HomeMy WebLinkAbout03-0866
KYRA ANN SGRlGNOLI,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
VS.
NO.t>3 - Pt./.
CIVIL TERM
RODGER EUGENE SGRIGNOLI, JR.,
DEFENDANT
CIVIL ACTION . LAW
ACTION FOR DIVORCE / CUSTODY
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims set forth in the following
pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed
without you and a decree of divorce or annulment may be entered against you by the court. Ajudgment
may also be entered against you for any other claim or relief requested in these papers by the plaintiff.
You may lose money or property or other rights important to you, including custody or visitation of your
child.
When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you
may request marriage counseling. A list of marriage counselors is available in the Office of the
Prothonotary at the Cumberland County Courthouse, One Courthouse Square, Carlisle, P A 17013-3387.
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 RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle P A 17013
(717) 249-3166
1-800-990-9108
vs.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO.03 ... ~ CIVIL TERM
KYRA ANN SGRIGNOLI,
PLAINTIFF
RODGER EUGENE SGRIGNOLI, JR.,
DEFENDANT
CIVIL ACTION - LAW
: ACTION FOR DIVORCE / CUSTODY
COMPLAINT FOR NO-FAULT DIVORCE
UNDER SECTION 3301(c) OF THE DIVORCE CODE
AND NOW, comes the Plaintiff, KYRA ANN SGRIGNOLI, by and through her
counsel, Susan Kay Candiello, Esquire, of the Law Firm of Susan Kay Candiello, P .c., and makes
the following consolidated complaint in divorce for divorce and custody.
1. Plaintiff is KYRA ANN SGRIGNOLI, an adult individual, who currently resides
at 424F Duke Street, Enola, Cumberland County, Pennsylvania, 17025. The Plaintiff has resided
in Cumberland County for over five (5) years.
2. Defendant is RODGER EUGENE SGRIGNOLI, JR., an adult individual, who
currently resides at 11 North Enola Drive, Enola, Cumberland County, Pennsylvania, 17025.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at
least six (6) months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were lawfully married on November 21, 1987.
5. There have been no prior actions of divorce or for annulment between the parties
except this Complaint filed for divorce.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of counseling and of the right to
request that the court require the parties to participate in counseling. Plaintiff has chosen not to
engage in, or to request any counseling.
8. Defendant was a member of the United States Navy for nine (9) years, but has not
been married long enough to have acquired any benefits subject to equitable division. Defendant
was a member of the Navy Reserves for three (3) years, but has not served long enough to have
acquired any benefits subject to equitable division. Plaintiff was never a member of the United
States Military Services.
9. Plaintiff and Defendant have two (2) children from their marriage, CHRISTIAN
TYLER SGRlGNOLI, born July 5, 1989, and TYLER JAMES SGRlGNOLI, born on
August 10, 1993.
COUNT I - REQUEST FOR NO-FAULT DIVORCE
UNDER SECTION 3301(c) OF THE DIVORCE CODE
10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference
thereto.
11. After ninety (90) days have elapsed from the date of filing this Complaint, Plaintiff
intends to file an Affidavit consenting to the divorce. Plaintiff believes Defendant may also file
such an affidavit.
WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90)
days have elapsed from the date of filing of this Complaint, Plaintiff, KYRA ANN
SGRlGNOLI, respectfully requests the court to enter a Decree of Divorce pursuant to Section
3301(c) of the Divorce Code.
COUNT II - REQUEST FOR EQUITABLE DISTRIBUTION OF
MARITAL PROPERTY UNDER SECTION 3502(a) OF THE DIVORCE CODE
12. Paragraphs 1 through 11 of this Complaint are incorporated herein by reference
thereto.
13. The Plaintiff requests the Court to equitably divide, distribute or assign the marital
property between the parties without regard to marital misconduct in such proportion as the Court
deems just after consideration of all relevant factors.
WHEREFORE, Plaintiff, KYRA ANN SGRIGNOLI, respectfully requests the Court
to enter an order of equitable distribution of marital property pursuant to Section 3502(a) of the
Divorce Code.
COUNT III - REQUEST FOR SPOUSAL SUPPORT AND/OR ALIMONY
UNDER SECTIONS 3701(a) and 3702 OF THE DIVORCE CODE
14. Paragraphs 1 through 13 of this Complaint are incorporated herein by reference
thereto.
15. Plaintiff is unable to sustain herself during the course of litigation.
16. Plaintiff lacks sufficient property to provide for her reasonable needs and is
unable to sustain herself through appropriate employment.
17. Plaintiff requests the Court to enter an award of spousal support until final hearing
and thereupon to enter an order of alimony in her favor pursuant to Sections 3701(a) and 3702 of
the Divorce Code.
WHEREFORE, Plaintiff, KYRA ANN SGRIGNOLI, respectfully requests the Court
to enter an award of spousal support until final hearing and thereupon to enter an order of
alimony in her favor pursuant to Sections 3701(a) and 3702 of the Divorce Code.
COUNT IV - REQUEST FOR CONFIRMATION OF CUSTODY
UNDER SECTIONS 3104(a)(2) and 3323(b) OF THE DIVORCE CODE
18. Paragraphs 1 through 17 of this Complaint are incorporated herein by reference
thereto.
19. The parties are the parents of the following children who reside with the Plaintiff:
NAME
AGE
SEX
DATE OF BIRTH
CHRISTIAN TYLER SGRIGNOLI
13 Years
Male
July 5, 1989
TYLER JAMES SGRIGNOLI
9 Years
Male
August 10, 1993
20. During the past five (5) years the children have resided with the parties and at the
addresses herein indicated:
WITH WHOM
ADDRESS
FROM / TO
Plaintiff and Defendant
11 North Enola Drive
Enola, P A
1993 to December 27,2002
Plaintiff
424F Duke Street
Enola, P A
December 27, 2002 to Present
21. Plaintiff has not participated in any other litigation concerning the children in this
or any other state.
22. There are no other proceedings pending involving custody of the children in this
or any other state.
23. Plaintiff knows of no person not a party to these proceedings who has physical
custody of the children or who claims to have custody, partial custody or visitation rights with
respect to the children.
24. The best interests of the children will be served if Plaintiff has Full Legal Custody
and Primary Physical Custody with Defendant having Partial Physical Custody of their children.
WHEREFORE, Plaintiff, KYRA ANN SGRIGNOLI, respectfully requests that,
pursuant to Sections 3104(a)(2) and 3323(b) of the Divorce Code, the Court enter an order
confirming Full Legal Custody and Primary Physical Custody with Plaintiff, KYRA ANN
SGRIGNOLI, and Defendant, RODGER EUGENE SGRIGNOLI, JR., having Partial
Physical Custody of the parties' minor children, CHRISTIAN TYLER SGRIGNOLI and
TYLER JAMES SGRIGNOLI.
Respectfully submitted,
LAW FIRM OF SUSAN KAY CANDIELLO, P.c.
.......
Dated: Februar~, 2003
--Susan Kay Candi
Counsel for Plain !ff
PA I.D. # 64998
5021 East Trindle oad
Suite100
Mechanicsburg P A 17050
(717) 796-1930
VERIFICATION
The undersigned hereby verifies that the facts averred in the foregoing document are true
and correct to the best of her knowledge, information, and belief. This verification is made
subject to the penalties of 18 Pa. C.S.A. ~4904 relating to unsworn falsification to authorities.
DATED: :t/;)-5 /0")
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KYRA N SGRIGNOLI .
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KYRA ANN SGRIGNOLI
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
03-866
CIVIL ACTION LAW
RODGER EUGENE SGRIGNOLI, JR.
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Thursday, March 06, 2003
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq.
at 39 West Main Street, Mechanicsburg, P A 17055 on Thursday, March 27, 2003
, the conciliator,
at 8:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearin2.
FOR THE COURT,
By: Isl
Dawn S. Sunday, Esq.
Custody Conciliator
tLl
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with DisabiIites Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our office.
All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must
attend the scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATIORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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MAR 3 1 Z003 r
KYRA ANN SGRIGNOLI
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
vs.
03-866
CIVIL ACTION LAW
RODGER EUGENE SGRIGNOLI, JR
Defendant
IN CUSTODY
ORDER
AND NOW, this ~ day of March ,2003, the conciliator relinquishes jurisdiction
in this matter. The Father filed a custody complaint just prior to the Mother's filing of a divorce
complaint containing a custody count and the Father's petition was scheduled for conciliation before
Melissa Greevy, Esquire on April 7, 2003. Although the Father appeared for the conference scheduled
before the undersigned conciliator on March 27, 2003, neither the Mother nor her counsel attended.
The conciliator determined by telephone that it was the understanding of the Mother's counsel that the
Father had cancelled this conciliation conference so that the custody issues would be addressed at the
conference scheduled on the Father's petition. The Father is not represented by counsel. The Custody
Conciliation Conference scheduled for today, March 27, 2003 is cancelled.
FOR THE COURT,
Da~i:&;uf.: I
Custody Conciliator
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KYRA ANN SGRIGNOLI,
PLAINTIFF
vs.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
: NO. 03-866 CIVll.. TERM
RODGER EUGENE SGRIGNOLI, JR., : CIVll.. ACTION _ LAW
DEFENDANT : ACTION FOR DIVORCE / CUSTODY
PRAECIPE TO REINSTATE DIVORCE COMPLAINT
To the Prothonotary:
Plaintiff, KYRA ANN SGRIGNOLI, respectfully requests to have the divorce
complaint in the above identified divorce action reinstated.
Counsel for the Plaintiff has attempted to serve this divorce complaint upon the
Defendant through certified mail and through the use of a constable. The Defendant continues to
take every action possible to avoid service of this divorce complaint.
Counsel for the Plaintiff has provided the Cumberland County Sheriff's department with
a true copy of the divorce complaint in the instant case to be served upon the Defendant.
Respectfully submitted,
LAW FIRM OF SUSAN KAY CANDIELLO, P.e.
0,,,,, dr ,-> =3
. J
Susan y Candiello, E
Counsel for Plainttff
PAI.D. #64998
5021 East Trindle Road
Suite 100
Mechanicsburg P A 17050
(717) 796-1930
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KYRA ANN SGRlGNOLl,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
: NO. 03-866 CIVIL TERM
RODGER EUGENE SGRlGNOLl, JR., : CIVIL ACTION - LAW
DEFENDANT : ACTION FOR DIVORCE I CUSTODY
ACCEPTANCE OF SERVICE
TO THE PROTHONOTARY:
I hereby accept service of the Complaint for No-Fault Divorce Under Section 3301(c) of
the Divorce Code, in the above matter.
Respectfully submitted,
Dated: August ~ 2003
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IN THE COURT OF COMMON PLEAS,
CUMBERLAND COUNTY, PENNSYLVANIA,
KYRA A. SGRIGNOLl
Plaintiff
Docket Number: 03-866
RODGER E. SGRIGNOLl JR.
Defendant
Civil Action - Law
Action In Divorce/Custody
Vs.
DEFENDANT'S RESPONSE TO COMPLAINT FOR NO-
FAULT DIVORCE UNDER SECTION 330119 OF THE
DIVORCE CODE
COMES NOW, Defendant Rodger E. Sgrignoli .Jr., CPA makes the
following response to Defendants Complaint for No-Fault Divorce Under Section
3301 c of the Divorce Code.
1. Avers.
2. Avers.
3. Avers.
4. Avers.
5. Avers.
6. Avers.
7. No response.
8. Avers in part. And denied in part. Defendant '.vas never a member of
Naval Reserves.
9. Avers.
10. Responded in 1-9 above,
11.Avers
12. Responded in 1-11 above.
13. Avers
14. Responded in 1-13 above.
15. Denied.
16. Denied.
17. Denied Requested. Plaintiff left "married residence" therefore, alimony
should be denied.
18. Responded in 1-18 above.
19. Avers in part. And denied in part. The children still spend 50% of their
time with Defendant.
20. Same as 19.
21. Denied. Defendant has filed for custody, and is Plaintiff in case number
03-851.
22. Same as 21.
23. Avers
24. Denied. Plaintiff is bi-polar and continues to consume alcoholic beverages
around children against Judge Guido's orders. Photographs provided
under case number 03-851, Action for Custody, in motion filed August 14,
2203,1:35 P.M.
WHEREFORE, Defendant, Rodger E. Sgrignoli Jr., Certified Public
Accountant, respectfully request No-Fault Divorce Under Section 3301 c of
the divorce code.
Respectfully Submitted,
Rodg
Defen ant
PA I.D. # CA.-041353L
11 N Enola Drive
Enola, PA 17025
RSgrignoli@state.pa.us
CERTFICA TE OF SERVIC~
I, Rodger E. Sgrignoli Jr., Defendant certifies that €I copy of foregoing
DEFENDANT'S RESPONSE TO COMPLAINT FOR NO-FAULT DIVORCE
UNDER SECTION 3301 (C) OF THE DIVORCE CODE
was served this date by depositing same in the Post Office at Enola, PA, first
class mail, postage prepaid, addressed as follows:
Susan Kay Candiello, Esquire
5021 East Trindle Road
Suite 100
Mechanicsburg, PA 1705~5
Attorney for:
Ms. Kyra A. Sgrignoli
424F Duke Street
Enola, PA 17025
)
By ----
Rodger Sg oli Jlr., CPA
11 North Enola Drive
Enola, PA 17025
Dated: August 25, 2003
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IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY,
PENNSYLVANIA
KYRA A. SGRIGNOLl
Plaintiff
Docket Number 03-866
Vs.
CIVIL ACTION - LAW
ACTION FOR DIVORCE!
CUSTODY
RODGER E. SGRIGNOLl JR
Defendant
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under ~ 3301 (c) of the Divorce Code was filed on
February 25,2003.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety
days have elapsed from the date of filing of thel Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of
intention to request entry of the decree.
I verify that the statements made in this affidavit are true and correct. I
understand that false statements herein are made subject to the penalties
of 18Pa.C.S. ~ 4904 relating to unsworn falsification to authorities.
Dated: August 25, 2003
CERTFICATE OF SERVICE
I, Rodger E. Sgrignoli Jr., Defendant certifies that a c:opy offoregoing Affidavit
of Consent was served this date by depositing same in the Post Office at Enola,
PA, first class mail, postage prepaid, addressed as follows:
Susan Kay Candiello, EsquirEl
5021 East Trindle Road
Suite 100
Mechanicsburg, PA 17055
Attorney for:
Ms. Kyra A. Sgrignoli
424F Duke Street
Enola, PA 17025
-'
By
Rodger
11 Nort Eno Drive
Enola, PA 17025
Dated: August 25, 2003
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SHERIFF'S RETURN - NOT SERVED
CASE NO: 2003-00866 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SGRIGNOLI KYRA ANN
VS
SGRIGNOLI RODGER EUGENE JR
R. Thomas Kline
, Sheriff
, who being duly sworn
according to law, says, that he made a diligent search and inquiry for
the within named DEFENDANT
SGRIGNOLI RODGER EUGENE JR
, to wit:
unable to locate Him in his bailiwick. He therefore returns the
but was
COMPLAINT - DIVORCE
the within named DEFENDANT
11 NORTH ENOLA DRIVE
ENOLA, PA 17025
NOT SERVED , as to
, SGRIGNOLI RODGER EUGENE JR
SERVICE STOPPED PER FAX FROM ATTORNEY.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
.00
.00
10.00
.00
28.00
so~~ ~
R. Thomas ~~
Sheriff of Cumberland County
SUSAN CANDIELLO
08/15/2003
Sworn and subscribed to before me
this .21-"-"
day of ~
;lvv~ A.D.
C /''1''- Q 7h,;&~ I +~
Prothonotary
KYRA ANN SGRIGNOLI,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
VS.
NO. 03-866
CIVIL TERM
RODGER EUGENE SGRIGNOLI, JR.,
DEFENDANT
CIVIL ACTION - LAW
: ACTION FOR DIVORCE
PETITION FOR SPECIAL RELIEF
Plaintiff, KYRA ANN SGRIGNOLI, files this Petition for Special Relief, and in support
thereof, avers as follows:
1. Plaintiff is an adult individual residing at 424 F Duke Street, Enola PA 17025.
2. Defendant is an adult individual residing at 11 North Enola Drive, Enola, Cumberland
County, Pennsylvania, 17025, the parties' marital residence.
3. Plaintiff and Defendant were married on November 21,1987.
4. Plaintiff and Defendant separated on or about December 27, 2002.
5. Plaintiff filed a divorce action in Cumberland County on March 7, 2003.
6. Defendant refused and avoided service of the divorce complaint until, Defendant was
personally served a true copy of the Divorce Complaint and signed an Acceptance of Service on
August 14,2003. The original Acceptance of Service signed by the Defendant was filed with in
Cumberland County on August 15, 2003.
7. Defendant has chosen to represent himself in all court actions involving this divorce,
child support and child custody.
--
8, Plaintiff's counsel served the Defendant with First and Second sets ofInterrogatories
and a Request for Production of Documents on or about October 28,2003,
9, Plaintiff's counsel has requested information of and concerning marital assets both in
written correspondence and verbally from the Defendant on numerous occasions following the
formal written documents of October 28,2003,
10, Plaintiff's counsel again served the Defendant with the same First and Second Set of
Interrogatories and Request for Production of Documents on or about April 28, 2005,
11, Defendant has refused to provide any information at any time from any of the
Plaintiff's numerous requests with the exception of a few statements of the Defendant's debt.
12, Defendant has been physically abusive and threatening to the Plaintiff for the entire
marriage of the parties and any time the parties have had to have contact since the Plaintiff fled
the marital residence,
13, Defendant has made threatening statements to the Plaintiff's counseL
14, Plaintiff does not believe the Defendant will cooperate in any manner without the
court issuing an detailed and direct order for the Defendant to comply.
WHEREFORE, Plaintiff, KYRA ANN SGRlGNOLl, respectfully requests that this
Honorable Court Order the Defendant, ROGER EUGENE SGRlGNOLl, JR., to share with
Susan Kay Candiello, Esquire, Plaintiff's counsel, all accurate information of and concerning the
marital property necessary to reach an equitable division of marital property and to cooperate and
take such actions procedurally necessary to reach a marital property settlement agreement and
finalize the parties' divorce.
Respectfully submitted,
LAW FIRM OF SUSAN KAY CANDIELLO, p,c.
Dated: June _, 2005
usan Kay Candiell
Counselfor Pial iff
PA J.D. # 6499
5021 East Trind e-.R,<3ad
Mechanicsburg P A 17050
(717)796-1930
.
VERIFICATION
The undersigned hereby verifies that the facts averred in the foregoing docmnent are true
and correct to the best of her knowledge, information, and belief. This verification is made
subject to the penalties of 18 Pa. C.S.A. 94904 relating to unsworn falsification to authorities.
DATED:
~~5
f!.~,,:L A "'f~'r/J,
KYRA SGRIGNOLI
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KYRA ANN SGRIGNOLI,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
NO. 03-866
CIVIL TERM
RODGER EUGENE SGRIGNOLI, JR.,
DEFENDANT
CIVIL ACTION - LAW
ACTION FOR DIVORCE
RULE
AND NOW, this 1,3~ day of r ' 2005, upon consideration of the
within Petition for Special Relief, a Rule is hereby entered against Defendant, ROGER
EUGENE SGRIGNOLI, JR., to show cause why the relief requested should not be granted.
RULE is issued upon the Defendant to show cause why the Plaintiff is not entitled to the
relief requested. The Defendant shall file an answer to the petition within .)0 _ days of
this date.
RULE RETURNABLE with hearing thereon the
I ().~ b o'clock Pc .M. in Courtroom 5"
,sit- day of ~ ,2005,
, Cumberland County Courthouse, I
at
Courthouse Square, Carlisle, Pennsylvania, 17013-3387.
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KYRA ANN SGRIGNOLl,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
OF CUMBElRLAND COUNTY,
PENNSYLVANIA
vs.
NO. 03-866
CIVIL TERM
RODGER EUGENE SGRIGNOLl, JR.,
DEFENDANT
CIVIL ACTION - LAW
ACTION FOIl DIVORCE
PETITION FOR APPOINTMENT OF MASTER
AND NOW, comes the Plaintiff, Kyra Ann Sgrignoli, by and through her attorney, Susan Kay
Candiello, Esquire, of the Law Firm of Susan Kay Candiello, P.C., and moves the court to appoint a
master with respect to the following claims:
(X) Divorce
( ) Annulment
(X) Alimony
( ) Alimony Pendente Ute
(X) Distribution of Property
( ) Support
(X) Counsel Fees
(X) Costs and Expenses
and in support of the motion states:
1. Discovery is not complete as to the claims for which the appointment of a master is requested;
2. The Defendant has appeared in all court actions pro se;
3. The statutory grounds for the divorce are 3301(c) of the Divorce Code;
4. The action is contested with respect to the following claims:
(a) Distribution of property;
(b) Alimony,
( c) Costs and Expenses,
(d) Counsel Fees.
5. The action does not involve complex issues of law or fact; and
6. The hearing is expected to take one-half (1/2) day.
Respectfully submitted,
Dated: July (f:;: , 2005
LAW FIRM OF S SAN KAY CANDIELLO, P.C.
~~
Susan Kay eel Esquire
Counsel for ainti
PA J.D. # 649-./
5021 East Trindle Road, Suite 100
Mechanicsburg P A 17050
(717)796-1930
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IN THE COURT OF COMMON
PLEAS, CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff,
Case No.: No. 03-866 CIVIL TERM
DEFEN[)ANT'S PETITION FOR
SPECIAL RELIEF
CIVIL ACTION - LAW
ACTION FOR DIVORCE
JUDGE GUIDO
KYRA ANN SGRIGNOLI,
VS.
RODGER EUGENE SGRIGNOLl JR.,
Defendant
Defendant, RODGER EUGENE SGRIGNOLl JR, files this Petition for
Special Relief, and in support thereof, avers as follows:
1. Defendant is an adult individual residing at 11 North Enola Drive,
Enola, Cumberland County, Pennsylvania, 1 :ro25.
2. Plaintiff is an adult individual residing at 424 F Duke Street, Enola,
Cumberland County, Pennsylvania.
3. Plaintiff and Defendant were married on November 21, 1987.
4. Plaintiff left the marital resident on her on accord on or about
December 27,2002.
5. Plaintiff returned to the marital residence on or about January 2, 2003
for sexual favors.
6. Defendant served Plaintiff's counsel with Interrogatories and Request
for Production of Documents on or about January 7,2004.
7. Plaintiff verbal asserts that she completed said Interrogatories.
8. Plaintiff's counsel has refused to provide Defendant with said
Interrogatories/Documents.
9. Plaintiff's counsel has made inappropriate sexual comments about
Defendant.
10. Defendant does not believe the Plaintiff/Plaintiff's Counsel will
cooperate in any manner without the court issuing a detailed and direct
order for the Plaintiff to comply.
WHEREFORE, Defendant, Rodger Eugene Sgrignoli Jr., respectfully
request this honorable court order Plaintiff, Kyra Ann Sgrignoli to share with
Defendant, Rodger Eugene Sgrignoli Jr., license celrtified public accountant,
all accurate information of and concerning the martial property necessary to
reach an equitable division of marital property and to order Plaintiff and her
attorney Susan Candiello, to cooperate and take such action within rules of civil
procedure necessary to reach a marital property settlement agreement and
finalize the divorce, and any other relief the court deems just and proper.
Dated this 15th y f July, 2005
L
Rod er E. Sgrignoli Jr.
11 N Enola Drive
Enola, PA 17025
RSQriQnoli@state.pa.us
VERIFICATION
The undersigned herby verifies that the facts averred in the foregoing
documents are true and correct to the best of his knowledge, information, and
belief. This verification is made subject to the penaltiEis of 18 Pa. C.SA 94904
relating to unsworn falsification to authorities.
Dated: July 15, 2005
~1
Rodger E. S~lrignoli Jr., CPA
KYRA ANN SGRIGNOLI,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 03-866 CIVIL TERM
RODGER E. SGRIGNOLI, JR.
Defendant
CIVIL ACTION - LAW
ACTION FOR DIVORCE
ORDER OF COURT
AND NOW, this 15th day of July, 2005, the
Defendant is directed to provide respo::lses to the answers to
interrogatories and request for production of documents to
Plaintiff's counsel immediately.
Susan K. Candiello, Esquire
For the Plaintiff
)
U-l'A.<-6 ,~ 7. lS:o~
c,L.
Rodger E. Sgrignoli, Jr., Esquire
11 North Enola Drive
Enola, PA 17025
Defendant, Pro se
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KYRA ANN SGRIGNOLl,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
VS.
: NO. 03-866
CIVIL TERM
RODGER EUGENE SGRIGNOLI, JR., : CIVIL ACTION - LAW
DEFENDANT : ACTION FOR DIVORCE
INCOME AND EXPENSE STATEMENT OF
KYRA ANN SGRIGNOLI
Plaintiff, Kyra Ann Sgrignoli, files the following Income and Expense Statement and
verifies the statements made herein are true and correct. Plaintiff understands any false
statements herein are made subject to the penalties of 18 Pa.C.S. g4904 relating to unsworn
falsification to authorities.
~ Ave, 4fc tv<?
K NN SGRIGNOLI V
INCOME:
Employer: Lenscrafters Inc.
Address: 4000 Luxottica Place, Mason, Ohio 45040
Type of Work: Apprentice Optician
Payroll Number: 77219329
Pay Period: Bi-weekly
Gross Pay Per Pay Period:
Itemized Payroll Deductions:
Federal Withholding:
Social Security (FICA):
State Income Tax:
Local Income Tax:
Pa Camp Hill OPT EM
P A Unemp10y EE
Medicare:
Retirement:
Savings Bonds:
Credit Union:
Life Insurance:
$ 1042.26
48.84
64.62
32.00
10.42
10.00
.94
15.!1
Health Insurance:
Tax Deferred Comp:
Fair Share Fee:
Short Term Disability:
TOTAL:
OTHER INCOME (MONTHLY):
Employment:
Interest:
Dividends:
Pensions:
Annuity:
Federal Withholding:
Savings Bonds:
Life Insurance:
Credit Union:
Social Security:
Rents:
Royalties:
Expense Account:
Gifts:
Unemployment Compensation:
Workmen's Compensation:
Support: (child)
TOTAL MONTHLY INCOME:
EXPENSES (MONTHLY):
HOME:
Mortgage:
Rent:
Utilities:
Electric:
Gas:
Oil:
Telephone:
Water/Sewer/Garbage
Cell Phone:
$ 1736.66
$ 960.00
$ 2696.66
$ 600.00
165.00
50.00
50.00
EMPLOYMENT EXPENSES:
Transportation:
Lunches:
100.00
TAXES:
School:
Real Estate:
Harrisburg City:
Personal:
Income:
INSURANCE:
Homeowners/Rental:
Automobile:
Life:
Accident:
Health:
$ 54.00
AUTOMOBILE:
Payments:
Fuel:
Repairs:
Maintenance:
Licenses/Registration
350.00
200.00
25.00
25.00
36.00/ annually
MEDICAL:
Doctor:
Dentist:
Hospital:
Medicine/Prescription Drugs: 50.00
(Mr. Sgrignoli refuses to pay his portion of the unpaid medical bills for the children.)
50.00
35.00
PERSONAL:
Clothing:
Food:
Barber/Hairdresser:
Laundry/Dry cleaning:
Memberships:
Bank Charges:
Credit Card Payments:
Support:
200.00
400.00
25.00
100.00
MISCELLANEOUS:
Papers/Books/Magazines: 18.00
Entertainment: 250.00
(Approximately $200.00 of this is for Christopher to play paint baiL)
Legal Fees: 150.00
TOTAL EXPENSES:
$ 2900.00
Total Monthly Income:
$ 26%.66
Total Monthly Expenses
$ 2900.00
Total Monthly Shortfall
$ 203.34
Respectfully submitted,
LAW FIRM OF SUSAN KAY CANDIELLO, P.c.
Dated: July &-, 2005
Ie 0, Esquire
Counsel fa Plain iJl
PA!.D. # 6 Q28
5021 East Trindle Road
Suite 100
Mechanicsburg, PA 17050
(717) 796-1930
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KYRA ANN SGRIGNOLI,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
VS.
: NO. 03-866
CIVIL TERM
RODGER EUGENE SGRIGNOLI, JR, : CIVIL ACTION - LAW
DEFENDANT : ACTION FOR DIVORCE
INVENTORY AND APPRAISEMENT FOR
KYRA ANN SGRIGNOLI
Plaintiff, Kyra Ann Sgrignoli, files the following Inventory and Appraisement of all
property owned or possessed by either party at the time this action was commenced and all
property transferred within the preceding three (3) years.
Plaintiff, Kyra Ann Sgrignoli, verifies the statements made herein are true and correct.
Plaintiff understands any false statements herein are made subject to the penalties of 18 Pa.C.S.
94904 relating to unsworn falsification to authorities.
~~'
SGR GNOLI
ASSETS OF PARTIES
Plaintiff marks on the list below those items applicable to the case at bar and itemizes the
assets on the following pages. If an item has been appraised, a copy of the appraisal report is
attached.
(X) I. Real property
(X) 2. Motor vehicle(s), Boat
(X) 3. Stocks, Bonds, Securities and Options
() 4. Certificates of deposit
(X) 5. Checking accounts, cash
(X) 6. Savings accounts, money market and saving c,ertificates
() 7. Contents of safe deposit boxes)
() 8. Trusts
(X) 9. Life insurance policies, (indicated face value, I~ash surrender value and current
beneficiaries)
() 10. Annuities
() 11. Gifts
() 12. Inheritance
() 13. Patents, Copyrights, Inventions and Royalties
() 14. Personal property outside the house
() 15. Businesses (list all owners, including the percentage of ownership, and
officer/director positions held by a party with the company)
() 16. Employment termination benefits (severan(:e pay, workman's compensation
claim/award)
(X) 17. Profit sharing plans (only 50% vested at time of separation)
(X) 18. Pension plans (indicate employee contribution and date plan vests)
(X) 19. Retirement plans, Individual Retirement Accounts
(X) 20. Disability payments
() 21. Litigation claims (matured and unmatured)
(X) 22. MilitaryN.A. benefits
() 23. Education benefits
() 24. Debts due, including loans, mortgages held
(X) 25. Household furnishings and personal (include as a total category and attach
itemized list if distribution of such assets is in dispute)
() 26. Other: Disability Settlement
LIABILITIES OF PARTIES
Plaintiff marks on the list below those items applicable to the case at bar and itemizes the
liabilities on the following page:
SECURED:
(X) 1. Mortgages
() 2. Judgements
() 3. Liens
() 4. Other secured liabilities
UNSECURED:
(X) I. Credit card balances
() 2. Purchases
(X) 3. Loan payments
() 4. Notes payable
() 5. Other unsecured liabilities
"
CONTINGENT OR DEFERRED:
() 1. Contracts or Agreements
() 2, Promissory notes
() 3. Lawsuits
() 4. Options
() 5. Taxes
() 6. Other contingent or deferred liabilities
Respectfully submitted,
LAW FIRM OF SUSAN KAY CANDlliLLO, P.C.
