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Home My WebLink About00-08840 l'_ ,. , l_ ..~; . " ~ "';;.., ., ... , ;,'- ",-, ,-- , ., Oh_"IiiriiiiiiiiIIi'- --, ~ . ~ ~~~ ~ ~~ ~ ~ ~ ~ ~~ ~~ ~~~ ~~~~~~~~~~~~~~~ ~~~ . . . . . . . . . . . . . . . . . . . . . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . PENNA. STATE OF . . . . Brian C.Coyle No. 2000-8840 Plaitltfff . . . VERSUS . . Shelley R.Coyle . .' Defendant . . DECREE IN DIVORCE . . . . . . c , 1.. J, IT IS ORDERED AND AND NOW, DECREED THAT Brian C. Coyle , PLAINTIFF, Shelley R. Coyle 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 parties hereby incorporate their Agreement dated April 17, 2003 herein. . . . . By THE COURT: . ATTE . ~ ~ ~ ~ ~ ~ ~~ ~ ~ ~ .. ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . ~ ~ 'Ii ~,.;-'f. - II DiIii . \..' - .. \,~" . .s~ I-ca W. c:?~ 4~# z:.d'dj 4~ s/ m ~~ -;G4*~ ~_.-- "JI!MlJI~"~''''_-" '~'!""""~~_~"~ _ 1_V'~O_ , " co _" "'<;_~~~_ ~<l''f_~FI'"7,r,n,," Ul?!'~~!\,~'1!'f'1;:~I!'.f!'!~1~1!lm~~1ffj,. - ~"""'~~! -~- "~ -- ""0 BRIAN C. COYLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs, : CIVIL 2000-8840 : CIVIL ACTION - LAW SHELLEY R, COYLE, Defendant : 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: I. Ground for divorce: irretrievable breakdown under Section 3301(c) and 3301(d) of the Divorce Code. 2, Date and manner of service of the complaint: January 12,2001 upon Defendant's counsel at ~the time, Thomas S. Diehl, Esquire, I West High Street, Suite 208, Carlisle, PA 17013, 3. (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff April 17, 2003; by Defendant April 17, 2003. (b) (I) Date of execution of the Plaintiff's Affidavit required by Section 330 I (d) of the Divorce Code: November 4, 2002; (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: November 5, 2002 and service via regular mail to Defendant's counsel, Jennifer L, Lehman, Esquire, 27 South Arlene Street, Harrisburg, P A 17112. 4. Related claims pending: None. 5, Date Plaintiff's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: April 17,2003; Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: April 17, 2003. Date: April 21, 2003 By: aylo P. Andrews, Esq. 78 est Pomfret Street arlisle, PA 17013 (717) 243-0123 Supreme Court ID No. 15641 oil l~..'~-'~:ii~&~~j"I~lI,;;~~~~\~m.~~,~t~~f,d~!.ilI'!ii;I,~~!~j~j~JiiiillM~' , ,-~~ L~lill:~ff-'~~~ e.IL e *+iJ """-~'W,UIll!imi~jj!jj!~~,~~.< -rJ i':;~ QJ(' .::."::.-', ~;: 1?: :-- ;:; )> (~., (:..:! ;::,~- ..-.~,..;, C::,) <:.." ~ , , -71 :t--.:n -" ;':) t',.,J c.,) --C] --;() -r, ';-1"1 ;(") -.~ en :0 m ''''-- ;.::j j"j -< ,--~.. , J . .Y. , ,"- ',- - ~--- ~~, - BRIAN C, COYLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA Defendant : CIVIL ACTION - LAW : NO. 2000 gf40 : IN DIVORCE . CIVIL TERM v. SHELLEY R. COYLE, 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 ofthe 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 Streets, 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, P A 17013 Phone: (717) 249-3166 ~"' --=-~ .J ~ k" .. ,- OJ'--, 1--5 ,__, ;_' '_ - BRIAN C. COYLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW SHELLEY R. COYLE, Defendant : NO. 2000 - 'i'?'fJO CIVIL TERM : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE I. Plaintiff is Brian C, Coyle, who currently resides at 702 Sandbank Road, Mt. Holly Springs, Cumberland County, Pennsylvania, since December 1997, 2. Defendant is Shelley R. Coyle, who currently resides at 210 Hill Street, Apt. 2, Mt. Holly Springs, Cumberland County, Pennsylvania, since November 3, 2000. 3, Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on February 10, 1990, in Beaver County, Pennsylvania, 5, There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6, The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available, and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree of Divorce. -~_""i>ffl~ ~.~ ~ ""~ . '~ . ~ "l--.f'-=".__ ,--;,-' ~M:~i&~; ." Count II Equitable Distribution of Marital Property 9. Paragraphs I through 8 of this complaint are incorporated herein by reference. 10. Plaintiff and Defendant have acquired marital property, and Plaintiff seeks an order of the Court to equitably distribute the marital property. WHEREFORE, Plaintiff prays your Honorable Court to enter orders equitably distributing the parties' marital property and terminating the marriage of the parties. ANDREWS & JOHNSON By: or p, Andrews, Esq. rneys for Plaintiff 78 W, Pomfret Street Carlisle,PA 17013 (717) 243-0123 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. S 4904, relating to unsworn falsification to authorities, Date: 12~Z(, ~ 60 ;5~!- ~ . Brian C. Coyle, R mtiff ;. ; --, Ji!(' BRIAN C. COYLE, Plaintiff vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL 2000-8840 : CIVIL ACTION - LAW SHELLEY R. COYLE, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 28, 2000, 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. ~ 4904, relating to unsworn falsification to authorities. Date/J~ 17~03 ~~~ Brian c. Coyle, Po aintiff j~i\~~4it.4~ti!ig'iMi~'it~vrif;jci>,l;;J!{Willil~i1!~:J![i,*#'op.4~~-'ia~~~,il.--t'~!1hf,,,,~~_,jji;.rl 'i~~'"""'_.l...~~~- ~Jl"' j.-- " () CD C.....,. ,.'~ (""' ;"{' ;~ a:: -:::1 .-- (f) -7 ~_"7 ~~& ::J o Ci..:::: t:l_~ ...:::t ~ (::._~ ...~~~~~~~1I!il ,.~".c ~ -- !: -!OI:i BRIAN C. COYLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs, : CIVIL 2000-8840 : CIVIL ACTION - LAW SHELLEY R. COYLE, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301{c) OF THE DIVORCE CODE I. 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! 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. 94904, relating to unsworn falsification to authorities. Date: Y.~11--O :!> 1~:!i~Wf<P~ftll~Ef...$i~iiJ;r~~iIiil!~~\':d~b';M;.ll:'h!,;j'W,~~~~~jj - ""~ "",::I ' ~ ia_~'"-" "'i"_.'~'-~-'iii~Uliiil!ii~~:'il-tl6i~mltlli1"'tr.c~.I1~~ ,-~, -.- :;:'2 ~-; ~Hr ~5~'~' ,"':,-, i' '''il (;:) (....J C) ~'i1 ""II , <~.' '- "'-i" r~-: '1,-," --l-i -:;:C) !'n ;''-1 ()' ""- ~-"~~ " ~ - '" . " "~ ,-,- - n lli~- BRIAN C, COYLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 2000-8840 v. SHELLEY R. COYLE, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301(c) of the Divorce Code was filed on December 28, 2000. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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. ~4904 relating to unsworn falsification to authorities, Date: 4-n-{8 ~~ ~r~ SHELLEY R. C YLE DEFENDANT :~"'iJl:~';j~ik~;;ij"~~,;;,;,'~,~~i!i~:G.'1~,11ffi1f1,^1~J:1!~~?,~1liI1,'fij;,jf,,b")bo&i'lI",ih-'t'~Rt-:J~li'~",1i1\~"' e~_. ~ ~_~ ,_ ^ ~, "~ ~~, _." ~~<J"I _ , '>~'~l._IIi!lliiliM1I'!'H'.'~'I!i~Ti!r!in_~~lj;'~""",,"""~,.~- . -" -~- - (') C) 0 C W --n -;-"'" :0lJ :::,~ "1J '-' -0 " " !Tl SL: ;cD ,= -/ ,~ ,-'''; 2..': -.J CI (f) '. -< -' Z~) S -rJ , -c. --~? -" " ,-- (') ::::::' !') ;\1 );.... <-' ;.::=~ ~" Xl t..'" ..<<;. ,'n"j '" " ~ , '-'....li;;.'t,-, BRIAN C, COYLE, Plaintiff : IN TIIE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO, 2000-8840 SHELLEY R. COYLE, Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2, I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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, 94904 relating to unsworn falsification to authorities. Date: 4~ n-03 SW~'Q (~~Q/ SHELLEY R. C YLE DEFENDANT ~'~~~~il~W~,~~_'~~~~li<<W&.,{~~',i,1,~4!i1%,,_jh'01~@Jf!ltiH1'';~;;;'!iIf.<~..ii~r -,~ , ~.,~~, ,~~~~I1IR"" JI , .,,....'t_mBttW-~~~~lj~~~~~_i ~ I, , (') c: :2" ~\~ (f)- ~~~' o~:r :5 Ci c;> ~:o ::t) C' -,l - ::9.: ~) .' .'V Ci' " "", --w,:, - ... BRIAN C. COYLE, Plaintiff vs, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL 2000-8840 : CIVIL ACTION - LAW SHELLEY R COYLE, Defendant : IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a counter- affidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on November 3, 2000, and have continued to live separate and apart for a period of at least two years. 2, The marriage is irretrievably broken, 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fe,es or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C,S. S 4904 relating to unsworn falsification to authorities, Date: (0;/6'2- 4t:66. ~ -~~--""""'. i/iijrj, '"' ... BRIAN C. COYLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA vs. : CIVIL 2000-8840 : CIVIL ACTION - LAW SHELLEY R COYLE, Defendant : IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that on this date, November 5, 2002 I mailed a copy of Plaintiffs Affidavit Under Section 3301(d) of the Divorce Code to the following person at the following address by U.S, Mail, delivered to addressee only: Jennifer Lehman, Esquire PO Box 6130 27 South Arlene Street Harrisburg, PA 17112-0130 I verify that the statements made in the foregoing Certificate of Service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S. ~ 4904, relating to unsworn falsification to authorities. ANDREWS & JOHNSON By: y r p, Andrews, Esq. orneys for Plaintiff 78 W. Pomfret Street Carlisle, P A 17013 (717) 243-0123 ;.,;- ',~ '"' *r,MlIm!l!~fi~jfrri~if~t~~lb~~)?'1~~tfj]"kl\6~~~"r.lii"""-" ~~....'~~~,.,~.~~ .., ,I,'."r.'~""",,-,'?-'=_"_'~" c ~_,", R~,<'~""',"',~",,,~_~,,,, "'_<;"_-,r,,",'_'o--,.-o' ~'.--<.,".~_"1'''''''.'_d,,,.,'''''' -__~". - ". .,,~ ,".~...J '"~,,~ " ~. , _ _~H Ii.... 'I-""-~'i' "--IfRI'~ '-dtfY.-i'ijdMiI..i!llMJIlL lJ ... (') ~: t.1=f;!, n"k- ~;~~~ (/5> ~~:~~: 2:~t5 ....- :;; :::1 -< h I. <:? -:1'1 (:;) _,'l'fil!' C) iT,,) '- -'- C::> >'C I en ~ - ..' " --;1 ::a r- -;-:101 ,-,0 ;'~(~ -c:~ ~i2,~~ -", .:0 -< ~ --~. - ~C"I ~i ~1 il i ".'1 Ii " I I I I I I I I I II I I ~ '.J '1'1 ~ ">, ,- ~, , , r' ~- - ., .'"k- < -,~ iili1\,j ~I \l/D:~f. BRIAN C. COYLE Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00-8840 CIVIL TERM v, SHELLY R. COYLE Defendant : CIVIL ACTION - LAW : IN DIVORCE PLAINTIFF'S PRETRIAL STATEMENT AS PER PA. R.C-P. 1920.33(b) I. ASSETS, The marital assets are set forth on Exhibit 1 attached. 