HomeMy WebLinkAbout98-00868
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ROBERT V. LIMRIC,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
vs.
NO. 98 - 868 CIVIL
CONNIE L. LIMRIC,
Defendant
IN DIVORCE
ORDER OF COURT
AND NOW, this
177"'-
day of ,<<ile-C.e/n~
2001, the economic claims raised in the proceedings having
been resolved in accordance with a marital settlement
agreement dated December 13, 2001, 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,
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Robert V. Limric (\o-p.U.o ..({')~S. ~
Plaintiff L- I; ~~5
Nora F. Blair 1~.-/7'C>'. \.
Attorney for Defendant
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MARITAL SETrLEMENT AGREEMENT
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AGREEMENT, made this I.) - day of ,'-. '.< 1'__/'
, 2001, by and
between ROBERTV. LIMRIC, hereinafter referred to as "Husband", and CONNIE
L. LlMRIC, hereinafter referred to as 'Wife".
WITNESSETH:
WHEREAS, the parties hereto are Husband and Wife, having been married
on December 31, 1978;
WHEREAS, the parties hereto separated on or about December 13, 1997;
WHEREAS, there were two children born during this marriage, Tanya D.
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Limric, born June 20, 1981; and Jesse R. Limric, born August 28, 1982; and
WHEREAS, diverse unhappy differences, disputes and difficulties have
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arisen between the parties, and it is the intention of Husband and Wife to live
separate and apart for the rest of their natural lives, and the parties hereto are
desirous of settling fully and fmally their respective financial and property rights
and obligations as between each other, including, without limitation by
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specification: the settling of all matters between them relating to the ownership
of real and personal property, the equitable distribution of such property; the
settling of all matters between them relating to the past, present and future
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support and/or maintenance of Wife by Husband or of Husband by Wife; and, in
general, the settling of any and all claims and possible claims by one against the
other or against their respective estates.
NOW, THEREFORE, in consideration of the premises and of the mutual
promises, covenants and undertakings hereinafter set forth and for other good
and valuable considerations, 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. AGREEMENT N<Yl' A BAR TO DIVORCE PROCEEDINGS. This
Agreement shall not be considered to affect or bar the right of Husband or
Wife to a divorce on lawful grounds 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 a
condonation on the part of either party hereto of any act or acts on the part
of the other party which have occurred prior to or which may occur
subsequent to the date hereof.
2. EFFECr OF DIVORCE DECREE. The parties agree that, unless otherwise
specifically provided herein, this Agreement shall continue in full force and
effect after such time as a final decree in divorce may be entered with
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respect to the parties. It is the intent of the parties hereto that this
Agreement shall create contractual rights and obligations entirely
independent of any Court Order and that this Agreement may be enforced
by contract remedies in addition to any other remedies which may be
available pursuant to the terms of this Agreement or otheIWise under law
or equity.
3. AGREEMENT TO BE INCORPORATED INTO DIVORCE DECREE. The
parties agree that the terms of this Agreement shall be incorporated, but not
merged, into any divorce decree which may be entered with respect to
them. The parties further agree that the Court of Common Pleas which may
enter such divorce decree shall retain continuing jurisdiction over the
parties and the subject matter of this Agreement for the purpose of
enforcement of any of the provisions thereof.
4. DATEOFEXECUTION. The "date of execution" or "execution date" of this
Agreement shall be defined as the date upon which it is executed by the
parties if they have each executed this Agreement on the same date.
OtheIWise, 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.
5. ADVICE OF COUNSEL. The provisions of this Agreement and their legal
effect have been fully explained to Wife by her attorney, Nora F. Blair,
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Esquire. Husband has been advised of and understands his right to seek
legal counsel to explain the provisions of this Agreement and their legal
effect. Husband voluntarily waives his right to legal counsel. The parties
acknowledge that they fully understand the facts and have been fully
informed as to their legal rights and obligations, and they acknowledge and
accept that this Agreement is, in the circumstance, fair and equitable and
that it is being entered into freely and voluntarily, after having received
such advice and with such knowledge and that execution of this Agreement
is not the result of any duress or undue influence and that it is not the
result of any collusion or improper or illegal agreement or agreements. The
parties further acknowledge that they have each made to the other a full
and complete disclosure of their respective assets, estate, liabilities, and
sources of income and that they waive any specific enumeration thereof for
the purposes of this Agreement. Each party agrees that he and she shall
not, at any future time, raise as a defense or otherwise the lack of such
disclosure in any legal proceeding involving this Agreement, with the
exception of disclosure that may have been fraudulently withheld. The
parties further acknowledge that as a part of the settlement negotiations
between the parties, each party has disclosed to the other party all assets
owned by the disclosing party having a value in excess of five hundred
dollars ($500.00) and further that neither party has failed to disclose assets
having a total value of more than two thousand dollars ($2,000.00).
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6. PERSONAL WGIfl'S. Husband and Wife, at all times hereafter, may and
shall live separate and apart. They shall be free from any control, restraint,
interference or authority, direct or indirect, by the other in all respects as
fully as if they were unmarried. They may reside at such place or places as
they may select. Each may, for his or her separate use or benefit, conduct,
carry on and engage in any business, occupation, profession or employment
which to him or her may seem advisable. Husband and Wife shall not
molest, harass, disturb or malign each other or the respective families of
each other or compel or attempt to compel the other to cohabit or dwell, by
any means or in any manner whatsoever, with him or her.
7. SUBSEQUENT RECONCll.JATION. The parties agree that the terms of
this Agreement shall not be affected by their subsequent cohabitation or
resumption of marital relations, unless the parties otherwise specifically
agree in writing.
8. MUTUAL RELEASES. Husband and Wife each do hereby mutually remise,
release, quitclaim and forever discharge the other and the estate of the
other, for all time to come, and for all purposes whatsoever, of and from any
and all rights, title and interests, or claims in or against the property
(including income and gain from property hereafter accruing) of the other
or against the estate of such other, of whatever nature or wheresoever
situate, which he or she now has or at any time hereafter may have against
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the other, the estate of the other or any part thereof, whether arising out of
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any former acts, contracts, engagements or liabilities of the other or by way
of dower or curtesy, or claims in the nature of dower or curtesy or widow's
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or widower's rights, family exemption or similar allowance, or under the
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intestate laws, or the right to take against the spouse's will; or the right to
treat a lifetime conveyance by the other as testamentary, or all other rights
ofa surviving spouse to participate in a deceased spouse's estate, whether
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arising under the laws of Pennsylvania, any State, Commonwealth or
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territory of the United States, or any other country, or any rights which
either party may have or at any time hereafter shall have for past, present
or future support or maintenance, alimony, alimony pendente lite, counsel
fees, property division, costs or expenses, whether arising as a result of the
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marital relation or otherwise, except, all rights and agreements and
obligations of whatsoever nature arising or which may arise under this
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Agreement or for the breach of any provision thereof. It is the intention of
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Husband and Wife to give to each other the execution of this Agreement a
full, complete and general release with respect to any and all property of any
kind or nature, real, personal or mixed, which the other now owns or may
hereafter acquire, except and only except all rights and agreements and
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obligations of whatsoever nature arising or which may arise under this
Agreement or for the breach of any provision thereof. It is further agreed
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in Husband's 401(k) account with Mold Base Industries shaH be Husband's
sole and separate property. Husband and Wife each agree that al1 accounts
that are joint with one or both of the parties and one or both of the parties'
children shall be the sole and separate property of the parties' child(ren)
whose narne(s) appear(s) on the account. Husband and Wife each assert that
neither has removed funds or will remove funds in the future from any
account titled solely to one or both of the parties' children or jointly with
one or both of the parties and one or both of the parties' children except that
Husband did remove funds from the DeCathur Fund that he held jointly
with the parties' daughter. Upon request of one of parties' children,
Husband and Wife each agree to remove their name trom any accounts held
jointly with Husband and/or Wife and that child. Both parties agree to
execute any documents necessary to effectuate this paragraph.
10. PERSONAL PROPERTY. Husband and Wife have accumulated various
tangible personal property including, but without limitation, jewelry,
clothes, furniture, furnishings, rugs, carpets, household equipment and
appliances, pictures, books, works of art and other personal property. The
parties have divided their personal property to the satisfaction of both
parties. Each party shall retain as their sole and separate property their
clothing, jewelry and other items of personalty. The parties do hereby
specifically waive, release, renounce and forever abandon whatever claim,
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claims arising out of Wife's failure to make payments as specified in this
paragraph. Each party agrees to execute all documents necessary to
implement this paragraph. Wife shall claim the mortgage interest and real
estate taxes for federal tax purposes for 2001 and subsequent years.
13. VEIDCLES. The parties are the owners of five vehicles. The 1995 Ford
Explorer with light bar shall be Wife's sole and separate property. The 1997
Ford Ranger and the Polaris six-wheel all terrain vehicle (including the
trailer) shall be Husband's sole and separate property. Husband shall be
solely responsible for the payment of any loan on his vehie1es. Husband
agrees to indemnify and hold Wife harmless for and against any and all
claims arising out of Husband's failure to make payments as specified in
this paragraph. The 1986 Plymouth Horizon shall be the sole and separate
property ofthe parties' son and daughter. The Polaris four-wheel all terrain
vehicle shall be the sole and separate property of the parties' son. Husband
agrees to return said vehicle to the parties' son within ten (10) days of the
date of this Agreement. Each party agrees to execute all documents
necessary to implement this paragraph within thirty (30) days of the date of
this Agreement and return all property as indicated in this paragraph
within said time period.
14. LIFE INSURANCE. The parties are the owners of various life insurance
policies. The life insurance policies shall be the sole and separate property
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of the insured, except as indicated below. There is a mortgage life
insurance policy on the life of Husband that will pay the mortgage balance
in full in the event of Husband's death. Husband agrees that Wife shall be
the owner and beneficiary of said policy. Wife shall make all payments on
said policy for so long as she wishes to have the policy remain in effect. In
addition Husband agrees that Wife may purchase life insurance on his life
for the sole purpose and in an amount of no more than is sufficient to cover
any alimony payments still due and owing to Wife in the event of Husband's
death. Husband agrees to cooperate in any required medical exams and to
complete any necessary papeIWork for Wife to obtain said insurance. Wife
shall be the owner and beneficiary of said policy and shall pay all premiums
on said policy.
15. CURRENT LIABILITIES. The parties have accumulated various debt
during the marriage. Wife shall be solely responsible for the payment of
any and all debt that is in her name. Husband shall be solely responsible
for payment of any and all debt that is in his name. The parties agree that
the Certificate of Deposit at Pennsylvania Central Federal Credit Union
shall be used to pay the loan that it secures. The balance of funds
remaining after the payment of said loan shall be the sole and separate
property of Wife. Husband and Wife have either canceled or divided all
jointly held credit cards, and they shall be fully and solely responsible for
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the credit cards, other debts and loans as stated above. Except 1111 othclwlllc
specifically stated in this Agreement, Husband shaH be entirely Ilnd lIoll!ly
liable for any past, present and future balances due on hili credit cllrd/l,
other debts and loans of any nature whatsoever, and he /lhllll l\lIly
indemnify Wife with regard to same. Except as othClwise speclficllHy /ltllted
in this Agreement, Wife shall be entirely and solely llllble for IIny pllllt,
present and future balances due on her credit cards, other debtllllnd 10llnll
of any nature whatsoever, and she shall fully indemnify HUllbllnd with
regard to same. If either party incurs any debt on a credit cllrd titled to both
parties after the date of the parties' separation, the party milking the charge
shall be solely responsible for payment of the charge amount and any
accumulated interest. Each party agrees to indemnify and hold the other
party harmless for and against any and all claims arising out of the pllrty's
failure to make payments as specified.
17. TAX CONSEQUENCES: The parties believe and agree, IInd have been so
advised by their respective attorneys, if any, that the division of property
heretofore made in this Agreement is a non-taxable division of property
between co-owners rather than a taxable sale or exchange of such property.
Neither party will take any positions, on his or her federal or state income
tax returns, with respect to the adjusted basis of the property assigned to
him or her, or with respect to any other issue, which is inconsistent with the
position set forth in this Agreement.
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18. TAX RETURNS. The parties agree that in the event any deficiency in
federal, state or local income tax is proposed or any assessment of any such
tax is made against either party in connection with the filing of a joint
federal, state or local income tax return for prior years, the parties shall
equally share any loss or liability in connection with such tax deficiency,
including counsel fees and such tax, interest, penalty or expense associated
therewith, unless and only unless said tax, interest, penalty or expense is
finally determined to be attributable to misrepresentations or failure to
disclose the nature and extent of either party's separate income on joint
returns, in which case any and all liability, cost or expense shall be the sole
responsibility ofthe party responsible for the misrepresentation or failure
to disclose the nat.ure and extent of separate income.
19. WAIVER OF PAYMENT OF LEGAL FEES. Wife shall be solely responsible
for payment of her legal fees. Husband shall be solely responsible for
payment of his legal fees. Each party waives the right to have the other
party pay any of their legal fees or costs.
20. ALIMONY AND ALIMONY PENDENTE LITE. The parties agree that all
spousal support and alimony pendente lite obligations shall cease as of the
date that the divorce decree is entered. The arrears owing shall stand but
shall not be a basis for a contempt or enforcement action and shall be
payable upon the termination of all alimony payments as set forth below.
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Wife agrecs not to initiatc, and shall request that the Ofl1ce of Domcstic
Relations not initiate, a contempt or enforcement proceeding provided that
the arrears balance does not increase over the current balance. Wife waives
her right to spousal support and alimony pendente lite as of the date of the
divorce decree. Husband agrees to pay to Wife alimony as set forth below.
The parties agree that said alimony shall be effective on the date the
Divorce Decree is entered, shall terminate upon the death of either party,
shall be deductible by Husband on his federal income tax return and shall
be included in Wife's gross income for federal income tax purposes. The
parties further agree that the alimony payments as set forth below shall be
non-modifiable by either party. Husband agrees to pay alimony to Wife of
One Thousand Nineteen Dollars ($1,019.00) per month payable through the
Cumberland County Domestic Relations Office (PaSCDU) from the date of
entry of the Divorce Decree until June 30,2014. Said amount shall be paid
whether Wife cohabitates or remarries or not and shall terminate prior to
June 30, 2014 only upon the death of either party.
21. DIVIDEDASSEITS. The parties agree to divide all of their assets including
but not necessarily limited to real estate, financial accounts, cash,
retirement funds, motor vehicles, personal effects and household contents
as set forth in this Agreement. Husband and Wife hereby assign all of their
respective rights, title and interest to the other as to the divided assets as
set forth in this Agreement. Husband shall be the sole and exclusive owner
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of such assets as divided herein and designated ('01' Husband. Wife shull be
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the sole and exclusive owner of such assets as divided herein IInd
designated for Wife.
22. PROl'ECrIONFROMABUSE. Wife currently has a Protection from Abuse
Order against Husband. Wife agrees to cooperate with Husband in
obtaining his gun permits and any guns or other weapons being held by the
Cumberland County Sheriffs Office. The parties agree that the Protection
from Abuse Order will remain in full force and effect until the end of the
term of the Order, but that the gun permits and weapons may be returned
to Husband at any time after the signing of this Agreement.
23. MUTUAL CONSENT DIVORCE. The parties agree and acknowledge that
their marriage is irretrievably broken, that they do not desire marital
counseling, and that a complaint in divorce has been filed in Cumberland
County at number 98-868-Civil. The parties agree to have the divorce decree
entered in that case pursuant to Section 3301(c) of the Pennsylvania Divorce
Code, Act 26 of 1980, as may be amended (herein referred to as the Code).
Accordingly, both parties agree to execute such stipulations, consents,
affidavits, or other documents and to direct their respective attorneys, if
any, to forthwith file such stipulations, consents, affidavits, 01' other
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documents as may be necessary to proceed to obtain a divorce pursuant to
said Section 3301(c) of The Code. Specifically Husband and Wife will each
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sign an Affidavit of Consent and Waiver of Notice of Intention to Request
Entry of Divorce Decree at the time of signing this Agreement and Wife
agrees to direct her attorney to file all documents to obtain the divorce
decree as quickly as possible. Upon request, to the extent permitted by law
and the applicable Rules of Civil Procedure, the named defendant in such
divorce action shall execute any waivers of notice or other waivers necessary
to expedite such divorce.
24. WARRANTY AS TO EXISTING OBLIGATIONS. Each party represents
that they have not heretofore incurred or contracted for any debt or liability
or obligations for which the estate of the other party may be responsible or
liable, except as may be provided for in this Agreement. Each party agrees
to indemnifY and hold the other party harmless for and against any and all
such debts, liabilities or obligations of every kind which may have
heretofore been incurred by them, including those for necessities, except
for the obligations arising out of this Agreement.
25. WARRANTY AS TO FUTURE OBLIGATIONS. Husband and Wife each
covenant, warrant, represent and agree that, with the exception of
obligations set forth in this Agreement, neither of them shall hereafter
incur any liability whatsoever for which the estate of the other may be
liable. Each party shall indemnity and hold harmless the other party for
and against any and all debts, charges and liabilities incurred by the other
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after the execution date of this Agreement, except as may be othelwise
specifically provided for by the terms of this Agreement.
26. WAIVER OR MODIFICATION TO BE IN WRITING. No modification or
waiver of any of the terms hereof shall be valid unless in writing and signed
by both parties, and no waiver of any breach hereof or default hereunder
shall be deemed a waiver of any subsequent default of the same or similar
nature.
27. MUTUAL COOPERATION. Each party shall, at any time and from time to
time hereafter, take any and all steps and execute, acknowledge and deliver
to the other party any and all further instruments and/or documents that
the other party may reasonably require for the purpose of giving full force
and effect to the provisions of this Agreement.
28. LAWS OF PENNSYLVANIA APPLICABLE. This Agreement shall be
construed in accordance with the laws of the Commonwealth of
Pennsylvania which are in effect as of the date of execution of this
Agreement.
29. AGREEMENT BINDING HEIRS. This Agreement shall be binding and
shall inure to the benefit of the parties hereto and their respective heirs,
executors, administrators, successors and assigns.
30. OTHER DOCUMENTATION. Husband and Wife covenant and agree that
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they will forthwith (and within no more than ten (10) days after demand
therefor) execute any and all written instruments, assignments, releases,
satisfactions, deeds, notes or such other writings as may be necessary or
desirable for the proper effectuation of this Agreement and make any
transfers of property required to be made by this Agreement within ten (10)
days of a request to do such.
31. NO WAIVER OF DEFAULT. This Agreement shall remain in full force and
effect unless and until terminated under and pursuant to the terms of this
Agreement. The failure of either party to insist upon strict performance of
any of the provisions of this Agreement shall in no way affect the right of
such party hereafter to enforce the same, nor shall the waiver of any default
or breach of any provision hereof be construed as a waiver of any
subsequent default or breach of the same or similar nature, nor shall it be
construed as a waiver of strict performance of any other obligations herein.
32. ENFORCEMENT OF AGREEMENT. If either party breaches any provision
of this Agreement, the other party shall have the right, at his or her election,
to sue for damages for such breach or to require specific performance. The
party breaching this Agreement shall be responsible for payment of legal
fees and costs incurred by the other party in enforcing their rights under
this Agreement or for seeking such other remedies of relief as may be
available to him or her.
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33. SEVERABll.J.TY. If any term, condition, clause or provision of this
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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 and operation. Likewise, the
failure of any party to meet her or his obligations under anyone or more of
the paragraphs herein, with the exception of the satisfaction of the
conditions precedent, shall, in no way, void or alter the remaining
obligations of the parties.
34. HEADINGS Nor PART OF AGREEMENT. Any headings preceding the
text of the several paragraphs and subparagraphs hereof are inserted solely
for convenience of reference and shall not constitute a part of this
Agreement, nor shall they affect its meaning, construction or effect.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals
the day and year first above written.
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ROBERT V. LIMRIC
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
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On this, the ) s,f5 day of \,"\J ".. P,
, 2001, before me, a Notary
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Public for the Commonwealth of Pennsylvania, personally appeared ROBERT V.
LIMBIC, known to me to be the person whose name is subscribed to the within
Agreement, and acknowledged that he executed the same for the purposes therein
contained.
IN WITNESS WHEREOF, I have hereunto set ~ hand and official seal.
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
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On this, the 12 - day of ,.:; " ~ / t?~_ ,2001, before me a Notary
Public of the Commonwealth of Pennsylvania personally appeared CONNIE L.
LIMRIC, known to me to be the person whose name is subscribed to the within
Agreement, and acknowledged that she executed the same for the purposes
therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
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ROBERTV. LIMRIC,
Plaintiff
: IN THE COURT OF COMMON PLEAS,
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 98-868-C1Vll..
v.
CONNIE L. LIMRIC,
Defendant
: CIVll..ACI'ION - LAW IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
UNDER ~ 3301(c) OF THE DIVORCE CODE
To the Prothonotary:
Transmit the record, together with the following information, to the Court for
entry of a divorce decree:
1. Ground for divorce: irretrievable breakdown under ~ 3301(c) of the Divorce
Code.
2. Date and manner of service of the complaint:
(a) Date of service: February 23, 1998.
(b) Manner of service: Acceptance of Service
3. Date of execution of the affidavit of consent required by ~ 330l(c) of the
Divorce Code:
(a) By the Plaintiff: December 13, 2001
(b) By the Defendant: December 7, 2001
4. Date of execution of Waiver of Notice of Intention to File Praecipe to
Transmit Record:
(a) By the Plaintiff: December 13, 2001
(b) By the Defendant: December 7, 2001
5. Related claims pending: NONE
DATED: December 13, 2001
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o F. Blair, Esquire
Attorney for Defendant
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R013ER~' V. LIMRIC,
Plaintiff
IN nlE COURT OF COMMON pr"EAS
CUM13ERLAND COUNTY, PENNSYLVANIA
NO. (I f. J~ J' (!.(~.,-,1 '!t-w-
v.
CONNIE L. LIMRIC,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE
1. The Plaintiff is Robert V. Limric, an adult
individual 224 Bella Vista Drive, Marysville, Perry County,
Pennsylvania, 17053.
2. The Defendant is Connie L. Limric, an adult
individual currently residing at 23 East Beale Avenue, Enola,
Cumberland County, Pennsylvania, 17025.
3. Plaintiff and Defendant have been bona fide residents
in the Commonwealth of Pennsylvania, for a period in excess of six
(6) months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on December 31,
1978 in Dauphin County, Pennsylvania.
5. There have been no prior actions of divorce or
annulment between the parties in this or any other jurisdiction.
6. This action is not collusive.
7. plaIntJ.ff and Defendant separated on or about
December 12, 1997.
B. 'l'he ground for divorce is: The marrIage is
irretrievably broken and Defendant has offered such indignities to
the Plaintiff, the innocent and injured spouse, as to render his
condition intolerable and his life burdensome.
9. Plaintiff and Defendant have two children under the
age of eighteen, namely Tanya Danielle Limric, born June 20, 1981,
and Jesse Ryan Limric, born August 28, 1982.
10. Plaintiff has been advised of the availability of
marriage counseling and understands that he may request that
his spouse and he participate in counseling.
11. Plaintiff does not request that the Court require
that his spouse and he participate in counseling prior to a divorce
decree being handed down by this Court.
WHEREFORE, Plaintiff requests this Honorable Court enter
a final Decree in Divorce.
COUNT I - EOUITABLE DISTRIBUTION
12. Paragraphs one through eleven are incorporated by
reference herein.
13. During their marriage, Plaintiff and Defendant have
acquired various items of marital property, both real and personal,
which are subject to equitable cJ.lstdbutIon under Sections 3501 !ll...
f:l.Q!L.. of: the IJi vorce Code of: 1960.
WlIlmEFOHE, Plaint.lff respectfully requests this Honorable
Court equitably distribute the parties' marital property.
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922~tinglesto n Hoad
Harr~sburg, PA 17112
(7170 671-1500
1.0. No. 33671
A F F IDA V I T
I, ~~, hereby certify that the aforegoing
is true and correct to the best of my knowledge, information and
belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn
falsification to authorities.
Dated:
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ROBERTV. LlMRIC,
Plaintiff
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: IN THE COURT OF COMMON PLEAS,
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 98-868-CIVIL
: CIVIL ACTION - DIVORCE
CONNIE L. LlMRIC,
Defendant
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under section 3301(c) of the Divorce Code was
flIed on February 13, 1998 and served on February 23, 1998.
2. The marriage of Plaintiff and Defendant is irretrievably broken and
ninety (90) days have elapsed from the filing of the Complaint and service of the
Complaint on Defendant.
3. I consent to the entry of a final Decree of Divorce after service of
Notice of Intention to Request Entry of Divorce Decree or at any time after the
signing of this Consent if I have also signed a Waiver of Notice of Intention to
Request Entry of a Divorce Decree Under Section 3301(c) of the Divorce Code.
I verify that the statements made in this Mfidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18
Pa.C.S. ~4904 relating to unsworn falsification to authorities.
DATED: / d - / J - 0/
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ROBERT V. LIMRIC
Plaintiff
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: IN THE COURT OF COMMON PLEAS,
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 9lJ.868.C1Vil..
: CIVil.. ACTION - DIVORCE
ROBERTV. LIMRIC,
Plainti11'
CONNIE L. LIMRIC,
Defendant
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under section 3301(c) of the Divorce Code was
fIled on February 13, 1998 and served on February 23, 1998.
2. The marriage of Plaintiff and Defendant is irretrievably broken and
ninety (90) days have elapsed from the filing of the Complaint and service of the
Complaint on Defendant.
3. I consent to the entry of a final Decree of Divorce after service of
Notice of Intention to Request Entry of Divorce Decree or at any time after the
signing of this Consent if I have also signed a Waiver of Notice of Intention to
Request Entry of a Divorce Decree Under Section 3301(c) of the Divorce Code.
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
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Pa.C.S. *4904 relating to unsworn falsification to authorities.
DATED: /;2/t/(),
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CONN! .' IC
Defendant
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: IN THE COURT OF COMMON PLEAS,
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 98-868-ClVIL
: CIVIL ACTION - LAW IN DIVORCE
.I
ROBERTV. LIMRIC,
Plaintiff
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CONNIE L. LIMRIC,
Defendant
SOCIAL SECURITY NUMBERS FOR THE PARTIES
l
1. The Social Security Number for Defendant, Connie L. Limric, as provided
to me is 193-56.0583.
2. The Social Security Number for Plaintiff, Robert V. Limric, as provided to
me is 196-52-0221.
Respectfully submitted,
Dated: I Z' 1:>-lJ/
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Nor F. Blair
Supreme Court ID 45513
5440 Jonestown Road
Post Office Box 6216
Harrisburg, PA 17112-0216
(717) 541-1428
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IN TilE COUIlT OF COMMON PLEhS OF
CUMBEIlL^ND COUNTY, PENNSYLV^NI^
CIVIl, ^C'I'ION - I.^W
NO. qq... ~~? CIVIl. 19
IN DIVOIlCI,:
S'l'^TUS SHEET
^CTIVITIES:
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ROBERT V. LIMRIC,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 9B - 8G8 CIVIL
CONNIE LIMRIC,
Defendant
IN DIVORCE
TO:
Kristin R. Reinhold ,,//
Attorney for Plaintiff
Nora F. Blair Attorney for Defendant
DATE: Wednesday, March 8, 2000
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
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(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
DATE
COUNSEL FOR PLAINTIFF
COUNSEL FOR DEFENDANT
NOTE:
PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
~
LIST OF MARITAL ASSETS AND DEBT
ITEM DATE OF MARITAL VALUE TO VALUE TO
NO. ASSET VALUE VALUE LIEN WIFE HUSBAND
1. House at 23 East Beale 60,000.00 (84,000.00) (24,000.00)
2. 1995 Ford Explorer 7,000.00 7,000.00
3. 1997 Ford Ranger 10,000.00 10,000.00
4. 1992 Yamaha Motorcycle 2,000.00 2,000.00
5. Four Wheeler 3,000.00 Son Son
6. Six Wheeler & trailer 5,000.00 5,000.00
7. Decatur Fund 12-13-97 4,907.26 4,907.26
8. Pa Central FCU CD 76,589.77 (45,503.54) 76,589.77 (45,503.54)
9. First Union CD (Daugh.) 6-2-00 1,790.00 Daughter Daughter
10. First Union CD (Son) 6-2-00 1,790.00 Son Son
11. Minnesota Life (H) 2-23-99 ~886.00 ~886.00
12. Minnesota Life (W) 12-31-99 1,421.00 1,421.00
13. Tools at Mold Base 6-2-00 1,000.00 1,000.00
14. Tools at Foust 6-2-00 500.00 500.00
15. Vacation leave 12-13-97 4,500.00 4,500.00
16. Mold Base 401(k) ,,39,427.56 ,,39,427.56
17. Loans to Sean Limric 2,600.00 2,600.00
18. Loans to Viola Limric 15,850.00 15,850.00
19. Proceeds of loan 12-1-97 33,212.71 33,212.71
20. Household (W) 3,750.00 3,750.00
21. Household (H) 3,500.00 3,500.00
22. Tools (W) 900.00 900.00
23. Tools (H) 4,000.00 4,000.00
24. Hunting & camping F.q. 500.00 500.00
25. Guns 4,000.00 4,000.00
26. Gun Safe 2,000.00 2,000.00
TOTAL 290,124.30 (129,503.54 98,873.48 55,167.2
.
1. Marital Debt paid by (29,191.34) (29,191.34)
Wife post separation -
see attached sheet
2. Husband's post (1,347.84) (1,347.84) 1,347.84
separation bills paid by
Wife
3. PA Central FeU VlBa 12-09-97 (4,143.95) (4,143.95)
4. eitibank VlBa 12-05-97 (4,260.63) (4,260.63)
5. Discover Card 12-03-97 (3,169.01) (3,169.01)
TOTAL (42,112.77) (30,539.18 (10,225.75
NE1VALUE 68,334.30 44,941.53
Ve1ues are current unless a different date is indicated.
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ROBERT V. LIMRIC,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Vs.
NO. 98 - 868 CIVIL
CONNIE LIMRIC,
Defendant
IN DIVORCE
THE MASTER: Today is Monday, October 8,
2001. This is the date set for a conference with counsel and
the parties. Present in the hearing room are the Plaintiff,
Robert V. Limric, who is unrepresented by counsel. Also
present is the Defendant, Connie Limric, who is present with
her counsel Nora F. Blair.
