HomeMy WebLinkAbout00-06961
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF ? PENNA.
Karl L. Krug,
Plaintiff
N O 2000-6961 Civil
VERSUS
Lisa L. Krug,
Defendant
DECREE IN
DIVORCE
AND NOW, QCCIti / 2002 IT IS ORDERED AND
DECREED THAT Karl L. Krug , PLAINTIFF,
AND Lisa L. Krug , 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; -
The terms of the Property Settlement and Separation Agreement dated
June 10, 2002, are incorporated, but not merged.
By THE COURT:
?i/ '/'/ .
ATTE T: J.
7 PROTHONOTARY
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120. "- L, 96/
THIS AGREEMENT made this day of J %-,? , 2002
of Mechanicsburg, Cumberland County, Pennsylvania, hereinafter
"Husband",
A
N
D
Lisa L. Krug, of Mechanicsburg, Cumberland County
to as "Wife".
RECITALS:
Karl L. Krug,
to as
Pennsylvania, hereinafter referred
R.1: The parties hereto are Husband and Wife, having been joined in marriage
August 22, 1981, in New Germany, Pennsylvania: and
R.2: A Complaint for Divorce has been filed in the Court of Common Pleas of
Cumberland County, Commonwealth of Pennsylvania, to Number 00-69G1, Civil Term;
and
R.3: The parties' hereto desire to settle fully and finally their respective financial
and property rights and obligations including, but not limited to all matters (between them
relating to the ownership of real and personal property, claims for spousal support,
alimony,'alimony pendente lite,
approximately ".1 /" to Husband.
9/6 LO Husband.
RA: The distribution of the parties' marital property is based on Exhibit "A" of this
Agreement which distributes the marital property approximately 55.9% to Wife and
i
R.5: The parties also desire to settle the issues of custody of their minor children,
Joshua M. Krug, DOB 4-29-85, and Jennifer L. Krug, DOB 7-30-88, co?jnsel fees and
costs, and the settling of any and all claims and possible claims agaiet the other or
against their respective estates.
NOW THEREFORE, in consideration of the covenants and promise hereinafter to
be mutually kept and performed by each party, as well as for other goo and valuable
consideration and intending to be legally bound, it is agreed as follows:
(1) SEPARATION: It shall be lawful for each party at all times hereafter to live
separate and apart from the other party at such place or places as he or sloe from time to
time may choose or deem fit, free from any control, restraint or interference from the
other. Neither party will molest the other or endeavor to compel the other to cohabit or
dwell with him or her by any legal or other proceeding. Each party shall Ibe free of the
interference, authority or contact by the other as if he or she was single and unmarried
except as maybe necessary to carry out the terms of this agreement.
(2) DIVORCE:
The parties acknowledge that the marriage is irretrievably broken ald that they will
secure a mutual consent no-fault divorce decree in the above-captioned (divorce action.
Upon the execution of this agreement, the parties shall execute and file lan Affidavit of
Consent and Waiver of Notice, necessary to finalize said divorce. Husba?d shall cause
the divorce to be transmitted to the Court, immediately after execution of thi? Agreement.
(3) REAL PROPERTY: The parties are the owners of certain rBal estate with
improvements thereon erected known and numbered as 4900 Charles Road,
Mechanicsburg, Pennsylvania 17050-3036.
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Husband and Wife agree that the real estate is under contralct for sale at
$116,500. Upon sale and settlement, the net proceeds as hereinafter prolvided shall be
i
divided fifty-five (55%) percent to Wife and forty-five (45%) percent to Husband.
Husband shall have exclusive possession of the marital residence until sale and
settlement. During said period, Husband shall be responsible for fall household
expenses, including the Wells Fargo Home Mortgage, utility bills, insuraryce, taxes and
maintaining the marital residence in its current condition, normal wear and dear excepted.
In the event all expenses with regard to the marital residence are not current at the time
of sale and settlement, said expenses shall be paid, by setoff, from Husbajnd's equitable
distribution as hereinabove set forth, except that interest for the current month, up to the
date of the settlement, shall not be deducted from Husband's share.
In the event repairs or extraordinary maintenance, which means a single repair or
maintenance item exceeding five hundred ($500) dollars, are required duri rig Husband's
period of exclusive possession then in that event Husband shall pay said item and shall
be reimbursed at settlement prior to equitable distribution. Husband shall, f time permits,
advise Wife of said items and request her consent, which shall not bell unreasonably
withheld.
(4) DEBT:
A. MARTIAL DEBT: Husband and Wife acknowledge and agree that
i
there are no other outstanding debts and obligations which are martial, or for which the
i
other might be liable, incurred prior to the signing of this Agreement, excepts as follows:
i. Members First Personal Loan $ 9,550.
ii. Mellon Bank Personal Loan
$ 5,090.
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iii. Firestone $ 226.
iv. Discover Card $ 7,216.
V. First USA Credit Card $ 8,054.
vi. American General Credit Card $ 964
vii. Fleet Credit Card $ 4,200.
viii. Members First -Van Loan $7,400.
TOTAL 35 300.
(The balances shown are approximate as of the date the debts were assumed by
the respective parties)
1: Husband hereby assumes the Members First Personal Loan,i Mellon Bank
Personal Loan, Firestone, Discover Card, First USA Credit Card, Ame?ican General
Credit Card and Fleet Credit Card by making timely monthly payments and agrees to
indemnify and hold Wife harmless from any and all loss on the loans assumed by
Husband. Husband agrees to regularly attempt to transfer these balances to credit
cards or loans in his own name or to refinance these obligations in order to remove
Wife's name from said obligations.
2: Wife shall pay the obligation to Members First with regard to the an by making
timely monthly payments and agrees to indemnify and hold Husband harmless from any
and all loss on the loan assumed by Wife.
Each party shall pay in a timely fashion the outstanding joint debts as set forth
herein and further agrees to indemnify and save harmless the other fro lm any and all
claims and demands made against either of them by reason of such debts or obligations.
B: Post Separation Debt: In the event that either party contracted or incurred any
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debt since the date of separation on July 1, 2000, the party who incurred aid debt shall
be responsible for the payment thereof regardless of the name in which Ithe debt may
have been incurred.
C: Future Debt: From and after the date of this agreement neither party shall
contract or incur any debt or liability for which the other party or his or h?r property or
estate might be responsible and shall indemnify and save the other party harmless from
any and all claims or demands made against him or her by reason of debts or obligations
incurred by the other party
(5) MOTOR VEHICLES: Each party relinquishes any right, title and interest he or
she may have to any and all motor vehicles currently in possession of
Wife shall have possession of the 1998 Pontiac Montana or its replacem
Husband the 1995 Ford Mustang and 1992 Chevrolet Caprice. Within
date of this agreement each party shall execute any documents necessc
vehicles properly registered in the other party's name with the Pennsylve
of Transportation. Each party shall assume full responsibility of any encu
motor vehicle received by said party, and shall hold harmless and
other party.
vehicle, and
days of the
to have said
Department
rance on the
iifv the other
party from any loss thereon.
(6) TANGIBLE PERSONAL PROPERTY: The parties hereto mutually agree that
they have effected a satisfactory division of the furniture, household furnishings,
appliances, tools and other household personal property between them, and they
mutually agree that each party shall from and after the date hereof bel, the sole and
separate owner of all such property presently in his or her possession) whether said
property was heretofore owned jointly or individually by the parties hereto. This
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agreement shall have the effect of an assignment or bill of sale from eacl party to the
other for such property as may be in the individual possession of each of the parties
i
hereto.
The parties currently have, in escrow, with the law firm of Saidis, Shoff, Flower and
Lindsay, the total amount of $ 14,089.37 being the escrow proceeds from tl?e refinance of
the home, the Edward Jones stock redemption, the income tax refund and the Fleet tax
escrow refund. The escrow held by Saidis, Shuff, Flower and Lindsay shall',be distributed
$7,589.37 to Husband and $6,500.00 to Wife.
(7) INTANGIBLE PERSONAL PROPERTY: Each party hereby relinquishes any
right, title or interest he or she may have in or to any intangible personal property currently
titled in the name of or in the possession of the other party, including, but snot limited to,
stocks, bonds, insurance, bank accounts, individual retirement accounts; employment
benefits including retirement accounts, savings plans, pension plans, stoc? plans, 401K
plans and the like.
This paragraph shall specifically include the following accounts: Husband shall
retain his Edward Jones 401 K and Edward Jones Roth IRA. Wife shall retalin her Edward
Jones 401 K and Pennsylvania State Retirement Account.
The Dreyfuss Retirement Account, having a balance of approximately $40,951.00
shall be divided fifty (50%) percent to Wife and fifty (50%) percent ',to Husband.
Husband acknowledges receipt prior to this distribution of the sum of fourthousand two
hundred 'eighteen ($4,218.00) dollars from the prior retirement account with Merrill Lynch
or AccuBanc which was rolled over into Dreyfuss.
Husband shall retain the Datek stock, which has a current value of $143, together
with the proceeds from its partial liquidation of twelve thousand ($12,000) d liars.
(8) CUSTODY OF CHILDREN: The parties agree that legal custod of their minor
children, Joshua M. Krug, DOB 4-29-85 and Jennifer L. Krug, DOB 7-30-88i shall be joint,
with both parties having the right to make major parenting decisions affecting the
children's health, education and welfare.
Wife shall have primary physical custody of the children subject to Husband's
partial physical custody at the following minimum times:
(a) Every other weekend from Friday at 5:00 p.m. until Sunday at 10:00 p.m.;
(b) One night per week as selected by Husband with Wife's con?ent;
(c) Alternating holidays with the holidays being New Year's Day, President's
Day, Memorial Day, 4`" of July and Labor bay,
(d) Easter and Thanksgiving shall alternate with Husband havingi Easter 2002
(i) Easter shall mean from Holy Thursday night or Good Friday morning
until Easter Sunday at 10:00 p.m.;
(ii) Thanksgiving shall be mean from after school on the preceding
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Wednesday to the following Sunday at 10:00 p.m.
(e) Christmas shall alternate between (i) and (ii) below with Husband having (i)
for Christmas 2002;
(i) 9:00 a.m. Christmas eve morning to 2:00 p.m. Christmas day;
(ii) 2:00 p.m. Christmas day to 2:00 p.m. December 26
(f) Two hours on each child's birthday, unless said birthday is on, a weekend at
which time Husband shall have one-half day;
(g) One-half of the children's summer vacation; and
3. The remarriage of Wife or cohabitation by Wife with' a member of
the opposite sex not within the degrees of consanguinity
4. The payment of the amount set out above for a period of 84
months from the date of the first payment.
B. The parties acknowledge that they know one another's Social Security
Number. Alimony payments shall be deductible from Husband's gross
income for the purpose of filing income tax returns and includible in Wife's
gross income for the same purpose.
C. Unless agreed otherwise, the alimony payment set out herein shall be
payable to the Office of Domestic Relations of Cumberland Oounty or the
Office of Domestic Relations of a county having jurisdiction fiver Husband
and enforcement shall be by attachment of Husband's wag .
D. Husband shall immediately secure a life insurance policy o his life which
may be a decreasing term policy in the initial amount of seventy thousand
($70,000) dollars, as security, for the payment of alimony and shall
designate Wife irrevocable beneficiary. Said policy may be decreased on
an annual basis based on the amount of alimony paid in the prior year
only. Proof of insurance coverage to be provided to Wife's counsel or
Wife upon inception and then on an annual basis thereafter.!
(11) POSTSECONDARY EDUCATION:
A. Husband shall pay or cause to be paid the net educationall expenses of
each of the parties' children at an accredited undergraduate college or
university provided he/she is enrolled as a full time student, yp to a total of
four (4) years of post secondary education subject to the limitations and
conditions set forth herein. Educational expenses shall be defined as
tuition, room and board (including full meal plan), fees, books, supplies,
reasonable clothing and spending money as well as transportation
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(g) Other times as agreed upon.
(9) CHILD SUPPORT:
(A) Husband shall pay to Wife for the use, benefit, support and m; aintenance of
their minor children, the sum ordered by the Court of Common Pleas, filed to
Docket 577-S-2000, PACES 053102436.
(B) Husband shall pay the total arrearage on the Support Order, which
currently includes spousal support upon execution of this Agreement,
(C) Husband and Wife agree that any inquiry into support for the period
preceding September 30, 2000, has been resolved and each party releases the
other for any claim for support or credit against support paid.
(D) The parties agree that in the event of a material change in circumstances of
either party, or a change in the custody arrangements set forth herein, the amount
of support payments shall be subject to an appropriate adjustment by agreement
or, if the parties are unable to agree, by order of a court of competent jurisdiction,
and the amount ordered by any such court shall be deemed to be the amount due
hereunder.
(10) ALIMONY:
A Alimony: Husband agrees to pay to Wife as alimony the sum of $825 per
month commencing the 1st day of June, 2002 and continuing in equal amounts
on the same day of each subsequent month until the occurrence) of one of the
following:
1. The death of Wife
2. The death of Husband
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expenses. If child is living off campus with the written consent of both
parties, instead of room and board, educational expensed, shall include
actual expenses for rent, utilities and food.
B. Husband's obligation to pay a child's educational expenses ?s set forth in
the paragraph above shall be reduced by deducting any applicable loans,
scholarships and grants. Each child shall be required to a' ply for loans,
scholarships and grants and the parties will cooperate o the extent
necessary in assisting him/her to so apply.
Husband's obligations to pay educational expenses shall cease upon the
happening of the first of the following events:
(a) Child's death;
(b) Husband's death;
(c) The child's receipt of a bachelor's degree or its equiva{ nt;
(d) The child's completion of four (4) consecutive or n n-consecutive
academic years of higher education;
(e) The child being placed on academic probation for more than one (1)
consecutive semester; or
(f) The child reaching the age of twenty-three (23) years df age.
C. To the extent permitted by law, Husband and Wife agree that Husband
shall be entitled to the income tax exemption for any child a rolled in post
secondary education for whom Husband is paying the expe ses as above
described. Wife agrees to execute any document necessary or desirable
for Husband to secure said exemption.
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(12) ADVICE OF COUNSEL: The parties hereto acknowledge that each has
i
been notified of his or her right to consult with counsel of his or her choice, and have been
provided a copy of this agreement with which to consult with counsel, Wife ?s represented
by Debra Denison Cantor, Esq. and Husband is represented by Robert C;. Saidis, Esq.,
Each party acknowledges and accepts that this agreement is, under the dircumstances,
fair and equitable, and that it is being entered into freely and voluntarily after having
received such advice and with such knowledge as each has sought from col'unsel, and the
execution of this agreement is not the result of any duress or undue influence, and that it
is not the result of any improper or illegal agreement or agreements. Each party shall pay
his or her own attorney for all legal services rendered or to be rendered) on his or her
behalf.
(13) ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at
the request of the other, execute, acknowledge and deliver to the other patty any and all
further instruments that may be reasonably required to give full force an? effect to the
provisions of this Agreement.
(14) INCOME TAX:
The parties have heretofore filed joint Federal and State Tax returns. Both parties
agree that in the event any deficiency in Federal, state or local income tax is proposed, or
assessment of any such tax is made against either of them, each will indemnify and hold
harmless the other from and against any loss or liability for any such tax deficiency or
assessment and any interest, penalty and expense incurred in connection therewith.
Such tax, interest, penalty or expense shall be paid solely and entirely by the individual
who is finally determined to be the cause of the misrepresentations or failures to disclose
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the nature and extent of his or her separate income on the aforesaid joint returns.
(15) COMPLETE DISCLOSURE: The parties do hereby warra4 represent,
acknowledge and agree that each is fully and completely informed of, and is familiar with,
the wealth, real and personal property, estate and assets, earnings and (income of the
other and has made any inquiry he or she desires into the income or estatte of the other
and received any such information requested. Each has made a full and complete
disclosure to the other of his and her entire assets, liabilities, income and expenses and
any further enumeration or statement thereof in this Agreement is specifically waived.
(16) RIGHTS AND RESPONSIBILITIES: Husband and Wife acknowledge that
each of them has read and understand his and her rights and responsibilities under this
Agreement and that they have executed this Agreement under no compr Ision to do so
but as a voluntary act.
(17) FULL SETTLEMENT: Except as herein otherwise provided, each party
hereby releases the other from any and all claims, or demands up to the date of
execution hereof. It is further specifically understood and agreed by and between the
parties hereto that each party accepts the provisions herein made in lieu of and in full
settlement and satisfaction of any and all of said party's rights against the 'other for past,
present and future claims on account of support, maintenance, alimony, alimony
pendente lite, counsel fees, costs and expenses, equitable distribution of marital property
and any other claims of the party, including all claims which have been raised or may be
raised in an action for divorce.
(18) RELEASE OF ALL CLAIMS: Except as may be otherwise specifically
provided in this Agreement, Husband and Wife, for themselves, their heirs,
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representatives and assigns, each hereby forever releases, remises, discharges and
quitclaims the other, and such other's heirs, representatives, assigns and estate, from
and with respect to the following:
A. All liability, claims, causes of action, damages, costs; contributions
and expenses or demands whatsoever in law or in equity;
B. All rights, title, interest or claims in or to any property of the other,
whether real, personal or mixed and whether now owned or hereafter acquired;
C. All rights of curtesy and dower and all claims or rights i? the nature of
curtesy and dower;
D. All widow or widower's rights;
E. All right, title, interest or claim in or to the other's estate, whether now
owned or hereafter acquired, including but not limited to all rights or claims:
(1) to take against the other's will;
(2) under the laws of intestacy;
(3) to a family exemption or similar allowance; and
(4) all other rights or authority to participate or intervene in a
I
deceased spouse's estate in any way, whether arising under the laws of Pennsylvania or
any other country, territory, state or political subdivision.
F. All rights or claims to any accounting;
G. All rights, claims, demands, liabilities and obligations arising out of or
in connection with the marital relationship or the joint ownership of property, whether real,
personal or mixed;
H. All rights, claims, demands, liabilities and obligations arising under
13
the provisions of the Pennsylvania Divorce Code, as the same may be amended from
time to time, and under the provisions of any similar statute enacted by anyother country,
state, territory or political subdivision;
1. All rights, claims, demands, liabilities and obligations each party now has,
or may hereafter have, against or with respect to the other.
(19) GOVERNING LAW: This Agreement shall be construed under lithe law of the
Commonwealth of Pennsylvania. If any provision of this Agreement is determined to be
invalid or unenforceable, all other provisions shall continue in full force and effect.
(20) INCORPORATION INTO DECREE: In the event that either of the parties shall
recover a final judgment or decree of absolute divorce against the othi in a court of
competent jurisdiction, the provisions of this Agreement may be incorporated by reference
or in substance but shall not be merged into such judgment or decree and this Agreement
shall survive any such final judgment or decree of absolute divorce and shall be entirely
independent thereof.
(21) BREACH: In the event that either party breaches any provision of this
Agreement, he or she shall be responsible for any and all costs incurred lio enforce the
Agreement, including, but not limited to, court cost and counsel fees of the,other party. In
the event of breach, the other party shall have the right, at his or her election; to sue for
damages for such breach or to seek such other and additional remedies as may be
available to him or her.
(22) ENTIRE UNDERSTANDING: This Agreement constitutes the entire
understanding between the parties and there are no covenants, conditions,
representations, or agreements, oral or written, of any nature whatsoever, other than
14
those herein contained.
(23) AGREEMENT BINDING ON PARTIES AND HEIRS: This Agreement shall
bind the parties hereto, their respective heirs, executors and assigns.
IN WITNESS WHEREOF, the parties hereto intending to be legally bound have
hereunto set their hands and seals the day and year first written above.
Ql?
Witness
COMMONWEALTH OF PENNSYLVANIA
COUNTY OFF, CUMBERLAND
On this _ I I 1day of , 2002, before me, the undersigned, personally appeared Karl L. Krug
whose naFne is subscrl ed to the within instrument, and acknowledged that they executed the same for
the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
1
COMMONWEALTH OF PENNSYLVANIA Stacy L. Frick,
East Pannsboro Twp
COUNTY OF CUMBERLAND My Commission Exj
On this "" day of 2002, before me, the undersigned, personally appeared Lisa L. Krug
whose name is subs bed to the within instrument, and acknowledged that they executed the same for
the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
NOTARIAL DEAL (4 CASSANDRA T. ROSENBAUM, Notary Public Notary Public
Camp Hill Boro, Cumberland County
6/5/02 My Commission Expires December 4, 2004
15
ASSETS - Lisa and Karl Krue
VEHICLES:
1998 Pontiac Montana
$ LISA
15,550 KARL
1995 Ford Mustang $ 10,550
1992 Chevrolet Caprice $ 2,925
Personal Property $ 5,000 $ 2,000
House (Estimate) $ 10,045 $ 8,218
Retirement Accounts:
a) Dreyfuss - $40,951 (Estimate)
$
20,535
$
20,416
POC $4,218 $ 4,218
Edward Jones (3 accounts)
b) Lisa - 401K - $8,510
$
8,510
c) Karl - 401K - $15,159 $ 15,159
d) Karl - Roth - $550 $ 550
e) PA State Retire. - Lisa - $2,708 $ 2,708
f) Natl.City/AccuBank (trans.toDreyfuss) $ -
SSF&L Escrow $14,089.37 $ 6,500 $ 7,589
Escrow Proceeds (Loan)
Edward Jones - Stock Redemption
Tax Refund
Fleet Escrow (Tax Rebate)
Datek - Stock $12,143 $ 12,143
$ 68,848 $ 83,768
LIABILITIES - Lisa and Karl Krug
Members 1st -Van Loan
$ LISA
7,400 KARL
Wells Fargo - New 1 st Mortgage
Members 1st - Personal $ 9,550
Mellon Bank - Personal $ 5,090
Firestone $ 226
Discover Card $ 7,216
First USA Credit Card $ 8,054
American General $ 964
Fleet Credit Card $ 4,200
$ 7,400 $ 35,300
6/4/02
Asset Totals $ 68,848 $ 83,768 $ 109,916
Liabilities $ 7,400 $ 35,300
Net Value = $ 109,916 $ 61,448 $ 48,468
55.9% 44.1%
Exhibit "A"
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Karl L. Krug,
Plaintiff
V.
Lisa L. Krug,
Defendant
IN THE COURT OF COMMON PLEASE OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-6961 CIVIL TERM
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court for entry of a
divorce decree:
1. Ground for divorce: irretrievable breakdown under Section 3301(c) 3301(d)(1)
the Divorce Code. (Strike out inapplicable section).
2. Date and manner of service of the complaint: Letter dated October 11, 2000 to
Debra Denison Cantor, Esq., Acceptance of Service signed October 13, 2000 and recorded
February 7, 2002.
3. (Complete either paragraph (a) or (b)).
(a) Date of execution of the affidavit of consent required by Section
3301(c) of the Divorce Code: by the Plaintiff June 11, 2002 ; by
the Defendant June 10, 2002 .
(b) (1) Date of e eutien of the DLd.etiffs ate" davit . `ed by SeatieR
3301(d)efthe Diveree Cede:
4. Related claims pending: None
5. Complete either (a) or (b).
(a) Date and manner of service of the notice of intention to file praecipe
to transmit record, a copy of which is attached: 6/14/02
SAIDIS
SNUFF, FLOWER
& LINDSAY
26 W. High Street
Carlisle, PA
(b) Date Plaintiffs Waiver of Notice in 3301(c) Divorce was filed with
the Prothonotary: 6/11/02
Date Defendant's Waiver of Notice in 3301(c) Divorce was filed with th
Prothonotary: 6/10/02 /
t a LO ° 2 z
I
Robert . iCt""ttorney for Plaintiff
C7 S"3 ?
C ie?*
5
1
?C - fJ?
Karl L. Krug, IN THE COURT OF COMMON PLEAS' OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. CIVIL TERM
Lisa L. Krug,
Defendant IN DIVORCE
NOTICE
You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you must take
prompt action. You are warned that if you fail to do so, the
case may proceed without you and a decree of divorce or
annulment may be entered against you by the Court. A judgment
may also be entered against you for any other claim or relief
requested in these papers by the Plaintiff. You may lose money
or property or other rights important to you, including custody
or visitation of your children,
When the ground for the divorce is indignities or
irretrievable breakdown of the marriage, you may request
marriage counseling. A list of marriage counselors is available
in the office of the Prothonotary at the Cumberland County Court
House, High and Hanover Street, Carlisle.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR
ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF
THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
ber C. Saidis, Esq.
Attorney for Plaintiff
Karl L. Krug,
Plaintiff
V.
Lisa L. Krug,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. M-(,9(/CIVIL TERM
IN DIVORCE
COMPLAINT UNDER SECTION 3301 (c)
OR 3301 (d) OF THE DIVORCE CODE
1. Plaintiff is Karl L. Krug, who currently resides at 2
North Locust Street, Apartment C, Cumberland County,
Shiremanstown, Pennsylvania 17011-6376.
2. Defendant is Lisa L. Krug, who currently resides at 4900
Charles Road, Cumberland County, Mechanicsburg, Pennsylvania
17050-3036.
3. Plaintiff and Defendant have been bona fide residents in
the Commonwealth for at least six months immediately previous to
the filing of this Complaint.
4. The Plaintiff and Defendant were marred on August 22,
1981, in New Germany, Pennsylvania.
5. There have been no prior actions of divorce or for
annulment between the parties.
