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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF ~. PENNA.
SANDRA L. GORHAM.
Plaintiff
~ o. 97-5945 exYU." 1997
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JAMES G. GORHAM, JR.,
Defendant
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DECREE IN
DIVORCE
AND NOW,. .V.lItf4.:. ..?? ......, 19.0q.
it is ordered and
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decreed that ............... ,-;r\t-Jl?!~!\ I". 0.Qr!l,l~~. . . . . . . . . .. . . . ., plaintiff.
and. .... ....... . .. . . .. ..,Ti\M.E;'i. G... .GO!l!I.i\M,..J.~.... .... ....... defendant,
are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet
been entered;
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. . . . . . NO~.E . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . y;./' . , . . , . . . . . . . . . ,
... .... .... ........ ...... .... ........,'..... .... ..... ..... ...
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SANDRA L. GORIIAM.
Plaintifl'
; COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, ;"ENNSYI.V ANIA
v,
: NO, 97-5945 CIVIL TERM
; CIVIL ACTION - LAW
: IN DIVORCE
JAMES G, GORHAM.
Defendant
PRACEIPE TO TRANSMIT RECORD
TO THE PROTHONOT AR Y:
Transmit the record. together with the following information, to the Court for
enll)' of a Divorce Decree:
L Ground for divorce: irretrievable breakdown under 3301(c) of the Divorce
Code,
2, Date and manner of service of the Complaint: Certified Mail, Restricted
Delivery delivered on November 1, 1997. a Certifi.:ate of Service filed on December 18,
1997,
3, Date of execution of the affidavit of consent required by 3301(c) of the
Divorce Code: by Plaintiff 10-13-99 ; by Defendant 10-2l-99
4.
Related claims pending: NONE
5,
Prothonotary:
Dale Plaintifl's Waiver of Notice in 3301(c) Divorce was filed with the
10-13-99
Prothonotary:
Date Defendant's Waiver of NOlice in 3301(c) Divorce was filed with the
10-27-99
Respectfully submitted,
Date: 11-2 'I',
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Mindy S. Goodman
Attorney at Law
1.0, No. 78407
2080 Linglestown Road
Harrisburg, PA 17110
(717) 540-8742
,
Attorney for Plaintiff
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SANDRA L. GORHAM.
PLAINTIFIo'
IN THE COURT OF COMMON
PLEAS OF CUMBERt.AND
COUNTY. PENNSYLVANIA
No. CIVIL 1997
c?7-S111S ~ 7~
v.
JAMES G. GORHAM.
DEFENDANT
CIVIL ACTION - IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the
claims set forth in the following pages, you must take prompt action. You are warned
that if you fail to do so, the case may proceed without you and a decree of divorce or
annulment may be entered against you by the court. Ajudgment may also be
entered against you for any other claim or relief requested in these papers by the
plaintiff. You may lose money or property or other rights important to you. including
custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the
marriage. you may request marriage counseling. A list of marriage counselors is
available in the office of the Prothonotary at the Lancaster County Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF
PROPERTY. LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR
ANNULMENT IS GRANTED. YOU MAY LOSE THE RIGHT TO CLAIM ANY OF
THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CA1\~ GET LEGAL HELP.
Court Administrator
Fourth Floor
Cumberland County Courthouse
Carlisle, P A 17602
(717) 240-6200
SANDRA L. GORHAM,
PLAINTIFF
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
No. CIVIL 1997
q7-54~S- cA.~ 1~
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v.
JAMES G. GORHAM,
DEFENDANT
CIVIL ACTION - IN DJVORCE
COMPLAIN'!' IN DIVORCE
1. PlaintitTis Sandra L. Gorham, who currently resides at 10 S. High Street,
Mechanicsburg, Cumberland County, Pennsylvania.
2. Defendant is James G. Gorham, who currently resides at 760 Conodoguinet
Avenue, Carlisle, Cumberland County, Pennsylvania.
3. PlaintitThas been a bona fide resident of the Commonwealth of
Pennsylvania for a period of more than six (6) months immediately preceding the
filing of this Complaint.
4. The parties were married on the third day of May, 1986, in Carlisle,
Cumberland County, Pennsylvania.
5. Neither plaintilTnor defendant is in the military or naval service of the
United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief
Act of the Congress of 194G and its amendments.
6. A prior action in divorce was filed by PlaintilTin 1991, and docketed at455
Civil 1991. PlaintitThas this week learned that the prior action was purged in 1994.
7. '!he plaintilThas been advised that counseling is available and that plaintitT
may have the right to request that the Court require the parties to participate in
counseling.
8. PlaintitT and Defendant have no minor children.
9. Plaintiff requests an equitable distribution be made of all marital property.
10. The marriage of the parties is irretrievably broken.
WHEREFORE, plaintilTrespectfully requests the Court to enter a decree of
divorce pursuant to ~ 3301 of the Divorce Code.
Respectfully submitted,
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t1sha K. Frederick, Esq.
Attorney for Plaintiff
State 1.0. No. 72406
P.O. Box 5228
'4407 N. Front Street
Harrisburg, PA 17110
(717) 236-8241
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VERn'ICATlON TO COMPLAINT IN DIVORCE
Plaintiff verifies that the statements made in this Complaint in Divorce are
true and correct. Plaintiffunderstand8 that false statements herein are made
subject to the penalties of 18 Pa.C.S. ~904, relating to unsworn falsification to
authorities.
Date: /~5f7
,~~A~O~
Sandra L. Gorham
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SANDRA L. GORHAM,
Plaintiff
; IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97-5945 CIVIL TERM
JAMES G. GORHAM, JR..
Defendant
.
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE
UNDER 330Htl OF THE DIVORCE CODE
1. A Complaint in divorce under ~ 3301 (c) of the Divorce Code was filed on
October 27, 1997.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of fil ing and service of the Complaint.
3. I consent to the entry of a final decree of divorce without formal notice of the
intention to request entry of a divorce decree.
4. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
5. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the Decree will be sent to me immediately after it is filed
with Ihe Prothonotary.
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.
Cons. Stat. ~ 4904. relating to unsworn falsification to authorities.
Date:j}-23-99
ames G. Gorham, Jr.
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IN THE COURT OF COMMON
PLEAS OF CU1-ffiERLAND
COUNTY, PENNSYLVANIA
No. 97.5945 CIVIL TERM
CML ACTION --LAW
IN DIVORCE
SANDRA L. GORHAM,
Plaintiff'
JAMES G. GORHAM,
Defendant
PROOF OF SERVICE
I, Latisha K. Frederick, Attorney for Plaintiff, do hereby certify that on the
first day of' November 1997, a true and correct t1>Py of the Plaintiff's Complaint for
Divorce was served on the Defendant, JamgS G. Gorham, by certified mail, restricted
delivery, return receipt requested. Proof of Service is evidenced by "Exhibit One"
(attached).
Respectfully submitted,
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La 'sha K. Frederick, Esq.
4407 N. Front Street
P.O. Box 5228
Harrisburg, PA 17110
State 1.0. No. 72406
(717) 236-8241
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October 29,1997
VIA CMRRR, RESl'RICTED DELIVERY
ITEM NO. P 0015 212 210
AND FIRST CLASS U.S. MAIL
Mr. James G. Gorham
760 Ccmodoguinet Ave.
Carlisle, PA 17013
He: ComplainttnDivorce
Dear Mr. Gorham:
Enclosed for service upon you pursuant to Pa.R.C.P. 1930.4 please find a
Complain\ in Divorce tiled by Sandra Gorham on October 27, 1997. According to the
Cumberland County Prothonotary, the prior divorce action was purged from the
Cumberland County records in 1994, necessitating a new tiling. I left word early last
week with Mr. Gilroy that he should contact me ifhe was willing to accept service of
the Complaint in Divorce. Mr. Gilroy has not contacted me; therefore, I am serving
you, directly.
Best regards,
;tiiJ~~~
Latisha K. Frederick
Enclosure
pc: Sandra Gorham
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'I' C...... ItemI 3. IOd 4. · ·
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nm.m WI 0....10 yQU< "
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fj . .'JMft~n"ft"will"'._.homlNMtil;\ew..~tdlnd"'-dlit.
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J 3. Article Add,...od to:
r Mr. James G. Gorham
6:~I~~~~~~~~~f~ Ave.
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folio wine ,.,viC" tfOl M ,Atre
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~ Receipt for
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Mr. James G. Gorham
760 Conodoguinet Ave
Carlisle, PA 17013 .
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IN THE COllIn OF COMI10N PLEAS OF
CUMBERLAND COUNTY, P~NNSYLVANIA
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IN DIVORCE
STATUS SHEET
DATE:
ACTIVITIES:
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OFFICI! OF OIVORCI! MASTER
CUMBEALAND COUNTY
COIJAT OF COMMON PLEAS
9 North Hano,er Slreet
Carlisle. PA 17013
(717) 240.6535
I. Ro"'~ IlIek.r, II
Divorce Masler
Trael .10 Coht.r
Office Manager Reporte..
w.., Ihor.
697.0371 Exl 6535
May 15, 1999
Mindy S. Goodman
Attorney at Law
2080 Linglestown Road
Harrisburg, PA 17110
Hubert X. Gilroy, Esquire
BROUJOS , GILROY, P.C.
4 North Hanover street
Carlisle, PA 17013
RE: Sandra L. Gorham vs. James G. Gorham
No. 97- 5945 civil
In Divorce
Dear Ms. Goodman and Mr. Gilroy:
By order of Court of President Judge George E. Hoffer
dated May 7, 1999, the full-time Master has been appointed in
the above referenced divorce proceedings.
A divorce complaint was filed on october 27, 1997,
raising grounds for divorce of irretrievable breakdown of the
marriage. No economic claims w~re raised in the complaint.
On February 17, 1998, the Plaintiff filed a petition
raising the economic claim of equitable distribution. No othwr
economic claims have been raised although the motion for
appointment of Master indicates that cost and expenses are
before the Master. I do not see any pleading raising that olai.
in the file.
I am going to proceed on the d3su~pt~on that grounds tor
divorce are not a~ issue and that the parties will either eign
affidavits of consent or have teen separated for a period in
excess of two years.
Based on that assumption, I am directing each counsel to
file a pro-trial statement in accordance with P.R.C.P.
1920.33(b) on or before Monday, June 14, 1999. Upon receipt of
Ms. Goodman and Mr. Gilroy, Attorneys at Law
15 May 1999
Paae 2
the pre-trial statements, I wil~ immediately schedule a
pre-hearing conference with counsel to discuss the issues and,
if necessary, schedule a hearing.
Very truly yours,
E. Rohert Elicker, II
Divorce Master
NOTE: Sanctions for failure to file the pre-trial statements
are set forth in subdivision (c) and (d) of Rul_ 1920.33.
THE ORIGINAL PRE-TRIAL STATEMENT SHOULD BE FILED IN THE
MASTER'S OFFICE AND A COpy SENT DIRECTLY TO OPPOSING
COUNSEL.
SANDRA L. GORHAM,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97-5945
JAMES G. GORHAM. JR..
Defendant
: CIVIL ACTlmJ - LAW
: IN DIVORCE
SOCIAL SECURITY DISCLOSURE
Plaintiff provides the Court with the following information in accordance
with the Itlws of the Commonwealth of Pennsylvania:
Plaintiff's Social Security Number is 181-42-9260.
Defendant's Social Security Number is 210-40-0365.
Respectfully submitted,
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Mindy S. Goodman
Attorney at Law
2080 Linglestown Road
Harrisburg, PA 17110
(717) 540-8742
Attorney for Plaintiff
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
SANDRA L GORHAM,
Plaintiff
SHARON L KREINER,
Defendant
: NO. 97-5945 CIVIL TERM
: CIVIL ACTION - IN DIVORCE
f.8AECIPE TO WITHDRAW PLAINTIFF'S CLAIM
FOR EQUITABLE DISTRIBUTION
Plaintiff. SANDRA L. GORHAM, by and through her counsel of record, Mindy S.
Goodman, Attorney at Law, respectfully represe"ts that:
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed
on October 27, 1997 in the above-captioned proC'.eeding.
2. Plaintiff filed a Petition for Special Relief in the Form of Equitable Distribution of
Property on FebnJary 17, 1997 in the above-captioned proceeding.
3. Plaintiff hereby withdraws Petition for Special Relief in the Form of Equitable
Distribution of Property on February 17, 1997.
Respectfully submitted,
Date: /1- l- <} ~.
BY:~~\S (-~ J2.
Mindy S. Goodman
Attorney at Law
Attorney 10 #78407
2080 Linglestown Road
Harrisburg, PA 17110
(717j 540-8742
Attorney for Plaintiff
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SANDRA L. GORHAM,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: No. 97.5945 CIVIL TERM
: CIVIL ACTION LAW
: IN DIVORCE
JAMES G. GORHAM,
Defendant
ORDER APPOINTING MASTER
7 "P'- )., .
day of /n ar ,1999,
, Esquire, is appointed Master with respect to the
AND NOW, this
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following claims:
BY THE COURT:
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SANDRA L. GORHAM,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: No. 97.5945 CIVIL TERM
JAMES G. GORHAM,
Defendant
: CIVil. ACTION LAW
: IN DIVORCE
MOTION FOR APPOI~TMENT OF MASTER
Sandra L. Gorham, Plaintir., moves the Court to appoint a master with
respect to the following claims:
(X) Divorce
( ) Annulment
( ) Alimony
(X) Distribution of Property
( ) Support
( ) Counsel Fees
( ) Alimony Pendente Lite (X) Costs and Expenses
and in support of the motion states:
(1) Discovery is complete as to the claim(s) for which the appointment of
a master is requested
(2) The Defendant has appeared in the action by his attorney, Hubert X.
Gilroy, Esquire.
(3) The statutory ground for divorce is Section 3301 of the Divorce Code.
(4) The action is contested with respect to the division of marital property;
namely, the marital residence located at 760 Conodoguinet Avenue, Carlisle,
Cumberland County, Pennsylvania.
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
No. 97.5945 CML TERM
CIVIL ACTION --LAW
IN DIVORCE
SANDRA L, GORHAM,
PlaintitTIPetitioner
JAMES G. GORHAM,
DefendantJRespondent
fETlTIONFOR SPECIALRELlEF INTHEFORMOFEQurrjlD.LE
D/STRIBUTIONOFPROPElfl'Y
1. Petitioner is Sandra Gorham who currently resides in the County of
Cumberland, State of Pennsylvania, and who can be contacted through her
attorney ofrecord, Latisha K. Frederick, 4407 North Front Street, P.O. Box 5228,
Harrisburg, Pennsylvania 17110, (717) '236-8241.
2, Respondent is James G, Gorham who currently resides in the city of
Carlisle, County of Cumberland, State of Pennsylvania, and who can be cont:lcted
through his attorney of record, Hubert X, Gilroy, 4 North Hanover Street, Carlisle,
17013,(717)243-4574,
3. Petitioner and Respondent are husband and wife, having been married
on May 3, 1986 in the city of Carlisle, Cumberland County, Pennsylvania.
4. Petitioner filed a Complaint in Divorce on October 27, 1997. Respondent
was served with the Complaint in Divorce on November 1, 1997.
5, Petitioner and Respondent own various real and personal property as
marital property
6, Petitioner desires the equitable distribution of the marital property.
CERTIFICATE OF SERVICE
And now, this 12th day of February, 1998, I, Latisha K. Frederick, Esquire,
hereby certify that I have mailed a true and correct copy of the forllgoing
document to counsel for Respondent addressed as follows:
Hubert X. Gilroy, Esq.
4 North Hanover Street
Carlisle, PA 17013
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La sa, Frederick, Esq.
Attorney for Petitioner
State I.D. No. 72406
4407 N. Front St.
P.O, Box 5228
Harrisburg, PA 17110
(717)236-8241
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SANDRA L, GORHAM,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: No. 97-5945 CIVIL TERM
: CIVIL ACTION LAW
: IN DIVORCE
JAMES G, GORHAM,
Defendant
INVENTORY AND APPRAISEMENT
AND INCOME AND EXPENSE STATEMENT
OF PLAINTIFF. SANDRA L, GORHAM
Plaintiff 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,
Plaintiff verifies that the statements made in this Inventory and Appraisement
are true and correct. Plaintiff understands that false statements herein are made
subject to the penalties of 18 Pa, C,S, Section 4904, relating to unsworn falsification
to authorities,
'~~l ~C~/>??
