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Home My WebLink About00-07645 . . .. . . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . PENNA. STATE OF JAY E. SNYDER, . NO. 00-7645 CIVIL TERM Plaintiff . VERSUS PAULA L. SNYDER, Defenn"nt DECREE IN DIVORCE AND NOW, :r~ 3 ~ sao,,/'1 . 2001 IT IS ORDERED AND , DECREED THAT J;,y F. Rnyrlpr , PLAINTIFF, . . Paula L. Snyder , DEFENDANT, AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None . ~.,. ; ,'.',' ~~.. .., .. \ . .... " . -.-' .. ./ " - - / ~ .1 _/'-'" : ' '.-./ ., , ". \... :; ~...: . r-'--;~ '" ~'''''''': RY . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . . . ~ l.....", , , - ' . ,'-''''- " "'-~, i 7.FcJl 7c5-,()/ "- .~ ~ ,. dJ-e'~~~'~~ 14~/U~ ~~~ ,~ ~~"""!lIl In I,~, , ~fi,OOM~~!<,,~ ..,4",~ ,,0.., ~<- ~II:W> - _ "I .,~= - , .,- r_ . JAY E. SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 00 - 7645 CIVIL PAULA L. SNYDER, Defendant IN DIVORCE o f; ~ 1-,.. "1:'" ~~. ~~?--\ '<: .~~! ?;;o 6() J>r ~. ~ -<. MASTER'S REPORT Proceedings held before E. Robert Elicker, II, Divorce Master 9 North Hanover Street, Carlisle, Pennsylvania proceedings held on May 15, 2001, commencing at 9:30 a.m. APPEARANCES: Marylou Matas AttoTney for Plaintiff Matthew J. Eshelman AttoTney for Defendant c'), :"ilMiI~..."'''''"''- ~: ::~: J:~ (I, -0 .~- -~,... . , ();:.;, ~~: i~;,) :':':::1 ~ ::<: ....:> ,'" =~ I - ".,',- '~~.- --l~:~;' JAY E. SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 00 - 7645 CIVIL PAULA L. SNYDER, Defendant IN DIVORCE REPORT OF THE MASTER THE MASTER: Today is Tuesday, May 15, 2001. This is the date that was set to have a pre-hearing conference with counsel; however, the Master, after reviewing the file yesterday, determined that it would be appropriate to bring the parties into the hearing room inasmuch as the Master does not find that the pleadings offer him much of an opportunity to distribute property or to make any other findings which the Master will later comment on in this report. The parties are present today at the request of the Master and Jay E. Snyder, the plaintiff is represented by Marylou Matas and the Defendant, Paula L. Snyder, is represented by Matthew J. Eshelman. This action was commenced by the filing of a divorce complaint on October 27, 2000. The complaint raised grounds for divorce of irretrievable breakdown of the marriage. At the time the complaint was filed, the 1 ~ J -';0-. -0", rr....-....'""""'"' 'f;~ Plaintiff was residing at 769 Hamilton Court, Carlisle, Cumberland County, Pennsylvania, and Defendant was residing at 151 North Middlesex Drive, Carlisle, Cumberland County, Pennsylvania. Counsel have indicated that the parties still reside at the addresses stated in the complaint. The parties were married on November 1, 1997, in Cumberland County, Pennsylvania, and separated in October 1998. The Defendant on December 12, 2000, filed a petition raising economic claims of equitable distribution, alimony, alimony pendente lite, and counsel fees and expenses. The Plaintiff filed a petition for counsel fees and expenses on January 18, 2001. The Plaintiff filed on October 27, 2000, an affidavit under Section 3301(d) of the Domestic Relations Code averring the separation in October 1998 and further stating that the parties have continued to live separate and apart since that time. The affidavit also alleged that the marriage is irretrievably broken. The Defendant on December 12, 2000, filed a counter-affidavit indicating that she did not oppose the entry of a divorce decree but that she wished to raise economic claims. Those claims, as noted, have been raised by petition. The Master was appointed on January 18, 2001, and was directed to consider all pending claims which 2 - -. l ,h 1_ " have been raised by the parties. The Master upon appointment sent certification documents regarding discovery to counsel and both counsel indicated that discovery was complete. Consequently, on February 15, 2001, the Master sent a letter to counsel directing the filing of pretrial statements which were to have been filed on March 12, 2001. The Plaintiff filed a pretrial statement on March 12, 2001; the Defendant has not filed a pretrial statement. The Plaintiff also filed an inventory and appraisement and an income and expense statement; the Defendant has filed neither an inventory and appraisement nor an income and expense stqtement. According to ~he pretrial statement filed by the Plaintiff, there are no marital assets to be distributed and the Defendant has not identified any marital assets to be distributed so, therefore, the claim for equitable distribution is denied. with respect to the claim for alimony, Mr. Snyder filed an income statement showing net pay from Carlisle Tire and Wheel on a weekly basis of $328.89. That net pay would be increased by spousal support which is noted on the deduction part of the statement in the amount of $103.54. Consequently, the net income weekly of husband, adding in the spousal support, would be $431.43. The Defendant has not filed an income statement so the 3 .: . '. I,. 1< "'.........~ ..' "~,,;;',1 " Master can make no conclusions regarding income of the Defendant. , Consequently, without any information in the record to show income as required in the rules, the Master is going do deny the Defendant's claim for alimony, Both parties have filed requests for counsel fees and expenses. The Master is going to deny both claims for counsel fees at this time; however, in the event this matter is further delayed or is returned to the Master, the Master will consider the counsel fee issue. with respect to grounds for divorce, the parties having been separated for a period in excess of two years, the Master finds that the husband is entitled to a divorce under Section 3301(d) of the Domestic Relations Code. RECOMMENDATIONS The recommendations of the Master are that the divorce proceed under Section 3301(d) of the Domestic Relations Code based on a separation in excess of two years, that the claims for equitable distribution and alimony be denied as well as the claims of both parties for counsel fees and expenses be denied. 4 . . I '. I~ '."[ "" J ro' -'.~"~- A copy of this report will be filed with the Prothonotary with a notice sent to counsel and the parties of the filing, and the parties and counsel will have ten (10) days from the date of the mailing to file exceptions to the Court raising whatever issues that they feel are appropriate to be heard by the Court on appeal. (A discussion was held off the record.) THE MASTER: Mr. Eshelman has indicated that he would like the record to note that a letter was sent to the Master dated May 3, 2001, indicating why a pretrial statement was not filed in this case. The letter, however, further stated that "It is not, however, Ms. Snyder'S intention to litigate any issues affirmatively." Therefore, the Master concluded that the Defendant was simply delaying the proceedings without any intention of participating or cooperating. Respectfully submitted, f)JJ&;t~-4 E. Robert Elicker, II Divorce Master 5 j.. , i . I, j '"--'- '., JAY E. SNYDER, Plaintiff VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PAUlA L.SNYDER, Defendant NO. 00- 7645 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divorce decree: I 1. Ground for divorce: 3301 (d)(1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: November 1, 2000 by certified mail restricted delivery 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by 93301 (c) of the Divorce Code: by plaintiff ; by defendant (b) (1) Date of execution of the affidavit required by 93301 (d) of the Divorce Code: October 27~ 2000 (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 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: See attached Mast:!'>r I s R"'pnrt r'l"j-"" Mi'ly 10:;. ?001 (b) Date of plaintiff's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: Date defendant's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: Marylou Matas, ~!i: ~,tVt~ Esq., ttorney for Plaml1fl ~t 1lfJ,.-" '~'F--'.: "''''' --~ .~,,,,,,,,,,,~~,t<.,,,.i~~...,~liiIiillilmlWlllW~' =-~~, ~..- '",,"',1'''.''"''_ 'r, .~ ,,~, .- .~ -~ "^ ~ ;,- """"'~'" ~I 0 C '---- C .-,'! Z f_ -0 ct; c::: ,'\ .~:~ rnrn "';~:: :~C': Z-;..-c: ;'"J :;2':1:;.'. <.:P ; , l~) 0) "':.:.: ,,<'c. , r;:CJ """'J ::."~:~~ "- :1:: l:;o- .....~, ~~~ .;;;,.-;: p-, ~ 'e'c" ~ (.\'1 :0 c::> -< -, .', j~ h _, ,~I" -,- "-'-"'--'0 ,---~, 'l1id:'ii -. i .--' \ JAY E. SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVlI.NIA : Vs. : NO. 00 - 7645 CIVIL PAULA L. SNYDER, Defendant IN DIVORCE ~ o = ~ . -~ - ~ ',_1 '." ~' '=::-= --~ -- --~-,--- - - -- - '.._-, "-- -- ---- ---- - ---- tT:';;:: ~.- C\..; - ?" :;.:-:, ~Q ~'"':-'-'-G,.'n . _-=-=-~-='~~.=-~:~~_;:.:~.:.:..:..;=-- ,__'-~"::-~-=~~~,~~~:o-~-',;::...._:..~=~;~,-' -=~=--,o_:'~ ..::::...o~~-~-:---= -:.~_-:;- _.-- ~:",,~:;~j~~--~,,~=-~,,=__ .. . ,."," --C'. --,~ ...,~.. . "n~__......._,.._.._.., ~ ,.,;., ~. .. un., , .. .. "~'-<;~~',.o) n~... ... ~ ~'-, -;-., MASTER'S REPORT - '~----.--:-'r--'-~--:~- ,-..'-.-' -..-~-,-. ..-'---.,.-~.