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HomeMy WebLinkAbout98-01395 ~; ~' --.. " lot .'" - \J '-.9:. 1! '? '> ~ \l iii iii - tJ c..9 1. r<' ~': "--'0 I ~.'. r-...'i .'. '" .,' - -;. ') .~:^ (:'l 'i. v\. 07,: ('(') - 'f, : .: <>0 6'i1 ':d. , .;. Ii, WHEREAS, there are two children born of the marriage, all of whom arc emancipated. WHEREAS, diverse unhappy marital difficulties have arisen between the parties causing them to believe that their marriage is irretrievably broken, as a result of which they have separated and now live separate and apart from one another, the parties being estranged due to such marital difficulties with no reasonable expectation of reconciliation; and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including without limitation by specification: the settling of all matters between them relating to the ownership of real and personal property; and the settling of all matters relating to the custody and support oftheir minor children, and in general, the settling of any and all claims and possible claims by one against the other or against their respective estate, particularly those responsibilities and rights growing out of the marriage relationship, NOW THEREFORE, in consideration of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, the receipt of which is hereby acknowledged by each of the parties hereto, husband and -2- wife, each intending to be legally bound, hereby covenant and agree as follows: I. SEPARATION. It shall be lawful for each party, at all times hereafter, to live separate and apart from the other, at such place or places as he or she may, from time to time, choose or deem fit. Each party shall be free from interference, authority or contact by the other, as fully as ifhe or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall mQlest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other, Should a Decree, Judgment, or Order of separation or divorce be obtained by either of the parties in this or any other state, country or jurisdiction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be affected in any way by any such separation or divorce; and that nothing in any such Decree, Judgment, Order or further modification or revision thereof shall alter, amend or vary any term of this Agreement, whether or not either or both of the parties -3- shall remarry, it being understood by and between the parties hereto, that this Agreement shall survive and shall not be merged into any Decree, Judgment, or Order of divorce or separation. It is specifically agrced howcvcr, that a copy of this Agreement or the substance of the provisions thereof, may be incorporated by reference into any Order of divorce, Judgment, or Decree. This incorporation, however, shall not be regarded as a merger, it being the specific intent of the parties to permit this Agreement to survive any Judgment and be forever binding and conclusive upon the parties. 2. EFFECTIVE DATE. The effective date of this Agreement shall be the "date of execution" or "execution date", defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, 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. 