6. The Plaintiff has been advised of the availability of
marriage counseling and the Plaintiff may have the right to
request that the Court require the parties to participate in
counseling. Having been so advised, Plaintiff does not desire
the Court to order counseling.
7. The marriage is irretrievably broken.
Plaintiff prays Your Honorable Court to enter a
decree of divorce.
Respectfully submitted,
Rober C. Saidis, Esq.
Attorney for Plaintiff
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
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.
DATED :
Karl L. Krug, aintiff
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AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on .
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. 1 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.
Karl L. Krug, Plai
Date: 6 " //-4 2
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
§3301(c) OF THE DIVORCE CODE
I consent to the entry of a final Decree of Divorce without notice.
2. 1 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. 1 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 herei are made subject to the penalties of 18
Pa.C.S. 4904 relating to unsworn falsification to authorities.
Karl L. Krug,, 'Plaintiff
Date: 6 -1,1-a Z
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KARL L. KRUG, IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 00-6961 Civil Term
LISA L. KRUG, CIVIL ACTION -LAW
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
October 11, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90)
days have elapsed from the date of the filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of
intention to request entry of the decree.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to
unworn falsification to authorities.
Date: June 10, 2002
Krug
JUN 1 1 2002
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KARL L, KRUG,
Plaintiff
V.
LISA L. KRUG,
Defendant
IN THE COURT OF COMMON PLEAS, CU
MP?C?2L AwD ;
COUNTY, PENNSYLVANIA
NO. 00-6961
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF DIVORCE DECREE UNDER
§ 33010 OF THE DIVORCE CODE
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. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating
to unworn falsification to authorities.
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DATE: June 10, 2002 LA - -(J
sa L. Krug
JUN 1 1 2002
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Karl L. Krug,
Plaintiff
V.
Lisa L. Krug,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.2000-6961 CIVIL TERM
IN DIVORCE
ACCEPTANCE OF SERVICE
I accept service of the Notice and Complaint in Divorce on
behalf of Lisa L. Krug, Defendant above, and certify that I am
authorized to do so in the above captioned matter.
Date
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DQDYa De?s1Qn Cantor, Esquire
REAGER, R & COGNETTI,P.C.
2331 Market Street
Camp Hill, PA 17011-4642
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Karl L. Krug, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 00-6961 CIVIL TERM
Lisa L. Krug,
Defendant IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
Plaintiff, Karl L. Krug, moves the court to appoint a master with respect to the following claims:
( x) Divorce (x) Distribution of Property
( ) Annulment ( ) Support
(1 Alimony ( 1 Counsel Fees
( ) Alimony Pendente Lite ( ) Costs and Expenses
and in support of the motion states:
(1) Discovery is complete as to the clalm(s) for which the appointment of a master is requested.
(2) The Defendant appeared in the action by her attorney, Debra Denison Cantor, Esquire, Reager,
Adler & Cognetti, P.C. 2331 Market Street, Camp Hill, PA 17011-4642
(3) The statutory ground(s) for divorce is/are: 3301( c) or 3301(d).
(4) Delete the inapplicable paragraph(s).
(a) The action is contested.
(b) An agreement has been reached with respect to the following claims: .
N/A
(c) The action is contested with respect to the following claims:
equitable distribution of property.
(5) The action complex issues of law or fact. N/A
(6) The hearing is expected to take: 1 day
(7) Additional information, if any, relevanyto/he motion:
Date: 1_Z?"02'
Rob6rt C. Saidis, Esquire
Attorney forPlaintiff, Karl L. Krug
26 W. High Street
Carlisle, PA 17013
ORDER APPOINTING MASTER n
AND NOW, this 77 day of 2002, , Esquire, is appointed master
with respect to the followiin-g- claims--
By the Cou ,
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KARL L. KRUG, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 00 - 6961 CIVIL
LISA L. KRUG,
Defendant IN DIVORCE
ORDER OF COURT
AND NOW, this _ 4 day of
2002, the economic claims raised in the proceedings having
been resolved in accordance with a property settlement and
separation agreement dated June 10, 2002, the appointment of
the Master is vacated and counsel can file a praecipe
transmitting the record to the Court requesting a final
decree in divorce.
cc: %obert C. Saidis
Attorney for Plaintiff
,,,,E)ebra A. Denison Cantor
Attorney for Defendant
BY THE COURT,
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PROPERTY SETTLEMENT AND SEPARATION AGREEMENT
THIS AGREEMENT made this
day of '2002 between Karl L. Krug,
of Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred to as
"Husband",
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Lisa L. Krug, of Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred
to as "Wife".
RECITALS:
R.1: The parties hereto are Husband and Wife, having been joined in marriage
August 22, 1981, in New Germany, Pennsylvania: and
R.2: A Complaint for Divorce has been filed in the Court of Common Pleas of
Cumberland County, Commonwealth of Pennsylvania, to Number 00-6961, Civil Term;
and
R.3: The parties' hereto desire to settle fully and finally their respective financial
and property rights and obligations including, but not limited to all matters between them
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relating to the ownership of real and personal property, claims for spousal support,
alimony, alimony pendente lite,
R.4: The distribution of the. parties' marital property is based on Exhibit "A" of this
Agreement which distributes the marital property approximately 55.9%. to Wife and
approximately 44.1 % to Husband.
1
R.5: The parties also desire to settle the issues of custody of their 'Minor children,
I
Joshua M. Krug, DOB 4-29-85, and Jennifer L. Krug, DOB 7-30-88, counsel fees and
costs, and the settling of any and all claims and possible claims against the other or
against their respective estates.
NOW THEREFORE, in consideration of the covenants and promises hereinafter to
be mutually kept and performed by each party, as well as for other good and valuable
consideration and intending to be legally bound, it is agreed as follows:
(1) SEPARATION: It shall be lawful for each party at all times hereafter to live
separate and apart from the other parry at such place or places as he or she from time to
time may choose or deem fit, free from any control, restraint or interference from the
other. Neither party will molest the other or endeavor to compel the other to cohabit or
dwell with him or her by any legal or other proceeding. Each party shall be free of the
interference, authority or contact by the other as if he or she was single and unmarried
except as maybe necessary to carry out the terms of this agreement.
(2) DIVORCE:
The parties acknowledge that the marriage is irretrievably broken and that they will
secure a mutual consent no-fault divorce decree in the above-captioned divorce action.
Upon the execution of this agreement, the parties shall execute apd file an Affidavit of
Consent and Waiver of Notice, necessary to finalize said divorce. Husband shall cause
the divorce to be transmitted to the Court, immediately after execution of this Agreement.
(3) REAL PROPERTY: The parties are the owners of certain real estate with
improvements thereon erected known and numbered as 4900 Charles Road,
Mechanicsburg, Pennsylvania 17050-3036.
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Husband and Wife agree that the real estate is under contract for sale at
$116,500. Upon sale and settlement, the net proceeds as hereinafter provided shall be
divided fifty-five (55%) percent to Wife and forty-five (45%) percent to Husband.
Husband shall have exclusive possession of the marital residence until sale and
settlement. During said period, Husband shall be responsible for all household
expenses, including the Wells Fargo Home Mortgage, utility bills, insurance, taxes and
maintaining the marital residence in its current condition, normal wear and tear excepted.
In the event all expenses with regard to the marital residence are not current at the time
of sale and settlement, said expenses shall be paid, by setoff, from Husband's equitable
distribution as hereinabove set forth, except that interest for the current month, up to the
date of the settlement, shall not be deducted from Husband's share.
In the event repairs or extraordinary maintenance, which means a single repair or
maintenance item exceeding five hundred ($500) dollars, are required during Husband's
period of exclusive possession then in that event Husband shall pay said item and shall
be reimbursed at settlement prior to equitable distribution. Husband shall, if time permits,
advise Wife of said items and request her consent, which shall not be unreasonably
withheld.
(4) DEBT:
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A. MARTIAL DEBT: Husband and Wife acknowledge and agree that
there are no other outstanding debts and obligations which are martial, or for which the
other might be liable, incurred prior to the signing of this Agreement, except as follows:
Members First Personal Loan $ 9,550.
ii. Mellon Bank Personal Loan $ 5,090.
3
iii. Firestone $ 226.
iv. Discover Card $ 7,216.
V. First USA Credit Card $ 8,054.
vi. American General Credit Card $ 964.
vii. Fleet Credit Card $ 4,200.
viii. Members First -Van Loan $7,400.
TOTAL 35 30 .
(The balances shown are approximate as of the date the debts were assumed by
the respective parties)
1: Husband hereby assumes the Members First Personal Loan„ Mellon Bank
Personal Loan, Firestone, Discover Card, First USA Credit Card, American General
Credit Card and Fleet Credit Card by making timely monthly payments and agrees to
indemnify and hold Wife harmless from any and all loss on the loans assumed by
Husband. Husband agrees to regularly attempt to transfer these balances to credit
cards or loans in his own name or to refinance these obligations in order to remove
Wife's name from said obligations.
2: Wife shall pay the obligation to Members First with regard to the van by making
timely monthly payments and agrees to indemnify and hold Husbarto harmless from any
and all loss on the loan assumed by Wife.
Each party shall pay in a timely fashion the outstanding joint debts as set forth
herein and further agrees to indemnify and save harmless the other from any and all
claims and demands made against either of them by reason of such debts or obligations.
13: Post Separation Debt: In the event that either party contracted or incurred any
4
debt since the date of separation on July 1, 2000, the party who incurred said debt shall
be responsible for the payment thereof regardless of the name in which 'the debt may
have been incurred.
C: Future Debt: From and after the date of this agreement neither party shall
contract or incur any debt or liability for which the other party or his or her property or
estate might be responsible and shall indemnify and save the other party harmless from
any and all claims or demands made against him or her by reason of debts. or obligations
incurred by the other party
(5) MOTOR VEHICLES: Each party relinquishes any right, title and interest he or
she may have to any and all motor vehicles currently in possession of the other party.
Wife shall have possession of the 1998 Pontiac Montana or its replacement vehicle, and
Husband the 1995 Ford Mustang and 1992 Chevrolet Caprice. Within 15 days of the
date of this agreement each party shall execute any documents necessary to have said
vehicles properly registered in the other party's name with the Pennsylvania Department
of Transportation. Each party shall assume full responsibility of any encumbrance on the
motor vehicle received by said party, and shall hold harmless and indemnify the other
party from any loss thereon.
(6) TANGIBLE PERSONAL PROPERTY: The parties heret mutually agree that
they have effected a satisfactory division of the furniture, household furnishings,
appliances, tools and other household personal property between them, and they
mutually agree that each party shall from and after the date hereof be the sole and
separate owner of all such property presently in his or her possession whether said
property was heretofore owned jointly or individually by the parties hereto. This
5
agreement shall have the effect of an assignment or bill of sale from each party to the
other for such property as may be in the individual possession of each of the parties
hereto.
The parties currently have, in escrow, with the law firm of Saidis, Shuff, Flower and
Lindsay, the total amount of $ 14,089.37 being the escrow proceeds from the refinance of
the home, the Edward Jones stock redemption, the income tax refund and the Fleet tax
escrow refund. The escrow held by Saidis, Shuff, Flower and Lindsay shall be distributed
$7,589.37 to Husband and $6,500.00 to Wife.
(7) INTANGIBLE PERSONAL PROPERTY: Each party hereby relinquishes any
right, title or interest he or she may have in or to any intangible personal property currently
titled in the name of or in the possession of the other party, including, but not limited to,
stocks, bonds, insurance, bank accounts, individual retirement accounts, employment
benefits including retirement accounts, savings plans, pension plans, stock plans, 401K
plans and the like.
This paragraph shall specifically include the following accounts: Husband shall
retain his Edward Jones 401 K and Edward Jones Roth IRA. Wife shall retain her Edward
Jones 401 K and Pennsylvania State Retirement Account.
The Dreyfuss Retirement Account, having a balance of apprd cimately $40,951.00
shall be divided fifty (50%) percent to Wife and fifty (50%) percent to Husband.
Husband acknowledges receipt prior to this distribution of the sum of four, thousand two
hundred eighteen ($4,218.00) dollars from the prior retirement account with Merrill Lynch
or AccuBanc which was rolled over into Dreyfuss.
Husband shall retain the Datek stock, which has a current value of $143, together
6
with the proceeds from its partial liquidation of twelve thousand ($12,000) dollars.
(8) CUSTODY OF CHILDREN: The parties agree that legal custody of their minor
children, Joshua M. Krug, DOB 4-29-85 and Jennifer L. Krug, DOB 7-30-88, shall be joint,
with both parties having the right to make major parenting decisions, affecting the
children's health, education and welfare.
Wife shall have primary physical custody of the children subject to Husband's
partial physical custody at the following minimum times:
(a) Every other weekend from Friday at 5:00 p.m. until Sunday at 10:00 p.m.;
(b) One night per week as selected by Husband with Wife's consent;
(c) Alternating holidays with the holidays being New Year's Day, President's
Day, Memorial Day, 4' of July and Labor Day,
(d) Easter and Thanksgiving shall alternate with Husband having Easter 2002
(i) Easter shall mean from Holy Thursday night or Good Friday morning
until Easter Sunday at 10:00 p.m.;
(ii) Thanksgiving shall be mean from after school on the preceding
Wednesday to the following Sunday at 10:00 p.m.
(e) Christmas shall alternate between (i) and (ii) below with Husband having (i)
for Christmas 2002;
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(i) 9:00 a.m. Christmas eve morning to 2:00 p.m. Christmas day;
(ii) 2:00 p.m. Christmas day to 2:00 p.m. December 26
(f) Two hours on each child's birthday, unless said birthday is on a weekend at
which time Husband shall have one-half day;
(g) One-half of the children's summer vacation; and
7
3. The remarriage of Wife or cohabitation by Wife with, a member of
the opposite sex not within the degrees of consanguinity
4. The payment of the amount set out above for a 'period of 84
I
months from the date of the first payment.
B. The parties acknowledge that they know one another's Social Security
Number. Alimony payments shall be deductible from Husband's gross
income for the purpose of filing income tax returns and includible in Wife's
gross income for the same purpose.
C. Unless agreed otherwise, the alimony payment set out herein shall be
payable to the Office of Domestic Relations of Cumberland County or the
Office of Domestic Relations of a county having jurisdiction over Husband
and enforcement shall be by attachment of Husband's wages.
D. Husband shall immediately secure a life insurance policy on his life which
may be a decreasing term policy in the initial amount of seventy thousand
($70,000) dollars, as security, for the payment of alimony and shall
designate Wife irrevocable beneficiary. Said policy may be decreased on
an annual basis based on the amount of alimony paid in the prior year
only. Proof of insurance coverage to be provided to Wife's counsel or
Wife upon inception and then on an annual basis thereafter.
(11) POSTSECONDARY EDUCATION:
A. Husband shall pay or cause to be paid the net educational expenses of
each of the parties' children at an accredited undergraduate college or
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university provided he/she is enrolled as a full time student, up to a total of
four (4) years of post secondary education subject to the limitations and
conditions set forth herein. Educational expenses shall be defined as
tuition, room and board (including full meal plan), fees, books, supplies,
reasonable clothing and spending money as well as transportation
9
(g) Other times as agreed upon.
(9) CHILD SUPPORT:
(A) Husband shall pay to Wife for the use, benefit, support and maintenance of
their minor children, the sum ordered by the Court of Common Pleas, filed to
Docket 577-S-2000, PACES 053102436.
(B) Husband shall pay the total arrearage on the Support Order, which
currently includes spousal support upon execution of this Agreement.
(C) Husband and Wife agree that any inquiry into support for the period
preceding September 30, 2000, has been resolved and each party releases the
other for any claim for support or credit against support paid.
(D) The parties agree that in the event of a material change in circumstances of
either party, or a change in the custody arrangements set forth herein, the amount
of support payments shall be subject to an appropriate adjustment by agreement
or, if the parties are unable to agree, by order of a court of competent jurisdiction,
and the amount ordered by any such court shall be deemed to be the amount due
hereunder.
(10) ALIMONY:
A Alimony: Husband agrees to pay to Wife as alimonylhe sum of $825 per
month commencing the 1st day of June, 2002 and continuing in equal amounts
on the same day of each subsequent month until the occurrence of one of the
following:
1. The death of Wife
2. The death of Husband
8
expenses: If child is living off campus with the written consent of both
parties, instead of room and board, educational expense' shall include
actual expenses for rent, utilities and food.
B. Husband's obligation to pay a child's educational expenses 'as set forth in
the paragraph above shall be reduced by deducting any applicable loans,
scholarships and grants. Each child shall be required to apply for loans,
scholarships and grants and the parties will cooperate to the extent
necessary in assisting him/her to so apply.
Husband's obligations to pay educational expenses shall cease upon the
happening of the first of the following events:
(a) Child's death;
(b) Husband's death;
(c) The child's receipt of a bachelor's degree or its equivalent;
(d) The child's completion of four (4) consecutive or non-consecutive
academic years of higher education;
(e) The child being placed on academic probation for more than one (1)
consecutive semester: or
(f) The child reaching the age of twenty-three (23) years of age.
C. To the extent permitted by law, Husband and Wife agree that Husband
shall be entitled to the income tax exemption for any child enrolled in post
secondary education for whom Husband is paying the expenses as above
described. Wife agrees to execute any document necessary or desirable
for Husband to secure said exemption.
10
(12) ADVICE OF COUNSEL: The parties hereto acknowledge that each has
been notified of his or her right to consult with counsel of his or her choice, and have been
provided a copy of this agreement with which to consult with counsel, Wife is represented
by Debra Denison Cantor, Esq. and Husband is represented by Robert C. Saidis, Esq.,
Each party acknowledges and accepts that this agreement is, under the circumstances,
fair and equitable, and that it is being entered into freely and voluntarily after having
received such advice and with such knowledge as each has sought from counsel, and the
execution of this agreement is not the result of any duress or undue influence, and that it
is not the result of any improper or illegal agreement or agreements. Each party shall pay
his or her own attorney for all legal services rendered or to be rendered on his or her
behalf.
(13) ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at
the request of the other, execute, acknowledge and deliver to the other party any and all
further instruments that may be reasonably required to give full force and effect to the
provisions of this Agreement.
(14) INCOME TAX:
The parties have heretofore filed joint Federal and State Tax returns. Both parties
agree that in the event any deficiency in Federal, state or local income tax is proposed, or
assessment of any such tax is made against either of them, each will indemnify and hold
harmless the other from and against any loss or liability for any such tax deficiency or
assessment and any interest, penalty and expense incurred in connection therewith.
Such tax, interest, penalty or expense shall be paid solely and entirely by the individual
who is finally determined to be the cause of the misrepresentations or failures to disclose
11
the nature and extent of his or her separate income on the aforesaid joint returns.
(15) COMPLETE DISCLOSURE: The parties do hereby warrant, represent,
acknowledge and agree that each is fully and completely informed of, and is familiar with,
the wealth, real and personal property, estate and assets, earnings and income of the
other and has made any inquiry he or she desires into the income or estate of the other
and received any such information requested. Each has made a full and complete
disclosure to the other of his and her entire assets, liabilities, income and expenses and
any further enumeration or statement thereof in this Agreement is specifically waived
(16) RIGHTS AND RESPONSIBILITIES: Husband and Wife acknowledge that
each of them has read and understand his and her rights and responsibilities under this
Agreement and that they have executed this Agreement under no compulsion to do so
but as a voluntary act.
(17) FULL SETTLEMENT: Except as herein otherwise provided, each party
hereby releases the other from any and all claims, or demands up to the date of
execution hereof. It is further specifically understood and agreed by and between the
parties hereto that each party accepts the provisions herein made in lieu of and in full
settlement and satisfaction of any and all of said party's rights against the other for past,
present and future claims on account of support, maintenance, alimony, alimony
pendente lite, counsel fees, costs and expenses, equitable distribution of marital property
and any other claims of the party, including all claims which have been raised or may be
raised in an action for divorce.
(18) RELEASE OF ALL CLAIMS: Except as may be otherwise specifically
provided in this Agreement, Husband and Wife, for themselves, their heirs,
12
representatives and assigns, each hereby forever releases, remises, discharges and
quitclaims the other, and such other's heirs, representatives, assigns and estate, from
and with respect to the following:
A. All liability, claims, causes of action, damages, costs, contributions
and expenses or demands whatsoever in law or in equity;
B. All rights, title, interest or claims in or to any property of the other,
whether real, personal or mixed and whether now owned or hereafter acquired;
C. All rights of curtesy and dower and all claims or rights in the nature of
curtesy and dower;
D. All widow or widower's rights;
E. All right, title, interest or claim in or to the other's estate, whether now
owned or hereafter acquired, including but not limited to all rights or claims:
(1) to take against the other's will;
(2) under the laws of intestacy;
(3) to a family exemption or similar allowance; and
(4) all other rights or authority to participate or intervene in a
deceased spouse's estate in any way, whether arising under the laws of Pennsylvania or
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any other country, territory, state or political subdivision.
F. All rights or claims to any accounting;
G. All rights, claims, demands, liabilities and obligations arising out of or
in connection with the marital relationship or the joint ownership of property, whether real,
personal or mixed;
H. All rights, claims, demands, liabilities and obligations arising under
13
the provisions of the Pennsylvania Divorce Code, as the same may be amended from
time to time, and under the provisions of any similar statute enacted by any other country,
state, territory or political subdivision;
1. All rights, claims, demands, liabilities and obligations each party now has,
or may hereafter have, against or with respect to the other.
(19) GOVERNING LAW: This Agreement shall be construed under the law of the
Commonwealth of Pennsylvania. If any provision of this Agreement is determined to be
invalid or unenforceable, all other provisions shall continue in full force and effect.
(20) INCORPORATION INTO DECREE: In the event that either of the parties shall
recover a final judgment or decree of absolute divorce against the other in a court of
competent jurisdiction, the provisions of this Agreement may be incorporated by reference
or in substance but shall not be merged into such judgment or decree and this Agreement
shall survive any such final judgment or decree of absolute divorce and shall be entirely
independent thereof.
(21) BREACH: In the event that either party breaches any provision of this
Agreement, he or she shall be responsible for any and all costs incurred to enforce the
Agreement, including, but not limited to, court cost and counsel fees of the other party. In
the event of breach, the other party shall have the right, at his or hjr election; to sue for
damages for such breach or to seek such other and additional remedies as may be
available to him or her.
(22) ENTIRE UNDERSTANDING: This Agreement constitutes the entire
understanding between the parties and there are no covenants, conditions,
representations, or agreements, oral or written, of any nature whatsoever, other than
14
those herein contained.
(23) AGREEMENT BINDING ON PARTIES AND HEIRS: This Agreement shall
bind the parties hereto, their respective heirs, executors and assigns.
IN WITNESS WHEREOF, the parties hereto intending to be legally bound have
hereunto set their hands and seals the day and year first written above.
Witness
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
On this 11day of 1 II I 1 L 2002, before me, the undersigned, personally appeared Karl L. Krug
whose n me is subscr"i((k to the within instrument, and acknowledged that they executed the same for
the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
('J'
Notarial Seal
COMMONWEALTH OF PENNSYLVANIA Stacy L. Frick, No try Publh
. East Pennsbaro Twp., Cuulberland
COUNTY OF CUMBERLAND My Commission Expires llan, 12,
On this /Of% day of 2002, before me, the undersigned, personally appeared Lisa L. Krug
whose name is subs bed to the within instrument, and acknowledged that they executed the same for
the purposes therein contained.
IN WITNESS WHEREOF, 1 hereunto set my hand and official seal.
NOTARIAL SEAL (.A.iZa?yt
CASSANDRA T. ROSENBAUM, Notary Public Notary Public
Camp Hill Som, Cumberland County
6/5/02 My Commission Expires December 4, 2004
is
ASSETS - Lisa and Karl Krug
VEHICLES:
1998 Pontiac Montana
$ LISA
15,550 KARL
1995 Ford Mustang $ 10,550
1992 Chevrolet Caprice $ 2,925
Personal Property $ 5,000 $ 2,000
House (Estimate) $ 10,045 $ 8,218
Retirement Accounts:
a) Dreyfuss - $40,951 (Estimate)
$
20,535
$
20,416
POC $4,218 $ 4,218
Edward Jones (3 accounts)
b) Lisa - 401K - $8,510
$
8,510
c) Karl - 401K - $15,159 $ 15,159
d) Karl - Roth - $550 $ 550
e) PA State Retire. - Lisa - $2,708 $ 2,708
f) Natl.City/AccuBank (trans.toDreyfuss) $ -
SSF&L Escrow $14,089.37 $ 6,500 $ 7,589
Escrow Proceeds (Loan)
Edward Jones - Stock Redemption
Tax Refund
Fleet Escrow (Tax Rebate)
Datek - Stock $12,143 $ 12,143
$ 68,848 $ 83,768
LIABILITIES - Lisa and Karl Krug
Members 1st -Van Loan
$ LISA
7,400 KARL
Wells Fargo - New 1st Mortgage
Members 1st - Personal $ 9,550
Mellon Bank - Personal $ 5,090
Firestone $ 226
Discover Card $ 7,216
First USA Credit Card $ 8,054
American General $ 964
Fleet Credit Card $ 4,200
$ 7,400 $ 35,300
6/4/02
Asset Totals $ 68,848 $ 83,768 $ 109,916
Liabilities $ 7,400 $ 35,300
Net Value = $ 109,916 $ 61,448 $ 48,468
55.9% 44.1%
Exhibit "A"
KARL L. KRUG, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. :NO. 00-6961 CIVIL TERM
LISA L. KRUG,
Defendant : IN DIVORCE
PETITION TO RAISE ADDITIONAL CLAIMS
AND NOW comes Petitioner, Lisa L. Krug, by and through her attorneys, Reager & Adler,
P.C. and files the following Petition.