~-~. - ....,,- - --------,,-,- . Proceedings"'held nbefore .. E.Robert .?lickeJ:' II~Di"orceMaster Un" . 9 Norih HanoverStreet.Carlisle~n,Pennsylv~a:__. proceedings held on May 15, 2001, commencing"'i:tt. 9:30 a.m. APPEARANCES: Marylou Matas Attorney for Plaintiff Matthew J. Eshelman Attorney for Defendant. , ['" .; .1 ~~,'~-~ , t~I'~' - JAY E. SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 00 - 7645 CIVIL PAULA L. SNYDER, Defendanc IN DIVORCE REPORT OF THE MASTER THE MASTER: Today is Tuesday, May 15, 2001. This is the date that was set to have a pre-hearing conference with counsel; however, the Master, after reviewing the file yesterday, determined that it would be appropriate to bring the parties into the hearing room inasmuch as the Master does not find that the pleadings offer him much of an opportunity to distribute property or to make any other findings which the Master will later comment on in this report. The parties are present today at the request of the Master and Jay E. Snyder, the plaintiff is represented by Marylou Matas and the Defendant, Paula L. Snyder, is represented by Matthew J. Eshelman. This action was commenced by the filing of a divorce complaint on October 27, 2000. The complaint raised grounds for divorce of irretrievable breakdown of the marriage. At the time the complaint was filed, the 1 ~- , -'~ Plaintiff was residing at 769 Hamilton Court, Carlisle, Cumberland County, Pennsylvania, and Defendant was r d - esi ing at 151 North Middlesex Drive, Carlisle, Cumberland County, Pennsylvania. Counsel have indicated that t~e parties still reside at the addresses stated in the complaint. The parties were married on November 1, 1997, in Cumberland County, Pennsylvania, and separated In October 1998. The Defendant on December 12, 2000, filed a petition raising economic claims of equitable distribution, alimony, alimony pendente lite, and counsel fees and expenses. The Plaintiff filed a petition for counsel fees and expenses on January 18, 2001. The Plaintiff filed on October 27, 2000, an affidavit under Section 3301(d) of the Domestic Relations Code averring the separation in October 1998 and further stating that the parties have continued to live separate and apart since that time. The affidavit also alleged that the marriage is irretrievably broken. The Defendant on December 12, 2000, filed a counter-affidavit indicating that she did not oppose the entry of a divorce decree but that she wished to raise economic claims. T~ose claims, as noted, have been raised by petition. The Master was appointed on January 18, 2001, and was directed to consider all pending claims which 2 1- " ,I, , .,.! Ll" -~~'- ~~ have been raised by the parties. The Master upon appointment sent certification documents regarding discovery to counsel and both counsel indicated that discovery was complete. Consequently, on February 15, 2001, the Master sent a letter to counsel directing the filing of pretrial statements which were to ~ave been filed on March 12, 2001, The Plaintiff filed a pretrial statement on March 12, 2001; the Defendant has not filed a pretrial statement. The Plaintiff also filed an inventory and appraisement and an income and expense statement; the Defendant has filed neither an inventory and appraisement nor an income and expense statement. According to the pretrial statement filed by the Plaintiff, there are no marital assets to be distributed and the Defendant has not identified any marital assets to be distributed so, therefore, the claim for equitable distribution is denied. With respect to the claim for alimony, Mr. Snyder filed an income statement showing net pay from Carlisle Tire and Wheel on a weekly basis of $328.89. That net pay would be increased by spousal support which is noted on the deduction part of the statement in the amount of $103.54. Consequently, the net income weekly of husband, adding in the spousal support, would be $431,43. The Defendant has not filed an income statement so the 3 , ,J - ~~ Master can make no conclusions regarding income of the Defendant. Consequently, without any informacion in the record to show income as required in the rules, the Master is going do deny the Defendant's claim for alimony. Both parties have filed requests for counsel fees and expenses. The Master is going to deny both claims for counsel fees at this time; however, in the event chis matter is further delayed or is returned to the Master, the Master will consider the counsel fee issue. With respect to grounds for divorce, the parties having been separated for a period in excess of two years, the Master finds that the husband is entitled to a divorce under Section 3301(d) of the Domestic Relations Code. RECOMMENDATIONS The recommendations of the Master are that the divorce proceed under Section 3301(d) of the Domestic Relations Code based on a separation in excess of two years, that the claims for equitable distribution and alimony be denied as well as the claims of both parties for counsel fees and expenses be denied. 4 " '~,i, J' 1"'-" ".~ -- " L 'J ,L ~~ -'" "'"':" '-~ A copy of this report will be filed with the Prothonotary with a notice sent to counsel and the parties of the filing, and the parties and counsel will have ten (10) days from the date of the mailing to file exceptions to the Court raising whatever issues that they feel are appropriate to be heard by the Court on appeal. (A discussion was held off the record.) THE MASTER: Mr. Eshelman has indicated that he would like the record to note that a letter was sent to the Master dated May ~, 2001, indicating why a pretrial statement was not filed in this case. The letter, however, further stated that "It is not, however, Ms. Snyder's intention to litigate any issues affirmatively." Therefore, the Master concluded that the Defendant was simply delaying the proceedings without any intention of participating or cooperating. Respectfully submitted, {;etc&'vt~ - E. Robert Elicker, II Divorce Master 5 1_, ~_ I -,L "~.~ -- . JAY E. SNYDER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW : NO. 01). 7{P~S : IN DIVORCE CIVIL TERM v. PAULA 1. SNYDER, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case will proceed without you and a decree of divorce or annulment may be entered against you for any 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 Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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 Two Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 _J ~= JAY E. SNYDER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA I : CIVIL ACTION - LAW v. PAULA 1. SNYDER, Defendant : NO. ['-0 - 11. 'IS : IN DIVORCE CIVIL TERM COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is Jay E. Snyder, an adult individual currently residing at 769 Hamilton Court, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Paula 1. Snyder, an adult individual currently residing at 151 North Middlesex Drive, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on November 1, 1997, m Gardner, Cumberland County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. jf J .~-~- 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. S3301(d) of the Domestic Relations Code. Respectfully submitted, GRIFFIE & ASSOCIATES ~~tt~::e Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 " ~ l.- . fllIollJllJlJiJ..il!!i_ VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. DATE: .Iv lpn / ~~_~~~*ii'jf.~~ii~~--II~(l rlL;l'~~~~~lIIlillJ .( ~ d"~~-'---"~'-y'-- I lIIiliIliilli' '" ". ' ;,i il I' I I i I 'I I I I I i I I I I I I I "'. ~ g ~ !:;? ~ ~ ~ ~j <::) \ n :;:} &, -i N:~::!) ~~ '" ,-: 't ~. ~ ~ ""-J ~-f~ P:; C)y ~8 '"l:I i!"t ~ '\ \ :JI: c.,:ti -. ~ :i>c.: ~ -:?of"') ~ ~ Om ~ c:- ?g ~ , co . -< ~ ~ W "~". __ - ~__1' _ ..' '.. - ,-., .1 ,~ 0 > ~""""""'~='" JAY E. SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW PAULA 1. SNYDER, Defendant : NO. 00-7645 CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this 3'd day of November, 2000, comes Marylou Matas, Esquire, Attorney for Plaintiff, and states that she mailed a certified and true copy of a Complaint in Divorce to the Defendant, Paula 1. Snyder, at 151 North Middlesex Drive, Carlisle, Cumberland County, Pennsylvania, by certified mail, restricted delivery, return receipt requested. A copy of said receipt is attached hereto indicating service was made on November 1, 2000. ~~7ff~ Marylou Mata sqUIre Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 Sworn and subscribed to befor~e this .2E!- day of ~ tmttCr , 2000. Jj!a~ TARY I Notarial Seal Ka~isa J. Lehman, Notary Public Carlisle 80m, Cumberland County My Commission expires Aug. 25, 2003 '..-'U-- r .~ ~I , Complete Items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. !- Print your name and address on the reverse . 50 that we can return the card to you. '. Attach this card to the back of the mailpiece, or on the front if space permits. o Agent o Addressee ':::.~,:"..:.::" \g:: 1. p;;I~Tt SY\~(UV /61 N()(th filidd/~x /)rive' Cavlf~'( PA- 110I,? I 3.