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HomeMy WebLinkAbout98-03127 . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. r.INnA K. RUFF / ---'. Plaint! ff No. 98-3127 . VERSUS WAYNE M. RUPI' '__________~__u__u______.,_"'_._""' DefenClant DECREE IN DIVORCE . AND NOW, ~~t~ !.-.~-~..._- ;t 1I:'I8A.M. 'JoO) . ._,. , __. IT IS ORDERED AND . DECREED THAT T. T NillL1L.._--RlilllL-._______, P LA I NT IFF. . AND WAYNE M. RUFP --~_._...._-- , DEFENDANT, . ARE DIVORCED FROM THE BONDS OF MATRIMONY. . THE COURT RETAINS JURISDICTION OF THE, F"OLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . . . . . N/A . . . . '. . . By TH . . . ATTEST: J. . ,1 ____L PROTHONOTARV . ... . . . of an agreement on the re~ord which the parties were going to reduce to writing and sign. However, we have agreed today, and this will be noted on the record by Mr. McKnight and Ms. Rupich, that we are going to disregard the June 7, 2000, statements which were made on the record with respect to their affecting any of the economic claims. We are going to have an agreement today placed on the record which will cover all the economic issues and resolve all of the economic claims. The agreement today will be considered the substantive agreement of the parties not subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. The draft of the agreement will be sent to counsel, and the parties and counsel can review the draft for typographical errors, make any corrections as required and than affix their signatures affirming the terms of settlement as placed on the record. It is specifically noted, however, that when the parties leave the hearing room today they will be bound by the terms of the agreement as stated on the record even though there may be no subsequent signing of the agreement affirming the terms of settlement, When the Master is provided a completed copy of the agreement, he will prepare an order vacating his appointment and counsel will then be able to file a praecipe transmitting the record to the Court requesting a final decree in divorce, The parties were married on October 19, 1973, and by stipulation have agreed that they separated on September 15, 1\195, Mr, McKnight.. MR. McKNIGHT: The parties have agreed to the following resolution of their outstanding issues: 1, The parties have agreed that from husband's retirement proceeds wife will receive the Bum of $20,000.00 paid in a lump sum to be paid through counsel in a reasonable period of time and he will apply for that distribution as soon as possible. Wife will sign any documents this date and any subsequent documents necessary to implement this retirement benefit. 2. Effective to the date of the divorce, the current order for spousal support./alimony will be modified to an indefinite alimony award in the amount of $1,200.00 per month. The alimony is modifiable upon a showing by either party of changed circumstances of a substantial and continuing nature. Said award will be terminated upon the marriage or cohabitation of the wife or the death of either party. It is deductible by the husband from his income taxes and income to the wife. 'l'here shall be an obligation on each party to notify the other upon a substantial change in their circumstances such as retirement by the husband or obtaining of disability benefits from social security by the wife or retirement social security benefits by the wife. The alimony award, following the entry of the divorce will continue to be paid through the Domestic Relations Office of Cumberland County, Pennsylvania. 3. In addition to the amount stated above, husband agrees to pay directly on behalf of wife the Blue Cross/Blue Shield special care rates, whatever those amounts are, and he will keep them in effect until remarriage, cohabitation, death of wife, or eligibility under any government social security. At husband's request, with wife's consent, husband will pay the amount of the special care Blue Cross/Blue Shield insurance to wife. Wife will secure the plan and will notify him of the premium amount and he will pay that to her every month. It is understood that if Blue Cross/Blue Shield raises their rates, he will likewise pay the increased amount. This is in addition to the total pa~1nent of $1,200.00 previously the $20,000.00 lump sum, do you understand everything that was set forth on the record? MR. RUPPI One question, Should the -- I do not know why they declined to pay her SSI at this time, but if it changes in the future, that will affect the amount of the alimony? THE MASTER: Absolutely you do, MS. RUPICHI Do you have any other questions? MR. RUE-PI No. MS, RUPICHI Do you understand all of the terms that were set forth in the agreement? MR, RUPPI Yes, i I i , I I .I I ! l [,INOA K. RUPP, Plaintiff VB. WAYNE M. RUPP, Defendant D^'rE: IN THE COUIl'1' OF COMMON PLEAB O~' CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTlON - I,AW NO. 90 - 3127 CIVU. 19 IN tHVOIlCE .S.TA:f.Y.J?_ SII1~r~'I' A.c:rr\,lJ~rll~:3 : PRETRIAL STATEMENTS DUE 9/17/99 8/17/99 _._...__' --. l_---- ].._._....m. ..______ . i ,/ ( /Do .J!Q.. ." ........----.--...- t.( 7. -{1A"'" ~ ...-' ~ ('/ / 7.Ar""" ---........----------_... .. -......... 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Rupich, A divorce complaint was filE!d on June 3, 1998, raisinq grounds fQr divorCE! of irretrievablE! breakdown of the marriage, The parties are going to sign affidavIts of consent and waIvers of notice of intention to request entry of dIvorco decree which counsel w.U 1 br:lnq alonq to our next confe[(~nce so that l:he di.vorce can be concluded under Section 3301(c) of the Domestic Relations Code. A petItion was fUed on August 5, 19J. raisinq economic claims of equitable distribution, alimony, alimony pendente lite, and counsel fees and costs. The parties were married on October 19, 1973, and according to husband, separated December E', 1993, and according to Wife, separated September 15, 1995, We have not yet determined whether or not the date of separation is particularly relevant to resolving the issues in this case, Counsel, after discussion, have determined with the Master that another confE!rence would be helpful in trying to resolvo tho issues and in order to prepare for that conference, counsel are going to state on the record what each will be doing before the conference in gathering information to hE!lp us to try to rE!solve the issues. Mr, McKnight, MR, McKNIGHT: As counsel for Linda K. Rupp, I will investigate the issu,~ of SSI for her. We believe she is eligible but hasn't recei.ved any becau,sl' of the amollnt of the spousal support that she Is receiving. What wo will be looking for is information on tho amount of the S8I she would be eligible for plus criteria for other income and how it would need to be designated in order for hor to receive that 88I. So wo will check that out: and have that of an agreement on the record which the parties were going to reduco to writing and sign. However, we have agreed today, and this will be noted on t.he record by Mr. McKnight and Ms, Rupich, that we are going to disregard the June 7, 2000, statements which were made on the record with respect to their affecting any of the economic claims. We are going to have an agreement tOday placed on the record which will cover all the economic issues and resolve all of the economic claims, The agreement today will be considered the substantive agreement of the parties not. subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. The draft of the agreement will be sent to counsel, and the parties and counsel can review the draft for typographical errors, make any corrections as required and than affix their signatures affirming the terms of settlement as placed on the I"ecord. It is specifically noted, however, that when the parties leave the hearing room today they will be bound by the terms of the agreement as stated on the record even though there may be no subsequent signing of the agreement affirming the terms of settlement. When the Master is provided a completed copy of the agreement, he will prepare an order vacating his appointment and COUnsel will then be able to file a praecipe transmitting the record to the Court requesting a final decree in dlvor.ce. The parties were married on October 19, 1973, and by stipulation have agreed that they separated on September 15, 1995. Mr, 11cKnlght. MR. McKNIGll'j': 1'he parties have agreed to the following resolution of their outstanding issues: 1, The parties have agreed that (rom husband's retirement proceeds wife will r.eceive the sum of $20,000.00 paid in a lump sum to be paid through counsel in a reasonable period of time and he will apply [or that distribution as soon as possible. Wife will sign any documents this date and any subsequent documents necessary to implement this retirement benefit. 2. Effective to the date of the divorce, the current order for spousal support/alimony will be modified to an indefinite alimony award in the amount of $1,200.00 per month. The alimony is modifiable upon a showing by either party of changed circumstances of a substantial and continuing nature. Said award will be terminated upon the marriage or cohabitation of the wife or the death of either party. It is deductible by the husband from his income taxes and income to the wife. 'rhere shall be an obligation on each party to notify the other upon a substantial change in their circumstances such as retirement by the Iwsband or obtaining of disability benefits from social security by the wife or retirement social security benefits by the wife. The alimony award, fol1owing the entry of the divorce will continue to be paid through the Domestic Relations OfUce of Cumberland County, Pennsylvania. 