Sandra L. Gorham
il
Ali!~J:TS OF PARTIES
Plaintiff marks on the list below those items applicable to the case at bar and
Itemizes the assets on the following pages, If an item has been appraised, a copy of
the appraisal report Is attached,
X 1. Real Property
2, Motor Vehicles
3, Stocks, bonds, securities and options
4, Certificates of deposit
5, Checking accounts, cash
6, Savings accounts, money market and savings certificates
7. Contents of Safe Deposit Boxes
8, Trusts
9. Life Insurance policies (indicated face value, cash value and
current beneficiaries)
10, Annuities
11, Gifts
12, Inheritances
13, Patents, copyrights, inventions and royalties
14. Personal property outside the home
15, Businesses (list all owners, including percentage of ownership.
and officer/director positions held by a party with company)
16, Employment termination benefits.. severance pay, Workman's
Compensation claim/award
17, Profit sharing plan
18, Pension plans (indicate employee contribution and date plan
vests)
19, Retirement plans, Individual Retirement Accounts
20. Disability payments
21, Litigation claims (matured and unmatured)
22, MilitaryN,A, benefits
23, Education benefits
X 24. Debts due, including loans, mortgages held
25, Household furnishings and personalty (include a total category
and attach itemized list of distribution of such assets is in
dispute)
30. Other
MARITAL PROPERTY
Plaintiff lists all marital property in which either or both spouses have a legal
or equitable interest individually or with any other person as of the date this action
was commenced:
Item Description Names of Date of
Number of Prooertv all Owners ACQuisition
1. $1,000 or Pickup Truck James Gorham 5/86
wedding money used,
2, Dehumidifier - gift by Both parties 6/86
Plaintiff's parents
3, Outdoor Gas Grill- gift Both parties 7/87
by Plaintiff's parents
4. Stack Washer/Dryer Both parties 5/88
5, Canoe Both parties 5/88
6, Aquarium Both parties 7/89
7, Console Television Both parties 6/85
8. Oak Desk Both parties 5/85
9, Oak Drop Leaf Table Both parties 5/88
10, Oak Glass Front Hutch Both parties 5/86
11. Oak Bench Wedding gift 5/86
12, 3 Lawn Mowers Both parties 5/86, 6/87, 6/89
13, Air Conditioner - gift by Both parties 6/89
Defendant's mother
14. Stove - gift by Plaintiffs Both parties 9/89
parents
Cost or Value Value as of
Item as of Date Date Action Amount of
Number of ACQuisition Commenced any lien
1, $10,0:)0,00 n/a
2, $300,00 n/a
3, $500,00 n/a
4, $500,00 n/a
5, $200.00 n/a
6, $150.00 n/a
7. $1,200,00 n/a
8. $400,00 n/a
9, $200,00 n'a
10, $400,00 n/a
11, $100.00 n/a
12, $100,00 each n'a
13, $400,00 n'a
14, $400,00 n'a
~ON-MARITAL PROPERrt
Plaintiff lists all property in which a spouse has a legal or equitable Interest
which is claimed to be excluded from marital property:
Item
Number
1,
Item
Number
1,
Item
Number
n'a
Item
Number
1,
Description Names of Date of
of Procertv all Owners ACQuisition
1988 Dodge Caravan Sandra Gorham 10/92
Cost or Value Value as of
as of Date Date Action Amount of
of ACQuisition Commenced anv Lien
$2,000,00 n'a
Nature of
anv lien
Effective
Date of
Lien
Holder of
Lien
Basis for Exclusion from Marital Procertv
Purchased after date of separation with
non-marital funds,
fBQfgBTYTRAH~fERRgQ
Plaintiff lists all property In which either or both spouses had a l&gal or
equitable Interest individually or with any other person and which has been
transferred within the preceding three years:
Item
Number
Description
of ProDertv
Names of
all Owners
Date of Date of
Acaulsitlon Transfer
n/a
Item
Number
Cost or Value
as of Date
of ACQuIsition
Value as of
Date of
Transfer
Amount of any
Lien as of
Date of Transfer
n/a
Item
Number
Nature of
anv Lien
Date of
Lien
Holder of
Lien
_n/a
LIABILITIES OF PARTIES
Plaintiff marks on this list below those items applicable to the case at bar and
itemizes the liabilities on the following pages:
Secured
X 1. Mortgages
2, Judgments
3, Liens
4, Other secured liabilities
Un.ecured
5, Credit card balances
6. Purchases
7. Loan payments
8, Notes payable
9, Other unsecured liabilities
Contingent or Deferred
10, Contracts or Agreements
11. Promissory notes
12, Lawsuits
13. Options
14, Taxes
15, Other contingent or deferred liabilities
I"lADIl.ITIF;!}
Plaintiff lists all liabilities of either or both spouses, alone or with any person,
as of the date this action was commenced:
Item
Number
Description
of Liabilitv
Names of all
Creditors Debtors
n'a
Item
Number
n'a
Date Liability
was incurred
Amount of Liability
on date incurred and
Action was commen~
Item
Number
Date Balance
is due
Periodic Payment
and amount
n'a
Sandra L, Gorham, Plaintiff
Income & Expenses (cont'd)
~:
a. Self..,..",.,."..."......"...$ 50.00
b. Household Supplies. , , , . . . , , . , . , . . . $ 25.00
Loans/Notes:
a, (list charge cards) . , , , . , , . . . , . . . . . ,.$ 0,00
Miscellaneous:
a, Entertainment, , . , , , , . . , , . . , . . . , , . ,$ 25,00
b, Barber/Beautician. . . . , . . . . . , . . . , . ,,$ 20.00
Child Care:
a, Court-Ordered Support. , , , . , , . . , , ,. $ N/A
MONTHLY INCOME;
Employer's Name:
Employer's Address:
PA Auto License Brokers
6483 Carlisle Pike, Suite 104
Mechanlcsburg, PA 17055
Employment Income:
Gross. , , , , , , , , , , . , . . . , , , , , , ,. . , , ,$1,200,00 monthly
Net. . . , , , , , . , . , . . , , . , , . . , , , , , . , ,$ 850,00 monthly
Dated: t1~{IP1
~~a-~
Sandra L. Gorham, Plaintiff
JOHN H, BIIOU)OI
tluBIIJlT x. GlUlOY
BROUJOS & GILROY, pc.
AtTORNEYS AT lAW
4 NORlli HANOVER STREET
CARUSLB, PENNSYLVANIA 17013
TllUll'HONI' (717) 243-6574
PAC"'''LI, (717) 243-8227
INrEaNn, br8I1roYP"O'DI,coDl
NoN-TOLL POll HAlwsau"" AR'A
717-766-1690
May 26, t 999
E, Robert Elicker, /I
Office of the Divorce Master
9 North Hanover Street
Carlisle, PA t 7013
Re: Goshorn v Goshorn
Dear Bob:
I received your letter of May 24, t 999. 1 am not representing Mr. Goshorn In this
matter.
Sincerely yours~ /
-~.....
rt X. Gilroy
dch
cc: Marcus McKnight, Esq.
"
.~
... . ..
.. . of
... . ..
MINDY S, GOODMAN
ATTORNEY AT LAW
2010 L1NllLESTOMl ROAD
IIARRISBURO, PA 17110
TELEPIIONE FAX
(717) '40.8742 (717) 540.810
JUN 1 '..-?
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SANDRA L, GORHAM,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97-5945 CIVIL TERM
JAMES G, GORHAM. JR.,
Defendant
: CIVIL ACTION - IN DIVORCE
PRE.TRIAL STATEMENT
AND NOW, comes the Plaintiff, SANDRA L. GORHAM, by and through
her attorney, Mindy S, Goodman, Attorney at Law, and files the following Pre-
Trial Statement as directed by the Divorce Master appointed to hear this matter
on May 15, 1999,
1, LIST OF ASSETS: A list of assets has previously been filed in the
form of an Inventory
and Appraisement filed on March 18, 1999 and is attached hereto as Exhibit A.
2, EXPERT WITNESS: Plaintiff intends to call John R. Verscharen. a
Licensed Real Estate Appraiiler as an expert witness. Mr, Verscharen's address
is 5521 Ridgeview Drive, Harrisburg, PA 17112, Mr, Verscharen has conducted
an appraisal on the marital residence. a copy of which is attached hereto as
Exhibit B, Plaintiff reserves the right to supplement this list of expert witnesses in
a timely manner prior to trial.
3. WITNESSES: At this time, Plaintiff does not intend to call any lay
witnesses other than the Plaintiff herself. Plaintiff reserves the right to
supplement this list of witnesses in a timely manner prior to trial.
SANDRA L, GORHAM,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: No, 97.5945 CIVIL TERM
: CIVIL ACTION LAW
: IN DIVORCE
JAMES G, GORHAM,
Defendant
INVENTORY AND APPRAISEMENT
AND INCOME AND EXPENSE STATEMENT
OF PLAINTIFF. SANDRA L. GORHAM
Plaintiff 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,
Plaintiff verifies that the statements made in this Inventory and Appraisement
are true and correct. Plaintiff understands that false statements herein are made
subject to the penalties of 18 Pa, C.S. Section 4904, relating to unsworn falsification
to authorities.
(~J ~&~?7?
Sandra L. Gorham
n ~o (jl
C' -.:)
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17, Profit sharing plan
18, Pension plans (indicate employee contribution and date plan
vests)
19, Retirement plans, Individual Retirement Accounts
20, Disability payments
21, Litigation claims (matured and unmatured)
22, MilitaryN,A. benefits
23, Education benefits
x
24. Debts due, including loans, mortgages held
25, Household furnishings and personalty (include a total category
and attach itemized list of distribution of such assets is in
dispute)
30. Other
MARITAL PROPERTY
Plaintiff lists all marital property in which either or both spolJses have a legal
or equitable interest individually or with any other person as of the date this action
was commenced:
Item Description Names of Date of
Number of ProDertv all Owners Acauisition
1. $1,000 or Pickup Truck James Gorham 5/86
wedding money used,
2, Dehumidifier - gift by Both parties 6/86
Plaintiffs parents
3, Outdoor Gas Grill - gift Both parties 7/87
by Plaintiffs parents
4, Stack Washer/Dryer Both parties 5/88
5, Canoe Both parties 5/88
6, Aquarium Both parties 7/89
7, Console Television Both parties 6/85
8. Oak Desk Both parties 5/85
9, Oak Drop Leaf Table Both parties 5/86
10, Oak Glass Front Hutch Both parties 5/86
11, Oak Bench Wedding gift 5/86
12. 3 Lawn Mowers Both parties 5/86,6/87,6/89
13. Air Conditioner - gift by Both parties 6/89
Defendant's mother
14, Stove - gift by Plaintiffs Both parties 9/89
parents
Cost or Value Value as of
Item as of Date Date Action Amount of
Number of ACQuisition Commenced any lien
1, $10,000,00 n/a
2. $300,00 n/a
3. $500,00 n/a
4, $500.00 n/a
5. $200.00 n/a
6, $150,00 n/a
7, $1,200.00 n/a
8, $400,00 n/a
9. $200.00 nla
10, $400,00 nla
11. $100,00 nla
12, $100.00 each n/a
13, $400.00 nla
14, $400,00 nla
NON-MARIT AL PROPERTY
Plaintiff lists all property In which a spouse has a legal or equitable Interest
which Is claimed to be excluded from marital property:
Item Description Names of
Number of Prooertv all Owners
1, 1988 Dodge Caravan Sandra Gorham
Cost or Value Value as of
Item as of Date Date Action
Number of Acauisitlon Commenced
1. $2,000,00
Date of
Acauisition
1 0/92
Amount of
anv Lien
n/a
Item
Number
Nature of
anv lien
Effective
Date of
Lien
Holder of
yom
n/a
Item
Number
1,
Basis for Exclusion from Marital prooertv
Purchased after date of separation with
non-marital funds,
~RQPEBrrlRAN~FERRED
Plaintiff lists all property in which either or both spouses had a legal or
equitable interest individually 01 with any other person and which has been
transferred within the preceding three years:
Item
Number
Description
of ProDertv
Names of
all Owners
Date of Date of
Acauisition Transfe(
n'a
Item
Number
Cost or Value
as of Date
of Acauisition
Value as of
Date of
Transfer
Amount of any
Lien as of
Date of Transfer
n/a
Item
Number
Nature of
any Lien
Date of
Lien
Holder of
Lien
n1a
Sandra L. Gorham, Plaintiff
Income & Expenses (cont'd)
E.22SI:
a, Self, , , , , , , , , . , . , , . , . , , . , . , . . , , . . $ 50.00
b, Household Supplies. . . , , . . . . . , . . . . . $ 25,00
Loans/Notes:
a. (list charge cards) . , . , , , . . . . . , . . . , ,.$ 0.00
Miscellaneous:
a. Entertainment, , . , , . . , . , . , , . . , , . , . . $ 25.00
b, Barber/Beautician. , . . , . . . . . . . . , . , ..$ 20.00
Child Care:
a. Court-Ordered Support, . , , , . , . , . , ,,$ N/A
MONTHLY INCOME
Employer's Name:
Employer's Address:
PA Auto License Brokers
6483 Carlisle Pike, Suite 104
Mechanicsburg, PA 17055
Employment Income:
Gross. , . , , , . , , , . . . , . , . , . , , , , , , . . ,$1,200,00 monthly
Net, . , . , , , , . , , , , , . , , , , , , . . , . . , , ,$ 850,00 monthly
Dated: LJ~;({/~
~~a-.~
Sandra L. Gorham, Plaintiff
\i
A Verscharen
Appraisals
Fit No MGIOl
"
APPRAISAL OF
COpy
",~'" ..
SINGLE FAMILY RESIDENCE
LOCATED AT:
760 CONODOGUINET AVENUE
CARLISLE. PA 17013
FOR:
SANDRA L. GORHAM
10 SOUTH HIGH STREET
MECHANICSBURG, PA 17055
AS OF:
AUGUST 13,1998
BY:
iI JOHN R, 'JERSCHAREN
RL,OOI977.I,
5521 RIDGEVIEW ORIVr" HARRISBURG, PA 17112
:t~~i~
"?k~~
P,ba.,tvO.'c"otlon ,,,. Ho.
I "'-"fAd..us 760 CONODOGUINET AVENUS_ C,ty CARLISLE Sf... PA z.,cm. 17013
Lea., 0."""1"" DEED BOOK: 33D PAGE 418 Counrv CUMBERLAND
A....."'. P.,ceI No 29-18-1384.024 Tu YeM 1998 R E r....1 66109 SOlO" "'....menl.1 NONE
~ SANDRAL,GORHAM C",.nlOwn", SANDRA AN-6 JAMES GORHAM Oct:vo.nl: IXI Own", r I Tenenl I I Vacanl
. PrOO.....Mhl..oor.,..... rXl F.. S..ol. I I L....M~ I Prole..t Tvtle I i PUD I I COlldomnftlm (HUDNA onM HOAI NONE iMo
~l>orhood or ProiOd N.me NONE /l.p Ra'",.nce ADC-15-A.7 Census Tria 0119
S.,. Price IN/A 0.1. oLS". NONE t Des(,]"l~ and S lmounl 01 loan chargoslco."eSSlOnllo be Dald by seI8' NOT APPLICABLE
Land",iCtianl SANDRA L GORHAM Add'... 10 SOUTH HIGH STREET MECHANICSBURG PA 17055
Ao",.~.. JOHN R. VERSCHAREN Add'... 5521 RIDGEVIEW DRIVE HARRISBURG PA 1711.
Localion Uban r&. SubUl'ban _ Rural p,.domhlonl Slntl 'omll~ haUlIng PrUlnlland UII % Land Uti chan"
Budl up Ov",m. ~ 25.15\. Und", 15'4 occupanc~ PRI E AGE On. 'alT'11'f 55% ~ NoII,k.1y 0 L,k.1y
l(llXll (".,
Growth ral' Rapid ~ Slable Slow ~ OwnOl 25 Low 5 2-4 f.",,1y In ptoctlS
PrD9arty '.~as lna...ing ~ Slable Oeo1fllllg "x Tenanl 325 H"h 100> I.IJl>forr#y To NOT APPLICABLE
OemanclIsupply Shorl.g. ~ nb.lloral 0.. t.Wt Vaow((h\\I) ,I Pre::lomnanl ,; Cotmi<<c:ial 5%
MarlIetiM lime /'" lXd",l"", J.6mos X Over 6 mos "" V~I_S"1 60 I 45 FARMLN , 40%
Not.: Rae, and Ih, ,oclal compoalllan 0' Ih. n.lghborhood .r. not .ppr.11I1 'acloft.
N.ighborh"'" bound..i.. ond chlllelori.lics ~OUTH OF UNION HALL ROAD NORTH OF ROUTE 641 EAST OF WILLOW GROVE ROAD
: AND WEST OF WAGGONERS GAP ROAp.
. F.Clorllh.I.Necf lI'Ie marketabIlity of Ihe proper Ii,S in the neighborhood (proximily Ie employment ancl amenIties, .mploymenlllibllily, appeal 10 mark.l. ele ):
, THE SUBJECT IS LOCATED IN NORTH MlgDLI::TON TOWNSHIP IN AN AREA COMPOSED OF A VARIETY OF DIFFERENTLY
a
" STYLED HOMES THAT ALSO VARY IN AGE AND QUALITY THE HOMES IMMEDIA TEL Y SURROUNDING THE SUBJECT ARE
MOSTLY SINGLE FAMILY DETACHED STYLE HOMES WITH SOME SCATTERED AVERAGE TO FAIR QUALITY
MANUFACTURED HOMES SITUATED ALONG THE BANKS OF THE CONODOGUINET CREEK. THERE IS SOME
SURROUNDING FARMLAND AND SOME COMMERCIAL ESTABLISHMENTS SITUATED PRIMARILY ALONG ROUTE 641,
Mark.t condilions in the subject neighborhood (including support for Ihe above conclusions ralalld 10 the t1end ot properly values. demand/supply. and m.rkehng time
o. luch.. d.ll on camp,Wive properUu 'or ul. tn Ihe neighborhood, description of the prevalencl of ules and financing concllsions. tiC,):
PROPERTY VALUES HAVE BEEN FAIRLY STABLE, CONVENTIONAL, VA, AND FHA FINANCING ARE READILY AVAILABLE TO
QUALIFIED BORROWERS, TYPICAL CONVENTIONAL RESIDENTIAL INTEREST RATES ARE AROUND 6,5 TO 9 PERCENT
DEPENDING ON THE LOAN TYPE TERM, AND/OR DISCOUNT POINTS PAID, IN SALES TRANSACTIONS IT IS COMMON TO
FIND THE SELLER CONTRIBUTING SOME FUNDS TOWARDS THE BUYERS CLOSING COSTS IN THIS AREA. SUPPLY AND
DEMAND ARE NEARLY BALANCED AND THIS AREA HAS DEMONSTRATED AVERAGE MARKETABILITY,
. ProJ.ellnformaUon 'or PUO. (ll.ppllcable). .Is Ii'll dey,roper/builder in conlrol of the Home Own.,,' Assocl.tlon (HOA)? U YES U NO
ApproIimll.lotal n\JfOOer of unils in 11'1. subject projecl 0 ApP'oxlmata tolal number of units for Jlle in Ii'll subject project 0
Oelaibt common elements.nel recreational 'acilitiu' NOT APPLICABLE
Oimtn.iona 60 X 175 Topog'.phy GENTLY SLOPING
Sil..,.. ,32 ACRES Com.. Lol 0 v.. [AI No Size AVERAGE FOR AREA
Sp.cific zoning clminellion .n~:iPllon C - CONSERVA TION ZONE/SEE ADDENDUM Shop. RECTANGULAR
Zoning COll'jli.nce 00 Lag.1 Log~ f1OI1alI1bmng (Qendf.lha'oo u..) [J m.gal U No 'OIling Orainape APPEARS ADEQUATE
I HiDh..1 & b..l u.. aslmoro,",d: X Pr...nl u.. . n Olh", u.. /.xcl.inl NOT APPLICABLE View AVERAGE/CREEK
UlllIUn Pu~Uc OlhOl Off.,"o Improv.m.nt, Typo P~jC Privafa Urdscaping LAWN/SHRUBS,TREE~_
EI.ctricity X Str..1 PAVED ASPHAI,T X Driveway SlXface NONE
G.. NONE CLlb/gullOl NONE App"'.nl....men.. TYPICAL UTILITIES
W.I", WElL WATER Sidewalk NONE FEMA Sp.ci.1 Flood H.m N.. ll!.J_ v.. ,I,J No
S.nlllll'/ .."'" I- SEPTIC SYSTEM Str.ollight, YES X FEMAZon. ZONE A9&C M.pDol.04101/82
Storm sewet NONE All.' NONE FEMAM.nNo, 4203670010 B
Comment. (apparent.dyer.. easements, enaolchmenl., special assalsments, slide area., Illegal or legal nonconfOlming zoning. use, et':.): THERE ARE NO
APPARENT ADVERSE EASEMENTS. ON SITE PRIVATE WATER AND SEWAGE SYSTEMS ARE COMMON TO THE AREA, A
PORTION OF THE SITE IS SITUATED IN FLOOD ZONE A9, SEE ADDENDUM,
GENERAL DESCRIPTION EXTERIOR DESCRIPTION FOUNDATION BASEMENT INSULATION
No, of Unil. ONE Foundation STONE Slab NONE N.. Sq.FI, 210 Roof UNK ,....