2. EXPERT WITNESSES. There is no apparent need for expert testimony, unless the parties cannot agree upon the fair market value of the marital residence [occupied by Mr. Coyle]. The value shown on Exhibit 1 is based upon a listing agreement signed by both parties and advice provided by a listing realtor. If an appraisal is needed, Plaintiff shall seek a stipulation with Defendant to retain one realtor and to split the cost of an appraisal, 3. LAY WITNESSES. None anticipated except the Mr. Coyle, Plaintiff reserves the right to amend this portion of the Pre-Trial Statement with at least ten days notice to the Defendant of any lay witnesses he intends to call. 4. EXHIBITS: I. Statements of mortgage balance on marital residence currently and as of the date of separation, 2. Statement of retirement funds refunded to Mrs, Coyle in June 2001. 3. Statement of balance owed on Fleet Master Card as of the date of separation. 4. Statement of balance owed to Members' First Credit Union as of the date of separation, " '- '"" , ",,,",'_ot.., - .~".'; 5, [IF NECESSARY] An appraisal of the value of the marital residence at 702 Sandbank Rd., Mt. Holly Springs, P A. 6. [IF NECESSARY] An itemized list of the personal property retained by Plaintiff after Defendant removed the personal property she wanted from the residence. 5-6. INCOMEIEXPENSES Plaintiff's income and expenses are as shown on the Income and Expense statement that he filed with the Cumberland County DRO in January 2002. A copy of this statement is attached hereto as Exhibit 2. DRO calculated Plaintiffs net income in February 2002 as $2,179.97. Plaintiff can be eligible for incentive bonuses from his employer and he was ordered to pay Defendant 10% of all such bonuses, Defendant is now a state employee, and her net income was calculated in February as being $1,741.63 per month, Plaintiff pays child support to Defendant in the amount of $197.45 per month. The support orders referenced herein are attached hereto as Exhibit 3. 7, PENSIONIRETIREMENT BENEFITS At the time of the separation Mr. Coyle had no retirement or pension plan or benefits. Mrs. Coyle was an employee of Cumberland County with nearly 8 years of service. Since the time of separation Mrs. Coyle has left the employment of Cumberland County and she has withdrawn her retirement benefits from Cumberland County. These proceeds are already included in the spreadsheet attached hereto as Exhibit I. 8. COUNSEL FEES/COST There is no claim for counsel fees or costs, 9. TANGIBLE PERSONAL PROPERTY After the parties separated Mrs. Coyle removed much of the parties' personal property from the marital residence, She made a list of the items that she took. This list is attached as Exhibit 4. Mr. Coyle has also made a list " -=- Co' , 'j-~ ' ~, ;'" ,-'- '~ ," ., -, "~1"-f&_: of items that he contends his wife also took. This list is attached as Exhibit 5. In the spring of 2002, more than a year after the separation, Mrs. Coyle, through counsel, provided a 2+ page itemized list of additional items that she wished to have, She also claimed that the value of the marital property in Mr. Coyle's possession exceeds the value of the personal property in her possession by $4,000. Mr. Coyle disputes this assertion. He contends that the personal property has been evenly divided as is. No personal property appraisal has been performed. 10. MARTIAL DEBTS The only debts that need to be taken into account are listed on Exhibit I attached hereto. II. PROPOSED RESOLUTION Plaintiff proposes a SO/SO division of the marital property with the property to be distributed as shown on Exhibit 1 attached hereto. By L r P. Aridrews, Esq. 7 est Porofret Street Carlisle, PA 17013 (717) 243-0123 Supreme Court 10 No, 15641 ~ ----, ;lo _'ii_ .,_,..,-,"-L'" -r_"':".., , '""-,~ ""lg,,: BRIAN C. COYLE , Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00-8840 CIVIL TERM v. SHELLY R. COYLE Defendant : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE I hereby certifY that on this date, December 11, 2002 I mailed a copy of Plaintiffs Pretrial Statement as per Pa. R.C.P. (1 920.33(b) to the following person at the following address by U,S. Mail, postage prepaid and addressed to: Jennifer L. Lehman, Esq, P.O, Box 6130 27 South Arlene St. Harrisburg, PA 17112-0130 I verifY that the statements made in the foregoing Certificate of Service are true and cormct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 9 4904, relating to unsworn falsification to authorities. ANDREWS & JOHNSON . T 10 p, Andrews, Esq. eys for Plaintiff 78 W. Pomfret Street Carlisle, P A 17013 (717) 243-0123 By: ,., _,,___ -I" -; -,~- = - "~ --- ,'",~ ,,--~-,,' ",-, " <--- '~''"ii;' Coyle Marital Property ProDertv value H w Comments Assets Residence - 702 Sandbank $105,000.00 listing price signed by both parties was ~~109.000 less mortg. ($88,547.91) balance as per statement as of Sepl 2001 less 1/2Iiq. Exp.[4%] ($4,200.00\ $12,252.09 $12,252.09 1993 Ford Ranger . $5,615.00 $5,615.00 Keny Blue Book - retail value 2000 Olds Alero $13,850.00 Kelly Blue Book - retail value less auto loan ($13,345.00\ $505.00 $505.00 Ws pension $10,687.59 less post seoaration contrib. ($510.00' $10,177.59 $10,177.59 as per statement and atty L~an Liabilities: Fleet Mastercard ($4,981.74) ($4,981.74) Members' First Credit Union ($2,000.00) ($2,000.00) Total Net Marital Estate $21,567.94 $10,885,35 $10,682.59 DOS value as per statement DOS value; for sewer connection EXHIBIT I B I j~ }"- __ .J. " '" . ';,,,,,c:. ....1ti,~ -' ... ~ . In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION 13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 11013 Phone: (717) 240-6225 Jl\NUARY 1. 0" 2 0 02 Plaintiff Name: BRIAN C. COYLE Defendant Name: SHELLEY R. COYLE Docket Number: 00258 S 2001 PACSES Case Number: 260103306 Other State,ID Number: 30552 Fax: (717) 240-6248 Please note: All correspondence must include the P ACSES Case Number. Income and Exoense Statement ' TillS FORM MUST BE FILLED OUT (If you are self-employed or if you are salaried by a business of which you are 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?/IJN C. CoYLE- Section I: Income and Insurance INCOME: ""VO/]I.J +/J, c.. Employer -LJ J.. AddIess Type ofWorl< Payroll No. Gross Pay per Pay Period $ /'lAI1.00 Pay Period (wkly., bi'wkly., etc.) Rl"-W'~!dy IteD1ize<i Payroll Deductions: Federal Withholding $1Z,3.bl Social SeCUritv $ Q3"" Local Wage Tax $/7_.111\ Stale Income Tax $">.1/-1.7 ~irement $ Savings BOnds $ Credit Union $ . Life Insurance $ . Health Insurance $ c:.1..CD $ . $ 01her Deductions (specifY) $ $ NetPayperPayPeriod$ QS9.88 OTHER (FilI inAppropriate Column) INCOME WEEK MONTH YEAR InteIest S S S Dividends Pension AMukv .. Social Security Rents Royalties ExDensc Account Gifts uue,;;;;iovment Workmen's Comoensation Other Other TOTAL S S S TOTAL INCOME ~ PROPERTY Ownership · , OWNED DESCRIPTION VALUE H W J Checking Accounta no Z,38 $/-00 .~ ~ ) Savings AccouI\lS /70~3~ 160.00 Ctedit Union Stocl:slBonds Real Estate Other TOTAL I Slob' v" . H=Hosband; W=Wife;J=Joint EXHIl91T Service Type M Fon ~ War D " J.. M " ~ ~,~ ~ ;,;,., -, .' "' O'~ ,- ," ""-""h..1IiI1.~~" Income and Expense Statement PACSES Case Number 260103306 INSURANCE Coverage * COMPANY POLICY # H W C Hospital ~s '[:)J2.N Disability Income Dental 7dl8 -bo.-\\. l"oht.J11e1 * H=Husband; W=Wife; C=Child. ~ ~d Olher Health! Accident Olher Section IT: SUDDlemental Income Statement 3. This form is to be filled out by a person o (1) who operates a bUsiness or practices a profession, or o (2) who is a member of a partnership or joint ventore, or o (3) who is a shareholder in and is sala~ 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'cntily: (I) the most recent FederalJneome Tax Retom,and (2) the most recent Profit and Loss Statement e. Name of business: Address and telephone number: d. Nature of business (check one) o (I) partnership o (2) joint veotore o (3) profession o (4) closed corporation o (5) other c. Name of accountant,. controUe:r or other person in charge: of fma.ocial 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) Specified deductions. if any: Page 2 of3 Form IN"()()8 Worker ID 21207 Service Type M " ~ Income and Expense Statement . ," '~ ,-, [4; ,. ,. h,j.",~ ,_ , ; , " Section ill: EXDenses PACSES Case Number 260J.03306 Instructions: Only show extraordinary expenses in this section unless 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 SupportlAPL 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) EXPENSES WEEK MONTH YEAR Home Mortgage/Rent S S U"l{g S Maintenance / ,"0 Utilities Electric S S 5' $ Gas Oil 1.5'" Telephone 5" Water 300 Sewer "2- Em 10 ent Public Transport. $ $ S Lunch Taxes Real estate S $ S Personal Property Insurance Homeowner's $ $ S Automobile 50 Life Accident Health Other Automobile Payments $ $ $ Fuel 7 0 Repain 2.00 Medical Doctor S S $ Dmtist Onhodootist Hospital Medicine n (glasses, braces, orth .c devk EXPENSES (Fill in Appropriate Column) (continued) WEEK MONTH YEAR Education Private School S S S Parochial School College Religious Personal Clothing $ $ 50 $ Food J!iO . Barberi 1-0 """;~sser Credit Payments Credit Card /50 Charge Memberships . 1./1.5' Loans Credit Union $ $ $ . . Miscellaneous Household Help $ '. $ S Child o:are I Of>- Paperslbooks /f.,~ Ma..,azine.s Entertainment Pay TV Vacation Gills , Legal fees z.ot> Chantable ("nntn"hutlon~ ~~:;:;~hi1d Alimony Pavmert" Other $ $/t(,f.l/A s3n1 I Total I WEEK MONTH YEAR EXDenses: $ $ h("I,'l9, s 3987.'. I verify fuat the statements made in this Income and Expense Statement are true a~d correct. I unde~tand. that false . . statements herein are subject to the criminal penalties of 18 Pa. C.S. ~ 4904. relating unsworn falsification to authonties. 2 ~ Z-~-o 'l-- Date Service Type M Page 3 oD Form IN-OOS Worker ID 21207 ~-. ~ , ...' ~-" . . ~ ~ ,--;",,-, ,.,;;" 'iii-' .> In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION SHELLEY R. COYLE ) Order Number 171 S 2002 Plaintiff ) vs. ) PACSES Case Number 218104297 BRIAN C. COYLE ) Docket Number 00171 S 2002 Defendant ) Other State ID Number ORDER OF COURT (i) Final 0 Interim 0 Modified AND NOW, 26TH DAY OF FEBRUARY, 2002 ,based upon the Court's detennination that the Payee's monthly net income is $ 1,741. 63 and the Payor's monthly net income is $ 2,179.97 , it is hereby ordered that the Payor pay to the Pennsylvania State Collection and Disbursement Unit ONE HUNDRED NINETY SEVEN AND 45/00 Dollars ($197.45 ) a month payable WEEKLY as follows: first payment due MARCH 2002, AT RATE OF $45.60 PER WEEK. The effective date of the order is 01/04/00. Arrears set at $ 338.22 as of FEBRUARY 26, 2002 are due in full IMMEDIATELY. All terms of this Order are subject to collection andlor enforcement by contempt proceedings, credit bureau reporting, tax refund offset certification, driver's license revocation, and the freeze and seize of fmancial assets. These enforcement/collection mechanisms will not be initiated as long as obligor does not owe overdue support. