HomeMy WebLinkAbout01-1579 FX
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SAlOIS
SHUFF, FLOWER
& LINDSAY
ATIORNEVS.AT.UW
26 W. High Street
Carlisle, P A
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LORRIE A. JONES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001-1579 CIVIL TERM
v.
GERALD W. JONES,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
ORDER OF COURT
AND NOW, this <J-4; day of fM/~t'..JJ , 2(Xl-" upon
consideration of the within Petition a Rule is issued upon Defendant to Show Cause
why the relief requested should not be granted.
Rule returnable at a hearing set for the I:<-c/; day of f...>>.I'~~>>
2005 in Courtroom #1 of the Courthouse at Carlisle, Pennsylvania at 3,' t17J
.oS R'l..tp.m.
BY THE COURT:
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SAIDIS
SHUFF, FLOWER
& LINDSAY
A'ITORNEVS'AT'LAW
26 W. High Street
Carlisle. PA
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LORRIE A. JONES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001-1579 CIVIL TERM
v.
GERALD W. JONES,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
PETITION TO ENFORCE MARITAL SETTLEMENT AGREEMENT
AND NOW, comes the Plaintiff, Lorrie A. Jones, by and through her counsel,
Carol J. Lindsay, Esquire, and files the within Petition for Contempt and, in support
thereof, alleges as follows:
1. The parties hereto entered into an agreement with regard to the
distribution of their marital property before the Divorce Master on October 4, 2005. A
copy of the agreement dated October 4, 2005 is attached hereto and marked as
Exhibit A. A Decree in Divorce has been requested but has not yet been granted by
the Court.
2. Subject to the terms of the agreement, Defendant was required to
perform the following with regard to equitable distribution of the parties' marital
estate:
a. Refinance the marital residence and make payment to Plaintiff in
the amount of $55,000 not later than forty-five (45) days from October 4, 2005,
Le., November 18, 2005;
b. Prepare a Qualified Domestic Relations Order conveying
$55,000 of Defendant's Teamster's Pension to Plaintiff within two (2) weeks of
October 4, 2005, Le., October 18, 2005.
SAlOIS
SHUFF, FLOWER
& LINDSAY
ATIORNEYSIAT'LAW
26 W. High Street
Carlisle. P A
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c. Convey all interest in his American Investors IRA and Putnam
IRA to Plaintiff within two (2) weeks of October 4,2005, i.e., October 18, 2005.
4. To date, Defendant has complied with the conveyance of the two IRA
accounts to Plaintiff; however, he has not complied with any other term of the
October 4, 2005 agreement.
5. On page 6 of their agreement of October 4, 2005 the parties agreed
that either party refusing to abide by or comply with a term of the agreement would
be responsible for the other party's attorney's fees and costs incident to enforcement
of the agreement.
WHEREFORE, Plaintiff respectfUlly requests this Honorable Court to issue a
Rule to Show Cause why the Defendant should not be found in violation of the
agreement of October 4, 2005 and ordered to pay Plaintiff's counsel fees.
Respectfully submitted,
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Dated: Il\'t.># J 0 ~
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LORRIE A. JONES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO, 01 - 1579 CIVIL
GERALD w. JONES,
Defendant
IN DIVORCE
THE MASTER:
Today is Tuesday, October 4,
2005. This is the date set for a hearing in the above
captioned divorce proceedings. Present in the hearing room
are the Plaintiff, Lorrie A. Jones, and her counsel Carol J.
Lindsay, and the Defendant, Gerald W. Jones, and his counsel
Karl E. Rominger.
The parties were married on July 5, 1982, and
separated March 31, 2001. The parties are the natural
parents of two children, both of whom are still minors. The
older child lives with the father and the younger child
lives with the mother.
The divorce complaint was filed on March 19,
2001, raising grounds for divorce of irretrievable breakdown
of the marriage. The Master has been provided affidavits of
consent and waivers of notice of intention to request entry
of divorce decree signed and dated today by both parties.
The affidavits and waivers will be filed with the
Prothonotary's office by the Master's office so that the
divorce can conclude under Section 3301(c) of the Domestic
Relations Code.
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An amended complaint in divorce was filed an
September 23, 2004, raising claims on behalf of wife of
equitable distribution, alimony, and counsel fees and costs.
The Master has been advised that after
considerable negotiations in this case, the parties have
reached an agreement with respect to all of the outstanding
economic issues. The 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. The parties and
counsel are going to return later today to review the
transcribed agreement and make typographical corrections as
necessary. They will then be asked to sign the agreement
affirming the terms of settlement as stated on the record.
However, it is specifically noted that when the parties
leave the hearing room today they are bound by the
substantive terms of the agreement even though there is no
subsequent signing of the agreement by the parties affirming
the settlement.
Upon receipt by the Master of the completed
agreement, the Master will prepare an order vacating his
appointment and counsel can then file a praecipe
transmitting the record to the Court requesting a final
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decree in divorce. Mr, Rominger,
MR. ROMINGER:
1. Husband agrees to make a direct cash payment to wife in
the amount of $55,000.00 within 45 days of today's date.
2. Husband agrees to prepare a QDRO to provide wife with
$55,000.00 of his Teamster's pension within two weeks of
today's date.
3. Husband agrees to convey all of his interest in two
IRAs now in his possession and listed on the property
statement of Plaintiff, being an American Investors IRA and
a Putnam IRA and will complete all documents necessary to
make the transfer or prepare any Court order if either would
require within two weeks of today's date.
Mr. Jones warrants that he has not removed any monies
from the American Investors IRA since March 28, 2005, when
it had a value of $6,853.65, Nor has he removed any monies
from the Putnam IRA since March 31, 2005, when it had a
value of $1,875.02. Wife will be receiving these two IRAs
reduced in value or increased in value only by market
conditions.
4. Husband shall agree to the entry of an alimony order in
the amount of $825.00 per month to be administered or
attached to the Domestic Relations Office of this county.
This is an indefinite alimony order and subject to
modification upon a change of circumstances and termination
upon the death of either party, cohabitation by wife with a
member of the opposite sex or remarriage of wife.
The alimony shall be effective October 1, 2005;
wife will advise the office of Domestic Relations that her
spousal support shall terminate on the same date and if any
over collection is made, it will be credited appropriately.
5. It is the intent of the parties that each party will
keep all tangible personal property now in their possession
and all vehicles now in their possession, and remain
responsible for all debts now in their name. Additionally,
at the time of the payment of the $55,000.00 lump sum to
wife, husband will refinance and remove wife from any
obligation to the marital residence.
6. Wife shall execute a deed at the time of the refinance
and receipt of the lump sum payment transferring her
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interest solely to husband. The deed will be prepared by
husband's counsel.
7. Except as specified above, both parties waive any and
all claims they may have as to any retirement or other
accounts held by the other for any purpose.
8. The parties expressly waive any further claims for
counsel fees or costs which they may have as against the
other.
9. Wife will retain the 1994 Ford Explorer and husband
will retain the 2000 Chevy pick-up, the 1972 Chevy pick-up,
and the 2001 Triumph motorcycle. Similarly, wife will
retain the two bank accounts which were in her individual
name at WayPoint and the $25.87 remaining in the Member's
1st Federal Union account as of the time of separation and
husband will retain his Waypoint account.
10. 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.
MS. LINDSAY, Lorrie Jones, did you hear the
agreement as it was dictated by Mr. Rominger and by me?
MS. JONES: Yes.
MS. LINDSAY: And did you understand it?
MS. JONES: Pretty much so except for some of
that stuff at the end. I understood.
MS. LINDSAY: Okay. Let me explain what that
4
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stuff at the end is about. That is some magic language
that's in there so that if you didn't get divorced between
now and -- if somebody died, one of you died, between now
and the date you were divorced, you might have a claim on
the estate of the other. What this is doing is waiving any
claims you have on the estate of the other for that period
of time. Once you are divorced you don't have a claim --
MS. JONES: Okay.
MS, LINDSAY: Do you have any questions in
addition about what I just said and Mr. Rominger just
dictated?
MS. JONES: No,
MS. LINDSAY: And are you in agreement that
the agreement as dictated is the agreement you want to make?
MS. JONES: Yes.
MR. ROMINGER: Gerald, have you heard the
agreement as dictated into the record?
MR. JONES: Yes.
MR. ROMINGER: And are you in agreement with
the contents of it?
MR. JONES: Yes,
MR. ROMINGER: Do you understand it?
MR. JONES: Yes.
MR. ROMINGER: Do you agree fully and
faithfully execute it?
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MR. JONES: Yes,
(Whereupon, a discussion was held off the
record, )
MS, LINDSAY: In the event, that one party to
this agreement fails or refuses to abide by a term or to
comply with a term hereof, and the other party seeks Court
intervention in order to enforce the agreement, the party
who has breached the agreement shall be responsible for the
attorney fees and costs of the other party expended to
enforce the agreement.
MR. ROMINGER: The only caveat would be
force'majeure and impossibility of paying as defenses.
MS. LINDSAY: If one of you do not adhere to
your deal here and the other guy has to go to Court to
enforce the attorney fees and costs, Karl's addition was
something like Hurricane Katrina comes along and it cannot
be done.
(Whereupon, a discussion was held off the
record. )
MS. LINDSAY: It is understood that
impossibility shall not be a defense to the payment of
$55,000,00 as set out in this agreement by husband to wife.
THE MASTER: You understand what they just
talked about?
MR. JONES: Yeah,
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MS, JONES: Okay.
MR, ROMINGER: Mr. Jones, are you satisfied
with your representation? Do you believe that you have been
adequately advised entering into this agreement?
MR. JONES: Yes.
MS. LINDSAY: The same question?
MS. JONES: Yes, definitely.
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:
"
ucLLf05 jr~O.1oYlp.o
j Lorrie A. Jone
tiff
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Gera d W. Jones
K~' Rominger
Attorney for Defendant
7
SAlOIS
SHUFF, FLOWER
& LINDSAY
ATI'ORNEYS-AT-LAW
26 W. High Street
Carlisle. PA
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VERIFICATION
I verify that the statements made in the foregoing document are true and
correct. I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S. 94904, relating to unsworn falsifications to authoriti
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SAlOIS
SHUFF, FLOWER
& LINDSAY
AITORNEYS-AT-LAW
26 W. High Street
Carlisle. PA
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CERTIFICAl:E OF SERVICE
I hereby certify that on this ],;~ay of November, 2005, a true and correct
copy of the foregoing document was served upon the party listed below, via First
Class Mail, postage prepaid, addressed as follows:
Karl E. Rominger, Esquire
155 S. Hanover Street
Carlisle, PA 17013
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LORRIE A JONES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 01 - 1579 CIVIL
GERALD W. JONES,
Defendant
IN DIVORCE
ORDER OF COURT
AND NOW, this
fS'Y"v
day of
~1;t.h14 )
2005, the parties and counsel having entered into an agreement
and stipulation resolving the economic issues on October 4,
2005, 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,
.J.
cc: Carol J. Lindsay
Attorney for Plaintiff
Karl E. Rominger
Attorney for Defendant
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LORRIE A. JONES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 01 - 1579 CIVIL
GERALD W. JONES,
Defendant
IN DIVORCE
THE MASTER:
Today is Tuesday, October 4,
2005. This is the date set for a hearing in the above
captioned divorce proceedings. Present in the hearing room
are the Plaintiff, Lorrie A. Jones, and her counsel Carol J.
Lindsay, and the Defendant, Gerald W. Jones, and his counsel
Karl E. Rominger.
The parties were married on July 5, 1982, and
separated March 31, 2001. The parties are the natural
parents of two children, both of whom are still minors. The
older child lives with the father and the younger child
lives with the mother.
The divorce complaint was filed on March 19,
2001, raising grounds for divorce of irretrievable breakdown
of the marriage. The Master has been provided affidavits of
consent and waivers of notice of intention to request entry
of divorce decree signed and dated today by both parties.
The affidavits and waivers will be filed with the
Prothonotary's office by the Master's office so that the
divorce can conclude under Section 3301(c) of the Domestic
Relations Code.
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An amended complaint in divorce was filed an
September 23, 2004, raising claims on behalf of wife of
equitable distribution, alimony, and counsel fees and costs.
The Master has been advised that after
considerable negotiations in this case, the parties have
reached an agreement with respect to all of the outstanding
economic issues. The 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. The parties and
counsel are going to return later today to review the
transcribed agreement and make typographical corrections as
necessary. They will then be asked to sign the agreement
affirming the terms of settlement as stated on the record.
However, it is specifically noted that when the parties
leave the hearing room today they are bound by the
substantive terms of the agreement even though there is no
subsequent signing of the agreement by the parties affirming
the settlement.
Upon receipt by the Master of the completed
agreement, the Master will prepare an order vacating his
appointment and counsel can then file a praecipe
transmitting the record to the Court requesting a final
2
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decree in divorce. Mr. Rominger.
MR. ROMINGER:
1. Husband agrees to make a direct cash payment to wife in
the amount of $55,000.00 within 45 days of today's date.
2. Husband agrees to prepare a QDRO to provide wife with
$55,000.00 of his Teamster's pension within two weeks of
today's date.
3. Husband agrees to convey all of his interest in two
IRAs now in his possession and listed on the property
statement of Plaintiff, being an American Investors IRA and
a Putnam IRA and will complete all documents necessary to
make the transfer or prepare any Court order if either would
require within two weeks of today's date.
Mr. Jones warrants that he has not removed any monies
from the American Investors IRA since March 28, 2005, when
it had a value of $6,853.65. Nor has he removed any monies
from the Putnam IRA since March 31, 2005, when it had a
value of $1,875.02. Wife will be receiving these two IRAs
reduced in value or increased in value only by market
conditions.
4. Husband shall agree to the entry of an alimony order in
the amount of $825.00 per month to be administered or
attached to the Domestic Relations Office of this county.
This is an indefinite alimony order and subject to
modification upon a change of circumstances and termination
upon the death of either party, cohabitation by wife with a
member of the opposite sex or remarriage of wife.
The alimony shall be effective October 1, 2005;
wife will advise the office of Domestic Relations that her
spousal support shall terminate on the same date and if any
over collection is made, it will be credited appropriately.
5. It is the intent of the parties that each party will
keep all tangible personal property now in their possession
and all vehicles now in their possession, and remain
responsible for all debts now in their name. Additionally,
at the time of the payment of the $55,000.00 lump sum to
wife, husband will refinance and remove wife from any
obligation to the marital residence.
6. Wife shall execute a deed at the time of the refinance
and receipt of the lump sum payment transferring her
3
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interest solely to husband. The deed will be prepared by
husband's counsel.
7. Except as specified above, both parties waive any and
all claims they may have as to any retirement or other
accounts held by the other for any purpose.
8. The parties expressly waive any further claims for
counsel fees or costs which they may have as against the
other.
9. Wife will retain the 1994 Ford Explorer and husband
will retain the 2000 Chevy pick-up, the 1972 Chevy pick-up,
and the 2001 Triumph motorcycle. Similarly, wife will
retain the two bank accounts which were in her individual
name at Waypoint and the $25.87 remaining in the Member's
1st Federal Union account as of the time of separation and
husband will retain his Waypoint account.
10. 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.
MS. LINDSAY, Lorrie Jones, did you hear the
agreement as it was dictated by Mr. Rominger and by me?
MS. JONES: Yes.
MS. LINDSAY: And did you understand it?
MS. JONES: Pretty much so except for some of
that stuff at the end. I understood.
MS. LINDSAY: Okay. Let me explain what that
4
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stuff at the end is about. That is some magic language
that's in there so that if you didn't get divorced between
now and -- if somebody died, one of you died, between now
and the date you were divorced, you might have a claim on
the estate of the other. What this is doing is waiving any
claims you have on the estate of the other for that period
of time. Once you are divorced you don't have a claim --
MS. JONES: Okay.
MS. LINDSAY: Do you have any questions in
addition about what I just said and Mr. Rominger just
dictated?
MS. JONES: No.
MS. LINDSAY: And are you in agreement that
the agreement as dictated is the agreement you want to make?
MS. JONES: Yes.
MR. ROMINGER: Gerald, have you heard the
agreement as dictated into the record?
MR. JONES: Yes.
MR. ROMINGER: And are you in agreement with
the contents of it?
MR. JONES: Yes.
MR. ROMINGER: Do you understand it?
MR. JONES: Yes.
MR. ROMINGER: Do you agree fully and
faithfully execute it?
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MR. JONES: Yes.
(Whereupon, a discussion was held off the
record. )
MS. LINDSAY: In the event, that one party to
this agreement fails or refuses to abide by a term or to
comply with a term hereof, and the other party seeks Court
intervention in order to enforce the agreement, the party
who has breached the agreement shall be responsible for the
attorney fees and costs of the other party expended to
enforce the agreement.
MR. ROMINGER: The only caveat would be
force'majeure and impossibility of paying as defenses.
MS. LINDSAY: If one of you do not adhere to
your deal here and the other guy has to go to Court to
enforce the attorney fees and costs, Karl's addition was
something like Hurricane Katrina comes along and it cannot
be done.