F
Dated: July k.., 2005
~
Susan Kay Can
Counsel for PI intiff
PA J.D. # 649~8 /
5021 East Trindre1toad
Suite 100
Mechanicsburg P A 17050
(717) 796-1930
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KYRA ANN SGRIGNOLI,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYL V AN][A
vs.
: NO. 03-866
CIVIL TERM
RODGER EUGENE SGRIGNOLI, JR., : CIVIL ACTION - LAW
DEFENDANT : ACTION FOR DIVORCE
ORDER APPOINTING MASTER
AND NOW, ilii, IV'" d" of f Jr, , 20OS, """ '"~id="oo of dre
attached Petition for Appointment of Mast , It IS hereby Ordered and Directed that
2~ rLJ&-u
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, Esquire, is appointed master with respect to the following
claims:
By the Court:
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RECEIVED JUL 18 Z005
r
IN THE COURT OF COMMON
PLEAS, CUMBERLAND COUNTY,
PENNSYLVANIA
KYRA ANN SGRIGNOLl,
Case NOI.: No. 03-866 CIVIL TERM
Plaintiff,
CIVIL ACTION - LAW
ACTION FOR DIVORCE
JUDGE GUIDO
vs.
RODGER EUGENE SGRIGNOLl JR.,
Defendant
RULE
AND NOW, this '). b(V day of ~_, 2005, upon
consideration of the within Petition for Special Relief, a Rule is hereby entered
against Plaintiff, KYRA ANN SGRIGNOLl, to show caLise why the relief
requested should not be granted.
RULE is issued upon Plaintiff to show cause why Defendant is not entitled
to relief requested. Plaintiff shall file an answer to the petition within r:9- 0
days of this date.
A:ULES RIii:r'I~t.J4RI F with hearina thereon the
day of
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RECEIVED JUL 18 1nn5pf'
IN THE COURT OF COMMON
PLEAS, CUMBERLAND COUNTY,
PENNSYLVANIA
KYRA ANN SGRIGNOLl,
Case No.: No. 03-866 CIVIL TERM
Plaintiff,
CIVIL ACTION - LAW
ACTION FOR DIVORCE
JUDGE GUIDO
vs.
RODGER EUGENE SGRIGNOLl JR.,
Defendant
ORDER
AND NOW, this
day of
, 2005, upon
consideration of Defendant's Petition for Special Relief, it is hereby ORDERED
and DECREED that Plaintiff, KYRA ANN SGRIGNOLI, shall share with
Defendant all accurate information of an concerning the marital property
necessary to reach an equitable division of marital property and shall cooperate
and take such actions procedurally necessary to reach a marital property
settlement agreement and finalize the parties' divorce.
BY THE COURT:
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IN THE COURT OF COMMON
PLEAS, CUMBERLAND COUNTY,
PENNSYLVANIA
Case No.: No. 03-866 CIVIL TERM
KYRA ANN SGRIGNOLI,
Plaintiff,
CIVIL ACTION - LAW
ACTION FOR DIVORCE
JUDGE GUIDO
vs.
RODGER EUGENE SGRIGNOLl JR.,
Defendant
RULE
AND NOW, thiS;' b~ day of ~ ' 2005, upon
consideration of the within Petition for Special Relief, a Rule is hereby entered
against Plaintiff, KYRA ANN SGRIGNOLl, to show cause why the relief
requested should not be granted.
RULE is issued upon Plaintiff to show cause why Defendant is not entitled
to relief requested. Plaintiff shall file an answer to the petition within ~ 0
days of this date.
l\tILES RIi!TIIRI\IARI E with hearina thereon the
day of
2096, al
u'docK.
Mill GUUIlIuvlII
, CUl'llberlsAeI C9b1nty
COUI !I,UU>>~, I (,ourmouse :square, Carlisle, (>A I 7151 ~.
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6 ORIG
IN THE COURT OF COMMON PLEAS,
CUMBERLAND COUNTY, PENNSYLVANIA
Judge GUIDO
KYRA ANN SGRIGNOLI,
Plaintiff,
Case No.: No. 03-666 CIVIL TERM
vs.
RODGER EUGENE SGRIGNOLI JR.,
CIVIL ACTION - LAW
ACTION FOR DIVORCE
Defendant
INCOME AND EXPENSE STATEMENT OF
RODGER EUGENE SGRIGNOLI JR.
Defendant, Rodger Eugene Sgrignoli Jr. files the following
Income and Expense Statement and verifies the statements made
herein are true and correct. Defendant understand any false
statements herein are made subject to the penalties of
18 Pa.C.S.~ 4904 relating to unsworn falsification to
authorities.
Oote oJU/()S
/
Rodger Eugene Sgrignoli Jr. CPA
INCOME:
Employer: PA Dept. of Revenue
Address: 1846 Brookwood St, Hbg, PA 17104
DEFENDANT'S INCOME & EXPENSE STATEMENT - 1
Type of Work: State Tax Auditing
Payroll Number: 454304
Pay Period: Bi-Weekly
Gross: $1,747.50
Itemized
Payroll
Deductions:
Federal $125.67
Withhoiding
Social Security $108.34
Locai Income $27.96
Tax
State Income $53.65
Tax
Hbg OPT $52.00
PAUC EE $1.57
Medicare $25.34
Union Dues $17.13
Alimony/Support $480.00
Retirement $109.22
Total $1,000.88
Deductions:
Net Pay Per $746.62
Pay Period:
DEFENDANT'S INCOME & EXPENSE STATEMENT - 2
TOTAL
MONTHLY
INCOME:
EXPENSES
(MONTHLY)
HOME:
Net Pay Per
Month:
Other
Income:
Mortgage:
Utilities:
Per Month
VA Disability
Electric:
Water:
Gas:
Sewer/Garbage:
Telephone:
Cable:
Maintenance
$200.00
$813.51
$125.00
$25.00
$75.00
$39.00
$50.00
$50.00
$150.00
DEFENDANT'S INCOME & EXPENSE STATEMENT - 3
$1,493.24
$1,693.24
EMPLOYMENT:
INSURANCE:
AUTOMOBilE:
MEDICAL:
PERSONAL:
lunches:
$100.00
Automobile:
$52.00
Payments:
Fuel:
$419.61
$240.00
$25.00
$25.00
Repairs:
Malnt:
Licences!
Registration
$3.00
Doctor:
Dentist:
Medicine:
Optometrist:
$20.00
$15.00
$20.00
$20.00
Clothing:
Food:
$100.00
$300.00
DEFENDANT'S INCOME & EXPENSE STATEMENT - 4
MEMBER-
SHIPS:
MISC.:
TOTAL
EXPENSES
Barber:
Laundry/Dry
Cleaning:
YMCA
Papers/
Books/Mag.
Entertain.:
Legal Fees:
$15.00
$40.00
$48.00
$21.00
$100.00
$150.00
TOTAL
MONTHLY
INCOME:
DEFENDANT'S INCOME & EXPENSE STATEMENT - 5
$3,041.12
$1,693.24
TOTAL
$3,041.12
MONTHLY
EXPENSES:
TOTAL
$1,347.88
MONTHLY
SHORTFALL:
Respectfully Submitted,
LAW FIRM OF DIANE RADCLIFF, P.C.
. CC" R cl~eq"i3 ~
Counsel for Defendant
PA I. D. # XXXXX
3448 Trindle Road
Camp Hill, PA 17011
(717) 737-0100
DEFENDANT'S INCOME & EXPENSE STATEMENT - 6
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
KYRA ANN SGRIGNOll,
Plaintiff
NO. 03-866 CIVIL TERM
V.
CIVIL ACTION - LAW
RODGER EUGENE SGRIGNOll, JR,
Defendant
IN DIVORCE
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY OF THE SAID COURT:
Enter my appearance on behalf of Defendant, Rodger Eugene Sgrignoli, Jr.
Papers may be served at the address set forth below:
Diane G. Radcliff, Esquire
3448 Trindle Road
Camp Hill, PA 17011
(717) 737-0100
Date: August 29, 2005
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KYRA ANN SGRIGNOLl1
Plaintiff NO. 03-866 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
V.
RODGER EUGENE SGRIGNOLl, JR,
Defendant
INVENTORY OF RODGER EUGENE SGRIGNOLl. JR
Defendant files the following inventory of all property owned or possessed by either party at the time
this action was commenced and all property transferred within the preceding three years.
Defendant verifies that the statements made in this inventory are true and correct. Defendant
understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating
to unsworn falsification to authorities.
~~oad
Camp Hill, PA 17011
Phone: (717) 737-0100
Supreme Court ID ~21 ~
Dated: -$ /7 () ')
I I
ASSETS AND LIABILITIES OF PARTIES
Defendant marks on the list below those items applicable to the case at bar and itemizes the assets and
debts on the following pages:
(X) 1.
(X) 2.
(X) 3.
() 4.
(X) 5.
(X) 6.
o 7.
() 8.
o 9.
o 10.
() 11.
o 12.
() 13.
() 14.
() 15.
o 16.
o 17.
( ) 18.
(X) 19.
() 20.
o 21.
() 22.
() 23.
() 24.
(X) 25.
() 26.
(X) 27.
Real Property and Real Estate Mortgages
Motor Vehicles and Vehicle Liens
Stocks, Bonds, Securities and Options
Certificates of Deposit
Checking Accounts, Cash
Savings Accounts, Money Market and Savings Certificates
Contents of Safe Deposit Boxes
Trusts
Life Insurance Policies
Annuities
Gifts
Inheritances
Patents, Copyrights, Inventions, Royalties
Personal Property Outside the Home
Business
Employment Termination Benefits-Severance Pay, Worker's Compensation
Profit Sharing Plans
Pension Plans (indicate employee contribution and date plan vests)
Retirement Plans, Individual Retirement Accounts
Disability Payments
Litigation Claims (matured and unmatured)
MilitaryN.A. Benefits
Education Benefits
Debts Due, including loans, mortgages held
Household Furnishings and Personalty
Other Assets
Loans, Credit Cards and Other Debts
-2-
INFORMATIONAL NOTES AND CODES
l.
2.
3.
4.
5.
",f" denotes that the entry (value) is verified by a document.
"*" denotes documents/information to be supplied by the designated party.
"." denotes an item about which a decision is required.
"NM" denotes non-marital property not subject to equitable distribution.
The values used in the various Tables herein may, in some cases, be based on estimated values. Those
estimated values are subject to adjustment upon appraisal or otherwise.
Any adjustment figures used in the various tables herein are for illustration purposes only and are not
to oe deemed a representation on the part of the Defendant as to whether an adjustment should be made
or the amount ofthe adjustment, if any is appropriate.
6.
-3-
SECTION I.
BACKGROUND INFORMATION
The following Table #1 sets forth the backgrolmd information relevant to this case:
TABLE #1-A
PARTIES
, :2,"" WIFE
..... ..
Name Rodger Eugene Sgrignoli, Jr Kyra Ann Sgrignoli
Maiden Name -- VanHoose
Address II North Enola Drive 424 F. Duke Street
Enola, P A 17025 Enola, P A 17025
Home Phone --
Cell Phone No. 421-4941
Work Phone No. 346-1024
E-mail rsgrignoli@state.pa.us
Date of Birth 5/28/1962 1112111960
Age 43 44
Place of Birth Harrisburg, P A Paintsville, KY
Race Caucasian Caucasian
Health Status Good Good
EducauonalBackground BS 3+ yrs. College
Names and Relationship of Persons None None Known
Living with Party
Date Party Moved to Current 5/1996 12/27/2002
Residence
Date PA Residency Began Since Birth 2/1992
Current Military Service N/A N/A
Employer's P A Dept. Of Revenue Lenscrafters
Name and Address
Occupation (Job Position) Tax auditor Optician
Date Employment Commenced 5/1995 1999-2000
Est. Annual Income $45,422 salary + $2,400 $27,092
military disability
-4-
TABLE #l-B
MARRIAGE INFORMATION
...... "" .... \
i '"Vl~.
Date of Marriage 11/21/1987
Place of Marriage Enola, PA
Date of Separation 12/27/02
Grounds for Divorce No Fault
Prior Divorce Actions Between Parties None
Number of this Marriage for Wife 2
Number of this Marriage for Husband I
TABLE #l-C
CHILDREN OF THIS MARRIAGE
Christian T. Sgrignoli
Tyler J. Sgrignoli
16
12
7/5/1989
8/10/1993
Wife
Wife
TABLE #l-D
SUPPORT FOR THIS MARRIAGE
......... ',>: "
"... ~"",." ...... ~~...."'1"\
Name of Party Paying Support Husband
Beneficiaries of Support 2 Children and Wife
Amount of Support $1,013/mo
Allocation $200 for wife $406.50 each child
Agreement or Order Order
Date of Agreement or Order 4/13/04
Effective Date of Order 3/15/04
Docket Number of Support Order 873 S 2002; Pacses #876104896
Comments: Due to changes in income and refusal of wife to give
husband aependency exemptions for children,
husband has requested a review ofthe support order.
-5-
Wife
TABLE #l-E
PRIOR MARRIAGES
1
1985?
Divorce
TABLE #l-F
CHILDREN OF OTHER RELATIONSHIPS/MARRlAGES
CUSTODIAN OR
EMANCIPATION
N/A N/A N/A N/A N/A
TABLE #l-G
SUPPORT/ALIMONY FOR PRIOR MARRIAGESIRELATlONSHIP
....... ...... ~.~"~ .. <
~~",," ~""lI.1
Name of Party Paying Support N/A N/A
Beneficiaries of Support N/A N/A
Allocation N/A N/A
Agreement or Order N/A N/A
Date of Agreement or Order N/A N/A
Docket Number of Support Order N/A N/A
Comments: N/A N/A
-6-
TABLE #l-H
PROCEEDINGS INFORMA nON:
.... ,,~ ......
<
Complaint Filing Date 2/26/03
Date of Service
Manner of Service
Type of Divorce Requested 3301 (c) No Fault
Economic Claims Raised Equitable Distribution;
Alimony; Custody
~S~B:,(J()tJNTJi;~(JJZ.A.fl\.f~t()~()1'lJ:1!lR~JZ~.A.l\)I~~~I~lNGEJC()~()MJCCLAI1\fS
Type of Pleading
Pleading Filing Date
Type of Divorce Requested
Economic Claims Raised
~.
Plaintiff's I&E Statement Filing Date 7/15/05
Defendant's I&E Statement Filing Date 8/26/05
~..."'.
1"v. J:lia 1 .....
Plaintiff's Inventory Filing Date 7/15/05
Defendant's Inventory Filing Date 9/l2/05?
. .........,"111...., .... To ".\". i< .......
Plaintiff's 3301(c) Affidavit Date
Plaintiff's 3301(c) Affidavit Filing Date
Defendant's 3301(c) Affidavit Date 8/25/03
Defendant's 3301(c) Affidavit Filing Date 8/25/03
Plaintiff's 3301(c) Waiver of Notice Date
Plaintiff's 3301(c) Waiver Filing Date
Defendant's 3301(c) Waiver of Notice Date
Defendant's 3301(c) Waiver Filing Date
-7-
TABLE #l-H
PROCEEDINGS INFORMATION:
::':Slll. ~ l.~"
Date of In House Separation --
Date of Physical Separation 12/27/02
In House 2 Year Separation Date --
Physical2 Year Separation Date 12/27/04
Plaintiff's 3301(d) Affidavit Date N/A
Plaintiff's 3301(d) Affidavit Date Filing Date N/A
3301 (D) Affidavit Service Date N/A
Manner of Service of3301(d) Affidavit N/A
Date of Plaintiff's Notice of Intent to Request Entry of Divorce Decree and NIA
Praecipe to Transmit Record
Plaintiff's Notice to Request Entry of Divorce Decree and Praecipe to N/A
Transmit Record Service Date
Manner of Service of Plaintiff's Notice to Request Entry of Divorce Decree N/A
and 3301(d) Counter-Affidavit
.... ....
.",~r
Has the case been bifurcated? No
Date of decree granting bifurcation N/A
If bifurcation granted by consent or after hearing NIA
......
r~
Issue #1 Resolution
Issue #2 Resolution
-8-
Kyra A, Sgrignoli vs, Rodger E. Sgrignoli, Jr
DOM: 11/21/1987
DOS (Physical): 12/27/02
EST. INCOME: Husband@$45,422; Wife@ $27,092
Date Prepared: August 30, 2005
SECTION II.
MARITAL ASSETS AND DEBTS
The following Table #2 sets forth the listing of the marital assets and dehts ofthe parties:
TAEllE#2
MARITAL. AS$ETSAND DEBTS
A B C D E F G H I J K L
Ln B,# Description DIAN Gross Net Value Proposed Proposed H% W% H Adjust W Adjust
No Value Husband Wife
.
5 RE-l 11 North Enola Dr Est 90,000 90.000 90.000 50% 50% 0 45.000
Enola, PA 17025 Value?
6 RE-1 Washington Mutual Est (l?,625) (77.625) (77.625) 50% 50% 0 (38,813)
#0263 DOS.f
7 RE-l Sales Cost @7% Est (6,300) (6.300) (6,300) 50% 50% 0 (3,150)
8 RE-1 Net Equity Est 6,075 /// V// ~//~ '/~ ,// '/// V//
9 .. Comm~nts:
*9,9,05taxassessmentvaIUe @$82,08o.f I
*,6,15.05 mtg.@$68,506,19.f
\
,
11 V-I Jt 2000 Chevy Value TSD TBD TBD 50% 50% 0 0
Cavalier (W's use)
12 V-I GMAC loan Value TSD TBD TBD 50% 50% 0 0
13 V-I Net Equity 0 V// '//~ '/// '// // /// //7
~
16 INV-1 H's US Saving Est 600 600 600 50% 50% 0 300
Bonds Value
17 .. Comm~nts: * Husband to supply proolof bonds acquired up to da.te of separation.
!, ,
,
19 A-I H's PSECU Share Value TSD TBD TBD TBD 50% 50% 0 0
20 A-I H's PSECU Draft Value TSD TBD TBD TBD 50% 50% 0 0
21 A-I Net Equity o ///V//I/// '// // r/// ///
22 .. Comments: * Husband to suppiystatementof account as. 0100$(12/27/02}
23 A-2 W's Waypoint Value TSD TBD TBD TBD 50% 50% 0 0
24 A-2 W's Waypoint Value? TSD TBD TBD TBD 50% 50% 0 0
25 A-2 Net Equity 0 /// ///" '/// '// // 1/// V/7
26 .. Comm~nts: * Wife to suppiystatement olaccount as. of 00$(12/27/02)
-9-
A
Kyra A. Sgrignoli vs. Rodger E. Sgrignoli, Jr
DOM: 11/21/1987
DOS (Physical): 12/27/02
EST. INCOME: Husband @ $45,422; Wife @ $27,092
Date Prepared: August 30, 2005
TABLE #2
MARITAL ASSETS AND DEBTS
B
B.#
c
D
DIAN
E
Description
F
Net Value
H
J K L
H % W% H Adjust W Adjust
HG-2
H's Personalty In
H's Possession
Comments: . Parties to determine If current as is division is acceptable to them
W's Personalty In Value? TBO TSO TSO
W's Possession
Comments: . Parties to determine If current as Is division Is acceptable to them
G
29
30 Ret-2
31
34
35
36
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
D-2
D-3
D-4
Comments:
H's T-Mobile V S
Wireless #6614
COmments:
H's CTSI #6235
Comments:
H's A T& T Wireless Est.
Value
Comment$: * Husband to supply DOS statement for this accounl.
H's Chase Auto DOS-f (390) (390) (390)
#1647
Comments: *8.12.03 SeWement Letter@$3f1.80.f
H's GMAC #7782 DOS-f (5,536) (5,536)
Comments:
H's Sank One
comments:
D-5
DOS-f
(131)
(131)
D-6
D-7
D-8
D-9
-10-
o
o
(4,606)
(2,671)
(66)
59
(445)
(195)
(2,768)
(467)
A B C D E F G H J K L
Ln B.# Description D/AN Gross Nel Value Proposed Proposed H% W% H Adjust W Adjust
No Value Husband Wife
56 0-10 H's East Penn SD 2.16.99f (8,041) (8,041) (8,041) 50% 50% 0 (4,021)
57 CQIl!lnents: JUdgmentfarlegel!ees
TABLE #2
MARITAL ASSETS AND DEBTS
Overall Adjustment for SO/50
Overall Adjustment for 40/55
Overall Adjustment for 40/60
-11-
SECTION III.
LISTING OF HOUSEHOLD GOODS AND CONTENTS
AND OTHER PERSONAL PROPERTY
The following Tables #3-A and # 3-B set forth the household goods and contents and other personal
property oftlle parties: " 2
*****Defendant believes that the current division of household goods and furnishings is acceptable to the
parties. Therefore, Tables 3-A and 3-B have not been completed.
TABLE #3-A
HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY
IN HUSBAND'S POSSESSION
NO. DESCRIPTION OWNER POSSESSOR VALUE VALUE BASIS FOR EXCLUSION
DATE IF NON- MARITAL
N/A H&W Husband
-- Comments:
H&W Husband
-- Comments:
TOTAL HUSBAND'S POSSESSION N/A
TABLE #3-B
HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY
IN WIFE'S POSSESSION
NO. DESCRIPTION OWNER POSSESSOR VALUE VALUE BASIS FOR EXCLUSION
DATE IF NON- MARITAL
N/A H&W Wife
-- Comments:
H&W Wife
-- Comments:
TOTAL. WIFE'S POSSESSION N/A
Note: Exclusions from marital property include property acquired before marriage, property acquired after separation,
or property acquired during marriage by way of gift or inheritance from third party not a spouse. For gifts aud
inheritance also specify the source person.
2
The value of each item bas been estimated by Defendant unless otherwsise noted.
-12-
SECTION IV.
NON-MARITAL ASSETS AND DEBTS
The following Table #4 sets forth the non-marital assets and debts ofthe parties: 3,4
*****Defendant believes the information in Table #4 is not relevant. If determined to be relevant in the
future this table will be completed.
TABLE #4
NON-MARITAL PROPERTY AND DEBTS
NO. DESCRIPTION OWNER POSSESSOR VALUE VALUE BASIS FOR EXCLUSION
DATE IF NON-MARlT AL
TBD ifrelevant H&W
-- Comments:
H&W
-- Comments:
H&W
-- Comments:
H&W
-- Comments:
H&W
-- Comments:
H&W
-- Comments:
'Note: Exclusions from marital property include property acquired before marriage, property
acquired after separation, or property acquired during marriage by way of gift or inheritance from third
party not a spouse. For gifts and inheritance also specify the source person.
'The value of each item has been estimated by Defendant unless otherwise noted.
-13-
SECTION V.
PROPERTY TRANSFERRED
The following Table #5 is Defendant's listing of all property which was transferred within 3 years of the
date of the commencement of this action or was transferred since the date of separation:
..... At present Defendant is not aware of any marital property that was transferred and therefore table #5 has not
been completed. Defendant reserves the right to complete table #5 at a later date if contrary information is received.
TABLE #5
PROPERTY TRANSFERRED
NO. DESCRIPTION OF PROPERTY TRANSFER CONSIDERATION TRANSFEROR TRANSFEREE
DATE
None Known
-- Comments:
-- Comments:
-- Comments:
-- Comments:
-- Comments:
-14-
CERTIFICATE OF SERVICE
I, Diane G. Radcliff, Esquire, hereby certify that on g
within Inventory, by mailing same by first class mail, postage
, I served a copy of the
d, addressed as follows:
Susan K, Candiello, Esquire
5021 East Trindle Road. Suite 100
Mechanicsburg, PA 17050
~
448 T. e Road
Camp Hill, PA 17011
Supreme Court ill # 32112
Phone: (717) 737-01 00
Fax: (717) 975-0697
Attorney for Defendant
-15-
(~
r","
..-;-)
"
~(1.
.^~
~"'-,
c~<
i:'t;t
~~~
(,...:;
-~"\
c)
~
~)
-
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KYRA ANN SGRIGNOLl,
Plaintiff NO. 03-866 CIVIL TERM
V.
RODGER EUGENE SGRIGNOLl, JR,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
DEFENDANT'S PRE-TRIAL STATEMENT
Defendant, Rodger Eugene Sgrignoli, Jr., by his attorney, Diane G. Radcliff, Esquire files this Pre-Trial
Statement.
TABLE OF CONTENTS
SECTIO DESCRIPTION PAGE
N
- Informational Notes, Codes and Rules 2
I. Background Information 4
II. Listing of Marital Assets and Debts 9
III. Listing of Personal Property 11
N. Listing of Non-Marital Assets and Debts 12
V. Pensions 13
VI. Incomes and Expenses 14
VII. Counsel Fees and Costs 18
VIII. Expert Witnesses 19
IX. Other Witnesses 19
X. Proposed Resolution 20
XI. Listing of Proposed Exhibits 21
XII Proposed Exhibits Supplement
Respectfully Submitted,
DATED: November 7.2005
I
G.
448 Trindle oad
C~m!l nrtt;1' A 17011
Phone: (717) 737-0100
Fax: (717) 975-0697
Supreme Court ill # 32112
Attorney for Defendant
UIRE
INFORMATIONAL NOTES AND CODES, RULES & SANCTIONS
NOTES AND CODES
I. ",f" denotes that the entry (value) is verified by a document.
2. "*" denotes documents/information to be supplied by the designated party.
3. "." denotes an item about which a decision is required.
4. "NM" denotes non-marital property not subject to equitable distribution.
5. The values used in the various Tables herein may, in some cases, be based on estimated values.
Those estimated values are subject to adjustment upon appraisal or otherwise.
6. Any adjustment figures used in the various tables herein are for illustration purposes only and are
not to be deemed a representation on the part ofthe Defendant as to whether an adjustment should
be made or the amount of the adjustment, if any is appropriate.
R-I
R-2
R-3
R-4
R-S
R-6
R-7
R-8
APPLICABLE RULES
Rule 1920.33 b 1 I: The Pre-Trial Statement shall include a list of the assets which may be in
chart form, specI mg the marital assets, their value, the date ofvaluation, whether any portion is
non-marital; and any liens and encwnbrances thereon.
Rule 1920.33(b )(9): The Pre-Trial Statement is to include, where there is a dispute, the description
and value of any items of tangible personal property, the method of valuing each item, ana the
evidence, including documentation, to be offered in support of the valuation.
Rule 1920.33(b )(10): The Pre-Trial Statement shall include a list ofthe marital debts including the
amount of each debt as of the date of separation, the date on which the debt was initially incurred,
the initial amount of the debt and its purpose, the amounts and dates of payments made since
separation, the evidence that will be offered in support of the claim.
Rule 1920-33(b)(7): The Pre-Trial Statement shall include the value of the pension or retirement
benefits, the marital portion thereof, and the facts and documentation upon which the party relies
to support the valuation.
Rule 1920.33(b)(5)~6): The Pre-Trial Statement shall include the party's gross income from all
sources, each payro I deduction, and the party's net income, including the party's most recent
federal and state mcome tax returns and pay stubs. Ifthe party intends to offer testimony as to his
or her expenses, the party must supply a current expense statement in the form required by the
practice and procedure governing an action in support.
Rule 1920.33~b)(8): If there is a claim for counsel fees, the Pre-Trial Statement shall include the
amount ofthe ees to be charged; the basis for the charge; and a detailed itemization ofthe services
rendered.
Rule 1920.33(b )(2l: The Pre-Trial Statement shall include the name and address of each expert the
party mtends to cal at trial as a witness. The report of each expert shall be attached to the Pre-Trial
Statement. The expert report shall describe witness's qualifications and experience and state the
substance of the facts and opinions to which the expert IS expected to testify and a summary ofthe
grounds of each opinion.
Rule 1920.33(b )(3): The Pre-Trial Statement shall include the name, address and a short summary
- 2 -
R-9
R-IO
S-1.
S-2.
S-3
oftestimony of each person, other than a party, whom the party intends to call at trial as a witness.
~ule 1920.33(b )(11 ): The Pre- Trial Statement shall include a proposed resolution ofthe economic
issues.
Rule 1920.33 b 4: The Pre-Trial Statement shall include a list of all exhibits a party expects to
o er mto eVI ence, each containing an identifying mark. All Exhibits that do not exceed three (3)
pages shall be attached. All exhibits over three (3) pages shall be described.
SANCTIONS
Rule 1920.33( c): If a party fails to file either an Inventory as required by subdivision (a) or a Pre-
Tnal Statement as required by subdivision (b), the Court may make an appropriate Order under
Rule 4019(c) governing sanctions.
Rule 1920.33(d)~I): A party who fails to comply with the requirement of subdivision (b) ofthis
Rule (the filing 0 . a Pre-Trial Statement with tlie information set forth in subparagraph (b)) shall,
except upon good cause shown, be barred from offering any testimony or introducing any evidence
in support of or opposition to the claims for the matters not covered therein.
Rule 1920.33 d ii: A party shall, except upon good cause shown, be barred from offering any
teslimony or mtro ucinE any evidence that is mconsistent with or which goes beyond the fair scope
of the information set forth in the Pre-Trial Statement.
- 3 -
SECTION I.
BACKGROUND INFORMATION
The following Table #1 sets forth the background information relevant to this case:
TABLE #l-A
PARTIES
DESCRIPTION HUSBAND WIFE
Name Rodger Eugene Sgrignoli, Jr Kyra Ann Sgrignoli
Maiden Name -- Van Hoose
Address 11 North Enola Drive 424 F. Duke Street
Enola, P A 17025 Enola, P A 17025
Home Phone --
Cell Phone No. 421-4941
Work Phone No. 346-1024
E-mail rsgrignoli@state.pa.us
Date of Birth 5/28/1962 11/21/1960
Age 43 44
Place of Birth Harrisburg, P A Paintsville, KY
Race Caucasian Caucasian
Health Status Good Good
Educational Background BS 3+ yrs. College
Names and Relationship of Persons None None Known
Living with Party
Date Party Moved to Current Residence 5/1996 12/27/2002
Date PA Residency Began Since Birth 2/1992
Current Military Service N/A N/A
Employer's P A Dept. Of Revenue Lenscrafters
Name and Address
Occupation (Job Position) Tax auditor Optician
Date Employment Commenced 5/1995 1999-2000
Est. Annual Income $46,800 salary + $2,400 $25,749.60 as ger 9/29/05
milita~ disabIlity aSler Support rder
9/29/ 5 Support Or er
- 4-
TABLE #l-B
MARRIAGE INFORMATION
DESCRIPTION
INFORMATION
11/21/1987
Enola, PA
12/27/02
No Fault
Date of Marriage
Place of Marriage
Date of Separation
Grounds for Divorce
Prior Divorce Actions Between Parties
None
Number of this Marriage for Wife
Number of this Marriage for Husband
2
1
NAME
TABLE #l-C
CHILDREN OF THIS MARRIAGE
AGE DATE OF BIRTH SCHOOL
GRADE
Christian T. Sgrignoli
Tyler J. Sgrignoli
16
12
7/5/1989
8/10/1993
CUSTODIAN OR
EMANCIPATION
Wife
Wife
TABLE #l-D
SUPPORT FOR THIS MARRIAGE
DESCRIPTION INFORMATION
Name of Party Paying Support Husband
Beneficiaries of Support 2 Children and Wife
Amount of Support $966/mo until 1/1/06 then
$710/mo allocated $686/mo/child& $24/mo/spousal
Allocation effective 1/1/06:
$686/mo/child& $24/mo/spousal
Agreement or Order Order
Date of Agreement or Order 9/29/05
Effective Date of Order 9/1/05
Docket Number of Support Order 873 S 2002; Pacses #876104896
Comments: Order effective 1/1/06 reflects fact that wife will be
claiming child on her tax return.