3, MUTUAL RELEASES. Husband and wife do hereby mutually remise, release, quit-claim or -4- forever discharge the other and estate of such other, for all time to come, and for all purposes whatsoever, from any and all rights, title and interest, or claims in or against the estate of such other, or whatever nature and wherever situate, which he or she now has or at any time hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements, or liabilities of such other or by way of dower or curtesy, of claims in the nature of dower or curtesy, or widow's or widower's rights, family exemption or similar allowance or under the intestate laws; or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary or all other rights or a surviving spouse to participate in a deceased spouse's estate, whether arising under the United States, or any other country; or any rights which either party may now have or at any time hereafter have for the past, present, or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. -5- It is the intention of husband and wife to give to each other, by the execution of this Agreement, a full, complete and general release with respect to any and all property of any kind or nature, real, personal, or mixed, which the other now owns or may hereafter acquire, except, and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. 4. DISTRIBUTION DATE. The transfer of property, funds and/or documents provided for herein shall only take place on the "distribution date" which shall be defined as the date of execution of the Divorce Decree, unless otherwise specified herein, 5, MUTUAL CONSENT/ADVICE OF COUNSEL.... Husband and wife acknowledge and understand the tenns and conditions of this Agreement, and wife is represented by Diane M. Rupich, Esquire, and Husband is represented by Herschel Lock, Esquire, Husband and wife acknowledge that they fully understand the facts as to their legal rights and obligations under this Agreement. Husband and wife acknowledge -6- otherwise set forth herein. Husband agrees to be solely responsible for debts and obligations outstanding as of the date of separation, including, but not limited to: the first mortgage, second mortgage and home equity loan on the real estate located at 2 I N. Humer Street, Enol a, Pennsylvania, the person loan owed to Alfreda Geissler, the loan on an insurance policy in the approximate amount of$II,OOO.OO, and the mortgages owed on the real estate located at 226 W. Shady Lane and 99 E. Perry Street, said debts are more fully set forth herein under Real Estate. Both parties hereby holds the other hannless and indemnities the other in connection with the above debts and assume full responsibility for the payment as set forth herein, 8, REAL EST ATE.... Husband and wife hereby acknowledge that they are the joint owners of the real estate as follows: 142 Cumberland Road, 226 W. Shady Lane, 209 Enola Road, 113 E. Cumberland Road, 326 Pitt Street, 24 Cassatt Street, 99 E. Perry Street, and 21 N, Humer Street, all located in Enola, Cumberland County, Pennsylvania. Husband and -9- Husband hereby agrees that he shall be solely responsible for the mortgage, utilities, taxes, and any and all other debt and liability of all real estate until the completion of the refinancing, and hereby indemnifies and holds wife hannless from the above obligation upon all real estate. Husband and Wife hereby agree that all real estate which is currently owned free and clear shall be transferred into their respective names upon the execution of this Agreement, and that all real estate which is currently encumbered, shall be transferred at the time of the refinancing by husband, thereby relieving wife of all obligations and debts owed on said real estate. Husband shall pay to wife the sum of $4,500.00 at the time of refinancing (within 60 days hereof). 