HomeMy WebLinkAbout98-06379
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF *~~ PENNA.
, "1. ~
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GOORGE: M. 1'UALASSlNOS,
Plaintiff
No,
98 - 6379 CIVIL TERM _____
VERSUS
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II
TINA L. THALASSINOS,
Defendant
DECREE IN
DIVORCE
.
AND NOW,
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, , IT 15 ORDERED AND
DECREED THAT
George M. Tha1assinos
, PLAINTIFF,
.
AND
Tina L. Tha1assinos
, DEFENDANT,
.
.
.
.
.
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED; None
.
The attached Agreement reached at the Master's conference on June 21, 2001
.
.
is hereby incorporated,
Decree in Divorce.
.
PROTHONOTARY
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.
BY
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Am"(JD~1
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GEORGE M. THALASSINOS,
PlaintH f
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Vs,
NO, 98 - 6379 CIVIL
TINA L, THALASSINOS,
Defendant IN DIVORCE
THE MASTER: Today is Friday, June 21, 2002,
This is the date we set for a conference with counsel and
the parties,
Present in the hearing room are the
Plaintiff, George M. Thalassinos. and his counsel John J,
Connelly, Jr" and the Defendant, Tina L, Thalassinos, and
her counsel Samuel L. Andes,
This action was commenced by the filing of a
divorce complaint on November 10, 1998. raising grounds for
divorce of irretrievable breakdown of the marriage, The
Master has been provided affidavits of consent and waivers
of notice of intention to request entry of divorce decree
signed and dated by both parties today,
The Master's
office will file the affidavits and waivers with the
Prothonotary, The divorce can proceed under Section
3301(c) of the Domestic Relations Code,
The complaint also raised the economic claim
of equitable distribution.
The parties were married on July 2, 1989,
and separated May 27, 1998, They are the natural parents
of two minor children who are in the custody of wife,
The Master has been advised that after
1
.
considerable negotiations this morning that the parties
have reached an agreement with respect to the claim for
equitable distribution which was raised with the filing of
the divorce complaint, 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, Consequently, when the parties leave the
hearing room today they will be bound by the terms of the
agreement even though there is no subsequent signatures on
the agreement ratifying the terms of settlement as stated
on the record.
Following receipt of the 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,
No claims have been raised in this action
for alimony or counsel fees or costs by either party, The
settlement that is going to be placed on the record will
deal only with the claim of equitable distribution raised
by husband in his complaint,
(A discussion was held off the record,)
2
THE MASTER: Nt". Connelly hilS advised that
in addition to the equitable distribution settlement there
is going to be an agreement stated on the record with
respect to child support matters that have been resolved
between the parties,
Mr, Connelly,
MR, CONNELLY: After several hours of
negotiations, prior sessions of negotiations, exchanges of
correspondence, and numerous telephone conversations with
counsel, the parties have reached the following agreement:
1, First as to child support for the parties' minor
children indexed to PACES case NO, 179100301, Effective
July 1, 2002, the spousal support order shall terminate,
On that date and on each month thereafter husband agrees to
pay for the support of his two minor children the sum of
$1,000,00 per month, This may not be modified for a period
of six (6) months from July 1, 2002,
2. In addition to support, husband agrees to pay 75% of
any unreimbursed medical expenses after $250,00 per child
per year, Further, husband agrees to provide medical
insurance for the children,
3, In the event wife secures employment, pending any
modification of this order in the future, husband will
agree to pay 75% of actual child care expenses.
4, As indicated previously, this order shall not be
modified for a period of six (6) months, Thereafter in the
event of modification, the proportional share of medical
bills or child care expenses shall be as determined by the
Court,
5, The new order will make no provision for the payment
of private school expenses for either of the parties'
children, The parties agree that Christina's upcoming
tuition, school year 2002 - 2003, for the Harrisburg
Academy will be paid out of escrow funds held by counsel,
Thereafter, each party reserves any claims or defenses they
may have regarding the contribution to private school
education for either child in the future, Husband agrees
3
to pay for Alexandra's preschool at Saint James for the
school year 2002 - 2003 in full,
6, The parties further agree that commencing with the tax
year 2002 each shall provide copies of their federal income
tax return together with copies of W-2s or 1099s or other
supporting documents no later than May 1 of the year
following the end of the tax year,
7, As to equitable distribution of marital property, each
party shall retain the motor vehicles currently in their
possession and ownership, Each party has traded a vehicle
owned previously for the vehicles they now hold title to,
8, Husband agrees to convey to wife as her sole and
separate property the real estate located at 819 Kent
Drive, Mechanicsburg, Pennsylvania, This transfer shall be
subject to all liens, encumbrances, easements, and
restrictions presently existing, Husband shall execute the
said deed upon presentation by wife's counsel which shall
occur within ten (10) days of the date of this agreement,
wife agrees that she shall indemnify and hold husband
harmless on the existing mortgage to the property and shall
on or before her daughter Alexandra begins first grade
refinance, modify the mortgage, sell the property, or take
any other steps necessary to remove husband's name from the
mortgage by that date.
9, In addition, wife shall, if she has not already done
so, delete husband's name from any existing utilities
relating to the property, The parties will take within
ten (10) days of today's date whatever steps are necessary
to have the utilities changed into wife's name
individually,
10. Husband shall retain ownership of his IRA account with
Smith Barney, Wife relinquishes any claims she may have to
that account,
11, The parties acknowledge that there are certain
accounts which wife holds as custodian for the parties'
daughters, Husband agrees that he will execute any
documents necessary to be certain that wife is the sole
custodian on these said accounts, Wife will provide
husband with annual statements from the accounts for the
purposes of providing him information on the status of
those accounts, The requirement for wife to provide annual
statements to husband shall begin in January 2003 and shall
be done on an annual basis thereafter,
4
.
12, Currently there are two escrow accounts being held by
counsel for the parties, Counsel for husband, John J,
Connelly, Jr" is holding approximately $66,500,00 in an M
& T Bank account and counsel for wife, Samuel L, Andes, is
holding approximately $78,400,00 in an escrow account, The
parties have agreed to divide the escrow accounts as
follows:
AI Christina's tuition payment to Harrisburg Academy
in the amount of $10,736,00 shall be paid immediately from
the escrow account held by counsel for husband.
B) Husband shall receive $53,000,00 as his equitable
distribution from the said M & T account. The remaining
monies shall be forwarded to counsel for wife and she shall
retain as her sole and separate property, in the form of
equitable distribution, the balance from the M & T account
as well as the account held by Mr, Andes as her counsel.
13. The parties have a tax liability to the Commonwealth
of Pennsylvania, As of February 22, 2002 for the tax year
1999 the amount of $648,01 and for the tax year 1998 in the
amount of $638.63, The parties agree that they will
equally share in the expense of the tax liability. It
should be noted for the record today that the tax liability
may have changed minimally since the date of the statements
referred to in this record, In any event, the parties
agree that they will share them equally,
In addition, any tax liability occurring in the future
for any joint returns filed by the parties shall be shared
equally unless there is a specific determination that
either party had under reported or inaccurately stated
income on their return and in that event that party shall
be responsible for the tax liability,
14, The parties' accountant has advised them of the
possibility of a tax credit in the amount of $3,807,00 as a
carryover from a prior year tax return, It is uncertain
at the time the parties enter into this agreement as to how
this tax credit can be used, and to the extent it can be
used by either party. they will share equally in the
benefit,
It is the intent to divide this tax credit equally to
the extent it can be used by both parties on an equal
basis, In the event that only one party can use the tax
credit, the other party shall receive one-half of the tax
credit which benefited the party using it, The parties
agree that they will share that tax credit in the future
5
,
~
equally as allowed by law.
~
15. As to the personal property, each shall retain
personal property in their possession with the exception of
certain items of personal property of husband in the
possession of wife or at her residence, As to the
personal property at wife's residence, husband will receive
his backgammon set which was a gift from his parents, The
parties agree to meet at the marital residence and attempt
to locate husband's diploma, passport, birth certificate,
jewelry box and jewelry, books and textbooks, and any items
of clothing that were not previously removed and will
cooperate in reviewing photographs and videos of the
parties' children in order to, if necesaary, make copies
should they not be able to agree on a division of the
photographs and videos.
~
:
16, Husband agrees that he shall secure a life insurance
policy with a death benefit of $100,000,00 naming the
children as sole and exclusive beneficiaries on the said
policy, Husband agrees that he shall pay all premiums and
take all action necessary to maintain such insurance
without reduction in the death benefit and continue the
children as sole and exclusive beneficiaries until the
youngest child attains the age of 24 years, Husband
further agrees that he shall provide proof to wife at least
annually of the continuation of such insurance in
compliance with this paragraph,
17, The parties acknowledge on the record today that
there are no marital debts with the exception of the home
mortgage on the marital residence, The parties further
acknowledge that part of the transfer of title of the
marital residence to wife is wife's assumption of any
obligation the parties have had to wife's father for a loan
to acquire the residence, All other debts of the parties
were paid off after the sale of their New York residence.