A Divorce Complaint was filed to the above term and number.
2. On February 5, 2002, Plaintiff raised claims for equitable distribution.
3. Defendant now raises the following claims.
ALIMONY, ALIMONY PENDENTE LITE, ATTORNEY'S FEES AND COSTS
4.. Defendant lacks sufficient property to provide for her reasonable needs.
5. Defendant is unable to sufficiently support herself through appropriate
employment.
6. Plaintiff has sufficient income and assets to provide continuing support for the
Plaintiff.
By reason of this action, Defendant will be put to considerable expense in the
preparation of her case in the employment of counsel and the payment of costs.
The Defendant is without sufficient funds to support herself and to meet the costs
and expenses of this litigation and is unable to appropriately maintain herself during the
pendency of this action.
9. Defendant's income is not sufficient to provide for her reasonable needs and pay
her attorney's fees and the costs of this litigation.
10. Plaintiff has adequate earnings to provide for the Plaintiffs support and to pay her
counsel fees, costs and expenses.
WHEREFORE, Defendant respectfully requests this Honorable Court to compel Plaintiff
to pay Defendant alimony pendente lite, support, counsel fees, costs and expenses of this action.
Respectfully submitted,
REAGER & ADLER, P.C.
ESQUIRE
IJ91. No. MAMS
2331 Market Street
Camp Hill, PA 17011
[717] 763-1383
ated: ; 1240 ?/ Attorneys for Defendant
CERTIFICATE OF SERVICE
AND NOW, this ?'?' day of 2002, I hereby verify that I
have caused a true and correct copy of the foregoing documen , to be placed in the U.S. mail,
first class, postage prepaid and addressed as follows:
Karl L. Krug, Plaintiff
c/o Robert C. Saidis, Esquire
SAIDIS, SHUFF, FLOWER & LINDSAY
26 West High Street
Carlisle, PA 17013
V
a
a
R
n
3.
ZI:
c '
ma
.?
C . C??'
. t
too
l
Karl L. Krug, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 00-( .941 CIVIL TERM
Lisa L. Krug,
Defendant IN DIVORCE
PETITION FOR EQUITABLE DISTRIBUTION
AND NOW comes the Petitioner, Karl L. Krug, by and through his attorneys, Saidis,
Shuff, Flower & Lindsay, and hereby files the following Motion:
1. A Divorce Complaint was filed to the above term and number.
2. There remains certain property, real and personal, which need to be divided.
WHEREFORE, the Petitioner respectfully requests Your Honorable Court to enter an
Order awarding equitable distribution pursuant to the Divorce Code.
Respectfully submitted,
SAID SHUFF, FLOWER & LINDSAY
BY:
Rdbert C. Saidis, Esquire
26 W. High Street
Carlisle, PA 17013
SAIDIS
SHUF$ FLOWER
& LINDSAY
ATIDRNEYS•AT•LAW
26 W. High Street
Carlisle, PA
CERTIFICATE OF SERVICE
I hereby certify that on the date set forth below I served a true and correct copy of the
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATTORNEYS-AT-LAW
26 W. High Street
Carlisle, PA
Petition for Equitable Distribution upon the attorney for the Plaintiff by first class mail
addressed as follows:
Debra Denison Cantor, Esquire
Reager, Adler & Cognetti, P.C.
2331 Market Street
Camp Hill, PA 17011-4642
Date: -?L) I
.r
VERYFICA O1
I verify that the statetnients made in the fomgp' ing Petition for Equitable Distribution
are true and correct. I understand that false statements herein are made subject to the penalties of
18 Pa. C.S. § 4904, relating to unswom falsification to authorities.
DATED: / - Z P-0 2-
SAIDIS
SHUFF, FLOWER
& LINDSAY
s' T "°-`
2b W. Higb Sired
C ,uele. PA
- Mr-
c
o
!
R.r PrC :
?
00
tv
C-n
KARL L. KRUG, IN THE COURT OF OCMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 00}6961 CIVIL TERM
LISA L. KRUG,
Defendant IN DIVORCE
PRE-TRIAL STATEMENT SECTION 1920.33(b)
i
AND NOW comes the Plaintiff in the above7captioned action and files the following
Trial Statement:
List of Assets: A list of the parties' ap
are attached hereto and marked Exhibit
"A„
2. Experts: Appraiser from Dynamic
Mechanicsburg, Pennsylvania 1
dated November 29, 1999, as well as
copy of the November 29, 1999
Inc., 5001 Carlisle Pike,
The witness shall testify as to the appraisal
current value of the marital residence. A
is attached hereto and marked Exhibit
«B„
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATTORNEYS-AT-LAW
26 W. High Street
Carlisle, PA
3. Other Witnesses: None.
4. List of Exhibits: The Plaintiff's list ef exhibits, by agreement of Counsel, shall be
provided at a later time.
5. Gross Income: The 2000 joint Incorne Tax Return is marked Exhibits "C".
Plaintiff has also attached his W-2s from the year 2001 from National City Bank,
Allied Mortgage and P.E.G.S.III, Inch
6. Plaintiff has itemized marital debt onlthe chart, which is marked Exhibit "D".
Plaintiff may provide additional evidence and reserves the right to submit at that
time an up-to-date income and expense form as required by the practice and
procedure governing an action in support.
Retirement Benefits: A list of the retirement benefits is disclosed on Exhibit "A".
8. There is no dispute known as to the value of items of tangible property.
9. List of marital debts: See Exhibit "D"
10. Proposed resolution of the economic issues: Plaintiff proposes the economic
distribution, by means of equitable distribution, 52% to wife, 48% to husband and
alimony in the amount of $650 for five years.
Respectfully submitted,
ISAIDIS, SHUFF, FLOWER & LINDSAY
BY:
Robert C. Saidis, Esquire
6 West High Street
Carlisle, PA 17013
Attorney for the Plaintiff
I
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATrORNRYS•AT•I.AW
26 W. High Street
Carlisle, PA
ASSETS - Lisa and Karl Krug
VEHICLES:
1998 Pontiac Montana
$ 15,550
1995 Ford Mustang $ 10,550
1992 Chevrolet Caprice $ 2,925
Personal Property $ 10,000
House $
Retirement Accounts:
a) Dreyfus - $40,951
$ 40,951
Edward Jones (3 accounts)
b) Lisa - 401K - $8,686
$ 8,686
c) Karl - 401K - $15,159 $ 15,159
d) Karl - Roth - $1,149 $ 1,149
e) PA State Retire. - Lisa - $2,708 $ 2,708
f) Natl.City/AccuBank - Karl - $2,681 $ 2,681
SSF&L Escrow $14,089.37 1 $ 14,089
Escrow Proceeds (Loan)
Edward Jones - Stock Redemption
Tax Refund
Fleet Escrow (Tax Rebate)
Datek - Stock $13,168 $ 13,168
$ $ 137,616
* House - Marital residence is 4900 Charles Road, Mechanicsburg, PA and
is currently listed for sale for $119,900. An appraisal is attached as Exhibit "B".
Exhibit "A"
I
00/28/2002 14:37 FAX 7179018286 ALLIED MTG CORP
Y
®,e4Ya
0 Deparboadit of the Yrpasury, _ mtemm Aeara a aMYpO
U.S. IndIvIdUal Income 7s" 2000
M tat'
Fort eyear JAA.i- Dec. eh, 2000, crethertax ear be hnlnr
_20f
Label ,
yaw noel name And Initial
Lasiname
land L Karl L
. KE?u
'
Inewetlons .
-
An page la) 9 1laldlnl r¢1um, epOpeA'SdUsl nameandlnltlal Last name
WBihahRe E Lisa L. Krug
We[. M 4=6 AddNA&nanbcrand susel). It you havpa P.O. hmr, gas 04961?a. "Y?
omerwlde,
please pool
t a 4900 Charles Road
vr
ype. E Clly,iownerpoeloHe¢,slats,andz[Padda.if you have aforeign addrosa.see page Is.
Presidar(lal M0ChAMioSIbUr91 PA 17050
Election Campaign' Nota. Checking "Yes" wil not 0hengs your tax or reduce your refund.
reee page 10.) Dd You, or ur Opangs If fun 11 grit return, Want $3 to o to this fund?
1 Single
121002
1545-0074
1169-54-7551
.irouse8m¢alauanatdncdo ear
21,G-52-532G
Apt. no. A IMPORTANTI A
You must enter
your SSN(S) above-
YOU Spouse
fling Stel 2 jmfliwr rred Deng joint return (even If only one had income)
3 rled Piing saparata return. -enter spouses sod. Goo, no, abdve 8 full name ham )o,
check only 4 d of.haraseheld (with qualifying person). (See page 19.) it that qualifying person 15 a child but not you dependant,
°n` bO1 this child $
name here P,
5 a1 1 wide at) wtal.tle endenk child yser 5 lute died 9e .See 19. Dago EXem tionS ea 0 Yourself, return, p parent cCar sommuere hock box aelsa) can claim you as a dependent 06 his or her fax -
P 9 ............ .. ............................ Nat. of baces
it cc rraacckdedan 2
b ® Spouse ......... .....:............................. .......................... C
Ii m ra than ale
dapenderla,
aea paw 2v.
roar ?.
non
With yo. 3
of llaewah
to drvoren
¢ allot
e 201
nta
above _^
Add npmb are
d Total nurrtler•ot turemoecns alafined....... anteredpn
?
....aaaae?,. 5
....s-..------------- .......................
c dependents!
g), Fire! Laalnanre 0, boppndentb coaLLt
eeeurlty number I'M Depandenl'B fa)dnklfquantinne Nu. of
'
'reptivnahlp to you ccrenlld tlll l fWaceGM141 0.90 LAX child'.
20) 0; Who
Jerem 8. Kru 210-68- 723 5on .,road
Joshua M. Kra 201-68-4071 Son K 0aldn
Tenn fif er L, Krug 199-72-2914 Hau hter ?C you due
(see pap
099ol
--l B
nal
t
entered
7 Wages, 461121195, ZIPS, table. Attach Form(s) W-2.. rArc s.
rte{!?,!
!?
C
,
Income as Taxable interest Attach Schedule 5 if required . crab vcrY7•x LArw.- irrtu cif
d as 216
4e l
b Tex-exempt'uterest, oo nos include on line W .. Dub Y.yes/v I??
Attach a Ordinary dividends, Attach Schedule 8 if required ...............:
.................... 9
I
w z ssww2and 1o Taxable refunds, credits, or offsets; of state and local income Was (seE page 9 , ........... 10
.
Alsoenaeh 11 Alimony received' ....... ................... .... ...............
W
R II ••..,••...
F 77
?IIIW
-
mX was wnhhaa. T8 easiness income rat (lass). Abaco Schedule C or 0.EZEZ . .. ..... . . . .. . . . . .. . . . .......... 12
13 Capital gain or (loss). Attach Utioduie Pit required. If not required, check here ? L7........ 13 15 }
14 other gains or (losses). Attach Form 4797 ..........................................
14 ? -
16a Total IRA dbtdbuaocs...... 1160 te Taxable amount taeapp.2aq 15b
t9a Too pensions and annuities too - I b- Taxable amount tspo p& gal 16b
if you dill not 17 Flenad real estate; royalill partnerships, S corporations, trusts, ate. Attach Schedule E....... 17
gel aW2,
5" Petro 21. t6 Farm income or (loss). Attach Schedule to ..........................................
161
but donat 19 Unemployment eompersaeoh .................. ...,................
enclose le
.
Ailmh a"rneymsnt, 208 So01al SE?urlty benaais..... 1200 J 1 b Taxable amount the pp. xs)
Al sob
-T-
eo, please use
renn W404. 21 Other income. Property Tax Rebate
22 Add the amounb in the ter eight column for lines 7 threw h 21. This is your total income .... b..
-??- 21
22 iC G 1
i14 , 2 91 I
23 IRA deducndn(sea gaga 27) ......................... 23 •,
Adjusted 24 Student loan interest deduction (see page 27) ......... ...
Gross 16 Medina( saving's account deduction. Attach Form
Income 26 Moving expenses. Attach Form 39M ....................
87 One-half of self-6mploymant tax. Athcht 3chedule'SE....:.
29 Seir-amployed health Insurance deduction (906 pegs 2) • • • 24
26
27
28
I
tai.
o:
r;
*;T
29 5alf-emPleyod SEP, SIMPLE, and 4uallfl6d ans ......
99 Penalty on early withdrawal of sarirrga ...........
......
3o
`:;;;•
I
ale Alimony paid, b Raciplerlre SSN ? Lola M l
32 Add linos 23 through 31a ............................. ..... 1,................ •- . •. 32
33 Subtract line 32 tom Pna 22 Ttts is yelr adlueted gross inco me.. . ?t . ................ . yi es 1 114,2311
FAFor Oisctoeura, Privacy Act, and Paperwork Reduction Apt Notice, see doge 96. (Faust 11471co roe,n 1040 (soon
Exhibit 1,0..
03/28;2002 14:88 FAX 7179018206 ALLIED MTG CORP
Fcrm 1040(2000) Karl L, and L132e L. Xruq
Ri003
169-54-7551 Pane 2
Tax and 34 Amount from line 33 (adjusted 9rom income) ...................... . . ... . ...... . ....... 34 1
114, 29 1
Credits $So Crack If: ?'you were 66 or elder, ? Blind; ? Spouse was 65 or older, ? Blind. -
Add the number of boxes chocked above and enter the toter hart . • ..... : ..... . ...? 35a t'?*`
or I
siendrve to IF you are maritd Wling separately and your apouee 11em®s deductions
?ou wer
,
e
y
agwoean a 01.16-elatua a4en, see page 31 and check here... • .... , .'........... 1 . , .. , . , ...® 954 ? a
•
'
ra•ldaet standard
30 Enter your Itemized dedslellons from Schedule A. Une.28
or a
' ?
,
P
shown on
i
d
` u Cr
an cl
i
e ecksd
?
p
Po a
m
you Re
4 get eons
ad nden
as
35ao
a
ny bo
an2ne
? 36 _7,874
ador ri
lna
37
36 from
3 ....'...,. .....
37 _
102,417
housemaid:
se
436
38 If line 34 is $88,700 or less, multiply 82,900 by the total number of exempBD
s claimed on Ina 6d.
:r r _
, It prig 34 t5 over $96,700, ties the worksVoot on page 32 for this amount toe er 14
000
Married riling
39 Taxable become
Subtract 11
19 38 f
li ............... 33 I
,
101nrly dl• .
,
rom
ne $7.
If lin
ee le Ma
3T
a
H
lin
4
?R
0 a
lliYln ,
e
rc
nlar-0- ••....... ••••••.......
eM
e .•.,..... ...... 35 ,
17
.
.
9
wldsntar); .40 Tax (see page 32), Check If any tax is from a ? Form(5) 8514 In ? Form 972,,,,,, 40 :, 19 ,059 i'
s7,3SO
mlc0 41 Alternative minimum tax, Attach Form 6251 , ......' . . . . . . ............ ............. . ........ 41 :-
f 42 Add lines 40 and 41 ..........................•............... .............. .....? i 42 19, 05'g T
tspmmey 43 Foreign tex credit. Att ch Form 9118 If required ..... . . . . .
...
. 43
4a.ms. ..
• f
44 Credit for child and dependent we expenses. Att. Form 2441 ..... 44 ,I
45 Credit for the sk iy or the disabled. Attach BCheduie R . , , , , , , . , . 45
Education
credits.
Form
6863
.
'
4
6) .
47 Child tax
cre
dit(Mp g 3
..
....'
..
......... 7
750
^l`
?
42
Adoption credit, Attach Form 88.9 , , .........
. ..
..
4S ,. I
49 Other. Chock If TOM a ? Form 3800 b ? Farm 8$98 ?rMr •ik tr
C Q Farm 8801 d Q Form (Specify) 49
50 Add line 43 through 49. These art your total credal . _ .............. j.... , , . • ............ , 50 750 1'
51 Subtract lima 80 from one 42. It line 50 ig more than 13ee 42, enter -p . ........... ......... - , , .. Ar , 51 1 d 3 0 9
Other 52 Sal-amployment tax. Att ^oh. SE ............ . ............. . . . ..... I..................... 52
fa%es 53 Social security and Medicare tax on lip Income not reported to ampicyar. Attach Form 4137 ......... 53 _
54 Tax on IRAs, othdl' retirement plans, and MBAs. Attach Form 5329 It raquuadL .................... 54
55 Advance owned Income credit payments from Farm(s) W-•2 .............,..... , ............... 55
56 Household employment WIN$- Attach Schedule H .:. • .....' ... . . . .......... . . . ....... ....... 5s
57 Add lines 61 through 58. ThIs Is Your total tax ................ :...... ............. • .....I.
67
18 , 3 0 9
-
laymertts es Federal Income tax withheld from Forms W-E and 10% .......... 56 22,189
-
--? 5s 2000 estimated tax payments and amount applied from 1999 return .
ave a
h 59
............ ............
Gas Earned income credit t? CI .
Wiring i
Yln9
698 47 s?;
hlld,allacn I
:ensdvme:lo. III Nontaxable earned income: amt. ?
and type? h?:
61 Excess social SeoUrlty and RRTA tax withheld (aaa P69060) ....
. 61 3 8 ,;
....
62 Additional child tax cred8t Attach Form 8812 ................. 62 Is';: .
63 Amount paid YEith raqueat for egensaom It fife ties page M . , .
64 Other payments. Check If from aUForm 2439 b E] Ferm 4136 .. W. ! N
65 Add ines
l 5a. 59, 80a, and 61 through Be, Ttreso are your tote( me
rts .. • • • • ,
. . . . . ........ . .'
5
2 2 , 2 2 7 f
37 from line 66. This Is the amount you overpaid , :. ; , , ...
letund 66 If line 65 is more than line 67, subtract tin 66 3 , 916
' -
y
ova It 678 Amount of Into 68 You want refunded to you ..:......... ........ . .............:.....? 97a 3 , 918
Mainly
eppallPtll
ee pxacso to RCUtlg number f ? C Type: ? Checking
? savings ? I
,
id III) In e]o.
'a, env ord. IN Account number I
88 Amount of line 86 You want applied to our toot estimated tax ? 68
t 69 If line 67 is more than line 65, subtract tine 85 from fine 57. This Is the amount you owe.
,MoUn
For details on how to pay, see page 51 .......................... .
oil Owe .................... .?
69
70 Estimated tax penalty. Also include on line 69 .......... . . ...... 7C
Undcrpenaldea or perjury, l declare Intl l have ea?mined lhlsraltm antl aacampan,li, aphe0udas it claimants, and to the beer of my knowlenpe and heliey, ahcY IM
ign Irua, citric 1, and eomplaw, Deelaratlon of praparer itother than raxpdYErl is DaBetl dnall lnforma'I, 0r which preporer has srryknewbdpe.
lore ycursonature Data Youro
nni n.wrn9 upa(aa oaytims peaneounpor
m page 1e. Sal s 717-901-$263
'aPxcpPY pause's Sllxdalure.rt sleinl velum, pain mud sign.
r your Date apaues accupatlon Mayy She IRS dlscUpamia l'etw.
wltlt fns nrepuer Shown belawl
bards, CZ°rl^&1
r "Opaeassn? ®Yod ?n.
Prpparar'e
a I
Date
chak If FreWw'e SON WFTIN
!d pmrtmrp Sue A, Redmond, CPA 4/05/03. eel(-amplarcd ® 159-38-620;
repareras Flan'.
se Only iisgif
EIN 25-16
IFOUetA 11122/00 Form 1040 (2000)
03,126,12002 14:38 FAX 7178016266 ALLIED MTG CORP (4004
(SCHHEDULES A&e Schedule A - Itemized Deductions oMq No. lase-ours 1040) i
oeprlmant m me Treasury 2000
? Attach to Form 1o40. ? See instructions for
A and 13 (Farm 1040),
07
namop) anown on Fo,m 1 of o Yma aadal sacwhy m,maar
Xaxi L. and Lisa L, krua fi9,54-7551
M@dlcal
Caution. Do notfiriclude
r paid by olhera
uribad
Deatial
..
t I
denta
e page A -Z)
l expenses
n
oa
ll
Ex
genaes
2
2
Itj
E
ar
mOU t fram
Form
Iln
3 Mlulnply line 2 above by7.5% (.075). ........ . ................... a 3 'e'I
4 Subtract line $ Wpm line?, r t' line 3 6 more than fine 1, enter -0- .......:....... ....... ......... . a i 11
Taxes YOU
a
and
local
Starts
income 'taXes .... , , ,,',,. .
. ,,' , . .
g 4
571
Paid 6 Real
estate
takes sae
? B ;
1
328
,
7 Personal property taxes ..........
...................'...., 7 , ',.
Coe a Other taxes. List
type and amount
case A-a)
?
See statement 1
- - • .
__---.- -------_--.--_
° NCC
_ - ^ - - -
S
490 7
_ 8 _ _ - - - -
Add lines fithrough 8 ....................................... ......--.. ............. 4 6.329
interest
10
Home mortgage lnlareet and pants reported on Form 1008 , , .. , ... , .
10
3 , 953
?d _
rou Paid 11 hi,omemoreago lntereat nolnaporley layuuon Farm logo. If pala tothe pafean n:.
lee whom you bought the home, owe page A-36 snow h al person'sname. In na L address
ape A-a} ?
- - - - - - - - - - - - - - - -
- - - - - - - - - - - - - - - - -
-
jail.
Riff ?
Iota.
e'lorA
_ _ _ _ - -- - - - - .- _ _ _ _
- _ _
n
I@rut le
_. -
_
_
_
_
_ e .. . _
-
ar 72 to
Panf3
not
reportatl
yoU
on n
Form 1098. pg.
Sea .,q-9 ............. 12
`
atluvllbie•
11 '
4?i
'
13 Investment Iplereet. Attach Form 4652, If required. ?I
:
°
(See Page A-3.).... .,................................. ....... 13 169 }
.
a
_ 14 Addlines_101hrough t9 .................:..................... ..,......... ..... ....., to 4,142
tft to
15
Gifts by cash or check. If any gift of $250 or more, see pg, A-4. B
?'
1 240
60 _
vweta s;
Iharity 16 Other than W cash or check. it any gift of $aso or more, see page A-4, '`? ?'
Y.0 made a Yap must attach Form 8283 if over 6500 ............... . .:........ 16
i
Ii and got a
emrll for ll, 17 -
,
Carryovar from prior Yaw....... ....... . . . . . ..,,, ............
.
17
A''S?'.F,
K Pool A-a. 13 Add lines 15 throw h 17 .................
to 1 1,240
asuany and 19 Casualty or theft lass(es). Attach Form 4684,
heft Losaft See. sA-5 .............................................. !........... 0
............I 19
ub Experboas 20 LlnraimbUraed employee expenses -job travel, union dues, job education) _
nd Most Other ate. You must attsoh Form 2106 or.2106-EZ if required. (see page Aw Ili
'
lixallsnecus
eductloma 0, Form 2106 (Tax a' er)
3 389
I ;
`'
s
'
u
- _ -----_..----^ -----
- - - - - - - - - - - - - - - - - - t"
______
. zo 2,389 ;i
21 ____ __ ___
Tax preparation fees.. , . ..:
, , ....?_ ..... ... 21 'b"
22 Otte' expenses - Investment. safe deposit box, ate, List type and amount ?.,"z
- - - - - - - - - - - - - - - - - - -
- - - -- - - - - - - - - - -
- - - - - - - - - - - - - - - - - -
here,) '_ .?
?
23 Add lines 20 through 22 ....... .....
, ,
? ......,.. '?, 23 2 , 3 8 9
24 ? _
?
Enter amount from Form 1040, line 34 .... L a"
114 , 2 911
J
25 .
.__
Multiply One 24 above by 255 (92) ............. ........ l i 2a v ..(
10
Aar 37 Other- b'om list on papa A-b. List type and amount ? _ - _ _ ?- - _ - - -
iscellanaou5 _ _ _ _ _ _ `li
adu Ndrrs _ _ _ - - _
- --
27 -- - --- - ;..1 0
no[ 20 is Form 1040, fine 34, over $125.950 (over $64,475 it maMed Ming 5eparal'ey)?
?mired ® No. Your deduction Is not limited. Add the amounts in the far right call
iductlons to lines 4 through V. Also, enter this amount on Form 1040, line 36. , , ..... ? 28 J. 1, 8 74
j] Yea. Your deduction may be limited. See a a A.S for the amount tolenter. F al
A For Paperwork Reduction Acl Notice, see Form 1040 Instructions. IFpusx 1 roalao Schedule A '(Form 1040) 2000
i
05/28/2002 14:59 PAZ 7179018288 ALLIED MTG CORP Z005
SCHMULS 9' amp No. 1dad-C04 _
(Form 1040) Capital Gains and Losses I
Oeparlmenr Cr Me Treasury 2p00 ll? Attach to Form 1040. ? See Instramend, for Schedule b (Form 1040).
inmrnnl Revenue Srrnde (as) Im Use SChedute D`•1 farmor6 GPace t0 I)6t transoctfong far Imes 1 ww e_ ` Atlaohmpnt^ 12
-na.