~ice Type Dr: ~Certified Mail 0 Express nc.SJ; o Registered 0 Return Rec" o Insured Mail 0 C.O.D. U. 4. Restricted Delivery? (Extra Fee) 2. Article Number (Copy from service label) "7rJOO (){MJO 0021 ,PS Form:381 1, Juiy 1999 Domestic Return Receipt ,1, I Z. LJ( p<jjCf 102595-o0-M.0952 - ~ .~---------- -,,---~---'--',.~-,-_. --~.,------ ----- IT" c(] ..n ;;:I' ru .-'l m ~ Return Receipt Fee ; (Eo'ms,moo' ",qe",d) Postage $ Certified Fee Restricted Delivery Fee (Endorsement Required) Cl t:J Total Postage & Fees ..n Cl Cl Cl Cl r'- .",- ~~;~'" .j. t<,: : h^,j~ - "'~~1I!:L8r'-.4.~~j?f~-";':'!I~.-M}J.'~I~t:;~'iS" ,> " -~ -~ '"' ,~~- ., ~ ~ ) } ) ) ."~ ",'c".i.i, "I!IlllOi 00' , li .llll.>lf' -.'1" 'J"'''' , \ ( , '00"''-'"'-''' n" \ , \ o C C c s: :-< -OeD ( -'-' norn Z:TI ~s:: 'i -,<2- r::O ,.. :zO ~2 i' :z; --',- .1 ,:~/ :(: C') ;~::ifn ::} 5:J -< ~ ~ I i' J I - - -~."~ "I,liI:iiillillljllihIIi1MiII~"'~~' @tRUGUNAIL. JAY E, SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. m- )(Pl/S : IN DIVORCE CIVIL TERM PAULA 1. SNYDER, Defendant COUNTER AFFIDAVIT UNDER ~3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): ___x (a) (b) I do not oppose the entry of a divorce decree. I oppose'the entry of a divorce decree. (Check either (i), (ii), or both) (i) The parties to the action have not lived separate an apart for a period of at least two (2) years. _ (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): ...,p- (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses ~' V' if! do not claim them before a divorce is granted. A- (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If! fail to do so before the date set forth in the notice of intention to request mv:arce decree, the divorce decree may be entered without further delay, I verify that the statements made in the foregoing document 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 falsifications to authorities. DATE: tz- z-otJ ~~~. AULA L. SNYDER, Detendant IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER AFFIDAVIT. :~~~;"~i'il~" j ~. :"', ", - ,"",^ , ~~- l~"iwiL:~';";"ii'~L'i.Mi~n''''''~ ~llut1lJ~~~~~illliil "'~, I, ;:\ M11i.0M;IQl'.' :;;'-- t..--.J l.,-itJ 1,( l..r!J1J ...nJ!: 0< .'~ n_jMtllJiji . ~. "T~;'..' .'., . (') 0 0 C 0 -n :? <:::J -~ ""00:1 fT1 ~ mnl CJ , Z::D ~B23 zc N ~$:. i.~t~ !;'.:c::: "CJ )>r-. :x ~l-) - ql" ;J> ,- .. ~.- :;: 7' :n ~ ::0 UI -< , li 1-- , "," '.v. , -,.-:--2.:1'" .;.1 .1",'. . Hl05.157 REV. 8-80 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT Of HEAcrH VITAL RECORDS 00- 7t.l.fS Cumberland DIVORCE lliI RECORD OF OR ANNULMENT (CHECK ONE) D STATE FILE NUMBER STATE FILE DATE COUNTY HUSBAND 1. NAME (First) (Middle) (Last) 2. DATE (Month) OF BIRTH 9 (Day) y,,, JAY EDWARD SNYDER 28 70 3. RESIDENCE Street or R.D. City, Boro. or Twp. County State 4. PLACE OF BIRTH (State or Foreign Countr)~ 427 North Hanover St. 2nd Floor 5. NUMBER 6. RACE OF THIS WHITE BLACK MARRIAGE. 1 st lliI D Carlisle Cumberland P 7. USUAL OCCUPATION PA OTHER (Specify) D WIFE Tire Builder . .. MAIDEN NAME (First) (Middle) (Last) 9. DATE (Month) (Day) Yea, OF PAUlA LOUISE KUHN BIRTH 2 17 63 10. RESIDENCE Street or R.D. City. Bora. or 7Wp. County State 11. PLACE (State or Foreign Country) OF 151 North Middlesex Drive, Carlisle Cumberland PA BIRTH PA 12. NUMBER 6. RACE 14. USUAL OCCUPATION OF THIS 2nd WHITE BLACK OTHER (Specify) MARRIAGE J[] D D Laborer 15. PLACE OF (County) (State or Foreign Country) 1.. DATE OF (Month) (Day) (year) THIS THIS MARRIAGE Cumberland PA MARRIAGE 11 1 97 17A. NUMBER OF 17B. NUMBER OF DEPENDENT 1.. PLAINTIFF . 19. DECREE GRANTED TO CHILDREN THIS CHILDREN UNDER 18 HUSBAND WIFE OTHER (Specify) HUSBAND WIFE OTHER (SpeCify) MARRIAGE n [X] D D XXI D D 20. NUMBER OF HUSBAND WIFE SPLIT CUS10DY OTHER (Specify) 21. LEGAL GROUNDS FOR CHILDREN TO D D D N/A DIVORCE OR ANNULMENT 3301 (d) CUSTODY OF 22. DATE OF DECREE (Month) (Day) (Year) 123 DATE REPORT SENT (Month) (Day) (Year) 10 VITAL RECORDS 24. SIGNATURE OF TRANSCRIBING CLERK ~, ~ -,,'-~~~ , - ~ . i-- ~'~~'" ~ '.<"""'-""",",<nc,>__ " JAY E. SNYDER, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW PAULA 1. SNYDER, Defendant : NO. t>> - 7t0~..5 : IN DIVORCE CIVIL TERM NOTICE If you wish to deny any of the statements set forth in the attached affidavit, you must file a counter-affidavit within twenty days after this Affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER ~3301(d) OF THE DIVORCE CODE 1. The parties to this action separated since October 1998 and have continued to live separate and apart since that time, 2. The marriage is irretrievable broken. 3, 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. I verify that the statements made in the foregoing document 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 falsifications to authorities. , _j~f ~'.1 ~ II "~~ni.Ur~~~iIDt!ll!ill'%'klif0ii'1-"~'i"";J"~4"jjj:li.mmdMl.;i " ,,' -~ - ='M~l~ lkJmilil:C"'~-~'" .j--",,"" j ,'I>,; ,", (") 0 >?, ~ 0 :s. 0 9iffl n :.:;:1 -t .~.;i# t;i.~ N ~,..., I"'rJ ~e -.J 0~ 18 -0 =j:f-rj ::J!: p::!J ~ 6P. ~ en. ~ '" -< '" " 'd' " "1 Ii I Ii " I I I I L~: I ~~ J I ''" ~ 4,--1 -... " JAY E. SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, NO. 00 - 7645 CIVIL PAULA L. SNYDER, Defendant IN DIVORCE NOTICE OF FILING MASTER'S REPORT The report of the Master has been filed this date and copies have been sent with this notice to counsel of record and the parties. In accordance with P.R.C,P. 1920,55 within ten (10) days after the mailing of this notice and report exceptions may be filed to the report by any party, If no exceptions are filed within the ten (10) day period, the Court shall o c> c receive the report, and if approved, shall enter a~~na~; ~[T :~( decree in accordance with the recommendations cont~ed~~n -<L_ t<o -0' the report. ~8 = ~!ll~ ,: " ~ '.-"....' -:'"~ j-'I ~_i ):~: ':0 ::< Date: 5/15/01 E. Robert Elicker, II Divorce Master NOTE: If exceptions are filed, file the original with the Prothonotary and a copy with the Master's office. At that time, the party filing the exceptions should notify the court reporter in the Master's office so arrangements can be made for a transcript. Upon completion of the transcript and receipt of payment, the entire file will be returned to the Prothonotary's office for transmittal to the Court at time of argument on the exceptions. .... Ail " I ~'" >" - . ~ '''-'--'"i: -"!' If no exceptions are filed, counsel shall prepare an order of Court consistent with the recommendations and provide a proposed order of Court to the Master. Counsel shall also prepare and provide with the proposed order of Court a praecipe* to the Prothonotary directing the Prothonotary to submit the case to the Court for final disposition. The Master will then transfer the file with the proposed order of Court and praecipe to the Prothonotary's Office for docketing and transmittal by the Prothonotary to the Court. * Form available in the Prothonotary's office and the Master's office, (NOT the praecipe to transmit the record form as set out in P.R.C,P, 1920.73(b).) ;1;W11ll!l ","",",I. ", 1 ,I ~~,,~ ~ JAYESNYDER ll.lI'~<l-l!l,."M_""';,}, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. PAULA 1. SNYDER CIVIL ACTION - LAW 00 - 7645 CIVIL NO. CIVIL : IN DIVORCE Defendant STATUS SHEET DATE: 19 t1 : ~l> c. ' . ~ ~~ ,,' , '<. -', "I'" ....1 I" . -,~ ,~ < J .".. ~' 'h' -., .," "Jih>': JAY E. SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00 - 7645 CIVIL PAULA L. SNYDER, Defendant IN DIVORCE TO: Marylou Matas Attorney for Plaintiff Matthew J. Eshelman Attorney for Defendant DATE: Thursday, February 1, 2001 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. ."'.J~ , ,~ J. " , . "jJ~ J ~ .l-~ ,'. _',. L ,,' ~~iM;;;'. ,.. (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. -- ~~ ,,~-- . L. L 1,,- "' ^ '. ',,',;.,.C'; ',,,;,,,.,,,, "!;[,. 8 S. Hanover Street Carlisle, PA 17013 (717) 249-6971 THE LAW OFFICES OF PATRICK F, LAUER, JR. 2108 MARKET STREET, AZTEC BUILDING CAMPHILL,PENNSYLVANlA 17011 (717) 763-1800 FAX (717) 763-4247 1-800-822-4-LAW 932 N, Second Street Harrisburg, PA 17102 (717) 232-7747 Patrick F. Lauer, Jr., Esq.' Matthew J. Eshelman, Esq.t Marlin L. Markley, Esq. Reply to Camp Hill Address www.dui-na.com Dictated: April 27, 2001 Transmitted: May 3, 2001 E, Robert Elicker, II, Esquire 9 North Hanover Street Carlisle, PA 17013 RE: Snyder v. Snyder 00-7645 Dear Mr. Elicker: Ki~dlyacceptthis correspondence as an abbreviated pre-trial statement under Rule 1920. This ~orrespondence is sent rather than the full court documentation for two reasons: First, I apologize for the belated and abbreviated nature of the correspondence. However, my office was taken by surprise with the early arrival of a baby boy, who remains in N.I.C.D. Many items of correspondence were pushed to the "back burner." Second, the defendant has indicated that she is not in a position financially to generate lengthy court documents. Ms. Snyder is receiving spousal support. However, as the defendant in the matter, I submit she is under no obligation in Cumberland County to pursue the divorce. She does not concede the issues set forth and will be represented at the pre-hearing conference currently scheduled for May 15, 2001 at 9:30 a.m. It is not, however, Ms. Snyder's intention to litigate any issues affirmatively. In all other respects, Mr. Snyder's pre-trial documents are accepted and! or adopted as accurate. In the meantime, if you have any questions or concerns, please do not hesitate to contact my office. MJE/~~m . . . cc: . Paula. Snyder Marylou'Matas, Esq. Sincerely yours, Matthew 1. Eshelman, Esquire. .. }- ~9~ . Board Certified as a Criminal Trial Advocate by the National Board of Trial Advocacy t Board Certified in Consumer Bankruptcy Law by the American Board of Certification ,';" , , ""e,n'~ .' _ 1'<:",'" ,',-o~ ',,~",.' ';,cw__I,""",~~,,,,t;",,,;d"'\,,L~",~<'E"";'_";' i ,'" L. , ;: :' .