HomeMy WebLinkAbout00-06024
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
RICHARD P. LONG
No.
00-6024
VERSUS
BARBARA A. LONG
DECREE IN
DIVORCE
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T."''''T.T.T.T.T.T.T.T.T.T.T.T.;f.T.T.~
AND NOW,
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,U.J. IT IS ORDERED AND
DECREED THAT
RICHARD P.
LONG
AND
BARBARA A. LONG
ARE DIVORCED FROM THE BONDS OF MATRtMONY.
, PLAI NTt FF,
, DEFENDANT,
THE COURT RETAINS JURISDICTtON OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAtSED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
JJ'Al6
ATTEST:
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PROTHONOTARY
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NUUUTALSETTLEMENTAGREEMENT
TillS AGREEMENT, made this /t17 day of h/tkJv.tol,l. 2003, by and
between RICHARD P. LONG (hereinafter called "Husband") and BARBARA A.
LONG (hereinafter called "Wife").
WITNESSETH:
WHEREAS, Husband and Wife were married on August 18, 1972, in New
Cumberland, Cumberland County, Peunsylv:l!llia.
WHEREAS, there were Two (2) children born of this marriage, both over the age
of Eighteen (18) years old.
WHEREAS, the parties hereto desire to fix and determine by this Marriage
Settlement Agreement the rights and claims they have accrued to each of them in the
estate and real and personal property of the other by reason of the marriage, and all
economic rights of every kind and description arising from the marital relationship.
NOW THEREFORE, in consideration of the promises and of the marriage, and
in further consideration of the mutual promises and undertakings hereinafter set forth,
each intending to be legally bound hereby, the parties agree as follows:
1. DIVORCE The parties hereto are aware that this Divorce Decree will be
entered under the provisions of the No Fault Code regarding separation of more than two
(2) years. Husband acknowledges that he has committed adultery during the marriage.
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2. SEPARATION It shall be lawful for each party at all times hereafter to live
separate and apart from the other party at such place as he or she may from time to time
choose or deem fit.
3. INTERFERENCE Each party shall be free from interference, authority, and
contact by the other, as fully as he or she were single and unmarried except as may be
necessary to carry out the provisions of this Agreement.
4. WIFE'S DEBTS Wife represents and warrants to Husband that as of the date
of separation she has not incurred, and in the future will not contract or incur, any debts,
liability for which Husband or his estate may be responsible and shall indemnify and save
harmless Husband from any and all claims or demands made against him by reason of
debts or obligations incurred by her. Any and all loans and/or debts and charge accounts
currently in Wife's name alone shall be Wife's sole and separate responsibility for
payment. Wife agrees to indemnify and save harmless the Husband from any loss he
may sustain, including attorneys fees, as a result of any default in paymenfOy Wife.
5. HUSBAND'S DEBTS Husband represents and warrants to Wife that as of the
date of separation he has not incurred, and in the future will not contract or incur, any
debt or liability for which the Wife or her estate might be responsible and shall indemnify
and save harmless Wife from any and all claims or demands made against her by any
reason of debts or obligations incurred by him, Any and all loans and/or debts and
charge accounts presently in Husband's name alone shall be Husband's sole and separate
responsibility for payment. Husband agrees to indemnify and save harmless Wife from
any loss she may sustain, including attorneys fees, as a result of any default payment by
Husband.
6. DIVISION OF PERSONAL PROPERTY The parties have divided between
them, to their mutual satisfaction, their personal effects, bank accounts,
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household furniture and furnishings, and all other articles of personal property which
have been heretofore been used by them in common.
7, ALIMONY Husband agrees to pay alimony through the date of his retirement
from the Commonwealth of Pennsylvania to the date he begins to receive monthly
retirement payments. Currently, Husband agrees to pay $570.00 per month in alimony,
which will be effective July I, 2003, through July I, 2004. Thereafter, the alimony will
be re-evaluated by the Domestic Relatious Office on a yearly basis.
8. EOUlTABLE DISTRIBUTION OF MARITAL PROPERTY
A. Husband agrees to pay wife one-half (1/2) of the marital value of his
pension defined as of March 30, 2002.. Attached hereto and marked
Exhibit A is a statement from the State Employee's Retirement System
certifYing the present value of the pension as of that date of Four Hundred
Twenty Two Thousand Dollars, Seven Hundred Eighty Three vollars and
Sixty Eight Cents ($422,783.68), Both parties agree that this value is
reasonable and this is the amount upon which wife will receive one half
upon the retirement of the husband. It is understood that this amount may
continue to grow based upon investments of the State Employee
Retirement System,
B, Wife agrees to waive any claim that she may have to husband's deferred
compensation through the Copland Group as part of an employee benefit
of employment with the Commonwealth of Pennsylvania.
C. Husband waives any claim that he may have for his wife's pension
through Giant Foods,
D. Husband agrees that he is responsible for his own attorney's fees,
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E. Wife agrees to waive any claim for attorney's fees.
F. Wife agrees to waive or not claim any health insurance coverage under
husband's coverage.
I 8. GENERAL RELEASE
Other than the terms of this agreement, it is hereby specifically agreed that Husband and
Wife shall forever relinquish to the other his or her right, title, and interest in said pension
plans and/or retirement plans and/or employee stock or savings plans, as well as all other
employee benefits of the other. The parties agree to execute any and all documentation
necessary to effectuate the terms herein contained.
9. BREA<;;H If either party breaches any proyision of this Agreement, the other
party shall have the right, at his or her election, to sue for damages of such breach,
including legal fees and expenses, or seek such remedies or relief as may be available to
him or her respectively.
10. ADDITIONAL INSTRUMENTS Each of the parties shall from time to
time, at the request of the other execute, acknowledge, and deliver to the other party and
all further instruments that may be reasonably required to give full force and effect to this
Agreement.
11. WAIVER OF CLAIMS AGAINST ESTATE Except 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 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, dower, curtsy,
statutory allowance, widow's allowance, right to take property against the Will of the
other, and the right to act as administrator or executor of the other's estate, and each will,
at the request of the other, execute, acknowledge, and deliver any instruments which may
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be necessary or advisable to carry into effect this mutual waiver and relinquishment of all
such interest, rights, and claims.
12. INCORPORATION OF AGREEMENT FOR ENFORCEMENT This
Agreement shall bind the parties hereto and their respective heirs, executors,
administrators legal representatives and assigns. This Agreement shall survive a Decree
of Divorce between the parties in any jurisdiction and any other Order which may be
entered in accordance with this Agreement. In the event that a Decree in Divorce is
entered in the Court of Common Pleas of Dauphin County, Pennsylvania, or in the event
that a Decree in Divorce is entered in any other jurisdiction, the parties agree to
incorporate this Agreement into the Divorce Decree for purposes of enforcement.
13. ENTIRE AGREEMENT This Agreem~t contains the entire understanding
of the parties, and there are no representatives, warranties, covenants, or undertakings
other than those expressly set forth herein.
14. MODIFICATION AND WAIVER A modification or waiver of any of the
provisions of this Agreement shall be effective only if made in writing and executed with
the same formality as this Agreement. The failure of either party to insist on strict
performance of any of the provisions of this Agreement shall not be construed as a
waiver of any subsequent default of the same or similar nature,
15. VOLUNTARY EXECUTION Each party acknowledges that the
Agreement is fair and equitable, that full disclosure has been made by each respective
party to the other, that it is being entered into voluntarily, and that it is not the result of any duress or undue influence, Wife and Husband acknowledges that they have been
furnished with all the information relating to the financial affairs of the other, which has
been requested by them respectively.
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16. DESCRIPTIVE HEADINGS The descriptive headings used herein are for
convenience only. They shall have no affect whatsoever in determining the rights or
obligations of the parties.
IN WITNESS WHEREOF, the parties hereunto set their hand and seals the day
and year first above written.
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ACKNOWLEDGEMENT
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
ON THIS, the /~ day of .71'~~~ ,.'\2003, before me, a Notary
Public, the undersigned officer, personally app are . ~HARD P. LONG, known to me
(or satisfactorily proven) to be the person whose name is subscribed to the within
instrument, and acknowledges that she executed the same for the purposes therein
contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal,
.
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PUBLIC
N'OT~SBAL
J~ M. Vfflsmi,'~PubUc
CltJo(llarIlsb\ll9.~OIImty
M'y Commlsslo1\ bp!1IIlqIt25, 2005
SS:
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ONTIDS,the Iff} day of ).,.hlll/',.f ,2003,beforeme,aNotary
Public, the undersigned officer, personally ~ARA A. LONG, known to
me (or satisfactorily proven) to be the person whose name is subscribed to the within
instrument, and acknowledges that she executed the same for the purposes therein
contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
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Y PUBLIC
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c:lly or!\atrl'burg,llaIIp!dIICounty
CDmmissio" F~ Apt. 25,2005
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STATE EMPLOYEES' RETIREMENT SYSTEM
30 NORTH THIRD STREET. P.O, BOX 1147
HARRISBURG, PENNSYLVANIA 17108.1147
TOLLFREE: 1-800-833.5461
717.783.9065
www.sers.state.pa.u.s
October 29, 2002
RICHARD P LONG
PERSONAL AND CONFIDENTIAL
3029 LOCUST STREET
HARRISBURG PA 17109
'SSN: 202-42.7423
Dear Mr. Long:
Responding to your inquiry regarding the value of your retirement account, with the State Employees'
Retirement System. I provide you with the following summary of member contributions and interest:
Value of Account as of 03/30/2002:
Total Contributions and Interest $ 55.809.53
Present Value . $ 422,783,68
Final Averaae Salarv $ 59,106.25
Maximum Single Life Annuity $1973.78
Years of Credited Service . 26.2818 vrs
.Value of Account as of 01/13/2011 fSuDerannuationl:
Total Contributions and Interest $107.321,09
Present Value'",' $ 815 217.19
Final AVeraeSala $ 60,866. 6
Maximum'Sin'le Life Annui $ 4,436.36
Years of Credited Service 35.0091 S
'EsUma/e based on eUITeIl/ anllual salary. Over/ime and raises cannot be projected Into /his
'of", uest.
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iiikeino'flfiTiiher.':?pfeaselto'not direct ouestions reaaroina these enclosures to me:1f1 am i16faff8WiTtev:'f:'.
I trust this information is sufficient for you: needs. It is your responsibility to promptly provide all of this
information to your attorney.
Sincerely,
~~
Jane Kuklish -----
Regional Manager
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Enclosures: divinf.mem; sample ORa;
SERS-157 (2 copies for member & attorney)
cc: SERS Region active files
Scanned: Member history (DRO correspondence)
Hsit S'E'R,S' <vc6site at 'cvcvw.sers.statc.pa.us
EXHIBIT A
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RICHARD P. LONG,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
BARBARA A. LONG,
Defendant
NO. 00-6024
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary;
Transmit the record, together with the following information, to the Court for entry of a
Divorce Decree:
1. Ground for divorce: Irretrievable breakdown under Section () 3301 (c) (X) 3301
(d) of the Divorce Code.
2. Date and manner of service of the Complaint: September 6. 2000. Certified MaiL Return
Receipt Reousted. 7099 3400 0003 11567834.
3. Complete either Paragraph (a) or (b).
(a) Date of execution of the Affidavit of Consent required by Section 3301 (c)
of the Divorce Code: by Plaintiff ; by Defendant
(b) (I) Date of execution of the Plaintiff's Affidavit required by Section 3301 (d) of the
Divorce Code: Februarv I. 2000;
(2) Date of service of the Plaintiff's Affidavit upon the Defendant: February 7.
2001.
4. Related claims pending: Marriage Settlement Agreement dated September 16, 2003.
5. Date and manner of service of the Notice of Intention Request Entry of a 3301 (d) Divorce
Decree, a copy of which is attached and marked Exhibit A: 09/29/03 First Class MaiL
Date: II / I J JIJ
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Joseph J. Dixon, Esquire
Attorney for (X) Plaintiff
Attorney for ( ) Defendant
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RICHARD P. LONG, ,
Plaintiff
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
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v.
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NO. 00-6024
,
BARBARAA.LONG,
Defendant.
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CIVIL ACTION-LAW
IN DIVORCE '.
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,', TO: BARBARA LONGe , ::::~i N 0fn"
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, ' You have been sued in an action for Divorce, You have failed to answer the Cbmplaint -< '
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orfile a COUnter-Affldav.\t/Thei:efore,gnorafter October 20, 2003, theotlierparty can request
.,', the CoUrt to enter it final decree ill Divorc-e~ '. '
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NOTICE Qli'!l'I!~~q~i()R,E:9YES'f~~Y ,
, '. OF~ 3301(d)l>IVORCE DECREE-
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,..'. .'. . Ify6udonotfileY4~~~~rgtl1o.~()~ofthe9purtaIlAnsW~withr~ursignature . '
, " '..'notarizedorverifi~Qta.C()11,!it~~~!iliVitb,yil1ea1:JQv~4ate>'thl;}C1l!lican.entera final decree,
, ':~~~J~b\&..~b~f~Affi<lli\1ffrhi(lhyi,g~Wfi1e\vith theProthonot;kyofthe Court is '
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Unless you ha.vealniadyf'iled With the c:ourt~written dalmfor <:conomic relief, you
must do so by the above date or the C:<>1l1t maygranfthe Divorce and you Will lose foreverthe
right to ask~ot economic relief. The filing ()fthe forin. Counter"Affidavitalone does not protect
,your' economic claiIns. '
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youim6uLD TAJCEcTlIIS PAPER TOYOURLAWYERATONCE. IF.YOU
DO NOT HAvE A LA WYER oR: CANNOT AFFORD ,ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH ":BELOW-H> FIND OUT WHEREY()U CAN GET LEGAL"
HELP.
'9()~t;@.~m'fQR7i.."',..".
CUMBERLA:W'~()UW'Y.C()URl'HOUSE
lCOuRiHOUSEfiQU~~OURiHFLOOR
','. CARLISLE,PA17"013~3387'
(717) 240-6200 '
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RICHARD P. LONG"
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-6024
:
BARBARA A. LONG,
Defendant
:
. CIVIL ACTION-LAW
IN DIVORCE
COUNTERA1<'FIDAVITUNDER~3301 (d)
',OF THE DIVORCE CODE
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CheckCither(a) or'(b):
, D (a) Ido not oppose the entry ofa Divorce Decree.
D (b) Iopposethe eIltryof a Divorce Decree because (Check (i), (ii) or both);
D (i)The partieS to this action have not lived separate
lind apart for a period of at least two years.
D (ii) The marriage is not irretrievabllbroken.
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2. Ch~cl\:eithl#Ja)or(b);. '.,' . ','
D (it) I <1o:p,c{~s:h tq.IIl*~lIl1ygll!il11sfor~conomic relief.. "I understand '
. ,....~1r~~1~ilt"l~~6i~~\i;~~t~~r:;v~;fi~t~f:ters
D(b)Iv,.f,~:~.claiID toecoll()micreliefwhichmay include aliniony, division,
of property, lawyer's fees or expenses or other important rights.
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I understaI1d tb.at in addition to checking (b) above, I must also file all
economic e1~ Withth~ Prothontary in writing lind serve th= on the other party.
.IfI fai(t9.c:IQ~6liefor!?i:he~tesetforth.onthe Notice of Intention to Request'
DivoJ:c~Pecre~;'tl:te'!)i~6iM])eCreem~y beenteredwithout further notice to me,
and I shall he 'iliiilblelh:;;{:eat'tet to file InY economic claims. " .