No, of Slori., 1,5 Extera WailS FRAME 0aY0ISpa::e YES PARTIAL % Finished 0 C.iIing UNK ~
I-
Typ. (lltIJAtt) OETACHEO Roof SOOac. METAL Bmmonl PARTIAL Ceiling EXPS-JOISl W.ns UNK ~
o..~n (Styl.) CAPECOD GuIlOl' & o....plS, SOME ALUM SlJrrpf'un1>NO WolI, STN/CONC Floor YES
ExislingJl'rooo'O<I EXISTING \\1ndow Typ. DBL.HUNG Oampn... YES Floor CONCRETE Non. N/A
AgaIY",) 59 (ESn Storm/Saeens STORM/SOME S.IlI.ment NONE NOTED Ou"-'l. Enly YES ......
Eff.cl". An. V",) 17 Manufactured House NO Inf.'lol~n NONE NOTED TYPICAL
. ROOMS FovOl Livinn Oininn Kitchen Don FomilvRm, Rec.Rm Bedrooms 1B01h. L.undN Olh", N..SaFI.
, B.1samonl AREA 210
Llvelt 1 1 1 2 1 1335
. l.vel2 1 1 434
.
Finished area.bov. Dr8de cont8ins: 6 Rooms' 3 BO<I,oom ,I' 2 B.lhI.l: 1 769 Snuar. Fut 01 o..oaslMno Ar..
, INTERIOR MaterlalsJCondition HEATING KITCHEN EQUIP:- ATTIC AMENITIES CAR STORAGE:
Floor. WDNlNYLlFAIR Typ. HWBB R.~igOlolor ~ Non. 'X F..pf.ce(.) ,~ :& Non. 00
DRYWUAVG/FAIR ~
. Wans Fu.1 OIL R.ng.Kl,on ~ Slail - P.11o NONE Gw.g. , of cars
TrinVFlII~h WOOD/AVG CoOO,fionA VG Di'oo..1 i- Drop 51.. O.ck REAR X AII.cIlad NONE
-
B.fh Floor TILE/AVG COOLING Dishwasher i- Sculll. Porch ENCLOSED X lltl.cIlad NONE
B.lhW.in.Cllt FIBG&TUB/AVG Cantrol NONE F.nJHood -
- Floor - F.nce NONE l- Bu~I"n NONE
Doors WOOD/AVG Olh", NONE Miaowave - Healed - Pool NONE I- Carport NONE
CoOOilionNONE WashOl'Jl":wver Finished NONE DrlvewlY NONE
Addition.I'..I....' (.p.ci.l.n.'gy .ffici.nl ilom., .Ic.) STANDARD' STORM WINDOWS AND DOORS, THERE IS ALSO A FIREPLACE IN
THE LIVING ROOM,
Condition 0' the improvements. 6eprecialion (physical. functional, 8nd exlernal). repairs needed, quality 0' construction, remodeling/additions. etc.: PHYSICAL
DEPRECIATION IS ESTlWATED TO BE 31%, THERE ARE NO APPARENT FUNCTIONAL OR EXTERNAL OBSOLESCENCES,
THE SUBJECT PROPERTY IS GENERALLY IN AVERAGE TO FAIR CONDITION THERE ARE NUMEROUS SMALL REPAIRS
. NEEDED AS WELL AS DEFERRED MAINTENANCE ITEMS, SEE ATTACHED T~D PHOTO ADDENDUMS,
Advt,.t envIron menial condilionl (Iuch U. bul nolllmiled to, h.urdoul Willies, loxic lubsl.nclI. elc,) prlllnl in Ihe lmprov.menll, on the IiI.. or in thl
Imm.di.l. ,icinily of Ih. ,ub,.ct poop."y, SEE ATTACHED TEXT ADDENDUM .'ND STATEMENT OF l[MITING CONDITIONS.
ff....iMcf..llIra.."
SUMMARY I<PPRA,SAL REPORT
UNIFORM RESIDENTIAL APPRAISAL REPORT
MG101
PAGE 1 OF 2
T....h......"'........"'...A(IO'_......Il....-......'P....ilUlllU-",1
'.........~IOO4..U
V,'u,lIon '.ctlon
SUMMARY APPRAISAL REPORT
UNIFORM RESIDENTIAL APPRAISAL REPORT
FIl. No MG10"
ESTlMllfED SITE VAlLE , I NOT APPLlC~8~ Comm.nts on COSl ApprOlcn (aucn U. aaurc. of 0051 ullm,t..
ESTiMATED REPROOlJClILlN CDSTNE'N DF IMP'<DVEMENTS sll. valu., SQulr. foot ~lcul.tion Illd for HUO, VA and FmHA, lh,
llMIrog 1.769 Sq FI. GlI ' S .stim,t,d remAinIng .conomlc Ii', of the prop<<ty);
BSMT 210 Sq,FI. 01 , THE COST APPROACH AS NOT BEEN DEVELOPED O'JE
FIP DECK PORCH' , TO THE AGE OF THE SUBJECT, SEE ATTACHED TEXT
, -
~ _Sq,Ft. GIS , ADDENDUM,
TOllt Estimaled Co.t Nt. = I t
. :-';5 PIIY1'COl I Funct"".1 I ExlOl'naJ
, I
OtpllOlllld V'lul ot Improvlmeflts , I
......... Valu' or 511' Impro'l,m.nl' , S
INDICATED VALUE BY COST APPROACH , I NOT APPLlCA8lE
IIEM I SUBJECT COMPARABLE NO I COMPARABLE NO 2 COMPARA8lE NO J
760 CONODOGUINET AVENUE 371 CORNMAN ROAD 1 CHANNEL DRIVE 5.011 CONODOGUINET AVE
Mdt... CARLISLE PA CARLISLE PA CARLISLE, PA CARL,ISLE PA
Prollifr'lll'Y to Sublect 275 MILES 2,75 MILES 2 BLOCKS
Salel Pnce I NIA I 65 900 , I 73 500 , I 79 900
Pnc::etQoss LN. NY I (Il S 37,27 III I 57,11 rLl ....-...,. , I 53,99 (Il " ~.;
0'11 andla PUBLIC RCRDS MULTIPLE LISTING SERVICE MULTIPLE LISTING SERVICE MULTIPLE LISTING SERVICE
VenbllOl'l Solrces INSPECTION PUBLIC RECORDS PUBLIC RECORDS PUBLIC RECORDS
VAlLE ,lfi,U;ThENTS DESCRIPTION DESCRIPTION 1.",....- DESCRIPTION 1.",,_ OESCRIPTlON I. .1&.010"-
SIIeI a F'fllndng FHA FINANCING: VA FINANCING FHA FINANCING:
Concessions , , NONE : NONE NONE :
0111 of S.leITimt NONE', ' , 03/10/96 : 04/09/96 : 07/13/96
locatiOn SUBURBAN SUBURBAN SUBURBAN SUBUROAN
1-.0_ FEE SIMPLE FEE SIMPLE : FEE SIMPLE : FEE SIMPLE :
Sill ,32 ACRES 1 ACRE : .1700 ,29 ACRES : ,09 ACRES : 600
\/low AVERAGE AVERAGE AVERAGE AVERAGE
o.."n and Ano.~ CAPE COD CAPE COD : CAPE COD : 2 STORY :
~<lCawt\.dkn AVERAGE EQUAL : EQUAL : EQUAL :
... 59 YRS, (EST) 68 YRS 51 YEARS 60 YRS IESn
Condition FAIR FAIRIEQUAL AVG/SUPERIOFl : -5500 AVGISUPERIOR : -10500
AboVI Glade 1C1l1l'14"" , .... T~"cf1M' .... : r~'8ctM.: .... : r...:........: .....
, ,
Room Count I 8: 3: 2,00 7: 4: 1,00' 1,000 8: 4: 1,00' 1,000 6: 3: 2,00'
GlOst I MM Arel 1 769 So FI 1 768 So Fl : 1 267 So FI. : 2900 1 460 So,Fl 1700
._I&.rOJ/'od 210 SQ,FT, EQUAL EQUAL EQUAL ,
,
RoomJ Btlow GIld. UNFINISHED UNFINISHED UNFINISHED UNFINISHED
" Function" Ut~tv AVERAGE AVERAGE AVERAGE AVERAGE :
I:liI Ho.' OILHWINONE OILFNNONE : OI~FNNONE : ELBBINONE :
r-tn- STANDARD EQUAL EQUAL EQUAL
OnotICaroa1 NONE le.DETAcHeo : -2500 lC,-DETACHED : ,2500 NONE :
, Pach, Ptli>, Oodl, ENCPORiDECK PORCHES PORCHIE,POR PORCHISUNRM :
...olA"",,\ tie. 1 000 1 000 COAL.STOVE ,
FIREPLACE NONE NONE , ,
Fonce Pool .Ie. NONE NONE : NONE : NONE :
OTHER NONE NONE : NONE : NONE :
Not Adl '101.11 i I. IXI. " 2200 ! I ,. IXI. 'I 3100 I I. lXI, : S ' 8200
1<IjuJlodSaitJPt'ao " On,.., 9.4 % Gnl..: 17,6%. GnlQ; 16.0% ..
01 eon....blo Ntt: -3,3% I 63 700 Ntl: -'\,2%' S 70 400 Not: .10,3'''" I 71700
Comments on Sar.. Comparison (including th, subject properly', compatibility 10 the neighborhood. ItC. ): SEE ATTACHED TEXT ADDENDUM,
ITEM SU8JECT COMPARA8LE NO, 1 COMPARABLE NO, 2 COMPARABLE NO, J
Ollt, Prico and 0.1. NONE THE PROPERTY HAS ONLY THE PROPERTY HAS ONLY THE PROPERTY HAS ONL Y
SWaI ra p'a..... NONE SOLD ONCE WITHIN SOLD ONCE WITHIN SOLD ONCE WITHIN
"""'-<1_ NONE THE PAST YEAR THE PAST YEAR THE PAST YEAR
Ana~ 01 any QJn".nllgreement 0' sale. option. a fisling oflhe subject property and Inalysi.of l'1y~sa.fesotsubjed and~...bIes 'Mthi'lOl'llyuotlhedateolapp;lisal:
THE APPRAISER WAS NOT MADE AWARE OF ANY SALES AGREEMENTS PERTAINING TO THE SUBJECT, IT IS ASSUMED
THAT THE PROP"RTY IS NOT CURRENTLY UNDER AGREEMENT TO BE SOLD,
INDICATED VALUE BY SALES COMPARISON APPROACH, '" .... ... , , , , , , , , ,S 68 000
. INDICATED VALUE BV INCOME APPROACH III An.....bIt' Estimlltd 'M~;t; R~~"I ' 1.,0" . Qos, Rtnll.Ulllor 'I "NO'~
~ Ippraisal is made ~ _ .IS is. . ~. subject to lherepan. afteral.cl1s. ~a ccnMo-lS ~led bKlw g _ subject to ~b1 per p&n Ind speabtCns.
ConditionJ<I~ THIS APPRAISAL IS TO BE CONSIDERED NULL AND VOID UNLESS ACCOMPANIED BY ALL OF THE FORMS
AND ADDENDA INCLUDED WITH THE ORIGINAL REPORT PROVIDED TO THE CLIENT BY THIS APPRAISER,
.",1 Rt"",oli.llion THE DIRECT SALES COMPARISON APPROACH IS CONSIDERED TO PROVIDE THE TYPICAL ACTIONS OF
BUYERS AND SELLERS IN THE MARKETPLACE AND HAS BEEN UTILIZED IN THE DETERMINING THE FINAL ESTIMATE OF
. VALUE,
The p4.I'pOse of this Ippraisll is 10 e,limate tho mar~l!It value of the real property thai is the subject 0' this report bued on th, QboVI condlllonS and IN artll'ab:ln, CXln~t
and Ilrn~ oondilions, and markf'll vlIue delinlll()/llhill are slaled In the artadied Freddie Mac Fcrm 439;faMfI Mae Fcrm l0048(Revis.ed 6/93 )
I (WE] ESTIMATE TliE MARKET VALUE AS DEFINED, OF THE REAL PROPERTY !HAilS THE SUBJECT OF THIS REPORT, AS OF AUGUST 13 1998
. (WHICH IS,~; ~SPECTlO ~NDTHE EFFECTIVE DATE OF THIS REPORT) TO BE I 66,000 ,
APPRAISER: .I.~I )0../ SUPERVISORY APPRAISER IONlY IF REQUIRED):
Sian.".. J Soon."'. OOwl OOwl Not
NIllllI JOHN R. VERSCHAREN Nlmo IMptd I'rol>trty
0". R.pon Sogntd NOVEMBER 06, 1998 , Dale R,cut Sianed
51.1. C""""'I"". RL-001977-L Sf.I.PA Slall CerMahon . SI't.
0- Stile License . Slale Or Slll.lans" . 511"
'"*"...,_" '-lJ " l'~ PAGE 2 OF 2 ,- ....,
f""'...._.._......."'I~~_"....I.,,:u.,l'
.... *..0
VERSCH/,REN APPRAISALS
ADDENDUM
'III No, 1.10101
THE METROPOLITAN STATISTICAL AREA LOCATION NUMBER IS 3240,
PLEASE NOTE THAT THIS TEXT AOOENDL'M IS AN INTEGRAL PART OF THE ENTIRE APPRAISAL REPORT
AND MUST BE INCLUDED WITH WE MAIN FORM PAOE{S) IN ORDER FOR THIS REPORT TO PROPERLY
COMPLY WITH USPAP STANOARbs, THIS APPRAISAL RF.PORT IS TO BE CONSIDERED NULL-AND-VOIO
UNLESS ACCOMPANIED BY ALL OF THE FORMS AND ADDENDA ORIGINALLY PROVIDED TO THE CLIENT
BY THIS APPRAISER.
SUBJECT PROPERTY
THE SUBJECT IS A WOOD FRAME COVERED CAPE COO STYLE HOME WITH AN ENCLOSED SIDE PORCH
AND A REAR DECK, THE INTERIOR OF THE HOME FEATURES A KITCHEN, DINING ROOM, LIVING ROOM
WITH A FIR.:PLACE, TWO BEDROOMS AND A BATHROOM ON THE FIRST FLOOR, THE SECOND FLOOR
HAS AN ADDITIONAL BEDROOM AND ANOTHER FULL BATHROOM, THERE IS A SMALL PARTIAL
UNFINISHED BASEMENT AREA,
ZONING CLASSIFlCATION AND DESCRIPTION
THE SUBJECT IS SITUATED IN AN AREA THAT IS ZONED "CONSERVATION ZONE", THIS ZONE SEEKS TO
PROTECT LARGE CONCENTRATIONS OF ENVIRONMENTALLY SENSITIVE FEATURES THAT ALSO HAVE
SIGNIFICANT VALUE FOR PASSIVE AND ACTIVE RECREATIONAL PURSUITS, SPECIFICALLY, FORESTED
AREAS, STEEP SLOPES, STREAM AND CREEK VALUES, WETLANDS AND FLOOD PLAINS ARE INCLUDED,
HOWEVER, THERE ARE A VARIETY OF OTHER PERMITTED USES AS DESCRIBED IN SECTION 200,2 OF
THE NORTH MIDDLETON TOWNSHIP ZONING REGULATIONS INCLUDING BUT NOT LIMITED TO SINGLE
FAMILY DETACHED DWELlINGS, AGRICULTURAL USES, FAMILY OAYCARE FACILITIES, SOME LIMITED
COMMERCIAL USES AND A VARIETY OF OTHER :.JSES,
SITE COMMENTS
THE LOWER PORTION OF THE SUBJECT PROPERTY IS SITUATED IN FLOOD ZONE A9 (SEE ATTACHED
COpy OF THE FEMA FLOOD MAP), ZONE A9 IS DEFINED AS "AREAS OF 100-YEAR FLOOD; BASE FLOOD
ELEVATIONS AND FLOOD HAZARD FACTORS DETERMINED",
WHILE VIEWING THE EXTERIOR OF THE SUBJECT, MR. GORHAM INDICATED THAT THE LOWER SECTION
OF THE REAR DECK ACTUALLY EXTENDS OVER THE REAR PROPERTY LINE ONTO THE NEIGHBORING
PROPERTY, THIS INFORMATION COULD NOT BE VERIFIED OR SUBSTANTIATED BY THIS APPRAISER
SINCE A SURVEY WOULD HAVE TO BE PERFORMED IN ORDER TO DETERMINE THE EXACT POSITION OF
THE HOME AND DECK IN RELATION TO THE REAR PROPERTY LINE, IF THIS REAR LOWER SECTION OF
THE DECK ACTUALLY DOES EXTEND OVER THE PROPERTY LINE, IT IS EXPECTED THAT THIS SITUATION
WOULD NOT HAVE A SIGNIFICANT MEASURABLE AFFECT ON THE OVERALL MARKETABILITY OF THE
SUBJECT SINCE THIS DECK COULD EASILY BE REMOVED TO COMPLY WITH THE SUBJECT'S PROPERTY
BOUNDARIES, SEE ADDITIONAL PHOTO 116 FOR A VIEW OF THIS LOWER DECK SECTION, THERE ARE
NO OTHER APPARENT ADVERSE EASEMENTS OR ENCROACHMENTS AFFECTING THE SUBJECT
PROPERTY,
THE FACT THAT THE SUBJECT IS SITUATED IN A FLOOD HAZARD AREA TYPICALLY WILL NOT HAVE A
SIGNIFICANT MEASURABLE AFFECT ON THE OVERALL MARKETABILITY OF SUCH PROPERTIES, I HAVE
PERSONALLY STUDIED THIS SITUATION IN THE MARKETPLACE AND IT APPEARS AS THOUGH THE
POSSIBILITY OF FLOODING IS OFTEN COMPENSATED BY THE RECREATIONAL AND/OR OTHER POSSIBLE
BENEFITS OF HAVING THE CRF.EK NEARBY,
CONDITION OF IMPROVEMENTS
DURING THE INSPECTION OF THE SUBJECT PROPERTY, THERE WERE SEVERAL DEFERRED
MAINTENANCE ITEMS AND SEVERAL NECESSARY MINOR REPAIRS, THE VINYL KITCHEN FLOOR HAS
SEVERAL DAMAGED SECTIONS (SEE ADDITIONAL PHOTO 111), THE FIRST FLOOR BATHROOM SINK IS
MISSING (SEE ADDITIONAL PHOTO 112), THE DRYWALL AROUND THE SHOWER HEAD IN THE FIRST
FLOOR BATHROOM IS DAMAGED (SEE ADDITIONAL PHOTO #3), THERE IS A HOLE IN THE WALL OF THE
FIRST FLOOR FRONT BEDROOM (SEE ADDITIONAL PHOTO #4),
AT THE TIME OF THE INSPECTION, MR, GORHAM INDICATED THAT THE METAL ROOF HAS SOME MINOR
LEAKS, THE CEILING SURFACE HAS SEVERAL AREAS OF DISCOLORATION AND/OR WATER MARKS
WHICH APPEARS TO CONFIRM MR. GORHAM'S STATEMENT, IN VIEWING THE ROOF FROM THE
GROUND, THERE DOES NOT APPEAR TO BE ANY SIGNIFICANT SECTIONS OF DETERIORATION OR
DAMAGE WHICH WOULD LEAD THIS APPRAISER TO BELIEVE THAT ONLY MINOR REPAIRS ARE
NECESSARY, SUCH AS CAULKING A SEAM, HOWEVER, IF WATER IS CONTINUED TO BE ALLOWED
ENTRY INTO THE HOME, SUBSTANTIAL DAMAGE AND DETERIORATION COULD OCCUR OVER A PERIOD
OF TIME, IT WAS IMPOSSIBLE TO VIEW THE ACTUAL WOOD ROOF DECKING MATERIAL TO ASCERTAIN
THE EXTENT OF ANY EXISTING DETERIORATION; HOWEVER, JUDGING FROM THE MINIMAL DAMAGE TO
THE CEILING TILES, I WOULD ESTIMATE THAT NO SERIOUS DAMAGE HAS OCCURRED THAT WOULD
AFFECT THE STRUCTURAL INTEGRITY OF THE ROOF'S SURFACE, SEE ADDITIONAL PHOTO 115 AND 116,
THE CURRENT CONDITION OF THE SUBJECT IS EXPECTED TO HAVE SOME AFFECT ON THE
MARKETABILITY OF THIS PROPERTY IF IT WERE CURRENTLY PLACED ON THE MARKET TO BE SOLO,
THIS CONDITION DIFFERENCE IS ADJUSTED FOR IN THE SALES COMPARISON GRID IN ORDER TO
COMPENSATE FOR THE ESTIMATED MARKET REACTION TO THIS SITUATION, PLEAS!': NOTE THAT
THESE ADJUSTMENTS ARE NOT BASED ON ANY "COST-TO-CURE" FIGURES BUT ARE BASED ON THE
ADDENDUM
fll. No, MG10l
ESTIMATED MARKET REACTION THAT THESE NECESSARY REPAIRS AND MAINTENANCE ITEMS WILL
HAVE ON THE MARKETABILITY OF THE SUBJECT PROPERTY,
IN ADDITION, PLEASE NOTE TH.A,;r THIS APPRAISER IS NOT A BUILDER, PROFESSIONAL HOME
INSPECTOR, CONSTRUCTION E!lPERT OR STRUCTURAL ENGINEER AND THERE MAY BE OTHER
PHYSICAL DEFICIENCIES OR NECESSARY NEEDED REPAIRS THAT WERE NOT READILY IDENTIFIABLE
DUE TO THE LIMITATIONS OF STANDARD APPRAISER WALK-THROUGH TECHNIQUES.