We have discussed many issues in this matter
involving as follows:
I. Husband's earning capacity.
2. Husband's failure to comply or keep current the terms
of an order entered by the Court regarding payment of a debt
on a certificate of deposit. Husband says he is around
$800.00 behind. He is to pay $150.00 per week on that loan.
The balance on the loan is around $45,000.00.
3. Husband is currently working at a job where he is
making around $13.00 an hour; he previously had worked for
Mold Industries, Inc., where he was making $52,000.00 per
year. He indicated that he quit that job because of the
stress involved with the divorce proceedings. There is,
therefore, an issue regarding his earning capacity. The
Master has been advised that an order was entered for him to
pay spousal support in excess of $1,000.00 per month based on
his earnings at Mold Industries, Inc.
Mr. Limric did not appeal the assessment of his
earnings or contest the order although he had ample
opportunity to do so. In discussing the alimony issue, the
Master informed Mr. Limric that he would be subject to an
alimony payment of at least $1,000.00 per month based on the
earnings attributed to him, which alimony would be modifiable
based on a change of circumstances of a continuing and
substantial nature or termination upon the cohabitation or
remarriage of wife or the death of either party.
4. We have a list of marital as sees that has been provided
by wife's counsel along with various debt items. Husband
removed his name from the title to the property at 23 East
Beale Avenue, Enola, Pennsylvania, although he remains on the
mortgage.
In reviewing the assets, Mr. Limric has indicated that
each party, as far as he is concerned, can retain property
which is presently in each of the parties' possession;
therefore, eliminating any issues regarding the items in the
marital estate.
5. With regard to the debt, Mr. Limric is under the Court
order to continue to pay the debt subject to the Master's
findings which could alter the disposition of how that debt is
paid. Mr. Limric has offered to pay 60% of the outstanding
balance of the debt and with his wife paying 40%. Mr. Limric
has also indicated that he thinks he should have some credit
for the debt that he has already paid; however, the Master is
not at this time disposed to getting involved in any credit
issues. The Master thinks that without hearing any testimony
that we should best leave the matter go forward with the
parties splitting the debt 60/40 and with Mr. Limric paying
the alimony as above indicated.
Each party would, therefore, retain the property
in each parties' possession. the debt would be split 60/40
remaining on the CD and Mr. Limric would obligate himself to
pay alimony in the amount of $1.000.00 per month to wife
subject to modification based on a change of circumstances of
a continuing and substantial nature or termination upon the
cohabitation or remarriage of wife or the death of either
party. The divorce would then be able to proceed under
Section 3301(c) of the Domestic Relations Code.
This memorandum is simply a result of discussions
which were held today as a result of the conference. The
Master has not attempted in any way to restate all the
arguments that were made or all points that either party
wanted to make regarding these various issues. The memorandum
is stated on the record for the purpose of giving perhaps some
direction to resolving this case. Wife's attorney has
indicated that she has asked the Court to reschedule the
pending issues involving the loan payments and some discovery
matters for the Court to consider and ask that the Court
direct Mr. Limric to comply with the order or be held in
contempt. That matter is pending but would not have to be
pursued if the case were finally settled.
The Master is not suggesting by the statement
above that this is the final recommendation that the Master
would make on this case because the Master cannot do so
without hearing all of the testimony. However, having heard
November 5, 2001
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I would like to continue on with the Master's Hearing. Connie and 1 have come to no middle
ground for a settlement, Therefor I would like to have a date set for a hearing to discuss this
matter.
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Thank - You,
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Sincerely, Robert V, Limric
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NORA F, BLAIR
Post Orrico Box 6216
Harrisburg, PA 17112.0216
Attorney At Law
5440 Jonostown Road
NFBLAW@paonlino.com
Fax (717) 541.1429
(717) 541.1428
November 12, 2001
Robert Ellicker, Esquire
OFFICE OF THE DIVORCE MASTER
9 North Hanover Street
Carlisle, PA 17013
RE: LlMRIC v. LlMRIC
98-868
Dear Mr. Ellicker:
I am in receipt ofthe copy of the letter that was sent to you by Robert Limric
requesting that this matter be scheduled for a Master's hearing. Although Connie
Limric would like to settle this matter and we will continue to negotiate in an
effort to settle, I do understand that you will need to schedule this matter for
hearing.
Although you are aware that Connie Limric is on social security disability,
I am not sure if you are aware of the difficulties that her condition causes. Connie
suffered a closed head trauma as a result of an automobile accident on November
3, 1993. As a result she is easily confused when she is tired or stressed. Therefore,
it is requested that the hearings in this matter be scheduled for the morning when
Connie is more rested and that there be no more than three hours of hearings on
any day.
Your assistance in this matter is greatly appreciated.
NFB:cd
c: Connie Limric
Robert Limric
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 9B-OB6B CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
ROBERT V. LIMRIC,
Plaintiff
CONNIE L. LIMRIC,
Defendant
ORDER OF COURT
AND NOW, this 1st day of February, 2001, it
appearing that additional documentation and testimony will be
needed, the hearing in this matter is continued until Monday,
March 19, 2001, at 10:00 a.m. The Plaintiff has been advised
that we will need the testimony of his doctor in order for him
to prove that he quit his job for medical reasons. We had
indicated that we will take the testimony of Dr. Magill by
telephone.
In the interim, the Defendant is directed to do
the following:
1. Provide a detailed breakdown of all
withdrawals made from his 401(k) plan and where the money was
spent.
2. Obtain the name and address of the people to
whom he sold his four-wheeler, six-wheeler, trailer, guns and
gun safe. He is also directed to provide an accounting of what
funds he received for the sale of those items and how he
disposed of those funds.
3. He is directed to provide an accounting of
the funds he received for his truck, including a copy of the
canceled check therefor and a copy of all the title work done in
connection therewith.
Pending further order of court, Lisa Bailey is
enjoined from selling, transferring, encumbering or otherwise
disposing of the 1997 Ford Ranger which she received from
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 9B - B6B CIVIL
ROBERT V. LIMRIC,
Plaintiff
CONNIE LIMRIC,
Defendant
IN DIVORCE
TO: Kristin R. Reinhold
Attorney for Plaintiff
NoraF. Blair Attorn~y for Defendant
DATE: Wednesday, March B, 2000
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
,j/J,qlDO
/ D TE
NOTE:
PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE l~STER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
.
ROBERT V. LIMRIC,
Plaintiff
IN THE COUR'r OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 9B - B6B CIVIL
CONNIE L. LIMRIC,
Defendant
IN DIVORCE
RE:
Pre-Hearing Conference Memorandum
DATE:
Wednesday, September 20, 2000
THE MASTER: Present for the Plaintiff,
Robert V. Limric, is attorney Kristin R. Reinhold, and present
for the Defendant, Connie L. Limric, is attorney Nora F.
Blair.
This action was commenced by the filing of a
divorce complaint on February 13, 199B, raising grounds for
divorce of irretrievable breakdown of the marriage and
indignities. Counsel are uncertain at this point as to
whether or not wife will sign an affidavit of consent and
husband has the option of filing a 3301(d) affidavit averring
a separation in excess of two years. Before filing a 3301(d)
affidavit, however, we are going to determine at a conference
that is to be scheduled whether or not wife will sign an
affidavit of consent. If she will not sign then counsel for
husband can proceed with the filing of the affidavit under
Section 3301(d).
The complaint raised the economic claim of
equitable distribution. On May 13, 1999, a counterclaim was
filed by wife raising the economic issue of counsel fees and
costs; on May 17, 2000, another counterclaim was filed by wife
raising the economic claim of alimony. Counsel have
indicated that they do not anticipate offering testimony on
the factor of marital misconduct. If that position changes,
counsel are to immediately notify the Master and opposing
counsel with a list of witnesses who will be testifying on
that factor.
The parties'were married on December 31,
197B, and separated December 12, 1997. There were two
children born of the marriage, Tanya, who is emancipated and
Jesse, who is a senior in high school. Both children are
living with wife.
Husband resides at 4 East North Avenue,
Enola, Pennsylvania, where he resides with a female friend.
He is 40 years of age and is a machine shop technician with
Mold Base Industries. His gross weekly income is $1,001.00.
The Master has been provided a copy of an order entered by
Judge Oler on February 1, 2000. Judge Oler's court order of
February 1, 2000, determines that husband's net monthly
income, prior to May 5, 1999, was $3,370.98 and thereafter
$3,47B.90. Wife's net monthly income has been determined to
be $791.00. The Court directed that husband pay spousal
support in the amount of $603.75 per month and child support
for one child in the amount of $675.39 per month. There is an
arrearage payment also of $43.45 until the arrearage of
$1,279.14 has been paid. Husband has not raised any health
issues.
Wife resides at 23 East Beale Avenue, Enola,
Pennsylvania, where she lives with the two children and her
mother. Wife is a high school graduate but is receiving
social security disability. Ms. Blair is going to provide
documentation showing that the disability is total and
permanent. If the documentation otherwise shows partial
disability then we will address that issue later. Wife had a
head trama injury in a car accident and is unable to work in
any type of employment.
Counsel have indicated that it does not
appear that the interest in the residence where wife is living
that was marital has any value. The property was owned
jointly with wife's mother who also resides on the premise.
Husband transferred his interest in the property to wife in
return for which husband received certain items of tangible
personal property.
There are issues involving receipt of marital
funds by the parties and how those funds were applied.
Counsel have indicated that they believe that they have some
agreement on the application of funds and amounts borrowed but
the Master would like to have the parties and counsel appear
and attempt to prepare a stipulation which can be placed on
the record to account for some of the funds that have been
expended by the parties for payment of debts and monies that
were perhaps loaned to other persons. To that end, the
Master is going to ask counsel to place on the record a
statement of what information each counsel feels she needs in
order to prepare for the conference. We will also, in
addition to discussing the debt issues and the payment of
debt, at the conference see if we can come to some stipulation
on values of tangible assets. There is a concern that the
Master has in looking at this estate that the value of the
marital estate may be minimal compared to the offsets and
charges that one party may have against the other relating to
debt payments. In any event, we hope to be able to arrive at
some numbers which will help us in determining the value of
the marital estate and what either or both parties may be
charged with receiving.
Counsel are going to state on the record
information that they would like to have provided by opposing
counsel in order to prepare for the conference. Ms. Reinhold.
MS. REINHOLD: Husband would request
documentation of any loans which wife alleges husband made to
third-parties and when those loans allegedly occurred.
Husband would also request any appraisals which wife has had
performed on marital assets in her or husband's possession.
MS. BLAIR: Wife would request that husband
provide proof of all payments that he made to any
third-parties from loans against the parties' certificate of
deposit or from funds received by wife from the personal
injury settlement. In addition, wife would request that
husband provide copies of his quarterly statements or however
often they are issued on his 401(k) account starting in
December of 1997 to the current time. Also wife would request
copies of any appraisals that were made on any marital
property whether the property is in husband's possession or in
wife's possession.
(A discussion was held off the record.)
MS. REINHOLD: Husband also requests
documentation and/or any accounting of wife's expenditures of
the personal injury settlement and worker's compensation
settlement.
MS. BLAIR: Wife also is requesting
documentation of expenditures on the personal injury
settlement and worker's compensation settlement.
THE MASTER: A conference between counsel and
the parties is scheduled for Monday, December 4, 2000 at 9:00
a.m. The purposes of the conference will be to try to arrive
at stipulations regarding assets and debts and values of
marital assets. Following the conference, we hopefully will
be able to place some stipulations on the record, determine
remaining issues if any, and then schedule a hearing to take
testimony on those issues.
The Master is aware that the alimony claim is
one of the major issues in this case and we should be able to
address that issue as well at the conference after we have
arrived at some stipulations and valuations.
.
cc: Kristin R. Reinhold
Attorney for Plaintiff
Nora F. Blair
Attorney for Defendant
ROBERT V. LIMRIC,
l:'laintif f
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - LAW
NO. 9B - B6B CIVIL
CONNIE L. LIMRIC,
Defendant
IN DIVORCE
CONFERENCE WITH
COUNSEL AND THE PARTIES
TO: Kristin R. Reinhold
Robert V. Limric
, counsel for plaintiff
, plaintiff
Nora F. Blair
Connie L. Limric
, counsel for Defendant
, Defendant
A conference has been scheduled at the Office of
the Divorce Master, 9 North Hanover street, Carlisle,
Pennsylvania, on the 4th day of December, 2000, at 9:00
a.m., with counsel and the parties to discuss the
outstanding economic issues to determine if there is a basis
of settlement of claims. If issues remain after the
conference a hearing will be scheduled at another date.
Very truly yours,
Date of Notice:
September 20, 2000
E. Robert Elicker, II
Divorce Master
LIMRICV. LIMRIC
MARITAL DEBT PAID BY WIFE POST SEPARATION
CREDITOR BILL DATE CHECK DATE AMOUNT
1. Wells Fargo visa Dee 16, 1997 842.73
2. Advanta Jan 26, 1998, bal for Dee 1997 1,109.57
3. AT&T Dee 11, 1997 1,488.84
4. Wells Fargo MC Jan 16,1998 636.01
5. Waehovia Jan 15, 1998 Dee 11, 1997 4,167.88
6. Texaco Dee 21, 1997 329.82
7. Fleet Feb 24, 1998 1,106.75
8. United consumer Dee 20, 1997 100.00
9. RRMC Nov 11, 1998 522.39
10. PP&L Nov 20- Dee 23 352.10
11. PP&L Oct 27-Nov 20 418.42
12. Trash Dee 15, 1997 96.57
13. Suburban Cable Dee 23, 1997 52.86
14. Chase Mortgage Dee 10, 1997 14,300.27
157.50
15. 1997 taxes Jul1, 1997 1,304.95
16. 1997 taxes Jan 13, 1998 337.81
17. Dental bill (service July, 1997) 113.76
18. Bell Atlantic Dee 10, 1997 600.00
19. West Coast Life April 20, 1998 81.97
.
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20. BJ'S wholesale MC Dee 21, 1997 21.00
21. PAWC Dee 10, 1997 83.48
22. PAWC Jan 6, 1998 109.18
23. Support 12/13-12/22 423.13
24. Dave Baboian 97 taxes Feb 16,1997 217.00
25. Dept of Revenue 97 taxes April 14, 1997 100.00
26. PP&L Nov 21,1997 117.35
TOTAL MARITAL DEBT PAID $29,191.34
1. Transfer. Dee 19,1997 1,000.00
2. Transfer. Feb 04, 1998 75.00
3. Sears.. Nov 30, 2000 272.84
TOTAL HUSBAND'S POST SEPARATION BILLS 1,347.84
.
Husband usedjoint account and bounced checks. Wife transferred money
from her account to the joint account.
..
Husband charged tires and a bicycle on Wife's Sears account after
separation. Husband paid all but $272.84 which Wife paid to protect her
credit.
With respect to the issues that need to be
resolved there has been a question about a withdrawal from a
checking account of the parties in the amount of $B,OOO.OO.
There is some suggestion that the monies were withdrawn by Mr.
Limric and given to his female friend to use toward the
purchase of a vehicle. In order to help us resolve that
issue at the hearing/conference that we are going to schedule,
we will ask that the girlfriend be subpoenaed so that she can
be sworn and testify about the issue of the $B,OOO.OO and any
other issues that are relative regarding the disbursement of
funds from the checking account.
Mr. Limric has indicated that he has disposed
of all of the assets in his possession but he has not denied
that he is to be held accountable for the value of the assets
that he has disposed of. To that end, the Master has
requested both parties to bring in a schedule of assets
stating a value for those assets and a schedule of debt which
may be owed by either or both of the parties that was a
marital obligation. That worksheet should be provided at the
time of the hearing/conference.
The Master has been advised that Judge Oler
has scheduled a support hearing on a petition by husband to
decrease his support for February 23, 2001. The issue is
whether or not husband should be attributed an earning
capacity even though his current income is substantially less
than it was when the original order was entered. After the
Master has had the benefit of Judge Oler's hearing and
findings, he will be able better to valuate wife's alimony
claim.
Attorney Blair is going to provide the Master
a copy of Judge Oler's order as soon as it is available and
request at that time that we have a hearing/conference
scheduled for the purpose of taking the testimony of husband's
female friend and also for the purpose of looking at the asset
and debt schedule of the parties so we can determine if
perhaps we might resolve the economic issue involving the
equitable distribution and allocation of debt. The alimony
claim of wife will be further developed after we know the
findings of Judge Oler on husband's earning capacity.
Husband is also scheduled for a hearing
before Judge Guido on March 19, 2001, because of his alleged
failure to make payments on a loan against the certificate of
deposit. Husband claims that currently he is taking home
$84.00 a week from his employment as a result of the
obligations that he has to pay with respect to the support and
he has been unable to make any payments on that certificate of
deposit loan.
As soon as the Master has been advised of the
status of the hearing before Judge Oler on support he will
schedule a hearing/conference with the parties and counsel and
any witnesses which they wish to subpoena.
(A discussion was held off the record.)
THE MASTER: I asked Mr. Limric if he has
requested any information that needs to be provided by the
other side to help prepare his case. He has been handed a
stack of papers today and he says that he supposes that the
information which he has been requesting for some time is
included in that information.
Attorney Blair has made a request for Mr.
Limric to provide information as follows:
MS. BLAIR: Any documents that Mr. Limric
plans to use as a part of his presentation in the Master's
hearing/conference, including any banks statements or copies
of checks that he might have received from the bank and any
other documentation he may be planning to use to support his
claims of the value of assets and debt at the time of the
parties' separation.
(A discussion was held off the record.)
THE MASTER: Do either of the parties or
counsel have anything further that they want to state on the
record at this time? Mr. Limric, do you have any questions?
MR. LIMRIC: Nope.
THE MASTER: Mrs. Limric, do you have any
questions?
MRS. LIMRIC: No.
THE MASTER: Attorney Blair?
MS. BLAIR: I would like to say that if Mr.
Limric could
if his girlfriend could provide documentation
of where she got the funds to purchase that car, then we can
probably avoid having to have her here and having to have __
you know, so if we can see some documentation of where she got
the money and provide that to me ahead of time then we might
not have to have her testify.
MR. LIMRIC: I'll ask her.
THE MASTER: Thank you. The record is closed
and we will be waiting to hear from Attorney Blair and a copy
of Judge Oler's order and then we will schedule a
hearing/conference.
cc: Robert V. Limric
Plaintiff
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Nora F. Blair
Attorney for Defendant
Connie L. Limric
Defendant
NOTE: Following the conference with Attorney Blair and the
parties, Attorney Blair called the Master's office around
11:30 a.m. on February 5, 2001, to advise that the hearing
before Judge Oler is not to determine husband's earning
capacity but is a hearing rather on contempt for husband's
failure to pay his support order. Apparently husband never
filed an appeal from the denial of his petition to decrease
the order that was heard in the Domestic Relations Office.
Consequently, husband is subject to two contempt hearings, one
for failure to pay the support order before Judge Oler on
February 23, 2001, and a contempt hearing before Judge Guido
on March 19, 2001, for failure to make payments on the loan
against a certificate of deposit. Attorney Blair will advise
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CONNIE L. LIMRIC,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
DOMESTIC RELATIONS SECTION
ROBERT V. LIMRIC,
Defendant
DRU 27,186
No. 1142 SUPPORT 1997
ORDER OF COURT
AND NOW, this 23rd day of February, 2001,
the Defendant, Robert V. Limric, now appearing in court on
a petition for contempt, and having been found in contempt
by the Court, the sentence of the Court is that the
Defendant undergo imprisonment in the cumberland County
Prison for a period of five months. The condition of purge
with respect to this sentence is that the Defendant pay the
sum of $5000.00.
By the Court,
Nora F. Blair, Esquire
For the plaintiff
Robert V. Limric, Pro Se
Cumberland County Prison
Carlisle, PA 17013
Defendant
Sheriff
DRO
CCP
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In the Court of Commoll Pleus of CUMBEltLANI> County, Pellllsylvllulll
I>OMESflC RELATIONS SECTION
CONNIE L. LIMRIC ) Docker Numhcr 01142 S 1997
Plahuirf )
VS. ) PACSES Casc Numher 971100017
ROBERT V. LIMRIC )
Dcfcnuant ) Other Stale ID Numher
CONSENT ORDER
AND NOW, to wit on this 11TH DAY OF DECEMBER, 2000
IT IS HEREBY
ORDERED that the 0 Complaint for Support or (i) Petition to Modify or 0 Other
filed on October 27, 2000 in the above captioned
matter is dismissed without prejudice due to:
a reduction in support not being warranted, as the defendant voluntarily
reduced his income.
o The Complaint or Petition may be reinstated upon written application of the plaintiff
petitioner.
Consented:
Date
Plaintiff Signature
.'
Date
Defendant Signature
BY THE COURT:
00: fm.f L. Ic:l<e;
~: plaintiff ad d9fa-d:nt
0::: NXa F. B13ir, ESq.
0::: Kristin R. RiliYnld, ESq.
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J. iJ'€sley Oler,
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Service Typc M
Form OE-505
Worker ID 21102
ROBERTV. LIMRIC, : IN THE COURT OF COMMON PLEAS,
PlaintifflRespondent: CUMBERLAND COUNTY, PENNSYLVANIA '} n.,1
: .IAN- 1.1 ",UN'
v. : NO. 9B-B68-CML
CONNIE L. LIMRIC, : CIVIL ACTION - LAW IN DIVORCE
Defendant/Petitioner:
AND NOW, this
q-tA
ORDER
day of l/ Ii ^' uAll 'I
, 2001, after
review of the attached Petition for Contempt and Special Relief, it is hereby
ORDERED AND DECREED that Respondent, Robert V. Limrie, should show
cause, if he has any, why the relief requested should not be granted. It is further
ORDERED AND DECREED that until further Order of This Court, Respondent
is prohibited from dissipating any assets. Specifically, Respondent is prohibited
from selling or otherwise transferring and from establishing a lien against or
otherwise diminiShing the value of any of property including the 1997 Ford
Ranger, Respondent's retirement and 401(k) accounts at Mold Base Industries,
and any other property in Respondent's name, controlled by Respondent or in
f>6~ ,...wt> 'l~c.
Respondent's possession. Further, RC3~BR8IlRt ill prohibited from removing any
funds from the Certificate of Deposit account number 17250-029 at Pennsylvania
Central FeU.
RULE RETURNABLE 10 DAYS AFTER MAILING. WI.. ~~ c...
~~d.c~b~~'
Edward E. Guido, J. c-C\c'
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ROBERT V. LIMRIC, : IN THE COURT OF COMMON PLEAS,
Plaintiff/Respondent: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 98-868-CIVIL
CONNIE L. LIMRIC, : CIVIL ACTION - LAW IN DIVORCE
DefendantlPetitioner:
PETITION FOR CONTEMPT AND SPECIAL RELIEF
AND NOW comes Connie L. Limrie, by and through her attorney, Nora F.
Blair, Esquire, files this Petition for Contempt and Special Relief and in support
thereof avers as follows:
1. The parties hereto are husband and wife and are involved in a difficult
divorce matter.
2. Following the filing of several Petitions for Special Relief in the divorce
matter, an Order was entered by Your Honorable Court resolving some of
the issues set forth in the various Petitions. A copy of the May 27, 1998,
Order is attached hereto, marked Exhibit "A" and incorporated herein by
reference.
3. Paragraph 3 of said Order required Robert V. Limrie to make any payments
necessary to keep the Pennsylvania Central FCU from being in default or
from incurring any late charges or penalties.
4. Petitioner has received notice from Pennsylvania Central FCU that the loan
payment is in serious default with the payment for November 12, 2000, not
made. A copy of the December 20, 2000, letter from the credit union is
.
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attached hereto marked Exhibit liB" and incorporated herein by reference,
5. Petitioner received a telephone call from Pennsylvania Central FCU on
January 5, 2001, indicating that no payments have been made since
November 12, 2000.
6. Respondents failure to pay the loan at Pennsylvania Central FCU is in
direct violation of the May 27, 1998, Order.
7. Petitioner requests that Respondent be held in contempt of Court, be
ordered to bring the loan at Pennsylvania Central FCU current and make
payments as required by the lender.
8. On or about October, 2000, Respondent quit his job at Mold Base Industries
where he made in excess of $52,000.00 per year. This occurred at the time
the Masters hearing was scheduled in the divorce matter. The Masters
hearing has been continued with a conference scheduled with the Master
in February.
9. Respondent filed for a decrease in the amount of support that he pays. Said
request was denied and the support matter is set for a contempt hearing
before Judge Oler.
10. Respondent has indicated to Petitioner and also to the conference officer at
the support conference that he does not care if he is thrown in jail and that
he will not do work release if he is in jail.
11. Petitioner believes and therefore avers that Respondent may dissipate
marital assets in an effort to avoid any payments to Petitioner in the divorce
matter.
12. Petitioner believes and therefore avers that Respondent is being paid
"under the table" in order to avoid the payment of the full amount of
support.
13. After separation of the parties, Respondent took a loan against his 401(k) at
Mold Base Industries. Petitioner believes this was done to avoid
distribution to Petitioner.
14. Petitioner believes that if Respondent has not already done such, he may
try to remove all of the funds remaining in his 401(k) and retirement
accounts with Mold Base Industries.
15. Respondent's 1997 Ford Ranger is free of any lien.
16. Petitioner believes and therefore avers that Respondent may try to establish
a lien against the truck or try to sell it in order to avoid payment to
Petitioner.
17. Petitioner request that Respondent be prohibited from any further
dissipation of assets.
18. Petitioner has incurred attorney fees in meeting with counsel, preparation
of this Petition and will incur attorney fees for representation at the hearing
on this Petition.
19. Petitioner requests that Respondent be required to pay Petitioner's
reasonable attorney fees in bringing this contempt matter to Court.
.111/;1/ . IJ.\'I ".,,(I'ark Ilrive
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Serving Mcmhcrs since IIJJH
WWw.p"ccnlrulfell.CtJI11
717.5r,.1.,lflfll or HIKI.J5(,.JH75
I'll.' 717.5(,.1.150.1
December 20, 2000
Robert V. Limric
4 East North Avenue
Enola, PA 17025-2726
Conme L. Lirnric
23 East Beale Avenue
Enola, Pa 17025-2804
RE: Account # 17250-029
Total Amount Past Due: $1,191. 77
Dear Mr. Limric and Ms. Limric:
Repeated efforts have been made to have you contact this office and make
satisfactory arrangements to bring your account current. Yet, you have ignored several
notices and still refuse to cooperate with us. Your account remains in serious default and
is now due for November 12, 2000 through December 14, 2000 in the amount of
$1,191.77.
We expect your account to be brought current within the next five (5) days. Your
failure to do so may result in further action being taken to collecl this loan in tllll Be
advised that iffurter action is taken. there will be additional costs to you.
I leave the decision for such action entirely up to you. If you have any further
questions, contact this office at (717) 564-4661 or toll free (800) 356-3875, extension
114.
This is an attempt to collect a debt and any information obtained will he used lor
that purpose.
Sincerely,
frJ@'fu.&tlJ ;/&U.~J/
Michaelann Horelsky
Colleclions Manager
EXHIBIT ~B"
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LIMRIC
\'. L1NRIC
PACSES ell,. NUlllh.r: 97110001'1
I'lnlntll'l' Inl'orlllntion
Cnrrent Income:
sse $631,00 per month.
Defl'ndunt Inforllllltilln
Earning capacity held at old
position in the amount of $53048.04
gross per year. Established under
the opinion and ordor set 2/1/00
Tux Return:
..
Medical Coverage:
Defendant must obtain medical
insurance.
Child Care/Tuition:
Additional Obligations:
Other Infonnation:
Defendant's petition to modify dismissed as he quit his position without
reason. Defendant indicated that he is under doctors care. He is takinq
Paxil for depression 30 mq. per day. Defendant did not provide a document
statinq he needed to quit hie employment. Defendant stated that his doctor
did not tell the defendant to quit his position due to stress.
Defendant had a neqative attitude durinq the conference. H- ~ ,~ ~p'
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Defendant told the parties that he wanted to qo ;ail, that if he were
incarcerated he would refuse work released. He told the parties that " I make
$6.00 per hour, this is what I make, and that's what you'll qet".
S.rvice Type M
Page 2 of3
Form CM-022
Worker ID 21102
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LIMRIC
v. LIMRIC
I'ACSES ClISC Nlllllhcr: 97 llOCl017
Other Inl'Ol'llllllllln (continued):
."
Facts Agreed Vllon:
Facts in Dispute and Contentions with Respect to Fllcts in Dispute:
DEFENDANT REFERRED TO COURT FOR CONTEMPT OF COURT.
GUIDELINES WERE NOT RUN AS DEFENDANT'S REASON FOR REDUCTION WAS UNWARRANTED.
Guideline Amount: $ 1.279.14 / MONTH
DRS Recommended Amount: $ 1.279.14 1 MONTH
DRS Recommended Order Et't'ective Date: 06/21/99
Pllrties to be Covered by Recommended Order Amount:
SPOUSAL AND CHILD.
Guideline Deviation:
o YES or (X) NO
Reason for Deviation:
ORDER ESTABLISHED BY THE COURT.
Submitted by: AMY L. ICKES
Dale Prepared: DECEMBER 11. 2000
Page 3 of 3
Form CM-022
Worker 10 21102
Service Type M
ROBERT V. LIMRIC,
Plaintiff
IN 'rilE COUR'r OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS,
CIVIL ACTION - LAW
NO. 9B - 86B CIVIL
CONNIE L. LIMRIC,
Defendant
IN DIVORCE
CONFERENCE WITH
COUNSEL AND THE PARTIES
TO: ----------------
Robert V. Limric
Counsel for Plaintiff
, Plaintiff
Nora F. Blair
Connie L. Limric
, Counsel for Defendant
, Defendant
A conference has been scheduled at the Office of
the Divorce Master, 9 North Hanover Street, Carlisle,
Pennsylvania, on the 20th day of September 2001, at 9:00
p.m., with counsel and the parties to discuss 'the
outstanding economic issues to determine if there is a basis
of settlement of claims. If issues remain after the
conference, a hearing will be scheduled at another date.
Very truly yours,
Date of Notice:
July 23, 2001
E. Robert Elicker, II
Divorce Master
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Defendnntls enjoined from dnmnglng or destroying nny property owned
Jointly by the pnrtles or owned solei)' by ('Inlntlff.
Defendant shall refrnln from hnrnsslng Plnlntlfrs relntlves.
Defendant shnll stny nwn)' from Plnlntlfrs residence locnted nt 23 E.