- 5-
TABL
PRIOR MA
PARTY NUMBER DA
OF TERM
MARRIAGE
Wife 1 1
TABL
CHILDREN OF OTHER REL
PARTY NAME OFCHILD
N/A N/A
TABLE
SUPPORT/ALIMONY FOR PRIO
DESCRIPTION INFO
Name of Party Paying Support
Beneficiaries of Support
Allocation
Agreement or Order
Date of Agreement or Order
Docket Number of Support Order
Comments:
- 6
13 #1-13
RRlAGES
TEOF
!NATION
MANNER OF TERMINATION
985?
Divorce
13 #1-F
A TIONSHIPS/MARRIAGES
DATE OF AGE CUSTODIAN OR
BIRTH EMANCIPATION
N/A N/A N/A
#1-G
R MARRlAGES/RELA TIONSHIP
RMATION INFORMATION
N/A N/A
WA WA
NM NM
WA WA
N/A N/A
N/A N/A
WA NM
TABLE #l-H
PROCEEDINGS INFORMATION:
COMPLAINT
Complaint Filing Date 2/26/03
Date of Service TBD
Manner of Service TBD
Type of Divorce Requested 3301 (c) No Fault
Economic Claims Raised Equitable Distribution, Alimony & Custody
ANSWER, COUNTERCLAIM AND/OR OTHER PLEADING RAISING ECONOMIC CLAIMS
Type of Pleading
Pleading Filing Date
Type of Divorce Requested
Economic Claims Raised
INCOME.ANDEXPENSESTATEMENTS
Plaintiff's I&E Statement Filing Date 7/15/05
Defendant's I&E Statement Filing Date 8/26/05
INVENTORIES
Plaintiff's Inventory Filing Date 7/15/05
Defendant's Inventory Filing Date 9/12/05
3301 CI>OCUMENTS
Plaintiff's 3301(c} Affidavit Date
Plaintiff's 3301(c} Affidavit Filing Date
Defendant's 3301(c} Affidavit Date 8/25/03
Defendant's 3301(c} Affidavit Filing Date 8/25/03
Plaintiff's 3301(c} Waiver of Notice Date
Plaintiff's 3301(c} Waiver Filing Date
Defendant's 3301(c} Waiver of Notice Date
Defendant's 3301(c} Waiver Filing Date
- 7 -
TABLE #1-H
PROCEEDINGS INFORMA nON:
3301 D DOCUMENTS
Date of In House Separation --
Date of Physical Separation 12/27/02
In House 2 Year Separation Date --
Physical 2 Year Separation Date 12/27/04
PlaintifFs 330I(d) Affidavit Date N/A
PlaintifFs 330I(d) Affidavit Date Filing Date N/A
3301 (D) Affidavit Service Date N/A
Manner of Service of 330I(d) Affidavit N/A
Date of PlaintifFs Notice of Intent to Re'luest Entry of N/A
Divorce Decree and Praecipe to Transmit Record
PlaintifFs Notice to Request Entry of Divorce Decree and N/A
Praecipe to Transmit Record Service Date
Manner J!e Service of Plaintif{;,s Notice to RefJ.uest Entry of N/A
Divorce ecree and 330I(d) ounter-Affidavlt
BIFURCATION
Has the case been bifurcated? No
Date of decree granting bifurcation N/A
If bifurcation granted by consent or after hearing N/A
PREVIOUSLYRESOLVEDlSSUEs
Issue #1 Resolution
Issue #2 Resolution
- 8 -
KYRA A. SGRIGNOLI vs. RODGER E. SGRIGNOLI, JR
DOM: 11/21/1987
DOS (Physical): 12/27/02
EST. INCOME: Husband @ $45,422; Wife @ $27,092
Date Prepared: November I, 2005
SECTION II.
MARITAL ASSETS AND DEBTS
The following Table #2 sets forth the listing of the marital assets and debts of the parties:
TABLE #2
MARITAL ASSETS AND DEBTS
A
Ln
No
c
o
D/AN
E
F
G H
Distribute To Distribute To
Husband Wife
Description
Value
Distribution
Value
90,000
6 RE.1 (77,625)
7 RE.1 (6,300)
8 RE-1 6,075
9 RE.1
12 V.1
13 V-1
14 V.1
divide
equally equally
27 RET.1 Comments: 12.31.02 @ $15,297.83 contribution account; State value @53,952.f
* Husband proposes that marital portion of pension be divided equally.
28 RET-2 W's Lenscrafter's 401 K Value 2,000 2,000 2,000
29 RET.2 Comments: * Wife to supply statement of account frO!n DOS (12/27/02) to current date.
As of630.05 Account value was $5,162.79, but included post separation contributions.
- 9 -
KYRA A. SGRIGNOLI vs. RODGER E. SGRIGNOLI, JR
DOM: 11/21/1987
DOS (Physical): 12/27/02
EST. INCOME: Husband @ $45,422; Wife @ $27,092
Date Prepared: November 1, 2005
TABLE #2
MARITAL ASSETS AND DEBTS
A
Ln
No
c
o
D/AN
E
F
G H
Description
Value
Distribution
Value
Distribute To Distribute To
Husband Wife
31 0.1 Jt East Pennsboro Township Current-l
32 0.1 Comments: Curbs and sidewalks assessment
33 0.2 H's MBNA #1677 DOs.[ (9,212) (9,212) (9,212)
34 0-2 Comments: *8.15.03 Settlement Letter@ $3755.12-1
35 0.3 Jt NFCU #2508 DOS-I (5,342) (5,342) (5,342)
36 0.3 Comments:
37 0-4 H's T-Mobile V S Wireless #6614 DOS-I (131) (131) (131)
38 0.4 Comments:
39 0-5 H's CTSI #6235 DOs.[ 117 117 117
40 0.5 Comments:
41 0.6 H's AT&T Wireless Value (890) (890) (890)
42 0.6 Comments: * statement for this account is not available
43 0-7 H's Chase Auto #1647 DOs.[ (390) (390) (390)
44 0.7 Comments: *8.12.03 Settlement Letter@ $311.80-1
45 0-8 H's GMAC #7782 DOS-I (5,536) (5,536) (5,536)
46 0-8 Comments:
47 0.9 H's Bank One DOs.[ (935) (935) (935)
48 0.9 Comments:
49 0.10 H's East Penn SD 2.16.99-1 (8,041) (8,041) (8,041)
50 0.10 Comments: Judgment for legal fees
4,847
4,847
-24.69%
57 TOTALS FROM ABOVE 4,847
58 LESS AMOUNT DUE IN 50/50 DIVISION (9,817)
59 ADJUSTMENT FIGURE FOR SO/50 (14,664)
Husband proposes that the adjustment figure be paid in cash by wife, or alternatively deducted from her share of
the Husband s SERS Contribution Account.
- 10-
SECTION III.
LISTING OF HOUSEHOLD GOODS AND CONTENTS
AND OTHER PERSONAL PROPERTY
The following Tables #3-A and # 3-B set forth the household goods and contents and other personal property
of the parties: ], 2
*****Defendant believes that the current division of household goods and furnishings is acceptable to the
parties. Therefore, Tables 3-A and 3-B have not been completed. *****
TABLE #3-A
HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY
IN HUSBAND'S POSSESSION
NO. DESCRIPTION OWNER POSSESSOR VALUE VALUE BASIS FOR EXCLUSION
DATE IF NON- MARITAL
N/A H&W Husband
-- Comments:
TOTAL HUSBAND'S POSSESSION NIA
TABLE #3-B
HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY
IN WIFE'S POSSESSION
NO. DESCRIPTION OWNER POSSESSOR VALUE VALUE BASIS FOR EXCLUSION
DATE IF NON- MARITAL
N/A H&W Wife
-- Comments:
TOTAL WIFE'S POSSESSION N/A
Note: Exclusions from marital property include property acquired before marriage, property acquired after separation,
or property acquired during marriage by way of gift or inheritance from third party not a spouse. For gifts and
inheritance also specify the source person.
2
The value of each item has been estimated by Defendant unless otherwsise noted.
- 11 -
SECTION IV.
NON-MARITAL ASSETS AND DEBTS
The following Table #4 sets forth the non-marital assets and debts of the parties: 3:
*****Defendant believes the information in Table #4 is not relevant. If determined to be relevant in the
future this table will be completed. *****
TABLE #4
NON-MARITAL PROPERTY AND DEBTS
NO. DESCRIPTION OWNER POSSESSOR VALUE VALUE BASIS FOR EXCLUSION
DATE IF NON-MARITAL
TBD if relevant H&W
-- Comments:
H&W
-- Comments:
H&W
-- Comments:
H&W
-- Comments:
H&W
-- Comments:
H&W
-- Comments:
3N ote: Exclusions from marital property include property acquired before marriage, property
acquired after separation, or property acquired during marriage by way of gift or inheritance from third
party not a spouse. For gifts and inheritance also specify the source person.
4The value of each item has been estimated by Defendant unless otherwise noted.
- 12 -
SECTION V.
PENSIONS AND RETIREMENT BENEFITS
The following Table #5 sets forth the listing of the pensions and retirement plans of the parties:
TABLE #5
RETIREMENT PLANS
NO DESCRIPTION DATE OF MARITAL TOTAL VALUE SUPPORTING FACTS OR
MARITAL VALUE OF OE,BENEEITS DOCUMENTATION
VALUE BENEFITS
RET-l H's SERS Plan TBD TBD TBD 12.31.02 Statement of
Account
-- Comments: 12.31.02 @$15,297.83conlributionaccount; State value@53,952-1
* Husband proposes that marital portion of pension be divided equally as received.
RET-2 W's Lenscrafter' s TBD TBD TBD 6.30.05 Statement
40lK
-- Comments: * Wife to supply statement of account from DOS (12/31/02) to current date.
As of6JO.05 Account value was $5,162.79, but includes post separation contributions. Martial value
cannot be determined until all requested statements provided.
- 13 -
SECTION VI.
INCOME AND EXPENSES
The following Table #6-A sets forth the incomes of the parties as reported on their respective Income and
Expense Statements:':
TABLE #6-A
INCOME OF THE PARTIES
DESCRIPTION
HUSBAND
$1,747.50
WIFE
1,042.26
Gross Pay per Pay Period
MANDATORY DEDUCTIONS
FICA
($108.34)
($25.34)
($125..67)
($53.65)
($27.96)
($17.13)
($109.22)
($1.57)
$1,280.19
$2,773.75
(64.62)
(15.11)
(48.84)
(32.00)
(10,42)
Medicare
F ederal Tax
State Tax
Local Tax
Union Dues
Mandatory Retirement
Unemployment Comp
(0.94)
871.27
1,887.75
TOTAL
NET PAY PER MONTH
5Actual Income may vary and will be updated at time of hearing.
6Effective 1/1/06 Wife will have no federal tax and will receive an earned income credit
payment as the result of her claiming the children on her tax return.
- 14 -
The following Table #6-B sets forth the monthly expenses of the parties as reported on their respective Income
and Expense Statements:'
TABLE #6-B
MONTHLY EXPENSES OF THE PARTIES
DESCRIPTION HUSBAND WIFE
HOME EXPENSES:
Rent $813.51 $600.00
First Mortgage
Second Mortgage/Home Equity Loan
Maintenance and Repairs $150.00
Electric $125.00 $165.00
Gas $75.00
Oil
Telephone $50.00 $50.00
Cell Phone $50.00
Water $25.00
Sewer/Trash $39.00
Trash
EMPLOYMENT
Public Transportation
Lunches $100.00 $100.00
Other Employment Expenses
TAXES:
Real Estate Taxes
Personal Property Taxes
Income Taxes Not Withheld
Per Capita/Occupation Taxes
INSURANCE:
Homeowners/Renters Insurance $54.00
Automobile Insurance $52.00
Life Insurance
7 Actual Expenses may vary and will be updated at time of hearing.
- 15 -
TABLE #6-B
MONTHLY EXPENSES OF THE PARTIES
DESCRIPTION HUSBAND WIFE
AUTOMOBILE EXPENSES:
Payments $419.61 $350.00
Fuel $240.00 $200.00
Maintenance and Repair $50.00 $50.00
License and Registration $3.00 $3.00
MEDICAL EXPENSES NOT REIMBURSED BY INSURANCE:
Doctor $20.00 $50.00
OpticalNision $20.00
Dental $15.00 $35.00
Orthodontic
Hospital
Medicine $20.00 $50.00
Special NeedslTherapy Etc.
EDUCATIONAL EXPENSES:
Private School
Parochial School
CollegeN ocational
Religious Training or Education
Books/Fees and Supplies
Other Educational Expenses
PERSONAL EXPENSES:
Clothing $100.00 $200.00
Food $300.00 $400.00
Barber and Hair Dresser $15.00 $25.00
Memberships $48.00
Other Personal ExpenseslLaundry Dry cleaning $40.00
- 16-
TABLE #6-B
MONTHLY EXPENSES OF THE PARTIES
DESCRIPTION ... HUSBAND WIFE
CREDIT CARDS AND LOANS:
$100.00
MISCELLANEOUS EXPENSES:
Household Help
Child Care
N ewspapers/Magazines/Books $21.00 $18.00
Entertainment $ 100.00 $250.00
Pay TV $50.00
Vacations
Gifts
Legal Fees $150.00 $150.00
Charitable Contributions
Other Child Support (not this action)
Other Spousal Support or Alimony (not this action)
Child & Spousal Support this Case (effective 1/6/06) $710.00
TOTAL EXPENSES $3,751.12 $2,900.00
- 17 -
SECTION VII.
COUNSEL FEES
The following Table #7 sets forth the listing ofthe counsel fees and expenses incurred by Defendant if a
claim has been made for counsel fees and costs:
*****Neither party has raised a claim for counsel fees. Therefore, Table #7 has not been completed. *******
TABLE #7
COUNSEL FEES AND COSTS
DESCRIPTION DATES, BILLS AND CIIARGES
Dates Services Were Rendered N/A
Hourly Rate N/A
Costs NIA
Total Amount of Fees and Costs Claimed to N/A
Date of this Pre-Trial Statement
Anticipated Fees and Costs N/A
Itemization of Services Rendered NIA
- 18 -
SECTION VIII.
EXPERT WITNESSES
The following Table #8 sets forth the listing of the experts who the party intends to call to testify in this case:
TABLE #8
EXPERT WITNESSES
NAME SUBJECT OF TESTIMONY REPORT ATTACHED REPORT TO.BE SUPPLIED
Experts who prepared any To be determined Report is attached if and If not currently available,
report referenced in the to extent such report is Report to be supplied as
Proposed Exhibits in Section referenced in Exhibit soon as available
XI and XII. ** Section.
** Additional experts who may be called to testify are not known at this time. Defendant reserves
the right to call additional expert witnesses upon proper notification to the other party once those expert
witnesses are identified and retained.
SECTION IX.
OTHER WITNESSES
The following Table #9 sets forth the listing of the anticipated witnesses other than experts who will he
called to testify in this case:
TABLE #9
LAY WITNESSES
NAME SUBJECT OF TESTIMONY
Rodger E. Sgrignoli, Jr. History of the marriage; Identification and valuation of marital assets and
debts; Other relevant testimony relating to the factors set forth in the divorce
code
** Additional witnesses who may be called to testify are not known at this time. Defendant
reserves the right to call additional witnesses upon proper notification to the other party once those
witnesses are identified and agree to testify.
- 19 -
SECTION XI.
PROPOSED RESOLUTION
The following is Defendant's proposed resolution of the issues presented in this case:
A. DIVORCE:
A No-fault Divorce Decree should be entered under either section 330lc or 3301d.
B. EOUITABLE DISTRIBUTION:
The parties' marital assets and debts should be divided and distributed in accordance with the schedule
set forth in Section II of this Pre-Trial Statement.
C. ALIMONY PENDENTE LITE:
NI A No claim for APL has been raised. Effective 1/6/06 there is a spousal support order in effect for
$24.00 per month.
D. ALIMONY:
Wife's claim for alimony should be denied. Wife is capable of self-support and Husband does not have
the ability to pay.
E. COUNSEL FEES AND COSTS:
NIA No claim for counsel fees has been raised. Each party has the ability to pay his or her own fees.
- 20-
SECTION XII.
PROPOSED EXHIBITS
The following Table #11 sets forth Defendant's listing the proposed exhibits to be submitted at the hearing in
this case. Exhibits are attached or to be supplied as indicated below. 8
TABLE #11
LISTING OF EXHIBITS
NO. DESCRIPTION ATTACHED TO BE SUPPLIED
1 Husband's Income and Expense Statement X To be updated by husband
2 Husband's Pay Stubs X To be updated by husband
3 Husband's 2004 Federal and State Income Tax Returns X 2005 Return to be submitted if
filed by time of hearing
4 9.29.05 Support Order(s) X
5 2004 Tax Assessment of IlN. Enola Drive X
6 Appraisal of IlN. Enola Drive To be submitted if obtained
7 Mortgage Amortization Schedule X
8 Mortgage Statement X To be updated by husband
9 NADA and KBB values for Wife's 2000 Chevrolet Cavalier X
10 GMAC Statement of Wife's Vehicle loan X
11 Husband's PSECU account statement as of 12.27.02 X
12 Wife's Waypoint account statement as of 12.27.02 X
13 Husband's SERS 2002 Statement of Account X
14 Wife's Lenscrafters 40lK Statement and Analysis X Analysis and post separation
statement to be submitted as
soon as Wife provides
statements to husband
15 East Penn Township Debt Statement X DOS Statement to be supplied
16 MBNA Statement X DOS Statement to be supplied
8Defendant rescr"cs the right to submit additional exhibits upon proper notiJication to the other
party.
- 21 -
TABLE #]]
LISTING OF EXHIBITS
NO. DESCRIPTION ATTACHED TO BE SUPPLIED
17 NFCU Statement X DOS Statement to be supplied
18 T Mobile Statement X DOS Statement to be supplied
19 CTSI statement X DOS Statement to be supplied
20 AT&T Wireless statement DOS Statement to be supplied
21 Chase Auto Statement X DOS Statement to be supplied
22 GMAC Statement X DOS Statement to be supplied
23 Bank One Statement X DOS Statement to be supplied
24 East Penn School District Judgment X
- 22-
I, Diane G. Radcliff, Esquire, hereby certify that on
within Pre-Trial Statement, by mailing same by first class
, I served a copy of the
iI, postage prepaid, addressed as follows:
Susan K. Candiello, Esquire
4010 Glenfinnan Place
Mechanicsburg, PA 17055
DCLlFF, ES
Road
Camp Hill A 17011
upreme Court ill # 32112
Phone: (717) 737-0100
Fax: (717) 975-0697
Attorney for Defendant
- 23-
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.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KYRA ANN SGRIGNOLl,
Plaintiff
NO. 03-866 CIVIL TERM
V.
CIVIL ACTION - LAW
RODGER EUGENE SGRIGNOLl, JR,
Defendant
IN DIVORCE
DEFENDANT'S LISTING OF EXHIBITS
NO. DESCRIPTION ATTACHED rOBE SUPPLIED
I Husband's Income and Expense Statement X To be updated by husband
2 Husband's Pay Stubs X To be updated by husband
3 Husband's 2004 Federal and State Income Tax Returns X 2005 Return to be submitted if
filed by time of hearing
4 9.29.05 Support Order(s) X
5 2004 Tax Assessment of IIN. Enola Drive X
6 Appraisa] of IIN. Enola Drive To be submitted if obtained
7 Mortgage Amortization Schedule X
8 Mortgage Statement X To be updated by husband
9 NADA and KBB valuesl Wife's 2000 Chevrolet Cavalier X
10 GMAC Statementl Wife's Vehicle loan X
]1 Husband's PSECU account statement as of 12.27.02 X
12 Wife's Waypoint account statement as of 12.27.02 X
13 Husband's SERS 2002 Statement of Account X
14 Wife's Lenscrafters 40lK Statement and Analysis X Analysis and post separation
statement to be submitted as
soon as Wife provides
statements to husband
]5 East Penn Township Debt Statement X DOS Statement to be supplied
16 MBNA Statement X DOS Statement to be supplied
.
.
DEFENDANT'S LISTING OF EXHIBITS
NO. DESCRIPTION ATTACHED TO BESUPPLlED
17 NFCU Statement X DOS Statement to be supplied
18 T Mobile Statement X DOS Statement to be supplied
19 CTSI statement X DOS Statement to be supplied
20 AT&T Wireless statement DOS Statement to be supplied
21 Chase Auto Statement X DOS Statement to be supplied
22 GMAC Statement X DOS Statement to be supplied
23 Bank One Statement X DOS Statement to be supplied
24 East Penn School District Judgment X
R~;:,;-,G.OOOSiFRI) In:58
. '"', -,
I
I
I
RU~5 ~arr15burg Reg Off
(FRX)7I, 783 Fin
.
I' 00:/005
IN TEE COURT OF COMMON PLEAS,
CUMBE~~ COUNTY, PErn"SYLVANIA
JudgE! GUIDO
KYRA ANt. 5GRIGNOLI,
PlQlntiff,
Case No.: No. 03-866 CIVIL
RODGER EUGENE SGRIGNOLI JR.,
CIVIL ACTION - LAW
ACTION FOR DIVORCE
TERM
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V$ .
Dofendan.t
INCOME AND EXPENSE STATEMENT OF
RODGER EUGENE SGRIGNOLI JR.
De[endant, Rodger Eugene Sgrignoli Jr. [1185 Lh8 following
~ncom8 .J..rlcl E.:-.pense S":-atE::ment and verifies t112 :::;tatement~ made::
h~reln 3r~ tru8 and correct.
Defendant unders~and any faJ.se
staLemerlts tlerein arE made subject to the penalties of
18 P2!.C_S.5 4904 rel.~t~.ng to ll~swcrn falsification to
2uthGrit':"8:.3.
,~c ~ ojz41J-L
Rodger Euqene Sgrlgnoll Jr. CP~
INCOME:
Employer PA Dept of Revenue
Address: 1846 Brookwood Sl. Hbg, PA 17104
r~lF.fEnJl\tJT' oS HJC::JtI:C l~ C:':t.='E!'l::[ STl\TJ:t-;[t:T ~
RU5~cG-cJl05(FRI) la 56
RUlIIl HarrlSburg Reg Off
(FR~)TIT
.
p 002,/00&
-'n,
10)
ilia
Type of Work State Ta< AUditing
Payroll Number: 454304
P"y Period: BI.Wcckly
Gross. 51.74750
Itemized
Payroll
Deductions
Federal 5125.67
Withholding
Social Security 5106.34
Local Income 527.96
Tax
Sidle Income 553.65
TciX
Hbg OPT $52.00
PAUC EE 51.57
MediCclre 52534
Union Dues $17.13
Alimony/Support $460.00
Reliromcnt $109.22
Total $1.000.88
Deduclions
Net Pay Per $746 52
Pay Period:
D:::;~'Ulu....r'I'l"::; lW':Ol'lt: ;. C:/.J!!:';USS :::T..::..rU']UIT - 2
RlIG.-25-?OOS(FRIl 1ass
iOiAL
MONH\L Y
INCOME:
EXPENSES
(1VI0NTHL Y)
I
)
HOME
RU., HarrIsburg Reg Off
(FRX)71 i 783 iila
.
Net P<lY Per
Month:
Other
Income:
Mortgage:
Utilities:
Per Month
VA Disability
$200.00
$813.51
Electric: $125.00
Water: S2500
Gas: S7500
Sewer/Garbage' S39.00
Telephone: S5000
Cable: $50.00
1v1<llnlenance $15000
l)~rf,I'm:'JJT' ~ :::Jr~otIlE EXPEH5E. 2T;Y~::::I'::::~]'r - ~!
P 003/005
$1,49324
$1.693.24
RUG.-25-2.I]05(FRI) 1~:58
EMPLOYMENT:
INSURANCE
AUTOMOBILE
MEDICAL
PERSONAL
RU.
HarrIsburg Reg Off
(FRX)(li
.
Lunches:
Automobile
Payments:
Fuel:
Repairs;
Main!'
Licencesl
RcglstrJtlon
Doctor'
Dentist:
Medicine:
Optometrist:
Clothing'
Food:
nr:V2t-1D;~'.1.JT' s ::Ll'lCCt~E u C':FEUSE :-:;':';\TU"J:::U'f - <'1
183 n I d
P ODd/DOG
$100.00
$5200
$41961
$240,00
$25 00
$25.00
$300
$20,00
51500
$2000
$20.00
S100.00
S300.00
RUG.-2D,-~OD5(FRI I I a 58
MEMBER-
SHIPS'
MISC.:
TOTAL
EXPENSES
RUiliS HarrISburg Reo Off
(FRX)7]7 183 iild
.
B"rber:
$1500
Laundry/Dry
$40 00
Cle3ning:
YMCA
$4800
P3per,/
$21.00
Books/Mag.
Enlerl<Jin.:
$100.00
Legal Fees:
$15000
TOTAL
MONTHLY
INCOME:
r;~r.E:t,l)ht.r.:':: InC(")f,W, ,~ EXFEN.':?, ST~.TSH.:.;t.J'l' - 5
P 005/JOG
$3,041.12
$1,693.24
RLI~-2D-.2oo5(FRI) 1[:58
"
RWS
HarrIsburg Reg Off
TOTAL
MONTHL Y
EXPENSES,
TOTAL
MONTHLY
SHORTFALL:
(FR~17 783 771a
P DOG/DOG
$3,041.12
$1,347.88
Respectfully Submitted,
LAW F~Rl'] 01" DIANE S..;DCLlff. LC.
-'_h
.~-Ql
~i~R["vcliff, Esqui:-~
Counsel for Defendant
PA I. D. it )';X;(y.x
3~~8 Trind18 Ro~~
Camp Hill, [,P. 17011.
(7171 737-0100
DEFI:ND;J.J-:T'S HJCCltiJC r. Ei:P::::I~:C ST.LTEf-1F>JT ~ (-j
grignoli Jr
IEnola Dr
A 17025
Personnel Number..... 00454304
Revenue
Pay Period.. 08/13/2005 - 08/26/2005
Fed Tax Status: Married
Fed Tax Allowances: 04 period: 18/2005
;A4
Group:07
Level: 10
Date
J9/2005
Payment Amount ~
842.81
Gross
1,800.00
.
Reim.
0.00
Taxes
328.43
Deds.
628.76
Gross Current Pay Rate Hrs/Unt Amount Year To Date
Normal working hours 24.00 71. 00 1,704.00 27,699.85
Annual Leave Pay 1.452.80
Paid-Office Closing 116.50
Sick Leave Pay 714.75
Sick Family Leave 174.75
Personal Leave Pay 24.00 4.00 96.00 457.85
Holiday/Camp lieu Holiday 1,053.75
Total Gross 1,800.00 31,670.25
Taxes Amount Year To Date
Federal Federal
TX Withholding Tax 105.05 1,788.31
TX EE Social Security Tax 111.60 1,963.56
TX EE Medicare Tax 26.10 459.22
State pennsyl vania
TX Withholding Tax 55.26 972.30
TX EE Unemployment Tax 1. 62 28.50
Local East Pennsboro Township
Tl( Withholding Tax 28.80 506.72
Local Harrisburg
TX EE Occupation Tax 52.00
Total Taxes 328.43 5,770,61
jOeductions
.;.es EE Bonds
~ME-13 Fair Share
Garnish: Alimony/Support
Full Cov Class AA/Cat 0
Amount
Year To Date
25.00
18.18
473.08
112.50
450.00
312.59
8,515.44
1,979.11
(
Total Deductions
628.76
11,257.44
Non Cash Compensation
Amount
Year To Date
Reimbursement;.s
Amount
Direct Deposit Bank / Check
Amount
Net Payment
842.81
State ~aid Benefits
Amount
TX ER Social Security Tax
TX ER Medicare Tax
ER Basic Life
Annuitant Med Hospital
ER Workers Comp Benefit
PR Aetna US Healthcare PA
ER-SERS
111.60
26.10
4.97
240.00
34.35
275.00
42.66
IFederal
,.- "'::"ent
Taxable Wages
Amount
Period Results
1,687.50
Garnishment Type
Beg Balance
Total To Date
Remain Balance
Garnish: Alimony/Support
0.00
20,176.65
0.00
(payrOll Area
Z2
.
.
Commonwealth of Pennsy lvania
EMPLOYEE PAY STATEMENT
IRodger E 5gri9001i Jr
113 Norch Erlola Dr
:EI101a FA 17025
I
1
IBin-A4
1_--
Level: 10
Group; 07
! Pay Date
1 06/17/2005
1____
Payment Amount
808_54
1,747.50
IGross Current Pay
Hrs/Unt
60 00 1,398.00
Amoun t
Rat.e
1-
I Norm,:, ] workin9 hours
I Annua 1 ~,Cilve Pay
IPdid O[[icc Closing
IS Lck LC<1ve Pay
I Sick Family Leave
IPersonal Leave Pay
IHoliday/Comp lieu Holiday
23 30
Personnel Nurrcbec.
Rc'/enue
Pay Period. OS/21!200S
Fe::! Ta:{ S,-at'__L3: Married
PeJ. Tax 1'.1: owaI1ces: 04
Gcoss
Reim.
0.00
23.30
7.50 174.75
7.50 174.75
23.30
ITota] Gross
1__--
ITa:~es
1__---
I Feder"l Federal
ITX Withho.lding Tax
ITX r,p, .':>JcizLl Security Tax
ITX EE Medicare Tax
IState Pennsylvania
I1'X Withholding Ta:~
[TX EE Unemployment Tax
I Local Ease Pennsboro Township
ITX W.::::hholding Tax
11>ocal Harrisburg
ITZ EE occu~atiorl T3X
1-
I Total Til;-:f's
1-
IDeductions
1-
15eries EE Bonds
IAFSCME-13 Fair Share
ICornish, P-.limonyjSuppCI:"t
I Ful' CO'! Clasc:; P-.AjCat 0
1_.
iToLal Deductio~s
I~;:o:\ Cash CQ~rFensa:::io:l
1-
1. 717.50
Amount
9"1.67
108.34
2':i.34
53.65
.57
:J7 %
314 53
f..IIIQUnt:
25.00
1"{ 13
473.08
10'~. 22
67.4 43
AmGunt:
GC 4 ~;4 3 04
c)("jOJ!200S
Period'
12/200:,
1
1
_I
Deds. I
624.13 I
I
Taxe5
314.53
Year To DaLe
1.9,16<1.25
29125
nr:i.50
174 7r..