ADVERSE ENVIRONMENTAL CONDITIONS
THERE ARE NO KNOWN ADVERSE ENVIRONMENTAL CONDITIONS AFFECTING THE SUBJECT PROPERTY
THAT THE APPRAISER COULD OBSERVE USING NORMAL INSPECTION TECHNIQUES,
THE APPRAISER IS NOT QUALIFIED TO DETECT THE PRESENCE OF RADON GAS IN THE SUBJECT
PROPERTY, SHOULD RADON GAS CONTAMINATION BE A CONCERN, A QUALIFIED PROFESSIONAL
SHOULD BE CONSULTED,
THE APPRAISER IS UNABLE TO VERIFY THE INSULATION "R" FACTOR. THE PRESENCE OF
UREA-FORMALDEHYDE FOAM INSULATION COULD NOT BE DETERMINED, IF UFFIIS PRESENT, THE
APPRAISED MARKET VALUE MAY BE ADVERSELY AFFECTED OR VOIDED, ANY INFORMATION ABOUT
INSULATION STATED ON THE APPRAISAL WAS PROVIDED BY INSPECTION, OWNER OR AGENT, AND IS
ASSUMED TO BE ACCURATE,
COST APPROACH COMMENTS
THE SUBJECT IS AN OLDER PROPERTY AND THE COST APPROACH HAS NOT BEEN DEVELOPED DUE TO
THE UNRELlABILlTY AND DIFFICULTY IN ACCURATELY ESTIMATING THE ACCRUED DEPRECIATION IN
HOMES OF THIS AGE, THERE IS A GENERAL CONSENSUS AMONG REAL E':STATE APPRAISERS AND
PROFESSIONAL APPRAISAL ORGANIZATIONS THAT THE COST APPROACH METHOD OF VALUATION IS
RENDERED INEFFECTIVE WHEN ATTEMPTING TO VALUE HOMES OF THIS AGE, IT IS THEREFORE
CONSIDERED PRUDENT FOR THE APPRAISER NOT TO INCLUDE THE COST APPROACH IN THE REPORT
INSOFAR AS IT MAY ACTUALLY BE MISLEADING TO THE CLIENT, THIS IS IN COMPLIANCE WITH THE
UNIFORM STANDARDS OF PROFESSIONAL APPRAISAL PRACTICE DEPARTURE PROVISIONS,
COMMENTS ON SALES COMPARISON
EVERY EFFORT WAS MADE TO FIND THE MOST SIMILAR COMPARABLE PROPERTIES FROM THE
SUBJECTS GENERAL MARKETING AREA, SUBSEQUENTLY, IT WAS NECESSARY TO USE SALES THAT
ARE MORE LOCATED FARTHER THAN ONE MILE FROM THE SUBJECT, THIS IS DUE TO THERE NOT
BEING ANY MORE RECENT OR CLOSER SALES, WITH SIMILAR CHARACTERISTICS, THAT HAVE SOLD
WITHIN THIS GENERAL AREA THAT BETTER REFLECT THE CURRENT MARKETABILITY OF THE SUBJECT,
ALL OF THE COMPARABLES HAVE SETTLED WITHIN SIX MONTHS OF THE EFFECTIVE DATE OF THE
APPRAISAL, THESE SALES ARE SITUATED IN THE SAME GENERAL MARKETING AREA AS THE SUBJECT,
AND ARE CONSIDERED TO THE BEST POSSIBLE COMPARABLE SALES AVAILABLE, PROPERTY VALUES
HAVE BEEN STABLE AND NO ADJUSTMENTS WERE NECESSARY FOR TIME OF SALE,
THE COMPARABLES PRESENTED HAVE BEEN RATED IN TERMS OF THEIR INHERENT SIMILARITIES TO
THE SUBJECT AND THEN CORRELATED INTO A FINAL ESTIMATE UTILIZING THE APPROPRIATE
APPROACH(ES), THE ROUNDED RATES OF $ 6,00 AND $ 2,500,00 WERE APPLIED FOR THE SQUARE
FOOTAGE AND LOT SIZE DIFFERENCES RESPECTIVELY, THE FIRST LINE OF THE ROOM SECTION IN THE
ADJUSTMENT GRID IS FOR THE BATHROOM DIFFERENCE AND THE SECOND LINE IS FOR THE ROOM
AND SQUARE FOOTAGE DIFFERENCE, IF NECESSARY,
COMPARABLE ONE IS A 1,5 STORY HOME SITUATED JUST TO THE NORTHEAST OF THE SUBJECT AND AT
THE TIME OF SALE WAS IN VERY SIMILAR CONDITION TO THE SUBJECT, THE GROSS LIVING AREA OF
THIS SALE IS ALMOST IDENTICAl. TO THE SUBJECTS, OTHER MINOR ADJUSTMENTS WERE ALSO
NECESSARY FOR COMMON TYPICAL DIFFERENCES,
COMPARABLE TWO IS A 1,5 STORY STYLE HOME LOCATED JUST OT THE EAST OF THE SUBJECT AND IS
ALSO LOCATED ALONG THE BANKS OF THE CONODOGUINET CREEK, AFTER VIEWING THIS SALE AND
ANALYZING INFORMATION PROVIDED BY THE LISTING AGENT, THIS SALE IS CONSIDERED TO BE
SLIGHTLY SUPERIOR IN TERMS OF CONDITION AND REQUIReD THE APPROPRIATE COMPENSATING
NEGATIVE ADJUSTMENT, OTHER TYPICAL COMMON ADJUSTMENTS WERE ALSO NECESSARY,
COMPARABLE THREE IS A TRADITIONAL TWO STORY STYLE HOME LOCATED ON THE SAME STREET AS
THE SUBJECT, THIS HOME HAS BEEN WELL MAINTAINED AND HAS HAD SOME RECENT REPAIRS AND
COSMETIC REDECORATING; SUBSEQUENTLY, THIS SALE IS ALSO CONSIDERED TO BE SUPERIOR IN
TERMS OF CONDITION AND REQUIRED THE APPROPRIATE COMPENSATING NEGATIVE ADJUSTMENT.
THIS SALE WAS UTILIZED DUE TO ITS CLOSE PROXIMITY TO THE SUBJECT AND IS CONSIDERED TO
ADEQUATELY REPRESENT THE MARKETABILITY OF HOMES WITHIN THIS IMMEDIATE MARKETING AREA.
OVERALL, MOST WEIGHT HAS BEEN GIVEN TO THE MEDIAN VALUE OF THE THREE ADJUSTED
COMPARABLE SALES IN DEVELOPING THE DIRECT SALES COMPARISON ESTIMATE,
IN THE VALUATION OF THE PROPERTY, ONLY ITEMS ATTACHED TO THE REALTY WERE CQNSIOERED,
ITEMS SUCH AS REFRIGERATORS, WASHERS, DRYERS, FURNITURE, OR OTHER CHATTe~ ITEMS WERE
NOT CONSIDERED IN THE VALUATION,
FLOORPLAN
Bolrowehcr..nt. SANDRA L. GORHAM
PrOlltl'lY Address: 760 CONODOGUINET AVENUE
, ARlISLE
File No,: MG10l
Case No,:
Slate: PA
l'
REAR DeCK
18,00'
51
1400' ,..: 10.00'
LIVING li ~
~ ...
c g
w tli
~ BR
51 51
::i BR z
w tli
BR
7,50
g
aD
o
8,00'
"
SkIId1l1V Apu ro/_"
AREA CALCULATIONS SUMMARY
Name 01 ArM Sin TolO"
PIU' rLOOR 1335.0000 1335.0000
..COND n.ooR U". 0000 UC. 0000
DfCLOI&O roacH "'3.0000 1n.0000
".-.nt 210.0000 210.0000
AIM
_1
0LA2
fl.
....
LIVING AREA BREAKDOWN
B'alkdown l.blolOla
rlAl'f FLOOA
..00. '.00
u.oo . 41.00
14.00 . 31.50
3.50 . . '.00
llCOND I'LOOR
1.00. 1.00
10.00 . 31.50
j
,
i
TOTAL LIVABLE (rounded)
,
,
!
i
,
!
~
1769 I 6 Areas Total (rounded)
;"oo...._.J-,....:..a.. 4- .\1:;............
.... "-U.'p
.....,~.u.. .'.~_"_"'"', :.H."" ....' ....",..,.. -,..._...
1769
5521 RIDGEVIEW DRIVE, HARRISBURG, PA 17112
21 : 1701
U,ODDD
131,0000
531.0000
21 ,0000
U.ooou
315.0000
........ Verscharen
...........
SUBJECT PROPE~TY PHOTO ADDENDUM
~lCllent SANDRA L GORHAM File No,: MG101
ProoertY ~drel1: 760 CONODOGUINET AVENUE Case No.:
. , ,CARLiSlE State: PA Zi : 17013
FRONT VIEW OF
SUBJECT PROPERTY
Appraised Date: AUGUST 13, 1 GG8
. .-1. ,_, _ ~,. .:.~~ .
;;" .".:\.~,/;;:).:>:."
...", .4." ,-. ,-
~..,.(._;.t:'I.;'...;,l-.:iN:"',".' .
.i'l~""'.'.h..' .
REAR VIEW OF
SUBJECT PROPERTY
STREET SCENE
...... Verscharen
.......""
.
AoomONAL,8UBJECT PHOTOS
0\lItI't'lt1ltn1: SANDRA L, GORHAM
Addr...: 760 CONODOOUINET AVENUE
: AR ISLE
File No,: M010l
Case No.:
Slale: PA ZiD: 17013
~
II!Iiir
l '
--
....4.
ADDITIONAL PHOTO'I
PHOTO OF KITCHEN FLOOR SURFACE.
ADDITIONAL PHOTO 112
PHOTO OF FIRST FLOOR BATHROOM
WITH MISSING SINK,
ADDITIONAL PHOTO '3
PHOTO OF DAMAGED BATHROOM
WALL.
..... Verscharen
Appn.ula
COMPARABLE PROPERTY PHOTO ADDENDUM
t: ANORA L. GORHAM File No.: MG10l
'7 CON 0 G INET AVENUE Cese No,:
Slele: PA
,;, \,.....:
~,-". .
-;j." "
:".-' '.....
..,.
.
.
Zi : 17013
COMPARABLE SALE 111
371 CORNMAN ROAD
CARLISLE. PA
Sale Dela: 03110198
Sale Price: $ 85,900
COMPARABLE SALE #2
1 CHANNEL DRIVE
CARLISLE, PA
Sale Dale: 04109/98
Sale Price: $ 73,500
COMPARABLE SALE 113
541 CONOOOGUINET AVE
CARLISLE, PA
Sale Dale: 07/13/98
Sale Price: $ 79,900
A Verscharen
..........
, '
LOCATION MAP
Borrower/Client: SANDRA L GORHAM
Properly Address: 760 CONODOGUINET AVE,.,UE
i : ARLlSLE
File No,: MG10l
Case No.:
II: PA
ZI : 17 1~
of
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A. Verscharen
--
5521 RIDGEVIEW DRIVE. HARRISBURG, PA 17112
. '
LEGAL DESCRIPTION
. '
,Bolrow'll'lClienl: SANDRA L. GORHAM
Prooerty Address: 760 CONODOGUINET AVENUE
City: CARLISLE
File No,: MG10l
Case No.:
Slale: PA lio: 17013
"
TRIS
DaaD
IWlB 'l'HII I f I:.. dar ot '3"c.~ ""II"YO
year Nineteen hundred and e ghty-eight It911)
BBTWEEK DAVID M. BAYER and NINA BAYER, hie wite, ot
the Borough ct Carli.le, Cumberland County, ,
Pennlylvanh,
, in the
Oranton
and
JAM!! G.. GORHAM and SANDRA L. GORHAM, h1awi~.,
ot North Middleton Town.hip, Cumberland County,
pennSYlvania,
Grantee.
wtTNESSBTR, that in con.ideration at THIRTY-SEVEN THOUSAND,and
00/100 1$37,000) Dollar., in hand paid, the receipt whereot i.
hereby acknowledged, the laid Grantor. do hereby grant and
convey to the laid Grantee., their heirs and assign.,
Att that certain tract ot land situate in North Middleton
Township, Cumberland County, PennSYlvania, more particularly
bounded and delcribed as tollow.,
BEGINNING at a point on Conodoquinet Avenue at the boundary
line between tots Nos. 47 and 46 on the herein~tter mentioned
pl~n at lots, thence along said Conodoquinet Avenue, North 29
degrees 30 minutes East 10' tee,t to property tormerly at C. C.
Swarner, thence along the northeastern boundary ot line ot tot
No. 41, South 60 degrees 30 minute~ East 175 feet to other
lands formerly of C. C. Swarner and ~art of Meadow Brook Park,
thence South 29 degrees 30 minutes West, 80 teet to the'
northern boundary line of tot No. 46, thence North 60 degree.
30 minutes West along the boundary line between tota Nos. '46
and 47, 175 feet to Conodoquinet Avenue, the Place of
BEGINNING.
BEING Lots No. 47 and 48 in the Plan of Bungalow Lot. laid out
by C. c. Swarner and of record in the Office of the Recorder at
Deeds in and for Cumberland County in plan 'Book 2, Pago 31.
BEING the same premises .which David M. Bayer and PaUline L.
Bayer, his wife, by Deed dated November 28, 1984, and recorded
in Cumberland County ODed Book A, Volume 31, Page 41, granted
and conveyed to David M. Bayer, one of the Grantors herein.
Nina Bayer hereby joins to convey any and all rights, title and
interest she may have acquired ins aid premises.
eOllllP 33 rACE 416
A Verscharen
Appni....
5521 RIDGEVIEW DRIVE, HARRISBURG, PA 17112
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. " F..,., MG101
gEFINITION OF MARKET VALUE: Th. mosl probabl. price which. property should bring In. comp.lltl" .nd op.n market
under .11 conditions requilll. to. f." III., Ih. buyer end liller, IIch .cling prud.nlly, knowlldgflbly .nd IIsumlng Ih. pllC' .. nol
.ff.CI.d by undu. .timulu. Implicit In IhlS d.flnition il Ih. con.umm'llon of . 111.11 of. Ip.cifl.d d.t. .nd th. p.ssmg of lill. from
IIlIer to buyer under conditione wh.reby: (1) buyer .nd III~er ar.typlc.lly mollv.l.d; (2) both partifl.re w.lllnform.d or w.lI.dvllld.
.nd uch .cllng In wh.t h. con.,d.1I hi. own bullnler.sl; (3) . reasonabl.lim. Is .1I0wld for ..posure In !h. op.n mark.l; (4) paym.nl
I. m.d,'n lerm. of cuh in U,S, dolla.. or in term. 01 finonclIl.rrlng.m.nts comp.rabl.lher.to; .nd (5) lh. price reprll.nll th. norm.1
conlld".lIon for th. prop"ly sold un.ffleted by Ip.ci.1 or <:fllliv. fin.nclng or salll conc,,,'on.' grant.d by .nyon. usocl.tld wllh Ihl
III.,
'Adjultm.nll 10 th. comparablll mUll b. m.da for .p.cl., or <:f..liv. financing or 11111 conclI,'onl, No adju.tmlnt.are nac..."y for
tho.. COlli which are norm.lly paid by ull... II a r.sull of tradillon or law In . markltarll; lhell co.t. .re re.dlly Idlnlifiabll Since thl
..11" P'Y' Ihll. COil. In vlrtu.lly .11 ul.. tr.n..cllon., Sp.ci., or <:fllllv. IIn,"clng adJu.tm.nt. cen bl mad. 10 th. comparebl. property
by comparl.onl to fln.nclng terml off.red by . Ihlrd party In.tllutlon,".nd" th.tla not ,'rudy Involv.d In Ih. proparly or lrenUCllon, Any
adjualmantahould not b. c.lculalod on . m.ch.nlcol dollar for doller COil of th. IInancing or conc.nlon bulth. dollar amount of .ny
adJullmentlhou1d approxlmat. the mark.rs ructlon 10 Ih. fin.l\clng or concessions bll.d on lhe Appra'lfI'a Judgm.nt.
STATEMENT OF LIMITING CONDITIONS AND APPRAISER'S CERTIFICATION
CONTINGENT AND LIMITING CONDITIONS: Th. .ppralaer'. c"llfic.llon th.l.pp.arsln Ih. appralll' report II.ubjact to tha
following condition.:
1. Th. .ppralllr will nol bo rupon.ibl. for mall"s of . I.g.' n.ture Ih.laff.cl .lIhar Ih. prop"ty b.lng .pprallld or the till. to It, Th.
appr,'aer IIsumos th.tlhe 1111. IS good and market.bl. end, ther.for., wilt not rend" .ny opinions eboul the 1111., Th. prop.rty Is .ppr.ised
on the basi, 0111 being under respon~bla ownership,
2, Th. .pprelser has provid.d . ak.tch In Ih. apprellll report to show .pproxlmal. dim.nalon. of the improv.m.nls .nd the .k.lch i.