9. PERSONAL PROPERTY. Except as set forth hereto, husband and wife have agreed that their personal property has been divided to the parties' mutual satisfaction and neither party will make any claims to the property possessed by the other, except as set forth hereto: NONE. The parties hereto acknowledge that Husband shall retain all antique automobiles and parts, and wife hereby waives all of her right, title and interest in said automobiles. Wife shall retain her life insurance policy. Husband and Wife further agree that they shall share, one-halfeach, the income -11- at any time hereafter have for past, present, or future spousal support, or maintenance, alimony, alimony pendente lite, spousal support, equitable distribution of marital property, attorneys fees, costs or expenses, whether arising as a result of the marital relation or otherwise. It is the intention ofthc husband and wifb to give to each other by the execution of this Agreement, a full, complete, and general release with respect to any and all property of any kind or nature, real, personal, or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. 13. ALIMONY PENDENTE LITE AND COUNSEL FEES Wife hereby agrees that upon receipt of a Decree in Divorce, that she will immediately notifY the Domestic Relations Office of Cumberland County to terminate the Order for alimony pendente lite docketed to No. 98- 139, Pasces No. 704100040. Husband hereby agrees that he shall pay the sum of One Thousllnd and no/I 00 ($1,000,00) Dollars to wife's attorney, Diane M. Rupich, Esquire, upon entry of the Decree in Divorce, -14- .~. COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN ~ 0' On this, th~1-- day of "'11v1!> ' 1999, before me, a Notary Public, the undersigned officer, personally appeared CAROL A. GEISSLER, known to me or satisfactorily proven to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. l"~;.~,~:~:.~}r.'~'::'::~~, rob"_ My Commission E i~es~."." . ':.' 5\::~,.: ~~~? ........~- COMMONWEALTH OF PENNSYL VANIA COUNTY OF DAUPHIN On this, the 5A--l day of j11 d.f- ,1999, before me, a Notary Public, the undersigned officer, personally appeared GEORGE H, GEISSLER, known to me or satisfactorily proven to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. My commission expires: 5"j,?.;z./ff' (;/}??o.A.C hJ'-&t:' ~d.. / . Notary Public ( , -18- .. -" ...,.....---.---- /lor"., - CONI-lIE L F"'/IN ../,l ~r~l I1Q'r#tbu EsrOQ-. IIIofQ hi. Co '0, Ooophin c '>' "0"'" ' rnrnl~ f Q~. ",. on .plr., M -"'T. .., OY 22. '!'Pp .' , ~ ,~ CJ ....0:> 0 C U> -n ~_:h .... .-J -" ~:U I );..'" :'-""1] fllfll -...: -,'j1;::: -,"-" __,rn ;?C. - ."cr (J' -~ .-J (j{ ) ;.;-t, ~~C7 ,..j -r' '"{J ~t~ .,1 ,:::C) ::!.': '~,~() ti:() 4~rn - ...-1 ;'.c: .. :;; ;3 :,) ?? .- - -. .." -. (") 1..0 0 c: 1..0 on -~ :r: -I ":," " "Om :;::.-. ~'11--n [!'lIT -< .1 f- ;?; -j -"If'n _.1 :>'lj:- -,,)~ ~- , '-J (2,6 ~;-:: GC,; -u -f- .',. ;--~ :n '""C' :1:: "'0 '7 > 6rl1 '-c :i>c" -, 0 :...> ;t" ~ .r. ~ GEORGE II. GEISSLER, IN 'rHE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. YEAR 1998'. /315 iuJ~ CAROL A. GEISSLER, Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary of Cumberland County, 1st Floor, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHTS TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYERS AT ONCE. IF YOU DO NOT HAVE A LAWYER OR COUNSEL OR CANNOT AFFORD ONE, GO TO OR TELEHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Bar Association 2 Liberty Avenue Carlisle, pennsylvania l7013 Telephone No. 7l7-249-3166 Court to enter a Decree in Divorce, divorcing the Plaintiff and Defendant. COUNT II - DIVORCE 9. Paragraphs 1 through 8 inclusive of this Complaint, are incorporated by reference and made a part hereof. 