights and agreements and obligations
of whatsoever nature arising or which may arise under this
Agreement or for the breach of any provisions thereof, It is the
intention of HUSBAND and WIFE to give each other, by the
execution of this Agreement, a full, complete and general release
with respect to any and all property of any kind or nature, real,
personal or mixed, which the other now owns or may hereafter
acquire, except and only except all rights and agreements and
obligations of whatsoever nature arising or which may arise under
this Agreement or for the breach of any provision thereof. It is
further agreed that this Agreement shall be and constitute a full
and final resolution of any and all claims which each of the
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parties may have against the ether for equitable division of
property, alimony, counsel fees and expenses, alimony pendente
lite or any other claims pursuant to the Pennsylvania Divorce
Code or the divorce laws of any other jurisdiction.
9. REPRESENTATION BY COUNSEL: This Agreement has been
prepared by MARIA P. COGNETTI, Esquire, counsel for WIFE. Said
counsel at the commencement of and at all stages during, the
negotiation of this Agreement, has acted solely as counsel for
WIFE and has not advised or represented HUSBAND in any manner
whatsoever. HUSBAND was represented by CATHERINE A. BOYLE,
ESQUIRE, during all proceedings in this matter, up through the
negotiation of this Agreement. After the parties reached this
Agreement HUSBAND chose to continue in this matter without
representation. HUSBAND has read this Agreement carefully and
thoroughly, fully understanding each of its provisions, and
therefore signs it clearly and voluntarily.
HUSBAND and WIFE acknowledge that this Agreement is not the
result of any duress or undue influence and that it is not the
result of any collusion or improper or illegal Agreement or
Agreements. The parties further acknowledge that they have each
made to the other a full accounting of their respective assets,
estate, liabilities, and sources of income and that they waive
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any specific enumeration thereof for the purpose of this
Agreement. Each party agrees that he or she shall not at any
time raise as a defense or otherwise the lack of such disclosure
in any legal proceeding involving this Agreement, with the
exception of disclosure that may have been fraudulently withheld.
10. WARRANTY AS TO EXISTING OBLIGATIONS: Each party
represents that they have not heretofore incurred or contracted
for any debt or liability or obligation for which the estate of
the other party may be responsible or liable except as may be
provided for in this Agreement. Each party agrees to indemnify
and hold the other party harmless for and against any and all
such debts, liabilities or obligations of every kind which may
have heretofore been incurred by them, including those for
necessities, except for the obligations arising out of this
Agreement.
11. WARRANTY AS TO FUTURE OBLIGATIONS: HUSBAND and WIFE
covenant, warrant, represent and agree that with the exception of
obligations set forth in this Agreement, neither of them shall
hereafter incur any liability whatsoever for which the estate of
the other may be liable. Each party shall indemnify and hold
harmless the other party for and against any and all debts,
charges and liabilities incurred by the other after the execution
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date of this Agreement, except as may be otherwise specifically
provided for by the terms of this Agreement.
12. DEBT OF THE PARTIES: HUSBAND hereby indemnifies WIFE
against, and agrees to assume the sole liability and
responsibility for, all debts, obligations or liabilities of any
nature whatsoever heretofore or hereafter incurred by HUSBAND for
the benefit of himself, except as provided herein.
WIFE hereby indemnifies HUSBAND against and agrees to assume
the sole liability and responsibility for all debts, obligations
or liabilities of any nature whatsoever heretofore or hereafter
incurred by WIFE for the benefit of herself, except as provided
for herein.
HUSBAND shall not and will not hereafter incur or cause to
be incurred for the benefit of himself, except as provided for
herein, any debts, obligations or liabilities for any nature
whatsoever, whether for necessaries or otherwise, upon the credit
of \-lIFE.
WIFE shall not and will not hereafter incur or cause to be
incurred for the benefit of herself, except as provided for
hc:-ein, any debts, obligations or liabilities for any nature
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whatsoever, whether for necessaries or otherwise, upon the credit
of HUSBAND.
13. PERSONAL PROPERTY: The parties have divided between
them, to their mutual satisfaction, the personal effects,
household furniture and furnishings, and all other articles of
personal property which have heretofore been used by them in
common, and neither party will make any claim to any such items
which are now in the possession or under the control of the
other. Should it become necessary, the parties each agree to
sign any titles or documents necessary to give effect to this
paragraph upon request.
By these presents, each of the parties hereby s'pecifically
waives, releases, renounces and ,forever abandons whatever claims
he or she may have with respect to any personal property which is
in the possession of the other, and which shall become the sole
and separate property of the other from the date of execution
hereof.
14. DIVISION OF REAL PROPERTY: HUSBAND agrees to transfer
all his right, title and interest in and to the real estate
situated at 1005 Chippenham Road, Mechanicsburg, Cumberland
County, now titled in the name of HUSBAND and WIFE as tenants by
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the entireties, to WIFE and agrees to immediately execute now and
in the future any and all deeds, documents or papers necessary to
effect such transfer of title upon request. HUSBAND further
acknowledges that he has no claim, right, interest or title
whatsoever in said property and further agrees never to assert
any claim to said property in the future. HUSBAND agrees to
simultaneously execute a deed conveying his interest to WIFE,
said deed to be delivered to WIFE"s attorney upon the signing of
this Agreement.
WIFE hereby covenants and agrees to assume and pay in full
the remaining balance of the mortgage now existing and presently
constituting a lien upon and encumbering the same premises, such
mortgage being owed and payable to Fleet Mortgage Group and
further covenants and agrees that she will indemnify and save
HUSBAND harmless from any and all liability, expense, cost, or
loss whatsoever as a result of her non-payment of or non.
performance of said mortgage and said mortgage conditions.
Wife further agrees that she will forthwith apply to Fleet
Mortgage Group in order to assume said loan in her name alone,
or, if that is not possible, to refinance the loan in order to
remove Husband's name therefrom.
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15. DIVISION OF BANK ACCOUNTS: The partien agree that the
Corestates Savings Account No. 239808-7731, Corentates Checking
Account No. 2336-0454, and Corestates Checking Account No.
141374-0458, presently held or previously held in the name of
WIFE alone or jointly by the parties, shall become the sole and
exclusive property of WIFE upon the entry of a final Decree in
Divorce. The PNC Bank account No. 50-8047-3993 held in the name
of HUSBAND alone, shall become the sole and exclusive property of
HUSBAND. The parties acknowledge that each has no further claim
or interest in said accounts of the other and agree that each
will not assert any such claim in the future.
16. DISTRIBUTION OF INDIVIDUAL RETIREMENT ACCOUNTS:
HUSBAND hereby acknowledges and agrees that WIFE shall retain, as
her separate property, free and clear from any claim, right,
title or interest on the part of HUSBAND, her Individual
Retirement Account with Ivy Account No. 030-0900702306. HUSBAND
hereby acknowledges that he has no further claim, right, title or
interest whatsoever in the Individual Retirement Account of WIFE,
and further agrees never to assert any claim to the asset in the
future.
\'iIFE hereby acknowledges and agrees that HUSBAND shall
l,'lain. as hi" separate property, free and clear from any cl.:lim,
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I iyht, title or interest on the part of WIFE, his Individual
I",tirement Account with Dean Witter Account No. 410046661
(formerly Ivy Account Nos. 030-0900702299 and 033-0900702299).
wrFE hereby acknowledges that she has no further claim, right,
title or interest whatsoever in the Individual Retirement Account
of HUSBAND, and further agrees never to assert any claim to the
asset in the future.
17. WIFE'S RETIREMENT ACCOUNT: HUSBAND agrees that any
monies which WIFE has acquired through her interests in either
pensions, profit sharing, savings and thrift plans, annuities
and/or retirement benefits through her present or past employers
shall remain her sole and exclusive property. HUSBAND hereby
covenants and agrees that he will execute any spousal waivers
that may be required under the Pension Reform Act of 1974, the
Retirement Equity Act of 1984, or any similar Federal or state
statute that is now in effect or may be enacted. This paragraph
is intended to substitute for any other statement, prepared form,
or document which might be required by any plan, fund, trust,
administrator, trustee, or similar entity or person, so that WIFE
may receive said benefits as if she were never married.
HUSBAND hereby consents to WIFE's election to waive a
qualified joint survivor annuity form of benefit and a qualified
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pre-retirement survivor annuity form of benefit under her
retirement account. HUSBAND further consents to WIFE's current
and future designation of any alternative form of benefit and of
beneficiaries other than HUSBAND under said plan and to any
t-evocation and/or modification of such designation (s). HUSBAND
hereby further agrees to execute any and all documents or forms
which shall be required, at any time, and from time to time, by
said plan, including but not limited to, any consents required to
effect the payment of benefits in this manner. HUSBAND hereby
acknowledges that he understands the effect of WIFE's elections
and he consents thereto. HUSBAND further acknowledges that he
understands that, absent the consent contained in this paragraph,
he would have the right to limit his consent to the designation
by WIFE of a specific beneficiary or a specific form of benefits,
and HUSBAND hereby voluntarily elects to relinquish both such
rights.
18. HUSBAND'S RETIREMENT ACCOUNT: WIFE agrees that any
monies which HUSBAND has acquired through his interests in either
pensions, profit sharing, savings and thrift plans, annuities
and/or retirement benefits through his present or past employers
shall remain his sole and exclusive property. WIFE hereby
covenants and agrees that she will execute any spousal waivers
that may be required under the Pension Reform Act of 1974, the
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Retirement Equity Act of 1984, or any similar Federal or state
"I.iltute that is now in effect or may be enacted. This paragraph
1S intended to substitute for any other statement, prepared form,
<II document which might be required by any plan, fund, trust,
ddministrator, trustee, or similar entity or person, so that
HUSBAND may receive said benefits as if he were never married.
WIFE hereby consents to HUSBAND's election to waive a
qualified joint survivor annuity form of benefit and a qualified
p.'e-retirement survivor annuity form of benefit under his
ret irement account. WIFE further consents to HUSBAND I s current
and future designation of any alternative form of benefit and of
b"neficiaries other than WIFE under said plan and to any
revocation and/or modification of such designation(s), WIFE
h,'reby further agrees to execute any and all documents or forms
which shall be required, at any time, and from time to time, by
said plan, including but not limited to, any consents required to
effect the payment of benefits in this manner. WIFE hereby
acknowledges that she understands the effect of HUSBAND's
elections and she consents thereto. WIFE further acknowledges
that she understands that, absent the consent contained in this
paragraph, she would have the right to limit her consent to the
designation by HUSBAND of a specific beneficiary 01- a specific
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form of benefits, and WIPE hereby voluntarily elects to
relinquish both such rights.
19. REAL ESTATE PARTNERSHIP: WIPE acknowledges that HUSBAND
has a 33% ownership interest in a real estate partnership known
as 4824 Trindle Associates. WIPE agrees to transfer any and all
of her marital right, title and interest in and to that
partnership to HUSBAND. WIPE agrees to execute, now and in the
future, any and all deeds, documents or papers necessary to
effect such transfer or title upon request. WIFE further
acknowledges that she has no claim, right, interest or title
whatsoever in the said partnership and further agrees never to
assert any claim to such asset in the future.
HUSBAND hereby indemnifies WIFE against and agrees to assume
the sole liability and responsibility for any encumbrance, lien,
loss, damages, expense, civil or criminal liability including
deficiency assessment, penalty or interest which WIFE may incur
or has incurred for any reason whatsoever as the result of any
transaction undertaken on behalf of the partnership. HUSBAND
further agrees that within sixty days of the signing of this
Agreement he will cause WIPE's name to be removed from any and
all debts that are associated with the partnership and provide
WIPE proof that her name has b~en removed.
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20. DENTAL PARTNERSHIP: WIFE acknowledges that HUSBAND has
a 33% ownership interest in the dental partnership of Mendelson,
Foer & Harrison Dental Associates. WIFE agrees to transfer any
and all of her marital right, title and interest in and to that
partnership to HUSBAND. WIFE agrees to execute, now and in the
future, any and all documents or papers necessary to effect such
transfer of title upon request. WIFE further acknowledges that
she has no claim, right, interest or title whatsoever in the said
partnership and further agrees never to assert any claim to such
asset in the future.
HUSBAND hereby indemnifies WIFE against and agrees to assume
the sole liability and responsibility for any encumbrance, lien,
loss, damages, expense, civil or criminal liability including
deficiency assessment, penalty or interest which WIFE may incur
or has incurred for any reason whatsoever as the result of any
transaction undertaken on behalf of the partnership. HUSBAND
further agrees that within sixty days of the signing of this
Agreement he will cause WIFE's name to be removed from any and
all debts that are associated with the partnership and provide
WIFE proof that her name has been removed.
21. MOTOR VEHICLES: With respect to the motor vehicles
owned by one or both of the parties, they agree as follows:
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(a) The 1997 Honda Odyssey shall be and remain the
sole and exclusive property of WIFE;
(b) The 1995 Honda Accord shall be and remain the sole
and exclusive property of HUSBAND.
The titles to the said motor vehicles shall be executed by
the parties, if appropriate for affecting transfer as herein
provided, on the date of execution of this Agreement, and said
executed title shall be delivered to the proper party on the
distribution date. Each party agrees to be solely responsible
for the amounts presently due and owing against his or her
respective automobile.
22. OWNERSHIP OF LIFE INSURANCE POLICIES, WIFE is cognizant
of the fact that HUSBAND has maintained and paid premiums on the
following life insurance policies: Northwestern Life Insurance
and Amerus Life Insurance. WIFE hereby expressly relinquishes,
waives and renounces any and all proprietary, statutory,
distributional, ownership and beneficiary rights and options to
the aforesaid insurance policies. WIFE hereby agrees and
warrants that HUSBAND has full and complete discretion to change
the designated beneficiaries on the aforesaid policies.
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completed. Said policy, as described above, shall be in the
amount of THREE HUNDRED THOUSAND DOLLARS ($300,000.00). HUSBAND
shall deliver to WIFE such insurance policy evidencing such
irrevocable designation of WIFE as beneficiary of said insurance
within ten (10) days from the execution of the within Agreement.
HUSBAND agrees and undertakes to payor cause to be paid all
premiums, dues and assessments on said insurance policy at least
fifteen (15) day prior to the grace date thereof. HUSBAND agrees
to provide the insurance company with authority to notify WIFE
should HUSBAND not pay the premium within five (5) days after
said premium is due and owing. A copy of such letter of
authorization shall be forwarded to WIFE.
In the event of HUSBAND's failure to pay any of the
premiums, dues or assessments that may become due on said policy
within fifteen (15) days prior to the grace date thereof, he
shall become indebted to WIFE in the amount of such premiums,
dues or assessments, whether or not the same shall have been paid
or advanced by WIFE. In the event that the said policy shall
have lapsed or expired, then HUSBAND agrees that he shall
immediately become indebted to WIFE in the amount of the initial
premium of a new policy covering the life of HUSBAND in the
amount of the policy that shall have lapsed or expired, and
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HUSBAND'a obligation to continue to pay the premiums on a new
policy shall continue has hereinbefore provided.
The foregoing shall not be deemed to limit in any way the
rights and remedies of WIFE in the event that HUSBAND shall fail
to perform the obligations required to be performed by him under
this paragraph or shall fail to pay any of the premiums, dues or
assessments that may become due on said policy within fifteen
(15) days prior to the grace date thereof.
If the life insurance policy for the benefit of WIFE, is not
in full force and effect at the time of HUSBAND's death, and WIFE
shall not have died, and WIFE does not receive the amount to
which she is entitled, then WIFE shall have a creditor's claim
and a lien against HUSBAND's estate for the difference between
the proceeds to which she is entitled and the amount she actually
receives upon HUSBAND's death.
At such time as all payments have been made pursuant to the
terms of this Agreement ownership of said policy shall revert
back to HUSBAND.
25. PRIVATE/PAROCHIAL SCHOOL EXPENSES: HUSBAND hereby
agrees to be fully responsible for any and all private/parochial
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"...hool expenses for the part ies' minor children unt il they obtain
,\ high school diploma. HUSBAND and WIFE acknowledge that their
daughter, Christina, is currently enrolled in Trinity High School
and that their son, Richard, will enroll at Trinity High School
when he attains the appropriate age. HUSBAND's agreement to pay
said expenses shall be in addition to any child support order,
shall be outside the purview of the Domestic Relations Office and
shall not be a factor in any future modification requests.
26, CHILDREN'S EXPENSES: HUSBAND shall timely pay, defined
as within ten (10) days of the underlying bills, directly to the
school, teachers, and/or instructors concerned, all expenses
relating to the children's music instruction and summer camps.
HUSBAND shall be required to pay for all books, suppl ies and
equipment required for such instruction or camps. HUSBAND
authorizes the expense of such instruction and camps to be billed
directly to him. WIFE shall forward promptly to HUSBAND all
bills received by her for such instruction, activity or camp.
Said expenses shall be paid by HUSBAND through the children's
completion of high school. HUSBAND's agreement to pay said
expenses shall be in addition to any child support order, shall
be outside the purview of the Domestic Relations Office and shall
not be a factor in any future modification requests.
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27. HIGHER EDUCATION EXPENSES: HUSBAND agrees that he will
provide the parties' children with a college education through
the attainment of a bachelor's degree or equivalent from a
college or university or its equivalent. It is contemplated by
the parties that college level education may be residential in
nature, and HUSBAND agrees that in connection with the college
education he will pay 100% of the following costs: tuition, room
and board, books, laboratory, student and other fees billed
directly by the educational institution. If the children should
reside "off campus" HUSBAND shall pay the reasonable rent and
reasonable food allowance directly to the child. The parties
agree to consult with one another and with each of the children
as to the choice of any college or university and that their
concern in such consultation shall be governed by a college or
university most appropriate to the needs and abilities of the
child. The financial commitment of HUSBAND to the children shall
continue until they reach the age of twenty-five (25) years so
long as they remain actively in pursuit of a degree, licensure or
certification.
28. SUPPORT ARREARS: Pursuant to an Order of Court dated
November 19, 1958, HUSBAND is to pay WIFE child support and
spousal support in the amount of $3,667.00 per month. As a
result of said Order an arrearage exists. HUSBAND herehy
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only pay such costs as would be paid by a regular employee. If
WIFE desires to terminate said coverage, WIFE shall give HUSBAND
thirty days notice of same.
33. COUNSEL FEES: Except as provided herein, each party
hereby indemnifies and agrees to indemnify and hold the other
free and harmless against the claims of any attorney or person
who rendered or claims to have rendered services to him or her in
connection with the divorce proceedings and the negotiation of
this Agreement or otherwise.
34. INCOME TAX PRIOR RETURNS: The parties have heretofore
filed joint Federal and state tax returns. Both parties agree
that in the event any deficiency in Federal, state or local
income tax is proposed, or any assessment of any such tax is made
against either of them, each will indemnify and hold harmless the
other from and against any loss or liability for any such tax
deficiency or assessment and any interest, penalty and expense
incurred in connection therewith. Such tax, interest, penalty or
expense shall be paid solely and entirely by the individual who
is finally determined to be the cause of the misrepresentations
or failures to disclose the nature and extent of his or her
separate income on the aforesaid joint returns.
-28-
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':'",nt I.
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35. CHILDREN'S TAX RETURNS: The parties acknowledge that
',AND has previously filed income tax returns for the parties'
ell i Ldren. WIFE agrees that HUSBAND shall continue to file said
1 'urns in the future and to continue to pay all tax liability,
Ii any, associated with said returns. HUSBAND agrees to consult
.':th WIFE prior to the filing of said returns so as to coordinate
"'j information which is in WIFE's possession which must be
1, ",)rted on said returns. HUSBAND agrees to give WIFE a copy of
illl such filed returns no later than April 30th of each year.
Furthermore, WIFE shall provide HUSBAND with information
received by her for tax years in which HUSBAND has already filed
",I urns for the children. HUSBAND will promptly amend such
returns and pay any tax liability, interest, and penalties
,,,;,:<c>ciated with the filing of said amended returns. HUSBAND
shall provide WIFE with a copy of said returns within ten (10)
ell)'S of filing.
36. APPLICABILITY OF TAX LAW TO PROPERTY TRANSFERS: The
p,lllies hereby agree and express their intent that any transfer
of property pursuant to this Agreement shall be within the scope
ell,,1 applicability of the Deficit Reduction Act of 1984
(Iwreinafter the "Act"), specifically, the provisions of said Act
p"ltaining to the transfers of property between spouses and
-29-
:n '.1'\ r:''''ll~ ,~.. IIII'M 1111"(1 Uly\IlU r l~"fl- E\AJI.........nt.., J>1'.~".t'l S..t t I.,....,,! ,l.lr.........nt "'p'l
~'T'll I. .r;\
former spouses. The parties agree to sign and cause to be filed
any elections or other documents required by the Internal Revenue
Service to render the Act applicable to the transfers set forth
in this Agreement without recognition of gain on such transfer
and subject to the carry-over basis provisions of the said Act.
37. WAIVER OF ALIMONY: HUSBAND and WIFE recognize and
acknowledge that the foregoing provisions for their individual
benefit are satisfactory with regard to their support and
maintenance, past, present and future. The parties release and
discharge the other absolutely and forever for the rest of their
lives from all claims and demands, past, present or future, for
alimony or for any provision for support or maintenance, except
as specifically provided for herein. The parties further
acknowledge that in consideration of the transfers made herein
each completely waives and relinquishes any and all claims and/or
demands they may now have or hereafter have against the other for
alimony, alimony pendente lite, spousal support and counsel fees,
except as specifically provided for herein.
38. EFFECT OF DIVORCE DECREE: The parties agree that
except as otherwise specifically provided herein, this Agreement
shall continue in full force and effect after such time as a
-30-
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:""'bl:
final Decree in Divorce may be entered with respect to the
l'drties.
39. BREACH:
If either party breaches any provision of this
Agreement, the other party shall have the right, at his or her
election, to sue for damages for such breach or seek such other
remedies or relief as may be available to him or her, and the
party breaching this contract shall be responsible for payment of
reasonable legal fees and costs incurred by the other in
enforcing their rights under this Agreement.
40. WAIVER OF CLAIMS: 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 shall now have or hereafter acquire, under the present and
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, dower, curtesy, statutory
allowance, widow's allowance, widower's allowance, right to take
in intestacy, right to take against the Will of the other, and
the right to act as administrator or executor of the other's
estate. Each party will, at the request of the other, execute,
acknowledge and deliver any and all instruments which may be
- 31-
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"'1"Jl~H I. ;COl
.'
" 'cessary or advisable to carry into effect this mutual waiver
:u relinquishment of all such interests, rights and claims.
41. ENTIRE AGREEMENT: This Agreement contains the entire
understanding of the parties and there are no representations,
w~rranties, covenants or undertakings other than those expressly
w,t forth herein.
42. FINANCIAL DISCLOSURE: The parties confirm that they
have relied on the completeness and substantial accuracy of the
financial disclosure of the other as an inducement to the
execution of this Agreement. Notwithstanding the foregoing, the
rights of either party to pursue a claim for equitable
distribution, pursuant to the Pennsylvania Divorce Code, of any
interest owned by the other party in an asset of any nature at
any time prior to the date of execution of this Agreement that
was not disclosed to the other party or his or her counsel prior
to the date of the within Agreement is expressly reserved. In
the event that either party, at any time hereafter, discovers
such an undisclosed asset, that party shall have the right to
petition the Court of Common Pleas of Cumberland County to make
equitable distribution of said asset.
-32-
"
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"
specifically under the Divorce Code of 1980 and any amendments
thereto.
IN WITNESS WHEREOF, the parties hereto have set their hands
and seals the date and year first above written.
(/!,://',/In .~~:!h.