Included only to ...islth. reader of th. r.port In visualizing th. property and understanding th. apprai...... d.termin.11on ollis .Iz.,
3, Th. .p~ralaer has aXlmln.d Ih. .vallabl. 1I00d maps Ihal are provldad by Ih. F.deral Em.rgency Management Agency (or other data
.ourcu) and has noted In Ih. eppralsal reporl wheth.r th. subj.cl sll. Is local.d In en Id.nlifi.d Sp.cl., Flood Huard Area, B.cauII Ih.
appraiser Is nol a SUl'i.yor, h. or she mak.s no guarantees, expre.. or Implied, regarding Ihis d.termlnatlon,
4. Th. appraiser will nol give loslimony or app.ar In courl b.caus. h. or she mad. en appraisal of th. prop.rty In quoslion, unloss .p.clfic
arrang.ments 10 do so have be.n mad. befor.hand,
5, Th. .ppr.lser hll oslimal.d th. velu. of Ih. land In Ih. coslapproach .1 Its hlghut and but use and Ih. Improv.ments allhelr
contrlbulory valu., Thu. s.paral. valuations of the land and improv.ments musl nol b. used In conjunction with .ny olh.r .ppralsal and
are Inv.1Id W they are so used.
8, Th. .ppraiser has noted In the appralset r.port.ny adv.rs. conditions (such as, need.d repairs, d.precletlon, Ih. pres.nce of hazerdou.
wastll, loxlc aubstances, etc, ) observed during Ih. Inspection of Ih. subject properly or thaI h. or sho became awere of durlnp Ih. normal
ros.arch Involved In p.rformlng Ihe appraisal. Unless olherwlse stated In Ihe appraisal reporl, the eppralser has no knowl.dg. of any hldd.n
or uneppar.nl conditions of th. properly or adverse .nvlronm.nlal conditions (including Ihe pr...nc. of huardous wutu, toxic
.ubstances, elc. ) thai would make th. properly mora or less valuable, .nd has .ssumed Ihallhere ara no auch conditions end makea no
gueranl.u or warrantlu, upross or Implied, r.gardlng Ih. condition of Ih. property, Th. .ppraleer will not b. responsible for eny euch
conditions Ihel do exlsl or for any .nglneerlng or t.stlng Ihal mighl b. required to discover wh'lher such conditions exist. B.caus.lh.
.ppralser Is not .n exp.rl ii, Ih. field of environ menial hazards, Ih. appraisal report mu.t nol b. conslder.d as .n environ menIal .ss.ssm.nl
01 the property,
7, Th. .ppralser oblaln.d Ih. Information, estlmalu, and opinions thaI w.re express.d In Ih. appraisal reporl ~om sourc.s thaI h. or she
consid.rs 10 b. reliable .nd bell.ves them to be Irue and corr.ct. The appraiser dou nol assume responsibility for Ih. accuracy of such
i1ems thalwer. furnished by olher parties,
8, The apprals.r will nol disclose Ih. cont.nls of th. appraisal report excepl as provld.d for In Ihe Uniform Stand.rds 0' Prof.sslonal
Appraisal Practice,
9, Th. epprals.r has bas.d his or h.r appraisal report and valuation conclusion for .n appralsellh.tls subj.cllo salisfactory complellon,
repa..., or all....llons on the essumptJon thaI compt.tlon of Ihelmprov.menls will b. performed In a workmanlike manner,
10, Th. .ppralser must provld. his or her prior wrlll.n consent b.fore Ih. lender/client specified In lh. eppralsal r&port can distribute Ih.
appralsel reporl (Including conclu.lons eboullh. properly value, the appraiser's Id.nlily and prof...lonel duign.tlons, .nd refer.nces to
eny prof.sslonal eppralsel org.nlzellons or th. firm with which the appraiser Is .ssoclal.d ) to .nyone other Ihan Ihe borrower; th.
morlgagee or Its succusors and .sslgns; Ihe morlgago Insurer; consultenls; prof.sslonalappralsal organizations; any st.te or f.derally
approv.d IIn.ncl.llnstllutlon; or eny d.parlmenl, agency, or Inslrumenlalily of Ih. United Slalu or .ny sial. or th. Dlslrlct of Columbia;
exc.plthallh. I.nder/cllenl may dlslrlbule Ih. properly doscriptlon s.ctlon of th. reporl only 10 data collection or reporling servlc.(s)
wllhoul h.vlng 10 oblaln the eppralser's prior wrlll.n conllnt. The appraiser's wrlllen consenland approval musl .Iso b. oblaln.d before
Ih. eppralsal can b. con'lIyed by anyone to Ih. public through advertising, public relations, n.ws, eales, or olher media,
Freddl. Mac Form 439 6-93
Page 1 012
Fannia Ma. Form 1004B 6-93
. I . .
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f~. No, MG101
APPRAJSERS CERTIFICATION:
The Apptaiw ",,\lfia. and agra..that:
1, I have r....rch.d th. lubj.ct m.rk.t area Ind have III.ct.d . minimum of thr.. r.cant III.. 01 prop.rllll mOlt Ilmllar .nd ploxlmat.
to th. lubllct prop arty lor conlldaratlon In th. lalll comparlaon analYlil Ind have mad. . dollar adjullmant whan applopllat.to rlnactth.
mark.t rllctlon io tholl It.ml 01 Ilgnlflcant varlltlon, II a .Ignlficant it.m In a comparabl. property la lup.rlor to , or mor. favorabla thin,
th. lubJ.ct pr~p.rty, I hava mad a a nagatlv. adjustmantto r.duc. th. adJust.d 11111 prlc. of tha comparabl. and, II a significant itam in I
comparabl. proparly Is Inl.rior 10, or lau "vorabla than tha subl.ct properly, I hava mad. a positlv. .dju.tm.nt to incr.... th. adjustad
IIlas ptica oIth. comparabl.,
2, I hava takan Into consideration tha factora thai have an Impacl on ,alu. In my d.v.lopmant olth. estlmat. of markat valua In Iha
appraiul raporl. I have not knowingly withhald any slgnllicant informalion from th. .ppralul r.port and I ballave, to tha but of my
knowle<lgll, thel aU stat.manls and information in tha apptaisal r.port are ~u. and correct,
3, I.tat.d In th. apprallll rapoll only my own parson ai, unbias.d, and prolesslonalanalysls, opinions, and conclusions, which sra subj.ct
only 10 lhe conling.nt and IImiling conditions sp.cifled In this lorm,
4, I hava no prallnt or prosp.ctlva Int.rut in th. prop arty that la th. .ubjactto thl. r.port, and I hava no prallnt or pro.pacliva par.onll
Intarllt or blu with rllp.ctto th. partlclpantl In the tranuctlon, I did not ball, .ith.r partially or compl.t.ly, my Inalysll and/or th.
utlmata 01 mark.t valu. In th. appraisal report on th. rac., color, r.llglon, 3ex, handicap, lamlllal Italul, or national origin of .lther tha
prosp.ctlv. owners or occupantl of th. aubj.ct property or of the pruant own.rl or occupanta olth. propertl.1 In th. vicinity of th.
aubject property,
5, I hava no pres.nt or cont.mplat.d lutur. Int.restln th. lubJ.ct proparty, and n.llh.r my curr.nt or lutura amploymant nor my
compensation lor performing thll Ippralsalll conllngant on the apprlll.d valu. 01 the ptoperty,
8, I was not raqulr.d to report a pr.d.t.rmln.d valu. or dlr.ctlon In valu. that lavorl th. caus. of the cll.nt or any ralat.d party,
the amount of th. valu. estlmat., th. allainm.nt of a sp.cllic rasult, or the occurr.nc. 01 a subs.quent .v.ntln order 10 receiv. my
comp.nsatlon and/or .mploym.nt for performing tha appraisal. t did not b... Iha appr.lsal r.port on a requut.d minimum valuation, a
spaciflc valuation, or th. need to apptov. a sp.cl1Ic mortgage loan,
7, 'p.rlorm.d this appraisal In conlormlly wllh tha Unllorm Standards 01 Profuslonal Appralu' Practlc. that w.re adopt.d and
promulg.ted by th. Appr.lsal St.nd.rds Board of Th. Appraisal Foundation and that w.r. In plac. II of th. .ff.cllv. dal. 01 Ihls appraisal,
wllh th. Ixclpllon of th. d.partur. provillon 01 those Standerds. which does not apply, I acknowl.dg. that an ullmlta of e reuonabl.
time for exposure In th. open mark.tls a condition In the daflnlllon 01 merket value end th. .stimata I d.velop.d II consistent with the
markellng tlm. not.d In the neighborhood section 01 this report, unle..' heve otherwise sleted In the reconciliation seclion,
8, I have personelly Inspected the Int.rlor and exterior areas of Iha subject property and the axtarlor of ell prop.rtles listed.. comparebles
In the apprelsal reporl. 'further cerllfy that I hava noted any apparant or known advarse conditions In the sUbjectlmprov.ments, on th.
subject sit., or on any sit. within Ih. Imm.dlate vicinity of tha subj.ct propsrty of which I em aware and have mad. adJuslmenls for thu.
adverse conditions In my analysis olth. prop.rty value to the exl.ntthall had markat .vldence to support them, I have also commented
about the effect of the adverse condlllons on the markatabillty of th. subject property,
9, I pereonelly pr.par.d all conclusions and opinions about the real estate that wer. set forth In the appralsel r.porl. III r.lI.d on
significant profuslonal aulstanca from any Individual or Individuals In tha performance of th. apprelsal or th. pr.parallon of the appraisal
r.port, I hev. nam.d such Indlvldual(s) and disclosed the sp.ciflc tasks performed by them In th8 reconclllallon s.cllon of this appraisal
r.port. I cartlly that any Individual so nam.d Is qualified to perform the tasks. I have not authorlzad enyone to make a chang. to eny Item in
Ihe report; therefore, ~ an unauthorized change Is mada to the appraisal report, I will take no responsibility for It,
SUPERVISORY APPRAISER'S CERTIFICATION: If a supervisory apprals.r slgn.d Iha .pprelsal report, he or she cerllfies
and agrees that: I directly supervise the appraiser who pr.pared the appraisal r.porl, have r.vl.wad th. appraisal raport, agra. with Ih.
stat.m.nts and conclusions of th. appralsar. egree to be bound by the appraiser's certific_lIons numb.r.d 4 through 7 ebove, and am taking
full r.spon~bUlty for th. appraisal and the apptalsal report.
ADDRESS OF PROPERTY APPRAISED: 760 CONODOGUINET AVENUE, CARLISLE, PA 17013
APPRAISER:
Slgnat~e: ~#L.l
Name: JOHN ,VERSCHAREN ~
Det. Signed: NOVEMBER 08, 199B
Stet. Certillcatlon ,: RL.OO1977-L
or State Licanse ,:
Stat.: P A
Explralion Oat. of Certificalion or licans.: 08/30/99
SUPERVISORY APPRAISER (only If r.qulred)
Signature:
Nama:
Dal. Signed:
SI.t. Certificalion ,:
or Stale Ucans. ,:
State:
expiration Oal. of Certlficallon or licans.:
o [);d 0 Old Notlnsp.ct Property
RL.OOI977-L
Freddi. Mac Form 439 8.93
Page 2 012
Fannie Mae Form It)O.\B 8-93
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MINDY S. GOODMAN
ATTORNEY AT LAW
2080 LI~OLESTOYlN ROAD
llARRISOURO, ilIto 17110
TELEPllONE FAX
OI7l S40.8742 (717) 540.8743
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4, EXHIBITS: The exhibits that Plaintiff Intends to introduce at Include
the appraisal of the marital residence, Plaintiff reserves the right to supplement
this list of exhibits In a timely manner prior to trial,
5, INCOME: Plaintiff's gross income has previously been reported In
the Inventory and Appraisement filed on March 18, 1999, which is attached
hereto as Exhibit A. Plaintiff is in the process of compiling tax returns and those
will be filed with the Court as soon as they are available,
6, MARITAL DEBT: Plaintiff ill aware that there Is a first mortgage
against the marital residence, but has no information conclrning the amount of
the outstanding balance as all records are in the possession of Defendant.
7, PLAINTIFF'S PROPOSED RESOLUTION: At issue in this case is
the division of the equity of the marital residence, Plaintiff proposes that the
marital residence be valued as of the date of trial and that the equity as of the
date of trial be divided equally (50/50) between the Plaintiff and Defendant.
RespectfUlly submitted,
.
~~s~~
Mindy S, GooClman
Attorney at Law
ID No, 78407
2080 Linglestown Road
Harrisburg, PA 17110
(717) 540-8742
Attorney for Plaintiff
..
,,1
2
SANDRA L. GORHAM,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: No, 97.5945 CIVIL TERM
: CIVIL ACTION LAW
: IN DIVORCE
JAMES G, GORHAM,
Defendant
INVENTORY AND APPRAISEMENT
AND INCOME AND EXPENSE STATEMENT
OF PLAINTIFF. SANDRA L. GORHAM
Plaintiff 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,
Plaintiff verifies that the statements made in this Inventory and Appraisement
are true and correct. Plaintiff understands that false statements herein are made
subject to the penalties of 18 Pa, C,S, Section 4904, relating to unsworn falsification
to authorities,
\~.-4J ~&~"W
Sandra L. Gorham
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ASSETS OF PARTIES
Plaintiff marks on the list below those items appliceble to the cese 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. Real Property
2. Motor Vehicles
3, Stocks, bonds, securities and options
4. Certificates of deposit
5. Checking accounts, cash
6. Savings accounts, money market and savings certificates
7, Contents of Safe Deposit Boxes
8, Trusts
9, Life Insurance policies (indicated face value, cash value and
current beneficiaries)
10, Annuities
11. Gifts
12. Inheritances
13, Patents, copyrights, inventions and royalties
.
14. Personal property outside the home
15. Businesses (list all owners, including percentage of ownership,
and officer/director positions held by a party with company)
16, Employment termination benefits - - severance pay, Workman's
Compensation claim/award
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17, Profit sharing plan
18. Pension plans (indicate employee contribution and date plan
vests)
19, Retirement plans, Individual Retirement Accounts
20, Disability payments
21, Litigation claims (matured and unmatured)
22, MilitaryN.A. benefits
23, Education benefits
X 24. Debts due, including loans, mortgages held
25. Household furnishings and personalty (include a totel category
and attach itemized list of distribution of such assets is in
dispute)
30. Other
MARITAL PROPERTY
Plaintiff lists all marital property in which either or both spouses have a legal
or equitable interest individually or with any other person as of the date this action
was commenced:
Item Description Names of Date of
Number of Prooertv all Owners ACCluisition
1, $1,000 or Pickup Truck James Gorham 5/86
wedding money used,
. 2, Dehumidifier - gift by Both parties 6/B6
Plaintiff's parents
3. Outdoor Gas Grill - gift Both parties 7/87
by Plaintiffs parents
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4. Stack WasherlDryer Both parties 5/88
5, Canoe Both parties 5/88
6. Aquarium Both parties 7/89
7, Console Television Both parties 6/85
8. Oak Desk Both J:arties 5/85
9, Oak Drop LeafTable Both parties 5/86
10. Oak Glass Front Hutch Both parties 5/86
11. Oak Bench Wedding gift 5/86
12, 3 Lawn Mowers Both parties 5/86,6/87,6/89
13. Air Conditioner - gift by Both parties 6/89
Defendant's mother
14. Stove - gift by Plaintiffs Both parties 9/89
parents
Cost or Value Value as of
Item as of Date Date Action Amount of
Number of ACQuisition Commenced any lien
1. $10,000,00 nJa
2, $300.00 nla
3. $500,00 nla
4. $500,00 nla
5. $200.00 nla
6, $150,00 nla
. 7. $1,200,00 nla
8, $400,00 n/a
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9. $200,00 n1a
10. $400.00 n1a
11, $100,00 n1a
12. $100,00 each n1a
13. $400,00 n1a
14, $400.00 n'a
NON.MARIT AL PROPERTY
Plaintiff lists all property in which a spouse has a legal or equitable interest
which is claimed to be excluded from marital property:
Item Description Names of Date of
Number of Prooertv all Owners Acauisition
1, 1988 Dodge Caravan Sandra Gorham 10/92
Cost or Value Value as of
Item as of Date Date Action Amoun~ of
Number of Acauisition Commenced any Lie!)
1, $2,000.00 n'a
Item Nature of
Number anv lien
n/a
Item
. Number
1,
Effective
Date of
Lien
Holder of
Lien
Basis for Exclusion from Marital Prooertv
Purchased after date of separation with
non-marital funds,
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eROPERTYTRANSFER~EQ
Plaintiff lists all property in which either or both spouses had a legal or
equitable Interest individually or with any other person and which has been
transferred within the preceding three years:
aem
Number
Description
of Prooertv
Names of
all Owners
Date of Date of
Acauisitlon Transfer
nla
Item
Number
Cost or Value
as of Date
of Acauisition
Value as of
Date of
Transfer
Amount of any
Lien as of
Date of Transfer
n'a
Item
Number
Nature of
any Lien
Date of
Lien
Holder of
Lien
nla
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SANDRA L. GORHAM,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: No. 97-5945 CIVIL TERM
JAMES G, GORHAM,
Defendant
.
: CIVIL ACTION LAW
: IN DIVORCE
FINANCIAL STATEMENT OF PLAINTIFF
MONTHLY EXPENSES
Shelter:
a. Mortgage or Rent ,.."....""., $400,00
b. SewerNJater , , , , , , , . , . . , . , , , . , , .. $ 20.00
c, Electric. . . , . . , , , , , . . , , . . , , . , , . ., $ 20,00
d. HeaUOil , , , , . , , , . , . , , , . , . , , , . , . , . $ 40.00
TransDortation:
a, Auto Loan payments. . . . . , . , , . . , , . . $ 0,00
b, Auto Insurance, . , , , , . . , , , . . . , , , . , . $562,82 yr. = $46.90 mo.
c. Auto Expense. . , . , , , , . , , , . . . . , . . , .$400,00 yr, = $33,00 mo,
d. Travel Expenses, . .. , . , , , , , . . , , . . , ,$500,00 yr, = $41,66 mo.
Medical Carellnsurances:
a, Life Insurance. , , , , . . , , . , , , . . . , . '. $ 0.00
b, Medical Insurance , , , , , , . , . . , , . . , , . $ 0.00
Clothlna:
a,
b.
c,
Self.."""..""".,.."...,.. .$
Gifts, etc, . , . . , . , , , , . . . , . . , . , . . , , , ,$
Dry Cleaning. , , , , , . , . , . , , , , . . . . " $
25.00
25.00
5.00
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......... Verscharen
Appraisals
FoIo No MGIOl
f
APPRAISAL OF
COpy
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SINGLE FAMILY RESIDENCE
LOCATED AT:
760 CONODOGUINET AVENUE
CARLISLE, PA 17013
FOR:
SANDRA L. GORHAM
10 SOUTH HIGH STREET
MECHANICS BURG, PA 17055
AS OF:
AUGUST 13, 1998
BY:
JOHN R. IJERSCHAREN
RL-001977-L
5521 RIDGEVIEW DRIVE, HARRISBURG, PA 17112
J:........ ...... ..