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all the means listed above. For the Support of: Name AMANDA MARIE COYLE Birth Date 06/17/90 EXHIBIT Service Type M Form OE- ~ Worker It s .3 - - ~ COYLE ";" ~'",' , . --- ~~' ~JJiiiLJili.~'-: v. COYLE PACSES Case Number: 218104297 The defendant owes a total of $197,45 WEEKLY $ 154.11 per month payable for current support and $ 43.34 for arrears. The defendant must also pay fees/costs as indicated below. This order is allocated and monies are to be applied as follows: Frequency Codes: Payment Amount! FreqJlp.ncy $ 154.11 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 1 =One Time B =BiWeekly 2 =Bi-Monthly M =Monthly 5 =Semi,Annually S =Semi,Monthly A =Annually W =Weekly Q = Quarterly Oeht Typp. np.~~riptinn Rp.np.fir.i:r(f 1M CHILD SPT ALLOC .l\MANIJA MARIE COYLE I I I I I I I I I I J I I I J J J I I Said money to be turned over by the Pa SCDU to: SHELLEY RENEE COYLE . Payments must be made by check or money order. All checks and money orders must be made payable to Pa SCDU and mailed to: Pa SCDU P.O. Box 69110 Harrisburg, Pa 17106-9110 Payments must include the defendant's PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. Service Type M Page 2 of 4 Form OE-518 Worker ID 21103 ~ " " - '" , ,,~ -'-'- " ,-,",. v.' ;-t'~ COYLE V. COYLE PACSES Case Number: 218104297 Unreimbursed medical expenses that exceed $250.00 annually per child and/or spouse are to be paid as follows: 55 % by defendant and 45 % by plaintiff. The plaintiff is responsible to pay the fIrst $250.00 annually (per child and/or spouse) in unreimbursed medical expenses. (i) Defendant(i) Plaintiff 0 Neither party to provide medical insurance coverage. Within thirty (30) days after the entry of this order, the (i)Plaintiff (i) Defendant shall submit to the person having custody of the child(ren) written proof that medical insurance coverage has been obtained or that application for coverage has been made. Proof of coverage shall consist, 'at a minimum, of: 1) the name of the health care coverage provider(s); 2) any applicable identifIcation numbers; 3) any cards evidencing coverage; 4) the address to which claims should be made; 5) a description of any restrictions on usage, such as prior approval for hospital admissions, imd the manner of obtaining approval; 6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and co-payments; and 8) fIve copies of any claim forms. Other Conditions: 1. ORDER IS BAS~ ON PARTIES AGREEMENT. 2. EACH PARTY SHALL PAY FOR CHILD CARE DURING THE TIME CHILD IS WITH HIM. 3 . UPON VERIFICATION THAT THE DEFENDANT HAS DROPPED HIS MEDICAL INSURANCE COVERAGE, THE ORDER IS TO BE INCREASED TO $217. 67 PER MONTH, AND THE PLAINTIFF WILL BE RESPONSIBLE FOR PROVIDING MEDICAL INSURANCE COVERAGE. 4. AT THE PRESENT TIME BOTH PARTIES TO MAINTAIN MEDICAL INSURANCE COVERAGE ON AMANDA. 5. DEFENDANT TO PAY DIRECTLY TO THE PLAINTIFF 14%' OF THE NET OF ANY BONUSES HE RECEIVES. Defendant shall pay the following fees: Fee Total $ 5. 00 $ 25.00 $ 0.00 $ 0.00 $ 0.00 Fee Description furJUDICIAL COMPUTER FEE for COURT COSTS for for for P~ent Freqllencv Payable at $ 5.00 Payable at $ 25.00 Payable at $ 0.00 Payable at $ 0.00 Payable at $ 0.00 perONE TIME per ONE TIME per per per Page 3 of 4 Form OE-5l8 Worker ID 21103 Service Type M - ~ '"" ~ ~" .~''''H'~'''W~Ji.J,'. COYLE V. COYLE PACSES Case Number: 218104297 IMPORTANT LEGAL NOTICE PARTIES MUST WITHIN .SEVEN DAYS INFORM THE DOMESTIC RELATIONS SECTION AND THE OTHER PARTIES, IN WRITING, OF ANY MATERIAL CHANGE IN CIRCUMSTANCES RELEVANT TO THE LEVEL OF SUPPORT OR THE ADMINISTRATION OF THE SUPPORT ORDER, INCLUDING, BUT NOT LIMITED TO, LOSS OR CHANGE OF INCOME OR EMPLOYMENT AND CHANGE OF PERSONAL ADDRESS OR CHANGE OF ADDRESS OF ANY CHILD RECEIVING SUPPORT. A PARTY WHO WIlLFUlLY FAlLS TO REPORT A MATERIAL CHANGE IN CIRCUMSTANCES MAY BE ADJUDGED IN CONTEMPT OF COURT, AND MAY BE FINED OR IMPRISONED. PENNSYLVANIA LAW PROVIDES THAT ALL SUPPORT ORDERS SHALL BE REVIEWED AT LEAST ONCE EVERY THREE (3) YEARS IF SUCH REVIEW IS REQUESTED BY ONE OF THE PARTIES. IF YOU WISH TO REQUEST A REVIEW AND ADJUSTMENT OF YOUR ORDER, YOU MUST DO THE FOLLOWING: CALL YOUR ATIORNEY. AN UNREPRESENTED PERSON WHO WANTS TO MODIFY (ADJUST) A SUPPORT ORDER SH<?ULD CONTACT THE DOMESTIC RELATIONS SECTION. ALL CHARGING ORDERS FOR SPOUSAL SUPPORT AND ALIMONY PENDENTE LITE, INCLUDING UNALLOCA TED ORDERS FOR CHILD AND SPOUSAL SUPPORT OR CHILD SUPPORT AND ALIMONY PENDENTE LITE, SHALL TERMINATE UPON DEATH OF THE PAYEE. A MANDATORY INCOME ATIACHMENT WILL ISSUE UNLESS THE DEFENDANT IS NOT IN ARREARS IN PAYMENT IN AN AMOUNT EQUAL TO OR GREATER THAN ONE MONTH'S SUPPORT OBpGAl'ION AND (I) THE COURT FINDS THAT THERE IS GOOD CAUSE NOT TO REQUIRE IMMEDIATE INCOME WITHHOLDING; OR (2) A WRmEN AGREEMENT IS REACHED BETWEEN THE PARTIES WHICH PROVIDES FOR AN ALTERNATE ARRANGEMENT. UNPAID ARREARAGE BALANCES MAYBE REPORTED TO CREDIT AGENCIES. ON AND AFTER THE DATE IT IS DUE, EACH UNPAID SUPPORT PAYMENT SHALL CONSTITUTE, BY OPERATION OF LAW, A JUDGMENT AGAINST YOU, AS WELL AS A LIEN AGAINST REAL PROPERTY. IT IS FURTHER ORDERED that, upon payor's failure to comply with this order, payor may be arrested and brought before the Court for a Contempt hearing; payor's wages, salary, commissions, and/or income may be attached in accordance with law; this Order will be increased without further hearing by 0 % a month until all arrearages are paid in full. Payor is responsible for court costs and fees. Copies delivered to parties . fES 2 72till2' Date Consented: Plaintiff Plaintiff s Attorney Defendant DRO: Sally S. Kreitzer XC: Plaintiff DEfendant Taylor Andrews, Esq. Jennifer Lehman, Esq. Defendant's Attorney BY THE COURT: Service Type M -/- , ! J -' ! ____, -' /,1 J / ii/:" (/ C VI J/.. tJESLEY OLER,;JR. j./ I L / Page.4 of 4 ~ Fonn OE-SI8 Worker ID 21103 Judge - J, . .. "-- ,'~""~; -" '~'.,- .' . ~ -i,~; In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION SHELLEY R. COYLE ) Docket Number 001.71 S 2002 Plaintiff ) vs. ) PACSES Case Number 21.81.04297 BRIAN C. COYLE ) Defendant ) Other State ID Nwnber Order AND NOW to wit, this MARCH 1.4, 2002 it is hereby Ordered that: DUE TO THE ORDER OF COURT DATED FEBRUARY 26, 2002, INCORRECTLY SETTING THE PERCENTAGE THAT THE DEFENDANT IS TO PAY THE PLAINTIFF FROM ANY BONUS, THE ORDER IS HEREBY AMENDED TO REFLECT THE CORRECT AMOUNT OF 1.0% OF THE NET OF ANY BONUSES HE RECEIVES TO BE PAID DIRECTLY TO THE PLAINTIFF, IN ALL OTHER RESPECTS THE ORDER TO REMAIN IN FULL FORCE AND ,EFFECT. DRO: XC: Sally S. Kreitzer Plaintiff Defendant Taylor P. Andrews, Esquire Jennifer L. Lehman, Esquire BY THE COURT: / /7 JUDGE Service Type M Form OE-OOI Worker ID 211.03 ,g- '" >~-'-if'-< , - &~-- . --- ---'--___' ..__ ". ._._mu_ _ ------ .. ,.,--,...$/bn1.(/~~_&___" __,_____,___ -------~~-=~~~-~~.,.=---'-~---~- -~-- - . ,--..~Jf,.wfL\\j-90:us..J~-\SIf'f\-Illl-..- ____ i_ ,<(j)nc(S !~L-- . , -l-iUiYlj , -- u- -0;;) . .._ ___, 1L~~tui'es-::.hc XI n~h~ m ;>itle. --- }:tPfS, c'lJ~ctUH. on -,---- ~cI{)I/.b.Je.. bed' Uhs G1C.q,t 6nr,,~h.Yf'Il--- >>s -~--- . rODYYl -~--------,- , , , , I i fJ1IJnt .,L Du 13. WS <+ sne.c-f r: c ie.)(' C r' - 9 jfe 110m 13r/l.uJ ~(:,)Lbf4&S___ ._n____ . . _ .______l1 . --,=..a..irti1l.9-tfJ.wt-__ un ___ ,________ ~'(lalfL:-1nH9 > ci. ~ .._., ,____~_ ,. ____nun, n_'::~lI.&L1b~ -~ - J i SbdJ.e.yJ.s whe.'l-S..he...J,llJLLlB-tlc...__ I _,'._______' ~ t..Dp-t..b...L/l()_tillL,~/1!..~ - Birlhb...Hifdr/l~~.rrii: ~ --=~_~it"~~=~~~-~=,~:~,~~"'... . ,.", ~~~{lj\ l~\e i~~_\C\e~\i ,_'-_~___':'::'~[)S,\ CDD~e.- ~ ,__ \:,o*e\ o~ l\ ~?>/LL~. : L"mc\ cltCK ~ ,- ,"'-'-'-' .1-- ,-~-~-,-,_..-.--,. " --'----'-.-;--. . _1..___--1 t\\~.'(I1~ o\a-tn\A~b d sm~_ ~____ r_ ~()v% EXHIBIT '--- - ,--------,----~~~~-- ------------ I 4 ___.,.__.____,_____';?\I~\Jll'l'€..~W_ ,. .. _______, _ B ~ . J.","", I tJ~~n~=_ '" ,1--. ~~ "- ,. "'-~ , ... , ,_ _-ii"''; _ ,.., '~ <-, s p (4:... to.cJ( +- ---- Ctrc.N::;cbRot,1v ...~~vI>,\~{l5 1--. C~5e-JOIvJ'1\ J,qjrS ~~~~~~~ _____4" . . ~r~-5,,~r~J .!",~rro( \filIi"".? n~~$' '" ?'IS ____ '__n -Ci) __p-_"n\J<LE~_ _____ n____'__~_______n ..__.~"--_.._~---~---"-- . ~ , - -~ ""'--- --..'-l- BRIAN C. COYLE : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW v. SHELLY R. COYLE : NO. 00 - 8840 : IN DIVORCE ORDER AND NOTICE SETTING HEARING TO: Brian C, Coyle Taylor P. Andrews , Plaintiff , Counsel for Plaintiff Shelly R. Coyle Jennifer L. Lehman , Defendant , Counsel for Defendant You are directed to appear for a hearing to take testimony on the outstanding issues in the above captioned divorce proceedings at the Office ofthe Divorce Master, 9 17th North Hanover Street, Carlisle, Pennsylvania, on the April 2003 at 8:30 day of a.m., at which place and time you will be given the opportunity to present witnesses and exhibits in support of your case. By the Court, Date of Order and Notice: 2/21/03 George . 4~', ':JJ1JlC;~ (ifi ~f(1udgi" , ~ , i~ f By: Divorce Master 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 TELEPHONE (717) 249-3166 - ~' -. - ~ -~ b~';; = .-._-- .--:1.:-'; - :"";;;,~_",~ H. .~~~"",; BRIAN C. COYLE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 00 - 8840 CIVIL SHELLEY R. COYLE, Defendant IN DIVORCE NOTICE OF PRE-HEARING CONFERENCE TO: Taylor P. Andrews Attorney for Plaintiff Jennifer L. Lehman , 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 21st day of February 2003, 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: 1/13/02 E. Robert Elicker, II Divorce Master ""'~ ~ ~ BRlAN C. COYLE, v. Plaintiff SHELLEY R. COYLE, Defendant --";"1t'-" , o~ :1" .. ,. .. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA : NO, 2000-8840 : CIVIL ACTION - LAW : IN DIVORCE INVENTORY OF SHELLEY R. COYLE Defendant files the following 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, Defendant verifies that the statements made in this inventory are true and correct. Defendant understands that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities, 9\~~~~~ ~ ~ SHELLEY R. COYLE Defendant ASSETS OF PARTIES Defendant marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages, (X) 1. (X) 2. ( ) 3. ( ) 4. (X) 5. (X) 6, ( ) 7. ( ) 8. ( ) 9, ( ) 10. ( ) 11. Real property Motor vehicles Stocks, bonds, 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 "" - ~" I" () 12. () 13, () 14. () 15, () 16. () 17, () 18. (X) 19. () 20. () 21. () 22. () 23. (X) 24. (X) 25. () 26. " - "-----~~~'--:-->-.. , , JIlli~ ~ ,. . Inheritances Patents, copyrights, inventions, 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 termination benefits - severance pay, worker's compensation claim/award 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, mortgages held Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute) Other MARITAL PROPERTY Defendant lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced: Item Number 1. 2. 3. 4, 5. 6. Description of Property Names of All Owners 702 SaudbankRoad Mt. Holly Springs, P A Plaintiff and Defendant 1993 Ford Ranger Plaintiff and Defendant 2000 Oldsmobile Alero Plaintiff and Defendant Cumberland County Pension Contribution Defendant Household Items Plaintiff and Defendant Personal Property Defendant .,j,j r ~" I. .. NON-MARITAL PROPERTY - ":;'-;:,1"" ^ _1.::_ ,. Defendant lists all property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property: Item Number Description of Property 7. Defendant's State Employees Pension PROPERTY TRANSFERRED Item Number Description of Property Date of Transfer Consid- eration None. LIABILITIES Reason for Exclusion Employment began after separation Person to Whom Transferred Item Description Names of Names of Number ofPropertv All Creditors All Debtors 8. Credit Card Fleet Defendant 9. Credit Card Members' First Credit Plaintiff and Union Defendant :",c, <- '~''j;i 4; :'~''"-'< '" '. - ~ ... __r,,__,:_,_,:__, __,;',,___ '_" 1- 'w XC';""'!' ,,," ,,'"'''''''''''' '''''''''''''liiIiIliIiI I: , ~ , ~ -~~ll~JMjl"MIiI> ""j''''''''-(''<''''''j,jj .. 0 C:.J () c: i"~;' '";'1 ." :-""p: U t~~' ':::) fj-j n!'::: ;.;:: ;::: '., I g~ .. CD ,- ~ ~, 7"'~ ,,.--, .. _.:i. ~~ C) .r-" c: , 5:) ::::1 :....::' -< ,r.' ~: - -1- ,~,,-,~,'- " ,,':,-;';:;~'-'-' -;>-o-C,,-,_ -,- ,__'-_. " '-<tn- _; ''''-,~,:~'';';;';"i;';:~,-' "--""1 I I , . .' 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 do Colyer Office Manager/Reporter West Shore 697 -0371 Ex!. 6535 November 25, 2002 Taylor P. Andrews, Esquire ANDREWS & JOHNSON 78 West Pomfret Street Carlisle, PA 17013 Jennifer 1. Lehman Attorney at Law P.O. Box 6130 27 South Arlene Street Harrisburg, PA 17112-0130 RE: Brian C, Coyle vs. Shelly R. Coyle No, 00 - 8840 Civil In Divorce Dear Mr, Andrews and Ms. Lehman: Both counsel have certified that discovery is complete although Mr. Andrews has qualified his certification by indicating that some updated values will have to be obtained should a hearing be necessary. A divorce complaint was fIled on December 28,2000, raising grounds for divorce of irretrievable breakdown of the marriage and the economic claim of equitable distribution. No claims have been raised for alimony or counsel fees and costs. An affidavit under Section 3301(d) was filed on November 5, 2002, averring a separation in excess of two years, since November 3, 2000, In accordance with P.R.C.P 1920,33(b) I am directing each counsel to file a pretrial statement on or before Monday, December 16,2002. Upon receipt of the pretrial statements, I will immediately schedule a pre-hearing conference with counsel to discuss the issues and, if c.W. ,. I"~ , _:--4,;._-,', -e_- '_ __..:__~<" "-" -, ';;''',G'',' -, ~ "---voo.1 ~ ' -~ . Mr. Andrews and Ms, Lehman, Attorneys at Law 25 November 2002 Page 2 necessary, schedule a hearing. Very truly yours, E. Robert Elicker, II Divorce Master NOTE: Sanctions for failure to file the pretrial statements are set forth in subdivision (c) and (d) of Rule 1920.33. THE ORIGINAL PRETRIAL STATEMENT SHOULD BE FILED IN THE MASTER'S OFFICE AND A COPY SENT DIRECTLY TO OPPOSING COUNSEL. FAILURE TO FILE PRETRIAL STATEMENTS AS DIRECTED BY THE MASTER MAY RESULT IN THE MASTER'S APPOINTMENT BEING VACATED. - _-n-" ~~ , I:,~ ,--- ,~'..: ,~_ .-_iL. IT '_'. c"",,,",,--,,_~ '" _ ... '-.. ..- ~-1l BRIAN C. COYLE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00 - 8840 CIVIL SHELLY R. COYLE, Defendant IN DIVORCE TO: Taylor P. Andrews , Attorney for Plaintiff Jennifer L. Lehman , Attorney for Defendant DATE: Monday, November 18, 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. - ,~~ - ~" ", ~__~ ; -, c- ,'"'C," '"... -~ '~=' ar;io. - - . (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. lI~loa DATE .. ~;J.lliLWJ CO SEL OR PLAINTIFF ( ) COUNSEL FOR DEFENDANT (,f) 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. 011 , ~ 6 , ",L - , ,- ~~, ,'",",--- .,';r~..;_ ANDREWS & JOHNSON Attorneys at Law 78 West Pomfret Street Carlisle, PA 17013 TAYLOR P. ANDREWS RONALD E. JOHNSON Telephone (717) 2413-0123 Telefax (717) 243-0061 November 20, 2002 E. Robert Elicker, II Divorce Master 9 North Hanover Street Carlisle, PA 17013 RE: Coyle vs. Coyle No: 00-8840 Dear Mr. Elicker: I enclose the certification with regard to discovery in the Coyle case. I am hopeful that a pretrial conference may be scheduled without delay, TP A:ss cc: Brian Coyle Jennifer Lehman, Esquire - , , , , , '-1:-, -'~ -~ 'i~'; , -- ' ;.---~ ,- 'L _ --~'-'~-->";"~:_;";;,,o-! NV'l'~l'O}Y BRIAN C. COYLE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00 - 8840 CIVIL SHELLY R. COYLE, Defendant IN DIVORCE TO: Taylor P. Andrews , Attorney for Plaintiff Jennifer L. Lehman , Attorney for Defendant DATE: Monday, November 18, 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. Both parties have had counsel for nearly two years. Correspondence between counsel have effectively defined the marital estate which is not complicated. Aside from updating certain valuations by appraisal or stipulation there is no additional discovery needed at this time. IiIi r "--------,1, ,'~ ".;t- "" ~:;~ -"'*:1 . (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. November 20, ,2002 DATE PLAINTIFF (X) 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. ~ lW': >1 C< - = ,-- :if' '",,-.'c.f >-0__"_' -,,-,,;',-- '-'-~1?, Jennifer L. Lehman ."~~II" Attorney at Law November 21,2002 Robert E. ElIicker, II, Esquire Nine North Hanover Street Carlisle, PA 17013 RE: Brian C. Coyle v. Shelley R. Coyle No. 00-8840 Civil Term, In Divorce Dear Mr, ElIicker: Enclosed please find the certification which I have signed regarding the above-referenced matter. Sincerely, den~LIdnn~ hr Jennifer L. Lehman JLUsf Enclosure cc: Taylor P. Andrews, Esquire Shelley Coyle . b PA 17112.0130.717-671.1200. telecopier 717.671-9601 P.O. Box 6130.27 South Arlene Street. Hams urg, II! - - I _ - . L___ ;;,--'- , "-,~" ; -i ,--,,-', "ie., BRIAN C. COYLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000-8840 CIVIL TERM SHELLEY R. COYLE, Defendant : CIVIL ACTION - LAW : IN DIVORCE ACCEPTANCE OF SERVICE AND NOW, this 12th day of January 2001, I, Thomas S. Diehl, Attorney for the Defendant, Shelley R. Coyle, hereby accept service of the Complaint on behalf of the Defendant, and I certify that I am authorized to do so. ubmitted, iOj . I T mas S. DieW One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX Supreme Court ID No.: 78942 cc: Taylor P. Andrews, Esquire Attorney for Plaintiff ~i;~~~~!m~~_i;%ii;l--ilil~~t~-}L'_:~- - I: 11 . ~" _ _,~o~ ~~- ->-., ,o~_ iiiI.' .~-" " .J , "L.' ~-~ "-' -~ - _~.I-_ -'~~~IiiM- -N I . 2 0 0 -q 3;: L.. -'~ "'U 0:' ;=:~ "T ~rTi z: ;,;;..~ :::::J ::C . . '1"~. 75.= N i~t 05 ;;~: 0'1 -<.<:~". kD -0 ~8 :x r:~~ :!:.! '~';i~C) -c v, ?",-~;.T~ PC: Z ::1 ~ .p.. ::< :n -< -( '/r"""""-- '-. , . ,,~ ' - '"*,~~I~;,~, BRIAN C. COYLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA v. : NO. 2000-8840 SHELLEY R. COYLE, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE FOR WITHDRAWAL AND ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly withdraw the appearance of Thomas S. Diehl, Esquire on behalf of the Defendant, SHELLEY R. COYLE, in the above-captioned action. Kindly enter the appearance of Jennifer L. Lehman, Esquire, on behalf of the Defendant, SHELLEY R. COYLE. Respectfully s 1 Thomas S. iehl, Esquire -461 ElI.lLvutli"l Strbet ( ....... "l~ ..ft..J- Carlisle, PA 17013 Dated: ~ - V:l -8{ Respectfully submitted, By ~,IJ~)J~) Jennifer L. Lehman, Esquire 27 South Arlene Street P.O. Box 6130 Harrisburg, PA 17110 (717) 671-1200 Dated: ;)-IJ-OI ~~'~m>4~~:~\<ft- -,,",,",iil'l1,;;!',,~..fulj,~!;;-jijY<l-t!\'I~,"i.~;,~'> ,",,",";~"&h0;,,";- '"""" ,,;,iltJ.-'~\{tSi':liiQ~h1'i~~_'@~'II~'~fumM~"W!ifr,Wi<"~wbiiiFi!.&,ilii~'!il~~ijati~~l,g-'~~-lft---..j,'~_ ~.{-';' ,., ~;i 0 '..J c: " -?'" ____1 _1"" -,..~ C,C ::-;::> rf! ~_.1 c;Q ~-,- 1 .~ en -', r- -u " ~,~~ --... ( C:? , ~:s :,,) :D -< I .0 ~; u - ,~.- -', ~ .' ""}i'W: .., .... BRIAN C. COYLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA vs. : CIVIL 2000-8840 : CIVIL ACTION - LAW SHELLEY R. COYLE, Defendant : IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Brian C. Coyle, Plaintiff, moves the court to appoint a master with respect to the following claims: (X ) Divorce ( ) Annulment ( ) Alimony ( ) Alimony Pendente Lite (X ) Distribution of Property ( ) Support ( ) Counsel Fees ( ) Costs and Expenses and in support of the motion states: I. Discovery is complete as to the claim(s) for which the appointment of a master is requested. 2. The defendant has appeared in the action by her attorney, Jennifer Lehman, Esquire. The Plaintiff has appeared in the action by his attorney, Taylor P. Andrews, Esquire. 3. The statutory ground( s) for divorce is Section 330 I (d) of the Divorce Code-2 year separation. Marriage is irre1:rievably broken. 4. The action is contested with respect to the following claims: equitable distribution. 5. The action does not involve complex issues oflaw or fact. 6. The hearing is expected to take _4_ hours. 7. Additional information, if any, relevant to the moti o c -uS, o --n Date: November 5, 2002 a f''' 2: r.::> ,.,,; 0~: ~i -'1;~ ~ r'--, ".~~ 1) ~:" :.b~ ,-""i-i ") . ORDER APPOINTING MASTER s;g ::K;2i~ AND NOW, ~ j- ,2002, E. Robert Elicker, Esquire is appoin~ m>iJ.11,r wi respect to the following claims: Divorce and Distribution of Property. ayl P. Andrews, Esq. omey for Plaintiff ~H':ild. .