Benle Avenue, Enoln, ('ennsylvnnla, nnd }'Ialntlfrs nttorney's office
locnted nt5440 Jonestown Rond, Harrisburg, Pennsylvnnln.
Defendant shall refrnln from having any contnct with Plaintiff, either In
person, by telephone, or In writing, personally or through third persons.
The court costs and fees are wnlved.
3. A certified copy of this Order shall be provided to the police department
where Plaintiff resides and any other agency specified hereafter:
Enst Pennsboro Police Department
4. THIS ORDER SUPERSEDES:
I. ANY PRIOR PFA ORDER
5. All provisions of this order shall expire on: October 4, 2002
NOTICE TO THE DEFENDANT
VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE
CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS
PUNISHABLE BY A FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE
OF UP TO SIX MONTHS. 23 PA,C.S. 96114. VIOLATION MAY ALSO
SUBJECT YOU TO PROSECUTION AND CRIMINAL PENALTIES UNDER
THE PENNSYLVANIA CRIMES CODE,
THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE
DISTRICT OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND
THE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE
AGAINST WOMEN ACT, 18 U.S,C. 92265. IF YOU TRAVEL OUTSIDE OF
THE ST ATE AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAY
BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT
ACT. 18 U.S.C 992261-2262, IF THE BRADY INDICATOR PARAGRAPH
APPEARS IN THE ORDER, YOU MAYBE SUBJECT TO FEDERAL
PROSECUTION AND PENALTIES UNDER THE "BRADY" PROVISIONS
OF THE GUN CONTROL ACT, 18 U.S.C. 9922(G), FOR POSSESSIO~,
TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION.
NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who have jurisdiction over the plaintirrs residence OR any location
where a violation of this order occurs OR where the defendant may be located,
shall enforce this order. An arrest for violalion of Paragraph I of this order may
be without warrant, based soley on probable cause, whether or not the violation
is committed in the presence ofthe police. 23 Pa.C.S, 96113.
Subsequent to arrest, the police officer shall seize all weapons used or
threatened to be used during the violation of the protection order or during prior
incidents of abuse. The shall maintain possession ofthe weapons until further
order of this Court.
When the defendant is placed under arrest for violation of this order, the
defendant shall be taken to the appropriate authority or authorities before whom
defendant is to be arraigned. A "Complaint for Indirect Criminal Contempt"
shall then be completed and signed by the police officer OR the plaintiff.
Plaintifrs presence and signature arc not required to file the complaint.
If sufficient grounds for violation of this order arc alleged, the defendant shall
be arraigned, bond set and both parties given notice ofthe date of the hearing,
Edward E. Guido, J
Joan Carey, Attorney fi Plaintif
MidPenn Legal Services
8 Irvine Row
Carlisle, P A 17013
If,""", p=~tto :h' "M'~72aintiffandLDefendant:
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lai tiff ItO ert Victor Limric, Defendant
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Distribution to:
-MidPenn Legal Services
-Faxed and Mailed to PSP
-Robert Victor Limrie, Defendant
4 E. North Avenue
PO Box 9
Enola, PA 17025
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ROBERT V, LIMRIC,
Plaintin.
v.
: IN TI-IE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY. PENNSYLVANIA
: NO. 98-868 CIVIL
CONNIE L. LIMRIC.
Delcndant
: CIVIL ACTION - LA W
: IN DIVORCE
CERTIFICATE OF SERVICE
The undersigned. Robert V, Limrie. hereby certifies that a eopy ofa
~
was served upon Defendant's Attorney, Nora F. Blair. on )c.<.~. LL,2001, by
first class mail. postage pre-paid. addressed as follows:
Nora F. Blair, Esquire
5440 Jonestown Road
Harrisburg. I' A 17112
Date:
I IN,; 10 1
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Robert V. Limrie
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ROBERT V. L1MRIC.
Plaintiff
: IN TIlE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY. PENNSYL VANIA
v,
: NO, lJll-1l611 CIVIL
CONNIE L. L1MRIC.
Delcndunt
: CIVIL ACTION - LA W
: IN DIVORCE
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance pro se in the above-captioned mutter.
Date:~
Respectfully submitted,
/~/~
Robert V. Limric
4 East North Avenue
Enolu. PA 17025
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ROBERT V. LIMRIC, : IN THE COURT OF COMMON PLEAS,
PlnlntifflRespondenl: CUMBERLAND COUNTY, PENNSYLVANIA
, .,
v.
: NO. 98-868-CML
I.
I.'.
,
;
CONNIE L. LIMRIC, : CML ACTION - LAW IN DIVORCE
Defendant/Petitioner:
ORDER
AND NOW, this ..:t5~ day of LilJIJ/U'llt-Y
I
, I
, 2001, upon
request of counsel for Petitioner, a hearing on the Petition for Contempt and
Special Relief, is hereby set for the / s-t day of "Q,(.uJli!Jtj ,2001, at
'I: oCJ fJ .m., in Courtroom Number....r of the Cumberland County
Courthouse, Carlisle, Pennsylvania.
,
Edward E. Guido, J.
I
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Distribution:
Nora F. Blair, Esquire ),
Kristen R. Reinhold, Esquire Yr"f"'. /'nt'c' eu~ /iJ()Ja/
'-1'-
ASSETS OF THE PARTIES
Connie L. Limrie, Defendant, marks on the list below those items applicable
to the case at bar and itemizes the assets on the following pages.
(x) 1.
(x) 2.
() 3.
(x) 4.
() 5.
() 6.
() 7.
() 8.
(x) 9.
() 10.
() 11.
() 12.
() 13.
() 14.
() 15.
(x) 16.
() 17.
(x) 18.
() 19.
() 20.
() 21.
() 22.
() 23.
(x) 24.
( x) 25.
() 26.
Real property
Motor vehicles
Stocks, bonds, securities and options
Certificates of deposit
Checking accounts, cash
Savings accounts, money markets and savings certificates
Contents of safe deposit box
Trusts
Life insurance policies (indicate face value, cash surrender value and
current beneficiaries)
Annuities
Gifts
Inheritances
Patents, copyrights, inventions, royalties
Personal property outside the home
Business (list all owners, including percentage of ownership, and
officer/director positions held by a party with company)
Employment termination benefits (severance pay, worker's
compensation claim! award, etc.)
Profit sharing plans
Pension plans (indicate employee contribution and date plan vests)
Retirement plans, Individual retirement accounts
Disability payments
Litigation claims (matured and unmatured)
MilitaryNA benefits
Education benefits
Debts due, including loans, mortgages held
Household furnishings and personalty (include as a total category
and attach itemized list if distribution of such assets is in dispute)
Other
MARITAL ASSETS
Connie L, Limrie, Defendant, lists all marital property in which either or
both spouses have a legal or equitable interest individually or with another person
as of the date of separation (December 13, 1997) and as of the current time (June
2, 2000):
I. REAL PROPERTY
ITEM VALUE AT CURRENT
NUMBER DESCRIPTION OF PROPERTY OWNERS SEPARATION VALUATION
1. House at 23 Beale Avenue W & W's
Enola, Cumberland County Mother 111,000.00 120,000.00
II. MOTOR VEHICLES
ITEM VALUE AT CURRENT
NUMBER DESCRIPTION OF PROPERTY OWNERS SEPARATION VALUATION
2. 1995 Ford Explorer W 12,000.00 9,505.00
3. 1997 Ford Ranger H 18,500.00 14,000.00
4. 1992 Yamaha motorcycle H 3,500.00 2,245.00
5. Four Wheeler H 5,000.00 3,000.00
6. Six Wheeler H 6,800.00 5,800.00
m. STOCKS, BONDS, SECURITIES AND OPTIONS
ITEM VALUE AT CURRENT
NUMBER DESCRIPTION OF PROPERTY OWNERS SEPARATION VALUATION
7.
Decatur Total Return Fund A H &
Class - cashed in by Daughter
Husband
4,907.26
-0-
IV. CERTJIt'ICATES OI~ DEPOSIT
ITEM VALm~AT CURRENT
NUMBER DESCRIPTION OF PROPERTY OWN.~RS S.~PAflATION VALUATION
8. Pennsylvania Central FCU
Certificate of Deposit H&W 64,708.56 73,983.89
9. First Union H&
Certificate of Deposit Daughter 1,500.00 1,790.00
10. First Union H & Son
Certificate of Deposit 1,500.00 1,790.00
V. CHECKING ACCOUNTS, CASH
ITEM VALUE AT CURRENT
NUMBER DESCRIPTION OF PROPERTY OWNERS SEPARATION VALUATION
VI. SAVINGS ACCOUNTS, MONEY MARKETS AND SAVINGS
CERTIFICATES
ITEM VALUE AT CURRENT
NUMBER DESCRIPTION OF PROPERTY OWNERS SEPARATION VALUATION
VII. CONTENTS OF SAFE DEPOSIT BOX
ITEM VALUE AT CURRENT
NUMBER DESCRIPTION OF PROPERTY OWNERS SEPARATION VALUATION
VIII. TRUSTS
ITEM VALUE AT CURRENT
NUMBER DESCRIPTION OF PROPERTY OWNERS SEPARATION VALUATION
IX. LIFE INSUHANCE (indicate face value, cash surrender value and current
beneficiaries)
ITEM VALUE AT CURRENT
NUMBER DESCRIPTION OF PROPERTY OWNERS SEPARATION VALUATION
11. Minnesota Life Insurance
Policy 18587730 -
Surrendered for cash 2-23-99 H 886.00 -0-
and may have taken loans on
policy after separation
12. Minnesota Life Insurance
Policy 1-858-781 W 687.00 1,421.00
X. ANNUITIES
ITEM VALUE AT CURRENT
NUMBER DESCRIPTION OF PROPERTY OWNERS SEPARATION VALUATION
XI. GUTS
ITEM VALUE AT CURRENT
NUMBER DESCRIPTION OF PROPERTY OWNERS SEPARATION VALUATION
XII. INHERITANCES
ITEM VALUE AT CURRENT
NUMBER DESCRIPTION OF PROPERTY OWNERS SEPARATION VALUATION
XIII. PATENTS, COPYRIGHTS, INVENTIONS, ROYALTIES
ITEM VALUE AT CURRENT
NUMBER DESCRIPTION OF PROPERTY OWNERS SEPARATION VALUATION
XIV. PERSONAL PROPERTY OUTSIDE THE HOME
ITEM VALUE AT CURRENT
NUMBER DESCRIPTION OF PROPERTY OWNERS SEPARATION VALUATION
13. Tools at Mold Base
Industries (including H 1,000.00 1,000.00
micrometers, zero-it, tool
boxes, etc.)
14. Tools at Foust Machine &
Tool H 500.00 500.00
XV. BUSINESS (list all owners, including percentage of ownership, and
officer/director positions held by a party with the company)
ITEM VALUE AT CURRENT
NUMBER DESCRIPTION OF PROPERTY OWNERS SEPARATION VALUATION
XVI. EMPLOYMENT TERMINATION BENEFITS - SEVERANCE PAY,
WORKERS COMPENSATION CLAIMS/AWARDS (include accumulated
vacation and sick leave)
ITEM VALUE AT CURRENT
NUMBER DESCRIPTION OF PROPERTY OWNERS SEPARATION VALUATION
15. Vacation leave H 4,500.00 5,000.00
XVII. PROFIT SHARING PLANS
ITEM VALUE AT CURRENT
NUMBER DESCRIPTION OF PROPERTY OWNERS SEPARATION VALUATION
XVIII. PENSION PLANS (indicate employee contribution and date plan vests)
ITEM VALUE AT CURRENT
NUMBER DESCRIPTION OF PROPERTY OWNERS SEPARATION VALUATION
16.
Mold Base 401(k) -- Husband
took out a loan against 401(k)
for $21,400.00
H
22,428.23 =26,500.00
marital part
XIX. RETIREMENT PLANS, INDIVIDUAL RETIREMENT ACCOUNTS
ITEM VALUE AT CURRENT
NUMBER DESCRIPTION OF PROPERTY OWNERS SEPARATION VALUATION
XX. DISABILITY PAYMENTS
ITEM VALUE AT CURRENT
NUMBER DESCRIPTION OF PROPERTY OWNERS SEPARATION VALUATION
XXI. LITIGATION CLAIMS (matured and unmatured)
ITEM VALUE AT CURRENT
NUMBER DESCRIPTION OF PROPERTY OWNERS SEPARATION VALUATION
XXII. MILITARYN.A. BENEFITS
ITEM VALUE AT CURRENT
NUMBER DESCRIPTION OF PROPERTY OWNERS SEPARATION VALUATION
XXIII. EDUCATION BENEFITS
ITEM VALUE AT CURRENT
NUMBER DESCRIPTION OF PROPERTY OWNERS SEPARATION VALUATION
XXIV. DEBTS DUE, INCLUDING LOANS, MORTGAGES HELD
ITEM VALUE AT CURRENT
NUMBER DESCRIPTION OF PROPERTY OWNERS SEPARATION VALUATION
17. Loan to Sean Limric by
Husband without Wife's
knowledge in H&W 2,195.74 2,601.89
lB. Loan to Viola Limrie by
Husband without Wife's
knowledge in 1995, 1996 & H&W 13,373.60 15,B47.34
1997
19. Loan to Lisa Bailey by
Husband without Wife's
knowledge in 1996 or 1997 H&W 8,000.00 10,500.00
20. Loan paid for Edgardo
Justiano H&W 2,589.96 3,069.02
XXV. HOUSEHOLD FURNISHINGS AND PERSONALTY (include as a total
category and attach itemized list if distribution of such assets is in
dispute)
ITEM VALUE AT CURRENT
NUMBER DESCRIPTION OF PROPERTY OWNERS SEPARATION VALUATION
21. Household furniture and
furnishings in Wife's
possession (including W 3,750.00 3,750.00
collectibles and big screen
TV)
22. Household furniture and
furnishings in Husband's
possession (including H 3,500.00 3,500.00
collectibles)
23. Tools in Wife's possession W
(including snow blower) 900.00 900.00
24. Tools in Husband's
possession (including air
compressor with tool attach-
ments, battery charger, table
saw, drills, power nailer, large
top and bottom tool chest,
etc.) H 4,000.00 4,000.00
25. Husband's hunting and
camping equipment other
than guns H 500.00 500.00
26. Husband's guns H 4,000.00 4,000.00
27. Husband's gun safe H 2,000.00 2,000.00
28. Husband's reloading
equipment (including
reloader, shaker, dies, shell
casings, desk, loaded H 1,000.00 1,000.00
ammunition, etc.)
XXVI. OTHER
ITEM VALUE AT CURRENT
NUMBER DESCRIPl'ION OF PROPERTY OWNERS SEPARATION VALUATION
PROPERTY TRANSFERRED
ITEM DATE m' CONSIDER-
NUMBER DESCRIPTION OF PROPERTY TRANSFER ATION TRANSFEREE
LIABILITIES
ITEM AMOUNT
NUMBER DEBTORS CREDITORS SECURED PROPERTY OWED.
1. H&W Bank of America 23 East Beale Avenue 104,390.17
Mortgage Enola, PA at separation
93,462.39
as of 1-00
2. H&W Wells Fargo 842.73
3. H&W AT&T 1,441.77
4. H&W Advanta 1,109.57
5. H&W Kirby Vacuum Vacuum cleaner 730.00
6. H&W Pennsylvania National
Bank Six Wheeler 6,252.18
7. H&W PA Central FeU Visa 4,143.95
8. H&W Citibank Visa 4,260.63
9. H&W Discover Card 3,169.01
10. W Sears (charges made
by Husband post
separation) =700.00
* At separation unless otherwise stated.
ROBERT V. LIMRIC,
Plaintiff
: IN THE COURT OF COMMON PLEAS,
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 98-868-CML
v.
CONNIE L. LIMRIC,
Defendant
: CML ACTION - LAW IN DIVORCE
CERTIFICATE OF SERVICE
I hereby certify that I have this date served a copy of the Inventory and
Appraisement of Connie L. Limrie on the person in the manner stated below
which service satisfies the requirement of Pa,R.C.P. No. 440.
SERVICE BY FIRST CLASS MAIL TO:
Kristin R. Reinhold, Esquire
SILLIKER & REINHOLD
5922 Linglestown Road
Harrisburg, PA 17112
Date: June 5, 2000
Respectfully submitted,
..-_.-~
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Per Pay Weekly Monthly Yearly
GROSS EARNED INCOME
DEDUCTIONS:
~ .
!
Federal Income Tax
State Income Tax
j
j
F.I.C.A.
Medicare Tax
Local Tax
O.P.T.
Union Dues
Medieal/HospitaVDental Insurance
Mandatory Pension
Voluntary Retirement
Savings Bonds
Other
TOTAL DEDUCTIONS
NET EARNED INCOME
OTHER INCOME:
Child Support
Spousal Support/APL
Interest
Dividends
675.39 8,104.68
603.75 7,245.00
Pension
Other Retirement
Annuity
Per Pay Weekly Monthly Yearly
Trash and Sewer Collection 30.00 360.00
Water 45.00 540.00
Cable Television 32.00 384.00
EMPLOYMENT:
Public Transportation
Parking
Lunch
Education
Supplies/Equipment
Memberships
TAXES:
Real Estate (Not in mortgage) 1,558.00
Income (Not set forth above)
School Occupation
INSURANCE:
Homeowners (Not in mortgage) 364.00
Automobile 1,360.00
Life 519.69
Accident
Health (Not deducted from pay)
Disability
AUTOMOBILE:
Payment
Fuel 40.00 480.00
Maintenanee/Repairs 600.00
i
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INCOME AND EXPENSE STATEMENT OF PLAINTIFF
ROBERT V. L1MRIC
Plalnliff
No. 98-868 CIVIL
v.
Date: February 22, 2000
CONNIE L1MRIC
Defendant
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OTHER INCOME:
WEEK MONTH YEAR
INTEREST
Dividends
Pension
Annuity
Social Security
Rents
Royalties
Expense Account
Child & Spousal Support
Unemployment Compensation
Workmen's Compensation
Totals:
Total Income:
EXPENSES:
Weeklv Monthlv Yea rlv
(Fill in appropriate column)
Home
Mortgage/Rent
Maintenance
Utlllties-
Electric
Gas
Oil
Telephone
Refuse
Water, Sewer
Furniture
$
200.00
Employment
Public Transportation
Lunch
1$
25.00 I
Taxes
Real Estate
Personal Property
-'-r-/'
ROBERT V. LIMRIC
PlaintifTlRespondent
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PA
: NO. 98-E68-CML
v.
CONNIE LIMRIC,
DefendantlPetitioner
: CML ACTION - LAW
: IN DIVORCE
ORDER
ANDNOWthis/~#..daYOf fIl~
, 1998, after review of the attached
Petition for Special Relief regarding payment on a loan, it is hereby ORDERED
AND DECREED that a rule is hereby issued upon Respondent Robert V. Limrie
to show cause, if he has any, why the relief requested should not be granted.
RULE RETURNABLE ;; 0 days after service.
BY THE COURT,
J.
. .....
_ FILED -(;.FileF
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from Petitioner's settlement was a $60,000.00 Certificate of Deposit at
Pennsylvania Central Federal Credit Union.
7. At the time of separation, there was a loan with Pennsylvania Central
Federal Credit Union secured by the Certificate of Deposit in the amount of
approximately $60,000.00.
8. The $60,000.00 loan had been used to payoff Respondent's 1997 Ford
Ranger (approximately $20,000.00), to pay $10,000.00 for Respondent's mother's
settlement to her now ex-husband in her divorce, to payoff the second mortgage
(approximately $15,000.00), and to payoff joint debt.
9. The balance of the proceeds from the loan with Pennsylvania Central
Federal Credit Union were used by Petitioner to pay the household bills after
Respondent left on December 13, 1997, until Petitioner began receiving support.
10. At the time of the parties' separation, Respondent promised to pay the
loan with Pennsylvania Central Federal Credit Union. Respondent indicated this
intention in writing. A copy of said writing is attached hereto marked Exhibit "A"
and incorporated herein by reference.
11. Respondent again agreed at the support conference on February 18,
1998, to continue making the $200.00 per week payments on the loan to
Pennsylvania Central Federal Credit Union.
12. The agreement of Respondent to continue making said loan payments
was not incorporated into the support order because the PACSES system would
not allow such and the Domestic Relations ofticer determined that such a
provision could not be enforced through Domestic Relations.
13. Petitioner tiled an appeal to the support order requesting that
Respondent's agreement to make the loan payments be incorporated into the
support order.
14. At the time of the support appeal hearing before Judge Oler,
Respondent indicated that he was no longer willing to make said loan payments.
15. Petitioner needs the funds in the Certificate of Deposit at
Pennsylvania Central Federal Credit Union to support herself in the future
because of her inability to work.
16. Petitioner believes and therefore avers that unless Respondent is
ordered to make payments on the loan with Pennsylvania Central Federal Credit
Union, Respondent will not do so,
17. Petitioner believes and therefore avers that unless Respondent is
ordered to make payments on the loan at Pennsylvania Central Federal Credit
Union, the loan will default and the Certificate of Deposit will be taken to pay the
loan.
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PA
: NO. 98-868-CIVIL
ROBERT V. LIMRIC
PlaintilT/Respondent
CONNIE LIMRIC,
Defendant/Petitioner
: CIVIL ACTION - LAW
: IN DIVORCE
CERTIFICATE OF SERVICE
I hereby certify that I have this date served a copy of the Petition for Special
Relief on the person in the manner stated below which service satisfies the
requirements of Pa.R.C.P. No. 440.
SERVICE BY FIRST CLASS MAIL TO:
Kristen R. Reinhold, Esquire
SILLIKER & REINHOLD
5922 Linglestown Road
Harrisburg, PA 17112
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NORA F. BLAIR. ESQUIRE
B440 JONESTOWN ROAD
POST OFFICE BOX 02ttl
HARRISBURG, PA 17112.0216
(717US41a1428
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ROIn:RT V. L1MRIC.
PlallltllT/RcSllOlldcllt
: IN TilE COURT 011 COMMON I'LEAS
: CUMln:I{LANI) COUNTY, I'.:NNSYLVANIA
v.
: NO. 98-868-CIVIL
CONNIE L. L1MRIC.
I)cfclldallt/Pctitlollcr
: CIVIL ACTION - LA W
: IN DIVORCE
ORDER
AND NOW this Ji"fAdaYOf mA Y
, 1998, after review of the attached
Petition for Special Relief, a rule is hereby issued upon Plaintiff Robert V. Limric to show cause, if
,
he has any, why the relief requested should not be granted.
IT IS FURTHER ORDERED AND DECREED that Robert V. Limric is prohibited from
selling his 1995 Ford Explorer or any of its accessories until further Order of Court.
A IltAlt./,A/f:", ,".s Ec,/.;ut,Jt.J I;IZ.. W~AU..selA t/ #
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BY THE COURT:
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NORA F. BLAIR. ESQUIRE
D440 JONESTOWN ROAD
POST OFFICE BOX 821a
HARRISBURG. PA 1711,.0,16
<<(17) D41.1428
@MAY U:) 199,8
ROBERT V. LIMRIC,
Plaintiff
IN 'rilE COUR'l' OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 90-868-CIVIL
CONNIE LtMRIC,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
PLAINTIFF'S RESPONSE TO DEFENDANT'S SECOND
PETITION FOR SPECIAL RELIEF
through his attorney, Kristin R. Reinhold, Esquire, and
respectfully presents his response to Defendant's Second Petition
AND NOW comes the Plaintiff, Robert V. Limric, by and
for Special Relief:
1. Admit ted.
2. Admit ted .
3. Admitted.
4. Admitted.
5. Admitted.
6. Denied. It is denied that at the time of the
parties' separation on or about December 13, 1997, the only asset
that remained was the Petitioner's Certificate of Deposit in the
amount of $60,000.00. To the contrary, a majority of the money
received from the personal injury settlement was used to make
improvements on the marital home, including a second story and
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garage; the deed of which is held jointly in the names of the
Defendant and her mother. Various other items of personalty
existed, including but not limited to a four-wheeler, a six-
wheeler with trailer, two vehicles, a motorcycle, and savings
accounts and Certificates of Deposit for the parties' two
children.
7. Admitted. By way of further answer, approximately
one week before the parties separated, the Defendant borrowed the
remaining equity in the Certificate of Deposit, approximately
$33,000, which she used to payoff a second mortgage and her
credit cards. The remainder was placed into her personal
savings.
B. Admitted in part, denied in part. It is admitted
that the $60,000 loan was used to payoff the loan on the
Plaintiff's 1997 Ford Ranger, to pay for Plaintiff's mother's
divorce in the approximate amount of $10,000, and to payoff a
second mortgage. It is denied that $20,000 was used to payoff
Plaintiff's 1997 Ford Ranger. To the contrary, the amount was
approximately $17,000. It is denied that monies were used to pay
off joint debts. To the contrary, Defendant used a portion of
the loan to payoff all of her outstanding credit card debts held
in her name alone, and not the Plaintiff's name.
9. Denied. Plaintiff is without specific knowledge as
to the truth of this averment, and therefore it is denied. By
way of further answer, Plaintiff believes and therefore avers
that Defendant still holds several thousand dollars derived from
the loan against the Certificate of Deposit with which she could
pay the minimum monthly payment in order to preserve this marital
asset.
10. Admitted in part, denied in part. It is admitted
that Plaintiff verbally agreed to pay a portion of the loan with
the Pennsylvania Central Federal Credit Union. It is denied that
this represented the complete agreement. By way of further
answer, the parties agreed that Mr. Limric would continue to make
payments on the PCFCU loan in return for several items of
personal property which he wanted from the home. Additionally,
Plaintiff agreed to remove his name from the Deed on the marital
home. Plaintiff followed through on his side of the agreement by
transferring ownership of the marital home unto Defendant and her
mother. Immediately afterward, Defendant refused to give
Plaintiff any of his personal property. Plaintiff continued to
make numerous requests for his personal property, all of which
were denied by Defendant. Plaintiff made payments in the amount
of $200 per week on the PCFCU loan from the date of separation,
December 13, 1997, until April 6, 199B, at which time he stopped
due to Defendant's refusal to return any of his personal property
to him.
11. Admitted. By way of further answer, Plaintiff
still believed that if he acted in good faith and continued to
and would return it as soon as Defendant returned his personal
property which he had requested on numerous occasions in the
past. At the time of the parties' separation in mid-December,
1997, the Plaintiff and Defendant agreed that Plaintiff would
remove his name from the Deed of the marital home and would make
regular payments on the parties' loan with the Pennsylvania
Central Federal Credit Union. In return, Plaintiff would be
entitled to several items of personal property acquired during
the parties' marriage. Plaintiff honored his side of the
agreement by transferring ownership of the marital home unto
Defendant and by making regular payments on the Pennsylvania
Central Federal Credit Union loan. Defendant reneged on her side
of the agreement and refused to allow Plaintiff any of the
personal property which he requested from the marital home.
7. No responsive pleading required. If a responsive
pleading is required, it is denied.
B. No responsive pleading required. If a responsive
pleading is required, it is denied.
9. Denied. It is denied that Defendant has no other
transportation available. Defendant lives with her mother in the
marital home and has access to her mother's automobile.
10. Denied. Plaintiff is without specific knowledge
as to the truth of this averment, and therefore is it denied.
11. Admitted.
12. Admitted.
WHEREFORE, Plaintiff respectfully requests this
Honorable Court dismiss Defendant's Petition for Special Relief
and refer this matter to a Divorce Master to more appropriately
resolve this issue within the context of equitable distribution.
Da te: (5) I 0 ) CJ rr-
Attorney for Plaintiff
TO REPORT ERRORS OR MA~E l~aUIRIES
AD OUT ~OANS I,lARKEONITH A~ "
WRITE TO
042 0 PENNSY~VANIA CENTRA~ FCU
959 EAST PARK DRIVE
HARRISBURG PA 17111-2910
'a.liOQI'I..D.'O.....llo,Q~,'-"..DU'
HICfOOot,C"...o' ,.."",.,. ""'101'. .,.. ro, IIC
_ 01 Th. ....,. fa ,... .DO"ln 0' .1" 01 C"I~
717/564-4BBI
125001BP 434.
.
17250-019
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04-30-98
. .
ROBERT V ~IMRIC
&/OR CONNIE ~ ~IMRIC 198-52-0221
PO BOX 9
ENO~A PA 17025-0008
1...11I...11I.....1.1.1.1.11...11...11...1.1../1...1.1..1.../1
. ANNUAL FEE OR I
OA TE TVPE OF AccduNT I TYPE OF TRANSACTION PERCENT FINANCE lATE CHANGES TO BALANCE
.....0 UA VII AGE RATE CHARGE' CHARGES BALANCE
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040298
043098
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040288
040988
043088
04'17~8
04301lB
043098
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019 SHARE ACCOUNT PP.E~IOUS BA~ANC~ 5322
DEPOSIT PAYRO~~ , 17200 22522
PAYMENT TRANSFER ,,' , ' 17200- 5322
, ! NEW BA~ANC" 53;22
-- - - - -- - -- -.. -- - -- - - - - - - -.. - - - - - - - -- - - - - - _i_ _ _ _ __ ..:_ __ _ _.. _.. _ _ _:_ _ _.. _ __.. _ _ _ _!_ __
029 INSTA~~MENT ~OAN ! PREV,IOUS BA~ANCE 59523A5
PAYMENT TRANSFER 79,5,. 7! 8343- 5B43002
ADVANCE INS PREMIUM 'i' 7432 5850434
i I NEW BA~ANC~ 5850434
-----------------------------_.._--------:------~------.._---~-----------~--
078 SHARE DRAFT ACC ! PREl/iIOUS BA~ANCE 10'15
DEBIT DUP TIT~E F 1 1 500- 5115
FEES/CHGS EFT I 1:00 100- 4115
- - - - -- --- ---- -- -- -- -- - - -- - - - -. - - - - -. - - - -1.. - - - - .1- ~~~ - ~~~~~~~ - - - -- -- - -_ ~~~_
OA9 CERTIFICATE ACT ' PREV,IOUS BA~ANCE 65B8587
NO TRANSACTIONS THIS PERIOD ! i NEW BA~ANC" B5B6587
RATE 8.0000% ISSUED OB/25/9B MATURES 09/2~/Ol I
! !
.-----h.----------------------yEAR TO DATE TOTALS-----.-------------____________
!