~"j."~,,;J,: .;, -'I(,\.:~'"-,, ","c..",'... ',;"", >,,_ <,.,';.'''. . '~" ~';" ;~, ":L"-,"",",:,',,,, "",.-~ _ '~' . -' OFFICE OF DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEAS 9 North Hanover Street Carlisle, PA 17013 (717) 240-6535 E. Robert Elicker, II Divorce Master Traci Jo Colyer Office Manager/Reporter West Shore 697-0371 Ex!. 6535 February 15, 2001 Marylou Matas Attorney at Law GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 Matthew J. Eshelman, Esquire PATRICK F. LAUER, JR. 2108 Market Street Aztec Building Camp Hill, PA 17011 RE: Jay E. Snyder vs. Paula L. Snyder No. 00 - 7645 Civil In Divorce Dear Ms. Matas and Mr. Eshelman: I have received the certification documents regarding discovery from counsel and both counsel are in agreement that discovery is complete. Therefore, I am going to proceed with the directive for pretrial statements. A divorce complaint was filed on October 27, 2000, raising grounds for divorce of irretrievable breakdown of the marriage, No economic claims were raised in the complaint. Filed with the complaint was an affidavit under Section 3301(d) of the Domestic Relations Code averring that the parties separated October 19, 1998, a period in excess of two years. Consequently, there does not appear to be any issues with respect to grounds for divorce. ~~,J .-- I , '. ~ , ' . ~ ii.,>. Ms. Matas and Mr. Eshelman, Attorneys at Law 15 February 2001 Page 2 On December 12, 2000, the Defendant filed a petition raising economic claims of equitable distribution, alimony, alimony pendente lite, and attorney fees and costs and expenses. The Defendant also filed a counter- affidavit indicating that she wished to raised economic claims which were raised with the filing of the petition on the same date. In accordance with P.R.C,P. 1920.22(b) I am directing each counsel to file a pretrial statement on or before Monday, March 12, 2001. Upon receipt of the pretrial statements, I will immediately schedule a pre-hearnig conference with counsel to discuss the issues and, if necessary, schedule a hearing. Very truly yours, E. Robert E!icker, II Divorce Master NOTE: Sanctions for failure to file the pretrial statements are set forth in subdivision (c) and (d) of Rule 1920.33. THE ORIGINAL PRETRIAL STATEMENT SHOULD BE FILED IN THE MASTER'S OFFICE AND A COpy SENT DIRECTLY TO OPPOSING COUNSEL. FAILURE TO FILE PRETRIAL STATEMENTS AS DIRECTED BY THE MASTER MA Y RESULT IN THE MASTER'S APPOINTMENT BEING V ACA TED. 3i:~ .1' ~ 'k'.:" ~."'- L, ',> "I~ .~'~ " . ~-" ,""~ Ai' GRIFFIE & ASSOCIATES Attorneys and Counselors At Law Bradley L Griffie, Esquire Marylou Matas, Esquire ZOO North ilanDver Street CarlIsle, PA 17013 (717) 243-5551 1(800)347-5552 Robin J. Goshorn Legal Assistant Reply to: Carllde 3SNorihMalnStreet a-benInlrl>PA 17Z01 (717) 267-1350 Fas (717):143-5063 March 12,2001 E. Robert Elicker, II, Esquire 9 North Hanover Street Carlisle,PA 17013 RE: Synder v. Snyder No, 00-7645 Dear Mr. Elicker: Enclosed is a copy of the Plaintiffs, Jay Snyder, Pre-Trial Statement, Inventory and Appraisement, and Income and Expense Statement. Very truly yours, /r{~~ 1f(k Marylou Matas MM/kjl cc: Jay E. Sndyer Matthew 1. Eshelman, Esquire - i ,,1. L' ,I .. _1." .,,,,--" ~ '". '!' 'il~1" .~; JAY E. SNYDER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW PAULA 1. SNYDER, Defendant : NO. 00-7645 CIVIL TERM : IN DIVORCE ORDER APPOINTING MASTER bf'" C AND NOW this I () day of ,2001, E. Robert Elicker. II. Esquire, is appointed Master with respect to the ollowing claims: f2l1-/ ,.. cc: Marylou Matas, Esquire Attorney for Plaintiff BY THE COURT, ~ ~ {\ . ~ l-~ 10.0\ 0\- 0 ?-~ 1fJ. Matthew J, Eshelman, Esquire Attorney for Defendant p\a.ced. \1-.1 t.\'\c.~e.rs+i\e oH1'OI :". "., , " ' , , ~"" <, "' " - ~, ~, - ,~ ~' F:111f1lll~_ l~,1:II!!lfill ". ____ '>,_ . 'd ^,~ & ,<, ,", --"~,, .--~ .'-, ."~ .,.,'.--'" '" -' - .~ '"'<,,,,",,r_ H-'." Pi! cfl-(i>:f\CE , ,~L_. n'IO-A"Y OF TH~~ FPi)'Jl Jl~f, Ir,n 0\ JAW 18 PM 3: 29 CUM~~~~~-ITY ,F~: ..~W'Mi"l-'!'#!H";Fl1WiWttj!"",~:m:;~~~~ffiili-!!f;\P,*;flii')I,'::-iWft'~":l~~ . , , ..<, J" ..I ;;-'liMliiII~~1i". JAY E. SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW PAULA 1. SNYDER, Defendant : NO. 00-7645 CIVIL TERM : IN DIVORCE MOTION FOR APPOINTMENT OF MASTER AND NOW come Plaintiff, Jay E. Snyder, by and through his attorney of record, Marylou Matas, Esquire, and moves the court to appoint a Master with respect to the following claims: (x) ( ) (x) (x) Oivorce Annulment Alimony Costs and Expenses (x) ( ) (x) (x) Distribution of Property Support Counsel Fees Alimony Pendente Lite and in support of his Motion states: 1. Discovery is complete as to the claims for which the appointment of a Master is requested. 2. The Defendant has appeared in this action by her attorney, Matthew J. Eshelman, Esquire. 3. The Statutory grounds for divorce are 23 Pa.C,SA 3301(d) or 3301(c). 4. An agreement has been reached with respect to the claim that the parties have been separated for at least two years, This action is contested with respect to the claims of equitable distribution and economic relief. 5. The action does not involve complex issues oflaw or fact. 6. The hearing is expected to take one day. 7. Additional information, if any, relevant to the motion: '- .J I" ..I. iiIliIiIloW" ,~ " illl!tllH".liIlml-""L a.) The parties to the action were married on November I, 1997, b.) The parties to the action separated on October 1, 1995. c.) Defendant filed a claim for spousal support on November 23, 1995, d,) On January 5, 1999, an Order for spousal support was entered against Plaintiff in the amount of $450.00 per month. e.) Plaintiff has paid this amount for two years. f.) Defendant is currently employed by Carlisle Tire and Wheel and has been so for more than one year. g.) Defendant has failed to respond to Plaintiff s repeated requests to identify any marital assets that may exist. h.) Plaintiff avers that no marital assets exist. i.) Defendant's lack of response is an indication of her intention to allow more time to pass so that she may collect additional spousal support, j.) Plaintiff has filed a Petition for Counsel Fees, Costs, and Expenses contemporaneously with the filing of this Motion, Respectfully submitted, 1'~~~&, 7YlJ-M Mary. tas, EsqUire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (SOO) 347-5552 >' "'~-.i:~.~~i~~~,ffi~~~~:lf~)M::.~fl~ .,,.~',U':'C",, ~,,'~, .;;.~, .~ '.' ~~"."i "~i~liIIliri' "",~,, , ,,' ,"~' ~'~"~''''~'~ "i (') 0 0 ,- >- ~ ~- ~OJ )' ~E;g fit- Z ::c , ~r- :823 J~ co C)~ 2""- .''''1., 0 "'1:] -'C 1. '< l):TI ~b :::;I: ZO >0 - Om ~ ., ?6 w ~ '< ~ "~I , JAY E. SNYDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . . vs. . CIVIL ACTION - LAW . . . PAULA L. SNYDER, . NO. 00-7645 CIVIL TERM . Defendant . IN DIVORCE . DEFENDANT'S SUBSEOUENT PETITION UNDER RULE 1920.151bl The Defendant, Paula L. Snyder, through her attorneys, the Law Offices of Patrick F. Lauer, Jr., brings the following subsequent Petition under Rule 1920.15(b) and, in support thereof, avers as follows: COUNT ONE - EOUITABLE DISTRIBUTION 1. The Defendant/Petitioner is Paula L. Snyder who resides at 151 West Middlesex Drive, Carlisle, Pennsylvania 17013. 2. The Plaintiff/Respondent is Jay E. Snyder who resides at 769 Hamilton Court, Carlisle, Pennsylvania 17013. 3. The Parties hereto were married on November 1, 1997, in Gardners, Pennsylvania. 4. During the course of their marriage and subsequent to their separation, the Parties acquired property jointly and individually. 5. The Defendant/Petitioner requests this Honorable Court to equally divide all marital property of the parties. COUNT TWO - ALIMONY & ALIMONY PENDENTE LITE 6. Paragraphs one (1) through five (5) are incorporated herein by reference. 7. The Defendant/Petitioner lacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment. JI '~"&J' ., 1- .1 '1IJIlilliiOli~~:'~;f:"" , 8. Defendant/Petitioner requires reasonable support to adequately 'maintain herself in accordance with the standard of living established during the marriage. 9. Defendant/Petitioner requests the Court to enter an award of reasonable temporary alimony and additional sums as they may become necessary from hereafter until final hearing and permanently thereafter. COUN'l' THREE - ATTORNEY'S FEES. COSTS AND EXPENSES 10. Paragraphs one (1) through nine (9) are incorporated herein by reference. 