3. In add.i.tion to the amount stated above, husband agrees to pay directly on behalf of wife the Blue Cross/Blue Shield spec.i.al care rates, whatever those amounts are, and he will keep them in effect until remarriage, cohabitation, death of wife, or eligibilIty under any government social security, At husband's request, with wife's consent, husband will pay the amount of the spec.i.al care Blue Cross/Blue Sh.i.eld insurance to wife, Wife will secure the plan and will notify him of the premium amount und he will pay that t.o her every month. It is understood that if Blue Cross/Blue Shield raises their rates, he w.i.ll likewisB pay thB increased amount, This is in addition to the total payment of $1,200.00 previously discussed. 1\, Huoband aloo agroes to pay wihJ'[i share of that is owed for the deficiency on the home salo, will hold wife harmloss on any claim against wife of that loan. the loan Husband for payment 5, 1~e agreement regarding payment of the retiremont, health insurance, alimony, and payments of the loan conclude all obligations of husband inClUding any claims by wife or husband for equitable distribution of any marital assets. 6. Wife waive[1 her claim for counsel fees and costs. 7. The parties agree that for purposes of the wife's upcoming surgery, the divorce will be finalized on or after January 31, 2002. 8. Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives ancl relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship inClUding without limitation, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate. Each will at the request of the other execute, acknowledge, and deliver any and all instrulnents which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interest., rights, and claims. THE MASTER: Mr. McKnight., do you understand that the document that was produced as a result of the meeting on June 7, 2000, is not specifically made a part of these proceedings or this agreenmnt? MR. McKNIGH1': Yes. THE MAS'rER: And that this agreement that we have placed on t.he record is the total substantive agreement of the parties'l . MR, McKNIGH'l': 'l'hat is correct, TH~; MAS'l'b~R: Ms. RupIch, you have heard what I have asked Mr. McKnight specIfically about the document generated on June '7, 2000. Do you likewise agree with the comments that Mr. lilcKnight has said regarding the status of this document? MS. RUPICH: Yes, sir. MR, McKNIGHT: You heard the terms of the agreement that we have outlined; is that correct, Linda? MS, RUPP: Yes, MR, McKNIGHT: And do you agree with those terms? MS, RUPP: Yes. MR, McKNIGHT: And you understand that you have no further right to modify those except for anyspell'ing errors in those terms? MS. RUPP: Yes. HR, McKNIGm': And you so agree to enter into this agreement? MS. RUPP: Yes. MS, RUPICH: Mr, RUPP, you heard the terms as outlined by Mr, McKnight as to payment of alimony, as to the MR. RUPP: MS, RtlPICH: .- health insurance -- __ health insurance, . payment of of an agreement on thee record which the parties were ,wing to reduce to writing Dnd sign, However, we have agreed today, and this will be neted on the record by Mr. McKnight and Ms. Rupich, that we are going to disregard the June "I, 2000, stat.ements which were made on the record with respect to their affecting any of the economic claims. We are going to have an agreement today placed on the record which will cover all the economic issues and resolve all of the economic claims. The agreement today will be considered the substantive agreement of the parties not subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. The draft of the agreement will be sent to counsel, and the parties and counsel can review the draft for typographical errors, make any corrections as required and than affix their signatures affirming the terms of settlement as placed on the record. It is specifically noted, however, that when the parties luave the hearing room today they will be bound by the terms of the agreement as stated on the record even though there may be no subsequent signing of the agreement affirming the terms of settlement. When the Master is provided a completed copy of the agreement, he will prepare an order vacating his appointment and counsel will then be able to file a praecipe transmitting the record to the Court requesting a final decree in divorce. The parties were married on October 19, 1973, and by stipulation have agreed that they separated on September 15, 1995, Mr. McKnight. MR. McKNIGHT: 'l'he parties have agreed to the following resolution of their outstanding issues: 1. The parties have agreed that from husband's retirement proceeds wife will receive the sum of $20,000.00 paid in a lump sum to be paid through counsel in a reasonable period of time and he will apply for that distribution as soon as possible. Wife will sign any documents this date and any subsequent documents necessary to implement this retirement benefit. 2. Effective to the date of the divorce, the current order for spousal support/alimony will be modified to an indefinite alimony award in the amount of $1,200.00 per month. The alimony is modifiable upon a showing by either party of changed circumstances of a substantial and continuing nature. Said award will be terminated upon the marriage or cohabitation of the wife or the death of ~ither party. It is deductible by the husband from his income taxes and income to the wife. There shall be an obligati on on each party to notify the other upon a substantial change in their circumstances such as retirement by the husband or obtaining of disability benefits from social security by the wife or retirement social security benefits by the wife. 'l'he alimony award, following the entry of the dj~orce will continue to be paid through the Domestic Relatiof'.; Office of Cumberland County, Pennsylvania. 3. In addi tion to the amount stated above, husband agrees to pay directly on behalf of wife the Blue Cross/Blue Shield special care rates, whatever those amounts are, and he will keep them in effect until remarriage, cohabit.ation, death of wife, or eligibi li ty under any government social secur! ty. At husband's request, with wife's consent, husband will pay the amount of the special care Blue Cross/Blue Shield insurance to wife. Wife will secure the plan and will notify him of the premium amount and he will pay that to her every month, It is understood that if Blue Cross/Blue Shield raises their rates, he will likewise pay the increased amount. This is in addition to the total payment of $1,200,00 previously the $20,000,00 lump sum, do you understand ~verything that was set forth on the record? MR, HUPP: One question. Should the -- I do not know why they declined to pay her S8I at this time, but if it changes in the future, that will affect the amount of the alimony? MS. RUPICH: Yes, THE MASTER: Just so you understand, Mr, Rupp, it is a circumstance that will allow you to raise the issue regarding the amount of alimony that you are paying, but I do not think that any of us here can specifically state to you that it will automatically change the amount; that will be up to the judge who would hear the case on a petition to modify, Just so you do not. have a misunderstanding that i'c will automatically, for instance, decrease because of her statLjs change, ~'hat will simply be up to the person who might hear the case later on. MR. HUPP: I was jus t concern(J(;\ tha t I wouid have the option to do that. THE MASTER: Absolutely you do, MS, RUPICH: Do you have any other questions? MR. HUPP: No. MS, RUPICH: Do you understand all of the terms that were set forth in the agreement? MR. RUPP: Yes. of an agreement on the record which tho partios were g01ng to recluqe t.o wd ling and niqn. lIowever, wo, helve fjgreed today, and this will be noted on the rBcord by Mr. McKnight and Ms. Rupich, that we Cl).'8 90ing to disregard the ,Iuno '/, 2000, statements which were made on the record with respect to thoir affecting any of the economic claims, We are going to have an agreement today placed on the record which will cover all the economic issues and resolve all of the economic claims. 'I'he agreement today will be considered the substantive agreement of the parties not subject to any changes or modifications except for correction of typographical errors which may be made during the transcl'lption. The draft of the agreement will be sent to counsel, and the parties and counsel can review the draft [or typographicL~ errors, make any corrections as required and than affix their signatures affirming the terms of settlement as placed on the record. It is specifically noted, however, that when the parties leave the hearing room today they will be bound by the terms of the agreament as stated on the record even though there may be no subsequent signing of the agreemenc affirming the terms of sett lemen t . When the Master is provided a C.'omplet.ed copy of the agreement, he will prepare an order vacating his appointment. and counsel will then be able to file a praebipe transmitting the record to the Court requesting a final decree in divorce. 'T'he parties were married on October 19,19'/3, and by stipulation have agreed that they separated on September 15, 1995. Mr. MCKnight. I~R. McKNIGlI'l': The partier; have agreed to the fallowing resolution of their outstanding issuBs: 1. 'I'he parties havt! agreed that from husband' s retirement proceeds wife will receive the sum of $20,000.00 paid in a lump sum to be paid through coumlel in a reasonable period of time and he will apply for that distribution as soon as possible. Wife will sign any documents this date and any subsequent documents necessary to implement this retirement benefit. 