(Whereupon, a discussion was held off the
record. )
MS. LINDSAY: It is understood that
impossibility shall not be a defense to the payment of
$55,000.00 as set out in this agreement by husband to wife.
THE MASTER: You understand what they just
talked about?
MR. JONES: Yeah.
6
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MS. JONES: Okay.
MR. ROMINGER: Mr. Jones, are you satisfied
with your representation? Do you believe that you have been
adequately advised entering into this agreement?
MR. JONES: Yes.
MS. LINDSAY: The same question?
MS. JONES: Yes, definitely.
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:
~
j O/l/l.J'p (J.~
Lorrie A. one
)
/Karl E. Rominger
Attorney for Defendant
--..
to /'-( /0)-
( ,
6. .~ ~
Gerald W. Jones
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GERALD W, JONES
DefendaI1t
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: IN THE COURTOF COMMON ,PLEAS OF
; CUMBERLAND COUNTY, PENNSYLVANIA
, REQUIREMENTS FOR DIVORCE MASTER
PRETRIAL STATEMENT
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TABLE OF CONTENTS
Borrower/Client ~/A
Address .3lLCarltQ11..A)[emJe
City Carlisle
Lender/Client Lorrie A. Jones
"County CUInberlaIld- State ~ Zip Code 120.13_
~J\~~~~~~,\".::.f " <
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Cover Page
Cover Letter
Table of Contents
Appraisal Summary
Uniform Residential Appraisal Report
Text Addendum
Subject Photos
Building Sketch
Comparable Photos
Location Map
Certification and Umitlng Conditions
Invoice
Addenda
B-H Agency Appraisal Services
163 N. Hanover Street
Carlisle,Pa, 17013
(717) 243-1000
"",i"'f'
this form was reproduced by United Syslems Software Company (800) 969-8727
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..__.Jil~No~O_ao.O~Ol " Pag~~2
Property Address:
3B Carlton Avenue
Carlisle, Pa. 17013
Appraisal Prepared For:
Lorrie A. Jones
40B B Walnut Street Bolling Springs,Pa. 17007
Prepared As Of:
OB/15/01
'",,/
Prepared By:
G.Arthur Calaman/Douglas R.Helneman
B-H Agency Appraisal Services 163 N, Hanover St. Carlisle,Pa.17013
This form was feproduced by UnUed Systems Soflware Company (800) 96~ -8727
Form Coverpg V8f. 1.1
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B-H Agency Appraisal Services
163 N. Hanover Street
carlisle, Po. 17013
(717) 243-1000 fax (717) 243-1718
Date: August 17,2001
alent: Lorrie A. Jones
408 8 Walnut Street
801llngs, Pa. 17013
cc: Attorney Johnna Kopecky
26 W. High street
carlisle, Pa. 17013
In accordance with your request, I have personally Inspected and appraised IIle property located at: 38 carlton Avenue carllsle,Po. 17013
As per your Instructions, the PU'llOSl' of this appraisal was to determine fair Mar1<etValue, In unenrumbered fee simple tille of ownership.
Note: This Is a Summary Appraisal Report, containing 16 pages (Indudlng attached addenda). Any single page is Invalid If detached or used
separately from this enllre report.
This report In Ifs entirety Is intended and valid for the use of the Client (as named above) only, and Is Invalid If photo copied In part or In
whole by anyone other than the Appralser(s) named In the report. It Is Intended soley for the alent, and shall not be used by anyone other
than the alent without the prior written consent from the alent and the State Certified Appraiser conducting the appraisal.
This report was prepared with the utmost care and was established with no pre-determined opinion of value.
Thank you for using B-H Agency Appraisal Services.
~~
Douglas R, Heineman
-~.. ,,,>"
Designed by Unfteel systoms Company (BOO) 96!l-8727
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"_....__J'ii!f:IoJl_~QI!301 ~~..i.
APPRAISAL SUMMARY
SubjecIAddress............. , 31lCar1to~nue,__
Legal Description. . . . . . . . .. . . . ~allil.the.d.deed
City......................... . carlisle.
County...... .....".... .... . . C.l.IIDberland
Slate....................... . Pa.
Zip Code. . . ... . . . . " . . . . . . . . . WilL
Census Tract. . .. . . . .. . . . . . . . . l!12.5-....
Map.Reference. . ... . . . . . . . , . . 2.l~lllllll83
..
-
Sales Price $................. --1J/ A -
Date of Sale. .................. .....Jl/ A -
..
Borrower/Client. . .. . ... . . . . . . . N/A
Lender..................... . Lorrie A. Jones
-
Size (Square Feet) ..., ......... 1300 -
Price per Square Fool........ $
Location.. ...,.. ............. SuburbaD
,
Age....................... .. 48 yrs.
CondKion...... .............. faiL-
Toml Rooms. . .. . . . . .. . . . . . . . 5 --
Bedrooms.............,.... . 2.
Baths....... .c:":............. 1,00
Appraiser................... . 09jlalas R. He!!!eman.BL~1IIiln
Date of Appraised Value. . . . , . . 08/15/01
final Estimate 01 Value. . . . . . . $ 79800
Designed byUnMed Syslems Soli"". Company 180D) 969-8727
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.
Proo.rlv Address:, 38 Alrenue Ql!LQ!rllsle .. Slale 'p-a. lip Code 110.13
Legal DOSCliptioni See attached d!!ed - Counly Cumberland ---
Assessor's ParceliNo. 40- 22c048!l-08J & 083 Tax Year 2001 R,E. Taxes $ Special Assessm.nls $ N/A
Bcrrowel : N/A CUrrent Owne~mI!:l&_l.orrie.AJpnes Dccupanl I5<l Owner fl,Tenanl n Vacant
Prooerlv rlohls appraised 1><1 Fee Simole I I leasehold II ProjeclType o PUD 0 Condominium (HUD/VA only) HDA$ N/A /Mo,
-,
Nelohborhooli or rrolect Name ' " ! Mrmor" Map Relerenc, 22:lMl!9-0ll2 &, 083 Census Tract' 0125
Sales Prlc. $ iN/A Dale of Sa!. N/A Desmlption and $ amounl of lean chargeS/concessions 10 b. PJiid by seller N/A
L.nder/ClI.nl Ibrrle A. Jones ' Address 408 B Walnut Street Boiling Sprlngs.~, 17007
Appraiser G.Ajitl,ur Calarl1lln/Douol" D Address R-H . ': 1/,1N : . <;t r".llsle.Pa.170"'-
Location : jgJ Urban ' o Suburban o Rural Pred.minant Single '.mlly hou$lng P.....nll.nd IISll % ~nd lISlieha11p
Built up jgJ Over 75'l. o 25-75'l. o Under 25% .....poncy PRICE AGE _,.9JL_ jgJ Nolllk.ly 0 Likely
$(000) (yrs) Onelamlly
Growth ,afe o Rapid ~ SIable o Slow ~ Owner __LO__ low _L o In process
Property values o Increasing ~ Slable o Declining [J Tenanl 1 ~O Hiah 60 2-4 ramily ---
Multl-lamlly -- To:
O.mand/supply '0 Shorl,g. ~ In balance 0 Over supply o Vacanl (0..5%) f-- Predominant Commercl~1 _10,
Mar1<etlng 11m. :0 Under 3 mos. ~ 3-6 mos, DOver 6 mos. o Vacanl(llver5%) 110 40 L__...L...
."0: Race ..dlhe 1llCI.1 composftltin.llhe nelghborho.d.re .... .ppral..I........
N.ighborhood ~o~ndarles and ch,iaclerlstics: 5.l.Ibject Is located just oveL~ CarusleJlm:!ll!9bJ.lne..lILSJ1iddletoo.IwRJtJsJl91df:r:ed_
to the noHl;liihv P".R.t 641' to the east by Pa.Rt.74;_to th~south b~ 1-8..1;.to the west I:1v Pa.Rt. 34.
Factors Ihat aff.cllhe markelability ollh. properties in Ihe neighborhood (proxlmlly 10 employmenl and amen Illes, employmenl slablllty, appeai 10 markel, elc):
Subject p~ is in thegrealer Carlis.te.aa,.)..Arei!.--Mi!jQL!Qi!dway1i~OOJpl<lY1IlMW/1l11JPin\l. schoQls (bo~li<:...aDd
,prlYate) a~'!wlthln rea:;<)nable dI:Mr:l!ulJS!aote..:.UtUities..as..weJI,as.1JreJ!lJd-PJl\ire.lllilteCtimJ.ilteipreseohloo_adetwate-fllr_-
the area. It is mv ooinionthat the subiect RroJErtv Is In fair contljtion_and is need of nillnOIJ;QSmetic rE:llain;..J;_uch as__
,g)~~tlQU!:p.alritii:!g~l;;i!IJ!e1IepJa!:_emE:llt.eJ&...;llli1J;!l'LE:IiD9cQU!l.LreilLqUi!rteLoLtbe_grteJj!)J...wIittYillYlsldinll-&__
lrjm.Jn It's current stijte,buyer a~ktl1!!--9rea~tE:d~
Markel conditions in Ih. subj.ct neighborhood (including supporllor Ihe above conclusions relaled 10 Ihe Irend of properly vaiues, demand/suppiy. and markellng time
- such as data on compelillve prop.rtles lor sale in Ih. neighborhood. description of Ih. prevalence of sales and Ilnanclng concessions. .Ic,):
.Emp~ent mortgage ',rates....amlh!!Us.lnQJ!l'LeIltllIiE:S.JJilY.e.r.emal!ll:.cls1ablejll.Jbe_i!tei!...amii!1tbOl.lllbJhe.madleti5.lf.elY
~~.JlaJ:UittJe~se OVeLl:Ire_~eilI:..AY.ool!l-e.1Jli!l'lretiDgJj/n!Lf2!:.sjmllM.PrnpetllesjlL......__
!tJ~ar!:il.vmuld be 90 to 1lIlL~~Sell!Lc.QIll;e5sions iLl'!:.Lela!ilLe!y__CQ01lJll)l1,JlYJ:..w;!!allv_d.QrLLexte_ed.llO.OJl_________
.._----~---_._~---_._-~--~.---_.-~._.
- , -"-- ONo
'IOJ'" '...."""'1.. lor ,UDs (II applicable) - -Is the dev.loper/bullder In conlrol ollhe Home Owners' Association (HOA)? DYes
Approxlmale Iala! number of units in Ihe subl.cl projecl N/A Approxlmal. Ialal number of unllS lor sale In Ihe subjecl proj.ct - N/A
Describe cornmon elemeJlts and recreational facilities: NJA
OImenslons J.ol#20 Parcel 082: 50'x150' loliillJ?_arc.eLJl8..J.:..Sl1:K150' -
Topography Jgy,gJLRollino
Slfe area ..M:acre (Tomlboth 1oJ!;) --- Cornellol DYes ~NO Size J!.J..1Atte
Speclllc zoning classlllcation and de~lIon Residential o No zoning Sh,p. .RettaIlgWar
Zoning compliance ~ Leg,1 Leg,1 nonconforming (Grandlalhered use) CJIII"1lal Drainage .AIl~uate
Highesl & b~1 use as Improved ~ Presenl use o Olheruse (explain) View ' .Iy-Plcal
omn,.. Public Other OfI.sIle Imp.......nl. Type Public Privale landscaping : .Mature
Elecklclty ~ Slreel 'Mata!lam______ jgJ 0 Driveway Surlace Macadam
Gas jgJ Curb/Guller tlooo..... 0 0 App,renl Easemenls None known
Waler jgJ Sidewalk Non'L-________ 0 0 FEMA Specla! Flood Hazard Area Dyes ~No
Sanllary Sewer jgJ St,..t lights Electric ~ 0 FEMA Zoo. _~ MapOate 4 NoV. 1981
Storm Sew.r jgJ Alley None 0 0 FEMA Map N9. 420371-0010 B
Comments (apparent allverse easemenls, enmeachmenls. special assessm.nls. slide areas. lIiegal or I.gal nonconlorming zoning use; elc,): tioneJlD!lWIl orobserv~
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- INSULATION
GENERAL DESCRIPTlON EXTERIOR DESCRIPTlON FOUNDATION BASEMENT
No. of Unlls 1 Faundallon S~_ Slab Yes Area Sq. FI. NL~_ Raol __0
No. 01 Slorles 1 ExtedarWalls Stone Crawl Space Nil 'l. Finished -- C.lling 0
Type {D.IJAt!.) Detached Rool Sudac. Shlngl../Rubb Basemenl No ___ C eiling --- Wails 0
Design (Style) Ranch Gullers & Dwnspls. Metal Sump Pump fW___ Walls ---- Floor ___0
Exlsllng,ol'roposed Existing WindowTyp. J:1bI..HIlg~ _ Dampness !'It! Floor -,- None ____0
Age (Vrs.) 48 SlormJScreens Yes S.llIemenl tilL OulsideEnlry Unknown __ ~
Effective Age (Vrs.) 30 . Manufaotured House No Inleslallon None .hcervP<
ROOMS Foyer Gving OInlng Kilchen Den FamilvRm. Rec. Rm. Bedrooms # Balhs laundry Other Area Sq. Ft
Basemenl - -
Levell 1 1 _1__ , Hlo 1 1 - 1300
--- --
level 2
F1n1sl11d _.... made contains: Ii Raorns; , Bedroorn!sl; 1,00 Balhlsl; non Snuare Feel of Gra,ss Llvlno Area
INlERIOR Malerlals/Condlllan HEATING KITCHEN EQUIP, ArnC AMENmES CAR STORAGE:
-- None ~ Fireplace(s) # ,--'1_ 0 0
Floors CI1.tL\lIrL~1r Typ. EI:IL_ Refrlgeralor 1-_ None
Walls Plas/D.W. fal- Fu.1 QL___ Rang_JOven fX- Stairs 0 Pallo 0 Garage # 01 cars
TrlmA'inish Wood lIVE Cond~ OIsposal i-- DropSI'ir 0 Deck :....____~_ 0 Allached
Dishwasher I- Scullle 0 Parch __ 0 --
Bath Floor Vinyl _-'M COOLING Detached 3 Car
BathWalnscol N/A Cenlral Nt A FanlHood I- Floor 0 Fence _______ 0 Bul1l~n
Doors Wnntl -;;;; Other WA Mlmowave I- Healed 0 Pool 0 Carport l1'x21'
Coodlllon WasherJlJlY"r Finished 0 0 Drlv"""
Addlllonal features (special energy ellicienlllems. oIc.): None ObservecL..
Condlllon 01 IhelmprllY8llle~I~~iallon (physical, functlooal. and external), repairs needed~ auallty 01 constructlo,n. remodeling/additions. elc.:_ ~aL_
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AlIversellllvlronmenlal condlllons (such as, but not Iimlled 10. hazardous wastes. loxia substances. elc.) present In th. Improvements. on the slle. or In lhe
Immed~e vicinity 01 th. subj.ct property: ,NomLQbserved
Freddie Mac F no 70 6-93 This lorm was re roduced b United Syslems Software Company (800) 969-8727 - Page 1 Fannie Mae Form 1004 6-93
UNIFORM RESIDENTIAL APPRAISAL REPORT
File No, 0600301 Page #5
File N.. 0800301
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t'alllatlo. Section
UNIFORM RESIDENTIAL APPRAISAL REPORJ
F[le No, OB00301 Page #6
Fllo No 0800301
ESTIMATED SITE VALUE .... ....... ,", '. .... '.. p$ ,_______tJJA Comments on Cost Approach (such as, source of cost estimate,
ESTIMATED REPRODUCTION GOST-NEW OF IMPROVEMENTS: slle value, square fool calculalion and, for UUD. VA and FmHA, the
Dwelling ----.1300.0!l Sq, Ft @ $ ~$ NJA eslimaled remaining economic life ollhe properly): Due 10 the Me of
Sq Ft @ $ ~ N/A s.ubj~ improvements, the cost appJ:l1jIt~
~ .1J/A used. UJLthe oWn.!oo..of this_j!~tmt the cos~
GaragetCarport Sq,Ft@$ - NlA ~ppmath.m.YaJueJsJnaJ.1eQuate,lllleJQ-'.t1e
T olal. Esllmaled Cosl-New . -
........... =$ _.._MlA
less Physical I Funcllonal I External .depIl:!;Jation faclors.
Depreclallon -$
DepreclaledValue of Impr(lVements ,......' ......". .,........"'$
"As-1s'Va'u,eolSilelmprOl'emenls ........".....,......,,'. .",$
IIDICARDVALUEIIYCDIrAPPROACH..........,...... '" .;-$ N/A
Iml, I SUBJECT COMPA~LE 10. 1 '- COMPAllABLE 10. 2 COMPARIIlE NO.8
38 S"rltonAvenue - 319 E. North Street
130 Petersburg Rd. 30 Pine Street
Address 'P: ,Carlisl~Pa. Carfi5leJ'iL __ CatlisL~
Proximllv 16 Subiecl ! Wilbin 1 mile Wi1lJJnJ..J:niIf' 1 WitIJiIL1.nii1p
Sales Price $ N/A 1$ 86250- I $ qooon $ RfiAOO
Price/Gross liv,Area $ lZl $ 79.13 JZi .LZ2.5L JZi $ 83.22 J2]'
Dalaandlm Inspection CCCH & CPMl CCCH & CPMl Inspection
Verification Sources CCCH _CCCl:L&.g>MI
VALUE ADJUSTI,lENTS DESCRIPTION DESCRIPTION +(-) Adjustment DESCRIPTIQfL.... +(-) Adiustm'n! DESCRIPTION '(-lAlljustm.n!