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. . I verify that thestaterrientslIladein this Counter Affidavit are true and
correcUuitdei$I1<ithat false statcin.ents herem are made subject to the penalties of
18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities,
Date:
(DEFENDANT)
NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE
DECREE AND DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC
RELIEF, YOU SHOULD NOT FILE THIS COUNTER AFFIDAVIT.
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RICHARD P. LONG : IN THE COURT OF COMMON PLEAS
Plaintiff . CUMBERLAND to., PENNSYLVANIA
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v. NO. 00 - ~~1
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BARBARA A. LONG :
Defendant : CIVIL ACTION - IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against
the claims set forth in the following pages, you must take prompt
action. You are warned that if you fail to do so, the case may
proceed without you and a Decree in Divorce or annulment may be
entered against you by the Court. A judgment may also be entered
against you for any other claim or relief requested in these papers
by the Plaintiff. You may lose money or property or other rights
important to you, including custody or visitation of your children.
When the ground for the divorce
irretrievable breakdown of the marriage,. you
counseling.
is indigni ties or
may request marriage
'.
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.
Court Administrator
Cumberland County Court House
1 Courthouse SqUare - Fourth Floor
Carlisler PA 17013-3387
(717) 240-6200
Joseph J. Dixonr Esquire
Attorney for Plaintiff
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.
9. The Plaintiff has been advised of her right to seek marriage counseling in this
divorce action, but waives the right to do so.
10. The Plaintiff and Defendant are not members of the Armed Forces of the United
States or any of its allies.
11, The Plaintiff avers that the marriage is irretrievably broken and he and his wife
have been separate and apart for more than Two (2) years.
WHEREFORE, The Plaintiff prays this Honorable Court enter a Decree in Divorce in
accordance with Section 3301(d)ofthe Divorce Code.
Respectfully submitted,
BY~ ~
Joseph 1. Dixon, Esquire
Attorney ill No, 28290
126 State Street
Harrisburg, PA 17101
Attorney for Plaintiff
Dated: August 30, 2000
, , ,- " - -'. ~'
,
L
VERIFICATION
I verify that the statements made in this DIVORCE COMPLAINT
are true and correct. I understand that false
statements herein are made subject to the penalty of 18 Pa. C.S.
S4904, relating to unsworn falsification to authorities.
DATED: 8/30/00
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RICHARD P. LONG,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-6024
BARBARA A. LONG,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
AFFIDAVIT OF SERVICE
Personally appeared before me, a Notary Public, in and for the aforesaid Commonwealth
and County, JOSEPH J, DIXON, ESQUIRE, who first being duly sworn according to law, does
depose and say that he made service of the Notice ofIntent to Request Divorce Decree and
Counter-Affidavit under 3301 (d) of the Divorce code upon the Defendant by placing a true and
correct certified copy with a Notice to Defend and Claim Rights in the United States Mail at
Harrisburg, Pennsylvania,
Certified Number: 7099 3400 0003 11574559
The same was received and acknowledged by the Defendant, Barbara A. Long, on the 2nd
day of October 2,2003, as the addressee.
Receipt for mailing is attached heretod~
I J eph J. Dixon, Esquire
Attorney for the Plaintiff
Sworn to and subscribed
before me this the tJ/II day
of /lhV~W-:Z003,
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RICHARD P. LONG,
Plaintiff
IN THE COURT OF COMMON PLEAS'
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-6024
BARBARA A. LONG,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
NOTICE OF INTENTION TO REQUEST ENTRY
OF ~ 3301(d) DIVORCE DECREE
TO: BARBARA LONG
You have been sued in an action for Divorce, You have failed to answer the Complaint
or file a Counter-Affidavit. Therefore, on or after March 18, 2001, the other party can request
the Court to enter a fmal decree in Divorce.
If you do not file with the Prothonotary of the Court an Answer with your signature
notarized or verified or a Counter-Affidavit by the above date, the Court can enter a final decree
in Divorce. A Counter-Affidavit which you may file with the Prothonotary of the Court is
attached to this notice.
Vnless you have already filed with the Court a written claim for economic relief, you
must do so by the above date or the Court may grant the Divorce and you will lose forever the
right to ask for economic relief. The filing of the form Counter-Mfidavit alone does not protect
your economic claims,
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.
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
1 COURTHOUSE SQUARE-FOURTH FLOOR
CARLISLE, P A 17013-3387
(717) 240-6200
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RICHARD P. LONG,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO.OO-6024
BARBARA A. LONG,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
COUNTER-AFFIDAVIT UNDER ~ 3301(d)
OF THE DIVORCE CODE
1. Check either (a) or (b):
D (a) I do not oppose the entry of a Divorce Decree.
D (b) I oppose the entry of a Divorce Decree because (Check (i), (ii) or both):
D (i) The parties to this action have not lived separate and apart for a period of at
least two years,
D (ii) The marriage is not irretrievably broken.
2. Check either (a) or (b):
D (a) I do not wish to make any claims for economic relief. I understand that I may lose
rights concerning alimony, division of property, lawyer's fees or expenses if! do not
claim them before a Divorce is granted.
D (b) I wish to claim economic relief which may include alimony, division of property,
lawyer's fees or expenses or other important rights.
I understand that in addition to checking (b) above, I must also file all my economic
claims with the Prothonotary in writing and serve them on the other party. If! fail to do so
before the date set forth on the Notice of Intention to Request Divorce Decree, the Divorce
Decree may be entered without further notice to me, and I shall be unable thereafter to file any
economic claims,
I verify that the statements made in this Counter-Affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904
relating to unsworn falsification to authorities.
Date:
(DEFENDANT)
NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE
DECREE AND DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF,
YOU SHOULD NOT FILE TIllS COUNTER-AFFIDAVIT.
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RICHARD P. LONG,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-6024
BARBARA A. LONG,
Defendant
CNIL ACTION-LAW
IN DNORCE
NOTICE TO DEFENDANT
If you wish to deny any of the statements in this Affidavit, you must fIle a Counter-
Affidavit within Twenty (20) days after the Affidavit has been served on you or the statement
will be admitted, and this Divorce action may proceed without further notice to you.
PLAINTIFF'S AFFIDAVIT UNDER SECTION 330l(d) OF THE DIVORCE CODE
1. The parties to this action separated on August 19, 1998, and have continued to
live separate and apart for a period of at least Two (2) years.
2. The marriage is irretrievably broken.
3. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if! do not claim them before a Divorce is granted.
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.g4904, relating to unsworn
falsification to authorities.
.w?
P aintiff
Date:~ -1- ,;200 I
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RICHARD P. LONG,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-6024
BARBARA A. LONG,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
AFFIDAVIT OF SERVICE
Personally appeared before me, a Notary Public, in and for the aforesaid Commonwealth and
County, JOSEPH 1. DIXON, ESQUIRE, who fIrst being duly sworn according to the law, does
depose and say that he made service of the Plaintiffs MfIdavit under Section 3301(d) of the
Divorce Code upon the Defendant by placing a true and correct copy with the Notice to Defendant
in the United States mail at Harrisburg, Pennsylvania.
CertifIed Number: 709934000003 11574214
The same was received and acknowledged on behalf of the Defendant, Barbara A. Long, on
this the 7"' day of February 7, 2001, as the addressee.
Receipt for mailing is attached hereto.
/
SWORN TO AND SUBSCRIBED BEFORE ME
~ .
THI&>J DAY OF 1'itJ,....."', , , 200l.
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NOTARY PUBLIC
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ATTORNEY AT LAW
126 STATE STREET. HARRISBURG, PA 17101
PHONE: (717) 233-8757 . FAX: (717) 233-5860
EMAIL: dixonlaw@paonline.com
www.dixonJaw.baweb.com
March 26, 200 I
BARBARA LONG
335 9lH STREET
NEW CUMBERLAND. PA 17070
VIA CERTIFIED AND FIRST CLASS MAIL
Dear Mrs. Long:
I have received your Affidavit requesting marriage counseling concerning the Divorce
filed by your Husband, Richard Long. Under PeDnsylvania Law, you can request marriage
counseling and my client is complying with that Jaw. He has arranged through his work and
insurance company for marriage counseling to be held at pennsylvania Counseling Services.
These counselors are located at 4918 Locust Lane. Roy Smith, a Counselor at Pennsylvania
COlffiseling Services has scheduled your meeting with him for mandatory malTiage counseling
for April 9, 2001 at 1:00 p.m.. I would point out to you that your husband is making
arrangements for payment of this visit.
Since you asked for marriage counseling, this is your opportunity and I would request
that you attend the session, If you do not attend the session, it is obvious that you are just nying
to obstruct the divorce. Thank you for your attention to this matter.
Very truly yours,
Joseph J. Dixon
JJD/jw
c. Richard Long
_ " , ..~ - .'"'-' , '-" "
April 13, 2001
JOSEPH J. DIXON
126 STATE STREET
HARRISBURG, PA 17101
Dear Mr. Dixon:
,- '" i __ ~,'__" ,-,-.,-
,----,
Enclosed is a copy of a letter I received from you dated March 26, 2001. Please
refer to the last paragraph, which is highlightEld. The following page is a
statement from Pennsylvania Counseling Services showing that I did go to the
meeting and that your client did not. Please1,./ilform your client that he owes a "no
show" fee of $60.00 before he can schedule nother appointment. I will be
waiting for your reply. Thank you for your att ntion to this matter.
A copy of these letters has been sent to Curti Long, Prothonotary of
Cumberland County.
Sincerely,
Barbara A. Long
"
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PENNSYLVANIA COUNSELING SERVICES
4918 Locust Lane, Harrisburg, PA 17109
Phone: (717) 671-9610
Fax: (717) 671-9680
Saghir Ahmad, MD
Anne Dall, MD
To Whom it may Concern:
.&~bG{ ~ Lo;t} G
was seen in my office.
Date:
Time: I-I : 30 AM(!$)
If you have any questions, feel free to contact the office at the above number.
.Arr ,d((A ftdf-
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Signature
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April 13, 2001
CURTIS LONG, PROTHONOTARY
CUMBERLAND COUNTY COURT HOUSE
ONE COURT HOUSE SQUARE
CARLISLE, PA 17013
Dear Mr. Long:
Enclosed are correspondence between Attorney Joseph Dixon and Barbara A.
Long. Please include in the divorce file of Richard P. Long vs. Barbara A. Long
for future reference.
Thank you for your attention to this matter,
Sincerely,
Barbara A. Long
~ ~ - - . "
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.
RICHARD P. LONG,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-6024
BARBARA A. LONG,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
NOTICE OF INTENTION TO REQUEST ENTRY
OF ~ 3301(d) DIVORCE DECREE
TO: BARBARA LONG
You have been sued in an action for Divorce. You have failed to answer the Complaint
or file a Counter-Affidavit. Therefore, on or after October 20, 2003, the other party can request
the Court to enter a final decree in Divorce,
If you do not file with the Prothonotary of the Court an Answer with your signature
notarized or verified or a Counter-Affidavit by the above date, the Court can enter a final decree
in Divorce. A Counter-Affidavit which you may file with the Prothonotary of the Court is
attached to this notice,
Unless you have already filed with the Court a written claim for economic relief, you
must do so by the above date or the Court may grant the Divorce and you will lose forever the
right to ask for economic relief. The filing of the form Counter-Affidavit alone does not protect
your economic claims.
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.
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
1 COURTHOUSE SQUARE-FOURTH FLOOR
CARLISLE, P A 17013-3387
(717) 240-6200
--...~
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RICHARD P. LONG,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-6024
BARBARA A. LONG,
Defendant
CML ACTION-LAW
IN DIVORCE
COUNTERAFFIDAVITUNDER~3301 (d)
OF THE DIVORCE CODE
1. Check either (a) or (b):
D (a) I do not oppose the entry of a Divorce Decree.
D (b) I oppose the entry of a Divorce Decree because (Check (i), (ii) or both):
D (i) The parties to this action have not lived separate
and apart for a period of at least two years.
D (ii) The marriage is not irretrievably broken.
2, Check either (a) or (b):
D (a) I do not wish to make any claims for economic relief. I understand
that I may lose rights concerning alimony, division of property, lawyers
fees or expenses ifI do not claim them before a Divorce is granted.
D (b) I wish a claim to economic relief which may include alimony, division
of property, lawyer's fees or expenses or other important rights.
I understand that in addition to checking (b) above, I must also file all
economic claims with the Prothontary in writing and serve them on the other party.
IfI fail to do so before the date set forth on the Notice ofIntention to Request
Divorce Decree, the Divorce Decree may be entered without further notice to me,
and I shall be unable thereafter to file my economic claims. .
I verifY that the statements made in this Counter Affidavit are true and
correct. I understand that false statements herein are made subject to the penalties of
] 8 Pa.C,S. 9 4904 relating to unsworn falsification to authorities,
Date:
(DEFENDANT)
NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE
DECREE AND DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC
RELIEF, YOU SHOULD NOT FILE TillS COUNTER AFFIDAVIT.
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RICHARD P. LONG,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO.OO-6024
BARBARA A. LONG,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
COUNTER-AFFIDAVIT UNDER ~ 3301(d)
OF THE DIVORCE CODE
1. Check either (a) or (b):
o (a) I do not oppose the entry of a Divorce Decree.
'8 (b) I oppose the entry of a Divorce Decree because (Check (i), (ii) or both):
o (i) The parties to this action have not lived separate and apart for a period of at
least two years.
'it (ii) The marriage is not irretrievably broken.
R~l.L-eS* r'(\OA-~o-~o""~ ffiCL""~" "-~ e... Co,-,-,,,-s.J: "-~
2. Check either (a) or (b):
o (a) I do not wish to make any claims for economic relief. I understand that I may lose
rights concerning alimony, division of property, lawyer's fees or expenses ifI do not
claim them before a Divorce is granted.
g(b) I wish to claim economic relief which may include "1;~9RY, di':isiGR gfproperto',
la\v~'er' 5 fee5 <;>r ""p"n<,,< or Qth~r importiIDt light5.
Rcl~('e..""'-ev--o*" ~ "tS ("-<:''l,-,-~,,...<::.cl ~ I~ o'"'~
I understand that in addition to checking (b) above, I must also file all my economic
claims with the Prothonotary in writing and serve them on the other party, If I fail to do so
before the date set forth on the Notice of Intention to Request Divorce Decree, the Divorce
Decree may be entered without further notice to me, and I shall be unable thereafter to file any
economic claims.
I verify that the statements made in this Counter-Affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 9 4904
relating to unsworn falsification to authorities,
Date:
3/ i I D 1
~~..
(DEFENDANT)
Q
NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE
DECREE AND DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF,
YOU SHOULD NOT FILE TillS COUNTER-AFFIDAVIT. \iO'vch q\ 20'0'}
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Notarial Seal
WlUlam D. W18nnan, Notary Public
New CUmbotfand Boro, CUmbotfand County
My Commission Expires Sept 15, 2004
Member, Pennsylvania Assoc;.1iIm of Notaries
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RICHARD P. LONG
Plaintiff
vs.