2. Effective to the date of the divorce, the current order for spousal support/alimony will be modified to an indefinite alimony award in the amount of $1,200.00 per month. The alimony is modifiable upon a showing by either party of changed circumstances of a substantial and continuing nature. Said award will be terminatad upon the marriage or cohabitation of the wife or the death of either party. It is deductible by the husband from his income taxes and income to the wife. There shall be an obligation on each party to notify the other upon a substantial change in their circumstances such as retirement by the husband or obtaining of disability benefits from social security by the wife or retirement social security benefits by the wife. 'rhe alimony award, following the entry of the divorce will continue to be paid through the Domestic Relations Office of Cumberland County, Pennsylvania. 3. In addition to the amount stated above, husband agrees to pay directly on behalf of wife the Blue Cross/Blue Shield special care rates, whatever those amounts are, and he will keep them in effect until remarriage, cohabitation, death of wife, or eligibility under any government social Elecurity. At husband's request, with wife's consent, husband will pay the amount of the special care Blua Cross/Blue Shield insurance to wife. Wife will secure the plan and will notify him of the premium amount and he will pay that to her every month. It is understood that if Blue Cross/Blue Shield raises their rates, he will likewise pay the increased amount. This is in addition to the total payment of $1,200.00 previously the $20,000.00 lump sum, do you un((l,nltlll\d f!vnrythtl\\/ tlint Wllfl set forth on the record? MH. HUPP: Om) qlWfltlo!l. IlliotiJd thnl do not know why they decl1mld to PllY liur WII {.It tIiIMtlm{l, but Ie it changes in the future", tl1l1t wLlI ,,!'foot tho II/I\ount of thEl alimony? MS. HLJPICll: YOII. THE MlIfl'l'E:H I <fUll t: liD you undo Iii tmld, Mr. Rupp, it is a cir'cumstanco thtll: ~JII.I allow you to ndf.l€! the .issue regarding the iJmoullt 01 (Ii ImullY tliilt you Ill'.'ll IliIylng, but I do not think that any of' 1/"1 horn (!l11I f1[)ocl. f'.Ie/lIly uUlt0. to you that it will automnl,j.cally dlllll\lO tlio wlIount; Ulat will be up to the judge who would hoar tho CHlIO Oil f\ potlUon to modify. Just so YOtl do not IlilVO Il rnlnundonll:ancllng that it will automatically, for imltanuu, decr8llf3() bociHm8 of her status change. 'I'hat will sImply )m up 1:0 tho person who might hear the case later on. MH. RUPP: I waH just concerned that I would have the option to do thilt. Absolutely you do. Uo youhavB any other questions? No. Do you understand all of the terms that were oot forth .In tho agreement? MI<. IWJ>Pl Yon. 'l'HlI: MAf-j'l'V.:H l MS, HLJl.'ICII: MH. HUPP: MS. HUl'ICII: of an agreement on the record which the parties were going to roduco to writing and nign. Howover. We have agreed today, and this will be noted on tho record by Mr. McKnight and Ms. Rupich, that we ara going to disregard the June 7, 2000, statements which were made on the H1cord with nlspect to their affecting any of the economic claims. We ara going to have an agreement today placed on the record which will cover all the aconomic issues and resolve all of the economic ciaims. The agreement today will be considered the substantive agreement of the parties not subject to any changes or modifications except for correction of typographical errors which may be made during the trans~ription. The draft of the agreement will be sent to counsel, and the parties and counsel can review the draft for typographical errors, make any corrections as required and than affix their signatures affirming ~he terms of settlement as placed on the record. It is specifically noted, however, that when the parties leave the hearing room today they will be bound by the terms of the agreement as stated on the recor'd even though there may be no subsequent signing of the agreement affirming the terms of set.tlement. When the Master is provided a completed copy of the agreement, he will prepare an order vacating his appointment and counsel will then be able to file a praecipe transmitting the record to the Court requesting a final decree " in divorce. 'l'he parties were married on October 19, 1973, and by stipulation have agn~ed that they separated on September 15, 1995. Mr. McKnight. MR. McKNIGHT: The parties have ilgreed to the following resolution of their outstanding issues: 1. 'rhe parties have agreed that from husband's retirement proceeds wife will receive the sum of $20,000.00 paid in a lump sum to be paid through counsel in a reasonable period of time and he will apply for that distribution as soon as possible. Wife will sign any documents this date and any subsequent documents necessary to implement this retirement benefi t. 2. Effective to the date of the divorce, the current order for spousal support/alimony will be modified to an indefinite alimony award in the amount of $1,200.00 per month. The alimony is modifiable upon a showing by either party of changed circumstances of a substantial and continuing nature. Said award will be terminated upon the marriage or cohabitation of the wife or the death of either party. It is deductible by the husband from his income taxes and income to the wife. There shall be an obligation on each par'ty to notify the other upon a substantial change in their circumstances such as retirement by the husband or obtaining of disability benefits from social security by the wife or retirement social security bonefits by the wife. The alimony award, following the entry of the divorce will continue to be paid through the Domestic Relations Office of Cumberland County, Pennsylvania. 3. In addition to the amount stated above, husband agrees to pay directly on behalf of wife the Blue Cross/Blue Shield special care rates, whatever those amounts are, and he will keep them in effect until remarriage, cohabitation, death of wife, or eligibi 1i ty under any government social secur! ty. At husband's request, with wife's consent, husband will pay the amount of the special care Blue Cross/Blue Shield insurance to wife. Wife will secure the plan and will notify him of the premium amount and he will pay that to her every month. It is understood that if Blue Cross/Blue Shield raises their rates, he will likewise pay the increased amount. This is in addition to the total payment of $1,200.00 previously MS. RUPICH: And do you agree to those terms? MR. IHJPP: Yes. MS. HUPICII: And you understand that this is not something that can be appoaled at this time? MR. HUPP: Yes. MS. RUPICII: Tlwt all of the issues are resolved inclUding equit.able distribution, alimony, and counsel tees? MR. RUPP: Yes. MS. RUPICH: You may not come back at a later point and make any additional claims? MR. HUPP: Okay. MS. RUPICH: And you are in agreement with those terms? MR. RUPP: Yes. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and int.end 'to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the . and fiied affidavits of consBllt and waivers of notice of intention to request entry of divorce decree sn that the divorce can be concluded under Section 3301(cl of the Domestic Reiations Code. Mr. McKnight. MR. MoKNIGHT: 1. The parties have agreed that from the husband's retirement proceeds wife will receive the sum of $20,000.00 paid in a lump to be paid through counsel in a reasonable period of time and lIe will apply for that distribution as soon as possible. Wife will cooperate with the application for the retirement benefit. 2. Effective to the date of the divorce, the current order for spousal support/alimony will be modified to a permanent alimony amount of $85.00 a month that is terminable by marriage, cohabitation, or death of either party. It is deductible by the husband and income to the wife. In addition, husband will pay a modifiable amount, modifiable in accordance with the Domestic Relations guidelines as if it were support but a modifiable amount of equitable distribution of $588.00 per month. In addition to that, he will pay the difference between the 5SI payment and $527.00 effective the date that wife receives her first monthly SSI payment, whatever the amount is. If the amount she receives in SSI exceeds $527.00, the amount of equitable distribution will be reduced by a like amount, so that the total payment, including the $85.00 for alimony from husband to wife, will be $1,200.00, $85.00 of which will be paid through Domestic Relation and the balance of which will be paid directly from husband to wife each month. 3. In addition to those amounts, husband agrees to pay directly, on behalf of wife, the Blue Cross/Blue Shield special care rates, whatever those amounts are and he will keep t~at in effect until remarriage, cOhabitation, or death of wife. 4. Husband also agrees to pay wife's share of the loan that is owed for the deficiency on the home sale. Husband will hold wife harmless on any claim against that loan. (A discussion was held off the record.) II' THE MASTER: After discussion off the record, Mr. McKnight is going t.o mako further comments regarding the propos~d agreement. MR. MoKNIGHT: At husband's request and with Wife's consent, he will pay the amount of the special care Blue Cross insurance directly to wife. Wife will Secure the plan and notify him of the premium amount and he will pay that to her every month. It is understood that if Blue Cross raises their rates, he will likewise pay the increased amount. This is in addi lion to the total payment of $l,200.00 previously discussed. The amount of the payment that is equi.table distribution will not be affected by bankruptcy filed by husband. It will be modifiable if husband is laid off and receiVing unemployment or if he is injured and receives worker's compensation, but it will not be modifiable if husband voluntarily quits his employment. THE MASTER: Ms. Rupich, is there anything else you want to add or comment about? MS. RUPleH: Simply that the parties understand they will be returning to revaluate their financial status Upon husband's retirement and application of social security benefits. LINDA K. RUPP, Plaintiff IN THE COURT OF' COMMON PLF:AS OF' CUMBERLAND COUNTY, PENNSYWANIA VS. CIVIL ACTION - LAW WAYNE M. RUPP, Defendant NO. 98 - 3127 Civil IN DlVORCE CONF'lmENCE: WITH COUNSr~L AND TIm PARTIES 'fO: Marcus A. McKnight, III , Counsel for Plaintiff I,inda K. Rupp , Plaintiff Diane M. Rupich , Counsel for Defendant Wayne M. Rupp , Defendant A conference has been scheduled at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 27th day of April, 2000, at 2:00 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: MC\rch 24, 2000 E. Robert Elicker, II DivorCe Master . \ Incomc and EX/lCIl'le Slatcmclll PACSES Case Numher 349100635 - --- -- OTHER (1'111 In Approprlale Coil/mil) rNCOME -- - - -- WEEK MONTI! YEAR - - '- Imerest $ $ $ .