I (a)Dle, 1 (Prn Are a q
(Example, PP an. . %VZ ¢.) m) acquired Date TO
(,170.., , da. aY, yr.! Yr.;
0* Date sold
pus, tlaY, h•1
(IQ Bales pared
(sdo page D-aj L._. wbwrA
-Ih ?
'?s+?q
(n Gainar(tols)
6
150 sh- 2}
ago D- t
Sublaall (C)rroM(eg ,;%Ep
n/23/00
7r 827
? 32,962
= olde' ?fir?J/®c??
200 sh- 4/18/00
8,290
wry ?'R
?h 407
8
29G a<
50 sh-A
IE?Xit ech, ,
250 sh-Rite Ai Corp 5/15/,00, ) 1,740 0 1
a Enter
your ehOrt-term totals, if any, from
SCIladula D-1, Ilne 2 ........ . ................ 2 13 9117111 3 Total short-term sates price amounts... ...... 3 l 3 5 9 2
r f
Add column (d) of fires I and 2 .......
4 Shat-term wain from Form 6252 and short-term gain or (loss) from
Forms 4684, 6781, and 6824 ............................................................. 4
5 Net snort term gain or (1095) from partnerships, S corporations, estates, and trusts from Sched luls(s) K-1 5
5 Short-term capitat loss carryover. Enter the amount, If any, Irpm Ilne 8 of year
tw9w Capital Loss Carryover Worksheet . . . . . ...................... ........ 6
7 Net short-temn capital gain or (Mal. Combine column f of limes 1 thr h.6...... , , , , , . ® 7
t it. t enowTerm CenNal d.artns cart f neees..e: _ Awe®4e, amts aa.".s r _s n_,. V-
8 11 D¢6011111not property
(EIGMCl9, i. N.XYZ Do.) (b) Des; e¢quaad
Mae., daY,Yr.) 417 Date adle
No., day„yr.) (d) 9ale£prlca
(sea Pape D-s) Ceat ¢r
(red age Dad (O Gain w(losal
eubbael (e)Rom(tl) aD PHYuri1C {Ain
•(sc¢or Paso lmal6M
3 Enter your long-term totals. if any, from
Schedule D•1, line w ........ .......... ....... 9 K I
1 Total long-Wm sales priest, amounts.
Add column (d) of ann9 6 and 9 . . . .. . ............ 70 1 !I
, '1
'f
x'
'r " < ..
! Un from Form 4797, Par. l; lpng-term' gain from Forms 24139 and 8282;
and long-farm gain or (lass) from Forms 4884, 8781, and 8824 .......... . ............ . , ... 11
Net long-term gain or pose) from partnerships, S corDOratioals, estates, and trusts from Sch9dulg(s) K-1 . 12
Capital gain distributions, See page D-1 .. . . .............. . ......... . . . .. . ......... ........ 13
Lang-term odi ltal Ices carryover. Enter In both ccIumrs (f) and (g) the amount,
if any, from line 13 of your 1999 Capital L058 Carryover Wcrkshsat .... . .... . .................... 74
COm01ne column (g) of tines 8 through 14 ....... . .. . ......... ..... . . . ....... . ... L .... , ,
....I ,<. ,? .
Net
Next; Go t? cel9?onl?athlhack`?). Combine column (f) or rlnpg B through 16.... , ...... ?
16
A i' f!:. !rt.. 'reEF
28% rate gain of less includits all "collectibles gains and tosses" (2g defined on page D-6) and up, to 50% citing ei igbte gain an qualiAed small buslneSt
ack (see page D-4).
r Paperwork Reduction Act Notl04, we Fond 1040 instruotlons. Schedule D (Form 1040) 2000
4 +FOUS5 12/07100
fYWU '- ' ..'?
®008
03/28/2002 14:40 FAI 7179018266 ALLIED MTG CORP
scneaaleptFam taaal saoo Karl L. aid L: Sa L. Krua 109-54-'7x51 aaae2
Summary of Parts 1, and II -
17 Combine lines 7 and 16. If a 1050, gp to I! me 16. If again, enter the gain On Form 7840, line 10 ............ . . ............. .
Nett: Complete Form 1040 through Ilne'39. Then, go to Part )V to figure your tar it:
• Both lines 16 and 17 are game and
• Form 1040, One 39, is more than zero.
othorwiss,stop here,
to If line 1715 a loss, enter horn and as a (loss) on Form 1040,1140 13. the smaller of these losshs:
• The loss on line 17 or
• (53,000) or, if mottled fling separately, (31,5001. ........ .... . ............ . ......... . ..........
Nan: Skip Pali IV below. Instead, complete Form 1040 through line 37. Then, complete the
Capital Lose Cartyover'Woiigheet on page D-6 if:
s The loss on line 17 exce®de the loss on line ill or
TaX Gtan UWI*n Using MWAMum Capital Gains Rates
---
19 Enter your taxahlB income from Form 1040, Ilne 39 ....... . .... . . . ..................:.....
.. --
'.........._ . _ ....... .
20 Enter the smaller of line 16 or line 17 of Schedule 0 .................... . . ................ . 20
21 If you are fling Form 4952, enter the amount from farm 4952. One 4e ........................ . 27
22 Subtract line 21 from line 20. It zero or Less, enter -0- ................... . . . ........ . ..... . 22
Z2 Combine lines 7 and 15. If zero or less, enter -D-........... ........... . . . ....... . . ..... . as
24 Enter the smaller of line 15 or line 23,bulnoINS than zoru ............................... . 24
:6 enter your unraoaptured section 1250 gain, If any, from link 17 of the worksheet on page D-e?..... . 25
26 Add lints 24 and 25 ........... ......... ............................................
.
26
27 Subtractfine. M from line 22. it Wo or less, enter -0- ....... ..................
......?.....
........,,,.,,,, .......
!a Subtract line 27 from line 16. If zero or less, enter -0- ............. ........
.?.....
.. , .............. , ... .
!e Enter the amalier of:
• The amount on line 16 of
• 826,250 if single; 543,650 If married filing jointly or qualifying widow(er)) } , , , . , < . .. . . . .. .. . . . . ............. . .. .
$21,926 If married filing Separately: of $35, 160 If head of household
0 Enter the amallsr of line 28 or Me 29 ............................ . ......:............. . 30
4 Subtract line 22 from line 19, If zero or less, enter -0- ............. ................ . 31
2 Ens' the larger of lire 30 or line 21 .......... .........1..............----.... 1.71 ... 32 .
3 Figure the tax on the amount on line 32. Use the Tax Table or Tax Rate Sche6la5, whichever' applies...... _ ..............
Note: If the amounts on liras 29 and 30 are the same, skip lines 34 through 37 and go to !Inc 38.
4 Enter the amount tam line 29.....,...................... ...................... 34
5 Enter the amount from !!no 30, 1 L . I I I ....................... ........... ....... I.... . a5
i...
9 Subtract tine 35 from fine 34.... .............. ........................
? 36
7 Mu@Iply line 36 by 10`6 (.10) ..............................' .................... !
.... .......................
II
NOW If dre amounts on Ones 19 and 29 are the same, skip lines 38 through 51 and go to tine 52.
I Entar the smaller of line 19 or line 27 ............................................ I.... . 3a _
) Enter the amount from fine 38 .................... _............................ I . ,,. .39
) Subtract line 39 from fine 36 ................ .. ...................... . ...... 11
A
I Multiply line 40 by 2046(.20) ........................................................ .....................
Note; If tine 26 I5 zero or blank, skip lines 42 through 51 and go to fine $2.
t Enter the smaller of rime 22 or line 25 ................................... I .........?L ... . 42
t Add lines 22 and 32 ................:...........: ............
I Enter he amount from line 19 .................. . ................ 4
4
Subtract line 44 tram line 4$. It zero or less, enter --0- ........................ . . . . . ..... . as
i Subtract fine 45 Nam fine 42. if zero or less, enter -0- .... , . ..................... i .. ? 46
' Multiply [Irte46try.26%(.25) ............... .....................................L.,. .......................
Note: H line 2414 zero or blank, skip lines 43 through 51 and gc tp line 62.
I Enter the amount from lima 19 ...................... ................................
? . 48
Add lines 312, and 46 ...... ........ ................................. ..........
? . 4e
Subtract ![no 40 from llne 46.......' ................................. I..... ....,.
?.... . a0
Multiply line 50 by 28% (.29) ....................................................1... .......................
Add lines 33, 37, 41,47, and 51 ................................................. ?...
.......
......... .......
Figure the lox on the amount an line 19. Use the Tax'rable of Tax Rate SChedulas, whichever applies
IPOU86A i v94190 Schedule D (Form 1040) 2000
03/28/2002 14:41 PAZ 7178018266 ALLIED MTC CORP @1007
Scheduie, D-.1 Continuation Sheet for Schedule D DaaaNAt5a5-°°'° ._
(Form 1040) (Form 1040) 2000
DeparE.ManI or lho Irreae?ry ? See inatrue im for Schedule D (erm 1040). AtWhmanr
in)amatsavsnua sevfce (so) ?Attach to Schedule D If you need more to Ilst ans=Uons for 6ne91 and e: 69CUB DE No. 12A
NAM0M)bMDWn9n FDnn104a I Yowxo Wwc=ftnuabar
Xar1 L. and Lisa L. Rru , 169-54-7551
Short-Term Capital Gains and Losses - Assets Held One ear or. Lose
(a) 0 escrip l ion of propoMy (b) Dale (c)Dalc 1100 I'MIGaPfice (a)COaIm O)Gain Pr(Iwa) .'j. ;ii.i:en,• p: ';•.
(Example; 1000h. %YY COJ ac°ulretl 1Me., pay. Yr.) (seepa??O.G) blhn DSels Eubfrtm (e)lrom ldl ?`. ?y' .'!:+
t SNIO.,Gey, Yr) Itieva?B D•%`:
200 sh-Rita Ai Carr 5/161001 11590
i5Q sh-T4 C
Com 1
1
6/021001 .
5,540
0 )fie .i1,0 T
5,540:
?
100 ah-Titan C x Com 6/06/00 3,896 0 3,B9E; a gi
100 sh-AT & T orp
4/26/001
6/01/00
2,891
2,95DI
-53V'3
hotels, d on S e cDlumne (d) and t0. cntsr ` 21 1.3,91A A yin M,!;u. y;
t °t?'? On ??:. 967
he^e and on 8credula D line 2 . , . , ... _ .. F „
A For Paperwork Rsduction Act NOdce, see Form 1040 instruction- 9ohedWe D-1 (.Form 1040) 2000
IM?1155E ?alZ7101
03/26/2002 14:42 FA% 7179018266 ALLIED MTG CORP
20(is
norm 2106- EZ Utrelnbursed Employee Business Expenses oma. No. 154-1461
2000
P rpartmenr of the TrearNrY
ntern., R.v,rf=KOr JQ0f99) 10 Affect] to Form 1040. ....... m- 54A
•u L. ..guy fsa-Les 169-54-7551
You May Use This Form Only If ALL of the FOIIOWIng Apply:
e You are an employee deducting expenses attribulable to your Job.
• You do not get reimbursed by your employer for any expanses (amounts your employer in WE= In bOX 1 Of Your Form IN-2 9'e
not considered reimbursements).
® If you are oWming vehicle expense, you are using the standard msoago rate far 2000.
Caution: Vow can use the standard mileage rate for 2000 only if. (a) you owned the vahld and used the standard mileage
rate for the first YBW YOU placed your vehicle In sarvire, or (b) YOU leased the Wilda and used the standard mileage rate
for the portion of the lease period after 1997.
Figure Your Expenses
1 Vehicle expanse using the standard rleage rate. Complete Part II and multiply line Be by 32-1/2 gents (,325)..... 1
2 Parking fees, foils, and transportation, including vain, bus, etc., that did not involve overnight travel
at commuting to and from work . . ............. . .................., .........l ............. 2
8 Trevd expense while away from home overnight, including lodging, atrplene car rental, 8b.
Do not Include meals and entertainment....... _ ........................... . Ji ...... , ......... , , ... 3
a Business expenses not included on lines 1 through 3. Do not include meals and anterta) theft .. . ............. a
5 Meals and entertainment expenses: $ x 6096 (?0) (Employees subJ+1!Ct to
Department of Transportation (DOT) hours of service thrifts: Multiply meal expenses by 696 (,60)
instead of 50%. For more details, see Instructions.) ................... :..'................. ............ 5
6 'fosat expanse., Add three 1 through 5. Enter here and on fine 20 of Sphedigg A (FOrml 1040), (Fee-basis stab?
cr focal government Officials, qualified performing arrcids, and in7viduafs with drsabilities:?,See the Instructiona for
Slower rules on wren fe enter this amount.) .................. .... i ........ 16 ? _ 2 3 6 9 i
Information an Your Vehicle. Complete this part Only If you are c!aiming veHola expense on line 1.
7 When did you place your vehlole in service far business use? (month, day, year)
e Of the total number or mlles you drove your vehicle during 2000, enter the number of mileis you used your vehicle for:
a Business
b Commuting,
e Other
9 Doyou (or your spouse) have another vehicle available for personal use? ............I ....................................0 Yes ? No
10 Was your vehide availabla for use durng off-duty hours! ........... , . , .Q Yes i] No
11 a Do you have evidence to support your deduction? .....:.................... ......... . ... , .Q Yes Q No
b _ if "Yes," is the evidence wrltten? ................. . .... ..................... .....0 Yes Q No
For paperwork Reduction Act Notice, see back of form. farm 2106-M (200
XFA IFOU553 69130104
09/28/2002 14;49 FAX 7179018288 ALLIED KG CORP Q009
Statement 1
Schedule A, Line a
Other Taxes
Occupation-Spouse ...................... ................ $ 195
Occupation-Taxpayer ........................................ 275
OPT - Spouse ............................................... 10
OPT - Taxpayer ....... ........ ...............
............... 10
Total $ 490
r - - - ------ - -.
- ._AOO...a - _- - - ----------_---
OMBNC.1545 ----^-------_- *?-
a Control number 1 Wages. up%OmM compenaadon 2 Federal income lax eetbrleld
95571.54 20900.68
b Employees idend5cation number 3 5ocal seemly wages 4 Social secondly = wimneld
34-0420310 76200.00 4724.40
d Emplme s socal seuri y camber 5 Mears wages and dpa 6 Medicare tax 40meld
169-54-7551 99314.32 1440.06
c Empbyees name, address, and ZIP code 7 Social secoriy lips
NATIONAL CITY CORPORATION
AGENT - NC'MORTG 310856949 9 miocated lips
4100 W 150TH ST LOC 5134
CLEVELAND,',OH 44135 9 Maence EEC payment
10 Oepardem care benefits 11 Noncualified Pans 12 EanetBa mewded in box
e EmPldy s name, address. and ZIP code 13
KARL L KRUG D 3742.78
4900 CHARLES RD
MECHANICSBURG, PA 17055 14 Omar
15 Baaary Penagn legw Qwwee
emaloy9. Plan top. mnpareedi
16 S19te Employees state I.C. No. 17 Slats wages, tips. ea, -
200O P,A 18380394 99210.82
l
E Wage and Tax 1B $lare ucoma ex 19 Local}y ramp
LL -` Statement 2777.90 MCHNCSBRGB
THIS COPY TO BE FIL ' WITH
OR 20 Local wages, tips etc
101326
82 21 Lace income tax
1013
27
STATE
EMPLOYEES LOCAL . .
u unn nnm ncwmm Mu"Idsu uspamnam Pn ma lreasury-+namai riwenue sand:
?TO?I
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05/28!2002 14:49 FAX 7179018288 ALLIED MTG CORP X010
7 so" m iy Ilpr, 1 Vre , W "Icer Wtrp6Mdbn 2 r I iilbmq N. nilhk.;d
urmW-2 Waae'and Tat Statement' 2®01 92327.78 2292Q
Known name. awfM. end Zp mde
P.E
III
G
Inc
S & Alhemed Ep9, T V-01 W My-nn 4 EEO" "wGg 1. wP,,bld
.
,
,
.
. 80400.00 4884.74
2050 Centex Avenue. aOWpWMI 5MMV0"peeN Apt gNVAgn I"nNW10 -?
Suits 336 92327.7 338.7x'4
Tort Lee, NJ 07024 77 oepemem cue e"mr?s 1l rdwge?kd plans ?ize Eee' ??tcr ewr t2 I
Empb,9c2 n®ma. adlrwe, entl EP eedl 95 emoev ' .'"n' i Oriet in
KARL L. KRUG LTF! 86.18 a
2 N
LOCUST STREET APT 6Empey? m lo9mmp;r4
1 Jl`J4?tl PA-L0, 915.47
.
MC a
d M5 aeaM n
5+4-551 t2d
SHIREMANSTOWN, PA 17011
_f6 p19u PA Emrwey° `?-? 1"'y" `684 to smM r?r?'c ;78 'Tft ti u i 19 tnw m
? mrm? ap .ynue .
__..l_. ... __ -- -- - ------- 5.21
905 :47 ?ActTMI;,
On" ft iww
r
LIABILITIES - Lisa and Karl Krug
Members 1st -Van Loan $ 7,400
Wells Fargo - New 1 st Mortgage
Members 1st -Personal $ 9,550
Mellon Bank - Personal $ 5,090
Firestone $ 226
Discover Card $ 7,216
First USA Credit Card $ 8,054
American General $ 964
Fleet Credit Card $ 4,200
$ 42,700
* This excludes the first mortgage loan that currently exists on the marital
residence, 4900 Charles Road, Mechanicsburg, PA.
Exhibit "D"
Dynamic Appraisals Inc.
"Specializing in Residential Real Estate Appraisals"
Residential Appraisal Report
Of
Single Family Residence
4900 CHARLES ROAD
MECHANIC'SBURG, PA 17055
For
ACCUBA C MORTGAGE
5115 E. TRINDLE ROAD
MECHANICSBURG, PA 17055
As of
NOVEMBER 29, 1999
Exhibit "B" f
Dynamic Appraisals Inc.
Serving Central Pennsylvania
TUESDAY, NOVEMBER 30, 1999
APPRAISAL PROCESSING
ACCUBANC MORTGAGE
5115 E. TRINDLE ROAD
MECHANICSBURG, PA 17055
In Reference To:
4900 CHARLES ROAD
MECHANICSBURG, PA 17055
Dear Lender:
In accordance with your request, I have completed an appraisal of the real
estate described above. A complete and thorough personal inspection of
the property has been performed. The attached report was prepared to
estimate the market value of the fee simple interest in the subject property.
A full legal description will be found herein.
In my opinion, the estimated market value of the property as of NOVEMBER 29, 1999
is:
ONE HUNDRED AND TWENTY THOUSAND DOLLARS
$120,000
The attached report contains the description,, analysis and supportive data
for the conclusion and final estimate of value, together with descriptive
photographs.
Respectfully submitted,
()'?aok
Daniel A. Hoffman, RL-001638-L
Certified Residential Appraiser
DYNAMIC APPRAISALS, INC.
Pr_Werty Address _ 490' ARLES ROAD Cay_ MECH,_ SBURG State _ PA Zip Code 17(
-- ----- - -
Le alpescri tionSEEATTACHEV vEED 34N-718 - ...- -----""---
--g•----p - E -- _ CountY_ CUMBERLAND
Assessor's Parcel No , - - 10-22-0527-097 Tax Year 1999 RE. Taxes $ 1469 APP Assessmants$
Name DELBROOKMANOR Map Reference SEEAPN Census Tract
FI Dale of Safe N/A Description and $ amount of loan chames/concessions to be pald by seller
CCUBANC MORTGAGE Address 5115 E. TRINDLE ROAD, MECHANICSBURG, PA 17055
DANIEL A. HOFFMAN Address 5001 CARLISLE PIKE. MECHANICSBURG. PA-170.9-5--
Location [] Urban LX.] Suburban
[ Rural
Predominant
Single family housing
Present land use %
Land use change
Built
Built up [_] Over 75% [9125-75% [ _ Under 25%
_I occupancy $(Oo) (yrel One family
95 [X] No( likely [
] Likely
Growth rate ] - ]Rapid X Stable J_
_ I Slow 1 X] Owner 5 5 Low WV -
2-4 family _
I In process :
I
Pro en values X increasing Stable ]Declining Tenant 200+ High 60+ _
Multi-family _
To:
Demand/supply ? Shortage LX I In balance ? Over supply [X] Vacant (0-5%) _
I Predominant , ;- _ _
Commercial 5
Marketing time Fl Under3mos. X 3-6 mos. over 6mos, vacant(overei) 100-1401_NEW-40
Note: race and the racial composition of the neighborhood are not appraisal factors.
Neighborhood boundaries and characteristics SEE OUTLINE ON MAP ADDENDUM. COMMERCIAL USE IN _ THE AREA IS LIMITED TO THE
TYPE TYPICALLY FOUND AND DESIRED ALONG MAIN ROADS IN SUCH AREAS.
Factors that affect the marketability of the properties in the neighborhood (proximity to employment and amenities, employment stability, appeal to market, etc.): ?.
THE SUBJECT IS LOCATED IN A PREDOMINANTLY RESIDENTIAL AREA AMONG, PROPERTIES OF SIMILAR STYLE AND MARKET
• APPEAL THIS AREA IS CONVENIENTLY LOCATED IN RESPECT TO SCHOOLS, SHOPPING, EMPLOYMENT, AND TRANSPORTATION I
- ACCESS HOMES IN THE NEIGHBORHOOD ARE OCCUPIED,AND APPEAR TO BE WELL MAINTAINED. THIS AREA PROVIDES
-
REASONABLE SAFETY AND SECURITY COVERAGE.
• I.
Markel conditions In the subject neighborhood (including support for the above conclusions related to the trend of property values, demand/supply, and marketing
time -- such as data on competitive properties for sale In the neighborhood, description of the prevalence of sales and financing concessions, etc.):
THE SUBJECT IS LOCATED IN HAMPDEN TOWNSHIP. IT PROVIDES AN AVERAGE ENVIRONMENT FOR THE HOUSE BEING APPRAISER
-
THERE
HERE ARE NO KNOWN FACTORS THAT WILL NEGATIVELY AFFECT THE MARKETABILITY OF THE HOUSE. ALL OF THE ITEMS IN THE
NEIGHBORHOOD RATING GRID ARE RATED GOOD OR A
ERAGE. THE PUBLIC SCHOOLS, PARKS, VIEWS AND NOISE LEVEL ARE
V
TYPICAL FOR THIS TYPE OF
NEIGHBORHOOD,
THIS IS
A FAIRLY ACTIVE MARKET WITH NO SPECIAL FINANCING
LOAN DIS000NTS
,
_
_
,
,
OR OTHER CONCESSIONS PREVALENT.
Project Information for PUDs (If applicable -- i
thdeveloper/builder in control of the Home Owner's Association (HOA)7 „-? es _-, No
Approximate total number of units in the subject N / A Approximate total number of units for sale in the subject project
N / A
project
• Describe common elements and recreational facilities: N /A
?.
Dimensions 65 X 120_____ SLIGHTLY SLOPING _
Site area AC _Corner Lot [J'.Yes I X] No Size AVERAGE OF AREA
Specific zoning classification and description RESIDENTIAL _ Shape RECTANGULAR i
Zoning compliance MX] Legal ? Legal nonconforming (Grandfathered use) ] Illegal L ] No Zoning Drainage APPEARS ADEQUATE
Highest & best use as improved_[X] Present use [_] Other use (explain) View AVERAGE
Utilities Public Other Off-site Improvements Type Public Private Landscaping AVERAGE_
Electricity ] Street ASPHALT - _ _ [X] [] Driveway Surface ASP
tHALT
-- - -
Gas Curb/gutter CONCRETE
LX] L_] Apparent easements NONE APPARENT
_
Water Sidewalk CONCRETE ]_X] [J FEMA Special Flood Hazard Area ?Yes [X] No
Sanitary sewer (X] Street lights MERCURY VAPOR { X ] I FEMA Zone X Map Date 0.3 (0 2 (9 3_ j
Slormsewer LX] Alley NONE [J L]- FEMA Map No. 420360 I
Comments (apparent adverse easements, encroachments, special assessments, slide areas, illegal or legal nonconforming zoning use, etc.): THE SIZE,
SHAPE AND LANDSCAPING OF THIS SITE IS TYPICAL OF SITES IN THIS NEIGHBORHOOD. NO APPARENT ADVERSE EASEMENTS,
ENCROACHMENTS, SPECIAL ASSESSMENTS, SLIDE AREAS, ETC. NEGATI'VELYAFFECT THE VALUE.
GENERAL DESCRIPTION EXTERIOR DESCRIPTION FOUNDATION ? BASEMENT INSULATION
No. of Units 1 Foundation CONC BLK Slab NO Area Sq. Ft. 1,1 44 Roof L]
r No. of Stories 2 Exterior Walls ALUM,BRICK Crawl Space ND- % Finished Ceiling _ __ ?
Type (Det./Att.) DETACHED Roof Surfaces COMP SHING
- - - Basement FULL
--- Ceiling DRYWALL Walls ?
- -
.