Sales or Financing None known None known None Known
Concessions
Dale of Sale/Time 01/31/01 -- ,!!6mlQl 08107l!!L
Locailon Ic:..h"""'n 'c:..".",,~n.
leaseholdifee Slmole Eee.Slmnl" Ee!LS.imn1p Fee..5llIllllp
Sile 34 acre .49 acre 1.03 acres __-5000 ,26 acre
View 'fvoical Tv,piQI1 -"- T'tPical TyJliQlL
Design and ADoeal IQ"nrh . Randt .Il"nrh Il;.nrh
OUaliIY of Construc1lon &~ AYerage
Age 4RVI'C. 10 vrs~ ,46 VI'C. 43V1'C.
Condition F~ir Ah;" '" Au. r'!Q!L -10000 -40 Avp age, -100001
T ofal I Bdrms I Balhs r- ~~ Bdrms 1 Balhs ,
Above Grade Tolal Bdrms Balhs Tolal Bdrms Baths
Room Counl 5 I 2 11.00 5 3 1.00 -3000 6 3 _11.00 -3000 6 2 1.l!.lt
Gross Livlna Area 1300 Sa,FI. 1109'<L_ Sa.Ft 7100 l:MQ So. Ft J,{M,l. So,FI. , 75.1.Q
Basemenl & Finished N/A Full -2500 Full -2500 Full -2500
Rooms Below Grade 0 0 0 0
Functional UlIIlty 'fvoical Tvnlcal 1i'l!ical Tunir"l
HoatlnolCoolino "'-'A AlA.O.iIlC...Air -7000
Enerav Elilclenlllems Nnne N~Ql'!lJL..... 1 NOne IImlwn
Galage/Calport 1 Car net I CIp!; 1 Car A~_ ___lLOQ!). 2 ~cCamQrt _ _~ooo 1 Car Atl. &000
~---_..-
Porch. Pallo, Deck. None Deck -1000 Porch -1000 Porch/Deck -1500
Fireplace(s), elc. Nnne 1'!ooe 1----- _Elrepll!!;e -150!! Erep~ -1~001
Fence, Pool. elc. Nnne None None E.~ce I
.---- 1
Net Adl. (total) .D:t.. IXI- $ -8400 1+ IXI- $ -9000IDLIXI- $ -4q101
AdJusled Sales Price G: 33.16% G: 27.78% ll~: 30.03%
01 Comparable N: 9.74% $ 77850 N: 10 00% $ 81000 : 5.68% $ 81870
Commenls on Sales Comparison (inclUding Ihe subjecl properly's compalibtllty 10 the neighborhood. ole,): .see~dum
, 111M SUBJECT COMPARABLE 10. 1 COMPARABlE 10. 2 COMPAMBLE NO.8
D~e. Price and D~a 12130/85 N/A NIA 12/14/00
Source lor prior sales $45450 $62300
wilhlnl"arolappralsal CCGH" eeCH
AnalysiS 01 any current "IlJe,ment olsale, oplion, or lisllng ollhe subjec1 property and analysis 01 any priorsales olsublec1 and comparables wilhin one year ollhe dale 01 appmlsal: '
; last transferred ownershiRJ!ILtbtulates listed above, and bi!Ye..ll!llbeeo~ IhP
best of this "n....;.l~er.s knowledge. - 7<lRoo
IIDICAlDVlLQE IYSALES COMPARISO APPROACH...... ........................................... $
I IllIICARD VB it Ill!:OME APPII!IACH lit ADolicable) Eslimaled Malket Renl $ ;Mo. x Gross Rent Momolier $ UtA
The appraisal is made ~ "as is" 0 subjecl to lhe repairs, alieralions, insaeclions, or condilions lisled below o subiec1lo complollon per plans and saecllicalions.
Conditions 01 Appraisal: ..see~mt!lIDn~__,__
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Final Reconclllalion: see attached addendum...
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The purpose 01 this appral$3lls \0 esllmalethe market value of the real property Ihat is Ihe sublect of this report, based on Ihe above condlllon. and the certlRcallon.
conllngenl and IImlllng condlllons. and marl<el value dellnillon Ihal are slaled In lhe aliaohod Freddie Mac Form 43!!IFannle Mae Form t0D4B (Revised )
I lWEI EmMAR 11IE lWIKIT VAWE,IS DEFINEO, OF 11IE REAL PROPERlY 11IAT IS 11IE SUBJECT OF 11I1S REPORT, .S OF .!l!l115J.oL
(WHICH IS 11IE OAR OF IISPECnO. .10 11IE EFFECnvE DAR OF 11I1S REPORT) TO IE $ 19800 --.-
APPRAlSBI: J.:j (JJ.Iu. W_ su'ilEl!'l~RT AP~OILY IF REOUIREDI: _
Slgnalure I; . \ A.. I8l DId 0 DldNol
Name r:: A......_, - Nan 1IeImIO.....____ Inspect Property
Dale R~ort Signed 08/17/01 I - Dale Report Signed 98/17l!!L-
Slate C(lrtlflcatlon # ~I""~ed.... ,.. Stale I'A Slale Certification # Rl-OOO_5fi~:L__ Slala Pa._,
Or Stal, l.Icense # Qp"t Fd"tp State Or Slate l.Icense # 1l1-000o;E;q-1 Stala p"
Freddi. Mac Fono 70 6-93 This form was reproduced by United Systems Software Company (800) 969-8727 . Page 2 Fannie Mae Form 11X14 6-93
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..,___..5~~0. 08Q!l301--'3~#2
TEXT ADDENDUM
File No.
OB00301
Borrower/Client Nt A
Address 3B Carlton Avenue
City Carlisle
Lender/Client Lorrie A. lones
County .cumberlancL..... State.ea......... Zip Code lZ013
COMMENTS ON COMPARABLE SALES
The comparable properties used In this analysis are In my opinion the best available, and being sold within the most recent months. All are In
dose proxlmlty and very similar In nature, style, s12e, and condition. .
EXPOSURE TIME: For the appraised property, the exposure time, based on the experiences of other similar properties In the same or
similar neighborhoods Is estimated at more or less than four months, Exposure time Is backward looking and there is historical data available
that provides a reasonable Indication of the amount of time that would have been Involved to market the property, and obtain a sale as of the
effective date of the appralsel. This data has been used in this estimate.
HARKET TIME: Marketing time on the other hand Is forward looking, and Is expressed as an estimate(projectlon) of the time that would be
required to market the property and obtain a sale, In this context, It should be noted that I have adhered to the definition of marketing time
as put forth by the "Appraisal Standards Board." This definition advises that marketing time does not begin until two things take place: an
offering of the property at price that marketing partldpants find acceptable, and, an effective marketing is Implemented.
SCOPE (EXTENT) OF APPRAISAL: In the preparation of this appraisal, I have made a physical Inspection of the site and the
improvements. [ have traveled to the neighborhood and made appropriate notes.
Data sources employed In addition to the physical Inspection were the zoning map and ordinance for the municipality, the recorded deed, the
tax assessor parcel records, and the FEMA maps for the location.
eCCH & CPML are aaonyms for Cumberland Co. Court House and Central Penn Multf-Ust respectively. These were the prfmry sources used to
secure property data. In addltfon, already verified Information and data from my own files was used If and where appropriate. The
Information developed was Independently verified where public sources did not provide neeiled data verification. [ have contacted listing
agents or other parties to the transactions, if I felt It necessary to verify data listed in CPMl, as well as any suspected unordinary seller
concessions.
In the valuation process, all appropriate value approaches, or their exclusions are discussed In the appropriate sections of the report.
CONDMONS OF APPRAISAL
The appraiser Is unable to know or verify, and in most Instances unqualified to determine or verify any insulation "R" factor; also the presence
of urea formaldehyde foam Insulatlon(UFFI), lead based palnt, asbestos, the presence of any radon, polyclorlnated b1pheny\s(PCB's),
chlorofluorcarbons(CFCs), leaking storage tanks(above or below ground), and soil contminates or any type of contamination. The Quality of
any drinking water cannot be tested or verified by this appraiser. The appraiser has no expertise and is unqualified to make any assumptions,
statements, or warranties as to the condition of any on site septic/sewage system if present.
The appraiser Is not qualified to test for any contaminates In, on, or around the property, and can make no assumptIon as to whether or not
they are present. It Is to be noted however, that If any of the afore mentioned items are present, the market value could be adversely
affected or Violated. The appraiser(s) hs made every effort to look, notice, and document If observed, any apparent or unusual appearing
circumstance In, on or around the property at the time of the Inspection.
The appraiser has only considered the dwelling and items attached as realty. Personal or other items not permently attached such as
refrigerators, washers, dryers, window air conditioners, etc. were not given consideration In the appraisal.
Also NO VALUE Is given as to small storage sheds, pools(above or In-ground), swing sets, normal fencing, or other exterior structures of
perceived value, unless specifically noted in report. All plumbing, heating, air conditionlng(1f present), and electrical systems appear to be
functional to the best of this appraiser's knowledge, but no warranty or expertise is stated In this report.
FINAL RECONCILATION
This report Is a SUmmary Appraisal report. In this appralse~s opinion, the Sales Comparison Analysis represents the best indiction of market
value for the subject as defined on page 1 of the Statement of Umlting Conditions. This Approach to Value was weighted the most in
estimating the subject's market value as of the date of the appraisal.
The Income Approach Was no1: considered by this appraiser, as the area is predominatly owner occupied, therefor limiting the mount of
available data that would be necessary to complete the Approach to Value. Because the area Is primrily owner occupied, there was
Insufficient available rental data to complete an Income Capitliztion Approach for this report.
COMMENTS ON SALES COMPARISON
All \:hree comparables are wi\:hin 1 mile of \:he subject property,and In similar neighborhoods. It is the opinion of this apprlser that all three
would have like appeal to a polent:ial buyer in the marketplace. Adjustments have been made to all comparables because of the better
appearance and condition at the time of their sale and appraisal for that sale. Conditions of each were verified by either CPMl and/or the
personal Inspection of this appraiser. In verification of comparable #3,it was listed in public record and CPMl data to be 3 Bedrooms and 1
1/2 baths. An Inspection of this property was made personally by this appraiser at the time that it was on the market,and It was actually 2
Bedrooms and had a toilet (only) In the basement. The 3rd Bedroom was In fact an enclosed porch or breezeway,much like the "Family
Room" of the subject. I have therefore shown It in this report as I have seen il...2 Bedrooms and 1 Bath. The property was totally renovated
and In excellent: conditlon,as was comparable # 1.
,or
Designed by Unned Systems Soli.." (800) 969.8727
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SUBJECT PHOTOGRAPH ADDENDUM
Borrower/Clienl: _--.1:l/A .._...,_"_____.._..________....._________
Address: 38 Carlton AvelJlllL... ..___________
City: Carlisle County: CUIlIberland____ Slate: !'.a.______,_ Zip Code: lLOlL,
lenderlClient: Lorrie A. Jones
Front View
Rear View
",./
This form was reproduced by Unfted Syslems Software Company (800) 969-8727
BOlTower/Cllent --1l/A
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Address 38 CarflDn Avenue...
-----.
Cily Carlisle County .G.umbe.rlan.d__ state P.a......... Zip Code J.101J
Lender/Client Lorrie A, Jones
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file No. 0600301
Paoe #,9
SKETCH
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0800301
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AREA CAlCULATIONS SUMMARY
COde DeacrlptIon Size Totals
GLAl l'J.rl!lt P100r 1300.00 1300.00
......,-.;If!
LIVING AREA BREAKDOWN
Breakdown Subtotals
First Floor
26.0 x SO.O 1300.00
TOTAL LIVABLE
(rounded)
1300
1 Area Totll' (rounded)
1300
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0800301
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file No,OIlOQ~L ,Page #10
Borrower/Clienl N1A
Address 3B Carlton Avenue
City Carlisle
lender/Client lorrie A. Jones
County ~ Slate ~ Zip Code _1ZO.1L
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file No. 0800301
DEFlNInON,'OF MlIRKET VALUE: The most probable price which a property should bring in a competitive and open market
~nder all conditions requisite to a fair safe, the buyer and seller, each acting prudently, knowledgeably and assuming the price
IS nol affected by undue stimulus, Implicit in this definition is the consummallon at a sale as of a specified date and the passing
of title from selle r to buyer under conditions Whereby: (1) buyer and seller are typically motivated; (2) both parties are well
informed or well advised, and each acllng in what he considers his own best interest; (3) a reasonable time is allowed tor
exposure in the open market; (4) payment Is made in terms ot cash in U.S. dollars or in terms of financial arrangements
comparable Ihereto; and (5) the price represents the normal consideration for the property sold unaffected by special or creative
financing or sales concessions' granted by anyone associated with the sale.
. Adjustments to the comparables must be made for special or creative financing or sales concessions, No adjustments are
necessary for those costs which are normally paid by sellers as a result of tradition or law in a market area' these costs are
readily identifiable since the seller pays these costs in virtually all sales transactions. Special or creative financing adjustments
can be made to the comparable property by comparisons to financing terms offered by a third party insfilutionallender that is not
already involved in the property or transaction. Any adjustment should not be calculated on a mechanical dollar for dollar cost
of the financing or concesSion, but the dollar amount of any adjustment should approximate the market's reaclion to the financing
or concessions based on the appraiser's judgement.
STATEMENT OF LIMITING CONDnlONS AND APPRAISER'S CERTlFlCAnON
CONnNGENIAND L1MtnNG CONDtnONS:
the following conditions:
The appraiser's certificafion that appears in the appraisal report Is subject to
1. The appraiser will not be responSible lor matters of a legal nature t~at affect either the property being appraised or the title
to it. The appraiser assumes that the fille is good and marketable and, therefore, will not render any opinions about the fille.
The property Is appraised on the basis of iI being under responsible ownership.
2. The appraiser has provided a sketch in the appraisal report to show approximate dimensions of the improvements and the
sketch is included only to assist the reader of the report in visualizing the property and understanding the appraiser's determination
of its size.
3. The appraiser has examined the available flood maps that are provided by the Federal Emergency Management Agency (or
other data sources) and has noted in the appraisal report whether the subject site is located in an idenfilied Special Flood Hazard
Area. Because the appraiser is not a surveyor, he or she makes no guarantees, expressed or implied, regarding this determination.
4. The appraiser will not give testimony or appear in court because he or she made an appraisal of the property in question,
unless specific arrangements to do so have been made beforehand.
5. The appraiser has estimated the value of Ihe land in the cost approach at its highest and best use and the improvements
at their contributory value. These separate valuations of the land and improvements must not be used in conjunction wilh any
other appraisal and are invalid if they are so used.
6. The appraiser has noted in the appraisal report any adverse conditions (such as, needed repairs, depreciation, the present of
hazardous wastes, toxic substances, etc.) observed during the inspection of the subjecl property or that he or she became aware
of during the normal research involved in performing the appraisal. Unless otherwise stated in the appraisal report, the appraiser
has no knowledge of any hidden or unapparent conditions of the property or adverse environmental conditions (including the
presence of hazardous wastes, toxic substances, etc.) that would make the property more or less valuable, and has assumed
that there are no such conditions and makes no guarantees or warranties, expressed or implied, regarding the condition of the
property. The appraiser will not be responsible for any such conditions thaI do exist or for any engineering or testing that might
be required to discover whelher such conditions exist. Because the appraiser is not an expert in the field 01 environmental hazards,
the appraisal report must not be considered as an environmental assessment of the property,
7. The appraiser obtained the information, estimates, and opinions that were expressed in the appraisal report from sources Ihal
he or she considers to be" re-llable and believes them to be true and correct. The appraiser does not assume responsibility for the
accuracy of such items that were furnished by other parties.
6. The appraiser will no! disclose Ihe contents of the appraisal report except as provided for in Ihe Unitorm Standards of
Professional Appraisal Practice.
9. The appraiser has based his or her appraisal report and valuation conclusion for an appraisal that is subject to satisfactory
complellon, repairs, or alterations on the assumption that completion of Ihe Improvements will be performed in a workmanlike
manner.