11. Defendant/Petitioner has employed Matthew J. Eshelman, Esquire as counsel, but is unable to pay the necessary and reasonable attorney's fees for said counsel. 12. Defendant/Petitioner requests your Honorable Court to enter an award of counsel fees, costs and expenses as are deemed appropriate upon final hearing. WHEREFORE, the Defendant/Petitioner respectfully requests your Honorable Court to equally divide all marital property of the parties, to enter an award of reasonable temporary alimony and additional sums as they may become necessary from hereafter until final hearing and permanently thereafter, and to enter an award of counsel fees, costs and expenses to the Defendant/Petitioner. ubmitted, Date' 4f Matthew J. Eshelman, Esquire 2108 Mark t Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 1D# 72655 Tel. (717) 763-1800 jj ,~,'r. k . JAY E. SNYDER, . IN THE COURT OF COMMON PLEAS OF . Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA . . vs. . CIVIL ACTION - LAW . PAULA L. SNYDER, . NO. 00-7645 CIVIL TERM . Defendant : IN DIVORCE VERIFICATION I, Paula L. Snyder, state that I am the Defendant/Petitioner in the above-captioned case and that the facts set forth in the above Petition are true and correct to the best of my knowledge, information, and belief. I realize that false statements herein are subject to the penalties for unsworn falsificatioIll to authorities under 18 Pa. C.S. S 4940. Q0.., Q.., \. S~..~ \i Date: \,..-'<""'\00 v ,1. "~J . --, iH8iIi""- 1.1_",~Jt', JAY E. SNYDER, IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. . CIVIL ACTION - LAW . . . PAULA L. SNYDER, NO. 00-7645 CIVIL TERM Defendant . IN DIVORCE . CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Petition upon the person, and in the manner, indic:ated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of the same with the United States Post Office at Camp Hill, Pennsylvania, through first class mail, prepaid and addressed as follows: Marylou Matas, Esq. GRIFFIE & ASSOCIATES 200 North Hanover St. Carlisle, PA 17013 Date: Res itted, Eshelman, Esquire .s of Patrick F. Lauer, Jr. 2108 Mar t Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 72655 Tel. (717) 763-1800 I ." ~ J_,. . ~ ; ~~'-"'" JAY E, SNYDER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v, : CIVIL ACTION - LAW PAULA 1. SNYDER, Defendant : NO, 00-7645 CIVIL TERM : IN DIVORCE NOTICE TO PLEAD You are hereby notified to file a written response to the within NEW MATTER within twenty days (20) days from service hereof or a judgment may be entered against you. """",'c ''''''''''"'''lilitUrfM;&.(i,r: JAY E, SNYDER, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, PAULAL. SNYDER, Defendant, : CIVIL ACTION -LAW : NO. 00-7645 CIVIL TERM : IN DIVORCE PETITION FOR COUNSEL FEES. COSTS & EXPENSES 1. Your Petitioner is the Plaintiff in the above captioned divorce action initiated by the filing of a Complaint in Divorce on October 27, 2000, 2. Your Re~pondent, Paula L, Snyder, filed a Subsequent Petition Under Rule 1920.15(b) and a Counter-Affidavit, essentially consenting to the divorce, but also raising collateral economic issues of equitable distribution, alimony, alimony pendente lite, counsel fees, costs and expenses, 3. Despite Petitioner's repeated requests to identifY marital property, Respondent has not been able to so identifY, 4. The parties did not acquire property during their marriage and, most particularly, did not acquire real estate during their marriage, 5, There are no property issues or any other issues available to be argued by the Respondent. 6. Petitioner has paid $450.00 per month in spousal support to Respondent for a period of two years, a time period equal to approximately two times the length of time the parties actually cohabited during their marriage, 7. Petitioner's payment of spousal support to Respondent in the aforesaid amount represents approximately $3,300.00 overpayment in spousal support as calculated according to Domestic Relations guidelines. "",,_-0'. < 'JI.l.~;j>< 8. There are no economic issues of any nature available to be argued by Respondent and no basis for the claim of alimony or alimony pendente lite by Respondent. COUNT ONE - COUNSEL FEES 9, The averments of paragraph 1 through 8 above are incorporated herein by reference as if set forth in their full text, 10. Due to the baseless claims made by Respondent, Petitioner was required to initiate a hearing before the Divorce Master. 11. Due to the fact that Respondent has made unsubstantiated and groundless claims for economic relief, Petitioner must continue to incur attorney's fees associated with litigation, 12, Respondent is aware that there is no basis for any of the claims she has made, which have necessitated the ongoing litigation in this case, 13. While Petitioner is gainfully employed, he has expended extraordinary sums in prosecuting this case and will continue to expend sums due to the false information to which the Respondent has sworn in her Subsequent Petition. 14. There is no legal or factua1 basis for proceeding with the economic claims raised by Respondent. 15. Respondent should be responsible for Petitioner's attorney's fees in prosecuting this vexatious and obdurate action. WHEREFORE, Petitioner requests your Honorable Court to enter an Order requiring Respondent to pay Petitioner's counsel fees in these proceedings, '" -., "~ .,' "~-,,;;:,,",' '. ,," "'. 1~; COUNT n - COSTS AND EXPENSES 16. The averments of paragraph 1 through 15 above are incorporated herein by reference as if set forth in their full text. 17, The costs and expenses incurred in this case in proceeding with a Master's hearing were incurred solely due to the baseless claims and statements of Respondent. 18. Petitioner should not have been required to incur any costs associated with a Master's hearing, which occurred due to the false statements and baseless claims of the Respondent. WHEREFORE, Petitioner requests your Honorable Court to require Respondent to compensate Petitioner for any and all costs associated with prosecuting the within divorce action and related economic demands, Respectfully submitted, GRIFFIE & ASSOCIATES ~~ JY(~&a Marylou tas, Esquire Attorney for PIaintift7Petitioner 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 , ') ,''- "~,,, ';'--"',; ,~. ~ r:", l;i'i I verify that the statements made in the foregoing document 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. DATE: //;~~ / / JAY E. SNYDER, Plaintiff ; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. PAULA L. SNYDER, Defendant, : CIVIL ACTION - LAW : NO. 00-7645 CIVIL TERM ; IN DIVORCE PRE-TRIAL STATEMENT OF PLAINTIFF. JAY E. SNYDER The above named Plaintiff, Jay E, Snyder, by and through his counsel of record, Marylou Matas, Esquire, files the following Pre-Trial Statement pursuant to Pennsylvania Rules of Civil Procedure No, 1920.33(b): L LIST OF ASSETS Plaintiff's Inventory and Appraisement, in compliance with Pennsylvania Rules of Civil Procedure, is filed contemporaneously with the filing of this Pre-Trial Statement. All assets and debts known to the Plaintiff at this time are identified thereon with all relevant information required by the Pennsylvania Rules of Civil Procedure being identified in the Inventory & Appraisement. IT. EXPERT WITNESSES It is not anticipated that expert witnesses will be necessary in this case. Plaintiff reserves the right to name expert witnesses following the Pre- Trial Conference in this matter, IlL WITNESSES Plaintiff will be testifying on his own behalf in these proceedings. While Plaintiff does not have additional witnesses identified at this time, he reserves the right to name additional witnesses at the time of the Pre- Trial Conference in this matter, ""~" ",,' ~'~'~I ?r"\~1J\ ~ " ""' O'~. _~ .", ___~'"" '~'~', .,,'~. ,~, ~~' IV. EXHIBITS Plaintiff's Inventory and Appraisement will be an exhibit, as will his Income and Expense Statement in the form provided in the Pennsylvania Rules of Civil Procedure. In addition, attached hereto and incorporated herein by reference are the following exhibits, which will be presented at trial: Exhibit" A:' - Plaintiff's 2000 federal income tax return Exhibit "B" - Defendant's 2000 federal income tax return Additional exhibits may be necessary depending upon the position taken by the Defendant at the time of the Pre-trial Conference, v. GROSS INCOME See attached Income and Expense Statement VL EXPENSES See attached Income and Expense Statement. VL PENSION The pension and retirement benefit available to Plaintiff is through Carlisle Tire & Wheel, with whom he began employment in approximately September 1996, The pension and retirement benefit available to the Defendant is through Carlisle Tire & Wheel as well, with whom she began employment approximately June 1999, Plaintiff s position is that each party waive any right or entitlement that they have to the other's pension or retirement benefits, considering the limited and approximately equal value of both Plaintiff s and Defendant's benefits, '7 " 