Design (Style) 6f _LEVEL Gutters 8 Dwnspts. METAL Sump Pump N? _ Walls DRYWALL Floor [
]
Existing/Proposed EXISTING Window Type DBLHUNG Dampness NO EVIDENCE Floor CARPET _
None ]
- Age (Yrs.) 33 Storm/Screens YES Settlement NO EVIDENCE Outside Entry YES- , Unknown
Effective Age rs. -7 Manufactured House ND infestation NO EVIDENCE
• ROOMS Foyer Living Dining Kitchepi I Den Family Rm. Rec_
Rm_ Bedrooms .- P -Baths __Laundry _ Other Are_a_Sq. Ft_
Basement __ _ _ _
... _
, 1.00 1 __1r144
• Level 1 1 1 AREA 1__ I
-
- _3
- 1.00
- 1 , 218
Level 2
-
--
---
--
T
-
--
----
---
--.-_..-
Finished ar ---
ea above ---
grade cont ----
ains: 5 -----._..._.
- Rooms; - -------.
3
Bedrooms
; 1.0 -----._
0 Bath _._...---'
s ; 1 ---._-
, 21 8 S ..------
ware Feel -
of Gross Living Area
INTERIOR Materlats(Condltion HEATING KITCHEN EQUIP, ATTIC AMENITIES CAR STORAGE
• Floors CARPET,PHW/AVG Type BB Refrigerator P None Fireplaces) 0 W/S X None
Walls DRYWALL/AVG Fuel ELECT Range/Oven [ X) Stairs ]J Patio [ J Garage 1 9 of cars
TrimlFinish WOOD/AVG Condition AVG Disposal L_] Drop Siak [X] Deck CVDIAMD X Attached
VINYL/AVG
Bath Floor COOLING Dishwasher [X] Scuttle U Porch
__
Detached ___-
_
_
Bath Wainscot FIBERGLASS/AVG Central ND Fan/Hood LX] Floor [-] Fence Built-In YES
_
Doors WOOD)AVG Other Nc E Microwave [P] Heated [J Pool [_] Carport
Condition N/A Washer/Dr er P Finished Driveway ASPH
Additional features (special energy efficient items, etc.): SEE COMMENT ADDENDUM _,-
• Condition of the improvements, depreciation (physical, functional, and external), repairs needed, quality of construction, remodeling/additions, etc.: NO FORMS
_
OF FUNCTIONAL OR EXTERNAL OBSOLESCENCE WAS NOTED DURING THE INSPECTION. NO PHYSICAL DEPRECIATION WAS
OBSERVED AT THE TIME OF THE INSPECTION. _
Adverse environmental conditions (such as, but not limited to, hazardous wastes, toxic substances, etc.) present in the improvements, on the site, or in the
immediate vicinity of the subject property.: NO KNOWN OR OBSERVED_ADVERSE ENVIRONMENTAL CONDITIONS WERE NOTED AT THE TIME OF
THE INSPECTION FOR THIS APPRAISAL.
Freddie Mac Form 70 6.93 MacAppraiserTM Real Estate Appraisal Software by Bradford and Robbins (aoe) e22-ar21. F .,,,i,& ,.,__ , ?,,,, ,,,... i _ -,
j- I,
DYNAMIC APPRAISALS, INC.
vafaanenectlon UNIFORM RESIDENTIAL APPRAl04L REPORT Fite No. 993327
ESTIg4AYED SITE VALUE _ $__ - 25,000 Con is on Cost Approach (such as, source of cost estimate,
• ESTIMATED REPRODUCTION COST-NEW-ur IMPROVEMENTS; site value, square foot calculation and for HUD, VA and FmHA, the
Dwelling _ 1 , 21 8_Sq. FL @ $ _58.45 =$ _ 71,192 estimated remaining economic life of the property):
BSMT, 1 144 Sq. FL @ $ _ _29.44 26,815
THE MARSHALL AND SWIFT RESIDENTIAL COST
EXTERIOR FEATURES/BUILT-INS _12,100 HANDBOOK WAS USED AS AN AID IN COMPUTING THE
Garage/Carport _ N /A Sq. FL @ $ -N/A y = p COST APPROACH UTILIZING AVERAGE QUALITY
Total Estimated Cost New = $ 110 107_ .-
THOMAS M_VOGELSONG PROVIDED SIGNIFICANT
Less Physical 10 Functional External
Depreciation
1 01 1
1 PROFESSIONAL ASSISTANCE IN ONE OR MORE OF THE
!
_-_____ $____ _ 11. 01
. 1 FOLLOWING AREAS, SUBJECT/COMP DATA RESEARCH,
_
Depreciated Value of Improvements = $ _ 99,096 VISUAL INSPECTIONS, URAR PREPARATION AN
D/
O
R
_
_
_
_
"As Is" Value of Site improvements = $ 2, 500 OVERALL APPRAISAL REVIEW.
INDICATED VALUE BY COST APPROACH =$ 126,596 Est Remain. Econ. Life: 40-50 rs
ITEM SUBJECT COMPARABLE N0. 1 COMPARABLE NO. 2 COMPARABLE NO. 3
4900 CHARLES ROAD 4 DELBROOK COURT 9 REDWOOD COURT 4801 BRIAN ROAD
Address MECHANICSBURG MECHANICSBURG CAMP HILL MECHANICSBURG
Prownft ty c,Subject
2 MI ?-
1.7 MI 2 MI
Sales Price $ RE 'uns
117 490 _
G 1 15 000 3 $ 121 900
Price/Gross Liv. Area $
$ 99:83 1 a $ 116.16 G? £ Q 111
69
.__-
Data and/or INSPECTION) MLS .
INSPECTION MILS
Verification Source
---- -`--
-
VALUE ADJUSTMENTS DESCRIPTION -DESCRIPTION rO$ Adjustment ------
DESCRIPTION
+O$ Adjustment
DESCRIPTION )$A d usIT rit _
Sales or Financing
,31
71 I 1? ?? CONVENTIONAL __
_
CONVENTIONAL CONVENTIONAL
Concessions NO EFFECT NO EFFECT NO EFFECT
- of 6alelTlme
05)27199
---111 z 02/26/99 05/27199_-_
Location ---___-- ---- AVERAGE .---AVERAGE .--.
--..._
....-AVERAGE- -AVERAGE
View
18 AC
BI-LEVEL
8E
Above Grade Tatat Idrms, .-Baths- Total -3Ms Baths,-._ Total edtms baths-.
Room Count 5 3 1.00 7 3 1.00 - 5 2 _1.00
Gross LivinArea- __1,218 S% EL 1,176 Sq..Ft 0 990Sq._FI
Basement & Finished FULL FULL FULL
Rooms Below Grade FR,RR,FB BR,FB +4,099 FR,DEN,2BR,FB
Functional Utility___ AVERAGE AVERAGE -_-AVERAGE
Heating/Cooling __ EBBINONE _ GFWAICA __ -2,000 EBBIWU_
Energy EtilcienI Items STORM UNITS SIMILAR SIMILAR
Garage/Carport-- - 1C B -IN GAR 1C GARAGE 2C ATT GAR
Porch, Patio, Deck, CVD DECK PATIO,DECK PATIO,C-DECK
Fireplace(s)_e(c__ _ WOODSTOVE 1 FIREPLACE 500 1 FIREPLACE
Net Ad) (total)_..-.._..
Adjusted Sales Price
3,000 _ 1-.1.J.+_._..L..L_
Comments on Sales Comparison (including the subject property's compatibility to the neighborhood, etc.):
122,660
AND DATE_SUTILIZED_ARE SETTLEMENT DATES AND NOT CONTRACT DATES. ALL CO_MPARABLES ARE CONSIDERED EQUAL
INDICATOR3-617-VALUE AND WEIGHED EQUALLY IN THE FINAL RECONCILIATION. SLIGHTLY WIDER fiANGES THAN IDEAL WER
REQUIRED TO BE UTILIZED TO LOCATE SUITA13LE_C_ OMPARABLE- S, THE BEST AVAILABLE COMPARABLES WERE SELECTED At
USED FOR THIS APPRAISAL.
ITEM SUBJECT COMPARABLE NO. COMPARABLE NO.2_ COMPARABLE NO.3
Date, Price and Data NO TRANSFERS NO TRANSFERS NO TRANSFERS NO TRANSFERS
Source, for prior sales WITHIN WITHIN WITHIN WITHIN
within earofa praisai _ONEYEAR ONE-YEAR--____ _ ONEYEAR ONEYEAR
Analysis of any current agreement of sale, option, or listing of the subject property and analysis of any prior sales of subject and comparables vAhh one year of the date of appraisal.
THIS IS A COMPLETE APPRAISAL-SUMMARY REPORT,.-
INDICATED VALUE BY SALES COMPARISON APPROACH $ __ 1 2D, 0_00
INDICATED VALUE BY INCOME APPROACH (If Applicable) Estimated Market Rent $ N / A /Mo.x Gross Rent Multiplier _ =$ N / A
This appraisal is made LXI "as is" 1,1.1 subject to the repairs, alterations, inspections or conditions listed below I _ _ I, subject to completion per plans and specifications
Conditions of Appraisal: SUBJEC+ IS APPRAISED IN ITS PRESENT CONDITION AS OF THE TIME OF INSPECTION.
Final Reconciliation: THE SALES COMPARISON APPROACH IS THE BEST APPROACH FOR THIS TYPE OF PROPERTY AND-THE-ONE FOR
WHICH THE MOST RELIABLE DATA IS AVAILABLE. THE COST APPROACH SUPPORTS SALES APPROACH. T_HE INCOME APPROACH
IS N/A SINCE BUYERS ARE MORE INTERESTED IN AMENITIES THAN INCOME POTENTIAL
The purpose of this appraisal is to estimate the market value of the real property that is subject to this report, based on the above conditions and the certification, contingent
and limiting conditions, and market value definition that are staled in the attached Freddie Mac Form 439(Fannie Mae Form 1004B (Revised 6 - 9 3 ).
I(WE) ESTIMATE THE MARKET VALUE, AS DEFINED, OF THE REAL PROPERTY THAT IS THE SUBJECT OF THIS REPORT, AS OF NOVEMB__ER_29_ ,__1_9_99_
(WHICH IS THE DAT F INSPECTION AND THE EFFECTIVE DATE OF THIS REPORT) TO BE $ 1120,000-
APPRAISER: (n` SUPERVISORY APPRAISER (ONLY IF REQUIRED):
Signature ?.. GAk ...... --'---__---------. Signature [_]Did E]Did Not
Name DANIEL A_HOFFMAN Name _-___ Inspect Properly
Date Report Signed -NOVEMBER 30, 1999 Date Report
State Certification a RL-001638-L_ ^ State PA State Certification tt State
Or State License a State Or Stale License q Stale
BI-LEVEL
3-7E
+2.500 7 3 2
FULL
SIMILAR
0
1 ,000 C GARAGE
-500 _
___
f1AT10
+1,5
______500 1 FIREPLACE _?5
4,530 X + _760
Freddie Mac Form 70 6-93 MacAppraiserTM Real Estate Appraisal Software by Bradford and Robbins (600) 6228727. Fannie Mae Form 1004 (6-93)
COMMENT ADDENDUM File No. 993327
Property Address 4900 CHARLES ROAD
city-- MECHANICSBURG_ countyCUMBERLAND State PA Zip Code 17055
Lender/Client ACCUBANC MORTGAGE Address 5115 E. TRINDLE ROAD, MECHANICS BURG, PA 17055
Additional Features
THE SUBJECT IS A TYPICAL BI-LEVEL HOUSE FOR THIS AREA WITH A NORMAL AND ACCEPTED
FLOOR PLAN FOR THIS TYPE OF HOME. MAIN ENTRY LEADS TO THE FOYER WHICH HAS A
HARDWOOD FLOOR. THE LIVING ROOM IS TO THE FRONT RIGHT WITH A CEILING FAN AND
PICTURE WINDOW. THE KITCHEN TO THE REAR INCLUDES A PARQUET FLOOR, DINING AREA,
CEILING FAN, LOWER LAZY SUSAN, SMOOTH TOP RANGE, AND DOOR TO THE COVERED REAR
DECK. BOTH OF THE FRONT BEDROOMS OFFER A SLIDING DOOR CLOSET AND CEILING FAN
WHILE THE REAR BEDROOM HAS TWO BI-FOLD DOOR CLOSETS. THE BASEMENT INCLUDES A
FAMILY ROOM WITH WOOD STOVE AS WELL AS A REC ROOM, BATHROOM, AND LAUNDRY ROOM.
THERE IS A ONE CAR BUILT-IN GARAGE AND ELECTRIC HOT WATER HEATER. THE PRECEDING
ITEMS MENTIONED AS ADDITIONAL FEATURES DO NOT WARRANT INDIVIDUAL ADJUSTMENTS
IN THE COST APPROACH OR SALES COMPARISON ANALYSIS. THEY WERE WORTHY OF MENTION
BECAUSE THEY DO INDEED AFFECT THE COST OF CONSTRUCTION, QUALITY OF CONSTRUCTION,
APPEAL, UTILITY, AND MARKETABILITY OF THE PROPERTY. IF ANY ADJUSTMENTS ARE
REQUIRED THEY WILL BE TAKEN IN THESE CATEGORIES.
MacAppralse0- Real Estate Appraisal So(tware by Bradford and Robbins (800) 622-8727. Page 1 01 1
Borrower 'KRUG SUBJECT PHOTO ADDENf- A FUaNo. __? 993327
F gperty Address_ _ 4900 CHARLES ROAD _
clly_ MECHANICSBURG county_ CUMBERLAND State PA _ ZipCode__ _ 17055
Lender/Client ACCUBANC MORTGAGE Address 5115 E. TRINDLE ROAD, MECHANICSBURG, PA 17055
RONT OF
UBJECT PROPERTY
adress
4900 CHARLES ROAD
MECHANICSBURG
ppr. Date NOVEMBER 29, 1
ppr. Value 120,000
Its .18 AC
1" AVERAGE
sgn/Ap'l BI-LEVEL
onsuDlty ALUM,BRICK
go 33A/3-7E
qFt 1,218
Dial Rms 5
edrooms 3
Dins 1.00
asememl FULL
garage 1C B-IN GAR
(replace WOODSTOVE
GEAR OF
>UBJECT PROPERTY
STREET SCENE
SKETCH ADDENDUM Re No. 99J327
Lender/Client ACCUBANC MORTGAGE Address 5115 E. TRINDLE ROAD, MECHANICSBURG, PA 17055
MacAppraiser'M Rea{ Estate Appraisal Software by Bradford and Robbins 18(10) 8zz-erzr.
W +...+Y+ryYYlYW11eeHYWlal???ll ,..?_u.
Borrower 'OMPARABLES 1-2-3 PHOTO AD NDUM File No. 993327
'KRUG
propeny
_gadress 4900 CHARLES ROAD
qy MECHANICSBURG County _ CUMBERLAND State PA Zip Code 17055
LenderlChem ACCUBANCMORTGAGE Address 5115E TRINDLE ROAD, MECHANICSBURG?PA 117055
:OMPARABLE SALE #1
ddress
4 DELBROOK COURT
MECHANICSBURG
ale Dale 05127199
alevalue 117,400
its .20 AC-CDS
lew AVERAGE
sgn/Apl BI-LEVEL
onsvolty ALM,BRK,STCO
go 29A/4-BE
qFl 1,176
otal pros 7
edroams 3
stirs 1 .00
asememl FULL
wage 1C GARAGE
!replace 1 FIREPLACE
:OMPARABLE SALE #2
ldaress
9 REDWOOD COURT
CAMP HILL
Sate Dale 02/26/99
Sale Value 115,000
'its .23 AC
/iew AVERAGE
)sgn/A{il BI-LEVEL
;nnsvouy ALUM,BRICK
age 24A/4.8E
SgFt 990
focal pans 5
3edrooms 2
Baths 1.00
Basement FULL
Garage 2C ATT GAR
Fireplace 1 FIREPLACE
COMPARABLE SALE #3
Address
4801 BRIAN ROAD
MECHANICSBURG
Sato Date 05127199
Sale Value 121 , 900
$Ile .21 AC
View AVERAGE
OsgNAVI BI-LEVEL
Consvolty ALUM,BRICK
Age 3-7E
Sq FI 1 , 0 92
Total Rms 7
Bedrooms 3
Baths 2.00
Basement FULL
Garage 1CGARAGE
Fireplace 1 FIREPLACE
LOCATION MAP ADDEt. JM PIIeNo. 993327
Lender/Client ACCUBANC MORTGAGE Address 5115 E.TTRINDLE ROAD MECHANIGSBURG, PA 17055
6EFINITION OF MAR , P VALUE: The most probable price which a properly should bring in a competitive and
open market under all conditions requisite to a fair sale, the buyer and seller, each acting prudently, knowledgeably and
assuming the price is not affected by unduc stllllulus. Implicit ill this defltlllioll is the consummation of a sale as of a
specified date and (lie passing of title from seller to buyer under conditions whereby: (1) buyer and seller are typically
motivated; (2) both parties are well informed or well advised; and each acting in what he considers his own best interest;
(3) a reasonable time is allowed for exposure in the open market; (4) payment is made in terms of cash in U. S. dollars
or in terns of financial arrangements comparable thereto; and (5) the price represents the normal consideration for the
property sold unaffected by special or creative financing or sales concessions* granted by anyone associated with the sale.
*Adjustments to the compatibles must be made for special or creative financing or sales concessions. No adjustments
are necessary for those costs which are normally paid by sellers as a result of tradition or law in a market; these costs
are readily identifiable since the seller pays these costs in virtually all sales transactions. Special or creative financing
adjustments can be made to the comparable property by comparisons to financing terms offered by a third party
inslihnional lender [fiat is not already involved in the properly or transaction. Any adjustment should not be calculated
on a mechanical dollar for dollar cost of the financing or concession but the dollar amount of any adjustment should
approximate the market's reaction to the financing or concessions based on the appraiser's judgment.
STATEMENT OF LIMITING CONDITIONS AND APPRAISER'S CERTIFICATION
CONTINGENT AND LIMITING CONDITIONS: The appraiser's certification [bat appears in the appraisal report is
subject to the following conditions:
1. The appraiser will not be responsible for matters of a legal nature that affect either the property being appraised or
life title (o it. The appraiser assumes that the title is good and marketable and, (berefore, will not render any opinions
about the title. Tire property is appraised on the basis of it being under responsible ownership.
2. The appraiser has provided a sketch in the appraisal report to show approximate dimensions of the improvements
and the sketch is included only to assist the reader of the report in visualizing the property and understanding the
appraiser's determination of its size.
3. The appraiser has examined the available flood maps that are provided by the Federal Emergency Management Agency
(or other data sources) and has noted in the appraisal report whether the subject site is located in an identified Special
Flood Hazard Area. Because the appraiser is not a surveyor, he or she makes no guarantees, express or implied, regarding
this determination.
4. The appraiser will not give testimony or appear in court because he or she made an appraisal of the property in question,
unless specific arrangements to do so have been made beforehand.
5. The appraiser has estimated the value of the land in the cost approach a( its highest and best use and therimprovements
at their contributory value. These separate valuations of the lend and improvements must [lot be []sell ill conjunction will)
any other appraisal and are invalid if Ihcy are so used.
6. The appraiser has noted in the appraisal report any adverse conditions (such as, needed repairs, depreciation, the presence
of hazard wastes, toxic substances, etc.) observed during the inspection of the subject property or that he or she became
aware of during the normal research involved in performing the appraisal. Unless otherwise stated in the appraisal report,
the appraiser has no knowledge of any hidden or unapparen[ conditions, of the property or adverse environmental conditions
(including the presence of hazardous wastes, toxic substances, etc.) that would make the property more or less valuable,
and has assumed that there are no such conditions and makes no guarantees or warranties, express or implied, regarding
the condition of the property. The appraiser will not be responsible for any such conditions that do exist or for any
engineering or testing that might be required to discover whether such conditions exist. Because the appraiser is not an expert
in the field of environmental hazards, the appraisal report must not be considered as an environmental assessment of
the property.
7. The appraiser obtained the information, estimates, and opinions that were expressed in the appraisal report from sources
that he or she considers to be reliable and believes them to be true and correct. The appraiser does not assume responsibility
for the accuracy of such items that were furnished by other parties.
8. Tile appraiser will not disclose the contents of the appraisal reporli, except as provided for in the Uniform Standards of
Professional Appraisal Practice.
9. The appraiser has (lased his or her appraisal report and valuation conclusion for an appraisal that is subject to satisfactory
completion, repairs, r alterations on life assumption that completion of the improvements will be performed in a
workmanlike manner.
10. The appraiser must provide his or her prior written consent before the lender/client specified in the appraisal report
can distribute the appraisal report (including conclusions about the property value, the appraiser's identity and professional
designations, and references to any professional appraisal organizations or the firm with which the appraiser is associated)
to anyone other than the borrower; the mortgagee or its successors and assigns; the mortgage insurer; consultants;
professional appraisal organizations; any state or federally approved financial institution; or any department, agency,
or instrumentality of the United Stites or any stale or the District of Columbia; except flint the lender/client may distribute
the property description section of the report only to data collection or reporting service(s) without having to obtain the
appraiser's prior written consent. The appraiser's written consent and approval inns( also be obtained before life appraisal
can be conveyed by anyone to lire public through advertising, public relations, news, sales, or other media.
Freddie Mac Form 439 (6-93) MacAppraiser'" Real Estate Appraisal Software by Bradford and Robbins (600) 622-6727. Fannie Mae Form 10048 (6-93)
APPRAISER'S CERTIFICATION: The Appraiser certifies and agrees that:
1. I have researched the subject market area and have selected a minimum of three recent sales of properties most similar
and proximate to the subject property for consideration in llte sales comparison analysis and have made a dollar adjustment
when appropriate to reflect the market reaction to those items of significant variation. If a significant item in a comparable
property is superior to, or more favorable than, lire subject property, I have made a negative adjustment to reduce the
adjusted sales price of the comparable and, if a significant item in a comparable property is inferior to, or less favorable
than the subject property, l have made a positive adjustment to increase the adjusted sales price of the comparable.
2. 1 have taken into consideration the factors that have an impact on value in my development of the estimate of market
value in the appraisal report. I have not knowingly withheld any significant information from the appraisal report and 1
believe, to the best of my knowledge, that all statements and information in the appraisal report are true and correct.
3. 1 slated in the appraisal report only my own personal, unbiased, and professional analysis, opinions, and conclusions,
which are subject only to (he contingent and limiting conditions specified in this form.
4. 1 have no present or prospective interest in the property that is the subject to this report, and I have no present or
prospective personal interest or bias with respect to the participants in the transaction. 1 did not base, either partially or
completely, my analysis and/or (he estimate of market value in the appraisal report on the race,color, religion, sex,
handicap, familial status, or national origin of either the prospective owners or occupants of the subject properly or of the
present owners or occupants of the properties in the vicinity of the subject property.
5. 1 have no present or contemplated future interest in the subject property, and neither my current or future employment
nor my compensation for performing this appraisal is contingent on [lie appraised value of the property.
6. 1 was not required to report a predetermined value or direction in value that favors the cause of the client or any
related party, [lie amount of the value estimate, the attainment of a specific result, or (lie occurrence of a subsequent event
in order to receive my compensation and/or employment for performing the appraisal. 1 did not base the appraisal report
on a requested minimum valuation, a specific valuation, or the need to approve a specific mortgage loan.
7. 1 performed (his appraisal in conformity with (lie Uniform Standards of Professional Appraisal Practice that were
adopted and promulgated by the Appraisal Standards Board of The Appraisal Foundation and that were in place as of the
effective date of this appraisal, with the exception of lire departure provision of those Standards, which does not apply.
i acknowledge that an estimate of a reasonable time for exposure in the open market is a condition in the definition of
market value and the estimate I developed is consistent with the marketing time noted in the neighborhood section of this
report, unless I have otherwise stated in the reconciliation section.
8. 1 have personally inspected the interior and exterior areas of (he subject property and the exterior of all properties
listed as comparables in the appraisal report. I further certify that 1 hav noted any apparent or known adverse conditions
in the subject improvements, on the subject site, or on any site within the immediate vicinity of the subject property of
which I am aware and have made adjustments for these adverse condiitions in my analysis of the property value to lire
extent that I had market evidence to support them. 1 have also connnclr(cd about the effect of the adverse conditions on
the marketability of the subject property.
9. 1 personally prepared all conclusions and opinions about the real estate that were set forth in the appraisal report. If i
relied on significant professional assistance from any individual or individuals in the performance of the appraisal or the
preparation of the appraisal report, I have named such individual(s) and disclosed the specific tasks performed by them
in the reconciliation section of this appraisal report. 1 certify that any individual so named is qualified to perform the tasks.
I have not authorized anyone to make a change to any item in the report; !therefore, if an unauthorized change is made to the
appraisal report, I will take no responsibility for it.
SUPERVISORY APPRAISER'S CERTIFICATION: If a supervisory appraiser signed the appraiser report, he or she
certifies and agrees that: I directly supervise the appraiser who prepared the appraisal report, have reviewed the appraisal
report, agree with the statements and conclusions of the appraiser, agree to be bound by the appraiser's certifications
numbered 4 through 7 above, and am taking full responsibility for the appraisal and the appraisal report.
ADDRESS OF PROPERTY APPRAISED: _`-4900 CHARLES ROAD; MECHANICSBURG, PA 17055
APPRAISER:
Signature: GSC?