SUMMARY APPRAISAL REPORT
UNIFORM REsloeNt1AL: APPRAISAL REPORT FlloNo, MG101 .
;: S NOT APPLICABLE Comm.nl. on COSI Appro.en (such II, loure. of co.t "lim'I.,
,itt v.lut, .qullI foot ctlcullUon .ncl for HUD. VA ,nd FmHA, th,
..Umated ,.mlming economic lif. of thl properly):
THE COST APPROACH AS NOT BEEN DEVELOPED DUE
TO THE AGE 0" THE SUBJECT, SEE ATTACHED TEXT
ADDENDUM.
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. I NnT APP'I'"A ""
COMPARABLE NO , COMPARABLE NO 2 COMPARABle NO 3
371 CORNMAN ROAD 1 CHANNf;L DRIVE 541 CONODOGUINET AVE
CARLISLE PA CARLISLl! PA CARLISLE PA
2,75 MILES 2,75 MILES 2 BLOCKS
1 N/A . 65 900 I 73 500 ' '1- 79 900
II ill S 37,27 ill Is 57,11 ill " , , 53,99 ill ".. '
PUBLIC RCRDS MULTIPLE LISTING SERVICE MULTIPLE LISTING SERVICE MULTIPLE LISTING SERVICE
INSPECTION PUBLIC RECORDS PUBLIC RECORDS PUBLIC RECORDS
DESCRIPTION DESCRIPTION I ",'I~'_ DESCRIPTION I '",'......_ DESCRIPTION T ,'.,._
" FHA FINANCING: VA FINANCING FHA FINANCING:
, , 'NONE : NONE ' NONE :
IIIIONE" r ' " , 03/10/96 : 04/09/96: 07/13/96:
SUBURBAN SUBURBAN SUBURBAN SUBURBAN '
FEE SIMPLE FEE SIMPLE: FEE SIMPLE: FEE SIMPLE :
,32 ACRES 1 ACRE :.1 700 ,29 ACRES: .09 ACRES :
AVERAGE AVERAGE' AVERAGE' AVERAGE
CAPE COD CAPE COD: CAPE COD: 2 STORY :
AVERAGE EQUAL : EQUAL : EQUAL :
59 YRS. IESn 68 YRS 51 YEARS 60 YRS IEsn '
Condition FAIR FAIR/EQUAL: AVG/SUPERIOR : .5500 AVG/SUPERIOR :
Aboye Grade relit ' Ilotl'llt' ..... Tou, I l,t",.' ... : T..... ' B4'llI. I ,-. : ,*' 1W1N' .-. :
RoomCounl '8: 3: 2.00 7: 4: 1,00: 1,000 6: 4: 1,00: 1,000 6: 3: 2,00'
Gros. LMoo kee 1 769 SoFI. 1 768 son : 1 287 50Ft: 2900 1 480 So.F1. '
. IlasemenI&Frished 210 SQ,FT, EQUAL : EQUAL : EQUAL :
Rooms Below Gt.de UNFINISHED UNFINISHED' UNFINISHED' UNFINISHED'
" Functlon.IUI~1v AVERAGE AVERAGE: AVERAGE: AVERAGE:
Hoer OILHW/NONE OILFNNONE: OILFNNONE: ELBB/NONE:
. ~ElIIOonllllllTll STANDARD EQUAL EQUAL EQUAL
Gar.oeIC...... NONE 1C.DE'(ACHED: ,2500 1C-DETACHED: ,2500 NONE :
I'O'ch, P.lio, Docl<, ENCPOR/DECK PORCHES, PORCH/E,POR ; PORCH/SUNRM :
Froolo""" elc. FIREPLACE NONE : 1 000 NONE ' 1 000 COAL-STOVE :
Fence Pool el~ NONE NONE ' NONE : NONE :
OTHER NONE NONE : NONE : NONE :
NeIMI.llole" .. '"' I I. IXI,:S 22CO I I. IXI.:I 3100 II. rXl. :i
:;r~=Abl " ',' ":~~~:'~:i~~~' .' 1 63 700 ~~'}}i:~~~X:i' S 70 400 ~(':;rftio.~oi.l; I
Commenl' on 5.1.. Comp.ri.on (Including Ihe ,ubject properly', comp.tibillty 10 Ihe neighborhood, otc,): SEE ATTACHED TEXT ADDENDUM,
Valu.llon.S,ctlon .
ESTIMATED SiTE VAlUE
ESTIMATED RfPROOUCTlON COST,NEW OF IMPROVEMENTS
IMIing 1,769SqFI ClII '1
BSMT.210 Sq,Ft ClII__ .
. F/P DECK PORCH'
, Gngoo\:a'pal _ Sq, FI. 0 1
" ToIoI E'llmolod Co,t New , , , , , ' , ,
. =oao~5 Physical I Function'" I Ellarnol
O.prtd.led Valu. or IlTIp'o".menll ,
.AI~. VaIu. of Sill Improv.m.nts .
INDICATED VALUE BV COST APPROACH, ,
ITEM I SUeJECT
760 CONODOGUINET AVENUE
Addie.. CARLISLE PA
F'fOI{ImI'" 10 Sub'''1
Sal,. Pric.
Pn::e.Qoa llV. kea
0.1. .nd/or
Vlliftcahon SOU-ct'
Vo'I.Le AIl.USTh'ENTS
S.101 fX Financing
CooceSsJonl
0.11 01 S.lelTlmo
location
I.Mllt'dl.foe Sm:io
.
.
... . 1 ,
. 1
Sil.
""W
De,lon 101 An'OII
~dCaotu:t:r1
800
.10500
1700
8200
71700
ITEM SUBJECT COMPARABLE NO, I COMPARABLE NO, 2 COMPARABLE NO, 3
D.le, Price ,nd 0.11 NONE THE PROPERTY HAS ONLY THE PROPERTY HAS ONLY THE PROPERTY HAS ONLY
Salce tqra..... NONE SOLD ONCE WITHIN SOLD ONCE WITHIN SOLD ONCE WITHIN
oIthi1~.oI'~." NONE THE PAST YEAR THE PAST YEAR THE PAST YEAR
An.~i. olony cu"nl.lIIOImanl 0' "II, Oplion, c.r ro,ling of the "biect plOper1y 'nd .n'~111 01 ,ny p'a sales of lU~ed lll1d lXIfT'l>a<IbIes l>i1hi1 one ywd Ihe d.lo d epp:Ma
THE APPRAISER WAS NOT MADE AWARE OF ANY SALES AGREEMENTS PERTAINING TO THE SUBJECT, IT IS ASSUMED
THAT THE PROPERTY IS NOT CURRENTLY UNDER AGREEMENT TO BE SOLD,
INDICATED VALUE BV SALES COMPARISON APPROACH, , , . , . .. . , , , . , ' , , , , . , .. . . , , ' , . , , , , , , ' , , . , , , .. , . , , .. ..I 88
INDICATED VALUE BVINCOME APPROACHIlfAn....""'\ E.tim.ted Mllk.IR.nll """ ,QnssRenl"""'" .1 ""...;;'
Thi. ,ppr.i..1 i. made ~... il" . L"J. .ubjeclloth.rep...., aJI....tions, i1speclionsrxCllOdilion. isled beklw W _subjeclIoCllf1'lllelklnP6'plnrd....1IonL
CordilionsolAppraisal: THIS APPRAISAL IS TO BE CONSIDERED NULL AND VOID UNLESS ACCOMPANIED BY ALL OF THE FORMS
AND ADDENDA INCLUDED WITH THE ORIGINAL REPORT PROVIDED TO THE CLIENT BY THIS APPRAISER.
Fin.IReoonciro.lion THE DIRECT SALES COMPARISON APPROACH IS CONSIDERED TO PROVIDE THE TYPICAL ACTIONS nF
BUYERS AND SELLERS IN THE MARKETPLACE AND HAS BEEN UTILIZED IN THE DETERMINING THE FINAL ESTIMATE nF
. VALUE.
. The PIXpOII of this apprail8l is 10 eslimate the market value of the real property thai Is the .ubjecl of this report, based on the above condItion. ard flIC*1IcItbn, CI:IrII'9Int
Ind mUng conditions, and market value dllrltlilion tha' Ire slated in (he attadled Frnddie Mac Fcrm439iFaMie Mae Fcrm 10048 (ReWsed 6/93 }
I (WE) ESTIMATE THE MARKET VALUF. AS DEFINED, OF THE REAL PROPERTY THAT IS THE SUBJECT OF THiS REPORT, AS OF AUGUST 13, 1998
. (WHICHISTHED~F "SrECTIOI NDTHEEFFECTIVEDATEOFTHISREPOR, T)TOBEI 68,000 ,
, APPRAlSEY,&'/' I JOJ, I 5UPERVlSORVAPPRAlSER (ONLVIF REQUIRED):
Sion,l"e J S~n.I"e OCid O~ Nllt ...
N.ma JOHN R. VERSCHAREN N.ma inIl>tctAllporly ,
D.leReportS~ned NOVEMBER 06, 1998 D.tIR.n<V1S~n.d ...,'
51,Ie Cartillcolion. RL.001977.L SI.le PA 51.11 Cart;rocal~n' Slolt.
() Sl.le license" Slate () Slale lIe!!nse' Slat.' ,-'
'_""~"'I) RL'uUl~II'L PAGE20F2 ._...t.......
r....boJI_"........1II'4.IGIO'.........~......fTIltI'IIQll~.tlt .::,..r
VERSCHAREN APPRAISALS.";
.
"
ADDENDUM
FII. No. MOIOI
THE METROPOLITAN STATISTICAL AREA LOCATION NUMBER IS 3240,
PLEASE NOTE THAT THIS TEXT ADDENDUM IS AN INTEGRAL PART OF THE ENTIRE APPRAISAL REPORT
AND MUST BE INCLUDED WITH l}lE MAIN FORM PAGE(S) IN ORDER FOR THIS REPORT TO PROPf:RL Y
COMPLY WITH USPAP STANDARbs, THIS APPRAISAL REPORT IS TO BE CONSIDERED NULL.ANO,VOID
UNLESS ACCOMPANIED BY ALL OF THE f"ORMS AND ADDENDA ORIGINALLY PROVIDED TO THE CLIENT
BY THIS APPRAISER,
SUBJECT PROPERTY
THE SUBJECT IS A WOOD FRAME COVERED CAPE COO STYLE HOME WITH AN ENCLOSED SIDE PORCH
AND A REAR DECK. THE INTERIOR OF THE HOME FEATURES A KITCHEN. DINING ROOM, LIVING ROOM
WITH A FIREPLACE, TWO BEDROOMS AND A BATHROOM ON THE FIRST FLOOR. THE SECOND FLOOR
HAS AN ADDITIONAL BEDROOM AND ANOTHER FULL BATHROOM, THERE IS A SMALL PARTIAL
UNFINISHED BASEMENT AREA
ZONING CLASSIF~CATION AND DESCRIPTION
THE SUBJECT IS SITUATED IN AN AREA THAT IS ZONED "CONSERVATION ZONE", THIS ZONE SEEKS TO
PROTECT LARGE CONCENTRATIONS OF ENVIRONMENTALLY SENSITIVE FEATURES THAT ALSO HAVE
SIGNIFICANT VALUE FOR PASSIVE AND ACTIVE RECREATIONAL PURSUITS, SPECIFICALLY, FORESTED
AREAS, STEEP SLOPES, STREAM AND CREEK VALUES. WETLANDS AND FLOOD PLAINS ARE INCLUDED,
HOWEVER, THERE ARE A VARIETY OF OTHER PERMITTED USES AS DESCRIBED IN SECTION 200,2 OF
THE NORTH MIDDLETON TOWNSHIP ZONING REGULATIONS INCLUDING BUT NOT LIMITED TO SINGLE
FAMILY DETACHED DWELLINGS, AGRICULTURAL USES, FAMILY OAYCARE FACILITIES, SOME LIMITED
COMMERCIAL USES AND A VARIETY OF OTHER USES,
SITE COMMENTS
THE LOWER PORTION OF THE SUBJECT PROPERTy IS SITUATED IN FLOOD ZONE A9 (SEE ATTACHED
COPY OF THE FEMA FLOOD MAP), ZONE A91S DEFINED AS "AREAS OF 100.YEAR FLOOD; BASE FLOOD
ELEVATIONS AND FLOOD HAZARD FACTORS DETERMINED",
WHILE VIEWING THE EXTERIOR OF THE SUBJECT, MR. GORHAM INDICATED THAT THE LOWER SECTION
OF THE REAR DECK ACTUALLY EXTENDS OVER THE REAR PROPERTY LINE ONTO THE NEIGHBORING
PROPERTY, THIS INFORMATION COULD NOT BE VERIFIED OR SUBSTANTIATED BY THIS APPRAISER
SINCE A SURVEY WOULD HAVE TO BE PERFORMED IN ORDER TO DETERMINE THE EXACT POSITION OF
THE HOME AND DECK IN RELATION TO THE REAR PROPERTY LINE, IF THIS REAR LOWER SECTION OF
THE DECK ACTUALLY DOES EXTEND OVER THE PROPERTY LINE, IT IS EXPECTED THAT THIS SITUATION
WOULD NOT HAVE A SIGNIFICANT MEASURABLE AFFECT ON THE OVERALL MARKETABILITY OF THE
SUBJECT SINCE THIS DECK COULD EASILY BE REMOVED TO COMPLY WITH THE SUBJECT'S PROPERTY
BOUNDARIES, SEE ADDITIONAL PHOTO #8 FOR A VIEW OF THIS LOWER DECK SECTION, THERE ARE
NO OTHER APPARENT ADVERSE EASEMENTS OR ENCROACHMENTS AFFECTING THE SUBJECT
PROPERTY,
THE FACT THAT THE SUBJECT IS SITUATED IN A FLOOD HAZARD AREA TYPICALLY WILL NOT HAVE A
SIGNIFICANT MEASURABLE AFFECT ON THE OVERALL MARKETABILITY OF SUCH PROPERTIES, I HAVE
PERSONALLY STUDIED THIS SITUATION IN THE MARKETPLACE AND IT APPEARS AS THOUGH THE
POSSIBILITY OF FLOODING IS OFTEN COMPENSATED BY THE RECREATIONAL AND/OR OTHER POSSIBLE
BENEFITS OF HAVING THE CREEK NEARBY,
CONDITION OF IMPROVEMENTS
DURING THE INSPECTION OF THE SUBJECT PROPERTY, THERE WERE SEVERAL DEFERRED
MAINTENANCE ITEMS AND SEVERAL NECESSARY MINOR REPAIRS, THE VINYL KITCHEN FLOOR HAS
SEVERAL DAMAGED SECTIONS (SEE ADDITIONAL PHOTO #1), THE FIRST FLOOR BATHROOM SINK IS
MISSING (SEE ADDITIONAL PHOTO #2), THE DRYWALL AROUND THE SHOWER HEAD IN THE FIRST
FLOOR BATHROOM IS DAMAGED (SEE ADDITIONAL PHOTO #3), THERE IS A HOLE IN THE WALL OF THE
FIRST FLOOR FRONT BEDROOM (SEE ADDITIONAL PHOTO #4).
AT THE TIME OF THE INSPECTION, MR, GORHAM INDICATED THAT THE METAL ROOF HAS SOME MINOR
LEAKS, THE CEILING SURFACE HAS SEVERAL AREAS OF DISCOLORATION AND/OR WATER MARKS
WHICH APPEARS TO CONFIRM MR, GORHAM'S STATEMENT, IN VIEWING THE ROOF FROM THE
GROUND, THERE DOES NOT APPEAR TO BE ANY SIGNIFICANT SECTIONS OF DETERIORATION OR
DAMAGE WHICH WOULD LEAD THIS APPRAISER TO BELIEVE THAT ONLY MINOR REPAIRS ARE
NECESSARY, SUCH AS CAULKING A SEAM, HOWEVER, IF WATER IS CONTINUED TO BE ALLOWED
ENTRY INTO THE HOME. SUBSTANTIAL DAMAGE AND DETERIORATION COULD OCCUR OVER A PERIOD
OF TIME, IT WAS IMPOSSIBLE TO VIEW THE ACTUAL WOOD ROOF DECKING MATERIAL TO ASCERTAIN
THE EXTENT OF ANY EXISTING DETERIORATION; HOWEVER, JUDGING FROM THE MINIMAL DAMAGE TO
THE CEILING TILES, I WOULD ESTIMATE THAT NO SERIOUS DAMAGE HAS OCCURRED THAT WOULD
AFFECT THE STRUCTURAL INTEGRITY OF THE ROOF'S SURFACE, SEE ADDITIONAL PHOTO #5 AND #6,
THE CURRENT CONDITION OF THE SUBJECT IS EXPECTED TO HAVE SOME AFFECT ON THE
MARKETABILITY OF THIS PROPERTY IF IT WERE CURRENTLY PLACED ON THE MARKET TO BE SOLO,
THIS CONDITION DIFFERENCE IS ADJUSTED FOR IN THE SALES COMPARISON GRID IN ORDER TO
COMPENSATE FOR THE ESTIMATED MARKET REACTION TO THIS SITUATION, PLEASE NOTE THAT
THESE ADJUSTMENTS ARE NOT BASED ON ANY "COST-TO-CURE" FIGURES BUT ARE BASED ON THE
.. .
ADDENDUM
FII. No. MGIO!
ESTIMATED MARKET REACTION THAT THESE NECESSARY REPAIRS AND MAINTENANCE ITEMS WILL
HAVE ON THE MARKETABILITY OF THE SUBJECT PROPERTY,
IN ADDITION. PLEASE NOT&: TH,AJ" THIS APPRAISER IS NOT A BUILDER, PROFESSIONAL HOME
INSPECTOR, CONSTRUCTION E.s!PERT OR STRUC rURAL ENGINEER AND THERE MAY BE OTHER
PHYSICAL DEFICIENCIES OR NECESSARY NEEDED REPAIRS THAT WERE NOT READILY IDENTIFIABLE
DUE TO THE LIMITATIONS OF STANDARD APPRAISER WALK-THROUGH TECHNIQUES.
ADVERSE ENVIRONMENTAL CONDITIONS
THERE ARE NO KNOWN ADVERSE ENVIRONMENTAL CONDITIONS AFFECTING THE SUBJECT PROPERTY
THAT THE APPRA:SER COULD OBSERVE USING NORMAL INSPECTION TECHNIQUES,
THE APPRAISER IS NOT QUALIFIED TO DETECT THE PRESENCE OF RADON GAS IN THE SUBJECT
PROPERTY, SHOULD RADON GAS CONTAMINATION BE A CONCERN, A QUALIFIED PROFESSIONAL
SHOULD BE CONSULTED.