]74.75
174.75
873.7':i
20,970.00
Year To Delte
1,172..04
1,3CO.14
304.07
643.80
18.87
~ 3 5 . S 2
,., cu
_I
I
.1
3,'O:C'14
Yeat" To Dace
300.00
205.56
~,67E .96
1,3]0 b'l
7,4'3316
'feat- To :Ja:::c
.
.
Commonwealth of Pennsylvania
EMPLOYEE PAY STATEMENT
1__-
jReimbursemeots
AI';lount
1____
1
---~_..._-,- -- -- .'-_... ---_..---.."-_.----------_.,
__I
I
I
,
1______-.--------
IDirect Deposit Bank / Check
Amoun.t
1_-
INet Payment
1'__-
8085'1
__~i
I
~_I
IState Poid Benefits
Am/II1Ilt
1______----.--
ITX ER Social Security Tax
ITX BE MedicJre Tax
I ER Rasic Li fe
IAnnuitant Med Hospital
]ER Workers Camp Benefit
]PR Aetna US Healthcare PA
IER-SERS
I
108.34
25 _ 34
4.78
I
-__I
I
I
I
I
1
I
I
-__I
204 .60
34 .57
270 .00
24 .99
IFederal Taxable Wages
Amount
I
---~___I
I
__I
1_-
leurrent Period Results
1, 638 _ 28
1___.
IGan~i.shmcnt '7ype
---.--_._-~---_.__....,-- --_._--------~-------
B\:'9 Balance
Total To Dat:f:C
Rwna:i. n Ea lance
IGarnish: Alil110ny/Support
0.00
17,338,17
0,00
I
_-I
I
I
1____.
12ayroll Area L~
1-
(See
instructions
~ page 16.)
~ the IRS
label. H Home address (number and sltreet). If you have a P.O. box, see page 16.
Otherwise, E I I IV En 0 ({ Diu
please print ~ City, lown or post OHiC? state, and ZIP code. If you have a foreign address, see page 16.
or type. . E:' (\ Q \ ,... . fI 1 '7 0 ;;t ,
PresIdential V\, ...:>
~ You Spouse
Ejection Campaign Note. Checking"Yes" will not change your tax or reduce your refund.
(See page 16.) Doyoll, or your spouse if filing a joint return, want $3 to go to this fund? ... DYes ItJNo DYes DNa
- 1 ~ Single 4 0 Head of hous~hold (with qualifying person). (See page 17.) If
Filing Status 2 0 Married filing jointly (even if only one had income) the qualifying pers'on is a child but not your dependent, enter
3 0 _ Married filing separately. Enter spouse's SSN above this chj)d's name here. ~
and full name here. ~ 5 0 Qualifying-widow,(er) with dependent 'child {see page 17)
rlA. '.} Boxes checked I
6a lfj' Your~eif. If someone can claim you as a dependent, do not check box 6a on 6a and 6b ~
b 0 Spa' se - No. of children
on 6c who:
. lived with you
. did not live with
you due to divorce
or separation
(see page' 18)
Dependents on 6c
not entered above----,---
Add'numbers li'n[iJ
lines above ~ ,
i{3 C;
7 Wages, salaries, tips, etc~Attach_ Form(s) W-2
Sa Taxable int~re;st. Attach Schedule B jf required
b Tax-exemp~ Interest. D~ not in.elude on Une 8a
.9a; On:linary dividends. J1It~acl:1'Schedule B if required
b QUal,ified.diV,!~en.ds,'<see,pa_g_e,20)' 9b
10. Taiablec_~e~~nds"credj:ts,:q~ (iffsets of stat~ and local income taxes (see page,20)
11 Alj~onyr_ef&j,v~d, ' ", _' " ,,' , "
12 Busjnessjnq'pme'Or,(IOS~)~,Attach Schedule C orC-EZ .
13 Capitalg_ainor(IOSs)~,~_tt~Ch Schedule 0 ,if required.. If not required;check--here ...
14 Oth~rg~Jns-:or:{Ios~estAtJach,Form 4797 .... . . . , . '." ,
15a IRAdist~ib,'~~<j~n~,,:,. '. ',.:.:1~ U b.Taxable amount(see,Page 22)
16a P~nsions apd.annuities .~I ,. I--.J b Taxable amount (,ee page 22)
17 ~~~t:aL r~~l,~~;t~t~j,~r;?xa!ti_~,~';.):>~r~q~rph_jps,. Scorporations, trusts,etc. Attach', ?c:hed~I~-'E.
18- . F~rmjncoi:pl?;or::Oos$).\An~4,h'_$chedule' F '
1'9' OnemPlb)'0;~6t_R'?,rt)P~,~'~'~~lqn'-:-, .:;
20a SOd~lIse~uriti,benefiis-'.... ','-J.2Da .J
\ "" . ,,' " " c'_:,'":;'';!::',J' .-:\" ;::~_,;;;:i: ",:::~-;
21- 'Other iT)c()rrie,;::Li!?M-yp~:anp,~a'mpunt(see page 24) _ __._ .__ _ _ ___..___ __ _ ________ _ _ __ .__
22 Add theamhunts'"n'thefafhght 'column for lines:? through 21. nii~ is your total income '.... ,
->'~-' ...., :,:i'~';: ."_':: '-,'" 'c'
23 E'~~cat?tc3'~~~.n_s~~'}~~~_'p~9:e.;2~)
'24 }?,er"tajnb(J_si~~$s;~xpe,~~~~:Qf.:'re;e~is-ts,'pe.rforming artists, Emd
Y:'"" :"",-, ,,' ':':,"::\:,:,t', "''':''.-,-':', ,",',':;;'-'''' '~,,:" _'-"'," ,"',:.- ", '" '," ':,:' '" " '
----- ,-~-~~~b~9j~':Q'?~~f~m~~;~9!fisl,a!~,~~t!~,c~c,Eomv2;106-of-:210EkEZ
25 IRA deduction (,ee:p'ag~26j',. .' : '. . . .
"::, '<::'-:-':_<:,-":,-_:r;__:,:",::__;::,~", " ,I
26' -$J~,~~~t-~?~!1\lqt~f'?~!:;?;~AV~,~jo~_:(s~e 'page '28) .
,27 JLjition'and.::te~s:{cj~f:i~qtlpn~'{seiErpage,,29), .
"2_~:,,' H~~'~lih-'~~~iW~~:~Gg6nrit~\a~8"cittj6A~'h\ha6hForm' 8889,.
',," .''';'':/;''~' '~'>";'~,'_-r:A':~~"'''l':}:"\':i~:'~:i':'~;:,,,\,;,>:;,':,' :" ,',' " " - .,'," .
29 fy1oviT1g~Xpe9~!3.~::':~tt~Rn-J6:rin"99'()3' - :'_' . _ . .
30 CYne_~D::~lf:'~f:__~.~if;~:T~I<~YlD~_~+;t~;,:J\~a;6:n':'Schedule" ~E. .
31 $$lt~einPloyei:l,:h~~'JtWlr;:~Urance;deduction'{see page 30)
, ,,"c':',,.-,._:,,- ,', ' ':'/'~':;":--'-,'/,,_,:": - ,- ':
32 "S~lf~employed_$<Ep:,:',SlrytRI):;;and_qua1ified' plans '.
:~a :1::~;po;d~atR:~ti~~:~~sO~:Vi!'.f~t.{. ~o'. 4q'S5
35 Add line~_2,3; t~r~,Ll'9p':;t~.~"":,_,,, , ,,'
36 SubtracUine35 frPrn":line 22. ,This is your adjusted gross income
For Disclosure, Prhiacy' Act; and Pap~ri1ibt~:'~'ed(.icti~'iJ'jl.,6t,' Notice,' see page' -75;--
~ 1040
Label
Check only
one box.
Exemptions
If more than four
dependents, see
page 18.
Income
Attach Form(s)
W-2 here_. Also
attach Forms
W~2G and
l)99-R if tax
J3S withheld.
If you did not
get a W-2,
see page 19.
Enelose, but do
not attach, any
payment. Also,
please use
Form 1040-V.,
Adjusted
Gr9sS
Income
L
A
B
E
L
Department of the TreaSUryarnat Revenue Service G))I(j\O 4
u.s. Individual In e Tax Return ~~U)
For the year Jan. 1-0ec_ 31, 2004, or other tax year beginning ,2004, ending
Yox firs\ name and initial Last name
t-< cd ~ rES (1 G / :
J
Your social security number
IQiS? IS3L
e Only-Do not write or staple in this space.
,20
OMS No. 1545-0074
If a joint re urn, spouse's first name and initial
Last
Spouse's social security number
Apt. no_
..
Important!
....
You m!Jst enter
your SSN(s) above.
c
u
Dependents: (2) Dependent's (3j:Oependent's (4JtJ'_ifqualilyiflg
, socialseclJrity number relationship to chitdforchildlax
j1) First name Last name . you creditfseenaoe18\
0
. . 0
0
. 0
d Total number of exemptions claimed
6b
I' b ~aX~bl; ,~ou';r-(s~e ;age 24)
10
11
12
13
14
1Sb
16b
17
18
19
20b
21
22
;(
"7
23
24
25.
26 .
27
. 28
29
30
.31
32
33
34a
2.4<?
Focm 1040 (2004)
-------
.
SCHEDULES.
lForrll040)
OMB ~ 15'1'
g~O]
.~nt
At\:acl"- No-
I> See Instructions for Schedules A and B (Form 1040). Sequ~
) , 'four social s~ritY I
t:. 53 r i j v1 a I :f{ , I '17 s~: f
Caution. 00 not include expenses reimbur~ed or paid by others.
Medical and dental expenses (see page A-2)
Enter amount from Form 1040, line 37 I 2 I
Multiply line 2 by 7.5% (.075). , 3
Subtract line 3 from line 1> If line 3 is more than line 1, enter -0- .
State and local (check only one box):
a ~ Income taxes, or }
b 0 General sales taxes (see page A-2)
Real estate taxes (see page A-3). . . . .
Personal property taxes . . . . . . . . . .
Other taxes. List type and amount..... .Fer,. 0f'...1. c,I
Vl(
Add lines 5 throu h 8 .
Home mortgage interest and points reported to you on Form 1098
Home mortgage interest not reported to you on Form 1098. It paid
to the person from whom you bought the home, see page A-4
and show that person's name, identifying no., and address ....
Oept'ent cl the Treas\.lry
In1e/ Revenue Serv,ca (L)
(Schedule B is on back)
Schedule A-Itemized Deductions
Nz(S) shONn on Form 1040
jll- Attach to Form 1040.
ROclg€,
,dical
d
mtal
(penSeS
I.
r'
crest
.f'Y-I:.... paid
-yo
(See ;>.-3.)
age
p
rJO<:"" r>@1
perSO sf jS
iflt8,,.-e
(lot tif:),e.
dedUC
r-'1~5 to
... .. .....,
Ct1<Jrl'" 16
ade a
If yOUn: got a
gift" .t for It. 17
be""tl "A-4. 18
~
casuall'is~=s 19
-rlle<< LO. 20
b EXpenses
Jo "osl
alld '"
Olher llaneoU5
\';II5ce . os
oed~cllO 21
22
(see )
'. />..5.
pag
23
24
25
26
27
~r::e\l3neOUS
oedUc\iOnS
28
-rotal
Iternized
r - -luetions
Points not reported to you on Form 1098. See page A-4
for special rules . . . . . . . .. 12
Investment interest Attach Form 4952 jf required, (See
page A-4.). .. ........... 13
Add lines 10 through 1'3 . .
Gifts by cash or check. If you made any gift of $250 or
more, see page A-4 .
Other than by cash or check, If any gift of $250 or more,
see page A-4. You must attach Form 8283 it over $500
Carryover from prior year
Add lines 15 through 17
Casualty or theft loss(es). Attach Form 4684. (See page A-5.) .
Unreimbursed _ employee expenses-job travel, union
dues, job education, etc. Attach Form 2106 or 2106.EZ
if required. (See page A-6.)'" .4"_:":~'__'"'''''h'''
::::!:~ji~:~ilJ.:::::::::::':::::::::::::::::::
Tax preparation f~es. .n. life ~ .--r"4){. . . .
Other expenses-investment, safe deposit box, etc. List
type and amount ....Wh..........h:.....m. .............
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
5
'3 <-I I J
l-/ '3 '-/ 2-
11?/O
Add lines 20 through 22
Enter amount from Form 1040, line 37 .0
Multiply. line 24,by 2% (.02) . . , . " . . 25 0 2 G
Subtract line 25 from line 23. If line 25 is more than line 23, enter -0- . .
other--:frojT1 list on page A-6. List type and amount'" ....h.....hh...... .....'h
Is Form 1040, line 37, over $142,700 (over $71,350 if married filing separately)?
.1':<1' N .a. Your deduction is not,limited. Add the amounts in the far ri9ht,column}
r for lines 4 through 27. Also, enter this amoLinton Form 1040, 1101339. ...
o Yes. Your deduction may be limited. See page A-6 for the amo~nt to enter.
n duction Act Notice, see Form 1040 instructions.
,,"or\(. l"e
for papal" ,
Cat No 126141'
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.-
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
KYRA A. SGRIGNOLI ) Order Number 873 S 2002
Plaintiff )
vs. ) PACSES Case Number 876104896
RODGER E. SGRIGNOLI JR ) Docket Number 00873 S 2002
Defendant ) Other State 10 Number
ORDER OF COURT
Ii) Final 0 Interim 0 Modified
AND NOW, 29TH DAY OF SEPTEMBER, 2005 ,based upon the Court's
determination that the Payee's monthly net income is $ 1,448.76
and the Payor's
monthly net income is $ 2,928.49
, it is hereby ordered that the Payor pay to the
Pennsylvania State Collection and Disbursement Unit
NINE HUNDRED SIXTY-SIX AND 00/100
Dollars ($ 966.00
) a month payable
MONTHLY
as follows: first payment due
IN ACCORDANCE WITH DEFENDANT'S PAY SCHEDULE.
The effective date of the order is 09/01/05 .
Arrears set at $ 186.47
as of SEPTEMBER 29, 2005 are due in full
IMMEDIATELY. All terms of this Order are subject to collection andlor enforcement by
contempt proceedings, credit bureau reporting, tax refund offset certification, driver's license
revocation, and the freeze and seize of financial assets. These enforcement! collection
mechanisms will not be initiated as long as obligor does not owe overdue support. Failure to
make each payment on time and in full will cause all arrears to become subject to immediate
collection by all the means listed above.
For the Support of:
Name
KYRA ANN SGRIGNOLI
CHRISTIAN TYLER SGRIGNOLI
TYLER JAMES SGRIGNOLI
Birth Date
11/26/60
07/05/89 .
08/10/93
~.<>....,;....""T,,,,,,,,, ....
Form OE-518
Worker ID '" n<;
SGRIGNOLI
.
.
v. SGRIGNOLI
PACSES Case Number: 876104896
per month payable
The defendant owes a total of $ 966 . 00
for arrears The defendant must
$ 930.00
MONTHLY
for current support and $ 36.00
also pay feeslcosts as indicated below. This order is allocated and monies are to be applied as
follows:
Frequency Codes:
Payment Amountl
Frequency
$157.00
$386.50
$386.50
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
1 ==One Time B =BiWeekly 2 =Bi~Monrhly
5 ==Semi-Annually S =Semi-Monthly A =Annually
M == Monthly
W =Weekly
Q == Quarterly
Op:ht Type flescriptlon
Renf~ficiary
1M SPOUSAL SUPPORT KYRA ANN SGRIGNOLI
1M CHILD SPT ALLOC CHRISTIAN TYLER SGRIGNOLI
1M CHILD SPT ALLOC TYLER JAMES SGRIGNOLI
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Said money to be turned over by the Pa SCDU to:
. Payments must be made by check or
KYRA ANN SGRIGNOLI
money order. All checks and money orders must be made payable to Pa SCDU and mailed to:
Pa SCDU
P.O. Box 69110
Harrisburg, Pa 17106-9110
Payments must include the defendant's PACSES Member Number or Social Security Number
in order to be processed. Do not send cash by mail.
Service Type M
Page 2 of 4
Form OE-518
Worker lD 21105
.
.
SGRIGNOLI
V. SGRIGNOLI
PACSES Case Number: 876104896
Unreimbursed medical expenses that exceed $250.00 annually per child and/or spouse
are to be paid as follows: 63 % by defendant and 37 % by plaintiff. The plaintiff is
responsible to pay the first $250.00 annually (per child andlor spouse) in unreimbursed
medical expenses. 0 DefendantO Plaintiff 0 Neither party to provide medical insurance
coverage. Within thirty (30) days alier the entry of this order, the OPlaintiff
o Defendant shall submit to the person having custody of the child(ren) written proof that
medical insurance coverage has been obtained or that application for coverage has been made.
Proof of coverage shall consist, at a minimum, of: 1) the name of the health care coverage
provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage;
4) the address to which claims should be made; 5) a description of any restrictions on usage,
such as prior approval for hospital admissions, and the manner of obtaining approval;
6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and
co-payments; and 8) five copies of any claim forms.
Other Conditions:
THIS ORDER IS PURSUANT TO AN AGREEMENT BETWEEN THE PARTIES.
EFFECTIVE 01/01/06, THE ORDER REDUCES TO $710 PER MONTH ALLOCATED: $686/MO CHILD
SUPPORT AND $24/MO SPOUSAL SUPPORT. THE UNREIMBURSED MEDICAL EXPENSE SPLIT
WILL CHANGE DEFENDANT'S PROPORTIONATE SHARE TO 58% AND PLAINTIFF'S PROPORTIONATE
SHARE TO 42%.
Defendant shall pay the following fees:
Fee Total
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
Fee Description
rorJUDICIAL COMPUTER FEE
for COURT COSTS
for
for
Payment Frequency
Payable at $ 0.00
Payable at $ 0.00
Payable at $ 0.00
Payable at $ 0.00
Payable ar $ 0.00
per MONTH
per MONTH
per
per
for
per
Service Type M
Page 3 of 4
Fonn OE-518
Worker ID 21105
.
.
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Phone: (717) 240-6225
Fax: (717) 240-6248
Plaintiff Name: KYRA A. SGRIGNOLI
Defendant Name: RODGER E. SGRIGNOLI ,JR
Docket Number: 00873 S 2002
PACSES Case Number: 876104896
Other State ID Number:
Please note: All correspondence must include the PACSES Case Number.
Support Guideline Calculation
CHILD SUPPORT Defendant Plaintiff
1. N umber of Dependents in
this Case 00 02
2- Total Gross Monthly Income $ 4,100.00 $ 2,145.80
3. Less Monthly Deductions $ 1,197.57 $ 7.25
4. Monthly Net Income $ 2,902.43 $ 2,138.55
5. Combined Total Monthly $
Net Income 5,040.98
6. Plus Monthg Social Security $
Benefit for hild/Children
7. Adjusted Monthly Net Income $ 5,040.98
8. Basic Child Support $
Obligation 1,344.00
9. Basic Child Sur~ort Less
Monthly Socia ecuri;r; $ 1,344.00
Benefit for Child/Chi I ren
10. Net Income as Percentage of
Combined Amount 57.58 % 42.42 %
11. Each Parent's Monthly Share
of the Basic Child Support $
Obligation 773.88 $ 570.12
12. Adjustment for Shared $
Custody
13. Adjustment for Child Care
Expenses $
14. Adjustment for Health
Insurance Premiums $ -87.49
15. Adjustment for Unreimbursed
Medical Expenses $
16. Adjustment for Additional
Expenses $
17. Total Obligation with
Adjustments $ 686.39
18. Less Split Custody $
Counterclaim 0.00
19. Obligor's Support Obligation $ 686.39
FOnD OE.019
Service Type M Worker ID 21105
.
.
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Fax: (717) 240-6248
Phone: (717) 240-6225
Plaintiff Name: KYRA A. SGRIGNOLI
Defendant Name: RODGER E. SGRIGNOLI JR
Docket Number: 00873 S 2002
PACSES Case Number: 876104896
Other State lD Number:
Please note: AU correspondence must include the PACSES Case Number.
Spousal SUDpOrt Guideline Calculation with Dependent Children
l. Obligor's Monthly Net Income $ 2,902.43
2. Less All Other Support $ 0.00
3. Less Obligee's Monthly Net Income $ 2,138.55
4. Difference $ 763.88
5. Less Child Obligation for Current Action $ 686.39
6. Income Available for Spousal $ 77.49
7. Multiply by 30% 30%
8. Amount of Basic Spousal Support $ 23.25
9. Adjustment for Mortgage $ 0.00
1O.Total Monthly Spousal Support $ 23.25
Spousal Support Guideline Calculation without DeDendent Children
L Obligor's Monthly Net Income $
2. Less All Other Support $
3. Less Obligee's Monthly Net Income $
4. Difference $
5. Multiply by 40% 40%
6. Amount of Basic Spousal Support $
7. Adjustment for Other Expenses $
8. Total Monthly Spousal Support $
Service Type M
Form OE-523
Worker ID 21105
.
.
In the Court of Common Pleas of
CUMBERLAND
County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Phone: (717) 240-6225
Plaintiff Name: KYRA A. SGRIGNOLI
Defendant Name: RODGER E. SGRIGNOLI JR
Docket Number: 00873 S 2002
PACSES Case Number: 876104896
Other State ID Number:
Fax: (71 7) 240-6248
Please note: All correspondence must include the PACSES Case Nwnber.
Support Guideline Calculation
CHILD SUPPORT Defendant Plaintiff
1. Number of Dependents in
this Case 00 02
2. Total Gress Monthly Income $ 4,100.00 $ 2,145.80
3. Less Monthly Deductions $ 905.04 $ 247.25
4. Monthly Net Income $ 3,194.96 $ 1,898.55
5. Combined Total Monthly
Net Income $ 5,093.51
6. Plus MOnJh~ Social Security $
Benefit for hildlChildren
7. Adjusted Monthly Net Income $ 5,093.51
8. Basic Child Support $
Obligation 1,354.00
9. Basic Child Sur~ort Less
Monthly Socia ecuri:fr $ 1,354.00
Benefit for Child/Chil ren
10. Net Income as Percentage of
Combined Amount 62.73 % 37.27%
11. Each Parent's Montbly Share
of the Basic Child Support
Obligation $ 849.36 $ 504.64
12. Adjustment for Shared $
Custody
13. Adjustment for Child Care
Expenses $
14. Adjustment for Health
Insurance Premiums $ -76.87
15. Adjustment for Unreimbursed
Medical Expenses $
16. Adjustment for Additional
Expenses $
17. Total Obligation with
Adjustments $ 772.49
18. Less Split Custody
Counterclaim $ 0.00
19. Obligor's Support Obligation $ 7'72.49
Form OE-DI9
Service Type M Worker ID 21105
.
.
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. I70I3
Phone: (717) 240-6225
Fax: (717) 240-6248
Plaintiff Name: KYRA A. SGRIGNOLI
Defendant Name: RODGER E. SGRIGNOLI JR
Docket Number: 00873 S 2002
PACSES Case Number: 876104896
Other State ID Number:
Please note: All correspondence must include the PACSES Case Number.
Spousal Support Guideline Calculation with Dependent Children
1. Obligor's Monthly Net Income $ 3,194.96
2. Less All Other Support $ 0.00
3. Less Obligee's Monthly Net Income $ 1,898.55
4. Difference $ 1,296.41
5. Less Child Obligation for Current Action $ 772.49
6. Income Available for Spousal $ 523.92
7. Multiply by 30% 30%
8. Amount of Basic Spousal Support $ 157.18
9. Adjustment for Mortgage $ 0.00
10. Total Monthly Spousal Support $ 157.18
Spousal SuPport Guideline Calculation without Dependent Children
L Obligor's Monthly Net Income $
2. Less All Other Support $
3. Less Obligee's Monthly Net Income $
4. Difference $
5. Multiply by 40% 40%
6. Amount of Basic Spousal Support $
7. Adjustment for Other Expenses $
8. Total Monthly Spousal Support $
Service Type M
Form DE-523
Worker ID 21105
.
.
Page 1 of 1
Detailed Results for Parcel 09-14-0832-362. in the 2004 Tax Assessment Database
P'trictNo 9
l-arcel ID 09-14-0832-362.
MapSuffix
HouseNo 11
Direction N
Street ENOLA DRIVE
Owner! SGRIGNOLl, RODGER E JR
Owner2 & KYRA A SGRIGNOLl
Prop Type R
PropDesc
LivArea 1440
CurLandVal 18000
CurImpVal 64080
CurTotVal 82080
Curl'refVal
Acreage 0.11
CIGrnStat
~
,Ex I
SaleAmt 79000
SaleMo 5
SaleDa 29
SaleCe 19
SaleYr 96
DeedBkPage 00140-00029
Year BIt 1920
HF File Date 10/25/2004
HF_Approval_Status A
-.. -- ~ . ~~_,... .... /,-,. n 11
. .
AMORTIZA TION SCHEDULE
Borrower: Rodger E. Sgrignoli
Loan Number: 289141
Term: 180
Payment Date of P&I In terest In terest Principal Principal
Number Payment Payment Rate Payment Payment Balance
78,940.00
1 08/01/2002 687.66 6.500 427.59 260.07 78,679.93
2 09/01/2002 687.66 6.500 426.18 261.48 78,418.45
3 10101/2002 687.66 6.500 424.77 262.89 78,155.56
4 11/01/2002 687.66 6.500 423.34 264.32 77,891.24
5 12/01/2002 687.66 6.500 421.91 265.75 77,625.49
6 01101/2003 687.66 6.500 420.4 7 267.19 77,358.30
7 02/0112003 687.66 6.500 419.02 268.64 77,089.66
8 03/01/2003 687.66 6.500 417.57 270.09 76,819.57
04/0112003 687.66 6.500 416.11 271.55 76,548.02
10 0510112003 687.66 6.500 414.64 273.02 76,275.00
11 06/01/2003 687.66 6.500 413.16 274.50 76,000.50
12 07/01/2003 687.66 6.500 411.67 275.99 75,724.51
13 08/01/2003 687.66 6.500 410.17 277.49 75,447.02
14 09/01/2003 687.66 6.500 408.67 278.99 75,168.03
15 10101/2003 687.66 6.500 407.16 280.50 74,887.53
16 11101/2003 687.66 6.500 405.64 282.02 74,605.51
17 12/01/2003 687.66 6.500 404.11 283.55 74,321.96
18
19
01101/2004
02/01/2004
687.66
687.66
6.500
6.500
402.58
401.03
399.48
285.08
286.63
288.18
74,036.88
73,750.25
73,462.07
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QU~ Washington Mul.l
HOME LOANS
Customer Service: Tall free 1,866.926.8937 Se habla espanal
TOO: Dial 7-1-1 for relay assistance
For a refinance or purdl3se loan, call 1.866.888.5935
WWW.wamu.com
#BWNCLNN
#3900539240926396#
007957501 AT 0,292 "AUTO T40911117025-2516 2 MA1
1,,,IIf,,,III,,,,,I,I,I,I,,,I,I,I,I,,,,II,II,,,,.II,,,III.I,,'
RODGER E SGRIGNOLl JR
KYRA A SGRIGNOLl
11 N ENOLA DR
ENOLA PA 17025-2516
Your Next Payment
Next Payment Due:
Principal and Interest:
Escrow:
Current Payment:
Total Amount Due:'"
$
$
$
cC
August 01, 2005
687.66
132.D9
819.75
81~
.
00795750079917
Page 1 of2
!Important Messages
'" To avoid a late charge of $27.51, we must receive your
payment of principal. interest, and any escrow deposits
and/or past-due payments by 08/16/05 during our business
hours. ff this di'tte faUs on a weekend or holiday, your
payment must be received by the next business day.
Please see the reverse side for Recent Account Activity.
II Washington Mutual
HOME LOANS
RODGER E SGRIGNOLl JR
KYRA A 5GRIGNOLl
loan Number:
Statement Date:
908-8
Home Loan Statement
July 2005
Statement Date:
Activity Since:
Your Loan Number:
July 19, 2005
June 15, 2005
0053240263
0053240263
July 19, 2005
o
o
Please write your loan number on your check.
Make check payable to Washington Mutual.
Pleas~ check here if change of address or telephone
number is indicated on the reverse sid", of this form.
Your Property and Loan Information
Property Address: 11 N ENOLA DR
ENOLA PA 17025
68,506.19
6.50000%
805.67
Principal Balance:
Interest Rate:
EscrolN Balance:
$
$
1..1,1,,,11,,1.11..1,,,11.11,,,,,1,1,,,11.1,,1,,,11.1,,1..1.11
WASHINGTON MUTUAL
PO BOX 830214
BALTIMORE MD 21283-0214
11,1,1"111,,111,,1111,1,111,,111,1,1,11,,,11111,1,1,,1111,,111,,1,111,1
Did You Know?
When a natural disaster strikes, be prepared with First
Protector. This insurance pays your monthly mortgage
payment when a disaster occurs. Call us today toll-free
1-800-349-9756 for info, such as costs, limitations and
Exclusion:,;.
Year to Date Account Activity
Principal Paid"
Interest Paid:
Property Taxes Paid:
Insurance Paid:
Late Charges Paid to Date:
$
$
$
$
$
2.593.53
3,D31.21
239.37
313.00
247.59
Washington Mutual Bank
9088 j:DJ~ e
Please allow ].10 days for postal delivery.
Payment Due Date: August 01, 2005
Current Payment: $ 819.75
Total Amount Due: $ 819.75
If Received After: August 16, 2005
Total Amount Plus late Charges: $ 847.26
Making Your Payment
Please write in any additional funds that you may be incfuding
with your payment. If you incfude additional funds and do not
indICate how to apply them. we will apply them first to applicable
advances, then to any fees due and then to principal.
Late Charges
Additional Principal
Additional Escrow
+
+
+
Future Payments
+
Total Amount Enclosed
0000000 0000000 0000000 0053240263 0081975 0002751 oD81975 7
Build and Price a New Car - .Aguides.col11
.
