HomeMy WebLinkAbout00-06541
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
KUM SOON SOL
VERSUS
BRYAN HWAN SOL
AND NOW,
PENNA.
No.
00-6541
CIVIL
DECREE IN
DIVORCE
.M~ .l1~
, .2601 , IT IS ORDERED AND
DECREED THAT
KUM SOON SOL
, PLAINTIFF,
AND
BRYAN HWAN SOL
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
Agreement and StipUlation-see transcript of 10-26-01 hearing
attached.
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PROTHONOTARY
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KUM SOON SOL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Vs.
NO. 00 - 6541 CIVIL
BRYAN HWAN SOL,
Defendant
IN DIVORCE
(WHEREUPON, THE FOLLOWING PROCEEDINGS WERE
INTERPRETED BY CHUN WATTS.)
THE MASTER: Today is Friday, October 26,
2001. This is the date set for a conference in the above
captioned divorce proceedings.
Present in the hearing room are the
Plaintiff, Kum Soon Sol, and her counsel Gerald S. Robinson,
and the Defendant, Byran Hwan Sol, and his counsel Dann S.
Johns.
This action was commenced by the filing of a
divorce complaint on September 26, 2000, raising grounds for
divorce of irretrievable breakdown of the marriage. The
parties are going to sign today affidavits of consent and
waivers of notice of intention to request entry of divorce
decree so that the divorce can be concluded under Section
3301(c) of the Domestic Relations Code.
The complaint also raised economic claims of
equitable distribution, alimony, alimony pendente lite, and
counsel fees and expenses.
The parties were married on May 19, 1983, and
separated in September 2000.
They are the natural parents of
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two minor children.
The Master has been advised that after
negotiations this morning, the parties have reached an
agreement with respect to the outstanding economic claims.
The agreement is going to be placed on the record in the
presence of the parties. The agreement as stated on the
record will be considered the substantive agreement of the
parties not subject to any changes or modifications except for
correction of typographical errors which may be made during
the transcription. The parties and counsel are going to
return later today to review the draft of the agreement for
typographical errors, make any corrections as necessary and
then affix their signatures to the agreement affirming the
terms of settlement as placed on the record.
It is specifically stated, however, that the
agreement will be binding on the parties irrespective of
whether or not they affirm the agreement by signing the
agreement.
Upon receipt by the Master of a completed
agreement, the Master will prepare an order vacating his
appointment and counsel can file a praecipe transmitting the
record to the Court for final decree in divorce.
For the record, it is specifically noted that
an interpreter is present on behalf of the Defendant and your
name is?
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MS. WATTS: Chun, C-h-u-n, Watts, W-a-t-t-s.
THE MASTER: Ms. Watts is going to assist in
any language difficulties which Mr. Sol may have in terms of
the understanding of what is going on here today with respect
to understanding the specific provisions of the agreement.
Mr. Johns is going to state the agreement on the record and
the interpreter will be assisting Mr. Sol in understanding the
provisions of the agreement. Mr. Johns.
MR. JOHNS: The parties intend the following
terms as the final resolution of their equitable distribution
claims:
1. Within ten (10) days of today's date husband shall
execute and acknowledge good and sufficient deeds to 3819
Chippenham Drive, Mechanicsburg, Pennsylvania, and 53 North
17th Street, Harrisburg, Pennsylvania. These deeds shall be
held in escrow by attorney Dann Johns pending wife's
refinancing of the existing mortgage against 3819 Chippenham
Drive and the payment to husband through his counsel of the
sum of $50,000.00.
Wife agrees to make an application with a bank or
mortgage lender within ten (10) days of today's agreement and
the parties anticipate that within six (6) weeks, but no
longer than ninety (90) days, wife will secure the loan to pay
off the existing mortgage on the Chippenham Drive property and
pay husband the $50,000.00 sum.
Pursuant to the payment to husband through his counsel
the sum of $50,000.00, attorney Dann Johns is authorized and
required to release to wife or her agent the deeds to the
Chippenham Drive and 17th Street properties so that they may
recorded as part of that transaction.
2. Wife shall pay husband an additional $15,000.00 as a
property settlement in 15 monthly installments of $1,000.00
per month beginning January 1, 2002, with each payment being
due on the first of each successive month. Payments shall be
made to Dann Johns as attorney for Byran Sol at his office at
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52 South Duke Street, York, Pennsylvania 17401. Both the
$15,000.00 sum and the $50,000.00 sum that wife is paying
husband are intended as a property settlement and not alimony.
3. Husband forever releases and waives to wife all of his
right, title, interest, and claim to a business known as MMK
Mini Market, formerly Sol's Mini Food Market, including all
inventory, receivables and any other aspect of the business.
4. Husband shall retain all personal property in his
possession. wife forever waives all her right, title,
interest and claim to all personal property in husband's
possession.
wife
possession.
and claim to
shall retain all personal property in her
Husband forever waives all right, title, interest
all personal property in wife's possession.
5. Upon receipt of the $50,000.00 payment described above,
husband's counsel shall immediately pay the IRS on behalf of
the parties the sum of $9,750.00 representing husband's entire
obligation on the 2000 tax liability for the business.
Husband's counsel shall provide proof of this payment to
wife's counsel and the balance of the $50,000.00 shall be
distributed directly to husband.
6. Wife shall receive the Mercedes and Toyota Tercel.
Husband shall receive the Toyota pickup. All titles and
registrations for these vehicles as stated herein shall be
transferred prior to wife's payment to husband of the
$50,000.00. Husband shall be responsible for timely payment
and he shall hold wife harmless from the loan on his Toyota
truck.
7. The parties hereby waive all claims for alimony,
alimony pendente lite, counsel fees, costs and expenses as
well as any and all contractual and other claims that they may
have, one against the other.
MR. ROBINSON:
8. Any debts held individually by the respective parties
shall be paid by each party individually and they will each
indemnify and hold each other harmless as to those said debts.
MR. JOHNS:
9. Except as herein otherwise provided, each party may
dispose of his or her property in any way and each party
hereby waives and relinquishes any and all rights he or she
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may now have or hereafter acquire under the present or future
laws of any jurisdiction to share in the property or the
estate of the other as a result of the marital relationship
including without limitation, statutory allowance, widow's
allowance, right of intestacy, right to take against the will
of the other, and right to act as administrator or executor in
the other's estate. Each will at the request of the other
execute, acknowledge, and deliver any and all instruments
which may be necessary or advisable to carry into effect this
mutual waiver and relinquishment of all such interest, rights,
and claims.
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MR. ROBINSON: Ms. Sol, appearing in the
office Robert Elicker, Divorce Master, on October 26, 2001,
and hearing the recitation of the agreement by the parties, do
you have any questions?
MS. SOL: No.
MR. ROBINSON: Do you understand everything
that was sa.id?
MS. SOL: Yes.
MR. ROBINSON: Do you have any reservations
about moving forward with this?
MS. SOL: No,
MR. JOHNS: Mr. Sol, you were here today,
October 26, 2001, at the Divorce Master's office, did you hear
the agreement as I dictated it?
MR. SOL: Yes.
MR. JOHNS: Do you understand the terms of
that agreement?
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MR. SOL: Yes.
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MR. JOHNS: And do you voluntarily agree to
accept that agreement as your own?
MR. SOL: Yes.
I acknowledge that I have read the above
stipulation and agreement, that I understand the terms of
settlement as set forth herein, and that by signing below I
ratify and affirm the agreement previously made and intend to
bind myself to the settlement as a contract obligating myself
to the terms of settlement and subjecting myself to the
methods and procedures of enforcement which may be imposed by
law and in particular Section 3105 of the Domestic Relations
Code.
WITNESS: DATE:
~I'f/'/DI
Gerald. S. Robinson
Attorney for a tiff
10 /2-6/0/
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Dann S. Johns
Attorney for Defendant
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Kuru Soon Sol
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KUM SOON SOL,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00 - 6541 CIVIL
BRYAN HWAN SOL,
Defendant
IN DIVORCE
ORDER OF COURT
AND NOW, this ;)!O ^ day of {}C/o6..aA....J
2001, the parties and counsel having entered into an
agreement and stipulation resolving the economic issues on
October 26, 2001, the date set for a four-party conference,
the agreement and stipulation having been transcribed, and
subsequently signed by the parties and counsel, the
appointment of the Master is vacated, and counsel can
conclude the proceedings by the filing of a praecipe to
transmit the record with the affidavits of consent of the
parties so that a final decree in divorce can be entered.
BY THE COURT,
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Gerald S. Robinson
Attorney for Plaintiff
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Dann S. Johns
Attorney for Defendant
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KUM SOON SOL,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Vs.
NO. 00 - 6541 CIVIL
BRYAN HWAN SOL,
Defendant
IN DIVORCE
(WHEREUPON, THE FOLLOWING PROCEEDINGS WERE
INTERPRETED BY CHUN WATTS.)
THE MASTER: Today is Friday, October 26,
2001. This is the date set for a conference in the above
captioned divorce proceedings.
Present in the hearing room are the
Plaintiff, Kum Soon Sol, and her counsel Gerald S. Robinson,
and the Defendant, Byran Hwan Sol, and his counsel Dann S.
Johns.
This action was commenced by the filing of a
divorce complaint on September 26, 2000, raising grounds for
divorce of irretrievable breakdown of the marriage. The
parties are going to sign today affidavits of consent and
waivers of notice of intention to request entry of divorce
decree so that the divorce can be concluded under Section
3301(c) of the Domestic Relations Code.
The complaint also raised economic claims of
equitable distribution, alimony, alimony pendente lite, and
counsel fees and expenses.
The parties were married on May 19, 1983, and
separated in September 2000.
They are the natural parents of
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two minor children.
The Master has been advised that after
negotiations this morning, the parties have reached an
agreement with respect to the outstanding economic claims.
The agreement is going to be placed on the record in the
presence of the parties. The agreement as stated on the
record will be considered the substantive agreement of the
parties not subject to any changes or modifications except for
correction of typographical errors which may be made during
the transcription. The parties and counsel are going to
return later today to review the draft of the agreement for
typographical errors, make any corrections as necessary and
then affix their signatures to the agreement affirming the
terms of settlement as placed on the record.
It is specifically stated, however, that the
agreement will be binding on the parties irrespective of
whether or not they affirm the agreement by signing the
agreement.
Upon receipt by the Master of a completed
agreement, the Master will prepare an order vacating his
appointment and counsel can file a praecipe transmitting the
record to the Court for final decree in divorce.
For the record, it is specifically noted that
an interpreter is present on behalf of the Defendant and your
name is?
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MS. WATTS: Chun, C-h-u-n, Watts, W-a-t-t-s.
THE MASTER: Ms. Watts is going to assist in
any language difficulties which Mr. Sol may have in terms of
the understanding of what is going on here today with respect
to understanding the specific provisions of the agreement.
Mr. Johns is going to state the agreement on the record and
the interpreter will be assisting Mr. Sol in understanding the
provisions of the agreement. Mr. Johns.
MR. JOHNS: The parties intend the following
terms as the final resolution of their equitable distribution
claims:
1. Within ten (10) days of today's date husband shall
execute and acknowledge good and sufficient deeds to 3819
Chippenham Drive, Mechanicsburg, Pennsylvania, and 53 North
17th Street, Harrisburg, Pennsylvania. These deeds shall be
held in escrow by attorney Dann Johns pending wife's
refinancing of the existing mortgage against 3819 Chippenham
Drive and the payment to husband through his counsel of the
sum of $50,000.00.
Wife agrees to make an application with a bank or
mortgage lender within ten (10) days of today's agreement and
the parties anticipate that within six (6) weeks, but no
longer than ninety (90) days, wife will secure the loan to pay
off the existing mortgage on the Chippenham Drive property and
pay husband the $50,000.00 sum.
Pursuant to the payment to husband through his counsel
the sum of $50,000.00, attorney Dann Johns is authorized and
required to release to wife or her agent the deeds to the
Chippenham Drive and 17th Street properties so that they may
recorded as part of that transaction.
2. Wife shall pay husband an additional $15,000.00 as a
property settlement in 15 monthly installments of $1,000.00
per month beginning January 1, 2002, with each payment being
due on the first of each successive month. Payments shall be
made to Dann Johns as attorney for Byran Sol at his office at
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52 South Duke Street, York, Pennsylvania 17401. Both the
$15,000.00 sum and the $50,000.00 sum that wife is paying
husband are intended as a property settlement and not alimony.
3. Husband forever releases and waives to wife all of his
right, title, interest, and claim to a business known as MMK
Mini Market, formerly Sol's Mini Food Market, including all
inventory, receivables and any other aspect of the business.
4. Husband shall retain all personal property in his
possession. wife forever waives all her right, title,
interest and claim to all personal property in husband's
possession.
Wife
possession.
and claim to
shall retain all personal property in her
Husband forever waives all right, title, interest
all personal property in wife's possession.
5. Upon receipt of the $50,000.00 payment described above,
husband's counsel shall immediately pay the IRS on behalf of
the parties the sum of $9,750.00 representing husband's entire
obligation on the 2000 tax liability for the business.
Husband's counsel shall provide proof of this payment to
wife's counsel and the balance of the $50,000.00 shall be
distributed directly to husband.
6. Wife shall receive the Mercedes and Toyota Tercel.
Husband shall receive the Toyota pickup. All titles and
registrations for these vehicles as stated herein shall be
transferred prior to wife's payment to husband of the
$50,000.00. Husband shall be responsible for timely payment
and he shall hold wife harmless from the loan on his Toyota
truck.
7. The parties hereby waive all claims for alimony,
alimony pendente lite, counsel fees, costs and expenses as
well as any and all contractual and other claims that they may
have, one against the other.
MR. ROBINSON:
8. Any debts held individually by the respective parties
shall be paid by each party individually and they will each
indemnify and hold each other harmless as to those said debts.
MR. JOHNS:
9. Except as herein otherwise provided, each party may
dispose of his or her property in any way and each party
hereby waives and relinquishes any and all rights he or she
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may now have or hereafter acquire under the present or future
laws of any jurisdiction to share in the property or the
estate of the other as a result of the marital relationship
including without limitation, statutory allowance, widow's
allowance, right of intestacy, right to take against the will
of the other, and right to act as administrator or executor in
the other's estate. Each will at the request of the other
execute, acknowledge, and deliver any and all instruments
which may be necessary or advisable to carry into effect this
mutual waiver and relinquishment of all such interest, rights,
and claims.
MR. ROBINSON: Ms. Sol, appearing in the
office Robert Elicker, Divorce Master, on October 26, 2001,
and hearing the recitation of the agreement by the parties, do
you have any questions?
MS. SOL: No.
MR. ROBINSON: Do you understand everything
that was said?
MS. SOL: Yes.
MR. ROBINSON: Do you have any reservations
about moving forward with this?
MS. SOL: No,
MR. JOHNS: Mr. Sol, you were here today,
October 26, 2001, at the Divorce Master's office, did you hear
the agreement as I dictated it?
MR. SOL: Yes.
MR. JOHNS: Do you understand the terms of
that agreement?
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MR. SOL: Yes.
MR. JOHNS: And do you voluntarily agree to
accept that agreement as your own?
MR. SOL: Yes.
I acknowledge that I have read the above
stipulation and agreement, that I understand the terms of
settlement as set forth herein, and that by signing below I
ratify and affirm the agreement previously made and intend to
bind myself to the settlement as a contract obligating myself
to the terms of settlement and subjecting myself to the
methods and procedures of enforcement which may be imposed by
law and in particular Section 3105 of the Domestic Relations
Code.
DATE:
rald. S. Robinson ~J
ntiff
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Kum Soon Sol
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Dann S. s
Attorney for Defendant
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KUM SOON SOL,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-6541
BRYAN HWAN SOL,
Defendant.
CIVIL ACTlON--LA W IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the Court for the entry of
a divorce decree:
1. Ground for divorce: irretrievable breakdown under section 3301(c) of the Divorce
code.
2. Date and Manner of service of the Complaint: Certified Mail, Restricted Delivery,
Return Receipt Requested on September 11, 2000.
3. Date of execution of the affidavit required by section 3301(c) of the Divorce Code: by
Plaintiff on October 26, 2001 and by Defendant on October 26, 2001.
4. Related claims pending. None
5. Date the Plaintiffs waiver of Notice in section 3301(c) of the Divorce was filed with
the Prothonotary: October 26, 2001.
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6. Date the Defendant's Waiver of Notice in section 3301(c) of the Divorce was filed
with the Prothonotary: October 26, 2001.
Respectfully submitted,
ROBINSON & GERALDO
BY~
Gerard S. Robinson, Esquire
Attorney LD. No. 27423
4407 North Front Street
P.O. Box 5320
Harrisburg, Pennsylvania 17110
(717) 232-8525
Attorney for Plaintiff.
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KUM SOON SOL
PLAINTIFF
v.
BRYANHWAN SOL
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
00-6541 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 29 day oYEPTEMBE.e., 2000, upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator,
at 214 Senate Avenue, Suite 105, CampHiU, PA 17011 on the ~ day of OCTOBER , 2000, at 11:00 A.M
for a Pre.Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
FOR THE COURT,
By: Isl
Melissa P. Greevy. Esq.!/)
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our office.
All anangements must be made at least 72 hours prior to any hearing or business before the court. You must
attend the scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATIORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATIORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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PeNNSYLVANIA
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KUM SOON SOL,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00- &5t/1
C?io;[ ~~
BRYAN HW AN SOL,
Defendant.
CML ACTION-DIVORCE
ORDER OF COURT
AND NOW, upon consideration of the attached Complaint, 11: is hereby directed that the
parties and their respective counsel appear before
, on the
day of
, 2000 at
, in the
, for
the Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the
issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard
by the Court, and to enter into a Temporary Order. Failure to appear at the conference may
provide grounds for the entry of a temporary or permanent Order.
For the Court,
Date:
By:
Custody Conciliator
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KUM SOON SOL,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00 - (,SIJ I
CfVlC I~
BRYANHWANSOL,
Defendant.
CIVIL ACTION-DIVORCE
NOTICE TO 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 child.
When the ground for the divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the Office of
the Prothonotary at the Cumberland County Courthouse, One Courthouse Square, Carlisle,
Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
Cl:lR'IBllflanli eQual?' Ce1iFl f.llmini3lnrtor
4!h FluUI, CWllb"".luu.d Cvu-uly CUwdluu:se
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KUM SOON SOL,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO.
BRYAN HWAN SOL,
Defendant.
CIVIL ACTION-DIVORCE
A VISO
USTED HA smo DEMANDADOI A EN CORTE. Si usted desea defenderse de las
demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de
los proximos veinte (20) dias despues de la notificacion de esta Demanda y A viso radicando
personalmente 0 por medio de un abogado una comparecencia escrita y radicano en la Corte por
escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se Ie
advierte de que si usted falla de tomar accion como se describe anteriormente, e1 caso puede
proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda 0 caulquier
otra reclamacion 0 remedio solicitado por el demandante puede ser dictado en contra suya por la
Corte sin mas aviso adicional. Usted puede perder dinero 0 propiedad u otros derechos
importances para used.
SED DEBE LLEV AR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE.
51 USTED NO TIENE UN ABOGADO 0 NO PUEDE P AGARLE A UNO, LLAME 0 VA Y A
A LA SIGUIENTE OFICINA PARA A VERIGUAR DONDE PUEDE ENCONTRAR
ASISTENCIA LEGAL.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
Cumberland County Court Administrator
4th Floor, Cumberland County Courthouse
Carlisle, P A 17013
(717) 240-6200
II
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KUM SOON SOL,
Plaintiff,
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. d-O- l,S<I/ ~ t..u-
BRYAN HWAN SOL,
Defendant.
CIVIL ACTION-DIVORCE
COMPLAINT UNDER SECTION 3301 (c) OF THE DIVORCE CODE
COUNT I
1. Plaintiff is KUM SOON SOL, an adult individual who currently resides at 3819
Chippenham Drive, Mechanicsburg, Cumberland County, Pennsylvania.
2. Defendant is BRYAN HW AN SOL, an adult individual who currently resides at
3819 Chippenham Drive, Mechanicsburg, Cumberland County, Pennsylvania.
3. Plaintiff has been a bona fide resident in the Commonwealth for at least six (6)
months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on May 19, 1983 in Chambersburg,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the Parties.
6. The marriage is irretrievably broken.
i
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7. Neither Party is a member of the Armed Forces of the United States or any of its
allies.
8. The Plaintiff has been advised of the availability of counseling and that either
party may compel the other by Order of Court to attend counseling sessions.
WHEREFORE, Plaintiff respectfully requests that your Honorable Court enter a Decree
in Divorce under Section 330l(c) of the Divorce Code.
COUNT II-EQUITABLE DISTRIBUTION
9. The Plaintiff incorporates by reference Paragraphs 1 through 8 of the Complaint
for Divorce as fully set forth herein.
10. During the marriage, Plaintiff and Defendant have acquired various items of
marital property, which are subject to equitable distribution under Section 3502 of the
Pennsylvania Divorce Code of 1980, as will be full set forth in the Plaintiff s Inventory and
Appraisement to be filed pursuant to the Pennsylvania Rules of Civil Procedure.
11. Plaintiff and Defendant have been unable to agree as to an equitable division of
marital property.
II
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WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital
property.
COUNT III-CUSTODY
12. The Plaintiff incorporates by reference Paragraphs I through II of the Complaint
for Divorce as fully set forth herein.
13. There were two (2) children born during this marriage, to wit: Minwoo Sol, born
AprilS, 1985 and Mintei Sol, born November 28,1986.
14. From birth to present, the children have resided with both Plaintiff and Defendant
at 3819 Chippenham Drive, Mechanicsburg, Cumberland County, Pennsylvania.
IS. The Court of Common Pleas of Cumberland County, Pennsylvania, Family
Division, has the sole and exclusive jurisdiction in this matter, pursuant to the Uniform Child
Custody Jurisdiction Act, and the Commonwealth Child Custody Jurisdiction Act for the
following reasons:
a. Cumberland County, Pennsylvania, has been the children's home county for
the six (6) months preceding the commencement of the instant proceedings.
b. It is in the best interest and welfare of the children that the Court of Common
Pleas of Cumberland County, Pennsylvania, assume jurisdiction because the child
. .
has a significant connection with this jurisdiction, and there is available in this
jurisdiction substantial evidence concerning the children's present or future care,
protection, training and personal relationships.
c. No other state has jurisdiction in this matter under the requirements of the
Uniform child Custody Jurisdiction Act and the Commonwealth Child Custody
Jurisdiction Act.
16. The Plaintiff has not participated in any capacity whatsoever in any other
litigation concerning the custody of Mintoo Soland Mintei Sol, minor children, in this or any
other state.
17. The Plaintiff does not know of any other person other than the Defendant herein
who claims to have custody or partial custody rights with the minor child.
18. The Plaintiff submits that it is in the best interests and welfare of the minor
children that she be granted custody of the children, and that Plaintiff can best provide the minor
children with a more stable, healthful, religious, and proper environment.
WHEREFORE, Plaintiff prays that this Honorable Court grant custody of the minor
children of the Parties to Plaintiff.
II
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COUNT IV.COUNSEL'S FEES. EXPENSES
19. The Plaintiff incorporates by reference Paragraphs 1 through 18 of the Complaint
for Divorce as fully set forth herein.
20. That by reason of the institution of the action to the above term and number,
Plaintiff will be and has been put to considerable expense in the preparation of her case in the
employment of counsel and the payments of costs.
21. The Plaintiff's income is disproportionately lower than Defendant's income, and
Plaintiff is without adequate funds to pay the costs and expenses of this litigation.
22. Plaintiff is currently self employed at 53 North 1 ill Street, Harrisburg,
Pennsylvania, where she and the Defendant jointly own a grocery store.
23. Defendant is currently self employed at 53 North 17th Street, Harrisburg,
Pennsylvania, where he and the Plaintiff jointly own a grocery store.