10. The Plaintiff avers, in the alternative, that the marriage is irretrievably broken; and that he is entitled to a divorce under the provisions of 53301(c) of the Divorce Code. 11. The Plaintiff has been advised, that counsel- ing is available and that he may have the right to request the Court to requuire the parties to participage in counseling. 12. The Plaintiff requests the Court to enter a Decere in Divorce. WHEREFORE, the Plaintiff requsts your Honorable Court to enter a Decree in Divorce in the alternative, divorcing the Plaintiff and Defendant. COUNT III - EQUITABLE DISTRIBUTION 13. Paragraphs 1 through 12 of this Complaint, are incorporated by reference and made a part hereof. 14. The Plaintiff and Defendant have acquired real and personal property during the time of their marriage. 15. That the Plaintiff and Defendant have been - 3 - .. ~ ...... 0 ..0 0 c;; o.D -n :.r- ,.., <-. ~~'1f9 ~r~l ~ rnt':1 -~ '11 - .-:"rn ~... '~J9, 7.1." ,-l (}"' . C.J,) 2~::' ,::l~.. ...\:.; -0 .I.-n ,_) ~.4 ~*::Cl ::J~ ,.0 ...:....rn ?-:'Cl - '=". >r.: .,... Z ,.oJ ~ ::l - -.. .. I I I GEORGE H. GEISSLER, PlaintifT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA VS. No. 1395 CIVIL TERM CIVIL ACTION. LAW IN DIVORCE CAROL A. GEISSLER Defendant I. A Complaint in Divorce Under Section 330l( ) of the Divorce Code was filed on MARCH 13, 1998 . 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a fmal Decree in Divorce, 4. I understand that I may lose rights concerning alimony, division of property, lawyers's fees or expenses if I do not claim them before a divorce is granted. 5, I have been advised of the availability of marriage cowlseling, and being so advised, I do not request that the Court require my spouse and myself to Participate in marriage counseling. I veritY that the statements made in this Affidavit are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated, MAY 3. 1999 ~~~ ,\, <.I ,c- o c.::. ,0 ~r\ -..... :r:. :.'~.\ ~i.J\ .-. ,:' :!J ~ , ' .1("" rnp' _. " -,T')) - .....r1"\ ~.(~"~ ...l ..,.jc-( " U1"., ,.~.?\tJ '.... "2;" ",\,..":j ~" '-1::.';\ '.. ";j:' '~J~' ?;(J 1~"Io( ) - t5f" .pC:, " -\ -/ '.,) ~. :2. .1'" .... ."' II. ISSUE INVOLVED: Under the applicable case law, statutory law, and Rule of Civil Procedure ~1033, should the amendment be granted without any preconditions? III. REFERENCE TO LEGAL AUTHORITY: The law is clear, that the intent is to be liberal in the amendment of pleadings. As set forth in Franqie v. Solomon, 7 D&C 2d, 394, that where the wrong form of action has been filed, leave should be granted to make an amendment at any stage of the proceedings. The requested amendment is under date of March 20, 1998, approximately a week after filing Complaint, so there is absolutely no question, as to the timeliness of filing the said Motion. There is no unfair surprise or comparable pre- jUdice from the requested amendment. As noted in the Superior Court Case of pilotti v. Mobile Oil Corporation, 565 A. 2nd 1227 (1989), at page 1229, that oue Supreme Court has held, that the policy in this Common- wealth, is to allow an amendment where there is a reasonable possibility that an amendment can be accomplished successfully. The attempt by the Defendant to condition the amendment on the payment of counsel fees and costs by the Plaintiff, for which there is no support in our research under the case law for such - 2 - II. ISSUE INVOLVED: Under the applicable case