Name: _ DANIEL A. HOFFMAN
Date Signed: __ _NOVEMBER 30, 1999
Slate Certification #: RL-001.638__1
or State License #: _
State: PA -?--
Expiration Date of Certification or License:_ 06/30/01
SUPERVISORY APPRAISER (only if required)
Signature:
Name:
Date
State Certification M
or State License #:
State:
Expiration Date of Certification or License:
[J Did [__] Did Not Inspect Property
Freddie Mae Form 439 6-93 MacAppraised° Real Estate Appraisal Software by Bradford and Robbins (6001622-8727. Fannie Mae Farm 100,48 6-93
ta1-Cr-Wa«anty oaad- t'd rwln-}.<i Ispy-Drub{. Shoff
Hanrr Hall. Inc., Indiana, Pa.
0
00 ;Pi. "14
ig H1
;Deeb'
MADE THE ?(; day of J`-r
in the year
of our Lord one thousand nine hundred ninety ( 1990)
UETVYEEN
KAREN E. WAY, a single woman, of Jamestown,
Pennsylvania,
Orancor
and
KARL L. KRUG and LISA KRUG, his wife, of
tlechaniesbur'g, Cumberland County, Pennsylvania,
Grantee s:
IYITNESSETH, that in consideration of EIGHTY THREE THOUSAND FIVE HUNDRED----
($83,500.00) AND NO/100 --------------------------------------- Dollars,
in hand paid, the receipt whereof is hereby acknowledged, the said grantor does hereby grant
and convey to the said grantees,
ALL THAT CERTAIN tract or parcel of land and premises, situate,
lying and being in the Township of ilampden in the County of
Cumberland and Commonwealth of Pennsylvania, more particularly
described as follows:
BEGINNING at a point on the southerly side of Charles Road, said
point of beginning being at the dividing line between Lots Nos.
26 and 27, flock "B", on the hereinafter mentioned Plan of Lots;
thence southwardl.y along said dividing line, a distance of one .
hundred twenty (120) feet to a point at lands now or formerly of
P. d S. Develcpment, Inc.; thence westwardly along same, a
distance of sixty-five (.5) feet to a point; thence northwardly
alnng I, Ii.ne running; aL right angles to Charles Road, a distance
of one hundred twenty (120) feel, to a point on the southerly aide
of Charles Road; Lhence castwardiy along; same., 11 distance of sixty-
five (65) feet to the point and place of BB;GINNING,
BEING Lot No. 26, Block "B" on plan No. 3 of DelBrook Planor,
said Plan being recorded in the Officer of the Recorder of
Deeds in and for Cumberland County in Plan Book 8, Page 11.
BEING the same premises which Jay It. Way and Karen E. Way, formerly
his wife, by their deed dated February 12, 1987, and recorded
February 12, 1987, fit the Office of the Recorder of Deeds, in
and for Cumberland County, in Deed Book 1,1, volume. 32, ['age 675,
granted and conveyed unto Kareu li. Way, a single person, Grantor
herein.
:u
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booH?w"A PACE "rib
Townehlp of 66?vr "" '-l
Cumlx Co, Pa
.J.% Real Estuto lronnln, Tna
t-. rJ '' // Z Z 1
t S An I. C i..r.? lr... q.p
umb. Co. Diet Col, Agt.
/41
School Dist. Curnb. Co. Pa "
t-% RealEsstttila Translu /Tax
D84L.L? - N _., Amt. / z v
rnbVtl Co. Dist Got. A;n J.S
MUL" I-PURPOSE SUPPLEIV 'NTAL ADDENDUM
FOR FEDERALLY RELATED TRANSACTIONS
Borrower/Client MUG 993327
Fropsrty Address 4900 CHARLES ROAD-_ _
city MECHMSICSBURG ----
county -,_CUMBERLAND _stata PA Zip Code 17055
Lender ACCUBANC MORTGAGE _
This Multi-Purpose Supplemental Addendum for Federally Related Transactions was designed to provide the appraiser with a con-
venient way to comply with the current appraisal standards and requirements of the Federal Deposit Insurance Corporation (FDIC),
file Office of the Comptroller of Currency (OCC), The Office of Thrift Supervision (OTS), the Resolution Trust Corporation (RTC)
and (lie Federal Reserve.
This Multi-Purpose Supplement Addendum is for rise with any appraisal Only those
statements which have been checked by fire appraiser apply to the property being appraised.
X RPOSE &FUNCTION OF APPRAISAL
The purpose of file appraisal is to estimate the market value of file subject property as defined herein. The function of the appraisal is to
assist the above-named Lender in evaluating tale subject properly for lending purposes. *]'his is a Federally related transaction.
X MILF APPRAISAL PROCESS
?_X) 'T'he appraisal is based on the infi n ialiotl gathered by the appraiser from public records, other identified sources, inspection of the
subject propert
and nei
hborhood
and selection of com
arable
le
ithi
li
b
t
t
i
l
f th
k
Th
i
y
g
,
p
sa
s w
re su
jec
e
area.
e or
g
source o
e cony
n
mar
na
parables is shown in the Data Source section of the market grid along with the source of confirmation, if available. The original source
is present first. The sources and data are considered reliable. When conflicting information was provided, the source deemed most
reliable has been used: Data believed to be unreliable was not included in the report nor used as a basis for the value conclusion.
(X] The Reproduction Cost is based on MARSHALL AND SWIFT RESIDENTIAL COST HANDBOOK
supplemented by the appraiser's knowledge of the local market.
(
I XI Physical deprecialion is based oil the estimated effective age of the subject property. Functional and/or external depreciation, if
present, is specifically addressed in the appraisal report or other addenda. In estimating the site value, the appraiser has relied on
personal knowledge of the local market.The knowledge is based on prior/or current analysis of site sales and/or abstractions of site
values from sales of improved properties.
[X] The subject property is located in an area of primarily owner-occupied single family residences and the Income Approach is not consi-
dered to be meaningful. For this reason, the Income Approach was not used.
The Estimate(] Market Rent and Gross Rent Multiplier utilized in the Income Approach are based on the appraisers knowledge of file
subject market area. The rental knowledge is based on prior and/or current rate surveys of residential properties. The Gross Rent
Multiplier is based on prior and/or current analysis of prices and market rates for residential properties.
For income producing properties, actual rents, vacancies and expenses have been reported and analyzed. They have been used to pro-
ject future rents, vacancies and expenses.
X SUBJECT PROPERTY OFFERING INFORMATION
According to CENTRAL PENN MULTI LIST SERVICE _..___ (lie subject property:
U has not beets offered for sale in the past 30 days.
is currently offeredfor sale for $ _
? was offered for sale within the past 30 days for
[J Offering information was considered in the final reconciliation of value.
? Offering information was not considered in the final reconciliation of value.
? Offering information was not available. The reasons for unavailability and the steps taken by the appraiser are explained later in
(his addendum.
X SALE HISTORY OF SUBJECT PROPERTY
Accordingto COUNTY RECORDS OFFICE-RECORIDER OFDEED _ the subject property:
U has not transferred in the past twelve months. ? has not transfen•edin the past 36 months.
? has transferred in the past twelve months. ?Iras transferredin (he past 36 months.
(] All prior sales which have occurred in the past months are listed below and reconciled to (he appraised value, either in (he body
of the report or in the addenda.
Date Sales Price Document# Seiler !layer
X FEMA FLOOD HAZARD DATA
[X, Subject property is not located in a FEMA Special Flood Ilazard Area.
Subecl propert iy s located in a FEMA Special Flood Hazard Area. Zone FEMAMairlNue1N
Name or Community
Map Date
__
_ _ __
The community does not participate in the National Flood Insurance Program.
(-1 The community does participate in the National Flood Insurance Program.
If is covered by a regular program.
It is covered b an enter enc program.
rW-70M November 1991 MacAppraiser1P Real Estate Appraisal sonware by Bradford and Hoooina luau) oze-0141. - ^e-
X ,A aaisrr
X?-The snbJectpropcrly tscurFentY riot under contract.
The contract and/or escrow instructions were not available for review. The unavailability of the contract is explained later in the
addenda section.
? The contract and/or escrow instructions were reviewed. The following summarizes the contract:
Contract Dale Amendment Date - Crnalracl Price -Seller--- -- ^-' ---`-
The contract indicated that personal property spas not inchrded in the sale.
[-_f The contract indicated that personal property spas included. It consisted of
Estimated contributory value is $
U Personal property was not included in the final value estimate.
? Personal property was included in the final value estimate.
? The contract indicated na financing concessions or other incentives.
?.The contract indicated the following concessions or incentives:
? if concessions or incentives exist, the comparables were checked for similar concessions and appropriate adjustments were made, if
applicable, so that the final value conclusion is in compliance with the Market Value defined herein.
2-6 months is considered it rcasonabic marketing period for the subject properly based ml MARKETING TIME AS
AVAILABLE FROM CENTRAL PENN MULTI LIST SERVICE.
X ADDITIONAL CERTIFICATION
The Appraiser certifies and agrees that:
(1) Their analyses, opinions and conclusions were developed, and this report was prepared, in conformity with the Uniform Standards of
Professional Appraisal Practice ("USPAP"), and in accordance with the regulations developed by the Lender's Federal Regulatory
Agency as requirei.l by EIRREA, except that file Department provisions of the USPAP do not apply.
(2) Their compensation is not contingent upon the reporting of predetermined value or direction in value that favors the cause of the
client, the amounli,of the value esfimale, the altainmeni of a stipulated result, or the occurrence of a subsequent event.
(3) This appraisal assignment was not based on a requested minimum valuation, a specific valuation, or the approval of a loan.
X ADDITIONAL (ENVIRONMENTAL) LIMITMOCoNDITIoNs
The value estimated is based on the assumption that file property is not negatively affected by the existence of hazardous substances or
detrimental environmental conditions unless otherwise stated in this report.The appraiser is not an expert in the identification of
hazardous substances or detrimental environmental conditions. The appraiser's routine inspection of and inquires about the subject
property did not develop any information that indicated any apparent significant hazardous substances or detrin`enlal environmental
conditions which would affect the property negatively males otherwise stated in this report. It is possible that tests and inspections made
by a qualified hazardous substance and environmental expert would reveal life existence of hazardous substances or detrimental
environmental conditions on or around the properly that would negatively affect its value.
APPRAISER'S SIGNATURE & LICENSEXERTIFICATION
X
Appraiser's Signature - _afC-_____.. Effective Dale 1 1 /29/99,__ _ Dale Prepared 11/30/99 Appraiser's Name (print) DANIEL A_HOFFMAN Phone # ( 717 ) 737_9433
State PA [License [Xj Certification # RL 001638 L TaxiD# 25-1715857
CO-SIGNING APPRAISER'S CERTIFICATION
The co-signing appraiser has personally inspected the subject property, both inside and out, and has made an exterior inspection of all
comparable sales listed in the report. The report was prepared by the appraiser under direct supervision of the co-signing appraiser.
The co-signing appraiser accepts responsibility for the contents of the report including the value conclusion and the limiting condi-
tions, and confirms that the certifications apply fully to the cosigning appraiser.
? the co-signing appraiser has not personally inspected the interior of life subject properly and:
- [ has riot inspecled',thd exterior of the subject properly and all comparable sales listed in (he report.
[ has inspected the exterior of Ilse subject properly and all comparable sales listed in the report.
_J The report was prepared by the appraiser under direct supervision of the co-signing appraiser. The co-signing appraiser accepts
responsibility for the contents of the report, including the value conclusions and the limiting conditions, and confirms that the
certifications apply fully to the co-signing appraiser with the exception of die certification regarding physical inspections. The above
describes the level of inspection performed by the co-signing appraiser.
? The co-signing appraiser's level of inspection, involvement in the appraisal process and certification are covered elsewhere in the
addenda section of this appraisal.
CO-SIGNING APPRAISER'S SIGNATURE & LICENSEXERTIFICATION
Co-Signing
Appraiser's Signature Effective Date Date Prepared
Co-Signing Appraiser's Name (print) Phone #
Stale License Certification if Trainee Tax 1D #
FW-70M November 1991 MacAppraiser'" Real Estate Appraisal Software by Bradford and Robbins (800) 622-8727. Page 2
Dynamic Appraisals, Inc.
"Specializing in Residential Real Estate Appraisals"
Serving Central Pennsylvania
5001 Carlisle Pike • Mechanicsburg, OA 17055 • (717)737-9433
are the qualifications of the appraiser, Daniel A. Hoffman, who performed the
as well as preparing this appraisal report.
I A. Hoffman is of the strong belief that to be one of the best in any profession, requires a
commitment to a continuing education program that keeps the professional abreast of all
les in their industry.
Educational Division of DPS, Inc. Camp Hill, PA
1980 Real Estate Practice
1980 Real Estate Fundamentals
Pennsylvania Real Estate Commission Harrisburg, PA
1980 PA Real Estate Salesperson License
FFR, META University Salt Lake City, UT
1981 Income Producing Property Management
1982 Private Property Management
1984 Single and Multi-Family Investment Analysis
1986 Real Estate Tax Training
1989 Asset Protection - Real Estate Trusts
Academy of Real Estate Studies Philadelphia, PA
3/91 Real Estate Practice
The Institute of Real Estate Studies Camp Hill, PA
5191 Real Estate Fundamentals
Pennsylvania Real Estate Commission Harrisburg, PA
5/91 PA Real Estate Salesperson License
Larry Foote Institute of Real Estate Carlisle, PA
10/91 Appraisal of Residential Property
The Real Estate School Camp Hill, PA
1 1 /91 Narrative Appraisal Report Writing
1 2/91 Standards of Professional Appraisal Practice
Pennsylvania REALTORS Institute
10/92GRI -1
1 1 /9 2 Cost and Income Approaches - RA4
12/92GRI - 2
03/93GRI - 3
The Institute of Real Estate Studies Camp Hill, PA
07/93 Residential Construction
PA Board of Real Estate Appraisers Harrisburg, PA
09/93PA State Certified Residential Appraiser
Pennsylvania REALTORS Institute Harrisburg, PA
09/93RS-203
Cincinnati Board of REALTORS Cincinnati,OH
09/93CRB-421,422,423
Pennsylvania REALTORS Institute Harrisburg, PA
03/94RS-205
06/94RS-204
Pennsylvania Real Estate Commission Harrisburg, PA
08/94 PA Real Estate Brokers License
Dynamic
ppraisals, Inc.
"Specializing in Residential Real Estate Appraisals"
Serving Central Pennsylvania
5001 Carlisle Pike • Mechanicsburg, PA 17055 • (717)737-9433
Allgood Appraisal Training New Cumberland, PA
1 1 /94 FHA Appraisal Training
Harrisburg Realtors Institute Camp Hill, PA
04/95 USPAP-Mandatory
Polley Association Newtown Square, PA
06/95 Environmental Appraisal Issues
Harrisburg Realtor Institute Camp Hill, PA
02/96 Broker Recertification-Mandatory
School of Real Estate Appraising King of Prussia, PA
06197 USPAP-Mandatory
School of Real Estate Appraising King of Prussia, PA
06/97 Fair Lending & The URAR
School of Real Estate Appraising King of Prussia, PA
06/97 Guide to Relocation Appraisals
School of Real Estate Appraising King of Prussia, PA
06/97 The FHA Appraisal
Memberships
Greater Harrisburg Board of REALTORS
Lancaster County Board of REALTORS
Lebanon County Board of REALTORS
Pennsylvania Association of REALTORS
National Association of REALTORS
National Association of Real Estate Appraisers
RS Council
Real Estate Brokerage Managers Council
York & Adams Counties Board of REALTORS
Designations
Slate Certified Real Estate Appraiser
GRI - (Graduate of the Real Estate Institute)
CREA - Certified Real Estate Appraiser (NAREA)
PA State Real Estate Broker
Dynamic Appraisals, Inc. 1993 - Present
Certified Residential Appraiser/President
H. Troup REALTOR/Appraisals 1991-1993
Assistant Appraiser
tployed 11 1979-1991
R.E. Licenr?se, R.E. Investment Analysis
Lice 2 se,
Property, Property Management
I
A. Hoffman/Dynamic Appraisals, Inc. currently services 6 counties in South Central
livania and these 8790+ appraisals, totalling over 968 million dollars, have been
ned on existing residential, new builds, construction, vacant land, subdivision, multi-
income producing, and some commercial property.
Dynamic Appraisals, Inc.
"Specializing in Residential Real Estate Appraisals"
Serving Central Pennsylvania
5001 Carlisle Pike • Mechanicsburg, PA 17055 • (717)737-9433
Client List
Below is a partial list of clients for which Daniel A. Hoffman has provided, or is approved to
provide services as an appraiser, contract appraiser, or assistant appraiser:
1998-1999
Aarrow Mortgage
AAA Financial Group
ACCB Mortgage
Acadia Financial
AccuBanc Mortgage Corp.
Accutech Associates
Action Mortgage
ADJ Mortgage
Advanced Residential
Advanta Finance
Advantage Equity
AFG First Financial
Affinity Finance
Agape Mortgage
Agents Mortgage
AIR Appraisals
Alliance Funding
Allied Mortgage Group
Alternative Lending Mortgage
American Beneficial
American Heritage
American Home Loans
American Mortgage Reduction
America's Mortgage Mart
Ameriquest Mortgage Company
AMRESCO
AP Funding
Apple Glen Mortgage r
Asset Mortgage
Associates Relocation
Assurance Mortgage Co.
Atlantic Central
Atlantic Home Funding
Atlantis Mortgage
Atlas Residential
AD
Axcess Financial
Baltimore American Mortgage
Banc One Mortgage Corporation
Bank of Lancaster
Barnett Mortgage
Blue Ball Financial
Blue Bail National Bank
Brandywine Mortgage
Broker Asset Mortgage
Capital Group
Capitol Mortgage Bankers
Cendant Mobility
Cendant Mortgage
Cenlar Mortgage
Centex Home Equity
Central Penn Mortgage Company
Chapel Mortgage
Chase Manhattan Mortgage Corporation
Coast to Coast
Columbia National Mortgage
Commerce Bank
CommonPoint Mortgage
COMNEr
Conti Mortgage
Cornerstone Federal Credit Union
Countrywide Home Loans
Crossland Mortgage
Dan The Mortqaqe Man _
Dynamic Appraisals, Inc.
"Specializing in Residential Real Estate Appraisals"
Serving Central Pennsylvania
5001 Carlisle Pike • Mechanicsburg, PA 17055 • (717)737-9433
Designer Mortgage
Drake Mortgage
Drogaris Companies
E Capital
E Mortgage
Eagle National
Eastern Savings Bank
Epic Mortgage
Epoch Mortgage
Equicredit Corp.
Equitable Mortgage
Equity Line
Equity One
Excell Financial
Farmers First
FDB Morgage
Fieldstone Mortgage
Fidelity Mortgage
Finances Unlimited
Financial Plus
First American Equity
First American Funding
First Central
First Federal Funding
First Mutual
First Union Home Equity Bank
First United
Franklin Financial
Freedmont Mortgage Corporation
Freedom Mortgage
FSC Corporation
Gateway Funding
General Mortgage
GMAC Mortgage
Great Eastern
Great Lakes Mortgage
Greatstone Mortgage
Green Tree Mortgage Service
Guardian Mortgage
Hamburg Home Mortgage
Hansen Mortgage
Harbor Mortgage
Hayden Mortgage
Highland Mortgage
Home Mortgage
Home Gold Mortgage
Homesale Mortgage
Home Team Mortgage
Household Finance
H & R Block
Interstate Home Equity
Irwin Mortgage
Jefferson Bank
Keystone State Mortgage
Koch Financial
KMF Mortgage
Land America
Laural Mortgage
Market Street Mortgage
Mechanics Savings and Loan
Mellon Mortgage
Members lst Federal Credit Union
Mid Atlantic Mortgage
Millenium Mortgage
MNC Mortgage
Money Store
ynamid Appraisals, Inc.
"Specializing in Residential Real Estate Appraisals"
Serving Central Pennsylvania
5001 Carlisle Pike • Mechanicsburg, PA 17055 • (717)737-9433
Client List, Con't
Money Tree Financial
Mortgage Services Group
Mortgage Support
Mortgages Unlimited
Mutual Consumer Discount
NASOD
National City Mortgage
Nationwide
Nittany Home Mortgage
NJMIC
NLPA Mortgage
North American Mortgage
One Loan Mortgage
Pace National
PC Mortgage
Pioneer Mortgage
Premier Mortgage
Prestige Mortgage
Progressive Marketing
Pro Source
Public Mortgage -
Reading Mortgage
Real Estate Mortgage Resources
Regal Savings Bank
R & R Mortgage
Security Funding
Select Mortgage
Shenango Home Equity
Shur Sale
Source One
STARS
Superior Bank
Susquehanna Mortgage
Thomas Politica, Sr.
UC Lending
United Financial
Upland Mortgage
..Upstate Capital
US Direct
US Mortgage
US Security
Valley Pine
Value America
Waterfield Financial
Wholesale Lending
York Federal
i
I
MTSERVERMServeAR&A Family LaMClient Directory\krug, LisaTre-Trial Statement of Lisa Krug (03-22-02).wpd O
April 2, 2002 1
KARL L. KRUG, IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO. 00-6961
LISA L. KRUG, CIVIL ACTION - LAW
Defendant IN DIVORCE
PRE-TRIAL STATEMENT OF
LISA L. KRUG
I. BACKGROUND INFORMATION:
PLAINTIFF:
1.
2.
Name:
Address:
Karl L. Krug
4900 Charles Road
Mechanicsburg, PA 17050
3.
4.
5.
6.
7.
8.
Age:
Date of Birth:
Educational Background:
Health:
Occupation:
Employer:
DEFENDANT:
41
April 16, 1960
Associate Degree in Business
No health issues were raised.
Mortgage Broker.
Superior Mortgage
1. Name: Lisa L. Krug
2. Address: 6501 Salem Park Circle
Mechanicsburg, PA 17050
3. Age: 42
4. Date of Birth February 16, 1960
\\ NTSERVER\NTServer,R&A Family Law\Client Directorykrug, Lisa\Pre-Trial Statement of Lisa Krug (03-22-02).wpd
April 2, 2002
5. Educational Background:
5. Health:
6. Occupation:
7. Employer:
High School
No health issues were raised.
Insurance Clerk.
Penn National.
CHILDREN OF THIS MARRIAGE:
1. Jeremy November 6, 1982
Joshua April 29, 1985
Jennifer July 30, 1988
Mother is the primary physical custodian of the minor child.
MARRIAGE INFORMATION:
1. Date of Marriage: August 22, 1981
2. Place of Marriage: New Germany, Pennsylvania
3. Date of Separation: July 1, 2000
4. Date Action Commenced: October 5, 2000
5. Issues Raised: Divorce, Equitable Distribution, APL, Alimony, Counsel Fees and
Costs
II. INCOME
See Income & Expense Statements previously filed.
2
d
\\ NTSERVER\NTServer\R&A Family Law\Client Direotory\krug, Lisa\Pre-Trial Statement of Lisa Krug (03-22-02).wpd
April 2, 2002
Ill. ASSETS:
A. Real Property
1. 4900 Charles Road, Mechanicsburg, Pennsylvania 17050. This asset is jointly held and
`. has been appraised at $120,000.00. Husband currently resides in the home.
B. Retirement
Plaintiff:
1. Edward Jones 401(k)
2. Edward Jones Roth IRA
Value 9/28/01 - $11,498.00
Value 9/28/01 - $459.00
National City/Accubanc 401(k) Value 6/30/01 - $54,801.00
2. Merrill Lynch Retirement Account Value 3/31/00 - $ 48,450.00
Defendant:
1. Edward Jones 401(k)
2. PSERS
C. Vehicles.
1. 1998 Pontiac Montana (V)
2. 1995 Ford Mustang (H)
3. 1992 Chevrolet Caprice (H)
D. Personal Pronertv associated with the house.
Value 4/28/00 - $ 8,669.00
Value 6/30/99 - $ 2,708.00
Value - $ 15,500.00
Value - $ 10,550.00
Value - $ 2,925.00
1. Divided by agreement
E. Accounts, Cash
1. Approximately $14,000.00 in escrow from various liquidations and tax refunds.
3
I
` \\NTSERVER\NTServer\R&A Family Law\Client Directory\krug, LisaTre-Trial Statement of Lisa Krug (03-22.02).wpd
April 2, 2002
2. Datek stock account - present balance $51.00, Husband withdrew $12,000.00 from this
account during separation.
IV. EXHIBITS
1. 2001 income tax return (W)
2. 2001 W-2's (W)
3. 1999, 2000, 2001 tax returns (H)
4. Appraisal - marital home
5. DOS statement: Edward Jones 401(k) (H)
6. Present statement: Edward Jones 401(k) (H)
7. DOS statement: Edward Jones Roth IRA (H)
8. Present statement: Edward Jones Roth IRA (H)
9. DOS statement: National City/Accubane 401(k) (H)
10. DOS statement: Merrill Lynch Retirement (H)
11. Present DOS statement: Merrill Lynch Retirement (H)
12. DOS statement: Edward Jones 401(k) (W)
13. Present statement: Edward Jones 401(k) (W)
14. DOS & present PSERS statement (W)
15. NADA values
1998 Pontiac Montana
1995 Ford Mustang
1992 Chevy Caprice
16. Current escrow account statement
17. Datek statement - DOS
18. Datek statement with liquidation amount
19. Datek statement - present
20. Current mortgage statement
21. DOS statement - Members First personal loan
22. DOS statement - Mellon Bank personal loan
23. DOS statement - Firestone
24. DOS statement - Discover card
4
r
MTSERVERWI-ServeAR&A Family LaMOlient Directory\krug, LisaTre-Trial Statement of Lisa Krug (03-22-02).wpd
April 2, 2002 -
25. DOS statement - First USA card
26. DOS statement - American General
27. DOS statement - Fleet credit card
28. Invoices Reager & Adler
V. MARITAL PROPERTY TRANSFERRED
A. Datek Stock Account.
Husband withdrew $12,000.00 during separation and must be credited with receipt for
equitable distribution purposes.