Page 1 of2
Vehicle Pricing & Information
noccguidos_<:orr
November 01,
2005
Autos . Motorqdes . Bclcds . Clauk CaIs . llecnalIon VehIdes . Ma IIaoMs
~
4~Door Sedan
2000 Chevrolet CBvalier-L4
Sedan 4D
AverageTradeMln A.verage Re.tail
B;:Jse P,ice
$3,500
$4,775
Mileage
42,000 miles
$700
S700
Options
Compact Disc Player (Std Z24)
$50
$75
TOTAL PRICE
$4,250
$5,550
Other Vehicle Information
Model Number: JC5
Weight: 2676
Average Trade~ln
An Average Trade-In vehicle should be clean and without glanng defects. Tires and glass should
be in good condition. The paint stlOuld match and have a good finish. The interior should have
wear in relation to the age of the vehicle. Carpet and seat Upflolstery should be clean and all
power options should work. The mileage should be within the acceptable range for the model
year. The "Average Trade-In" value is a national average calculated from the Officjal Used Car
Guide's ten regions. The "Average Trade-In" value for your vehicle could be higher or lower than
the national average due 10 your local market conditions.
Average Retail Value
An average retail vehicle should be clean and without glaring defects. Tires and glass should be in
good condition. The paint s~lould match and ~lave a good finish. The interior should have wear in
relation to the age of the vehicle. Carpet and seat upholstery should be dean, and all power
options should work. The mileage should be within the acceptable range for the model year
An Average Retail vehicle on a dealer lot may include a limited warranty or guarantee, and
possibly a Current safety and/or emission inspection (where applicable).
Note: VehiCles with low mileage that are in exceptionally good condition and/or Include a
manufacturer certification can be worth a srgnincantly higher value than the Average Retail price
shown.
Finding the exact car you want
doesn't have to be overwhelming.
AutoTrader~i
~.~liJ.t~.I.UU.;~li:];I'f"\
Kelley Blue Book - Private. Pricing Report - Chevrolet, Cavaliee
Page 1 of2
e>.~
~. N.'.'. Kelley Blue Book
~ THE TRUSTED RESOURCE
':. . kbb.com
(,Jh~n.I';('ir;,'
IntllJi:,l rriaY'ifIIY, A~;';kili;e l::(ul"U :j:j)4.
Quick Dealer Price Quote
I;.1SED eAF'S
Search Used Car listings
Us
'"
BLUE BOOK' PRIYATE PARTY REPORT
Pennsylvania. November 1,2005
2000 Chevrolet Cavalier Sedan 40
BlUE BOOK
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S!larch Listings for This Car
LisLYour Car For Sale Online
QjJick New Car Price Quote
FleeCARFAX Record Check
Auto Loans from 5.19% APR
Insurance Quote
Print "For Sale" Sign
Payment Calculator
Q
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6
VE
find exact
you want.
Engine: 4-Cyl. 2.2 Liter
Trans: Automatic
Drive: FWD
Mileage: 42,000
Air Conditioning
Power Steering
AM/FM Stereo
Single Compact Disc
Dual Front Air Sags
ASS (4-Wheel)
Equipment
Consumer Rated Condition: Good
"Good" condition means that the vehicle is free of any major defects. This vehicle has a
clean title history, the paint, body and interior have only minor (if any) blemishes, and
there are no major mechanical problems. There should be little or no rust on this
vehicle. The tires match and have substantial tread wear left. A "good" vehicle will
need some reconditioning to be sold at retail. Most consumer owned vehicles fall into
this category.
Private Party Value Sea ":_h Local Listings I List This Car tor Sale $4,215
Private Party Value is what a buyer can expect to pay when buying a used car from a
private party. The Private Party Value assumes the vehicle is sold "As Is" and carries
no warranty (other than the continuing factory warranty). The final sale price may
vary depending on the vehicle's actual condition and local market conditions. This
value may also be used to derive Fair Market Value for insurance and vehicle donation
pu rposes.
Getal,Jsed Car Jr?l9.e-In V21J~~
Get Invoic~ 8d~SRP on N~w Cars
v d_/"V", . ulevrolet. CavaE.
.
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.dINTRODUGING:THE ALL-NEW COBALT COUp'"
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lIid'a de:i1e-t Take a tesl drive. Go'"
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_ NEWCAU .
Quick De.aler Price Quote Search Used Car Listings Lis
~fil.S'j:"_m!!!""I~.i"':
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BLUE BOOK' TRADE-IN VALUE
Pennsylvania' October 24, 2005
2000 Chevrolet Cavalier Sedan 40
~
Sea rch LJ ?llDll~Qr.IlJ cS. Gar
List Your Car F or Sale Onli.r1.e
Quick New Car Price Quote
Free CARFA!'-.EfcordC.be9<
6uto Loans_ fro_1Jl.5~1~'Y'_AfOR
ln~lL(jlnq~~l,Lote
>:?YrTle n t~.?LcuJ.?tor
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Engine: 4-Cyl. 2.2 Liter
Trans: Automatic
Drive: FWD
Mileage: 42,000
Equipment
Single Compact Disc
Dual Front Air Bags
ABS (4-Wheel)
Air Conditioning
Power Steering
AM/FM Stereo
Consumer Rated Condition: Good
"Good" condition means that the vehicle IS free of any major defects. ThiS vehicle has a
clean title history, the paint, body and Interior r'2"je only minor (If any) blemishes, and
there are no major mechanical problems. There s!;ould be little or no rllst on thiS
vehicle. The tires match and have substantial trea:J wear left. A "good" vehicle will
need some reconditioning to be sold at retail. Mos~ consumer owned vehicles fall Into
thiS category.
Trade-In Value ~:i~ Your Car For Sale Online $2,970
Trade-in Value is what consumers can expect to receive from a dealer for a trade-In
vehicle assuming an accurate appraisal of conditIOI". This value will likely be less than
the Private Party Value because the reselling deale' 1.1curs the cost of safety
inspections, reconditioning and other costs of dOing business.
NEXT STEP:
Get New Car Pricing
httpllwww.kbb.comlkb/kidlllkw kc ur"kbb PA.~730 11.1)\041 & 170 I ]snrl+t.l',,)70J"
WJE EOa:
k
carS.com
other por
ad:
I
BSTSWLDP 3105
~~R ASSISTANCE CALL: 800-200-4622
MAKE/MODEL: 01 CHEV CAVALIER
VIN: 1G1JC524117213310
ACCOUNT NUMBER:
;:~~lh~;~"'~ ~.~'~~
DU' SCHEDULED
DATE PAYMENT
03/19/04 348.96
04/19/04 348.96
05/19/04 348.96
06/19/04 348.96
07/19/04 348.96
08/19/04 348.96
09/19/04 348.96
10/19/04 348 96
11/19/04 348 96
12/19/04 348 96
01/19/05 348.96
02/19/05 348.96
03/19/05 348.96
04/19/05 348.96
05/19/05 348.96
06/19/05 348.96
07/19/05 348.96
08/19/05 348.96
TOTALS 17.099.04
. -, ,~..":.... "', . ;:;..'"
.
GMAC.
.~~_ ~ou 'OIl """"""0<<; ~"'-"' OO!~'U ""ID "...,,,
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PAGE 2 OF 2
--
=
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020 0676 0 1382 STATEM,NT REFLECTS PAYM'NT(S) R,CEIV,D
- - FRQM:04/04/01 THRQUGH:09/21/05
R~HISTORY - - - - PA YMENTS APPLIED AS FOLL . WS.
I
DATE
PAID
PA YMENT
AMOUNT
LATE
CHARGES
EXTENSION
FEES
OTHER
CHARGES
05/07/04 350 00
05/31/04 672 .66
06/16/04 350 00
07/26/04 350 00
08/23/04 350. 00
09/27/04 350 00
10/22/04 350. 00
11/18/04 350 00
01/03/05 343 15
01/31/05 350 00
02/28/05 350 00
03/21/05 350 00
05/02/05 345. 41
OS/26/05 348 .96
07/05/05 348 96
08/01/05 348 96
09/06/05 348 .96
17 ,099 .04
55.61
6.85
4.59
1.04
1. 04
1. 04
16 04
173.63
287.52
#REMAINING DAYMENTS: 11
MESSAGES
GENERAL MESSAGES
THIS STATEMENT WAS ISSUED ON YOUR REQUEST.
'SAVE TIME AND POSTAGE EACH MONTH BY HaVING YOUR MONTHLY PAYMENT AUTOMATICALLY
WITHDRAWN FROM YOUR CHECKING OR SAVINGS ACCOUNT! VISIT
WWW.GMACfS.COM/OIRECTPAY/ TO ENROLL IN GMAC DIRECT PAY AUTOMATIC.'
THE PAYMENT HISTORY REPORT REPRESENTS PAYMENTS
RECEIVED ON YOUR ACCOUNT - NO ACTION IS REQUIRED /
FOR YOUR INFORMATION ONLY
'''~B'
-1.'j'~~~,,:';
TOTAL
PAID
350
728
350
350
350
350
350
350
350
350
350
350
350
350
350
350
365
17.560.
.
GMAC.
PO BOX 10~677
ATLANTA GA 30348
T~"'''' '<XJ FOIt c...,..~.""", Ol["l(~ ,,"" C.....t
FOR ASSISTANCE CALL: 800-200-4622
---
......
KYRA A $GRIGNOLI
424 DUKE 5T APT F
ENOLA PA 17025
=
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-
~AKE/MODEL: 01 CHEV CAVALIER
vIN: 1G1JC524117213310
PAGE 1 OF 2
.....
ACCOUNT NUMBER: 020-0676-01382 STATEMENT REFLECTS PAYMENT(SJ RErEIVED
FROM:04/04/01 THROUGH:D /21 05
AYMENTHISTORY - - - - PA YMENTSAPPL1ED:AS FOLLOWS ::'~'~~:~ ~-~~:~:/.
DUE SCHEDULED DATE PAYMENT LATE EXTENSION OTHER TOTAL
DATE PAYMENT PAID AMOUNT CHARGES FEES CHARGES PAID
05/19/01 348.96 05/18/01 348.96 348.
06/19/01 348.96 06/19/01 348.96 348.
07/19/01 348.96 07/19/01 348.96 348.
08/19/01 348.96 08/20/01 348.96 348.
09/19/01 348.96 09/19/01 348.9E 348.
10/19/01 348.96 10/22/01 348.96 348.
11/19/01 348.96 11/19/01 348.96 348.
12/19/01 348.96 01/14/02 348.96 348.
01/19/02 348.96 02/11/02 156.97 156.
03/08/02 160.00 160.
03/21/02 225.00 225.
02/19/02 348 .96
04/01/02 . 210.00 210.
03/19/02 348 96
04/24/02 225.00 225.'
OS/21/02 420.00 420.(
J4/19/02 348.96
05/19/02 348.96
06/10/02 347.83 347.1
06/19/02 348.96 07/01/02 348.96 16.04 365.(
07/19/02 348.96 08/01/02 348.96 25.76 374. ~
08/19/02 348.96 08/29/02 348.96 348. ~
09/19/02 348.96 10/18/02 348.96 13.94 362. ~
10/19/02 348.96 11/21/02 348.96 348.f
11/19/02 348.96 01/06/03 400.00 400.(
12/19/02 348.96
01/24/03 318.83 318 E
01/19/03 348.96
02/12/03 348.96 348 S
02/19/03 348 96
03/13/03 355.52 355 C
03/19/03 348 96
04/25/03 350.00 350.C
04/19/03 348.96
06/02/03 350 00 350.0
05/19/03 348.96
07/07/03 350 00 350.0
08/19/03 .05 287.52 287.5
09/19/03 348.96
09/18/03 348.96 348 9
10/19/03 348 96
10/20/03 348.96 348.9'
11/19/03 348 .96
11/21/03 318.37 31.63 350.0
12/19/03 348 96 01/27/04 371.10 371.1<
01/19/04 348 96
02/16/04 350.00 350.C
02/19/04 348 96
03/26/04 350.00 350.(
THE PAYMENT HISTORY REPORT REPRESENTS PAYMENTS
RECEIVED ON YOUR ACCOUNT - NO ACTION IS REQUIRED /
FOR YOUR INFORMATION ONLY.
".T5T
NOV-02-2005(WEOl 09' 3D
RUd.HarrlSburg Reg Off (FRX1. 783 7'ld
P ODI/OOI
Page 1 of I
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Read Email
Reply I Delete I Close I
1'(om: The Other Account Questions Department
To: RODGER SGRIGNOLl (0197581532)
Subject: Acct balance as of 12/27/2002
Dato: 10/4120051:21:54 PM
Dear RODGER SGRIGNDlI: Thank you for contacting us. I was able to locate the
bal:lnces as of 12/27/2002; the S01, Regular Shares was 524.84, and the S4.
Checking Shares was 51B73.98. If we can further assist you, use the Contact Us
tab for e-mail options, phone numbers and hours 01 operation. Sincerely, Usa (114)
,
,
,
1
Reply M€lr.sago
j
From;
To:
Su bJeet:
Date:
RODGER SGRIGNOll (0197581532)
The Other Account Questions Department
Acct balance as of 12/27/2002
1014/2005 B41:3BAM
~
,
!!
:1
"
Yes. No.
Reply Ml';lSJ;3ge
From:
To:
SubjQct:
Date:
The Other Account Questions Department
RODGER SGRIGNOll (01975B1532)
Acct balance as of 12127/2002
10/3120052:3338 PM
Dear RODGER SGRIGNOll: Thank you for contacting us. In response to your
"mail; I am abl" to provide some Information via email. Are you looking to have
only the balances provided as of 12/27/027 Is thiS something that you are needing
to provide for a mortgage? If we can further assist you, use the Contact Us tab for
e.rnail options. phone numbers and hours of operation. Sincerely Lisa (1 14)
~_~____.___._________ Origiot:ll Mel:>8oge
From:
To:
SUbJoct:
Date:
RODGER SGRIGNOLl (0197581532)
The Other Acoount Questions Department
Acct balance as of 12127/2002
10/3/20059:12:42 AM
Can I have the Info. emailed to me7 Thanks, Rodger
hUrs:1 n,ol11ebank. psccu_cornlhomcb'lDklErnaillrcadcmail.asp ?LlD=& Ernail~kssagcID=42... 110.12005
.
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KlRA A SGRIGNOLl
\1 N ENOlA OR
ENOLA PA 17025~2516
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.
Page 1 of I
\ ~
STATEMENT DATE \
11503 )
/
,////
------
-
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SPECIAL LIMITED TIME OFFER' ASK US tECUT OUR lOW
FIIED.RATE HOME EQUITY lOANS TODAYI 4LPRY THESE
RATES WON'T LAST' CALL 1~866.929.76~~ 'OOAY'
ACCOUNT TYPE Of ACCOUNT
900039843 TOTALLY fREE
---~_________~_______________L_____________
PREVIOUS BALANCE
OEPOS ITS
WITHDRAWALS
CHARGE S
I NTf RE 5T
ENDING BALANCE
~ - - - - - - -. - - INTEREST SUMMARv.
INTEREST PAID THIS YEAR
INTEREST ~lTHHElO THIS YEAR
,
TRANSACTION SUHH'f'
DEPDS iT' /
CREDIT:
------
DATE TRANSACTiON OESCR/PTION
1211..
12/13
12/23 CHECK 2341
12/24 DEPOSIT
12/24 CHECK 2342
12/~7 lENSCRAFTERS
111 1
11/ I CHEC~ 234)
1103 CHECK 2344
1/03 CHECK 1345
1/07 CHECK 2335
1107 CHECK 2346
1/\0 LEM5CRAfTERS
1/1 0 CHECK 2349
1/13
\113 CHECK 2349
1/13 CHECK 234B
1/13 CHECK 2347
1/15 SERVICE CHARGE
654 42
PLCI22402
50 [0
692.['
PLC 11 8/ 03
, .CHECKS PAil
NO. DATE AMOUH C DATE
2335 }'07 400.00 2 44 !-O3
1341' 12.23 16 35 , 45 1.03
2342 1224 71 .95 2 45 1.07
2343 12.31 44 96 2 ~ 7 1.13
CONTINUED ON Nf IT , GE
CHE CK SI
DEBITS
120 GO
200.00
16 35
71 95
]00.00
l4 96
600 00
39 45
400.00
19.11
40 00
100 DO
4134
25.00
21 04
1 00
AVERAGE BALANCE
1.196 97
403 9\
.396 49
.B40 20
1.00
00
95B 20
,
00
.00
BALANC:
l1B3.91
1083 91
1067 56
1117 56
,J~
1 .
1592 7!
,91"
953 26
553 16
534.15
118B 58
1148 58
1048 58
1006 24
981.24
960 20
958 20
,
AMOUNT
600.00
39.45
19 II
2104
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1 nil It I""I"F'I~
~2-2;-2002
DDA/NOW ACCOUNTS
TRANSAC7ION SYST~M
ACCOUNT SHORT NAME
NUMBER
900039843 SGR!GNOLI KYRA A
R
C
CURRENT
BALANCE
1, 7 3 ~ . 6'
.
WAYPOIN':" BAN!\
SUHMERDALE
TRIAL BALANCE
HOLDS S COLLEC
.r.. BALP.NCE
,--AS7
.:=11V~
~: -:., -02
'---LAST
DATE
12-21-02
~PROCESS-T~RC
DEPOSIT---
AMOUNT
692.06
12-27-02
CHKS
SINCE
,
12-29-2002
21:25:12
DEe
SINCE
PRY 5TH
DATE
12- ~ 5- 02
PAGE 405
rA033C
20-0010
STM! S.C.S TOOl
7' CY C - T Y D
C 1512 R 110499 z:
1<../ J '_.1
1<
11\
. COMM01't'VIEAl TIi OF PENNSYLVANIA
TATE EMPLOYEES' RETIREMEC'lT SYSTEM.
TOLL FREE: 1-800-633-5461
www.sers.staie.pa.us
[R;
2002 STATEMENT OF ACCOUNT
For:
RODGER E SGRIGNOLI
BASIC DATA
Personal Data
Account Balance
SDC~! Security Number'----_________ 197-58-1532
Sex: MALE Birth Date: 28-MAY-1962
_'__ ___~_..__o__~__.___~.____.___.___.___~___
Coverage TJPe:____ _____________._._-.!:.ULL
Contribution Rate: 6.25%
.-----..~.~--_._--_._--_.
Counselinll, Center:___ HARRISBURG
Normal Retirement Date: 28-MAY-2022
--.-----...
Final Average Salary: $39,729.42
2002 Retirement Covered Earnings: $43,365.37
--~~_._------_._._---- -...------.-
Total SSI Non-Covered Earnings:
___.__...____u _________0.__
Joint S:over~e Co~vers~on!tmount:_._____..__________.__
~andat()ry_~'2'Cbt: _____..__________________
Service Purchase Debt:
Service Credit as of December 31, 2002 *
Class
AA-60
Years of Service Class
8.1400
Years of Service
TOTAL SERVICE 8.1400
-
Principal Beneficiary(ies) **
-
KYRA A SGRIGNOLI
- -"
f-------------------.- -~----_._----
------------------ -_.~- -.- --
-..-
* If you are eligible to purchase creditable state and/or non-state
service, contact your Retirement Counselor for information on
purchasing service. All requests to purchase service must be
filed while you are an active, contributing member.
** Information filed on a Nomination of Beneficiary{ies) form
before 1993 or since December 31,2002, or involving special
circumstances (such as the designation of an estate or trust as
your beneficiary may be shown here; however, you may have
more beneficiaries on your retirement record. Keep your
beneficiary information current. You may change your
beneficiary nomination at any time by filing a new Nomination
of Beneficiary(iesj form with SERS. Forms are availahlefrom
your agency Personnel Office or your regional SERS Retirement
Counseling Center. Please contact us if you do not want your
beneficiary(iesj listed on future Statements.
I IIIIIIIIIII~ 1111111111111111111111111111111I1111111111111111111111111111111111111111111/1111111111
*2LO004055*
Regular
Contributions
55!
Contributions
December 31, 201Jl...Ba!an,,-,--~12,050.8o...~~_______
Contributions . $2,710.36
--------.--.--.--------
Lump Sum Payments
Arrears Payments
Credited Interest
YTD Adjustments *'*
December 31, 2002, Balance
I TOTAL DEDUCTIONS
$536.67
-- ------r----- - --
$15,297.83 .
$15,29'1.831
Arrears Balance as of December 31, 2002
Regular SSI
Taxable Breakdown of Your Account ****
Taxable Contributions $12,991.62
Pre 87 Non-Taxable Contributions
f-- ~------ -
Post 86 Non- Taxable Contributions $382.20
-.-----.-
Credited Interest (Taxable) $1,924.01
d --~
December 31, 2002, Balance $15,297.83
*** YTD (Year-To-Date) Adjustments reflect corrections to
your account for which you already have received notification.
**** SERS is a defined benefit plan under Internal Revenue
Service Code Section 401 {a}.
SPECIAL CONDITIONS
The following Special conditions apply to your benefit estimates
or reasons estimates were not calculated:
111/1111111111111111I111111111111111111111111111111I111111111111111111
03073D300~SERSOA-7 -650-8212
~
ENV#OP009803---
OP 0505: E
1)~ OJl (Cc CPVLt~~
Retirement Savings Statement. .j'
Apnl 1, 2005 . June 30, 2005 .
Luxottica Group
Retirement Plans
KYRA A SGRIGNOLI
424 DUKE ST
lIF
ENOLA, PA 17025
~ Cuslomer Service Number: 1.800-742-4015
To make changes to your account, call the Customer
Service Number between 8:30 AM and 8:00 PM any
business day.
Your Cash Balance Pension Plan Account Summary
Beginning Balance
Company Contributions
Interest
Ending Balance
Vested Balance
Vested Percent
Date of Hire:
Date 01 Birth:
Cash Balance Pension Plan
$4,7t5.72
406.34
40.73
$5,162.79
$5,162.79
100.00%
02/14/2000
11/26/1960
For questions regarding your Cash Balance Pension account, please contact your Benefils Department.
If you are a terminated Associate and have a balance j!1 the Cash Balance Pension Plan, please note the following: . If 100%
vested and your account is less than $3.500, you will be contacted automatically in the quarter following your termination about
withdrawing your balance.
. If 100% vested and your account is greater than $3.500. you Will be eligible for distribution at age 65 or early at age 55 IT you have
attained 10 years of service.
- If 0% vested, your balance will be forfeited. You should receive a final statement at the end of the next quarter following your
forfeiture.
--""'-',ou an, aJ,~;...~. .lIgj~j8 b.~8e8:.at8 1_ r: t:~p;;hv--i;+-'I~8-j0-4;~1 S~s P.L!.':!_~ never ~C'o !~ls' ~c ~t;\.Cl5_~ving_ Talc:~ ~tjv;:HllaQe
of the tax savingS>company match and money accumulating opportunities the Plan provides. A little money saved early can r,~
worth more than a lot saved later.
Please read this statement carefully Any error fnlsl be reported to Fidelity Investments within 90 days
9803 OP009803
0001 20050728 OP4K
Page 1 of 1
JOSEPH H. BONNARIGO
Twp. Engineer/P.W. Dir.
JEFFREY SHULTZ
Bldg. Inspector & Code Enforcement Officer
ROBERT GOULD
Code Enforcement Officer
.
.
JOHN B. OWEN
Oir_ of Housing & Community
DevelopmenVZoning Officer
KAREN DUNKLE
Health & Code Enforcement Officer
JOYCE STOM
Department Secretary
EAST PENNSBORO TOWNSHIP
March 18, 2005
Rodger E & Kyra A Sgrignoli
11 N Enola Dr.
Enola, PA 17025
RE: PennDOT/East Pennsboro Township
Resurfacing - Curb and Sidewalk Project
Parcel No. 09-14-0832-362
Dear Rodger E & Kyra A Sgrignoli:
The Pennsylvania Department of Transportation (PennDOT) is scheduled to resurface the
following State routes in East Pennsboro Township this summer:
. Beginning at the intersection of Wertz vi lie Road and S. Enola Drive - North to
Valley Street
. Beginning at the intersection ofRT ll1l51Columbia Road to N. Enola Drive
In conjunction with this major PennDOT project, the Board of Commissioners has
authorized the following:
-------
. New curb and sidewalk improvement project from Wertzville Road to Dauphin
Street (Both Sides)
. A contract for a sanitary sewer replacement project on N. Enola Drive from
Fulton Street to Dauphin Street and on a portion of Fulton Street towards Brick
Church Road.
Pursuant to the Township's Ordinance No. 690-05, which was adopted by the Board of
Commissioners of East Pennsboro Township on Wednesday, March 16, 2005 and according to
the First Class Township Code, the Township has authorization to assess each property owner
for the costs to install curbs and sidewalks.
Upon completion of this project, each property owner will be invoiced for the installation
ofthe curb and sidewalk based on your property's frontage. Each property owner will be given
the opportunity to set up monthly installment payments and will have up to three (3) years at 0%
interest to pay for your assessment.
98 South Enola Drive. Enola, PA 17025-2796 . [717J 732-0711
.
.
PennDOT will be bidding out this project in May 2005 and construction is expected to
start the first week of July with completion sometime in September.
PennDOT has estimated the costs for installatio'1 ')fthe curb to be $25.00 per lineal foot
and the concrete sidewalk will be $42.00 a square foot.
The Township has svrveyed this area and has calculated your street frontage to be 40.2'
feet After calculating your frontage the cost of your curb will be$l 005 with a 0% credit and the
cost of your sidewalk will be $1688.4 with a 0% credit.
Based on PennDOT's estimates, your curbing and sidewalk assessment will be $2694.
You will receive a credit of $0 making the balance due East Pennsboro Township $2694.
This major joint improvement project between PennDOT and East Pennsboro Township
will enhance your neighborhood and will definitely improve the safety factor for all pedestrians
who utilize your sidewalks.
Please review your deed for the accuracy of your property frontage and jf you have any
questions or discrepancies with the above information, please feel free to contact one of the
following: Mr. John Pietropaoli, Assistant Township Manager; Mr. Joseph Bonarrigo, Township
Engineer or myself at (717) 732-0711.
Any appeals concerning your assessments andlor credits must be received in writing by
Friday, April 22, 2005.
If you are in agreement with the assessment for your curb and sidewalk, please sign the
attached agreement and forward it in the enclosed envelope.
Thank you for your cooperation in this major public improvement project
Sincerely yours,
Robert L. Gill
Township Manager
RLG/dt
Enc.
POBOX 13561
Oep! 22
Philadelphia. PA 19 III I
.
NCO FI&NCIAL SYSTEMSINC
800-685-4343
OFFICE HOURS
8AM-MIDNIGHT MON THRU THURSDAY
8AM-9PM FRIDAY
8AM-6PM SATURDAY
NOON- 1 OPM SUNDAY
lun 4. 2003
DN1677
11111111111111111111111111111111111I11111111111111
RODGER E SGRIGNOLI
11 N ENOLA DR
ENOLA, PA 17025
CREDITOR/ORIGINAL
INSTITUTIONCRDTRST ASSIGNEE OF MBNA AM I
ACCOUNT #: 5329005999261391
REGARDING:MBNA
BALANCE PAST DUE:$ 9211.62
* * * SETTLEMENT OFFER * * *
We have becn authorized by the above referenced client to accept $2302.91 as a lump slim of the above amount so long as
payment is rcccived within 30 days of the date of this letter.
Make your chcck or money on':cr payable to our clienl and forward to the address listed below.
If you have any fUlther questions or need assistance, please contact us at 800-685-4343.
This is an attempt to collect a debt. Any infonnation obtained will be used for that purpose. This is a
communication from a debt collcctor.
PLEASE RETURN THIS PORTION WITH YOUR PAYMENT (MAKE SURE ADDRESS SHOWS THROUGH WINDOW)
------------------------------------------------------------------------------------------------------------~----------------------------------------------------
Account #
DN1677
RODGER E SGRIGNOLl
Payment Amount .
Total Balance
$ 921 1.62
$
Check here if your address or phone number has
changed and provide the new information below.
Make Payment To
1,.,111,1"",1111......11...11,1,.1,',.11,,1,,',,11,.'.1,',,'
NCO FINANCIAL SYSTEMS
PO BOX 41448
PHILADELPHIA PA 19101
Neo E1
9873
nt?200DN167720000001500000000009211629
.
. ven.t \nc.
. r Reco · J
prell\\e (859) 655-7670
phone Number.
pO 80x 2658 41012-2658
covington KY CE REQUE5TEO
"555ERVI
AOOR"-
APril 30, 2003
IER RECOVERY INC
PREM tn 5t 5te 110
525W5 KY41011-1262 II 1111..1.1..1..11
covington \\ \\111\\1I\.h 1111 I It
\,\"\111\\\\11"1' III
11351 I
8540-19g 364287 1\.11.....11,..111.\..
~2~1I...II\...'.\~I.I.II'.~;\~~~;~ A 5grignoli
1I r: 5g09no \
Rodger"
11 N Enol~~~25_2516
Eno1a PI"
Account #
A.mOunt:
4060950090092508
$ 534244
-
h*Detach Upper Portion and Return with Payment'"
NAVY FEDERAL CREDIT UNION
Account#: 4060950090092508
Balance: $ 5342.44
Dear Rodger E Sgrignoli Jr & Kyra A Sgrignoli
This letter is to inform you that your account has been placed with our company.
Unless you notify this office within 30 days after receiving this notice that you dispute the validity of this debt or any
portion thereof, this office will assume this debt is valid. If you notify this office in writing within 30 days from
receiving this notice, this office will obtain verification of the debt or obtain a copy of a judgment, if one has been
obtained, and mail you a copy of such judgment or verification. If you make a request in writin9 within 30 days
after receiving this notice, this office will provide you with the name and address of the original creditor, if different
from the current creditor.
This is an attempt to collect a debt, and any information obtained will be used for that purpose.
This communication is from a debt collector.
Yours Truly,
Premier Recovery Inc.
John Steinberg
Collection Manager
888-773-8452
If you wish to pay by Visa, MasterCard, American Express or Discover, fill in the information below and return the
entire letter to us.
ACCOUNT NUMBER
PAYMENT AMOUNT
EXPIRE DATE
~-
I
,
$
CARD HOLDER NAME
10NSOUT20199
SIGNATURE OF CARD HOLDER
~llmlmln.n.~lml~
PO Box 551268
Jacksonville FL 32255
ETURN SERVICE REQUESTED
.
Diversified Wlnsullanl3, ~m".-------
PO.551268
Jacksonville, FL 32255
(800) 771-5361
May 8, 2003
Re: T-Mobile, formerly Voice Stream Wireless
Client Ref#: 170361674
Account #: 706614
Balance: $131.37
706614 - 0200 - 006314
Robert E Sgrignoli
II N Enola Dr
EnolaPA 17025-2516
1,"111..,11I11,"1.1,1,1",1.1,1.1""11,11,,".1111I111.1"1
Diversified Consultants, Inc.
PO Box 551268
Jacksonville FL 32255-1268
1111111I1.1,,1.1.1.1..1.1111111..1.1.11.,1111..11..1.,111,1.11
u* Detach Upper Portiml and Retnrnwith Paymt'nt u..
DIC()120008E73066S1
Re: T-Mobile, formerly VoiceStream Wireless
Client Ref#: 170361674
Account #: 706614
Balance: $13 1.3 7
Our attempts to contact you regarding your serionsly past due account have been unsuccessfuL It is important that
you contact us to discuss payment oftms account. Failure to comply with this demand may result in further collection
activity.