HT ESS
fJ..~6-t.dv a f.la.tt1lAJ'tU (SEAL)
ELIZ ETH A, HARRISON
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WITNESS
1" ~ ;1J0wL /41#"'--
C. RICHARD HARRISON
(SEAL)
-35-
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF t!u.m...6.v.L<<-J<-,c
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)SS:
)
On this, the 'lR day of at{ 7!'A;r.;- ,2001, before me,
a Notary Public, the undersigned oyficer, personally appeared
ELIZABETH A, HARRISON, known to me (or satisfactorily proven) to
be the person whose name is subscribed to the foregoing Property
Settlement Agreement and acknowledged that she executed the same
for the purposes therein contained,
IN WITNESS WHEREOF, I hereunto set my hand and official
seal,
ary Public
NOTARIAL SEAL
JANE K. HAVNAER, t><o!ary P"i";.: I
Camp Hi~1 Boro, Curnbo;i3r.~ :-:":0,, ,I
MyCorr.mlss~l EXP:iC$",t.'r'l~ ~ I. .....j 2J
COMMONWEALTH OF PENNSYLVANIA )
/I ) SS:
COUNTY OF u/./mber/{)/lC/ )
On this, the cilyd day of rtUilllsf- , 2001, before me,
a Notary Public, the undersigned ~fficer, personally appeared C,
RICHARD HARRISON, known to me (or satisfactorily proven) to be
the person whose name is subscribed to the foregoing Property
Settlement Agreement and acknowledged that he executed the same
for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set m~ hand and official
seal,
.U/
._--......
J
NOTARIAL SEAL
SUZANNE M OEOERER, NOlary Public
Camp H,II Bore, Cumberland County
My Comm'sslon Expires Aug. 20, 2005
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010211.00001IJun. 17. 199710WOIMHI64553
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C, RICHARD HARRISON,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 1'7- -3~I4- ~
Plaintiff
vs,
IN DIVORCE
ELIZABETH A, HARRISON,
Defendant
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims set forth in the 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 judgmant
may also be entered against you for any other claim or relief requested in these pages by the Plaintiff.
You may lose money or proparty 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 Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR
EXPENSES BEFORE THE 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
1 Courthouse Square
Carlisle, PA 17013-3387
Telephone: (717) 240-6200
010211.00001/Juno 17. 1997/DWD/MH/64SS3
C, RICHARD HARRISON,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. q 1- :11,1'1 C(u.:! 0..-
Plaintiff
vs,
IN DIVORCE
ELIZABETH A, HARRISON,
Defendant
COMPLAINT IN DIVORCE
UNDER SECTIONS 3301fcJ OR 3301fdJ OF THE DIVORCE CODE
AND NOW, comes the Plaintiff, C. Richard Harrison, by his attorneys, Johnson, Duffie, Stewart
& Weidner, and files this Complaint in Divorce of which the following is a statement:
1, The Plaintiff, C, Richard Harrison, is an adult individual residing at 133 West Locust Street,
Apr. C7. Mechanicsburg, Cumberland County, Pennsylvania.
2. The Defendant, Elizabeth A, Harrison, is an adult individual residing at 1005 Chippenham
Road. Mechanicsburg, Cumberland County, Pennsylvania.
3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least
six months previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on July 7, 1979, in York. York County,
Pennsylvania, and separated on or about September 2, 1996,
5. There have been no prior actions for divorce or annulment between the parties,
6. The Plaintiff has been advised of the availability of marriage counseling and that the Plaintiff
may have the right to request that the Court require the parties to participate in counseling.
7. The marriage is irretrievably broken.
010211'OOOO1/Juno 17, 1997/DWD/MH/64553
.
C, RICHARD HARRISON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, cU. .J~ 1'1 C{~:.. (' U "'.
vs,
IN DIVORCE
ELIZABETH A. HARRISON,
Defendant
AFFIOA vIr
C, RICHARD HARRISON, being duly sworn according to law, deposes and says:
1, I have been advised of the availability of marriage counseling and understand that I may
request that the court require that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the Prothonotary's
Office. which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse and I participate
in counseling prior to a divorce decree being handed down by the court,
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 falsification
to authorities.
Date: 6.2 7 -</7
(,/{...,t.w"<~) /t;.:~
C. Richard Harrison
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MARIA p, COGNETII & ASSOCIATES
Allorneys and Counselors 01 Law
210 Orandvlew Avenue, Suite 102
Camp Hili. PAI701I .
(717) 909-4060 ~C..I~) 909-4068
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C. RICIIARD HARRISON,
Plaintiff
: IN TIlE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: No. 97-3614 Civil Term
ELlZABETII A. IIARRISON,
Defendant
: CIVIL ACTION - LA \V
: IN DIVORCE
AFFIJ)A VIT OF CONSENT
1, A Complaint in Divorce under Section 3301(e) of the Divorce Code was liIed on
July 2, 1997.
2, The marriage of PlaintilTand Defendant is irretrievably broken, and ninety (90)
days have elapsed frlllll the date of the filing and service of the Complaint.
3, I eonsentto the entry ofa final decree of divorce afier service of notice of
intention to request entry of the decree,
I verify that the statements made in this affidavit arc true and correct. I understand that
false statements herein are made subject to the penalties of 18 l'a,C.S, Section 4904 relating to
unsworn Ihlsifieation to authorities,
Date: qj ~i/O/
_ _~: IM'-..ui..2..L~_
c. RICHARD HARRISON, Plaintiff
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MAlUA p, COGNn'IT1 & ASSOCIATES
Allorne)'! and CoulUe/or! 01 Law
210 Grnndvlew Avenue, Suite 102
Camp Hili, PA 17011
(717) 909-4060 ,J.px-J~I7) 909-4068
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C. RICIIARD HARRISON,
PlaintilT
: IN TilE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: No. 97-3614 Civil Term
ELllABETII A. HARRISON,
Defendant
: CIVIL ACTION - LA \V
: IN DIVORCE
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1.
I eonsentlo the entry of a linal Deeree of Divoree without notiee.
WAIVER OF NOTICE OF INTENTION TO REOlJEST ENTIty
OF IHVORCE J)ECREE lJNJ)m
1\ 3301lc} OF TilE IHVORCE COJ)E
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2. I understand that I may lose rights concerning alimony, division of property,
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lawyer's fees or expenses if I do not elaim them before a divorce is granted.
3. I understand that I will not be divorced until a Divorce Decree is entered by the
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Court and that a copy of the Decree will be sent to me immediately after it is filed with the
I verify that the statements made in this anidavit are true and correct. I understand that
,
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Prothonotary .
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false statements herein are made subject to the penalties of 18 l'a,C ,S. * 4904 relating to unsworn
falsification to authorities.
DATE: 0/9/Dt
c: /~ ~
C. RICHARD HARRISON, PlaintilT
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MAlliA p, COGNETII & ASSOCIATES '
Allorneys ond Counselors 01 Law
210 Grandvlew Avenue, Sullo 102
'.CampHlII, PA \7011
(717)909-4060, "FQGI7) 909-4068
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C. RICIIARD HARRISON.
Plaintiff
: IN TilE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: No, ')7.3614 Civil Tern!
ELlZABETII A. HARRISON,
Defendant
: CIVIL ACTION - LA \V
: IN DIVORCE
AFFmA VIT OF CONSF:NT
I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
July 2, 1997,
2. The marriage of Plain tilT and Defendant is irretrievably broken, and ninety (90)
days have elapsed from the date of the Iiling and service of the Complaint.
3. I consent to the entry of a Iinal decree of divorce aner service of notice of
intention to request entry of the decree.
I verify that the statements made in this affidavit arc true and correct. I understand that
false statements herein arc made subject to the penalties of ] 8 Pa,C.S. Section 4904 relating to
unsworn falsilicationto authorities.
Date: q - 3 - 01
[); ~h((-(,- -a I...Jrt .1 '1(,1 f.j-r
ELlZ;(OETII ^, HARRISON, Defendant
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AIIOrm!)'J and CoulUDlorJ al Law
210 Ornndvlew Avenue, Suite t02
Camp 11111, PA t7011
(717) 909-4060~. FJliU7t7) 909.4068
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C, RICIIARD IIARRISON,
Plaintiff
: IN TilE COllin OF COMMON PI.EAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: No,lJ7-J614 Civil Term
ELlZABETII A.IIARRISON,
Defendant
: CIVIL ACTION - LA \V
: IN DIVORCE
W AIVEI{ OF NOTICE OF INTENTION TO REQUEST ENTRY
OF IlIVORCE DECREE UNDER
& JJOl{c) OF TilE DIVORCE COIlE
4. I consent to the entry of a Jinal Decree of Divorce without notice.
5. I understand that I may lose rights concerning alimony, division of property,
la\\yer's fees or expenses if! do not e1aim them before a divorce is granted,
6, I understand that I will not be divorced until a Divorce Decree is entered by the
Court and that a eopy of the Deeree will be sent to me immediately after it is filed with the
Prothonotary ,
I verify that the statements made in this affidavit arc true and correct. I understand that
t~lIsc statements herein :)n.~ made ~uhjcct. II) ~'!e pf:na!tie~ of! ~ P3.C.S. ~ 190'1 relating to U:iS\VOfll
falsiJieation to authorities.
DATE: 9 - 2-;) - D I
c _C 1,,0.: (l t-f,- a. fj-tll1U CI^-.
ELlZAIlE'IJII A, HARRISON, Delendant
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IN Tim COUIlT 01' COMMON Pl.EAS OF
CUMUI,IlI.AND COUNTY. PENNSYLVANIA
CIVI I. ACTION - LAW
VB.
No.Q1;%lf
IN DIVORCE
19
CIVIL
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STATUS SlIImT
DATE: ACTIVITIES:. L. . j., ___I-
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C. RICHARD HARRISON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
VS.
ELIZABETH A. HARRISON,
Defendant
NO. 97 - 3614 CIVIL
IN DIVORCE
RESCHEDULED PRE-HEARING CONFERENCE
TO: Catherine A, Boyle
Maria P. Cognetti
, Counsel for Plaintiff
, Counsel for Defendant
A pre-hearing conference has been scheduled at the
Office of the Divorce Master, 9 North Hanover Street, Carlisle,
Pennsylvania, on the 3rd day of December, 1999, at 9:30 a.m., at
which time we will review the pre-trial statements previously
filed by counsel, define issues, identify witnesses, explore the
possibility of settlement and, if necessary, schedule a hearing.
Very truly yours,
Date of Notice: 9/15/99
E. Robert Elicker, II
Divorce Master
i ~
C. RICHARD HARRISON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs,
NO, 97 - 3614 CIVIL
ELIZABETH A, !lARRISON,
Defendant
IN DIVORCE
RE:
Prehearing Conference Memorandum
DATE:
Friday, December 3, 1999
Present for the Plaintiff, C, Richard Harrison, is
attorney Catherine A. Boyle, and present for the Defendant,
Elizabeth A, Harrison, is attorney Maria P. Cognetti,
A divo=ce complaint was filed on July 2, 1997,
raising grounds for divorce of divorce of irretrievable
breakdown of the marriage, Counsel have indicated 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 to be scheduled in these proceedings,
On March 22, 1999, the Plaintiff filed an amended
complaint raising the economic claim of equitable
distribution, A petition was filed by the Defendant on
April IS, 1999, raising the economic claims of alimony,
alimony pendente lite, and counsel fees and expenses. With
respect to the alimony claim, counsel have indicated that
they do not intend to present any evidence with respect to
the factor of marital misconduct,
The parties were married on July 7, 1979, and
separated September 2, 1996, They are the natural parents
of two minor children, Christina, born June II, 1985, and
Richard, born June 24, 1988, Both children are in the
custody of wife,
!lusband is 51 years of age and resides at 1500
Timber Chase Drive, Mechanicsburg, Pennsylvania, where he
lives alone, This is a recently purchased town home, The
property was purchased subsequent to the separation of the
parties, Husband is self-employed as a dentist, He has a
DMD and is a partner in Mendelson, Foer and Harrison,
Based on the support proceedings and an order entered on
November 19, 1998, husband's net income was computed to be
$8,923,00 per month, !Ie is currently paying spousal support
in the amount of $1,909,00 per month and child support in
the amount of $1,758,00 per month, Husband has not raised
any health issll<'s, Husband is currently covering the wife
and children on his medical insurance policy,
upon the entry of a divorce decree wife will
to coverage under husband's current plan and
know the cost to wife of maintaining her own
coverage,
Most likely
not be entitled
we will need to
health
Wife is 45 years of age and resides at 1005
Chippenham Road, Mechanicsburg, Pennsylvania, where she
lives with the two children, She is also a DMD but has an
additional speciality in pediatric dentistry, She currently
works part-time for Dr, James Call and reports her net
monthly income at $1,500,00, Wife has not raised any health
issues.
Wife lives in the marital real estate at 1005
Chippenham Drive, Mechanicsburg, Pennsylvania, The property
was purchased for $216,400,00, Wife believes the property
is currently worth $225,000,00 and husband has set a value
on the property of $275,000,00, Because of differences in
opinion of the parties as to the value of the real estate,
it is probably necessary that the property be appraised and
counsel will attend to that within the next month and share
the appraisal report or reports with each other, The
property is currently subject to a mortgage in favor of
Fleet Mortgage Company and as of June 16, 1999, the payoff
was $95,046,93, Wife is paying the mortgage payment
monthly in the amount of $1,750,00 which includes taxes and
insurance Wife's counsel has indicated that wife would
like to retain the home,
Husband has a one third interest in the general
dentistry practice at Mendelson, Foer and Harrison and
counsel are going to have the interest of husband valued,
Wife is using Mr, Brown and husband, Mr, DeMuth, Husband
bought into the practice in October 1990 and made his first
payment in January 1991, His last payment is due December
1999, He paid $200,000,00 for the buy in, The practice is
conducted in a building at 4824 East Trindle Road,
Mechanicsburg, Pennsylvania, and according to husband the
property was appraised in January of 1998 for $670,000.00,
There is currently a mortgage against the property in the
amount of $520,000,00 leaving equity of around $150,000,00,
Husband's one third interest then computes to be around
$50,000,00 in the real estate,
The parties have a Dean Witter retirement
account, IVY funds in l!U\s, and Corestate checking and
savings account.s, The liean \'Ii tter account. as of June 1998
had $12,472,1,1 in the account. Husband's position is that
the Dean Witter account is nonmarital. Husband's IVY fund
IRA as of June 1996 hild $44,656,23 in the ilccount,
Ilusbilnd's counsel has pointed out that the amount of funds
in husband's IVY fund IRA ilccount include some premarital
and other nonmarital contributions. Documentation on the
marital portion of the account should be provided to
attorney Cognetti to see if she can agree as to how the
value is computed for purposes of equitable distribution,
Wife has an IVY fund IRA account and as of December of 1998
that fund was valued ilt $31,570,00,
The Corestates checking and savings accounts were
valued at around $25,000,00 ilnd wife received the benefit of
both of those accounts,
Husband also has a 401(k) with his dentistry
practice but counsel for husband has pointed out that
$9,000.00 in that 401(k) are post-separation contributions,
Wife has a 1997 Honda Odyssey which her counsel
has valued net at $7,650,00, Husband has a 1995 Honda
Accord and wife has valued that vehicle at $11,075,00,
Husband is going to provide his opinion as to the value of
those vehicles to see if there can be any stipulation as to
the value, Husband has been making the payments on the
Honda Odyssey since separation and the amount of payment
monthly is $485,00, He has been making these payments in
addition to paying the support order,
Both counsel and the parties have agreed that the
household tangible personal property has a value of
$7,500,00, Wife has retained the personalty, therefore, she
will be charged with receiving an asset with a value of
$7,500,00. Also, she will be charged with receiving the
value of the Corestates checking and savings accounts at
around $25,000,00,
The only marital debt is the mortgage with Fleet
Mortgage Company and a Visa account with a balance of around
$2,800.00,
After discussion with counsel, they have agreed
that the reports and the evaluators for the dentistry
practice should be completed and exchanged by February 15,
2000, It is anticipated the evaluators will meet with each
other prior to completing their reports on or before January
15, 2000, Counsel will exchange any information that is
derived from the meeting of the accountants or their reports
and then each counsel will have an opportunity to prepare a
rebuttal report if necessilry prior to the heilring,
A hearing is scheduled for Wednesday, May 31,
2000, to take the testimony of any expert witnesses and any
additional testimony, including the parties and other
witnesses, will be completed by the end of the day on
Thursday, June 1, 2000, Notices will be sent to counsel and
the parties.
E. Robert Elicker, II
Divorce Master
cc: Catherine A, Boyle
Attorney for Plaintiff
Maria p, Cognetti
Attorney for Defendant
1\'1lARIA P. CO(JNE'I~1'I & A~~()CIATE~
A /t"mey.I' 1111<1 ( '/lIII/xel",.,I" 1111.//11'
I'I"I/c/h'e 1.;/IIi/eel/" MIII,.;/II"//;IIII.IIII'
Maria P. Cognclli.
AllumcyOll.u\\
Koren A. Sheriff
PlUalcgaJ
trdltlw. Amcm:an AcadcnI) ur
~tnlrlnhJnlall.8\\)Cr\
September 20.2001
Robert Elicker. II, Divorce Master
Cumberland County
9 North Hanover Strecl
Carlisle. P A 17013
RE: Harriso" v. Harriso"
Ollr File No. 61
Dear Mr. Elicker:
Enclosed please find two copies of the fully executed Property Settlement Agreement in
the above-referenced matter. Upon your receipt of same, would you kindly proceed to have your
appointment revoked.
Thank you for your attention to this matter. Should you require any further infonnation.
please do not hesitate contact me.
MPC/sab
Enclosures
ee: Dr. Elizabeth Ilarrison
210 (irandview A,enue. Suile 1112 . Camp lIill,l'A 171111
relephune (717) l)1ll)-~1l1111 . Fa, (7171l)1ll).~1lI1R
1:ll1ailt'ognCltil,u\\ill,ltol.l.:orn
C. RICHARD HARRISON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97 - 3614
:
vs.
CIVIL ACTION - LAW
ELIZABETH A. HARRISON,
Defendant
: IN DIVORCE
ORDER AND NOTICE SETTING HEARING
TO: C. Richard Harrison , Plaintiff
Catherine A, Boyle , Counsel for Plaintiff
Elizabeth A. Harrison Defendant
,
Maria P. Cognetti 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 31st and 1st days
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.
" , O,Vi'"
'g' ". t:~l,.
Pres iden t Judge
Date of Order and
Notice: 12/3/99
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,
CUMBEI1!.ANIl COllNTY IlAI1 ASSOCIATION
;, LillI-iii Y AVENlIE
CAli!. I ~;! I,:, 1',\ 170 II
TEI.Ei'llflNI.: I; I; I :'4'1- \161>
'^
&/I~~nft j
C, RICHARD HARRISON,
Plaintif f
vs,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-3614 CIVIL TERM
ELIZABETH A. HARRISON,
Defendant
CIVIL ACTION
IN DIVor,n.
PLAINTIFF C. RICHARD HARRISON'S PRE-TRIAL STATEMENT
PURSUANT TO PA,R,C,p. 1920,33
Meyers, Desfor, Saltzgiver & Boyle, hereby files his Pre-trial
Plaintiff C. Richard Harrison, by and through his counsel,
Statement Pursuant to Pa.R,C.p. 1920.33:
I. FACTS AND PROCEDURAL HISTORY The parties, Richard Harrison
lawfully married on July 7, 1979. They have two minor
and Elizabeth Harrison, are Husband and Wife having been
children, Christina (date of birth June 11, 1985) and
Richard (date of birth June 24, 1988). The custody issues
The parties share legal custody.
physical custody with liberal pilrt ial custody in HURbimri
have been resolved by way of Agreement. IHfe has priC1:11")'
Husband graduated from dental school in 1977 and met
Wife a couple of years later, while she was a dental sclluol
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together in May 1980.
student. Thereafter, the parties opened a dental practice
certificate in pedodontics, dentistry for children. Both
In 1981-1982, Wife returned to school and received her
time as a specialist.
continued to work in the practice, with Wife working part-
In 1990, the parties sold their practice. Husband
MEYERS, OESFOR, SAlTlGIVER & BOYLE
~Hl NOHIH SlCONO STIli (I . I'D nm: 101;( . IlAnf:IISmmc; f'A 17HJfl
1!17J~'itj'l";)H . fAX(717)23b'7H'"
II
II
II
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I,
.
On or about March 22, 1999, Husband filed an Amended
Divorce Complaint seeking equitable distribution of the
marital assets, A Motion EOl- Appointment of a Master was
filed by Husband contemporaneously with his Amended
Complaint. Wife filed a Petition for Alimony, Alimony
Pendente Li te and Counse 1 p,.'es on Ma rc:h 15, 1999. By n'-d,-,r
of Court dated May 6, 1999, Master E, Robert Elicker was
appointed to hear this matter. This Pre-trial Statement is
submitted in compliance with Master Elicker's directive to
file same.
II. ASSETS,
See attached Inventory and Appraisement of C.
Richard Harrison previously filed on March 22, 1999, marked
Exhibit "B".
III. EXPERT WITNESSES.
A. Crystal St. Omeroy, C.P,A.
B. William J. Daylor, MAI, SRPA,
C. Residential real estate appraiser to be announced, if
necessary.
D. Furniture/furnishings appraiser to be announced, if
necessary.
E. Valuation expert to be announced, if necessary.
IV,
OTHER WITNESSES.
A, C. Richard Harrison
MEV[flS. OESFon, SAlTZGIVE.R & BOVlE
.ITI1I,mUIl s!corm SIHII' . PO 11I)X It,".' . ItAlH1ISBl!lH. 1'.\ 1,'l(l1l
(,., .') ~) H) <j,I.'[; . 'AX (1111 ~>!t) :'!l' ,
.
B, Elizabeth A, Harrison
Husband retains the right to call l"nbuttal
I
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witnesses.
V, LIST OF EXHIBITS,
A. Appraisal of 1005 dlippenham Road, Mechanicsburg,
Pennsylvania.
B.
Appraisal of 4824 Trindle Road, Mechanicsburg,
,
,
I
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Pennsylvania.
C. Mortgage statements as of date of separation and
current date for 4824 Trindle Road, Mechanicsbura,
Pennsylvania.
D. Wife's pay stubs.
E. Husband's pay stubs,
F. Joint tax returns.
G, 1998 separate tax returns.
H, Tax calculations.
I, Checking/savings account statements.
I
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I
I
J. MAC receipts.
K.
Current lease/other expenses for 4824 Trindle Road,
Mechanicsburg, Pennsylvania,
L.
Retirement account stntements.
M. Furniture inventory and ,lPF)f"aisal of same,
N. credit card stLltC'tnt?lltS.
O. Documentation of credit/marital debts paid by Husband
since date of s"par,lt ion.
'.
Ml YlIlS. [)[sron, SALTIGtVER & BOYLE
.IIL '.n'"H ~,I ((1'111 '.IHII' . I'n !IU( l()t>2 . ttAIHlISlltJf1Ci. PA 1710B
1,'\,',.; 'I. ".1.'11 . fAll' (illl,':!!, ;'1-11;'
p,
Both parties' Income and Expense Statements,
I
!
II
,
!
i
,
Q,
N.A,D,A. Values,
R.
Documentation of vehicle debt/p<lyments as of separation
and present date,
S, Health Insurance documents/costs.
T. valuation of Mendelson, Fe,,'r imd Harrison/supporting
documents.
U, Husband's cash flow.
V. Partnership Agreements for Mendelson, Foer and
Harrison.
W. Note payable for Mendelson, Foer and Harrison.
X, Loan amortization schedule,
Y. Documentation of Pediatric Dentist salary.
Husband retains the right to submit rebuttal exhibits.
VI. INCOME & EXPENSES, See <ltt<lcheu Income and Expense
Statement of C. Richard Harrison previously filed on
I November 19, 1998, marked Exhibit "CO.
III
VII. DEFENDANT'S EXPENSES. See attached Income and Expense of
~ Elizabeth Harrison previously filed on November 19, 1998,
I'
~ marked Exhibit "D".
VIII .