,
I
I ,
18, In reference to the child support action addressed
previously, this settlement takes into account any and all
Obligations for reimbursement of medical coverage on the
said support order with the exception of a balance due to
pinnacle Health in the amount of $124,10 which shall be the
sole responsibility of husband, That is identified as
Account No. 220220803, In addition, there is a payment due
to Dr, Mayes at the Hershey Medical Center for an
evaluation of the parties' daughter Christina for ADD,
That bill shall also be paid by husband individually, The
medical bills referred to for Pinnacle Health and Dr, Mayes
shall be paid within ten (10) days of the distribution of
6
the escrow account funds,
19, In the event of breach of the terms of this agreement
by either party, the non-breaching party shall be entitled
to recover reasonable attorney fees for enforcement of the
terms of the agreement,
20, The parties agree that they will not conclude the
divorce until after the 1st of July 2002; that they will
communicate and cooperate so that wife's insurance will not
be terminated prior to the end of July and will exchange
information about the insurance Coverage available to wife,
21. 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,
MR, CONNELLY: Mr. Thalassinos, you've heard
me dictate on the record the terms and conditions of the
agreement we reached today; is that correct?
MR, THALASSINOS: Yes,
MR, CONNELLY: Do you understand the terms?
MR, THALASSINOS: Yes,
MR, CONNELLY: Do you agree with them?
MR, THALASSINOS: Yes,
MR. CONNELLY: Do you understand that upon
the completion of the record today no further documents
will be signed confirming this agreement with the exception
7
,
of which you heard placed on the record?
I1R, TIfALASSINOS: Yes,
I1R, CONNELLY: And that it is completely
enforceable from this moment forward?
I1R, THALASSINOS: Yes,
MR, ANDES: Mrs. Thalassinos, you heard the
agreement that was dictated, did you?
I1RS, THALASSINOS: Yes.
MR, ANDES: We have been at this for three
hours today, but you and I have met and we have been over
the issues and we have been over the assets previously; is
that correct?
MRS, THALASSINOS: Yes.
I1R, ANDES: Do you have any questions about
the terms of the agreement and are you satisfied that you
understand it?
MRS, THALASSINOS: Yes, I'm satisfied,
MR, ANDES: Is this what you're willing to
do so resolve these claims and get the divorce completed?
MRS, THALASSINOS: Yes,
THE MASTER: Do you understand that when you
leave this hearing room today that you are bound by the
8
GEORGE M. '1'IlALASSINOS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Vs,
NO, 98 - 6379 CIVIL
TINA L, 1'HALASS I NOS,
Defendant IN DIVORCE
THE MASTER: Today is Friday, June 21, 2002,
This is the date we set for a conference with counsel and
the parties,
Present in the hearing room are the
Plaintiff, George M, Thalassinos, and his counsel John J,
Connelly, Jr" and the Defendant, Tina L. Thalassinos, and
her counsel Samuel L, Andes,
This action was commenced by the filing of a
divorce complaint on November 10, 1998, raising grounds for
divorce of irretrievable breakdown of the marriage, The
Master has been provided affidavits of consent and waivers
of notice of intention to request entry of divorce decree
signed and dated by both parties today,
The Master's
office will file the affidavits and waivers with the
Prothonotary, The divorce can proceed under Section
3301(c) of the Domestic Relations Code,
The complaint also raised the economic claim
I
of equitable distribution.
i
r
f"
f
r~~
The parties were married on July 2, 1989,
and separated May 27, 1998, They are the natural parents
of two minor children who are in the custody of wife,
The Master has been advised that after
1
considerable negotiations this morning that the parties
have reached an agreement with respect to the claim for
equitable distribution which was raised with the filing of
the divorce complaint,
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,
Consequently. when the parties leave the
hearing room today they will be bound by the terms of the
agreement even though there is no subsequent signatures on
the agreement ratifying the terms of settlement as stated
on the record,
Following receipt of the 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,
No claims have been raised in this action
for alimony or counsel fees or costs by either party. The
settlement that is going to be placed on the record will
deal only with the claim of equitable distribution raised
by husband in his complaint,
(A discussion was held off the record,)
,;:,;,
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2
THE MASTER: Mr, Connelly has advised that
in addition to the equitable distribution settlement there
is going to be an agreement stated on the record with
respect to child support matters that have been resolved
between the parties,
Mr, Connelly,
MR. CONNELLY: After several hours of
negotiations, prior sessions of negotiations, exchanges of
correspondence, and numerous telephone conversations with
counsel, the parties have reached the following agreement:
1, First as to child support for the parties' minor
children indexed to PACES case NO, 179100301, Effective
July 1, 2002, the spousal support order shall terminate,
On that date and on each month thereafter husband agrees to
pay for the support of his two minor children the sum of
$1,000,00 per month, This may not be modified for a period
of six (6) months from July 1, 2002,
2, In addition to support, husband agrees to pay 75% of
any unreimbursed medical expenses after $250,00 per child
per year, Further, husband agrees to provide medical
insurance for the children,
3, In the event wife secures employment, pending any
modification of this order in the future, husband will
agree to pay 75% of actual child care expenses,
4, As indicated previously, this order shall not be
modified for a period of six (6) months. Thereafter in the
event of modification, the proportional share of medical
bills or child care expenses shall be as determined by the
Court,
5, The new order will make no provision for the payment
of private school expenses for either of the parties'
children, The parties agree that Christina's upcoming
tuition, school year 2002 - 2003, for the Harrisburg
Academy will be paid out of escrow funds held by counsel,
Thereafter, each party reserves any claims or defenses they
may have regarding the contribution to private school
education for either child in the future, Husband agrees
3
to pay for Alexandra's preschool at Saint James for the
school year 2002 - 2003 in full.
6. The parties further agree that commencing with the tax
year 2002 each shall provide copies of their federal income
tax return together with copies of W-2s or 1099s or other
supporting documents no later than May 1 of the year
fOllowing the end of the tax year,
7, As to equitable distribution of marital property, each
party shall retain the motor vehicles currently in their
possession and ownership, Each party has traded a vehicle
owned previously for the vehicles they now hold title to,
t
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~.
8. Husband agrees to convey to wife as her sole and
separate property the real estate located at 819 Kent
Drive, Mechanicsburg, Pennsylvania, This transfer shall be
subject to all liens, encumbrances, easements, and
restrictions presently existing, Husband shall execute the
said deed upon presentation by wife's counsel which shall
occur within ten (10) days of the date of this agreement,
Wife agrees that she shall indemnify and hold husband
harmless on the existing mortgage to the property and shall
on or before her daughter Alexandra begins first grade
refinance, modify the mortgage, sell the property, or take
any other steps necessary to remove husband's name from the
mortgage by that date,
)
~
9, In addition, wife shall, if she has not already done
so, delete husband's name from any existing utilities
relating to the property. The parties will take within
ten (10) days of today's date whatever steps are necessary
to have the utilities changed into wife's name
individually,
,
~
10. Husband shall retain ownership of his IRA account with
Smith Barney, Wife relinquishes any claims she may have to
that account,
11. The parties aCknowledge that there are certain
accounts which wife holds as custodian for the parties'
daughters, Husband agrees that he will execute any
documents necessary to be certain that wife is the sole
custodian on these said accounts, Wife will provide
husband with annual statements from the accounts for the
purposes of providing him information on the status of
those accounts, The requirement for wife to provide annual
statements to husband shall begin in January 2003 and shall
be done on an annual basis thereafter,
4
to pay for Alexandra's preschool at Saint James for the
school year 2002 - 2003 in full,
6, The parties further ilgree that commencing with the tilX
year 2002 each shall provide copies of their federal income
tax return together with copies of W-2s or 1099s or other
supporting documents no lilter than Hay 1 of the yeilr
following the end of the tilX year,
7, As to equitable distribution of marital property, each
party shall retain the motor vehicles currently in their
possession and ownership, Each party has traded a vehicle
owned previously for the vehicles they now hold title to,
8, Husband agrees to convey to wife as her sole and
separate property the real estate located at 819 Kent
Drive, Mechanicsburg, Pennsylvania, This transfer shall be
subject to all liens, encumbrances, easements, and
restrictions presently existing, Husband shall execute the
said deed upon presentation by wife's counsel which shall
occur within ten (10) days of the date of this agreement,
Wife agrees that she shall indemnify and hold husband
harmless on the existing mortgage to the property and shall
on or before her daughter Alexandra begins first grade
refinance, modify the mortgage, sell the property, or take
any other steps necessary to remove husband's name from the
mortgage by that date,
9, In addition, wife shall, if she has not already done
so, delete husband's name from any existing utilities
relating to the property, The parties will take within
ten (10) days of today's date whatever steps are necessary
to have the utilities Changed into wife's name
individually,
10. Husband shall retain ownership of his IRA account with
Smith Barney, Wife relinquishes any claims she may have to
that account,
11, The parties aCknOWledge that there are certain
accounts which wife holds as custodian for the parties'
daughters, Husband agrees that he will execute any
documents necessary to be certain that wife is the sole
custodian on these said accounts, Wife will provide
husband with annual statements from the accounts for the
purposes of providing him information on the status of
those accounts, The requirement for wife to provide annual
statements to husband shall begin in January 2003 and shall
be done on an annual basis thereafter.