BARBARA A LONG
Defendant
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IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYL VANIA
No. 00-6024 CIVIL TERM
CIVIL ACTION - IN DIVORCE
INCOME AND EXPENSE STATEMENT OF
RICHARD P. LONG
INCOME
(a)
Wages/Salary
Employer & Address:
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Commonwealth of Pennsylvania
Department of General Services
Harrisburg, P A
Job Title/Description:
Pay Period (weekly, bi-weekly, monthly):
Gross Pay per Pay Period
Payroll Deductions:
Federal Withholding. , , . . , ,
Social Security. , , . , , . , ,. ,
Local Wage Tax. . . . . . , . . ,
State Income Tax . . . . . . . . .
Pa. Unemployment Comp.Tax
Retirement.....,.,.... ,.
Health Insurance, . . , . . . . .
Other (specify) Union Dues
Sup Order PA. , . , , , . , , . .
Tax Deferred Comp , , . , , .
Net Pay per Pay Period, . .
MonthlyNet ........,.,
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High Voltage Electrician
Bi-weekly
$1.975.35
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$
$
$
$
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$ 123.46
$
$
$ 263.08
$ 50.00
$1.008.22
$2.184.48
333,06
122.47
19,75
55.31
-
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(b) Other Income Week Month Year
InterestJDividends. , . , $ $ $
Pension/Annuity, . . , $ $ $
Social Security, , . . , . . , $ $ $
Rents/Royalties, , , . . . . , $ $ $
Expense Account. . . . . . $ $ $
Gifts. , , . , . . . , . , , . , , . $ $ $
Unemployment Compo . $ $ $
Worlanen's Compo . . . , $ $ $
Other (specify). . . . . . . . $ $ $
Total, Other Income, , . . $ $ $
Total, Monthly Income. . , , . . , , . , , . , , . $ 2,184.48
EXPENSES
Home Week Month Year
Mortgage/Rent $ $ 375,00 $
Maintenance $ $ $
Utilities (Telphone,
Heating, electric, etc.) $ $ 80,00 $
Employment
(Transportation, lunches) $ $ 20.83 $
Taxes
Real Estate $ $ $
Personal Property $ $ 29.17 $
Income $ $ $
Insurance
Homeowners $ $ $
Automobile $ $ 82.00 $
Life/ AccidentlHealth $ $ $
Children's Life Insurance $ $ $
Other $ $ $
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Automobile
(payments, fuel, repairs) $ $ 68.33 $
Medical
Doctor, Dentist,
Orthodontist $ $ 41.67 $
Hospital $ $ $
Special (glasses, braces,
Etc,) $ $ 25.00 $
Education
Private, Parochial School $ $ $
College $ $ 25.00 $
Personal
Clothing $ $ 62.50 $
Food $ $ 333.33 $
Other (household supplies,
Barber, etc.) $ $ 34,00 $
Credit payments and loans $ $2.083.33 $
Miscellaneous
Household help/child care $ $ $
Entertainment (inc. papers,
books, vacation, pay tv, etc.) $ $ 70,00 $
Gifts/Charitable Contributions$ $ $
Lellal Fees $ $ $
Other child support!
Alimony payments $ $ $
Other $ $ $
Total Expenses $ $ 3.330.16 $
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PROPERTY OWNED
Checking Accounts
Savings Accounts
Credit Union
StockslBonds
Real Estate
Other
Total Property
DESCRIPTION
PSECU
INSURANCE
COMPANY
POLICY NO.
Hospital
Medical
Blue Cross
Health!
Accident
Disability
Income
I _"" ^ ~ _,
.'l!:+e
$
$
$
$
$
$
$
$
VALUE OWNERSHIP
H W J
$ 150,00 X
$ 150,00
PFP 202-42-7423 502625
X
COVERAGE
H W C
X
Other
(Specify)
***( H-Husband, W-Wife, C-Children)
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VERIFICATION
I verify that the statements made in this Income & Expense
.
statement
are true . and correct.
I understand that false
statements herein are made subject to the penalty of 18 Pa. C.S.
54904, relating to unsworn falsification to authorities.
-'., .
DATED: March 21, 2003
/@14
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INVENTORY
AND
APPRAISEMENT
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ASSETS OF PARTIES
(plaintiff) (Defendant) 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,
( ) 1. Real property
(X) 2, Motor vehicles
( ) 3, Stocks, bonds, securities and options
( ) 4, Certificates of deposit
( ) 5. Checking accounts, cash
( ) 6, Savings accounts, money market and saving certificates
( ) 7. Contents of safe deposit boxes
( ) 8. Trusts
(X) 9. Life insurance policies (indicate face value, cash surrender value and
current beneficiaries)
( ) 10. Annuities
( ) 11. Gifts
( ) 12, Inheritances
( ) 13. Patents, copyTights, inventions, royalties
( ) 14. Personal property outside the home
( ) 15, Businesses (list all owners, including percentage of ownership, and
officer/director positions held by a party with company)
( ) 16. Employment termination benefits--severance pay, workman's
compensation claim/award.
( ) 17, Profit sharing plans
(X) 18, Pension plans (indicate employee contribution and date plan vests)
( ) 19, Retirement plans, individual retirement accounts
( ) 20, Disability payments
( ) 21- Litigation claims (matured and unmatured)
( ) 22. MilitaryN.A. benefits
( ) 23. Education benefits
( ) 24, Debts due, including loans, mortgages held
( ) 25, Household furnishings and personalty (include as a total category and
attach itemized list if distribution of such assets is in dispute
( ) 26. Other
Il
LIABILITIES OF PARTIES
(Plaintiff) (Defendant) marks on the list below those items applicable to the case at bar
and itemizes the liabilities on the following page,
SECURED
( ) 1.
( ) 2,
( ) 3,
( ) 4,
Mortgages
Judgements
Liens
Other secured liabilities
UNSECURED
(X) 5, Credit card balances
( ) 6. Purchases
(X) 7. Loan payments
( ) 8. Notes payable
( ) 9, Other unsecured liabilities
CONTINGENT OR DEFERRED
( ) 10. Contract or Agreements
( ) 11. Promissory notes
( ) 12. Lawsuits
( ) 13. Options
( ) 14, Taxes
( ) 15. Other contingent or deferred liabilities
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VERIFICATION
I verify that the statements made in this Inventory and
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are true and correct.
I understand that false
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S4904, relating to unsworn falsifica~ion to auth~rities.
DATED:
March 21, 2003
{,m 11-4
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CUMBERLAND COUNTY DIVORCE MASTER
9 NORTH HANOVER STREET
CAlU.lSLE, PA 11013
E. Robert Elicker, II
DiwrceMaster
Te1epbone717-240-6535
West Shole 697'()371 Ext. 6535
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TraciJ. Colyer
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FACSIMILE TRANSMITTAL MEMORANDUM
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SUBJECT: Lnl'le, \jo;, \Il'/l~
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FILE No. 49506/05 '0314:01 ID:YOFFE & YOFFE, P.C.
717 975 1912
PAGE 1
NORMAN M, VOl FE
JEFFREY N, YOFI E
LAW OFFICES
YOFFE & YOFFE, P,C.
214 Senate Avenue * Suite 203
Camp Hill, Pennsylvania 17011
Telephone (717) 975-1838
Fax (717) 975-1912
DATE: June 5, 2003
TO: E. Robert Elicker, II, Esq,
FAX NUMBER: 240-7890
FROM: Jeffrey N, Yaffe, Esq,
NO. OF PAGES: (6) Including this one
RE: Lont! v Lon!!; OQ.602~
Attached llease find the petition for leave to withdrew which I will mail for filing on
today's date. PllIase note that Barbara Long concurred with the same and signed Exhibit
"A" to that effect
I am co ~cerned about the June 23 deadline set forth In your May 30
correspondence, Mrs, Long will be representing herself and said she would file a pretrial
statement by the I date,
~~~-'--
I assume', he Court will ~ow my appe!!rance tn be wlthdrawn~pectfUIlY re~~;;i
thet you fax me lomethlng short Indicating that If the Court allows Il!1' appearance to be
withdrawn, then I do not have to comply with the June 23 dead.lJ.n!,) Both myself and
Barbara long Will thereafter operate under the assumption that Barbara Long will comply
with the June 23 ~eadllne,
Sincerely,
"
Thank you,
YOFFE & YOFFE, P,C,
By
cc:
Joseph J. DIxon, E sq,
Fax: 233.5860
Barbara A. long
Hand Delivery
Jeffrey N. YOffe
long, barbara \fax ~
-- -. . ~"
FILE No, 49506/05 '0314:01 !D:YOFFE & YOFFE, P,C.
717 975 1912
RICHARD P. LONG
PLAn'I'IH'
IN 'nit:': COURT OF COMMON PLEAS
COMBEHL/INP COUNTY, PENNSYLVANIA
V"
"
NO. 00-6021
BARBARA A. ,,'oNG
DU'E:tIDANT
CIvn ACTION-LAW
IN DIVORCE
ORDER
AND NOW,
1:.hi.,5 ___ clay of
2003,
it i;3 he:cet)y
Ol.'de,:ed that t 1e appe,~:r,~nG<' of Yoffe & Yoff..., I~, C, by ,reffrey N,
Yof:Er~!, Esq. f.O( lj,:lI"bara A. Long" in I:..t~(~ above cap"tionecl dction 'is
11e.r:(!by wi thdraw:I,
BY THE COURT
,.-'
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PAGE 2
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FILE No. 495 06/05 '03 14:01 ID:YOFFE & YOFFE, P.C.
717 975 1912
RICHARD P. LONG
PLAHTIFI?
fN '('au: COURT Ow COMMON PLEAS
(:lJM.B8RLAND COUNTY, PENN:3Yl,VI\NIA
vs
NO. 00-6024
RARBAHA 1\. LONG
DE 1"I': t DANT
CIV.l.J. ACTION"I.I\W
IN DOl VORCE
PETrTI.!?.!'i---2r YO Fn;; & YOI'FE, f~:..~_.. BY JEH'I'~:Y N. YOFFE,..._y;,;QlJIRE
FOR L8/WE 1'0 WI'l'(.lDRAW AS COUNSEL fOR BARBARA A. 'LONG
-~"'- ... ',..-- .", '~'.'''''''''-
1. petitiloer is Yoffe , Yoffe, P.C. by Jeffrey N, Yoffe, Esq.
2. On or arolmd July 16, 2001, IJY w~y of fil,j.ng a .response 1':0
the Di.vorce com.plaint on b(~hi.llf of R;,.t:.bllra A. Lon9, Pet.ltlonoI entered
hj.$ appearancc1 j or B.-:"J.'b';l.I:a A. L,onq i.11 tl1e ab<.rvo:;: ma't'\:.e.:::.
3. As i.ncicated by 8xl1ib:Lt. "/.\" attaclled hel."eto, B~.l.cba.t:t1 A. Long
is cOllcurring wJth the Wi1:tldraw ot l:tle appearance of the LIO(iersj.gned.
q. The w.l:rldr.:\wal of I;he appe;Hance of !:lIe llnders:Lgned ~,hOllld
not delay any ,~tag", of the :i.-[ 1;.i.9atiol1 ot this Ga3~).
At tile pn'.sent
t.ime, l:hc.r0 are no pencting hearings in thiS! case.
Divo:cce Ma.':ite.r E.
Robert Elick~r, II, ~5q. has 8et ~ June 23, 2003 deadline for Ba~bar~
1\. Long- to file a p,retl'ial ti"!:.at.ement, however, Barbara A.. [.r,H11] shoulct
[lave suf!ic::i.onl, elme to Ole tl1at stutement even ttlollgh the
llnct".rsigned beli eveS Chat Ba.i:IJ8.n' A. 1,01\9 will be proc:eert:i.ng in this
matter without the a.Bi~tance of an Attorney.
.~. At Lorn.~~y ,Joseph .]. Dixon rl~p)~E.!Sel.1,t~; R.lcrla.cd I? Lon~r.
6, The LlwlersiCfned ha,; mad.. f>1Cfol'-cS to (:ommun~c"l;o W.l th Atto.mey
Dixon reqarcling h.1..'3 posit..i.on on t.hi.'5 mot.ion, howeve:r., the Llnde,t.'SignsL1
ha. not yet been able to directly speak w.lth Attorney Dixon.
PAGE 3
.)_~~", 0
"
FILE No. 495 06/05 '03 14:02 ID:YOFFE & YOFFE, P.C.
717 975 1912
WriEREf'OHE, Peti tione.t:' request$ tha't. I:.rl<:l COL1:rt. qriJnt P.8'1,.:i. t..i.oner
J.e"ve t() Wl thdrilw his "ppearanc(, for Ba,cbdra A, Long tn 1:I\i.s action.
YOFFE & YOFFB, P.C.
,o:fs, E:iqui.t'e
Avenue, Stlite 203
Camp HUl, PA 1'70J..1.
(717) 975-J.830
At:torney fD No. 52933
l(:lJl'4. t1d:rbal:i1\I.;:nvt' 1;( wj r.l',tlJ.':IW
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PAGE 4
FILE No. 495 06/05 '03 14:02 JD:YOFFE & YOFFE, P.C.
717 975 1912
RICHI\RD P. J,ONG
~):,AnTIH'
IN 'j,I11:: COl1R'l' OF COMMON PI"CAS
CIJMB8l<1.,AND COUNTY, P8NNSYlNANIA
VS
NO. 00-6024
BAH8ARA 1-\, LONG
DEFE~ DANT
CIV 1.1" ACT JON-LAW
IN DIVORCE:
CERT'\I"ICATE CW SERVJ(~.~
Tile IjJlder, i.c)ned certifies that on the date i.nd:i.catecl bolow he
.'~iJrvecJ i:l copy 0:: the .f.ore9oi.n/J PetiL:ion on .Joseph .J. Dixon, E'.sq ancl ~;.
RobetL E'..licke:r. I I I, h~sq. Service W,';l!;i accomplished by fay.:~ng tl1e same
co them c$ follcws:
Joseph J. Dixon, e~q.
233"~i86(J
8. ROI)ert E.I.i.cker, 1I, Esq.
240-7890
YOFFE & YOFFE, P,C.
Dat~: ~rune 5, 20)]
:if/r:y - VY..illJ A: i _.__
e.~. ~~SqUiCe
21~ Seo,a.te Avr:'l1ue, Suite 203
Callip Hill, PA 1/1111
(n.7) 975-.1838
At~orney 10 No. 52933
PAGE 5
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FILE No. 495 06/05 '03 14:02 ID:YOFFE & YOFFE, P.C.
717 975 1912
PAGE 6
RICHAl~D 1'. WNG
PLAHTIPF
IN 'l'l'IF: COllf('J' O.T:' COMMON PLEAS
Cl1MBEfiLAND COUNTY, PENNSYLVANIA
vs
NO. 00-6024
IjARBMiI A. LONe
1)I,fE~ W\N'I'
CIVIl, ACTION-I,AW
IN fn VORCE
.g~ru:x.E'I CATE9F CONCUHRENCE
'the Llndl~[.sigTied .repre~a:1nts that: on [he daLe i.ndicateCi below 9rl~
appea.red .i,n the office o:f. YOffe & Yaffe/ P.C, and l-.hcrr:=.in l:'eccivecl a
copy of the to :0.go;,n9 pet.\ I'. i.on 1:0" lp.ave to w:i.I:.hdraw.
l r:e8c~ t.he
pe.titiorJ ancl (jLfcu8sed the ::l.:lme with ,Jef:[rr:'y N. Yaffe, tI',.::q,
i: agree
Ulat tl'le appea.~'ance of Yoft? & YOff"" P.C. by ,Jeff~0'y N. Yoffe, Esq. on
my benal r: .'howl:l be w5. thdrawn and I hav? no oJJjection to the COIl.t't
signIng ell" prop )Sed Or(l<)1' atr.~ched l'le.,."to to I:hat e[fect.