PENSION OR RETIREMENT BENEFITS, During the marriage,
the p,lrties eilch erit'lbl i~,l1t::"rl .:111 individual rl~t i r~~!W'''llt
"
MEYEUS. DESFOA. SALTZGlVEA & aOYLE
.11il fj{}Il' II ~,~l (OM) ~; 1111 f r . I' 0 BOll ll1(;;' . ttAIH11SIIlJllli F'A 1110H
(lli);:;h'I.I,'1I . r^Xjl'lI,.lh~'Hll
XII, PROPOSED RESOLUTION.
Date
IIUHb;lIJd pnJposes tholt- lIP boo l\~lJdpd
60% of the net marital as::;ets Clnd Wife be awarded 40% ot the
11et tnarital assets.
Respectfully submitted,
atherine A, Boyle, Es
MEYERS, DESFOR, SALTZG
& BOYLE
Attorney I.D, #76328
410 North Second Street
P.O. Box 1062
Harrisburg, PA 17108
(717) 236-9428
Attorney for Plaintiff
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MEYEns. orSfon, SALTIGIVU\ 8. UOYll
l\'lt;(IH'"~~I{Ot.ll':Il<lIT . 1'(lH' \~"'. . HMH.I',IHHil,I'r.I,tl,j.
1:':,1" ". ",1..11 . I..." 1:1:, ,"" ,'111:
'.
A'f))A~
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fl...' , 131"'"
.R~~. '?fl.,
211 East Chicago Avenuo
Chie1go, Illinois r.ooll
312.44(}.2568
Survey C~nler
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The 1993 Survcy of Dcntal Practice -
Specialists in Private Practice
EXHIBIT
fA
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Table 7: 'Net Income of Independent Speci3lisls by Source' of Dent31lncome, 1992
Specially Mean' 1st Qumlile' Median' 3rd Quartile' Standard N'
Deviation'
Oml and M3xillofacl31 Surgeons
Primary Private Practice $171,836 $100,000 $160,000 $225,000 $ 92,194 317
Tolal from Privale Pmctice 174,553 100,000 160,000 230,000 92,793 316
Tolal from Denlistry 177.457 105,000 160,000 238,000 93,982 316
Endodontists
Primary Private Practice 171,574 102,820 160.000 225,000 87,309 165
Total from Private Pmctice 172,365 105,000 160,000 225,000 86.691 165
Total from Dentistry 175,301 108,000 165,000 228,000 86,998 165
Orthodontists
P,imary Private Practice 153.239 80,000 138,564 196.544 105,392 444
Total from Private Practice 155,563 87,000 139,564 200,000 104.444 444
Total from Dentistry 157,368 89,738 140,000 200,000 104,926 444
Pediatric Dentists
Primary Private Practice 145,020 79,150 120,000 188,148 106,524 168
Total from Private Practice 146,270 79,150 120.500 190,000 107,379 168
Total fro", Dentistry 148,558 79,650 121,000 193,787 108,168 168
Periodontists
Primary Private Practice 138,575 84,000 120,000 185,109 83,527 239
Total from Private Practice 142,073 90.000 125,000 190,000 83,722 239
Tolal from Dentistry 144,329 90,000 128,000 190,000 85,834 239
Prosthodontists
Primary Private Practice 119,566 62,000 92,000 150,000 105,023 99
Total from Private Practice 120,334 62,000 100,000 150,000 104,688 99
Total from Dentistry 123,544 69,000 104,000 152,000 104,074 99
Overall
Primary Private Practice 153,702 85,000 137,000 200,000 98,230 1433
Total from P,ivato Praclice 155,884 90,000 140,000 200,000 98,159 1432
Tol;,1 from Deotd,v 158 290 90,000 140000 200 000 98973 1432
Sourc(' Anll.'rlC,ln Den!a! A~.~.O(IJtlon, SUl'\iey Cenler. 19'J.1 fiw~~''i of P'~r1!~l,ryJ,l{::!I_Cf' _' :'f"~_I.lll,!!sjt!.11!(ol'{' rr~.~!~~.
.. Oelinrt,ans ollhe flH"m, 1,t '1ua,t,le, median, 3rd qu",III", "nd c,l""cj",d devialion (S.o) can be
fou"d '" Ihe glossa,y
J N " IllllTlIHll of /f~r,pOfHh'llh
8
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'Table 8: Net lricome' of Independent Specialists by Age and Source of Dental Income, 1992
Under 40 Years of Age 40 Years of Age or Over
Mean S,D, Number Mean S.D. Number
Oral and Maxillofacial Surgeons
Primary Private Practice $190,226 S100,006 62 S167.365 $ 89,834 255
Total from Private Practice 192,169 96,144 62 170.253 91,125 254
Total from Dentistry 193.262 97,863 62 173.595 92,799 254
Endodontists
Primary Private Practice 154,096 63,854 44 177,929 93,630 121
Total from Private Practice 155.669 62,457 44 178,429 93,456 121
Total from Dentistry 160.791 66,706 44 160,577 92,450 121
Orthodontists
Primary Private Practice 139,510 66,901 107 157,599 109,673 337
Total from Private Practice 144,946 65,341 107 156,934 109,715 337
Total from Dentistry 148,065 86,072 107 160,322 109,691 337
Pediatric Dentists
Primary Private Practice 105,652 62,121 41 157,730 114,663 127
Total from Private Practice 107,846 60,703 41 156,675 116,090 127
Total from Dentistry 106,609 61,193 41 161.456 116.756 127
Periodontists
Primary Private Practice 116.532 65.851 57 144,852 67,556 182
Tolal from Private Practice 124,724 64,739 57 147,506 68,293 162
Tolal from Dentistry 125,696 65,545 57 150,164 90,636 182
Prosthodontists
Primary Private Practice -- ,- 26 126,169 116.210 71
Total from Private Practice -- -- 26 127,175 115,767 71
T alai from Dentistry -, -- 26 129,883 115.015 71
Overall .
Primary Private Practice 140.022 64,677 339 157,941 101,803 1094
Total from P,ivate Practice 143,624 82,587 339 159,686 102,246 1093
Total from Dentistry 146,101 84,199 339 162,070 102,869 1093
~;O\Jrcc l\nll'I~:.I:J (kn~,ll A!.SC'~'I,lld'll ~'dj1\'I', C..~~I"'. l~t:jJ ~ ~!r\\'I' ('!J','n:.l~ Pld. :" I'. ~,;, .,'!I',t"~'l_I_'D!",t"".r.r,!~~~
10
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Table 18: Netlncorne, Age, and Hours Worked lor Independent Orthodontists
by Hours Worked and Source of Dental Income, 1992
f
Mean 1 st Quartile Median 3rd Quartile Standard N
Deviation
Less than 32 hours;
Primary Private Practice $114,067 $48,000 $ 79,000 $160,000 $ 96,640 69
Total from Private Practice 122,156 55,000 100,000 175,000 97,962 89
TDtal frDm Dentistry 125,212 60.000 100,000 175,000 97,330 89
Dentist Age 50,9 43,0 50,5 60,0 11.1 130
HDurs WDrked per Week 24,6 20,0 27,0 30,0 6,1 130
32 hDurs Dr mDre:
Primary Private Practice 163,060 95,000 143,000 200,000 104,675 355
TDtal frDm Private Practice 163,938 97,360 143,000 200.000 104,466 355
T Dtal frDm Dentistry 165,430 98,000 145,000 200,000 105,344 355
Dentist Age 47,9 40,0 46,0 55,0 10,2 579
HDurs Werked Der Week 36,9 34,0 37,0 40,0 7,1 579
Source American DenIal As~ialion, Survey Cenler, 1W3 Sur.ev of DenIal Praclice~i3tisls in Private Praclice.
Table 19; Net Income, Age, and HDurs Worked for Independent Pediatric Dentists
by HDurs Worked and Source of Dental Income, 1992
Mean 1 st Quartile Median 3rd Quartile Standard N
DeviatiDn
Less than 32 hours:
P,imary Private Practice $ 87,287 $29,000 $ 81.487 $ 135,000 $ 74,246 30
TDtal from P,ivate Practice 89,520 29,000 81,487 140,000 74,221 30
Total from Dentistry 90,223 29,000 82,687 140,000 74,382 30
Dentist Age 50,8 39,0 50,0 61.0 12,8 46
Hours Wo,ked per Week 26,0 240 280 30,0 4.7 46
32 hours or more;
Primary P,ivato Practice 157,571 85,875 131,500 200.000 108,521 138
Total from Private P,actice 158,607 85,875 131,500 200.000 109,684 138
Total f,orn Dentistry 161,240 90,000 133,500 200,000 110,362 138
Dent,st A(lo 46,3 400 .~6 0 51,0 8,0 194
Hours Wor~"d ~ W"ck 400 ~D (I 380 42,0 7.7 194
,.- ' .. .. ,=" ---'.---'- ---- -. --' - . - .. -
~"Ll:~t f' f<n~f'rlcan Ih'f"Ji f,~;.,(}(I,l!i 'll, ~,t:l...y (t'r:~l.r ltr(~', '.\"," 'lkl'~ .11'I,H "~f" ~'P",'(I;!~I~,I.~~ U1l'llv,lt~J~r,~\".;I~~~
/1
Table 24: ,Net.lnc~me 01 Solo Specialists by Ag~ and Source of Dentai Income, '1992
Under 40 Years 01 Age 40 Years 01 Age or Over
Mean S.D, N Mean S,O. N
Oral and Maxillolacial Surgeons
Primary Private Practice $188,211 $102,485 38 $154,270 $ 90,468 155
Total from Private Practice 191,316 99,496 38 156,578 90,631 154
,-
Totallrom Dentistry 193,132 99,048 38 158,718 90,883 154
Endodontists
Primary Private Practice 139,644 55,856 30 157,842 93,495 72
Total from Private Practice 141,977 54,096 30 158,362 93,111 72
Total from Dentistry 149,427 65,834 30 160,631 91,641 72
Orthodontists
Primary Private Practice 139,740 89.676 85 152,496 112,588 276
Total from Private Practice 144,583 86,759 85 153,988 112,328 276
Total from Dentistry 147,990 90,189 85 155,283 112,335 276
Pediatric Dentists
Primary Private Practice n -. 29 153,081 115,274 94
Totall,om Private Practice n -- 29 . 152,943 115,472 94
Total from Dentistry .. -- 29 155,686 115,931 94
Periodontists
P,imary Private Practice 123.091 69,129 45 128.657 77 ,958 136
Total from P,ivate Practice 126,491 68,394 45 132,209 79.774 136
Total from Dentistry 127.035 68,355 45 135,068 83,874 136
Prosthodontists
Primary Private Practice '- .. 21 100,014 62.878 51
Total from P,ivate Practice n .. 21 100,603 62,731 51
Total from Dentist'y n .. 21 102.941 61,797 51
Overall
Prima,y P,ivate Practice 135,615 83,597 248 145,858 99,851 784
Tolal from P,ivatc Practice 138.997 81.786 248 147,514 99,985 783
Total from Dentistrv 141,817 83,990 248 149,579 100,476 783
Souret. Amtfl,:.ln Denlill A",~VCI.1llon. ~Ur.'l:l Cf'nler, 1993 Sll/VC'Y of Dg.Qlill PrE-.cJ.!.t;E. Sr)('ciahsls in Privale P!.~cljc~,
2l
Table 25: Net Income 01 All Solo Specialists bi' Region and Source of Dental Income, 1992
Region Mean 1st Oua,lile Median 3rd Ouartile Standard N
Deviation
Primary Private Practice
New England S134.943 S75.000 S120,000 S186,484 $ 86,603 72
Middle Atlantic ' 124,891 58,332 , 116,500, 170,000 83,354 174
East North Contral 150,169 79,300 127,500 189,000 106,539 142
West North Central 156,257 96,500 136,101 200,000 111,338 56
South Atlantic 154.651 90,000 134,500 185,653 101,544 192
East South Central 151,324 80,500 140,000 208,000 90,534 63
West South Central 147,626 79,000 135,000 199,000 93,025 85
Mountain 135,941 75,000 105.000 185,000 97,973 73
Pacific 145,533 76,000 120,000 200,000 94,515 165
Totallrom Private Practice
New England 137.761 77,500 120,000 186,484 85,873 72
Middle Atlantic 128,925 67,000 120,000 179,362 84,153 173
East North Central 152,933 80,000 130,000 200,000 106,028 142
West North Cenlral 156,418 96,500 136.101 200,000 111,159 56
Soulh Atlantic 155.726 90,000 136,250 185,653 100.874 192
East South Central 151,740 80,500 140,000 208,000 89.749 63
West Soulh Central 148,189 79,000 135,000 199,000 92,725 85
Mountain 136,900 79,000 105,000 185,000 97,4 51 73
Pacific 148,311 81,000 121,000 200.000 94,668 165
Totallrom Dentistry
New England 139,443 80,000 121,165 186,484 86,535 72
Middle Atlantic 131,899: 75,000 . 1;:'),000 , 179.362 86,612 173
East North Cent,,,1 155,545 80,000 131,000 200,000 1 05,730 142
West North Cent,"1 156,548 96,500 136,501 200,000 111,170 56
South Atlantic 158,186 90,000 136,500 186,653 102,217 192
East South Cent,al 152,149 80,500 140,000 208,000 89,678 63
Wesl South Central 150,379 84,000 140,000 200,000 92,073 85
Mounlain 138,216 79,000 107,000 191,900 97,130 73
Pacific 151,158 81,671 125,000 202,084 96.619 165
Source ArrH'IlCJn (h.-IlIJ: A~~(oC!J!lOn. Sur.t'y Ccn:L:I, HI~IJ ;;W-,",!'f (,f n.on!;)) tJ'a~:,li(t.:' =-~'r~~:i~!'i!!L!!1..flJYi)t~ Pr<1.f.Ec~
;,j
C. RICHARD HARRISON,
Plaintif f
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-3614 CIVIL TERM
vs,
ELIZABETH A. HARRISON,
Defendant
CIVIL ACTION
IN DIVORCE
INVENTORY AND APPRAISEMENT
OF
C. RICHARD HARRISON
(xl Plaintiff (
Defendant files the following inventory
and appraisement of all property owned or possessed by either
party at the time this action was commenced and all property
transferred ~!ithin the preceding three years.
(x) Plaintiff ( ) Defendant verifies that the statements
made in this invelltory a!ld appraisClncllt are trllC and correct.
(x) plaintiff ( ) Defenciant unde,.stands that false
st':-ttements herein clre llIade ~Jub:iect to ::he penalties of 18 Pa.
C.S, 4904, rclatin'l to unSl'lOrn falsification to authorities,
'I
"
EXHIBIT
I~
ASSETS OF THE PARTIES
(x) PLAINTIFF ( ) DEFENDANT MARKS ON THE LIST BELOW THOSE
ITEMS APPLICABLE TO THE CASE AT BAR AND ITEMIZES THE ASSETS ON
THE FOLLOWING PAGES. IF AN 1:TEM HAS BEEN APPRAISED, A COPY OF
THE APPRAISAL REPORT IS A'1"l'ACHED.
(x) 1.
(x) 2.
(x) 3.
(x) 4,
(xl 5.
(x) G.
) 7 .
) 8 .
) 9.
) 10.
) 11.
) 12.
l 13 .
( ) 14 .
(xl 15,
16 .
(x) 17 .
( ) 18.
(xl 19.
( l 20.
( l 21.
( ) 22,
( ) 23,
( ) 24.
(xl 25,
26,
Heal Property
Motor vehicles
Stocks, bonds, securj.tj.cs and options
CertificateD of deposit
Checking accounts, cash
Savings accounts, money market and savings
certificates
Contents of safe deposit boxes
Trusts
Life insurance policies
Annuities
Gifts
Inheritances
Patents, copyrights, inventions, royalties
Personal property outside the home
Businesses (list all owners, including perc2ntage of
ownership, and officer/director positions held by a
party \'Ii th company)
Employment ten,lination benefiu5, severance pay,
workman's COmpe!lsatj,ofl cl~inl/award
Profit sharing plans
Pension plans (indic'-.lte elllplQyet:~ contribut:.on and
date plan vests)
RetirE:n\(~n.' plans, Individuill R(~t irern.'?nL IJ..ccs'Jntf3
Disability paynl~nts
Litigation clailllf3 (matUlca and Ullfllaturccl)
Military/V,A. benefits
Education b<:!lcfits
Debts duc, ~.ncluding loans, mort~.F19c:3 held
Ilousehold furnishings and personalty (include as a
total category and attach iterni~ed list if
distribution of such assct.B is ill dinpute)
Othel.
"
MARITAl" PROPERTY
(x) PLAINTIFF (
\~HICH EITHER OR BOTH
INDIVIDUALLY OR WITH
\~AS COMMENCED,
) DEFENDANT LISTS ALL MARITAL PROPERTY IN
SPOUSES HAVE A LEGAL OR EQUITABLE INTEREST
ANY OTHER PERSON AS OF THE DATE THIS ACTION
DESCRIPTION
OF PROPERTY
Furniture and Furnishings
NAMES OF
ALL OWNERS
C. Richard Harrison
Elizabeth Harrison
DATE OF
ACQUISITION
COST OR VALUE
AS OF DATE OF'
ACQUISITION
VALUE AS OF
DATE OF
SEPARATION
PRESENT VALUE
$7,500.00
A1~OUNT OF
JI.NY LIEN
NATURE OF
ANY LIEN
EFFECTIVE
DATE OF LIEN
HOLDER OF
LIEN
"
MARITAL PROPERTY
(xl PLAINTIFF (
NHICH EITHER OR BOTH
INDIVIDUALLY OR WITH
\1AS COMMENCED,
) DEFENDANT LISTS ALL MARITAL PROPERTY IN
SPOUSES HAVE A LEGAL OR EQUITABLE INTEREST
ANY OTHER PERSON AS OF THE DATE THIS ACTIO>:
DESCRIPTION
OF PROPERTY
Cores tate checking and savings accounts
NAMES OF
ALL ONNERS
DATE OF
ACQUISITION
COST OR VALUE
AS OF DATE OF
ACQUISITION
VALUE II.S OF
DATE OF
SEPARATION
9/96 approximate total account balance
~ $25,000.00
PRESENT VALUE
unknown; both accounts cashed by Nife
after date of separation
AI~OUNT OF
I,NY LIEN
NATURE OF
ANY LIEN
EFFECTIVE
DATE OF LIEN
1l0!JDER OF
LIEN
I"
NON-MARITAL PROPERTY
(x) PLAINTIFF ( ) DEFENDANT LISTS ALL MARITAL PROPERTY IN
I,HICH A SPOUSE HAS A LEGAL OR EQUITABLE INTEREST WHICH IS CLAIM:::D
TO BE EXCLUDED FROM MARITAL PROPERTY:
DESCRIPTION
OF PROPERTY
401 (K) at r.lendelson, Foer & Harrison
NAMES OF
ALL Ol1NERS
C. Richard Harrison
DATE OF
ACQUISITION
COST OR VALUE
AS OF DATE OF
ACQUISITION
VALUE AS OF
DATE OF
SEPARATION
PRESENT Vl'dJUE
approximately $9,000,00
AMOUNT OF
ANY LIEN
m\TURE Or-
ANY LIEN
EFFECTIVE
DATE OF LIEN
HOLDER OF
LIEN
11
NON-MARITAL PROPERTY
(xl PLAINTIFF ( ) DEFENDANT I~ISTS ALL MARITAL PROPERTY IN
\1HICH A SPOUSE HAS A LEGAL OR EQUI'1'AI3LE INTEREST WHICH IS CLAIMED
TO BE EXCLUDED FROM MARITAL PROPER1'Y:
DESCRIPTION
OF PROPERTY
1500 Timber Chase Drive
Mechanicsburg, PA
NAMES OF
ALL OWNERS
C. Richard Harrison
DATE OF
ACQUISITION
9/30/97
COST OR VALUE
AS OF DATE OF
ACQUISITION
$98,2GS,OC
V1>.LUE AS OF
DATE OF
SEPARATION
PRESENT VALUE
$3,265.00 ~quity)
AMOUNT OF
ANY LIEN
$95,000,0:
NATURE OF
ANY LIEN
m:)rt~Jage
EFFECTIVE
DATE OF LIEN
HOLDER OF
LIEN
National ~ity Mortgage
"
, .
LIABILITIES
(x) PLAINTIFF ( ) DEFENDANT LISTS ALL LIABILITIES OF EITHSR
OR BOTH SPOUSES ALONE OR WITH ANY OTHER PERSON AS OF THE DATE
THIS ACTION \~AS COMMENCED.
DESCRIPTION
OF LIABILITY
Corestates Visa NOl-3116668-8
N.'w1E OF
CREDITOR(S)
Np.NES OF ALL
DE3TOR(S)
C. Richard Hal-rison
Elizabeth Harrison
D.~.TE LIABILITY
\'I.~.S INCURRED
p';,:OUNT OF
LliillILITY ON
D.L.TE INCURRED
i'.J':OUNT OF
L:.l>.BnITY OJ,
O.L.TE OF
S:::?ARATION
$2,B27,7S
0;..: , BALi'.NCE
s.:::paratiOll
IS DUE
paid in full by Husb,,:;d after d.te of
P:::~IODIC PAYMENT
1-:',0 AMOUNT
1 :.~
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VT:R1TIC.i\'rIOH
I, ~, Richard lIarrison
, verify tha~ the
statemen;:s made in this INVENTORY AND APPRAISEHENT
i'
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are t!:"ue and
correct to
~'
Lne
~est of ;~lY J.:noh'l(:dge I information and be~ief.
I understand
"
'.:.112.t felse st.e'Ce;-.el1ts herein are made subject to the
I
::e!12.1'"C.ie~..: c: lE ;'2., C.S. Sec~ion 4904, :cr:lc.ting to uns"v.'c:n
~~lS:~lC2~i()!) ~c all~~la~l~iEs.
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Dated:
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(X)
Plaintiff
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Defendant
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C. RICHARD HARRISON,
Plaintiff
IN THE COURT OF COr~MON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 97-3614 CIVIL TERM
ELIZABETH A. HARRISON,
Defendant
CIVIL ACTION
IN DIVORCE
II
I
INCOME & EXPENSE STATEMENT OF
C, RICHARD HARRISON
Submitted by:
Cathe~ine A. Boyle, Esquire
Meyers, Desfor & Saltzgiver
,
I
,
I Date:
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November 18, 1998
Full Name of Clien~:
Age: 51
C, Richard Harrison
Present Address of Client:
Mec}lani.csburg, PA J~~55
1500 Timber Chase Dri .,;" ,
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I! Telephone'!
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i: Name of Ewplo':,er:
"
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I: Employer's 11ddress:
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!'\'umber:
732-8]70 Home
761-8056 \'Jork
';oc,li -elOp] eyed
:~elld01son, Foer & Harrison
~824 East Trindle Road
;~echallicsbul:~, PA
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EXHIBIT
I c
Uf '1'1 Ii'" ld ~,I Ill!" !:fd 1/(;1....( II
Ii: . .,
. It\i;," "',1:', ;,..'
(
ray period (weekly, bi-weekly, etc.)
INCOME
I Gross pay:*
I
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'I Deductions:
I,
II Federal:**
,I
!i F.I.C,A. :
'!
I:
Ii State Income Tax:
"
" Local Income Tax:
i:
"
ANNUAL FIGURES
PAY PER PERIOD
$167,614.00
$
$54,275.00
$4,693.00
$1,565.00
Hospital/Medical Insurance:
Life Insurance:
i'
( Pension/Profit Sharing:
$9,000.00
Credit Union:
Savings Bonds:
Ot.loer:
(Specify)
, TOTAL DEDUCTIONS:
s
r<ET PAY PER PERIOD: $'J'!,O'I(j,QO
~::: ., -: '1 ..
.~ - , - ' ... . . .