4
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12, Currently there are two escrow accounts being held by
counsel for the parties, Counsel for husband, John J,
Connelly, Jr" is holding approximately $66,500,00 in an M
& T Bank account and counsel for wife, Samuel L, Andes, is
holding approximately $78,400.00 in an escrow account, The
parties have agreed to divide the escrow accounts as
follows:
A) Christina's tuition payment to Harrisburg Academy
in the amount of $10,736,00 shall be paid immediately from
the escrow account held by counsel for husband,
B) Husband shall receive $53,000,00 as his equitable
distribution from the said M & T account, The remaining
monies shall be forwarded to counsel for wife and she shall
retain as her sole and separate property, in the form of
equitable distribution, the balance from the M & T account
as well as the account held by Mr. Andes as her counsel,
13, The parties have a tax liability to the Commonwealth
of Pennsylvania, As of February 22, 2002 for the tax year
1999 the amount of $648,01 and for the tax year 1998 in the
amount of $638,63, The parties agree that they will
equally share in the expense of the tax liability, It
should be noted for the record today that the tax liability
may have changed minimally since the date of the statements
referred to in this record, In any event, the parties
agree that they will share them equally.
In addition. any tax liability occurring in the future
for any joint returns filed by the parties shall be shared
equally unless there is a specific determination that
either party had under reported or inaccurately stated
income on their return and in that event that party shall
be responsible for the tax liability,
14, The parties' accountant has advised them of the
possibility of a tax credit in the amount of $3,807,00 as a
carryover from a prior year tax return, It is uncertain
at the time the parties enter into this agreement as to how
this tax credit can be used, and to the extent it can be
used by either party, they will share equally in the
benefit,
It is the intent to divide this tax credit equally to
the extent it can be used by both parties on an equal
basis. In the event that only one party can use the tax
credit. the other party shall receive one-half of the tax
credit which benefited the party using it, The parties
agree that they will share that tax credit in the future
5
equally as allowed by law,
15, As to the personal property, each shall retain
personal property in their POssession with the exception of
certain items of personal property of husband in the
possession of wife or at her residence, As to the
personal property at wife's residence, husband will receive
his backgammon set which was a gift from his parents, The
parties agree to meet at the marital residence and attempt
to locate husband's diploma, passport, birth certificate,
jewelry box and jewelry, books and textbooks, and any items
of clothing that were not previously removed and will
cooperate in reviewing photographs and videos of the
parties' children in order to, if necessary, make copies
should they not be able to agree on a division of the
Photographs and videos,
16. Husband agrees that he shall secure a life insurance
pOlicy with a death benefit of $100,000,00 naming the
children as sole and exclusive beneficiaries on the said
policy, Husband agrees that he shall pay all premiums and
take all action necessary to maintain such insurance
without reduction in the death benefit and continue the
children as sole and exclusive beneficiaries until the
youngest child attains the age of 24 years, Husband
further agrees that he shall provide proof to wife at least
annually of the continuation of such insurance in
compliance with this paragraph,
17, The parties acknowledge on the record tOday that
there are no marital debts with the exception of the home
mortgage on the marital residence, The parties further
acknowledge that part of the transfer of title of the
marital residence to wife is wife's assumption of any
obligation the parties have had to wife's father for a loan
to acquire the residence, All other debts of the parties
were paid off after the sale of their New York residence,
18, In reference to the child support action addressed
previously, this settlement takes into account any and all
obligations for reimbursement of medical coverage on the
said support order with the exception of a balance due to
Pinnacle Health in the amount of $124,10 which shall be the
sole responsibility of husband, That is identified as
Account No, 220220803, In addition, there is a payment due
to Dr, Mayes at the Hershey Medical Center for an
evaluation of the parties' daughter Christina for ADD,
That bill shall also be paid by husband individually, The
medical bills referred to for Pinnacle Health and Dr, Mayes
shall be paid within ten (10) days of the distribution of
6
.
of which you heard pldced on the record?
MH, 'l'IIALASSINOS: Yes,
MH, CONNELLY: And that it is completely
enforceable from this moment [oL"wdrd?
MR, THALASSINOS: Yes.
MR, ANDES: Mrs, Thalassinos, you heard the
agreement that was dictated, did you?
MRS, THALASSINOS: Yes,
MR, ANDES: We have been at this for three
hours today, but you and I have met and we have been over
the issues and we have been over the assets previously; is
that correct?
MRS, THALASSINOS: Yes,
MR, ANDES: Do you have any questions about
the terms of the agreement and are you satisfied that you
understand it?
MRS, THALASSINOS: Yes, I'm satisfied,
MR, ANDES: Is this what you're willing to
do so resolve these claims and get the divorce completed?
MRS, THALASSINOS: Yes.
THE MASTER: Do you understand that when you
leave this hearing room today that you are bound by the
8
5. Date and manner or service or Notice of Intention to Iik Praecipe to
Transmit Record, a eopy or which is i111aehcd. iflhe decree is to be entered under Section 3301(d)
of the Divoree Code:
or, datc of execution of Waiver ofNotiee of Intention to Request Entry of a Divoree Deeree
under Seetion 3301(e) oflhe Divorec Code: by Plilintin: June 21, 2002; by Derendilnt: June 21,
2002.
Date: 6& -,AS -OJ,
and, date of filing ofthc Waiver of Notice of Intention to Request Entry of a Divoree
Decree: Both Waivers were filed on June 24, 2002.
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GEORGE M, THALASSINOS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO, 'JJ' C ~I'/ (it" I j",.,
TINA L. THALASSINOS,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
To the Within Named Defendant:
You have been named as the Defendant in a divorce proceeding filed in the
Court of Common Pleas of Cumberland County, This notice is to advise you that in
accordance with Section 3302(d) of the Divorce Code, you may request that the Court
require you and your spouse to attend marriage counseling prior to a divorce decree
being handed down by the Court. A list of professional marriage counselors is
available at the Office of the Prothonotary, One Courthouse Square, Carlisle,
Pennsylvania, You are advised that this list is kept as a convenience to you and you
are not bound to choose a counselor from this list, All necessary arrangements and
the cost of counseling sessions are to be borne by you and your spouse,
If you desire to pursue counseling, you must make your request for counseling
within twenty (20) days of the date on which you receive this notice, Failure to do
so will constitute a waiver of your right to request counseling,
Prothonotary
.'
GEORGE M. THALASSINOS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO. 'i I' - (, 1 ./ '7 ('(;,<1 7i ,.,
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TINA L. THALASSINOS,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT UNDER SECTION 3301
OF THE DIVORCE CODE
1, Plaintiff is George M, Thalassinos, social security no, 117-60-2613, who
currently resides at 438 Meadow Drive, Camp Hill, Cumberland County, Pennsylvania
17011.
2, Defendant is Tina L. Thalassinos, social security no, 209-54-5681, who
currently resides at 819 Kent Drive, Mechanicsburg, Cumberland County, Pennsylvania
17055,
3, Plaintiff and Defendant have been bona fide residents in the
Commonwealth for at least six months immediately previous to the filing of this
Complaint,
4, Plaintiff and Defendant were married on July 2, 1989, in Camp Hill,
Pennsylvania,
,.
WHEREFORE, the Plaintiff requests the Court to enter a Decree:
a, dissolving the marriage between the Plaintiff and Defendant;
b,
equitably distributing all property owned by the parties hereto; and
c, for such further relief as the Court may determine equitable and just,
JAMES, SMITH, DURKIN & CONNELLY
Date:
11--'1 _,1/ ~
. ~:~C-'_~o C~ Ct>,
By:
John ,COnn~IIY' Jr" Esquir
Att~ey tor P aintiff \,
108-112 Wal ut Street
Harrisburg, PA 17101
(717) 238-4776
PA I.D, No, 15615
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GEORGE M, THALASSINOS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO, 98-6379 CIVIL
TINA L, THALASSINOS.