WHEREFORE, Plaintiff prays that your Honorable Court grant an Order upon Defendant
to pay Plaintiffs counsel fees and costs oflitigation.
I,
II
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COUNT V-ALIMONY AND ALIMONY PENDENTE LITE
24. The Plaintiff incorporates by reference Paragraphs 1 through 23 of the Complaint
for Divorce as fully set forth herein.
25. Plaintiff lacks sufficient property to provide for her reasonable means and is
unable to support herself through appropriate employment.
26. Plaintiff requires reasonable support to adequately maintain herself in accordance
with the standard ofliving established during the marriage.
WHEREFORE, Plaintiff requests Your Honorable Court to enter an award of alimony in
her favor.
Respectfully submitted,
ROBINSON & GERALDO
Date: 9/1S-)Db
...
By:
G iIld S. Robinson, Esquire
Attorney LD. No. 27423
4407 North Front Street
P.O. Box 5320
Harrisburg, PAl 711 0
(717) 232-8525
Attorney for Plaintiff
'.
VERIFICATION
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.
Section 4904, relating to unsworn falsification to authorities.
~~
urn S. Sol, Plaintiff
. ,
.
"
CERTIFICATE OF SERVICE
I, Gerald S. Robinson, Esquire, do hereby certifY that on the 15th day of
September, 2000, I caused a true and correct copy of the Complaint to be served upon the
following individual by certified mail return receipt requested restricted delivery to
addressee only by depositing same in the United States, postage prepaid, in Harrisburg,
Pennsylvania.
Bryan Hwan Sol
53 North 17th Street
Harrisburg, P A 17103
Respectfully submitted,
ROBINSON & GERALDO
~
By: -
Gerald S. Robinson, Esquire
Attorney I.D. No. 27423
4407 North Front Street
P.O. Box 5320
Harrisburg, P A 17110
(717) 232-8525
Attorney for Plaintiff
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KUM SOON SOL,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2000-6541
BRYAN HWAN SOL,
Defendant.
CIVIL ACTION-DIVORCE
PROOF OF SERVICE
The undersigned makes the following return of service: the Complaint in Divorce was
served upon Bryan Hwan Sol, the Defendant, on September II, 2000 at 53 North 17th Street,
Harrisburg, Dauphin County, Pennsylvania. The signed receipt is attached hereto as Exhibit 1.
SIGNATURE AND AFFIDAVIT
-"..~",
I, Gerald S. Robinson, Esquire, certifY that I am a competent adult not a party to this
action.
I verify that the statements made in this affidavit and return of service 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 falsfication to authorities.
Respectfully submitted,
ROBINSON & GERALDO
Dated: /O/3/0D
~~
By:
Gerald S. Robinson, Esquire
Attorney I.D. No. 27423
4407 North Front Street
P.O. Box 5320
Harrisburg, Pennsylvania 17110-5320
(717) 232-8525
Attorney for Plaintiff
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2. Article Number (Copy from service label)
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KUM SOON SOL,
Plaintiff
VS.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL TERM - LAW
: NO. 00 - 6541 CIVIL TERM
BRYAN HWAN SOL,
Defendant
: DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under !il 3301 (c) of the Divorce Code was filed on
September 25, 2000.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety
days have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final Decree in Divorce after service of notice of
intention to request entry of the Decree.
I verify that the statements made in this Affidavit are true and correct to the best
of my knowledge, information and belief. I understand that false statements herein are
made subject to the penalties 9f 18.E'.i;l.C.S. 4994 relating to unsworn falsification to
authorities.
~~
Kum Soon Sol, Plaintiff
Date:
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Plaintiff
VS.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL TERM - LAW
: NO. 00 - 6541 CIVIL TERM
BRYAN HWAN SOL,
Defendant
: DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
S3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of
property, lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a Divorce Decree is entered
by the Court and that a copy of the Decree will be sent to me immediately after it is
filed with the Prothonotary.
I verify that the statements made in this Affidavit are true and correct to the best
of my knowledge, information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to
authorities.
~~~~/
Kum Soon Sol, Plaintiff
Date: I 0 - ;).~ - "I
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Plaintiff
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: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL TERM - LAW
: NO. 00 - 6541 CIVIL TERM
: DIVORCE
BRYAN HWAN SOL,
Defendant
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under !il 3301 (c) of the Divorce Code was filed on
September 25, 2000.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety
days have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final Decree in Divorce after service of notice of
intention to request entry of the Decree.
I verify that the statements made in this Affidavit are true and correct to the best
of my knowledge, information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to
authorities.
an Hwan Sol, Defendant
Date: / /) - 26 ~ CJ /
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Plaintiff
VS.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL TERM - LAW
: NO. 00 - 6541 CIVIL TERM
BRYAN HWAN SOL,
Defendant
: DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
S3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of
property, lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a Divorce Decree is entered
by the Court and that a copy of the Decree will be sent to me immediately after it is
filed with the Prothonotary.
I verify that the statements made in this Affidavit are true and correct to the best
of my knowledge, information and belief. 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:
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
CIVIL ACTION LAW
vs.
NO. 00 _ 6541
IN DIVORCE
CIVIL
19
BRYANKWANSOL
Defendant
STATUS SHEET
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KUM SOON SOL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00 - 6541 CIVIL
BRYAN KWAN SOL,
Defendant
IN DIVORCE
TO: Gerald S. Robinson
Attorney for Plaintiff
Dann S. Johns Attorney for Defendant
DATE: Thursday, April 26, 2001
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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KUM SOON SOL
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
V.
BRYANHWANSOL
: NO. 2000-6541 CIVIL
ORDER OF COURT
AND NOW, this 5TH day of FEBRUARY, 2001, the hearing scheduled for Friday,
February 9, 2001, before Judge Guido will now be heard along with the support matter
scheduled for 'March 22. 2001. at 9:00 a.m. before Jndge Hess in Courtroom # 4.
Edward E. Guido, 1.
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Gerald S. Robinson, Esquire
For the Plaintiff
Dann S. Johns, Esquire
For the Defendant
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Ronald M. Leik, CPA
1517 Cedar Cliff Drive
Camp Hill, PA 17011-7705
Tel. 737-8909
October 23, 2001
I have compiled the accompanying Statement of Opera-
tions--Modified Cash Basis for
MMK MINI MARKET
for the months of February through September of 2001.
The statement was prepared in accordance with State-
ments on Standards for Accounting and Review Services issu-
ed by the American Institute of Certified Public Account-
ants.
A compilation is limited to presenting in the form of
a financial statement information that is the representa-
tion of the owner. I have not audited or performed a re-
view of the statement and, accordingly, do not express an
opinion or other form of assurance.
The statement was prepared on the modified cash basis
of accounting, which is an accepted and comprehensive basis
of accounting but other than generally accepted accounting
principles.
An interim financial statment--Iess than twelve months
--is prepared differently from a year-end, twelve-month
statement. And it should be read differently.
For example, the interim statement shows monthly
purchases of merchandise. At year end, the owner will
report her inventory on hand, and a calculation will be
made to determine merchandise actually sold during the
year, which then will be used on the financial statement.
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Mrs. Sol opened the business with herself as a sole
proprietor on February 15, 2001, which is why the state-
ment reflects a partial month for February.
She immediately began renovations to the building
at 53 N. 17th Street, Harrisburg. Those costs are shown
in the expense account, Repairs & Maintenance. On her
federal income tax return for 2001, part of those costs
will be depreciated; that is, spread over a number of
years.
Sincerely,
a~ m. 01\.....:1
Ronald M. Leik
Certified Public Accountant
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Ronald M. Leik, CPA
7577 Cedar Cliff Drive
Camp Hill, PA 77011-7705
Tel. 73?-8909
October 23, 2001
I have complied the accompanying Statement of Opera-
tions--Modified Cash Basis of
SOL'S MINI FOOD MARKET
for the months of October-December, 2000, and January, 2001.
The statement was prepared in accordance with State-
ments on Standards for Accounting and Review Services issu-
ed by the American Institute of Certified Public Account-
ants.
A compilation is ,limited to presenting in the form of
a financial statement information that is the representa-
tion of the owner. I have not audited or performed a re-
view of the statement and, accordingly, do not express an
opinion or other form of assurance.
The statement was prepared on the modified cash basis,
which is an accepted and comprehensive basis of accounting
but other than generally accepted accounting principles.
An interim financial statement--Iess than twelve
months--is prepared differently from a year-end, twelve-
month statement. And it should be read differently.
For example, the interim statement shows monthly
purchases of merchandise. At year end, the owner reports
his inventory on hand, and a calculation is made to deter-
mine merchandise actually sold during the year, which is
then used on the financial statement.
, ~
~!~l';;
In addition, commissions (such as, lottery) are re-
ported to the owner by the payer only at year end. On the
attached statement, commissions for calendar year 2000 were
divided ,by one-twelfth and that amount was reported monthly
regardless of how commissions were earned.
The owner operated the business for
January of 2001. At that time, he broke
and did not deliver his January records.
activity is shown for January.
about two weeks in
off contact with me
That is why no
Sincerely,
a~ m. 7i\~
Ronald M. Leik
Certified Public Accountant
,.'
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
KutIl Soon Sol
CIVIL ACTION - DIVORCE
Jcm - G 5Y /
vs.
Bryan Hwan Sol
PRAECIPE FOR THE ENTRY OF APPEARANCE
Please enter my appearance in the above captioned matter on behalf of the Defendant,
Date:
5tpr Zi;. ?tJu:.J
\(]/
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Dann S. Johns, Esq.:iile
52 South Duke Street
York, Pennsylvania 17401
741-4717 telephone
741-0368 fax
ID #52681
Bryan Hwan SoL
Attorney for Bryan Hwan Sol
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KUM SOON SOL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - LAW
NO. 00 - 6541 CIVIL
BRYAN KWAN SOL,
Defendant
IN DIVORCE
CONFERENCE WITH
COUNSEL AND PARTIES
TO: Gerald S. Robinson
Kum Soon Sol
Counsel for Plaintiff
, Plaintiff
Dann S. Johns
Bryan Kwan Sol
, Counsel for Defendant
Defendant
A conference has been scheduled at the Office of
the Divorce Master, 9 North Hanover Street, Carlisle,
Pennsylvania, on the 26th day of October, 2001, 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: 10/3/01
E. Robert Elicker, II
Divorce Master
-,' --~
- .~~.~ "."*
~t.
Support and Maintenance of Children
September 13 to October 14
$1,765.68
1,765.68
October 14 to November 14
November 14 to December 14
1,765.68
December 14 to January 14
1,765.68
January 14 to February 14
500.00
February 14 to March 14
500.00
March 14 to April 14
500.00
April 14 to May 14
500.00
May 14 to June 14
500.00
June 14 to July 14
500.00
July 14 to August 14 ,
500.00
August 14to September 14
500.00
September 14 to October 14
500.00
Total $11,562.72
-300.00 (pd 11/29/00)
Total $11,262.72
~ '
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Contributions to Marital Estate Made Bv Plaintiff
Paid by Plaintiff to cure default
Mortgage Payments after cure (2 months)
House Repairs
Repairs to Re-Open Store
Car Repairs
$12,978.19
3,105.42
3,080.50
12,969.00
10.000.00
Total $42,133.11
~
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Mercedez Benz (wife)
Toyota Truck (husband)
House (Net Equity)
Store
~~
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Marital Estate
$ 14,000.00
0.00
70,000.00
. 120,000.00
Total $204,000.00
-
Painting/Cleaning
Sump Pump
Ceiling Repair
Moving Expense
Truck Rental
Recent Repairs
-~
~~.
House Repairs
$897.00
650.00
300.00
600.00
50.00
583.50
Total $3080.50
.
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Distribution Summary
50/50
Husband
$104,000.00
-21,066.56 (1/2 of Contribution to Marital Estate)
-11,362.00 (Child Support Arrearage)
, "~
-
Wife
$104,000.00
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Distribution Summary
40/60
Husband
$ 83,200.00
-21,066.56 (1/2 of Contribution to Marital Estate)
-11,362.00 (Child Support Arrearage)
Wife
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$124,800.00
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Distribution Summary
45/55
Husband
$ 93,600.00
-21,066.56 (1/2 of Contribution to Marital Estate)
-11,362.00 (Child Support Arrearage)
-
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Wife
$114,400.00
.~
KUM SOON SOL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - LAW
NO. 00 - 6541 CIVIL
BRYAN KWAN SOL,
Defendant
IN DIVORCE
NOTICE OF PRE HEARING CONFERENCE
TO: Gerald S. Robinson
, Attorney for Plaintiff
Dann S. Johns
, Attorney for Defendant
A pre-hearing conference has been scheduled
at the Office of the Divorce Master, 9 North Hanover Street,
Carlisle, Pennsylvania, on the 3rd of October, 2001, at 9:30
a.m., at which time we will review the pre-trial statements
previously filed by counsel, define issues, identify
witnesses, explore the possibility of settlement and, if
necessary, schedule a hearing.
Very truly yours,
Date of Notice: 7/26/01
E. Robert Elicker, II
Divorce Master
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JAN 29 2001
January 26, 2001
The Honorable Edward Guido
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013-3387
The Honorable Kevin Hess
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013-3387
Re: Kum Soon Sol v. Bryan Hwan Sol- No. 2000-6541
Dear Judges Guido and Hess:
Please be advised that there is a hearing scheduled in front of Judge Guido on
February 9, 2001 regarding exclusive possession of the marital residence and a special
hearing on support in front of Judge Hess on March 22,2001 in the above referenced
matter. The purpose of this letter is to request that these two hearings be combined into
one and be heard in front of one Judge.
Because these two hearings are similar in nature, opposing counsel and I both feel
it would be beneficial to all parties if the hearings were conducted together.
Please advise me at your earliest convenience if this is feasible. I appreciate in
advance your cooperation in this matter.
Should you have any questions, please do not hesitate to contact me.
Sincerely yours,
ROBIN ON & GERALDO
"
By:
Gerald S. Robinson, Esquire
Cc: K. Sol
GSR:llb
/
P.O. Box 5320
Harrisburg, PA 17110-5320
Harrisburg
4407 North Front Street
Harrisburg, PA 17110
(717) 232.8525
(800) 571-2727
Fax (717) 232-8525
Cumberland County
61 W. Louther Street
Carlisle, PA 17013
(717)249'1177
Fax (717) 249.4514
Washington, D.C.
1316 Pennsylvania Ave., S.E.
Washington, D.C. 20003
(202) 544-2889
Fax (202) 547-8342
. --
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LAw OFFICE OF DANN JOHNS
52 SOUTH DUKE STREET
YORK, PENNSYLVANIA 17401
July 19, 2001
Cumberland County Court House
High & Hanover Streets
Carlisle FA 17013
Attn: Prothonotary
Re: Kum Soon Sol vs. Bryan Kwan Sol 00-6541
Dear Prothonotary:
Please file the Defendant's Rule 1920.33 Statement. The
original was filed with the Divorce Master's office.
An extra copy is being provided to be returned once it has
been time stamped.
Thank you for your attention to this matter.
Respectfully,
Patricia McElwain
Certified Paralegal
Encl: Defendant's Rule 1920.33 Statement
~: Divorce Master w/encl. (Original and copy)
Gerald Robinson, Esquire w/encl.
Bryan Sol w/encl.
file
TELEPHONE 717 741-4717
JOHNSDANN@AOL.COM
FAX717741-0368
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LAw OFFICE OF DANN JOHNS
52 SOUTH DUKE STREET
YORK. PENNSYLVANIA 17401
July 19, 2001
Office of Divorce Master
9 North Hanover Street
Carlisle PA 17013
TELEPHONE 717 741-4717
JOHNSDANN@AOL.COM
FAX717741-0368
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July 24, 200 I
VIA FACSIMILE and 1 ST CLASS MAIL
E. Robert Elicker, II, Esquire
9 North Hanover Street
Carlisle, PA 17013
Re: Kum Soon Sol v. Bryan Kwan Sol. No. 00-6541 CIVIL
Our File No. 1708.001
Dear Mr. Elicker:
Enclosed for your file, please find Plaintiffs Pre-Trial Statement in the above
referenced matter.
Should you have any questions or concerns, please do not hesitate to contact me.
Sincerely yours,
. ._~..,~w~
By:
Gerald S. Robinson, Esquire
Enclosure
Cc: Dann Johns, Esquire
Kum Sol
GSR: vir
p. 0, Box 5320
Harrisburg, PA 17110-5320
Harrisburg
4407 North Front Street
Harrisburg, PA 17110
(717) 232-8525
(800) 571-2727
Fax (717) 232.5098
Cumberland County
61 W. Louther Street
Carlisle, PA 17013
(717) 249.1177
Washington, D.C.
1316 Pennsylvania Ave., S.E.
Washington, D.C. 20003
(202) 544-2889
Fax (202) 547-8342
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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 Jo Colyer
Office Manager/Reporter
West Shore
697-0371 Ex!. 6535
June 27, 2001
Gerald S. Robinson, Esquire
ROBINSON & GERALDO
P.O. Box 5320
Harrisburg, PA 17110-5320
Dann S. Johns, Esquire
52 South Duke Street
York, PA 17401
RE: Kum Soon Sol vs. Bryan Kwan Sol
No. 00 - 6541 Civil
In Divorce
Dear Mr. Robinson and Mr. Johns:
Mr. Robinson has certified that discovery is complete. Mr. Johns has not
responded regarding discovery. I am going proceed, therefore, on the basis that there will
be no discovery issues that I will be addressing at the pre-hearing conference stage and
that all discovery matters are complete. If discovery matters are raised at the pre-hearing
conference I will determine whether or not I will hear any evidence that is relating to
unfinished discovery issues.
A divorce complaint was filed on September 26, 2000, raising grounds for divorce
of irretrievable breakdown of the marriage. The complaint also raised economic claims
of equitable distribution, alimony, alimony pendente lite, and counsel fees and expenses.
I assume that grounds for divorce are not an issue and that the parties will either sign
affidavits of consent or have been separated for a period in excess of two years.
In accordance with P.R.C.P. 1920.33(b) I am directing each counsel to file a
pretrial statement on or before Friday, July 20, 200 I. Upon receipt of the pretrial
statements, I will immediately schedule a pre-hearing conference with counsel to discuss
,
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,
- ~ u,l
Mr. Robinson and Mr. Johns, Attorneys at Law
27 June 2001
Page 2
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 V ACA TED.
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KUM SOON SOL,
Plaintiff/Petitioner,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2000-6541
BRYAN HWAN SOL,
DefendantJRespondent.
: CMLLAW-LAWINDIVORCE
ORDER OF COURT
AND NOW, this q -tf, day of January, 2001, upon consideration of the Request
for Continuance, it is hereby Ordered and Decreed that a hearing presently scheduled for
January 10, 2000 at 3:30 PM will be continued to the ~ day of
~~y ,2001. @ /O:.3tJ ,11. ffJ'j CLdCotteotlly/41 .!J-.
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January 5, 2001
The Honorable Edward Guido
Cumberland County Courthouse
One Courthouse Square
Carlisle, P A 17013-3387
Re: Kum Soon Sol v. Bryan Hwan Sol- No. 2000-6541
Dear Judge Guido:
Please acknowledge this letter as a request to continue the hearing for Exclusive
Possession of the Marital Residence presently scheduled for January 10, 2001 at
3:30 PM. Please be advised that our expert witness is not available on said date.
Opposing counsel does not object to this matter being continued to another date, provided
that it is not scheduled for the week of January 22, 200 I.
Accordingly, I am requesting that this matter be continued.
I appreciate in advance your cooperation in this matter.
Sincerely yours,
ROBINSON & GERALDO
;1
, ,
I' /'..,
By: )iu,&lE5k't:~
Gerald S. Robinson, Esquire
cc: Kum Soon Sol
Dann Johns, Esquire
GSR:clf
P.O. Box 5320
Harrisburg, PA 17110-5320
Harrisburg
4407 North Front Street
Harrisburg, PA 17110
(717) 232.8525
(800) 571-2727
Fax (717) 232-8525
Cumberland County
61 W. Louther Street
Carlisle, PA 17013
(717) 249-1177
Fax (717) 249-4514
Washington, D.C.
1316 Pennsylvania Ave., S.E.
Washington, D.C. 20003
(202) 544-2889
Fax (202) 547.9342
~-
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01/05/2001 FRI 17:39 FAX 717 232 5098 ROBINSON & GERALDO
I .
I
I4J 003/007
i
KUM SOON SOL,
Plaintift)'Petitioner,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2000-6541
BRYAN HWAN SOL,
Defendant/Respondent.
CIVIL LAW-LAW IN DIVORCE
MOTION FOR CONTINUANCE
TO THE HONORABLE JUDGE OF SAID COURT;
AND NOW COMES, Plaintiff, KUM SOON SOL, by and through her attorney,
GERALD S. ROBINSON, ESQU1RJ::, and respcctfully requests a continuance ofthe within
procccding and in support thereof states:
1. The Petition for Exclusive Possession seeking exclusive possession of the marital
residence was filed on or about December 15, 2000.
2, An Order scheduling the Hearing for January 10,2001 was entered on
Dcccrnber 26, 2000~
3. Petitioner intends to submit the testimony of an expert witness, who is unavailable
OIl the date <md time set for the hcaring.
"",-
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01,-05/2001 FRI 17:39 FAX 717 232 5098 ROBINSON & GERALDO
I
,
I4i 004/007
4. Counsel for Respondent was on vacation the week of December 25, 2000;
therdore Counsel for Petitioner was unable to consult him regarding thc continuance.
5, A proposal to amicable resolve this matter was sent to Respondent's counsel on
Dcccmhcr 28, 2000.
6. Respondent is considering Petitioner's proposal for amicably resolving the issues
raised in the Petition for Special Relief.
7. Counsel for Respondent does not oppose this continuance reql1eSL
8. Counsel for Respondent is unavailable the week ofJanuary 21, 2000.
9. Neither paxty will sutTer prejudice if this Motion is granted.
-
.
:," ~'.:......&~-,',
01/05/2001 FRI 17:39 FAX 717 232 5098 ROBINSON & GERALDO
II
IiIJ 005/007
,
WHEREFORE, Petitioner's counsel respectfully requests that this Honorable Court
reschedule the ubove-captioncd hearing.
Respectfully submitted,
ROBINSON & GERALDO
-', \ n I} .\ -
BY:JP 11l.l r! i) k f'i. '-(;YL,LX;( _'
Gerald S. Robinson, Esquire
Attorney I.D, No. 27423
4407 North Front Street
P.O. Box 5320
Harrisburg, PCIIDsylvania 17110
(717) 232-8525
Dated: !/5j()O Attorncy tor thc Dcfcndant
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01/05/2001 FRI 17:39 FAX 717 232 5098 ROBINSON & GERALDO
I4J 006/007
JI
VERIFICATION
[ vl;lrifY that the statcments made in this Motion are true and correct. 1 ullderslanc.l
that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904,
relating to unsworn falsification to authorities.
GJI/l cJ /'1 :'\. PrLr ~I JJll
Gerald S. Robinson, Esquire
01/05/2001 FRI 17:39 FAX 717 232 5098 ROBINSON & GERALDO
I
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.
CERTIFICATE OF SERVICE
I, Gerald S. Robinson, Esquire, do hereby certifY that on the 5u. day of January 2000, T
caused a truc and correct copy of the Motion for Continuance to be served upon the following
individual by Regular Mail:
Dann Johns, Esquire
52 South Duke Street
York, PA 17401
Respectfully submitted,
ROBINSON & GERALDO
By:
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!-f:j(.(L~..('1 0, fr; J( nJ/li_
Gerald S. Robinson, Esquire
Attorney I.D. No. 27423
4407 North Front Street
P.O. Box 5320
Harrisburg, Penn~ylvania 17110
(717) 232-8525
Attorney for Petitioner
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01/05/2001 FRI 17:38 FAX 717 232 5098 ROBINSON & GERALDO
Ii!J 001/007
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HOBINSON
GERALDO
/1/111l"f!I)l(/{.Ltl,',L','
A p'(Jk~,:~.;i(l(l,,1 CDl"PI~(8Iiur1
Fax
TO: The Honorablc Edward Guido
FR.oM: Gerald S. Robinson. Esquire
FAX: 240-6462
I'ACl5:, ,1
PI lONE: 240-6290
DATE: 1/05/2001
RF: Kum Soon Sol v. Bryan Hwan Sol- 2000-6541
o Urgent 0 For Rcvicw 0 Please Comment 0 Please Reply
. Comments:
Attached please find the Motion for Continuance to further support our
continuancc rcquest that was faxed to you earlier. Kindly contact our office at YOLlr
earliest possible conveniencc to inform us of your decision. 1 thank you in advance for
your courtesy in this matter.