* Extrapolated [rom Sep~~.:::!::r_'-:.~r ~,~"::8 YP,'ll- to date
includes renLl1. income,
in'::-C::i0 :~~1\::
..-It Based on 5l~lf-emploYi:-.::,;nl t-.c"::'; 'Inri llI<-lI-ried fi.1.in~J ser~~::",ti>:_Y
~:;t(1tus. "life refuses tc file' t1 joint tax return.
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OTHER INCOME: None
(Fill in appropriate column)
WEEKLY
MONTHLY
YEARLY
Interest:
I
t, Dividends:
Ii Pension:
"
II A '
I, nnu~ty:
i'
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:! Social Security:
i ~
Rents:
Royalties:
Expense Account:
Gifts:
Unemplo~ne~: Compensation:
Worker's Compensation:
Other:
(Sp'2cify)
, $ $
" TOTAL OTHER INCOI1E: $
,
,
,
TOTAL NET E;~'Oi.1E : C' $ $
,,'
TOTl\L !-JET &. ~jTHE!\. I NCOi-iE : c' c' $
" .,
I.'! n II~.,III '~rOH A '.,\11/(;".-111
: : : I ~" :!; If! : : ( ,( ',' , i . I . ! I ; . '. i (.'" '
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EXPENSES:
WEEKLY
MONTHLY
YEARLY
Home:
Mortgage/rent
Maintenance
790.00
64.00
9,480.00
760,00
I Utilities:
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Electric
Gas
Oil
\1ater
Trash/Se\'ler
Telephone
tHfe's cell
Cell Phone
phone
112.00 1,344.00
24.00 280.00
33.00 396.00
62.00 744.00
80,00 960,00
70,00 840.00
:' Employment:
"
Ii
"
Public Transportation
Lunch
960.00
80.00
Taxes:
Real Estc\t:"2
Personal ?~operty
Income
I Insurance:
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HomeO\'mers
Automobile
Life
Accident
Other (mecii':ul
\-life and kiJsl
i\utomobile:
S.?2(',QO
10,00
133, DO
52.00
120,00
1,S96,OO
624,00
incl ud(~s
43';,00
Paymentfj {i'; i [I~' f; C:11)
Fuel
Hcpairs
Tires, 1,icc'nf~illq,
Regi st t'ill i:"n
4 ii'., 00
l\(j. on
l_~ C , on
'j. fl2C, OG
GOQ,OO
(,O~". 00
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M[Y[IlS, IH 51'01; ~ ~f,lllC,1IJr 1\
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Ii Miscellaneous:
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WEEKLY
MONTHLY
YEARLY
Household help
Child care
Papers/books/magazines
Entertainment
Pay television
Vacation
Legal fees
Charitable contributi0~S
Other child support
Alimony payments
Gifts (Christmas and
bi rthdays)
35.00
200,00
26.00
100.00
1\15.00
1\20.00
2,1\00,00
312,00
1,200,00
1\,980.00
80.00
960.00
Other:
Children's music
lessons/rentals
164,00
1,968.00
TOTAL EXPENSES:
5,373.00
76,476.00
'/
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. .
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C. RICHARD HARRISON,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 97-3614 CIVIL TERM
ELIZABETH A. HARRISON,
Defendant
CIVIL ACTION
IN DIVORCE
CERTIFICATE OF SERVICE
I hereby certify that on this I~ day of 12~
1999, a copy of the attached pre-Tr~al Staternent!;ursuant
to Pa.
R.C.P. 1920.33 was hand-delivered Lu:
Elizabeth A. Harrison
c/o Maria Cognetti, Esquire
200 North Third Street
Harrisburg, PA 17101
~
Cat erine A. Boyle
Attorney I.D. #76328
Attorney for Plaintiff
MEYERS, OESFOR. SAlTlGIVER 8. BOYlE
.110 tjOlil Ii ;;( cor,n ;; lIill' . f' 0 nux HIIo.' . ti.\HIH:;(IlJlh. 1''\ 1 :I()II
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~'~I~ ~.-;;-::....;tt':A1l98NIY~~I"'j\~~:tt~.:.t\-'J~,t ~\"~'d:'> :.~~~..~ '-: ~~r.._ :'., HARRIUURi1 PA.: I7loa ,,,~:. e ',.,.,:- 'T ..: ""~' t::"./ ~I'~:MJ..~ ;( ~;'~~'Fil; RNEY~L
-:::"'~H~";,-=-.\dJd"~\i rr~!~'~~f.~~'"'1J.1<"~:~ 'j"": y:r,.;.,.....~'.. ,- '." :: ,. 't' ',.,'. -';, . -" ~ \~ -'t::.":-,,, ':r-: ,~- ,-'>' ~_~"'~'::.'.~ ~: <"'-,~;:~, ~J:T~;'~"'t~;.n,~~'V.ii,.;
"-: ",'''''.1~.~~~\{.fl>11;.l41ht~.~:.~....;t;~.,~:.~..,", t";H':~' : I'.;'. ..,.', ~ ~ ': ,\\':,.....'" y..,.-I~"'";';.'~i"'-':'''''i(:;';'''{('J'.n'~;,y~~)'
.-. , :' ~:~'" ~...J /~Z~"~!!~~~~'t,..;.~. ~:'. ';, ~"\{:' ":~-':.;_._~~.',.,-~_L.....~--oc...~..._,-_:~-,;'..~.,':. ':' -' f_. ,.,' .,~t:;~<,: ~~I~~l~~.:.:~~:;:~~' :(~:~4,,\'-f~i.{~1~t~.~'r~~:t'~fi'
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C. RICHARD HARRISON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 97-3614 CIVIL TERM
ELIZABETH A. HARRISON,
Defendant
CIVIL ACTION
IN DIVORCE
PRAECIPE TO ENTER APPEARANCE
Please enter my appearance on behalf of the Plaintiff,
C. Richard Harrison, in the above-captioned matter.
Respectfully submitted,
Catherine
I.D.#76328
MEYERS & DESFOR
410 North Second Street
P.O. Box 1062
Harrisburg, PA 17108
(717) 236-9428
Attorney for the Plaintiff
MEYERS & DE Sf OR
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.1f~i~;~i~~fi:c!iU.:i.'::'~;;;:~~.:f,;':i1;;:~li~~fa...~
. ""-',--~'~"-----_._-'---"---~.,~ . .
C. RICHARD HARRISON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO.
97-3614 CIVIL TERM
ELIZABETH A. HARRISON,
Defendant
CIVIL ACTION
IN DIVORCE
PRAECIPE TO WITHDRAW APPEARANCE
TO THE PROTHONOTARY OF SAID COURT:
Please withdraw my appearance on behalf of the
Plaintiff, C. Richard Harrison, in the above-captioned
matter.
Respectfully submitted,
vid 0 Luce, Esquire
301 Market Street
Lemoyne, PA 17043
:r. {). 114/& 'l7
MEYERS & OESFOR
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. .
C. RICHARD HARRISON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 97-3614 CIVIL TERM
ELIZABETH A. HARRISON,
Defendant
CIVIL ACTION
IN DIVORCE
AMENDED COMPLAINT IN DIVORCE
COUNT I
EQUITABLE DISTRIBUTION
8. Paragraphs one through seven of the Divorce Complaint
filed on June 27, 1997 are incorporated herein by reference as i
set forth in full.
9. During the marriage, plaintiff and defendant have
acquired various items of marital property, both real and
personal, which are subject to equitable distribution under the
Divorce Code.
MEYERS. OESFOR, SALTlGIVrR & DonE
4LIt;(JIlTIIS.(Otj()51JHil .1'0 1I()x ll>t>.' . 1I^1H11~;(lIJIl(. PA L'l'li~
I,',!l :H; <j.I:H . 'AX rll?l.' III .HI!
WHEREFORE, plaintiff respectfully requests this Honorable
Court equitably distribute all property, both real and personal,
I tangible and intangible, acquired by the parties during their
marriage.
Respectfully submitted,
C herine A. Boyle,
1.0. #76328
MEYERS & DES FOR
410 North Second Street
P.O. Box 1062
Harrisburg, PA 17108
(717) 236-9428
Attorney for the Plaintiff
Ml yrllS, UlMOR, SAlTlGIVER & 1l0YL[
-Illlt.llHTlI:~lr()IH)SWII' .1'0 IlOl\, 1,~.' . It.\l'I\!~JI\\IHti 1',\"HI1
i?l.'i i ", 1.1.fl . I fly. In?).' H, ;1'17
C. RICHARD HARRISON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 97-3614 CIVIL TERM
ELIZABETH A. HARRISON,
Defendant
CIVIL ACTION
IN DIVORCE
CERTIFICATE OF SERVICE fA
I hereby certify that on this -l~~ day of fl/L~~
I
I, 1999, a copy of the foregoing Amended Complaint in Divorce was
II
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sent via U.S. mail to:
Elizabeth Harrison
c/o Maria P. Cognetti,
200 North Third Street
Harrisburg, PA 17101
Esquire
atherine A.
ID # 76328
Attorney for
Plaintiff
Mlnns, DESfon. SAlTlG'VEn & BOYLE
Illlj(lHl Ii ~( LU!Hl ~i 11111' . PO \lOx 1(11,;' . HAiHlI~1ll !n-; 1''\ 1/1,,11
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;- C. Richard Harrison
- ,
, "'2rify that ths
state:oen;:s lacee in this -1lJ1f.JillED COMPLAINT IN DIVORCE
ere trL::: ::nd correct to t.rd:
~: := 5 t
0~ :1\: ~':n::'i~lledge I
info~':7c.:ioi', =.nd
b- -..
c.~.,;::..
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,
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'~!':c.-:. fl:.~s~ S'L2.'::'.ClileI1ts herei:--: arc :-e.de SL:~~ct to t.::e
:: ':e:'la.::.:':.c~~~ c: :~ ?a. C,S. SQc'.::~orl .:;:01.;, :"::_,:7,'Cl;-'tS:'C ur.="'::::-I
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(fII'I'I
VERIFICATION
I, ELIZABETH A. HARRISON. hereby verify and state that the faets set forth in
the foregoing doeument are true and correetto the best of my infonnation. knowledge and
belief: I understand thatlalse statements herein are made subject to the penalties of 18 Pa.
C.S.A. ~4904 relating to unsworn verilieation to authorities.
{) . ~dv a. Muvu.cJc-r0
ELI~DETH A. HARRISON
DATE: 4/8/99
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C. RICHARD IIARRISON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-3614 CIVIL TERM
VS.
ELIZABETH A. HARRISON,
Defendant
CIVIL ACTION
IN DIVORCE
INCOME & EXPENSE STATEMENT OF
C. RICHARD HARRISON
Submitted by: Catherine A. Boyle, Esquire
Meyers, Desfor & Saltzgiver
Date: November 18, 1998
Full Name of Client: C. Richard Harrison
Age: 51
Present Address of Client: 1500 Timber Chase Drive,
Mechanicsburg, PA 17055
Telephone Number:
732-8170 Home
761-8056 Work
Name of Employer:
Self-employed
Employer's Address:
Mendelson, Foer & Harrison
4824 East Trindle Road
Mechanicsburg, PA
1
MEYERS. DESFOR & SALTlOIVER
410 NORTH SECOND STREET . PO 00>: 1062 . HARRISOURG. PA 17108
\1171236.9428 . FAX (717) 1362817
OTHER INCOME: None
(Fill in appropriate column)
WEEKLY
MONTHLY
YEARLY
Interest:
Dividends:
Pension:
Annuity:
Social Security:
Rents:
Royalties:
Expense Account:
Gifts:
Unemployment Compensation:
Worker's Compensation:
Other:
(Specify)
TOTAL OTHER INCOME:
$
$
$
$
$
$
$
$
$
TOTAL NET INCOME:
TOTAL NET & OTHER INCOME:
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MEYERS. DES FOR & SALTZGIVER
410 NORTH SECOND STREET . PO BOX 1062 I HARRISBURG. PA 11108
(7171236.9428 . FAX (717) 236.2817
EXPENSES:
WEEKLY
MONTHLY
YEARLY
Horne:
Mortgage/rent
Maintenance
790.00
64.00
9,480.00
768.00
Utilities:
Electric
Gas
Oil
Water
Trash/Sewer
Telephone
Wife's cell phone
Cell Phone
112.00 1,344.00
24.00 288.00
33.00 396.00
62.00 744.00
80.00 960.00
70.00 840.00
Employment:
Public Transportation
Lunch
80.00
960.00
Taxes:
Real Estate
Personal Property
Income
Insurance:
Homeowners
Automobile
Life
Accident
Other(rnedical includes
Wife and kids)
Automobile:
10.00
133.00
52.00
120.00
1,596.00
624.00
435.00
5,'220.00
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Payrnents(Wife's car)
Fuel
Repairs
Tires, Licensing,
Registration
5,820.00
600.00
600.00
485.00
50.00
50.00
4
MEYERS, DE5FOA' SALTZGIVER
410 NORTH SECOND STREET . PO BOX 1062 . HARRISBURG PA 17108
(7171236-9428 . FAX (7171236.2817
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I, C. Richard Harrison
, verify that the
statemen;:s made in this INCOME & EXPENSE STATEMENT
are true and correct to the
best 0~ T'Y kno\Jledge, information and belief.
I understand
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Dated:
11/19/98
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() Defendant
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C. RICHARD HARRISON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V'-
...
NO. 97-3614 CIVIL TERl~
ELIZABETH A. HARRISON,
~ Defendant
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CIVIL ACTION
IN DIVORCE
ORDER
APPOINTING MASTER
day of )1t a.y
, Esquire, is appointed
AND NOW, this
(gT'l
, 1999,
.
[' ,2.,. -ktd CL(./~
Master with
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Additional information,
none
if any,
relevant to the motion:
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1, C. Richard Harrison , ..'erify ;:l1a';:, the
statCr.1en;:s lI1ace in this NOTION FOR APPOINTHENT OF HASTER
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are tru~ and correct to the
best 0: r.~y kno,..'ledge, infol.-mation and be~:..ef.
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t}1b~ false s~a~eJnel)ts herein are nade s~~~ect to ~he
~p.n2.l t: GS 0: J..8 Pa. C. S. Section ~ 90'-, ~:.;:a~ing :'0 unSl,..Jc:r:"l
~i~~S:"~:~2~io~ ~o au~horlties.
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Dated:
3/19/99
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ME YERS & OESFOR
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!71]IDbC)..:]E . F':'\c71112J(.2S17
LAW OFFICtS
MEYERS, DESFOR. SALTZGIVER & BOYLE
"10 NORTH StCOND STRtE:T
P.O, BOX loez
I. E:MANUE:L ME:YE:RS (1915-19701
BRUCE: D. DtSFOR
LAURlt A. SALTZQIYE:R
CATHE:.RINE: A. BOYLe
HARRISBURG, PA. 1710B
17171136>e..ze
FAX (7171136>1817
June 10, 1999
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VIA FEDERAL EXPRESS OVERNIGHT MAIL
Office of Divorce Master
Cumberland County Court of Common Pleas
9 North Hanover Street
Carlisle, PA 17013
Re: C. Richard Harrison v. Elizabeth A. Harrison
No. 97-3614 civil
In Divorce
Dear Master Elicker:
Pursuant to your correspondence dated May 12, 1999, enclosed
please find one original and two copies of the Plaintiff's Pre-
trial Statement in the above-referenced matter. Would you kindly
file the original and return the time-stamped copies to my office
in the enclosed self-addressed stamped envelope. If you have any
questions please feel free to contact me.
CAB/skl
enclosure
cc: C. Richard Harrison
Maria Cognetti, Esq.
Very truly yours,
:t~~
~~?therlne A. Boyle
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LAW OHICCS
MEYERS, DESFOR, SALTZGIVER & BOYLE
"10 NORTH SCCOND STRCU
P.O. BOX 108Z
I. E:MANUE:L M[YCRS 11915.1970)
BRUCE: D. DCSFOR
LAURIE: A. SAL TZGIVE:R
C^THCRIN[ A. BOYLE:
HARRISBURG, PA. 17108
1111) Z3&-e4Z8
FAX 11171 Z38.ZIItI1
June 23, 1999
E. Robert Elicker, II
Office of Divorce Master
Cumberland County Court of Common Pleas
9 North Hanover Street
Carlisle, PA 17013
Re: C. Richard Harrison v. Elizabeth A. Harrison
No. 97-3614 civil
In Divorce
Dear Master Elicker:
In correspondence dated May 12, 1999, you instructed counsel
for both parties to file a Pre-trial Statement on or before
Friday, June 11, 1999. I have complied with your instructions
and have waited patiently for Ms. Cognetti to do the same.
I have not yet received any Pre-trial Statement or an
Inventory and Appraisement in this matter, as is required by the
Pennsylvania Rules of Civil Procedure.
It is difficult to impress upon one's client the necessity
to comply with the Rules of Procedure and instructions from the
Master, causing him to incur additional attorneys fees, all the
while watching his spouse and her attorney ignore the same.
Moreover, such disregard for procedure, makes it very difficult
to move this case to a speedy and amicable resolution.
This case has been dragging on considerably since the
parties separated in 1996. The wife is merely interested in
continuing this litigation so that she may collect additional
support payments. She has also applied for attorneys fees, costs
and expenses and it is my hope that you will recall this letter
when considering her claim.
I am left with no other choice but to ask you to impose
sanctions and to exclude any testimony and/or evidence that is
inconsistent with my client's position in compliance with
Pa.R.C.P 1920.33 (c) and (d).
MEYERS, DESFOR, SALTZGIVER & BOYLE
E. Robert Elicker, II
June 23, 1999
Page 2
Thank you for your attention to this matter.
Very truly yours,
Jik t:/
CAB/skl
cc: C. Richard Harrison
Maria Cognetti, Esq.
Catherine A. Boyle
MARIA P. COGNElTl'
~ C"g","i & B,,,I,,,,,",,
JAY R. IlRAIlERMAN
'fellow, American Academy
ur M.lrimonl.1 Law)'cD
KAREN A slIERIFF
P.u.le~11
June 3D, 1999
E. Robert Elicker, II, Divorce Master
Cumberland County
9 North Hanover Street
Carlisle, P A 17013
RE: HARRISON 1'. HARRISON
DOCKET NO. 97-36/4
Dear Master Elicker:
Enclosed for your file in the above-referenced mailer please find copies of
Defendant's Pre-trial Statement, Inventory and Appraisement and Income and Expense
Statement. Simultaneous with the filing of these documents they are being hand
delivered to the office of Allorney Boyle. I certainly apologize for any minor problems
which may have been caused by my delay in filing these documents. However, as the
Court knows, I am usually very prompt in my filing of documents. However, at the point
at which these documents were due, June I 1,1999, we had not yet finished compiling the
information which was available to us. I am hopeful that a two week delay has not
created any major problems. I am however distressed by the content of Allomey Boyle's
Ieller to you dated June 23, 1999. Although this leller was copied to me I believe that, at
the very least, the third and fourth paragraphs contained therein are extremely
inappropriate statements to have been made by a party to the Court. Therefore, I am
hopeful that by copy of this leller to Allorney Boyle she will cease and desist this type of
communication.
(717) 2.12.210.1' (7171 2.\2.(,('()1l. r." (71712.\2.5775
200 Nu"h Thud Slreel . TwdOh Ho"r . I'.(). II", (,X>) . Ilarn,hur~. 1';\ 1710X.OI>X>)
C. RICHARD HARRISON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VB.
NO. 97-3614 CIVIL TERM
ELIZABETH A. HARRISON,
Defendant
CIVIL ACTION
IN DIVORCE
INVENTORY AND APPRAISEMENT
OF
C. RICHARD HARRISON
(x) Plaintiff (
Defendant files the following inventory
and appraisement of all property owned or possessed by either
party at the time this action was commenced and all property
transferred within the preceding three years.
(x) plaintiff ( ) Defendant verifies that the statements
made in this inventory and appraisement are true and correct.
(x) Plaintiff ( ) Defendant understands that false
statements herein are made subject to the penalties of 18 Pa.
CoSo 4904, relating to unsworn falsification to authorities.
ASSETS OF THE PARTIES
(x) PLAINTIFF ( ) DEFENDANT 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.
(x) 1.
(x) 2.
(X) 3.
(X) 4.
(x) 5.
(x) 6.
) 7.
) 8.
) 9.
) 10.
) 11.
) 12.
) 13.
( ) 14.
(x) 15.
16.
(x) 17.
( ) 18.
(x) 19.
( ) 20.
( ) 21.
( ) 22.
( ) 23.
( ) 24.
(x) 25.
26.
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
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)
Military/V.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
2
MARITAL PROPERTY
(x) PLAINTIFF (
WHICH EITHER OR BOTH
INDIVIDUALLY OR WITH
WAS COMMENCED.
) DEFENDANT LISTS ALL MARITAL PROPERTY IN
SPOUSES HAVE A LEGAL OR EQUITABLE INTEREST
ANY OTHER PERSON AS OF THE DATE THIS ACTION
DESCRIPTION
OF PROPERTY
1/3 interest in Mendelson, Foer & Harrison
NAMES OF
ALL OWNERS
C. Richard Harrison
DATE OF
ACQUISITION
COST OR VALUE
AS OF DATE OF
ACQUISITION
VALUE AS OF
DATE OF
SEPARATION
PRESENT VALUE
to be determined
AMOUNT OF
ANY LIEN
NATURE OF
ANY LIEN
EFFECTIVE
DATE OF LIEN
HOLDER OF
LIEN
3
MARITAL PROPERTY
(xl PLAINTIFF (
WHICH EITHER OR BOTH
INDIVIDUALLY OR WITH
WAS COMMENCED.
) DEFENDANT LISTS ALL MARITAL PROPERTY IN
SPOUSES HAVE A LEGAL OR EQUITABLE INTEREST
ANY OTHER PERSON AS OF THE DATE THIS ACTION
DESCRIPTION
OF PROPERTY
1005 Chippenharn Road
Mechanicsburg, PA
NAMES OF
ALL OWNERS
C. Richard Harrison
Elizabeth Harrison
DATE OF
ACQUISITION
COST OR VALUE
AS OF DATE OF
ACQUISITION
VALUE AS OF
DATE OF
SEPARATION
PRESENT VALUE
unknown
AMOUNT OF
ANY LIEN
mortgage
NATURE OF
ANY LIEN
EFFECTIVE
DATE OF LIEN
HOLDER OF
LIEN
5
MARITAL PROPERTY
(xl PLAINTIFF (
WHICH EITHER OR BOTH
INDIVIDUALLY OR WITH
WAS COMMENCED.
) DEFENDANT LISTS ALL MARITAL PROPERTY IN
SPOUSES HAVE A LEGAL OR EQUITABLE INTEREST
ANY OTHER PERSON AS OF THE DATE THIS ACTION
DESCRIPTION
OF PROPERTY
Furniture and Furnishings
NAMES OF
ALL OWNERS
C. Richard Harrison
Elizabeth Harrison
DATE OF
ACQUISITION
COST OR VALUE
AS OF DATE OF
ACQUISITION
VALUE AS OF
DATE OF
SEPARATION
PRESENT VALUE
$7,500.00
AMOUNT OF
ANY LIEN
NATURE OF
ANY LIEN
EFFECTIVE
DATE OF LIEN
HOLDER OF
LIEN
6
NON-MARITAL PROPERTY
(x) PLAINTIFF ( ) DEFENDANT LISTS ALL MARITAL PROPERTY IN
WHICH A SPOUSE HAS A LEGAL OR EQUITABLE INTEREST WHICH IS CLAIMED
TO BE EXCLUDED FROM MARITAL PROPERTY:
DESCRIPTION
OF PROPERTY
401(K) at Mendelson, Foer & Harrison
NAMES OF
ALL OWNERS
C. Richard Harrison
DATE OF
ACQUISITION
COST OR VALUE
AS OF DATE OF
ACQUISITION
VALUE AS OF
DATE OF
SEPARATION
PRESENT VALUE
approximately $9,000.00
AMOUNT OF
ANY LIEN
NATURE OF
ANY LIEN
EFFECTIVE
DATE OF LIEN
HOLDER OF
LIEN
11
NON-MARITAL PROPERTY
(xl PLAINTIFF ( ) DEFENDANT LISTS ALL MARITAL PROPERTY IN
WHICH A SPOUSE HAS A LEGAL OR 8QUITABLE INTEREST WHICH IS CLAIMED
TO BE EXCLUDED FROM MARITAL PROPERTY:
DESCRIPTION
OF PROPERTY
1500 Timber Chase Drive
Mechanicsburg, PA
NAMES OF
ALL OWNERS
C. Richard Harrison
DATE OF
ACQUISITION
9/30/97
COST OR VALUE
AS OF DATE OF
ACQUISITION
$98,265.00
VALUE AS OF
DATE OF
SEPARATION
PRESENT VALUE
$3,265.00(equity)
$95,000.00
AMOUNT OF
ANY LIEN
NATURE OF
ANY LIEN
mortgage
EFFECTIVE
DATE OF LIEN
HOLDER OF
LIEN
National City Mortgage
13
LIABILITIES
(x) PLAINTIFF ( ) DEFENDANT LISTS ALL LIABILITIES OF EITHER
OR BOTH SPOUSES ALONE OR WITH ANY OTHER PERSON AS OF THE DATE
THIS ACTION WAS COMMENCED.