5957.70 REGU~AR DIVIDENDS :,,1:
1042.83 ~DAN INTEREST
A NEWLY CREATED CREDIT UNION MONEY ~RKET MAKES
I' t
INVESTING YOUR MONEY EASY, SAFE!.& BE~EFICIAL i
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See Reverse Side For Important Information
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f;~!! EXHIBIT, 'i'-
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4. PlaIntiff requested the 16 items as set forth in
Exhibit "A", ilttached hereto and incorporated herein.
5. Plaintiff executed a Deed in good faith
transferring ownership of the marital home unto Defendant and her
mother sometime in December of 1997.
6. Immediately after Plaintiff executed a Deed
transferring ownership, Defendant refused to give Plaintiff any
of the personal property that he had been promised.
7. Despite Defendant's breach of the parties' oral
agreement, Plaintiff continued to make regular weekly paym~nts in
the amount of $200.00 on the Pennsylvania Central Federal Credit
Union loan in good faith, from mid-December 1997 until early
April 199B.
B. Plaintiff continued to make numerous requests upon
the Defendant for the personal property which she promised him in
return for the transfer of real estate and the payment of the
Pennsylvania Central Federal Credit Union loan from the time of
the parties' separation until April of this year.
9. Plaintiff has received none of the items as set
forth in Exhibit "A" to date.
10. Plaintiff believes and therefore avers that
Defendant may sell some of his personal property as set forth in
Exhibit "A" to be vindictive.
r,
"
. . .
ROBERT V. LIMRIC,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
98-868 CIVIL TERM
CIVIL ACTION - LAW
CONNIE LIMRIC,
Defendant
IN DIVORCE
IN RE: PETITION FOR SPECIAL RELIEF
ORDER OF COURT
.AND NOW, this 27th day of May, 1998, after
hearing on the various Petitions for Special Relief, the Court
will enter an order that will address the relief requested in
each petition. Nothing contained in this order shall in any way
be construed to determine the issues of marital property,
marital debts or equitable distribution. Those matters are left
for the sole determination of the Master that may be appointed
to hear those matters. In addition, the Court makes no
determination as to whether or not a partial agreement in
connection with equitable distribution exists between the
parties.
This issue is also reserved for determination by the
Master.
With the foregoing in mind, the Court issues the
following order:
1. Husband is directed to forthwith return the
1995 Explorer to Wife. The truck is to be returned in the
condition in which it was taken. Wife shall be entitled to full
and exclusive use and possession of said vehicle pending any
Master's hearing. Wife shall be responsible for the payment of
upkeep and insurance thereon.
2. Wife shall immediately deliver or make
available to Husband the personal property listed in Exhibit A
of Husband's Petition for Special Relief. The personal property
ASSETS OF Tim l'Alrrms
Plaintiff marks on the list below the items applicable to the case at bar and
itemizes the assets on the following pages,
(x) 1. Real Property
(x) 2. Motor Vehicles
() 3. Stocks, bonds, seeuritics and options
(x) 4. Certificates of Deposit
() 5. Checking accounts, cash
() 6. Savings accounts, money market and savings certificates
() 7. Contents of safe deposit boxes
() 8. Trusts
(x) 9. Life insurance policies (indicate face value, cash surrender value
and currcnt beneficiaries)
() 10. Annuities
() II. Gifts
() 12. Inheritances
() 13. Patents, copyrights, inventions, royalties
() 14. Personal property outside the home
() 15. Business (list all owners, including percentage of ownership, and
officer/director positions hcld by a party with company)
() 16. Employment tennination benefits-severance pay, Workers' Compensation
claim/award
() 17. Profit sharing plans
() 18. Pension plans (indicate employee contributions and date plan vests)
(x) 19. Retirement plans, Individual Retirement Accounts
() 20. Disability payments
() 21. Litigation Claims (matured and unmatured)
() 22. MilitaryN.A. benefits
() 23. Education benefits
() 24. Debts due, including loans, mortgages held
() 25. Household furnishings and personalty (include as a total category and
attach itemized list if distribution of such assets is in dispute)
() 26. Other
~I"IUTI\I. l'IUWElrr\'
I'lnintiff lists nllll1l1rllnl property in which either ur both spouses hllvc II
legal or equltllble interestlndivldnnlly or with IIny other person liS of the dnle Ihis IIclion
commcnccd.
11l:l1111lUllhll UmllllllulIllL l'IUI><;i11 l'iJIIIIIJlUlillIill Vallie ns oflJolc
Action Commenced
I. 1II11l1lnllullllc hll~lmlltl. wife & $120,000,00
2J E 1 ":al.: Au'nlle: \\irl:'~ muther
r:1I11111.I'^ 1711l~
2, IW~l'lIflll:\llltll.:r hushlllllJ &. wile $ 15,000.00
3, 11JIJ1 rUhlltnll~l:r husband & wife $ 14,000.00
4, \'Cllllh:1I11:11I'tkpmil wili: approximately
$ 70,000.00
5, .1iI1~ 1'111" husband approximately
$20,000.00
6. uun cnllcl:llnn hushmuJ approximalely
&.lI11ll\nli: $10,000,00
7. Itllll\ hll!ohlllld approximately
$ 2,000.00
8. 11...,1\ wile $ 1,500,00
9. .1.\\IIc:.:l\:r hushand & wif\: $ 3,000.00
10. CIIIII clllh:cliulI hushand $ 500.00
II. 1l.\\III:dc,&llllllcr hushmu.llllul wife $ 5,800,00
12. 11}l)2 YUlIIlllllllIUllllff;)clc hushnml $ 2,000.00
13. t-.tillllc~lllll ~lllIUllll.ili: hushlllld $ 886.00
IUillllllm:I'lllic)'
14, I:llllcclihlc\" curll' cllhlncls wile $ 10,000,00
IS, IIl'^ hl8 "'''" T. V, \,ire $ 1.800,00
IfI, MlIllllll\'Il\T.V. \\ili: $ 800,00
17, 1.1\'11111 1(1I1I11I11I1L1 wile $ 2,000.00
1)lllilllll(tMllIIl\lllliIIllC
18 lOtlllllllll(' wile $ 2,5110,OO
1'1 lI~hlh", husbllnd $ 800.00
III IllllllllllllllllllC wile $ 300,00
II \'\(II;I\\.'\'lllIiIlIllCIII wile $ 6011.00
NON-MARITAL PROPERTY
Plaintiff lists all property in which a spouse has a legal or equitable
interest which is claimed to be excluded from marital property:
Ilelll Numher
I.1.!:.Ktinlion of IJro~
Reason nlf l:xclusiol1
I.
N/A
PROPERTY TRANSFERRED
Ilem NumhcT Descrintinn of Pro~ Dale of Transfer Consideration Person In Whom
Transferred
I. .44 Super U1ackhu\\k pistol 1998 $ 150,00 Steve Bailey
2, 1991 Yamaha motorc)'cle 12198 $2,000,00 Wayne Feeser
',I^J1I1,ITIES
II~Jtililllllb~1
lJmllllllllll.uLI"UI'''I)
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I'!nU1~J!lJill
llJ:b1ru
t\II1I1Ul1ll1Wcll ns
or dale AClioll
Commenced
I. 1111111110111: IlIlIIk IIf hushlllul& S93,4112.00
Al1lcrlCII win: (1/00)
2, crcllll CllltI l'i1)' IInnk hushlllltl& $4,2f>O,00
1',,:Ii:uc:d "ire (12130/97)
J. 1:11:1111 Cllld 1',llTl'lJ hushmuJ& $4,143,00
VISA wife (12/9/97)
,I. &:lclllI&:1I111 l>i5l:U\'I,," huslmnd & S3,I1I9,OO
wife (1213197)
S, hum I'ACFCU hU!lbDlld & SS8,877.00
wire (2/28/98)
(,. limn PANnliulllll husband & $(,,2S2,OO
Blink wife (12113/97)
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ROBERT V. L1MRIC,
Plaintiff
IN TIlE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 911-11611 CIVIL
CONNIE LlMRIC,
CIVIL ACTION - LA W
IN DIVORCE
Defendant
MOTION FOR APPOINTMENT OF MASTER
Robert V. Limric, Plaintirt: moves the Court to appoint a Master with
respect to the following claims:
(x) Divorce
( ) Annulment
() Alimony
(x) Alimony Pendende Lite
(x) Distribution of Property
( ) Support
(x) Counsel Fees
(x) Costs and Expenses
And in support of the Motion states:
J. Discovery is complete as to claims for which the appointment of
Master is requested.
2. The Defendant (x) has ( ) has not appeared in the action
( ) personally (x) by her allomey, Nora Blair. Esquire.
3. The statutory ground for divorce is: 330 I ( c) and (d)
Irretrievable breakdown and the parties have been separated in
excess of two years
4. Delete the inapplicable paragraph(s):
(a) The action is not contested.
(h)
An Agrccmcnt hils hccn rCllchcd with rcspcctto the
Illllowing claims:
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(e) The IIction is eontested with respect to the following
claims: Divorce. Alimony Pendente Lite. Equitable
Distribution, Counscl Fees, Costs and Expenses.
5.
The action ( ) involves (x) does not involve complex issues 01' law
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or Illcl.
6. The hearing is expected to take one day.
7, Additional information, if any, rclevantto the motion:
Date:
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AND NOW, this .i/J,,/l./tl'(j ,9B ,2000. F: i.!,ltc.d ['e~l'ic;.~'\. ,Esquire, is
hereby appointed Master with respect to the lollowing claims: -1Jlt/
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BY THE COURT:
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and his life burdensome. To the contrary, Plaintiff Is not the
innocent and Il\lured spouse and if indignities have been offered they
were offered by Plaintiff on Defendant.
9. Admitted.
10. Denied. Defendant is without knowledge of what Plaintiff has been
advised.
11. Denied. Defendant is without knowledge of what Plaintiff wants.
COUNTERCLAIM
ALIMONY PENDENTE LITE, COUNSEL FEES, COSTS AND
EXPENSES UNDER SECTION 3702 OF THE DIVORCE CODE
12. The eleven prior paragraphs of this pleading are incorporated herein
by reference thereto.
13. Defendant is unable to sustain herself dUring the course of litigation.
14. Defendant lacks sufficient property to provide for her reasonable
needs and is unable sustain herself through appropriate employment.
15. Plaintiff has sufficient resources available to sustain himself, pay his
counsel fees, costs and expenses and provide assistance to Defendant
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for her support, counsel fees, costs and expenses.
16. Plaintiff is in a better position to provide for Defendant than
Defendant can provide for herself.
'-",
ROBERT V. LIMRIC,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS,
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08-808-CIVIL
CONNIE L. LIMRIC,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
CERTIFICATE OF SERVICE
I hereby certify that I have this date served a copy of the Answer and
Counterclaim to the Divorce Complaint on the person in the manner stated below
which service satisfies the requirement of Pa.R.C.P. No. 440.
SERVICE BY FIRST CLASS MAIL TO:
Kristin R. Reinhold, Esquire
5922 Linglestown Road
Harrisburg, Pa 17112
Date: May 10, 1999
Respectfully submitted,
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VERIFICATION
I verify that the statement made in the foregoing document are true and
correct to the best of my knowledge, information and belief. I understand that the
statements therein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating
to unsworn falsification to authorities.
.
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ROBERT V. LIMRIC,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS,
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 98-B6S-CML
CONNIE L. LIMRIC,
Defendant
: CML ACTION - LAW IN DIVORCE
CERTIFICATE OF SERVICE
I hereby certifY that I have this date served a copy of the Additional Count
to Divorce Complaint on the person in the manner stated below which service
satisfies the requirement ofPa.R.C.P. No. 440.
SERVICE BY FIRST CLASS MAIL TO:
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Kristen R. Reinhold, Esquire
SILLlKER & REINHOLD
5922 Linglestown Road
Harrisburg, Pa 17112
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Date: May 17, 2000
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I. BACKGROUND INFORMATION
A. PARTIES
HUSBAND
NAME
ADDRESS
AGE
DATE OF BIRTH
PLACE OF BIRTH
SOCIAL SECURITY NUMBER
HEALTH
EMPLOYER
OCCUPATION
LENGTH OF SERVICE
EDUCATIONAL BACKGROUND
WIFE
NAME
ADDRESS
AGE
DATE OF BIRTH
PLACE OF BIRTH
Robert V. Limric
4 East North Avenue
Enola, P A
40
January 27,1960
Philadel phia, Pennsylvania
196-52-0221
Good
Mold Base Industries
Machine Shop Foreman
19 Years
Vo-Tech Diploma
Machine Shop Training
Firefighter Certification
Search and Rescue Certification
Hazmat Certification
Repelling Training
Computer Training
Connie L. Limric
23 East Beale Avenue
Enola, PA 17025
39
January 16, 1961
Harrisburg, Pennsylvania
I HUSBAND
WIFE
I None
None.
F. PROCEEDINGS INFORMATION
DATE COMPLAINT FILED
DATE OF SERVICE
MANNER OF SERVICE
ISSUES RAISED IN
COMPLAINT
DATE OF
ANSWEWCOUNTERCLAIM
ISSUES RAISED IN
COUNTERCLAIM
BIFURCATION
PREVIOUSLY RESOLVED
ISSUES
February 13, 1998
Certified Mail
Divorce, Equitable Distribution
May 13, 1999
May 17, 2000
Counsel Fees Costs & Expenses
Alimony
None.
None.
II. MARITAL ASSETS AND DEBTS
Defendant has filed and Inventory and Appraisement setting forth
complete information regarding marital assets and debt. The following is
a list of the marital assets and debts of the parties with an indication of
the proposed distribution of the assets and debt:
ITEM DATE OF MARITAL VALUE TO VALUE TO
NO. ASSET VALUE VALUE LIEN WIFE HUSBAND
1. House at 23 East Benle 1.28-00 60,000.00 (104,390.17) (44,390.17)
2. 1995 Ford Explorer 6-2-00 9,505.00 9,505.00
3. 1997 Ford Ranger 6-2-00 14,000.00 l4,000.00
4. 1992 Yamaha Motorcycle 6-2.00 2,245.00 2,245.00
5. Foul' Wheeler 6-2-00 3,000.00 3,000.00
6. Six Wheeler' & trlliler 6-2-00 5,BOO.00 (0,252.10) (452.10)
7. Decatur Fund 12-13-97 4,907.26 4,907.26
B. Pa Centrnl FCU CD 3-31-00 73,983.BB (51,:142.72) 73,9B3.BB (51,342.72)
9. First Union CD (Daugh.) 6-2-00 1,790.00
10. First Union CD (Son) 6-2-00 1,790.00
11. Minnesota Life (H) 2-23-99 ~8B6.00 ~8B6.00
12. Minnesota Life (W) 12-31.99 1,421.00 1,421.00
13. Tools at Mold Base 6-2-00 1,000.00 1,000.00
14. Tools at Foust 6-2-00 500.00 500.00
15. Vacation leave 12-13.97 4,500.00 5,000.00
16. Mold Base 401(k) 6-2-00 =26,500.00 =26,500.00
17. Loans to Sean Limric 6-2-00 2,601.B9 2,601.B9
IS. Loans to Viola Limric 6-2-00 15,B47.34 15,847.34
19. Loans to Lisa Bailey 6-2.00 10,500.00 10,500.00
20. Loan paid for Edgardo 3-20-95
Justiano 9-2B-96 3,069.02 3,069.02
21. Household (W) 6-2-00 3,750.00 (730.00) 3,020.00
22. Household (H) 6-2.00 3,500.00 3,500.00
23. Tools (W) 6-2-00 900.00 900.00
24. Tools (H) 6-2.00 4,000.00 4,000.00
25. Hunting & camping Eq. 6-2.00 500.00 500.00
26. Guns 5-29-9B 4,000.00 4,000.00
27. Gun Safe 6-2-00 2,000.00 2,000.00
2. Wells Fargo Credit Card 12-16-97 (042.73) (042.73)
3. AT&T credit card 12-15-97 (1,441. 77) (1,441.77)
4. Advanta 12.24.97 (1,109.57) (1,109.57)
7. PA Central FCU Visa l2.09.97 (4,143.95) (4,143.95)
B. Citibank Visa 12-05.97 (4,200.63) (4,260.63)
9. Discovel' CDI'd
10. Senl's (post-sepnr'ntion)
12-03-97
1998
(:I,1011.01)
(700,(10)
(:I,1011.01)
III. LISTING OF DISPUTED PERSONAL PROPERTY
Plaintiff has indicated that he would like to have the light bar that is on
Defendant's truck. At one time, Plaintiff removed said light bar from Defendant's
truck and was ordered to return the light bar. The light bar cost less than $600.00
new, is affixed to Defendant's vehicle and Defendant would like for it to remain
such.
Defendant has the Four Wheeler which was purchased for the parties' son
prior to separation. Defendant originally left the Four Wheeler at the marital
residence, but later returned and took the Four Wheeler without Defendant's
knowledge. Defendant would like to have the Four Wheeler returned to the
parties' son.
IV. LISTING OF NON-MARITAL ASSETS
A. REAL ESTATE
The marital residence was owned by Defendant's mother and step-father.
The parties began to reside with Defendant's mother and step-father with the
agreement that the parties would pay the mortgage on the house. At some point
after that the parties needed to borrow money to payoff credit card debt and other
liabilities but had no property to establish a security interest. Defendant's mother
and step-father agreed to allow the parties to establish a mortgage against the real
estate. It was necessary to add the parties' names to the title to the real estate in
order to establish the mortgage. The mortgage from Defendant's mother and step-
father was paid off and a new mortgage established in the parties' names only.
Therefore, the parties have a fifty percent (50%) ownership interest in the real
estate but are solely liable on the mortgage on the property.
B. WIFE'S PERSONAL INJURY SE'ITLEMENT
The parties to this action originally separated in 1991 when Plaintiff
threatened Defendant with bodily harm if she did not leave. Defendant left the
residence and Plaintiff continued to reside in the marital residence with
Defendant's mother and step-father. In November 1993, Defendant was involved
in an accident and suffered a head trauma injury which has resulted in short-term
memory loss, equilibrium problems, vision problems, comprehension difficulties,
post-traumatic stress and anxiety disorder. When Defendant lef't. the hospital
following the accident, she could not live alone so she lived in the marital
residence although the parties were still living separate and apart and both parties
dated other people. Defendant received her settlements from the accident in the
amount of $239,000.00 in February 1995. Defendant received a worker's
compensation settlement for $28,000.00 in May 1997. The parties did not reconcile
until sometime in late 1996. Defendant believes that said reconciliation was done
by Plaintiff in order to gain access to Defendant's settlement money.
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V, PENSIONS
Plaintiff has a 401(k) account with his present employer, Mold Base
Industries. The value of the 401(k) account at the time of separation was
$22,483.23. Plaintiff has not provided information to determine the earnings on
said fund since the time of separation. In addition, since separation Defendant
has taken out a loan against the 401(k) for almost the full value of the account.
,
Defendant had a retirement account but the parties decided to cash in that
account during the marriage.
VI. INCOME AND EXPENSES
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Defendant has filed an Income and Expense Statement setting forth her
current income and expenses.
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VIT. COUNSEL FEES AND COSTS
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Defendant has incurred counsel fees and costs in excess of $6,000.00 to date
and will incur counsel fees of at least $2,500.00 if this matter is fully litigated
through the Master's hearing. Much of the counsel fees has been a result of
actions taken by Plaintiff such as when it was necessary to file a Petition for
Special Relief for the return of Defendant's vehicle after Plaintiff came in the dead
of night and took the vehicle and advertised the vehicle for sale.
It has been necessary for Defendant to borrow money from various people
in order to pay her counsel fees but has an outstanding balance in excess of
$3,000.00 at this point.
VIII. EXPERTS
Defendant does not plan to call any expert witnesses.
IX. OTHER WITNESSES
CONNIE L. LIMRIC - Defendant will testify about the information set forth
in this document, her Inventory and Appraisement and Income and Expense
Statement as well as other relevant information.
JOSEPHINE VOGELSONG - Defendant's mother will testify about the
arrangements made between the parties and Defendant's mother and step-father
with respect to the real estate. She will further testify about the parties' time of
separation and the condition of Defendant after the accident and that Plaintiff told
Defendant on numerous occasions that he would pay the loan on the certificate of
deposit and not ask for any part of the certificate of deposit.
VICTOR KRESGE - Defendant's father will testify about hearing Plaintiff
tell defendant that he would payoff the loan on the certificate of deposit and let
Defendant have the entire certificate of deposit. He will further testify that
Plaintiff said he did not want any part of the house or Defendant's money and the
condition of Defendant after the accident.
AARON GOLD - Defendant's friend will testify about hearing Plaintiff
indicate that he did not want Defendant's money and saw Plaintiff sign the note
indicating that Plaintiff would pay the loan on the certificate of deposit and not
touch the certificate of deposit.
X. LISTING OF PROPOSED EXHmITS
A. Copies of Defendant's legal bills.
B. Note signed by Plaintiff dated December 21, 1997 indicating he will
"pay the loan off and not touch her CD".
C. Kelley Blue Book printout for 1995 Ford Explorer.
D. Kelley Blue Book printout for 1992 Yamaha.
E. Decatur Group statement dated January 20, 1998.
F. Copies of checks to Viola Limric.
G. Copies of checks to Sean Limric.
H. Documentation of money to Lisa Bailey.
.~
D. If Plaintiff challenges the alimony award, after entry, based on
Defendant's alleged cohabitation and the Court determines that there
is no cohabitation under the Divorce Code, then Plaintiff must pay
Defendant's attorney fees to defend the action.
E. Plaintiff pay the loan secured by the Pennsylvania Central FeU
certificate of deposit with the payment indicated to be necessary for
preservation of the certificate of deposit to provide for Defendant's
future support and maintenance.
F. Defendant retain the house at 23 East Beale Avenue and be solely
responsible for payment of the mortgage on said property.
G. Defendant retain the Pennsylvania Central FCU certificate of deposit
as her sole and separate property.
H. Plaintiff retain the 401(k) at Mold Base Industries as his sole and
separate property.
I. Plaintiff retain as his sole and separate property any payments made
on the loans to Sean Limric, Viola Limric, Lisa Bailey, and Edgardo
Justiano.
J. The parties retain all personal property and motor vehicles that are
in the party's possession except as stated below.
K. Each party retain their life insurance policy or its cash value as the
party's sole and separate property.
L. Plaintiff pay the balance on Defendant's Sears account, pay the
balance on the Pennsylvania Central FCU Visa account, pay the
balance on the Citibank Visa account and pay the balance on the
Discover Card.
M. Plaintiff secure the Keystone Financial f/nJa Pennsylvania National
Bank loan with the six wheeler and pay the balance on said loan.
N. Plaintiff return the funds to the parties' children that were in the
Decatur Fund that was titled to Plaintiff and the parties' daughter,
allow the parties' children to retain the certificates of deposit that are
or were titled to Plaintiff and the parties' children, and return the four
wheeler to the parties' son.
v,
NO. 98-868 CIVIL
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ROBERT V. LlMRIC.
Plaintiff
IN TilE COURT OF COMMON PLEAS
CUMI.lERLAND COUNTY. PENNSYLVANIA
CONNIE LlMRIC.
Defendant
CIVIL AC'rION - LA W
: IN DIVORCE
PLAINTIFF'S 1'lmTlUAL STATEMENT
I. LIST OF ASSETS:
See document al\ached hereto as Exhibit "A".
2. EXPERT WITNESSES:
(a) Mark W. Heckman
1309 Bridge Slrec\
New Cumberland, I' A 17070
Mr. Heckman shall testify as to the vulue of thc marital homc as per his
appraisal report dated January 28. 2000.
(b) Robert A. Ensminger
3557 Elmcrton Avenuc
Harrisburg, I' A 17109
Mr. Ensminger shall testify to thc value of personal property located in the
marital home, as per his appruisal report duted May 22, 2000.
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3.
NON-EXPERT WITNESSES:
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(a) Robcrt V. Limric, Plaintiff, shall testify on his own behalf regarding
all issues rclevantto equitable distribution.
(b) David A. Lloyd
37 Sherwood Circle
EllOla.PA 17025
Mr. Lloyd. Chief of Midway Fire Company. shall testify to his
observations of Mrs. Limric in performing search and rescue tasks,
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EXIIIBIT "A"
LIST 011 MAIUTAL ASSETS
lIem A11~J Ynhl~ Dnh:uf NlllHIIIITillll Llcll~&
l:llllllh~[ Yn1J!ulillll 1'lllliuJI l~mllllhll!lIm
I. MlUilnl humc - 23 EII.~t SI~O,OOO JlIllllllty 2M, 201111 Wilc'slIIulhcr is II MllrI~lIgc: Blink uf
I1Cllh:^\'cllllc,EllUllI,I'A jllinllcllum 1\lI1cricnSC)J,.If,2
(1/00)
~. IW~ Fmll b:plun:r Sll,OOU Cmlen! NUllc NUllc
(wife)
3, 1997 Fun-tltllngcr SI,I,OUO Current NUlle NOllc
(husblllllJ)
4. CCTtilicllIC ofl>cpusit S73.'IK3 03/3110U NIlIIC PACFCLJ Inon
(wile) Sl1.3,I~
l. -10U" Illlln S~~,4~K 12/l}7 l'ost-scl'lIIIUinn S~0.ll6.00
(husband) cUlllrillllliollS lIull Il/311(0)
npprccinlinn
6. GUll collectiun, Sl.~9l 3m/UU NOllc None
gun sufe. nnd looding
equipment
(hu,bllnd)
7. Tools ill possessioll of S2,OUO Currclll Nunc Nunc
Ilushllllll
H. Touls in possession llr Sl,lOU Currenl NOlie NUllc
Wili;
9. FU1If9wJIl:clcr S3,OOO Cllrrcllt NOllc NOlle
(hushlllul)
10. Si".whcch:r 1I11d unilcr Sl,KOU Current Nunc I.olm: flA NntillllDl
(husband) Uank S6,2l2
(12113197)
II. 1992 Ynnmha motorcyclc S2,UOO 12/98 NUllC Nunc
(husbllnd)
12, Minncsuta Mutuull.irc SHHfo 2/23/1)1) NUlle NUllc
Insurance Polic~'
(husband)
13. Culleclibh:s and curiu SI/>lU 5/22/00 Nunc Nune
cubillcls
(wife)
14. HCA hig.scrcclI TV S600 l/22/0U NOlie Nunc
(wile)
Il, Ught hilT SHUU ~/22IUO NOlie NUllc
(wirc)
Ill. househuld eolllcnts in IlPJlruxill1alel~' CUTrent NOllc Nune
possession ufwife Sl.lOU
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EXIIIBIT "B"
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LIST OF EXIIIBITS TO BE INTIWDUCED AT TRIAL
I. Appruisal rcporl datcd January 28. 2000. prcparcd by Mark W, Ilcckman indicating a
valuc 01'$120.000 relative tolhc marital homc.
2. PACFUC statcmcnt of account datcd March 31. 2000. indicating a balancc relativc to
Wifc's Ccrtificatc of Dcposit inthc amount 01'$73.983. and thc balancc ofthc loan
against it inlhc amount of $51.342,
3. Corrcspondcncc fl'Om Bank of Amcrica datcd January 19. 2000, indicating an
oUlstanding principlc balancc on thc mortgagc 1'01' thc marital homc inlhc amount of
$104.390 as of January. 1998. and $93.462 as of January 1.2000.
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4. Appruisal trom Fcrguson's datcd March 23. 2000. indicating thc valuc of Plaintiff's
guns.
5. Statcmcnt of policy surrcndcr from Minncsota Mutual Lifc Insurancc Company datcd
Fcbruary 23, 1999, indicatcd a cash surrcndcr valuc of Plaintifrs policy inthc amount of
$886.
6. Statcmcnt of PACFCU Visa account datcd Dcccmbcr 9. 1997. indicating a balancc of
$4,143.95
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7. Statcmcnt ofCitiBank Prcfcrrcd Visa datcd Dcccmbcr 30.1997, indicating a balancc
01'$4,260.
8. Statcment of Discovcr card datcd Dcccmbcr 3, 1997. indicating a balancc 01'$3,169.
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9. Statcmcnt ofbalancc ofloan wilh PA National13ank. indicating a balancc 01'$6,252.
as of Dcccmbcr 30, 1997.
10, Statcmcnt of Plaintiff's 40 I (k) plan as of Dcccmbcr 31, 1997. indicating a balancc of
$22,428.
II. Appraisal Rcport datcd May 22, 2000 prcparcd by Robcrt A. Ensmingcr valuing
ccrtain itcms ofpcrsonal propcrly in posscssion of wit\:.
12. Slatcmcnt ofloan against Husband's 40 I K plan inthc amount 01'$20.156, datcd
May 31, 2000.
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Mlllk Ilrot;"rnnn U..nl (!Illlll' ^NJlnIJr'!1
r'ol'.rlr UUClI ,11011 UNIFORM RESIDENTIAL APPRAISAL REPORT rill t1lJ. 2Jlllllm"
!..!~f'!!!,A<U:!!!.1~~.l!-l!.I1~l!_~"'_~!~l!~__ ~___.'___ .,. _. __ .C;I, tl!~_ln~_ ...___ H____ __ _.__!i1...I'J~I\__. .lI'~~II_.1IQ?~. ..__.__
l~~~..l'!1lfrt!lfl_l!I!~IJJ!~!_l!_~J~~,Jl_nU,!,!![l!l_.. n... ,_ '....,__, _ __ "m_ _ . .__, ,_,. ___'. ,~_,__lJOO!!ll~I!I,I~h~r.I~'!!~I_._ "'h. ___.,__.-_
~"~~~~"illl~"~_~~~M~J~'l~ff:~,~~!CJ,tJ!J~.~EH __,__. __ , _. '~I'I'.~_2(JO!l_.",t._,~~,.,_. JI1_~1...;.~U _!;r.~\t^!"""~~~,~ -=.!J:, ___'n
~ 0110"" llnlllc ClIl1llln l C"r"!IlU.,!I!!!_.\Iuu".I~n!lUIUnUlc.. __.-_ __ __~I{tjI'oIntJE) 9_"'~.__,__OJII"~nL__O_~~I"'~
!:!!J."'.Jl.rt1hll If o1ll.d X r.. Gif1~1 Il.mhQlJ 1.___m,r...!oj.It1U'~" _ O.!'uu..... OC~I,I!l!lIIll!n!ti!I}t"Y.~_Of.'I~, __. .!!2~' ____.uo~.u:_ ~o_
t'~'ll~~! ~t!_OjIl~Ht~I!. J~!' ___ ___" _ __._.___~.__...'U_. _ _ ... ~.If'r.-~!!-~I(.!.JI1!.:.!E.:12!Jl.:~~L. ~_~!!!~!.!ID.!!.!WJ)_____u_~__.