Dace:
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Dar):'M:'" A. Long
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EXHIBIT "A"
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HP LASERJET 3330
Jun-5-2003 13:57
Fax Call Report
Job Date Time Type
135 61 5/2003 13:56:23 Receive
1:18
Identification
Duration
717 975 1912
FILENo.49500/Q5'0314:01ID:YCJFFE&YOFFE,P.C.
7179751912
NORMAN M. YOf FE
JEFFREY N. YOFJ E
LAW OFFICES
YOFFE & YaFFE, P.C.
214 Senate Avenue <I< SuIte 203
Camp Hill, Pennsylvania 17011
Telephone (717) 975-1838
Fax (717) 975-1912
DATE: June 5, 2003
TO: E.Roberl ElIcker, II, Esq.
FAX NUMBER: 240.7890
FROM: Jeffrey N. Yaffe, Eaq.
NO. OF PAGES: (6) IncludIng thl& one
RE: Lonl!" v Lonl!' On.S02~
Attached lleasa fInd the petillon for leave to wIthdraw which I will mall for filing on
today'a date, Pl"ase note thai BarbarB Long COncurred with the same and slgnad Ekhlbll
"A" to Ihat effl;!ct
I am co~ceml;!d about the Junl;! 23 deadline set forth In your May 30
corraspondence. Mrs,Longwlll bo representIng herself andssld she would fllea pretrial
alatemanl by th;rl date,
I flssume 'he Court will allow my appearanca to bee withdrawn. I respectfully request
Ihat you fax mil lomelhlng &lIorllndlcaUng that If the Court allows my Ilppsllranca to be
wIthdrawn, then I do not have 10 comply wIth the June 23 deadline, Both- myself and
Barbllra Long will thereafter operate under Ihe s&&umpllon Ihat Barbarl!l Long will comply
wIth Ihll June 23 :loadllne.
Thank you
SIncerely.
YOFFE & YOFFE, P.C,
By
Jaffroy N. Volfe
cc:
JosephJ.Dlxon,Esq,
Fax: 233-5&60
BllrbarllA.long
Hand Del1vary
long,barbllra\to_~
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RICHARO P. LONG
PLAINTIFF
JUN 1 1 Z003 ~
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-6024
VS
BARBARA A.. LONG
DEFENDANT
CIVIL ACTION-LAW
IN DIVORCE
ORDER
AND NOW, this 1J.~day of ~
Ordered that the appearance of Yaffe & Yaffe, P.C. by Jeffrey N.
2003, it is he.reby
Yoffe,~ Esq. for Barbara A. Long in the above captioned action is
hereby withdrawn.
BY T
J.
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Certified As A True Copy
01 Original Document Filed\T,tV Y
RICHARD P. LONG
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
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PETITION OF YOFFE & YOFFE, P.C. BY JEFFREY N. YOFFE, ESQUIRE~
FOR LEAVE TO WITHDRAW AS COUNSEL FOR BARBARA A. LONG
NO. 00-6024
VS
BARBARA A. LONG
DEFENDANT
CIVIL AC'l'ION-LAW
IN DIVORCE
1. Petitioner is Yaffe & Yaffe, P.C. by Jeffrey N. Yaffe, Esq.
2. On or around July 16, 2001, by way of filing a response to
the Divorce c;omplaint on behalf of Barbara A. Long, Petitioner entered
his appearance for Barbara A. Long in the above matter.
3. As indicated by Exhibit "A" attached hereto, Barbara A. Long
is concurring with the withdraw of the appearance of the undersigned.
4. The wi thd.rawal of the appearance of the undersigned should
not delay any stage of the litigation of this case. At the present
time, there are no pending hearings in this case. Di vorce Master E.
Robert Elicker, II, Esq. has set a June 23, 2003 deadline for Barbara
A. Long to file a pretrial statement, however, Barbara A. Long should
have sufficient time to file that statement even though the
undersigned believes that Barbara A. Long will be proceeding in this
matter without the assistance of an Attorney.
5. Attorney Joseph J. Dixon represents Richard P. Long.
6. The undersigned has made efforts to communicate with Attorney
Dixon regarding his position on this motion, however, the undersigned
has not yet been able to directly speak with Attorney Dixon.
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WHEREFORE, Petitioner requests that the Court grant Petitioner
leave to withdraw his appearance for Barbara A. Long in this action.
YOFFE & YOFFE, P.C.
o fe, Esquire
Avenue, Suite 203
Camp Hill, PA 17011
(71 7) 975-1838
Attorney 10 No. 52933
long, ha~ba~a\leave to withdraw
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RICHARD P. LONG
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-6024
VS
BARBARA A. LONG
DEFENDANT
CIVIL ACTION-LAW
IN DIVORCE
CERTIFICATE OF SERVICE
The undersigned certifies that on the dat.e indicated below he
served a copy of the foregoing Petition on Joseph J. Dixon, Esq and E.
Robert Elicker, II, Esq. Service was accomplished by faxing the same
to them as follows:
Joseph J. Dixon, Esq.
233-5860
E. Robert Elicker, II, Esq.
240-7890
YOFFE & YOFFE, P.C.
Date: June 5, 2003
e f N. Yo e, Esquire
214 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
Attorney 10 No. 52933
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RICHARD P. LONG
PLAINTI FF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-6024
VS
BARBARA A. LONG
DEFENDANT
CIVIL ACTION-LAW
IN DIVORCE
CERTIFICATE OF CONCURRENCE
The undersigned represents that on the date indicated below she
appeared in the office of Yoffe & Yoffe, P. C, and therein received a
copy of the foregoing petition for leave to withdraw.
I read the
peti tion and discussed the same with Jeffrey N. Yoffe, Esq.
I agree
that the appearance of Yoffe & Yoffe, P.C. by Jeffrey N. Yoffe, Esq. on
my behalf should be withdrawn and I have no objection to the Court
signin9 the proposed Order attached hereto to that effect.
Date:
(,/:;/03
R.Jr..- Q.~
Barbara A. Long
EXHIBIT "A"
?~,
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RICHARD P. LONG
PLAINTIFF
JUN 1 1 2003 ~
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-6024
VS
BARBARA A. LONG
DEFENDANT
CIVIL ACTION-LAW
IN DIVORCE
ORDER
AND NOW, this ,rday of ~
2003, it is hereby
Ordered that the appearance of Yaffe & Yaffe, P. C. by Jeffrey N.
Yaffe, Esq. fa': Barbara A. Long in the above captioned action is
hereby withdrawn.
BY T
J.
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RICHARD P. LONG
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-6024
VS
BARBARA A. LONG
DEFENDANT
CIVIL ACTION-LAW
IN DIVORCE
PETITION OF YOFFE & YOFFE, P.C. BY JEFFREY N. YOFFE, ESQUIRE
FOR LEAVE TO WITHDRAW AS COUNSEL FOR BARBARA A. LONG
10 petitione.r is Yoffe & Yoffe, PoCo by Jeffrey N. YOffe, Esq.
2. On or around July 16, 2001, by way of filing a response to
the Divorce complaint on behalf of Barbara A. Long, Petitioner entered
his appearance for Barbara A. Long in the above matter.
3. As indicated by Exhibit "A" attached hereto, Barbara A. Long
is concurring with the withdraw of the appearance of the undersigned.
40 The withdrawal of the appearance of the undersigned should
not delay any stage of the litigation of this case.
At the present
time, there are no pending hearings in this case.
Divorce Master E.
Robert Elicker, II, Esq. has set a June 23, 2003 deadline for Barbara
A. Long to file a pretrial statement, however, Ba.rbara A. Long should
have
sufficient time to
file that statement even though the
undersigned believes that Barbara A. Long will be proceeding in this
matter without the assistance of an Attorney.
5. Attorney Joseph J. Dixon represents Richard P. Long.
6. The undersigned has made efforts to communicate with Attorney
Dixon .regarding his position on this motion, however, the undersigned
has not yet been able to directly speak with Atto.rney Dixon.
,~.. ~,-
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WHEREFORE, petitioner requests that the Court g.rant Petitioner
leave to withdraw his appearance for Barbara A. Long in this action.
YaFFE & YaFFE, P.C.
o fe, Esquire
Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
long, barbara\leave to withdraw
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RICHARD P. LONG
PLAINTI FF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-602Q
VS
BARBARA A. LONG
DEFENDANT
CIVIL ACTION-LAW
IN DIVORCE
CERTIFICATE OF SERVICE
The undersigned certifies that on the date indicated below he
served a copy of the foregoing Petition on Joseph J. Dixon, Esq and E.
Robert Elicker, II, Esq.
Service was accomplished by faxing the same
to them as follows:
Joseph J. Dixon, Esq.
233-5860
E. Robert Elicker, II, Esq.
240-7890
YOFFE & YOFFE, P.C.
Date: June 5, 2003
e f N. Yo e, Esquire
214 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
Attorney 10 No. 52933
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RICHARD P. LONG
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-6024
VS
BARBARA A. LONG
DEFENDANT
CIVIL ACTION-LAW
IN DIVORCE
CERTIFICATE OF CONCURRENCE
The undersigned represents that on the date indicated below she
appeared in the office of Yoffe & Yoffe, P.C. and therein received a
copy of the foregoing petition for leave to withdraw.
I read the
petition and discussed the same with Jeffrey N. Yoffe, Esq.
I agree
that the appearance of Yoffe & Yoffe, P.C. by Jeffrey N. Yoffe, Esq. on
my behalf should be withdrawn and I have no obj ection to the Court
signing the proposed Order attached hereto to that effect.
Date:
C,/S/()3
rs~ Q.~
Barbara A. Long
EXHIBIT "A"
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ATTORNEY AT LAW
126 STATE STREET. HARRISBURG, PA 17101
PHONE: (717) 233-8757 . FAX: (717)~3-5860
EMAIL: dixonlaw@paonline.com .
WWIN.dixonlaw.baweb.com
November 13, 2003
CUMERLAND COUNTY COURT OF COMMON PLEAS
OFFICE OF THE DIVORCE MASTER
ATTENTION: TRACY
9 NHANOVER STREET
CARLISLE, P A 17013
Re: Richard P. Long v. Barbara Long
No. 00-6024 Civil
In Divorce
Dear Tracy:
In follow up to the conversation you had with my secretary this date, enclosed
please find two (2) copies of the signed Marital Settlement Agreement. I understand that
you will prepare the Order and upon receipt of our signed copy by the Judge we may then
file the Praecipe to Transmit the Record.
Thank you for your assistance.
Very truly yours,
Joseph J. Dixon
JJD/jw
Enclosures 2 Marital Settlement Agreements
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ATTORNEY AT LAW
126 STATE STREET. HARRISBURG, PA 17101
PHONE: (717) 233-8757 . FAX: (717) 233-5860
EMAIL: dixonlaw@paonline.com
www.dixonlaw.baweb.com
June 20, 2003
OFFICE OF DIVORCE MASTER
ATTN: E. ROBERT ELICKER, II, ESQUIRE
CUMBERLAND COUNTY COURT
OF COMMON PLE-AS
9 NORTH HANOVER STREET
CARLISLE, PA 17013
Re: Richard P. Long vs. Barbara A. Long
No. 00 - 6024 Civil
In Divorce
Dear Bob:
In follow-up to your correspondence of May 30, 2003, the above-referenced
divorce is resolved in principle. Attorney Y offee is no longer representing Barbara Long.
I have received the enclosed letter from Barbara Long which sets forth the agreement of
the parties. I am concerned about what is the best way to handle this procedurally in light
of Number (1) of Mrs. Long's letter to me.
Please contact me and give me your advice as to procedurally how to handle the
settlement at this time.
Very truly yours,
~
Enclosure
cc: Richard Long
Barbara Long
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Barbara Long
238 Walnut Street Apt 2
Lemoyne, PA 17043
.
June 16, 2003
HAND DELNERED
Mr. Joseph Dixon
Attorney At Law
126 State Street
Harrisburg, P A 17101
Dear Mr, Dixon,
On Saturday, June 14, 2003, and again on Monday, June IS, 2003, I conferred
with your client, Richard Long, and we have come to the following overall resolution.
We both agree to the following: (1) The divorce would be entered upon the.;grounds of
adultery. (2) Mr. Long agrees to continue to pay alimony up until his retireJ;Qent date and
the date that I begin receiving monthly retirement payments from his state pension. The
amount will be Five Hundred and Seventy Dollars ($570.00) per month for a period of
one year commencing on July 1, 2003 until July 1,2004. After such time Mr. Long
requests that a re-evaluation by DRO be done on a yearly basis as to how much he will
continue to pay each year. (3) Mr. Long agrees to pay me one half of the marital value of
his pension with the date of separation being March 31, 2002. (4) This pension payment
would be payable to me upon his retirement from the Commonwealth of Pennsylvania.
(5) I have agreed to waive any claim for deferred compensation. (6) I have agreed to not
claim or ask for health insurance coverage. (7) Mr. Long agrees to waive any claim for
my pension at the Giant. (8) Mr. Long will be responsible for any attorney's fees charged
by you (Mr. Dixon) and for any court costs. I agree not to ask for fees charged by Mr.
Yoffee, Attorney at Law, while he was employed by me up until June 5, 2003.
Please prepare the Marriage Settlement Agreement and notify me when it is
fmished by sending me the papers to read over. We can then set aside a time that is
convenient for both of us for me to come to youfoffice to sign the papers.
Very truly yours,
Barbara Long
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Barbara Long
238 Walnut Street Apt 2
Lemoyne, P A 17043
June 16, 2003
E. Robert Elicker, II
Divorce Master
Cumberland County
Court of Common Pleas
9 North Hanover Street
Carlisle, PA 17013
RE: Richard P. Long vs. Barbara A. Long
No. 00-6024 Civil
In Divorce
Dear Mr. Elicker,
This letter is to inform you that my husband and myself (the above listed parties)
have come to a Marriage Settlement Agreement upon which Mr. Joseph Dixon, Attorney
at Law, as been instructed to draw up the papers. A copy of the agreement is enclosed.
I am under the understanding that because we have reached an agreement that it is
not necessary for me to file a pretrial statement on or before Monday, June 23, 2003. If
this is incorrect, please notify me immediately on receipt of this letter, so that I can have
it in on time.
Very truly yours,
Barbara Long
enclosure
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Barbara Long
238 Walnut Street Apt 2
Lemoyne; PA 17043
June 16, 2003
HAND DELIVERED
Mr. Joseph Dixon
Attorney At Law
126 State Street
Harrisburg, PA 17101
Dear Mr. Dixon,
On Saturday, June 14,2003, and again on Monday, June 15, 2003, I conferred
with your client, Richard Long, and we have come to the following overall resolution.
We both agree to the following: (1) The divorce would be entered upon the grounds of
adultery. (2) Mr. Long agrees to continue to pay alimony up until his retirement date and
the date that I begin receiving monthly retirement payments from his state pension. The
amount will be Five Hundred and Seventy Dollars ($570.00) per month for a period of
one year commencing on July 1, 2003 until July 1, 2004, After such time Mr. Long
requests that a re-evaluation by DRO be done on a yearly basis as to how much he will
continue to pay each year. (3) Mr. Long agrees to pay me one half of the marital value of
his pension with the date of separation being March 31,2002. (4) This pension payment
would be payable to me upon his retirement from the Commonwealth of Pennsylvania.