-'~lii~:01!~~,-b:;w "!.Jjl.~_i!]liilld~~IJl;~~~m' .... .~ ,~^ M ~ .. _Iii-I 1i!.;,'>G~.:iSIliGl - (') c: <: ""t.l C::~I fllil Z::J:~' zr~ 0) ), -<:::: ~C.: )>(-- Z J --,.(1 PC: ~J ~. - .c 'c .~'~. ,cc, 'C c, " c: 1"'''<1' ~~ :~d , (F; /') IQ Ll..., ..,!',,-; " ~'l 8~ :;! :r;J -< :0.'" -'.. co :.n ,,~ , ,. ,~ L.,' ,'.;] ';", '-' i";~.. -~"t,'"_ ",,-. _, _. "~ ANDREWS & JOHNSON Attorneys at Law 7 8 West Pomfret Street Carlisle, PA 17013 TAYLOR P. ANDREWS RONALD E. JOHNSON Telephone (717) 243-0123 Telefax (717) 243-0061 December 11, 2002 E. Robert Elicker, II Divorce Master 9 North Hanover Street Carlisle, PA 17013 RE: Coyle vs. Coyle No: 00-8840 Pretrial Statement Dear Master Elicker: I enclose Plaintiff s Pretrial Statement in the above referenced case. 1 look forward to receiving the date of a Prehearing Conference when we may all get together to see if this case may be resolved. 1 wish you a very Happy Holiday Season. Sincerely yours, TP A:ss cc: Brian Coyle (w/encl) Jennifer Lehman, Esquire (w/encl) ]~,.,-;-~; Jennifer L. Lehman ..~6.~i' Attorney at Law December 16, 2002 HAND DELIVERED TO: Robert E. Ellicker, II, Esquire Nine North Hanover Street Carlisle, PA 17013 RE: Brian C. Coyle v. Shelley R. Coyle No. 00-8840 Civil Term, In Divorce Dear Mr. Ellicker: Enclosed please find the Defendant's Pre-trial Statement Pursuant to Pa. R.C.P. 1920.33(b) which I have filed today regarding the above-referenced matter. Sincerely, ~d,~ Jennifer L. Lehman JLL:lsf Enclosure cc: Taylor P. Andrews, Esquire Shelley Coyle EO. Box 6130 . 27 South Arlene Street. Harrisburg. PA 17112-0130 · 717-671-1200 · telecopier 717-671..9601 Iil~~ ,.." BRIAN C. COYLE, L.... ."" , _J '" '-"~J"~r.' Plaintiff W. \{p'D~~f/ : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA v. : NO. 2000-8840 SHELLEY R. COYLE, Defendant I. ASSETS: : CIVIL ACTION - LAW : IN DNORCE DEFENDANT'S PRE-TRIAL STATEMENT PURSUANT TO Pa R.C.P. 1920.33(b) PRESENT VALUE A. Marital Property: 1. 702 Sandbank Road Mt. Holly Springs, P A $106,500.00 2. 1993 Ford Ranger $ 5,615.00 3. 2000 Oldsmobile Aero $ 8,375.00 $ 9,355.05 4. Defendant's Cumberlan9 County Pension Contributions (current value of rollover into American Express IRA) 5. Household items and guns A. Plaintiff's possession B. Defendant's possession $ 11,072.00 $ 1,974.00 6. Personal Property $ Unknown B. Non-Marital Property: 7. Post separation contributions to Defendant's Cumberland County'Pension $ 590.00 8. Defendant's State Employee Retirement Pension $ Unknown .~,,~~ - I~~.. ".', I~;: ; II. EXPERT WITNESSES: None. m. NON-EXPERT WITNESSES: None. IV. EXlITBITS: Based upon figures used in prior negotiations, counsel for Defendant believes that the parties will stipulate to most of the values. Defendant retains the right to enter exhibits to show the value of an asset with an unstipulated value. These will be identified at the pre-trial conference. As to the disputed personalty, Defendant attaches Exhibit A - a list of household items in Plaintiffs possession and Exhibit B - a list of household items in Defendant's possession. Also attached is a list of personal items (Exhibit C) which are items which the Defendant would like returned to her. V. INCOME OF THE PARTIES: A. Plaintiffs Income Plaintiff has been employed by Eberts Paints and Wallcovering, or its predecessors, for over ten years. Cumberland County Domestic Relations Office determined that as of February, 2002, his base net monthly income was $2,179.97, excluding bonuses. B. Defendant's Income Defendant is currently employed by the Commonwealth of Pennsylvania, Department of Revenue, with a net monthly income of$1,618.00. VI. EXPENSE STATEMENT: An Expense Statement for the Defendant is filed herewith. '"" ... I,~ -----" " H ,"' .;.'''"-' It,Yllil-, '~~, VII. PENSIONS/RETIREMENT: A. Plaintiff's Retirement Although Plaintiff has been continuously employed at the same establishment for over 10 years, he claims to have no retirement benefits. B. Defendant's Retirement Defendant participated in the Cumberland County Pension plan from 1995 through May 1, 2001. She was terminated prior to her benefits vesting, so only her contributions were refunded. The contributions totaled $10,687.59 with approximately $590.00 of post separation contributions. The entire amount was rolled over into an IRA with American Express. There have been no additional contributions. The value of the account as of August 6,2002 was $9,355.05. Defendant has been employed with the Commonwealth of Pennsylvania since January, 2002, and is required to participate in the State Employees' Retirement Plan. VIII. MARITAL DEBTS: A. The marital residence is encumbered by a mortgage owed to PHH with a balance of$87,316.11 as of November 30, 2002. B. There is a Fleet Mastercard with a balance of $4,98 1.74 as of the date of separation. C. There is a loan against the 2000 Oldsmobile Alero with a balance of $11,421.14. ~ ,-"', ", ~. ,',,-., ,>>."", ~ "'in.,! lX. PROPOSED RESOLUTION: Plaintiff would keep the marital home, his truck, household goods, and guns. He would also pay the Member's 1" loan and the Fleet credit card. Also, we would request that he refinance the mortgage loan and credit card debt so as to remove Defendant's name. Defendant would keep her retirement and car. Ifher name were removed from the other marital debts, she could then, in turn, remove Plaintiff's name from her car loan. Also, Defendant would like the attached list of items returned to her. In order to equalize the distribution, Defendant proposes a lump sum payment of $10,000.00 from the Plaintiff. Respectfully submitted, By :x~ J: ~0- Jennifer L. Lehman, Esquire 27 South Arlene Street P.O. Box 6130 Harrisburg, PA 17112-0130 (717) 671-1200 I.D. No. 52784 DATED: December 16,2002 ~ " .... I_~ ........,., , ..~ ~ ," ~ ^ ,~ 07/26/2002 15:05 HBG PHOfE UNIT 71 7 -783-012901 List of marital assets in Brian Coyle's pQssession: 1. GE Refrigerator $500,00 2. GE Washer & Dryer $700.00 set 3, Microwave $125.00 4, 27in Color TV $299.00 5. Entertainment Center $200.00 6. Sharp Stereo System $215,00 7. Patio Table and Chairs $100.00 8. Cr.ut5lIlllI1 Lawnmower $200.00 9, Gas Fire Place w/gas logs (package) $350.00 10. Dell Computer Package ftower, monitor. printer,speakers) $3000.00 11. Computer Desk wI chair $240.00 12. Dehumjdifier $140.00 13. Sofa Bed and Chair (set) $800.00 14. Small Side Tables $40.00 15, Coffee Tables and End Tables (set of 3) $125.00 16. Leaf Blower $100.00 17. Guns (no value detennined-need appraisal) $?????'? 18. Bedroom set (Amanda'solid wood! maple) $500.00 19, Labot'adorReU\.-iver (family dog! Sable). $200.00 20. 13 in Color TV $ 90.00 21. GE VCR $ 90.00 22. Recliner (brown) he got rid of this chair $125.00 23 FlcJr.ll Curtains (living room) $175.00 24. Trampoline $199.00 25. Dark Blue Huffy Mountain Bike (amanda's) $100.00 26. 2 TV Stands' $100.00 27. Quill Set from Master bedroom (quilt & shams) $ 75.00 28. Student Desk (Amanda's) wi chair $ 80.00 29. Landscaping (p..."Iennials & Bushes) $200.00 30, Carpeting (downstairs) $800.00 31. Barstools (solid oaklset of 2) $100,00 32. SOllY P1aystation wi games $250.00 33. Smoked glass Lamps (set of 2) $100.00 34. 14x16in Professional Portrait of Amanda $ 59.00 35. GE Answering ~chine $ 35.00 36. Malibu Light Scot (exterior lighting) $100.00 37. lGrchen misc. urensils and dishes, potsIpans, glasses, toaster, Meat Grinder etc. $200.00 38. Tools (drill, power saw, portable lighting, wrench set, screw- driver set etc. . $200.00 39. Gas Grill (Charbroil) $150.00 Assets total $11,072.00 "EXHIBIT A" ,'\'" ~t<~",'; PAGE 0:::/03 _-1 - .~~- ~ 07/26/2002 15:05 3. 4. 5. 6. 7, 8. 9. 10. 11. P ,~I - " .~'"' l ~ " , ." - 717-783-4::94 HEG PHONE UNIT List of Marital Assets in Shelley Coyle's Possession: 1. ., .- Sofa & Coffee Table wI end Tables Glider Rocker Phaltzcr<lft Dish Set Kitchen Table wI Chairs & Hutch (set from my Mom! Lamps (set of 2 from Mom) Bedroom Set (bead board/footboard. chest of drawers dresser bureau (from great gL"andmorhers estate) 19 in Color TV (Sharp) TV Stand Kitchen Items (misc. pots/pans, dishes toaster, crock pot) Mountain Bike (purchased from Friend) Cheval Mirror VCR (Admiral) Assets Total "EXHIBIT B" ;,', $850.00 $ 99.00 $125.00 $100.00 $ 60.00 $100.00 $190.00 $ 60.00 $200.00 $ 50.00 $ 60,00 $ 80.00 $1,974.00 "'-- ,:&t..::~?f_,; PAGE 03/03 ~-, . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~ ,~ I~ .nt" ~ ';.",.-l~' "_~ 1,<; , -,'., , ""~. ~. 1~ ,;L ""~ LIST OF ITEMS TO BE RETURNED TO SHELLY COYLE All Home and Garden Party items (small pitcher and sugar bowl) Curio shelf in dining room with greenery and wooden apples (gift from friend at work) Small shelf beside patio door . Small picture above shelf by patio door Half basket on wall opposite door with floral arrangement in it Longaberger basket from work (from boss) Any Keaton pottery, including apple pencil holder from curio shelf Large apothecary candle with potpourri lid Valances above kitchen window, patio door and kitchen door Greenery vines above all kitchen windows and doors Six cast iron trivets (fruit) handing on soffit in kitchen Grapevine swag and fruit swag hanging on soffit in kitchen Bless this home picture hanging above kitchen sink on soffit Small green shelf by kitchen back door Apple plaques (small wooden) in kitchen Two pictures in dining room (hanging herbs) from Home and Garden (bought from Home and Garden party) Tan toaster cover in kitchen (Sher made) Ice shaver from Pampered Chef in cabinet above refrigerator Sandwich maker in dining room cabinets (electric) Shell baker in dining room cabinets (electric) Green table cloth, vinyl lace table cloth, santa and birdhouses tablecloth (gift) Long planter basket with greenery above stove Thigh master in coat closet in all (gift) . Blue aerobic step in basement on shelves Burgundy colored floral arrangement on entertainment center in living room Patio table and chairs with cushions Amanda's mountain bike Basket picture above entertainment center in living room Burgundy porcelain doll on entertainment center Ballerina porcelain doll on stereo speaker (gift) Bride porcelain doll (gift) Bird house mantel clock Bean bag chair, bear stuffed animal and brown dog (gifts from Sher) Lab stuffed