10. The appraiser must Pl'Ovide his or her prior written consenl before Ihe lender/cli~nt specified in Ihe appraisal report can
distribute the appraisal report (Including conclusions about the property value, the appraiser's Idenlity and professional
designations, and references to any professional appraisal organizations or the firm with which the appraiser is associated)
to anyone other than the borrower; the mortgagee or its successors and assigns; the mortgage Insurer, consultants; profeSSional
appraisal organizallons; any state or federally approved linancial institution; or any department, agency, or inslrumentality of
the United Slates or any state or the District of Columbia; except that thelender/clieijt may distribute the property description
section of the report only to data collection or reporting service(s) without having to obtain the appralse~s prior wrillen consent.
The appralse!'s wrillen consent and approval must also be obtained belore the appraisal can be conveyed by anyone to tM
pu~lic through advertising, pUblic relations, news, sales, or other media.
Freildle Mac Form 439 6,93
I'ogelo12
Th~ form was reproduced by UnRed SlSfems Soli"" Coml'lny (800)989-8727
Fannie Mae Form 10049 8-93
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File No. 0800301 Page #12
File 110. 0800301
APPRAISER'S CERnFICATlON:
The Appraiser certifies and agrees that:
1. I have researched the subject market area and have selected a minimum 01 three recent sales 01 properties mosl similar
and proximate to the subject property for consideralion in the sales comparison analysis and have made a dollar adjuslment when
appropriate to rellectthe market reaction to those items of significant variation. II a Significant item in a comparable property
is superior to, or more favorable than, Ihe subjecl property, I have made a negative adjuslment to reduce Ihe adjusted sales price
of the comparable and, if a significant ilem in a comparable property is inlerior to, or less favorable than the subjecl, I have made
a positive adjustment to increase the adjusted sales price of the comparable.
2. I have taken into consideration the factors that have an impact on value in my development of the estimate of market value in
Ihe appraisal report. I have not knowingly withheld any significant information from the appraisal report and I believe, to the best
of my knowledge, that all statements and information in the appraisal report are true and correct.
3. 1 staled, in the appraisal report,onty my own personal, unbiased, and professional analysis, opinions, and conclusions,
which are subject only 10 the contingent and limiting conditions specified in this lorm.
4. I have no present or prospective interest in the property that is the subiect ot this report, and I have no present or prospective
personal interest or bias with respect to the participants in the transaction. I did not base, either partially or completely, my
analysis and/or the estimate of markel value in the appraisal report on Ihe race, color, religion, sex, handicap, familial slatus.
or national origin of either the prospective owners or occupants of Ihe subject properly or of the presenl owners or occupants
01 the properties in the vicinity of the subject property.
5. I have no present or contemplated future interest in the subject property, and neilher my current or fulure employment
nor my compensation for performing this appraisal Is contingent on the appraised value of the property.
6. I was not required to report a predetermined value or direction in value that lavors the cause of the client or any related party,
the amount of the value estimale, the attainment of a specific result, or the occurrence of a subsequent event in order 10 receive
my compensation and/or employment for performing the appraisal. I did not base the appraisal report on a requested minimum
valuation, a specific valuation, or the need to approve a speCific mortgage loan.
7. I performed this appraisal in conformity with the Uniform Standards of Professional Appraisal Practice that were adopted
and promulgated by the Appraisal Standards Board of The Appraisal Foundation and that were in place as 01 the ellec\ive dale of
this appraisal, with the exception of the departure provision of those Standards, which does not apply. I acknowledge that an
estimate of a reasonable time for exposure in the open market is a condition in the definition 01 market value and the estimate
I developed is consistent with the marketing time noted in the neighborhOOd section of this report, unless I have otherwise
stated in the reconciliation section.
8. I have personally inspected the interior and exterior areas of the subject property and the exterior of all properties listed as
comparables in the apPl3isal report. I further certify Ihat I have noted any apparent 01 known adverse conditions in the subject
improvements, on the SUbject site, or on any site within Ihe immediate vicinity of the SUbject property of which I am aware
and have made adjustments for these adverse conditions in my analysis of the property value to the exlenllhal I had market
evidence to support them. I have also commented about Ihe effect of the adverse conditions on the marketability of the subject
property.
9. I personally prepared all conclusions and opinions about the real estate that were sel forth in the appraisal report. If I relied on
signillcant profeSSional assistance from any individual or individuals in the performance of the appraisal or the preparation of
the appraisal report, I have named such individual(s) and disclosed the specific tasks performed by them in the reconciliation
section of this appraisal report. I certify that any individual so named is qualified to perform the tasks. I have not authorized
anyone to make a change to any ilem in the report; therefore, if an unauthori2ed Change is made 10 the appraisal report, I will lake
no responsibility for it.
G. Arthur Calaman,Asslstant to the Certified Real Estate Appraiser,has assisted and contributed significantly In the
Inspection,collectlon of data,market research,and all other areas involved in this appraisal procedure,
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SUPERVISORY APPRAISERiS CERTIFICATION: If a supeNisory apprai~er signed the appraisal report, he or she certifies
and agrees that: I directly supeNise the appraiser who prepared Ihe appraisal report; have reviewed the appraisal report, agree with
the statements and conclusions of the appraiser, agree to be bound by the appraiser's certification numbered 4 through 7 above. and
am taking full responsibilily for the appraisal and the appraisal report,
ADDRESS OF PROPERTY APPRAISED: 38 CarltonAYenue. Carlisle, Pa. 17013
APPRAISER:
SUPERVISORY APPRAISER:
(only il required)
S~~
Name:
Date Signed: 08/17/0t
State Certification #: Al.:J)OOS69-L
or State License #: 1!.L:J100569-1
State: J'..iI.-
Expiration Date of Certification or License:
~ Did 0 Did Nollnspect Property
Signature:
Name:
, Date Signed: .11811ZllIL..
Slate Certification #: Assistant to the~fied
or State license #: RelIl Fstate Appral<er
Slate: "pJ9..
Expiration Date 01 Certification or License:
D6!.J0/03
Pag.2012
This lorm was reproduced by UnDed Systems Sollware Company (800) 969-8727
Fannl. Ma. Form 10048 6.93
F'eddl' Mac F0<<lI439 9-93
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Page #13
INVOICE
B-H Agency Appraisal Services LOB00301 I
163 N. Hanover St. Carllsle,Pa.17013
Lorrie A. Jones
40B B Walnut Street Boiling Springs,Pa. 17007
OB{17{01 OB{15{01 S -1
Purchaser/Borrower N/A -
Property Address 3B Carlton Avenue Unit
City Carlisle .. Subdivision ~rlisle ManDril
County Cumberland _ Slate .I'a..- Zip Code .lIQU.
Legal Descriplion ,Seeattach~
Map Reference 22-0489-082 &. 08~
Apprnisal Fee Amount , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . , . . . $ _~25.00 (Paid)
Mail or Handling Fee "" .. $
Addilional Charge No. 1 " .. $
Additional Chalge No.2 " .. $
Addilional Charge No.3 .. " $
Sales Tax ................,............................................ $
Total Amount of Invoice $ $225.00 (Paid)
Comments: Paid llll time of inspection: check , 4591 from H. Clay StalT\Y III THANK YOU
..'~ .
__~___H_____________________________________~_________________________.___________~____
OB{17{01 08{15{01 ~01 (717) 960-9509
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Lorrie 1\. Jones AMOUNT
408 B Walnut Street DUE
Boiling fPrlngs,Pa. 17007 $ $225.00 (Paid)
B-H Agency Appraisal Services AmOUNT
163 N. Hanover Street EN LOSED
Carllsle,Pa. 17013
I . $
TERMS - Balance due Upon recelpl of invoice.
Please reIum 1I1~ portion wI1~ toJl:~. Thank JOUI
" OaSianed"j;; Uniloo.sVSi,ms oilllOreJaoO\'969.:a727
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;,;:C:J,;c'c(' - f.'FFICE Of THE
::[C~~~F.H CF DEEDS
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'BS DEe 30 nl I 25
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""''''''.cllo..... IlNn4recl..104 eighty-five ,(1985).
~rtturrai WILLIAM K. BECK, also known as WILLIAM K.- BECK, SR., widower
of South Middleton Township; Cumberland County, pennsylvania,
GRANTOR and party of the first part,
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GERALD W.JONES and'LORRIE A. JONES, his wife, of Newville,
Pennsylvania, GRANTEES and partres-
./Ih. .""".d po.I, mitltellnd~ Thl III. lOld>po.1 Yo/II.. flr., pori, lor o.d I. """ticler"Il..
."10......", 'FORTY-FIVE THOUSAND FOUR HUNDRED F'IFTY AND 00/100 1$45,450.00)
n"lIaro, latr/.I "..'1/'f tho U"ited State. ./ A",.,.;cn, fCcll and I...I1y pold by Ih. ..Id pori ies ./Ih,
.econd pon to the ,uid pa,., y oj the Jir~'t part. nt (lI,tf bfJfort 'lte .{'dUng and d'-Uf'tTlI "1 tAt'!.,
IIYe,tnh. the receipt whereof i, hr.r~by acknowledged. has
9t'"aa(C"d. bargained, lold, alieM"d, en/tofJed, released, c(H\l~eyed and cunf;nned orad by thu" ,n-Nfttda d_
grunt. bn"rI~';H:. .~II. .,Ii"". fO,,11:61'. releolt, conl't'y, allll OMttinn ""'0 IJ" _"id pnr, lea .,.
tlt ,fWy",d pot,.' their '''''1''. 4..d ,....~..
1\11 those certain lots or parcels of ground situate in South Middleton
Township, Cumberland County, Pennsylvania, together with buildings
and improvements erected thereon, bounded and described as follows 1
NO.1 - ALL~hat certain lot of ground situate in South Middleton
Township, Cumberland County, Pennsylvania, being Lot No. 20, Block
"F", in the Plan of Lots known as "Carlisle Manor", which Plan is
recorded in the Office of the Recorder of Deeds in and for Cumberland
County, Pennsylvania, in Plan Book 3, Page 7,9. HAVING thereon erected
a one-story dwelling house.
BEING the same premises title to which became vested in William K.
Beck. and Anna M. Beck, his 'wife, by deed of WalteL' F. Nickel, Jr.
and Louise G. Nickel, his wife, by their attorney-in..fact, Linda
F. Farner, dated July 1, 1958 and recorded in De~d Book IS-N, Page
14, Cumberland County records.
NO.2 - I,OT 21, Block "F'r, of Plan of Lots known as Carlisle Manor
as recorded in the Office of the Recorder of Deeds for Cumberland
County, at Carlisle, Pennsylvania, in Plan Book 3, Page 791 said'" /'
Lot having a frontage of fifty (SOl feet on Carlton Avenue and
extending one hundred fifty (150) feet in depth, and'being subject
to building and use restrictions which are attached to and made '
part of said Plan of Lote, excepting Restriction No.2, which is
expressly intended not to impose or reimpose.
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BEING the same premises title to which became vested in William K.
Beck, Sr. and Anna Marie Beck, his wife, by deed of Charles A. B.
Heinze and Mary L. Heinze, husband and wife, dated September 29,
1966 and recorded in Deed Book 0-22, Page 189, Cumberland County
records.
THE said Anna M. Beck, also known as Anna Marie Beck died on May 7,
1982, thereby vesting title in William K. Beck, also known as William
K. Beck, Sr., widower, by operation of law.
UNDER AND SUBJECT, nevertheless, to easements, restrictions, reserva-
tions, conditions and rights of way of record.
....
""' COMMONWEALTH OF PENNSYLVANIA ==
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BOARD APPROVED CHECKLIST FOR ASSISTANTS
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. Property:
3R CAQl..7'D1J /l;;t.
CIJI!t-I3 l..-r.: ?IJ.. 176 a,
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The assistant to the state certified llppraiser for this report has assisted in the following items:
~set up the file with all forms and general Information for this report.
r ~Sisted In the gathering and entering the data as the following: Tax Assessment information and map. Flood
Hazard information and map, Zoning information and map, location map, and similar information.
.~ Accompanied and assisted in the inspection of the subject property for this report.
~ Assisted in the analyzing of the Highest and Best Use of the subject property for this report.
''[It'' Assisted in the gathering of the information for the comparable land sales data, verified and analyzed the
r comparable land sales data for this report. '
o Assisted In the gathering of the Information for the Cost Approach data, analyzed and selected the cost amounts
for this report.
o Assisted In the gathering of the information for the Income Approach data, verified and analyzed the rental data for
this report. ' .
?!Assisted In the gathering of the information for the comparable market sales data, verified and analyzed the
comparable market sales data for this report.
pt Assisted in the verifying of the data at the Tax Assessment office, the Recorder of Deeds Office: County SreB
monthly report,'County Microfiche service and/or local MLS Service.
]it Assisted In the exterior inspection of the sales, rentals, land and other comparables used for this report.
;B Assisted In the sketch drawing for this report. ' , " ' ,
pt, Assisted in the enterl~g of the subject and comparable data on the form and the data inthecomment areas of this
, rep,ort." i ' '", ':
, ' , .. ' -.,.' :~ ~ .,.. . ..: . ..... ". .: ' "
Assisted in the final reconciliation and the final estimate of value of the subject property for this report .
l' .,.1
AsSisted in the final review of this report.
. . ; ,:~"( ,i ,...:'"
, As~lstecfinpUttlng together and packaging the final report.
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DATE OF INSPECTION: Iki6 UST IS. .}m/
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Assistant to the State Certified Appraiser
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state certified appraiser did review all the work done by the assistant
Thu~' ' R.: Jk.J /liE rY/lI-tJ
State CertlfleQAPpralser
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Date: ' 68 J... 'I 1 ~iol
Signature
Certificate#: /2'L- OO{)S~lj-L
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07/25'l2005 '17:24
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71 72436510
SAIDIS SHUFF FLOWER
ItlCltu.~
Property Address:
, 38 CarllDn Avenue
CarlISle, I'll 17013
Prepared For:
LalTIe A. Jones
0108 WII\nuI: St.
BOJnnv SpIlngs, Pi. 1?OO'
PrGpared As Of;
Mey 34('2005
Prepa..... By:
DOugIIlS R. HeinIlman I G. AnlIur CllIman
B-H Agency AppIlllsaI S8I\IlceS
163 N. Hanover St.
Qlrtosle, I'll. 17013
711-243-1000
<0
Exhibit "A" , ~
D"'1",8 by Unltl!d BY"Iem, SoI~'.,. eomp"'Y (BOO) 0611-8727
PAGE 03/16
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PAGE 04/16
111.""._,,",
APPRAISAL st,I_ARY
Subjecl 'Address
38 CarllDn Avenue
Legal, DeSCflption ... . . . . . . . . . . . . " See Allacheel Deed QI I\'om DB 31-Q PG 1050/51
City. . . . . . . .. . . ., . . . . .. . . .. . . __ .. Ca~iSIe
County ...........,............. !:umlIeIIBmI
State. . . , . . . .. . , .. .. . .. . . . .. .... pa
Zip Code..,.. ........... _, ...... 17013
Census liBot ..................... 0125
-....-..,-
Map Reference ....'.............. 22-0<\89-Q82
Sales P~loe ...........,.........$ NfA
Date of Sale ... _ .. .. . .. . ___ ..... _ NJA
Borrower ........................ NfA
IJinder/Client ............... . .. ... loRle A. .lanes
Size (Square Feel) ................. 1300
Price per Square Fool ............. $
I.oeilllon .................. ......AveraGe
Age. __.......'........... ..,.... 52:r!!.l!!!l!l
Condition ..,.._...........__.... FIllr
Total Rooms ..................... 5
Bedrooms ................. ...... 2
....f"
Baths.. .. . .. . .. . .. .. .. . .. . , .. . .. 1.0
Appraiser . . . . . . . . . . . . . . . , , . . . . . . . Do"g!l!!~,,_t1.!ineman &. G. Arthur Cataman
Date of Appraised Value ....... ...... Mav 24, 2005
Final EstImate of Value ....""" _ . $ $70,000.00
lle.iQoed lV United sy<~"" saltw'~ ComjIony (6001969.6721
"M""'"'
. ~-""""""",_"~I~liilililW~611"'"
"_ .~_""" n
07!2~/2005. 17:24
7172436510
SAlOIS SHUFF FLOWER
PAGE 05/16
..11I..,.,....,.............,.....-
IIfO l\\t. \NUW\
'ftALSAL.ltEPORI Fill Ie. 050080!
. "....__._!:ilV Ca~lsl. Sfalt Pa Zip Code 17013
. Qn SUAllllc:l\l!d ~ l\omDB 31-Q fIG 1050151 COIlII\Y Cumberland ._.
No, '2:,~?;:\!<\lIlH1112j083 - '......'..-------;:;;;;):m '04/ '05 RoE. TlIllI!s $ 1045.00 Sp.lqlsl.AsSMSmenls $ 0.00
Curren! Owner JO!ll!s, Gemid W.l i:orrte A. Dccu nr Owner' ~ ~ r
l.eaIl!hald 'act [J PUO [J..~~IIlIlR\ {HUOtIA onlY! HOA $ Nll!._. IMo.
___,...... ,.,. . Map Relel!llce 22-o4ll9-lJll2 ..."pensu. Tract 0125
Oeserl lion end $ ,,~~t 01 ioon chill1lel/ccnelllsiona to be paid by .eller NlA
I\ddN '-..'108 Wal!lUt St., I!llI1Ing S\llInIIS, I'a. l7Oq?..