(5) I have agreed to waive any claim for deferred compensation. (6) I have agreed to not
claim or ask for health insurance coverage. (7) Mr. Long agrees to waive any claim for
my pension at the Giant. (8) Mr. Long will be responsible for any attorney's fees charged
by you (Mr. Dixon) and for any court costs. I agree not to ask for fees charged by Mr.
Y offee, Attorney at Law, while he was employed by me up until June 5, 2003.
Please prepare the Marriage Settlement Agreement and notify me when it is
finished by sending me the papers to read over. We can then set aside a time that is
convenient for both of us for me to come to your office to sign the papers.
Very truly yours,
Barbara Long
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RICHARD P. LONG,
Plaintiff
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00 - 6024 CIVIL
BARBARA A. LONG,
Defendant
IN DIVORCE
ORDER OF COURT
AND NOW, this
/8-11--
day of
5~,
.
2003, the economic claims raised in the proceedings having been
resolved in accordance with a marital settlement agreement
dated September 16, 2003, the appointment of the Master is
vacated and counsel can file a praecipe transmitting the record
to the Court requesting a final decree in divorce.
BY THE COURT,
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t,.Joseph J. Dixon
Attorney for Plaintiff
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vlBarbara A. Long
Defendant
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NUUUTALSETTLEMENTAGREEMENT
.. THIs A(:iREEMEN'f' made this . /617 day of 5'Yjtftp;t~1. 2.003, by.. and
between RlCHARnP.LONG(1iereinafter called ''Husband'') and BARBARA A.
LONG (hereinafter called "Wife").
WITNESSETH:
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WHEREAS, Husband and Wife were married on August 18, 1972, in~:
Cumberland, Cumberland County,Pennsyl~~a. g& .....,
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WHEB,EAS, there'Y<:re Two (2) childrenbomofthismarriage, bOth Qver~eaie .
, .;' . ';;::"-'.;~-_.,,:_: ,~-., . c.",' ;". :',::." '-. " -~ '; - -':" ,- .--..:.---. .....-:' C.:O
of Eighh::eU (18) years Old. .... .
WHEREAS, the parties hereto desire to fix and determine by this Marriage
Settlement Agreement the rights and claims they have accrued to each of them in the
estate and reaJ, and per~onal property of the other by reason of the marriage; and aJ,I
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economic rights of every kind and description arising from the marital relationship.
NOW THEREFORE, in consideration of the promises and of the marriage, and
. .
in further consideration of the mutual promises and undertakings hereinafter set forth,
each intending to be legally bound hereby, the parties ll:gree as follows:
1. DIVORCE The parties hereto are aware that this Divorce Decree will be
entered under the provisions of the No Fault Code regarding separation of more than two
(2) years. Husband acknowledges that he has committed adultery during the marriage.
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2. SEPARATION It shall be lawful for each party at all times hereafter to live
separate and apart from the other party at such place as he or she may from time to time
choose or deem fit.
3. INTERFERENCE Each party shall be free from interference, authority, and
contact by the other, as fully as he or she were single and unmarried except as may be
. necessary to carry outthepr()\'isi~i1.s ofprisAgreement.
4. WIFE'S DEBTS Wife represents and warrants to Husband that as of the date
of separation she has not iJ;1curred, and in the future will not contract or incur, any debts,
liability for which Husband or his estate may be responsible and shall indemnify and save
harmless Husband from any and all claims or demands made against him by reason of
debts or obligations incurred byh~. Any.and alllo~ and/or debts and charge accounts
currentlyinWife's name alone)hilllbe Wife's sole;: and sepal-ate responsibility for.
paymer;t. Wifeagreest9~d~f?' and save harmless theHusband from any loss he
may sustain, inCluding~ttori1eysfees, as aieSult of any default in payment'bjiWife.
"
5. HUSBAND'S DEBTS Husband represents and warrants to Wife that as of the
date of separation he has not incurred, and in the future will not contract or incur, any
debt or liability for whi.chthe Wife or: her estate might be responsible and shall indemnify
and save harmlesS"Wife from anyand all cl;llins or demands made against her by any
reason of debts or 'obligations incurred by him. Any and :lllloans and/or debts and
charge accounts presently in. Husblind's name alone shall be Husband's sole and separate
responsibility for payment. Husband agrees to indemnify and save harmless Wife from
any loss she may sustain, including attorneys fees, as a result of any default payment by
Husband.
6. DIVISION OF PERSONAL PROPERTY The parties have divided between
them, to their mutual satisfaction, their personal effects, bank accounts,
household furniture and furnishings, and all other articles of personal property which
have been heretofore been used by them in common.
7. ALIMONY Husband agrees to pay alimony through the date of his retirement
from the Commonwealth of Pennsylvania to the date he begins to receive monthly
retir~~t payrrlents, Currently, Husband agrees to pay $570.00 per month in alimony,
. which Will be effective July I, 2003, through July 1,2004. Thereafter, the alimony will
, ,. . -', - , . .
be re:~~aluat~d>by the 'Domestic Rel~tions Office on ayearlybasis.
8. EOUlTABLE DISTRIBUTION OF MARITAL PROPERTY
,
,
A. Husband agrees to pay wife one-half (112) of the marital value of his
pension defined as. of March 30, 2002,_ Attached hereto and marked
Exhibit A .is a statement from the State Employee's Retirement System ,
certifYit?g .!lIl;l pr~sl;)11t v:al'Utl of the pension lIS pfthat d~te ofF.our Hun~red
Twentyi.w'd'niou~aiId. DciI1~>se';~ Htiri&:~pighf);. ~~.Dohars and
'. .',',' ': ,-,:.," ',' :- . _'0 -','; '" _". ..: ,'.: _','-..,. .. ,.", '''0 -.
Sixty Eight Cents ($422,783.68). Both parties agree that thi~ value is
reasonable and this is the amount upon which Wife Will receive one half
upon the retirement of the husband. It is underStood that this amount may
continue to grow based upon investments of the State Employee
Retitenlent System.
B. Wife agrees to waive any claim that she may have to husband's deferred
compensation through the Copland Group as part of an employee benefit
of employment with the Commonwealth ofPennsy1vania.
C. Husband waives any claim that he may have for his wife's pension
through Giant Foods.
D. Husband agrees that he is responsible for his own attorney's fees.
. .
E. Wife agrees to waive any claim for attorney's fees.
F. Wife agrees to waive or not claim any health insurance coverage under
husband's coverage.
8. GENERAL RELEASE
Other .than the termsofthisagreem(mt, it is hereby specifically agreed that Husband and
c, _, _, _ _ ,..: _ '. _. .' _ ,,'.' _._"' _ ,,' " . , , .
Wife shall forever relinquish to the other his or her right, title, and interest in said pension
plans and/or retirement plans and/or employee stock or savings plans, as well as all other
employee benefits of the other, The parties agree to execute any and all documentation
necessary to effectuate the terms h';ein contllined.
"
9. BREACH If either party breaches any proyision of this Agreement, the other
party sh1l11 have the right, at his or her eIection,to sue for damages of such breach,
. in<::lu~g.~F.5~';[7,9?~~ eJ(p~es'9r~~elc.s.uchrlllJledies or relief as may beavailable to
him 6r,hefi~sp~tively. " --
10. ADDITIONAL' INSTRUMENTS Each of the parties shall from time to
time, at the request of the other execute, acknowledge, and deliver to the other party and
all further instruments that may be reasonably required to give full force and effect to this
Agreement. ,-..,=.
11. WAIVER OF CLAIMS AGAINST ESTATE Except 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 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, dower, curtsy,
statuto!)' allowance, widow's allowance, right to take property against the Will of the
other, and the right to act as administrator or executor of the other's estate, and each will,
at the request of the other, execute, acknowledge, and deliver any instruments which may
.'
- ..
be necessary or advisable to carry into effect this mutual waiver and relinquishment of all
such interest, rights, and claims.
12. INCORPORATION OF AGREEMENT FOR ENFORCEMENT This
Agreement shall bind the parties hereto and their respective heirs, executors,
administrators legal representatives and assigns. This Agreement shall survive a Decree
of Divorce between the parties in any jurisdiction and any other Order which may be .
, " :- _ ,"',' ,>, - :-.,":-'....~:. ".- ~'.;" ,'-. ~ :_'_:'<~.~ ,~.<:',' ,(-:' - '_: 7:.>'~ -__ - - eo - .'., <,' '...' "?~' - -', ~-:" ':.::J _~~-. ..'.',-'" '-,:",' .;
entered inaccordance with this. Agreement. . In the event that a Decree in Divorce is
entered in the Court of Common Pleas of Dauphin County, Pennsylvania, or in the event
that a Decree in Divorce is entered in any other jurisdiction, the parti~s agree to
. incorporat~this A.greement into the bivorce Decree for purposes of enforcement.
"
13. ENTIRE AGREEMENT This Agreem.~t contains the entire imderstanding
. .
of the partie~, and there are no representatives, warranties, covenants, or undertakings ..'
--
14. MODIFI~ATI()N'~",AlVER4 modificati9n or waiver of anyofthe .
provisions of this Agreement sha.ll be effective only if made in writing and executed with
the same formality as this Agreement. The failure of either party to insist on strict
performance of any of the provisions of this Agreement shall not be construed as a
waiver of any subsequent defaUlt ofthes8ll!:e or similar nature.
- .
15. VOLUNTARYE:XECUTION Each party acknowledges that the
. --.
Agreement is fair and equitable, that full disclosure has been made by each respective
party to the other, that it is being entered into voluntarily, and that it is not the result of
any duress or undue influence. Wife and Husband ackiiowledges tI:1at they have been
furnished with all the information relating to the financial affairs of the other, which has
been requested by them respectively.
16. DESCRIPTIVE HEADINGS The descriptive headings used herein are for
convenience only. They shall have no affect whatsoever in determining the rights or
obligations of the parties.
IN WITNESS WHEREOF, the parties hereunto set their hand and seals the day
and year first above written.
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. ~ARA A. LONG
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ACKNOWLEDGEMENT
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
. '. ONl'IDS,the ......I{dayOf;~~~ il2003,beforeme,aNotary .
Public, the undersigned officer,personally app e CHARD P. LONG, known to me
. (or satisfactorily proven) to be the person whose naihclis subsCribed tothe Within
instrument, and acknowledges that she executed the same for the purposes therein
contained.
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. IN WITNESS WHEREOF,:r hereunto set my hand and official seal.
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';:.NOTARiAL~"j>
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My~Il>:pINSApr.2S,2005
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
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ON TIDS,tlie .' . day of -J, . 2003, before me, a Notary
Public, the undersigned officer, personally appea.re ARBARAA.cLONG, known to
me (or satisfactorily prov~) to be the person whose name is subscribed to the Within
instrument, and acknowledges that she executed the same for the purposes therein
contained.
IN WITNESS WHEREOF, I hereunto set myhand and official seal.
~u~
NO-T hRIAL SEAL
lennifer ~i. WilsCIl, KatlD1 Public
Cll:y o! !IlltrtSbUl:g.lJaUllb!n County
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STATE EMPLOYEES' RETIREMENT SYSTEM
30 NORTIHHIRD STREET - P.O. BOX 1147
HARRISBURG, P,ENNSYLyANlA 17108-1147
TOLLFREE: 1-800-833,5461
717.783-9065
www.sers.state.pa.u.s
October 29, 2002
RICHARD P LONG
PERSONAL'AND CONFIDENTIAL
3029 LOCUST,STREET
HARRISBURG PA 17109
SSN: 202-42-7423
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:Dear Mr :~ong:
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Responding to yo.ur inquiry regarding the value of your retirament account. with the State Employees'
Retirement System, I provide you with the following summary of member cont,!butions and Interest:
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Value of Account as of 03/30/2002: $ 55 809.53
Total ContribUtions and Interest
Present Value, ' $ 422,783.68
Final AveraoeSalarv . .' $ 59,106.25
MaxirritiinSindle Life Annultv $ 1,973.78
Years of Credited Service -. 26.2818 vrs
,,' c.-."_. ";";,,'''-;r.;/.'''-.
'Value'of Account a50f01/13/2011 (Superannuation): '.
Total Contributions and Interest. ' $ 107,321.09
, PreseritVahrE!'i\~*,;if\:~(j(,/.$ 815,217~19
Final Avera~Sala $ 60 m:-Sa
Maximuiil'Sin le~Llfe-AifriUi .. $ 4,:436.36
YeaiifbfCreclite(l SeNic's ',;; 35.0091
.Estimate. based on current annual salary. Overtime and raises cannot be projected into this
eofie"-Uest.-"'.~
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~lr\.~~n:~~jXJ!Jna.i,~\~'!;llJ)i~:i!l1f\'rr.nati~nis. .~~e~El~ . forclivor~,:p~!p-'!,~!',,~{;Ji.!:t~ci"~~f..-:~W)~P.;ffiQ~,
lrrt:o[f!layon;r.Elgarolngyour retirement account which IS mtended. for your attorneY's use ana .should.be.
iakeri'tirhTm7her~&pjease~do"not aireCtq-ueSfionsreaarainifthese'''imclosutes 'to'me:'f,1 arifhbfiilta"iid'meV}(:
I trust tl1is information is sufficient fo, you, needs. it iz your responsibility to prornpliy provide ail of this
information to your attorney.
Sincerely,
~ ~h-<--
Jane KukIish '
Regional Manager
kk
Enclosures: divinf.mem; sample DRO;
SERS-157 (2 copies for member & attorney)
cc: SERS Region active files
Scanned: Member history (DRO correspondence)
1'-'inc S'EtJ?S~ w(!ositc at .www.sers.statc.lJa.us
EXHIBIT A
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RICHARD P. LONG,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - LAW
NO. 00 - 6024 CIVIL
BARBARA A. LONG,
Defendant
IN DIVORCE
CONFERENCE WITH
COUNSEL AND PARTIES
TO: Joseph J. Dixon
Richard F. Long
, Counsel for Plaintiff
, Plaintiff
Barbara A. Long
Counsel for Defendant
, Defendant
A conference has been scheduled at the Office of
the Divorce Master, 9 North Hanover Street, Carlisle,
Pennsylvania, on the 15th day of August 2003, at 9:00 a.m.,
with counsel and the parties to discuss the outstanding
economic issues to determine if there is a basis of settlement
of claims. If issues remain after the conference, a hearing
will be scheduled at another date.
Very truly yours,
Date of Notice: 7/10/03
E. Robert Elicker, II
Divorce Master
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ATTORNEY AT LAW
126 STATE STREET. HARRISBURG, PA 17101
PHONE: (717) 233-8757 . FAX: (717) 233-5860
EMAIL: dixonlaw@paonline.com
www.dixonlaw.baweb.com
April 16, 2003
CUMBERLAND COUNTY
DOMESTIC RELATIONS
ATTENTION: DIVORCE MASTER
9 N HANOVER STREET
CARLISLE, PA 17013
Re: Long v. Long
Dear Sir/Madam:
Enclpsedl:ilease find. a Certification that Discovery is not complete on behalf of
the Plaintiff, Richard P. Long.