THE INFORMATION IN THIS FACSIMILE TRANSMISSION IS INTENDED
ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS
ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED,
CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE
LAW. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED
RECIPIENT, OR THE EMPLOYEE OR AGENT RESPONSIBLE FOR
DELIVERING THE MESSAGE TO THE INTENDED RECIPIENT, YOU ARE
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HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY THE
SENDER IMMEDIATELY BY TELEPHONE AND DESTROY THE ORIGINAL
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P.O. Box 8320
Harrisburg, PA 1111 a-53~O
Harrisburg
4407 North Ftun( Street
Hat(J:5burg, PA 17110
(717) 232..52.
(800) 571.2727
Fax (7H) 292-8525
Cumberlanl;l County
61 W. lnutherStreet
CarliSle, PA 17013
(717) 249-1177
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VVa~hlngton, D.C.
1316 Penl"ll,ylvania Ave., S.E.
WashIngton, O,C, 20003
{;102} S44-Zeaa
FSlf (202) 541-as42
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KUM SOON SOL,
PlaintifflPetitioner,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2000-6541
BRYAN HWAN SOL,
DefendantJRespondent.
: CIVIL LAW-LAW IN DIVORCE
ORDER
AND NOW, this 10 ~ day of January 2001, upon consideration of the within
Motion for Continuance requested by the Plaintiff's Counsel, Gerald S. Robinson, Esquire, the
above captioned Hearing for Exc1nsive Possession of the Marital Residence previously
scheduled for the January 10,2001 at 3:30 AM, has been rescheduled to
)'~> Ft/;. ~. J.OdI,atIO:.30r::;;:-,
D~1l4I E. C'IA,'N'(J / J.
II
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KUM SOON SOL,
PlaintiffJPetitioner,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2000-6541
BRYAN HWAN SOL,
DefendantJRespond~t.
CIVIL LAW-LAW IN DIVORCE
MOTION FOR CONTINUANCE
TO THE HONORABLE JUDGE OF SAID COURT:
AND NOW COMES, Plaintiff, KUM SOON SOL, by and through her attorney,
GERALD S. ROBINSON, ESQUIRE, and respectfully requests a continuance of the within
proceeding and in support thereof states:
I. The Petition for Exclusive Possession seeking exclusive possession of the marital
residence was filed on or about December 15, 2000.
2. An Order scheduling the Hearing for January 10, 2001 was entered on
December 26, 2000.
3. Petitioner intends to submit the testimony of an expert witness, who is unavailable
on the date and time set for the hearing.
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4. Counsel for Respondent was on vacation the week of December 25, 2000;
therefore Counsel for Petitioner was unable to consult him regarding the continuance.
5. A proposal to amicable resolve this matter was sent to Respondent's counsel on
December 28, 2000.
6. Respondent is considering Petitioner's proposal for amicably resolving the issues
raised in the Petition for Special Relief.
7. Counsel for Respondent does not oppose this continuance request.
8. Counsel for Respondent is unavailable the week of January 21, 2000.
9. Neither party will suffer prejudice if this Motion is granted.
I
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WHEREFORE, Petitioner's counsel respectfully requests that this Honorable Court
reschedule the above-captioned hearing.
Dated: 1/5106
II
II
Respectfully submitted,
ROBINSON & GERALDO
By:C1AL1lri0.~ ,
Gerald S. Robinson, Esquire
Attorney I.D. No. 27423
4407 North Front Street
P.O. Box 5320
Harrisburg, Pennsylvania 17110
(717) 232-8525
Attorney for the Defendant
~~
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VERIFICATION
I verifY that the statements made in this Motion are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904,
relating to unsworn falsification to authorities.
GtJA('~rJ ~, fu& ~Ml
Gerald S. Robinson, Esquire
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CERTIFICATE OF SERVICE
I, Gerald S. Robinson, Esquire, do hereby certifY that on the 5th day of January 2000, I
caused a true and correct copy of the Motion for Continuance to be served upon the following
individual by Regular Mail:
Dann Johns, Esquire
52 South Duke Street
York, PA 17401
Respectfully submitted,
ROBINSON & GERALDO
By:
~~. R9lx"nfJIL
Gerald S. Robinson, Esquire
Attorney l.D. No. 27423
4407 North Front Street
P.O. Box 5320
Harrisburg, Pennsylvania 1711 0
(717) 232-8525
Attorney for Petitioner
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RUM SOON SOL,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DOMESTIC RELATIONS SECTION
CIVIL ACTION - SUPPORT
NO. 812 SUPPORT 2000
DR 30,049
BRYAN H. SOL,
Defendant
BRYAN H. SOL,
-~ Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DOMESTIC RELATIONS SECTION
CIVIL ACTION - SUPPORT
NO. 150 SUPPORT 2001
DR 30,452
RUM SOON SOL,
Defendant
IN RE: AGREEMENT
ORDER OF COURT
AND NOW, this 5th day of April, 2001, the above
support proceedings are dismissed and arrearages remitted,
without prejudice to the parties to raise any and all economic
issues in the context of equitable distribution. Further, it is
noted that these actions are dismissed in accordance with the
agreement of the parties, as announced in open court and in
their presence this date, which agreement is herewith made an
o:rder of court,.
By the Court,
Gerald S. Robinson, Esquire
For Kum Soon Sol
./I.1t
Hess, J.
Dann Johns, Esquire
For Bryan H. Sol
DRO
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KUM SOON, SOL,
, Plaintiff
V.
BRYAN H. SOL,
Defendant
BRYAN'H. "SOL,
Plaintiff
V.
KUM SOON SOL,
Defendant
-,~'~~.
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---"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DOMESTIC RELATIONS SECTION
CIVIL ACTION - SUPPORT
NO. 812 SUPPORT 2000
DR 30,049
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DOMESTIC RELATIONS SECTION
CIVIL ACTION - SUPPORT
NO. 150 SUPPORT 2001
DR 30,452
IN RE: TRANSCRIPT OF PROCEEDINGS
APPEARANCES:
Proceedings held before the
HONORABLE KEVIN A. HESS, J.,
Cumberland County Courthouse,
Carlisle, Pennsylvania,
on Thursday, April 5, 2001,
in Courtroom Number 4.
GERALD S. ROBINSON, Esquire
For KUM SOON SOL
DANN JOHNS, Esquire
For BRYAN H. SOL
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1 THE COURT: Now, I understand there has been
2 some resolution o'f ,this matt,er?
3 MR. ROBINSON: Yes.
4 THE COURT: Did you want to announce it, Mr.
5 RobilTSon?
6 MR. ROBINSON: Yes. May it please the
7 Court, I would just like to tell you that the parties have
8 reached an agreement with regard to the request for relief
9 that was made on behalf of the petitioner in this matter,
10 Kum Sol.
11 We have agreed that the wife, Kum Sol, would
12 be granted exclusive possession of the marital residence
13 until on or about July 1st, 2001, to accommodate the
14 children so that they don't have to move before the school
15 year ends. And we have picked July 1st as the first date
16 she would be able to get another place, an apartment.
17 We have 'reserved the child and spousal
18 support issues that both parties have against each other,
19 to be decided during the course of the equitable
20 distribution and divorce issues that will be handled by a
21 master in all likelihood.
22 We have also agreed that the house, the
23 marital residence, will be listed immediately for sale, and
24 that the proceeds will be escrowed pending the divorce.
25 And the house will be listed at $250,000.00.
2
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1 And, lastly, we have one open item, and that
2 is the accounting for December and January of this year,
3 but more "importantly December, because the accountant needs
4 that information for tax filing purposes. And we are just
5 at a-quandary for that, because at that time the defendant
6 indicated -- well, the defendant was in possession of the
7 store, but now he is indicating in here today that when he
8 closed the store and left the store he left the documents
9 in the store. And the wife does not know where they were,
10 so We do have an issue there, that although it can't be
11 resolved in terms of testimony --
12 THE COURT: Well, will he at least, as part
13 of this agreement, agree to use his best efforts to locate
14 the material?
15 MR. JOHNS: That's certainly true. And
16 that's what our agreement is, is that Mr. Sol will use his
17 best efforts and good faith to provide December and January
18 sales tax information.
19 THE COURT: Very well. Okay.
20 MR. JOHNS: Also, I would like to clarify,
21 so that the Domestic Relations knows what to do with the
22 support claims, that really for purposes of the action No.
23 812 S 2000, as well as Mr. Sol's claim against
24 Mrs. Sol -- do you have that docket number, Mr. Carothers,
25 for Mr. Sol's claim against Mrs. Sol, or would it be the
3
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1 same?
2 THE COURT: That 1 sat 150 Support 2001.
3 MR. JOHNS: Thank you. That both of those
4 claims are being discontinued, and the arrears are being
5 redu~d to zero in both claims. Both actions are being
6 suspended. However, the parties are agreeing that for
7 purposes of their equitable distribution they will be
8 addressing issues of expenditures and use of income by both
9 parties in the equitable distribution proceedings, is that
10 correct?
11 MR. ROBINSON: Are you suggesting that for
12 Domestic Relations they will no longer have to enforce it
13 or work with that at all, but those issues will remain open
14 for discussion by the divorce master?
15 MR. JOHNS: Correct. But as far as Domestic
16 Relations is concerned there is going to be no further
17 action on these matters.
18 MR. ROBINSON: I have no problem with that.
19 THE COURT: Okay. Well, then in that regard
20 I can enter an order captioned to both of the support cases
21 to this effect, And Now, this date, the above support
22 proceedings are dismissed and arrearages remitted, without
23 prejudice to the parties to raise any and all economic
24 issues in the context of equitable distribution. Okay?
25 MR. JOHNS: Yes. Thank you.
4
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1 THE COURT: Okay. And why don't I then just
2 continue that order, further, it is noted that these
3 actions are dismissed in accordance with the agreement of
4 the parties, as announced in open court and in their
5 preserlce this date, which agreement is herewith made an
6 order of court. Okay?
7
8
MR. JOHNS: Yes.
MR. ROBINSON: Your Honor, we would like an
9 order on the exclusive possession until July 1st. We have
10 agreed that --
II THE COURT: Well, I have actually made
12 everything that you agreed on an order of court. I don't
13 think there is any question about that. And we will have
14 that transcribed, and Mrs. Graham can send a copy to both
15 of you. But I think it is pretty clear from what I said,
16 that your agreement as stated becomes the order of this
17
18
19
20
21
22
23
24
25
court.
MR. JOHNS: Thank you.
MR. ROBINSON: Thank you, Your Honor.
(End of proceedings)
5
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CERTIFICATION
--:
I hereby'certify that the proceedings are
contained fully and accurately in the notes taken by me on
the abovecause and that this is a correct transcript of
same.
Barbara E. Graham
Official Stenographer
The, foregoing record of the proceedings on
the hearing of the within matter is hereby approved and
directed to be filed.
Date
Kevin A. Hess, J.
Ninth Judicial District
6
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
,
PENNSYLVANIA
KUM SOON SOL
v.
00-6541 CIVIL
BRYAN KWAN SOL
IN DIVORCE
DEFENDANT'S RULE 1920.33 STATEMENT
I. LIST OF ASSETS
See attached Inventory.
II. EXPERT WITNESSES
Cindy Varhola (Realtor currently employed by both of the parties), on the
value and marketing of the marital home.
III. FACTUAL WITNESSES
1. Bryan Sol, on all issues.
2. Kum S. Sol, on all issues.
3. Cindy Varhola, Realtor, marketing of home.
4. Various Korean business people, value of grocery store business.
5. [Defendant reserves right to name additional witnesses on Issues of
authentication and hearsay where documentary evidence cannot be stipulated to]
6. Representative of Korean Union Kay, regarding monies received by Mrs.
Sol.
IV. EXHIBITS
1. Listing agreement for sale of home.
2. Foreclosure pleadings
3. Bank account statements & checks
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4, Documents of Korean Union Kay
5, Statements of account for Toyota loan
6. [Defendant reserves the right to identify additional exhibits to refute
Plaintiff's yet undisclosed evidence]
V. GROSS INCOME FROM AIL SOURCES
Wife's projected annual gross income from operation of the grocery store is
$65,000.
Husband works as a cashier for minimum wage,
VI. E::\."PENSES OF THE PARTIES
Wife's income is more than sufficient to pay her expenses, although she has
not been paying the mortgage on the marital home in which she resides.
Husband's income is not sufficient to pay his expenses, so he lives with
relatives. His expenses consist of repayments of monies lent to him by his family, payments
on the Toyota truck, food, clothing, and medical bills stemming from his diagnosis of post-
traumatic stress disorder (following an armed robbery at the grocery store in December
2000).
VII. PENSION OR RETIREMENT BENEFITS
None.
VIII. COUNSEL FEES
Not at issue presently.
IX. TANGIBLE PERSONAL PROPERTY
At this time, it is not apparent whether there is a dispute as to distribution or
valuation.
X. MARITAL DEBTS
See attached Inventory form.
. ,
~ ,
XI. PROPOSED RESOLUTION OF ECONOMIC ISSUES
..-
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The marital estate should be divided equally, with wife to pay husband an
alimony of 30% of the difference between their net incomes. Alternatively, husband should
receive a distribution of sixty percent of the marital estate.
Respectfully submitted,
DannJohns, Esquire ~.
52 South Duke Street
York, Pennsylvania 174' 1
741-4717 telephone
741-0368 fax
J ohnsdann@aoLcom
ID 52681
Attorney for Bryan Kwan Sol
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I certify that I shall serve a true and correct copy of the foregoing document this day in the
manner indicated below, which service satisfies the requirements of the Pennsylvania Rules
of Civil Procedure:
VIA FIRST CLASS U.S. MAIL
Gerald Robinson, Esquire
P.O. Box 5320
Harrisburg PA 17110-5320
Office of the Divorce Master
9 North Hanover Street
Carlisle P A 17013
Dann Johns, Esquire l
52 South Duke Street y
York, Pennsylvania 17401
741-4717 telephone
741-0368 fax
J ohnsdann@aoLcom
ID 52681
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KUM SOON SOL,
Plaintiff,
v.
BRYAN KWAN SOL,
Defendant.
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IN THE COURT OF COMMON PLEAS
DAUPHIN COUNTY, PENNSYLVANIA
NO. 00 - 6541 CIVIL
CIVIL ACTION - LAW IN DIVORCE
PLAINTIFF'S PRE-TRIAL STATEMENT
Kum Soon Sol, the Plaintiff, by and through her attorney, Gerald S. Robinson, Esquire,
files the following Pre-Trial Statement:
1. Background Information
2. Listing of Marital Assets and Debts
3. Listing of Personal Property
4. Listing of Non-Marital Property
5. Pensions
6. Income and Expenses
7. Counsel Fees and Costs
8. Expert Witnesses
9. Non-Expert Witnesses
" ~
10. Listing of Proposed Exhibits
I I. Proposed Resolution
Dated: "tll0{ 0 I
.
Respectfully submitted,
ROBINSON & GERALDO
By:
~~
Gerald S. Robinson, Esquire
Attorney I. D. No. 27423
4407 North Front Street
P. O. Box 5320
Harrisburg, PAl 711 0
(717) 232-8525
Attorney for Plaintiff
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1. BACKGROUND INFORMATION
A. PARTIES
HUSBAND
NAME Bryan Kwan Sol
ADDRESS UNKNOWN
AGE 47
DATE OF BIRTH 2/10/54
PLACE OF BIRTH Targu City, South Korea
SOCIAL SECURITY NUMBER 203-58-4654
HEALTH Unknown
EMPLOYER NONE
OCCUPATION Unknown
LENGTH OF RESIDENCY IN P A 20 years
EDUCATIONAL BACKGROUND High School
, ,WIFE,
NAME Kum Soon Sol
ADDRESS 3819 Chippenham Drive
Harrisburg, P A 17055
AGE 46
DATE OF BIRTH 8/9/54
PLACE OF BIRTH Seoul, South Korea
SOCIAL SECURTIY NUMBER 229-29-6811
HEALTH Good
EMPLOYER Self Employed
OCCUPATION Shop Owner
LENGTH OF RESIDENCY IN P A 18 years
EDUCATIONAL BACKGROUND High School
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B. CHILDREN
NAME AGE DATE OF BIRTH CUSTODIAN
Minwoo Sol 16 4/5/85 Kum Soon Sol
Mintei Sol 14 11/28/86 Kum Soon Sol
C. MARRIAGE INFORMATION
DATE OF MARRIAGE 5/19/83
PLACE OF MARRIAGE Chambersburg, P A
DATE OF SEPARATION September 2000
CIRCUMSTANCES OF SEPARATION The marriage is irretrievably
broken.
D. PRIOR MARRIAGES
I__
HUSBAND
I Non,
None
E. CHILD OF OTHER RELATIONSHIPSIMARRIAGES
WIFE
None
HUSBAND
None
F. PROCEEDING INFORMATION
DATE ACTION COMMENCED 9/15/00
DATE OF SERVICE OF COMPLAINT 9/17/00
MANNER OF SERVICE OF United States Certified Mail Return
COMPLAINT Receipt Requested Restricted
Delivery
ISSUES RAISED IN DIVORCE Complaint in Divorce under ~3301
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COMPLAINT
(c), Equitable Distribution,
Custody, Counsel's Fees and
Expenses, and Alimony and
Alimony Pendende Lite
Custody and Support
PREVIOUSLY RESOLVED ISSUES
2. MARITAL ASSETS AND DEBTS
The following is a listing of the marital assets and debts of the parties:
ITEM DESCRIPTION TOTAL HUSBAND'S WIFE'S
NO. VALUE POSSESSION POSSESSION
REAL ESTATE
1 3819 Chippenham Dr. $257,000.00 -/ ./
Harrisburg, P A
2 17m and Regina Streets $120,000.00 ./
Harrisburg, P A
VEHICLES
3 1992 Mercedes 300E $16,410.00 -/
4 I 997Toyota Tacoma Short $14,605.00 -/
Bed
5 1985 Toyota Tercel $ 750.00 -/
BANK ACCOUNTS-aDioint bank accounts have been closed
PENSIONS - NONE
LIFE INSURANCE
6 Met Life (Term Life) $0.00 -/
STOCKS AND BONDS - NONE
HOUSEHOLD GOODS
7 Kitchen furnishings, Unknown -/
supplies, and utensils.
Furniture from living
room, guest room, and
children's bedrooms.
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DEBTS ,
8 Bank One Mortgage Mortgage Kum and $168,735.94
Corporation Byran Sol
3. LISTING OF PERSONAL PROPERTY
ITEMS RETAINED BY WIFE
DESCRIPTION VALUE
Kitchen furnishings, supplies, and utensils.
Furniture from living room, gnest room,
and children's bedrooms
ITEMS RETAINED BY HUSBAND
DESCRIPTION VALUE
Unknown
4. LISTING OF NON-MARITAL PROPERTY
The following is a listing of the non-marital assets of the parties:
NO. DESCRIPTION BASIS OF OWNER
EXCLUSIONS
1. N/A N/A
,
,
5. PENSIONS ,
The following is a listing of the pensions of the parties: ,
I Hu,b""d PARTY I~~~: DESCRIPTION .
Wife
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6. INCOME AND EXPENSES
The following is a listing of the income and expenses of the parties:
PARTY
Husband
DESCRIPTION
AMOUNT
Gross Monthly Income Unknown
Monthly Expenses
Net Monthly Income
Wife
Gross Monthly Income
Monthly Expenses
Net Monthly Income
$6,000.00
$4,000.00
$2,000.00
7. COUNSEL FEES
The following is a listing of the counsel fees and expenses incurred, or to be incurred by
the parties:
PARTY DESCRIPTION DATES AMOUNT
Husband
Counsel Fees Unknown
Costs
Anticipated Costs
and Fees
Wife
Counsel Fees 9/13/00 - 7/10/01 $12,322.50
Costs $ 122.74
Anticipated Costs Unknown
and Fees
8. EXPERT WITNESSES
The following is a listing of the anticipated experts who will be called to testifY in
this case:
I None
NAME
SUBJECT OF TESTIMONY
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Additional experts who may be called to testifY are not known at this time. If such
additional experts are retained, the Defendant reserves the right to call them as witnesses upon
proper notification to the Plaintiff.
9. NON-EXPERT WITNESSES
NAME SUBJECT TO TESTIMONY
Kum Soon Sol History of the marriage; identification
and valuation of marital assets and
debts; other relevant testimony relating
to the factors set forth in the Divorce
Code.
Bryan Kwan Solon cross- History of the marriage; identification
examination and valuation of martial assets and
debts; other relevant testimony relating
to the factors set forth in the Divorce
Code.
Additional witnesses who may be called to testifY are not known at this time. If such
additional witnesses are identified, the Defendant reserves the right to call them as witnesses
upon proper notification to the Plaintiff.
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.
10. LISTING OF PROPOSED EXHIBITS
The following is a listing of the Exhibits, which are anticipated to be submitted at the
hearing in this case:
NO. DESCRIPTION
1 Mortgage Statement (Good through 7/30/01)
2 Listing Contract of Marital Residence
3 Kelley Blue Book Value of 1997 Toyota Tacoma Short Bed
4 Kelley Blue Book Value of 1992 Mercedes 300E
5 GMAC Mortgage Corporation Default Notice
6 1999 Joint Income Tax Return
7 Satisfaction of Mortgage Default
8 Domestic Relations Order
9 Custody Order
10 Kelley Blue Book Value of 1985 Toyota Tercel
If additional Exhibits are identified, the Defendant reserves the right to submit any
additional Exhibits upon proper notification to Plaintiff.
11. PROPOSED RESOLUTION
A. EQUITABLE DISTRIBUTION
The parties have been discussing how the marital estate should be divided since the
divorce complaint was filed in September oflast year. In this regard. Plaintiff contends that she
should receive a 60 percent distribution because she has custody of the two teen-age boys and the
other factors specified in the Divorce Act are essentially equal when the parties are compared.
Initially, the parties based their proposed distribution of the marital estate on Defendant
receiving the family business (a grocery store located at 17th and Regina Streets in Harrisburg,
,
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which they agreed was worth $120,000.00), and Plaintiff receiving the marital residence (located
in a desirable neighborhood in Mechanicsburg, with a stipulated net equity of $70,000.00)
because Defendant had exclusive possession of the store since September of 2000 which he kept
until mid-February when he liquidated the stock and closed the store. During this period
Defendant had total control over the parties' sole income stream and after he closed the store,
expenses associated with the operation of the store remained unpaid and are still outstanding.
In mid-February of 200 I, Plaintiff re-opened the store under her name and established
new accounts with vendors and utility companies. The parties revised their distribution proposal
so that it was now based on Plaintiff receiving the store and Defendant receiving the marital
residence. In this regard they agreed that Plaintiff would take over the management of the store
and enjoy exclusive possession of the marital residence until she and the children moved into an
apartment. The move is planned for August 4, 2001 and the marital residence has been listed for
sale.
Plaintiff, relying on the above proposal, invested over $15,000.00 into the store's needed
repairs and other cosmetic renovations. She has also spent $1,500.00 preparing the marital
residence for sale.
Defendant, claiming to be disabled, is not providing any support for his family.