~-- Dlvldcnds t----- Pension - - -- -- Annuity Social SecurllY - Reots - Royalties - - Expense Account Gifts - -- Unemployment Coropensadon - -- Workmen's Compensation - IRS Refund Other !..Spousal) d.'., -- Sl.2lJO.OQ _. Other TOTAL $ $ $ - TOTAL INCOME $1,200.00 Monthly (Fill in Appropriate Column) EXPENSES WEEK MONTH YEAR, Home MongagelRelll $ $450.00 $ Maintenance ----- Utilities Electric 45.00 GIIS 2 011 Telephone 45.00 - -- Page 2 of 6 FomllN-008 SelVice Type M Worker ID 21205 Incume and e~Jlllllle Statemem PAcses Case Number 348100635 -- (Pili in Appropriate Culumn) ------,---- EXPENSES (conllnued) WEEK MONTII VEAR - Water $ $ $ Sewer - - - Employment Public Traruiponalion $ $ $ Lunch - Taxes Real Estate $ $ $ Personal Propeny - locome Insurance HomeolVllers $ $ $ Automobile Life Accldeol Health -- Other (Rentera) 12.00 - Automobile '- ~eolS $ $ $ - Fuel -1!hQ0 - - Repalrs -- Medical Doctor $ $ $ DemisI -- Onhndoulist ---- - Service Type M Page 3 of 6 Porm IN-GOB Worker ID 21205 lnC(llll~ and E~pc:ns~ Slat~I1lCnt PACSES Case Numb~r 348100635 - . -- - (Pill In Appropriate Column) EXPENSES (continued) WEEK MONTH YEAR - .- -- Hospital -- Medlcin~ 21.00 Special needs (glasses. braces. onhopc:dic devices) Education -- Private School $ $ $ Parochial School College Religioos PenonaJ Clothing $ $ 20.00 $ Food 7no.OO Barber/Hairdresser 5.00 Credit Payments: Credlt Card Charge AccoUDt 81.00 Memberships Loans Credit Union $ $ $ --- - MlscellaneoWl ,- --- Household Help $ $ $ Child Care Papc:rs/Books/MagaziD~ 14.00 Elllenainmem 40.00 Pay TV 3 J. 32 --- Vacadon Page 4 of 6 Form IN-008 Worker ID 21205 Service Type M \ Incomc and Expense Stalemcnt PACSES Casc Numbcr 348100635 EXPENSES (conllnued) WEEK (Fill III Appropriale Colullln) MONTH YEAR GlflS Legal Fees Charilllble COlllribulions Oilier Child Suppa" Alimony Payments .....20.00 Other $ $ $ TOTAL EXPENSES $ $ $ PROPERTY OwnershIp' OWNED DESCRIPrION VALUE H W J Checking ACCOUDLS $ Savings ACCOWllS Credll Union Stocks/BoDlIs Real Estate Other , TOTAL $ i I, Coverage · INSURANCE COMPANY POLICY # ! I, i' H W c I Hosphal i , Blue Ctoss I Other I Medical I Blue Shield I Oilier · H .. Husband W-Wlte C .. Combined J .. Joint I" "t Page 5 of 6 Fonn IN-DOS Scrvlce Type M Worker ID 21205 ,! r I U. 8~lIin.lI. Oht IIU Owll4ilrll. illClluding pUL'Cl,lntil<jU vi Qwnouhip. Anc.l OULClu/diroCltor poMi.tion.. ,,,,1<.1 L1y II p.rt~ with companyl. 16. Employmarnt urminAdon tHlneUta .: liltrVIHilnc~' "<1\'. workman'l ClompelllAtion claiR(award Profit IIharing plana Penaion plAn I lindicAte emploY4ile contribut~on ilnu ute pl.n Vlllltlll Rlltir~ment plAnll. Individual aetirllm~nt Ac~ountu I I 17. lt/ u. I 111. I 20. I 21. I U. I I U. lvf' :u. l~ 2$. Pi..bility p.yment. LitigAtion clAim. (mAtured And unmllturudl Military/V.A. ben.fit. Education banllfit. D.Dta due. including l~.n.. ~rtgllg.a harlc.l HQu..hold furni.hin9a .nd porlonalty lincludo Q~ Q I total cattl90ry and att.Ch itomiltld liat if di~tr~but~on . of Illch ..lIl1tl1 111 in' d~aplltel (I 26. Other ..,. ,... 1) .. I III .., C'tl .<: . '".-4 ) ." .8 .' ... .- ~ Cl > Cl ..,.... .. ... :) 0:: IJ ... CI CI .:: .......11I III .... Ill'" ... WQ..l .0 III ... III .., ... g. ::I 'C ... Q/ II 1II"-4',..j a: O..l .. D .. ... Q III :I c: D\ J~'~ II ... O~ C >- ....c ~ III 00 III .., '0 .<: 11I401 ~ i IllU " .c 0:: III 8C11 A. :I 8. ...... ~ 11I11I 1/1 >Q lJ ... III QI.... A: :>0 ~ .<: .., c: 0 "110 >oj >..., ~ .c: Ill'" ) .. ..Q,., a: >. a III ~t: ......, t:og. >.~ Bill 0 1::... Ill.c 8, Co c: 0 0... .., ... " 401 Co... ........ .,. 01/1 ..... .., ~I QI:I 4010' .., 11I0 ..e Q< a e .... ...11I.., ... .,..... ~ .. ...'0 ~" QI ~. III QI '0 z'il~ :I: ...:1 Ill... .... U ...Ie C>. II 0... ... .,. .. t! ta '0 .,. 0 co .... II... OA. .... III &'0 &"il .J U . " ... u ... -- . ~ I I ... ... ::> I \ III ~ .......,-, .. ~ ... '0 ~ ~ . , 0 ... . ~ .. 0 ... ~ .. ~ Co III QI Cl ....t :I ...... .. III III > Co ... III 0 \) ~ tj.... .<: ....401 0'" III ... ~.t C Ill'll I~ lil 8 ~~' C Q/D\ 0 .. ....t D\ C ... Ill'...t ~. III >. .. >..... ~, +l 1ll,Q 0 .. 0. III 1Il'tl'tl 0. III III III 0 'Dill , ... ":18, ~ '::\::. llo QI'" +lUll) ".f""'4 .... x... III C III III Q/'D U 1~ 0... 0:: ~ '" 'rf 'D >. >. III III .. II........ ::I III ..... 104'" l~ "ll ... QI 8.... U I ... :I 0. III ICII....O'OO.c w.....u.....c llol:l.cll.llo'" t-.~ I~ .. 0 I~~ ..... . . . . . -NM"-IIl\o 14 ... . 1/1 ,; ./1' , .. 01/ Nit .... ...... c: . ...=. . :';. ,J '14 ... i: .14 "''0 Ot ~.. .. ... goD. '=08 ." II '0.14 .I~ '14 .. . .~ L. .. i ... '5~ .Be '" ... IJ\ ... ! Oil ..J , !. .~ S 4lJ ~ '5'5 ... '14 tt '=1 .... ...1: , .. 0 .= ..!. D... ..... ~.I: .., .0 ...>- . I: .... 1 ... '5 '14 ~ . ~ ~ >t ~ ... ... . .g ': '14 ] \.'" " EChol A I 01/ U II'" .~..~ :::'14 & IN ...... 0 .... 0.. .r. U ;I . 'II....... ...... !II" II~A A ... . 1II1:...... .. .... .... IN Oil 0.. "II" "" ,,. .,... jl:..a& = >- . 1:...... . ... ... .... 0.... II'" . 11011<<: ... .... ....... llo.A" I: "'0 0'14 . ... ....11.14 o .... C1Q.f4. ... lJ/:l:1 .... ao 8..... u > ,00( .. ....CI 0... . III: .... &1: I: o '14 ... ... '14 o. '14 11:1 ...ao .u Go( .. . ...., I 11:- . 'a~lI: I: o '14 ~ >- ... t b X. . .0 &"O~ u ... ... l' - - ~ ....~l ~. . \ . ~ , ,~\~~ :,.\ , ~ t? "h. . ~ ~' " ~ "'.:.:, ~" . ~ ~ . ~. . ~ . ~ '-. . , . . . . . . ~) . . ,~ "'~ ~\t . .~ PSGe Actuarial and Mortality Tables Method AJgust 10, 1999 Wayne Rupp - File # 06.15-99.156.15698 ...... " MORTALITY TABL.ES AND INTEREST RATES: ivlortality Tables (1983 Group Annuity MOl1ality Tables). Into rest Rates and Factors used by the Pension Benelit Guaranty Corporation to determine the presont value of annuities lor single-employer plans. INTEREST RATE ASSUMPTIONS: Table II - Annuity Ratos Rates as of December 15. 1993 : 11 '" 5.60 %. i2 '" 5.25 % and i3 '" 5.25 % Estimated Plan Cost 01 Living Adjustment: 0.00 % Adjusted Rates if Applicable: 11 = 5.60 %. i2 = 5.25 % and i3 '" 5.25 % Estimated Social Security Cost of Living Adjustment: 2.60 % Adjusted Rate'. il Applicable: , i1 = 3.00 %. i2 '" 2.65 % and i3 = 2.65 % ASSUMED MONTHLY BENEFIT: $1.365.93 Monthlv pension benelltthe pension holder would receive at retirement age WI(n ft fUllY YO"'''d p..n."CtM b...id UpClIM O~t"'f='''riac\Ut1n ~M~ plel.M provisions as 01 December 15, 1993. Formula: (A) Take: 1 1/2% of the "high-3" average pay and multiply the result hy 5 years 01 service. (B) Add: 1 3/4% of the "hlgh-3" average pay multipliod by the years of service between 5 and 10, (C) Add: 2% of the "high"3" average pay multiplied by all service over 10 years, Data: Years of Service: 18,34 Years (8/15/75 - 12/15/93) t~,OJ) Vears (Military creclit) 21.34 Veal's (As of 12iI5/93) Assumed "High-3" Years Average Pay: $42.104.33 Analysis: lA) 0.0150)( $42.104.33 x 5,00 Years =$ 3.157,82 B) 0.0175 x $42.104.33 x 5.00 Years = 3.684.13 C) 0.0200 x $42,104.33 x11.34Years = .9.,5~(;U~Q Total Annual Benefit $16.391.21 DEPARTMENT OF DEFENSE CIVILIAN LEAVE AND EARNINGS STATEMENT I ",-, "I ~,;,t, ".' 08/14/99 I ~." ,!f..\1l ."...... 'h4"" __.".. ... . ,ot ..~ "", 08/10/99 ~ ,.v """1"""011.1'; . '''".l1l\1ln~" I ~"" "'''' ,. 'II' """Ut , II.~I" !If ~.\, Ij ..., ... I 'I"'" ~'" .....pt"'"'...~ 11Z-JZ..1140 tl,8/ I 08/22//11 140 Ill<.,'I'AUI "II"""P ,.", _.""""~ .'_1.."'1 r II H'l:il';~ 11;~IlJ "IOCA"'". IUf"",-"rl',')jI, " ',[U,'AV, II ..... 'I A'," "..., I,~," 14 1!H".u~, 'lnll"n,t". ...1 Pol, MOlDERS 1ST fell 1', "..,,"'.,~, ''''\101''10'", .""'MI'I' f' "''''''",.""-",!..,,,,,, ..,,,r"I"'., ,1"fA.,,- ~r:I:,~' lIllol1!,,~,\ '00. I.-i~... ~r:\!II\(' i~I-~~i"ltl~ - -~on I I" .'';';-'''I',i'll;~j i. "~\I..i,,-':i'~l _, i.liuiIN'- - 1<1 "'lIi.~f 1W,;\l\H fED PA M S 411080 S IIAMPDIN TS PA eSRS: 0810. /4 " OURREN! YE^" TO OA TE " GRO~S PAY 1991. 10 34131,40 TAXAlLE WAGES 1991.10 341JZ,40 NOMTAXAILE WAGES TAX DErERRED WAGES DEDIJ(:T10NS bOO .10 0/30,11 AElC NIT PAY \41&,01 24393.7,3 TYPE Nleul.^" "'^'l' ..-----~-.----C-URRENT EARNINGS----. HOURS/DAYS AMOUNT TYPE flOURS/DAYS AMOUNT TYPE HOURS/DAVS AMOUN 80,00 1..1."U --_._-~---_._-----_._~_.___u_. DEDuctjoNs-----O-~-O---.-------O--- TYPE CODE CURRENT YEAR TO ()ATE TYPE CODE CURRENT HAft TO DATE fEGLI co 8,37 140,90 FEHO 101 60,71 9f>l. III MEDICARE 20,1l7 494,91 RETIRr. eSRS I 144.30 1444,3'1 TAX. FEDERAL 163.11 4304,/0 TAX. lOCAL 411080 19.91 341, {II TAX.LOC Dec 411080 10.00 lAX. STAll PA 6&,76 9bb.6!i LEAveo------------... TVPE PRIOR VA AOORUED ACCRUED USEO USED DONA TED/ OURRENT US[ .lO<j 8M ANOE HY PO no PA, PO no RETURNED BALANOE ;tiftM n^ ANNUAL T3.00 8.00 110,00 8.00 114.00 17.00 SICK 8.00 4,00 04,00 106.bO -34.50 HOLl DAY 31,00 ADMIN 1.00 3.00 --~_._---~------_._--_._~--~-- REMARKS WILL I GET PAlO IN JANUARY 10ll0? YES! Of AS IS RlADY. VISl1 Hl1P:IIWWW.DfAS.MII.IYlK fOR MORE INfORMATION ON flOW YOU CAN "RlPAOl fOO Y1K. I SEND YOUR EMPlOYMlNT/LOAN VERifICATIONS TO YOIlR HIIMAN OISOIJRCES OFfiCI. l'llllIJlH'I.' UeU .---'---.-.--..--.----......-+->---...,---........