Very truly yours,
~
~ Joseph J. Dixon
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Enclosure (1)
c. JeffYoffe, Esquire (w/enc.)
Richard Long (w/enc.)
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DI THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Richard Po Lonq
No. 00-6024
Plaintiff CIVIL ACTION-LAW
vSo IN DIVORCE
Barbara A. Lana
Defendant NO. 19
MOTION
Richard P. Lonq
a master with respect to the
(X) Divorce
( ) Annulment
( X) Alimony
( X) Alimony Pendente
FOR APPO INTl1ENT OF MASTER
(Plaintiff) (Defendant),
following claims:
moves the court to appoint
Lite
(X)
( )
(X)
( X )
Distribution of Property
Support
Counsel Fees
Costs and Expenses
and in support of the motion states:
(1) Discovery is complete as to the claims(s) for which the
appointment of a master is requested.
(2) The defendant (has) (has not) appeared in
(by his attorney, Jeffrey Yoffe _
(3) The staturory ground(s) for divorce (is)
3301(C). 3301/Dl. 3301/1I)//;)
(4) Delete the inapplicable paragraph(s):
(a) The action is not contested.
(b) An agreement has been reached with respect to the
the action (personally)
,Esquire) .
(are)
following claims:
claims :
(c) The action is contested with respect to the following
All pendinq claims
(5) The action (involves) (does not involve) complex issues of law
or fact.
(6) The hearing is expected to take 2 hours (hours) (days).
(7) Additional information, if any. relevant to the motion:
Date: ......--J ~
Attorn~r (Plaintiff)
(Defendant)
l. ORDER APPOINTING MASTER _
AND NOW /t1.~:2s ,1"9"~ P_c2"---I-,,J{"'~
is appointed master lNith respect to the following claims:
Esquire,
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RICHARD P. LONG
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-6024
VS
BARBARA A. LONG
DEFENDANT
CIVIL ACTION-LAW
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against
the claims set forth in the following pages, you must take prompt
action. You are warned that if you fail to do so, the case may
proceed without you and a decree of divorce or annulment may be
entered against you by the Court. A judgment may also be entered
against you for any other claim or relief requested in these
papers by the Plaintiff. You may lose money or property or other
rights important to you, including custody or visitation of your
children.
When the ground for the divorce is indignities or
irretrievable breakdown of the marriage, you may request marriage
counseling. A list of marriage counselors is available in the
office of the Prothonotary, Dauphin County Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE OR ANNULENT
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.
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
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RICHARD P. LONG
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-6024
VS
BARBARA A. LONG
DEFENDANT
CIVIL ACTION-LAW
IN DIVORCE
ORDER
And now, this
day of
, 2001, it
is hereby Ordered pursuant to the applicable rules of Civil Procedure,
that the Cumberland County Domestic Relations Office shall set up a
hearing through their office to issue a recommendation to the Court as
to a resolution of the claim for Alimony Pendente Lite filed by
Defendant in the above captioned action.
BY THE COURT
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RICHARD P. LONG
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-6024
VS
BARBARA A. LONG
DEFENDANT
CIVIL ACTION-LAW
IN DIVORCE
ANSWER OF BARBARA A. LONG WITH NEW MATTER AND COUNTERCLAIM
1. Admitted.
2. Admitted.
3. Admitted.
4. Admitted.
5. Denied. The parties separated on October 1, 1999.
6. Admitted.
7. Admitted.
8. Admitted.
9. Denied. Defendant did not waive her right to counseling.
10. Admitted.
11.
Denied.
The marriage is not irretrievable broken.
NEW MATTER
COUNTERCLAIM
COUNT I
CLAIM FOR COUNSEL FEES, COSTS AND EXPENSES
UNDER SECTION 3702 OF THE DIVORCE CODE
12. Defendant hereby incorporates by reference all admissions
and averments contained in Paragraphs 1-11 herein.
13. Defendant does not have sufficient funds to pay counsel
fees, costs and expenses incidental to this action.
14. Plaintiff is well able to pay Defendant's counsel costs and
expenses incidental to this matter.
~-
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15.
Defendant requests this Court to grant her counsel expenses
incidental to this action.
COUNT II
CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY
UNDER SECTION 3502 OF THE DIVORCE CODE
16. Defendant hereby incorporates by reference all of the
admissions and averments contained in Paragraphs 1-15 herein.
17. Plaintiff and Defendant are the owners of real estate,
motor vehicles, bank accounts, insurance policies, pensions,
retirement benefits and other personal property acquired during the
marriage which is subject to equitable distribution by this Court.
18. Plaintiff and Defendant have been unable to agree as to an
equitable division of said property as of the date of the filing of
this counterclaim.
19. Defendant requests this Court to equitably distribute the
parties' marital property.
COUNT III
CLAIM FOR ALIMONY PENDENTE LITE
UNDER SECTION 3702 OF THE DIVORCE CODE
20. Defendant hereby incorporates by reference all of the
admissions and averments contained in Paragraphs 1-19 herein.
21. Defendant does not have sufficient funds to support herself
during the pendency of this action.
22. Plaintiff is well able to pay support to Defendant.
23. Defendant requests this Court to grant her alimony pendente
lite.
-,
COUNT IV
CLAIM FOR ALIMONY
UNDER SECTION 3701 OP THE DIVORCE CODE
24. Defendant hereby incorporates by reference all of the
admissions and averments contained in Paragraphs 1-23 herein.
25. Defendant does not have a sufficient source of income or
earning capacity at the present time to maintain the standard of
living enjoyed by the parties during their marriage.
26. Plaintiff does have a sufficient source of income and
earning capacity to aid Defendant in maintaining the standard of
living enjoyed by the parties during their marriage.
27. Defendant requests this Court to grant her alimony.
WHEREFORE, Defendant respectfully requests this Honorable Court
to enter a Decree:
A. Equitably distributing all property owned by the
parties hereto; and
B. Directing the plaintiff to pay alimony pendente lite
to Defendant; and
C. Directing the plaintiff to pay Defendant's counsel
fees), costs and expenses incidental to this divorce
action; and
D. Granting alimony to Defendant; and
,
,-~.--
.
. .
E. For such further relief as the Court may determine to
be equitable and just.
YOFFE & YOFFE, P.C.
47
Yoffe, squire
ttorney for Barbara A. Long
214 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
,
.j,;-
RICHARD P. LONG
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-6024
VS
BARBARA A. LONG
DEFENDANT
CIVIL ACTION-LAW
IN DIVORCE
CERTIFICATE OF SERVICE
The undersigned certifies that on the date indicated below he
served a copy of the foregoing pleading on Joseph J. Dixon, Esq.
Service was accomplished by depositing the same in the United States
Mail, First Class, postage prepaid and addressed as follows:
Joseph J. Dixon, Esq.
126 State Street
Harrisburg, PA 17101
YOFFE & YOFFE, P.C.
July 16, 2001
ire
Attorney for Barbara A. Long
214 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
-
--
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RICHARD P. LONG
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-6024
VS
BARBARA A. LONG
DEFENDANT
CIVIL ACTION-LAW
IN DIVORCE
VERIFICATION
I hereby state that I am an adult individual who is authorized
to make this verification and that the facts set forth in the foregoing
response are true to the best of my knowledge, information, and belief.
I understand that false statements herein are made subject to the
penal ties of 18 Pa. C:S. .~4904 relating to unsworn falsification to
authorities.
Dated:
~
BARBARA A. LONG
o
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OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240-6535
E. Robert Elicker, II
Divorce Master
Traci .10 Colyer
Office Manager/Reporter
West Shore
697-0371 Ex!. 6535
May 30,2003
Joseph J. Dixon
Attorney at Law
126 State Street
Harrisburg, PA 17101
Jeffrey N. Yoffe
Attorney at Law
214 Senate Avenue, Suite 203
Camp Hill, PA 17011
RE: Richard P. Long vs. Barbara A. Long
No. 00 - 6024 Civil
In Divorce
Dear Mr. Dixon and Mr. Yoffe:
Mr. Dixon has indicated in the certification document that
discovery is not complete and that he needs to have pension information
from the Defendant. However, since we have not heard from Mr. Yoffe
regarding the status of discovery, I am going to proceed with a directive
for pretrial statements.
The divorce complaint was filed on August 31,2000, raising
grounds for divorce of irretrievable breakdown of the marriage. An
affidavit was fIled by the Plaintiff on February 5, 2001, averring
separation since August 19, 1998. The Defendant filed a counter-
affidavit and an answer with new matter and counterclaim. The
Defendant raised the claims for equitable distribution, alimony, alimony
pendente lite, and counsel fees, costs, and expenses.
Apparently, the Defendant needs to provide information to the
Plaintiff regarding her pension. That should be accomplished by the time
that the pretrial statements are due so that that information can be
included on the pretrial statements for purposes of discussion at the pre-
hearing conference.
,--
"
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Mr. Dixon and Mr. Yoffe, Attorneys at Law
30 May 2003
Page 2
In accordance with P.R.C.P. 1920.33(b) I am directing each counsel
to me a pretrial statement on or before Monday, June 23, 2003. Upon
receipt of the pretrial statements, I will immediately schedule a pre-
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 the 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.
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RICHARD P. LONG,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00 - 6024 CIVIL
BARBARA A. LONG,
Defendant
IN DIVORCE
TO: Joseph J. Dixon
, Attorney for Plaintiff
Jeffrey N. Yoffe , Attorney for Defendant
DATE: Wednesday, April 2, 2003
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
- ~ -~
-
..
-, '~-- - -', -,
.
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
The Plaintiff has not yet received documentation
from the Defendant concerning the value of her pension
plan she had with Giant Food stores. It is requested
that the Defendant be ordered to turn over that infor-
mation to councel.
'1/(fl?f~
DATE
CO~F
COUNSEL FOR DEFENDANT
(Xl
( )
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.
2E~',"':iLi""'-<f~~ '" '.
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.
RICHARD P. LONG
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
BARBARA A. LONG
CIVIL ACTION - LAW
00 - 6024
NO.
CIVIL
19
IN DIVORCE
Defendant
STATUS SHEET
DATE:
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ACTIVITIES:
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RICHARD P. LONG,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00 - 6024 CIVIL
BARBARA A. LONG,
Defendant
IN DIVORCE
TO: Joseph J. Dixon
, Attorney for Plaintiff
Jeffrey N. Yoffe , Attorney for Defendant
DATE: Wednesday, April 2, 2003
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
"'
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.
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
DATE
COUNSEL FOR PLAINTIFF
COUNSEL FOR DEFENDANT
NOTE:
PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
~ .
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
RICHARD. WNGr ) Docket Number 2.0.0.0-6.024 CiiVIL
Plaintiff !Respondent )
VS. ) PACSES Case Number 472104026
BARmiRAi WNG' )
DefendantlPeti tioner ) Other State ID Number
ORDER
AND NOW, to wit on this 2ND DAY OF SEPTEMBER, 2004
IT IS HEREBY
ORDERED that the 0 Complaint for Support or (i) Petition to Modify or 0 Other
filed on
JULY 7, 2004
in the above captioned
matter is dismissed without prejudice due to:
THE DOMESTIC RELATIONS SECTION HAVING NO JURISDICTION OF AN ALIMONY MATTER.
o The Complaint or Petition may be reinstated upon written application of the plaintiff
petitioner.
DRO: RJ Shadday
xc: plaintiff
defendant
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Plaintiff
: IN TIffi COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION
Barbara .... Long
VS
Richard P. Long
Defendant
: NO.
Docket N1.ID1ber
00-6024 CIVIL
P-"CSES Case Number 472104026
Other State ID Number RS
ORDER OF COURT
AND NOW, this _ day of
20~, the foregoing petition is ordered f1!ed
and a private hearing thereon is fixed for
, 2000, at
in
Courtroom No.
of the Courthouse in Carlisle, Pennsylvania,
BY TIffi COURT,
Judge
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
BARBARA A. LONG ) Docket Number 00-6024 CIVIL
Plaintiff )
VS, ) PACSES Case Number 472104026
RICHARD P. LONG )
Defendant ) Other State lD Number RS
PETITION FOR MODIFICATION
OF AN EXISTING SUPPORT ORDER
1. The petition of
RICHARD PHARRIS LONG
respectfully
represents that on JULY 22, 2002
, an Order of Court was entered for the
support of
BARBARA ANNE LONG
A true and correct copy of the order is attached to this petition.
Service Type M
Form OM-501
Worker lD 21503
~ I
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,. .
LONG
v. LONG
PACSES Case Number: 472~04026
"'2. Petitioner is entitled to 0 increase G9 decrease 0 termination 0 reinstatement
o other of this Order because of the following material and substantial change(s) in
circumstance:
'" Husband agrees to pay alimony tbrough the date of his retirement
f'rom +1-\,::. rf""m1mnnb1t::>~1+-h of' Pt::>nnc;:yhT;!tn;~ +-0 +l.:1e O:;-+-E;> he 001jpS to r.ecei'J:TQ
monthlY retirement payments. Currently, Husband aarees to pa:v $570.00
per IlIOllth in alimony, \-Ihich ".>,ill be effective July 1, 2QQJ, throu"fh
,Tnly 1 200'4 ThprPnft-pr. tJu::~_ Alimnny will hP rp-j:::~I"'rrtl11.:=l+-pn ny t-hp
Domestic Relations Office on a yearly basis.
Substantial cbanqe (s) in cirCLlIllStance: Husband desires to reduce
the amount of over-time hours worked due to physical health issues.
'\no. cnTrent monthly p.>(pPJ1"es have jnCTp.aSp.o.
WHEREFORE, Petitioner requests that the Court modify the existing order for support.
"-.J.
Petitioner
ttorney for Petitioner
I yerify that the statements made in this complaint are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to
unsworn falsification to authorities.
--.j. q~q~O'-/
Date
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Petitioner
Page 2 of 2
Form OM-50 I
Worker ID 2~503
Service Type M
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Barbara '\, Long
VS
Richard p, Long
Plaintiff
Defendant
AND NOW, this _ day of
Courtroom No,
and a private hearing thereon is fixed for
of the Courthouse in Carlisle, Pennsylvania.
Ifu:l' '"'~,"-
SEP 1 0 2U041V
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION
: NO.
Docket Number
00-6024 CIVIL
P'\CSES Case Number 472104026
Other State ID Number RS
ORDER OF COURT
20_, the foregoing petition is ordered med
, 2000, at
in
BY THE COURT,
Judge
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
BARBARA A. LONG ) Docket Number 00-6024 CIVIL
Plaintiff )
VS. ) PACSES Case Number 472104026
RICHARD P. LONG )
Defendant ) Other State ID Number RS
PETITION FOR MODIFICATION
OF AN EXISTING SUPPORT ORDER
1. The petition of
RICHARD PHARRIS LONG
respectfully
represents that on JuLY 22, 2002
, an Order of Court was entered for the
support of
BARBARA ANNE LONG
A true and correct copy of the order is attached to this petition.