This is an attempt to collect a debt Any and all infonnation obtained will be used for that purpose. This
communication is from a debt collector.
Hours of Operation:
8:00am. 9:00pm Monday - Thursday. Eastern Standard Time
8:00am - 5:00pm Friday. Eastern Standard Time
8:00am ~ 12:00pm Saturday <> Eastenl Standard Tmje
P.o. Box 18036
ffollppallge, NY 11788-8836
Address Service Requested
.
Tel: (57IJ) 347-1115 ~, (570)963,1644 Nee
..I dh'/s/O// of NOR THE A S T
Commonwealth Financjal S),'stems, lnc.-...;_II..-....'....:;:..n.l.'''-
Personal & Confidential
December 102003
Regarding: CTSI
Original Account #: 7177326235
Amount Due: $ 117.46
#BWNBZWJ
1038198'39
RODGER E SGRIGNOll JR
11 N ENOLA DR
E PENNSBORO PA 17025,2516
Send To:
NORTH EAST CREDIT & COLLECTION
120 N. KEYSER AVENUE
SCRANTON, PA 18504
1..,/11,.1"1,1,"....1..11.1..1...111....,,11.,1,111.,,,,11.I
,. _ ,. ___' _____.'__ ,___.__________E!?-'l?_~ J!~t'!f_h._6'lg,R!1.tYrD_Jn_TJJQ_~QfJQ~-',9._I;'lyJ'.LQP_?_'!Yitb.YQ~Lf'a.'i!l1.?!lL_,_ ._______,____'__________h ,___,_______,_,_
[Il:eg~r<ling: CTSI
lOriginal Ace. No: 7177326235
--,.----$117"46-- -J
_____.._J_______ __
Dear: Rodger E Sgrignoli Jr
This is a statement ofyonr current balance for the above referenccd debl(s). This is the balance as of the date of this notice. Thank
"')U for your cooperation.
This is an altemptto collect a debt any infonnation obtained will be lIsed for that purpose
Sincerely
Ameya Smith Ext. 280
(800) 848-2170
TO PAY USING OUR AUTOMATED CREDIT CARD LINE CALL 1-800-816-3442 OR
fiLL IN THE INFORMATION BELOW AND RETURN THE ENTIRE LETTER TO us.
I AUTHORIZE MY CREDITOR TO CHARGE MY OBLIGATION TO THE CHARGE CARD BELOW
~
ACA
o DISCOVER 0 VISA
o MASTERCARD
o AMERICAN EXPRESS
]1<1 OR ~~Tl 0''''"
~ ~ r-'---ITilTlllITIIJ iTIII
Acc.ounl# ~L----1~~L~ L.J_.'----L.J Exp[rati.onDate
AifI
C Card Holder Name
ell]
E
~.
[I] /0]
Amoco< LOTI. Cll
Signature
Date
Please return top portion with payment.
se~erse side for return address.
CHASE ALITO I-'INA EASE
RE. RODGER SGRJGNOU
Date. AUGUST 12, 2003
Creditor. CHASE AUTO FINANCE - LEASE
Account Number' 4970981647
Balance Due' $389.75
Control Number. 45261790-])
--
$311.80
A SETTLEMENT OFFER
Please be advised that we are a professional collection agency.
We have been authorized to offer you the opportunity to settle this account with a lump sum payment
for 80% of the above balance due, which is equal to $311 .80.
This ofter will be valid for a period of thirty-live (35) days from the date of this letter.
above.
Jf you have :my questiop~~ regarding this offer, r!~:ase cnnt:.lct this office at the p\llnner(s) provirled
Unless you HOliry (his office within 30 days after receiving this notice that yon dispute the validity of
this debt or any portion thereol, this office will assume this debt is valid.
If you notify this omce in writing within 30 days from receiving this notice, this office will: Obtain
verification of the debt or obtain a copy 01 a judgment and mail you a copy of such judgment or verification.
. If you request this office in wri~iqg within)O d?ys.a~er receiving this notice, thjs office will provide
you wnh the nallle and address of the ongmal creditor, If different frOIll the current crednor.
This cOIlnllunication is from a debt collector and is an attempt to collect a debt. Any information
obtained will be nsed tor dtal purpose.
PLEASE ADDRESS ALL PAYMENTS TO:
Plaza Associates
JAF Station, PO Box 2769
New York, NY 10116-2769
Plaza Associates ~ 370 Sevendl Ave, New York NY 10001-3900 ~ 1-866-622-2025 ~ (212) 847-8125
24 Hours Website www.plazaassociates.com
Office Hours: Monday - Thursday
Friday
Saturday
8:00am-Midnight EST
8:00am-8:00pm EST
8 :DOalll- 5 :DOpm EST
P12ASl
PLZAS1.V7
'-~-'",n^ 11
POBOX 41417
DEPT 99
PHILADELPHIA PA 19101
.
11111111111111111111111111111111111111111111111111
NCO ~ANCIAL SYSTEMS INC
FORMERLY I'INANCIAL COLLECTION AGENCIES
507 Prudential Road. Harsham, PA 19044
800-520-3594
OFFICE HOURS
8AM-9PM MON THRU THURSDAY
8AM-5PM FRIDAY
8AM.12PM SATURDAY
Jul 8, 2004
95EH8Z
ROGER E SGRIGNOLI JR
11 N ENOLA DR
ENOLA PA 17025-2516
CREDITOR: GENERAL MOTORS ACCEPTANCE C
ACCOUNT #: 251547782
REGARDING PAST DUE BALANCE
TOTAL BALANCE $ 5336.38
The namcd creditor has placed this account with our office for collcction. It is important that you forward payment in full.
If you choose not to respond to this notification, we will assign your account to a collector with instfilctions to collect the
balance.
To assure proper credit please put our internal account number 95EH8Z on your check or money order and enclose thc
lower portion of this letter with your payment. If you need to speak to a representative contact us at 800-520-3594.
Returned chccks will be subject to the maximum fces allowed by your state.
Unless you notify this office within 30 days after receiving this notice that you dispute the validity of the debt or any portion
thereof, this office will assume this debt is valid. If you notify this office in writing within 30 days from receiving this
notice, this office will obtain verification of the debt or obtain a copy of a judgement and mail you a copy of such judgement
or verification. If you request this office in writing within 30 days after receiving this notice, this office will provide you
with the name and address of the original creditor, if different from the current creditor.
This is an attempt to collect a debt Any infornlation obtained will be used for that purpose. This is a
conununication from a dcbt collector.
___________________~.L:~~~_~__~~:r:I,IF3~_:r:~!~_~_?~:r:~?':!_\I'!L~!:I_:r:!?_LJ_~_!"~:r:~_~_~_~j~_~!5_~_:'!I,IF3_~_~~~F3!":'!:'!2~(J'^':'!TH_~_?1,I~_I:J_~!!'lQ,().'!!L___________
Account #
95EH8Z
ROGER E SGRIGNOLl IR
Payment Amount .
Total Balance
$ 5336.38
$
Check here if your address or phone number has
changed and provide the new informallon below.
Make Payment To:
1".111.1"",1111",..,11".11,1"1.1.1,1,,,1,1.1,1.,,11,1..1
NCO FINANCIAL SYSTEMS
PO BOX 41457
PHILADELPHIA PA 19101-1457
NCO A
1968
01990095EH8Z10000000100000000005336381
P.
111II1I1I1111illIlllIlllIIlllllllIlIIlIllllIllll~
Return Address:
MRS ASSOCIATES.INC.
3 EXECUTIVE CAMPUS. SUITE 400
CHERRY HILL NJ 08002
~.
3 Executive Campus, Suite 400
Cherry Hill NJ 08002
1-866-709-0912
Office Hours.
Monday - Thursday
Friday
Saturday
Sunday
8am - 9pm ET
8am - 5pm ET
8am - 12pm ET
9arn - 12pm ET
January 12, 2005
S-DK014670 L-001 A-05459131
P01ALF00201072 102145
RODGER E SGRIGNOLl
11 N ENOLA DR
ENOLA PA 17025-2516
1",111",111"",1,1,1,1",1,1,1,1""11,11"",11,,,111,1,,1
Payment To / Correspondence To;
MRS. ASSOCIATES, INC.
3 EXECUTIVE CAMPUS, SUITE 400
CHERRY HILL NJ 08002
111",1"1,11",11"",1,1,1"1",1111",,,11,11,,,11,""I,ll
CLT ACCT #: MRS ACCT # : ACCT. BALANCE
4970981650 05459131 $934.55
I RE: BANKONE
X IMPORTANT: ro Ri:::CE1VE PROPE:K CR~DjT BE SuRE TO EhiCLGSE THiS POR.TiOi>i .....ViTH YOUR PAYMEN7 iN FULL ~<
SEE REVERSE SIDE FOR CREDIT CARD AND WESTERN UNION PAYMENT INFORMATION
RE: BANKONE
CL T ACCT#: 4970981650
MRS ACCT#: 05459131
ACCOUNT BALANCE: $934.55
Office Handling Your Account:
M.R.S. Associates, Inc.
3 Executive Campus, Suite 400
Cherry Hill NJ 08002
1-866.709-0912
Dear RODGER E SGRIGNOLl,
The above referenced client has placed your account with our office for collection. This decision was made due to your
continued failure to meet your contractual obligation. If for some reason you believe this debt is not valid, please review your
rights listed at the bottom of this letter.
If the debt is not in dispute, then you have an important decision to make: honor your contractual obligation and receive
significant positive benefits from satisfying the debt or continue not honoring your contractual obligation and face the
possibility of negative consequences. The negative consequences are determined by the terms and conditions of your
contract, the applicable laws in your state, and our client's willingness to incur additional costs and expenses (which may in
turn be passed on to you!).
C!early our client would prefer to work with you than against you, however, the decision to proceed with further collection
activity is determined by you and your willingness to honor your commitment.
Which would you prefer the positive benefits or negative consequences? The choice is yours!
IMPORTANT CONSUMER JNFORMAT!ON
Unless you notify this office within 30 days after receiving this notice that you dispute the validity of the debt or any portion
thereof, this office will assume this debt is valid. If you notify this office in writing within 30 days from receiving this notice
that you dispute the validity of this debt or any portion thereof, this office will obtain verification of the debt or obtain a copy
of a judgment and mail you a copy of such judgment or verification. !f you request this office in writing within 30 days after
receiving this notice, this office will provide you with the name and address of the original creditor, if different from the
current creditor.
Sincerely,
f1.L~
J.Lawson
Director of Operations 1-866.709-0912
M.R.S. Associates, Inc.
fill
This is an attempt to collect a debt and any information obtained will be used for that purpose.
This communication is from a debt collection agency.
PLEASE SEE REVERSE SIDE FOR IMPORTANT INFORMATION.
.
.
AO 450 (Rev. 5/35) Judgment in a Civil Case
United States District Court
MIDDLE DISTRICT OF PENNSYLVANIA
JUDGMENT IN A CIVIL CASE
RODGER E. SGRIGNOLl, JR.,
Plaintiff
Civil NO.1 :cv-98-0768
Judge Rambo
v.
FILED
HARRISBURG, PA
FES 1 G 1999
DR. GLENN W. ZEHNER;
KIMBERLY L. BRIGHT; KEITH M.
VOELKER; ROBERT BURGETT;
individually and as members of
East Pennsboro Area School District;
EAST PENNSBORO AREA SCHOOL
DISTRICT; EAST PENNSBORO AREA
SCHOOL BOARD; ANTHONY J. FILIPPELLI;
PATTY J. SCHMICK; RANDOLF C. ALBRIGHT;
JAMES N. BIDDLE; JILL S. DYSON; NANCY
K. OTSTOT; EAST PENNSBORO TOWNSHIP,
The County of Cumberland, Pennsylvania; THE
COUNTY OF CUMBERLAND, PENNSYLVANIA;
and THE COMMONWEALTH OF PENNSYLVANIA,
Defendants
, NDREA. CLERK
o Jury Verdict. This action came before the Court for a trial by jury. The issues have been tried
and the jury has rendered its verdict
X Decision by Court. This action came to trial or hearing before the court. The issues have been
tried or heard and a decision has been rendered.
. /1 Ie"!
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IT IS ORDERED AND ADJUDGED that the award of attorney's fees in the
amount of $8,041.00 are awarded to
the defendants, East Pennsboro Area
School District, Glenn W. Zehner,
Kimberly L. Bright, Keith M. Voelker,
Robert E. Burgett, Anthony J. Filippelli,
Patty J. Schmick, Toni E. Porter,
Randolph C. Albright, James N. Biddle,
Jilll S. Dyson, Roger D. Kelley, Nancy
K. Otstot, Sheila A Sawyer, and East
Pennsboro Area School Board and
against the Plaintiff, Rodger E. Sgrignoli, Jr.
In the sum of $8,041.00.
---.--
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Date: February 16, 1999.
Mary E. D'Andrea, Clerk of Court
(By)George T. Gardner, Deputy Clerk
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IN THE COURT OF COMMON PLEAS,
CUMBERLAND COUNTY, PENNSYLVANIA
Judge GUIDO
KYRA ANN SGRIGNOLI,
Plaintiff,
Case No.: No. 03-866 CIVIL TERM
vs.
RODGER EUGENE SGRIGNOLI JR.,
CIVIL ACTION - LAW
ACTION FOR DIVORCE
Defendant
INCOME AND EXPENSE STATEMENT OF
RODGER EUGENE SGRIGNOLI JR.
Defendant, Rodger Eugene Sgrignoli Jr. files the following
Income and Expense Statement and verifies the statements made
herein are true and correct. Defendant understand any false
statements herein are made subject to the penalties of
18 Pa.C.S.~ 4904 relating to unsworn falsification to
authorities.
Date: 1/2.-/ 0/
, I
L __
Rodger Eugene Sgrignoli Jr. CPA
Respectfully Submitted,
~v
Rodger E. Sgrignoli Jr. CPA
DEFENDANT'S INCOME & EXPENSE STATEMENT - 1
f
INCOME:
Employer: PA Dept. of Revenue
Address: 1846 Brookwood Street, Hbg, PA 17104
Type of Work: State Tax Auditing
Payroll Number: 454304
Pay Period: Bi-Weekly
Gross: $ 1,839.00
Itemized Payroll Deductions:
Federal Withholding $
Social Security $
Local Income Tax $
State Income Tax $
Hbg OPT $
PAUC EE $
Medicare $
Union Dues $
Alimony/Support $
Retirement $
Total Deductions: $
Net Pay Per Pay Period:
Net Pay Per Month:
Other Income:
Rental Income
TOTAL MONTHLY INCOME:
EXPENSES (MONTHLY)
HOME:
Mortgage:
Utilities:
Electric: $
Water: $
Gas: $
Sewer/Garbage: $
Telephone: $
Cable: $
Maintenance: $
137.65
126.42
32.62
62.60
52.00
1.83
29.57
18.02
404.08
114.94
979.73
$ 859.27
$ 1,718.54
Month
$ 200.00
$ 1,918.54
$ 813.51
150.00
50.00
1 00.00
39.00
50.00
50.00
150.00
EMPLOYMENT:
Lunches: $ 100.00
INSURANCE:
Automobile: $ 52.00
Medical: $ 18.39
AUTOMOBILE:
Payments: $ 419.61
Fuel: $ 240.00
Repairs: $ 25.00
Maintanence: $ 25.00
Licences/Registration: $ 3.00
MEDICAL:
Doctor: $ 20.00
Dentist: $ 15.00
Medicine/Prescription Drugs: $ 20.00
Optometrist: $ 20.00
PERSONAL:
Clothing: $ 100.00
Food: $ 300.00
Barber: $ 15.00
Laundry/Dry Cleaning: $ 40.00
MEMBERSHIPS:
YMCA $ 52.00
MISCELLANEOUS:
Papers/Books/Magazines: $
Entertainment: $
Legal Fees: $
Half is for Tyler to go to races and play football
21.00
100.00
150.00
TOTAL EXPENSES
TOTAL MONTHLY INCOME:
TOTAL MONTHLY EXPENSES:
TOTAL MONTHLY SHORTFALL:
$ 3,138.51
$1,918.54
$ 3,138.51
$ 1,219.97
.,.
,
CERTIFICATE OF SERVICE
On January 2, 2007, the attached Income and Expense Statement of Rodger
Eugene Sgrignoli Jr. was mailed postage prepaid to:
Susan Kay Candiello, Esq.
4010 Glenfinnan Place
Mechanicsburg, PA 17055
Attorney For:
Ms. Kyra A. Sgrignoli, Plaintiff,
~ .,...//
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Rodger E. Sgrignoli Jr., Defendant
J
KYRA ANN SGRIGNOLI,
PLAINTIFF
: IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYL VANIA
vs.
: NO. 03-866
CIVIL TERM
RODGER EUGENE SGRIGNOLI, JR., : CIVIL ACTION - LA W
DEFENDANT : ACTION FOR DIVORCE
PLAINTIFFIWIFE'S STATEMENT UNDER
PENNSYL VANIA RULE OF CIVIL PROCEDURE 1920.33(b)
I. ASSETS:
A list of assets can be found at the Inventory and Appraisement Statement.
II. EXPERTS:
No experts will be called for this case.
III. WITNESSES:
The only anticipated witness is Ms. Sgrignoli. At such time as any additional witnesses
become anticipated, appropriate notice will be given to all parties involved and the Master.
IV. EXHIBITS:
The following are the known exhibits at this time:
1. The Inventory and Appraisement for Kyra Ann Sgrignoli (at Exhibit "A");
2. The Income and Expense Statement for Kyra Ann Sgrignoli (at Exhibit ""B");
3. Copy of Wife's W2 for 2005 (at Exhibit "C"). (If Wife has her W2 for 2006 at
the time of the hearing, this will be produced.);
4. Copy of most recent child and spousal support order (at Exhibit "D");
5. Copy of the letter from the Wife's Employer stating there is an annual
variation in Wife's earning capacity (at Exhibit "E");
6. Kelley Blue Book value for Wife's 2000 Chevrolet Cavalier Sedan 4D (at
Exhibit "F");
7. Statement of the present value of Wife's 401k with Luxottica Group and
statement of the value at the time of separation (at Exhibit "G");
8. Statement of Wife's Waypoint bank account at the time of the parties'
separation and a statement of Wife's Sovereign bank account at present (at
Exhibit "H");
9. Statement of Wife's Legal Fees (at Exhibit "I").
V. INCOME:
Wife has provided her Income and Expense Statement.
VI. EXPENSES:
Wife has provided an Income and Expense Statement.
VII. RETIREMENT BENEFITS:
Husband has a retirement plan through SERS. Wife has a 401k through her employer.
VIII. SAVINGS BONDS:
Wife believes Husband had a $100.00 savings bond deducted from his income every
month during the parties' marriage. (Wife realizes there was not the full $100.00 but rather only
the amount required to purchase a $100.00.) Husband has produced documentation to support
only $600.00 in savings bonds. Wife does not believe Husband has provided accurate and
correct information.
IX. COUNSEL FEES:
Husband did not obtain counsel in this matter until a master's prehearing was scheduled.
This has been a marriage filled with anger, lies, threats, manipulation, physical and
psychological abuse. Husband began a campaign early in the mamage of physical and
psychological threats and abuse of Wife and the minor children. Husband made numerous
threats to Wife when she fled the marital residence (which she had done on previous occasions)
and filed for divorce, he clearly stated to Wife, one of his goals would be to force Wife to incur
substantial legal fees so she would be left worse off than when they were married. Wife is
seeking to have her counsel fees be paid by Husband.
x. DISPUTES ON VALUE:
Wife disputes the credit card debt which Husband alleges. The children told Wife on
numerous occasions Husband was making significant purchases following the parties'
separation. Although Wife was able with her extremely limited income to payoff her one credit
card following the parties' separation, Husband with his significantly greater income was
allegedly not able to make any payments on the credit cards in his name.
Wife disputes the number and value of US Savings Bonds the Husband has
acknowledged. Wife believes Husband had money deducted from every pay check Husband
received regularly getting savings bonds during the entire marriage.
XI. DEBT:
11 North Eoola Drive, Eoola PA 17025-2516/ Mortgage The mortgage on the marital
residence is with Washington Mutual Home Loans. The parties have stipulated to a value of the
marital residence of $94,500.00. The current mortgage is approximately $61,000.00.
Numerous Credit Card Debt Husband has only provided statements from collections
groups dated months after the separation date with one exception. Husband has produced a
statement from the date of separation for the Navy Federal Credit Union. The statement at the
time of separation is in the amount of $ 3,165.67. Husband initially alleged the debt was $
5,342.44. This is a significant difference which cannot be accounted for in simply interest and
fees. This is yet another example of Husband submitting information which is not correct.
Husband has failed to produce statements of other accounts which he alleges existed at the date
of separation. Wife has no knowledge of these alleged marital credit accounts.
Auto Debt Husband's actions alone created the debt involving one of the vehicles
leased during the parties' marriage. Husband demonstrated the same type of behavior
throughout the marriage. Wife would not have created such a debt, nor did she agree with
Husband as he created this debt, but as a result of the abusive threats of Husband, Wife was not
able to take any actions against Husband. Wife's position is she is not responsible for this debt.
Personal Judgement This is a personal judgement against Husband for his sole
inappropriate actions. Wife was never involved in this action nor did she ever support Husband's
actions. Wife attempted on numerous occasions, to the extent she was allowed by Husband, to
intervene and alter his actions. Wife is not a named party in this lawsuit and never was a party to
this lawsuit. Wife's position is she is not responsible for this debt.
XII. PROPOSAL FOR SETTLEMENT:
1. Separation Date Wife proposes a separation date of December 27,2002.
2. 11 North Enola Drive, Enola, PA It is Wife's belief Husband wants to keep the
marital residence. The parties have stipulated to a value of this property of Ninety-Five
Thousand Five Hundred Dollars and No Cents ($94,500.00). Wife does not object to Husband
keeping the marital residence.
3. Husband's SERS Wife is seeking one-half (l/2) of the present value of Husband's
SERS.
4. Wife's Luxottica Group 401k Wife believes she should be able to keep this 401k in
her name alone. From 1998 to 1999, Wife was not able to work full time. Wife did work part-
time as a home health care provider. Husband refused to provide any support for Wife and the
children. Wife had no other option but to use her entire retirement of approximately $12,000.00
to pay for food and clothing for herself and her children. Wife believes as a direct result of
Husband refusing to provide any support for her or the children necessitating she use her
retirement to support the family, she should be credited with the full amount of her present 40lk
in the amount of $2,000.00.
5. Marital Debt Wife took one credit card with her when she fled the martial residence.
This was the only credit card which Wife had in her name. She paid that credit card in full after
the parties' separation. Husband produced several credit cards alleging significant debt.
However, when asked to produce evidence of this credit card debt at the time of the parties'
separation, Husband has not been able to do so with the exception of the Navy Federal Credit
Union. When finally producing evidence of debt at the time of the separation, there was
substantial difference between what Husband alleged was marital debt and what was true marital
debt. Husband's inability to share the truth has been a consistent factor in this divorce action. It
is Wife's belief Husband deliberately made substantial purchases immediately after the parties'
separation charging them to the credit cards. Wife believes this based on the children's
statements of all the new items Father purchased after the separation. Wife further believes
Husband then never made any payments on any of his credit accounts to create the appearance of
significant marital debt and interest and fees. It is Wife's position she should only be responsible
for one-half (1/2) of marital debt which Husband can provide accurate evidence for. If there are
any fees for non-payment and/or failure to make any payment these should be the responsibility
of Husband.
6. CHASE AUTO FINANCE and GENERAL MOTORS ACCEPTANCE
CORPORATION This vehicle was in Husband's name. Husband knowingly returned the
vehicle damaged. Husband"s attitude and statement to Wife were "they" (meaning Chase and
GMAC) could not do anything to him. It is Wife's position Husband by his continuing disregard
for the truth in combination with his irreverent and irresponsible attitude and created this debt
alone and she is not responsible for this debt.
7. 2000 Chevrolet Cavalier Sedan 4D Wife paid this vehicle off in full during the
parties' separation. At present time this vehicle has a Kelly Blue Book value of approximately
$ 3,090.00.
8. Husband's Vehicles Husband sold his vehicle soon after the parties' separation.
The value of his vehicle has yet to be determined. Husband has recently purchased a second
vehicle.
9. Sidewalk and Curb Resurfacing Husband is keeping the marital residence and
will directly benefit from the new sidewalks and curbs in the form of increased value of the
marital residence. As with other debt, Husband initially greatly exaggerated the amount of this
debt, when the true facts were produced the debt was significantly smaller. Wife's position is the
debt for the sidewalk and curb should be the sole responsibility of the Husband since he will be
keeping the marital residence.
10. Husband's Personal Judgment from United States District Court Husband's
actions are the sole reason for this judgment. This is a personal judgment naming Husband
alone. Wife had absolutely no involvement whatsoever with Husband's actions and continued
actions which resulted in this debt. This action was the result of Husband's ongoing disregard
for the tnlth in combination with his irreverent and irresponsible attitude. This is not marital
debt and Wife will not agree to be responsible for this judgment.
11. Alimony This is a marriage of 18 years. Wife is currently receiving $99.50
monthly in spousal support from Domestic Relations. It should be noted this amount should be
higher. Husband has two (2) individuals renting space in his home. Husband told his son, the
renters provided him with sufficient money to pay his mortgage, approximately Six Hundred
Dollars and No Cents ($600.00). Husband's attorney at the last master's hearing also stated
Husband was receiving payment from his renters in the amount of more than Six Hundred
Dollars ($600.00) per month. At the support conference following the master's hearing,
Husband stated he did not receive that much. Husband provided the support conference officer
with a note signed by a man alleged to be one of the Husband's renters stating he paid Husband
$25.00 per night. Yet another example of Husband's failure to provide the truth and attempt to
submit false evidence. The support conference officer did not give full credit to Husband's
statements, but did make a decision to use only the sum of Four Hundred Dollars and No Cents
($ 400.00) as rental income. If the conference officer had used the full amount Husband is
receiving from his renters Wife's spousal support would be greater than the present Ninety-Nine
Dollars and Fifty Cents ($ 99.50). Husband presently has a significantly greater income than
Wife with job stability and regular wage increases. Wife supported the family while Husband
attended school and obtained his degree. Wife has primary custody of the parties' 2 sons.
Husband has no contact with the eldest son. Husband refuses to provide any financial assistance
for the children beyond court ordered child support. Husband's support for the eldest son will
end June, 2007. Wife's employment occasionally suffers from reduced hours depending upon
the economic climate. Wife is seeking alimony in the amount of $200.00 per month for a
minimum of 10 years. The parties' children are 16 and 12 years of age. This alimony will assist
Wife in being able to afford a few of the necessities in raising the parties' teenage boys through
high school and their further education.
12. Summary This has been a marriage marked with violence and anger, physical and
psychological abuse of wife and both children. Husband has regularly engaged in the use of a
controlled chemical substances during the entire marriage. We must ask the question where
Husband obtains the funds to purchase this controlled substance in substantial quantities. Wife
finally attained sufficient psychological and physical independence to enable her to leave the
mamage. Husband has engaged in a campaign of threats, violence and continued harassment
with the stated goal of increasing Wife's attorney's fees and costs. Wife is seeking
reimbursement for her attorney's fees and costs. If Husband is found responsible for Wife's
attorney fees, Wife is seeking a (60/40) distribution of marital assets. Wife does not believe she
should be held responsible for any debt incurred as a direct result of Husband's inappropriate and
violent actions. There is a substantial difference between Husband and Wife's financial
standing. Wife is seeking alimony to enable her to maintain simply a very basic lifestyle which
she has established for herself and her sons since the parties' separation.
MARITAL ASSETS AND DEBT
Marital Residence Mortgage
Stipulated Value $ 94,500.00 $61,000.00 $33,500.00 $ 0.00 ($61,000.00) $ 0.00
Wife's 2000 Chevrolet Kelly Blue
Cavalier Book Value $ 0.00 $3,090.00 $ 0.00 $ 0.00
Loan paid in full by Wife $3,090.00
Husband's Vehicles
Husband's Savings Bonds $ 600.00 $ 600.00 $ 0.00 $ 0.00 $ 0.00
Husband's SERS Divide Divide Divide Divide
Equally Equally Equally Equally
Wife's Lenscrafter's 40lK $ 2000.00 $ 0.00 $ 2000.00 $ 0.00 $ 0.00
Navy Federal Credit Union $3165.67 $ 0.00 $ 0.00 $3165.67 $0.00
East Pennsboro Township $ 2450.00 ($2450.00) $ 0.00 ($2450.00) $ 0.00
Curb and Sidewalk Project
Attorney Fees $14000.00
TOT ALS $34,100.00 $ 5,090.00 $ 3165.67 $14000.00
(Husband)
Value to Value to
Husband Wife
Debt to Debt to
Husband Wife
Wife to receive from Husband $ 12,015.00 representing 600/0 of the marital assets.
Respectfully submitted,
LAW FIRM OF SUSAN KAY CANDIELLO, P.C.
Dated: January 2, 2007
Susan Kay C
Counsel for P inti
PA J.D. # 649 8
4010 Glenfinn ace
Mechanicsburg, PA 17055
(717) 724-2278
EXHIBIT "A"
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KYRA ANN SGRIGNOLI,
PLAINTIFF
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IN THE COURT OF COMMONj)L~S
OF CUMBERLAND COUNTY, (; en
PENNSYL V ANIA~~_
o
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CIVIL TERM
vs.
: NO. 03-866
(::)
RODGER EUGENE SGRIGNOLI, JR.,
DEFENDANT
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CIVIL ACTION - LA W
ACTION FOR DIVORCE
INVENTORY AND APPRAISEMENT FOR
KYRA ANN SGRIGNOLI
Plaintiff, Kyra Ann Sgrignoli, files the following Inventory and Appraisement of all
property owned or possessed by either party at the time this action was commenced and all
property transferred within the preceding three (3) years.
Plaintiff, Kyra AIlll Sgrignoli, verifies the statements made herein are true and correct.
Plaintiff understands any false statements herein are made subject to the penalties of 18 Pa.C.S.
g4904 relating to unsworn falsification to authorities.
K /(t~ . x1: ~, ~ ~
KYRA ~SGRIGNOLI M v
ASSETS OF PARTIES
Plaintiff marks on the list below those items applicable to the case at bar and itemizes the
assets on the following pages. If an item has been appraised, a copy of the appraisal report is
attached.