~,~. r~.-., t!~.___ ____,__~ _J!~!',of !!.~!.. I 'A___._..__ ,J~lff'~inI' D'!'IJllrn)l!.~I.uf~ lo.lnt!!~~!.lI,t~n,("I!IoI!~ !~~.! 1':"lloJ ~~_1~^ ~_ ____ ___~ _, . .__
~.IIIl"'_ICI!~" _~~'i_!!f!i!!IIl!N..~.l'~!'lk_I!'_~ ___~_,__ .___._^,MI'.n_~,!??lh)Ul..~I.l!.....tl--'~.Ol.!'I,.~Jr_'1JI!:,'l!:'~tl,,"!'..F-'.1.2__,_, ,_.. .._ .__ ...___ ___.
Arlur." Mi1Ik W Ilnt:kmtlll ^""hn 13UlIlhilll n !itrl'nl, tlnw CWllhnrllllnl PA 1101U
loulrtll\ X lJ.b~1l ~.! Sul1U'b:1l ~"lI1a1 "'.tllltnlnlnl m"ot.,4mllrhnUI.lno r....nlllmdu..% l'"du..ch.ngl
11<.1"111' X 0.., n'A. ~ 25,n.. Uno:l"2~'.4 O~~UP'"C~ r:,:J.~t ~~:f Or,,'~n", 2~1l!. LJ 1f,,11''', [) t"'."
Gt01l1hlal. II...".... X fil...U. J90" ~OIlIlPl ._,JiQ lll" ._J~'!.'!'!' '''''11''1 __~ 1X1lnl~onn
r'ol\Olft"aIu" x IlMuulng IiInt~. IJ IlltJ"'..g hUIII 2;l1l 1101111 120 LUrIMl.' __. ___.. to !!!'.!I!!.e!,IJ~~l!I.~!!__
l"'n"l\OlI~rI11 _ !;IKlIlall_ B t.hh.., IJ OrwIl~11y 18) Y..p1lU!,"-') ~=,.t;;';~w:!,~;;!= CnnllOOfIUl _-....2..~ Vilcnll~ _
".'",.l!!'!'g!I!.!_ X J"!l!t_~!!-"JLOJ.~!'!'l1-_U_O.1!1'.J,'!~L-.U.~!":."'I~~!_.I_ ,_l!o..:J.i!LI..2o.(J~ Y~~r!LJ_.J..~~ ____.__...~__
tlol': Ran and Ih. flcl.1 compo,lllo" of II.. n.lghbo.hllod.II IlIII'flPI.lullAclnll
ll'io;Ihbtllhood bllllnd"l.. .ndeh".llllillict 10 locnln..!!!!!..l!osl cornJ1..!!!.~lhl!l ~1!!!:1.!lle IIIf! ~1~J!!..nI50111!..AYJ!.n_Y_l!J2!!!.I.!W!L!.~!!:!.!.,!.'!!..oJ~
: !~..!!IIlUnIJ.l.!lyt!bOlho.Q~~ wllhin Ihn ,"orkel 81011 1ho subJ'!.tl'l.!!!II.!!!~Yl~~l!I~dlll Enst P~'W!!.slJoll!..TOWnl!!!IL-______._
r.tloII Ih31111,c1lh. m.lIht.bUT ofth. JlfDf'rli.. In UII n.ighbllfllood f",ollrr.I, 10 .n"'olmanl ;1nd amanll"I, 'rrr!OI"...nlllabH" IIp,,,,t 10 lNlk.t, .Ie I
. 11!!..s_!!~!l!!'!!al~o'h.Q.Q~.t1l11 Itl~JltJtJlIC .!!!!!!!.t~J!1!!~9J lelAIiy!ly OilSY nc~_s to~pJP'yrnOl1t !1_lId lorvlco~l.~!I,!-L!,Lc.Q!!!I!!,UIi,-:" wIIIL
" .!'J.I}!!'_'!!!jU!!~QIJ!.ood~~u!,nCl~!..!!!.l!f!.:.2~!.o..!.~!!l!!...I~!!!lllilies, ~~!!.el nctiv!.IYJwJjcn~'l!_l!.Y!!'.!!U~I!!"!!Q!I~~Jl!!!!!f!.lJ~__
n IlInrkc~fl~1~.!.L~.2l!nlnvolnlJln IlIclors '!P!!!.oliscrvp1.~ll'ch wt!~tLn_l.!!'!!.s.Q!1.El!ecl.!!!.<!'kell~Y____________.__.__,_
------------------- ---'----."_._-----,---_._-~--
Lblbl eond~lont III Ill_ lubj_ti n,lghbOfhood (IntJudrn!l .UI'I'OII 'ollh_ llbll" tontluuonllllal.d 10 th, tr.nd 1I1,~orHt, ,oW". d.nund/WI'fI" nnd nnhlll9l"..
.-lutllndalllonto"'P.I~"fl'lorfllltllolul'lnlll.n.lghbollrood,dfltllpllon 01 Ih. p"fal.nt. 'II Ulft;1ndlinllntingtllnc.uloMl,.le I
TillS IS A ~COMrlET~ APPRAISAL _ SUMMARY r~EPOR'~ Thero 010 110 loresoonblo economic hends which mill,l~unllicnnlly_
fnflulmco I1lnlkel conditions In Ihls Oft',' Tho cu"ollllllor!y~ue I1Imkol olle" a Wldo vlIllcly of convelllionllllonllS wflh cOlllpollllve
IlIloro~l 'nles, As n fosul', Iho ImlllS 01 flllanclllg 1I0vn hWa. II nnY...!m'locl 011 sale prices II IlIlm&sllalos IUl1Iolo IClIsonolJlo, f!IOEClly' _
vnlucs ond mrukalntJl1llyshouldlinslahlo
B PloJ.cl'n'ofmlllloll for PUO. (II 'PI"ic;1bl~)..1t III. dn.loptrfbu'd.r In contrnl ollh.llom" OWnlrt' Anorl3110M {1I0AI' U YES U tlO
, "rP01WIQt. lolal nunk of uMila In Ih. Illbj'd projl" . Arr-OulUt, lolal nuntlfl o'llnrlslollnt. In III. Illbj.d rloJ.tl
Onwba common .t.IMIlII Ind Itunlionnl IJc~,li_t
Onwn,bnl 75 X 150 TOf'O!l'aphr SUghl~Slop'o
S"lI'f.1 11250 S!1 FI. COfnfflol ~ y,~ 0110 SII' IYr.lcnllor OIoa
S"tcrlic lont'!1 dani'ic:olion and dncltrlion R-2 Residcnllnl MulU.Familv SII:oI" Roclal1llUlal
lri-ogum.......II(. 00 l"9a1_O h9...l'IOIocUlICfn.-.g(Ol.....JItll'l....U"..1 Ullpgal U'lolonng (Jr,lNg. ~P"IClHS odCllUnle
!!'!Ihtll & blllll"llIII1U~.rIn..!!t!:ill Otlllt"ultl!!..~ YIIW AYCfoge
UIllIlI.. rubric 01h" Oll.slt. Improv.m.nls tJ~' PublIC r,Nat. lMJ.o.rnr4r"" Ayorn!ln
EI,drd, (RJ 200 Dmps Slrul Asphnlt (&) [)Iif.wa, Surl..." AS'IIIllII
. O.n [.J Uona Curbl'ilUU" None ~ App....'nl '..."m'nlt NOlle Oblic!Vcd
Wal" (&) Srdf,,31~ NOl1n fEUASp.cbInoodlhl'....dN'-;:-OfuG!Jr;;-
S.n.....''''IIff ~ SIt..lligl1tl Slandald Ax' fEUAZOIl. C ',,",pO,I.4115/77
SltI'm,,'ll" (xl AI. --..!illlllllll IXI rEIMLbptlo 4203500111&1.03
COllVNnll (appallnl nd,.ru lI"n...nll, .ntlo...ellmanll. Ip'e~1 lIullmanh, Ilid. arUI, 1I.g~1 011'g31 nllneon'lIfming Ion lng, l'st, .te ) Tho liln
htlJllovcrnollls Dud liclvlce' to Iho sitc iII0 nde(~ and acceptable In Ihls '1Hllko!. Tho 'oar VOId Is cnclosed willi fnnCin!l Thern orn 110
8 I <lrenl adverse ensernents enClollchrTUlIIls 01 olhel DdvOIIO condillons ol1lhlli liile
OEtlERAL OCSCRII'notl EXIERIOR OESCRIPTlotl rOUllOATlOIl
1/0 fAUn.1 1__ rOlJnd~liOll Co Block 5l.1b No
tlnfASltI'itt 2 E.tHioIW.ll1 Y.!!!YL- ();w,If.!n:ItNo
tlpt{DPIIAlI) Delached Roo'Su.fJe. 5hing~_ Omn..nl Full Basemenl
0I19n (51)1.) Tradlllonal GuU". & Ullnlrtl Aluminium Sunp l'unp None
Ellstfl;/l'lopll$.d ExlstilllJ Wndo" Typ. Ooubln Insul 1J~lIfIn"t None noled
n "g'{YII) 75 SltI'lrl'SUnn. No/Yeli S,U1'Il"nl Nonenoled
n Elfltlif. A . Nit 20 Ihnul:odllltd Itouu No tnlflt;1lion None noled
. J!QQ!!L -L11)!!- ~,!lg_ ~....llli!!!L ~ hll"tRm ~ ~~.!!!!- ~L ~_ NUS'l!L..
: ~1PIlI Smnll 1 I 952
. lmll -- 1 ~--r-------~-X- U40
. lual-;- --- tJressftlll ~--.-- 1,344
o
(JASEt.lEtn
NUS'1rt 052
%rillnll'd 100%
c.'irl!l O,op- Pallel
Wals Poncl
rloor COIEol
ChoI:.d.Erhy Yes
~~LATlON ~
C""v==X
W3h _)(
""'-
lion.
~-
, --,--
rnnh.dllluabov,OI;1d.conl;1rl,
o lloom.' <l Ol\lroon ,
Il[ATIIlQ III1CltEllEQUll', AnlC
Trp'~R'''ig'fat(ll linn.
rllal Eloc rbn!l./Onn X Sla,.
CondliJnA~unro':ol [)opSlai'
COCUtlG [}io.h"ull., Sculll.
C'nlt.lI~hnntood X Floor
Olllt'l None LliuOYl.n. II....t.d
CCllc:!hWlAvu.- Wa~II.f/()II" r"iUrPd
Addh"I.l' 'ulullt {lp,cI...l.n.lg, .1IH;I.nl II.m;, .Ie I See AUachcd AddendUllI
20a11J,1
ALlEtnllES
F"~"~"'_~
rilho
Ottk__
P.'"
r.ne, ChaIn link ~
Pod
SID/Qf 0 Sllod x
2284 S
:01. rnl01 Groll liv
CAR STORAGE:
lion. 0
0....ag.2
All3thtd
Otl...clltd
Bl/II~n
Co)/J'OfI
lllffll'W:O
,,,'
ItllERIOR
FIoo.
W~.
TrJnfflish
Datil Floor
htllWa~tCoI
000.
Ll11Ilbl:slCond.ion
CDIPeVVjll~
OrvwolUPa/lollAvo
Wood/Avo
Ca!p-cIlAvDt!Dl!-
Fibellllnss'Avo
LV/Avcrage
~
~
'oItall
L-
2
Cond~lon 01 Ih.In'f'lonn""nll. d_J'l'd~hon lI'!'1,k..l. luntlirm31. ...n,1 .ol""all. "pJ.. n..d.d, qu~l4r QI eonltruction "nlOd.lmg/;1dd,tionl, .Ie: Seo Alloched
n ^drJel~______ _
Ad._""nVlonrlllnlalconddionl{luchll,blOlnollirn,l,d III, h.lllldolllwaltn, loliclllbll.ne.., ,'c.)""..n'lnlh. lmplo,.rn.nll.onlh.III., 01 In Ih,
immedial. vlclnil, ollh. lubj.cl nroplllr: No ndvcrse OllyirOllll1Clllal condlllons WOIII obse'vfldln Iho ImlllovslIlenll, on Ihe sit., on In Ihe
IlIll1lodJolo ylclnllv ollho sublo~t;;lon-I!11 .
',_I,IooI...llIt1
PAGE IOf 2
,......_.._.........'1__.....,...'__11111."
1__rIOIOWhlt"
.tnru.llo"SuUolI
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MlIlk I h'rIUlmlllh'"I.E~IIlIl' ^1'IJllIl!oI""
UNIFORM RESIDENTIA~ APPRAISAL REPORT
ru.No 2:1eheulo
ESIIUATEUSIIEVAWE '1 ,-- ...'----.-,.. COrllm.nlt IIn COt' "rJl'o.uh Itllth at, .IIUIt. nf totl "'hn~I,,
ES1IUA'W 1lF.f'IIODUCTlotl CO~J.rl[W or I\U'ROV[UWIS "I. ul.... ''1l1alflllol ral(ulJlhlln .nd lot IIIHl. VA .n,1 miliA. II..
o"tlrICJ____Sqrl 0)1...__ '1 --------.-.-Q .'huIJII.d",mlnillll'tonlln.clot,ollh'I'ttll,.tl,)
. _ __.__.._____ !iq n "S ______ . .----,---.-Q -. .-----.-----____~._,_,______.__u _. _. .--_. . .-."..,-
. , ------.,.- ~. "-,"--~ ~_._--, -,-, ~.._'--,---_.._--_.- ----.-- ___'~_._m__
O'~~I~~_=___=-liqnO S-=-= - 0 -.--'----~____..__...____._ ___d_____,__...___.,__..
--,-~-'.
101a11:1',"l1t.4Co,III." .."... ... '1 0 -----_.. -' ----~-_.._.__._--------_..--, _._-------,- -.-
: In. rhl,otallruntlc,,,;Il1 [ltl'frl;JI Cd Il.,,~;;;;';-~~;Ti. .------.,--..,-- ..- .. --,-----.-- --'-------,---_.
{llopflull,," ___. ___ __ .. '1 ----,~-,..,-q - --.'--,-. ------- ---.--._______. '___ ___ _,_____ no __ ,_
o.Jt.rl11.d\lalulcflnf'0'I'~' '1 ____,__u_ .q -.._____.__'_.n__ -----.-------..----
'A., ".\I,1~.t..l!i~. Impo"lnfnlt " --------.- -'-----.-----.----------------
INDICA1ED VALUE OY COST APpnOAelf -I II
__-'!1.~_::~.~~[~ COUr'AnAOL~ 140, I COUI,^,tAlIlF.IlO 2 COUI'AltAOLEf40,J
23 E. 0'''11" ^VflI1UO 2G5-'hlck Ciiulch-Hon;j---- ~jjorii,IGilnUi-m--- -i4T1lillmil~i 1W;'-liUrr.--~.- -~-
"ddl.t~~fl_~_ ~lIoll1 1l~!r.!.!.!!!!'ldolL-,_____ ~!!!!!.oy~~!'_____,..,__~_
!i01."'1,1i!..5!!.'-'j.~1 - 5 MUe ..-- I Mil" ..2~.___~ -_._--
l!~tJ~!!_!.._ L__ "^ 1 19~ ----~ 108,000 '__!ll.JLO.Q
l'rl~IItt'~J."h.~_ '_---!Loa V1 .S_~Q..~____ s 72.00 V1 L_72,~~~~____
P~I. ~ndtOf InspecUon A'iSeSsrllt'1l1 Recolds & MlS ^nessrncnl Recolds & MLS ^ssossll1ant Rncollls ^ MlS
V"'l(~Li?!!!!I..'II-'!!!... --- ~)JH:tlsf!l's rll~ __.____ -_._--,--- OC5C~!I'IIOtl _L.!l~~...!-
VN.~.:.....N.W.'ilr.ul1!i -y]~.!!.- -PESCli!rJlOI.L_.I--!.ll'~~..!- _J)~_S.5mr"~llli- -!.tJ!~~L
S3IuOf rnanmg COllvcnlio",,1 : FIl^ Convonllonal
CO'!!=.UlOn, None : None Uono
D~l.ofSaI""i1l1 ,,^ 3126199 ------.JAgO 10129199 11124"'9 .
^vclogo Avcloga Avoroge Aveiane .
lotalion i ! i
l-..hJlr",!ihl~ Fee Slm[!to fee Shn[!le reo 81111fllo Foc Slmp.le
... .20 Ac/Colller .24 ^c1CO/llel .27 Ac/Colller : .12 ^c1^vo +1,500
Y.. Average AverOll8 : Avernge i Avoro{lo i
~nDnd"flP!L 2 Sl~hrad/Ave LIDYfTtad/Avo Capo Cod/Avo 2.5Slv/Trad/Ave
QDfy d Cat.tWm Flame/Avelage Brick/Frome/Avo . -1,500 Frarne/N..eloga AIIDllck/Avo . -5,000
~g' 75120 32/15 : -1.500 45IHi i ~1,500 7!:i/15 , -1.500
, Cond'lon AV1l,!!!1I0. Averago ^ve,!!U!!; AVo,!!Y.!.~J
. ,
, Abm.GI~d. ,.....1\1"'" w. ~!!.j N"" :_~-: ~M": u. : ~:fI.t..~:
lloomCOIInl -0:=-4:-200 0, <I: I.tro' t 1,600 7:-;;: 2.00; 8: 4: 1.50: '1,500
~iMSgn --~ ~B~
Gttr.isU'IIlINu 1,710 SQrI : t4,500 --...1..500 S_qIL-: tO,JOO '4,800
. 8.T.IIl1'l1t& rril.hloJ Full OasC/nonl Full OsmVElIJI : .4,000 rull Basement Full Basement
. ROOI1.,DtfowG/adl RecR01/KIUBalh Rec Rm/.5 Oath ~~ Unfjnished , '5,000 Unfllllshod : '5.000
rUlKlionarU\U_ Avelon!, Avellrge AVerBije Average
~!!; EHP/Cenl Air GHW/Cenl ^Ir EFNUa ct Air :-+1.500 mlWlNo Ct Air '1,500
. EIlfOVtElrcieo1lMtn. T rorAroa }yp lor Alea Tv~r^rea nil forAlon !
G:lrJgHCarpoll 2 Gar AU w/loll OffShoet : +5.000 all Sheet ; +5.000 1 CalGRI/Det t2,500
Pcnh.ralio.D.cl Cove,ed Stoop Porch & Deck -J,OOO Porch & Palio -3,000 Porch & Pallo -J,OOO
Fi,pl~!~ None Firer.'nc9 : -2.000 Fireplace : .2.000 FhelJlaco : -2,000
rllltl.pod "t. Fence ~"Jone '500 None '500 Fence/Allic .~
Other Shed Shed : Shed , Shdlt lew kitchen : .3,000
!!IIAdU!.~__ TXJ7lI, :1 5...1QQ EJ. n. :, 11.800 'rxr;-n-:-: 1 300
AdrJ"ed~"~ . Ciro..:20.1% Glon: 23.0% 0,0..:27,2%
orCoom,)latl. tl,1; 4.8% 1 117,900 tI,l: 10.0% 1 119 noo '1ft,' 0.2% 1 122800
ColMItnl, on S~!n Comparj,on (lndudinlllh, ~ubj,cl plop"I,', tOlT1pahb'~, 10 Ih. nlighbOlhood, ,Ic. ). See Allached Addendum
I1EU SUBJECT COMr'ARABlE 110. I CQUr'ARABLErlO.2 COMPARABLE 110. 3
0lt11,I'rNondOa13 None r~o plior sale other No prior sale olher No prior sale olhet
So.n.bpr",,", Ihan thatllsled above Ihan thol listed obov" Ihan lhallisted above.
M:hit_rJlIllln<
Ard"is of InJ tun,nl.gt'ltnrnl or sail. option. or 11$11111 011'"' subjltl pto""', lod In;tl,~is Ol,n, JlO $.Jln rJtul>jtd ond coop3aUn mhitOlll ),..orlhld.1l.dllf?:Hl.1I
^ccording 10 Informalion provided bv the mulU.list SI"vices In Ihls 'e~, tho sublect mopelty has nClt been listed fat sale WilhJnlhe
past year.
INDICATED VALUE BY SALES COMPARISON APPROACH '...... N/A" M; ~Q~R~~i.Ui;':' ".1 120.000
. INDICATED VAlUE OY INCOME APPROACH II AnrlClU,) E'li~i.d M~\,i R~~I S . N1A 'I N^
Thisapptilisalbnucf. ~ ".lltb' ,U w4tdlolhlriPpo1n,lJlI...oIi:lns,~Ii:lnsc:rCXlflltiOntlr:.ltdbrlcrrr UsuL;fdloWlll""iJrtr'"Jtmslnd'l'ft/Cllilm.
CorIU.,n,d ^nt3il.:tt See Allached Addendum.
rmrRItOfltii:tlion; See AlIachod Addendum.
11lIPUfpot.OllhitllPJui:.1lisI0"til\1l,lh.nJ.)lk.ly.:W.oflhlllalptoP.Il,Ih.1listh.tubjtdoflhisllpc:rl.b3,.cfonlhlobm.tondAion,ancfl,",tIf{falliln.alhIi-IgoPnl
and 1imI~ tlll1'Uion.. 'l1d flUIhl Y~I d.r..'ion Ih.:tl.. &l;lltdi1U..llt.xlotd r,NJit klltrc:rmOM"OtIt;, l.b. rc:rm loo.lBjR"Mcf )
IIWEI ESTIM~~AAKET VAlUE, AS DEFINED,OF TIlEREA1. PROPERTY TIlAT IS TIlE SUBJECT CFTtlISREPORT,ASOF 1120/00
(WHICHISTHED F1NsrEC~N~VEOATEDFTHISREPORTJTDBEI 120,000 ,
APPRAISER: / / ~ SUPERVISORY APPRAISER (ONLY IF REQUIRED). OOol OOol""
S"n~tulI .. -,- ~nallll'
'bll1l Mark . Heckman lbnw In'prtlPropfrly
lbl.R'P<rlSil:Jn.d 1128/00 OJI,R,portS~ntd
SI~t.CeMation' GA.OOOOOO.l SIOItlPA Slar.C"tlocation' sr.11
OrSlalllk:.nSl' sr31. Or !i131. Lit,n" , SI:>rl
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PAGE 20f 2
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mark heck01an leal estate nppralscls
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ADDENDUM
OolIUWl'I: l~1I11t Conllllll. r,lc tl,,' 23~IH!al"
:r'opt'llt Md;lI..'jJ E..DlI_a'I!'^vt'I\lIf'__==----=-====~~__~==:~~=~.~_=~~==._==ca.'" 110- ~--=.-==.~~==-=-_-===-
.C~r:_En(l4' _____._~__,_,.______Statll_M___~_____1.tp_1102~_____..___.
If'l"lllr: ^llr R.lnhwl A Sln,\l"
Addlllunnl Funturos
4 skV IIUlll.; tJltJllllAllel coiling III k/llllJ loom; 1l'llIm:nlllolll wlllllom. unh6illmJ utility IVLIlI; oVf!llllzll lnv,,1 2 hnlh Wllh Inlun
whl,lpool tub nil II 5"1'01"10 showm, lIloslm bed,oom hll~ cnlhmlrnl CI!ilillU. I1lMfV lIil....1)11 dllv(JWiJ'r', blllCltlWny; !!lIinll kilcholl
InbnSI!'II1f!nl
Condition of hnproyol1lonls
lhllSO Irnrll'lvolllonla nil' or 8VOfnuo quallly homo dMlun nnd tcllcel 8\1010UO lllnlnlonnncIl UliUlV 01 flOOI plan Is typlcnllOl
o hou," Dr thl, ago and Ilylo And &hould rocelvo avornge accept ontO In 11m I11nlknl pineo, No unulunl funclloll;t!
cbsoht'lcol1tO 01 exhllnnllnadoquilclol wel8 o~orvod lho "nlluDe,"', kllchon, mochnnlcnll'qulpl1l1ml, nlld olhol fonlurma
11I081 cUllenl slBntJnrd'l fOI houlos of Ihis oUel" Ihlslltarkol Hownvo. kilcllP.n I" mlnlmol "y CUllont sIRlulnr.I'
Comlllollts on Salos Comparison
All!!1 n lholough sonlch 01 011 ovmlablo lIuukl!1 lIuln, Iho Ihum Sll"'" used nlO cOllsidoled 10 he 11m hmot IndicnlolS 0' vnltlo
InsullldonlsnlosIn t10S11IJ/Oldllllly 10 Ihe suhlncllofluhe Iho OPl1lnlslJllo o~hmd !Joulch pOlnmttlnls. 111 Oldnllo lind
colttpllloblo snlC5l1 Wn!I nOCrnlsary 10 use letS" IftCfllll snll!s, 11m.. ndJusIIIIlllIl1I 810 tm""d fill nl1l1lOllllnlo 105I)Rlch lif tho
IIlnrknl dlll.1ln lho mnlkol oUm, ApplDpllolo odjllslnllmls hnve been mndo 101 nil dlllmonco!lo, Mlhllm sahlS nlo t01l1lidOl011
10 he lellablo 1l\lllcillolA of voluo, ond aro welghtod shllllillly IlIlho flllnlloconcillnUo!l, Dnys olllllnlkcl. COllllliUllhlo I~o 1:
3 days; Compnlni~o No, 2: 15 days; COlllllnrnblo NO.3; 10 days, COlllpmilhte sntos used mil nil closed sntes ^ lholOuuh
1I00lch fot cQlnpolnhlo sillos has been mode to 'Inti snl08 whIch blDckotlho thull voluo esllmoto, AJllIuoo cOIllI1n1oblo Inlns
n1olocalod In Iho SAIIIOlltOlkol mea ns Ihe lIuhJect nmJ woold hA cOlIsldewd hy Iho SiUno plospecllva pUlchnsfll 01 nil wOle
0111118 llI81kel ollha sOl11e lhue os tho sulllect.
Conditions of ApPTnlsnl
lhls ol'lllalsallolloll has been prepared wllh Ihlll1rope/ty In ~ns Is" CClIlhUOII tlo pe/sollal 1J10perly has boen Included In
Ihis vnlunllcn Accolding to lecord5 plovlded by tho cOUllly onoS~lnenl oHice, Iho subjp.ct plope/ty hns nolllallSlellftlJ In
Ihepi1slyenl.
,
Flnnl Roconclllotloll
lhls 01'I',ni8nl nnumes n IIlnsonilblo mnrkoUnu porlod fOllhe sullJect"prollorly 01 loullllonlhs Tho SnlCll Compnllson
Analyslslellecls ll?Cenl ncUvlly In Ihe mnlkol pl;oce on Is u1von Iho most wclUhl. 111 vluw 01 the ngo ollhese hnplovcmollls,
Iho Cost epplonch connot ho considelod on occulDle Indicolol 01 vnlue, lhe Incomo oIJPloach IslnoPlllopllnle because fllW
slngl9 family houses 010 lrllltod III this mnlket. AS81s1onco 10 the 81010 tOllllled fenl eslale approislll was plovlded by slale
celllfied npPlOlset Luann E. ~lIudson, PA Celt No. RL.OOJ08G.l.
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DIMEH~IOH LlOiT ADDEHDUM
UUIOWOl: Ullulc COllllin L 1'110 No,: 2311IJ('nln
ljoii~VMt!!,,!~;;-73 E.J1~ate ^v~ntl!! ====~.=~-~='-~~."-=-~~~~~~~-~_~='. G~~ ;;0.: --.====---==-__.__
ell. Enola SlnlfJ r'^ b I: 110:.n.
GRO~S BUILDIHO AREA (GBAI .020
GROSS ~IVIHG AREA (GLAI :~=:-}:?i!1
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UtI!OV;flI: lInlllc COIlIII" L.
t'L~~~fiMdfO~:2"j"ifUnnIO ^V;;;;'iO--- --.--.-----'-
C" ,Enoln
FRONT VIEW OF
SUBJECT PROPERTY
AJlprnl50tJ Onlo; 1128100
ApPfn15ctJ Vnluo: S \20,000
REAR VIEW OF
SUBJECT PROPERTY
-
,..-
""'....
STREET SCENE
.
SUBJECT PROPERTY PIIOTO AOIlEIlIlUM
lli!t~!!!i.I.II'!!!~I,Col!!!!!h_ _______~____*____~.._____l!l!!U~~~~~!L_*____ \
f?t~YlI!!!!yru!~!!!!2.!JL!!!~ IluO ,_'.__________._~_._ __._______t1!!!l!!!Q~_____....^'_______._
Ci .11110111 Slnlo: I'A lilt: IIU25
FRotH VIEW OF
SUBJECT PROPERTY
Al'p.nIIOlJUnlo; 112DIOU
"(lI~"lsot.l Valuo: $ I:W,OOO
REAR VIEW OF
SUBJECT PROPERTY
STREET SCENE
1I.1t'IJ\/f/f U"_lI~e,Cnnll!nl." .
!)uf1l'1ly [\'MIOS!l_~} (: !JIlA!n ^'11!1ll1l'
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COMPAAADLE PROPERTY PIIOTO ADDENDUM
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COMPAAADLE 9ALE.1
25[1 (Illtk ChUlth !toad
(;110111
Sill" tlIIIII: 3/20/09
51110 "rico: $ 11;1,fiOO
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,
COMPARAB~E SALE #2
500 Filst SIIDel
SUITlInerdulo
51110 Data: 10120190
Salo Prlco: $ 108,000
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COMPARABLE SALE #3
t41 Hummel Avenue
LOllloyno
Saro Dalo: 11124/99
Saro Prlco: $ 122,500
. COMPARADLE PROPERTY PilaTO AOOEllOUM
I !~r~\ro~~!;~~~jW!'L;~'!~',;,;;;-~==-=,::==::..::.~':':::-::~~=.~'~~il~.I;^ '.ll~!~L~_=~:-';i;~~O~~~=.:':'-=-=--:-= \
\
COMPARAULE DALE"
:'155 Ullck ChtllLh HUlI!1
Enolll
Snlo 01\\0; 3120/UO
Solo Pllco: $ 112,[jOU
COMPARABLE SA~E n
~oo FI"1 SIIBot
SUOlllleltlale
Sura Oate: 10120/09
Salo Pllco: $ 108,000
COMPARABLE SALE n
141 HUllIlTlel Avenuo
lellloVllo
Solo Oalo: 11124'00
5alo Plica: $ 122,500
SKETCH ADDENDUM
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1.0, ':1, II 0 "I PENNSYLVANIA CENTRA~ fCU
: , '. I,a lAST PARK DRIVE
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. r NDUN ^VI
rNOLA PA 17021-2726
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'cl812'6'll Dll"lInT" - "'YWDLL '.-.' _.. _ ._.no...