Defendant
CIVIL ACTION. LAW
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
: ss,
COUNTY OF DAUPHIN
Ij .' I
ANDNOW,this \.lr dayof'1',V.)",1~,,;,( .tL.
. 1998, personally appeared
before me, a Notary Public in and for the State and County aforementioned, John J,
Connelly, Jr., Esquire, who, being duly sworn according to law, deposes and says that
a copy of the Complaint in Divorce was served on the Defendant, Tina L. Thalassinos,
on November 18, 1998 by certified mail number P 397 739 949, addressee only,
return receipt requested, as evidenced by the return receipt card attached hereto and
made a part hereof,
\,
Sworn to and subscribed
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before me this il.' fL-
j. )1998.
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NOTARIAL SEAL
.I!:AN L. KOSIEA. No~~ry Public
ell'; 01 H;tm~bura. DiltJi,il;n Cfl1Jrlt'1
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J~MES SMITH DURKIX & COSSELL\
TEL::I~ 533 3280
P. 0021005
OBORaE M, THALASSINOS,
Plaintiff
: IN TIlE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLV ANlA
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: NO, 98-6379
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TINA L, TIIALASSINOS,
Defendant
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: CIVIL ACTION . LAW
: IN DIVORCE
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PLAINTIFF'S AFFlDA VIr OF CONSENT
.o\NP W A-IVER OF C.OIlNSELING
A Complaint in Divorce under SectIon 3301(c) of the Divorce Code WIl!l filed on
I,
November 10.1998,
2, The mlllriage of the Plaintiff and Defendant is irretrievably broken, and ninety days
have elapsed from the date of both the filing and service of the Complaint.
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3, I consent to the entry of a final decree of divorce after scrvice of Notice of Intention
to request entry of the Decree.
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4, I have been advised of the availability ofmlllTiage counselinll. and understand that I
may request that the CoUlt require that my spouse and I participate in counseling, I flutber
understand that the Court maintains a list of marriage counselors In the Prothonotary's Office,
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which list is available to me upon request, Being so advised, I do not request that the CoUlt require
that my spouse anI! ) participate in cOllllSellng prior to a divorce decree being handed down by the
Court.
I verifY that the statements made in this Affidavit EI1'e bue and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C,S.A, Section 4904, relating to
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uns~m falsification to authorities.
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Georse M, Tha1asslnos. Plaintiff
-
Date' .
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JUS, -21' 021FRI) 10:45
JAllES SlIITH DURKIS & COmLL\
TEL:;17 533 3280
P. 003/005
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OEOROE M. THALASSINOS,
Plaint1ft'
v,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO, 98-6379
: CIVIL ACTION - LAW
: IN DIVORCE
TINA L, lHALASSINOS,
Defendant
WAlWR OF NOTICE 0' IN'rnN'l'JOl\7 TO RF.OUEST ~~~F A orVORCE
I DECREE UNDER 1~]Ol(e\ OF THE OIVO E
1. 1 consent to thc cnlly ora finel Decree of Divorce without notice.
2,
I understand that I may lose rights concerning alimony, division of property,
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lawyer's fees or expenses If I do not claim them before a divorce is granted.
3, I understand that I wilI not be divorced until a Divorce Decree Is entered by the
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Court and t1uIt a copy of the Decree will be sent to me immediately after it is filed with the
Prothonotary,
I verilY that the slIltcments made in this Affidavit are true and correct. I understlllld t1uIt
false ~ements herein arc made subject to the penalties of 18 Pa, C,S.A. Section 4904. relating to
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unswOrn falsification to authorities,
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JUS. -2\' 02lFRIl 10:45
JAMES S~ITH DURKIX & COX~,LLV
TEL 7Ii m 3280
GEORGE M, llIALASSINOS,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO, 98-6379
TINA L, THALASSINOS,
: Defendant
: CIVIL ACTION -LAW
: IN DIVORCE
DF:FENDANT'S AFFIDAVIT OF CONSENT
AND W AJVF.R OF r.OIINSELIN(J
I. A Complaint in Divorce under Section 3301(c) of the Divorce Code WIlS filed on
November 10,1998.
2, The nwriAge of the P111intiff and Defendant is irretrievably broken, and ninety days
have elapsed from the date of both the filing and service oflhe Complaint
3. I consent to the entry of a finaJ decree of divorce after service of Notice oflntcntion
to request enny of the Decree.
4, I have been advised of the availability ofmzuriage counseling. and W1derstand that I
may request that tho Court require that my spouse and I participate in counseling, I further
,
lUIdcdlllnd that the Court maintains II list of marriage counselors in the ProthonollUy's Office.
wbich,llst is available to me upon request. Bcing so advised, I do nol request that tho Court require
that my spouse and I panicipate in coWlSelinll prior to a divorce decree being handed down by the
Court.
I verify that the statements made in this Affidavil arc true and correct I understand that
false statements herein Ilt'C made subject to the penaltie:l of 18 Pa. C,S,A, Section 4904. relating to
unsworn falsification to authorities,
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Tina L. Thalassln9S', Defendant
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Date:
P. 004/005
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IN TilE COUIlT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIl. ACTION - I.AW
NO/f).. (/>17 CIVIL 19
IN DIVORCE
STATUS SHEET
DATE:
ACTIVITIES:
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Mr, Connelly and Mr, Andes, Attorneys at Law
30 October 2000
Paae 2
hearing conference with counsel to discuss the issues and, if necessary,
schedule a hearing,
Very truly yours,
E. Robert Elicker, II
Divorce Master
NOTE:
Sanctions for failure to file pretrial statements are set
forth in subdivision (c) and (d) of Rule 1920.33,
THE ORIGINAL PRETRIAL STATEMENT SHOULD BE
FILED IN THE MASTER'S OFFICE AND A COPY SENT
DIRECTLY TO OPPOSING COUNSEL.
FAILURE TO FILE PRETRIAL STATEMENTS AS DIRECTED
BY THE MASTER MAY RESULT IN THE MASTER's
APPOINTMENT BEING VACATED.
II
I
GEORGE M, THALASSINOS,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
I
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vs.
CIVIL ACTION - LAW
NO. 98-6379 CIVIL TERM
TINA L. THALASSINOS,
Defendant
IN DIVORCE
DEFENDANT'S PRE-TRIAL STATEMENT
Defendant, by her attorney, Samuel L. Andes, files this Pre-Trial Statement in
accordance with Pa. R.C.P. 1920.23(b):
1. ~IS. Attached hereto and marked as Schedule A is a list of the marital
assets as known to the Defendant and, marked as Schedule B, a list of the non-marital
assets as known to Defendant.
2. EXPERT WITNESSES. At the present time, no expert witness has been engaged
by Defendant because she is not certain what expert testimony may be required at the
hearing, If the parties cannot agree on the value of various assets, she identifies the
following experts that she may have to call to testify:
A. A real estate appraiser if the parties cannot agree to sell or
otherwise dispose of the residence.
B. An accountant or other business expert who may have to testify
about the proper value and distribution of the proceeds from the sale of the
Maverick Steak House and the taxes to be imposed upon those proceeds after
distribution,
C. An appraiser of personal property.
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C. Documents relating to the sale of the Maverick Steak House, the
negotiations of the price or considoration involved in that sale, and documents
relating to the calculation of taxes and distribution of the proceeds of sale.
D, Documents relating to the undistributed profit generated by the
Maverick Steak House during the period after the parties' separation up to the
time the business was sold.
E. Various financial documents showing the financial operations and
profits of the Maverick Steak House during the time that Husband was
actively involved in the management and operation of the business and both
prior and subsequent to his involvement.
F. Tax returns and other documents showing the incomes of the
parties both during the marriage and after the separation.
Defendant reserves the right to offer such additional exhibits as may be necessary to
respond to Plaintiff's case in chief.
5. INCOME STATEMENT. Defendant is not currently employed and has no income
other than the modest child support which Plaintiff pays her through the Domestic
Relations Office, Prior to the hearing, she hopes to be employed and will provide an
Income and Expense Statement at that time,
6. EXPENSE STATEMENT, Because Defendant is not employed, she is not able to
properly calculate the expenses that she should be paying for herself and the children and
cannot prepare an accurate expense statement at this time. She will prepare and file an
accurate Income and Expense Statement prior to the hearing.
7, PENSION INFORMATION. To Defendant's knowledge, neither of the parties
Ii owns any interest in or participates in any pension plan or pension system and so there is
"
II no ponsion asset to value.