(X) 1. Real property
(X) 2. Motor vehicle(s), Boat
(X) 3. Stocks, Bonds, Securities and Options
() 4. Certificates of deposit
(X) 5. Checking accounts, cash
(X) 6. Savings accounts, money market and saving certificates
() 7. Contents of safe deposit box( s)
() 8. Trusts
(X) 9. Life insurance policies, (indicated face value, cash surrender value and current
beneficiaries)
() 10. Annuities
() 11. Gifts
() 12. Inheritance
() 13. Patents, Copyrights, Inventions and Royalties
() 14. Personal property outside the house
() 15. Businesses (list all owners, including the percentage of ownership, and
officer/director positions held by a party with the company)
() 16. Employment termination benefits (severance pay, workman's compensation
claim/award)
(X) 17. Profit sharing plans (only 50% vested at time of separation)
(X) 18. Pension plans (indicate employee contribution and date plan vests)
(X) 19. Retirement plans, Individual Retirement Accounts
(X) 20. Disability paynlents
() 21. Litigation claims (matured and unmatured)
(X) 22. MilitaryN .A. benefits
() 23. Education benefits
() 24. Debts due, including loans, mortgages held
(X) 25. Household furnishings and personal (include as a total category and attach
itemized list if distribution of such assets is in dispute)
() 26. Other: Disability Settlement
LIABILITIES OF PARTIES
Plaintiff marks on the list below those items applicable to the case at bar and itemizes the
liabilities on the following page:
SECURED:
(X) 1. Mortgages
() 2. Judgements
() 3. Liens
() 4. Other secured liabilities
UNSECURED:
(X) 1. Credit card balances
() 2. Purchases
(X) 3. Loan payments
() 4. Notes payable
() 5. Other unsecured liabilities
CONTINGENT OR DEFERRED:
() 1. Contracts or Agreements
() 2. Promissory notes
() 3. Lawsuits
() 4. Options
() 5. Taxes
() 6. Other contingent or deferred liabilities
Respectfully submitted,
LA W FIRM OF SUSAN KAY CANDIELLO, P.C.
"--
Dated: July &, 2005
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Susan Kay Ca tell
Counsel for Ifainti
PA LD. # 6499s~/
5021 East Trindle Road
Suite 100
Mechanicsburg P A 17050
(717) 796-1930
EXHIBIT "B"
KYRA ANN SGRIGNOLI,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
VS.
: NO. 03-866
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CIVIL TERM
RODGER EUGENE SGRIGNOLI, JR., : CIVIL ACTION - LAW
DEFENDANT : ACTION FOR DIVORCE
INCOME AND EXPENSE STATEMENT OF
KYRA ANN SGRIGNOLI
Plaintiff, Kyra Ann Sgrignoli, files the following Income and Expense Statement and
verifies the statements made herein are true and correct. Plaintiff understands any false
statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn
falsification to authorities.
~~~~ ~/L1-) ~
KY ,i A SGRIGNOLI '0
INCOME:
Employer: Lenscrafters Inc.
Address: 4000 Luxottica Place, Mason, Ohio 45040
Type of Work: Apprentice Optician
Payroll Number: 77219329
Pay Period: Bi~weekly
Gross Pay Per Pay Period:
Itemized Payroll Deductions:
Federal Withholding:
Social Security (FICA):
State Income Tax:
Local Income Tax:
Pa Camp Hill OPT EM
PA Unemploy EE
Medicare:
Retirement:
Savings Bonds:
Credit Union:
Life Insurance:
$ 1042.26
48.84
64.62
32.00
10.42
10.00
.94
15.11
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Health Insurance:
Tax Deferred Comp:
Fair Share Fee:
Short Term Disability:
TOTAL:
OTHER INCOME (MONTHLY):
Employment:
Interest:
Dividends:
Pensions:
Annuity:
Federal Withholding:
Savings Bonds:
Life Insurance:
Credit Union:
Social Security:
Rents:
Royalties:
Expense Account:
Gifts:
Unemployment Compensation:
Workmen's Compensation:
Support: (child)
TOTAL MONTHLY INCOME:
EXPENSES (MONTHLY):
HOME:
Mortgage:
Rent:
Utilities:
Electric:
Internet:
Cable:
Telephone:
Water/Sewer/Garbage
Cell Phone:
$ 1 736.66
$ 666.00
$ 2402.66
$ 600.00
165.00
45.00
45.00
50.00
90.00
EMPLOYMENT EXPENSES:
Transportation:
Lunches:
100.00
TAXES:
School:
Real Estate:
Harrisburg City:
Personal:
Income:
INSURANCE:
Homeowners/Rental:
Automobile:
Life:
Accident:
Health:
$ 54.00
AUTOMOBILE:
Payments:
Fuel:
Repairs:
Maintenance:
Licenses/Registration
350.00
200.00
25.00
25.00
36.00 / annually
MEDICAL:
Doctor:
Dentist:
Hospital:
Medicine/Prescription Drugs: 50.00
(Mr. Sgrignoli continues to refuse to pay his portion of the unpaid medical bills for the
children. )
100.00
35.00
PERSONAL:
Clothing:
Food:
BarberfHairdresser:
Laundry/Dry cleaning:
Memberships:
Bank Charges:
Credit Card Payments:
500.00
50.00
25.00
100.00
MISCELLANEOUS:
Papers/Books/Magazines:
Entertainment:
Kyra has no extra monies to pay legal fees.
18.00
150.00
TOT AL EXPENSES:
$ 2783.00
Total Monthly Income:
$ 2402.66
Total Monthly Expenses
$ 2783.00
Total Monthly Shortfall
$ 380.34
Respectfully submitted,
LA W FIRM OF SUSAN KAY CANDIELLO, P.C.
Susan Kay
Counsel for Plaint
PA I.D. # 64998
4010 Glenfinnan Place
Mechanicsburg, P A 17055
(717) 724-2278
Dated: O(:tober 17, 2005
-
EXHIBIT "C"
elf Employee'. name,lIddreaa, and ztp code
KYRA A SGRIGNOll
424 DUKE ST
IF
ENOLA, PA 17025
9 Advance EIC payment
11 Nonquallfied plans
14 other
52.00 UNITED WAY
na ~III
d Employee'. SSA_ber
404-90-4955
2 Feder8t incometu: withheld
1001.70
4 SocilII security tax withheld
1512,52
6 Medicare tax withheld
353.73
8 AHocated tips
10 Dependent ClIfe benefda
124
12b
12c
12d
2
2005 W-2 and EARNINGS SUMMAR~;
KYRA A SGRIGNOU
424 DUKE ST
Social Security Number: 404-90-4
EXHIBIT "D"
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
KYRA A. SGRIGNOLI ) Order Number 873 S 2002
Plaintiff )
vs. ) P ACSES Case Number 876104896
RODGER E. SGRIGNOLI JR ) Docket Number 00873 S 2002
Defendant ) Other State 1D Number
ORDER OF COURT
o Final (i) Interim 0 Modified
AND NOW, 21ST DAY OF NOVEMBER, 2006
, based upon the Court's
determination that the Payee's monthly net income is $ 1,923.15
and the Payor's
monthly net income is $ 3,019.04
, it is hereby ordered that the Payor pay to the
PellllSylvania State Collection and Disbursement Unit
EIGHT HUNDRED NINETY-NINE AND 50/100
Dollars ($ 899.50
) a month payable
MONTHLY
as follows: first payment due
IN ACCORDANCE WITH THE DEFENDANT'S CURRENT PAY SCHEDULE.
The effective date of the order is 10/18/06 .
Arrears set at $ 644.79
as of NOVEMBER 21, 2006 are due in full
IMMEDIATELY. All terms of this Order are subject to collection and/or enforcement by
contempt proceedings, credit bureau reporting, tax refund offset certification, driver's license
revocation, and the freeze and seize of financial assets. These enforcement/collection
mechanisms will not be initiated as long as obligor does not owe overdue support. Failure to
make each payment on time and in full will cause all arrears to become subject to immediate
collection by all the means listed above.
For the Support of:
Name
KYRA ANN SGRIGNOLI
CHRISTIAN TYLER SGRIGNOLI
TYLER JAMES SGRIGNOLI
Birth Date
11/26/60
07/05/89
OS/10/93
Service Type M
Form OE-5I8
Worker 1D 21101
SGRIGNOLI
V. SGRIGNOLI
PACSES Case Number: 876104896
per month payable
The defendant owes a total of $ 899.50
for arrears. The defendant must
$ 863 . SO
MONTHLY
for current support and $ 36 . 00
also pay fees/costs as indicated below. This order is allocated and monies are to be applied as
follows:
Frequency Codes:
Payment Amountl
Freqnency
$ 99.50
$382.00
$382.00
$ 0.00
$ 0.00
$ 0 .00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
1 =One Time B =BiWeekly 2 =Bi-Monthly
5 =Semi-Annually S =Semi-Monthly A =Annually
M = Monthly
W =Weekly
Q = Quarterly
Debt Type De!;.cnption
Renefida1:}'
1M SPOUSAL SUPPORT KYRA ANN SGRIGNOLI
1M CHILD SPT ALLOC CHRISTIAN TYLER SGRIGNOLI
1M CHILD SPT ALLOC TYLER JAMES SGRIGNOLI
I
/
I
I
I
I
I
I
I
/
I
I
/
I
/
/
I
Said money to be turned over by the Pa SCDU to:
. Payments must be made by check or
KYRA ANN SGRIGNOLI
money order. All checks and money orders must be made payable to Pa SCDU and mailed to:
Pa SCDU
P.O. Box 69110
Harrisburg, Pa 17106-9110
Payments must include the defendant's PACSES Member Number or Social Security Number
in order to be processed. Do not send cash by mail.
Service Type M
Page 2 of 4
Form DE-5I8
Worker ID 21101
SGRIGNOLI
v. SGRIGNOLI
PACSES Case Number: 876104896
Unreimbursed medical expenses that exceed $250.00 annually per child and/or spouse
are to be paid as follows: 60 % by defendant and 40 % by plaintiff. The plaintiff is
responsible to pay the first $250.00 annually (per child and/or spouse) in unreimbursed
medical expenses. <i) Defendant 0 Plaintiff 0 Neither party to provide medical insurance
coverage. Within thirty (30) days after the entry of this order, the o Plaintiff
<i) Defendant shall submit to the person having custody of the child(ren) written proof that
medical insurance coverage has been obtained or that application for coverage has been made.
Proof of coverage shall consist, at a minimum, of: 1) the name of the health care coverage
provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage;
4) the address to which claims should be made; 5) a description of any restrictions on usage,
such as prior approval for hospital admissions, and the manner of obtaining approval;
6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and
co-payments; and 8) five copies of any claim forms.
Other Conditions:
EFFECTIVE JANUARY 1, 2007, THE SUPPORT OBLIGATION SHALL BE MODIFIED TO $852.00,
$748.00 PER MONTH FOR CHILD SUPPORT AND $104.00 PER MONTH FOR SPOUSAL SUPPORT.
Defendant shall pay the following fees:
for
Payment Frequency
Payable at $ 0.00
Payable at $ 0.00
Payable at $ 0.00
Payable at $ 0.00
Payable at $ 0.00
per MONTH
per MONTH
per
per
per
Fee Total
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 0.00
Fee Description
furJUDICIAL COMPUTER FEE
for COURT COSTS
for
for
Page 3 of 4
Form OE-518
Worker ID 21101
Service Type M
SGRIGNOLI
V. SGRIGNOLI
PACSES Case Number: 876104896
IMPORTANT LEGAL NOTICE
PARTIES MUST WITHIN SEVEN DAYS INFORM THE DOMESTIC RELATIONS SECTION AND
THE OTHER PARTIES, IN WRITING, OF ANY MATERIAL CHANGE IN CIRCUMSTANCES RELEVANT
TO THE LEVEL OF SUPPORT OR THE ADMINISTRATION OF THE SUPPORT ORDER, INCLUDING,
BUT NOT LIMITED TO, LOSS OR CHANGE OF INCOME OR EMPLOYMENT AND CHANGE OF
PERSONAL ADDRESS OR CHANGE OF ADDRESS OF ANY CHILD RECEIVING SUPPORT. A PARTY
WHO WIUFUUY FAILS TO REPORT A MATERIAL CHANGE IN CIRCUMSTANCES MAY BE ADJUDGED IN
CONTEMPT OF COURT, AND MAY BE FINED OR IMPRISONED.
PENNSYLVANIA LAW PROVIDES THAT ALL SUPPORT ORDERS SHALL BE REVIEWED AT LEAST
ONCE EVERY THREE (3) YEARS IF SUCH REVIEW IS REQUESTED BY ONE OF THE PARTIES. IF
YOU WISH TO REQUEST A REVIEW AND ADJUSTMENT OF YOUR ORDER, YOU MUST DO THE
FOLLOWING: CALL YOUR ATTORNEY. AN UNREPRESENTED PERSON WHO WANTS TO MODIFY
(ADJUST) A SUPPORT ORDER SHOULD CONTACT THE DOMESTIC RELATIONS SECTION.
ALL CHARGING ORDERS FOR SPOUSAL SUPPORT AND ALIMONY PENDENTE LITE, INCLUDING
UNALLOCATED ORDERS FOR CHILD AND SPOUSAL SUPPORT OR CHILD SUPPORT AND ALIMONY
PENDENTE LITE, SHALL TERMINATE UPON DEATH OF THE PAYEE.
A MANDATORY INCOME ATTACHMENT WILL ISSUE UNLESS THE DEFENDANT IS NOT IN
ARREARS IN PAYMENT IN AN AMOUNT EQUAL TO OR GREATER THAN ONE MONTH'S SUPPORT
OBLIGATION AND (1) THE COURT FINDS THAT THERE IS GOOD CAUSE NOT TO REQUIRE
IMMEDIATE INCOME WITHHOLDING; OR (2) A WRITTEN AGREEMENT IS REACHED BETWEEN
THE PARTIES WHICH PROVIDES FOR AN ALTERNATE ARRANGEMENT.
UNPAID ARREARAGE BALANCES MAY BE REPORTED TO CREDIT AGENCIES. ON AND
AFTER THE DATE IT IS DUE, EACH UNPAID SUPPORT PAYMENT SHALL CONSTITUTE, BY
OPERATION OF LAW, A JUDGMENT AGAINST YOU, AS WELL AS A LIEN AGAINST REAL
PROPERTY .
IT IS FURTHER ORDERED that, upon payor's failure to comply with this order, payor may be
arrested and brought before the Court for a Contempt hearing; payor's wages, salary,
commissions, and/or income may be attached in accordance with law; this Order will be
increased without further hearing by 0 % a month until all arrearages are paid in full. Payor
is responsible for court costs and fees.
nJ'J.7jofo
Copies delivered to parties .
Date
Consented:
Plaintiff's Attorney
Plaintiff
Defendant
Defendant's Attorney
DRO: Todd Maul
cc: plaintiff and defendant
cc: Diane RadCUdI, Esq.
cc: Susan Candiello, Esq.
Judge
J.
Page 4 of 4
Form OE-518
Worker ID 21101
Service Type M
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
PACSES Case Number: 876104896
Docket Number: 00873 S 2002
Other State ID Number:
Please note: All correspondence must include the PACSES
Case Number.
NOVEMBER 16, 2006
SUMMARY OF TRIER OF FACT
Plaintiff Information
Defendant Information
KYRA A. SGRIGNOLI
RODGER E. SGRIGNOLI JR
Address:
424 F DUKE ST
ENOLA PA 17025-2318
Address:
11 N ENOLA DR
ENOLA PA 17025-2516
Employer:
LUXOTTICA RETAIL
PAYROLL DEPT
4000 LUXOTTICA PL
MASON OH 45040-8114
Attorney:
SUSAN K. CANDIELLO, ESQ.
Employer:
BUREAU OF COMMONWEALTH
C/O PAYROLL OPERATIONS
ATTACHMENTS RESEARCH UNIT
PO BOX 8006
HARRISBURG PA 17105-8006
Attorney:
DIANE G. RADCLIFF, ESQ
o Complaint for Support
[XJ Petition for Modification Filed 10/18/06 0 Other
Reason for Conference: PLTF FILED PETITION TO INCREASE
Dependent( s)
CHRISTIAN TYLER SGRIGNOLI
07/05/89
08/10/93
253-71-6482
TYLER JAMES SGRIGNOLI
189-74-7138
Current Order: $ 711. 00
/ per month
Service Type M
Form eM -022 vI
Worker ID 21101
SGRIGNOLI
v. SGRIGNOLI
PACSES Case Number: 876104896
Defendant Information
Plaintiff Information
Current Income:
$2273.61/MO GROSS
$1923.1S/MO NET
$4384.S0/MO GROSS
$3019.04/MO NET
Tax Return:
HEAD OF HOUSEHOLD WITH 3 EXEMPTIONS
SINGLE WITH ONE EXEMPTION
Medical Coverage:
N/A
PROVIDED THROUGH EMPLOYER AT NO
COST, EFFECTIVE 1/1/07 COST WILL BE
1% OF GROSS INCOME.
Child Care/Tuition:
N/A.
N/A
Additional Obligations:
N/A
N/A
Other Information:
1. PLTF'S INCOME WAS DETERMINED USING PAY STUBS PROVIDED BY HER.
2. DEFT'S INCOME WAS DETERMINED USING WAGE INFO PROVIDED BY HIS EMPLOYER.
RENTAL INCOME OF $400.00 PER MONTH IS INCLUDED IN THIS INCOME.
3. THE DEFT IS CURRENTLY PROVIDING MEDICAL INSURANCE FOR ALL PARTIES AT NO
COST. EFFECTIVE 1/1/07, THE COST FOR COVERAGE WILL BE 1% OF HIS GROSS
INCOME.
4 . THE PARTIES DISPUTED THE AMOUNT OF RENTAL INCOME. THE DEFT INDICATED HE
RECEIVED ONLY $200.00 PER MONTH, BUT HAD NO PROOF. PLTF INDICATED THAT DEFT
RECEIVES $600.00 AS WAS DISCUSSED AT A PRIOR MASTER'S HEARING.
Page 2 of 3
Form eM -022 v 1
Worker ID 21101
Service Type M
SGRIGNOLI
V. SGRIGNOLI
PACSES Case Number: 876104896
Other Information (continued):
Facts Agreed Upon:
Facts in Dispute and Contentions with Respect to Facts in Dispute:
Guideline Amount: $ 863.50 / MONTH
DRS Recommended Amount: $ 863 .50 / MONTH
DRS Recommended Order Effective Date: 10/18/06
Parties to be Covered by Recommended Order Amount:
SPOUSE AND TWO CHILDREN.
Guideline Deviation:
Reason for Deviation:
o YES or (i) NO
Submitted by: TODD A. MOUL
Date Prepared: NOVEMBER 16, 2006
Page 3 of 3
Form CM-022 v1
Worker ID 21101
Service Type M
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA.17013
Phone: (717) 240-6225
Plaintiff Name: KYRA A. SGRIGNOLI
Defendant Name: RODGER E. SGRIGNOLI JR
Docket Number: 00873 S 2002
PACSES Case Number: 876104896
Other State ID Number:
Fax: (717) 240-6248
Please note: All correspondence must include the PACSES Case Number.
Support Guideline Calculation
CHILD SUPPORT Defendant Plaintiff
1. Number of Dependents in
this Case 00 02
2. Total Gross Monthly Income $ 4,384.50 $ 2,273.61
3. Less Monthly Deductions $ 1,365.46 $ 350.46
4. Monthly Net Income $ 3,019.04 $ 1,923.15
5. Combined Total Monthly $
Net Income 4,942.19
6. Plus Monthl2] Social Security $
Benefit for hild/Children
7. Adjusted Monthly Net Income $ 4,942.19
8. Basic Child Support $ 1,251.00
Obligation
9. Basic Child S~~ort Less
Monthly Soci ecuri2;. $ 1,251.00
Benefit for Child/Chi! en
10. Net Income as Percentage of 38.91 %
Combined Amount 61. 09 %
11. Each Parent's Monthly Share
of the Basic Child Support $ $
Obligation 764.24 486.76
12. Adjustment for Shared $
Custody
13. Adjustment for Child Care $
Expenses
14. Adjustment for Health $
Insurance Premiums
15. Adjustment for Unreimbursed $
Medical Expenses
16. Adjustment for Additional $
Expenses
17. Total Obligation with
Adjustments $ 764.24
18. Less Split Custody $ 0.00
Counterclaim
19. Obligor's Support Obligation $ 764.24
Form OE-OI9
Service Type M Worker ID 21101
SGRIGNOLI
V. SGRIGNOLI
PACSES Case Number: 876104896
Summary
Date:
NOVEMBER 21, 2006
Monthly obligation amount selected: $ 863.74
Payment: frequency: MONTHLY
Obligation amount: $ 863.74
Deviation reason: 1.
2.
3.
4.
5.
Page 2 of 2
Form OE-DI9
Worker ID 21101
Service Type M
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Phone: (717) 240-6225
Fax: (717) 240-6248
Plaintiff Name: KYRA A. SGRIGNOLI
Defendant Name: RODGER E. SGRIGNOLI JR
Docket Number: 00873 S 2002
PACSES Case Number: 876104896
Other State ID Number:
Please note: All correspondence must include the PACSES Case Number.
Spousal Support Guideline Calculation with Dependent Children
1. Obligor's Monthly Net Income $ 3,019.04
2. Less All Other Support $ 0.00
3. Less Obligee's Monthly Net Income $ 1, 923 .15
4. Difference $ 1,095.89
5. Less Child Obligation for Current Action $ 764.24
6. Income Available for Spousal $ 331. 65
7. Multiply by 30 % 30%
8. Amount of Basic Spousal Support $ 99.50
9. Adjustment for Mortgage $ 0.00
10. Total Monthly Spousal Support $ 99.50
Spousal Support Guideline Calculation without Dependent Children
1. Obligor's Monthly Net Income $
2. Less All Other Support $
3. Less Obligee's Monthly Net Income $
4. Difference $
5. Multiply by 40% 40%
6. Amount of Basic Spousal Support $
7. Adjustment for Other Expenses $
8. Total Monthly Spousal Support $
Service Type M
Form OE-523
Worker ID 21101
SGRIGNOI~I
V. SGRIGNOLI
PACSES Case Number: 876104896
Summary
Date:
NOVEMBER 21, 2006
Monthly obligation amount selected: $ 863.74
Payment frequency: MONTHLY
Obligation amount: $ 863.74
Deviation reason: 1.
2.
3.
4.
5.
Page 2 of 2
Form OE-523
Worker ID 21101
Service Type M
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Phone: (717) 240-6225
Plaintiff Name: KYRA A. SGRIGNOLI
Defendant Name: RODGER E. SGRIGNOLI JR
Docket Number: 00873 S 2002
PACSES Case Number: 876104896
Other State ID Number:
Fax: (717) 240-6248
Please note: All correspondence must include the PACSES Case Number.
Support Guideline Calculation
CmLD SUPPORT Defendant Plaintiff
1. Number of Dependents in
this Case 00 02
2. Total Gross Monthly Income $ 4,384.50 $ 2,273.61
3. Less Monthly Deductions $ 1,365.46 $ 350.46
4. Monthly Net Income $ 3,019.04 $ 1,923.15
5. Combined Total Monthly $
Net Income 4,942.19
6. Plus Mon~ Social Security $
Benefit for ild/Children
7. Adjusted Monthly Net Income $ 4,942.19
8. Basic Child Support $
Obligation 1,251.00
9. Basic Child S~~ort Less
Monthly Soci ecurig $ 1,251.00
Benefit for Child/Chil ren
10. Net Income as Percentage of
Combined Amount 61. 09 % 38.91 %
II. Each Parent's Monthly Share
of the Basic Child Support $ $
Obligation 764.24 486.76
12. Adjustment for Shared $
Custody
13. Adjustment for Child Care $
Expenses
14. Adjustment for Health
Insurance Premiums $ -15.51
15. Adjustment for Unreimbursed
Medical Expenses $
16. Adjustment for Additional
Expenses $
17. Total Obligation with
Adjustments $ 748.73
18. Less Split Custody $
COlmterclaim 0.00
19. Obligor's Support Obligation $ 748.73
Form OE-OI9
Service Type M Worker ID 21101
SGRIGNOIJI
V. SGRIGNOLI
Summary
Date: NOVEMBER 21, 2006
Monthly obligation amount selected: $ 852.88
Payment frequency: MONTHLY
Obligation amount: $ 852.88
Deviation reason: 1.
2.
3.
4.
5.
Service Type M
Page 2 of 2
PACSES Case Number: 876104896
Form OE-OI9
Worker ID 21101
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Phone: (717) 240-6225
Fax: (717) 240-6248
Plaintiff Name: KYRA A. SGRIGNOLI
Defendant Name: RODGER E. SGRIGNOLI JR
Docket Number: 00&73 S 2002
PACSES Case Number: 876104896
Other State ID Number:
Please note: All correspondence must include the PACSES Case Number.
Soousal Support Guideline Calculation with Dependent Children
1. Obligor's Monthly Net Income $ 3,019.04
2. Less All Other Support $ 0.00
3. Less Obligee's Monthly Net Income $ 1,923.15
4. Difference $ 1,095.89
5. Less Child Obligation for Current Action $ 748.73
6. Income Available for Spousal $ 347.16
7. Multiply by 30% 30%
8. Amount of Basic Spousal Support $ 104.15
9. Adjustment for Mortgage $ 0.00
10. Total Monthly Spousal Support $ 104.15
Spousal Support Guideline Calculation without Dependent Children
1. Obligor's Monthly Net Income $
2. Less All Other Support $
3. Less Obligee's Monthly Net Income $
4. Difference $
5. Multiply by 40% 40%
6. Amount of Basic Spousal Support $
7. Adjustment for Other Expenses $
8. Total Monthly Spousal Support $
Service Type M
Form OE-523
Worker In 21101
SGRIGNOLI
V. SGRIGNOLI
PACSES Case Number: 876104896
Summary
Date: NOVEMBER 21, 2006
Monthly obligation amount selected: $ 852.88
Payment frequency: MONTHLY
Obligation amount: $ 852.88
Deviation reason: 1.
2.
3.
4.
5.
Service Type M
Page 2 of 2
Form OE-523
Worker ID 21101
NOV-21-06 14:21
FROM-Cumberland County Oorne5tic Relations
+11112406248
T-299 p.002/013 F-668
To Whom It May Concern::
I, Richard Miller, do hereby assert that I currently reside occasionally on a
temporary basis with Rodger E. Sgrignoli Jr. at 11 N Enola Drive, Enola, PA,
I assert that my lease is on day to day status, and that I pay the sum of $25.00
for every 2 nights stayed.
I further assert that Jam employed:8s an overnight truck driver with a national
carrier that requires constant travel weeks at a time making many out of state
deliveries.
Dated: ,kv. 1~~ca&1
.z~ ~ /J1Ji..{ ~
Richard Miller
EXHIBIT "E"
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EXHIBIT "F"
=ZeEey Blue Book - Trade-In Pricing Report - Chevrolet, Cavalier
Page 1 of3
.~~~!!~I~
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Home > Us..ed Cars> .s.e.ilim > Chevrolet> ~lier > ;WOO > 5..edan 4Q > Equipment f5'i
2000 Chevrolet Cavalier Sedan 40
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D_loh -.1,;....... .............,II....~,.I.ff~1:!:~~:J
Condition
Value
Excellent
$3,450
$3,090
(Selected)
Good
More Photos
Fair
$2,515
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Vehicle Highlights
Mileage: 50AOO
Engine: 4-Cyl. 2.2 Uter
Transmission: Automatic
Drivetrain: FWD
Change Equipment
Selected Equipment
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10/16/2006
.K,:'!-e:r !.~nt:~ Pook - Trade-In Pricing Report - Chevrolet, Cavalier
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Standal"d
Air Conditioning
Power Steering
AM/FM Stereo
Dual Front Air Bags
ABS (4-Wheel)
Option311
Single Compact Disc
Blue Book Trade-In Value
Trade-in Value is what consumers can expect to receive from a dealer for a
trade-in vehicle assuming an accurate appraisal of condition. This value will
likely be less than the Private Party Value because the reselling dealer incurs
the cost of safety inspections, reconditioning and other costs of doing
business.
Vehicle Condition R.atings
Check Vehicle Title History
Excellent
$3,450
"Excellent" condition means that the vehicle looks new, is in excellent
mechanical condition and needs no reconditioning. This vehicle has never
had any paint or body work and is free of rust. The vehicle has a clean title
history and will pass a smog and safety inspection. The engine
compartment is clean, with no fluid leaks and is free of any wear or visible
defects. The vehicle also has complete and verifiable service records. less
than 5% of all used vehicles fall into this category.
$3,090
"Good" condition means that the vehicle is free of any major defects. This
vehicle has a clean title history, the paint, body and interior have only
minor (if any) blemishes, and there are no major mechanical problems.
There should be little or no rust on this vehicle. The tires match and have
substantial tread wear left. A "good" vehicle will need some reconditioning
to be sold at retail. Most consumer owned vehicles fall into this category.
Fair
$2,515
"Fair" condition means that the vehicle has some mechanical or cosmetic
defects and needs servicing but is still in reasonable running condition. This
vehicle has a clean title history, the paint, body and/or interior need work
performed by a professional. The tires may need to be replaced. There may
be some repairable rust damage.
Poor
N/A
"Poor" condition means that the vehicle has severe mechanical and/or
cosmetic defects and is in poor running condition. The vehicle may have
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Page 2 of3
a(
10/16/2006
EXHIBIT "G"
I!KJITICi1
f"'. j:: , I
r( '.- ; L
January 19,2006
Diane G. Radcliff, Esquire
3448 Trindle Road
Camp Hill, P A 17011
Re: Luxottica Group Pension Plan Balances
Krya Sgrignoli (404-90-4955)
Dear Ms. Radcliff:
I was unable to obtain statements for the periods you requested but I have included all of
the information that would have been on the quarterly pension statements. In the table
below is the pension information for each quarter from 1/1/2003 through 9/30/2005.
Information for the fourth quarter of 2005 is not yet available.
1/1/2003 - 3/31/2003 $1,676.95 327.82 14.48 $2,019.25
4/1/2003 - 6/30/2003 $2,019.25 272.90 1 7.44 $2,309.59
7/1/2003 ~ 9/30/2003 $2,309.59 314.70 19.95 $2,644.24
1011/2003 -12/31/2003 $2,644.24 275.10 22.84 $2,942.18
1/1/2004 - 3/31/2004 $2,942.18 327.26 25.41 $3,294.85
4/1/2004 - 6/30/2004 $3,294.85 283.45 28.46 $3,606.76
7/1/2004 - 9/30/2004 $3,606.76 331.93 31.15 $3,969.84
10/1/2004 - 12/31/2004 $3,969.84 311.69 34.29 $4,315.82
111/2005 - 3/31/2005 $4,315.82 362.62 37.28 $4,715.72
4/1 /2005 - 6/30/2005 $4,715.72 406.34 40.73 $5,162.79
711/2005 ~ 9/30/2005 $5,162.79 477.25 44.59 $5,684.63
If you have any questions regarding the information presented above, please write to me
at the address below or call me at (513) 765-6917.