VI. MARITAL DEBT
A. Loan.
1. Mortgage
2. Members First Personal Loan
3. Mellon Bank Personal Loan
B. Credit Cards.
1. Firestone
2. Discover Card
3. First USA Card
4. American General Card
5. Fleet Credit
Present value unknown
Value 8/31/01 - $ 9,150.00
Value DOS - $ 5,090.00
Value DOS - $ 226.00
Value DOS - $ 7,216.00
Value DOS - $ 8,054.00
Value DOS - $ 964.00
Value DOS - $ 4,200.00
VII. WITNESSES
A. Expert
.
1. None. Unless a dispute regarding the value of the home arises.
B. Fact:
1. Lisa Krug
2. Karl Krug, as on cross examination
5
r
MTSERVERWTServer\R&A Family Law\Client DireotogAkmg, Lisa\Pre-Trial Statement of Lisa Krug (03-22-02).wpd
April 2, 2002
3. Records Custodian, Accubanc, Superior Mortgage, Allied Mortgage
4. David Kennerly
VI. PROPOSED RESOLUTION
A. 56%-44% division of the assets
B. Husband may retain the home
C. Alimony $825.00 per month for 7 years
D. Fees and Costs - $3,000.00
Respectfully Submitted,
REAGER & ADLER, PC
s
Date: April 2, 2002 By:
66378
2331 Market Street
Camp Hill, PA 17011-4642
Telephone No. [717] 763-1383
Attorneys for Defendant
6
Y
\\NTSERVER\NTserver\R&A Family Law\Client Dirsctory\krug, Lisa\Pre-Trial Statement of Lisa Krug (03-22-02).wpd
April 2, 2002
CERTIFICATE OF SERVICE
n?
AND NOW, this day of , 2002, I hereby verify that I have
caused a true and correct copy of the foregoing document, Pre-Trial Statement of Lisa L Krug, to
be placed in the U.S. mail, first class, postage prepaid and addressed as follows:
Karl L. Krug
c/o Robert C. Saidis, Esquire
Saidis, Shuff, Flower & Lindsay
2109 Market Street
Camp Hill, PA 17011
7
REAGER & ADLER, P.C.
REAGER & ADLER, PC
ATTORNEYS AND COUNSELORS AT LAW
2331 MARKET STREET
CAMP HILL, PENNSYLVANIA 17011-4642
717-763-1383
TELEFAX 717-730-7366
WEBSITE: ReagerAdlerPC.com
THEODORE A. ADLER +
DAVID W. REAGER
CHARLES E. ZALESKI
LINUS E. FENICLE
DEBRA DENISON CANTOR
Writer's E-Mail Address: ddenison@epix.net
February 26, 2002
E. Robert Elicker, II, Esquire
9 Hanover Street
Carlisle, PA 17013
RE: Krug v. Krug
No.: 00-6961
Our File No.: 00-550
Dear Bob:
THOMAS O. WILLIAMS
SUSAN H. CONFAIR
JOANNE HARRISON CLOUGH
CHRISTINE SCHWAMBERGER
+ Certified Civil Trial Specialist
Enclosed please find the fully executed Certification in the above-referenced matter.
DDC/waw
Enclosure
cc: Lisa Krug (w/enclosure)
KARL L. KRUG, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 00 - 6961 CIVIL
LISA L. KRUG,
Defendant IN DIVORCE
TO: Robert C. Saidis
Debra Denison Cantor
Attorney for Plaintiff
Attorney for Defendant
DATE: Wednesday, February 20, 2002
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
DATE SEL F AINTIFF ( )
COUNSEL FO EFENDANT
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.
KARL L. KRUG,
Plaintiff
VS.
LISA L. KRUG,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 00 - 6961 CIVIL
IN DIVORCE
NOTICE OF PRE-HEARING CONFERENCE
TO: Robert C. Saidis
Debra A. Denison Cantor
, Attorney for Plaintiff
, 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 14th day of June 2002, 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: 4/9/02 E. Robert Elicker, II
Divorce Master
i
A
IN THE COURT OF COMMON PLEAS OF
KARL L.KRUG CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff CIVIL ACTION - LAW
VS. NO 00-6961 CIVIL 19
IN DIVORCE
LISA L. KRUG
Defendant
STATUS SHEET
KARL, L. KRUG, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 00 - 6961 CIVIL
LISA L. KRUG,
Defendant IN DIVORCE
TO: Robert C. Saidis
Debra Denison Cantor
, Attorney for Plaintiff
, Attorney for Defendant
DATE: Wednesday, February 20, 2002
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.
d
(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.
LAW OFFICES
SAIDIS, SHUFF, FLOWER & LINDSAY
A PROFESSIONAL CORPORATION
26 WEST HIGH STREET
JAMES D. FLOWER CARLISLE, PENNSYLVANIA 17013
JOHN E. SLID TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486
ROBERT C. SAIDIS EMAIL: attomey@ssfl-Iaw.com
GEOFFREY S. SHUFF www.ssfl-law.com
JAMES D. FLOWER, JR.
CAROL J. LINDSAY
JOHNNA J. KOPECKY
KARL M. LEDEBOHM
JOSEPH L. HITCHINGS
THOMAS E. FLOWER
FORREST N. TROUTMAN, II
April 4, 2002
Mr. Robert Elicker
Support Master
9 North Hanover Street
Carlisle, PA 17013
Re: Krug v. Krug
No. 00-6961
Dear Mr. Elicker:
WEST SHORE OFFICE:
2109 MARKET STREET
CAMP HILL, PA 17011
TELEPHONE: (717)737-3405
FACSIMILE: (717)737-3407
REPLY TO CARLISLE
Enclosed please find the Pre-Trial Statement as required to be
filed with you on or before April 5, 2002.
Upon agreement of counsel, we have determined to proceed without
attaching the exhibits at this time. Our negotiations lead us to
believe we are relatively close to a Property Settlement and
Separation Agreement which shall resolve this entire matter.
Nonetheless, we would ask that you schedule a Pre-Trial Conference
at your earliest convenience.
Very truly yours,
S&i SHUFF,
FLOWER & LINDSAY
Robert C. Saidis
RCS/pm
Enclosure
CC: Debra Denison Cantor, Esq.
Karl Krug
REAGER & ADLER, PC
ATTORNEYS AND COUNSELORS AT LAW
2331 MARKET STREET
CAMP HILL, PENNSYLVANIA 17011-4642
717-763-1383
TELEFAX 717-730-7366
WEBSITE: ReagerAdlerPC.com
THEODORE A. ADLER +
DAVID W. REAGER
CHARLES E. ZALESKI
LINUS E. FENICLE
DEBRA DENISON CANTOR
Writers E-Mail Address: ddenison@epix.net
April 4, 2002
E. Robert Elicker, II, Esquire
9 Hanover Street
Carlisle, PA 17013
RE: Krug v. Krug
No.: 00-6961
Our File No.: 00-550
Dear Bob:
THOMAS O. WILLIAMS
SUSAN H. CONFAIR
JOANNE HARRISON CLOUGH
CHRISTINE SCHWAMBERGER
DOUGLAS P. LEHMAN
+Certi£ed Trial Specialist
Enclosed please find a copy of the Pretrial Statement of Lisa L. Krug. Pursuant to an agreement
among counsel, we have not filed the exhibits as we hope to have this matter settled in due course.
Your attention is appreciated.
truly
Cantor
DDC/waw
Enclosure
cc: Robert C. Saidis, Esquire (w/enclosure)
Lisa L. Krug (w/enclosure)
LAW OFFICES
SAIDIS, SHUFF, FLOWER & LINDSAY
A PROFESSIONAL CORPORATION
26 WEST HIGH STREET
JAMES D. FLOWER CARLISLE, PENNSYLVANIA 17013
JOHN E. SLIKE TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486
ROBERT C. SAIDIS EMAIL: attorney@ssfl-law.com
GEOFFREY S. SHUFF www.ssfl-law.com
JAMES D. FLOWER, JR.
CAROL J. LINDSAY
JOHNNA J. KOPECKY
KARL M. LEDEBOHM
JOSEPH L. HITCHINGS
THOMAS E. FLOWER
FORREST N. TROUTMAN, II
March 1, 2002
Mr. Robert Elicker
9 North Hanover Street
Carlisle, PA 17013
Re: Krug v. Krug
No. 00-6961
Dear Bob:
Please be advised that Discovery is complete in the above captioned matter.
Very truly yours,
WEST SHORE OFFICE:
2109 MARKET STREET
CAMP HILL, PA 17011
TELEPHONE: (717)737-3405
FACSIMILE: (717)737-3407
REPLY TO CARLISLE
SAI , HUFF, FLOWER & LINDSAY
Yobert/CS?ajidis
RCS/kll
Enclosure
cc: Debra Denison Cantor, Esq.
Karl Krug
JOHN E. SLIKE
ROBERT C. SAIDIS
GEOFFREY S. SHUFF
JAMES D. FLOWER, JR.
CAROL J. LINDSAY
JOHNNA J. KOPECKY
KARL M. LEDEBOHM
JOSEPH L. HITCHINGS
THOMAS E. FLOWER
FORREST N. TROUTMAN, II
LAW OFFICES
SAIDIS, SHUFF, FLOWER & LINDSAY
A PROFESSIONAL CORPORATION
26 WEST HIGH STREET
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486
EMAIL: attorney@ssfl-law.com
www.ssfl-law.com
June 13, 2002
Mr. Robert Elicker
9 North Hanover Street
Carlisle, PA 17013
Re: Krug v. Krug
No. 00-6961
Dear Mr. Elicker:
We have resolved the above-captioned action.
WEST SHORE OFFICE:
2109 MARKET STREET
CAMP HILL, PA 17011
TELEPHONE: (717)737-3405
FACSIMILE: (717)737-3407
REPLY TO CARLISLE
I will provide you all the necessary information to complete your
file. Please note the pre-trial hearing scheduled for Friday, June
14, 2002, at 9:30 a.m. will not be necessary.
Thank you for your continuing cooperation in this matter.
Very truly yours,
IS, SHUFF, FLOWER & LINDSAY
obert C. Saidis
RCS/pm
CC: Debra Denison Cantor, Esq.
Rickie Shadday
OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240-6535
E. Robert Elicker, 11
Divorce Master
Traci Jo Colyer
Office Manager/Reporter
March 11, 2002
West Shore
697-0371 Ext. 6535
Robert C. Saidis, Esquire Debra A. Denison Cantor
SAIDIS, SHUFF, FLOWER & LINDSAY Attorney at Law
26 West High Street REAGER & ADLER, P.C.
Carlisle, PA 17013 2331 Market Street
Camp Hill, PA 17011
RE: Karl L. Krug vs. Lisa L. Krug
No. 00 - 6961 Civil
In Divorce
Dear Mr. Saidis and Ms. Denison Cantor:
Both counsel have certified that discovery is complete. Therefore, I
am going to proceed with a directive for pretrial statements.
A divorce complaint was filed on October 11, 2000, raising grounds
for divorce of irretrievable breakdown of the marriage. No economic
claims were raised in the complaint. On February 5, 2002, the Plaintiff
filed a petition for equitable distribution. No claims have been raised by
either party for alimony or counsel fees and costs.
In accordance with P.R.C.P. 1920.33(b) I am directing each counsel
to file a pretrial statement on or before Friday, April 5, 2002. Upon
receipt of the pretrial statements, I will immediately schedule a pre-
hearing conference with counsel to discuss the issues, and if necessary,
Mr. Saidis and Ms. Denison Cantor, Attorneys at Law
11 March 2002
Page 2
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.
Karl L. Krug,
Plaintiff
V.
Lisa L. Krug,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
NO. 00-6961
IN DIVORCE
CIVIL TERM
MOTION FOR APPOINTMENT OF MASTER
Plaintiff, Karl L. Krug, moves the court to appoint a master with respect to the following claims:
( x) Divorce (x) Distribution of Property
1 1 Annulment ( 1 Support
( ) Alimony ( ) Counsel Fees
( ) Alimony Pendente Lite (1 Costs and Expenses
and in support of the motion states:
(1) Discovery is complete as to the claim(s) for which the appointment of a master is requested.
(2) The Defendant appeared in the action by her attorney, Debra Denison Cantor, Esquire, Reager,
Adler & Cognetti, P.C. 2331 Market Street, Camp Hill, PA 17011-4642
(3) The statutory ground(s) for divorce is/are: 3301( c) or 3301(d).
(4) Delete the inapplicable paragraph(s).
(a) The action is contested.
(b) An agreement has been reached with respect to the following claims: .
N/A
lc) The action is contested with respect to the following claims:
equitable distribution of property.
(5) The action complex issues of law or tact. N/A
(6) The hearing is expected to take: 1 day
(7) Additional information, if any, relevarlVio/he motion:
Date: J- 2
Rob6rt C. Saidis, Esquire
Attorney forPlaintiff, Karl L. Krug
26 W. High Street
Carlisle, PA 17013
ORDER APPOINTING MASTER n
6.
AND NOW, this day of 2002, , Esquire, is appointed master
with respect to the following claims:
By the Cou
'A,' W. -
10- i
i- s
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsylvania
Co./City/Dist. of CUMBERLAND
Date of Order/Notice 07/31/06
Case Number (See Addendum for case summary)
Employer/Withholder's Federal FIN Number
WELLS FARGO HOME MORTGAGE INC
C/O PAROLL DEPT
FL 14
90 S 7TH ST
MINNEAPOLIS MN 55479-0001
169-54-7551
Fmployee/Obligor's Social Security Number
9454100578
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 825. 00 per month in current support
$ 0.00 per month in past-due support Arrears 12 weeks or greater? Oyes ® no
$ 0.00 per month in current and past-due medical support
$ 0.00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 825 , 00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 190.38 per weekly pay period.
$ 380.77 per biweekly pay period (every two weeks).
$ 412.50 per semimonthly pay period (twice a month).
$ 825.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on page 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
Date of Order: AUG U 1 2066
DRO: R.J. Shadday
Service Type m
053102436
00-6961 CIVIL
O Original Order/Notice
O Amended Order/Notice
O Terminate Order/Notice
RE: KRUG, KARL L.
Employee/Obligor's Name (Last, First, MI)
BY THE COURT:
/ 054 X4
Kevif Hess, Judge
Form EN-028
OMB No.: 0970-0154
$IATT
I
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
? Ifghecked you are required to provide a copy of this form to yourgmuloyee. If your employee works in a state that is
di erent from the state that issued this order, a copy must be provi a to your employee even if the box is not checked.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employeelobligor,
3.
You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
THE EMPLOYEE(OBLIGOR NO LONGER WORKS FOR: 1905100188
EMPLOYEE'S/OBLIGOR'S NAME: KRUG, KARL L.
EMPLOYEE'S CASE IDENTIFIER: 9454100578 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment,
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.S.C. §1673 01; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. Fortribal orders, you may not withhold more
than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more
than the amounts allowed under the law of the state that issued the order.
10. Additional Info:
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
i I -Submitted By: If you or your employee/obligor have any questions,
DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT
13 N. HANOVER ST by telephone at (717) 240-6225 or
P.O. BOX 320 by FAX at (717) 240-6248 or
CARLISLE PA 17013 by internet www.childsupport.state.pa.us
Page 2 of 2 Form EN-028
Service Type M oMBNo 097MI 54 WorkerlD $1ATT
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: KRUG, KARL L.
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
? If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
U
KARL L. KRUG, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION -LAW
LISA L. KRUG, : NO. 00-6961 CIVIL TERM
Defendant : IN DIVORCE
ADDENDUM TO PROPERTY SETTLEMENT AND
SEPARATION AGREEMENT
AGREEMENT TO TERMINATE ALIMONY
This Agreement made this day of
2008, between
4A91
KARL L. KRUG of New Cumberland, York County, Pennsylvania hereinafter
(referred to as "Husband") and LISA L. KRUG of Mechanicsburg, Cumberland
County, Pennsylvania hereinafter (referred to as "Wife").
RECITALS:
RA: The parties hereto are former Husband and Wife, having been divorced on
July 1, 2002. A copy of their Decree is attached hereto and incorporated herein by
reference as "Exhibit A".
R.2: The parties entered into a Property Settlement and Separation Agreement
dated June 10, 2002. A copy of said Agreement is attached hereto and incorporated
herein by reference as "Exhibit B".
R.3: The parties hereto desire to amend their Property Settlement and Separation Agreement
and to provide for the termination of the Alimony provision of said Agreement.
NOW THEREFORE, in consideration of the covenants and promises hereinafter to be
mutually kept and performed by each party, as well as for other good and valuable consideration
and intending to be legally bound, it is agreed as follows:
(1) TERMINATIONOFALIMONY
(a) Paragraph ten (10) of the parties Separation and Property Settlement
Agreement provided for Husband to pay to Wife, as alimony, the sum of $825 per
month, commencing the 1St day of June, 2002 and continuing in equal amounts on the
same day of each subsequent month until the occurrence of one of the following
events:
1. The death of Wife
2. The death of Husband
3. The remarriage of Wife or cohabitation of Wife with a member of
the opposite sex not within the degrees of consanguinity
4. The payment of the amount set out above for a period of 84
months from the date of the first payment
(b) As of May 11, 2008, Wife is cohabiting with a member of the opposite sex
not within the degrees of consanguinity; that person's name is Robert Snyder.
(c) Wife acknowledges her cohabitation and agrees that this is a cause for
immediate termination of the alimony payments to her by Husband.
(d) Husband's alimony payments shall terminate effective July 31, 2008 and
no additional payments shall be collected by Domestic Relations or by Wife. On the
date of execution of this Agreement Wife shall forward a copy of this Agreement to
the office of Domestic Relations and sign whatever other documents necessary to
terminate collection of alimony effective July 31, 2008 at that office.
(e) If additional payments are collected by attachment by the Office of
Domestic Relations of Cumberland County after July 31, 2008, and Wife receives
said payment, Wife shall reimburse Husband the amount she has received.
(2) LIFE INSURANCE: Paragraph 10(d) of the parties' June 10, 2002,
Property Settlement and Separation Agreement provides for Husband to immediately
secure a life insurance policy on his life in the initial amount of $70,000 as security
for the payment of alimony designating Wife as irrevocable beneficiary. Husband
shall be permitted to terminate said policy as of August 1, 2008.
(3) OTHER CONSIDERATION: For and in consideration of the agreements
made herein, Husband also shall make a one time payment to Wife in the amount of
TWO THOUSAND AND 00/100 DOLLARS ($2,000.00) within 30 days of
execution of this Agreement, after all other provisions of this Agreement are
complied with and satisfied, so that Husband's payment shall be received by Wife
after she has terminated alimony at Domestic Relations and Husband's payment shall
be reduced by any amount that Wife has withheld (if she has done so) of any alimony
amount received after July 31, 2008.
(4) ADVICE OF COUNSEL: The parties hereto acknowledge that each has
been notified of his or her right to consult with counsel of his or her choice.
Husband is represented by Marylou Matas, Esq. Wife has reviewed this Agreement
and has had the opportunity to have the provisions of this Agreement and their legal
effect explained to her by counsel but has chosen to proceed on her own without legal
representation and is entering into this Agreement of her own free will. Each party
acknowledges and accepts that this Agreement is, under the circumstances, fair and
equitable, and that it is being entered into freely and voluntarily after having received
such advice and with such knowledge as each has sought from counsel, and the
execution of this Agreement is not the result of any duress or undue influence, and
that it is not the result of any improper or illegal agreement or agreements. Each
party shall pay his or her own attorney for all legal services rendered or to be
rendered on his or her behalf.
(S) ADDITIONAL INSTRUMENTS: Each of the parties shall from time to
time, at the request of the other, execute, acknowledge and deliver to the other party
any and all further instruments that may be reasonably required to give full force and
effect to the provisions of this Agreement.
(6) RIGHTS AND RESPONSIBILITIES: Husband and Wife acknowledge
that each of them has read and understands his or her rights and responsibilities under
this Agreement and that they have executed this Agreement under no compulsion to
do so but as a voluntary act.
(7) RELEASE OF ALL CLAIMS: Except as may be otherwise specifically
provided in this Agreement, Husband and Wife, for themselves, their heirs,
representatives and assigns, each hereby forever releases, remises, discharges and
quitclaims the other, and such other's heirs, representatives, assigns and estate, from
and with respect to the following:
A. All liability, claims, causes of action, damages, costs, contributions and
expenses or demands whatsoever in law or in equity;
B. All rights, title, interest or claims in or to any property of the other,
whether real, personal or mixed and whether now owned or hereafter acquired;
C. All rights of curtsey and dower and all claims or rights in the nature of
curtsey and dower;
D. All widow or widower's rights;
E. All right, title, interest or claim in or to the other's estate, whether now
owned or hereafter acquired, including but not limited to all rights or claims:
(1) to take against the other's will;
(2) under the laws of intestacy;
(3) to a family exemption or similar allowance; and
(4) all other rights or authority to participate or intervene in a deceased
spouse's estate in any way, whether arising under the laws of Pennsylvania or any
other country, territory, state or political subdivision.
F. All rights or claims to any accounting;
G. All rights, claims, demands, liabilities and obligations arising out of or in
connection with the marital relationship or the joint ownership of property, whether
real, personal or mixed;
H. All rights, claims, demands, liabilities and obligations arising under the
provisions of the Pennsylvania Divorce Code, as the same may be amended from time
to time, and under the provisions of any similar statute enacted by any other country,
state, territory or political subdivision;
I. All rights, claims, demands, liabilities and obligations each party now has,
or may hereafter have, against or with respect to the other.
(8) BREACH: In the event that either party breaches any provision of this
Agreement, he or she shall be responsible for any and all costs incurred to enforce the
Agreement, including, but not limited to, Court costs and counsel fees of the other
party. In the event of breach, the other party shall have the right, at his or her
election; to sue for damages for such breach or to seek such other and additional
remedies as may be available to him or her.
(9) ENTIRE UNDERSTANDING: This Agreement constitutes the entire
understanding between the parties and there are no covenants, conditions,
representations, or agreements, oral or written, of any nature whatsoever, other than
those herein contained.
(10) AGREEMENT BINDING ON PARTIES AND HEIRS: This Agreement
shall bind the parties hereto, their respective heirs, executors and assigns.
IN WITNESS WHEREOF, the parties hereto intending to be legally bound have
hereunto set their hands and seals the day and year first written above.
? 81r 0?
Witness a e . Karl L. Krug
Wit @ss a e i a L. Krug
COMMONWEALTH OF PENNSYLVANIA :
COUNTY OF CUMBERLAND
On this 114 day of AuSus T , 2008, before me, the undersigned,
personally appeared KARL L. KRUG, whose name is subscribed to the within
instrument, and acknowledged that he executed the same for the purposes therein
contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Al
K?tA
Notary Public
NOTARIAL SEAL
THOMAS W. MARTINDALE, Notary PUNC
City of Harrisburg, Dauphin Cour>ty
My C mftsion Expires April 28, 2011
COMMONWEALTH OF PENNSYLVANIA :
COUNTY OF CUMBERLAND
On this _ 9 day of (" 4AD-? , 2008, before me, the undersigned,
personally appeared LISA L. KR, whose name is subscribed to the within
instrument, and acknowledged that she executed the same for the purposes therein
contained.
IN WITNESS WHEREOF, i here«nto set my hand and official seal.
.. R
Not Public
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
NANCY E. WWEL, Notary Public
Hampden TWp., Cwnbwl&W County
My Cammis" Expim Dec. 25, 2011
+
+
+ IN THE COURT OF COMMON PLEAS
+ +
+ OF CUMBERLAND COUNTY +
+
+ `a
+ STATE OF PENNA. +
+ +
Karl L. Krug,
Plaintiff
No. 2000-6961 Civil
VERSUS
Lisa L. Krug,
Defendant
DECREE IN
DIVORCE
AND NOW, July 1 32002 , IT IS ORDERED AND
DECREED THAT Karl L. Krug PLAINTIFF,
Lisa L. Krug
AND 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;
The terms of the Property Settlement and Separation Agreement dated
June 10, 2002, are incorporated, but not merged.
BY THE COURT:
Kevin A. Hess
ATTEST: J
/t PROTHONOTARY
Certified Copy Issued: July 1, 2 2
. r
PROPERTY SETTLEMENT AND SEPARATION AGREEMENT
THIS AGREEMENT made this tic day of 2002 between Karl L. Krug,
of Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred to as
"Husband",
A
T
D
Lisa L. Krug, of Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred
to as "Wife".
RECITALS:
R.1: The parties hereto are Husband and Wife, having been joined in marriage
August 22, 1981, in New Germany, Pennsylvania: and
R.2: A Complaint for Divorce has been filed in the Court of Common Pleas of
Cumberland County, Commonwealth of Pennsylvania, to Number 00-6961, Civil Term;
and
R.3: The parties' hereto desire to settle fully and finally their respective financial
and property rights and obligations including, but not limited to all matters between them
relating to the ownership of real and personal property, claims for spousal support,
alimony, alimony pendente lite,
R.4: The distribution of the parties' marital property is based on Exhibit "A" of this
Agreement which distributes the marital property approximately 55.9% to Wife and
approximately 44.1 % to Husband.
i
?? L t
R.5: The parties also desire to settle the issues of custody of their minor children,
Joshua M. Krug, DOB 4-29-85, and Jennifer L. Krug, DOB 7-30-88, counsel fees and
costs, and the settling of any and all claims and possible claims against the other or
against their respective estates.