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!I 8, COUNSEL FEES, Defendant has spent substantial sums of money on counsel
I fees and related expenses since the parties' separation. At the hearing she will provide
I copies of bills and testimony regarding the hourly rate she has paid or is obligated to pay
; for those attorney's fees,
II 9, PERSONAL PROPERTY, Defendant believes the parties have substantially
I divided their personal property and that there is no further action required by the court to
I complete that process. In the event that Plaintiff does not agree and insists on disputing
I the division of personal property, she proposes to have the items appraised and each party
I charged with the reasonable value of the items they have retained.
1 0, MARITAL DEBTS, The marital debts of the parties are listed on Schedule A
and consist primarily of a debt owed to Defendant's father.
11. PROPOSED RESOLUTION OF ECONOMIC ISSUES. Defendant proposes that
she receive the funds which represent the undistributed profits of Maverick Steak House
which were generated after the parties' separation, while she was working at the business,
that the court recognize that the proceeds from the sale of the Andrx stock were applied to
pay marital debts and preserve marital assets, that the house be sold and the proceeds
applied to pay the mortgage and the debt owed to her father, and that the remaining
assets, including the country club membership which should be charged to Husband, be
divided so that she receives 60 percent of those assets and that the Plaintiff receive 40
percent. She also proposes that Plaintiff pay her alimony at the rate of $500.00 per month
for an indefinite term, that he reimburse her $20,000.00 for the attorney's fees she has
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,! insurance on his life with Dofondnnt and tho children as the sole beneficiaries.
II
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Samue L, Andes
Attorney for Defendant 2'\ t'bJ CO
Supreme Court ID 17225
525 North 12th Street
Lemoyne, PA 17043
(717) 761-5361
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SCHEDULE A - MARITAL PROPERTY
1\ DATE OF MARITAL
'I ASSET VALUE V ALUA TION PORTION LIENS
I Residence at 819 Kent $165,000,00 10/2000 100% First mortgage owed
Drive, Mechanicsburg (est'd) to Dovennuhel
Mortgage Co,
1$120,000,001
Escrow account held by $90,000.00' 10/2000 100% None
Husband's attorney
representing proceeds of
sale of former residence in
New York State
Proceeds from sale of $48,400.00 10/2000 100% None
Maverick Steak House, Ine,
(In escrow with James
Morgan, Esquire)'
Individual retirement $2,000.00 6/1998 100% None
aceount held in Husband's
name alone
Proceeds of sale of stock in $13,794.33 8/1998 100% None
Andrx Corporation' (net of
commission)
Household furnishings and Unknown 10/2000 100% None
appliances
'By agreement, the parties have made disbursements from this escrow account. There is
no agreement, however, as to which of the parties should be charged with the disbursements, as
they were made to pay various items that were the responsibility of one or both of the parties, The
present balance in the escrow account is approximately $83.000.00, but the court will have to
decide which of the parties should be charged with prior disbursements.
'An additional sum of approximately $33.000.00 is being held in escrow by Mr, Morgan,
which represents profits generated by the corporation after the date of the parties' separation but
before the sale of the business. Those funds are listed as non-marital property because Wife
contends they were generated by her post-separation efforts while working at the restaurant
business.
'Wife liquidated this stock and applied the proceeds 10 pay marital debts (in the form of six
months of mortgage installments) and 10 reimburse her parenls money loaned to her during the time
that Husband was not supporting the children. As a result, all of the proceeds of the sale of this
stock were appiied to pay marital debls and preserve marital assets for the family.
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I Membership in West Shore
I Country Club
$10,000.00 7/1998
100%
None
MARITAL DEBTS
In addition to the mortgage owed on the residence, Wife identifies the following
marital debts owed by the parties:
.
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1. Personal loan from George Giannaris (Wife's father) in the amount of
$38,000,00 plus interest from May of 1994. These were funds advanced to the parties by
Wife's father in the spring of 1994 to assist them in the purchase of the Kent Drive
residence and at various dates after that time to assist them in paying their living expenses
during periods of time when Husband was not gainfully employed or the parties had other
financial difficulties,
~~
SCHEDULE B - NON.MARITAL PROPERTY
ASSET
VALUE
DATE OF REASON FOR
VALUATION EXCLUSION
AMOUNT
LIENS OF
LIEN
Funds in $33,000,00 10/2000
escrow with
James
Morgan,
Esquire,
representing
undistributed
profits of the
Maverick
Steak House,
Inc,
These funds represent None N/A
earnings of the
corporation generated
by Wife's post-
separation efforts while
employed by and
worki ng at the
corporation's
restaurant business,
GEOHGE H, TIlALASSINOS,
PIa inti If
IN TilE COUHT OF' COMMON PLEAS OF
CUHBEHLAND COUNTY, I'r:NNSYLVANIA
vs.
NU, 9f3 - 6379 CIVIL
TINA L. 'I'IIALASSINUS,
Delendilnt
IN DIVOHCE
'1'0: John J, Connelly, Jr,
Attorney for Plaintiff
Haria p, Cognetti Attorney for Defendant
DATE: Thursday. August 24, 2000
CERTI FI CATI ON
I certify that discovery is complete as to the claims
for which the Haster has been appointed,
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions,
.'
(b) (Jrovidl! dppro.,(lr~ldt.(.. dat.e when discovery wi 11 be
complt'lt' dlld indicdte what dctioll i~ beinq taken
to complete di~icovery.
DATE
COUNSEL FOR PLAINTIFF
COUNSEL FOR DEFENDANT
NOTE:
PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION,
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY,
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT,
cc: Samuel L, Andes, Esquire
S^~t1lJ". L ANJ)Jo:!.;
ATTOIfNY.V AT I.A"'"
:'\:.t:\ SOlfTII TWt':I,...rll .."rUf.t:r
('.0110:'( IHII
1.Y.MOYNI~, PJ~SSN\'I.\'^SI^ 17(1,1:,
TP.'.y.I'lInNr;
'1' 'UI.:o,:U11
27 October 2000
...
'''''7111...a:l:\
E, Robert Elicker, II
Office of the Divorce Master
9 North Hanover Street
Carlisle, PA 17013
RE: Thalassinos
Dear Mr, Elicker:
I have reviewed John Connelly's letter of 6 October 2000 and his suggestion
that you schedule a pre-trial conference in the above case prior to the time we
conclude discovery,
I concur in John's suggestion, I believe discovery in the case will be
somewhat limited and I feel I can rely upon John to cooperate in that process to
get it done prior to any hearing, In fact, the process of preparing and exchanging
pre-trial statements and meeting with you at the pre-trial conference will probably
simplify the discovery process and help John and I, and our two clients, focus on
just what has to be done to get the case concluded,
.\
If you are willing to do so, I request that you set a date for us to file our pre-
trial statements and, when they have been filed, schedule the pre-trial conference,
Sincerely,
&,"
amh
cc: John J, Connelly, Jr., Esquire
GEOHGE M, TIfALASSINOS,
Plaintiff
IN '1'11,: CO[JHT OF' COMMON PLET,S OF
CUMBEHLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
TINA L, TIfALASSINOS,
Defendant
NO, '1'1 - c:n'l CIVIL
III DIVOHCE
RE:SCIfEDULED NOTICE OF PRE-IfEARING CONFERENCE
TO: John J, Connelly, Jr,
, Attorney for Plaintiff
Samuel L, Andes
, Attorney for Defendant
A pre-hearing conference has been scheduled at the
Office of the Divorce Master, 9 North Hanover Street,
Carlisle, Pennsylvania, on the 7th day of March, 2001, at
9:30 p,m" at which time we will review the pre-trial
statements previously filed by counsel, define issues,
identify witnesses, explore the possibility of settlement
and, if necessary, schedule a hearing,
Very truly yours,
Date of Notice: 1/19/01
E, Robert Elicker, II
Divorce Master
GEORGE N, THALASS!NOS
Plaintiff
I:'; THE COURT OF COMMON PLEAS
: COUNTY PENNSYLVANIA
Cumberlana '
y,
NO, 98-6379 CIVIL
TINA L, THALASSINOS
Defendant
CIVIL ACTION - LAW
IN DIVORCE
INVE!\'TORY
n
OF
GEORGE M, THALASSINOS
"
. .
Plaintiff files the following inventory of all property owned or possessed hy eitner pari)' at
the time this action was commeneed and all property transferred within the preceding three (3)
years.
Plaintiff verifies that the statements made in this inventory are true and eorreet. Plaintiff
understands that false statements herein are made subject to the penalties of IS Pa.C,S. Section 4904
relating to unswom falsifieation to authorities.