With regard to the assets of the parties, Plaintiff proposes that the marital estate be
divided as follows. Plaintiff would be awarded the family business (including the real estate)
-~~
and Defendant would be awarded the marital residence (or the proceeds of its sale if that occurs
first). Since the assets havlil a stipulated total value of$190,000, Defendant (assuming a 60/40
division) would be entitled ito $76,000.00 which would result from the sale of the marital
residence ($70,000.00 expected net proceeds), but he would have to reimburse Plaintiff for the
expenditures she made in making the house ready for sale ($1,500.00) and for half of the amount
Plaintiff paid to cure the mortgage default ($6,000.00). Hence, Defendant would be awarded the
marital residence or the proceeds of its sale and the Plaintiff would be awarded the family
business.
With regard to the ei'penses associated with the store, each of the parties would be
responsible for the expenses generated during their respective periods of exclusive possession
and they would share the expenses during the period January through August 2000 when they
jointly operated the store. Therefore, with regard to their 2000 income taxes, Defendant would
be liable for 2/3 of the tax liability, since he had exclusive possession of the store for four
months in the year 2000, and Plaintiff would be responsible for most of the 2001 income tax
liability since she bad exclusive possession ofthe store for 10 Y:z months.
Since the parties are essentially equal insofar as their ability to earn money,
alimony is not warranted- especially since Defendant closed the store, liquidated its assets and
attempted a distressed sale of the building.
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Federman and:rhel~, LLP
One Penn Center at'Suburban Station
1617 John l?Kenn~~y B~ulevard
Suite 1400 .
Philad~phia,:ra,'19~ 03
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215-563-7000' "
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Fax 215-568-0719
Email: CO\111l1ev.bambribffifedphe.com
PAYOFF FJiGURE
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NAME: SOL, MYONG &. KUM' ; ACC~ #': 7856842
DATE 07-16-01 . " " i ONLY Good Through 07/30/01
,
Principal Balance
Interest
Escrow Advance
Late Charges
Property Insp.jMaint.
Pro Rata MIPjPMI
Release/Recording Fees
Tax Payments
NSF Fees
Corp. Adv.
Suspense
$160,606.00
$6,514.44
$32.00
$95.00
Attorney Costs
Attorney Fees
Sheriff's 2%
$838.50
$650.00
TOTAL
I
$168,735.941
ALL FUNDS KU8T BE
IN FULL AND IN
CERTIFIED FORM
FORWARDED TO OUR
FIRM
Pleuc bt' advised that this firm is.t debt coJle.ctor attempting to called: a debt. Any iorarmatioR rectivtd will be Psed for that purpoS4!. I(you haYC n::ccivcd 11
4isdt=-rge III baD,kruptcy~ and this debt was aat ream.-med. tbls coCTt$lOndence J$ not ~nd sbl)uld not be! construed to be an u,tt.empt to collect ~ debtt bltt onl)'
catorccmcat ufa lieD against PtoPetlf.
As oClhe .ate oerbis roMD1Unllf:ldolft YOD bWr the amoDDhpwGcd. ~ust 6r"'ter~ late ~arg~ and Dthtl' m3.TJtu Ulat amy vary (~m Wl)' to d",)\ tile :tIIIO'unt
due 00 tbc dayyou pay DUly be greater. Hel1~ iryou pay the amoulltshDWll.abovt', an adjustmeut ~y be De~r'1 alltr we recelve-:your dlttk, in which event we:
wm iDfonn you. bcl'on: depositing the c:Ju:ck. tur coUtUiOI). For tardier Information, write tbe uadcrsfgncd or call (liS) 563-7000 and Mk (01' the I'teinstatenlerzt
Depq;"~t..
IFtbh- is the rmt notice that )'00 have rcedyed Item tbls office. be ac1vbe6 that: You may IfJ5)dltIl' the wUdity DrUm debt or j,lrf -poJ1iQ" theteOr. If)'o\l do so in
writing w1tbin thirty (30) d3)'$ of receipt ofthls letter, tbk Gnn win obtain and 9l'O'Vide )'0'11' writull verl:GcacfoQ thereof; otherwiSt\. tbe deW: will- be: assumW. to be
,..nil. Llkewis<<; yuu mar .-equest tbe' nAme IInd ackfress or,he: orlgin1 oeditar ifdiffel'ent from abovt.
EXHIBIT
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'ING CONTRACT
EXCLUSIVE RIGHT TO SELL REAL PROPERTY
This fO~ recomme~d and approved for. but 1101 restricted to use by, the members of J.he Pennsylvria Association of REALTORS<<r (PAR).
BROKER (Company) ./{-11 ~~NCy 1dM.,41"' Pr-AL r-:<rrA-r(.;
~~t~~~EEHyo2;t[}Y <l~D":~~ .":MJJ ~L.
I. PROPERTY
Add,ess ~slq C/o//fI?t=.JIf,.4& D!1IV~ ~{l>l
Municipality (city, borough, township) J-fA1J.,;freJ
County CJJMfJ~t2J .M)n
Zoning and Present Use D~~IDI=JJr'4'-"
Identification Number (For example, tax identification number; parcel number; deed book, page, recording date)
XLS
LISTED PRICE $ .;:\ ?: ') ~OO .
'fA /'7 at:;t:;'
School District r-.(UA ~~p l--:~I.) J)
2. STARTING & ENDING DATES OF LISTING CONTRACT (also called "Term")
A. No Association of REALTORS@has set or recommended the term of tltis contract. By law, the length or term of a listing con-
tract may not exceed one year. Broker an<;t Seller have discussed and agreed upon the length or term of this contract.
B. Starting Date:' This Contract starts when signed by Broker and Seller, unless otherwise stated here:
C. Ending Date: This Contract ends on q / ~ 0 /0 I
3. PURPOSE OF THIS CONTRACT Seller is hiring Broker to market Property and to find a buyer. Seller will refer all offers and
inquiries to Broker. Seller allows Broker to use print and/or electronic advertising. Broker is acting as Seller Agent, as described
in the Consumer Notice.
4. BROKER)S FEE No Association ofREALTORS@hassetorrecommendedtheBroker's Fee. Broker and Seller have negotiated
the fee Ihat Seller will pay Broker. The Broker'~ Fee is ?, t1/n of/from the sale price and paid by Seller.
S. COOPERATION WITH OTHER BROKERS Licensee has explained Broker's company policies about cooperaling with other
brokers. Broker and Seller agree that Broker will pay from Broker's Fee:
A. A fee to another broker who represents the Sener (SUBA,GEN'f).
D No I!I Yes If Yes, amount: ,;; c9h, of/from the sale price.
B. A fee to another broker who represents a buyer (BUYER'S AGENT). A Buyer)s Agent) even if compensated by Broker
or Seller, will represent the interests of the buyer.
D No ts Yes lfYes, amount: 3 C)fr. of/from the sale price.
C. A fee fo another broker who does not represent either the Seller or a buyer (TRANSACTION LICENSEE).
D No 0 Yes If Yes, amount: ~ e.t. of/from the sale price.
6. PAVMENT OF BROKER'S FEE .
A. Seller must pay Broker's Fee if Property, or any ownership interest in it, is sold or exchanged during the length or term
of this Contract by Broker, Broker's agents, Seller, or by any other person or broker, at the listed price or any price
acceptable to Seller.
.8. Seller will pay Broker's Fee if negotiations that are pending at the Ending Date of this Contract resuil in a sale.
C. Seller will pay Broker's Fee after the Ending Date of this Contract IF:
(I) A sale occurs within ~ days of the Ending Date, AND
(2) The buyer was shown or negotiated to buy the Property during the [enn of this contract.
Seller will not owe Broker's Fee if the Property is listed under an "exclusive right to sell contract" with another broker
at the time of the sale.
7, llROKER'S FEE IF SALE DOES NOT OCCUR
A. Seller will pay Broker's Fee if a ready, willing, and able buyer is found by Broker or by anyone, including Seller. A
willing buyer is one who will pay the listed price or more for the Property, or one who has submitted an offer accepted by
Seller.
:8. If the Property or any part of it is taken by any government for public use (Eminent Domain), Seller will pay Broker
b ~.t, of/from any money paid by the government.
C. If a buyer signs an agreement of sale then refuses to buy the Property, or if a buyer is unable to buy it because of failing to do
all the things resuired of the buyer in the agreement of sale, Seller will pay Broker:
(1) ;"0 Y.., of/from buyer's deposil monies, OR
(2) the Broker's Fee in Paragraph 4, whichever is less.
8. DUAL AGENCY Seller agrees that Broker may also represent the buyer(s) of the Property. Broker is a DUAL AGENT when
representing both Seller and the buyer in the sale of a property.
Designated Agency:
~ Not Applicable.
[J Applicable. Broker, as the Dual Agent, may designate licensees to represent the separate interests of Seller and the buyer.
Licensee (identified above) is the Designated Agent, who will act exclusively as the Seller Agent. If Property is introduced to
the buyer by a licensee In the Company who is not representing the buyer, then that licensee is authorized to work on behalf
of Seller. If Licensee is also the Buyer Agent, then Licensee is a DUAL AGENT.
9. 8ROKER'S SERVICE TO BUYER Broker may provide services to a buyer for which Broker may accept a fee. Such services
may include, but are not limited to, deed/ documenf preparation; ordering certifications required for closing; financial services; title
[fansfer and preparation services; ordering insurance, construction, repair, 01 inspection services. Broker will disclose to Seller if
any fees are to be paid by Buyer.
10. OTHER PROPERTIES Seller agrees that Broker may list other properties for sale and that Broker may show other properties
tD prospective buyers.
11. CONFLICT OF INTEREST A conflit'1 of interest \s when Broker or Licensee has a financial or personal interest where Broker
or Licensee cannot put Seller's interests before any other. If the Broker, or any of Broker's salespeople, has a conflict of interest,
Broker will notify Seller in a timely manner.
Seller Initials \. \))U .K. ____
m Pennsylvania Association of
I...[! REALTORS"
""AllOR" ..._..R.........~.........,_
Page 1 of 3
BrokerlLicensee Initials
COPYRIGHT PENNSYLVANIA ASSOCIATION OF REALTORS""I996
llJ99
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EXHIBIT
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12. SETTLEMENT & POSSESSION
A. Preferred Settlement Date: 111) n~ A':, .J ~ 8 J!ln. J c J
B. Seller will give possession of the Property to Buyer at settleiheot ~r 00 .
c. (1) If the ,Property, OJ an.y part of it, is rented, Seller will give any leases 'to Broker Hefore signing this Contract.
(2) If any leases are ora.l, Seller will provide a written summary of the renns, including amount of rent, ending date, and
Tenant's responsibilities.
(3) Seller will not enter into or renew any lease during the term of this Contract except as follows:
13. TITLE
A. At settlement, Seller will give full rights of ownership (fee simple) to a buyer except as follows:
(I) Mineral Rights Agreements
(2) Other
B. Seller has;
J!iJ Yes 0 No
Mortgage with
Address
Acct.#
EqUity loan with
Address Phone
Acct. # Amount of balance $
Seller authorizes Broker to receive mortgage payoff and/or equity loan payoff information from the
lender.
Past Due Taxes
J1ldgments
Type
Municipal Assessments
Other
Amount $
C. If Seller, at any time on or since January I, 1998, has been obligated to pay support under an order that is on record in any
Pennsylvania COUnly, list the county and the Domestic Relations Number or Docket Number;
14. MULTIPLE LISTING SERVICE (MLS) (Complete if Broker is a member of an MLS)
%1 Broker will use a Multiple Listing Service to advertise the Property to other real estate salespersons, who can tell their clients
and customers about it. Seller agrees that the MLS, the Broker, and the Licensee are not responsible for mistakes in the MLS
description of the Property.
o Broker will not use a Multiple Listing Service to advertise the Property to other real estate salespersons.
IS, PUBLICATION OF SALE PRICE
A. Seller is aware that newsj)apers may publish the final sale price after settlement.
B. Seller will allow publishing of the sale price after Seller accepts an Agreement of Sale.
o Yes }I!f No
16. SIGNS & KEYS Seller allov,rs (where pennitted):
til Yes 0 No Sale Sign
DYes 0 No Key in Office
DYes 0 No
17. ITEMS INCLUDED IN THE PRICE OF THE PROPERTY
A. Included in the sale and purchase price are all existing items permanently installed in the Property, free of liens. including
plumbing; heating; lighting fixtures (including chandeliers and ceiling fans); water treatment systems; pool and spa equipment;
garage door openers and transmitters; television antennas; shrubbery, plantings, and unpotted trees, any remaining heating and
cooking fuels stored on the Property at the time of settlement; wall to wall carpeting; window covering hardware, shades, and
blinds; built-in air conditioners; built-in appliances, and the range/oven. Also included:
Phone
Amount of balance $
DYes
o No
DYes
o No
DYes
DYes
o No
o No
Amount owed $
Amount $
DYes
DYes
o No
o No
Amount $
lil Yes
.Ill Yes
o No Sold Sign
o No Lock Box
B. 0 See attached sheet for additional items included in the sale.
18. ITEMS NOT INCLUDED IN THE PRICE OF THE PROPERTY
The following items are not included in the purchase and price of the Property:
A,
B. Items renled by the Seller
C. 0 See attached sheet for additional items not included in the sale.
19. SELLER WILL REVEAL DEFECTS & ENVIRONMENTAL HAZARDS
A. Seller (including Sellers exempt from the Real Estate Seller's Disclosure Act) will disclose all known material defects and/or
environmental hazards on a separate disclosure statement. A material defect is a problem or condition that:
(1) is a possible danger to those living on the Property, or
(2) has a significan!, adverse effect on the value of the Property.
B. If Seller fails to tell of known material defects and/or environmental hazards,
(1) Seller will not hold Oroter or Licensee responsible in any way;
(2) Seller will protect Broker and Licensee from any claims, lawsuits, and actions tOOt result;
(3) Seller will pay all of Broker's and Licensee's costs that result. This includes attorneys' fees and court-ordered paymems
or settlements (money Broker or Licensee pays to end a lawsuit or claim).
20. IF PROPERTY WAS BUILT BEFORE 1978 The Residential Lead-Based Paint Hazard Reduction Act says that any Seller of
properly built before 1978 mllst give the buyer an EPA pamphlet titled Protect Your Family From Lead in Your Home. The Seller
also must tell the buyer and the Broker what the Seller knows about lead~based paint and lead-based paint hazards that are in or on
[he property being sold. Seller must tell the buyer how the Seller knows that lead-based paint and lead-based paint hazards are on
the property, where the lead-based paint and lead-based paint hazards are, the condition of the painted surfaces, and any other infor-
mation Seller knows about leild-based paint and lead-based paint hazards on the property. Any Seller of a pre-1978 structure must
also give the buyer any records and reports that the Seller has or can get about lead-based paint or lead-based paim hazards in or
around the property being sold. the common areas, or other dwellings in multi-family housing. According to the Act, a Seller must
give a buyer 10 days (unless Seller and the buyer agree to a different period oftime) from the time an Agreement of Sale is signed
to have a "risk asses~ment" Qr inspection for possible lead-based paint hazards done on the property. Buyers may choose not to
have the risk assessment or inspection for lead paint hazards done. If the buyer chooses not to have the assessment or inspection,
the buyer must infollu the Seller in writing of the choice. The Act does not require the Seller to inspect for lead paint hazards or to
correct lead paint hazards on the property. The Act does not apply to housing built in 1978 or later.
S..U..r Initials < 061- 1/. Page 2 of 3 Broker/Licensee Initials
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21. DEPOSIT MONEY
A. Broker. or any person Seller and the buyer name in the Agreement of Sale, will keep all deposit monies paid by or for the buyer
in an escror account.}f held by Broker, this escrow account will be held as required 'by real estate licensing laws and regula-
tions. Seller agrees that the person keeping the deposit monies may wait to deposit any uncashed check that is received as
deposit money until Seller has accepted an offer.
B. If Seller joins Broker or Licensee in a lawsuit for the return of deposit monies, Seller will pay Broker's and Licensee's attor-
neys' fees and costs.
22. RECOVERY FUND Pennsylvania has a Real Estate Recovery Fund (the Fund) to repay any person who has received a final
court ruling (civil judgment) against a Pennsylvania real estate licensee because of fraud, misrepresenlation, or deceit in a real
estate transaction. The Fund repays persons who have not been able to collect the judgment after trying all lawful ways to do so.
For complete details about the Fund, call (717) 783-3658, or (800) 822-2113 (within Pennsylvania) and (717) 783-4854 (outside
Pennsylvania).
23. TRANSFER OF THIS CONTRACT
A. Broker will notify Seller immediately in writing if Broker transfers this Contract to another broker when:
(I) Broker srops doing business, OR
(2) Broker forms a new real estate business, OR
(3) Broker joins his business with another.
Seller agrees that Broker may transfer this Contract to another broker. Broker will notify Seller immediately in writing when
a transfer occurs or Broker will lose the right to transfer this Contract. Seller will follow all requirements of this Contract with
the new broke:r.
B. Should Seller give or transfer the Property, or an ownership interest in it, to anyone during the term of this Contract, all OWI1-
ers will follow the requirements of this Contract.
24. NOTICE TO PERSONS OFFERING TO SELL OR RENT HOUSING IN PENNSYLVANIA Federal and state laws make
it illegal for Seller, Broker, or anyone,to use RACE, COLOR, RELIGION or RELIGIOUS CREED, SEX. DISABILITY (physical
or mental). FAMILIAL STATUS (children under 18 years of age), AGE (40 or older), NATIONAL ORIGIN, USE OR HANDl-
ING/TRAINING OF SUPPORT OR 'GUIDE ANIMALS, or the FACT OF RELATIONSHIP OR ASSOCIATION TO AN INDI-
VIDUAL KNOWN TO HAVE A DISABILITY as reasons for refusing to sell, show, or rent properties, loan money, or set deposit
amounts, or as reaSons for any decision relating to the sale of property.
25. NO OTHER CONTRACTS Seller will not enter into another listing agrecment with another broker that begins before the
Ending Date of this Contract.
26. ADDITIONAL OFFERS ONCE SELLER ENTERS INTO AN AGREEMENT OF SALE. BROKER IS NOT REQUIRED TO
PRESENT OTHER OFFERS,
27. ENTIRE CONTRACT This Contract is the entire agreement between Broker and Seller. Any verbal or written agreements that
were made before are not a part of this Contract.
28. CHANGES TO IHIS CONTRACT All changes to this contract must be in writing and signed by Broker and Seller.
29. SPECIAL INSTRUCTIONS The Office of Auomey General has nor pre-approved any special conditions or additional terms
added by any pardes. Any special instructions in the Contract must comply with the Pennsylvania Plain Language Consumer
Contract Act.
ADDITIONAL INFORMATION (OPTIONAL)
30. TAXES, UTILITIES, & ASSOCIATION FEES
A. At settlement, Seller will pay one-half of the total Real Estate Transfer Taxes, unless otherwise stated here:
B_ Real Estate Property Tax Assessment $ Yearly Taxes $
Wage/lncome Tax Per Capita Tax $
C. Estimated Utilities (trash, water, sewer, electric, gas, oil. etc.)
D. Association F~es $ Include:
E. Other
31. BUYER FINANCING Seller will accept the following arrangements for buyer to pay for the Property:
IiQ Cash
o Buyer will applY for a mortgage. Type(s) of mortgages acceptable to Seller are:
m Yes 0 No Conventional 0 Yes 0 No FHA
't)(l Yes 0 No VA 0 Yes 0 No
o Seller's help to buyer (if any):
Seller has read the Consumer Notice as adopted by the State Real Estate Commission at 49 Pa. Code 935.336. All Sellers must
sig., this Contract.
ELLER HAS LEGAL QUESTIONS, SELLER IS ADVISED TO CONSULT AN ATTORNEY.
DATE 4-'-?-C;/
SS# -'I. ^~ -"t',..,..A'.3(L'
o
SELLER
Name (prin
Mailing Address
Phone#s ~-. FAX #
SELLER -r! \-A-
Name (print)~ at-
Mailing Address
Phone #s
FAX #
SELLER
Name (print)
Mailing Address
Phone #s
FAX #
BROKER (Company Name)
ACCEPTED BY
Mailing Address
Phone #s
FAX #
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Kelley Blue Book Used Car Values
Page 1 of2
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USed Car Values
N_ Car Pridll!!l
MlltOrtydes
Buy" New Car
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$ell Your Car
Finandll!!l
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Blue Book Retail Report
Pennsylvania' February 27, 2001
1997 Toyota Tacoma Short Bed
Engine: 4-Cyl. 2.4 Liter
Trans: Automatic
Drive: 4 Wheel Drive
Mileage: 40,000
Wavs to Buv a Used Car
Wavs To Buv a New Car
List Your Car For Sale Online
Financino Ouote
Insurance Ouote
Warranty Ouote
Parts & Accessories
pavment Calculator
Equipment
SX
Air Conditioning
Power Steering
Power Windows
Power Door Locks
Tilt Wheel
Cruise Control
AM/FM Stereo
Cassette
ABS (4-Wheel)
Power Seat
Alloy Wheels
Retail Value
$14,605
Suggested retail represents the price a dealership might ask for this make and
model vehicle. This represents a fully reconditioned vehicle in excellent
condition with a clean title history. This retail price is not a trade-in or private-
party value, but rather assumes that a dealer has absorbed the cost of making
the vehicle ready for sale, reconditioning, advertising, sales commissions,
arranging for financing and insurance and standing behind the vehicle for any
mechanical or safety problems. Many late model vehicles at this price have
passed an inspection program or carry a warranty. Actual dealer selling price
may vary from this price.
Copyright @ 2001 by Kelley Blue Book Co., All Rights Reserved. Jan-Feb 2001 Edition. The information
in this report was printed from the KellE!!Y Blue Book Web site (www.kbb.com) and is intended for the
personal use of the customer only and may not be sold or transmitted to another party. We assume no
responsibility for errors or omissions.
EXHIBIT
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USed Car Values !
New Car Pridllg ,
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Financing
ln$urlm<:e
Lemon (heck
w_nties
Car ItIlvitIw$
Car Previews
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Abo!lt kbb
Home
Click on the image above to visit this advertiser
Blue Book Retail Report
Pennsylvania' February 27,2001
1992 Mercedes-Benz 300E 3.0 Sedan 40
Engine: 6-Cyl. 3.0 Liter
Trans: Automatic
Drive: Rear Wheel Drive
Mileage: 80,000
Ways to Buy a Used Car
Wavs To Buv a New Car
List Your Car For Sale Online
Financina Ouote
Insurance Ouote
Warranty Ouote
Parts & Accessories
Payment Calculator
Equipment
Air Conditioning
Power Steering
Power Windows
Power Door Locks
Telescoping Wheel
Cruise Control
AMjFM Stereo
Cassette
Dual Air Bags
ABS (4-Wheel)
Slip Control
Leather
Dual Power Seats
Sliding Sun Roof
Alloy Wheels
Retail Value
$16,410
Suggested retail represents the price a dealership might ask for this make and
model vehicle. This represents a fully reconditioned vehicle in excellent
condition with a clean title historv. This retail price is not a trade-in or private-
party value, but rather assumes that a dealer has absorbed the cost of making
the vehicle ready for sale, reconditioning, advertising, sales commissions,
arranging for financing and insurance and standing behind the vehicle for any
mechanical or safety problems. Many late model vehicles at this price have
passed an inspection program or carry a warranty. Actual dealer selling price
may vary from this price.
Copyright @ 2001 by Kelley Blue Book Co" All Rights Reserved. Jan 'Feb 2001 Edition. The information
in this report was printed from the Kelley Blue Book Web site (www.kbb.com) and is intended for the
personal use of the customer only and may not be sold or transmitted to another party. We assume no
responsibility for errors or omissions.