Service Type M
Form OM-50l
Worker ID 21503
,~~
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. '
LONG
V. LONG
PACSES Case Number: 472104026
'-"2. Petitioner is entitled to 0 increase G9 decrease 0 termination 0 reinstatement
o other of this Order because of the following material and substantial change(s) in
circumstance:
'--s Husband agrees to pay alimony through the date of his retirement
frf"\TTl i-hc:> rnTllTlf"'l1ThTCil.::llt-n f"'If PClormc:yl...,::!,n;Q to the Og+e he OO'Jjl1fiii +0 rec@iJTQ
monthlY retirement payments. Currently, Husband aqrees to paY $570.00
pgr JIIOHth iF! alimoRy, "'Rich \'.>ill bo offocti'JO July 1, 2()()3, throo"l'h
lTnly 1 _ ./.004 ThprPFlf+pr. +hp ;::)1 imnny wi 11 hI=' rp-PVril11rlrl='n hy +hp
Domestic Relations Office on a yearly basis.
j,.
Substantial chanqe (s) in circumstance: Husband desires to reduce
the amount of over-time hours worked due to physical health issues.
1\nd, current monthly "~.n"e" have incr""""d.
WHEREFORE, Petitioner requests that the Court modify the existing order for support.
.'
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Petitioner
I yerify that the statements made in this complaint are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa. e.S. ~ 4904 relating to
unsworn falsification to authorities.
.~.
---.J-
Date
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Page 2 of 2
Form OM-50 I
Worker 10 21503
Service Type M
)
Barbara '\. Long
Plaintiff
VS
Richard P. Long
Defendant
, ~ '.
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, ,
SEf' 1 0 2004
: IN TIIE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION
\P
: NO.
Docket NlIDIber 00-6024 CIVIL
P'\CSES Case Number 472104026
Other State ID Number as
ORDER OF COURT
20_, 1he foregoing petition is ordered med
AND NOW, this _ day of
and a private hearing 1hereon is fJXed for
Courtroom No.
, 2000, at
in
of1he Courthouse in Carlisle, Pennsylvania.
BY TIIE COURT,
Judge
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
BARBARA A. LONG ) Docket Number 00-6024 CIVIL
Plaintiff )
VS. ) PACSES Case Number 472104026
RICHARD P. LONG )
Defendant ) Other State 10 Number RS
PETITION FOR MODIFICATION
OF AN EXISTING SUPPORT ORDER
1. The petition of
RICHARD PHARRIS LONG
respectfully
represents that on JULY 22, 2002
, an Order of Court was entered for the
support of
BARBARA ANNE LONG
A true and correct copy of the order is attached to this petition.
Service Type M
Form OM,501
Worker ID 21503
<<
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/' .
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LONG
V. LONG
PACSES Case Number: 472104026
"'-'2. Petitioner is entitled to 0 increase G9 decrease 0 termination 0 reinstatement
o other of this Order because of the following material and substantial change(s) in
circumstance:
'" Husband agrees to pay alimony throuqh the date of his retirement
f'rrm The:. rrmm,",nwt::l.::!lf-h r"\r pt;:)nT'lc::yl\T~ni;!l "'0 ....ht::l Q~+,:o. h~ OOl)in'S to recei'~Te
1IlDnthly retirement pavments. Currently, Husband aqrees to pay $570.00
per month in alimony, wbich will bo effeotive Ju.ly 1, 2QQ3, tllrOU'l'h
11111 Y 1. 200'4 ~ Tl-u:::'YPnft-pr t-l1P PI 1 ; mnny wi 11 hP rp.-p"i.TFll11;::lTPn hy +-h.:::.
Domestic Relations Office on a yearly basis.
Substantial chanqe (s) in circumstance: Husband desires to reduce
the amount of over-time hours worked due to physical health issues.
'\nd. cllrrent monthly "~nse" MV" incY:""a""cJ.
WHEREFORE, Petitioner requests that the Court modify the existing order for support.
" ~~ ~ Attnnw, fm P,titi_
j~c'
I verify that the statements made in this complaint are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to
unsworn falsification to authorities.
---.}. 9:..,., 1-17'1
Date
~ U/J-i-
Petitioner . <
Page 2 of2
Form OM,501
Worker ID 21503
Service Type M
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--,.'-,-,
BARBARA A. LONG,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
RICHARD P. LONG,
DEFENDANT
00-6024 CIVIL TERM
ORDER OF COURT
AND NOW, this
z.,\
day of November, 2004, a hearing on the
petition of Richard P. Long to modify alimony shall be conducted in Courtroom Number
2, Cumberland County Courthouse, at 1 :30 p.m., ThursdaY,j:.ebrua ,2005.
.,/
By tha--C~urt,
//
/
Aarbara A. Long
335 9th Street
New Cumberland, PA 17070
~ichard P. Long, Pro se
3029 Locust Street
Harrisburg, PA 17109
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CUt,/[:L::'-;~/\"-~~j COUNTY
PENNSYLYANiA
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
BARBARA A. LONG ) Docket Number 00-6024 CIVIL
Plaintiff )
VS. ) PACSES Case Number 472104026
RICHARD P. LONG )
Defendant ) Other State 1D Number RS
PETITION FOR MODIFICATION
OF AN EXISTING SUPPORT ORDER
l. The petition of
RICHARD PHARRIS LONG
respectfully
represents that on JuLY 22, 2002
~L"f1~1J'f
S'IM @R of
BARBARA ANNE LONG
, an Order of Court was entered for the
A true and correct copy of the order is attached to this petition.
Service Type M
Form OM,501
Worker 1D 21503
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LONG
PACSES Case Number: 472104026
V. LONG
"-'2. Petitioner is entitled to 0 increase G9 decrease 0 termination 0 reinstatement
o other of this Order because of the following material and substantial change(s) in
circumstance:
'-.J Husband agrees to pay al:ilnony through the date of his retirement
frf"\1l'l +he ('lrmmt"'lnt.7~:::.1+-h I'"'\r P~nnC!ylu:::..n;~ ""0 +he O<7te> hell nel)ins +-0 recej'tTe
monthlY retirement payments. Currently. Husband aqrees to pay $570.00
per month in aliIlloo.y. which will bo effectiyo .July 1, 2()():!, throU<;Jh
lTnly 1 200'4 T'hF>rp':r.ifrpr t-hp r.il imnny wi 11 'hP rp;"pvFl111:::lrpn hy t-hp
Domestic Relations Office on a yearly basis.
Substantial chanqe (s) in cirCillllStance: Husband desires to reduce
the amount of over-time hours worked due to physical health issues.
1\nc1. current monthly ".JQ?Pn"",,, hi'lve ;ncr",i'l""'c1.
WHEREFORE, Petitioner requests that the Court modify the existing order for support.
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Petitioner
Attorney for Petitioner
I verify that the statements made in this complaint are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to
unsworn falsification to authorities.
---.J-
Date
~p~ /2,'4
Page 2 of2
Form OM-50l
Worker 1D 21503
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BARBARA A. LONG,
PLAINTIFF
V.
RICHARD P. LONG,
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
00-6024 CIVIL TERM
ORDER OF COURT
AND NOW, this
Lf/t--
day of February, 2005, the petition of
defendant, Richard P. Long, to modify alimony, IS DENIED.1
By ~ourt,
&bara A. Long, Pro se
238 Walnut Street
Apt. 2
Lemoyne, PA 17043
vRlchard P. Long, Pro se
3029 Locust Street
Harrisburg, PA 17109
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1 Defendant contractually agreed to pay alimony to plaintiff in a written marital
settlement agreement dated September 16, 2003. The agreement provides for a
reevaluation on a yearly basis, Since alimony was commenced, plaintiff's
earnings have not increased, and her needs have not declined. Defendant's
base earnings have increased. While he has incurred some debt, he is not
paying any marital debt. While we understand the desire of defendant to cut
back his mostly voluntary overtime, it is the base earnings of the parties and their
circumstances at the time of the agreement that forms the backdrop to the
question of whether there has been a change in circumstances of a substantial
and continuing nature to warrant changing the alimony. There has been none,
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BARBARA A. LONG,
PLAINTIFF
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
RICHARD p, LONG,
DEFENDANT
00-6024 CIVIL TERM
ORDER OF COURT
AND NOW, this
1-1\.
day of November, 2004, a hearing on the
. petition of Richard P. Long to modify alimony shall be conducted in Courtroom Number
2, Cumberland County Courthouse, at 1 :30 p.m., ThurSd9brua ." , 2005.
/'
By the'Cou rt,
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Barbara A. Long
335 9th Street
New Cumberland, PA 17070
~
Richard P. Long, Pro se
3029 Locust Street
Harrisburg, PA 17109
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LONG
V. LONG
PACSES Case Number: 472104026
'-"2. Petitioner is entitled to 0 increase G9 decrease 0 termination 0 reinstatement
o other of this Order because of the following material and substantial change(s) in
circumstance:
'--' Husband agrees to pay alimony through the date of his retirement
f'rnm t-hA ("r'mmf'"lnu.7A~1t-n of' pp.nnc:::yl"'7::!ni~'+-r, tnp. ~~+,::. h$ ooiJ;in5! to.n:~cej'Ue
monthly retirement pavments. CurrentlY. Husband aqrees to pay $570.00
par lI10Rth in alimony, ','hiGh '.7ill sa affaoth'c July 1, 2QQ3, through
,In1y 1 ::WO'4 'J'hF''''F'"ft-RL t-h.. ,,1 irnnny wi 11 hi> rF'-F'""ln"t-F'r'l hy t-nF'
Domestic Relations Office on a yearly basis.
Substantial chanqe (s) in cirClIDlStance: Husband desires to reduce
the amount of over-time hours worked due to physical health issues.
"JJd. cnrrent monthly ",~..nses have increased.
WHEREFORE, Petitioner requests that the Court modify the existing order for support.
"-.J
Petitioner
Attorney for Petitioner
I verify that the statements made in this complaint are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S. !l 4904 relating to
unsworn falsification to authorities.
---.}.
Date
~ .f2Lt ;2.~
Petitioner '
Page 2 of2
Form OM,501
Worker ID 21503
Service Type M
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Diane S. Baker, Esquire
J.D. No. 53200
27 South Arlene Street
P.O. Box 6443
Harrisburg, PA 17112-0443
(717) 671-9600
RICHARD P. LONG,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-6024
BARBARA A. LONG,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
PRAECIPE TO WITHDRAW APPEARANCE
Please withdraw the appearance of Joseph J. Dixon, Esquire, on behalf ofthe
Plaintiff, Richard P. Long, in the above captioned action.
By
eph J. Dixon, Esquire
126 State Street
Harrisburg, P A 17101
(717) 975-1838
PRAECIPE FOR ENTRY OF APPEARANCE
PLEASE enter of the appearance of Diane S. Baker, Esquire, on behalf of the
Plaintiff, Richard P. Long, in the above-captioned action.
lane S. Baker, Esquire
27 South Arlene Street
P.O. Box 6443
Harrisburg, P A 17112
(717) 671-9600
ID# 53200
DATE: ,J-q-OCo
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENN~~~cc~. ....
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Richard P. Long
Plaintiff
CIVIL ACTION -LAW
IN DNORCE
VS.
Barbara A. Long
Defendant
NO. 00-6024
STIPULATION FOR THE ENTRY OF "DOMESTIC RELATIONS ORDER"
AND NOW, this I S-IA day of /h/li , '2-00 t ,the parties, Richard P.
Long, Plaintiff and Barbara A. Long, Defendant, do hereby Agree and Stipulate as follows:
1. The Plaintiff, Richard P. Long (hereinafter referred to as "Member") is a member of the
Co=onwealth 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. ~~5101-5956 ("Retirement Code").
3. Member's date of birth is January 26,1954, and his Social Security number is 202-42-
7423.
4. The Defendant, Barbara A. Long (hereinafter referred to as "Alternate Payee") is the
former spouse of Member. Alternate Payee's date of birth is May 25,1954, and her Social Security
number is 355-50-0905.
5, Member's last known mailing address is:
3029 Locust Street
Harrisburg, PA 17109
6. Alternate Payee's current mailing address is:
238 Walnut Street, Apt. 2
Lemoyne, PA 17043
"
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Page 2
It is the responsibility of Alternate Payee to keep a current mailing address on file with
SERS at all times.
7. (a) The marital property component of Member's retirement benefit equals (1) the
coverture fraction multiplied by (2) the Member's retirement benefit accrued on October 1, 1999,
based upon the final average salary as of October 1, 1999, and based upon the years of service
under SERS as of October 1, 1999, and calculated in accordance with the Retirement Code in
effect on the date benefits co=ence to the Member.
(b) 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
August 18, 1972 (the date of marriage) to October 1, 1999 (the date of separation). The
denominator is the total amount of Member's service, as defined by SERS, on October 1,1999 (the
date of separation).
(c) The portion of the marital property component of Member's retirement benefit to
be allocated to the Alternate Payee as her equitable distribution portion of this marital asset is
50%.
8. Member's retirement benefit is the Maximum Single Life Annuity, as defined in 71 Pa.
C.S. g5702(a) (without regard to any reduction to reflect the election of any option in accordance
with 71 Pa. C.S. g5705) including any scheduled or ad hoc increases, but excluding the disability
portion of any disability annuities paid to Member by SERS as a result of a disability which
occurred 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. The equitable distribution portion of the marital property
component of Member's retirement benefit, as set forth in Paragraph 7 after the application of the
appropriate early retirement reduction factor, if any, 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.
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Page 3
9. 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, if the Member dies before the effective date of his retirement. This
nomination shall become effective upon approval by the Secretary of the Retirement Board, or his
authorized representative, of any Domestic Relations Order incorporating this Stipulation and
Agreement. The balance of any death benefit remaining after the allocation of Alternate Payee's
equitable distribution portion ("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.
(a) 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: (1) 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 Alternate Payee's estate.
(b) 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. Alternate Payee shall
deliver the authorization to SERS which will allow the Alternate Payee to check that she has been
and continues to be properly nominated under this Paragraph 9 and its subparts.
10. The term and amounts of Member's retirement benefits payable after SERS approves a
Domestic Relations Order incorporating this Stipulation and Agreement and after the Member
files a retirement application shall be in accordance with Paragraphs 10(a), 10(b) and 10(c) as
follows:
(a) Member may elect to receive, by lump sum, all or a portion of his accumulated
deductions.
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The portion ofthe accumulated deductions to be paid to the Alternate Payee or to
her estate, shall be determined by multiplying (1) by (2) by (3) by (4) where (1), (2), (3) and (4) are
as follows:
(1) Accumulated deductions on October 1, 1999, accumulated with interest at
the statutory rate (currently 4% per annum) compounded annually from October 1, 1999, until the
effective date of Member's retirement.
(2) The coverture fraction (pursuant to Paragraph 7(b)).
(3) 50%.
(4) Ratio obtained by dividing amount of accumulated deductions the Member
elects to receive by the total amount of his accumulated deductions on the effective date of
Member's retirement.
(b) (i) If Alternate Payee is living, the exceSS of the present value of the equitable
distribution portion of the Member's retirement benefit (based upon a maximum single life
annuity) assigned to the Alternate Payee over the portion of the accumulated deductions paid to
the Alternate Payee (pursuant to Paragraph IO(a)) shall be used to provide the Alternate Payee
with an annuity payable to her as long as she liVes. The Alternate Payee shall share in any
scheduled or ad hoc increases to the extent of her equitable distribution portion of the Member's
benefit.