Date:
II) !t./DO
J7 ~/L-
--l
l\J.\RIT.\I I'IWPERTY
Plaintifflists allmaritalpr(lperty in which either or b(llh spouses have a legal 01' equitable
interest individually or with any person as of thc date thi, :lclion "':IS commcnced.
ITEM NUMBER DESCRlrTIOl'\ NAMES OF ALL
OF PROPERTY OWNERS
1. S Guilford Road George and Tina Thalassinos
Port Washington,l'-'Y
(Escrowed monies from sale)
1. 819 Kent Drive George and Tina Tha1assinos
Mechanicsburg, I'll.
~ 1995 Ford Explorer Tina Thalassinos
2. 1991 Lincoln Continental George Thalassinos
(Traded in by (H) on purchase
of 1994 C1rrvsler Concorde)
3. 400 Shares - ADRX Corp. George and Tina Thalassinos
Slock
(sold by (W) in 1997)
5. Mellon Bank - Checking George and Tina Thalassinos
(Closed approximately one
veal' aGo)
. "
5. Cash George and Tina Thalassinos
(H) left (W) approximately
$5,000 in cash)
....
1\1 ".RTT ".1. PROPERTY ICO!\'TI'.a:EIlJ
Plaintifflists all marital property in which either or both spouses havc a legal or cquitahle
interest individually or wilh any person as of the date this action was commenced.
ITEM NUMBER DESCIUPTlON !'\AMES OF ALL
OF PROPERTY OWNERS
6. Mel10n Bank - Savings I George and Tina Thalassinos
6. Mel10n Bank - Money George and Tina Thalassinos
Market Account
7. Contents of Safe Deposit Box George and Tina Thalassinos
(Approx. 53,000 in savings
bonds, gold chains, jewelry)
II. Gifts - Jewelry, Wedding George and Tina Thalassinos
Gifts, etc...
(Values TBD)
IS. The Maverick Restaurant George and Tina Tha1assinos
1851 Arsenal Blvd (33 1/3% interest)
Harrisburg, P A
Maria Giannaris
(33 1/3% interest)
Paul Giannaris
(33 1/3% interest)
19. Smith Bamey IRA George and Tina Thalassinos
PROPERTY TR.\NSFERREIl
,
I
ITEM ' DESCRIPTION DATE OF CO:\'SIIlERATIO:\' TRM>lSFEREE
NUMBER TRANSFER
I. I Distribution of Multiple N/A Tina Tha1assinos
escrowed monies
from sale of 8
Guilford Rd.
15. Sale of the 12199 TED Unknown
Maverick
restaurant
LI .\/l/r ITlI'S
ITEM !"lIMIlER
IlESC/W'T/O!"
eREll/Tons
I.
----.
.\tol1gagc
Unknown
UEIlTORS
I
I
I
I
I
I
I
I
I
I
I
I
George :md Tina
ThaJassinos
MO!'\TIII ,y
YE.\RLY
(l'iII in appropriatc column)
OTHER '''ICO:\tE
Intercst
Dividends
Pcnsion
Annuity
Soeial Security
Rents
Royalties
Expense ACCOllllls
Gifts
Unemployment Comp.
Worker's Compo
Alimony
Child Support
TOTAL NET INCOME
s
s
EXPENSES
Home
MortgagelRent
Maintenance
$ 550.00
$ 6,600.00
Utilities
Electric
Gas
Oil
Telephone
Water
75.00
900.00
150.00
1,800.00
1
Sewer
"
-
.~
1110'\''/'11I y YE o\RI Y
(FlII ill apprllprintc clllumnl
Employment
PlIblic Transportatillll
LlInch
S 100.00
S 1.200.00
Taxes
Real Estate
Personal Properly
Income
Insurance
Homeowncrs
AlItomobile
Life
Accident
Health
Other
Automobile
Payments
Fuel
Repairs
Medica'
Doctor
Dentist
Orthodontist
Hospital
Medicinc
Speciall\'eeds (glasses,contacts,
braccs, orthopedic devices)
"
37.70
452.40
120.00
1,440.00
1\10'\'1'11I \'
YE.\RI.Y
(Fill in appropriate column)
Education
Private School
Tuition Expenses have been paid for
Christina 0111 of the parties' escrow account.
s
3] .50 (Alexandra) S
378.00
Parochial School
College
Religiolls
Person al
Clothing
Food
Barber/Hairdresser
Credit Payments
Charge Accollnts
Memberships
25.00
300.00
1,200.00
100.00
Loans
Credit Union
Miscellaneous
Household Help
Child Care
Paper/B ooks/M agazines
\'F.'UF'C'\ 1'10:\1
Thc lIndcrsigncd, JOHN .I. CONNELLY, .IR.. ESQUIRE, of the law fiml of .Iamcs, Smith,
Durkin & Connelly LLP, Hershcy, Pcnnsylnmia. hcrcbyccrlifies that the forcgoing Pre-Trial
Statcment has becn preparcd by mc by knowlcdgc and infonnalion ncquircd during the cOllrse of
my rcpresentation of Plaintiff, George M. Thalassinos; that [ execlltc this verification as a signature
of said Plaintiff cannot be obtained in the time pcrmitted for thc filing of this pleading; and that
false statements herein are madc subjcct to thc pcnalties of 18 Pa.C.S.A. S4904 relating to unswom
falsification to allthorities.
/ 1- ~()-O()
Date
S^~lllgl. I. ASIlES
ATTUIINY.Y AT I.A\'t'
:'\:Jr. NOIlTII T"""~U'lll "lI"~I~r
",0 'MIX 'l"t
1.t:MOYNI~, I'KNSSYI,\'ASIA 1704:1
T~I.r.I.ItIlNr:
'71' ."U.I\:1f1l
5 September 2000
'AX
,PI': 1111."':11\
E. Robert Elicker, II
Office of the Divorce Master
9 North Hanover Street
Carlisle, PA 17013
RE: George M, Thalassinos vs, Tina L. Thalassinos
No. 98-6379 Civil Term
Dear Mr. Elicker:
I represent the Defendant in the above matter and I enclose my discovery
certification on her behalf.
I only recently entered in this case and I am not, as yet at least, familiar with
all the assets and claims, As far as I can determine, virtually no formal discovery
has been done and the informal information that has been exchanged is not
complete and does not appear to provide all of the information that I will need to
represent my client, For example, there is a significant dispute in the case about
the value of the parties' interest in a business, The business was sold earlier this
year and the Plaintiff contends that the business is worth more than its sale price,
I am going to have to have some formal discovery to see what information the
Plaintiff has to support that claim,
The Plaintiff is represented by John Connelly and I am quite confident that he
and I will be able to work these matters out. Unfortunately, I do not think we will
be able to do that in much less than sixty days,
I hope this answers your questions regarding the status of discovery,
Sincerely,
~des
amh / Enclosure
cc: John J, Connelly, Jr., Esquire (w.enclosurel
Tina L. Thalassinos
....
(bl Provide approxim,ltf' ddt.. \-Ihen discovery Wl j I be
complete and indlcilt(' ''''flat actiun i~i b(dnq taken
to complete discovery.
Two months or more,
5 Sm QI)
T DATE
FOR PLAI I~
COUNSEL FOR DEFENDANT (X )
Samuel L. Andes, Esquire
NOTE:
PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION,
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOtlE~/ER, IF BOTH COUNSEL, OR p..
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY,
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT,
cc: Samuel L. Andes, Esquire
1:1 TIlE COURT rlF CO/!1lml PLEAS OF
cm.tBERJ..\I1O COUNTY, PE:mSvtVAlIlA
GEORGI'; H. IIlAI.ASS I NOS.
Pl.1tnrHf
'I..
TINA I.. 'l'IlAI.ASSINOS.
:10,
~H - hJ7~ Civil
19
-
IIOTtON FOR APPO INTMEIlT OF MASTER
(Plaintiff) COOtlIiil'Utl'iillQ,
f()llowin~ chims:
Gcorr.e M. ThllJIIHHf.noR
a mastor with respect to the
( ) Divorce
( ) Annulment
( ) Alimony
( ) Alimony Pendente
moves rhe COurt to appoint
Q(X )
( )
( )
( )
Distribution of Property
Support
Counsel Fees
Costs and Expenses
Lite
and in SUpport of the ~otion states:
(1) Discovery is cOlllJllete as to the claims(s) for ,..hich the
appointment of a master is requested.
(2) The defendant (has) ~JljQ't) .ppeared in
(by his attorney, Samuel L. Andes
(3) The staturory ground(s) for divorce (is)
Irretrievable breakdown
(4) Delete the inapplicable paragraph(s):
(a) The action is not contested.
(b) An agreement has been reached with respect to the
the acr.ion ~
,Esquire) 0
)
follOwing claims:
claims:
(c)
Distribution of
(5) The
The action is contested with respect to the fOllowing
Property
action ~) (does not involve) comple", issues of law
or fact.