---.--- ---~-'"---,--....... '..---., -"--- ._- .....~--,-_._-------_._-..---., ,-". .... rfll~ ml'Ofi! C.OfHAINS INfOHM^IION !)tllll!;(,f 10' lilt 1'1\10'.11,0 AU 01 I'll" AS AMLN(ILD D''''~ 'lIl,., I , ~l V L' (5.0 l instluclloo!l ~ on paUl' 10) f. ~~~ l ., labol. H HO!llo nddr05~ (fllHl\btlr lInd ",hOOI) If YOlI thlvu 111'0 1J1l~, c,uu P,IW' 10 . Apt '~IO f'ar halp In finding Uno (~lt~OIWI"~, t ~_PDr)(.,> t :) A ! ... ... ~n:~~O~lr~'~h:~~O~:~~~ p 0 so pr " I( City, town Of pO<,l ot/len. Mutu, aflel!!!' (;r Ill' If YU\I IlilVU II 1011111111 MidfW,:\. ~,uo I'llll" 10 ~;~::~~n\lUI <( .. ., '> y\( ) 1\ II~";~ =1V~.~T:N.~l~:S~:;,;,,~:;,g . [faction Campaign ~ (JO ynll warlt '$3 to 9010 lhl':! ItJflcl',I, , , , , . , , , , . . , . . . .. ...',~J:-~-~~C.. "',1090 yOtlf t.tx Of ~o paqn 10.) ..J~ Ir...I.!.~Ilf1t)~~~~!~IO()<; ~!_~e.OU~i~~l.t._~_!l(!Jl:~~~,.I~~!f1d't ~_.:.........:.......,~ ,. _L WOllell yelll( wftm,/ 1 ~illl!lro Filing Status 2 M'rrlo" 11I111(llolnlllllllrlllnvon II only 0110 Iwellncn",o) 3 MMriucl lihfl9 50fJ.Hillu rullllll !:nw( SfJOU'iU'5 ~oclcll 'lu(:\l(lty IlO. ulJove cHid fuli 1I.lIIllt 11m!,). ... ________.___.__ .._..___._____ 4 Iloi:lcl ot hOU~i(!tlolcl (Wllh qunllfyh10 pmson), (Suo rll~IO '10,) If lho qlllllitying pnr~on is II r.hllcllllll not your dopondoflt, ontor Ihls chlld's nmllo hmo, .. _________________ .~~i.~~vlcl~~(ur) witt! d(Jpofl(~~~t r.1l!ldJY2.i~':...~rOU<;o diml .19 ). (Soo pHon 10.) 6a e_ our8all. If your pdront (or SonWO/lO lll~o) ClHl d.ulO you ilS it eJopoJl(lont on his or hor tllX} No. ot bO~lI~ roturn, do not ctlOck !lox fill. . . " ..,.".... chcck(ld 011 6a and 6b b lL~p.~II'''-_, . _ _.' ~_ . -' _ _'... _ _ . ' .. C._'._'. N', "y,or c Oopondonts: (l) Dl!~r1dlll1rS PI (Jopl!ndo/l['s W No of months chlldrllfl on 6c socJ.ll Sl)cuflty n\lmber rolallonship 10 lived in YOllf who: ~U.~~.~~~~1.1~ t"'ll nlmc .____...._.___.__...___._______ ____-'lQI! ..hq!!~~J.QJTI_L. lived with )au --~~-- --------- --.-.-.--.. . ...--.------.-._._____ .____._____~ _.__ . did nollivft with you due 10 divoru or supatallon -- -------_~.._. ..___,_..~_.. (see page 11) Oependenl~ on 6c nolenlerodabove __~ Add numbers enlered on line, .bovu .. 22 Add tho amollnts.ln Hlo f,lr tlqht column tor linos 7 thrOllr h 21. This Is our tOlallncome ,... 23 IRA e1oelllctlon (soo paoe 1 &) , 24 Modlcal savings account doell/clion. Attach Form 8853 25 Moving exponses, Attach Form 3903 ur 3903-F 26 Ono-half of solf.omployment 11lx., Attllch Schodulo SE 27 Self.omployed health insurance c!OClllCtiOfl (soo pi1go 17) 28 Keogh find solf.omployed SEP ilnel SIMPLE plans 29 Ponalty on o1lfly withdrawal of savi.nqs, . , ' ~:' . . 30. Alimony palel b Recipiont's SSN ~;;.~__~_. (,,<;,tb 31 Aelellines 23 through 30<1 32 Sutltract lille 311rom lino 22 Ttl151':l your adjusted gross Income For Privacy Act and Papnrwork ReducUon Act Nollce, see page 38, ... .. ;,~ 1040 Label ChocK ollly ono box. s --- Exemptions It more than six dependonts, see pago 10, ,"come Allaoh Copy B 01 your Forms W-2, W-2G. and 10e9.R h.r., "yoll e11e1 nol gOI . W.2. Joe page 12. Encloso but do not lHlflch any payment Also, 1)1eal'e llse Form 1040-V. Alljusted Gross Income If line 32 Is undor 129,290Iund.r 19,770 If a child jid not livo with you), soe EIC inst- on page 21. fJl.'pllflllllmt Ilf I/\!! TltlH'l\Jry-..lrltulrllll 1~IlVtJIllW ~ilJ/vil:lt 1'11(0'97 I u.s. Indi~lduaL!nc~_~~.Ta~~~!,~!~~_._.__~~::2___, ._. ,,{?,~_~",~r~~'!~.~~.l!L:.~~~' or ~I~p!lt I', 111/\ '113CfJ for Hlfl YUll( JllIll..0m;, 31. HI9'1, or olllilr lil~ YUiH btJgirH\i'~~1 , IU!I1, IIIlcllf1!1__.__.".:.1_9.._.JS)~~!.~,?_1~_{~Q9?..__. Yoo, 1^Jof\i~~1"1~ .... M. l"it'J~~J rP 71;'h_~13;'U/n;41_ If 0 JOinl foturn, ~p(JUSt"f, flrf,t /l<HIIU 111\<1 11l1l1ll! I.il',\ Ilanw Spou~e'. lOlJhll.eoutUy number -I. _ _ _ ___......_.__u_ ~___.._~___~_~ __~._..___ ___.____ [jJ d lotnl nllmber of exemptions clalmod 7 e. b o '10 11 12 13 14 15. le. 17 le 19 20. 21 ..2110 ou WflgOS, salmios, Ups. ote, Attach rorm(s) W.2 , TaMablo Interest. Attach SchodLlle n If roqulred Tu-oxempt Int(1rost. DO NOT include on line Ba . Dlvldunds. Attach Schodulo B If rcqllirocl , Taxablo refunds, credits. or offsets of state ancllocallncomo taxes (sEle page 12) Alimony rocolvod Business Incomo or (loss), Attach Schedule C or C-EZ Capltill gain or (loss), Antleh Schodule 0 . Other gaIns or (tossos). Attllch rorm 4797, , . , . , . , . , . . . . Total IRA (!islrlbullons , L1s. .1-____ f- I b Tmbl. ,mount lsoo pago 131 Total pensions and anntlilifJS lJ6a.L_______ b Taxable amount (soe pago 13) Rentfll real ostato, royalties, partnerships,S corporations. trllsts. ote. Attach Sctloclulo E Farm incomo or (loss). Atlach SdlOclllle r . Unomployment componsation . . . . . . . . Suclal security benefils . L~~~_L..._~._____L.J b TAx.able amolmt (seo page 14) Othor Incomo, List typo flnel i1nlOunt-soo page 15 ...,..........,. " 7 eo i eb .L~_:...J_~ ~liiilj ~.- -----.- ~.- ..1Il.. ..11.. __.~ 12 13 lL ill. 18b 17 1!.. ______ 19 20b 21 23 24 _~L 28 t27 lit~B- t ~-- W ~ 31 32 I{ Cat. No 113200 r.XHIRIT "8" Hlffn IQ,\{) l1YI'N _--.._.M._.'__M__............_.....___._.___----.......-..._.---.-.-.___.~._.~_~__.__~__<_....._ If Ihw :13 1'1 SfJO,'JOO ()( 103'i, multiply S2.[,50 by Iho latol nurnbur of (HWlTlpUans r.lillnwd on Uno Gr!. If IIno :u I'j ovm $90,900, !;(JU tho workstllJut 011 P"~Jo HIlar tho omount 10 unto( , TalCablo 111como, Subtract lino 37 from Ilrlt! :16, If lino :015 lJ\oru than linn 36, on tor .0. _~'a.~~ So~_ p,~~_~_~:_5:tlO~:k, !1.~I(ly"!!I.~__(~(HIl.,.~. r.J--':~J-'~,~(~'_.l.I.~~~_____.bJ~!.. Form_'!.u_L2_____~...." ,~__.. Crud It for child and dOIJOnclU/lt caro (JxpiJn~os. AltClctl form 2441 ..:.tL _.__.....__.,...__".._J___~ Croclit for UIO oldorly or Iho di~<'hll](l, Anach Sdw(julu H . __~~ __ ~___~_ AdoplJon crodil. Attactl Form 8839 , "_~_?___ ___.._._.. rorelgn lax crudl!, Allach Form 11-16 .....'1L ____.._._..._~ _._~ OUmr. Chock II lrom . [] Form 3000 b [) Form 0396 00 Form 0001 d L 1 Form (spocilyl_.. ......_.____... ~4 45 Aclcllinos 40 through 44 45 ---------~~-~ Subt~~~.Ui~l"O_~~~.!!9..~!..I,~!~J_~~.!!JI~1_f)__4~_.i.s _!~~~Jt~~~.!!~!~._~~. ~~~i_:9...:..:._...:..._..~~..'____'__----'_~__ _~~." 47 Solf.omploymont teli(. Attach SctlOdulo SI:: . ..!I__~__._~___ __ 48 Alte-rmHlvo minimum (ilX. Attach Form 6251 ~_ 49 Social secllrity line! Modicare fax on tir income not rapofled to employer. Attach Form 4131 _1!... ...._____ 50 Tax on quallflecl rntlroment plans (Incll!(Jing IRAs) and MSAs, Allach Form 5329 If roqulrtld SO 51 Advance earnocllncomo crodit payments frorn Form(s) W.2 _.!1_ 52 Household employmont taxos, Attach Sctmdule H . 52 _~~__ Add linos 46Ihrou9.'2)]:.1!~!~~~IL.t..o_~~U!!'_~__.:.__._~_,_:.... ' .., j)> ~ ____._~ Payments 54 FDclomllncomo lax wilhhelcl Irom Forms \V.~ .ncll099. . ~ '+3~' 3 ..... .-(su .';ir~'( 55 1997 eSfimated lax payments and amount applied from 1996 mturn 55 _.._~___.... ___ JJry:l~i 56a Earned It/come credit. All,1Ch Schedule [Ie if you hal/u a qualifying :'J~l\~-~ :~,_;! child b Nonla~able carned income: amount ... L_~__L-J J~j:: ~,;{il:; ~~~~~ W.2, 57 ~~~~~:,op:el ~II~ ~0;';;;~68 (roquesl ;~;~;;~;l~i~~). ~5~' -_..=~=~:= ='''!~~j/ ~~~Ra~~ 58 Exce3s sodal slJcurlty and RRTA tax withlwleJ,(soo pago 27) 68 _"__ ~ ~:'1i<:: Iho IranI. 59 Olhor p'ymonls. Chock II from .0 Form 2439 ',1> [.I Form 4136 59 .%>1' .--~___~.Q..._Mc.!..!!!~2J..~~_~~~_~_E,..?~:....a~~Ji~~:~l.~~.~~_y_~~~.Jo'a!J!~monts _.~_~:....~_ 80_ ___~2S-L'L.~. Refund 81 II Ii no 60 Is moro Ih.n line 53, sublr.ollino 5~ from lino 60. This Is Iho .mount you OVERPAID ~ ._.._.sLL.!i._ toll f1.vo II ij2. Amoun' 01 lino 61 you w.nl REFUNDED TQ YOU. . , , , . . . . ~ 82. _.__..5.L!:L ..:~ <liroclly R b . [IIT_ITIITJ- 0 [I deposlwdl ~ b outing nLlm ar _., ...->. _... _ .... c Type: Chocking _ Savings ~~~ ~f?~ lk ~ d Aceoun' numbor OIL:"IT[ID=TTITIICI 62c. onel 62~_jll......A_rT1QgnL9Li!.n.~~l1<!u w~'!ilpPlIED To..Y9.1!~.!Q98 EE!~.A.lEO TAx..-"_.LI!!..L__..._~n._L.._ Amount 8~ Illino 5315 moro Ih.n lino 60. subtr.ctllno 60 Irom line 53. This Is tho AMOUNT YOU OWE You Owe for dOI.lIs on how 10 p.y, 'oe p.ge 27 , , ~ !!... Estimated lax-.eona!!t~J~lso Include on line ~1 '. I 65 I Undor penallies. of PO(ilJlY. I doclaro Ihall h,lvll e:C:i1,ninod this rOlum ancl ilccompill1ying schod\lles ilnd slatorntlnt'i, ond 10 IhellOsl of my knowledgo end bolief, they are lllle, COHee!. and complete. OeclarllMn 01 preparl.'r (otnor Ih,ln laxpayer) 15 based on olllnfa/Illalion of which preparer has any kll(lwledgu. et Yow slgnatu(e D<1to Your occupation '---"'---"-~" ....... --. - - - --.........--.- Spouse's signaturll'f o joint rewrn. UOrH mllS\ sign Tax Compu. tatlon If you wonl Iho IRS to f1ooro yoor 111:<, sou p.go HI. Credits Other Taxas '. Sign Here Koop . copy of this roturn for your rucor(ls Paid Pi'eparer's Use Only J3 34. (J Bllnel. ~ 34. ^mount from Iiflu 32 (iHIJu~if(JcI ~,ro~i~; Iflcnrtw) CIUlCk. It: [J You WUfn 6~ or oldO(, [] Blind; [J Spouso wO'; 6~i or ol(Jor, ^dd Iho IllHl\bm 01 !JmW'i ctI(IC~,lld aho1/tI iH1(1 untor tho tollllllnw , 35 II Ir you llrll mmrlml WII1\j !;upllrilwly /ltld your 'ipotl'IO Ilornl/lls doducUow. or you WlJ(u II dUill'!ltillu~i nllllll, 'iOfJ IIiIWI 1ft und dwck IImu . /ItOfnIUd deductions "UfIl Sdwdulo A, IifW 20, Oft rnlOr SIAndard d.,ducl!ON ~;hown l1olow for YLlll( lilln~J <JtlltU'i, OUI Sfli! thu Pll90 HI I! you ctwcKoclullY IJOX o'l linn ],1<101 :l4h or sOHluorle largor (;1111 dillrn Ytlll lI~i II dllpOfldtJrlt ~:)ur: · Slnn'll...$~,l!iO · MiHf!{l(lliIlflujOlntly or qllaljfylrl~J wklow(m).---S6,OOO · HOlle! II' hUU~;illlold-.Stl,(J~JO . MiHl!od IllInq ~Hlpnf/Huly-..$3.450 Suhfr<lct IIlw 3!i from lirHJ :\3 .!:I.l2'(~~ rll ~ 34b [J 36 37 39 39 40 41 42 43 44 Onto Spollse's oc:cupallon Proparer's .. slgn<lturo r ~..~'-_._-_."~-.~-., ._~-~_._--~--_.