law, statutory law, and Rule of civil Procedure ~1033, should the amendment be granted without any preconditions? III. REFERENCE TO LEGAL AUTHORITY: The law is clear, that the intent is to be liberal in the amendment of pleadings. As set forth in Frangie v. Solomon, 7 D&C 2d, 394, that where the wrong form of action has been filed, leave should be granted to make an amendment at any stage of the proceedings. The requested amendment is under date of March 20, 1998, approximately a week after filing Complaint, so there is absolutely no question, as to the timeliness of filing the said Motion. There is no unfair surprise or comparable pre- judice from the requested amendment. As noted in the Superior Court Case of pilotti v. Mobile Oil Corporation, 565 A. 2nd 1227 (1989), at page 1229, that our Supreme Court has held, that the policy in this Common- wealth, is to allow an amendment where there is a reasonable possibili ty that an amendment can be accomplished successfully. The attempt by the Defendant to condition the amendment on the payment of counsel fees and costs by the Plaintiff, for which there is no support in our research under the case law for such - 2 - ~. II. ISSUE INVOLVED: Under the applicable case law, statutory law, and Rule of Civil Procedure ~l033, should the amendment be granted without any preconditions? III. REFERENCE TO LEGAL AUTHORITY: The law is clear, that the intent is to be liberal in the amendment of pleadings. As set forth in Frangie v. Solomon, 7 D&C 2d, 394, that where the wrong form of action has been filed, leave should be granted to make an amendment at any stage of the proceedings. The requested amendment is under date of March 20, 1998, approximately a week after filing Complaint, so there is absolutely no question, as to the timeliness of filing the said Motion. There is no unfair surprise or comparable pre- judice from the requested amendment. As noted in the Superior Court Case of pilotti v. Mobile Oil Corporation, 565 A. 2nd l227 (l989), at page l229, that our Supreme Court has held, that the policy in this Common- wealth, is to allow an amendment where there is a reasonable possibility that an amendment can be accomplished successfully. The attempt by the Defendant to condition the amendment on the payment of counsel fees and costs by the plaintiff, for which there is no support in our research under the case law for such - 2 - , , , . ~ C) .0 0 b 5; c:o "'-1 :~ :To ~:o ::!in:: ,.. D)r'lf ;:::> rn r-- t. ..":. ",,1.:1 N .,,~ Zr. .c- 'o:J C,~c-~~ O( --- .- J::a r-~i,::,: -0 ~ :z: 0 r.:..C) -'p troR w an J> .: .. 15 ::j ~. ..... 0 -< .". 14, Paragraph fourteen (14) is admitted. 15. Paragraph fifteen (15) is admitted. WHEREFORE, Defendant prays your Honorable Court to enter a Decree in Divorce and order equitable distribution of all marital property. COUNTERCLAIM CLAIM FOR ALIMONY PENDENTE LITE AND ALIMONY 16. Carol A. Geissler avers that she does not have sufficient funds in which to support ,I \ i \, I herself and the minor child born ofthe marriage, 17, Carol A. Geissler has been a housewife for over twenty (20) years, and does not have employable skills. 'I '0 , 18. Carol A. Geissler is currently working; however, her earning capacity is such that -4- she is need of financial assistance from George H. Geissler in thc form of alimony pendentc litc and alimony. 