(5) The hearing is ex~==ted := take
(7) Additional information, if any.
QIlOO\lijQ (days).
motion: None
\'
Date: 'X-/J./-OO
r
"
,Att
(
ORDER APPOINTING :'lASTER __
AND 110101 4(1.. 01/U I? ,'19~. CO /kjcu...-
is appointed mas~r with respect to the follOWing claim.:
(PIaineHr
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GFOIWE M, TIIAI.ASSINOS.
Plaintiff
: IN TilE COURT OF COMMON PI.EAS
: l'l JMIlERI.AND COUNTY. PENNSYJ. VANIA
v,
: NO, 98.6379 CIVIL
TINA L. TIIALASSINOS.
Defendant
: CIVIl. ACI'ION . LAW
: IN DIVORCE
RULE TO SHOW CAUSE
ANDNOW.towit.this 16~daYOf D~c.~tfV\~Ii..( .1998.upon
consideration of thc lorcgoing Pctition of Maria 1', Cognetli, Esqllirc, counsel for
Dclcndant, a Rulc is hcrcby issucd upon Plain tifT to show callsc why thc above-namcd
parties should not undergo thrcc (3) counseling sessions with Belly Weinberger, ACSW,
RULE RETURNABLE dO DA YS FROM SERVICE,
J.
....
(."h...n.....rl"I"III...(j'Ih..I..,,,...,,'C'f"'''''
l,a.,.
GEORGE M, TIIAI .ASSINOS.
Plaintiff
: IN TIlE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY. PENNSYLVANIA
v.
: NO, 98-6379 CIVIL
TINA L. THALASSINOS.
Dcfendant
: CIVIL ACTION - LAW
: IN DIVORCE
ORDER OF COURT
AND NOW, to wit, this _ day of
, 1998, upon
consideration ofDefcndant's Pctition for COllnseling it is hcrcby ORDERED AND
DECREED that the Plaintiff. George M, Thalassinos, and the Defendant, Tina L.
Thalassinos, be required to undergo three (3) counseling sessions with Bctty Weinberger,
ACSW, The aforesaid counseling sessions shall be held within the ninety (90) day period
following the filing of the above-captioned Complaint in Divorce,
BY THE COURT:
.I,
rIM" IIft',,"',"11 "m~"'NI""I"''''''''pot
11:....'.
GEORGE M, TIIALASSINOS,
Plaintilf
: IN TilE COl JRT OF COMMON PLEAS
: Cl JMBERI.ANJ> COUNTY, PENNSYL VANIA
v,
: NO. 1)8.6379 CIVIl.
TINA L. THALASSINOS,
Defendant
: CIVIL ACTION. LA W
: IN DIVORCE
PETITION FOR COUNSELING
AND NOW. comes the Defend.ml, Tina L. Thalassinos. by and throllgh her
attorney, Maria p, Cognelti, Esquire, and respectfully requests as follows:
I. Tina L. Thalassinos is the Defendant in thc above-cited Complaint in
Divorce,
2, Thc aforementioned Complaint in Divorcc was brought pursuant to Scction
3301(c) of the Pcnnsylvania Divorcc Code,
3, Defendant is not ofthe belicfthat the said marriagc is irrctrievably broken,
4, Defendant believcs the usc of cOllnseling may cncouragc and indeed effcct
a reeonciliation of the parties and thcrcby preserve the family unit.
5, Defendant suggests the counseling serviccs of Betty Weinberger, ACSW
and believes she would be the bcst individllal to assist these partics in cOllnseling,
WHEREFORE, Defendant respectfully requests this Honorable Court enter an
Order requiring the parties to lIndergo counscling,
Respectfully Submitted,
Date: December 4, 1998
2............. '.
',' / I '/p1o
. "-I.
i _ ~,~. ..... ,
Gu <., -r: ,.~
Maria p" ognetli ~squire
Superior COllrt I.D, #27914
200 North Third Street
P,O, Box 689
Harrisbllrg, P A 17108-0689
(717) 232-2103
C'-'ht'.\n\W,.\Plf.AJ)JNU.h.I..."...,1'd ..rot
12,.a.YI
VERIFICATION
I, Tina L. Thalassinos, hercby vcrily and statc that the facts sct forth in the
forcgoing documcnt are truc and corrcctto the bcst army information, knowlcdge and
::'
~
belief. I understand that false statements hercin arc made subject to thc pcnalties of 18
:7
/-
1
Pa, C,S,A, ~4904 rclating to unsworn vcrification to authorities,
Tina
DATE: /().. Lj_ tj q
, ~
,,\
,
.i
..
REAGER, ADLER & COGNETTI, PC
ATTORNEYS AND COUNSELORS AT LAW
2331 MARKET STREET
CAMP HILL. PENNSYLVANIA 17011...642
717.763.1383
TELEFAX 717.909...333
WEBSITE ReegorAdlorPC com
THEODORE A, ADLER +
DAVID W, REAGER
MARIA P. COGNElTl ++
LINUS E. FENICLE
DEBRA DENISON CANTOR
THOMAS 0, WILLIAMS
SUSAN H. CONFAIR
JULIE A, McCONAHY
Septembcr 6. 2000
. Certified CIVil Trial Specialist
.. Fellow. Amenc:an Academy
0' Matnmonial Lawyer1
E, Robert Elicker. II, Divorce Master
Cumberland County
9 North Hanover Street
Carlisle, P A 17013
RE: Tina TI/Qlassil/os
Cllmberland COIIl/ty c.c.P. No.: 98-6379
Dear Mr, Elicker:
I am in receipt of your Discovery Certifieation in the above-referenced matter, Please be
advised that I have forwarded it to Tina Thalassinos' new attorney, Samuel Andes, Please note in
your file that Mr, Andes will be taking over Mrs. Thalassinos' representation, It is my understanding
that Mr, Andes has, in fact. filed a Praecipe for Entry of Appearance in this matter,
Thank you for your attention to this matter.
MPC:sml
cc: Samuel Andes, Esquire
}!;:il~~/~
Maria p, Cognettl
"
"
;:~
GEORGE M, THALASSINOS.
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY. PENNSYLVANIA
vs,
CIVIL ACTION - LAW
,
II TINA L. THALASSINOS.
II Defendant
,!
NO. 98-6379 CIVIL TERM
IN DIVORCE
Ii PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance for the Defendant. Tina L. Thalassinos in the above
matter,
Ie?- Sep-k.~_\-,Q--- 2cxn
Date
~J2
Samuel L. Andes
Attorney for Defendant
Supreme Court ID # 17225
525 North 12th Street
Lemoyne. Pa 17043
(717) 761-5361
~,t\ECI~E_,[O_WITHOR,t\W_,t\~~E,t\R,t\NCE
TO THE PROTHONOTARY:
Please withdraw my appearance for the Defendant. Tina L. Thalassinos in the above
matter,
q ( \ ~ \ oD
Date
/i~.
Attorney at Law
Supreme Court 10 #27914
2331 Market Street
Camp Hill. PA 17011
(717) 763-1383
I
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Novcmhcr 21, 2000
UPS OVERNIGHT MAIL
E, Robert Elicker, Ill, Esqllire
ClImberland County Divorce Master
9 North Hanover Strcct
Carlisle, P A 17013
~
Re: Gcorge M, Tha'assinos v. Tina L. Thalassinos
No. 98 - 6379 Civil Tcrm
Dear Mr, Elicker:
Juhn J. ('unnclly, Jr.
JjcjrCl..,jsdlcgal.com
Enclosed pi case find the Plaintifrs Inventory and Appraisemenl and Income
and Expensc Statement pllrsllant to YOllr dircctive.
Very truly yours, ,
l,s}(lcLWU(j I~
I) John ~ Connclly. Jr~.fJI '
,
"
;~
.
JJC:jlk
".!
;..(
''1.
cc: Samllel L. Andes, Esquire
Enclosllres
aUSINESS&
COMMERCIAL LAW
CIVIL LItIGATION
CREOITORS' RIOHTS
EOUCATION LAW
EMPLO'l'MENT LAW
ESTATE PLANNlrlO
FAMILY LAW
INSURANce LAW
LAND USE
MUNICIPAL LAW
REAL ESTAte
TRUST & ESTATE
ADMINISTRATION
\
"
GEORGt: M. TIIALASS I NOS
Plaintiff
IN TilE COURT OF eOMMON PLEAS
: C b I rOUNTY,l'ENNSYLVANIA
urn l'r nlicT
v.
NO. 98-6379 CIVll.