- ....- Firrn'!'>nnmo (or YOU(a ~ if solf.employecl) nrICl u. .----.-_. .--_....__ Il(l<fltls<; Dale P(tlpilrer's social security no, Check II ['] _..".~_ _~~~~nploy.~.~_w:,.~. .__._._~-_._---.-._---~...._-.. EIN "'--~--~'---~ _.~-~._~----~.~~-- liP coda (i) d Total number of exeme,liofls claimed 7 Wages. onlarles, tips, elc, AIIach Formls) W-2 . 8a Taxable interest. Attach Schedule B it required b Tax-exempt in teres!. 00 NOT Include on lino On , 9 Ordinary dividonds. Allactl Scheclulo B if ,equlrocl 10 Taxable rolumls, credits, or o"sols of slate nnclloc111 incomo taxes (see page 21) 11 Alimony mceivoel 12 Business Incomo or (loss), Allach Schedule C or C.EZ 13 Capllal gain or Iloss), AIIach Schedule D . 14 Other gains or (lOS90S). Attach Form 4797, . . , . . . . . . . . , , 15a Total IRA disl'ibulions. ~L. _..L.J b Taxable amounllsee page 22) 16a Talal pellsions atld annulI/os ~._._---l_.._J b Taxable amollnl {see page 22) 17 Renl.ll roal estato, royalties, partnerships, S corporations, trusts, otc. Attach SchocJule E 18 Fa,m Income 0' Iloss). Attach Schedule F 19 Unemployment componsatlon . . , . . . . , . . . . . 20a Soci.1 secu,lIy h.".liIs . 120a I J----.J b Taxable amou"II". page 241 21 Other Income. Usl typo anel amount-seo page 24.................................... 22 Add tho amounts In the tar right collllnn lor lines" through 21, Ttlis is ol~r totallnoome .. 23 IRA deduotlon (s.. page 25) . 23 24 Sludenlloan interest declucUon (soo page 27) . ~ 26 Medical ~avjngs account doducUon. Attach Form 8853 26 26 MoYlng oxpensos. Attach Form 3903 _ 26 27 Ono-half of self. employment tax, Atlach Schedulo SE 27 28 Solf-omployed hoalth Influrancf) doeluction (see page 20) ~__ ~___.___ __ 29 Keogh and self-employed SEP and SIMPLE plans 29 ~_"_'___ 30 Ponally Cln early withdrawal 01 savings . 1!!...- ____~_~ 31. Alirnonyp,l;d bRecipiolll'sSSN. +0"1 :'~f1.01~~ 1.!! ~ 32 Acid linos 23 ttJrouOh 31 il . 33 SlJ~Cllinf: ~j2 from line 22, This is your ndjustod grolS Inoome For Ol.olosure, PriVACY Act, and Paperwork Reduotion Aot Nalleo, 80a poge 51. ---, .~ 1040 Label Filing Status Chock only ono box. Exemptions If more lhan six dependents, seo page 19. Income A"aoh Copy B 0' your Form. W.2. W.20, and 1099.R here. If YOll did not g.t a W.2, see page 20. Enclose, but do not slaple, llllY payment. Also, please use Form 1040-V. AdJusled Gross Income It hne 33 is undor $30,095 (lInd.r $10,030 if a chllei did not livo with you), so. EIG Inst. On page 3G. (lUII,I'lI11,,,,1 t,I "I', I'Ull.q'lr., .11,1"",111 IIUVlIIl1111 HUlI/i'J(' U.S. Indlvldunllncome Tall Return 'il~)98 I..!!L--.!Il'j UiO Only , 10\111, lJlldlll~' .l!'l !1(lt '''''''0 01 8Iapl,) 1/1 Ihi, tl'''<:o l A " " I " ~ " ~ "Of lhu YllIIf ,1,1" I-{li'f;, ;11. 1[)(}Il, or 01111,1: III.. YOllf Illlllirl/lIrli! V"", \'''' 0.1"'" "".I 1111'.." I ilrz'''c~ r () HL.lf\W~~ 11V\ If II Join! 10111111. !IJ)(Jljqll'll forst rlilr!!" WId Il\illitl lnqt llit!!lH 81'011''''1 llllCl/t1 ,,,ourIIV flwuher - ,10 OMfI No I!Wi-(1074 '(our loolnl1fHlu,IlV IHIIl1her .'I"\"'~!~~'I""(;:':~'~:'f;'~'~I''''''il~~I'['''WP'I\I''11I .. I ^ff"1 ~ yl,~~?~~~~TI ~ C!lY, 10""11 {)f pO!ll (\"11:0. qt,I!!I, Hnd IH' cfI(lo. If (0;; t\,I"H II frltUl(jfl Ildd(ll~", fit'(1 pll\lt! Ifl your SSN(s) abovo, '~,\\.<),. r",.t {::" I 1(;t("> ~a-'iN~- N.l"-CI;;'!.;'~---' - -~- -- "YtlJ"WlllflOr 00 Y(Jlj wallt $:110 go 10 this fund", . . , . . . , , . , . . , " ~ _ C/l<lllfJ6 ~o(Jr tax Ot II ~ joint rotUfn, doe!! your spouso want $:110 {lo 10 lhlH ~~~...:......_~~.~~ ' ~ fffcfllr.O YOtlf 'olund Slrlnlo -.. - -- Married Wlnn Jolnl roturn (OVllfl I' DrIly ono tmd Ifl(;mno) MArried Will\) svparillu toIurn. [nlor SpOll'W'S !iQ(:!i'\1 security no (lbovo Hod lull n(llJlO Iloro" ____.._.~~____________ 'load of hOll~oholcj (wilh qualilyinO porson). (SOD pago 10.) If lho qualifying per SOt I Is a child but not your clopondMI, eniD' 1111s ehllel's 'l<lrno hmo, II- '___'_~'_______~___~~.___--------'."-------'__ Ql/ali/vln wldow(or) with dopondonl child (yom spoww cjit1d.. 10 ). (Soo l!.a~ 68 g--yourself. If your paTOn I (or somoono olso) can c1<1I/Yl you as n cloponclonl on hls or 110r tax} No. 01 b011l rat urn, do not chock box 6a. . . , , . . , . , , , , . " ch'c~.d on "lnd 8b b ~use. , '--~- . . . . '._.:......~.:..._~---'-,~_. .' . , , . . .' '!.. No. of your o Dependents: (2) Oi/pandonl's (3) D~P6nd6nrs 41 if qUI,II~iil1Q chlldrln on 8e SOCill ~acurj!y num/)Ilr ,el,lllOnshlp 10 Child lor eMd lJA whO' (I) Fjlsl flJmtl laS!llilflli/ ' a YOIl CI~dlt f1UDJQiI 191 ' ----~----~-..--._- ~------.~ -- - . ~ ~ - . lived with ,OU m______. -__. O. dldnelllvo olin o YOU4uIlodlvorc. O .'"Plllllon III'Pll.l1) o D.pendentl..I, o nOI.nll"dabov.~_ o Add num.." [jJ Inll'ldon IIn..abov." 1M- 5 -L --'--------~~- -~.-..._-_._- ~~_.__.__.-.._---~ , --------.---- ---...---- ~-- l!iu:~~. 9 10 11 12 13 _1.L____ 15b lOb 17 10 19 20b 21 22 .-------.- - ___h~_ __ .,-; '1 ilY J_ (:.11. No. 11320R . /"011" 1040 {109B) I~XHTn'rI "1'" 34 A/llOtlnt from Iino :n (lldju!\h\(1 flfOfHl lrlGOlT1o) " "..., ~" -'13 .l.d:,c1 35n Chock il: 0 You worn O!i or oldof, [] Ulind; 0 8pouIO Wns fl!) Of tlldtlr, rJ UUne!, . Add 1110 Illunbor 0' bO)(IJ~; c:hunkod nll{IVU llnd Ulllt1f Um lotul horo . ... 3611 ~...'.;~ b If YOll mil II1wrlod Winy llopnrnluly lIr1d your OPOWlfl Ilornllos dodllGtlullH or\t.~ YOll wow n cllIlll,ulnlw,lIlioll, \100 pnqo 29 unci (:tltl~:k limo , .. 35b 0 -:B~ (~r\lor lho larger of YlHlf Ilomllod deduotlon. 'rolll SdlUdu!o At linn 2U, OR .tnndard ~~~\ deduatlon stlOW.l 011 the 10'1. Out 111)0 pago ~IO to find your 1111ln<lllr(j <!l';(lual!on If you " ::-;.", .r.' ~ dlockod IHIY bo)( 011 lil10 ~~lll (If :Hih or If SO/HOOfIO cafl ulillrn you nn <1 dupundonl . 38 ._~~~~e,. SlIhlfftcllino 30 from linn :14 . 37 __5__K__"J~(_._.~J~ If lil\o :14 Is $9:\,1100 or IO!l'\, lIlultlply $2.100 by tho 101111 flumtlllr 0' tlXOmptl0f13 clllhnod Or! ~~ linn 6d. If Iino 311 bl ovm $9:\,4UO. ~oo Iho workshcol on pagll ~IO for HUt llfllollnt to ontor. .1.l!. TRulll, lncomo. SulJlfUctlino 30 Iromlino Ji', If lino ao l!lll1oro than Uno :17, ontor .0- ~~_ Tu Soo pago 30. Chock IllIny Ill> fmlll . U Form(o) 8H14 b [J Form 497~ .. 40 Crodit 'Of child "nd dupondont cme (lXpOnso9. Attach form 2441 41__ ...__._______._ __._. ~ Credll for tho uldmly o( tho di!iabled, Allnch SChodu,le n . .~2 _ ~~~~~_ _ __. ~~ Uhlld la, oro";1 (00" pago 31) _!~ __ _ __.. u__ __ _ ~ Edllcal!on crodils, AlIaeh Form BHll3 ~~ _ __ _ _ ~ Adoption credit. Allach fCJIrn 6839 . ___ . .... ._~ ~ forolgn lax Cfocht. Attach FornI 1116 If roqulrud 46 ~ ~ ._____~___ _.__ ~ Othor. Chock Illro", n 0 Form 31100 b [J Form B39tl ~ ~ cD Form HBOI dO Form (spocl,y)_____ 47 ~" 48 Add Unes 41 IhrOllgh 41, TI1030 am your tolal credits 48 _ 49 ~Yact line 48 lr~~)lne 40. If line 48 Is "!Ere thar~e 40, enter .O.....:...~_ .... 49 60 Solt.employmonltax. Attach Schedulo SE . 60 __._..__ 61 Alternative minimum tCUt AUactJ Form 6251 51 __.~_~._ 52 SocIal security and Medici\rc tax on tip Income not reported to employer. Attach Form 4137 62 ._.~___~ 53 Tax on lRAs, other retlf(Jmonl plans, and MSAs, Attach Form 5329 If required 63 64 Advance earned Income' credit payments from Form(s) W-2 . 54 65 Household employment laxes. Attach Schedule H. 65 56 Add linos 49 throllgh ~~, This Is YOllr totnl tn, . 56 Payments 57 Feclornllncomo la, withhold from Forms W-2 nnd 1099 (.. 9 :r~. 68 1991) eslirnated tax payments and amount appllAd lrom 1997 rclurn. 698 Earned Income credit. Attach Schedule EIG If YOll have it qualifying child b Nontaxable earned Income: amount .. L- 1 I an" type. .........................................._ 59a 60 Additional child In' crodit Attnch Form Hal2 . 50 61 Amollnt palcl with Form 486B (roqllosl for e,lonslon) . 61 62 E,coss social s.cllrlty ond RRTA la' withhold (soe pngo 43) 62 63 Othor paymonts, Chock il Irom a 0 Form 2439 b 0 Form 4136 63 _6;1_~dd Iin.s 57 ~ 59a, and 60 throllgh 63. Thes. ore YOllr total pnyment. . . 65 Ii Iino 641s moro thnn line 56. sllblroct IIno 56 from line ll4. Thio is Ihe nmollnt YOll OVERPAID 56a Amollnl of lino 65 YOll wanl REFUNDED TO YOU. . . Hove II dlroclly clopoSltod! . b Rouling number ~ c Type: 0 Checking 0 Saving, ;~~ fflf?~ ~b, ~ d Accounl numller LJ:::r:L~TIIII:Jl-o:J !i!!s ani' ~lld. ~~mount 01 Iin, 65 you wanl AP~lIED TD YDUR t999 ESTIMATED TAX ~ 1 57 I Amount 56" IIno 5ll Is moro than IIno 64. slIbtractline 64 from line 56, This Is lho AMOUNT YOU OWE. You Owe For dol ails on how 10 pay. s.o pago 44 . . . . . 69 Estlmalod tn, ponally, Also Inclucl. on line 6ll . 1 69.1 1 Under penallios 01 POljUry, I declare that I ha'ie e)(amlnad this relurn and accompanying 9cllOdulos and slalemenls, and to Ihe best of my knowledge lll'td bellel, they are lrue, COrlectb.and complete, Ooclartlllon of preparer (other than t(!x.payorl Is bas.ed on "It information of which prflparer has any knowledge. Yovr 91. f),11lflO DillE! YOllr occupation I Daytime telephone ~ V. c._~qJl~("'~4.A>r mlmber (opllonal) r SPOLJ~O'S Sig~;lj~~lIa~~\IIfl. ROTH mu~~ -():11;-- Spouso's occupalion __ I ) Pro'lMur's ~ Dille Plflpa7o~-;;;r~" CllflCkil 51qnalllrfl _~~:~~loYO(:J:L ;:~I~~~~;-(~7;~~r-~-~----~-_._-_.._-._......_-,.__.__.- II !Iolf,jJlTlploy~dl ill\d .--.--...-.-"..-.-- ... --.----~--_.----- ilddress form t 040 (HJ90l Tall and Credits 8lundnrd OaduoUon for Mol" People Slnglo: $4,2f10 t-l(Jad of hOllSehold' $O,nW Mllrrlod fillrlfl jointly or Qllalifyln9 widow(or) ,II,IOU Marrlod filing saparatoly: $3,550 Other Talles Attach Forms W.2 and W-20 on the fronl. Also attach Form 1099-R If tax was withheld. Relund Sign Here Joint return? Soo pago lB. Keop il copy lor your records. Paid Preparer's Use Only rtllY'?..