G. Al'II1ur ClIIainlln Ail N sM1 A 81 II SeIvIces 1631\1. Hlnover St. Ca Pa. 170 3
I&l Suburban 0 Aural ~=I.,it ~l\.'fI""'IlD""g P_IlIt.d.". 1.alId_......
~ 25-15% B. Under 25% By fllIDa) r~ One larnlly 7 181 Not likely 0 Likely
StIllle J Slow 1Zl Owner &Ok LDw 0 2-4 lamily 0 In process
Slllble 8 Declinil11J 8 ronant, 350k Hi h 110.. Muln-Iamlly ro:
181 ShQllllge In belance _ 0>Jer .uflllly V3C3llt(I~S'l\) Pred in..t I' Commercial 1
,~g,t\n)eUnder3~::J:J1:t!!!~~., 0 Over6mps. Vacentl~r5%) 150-170 40+ I In~. )
:....~Rlllia'...d .~,_....1\In GlIII..llJialla_d I" .DI.ppiar.I.'....... '
,m1g1lbomlllld,)lotindat\olland charllllttrilllica: SubjeCtl~ silullie41ust oulsflll! and v'~..!!!!,Cariisle 8010 In South MIckllI!lllll T~,",!~~, ~ to tI\e lIOIIII by
-.... ~ 6<11: ll)'I\uoull\ aNI east by 1'81; III u.e._ bySpitng ~~ St. ,
'Faclol8ltlat a""ctltle markelllbillly oIl1le properlle. in Ihenelghb~molld (pmlmily,!o em~;lYment and amenRias, ""I'loymenl Slllbilily, epplellO marll!!, etc}
"' '5!lIlI~ ".' '",. '"Is10 lIle r Car!isle.~,.l Martcet Area. Major ~~Ym!!'to shOppiAg. schoals (lmlh public an~_~,:!!) are wUllln 1'OIISO/l8b1l!
drM~~8S~\"finI and ~:~ ....presel\t'aN1 ~!!!9\!.~.\\!,1I\e ......IUs my opinion lI\atll\e.~.~ 1\1 In fllW 0/' lesS
lhanavera 2!!!il1I!!ln and WllUkl h.....lM!I'!!!Ie (It best)1 nlarl!!!l!.apcitllnllal.
-,....~_.
.Mame! coodlllmm In thnub;ect oeighbomood /including suppOfllor the ablM! ooncluslonu ..lal1llllo m. trend 01 propeny I'8IUIlS, demand/supply, and IlUIrkeling time
- such 8S da'" cn comp6t;liW prop.llies lor sale in ltie neighborhood. deScription olth. pll!'IIIlence of sales and llnancing concesaions. etc.):
, "ment"" ,,>'~ and ~~es ~lUIaiIIed ~ In tlIurea. and alltlOl.l!ll\ lnle~;lt mes -'lIoIn!I_lly, 1M II\lIMt 1$ WIY
:'9IiII)to-4~.~on Ilasllad l1\llClel,~ inCl~_lfle past ~rla,~~y S - 9"10). Averaaemlr1cetlnq lill1l!. tor.,!'l.m.llar propelll!!51n tillS area
,~ ~UlD!ill~, bUt ~.~!!L~~id$ III 1811 days. Soller con~~. in tne-Illrm Of closing COSUSSISllInce to Ine bU'(er are relativei)' com!!)!1!!d?!lt_
l\lSU8don~~$3000to$50l1ll. .' _.
'i...alll.atIi11Dr I'UIlt (lI applicable) - -Is 1I1e developer/bullder in Control 01 nle Home Owners' ADSocldtion (HOA)? D Yell 0 No
i~llUItstll1al number of unilllln lIluUblecl project N/A , ApIlftl1lI!l'lalll tIl1aI number of unit! lor salt in lt1e wbiettproieot N1A
Od.cli c e\emen,,,or' lanilities: NlA
Oimenslon. 2'1tlM;ts@0.178Cm eacIl....5eeatlllChel! lejlal cIesaIptlon In Iddll!9!'-~ of 18 T""oglltlhy .~I
Silue tl>810;41sq. R. __M Com!r LIll Vel Igj No SIle 0.3<\ lIClO (mil) ~~ IrQ
Speclt1c zoning classUicaiion and description ~~ Shape Rel:lanfjUlilr
ZOning compliance l8Ilegal 0 Legal n_formlng (Grandfalhemd use) l'J 1I1'!li1 D No zoning OIlIinage AppIliIIll ID I1ll ~_,
Highdst 80 best uae as Irnoroved !;81 Present usa 0 01h11l use (elIIlldln) VIew ResidentiaL
ic Other ......'mpJMIIIIUlI '!yp. Public Private I>>ldSCllJllng NOne
1Zl Slreet Macadam \81 8 Driveway SUlface MacBd8m
18I -. CurblGuller !'lOne Olinrved-' B 0" AIlllllrenl EaaemlllllS None Found or o~
~ Sidewalll !'lOm' 0bseM!d FEMA Speoial Flood H81$1I mtl [Tves i&l No
SIIeel Ughls Yes B FEMA Zone C !Aep Date 1110'1I1981
Jell!! I ~ 0lI8eM!11 '-'-. _, F MA M N-. 420371'0010 B
,Commenlll (app"rent aMme essemenls. encroachmenlll. special esse98menls, .lidelllSllll, illega1 or legal nonconttm1llng zoning use. etc.): None olJseM!d or found durIna the
nonnai ~n;e of_h oflllls praperly.
1
1
1
AilON 8ASEMEtlT INSUlJ\llON
V.. Area Sq. fl. ,WA Aoof D
IllIce N/A % Finished Ceiling
----- 8
lilt None Ceiling Walls __._J
---'-'-
.'ump No Walls --- Floor
,!ss NOne oIl6M1 floor None D
.
lent NOne OIlllMl Outside En\Iy Un_IIIlVM IZI
ion \.IIIknOWn See BCfd1!ndum
11. Rsc. Rm. Bedroo!l'.L #Ba1ll8 Lall/1dlV Other AulL
,_._, - NlA
~ 1.00 1 1:300
-
GENElIAl DESCRiPllON f.X$IOR DESCRIPllON
SI~._ Foundation 511b
One ElcIe~orWelld !!!~_
DEl: AooI Surtac.
RanCh Gutters & DWIlSIlIs, Aluminum
Eldslln Window Type DllI.Hno.
52 Sln~c_s Some
2O-2S fAanulac\Ured House No
L1vin Kitd>en Q!!1
FOUNt!
Slab
Clawl ~!
Ba.en"
SlimpI'
Dampn
5elllan
111_1
Femil RI
. ........11I: 5 R O!!!!: 2 ae !:22!!!.ts' 1.00 Ilalh 1:300 WIN feet III GrllSllliv\nQ Area
iNTERIOR Malerlal~ondition HEAllNG KITCHEN EOUlfl ArnC AMENITiES CM STOIlAGF.:.
~ FIOlll$ Cpt/Ifm:Poar Type FHA Refrigeralor None D Flrepldce(sl"" _ D Non. 181
Walla P1_r:~r Fual OU Aange/ClvM SIaIls ~ Patio IIone 0bsNd 0 Garage <1101""",
'liinVFlnW, Woodll'\llr on i:9~" DlspoSl1 DropSllllr Oack ~.,~ 0 AlIachad
'lIa1hFloor V1nyl:FGir COOLING Dishwasher ScuIIl. Porch Sid. 181 Oetaehed
8atII WaInSCot NlA CenUal No FanMood Flodr Fence None ObsMl 8 Bu/IHn
Doors Wood:A>lellQe 01her Microwave Healed Pool N/" CatllOrI
Condmon We.herlDfY'lr finished 0 0 DrlvOWilY 2
AIIdlUonell"""" iSplIcial energy elllclent I1ems, el1:.): Ntn ~
Condition of lIle IlI1IJI1lV8rnell18, depll!Olsiirm (~I, functional. end Dlemall........lrsnee;led.o.uali~ 01 condtruction, ..modolinglllddltion~ elc.: Home Is In rail' concfollon
\MltllI<lIlhV$lCal. tilncIIllnaI or f!llII!maI obsol_ ! was nCIlI!ll at lIIe Ume.:~.InspettIon. roof IS badl, \\Om, ~at _rlor (wood) soft\tIliCia Is m.~
if and Jli!l!'t or aluminum cover: all ftocIrll)ll"mMorIalls badly wom and ~ls replaced: entilt illteTtor ""!!!!..l)~"t, ~ Il!1lllir in sllO\5<.!!1!!... mIlMltionl
rentodeIinand IIln.. no .iIll,..",. In ' ~atoly of QmslNaion '$ average lD the peIfad. _.
AdYette enviltlnmenIBl cDlldlUona (such 85. but nollimiled to, hazardPus wastes, loJiC slIbscmces. elC.) prnaenl in me imP/llwmenl1l. D11l1le slle, Or in the
immediate vicinily .rthe subjectllfOPeIIy: None olrsl!!,!!"...Nat quallftod Or o;!tifl~ IDsee or _",Sl!e.:!'~ AdClend~m.
-'_<\iiilt;_~"
~. --,
-~,". ~
.--~"~",,,,"f.H>IIiWl"""'d1;1\Ilf
H
""~j_"~rirniIWl~-,~J;l"";;,,,,;<,.-<
07/25A2005 '17:24
(01'-11 "1I'ot1_. MWtUlWI "'lilt""'"
7172436510
SAIDIS SHUFF FLOWER
, .
PAGE 06/16
rmr nu. UiANClll
UNIFORM RESIDENllAL APPIIlAI R _.... 0500805
ESTIMATED SITE VALUE .".."...,'...,.,."..,.... = $ , 30 000 Comments on Cost Approach lsuch as souru 01 ooSI.stimate .lmv.luo squ.,.
ESTIMATED REPRODUCTION COST-NEW OF IMPROVEMENlS: .. . .
D...l1ing 1300 Sq. Ft.@$ $ N/A laD! ealCtJlatlon and, lor HUD, VA.nd FmHA. 1t10 Ollljmaled remaining eoonomlo
Sq. Fl. @ $ - li19 01 the property): p~~~ llIe age Of the sulljett 111lJlrDVOll1enlS, the
= Cost Annraoch III value was not ~sed. It is the !)lljI!iOn of thl, '
. G...goJCarport -sq:Fi~@$"--._-- _ Mlnllliser lINIt: ~."Cost A/l/llDsch'1D value 1$ inedeQUalIein.!~,_
,. .....~ Ofa -.:. ~.;: & ~~""' ~a, 11itmlca1,', " , .. II!
ToIaIEstimatodCOst.New"...,...,.,.,......,=$ lh hi d I' .,
lJ!ss Physical Func<<onal Extemal '. .~~~;ect, an WCU d not yteld an acrUIlIlI! rep"~n '" Marloet
I I Value.
D.preciaUon - $ N/A __. ..'-."
Dl!p""latodValueollmprovemen1ll ...,.....,.....,...... = $ .......!J/A
;Aa~~,:totl~~~'':~'=:'-';~' .ftN',........"..... : $-..- N/A
,'IDl OVA E ,III. OAC . ........"" $ NlA
ltEli 1 SlJlIJm MIIIIlI,~.IUo. 1 COIII!,4!!4..L"~~ ~ "0IIP1 " ~lJJ!, 3
38 CarllDn A'<enIle 221 yon.. Road 1 _ S\reet. 411<enwC1od Aveliu.
ea..... Pa1~ Ca~lSle.Po.17013 .",,~"'"Ie,Po.l7013 ... <?i.rlISIe,PIl.l7013
:~~c~sublect ~~;m~~'$ 82,000 ,. -- ,~~~~..~iE, ,I $ 60,ilOo ....- ?~~~':~;'r~~,~j]$ 82;000
P' eJ"- L' $ -~ $ :&:I'''' ,--" '-' ''''I' :~ '", 12'T't1 ", ,'''".,.....,....'..,~ S ' .',.., ",.. '"'
n,c \7IUSS IV. Ars! /'71 71.30 i..l,'lll-'.~I~":~.,,.,.i1;~! ,,~.., \l:~." $ .Sl,64 ' ':i""I.'Il,'.;;~!rJvr i\\,.Ij.'"'-.;,,m.ll. -, 2'"' I?"f' I~~ ":'!,,:::;,~.~.'~:~,;:: "..!.,,!,:~
. _. ..,~.......... ~....",.r~..,..~.--.:__. ,""'.'"/11,'1~.f.:b:';;I-1,~, _,:"T ~1~""'~I,.,,,_,,,,I.,.,
,Data andlor Inspec:lfon CIlML &. eCCH . CPML'&.' CccH Cl'ML Il. cci.li' ,,,,,- ' . ,'.. .
Var;n~lIIIon Sources CCCH ~... Ext. !r.~n D~~~....,~,!!_ Of1ve.bv Ext. Inspe.ction
:"',V",,,AW,., ,EADJUS'lM~NTS 0, IP o~ ,OES,CRIP110N +1-IAdius~,nt OESCIlIPllDN +1-\Adlu.Ime~t.. DESCRIPllON +1-IAdiustmef1t
:Sale. or financing nvenI!on~, ComIenllanal Cash
:oncessiona , ne Known '.',", ...._ None KnOwn ....._"".. None_
;Date 01 Salo/llm. ~~9/2004 O!lB..~2004 0.~~9/2005
l.lIoelion Averan. lmllar ;;imllar Similar
holdlFee Slmo'e--' Fl!I! SiriiDle FlIe Siml!!! ." Fl!I! Simple -.-""... Fee Simple _.
Ie O.34aCle......' 0.13."""'(mfl1 l.i~~",17acn,TniIL1 17Dq~~2ar"'(m/ll
VI.w ReSkIentlIlI Resldenllal/COmm. -3;100 Residential Residenlial
,DeslM and Anneal Allncll;Less than I\!!! 1.5 SlIJ!)':Averi,.. .. - Ilanch:-. - . Ranch:Ave""'"
'QwUli\lolConstruatlop ~ - ~ne ;;:;e,.De
. sZ-;;;7m!l\ S5.rs.1lilil:\ "- SO-"" 'm- \ - 42
Condition .", fair AWIiI ;e- ...,...., _ ,-8\100 fair - Avera e
Above Grade TOIllITad;;;.s Il\atba Tolal I Rdrms Illi!hL " ....., TotaiT BdrmiJ J!!!l!11... Tolal Blllms I ~
RoomCounl sT 2:.m 6 3 'I 1.0' s I 3 'lu S 3 1;:':5
- ft)S" M.. Alea", 1300 g; Ft. 11SO ~. Fl ""_ 1::00 1041 So, Ft .__',,, 2590 1238 "'. F'.
~Ba.om"'l & Finished N/A I'llrllal Pallltll iOlIW' Spa".
Rgg",Il!PBelowGrade NoIIa NOlle ___ NOlle ".,,__ None
; Funolionallltil"" LeliS ~~!._ ~ m_ A_ c~_!l"
~ ,~!atinll&.!!ollno AiA/No c. AIr FHAfNo c.~.. FHAJNo C,Alr ..." ..".. FtIA/NO CJ\lr __
En..... E~iclentllllm. ._. ~ne obGeMd NOne KnlllMl ,_. None Known _ None KnCPMI
_Ga;"-;;;;-lI'amo~ , ~!!~ None ,,,.,., 1 Car Aft. -10001 CarAtt.
POmh, Pallo. Oeck, Endosed PomI PlIrd1 I'orrhlPolth -1000 l'M:h/DeCk
FIlIlnlace/s" elt. NOne None None None
I'1!n'; Pool .Ie. None .,... ~ne ......v.Ci- . /i..0!l'l ob"'''.ed' '-" ~~~,!IIed
'~Anish BlOC Co n A1umirnlm Aluminum
, M1.llolBlI + - 1 '7;1OO_":~'" - j-~ 2m n t .' - 1$
'Adjustod Sales Plitt ..., " m.. ftl~",~lI:~;fI:~'. "9
~"'"- . _~_ :..r."'Ii\'.'II:.~i:."'lf~.~'"
01 Com..r.bl. , ,,' ..'. ,,$ '7~,.~~" . $ .6>.290..: 1;,..~1,,:&?9'll1 $ $;3.320
,CommenlS on Sales Comparison (Including Ihe aubjoctPlllperty'.eoml"llibillty to Ihe neighlomood, ole.): TIle comparable ~erues used In this analPlS are In my
,0000nion th...rybestill/llllabl. at tho p~ and havinQ been _'!!!ld mthln lite. most re.cent months. All are lli~ In ptll)lImty ,and simllar' in~~.!,_.