EXHIBIT
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2/27/01
http://www.kbb.com/kblki.dl1/kw.kc.ur?kbb;
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07/17/01 TUE 14:52 FAX 2155680719
,
REINSTATE DEPT
141002
<
Fede~an and Phelan, LLP
One Penn Center at Suburban Station
1617 John F. Kennedy Boulevard
Suite 1400
Philadelphia, PA 19103
215-563-7000
Fax 215~S68-0719
Email: kamiel.houston@fedphe-pa.com
Kamiel A. Houston
Legal Assistant Bxt. 1262
Representing Lenders in
Pennsylvania & New Jersey
REINSTATEMENT FIGURE
NAME: Sol, Myong & Kum ACCT. 7856842
DATE: 7/17/01 Good Through 07/30/01
Payments Due (6)
Late Charges
Property Inspection
$9,410.76
$470.52
$40.00
Attorney Costs
Attorney Fees
$838.50
$650.00
$11,409.781
TOTAL
ALL FUNDS MUST B:B IN FULL IN CERTIFJ:ED FORM AND FORWARDli:D TO OUR. FIRM
REINSTATEMENT FIGURES MUST BE VERIFIED PRIOR ~O SUBMITTAL!
EXHIBIT
..Plc~~c be adv~eed ~e this fir.m 1s a debc co11ecto. att~~ing to dolleo~ A deh~. Any
info:r:mation z;-eceive4 will ;be ued. for t:hat purpose. If you ha.ve received Q c:li&cb;.\~ 10.
bahkrupt.cy, and this debt was not .8affi~g,1 tbi= eO"e:C::POh~e is not. and should not be
con:::.t:.~~ to be an attempt. to col.lect a. debt,. but; only Qnforc~ent. of a lien a.gainst prope~
j
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[)epartrnerlt d tho Treasury. ~I Revenue seMctt l \ \
1040 U.S. Individual Income Tax Return
Label Forthe Jan.l-Oec.31 1999 orothertax nnI
Your first name M.I. Last name
MYONG H SOL
If a joint return, spouse's first name M.l. Last name
KUM S SOL
Home address (number and street). If you have a P. 0, box, see page 18,
3819 CHIPPENHAM RD
City, town or post office
MECHANICSBURG
Presidential Do you want $3 \0 go 10 this fund?
Election tam It a nt retum does s want $310 10 this fund?
Single
X Married filing joint return (even if only one had income)
MarIIed ftIIng saparate Mum. Enter spouse's SSN _ and IYIt name here,
Head of household (with qualifying person). (See page 18.) lithe qualifyin9 person is a child but not your
dependen~ enter this child's name here. SSN:
5 DQualifying widow(erl with dependent child (year spouse died 19 I, (See page 18,)
6aWYourself. If your parent (or someone else) can claim you as a dependent No, of boxes checked
on his or her tax return, do not check box 6a. on 6a and 6b 2-
No. of your Children
on 6c who:
Usa the
IRS label.
Other.
-.
p/elIse
print or
typo.
Filing
Status
Check only
one box.
-~
~
1999
IRSU
notWriteOfSla mUll's.
endin
9 No. 1545.0074
Your SSN
203.56-4654
Spouse's SSN
229-29-6811
IMPORTANTI
Suffix
Surf IX
Apt no,
Slate
PA
You must enter
your SSN(s) above,
ZIP code
17055.21 g9
X No
X No
Note. ....,8$~ will not change
ur lax or refund.
First name:
Last name:
Exemptions
If more than six
depelldellla,
see page 19,
Income
A_ Copye
d.'JOUC'FonMW-2
and W-2G here.
AJeo dach Fonn(a)
11>>9-Rittax
W1ISwiChhelcl.
lfyoudidnotgeta
W.2, see page 20.
Encfose. but dO
not_....,
pa,ment. Also,
-...
1040-V.
Adjusted
Gross
Income
bWSpouse
c
Dependents: 3) Dependent's 4} Check if qual.
2) Dependent's relationship ~GMdfot
1\ FIra\ name Last name soelaI securitv number lo'iOU chikl tu credit
MIN WOO SOL 203-70-8261 Son X
MINGEI SOL 203-70-8203 Son X
...... ~ . .
IIU
lUJ
'__you 2
" lfld not IMt With you due
lIOd~OfseparatlOr\
OepeI.dents on
6c not entered
above
Add numbers
entered on
d Total number of exemptions claimed . . . . . ' . . , . ' , lines above
7 Wages, salaries, tips, etc. Attach Form(s) W-2 . . , . , 7
8a Taxable interest Attach Schedule B if required . . ' . 8a
b Tax_empt interesl DO NOT include on line 8a . . . . . . .. 8b 0 ,;~'
9 Ordinary dividends. Attach Schedule B if required , , . . " . . , 9
10 Taxable refunds, credits, or offsets of slate and local income taxes (see page 21) 10
11 Alimony received . . . . . . . . . . . . . . ' . ., .." 11
12 Business income or (loss). Attach Schedule C or C-EZ ' . . , , . ' , , , " 12
13 Capital gain or (lOss). Altach Soh, D if required. If ~ot required, check here 0 13
14 other gains or (losses). Attach Form 4797 . , , . , ' . . . , . . . ' . .' 14
15a Total IRA distributions . . . . , , . .~ 01 b Taxable amount . 15b
16a Total pensions and annuities . . . . . ~ 0 b Taxable amount . . . 16b
17 Rental real estate, royalties, partnerships, S corporations, trusts. etc. Attach Schedule E 17
18 Farm income or {loss). Attach Schedule F . , . . . . . . , . ' ' . . . , " 18
19 Unemployment compensation . . . . . . . . . .. . . ' .',.. 19
20a Social security benefits . . . . .. . ~I 01 b Taxable amount . . . 20b
21 other income. Ust type and amount (see page 24) .................____....__
$
22 . Add the-amountS in "the far ri. tit coiumri 'for .Iiries.j throi; h 21.' This" is. our" tOt81 'income-..
23
24
25
26
27
28
29
30
31a
23 IRA deduction (see page 26). . . . , . . . . . , . . . . ,
24 Student loan Interest deduction (see page 26) . . . . . . . . . .
25 Medical savings account deduction. Attach Form 8853 . . . . ' .
26 Movin9 expenses. Attach Form 3903 . . . , . . . . . . . . ,
Xl One-half of se"-employment tax. Attach Schedule SE . . . ' . .
28 Self-employed health insurance deduction (see page 28) . . . , .
29 Keogh and self-employed SEP and SIMPLE plans . . . ' , . ' ,
30 Penalty on early withdrawal of savings . ..,.,
31a Alimony paid b Recipient's SSN
32 Add lines 23 through 31a . . . . . .
33 Subtract line 32 from line 22. This Is our ad'usted ross income . .
For Disclosure, Privacy /la, Bnd Paperwork Reduction Aot Notice, see page 54:
32
33
(>ITA)
o
o
ill
o
o
o
o
54 684
o
o
o
o
o
o
o
o
o
54 684
EXHIBIT
6
4,706
49 978
Form 1040 (1999)
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Fonn 1040 11999\ , , MYONG Hand KUM S SOL . 203-58-4654 Paae 2
34 Amount from line 33 (adjUstej Qrjs incomeb' ' , , . , . ' [jB;in~. 34 49.978
Tax and 35aD You were 65 or older, Blind; Spouse was 6S or older. ;t'1
Credits Add \he number of boxes cheeked above and enter the latal hete , 35aD ~'< '
,'c'
b 11'p.J are married filing separately and your apouse ~e_ deductions "
Slandard or 'p.J were a dua_ allen, see page 30 and check here ' 35bD
Deduction 36 Enter your ~emized deductions from Schedule A. line 28, OR standard deductian ,
lorMasl shown on \he left. But see paga 30 to find your standard deduction W you ,
People checked any box online 35a ar 35b ar W someone can claim you aa a dependent , 36 18,070
37 Subtract line 36 from line 34 37 31,908
Single: 38 II line 34 Is $94.975 ar less. multiply $2,750 by the tclal number 01 exemptians claimed
$4,300 on line Sd. II line 34 is aver $94.975, see the ~heet on page 31 lar the amount ta enter . 38 11.000
Head 01 39 TSlOlble income. SUbtract line 38 from line 37. II line 38 is mare than line 37, enter.(). , , , , 39 20,908
household: 40 Tax (see page 31). Cheek II any tax is from a DFonn(a)8814 b DFonn4972 40 3,139
$6.350 41 Credft lor child and dependent care expenses. Attach Fonn 2441 . . 41 0
Married filing 42 Credft for the elderly or the disabled. Attach Schedule R 42 0
jointIyar 43 Child tax credit (see page 33) 43 1000'
Qualifying 44 Education credits. Attach Form 8863 44 0
widow(er): 45 Adoption credft, Attach Form 8839 45 0
$7,200 46 Foreign tax credit. Attach Form 1116 if required . ' , , . 46 0
Married filing 47 Other. Check if from OForm 3800 DForm 8396 1'1.",
separately: DForm 8801 D Form (specify) 47 0
$3.600 48 Add lines 41 through 47. These are your total credits 48 1000
49 Subtract line 48 from line 40. If line 48 is more than line 40 enter -0- 49 2139
50 Self-employment tax. Attach Schedule SE 50 7,727
Other 51 Memative minimum tax. Attach Form 6251 51 0
Taxes 52 ScciaI sewTlty and ~,~ on,J1p,~~ not,reparted to employer, Allach Form 4137 52 0
53 Tax on IRAs. other retirement planl\.i.ar\d ~~. Attach Form 5329 W required , , , , , 53 0
54 Advance eamed income credft''jlaynll!ilts from Form(s) W-2 ' , 54 0
55 Household employment taxes. Attach Schedule H 55 0
56 Add lines 49 throunh 55. This is your total tax , 56 9866
57 Federal income tax withheld from Forms W-2 and 1099 ,157 I 0
, Payments 58 1999 estimated tax payments and amount applied from 199B return 'I 0: ,.'
59a Earned income credit. Attach Sch. EIC if you have a qUalifyinr
child, b Nontaxable earned income: amount I 0
and type 59a 0
.___w_________________._._._..._.__.____..___
60 Additional child tax credit, Attach Form 8812 80 0
61 Amount paid with request for extension to file (see page 48) 61 0
62 Excess social security and RRTA tax withhelj (Sj page 48) . 62 0
63 Other payments. o Form 2439 Form 4136 63 of'-
64 Add lines 57 58 59a and 60 thro- ~h 63. These are """r total . , 64 0
Refund 65 II line 64 Is more than Ilne58. subtract line 58 from nne 64. This Is \he amount you OVERPAID. . , , 65 0
Have it directly 86a Amount of line 65 you want REFUNDED TO YOU ' . ' , 66a 0
~I'" b Routing number I I c Type: DChecking
P8ve 48 IInd fin in d Account number I I o Savings
fJ6b _. end86d.. 67 Amount of line 65 ~u wan! APPLIED TO YOUR 2000 ESTIMATED TAX , . . i 671
Amount 68 If line 58 Is more than line 64. aubtract fme 64 from line 58. This Is the AMOUNT YOU OWE,
You Owe Far details on hoW to pay. see page 49. . . . , . . . . : "69 i . 68 10278
69 Estimated tax nena!t,;. Also Include on line 68 . . 41 2 ". "
Paid
Preparer's
Use Only
Under penalties 01 perjury, I decl8re that I have examined this retum and accompanying SChedules and statements, and to the best of my knowIt<Ige al'ld belief,
they~ true, COftect, and. compteta. Oeclaratlon 01 ~ (otMt It\an ~yef) ill based 0l\.1I infonnation 01 whic/'l preparer has any kl'\QWIed~<
Your signature Dale Your occupation Daytime Phone Na,
SELF-EMPLOYED 717 233-0634
Spouse's occupation Harne Phone Na,
HfW
Dale Cheek If j'''xmioyed
5/1612000
EIN
Phone
ZIP code
Spouse's signature. lIa joint return. BOTH must sign.
Dale
Sign
Here
Keep . copy
"" r'""""'-
Prepal8l'S
signature
Flrm's name
(ar youra)
and address
m.
RONALD M LEIK CPA
1517 CEDAR CLIFF DR
CAMP HILL
'-..i
State PA
Prepare(a SSN or PTIN
186-26-9498
25-1619299
717 737-8909
17011-7705
Form \040 (\999)
Oepanmem of the Treasury
/trtIloUll Rellenue SeMc:e
Name(s) shown on Form 1040
MYONG Hand KUM S SOL
Medical Caution: 00 not include expenses reimbursed or paid by others.
and 1 Medical and dental expenses (see page A-1 ) ,
Dental 2 Enter amount from Form 1040, line 34 . 2
Expenses 3 Multiply line 2 above by 7.5% (.075)
4 Subtract line 3 from line 1, If line 3 is more than line 1
5 State and local income taxes , '
6 Real estate taxes (see page A-2). , , ,
7 Personal property taxes '
8 other taxes. ...._....._.._____... ._.. ~__......__.______
$ 0
9 Ad(lliiies'5-th;.o~-'hii"-'" "'- .-.-.---~... .~.--.: '-""""
10 Home mortgage interest and points reportecl to you on Form 1098
11 Home mortgage interest not reported to you on Form 1098, If
paid to the person from whom you bought the home, see page
A-3 and showlhal person's name. identifying no,. and address,
N8me..~R._..________.__.__R__________________________.____.___._
Addr...__..._._..______.__________...._._._._.____._.__._..________
TIN ._.___hn___n.__nn_____......_..... "__' .._. ... ..h.___. 11
12 Points not rep()rted to you on Form 1098. See page A-3
for special rules . ' . , , ,
13 Investment interest Attach Form 4952 if required, (See
page A-3.) . , , . , , . ' , ,
14 Add lines 10 throu h 13 , , , , ,
15 Gifts by cash or check. If you made any gift of $250 or
more,seepageA-4 . . . . . " .""
16 other than by cash or check. If any gift of $250 or more,
see page A-4. You MUST attach Form 8283 if over $500
17 Carryover from prior year . ,
18 Add lines 15lhrou h17 , . . . . , , ,
-
~~
SCHEDULE A
(Fonn 10401 .
Taxes You
Paid
(See
page A-2,)
Interest
You Paid
(See page A-3,)
Note.
Personal
interest is
not
deductible,
Gifts to
Charity
If you made a gift
and got a benef4 for
see A-4.
Casualty and
Theft Losses
Job Expenses
and Most
Other
Miscellaneous
Deductions
(See
page A-5 for
expenses to
deduct here.)
Other
Miscellaneous
Deductions
Total
Itemized
Deductions
.-."." ~ ~
<~-r~-~<~
Schedule '^ ., Itemized Deductions
OMS No 15045-0074.
1999
"ttactlmem $eQuetlce!>lo
Attach to Form 1040, See Instructions for Schedules A and B Form 1040 , 07
Your social security number
203-58-4654
12
4313
3,748
enter-O- 565
1871
2,702
571
5.144
11,951
13
11.951
410
19
20
o
._._._----------_._-.--_._-_._._-.-.......~-._.__.......-...
.._--.-------------_.-.-...-.._._._._..__.~.._..._...-...--Q
21 Tax preparation fees . . . . " ,....
22 other expenses. investment, safe depostt box, etc, List
type and amount .___ .__._...___ ..____ .__.~... ..._.n__. ._..
$
.--.---.-.-.-.-.-.------.-.-----.---------ji--...-.-------.0
23 -Add-,iiies-20-ihrough '22- -.- -: - -.- -: -~. - ,- - ~ - -'-' - - -- - -. - n - - - -'-
24 Enter amount from Form 1040, line 34 ' 24
25 Mu"iply line 24 above by 2% (.02) . . , , 25
26 Subtract line 25 from line 23. If line 25 is more than line 23 enter-o.
27 other - from list on page A-5. Ust type and amount
$
-....-.-.-.-------...-.-------."-.---.---.-...-.--...-----.....-$.--.-.....-.-0
26 Is F()rm 1040, line 34, over $126,600 (over $63,300 if married filing separately)?
WOO. Your deduction is not limited. Add the amounts in the far right column for
lines 4 through 27. Also. enter this amount on Form 1040, line 36.
DYES. Your deduction may be limited. See page A.f3 for the amount to enter,
o
o
For Paperwork Reduction Act Notice, see Form 1040 InsInlctions.
lHTl\)
Schedule A (fonn 1040) 1999
~
(Sole Proprietorship)
Partnerships, joint ventures, etc., must file Form 1065 or Form 1Q6S..8. Attactlmenl$eQuenceNc
Attach to Form 1040 01' Form 1041, See Instructions fOl' Schedule C lFonn 1040 ' 09
Social secutIly number (SSN)
203-58-4654
8 Entef code (rom pgs C-a &. 9
445100
Departmentofthe TlaSl,lry
tmernalR ' RlQ\
Name of proprietor
MYONG H SOL
A Principal business or profession, including product or service (see page C-1)
RETAIL GROCERY STORE
C Business name. If no separate business name, leave blank,
SOL'S MINI FOOD MARKET
E Business address (including suite or room no,) 53 N 17TH ST
City, town or post office, state, and ZIP code 'HARRiSBUR-G-----------------.--....PAuu.-.i7103..... ,'" '
F Accounting method: 0(1) Cash W(2) Accrual 0(3) Other (specify) ______.___..u......uu.....p,
G Did you "materially participate" in the operation of this business during 1999? If "No." see page G-2
for limn on losses. ' . ' , , , . , ' , , ' , ' , ,
H If you started or acquired this business during 1999. check here
Part I Income
.....""~.,~l,.,;_
-
"~
~ Co. F
.1
SCHEDULE C
(Fonn 1040)
Profit or Loss from Business
OMS No 1545-0074
1999
l
o Empk)yer 10 numbef (fIN). If an,!
OJ Yes
o
NOe
1 Gross receipts or sales, CAUTION: If this income was reported to you on Form W-2 and the
"Statutory employee" box on that form was checked, see page C-2 and check here D 1 337,401
2 Retums and allowances 2
3 Subtract line 2 from line 1 3 337,401
4 Cost of goods sold (from line 42 on page 2) 4 275,066
5 GROSS PROFIT, Subtract line 4 from line 3 5 62,335
6 Other income, inclUding Federal and state, gasoline or fuel tax credit or refund (see page C-3) CSt F sun) 6 20,459
7 GROSS INCOME. Add lines 5 and 6 7 82,794
32a IT] An investment IS at rrsk
32b 0 Some investment IS
nolal risk,
Schedule C (Form HMO) 1999
Part II Ex enses. Enter ex enses for business use of our home ONLY on line 30.
8 Advertising, , . 8 19 Pension and profit-sharing plans
9 Bad debts from sales or 20 Rent or lease (see page C-4):
services (see page G-3) 9 a Vehicles, machinery. and equipment
10 Car and truck expenses b Other business property
(see page C-3) . , . . , ' , , , 10 5869 21 Repairs and maintenance
11 Commissions and fees , , , . , , 11 5258 22 Supplies (not included in Part III)
12 Depletion , , . , . , , ' , , ,12 23 Taxes and licenses , . '
13 Depreciation and section 179 expense 24 Travel, meals. and entertainment:
deduction (not included in Part III) (see a Travel .
page C-3) , ' , , 13 2810 b Meals and
14 Employee benefit programs entertainment
(other than on line 19) , , 14 c Enter nondeductible amount
15 Insurance (other than health) "" 15 513 included on line 24b (see page C-5)
16 Interest: Nondeductible percentage: 50%
a Mortgage (paid to banks, etc,) . 16a d Subtract line 24c from line 24b
bOther , , , . , . , 16b 25 Utilities , ' , ' , . , '
17 Legal and professional 26 Wages (less employment credits)
services . , . , , . . , . ' . 17 1 025 27 Other expenses (from line 48 on
18 Office ex ense. , , . , , , , .. 18 a e 2 , ' ,
28 TOTAL EXPENSES before expenses for business use of home, Add lines 8 through 27 in columns
29 Tentative profit (loss). Subtract line 28 from line 7 , . , , ' , '
30 Expenses for business use of your home, Attach Form 8829 . . '
31 NET PROFIT or (LOSS). Subtract line 30 from line 29,
. If a profit, enter on Form 1040, line 12, and ALSO on Schedule SE, line 2 (statutory
employees, see page C-6). Estates and trusts, enter on Form 1041, line 3,
. If a loss, you MUST go on to line 32,
32 If you have a loss, check the box that describes your investment in this activity (see page C-6),
. If you checked 32a, enter the loss on Form 1040, line 12, and ALSO on Schedule SE,
line 2 (statutory employees, see page C-6), Estates and trusts, enter on Form 1041, line 3,
. If you checked 32b, you MUST attach Form 6198,
or Paperworl< Reduction Act Notice. see Form 1040 instructlons.
(HrA)
, 19
20a 60
, 20b
21 1.476
22 355
23 1,531
248 0
, 24b 0
,24c 0
24d 0
25 6,969
26
27 2,244
28 28,110
29 54,684
30 0
31 54,684
~~
~
~. "'"""'_N=-....~"'-~"""'"
JJ....
~ .!l-c
Sd1edIIIe C (F0l11l1040) 1999
Part III CestofOood$ Sold
33 Method(s) used to
value closing inventory: , We Cost Db Lowerolcostormal1<et Dc OIher(ellaehellpiana\ion)
34 Was there any change in determining quantities, costs, or valuations between opening and closing
inventory? If "Yes," attach explanation . . . , , . . . . . , . . , , , . , , . . . Dyes [TINo
MYONG H SOL
(see page C.7)
203-5~54
P8Qe 2
'.
35 Inventory at beginning of year. If different from last year's closing inventory, attach explanation 35 27.010
36 Purchases less cost of items withdrawn for personal use 36 275 .082
37 Cost of labor. Do not include any amounts paid to yourself 37
38 Materials and supplies 38
39 other costs . 39
40 Add lines 35 through 39 40 3.02. .092
41 Inventory at end of year 41 27 .026
42 COST OF GOODS SOlD. Subtract IineA1 from line 4.0. Enter the result here and on oaoe1 line 4 42 275..066
.
Part IV Infonnatlon oniYour VehIcle. Complete thiS part ONLY if you are claiming car or truck expenses '
on line 1.0 and are not required to ,file Form 4562 for this business. See the instructions for line 13 on page
C-4 to find out If rou must file.
43 When did you place YOl.!r vehicle in service for business purposes? (month, day, year)
44 Of the total number of miles you drove your vehicle during 1999, enter the number of miles you used your vehicle for:
a Business n.....................__ b Commuting ____.h..__.________... c other '..._ 00 OOh' _...........
45 Do you (or your spouse) have another vehicle available for personal use? , Dyes DNo
46 Was your vehicle available for USe during off-duty hours? . Dyes 0 No
47a Do you have evidence to support your deduction? . . . , Dyes ON.
blf"Yes;istheevidencewritten?............,......". ,DYesDNo
Part V Other Exnenses. Ust below business exnenses not included on lines 8.26 or line 3.0, ,
SECURITY ' 359
___________________~________.__________~_~_______~______________._______~w~.___~___~._a.a_._~...~.~a..._a.
TELEPHONE 1,317
_______________.______________________________________________~___________._.._..__.___.a_._______.~._.___
MISCELlANEOUS 568
_._____________________a_.._.__________.______________._._____.________._a_.___...._______.___.____.__._._
_.________.___________________.__._.________.______._______._____.____.._.__._____a_~.__._.___________..._
-------------------------------.------------.------.-------_._------_._-------_._----_..__.__._-_._-~...-.
-------------------------------------------------------------------------.----.--------------------------.
----...-.------------.---------.....-.-----..-------.---_.----_._-._---.------_._------_._--------_._.._~.