~ bl l 36 37 JlI _~-,-L..ro 0'0. __'3. _"_L'll{_~t-_ ____I>'8_~'i _qq 39 40 41 42 43 44 45 46 47 ~_~lL ___ ~~( cr-D EIN lIP code 3. A divorce action is cUJ'/'cntly pending before your Honomble Court to No. 98-3127 Civil wherein the Defendant, Linda K. Rupp, is the Plaintiff and Plaintiff: Wayne M. Rupp is the Defendant. 4. Defendant, Linda K. Rupp, is represented by Attorney Marcus A. McKnight, 11/ in the divorce action, whose office is located at 60 West Pomfret Street, Carlisle, Pennsylvania 17013. 5. After request for Appointment of a Special Master having been made by a party to the divorce, E. Robert Elicker, II, Esquire, Master, scheduled a pre-hearing conference on June 7, 2000, at which time, the parties appeared with counsel and had full opportunity to confer with counsel and the Special Master, a review of all relevant divorce issues and relevant divorce laws of the Commonwealth of Pennsylvania, a full and complete agreement was reached between the parties. See Exhibit "A" attached hereto being a copy of the transcript of said pre-hearing conference. -2- and filed affidavits of consent and waivers of notice of intention to request entry of divorce decree so that the divorce can be concluded under Section 330l Ie) of the Domestic Relations Code. Mr. McKnight. MR. McKNIGHT: 1. The parties have agreed that from the husband'n retirement proceeds wife will receive the sum of $~O,OOO.OO paid in a lump to be paid through counsel in il nlililonilhl (J pori ad of time and he Inll apply for that dl,;t.rJl>\I\ lOll illI soon as possible. Wife \vlll cooperC\t.e wlt.h tho dppllcdlioll for the retirement benefit. 2. Effective to the date of the divorce, thu cllrJnl\t. oldor for spousal support/alimony will be modi fieri to ,I 1)l!llIIilllOld alimony amount of $85.00 a month that is torlllilldblo I,y marriage, cohabitation, or death of either parLy. It III deductible by the husband and income to t.ho wi r". In addition, husband will pay a modi f I all [() ilHlCJlllil, modifiable in accordance with the [James tie 1\(11 iI Ii oilS guidelines as if it were support but a modi f.i ab 1 0 i1mO\l1l t 0 f equitable distribution of $588.00 per month. In i1ddlt.lon to that, he will pay the difference between tho ~-;Sl paymont. Hllel $527.00 effective the date that wife receives her firHt monthly S3I payment, whatever the amount is. I f till) ilIl10unt she receives in S8I exceeds $527.00, the amount of equi tilblo distribution will be reduced by a like amount, BO that t.h(] total payment, including the $85.00 for alimony frolll hU~lbiJncl to wife, will be $1,200.00, $85.00 of which will 1)(, pilid through Domestic Relation "nd the balance of \,/hi,::1I Iv! Ll bo paid directly from husband to wife each mont.h. 3. In addition to those amounts, husband agrees 10 PilY directly, on behalf of wife, the Blue Cross/B.!uo SlIiold special care rates, ~/hatever those amounts are illld ho wll.! keep that in effect until remarriage, cohdbJ lilllon, or dO/tlh of wife. 4 . that will Husband also agrees to pay wi 1'0 I fl i-illd I'l! "f I hn 101ln is owed for the deficiency on Iho hOIlI" lid I". 1I11111'"nd hold wife harmless on any claJm iAqid IlHI t hill: [(Jitll. IA discussion was hold off thu rocord.) THE MASTER: After discussion off the record, Mr. McKnight is going to make further comments regarding the proposed agreemen l:. MR. McKNIGHT: At husband's request and with. wife'.s consent, he will pay the amount of the special care Blue Cross insurance directly to wife. Wife will secure the plan and notify him of the premium amount and he will pay that to her every month. It is understood that if Blue Cross raises their rates, he will likewise pay the increased amount. This is in addition to the total payment of $1,200.00 previously discussed. The amount of the payment that is equitable distribution will not be affected by bankruptcy filed by husband. It will be modifiable if husband is laid off and receiving unemployment or if he is injured and receives worker's compensation, but it will not be modifiable if husband voluntarily quits his employment. THE 11ASTER: Ms. Rupich, is there anything else you want to add or comment about? MS. RUPIeH: Simply that the parties understand they will be returning to revaluate their financial status upon husband's r.etirement and application 0f social security benefits. WHEREAS, diverse unhappy marital diffICulties huve arisen between the purties causing them to believe that their marriage is irretrievably hroken, liS a result of which they have separated and now live separate and apart fhllll one another, the parties being estranged due to such marital difficulties with no reasonable expectation of wconciliation; and the parties hcreto are desirous of settling fully and final:y 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 propeliy; and the settling of all matters relating to the custody and support of their minor children, and in general, the settling of any and all claims and possible claims by one against the other 01' against their respective estate, particularly those responsibilities and rights growing out ofthe 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 wife, each intending to be legally bound, hereby covenant and agree as follows: -2- 1. SEPAI{ATION. It shall be lawful IIJr each par1y, at all times hereaner, to live separate and apm1 from the othcr, at such placc or places as he or she may, from time to time, choose 01' deem fit. Eadl party shall be free from interference, authority or contact by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry out the provisions ofthis Agrcement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 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, eaeh 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 vmy any term of this Agreement, whether or not either or both of the parties shall remany, 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 -3- of divorce 01' separation. It is specifically agrccd howcver, that a copy of this Agreement or the substance of the provisions thereot: may be incorporatcd by reference into any Order of divorce, Judgment, or Dccrec. This incorporation, howevcr, shall not bc rcgarded as a mcrgcr, it being the spccinc intcnt of the parties to permit this Agreement to survive any Judgmcnt and be forcver binding and conclusive upon the parties. 2. EFFECTIVE DATE. The effective date of this Agrcemcnt shall be thc "date of execution" 01' "execution date", defined as thc datc upon which it is cxecuted by the parties if they have each cxecuted the Agreement on the same date. Otherwisc, the "date of execution" 01' "exccution date" of this Agrcemcnt shall be defined as the date of execution by the party last executing this Agrcement. 3. Ml./TUAL RELEASES, Husband and wife do hercby mutually remise, release, quit-claim or fotever discharge the othcr and estate of such other, for all time to come, and for all purposes whatsoever, from any and all rights, titlc and interest, 01' claims in 01' -4- against the estate of sueh other, or whatever nature and wherever situate, which he or she now has or at any time hereatler may have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements, 01' 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. 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 -5- of any kind or naturc, rcal, personul, 01' mixed, which thc othcr now owns or muy hereaftcr acquirc, cxccpt, and only CXCl'pt, all rights and agrccmcnts and obligations of whatsoevcr naturc arising 01' which may arisc undcr this Agrcemcnt 01' for the breach of any provision thcrcof. 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 dcfined as the date of execution of the Divorce Decree, unless otherwise specified herein. 5. MUTUAL CONSENTIADVICE OF CQlJNSELJ.t Husband and wife acknowledge and understand the terms and conditions of this Agreement, and wife is represented by Marcus A. McKnight, III, Esquire, and Husband is represented by Diane M. Rupich, 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 and accept that this Agreement is, undcr thc circumstances, fail' and equitable and that it is being entered into freely and voluntarily, and that the execution of this -6- Agreement is not the result of any collusion 01' improper 01' illegal agreement 01' agreements. 6. ~NCIAL DISCLOSURE. The parties contiI'm that each has relied on the substantial accuracy of the financial disclosure of the other as an inducement to thc execution of this Agreement. The parties acknowledge that there has been no tormal discovery conducted in their pending divorce action and that neither party has tiled an Inventory and Appraisement as required by Section 3505(b) of the Pennsylvania Divorce Code. Notwithstanding the foregoing, the rights of either party to pursue a claim for equitable distribution, pursuant to the Pennsylvania Divorce Code, of any interest owed by the other party in an asset of any nature at any timt' prior to the date of execution of this Agreement that was not disclosed to the other party or his or her counsel prior to the date of the within Agreement is expressly reserved. In the event that either party, at any time hereafter, discovers such an undisclosed asset, the patties shall have the right to petition the Court of Common Pleas of Dauphin County to make equitable distribution of said asset. .7. The non-disclosing party shall be responsible for payment of counsel fees, costs, or expenses incurred by the othcr party in seeking equitable distribution of said asset. 7. DEBTS AND OBLlGAl'IONS. Husband represents and warrants to wife that since 1995, he has not, and in the future he will not contract or incur any dcbt or liability for which wife or her estate might be responsible and shall indemnify and save wifc harmless from any and all claims or demands made against her by reason of such debts or obligations incurred by him since the date of said separation, except as otherwise set forth herein. Wife represents and warrants to husband that since 1995, she has not, and in the future she will not contract 01' incur any debt or liability fot which husband or his estate might be responsible and shall indemnify and save husband harmless from any and all claims or demands made against him by reason of such debts or obligations incurred by her since the date of said separation, except as otherwise set forth herein. 