19, George H, Geissler does have substantial funds and the ability to pay alimony pendente lite and alimony to his wife. WHEREFORE, Carol A. Geissler, Defendant, prays your Honorable Court to Order her husband, George H. Geissler, to pay her alimony pendente lite and alimony, CLAIM "'OR COUNSEL FEE. COSTS AND EXPENSES 20. Carol A. Geissler docs not have sufficient funds to defend the divorce action filed by her husband. 21, The parties have substantial real estate holdings, and it is averred that said real ., 'I -5- r, ll.i., ---~ CJ lO 0 c:: ~ 'II . "" :;-J ' , "'0,:1.' -ry '-fl:!] rn,.;-: ;:':1 %::r- ,-- I .~'T1 ~;~ ~.:. c, -C'e;:' ", ,~ . ;.J,_, ~J~) .;:J - ::q . -II ;.'5:0 :-.(') ;:;~? ~ Hm -=. ..,.. ~ i'fj ~ rv -< Ii " ( I ( ( 1 I . ASSETS OF THE PARTIES List of items applicable to the case at bar and item- ization of the assets on the following pages. ( X) l. Real Property ( X) 2. Motor vehicles () 3. Stocks, bonds, securities and options ( X) 4. Certificates of deposit ( X) 5. Checking accounts, cash () 6. Savings accounts, money market and savings certificates () 7. Contents of safe deposit boxes () 8. Trusts ( X) 9. Life insurance polices (indicate face value, cash surrender value and current beneficiaries) ) 10. Annuities ) ll. Gifts ) 12. Inheritances ) l3. Patents, copyrights, inventions, royalties X) 14. Personal property outside the home X) l5. Business (list all owners, including percentage of ownership, and officer/director positions held by a party with company) l6. Employment termination benefits - severance pay, worker's compensation claim/award ) l7. Profit sharing plans X) l8. Pension plans (indicate employee contribution and date plan vests) ) 19. Retirement plans, Individual Retirement Accounts ) 20. Disability payments ) 2l. Litigation claims (matured and unmatured) ) 22. Military/V.A. benefits ) 23. Education benefits ) 24. Debts due, including loans mortgages held X) 25. Household furnishings and personalty (including a total category and attach itemized list if distribution of such assets is in dispute) X) 26. other MARITAL HOUSEHOLD FURNISHINGS IIND PERSONALTY Master bedroom: Smnll oak dresser Small oak dresser 2 night stands Cedar Chest Guest room: 2 single bed frames 1 small table 1 Wall mount sewing cabinet Upstairs and Downstairs Hall: 2 Small decorative benches 1 Church bench 1 sewing cabinet 2 wall tapestries Dining room: 1 wall corner cabinet 1 Rocking horse 1 wine rack 1 handmade tray 1 plant stand Living room: 1 oak coffee table 2 oak end tables 1 oak bookcase 1 2-drawer oak dl 'sser 1 oak library tat_e Couch - loveseat - recliner (7 1 TV - stero - VCR - CD Player Several pictures - small shelf home interior decorations 1 Mahogany stand 1 stand Kitchen: Antique oak cabinet Antique oak table 4 oak chairs 1 Antique milk can 1 refrigerator ( 8 yrs. old) 1 stove (8 yrs. old) 2 wood stools 2 metal stools Misc. : 1 hall tree Linens Set of White dishes Set of tableware 1 upright freezer (15 yrs. old) $ 75.00 $ lOO.OO $ 30.00 $ 75.00 $ 25.00 $ l5.00 $ l25.00 $ 30.00 $ 80.00 $ 25.00 $ 50.00 $ 50.00 $ 200.00 $ 40.00 $ 30.00 $ 25.00 $ lOO.OO $ 300.00 $ l75.00 $ 75.00 $ l60.00 yrs. old) $ 200.00 unit $ 500.00 units $ l50.00 $ 40.00 $ 30.00 $1,500.00 $ l50.00 $ 300.00 $ 30.00 $ 300.00 $ 250.00 $ 25.00 $ 20.00 $ 35.00 $ 400.00 $ 200.00 $ 50.00 $ l50.00 EXHIBIT "A" ,k ~( ~,(P7 r/n ~~ ~-nV_ .._____..._ __..... ..u..._ U J~ /. ~h ~ ~1tt..iiJ.R.., a1t'/rU.~ ~ ) . /3. PV ~(. ~ . #~ ~/t!/r-.b Ik t!tup~. u. 10 'J" ~'(4.; (!41V J7.,.I(; f . , 01. ;)4~_~~.~{r;...v)~Am.J, ~_.. jJ.dV cUMb, .~. ~_..L-u~jl/MI-';. ,.. J. ~~~~~~;~~,#. 'J;~ f, ~f~ ~: ~ tUU~1' /~~Q4" ./(1. v-o , ~ I ~ ~ ~4v ~(I:;'X3.J). :t: S. ~~~",ta~1~~~~1 . /2,eIO ~dah~'1'~~~ ~ ~~. . /,(" Kif".. .._ . _".'