___..___.._____________.________~___.____________._.___________.__.____________.__..___.______.~_.__.__..a
46 TOTAL OTHER EXPENSES. Enter here and on oaoe 1 line 27 .146 2 244
Schedule C (Fonn 1040) 1999
--
.~ , . n ,
""""""---"~>
SCHEDULE SE
Self-Employment Tax
OMBNo_ ,
"
. . >
1999
(Fonn 1040)
.,.".............,....ury See lnsINclions for Schedule SE (Form 1040),
__ Allaoh to Form 1040.
Name 01 person with self-employment Income (as shown on Form HMO)
MYONG H SOL
Who Must File Schedule BE
You must file Schedule SE If:
. You had net earnings from self-employment from OTHER THAN church employee income (line 4 of Short Schedule SE or line 40 of
Long Sohedute SE) 01 $400 or mote, OR
. You had ohurc:l1 employee income of $108.28 or more. Inoome from services you performed as a minister or a member of a
religious order IS NOT _ employee income, See page SE-l.
Attachment Sequence No
17
SSN of person with self-employment income
203-58-4654
NOTE: Even If you had a loss or a small amount of/noome from self-employment. ft may be to your benefit
10 file Schedu18 SE and use eIther.~ method" In Part \I of Long SoheduIe SE, See page SE-3.
EXCEPTiON. If your only self-employment income was from eam/ngs as a minister, member of . religi""s order. or Christian Science
prac.titloller AND you filed Form 4361 and _IRS approwl not 10 be \axed on thoee eamlngs. 00 NOT file Schedule SE,
Instead, _ "Exempt-Form 4361" on Form 1040, line 50.
Section A - Short Schedule BE. CAUTION: Read instructions to see if you can use Short Sohedule SE.
1 Net farm profit or (loss) from Schedule F, line 36, and farm partnerships, Schedule K-1 (Form
1065), line 15a . . . . ' ' . . . , . . , . , ' . ' , . . , . . . ' . . 1
2 Net profit or (loss) from ScheduleC, line 31; Schedule C-EZ, line 3; Schedule K-1 (Form 1065), line
15a (other than farming); and Schedule K-1 (Form 1065-B). box 9. Ministers and members of religious
orders, see page SE-1 for amounts to report on this line, See page SE-2 for other income to report 2
o
54.684
3 Combinelifles 1 and 2 . . . . . . . . . . . . . . . , . . . , ' . . , , , ' . ,
4 NET EARNINGS FROM SELF-EMPLOYMENT. Multiply line 3 by 92.35% (.9235). If less than $400,
DO NOT file this schedule; you do not awe self-employment tax . , , ' . ' , , . , '
5 SELF-EMPLOYMENT TAX, If the amount on line 4 is:
. $72,600 or less, multiply line 4 by 15.3% (.153). Enter the result here and on Form 1040,
Iine50 . . . . . . .. . . . . , . . . . . . . . , , . . . ' , ' ,
. More than $72,600, multiply line 4. by 2.9% (.029). Then, add $9,002.40 to the resutt, Enter
the total here and on Form 1040, line 50.
3
54 684
4
50501
6 DEDUCTION FOR ONE-HAlF OF SELF-EMPLOYMENT TAX. Multiply line 5 by
50% .5. Enter the result here and on Form 1040 line 27', ' . . ' , , ,. 6
For Paperwork Reduction Act Notice, see Form 1040 1nstrucIlons. (>!TAl
3864
SoheduIe se (Form 1040) 1999
I
"-~~.~
--
~~..... .-.-
Fann 4562
.
I I , )
, .
Depreciation'a'nd Amortization
(Including Information on Listed Property)
Oepanment of the Trasury
Internal RtMf'lue Service See rate Instructions. Attach this form to ur return.
Name(s) shown on return Business or activity to which this form relates
MYONG H SOL RETI\IL GROCERY STORE
Part I Election To Expense Certain Tangible property (Section 179)
NOTE: If ou have an "listed ro e .. com lete Part V before ou com lete Part I.
1 Maximum dollar limitation. If an enterprise zone business, see page 2 of the instructions
2 Total cost of section 179 property placed in service, See page 2 of the instructions
3 Threshold cost otsection 179 property before reduction in limitation .
4 Reduction in limitation. Subtract line 3 from line 2. If zero or less, enter -O-
S Dollar limitation for tax year. Subtract line 4 from line 1, If zero or less, enter -0-, If married filing
se aratel see a e 2 of the instructions . ' . . , . . ,
a of
Identifying number
203-58-4654
5
e Elected cost
1419
o
1 Listed property. Enter amount from line 27 . . . . . . . . , . . , , , 7 0
8 Total elected cost of section 119 property, Add amounts in column (c), lines 6 and 7 8
9 Tentative deduction. Enter the smaller of line 5 or line 8. '.," 9
10 Carryover of disallowed deduction from 1998. See page 2 of the instructions ' , 10
11 Business income limitation. Enter the smaller of business income (not less than zero) or line 5 11
12 Section 179 expense deduction. Add lines 9 and 10, but do not enter more than line 11 12
13 Car over of disallowed deduction to 20. Add lines 9 and 10 less line 12 ' , , . 13 0
Note: Do not use Part II or Part 111 below for listed property (automobiles, certain other vehicles. cellular telephones. certain
computers, or property used for entertainment, recreation, or amusement). Instead, use Part V for listed property,
Part" MACRSOepreciation For Assets Placed in Service ONLY During Your 1999 Tax Year
(Do Not Include Listed Property.)
Section A.. General Asset Account Election
14 If you ara making the e1eetlon under section 168(1)(4) to group any assets placed in service during the tax year into one or more
general asset accounts. check this box. See page 3 of the instructions , , , , .. "",'
b Cost business use onl
8 EQUIPMENT
1419
Section B . General De reclation S stem GDS
(b) Month and (e) Basis for
(0) Classiftcatlon of property year placed dep<eclalion
in ulliiin InYeS e
See a e 3 of the instructions.
(d) Recovery (e) (f)
period Convention Method
1'&
25
27.5
27.5
39
SIL
MM S/L
MM S1L
MM SIL
MM SlL
m ADS See a e 5 of the instructions.
SIl
12 SlL
40 MM S/L
Part \II Other D~ reciation Do Not Inc,lude List~d Pro e See a e 5 of the instructions.
11 GDS and ADS deductions for assets placed in service in tax years beginning before 1999
18 Property subject to section 168(1)(1) election . , , ,
19 ACRS and other d reciation ' . . . . ' . . . . .
Part IV Summa See e 6 of the instructions.
20 Listed property. Enter amount from line 26 . , , . . . , , . ' . .
21 Total. Add deductions on line 12, lines 15 and 16 in column (g). and lines 17 through 20, Enter here
and on the appropriate lines of your return. Partnerships and S corporations - see instructions
22 For assets shown above and placed in service during the current year, enter the portion
of the basis attributable to section 263A costs , . . . ' , , ' '. ""
For Paperworl< Reduction Act Notice, see the separate instructions.
22
(HTA)
OMBNo 1545.'::":-2
1999
AttaChment SeQ to.c
67
1
2
3
4
19,000
o
200,000
o
19.000
1,419
1,419
o
19,000
1.419
D
(9)
DeprecIation
deduction
o
o
o
o
o
o
o
o
o
0
0
0
17 1,391
, 18
19 0
20 0
21
Form 4562 (\9991
~
I
""""'--,.---""'~- ~. ~
~"
~ '~
iItt~l""oi......i&~iIhlI~ ......_~I
. ,
Fcnn 4562 (l~l MYONG ~ SOL . ., . " 20~58-4,654
Part V LI,sted Property. Automobiles, Certain Other Vehicles, Ce,lIular Telepholile~,'C.rtain
Computers, and Property Used for Entertainment, Recreation, or Amus~mllnt
NOTE: For any vehicle for which you are using the standard mileage rate or deductin!! lease expense. complete
only 23a, 23b. columns (a) through (c) of Section A, all of Section e, and Section C if applicable,
Section A . De reclatlon and other Information CAUTION: See e 7 oflhe lnslructlons;forlimfts on atJIomobiles,
23a ........ ;nessIi_ntuse c!a; X Yes No 23b K"Yes.listheevidOnceWritten? X. ' Yes
(a) (b) Dale (e) IiuslneSsi (eI) (e) Basis for (I) <Ill (h) (i) Elected
Type of property placed Inveslment use Cost or depreciation Recovery Met\IDdI Depreciallon section 179
, vehicles lInlt In seNIce ' other basis '............. Convention deduction cost
24 Pro e used more than 50% in a uslilied ,business use See a e 6 of the instructions, ; ,
93 TOYOTA 41211993 78.00%
,
.
PllQe2
.
No
o
26 Add amounts in column (h). Enter the total, here and on line 20. page 1 , . , , .
27 Add amounts in column I. Enter the total here and on line 7 e 1 . . . . . . . .
Section B - Information on Use of Vehicles
COmplelethls section for vehicles used by a sole proprietor, partner, or other 'more than 5% owner,' or related person. If you prilllided vehicles
26
0'
o
o
25 Pro e
used 50% or less in a ualified business use See
a e 6 oflhe instructions. ;
SIL-
SlL-
SIL-
to ~ 'r em- first answer the nuestions In Sec:tlon C to see n~' meet an exceDlIon to comoletina this section! for those vehicles, ,
(al (b) (e) (dl (el (I)
28 Total businessllnvestment miles driven V_I Vehicle 2 Vehiele 3 Vehicle 4 Vehicle 5 Vehicle 6
dUring the year (00 NOT Include commu1Ing
miles see page 1 of the Instruc.) 18705
29 ToIal commuting miles driven during the veer 5230
30 Total other personal (noncommUllng)
miles driven
31 Total miles driven during the year.
Add lines 28 through 30 23 935 0 0 0 0 0
Ves No Yes No Ves No Ves No Yes No Yes No
32 Was the vehicle available for perSonal
use during off-duty hours? . . . . . X
33 Was the vehicle used primarily by a more than
5% """'" or reIaIed penon? . X
34 Is another vehicle available for
nersonal use? X
SectIon C - Questions for Employers Who Provide Vehicles for Use by Their Employees
Answer these questions to determine if you meet an exception to completing Section B for vehicles used by employee'l
Who ARE NOT more than 5% owners or related ersons.
Yes No
35 00 you maintain a written policy statement that prohibits all personal use of vehicles, including commuting.
by your employees? . ' , . . . ' . . . . . . . . . . . . . ' , . . . ' . . . ' , ,
36 Do you maintain a written policy statementlhat prohibits p8ISOll8I use of vehicles. except commuting, by your employees?
See page 8 of the inslNclions for vehides used by COlJlOI8le ofIicels, di~, or 1 % or l110lll ownet$ . . . , ,
37 00 you treat all use ofvehicles by employees as personal use? . . . . , . , , . , , : ' . ,
38 Do you provide more than live vehicles to your employees, obtain information from your employees about
the use of the vehicles, and retain the information received? . . . . . . . . . , '
39 00 you meet \he requIrernen1s COo -..Ing quaIIIIecl auIomobIIe demo,"",.roun use? See p. 8 of the lnsIruclions '
Note: If enswerto,35 36 'Sf 36 or 39 Is "Yes " uneednolcom Section B forlhe covered vehicles,
Part VI Amortization
(a)
DescrlplIon of costs
40 Amortization of costs that be Ins durin
(b) Dale
BnlVlltulUvr.
Ins
our 1999 tax ear:
(c)
AmortiZable
amount
41 Amortization of costs that began before 1999 . . . .
42 Total. Enler here and on "other Deductions" or "other
enses" line of our return. . . ','
41 0
42 0
Fcnn 4562 (1999)
--
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.
, ,
MYONG H
FORM 1040
, ,
& KUM S SOL
203-58-4654
1999
. I , .
SCHEDULE C, LINE 6--0THER INCOME
Pa. Lottery Commission (Form 1099)
National Bank Equipment (Form 1099)
Lorillard Tobacco Co. (Form 1099)
Telephone Commissions
$14,540
4,467
1,050
402
$20,459
-""~"
-.'
._~ ~~" '~_~I
"'J l'
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.::,",.i.,.._"",-"..J_"..w;l1loEiIlmI;I:I-'_
, f I J
I . , 1
July 23, 2001
Frank Fedennan, Esquire
Federman and Phelan, LLB
One Penn Center at Suburban Station
1617 John F. Kennedy Boulevard
Suite 1400
Philadelphia, PA 19103-1814
Re: Bank One et al v. Myonl! H. Sol andKum S. Sol., No. 01-3241
Dear Mr. Fedennan:
Enclosed is a certified check on behalf of the debtor in this matter satisfYing the
total amount owed including costs and fees. Please have this action withdrawn and send
me a copy of the Praecipe requesting the same.
Sincerely yours,
ROBINSON & GERALDO
Enclosure
Cc: Kum S. Sol
GSR: vir
EXHIBIT
i
S>
11 7
p. 0, Box 5320
Harrisburg, ?A 17110-5320
Harrisburg
4407 North Front Street
Harrisburg, ?A 17110
(717) 232-8525
(BOO) 571-2727
Fax (717) 232.5098
Washington, D.C.
1316 Pennsylvania Ave., S.E.
Washington, D.C. 20003
(202) 544-2889
Fax (202) 547.8342
Cumberland County
61 W. Louther Street
Carlisle, PA 17013
(717) 249-1177
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\; 07/17/01 WE J '; 52 FAX 2155680719
REINSTATE DEPT
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Federman and. Phelan, LLP
One Penn Center at Suburban Station
1617 John F. Kennedy Boulevard
Suite 1400
Philadelphia, PA 19103
215-563-7000
Fax 215-568-0719
Email: kamiel.houston@fedphe-pa.com
Karniel A. Houston
Legal Assistant Ext. 1262
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Representing Lenders in
Pennsylvania & New Jersey
REINSTATEMENT FIGURE
NAME: Sol, Myong & Kum ACCT. 7856842
DATE; 7/17(01 Good Through 07/30/01
Payments Due (6)
Late Charges
Property Inspection
Attorney Costs
Attorney Fees
$9,410.76
$470.52
$40.00
$838.50
$650.00
TOTAL
$11,409.781
ALL FONDS MOST BE IN FULL IN CERTIFIllD FORM AND FORWARDED TO OUR FIRM
REINSTATEMENT FIGURES MUST BE VERIFIED PRIOR TO SUBMITTAL!
~.Pl~~~c be Adv~ee4 hhat ~his fir.m is a debt col19~tor ~ttempting to do11e~~ A debt. Any
info:cmat;ion received ril:L be \teed. for ~t purpose. rf you ha.ve receiv6d Q di.5cha~ in
b8J:1krupt.cy. and this debt was not reaf:fiJ:mSd, tbi.::: cotte;::poft4ehee is not and should not he
con.~I:~ tQ :be an at.tempt. to co11ect a debt. b\1.t only (:rd:!o~(!ctQent of a lien against property.**
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. . , , ., ) 1- . . . .
KUM SOON SOL, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. DOMESTIC RELATIONS SECTION
CIVIL ACTION - SUPPORT
BRYAN H. SOL, NO. 812 SUPPORT 2000
Defendant DR 30,049
BRYAN H. SOL, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. DOMESTIC RELATIONS SECTION
CIVIL ACTION - SUPPORT
KUM SOON SOL, NO. 150 SUPPORT 2001
Defendant DR 30,452
IN RE; AGREEMENT
ORDER OF COURT
AND NOW, this 5th day of April, 2001, the above
support proceedings are dismissed and arrearages remitted,
without prejudice to the parties to raise any and all economic
issues in the context of equitable distribution. Further, it is
noted that these actions are dismissed in accordance with the
agreement of the parties, as announced in open court and in
their presence this date, which agreement is herewith made an
order of court.
By the Court,
Gerald S. Robinson, Esquire
For Kum Soon Sol
. /-I. It
Hess, J.
Dann Johns, Esquire
For Bryan H. Sol
DRO
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EXHIBIT
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KUM SOON SOL,
Plaintiff,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 00-6541
BRYAN HWAN SOL,
Defendant.
: CIVIL ACTION--CUSTODY
ORDER OF COURT
AND NOW.. this ~ day of _~, 2001, upon stipulation of the Parties, it is
HEREBY ORDERED AND DECREED :ha~he terms, conditions and provisions ofthe attached
stipulation are adopted as an order of court as if the same were set forth herein at length,
BY THE COURT:
EXHIBIT
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KUM SOON SOL,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 00-6541
BR Y AN HW AN SOL,
Defendant.
: CIVIL ACTION--CUSTODY
CUSTODY STIPULATION AGREEMENT
THIS AGREEMENT, made this tl!ft~ay Of~, 2001, by and between
KUM SOON SOL, of Harrisburg, Pennsylvania, hereinafter referred to as "Plaintiff," and
BRYAN HW AN SOL of Harrisburg, Dauphin County, Pennsylvania, hereinafter referred to as
"Defendant."
WITNESSETH
WHEREAS, the parties have reached an agreement concerning the issue of custody and
desire that this Stipulation be entered as an Order by the Court of Common Pleas of Cumberland
County, Pennsylvania;
WHEREAS, Plaintiff and Defendant are the natural parents ofMin Woo Sol, a minor,
born AprilS, 1985; and Min Gei Sol, a minor, born November 28, 1986.
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NOW, THEREFORE, intending to be legally bound, the parties hereby agree as
follows:
I. The parties shall have shared legal custody of the subject minor children. They
shall consult with each other relative to all important decisions concerning the minor children,
including such matters as health, education, and religion.
2. Plaintiff shall have primary physical custody of the minor children.
3. Defendant shall have partial physical custody of the minor children at times
mutually agreed upon by the parties.
4. All parties shall refrain from making derogatory comments about the other party
in the presence of the children and to the extent possible shall prevent third parties from making
such comments in the presence of the children whether "sleeping" or awake.
5. During any period of custody or visitation, the parties to this Stipulation shall not
possess or use any controlled substance, neither shall they consume alcoholic beverages to the
point of intoxication. . The parties shall likewise assure, to the extent possible, that other
household members and guests comply with this prohibition.
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IN WITNESS WHEREOF, the Parties hereto have voluntarily executed this Agreement
Witness
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KUM SOON SOL,
Plaintiff,
IN THE COURT OF COMMON PLEAS
: DAUPHIN COUNTY, PENNSYLVANIA
: NO. 2000-6541
BRYAN HWAN SOL,
Defendant.
: CIVIL LAW"LAW IN DIVORCE
INVENTORY AND APPRAISEMENT
AND INCOME AND EXPENSE STATEMENT
Plaintiff files the following Inventory and Appraisement of all property owned or
possessed by either party at the time this action was commenced and all property transferred
within the preceding three was commenced and all property transferred within the preceding
three years.
Plaintiff verifies that the statements made in this Invenlory and Appraisement are true
and correct. Defendant understands that false statements herein are made subject to the penalties
of 18 Pa. C.S. Seclion 4904, relating to unsworn falsification to authorities.
~~.1
KUM SOON SOL, Petitioner!Plaintiff
I
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ASSETS OF PARTIES
Plaintiff marks on the list below those items applicable to the case at bar and itemizes the
assets on the following pages. If an item has been appraised, a copy of the appraisal report is
attached.
X 1. Real Property
X 2. Motor Vehicles
3. Stocks, bonds, securities and options
4. Certificates of deposit
X 5. Checking accounts, cash
6. Savings accounts, money market and savings certificates
7. Contents of Safe Deposit Boxes
8. Trusts
X 9. Life Insurance policies (indicate face value, cash value and current beneficiaries)
2
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10. Annuities
11. Gifts
12. Inheritances
13. Patents, copyrights, inventions and royalties
14. Personal property oulside the home
X 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 plan
18. Pension plans (indicate employee contribution and date plan vests)
19. Retirement plans, Individual Retirement Accounts
20. Disability payments
3
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21. Litigation claims (matured and unmatured)
22. MilitaryN.A. benefits
23. Education benefits
X 24. Debts due, including loans, mortgages held
. X 25. Household furnishings and personalty (include a total category and attach itemized
list if distribution of such assets is in dispute)
26. Other
4
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MARITAL PROPERTY
Plaintiff lists all marital property in which either or both spouses have a legal or equitable
interest individually or with any other person as of the date this action was commenced:
Item Description Names of Date of
Nnmber of Propertv all Owners Acquisition
1 3819 Chippenharn Dr. Both 1996
Mechanicsburg, P A
2 1992 Mercedes 300 E Both 1992
2 Toyota Pick-up Both 1998
2 Toyota Dorsette Both 1985
5 PNC Bank Checking Account Kum September 2000
9 Met Life Insurance policy Kum 1997
$250,000 Term Life (Kum)
15 Sol's Mini Food Market Both 1988
24 See Liabilities
25 Household Furnishings Both Throughout
the marriage
I
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LIABILITIES OF PARTIES
Plaintiff marks on the list below those ilems applicable to the case at bar and itemizes the
liabilities on the following pages.
Secured
X 1. Mortgages
2. Judgments
3. Liens
4. Other secured liabilities
Unsecured
5. Credit card balances
6. Purchases
7. Loan payments
6
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8. Noles payable
9. Other unsecured liabilities
Contingent or Deferred
10. Contracts or Agreements
11. Promissory notes
12. Lawsuits
13. Options
14. Taxes
15. Other contingent or deferred liabilities
7
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LIABILITIES
.,.,-
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Plaintiff lists a111iabi1ities of either or both spouses, alone or with any person, as of the
date this action was commenced:
Number
of Liability Creditors
1 GMAC
Ii
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Descriution
Mortgage
8
Debtors
Amount
Both
$110,000
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FINANCIAL STATEMENT OF DEFENDANT
Monthlv Expenses
Shelter :
a. Mortgage or Rent --------------------- $1,700.00
b. Sewer/W ater ------------------------------ $70.00
c. E1ectric.------------m-------------------- $100.00
d. Heal/Oil/Gas ----------------------------- $100.00
The expenses listed above are paid by Bryan Sol.
Transportation:
a. Auto Loan payments ---------------------- $0.00
b. Auto Insurance ----------------------------- Unknown because it's paid by the Husband
c. Auto Expenses ---------------------------- $40.00
d. Travel Expenses ------------------------ $100.00
Medical Care/Insurances :
a. Life Insurance/Medica1 Insurance------ $40.00
9
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Clothing:
a. Self & Kids --------------------------------- $0.00
b. Gifts, etc------------------------------------- $0.00
c. Dry Cleaning ------------------------------- $0.00
Food:
a. Self and children ------------------------ $500.00
b. Household Supplies m__m____________ $100.00
Loans/Notes:
a. Home Equity-------------------------------- $0.00
b. Visa ----------------------------------------- $0.00
c. Personal Loan ----------------------------- $0.00
Miscellaneous:
a. Entertainment------------------------------ $30.00
b. Barber/Beautician------------------------ $60.00
c. Contributions ----------------------------- $50.00
d. Telephone bill----------------------------- $60.00
Child Care:
a. Court-Ordered Support-------------------- $0.00
b. Day Care ------------------------------------ $0.00
10
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Spousal Support:
a. Court-Ordered Support-------------------- $0.00
TOTAL MONTHLY EXPENSES-----------------$980.00
Monthlv Income
Employer Name: m__________________________________ Unemployed
Dated: /I - d. 'J - " 0
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June 4,2001
E. Robert Elicker, II
9 North Hanover Street
Carlisle, PA 17013
Re: Knm Soon Sol v. Bryan Kwan Sol, No. 00-6541
Our File No. 1708.001
Dear Mr. Elicker:
Enclosed please find the original and one copy of the Certification in the above
referenced matter. Kindly return the time/date slamped copy in the envelope provided.
Should you have any questions or concerns with regard to the above, please do
not hesitate to contact me.
Sincerely yours,
ROBINSON & DO
By:
Enclosures
VLR
P. Q. Box 5320
Harrisburg, PA 17110-5320
Harrisburg
4407 North Front Street
Harrisburg, PA 17110
(717) 232-8525
(800) 571-2727
Fax (717) 232-5098
Cumberland County
61 W. Louther Street
Carlisle, PA 17013
(717) 249-1177
Washington, D.C.
1316 Pennsylvania Ave., S.E.
Washington, D.C. 20003
(202) 544-2889
Fax (202) 547-8342
., "
KUM SOON SOL,
Plaintiff
VS.