Sr;;:-c, Ad '" l\Ivel1eM tlIIde!!.~mpeMllle Ibrdl~inthec!l!!!l!!~.~wllerel\O\Z!8fY.lI.~fltI""'~..u1.l!lsq.fto_
u....to ealculall! _-;m;;;nd iIiIlshed UVln9}!.~..'n ....... of 100 SQ.ft. $10,IlOo.I!lscre !!':.!!!!ction lIlerool'lMlS uslllt Il:I calcullll>l dllIilren~ln.itUS- A W!IY
m1nl."!\!..~~~usted ftlr the depreCiated ClllIdIllDn of lbe SUl!l~ In.. ~at lOaf replacement alon. rauld well be ~M!I,o.,__.
1200
-~Q
-500
620
-1000
.1000
-8680
. ~ _ CDllPARABLE 10.1 ,,_ __..:::.ia!ilPlUIU; III I CJUm".'Oo. 3 '--'"
Dato. Price and Data 12/30/1985 06108/1987 12/0811999 01/1112005 09/15/1994
SOUln tor p~or lIlIles CO!. "c CCCH etCH CCCH CCOt
wt1h1n year 01 BPprallllll 45,450.00 _. $'18.000.00 _..___ $1.00 _. ,$45,000.00 $45.000,00
~iS 01 any CU!rnnI agreement 01 sale. OIlIlon, or li~ of 1I1e ~ect proper1!J and &nall'lis 01 any prior sal~ 01 subject and oomparablos within ona YIllI! 01 the IlaIa ot apP!lliaal:
S I!l:t Is not and \IllS not listed J!!r:..~Ie. hils not been llmled for sale "'~!~l past 12 monllIS. and hllll not beentra~,1n _past 3yeal$. Subiett .
, and co!!!palllbleS last,transfilrrod IIWIlerShlP on the ~ above, & have not b.!!!..-.~!~_ Since Ihen, Il:I th. best of iii'" a2P.rai~~~,~!I~dQe.'
"DICATED'AWE" lI,lLEllIDUPlRllDllPPIIOACH ........................,... ................................... $
i.niCAnll '...... " III:UE .~IIAIiH fiI Allnl103ble) EotImallld Marlcal Rent SN/A /Mo. ~ Gross Rent Mul"plier NIl< - $
:The 0\I1lf8i1m1 i. made ~ 'a. is' 0 subjoGlll> Ill. ropm. al\tlation.. inSlletllions. Of CIlndi~on.lisled balow 0 .ubjetl to CIlmplmien pi! planunhpec\l\oa~ons.
Condi"ons ot Appraisal: See 1llxt Addendum page... _" '__ __.
;0,000
N/A
Final Reconeiflalion: ~ Addendum page...
. The putp... ot Ihls appraisal is III eSllmate the msrllet valus ollhe real proper1!J Ihat is tho ,,: bject ollhls report, based on Ihl: abll'lll condlbons and ltIe cenll/cabon.
conting.nt .nd limiting conditions, and marl<etv.lue dannlllen Ihal8lll $lilted In the otIacll.d F..ddlo Mac Form 439/1'anni. M.. Form 10048 (Revlsed N/A ).
IIWfI mllI.lITHE IIA11l1ET VAWI, AI UFIIED, OF THE REAL PROPER" DIAT .1 THE IlIIJECT OF THII REPORT, AI OF May 24. 20ft~"....__
fWHIIlII II THE IIATE OF' alllPEcn ID THE EFFECn'E IIATE OF THII REPDIITI TO IE . ~.~__
APPIWIIR: /} ~RVlID"~ I"LY IF REQUIRlO\:
SiQIIB!Jn: U. r -, ,~~ill ""Q 1\ ~ Dill 0 OIdNot
'Nama G.ArlIIur Calmniin -., N;;;,,7'iiaunfaS il~ Inspect PIllPer1y
Dam R.-o" S.l9M" 0.5/31'_.. ..... '- !lm!B.q1.p.tt~ned 0.51311200.5 .."
~:~,r1il/cabon # AssISlaIlt,ll:IlI1e CerUfted SIlII1l.. S!3bl Cartillcstion # RL.000569-~_,
Or Stal> Ucanse # Real EStalll Apl""l!lor S1al:e Po. 0, SIlIIe Uoen.. ""
Fmddl. II.. Fann ttI s.93 1lI~""'''' ~orvtl"",d Ill' Um"d 5""... _Ill Com,,,"v (800) 1lll\l..!l7l!7 - ",,, 2
.. SllIte I'll.
Sla\l1
Fi'fM'" M~, Form 1004 6~9~
L J~lj",'"",,~ '~i.i.o."W"" ; "".......,
-, ~
,. .~,:,tJ:.L_ . i,jjp;iol:lld!i:~r~"!'N_~":<';"
07/251.2005 '17: 24
71 72436510
SAIDIS SHUFF FLOWER
PAGE 07/16
rns NO.lJOUUatJ
TEXT ADDmiNDUM
BOllowerlCHanl ':.I/A
Address 38 OIt1Ian AOwlUe
Clly~e ..,
lenderlCHent Lorrie A. Janes ."
Counly O:Imber1I!nd
Unit No. ~A
Slate !!._ Zip Coda 17013
DEF!NInONS AND DATA SOURCES:
~OSURE nME: For the apJIl'aisl!d property, the I!IlJlOSUIe lime, ~ased on the experiences of other similar proplll1les in the SlIme or
S1l1l1lar ~hborhoodsls ~I~~ to be 1Il1hree tosix months. EllpOllui'e time is backwanllooklng, where lht!re Is historical (IatallVallable
IhIlt prlMdes a Il!lISGnable IndicatiOn of the amount of lime that would have been Involved to market the SUbject property being analvred
and obtain.a sale as of the effective date of the appraisal. This data ha,;; been considered and used in this estimate '
MAQETlIME:, Marketing time on the other har1d Is lbnvard lOOkIng, and is expnIGSed as anestJmate (projllClI~) of the Ume that WOUld
be reIlIil!8d 1O market the subject PlOperty and obtain a sale. In this cOntext, it Should be; noted that I ha1Ie adhered to ll1e dennlllon of
"MaIfletlng Tome" as put filrth by ll1e "AppraisalStandanls Board" an,f' induded in this repOt:t. 1l11s definilionadvlses that marketing time
does ~begln until two things take place; (1) an offering of the property at a price that marketlng participants nnd aa:ePtable and (2) an
efft!dIve mal1\l!li",,~lan Is implemented. ,
SCOPE (EDEtn}OF APPRAISAL; In the preparation of this al1praisal, I have macle a phV$lcal Inspection of ll1e site and ll1e
Improvements (Ifanv). I have traveled the neighborholld and if necess'I'Y, made appro~ OIlseNatio"" or notes. DaIS _ employed
In addlllon werll the zoning map or olnar IIIld orqinance for !he mUlllI~!pality, the recorded deed or Iegaldescriptlon,the tall ~
pan;el rKOrdS, roa.l' multl-nst recOrds, and the FEMA mapS for the 100~tlon, If required, Co/Islderatfon has been UiYl!n to the hl~ and
best Ulie of the property, and a" three approaches to value; with aPPII#tion to those most ,relevant andappllc:able to the vaiuatiiln of the
subject OIitareferrl~to Predominant OcCUpancy, Single Family Age .,"!d Priclng, Pr_nt land Use and Changes are reflecting Iltallstlcs for
towlWlhip/~!Jru\l!lh/gj!neral area, not fat precise subject neighborhood.
ccctt a.-.L BIl!acranyms for the Cumberland County Court HOWland Cenlral Penn Multi-liSt respecIlvely. l11ese were the PIillIarr
sources ll!led til ~ property data. In addltlon, already verilled info~tlon and data (rom my own liles was ll!ledif~d,and where
applOprtate. Al. Information develDped was Independently verified wh,~ public soUrte$ did not provide needed veriti,GltlQn. I mar have
contacted "sting, Or ilille ag~ or other parties to the lransattlons, If I felt It necessary to verify data listed in CPMl, as well as any
suspected unIlrdinary seller concessIOns.
In the valuation process, all appropriate value approaches, or thelr exc',JSions are menlloned In appropriate sections of the report.
CONDII10NSOF APPRAISAL (D.lSCLOSURE):
The apprlllilet(s) is u~ble to know Or verify, and In most Instances un'~ualifted to determine or verify any insulatlon or "tt. fllClor; also the
presence of urea formaldehyde roam Insulation (UFFl), any wood infeitiitlon or causes thereof, anv lead based palnt,any~e, of IIIO/d, or
mildew, any asbestos, the presence or amount of any radon, polycloril1llted biphenyls (Pells), chIorolluQrC/ll'bons (CF<;'s),~~g .~
tana (above or below ground), and soli contamlnaleS or any type of ':Ql1taminallon, "'e quality, of any dtinklno water qmnot be tested or
verllled by theappraJSer(s). "'e appralser(s) has no expertiSe and Is unquallfed to makeanv assumptions, statements, or VlIJrrat1lle5 as to
ll1e condition of any on or off site sePtiC/sewage system if present Th,! appralser(s) Is not quallfied to lest for any COI\liimi~ln,on, or
aroundlhe property. and can make no assumption as to whether or tllllt they are present. It Is to be noted l1owevilr, lhalJI'i1"l'of the afore
mentioned items aie '~ lI1e market value CIOUId be adversely aflllcted or vlolab!d. 1l1e appraiset(s) has I1IlicIe ever, tlI'ort to lOOk,
nollce and dowment If observed, anv apparent or unusual appearing circumstance in, on or around the property at the time of the
inspecllon process.
l11e appr8iset(s) his only considered lhe dwelling and Items ~maJ;enlIy attached as realty. Personal or other Items nOj: permanently
attached such as refi'tgerators, washers/dryefS, window air conditiOfMliS, liee standing SloYes, portable dishwaShen;, et(. were not gillen
value consldilration in the appnllsal pnlCess.
Also NOYAWE Is given as tostoJ:age sheds, pools (above or inlllUunJ), swing sets, normal fencing, or olhEr items or I!Ilterlor structures
of pen:elved value, unlessspoo\ically noted in tile report. Utilities wen;, on @ lime of inspection and all Plumblng!' heating" air tondltlonlng
(if present), mec:ha~al and electrical systems are assumed to be l'uncUonal1ll the best of the appraiser's knowledge, hoIveYilt no walTanty
or exPertiSil is Iltatedll'J this report.
Areas In Cumberland Comly, Pennsylvania were declared 'Disaster jl,reas" alblr September 19, 2004 due 10 Tropical Storm Ivan. 11le
appraiser(s)dk1 not cIetect any evidence ofal'fect l'rom this natural disa!;ter.
FINAL RECONClUATlDN:
ThIs report Is a Summary Appraisal Report and limited Appraisal. lrl the opinion of the appraiser(s), the "Sales CompariSon Analysis"
repr~ lhe best indication of market value for the subject, as diltinl~ in the "Statement of limiting Conditions" contained In this report.
This approach to value was given consideration In estJmatlng the subJec:t's market value as of the date of the appraisal.
The "Income ApplO8ch 10 Value" was not considered, as the area ~i. predomlnalllly owner occupied, therefore limiting the amount of
ayailable rental data that would be necessary to aCCll'alely tomp/ele lhat approach to value. 1be "Cost Approach to Value" was also not
considilred as PI'l!Viously mellt10ned In that section of the report,
1l11s wbject property was prevtOWilr appraised by the appraiser(s) on Jlugust 15, 2001. It Is lhe opinion of ll1e appral~s?lha~ since that
time, lI1e dwelling has deteiorated and depreciated even more 50 thall it was at that time. Despite the "Property APP/illil.ii!!OA factors of
this malllet area (on average and upward condlllon properties), it is fell that the deteriorated condlllon and lack of malnt;l!!1arke and repair
has not only !Ill!; appredated the value, but In fact the dwelUng has dilpreciated In value, which Is shown In the analysis With even minimum
adjustments.
PRIVACY NOTICE:
PUlSl/llnt to the Gramm-lead1-BlIley Act of 1999, erredive July 1, 200:1, appraiSeftl and all providilrs of Pertllnal fitlilnclal services are now
required by fedel'a' law to inl'onn their clients of porlCies with regilnl to lhe privacy of dlent nonpubllcpe/'$C!l18l il1fortl18tion.
In the course of research for this appraisal, we may coiled; what Is m.wn as "nonpublic personailnformation." 'l'his InfotmaUon Is ll!led 10
f8dt1tate the senIIce that we provide, and may includil informatlon p~'ldild to us by you, or Indirectly provided to lIS fro", others with VOW'
authorlzation.
We do not disclose any notqlUbllc personal information obtained in lhth course of our engagement to nonaftlllated third palties, except as
necessary or as requlral by law. A nee: rry disciO$Ut'e would be III an Independent mntractor, or In certain sltualiOl1S 10 thlrd party
consultilnts who would need to know certain Information 10 assist us In providing these appraisal services to you. Shoutda discloSUtl! of this
nature to any person or nrm assiSting in ll1e appraisal process be f1e1:essary, such jlIl(SOl1S shall be adYlsed that an informatIOn Is to be
maintained In strict confidence Within the firm. A disclosure required by law would be one that III ordered by a court of competent and legal
jurisdiction, with regard to a legal action to which you aJ'l! a party.
We will retain records relating to the professional servtces that we haVE, provided for a reasonable time. In order III protett your nonpubllc
personallnformaaon lium III18l1lholizecl aOCl!SS by others, we l11Bintaln physical, electrontc and procedural safeguards that comply with our
prolil5:iional stIIndanls, tv insure lieCIIlty ancllhe integrtty of your Information.
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PAGE 0a/16
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SURlEer PHOTOGRJIIPH ADDENDUM
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Borrower/Clienl ~!.!'..
Address 38 Olrtta~,~u.
Cil)' Carlisle ____,__.,__._.
l.enderlClienl l.ollIe A. :!an...
UnilNo. NlA
Slale ~ Zip Code 1701L,
County Cumlierti"d
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SKE1I'CH
BorrowerlCllenl N/A
Address ~ Carlllln Avenue
City Carlisle
lendertcllent ~!!".;JOtIe8
County 9!~!'d
Unit No. N/A
Slate ~ Zip Code 17013___
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AREA CALeULAllONS SUMMARY LMNG AREA 8REAKOOWN
Cod<! De&afiptian Si_ Nel Total. llllOllllown Sublulalo
GlLlU Piz:JI't:. l'1aQiI' 1900.00 1300,'10 1"!.J:lllt. P],cIo:r;
.,. bol..eeI Pomh 1!18.00 198..'0 !f.0 " '0.0 1300.00
,
TOTAL UVABLE (rounded) 13(,0 1 Calculation Total (rounded) 1300
0..1""'" brUnk", Syot.... So",,,.. COmptny (miDI 9811.8727
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COMPARABLE PHOIOCIIIAPH ADDENDUM
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PAGE 10/15
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Borrower/Client NlIl
Address 3lI CllrIaI Avenue
City Carllllle
l.enderlClienl lolTll! A. Janes
County Cumbe~ll!d
Unil No. NlA
State ".!!.,_ Zip Code 17013
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O"l!Ined by Un"ed S}OI'n11 Sotto... Company (Son) 059.8727
Sail. Comparabll 1
',old V\_
Addl8$s:
PrOl. In Subject:
Sales Price: $
Gross Living Area:
Total Aooms;
Total Bedrooms:
Total Bathrooms:
looalion:
SailS Compalebls 2
Fronl VIew
Address;
Prol. to Subject:
Sales Price: $
Gross Living Area:
Total Rooms:
Total Bedrooms:
Total eal,hrooms:
location:
Sel.1 Comperlbls 3
Frent VIew
AcIdreoo:
Prolllo Subject:
Sales Pllce; $
Gross Living Area:
iotal Rooms:
Tolal Bedroomo:
Total Bathrooms:
, Location;
-...........,^----
221 York RQId
0.10 141 S
82,000
1150
6
3
1,00
Similar
92 Rlirview Street
D.91l MI elE
60,000
1041
5
3
1.00
Similar
42 KenwOOcI Avenue
0.07141 W
82,000
1138
5
3
1.50
Similar
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LOCATION MAP
BOITower/Client !!'lA
Address 38 Olt1llm A_ue
City CarIlsle
lenderlClil!llt L.anIe A. Jones
,----
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PAGE 11/16
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State ~ Zip Colle 17013
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Fill .. 0S00805
~EfIIRlO.OF MARlin VALUE: The most probable price which a properly should bring in a competitive and open market
under all conditions requisite 10 a fair sale, the buyer and seller, each actlng prudently, knowledgeably and assuming Ihe price
Is nol allectedby undue stimulus. Implicit in lhis defininon is the r.oosl,lmmalion of a sale as ot a specified date and Ihe passing
of !ille from seller to buyer under conditions whereby: (1) buyer and sElller are typically motivated; (2) both parties are well
infonnedor well advised, and each acting in what he considers his own bosl interest; (3) a I8aSOnable,lime is allowed for
exposure in the open market; (41 payment is made in terms or cash in U.S, dollars or in teons ot financial allangements
comparable thereto; and (5) Ihe price represents the nonnal considerallon far the property sold unaffected by special or creative
financing or sales concessions' granted by anyone associal,ed wilh lhl! sale.