DESCRIPTION
OF LIABILITY
Corestates Visa #01-3116668-8
NAME OF
CREDITOR(S)
NAMES OF ALL
DEBTOR(S)
C. Richard Harrison
Elizabeth Harrison
DATE LIABILITY
WAS INCURRED
AMOUNT OF
LIABILITY ON
DATE INCURRED
AMOUNT OF
LIABILITY ON
DATE OF
SEPARATION
$2,827.75
DATE BALANCE
separation
IS DUE
paid in full by Husband after date of
PERIODIC PAYMENT
AND AMOUNT
16
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C. RICHARD HARRISON,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY. PENNSYL VANIA
: No. 97-3614 Civil Tcnn
ELIZABETH A. HARRISON,
Dcfcndant
: CIVIL ACTION - LAW
: IN DIVORCE
DEFENDANT'S PRE-TRIAL STATEMENT
Elizabeth A. Harrison, the Defendant, by and through her attorneys, COGNETII &
BRADERMAN, files the following Pre-Trial Statement:
TABLE OF CONTENTS
I. Background Information
II. Listing of Marital Assets and Debts
III. Listing of Personal Property
IV. Listing of Non-Marital Assets
V. Pensions
VI. Income and Expenses
VII. Counsel Fees and Costs
VIII. Expert Witnesses
IX. Non-Expcrt Witnesses
X. Listing of Proposed Exhibits
XI. Proposed Resolution
Respectfully Submitted
Dated: ~ (30 ferer
By:
Maria p. Co netti. Esqu e
Sup. Cl. \.D. #27914
200 North Third Street
Twcltlh Floor
P.O. Box 689
Harrisburg. I' A 17108-0689
(717) 232-2 \03
II 1WI"."uSl'UOn1'JIAlIll<IIl, tI" .I"C"lllal !lIIIC'tl1C'1\I"p.t
h.'J(WI
LENGTH OF RESIDENCY IN PA Since Birth
EDUCATIONAL BACKGROUND Doctor or Dentistry
B. CHILDREN
NAME AGE DATE OF BIRTH CUSTODIAN
Christina 14 June 11,1985 Wire
Richard 10 June 24, 1988 Wire
C. MARRIAGE INFORMATION
DATE OF MARRIAGE
PLACE OF MARRIAGE
DATE OF SEPARATION
CIRCUMSTANCES OF SEPARATION
July 7, 1979
York. PA
Scptember 2, 1996
Irreconcilable Differences
D. PRIOR MARRIAGE
I WIFE
HUSBAND
I None
One
E. CHILDREN OF OTHER RELATIONSHIPS/MARRIAGES
I WIFE
HUSBAND
IN,"'
Two (no minors)
F. PROCEEDINGS INFORMATION
DATE ACTION COMMENCED July 2, 1997
DATE OF SERVICE OF COMPLAINT Unknown
MANNER OF SERVICE OF Certificd Mail
COMPLAINT
IIIWI'.\U\n)()nrJllm.......II".Prt,llltl\IJlf1Tlfnl"pJ
WI(~'Y1
ISSUES RAISED IN DIVORCE
COMPLAINT
DATE AMENDED COMPLAINT
FILED
ISSUES RAISED IN AMENDED
COMPLAINT
DATE OF FILING OF ANSWER,
COUNTERCLAIM AND/OR
PETITION RAISING CLAIMS
ISSUES RAISED IN COUNTERCLAIM Alimony, Alimony Pendente Lite and
Counsel Fees
Divorce only
March 19, 1999
Equitable Distribution
April IS, 1999
BIFURCATION None
PREVIOUSL Y RESOLVED ISSUES None
II. MARITAL ASSETS AND DEBTS
The following is a listing of the marital assets and debts of the parties:
ITEM DESCRIPTION TOTAL HUSBAND'S WIFE'S COMMENTS
NO. VALUE POSSESSION POSSESSION
I. Real Estate
I.A 4824 E. Trindle Unknown Unknown
Road.
Mechanicsburg,
PA
1.13 1005 Unknown Unknown
Chippcnham
Road.
Mechanicsburg.
PA
2. Vehicles
2.A 1997 Honda $7,650.00 $7.650.00
Odyssey
II 1\I",\II\t"UO(OHII'''I''''olll, -I"fUUI \I.l""fnl"~
W'I~'1'.l
ITEM DESCRIPTION TOTAL IIUSBAND'S WIFE'S COMMENTS
NO. VALUE POSSESSION POSSESSION
2.B 1995 Ilnnda $11.075.00 $11,075.00
Accord
3. Bank Accounts
3.A Corestatcs $956.63 $956.63
Checking
Account
#2336-0454
3.B Corestatcs $25,001.00 $25,001.00
Capital Account
#23 9808 7731
4. Pensions!
Retirement
4.A Ivy Funds IRA $31.569.86 $31,569.86
4.B Ivy Funds IRA Unknown
4.C 401(K) Unknown Unknown
5. Life Insumncc
5.A Security Mutual $0.00 $0.00 Tenn
5.B Northwestern $0.00 $0.00 Term
5.C. Amerus $0.00 $0.00 Tenn
6. Business
6.A Mendelson Foer Unknown Unknown
& Harrison
7. Household
Goods
7.1\. Miscellaneous $7.500.00 $7.500.00
Household
Goods
8. Debts
8.A Fleet Mortgage $lJ5.047.00 $95.047.00
Description Basis of Exclusion Owner
First Union Savings Daughter's Savings Wife & Daughter
(Iimnerly Core States) (UGMA)
#3059980332354
First Union Savings Son's Savings Wi Ii: & Son
(Iimnerly Core States) (UGMA)
113014131776694
Capital Growth Account Account Acquired Wili:
- First Union Post-scpuration
#3014137404588
First Union Checking Account Acquired Wili:
(Iilrmerly Core States) Post-separation
lil014148380787
1l'\~r'\lI'lIMlC I~ Jhlln..",. 11,,-I'1f 1l1l1 \lllnnrnt "'I~l
ITEM DESCRIPTION TOTAL
NO. VALUE
ITEM DESCRIPTION TOTAL
NO. VALUE
8.B Amerieun Ilondu $9.000.00
Finunee
IIUSBAND'S
POSSESSION
IIUSBAND'S
POSSESSION
III. LISTING OF I'ERSONAL PROPERTY
ITEMS RETAINED BY WIFE
DESCRIPTION
Miscellaneous Household Goods
ITEMS RETAINED BY HUSBAND
DESCRIPTION
Clothing and Personal Belongings
IV. LISTING OF NON-MARITAL PROPERTY
The following is a listing of the non-marital assets of the purties:
No.
I.
2.
3
4.
f.iln"'l
WIFE'S COMMENTS
POSSESSION
WIFE'S COMMENTS
POSSESSION
$9.000.00
VALUE
$7.500.00
VALUE
Unknown
1l"Wfl.\ll~nlol)('L"II"In.'O\.IIII.I'1HIl&1 \1&lnnnl1"rot
"...I(\W
No. Description Dasis of Exclusion Owner
5. PSECU Checking Account Acquired Wife
//01 99382034-SR Post-separation
6. PSECU Savings Account Acquired Wife
//0199382034-SI Post-separation
7. Harris Savings Bank CD Daughter's CD - gift Wife & Daughter
//23-65-303907 from her grandfather (UGMA)
8. Fulton Dank CD Son's CD- Wife and Son
//252-0086942 inheritance from (UGMA)
Great Aunt
9. Fulton Dank CD Daughter's CD - Wile and Daughter
//252-0086943 inheritance from (UGMA)
Great Aunt
10. York Federal CD Son's CD - gili from Wile, Son and
//83-01-10-0000188538 Grandlather Grandfather
(PA - UGTMA)
11. Hill Financial CD Daughter's CD - gift Wife and Daughter
(now Meridian) from Grandfather (UGMA)
// 30-72-000610
12. First Union CD Inheritance Wife
(lormerly Core states)
//247022055626533
V. PENSIONS
The following is a listing of the pensions of the parties:
PARTY
DESCRIPTION
Husband
Ivy Funds IRA
401(K)
Wife
Iv}' Funds IRA
II \....rMI\('f)()fl:J1Alllklll.1 hI .1'tt-lnAl SIAI"","'...f"J
WI."",
C. COUNSEL FEES AND COSTS
Counsel fees in the amount of $5.000.00.
Repairs
Maintenance
Licenses
Registration
Auto Club
$3.75
MEDICAL:
Doctor
$54.00
Dentist
Orthodontist
Hospital
Medicine
$16.67
Special needs
(glasses, braces,
orthopedic
devices)
$33.00
EDUCATION:
Private school
Parochial school
(for daughter)
College
Religious-CCD
School lunches
Books/misc.
$300.00
Dental Continuing
Education Courses
PERSONAL:
Clothing
Food
Barber/hairdresser
Personal care
Laundry/dry cleaning
Lessons for
Children
$144.80
OTHER:
Sports-Ricky
Security Alarm
Homeowner's Dues
IRA Contributions
TOTAL EXPENSES
$6.576.82
* - Extraordinary repairs needed.
J
ASSETS OF PARTIES
Defendant marks on the list below those items applicable to the ease at bar and
itemizes the assets on the following pages. Ifan item has been appraised, a copy of the
appraisal report is attached.
(X) 1. Real property
(X) 2. Motor vehicles
( ) 3. Stocks, bonds, securities and options
( ) 4. Certificates of deposit
(X) 5. Checking accounts, cash
( ) 6. Savings accounts, money market and savings certificates
( ) 7. Contents of safe deposit boxes
( ) 8. Trusts
(X) 9. Life insurance policies (indicate face value, cash surrender
value and current beneficiaries.
( ) 10. Annuities
( ) 11. Inheritances
( ) 12. Patents, copyrights, inventions, royalties
( ) 13. Personal property outside the home
(X) 14. Business (list all owners, including percentage of ownership
and officer/director positions held by a party with company.
( ) IS. Employment tennination benefits - severance pay, workman's
compensation claim/award
( ) 16. Profit sharing plans
(X) 17. Pension plans (indicate employee contribution and date plan
vests)
( ) 18. Retirement plans, Individual Retirement Accounts
( ) 19. Disability payments
( ) 20. Litigation claims (matured and unmatured)
( ) 21. MilitaryNA benefits
( ) 22. Education benefits
( ) 23. Debts you owe (and/or your wife or husband), including
loans, mortgages held, etc.
( ) 24. Ilousehold furnishings and personalty (include as a total
category and attach an itemized list if distribution ofsueh
assets is in dispute
( ) 25. Othcr
,
MARITAL PROPERTY
Defendant lists all marital property in whieh either or both spouses have a legal or
equitable interest individually or with any other person as of the date of separation:
MARITAL PROPERTY
2. Motor Vehicle
ITEM DESCRIPTION:
1995 Honda Accord
OWNERSHIP:
Husband and Wife
POSSESSOR:
Husband
DATE ACQUIRED:
January 31, 1995
COST/ACQUISITION VALUE:
DATE OF SEPARATION VALUE:
PRESENT VALUE:
NAME AND ADDRESS OF
ANY LIEN HOLDER:
EFFECTIVE DATE OF LIEN:
NATURE OF LIEN:
PRESENT AMOUNT OF LIEN:
$22,508.00
$11,075.00 See NADA
None
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.UNIS.TATEMENT
.. ----
CORESTATES BANK
PO 80X 7618 F.C. 01-02-08-21
PHILADELPHIA PA 19101-7618
P AG E 3
ACCOUNT NO.
2336-0454
STATEMENT PERIOD
08/15/96 TO 09/13/96
-- ..---
I..,III".III,."I,I.,I,I,I,.,!.I!"I.,I.,I!"II,...I,1.11.,.1
C RICHARD HARRISON, OR
ELIZABETH A HARRISON
1005 CHIPPENHAM RD
MECHANICSBURG PA 17055-7686
~
B STATEMENT SAVINGS ACCOUNT f-5,;[:jJ'!'J~:llli!~'f!~~"!!f.'l:.y#~~if,...",it&~;~~t'$~~~~~
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EtlDIIlG BRLRtlCE 011 09/13/%
FROII 00/15/% TO 09/1]/%: IIITEREST ERRtlEO s.~5. RlIllURL PERCEtHRGE VIELD ERRtlED 2.31:.
En CAP IT AL GR O~ITH ACCOUNT 1~l'::.",.".j,'.'~f,'r'S:~;~;;s:'il'f}t.;'..",;if'';<i;;>~1t;!;~(.~r.':~',\~\..\kt.&'0>t'J~&,;.'il'~!1'g~.&N~"'l
ELIZRBETH R HRRRISOtl N /;. rJ A c. (".:1, 0 PC NeD Cf /~ /Cf&
+.~5
BRLRIICE
225.93
225.93
STRTEIIEtlT PERIOD: 09/03/% TO 09/131%
SUIIIIRRY OF RCCOutH H13H-om
3z.70
BEGIIIIIltIG BRLRtlCE 011 09/03/%
DEPOSITS RtlD CREDITS
WITHDRRWRLS RtlD TOTRL FEES
EIlOltlG BRLRlICE 011 U9/13/%
.00
125.033.70
.OU
25.033.70
YERR TO DRTE IIITEREST PRID
DRILY RCTlVITV
WITHoRRWRLS/DEBITS (-)
DEPOSITS/CREDITS (I)
BRLRtlCE
.00
25.001.00
25.033.70
25.033.70
DRTE DESCRIPTlOIl
BEGltlllltlG BRLRtlCE
09/03 DEPOSIT
09/13 1IlTEREST PRID
ElI01IIG BRLRtlct Otl 09/13/%
125.0111.00
1J2.70
FROII 09/0]/% TO U9/13/%: 1IlTEREST E~RtlEO $J2. 70. RtltlURL PERCEtllRGE YIELD ERRtlED J. 75:.
~3 CAPITAL GRmlTH ACCOUNT ~,'{j{;::~':::'-';!' ,;;:,,;"L;..."j.~:jAiL..:.~;.::L:::..:.:..~{~;;:.;~0l:H",",",~~F~::
ELIZRBETH R HRRRISOII
SUIIIIRRY OF RCCOUtlT 2190110-7731
BEGItlllltlG BRLRIlCE 011 011/15/%
DEPOSITS RIID CREDITS
WITHoRRWRLS RlIO TOTRL FEES
EllOlIlG BRLRtlCE Otl 0~/13/%
12.~H.~2
+ 11.022.71
-25.1Il11.lIl1
~G6.1S
H,o.3~
YERR TO DRTE ItlTEREST PRID
DRILY RCTlVITV
WITIIORRWRLS/OEBITS (-)
DEPOSITS/CREDITS (+1
BRLRIICE
12.~~~.~2
. DRTE DESCRIPTI011
BEG1I1IIltlG ORLRlICE
UNISTATEMENT
CORESTATES BANK
PO 80X 761B F.C. 01-02-0B-21
PHILADELPHIA PA 19101-761B
PAGE 4
ACCOUNT NO.
2336-0454
STATEMENT PERIOD
OB/15/96 TO 09/13/96
--- ----
1.,.111...111....1.1..\.1.\...1.11..1.,\..11..11....1.1.\1...1
C RICHARD HARRISON, OR
ELIZABETH A HARRISON
1005 CHIPPENHAM RD
MECHANICSBURG PA 17055-76B6
H
I CAPITAL GROWTH ACCOUNT ;d\7~~,o:;~;.c~{iJ.{~iLi:i:~~~"~.,";ha~lj.tJ :'1';- . '-:_.~i"':':'--~i,,~;t.PY~~ -.. ~i"tf.-,~' ~~V!
OATE OESCRIPTIO!I
09/03 TBS TRRNSFER RUTH U 2~7~01
HITHDRRHRL
09/13 INTEREST PRIO
ENOIIIG BRLRNCE 011 WI3/%
FROH 00/11/% TO Wl3I%: llHEREST ERRIIEO $22.73. RIIIIURL PERCEIHRGE YIELO ERRNEO 3.~9:.
fa STATEMENT SAVINGS ACCOUNT ~,;:'l:lli1i'i't;>c~~&t'~.~7~'Jilltiii,)"~i;~j'l\~.~1tffi-i~.o1~t;.;'~a&~
CHRISTINR HRRRISON
SUlIHRRV OF RCCOUIH S991103- 3231
BEGIIIIIIIIG BRLRNCE 011 00/15/%
OEPOSlTS RNO CREOITS
H1THORRHALS RIIO TOTRL FEES
EIIOIIIG BALRNCE ON 09113/%
HITHORRHRLS/OEBITS (-)
OEPOSITS/CREOITS (I)
113.000.00
-25.001.00
122.73
BRLRNCE
25.m.~2
HM2
~00.15
-
Q66.15
100.70
Ion
.00
YERR TO ORTE IlHEREST PRIO
2.15
161. 08
ORIL V RCTlVITV
ORTE OESCRIPTIOII
BEGJllIlIIlG BRLRNCE
09113 JlITEREST PRIO
ENOIIIG BALRIICE 011 09/1]1%
FROlI OB/lll% TO 1I~/13/%: llHEREST ERRIlEO
HITIIORRHRLS/OEBITS (-)
OEPOSITS/CREOITS (I)
1032
BRLRIlCE
100.70
101. 00
101.08
$.32. RIlIlURL PERCEIHRGE YIELO ERRIIEO 2.30:.
STRTElIEIlT OUESTlOllS SHOULO BE OIRECTEO TO CORESTRTES OIRECT 8RIlKIIIG CEIHER RT (215) 973-1000. OR
(0001 "0-L9t1U (fROil TOLL CRLLIIIG RRERS I. CUSTOIIER SERVICE HOURS RRE U:UU All TO U:OO PlI ORILY.
CORESTRTES TElEPHOlIE BRIlUIIG OFFERS 2~ HOUR R ORY. SEVElI ORY R HEEK RCCESS TO UP TO ORTE STRTEHENT
IIIFORlIRTIOII. YOU CRII EVEN TRRIlSFER FUIlLS AlIO lIA1E PRVIIEIlTS - CRLL (ZI5) 973-1000. OR (Om)) ~ZO-0900
(FROH TOll CRLLIIIG RRERS).
.-::;;;-- .
~
CorcStalcs
CORESTATES BANK
PO BOX 7618 F.C. 01-02-08-21
PHILADELPHIA PA 19101-7618
UNISTATEMENT
PAGE
ACCOUNT NO.
2336-0454
---- ----
1,"111".111,",1,1"",.1",1.11"'"1"11"1',",1,,.11,"1
C RICHARD HARRISON, OR
ELIZABETH A HARRISON
1005 CHIPPENHAM RD
MECHANICSBURG PA 17055-7686
STATEMENT PERIOD
08/15/96 TO 09/13/96
fi
CYC BR TYP DISP 2N EI
.",......ll...li&W!W1l1t...L
~ COREFLEX SUI1HARY OF ACCOUNTS 1~~','Mi{EfI1il,;M;;'\W.iwtr~ml.;miol\'~.,'i,-::,~'YJl't~~~
DEPOSIT ACCOUNTS BALANCE
. INCONE CHECKIIIG ACCOUNT 95G.G3 J..nt-
· STATEHEIIT SAVIIIGS ACCOU/IT 225. 93 ~rn
· CAPITAL GROHTH RCCOU/IT 25.033.70 e'/.2ob,,!,
· CAPITAL GROHTH ACCOUlIT qGG.15e'J. 1~ h,1I-
· STATElIEIIT SAVIIIGS ACCOUIIT 1G1.0u djM"~
TOTAL 2G,OO.q9
· COREFLEX OUALlFYIIIG BALANCES TOTAL 2G.OO.q9
lt~'<:~ CORESTA TES UPDATE r11I~,~~;':Jjf~1"'1'fii",it"~;~~8~f.k,<"tl';;~f@~i;i)\~~",.:~?~,;~t"4,;.;p~~~_~j.'~4Il
HAKE THE RIGHT rlOVE TO FIIID YOUR OREAH HOHE. SEE YOUR LElIDER FIRST. CORESTATES HORTGAGE SERVICES CORP.
OFFERS A VARIETY OF FLEXIBLE PROGRAHS. LOH RATES. INSTANT PRE-OUALIFICATION AND FAST APPROVALS. HE ALSO
HAVE SPECIAL PROGRAHS FOR LOH AND II00ERATE IflCOIIE APPLICANTS. FOR HORE IfIFORHATIOII 011 HORTGAGES. CALL
1-000-999-3305.
~i!l I NC Of1E CH E C KING ACCOUNT m'1ti(~"~!iiV""-,,~;"1''''iJ'.(~;;,,,}i;1ifi~f.~''~:;~i:i.l(i,j'~~.wJ:r~wt'b'Gij;~~~~!',"fiii
C RICHARD HARRISOII. OR
SUNI1ARY OF ACCOU/IT 233G-OQ5Q
BEGIfIlIING BALANCE 011 00/151%
DEPOSITS ANO CREDITS
IfITEREST PAlO
CHECKS. HITHDRAHALS 8 TOTAL FEES
E/IDIfIG BALAlICE 011 091131%
lfi.173.1G
.00
19.GO
-17.22G.13
95G.G3
AVERAGE BALANCE
VEAR TO DATE IIITEREST PAID
11. 709.00
122.5Q
CHECKS PAID: 17
CHECK .
ANOU/IT DATE PAlO REFERENCE'
CHECK < A/IOUIIT DATE PAID REFERENCE<
1300 50.00 091111% 395Q9772
"_1302 . . Un 1.7.'17.00 . 09l01/9G Ullr.GG23G
1:J1I3 2<2. SO U9/U]I% 0~UO~5nq
130Q Gr..10 091U31% UH03025
1]05 37.52 Oul291% OUII17529
I]or. 22.00 091U51% O~UGOlH.