THE APPRAISER IS UNABLE TO VERIFY THE INSULATION "R" FACTOR. THE PRESENCE OF
UREA.FORMALDEHYDE FOAM INSULATION COULD NOT BE DETERMINED, IF UFFIIS PRESENT, THE
APPRAISED MARKET VALUE MAY BE ADVERSELY AFFECTED OR VOIDED, ANY INFORMATION ABOUT
INSULATION STATED ON THE APPRAISAL WAS PROVIDED BY INSPECTION, OWNER OR AGENT, AND IS
ASSUMED TO BE ACCURATE,
COST APPROACH COMMENTS
THE SUBJECT IS AN OLDER PROPERTY AND THE COST APPROACH HAS NOT BEEN DEVELOPED DUE TO
THE UN RELIABILITY AND DIFFICULTY IN ACCURATELY ESTIMATING THE ACCRUED DEPRECIATION IN
HOMES OF THIS AGE, THERE IS A GENERAL CONSENSUS AMONG REAL ESTATE APPRAISERS AND
PROFESSIONAL APPRAISAL ORGANIZATIONS THAT THE COST APPROACH METHOD OF VALUATION IS
RENDERED INEFFECTIVE WHEN ATTEMPTING TO VALUE HOMES OF THIS AGE, IT IS THEREFORE
CONSIDERED PRUDENT FOR THE APPRAISER NOT TO INCLUDE THE COST APPROACH IN THE REPORT
INSOFAR AS IT MAY ACTUALLY BE MISLEADING TO THE CLIENT, THIS IS IN COMPLIANCE WITH THE
UNIFORM STANDARDS OF PROFESSIONAL APPRAISAL PRACTICE DEPARTURE PROVISIONS,
COMMENTS ON SALES COMPARISON
EVERY EFFORT WAS MADE TO FIND THE MOST SIMILAR COMPARABLE PROPERTIES FROM THE
SUBJECTS GENERAL MARKETING AREA. SUBSEQUENTLY, IT WAS NECESSARY TO USE SALES THAT
ARE MORE LOCATED FARTHER THAN ONE MILE FROM THE SUBJECT, THIS IS DUE TO THERE NOT
BEING ANY MORE RECENT OR CLOSER SALES, WITH SIMILAR CHARACTERISTICS, THAT HAVE SOLO
WITHIN THIS GENERAL AREA THAT BETTER REFLECT THE CURRENT MARKETABILITY OF THE SUBJECT,
ALL OF THE COMPARABLES HAVE SETTLED WITHIN SIX MONTHS OF THE EFFECTIVE DATE OF THE
APPRAISAL, THESE SALES ARE SITUATED IN THE SAME GENERAL MARKETING AREA AS THE SUBJECT,
AND ARE CONSIDERED TO THE BEST POSSIBLE COMPARABLE SALES AVAILABLE, PROPERTY VALUES
HAVE BEEN STABLE AND NO ADJUSTMENTS WERE NECESSARY FOR TIME OF SALE,
THE COMPARABLES PRESENTED HAVE BEEN RATED IN TERMS OF THEIR INHERENT SIMILARITIES TO
THE SUBJECT AND THEN CORRELATED INTO A FINAL ESTIMATE UTILIZING THE APPROPRIATE
APPROACH(ES). THE ROUNDED RATES OF $ 6,00 AND $ 2,500,00 WERE APPLIED FOR THE SQUARE
FOOTAGE AND LOT SIZE DIFFERENCES RESPECTIVELY, THE FIRST LINE OF THE ROOM SECTION IN THE
ADJUSTMENT GRID IS FOR THE BATHROOM DIFFERENCE AND THE SECOND LINE IS FOR THE ROOM
AND SQUARE FOOTAGE DIFFERENCE, IF NECESSARY,
COMPARABLE ONE IS A 1.5 STORY HOME SITUATED JUST TO THE NORTHEAST OF THE SUBJECT AND AT
THE TIME OF SALE WAS IN VERY SIMILAR CONDITION TO THE SUBJECT, THE GROSS LIVING AREA OF
THIS SALE IS ALMOST IDENTICAL TO THE SUBJECTS, OTHER MINOR ADJUSTMENTS WERE ALSO
NECESSARY FOR COMMON TYPICAL DIFFERENCES,
COMPARABLE 1W0 IS A 1.5 STORY STYLE HOME LOCATED JUST OT THE EAST OF THE SUBJECT AND IS
ALSO LOCATED ALONG THE BANKS OF THE CONODOGUINET CREEK, AFTER VIEWING THIS SALE AND
ANALYZING INFORMATION PROVIDED BY THE LISTING AGENT, THIS SALE IS CONSIDERED TO BE
SLIGHTLY SUPERIOR IN TERMS OF CONDITION AND REQUIRED THE APPROPRIATE COMPENSATING
NEGATIVE ADJUSTMENT, OTHER TYPICAL COMMON ADJUSTMENTS WERE ALSO NECESSARY,
COMPARABLE THREE IS A TRADITIONAL TWO STORY STYLE HOME LOCATED ON THE SAME STREET AS
THE SUBJECT, THIS HOME HAS BEEN WELL MAINTAINED AND HAS HAD SOME RECENT REPAIRS AND
COSMETIC REDECORATING; SUBSEQUENTLY, THIS SALE IS ALSO CONSIDERED TO BE SUPERIOR IN
TERMS OF CONDITION AND REQUIRED THE APPROPRIATE COMPENSATING NEGATIVE ADJUSTMENT,
THIS SALE WAS UTILIZED DUE TO ITS CLOSE PROXIMITY TO THE SUBJECT AND IS CONSIDERED TO
ADEQUATELY REPRESENT THE MARKETABILITY OF HOMES WITHIN THIS IMMEDIATE MARKETING AREA,
OVERALL, MOST WEIGHT HAS BEEN GIVEN TO THE MEDIAN VALUE OF THE THREE ADJUSTED
COMPARABLE SALES IN DEVELOPING THE DIRECT SALES COMPARISON ESTIMATE,
IN THE VALUATION OF THE PROPERTY, ONLY ITEMS ATTACHED TO THE REALTY WERE CONSIDERED.
ITEMS SUCH AS REFRIGERATORS, WASHERS, DRYERS, FURNITURE, OR OTHER CHATTEL ITEMS WERE
NOT CONSIDERED IN THE VALUATION,
FhOORPLAN
, '
Booowfll'lCllent. SANDRA L. GORHAM
ProDMtv Address: 760 CONODOG\,IINET AVENUE
I : ARLlSLE
File No,: MG10f
Case No,:
Slele: PA
Zi : 17 1
of
REAR OECK
18,00'
Sl
14,00' ... 10,00'
LIVING is a
~ ...
n !3
UJ ~
~ SR
Sl Sl
~ SR UJ ~
SR
.50'
!3
.;
o
6,00'
10,00'
SkllCh by Apo IVW1ndowI'"
AREA CALCULATIONS SUMMARY
AN, Nlm. or ANI
-.--.---
G1.Al rnUT rLOOA
01.A2 IlCOHO n.ooa
p,p INCLO.ID PORCH
aSH! .....-nt
Size
133S,OOOO
U4.0000
'''.0000
210,0000
Tolell
133S,OOOO
414.0000
713,0000
I 210,0000
LIVING AREA BREAKDOWN
BrwlklJown Subtotal.
FlU., J'LOOR
..00 .
11.00 .
U.OQ .
3.50 .
llCOHD J'LOOR
'7.00. 1,00
10.00 . 31.50
1.00
41,00
31,SO
1,00
32,0000
731,0000
SU,OOOO
aI.OOOO
".0000
31S,OOOO
. .
....,..-
I
"
~
I
6 Areas Total (rounded)
1769
TOTAL LIVABLE (rounded)
1769
....M
{' . ..... ,.".".....",..',..,,,......,............ '
'." . --"';-
A Verscharen
--
5521 RIOGEVIEW DRIVE, HARRISBURG. f'A 17112
ADDITIONAL SUBJECT PHOTOS
~lCIlent: ~NDRA L. GORHAM . ., File No,: MGlOl . " .
ProD8I1V Add",,: 760 CONODOGUINET AVENUE Case No,:
, AR I E S.e 0: PA Zi : 17013
~
~..
ADDITIONAL PHOTO .1
PHOTO OF KITCHEN FLOOR SURFACE,
.....
-4.
, '
ADDITIONAL PHOTO t2
PHOTO OF FIRST FLOOR BATHROOM
WITH MISSING SINK,
ADDITIONAL PHOTO t3
PHOTO OF DAMAGED BATHROOM
WALL.
.~ Verscharen
-
ADDITIONAL SUBJECT PHOTOS
~ICIlent: AANDRA L, GORHAM . .
Prooertv' Addrese, 760 CONODOGUINET A VENUE
RUSLE Slale: PA
, "'~"....
".-~~' "-"2.:'1,"
".....-",..,. i"'."'," ~
k.~'''' :I".":' .
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, -'.J#'1I':i~.r..... .....'.,)
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~,.
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I ,-t ,', ~/~ '
~'~ "/,,
-', ,.
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,"f.~~L
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>-,',',<'. ;,;~',/:
:. ' .,' :. - ,," '. ..' ~~'
g.~,~\.:~ :XJ<':1k
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~
-
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..
File No,: MOlal
Case No,:
. .,
Zi : 17
ADDITIONAL PHOTO 1M
PHOTO OF DAMAGED FIRST FLOOR
WA'.L,
ADDITIONAL PHOTO 15
PHOTO OF 2ND FLOOR CEILING,
ADDITIONAL PHOTO M
EXTERIOR SIDE PHOTO,
'''',
~.~:;~
~:~~
~/-~J
",";>;-;
;,",,;;~
,..,'::;'!;
'~'~--:t~"
.-{~t~:
'_-",G",iti
-":i::ii'l:-
O:~~~d"
?~!
,:.;~':i~.
';'""'",';.,.,,
'.~;::"'1.
':-:';=i23.k"
'-<".~.;
"--;;><;'
_ cOt..,;.
""'-':"H'i
A Verscharert
~
o:).{
"'c'
COMPARABLE PROPERTY PHOTO ADDENDUM
llent: ANORA L G RHAM .. File No,: MG101
~7 ON 00 INET AVENUF. ~se No,:
E Slale: PA Zi : 17
, .. .
COMPARABLE SALE.1
371 CORNMAN ROAD
CARLISLE, PA
Sale Dale: 03110198
Sale Price: S 65,900
'.. \,......
.;:.;.:.>....r:'
~,~ '
.....' "
'.' ,....
COMPARABLE SALE 112
.....
.
1 CHANNEL DRIVE
CARLISLE. PA
Sale Date: 04109196
Sale Price: $ 73,500
COMPARABLESALEA13
541 CONODOGUINET AVE
CARLISLE, PA
Sale Date: 07/13198
Sale Price: S 79,900
....,A Verschar~n
.....-
"
1.0o.t.TlON MAP
. I, .
BOITOW8(lClifnl: SANDRA L GORHAM
PrQW1v Address: 780 CONODOGUINET AVENUE
j : AR IS
File No,: MG101
C... No,:
:PA
Zi : 17
"
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. 1m I>o~, -._ USA
I!
I:
"
-
A Verscharen
~
5521 RIDGEVIEW DRIVE, HARRISBURG, PA 17112
. '.
8onuWer/Cllent: SANDRA L. GORHAM
~ ~:e..; 760 eONODOOlJlNET AVENUE
I ; AR I E
. fl.OQD MAP
.. .. ..
Slle: P
File No,; MG101
ee.. No,;
ZID: 1701
I
I
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8.
~
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I
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A Verscharen
.....-
5521 RIDGEVIEW DRIVE, HARRISBURG, PA 17112
. . ,
" .. . ' .. . F. No. MG101 . . .
DEFINITION OF MARKET VALUE: Th. mo.' probabl. prle. which. prop.rty .hould bring In . comp.lIt1v. .nd op.n mark.t
undar .11 condllion. r.qui.lI. to . I.ir II'., lh. buy.r .nd liller, neh .ellng prud.ntly, knowl.dgubly .nd ...uming lh. prlc, I. not
.ff.eted by undue IlImulul, Implicit In this d.linlllon I. th. conlumm.tlon 01 . III. II 01. Ip.cill.d dal. .nd the pUling 01 till. Irom
1111.'10 buyer under condillonl wher.by: (1) buyer and ..II.r .r. typlc.lly motlv.t.d: (2) both parll..ar. w.lllnlormod or w.lI.dvllld,
.nd IIch .cllng'ln wh.t h. con.lder. his own b..~ Interest: (3). reuon.blellm. I. .1I0w.d for uposur. in lh. .p.n mark.l: (4) p.ym.nt
is m.d. in terms of ellh In U,S, dollara or In I.rms 01 fln.neial .rrangem.nl. eomp.rabl. Iherelo: and (5) th. price repruenl.lh. normal
con.lderallon lor the property .old unafl.CI!"d by .poeial or crealive financing or salas caneas.ion.' granted by .nyon. u.oeialed wilh the
sal.,
'Adju.lm.nlllo th. eompar.blll mUll b. m.d. for Ip.clal or crullv. financing or lllea cone. ulan., No adjultm.ntl.re n.c.....y for
thosa caot. which are normally paid by IIII.ra IS a rasull 01 tradlllon or law In a markot arll: theso cOltlar. read,ly Id.nllflablo line. tho
seller pay. thu. Call. In vlrlually alllales transacllon., Sp.elal or crullvo financing .dJu.tmont. c.n b. m.d. to Ih. camp.llbl. property
by eomparl.on. 10 linanelng terme offer.d by e third party Inltitullonallender Ihat Is nol elre.dy Involved In the properly or lranlletlon, Any
adJu,'mftnllhould not be c.lculat.d on a mach.nic.1 dollar for dollar co., of Ih. financing 0' conc.sslon bullh. dollar .mount 01 .ny
adju.lmant should approxlmat.lh. market's raaclion to Ih. financlng or conce.sionl ba..~ on th. Apprai..~e Judgmanl.
STATEMENT OF LIMITING CONDITIONS AND APPRAISER'S CERTIFICATION
CONTINGENT AND LIMITING CONDITIONS: Th. epprellll'e certiflcallon thet.ppuraln the eppr.llel r.portII lubJ.ct 10 the
following condilions:
1. Th. apprelll' will not b. r.epon.ibl. for matt.rs 01 a I.gal nalure thallll.cl .lIher Ihe property being apprellld or the tille to ii, The
appral.e, as.umes Ihat the tIlie I. good end mark. table and, Ihar.for., will not r.ndar any opinion. about the 1111., Th. property I. apprail.d
on th. basi. of /I being under respon.ible owner.hip,
2, Th. .ppral..r has provld.d a Iketeh In the appralsa' report to Ihow approxlmat. dim en lions of th. Improv.msnls .nd Ih. Ik.teh I.
includad only to assl.ttha raader 01 Iha ro?Oll In visualizing Ih. property and under.landlng Iha appral.er'. doterminalion 01 It. .iza,
3, Th. appraiser has examined the available flood map. that are provided by the Federal Emergftney Managemanl Agency (or olher data
.ources) and hIS no led in the apprai.al r.port whether Ihe .ubject .It. Is loeal.d in an id.nlifled Spacial Flood Hazard lVea, Beeau.. th.
appraiser Is not a 'UI'Ieyor, he or she mako! no ~'liaranleas, axpr.ss or Implied, reg'''I.~ng t~l. detlrmlnatlOl1,
4, Th. apprai..r will not give lesllmony or appear In court because he or Ihe made an appraisal of the property In que.lIon, unless .peclfle
arrang.m.nt. to do so hay. ba.n made b.forehand,
5, Th. appral..r has ..tlmated the velue of the land In Ihe co. I approach alII. highest and b..1 use end thelmprov.m.nt. allh.lr
contributory valu., Thes. .aparat. veluatlon. 01 the land and Improvements mu.t not be used In conjunellon with any other appraisal and
are Invalid n they are so u..d,
6, The apprals.r hes nOled In the appralsat report any edv.rse condlllon. (.ueh a., needed repairs, depr.elatlon, the presence of hazardous
waste., toxic sub.tane.., .Ie, ) ob.erved during the Inspecllon of thelubjeel property or thel he or .he b.came aware of during the normal
r..eareh involved In p.rforming the appraisal. Unle.. olherwlse stated In Ihe appral.al report, the eppral.er he. no knuwl.dg. of any hidden
or unepparant condition. olth. property or adverse environ menial condition. (Including the presence 01 hazerdo'JI waslll, toxic
.ubatanc.s, etc, ) Ihat would make Ihe prop.rty mar. or I... valuable, and has e"umad Ihat there are no luch condlllon. and make. no
guarant.es or warranll.s, express or Implied, regarding Ihe condition of the properly, Th. appral.er will not be respon.lbla for any luch
conditions that do exlat or for any englne.rlng or tesllng thet might be requlrad to discover wh.ther .ueh condlllon. .xist. Because the
appral..r I. nol an experlln Ihe field of .nvlronmental hazard., the appraisal report musl not be cansld.r.d a. an .nvlronmental a.....m.nt
01 the property,
7, The appral.er oblaln.d Ihe Informallon, esllmates, end oplnlon.lhat were expre.sed in the eppralsel report Irom .ources thai he or she
conald.rs to be r.llable and b.lleve. them to b. true and correct. The eppralsar doe. not ...ume re.pon.lblllly for the accuracy of .uch
item. Ihat were furnish.d by oth.r pertle.,
8, The appral..r will nol dl.elose the eonlenls of the appraisal r.porl except.. provld.d for in Ihe Uniform Slendard. of Professional
Appraisal Practice,
9, The apprals.r has b...d hi. or her appral.al report and valuation conclusion tor an appral.althetI. subject to sall.faetory complellon,
r.pa,s. or altllalions on th. essumplion Ihet complellon of the Improvements will be performed In a workmanllk. manner, '
10, Th. apprelse, must provide his or h., prior wrlllen consent before the lenderlellent specified In the appraisal r.port can dlltrlbule the
appraisal reporl (Including eoneluslona aboutlh. properly value, Ih. appraiser'. Idenllly end prolesslonel deslgnallons, and ref.renees to
any prol.sslonal appraisal organize lions or th. firm with which Ih. appraiser Is associaled ) to anyone olher than Ihe borrower; Ih.
mortgag.. or lis luccessors and assigns; the mortgage In.urer; con.ullant.: professlonel appralsel orgenlzatlons; any slale or I.derally
approved flnanelallnslltutlon; or any department, agency, or inltrumentallty of the United States or any .tate or the Dlslrlet 01 Columbia:
exc.pt that Ihel.nder/cli.nl mey dl.trlbut. the prop.rty description a.ctlon of Ihe r.port only to deta coll.etlon or reporllng s.IYlee(s)
without having to oblaln Ih. appraller'l prior written cons.nl. Th. appralser'a wrlll.n con.enl end approvel must elso be obtained belore
the appral.al ean be eonv.yed by enyon. to th. public Ihrough adv.rllslng, public relations, n.w., sal.., or oth.r media,
Fr.ddle Mac Form 439 6-93
Pagelot2
F.nnle Mae Form lOO4B 6-93
. . . .
I .. It
. .. .
. .. I .