. Adjustments 10 lhe comp3/llbles must be made for special or creative financing or sales concessions, No adjustments are
necessary for those costs which are nonnally paid by sellers as a resull of tradinon or law in a market area; these costs are
readily identiliab,le since the seller peys Ihese costs in vlrtoally all salelltransactions. Special or crearlVe llnancingadjUstments
can be made 10 the comparable property by comparisons to financing lerms offered by A thim party ins"lutionallender that is not
already.involved i" l!1e property or transaction, Any adluslment should no! be calculated on s mechanlcal dollar for dollar cost
of lhe financing or concession, but the dollar amount of any adjuslmenl should appnMmale the markel's reaction to the financing
or concessions based on lhe appraisers JUdgmenl.
STATEMENT OF UMmNG CONDITIONS AND ,lPPRAlSER'S CER'IFICATBON
CO,.TII'E'" AID L1Mlnl. COIOIIIOII: The apfllsiser's cerl ifir.ation that appears in the appraisal report is subject to
the following conditions:
1. The appraiser will not be responsible for mallelS of a legal nature oiat allect either lhe fIIoperty being appraised or Ihe title
10 it. The appraiser aS$Umes lhallhe tille is good and marketable and, I here/ore, will nol, rendorany opinions aboulthe title.
The property is appraised on the basis at it being under responsible awneJShip.
2. The appraiser has provided a skelch in \be appraisal re\lOrt to show apprnllimate dimensions ot the ImplllVements and the
sketch is included only to assistlhe reader of the report in visualiZing the properly and understanding the appraisers detennination
01 its size.
3. The apflllliser has examined the available flood maps lhat are PIllVI,jed by the Federal Emelllency Mal1lJllBment Agency (or
ol,her dala sources) and has noted In the appraisal report whether the Ei~bjecl site is located in an idenlllied Special Flood Hazafd
Area. Because the appraiser is not a surveyor, he or she makes no goa,lantees, express or implied, regallling Ihis delenninalion.
4, The appraiserwitl not give testimony or appear in court because h'l! or she made an appraisal ollhe property in questiO",
unless specific alT3ngemenls 10 do so have been made beforehand.
5, The appraiser has estimated the value 01 the land in the cost appl1lllch at its highest and best use and the Improvemenls
at thAlr conlrlbutolY value, These separale valuations of the land and improvements musl nol be used in conjunction wlIh any
olher appraisal and are invalid it they are so used,
6. The apflllliser has noled in the appraisal report any adverse condithns (such as, needed repairs, depreciation, the presence of
ha2ardous wasles, 1000C substances. etc.) observed during lhe inspection M (he subject property or that he or she became awa~
01 during the nonnal research involved In pertonning the appraisal. Un ,oss otherwise stated in the appraisal mport, the appraiser
has no knowledge of any hidden or unapparent conditions of the propllrty or adverse environmental conditions !including the
presence of hazardous wasles, toxic substances, elc.) thai WOUld makll the property mom or less valuable. and has assumed
that there are no such condi\ions and makes no guarantees or warmnthlS, elqlress or implied, regarding the condition 01 the
property. The appraiser will nol be I1lsponslble tor any such conditions that do exist or for any enginooling or testing thai might
be required to discover whether such conditions exist. Because lhe apllraiser is nol an expert in the field of environmental hazards,
the appraisal report must not be considered as an environmental assll.\sment of the property.
7. The appra!w oblllin€d1he inlol11lBliOll, estimates, and opini1ms thlll Wlll8 ellplllSSlld In the appraisal report Il'Om soult83lha1
he or she considers 10 be reliable and believes them to be true and COIIllCl. 111e appraiser does nol assume responsibility for the
accuracy ot such lIems lhat were furnished by olher parties.
8. The appraiser wm not disclose the contents of the appraisal report except as proVided lor In the Unilonn Slandaldi of
Professional Appraisal Practice.
9. The appraiser has based his or her appraisal report and valUation !;Dnclu3ion for an appraisallhat is subject to sal,isfaetory
completion, mpainl, or alterations on the assumption 'hat completion ot the imfl/Ovements '/IIilI be performed in R wolkmanllke
manner.
10, The appraiser must provide his or her prior written consenl before Ihe lender/clienl specified in the appraisal re\lOrI can
distribute the appraisal report (Including conclusions about the propel'Y value, the appraise~s idenlily and professional
designations, and mlerences to any professional appraisal OrganizatiOFlS or the tinn with which the appraiser is associaled)
to anyone olher lhan the borrower; the mortgagee or its successors an.1 assigns; the mortgage insurer, consultants; profeSSional
appraisal olllanizallons; any stale or federally approved financial institution; or any deparlment, agency, or instrumentality of
the United States or any stale or the District of Columbia; except Ihal the lender/client may dislJibute the property descriplion
section of the mport only 10 data collection or fllporting servlce(s) wit/lOut having to obtain Ihe appraisers prior wrillen consent.
The appraisers wrillen consent and approval must also be obtained be;'ore the appraisal can be conveyed by anyone to the
public through advertising, public relations, news, sales, or olher media.
F...rdl."... F."" >130 (lII93, WIH)
f'3ve'of1
This 'orm Walt repRJduGll1 byUnI1l!d Syt18rm Sfdtwafl! r.ol1'lPllny (BOO) 9&O..fl727
Fm. "'.. Form 10046 {1II9l
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07/25.2005 '17:24
7172436510
SAIDIS SHUFF FLOWER
PAGE 13/16
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APPRAISER'S CElTlFICATml: The Appraiser certifie.q and agreellhal:
1, I have researched fhe subject mal1ret area and have selected a minimum ollh," recent sales of properties most similar
and proximate to the subject properly tor consideration in the sales cOl"1parison analysis and have made a dollar adjustment when
appropriate to relleclthe market reaction to those items 01 significant v!uiation. If a significant item in a comparable property
is superior to, or more favorable lhan, the subject properly, I have madl! a negatIVe adjustment 10 reduce the adjusted sales price
of the comparable and, if a sillnificant lIem in a COlllpal1lble properly i~ Inleriorto, or less favorable IIlan the subject properly \
have made a positive adjustment to increase the adjusted sales price c,lthe comparable. '
2. I have laken into oonsidellllion the lactolS that have an impael on value in my clevelopmenl 01 the esllmate of market value in
the appraisal report. I have not knowingly wilhhelcl any signllfcantlnlonnalion from the applllisal report and I believe, to the besl
of my knowledge, ll1at all statements and information in ll1e appraisal ",port are true and COIlllCt.
3. I slated, in lhe appralsat report, only my own personal, unbiaMlcl, and pt'Ofessional analysis.llIlinlons, and conclusions,
which are subject only to the contingent and limiting conditions specWed In this fonn.
4. 1 have no present or prospective intere:;1 in Ihe properly that is the :!:tJbject of lhis report, ancll have no present or prospective
personal interest or bias with respect to the participants in the transaction. I did not base, either partially or complelely. my
analysis andlor the esIImale of market value in the applaisal report an lhe moo, color, religioll. sex, handicap. familial slatus.
or nalional origin of either the prospective owners or oocupants of the Bubject properly or of the present owners or occupants
of the properties in the vicinity 01 the subject properly.
5, I have no present or contemplated fulure Interest In the subject Prol18r1y, and neither my current or future employment
nor my compenll8lion for performing this appraisal is cnnllngenl on IIlI! aPllllllsed value of lI1e properly.
6. I was not re~uired to reporf a predetennined value or direction inv,lue lhatfavors Ihe cause ollhe client or any related parly,
the amnunl 01 the value eslimale. the attainment of a specific result. or the occurrence of a subsequent event in ortler 10 receive
my compensation andlor employmenl for performing Ihe appraisal. I did not base the appraisal report on a requested minimum
valuallon. a speclfic valuation, or the need 10 approve a speo\1ic mortgage 'Ioan_
7. I perfonned Ihis appraisal i'n con/onnity with the Unllonn S\andan:J,~i of Professional Appraisal Pmctice Ihal were adopted
and promUlgated by the Appraisal Standards Board of The ApPlaisal HlUndation anclthat were in place as 01 the effective dale of
this appraisal, with the exception nlthe departure provision 01 Ihose Standards, which does not apply. I acknowledge thai an
estimate ot a masonable lime lor elIposure in the open market is a condition in the definition of markel value and l.he estlmale
I deVeloped Is consIstent with tile marketing time noted in the neighbo,llOOd section of Ihis report, unless I have olherwlse
staled in the reconciliation seelion,
8. I have personally inspected the inlerior and exterior areas of the sUlljecl properly and the exterior of all properties listed as
comparables In the appraisal report lfurlher cart.lly thai I have noled allY apparent or known adverse conditions In the sublecl
improvements, Oil the subject site, or on any site within the immediate, vicinity of the subject property 01 which I am aware
and have made adjustments tor these adverse conditions in my analysis of the properly value 10 the elllentlhatI had malkel
evidence to support them. I have also commented aboullhe effecl 01 the adverse conditions on the mar1celabllily of the SUbject
properly.
9, I personally prepared all conclusions and opinions abeulthe ",.aIIJslale thaI were set forth in Ihe appraisal report. It I relied on
S\gnificanl professional assistance from any individual or individuals hi the perlonnance of the appraisal or the plepalatinn of
the appraisal report. I have named such individual(s) and disclosed thlli specific tasks perlonnecl by them In the reconciliation
section of this appraisal report. I certify thaI any Individual so named 11, qualified to perlenn the tasks, I have not authorized
anyone 10 make a change to any item in the report; therefore. it an unauthorized change is made to the appraisal report, I will take
no responsibility for ii,
G. Arthur Calaman, Asol!lrant III the CsIIInod Real EsIlllJ! Appra"'.r, has aS$SlIod and contrlbU\l!d S1gniftcanlly In the 1l1$flGCllon procedure, colloction of
dlllll, mar1<et _rch, (O/I\plGllng of forms, pholllS, sketl:hes, compiling ",'I written report, and all other arellS involved in the prepal1ltiOll oftniS
appraiSal ..pat.
}V'
SUPERVISORY APPRAISER'S CERTIFlt:ATfOI: " a supelViso~I' appllliser signed the appraisal report. he or she certilfes and
agrees that: I directly supervise the appraiser who prepared the apprailiJI report, have reviewed rhe appraisal report, agree with
the slatements and conclusions of lhe appraiser, agree to be bound by'lhe appraisers certffir.allons numbered 4 through 7 above,
and am laking full responsibility lor theappraisa\ and the apPlilisal rep'lrt,
ADDRESS OF PROPElTY APPRAISED: 38 ClrflDn Avenue, Carlll:e, P3 17013
Signature:
Name: G.Arthur ealaman
Date Slgnecl: 05/31/200S
Stale Certilfcalion #; . nt Ill.". Cl!rtified
or State License #: Real e- ~~L,
State: P3
Expiration Date of ClIrlificallon or license:
f Ulll:
. ; DOuglas
Dale Slgne : 5 '"
State Certilfcallon #: R1:000569-L __...,..._.__.....__""'"'......._..
orSlale License #: __....___
State: Pa.
ExpireUon Dale of Certification or license: 0&/30/05
181 Did 0 Did Not Inspect Property
(only if required):
APPlAISER: \~UP
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P'IlZ0IZ
T~, ra...... """""..0 by U~led S,vot.... Sollw... OIlmp'ny (800) 080-8727
Fannl. M.. Form 100<18 (0191
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71 72435511'1
?~IDIS.SHUFF FLOWER
PAGE 14/16
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Idm.,m !!tLLIAM K. ~Q}(. ftl!le~'~il~~:;,!,~W~I.'l..tNl1\'. DECK,S!., widOVOlI:'
of. :SauthMidd'lOtO\'l,::1(l.!iI~s,!:!l;;l!!!:i,:tulnb<l'-" luc! eOUl'lt~., renn.ylvlUlill"
'<lRANron and Pllt'tyof:i~:;~,f,it?ft pe.rt,
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GlilAA1.D fl.' ,;r~ .n~r'6!i.'jj.t:,2;~":.\10\11F.S, hi8 liib, of N"wille,
perl'lIlJylvl1.I1ia-;"GRAN. .. .;'arl "'i!fil:z:tiltll
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., t~. _a. port, IIttl\t!lf,l~t~ T"~i~~~:~.~~;(; "l..e Jl~oI ....., for lO1Ni '" _.-."..
.1I~""" ofli'OBU~FIV8 ~~~':J!.:Jtt~';:*iimlRED FUU Al!lJ) OD/10D 1$45,450. DOl
noli.... 101".1 .....l' ot III. O"lledtli,'t. :iiiiii~~~i~}~f.~if.i;,d '",ly "";~ b!,'~' ...I! "",. ieso! .~.
_cOOftfl pnf'1. tv tlG Hi" fUr'l Y' ell t~fr~~r~;~.ff~'~~~n.4 btllOC'ft th oft.li1\. "nd tI,,"e.,-y 0' t"n,
CIlrc.anlh~ t;,.e rcoeipJ: l(lJatrtJOf.f Itt.:rebN dokR,nU",if';II,:':"::, '. .1\8.8-
tre.t...., _gol.IlISef. f1l'd.. IIUCftf'd, tt\tt.oJJr.d, 'rGJcQlt~~!;.:(!~~~je.J ."~ cuctfir"1llr:d. (U,d loM '''''.d tl'l"N"'~ ,,~.
pranl. hlJl',m.. MU~ IIC1(l'ft. ,~'4QJ1, retM';;~!I;e"tl eDftU... ..<<0 ,.., ftt.(lt PU"f ;i.e.s or
tlte ,...,:",11: ..,., ~hair ft..,..I ""... ....~...
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~~ll ~bo&e c:ertain lots, or parcels of ground situate in South Middleton
TOWJlehip, Cumblll;rlal'ld CoUl\ty, PGnn>lylvlInh., ~\!tl\c-c ....ith. Ilouildinqs
"'nO illIprovl'.tnant.ll ereC"l:ElI'l, :thereOn ,boiuldea:,i\l:.a. dl)lledbed as foU.,."g:
. .: ~.:',,:;'('. :/::.'.,:::<; " .:',~ ,"',:'>"'.'" ~.;:::'.~i -:;: ~':
!:!Q:.. 1 - I\Lf. that all;r~',io't::&.~:\:9:),.oi!M::,,~~ii:;i;t;e in Soutb Mia131eton
TownShip, C\lmbe!J::ls:M.,..eblJl1ti!,.:Plilti~JJl1ik.i:o!I'll;:La./.ibl!d.ng Lot No. 21'1i alock
UF", :l.n the il,an of ~D-61i:..knQ\irif:::::_i;r;''!darlik.llS;..Iii~~OI:'.. whicll l' ll.l\ is
rec:orded in tl'l.e OffiQe'.'Ql!:,>th4i~i'i\~,:l(I;;d:;ai':::':of;.::tl'iiM. il\ and fo:!: Cl,\Illl:llarb.nd
CO\ll\ty" PGl'lnsyl'llanill,' i!l.",~..l!i.\i'i: ~cie;h-/~ ; :;:i>.a~,-':;7-g..' IIAVING the>:eon erected
II Cllldil~"t.O%y awe1:L1ng hO?i~~ ,:" ';". '.'" .
aJ:ING t1'le same pJ:em1sas ttl'l:le to ",biob became vellted in William K.
Beck &ng Mila 1'1. !Jack, his ",!.fa. ~,y <3o~ .",f Walte.!: I!'. Nickel. Jr.
lIna Louise G. Nicksl. hirr':llii-fe, ,b);'.'l;htij,l".:al;.-tornGy~in-fact, Linda
F. PBJ::Dltr. datod July 1, 'l!iSll':a~:~ ,:i:$cordeCl in Dellel aDak lq-N, Page
? 4. CullIber land County rocord,;' . . ".
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NO. :I - :t.01!, 27., Block .F", of 1'11'1'1 of Lots knCl'lll\ all CarliBla Manor ,'.
as %ecorded in the Office of the A~corder.' of Deeds fO% CumberlanCl , .
County, at Carlisle, PeDIlSylvan1a. in Plan Book l. '898 19. saul'" ,'" ','"",
Lot hllving a frolltag~ of fifty (SOl feet on Car.lton Avenue and <
extending one h'~n41:'1!a ut'ty 1150) :fest in depth, and 'be;ng subjeot ,
to building ana '11lEt rQst.r.iCltiol'l!\l w!\ich. ilJ:e attac::hed "tel lInd made ~
pll.:t.t. of sdd Pan of :t.Qt.s, exoepting )lest.rietion No.2. ",hich ill .;
e~l:Q.1I1y iJlt".e.n<Se.o. tlO't t.o impose 0,\: rQ;!.1\\pose, .. , , ':
',' ,'..,.!;t).,..r\ ..,;:..,. .,:,:.. """",'''.'''",,:, ...'.;..-i.,.. '...', ,..:",.,:,:,:t'-;;::i'~i,;,;,\'(,.;:;Y;.':j";a;; j.K:
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7172436510
SAIDIS SHUFF FLOWER
PAGE 15/16
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RING the IIAl11ep:8IlIl.eeB ti tl,. to whioh became "ellted in Milliam K.