1300 . SQ.UII 09/05/% OH I03:N
13U9 HO.OII 0910GI% nn513111
1322 9.5Q 0911119G 01151322
1m . 9.5Q 091111% 01151321
1J25 liD:OGn -1J9il2i:JG--D;oUU~030
1327 . QQ.13 0910~I~G 10019S9Q
1HO . 17.50 091051% 0~OG1I117
1371 . 20.110 OUIISI% 05HIOll3
1373 . 130.00 OBI1519G 39GQ5092
137B . ]%.00 OBI2GI% OlGSI201
1379 25.00 OBI2GI% U5GOBOGI
. BRERr III ClIECI: I/UIIBER SEQUEI/CE
ORIL Y ACTIVm
DATE OESCRIPTION
BEGINI/II/G BRLAI/CE
DBI15 CHEcrs PIIID: 1171 117]
OUl21 .IIAC PURCHAsr L75 SILVER SPRIIIG IlrulAlIlCSBI/RG PII
OB12111% REF <21fJ,HI IHIIII1711~[,
CHEcrSIOEBITS (-)
DEPOSITSICREDITS Itl
-1"11.1/11
-~rf.n
BRLAlICE
lU.17].JL
III .OIS.IG
17.9511.95
00/22 'RTII WTH PllnOOl ~2~2 CARLISLE PIKE CAIIP IIlLL PR
00/2& CHECKS PAID: 1379 1370
00/20 'IIRC PURCHASE &75 SILVER SPRIIIG IIECHRlIICSBURG PR
00/'0/~& REF '2102~11 00002375
'ATII HTH PllIIOOl ~2~2 CARLISLE PIKE CAIIP HILL PA
00/29 CHECKS PRIO: 1305
'CHECK CRRD PURCHASE OFFICE IIAX 000D03~0 00/271%
IIECHRllICSBRG PR 17055 REF'2~39900&2H1000n3900272
09/03 STOP PRVHEIH FEE
CHECKS PRID: 130~ 1303
'RTII WTH R91& '110 CAIIP HILL CAIIP HILL PR
'TELEPHD~IE ORlIKlIlG TRRlISFER RUTH , 2~7~01
TO RCCOUIH: 2390007731
09/0~ CHECKS PRIO: 1327 13B2
'IIAC PURCHASE 32110 ST a TRIIIJLE CAllPHILL PR
09/0~/~& REF 'Ol~~553001PSOO~~~9
'RTII WTH SRB257 ~231 TRIIIOLE RD CRIlP HILL PR
09/05 CHECKS PRID: 13~0 130& 1300
09/0& CHECKS PRID: 1309
'PAWC - CRPITOL 0 : PPD PRVIIEIIT
10000%&&0 11&70&&001 till: HRRRISOII C RICHRRD
0~/D9 'ATII HTH PH0001 ~2~2 CRRLlSLE PIKE CRIIP HILL PR
'RTII HHI R91& 'lID CAIIP IIlLL CAIlP HILL PA
'PA POHER ~ LIGHT : PPD ELEC BILL
5230959590 52~-~021-310 1111: C RICHARD HARRISOII
09/11 CHECKS PAID: 132~ 1322 1300
09/12 CHECKS PRID: 1325
0~/13 IIlTEREST PRlO
EliDING BRLRIICE 011 0911319&
. !lIOICRTES ELECTRotllC TRRIISRCTIotl
FRDII 00/15/% TO n91131%: IIlTEREST ERRIIEO $9.&U. RIIIIURL PERCENTRGE YIELD ERRIIED 1.00:.
~aSTAtEMENT SAV INGS ACCOUNT E~';:~"'F~~~,:i'lIf"~~",1'.j!'?f"j',t1t'~~",~"~~f"'P~~
~
I,JNISTATEMEN'
. CORESTATES BANK
PO BOX 7618 F.C. 01-02-08-21
PHILADELPHIA PA 19101-7618
ACCOUNT NO.
2336-0454
Core States
PAGE 2
STATEMENT PERIOD
08/15/96 TO 09/13/96
1",111."111""1,1,,1,1,1,,,1,11,,1,,1,,11,,11,,,,1,1,11",1
C RICHARD HARRISON, OR
ELIZABETH A HARRISON
1005 CHIPPENHAM RD
MECHANICSBURG PA 17055-7686
mm INCOME CHECKING ACCOUNT ~,I;1.ai;~ij~"'!m~~:.f.;i,;%"il~~:-tf\\:~;~~.~~~~~,.7D~~~~~~
CHECKS/DEBITS (-)
DEPOSITS/CREDITS (+)
DRTE
DESCRIPTION
BRLRNCE
17,75B.~5
17 ,337 .~5
17.2~2.&~
-200.50
-~21.00
-~~.Ol
-100.50
- 37.52
- 3~ . O~
17.192.H
17,15~.&2
17.120.50
-20.00
-200.fiO
-100.00
-13.000.00.
17.100.50
l&.Oll.~O
1&.711.90
3.711. 90
-1.7~1.21
-5&.~0
1.920.&~
1.0&3.71
1.7&3.71
1.&70.21
1.522.21
1.~01.25
1.300.75
1.2~0. 75
1.0%.11
-100.00
-~3.50
-l~O.OO
-~O.%
-100.50
-HO.OO
-1~~.&~
-&~.OO
-00.00
+~.&O
1.027.03
~H.03
~5&.&3
956.63
RICHRRO R HRRRISOII
SUIlIIARV OF RCCOUIIT IH317-7GG9
BEGINIIIIIG BRLRIICE 011 OO/1519G
DEPOSITS RIIO CREDITS
WITHDRRHRLS RIIO TOTRL FEES
ENDIIIG BRLRIICE 011 09/1]/~G
225.~0
+.~5
.no
225.93
VERR TO ORTE ItITEREST PRID
ORILV RCTIVITV
DRTE DESCRIPTIOII
BEGIIIIIIIIG BRLRIICE
HITHDRRHRLS/DEBITS (-)
DEPOSITS/CREDITS 1+)
BRLAIICE
225.~0
!I.'II()li-' I"'VJI
t\
.93
MARITAL PROPEIHV
DATE ACQUIRED:
1990
14. Business
ITEM DESCRIPTION:
Mendelson Filer & Ilarrison
OWNERSHIP:
Husband (1/3 interest)
POSSESSOR:
Husband (1/3 interest)
COST/ACQUISITION VALUE:
DATE OF SEPARATION VALUE:
Unknown. Ifparties are unable to
stipulate to value, Wife will have
appraised
PRESENT VALUE:
Unknown. Ifparties are unable to
stipulate to value, Wife will have
appraised
NAME AND ADDRESS OF
ANY LIEN HOLDER:
EFFECTIVE DATE OF LIEN:
NATURE OF LIEN:
PRESENT AMOUNT OF LIEN:
None
MARITAL PROPERTY
17. Retirement
ITEM DESCRIPTION:
Ivy Funds IRA
OWNERSHIP:
Wife
POSSESSOR:
Wife
DATE ACQUIRED:
Date of marriage
COST/ACQUISITION VALUE:
DATE OF SEPARATION VALUE:
$27,124.19 See attached.
PRESENT VALUE:
$31,569.86 as of 12/31/98. See Attached
NAME AND ADDRESS OF
ANY LIEN HOLDER:
None
EFFECTIVE DATE OF LIEN:
NATURE OF LIEN:
PRESENT AMOUNT OF LIEN:
Ivv Mackenzie
vv FUNOS.A Glowing Globol FOlco
IVY GROWTH FUND CLASS A
RETIREMENT PLAN CONFIRMATION STATEMENT
ST"l{l,lEI11 DAlf
YOUR .CCOu~T NUMD(R
DEe 31, 1998 030-090070230G
PAGE 1 OF 1
IBT CUST IRA FBO
ELIZABETH A HARRISON
1005 CHIPPENHAM RD
MECHANICSBURG, PA 17055-7686
FOR SERVICE CALL TOLL-FREE: 1-800-235-3322
RECORD OF YOUR TRANSACTIONS YEAR-TO-DATE
DATE TYPE OF TRANSACTION DOLLAR AMOUNT PRICE SHARES THIS
A PER SHARE TRANSACTION
01/01/98 BALANCE FORWARO
02/09/98 PRIOR YEAR CTR8
'2/23/98 REINVEST OIVIOENO
'2/23/98 REINVEST CAPITAL GAIN
_ _ LONG-TERM CAP GAIN
SHORT-TERM CAP GAiN
12/29/9B ANNUAL TRUSTEE FEE
NUMBER OF
HARES YOU OWN
1,447.076
1,555.536
1,556.B60
',588.529
2.000.00 18.44 108.460
0.0166 25.82 19.50 1.324
0.397 617 . 55 19.50 31.669
. 0.3908 607.91
0.0062 9.64
10.00 19.70 0.508
, .588.021
THE VALUE OF YOUR ACCOUNT AS OF OEC 31. 1998 IS $31,5B9.86
SUMMARY OF YOUR ACCOUNT
CURRENT YEAR'S ACTIVITY (EXPRESSED IN $1 NUM8ER OF
TOT:'l
HARE Y U
WN
= TOTAL SKA.IU'S
OI\lIDEhDS .. ST. GA1',S
1101 CEFllj~IC.4TE fCRM
+ 0" DEPOSIT
+lO"'C; TER.'" CAPITAl (jA:f.I~
=
~'''''Q,' I" ~
35.46
643.37
1,588.021
1.588.021
607.91
0.000
PRieR ~fAR
CCt.lJj'AJf'O'1
C'JI\I\[f'jT ~E.e.q
r(l"~I'l:" J"l:"1"
JlO,~c'..[~S
YOUR ACCOUNT FEATURES ARE:
,LE.""":: EA';''''';'~[
DIo,[,<;I.... CP:'v"
,:.:.p<,...~ \1M.. "'..~.o.
2.000.00
0.00
0.00
.....,T~:;'lI.WALS
TAXES wl~I1"'E~::
YES
REINVEST
REINVEST
~...x.n::~ '0 t,J'..a::'l
0.00
0.00
ON fILE
TUEPllG1I1; f{EDEl.lrTIO~ S'l'Sll;:M.\lIC Vo'ITt-<ORAW/ol
AU10Io4A.TIC 1'\"'ESTIo4EI;T
I.CCOJ"T 1Y~E IRA" REGULAR
NO
NO
NO
NON-MARITAL PROPERTY
ITEM DESCRIPTION:
First Union Savings
(formerly Core States)
1/ 3059980332354
OWNERSHIP:
Daughter and Wife (UGMA)
POSSESSOR:
DATE ACQUIRED:
Wife
June 16, 1992
COST/ACQUISITION VALUE:
PRESENT VALUE:
$468.66 as of June 15, 1999
NAME AND ADDRESS OF
ANY LIEN HOLDER:
EFFECTIVE DATE OF LIEN:
None
NATURE OF LIEN:
PRESENT AMOUNT OF LIEN:
BASIS CLAIMED FOR
EXCLUSION FROM
MARITAL PROPERTY:
Daughter's Savings
,
!
i
I
I'
NON-MARITAL PROPERTY
ITEM DESCRIPTION:
First Union Cheeking
(formerly Core States)
# 1014148380787
OWNERSHIP:
Wire
POSSESSOR:
Wife
DATE ACQUIRED:
November 25. 1996
COST/ACQUISITION VALUE:
PRESENT VALUE:
$ .59 as of June 15, 1999
NAME AND ADDRESS OF
ANY LIEN HOLDER:
EFFECTIVE DATE OF LIEN:
NATURE OF LIEN:
PRESENT AMOUNT OF LIEN:
BASIS CLAIMED FOR
EXCLUSION FROM
MARITAL PROPERTY:
Account acquired post-separation
. " ..
NON-MARITAL PROPERTY
ITEM DESCRIPTION:
PSECU Savings /I 0199382034-SI
OWNERSHIP:
Wife
POSSESSOR:
Wife
DATE ACQUIRED:
December 7, 1998
COST/ACQUISITION VALUE:
PRESENT VALUE:
$6,315.48 as of June 15, 1999
NAME AND ADDRESS OF
ANY LIEN HOLDER:
EFFECTIVE DATE OF LIEN:
NATURE OF LIEN:
PRESENT AMOUNT OF LIEN:
BASIS CLAIMED FOR
EXCLUSION FROM
MARITAL PROPERTY:
Account acquired post-separation
. .. ..
. .. .
NON-MARITAL PROPERTY
ITEM DESCRIPTION:
Harris Savings Bank CD 23-65-303907
OWNERSHIP:
Daughter and Wife
POSSESSOR:
Wire
DATE ACQUIRED:
February II. 1997
COST/ACQUISITION VALUE:
$3,000.00
PRESENT VALUE:
- $3.400.00
NAME AND ADDRESS OF
ANY LIEN HOLDER:
EFFECTIVE DATE OF LIEN:
None
NATURE OF LIEN:
PRESENT AMOUNT OF LIEN:
BASIS CLAIMED FOR
EXCLUSION FROM
MARITAL PROPERTY:
Daughter's CD - gift from Grandrather
.. .. .
,. .. .
NON-MARITAL PROPERTY
ITEM DESCRIPTION:
Fulton Bank CD /I 252-0086942
OWNERSHIP:
Son and Wife
POSSESSOR:
Wire
DATE ACQUIRED:
June 3,1996
COST/ACQUISITION VALliE:
$4,000.00
PRESENT VALUE:
- $4,800.00
NAME AND ADDRESS OF
ANY LIEN HOLDER:
EFFECTIVE DATE OF LIEN:
None
NATURE OF LIEN:
PRESENT AMOUNT OF LIEN:
BASIS CLAIMED FOR
EXCLUSION FROM
MARITAL PROPERTY:
Daughter's CD - Inheritance
I:
lU
5 ~
"'"tj o.~
lU~_
.."'~
co ~:(
~"l"
Oe.i
.- c.. ::I
~ ~
~ .~
..,. x
o
U
~
....
::l ~
r:-~
;::: N
- M
N
. -
~
a r:
;;; a
::: ...
N
;::
E
:'>- v,
(.1; F;
-.' ..::
':.~ " ''':.
tl!: - , ..-;
r,)' . (..Jo_.
. .\ .....
11.. ,.
" --
("): ~ -j':'.
"f ,'" ,-'
(' . - :'0
LJ!' C'\.! (..1~,:
2!., ~: -:':
~ : . - ~ J I JJ
lo.. "l ':'.'rJ..
0 0'1 .3
C1'\ C,J
\0 '-
"" f-:
l1"; c ~.
-c - I ,
~. N ~~;:
tJJ~:: ( ~ ~~
~.!( . :l: - :....
f't j', Co- ..~I;"'j
.~
2' . . ~. ( ')
I. N 1 <.
:'I )~ I ,-
l.l.-' . ,,; ;;;:
~I. '" lllU
.< ~ flO-
,_. -,.
- J
I.. .-:>
I.' U
w
..J
>
0
m
..,
0: ..
w . 0
> w ;:
w
G < ~
. rf
III ~ . ~
w ~
u
;;; 0 . Cl
< u 0 a:
~ tJl w .
0 . :>
~ ci I' 0 1Il
. . III
0 g ii'
LI. a:
tJl a <t
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C
ui
0:
w
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--
'>- V) --
- c: >-;
~ l.r-
. . ~:~
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~ J,~ ; --
.., .4-.
". .....
i~',:: N .t/~
, . 'I.~' ~
l;~: I .. ..
-.It O~ ;: i(l.
LJ. . .- I.JU-
I. ::c -j
,. <::>
C") a iJ
W
...J
~
m
ll/l
0:: "
W . 0
> - ;::
-
a " ~
. CE
" ~ " ~
w ~
u ci
u: 0 .
< u 0 a:
~ - =
0 Ul " ::>
~ ci % 0 CD
. . '"
S 0 " a:
0
u. z a:
Ul " ~
w ;
C
Ul
0::
W
>-
W
::;:
.."
. 4
LAW Of'F1CCS
MEYERS. DESFOR, SALTZGIVER & BOYLE
4410 NORTH SE:.COND STRI:I:T
P,O. DOX Icez
I. E:.MANUCL MCYE:.RS (1915.19701
BRUCE: 0, OE:.Sf'OR
LAURIE:. A. SALTZOIV[R
CATHERINE: A. DOYLE:
HARRISBURG. pA.1710e
171712:J6.g44Z8
f'AXI71712:J6-Z817
July 25, 2000
E. Robert Elicker, II
Office of Divorce Master
CUMBERLAND County Court of Common Pleas
9 North Hanover Street
Carlisle, PA 17013
Re: C. Richard Harrison v. Elizabeth A. Harrison
No. 97-3614 Civil
In Divorce
Dear Master Elicker:
It has come to my attention that Ms. Cognetti's office
contacted you in order to reschedule the 4-party conference
scheduled for August 24, 2000 in the above-referenced matter. as
you are aware, the parties and counsel were contacted some time
in June and could not get in to see you until late August due to
various conflicts in everyone's schedule and the busy doctor
appointments of each of our clients.
Accordingly, my client purposely did not schedule patients
on the scheduled day so that he could attend the conference. He
has patients scheduled for each of the other proposed alternative
dates. Furthermore, I am unavailable each of those dates due to
conflicts from my other cases.
Accordingly, I cannot agree to reschedule the 4-party
conference before you on August 24, 2000.
Thank you for your attention to this matter. If you have
any questions, please feel free to contact me.
Very truly yours,
CAB/skl
cc: C, Richard Harrison
Maria Cognetti, Esq.
LAW OFFICCS
MEYERS, DESFOR, SALTZGIVER & BOYLE
<410 NORTH SCCOND STRE:CT
P.O. BOX 100Z
I. E:M"'NUE:.L ME:YE:RS 11915.1970'
BRUCE: D. DE:SFOR
LAURIE....S...L.TZGIVE:R
CATHE:RINE:.... BOYLE:.
HARRISBURG. PA. 17106
(717) 236-9426
FA,)(t7171236-Z817
WEBSIT[ WNW meyersdlsfOl' com
E:M"'ILISI~I'OI'com
~sdes'OI'com
November 21, 2000
E, Robert Elicker, II
Office of Divorce Master
CUMBERLAND County Court of Common Pleas
9 North Hanover Street
Carlisle, PA 17013
Re: C. Richard Harrison v. Elizabeth A. Harrison
No. 97-3614 Civil
In Divorce
Dear Master Elicker:
As per your request, I am writing to inform you as to the
status of this matter. My client simply cannot agree to use a
third valuator in this matter because he has already retained
what we believe to be the leading expert in valuations of dental
practices in Pennsylvania and perhaps in the United States. He
simply sees no reason to go beyond an expert who we already feel
to be the top of the field,
Mr, DeMuth has valued numerous dental practices for actual
sales, testified repeatedly in the court room on valuations of
numerous dental practices. We cannot justify the expenditure of
additional funds on another expert who's capabilities in our
opinion would be inferior to those of Mr. DeMuth.
I understand that this matter will proceed to a hearing
before you in February 2001. If y~u have any questions, please
feel free to contact me.
CAB/elk
cc: C, Richard Harrison
Maria Cognetti, Esq.
Donald L. DeMuth, C.P.A.
C, RICHARD HARRISON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS,
DIVORCE NO: 97 - 3614
SUPPORT NO: 00789 S 1998
CUSTODY NO: 96-6737
CIVIL ACTION - LAW
ELIZABETH HARRISON,
Defendant
MOTION TO WITHDRAW AS COUNSEL
AND NOW, comes Movant, Catherir.e A. Boyle, Esquire and
Meyers, Desfor, Saltzgiver & Boyle and hereby file the following
Motion to Withdraw as Counsel, and in support thereof avers as
follows:
1. Movant is Catherine A. Boyle, Esquire and Meyers, Desfor,
Saltzgiver & Boyle who are presently counsel of record for
C. Richard Harrison, a party in the above-captioned action.
2. Respondent is C. Richard Harrison, a party in the above-
captioned actions.
3. Movant has represented Respondent in the above-captioned
actions since on or about May 1, 1998.
4. Recently, Movant received eorrespondence form Respondent
dated December 15, 2000, in which Respondent indicates he
no longer requires Movant's serviees. Specifically,
Respondent stated, "I do and have valued your
representation, and I know that you have done your best for
me within the constraints of an absurd legal system. I
thank you for this, and would not hesitate to recommend you
or contact you in the future. However, at this point I am
comfortable with my settlement and do not require legal
MEYERS, DESFOR. SAlTZGlVER & BOYLE
410 NORTH SECOND STREET . PO BOX 1062 . HARRISBURG, PA 17108
(717) 236.9428 . FAX (717)236-2817
C. RICHARD HARRISON,
Plaint if f
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO: 97 - 3614
NO: 00789 S 1998
PACSES NO: 6821003647
CIVIL ACTION - LAW
VS,
ELIZABETH HARRISON,
Defendant
CERTIFICATE OF SERVICE
'1.1'~
I hereby certify on this ~ day of ;]~~' 2001,
a copy of the foregoing Motion to Withdraw as Counsel was sent
via facsimile and mailed first-elass, postage pre-paid to:
Maria Cognetti, Esquire
210 Grandview Avenue
Camp Hill, PA 17011
Master Robert Elicker II, Esquire
9 North Hanover Street
Carlisle, PA 17013
I hereby certify on this ~ day Of~, 2001,
a copy of the foregoing Motion to Withdraw as Counsel was mailed
first-class, postage pre-paid to:
C. Riehard Harrison
1500 Timber Chase Drive
Meehanicsburg, PA 17055
-~ ~
MEYERS, CESFOR, SALTZ GIVER & BOYLE
410 NORTH SECOND STREET. PO BOX 1062 . HARRISBURG, PA 17108
(717) 236.942B . FAX (717) 2J6.2817
,
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to the ownership and equitable distribution of real and personal
property; settling of all matters between them relating to the
past, present and future suppon, alimony and/or maintenance of
WIFE by HUSBAND or of HUSBAND by WIFE; settling of all matters
between them relating to the past, present, and future support
and/or maintenance of the ehildren; and in general, the settling
of any and all claims and possible claims by one against the
other or against their respeetive estates.
NOW, THEREFORE, in consideration of the premises and of the
mutual promises, eovenants and undertakings hereinafter set forth
and for other good and valuable eonsideration, reeeipt of which
is hereby acknowledged by eaeh of the parties hereto, HUSBAND and
WIFE, each intending to be legally bound hereby eovenant and
agree as follows:
1. SEPARATION: HUSBAND and WIFE shall at all times
hereafter have the right to live separate and apart from each
other and to reside from time to time at sueh plaee or plaees as
they shall respectively deem fit, free from any control,
restraint or interferenee who:tsoever by the other. Neither party
shall molest the other or endeavor to eompel the other to eohabit
or dwell with him or her by any legal or other proceedings. The
foregoing provisions shall not be taken to be an admission on the
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All'J'UI I. 2001
part of either HUSBAND or mFE of the lawfulness or unlawfulness
of the causes leading to their living apart.
2. INTERFERENCE: Eaeh party shall be free from
interference, authority, and eontact by the other, as fully as if
he or she were single and unmarried, except as may be necessary
to earry out the provisions of this Agreement. Neither party
shall molest the other or attempt to endeavor to mole9t the
other, nor compel the other to cohabit with the other, or in any
way harass or malign the other, nor in any way interfere wi th the
peaeeful existence, separate and apart from the other, and each
of the parties hereto eompletely understands and agrees that
neither shall do or say anything to the children of the parties
at anytime whieh might in any way influence the children
adversely against the other party, it being the intention of both
parties to minimize the effect of any such separation upon the
children.
3. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS: This
Agreement shall not be considered to affect or bar the right of
HUSBAND or \;IFE to a divorce on lawful grounds as sueh grounds
now exist or shall hereafter exist or to sueh defense as may be
available to either party. This Agreement is not intended to
condone and shall not be deemed to be a condonation on the part
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of either party hereto of any aet or aets on the part of the
other party whieh have occasioned the disputes or unhappy
differences whieh have occurred prior to or which may occur
subsequent to the date hereof.
4. SUBSEOUENT DIVORCE: The parties hereby aeknowledge that
HUSBAND has filed a Complaint in Di voree in Cumberland County to
Doeket No. 97-3614, elaiming that the marriage is irretrievably
broken under Seetion 3301 (e) of the Pennsylvania Divorce Code.
Both parties hereby express their agreement that the marriage is
irretrievably broken and express their intent to execute any and
all Affidavits, waivers or other documents neeessary for the
parties to obtain an absolute divorce pursuant to Section 3301 (e)
of the Divoree Code at the same time as they execute this
Agreement. The parties hereby waive all rights to request eourt
ordered eounseling under the Divoree Code. It is further
specifically understood and agreed by the parties that the
provisions of this Agreement as to equitable distribution of
property of the parties are aceepted by each party as a final
settlement for all purposes whatsoever, as eontemplated by the
Pennsylvania Di voree Code.