(b) (ii) If Alternate Payee is not living, the excess of the present value ofthe
equitable distribution portion of the Member's retirement benefit (based upon a maximum single
life annuity) assigned to the Alternate Payee over the portion of the accumulated deductions paid
to the Alternate Payee's estate (pursuant to Paragraph IO(a)) shall be used to provide the
Alternate Payee's estate with an annuity (maximum single life) payable as long as the Member
lives. The Alternate Payee's estate shall share in any scheduled or ad hoc increases to the extent
of the Alternate Payee's equitable distribution portion of the Member's benefit.
.
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Page 5
(c) The eXCess of the present value ofthe Member's retirement benefit (based upon a
maximum single life annuity) OVer any accumulated deductions paid to the member under
Paragraph 10(a) and OVer the present value of the equitable distribution portion of the Member's
benefit assigned to the Alternate Payee shall be used to provide the Member with an annuity
based upon the retirement option selected by the Member.
11. 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.
12. In the event of the death of Alternate Payee, any death benefit payable to Alternate
Payee by SERS by reason of the Member's death before the effective date of his retirement shall
be paid to Alternate Payee's estate to the extent of Alternate Payee's equitable distribution
portion of Member's retirement benefit.
13. In no event shall Alternate Payee have greater benefits or rights other than those
which are available to Member. Alternate Payee is not entitled to any benefit not otherwise
provided by SERS. The Alternate Payee is only entitled to the specific benefits offered by SERS as
provided in this Order. All other rights, privileges and options offered by SERS not granted to
Alternate Payee by this Order are preserved for Member.
14. It is specifically intended and agreed by the parties hereto that this Order:
(a) Does not require SERS to provide any type or form 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 ofliving or
increases based on other than actuarial values.
15. The parties intend and agree that the terms of this Stipulation and Agreement shall be
approved, adopted and entered as a Domestic Relations Order.
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16. 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 no such amendment shall require SERS to provide any type or
form of benefit, or any option not otherwise provided by SERS, and further provided that no such
amendment or right of the Court to so amend will invalidate this existing Order.
17. Upon entry as a Domestic Relations Order, a certified copy of the Domestic Relations
Order and this Stipulation and Agreement and any attendant documents shall be served upon
SERS immediately. The Domestic Relations Order shall take effect i=ediately upon SERS
approval and SERS approval of any attendant documents and then shall remain in effect until
further Order ofthe Court.
WHEREFORE, the parties, intending to be legally bound by the terms of this
and Agreement, do hereunto place their hands and seals. ___
BYT
5/;:S/tk
Judge
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Date
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Defendant/Alternate Payee
Date
yofft a~ Vt/f~ ;: (,
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ttorney for Defendant/
Alternate Payee
Date
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BARBARA A. LONG,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
RICHARD P. LONG,
DEFENDANT
00-6024 CIVIL TERM
ORDER OF COURT
AND NOW, this
t..'\
day of November, 2004, a hearing on the
petition of Richard P. Long to modify alimony shall be conducted in Courtroom Number
2, Cumberland County Courthouse, at 1 :30 p,m" Thursday, ~rua ;3, 2005,
" ;
~
Edgar 8,
Aarbara A. Long
335 9th Street
New Cumberland, PA 17070
~ichard p, Long, Pro se
3029 Locust Street
Harrisburg, PA 17109
,
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AU\ilC~;' ,~();-L!.Ced 3;~1 jO
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
BARBARA A. LONG ) Docket Number 00-6024 CIVIL
Plaintiff )
vs. ) P ACSES Case Number 472104026
RICHARD P. LONG )
Defendant ) Other State ID Number RS
PETITION FOR MODIFICATION
OF AN EXISTING SUPPORT ORDER
1. The petition of
RICHARD PHARRIS LONG
respectfully
represents that on JULY 22, 2002
/JL1#10IJ4(
SUM!! ON of
BARBARA ANNE LONG
, an Order of Court was entered for the
A true and correct copy of the order is attached to this petition.
Service Type M
Form OM-50 I
Worker ID 21503
LONG
V. LONG
PACSES Case Number: 472104026
"2. Petitioner is entitled to 0 increase G9 decrease 0 temlination 0 reinstatement
o other of this Order because of the following material and substantial change(s) in
circumstance:
"-' Husband agrees to pay alimony through the date of his retirement
fron t-hE' C'()TTTTl()rn..1p;:!lt-h of PE'nnsyluonia to the date he be']ins to receipe
monthly retirement pavments. Currently, Husband agrees to pay $570.00
per J:OC)nth in a.l.iroc>ny, which. '.viU be effocti~J{) July 1, 2003, through
J1l1y 1. 2004. ThArp.nft-p.r~ thp. nlimnny will hP. n"-p.vnllli'lt-pn hy t-hp.
Domestic Relations Office on a yearly basis.
Substantial chanqe (s) in circumstance: Husband desires to reduce
the amount of over-time hours worked due to physical health issues.
'l\nd. current monthly expenses have increased.
WHEREFORE, Petitioner requests that the Court modify the existing order for support.
'-.t
Petitioner
Attorney for Petitioner
I verify that the statements made in this complaint are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to
unsworn falsification to authorities.
~,
Date
r2tL~~
"-I ' ).
Petitioner '
Page 2 of 2
Form OM-50l
Worker ID 21503
Service Type M
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BARBARA A. LONG,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
RICHARD P. LONG,
DEFENDANT
00-6024 CIVIL TERM
ORDER OF COURT
AND NOW, this
Lf/t--
day of FebrualY, 2005, the petition of
defendant, Richard P. Long, to modify alimony, IS DENIED.1
~bara A. Long. Pro se
238 Walnut Street
Apt. 2
Lemoyne, PA 17043
.Atchard P. Long, Pro se
3029 Locust Street
Harrisburg, PA 17109
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I Defendant contractually agreed to pay alimony to plaintiff in a written marital
settlement agreement dated September 16, 2003. The agreement provides for a
reevaluation on a yearly basis. Since alimony was commenced, plaintiff's
earnings have not increased, and her needs have not declined. Defendant's
base earnings have increased. While he has incurred some debt, he is not
paying any marital debt. While we understand the desire of defendant to cut
back his mostly voluntary overtime, it is the base earnings of the parties and their
circumstances at the time of the agreement that forms the backdrop to the
question of whether there has been a change in circumstances of a substantial
and continuing nature to warrant changing the alimony. There has been none.
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BARBARA A. LONG,
PLAINTIFF
V.
RICHARD P. LONG,
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
00-6024 CIVIL TERM
EDGAR B, BAYLEY_ (,c--t:
JUDGE .re) , C"
1 COURTHOUSE SQUARE L' ^ !"\Q/ ", L)->
CARLISLE, PENNSYLVANIA 17013-3387 ){6. 0 ( ~~,i.. (;l.(
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Barbara A. long ')
335 9th Street
New Cumberland. PA 17070
OAG 0 JIOSUFFICIENT ADDRESS ~
G<l'ATTEMPTED NOT KNOWN 0 OTHER "
o NO SUCH NUMBER! STREET
S . 0 NOT DELIVERABLE AS ADDRESSED
. UNABLE TO FORWARD . . . '.
i 707!)-\- \'~Q~-:-;j-;;'5:!.,:,~'4':? 1,11l111.1lI1111111l1l1l1l.1I111l,"1.11111,Ull.11I1.111
Diane S. Baker, Esqnire
1.0. No. 53200
27 South Arlene Street
P.o. Box 6443
Harrisburg, PA 17112-0443
(717) 671-9600
RICHARD P. LONG,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-6024
BARBARA A. LONG,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE TO WITHDRAW APPEARANCE
Please withdraw the appearance of Joseph J. Dixon, Esquire, on behalf of the
Plaintiff, Richard p, Long, in the above captioned action,
By
eph J. Dixon, Esquire
126 State Street
Harrisburg, PA 17101
(717) 975-1838
PRAECIPE FOR ENTRY OF APPEARANCE
PLEASE enter of the appearance of Diane S. Baker, Esquire, on behalf of the
P"".tiff, ItiohMd P. Long, i. <h, 'bo.""'ti:~.~O"_+. / ~~
b'~
By /;/
;- lane S. Baker, Esquire
27 South Arlene Street
P,O. Box 6443
Harrisburg, PA 17112
(717) 671-9600
DATE: .J-q-oto ID#53200
"
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. JUN 0 9 Z006
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENN~~~IA__F--=
Richard P. Lone:
Plaintiff
CIVIL ACTION - LAW
IN DIVORCE
VS.
Barbara A. Long
Defendant
NO. 00-6024
STIPULATION FOR THE ENTRY OF "DOMESTIC RELATIONS ORDER"
AND NOW, this 151/' day of /f1/1.i , Uo t , the parties, Richard P.
Long, Plaintiff and Barbara A. Long, Defendant, do hereby Agree and Stipulate as follows:
1. The Plaintiff, Richard P. Long (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. ~~5101-5956 ("Retirement Code").
3. Member's date of birth is January 26,1954, and his Social Security number is 202-42-
7423.
4. The Defendant, Barbara A. Long (hereinafter referred to as "Alternate Payee") is the
former spouse of Member. Alternate Payee's date of birth is May 25, 1954, and her Social Security
number is 355-50-0905,
5. Member's last known mailing address is:
3029 Locust Street
Hancisburg,PA 17109
6. Alternate Payee's current mailing address is:
238 Walnut Street, Apt. 2
Lemoyne,PA 17043
DRO
Page 2
It is the responsibility of Altemate Payee to keep a current mailing address on file with
SERS at all times.
7. (a) The marital property component of Member's retirement benefit equals (1) the
coverture fraction multiplied by (2) the Member's retirement benefit accrued on October 1, 1999,
based upon the final average salary as of October 1, 1999, and based upon the years of service
under SERS as of October 1, 1999, and calculated in accordance with the Retirement Code in
effect on the date benefits commence to the Member.
(b) 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
August 18, 1972 (the date of marriage) to October 1, 1999 (the date of separation). The
denominator is the total amount of Member's service, as defined by SERS, on October 1, 1999 (the
date of separation).
(c) The portion of the marital property component of Member's retirement benefit to
be allocated to the Alternate Payee as her equitable distribution portion of this marital asset is
50%.
8. Member's retirement benefit is the Maximum Single Life Annuity, as defined in 71 Pa.
C.S. ~5702(a) (without regard to any reduction to reflect the election of any option in accordance
with 71 Pa. C.S. ~5705) including any scheduled or ad hoc increases, but excluding the disability
portion of any disability annuities paid to Member by SERS as a result of a disability which
occurred before Member's marriage to Alternate Payee or after the date of Member's and Altemate
Payee's final separation. Member's retirement benefit does not include any deferred compensation
benefits paid to Member by SERS. The equitable distribution portion of the marital property
component of Member's retirement benefit, as set forth in Paragraph 7 after the application of the
appropriate early retirement reduction factor, if any, 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.
" , ,..
DRO
Page 3
9. 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, if the Member dies before the effective date of his retirement. This
nomination shall become effective upon approval by the Secretary of the Retirement Board, or his
authorized representative, of any Domestic Relations Order incorporating this Stipulation and
Agreement. The balance of any death benefit remaining after the allocation of Alternate Payee's
equitable distribution portion ("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.
(a) 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: (1) the terms ofthe 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 Alternate Payee's estate.
(b) 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. Alternate Payee shall
deliver the authorization to SERS which will allow the Alternate Payee to check that she has been
and continues to be properly nominated under this Paragraph 9 and its subparts.
10, The term and amounts of Member's retirement benefits payable after SERS approves a
Domestic Relations Order incorporating this Stipulation and Agreement and after the Member
files a retirement application shall be in accordance with Paragraphs 10(a), 10(b) and 10(c) as
follows:
(a) Member may elect to receive, by lump sum, all or a portion of his accumulated
deductions.
. . ,
DRO
Page 4
The portion of the accumulated deductions to be paid to the Alternate Payee or to
her estate, shall be determined by multiplying (1) by (2) by (3) by (4) where (1), (2), (3) and (4) are
as follows:
(1) Accumulated deductions on October 1, 1999, accumulated with interest at
the statutory rate (currently 4% per annum) compounded annually from October 1, 1999, until the
effective date of Member's retirement.
(2) The coverture fraction (pursuant to Paragraph 7(b)).
(3) 50%.
(4) Ratio obtained by dividing amount of accumulated deductions the Member
elects to receive by the total amount of his accumulated deductions on the effective date of
Member's retirement.
(b) (i) If Alternate Payee is living, the excess of the present value of the equitable
distribution portion of the Member's retirement benefit (based upon a maximum single life
annuity) assigned to the Alternate Payee over the portion of the accumulated deductions paid to
the Alternate Payee (pursuant to Paragraph 10(a)) shall be used to provide the Alternate Payee
with an annuity payable to her as long as she lives. The Alternate Payee shall share in any
scheduled or ad hoc increases to the extent of her equitable distribution portion of the Member's
benefit,
(b) (ii) If Alternate Payee is not living, the excess of the present value of the
equitable distribution portion of the Member's retirement benefit (based upon a maximum single
life annuity) assigned to the Alternate Payee over the portion of the accumulated deductions paid
to the Alternate Payee's estate (pursuant to Paragraph 10(a)) shall be used to provide the
Alternate Payee's estate with an annuity (maximum single life) payable as long as the Member
lives. The Alternate Payee's estate shall share in any scheduled or ad hoc increases to the extent
of the Alternate Payee's equitable distribution portion of the Member's benefit.
. 411 I - ...
DRO
Page 5
(c) The excess ofthe present value of the Member's retirement benefit (based upon a
maximum single life annuity) over any accumulated deductions paid to the member under
Paragraph 10(a) and over the present value of the equitable distribution portion of the Member's
benefit assigned to the Alternate Payee shall be used to provide the Member with an annuity
based upon the retirement option selected by the Member.
11. 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.
12. In the event of the death of Alternate Payee, any death benefit payable to Alternate
Payee by SERS by reason of the Member's death before the effective date of his retirement shall
be paid to Alternate Payee's estate to the extent of Alternate Payee's equitable distribution
portion of Member's retirement benefit.
13. In no event shall Alternate Payee have greater benefits or rights other than those
which are available to Member. Alternate Payee is not entitled to any benefit not otherwise
provided by SERS. The Alternate Payee is only entitled to the specific benefits offered by SERS as
provided in this Order. All other rights, privileges and options offered by SERS not granted to
Alternate Payee by this Order are preserved for Member.
14. It is specifically intended and agreed by the parties hereto that this Order:
(a) Does not require SERS to provide any type or form 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 ofliving or
increases based on other than actuarial values.
15. The parties intend and agree that the terms of this Stipulation and Agreement shall be
approved, adopted and entered as a Domestic Relations Order.
. .
, ,.. t . ...
DRO
Page 6
16. 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 no such amendment shall require SERS to provide any type or
form of benefit, or any option not otherwise provided by SERS, and further provided that no such
amendment or right of the Court to so amend will invalidate this existing Order.
17. Upon entry as a Domestic Relations Order, a certified copy of the Domestic Relations
Order and this Stipulation and Agreement and any attendant documents shall be served upon
SERS immediately. The Domestic Relations Order shall take effect immediately upon SERS
approval and SERS approval of any attendant documents and then shall remain in effect until
further Order of the Court.
WHEREFORE, the parties, intending to be legally bound by the terms of this
and Agreement, do hereunto place their hands and seals.
BYT
slts/ &
Judge
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Date
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Defendant/Alternate Payee
Date
Yofft a~Vt.1fl? ;:{,
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ttorney for Defendant/
Alternate Payee
Date
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