'r"',I"" """'."",; ",,',> .".,~ ',-" ~"""", ",~-'--, '" hl&1 vm. COUNSEL FEES While both parties have incurred counsel fees, it has been necessary for Plaintiff to file for the appointment of a Master in order to bring this matter to a close. The parties were married on November 1, 1997. The parties separated on October 19, 1998, less than one year after the date of marriage, During this time period, the parties did not acquire assets, nor did they incur debts. There has been no communication between the parties since the time of separation, more than two years ago, regarding any outstanding assets or obligations that must be distributed. It is Plaintiff's position that Defendant's claim for equitable distribution is meritless, Furthermore, although Plaintiff has been paying spousal support to Defendant in excess of two years and Defendant has been working full time since June of 1999, earning a monthly net income of$I,892.00, Defendant insists that she is unable to support herself. Therefore, Plaintiff's position is that Defendant's claim for alimony and alimony pendente lite is meritless as well. Plaintiff filed a Petition for Counsel Fees, Costs and Expenses on January 18, 2001, which incorporates the statements included herein, For all of these reasons and for reasons which will be more fully articulated at the Pre-trial Conference, Plaintiff's position is that Defendant should be responsible for paying Plaintiff's attorney's fees, IX. PERSONAL PROPERTY Plaintiff's position is that each party retain whatever personal property they have in their own possession. Plaintiff removed very little personal property from the home at the time of separation. Furthermore, there has been no request that any items of personal property be returned or appraised, --, '- ., "" ~'" "^~;. .'"," '"''..''' [1, 'c~'--"'~;: X. MARITAL DEBT To Plaintifl's knowledge, there is no outstanding marital debt. XL PROPOSED RESOLUTION OF ECONOMIC ISSUES Plaintifl's position is that Defendant's request for equitable distribution, alimony, alimony pendente lite, counsel fees, costs and expenses be denied. There is no legal or factual basis for proceeding with the economic claims raised by Defendant, Defendant has not been able to identify any existing marital property or outstanding marital debt. In addition, Defendant is gainfully employed with the same employer as Plaintiff. Defendant's insistence on proceeding with these groundless and baseless claims have forced Plaintiff to incur attorney's fees associated with litigation. Based upon the length of the marriage, the parties' incomes, the parties' ages, the parties' skills and the lack of any marital property, and for the reasons more fully set out herein, Defendant should be responsible for Plaintifl's attorney's fees associated with these proceedings. Respectfully submitted, GRIFFIE & ASSOCIATES Mary~1:t~ Attorney for Plaintiff 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 '.=...."xII....._'""""""'.....""""" Form 1 040 Label (See instructions on page 19.) Use the IRS label. Otherwise, please print ortype. Presidential Election Campaign ~ ISeeoa e 19.) , ...,..- ;..J. 0", ~ '~~\~fi!;" Department of the Treasury - Internal Revenue Service U.S; Individual Income Tax Return ~@oo !9\}) IRS Use Onlv - - Do not 'Nfl\S er StacIe 'In tl1 is scace ,2000.endinc . .20 ! OMBNa.1545-0074 Your social security number 204-60-9465 FOf the Veaf Jan. 1- Dec. 31. 2000, orotheftaxvearbeainnina JAY E SNYDER 769 HAMILTON CARLISLE, PA Filing Status 1 2 3 Check only 4 ons box. 5 Exemptions 6a CT 17013 Spouse's social security number Important! You mustenter your SSN(s) abovl~. ! ! !fmorethan six dependents, see page 20. Income Alt3ch Forms W~ 2 and w- 2G here, Also attach Farm(s) 1099- R jf taX was witllheld, If you did not getaW-2, see page 21. Enclose, but do not attach, any payment.A1so. p lease use Form 1040- V. You Note. Checking ''Yes'' will not Change yourtax or reduce your refund. Dovou.or oursoouseiffilin a.ointreturn.wantS3to otothisfund? X Single . " "':;';~;,_. Married filing jointretum (ev,,",if oiiJY one hactincorrie) Married filing separate return. Eni~.sPQuse'~S~~ ~~and fui! l'Iam~n~': ... Head of household'(with qualifying person); (Seepage 19.) lfthe qualifying person is a child but not your dependent enterthischild's name-here. ... Qual" in wicow(er with de endentchild ( ear scousedied )too ). See oaoe 19.) Yourself. If your parent (or someone else) can claim you as a dependent on his orhertax return, do not cheCk box6a Spouse nYeSnNo . No } No, ~( boxes CheCked an 5aand5b 1 No, ~f yOlJ,f crlllclnlnon6,: who: b n Spouse c Dependents: (2) Dependent's (3) Dependenrs 4)-./"1 :!l.lal. 11) First name Last name social securitv numbe relationship to ::nila f':Jr vau l'1ild ~~".r . " . ,,,^ .--, . ~' ,'.~ . ..' . /~~' ! ;-,.';: .. , .... , . I . . " . ..... , .., .' . '.i'leO'N\\t\'JClJ_ . ,jidnol!lvewltn you due to aj'lores OfSepelrallon see oage 20} Dependents ~m 5c not anterel~ aOave d Total numberofexemctiansclaimed 7 Wages, salaries, tips. etc. Attach Farm(s) W- 2 Addnumoersu enlered en !inesatlave" 1 41,649, 8a ~ 9 10 11 12 13 14 15a 16a 17 18 19 20a 21 Taxable interest. Attach Schedule 6 ifrequired Tax- exempt interest. Do not include on line Sa. 8b Ordinary dividend$'~Att1ch SChed,ule;6"tfrequired .:'~,' .",~ Taxable refunds...credits, oroffSets of state and local i~ taxes (seepage 22l}~,:; Alimony received'" ,-', "," , , ":,,:,, " ~ Business incort1",Or(loss~.AttaCh. ~Ch:"'l.Ile C or C- ~ . Capital gain ocliclisi IiSch D ncit,.qjl[;e',j, chec~ hete Other gains cr (losses). Attach Form 4797 . TotalJRAdistributions . .! 153 I I bTaxableamt Total pensicns and annunles. i16al . b Taxable amt Rental real estate, royalties, partnerships, S corporations, trusts, etc. Attach Schedule E. Farm incame 0(' (loss). Attach Schedule F . Unemployment compensation . . . Social security benefits L~J I. b Tax~b~a~t Other income. Listtype and amount'(seepage 25) 9 10 11 12 '.~O 13 14 15b 16b 17 ~ I 19 I ~~:yj r/~/1 . I 22 i 41,649. 22 Add the amounts in the far ri ht corumn forlinesTthrouoh 21. This is vourtotal income 23 IRA deduction (see page 27) . 24 Student loan interest deduction (see page 2i) 25 Medical savings account deduction. Attach Form BB53 26 Moving expenses. Attach Form 3903 27 One- half of self~ empJoymenttax. Attach Schedule SE 28 Self- employed health insurance deducticn (see page 29) 29 Self- employed SEP, SIMPLE. and qualified pians . 3Q Penalty an earlywithdrawa! af savings 31a Alimonypaid bRecipient'sSSN. 177-50-3889 32 Add lines 23 through 31a 33 SubtractHne 32 from line 22. This is your ad"usted ross income For Disclosure, Privacy Act, and PaperNork Reduction Act Notice, see page 56. Adjusted Gross Income KBA 5,382. 36,267. Form 1040 (2000} 23 24 25 26 27 28 29 30 31a 5,382, .. Form 1040 (2000) FD1040-1V 1.25 Form Software COPYrlgM I 1996 - 2eOl H &R B lock Tax Sarvlces. Inc. EXHffiIT A .~~ Form 1040 (2900) Tax and Credits Stand.rd Deduction for Most People Single: 54,400 Head 01 hcusehold: 56,450 Married filing jointly or Qualifying widow(er): 57.350 Mcarned filing separately., 53.675 Other Taxes Payments If you have a qualifying child..tt.ch Schedule EIC. Refund Have it directly deposited~ See p.ge 50 and fill in 67b. 67c. and 67d. Amount You Owe Sign Here Joint return? See page ~9. Keep a copy foryaur records. Paid Pre parer's Use Only 57 Add lines 51throu h 56. This is ourlotallax 58 Federal income tax withheld from FormsW~ 2 and 1099 59 2000 estimated tax:pay(l1ents & amountapplied from 1999 retum. 60a Earned income,~~redit(SC). ,-' ::';:, b Nontaxable eamiad. income: amount .....: i .nd type. Excess social securil'pand RRT~withheld (see page 50) Additional child tax credit. Attach Form 8812 Amount paid with request far extension to file (see~e 50) . . Other payments. Check illrom .0 Form 2439 bUForm4136 Add lines 58.59. 60a. and 61throu h 84. Total ments If line 65 is more than line 57, subtract line 57 from line 65. This is the amount you overpaid Amount of line 66 you want refunded to you Routing number 031100254. cT e. XChecklng Osavlngs Account number 900479152 Q4 6094 65- Amount of Hne 66 au want a Iiedto 2001 estimatedtax 69 If line 57 is more than line 65, subtract line 65 from line,57. This is the amount you owe. Fordetails an how to pay, see page 51 . ~' . ." _ . 70 Estimated tax Denal . Also include on line 69 70 Under penalties Of perjury. I declare tl'lat Il'Iave examineo tl'llS ,eturn and acccm"anying sChedUles and statements. iJnl3 lO III e oest of my l<now\edge and ~eHef, they are !rue. correct. and complete, 0 eclaratlon of ::lreparer (other than taxpayer) IS :lased on alllnformatron of wn Ie!"! preoar9r has any .~nowlaage - .. ~ = '0 _I. ""'-~, JAY E SNYDER 34 Amountfrom line 33 (adjusred gross income). . , . .35a Check if: 0 Youwere6Saralder, 0 Blind; 0 Spouse was 65 oroJder, Add the number of boxes checked above and enter the total here b lfycu are married filing separately and your spouse itemizes deductions, or you were a dual- status alien, see page 31 and check here O~Jin~. ,.35a .