01!o2oo 'AVMINT TIlAN'I'!It 11000 8020
O~OOO DIiPDBlT rAYIIO~L '1000" 20020"
0_100 PAYMINT nAN.1'1II '1000- 1010
011'100 DI~Oln PAYIlOLL tlCltllO 20020
0111100 "V"INT TIIANIFlR 11000 1010
0~3oo Dr'Dln PAYIlDLL 110100 - "I 20010
O~.OO 'AYMINT TIANII'ER 1110l00~. . '010
0*1000 DI'D'IT 'AYIlOLL 000 20020
Oil!lOOO PAVMINT TRANS~U 110100- lalO
0~'90 DIVIDEND I SO .. lI~U.
/: I ANNUAL PIRCENTAGE YJtLD EARNED IS 02. UlIi I'
I I'OR "ANUARY 01. 2000 THRU MAIlCH 21. 2000 : ;:
OHlOO : : NI'i 'll~'~:: &041''''
I! "oai-i:o;ii"exTiiiiioii" - - - ~iiAjj----- ------ -r -piiE~iiijji-iAi:Ajj;.-:!~~'i1;i;ji-
0"2110 PAVIlINTTIlANIPIIt 11000. I, . t?lT"
011II100 'AVMINT """1 n'l" '.' "?lao
030100 PAVIIINT TIlANII' III . ,J ." IIQ1OO- 1"1"0
O!,!IOO PAV"INT TIlANII'IIl .1111 ICIf7I- 1110..1
0_100 PAVMINT TIlAN'F1R 11'14 loal- 1161:'81
Oil;!OQ(l PAVMENT .TRANSFER n02 : ,.. .0I7~, 1I3U7& .
0:11:I'00 ! ' N!lI I"~ANCII 1124271
I :' - o;i - -- sHAitE" iiRAFT - A~~ - - - - -- -. - - - - - - - -- -1-- - piicviiiLii -iii:A~~-';~~~- - - -ii i:
0".,00 NO TIl"NIACTIOHS THIS PERIOD " NIW U~ANCI III
I: -oii--ciiirI;icATi-;c,-------------------i---piiiviiijji"uAi:Ajj~------;aiiii;~.
a~ too DIVIDEND , . lOIOil.' ,nl'"
031:1 too I i NIW I"LAN:I 7211:1..
' lATE B.OOOO~ I5SUEO DO/2B/gB NATUlllS 01/21/01 i
,
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: aQ~.Oo ~a^H IHTIiRIST
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PAY YOUR BILLS ONLIN!!: (rOR rUI!:,)! COM-
PLETE AN APPLICATION FOR VIRTUAL BRANCH I
:
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lhhlnll
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CUSTOMER'S OROER '10
f'lHDrl(
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2:3f-6:tJ-
fjAME
ADDRESS
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61CO
'3 100
.-
2
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TAX
RECEJVECJ BY
TOTAL
54081
All claims Jnd relu,ned gOOds MUST be i1ccomp:mied by Ihis bill.
THANK YOU
.AI'" NInth MIItt"I~" Rn'" (,.......;^'l
11...........,.,,11I ~~~=.
l"hnnt 117.J.&I.iIUl1 :;::;-\
F" "'.....,.. Ferguson's.
11,.., 11.". w..., TheStorc rorSporl5ml'l1
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I PHOtlE
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NAME
AOORESS
.
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(1.t D
TAX
RECEIVED BY
TOTAL
240 100
6 J01:l
I 00 I~~
18>1~
54082
All claims and relurned goods MUST be accompanied bV this bill.
THANK YOU
"'01
....'''Ih'''''''''''.,...~
lI.rrilh.,...P,\I1IU
=..
rt.w 1I1.s..I..)lUQ .-\'
... "'......... Fer IJS()n's.
"".' 11.,.. w.." TheSIO~ IiJrSportsrnen
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IfUllUnat
-'rd."
CUSTOM!:RS ORD!!R NO
PHONE
/2 "1/~
NAME
ACDF1E$S
6 c. I G:::.
I
RECEIVED BY
TAX
TOTAL
54083
All claims and relurned gOOds MUST be accomp:nled by thIs bill.
THANK YOU
DATE 02 23 1999
INSURED ROBERT VICTOR LIMRIC
MINNESOTA LIFE
'00 nODEnT STREET NonTH. ST, PAUL, ""NNESOTA 55101
A G6-5993 0
POLlCV NUMBER 18587730
RRENDER
".....:'.
:~','<~ .
FOR SERVICE NEED~ CONTACT 1173-21U
ROBERT VICTOR LIMRIC
4 EAST NORTH AVENUE
ENOLA PA 17025
THOMAS J GRAHAM It
SUMMIT FINANCIAL GROUP
1966 GREENSPRING DRIVE
SUITE 400
TIMONIUM MD 21093
PHONE:410-561-4900
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EFFECTIVE 02 23 1999 WE SURRENDERED POLICY NUMBER 18587730 FOR CASH.
ALL BENEFITS, RIDERS, AND AGREEMENTS ATTACHED TO THIS POLICY HAVE BEEN
TERMINATED.
'"
CHARGES
CREDITS
886.00
886.00
,
CASH VALUE
NET PROCEEDS
886.00
TOTALS
ATTACHED IS A CHECK IN THE AMOUNT OF
$886.00.
IMPORTANT TAX INFORMATION
YOU HAD NO REPORTABLE GAIN.
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I
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PLEASE CONTACT THE SERVICING AGENCY SHOWN ABOVE IF YOU HAVE QUESTIONS
ABOUT THIS TRANSACTION.
WE SUGGEST YOU KEEP THIS STATEMENT FOR YOUR RECORDS.
..........,..,............OS.'j..."fRANSAC''fI'ON..'COMiLETE....'....'........,............,..,........,..,......,..,..,....,........,..,............,......,......,..,..,......,..,................,..,..,......,......,...............,..,.......,......,........,....,........
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ROBERT V LIMRIC
4 E NORTH AVE
ENOLA PA
17025
CITIBANK PREFERRED
P.O. BOX 3103
S HACKENSACK. NJ
USA 07606-3103
L. -! p_ f_Il..':'u ,-_
Plot... 11'11I1 CMftOe 01 Actd"" Of '110M Number ,ban.
fOhO""Mtl)l.",.II'lNAPlCECIlAAQEbow>gl"""",lo,ourc:urlllf1pu1t/l,U..onrw,1
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eitibank Preferred Visa
ACCOU'lt Nl.mber
4271 3320 7410 6309
PAYMENT DUE DATE 12/30/97
SlatementICloslng Dele Tolel Credit Line
12/05/97 $5DOD
Sal.all. PottD.~ R.,.,.nceNumb.r'
For CUllom., S.rvln. ul orwrill
1-8DO-950-5118
BOX 6D62
SIOUX FALLS, SD
57117
TOf,"..'bllllll.",on,wttt,
lolNl.t14,....c..II/1.wlll
tlO\pfUIt"rOUI"I,1'I1t
Cash Advance L1mil
$3DDO
....,
New Balance
$4260.63
Bltul. Lut 8l.1twn.nl
Available Credll Une
$739
Available Cash Urnt
$739
",,"cunl
1117
1117
11/18
11118
21Dl
12/03 97911268 PAYMENT THANK YOU
11/17 MVGBXBBO BOSCOV DEPARTMENT STORE
11/17 DP1455GV PIERCING PAGODA 188
11/18 Z4KSNGF9 WAL-MART 1886
11/18 OMZQFML2 HILLS STORE 139
12/01 TTKTVV31 BJ'S WHOLESALE 125
CAMP HIL L PA
CAMP HILL PA
MECHANICSBURGPA
CAMPHIL L PA
HARRISBURG PA
-132.DO
18.76
133.56
46.26
54.34
337.63
HAPPY HOLIDAYS FROM ALL OF US AT CITIBANK!
We'd like to take a moment to thank you for
being a Citibank cardmember and let you know
that we appreciate your business. Warmest
wishes for the upcoming yaar.
Please see the enclosed change in terms notice for
important information about changas to your Citibank
Card Agreement. These changes will be effective on
tha date of your January, 1998 billing statemant and
will appaar on your February statament.
Test Drive Citibank's New PC Banking at
www.citibank.comI
Call 1-800-526-4848 to receive an Exclusive Citibank
Offer on guaranteed low priess on over 250,00D name
brand products (Sony,JVC,Sharp). Call by Feb. 28th
and receive a free Personal Electronic Databank just
for trying CitiShopper for 3 months freelY!
AccClUnt Bumrn. ~,.' , '.."..'. " ,:' '''".....'
Previous (+)purchases (.I Payments 1.ICredls ,+) Finane. 1+) Lale
Balance & AdVances CharQ. Charges
Purchases 3749.95 590.55 132.00 52.13
AdVances
Tollll 3749.95 S90.55 132.00 52.13
Rale Soovnlll)' Purchases Advances
Nunb., ofdaVt Ifill ailing P.rIod 30
Salane. SLlbJtd 10 Firnne. Chat;. 3934.56
p.riodie Ral. 1. 325DD" .D4356"
Nominal Annual P.t'UnlaO' Ral. 15.900" 15.90D"
AnnulIl PArr'Anlll"" Allt. 15.900" 15.900"
.'. M10unt ou.
t-lNIW aalane. ''''cfI.......n1nut1Du. 88.00
AlI,,,,,..MlnlItlWl\Ou.
""'_I 0...... C,ldllUn.
4260.63 "..
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4260.63 "n1_""'_IDu.
88.00
745
{B-7)
DlsceVER'
P-1ynlllnl dUf! a.lllt
Olaemb., 28. 1997
minimum Po,ym",,' dUf!
$33,00
1,,,111,,,111,,,,,1,1,1,1,,,1,11,,,1,,1,1,11,,1,,1,1
ROBERT LIHRIC
4 E NORTH AVE
ENOLA PA 17025-2726
-
-
AddreJJ or telephone C/JlJngfJ? Ple:JSe print change In flu, spilC! above.
np.wV.l','''C!J
$3,169.01
.1ccounr numb!f au I I UU.cb , ~:).t d4,Ua
en/tor o1/flOunt ttncloud bIt/ow
$1 .
PlfJ,1Stl tn.,,,., chttcl P.l)'.lblfl to D,Jeal/ltr C':Jfd.
Glial Bnlanc. Tran.'., rallll
C.nl.800.DIBCOVER 'a ...11 an
oN., I. avanabl. la, you,
PO BOX 6011
DOVER DE 19903-6011
1",11I,1"1,1"11,,,,,11,,11,,11,,,,,,11,,,11,,,11,,,11I,,1,1
000006011002679528208031690100000000003300
Casl:1baclL,
Bonu~ "tJ
' aloal-d
Ollcov.r Card Acccunt Summary
-
account number
p.ym.nt duo d.te
mInImum p.ym.nt duo
C/Wdlt limIt
C/Wdlt ...II.bl.
6011 0026 7962 8208
D.c.mb., 28, 1997
$33,00
$5,900.00
$2,730,00
Tran..cllonl
-
Clollng Oal.: O.c.mb.r 3, 1997
P.O. 1 of 1
Calhback Bonul<I!JAward
qu./III.d purch....
Oashback Bonus.ward earned
O..hbaak Bonu. annlv.,.ary d.tII:
mls fMn'od
$0.00
$0.00
July 3
todiJte
$35.46
$0,09
prevloul b,',nCfl $3,124,02
p.ym.nlo .nd C/Wdllo 0.00
purch.aN + 0.00
cash .dvanCH + 0.00
balance tran".(8 + 0.00
FINANCE CHARGE5 + 44.99
new bl/ant>> = $3,169,01
To "void addltlona' ffnanCfl chargH, pay your Intfre new
b.l.nee by D.eembor 28, 1997.
a.,. fron' row...t 10 th. haHN' .howon lee wh.n Kri.N Y.m.guchl, ScoN H.mlllon, Ek.Iorin. Gord.... .nd oth.ro
.k.te'nlo your livIng room. 711. DI.covor(R) SI.ro on I.. lour .,Iro on T8S on Sund.y, Docembor 14, .nd on NBO on
S.turd.y, J.nu.ry 10. Oh.ck 10c.I If.llng. forprogr.m Nm...
A v.rag.
D.lly
Ba/anCH
D.lly
PeriodIc
R.t..
ANNUAL
PEROENTAGE
RATES
Tran..ctlon
F..
FINANCE
CHARGES
curront billing p.riod: 30 d.Y'
Purch.... $3146,71
O..h Adv.n... $0
provfoue billing p.riod: 31 d.Y'
Purch.... $0 O,04767''{' 17.40"'{' $0 non.
O..h Adv.n... $0 0.06426''{' 19,80% $0 non.
Qu..Uunl7 Call1.800.DISCOVER (1.800.347.2883). Fo,TOD (T.I""ommun~.lIon O.v~.to'1h. D..Q ...I".nc.,". roverl. ,Id.,
Send blUing Ifror nolk:e to: DIscover Card; P.O. Box 15192; Wllmngton. DE 19886,1020,
0.04767'A.
0.06426''{'
P.ricdlo
FINANOE
CHARGES
17.40"A.
19.80"A.
$44,99
$0
non.
$0
I"A'l' 23 '00 1111106Al1 Kf1.O
P.l'l
IltS'1'OR.Y or UWI .. 1'1:8 JARTCl
pIOUUY: 242
(.I>CCOllR'l' I 000001773"--..,
SBAaCK ~I 3DOOi -
Dl!Il A A'1t'HOlLt'rY COOK: 0
1'H!IS 1101 002
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613 10/27/'7 001
10/21/''1
&13 12/11/'1 001
12/n/J7
,.Tloue ROBIIRT
I,Ijl~Ol 2, .JWlCB 2, ALt.
LAST Jl!ST MaiM D~"" 12/17/'8
TRAN9 AM'l' l'Anaan'/'l'UIfS ALt.OC
UWl IlAL
Ii. 6:15,'/9
pU-T/IAYIIII
195.11
6,4.10.24
70,111
21.03
14.5.5S
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613 02/02/91 001
02/02./98
,1)0.11
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190.11 \
6,137.76
~Ul
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PR1118 PAa 1IOIl IIORlI l'AGM
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~~
~ ~ \\'\-'l~d...'\I~\
p~ )J~\ &~
J "'600 -6IQ~JSSS'
(B-LJ )
ROB.ERT ENSMINGER APpRAISERS
REAL ESTATE and PERSONAL PROPERTY
RE: L1mric v. L1mrlc
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3117 ELMERTON A VENUE
IIARRISDURO. PA 17109.1132
PIIONE 717-632-4111
FAX 717.341.9444
May 22. 2000
E.MAlL:
TIIREECOMPS@AOL,COM
Kristin R. Reinhold, Esquire
5922 L1nglestown Road
Harrisburg, PA 17112
Dear Ms. Reinhold:
In accordance with your request, I have appraised the listed personal property
of Robert & Connie L1mric. The property is located at 23 E. Beale Ave, Enota,
PA.
,..
,
The values shown have been arrived at after a careful study of the property.
believe It to reflect a true measure of Its market value as of May 18, 2000.
Market value is defined as being the most reasonable or probable price in
terms of money that real or personal property will bring in an open and
competitive market under all conditions requisite to a fair sale, the buyer and
seller each acting prudently and knowledgeably, and assuming the price is not
affected by undue stimulus.
'I
.
I
,
I
Taking into account all of the factors set forth in the pages that follow, it Is
the opinion of the undersigned that the market value of the listed personal
property Is Three Thousand Five Hundred Seven Dollars ($3,507.00.)
J
Employment in and compensation for making this appraisal are in no manner
contingent upon the value reported and I certify that I have no financial
interest in the property appraised, present or contemplated.
, .
(ll(;f!l{~/I'~;~f1
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Very truly yours,
Robert A. Ensminger
(B-II)
Big screen TV $ 600,00
Patio Table $ 20.00
Patio table & chairs $ 35.00
Recliner Sofa $ 125.00
Electric start Snow Kina snow blower $ 600,00
1300 PSI pressure washer $ 75.00
6' fiberglas ladder $ 35.00
Water bed $ 125.00
Console TV $ 75.00
2 curio cabinets $ 500.00.
Curio cabinet $ 100.00
Exercize bike $ 40,00
Cardio-gulide $ 40.00
Comouter - 133 mhz pentium - not working $ -
HP DeskJet 540 orinter $ 60.00
QEtic pro scanner $ 35.00
4 Resin Unicorns $ 40.00
Black ceramic unicorns $ 10.00
Ceramic music box $ 10.00
Resin eaale $ 30.00
Resin eaale $ 15.00
Glass unicorn (5\ $ 10.00
Pewter unicorns $ 25.00
Westland Music boxes (28\ $ 420.00
Westland globed fiaures $ 30.00
Westland figurines $ 30.00
Alabaster bull $ 10.00
3 anaels $ 25.00
Train music box $ 15.00
4 small unicorns $ 15.00
2 cherubs $ 10,00
Snake $ 2.00
Small westland fioures (22\ $ 88.00
Westland fuiaures (7) $ 49.00
Alabaster candlesticks $ 8.00
Tortise & hare fiaurine $ 15.00
5 Franklin Mint Unicorns $ 100.00
Peaasus fiourine $ 35.00
Unicorn bookends $ 5.00
4 anales $ 10.00
Alabaster birds $ 10.00
Ceramic child wi winos $ 10.00
Misc. contents of curio cabinets $ 15.00
TOTAL $ 3507.00
/t'
.,
"
Page 1 or 1,
INCOME AND EXPENSE STATEMENT OF PLAINTIFF
ROBERT V. L1MRIC
Plaintiff
v.
CONNIE LIMRIC
Defendant
INCOME:
Employer: Mold Base Industries
Address: 7501 Derry Street
Harrisburg, PA 17111
Type of Work: machine shop
Payroll Number: 97
Pay Period (weekly, bi-weekly, etc.): weekly
Gross pay per pay period: I 51,001.00 I
Itemized Payroll Deductions:
Federal Withholding: 5 173.92
Social Security: 5 76.57
Local Wage Tax: 5 10.01
State Income Tax: 5 28.03
Retirement: 5 50.05
Savings Bonds: 5
Credit Union: loan-Court Ordered 5 150.00
Life Insurance: 5
Health Insurance: 5
Other (specify): Dom Rei 5 304.39
401Kloan 5 103.47
Net Pay per pay period: 15 104.561
()(h-ib t \\ ell
No. 98.868 CIVIL
Date. February 22. 2000
.
-
,
. ..-.._._-~-
- :,
,7".
'-'
OTHER INCOME:
WEEK MONTH YEAR
INTEREST "
Dividends . '~I
Pension I,
Annuity
Social Security
Rents
Royalties
Expense Account
Child & Spousal Support
Unemployment Compensation
Workmen's Compensation
Totals:
Total'ncome:
EXPENSES:
Weeklv Monthlv Yearlv
(Fill in appropriate column)
Home
Mortgage/Rent
Maintenance
Utilities-
Electric
Gas
Oil
Telephone
Refuse
Water, Sewer
Furniture
S
200.00
!
I
I
I
i
Employment
Public Transportation
Lunch
Is
25.00 I
Taxes
Real Estate
Personal Property
111:111 lkscrlrlloll or
~uul!\rr ~Itmr
I. Monpilgc
2. l'rcdilcnrd
3. Crcl!ilcnrd
4. Crcdilcnrd
S. I.onn
6. 1.01111
EXIlIUIT "I)"
LIST OF MAIUTAL mmT
Nlllllcsnf NUllu:soJ' VllIUCll!iUI'
nlLCr~~ill1/~ nUJl'.hwu 1>1I1cActiOll
!:lmmlffi\r.4
1I:lIlkllfAl1lcriclI IllIshil/ltl mill Wile S 104,390 W18)
S93,.162 (IIUO)
CililJnnk Preferred Ilusbl1lld lUltl Wile S4,21,0 (12IJ0~17)
l'ACFCll Visa Ilushnnd nud Wili; SoI,J.I3 (12/9197)
Discover Ilushlllld lIIul Wile S3,I69 (12/3/97)
l'ACFCll Ilushltlld and Win: S58,877 (2128N8)
S51,342 (03/31100)
IJANulilll1111Unnk Ilustlll/U.lnndWilc S6,252 (12113/97)
ROBERT V, L1MRIC,
Pluintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,PENNSYLVANIA
: NO, 911-11611 CIVIL
CONNIE L1MRIC,
: CIVIL ACTION - LA W
: IN DIVORCE
Defendant
AFFIDAVIT OF CONSENT
I. A Compluint in Divorce under Section 3301(e) of the Divorce Code
was filed on F ~ I \ . I ~ ?&
2, The marriage of the Pluintiff and Defendunt is irretrievubly broken, and
ninety days have elapscd since the dutc of filing and scrvice of thc Complaint.
3, I consent to the entry of a Final Deerce in Divorce after service of
notice of intention to rcquest entry of the dccree,
I verifY that the statements made in this Affidavit are true und correct. I
understand that false stutements herein ure made subject to the penulties of 18 Pa.C.S, ~
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Robert V, Limric
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ROBERT V, L1MRIC,
Pluintiff
IN TIlE COURT OF COMMON PLEAS
CUMIJERLANIJ COUNTY, PENNSYLVANIA
NO. 98-868 CIVIL
CONNIE L1MRIC,
CIVIL ACTION - LAW
IN DIVORCE
Defendant
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDEI{ SECTION 3301 (c)
OF THE DIVORCE CODE
I, I consent to the entry of a final Decree in Divorce without notice,
2. 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 grunted,
3. I understand that I will not be divorced until a Divorce Decree is
entered by the Courl and that a copy of the Decree will be sent to me immediutely after it
is filed with the Prothonotury.
I verify that the stutements made in this Affidavit are true and correct. I
understand that false stutements herein arc made slIbjcetto the pcnulties of 18 Pa.C.S
Section 4904 relating to unsworn falsifieutionto authorities.
Date: /0, t'~ dO(') I
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Robert V. Limric
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ROBERTV. LIMRIC, : IN THE COURT OF COMMON PLEAS,
PlaintifTlRcspondcnt: CUMBERLAND COUNTY, PENNSYLVANIA
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: NO. 9B-B6B-CML
CONNIE L. LIMRIC, : CML ACTION - LAW IN DIVORCE
DefendantIPetitioner:
ORDER
AND NOW, this
q-d
day of LI Ii AI llAle. y'
, 2001, after
review of the attached Petition for Contempt and Special Relief, it is hereby
ORDERED AND DECREED that Respondent, Robert V. Limric, should show
cause, if he has any, why the relief requested should not be granted. It is further
ORDERED AND DECREED that until further Order of This Court, Respondent
is prohibited from dissipating any assets. Specifically, Respondent is prohibited
from selling or otherwise transferring and from establiShing a lien against or
otherwise diminiShing the value of any of property including the 1997 Ford
Ranger, Respondent's retirement and 401(k) accounts at Mold Base Industries,
and any other property in Respondent's name, controlled by Respondent or in
&6~ '''~Wt~ cll.c..
Respondent's possession. Further, R':'.1Jl8RSIIRt ii: prohibited from removing any
funds from the Certificate of Deposit account number 17250-029 at Pennsylvania
Central FCU.
RULE RETURNABLE 10 DAYS AFI'ER MAILING. WL ~c;...~~ c...
~ Met. "6'" g ~ ~. ~
Edward E. Guido, J.
attached hereto marked Exhibit "8" and incorporated herein by l'efer'('/I('"
5. Petitioner received a telephone call from Pennsylvania Central 1''CU on
January 5, 2001, indicating that no payments have been made Hlnel!
November 12, 2000.
6. Respondents failure to pay the loan at Pennsylvania Central Ii'CU iH In
direct violation of the May 27, 1998, Order.
7. Petitioner requests that Respondent be held in contempt of COlll't, be
ordered to bring the loan at Pennsylvania Central FeU current und IIIlIke
payments as required by the lender.
8. On or about October, 2000, Respondent quit his job at Mold Base Industries
where he made in exeess of $52,000.00 per year. This occUlTed at the time
the Masters hearing was scheduled in the divorce matter. The Masters
hearing has been continued with a conference scheduled with the Master
in February.
9. Respondent filed for a decrease in the amount of support that he puys, Suid
request was denied and the support matter is set for a contempt helll'ing
before Judge Oler.
10, Respondent has indicated to Petitioner and also to the eonference of'fker' lit
the support conference that he does not care if he is throwlI illjllillllldl.hlll
he will not do work relens!' iflw is illjnil.
11. Petitioller believes nlld UIl'I'l'I'O/'(' nVl'l'S 111111 lll'spOIIlI!'1I1 IlIIlY dissipllll'
IlInl'ilnl nSSl'ts ill all l'f'fol" IO/lvoid /lilY JI/l,VlI"'llls 10 1'l'liIIOlll'I'IIlIIII' divo/'('l'
matter.
12. Petitioner believes and therefore avers that Respondent is being paid
"under the table" in order to avoid the payment of the full amount of
support.
13. After separation of the parties, Respondent took a loan against his 401(k) at
Mold Base Industries. Petitioner believes this was done to avoid
distribution to Petitioner.
14. Petitioner believes that if Respondent has not already done such, he may
try to remove all of the funds remaining in his 401(k) and retirement
accounts with Mold Base Industries.
15. Respondent's 1997 Ford Ranger is free of any lien.
16. Petitioner believes and therefore avers that Respondent may try to establish
a lien against the truck or try to sell it in order to avoid payment to
Petitioner.
17. Petitioner request that Respondent be prohibited from any further
dissipation of assets,
18. Petitioner has incurred attorney fees in meeting with counsel, preparation
of this Petition and will incur attorney fees for representation at the hearing
on this Petition.
19. Petitioner requests tl1at Hespondent be required to pay Pelitionel"s
reasonable allorney f('('s ill bringing this contclllptlllaller to Cour1.
" ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
bi!(. 11,,'1 (!/UIC; /C,(7V
State Commonwealth of pennsylvania /J.J/(,(;p< 1711~{){;'/7
Co.lClty/Dlsl. o( CUMBERLAND '" ~
Date of Order/Notice 01/14/02 .w.. .A 7/ f&
Court/Case Number (See Addendum (or case sumnldry)
o Orl~lnJI O"lt'r/NnUcl!
(E) ^nll'llllt'cl Onll'r/Nullcl!
o Tt'nnln.lh! Onll!r/Nnllce
EmploycrlWilhhold.r's Fcd.,,1 EIN Numl."
FOUST MACHINE & TOOL
Employ.rlWilhhol,lc~s N.m.
6380 BASHORE RD
Employ.rlWilhhold.r's Add",..
MBCHANICSBURG PA 17050-2801
IRE, LIMRIC. ROBERT V,
I [m"luY(~I'IOhIlK()r'!Io N.lme (Lout, flfll, Mil
I 196-52-0221
I EmplnYI't'/OhIlKUf'!Io SnelJI S,'curlly Nurnl>t!r
I 4951100028
I EmplnYI!e/Obllgor's c.ut! Ichmllfll!r
I (5.. Add.ndum (or pI.lnll(( n.m., ."od.l.d with r.s.. on '''"hm.nll
) Cuslmllal P.wml's Nolme (last, FIBI, Mil
)
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER /NFORMA T/ON: This is an Order/Notice 10 Withhold Income for Support based upon an order (or support
from CUMBERLAND County. Commonweallh of Pennsylvania, By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until (urther notice even If the Order/Notice is not
issued by your State,
$ 1. 01!!. 00 per month in currenl support
$ 43.45 per month in past-due support Arrears 12 weeks or grealer? 0 yes <X> no
$ Q.....Q..Q.per month in medical support
$ 0.00 per month (or genetic test COSlS
$ per month in other (specify)
for a total of $ 1.062.45 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order, If your pay cycle does not match
the ordered support payment cycle. use the foliowing to delermine how much to wilhhold:
$ 245.18 per weekly pay period.
$ 4!!0. 36 per biweekly pay period (every two weeks),
$ 531. 23 per semimonthly pay period (twice a month).
$ 1.062.45 per monthly pay period,
REMITTANCE INFORMAT/ON:
You must begio withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydatefdate o( withholding, You are entitled to
deduct a fee to defray the cost of withholding. Refer 10 the laws governing the work state of your employee for the
the aliowable amount. The total withheld amounl, and your fee, cannot exceed 55% of lhe employee'sf obligor's
aggregate disposable weekly earnings. For the purpose of the Iimitalion on withholding, lhe foliowing information is
needed (See #9 on pg. 2).
If remitting by EFT/EDI, please cali Pennsylvania Slate Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1 -877-676-9580 for instructions,
Make Remittance Payable to: PA seou
Send check to: Pennsylvania seou, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURtTY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BY THE COURT:
Date of Order: 'JAN 2 5 2002
Service Type M
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Jl,.J lD (,:
Form EN-028
Worker ID $IATT
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, ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If checked you dH! required to provldl!.1 fOpy of ,hili form to your mnployel~.
1. Priority: Wlthholdh,g under Ihi. Ordm/Notln. h,,, priority ov'" ,lilY oll",r leg"I,,,,)[e,, IInd", Slale law dgalnlllhe .ame Inmn..,.
Federal tllK levlmlll effcct bH(ore recelpl oflhl~ ordl~r Ilt1VI~ priority. Irthl!U! .HI! FI!d~r.llld)( hwll!S In I!((ert pleJ!iI! COlllde1 till! requestlllK
agency IIlled below,
2. Combining Pdyments: You Cdll ((Jll1hhu! wilhlwld dl110untllj (rol11 more th.tll U1H! employef!/ohIlKor's Incolll!! In d ShlHh! pdymf!lll
10 each agency requeltlng Wllhholdlng. YOII mll,I, however, "'parall,ly Idenri(y Ihe portion of Ih.. .ingle payn",nt Ihalll allrihlllable 10
each employee/obligor,
3.' -Reportlng-the-PaydatelDa~ofWllhholding:-YolI mll.t",porl the paydale/dale'of withholdinltwhelMendlnltthe-payment;-The-
poydllleldll1e'ofwithholding-;,.thedate on-which-amollnt wa. withheld Imm.the'employee".wage" You mUll comply with II", law o( Ihe
l!.lte of the employee's/obllgor'l principal place 01 employment wilh ,"'pect 10 Ihe lime period, wilhln which you mUlt Implement the
withholding order and (orward Ihe IUpport payment,.