BRYAN KWAN SOL,
Defendant
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00 - 6541 CIVIL
IN DIVORCE
CERTIFICA nON
I certify that discovery is complete as to the claims for which the master has been
appointed.
&/L(f()(
DATE
~~
. Gerald S. Robmson, Esqrnre
6ttorney LD. No. 27423
4407 North Front Street
P.O. Box 5320
Harrisburg, P A 17110
(717) 232-8525
Attorney for Plaintiff
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NOTE:
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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
DIRECTNE 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.
- "-'li&Ji(~"~ , ~.
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.
JAN - 9 20~
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNlY
,
PENNSYLVANIA
Kum Soon Sol
v.
2000-6541
Bryan Hwan Sol
DEFENDANT'S MEMORANDUM OFLAW
ON PETITION FOR EXCLUSIVE POSSESSION OF THE MARITAL
RESIDENCE
The Pennsylvania Divorce Code, Section 3502(c) gives the Court authority to award
exclusive possession of the marital residence to either of the parties during the pendency of
the divorce matter. 23 Pa.C.S. 3502(c); LacZkowski v. LacZkowski, 344 Pa. Super 154, 496
A.2d 56 (1985). But the exclusion of one spouse from a marital residence is a harsh remedy
that will not be awarded cavalierly. There must be clear and convincing evidence in order to
enter such an award. LacZkowski v. LacZkowski, supra. Courts are more likely to award
exclusive possession where a spouse has move out of the marital residence and established a
separate residence, and then only where the formerly absent parent's return to the residence
would cause unwarranted stress and disruption to minor children. Merola v. Merola, 19
D&C4th 538 (Luzeme County, 1993).
In the present case, husband has never moved out of the marital residence; llits not
established a sepllrllte residence. Therefore, purSUllnt to llPplicable case law he should not be
evicted from his own home.
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Fmther, it is important to consider the fact that husband works outside of the marital home
from early morning through early evening every day. This provides wife with a reasonable
and sufficient degree of isolation and peace, while also affording husband his traditional
home. And while there have been marital difficulties, arguments, and the garden variety
nonsense that sometimes accompanies a divorce, the teenage boys have not witnessed
anything more than occasional arguments. Husband and wife have their own rooms and
areas of the house.
No doubt that wife would prefer to have the house to herself 100% of the time. Still, the
totality of circumstances and the harshness of the remedy require that her requested relief be
refused.
Be it ever so humble, there is no place like home.
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Respectfully submitted,
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DannJohns, Esquire
52 South Duke Street
York, Pennsylvania 17401
741-4717 telephone
741-0368 fax
Johnsdann@aoLcom
ID 52681
Attorney for Bryan Hwan Sol
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K:(ti!t.i:iti. LL~~'
I certify that I shall serve a true and correct copy of the foregoing document this day in the
manner indicated below, which service satisfies the requirements of the Pennsylvania Rules
of Civil Procedure:
VIA FIRST CLASS U.S. MAIL
Gerald Robinson, Esquire
4407 North Front Street
P.O. Box 5320
Harrisburg PA 17110-5320
Dann Johns, Esquire
52 South Duke Street
York, Pennsylvania 17401
741-4717 telephone
741-0368 fax
J ohnsdann@aoLcom
ID 52681
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S 2ddl
(
Attorney for Bryan Hwan Sol
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.
JAN - 9 200t)
-)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
,
PENNSYL V ANlA
Kum Soon Sol
v.
2000-6541
Bryan Hwan Sol
DEFENDANT'S MEMORANDUM OF LAW
ON PETITION FOR EXCLUSIVE POSSESSION OF THE MARITAL
RESIDENCE
The Pennsylvania Divorce Code, Section 3502(c) gives the Court authority to award
exclusive possession of the marital residence to either of the parties during the pendency of
the divorce matter. 23 Pa.C.S. 3502(c); LacZkowski v. LaCZkowski, 344 Pa. Super 154,496
A.2d 56 (1985). But the exclusion of one spouse from a marital residence is a harsh remedy
that will not be awarded cavalierly. There must be clear and convincing evidence in order to
enter such an award. LacZkowski v. LacZkowski, supra. Courts are more likely to award
exclusive possession where a spouse has move out of the marital residence and established a
separate residence, and then only where the formerly absent parent's return to the residence
would cause unwarranted sttess and disruption to minor children. Merola v. Merola, 19
D&C4th 538 (Luzeme County, 1993).
In the present case, husband has never moved out of the marital residence; has not
established a separate residence. Therefore, pursuant to applicable case law he should not be
evicted from his own home.
-
~ .,
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;,,,/
Further, it is important to consider the fact that husband works outside of the marital home
from early morning through early evening every day. This provides wife with a reasonable
and sufficient degree of isolation and peace, while also affording husband his traditional
home. And while there have been marital difficulties, arguments, and the garden variety
nonsense that sometimes accompanies a divorce, the teenage boys have not witnessed
anything more than occasional arguments. Husband and wife have their own rooms and
areas of the house.
No doubt that wife would prefer to have the house to herself 100% of the time. Still, the
totality of circumstances and the harshness of the remedy require that her requested relief be
refused.
Be it ever so bumble, there is no place like home.
Respectfully submitted,
Dann Johns, Esquire
52 South Duke Street
York, Pennsylvania 17401
741-4717 telephone
741-0368 fax
J ohnsdann@aol.com
ID 52681
Attorney for Bryan Hwan Sol
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I certifY that I shall serve a true and correct copy of the foregoing document this day in the
manner indicated below, which service satisfies the requirements of the Pennsylvania Rules
of Civil Procedure:
VIA FIRST CLASS U.S. MAIL
Gerald Robinson, Esquire
4407 North Front Street
P.O. Box 5320
Harrisburg PA 17110-5320
DannJohns, Esquire
52 South Duke Street
York, Pennsylvania 17401
741-4717 telephone
741-0368 fax
J ohnsdann@aol.com
ill 52681
01
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I
Attorney for Bryan Hwan Sol
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l?JAN - 9 20~
LAw OFFICE OF DANN JOHNS
52 SOUTH DUKE STREET
YORK. PENNSYLVANIA 17401
January 5, 2001
Cumberland County Court House
High & Hanover Streets
Carlisle PA 17013
Attn: Prothonotary
Re: Sol vs. Sol 2000-6541
Dear Prothonotary:
Please file the attached Defendant's Memorandum of Law on
Petition for Exclusive Possession of the Marital Residence in
the above referenced matter.
Respectfully,
-r~lkUw~
Patricia McElwain
Certified Paralegal
Encl: Defendant's Memorandum of Law on Petition for Exclusive
Possession of the Marital Residence
Copy: Bryan Sol wlo encl.
file
TELEPHONE717741-4717
JOHNSDANN@AOL.COM
FAX717 741-0368
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
,
PENNSYLVANIA
Kum Soon Sol
v.
2000-6541
Bryan Hwan Sol
DEFENDANT'S MEMORANDUM OF LAW
ON PETITION FOR EXCLUSIVE POSSESSION OF THE MARITAL
RESIDENCE
The Pennsylvarllii Divorce Code, Section 3502(c) gives the Court authority to award
exclusive possession of the marital residence to either of the parties during the pendency of
the divorce matter. 23 Pa.e.S. 3502(c); UicZkowski v. UiCZkowski, 344 Pa. Super 154, 496
A.2d 56 (1985). But the exclusion of one spouse from a marital residence is a harsh remedy
that will not be awarded cavalierly. There must be clear and convincing evidence in order to
enter such an award. UicZkowski v. UicZkowski, supra. Courts are more likely to award
exclusive possession where a spouse has move out of the marital residence and established a
separate residence, and then only where the formerly absent parent's return to the residence
would cause unwarranted stress and disruption to minor children. Merola v. Merola, 19
D&C4th 538 (Luzeme County, 1993).
In the present case, husband has never moved out of the marital residence; has not
established a separate residence. Therefore, pmsuant to applicable case law he should not be
evicted from his own home.
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Further, it is important to consider the fact that husband works outside of the marital home
from early morning through early evening every day. This provides wife with a reasonable
and sufficient degree of isolation and peace, while also affording husband his traditional
home. And while there have been marital difficulties, arguments, and the garden variety
nonsense that sometimes accompanies a divorce, the teenage boys have not witnessed
anything more than occasional arguments. Husband and wife have their own rooms and
areas of the house.
No doubt that wife would prefer to have the house to herself 100% of the time. Still, the
totality of circumstances and the harshness of the remedy require that her requested relief be
refused.
Be it ever so humble, there is no place like home.
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Respectfully submitted,
Dann Johns, Esqui1:e
52 South Duke Street
York, Pennsylvania 17401
741-4717 telephone
741-0368 fax
J ohnsdann@ao1.com
ID 52681
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Attorney for Bryan Hwan Sol
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I certify that I shall serve a true and correct copy of the foregoing document this day in the
manner indicated below, which service satisfies the requirements of the Pennsylvania Rules
of Civil Procedure:
VIA FIRST CLASS U.S. MAIL
Gerald Robinson, Esquire
4407 North Front Street
P.O. Box 5320
Harrisburg PA 17110-5320
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Dalill Johns, Esquire
52 South Duke Street
York, Pennsylvania 17401
741-4717 telephone
741-0368 fax
J ohnsdann@ao1.com
ID 52681
Attorney for Bryan Hwan Sol
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LAw OFFICE OF DANN JOHNS
52 SOUTH DUKE STREET
YORK,PENNSYLVANIA 17401
January 5, 2001
Cumberland County Court House
High & Hanover Streets
Carlisle PA 17013
Attn: Honorable Judge Guido
Re: Kum Soon Sol vs. Bryan Hwan Sol 2000-6541
Dear Judge Guido:
Enclosed for your information please find Defendant's
Memorandum of Law on Petition for Exclusive Possession of the
Marital Residence.
There is a Special Relief Hearing scheduled before your honor
on Wednesday, January 10, 2001 at 3:30 p.m.
Thank you for your attention to this matter.
Respectfully,
"F / ~f.t.u:,~
Patricia McElwain
Certified Paralegal
Encl: Defendant's Memorandum of Law on Petition for Exclusive
Possession of the Marital Residence
Copy: Bryan Sol w/o encl.
file
TELEPHONE717741-4717
JOHNSDANN@AOL.COM
FAX717741-0368
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01/05/01 fRI 13:17 FAX 2406462
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KUM SOON SOL,
Plaintiff/Petitioner,
: IN TIlE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2000.6541
BRYANHWANSOL,
DefendantIRespondent.
CML LA W.LA WIN DNORCE
ORDER OF COURT
AND NOW, tlus :J...~ '"'" day of December, 2000, upon consideration of the attached
Petition, it is hereby Ordered and Decreed that a hearing on this Petition shall be scheduled for
the /tJ-th day of liii/l.l.uA/L,Y ,200Lat 3 :J() /. m.
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BY THE COURT:
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Kum Soon Sol
v.
2000-6541
Bryan Hwan Sol
ANSWER TO
PETITION FOR EXCLUSIVE POSSESSION OF THE MARITAL RESIDENCE
1. ADMITTED.
2. ADMITTED.
3. ADMITTED.
4. ADMITTED. Mill Woo Sol (DOB April 5, 1985) is 15 years old, and Mill Gei Sol (DOB
November 28,1986) is 14 years old.
5. DENIED IN PART. The grocery business was purchased, and is owned, by husband. It
is his exclusive source of income. ADMITTED that the grocery business was purchased
during the marriage.
6. DENIED. Husband's grocery business showed a net profit of $54,684 in 1999
(corresponding to $4,557 net income per month).
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7. DENIED. Wife worked in the store from approxitmtely 2:00 p.m. to 7:00 p.m. each
day. In September 2000, wife improperly took money from the business accounts and
stopped working in the store.
8. DENIED. Both husband and wife have limited English language skills. In fact, wife's
English language skills are better than husband's. Both were able to communicate with
customers and otherwise function in the community. Both are capable of running a small
business.
9. DENIED. Wife repeatedly has instigated arguments, and husband withd1:aws from those
arguments. Wife has been physically abusive to husband. But there has been no physical
fighting for over five years. On information and belief, the child1:en have not witnessed any
physical violence.
10. DENIED. Husband has not been spending any more time away from the marital
residence than usual. Husband works long hours in the gmcery business--especially since
wife no longer works there.
11. DENIED. Wife moved to the basement of the marital residence over the protest of
husband. She did this of her own free will. Her move was not requested or caused by
husband.
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12. DENIED. The implication that husband caused any physical or psychological abuse is
strongly denied. Wife filed a no-fault divorce.
13. DENIED. In September 2000 wife announced that the marriage was over. Husband
did not use any physical force or threats to exclude wife from the grocery business. In fact,
wife has come into the store since September. Husband has continued to manage his
grocery business as usual, except that wife no longer works there.
14. DENIED. Husband acted to prevent wife from improperly taking further money from
the business. Nevertheless, he has continued to pay all household bills, bring food home
from the grocery business, and take care of the financial needs of the children. Husband
has given wife money on several occasions since September.
15. DENIED. Husband works long hours at the grocery store, and takes occasional time to
visit with his family. But he continues to reside at the marital residence. He has not moved
from the marital residence at any time.
16. DENIED. Husband returns to the marital residence eat, sleep, and to do all of the
other things that a resident would do in his home. It is his home, and he does not have any
other residence.
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17. DENIED. To the contrary, wife has requested that husband leave. But husband
steadfasdy has refused. The Custody Conciliation Conference was continued because
husband and wife continued to reside in the same residence.
18. DENIED. Wife knew that collision insurance was dropped by the parties
approximately two years ago in order to save money. Husband did not cancel wife's
collision coverage without her knowledge. Wife has other means of transportation, namely a
Toyota Tercel. Husband questions how the allegations of this paragraph in wife's petition
are relevant to exclusive possession. Husband objects to relevance thereof.
19. DENIED. The children do not need to be shielded from an "emotionally charged
atmosphere" that does not exist in fact. Husband does not have--nor does he use--any
violent tendencies. On information and belief, wife has not sought appropriate employment.
20. DENIED. On information and belief, wife has cousins in New Jersey.
21. DENIED. Husband can not reside with his relatives, nor should he be required to leave
the marital residence merely because wife no longer wants him there. The circumstances do
not warrant exclusive possession by wife.
22. DENIED. Wife has not been confined to the marital residence. The parties equally
shared in the nurturing of the children. Indeed, while wife worked at the store from 2 p.m.
to 7 p.m. husband took care of the children.
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23. DENIED. Husband's presence in the home does not create a hostile or disruptive
atmosphere, nor does it adversely impact the children. Wife merely wants to oust husband
so that she can collect support.
24. DENIED. After reasonable investigation, husband is unable to confirm or refute the
allegation that wife's attorney fees are as stated. Strict proof thereof is demanded, if relevant.
Husband denies liability for wife's attorney fees.
WHEREFORE, Wife's Petition For Exclusive Possession should be dismissed, and her
requested relief must be refused.
Respectfully submitted,
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Dann Johns, Esquire 1/
52 South Duke Stteet i
York, Pennsylvania 17401
741-4717 telephone
741-0368 fax
J ohnsdann@aol.com
ID 52681
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Attorney for Bryan Hwan Sol
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I verify that the statements contained in the foregoing Answer To Petition For Exclusive
Possession Of The Marital Residence are true and correct based on my personal knowledge
or information and belief. I understand that false statements are subject to the penalties of
18 Pa.C.S. 4904 relating to unsworn falsification to authorities.
ate:
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Bry an Sol
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I certify that I shall serve a true and correct copy of the foregoing document this day in the
manner indicated below, which service satisfies the requirements of the Pennsylvania Rules
of Civil Procedure:
VIA FIRST CLASS U.S. MAIL
Gerald Robinson, Esquire
4407 North Front Street
P.O. Box 5320
Harrisburg PA 17110-5320
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Dann Johns, Esquire //
52 South Duke Street ;
York, Pennsylvania 17401
741-4717 telephone
741-0368 fax
J ohnsdann@aol.com
ID 52681
Attomey for Bryan Hwan Sol
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KUM SOON SOL,
Plainlifii'Petitioner,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2000-6541
BRYANHWANSOL,
DefendantJRespondent.
: CIVILLAW-LAWINDIVORCE
ORDER OF COURT
AND NOW, this ~t, t:/. day of December, 2000, upon consideration of the attached
Petition, it is hereby Ordered and Decreed that a hearing on this Pelition shall be scheduled for
the I(}~ day of VfI/~"""L,Y ,200Lat.3 :J() /. m.
CUI4/dI&:J()/}1 S- .
BY THE COURT:
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KUM SOON SOL,
Plaintiff/Petitioner,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2000-6541
BRYANHWAN SOL,
Defendant/Respondent.
: CIVIL LAW-LAW IN DIVORCE
PETITION FOR EXCLUSIVE POSSESSION OF THE MARITAL RESIDENCE
AND NOW, comes, Petilioner, Kum Soon Sol, by and through her attorney, Gerald S.
Robinson, Esquire and the law firm of Robinson & Gera1do, and respectfully states the
following:
1. Petitioner is KUM SOON SOL, an adult individual residing at 3819 Chipperham
Drive, Mechanicsburg, Cumberland County, Pennsylvania.
2. Respondent is BRYAN HWAN SOL, an adult individual residing at 3819
Chipperhmll Drive, Mechanicsburg, Cumberland County, Pennsylvania.
3. The parties are Korean immigrants and have been married for seventeen (17)
years.
4. There were two (2) children born of this marriage, both of which are minors.
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5. The parties purchased a convenience store approximately six (6) years ago, which
is their exclusive source of income.
6. The convenience store owned by the parties has a net income of approximately
$8,000.00 per month.
7. Historically, both of the parties worked in the store and until September 2000,
Petitioner handled the store's bookkeeping and financial affairs.
8. During the entire course of their marriage, Petitioner worked exclusively for the
various small businesses that the parties owned, and as a result, Petitioner speaks very little
English.
9. During the course of the marriage, the parties argued frequently and on many
occasions the arguments resulted in physical abuse. Many times the physical altercations were in
the presence of the minor children. Petitioner suffered many years of physical abuse.
10. Since December 1999, Respondent has been spending significant periods of time
away from the marital residence, coming home infrequently and sometimes in the early morning.
11. The parties ceased cohabiting in August 2000 when Petitioner began to reside in
the basement of the parties' residence and remain there whenever Respondent was present to
avoid any further confrontation.
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12. In September 2000, Petitioner, after suffering years of physical and psychological
abuse, filed for divorce.
13. In September 2000, Respondent, using physical force and threats, took over
financial control of the store and the parties' sole source of income.
14. In September 2000, Respondent closed all of the parties' joint bank accounts, not
giving any of the money to Petitioner to support her and the minor children.
15. Since September 2000, Respondent has been spending most of his time away
from the marital residence including 80-90 hours per week at the store and additional time that is
unaccounted for.
16. Respondent does not return to the marital residence to eat or sleep an average of
two to three (2-3) times per week.
17. The Custody Conciliation Conference held on November 29,2000 was continued
because the parties were contentious pending the parties negotiation of a property settlement
agreement, wherein Petitioner would receive the marital residence and Respondent would
receive the convenience store and pay child and spousal support to Petitioner.
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18. On or about December 14, 2000, Petitioner was involved in a car accident due to
the icy conditions. She then learned that she did not have any car insurance covering her vehicle.
Apparently, Respondent had cancelled Petitioner's collision coverage without her knowledge.
The car is inoperable and Petitioner has no means of transportation.
19. Petitioner does nol have the resources to relocate and shield the minor children
from the emotionally charged atmosphere to which the minor children are subjected because
Respondent, using his violent tendencies, has total control over the parties' financial resources.
20. Aside from her immediate family, Petitipner has no relatives in the United States.
21. Respondent's mother and siblings reside in Central Pennsylvania and Respondent
could reside with his relatives until he could make other living arrangements.
22. Petitioner has been confined to the marital residence providing the principal
nurturing of the parties' minor children.
23. Respondent's presence in the house creates a hostile and disruptive atmosphere
that adversely impacts the children, both of whom are in school.
24. Petitioner has incurred attorneys fees in the amount of $3,000.00 to date.
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WHEREFORE, Petitioner respectfully requests this Honorable Court to:
a. grant Petitioner exclusive possession of the marital residence;
b. order Respondent to pay Petilioner child support and spousal support;
c. order Respondent to pay the mortgage on the marital residence;
d. order Respondent to pay Petitioner's attorneys fees;
e. order Respondent to pay for the repairs need to get Petitioner's car operable; and
f. any other relief that this Honorable Court deems appropriate.
Respectfully submitted,
ROBINSON & GERALDO
By: $J~ ty.U.f~'l
Gerald S. Robinson, Esquire
Attorney J.D. No. 27423
4407 North Front Street
P.O. Box 5320
Harrisburg, PA 17110-5320
(717) 232-8525
Attorney for Petitioner
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VERIFICATION
I verifY that the stalements made in this Petition are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904,
relating to unsworn falsification to authorities.
~~
Kum S. Sol, Petitioner
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CERTIFICATE OF SERVICE
I, Gerald S. Robinson, Esquire, do hereby certify that on the 15th day of
December, 2000, I caused a true and correct copy of the Petition to be served upon the
following individual by first class mail by depositing same in the United States, postage
prepaid, in Harrisburg, Pennsylvania.
Dann Johns, Esquire
52 South Duke Street
York,PA 17401
Respectfully submitted,
ROBINSON & GERALDO
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Gerald S. Robinson, Esquire
Attorney J.D. No. 27423
4407 North Front Street
P.O. Box 5320
Harrisburg, P A 17110
(717) 232-8525
Attorney for Plaintiff
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KUM SOON SOL,
Plaintiff,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No. 00-654 I Civil Action - Law
BRYANHWANSOL,
Defendant.
In Custody
INTERIM ORDER OF COURT
AND NOW, this 9~
day of 117 A /I /' -f ' 2001, upon consideration of the
Custody Conciliation Summary Report it is hereby ORDERED AND DIRECTED AS
FOLLOWS:
1. A Hearing is scheduled in Court Room # '/ of the Cumberland
County Court House, on the f2J1/J day of ~/r.-1 t ,2001 at
9 : :$ 0 o'clock It. m. , at which f e testimony shall be taken.
For the pUrposes of the Hearing, the Mother, Kum soon Sol, shall be deemed to be
the moving party. and'shal:lproceed initially with testimony. Counsel for the
parties and or the parties pro se shall file with the Court and opposing
counsel/party a Memorandum setting forth each party's position on custody, a list
of witnesses who are expected to testify at the Hearing, and a summary ofthe
anticipated testimony of each witness. These Memoranda shall be filed at least 10
days prior to the Hearing date.
2. The parties shall submit themselves and their minor children to an Independent
Custody Evaluation by Pauline Wallin, Ph. D. The parties shall sign all necessary
releases and authorizations for the evaluator to obtain medical and psychological
information pertaining to the parties. Cost of this evaluation shall be initially be
borne by Mother who shall retain the right to petition for contribution from
Father. The parties shall extend their full cooperation to Dr. Wallin in scheduling
appointments and participating in the evaluation process.
3. Pending further Order of this Court, the following shall be in effect:
A. The parties, Kum Soon Sol and Brian Hwan Sol, shall have shared legal custody
ofMin Woo Sol born Apri15, 1985 and Min Gei Sol, born November 28, 1986.
Each parent shall have an equal right, to be exercised jointly with the other parent,
to make all major non-emergency decisions affecting the Children's general well-
being including, but not limited to, all decisions regarding his health, education
and religion. Pursuant to the terms ofPa. C. S. S 5309, each parent shall be
entitled to all records and information pertaining to the Children including, but not
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limited to, medical, dental, religious or school records, the residence address of
the Children and of the other parent. To the extent one parent has possession of
any such records or information, that parent shall be required to share the same, or
copies thereof, with the other parent within such reasonable time as to make the
records and information of reasonable use to the other parent.
B. The parties shall have shared physical custody on a week on, week off basis. The
change in custody shall occur after the children are out of school on Fridays.