~ 35bO 36 Enteryour itemized deductions from Schedule A.line 28, or standard deduction shown on the left But see page31 to find your standard deduction if you checked any box an line 35a or 35b orifsomeonecan claim you as a dependent. . . . . . , . 37 Subtract line 36 from line 34. 38 Illine 34 is 596.700 or less. multiply 52.800 by the tot.1 number 01 exemptions claimed on Jine6d.lfline 34 isoverS96,70Q, see the worksheet on page 32 forthe amount to enter . 39 Taxable income. Subtr.ct IIne38from line 37.lfITn..38 is morelhan:line37 enter-O- 40 T.x.Checkifanylaxisfrom aOFcrm(s18814 bOF9.:m4972 . ... ,'. '.' . 41 Alternative minimum tax. Attach Form 6251: . - . 42 Add lines 4.0 and 41 43 Foreign tax credit. Artach Form-t1'16ifrequired. \' 44 Credit for child and dependent care expenses. Attach Farm 2441. 45 Creditfortheelderlyorthe disabled. Attach Schedule R 46 Education credits. Attach Form 8863 47 Child tax credit (see p.ge 36). 48 Adootion credit. Attach Form 8839 . 49 Oth~r.CheCkilfrom .OFo.rm3800.... bOF~rm8.3~6 c o Form 8801 dO Fo<rn:Cspecify) .>>,..' 49' ,:0:" ' 50 Add lines43 through 49. .' .... ..:.' .' 51 Subtract line 50 from fine 42.lfline 50 is,morethamline42. eiiter - 0- 62 Se~- employment tax. AllachSchedule.SE. 53 Social security and Medicare t3X:on--tfp income notreportedlt0<employer: Attach Form 413i . 54 Tax on lRAs, other retirement plans, and MSAs. Attach Form 5329 ifrequired . 55 Advance earned income credit payments from Form(s) W. 2 56 Household employment taxes. Attach Schedule H . 61 62 63 64 66 66 67. b d ~ 68 ~ I 68 Date Your occupation LABORER Spouse's occupation ~ Your signature For Info Only-Do not fil Spouse's signature.lfajoint return, both must sign. For Info Only-Do not fil Preparers It. Date signature r 1/22/01 Firm's name (or ~Ii AND R BLOCK yoursilself-employed), CARLI SLE PA 17013 - 33 06 address. and ZIP code , - '""':..'.....~~. 204-60-9465 Pa e2 34 36,267.. 36 ! 4,400. 37 ! 31,867. ;;% 38 I 2,800. 39 I 29,067, 40 4,729. 41 . 42 4,729. . 7,339. 2,610. 2,610. 4,729. . 4,729, 7,339. ~ 66 i 66 i . 67. f:I . 0~ I Daytimephonenumber MaylRSclscus$thlsreturnwllh the:;:reparer n rl shown Oelow-' Yes No Check il I Preparer's SSN or PTIN self- em loved n EiN 25-1769631 IPhcneno. (71 7) 243- 68 68 Form 1040 (2000) KBA F0(lT11040(2000) FD1040-2V1.25 Form Software Copyrlgnt 199-6 - 2001 H&.R. BlOCK Tax Ser'llcas. \nc s (s.e instructions on page 19,) U.. the IRS label. Otllerwise, please print ortype. ~sidentlal Electlon Campaign" s.e a e19. , Filing Status 1 2 3 4 Check only one box. Exemptions If more than six dependents, see page 20; Income AtllOch FormsW-2and W. 2G here, Also attach Form(s) 1099- R Iftaxwas withheld. If'jOu did nol getaW-2, see page 21. Enclose, but do notattach,any payment Also, please use Form 1040- V, Adjusted Gross Income KIlA .J.........,__ ,..I, I"~ (f;;..,'.. Department of the Treasury - Inlemal Revenue Service G))I1\\t\O U.S. Individual Income Tax Return . (f,~V . IRSU..Onl Fortlle ""Jan.,1-Dec.31,2OOO,orothertax rb Innln .2OOO,endln ,p\;;-<...~e... s.~~cL- -\'-.....:..... \q~ ~'\ 0",,',,\ Co '?'"\ ' -~v II~~~~ 04 Donolwnteorst 'elnlhls. ace. ,~ OMBNo,l545=0074 YOlB'socIaI Mcurlty nllll'lber 177-50-3889 Spouoe'._..curtly number PAULA L SNYDER 151 W MIDDLESEX DR CARLISLE, PA 17013 ~""'--\W. 'Y~~~'-<:.,~ 22 Add the amounts in thefarri ht 23 IRA deduction (see page 27) . 24 Sl1Jdentloaninterestdeduction(seepage27). 25 Medical savingsaccountdeducUon. Attach Form 8853 26 Moving expenses. A11ach Form 3903 , , . . . 27 One- half of self- empioymentlax. A11ach Schedule SE 28 Self- employed health insurance deduction (see page 29) 29 SeW-employed SEP,SIMPlE,and"lualifiedplans. 30 Penalty on eariywithdrawalofsavings , 31a AJimonypaid bRecipienfsSSN.. 32 Add lines 23 through 31a . , , . . . , . 33 Subtract line 32 from line 22. This is 'lOur l!dlu.led.llrcuJncome For Disclosure, PrIvacy Act, and Paperwork Reduction J EXHIBIT B 16, .. X 5 60 b (3) Depenfjenfs relationshiP to u d Total number of exam lions claimed , . . . . . . . . . 7 Wages, salaries, Ups, ete, A11ach Form(s) W- 2 _________ 60 Taxable Interest Attach Schedule 8 ffrequlred . . , . . . . b Tax-exempt interest 00 not include on line Sa. . . . . . 8b 9 Ordinarydividen Sch uired ftJ. 'O'T" 10 Taxablerefund dlocaii (ge,. . 11 AJimonyreceiv .... " . ,.. 12 Businessinco Core.,." . . 13 Capital gain 0 0 ,checkh.., ""..0 14 Other gains or (losses). Attach Form 4797 . . . . . . . . . , . 150 TotallRAdistributions . . ~ I b Taxableamt 160 Totalpensionsandannuilies. ~ bTaxableamt 17 Rental real estlle, royalties, pa~"'erships. S corporations, trusts, etc. Attach Schedule E . 18 Farmincomeor(loss).AttachScheduIeF. 19 Unemployment compensation . . . . . 20a Social security benefits , . 2 21 Other income, Usttype and amo 24 25 26 27 28 29 30 31a Form 1040(2000) FD1040-1Vl.25 FotmSoftware~opyriQhI1996- 2001 H&R Block Tax Services, Inc. Importantl Youmllllenter yourSSN(s} above. You Spouse X Yes , , No } No. of boxes ch~cked 0:1 . . . Gaand6b . " No. of your 4 f qual.~h~~:ren on Eic: child for 2 hild lax cr. . lived wilh you X' . did not llvewiU;--- X you due to divorce or separation (seepage 20) - Dependenls on Be not entered ab0'49 1 Add numbers .~~:=::e Ill> 3 27,560. 9 10 11 12 13 14 15b 16b 17 18 19 .. ,~ .. Form 1040 (2OOO) ~"""I"ii!iloll~Iii~IYI\iolio~.1lliIlilliI 1. I.. Form 1040 2000 PAULA L SNYDER 57 Addlines51thlOu h56,Thisis urtotaltax . 909. 58 Federal income tax withheld from Forms W- 2 and 1099 59 2000 estimated ts & plied from 1 60a Earned income b Nontaxable ea and type. D 61 Excess social RR eid (see 62 Additionalchild taxcredil Attach Form 8812 63 Amount paid with requestfor extension to file (see ~ge 50) . . 64 Otherpayments,Check~from aD Form 2439 bUForm4136. 65 Adlflines58,59, 6Oa,and 51 through 64, Totalpa ments 66 If line 55 is more than line 57, subtract line 57 from line 55. This is the amounlyou overpaid 67a Amounlofline66youwantrefundedtoyou · . b Routing number ings . d Account number 68 Amountofline66 uwanta r 69 If line 57 is more than line 55, su For details on how to pay. see 51, . 70 Estimated tax enal . Also indude on line 59 . Under pen~lIies of perfury.l declare that I have examined this return and accompanying schedules and statements. and to the best 01 my knowledoe and belief. they are true, correct, and complete. Declaration of preparer (otherthan taxpayer)!s based on all Information of which preparerhas any knowledge. Tax and Credits Standard Deduction for Most People Single: $4,400 Head of household: $6,450 Married filing joinUyor Qualifying wldow(er): 57,350 Married filing separately: $3,675 Other Taxes Payments If you have a qualifying child. attach Schedule EtC. Refund Have it directly deposited! See page 50 and fiUin57b, 57c,and 67d. Amount You Owe Sign Here Jointretum? See page 19, Keep a copy for your records. Paid Pre parer's Use Only 34 Amount from line 33 (adjusted gross income) 358 Che;;kif: 0 You were 55 or older, 0 Bilnd; 0 'S~~as6s~roJder: OSnnd, Add the number of boxes checked above and enterthe total here , " ,.35a b If you are married filing separately and your spouse itemizesdeduclions, or you were a dua~ status alien, see page 31 and check here 36 Enter your ~emlzed deductions from Schedule A, line 28, or standard deduction shown on the !ell. But see page 31 to find your standard deduction Wyou checked any box on Iina35aor35bor~someonecanclaimyouasadependent. . . . . . . , 37 Subtract line 35 from line 34 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 ~ Your signature For Info Only-Do not fil Spouse's signature.lfajoint return. both must sign. For Info Only-Do not fil Prepare~s lir.. signature , Firm's name (or ~ yours if self- employed), address and ZIP code Date Your occupation CLERK Spouse'soccupation , ='~"~~~t' ,~ .. 1,000. ~ Daytime phone numbar Date 1/20/01 KBA Fonn1040(2000) FD1040-2V1,25 Form Softwsr.Copyright 1996 ~ 2001 !