8. REAL ~StAIE.. Husband and wife hereby acknowledge that they were the joint owners of the real -8- estate located at Cumberland County, Pennsylvania; however, said real cstate has becn sold as of 1996, and as a rcsult of said sale, tlw partics hcrcto wcre required to borrow the sum of$13,650,60 through Commcrcial Credit Plan Consumer Discount Company, Account number 349720, to pay the deficiency balance Ilccessary to sell their real estate, Ilusband hcreby agrces to be solely rcspollsible 1'01' the payment of said loan, and hCl'cby indemnifies and holds wife harmlcss for the payment of said debt owed Commercial Credit Plan Consumer Discount Company 9, J.>ERSONAL PROPERTY. Except as set forth hercto, husband and wifc havc agreed that their personal property has bcen divided to thc parties' mutual satisfaction and neither party will make any claims to the property possessed by the other, except as set forth hereto: NONE. 10, PENSION AlW RETIREMENT. Husband and wife hereby acknowledge that the marital portion of husband's employee contributions to his prior employer, the United States federal government, are currently available, and Husband and Wife hereby agree that Wife shall rcceive the sum of Twenty Thousand and no/IOO -9- ($20,000,00) Dollars, payable through her attorney, Marcus A. McKnight, III, Esquire, mpresenting her agreed upon share of said employee contributions, Wife hereby agrees that upon the eXl1cution oCthe Property Scttlcmcnt Agreement, she will simultanco',lsly execute the neeessary documcnts for Ill<: withdrawal of thcse funds, Husband Curther agrces thai upon receipt of his share of thc employcc contributions fl'om thc Unitec1 States federal governmcnt, he will pay in full all arrearages due and owing to Wife in conncetion with the currcnt support Order entered in thc Court ofComl11on Pleas of Cumberland County. II , WAIVER OF RIGHTS. The parties hereto fully understand thcir rights under and pursuant to the Divorce Code, Act of 1980, No, 1980-26, as amended February 12, 1998, paliicularly the provisions for alimony pendente lite, spousal support, equitable distribution of marital property, attorneys fees, and expenses, Both parties agree that this Agreement shall conclusively providc for the distribution of property under the said law and thc parties hcreby waive, rek~ase and forever relinquish any furthcr rights they may respectively have against the other for alimony, alimony pendente lite, spousal support, equitable distribution of marital property, attorneys fees, and expenses. -10- 13, .w^I\'I~I{ 01{ MOD1EICATION TO liE 1~:W1UTING. A modification 01' waivcr or any or the terms of this Agrecment shall be effective only if in writing, signed by both parties, and executed with the same formality as this Agreement. No waiver of any breach hercof or default hercunder shall be dcemed a waivcr of any subsequent default of the same 01' similar nature, 14, A.J.JM.QID:: Husband hcreby agrces to pay to Wife the sum of Eighty-fivc and no/IOO ($85.00) Dollars alimony per month commcncing the first month after issuance of the Decrec in Divorce. Wife hercby agrccs that upon issuance of the Dccree in Divorce, she shall notify the Cumberland County Domestic Relations Officc so that this modification of the current Order may be placed into effect. Husband and Wife hereby agree that the sum of $85.00 shall be collectible and cnforced by the Cumberland County Domestic Relations Office. Wife hereby waives all arrearages due and owing on thc current Order for support, pursuant to Paragraph ten (10) herein. The parties hereto agree that the sum of$85,00 shall be taxable to Wife and deductible by Husband pursuant to the Intel11al Revenue Code and shall be tcrminable upon Wife's remarriage, cohabitation with a member of the opposite sex or death. -12- IS. EQ.l!I1'AnLltD.ISTlU811TIQ~ Husband hereby agrees to pay to Wile a sum of Ilmds monthly, commencing thl~ first month after finalization or the divorcc, to be determincd as Itlllows: $1,200.00 minus Wife's SSI payment minus $85,00 alimony payment, until such time as Husband rctircs and is eligible for Social Security bencfits, at which time, tlll~ par1ies hereto agrce to rc-evaluate and re-negotiatc said monthly paymcnts. Said paymcnt to Wife is not for Wife's maintenancc or support; howevcr, said payment is modifiable upon Husband's cntitlcmcnt to workman's compensation or unemploymcnt compensation, and shall be tcrminable upon Wife's remarriage, cohabitation with a member of the opposite sex or death, Husband may not deduct said monthly payment and Wife need not claim said monthly payment as income for income tax purposes, Husband hcreby acknowledges that the payment set forth in this Paragraph shall not be affected by any filing of bankruptcy by Husband in the future, and Husband hereby acknowledges his understanding that said monthly payment shall not be dischargeable in any bankruptcy proceeding, even though said payment is not for Wife's maintenance and support. The payment as set forth above shall be paid directly to Wife by Husband. -13- 16. HEALTH IlSSlJRANCE Wife's health insurance coverage through Ilusband'fl employment will ecase upon finalization of the divorce, Husband hereby agrl~es to pay Wife's health insurance rates and all increases pursuant to the Special Carc Rates as offercd by Capital Blue Cross, At the time ofthe exeeution ofthis Agrccmcnt, it is believcd by Husband and Wife that said monthly premium is $82,65, Wifc hereby agrees to cooperate and apply for health insurance coverage under the Special Care Ratcs as provided by Capital Bluc Cross immediatcly upon final ization of thc divorce, Said paymcnt shall be made dircctly to Wife by Husband, 17. MUTUAL...CQOPERATlON. Each party shall, at any time and from time to time hercaftcr, take any and all steps and execute, acknowledge and deliver to the other party, any and all future instruments and/or documents that the other party may reasonably require for that purpose of giving full force and effcct to the provisions of thc Agreement. 18. AGREEMENT BINDING ON HEIRS. This Agreement shall bc binding and shall inure to the benefit of the parties hereto and their respective legatccs, devises, heirs, executors, administrators, -14- successors, and assigns in the intercst of thc parties, 19, BREACH, If either party breachcs any provision of this Agrcement, the other party shall have the rights, at his or hcr election, to sue in law or in equity to enforcc any rights IInd rcmedies which the party may have, and the paJ1y breaching this Agreement shall bc responsiblc for payment of attorncys fees and all costs incurred by thc othcr in enforcing his or her rights under this Agrecment. 20. LAW OF PENNSYLVANIA APPLICABLE. This Agreement shall be construed in accordance with the laws of the Commonwcalth of Pennsylvania, 21. HEAQINGS NOT PART OF AGREEMENL Any headings preccding the text of the several paragraphs/provisions and subparagraphs hereof, lire inserted solely for convcnicnce of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect, -15- 'If" , \ Ii \\ . ~~ ) ';''1 , '?"~., Office of Divorce Master 9 North Hanover Street Carlisle, Pennsylvania 17013 MARCUS A, McKNIGHT, III, ESQUIRE IRWIN, McKNIGHT & HUGHES 60 WEST POMFRET STREET CARLISLE, PA 17013 ""'..-.,'(''''!j';-''" "l!" 1, v;l : j~"'- , ....' .,,', J" ,_. '+<1 . , '.~';:' '--, -j,\ ' ." .,. ~!;f.i "\~- t. ' i'. ;')i'! -, '\ , ,\." '. -~ l,t, , YI-j" _,,;,\<,1': I (~. \', ."it , , - ,~~' ,jL ~1 .~, y \~:". ':. ,~ .,",-- " :f4;,.". ,./ ~l )\ ... " , , I 'H , ) .' " '" . "1:'....i.~, , Office of Divorce Master 9 North Hanovor Slroot Carllslo, Pennsylvania 17013 ARTHUR K, DILS, ESQUIRE 1017 NORTH F'RONT STREET HARRISBURG, PA 17102 oa-".-, ,--i . "L;t. r.:'~ : -;If -", ~:i; '1" ",~..., ,...., "ji-' - ~~, ,.- " " I' Ii' "tf ~\.. I, '''-'.. -, ",; c _ -1., _"I~~,."',' ':".' '- -.\ l "',. II, ~..., .. 'J "iI" . 'i" 1';, ".'''..'..' ;-'j' "":,.. 'Ii. " I 't- _~. ( ,~". ,114:,. ' ,fc1J, ~ ", , II f. ;.. J, I 5, The avell11ents of fact contained in paragraph flve (5) of the Complaint are admitted, 6, The aVelments of fact contained in pamgraph six (6) of the Compluint ure admitted. 7. The avell11ents of fact contuined in puragrnph seven (7) of the Compluinl are admitted in part und denied in part, It is udmitted thut Exhibit "A" wus the understanding by the parties, However, Exhibit "B" is u Marriuge Settlement Agreement prepured by counsel for husband, The pluintiffsimply sccks further assurance thut the hcalth expenscs will be covered by the insurance coverage provided by husbund after the divorce. 8. The avennents of HlCl contained in paragruph cight (8) of the Complaint are denied, On the contrary, wife seeks adequute protection for her medical expenses after the entry ofthe Divorce Decree. 9, The avennents of fact contained in paragraph nine (9) of the Complaint are specifically denied. On the contrary, an equity action of law is not pennitted and this action should be dismissed. 10. The avennents of fact contained in paragruph ten (10) of the Complaint are spllcitlcally denied. The plaintiff is without knowledge to know what infol'l'l1ation is aoceptable to husband's retirement, 3 '", ..... ou ':... h: t,: .-.t f.. .. ,.. C" ..;1 .J...", III. fh) ().' :1'.: C);,~ rl; ; (Ii nO. ('J 2i -,-.;:- 1: ,."t" :s ~t) I" I i,,' (\' ;;; cd, (..J I /,0 ltJ ,.I ~.l. t- "''--I CJ ;;i I ~~ (,:'.) :J <';J C,) b