Should a deeree, judgment or order of di voree be obtained by
,>ither of the parties in this or any other state, eountry or
.4.
.
\\111 rob\f.."'t:, ;1o\ClhM DII.ctnrY\lhn~J~Il'E\A<Jrp.....,ntl .i'lop...rty S'I tl........nt A]r"f'_nt . "',><t
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jurisdietion, each of the parties hereby consents and agrees that
this Agreement and all of its covenants shall not be affected in
any way by such separation or divorce; and that nothing in any
such deeree, judgment, order or further modification or revision
thereof shall alter, amend or vary any term of this Agreement,
whether or not either or both of the parties shall remarry. It
is the specific intent of the parties to permit this Agreement to
survive any judgment and to be forever binding and conclusive
upon the parties.
5, INCORPORATION IN DIVORCE DECREE: It is further agreed,
eovenanted and stipulated that this Agreement, or the essential
parts hereof. shall be ineorporated in any decree hereinafter
entered by any court of competent jurisdiction in any divorce
proeeedings that have been or may be instituted by the parties
for the purpose of enforcing the contractual obligations of the
parties. This Agreement shall not be merged in any such decree
but shall in all respeets survive the same and be forever binding
and conclusive upon the part ies.
6. EFFECTIVE DATE: The effective date of this Agreement
shall be the "date of execution" or "execution date," defined as
the date upon which it is executed by the parties if they have
eaeh exeeuted this Agreement at the same date. Otherwise, the
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AU'lunl I. ~(Jlll
"date of execution" or "execution date" of this Agreement shall
be defined as the date of execution by the party last executing
this Agreement.
7. DISTRIBUTION DATE: The transfer of property, funds
and/or documents provided for herein, shall only take place on
the "distribution date", which shall be defined as the date of
execution of this Agreement unless otherwise specified herein.
However, the support and/or alimony payments, if any, provided
for in this Agreement shall take effect as set forth in this
Agreement.
-"
8. MUTUAL RELEASE: HUSBAND and WIFE each do hereby
mutually remise, release, quit-claim and forever discharge the
other and the estate of such other, for all time to come, and for
all purposes whatsoever, of and from any and all rights, title
and interest, or claims in or against the property (including
income and gain from property hereafter accruing) of the other or
against the estate of such other, of whatever nature and
wheresoever situated, whieh he or she now has or at any time
hereafter may have against the other, the estate of such other or
any part thereof, whether arising out of any former acts,
contracts, engagements or liabilities of such other or by way of
dower or curtesy, or claims in the nature of dower or curtesy or
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AU'lllBI I, }Otll
widow's or widower's rights, family exemption or similar
allowance, or under the intestate laws, or the right to take
against the spouse's will, or the right to treat a lifetime
conveyance by the other as a testamentary gift, or all other
rights of a surviving spouse to participate in a deceased
spouse's estate, whether arising under the laws of (al
Pennsylvania, (b) any State, Commonwealth or territory of the
United states, or (c) any country or any rights which either
party may have or at any time hereafter shall have for past,
present or future support or maintenance, alimony, alimony
pendente lite, counsel fees, division of property, costs or
expenses, whether arising as a result of the marital relationship
or otherwise, except, all rights and agreements and obligations
of whatsoever nature arising or which may arise under this
Agreement or for the breach of any provisions thereof. It is the
intention of HUSBAND and WIFE to give each other, by the
execution of this Agreement, a full, complete and general release
with respect to any and all property of any kind or nature, real,
personal or mixed, which the other now owns or may hereafter
acquire, except and only exeept all rights and agreements and
obligations of whatsoever nature arising or which may arise under
this Agreement or for the breach of any provision thereof. It is
further agreed that this Agreement shall be and constitute a full
and final resolution of any and all elaims which each of the
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A\l'J'11l I. J'-,l:l
parties may have against the other for equitable division of
property, alimony, counsel fees and expenses, alimony pendente
lite or any other claims pursuant to the Pennsylvania Divorce
Code or the divorce laws of any other jurisdiction.
9. REPRESENTATION BY COUNSEL: This Agreement has been
prepared by MARIA P. COGNETTI, Esquire. counsel for WIFE. Said
counsel at the commencement of and at all stages during, the
negotiation of this Agreement, has acted solely as counsel for
WIFE and has not advised or represented HUSBAND in any manner
whatsoever. HUSBAND was represented by CATHERINE A. BOYLE,
ESQUIRE, during all proceedings in this matter, up through the
negotiation of this Agreement. After the parties reached this
Agreement HUSBAND chose to continue in this matter without
representation. HUSBAND has read this Agreement carefully and
thoroughly, fully understanding each of its provisions, and
therefore signs it clearly and voluntarily.
HUSBAND and WIFE acknowledge that this Agreement is not the
result of any duress or undue influence and that it is not the
result of any collusion or improper or ill~gal Agreement or
Agreements. The parties further acknowledge that they have each
made to the other a full aeeounting of their respective assets,
c~tate, liabilities, and sources of income and that they waive
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A.U'I"nl I. Jonl
any specific enumeration thereof for the purpose of this
Agreement, Each party agrees that he or she shall not at any
time raise as a defense or otherwise the lack of such disclosure
in any legal proceeding involving this Agreement, with the
exception of diselosure that may have been fraudulently withheld,
10. WARRANTY AS TO EXISTING OBLIGATIONS: Each party
represents that they have not heretofore incurred or contracted
for any debt or liability or obligation for which the estate of
the other party may be responsible or liable exeept as may be
provided for in this Agreement. Eaeh party agrees to indemnify
and hold the other party harmless for and against any and all
such debts, liabilities or obligations of every kind which may
have heretofore been incurred by them, ineluding those for
necessities, exeept for the obligations arising out of this
Agreement,
11, WARRANTY AS TO FUTURE OBLIGATIONS: HUSBAND and WIFE
eovenant, warrant, represent and agree that with the exception of
obligations set forth in this Agreement, neither of them shall
hereafter incur any liability whatsoever f9r whieh the estate of
the other may be liable. Eaeh party shall indemnify and hold
harmless the other party for and against any and all debts,
rharges and liabilities ineurred by the other after the exeeution
.9.
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"'lJlJCllIl I, JOOl
date of this Agreement, exeept as may be otherwise specifically
provided for by the terms of this Agreement.
12. DEBT OF THE PARTIES: HUSBAND hereby indemnifies WIFE
against, and agrees to assume the sole liability and
responsibility for, all debts, obligations or liabilities of any
nature whatsoever heretofore or hereafter incurred by HUSBAND for
the benefit of himself, except as provided herein.
WIFE hereby indemnifies HUSBAND against and agrees to assume
the sole liability and responsibility for all debts, obligations
or liabilities of any nature whatsoever heretofore or hereafter
ineurred by WIFE for the benefit of herself, except as provided
for herein.
HUSBAND shall not and will not hereafter incur or cause to
be incurred for the benefit of himself, except as provided for
herein, any debts, obligations or liabilities for any nature
whatsoever, whether for necessaries or otherwise, upon the credit
of WIFE.
WIFE shall not and will not hereafter incur or cause to be
incurred for the benefit of herself, exeept as provided for
herein, any debts, obligations or liabilities for any nature
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;''''I'IH I 1:'01
whatsoever, whether for necessaries or otherwise, upon the credit
of HUSBAND.
13. PERSONAL PROPERTY: The parties have divided between
them, to their mutual satisfaction, the personal effects,
household furniture and furnishings, and all other articles of
personal property which have heretofore been used by them in
common, and neither party will make any claim to any such items
which are now in the possession or under the control of the
other. Should it become necessary, the parties each agree to
sign any titles or documents necessary to give effect to this
paragraph upon request.
By these presents, each of the parties hereby s'pecifically
wai ves, releases, renounces and .forever abandons whatever claims
he or she may have with respect to any personal property which is
in the possession of the other, and which shall become the sole
and separate property of the other from the date of execution
hereof.
14. DIVISION OF REAL PROPERTY: HUSBAND agrees to transfer
all his right, title and interest in and to the real estate
situated at 1005 Chippenham Road, Mechanicsburg, Cumberland
County, now titled in the name of HUSBAND and IHFE as tenants by
....
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the entireties, to WIFE and agrees to immediately execute now and
in the future any and all deeds, documents or papers necessary to
effect such transfer of title upon request, HUSBAND further
acknowledges that he has no claim, right, interest or title
whatsoever in said property and further agrees never to assert
any claim to said property in the future, HUSBAND agrees to
simultaneously execute a deed conveying his interest to WIFE,
said deed to be delivered to WIFE's attorney upon the signing of
this Agreement.
WIFE hereby covenants and agrees to assume and pay in full
the remaining balance of the mortgage now existing and presently
constltuting a lien upon and encumbering the same premises, such
mortgage being owed and payable to Fleet Mortgage Group and
further covenants and agrees that she will indemnify and save
HUSBAND harmless from any and all liability, expense, cost, or
loss whatsoever as a result of her non-payment of or non-
performance of said mortgage and said mortgage conditions.
Wife further agrees that she will forthwith apply to Fleet
Mortgage Group in order to assume said loan in her name alone,
Qt, if that is not possible, to refinance the loan in order to
remove Husband's name therefrom.
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15. DIVISION OF BANK ACCOUNTS: The parties agree that the
(\)~estates Savings Account No. 239808-7731, Corestates Checking
Account No. 2336-0454, and Corestates Checking Account No.
l1L374-0458, presently held or previously held in the name of
WIFE alone or jointly by the parties, shall become the sole and
exclusive property of WIFE upon the entry of a final Decree in
Divorce. The PNC Bank account No. 50-8047-3993 held in the name
of HUSBAND alone, shall become the sole and exclusive property of
HUSBAND. The parties acknowledge that each has no further claim
or interest in said accounts of the other and agree that each
will not assert any such claim in the future.
16. DISTRIBUTION OF INDIVIDUAL RETIREMENT ACCOUNTS:
HUSBAND hereby acknowledges and agrees that WIFE shall retain, as
h,-:r separate property, free and clear from any claim, right,
title or interest on the part of HUSBAND, her Individual
Retirement Account with Ivy Account No. 030-0900702306. HUSBAND
hereby acknowledges that he has no further claim, right, title or
interest whatsoever in the Individual Retirement Aceount of WIFE,
and further agrees never to assert any claim to the asset in the
future.
WIFE hereby acknowledges and agrees that HUSBAND shall
t0tain, as his separate property, free and clear from any elaim,
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right, title or interest on the part of WIFE, his Individual
Retirement Aecount with Dean Witter Account No. 410046661
(formerly Ivy Aecount Nos. 030-0900702299 and 033-0900702299)
WIFE hereby acknowledges that she has no further claim, right,
title or interest whatsoever in the Individual Retirement Account
of HUSBAND, and further agrees never to assert any claim to the
asset in the future.
17. WIFE'S RETIREMENT ACCOUNT: HUSBAND agrees that any
monies which WIFE has acquired through her interests in either
pensions, profit sharing, savings and thrift plans, annuities
and/or retirement benefits through her present or past employers
shall remain her sole and exclusive property. HUSBAND hereby
covenants and agrees that he will execute any spousal waivers
that may be required under the Pension Reform Act of 1974, the
Retirement Equity Act of 1984, or any similar Federal or state
statute that is now in effect or may be enacted. This paragraph
is intended to substitute for any other statement, prepared form,
or document whieh might be required by any plan, fund. trust,
administrator. trustee, or similar entity or person. so that WIFE
may receive said benefits as if she were never married.
HUSBAND hereby consentB to WIFE's election to waive a
qualified joint survivor annuity form of benefit and Cl qualified
- 1,1-
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p~e-retirement survivor annuity form of benefit under her
l'<~tirement account. HUSBAND further consents to WIFE's current
and future designation of any alternative form of benefit and of
beneficiaries other than HUSBAND under said plan and to any
revocation and/or modification of such designation(s). HUSBAND
hereby further agrees to execute any and all documents or forms
which shall be required, at any time, and from time to time, by
said plan, including but not limited to, any consents required to
effect the payment of benefits in this manner. HUSBAND hereby
acknowledges that he understands the effect of WIFE's elections
and he consents thereto. HUSBAND further acknowledges that he
understands that, absent the consent contained in this paragraph,
hp. would have the right to limit his consent to the designation
by WIFE of a specific beneficiary or a specific form of benefits,
and HUSBAND hereby voluntarily elects to relinquish both such
rights.
18. HUSBAND'S RETIREMENT ACCOUNT: WIFE agrees that any
monies which HUSBAND has aequired through his interests in either
pensions, profit sharing, savings and thrift plans, annuities
and/or retirement benefits through his present or past employers
shall remain his sole and exclusive property. WIFE hereby
covenants and agrees that she will execute any spousal waivers
that may be required under the Pension Reform Aet of 1974, the
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Retire~ent Equity Act of 1984, or any similar Federal or state
statute that is now in effect or may be enacted. This paragraph
is intended to substitute for any other statement, prepared form,
or document which might be required by any plan, fund, trust,
administrator, trustee, or similar entity or person, so that
HUSBAND may receive said benefits as if he were never married.
WIFE hereby consents to HUSBAND's election to waive a
qualified joint survivor annuity form of benefit and a qualified
pre-retirement survivor annuity form of benefit under his
retirement account. WIFE further consents to HUSBAND's current
and future designation of any alternative form of benefit and of
beneficiaries other than WIFE under said plan and to any
revocation and/or modification of such designation(s). WIFE
hereby further agrees to execute any and all documents or forms
whieh shall be required, at any time, and from time to time, by
said plan, including but not limited to, any consents required to
effect the payment of benefits in this manner. WIFE hereby
acknowledges that she understands the effect of HUSBAND's
eleetions and she consents thereto. WIFE further acknowledges
that she understands that, absent the consent contained in this
paragraph, she would have the right to limit her consent to the
designation by HUSBAND of a specific beneficiary or a specific
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A\l'I"~t I. ;r'Qj
form of benefits, and WIFE hereby voluntarily elects to
relinquish both such rights.
19. REAL ESTATE PARTNERSHIP: WIFE acknowledges that HUSBAND
has a 33% ownership interest in a real estate partnership known
as 4824 Trindle Associates. WIFE agrees to transfer any and all
of her marital right, title and interest in and to that
partnership to HUSBAND. WIFE agrees to execute, now and in the
future, any and all deeds, documents or papers necessary to
effect such transfer or title upon request. WIFE further
acknowledges that she has no claim, right, interest or title
whatsoever in the said partnership and further agrees never to
assert any claim to such asset in the future.
HUSBAND hereby indemnifies WIFE against and agrees to assume
the sole liability and responsibility for any eneumbrance, lien,
loss, damages, expense, civil or criminal liability including
deficiency assessment, penalty or interest which WIFE may incur
or has incurred for any reason whatsoever as the result of any
transaction undertaken on behalf of the partnership. HUSBAND
further agrees that within sixty days of the signing of this
Agreement he will cause WIFE's name to be removed from any and
all debts that are associated with the partnership and provide
WIFE proof that her name has been removed.
- 1'1-
\"IH~b\f.ITllli ;...,Clll"H [l,l"n"!'/\11.1I11P'''1 .:,'q"........f~3 rl('I\"f1Y s..'tlo......'lI "'1''''''''''''1 "I<J
"''''r lilt I ~~Ol
20. DENTAL PARTNERSHIP: ~IIFE acknO\~ledges that HUSBAND has
a 33% ownership interest in the dental partnership of Mendelson,
Fo~r & Harrison Dental Associates. WIFE agrees to transfer any
and all of her marital right, title and interest in and to that
partnership to HUSBAND. WIFE agrees to execute, now and in the
future, any and all documents or papers necessary to effect such
transfer of title upon request. WIFE further acknowledges that
she has no claim, right, interest or title whatsoever in the said
partnership and further agrees never to assert any claim to such
asset in the future.
HUSBAND hereby indemnifies WIFE against and agrees to assume
the sole liability and responsibility for any encumbrance, lien,
loss, damages, expense, civil or criminal liability including
deficiency assessment, penalty or interest which WIFE may incur
or has incurred for any reason whatsJever as the result of any
transaetion undertaken on behalf of the partnership. HUSBAND
further agrees that within sixty days of the signing of this
Agreement he will cause WIFE's name to be removed from any and
all debts that are associated with the partnership and provide
WIFE proof that her name has been removed.
21. MOTOR VEHICLES: With respect to the motor vehicles
(~ned by one or both of the parties, they agree as follows:
-18-
~;tr.I"rll.m:l~ llllol\C1UlIlt 11l1"C'l"ry\lt..rrlll<ln'''\''',ro.''''''''t~',rr''l'''lty S..ttl"lI't'nt ".H........"~ loll'"
"1l'Jult I, 1001
(a) The 1997 Honda Odyssey shall be and remain the
sole and exclusive property of WIFE;
(b) The 1995 Honda Accord shall be and remain the sole
and exclusive property of HUSBAND,
The titles to the said motor vehicles shall be executed by
the parties, if appropriate for affecting transfer as herein
provided, on the date of execution of this Agreement, and said
executed title shall be delivered to the proper party on the
distribution date. Each party agrees to be solely responsible
for the amounts presently due and owing against his or her
respective automobile.
22. OWNERSHIP OF LIFE INSURANCE POLICIES: WIFE is cognizant
of the fact that HUSBAND has maintained and paid premiums on the
following life insurance policies: Northwestern Life Insurance
and Amerus Life Insurance. WIFE hereby expressly relinquishes,
waives and renounces any and all proprietary, statutory,
distributional, ownership and beneficiary rights and options to
the aforesaid insurance policies. WIFE hereby agrees and
warrants that HUSBAND has full and complete discretion to change
the designated benefieiaries on the aforesaid policies.
-19-
Wr,I)..~..mlly :.I-\l'II"ot t'1,..ctofy\H.uru'.n P.V..lfO..'....n~.\rr::I'..'~j' SC"ltl"""'r,1 "II~~-""t "1.1
"U'I"1l1 I. lOCI
HUSBAND is cognizant of the fact that WIFE has maintained
and paid premiums on the following life insurance policy:
Security Mutual Life Insurance. HUSBAND hereby expressly
relinquishes, waives and renounces any and all proprietary,
statutory, distributional, ownership and beneficiary rights and
options to the aforesaid insurance policies. HUSBAND hereby
agrees and warrants that WIFE has full and complete discretion to
change the designated beneficiaries on the aforesaid policy.
23. AFTER-ACOUIRED PROPERTY: Each of the parties shall
hereafter own and enjoy, independently of any claim or right of
the other, all items of property, be they real, personal or
mixed, tangible or intangible, whieh are hereafter acquired by
him or her, with full power in him or her to dispose of the same
as fully and effectively, in all respects and for all purposes,
as though he or she were unmarried.
24. LIFE INSURANCE AS SECURITY: Notwithstanding paragraph
this Agreement or for ehild support, HUSBAND shall, at no cost to
make any
('lOd3D)3/
29 of ,
SAh
ClUJ-
J-2-
~, for the period during whieh HUSBAND is obligated to
payments pursuant to paragraphs ~<, 25, 26, 27. 28, and
WIFE, provide and make all payments on a life insurance policy
under which WIFE shall be designated as irrevocable beneficiary
until such time as all PQyments as set forth above have been
-20
\\111:.(; 1,''''lly IJ'oI\CII"nt r>I,,'n,"y\tt.lI'IIHJll F.\^,"..'......IH~ '~:I''''''i !;ptll.."',.l" .s.1I........,nl ""d
.s.U'1ulit I, 2001
completed. Said policy, as deseribed above, shall be in the
amount of THREE HUNDRED THOUSAND DOLLARS ($300,000.00). HUSBAND
shall deliver to WIFE such insurance policy evidencing such
irrevocable designation of WIFE as beneficiary of said insurance
within ten (10) days from the execution of the within Agreement.
HUSBAND agrees and undertakes to payor cause to be paid all
premiums, dues and assessments on said insurance policy at least
fifteen (15) day prior to the grace date thereof. HUSBAND agrees
to provide the insurance company with authority to notify WIFE
should HUSBAND not pay the premium within five (5) days after
said premium is due and owing. A copy of such letter of
authorization shall be forwarded to WIFE.
In the event of HUSBAND's failure to pay any of the
premiums, dues or assessments that may become due on said policy
within fifteen (15) days prior to the graee date thereof, he
shall become indebted to WIFE in the amount of such premi~ms,
dues or assessments, whether or not the same shall have been paid
or advanced by WIFE. In the event that the said policy shall
have lapsed or expired, then HUSBAND agrees that he shall
immediately become indebted to WIFE in the amount of the initial
premium of a new poliey covering the life of HUSBAND in the
amount of the poliey that shall have lapsed or expired, and
-21-
\'f'll.t>',t"""lly I..... Cllrnt t'11..:tnly\H"lr;~"~"!\"Jr"f''''''n!'' i'H;.ny S..lllP"'ent "'Ir........nl "p.l
:'U'lun I. lOOI
HUSBAND's obligation to continue to pay the premiums on a new
policy shall continue has hereinbefore provided.
The foregoing shall not be deemed to limit in any way the
rights and remedies of WIFE in the event that HUSBAND shall fail
to perform the obligations required to be performed by him under
this paragraph or shall fail to pay any of the premiums, dues or
assessments that may become due on said policy within fifteen
(15) days prior to the grace date thereof.
If the life insurance policy for the benefit of WIFE, is not
in full force and effect at the time of HUSBAND's death, and WIFE
shall not have died, and WIFE does not receive the amount to
which she is entitled, then WIFE shall have a creditor's claim
and a lien against HUSBAND's estate for the difference between
the proceeds ~o which she is entitled and the amount she actually
receives upon HUSBAND's death,
At such time as all payments have been made pursuant to the
terms of this Agreement ownership of said policy shall revert
back to HUSBAND.
25. PRIVATE/PAROCHIAL SCHOOL EXPENSES: HUSBAND hereby
agrees to be fully responsible for any and all private/parochial
-22-
!ar.1 1_1"'liy 1...."l'll..nl (Jlr"'-I"ry\lldlll,"n r.\A."...._ntl 1'''1'''':'' 5..ttl_n: J,l'.....~.. "I"
",,,,,,tot I. ~OOI
school expenses for the parties' minor children until they obtain
a high school diploma, HUSBAND and WIFE aeknowledge that their
daughter, Christina, is currently enrolled in Trinity High School
and that their son, Richard, will enroll at Trinity High School
when he attains the appropriate age. HUSBAND's agreement to pay
said expenses shall be in addition to any child support order,
shall be outside the purview of the Domestie Relations Office and
shall not be a factor in any future modification requests.
26. CHILDREN'S EXPENSES: HUSBAND shall timely pay, defined
as within ten (10) days of the underlying bills, directly to the
school, teachers, and/or instruetors coneerned, all expenses
relating to the children's music instruetion and summer camps.
HUSBAND shall be required to pay for all books, supplies and
equipment required for sueh instruction or camps. HUSBAND
authorizes the expense of such instruction and eamps to be billed
directly to him. WIFE shall forward promptly to HUSBAND all
bills received by her for such instruction, activity or camp.
Said expenses shall be paid by HUSBAND through the children's
completion of high sehool. HUSBAND's agreement to pay said
expenses shall be in addition to any child support order, shall
be outside the purview of the Domestic Relations Offiee and shall
not be a factor in any future modification requests.