TINA I.. TIIALASSINOS
De(endlnt
e'V'L ACT'ON . LAW
IN mVORCE
INVENTORY
OF
GEORGE M. TIIALASSINOS
Plaintiff files the following invcntory 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 verifies that the statcments made in this inventory are true and correct. Plaintiff
understands that false statemcnts herein are made sllbject to the penaltics of 18 Pa,C,S, Section 4904
relating to unsworn falsification to authorities.
Date:
u) ,do 0
f ---M---
MARITAL PROPERTY
Plainti IT lislS alllllarital property in which eithcr or both spollses havc a legal or e1luilable
interest individually or with auy pcrson as of the dale this :Iction was commcnced.
ITEM NUMBER DESCRIPTION NAMES OF ALL
OF PROPERTY OWNERS
l. 8 Guilford Road Georgc and Tina Thalassinos
Port Washinglon, NY
(Escrowed monies from salc)
I. 819 Kent Drive Georgc and Tina Thalassinos
Mechanicsburg, P A
2. 1995 Ford Explorcr Tina Thalassinos
2. 1991 Lincoln Continental Gcorge Thalassinos
(Traded in by (H) on Pllrchasc
of 1994 Chrysler Concordc)
3, 400 Shares - ADRX Corp. George and Tina Thalassinos
Stock
(sold by (W) in 1997)
5. Mellon Bank - Chccking George and Tina Thalassinos
(Closed approximately onc
year ago)
5. Cash George and Tina Thalassinos
(H) left (W) approximately
$5,000 in cash)
l\!ARITAL "'WI'ERTY rCONT'NIJEUl
I
,
I
I
'I
i'laintifflisls all m:lrilill property in which eilher or bolh spouscs have a legal or cquitable
interesl individually or wilh any pcrson as or lhe dale this action was commenced,
'TEl\! NIJI\IIlER DESCR'PTlON NAMES OF ALL
OFI'ROPERTY OWNERS
6. Mellon Bank - Savings Gcorgc and Tina Thalassinos
6. Mellon Bank - Moncy Gcorge and Tina Thalassinos
Market Accollnt
---
7. Contcnls or Safe Deposit Box George and Tina Thalassinos
(Approx. 53,000 in savings
bonds, gold chains, jewelry)
II. Gifts - Jewelry, Wedding Gcorge and Tina Thalassinos
Gifts, etc...
(Values TBD)
15. The Maverick Restaurant Gcorge and Tina Thalassinos
1851 Arsenal Blvd (33 1/3% interest)
Harrisbllrg, P A
Maria Giannaris
(33 1/3% intcrest)
Pall I Giannaris
(33 1/3% interest)
19. Smith Bamey IRA George and Tina Thalassinos
"ROI'ERT\' TRANSFERREU
_n -.-- -...--.---....-.... --_.----~._---
/TEl\! DESCR'PTlON HATE OF ('O:oiSIIIERATlO:ll TRANSFEREE
NUMBER TRANSFER
l. Distriblltioll of MlIltiple N/A Tina Thalassinos
escrowed monies
from sale 0 f 8
Guilford Rd.
15. Sale of the 12/99 TBD Unknown
Mavcrick
reslallranl
UABIJ.IT'ES
ITEM NUJ\IIIER
'>ESCRII'T10N
CREDITORS
DEBTORS
I.
Mortgage
Unknown
George and Tina
Thalassinos
GEORGE M. TIIALASSINOS
Plailllilr
: IN TilE COlJRTOF COMMON PLEAS
: ClJMBERLAND COlJNTY. PENNSYL VANIA
NO. IJS (,J7')('fVII.
TINA L. TIIALASSINOS,
Dcfcndant
CIVIL ACTION LAW
IN DIVORCE
'NCOI\IE AN/) EX"ENSE STATEMENT OF:
GEORGE 1\1. TIIALASS'NOS
INCOME
Employcr:
Address:
Commcrcial Re:llly Group, Inc.
1300 Markct Street, Lcmoyne. P A 17043
Type of Work: Commercial Real Estate Sales/Lcasing
Pay Period (weekly. biweekly, elc,): N/A
Gross Pay per Pay Pcriod: N/ A
Itemized Payroll Dcductions: N/ A
Federal Withholding
Social Security
Local Wagc Tax
State 'ncome Tax
Retirement
Savings Bonds
Credit Union
Life Insllrance
Hcallh Insllrance
Uncmployment Tax
Othcr
Net Pay per Pay Period:
r
l,,:,
I'.,
't
Fi~
VIi
Gross income ycar-to-date from commissions received $10,953.76.
To date, 110 taxes or business deductions have been deducted from
this amOllnl.
i
I
,
i
:\IONTIII.\' YE^'U.\'
(1'11I In npproprlllte column)
OTHER INCOME
Interest
Dividends
Pension
Annllity
Social Security
Rents
Royallies
Expense Accounts
Gifts
Unemploymcnt Compo
Worker's Camp,
Alimony
Child SlIpport
TOTAL NET INCOME
75.00
900.00
$
$
EXPENSES
Home
Mortgage/Rent
Maintenance
Utilities
Electric
Gas
Oil
Telephone
Watcr
Sewcr
S 550.00
$ 6,600.00
150.00
1,800.00
:\IONTIIJ.\'
YEARLY
(Fill In llJlproprlate column)
Education
Privatc School
Tuilion Expcnscs have been paid for
Christina olltofthe parties' escrow accollnt.
$
31.50 (Alexandra)
$
378.00
Parochial School
College
Rcligiolls
Personal
Clothing
Food
Barber/Hairdresser
Credit Payments
Charge Accollnts
Memberships
25.00
100.00
300,00
1,200.00
Loans
Credit Union
Miscellaneous
HOllsehold Help
Child Care
Paper/Books/Magazines
GEORGE N. 'rIlALASSINOS,
PIa inti ff
IN TilE couln OF COMMON I'I,EAS OF
CUtlllEHI.AIlD COUNTY, I'ENNSYINANIA
vs.
NO, 98 - 6319 CIVIL
TINA L, TIIALASS I NOS,
Defendant
IN DIVOHCE
ORDER OF COURT
AND NO~l,
,;s Ill.'
C)uJ
ln to an
this
day of
2002, the parties and counsel having entered
agreement and stipulation resolving the economic issues on
June 21. 2002. the date set for a four-party conference. the
agreement and stipulation having been transcribed. 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,
BY THE COURT.
Geo
cc: John J, Connelly, Jr.
Attorney for Plaintiff
Samuel L, Andes
Attorney for Defendant
TO ______
"ou "It I Hlltl" "'0"'11('1 TO "LI"O '0
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AIlAINS' 'OU
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JAMES, SMITH. DURKIN & CONNELI.Y. LU'
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A 'ltUI AND COltltlCT COPY 0' THI
OltlGINAL 'IUD IN ,".. ACTION
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GEORGE M. TIIAI.ASSINOS
Plaintiff
: IN TIlE COURT OF COMMON ('LEAS
: CUMBERLAND COUNTY, PENNSYI. VANIA
NO, 98 - 6379 CIVIL
TINA I., TI/ALASS(NOS,
Defendant
CIVIL ACTION - LA W
IN DIVORCE
I'RA"CII'" TO WITIIDRA W CLA'M
TO THE PROTHONOTARY:
Please withdraw the claim for Equitable Distribution in the above-captioned divorce
action,
JAMES, SMITH, DURKIN & CONNELLY LLP
Date: OIP -.!J,8 -Lid-,
I N Till'; COlI/I'/' OF COMMON I'I.I':^!; OF CUMIIIWI.^NIl COUNTY. I'J-:NN:;YI.V^N I ^
('IVI J. M:TION I.^W
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IN DIVOIlC~;
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Ilefendant:
NOTICE TO IlE~_ll.fol.l;:__PIl.!OIl_SURN^ME
prior
this
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sl/gn~~re
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SignaLu . of (~~me heing resumed
COMMONWEM,TII OF PENNSYLV^NI^:
SS.
COUNTY OF CUMIlf:IlL^NIl
Notary ~::h :;';;. l)fi~\I~Yil~:)Ca;-c~Yd~i;i);;vc' ,,~f~' k~~~~r~o m~~ ~o
ue the persoll whose nallle jf; suh:;t:r-ibcd to the within document clnd
acknowledged that he/she executed I he foregoing for the pUl"pOSC
thor-cin contained.
scal.
In W i lll(~!;~i 'Whcr~eo[.
official
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hilve ll(lr"eunLo !i(~t lilY hand and
C1r . Si.,rAP1 .l:l!E/t
ClAU i?HIfEYiBAKiW lldi'ARY PUBLIC
Carlisle BorG., Cumb.dand County
My COf'1missron Expir~~ April 4. 2005
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