animal and any Boyd's Bear stuff animals (large bunny and bear) Shelf with closing doors in bathroom Electric tart burner (buck) in basement All furniture from Amanda's room (t1).is was Shelley's prior to marriage) Little chair with Amanda's name on back All porcelain dolls in Amanda's room (gifts) All Beanie Baby animals that I purchased "EXHIBIT C" "" ~"~ " MO .. ~ · Small Beanie Babies that I purchased · Large wood shelf in Amanda's room · Dreamsicle plaque in Amanda's room (gift) · Personalized picture in Amanda's room · Two maple shelves in Amanda's room · Deer picture in basement by computer stand with two wood wheat shelves · Green wrought iron flower cart · Carry on shoulder bag to match luggage set · Two white lounge chairs in shed (gift) · White metal cookie racks in kitchen cabinets · Cast iron meat grinder and attachments · Sugar bowl and creamer for Phaltzcraft dish set . Wood entertainment center . Select CD's · Stereo or large TV in living room . Wrought iron heart shaped plant hanger in shed · Porcelain lawn ornaments, signs, frogs, burmies, pick signs, flag holders · Comer shelf under air conditioner unit · Ficus tree with white flowers . Green shelf from third bedroom with two green sconces . Small standing shelf (green) from third bedroom . All twin size sheet sets for Amanda's bed . Wood ladder shelf from third bedroom with figurines . Basket stand from third bedroom with burgundy floral arrangement . Wreath above mantle in living room . Amanda's Disney movies bought by Shelley's family as follows: Beauty and the Beast Beauty and the Beast Christmas Aladdin ( set) Cinderella Little Mermaid Dr. Do Little George of the Jungle Grease Dumbo Bambi Stewart Little Billboard Dad Olsen Twins (ballet) Great Mouse Detective Sword in the Stone The Craft Casper Parent Trap Parent Trap with Hailey Mills '~,....:. '"" o~'~"-r~Wi.E: '"' . j " Poly Anna · All Olsen Twin movies · All Land Before Time movies (5 in series) · Two small wood tables down stairs · Touch lamp from third bedroom · Oscillating fan on stand · Burgundy centerpiece on entertainment center · Pastel comforter set from Amanda's bed including white toss pillows ,." " ,"'.;'__,c'<..' u ~~ _~~;; - t'" , , ~ ~,'k!., < 0;"" [""i...; CERT~CATEOFSERVICE I, Jennifer L. Lehman, Esquire, hereby certify that on this 16th day of December, 2002, I served a true and correct copy of the foregoing by depositing the same in the United States mail, first class postage prepaid, addressed as follows: Taylor P. Andrews, Esquire Andrews & Johnson 78 West Pomfret Street Carlisle, PA 17013-3216 ~M /11 I /1{ I ;; JJ. /i'Ycru ) Je ifer L. Lehman, Esquire P.O. Box 6130 27 Sonth Arlene Street Harrisburg,PA 17112 (717) 671-1200 ...&i ,of ~ _.~" . . " '~ "~ ~ <'C ~, . BRIAN C. COYLE Plaintiff ; IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-8840 CIVIL TERM SHELLY R. COYLE Defendant : CIVIL ACTION - LAW : IN DIVORCE PLAINTIFF'S PRETRIAL STATEMENT AS PER PA. R.C.P. 1920.33(b) 1. ASSETS. The marital assets are set forth on Exhibit 1 attached. 2. EXPERT WITNESSES. There is no apparent need for expert testimony, unless the parties cannot agree upon the fair market value of the marital residence [occupied by Mr. Coyle]. The value shown on Exhibit 1 is based upon a listing agreement signed by both parties and advice provided by a listing realtor. If an appraisal is needed, Plaintiff shall seek a stipulation with Defendant to retain one realtor and to split the cost of an appraisal. 3. LAY WITNESSES. None anticipated except the Mr. Coyle. Plaintiff reserves the right to amend this portion of the Pre-Trial Statement with at least ten days notice to the Defendant of any lay witnesses he intends to call. 4. EXHIBITS: 1. Statements of mortgage balance on marital residence currently and as of the date of separation. 2. Statement of retirement funds refunded to Mrs. Coyle in June 2001. 3. Statement of balance owed on Fleet Master Card as of the date of separation. 4. Statement of balance owed to Members' First Credit Union as of the date of separation. ,. ",~, ~'~'""" ~~' '., '->'--~,: 5. [IF NECESSARY] An appraisal of the value of the marital residence at 702 Sandbank Rd., Mt. Holly Springs, P A. 6. [IF NECESSARY] An itemized list of the personal property retained by Plaintiff after Defendant removed the personal property she wanted from the residence. 5-6. INCOMEIEXPENSES Plaintiffs income and expenses are as shown on the Income and Expense statement that he filed with the Cumberland County DRO in January 2002. A copy of this statement is attached hereto as Exhibit 2. DRO calculated Plaintiff's net income in February 2002 as $2,179.97. Plaintiff can be eligible for incentive bonuses from his employer and he was ordered to pay Defendant 10% of all such bonuses. Defendant is now a state employee, and her net income was calculated in February as being $1,741.63 per month. Plaintiff pays child support to Defendant in the amount of $197.45 per month. The support orders referenced herein are attached hereto as Exhibit 3. 7. PENSION/RETIREMENT BENEFITS At the time of the separation Mr. Coyle had no retirement or pension plan or benefits. Mrs. Coyle was an employee of Cumberland County with nearly 8 years of service. Since the time of separation Mrs. Coyle has left the employment of Cumberland County and she has withdrawn her retirement benefits from Cumberland County. These proceeds are already included in the spreadsheet attached hereto as Exhibit 1. 8. COUNSEL FEES/COST There is no claim for counsel fees or costs. 9. TANGIBLE PERSONAL PROPERTY After the parties separated Mrs. Coyle removed much of the parties' personal property from the marital residence. She made a list ofthe items that she took. This list is attached as Exhibit 4. Mr. Coyle has also made a list , of items that he contends his wife also took. This list is attached as Exhibit 5. In the spring of 2002, more than a year after the separation, Mrs. Coyle, through counsel, provided a 2+ page itemized list of additional items that she wished to have. She also claimed that the value of the marital property in Mr. Coyle's possession exceeds the value of the personal property in her possession by $4,000. Mr. Coyle disputes this assertion. He contends that the personal property has been evenly divided as is. No personal property appraisal has been performed. 10. MARTIAL DEBTS The only debts that need to be taken into account are listed on Exhibit 1 attached hereto. 11. PROPOSED RESOLUTION Plaintiff proposes a 50/50 division of the maJital property with the property to be distributed as shown on Exhibit 1 attached hereto. By I r P. Andrews, Esq. 7 est Pomfret Street Carlisle, P A 17013 (717) 243-0123 Supreme Court ID No. 15641 ~~' ""'~4jitj "" ,~L I ~ =" ~'. - ;'; -, ,,;, ~,.....' -- W} BRIAN C. COYLE Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00-8840 CIVIL TERM v. SHELLY R COYLE Defendant : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that on this date, December II, 2002 I mailed a copy of Plaintiffs Pretrial Statement as per Pa. RC.P. (1920.33(b) to the following person at the following address by U.S. Mail, postage prepaid and addressed to: Jennifer L. Lehman, Esq. P.O. Box 6130 27 South Arlene St. Harrisburg, PA 17112-0130 1 verify that the statements made in the foregoing Certificate of Service are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904, relating to unsworn falsification to authorities. ANDREWS & JOHNSON T 10 P. Andrews, Esq. neys for Plaintiff 78 W. Pomfret Street Carlisle, P A 17013 (717) 243-0123 By: .~ "J, , ~;I Coyle Marital Property Propertv value !:! w Comments Assets Residence - 702 Sandbank $105,000.00 listing price signed by both parties was $'109,000 less mortg. ($88,547.91) balance as per statement as of Sept. 2001 less 1/2 Iiq, Exp.[4%] ($4,200.00) $12,252.09 $12,252.09 1993 Ford Ranger . $5,615.00 $5,615.00 Kelly Blue Book - retail value 2000 Olds Alero $13,850.00 Kelly Blue Book - retail value less auto loan ($13,345,00) $505.00 $505,00 W's pension $10,687.59 less past separation contrib, ($510.00) $10,177.59 $10,177.59 as per statement and atty Lehman Liabilities' Fleet Mastercard ($4,981.74) {$4,981 ,74) Members' First Credit Union ($2,000.00) ($2,000.00) Total Net Marital Estate $21,567.94 $10,885.35 $10,682.59 DOS value as per statement DOS value; for sewer connection EXHIBIT ,; i I ""' ~ , ,I ~ _"""~"",,,~,~ 1 ~ ~""=>IIIl'~ ,I ~" ,~' , '"' , - '& .~" '~ "i'~ '~'-i!:~ -. .. . In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Phone: (717) 240-6225 , DOl\lESTlC iu:uTIONS SECTION 13 N. HANOvER ST, P.O. BOX 320, CARLISLE, PA. 17013 JANUARY 10, 2002 Plaintiff Name: BRIAN C. COYLE Defendant Name: SHELLEY R. COYLE Docket Number: 00258 S 2001 PACSES Case Number: 260103306 Other State ID Number: 30552 Fax: (717) 240-6248 Please note: AIl correspondence must include the P ACSES Case Number. Income and Ex;pense Statement ' TIllS FORM MUST BE FILLED OUT (Iryou are self-employed or if you are salaried by a business of which you are 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 ffilf11J C. CoYLf-, Section I: Income and Insurance INCOME: Employer '/:) \J (",-1 We,. AddIesS Type ofWodi: Payroll No. Gross Pay per Pay Period $ IZ..9fJ. DO Pay Period (wkly., bi'wkly., etc.) RI....W'<<.kly Itemized Payroll Deductions: Pederal Wtthhold;n. . $11.3.1>' Social SecuritY . $ Q3.t.l/ Local Wage Tax $ /7 .41\ State Income Tax $.../1.1.7 RetiIement $ . . Savings BOnds $ Credit Union $ Life Insurance $ Health Insumlce $.t;,J..CO Other Deductions (specilY) S $ . $ $ I Net Pay per Pay Period $ q 59. 