-fAR Block Tax Servu:es, Inc. -OITB' Form 1040 (2000) . ." " _ .,.,.,. ,,__ "'''M~'''~"'~"'' '.'" '<"~-'--'- "~~,~, ,-,,' '. ~ """"'''''/& JAY E, SNYDER, Plaintiff : IN THE COURT OF COMM:ON PLEAS OF fl \ n f\\)(j. : CUMBERLAND COUNTY, PENNSYLVANIA, J' ,r"''V \ y : CIVIL ACTION - LAW v, PAULA L. SNYDER, Defendant : NO. 00-7645 CIVIL TERM : IN DIVORCE INVENTORY AND APPRAISMENT OF PLAINTIFF. JAY E. SNYDER Jay E. Snyder, Plaintiff, files this inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Jay E, Snyder, Plaintiff, verifies that the statements made in this inventory are true and correct, Defendant further understands that false statements herein are made subject to the penalties of 18 Pa.C,S. Section 4904 relating to unsworn falsification to authorif ASSETS OF PARTIES Jay E. Snyder, Plaintiff, avers that none of the items listed below are applicable to the case at bar and, therefore, there can be no itemization. ( ) 1. ( ) 2. ( ) 3. ( ) 4. ( ) 5, ( ) 6, ( ) 7, ( ) 8. ( ) 9. ( ) 10, ( ) 11. ( ) 12. ( ) 13, ( ) 14. ( ) 15. ( ) 16. Real property Motor vehicles Stocks, bond, securities and options Certificates of deposit Checking accounts, cash Savings accounts, money market and savings certificates Contents of safe deposit boxes Trusts Life insurance policies (indicate face value, cash surrender value and current beneficiaries) Annuities Gifts Inheritances Patents, copyrights, invention, royalties Personal property outside the home Business (list all owners, including percentage of ownership, and officer/director positions held by a party with company) Employment tennination benefits-severance pay, worker's compensation claim/award () 17. () 18, () 19, () 20. () 21. () 22, () 23, () 24. () 25, () 26, .' "I, '~ "l- 1"- _'I ~, ,-, 0: - , .' _.,~~" Ltc: . Profit sharing plans Pension plans (indicate employee contribution and date plan vests) Retirement plans, Individual Retirement Accounts Disability payments Litigation claims (matured and unmatured) MilitaryN.A. benefits Education benefits Debts due, including loans, mortgage held Household furnishings and personalty (include as a total category and attach itemized list of distribution of such assets is in dispute) Other LIABILITIES OF PARTIES Jay E, Snyder, Plaintlll: avers that none of the items listed below are applicable to the case at bar and, therefore, there can be no itemization of liabilities, SECURED () 1. () 2. () 3, () 4, UNSECURED () 5. () 6, () 7. () 8, () 9, Mortgages Judgments Liens Other Secured Liabilities Credit Card Balances Purchases Loan Payments Notes Payable Other Unsecured Liabilities CONTINGENT OR DEFERRED () 10. () 11. () 12. () 13, () 14, () 15, Contract or Agreements Promissory Notes Lawsuits Options Taxes Other Contingent or Deferred Liabilities . ~ ~ " , "'lit;] MARITAL PROPERTY Jay E. Snyder, Plaintiff, avers that there is no marital property in which either or both spouses have a legal or equitable interest individually or with any other persons as of the date this action was commenced: " ~ .., . "I~; JAY E. SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 00 - 7645 CIVIL PAULA L. SNYDER, Defendant IN DIVORCE NOTICE OF PRE-HEARING CONFERENCE TO: Marylou Matas , Attorney for Plaintiff Matthew J. Eshelman , 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 15th day of May 2001, at 9:30 a.m., at which time we will review the pre-trial statements previously filed by counsel, define issues, identify witnesses, explore the possibility of settlement and, if necessary, schedule a hearing. Very truly yours, Date of Notice: 4/12/01 E. Robert Elicker, II Divorce Master Marylou Mattas, Attorney for Plaintiff, filed a pre-trial statement on March 12, 2001. Matthew J. Eshelman, Attorney for Defendant, has not filed a pre-trial statement as of the date of this notice. b"'"tU'IIii l~~. '.' ~ 1,1 ,,1 I:.:"t l~ " ~~y JAY E. SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00 - 7645 CIVIL PAULA L. SNYDER, Defendant IN DIVORCE TO: Marylou Matas Attorney for Plaintiff Matthew J. Eshelman Attorney for Defendant DATE: Thursday, February 1, 2001 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. =tf- (s. k)leve.d, i h.J JIsCOOet.. is." ' (01.1, t.,k. peJAJ'1 reu lew of rrl eS f;1 / . . vt-t t'vt(l)JULtiucL l",u~WliJr~ ~~d ~rr~I~WW , J \i:)j;J0'-""'"" ~r\t~C I ~UJ pre - fr." ii;r~B - 5 20011111 . ~ · U~T:Ju U L::ItJ!; -...........CO... Q---............... "'~'~.~<",= "' .1 . I". &.,'," . ,.,' .Ii1i4--' -r~, >' (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. ~/6JOI (DATE! ( ) ~) 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 ~OMPLETE, 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. .... " ,", "'~"'I' k- IW*";: JAY E. SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00 - 7645 CIVIL PAULA L. SNYDER, Defendant IN DIVORCE TO: Marylou Matas Attorney for Plaintiff Matthew J. Eshelman Attorney for Defendant DATE: Thursday, February 1, 2001 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. 0' :'1":' ~ ' I 1,;,,--. ""'~~"'~"- L',ii ~ (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. Discovery is complete. 7-.) (3! 0 \ , DATE ..~ 7fL~ COUNSEF PLAINTIFF (2') 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. i3l~--: l~jjJ ","'~~,'A"' ~ ~ ". /~ 1,\'\ ,; \'.,:r \ " , '>, " ',' "". , \ ," ~ .., '. (~(,~ t \' -- \.Il, \\, " ~ 1\\\\\ rt.'O ' !!H'jlll~CJi!W~~&J:'~'ii~~iI!W ,-'" .,' ~_t!~_~_~JIa!lIlUilMf~' \~ \" " ''",,\' \" \,\ 1,' ",\ ',',. \ " ~ r \ --;, ': ~'., ",",",", " ;. " ~:;""-" ' "oJ, ~, -"j ~ , , , ~I" ,I In the Court of Common Pleas of Cumberland County, Pennsylvania Domestic Relations Section P.O. Box 320, Carlisle, PA 17013 Phone: (717) 240-6545 ~1\~/0)1-' Fax: (717) 240-6248 Plaintiff Name: PAULA L. SNYDER Defendant Name: JAY E. SNYDER Docket Number: 01014 s 1998 PACSES Case Number: 954100520 Other State ID Number: Please note: All correspondent must include the PACSES Case Number. Income and Expense Statement THIS FORM MUST BE FILLED OUT (If you are self-employed or if you are salaried by a business of which you are the owner in whole or part, you must also fill out the Supplemental Income Statement which appears on page two of this income and expense statement. ) INCOME STATEMENT OF J av E. Snvder Section I: Income and Insurance INCOME: Employer Carlisle Tire & Wheel Address Carlisle PA 17013 Type of Work laborer Payroll No. 1629 Gross Pay per Pay Period $ 649.12 lID d Itemized Pavro e uctlOnS: Federal WithhOlding $ 103.19 Social Security $ 39.96 Local Wage Tax $ 6.49 State Income Tax $ 18,05 Retirement $ 12,98 Savings Bond $ Credit Union $ Life Insurance $ Health Insurance $6.92 Other Deductions (specify) Spousal Support $ 103.54 Vacation $ 15.00 , Garnishment Fee $ 2.07 Christmas $ 5.00 Net Pay per Pay Period $ OTHER (Fill in Appropriate Column) IN C 0 lVlE WEEK MONTH YEAR Interest $ $ $ Dividends Pension Annuity Social Security Rems Royalties Expense Account G,ftS Unemployment Workman's Compensation Other Other TOTAL $ $ $ TOTAL $ INCOME Service Type Pay Period (wkly" bi-wkly., ete,) weekly 328 89 PROPERTY Ownership. OWNED DESCRIPTION VALUE H W J Checking Accounts $ Savings Accounts Credit Union Stocks/Bonds Real Estate Other TOTAL $ * H = Husband; W = Wife; J = Joint Form IN-008 Worker ID ..w JIlMJ~' < ~n, .' Income and Expense Statement PACSES Case Number 954100520 Coverage. INSURANCE COMPANY POLICY # H W C HO~l'ital Blue Cross Other Medical Blue Shield Blue Cross/Blue Shield X X Other Health! Accident Disability Income Dental Other * H : Husband; W: Wife; C : Child Section II: SU1,)plemental Income Statement a. This form is to be filled out by a person (I) who operated a business or practices a profession, or (2) who is a member of a partnership or joint venture, or (3) who is a shareholder in and is salaried by a closed corporation or similar entity b. Attach to this statement a copy of the following documents relating to the partnership, joint venture. business, profession. corporation or similar entity: (I) the most recent Federal Income Tax Return, and (2) the most recent Profit and Loss Statement c. Name ofbusiness: Address and telephone number: d.Nature of business (check one) ( I) partnership (2) joint venture (3) profession (4) closed corporation (5) other e, Name of accountant, controller or other person in charge of financial records: f. Annual income from business: (I) How often is income received? (2) Gross income per pay period: (3) Net income per pay period: (4) Specitied deductions, if any: Service Type Page 2 of3 Fonn tN-008 Worker ID . Income and Expense Statement "', ~'A" I.. ~" "j"~ "'0'"'''' "'l~' PACSES Case Number 954100520 Section III: Expenses instructions: Only show extraordinary expenses in this section wIess you filled out Section II on page two. The categories in BOLD FONT are especially important for calculating child support. If you are requesting Spousal Support! APL or if you assert your case cannot be determined according to the guideline grids or formula, this section must be fully completed. (Fill in Appropriate Column) EXPENSE WEEK MONTH YEAR ~ Mortgage/Rent $ $170.00 $ Maintenance ~ Electric $ $120,00 $ Gas Oil Telephone 40.00 Watef & Sewer 20.00 Emnlnvment Public Transponation $ $ $ Lund. 100.00 Taxes Real Estate $ $ $ Personal Property Insurance Remer's $ $5.00 $ Automobile 75.00 Life Accident Health Other Automobile Payments $ $ $ Fuel 80.00 Repairs Medical Doctor $ $27.68 $ Dentist 10.00 Orthodontist Hospital Medicine Special needs tglasses.braCllS 25.00 orthopedic devices) EXPENSES (Fill in Appropriate Column) (continued) WEEK MONTH YEAR Education Private School $ $ $ Parochial School College Religious ~ Clothing $ $80.00 $ Food 400.00 Barberf Hairdresser Credit Payments Credit Card 100.00 Charge Memberships-YMCA 50.00 .!.!llil> Credit Union $ $ $ Mh:cellaneous Household Help $ $60.00 $ Child care Paperslbooks Magazines Entertainment Pay TV 20.00 Vacation 100.00 Gifts Legal fees 100.00 Charitable Contributions Other Child Support Alimony Payment 450.00 ~ $ $ $ Total Expenses WEEK $ MONTH $ YEAR $ \ verify that the statements made in the foregoing document are true and correct. I understand that fals~ statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsIficatIOns to authonlIes. DATE: Service Type Page3 of 3 Defendant Form IN-OOs Worker ID