4,' . Employee/Obligor with Multiple Support Holding!: If Ih..re I, more Ihan one Order/Notice to Withhold Income lor Support
agalnlt Ihls employee/obligor and you are unable to honor all ,upport Order/Notices due 10 Federal or Stale withholding limits, you must
follow the law of Ihe Itale 01 employee'l/obllgor's principal pl"te o( ..mployment. You mUll honor all Orders/Nollces to the greatesl
extent possible. (See '9 below)
S. Termination Notification: You mu,t promplly norily the Requesting Agency when Ihe employee/obligor I, no longer working lor
you, Pleale provide Ihe inlormallon reque'led and return a copy olthl, Order/Notice to the Agency Identified below.
WITHHOLDER'S ID: 2228100142
EMPLOYEE'S/OBLlGOR'S NAME: LIMRIC , ROBERT V.
EMPLOYEE'S CASE IDENTiFIER: 495110002B DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and wilhhold Irom lump sum payments such a' bonules, commllSlons, or
severance pay, IIyou have any quesllons about lump sum payments, conlact Ihe person or authority below,
7. Liability: II you lalllo withhold Income as Ihe Order/Notice directs, you are liable lor both the accumulated amount you should
have withheld from Ihe employee/obligor's Income and other penalties set by Pennsylvania Stale law. Pennsylvania Slate law governs
unless the obligor Is employed in anolher Stale, In which case the law o( Ihe Slale in which he or she is employed governs.
8. Antl-dlscrimlnatlon: You are subject to a fine determined under State law (or discharging an employee/obligor from
employment, refusing 10 employ, or laking disciplinary aClion againsl any employee/obligor because 01 a support wllhholding.
Pennsylvania S!.lte law governs unless Ihe obligor is employed in anolher State, in which case the law of Ihe Stale In which he or she Is
employed governs.
9,' Withholding Limits: You may not wllhhold more Ihan the lesser 01: 1 I Ihe amounts allowed by the Federal Consumer Credit
Protection Act (1 S U.S.C. ~ 1 673 (b)1: or 2) Ihe amounts allowed by Ihe State 01 Ihe employee's/obligor's principal place 01 employment.
The Federal limit applies 10 the aggregate disposable weekly earnings (ADWEI. ADWE Is the net income left after making mandatory
deductions such as: Stale, Federal, local!.lxes; Social Security taxes: and Medicare taxes.
10.
'NOTE: If you or your agent are served with a copy of Ihis order in the stale thaI Issued the order, you are to follow the
law of the state that Issued Ihis order with respect 10 these Items,
Requesting Agency:
DOMESTIC REI.ATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 24Q.6225 or
by FAX al (717) 240-fi24R or
by Internet @
rF;
Page 2 or 2
Form EN-02B
Worker ID$IATT
Service Type M
0,\\0"'0,:0910.01501
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ORDER/NOTICE fO WITHHOLD INCOME FORjUPPORT
bl:( I0?R. ft.? {l/llle
State CommonWl!allh 01 Pl!nnsvlvanla ).,' '[5 /J /I 7
Co.lClty/Dlst, of CUMBERLAND /-'),r:;;. "1711t}Ovl
DateofOrder/Nollce 01/30/U2 JJ/2 .s?'llfu,
Court/Case Number (Sl!l! Addl!ndum for caSl! summary)
o Or'sln.1 Onle,INnllce
o Amt!mlecl Order/Nolle€!
o Tllrmln.ale Onlt!f/Nollcn
Emp1oyerlWllhhuldl!r's f(!der.1I EIN Numh!.!r
MOLD BASI! INDUSTRIES INC
EmploycrlWllhholclt!r's N,lme
7450 DERRY ST
EmploycrlWlthholdcr's Alfffress
HARRISBURG PA 17111-5228
) RE: LIMRIC, ROBERT V,
) Emplnyt'I'/OhIIKur's NoInm (lol\l, Flnl, MI)
) 196-52-0221
I EmplnYII('/Ohllflflr's Sodoll SI~(lJrlly Numht!r
) 4951100028
) EmJllnyt'I'/Ohllgnr's CaSt! Idl.!nUOt!r
) (5.. Add.ndum for pI.lntif( n.m.. mod.,.d with c.... on ,".mm.n/)
) CuslfllU..1 PJn'nl's NoIml! (LdSI, Flnt. Mil
)
See Addendum far dependent names and birth dates assaciated with cases on attachment.
ORDER /NFORMA TION: This is an Order/Notice to Wilhhold Income for Support based upon an order for support
from CUMBERLAND County, Commonweallh of Pennsylvania, By law, you are required to deduct these
amounts from the above-named employee's!obligor's Income until further nOlice even If Ihe Order/Notice Is not
Issued by your State.
$ 1 ,019.00 per monlh In current support
$ 43.45 per month in past-due support Arrears 12 weeks or grealer! Qyes @ no
$ 0.00 per month in medical support
$ 0.00 per month for genellc test costs
$ per month In olher (specify)
for a total of $ 1,062.45 per manth ta be farwarded to payee belaw,
You do not have to vary your pay cycle to be In compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to delermine how much to withhold:
$ 245.18 per weekly pay period,
$ 490.36 per biweekly pay period (every two weeks),
$ 531.23 per semimonthly pay period (Iwice a month),
$ 1.062.45 per monthly pay period,
REMITTANCE INFORMA T/ON:
You must begin withholding no later than the first pay period occurring len (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/dale of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work slate of your employee for the
the allowable amount. The total withheld amounl, and your fee, cannol exceed 55% of the employee's/ obligor's
aggregate disposable weekly earnings. For the purpose of Ihe limitation on withholding, the following informal/on is
needed (See #9 on pg, 2),
If remitling by EFT/EDI, please call Pennsylvania Slate Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for Instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER 10 (shown
abave as the Emplayee/Obligar's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
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BY THE COURT:
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D t f 0 d JAN;J 1 2DDZ
a e 0 r er:
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4-6.
Form EN-028
Worker ID $IATT
Service Type M
I?[;lJ' 1.m. "'~ ~i:7t
~.,.:i~..C;MA!-.:Il.:0911l'OI'
2 .'-j-t') hpirlllllnO.II": 12fJI/OO
.~:~
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o II checked you are required '0 provide a wpy of Ihl. lorm'o your I!mploYl!e.
1, Priority: Withholding under Ihl. Ordl!r/Nolkl! ha. prlorlly oVl!r any olher Il!gal promll undl!r S'ale law agaln"lhe .ame Income.
Federal tax levies In ellecl belore recelpl ollhl. ordl!r have prlorlly. II Iherl! are Fl!dl!ral tax Il!vle. In elfecl plea.e conlacllhe reque'llng
agency IIsled helow,
2. CornblnhlK Pdynwnl5: You r.1I1 CfJlnhhm wilhhl!ld dI11011l1t!i (ro1111110m Ih.m one (~rnployeelobIlHor'!i Income In d shlRle pJyrnent
10 each agency reque.llng withholding. You mu,', howl'vl'f, "'parall!ly Id","lly II", pnrllon of ,hI! .ingll! paymenlIhalI. allribulable 10
each "mploymyobllgor.
3.' -Reportlng'lhe'P.yd.~JD.te olWithholdlng:-You mu,t report Ihe'p.yd.~Jdale-ol wilhholdlngwhen-.ending.the-poyment;-The-
payd.teId.te-ofwlthholdlng'I"lhe'date onwhlrh'.mount wa. wilhheld-Imm theemployee'.w.ge!; You mU'1 comply wllh Ihe law ollhe
slale 01 Ihe employee's/obllgor's principal place 01 I!mployml!nl with respecllo ,he time period. within which you musllmplemenllhe
withholding order and forward Ihl! .upport paymenl..
4.' Employee/Obligor with Multiple Supporl Holdings: If Ihere Is more Ihan one Order/No lice 10 Withhold Income for Support
agaln.t Ihl. employee/obligor and you are unable 10 honor all .upport Order/Nolices due 10 Federal or Stale wllhholdlng limits, you must
lollow Ihe law of Ihe .Iale 01 employee's/obligor's principal place of employment. You mU'1 honor all OrderslNollce. to Ihe grealest
exlent polllble, (See #9 below)
5. Termlnallon Nollfication: You mU'1 promplly nOlify Ihe Reque.ting Agency when Ihe employee/obligor Is no longer working lor
you, Plea.e provide the Inlormation requested and relurn a copy oflhls Order/Notice 10 Ihe Agency Identified below.
WITHHOLDER'S ID: 2319428350
EMPLOYEE'S/OBlIGOR'S NAME: LIMRIC , ROBERT V.
EMPLOYEE'S CASE IDENTIFIER: 4951100028 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required 10 report and wllhhold Irom lump .um paymenl. .uch as bonu.es, eommllllons, or
.everanee pay, II you have any quelllons aboullump sum payments, eonlacllhe person or aUlhorlty below.
7. liability: If you fail to withhold Income a. Ihe Order/Nolice directs, you are liable lor bolh the .ceumulaled amount you should
have wilhheld /rom Ihe employee/obligor's income and olher penaltle. sel by Penn.ylvania Slale law. Penn.ylvania Slale law governs
unlell Ihe obligor I. employed In anolher Srale, In which ea.e Ihe law 01 Ihe Slale In which he or she I. employed governs.
8. Anll-dlserlmination: You are subjeello a fine delermined under Stale law for dl.charglng an employee/obligor /rom
employment, refusing 10 employ, or taking disciplinary aclion agalnll any employee/obligor beeau.e 01 a support withholding.
Pennsylvania Stale law governs unlell Ihe obligor Is employed in anolher Slale, In which case Ihe law ollhe Stale In which he or she Is
employed governs.
9.' Wilhholding LimllS: You may nol withhold more Ihan the leller 01: 1) the amounts allowed by the Federal Consumer Credll
Protection Act (1 5 U.S.c. ~ 1673 (b)1; or 2) the amounls allowed by Ihe Slale 01 Ihe employee's/obligor's principal place 01 employment.
The Federal limit applies to Ihe aggregale disposable weekly earnings (ADWE). ADWE Is the nel income lefi afier making mandatory
deductions such as: Slate, Federal, local taxes; Social Security taxes; and Medicare taxes.
10.
'NOTE: If you or your agenl are served with a copy of this order in the state Ihat issued Ihe order, you are to follow the
law 01 Ihe state that Issued Ihis order with respect to these items,
Requesting Agency:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 1 7013
II you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by lelephone at (71 7l 240-6225 or
by FAX at 17171 240-6248 or
by Inlernet @
Page 2 01 2
Form EN-028
Worker ID $IATT
Service Type M
0.'.18 No.: 0910.015..
hplrl.ltonOl.ln: 12/11100
ADDENDUM
Summary 01 Cases on Allachment
Defendant/Obligor! LIMRIC, ROBBRT V.
PACSES C,lIe Number 971100017 ~ '71 N;, PACSES C.lm Nu",j,,'r
Plalntl(l Name /'" Plalntlfr Nan..,
CONNIE L. LIMRIC
J22tJm1 Alti\(hnlfml Amount
868 CIVIL 98 S 1,062,45
Chlld(ren)'s Name(s):
TANYA DANIELLE LIMRIC
JBS9BRYAN LIMRIC
DOB
DOB
06/20/81
08/28/82
Atti1rhnwnt Amount
S 0.00
Child(,en)'s Name(s):
Dorket
o Ir checked, you are required to enroll the chlld(ren)
Identified above in any heailh Insurance coverage available
through the employee's/obllgor's employment.
o II checked, you a,e required 10 enrolllhe chlld(ren)
identified above in any heailh insurance coverage available
through the employee's/obllgor's employment.
PACSES Case Number
Plaintiff Name
Docket Anachment Amount
So.oo
Child(ren)'s Name(s):
PACSES Ca,e Number
Plalntill Name
DOB
Docket Attarhment Amount
S 0.00
Childilen)'s Nameh):
DOB
..-...-......-....,_...._'..,...._' '..
bli~hecked; you ~re required 10 enroll the child(ren)
identified above In any heailh insurance coverage available
through the employee's/obligor's employment.
o Ir checked, you are required t; enroll the child(ren)
identilied above in any heailh insurance coverage available
Ihrough the employee's/obllgor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
S 0_00
Child(ren)'s Name(s):
PACSES Case Number
Plaintirr Name
DOB
Docket Anarhment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
Dlrchecked, you are required to enroll the child(ren)
Idenlified above in any health insurance coverage available
through the employee's/obllgor's employment.
o II checked, you are required to enroll the child(ren) .
identified above in any heailh Insurance coverage available
through the en,ployee's/obllgor's employment.
Addendum
Form EN.028
Worker 10 $IATT
Service Type M
OMB No.: 0910.0154
hplr.llonO.lp.: 12/]1100
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.
ORDER/NOTICE TO WITHHOL~~{OIt:.\l{J~'s'~'~PORT
/),1// q'~: - , " (I/f'd..
Stale Commonwealth of Pennsvlvanla '}/('('f'(, (II/I {, ('tV 7
Co./Clty/Dlst, o( CUMBERLAND I ~ . .' -
Date of Order/Notice 02/04/02 ,c ,;J 71 '!J{("
Court/Case Number (See Addendum (or case summary)
o Orlglnill Onll!r/NnllCl!
o Amended Onlt!r/Nollcc
o Tcnnln.1le Onler/Nollce
R
,
Emploverl'Nilhholdcr', Fcdcr.ll EIN Numher
POUST MACHINE & TOOL
Employer/Wllhhohler's N.me
6380 BASHORE RD
Employer/Wllhholder's Add",,,
MECHANICSBURG PA 17050-2801
) RE: LIMRIC, ROBERT V.
) EmpluYI!l'/Ohllgnr'. NJml! (l,ul, Flnt, Mil
) 196-52-0221
) Employc(!/Ohllgllr's SUdoll Sllcurlly Number
) 4951100028
) Employee/Obligor's c.ut! Identifier
) (5.. Addendum (IN pI.lnl/ff n.m"'lSod.r.d wllh <"" on ",.chmenl)
) Custodial P.nenl', Name (lasl, Flrsl, Ml)
)
See Addendum (or dependent names and birth dates assodated with cases on allachment.
ORDER INFORMATION: This Is an Order/Notice to Withhold Income (or Support based upon an order (or support
from CUMBERLAND County, Commooweaith of Pennsylvania, By law, you are required to deduct these
amounts from the above-named employee's/obllgor's iocome until further notice even if the Order/Notice Is not
Issued by your State,
$ 0.00 per month In current support
$ 0.00 per month In past-due support Arrears 12 weeks or greater? 0 yes @ no
$ 0.00 per month in medical support
$ 0.00 per month for genetic test coSlS
$ per month in other (specify)
for a total of $ 0 .00 per month to be forwarded 10 payee below.
You do oot have to vary your pay cycle to be In compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 0.00 per weekly pay period.
$ 0.00 per biweekly pay period (every two weeks).
$ 0.00 per semimonthly pay period (twice a month),
$ 0.00 per monthly pay period,
REMITTANCE INFORMATION:
You must begin withholding 00 later than the first pay period occurring ten 11 0) working days after the date of this
Order/Notice, Send payment within seven (7) working days of the paydate/date of withholding, You are entitled to
deduct a fee to defray the cost of withholding, Refer to the laws governing the work state of your employee for the
the allowable amount. The total withheld amount, and your fee, canoot exceed 55% of the employee's! obligor's
aggregate disposable weekly earnings, For the purpose of the limitation on withholding, the following Information Is
needed (See #9 on pg. 2). .
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at '-877-676-9560 for Instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Oblisor's Case Identi(ier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BY THE COURT:
Dale of Order:
FEB 5 20r2
Service Type M
1}~.~1 ~ t'fff ~~
I~MBNa.:o91()'()1'4
;;.. 7. C;). hpl~llon Dolle: 12/J 1/00
'Yu D&-c
Form EN-028
Worker 10 $IATT
.
" ADDITIONAL INFORMATION TO EMPLOVERS AND OTHER WITHHOLDERS
o If checked you are required 10 provide a copy of Ihl. rormlo your ",nployee.
1, Prlorfly: Withholding under Ihl. Order/Nollee ha, priority OVI!! any olh"r leg,,1 process und"r Stale law aRJin.tlhe .ame Income.
Federall.1x levle. In effect before receipl or thl. order have priority. Ir Ihere ar" f"d",allJ' levle. In efrecl plea.e conlact Ihe reque.tlng
agency lI.ted below.
2, Combining Payments: Vou can comhlne withheld amount. from more Ihan one employerJobllgor'. Income in a single payment
to each agency reque.tlng withholding. You mu.I, however, .eparalely Id"'\Ilfy Ihe pMlon of the single payment Ihat is a"ribulable 10
each employee/obligor,
3.' -Reporting1he-PaydotelOale'ofWithholding,-Vou-must-reportthe-p;1ydoteldale'ofwithholdinRwhen..endinR!he-poyment,-l!le-
poydotl!!d.1O of hlthholding-k-the-dllle-olt'Whlchllmountwuwithheld'fmm-the-employee'. woge!' You mu.t comply with the law of the
sl.1te of the employee's/obllgor's principal place of employment with re.peclto thp. time period, within which you mu,t Implement the
withholding order and forward Ihe ,upport paymenls.
4.' Employee/Obligor with Muhlple Support Holdings: If there Is more than one Order/Notice to Withhold Income for Support
agalnsl this employee/obligor and you are una hie to honor all support Order/Nollces due 10 Federal or Stale withholding IImhs, you must
follow the law of Ihe state of employee's/obllgor's principal place of employmenl. You must honor all Orders/Nollces to Ihe greatest
extent possible. (See #9 below)
S, Termination Nolificallon: You must promptly notify the Reque,lIng Agency when the employee/obligor is no longer working for
you, Plea,e provide the Information reque'ted and relurn a copy of this Order/Notice 10 the Agency Identified below,
WITHHOLDER'S ID: 2228100142
EMPLOYEE'S/OBLlGOR'S NAME:
EMPLOYEE'S CASE IDENTIfiER:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
LIMRIC. ROBERT V.
4951100028 DATE Of SEPARATION:
6. Lump Sum Payments: You may be required to report and withhold from lump sum paymenls such as bonu,es, commissions, or
severance pay. If you have any questions aboullump ,um payments, contaclthe person or aUlhorily below.
7. L1abllily: If you fall 10 withhold Income aSlhe Order/Notice directs, you are liable for bolh the accumulated amount you should
have withheld from the employee/obligor's Income and other penaltie, ,et by Penn'ylvania Slate law. Penn'ylvania State law govern,
unless the obligor I, employed In another State, in which ca,e Ihe law of the Slale In which he or ,he i, employed govern,.
8. Anti-di,crlmlnatlon: You are ,ubject to a fine determined under Stale law for di,charging an employee/obligor from
employment, refu,ing to employ, or taking di,ciplinary acllon again" any employee/obligor becau,e of a ,upport withholding.
Penn'ylvanla Stale law govern, unless the obligor i, employed in another Stale, in which ca,e Ihe law of Ihe Stale in which he or ,he I,
employed govern,.
9,' Withholding Limits: You may nol wilhhold more Ihan Ihe lesser of: 1) the amounts allowed by Ihe Federal Con,umer Credit
Prolectlon Act (1 S U,S.C. 51673 (b)l; or 2) Ihe amounl' allowed by the State or the employee's/obligor', principal place of employment.
The Federalllmilapplie, 10 the aggregale di'po,able weekly earning' (ADWE). ADWE is the nel income left after making mandalory
deductions such as: Sl.1le, Federal, local taxes; Social Securily taxe,; and Medicare l.1.e,.
10,
ONOTE: If you or your agent are served with a copy of Ihis order in the state that issued the order, you are to follow the
law of the state that issued this order with resped to these ilems.
Requesting Agency:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
conlad WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717) 240-6248 or
by Internet @
Page 2 of 2
Form EN-028
Worker 10 $IATT
Service Type M
O,\IB~.:0970-a1S"
hpl"UonO'Ill: 12131/00
State Commonwealth of Penn~vlvanla
Co.lCity/Dl~t, of CUMBERLAND
Dilte of Order/Nolice 09/30/02
Trlbunal/Clse Numher fSee Addendum (or Colse summ.lrY)
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
lJkI. I"'" ~f C,IIIL
1'/fI~S'Ff '711~()()17
~ ,,77/1(,
OOriMillolIOHll't/Nnlln.!
@ Anwnd(.tl Orch'r/Nollw
o Icrmln,llr. Onlrr/Nuliu'
MOLD BASE INDUSTRIES INC
7450 DERRY ST
HARRISBURG PA 17111-5228
R[: LIMRIC , ROBERT V.
l.rnlllnvcc/Ohllgor's Nitm('ll.,sl. I irst. Mil
196-52-0221
I:rnployrl'IObllRnr's Sociill Sccurlly Number
4951100028
[mployc{!/Obligor'!j C.ne Identifier
(S.. Add.ndum (0' pl.ln/iI( n.m..
.u5ocl.:lI~d with CtlS(lS on "UlIrhm(lnlJ
CustodiO'll ('.1fenl'S Name llasl. first. Mil
lmploycrlWilhholdl"'s r(~IIr.I.tl [IN Numht!1
See Addendum (or dependent names and birth dates ,lSsociated with cases on attachment.
ORDER INFORMA TlON: Thi~ i~ an Order/Notice to Wilhhold Income for Support ba~ed upon an order for ~upport
from CUMBERLAND County, Commonweallh of Pennsylvania. By law, you are required 10 deduct these
amounts from the above-named employee's!obligor'~ income until further notice even if the Order/Notice i~ not
Is~ued by your State.
$ 1,019,00 per month in current support
$ 28,97 per month in past-due ~upport Arrears 12 week~ or greater? @ye5 0 no
$ 0.00 per month in medical ~upport
$ 0 . 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 1, 047 . 97 per monlh to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the ~upport order. If your pay cycle doe~ not match
the ordered ~upport payment cycle, use the following to determine how much to withhold:
$ 241.84 per weekly pay period.
$ 483.68 per biweekly pay period (every two weeks).
$ 523.99 per semimonthly pay period (twice a month).
$ 1.047 . 97 per monthly pay period.
REMITTANCE INFORMAT/ON:
You mu~t begin withholding no later than the first pay period occurring ten (10) working days after the date of thi~
Order/Notice. Send payment within seven (7) working days of the paydateldate of withholding, You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount, The total withheld amount, and your fee, cannot exceed 55% of the employee's! obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #10 on pg. 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCOU
Send check to: pennsylvania SCOU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Emptoyee/Obligor's Case Identi(ier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
Date of Order: Oc... t, L. I 1 OD)
Service Type M
~
,__ ,..,- 'i'";""!'
~'4'~~~ !~1~~ .', II.: IJ'J70-01 54
It):~ f))
Form EN-028
Worker ID $IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If ~heckCjI you are re(lulrl't1 to Jlrr~I\le a ropy o( Ihls (orm to your cl11/,loyee. If YOl'r ,,"'ployec works In iI sl"I('lh"t Is
dlt(crenllrorn the stille Ihilt issuel 111 Is order, il copy must he provhlC( 10 your 1!111(J OYltt! cVlm if t1W hox Is nol c1l(~fk('d.
1. We appreclale the volunl,ny cornpll"nct! of F,,"'r,llly rt!(()nnlll.d Indi,lI1lrihes, Irihally.owned husinesses, ,1I1l11r1lIlillH1WI",d
huslnrsses IDcilled on i1 rescrv.ltlon Ihill choose 10 withhold In .1ffonl.lnre wUh this nollc{~.
2. Priorlly: Withholding under Ihls Order/Nolin! has priority oV(~r tiny olher Icgill process urHIN StIlle IIIW ag.linst the Silnw Income.
FcdcralllJ)( levies In cffccl hefore receipt of this unlt!r h.wI! I)riorily. If Hum.' .lrc F('d(!f.,lliIX levies In ('((eet ph_w~c conlact the requesting
agency listed helow.
3, Comhlnlng Paymenls: You c"n comhlnt! wilhheld ,)l1Iounls from more Ih"n one el1lployee/ohligor's Incol11e In a single paYl11enllo
cilch agency requesting withholding. Vou must, how~ver, sCJlitr.llcly idcntify lhe portion of thc single paymcnt that is altribut,lhlc 10 each
el1lployee/obligor,
4. "Reportingthe Payt!ate/Date ofWilhholding:-Y ou-mu,1 report-thepayt!ate/dalC"of-withholdingwhen-,endingthe payment;-The-
payt!ale/date ofwithholding-I'-the datC"on-whichamollnl w35-withheld-(rom-the empIOYl't!','wag""c You must comply with the law o( Ihe
state of Ihe employee's1obllgor's principal place of employment with respecllo Ihe lime periods within which you l11ust Implement the
withholding order and forwanl the support payments.
5.' Employee/Obligor wllh Multiple Support Holdings: I( li1t!re is more Ihan one Order/Notice 10 Withhold Income for Support anainsl
Ihis employee/ohligor and you are unahle to honor all support Order/Notices due to Federal or Stale withholding Iimlls, youl1lusl follow
Ihe law o(the slale of employee's1obligor's principal place of employment. You must honor all Orders/Nolices 10 Ihe grealest exlenl
possible. (See #10 below)
6. Termination Notification: You musl prompliy notify the Requesting Agency when the employee/ohllgor is no longer working (or you.
Please provide the In(ormation requested and relurn a copy o( this Onler/Notice to Iht! Agency identified helow.
WITHHOLDER'S 10: 2319428350
EMPLOYEE'S/08L1GOR'S NAME:
EMPLOYEE'S CASE IDENTIFIER:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
LIMRIC, ROBERT V.
4951100028 DATE OF SEPARATION:
7. Lump Sum Payments: You may be required to report and wilhhold (rom lump sum Ilaymenls such as honuses, commissions, or
severance pay, If you have any questions ahoullump sum paymenls, conlacl the person or aUlhority helow.
8. Liability: If you (all 10 withhold income as the Order/Notice direcls, you are liable for holh Ihe accumulaled amounl you should have
withheld from Ihe employee/obligor's Income and other penalties sel hy Pennsylvania Slale law. Pennsylvania Stale law governs unless
Ihe ohligor Is employed In anolher Stale, in which case Ihe law of Ihe Slate in which he or she is employed governs.
9. Antl-dlscrimlnation: You are subject to a fine delermined under State law (or discharging an employee/obligor from employmenl,
refusing to employ, or taking disciplinal)' action against any employee/ohligor because o( a support withholding. Pennsylvania Stale law
governs unless the obligor Is employed in anolher 51 ale, in which case lhe law o( the Slate In which he or she Is employed governs.
10.' Withholding Limits: You may not withhold more than the lesser of: 1) Ihe amounts allowed hy Ihe Federal Consumer Credit
Prolection Acl (15 U.S.c. ~1673 (b)l; or 2) Ihe amounls allowed hy Ihe Slale of the employee's/obligor's principal place of employmenl.
The Federal limit applies 10 Ihe aggregate dlsposahle weekly earnings (ADWE). ADWE is Ihe nellncome left afler making mandatoI)'
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes.
11. Additional Info:
'NOTE: If you or your agenl are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to Ihese items.
Submitted By: If you or your employee/obligor have any questions,
DOMESTIC RELATIONS SECTION conlact WAGE ATTACHMENT UNIT
13 N. HANOVER ST by telephone at (717) 24lJ..6225 or
P.O. BOX 320 by FAX at (717) 24lJ..6248 or
CARLISLE PA 17013 by Internet
Page 2 of 2
Form EN-028
Worker ID $IATT
Service Type M
OMB No.: lllJ70.{)1.S",
ADDENDUM
Summary of C.ues on AlIachment
ROBERT V.
Defendant/Obligor: LIMRIC,
PACSES Ca,e Number 971100017 4?.IJt,
PI,llnll(( N,lme '/ ..
CONNIE L. LIMRIC
.I2!lds.!:I Allachmenl Amount
868 CIVIL 98 S 1,047.97
Child(ren)'s Nilme(s):
TANYA DANIELLE LIMRIC
JESSE RYAN LIMRIC
PACSES Cil'i(l Numl)(lr
Plillnlll(N,lIlll:
Dock<'1
AlIllchnwnt Amount
$ 0,00
Child(ren)'s Name(sl:
DOB
DOB
06/20/81
08/28/82
o II checked, you are required 10 enrolllhe child(renl
Idenllfied above In any heallh Insul'ilnce coverage available
through Ihe employee's!obilgor's employmenl.
o If checked, you are required 10 enrolllhe Child(ren)
Idenlified above In any heallh Insurance coverage available
through Ihe employee's!obllgor's employmenl.
PACSES Case Number
Plalntlf( Name
.I2!lds.!:I Allaehment Amount
S 0,00
Child(ren)'s Name(s):
PACSES Ca,e Number
Plalnlif( Name
DOB
Dockel Allachment Amount
$ 0.00
Chlld(ren)'s Name(s):
o If checked, you are required to enrolllhe chlld(ren)
Idenlified above In any heallh Insul'ilnce coverage available
Ihrough the employee's!obllgor's employmenl.
o If checked, you are required to enroll the chlld(ren)
Idenlified above in any heallh insurance coverage available
Ihrough the employee's!obllgor's employment.
PACSES Case Number
Plaintiff Name
Dockel Allachmenl Amounl
$ 0.00
Chlld(ren)'s Name(s):
PACSES Case Number
Plalnlil( Name
Docket Altarhmenr Amount
$ 0,00
Chlld(ren)'s Name(s):
DOB
DOB
o If checked, you are required 10 enroillhe child(ren)
identified above in any health insurance Coverage available
Ihrough the employee's!obilgor's employ men I.
Olf checked, you are required 10 enroillhe Chlld(ren)
Idenlified above In any heallh Insul'ilnce covel'ilge available
through Ihe employee's!obllgor's employmenl.
Service Type M
Addendum
Form EN-028
Worker ID $IATT
O"'BNo,:ll'J7o.lIIS~
DOB
cu ~
rr. c (--
-.L Z
.- N -,-
uF1 ,- .,:;
'.?~/
t.)i':, :C '~~.L
Ft.. a- '::~
c:51:., Cl .':.0-
;1:,'.'
c.:: I ;~ - ;',!-jP
l.ut~-
:...J", l- ~i1l:U
u:: _c, U U.\o..
.'. 0 :~
.~
l'-- N -::>
0 0 D
-.