68 OTHER (Fill in.Appropriate Column) INCOME WEEK MONTH YEAR Interest $ $ $ Dividends Pension Annuitv ,. Social Secum. Rents Ro-;;;lties Exoense Account Gills Une=loVD1Cnt Workmen's CornnP.nsation Other Other TOTAL $ $ S TOTAL INCOME ~ PROPERTY Ownership · OWNED DESCRIPTION VALUE H W J Checking Accounts na Z,3R $ /-00.'" ~ Savings Accounts /7on\( (60.00 \ Credit Union StockslBonds Real Estate Other TOTAL ISlob'uO * H~Husband; W~Wife; I=Iolnt EXHII3IIT , Service Type M Pon .... ~ Wo Jj ~ -, - - ~ ,l~" . Income and Expense Statement PACSES Case Number 260103306 INSURANCE Coverage II: COMPANY POLICY # H W C Hospital ~s M~1Je,' '. ~d Other Health/Accident 1J(2.N Disability Income Dental 7dlt --t..1\- I~00t-/ If., · H~Husband; W=Wife; C=Child Other Section II: Supplemental Income Statement a. This form is to be fIlled ,out by a person o (1) who operates a business or practices a profession. or o (2) who is a member of a, partnership or joint venture. or o (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, professio~ corporation or similar entity: (l) the most recent Federal Income Tax Return, and (2) Ibe most rerem Profn and Loss Statemem c. Name ofhusiness: Address and telephone number: d. Nature of business (check one) o (1) partnership o (2) joint venture o (3) profession o (4) closed colporation o (5) other e. Name of accountant. controller or other person in charge of fmancial records: f. Annual income from business: (1) How often is income received? (2) Gross income per pay period: (3) Net income per pay period: (4) SpeciflCd deductions, if any: Page2of3 Form IN-008 Worker ID 21207 Service Type M '. "~ 'l'iU""'-'-1f;iJ ~~~ . ~ Income and Expense Statement ~ ... , 0'--'" ..n~,,: Section III: Exnenses PACSES Case Number 260103306 Instructions: Only show extraordinary expenses in this section unless 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. (FilI in Appropriate Column) EXPENSES WEEK MONTH YEAR Horne Mortgage/Rent $ $ Maintenance ."0 Utilities Electric $ $ Gas Oil 1..'0 Telephone SS- Water .::loo Sewer 1- Em 10 ent, Public Transport:. $ $ $ Luncb axes Real estate $ $ $ Personal Property Insurance Homeowner's" $ $ $ Automobile 50 Life Accident Health. Other Automobile PaymeDlS $ $ $ . Fuel 7 b Repairs z.o!:> Medical Doctor $ $ $ Dentist Orthodontist Hospital Medicine n (glasses, braces, 0 . devic EXPENSES (Fill in Appropriate Colunm) (continued) WEEK MONTH YEAR Education Private School $ $ $ Parochial School College Religious Personal Clothing $ $ 50 $ Food 160 Barber/ 2.0 H'irdre,se_ Credit-Payments Credit Card /5'0 Charge . Memberships l/t.~ Loans . . Credit Union $ $ $ . . Miscellaneous Housebold Help $ $ $ Cbildcare 101>. Papenlbooks I"'~ Ma~ines Entertainment Pay TV Vacation Gifts Legal fees ~Ob Chantable Con'n"u,;nn, UtherCbild ."n~'" Alimony P'~ent< Other $ $I1{,{.I/~ $ 3'167 I Total I WEEK MONTH YEAR Expenses: $ $ h{,,/.t{f, $ 3987." I verify that the statementa made in this Income and Expense Statement are true and correct I unde~tand that false , , statements herein are subject to the criminal penalties of 18 Pa. C.S. ~ 4904, relating unsworn falsIfication to authonties. z - Z-~-(j L- Date Service Type M Page 3 of? Fonn IN-008 Worker 1D 21207 ,-~ .~ - , ~"" ilillc~;'iu;l\l!li , In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION SHELLEY R. COYLE ) Order Number 171 S 2002 Plaintiff ) vs. ) PACSES Case Number 218104297 BRIAN C. COYLE ) Docket Number 00171 S 2002 Defendant ) Other Slate ID Number ORDER OF COURT <i) Final 0 Interim 0 Modified AND NOW, 26TH DAY OF FEBRUARY, 2002 ,based upon the Court's determination that the Payee's monthly net income is $ 1,741.63 and the Payor's monthly net income is $ 2,179: 97 , it is hereby ordered that the Payor pay to the Pennsylvania State Collection and Disbursement Unit ONE HUNDRED NINETY SEVEN AND 45/00 Dollars ($ 197.45 ) a month payable WEEKLY as follows: first payment due MARCH 2002, AT RATE OF $45.60 PER WEEK. The effective date of the order is 01/04/00 . Arrears set at $ 338.22 as of FEBRUARY 26, 2002 are due in full IMMEDIATELY. All terms of this Order are subject to collection and/or enforcement by contempt proceedings, credit bureau reporting, tax refund offset certification, driver's license revocation, and the freeze and seize of financial assets. These enforcement/collection mechanisms will not be initiated as long as obligor does not owe overdue support. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all the means listed above. 'For the Support of: Name AMANDA MARIE COYLE Birth Date 06/17/90 EXHIBIT , Service Type M Form OE- ~ Worker I i 'I .j, . ~' ~ " COYLE " . "~' ~. O!Jii~it,:;! ~ >-.. 'J'.--, "'~' V. COYLE PACSES Case Number: 218104297 The defendant owes a total of $197.45 WEEKLY $154.11 Frequency Codes: Payment Amount! Freqnency $154.11 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 per month payable for current support and $ 43.34 for arrears. The defendant must 1 =One Time B =BiWeekly 2 =Bi-Monthly 5 =Semi-Annually S =Semi-Monthly A =Annually M = Monthly W =Weekly Q = Quarterly np.ht Typp. np.~r.ription Rp.nf~fic:i::Jt}' 1M CHILD SPT ALLOC AMANDA MARIE COYLE I I I I I I I I I I I I I I I I I I I Said money to be turned over by the Pa SCDU to: . Payments must be made by check or SHELLEY RENEE COYLE money order. All checks and money orders must be made payable to Pa SCDU and mailed to: Pa SCDU P.O. Box 69110 Harrisburg, Pa 17106-9110 Payments must include the defendant's PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. Service Type M Page 2 of 4 Form OE-518 Worker 1D 21103 .~" ~' " ,,' '"0''''''';'' <~- ~. "'~ _~ ~~~! COYLE V. COYLE PACSES Case Number: 218104297 Unreimbursed medical expenses that exceed $250.00 annually per child and/or spouse are to be paid as follows: 55 % by defendant and 45 % by plaintiff. The plaintiff is responsible to pay the first $250.00 annually (per child and/or spouse) in unreimbursed medical expenses. GY DefendantGY Plaintiff 0 Neither party to provide medical insurance coverage. Within thirty (30) days after the entry of this order, the GYPlaintiff GY Defendant shall submit to the person having custody of the child(ren) written proof that medical insurance coverage has been obtained or that application for coverage has been made. Proof of coverage shall consist, 'at a minimum, of: 1) the name of the health care coverage provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims should be made; 5) a description of any restrictions on usage, such as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms. Other Conditions: 1. ORDER IS BASED ON PARTIES AGREEMENT. 2. EACH PARTY SHALL PAY FOR CHILD CARE DURING THE TIME CHILD IS WITH HIM. 3. UPON VERIFICATION THAT THE DEFENDANT HAS DROPPED HIS MEDICAL INSURANCE COVERAGE, THE ORDER IS. TO BE INCREASED TO $217.67 PER MONTH, AND THE PLAINTIFF WILL BE RESPONSIBLE FOR PROVIDING MEDICAL INSURANCE COVERAGE. 4. AT THE PRESENT TIME BOTH PARTIES TO MAINTAIN MEDICAL INSURANCE COVERAGE ON AMANDA. 5. DEFENDANT TO PAY DIRECTLY TO THE PLAINTIFF 14% OF THE NET OF ANY BONUSES HE RECEIVES. Defendant shall pay the following fees: Fee To1a! $ 5.00 $ 25.00 $ 0,00 $ 0.00 $ 0.00 Fee Description for JUDICIAL COMPUTER FEE for COURT COSTS for for PlIYmen1 Freq,uenqy Payable at $ 5.00 Payable at $ 25.00 Payable at $ 0 . 00 Payable at $ 0.00 Payable at $ 0.00 perONE TIME per ONE TIME per per per for Page 3 of4 Form OE-518 Worker lD 21103 Service Type M '1- I . - , __~ '. , ,'J i " ,",,' ih,. COYLE v. COYLE PACSES Case Number: 218104297 IMPORTANT LEGAL NOTICE PARTIES MUST WITHIN ,SEVEN DAYS INFORM THE DOMESTIC RELATIONS SECTION AND THE OTHER PARTIES, IN WRITING, OF ANY MATERIAL CHANGE IN CIRCUMSTANCES RELEVANT TO THE LEVEL OF SUPPORT OR THE ADMINISTRATION OF THE SUPPORT ORDER, INCLUDING, BUT NOT LIMITED TO, LOSS OR CHANGE OF INCOME OR EMPLOYMENT AND CHANGE OF PERSONAL ADDRESS OR CHANGE OF ADDRESS OF ANY CHILD RECEIVING SUPPORT. A PARTY WHO WlUFUUY FAlLS TO REPORT A MATERIAL CHANGE IN CIRCUMSTANCES MAY BE ADJUDGED IN CONTEMPT OF COURT, AND MAY BE FINED OR IMPRISONED. PENNSYLVANIA LAW PROVIDES THAT ALL SUPPORT ORDERS SHALL BE REVIEWED AT LEAST ONCE EVERY THREE (3) YEARS IF SUCH REVIEW IS REQUESTED BY ONE OF THE PARTIES. IF YOU WISH TO REQUEST A REVIEW AND ADJUSTMENT OF YOUR ORDER, YOU MUST DO THE FOLLOWING: CALL YOUR ATTORNEY. AN UNREPRESENTED PERSON WHO WANTS TO MODIFY (ADJUST) A SUPPORT ORDER SH<?ULD CONTACT THE DOMESTIC RELATIONS SECTION. ALL CHARGING ORDERS FOR SPOUSAL SUPPORT AND ALIMONY PENDENTE LITE, INCLUDING UNALLOCATED ORDERS FOR CHILD AND SPOUSAL SUPPORT OR CHILD SUPPORT AND ALIMONY PENDENTE LITE, SHALL TERMINATE UPON DEATH OF THE PAYEE. A MANDATORY INCOME ATTACHMENT WILL ISSUE UNLESS THE DEFENDANT IS NOT IN ARREARS IN PAYMENT IN AN AMOUNT EQUAL TO OR GREATER THAN ONE MONTH'S SUPPORT OBpGATIONAND (1) THE COURT FINDS THAT THERE IS GOOD CAUSE NOT TO REQUIRE IMMEDIATE INCOME WITHHOLDING; OR (2) A WRITTEN AGREEMENT IS REACHED BETWEEN THE PARTIES WHICH PROVIDES FOR AN ALTERNATE ARRANGEMENT. UNPAID ARREARAGE BALANCES MAYBE REPORTED TO CREDIT AGENCIES. ON AND AFTER THE DATE IT IS DUE, EACH UNPAID SUPPORT PAYMENT SHALL CONSTITUTE, BY OPERATION OF LAW, A JUDGMENT AGAINST YOU, AS WELL AS A LIEN AGAINST REAL PROPERTY. IT IS FURTHER ORDERED that, upon payor's failure to comply with this order, payor may be arrested and brought before the Court for a Contempt hearing; payor's wages, salary, commissions, and/or income may be attached in accordance with law; this Order will be increased without further hearing by 0 % a month until all arrearages are paid in full. Payor is responsible for court costs and fees. Copies delivered to parties . FEB 2 72002' Date Consented: Plaintiff Plaintiffs Attorney Defendant DRO: Sally S. Kreitzer xc: Plaintiff DEfendant Taylor Andrews, Esq. Jennifer Lehman, Esq. Defendant's Attorney BY THE COURT: ./- Service Type M J; , ... / : / / /~ (/ C- / / / //(:::7 \,/ .' VI J /'(.]ESLEY OL~~;)JR. j/ Judge Page,4 of 4 ( Fonn OE-SI8 Worker ID 21103 ~~- - ., -',' .-.<." , lillil\i!jil:~," In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION SHELLEY R. COYLE ) Docket Number 00171 S 2002 Plaintiff ) VS. ) PACSES Case Number 218104297 BRIAN C. COYLE ) Defendant ) Other State ID Number Order AND NOW to wit. this MARCH 14, 2002 it is hereby Ordered that: DUE TO THE ORDER OF COURT DATED FEBRUARY 26, 2002, INCORRECTLY SETTING THE PERCENTAGE THAT THE DEFENDANT IS TO PAY THE PLAINTIFF FROM ANY BONUS. THE ORDER IS HEREBY AMENDED TO REFLECT THE CORRECT AMOUNT OF 10% OF THE NET OF ANY BONUSES HE RECEIVES TO BE PAID DIRECTLY TO THE PLAINTIFF, IN ALL OTHER RESPECTS THE ORDER TO REMAIN IN FULL FORCE AND EFFECT. DRO: XC: Sally S. Kreitzer Plaintiff Defendant Taylor P. Andrews, Esquire Jennifer L. 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':1.~, /"""" I i "J" -- " , !!I ,,,\..,;o:~-,~,~ "',"~i"~''''''1'~~''U (1. - < ::..' ~_ J _ ' ' I , '--' , "',:,:,,-,,-j-,,,' ".,!h:~,~;!4i1ii!tl~!ii'~ ~"'~"',1~~"!\'!!if~~i,W;d~~' r\ ;-; 2' "'T.