-23-
'....ll\t...._lh. l.,~ "l..-nt ::t"'''f}'\Il'',:,;-.,. 1:....'1"........111. ;-f.l~lti' ~..ttl.._nt .1.1"......,.1..,,,
"''''J\II.I 1. 1001
27. HIGHER EDUCATION EXPENSES: HUSBAND agrees that he will
!.,uvide the parties' children with a college education through
the attainment of a bachelor's degree or equivalent from a
eollege or university or its equivalent. It is contemplated by
the parties that college level education may be residential in
nature, and HUSBAND agrees that in connection with the college
education he will pay 100% of the following costs: tuition, room
and board, books, laboratory, student and other fees billed
directly by the educational institution. If the children should
n~side "off campus" HUSBAND shall pay the reasonable rent and
reasonable food allowance directly to the child. The parties
agree to consult with one another and with each of the children
au to the choice of any college or university and that their
concern in such eonsultation shall be governed by a college or
university most appropriate to the needs and abilities of the
ehild. The financial commitment of HUSBAND to the children shall
eontinue until they reach the age of twenty-five (25) years so
long as they remain aetively in pursuit of a degree, licensure or
eertification.
28. SUPPORT ARREARS: Pursuant to an Order of Court dated
November 19, 1998, HUSBAND is to pay WIFE ehild support and
spousal support in the amount of $3,667.00 per month. As a
I'''sult of said Order an arrearage exists. HUSBAND hereby
- ~'1 -
IIICI'\f""'li, 1....11.11..01 t'II~"'Uly\IlAII:"_n-f.\^'J''''''''''r.!~ 1"fl"..,ly fo"tll......nl ^'II..~~.-. .,,_1
^",.H I 1""1
acknowledges that his present arreilrage is $2,721.78 dS of April
20, 2001. HUSBAND agrees to pay silid arrearage in full
contemporaneously with the signing of this Agreement. Said clwck
shall be made payable to WIFE, WIFE ilgrees to notify Domestic
Relations that HUSBAND shall be given a credit of $2,721.78.
29. CHILD SUPPORT: The parties hereby agree and acknowledge
that there is currently a support order in place, docketed to no.
789 S 98, PACSES no. 682100347, in the Court of Common Pleils of
Cumberland County, Pennsylvilnia. Said order provides, in part,
for the support of the parties' two minor children. Said Order,
as it relates to the children, is currently in the amount of
$1,758.00 per month. HUSBAND and WIFE agree that the portion of
the order relating to spousal support shilll terminate in
conjunction with the start of alimony as eillled for in Pill-iJtJl-aph rtli
".fJ
29 hereof. The portion of the order relating to the children .tI'h1-
/
shall remain unchanged. Therefore, HUSBAND shall cont inue to p.IY
the sum of $1,758.00 per month for the support of his childr011
pursuant to the terms of the current order. Said amount in
subject to periodic review and modificiltion ilS allowable by th..
Pennsylvania Support Guidelines.
30. ALIMONY: HUSBAND shall pay to WIFE al1mollY III Iii.. ""111
.'
of Two Thousand Dollilrs ($2,000.00) per mClllh, C"IliIll"Il<'ln'l "II t II"
- ~s-
, ~,: nl,\f,I"l: i l"...\Cll1mt OJ r..qnry\H.H II ~r.n- g\A'lr.....,..,'nt5\tlopPuy ~..t t I.._nt A'lr".l'IoI'nt _ "f'd
AU'I''';! I ,",I
If HUSBAND files for bankruptcy within fifteen (15) yean:; O[
the date of this Agreement, this Agreement shall constitute
eonclusive evidence of the parties' intent that the obligation of
this paragraph is in the nature of support and maintenance dlld ill
not dischargeable in bankruptcy under the current bankruptcy I,IW
or any amendment thereto.
31. HEALTH INSURANCE - CHILDREN: HUSBAND shall be
responsible for and shall maintain health insurance benefitu [or
the parties' children until they have each graduated from coll,,'l"
or trade school or until age twenty-five, whichever shall [illll.
occur. HUSBAND shall supply WIFE with proof of such covel-a'l"
upon her request. The parties further agree that any non-
eovered, extraordinary medical, dental, vision, orthodontic,
psychiatrie and psychological expenses for the ehildren nh,IIl I".
paid one hundred percent (100%) by HUSBAND.
32. HEALTH INSURANCE - WIFE: HUSBAND agreen t h,\ t no lon'l
as he is associated with by Mendelson, Foer & !Iarriuon lJ,.nt.;ll
''''' Of C
Associates or any sueeessor thereof, bllt in no event ),<,.:Hrf' t h,.n
( j;{;f
fAI~
three (3) years, WIFE will continue to be C'ovt'r,.d by 111<'
practiee's health insuranee policy. IHFE '''In'(,ll to ".imIHII-n,.
HUSBAND for the premiums all hel- eov,'rdq" 011 .1 11I0lll hly ur
quarterly basis, however same an: chanl"d. !IoW"V"I', I'IIFE "hall
-2'/-
~;: $1>\ t ."'11 j' l~.. .Cllt'r.t tl r~,.t ory\Hu r 1 ~cn '1\1.1ro~~""'nt ~ \ rr r.t"" t Y !'"t t If''''''nt ...q'..f'.....nt "1'<.1
;''''j.," I 1. 1~: ~
only pay such costs as would be paid by a regular employee. If
\-IIFE desires to terminate said coverage, WIFE shall give HUSBAND
thirty days notice of same.
33. COUNSEL FEES: Except as provided herein, each party
hereby indemnifies and agrees to indemnify and hold the other
free and harmless against the claims of any attorney or person
who rendered or claims to have rendered services to him or her in
eonnection with the divoree proceedings and the negotiation of
this Agreement or otherwise,
34. INCOME TAX PRIOR RETURNS: The parties have heretofore
filed joint Federal and state tax returns. Both parties agree
that in the event any deficiency in Federal, state or local
income tax is proposed, or any assessment of any sueh tax is made
against either of them, each will indemnify and hold harmless the
other from and against any loss or liability for any such tax
deficie~cy or assessment and any interest, penalty and expense
incurred in connection therewith. Such tax, interest, penalty or
expense shall be paid solely and entirely by the individual who
is finally determined to be the cause of the misrepresentations
or failures to disclose the nature and extent of his or her
separate income on the aforesaid joint returns.
-28-
f""'II~ \....['11..111 1'lr..rl-JI.,.\Il,U'I~'..n K.,I.'I........."I~ 1""l,..,ly l;_tll_1lt '''1'....''.", "','
^".l"'" I, ;I,U'
35. CHILDREN'S TAX RETURNS: The parties acknowledge that
,. :'iAND has previously filed income tax returns for the parties'
cl.lldren. WIFE agrees that HUSBAND shall continue to file said
n,Lurns in the future and to continue to pay all tax liability,
if any, associated with said returns. HUSBAND agrees to consult
with WIFE prior to the filing of said returns so as to coordinate
"1)' information which is in WIFE I S possession which must be
""ported on said returns. HUSBAND agrees to give WIFE a copy of
all such filed returns no later than April 30th of eaeh year.
Furthermore, WIFE shall provide HUSBAND with information
received by her for tax years in which HUSBAND has already filed
r,.':urns for the children. HUSBAND will promptly amend such
returns and pay any tax liability, interest, and penalties
<I.:::ociated with the filing of said amended returns. HUSBAND
shall provide WIFE with a copy of said returns within ten (10)
d1YS of filing.
36. APPLICABILITY OF TAX LAW TO PROPERTY TRANSFERS: The
!"llties hereby agree and express their intent that any transfer
of property pursuant to this Agreement shall be within the scope
illld applicability of the Deficit Reduction Aet of 1984
(hereinafter the "Act"), specifically, the provisions of said Act
['i'rtaining to the transfers of property between spouses and
-2')-
I .. .
'II '_I. r..,.;., 1....\l.II..nt tlll"(l('ly\ll'I:;.r,,, Lrql.........I\I..\r'VI'...ty ~;..!III'"".Ul A'urr""'!l! "1"1
AJ"J1l.t 1. JC~ I
:'onner spouses. The part ies agree to sign and cause to be filed
.IIIY elect ions or other documents required by the Internal Revenue
Service to render the Act applicable to the transfers set forth
in this Agreement without recognition of gain on such transfer
and subject to the carry-over basis provisions of the said Act.
37. WAIVER OF ALIMONY: HUSBAND and WIFE recognize and
acknowledge that the foregoing provisions for their individual
benefit are satisfaetory with regard to their support and
maintenance, past, present and future. The parties release and
discharge the other absolutely and forever for the rest of their
lives from all claims and demands, past, present or future, for
alimony or for any provision for support or maintenance, except
as specifically provided for herein. The parties further
acknowledge that in consideration of the transfers made herein
each completely waives and relinquishes any and all claims and/or
demands they may now have or hereafter have against the other for
alimony, alimony pendente lite, spousal support and counsel fees,
except as specifically provided for herein.
38. EFFECT OF DIVORCE DECREE: The parties agree that
except as otherwise specifically provided herein, this Agreement
shall continue in full force and effect after sueh time as a
-30-
';tn,'t."lly 1...\CII..nt ['II'''' ly\II~III~"n .:\1"'II..r~...nt"',II,,,..lt, ~..tllf'_nt ""II~"""'" ...,,1
:'" ,.~'.l I :~()t
final Decree in Divorce may be entered with respect to the
parties.
39. BREACH: If either party breaches any provision of this
Agreement, the other party shall have the right, at his or her
election, to sue for damages for such breach or seek such other
remedies or relief as may be available to him or her, and the
party breaching this contract shall be responsible for payment of
reasonable legal fees and costs incurred by the other in
enforcing their rights under this Agreement.
40. WAIVER OF CLAIMS: 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 shall now have or hereafter acquire, under the present and
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, dower, curtesy, statutory
allowance, widow's allowance, widower's allowanee, right to take
in intestacy, right to take against the Will of the other, and
the right to act as administrator or exeeutor of the other's
estate. Each party will, at the request of the other, execute,
aeknowledge and deliver any and all instruments whieh may be
-31-
dd "I" r.I"HI,' :.,..\('11"111 llU..n"ry\II.UrU<lo.t;\A'Jr...."'..n" ;:',r"ny r...lt l"_ot A.,I........r.t "',,'
:.',d~:.1 I. ~ ..
r.",;essary or advisable to carry into effect this mutual waiver
.".J relinquishment of all such interests, rights and claims.
41. ENTIRE AGREEMENT: This Agreement contains the entire
understanding of the parties and there are no representations,
w'lrranties, covenants or undertakings other than those expressly
net forth herein.
42. FINANCIAL DISCLOSURE: The parties confirm that they
iklVe relied on the completeness and substantial accuracy of the
financial disclosure of the other as an inducement to the
execution of this Agreement. Notwithstanding the foregoing, the
rights of either party to pursue a claim for equitable
distribution, pursuant to the Pennsylvania Divorce Code, of any
interest owned by the other party in an asset of any nature at
any time prior to the date of execution of this Agreement that
was not disclosed to the other party or his or her counsel prior
to the date of the within Agreement is expressly reserved. In
the event that either party, at any time hereafter, discovers
such an undisclosed asset, that party shall have the right to
petition the Court of Common Pleas of Cumberland County to make
equitable distribution of said asset.
-32-
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
MI, t(7-3{Afj (lit/I.
Slate Commonweallh 01 Pennsvlvania /)),t!C;~''5 dld/v}"!'?/
Co.lCily/Disl. of CUMBERLAND '>., flY,
Date of Order/Notice 11/01/01 .LYe. :III/I(
Court/Case Number (See Addendum (or case summary)
EmploYl'''\Vilhholdt'r'\ Ft'dt'r.ll fiN Numb'r
MENDELSON, FOER, HARRISON
Employt'rNVilhholcft'r'\ NoImt'
DENTAL ASSOCIATES
Employt'rlWilhhol(h','s Addn'ss
4824 E TRINDLE RD
MECHANICS BURG PA 17055-3617
@OriginJI Onlt'r/NCllirt.
o Aml'nllt,d Ordf.'r/Nolirt'
o Tt'rminJh' Onlf.'r/Noliu'
J RE, HARRISON , CR.
I Emplo~'I','JOblj~or's NJml' ll.hl, Finl, Mil
J
I
J
J
J
J
J
564-72-2683
Empl{)Yt'I'JOhlignr'~ ~{)d,1I St'curily Numht'r
9319100097
EmploYI'I'JObligor'.. C.I\t! Id,'nlifil'f
(Srp Addtndum (0( pldinti" nlmps dSSOOdtl'd with e.sf'S on ..tt.chmrntJ
CU\IOfH.1I P,Jn'nl's N.lrnt. (LHI. Fi~l. Mil
See Addendum (or dependent names and birth dates associated with cases on attachment,
ORDER INFORMA nON: This is an Order/Notice to Wilhhold Income lor Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to dedud Ihese
amounls Irom Ihe above-named employee's/obligor's income unlil lurther notice even il Ihe Order/Notice is nOI
issued by your Slate.
$ 3 ,758.00 per month in currenl support
$ 75.00 per monlh in past-due support
$ 0.00 per monlh in medical support
$ 0.00 per monlh for genelic leSI costs
$ per monlh in olher (specify)
for a total 01 $ 3, 833 .00 per month to be forwarded to payee below.
You do not have 10 vary your pay cycle 10 be in compliance with the support order. II your pay cycle does not match
Ihe ordered support payment cycle, use the following 10 deJprmine how much 10 withhold:
$ 884.54 per weekly pay period.
$ 1.769.08 per biweekly pay peri"" ' ),
$ 1.916 50 per semimonJ~I, ;
$ 3.833.00 per monlh,
REMITTANCE INFORMAT/O" 0'
You must begin withholding no ilr ~
Order/Notice. Send payment w,
dedud a lee 10 defray the cost 01
the allowable amount. The total \
aggregate disposable weekly earnil
needed (See #9 on pg. 2).
Arrears 12 weeks or greaterl
@yes 0 no
'rring len (1 Ol working days after the dale of Ihis
paydate/date of withholding. You are enlitled 10
""verning the work slate 01 your employee ler Ihe
,uur fee, cannol exceed 55% 01 the employee's/ obligor's
~"rpose of the limilalion on withholding, the lollowing inlormation is
If remitting by EFT/EDI, please call Pennsylvania State Coiled ions and Disbursemenl UnillSCDUl Employer
Customer Service at 1-877-676-9580 lor instructions.
Make Remittance Payable to: PA seDU
Send check to: Pennsylvania SeDU, P,O, Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL,
Date 01 Order:
NOV 2 2001
Service Type M
~
l/-;){) I
(1\1110.., ,:'l.','OIH
hl'".I,,,,, 1'.1" I ~ II ".'
BY THE COURT:
~, /9.
I{r '/" Ni-<;:':,
4..
Jt.,)(.x
lonn IN-028
WOIker ID $IATT
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
MI, t/7-dc.df( ell/It.
State Commonwealth of Pennsvlvania /';,c~:;':> d/'/lo)t)' 7/
Co.lCity/Dist. of CUMBERLAND )" "/17"
Date of Order/Notice 11/01/01 02 .:51/'/$/
Court/Case Number fSee Addendum (or case summary)
@ OrifotinJI Or"('r/NoljCl~
o Aml'ndt'll Dnler/Nolin'
o Tt'rminJb' OnlN/Nolin'
EmploYl'r^'VilhholdL'r's Ft'dl'r.d EIN Numht'r
MENDELSON, FOER, HARRISON
Employt'rJ\Vilhholder's Ndmt'
DENTAL ASSOCIATES
EmploYI'rM/ilhholder's Addn'ss
4824 E TRINDLE RD
MECHANICSBURG PA 17055-3617
) RE, HARRISON, C R.
) Empl{)~'I't'IOhlj~nr's N.lml' (LoiS!, Firsl, Mil
) 564-72-2683
l Empl()Yt.t'/Ohli~ur's SIx:iJI Sllcurily NumlX'r
) 9319100097
) EmploYI'I'/Obli~or's CdS\! hfl~nlj(iL'r
) (SE'f' Addfndum 101 pJ,J;ntiff ndmf'S dssoddtf'd with C.JSflS on .att.chmMt)
) Cuslodi.&1 P,m-n"s Naml' lLJS1. Fir-.l. Mil
)
See Addendum (or dependent names and birth dates associated with cases on attachment,
ORDER INFORMA TION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to dedud these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 3.758.00 per month in current support
$ 75.00 per month in past-due support Arrears 12 weeks or greaterl @yes 0 no
$ 0.00 per month in medical support
$ 0.00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 3,833.00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 884.54 per weekly pay period.
$ 1.769.08 per biweekly pay period (every two weeks!.
$ 1.916 50 per semimonthly pay period (twice a month!.
$ 3. 833.00 per monthly pay period.
REMITTANCE INFORMA nON:
You must begin Withholding no later than the first pay period occurring ten (10l working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
dedud a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's! obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on pg. 2l.
If remitting by EFT/EDI, please call Pennsylvania State Coiled ions and Disbursement Unit (SCDUl Employer
Customer Service at 1-B77-676-95BO for instructions.
Make Remittance Payable to: PA seou
Send check to: Pennsylvania seou, P,Q, Box 69112, Harrisburg, Pa 17106.9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BY THE COURT:
Date of Order:
NOV 2 2001
~, /9.
~/t- 'r N /Il. <.-;
4..
Service Type M
\VUUJ.ED
//;){ll
I ;\1 n '." P",'i'_1l1 ~ ~
"JL ,)1;...-
Form EN-02B
Worker 10 SIATT
1'1"'.1..". r ,,,I,. I ~ j 1 ','<1
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If checked you olre required 10 providt~ a ropy of this form In your f'l11ployt'e.
1. Priority: \Vilhholding under this Order/Not ire holl) priority OVl'r ,my ollwr It'gdl prore'iS under SrJle law oJgJimt the s.Jn1e innll1l1!.
FederJI t.1X levies in effert before receipt oflhili ord!!r hJVf~ priorily. Ifther!' Jrt! Fed,'rdl tJX h!vies in dfe<:t pleJse contJef the requesting
.IW~I1(Y listed helow.
2. CombininR Payments: You ("oJll comb/nl! withheld .unounl\ (rom mort! 111.111 0111' (!l11ploYt't>JohliglJr's income in oJ single pJYl11f~nl
to p.dch Jgency requesting withholding. Yuu mUlOt, hOWI'VI", wpJrdft'ly idt'lllify tlw portion of the single payment Ihill is Jllributdble 10
f~dCh f~l11ployepJobliKor.
J. '-ReponingthePaydatelDatenl Withholding:~ You mm! ....pon th~ payd.te/date olwithholdin~ when'endin~ th~ p.yment. ~~The~
p<tytbt~ate-ofwithtmfdinRi'-th~d.1teon whim amount \Va' withheld from th1'" f'!'mplo~', \'Va~~; You mUl:ot romply with tilt' l.Jw of Ilw
...rdtp of the employee's/obligor's prindpJI pl.lee of employment with rt~lipNt to the till\t~ rwriod.. within whirh you mu..t implt'Olt'flt Ihe
withholding order .md (orw.Jrd t1w support pJynwnts.
4." Employee/Obligor with Multiple Support Holdings: If then~ is more IhJIl olle Order/Nolie-I" In \\lithhold Inronw for Support
JgJinst this employee/obligor Jnd you Jre ull..!ble 10 honor JII support Order/Notices due to FederJI or Sidle withholding limit.... you must
{ollow the IdW of the sidle of employee's/obligor's prinripdl pl.Jrp. of employment. You nu....' honor JII OrdPrs/Notires to lhe gredle..t
eXlent possible. (See #9 below)
5. Termination Notificdtion: You must promptly notify the Requesting Agency when the employee/obligor is no longer working (or
you. Pled!e provide the in(ormJtion requested .md return ol copy of this Order/Notire to the Agency identified below.
WITHHOLDER'S ID: 6286100068
EMPLOYEE'S/OBLlGOR'S NAME: HARRISON. CR.
EMPLOYEE'S CASE IDENTIFIER: 9319100097 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Pdyments: You may be required to report olnd withhold (rom lump sum pdyments such as bonuses, commissions, or
severolnce polY. If you have Jny questions about lump sum payments, C"ont.lct the person or duthority below.
7. Liability: If you f.liI to withhold income dS the Order/Notice directs, you .lre liable (or both the Jccumulated Jmount you should
hJve withheld from the employee/obligor's income and olher penolhies set by Pennsylv.mia State IdW. Pennsylv.miol Stolte law governs
unless the obligor is employed in Jnather Stolte, in \,\'hich Colse the lolW o( rhe State in which he or she is employed governs.
6. Anti-discriminJtion: You are subject to ol fine df'lermirwd under Sfolte IdW for di'irhdrging dn employeeJobligor (rom
empbyment, refusing to employ, or taking disc-iplil1olry dC"tion dgdinst dny Pl11ployef'/nhligor becduse of ol support wilhholding.
PennsylvdniJ Stdte IJW goverm unless the obligor i'i employed in olllother Stolle, in which (-ol'ie the lolW o( the Stolte in \\'hirh lu' or 'ihe i'i
employed governs.
9.. Withholding Limits: You may not withhold more thJn the lesser 0(: 11 the olmounts Jllowed by the Federal Consumer Credit
Protection Act (15 U.S.c. 91673 (h)1; or 2) the Jmounls olllowed by rhe StOlte of the employee'o;;/obli~or's principal pl.Ke of employment.
The FederJllimit Jpplies to the Jg~regJte disposable weekly e.uning'i (AO\VE). AOWE is the net inrome leh Jfter mJking mollldoltory
deductions such as: State, Federdl,loC"olI taxes; Soddl Serurity tJxes; Jlld Medicare tJxes.
10.
'NOTE: II you or your agent are served with a copy 01 this order in the state that issued the order, you are to loll ow the
law of the state that issued this order with resped to these items.
Requesting Agency:
DOMESTIC RHATlONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
II you or your employee/obligor have any questions,
conrad WAGE AITACHMENT UNIT
by telephone at (717) 240.6225 or
by FAX at (717) 240-6248 or
by Internet @
P~ge 2 of 2
Form FN-028
Worker ID $IATT
Service Type M
( ) \' 1\ '." <I,.~n" I \ ~
1'1'"..1', " ('.'" I~.! I .'.,
ADDENDUM
Summary of Cases on AlIachment
Defendant/Obligor: HARRISON, CR.
PACSES Cd'" Numlwr 914103971/:;;Ol/
PJdintiff Nolmp.
ELIZABETII IIARRIBOtl
Dork.., AtI.lrhmenl Amount
97-3614 eIVIL$ 2,000.00
Child(ren)'s Ndme(.): DOB
o If checked, you dre required to enroll the child(,en)
identified dbove in .my health insl1r..mce roverdgp. olVdilolble
through the employee's/ohligor's employment.
PACSES Cdse Numher
Plaintiff Name
Dorket AnJrhmf-'nt Amount
$ 0.00
Child(ren)'s Namels):
DOB
Dlf checked, you are required to enroll the child(ren)
identified Jbove in any health insurance coverage dVJilJble
through the employee'slobligor's employment.
PACSES Cdse Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'. Name{sl:
DOB
o If checked, you are required to enroll th" child(ren)
identified dbove in ,my heJlth insurJllre roverJHP JVdilJble
through the employee's1obligor's employment.
Addendum
SeNice Type M
(l\\K "", !I'l~(l.,' I S~
"I,,,.t,,,,,I.,I..I:llilU
PACSES Cd,e Numlwr
PIJintiff NJIlW
Duchl Attdfhmt!nf Amount
$ 0.00
Child{ren)'s Ndme(.):
DOB
o If checked, you are required to enroll the child(ren)
identified above in .lny heJlth insurJnce coverage dvailable
through the employee's1obligor's employment.
PACSES Cd,e Numher
Plaintiff Name
Dorket Att<lrhml-'nt Amount
$ 0.00
Childlren)'s Name{s):
DOB
o If checked, you a,e required to enroll the child!ren)
identified above in olny health insurance coverage available
through the employee's/obligor's employment.
PACSES Cdse Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(,en)'s Name(s):
DDB
o If ,he,ked, you dre required to enrollth. child!ren}
identified dlxJVP in any health insur.Jnce ("overage available
lhrou~h the employee'~ohliKor'S emploympnl.
Form E N-028
Worker 10 $IATT