In th~ Conrt of Common 1'I~lIs of
COllnty, J>cnnsylvlInln
CUMIIERLANJ)
1I0ME~TIC REI.A'nONS SECflON
1.\ N, II'\Nll\'ER ST, 1',0. IIOX 320, C,\RI.ISU:, \',\, \7013
Dcfcndant Namc: ROBERT V, LIMRIC
Mcmbcr ID Numhcr: 4951100028
l'lell!i1! note: All t'orn"llondt'ncc InILlillndlldc Ihe McmlK'r III NUlllhcr.
ORDER OF ATTACHMENT OF UNEMPLOYMENT COMJ>ENSATION BENEFITS
FlnllnclulllrclIk Down of Mnltlplc CIISCS on Attllchmcnt
f1lalnliffNamc
CONNIE L. LIMRIC
PACSES
ClI'iCNulTlhcr
971100017
Duckel
NUll1hcr
868 CIVIL 98
i
$
$
~
$
1,047.97 I. MONTII
~
I
~
~
I
I
AllilchmclIl AI1111UnllFrcuucllcv
TOTAL. '\1TACIIMENl' '\MOllNl': $
1,047.97
Now, by Order of Ihis Court, the Department of Labor and Industry, Bureau of Unemployment
Compensation Benenls and Allowances (BUCBA), is hereby directed to auach the lesser of $ 241. 84
per wcck, or 50 %, of lite Unemployment Compensation benents otherwise payable to the Defendant,
ROBERT V. LIMRIC Social Security Number 196-52-0221 ,Member
ID Number 4951100028 . BUCBA is ordered to remit the amount auached 10 Ihe Department of Public
Welfare (DPW). DPW shall forward the Ilmount received from BUCBA 10 the Domestic Rclalions Section of this
Court for support and/or support Ilrrcarages.
If the Defendant's Uoemployment Compensation benents arc attached by another Court or Courts for
support and/or support arrearages, DPW may reduce Ihe amount attached under this Order so thatlhe total
amount attached docs not excced the maximum amount subject to garnishment pursuant to 15 U,S.C. ~ 1673
(b)t2) and 23 PII. C.S,A. ~ 4348 (g).
This Order shall be effective upon receipt of the notice of the Order by Ihe BUCBA and shall remain in
cffect until the Defeodant's cntitlement to Unemployment Compeosatioo benents, under the Application for
Beoents dated SEPTEMBER 7, 2003 is exhausted, expired or defcrred.
BUCBA shall comply with this Order, unless it is amended or vacatcd by subsequent Order of this Court.
All questioos, challenges or obligations 10 this Order shall be directed to Ihe Domestic Relalions Sectioo of this
Court.
BY THE COURT
Date of Order: 'SEP 1 R iOq~
?- ~ 4.-
Kc=oJv4. Hl:::-s''j
JUDGE
(
Servicc Type M
Form EN-530
Worker ID $IATT
ORDER/NOTICE TO WITHHOlD INCOME FOR SUPPORT
Slale Commonweallh of Pennsvlvanla
Co.lCily/DI5t. of CUMBERLAND
Date of Order/Notice 08/06/04
Tribunal/Case Number (See Addendum for C,lSe summary)
~I.: LIMRIC , ROBERT V.
[rnployc!'/OI,llgor's N.unC' (1.lst, rirsl. Mil
6) ()riRIJ1.l1 Ordl',INulin1
o AI111'mll'd ()"fe'f/Nnllce
o Il'rrnlll.lh' ()rlll',/Nnlln'
EmployC'rlWilhholdc,'s Federal [IN Numlx'f
G. DAVID GELBAUGH
45 HILLDALE RD
ETTERS PA 17319-9651
i)J/
jJ)1C~[';
'if 1,'9' -/17ct ('II
Cl'7llc-c617
196-52-0221
[,"ploYf~('/Ohligor's 5ocl.1I SI!curlly Numher
4951100028
[mployer/Obligor's Ca~ Iclenllfil"r
(5.. Md.-dum for pl.lnllff n.m.,
duocl.'rd with cast's on attdchmrnlJ
CUSlodlJI Parent's Name Il.1St. rirsl. MI)
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee'sfobligor'5 income until further notice even If the Order/Notice is not
issued by your Stale.
$ 1.019.00 per month in current support
$ 28 . 97 per month in past-due support Arrears 12 weeks or greater? <Xl yes 0 no
$ 0,00 per month in medical support
$ 0.00 per monlh for genetic test cosls
$ per monlh In other (specify)
for a total of $ 1,047.97 per month 10 be forwarded 10 payee below.
You do not have to vary your pay cycle 10 be in compliance wilh the support order. If your pay cycle does not malch
Ihe ordered support payment cycle, use the following to determine how much to wilhhold:
$ 241.84 per weekly pay period.
$ 483.68 per biweekly pay period (every two weeks),
$ 523.99 per semimonthly pay period (twice a month).
$ 1.047.97 per monthly pay period.
REMIT7ANCE INFORMATION:
You must begin withholding no later than Ihe first pay perioe! occurring ten (10) working days afler the date of this
Order/Notice, Send payment within seven (7) working days of Ihe paydateJdate of withholding. You are entitled to
deduct a fee 10 defray Ihe cost of wilhholding. Refer to the laws governing the work state of your employee for Ihe
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee'sf obligor's
aggregate disposable weekly earnings. For the purpose of Ihe limitation on withholding, the following information is
needed (See #10 on pg. 2).
If remitting by EFT/EDI, please call Pennsylvania Stale Collections and Disbursement Unit (SCDUl Employer
Cuslomer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST tNCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
Date of Order: AUG - 9 200~
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7U
Form EN-028
Worker ID $IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o Ir ~hecked you ate re'lulr,.llo '''I>vlde a copy of 11* form 10 your em'lloy,'", If YOI" ,'mploY"l' works In ,\ slill" 11...1 Is
dUrcrenllrom the stIlle tllc1ll!lsu(,( Ihl!! onlN, il ropy rnu!il h(~ IJrovifh'( 10 your ('1111) OY('(~ (~\lI'n I( lIw ho'f( Is not r1wrkecl.
1. We .1Jlprccl.llc the voluntary cornpllilnce of FcdNallv reeognl/cd Indi.ll1 trihes, Irihillly-owl1pd husln(,ss(~!i, .111d Indlim-nwrH'c1
huslnesses lorllled on a rcscrv.ltlon thai choose 10 wllhhold in i1l"cordim[(~ with Ihls notlc('.
2, Prlorlly: Wilhholding under Ihls Onler/Notice has priorily owr iln\' olher leg,ll process IInd,'r Sl.lle Iilw ilg"insllhe silme income,
Fct.lcr.,1 ti'''' levies In elfcc' before receipt of this order Ihtvc luiority. If them Me Fl'clN.ll t.l'" levies In e(fCClll!l'asc contact the rcquc!iting
asency IIsl,,1 helow.
3, Combining Paymen..: You can combine wllhheld amounls rrom m",e Ihiln or1<' ('mployeelohllgor's Income In .1 single llolymenllo
each ilKcncy rCllucsling wilhholdlng. Vou must, however, wp.lr.tlcly Iclt'ntlfy the Imrtion of lhe single pilynwnt thiltl~ illtrihuti1hle to (!,ll"h
employee/ohllgor.
4. '-Reportinglhe'Paydnlt'lDale or Withholdin~:-You mu'lrcport Ihe l,ay""le/d"le or withholdin~ when ,ending Ihe paymenlc-The-
paydale/dale or withholdlng-i,'lhe dnle on which nmounl wa, wilhhe'" rmmlhe employ.....' wage" You musl com Illy with Ihe law or Ihe
slale or Ihe employee's/ohllgor's principal place or employmenl wllh reslll'cllo Ihe time periods wllhln which you musl hnplemenllhe
wllhholding onter and rorward Ihe support paymenls.
5.' Employee/Obligor with Multiple Support Holdings: Ir Ihem Is more Ihan one Onler/Notlce 10 Wllhhold Income (or Support agalnsl
Ihis employee/obligor and you are unahle 10 honor all support Onler/Notlces due 10 Feder,ll or Slale wilhholdlng limits. you musl rollow
Ihe law or Ihe slale or employee's/obllgor's principal place of employment. You musl honor all Orders/Notices 10 Ihe grealesl exlenl
possihle, (See #10 he low)
6. Termlnallon Nollficallon: You musl promptly nolify Ihe Requesling Agency when Ihe employee/obligor is no longer working ror you.
Please pmvide Ihe inrormatlon requesled and relurn a copy or Ihis Onler/Notlce 10 Ihe Agency identlned helow.
WITHHOLDER'S 10: 2330139130
EMPLOYEE'S/OBlIGOR'S NAME:
EMPLOYEE'S CASE IDENTIFIER:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
LIMRIC. ROBERT V.
4951100028 DATE OF SEPARATION:
7. Lump Sum Paymenls: You may be required 10 report and withhold rrom 111mI' sum paymenls such as honuses. commissions, or
severance pay. Iryou have any questions ahoullump sum paymenls. conlacllhe person or aulhority he low.
8, Liability: If you rail 10 wilhhold income ~s Ihe Order/Nolice direcls, you are liahle ror holh Ihe accumulaled amounl you should have
wilhheld rrom Ihe emllloyee/ohligor's income and olher pen allies sel by Pennsylvania Slale law. Pennsylvaniil Slale law governs unless
Ihe ohllgor is employed in anolher Slale. in which case Ihe law or Ihe Slille In which he or she is employed governs.
9. Antl-dlscrlmlnallon: You am subjecllo a nne delermined under Slale law for discharging an employee/obligor from employmenl.
refusing 10 employ, or laking disciplinary action againsl any employee/obligor hecause of a support withholding. Pennsylvania Slale law
governs unless Ihe ohligor Is employed in anolher Slale, in which case Ihe law of Ihe Slale In which he or she Is employed governs.
10.' Withholding Limits: You may nol withhold more Ihan Ihe lesser of: 1) Ihe amounls allowed hy Ihe Federal ConsumerCredil
Prolection ACI (15 U.S.c. ~ 1673 (b)l: or 2) Ihe amounls allow,,1 hy Ihe Slale or Ihe employee's/obllgor's principal place or employment.
The Federalllmil applies 10 Ihe aggregale disposahle weekly earnings (ADWE). ADWE is Ihe nel income lerl afler making mandalory
deductions such as: State, Federal, locallaxes; Social Security taxes; and Medicare taxes.
11. Additionallnro:
'NOTE: If you or your agent are served wilh a copy of this order in Ihe stale Ihal issued Ihe order. you are 10 follow Ihe
law of Ihe slale that issued lhis order with respect to Ihese items.
Submitted By: If you or your employee/obligor have any questions,
DOMESTIC RELATIONS SECTION con lac I WAGE ATTACHMENT UNIT
13 N. HANOVER ST by lelephone at (717) 240..6225 or
P.O. BOX 320 by FAX al (717) 240..6248 or
CARLISLE PA 17013 by inlernet www.childsupport.slate.pa.us
Pitge 2 of 2
Form EN-028
Worker ID $IATT
Service Type M
OMRNlI,:(J'llll-HI,.1
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: LIMRIC, ROBERT V,
PACSES ColSe Numh,'r 971100017
Pltllnllf( Nanl('
CONNIE L, LIMRIC
~ Allachmenl Amnunt
868 CIVIL 98 S 1,047.97
Chihllren)'s Name!s):
TANYA DANIELLE LIMRIC
JESSE RYAN LIMRIC
DOB
06/20/81
08/28/82
PArSES Cl~{, Num!Jpr
fWlnli(( Nitf1W
Docket Attilchnwnl Amount
S 0.00
Chlhllren)'s Name!s):
Olf checked, ynu are re<lulred to enroll the chlld(ren)
Idenlifil~1 above In any heallh Insurance cover.lge available
Ihrough the employee's/obllgor's employment.
Olf checked, you are required to enroll the chlld(ren)
Idenlified above In any heallh insurance coverage available
Ihrough the employee's/obligor's employment.
PACSES Case Number
Plalnlifl Name
Docket Allachmenl Amount
$ 0.00
Child(ren)'s Name!s):
PACSES Case Number
Plalnlill Name
Docket Allachment Amounl
S 0.00
Child!ren)'s Name!s):
DOB
DOB
o II checked, you are required to enroll the chlld(ren)
Idenlified above In any heallh Insurance coverage available
Ihrough the employee's/obligor's employment.
o II checked, you are required to enroll the child!ren)
idenlified above In any heallh insurance coverage available
through the employee's/obllgor's employment.
PACSES Case Number
Plalnlifl Name
PACSES Case Numher
Plainlilf Name
Docket Allachmenl Amount
S 0.00
Child(ren)'s Name(s):
Docket Allachmenl Amount
S 0.00
Child!ren)'s Name!s):
DOB
DOB
o If checked, you are required to enroll the child!ren)
idenlified above In any heallh insurance coverage available
through the employee's/obligor's employment.
o If checked, you are re<luired to enrolllhe chlld(ren)
idenlified above In any heallh insurance coverage available
through the employee's/obllgor's employmenl.
Service Type M
Addendum
Form EN-028
Worker ID $IATT
OMB No,: 1I'Jl001 S.&
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
Slate Commonwealth of Pennsvlvania
Co.lCily/Dlst, of CUMBERLAND
Date of Order/Notice 10/28/04
Tribunal/Case Number (See Addendum (or case summary)
o OrlKlnJI Order/Nolle!:!
o Allu'ndcd Order/Nollec
<9 Tcrmin.\le Order/Notice
Rl: LIMRIC,
ROBERT V.
[mployee/Obligor's N.mlC {lasl, first, Mil
196-52-0221
Employee/Obligor's SoclJI Security Number
4951100028
Employee/Obligor's Case Identifier
ISee Addendum for pl.lnllH n.me'
associalrd with rasps on altachmMtJ
CuSlodial Parent's Name (Last. First. MI)
EmploycrfWilhholder's Federal [IN Number
G. DAVID GELBAUGH
45 HILLDALE RD
ETTERS PA 17319-9651
.MI, -9(,$'-/999 ('ltIIt..
,tJ)/{!.5l.....<;. '7 7/1 ~ ~ 6/7
See Addendum (or dependent names and birth dates associated with cases on attachment.
ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee'sfobligor's income until further notice even if the Order/Notice is not
issued by your State,
$ 0.00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greaterl Oye5 <Xl no
$ 0.00 per month in medical support
$ 0.00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 0 . 00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle. use the following to determine how much to withhold:
$ 0 . 00 per weekly pay period.
$ 0.00 per biweekly pay period (every two weeks).
$ 0.00 per semimonthly pay period (twice a month).
$ 0.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydateldate of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee. cannot exceed 55% of the employee'sf obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following Information is
needed (See #10 on pg. 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCOU
Send check to: Pennsylvania SCOU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
Date of Order: O\;\ '2. \) 200~
Service Type M
OMO No.: UlJ71).{)IS'-
.:;;n.I, (:
Form EN-028
Worker ID $IATT
...
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If ~heckCjI you are required 10 prrvl\le a ropy of this form 10 your employee. If your employee works In ,1 slale that Is
dlf(crcnllrol111hc !llate t1hllls5UCf fills onler, it copy musl he provided 10 your employee even If Ille box Is nol checked.
I, We apprecl.lIe Ihe volunl.lIY compliance of Fed..",l1y recognized Indian Irihes, lrihally-own,,' huslnesses, .lIld In,II,ln.owned
businesses locilled on it rt'scrv,lllon thai c110nsc 10 wllhhold In accordance will, this nollcc.
2, Priority: Wilhholding under this Ord~r/Nollce h,15 priorily over any olher legalllrocess und.., Slale 1.lw agalnsllhe 50lme Income,
Federal lax levies In effect he fore recelpl of Ihls onler have prlorily. If Ihere ,,,e Feder,lll,lX levies in effect please contacllhe refluesllng
agency IIsled helow.
3, Combining Payments: You can combine withheld amounls from more than one employee/obligor's Income in ,1 single paymenllo
each agency refluesllng wilhholdlng. You musl, however, separalely Idenllfy the portion of the single paymenllhal Is ,ll1ribulahle 10 each
employee/obligor.
4. '-Reportlng-Ihe' Paydale/Dnle'of-Wilhholding:-You'mu!t~",port.the'llnYdnte/dnte o( withholding'when'!ending.thepnymentc-The-
pnydale/dnle o( wilhholdingl!.thednle on'which'nmoUnlwo!'wilhheld(rom.theemployee'!'wogl!!, You must comply wilh Ihe law o( Ihe
slale of the employee's!ohllgor's principal place o( employment wllh respeclto the lime periods wilhin which you must Implement the
wilhholdlng order and forward the support paymerlls.
S,' Employee/Obligor with Mulllple Support Holding,: If there is more Ihan one Order/Nollce to Wllhhold Income (or Support agalnsl
this employee/obligor and you are unable 10 honor all support Order/Nollces due to Federal or Stale wilhholdlng IImlls, you must (ollow
the law o( the slate o( employee's!obligor's principal place o( employment. You musl honor all Orders/Nollces 10 Ihe grealesl exlenl
possible. (See # 1 0 below)
6. Termination Notification: You must promplly noll(y Ihe Requesllng Agency when Ihe employee/obligor is no longer working (or you.
Please provide the Info011nllon requesled and relurn a copy of Ihls Order/Nollce to the Agency idenlified below.
WITHHOLDER'S 10: 2330139130
EMPLOYEE'S/OBLlGOR'S NAME:
EMPLOYEE'S CASE IDENTIFIER:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
LIMRIC, ROBERT V.
4951100028 DATE OF SEPARATION:
7. Lump Sum Paymenls: You may be required 10 report and wilhhold (rom lump sum paymenls such as bonuses, commissions, or
,everance pay, If you have any quesllons aboullump ,urn payment" conlact the person or aUlhorlly below.
8. Liability: I( you (nil 10 wllhhold income a, Ihe Order/Nollce directs, you are liable (or bolh Ihe accumulaled amount you ,hould have
withheld (rom the employee/obligor', Income and olher penaille, set by Pennsylvania Slale law. Pennsylvania Stale law governs unless
the obligor i, employed in anolher Stale, In which case Ihe law o( Ihe Slale in which he or she is employed governs.
9. Antl-dlscrlmlnallon: You are subject to a fine delermined under Slale law (or discharging an employee/obligor from employmenl,
re(uslng to employ, or taking diSciplinary acllon againsl any employee/obligor because o( a ,upport wllhholding. Pennsylvania State law
govern, unless the obligor i, employed in another Slale, in which case the law o( the Stale in which he or she is employed governs.
10.' Withholding Limits: You may nol wilhhold more than Ihe lesser of: 1) Ihe amounls allowed by Ihe Federal Consumer Credit
Prolecllon ACI (1 S U.S.c. ~ 1673 (b)]; or 2) the amounl' allowed by the Slate o( the employee's!obligor's principal place o( employmenl.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: Stale, Federal, local taxes; Social Security taxes; and Medicare taxes.
11. Addilionallnfo:
'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow Ihe
law of the stale that issued this order wilh respect to these items.
Submitted By: If you or your employee/obligor have any questions,
DOMESTIC RELATIONS SECTION contacl WAGE ATTACHMENT UNIT
13 N. HANOVER ST by telephone at (717) 240-622S or
P.O. BOX 320 by FAX at (7171 240-6248 or
CARLISLE PA 17013 by internet www.childsupport.slate.pa.us
Service Type M
Pilge 2 o( 2
Form EN-028
Worker ID $IATT
OM!J Nu,: 1l'Jl{}.OlS4
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ORDER/NOTICE TO WITHHOlD INCOME FOR SUPPORT
Stale Commonwealth of Pennsvlvanla
Co.lCitylDiM. or CllMBERLAND
O.lh'ofOrdt'r/NoUn' 00/04/06
c.",! Numbm fSee Addendum (or mse sumnr.1ry)
971100017
98.-868 CIVIL
o Orlnln.lI Oflll'r/Nnlin'
@ ""lI'l1lll'd Olc!c',/Nnlkc
o h'lmln.lh' Olllc',/Nlllicc
Iltlll!UYt',^Vilhhohh','" rl'c!t'f,lIIIN NurnlH',
RI: LIMRIC , ROBERT V.
111l1lInyc'('/Ohliglll's N.lI11C' II ,1St. first. MI)
196-52-0221
Lrnplcl}'c!('/Ohligm's SOci.ll St~rurily Number
4951100028
Irnpl()YI'(1/()hlil~nr''j c'lse' Identifier
IS.. Addrndum fo, pldlnlllf ndm.,
dUOe/Jlltd wllh Cd5l"S on dltdchmrntJ
Cmlndi.ll P.uenl's N.lrnl! 11.;ISI.1 I,..t. Mil
MOLD BASE INDllSTRIES INC
7450 DF.RRY ST
HARRISBURG PA 17111-5220
See Addendum (or dependent names and birth dates associated with cases on attachment,
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND Counly, Commonwealth of Pennsylvania. By law, you me required to deduct these
amounls from the above-named employee'slobligor's income unlil further notice even if Ihe Order/Notice is not
issued by your State.
$ 862.25 per month in current support
$ 0.00 per month in pasl-due support Arre,,,s 12 weeks or greater? 0 yes <ID no
$ 0.00 per monlh in current and past-due medical support
$ 0.00 per month for genelic test costs
$ per month in other (specify)
for a lolal of $ 862.25 per monlh 10 be forwarded 10 payee below.
You do not have to vary your pay cycle to be in compliance with Ihe support order, If your pay cycle does not match
Ihe ordered support payment cycle, use the following to determine how much to withhold:
$ 190.90 per weekly pay period.
$ 397 . 96 per biweekly pay period (every Iwo weeks).
$ 431.13 per semimonthly pay period (twice a month).
$ 062.25 per monthly pay period.
REMITTANCE INFORMA T/ON:
You must begin withholding no later than the first pay period occurring ten (10) working days after Ihe date of Ihi5
Order/Notice. Send payment wilhin seven (7) working days of Ihe paydate/date of wilhholding. You ,1(1' entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for Ihe
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's! obligor's
aggregate disposable weekly earnings. For the purpose of the Iimilation on wilhholding, the following information is
needed (See #9 on page 2).
If remilling hy EFl/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER IV (shown
above as the Employee/Obligor's Case Identi(ier) OR SOCIAL SECURITY NUMBER (N ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
!l v 0' ?
DRO: R.J. Shadday
Service Type M
Date of Order:
200(.
Judge
Form EN-028
Worker 10 $IATT
(1\\B Nu.; lI'llll-HIS
.,
ADDITIONAL INFORMATION TO EMPLOYERS ANI) OTHER WITHHOLDERS
o If /o!wrkt'tl you iUl' rl'qulrt'd 10 prl)~'lh' ,11'opV of Ihls form to your l'Ill/JloYPI'. If YOllr ('mllloy!'", works in " 51.1Il' Ilhllls
ell hlH1nllforn tll(l 'lllh~ 11"'11"\111'1 1115 Oft I~r..l ropy I11US' hi! provldt.( 10 your ('1111) OYI't' (lVI'Il If 111(1 !lox I, nol r1W[kl'd.
t. Priority: Withholding lIIull'r this Onll'r/NlIlin! hilS priority ov(!r 11l1Y ollwr I('HIII prO( (lSS llmlt'r Sl.lh' Ill\\' .tJ;.linsllhe Slum! lllfnnw.
Ft-.IN.lIl.lx levills In (1 {((If I IIllfCH(' ft'f(lipl of Ihis onl(lr IMVI' priority. If Ilwn' iH!! Fl.dl'rllllilX I('vlps In ('(fl,rt pllWiP ronl,U:lllw rt'(lu('slinR
i'Ht'llCY Ii,tpd hplow.
2. CnmblnlnK P.lymenls: Vou rim comhlr1l' wllhhehl.llllounls from more th,Ul orw (II11Jlloyp(l/ohligm's Inrol1w In .1 "lnHlp p.'ynll'nt to
l.'lteh ilgem:y f(lqUt'!'III1H wilhholdhlA. You mu!'l, hOWeVI!r, !,pIMr,tlt!ly ilh1Jllify Ihl1 portion of till' !'hlAlelJ.1YI1l('nt Ihilll!' ,1IIrihul,lhlp 10 l1tlCh
crnllloy(~e/ollliHor .
./
3.' R~porting th~ Paydat~/Dat~ of Withhnhling: You mu'tll'port th,' paydal~/dal~ of withholding wh~n '~nding th~ paym~nt. - Th~
Ililydilte/diltr of withhold in,; is the dilll' on whirh ilmOllnl WitS wilhhr.ld from Ihr. ('mploy('("s WilgC5; You nHl!'1 comply with IIw Ielw of the
stall! of Ihe ('rnployc("s!ohliHor'!, prinriIJilII)',ICC of (!I11I)loynwnl with respect 10 11ll' linll' periods within whirh you must implement the
withholding order i1lHI fnrw,Hd lilt' support p.lyrnenl!!.
4.' Employ~"/Obllgor witb Mollipl. Suppnrl HnldinK" t( th~r~ is mnll' than on~ Order/Nnllce to Wilhhnld Incume for Support against
this cmploycl'!ohlinor .mil you ,UI' U1Mhle to honor all support Order/Notices due 10 Federlll or Slale withholding limits, you must follow
Ihe '11w of Ihe slllle of ernploycc'slohligor's IJrlncipl11 plilCe of employment You must honor ,111 Orders/Nolices to Ihe greatest ex lent
Ilossihle. (See #9 t)(~lo\V)
5. Terminatinn Nolllicallon: You must promptly noll(y the Requesllng Agency when the employee/obligor is no Innger working for you.
Please IJrovide Ihl! infornMlion re1luesled imd return a COllY of this Order/Nolice 10 the Agency identified he low.
THE EMPLOYEE/OBLIGOR NO LONGER WORKS fOR: 2319428350
EMPLOYEE'S/OBLlGOR'S NAME: LIMRIC. ROBERT V,
EMPLOYEE'S CASE IDENTifiER: 495110002B DATE Of SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any Iluestions i.lhout lump sum paymenls, conlacl the person or aulhority below.
7. Liability: If you (ail to withhold income as the Orrler/Nolice directs, you arc liable for both the accumulaled amollnt you should have
withheld from the employel1/obligor's income and olher penalties sel by Pennsylvania Slille law. Pennsylv.mia Slate law governs unless
the obligor is employed in anolher Slate, in which case Ihe law of the Stale in which he or she is en11110yed governs.
.'\
,
I
B. Anli-discriminalion: You are subject 10 a (ine delermined under Stal~ law (or discharging an employee/ohligor from employment,
refusing 10 employ, or taking disciplinary action agilinst any employee/ohligor because of a support withholding. Pennsylvania Slale law
governs unless the obligor is employed in ,motlwr Slate, in which case the Illw of the Stale In which he or she is emllloyed governs.
9.' Withholding Limits: You may not wilhhold more Ihan the lesser of: 1) the amounls allowed by Ihe Feder,ll Consumer Credit
Prolection Acl (15 U.s.c. ~1673 (u)l; or 2) Ihe amounts allowed by Ihe 51ale of Ihe employee'slobligor's principal place of employment.
The Federal limit applies to Ihe aggregale disposable weekly earnings IADWE). ADWE is the net income lefl after making mandalory
deductions such as: Stale, Federal, local taxes; Social Securily laxes: and Medicare taxcs. For Iribal orders, you may not withhold more
Ihan thc ilmounls allowed under the law of the issuing tribe. For Iribal employers who receive a slale order, you nMY not withhold more
Ihan the amounls allowed under the law of the slate thai issued the order.
10. Addilionallnfn:
,
\~
.,
'NOTE: If you or your agent are served with a copy of Ihis order in the state thai issued the order, you are to follow the
law of Ihe state Ihat issued this order with respect to these items.
[
11. Submitted By:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717) 240-6248 or
by internel www.childsupport.stilte.pa.us
Pilge 2 of 2
Form EN-028
Worker ID $IATT
,
,
Service Type M
CIMI1 NlI,; U'I/IHll'i4
,
ADDENDUM
Summary 01 Cases on AlIachmenl
Defendanl/Ohllgor: LIMRIC. RODERT V.
PArSES CISP NUI11IJt1r 971100017
P',lInllffN,lIIH'
CONNIE L. LIMRIC
Dorkl'1 AII.lfl1l11f1nl AnlfHlul
868 CIVIL 98 S 862.25
Childlrcn)'s N,lInel'):
TANYA DANIELLE LIMRIC
JESSE RYAN LIMRIC
P,ACSfS CilS(l NlIl1Ihl'f
PI.llnlirfN,1II1(l
Dorktll AllilrlU1wl1f Amount
S 0.00
Childl,en)', N.",,,,I,):
DOll
06/20/81
08/28/82
DOB
Oil checked, you a,e ,e'luirl.llo e",olllt", childl,en)
identified ilhove In any hCilllh insuriUlcc covcr.lge av.lil.lhlc
through the CIl1I)I()yc(~'!Jobligor's employment.
o If checked, you .1m required to enroll the childlum)
identified "bovc in ,my 11<.';ll1h insur,1I1cc COVl!r,lgc ilV,li1l1blc
through lhe cmployec's/ohligor's employment.
PACSES Cas,' Numhe,
PI"ln1iffNa",e
PACSES c,,,,, Numhrr
PI.linlif( N.lnlP.
Docket Altarhrnpnl Amount
So.oo
Child(,,,,,)'s Namel,):
Dorkpl AtlilchnlC'nt Amount
So.oo
Chlld(,en)'s Namels):
DOB
DOB
o If checked, you a'e ,e'lui,ed 10 enrolllhe chlldl,en)
identified above in any health insurance coverilge iwaHable
through the employee's!obligor's employ men!.
o II checked, you a,e ,e'lui,ed 10 e",olllhe chifd(renl
identified ahove in any heillth inSUrilnCe coverage available
Ihrough Ihe employee's!obligor's employmen!.
pACSES Case Number
Plaintiff Nam(l
PACSES Case Numher
Plollnliff Nolm"
Dorket All,lrhment Amount
So.OO
Childl'en)'s Name(s):
Dorket Atlachmronl Amount
S 0.00
Child(,en)'s Namels);
DOB
DOB
o If checked, you a,e ,e'lui,ed 10 e",olllhe chifdl,en)
idenlified above in imy heallh insuranre cover.lge ilvili1ilhle
through the emllloyee's/obligor's employment
o If checked, you a,e ,e'lul,ed 10 e",olllt", chlld(,en)
identified above in any health insurance coverage ilvililable
lhrough Ihe employee's!obligor's employmenl.
Service Type M
Addendum
Form EN-028
Worker ID $IATT
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