~'r;': nll-{': Z:T' 't5~: -/ , ~~~:. ~c,\ )>~; ,L, --.s --. LI ,L~,:) ,'..., ~ co :.11 -- {.J1 .,~ '1['\ " ,,,Jli. '~ -"""J- -"" ;-'~ .:-} f'J ~~ir~ '....J ~ -< (~: -~~, 'it; ,,..a~~- '~ '!t._ r .!;f01 ,itf"""""'-~', '''~<~ ~, ~~' . ~" . ~I ~<mlili~~"', , t- BRIAN C. COYLE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. CIVIL ACTION LAW 00 - 8840 NO~ CIVIL 19 SHELLEY R. COYLE IN DIVORCE Defendant STATUS SHEET ui',TE: ACTIVITIES: 1.(/'1/6,"3, - - r L ,",0-" > , "'~',' ,', ^ ,-,' ,,' '-~' j),'"~,' 't,;:"'L~,,,,-,- , ~~ --. J:i{ , BRIAN C. COYLE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00 - 8840 CIVIL SHELLY R. COYLE, Defendant IN DIVORCE TO: Taylor P. Andrews , Attorney for Plaintiff Jennifer L. Lehman , Attorney for Defendant DATE: Monday, November 18, 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. ~ ,~. , ,/ . -~ ,.,," ''",",'- -')"' ", ' ~,'" '.-' i ,,~, ';. "~';" ,. "__<C" ,m; " . (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. l1i~" " -, '~ ,~ ,'~ "L , ~ ~ "'" ~'litidi' ',', ' Ii. '1\. BRIAN C. COYLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA v. : NO. 2000-8840 SHELLEY R. COYLE, Defendant : CIVIL ACTION - LAW : IN DIVORCE NOTICE OF ELECTION TO RESUME MAIDEN NAME Notice is hereby given that pursuant to the above-captioned divorce actioll,'Plail1tiff hereby elects to resume her maiden name of BUCKINGHAM, and gives this written notice of her intention in accordance with the provisions of 54 Pa.C.S. Section 704. < ...,~' SHE~O~~~ '. " To be known as ., SHE~~~ ".,.,,., COMMONWEALTH OF PENNSYL V ANlA : SS: COUNTY OF DAUPHIN On the L day of ~ ' 2003, before me, a Notary Public, personally appeared SHELLEY . CO . E, to be known as SHELLEY R. BUCKINGHAM, known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto s official seal. tlOTAlIIAI. SIAl. ., . _ s.1tAIR NllIaIY ~ ......, I'oIdOft Twp..t:laIJPhln,o _ "" c;ommIIIlun ~- . .. i~(~~liIiIffl.JIT'-~lt_I'"'~~~~!!i~~~i$r&.",:4i~f",!',i<::';'!";":.i.&""!~0fi#M-~~~il~IkIl~' ~ ~ -&q 0 c.::: C' ~ C C,.h; "tt Ii $:. L -00 0 me: ,,'-= Z_.'.' -~.. . 0 65~:r: c,:, ~ -<:o~ - ..r-} - !<c :y" " :z~ ~ "V )>c ' 1_':"'; Z-' '-:-:c) pC ,.-:; IT, -. p: " i..D ~ " ~ 0- 2:: ~ '''V ::;> ::;! :0 ....0 ~ CY> -< ...t: ~ --, ~. " ..,.... ,~ ",,,,,' , '~'~'~~_"I'~'~""""n':j;: ,i ....','! i~~,;i BRIAN C. COYLE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00 - 8840 CIVIL SHELLEY R. COYLE, Defendant IN DIVORCE ORDER OF COURT AND NOW, this A,f,. ;, /7~day of .~ 2003, the parties and counsel ha~ing entered into an agreement and stipulation resolving the economic issues on April 17, 2003, the date set for a Master's hearing, the agreement and stipulation having been transcribed, and subsequently signed by the parties and counsel, the appointment of the Master is vacated and counsel can conclude the proceedings by the filing of a praecipe to transmit the record with the affidavits of consent of the parties so that a final decree in divorce can be entered. BY THE COURT, cc: Taylor P. Andrews Attorney for Plaintiff .J. Jennifer L. Lehman Attorney for Defendant ~ ~ 'f..)/.()J CJ- ,C', ~ " , , c. , -;;,.,:' BRIAN C. COYLE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 00 - 8840 CIVIL SHELLEY R. COYLE, Defendant IN DIVORCE THE MASTER: Today is Thursday, April 17, 2003. This is the date set for a Master's hearing in the above captioned divorce proceedings. Present in the hearing room are the Plaintiff, Brian C. Coyle and his counsel Taylor P. Andrews, and the Defendant, Shelley R. Coyle and her counsel Jennifer L. Lehman. A divorce complaint was filed on December 28, 2000, raising grounds for divorce of irretrievable breakdown of the marriage. On November 5, 2002, an affidavit under Section 3301(d) was filed averring a separation in excess of two years. Today counsel provided the Master with affidavits of consent and waivers of notice of intention to request entry of divorce decree signed and dated by both parties; therefore, the divorce can proceed under Section 3301(c) of the Domestic Relations Code. The affidavits and waivers will be filed with the Prothonotary by the Master's office. The complaint in divorce also raised the economic claim of equitable distribution. There are no claims raised by either for alimony or counsel fees and costs. _J l, '~' , ~. "1'-",( An agreement is going to be placed on the record in the presence of the parties. The agreement as placed on the record will be considered the substantive agreement of the parties not subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. Counsel and the parties are going to return later this morning to review the transcription for typographical errors, make any corrections as necessary and then affix their signatures affirming the terms of the agreement as stated on the record. In any event, when the parties leave the hearing room today they are bound by the terms of the agreement even though there is no subsequent signing of the agreement affirming the terms of settlement. The parties were married on February 10, 1990, and separated November 2000. There is one minor child of this marriage and the custody of the child is shared between the parties. When the Master has received a completed copy of the agreement he will prepare an order vacating his appointment and counsel can then file a praecipe transmitting the record to the Court requesting a final decree in divorce. Mr. Andrews. MR. ANDREWS: The terms of the economic claim of equitable distribution are resolved with the - ~" ,"-, .. . :'",,,'.,;'-, ,<- ~ ,- ~ - - i " "Oic' I I I I I I i I I , .- following agreement: 1. The parties' marital real estate at 702 Sandbank Road, Mt. Holly Spring, Pennsylvania, shall be transferred to husband on the occasion of the refinancing of the property to have wife's name removed from the debt on the property. wife agrees to execute a deed to transfer ownership to husband of the marital real estate within the next thirty (30) days which deed shall be held by wife's counsel in escrow and a photo copy of the executed deed to be made available to husband for purposes of pursuing the refinancing. 2. Husband shall apply for refinancing of the real estate referenced above within thirty (30) days from today. Husband shall be responsible for all property related expenses and shall indemnify wife from any cost or loss related thereto. 3. The 1993 Ford Ranger shall be transferred to husband. Wife shall sign off the title within thirty (30) days of today. 4. The 2000 Oldsmobile Alero shall be transferred to wife. Husband shall sign off the title at such time as his name shall be removed from the loan on the 2000 Oldsmobile Alero. 5. Tangible personal property shall remain as is except those items listed on a three-page handwritten list labeled at the top "Shelley's list", which items are currently in the possession of husband but shall be transferred to wife. with reasonable notice from wife, husband shall have these items ready for her to pick up to take to her premises. This transfer shall be done within thirty (30) days of this date. 6. All intangible personal property including the employment benefits of each party shall be retained by the party named on the asset or in the benefits. 7. Husband assumes responsibility for the Member's 1st Federal Credit Union debt that had a balance of $2,000.00 approximately as of the date of separation. 8. Wife shall assume primary responsibility for payment of the Fleet MasterCard and credit account No. 431302707500 which is a credit card through M&T Bank (MBNA). Wife shall indemnify husband from any loss or expense related to these two credit accounts. "1,,, ~r~u.,. .,'. "". ~ 9. Husband shall pay wife $4,000.00 within thirty (30) days of this date. 10. At the time that the title to the real estate is transferred to husband's name, husband shall pay wife $4,982.00 which funds shall be held by Jennifer L. Lehman, Attorney at Law, in escrow until such time as husband is no longer obligated for the currently existing automobile loan on the 2000 Oldsmobile Alero. The escrowed funds may be distributed to a creditor if necessary to facilitate the removal of husband's name from the debt on the Alero provided this is a condition of the refinance and the refinance is accomplished. 11. Wife shall apply to refinance the debt on the 2000 Oldsmobile Alero within thirty (30) days of the settlement on the transfer of the real estate. 12. Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship including without limitation, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate. Each will at the request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interest, rights, and claims. MR. ANDREWS: Brian, you heard me outline that agreement? MR. COYLE: Yes. MR. ANDREWS: Do you understand -- I want you to understand what Mr. Elicker said at the beginning and that is when you affirm this agreement now verbally you are -- when you both do, you will be bound by this agreement. It will be prepared in writing for you to sign but you are bound by the "',--, , '...;-- ~ agreement as soon as you each affirm it and when we come back and look at the writing, all we are looking at is to see that it has been transcribed accurately; it's not an opportunity to rethink whether you want to be bound by the agreement; do you understand that? MR. COYLE: I understand. (A discussion was held off the record.) MR. ANDREWS: Do you understand the terms as I have laid them out? MR. COYLE: Yes. MR. ANDREWS: And do you agree to them? MR. COYLE: Yes. MS. LEHMAN: Ms. Coyle, have you been present in the room during the recitation of the terms of the agreement? MS. COYLE: Yes. MS. LEHMAN: And you've heard and understood the terms of the agreement? MS. COYLE: Yes. MS. LEHMAN: Do you understand that you are bound by the terms of the agreement at this point in time? MS. COYLE: Yes. MS. LEHMAN: And you agree to that? MS. COYLE: Yes. - ~. "'. .. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations Code. WITNESS: DATE: 'f-(7.<Y) ~~_ yl P. Andrews orney for Plaintiff ~IIJ );1~ J nifer L. Lehman Attorney for Defendant +/7/05 Sh~~~IM ~o~~Q / _ ~,c . '_'o.w..--=,,",': - ~ I ~,~ stle.!it yS 11 '5,f- )h:-V\ :i\- 3'5 - s~w_ his Set 0 f 8 r,oT '7 - 70.7) ~ i tQ,~\ 5 h ~ is. 'J2.d" r,",cc/ -- .~ preJ",c{ '*' . c.kScn,1iv\ . 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