Mother shall have the first week to commence March 9, 2001.
4. The parent who does not have custody shall be entitled to have reasonable
telephone contact with the Children.
5. Both parents shall establish a no-conflict zone for their children and refrain from
making derogatory comments about the other parent in Ihe presence of the
children and to the extent possible shall prevent third parties from making such
comments in the presence of the child.
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Gerald S. Robinson, Esquire 4407 North Front Street, Harrisburg, P A 1711 0
Dann Johns, Esquire 52 South Duke Street, York, PA 17401
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KUM SOON SOL,
Plaintiff,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No. 00-6541 Civil Action - Law
BRYANHWANSOL,
Defendant.
In Custody
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the subject of this
litigation is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Min Woo Sol
Min Gei Sol
April 5, 1985
November 28,1986
Father
Father
2. A Custody Conciliation Conference was held on February 27, 2001, with the
following individuals in attendance: the Mother, Kuru Soon Sol, and her counsel, Gerald S.
Robinson, Esquire; the Father, Bryan Hwan Sol, and his counsel, Dann Johns, Esquire.
3. The parties reached an agreement for an Interim Order as attached without prejudice
to either's right to pursue primary physical custody at time of hearing. The parties will participate
in an Independent Custody Evaluation and will require a hearing to be scheduled. Currently
pending are: a PFA hearing for March 2,2001 before Judge Hoffer No. 01-1026 and a Petition
for Exclusive Possession in the Divorce matter No. 00-6541, before Judge Hess on AprilS, 2001.
4. Mother's position on custody is as follows: Mother describes herself as the parent who
has been primarily responsible for the care and feeding ofthe children. She reports that Father
has not been as participatory due to long work hours. She also reports that Father has frequently
been absent from the home over night, thus leaving her with the responsibility for the children.
5. Father's position on custody is as follows: Father expressed concern that his children
would be confused by the Week on, week off schedule. He suggests that he have primary
physical custody with Mother having partial custody each weekend from Friday until Sunday at
8:00 p.m. and two dinners per week.
6. Both parents expressed a desire to consider what the children want for a custodial
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No. 00-6541
arrangement.
Date c!lf~ 7 /D /
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Melissa Peel Greevy, Esquire
Custody Conciliator
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KUM SOON SOL,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-6541
BRYAN HWAN SOL,
Defendant.
CIVIL ACTION- LAW IN DIVORCE
CERTIFICATE OF SERVICE
I, Virginia L. Rufo, Paralegal, do hereby certify that on the 17th day of April,
2001, I caused a true and correct copy of the Order to be served upon the following
individual by first class mail by depositing same in the United States, postage prepaid, in
Harrisburg, Pennsylvania.
Dann Johns
52 South Duke Street
York,PA17401
Respeclfully submitted,
By:
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KUM SOON SOL,
Plaintiff,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-6541
BRYAN HWAN SOL,
Defendant.
: CIVIL ACTION--CUSTODY
ORDER OF COURT
AND NOW, this ~ day of I'h ~
, 200 I, upon stipulation of the Parties, it is
HEREBY ORDERED AND DECREED that the terms, conditions and provisions of the attached
stipulation are adopted as an order of court as if the same were set forth herein at length.
BY THE COURT:
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Plaintiff,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-6541
BRYAN HWAN SOL,
Defendant.
: CIVIL ACTION--CUSTODY
CUSTODY STIPULATION AGREEMENT
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THIS AGREEMENT, made this Jk 'day of
2001, by and between
KUM SOON SOL, of Harrisburg, Pennsylvania, hereinafterreferred to as "Plaintiff," and
BRYAN HW AN SOL of Harrisburg, Dauphin County, Pennsylvania, hereinafter referred to as
"Defendant. "
WITNESSETH
WHEREAS, the parties have reached an agreement concerning the issue of custody and
desire that this Stipulation be entered as an Order by the Court of Common Pleas of Cumberland
County, Pennsylvania;
WHEREAS, Plaintiff and Defendant are the natural parenls of Min Woo Sol, a minor,
born AprilS, 1985; and Min Gei Sol, a minor, born November 28, 1986.
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NOW, THEREFORE, intending 10 be legally bound, the parties hereby agree as
follows:
1. The parties shall have shared legal custody of the subject minor children. They
shall consult with each other relative to all important decisions concerning the minor children,
including such matters as health, education, and religion.
2. Plaintiff shall have primary physical custody of the minor children.
3. Defendant shall have partial physical custody ofthe minor children at times
mutually agreed upon by the parties.
4. All parties shall refrain from making derogatory comments about the other party
in the presence of the children and to the extent possible shall prevent third parties from making
such comments in the presence of the children whether "sleeping" or awake.
5. During any period of custody or visitation, the parties 10 this Stipulalion shall nol
possess or use any controlled subslance, neither shall they consume alcoholic beverages to the
point of intoxication. The parties shall likewise assure, to the extent possible, that other
household members and guests comply with this prohibition.
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IN WITNESS WHEREOF, the Parties hereto have voluntarily executed this Agreement
the day and year firsl above written.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PEN]\SYL VANIA
Kum Soon So]
Civil Action - Divorce /k;(tJ -(pS-lf /
vs
Bryan Hwan Sol
CERTJ[FICATE OF SERVICE
I certify that: I served a true and correct copy of the Praecipe for the Entry of Appearance
this date by first: class U. S. Mail, addtessed as follows, which service satisfies the
requirements of the Pennsylvania Rules of Civil Procedure:
Gerald S. Robinson, Esquire
4407 North Front Street
P. O. Box 5320
Harrisburg, PA 17110
LAW OFFICE OF DANN JOHNS
Date:
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Dann S. Johns, ~uire
52 South Duke Street
York, Pennsylvania 17401
741-4717 telephone
741-0368 fax
Tohnsdann@aoLcom
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ID # 52681
Attorney for Bryan Hwan Sol
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KUM SOON SOL,
Plaintiff,
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. .,2 cx::o - ~~Y/
BRYAN HW AN SOL,
Defendant.
CIVIL ACTION-DIVORCE
ACCEPTANCE OF SERVICE
I, Bryan Hwan Sol, certify Ihat I accepted service of the Complaint in Divorce on or
about September 15, 2000.
Date 9'-11-00
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KUM SOON SOL,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
BRYANHWANSOL,
Defendant
00-6541 CIVIL
IN RE: PETITION FOR EXCLUSIVE POSSESSION
ORDER
AND NOW, this
I'" day of February, 2001, it appearing that the court is
unavailable on March 22,2001, hearing in the above captioned matter is continued to Thursday,
Apri15, 2001, at 9:00 a.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle,
PA.
BY THE COURT,
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Gerald S. Robinson, Esquire
For the Plaintiff
Dann S. Johns, Esquire
For the Defendant
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KUM SOON SOL,
Plaintiff,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-6541
BRYAN KWAN SOL,
Defendant.
: CIVIL ACTION-DIVORCE
ORDER APPOINTING MASTER
PI '
AND NOW, this 12:... day of ,,(J f:J AJ 2001,
s:: f-WE rAAi~ , Esquire, is appointed master with respects to the following
claims:
1. Distribution of Property,
2. Support, and
3. Cosls and Expenses.
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KUM SOON SOL,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-6541
BRYAN HWAN SOL,
Defendant.
CIVIL ACTION- LAW IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
Kum S. Sol, Plainliff, moves the court to appoint a master with respect to the
following claims:
( ) Divorce
( ) Annulment
( ) Alimony
( ) Alimony Pendente Lite
(X) Distribution of Property
(X) Support
( ) Counsel Fees
(X) Costs and Expenses
and in support of the Motion states:
1. Discovery is complete as to the claims for which the appointment of a
master is requesled.
2.
The Plaintiff is represented in this action by Gerald S. Robinson, Esquire.
3.
The Defendant is represenled in this action by Darrn Johns, Esquire.
4.
3301 (c).
The statutory ground for divorce is irretrievable differences under section
5.
The action is contested with respect to the following claims: property
distribution, support, and costs and expenses.
6.
The action does not involve complex issues oflaw or fact.
7.
The hearing is expected to take approximately a half-day.
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Respectfully submitted,
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G d S. Robinson, Esquire
Attorney J.D. No. 27423
4407 North Front Streel
P.O. Box 5320
Harrisburg, Pennsylvania 17110
(717) 232-8525
Attorney for Plaintiff
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COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF HEALTH
vrTAl RECORDS
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STATE FILE NUMBER
COUNlY
DIVORCE
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RECORD OF
OR
(CHECK ONE)
ANNULMENT
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STATE FILE DATE
HUSBAND
1. NAME
(First)
(Middle)
(Last)
2. DATE
OF
BIRTH
4. PLACE
OF
BIRTH
7. USUAL OCCUPATION
(Morrth) (Day)
2-10-54
(Year)
BRYAN HWAN SOL
3. RESIDENCE
Street or R.D.
City, Bora. orTwp.
County
Sta"
(State or Foreign Country)
1508 BEAVER DAM
5. NUMBER
OF THIS
MARRIAGE
2
COURT,
6. RACE
WHITE
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HANOVER MD
21076
KOREA
BLACK OTHER (Specify)
KX ASIA
WIFE
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,. MAIDEN NAME (Arst) (Middfe) (Last) 9. DATE (Month) (Day) (Year)
KUM SOON LEE OF 8-9-54
BIRTH
10. RESIDENCE StrestorR.D. City, Bom. or Twp. County Stat. 11. PLACE (State or Foreign Country)
3819 CHIPPENHAM OF KOREA
ROAD MECHANICSBURG PA 17055 BIRTH
12. NUMBER f3. RACE SlACK ~ ~ 4. USUAL OCCUPATION
OF THIS 1 WHITE OTHER (Specify)
MARRIAGE 0 0 lla ASI STORE flWNRR
15. PLACE OF (County) (State or Foreign Country) 16. DATE OF (Month) (Day) (Year)
nilS DAUPHIN nilS
MARRIAGE PENNSYLVANIA MARRIAGE 5-19-84
17A. NUMBER OF T.. NUMBER OF DEPENDENT 18. PlAINTIFF 9. DECREE GRANTED TO
CHILDREN 11-IIS CHILDREN UNDER 18. HUSBAND WIFE OTHER (Specify) HUSBAND WIJ:E OTHER (Specify)
MARRIAGE 2 2 0 KX 0 0 oa 0
20. NUMBER OF HUSBAND WIFE SPUT CUSTODY OTHER (Specify) 121 LEGAL GROUNDS FOR
CHILDREN TO I1IJ IZJ 0 0 DIVORCE OR ANNULMENT
CUSTODY OF IRRETRIEVABLE BREAKDOWN
22. DATE OF DECFtEE (Month) (Day) (Year) r3. DATE REPORT SENT (Month) (Day) (Year)
TO VITAL RECORDS
PENDING 11'-7-01
24. SIGNATURE 01=
TRANSCRIBIN<3 CLERK
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KUM SOON SOL,
Plaintiff,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-6541
BRYAN KW AN SOL,
Defendant.
: CIVIL ACTION-DIVORCE
ORDER APPOINTING MASTER
P\ .
AND NOW, this 1L day of lJ f) AJ 2001,
~ ~W/; rAAi~ , Esquire, is appointed master with respecls to the following
claims:
1. Distribution of Property,
2. Support, and
3. Cosls and Expenses.
Date:
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KUM S. SOL,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
Petitioner,
v.
: NO. 00-6541 CIVIL
BRYANH. SOL,
Respondent.
: IN DIVORCE
RULE TO SHOW CAUSE
AND NOW, THIS !f!:Ii day of~Jp/L/ , 2002, upon consideration of the
Plaintiffs Petilion for Civil Contempt, a Rule is hereby issued on the Defendanl, Bryan H. Sol to
show cause why Defendanl should not be held in contempt of Court.
RULE RETURNABLE day" f.5ffi tI,,, d"lc:: of st:Ivicc::. ~ "" b..-Al. ,.L-,
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KUM S. SOL,
:IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
Petilioner,
v.
:NO. 00-6541 CIVIL
BRYANH. SOL,
Respondent.
:IN DIVORCE
PETITION FOR CIVIL CONTEMPT
The Petition ofKum S. Sol, Plaintiff/Petitioner respectfully represents that:
I. An Order was entered by this Court daled October 26, 2001 directing Respondent to
transfer the titles of two vehicles to Petitioner prior to Petitioner's payment to Respondent of
$50,000.00 A copy of the said order is attached hereto as Petitioner's Exhibit No.1.
2. Pursuant to the Order, Petitioner made the $50,000.00 payment in January of2002 and
has been making the monthly $1,000.00 through September of this year.
3. Several dates were established wherein the parties were to meet at PennDOT to transfer
the titles but each date was cancelled at the request of Respondent.
4. By letter dated July 30,2002, a copy of which is attached herelo as Exhibit 2, Petitioner
advised Respondent that she would pay the remaining eight $1,000.00 installments in one full
payment as soon as the titles were transferred. A date for the transfer was scheduled but
Respondent failed to deliver Ihe titles.
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5. Attempts to reschedule the visit to PennDOT were made in August and September, but
Respondent failed to keep the appointments at PennDOT. The tides have not been transferred to
date despite Petitioner's compliance with her obligations under the Court Order.
6. As a result of Respondent's failure to comply, Petitioner has stopped making the monthly
payments.
7. Despite our requests Respondent has not scheduled any meetings at PennDOT to transfer
the tides and is in Contempt of Court.
8. Petitioner has incurred legal fees in the amount of $612.50 to date attempting to get tide
of the motor vehicles as provided in the Order.
WHEREFORE, for the forgoing reasons, Respondent should be held in cbnlempt of
Court, ordered to pay for all of Petitioner's expenses related to her attempts 10 get compliance
with the October 26, 2001 Court Order, and Respondent should be ordered 10 appear at
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PennDOT 011 a dale certain in possession of the titles and sign them over to Petitioner. In the
alternative an Order should be entered directing PennDOT to issue new title certificates to
Petitioner transferring litle to the vehicles in question to her.
Respectfully submitted,
ROBINSON & GERALDO
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By:
Gerald S. Robinson, Esquire
AttorneyLD. No. 27423
4407 North Front Street
P.O. Box 5320
Harrisburg, Pennsylvania 17110
(717) 232-8525
Attorney for Petitioner
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KUM SOON SOL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Vs.
NO. 00 - 6541 CIVIL
BRYAN HWAN SOL,
Defendant
IN DIVORCE
(WHEREUPON, THE FOLLOWING PROCEEDINGS WERE
INTERPRETED BY CHUN WATTS.)
THE MASTER: Today is Friday, October 26,
2001. This is the date set for a conference in the above
captioned divorce proceedings.
Present in the hearing room are the
Plaintiff, Kum Soon Sol, and her counsel Gerald S. Robinson,
and the Defendant, Byran Hwan Sol, and his counsel Dann S.
Johns.
This action was commenced by the filing of a
divorce complaint on September 26, 2000, raising grounds for
divorce of irretrievable breakdown of the marriage. The
parties are going to sign today affidavits of consent and
waivers of notice of intention to request entry of divorce
decree so that the divorce can be concluded under Section
3301(c) of the Domestic Relations Code.
The complaint also raised economic claims of
equitable distribution, alimony, alimony pendente lite, and
counsel fees and expenses.
The parties were married on May 19, 1983, and
-- arated in September 2000.
They are the natural parents of
EXHIBIT
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two minor children.
The Master has been advised that after
negotiations this morning, the parties have reached an
agreement with respect to the outstanding economic claims.
The agreement is going to be placed on the record in the
presence of the parties. The agreement as stated on the
record will be considered the substantive agreement of the
parties not subject to any changes or modifications except for
correction of typographical errors which may be made during
the transcription. The parties and counsel are going to
return later today to review the draft of the agreement for
typographical errors, make any corrections as necessary and
then affix their signatures to the agreement affirming the
terms of settlement as placed on the record.
It is specifically stated, however, that the
agreement will be binding on the parties irrespective of
whether or not they affirm the agreement by signing the
agreement.
Upon receipt by the Master of a completed
agreement, the Master will prepare an order vacating his
appointment and counsel can file a praecipe transmitting the
record to the Court for final decree in divorce.
For the record, it is specifically noted that
an interpreter is present on behalf of the Defendant and your
name is?
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MS. WATTS: Chun, C-h-u-n, Watts, W-a-t-t-s.
THE MASTER: Ms. Watts is going to assist in
any language difficulties which Mr. Sol may have in terms of
the understanding of what is going on here today with respect
to understanding the specific provisions of the agreement.
Mr. Johns is going to state the agreement on the record and
the interpreter will be assisting Mr. Sol in understanding the
provisions of the agreement. Mr. Johns.
MR. JOHNS: The parties intend the following
terms as the final resolution of their equitable distribution
claims:
1. within ten (10) days of today's date husband shall
execute and acknowledge good and sufficient deeds to 3819
Chippenham Drive, Mechanicsburg, Pennsylvania, and 53 North
17th Street, Harrisburg, Pennsylvania. These deeds shall be
held in escrow by attorney Dann Johns pending wife's
refinancing of the existing mortgage against 3819 Chippenham
Drive and the payment to husband through his counsel of the
sum of $50,000.00.
wife agrees to make an application with a bank or
mortgage lender within ten (10) days of today's agreement and
the parties anticipate that within six (6) weeks, but no
longer than ninety (90) days, wife will secure the loan to pay
off the existing mortgage on the Chippenham Drive property and
pay husband the $50,000.00 sum.
Pursuant to the payment to husband through his counsel
the sum of $50,000.00, attorney Dann Johns is authorized and
required to release to wife or her agent the deeds to the
Chippenham Drive and 17th Street properties so that they may
recorded as part of that transaction.
2. Wife shall pay husband an additional $15,000.00 as a
property settlement in 15 monthly installments of $1,000.00
per month beginning January 1, 2002, with each payment being
due on the first of each successive month. Payments shall be
made to pann Johns as attorney for Byran Sol at his office at
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52 South Duke Street, York, Pennsylvania 17401. Both the
$15,000.00 sum and the $50,000.00 sum that wife is paying
husband are intended as a property settlement and not alimony.
3. Husband forever releases and waives to wife all of his
right, title, interest, and claim to a business known as MMK
Mini Market, formerly Sol's Mini Food Market, including all
inventory, receivables and any other aspect of the business.
4. Husband shall retain all personal property in his
possession. wife forever waives all her right, title,
interest and claim to all personal property in husband's
possession.
Wife
possession.
and claim to
shall retain all personal property in her
Husband forever waives all right, title, interest
all personal property in wife's possession.
5. Upon receipt of the $50,000.00 payment described above,
husband's counsel shall immediately pay the IRS on behalf of
the parties the sum of $9,750.00 representing husband's entire
obligation on the 2000 tax liability for the business.
Husband's counsel shall provide proof of this payment to
wife's counsel and the balance of the $50,000.00 shall be
distributed directly to husband.
6. wife shall receive the Mercedes and Toyota Tercel.
Husband shall receive the Toyota pickup. All titles and
registrations for these vehicles as stated herein shall be
transferred prior to wife's payment to husband of the
$50,000.00. Husband shall be responsible for timely payment
and he shall hold wife harmless from the loan on his Toyota
truck.
7. The parties hereby waive all claims for alimony,
alimony pendente lite, counsel fees, costs and expenses as
well as any and all contractual and other claims that they may
have, one against the other.
MR. ROBINSON:
8. Any debts held individually by the respective parties
shall be paid by each party individually and they will each
indemnify and hold each other harmless as to those said debts.
MR. JOHNS:
9. Except as herein otherwise provided, each party may
dispose of his or her property in any way and each party
hereby waives and relinquishes any and all rights he or she
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may now have or hereafter acquire under the present or future
laws of any jurisdiction to share in the property or the
estate of the other as a result of the marital relationship
including without limitation, statutory allowance, widow's
allowance, right of intestacy, right to take against the will
of the other, and right to act as administrator or executor in
the other's estate. Each will at the request of the other
execute, acknowledge, and deliver any and all instruments
which may be necessary or advisable to carry into effect this
mutual waiver and relinquishment of all such interest, rights,
and claims.
MR. ROBINSON: Ms. Sol, appearing in the
office Robert Elicker, Divorce Master, on October 26, 2001,
and hearing the recitation of the agreement by the parties, do
you have any questions?
MS. SOL: No.
MR. ROBINSON: Do you understand everything
that was said?
MS. SOL: Yes.
MR. ROBINSON: Do you have any reservations
about moving forward with this?
MS. SOL: No,
MR. JOHNS: Mr. Sol, you were here today,
October 26, 2001, at the Divorce Master's office, did you hear
the agreement as I dictated it?
MR. SOL: Yes.
MR. JOHNS: Do you understand the terms of
that agreement?
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MR. SOL: Yes.
MR. JOHNS: And do you voluntarily agree to
accept that agreement as your own?
MR. SOL: Yes.
I acknowledge that I have read the above
stipulation and agreement, that I understand the terms of
settlement as set forth herein, and that by signing below I
ratify and affirm the agreement previously made and intend to
bind myself to the settlement as a contract obligating myself
to the terms of settlement and subjecting myself to the
methods and procedures of enforcement which may be imposed by
law and in particular Section 3105 of the Domestic Relations
Code.
WITNESS: DATE:
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Gerald. S. Robinson
Attorney for a tiff
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Kum Soon Sol
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Dann S. Johns
Attorney for Defendant
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July 30, 2002
VIA FACSIMILE
Dann Johns, Esquire
52 South Duke Street
York, PA 17401
Re: Kum S. Sol v Bryan H. Sol
Our File No.: 1708.001
Dear Mr. Johns:
Thank you for your response to my letter dated July 29, 2002. Ms. Sol is prepared to pay
the $8,000 at one time, but will not do so unlil the title the automobile is transferred. Please
contacl me, or Andrew Shaw, to coordinate a time that would be convenient for all parties
involved. Thank you.
Sincerely yours,
ROBINSON & GERALDO
"' /1
Gerald S. obmson, EsqUlre
cc: Kum S. Sol
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EXHIBIT
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CERTIFICATE OF SERVICE
I, Gerald S. Robinson, Esquire, do hereby certifY that on the~ay of October,
2002, I caused a true and correct copy of the Petition to be served upon the following
individual by first class mail by depositing same in the United States, postage prepaid, in
Harrisburg, Pennsylvania.
~
Dann Johns, Esquire
52 South Duke Street
York, PA 17401
Respectfully submitted,
ROBINSON & GERALDO
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Gerald S. Robinson, Esquire
Attorney I.D. No. 27423
4407 North Front Street
P.O. Box 5320
Harrisburg, PA 17110
(717) 232-8525
Attorney for Plaintiff
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KUM S. SOL,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
v.
NO. 00-6541 CIVIL
BRYAN H. SOL,
Defendant.
CIVIL ACTION - DIVORCE
PRAECIPE TO WITHDRAW PLAINTIFF'S
APPLICATION FOR RULE TO SHOW CAUSE
To the Prothonotary of said Court:
Kindly withdraw Plaintiff's Application for Rule to Show Cause.
Respectfully submitted,
Date: November 19,2002
ROB~RALDO ,
By: ~
Gerald S. Robinson, Esquire
Attorney l.D. No. 27423
4407 North Front Street
P.O. Box 5320
Harrisburg, PA 17110
(717) 232-8525
Attorney for Plaintiff
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Re: Kum Soon Sol v. Bryan Hwan 801- No. 2000-6541
Date: December 20,2000
Enclosed please find an envelope addressed to Opposing Counsel as requested. Kindly send a copy of the
Order scheduling the hearing to Opposing Counsel as soon as it is available. I thank you in advance for your
attention to this matter.
Cumberland County Prothonotary
To: Attention: Becky
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013-3387
&G
Robinson & Geraldo
Attorneys at Law
4407 North Front Street
P.O. Box 5320
Harrisburg, Pennsylvania 17110.5320
Phone, (717) 232..8525