NOW THEREFORE, in consideration of the covenants and promises hereinafter to
be mutually kept and performed by each party, as well as for other good and valuable
consideration and intending to be legally bound, it is agreed as follows:
(1) SEPARATION: It shall be lawful for each party at all times hereafter to live
separate and apart from the other party at such place or places as he or she from time to
time may choose or deem fit, free from any control, restraint or interference from the
other. Neither party will molest the other or endeavor to compel the other to cohabit or
dwell with him or her by any legal or other proceeding. Each party shall be free of the
interference, authority or contact by the other as if he or she was single and unmarried
except as maybe necessary to carry out the terms of this agreement.
(2) DIVORCE:
The parties acknowledge that the marriage is irretrievably broken and that they will
secure a mutual consent no-fault divorce decree in the above-captioned divorce action.
Upon the execution of this agreement, the parties shall execute and file an Affidavit of
Consent and Waiver of Notice, necessary to finalize said divorce. Husband shall cause
the divorce to be transmitted to the Court, immediately after execution of this Agreement.
(3) REAL PROPERTY: The parties are the owners of certain real estate with
improvements thereon erected known and numbered as 4900 Charles Road,
Mechanicsburg, Pennsylvania 17050-3036.
z
a '
Husband and Wife agree that the real estate is under contract for sale at
$116,500. Upon sale and settlement, the net proceeds as hereinafter provided shall be
divided fifty-five (55%) percent to Wife and forty-five (45%) percent to Husband.
Husband shall have exclusive possession of the marital residence until sale and
settlement. During said period, Husband shall be responsible for all household
expenses, including the Wells Fargo Home Mortgage, utility bills, insurance, taxes and
maintaining the marital residence in its current condition, normal wear and tear excepted.
In the event all expenses with regard to the marital residence are not current at the time
of sale and settlement, said expenses shall be paid, by setoff, from Husband's equitable
distribution as hereinabove set forth, except that interest for the current month, up to the
date of the settlement, shall not be deducted from Husband's share.
In the event repairs or extraordinary maintenance, which means a single repair or
maintenance item exceeding five hundred ($500) dollars, are required during Husband's
period of exclusive possession then in that event Husband shall pay said item and shall
be reimbursed at settlement prior to equitable distribution. Husband shall, if time permits,
advise Wife of said items and request her consent, which shall not be unreasonably
withheld.
(4) DEBT:
A. MARTIAL DEBT: Husband and Wife acknowledge and agree that
there are no other outstanding debts and obligations which are martial, or for which the
other might be liable, incurred prior to the signing of this Agreement, except as follows:
i. Members First Personal Loan $ 9,550.
ii. Mellon Bank Personal Loan $ 5,090.
3
iii. Firestone $ 226•
iv. Discover Card $ 7,216.
V. First USA Credit Card $ 8,054.
vi. American General Credit Card $ 964•
vii. Fleet Credit Card $ 4,200.
viii. Members First - Van Loan $7,400.
TOTAL 35 300.
(The balances shown are approximate as of the date the debts were assumed by
the respective parties)
1: Husband hereby assumes the Members First Personal Loan, Mellon Bank
Personal Loan, Firestone, Discover Card, First USA Credit Card, American General
Credit Card and Fleet Credit Card by making timely monthly payments and agrees to
indemnify and hold Wife harmless from any and all loss on the loans assumed by
Husband. Husband agrees to regularly attempt to transfer these balances to credit
cards or loans in his own name or to refinance these obligations in order to remove
Wife's name from said obligations.
2: Wife shall pay the obligation to Members First with regard to the van by making
timely monthly payments and agrees to indemnify and hold Husband harmless from any
and all loss on the loan assumed by Wife.
Each party shall pay in a timely fashion the outstanding joint debts as set forth
herein and further agrees to indemnify and save harmless the other from any and all
claims and demands made against either of them by reason of such debts or obligations.
B: Post Separation Debt: In the event that either party contracted or incurred any
4
debt since the date of separation on July 1, 2000, the party who incurred said debt shall
be responsible for the payment thereof regardless of the name in which the debt may
have been incurred.
C: Future Debt: From and after the date of this agreement neither party shall
contract or incur any debt or liability for which the other party or his or her property or
estate might be responsible and shall indemnify and save the other party harmless from
any and all claims or demands made against him or her by reason of debts or obligations
incurred by the other party
(5) MOTOR VEHICLES: Each party relinquishes any right, title and interest he or
she may have to any and all motor vehicles currently in possession of the other party.
Wife shall have possession of the 1998 Pontiac Montana or its replacement vehicle, and
Husband the 1995 Ford Mustang and 1992 Chevrolet Caprice. Within 15 days of the
date of this agreement each party shall execute any documents necessary to have said
vehicles properly registered in the other party's name with the Pennsylvania Department
of Transportation. Each party shall assume full responsibility of any encumbrance on the
motor vehicle received by said party, and shall hold harmless and indemnify the other
party from any loss thereon.
(6) TANGIBLE PERSONAL PROPERTY: The parties hereto mutually agree that
they have effected a satisfactory division of the furniture, household furnishings,
appliances, tools and other household personal property between them, and they
mutually agree that each party shall from and after the date hereof be the sole and
separate owner of all such property presently in his or her possession whether said
property was heretofore owned jointly or individually by the parties hereto. This
5
agreement shall have the effect of an assignment or bill of sale from each party to the
other for such property as may be in the individual possession of each of the parties
hereto.
The parties currently have, in escrow, with the law firm of Saidis, Shuff, Flower and
Lindsay, the total amount of $ 14,089.37 being the escrow proceeds from the refinance of
the home, the Edward Jones stock redemption, the income tax refund and the Fleet tax
escrow refund. The escrow held by Saidis, Shuff, Flower and Lindsay shall be distributed
$7,589.37 to Husband and $6,500.00 to Wife.
(7) INTANGIBLE PERSONAL PROPERTY: Each party hereby relinquishes any
right, title or interest he or she may have in or to any intangible personal property currently
titled in the name of or in the possession of the other party, including, but not limited to,
stocks, bonds, insurance, bank accounts, individual retirement accounts, employment
benefits including retirement accounts, savings plans, pension plans, stock plans, 401 K
plans and the like.
This paragraph shall specifically include the following accounts: Husband shall
retain his Edward Jones 401 K and Edward Jones Roth IRA. Wife shall retain her Edward
Jones 401 K and Pennsylvania State Retirement Account.
The Dreyfuss Retirement Account, having a balance of approximately $40,951.00
shall be divided fifty (50%) percent to Wife and fifty (50%) percent to Husband.
Husband acknowledges receipt prior to this distribution of the sum of four thousand two
hundred eighteen ($4,218.00) dollars from the prior retirement account with Merrill Lynch
or AccuBanc which was rolled over into Dreyfuss.
Husband shall retain the Datek stock, which has a current value of $143, together
6
with the proceeds from its partial liquidation of twelve thousand ($12,000) dollars.
(8) CUSTODY OF CHILDREN: The parties agree that legal custody of their minor
children, Joshua M. Krug, DOB 4-29-85 and Jennifer L. Krug, DOB 7-30-88, shall be joint,
with both parties having the right to make major parenting decisions affecting the
children's health, education and welfare.
Wife shall have primary physical custody of the children subject to Husband's
partial physical custody at the following minimum times:
(a) Every other weekend from Friday at 5:00 p.m. until Sunday at 10:00 p.m.;
(b) One night per week as selected by Husband with Wife's consent;
(c) Alternating holidays with the holidays being New Year's Day, President's
Day, Memorial Day, 4th of July and Labor Day,
(d) Easter and Thanksgiving shall alternate with Husband having Easter 2002
(i) Easter shall mean from Holy Thursday night or Good Friday morning
until Easter Sunday at 10:00 p.m.;
(ii) Thanksgiving shall be mean from after school on the preceding
Wednesday to the following Sunday at 10:00 p.m.
(e) Christmas shall alternate between (i) and (ii) below with Husband having (i)
for Christmas 2002;
(i) 9:00 a.m. Christmas eve morning to 2:00 p.m. Christmas day;
(ii) 2:00 p.m. Christmas day to 2:00 p.m. December 26
(f) Two hours on each child's birthday, unless said birthday is on a weekend at
which time Husband shall have one-half day;
(g) One-half of the children's summer vacation; and
o
i
(g) Other times as agreed upon.
(9) CHILD SUPPORT:
(A) Husband shall pay to Wife for the use, benefit, support and maintenance of
their minor children, the sum ordered by the Court of Common Pleas, filed to
Docket 577-S-2000, PACES 053102436.
(B) Husband shall pay the total arrearage on the Support Order, which
currently includes spousal support upon execution of this Agreement.
(C) Husband and Wife agree that any inquiry into support for the period
preceding September 30, 2000, has been resolved and each party releases the
other for any claim for support or credit against support paid.
(D) The parties agree that in the event of a material change in circumstances of
either party, or a change in the custody arrangements set forth herein, the amount
of support payments shall be subject to an appropriate adjustment by agreement
or, if the parties are unable to agree, by order of a court of competent jurisdiction,
and the amount ordered by any such court shall be deemed to be the amount due
hereunder.
(10) ALIMONY:
A Alimony: Husband agrees to pay to Wife as alimony the sum of $825 per
month commencing the 1st day of June, 2002 and continuing in equal amounts
on the same day of each subsequent month until the occurrence of one of the
following:
1. The death of Wife
2. The death of Husband
8
v
i
3. The remarriage of Wife or cohabitation by Wife with a member of
the opposite sex not within the degrees of consanguinity
4. The payment of the amount set out above for a period of 84
months from the date of the first payment.
B. The parties acknowledge that they know one another's Social Security
Number. Alimony payments shall be deductible from Husband's gross
income for the purpose of filing income tax returns and includible in Wife's
gross income for the same purpose.
C. Unless agreed otherwise, the alimony payment set out herein shall be
payable to the Office of Domestic Relations of Cumberland County or the
Office of Domestic Relations of a county having jurisdiction over Husband
and enforcement shall be by attachment of Husband's wages.
D. Husband shall immediately secure a life insurance policy on his life which
may be a decreasing term policy in the initial amount of seventy thousand
($70,000) dollars, as security, for the payment of alimony and shall
designate Wife irrevocable beneficiary. Said policy may be decreased on
an annual basis based on the amount of alimony paid in the prior year
only. Proof of insurance coverage to be provided to Wife's counsel or
Wife upon inception and then on an annual basis thereafter.
(11) POSTSECONDARY EDUCATION:
A. Husband shall pay or cause to be paid the net educational expenses of
each of the parties' children at an accredited undergraduate college or
university provided he/she is enrolled as a full time student, up to a total of
four (4) years of post secondary education subject to the limitations and
conditions set forth herein. Educational expenses shall be defined as
tuition, room and board (including full meal plan), fees, books, supplies,
reasonable clothing and spending money as well as transportation
9
a
expenses. If child is living off campus with the written consent of both
parties, instead of room and board, educational expenses shall include
actual expenses for rent, utilities and food.
B. Husband's obligation to pay a child's educational expenses as set forth in
the paragraph above shall be reduced by deducting any applicable loans,
scholarships and grants. Each child shall be required to apply for loans,
scholarships and grants and the parties will cooperate to the extent
necessary in assisting him/her to so apply.
Husband's obligations to pay educational expenses shall cease upon the
happening of the first of the following events:
(a) Child's death;
(b) Husband's death;
(c) The child's receipt of a bachelor's degree or its equivalent;
(d) The child's completion of four (4) consecutive or non-consecutive
academic years of higher education;
(e) The child being placed on academic probation for more than one (1)
consecutive semester; or
(f) The child reaching the age of twenty-three (23) years of age.
C. To the extent permitted by law, Husband and Wife agree that Husband
shall be entitled to the income tax exemption for any child enrolled in post
secondary education for whom Husband is paying the expenses as above
described. Wife agrees to execute any document necessary or desirable
for Husband to secure said exemption.
10
a
(12) ADVICE OF COUNSEL: The parties hereto acknowledge that each has
been notified of his or her right to consult with counsel of his or her choice, and have been
provided a copy of this agreement with which to consult with counsel, Wife is represented
by Debra Denison Cantor, Esq. and Husband is represented by Robert C. Saidis, Esq.,
Each party acknowledges and accepts that this agreement is, under the circumstances,
fair and equitable, and that it is being entered into freely and voluntarily after having
received such advice and with such knowledge as each has sought from counsel, and the
execution of this agreement is not the result of any duress or undue influence, and that it
is not the result of any improper or illegal agreement or agreements. Each party shall pay
his or her own attorney for all legal services rendered or to be rendered on his or her
behalf.
(13) ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at
the request of the other, execute, acknowledge and deliver to the other party any and all
further instruments that may be reasonably required to give full force and effect to the
provisions of this Agreement.
(14) INCOME TAX:
The parties have heretofore filed joint Federal and State Tax returns. Both parties
agree that in the event any deficiency in Federal, state or local income tax is proposed, or
assessment of any such tax is made against either of them, each will indemnify and hold
harmless the other from and against any loss or liability for any such tax deficiency or
assessment and any interest, penalty and expense incurred in connection therewith.
Such tax, interest, penalty or expense shall be paid solely and entirely by the individual
who is finally determined to be the cause of the misrepresentations or failures to disclose
11
the nature and extent of his or her separate income on the aforesaid joint returns.
(15) COMPLETE DISCLOSURE: The parties do hereby warrant, represent,
acknowledge and agree that each is fully and completely informed of, and is familiar with,
the wealth, real and personal property, estate and assets, earnings and income of the
other and has made any inquiry he or she desires into the income or estate of the other
and received any such information requested. Each has made a full and complete
disclosure to the other of his and her entire assets, liabilities, income and expenses and
any further enumeration or statement thereof in this Agreement is specifically waived.
(16) RIGHTS AND RESPONSIBILITIES: Husband and Wife acknowledge that
each of them has read and understand his and her rights and responsibilities under this
Agreement and that they have executed this Agreement under no compulsion to do so
but as a voluntary act.
(17) FULL SETTLEMENT: Except as herein otherwise provided, each party
hereby releases the other from any and all claims, or demands up to the date of
execution hereof. It is further specifically understood and agreed by and between the
parties hereto that each party accepts the provisions herein made in lieu of and in full
settlement and satisfaction of any and all of said party's rights against the other for past,
present and future claims on account of support, maintenance, alimony, alimony
pendente lite, counsel fees, costs and expenses, equitable distribution of marital property
and any other claims of the party, including all claims which have been raised or may be
raised in an action for divorce.
(18) RELEASE OF ALL CLAIMS: Except as may be otherwise specifically
provided in this Agreement, Husband and Wife, for themselves, their heirs,
12
representatives and assigns, each hereby forever releases, remises, discharges and
quitclaims the other, and such other's heirs, representatives, assigns and estate, from
and with respect to the following:
A. All liability, claims, causes of action, damages, costs, contributions
and expenses or demands whatsoever in law or in equity;
B. All rights, title, interest or claims in or to any property of the other,
whether real, personal or mixed and whether now owned or hereafter acquired;
C. All rights of curtesy and dower and all claims or rights in the nature of
curtesy and dower;
D. All widow or widower's rights;
E. All right, title, interest or claim in or to the other's estate, whether now
owned or hereafter acquired, including but not limited to all rights or claims:
(1) to take against the other's will;
(2) under the laws of intestacy;
(3) to a family exemption or similar allowance; and
(4) all other rights or authority to participate or intervene in a
deceased spouse's estate in any way, whether arising under the laws of Pennsylvania or
any other country, territory, state or political subdivision.
F. All rights or claims to any accounting;
G. All rights, claims, demands, liabilities and obligations arising out of or
in connection with the marital relationship or the joint ownership of property, whether real,
personal or mixed;
H. All rights, claims, demands, liabilities and obligations arising under
13
the provisions of the Pennsylvania Divorce Code, as the same may be amended from
time to time, and under the provisions of any similar statute enacted by any other country,
state, territory or political subdivision;
1. All rights, claims, demands, liabilities and obligations each party now has,
or may hereafter have, against or with respect to the other.
(19) GOVERNING LAW: This Agreement shall be construed under the law of the
Commonwealth of Pennsylvania. If any provision of this Agreement is determined to be
invalid or unenforceable, all other provisions shall continue in full force and effect.
(20) INCORPORATION INTO DECREE: In the event that either of the parties shall
recover a final judgment or decree of absolute divorce against the other in a court of
competent jurisdiction, the provisions of this Agreement may be incorporated by reference
or in substance but shall not be merged into such judgment or decree and this Agreement
shall survive any such final judgment or decree of absolute divorce and shall be entirely
independent thereof.
(21) BREACH: In the event that either party breaches any provision of this
Agreement, he or she shall be responsible for any and all costs incurred to enforce the
Agreement, including, but not limited to, court cost and counsel fees of the other party. In
the event of breach, the other party shall have the right, at his or her election; to sue for
damages for such breach or to seek such other and additional remedies as may be
available to him or her.
(22) ENTIRE UNDERSTANDING: This Agreement constitutes the entire
understanding between the parties and there are no covenants, conditions,
representations, or agreements, oral or written, of any nature whatsoever, other than
14
those herein contained.
(23) AGREEMENT BINDING ON PARTIES AND HEIRS: This Agreement shall
bind the parties hereto, their respective heirs, executors and assigns.
IN WITNESS WHEREOF, the parties hereto intending to be legally bound have
hereunto set their hands and seals the day and year first written above.
Witness Karl L. Krug
??" (?g - a.(i `
Witn ss
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBER AND ;
On this day of Ul U:. 2002, before me, the undersigned, personally appeared Karl L. Krug
whose name is subscribed to the within instrument, and acknowledged that they executed the carne for
the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official
'-Notarial Seal
Stacy L. Frick, Notary Public
COMMONWEALTH OF PENNSYLVANIA East Pennsboro Twp., Cumberland County
My Commission Expires Jan. 12, 2004
COUNTY OF CUMBERLAND
On this day of , 2002, before me, the undersigned, personally appeared Lisa L. Krug
whose name is subscribed to the within instrument, and acknowledged that they executed the same for
the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
NOTARIAL SEAL
CASSANDRA T. ROSENBAUM, Notary Public Notary Public
Camp Hill Boro, Cumberland County
6/5/02 My Commission Expires December 4, 2004
is
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ASSETS - Lisa ane 'zarl Krug
VEHICLES:
1998 Pontiac Montana
$ LISA
15,550 KARL
1995 Ford Mustang $ 10,550
1992 Chevrolet Caprice $ 2,925
Personal Property $ 5,000 $ 2,000
House (Estimate) $ 10,045 $ 8,218
Retirement Accounts:
a) Dreyfuss - $40,951 (Estimate)
$
20,535
$
20,416
POC $4,218 $ 4,218
Edward Jones (3 accounts)
b) Lisa - 401K - $8,510
$
8,510
c) Karl - 401K - $15,159 $ 15,159
d) Karl - Roth - $550 $ 550
e) PA State Retire. - Lisa - $2,708 $ 2,708
f) Natl.City/AccuBank (trans.toDreyfuss) $ -
SSF&L Escrow $14,089.37 $ 6,500 $ 7,589
Escrow Proceeds (Loan)
Edward Jones - Stock Redemption
Tax Refund
Fleet Escrow (Tax Rebate)
Datek - Stock $12,143 $ 12,143
$ 68,848 $ 83,768
LIABILITIES - Lisa and Karl Krug
Members 1 st -Van Loan
$ LISA
7,400 KARL
Wells Fargo - New 1st Mortgage
Members 1st - Personal $ 9,550
Mellon Bank - Personal $ 51090
Firestone $ 226
Discover Card $ 7,216
First USA Credit Card $ 8,054
American General $ 964
Fleet Credit Card $ 4,200
$ 7,400 $ 35,300
6/4/02
Asset Totals $ 68,848 $ 83,768 $ 109,916
Liabilities $ 7,400 $ 35,300
Net Value = $ 109,916 $ 61,448 $ 48,468
55.9% 44.1%
Exhibit "A"
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsylvania
CO./City/Dist. of CUMBERLAND
Date of Order/Notice 08/18/08
Case Number (See Addendum for case summary)
Employer/Withholder's Federal EIN Number
00-6961 CIVIL
OOriginal Order/Notice
OAmended Order/Notice
OTerminate Order/Notice
OOne-Time Lump Sum/Notice
RE: KRUG, KARL L.
Employee/Obligor's Name (Last, First, MI)
169-54-7551
Employee/Obligor's Social Security Number
WELLS FARGO HOME MORTGAGE INC 9454100578
C/O PAROLL DEPT Employee/Obligor's Case Identifier
FL 14 (See Addendum for plaintiff names
90 S 7TH ST associated with cases on attachmenO
MINNEAPOLIS MN 55479-0001 Custodial Parent's Name (Last, First, MI)
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee'slobligor's income until further notice even if the Order/Notice is not
issued by your State.
$ o . oo per month in current child support
$ o. oo per month in past-due child support Arrears 12 weeks or greater? Oyes ® no
$ 0.00 per month in current medical support
$ 0.00 per month in past-due medical support
$ 0.00 per month in current spousal support
$ o . oo per month in past-due spousal support
$ o . o o per month for genetic test costs
$ o . oo per month in other (specify)
$ one-time lump sum payment
for a total of $ o . o o per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 0.00 per weekly pay period. $ 0.00 per semimonthly pay period
(twice a month)
$ o . 00 per biweekly pay period (every two weeks) $ 0.00 per monthly pay period.
REMITTANCE INFORMATION: You must begin withholding no later than the first pay period occurring ten (10)
working days after the date of this Order/Notice. Send payment within seven (7) working days of the paydate/date of
withholding. You are entitled to deduct a fee to defray the cost of withholding. Refer to the laws governing the work
state of your employee for the allowable amount. The total withheld amount, and your fee, cannot exceed 55% of
the employee's/ obligor's aggregate disposable weekly earnings. For the purpose of the limitation on withholding,
the following information is needed (See #9 on page 2).
If required by Pennsylvania law (23 PA C.S. § 4374(b)) to remit by electronic payment method, please call
Pennsylvania State Collections and Disbursement Unit (PA SCDU) Employer Customer Service at 1-877-676-9580
for instructions. PA FIPS CODE 42 000 00
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PAYMENTS MUST INCLUDE THE DEFENDANT'S NAMEAND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BY THE COURT: /\,a,• /*
VINNA. HESS, JUDGE
DRO: R.J. SHADDAY / Form EN-028 Rev. 4
Service Type M OMB No.: 0970-0154 Worker ID $IATT
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
If hecke l you are required to provide a opy of this form to your employee. If yoyr employee works in a state that is
di Brent rom the state that issued this o er, a copy must be provided to your emp ogee even if the box is not checked
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employeelobligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employee/obligor.
3.* Reporting the Paydate/Date of Withholding: You must report the paydate/date of withholding when sending the payment. The
paydate/date of withholding is the date on which amount was withheld from the employee's wages. You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below. 1905100188
THE PERSON HAS NEVER WORKED FOR THIS EMPLOYER : ED THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 0
EMPLOYEE'S/OBLIGOR'S NAME:KRUG, KARL L.
EMPLOYEE'S CASE IDENTIFIER: 9454100578
LAST KNOWN HOME ADDRESS:
LAST KNOWN PHONE NUMBER:
DATE OF SEPARATION:
FINAL PAYMENT AMOUNT-
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Antidiscrimination: You are subject to a fine determined under State law for discharging an employeelobligor from employment,
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9.* Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (CCPA) 0 5 U.S.C. 1673 (bp; or 2) the amounts allowed by the State or Tribe of the employee's/obligor's principal place of
employment. Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes, Social
Security taxes, statutory pension contributions and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is
supporting another family and 60% of the disposable income if the obligor is not supporting another family.However, that 50% limit is
increased to 55% and that 60% limit is increased to 65% if the arrears are greater than 12 weeks. If permitted by the State, you may
deduct a fee for administrative costs. The support amount and the fee may not exceed the limit indicated in this section.
Arrears greater than 12 weeks : If the Order Information does not indicate whether the arrears are greater than 12 weeks, then the
employer should calculate the CCPA limit using the lower percentage. For Tribal orders, you may not withhold more than the amounts
allowed under the law of the issuing Tribe. For Tribal employers who receive a State order, you may not withhold more than the lesser of
the limit set by the law of the jurisdiction in which the employer is located or the maximum amount permitted under section 303(d) of the
CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State law, you may need to take into consideration the amounts paid for health
care premiums in determining disposable income and applying appropriate withholding limits.
10. Additional info:
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the law of the state
that issued this order with respect to these items.
11. Send Termination Notice and
other correspondence to:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717) 240-6248 or
by internet www.childsupport.state.pa.us
Page 2 of 2 Form EN-028 Rev. 4
Service Type M OMB No.: 0970-0154 Worker ID $IATT
N ?
ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: KRUG, KARL L.
PACSES Case Number 053102436
Plaintiff Name
LISA L. KRUG
Docket Attachment Amount
00-6961 CIVIL$ 0.00
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
Addendum
Service Type M
OMB No.: 0970-0154
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s): DOB
Form EN-028 Rev. 4
Worker I D $ IATT
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