Si~cerely,
~. . (\
c./~~'I.J\~ \_Jl}1)0~
Lynne Wever
Manager, Retirement Plans
Luxottica Retail, 0 Luxottica Group Company
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Luxottica Group
Retirement Plans
Retirement Savings Statement
April 1 ,2006 - June 30,2006
ENVIOP013569
OP 05051 E
~ Customer Service Number: 1-800-742-4015
To make changes to your account, call the Customer
Service Number between 8:30 AM and 8:00 PM any
business day.
KYRA A SGRIGNOLI
424 DUKE ST
#F
ENOLA, PA 17025
Your Cash Balance Pension Plan Account Summary
Beginning Balance
Company Contributions
Interest
Ending Balance
Vested Balance
Vested Percent
Date of Hire:
Date of Birth:
Cash Balance Pension Plan
$6,681.97
426.97
67.46
$7,176.40
$7,176.40
100.00%
02/14/2000
11/26/1960
For questions regarding your Cash Balance Pension account, please contact your Benefits Department.
If you are a terminated Associate and have a balance in the Cash Balance Pension Plan, please note the following: - If 100%
vested and your account is less than $3,500, you will be contacted automatically in the quarter following your termination about
withdrawing your balance.
. If 100% vested and your account is greater than $3,500, you will be eligible for distribution at age 65 or early at age 55 if you have
attained 10 years of service.
_ If 0% vested, your balance will be forfeited. You should receive a final statement at the end of the next quarter following your
_ J()rfeitl!r~-=-
If you are an active, eligible associate to participate in the 401 (k) Savings Plan. it is never too late to start saving. Take advantage
of the tax savings, company match and money accumulating opportunities the Plan provides. A little money saved early can be
worth more than a lot saved later.
Please read this statement carefully. Any error must be reported to Fidelity Investments within 90 days.
13569 OP013569
0001 20060913 OP4K
Page 1 of 1
EXHIBIT "H"
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tJ~lcv.~
1-877-S0V-BANK (1-877-768-2265) www.soverelgnbank.com
Balances
Beginning'B~'lancfr: . ,<"'.. .. ,
Deposits/Credits
W ithdrawals/Debits,,;.;;;.'i::' ."".;:
, -"', "",=0"",.0;"",,-0" .'.~' ::."".~~,,~~o f's....... "
$2,317.16
+$3,110.22
-$3,623.96
Current Balance
Average Daily Balance
///-'~
$1,803.42'
$2,217.83
Service Fees
POINTOF~SA~'pUfi'CHASES'US1NG A PIN FEE
NON-SOVEREIGN A TM TRANSACTION FEE
Total
# Transactions
f~F'
5
Fee
Total
$7.00
$7.50
$14.50
. - .. .... .' " ," _' "~_>''f''
, . - ,."' -""-'<>;-~.
0.50
1.50
Checks Posted
Check # Date Paid
Amount Reference #
"::"~~~~~;">:'~~-':~' ,
~~-:;$15.00 ":,;618618900
587* 08/18 $17.79 616686360
588_.?;t~i~ti~~~~o8123t~'~$585.00 "...., 614044310
589 08/19 $50.00 618636930
8 Check(s) Posted = $1,397.89
An asterisk (*) indicates a skip in sequential check numbers.
Accou nt Activity
Date Description
Beginning Balance
PA-SCDU CHLD SUPPT
050812
Check # Date Paid
Amount Reference #
"'. -' . -. -~. ~ ~-~~~ -r ~.,,,.,,.........,...u._,,,,,,,,,.tt":...':.t....~,,,.;~
$168.10 j. ....".. 6'14046830'J
$365.00 644677600
$35.00 : . : 642539270'
.
$162.00 614819310
591*"'~:I~:;: '
593*
596*'2""
598*
:o8l29"D7
09/06
. '.' 09/09' .:? ....-
09/14
Additions
Subtractions
Balance
"f"--,,..-r4........-"'-....-..~- <,~-
. __ "_"_"V_'_'_~_""'_' ".b
$2,317.16
,. '~'-', ~;~f~~~~ $2:'30~~'1)~?
$2,775.24
<,'?;;;et:.;ib;i'if"'1"5' . '0"0'"
';:::'::"'-;::2~f??~;W~i-1l- .
$473.08
POS PURCHASE 450752
BOSCOV'S 870CAMPHILL
CAMP HILL PA
page 3 of7
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~ ~~~~\\D<Y
S1 OJ \'J{
SPECIAL LIMITED TIME OFFER! ASK US ABOUT OUR LOW
FIXED-RATE HOME EQUITY LOANS TODAY! HURRY - THESE
RATES WON'T lAST! CALL 1-866-929-7646 TODAY!
l~t
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STATEMENT DATE
1-15-03
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KYRA A SGRIGNOLI
11 H [NOLA DR
ENOLA PA 17025-2516
ACCOUNT TYPE OF ACCOUNT
900039843 TOTALLY FREE
AVERAGE BALANCE
1.196.97
_____________________________L________________~_____________________________
PREVIOUS BALANCE 1,403.91
OEPOS ITS 1.396.49
WITHDRAWALS 1.840.20
CHARGES 2.00
INTEREST .0 Q
ENDING BALANCE 958.20
* - - - . - - - - - - - -INTEREST SUMMARY- .. .. ~ .. ~ .. .. . "*
INTEREST PAID THIS YEAR .00
INTEREST WITHHELD THIS YEAR .00
* - - - - - - - - - - - - - TRANSACTION SUHMARY- - ... ... - *
DEPOSITS/ CHECKS/
DATE TRANSACTION DESCRIPTION CREDITS DEBITS BALANCE
12/16 120.00 1283.91
12/23 200.00 1083.91
12/23 CHECK 2341 16.35 1067.56
12/24 DEPOSIT 50.00 1117.56
12124 CHECK 2342 71.95 1045.61
---- 12/27 lEHSCRAfTERS PlC122402 692.06 1737.67
lUJl 100.00 1637.67
121 1 CHECJ: 2343 44.96 1592.71
1/03 CHECK 2344 600.00 992.71
1/03 CHECK 2345 39.45 953.26
1/07 CHECK 2335 400.00 553.26
1/07 CHECK 2346 19.11 534.15
1/10 LEHSCRAFTERS PLC 1/8/03 654.43 1188.58
1110 CHECK 2349 40.00 1148.58
1/13 100.00 1048.58
1/13 CHECK 2349 42.34 1006.24
1/13 CHECK 2348 25.00 981. 24
1/13 CHECK 2347 21. 04 960.20
1/15 SERVICE CHARGE 2.00 958,20
* ...--...--- - - - -CHECKS PAID- - - ... ... - - -*
NO. DATE AMOUNT NO. DATE AMOUNT
2335 1-07 400.00 2344 1.03 600.00
2341* 12-23 16.35 2345 1-03 39.45
2342 12-24 71.95 2346 1-07 19.11
2343 12-31 44.96 2347 1.}3 21.04
CONTINUED ON NEXT PAGE
https://192.168.99.20/dsi-binldsigtwy.dlllZOS--------n-900039R41?()O~() 11l\()()() 1 l-.+-.-.-.
'1\/1 Alf"\^"-
12-27-2002
DDA/NOW ACCOUNTS
TRANSACTION SYSTEM
ACCOUNT SHORT NAME R
NUMBER C
900039843 SGRIGNOU KYRA A
WAYPOINT BANK PROCESS-THRU 12-29-2002 PAGE 405
SUMMERDALE TA0330
TRIAL BALANCE 12-27-02 21:25:12 20-0010
CURRENT HOLDS S COLLECT LAST *---LAST DEPOSIT--* CHKS DEP PRV STM STMT S.C.S T o OF]
BALANCE A BALANCE ACTIVE DATE AMOUNT SINCE SINCE DATE T CY C T T Y D
1,737.67 1737 12-27-02 12-27-02 692.06 4 2 12-15-02 C 1512 R 110499 ZZ:
EXHIBIT "I"
Kyra Sgrignoli
424 F Duke Street
Eno/a, P A 17025
LAW FIRM OF SUSAN KA Y CANDIELLO
Nurse/Attorney
4010 Glenfinnan Place, Mechanicsburg, PA 17055
(717) 724-2278 Fax: (717) 724-2279
Invoice Date: January 1, 2006
Date Descriotion
Balance Forward: $ 14,000.00
Time Exoenses Pavments Amount
Balance Due
LAW FIRM OF SUSAN KAY CANDIELLO
Nurse/Attorney
4010 Glenfinnan Place, Mechanicsburg,-PA-1..Z055
~17) 724-2278 =7;;fJ1:J
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$14,000.00
JRN-29-2007 23:13
DIRNE Ri=lDCLIFF
717 975 0597 P.02/26
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
KYRA ANN SGRIGNOLl,
Plaintiff
V.
RODGER EUGENE SGRIGNOLl, JR,
Defendant
NO. 03-866 CIVIL TERM
CIVIL ACTION. LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was fHed on
February 26, 2003.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final Decree in Divorce after service of notice of intention
to request entry of the decree.
I verify that the statements made in this Affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
Dated:
J/3ZJ/()7
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JAN-29-2007 23:13
DIANE RADCLIFF
717 975 0697 P.03/26
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
KYRA ANN SGRIGNOLl,
Plaintiff
NO. 03.866 CIVIL TERM
V.
CIVIL ACTION. LAW
IN DIVORCE
RODGER EUGENE SGRIGNOLl, JR,
Defendant
1 . I consent to the entry of a final decree in divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I wm not be divorced untn a divorce decree is entered by the Court
and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary .
I verify that the statements made 1n this Waiver are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. 54904 relating
to unsworn falsification to authorities.
Da ted:
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JAN-29-2007 23:13
DIANE RADCLIFF
717 975 0597 P.04/25
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
KYRA ANN SGRIGNOLl,
Plaintiff
v.
NO. 03.866 CIVIL TERM
CIVIL ACTION. LAW
RODGER EUGENE SGRIGNOLl, JR,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
February 26) 2003.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final Decree in Divorce after service of notice of intention
to request entry of the decree.
I verify that the statements made in this Affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
Dated:
J/30/0'7
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DIANE RADCLIFF
717 975 0697 P.05/26
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY , PENNSYLVANIA
KYRA ANN SGRIGNOLl,
Plaintiff
V.
NO. 03.866 CIVIL TERM
CIVIL ACTION. LAW
IN DIVORCE
RODGER EUGENE SGRIGNOll, JR,
Defendant
1. I consent to the entry of a final decree in divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court
and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary .
I verify that the statements made in this Waiver are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. 54904 relating
to unsworn falsification to authorities.
Dated: I / JO! () I
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KYRA ANN SGRIGNOLI,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 03 - 866 CIVIL
RODGER EUGENE SGRIGNOLI, JR.,:
Defendant IN DIVORCE
ORDER OF COURT
AND NOW, this
J/~
day of
~'
fnto an a reement
2007, the parties and counsel having entered
and stipulation resolving the economic issues on January 30,
2007, the date set for a Master's hearing, the agreement and
stipulation having been transcribed, and subsequently signed by
the parties and counsel, the appointment of the Master is
vacated and counsel can conclude the proceedings by the filing
of a praecipe to transmit the record with the affidavits of
consent of the parties so that a final decree in divorce can be
entered.
~E caU,RT,
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Edgar B. Bayley, P.J.
cc:
~san Kay Candiello
Attorney for Plaintiff
~ane G. Radcliff
Attorney for Defendant
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KYRA ANN SGRIGNOLI,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
NO. 03 - 866 CIVIL
RODGER EUGENE SGRIGNOLI, JR.:
Defendant IN DIVORCE
THE MASTER: Today is Tuesday, January 30,
2007. This is the date set for a hearing in the
above-captioned divorce proceedings. Present in the hearing
room are the Plaintiff, Kyra Ann Sgrignoli, and her counsel
Susan Kay Candiello, and the Defendant, Rodger Eugene
Sgrignoli, Jr., and his counsel Diane G. Radcliff.
This action was commenced by the filing of a
complaint in divorce on February 26, 2003, raising grounds
for divorce of irretrievable breakdown of the marriage.
The parties have signed affidavits of consent and waivers of
notice of intention to request entry of divorce decree and
provided those documents to the Master. The documents were
dated January 30, 2007, and will be filed with the
Prothonotary by the Master's office. The divorce will,
therefore, conclude under Section 3301(c) of the Domestic
Relations Code.
The complaint also raised economic claims of
equitable distribution and alimony. The pleadings do not
show any claims raised for counsel fees and costs.
The parties were married on November 21,
1
1987, and separated on December 27, 2002. They are the
natural parents of two minor children who are currently in
the custody of wife.
The Master has been advised that the parties
have reached an agreement with respect to the issues
outstanding and an agreement is going to be placed on the
record in the presence of the parties. The agreement as
placed on the record 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 parties and
counsel are going to return later today to review the draft
of the agreement, make any corrections of typographical
errors as required, and then the parties will affix their
signatures affirming the terms of settlement as stated on
the record. In any event, when the parties leave the
hearing room, even though they have not signed the
agreement, they are bound by the terms as stated on the
record.
Upon receipt by the Master of a completed
agreement, the Master will prepare an order vacating his
appointment and counsel can then file a praecipe
transmitting the record to the Court requesting a final
decree in divorce. Ms. Radcliff.
MS. RADCLIFF: The terms of the agreement are
2
to be as follows:
1. The agreement is to be incorporated but not merged into
the divorce decree.
2. The provisions of the agreement and their legal effect
have been fully explained to the parties by their respective
legal counsel and the parties acknowledge the agreement is
fair under the circumstances and not the result of any
duress or undue influence.
3. Except as herein otherwise provided, each party may
dispose of his or her property in any way and each party
hereby waives and relinquishes any and all rights he or she
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 instruments which may be necessary or
advisable to carry into effect this mutual waiver and
relinquishment of all such interest, rights, and claims.
4. The parties agree that the 2004 income tax returns
shall stand as currently filed.
5. No waiver or modification of the terms of the agreement
shall be valid unless in writing signed by both of the
parties.
6. This agreement shall be binding and inure to the
benefit of the parties, their respective heirs, executors,
administrators and successors, and assigns.
7. The agreement constitutes the entire understanding of
the parties and supersedes any and all prior agreements.
8. The parties marital assets and debits shall be divided
and distributed as follows:
a.) The jointly owned real estate known as 11 North
Enola Drive, Enola, Pennsylvania, which is in encumbered
with a mortgage, No. 0263 owed to Washington Mutual shall be
divided and distributed in accordance with the following
provisions:
3
.
.,
1.) Husband shall prepare and wife shall execute
the deed conveying, transferring and granting all of wife's
interest in the real estate to husband. The deed of
conveyance shall be executed by wife within five (5) days of
her receipt of the deed and shall be held in escrow by
wife's attorney pending the refinance/assumption of the
mortgage and the payment of the monetary sum hereinafter
provided at which time the deed shall be delivered to
husband to record.
2.) The conveyance shall be subject to all liens
and encumbrances of record including the lien of the
mortgage. Hereafter, husband shall be solely responsible
for the payment of such expenses and shall indemnify,
protect, and save wife harmless therefrom.
3.) Husband shall apply for
refinancing/assumption of the mortgage within 15 business
days of the date of this agreement and shall complete that
refinance/assumption within 60 days of the date of this
agreement so as to release wife from further liability under
the mortgage. The costs of that refinance/assumption shall
be paid by husband.
b.) Wife shall receive the 2000 Chevrolet Cavalier
subject to any outstanding lien, loan, or other obligation
pertaining to the purchase thereof, previously GMAC and
shall indemnify and save husband harmless therefrom.
Husband shall execute the title to transfer that vehicle
into wife's name within five (5) business days upon receipt.
c.) The parties acknowledge that they have previously
divided to their satisfaction any bank accounts,
certificates of deposit, monetary accounts, US savings
bonds, and the like and hereafter any such accounts,
certificates of deposit, monetary deposits, savings bonds
and the like shall be the sole and separate property of the
party in whose name said assets are titled.
d.) Wife shall receive sole ownership of her
LensCrafters 401(k) plan.
e.) The marital value of husband's SERS retirement
plan shall be divided equally between the parties on a
deferred basis. Husband or husband's attorney shall prepare
the required QDRO for purposes of effectuating that transfer
and shall supply the same to wife and/or her counsel for
review and approval. That QDRO will then be entered as an
order of court and processed by the plan administrator
accordingly.
4
f.) The parties agree that their tangible personal
property including but not limited by way of specific
reference to jewelry, clothes, furniture, furnishing, rugs,
carpets, household equipment and the like have previously
been divided by the parties to their satisfaction and all
items of such personal property in the possession of wife
shall remain her sole and separate property and all such
personal property in the possession of husband shall remain
his and sole property.
g.) Husband shall pay wife the amount of $12,000.00 at
the time of completion of his refinance/assumption, to be
completed within sixty (60) days of the date of this
agreement.
h.) Husband shall assume sole responsibility for the
payment of the following debts:
1.) Joint East Pennsboro Township curbing debt
and Cameron Construction Sidewalk debt;
2. ) His GMAC car loan debt;
3. ) His MBNA,.Account No. 1677;
4. ) The joint NFCU, Account No. 2508;
5. ) Husband's Bank One debt;
6. ) Husband's TMobile Wireless, Account No.
6614;
7.) Husband's CTSI, Account No. 6235;
8.) Husband's East Pennsboro School District debt
for attorney fees.
Husband shall provide wife with proof of payment
of the joint NFCU, Account No. 2508. He shall not be
obligated to provide wife with proof of any of the remaining
debts since they are solely in his name.
9. The parties hereto agree and waive any right or claim
they may have now and in the future against the other for
alimony, alimony pendente lite, spousal support, and
maintenance.
10. Each of the parties hereby waives any right or claim
they may have both now and in the future against the other
for counsel fees, costs and expenses except for any such
5
counsel fees, costs and expenses arising out of the breach
of this agreement.
MS. CANDIELLO: I am Susan Kay Candiello
representing Kyra Ann Sgrignoli. Kyra, you've heard the
agreement as stated by Roger's Sgrignoli's counsel. Are you
in agreement with that?
MS. SGRIGNOLI: Yes.
MS. CANDIELLO: Do you understand that
agreement?
MS. SGRIGNOLI: Yes.
MS. CANDIELLO: Do you have any questions
about the agreement?
MS. SGRIGNOLI: No.
MS. CANDIELLO: Are you prepared when we see
the agreement in writing to sign that agreement?
MS. SGRIGNOLI: Yes.
MS. CANDIELLO: And today is January 30,
2007?
MS. SGRIGNOLI: Yes.
MS. RADCLIFF: Mr. Sgrignoli, you were
present when I read off the terms of the agreement?
MR. SGRIGNOLI: Yes.
MS. RADCLIFF: Did you understand each and
every term that I so stated?
MR. SGRIGNOLI: Yes, I did.
6
MS. RADCLIFF: Did you have any questions
about any of those terms?
MR. SGRIGNOLI: No; just like a copy of it
then.
MS. RADCLIFF: And do you agree to be bound
by the terms as read?
MR. SGRIGNOLI: Yes, I do.
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 intend
to bind myself to the settlement as a contract obligating
myself to the terms of settlement and subjecting myself to
the methods and procedures of enforcement which may be
imposed by law and in particular Section 3105 of the
Domestic Relations Code.
WITNESS:
DATE:
t/ 60 IV7-
#2
7
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Kyr Ann Sgrlg litfYl
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KYRA ANN SGRlGNOLI,
PLAINTIFF
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
~.. RNNSRVANIA
VI.
: NO. 03-866 CML TERM
.
'"'
ROGER EUGENE SGRIGNOLI,
DEFENDANT
: CML ACTION - LAW
: ACTION FOR DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
P!ea.seilHMmit the~.togethet wHltthe~ ~totheC~fat~
of a divorce decree:
t. 6roond fordiv~ &retrievabte'breakdown underSectiort JJ&t~e}ofthe Dtv6fCe
Code.
2. Date and manner of service ofComplamt: The Defendant, Roger Eugene Sgrignoli,
signed the Acceptance of Service on August 14th, 2003. Said Acceptance of Service
was filed with the Cumberland County Prothonotary on August 15th, 2003.
3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the
Divorce Code by:
Pluiutilf. January Jdh , 2007
Defendant: January 30th , 2007
(a) Related claims pending: None
(b) Claims withdrawn: None
(c) Claims settled by agreement of the parties: All claims
(d) Please see the Mariat. Prop.a~' Settiement Agreement wftidt. was filed by the
Master, Robert Elicker and is to be incorporated but not merged into the Divorce
Decree. (Master Robert Elicker also filed the Affidavits of Consent.)
4. I certify that the Waiver of Notice of Intention to Request Entry ofa Divorce Decree
Under Section 3301(c) of Divorce Code, as required by Rule 1920.42(e)(l), were
exeeu(ed. 00 JmUlU) ~ , 2001 by the- Plaftttitf and Oft JumJary 3(th , 2001 by the
~
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Defendant, and these documents were filed by Master Robert Elicker. I further
certify that all other documents required by Rule 1920.42 are enclosed herewith.
Respectfully submitted,
LAW.FlRM OF SUSAN KAY CANDtELLO; PC.C.
Dated: February ~ 2007
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IN THE COURT OF COMMON P
OFCUMBERLANDCOUNTY
AS
STATE OF
PENNA.
KYRA ANN SGRTGNOLI,
Plaintiff
NO.2
RM
VERSUS
RODGER EUGENE SGRIGNOLI, JR.,
Defendant
DECREE IN
DIVORCE
AND NOW,
f~~' tr }1
'2007
, IT IS 0
ERED AND
DECREED THAT KYPA ANN SGRTGNOT T
AND
RODGER EUGENE SGRIGNOLT. eTR.
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL OR
YET BEEN ENTERED;
H ICH HAVE
R HAS NOT
No issues are outstandin . All issues have been resolved and s
the Parties' Marital Agreement dated January 30, 2007, filed
and incor orated into but not
tIed b
record
By T
HONOTARY
J.
/IrrrI Jr ~ ~ r>r;:oJl., (..0 IJ [:
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KYRA ANN SGRIGNOLI,
Plaintiff NO. 03-866 CIVIL TERM
V.
CIVIL ACTION - LAW
RODGER EUGENE SGRIGNOLI, JR,
Defendant
IN DIVORCE
STIPULATION AND AGREEMENT
FOR THE ENTRY OF "DOMESTIC RELATION ORDER"
AND NOW, this \a~y of ~ ,2007, the parties having been divorced by Decree
dated _f;h~ J.1 ,2007 of the Court of Common Pleas of Cumberland County, Pennsylvania,
entered at Doc et Number 03-866, do hereby stipulate and agree as follows:
1. The Defendant, Rodger E. Sgrignoli Jr., (hereinafter referred to as "Member") is a member
of the Commonwealth of Pennsylvania State Employees' Retirement System (hereinafter
referred to as "SERS").
2. SERS, as a creature of statute is controlled by the State Employees Retirement Code, 71 Pa.
C.S.SS 5101-5956 ("Retirement Code").
3. Member's date of birth is May 28, 1962 and the Member's Social Security number is 197-
58-1532.
4. The Plaintiff, Kyra A. Sgrignoli, (hereinafter referred to "Alternate Payee") is the former
spouse of Member. Alternate payee's date of birth is November 26, 1960. Alternate Payee's
Social Security number is 404-90-4955.
5. Member's current mailing address is:
11 North Enola Drive
Enola, P A 17025
6. Alternate Payee's current mailing address is:
424F Duke Street,
Enola, P A 17025
It is the responsibility ofthe Alternate Payee to keep a current mailing address on files with
SERS at all times.
\ .
7. The marital property component of Member's retirement benefit equals:
(a) the Coverture Fraction multiplied by
(b) Member's retirement benefit on effective date of Member's retirement calculated
using the Retirement Code in effect on December 27, 2002, date of parties'
separation, and Member's final average salary on December 27, 2002 (date of
separation).
8. The Coverture Fraction is a fraction with a value less than or equal to one. The numerator
is the amount of Member's service, as defined by SERS, for the period of time from July 1,
1995 (date of hire) to December 27,2002 (date of separation). The denominator is the total
amount of Member's service, as defined by SERS, on the effective date of Member's
retirement.
9. Fifty percent (50%) ofthe marital property component of Member's retirement benefit is to
be allocated to Alternate Payee as the equitable distribution portion of this marital asset.
10. Member's retirement benefit is defined as all monies paid to on or behalf of Member by
SERS, including any lump sum withdrawals or scheduled ad hoc increases, but excluding
the disability portion of any disability annuities paid to Member by SERS as a result of a
disability which occurs before Member's marriage to Alternate Payee or after the date of
Member's and Alternate Payee's final separation. Member's retirement benefit does not
include any deferred compensation benefits paid to Member by SERS or any enhancement
to the Member's retirement benefit arising from post-separation monetary contributions
made by Member. The equitable distribution portion of the marital property component of
Member's retirement benefit, as set forth in paragraphs seven through nine (7-9), shall be
payable to Alternate Payee and shall commence as soon as administratively feasible on or
about the date Member actually enters pay status and SERS approves a Domestic Relations
Order incorporating this Stipulation and Agreement, whichever is later.
11. Member hereby nominates Alternate Payee as an irrevocable beneficiary to the extent of
Alternate Payee's equitable distribution portion of Member's retirement benefit for any death
benefits payable by SERS. This nomination shall become effective upon approval by the
Secretary of the Retirement Board, or other authorized representative ofthe Secretary, of any
Domestic Relations Order incorporating this Stipulation and Agreement. The balance of any
death benefit remaining after the allocation of the equitable distribution portion payable to
Alternate Payee and any other alternate payees named under other SERS-approved Domestic
Relations Orders ("Balance") shall be paid to the beneficiaries named by Member on the last
Nomination of Beneficiaries Form filed with the Retirement Board prior to Member's death.
If the last nomination of Beneficiaries Form filed by Member prior to Member's death (a)
predates any approved Domestic Relations Order incorporating this Stipulation and
Agreement, and (b) names Alternate Payee as a beneficiary, then: (l) the terms of the
Domestic Relations Order shall alone govern Alternate Payee's share of any death benefit,
and (2) for purposes of paying the Balance via the last Nomination of Beneficiaries Form
filed with the Retirement Board prior to Member's death, Alternate Payee shall be treated
as if Alternate Payee predeceased Member. No portion of the Balance shall be payable to
J .
Alternate Payee's estate.
In addition, Member shall execute and deliver to Alternate Payee an authorization, in a form
acceptable to SERS, which will authorize SERS to release to Alternate Payee all relevant
information concerning Member's retirement account.
12. The term and amounts of Member's retirement benefits payable to Alternate Payee after
SERS approves a Domestic Relations Order incorporating this Stipulation and Agreement
depends upon which option Member selects at retirement. Member and Alternate Payee
expressly agree that Member may select any retirement option offered by SERS under the
Retirement Code at the time Member files an Application for Retirement Allowance with
SERS.
13. Alternate Payee may not exercise any right, privilege, or option offered by SERS. SERS
shall issue individual tax forms to Member and Alternate Payee for amounts paid to each.
14. In the event of death of Alternate Payee prior to receipt of all payments payable from SERS
under a Domestic Relations Order incorporating this Stipulation and Agreement, and death
benefit or retirement benefit payable to Alternate Payee by SERS shall "Revert to Member."
15. In no event shall Alternate Payee have benefits or rights greater than those that are available
to member. Alternate Payee is not entitled to any benefit not otherwise provided by SERS.
Alternate Payee is only entitled to the specific benefits offered by SERS as provided in this
Stipulation and Agreement. All other rights, privileges, and options offered by SERS not
granted to Alternate Payee by this Stipulation and Agreement are preserved for Member.
Member and Alternate Payee acknowledge that benefits paid pursuant to this Stipulation and
Agreement are and shall remain subject to the Public Employee Pension Forfeiture Act, 43
P.S. S 1311, et seq.
16. It is specifically intended and agreed by the parties hereto that any Domestic Relations
Order incorporating this Stipulation and Agreement:
(a) Does not require SERS to provide any type of benefit, or any option, not otherwise
provided under the Retirement Code;
(b) Does not require SERS to provide increased benefits (determined on the basis of
actuarial value) unless increased benefits are paid to Member based upon cost of
living adjustments or increases based on other than actuarial values.
17. The parties intend and agree that the terms of this Stipulation and Agreement shall be
approved, adopted and entered as a Domestic Relations Order.
18. The Court of Common Pleas of Cumberland County, Pennsylvania, shall retain jurisdiction
to amend any Domestic Relations Order incorporating this Stipulation and Agreement, but
only for the purpose of establishing it or maintaining it as a Domestic Relations Order;
provided, however, that such amendment shall not require SERS to provide any type ofform
of benefit, or any option not otherwise provided by SERS, and further provided that such
amendment or right to so amend will not invalidate the parties' existing Domestic Relations
Order.
"II ...!. .
19. Upon entry of a Domestic Relations Order incorporating this Stipulation and Agreement, a
certified copy of the Domestic Relations Order and this Stipulation and Agreement any
attendant documents shall be served upon SERS immediately. Such Domestic Relations
Order shall take effect immediately upon SERS approval and SERS approval of any
attendant documents and then shall remain in effect until such time as a further Order of
Court amends or vacates the Domestic Relations Order.
WHEREFORE, the parties, intending to be legally bound by the terms of this Stipulation and
agreement, do hereunto place their hands and seals.
Date:
~ _/1 +~
Plainti'l:emate Payee
Date:
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Date: d-j lic I () 1-
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KYRA ANN SGRIGNOLl,
Plaintiff
NO. 03-866 CIVIL TERM
V.
CIVIL ACTION - LAW
RODGER EUGENE SGRIGNOU, JR,
Defendant
IN DIVORCE
CERTIFICATION OF ASSIGNED JUDGES
I, Diane G. Radcliff, Esquire, attorney for the Defendant in the above captioned matter,
hereby certify that judges involved in this case are as follows:
Edward E. Guido
Petition for Special Relief
Decree in Divorce
George Hoffer
Order Appointing Divorce Master
Edgar B. Bayley
Order Vacating Divorce Master
Respectfully submitted,
. Radc 'ff, Esquire
oad
Camp Hill, PA 17011
(717) 737-0100
I.D. No. 32112
Attorney for Defendant
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lIAR U 200711 '7
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
KYRA ANN SGRIGNOLI,
Plaintiff
NO. 03-866 CIVIL TERM
V.
CIVIL ACTION - LAW
RODGER EUGENE SGRIGNOLI, JR,
Defendant
IN DIVORCE
DOMESTIC RELATIONS ORDER
AND NOW, this ~"J... day of ~ ,2007, the attached
STIPULATION AND AGREEMENT FOR THE ENTRY OF "DOMESTIC RELATION
ORDER dated3 -/l-1)1 is incorporated into this Order of Court the same as offully set forth
herein.
1.
Distribution to:
~orney for Plaintiff: Susan K. Candiello, Esquire, 4010 Glenfinnan Place, Mechanicsburg, P A 17055
;torney for Defendant: Diane G. Radcliff, Esquire, 3448 Trindle Road, Camp Hill, PA 17011
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