. . t., tJ4tu~.~ ;~,. ~,.jUU4, ~ 13,t/O .I6f'l~. .. . . . . 1. ~1~: ~~ ~citv4P~jJUdI f,;'t) ~~ j ~(h.~./u.v A.Jrrm ILf/le) .,. t' P ~~'~~, ~,/J1Wdu.~/3'~ I UtI." ~ /01..J<t,g', a~~v~ "~~/~c(~'" !!:l/!1!fJpJ-"-v;-/~. .,bdlAr' Fl. )< ,;J. 'I' . . /~ (fJl;1!;~~;~~/' e4J..tO ~.. ---. . (Ii) EXHIBIT "B" IJ. ~ f'tWv ~~tuualA(~ $:(/i) ~/ ~~~ .kv{~j \.?/(kJ /~ fJ4(udu4 (~J~/4.,(f~ 07S-,o/V If ~~~~~ /.j,vr) ~/- ~~ 4:.. ... .. . ~/t.AJ ~j: J.d,. Wtte/u.- -~ lAJr1A 0;!4;;~ 1/. ro ~ ~ #,},., , /9,ctV r!)t( /1' . ,'" .h7' ,ClIddtdw'"w M /d.diJ ~~-, ' , '. (., c() ~M~a;:t~~~ ,,' /;,rJi), J2t. os,?, /~ tJ.1{4t/kJ/ ~ Ctit~~u, r:!2/. 1'0 4.~,ri~~:t~. ' c.}l/ttHJ. . ,~~~, ~ IZ,flO c2r - ~v~ ~tuw.. .f)7. d7J cflq tJuItu,~~,_~.r,_ ' .', ,/:17), 9J ~ ~ ~..,vM" ,0#11. //ltlV__. aN! e/'~ .... ' ..", ,,3/, tJJ~rJCd~ -f~~ 1,{f() ..' J;l-,'tkvp:::;fJ:::~ ~ II, Or) '~ - GEORGE H. GEISSLER, Plaintiff IN THE COURT OF COMMON PLEAS OF VS. CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CAROL A. GEISSLER, Defendant NO. Ol395 YEAR 1998 IN DIVORCE INCOME AND EXPENSE STATEMENT OF GEORGE H. GEISSLER, PLAINTIFF INCOME Employer: Cumberland Perry AVTS. Address: llO Old Willow Mill Road Mechanicsburg, Pa. 17055 Type of Work: Teacher Payroll Number: Pay Period: Bi-weekly Gross Pay per Pay Period Iemized deductions: Federal Withholding Social Security Local Wage Tax State Income Tax Retirement Savings Bonds Credit Union Life Insurance Health Insurance Other: Union Dues $ 1,632.40 $ 131. 22 $ l24.l9 $ 16.23 $ 45.46 $ 85.23 $ $ $ $ $ 45.90 $l,175.l7 Net Pay per Pay period (Bi-weekly): 26 weeks Bi-Weekly = Annual pay...................$30,554,42 i. ,/ ','1' , , : ;)~ I I " Ii. ,,' I' , " ,;" '/ f .,! EXPENSES Home: Mortgage/Rent Maintenance Utilities Eler:tric Gas Oil Telephone Water/ Sewer Employment: Public Transportation/ Lunch Taxes: Real estate Personal property (Occupational) Income (Quarterly payments) Insurance: Homeowners Automobile Life Accident Health Other Automobile: Payments Fuel Repairs Medical: Doctor Dentist Orthodontist Hospital Medicine Special needs (glasses, etc.) Education Private school Parochial school College $ 9,000.00 Religious Week Month - Year - $14,300.00 $ l,oOO.OO $ 1,000.00 None $ 900.00 $ 700.00 $ 351.00 $ 575.00 $ 2,200.00 $ 480.00 $ 2,300.00 '..' $ 340.00 $ 1,340.00 $ 432.00 None None None $ 1,100.00 $ 3,200.00 $ 250.00 $ 150.00 $ 200.00 $ 250.00 (') u:> 0 C c:J 'rl .;: 2: --I ~r-i1 fF.:tI rnn', G'-' ;<.::-0 -:1~ /.,1:;: - :11 (J) .~~~ ~2c' '/ 2.\:.) "'" :t~:::I :;:; G..c.') ::-h: 2~ ~Cl lD c:. .. 9, ~ .r:- ~ .... C) '0 0 c CO -n :c.". en 5!~ -051 r:1 ~~-:l 'lJ '-n- '7[" N -r! ti5..-:,: w (:i( ;S(i -4., !< .' > ::1:-rJ "'n Z ' ::J: ':)-" ~.,.c-> <~o Om ;po c: ~ :.oJ 'l';! \\ (7) ~ In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION CAROL A. GEISSLER ) Docket Number 98-1395 CV Plaintiff ) vs. ) P ACSES Case Number 640100264~~lrlf GEORGB H, GEISSLER ) Defendant ) Other State 10 Number Order AND NOW to wit, this MAY 25, 1999 it is hereby Ordered that: I THE ./\BOVE CAPTIONED ALIMONY PENDENTE LITE ORDER IS TERMINATED, EFFECTIVE MAY 18, 1999, PURSUANT TO THE DBCREE IN DIVORCE ON THAT DATE, THERE IS A BALANCE OF $1,658.34 OWED TO PETITIONER, THE REMAINING BALANCE IS TO BE PAID IN FULL BY AUGUST 31, 1999 AND IS PAYABLE AT $276,39 BIWEEKLY, DRO: RJ Shadday xc: pla.Lnt.L defendant ~ H. Lock Esq. MoN.w. D, RupLch, Esq. ",\~\q'l Edward E, GuIdo JUDGE Service Type M Fonn OE-OOI Worker 10 21005 .....r FILEO-OfACE OF noli; FPClTHONOTARY 99 JUN"3 A11 811i~ CUMBER1JlNO COUNTY PENNSYLVANIA '.\