APPRAISERS CERTIFICATION: Tho Apprll.., cortlfteo Ind ogro..thlt:
Folo No, MG10l
" I h.v. r....rch.d Ih. lubj.ct m.rk.l.rll .nd h.v. III.ct.d. minimum 01 thrll flcentlllll or prop.rtlll mOltllmlllr .nd prollm.t.
to Ih. lubjoct proporty lor con.ldor.lion In th. ilia. comporl.on .n.IYI'1 .nd hay. m.d.. dollar 'dju'lm.nt wh.n .pproprlll.to flfl.ctth.
morkot rllclion io tholl lI.ms of Ilgnltic.nl vorl. lion, If a .Ignlflcantll.m In . compor.bl. proporty Is luporlor 10 , or mor. favorlJl. thin,
th. lubj.ct proporly, I havl mad. . n.glllv. Idjullmlntto rlduc. Ih. .dJust.d s.11I prlc. 01 thl compel.bl. .nd, It I slgnlflcantll.m In I
comp.robl. proporly II Inforlor 10, or I... ",or.bl. th.n th. sUbJ.ct proporty, I h.v. m.d. I pOllllv. .dj'lltm.ntto Incr.... Ih. .dJust.d
sal.. prlel of th. comparabl.,
2, I hay, tak.n Inlo conllderlllon the factorl that have an Impact on valu. In my d.v.lopm.nt of Ih. ..limit. 01 mark.t '.Iu. In th.
Ippr.III' roport, I have not knowingly wllhh.ld Iny Ilgnlflcanllnformalion from th. .pprlllll report .nd I b.II"., to th. b..1 of my
knowledg., that.1I stlt.m.nts and Informallon In th. appraisal report are tru. and corr.cl.
3, I Itat.d In lhl appraisal raport only my own perlonal, unblll.d, and prof...lon.1 analysis, opinions, Ind conclusions, which arl lubJICt
only to the conllnglnt and IImlllng condllions Ipecilled In this fctm,
4, I hlv, no prlllnt or prospecllve Interlllln th. proplrly thllllth. lubj.clto Ihll flport, .nd I h.v. no pr'l.nt or prosplctlve porlonll
Intlrlll or bill wllh rllp.ctto thl parllclpanls In Ihl lronSlctlon, I did not b,", .lIher parli.lly or compl'I.ly, my InalYll1 Ind/or lh.
IItlmltl 01 markel valu. In lh. apprslsal report on lh. rac., color, religion, lex, handicap, famlllalltb:US, or nallonal origin Of IlIher th.
prosp.ctlv. owners or occupanll of Ih. subj.ct property or of lh. prll.nt ownerl or occupantl 01 th. propertlll In Ih. vlclnlly of lh.
subjad property,
5, I hay. no preunt or cont.mplal.d fulure Interest In th. subj.ct property, and n.llh.r my current or luture.mploym.nt nor my
c:ompensalion for performing this .ppralsalls conllngent on th. appraised v.lu. of th. property,
8, I Wll not flqulred 10 reporl . pred.termln.d valu. or direction In v.lu. that I.vorl th. C'UII of th. cli.nt or Iny fllat.d party,
Ih. amounl of Ih. valu. eslimat., th. allalnm.nt of a Ip.clflc rllull, or th. occurrence of a lubllqu.nt .v.ntln order to rec.lv. my
comp.nsatlon andlor .mploym.nt for parformlng th. appraisal, I did not base th. appraisal report or. a request.d minimum valuation, a
specific valuation, orlh. nlld to approve a specific mortgag.loan,
7, I perform.d thll appraisal In conformlly with th. Uniform Standards of Professional Appraisal Practlc. that w.r. adopt.d .nd
promulg.t.d by Ih. Appraisal Standards Board of Th. Appraisal Foundalion .nd Ihal were In plac. .. of th. .ff.cllv. dat. of Ihls appralSlI,
with Ih. exc.plion of th. deparlure provision of those St.ndards, which does not apply, I acknowl.dg. (hat .n eslimat. of a flasonabl.
tlm. for exposura In Iha opan markatls a condition In tha daflnlllon of mark.t valu. and th. eslimat. I dav.lop.d II conslslent wllh th.
mark.tlng lime noted In the neighborhood section of Ihls report, unless I have olhllWlse stal.d In the reconciliation sadlon.
8, I have personally Inspected th. Interior and exterior areas of the subject property and th. exlerlor of all propertlesllsled es comperables
In Ihe appraisal reporl. I furlhar certlly that I have nolad any apparenl or known adverse condlllons In th. lubJectlmprovementl, on the
subj.ct IlIe, or on any sill wllhln thelmm.dlal. vlclnlly Of the subj.ct property 01 which I .m aware and have mad. adjuslments fot lhes.
adversa condlllons In my analysis 01 lh. property valu. to Ih. ext.nllhal I had markel evld.nc. to supportth.m, I hava also comm.nt.d
about the ."act of Ihe adverse conditions on the markatabllily Of tha subjact property.
9, I personally prepared all co~cluslons and opinions about Iha real IItala Ihal ware sat forth In Iha appraisal rap or I. If I rell.d on
slgnlficanl profesSional asslstanca from any Individual or Individuals In lh. parformanca of the appraisal or Ih. praparallon of Ihe Ippralsll
reporl, I have nam.d luch Indlvldual(l) and dlsclosld Iha spaclflc tasks performed by lhem In th. reconclllallon secllon 01 this Ipprllsal
raporl. I certify that any Individual so nam.d Is quallfled to parform the tasks, I hay. not authorized inyone to make a change to Iny 111m In
the report; therefora, It an unauthorized changals madato the appraisal report, I will taka no responsibility for It.
SUPERVISORY APPRAISER'S CERTIFICATION: III suplrvlsory Ippralser Ilgned th. Ippralsal tlpott, he ot ah. cerllfles
and agreas Ihlt: I dlrlctly suplrvlsa the appraiser who prlparld Iha appraisal raport, havl reviewed Ihe appraisal raport, agree wllh lhl
slatlmenta and concluslona Of th. appraiser, Igrla 10 be bound by Iha appralsar's certlflcallons numblred 4 through 7 Ibove, and 1m taking
full responsibility forthl appraisal and the appraisal rlport.
ADDRESS OF PROPERTY APPRAISED: 760 CONODOGUINET AVENUE, CARLISLE, PA 17013
APPRAISER:
S~nlt~l: ~RJ4
Name: JOHN ,VERSCHAREN - -
Dall S~ned: NOVEMBER 06, 1998
Slall Certlficallon ,: RL.OOI977,L
or State Llelnaa ,:
State: PA
Exprallon Dale of Certlficalion or Llelnaa: 06/30/99
SUPERVISORY APPRAISER (only I' required)
S~nalure:
Name:
Dati S~ned:
Slate Certlficallon .:
or Stal. L1canse .:
Stale:
Exprallon Data of ellllficallon or Llelnse:
o Old 0 Old Nollnspld P\'operty
RL-001977-L
Freddie Mac Form 439 8.93
Page 2 of 2
Finnie Ma. Form lOO4B 8-93
JOHN H, BIOU)OS
HlJIOIIT X, GIUlDY
BROUJOS & GILROY, r, c.
ATroRNEYS AT LAW
. NORTII HANOVER STREET
CARUSLB, PENNSYLVANIA 17013
T\!W'IIONB: (717) 243-4574
PAC""'LB: (717) 243-8227
INI1IllNn, b,gllroypcOaol ,com
NON-TOlL I'Oll HAlWSBURG ADA
717.766-1690
t(Q)[PY
June 14, 1999
Mindy S. Goodman, Esq.
2080 L1nglestown Road
Harrisburg, P A 17110
Re: Gorham
Dear Mindy:
Mr. Gorham will settle the case at the S 1 0,000.00 figure. He will need time to make
arrangements to refinance,
Based upon our agreement, I ask that the Master generally continue proceedings In this
case for 30 days to give us an opportunity to finalize the terms of the agreement. Please
proceed with preparing a property settlement agreement.
I am copying Mr. Elicker with this letter so he Is aware of our potential for settlement and,
by copy of this letter, I am requesting that our requirement to file a pre-trial statement be
suspended at this point.
I look forward to hearing from you.
Sir
Hubert X. GlIroy
dch
cc: James Gorham
E. Robert Elicker
SANDRA L, GORHAM,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 97 - 5945 CIVIL
JAMES G. GORHAM,
Defendant
IN DIVORCE
ORDER O~OURT
AND NOW, this Jt;
of PJIlf
day
,
1999, the economic claims raised in the proceedings having
been resolved in accordance with a property settlement
agreement dated August 31, 1999, the appointment of the
Master is vacated and counsel can file a praecipe
transmitting the record to the Court requesting a final
decree in divorce.
BY THE COURT,
cc:
Mindy S. Goodman
Attorney for Plaintiff
P.J,
Hubert X. Gilroy
Attorney for Defendant
- e.c-f:....~ I)oL"~d
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A 'ft- J~ 46
C;.() rM.W'-
d ~ortttlH'\
PROPERTY SETTLEMEln AGREEMENT
.) /.1 .J I
THIS AGREEMENT, made this ,) day of , '1'1.. '. ' ,
,
1999, between SANDRA L. GORHAM, hereinafter called "WIFE" and JAMES G.
GORHAM, JR., hereinafter called "HUSBAND,"
WITNESSETH:
The parties hereto, being HUSBAND and WIFE, were lawfully married on
May 5, 1986 in Carlisle, Cumberland County, Pennsylvania;
There were no children born of the parties; and
WIFE is represented by Mindy S, Goodman, Attorney at Law, and
HUSBAND is represented by Hubert X, Gilroy, Attorney; and
Diverse and unhappy differences have arisen between the parties, and It
is the intention of HUSBAND and WIFE to separate for the rest of their natural
lives, and the parties hereto are desirous of settling fully and finally their
respective financial and property rights and obligations as between each other
including, without limitation by specification: the settling of all matters between
them relating to the ownership and equitable distribution of real and personal
property; the settling of all matters between them relating to the past, present and
future support, alimony and/or maintenance of each other; and in general, the
settling of any and all claims and possible claims by one against the other or
against their respective estate,
NOW THEREFORE, in c.onsideration of the mutual promises, covenants
and undertakings hereinafter set forth and for other good and valuable
consideration, receipt of which is hereby acknowledged by each of the parties
hereto, HUSBAND and WIFE, each intending to be legally bound hereby,
covenant and agree as follows:
1. INCORPORATION OF PREAMBLE
The recitals $et forth in the Preamble of this Agreement are Incorporated
herein and made a part hereof as if fully set forth in the body of the Agreement.
2. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS
This Agreement shall not be considered to affect or bar the right of
HUSBAND and WIFE to an absolute divorce on lawful grounds if 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
condonation on the part 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 or may occur subsequent to the date hereof, The parties
acknowledge that their marriage is irretrievably broken and that they shall secure
a mutual consent no-fault divorce pursuant to the terms of Section 3301 (c) of the
Divorce Code in a Dauphin County divorce action, The parties shall execute
Affidavits of Consent upon the expiration of the mandatory gO-day waiting period.
2
3. EFFECT OF DIVORCE DECREE
The parties agree that unless otherwise specifically provlded.,erein, this
Agreement shall continue in full force and effect after such time as a final Decree
in Divorce may be entered with respect to the parties,
4. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE
The parties agree that the terms of this Agreement shall be incorporated
Into any Divorce Decree that may be entered with respect to them,
6. NON-MERGER
It Is the parties' intent that this Agreement does not merge with the
Divorce Decree, but rather shall continue to have independent contractual
significance, Each party maintains his or her contractual remedies as well as
court ordered remedies as the result of the aforesaid incorporation or as
otherwise provided by law or statute, Those remedies shall include, but not be
limited to, damages, resulting from breach elf this Agreement, specific
enforcement of this Agreement, and remedies pertaining to failure to comply with
an order of court or agreement pertaining to equitable distribution, alimony,
alimony pendente lite, counsel fees and costs as set forth in the Pennsylvania
Divorce Code or other similar statutes now in effect and as amended or hereafter
enacted,
3
8. DATE OF EXECUTION
The "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. WAIVER OF APPRAISAL AND INVENTORY
The parties acknowit:ldge and ayree that HUSBAND and WIFE have each
made a full and complete disclosure to the other of all information pertaining to
the parties' separate and marital property owned, possessed and/or controlled by
the other party at the time of separation, HUSBAND and WIFE have each had
an opportunity to value or have appraised any and all marital property, and they
do hereby waive a formal appraisal and inventory of same, and no statemfillt or
representation by either party as to value shall be deemed a misstatement or
misrepresentation to the other or be deemed fraudulent.
8. SEPARATION
It shall be lawful for each party at all times hereafter to live separate and
apart from the other party, at such place or places as he or she from tire to time
may choose or deem fit.
9. NONINTERFERENCE
Each party shall be free from interference, authority and control, direct or
indirect, by the other in all respects as fully as if he or she were single and
~
unmarried, Each may, for his or her leparate use or benefit, conduct, carry on
and engage In any business, occupation, profession or employment which to him
or her may leem advisable, Neither party shall molest, harass, disturb or malign
the other nor the family of said other, nor compel or attempt to compel the other
to cohabit or dwell with him or her,
10. MUTUAL RELEASES
HUSBAND relinquishes his inchoate intestate right In the estate of WIFE,
and WIFE relinquishes her inchoate intestate right in the estate of HUSBAND,
and each of the parties hereto by these presents, for himself or herself, his or her
heirs, executors, administrators or assigns, does remise, release, quitclaim, and
forever discharge the other party hereto, his or her heirs, executors,
administrators or assigns, or any of them, of and from any and all claims in the
nature of dower and curtesy or widow'sj' 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 as testamentary, or all
other rights of a surviving spouse to participate in a deceased spouse's estate,
whether arising under the laws of the Commonwealth of Pennsylvania or any
other state or any country, as well as any and all other claims, demands,
damages, actions, causes of actions, or suits at law or in equity, of whatsoever
kind or nature, for or because of any matter or thing done, omitted, or suffered to
be done by said party prior to and including the date hereof: except that this
5
release shall in no way exonerate or discharge either party hereto from the
obligations and promises made and imposed by reason of this Agreement, and
shall in no way affect any cause of action in absolute divorce which either party
may have against the other party,
11. MARITAL AND NON-MARITAL PROPERTY
HUSBAND and WIFE do hereby acknowledge that they have heretofore
divided the marital and non-marital assets including but without limitation,
business interests, jewelry, clothes, furniture, stocks, bonds, pensions and other
assets wherever situated whether real, personal or mixed, tangible or intangible,
and HUSBAND agrees that all assets in the possession of WIFE shall be the sole
and separate property of WIFE; and, WIFE agrees that all assets in the
possession of HUSBAND shall be the sole and separate property of HUSBAND.
Each of the parties does hereby specifically waive, release, renounce and forever
abandon whatever claims, if any, he or she may have with respect to any of the
above said items which are the sole and separate property of the other,
12, REAL ESTATE
The parties have one jointly owned property located at 760 Conodoguinet
Avenue, Carlisle, Pennsylvania, HUSBAND shall assume sole and separate
liability for the unpaid balance on any and all mortgages, liens and judgments
and delinquent taxes on the property and said property shall become the sole
6
and separate property of HUSBAND, WIFE hereby relinquishes any right, title,
and/or Interest she may have in the property located at 760 Conodoguinet
Avenue in Carlisle,
Within a reasonable time, but in no event later than sixty (60) days from
the date of execution of this Agreement, HUSBAND shall secure refinancing and
remove WIFE'S name from the mortgage and other obligations for the property,
In connection therewith, WIFE will execute any and all deeds, documents, or
papers provided by HUSBAND'S attorney necessary to transfer her interest in
said property to HUSBAND,
13. LUMP-SUM PAYMENT TO WIFE
HUSBAND shall pay to WIFE the sum of TEN THOUSAND ($10,000.00)
DOLLARS and 00/100, This sum shall be paid in a lump sum within thirty (30)
days of the date of execution of this Agreement.
14, DEBTS
Other than the mortgage and other liens and judgments against the jointly
owned real property, which are handled elsewhere in this Agreement, there are
no obligations remaining in joint names, There are no other joint obligations
remaining between the parties, and no other obligations have been incurred for
which the other would be liable, Each of the parties hereto covenants and
agrees to assume full responsibility for and to pay all debts and obligations of
7
whatsoever kind or nature incurred individually and by that party prior to the day
and date of this Agreement, and each of the parties hereto hereby covenants and
agrees to Indemnify and defend the other party and hold him or her harmless
from all liability or claim on account of said debts and obligations from and after
the date hereof,
Any and all credit card accounts in jOint names shall be closed, and all
joint checking and savings accounts shall similarly be closed, Each party has the
right to open new accounts in each party's individual name,
15. PENSIONS
Each party hereby waives any and all claims that he or she may have
against the other to any pension, employee saving or other stock benefit program
of the other, if applicable, Each party Rhall execute the paperwork necessary to
relinquish his or her interest in any pension, employee saving or other stock
benefit program of the other.
16. FUTURE OWNERSHIP OF PROPERTY
Each of the parties hereto may hereafter own and enjoy, independently of
any claimG or rights of the other, all items of personal and real property, tangible
or intangible, hereafter acquired by him or her, with full power in him or her to
dispose of the same as fully aild effectively in all respects and for all purposes as
though he or she were unmarried,
8
17. MUTUAL RELEASES
The parties hereto acknowledge that under prevailing Pennsylvania law
'they each have certain possible fiscal rights, including but not limited to the
following: spousal support, alimony pendente lite in the event of a divorce,
permanent alimony subsequent to a divorce, recovery of counsel fees, costs and
expenses in the event of a divorce, and the equitable distribution of marital
property, as well as the right to seek discovery of assets through interrogatories
and/or depositions. It is the intention of the parties hereto that except as
otherwise provided herein, all of the foregoing rights and remedies are hereby
waived and forever released and that this Agreement shall have the effect of a
final Order of Court relieving each party of the obligation to the other for any and
all of the foregoing possible rights and remedies, except as otherwise provided
herein. Specifically, both partiE'ls covenant and agree that: both waive, release
and forever relinquish their respective possible rights of spousal support of, from
and against the other party; neither party will at any time seek alimony pendente
lite, alimony, counsel fees, costs or expenses from the other party; neither party
will seek discovery of assets; and the parties have effected an equitable
distribution of their marital property and neither will seek further distribution by
any action at law or in equity.
9
22. AGREEMENT VOLUNTARILY AND CLEARLY UNDERSTOOD
Each party to this Agreement acknowledges and declares that he or she
respectively:
a. Is fully and completely informed as to the facts relating to the
subj~ct matter and their Agreement as the rights and liabilities of both parties;
b. Has given careful ond mature thought to the making of this
Agreement;
c. Has carefully read each provision of this Agreement;
d. Fully and completely understands eacn provision of this
Agreement, both as to the subject matter and legal affect;
e. Enter into this Agreement voluntarily after receiving the advice of
counsel.
23. AMENDMENT OR MODIFICATION
This Agreement may be amended or modified only by a written instrument
signed by both parties.
24. SEVERABILITY
If any term, condition, clause or provision of this Agreement shall be
determined or declared to be void or invalid in law or otherwise, then only that
term, condition, clause or provision shall be stricken from this Agreement and in
all other respects this Agreement shall be valid and continue in full force, effect
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