Beck, Sr. llnd Anna Harte llee:~, hia wife, by deel.!. of Charles A. ~.
lieill1:e .llI~d Mary to. Hein;l:e, tl'~sb<lnd and, wife, dated Septelllce.r: 29.
1966 and recorded J.n Deed 20~l:. n-22, Pll<J'" 199, CtlI!lbadand County
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TilE sdel Anna M. :,;:lil~~W~"~~;r;Qfi~_if.,,.;1j\ Mila Mad.. lIeek died on May 7.
3.982, thereby "~a;,~,~'!li1r'i;~:i~l.K:.;!(.jt;:,i>r;ii~niM K. ~e"Jc., aJso );nown as william
K. IJ<i:ck.. Sr., "':l.O\c;!~~*/i,b.]/:.;i,!llt!!S.i,M.:;jlEl1\::,:of ll1w.
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UNPEII AND SUBJECr, neVEll:'th:eJ,ess. to easements, ;r;..~t.:cl,ctions, :reserva-
tions, conditions and ::igntII ,of way of ,~.":"'rd.
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O..lg..d by Un~'" SlOt... So"",.. Company 1811D) Illlg.am
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07/25,(2005'17;24
7172435510
PAGE 15/15
SAIDIS SHUFF FLOWER
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AlTACH.MENT1
BOARD APPROVED CHECKLI$T FOR, ASSISTANTS
I THE IlOARD I:iAS APPR.OVED THIS CHECKLIST FOR US!:, BY ASSI~TANTSITRAINEeS WHEN ASSISTING IN THE
I,', PNf;.RL~DANCE OFAPPRAISAI.~ FOR QUALIFYING EJ':PEAIENCE. A COPY OF THE CHECKLIST i5 TO SE
I \0 i~PE[] !NiALL AIi'PRAISAL R",PORTS COMPLETED B.... ASSISTANTSlfRAINEES. tHE CHECKLIST SliOUI..D
Ii se R~rAINEq IN YOIJR WORK FIlP. ANDINCLUOED WIl'H THE APPRA~L REPORTS THAT ARE REQUESTED
Ii BY T1tSOA"-DOFFlCE. TH& qlfiCJY.JSTIS roJYiJ~;JLIN AD9I170NJro rnE..8EQJJ~Nn'i ,OF ~,fl.13(a1
: ,1M ~ ,'i' ,',"'" ~J1!l,TTHESII~VISING !;'~llrrF'E'D AfiRRAI9ERMtlST SIGN AS "CER'f;Jf.'lISO RElL
:JIii::ltt~ AN8 mAT ?),;f[t_~ISTANJ;M!lSr;.SJ~.,;.rs_~,'rI$(J:1'rAN7J.Q.1JIE CER'(Jf'liO 8m
E T. ',I, ". ,SER\~ YOU MAY.:COPVitHE":lHeCKiJ$fAS NEEDED.
," ';.;/: ;::.:-".,:~~. ,.: . ,," <:::..,....-:.. .:, ,:::~;- ,: ':'.~:,
SU&JEt'r PROPERTY: 38 Ca.rJ.tp.!lAY-etIl.lE!. ca~nsi~.;:Pa;, 170ia:.:' .','. _._______.______,__
DATe, OF INSPECTION: OS/24/?,OO5
Tile ~18tIInt 10 the lItat&Il/lertIflQd real esta1e appr~et 'f~ 'tlil~~liport has assisted In UIe foll6wing:
"""". .1'
..l:... Set up the file With all form& and gellehlll inf~rhililKl~fri;..i'tiI$ report
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Aulsl8d In gatheringlllld enlllrlng d,lIlli as foli~: ..riii,AUtlSBmel1t informlltic)n and map, FI~ Hazard
inform81lon and map, Zoning Information an,~~l!,,:~on map and s'milm' information.
Accompanlerl and assisted In tll9lnspection.~f:~~t~.~ profKIrty.
" . . .. ,.,,'." . . ~.~" . ,:;'.
AMI.led in analyzing tfle Highest and Best uSe'Q(tllll;~~bJect property_
. .... . ~ : ", ,.' .~: <i. . .
AeaI!l1Ild In e-erin9 information fct oom~le:'imn';.t$8tes dlltlil. verified .... ana\y2:ed 1tIe I10Trlparable
land &11I$$ data.'; ," :'-: : ,,::,:' ,
, ,'. . ....'...:
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AsslsfwS In ga1tIering InfonnatiQn f()f tM C08~:"'j)p~\~k.~ata. aMlya~ and selected Ule OOfit amounta.
Asslsflld In ga\I1llflng Information for the fn~~'Ap~r~h data. verIfied and analyzed U1e rental data.
':',::'" ....:::.:.":
Asal8flld In plherIng Information for compa~bJemBrket Sales da1a. verified and analyzed the
c;omparable m8rket sales da1a.
Aesisllld In verlfylllg data at 1tIe Tax Assessment Office. Recorder 0'1 Deeds otfiee, COunty STEB monthly
rl!port. County microfiche service andlOr local MLS :;ervice.
Assisted in file eX18rlor inspection of the salas, rentlhl, land and other comparables.
Assisted'in eketdI drawing.
AlISlsl8d In entering subject and comparable d_ OJ!I tlla form and the data In the commBnt areas.
AuIslIId In final hlCOnr;l/lOltion and final estimate of '/a1ue 01 the subject property.
A8lIIslIId 111 the final revlOw of !hIs report
..l!. Assisted in putttng, ,together and packaging U'te flnalreport~7'
, "', ""- ...-) ,,,""-',
SlGNAntREOF ASSISTANTITRAINEE: C&d.:;-{ , L
G. Arthur CalB1
-----......
,
The ell_VisI", "tate _Ilfled reaJutafe appralser did reV~i. all work clone by the llUlSClIntltralnee and vwlfles
ttIe Millltafltltralnee did a&8ist wllti the items checked IIlboVll,
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o.~,/IId by United Sl".... Soli.... _"" 1100) 9llIh'I127
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9 114. Credit from your 2003 PA income Tax retum. .....,.................,...,..... 14.
~I
~ 115. 2004 Estimated Installment Payments. ...................................... 15.
1"'1
fill 16. 2004 Extension Payment. .. .. .. .. . . . .' .. . .. .. .. . .. .. .. .. .. . . . . . .. . . ., .. . .. 16.
~I
~ : 17., Nonresident Tax Withheld from your PA Schedule!s) NRK-1. (Nonresidents only) 17.
lll1L18. Total Estimated Payments and Credits. Add Lines 14, 15, 16, and 17. . .. . .. . . . . .. 18.
.... - ,-
Tax Fo;r~iveness Credit. . Dependents, Part B, Une 2,
19a. Filing Status: c::> Unmarried or c::> Married c::::> Deceased 19b. PA Schedule SP
, Separated ,............
20. Total Eligibility Income from Part C, Une 11, PA Schedule SP. . mIl.JJl.I]
21. Tax Forgiveness Credit from Part D, Line 16, PAschedule SP. .....".......... 21.
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PA-40 2004
0400220018
Social Security Number shown first
Name(s)
j .I N ~s
12. PA Tax Liability. Multiply Line 11 by 3.07 percont (0.0307). . . . . . . . .. . . . . . ., . . . .. 12.
13, Total PA Tax Withheld. See the instructions. .................................. 13.
22. Resident Credit. Submit your PA schedule(s) G and/or RK-1. . . . . . . . . . . . . . . . . . .. 22.
'.
23. Total Olner Credits. Submit your PAScnedule OC. . . ..... . . .... .. . . .. ..... . .. 23.
.... 24. TOTAL PAYMENTS and CREDITS. Add Lines 13.18. 21. 22, and 23. ,............ 24.
.... 25. TAX DUE. if Line 12 is more than Line 24, enter the difference here. ., . . .. . .. . .. . .. 25.
26. Penalties and Interest. See the instructions.
If attaching form REV-1630, fill in this oval ,......................... ~ 26.
.... 27. TOTAL pAYMENT. Add Lines 25 and 26. ..................,................. 27.
lB.-OVERPAYMENT. If Line 24 is more than the total of Line 12 and Line 26, enter the
difference here. . . . . . .. .. . .. . . . . . . . . . :, .. . . . , . . . .. . .. , . . . .. .. .. . . . . . . . . .. 28.
The total of Li,nes 29 through ,35 must equal Line 28. r.::;;;;;;:;;:;
29. Refund-Amount of Line 28 you want as a check mailed to you.. ...... .~~ 29.
30. Credit- Amount of Line 28 you want as a credit to your 2005 estimated account. .... 30.
"
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OFFICIAL USE ONLY
.,
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131. Amount of Line 2B you want to donate to the Wild Resource Conservation Fund. . .. 31.
i: 32. Amount of Line 28 you want to donate to the United States Olympic Committee. 32.
Q 1 33. Amount of Line 28 you want to donate to the Governor Robert P. Casey Memorial
~ 1 Organ and Tissue Donation Awareness Trust Fund. ...................,..... 33.
:2:1
g I 34. Amount of Line 2B you want to donate to the KoreaMelnam Memorial Inc. ........ 34.
....: 35. Amount of Line 28 you want to donate to the Breast and Cervical Cancer
L Research Fund...,...................................................,. 35.
--"
SIC3NATURES(S). Un(ler penalties of perjury, J'(we) declare that I (we) have examined this return, Including all accompanying 'schedules and
statements. and to-the best of my (our) belief, they are true, correct. and complete.
Your Signature Date Spouse's Signature, if filing jointly Date
:Ii! Preparer or Company Name, other thEm taxpayer(s), based on all information of which the preparer has any knowledge. (Please Print)
~ L 'I Date I(".,,.')telephone numb"
o - - PLEASE DO NOT CALL ABOUT YOUR REFUND UNTIL EIGHT WEEKS AFTER YOU FILE.
Side 2
L
0400220018
Exhibit "B"
0400220018
-.J
pa.402004 (09-04)
Pennsylvania Income Tak Return
~AoeporbjJent of Reyenue, Ho'n$urQ, PA17129 , , , , , ' ',', ' , "" OFFICIAL USE ONLY
PLEASEPRINTlN ll~CK INK. alilillER'ONELETTER OR NUM$ER.IN EACH BOX. IFILL IN Ol/'ALS cOMPLETELY.
YourSoci,,' security Number , Spouse's Social Security Number (ff filing jointly)c::::> ' ' Extension. See the inetruClions.
, ',',', ' ;,::',IlJ],." ,', l.ImTl c::::> Amended Retum. See lheinslructions.
Resl~ncy Status. Fill .jn only one oval.
,CIJII R Pennsylvania Resident
c:::J N Nonresident
c::> P Part.Year Resident from
_,_ /2004 to _1_ 12004
~~~il-"le~"il-i1"1;ii1,}'Jj"-1i*";l>iiih1tl1H,,ii~1SlC1-"',j]"i ','!1',:.":!J:",..,c1, ".q"":-I,,,,,.;,;;,it:r~1jMJr.mi:!jMiJi!IlIJ~~__d~!lii8lilUjiRIi!~i!,!~lJli!I'~~'"~'"RWi""' -,' ~.
.-J
OliOOll0011
';:;'$
Suffix
fII]
I
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Suttle
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First Une of Address
0TIIIITlJ_=
Second Une of Address
=rm
City or Post Office State ZIP Code '
DJI[[l_:[IlIillJ rn (]J]l]
Daytime Telephone Number School Code
mIIJ]] ~
....
WI
Il5 I your FirstN.me
:I: I
ml .
S 1 Spouse's First Name
wl=
~ I Spouse's Last .Name - Only ff different fro ' , Lest !'jam. above
...1
.... '
MI
o
MI
o
OVERSEAS
MAIL.
Usefullrelurn
address to Indude
ciIy,alUntryand
ZIP'Code in local
formals.
1a. Gross Compensation. Do not include exempt income, such as combat zone pay and
qualifying retirement benefits. See the i'nstructions. ............................. 1 a.
1b. Unreimbursed Employee Business Expenses. ................................. 1b.
1c. Net Compensation. Subtract LIne 1b from Line 1a. ... . .. . . .. . . . . . . . . . . . . . . . . . . .. 1c.
2. Interest Income. Complete PA Schedule A if required. .......................... 2.
3. Dividend and Capital Gains Distributions Income. Complete PA Schedule B if required. .. 3.
Q LOOS
4. Net Income or Loss from the peration of a Business, Profession, or Farm. ... c::>
5. Net Gain or Loss from the Sal~, Exchange, or Disposition of Property. ....... <::3
lOSS
6. Net Income or Loss from Renlll, Royalties, Patents, or Copyrights. .......... c::::>
7. Estate or Trust Income. Complete and submit PA Schedule J. .................... 7.
8. Gambling and Lottery Winnings. Complete and submit PA Schedule T. ............. 8,
9. Total PA Taxable Income. Add oniy the positive income amounts from Lines 1 c, 2, 3,
4, 5, 6, 7, and 8. DO NOT ADD any losses reported on Lines 4, 5, or 6. .. . . . . . . . . . .. 9.
10. Medical Savings Account. CAUTION: See the Instructions. Enter the amount from
your Federal Income Tax return. Do not deduct medical expenses or insurance. 10.
11. Adjusted PA Taxable Income, Subtract Line 10 from Line 9. .................,... 11.
L
Side 1
EC OFFICIAL USE ONLY Fe
rnr.C] f,rnCO
0400110011
~"".
~ -~,~ -~- - -~ ,~ ,,~ '-,'., -~>". -,-
-~, ~- -~~
c
,-
Filing Status. Fill in only one oval.
(Bo S Single
c::> J Married, Filing Jointly
c::> M Married. Filing Separately
c::> F Final Return. Indicate reason:
c::::>
o Deceased.
Date of death
/2004
c::::>
identification Label Change.
FlII in this oval if the label Is not
completely correct. Discard the incorrect
label. All in this oval if you did not ftle a
2003 PA lax return.
Faimers. Fill in this oval if at least
two-thirds of your gross income is
from fanning.
Name of school district where you lived
on 12/31/2004: J IVI" d d I (T",y
c::::>
Your occupation Spouse~s ()ccupation
;\'w~~a,v >'l
4.
5.
6.
Oli00110D11
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Form
2106
Employee Business Expense~
OMS No. 1545-0139
... See separate instructions~
~@04
Department of the Treasury
Internal Revenue Service (Ol
Your name
JUf'J,E..t
Occupation in which you incurred expenses
-1 K '{J('.1-rf"-le
Attachment
Sequence No. 54
Social security number
~oS ~5'J.. 9q,-~
~ Attach to Form 1040.
ImJ Employee Business Expenses and Reimbursements
Step 1 Enter Your Expenses
Column A
Other Than Meals
and Entertainment
Column B
Meals and
Entertainment
-1.
1 Vehicle expense from line 22 or line 29. (Rural mail carriers: See
instructions.) . . . . . . . . . . , . . . . . " 1
2 Parking fees, tolls, and transportation, including train, bus, etc., that
did not involve ovemlght travei or commuting to and from work.. 2
3 Travel expense while away from home overnight, including lodging,
airplane, car rental, etc. 00 not include meals and entertainment. 3
4 Business expenses not included on lines 1, through 3. 00 not
include meals and entertainment . . . . . , . . . . .
5 Meals and entertainment expenses (see instructions). . . , .
6 Total expenses. In Column A, add'lines 1 through 4 and enter the
result.ln Column B, enterthe amountfrom line 5 . . , . .. 6
Note: If you were not reimbursed for any expenses in Step 1, skip line 7 and enter the amount from line 6 on line' 8.
Step 2 Enter Reimbursements Received From Your Employer for Expenses Listed in Step 1
7 Enter reimbursements received from your employer that were not
reportedtQ you in box 1 of Form W-2. Include any reimbursements
reported under ,code "L" in box 12 of your Form. W-2 (see
instructions) ......,...,.......7
Step 3 Figure Expenses To Deduct on Schedule A (Form 1040)
8 Subtract line 7 from line 6. If zero or less, enter -D-. However, if
line 7 is greater than line 6 in Column A, report the exeess as
income onForm 1D4D, line 7 . . . . . . . . . . . .
Note: If both columns of line 8 are zero, you cannot deduct
employee business expenses. Stop here and attach Form 21D6
to your return.
9 In Column'A, enter the' amount from line 8. In Column B, multiply
line 8 by '5D% (,5D). (Employees subject to Department of
Transportation (DOT) hours of service limits: Multiply meal,
expenses incurred while away from home on business by 7D% (.7D)
instead of 5D%. For details, see instructions.) . . . , .. . .
;)/c17
ttfll ).,/
3/31
10 Add the amounts on line g of both columns and enter the total here. Arso. enter the total on
Schedule A (Form 10401. line 20. (!'ieservists, qualified performing artists, fee-basis state or
local government officials, and individuals with disabilities: See the instructions for special rules
on whereto enter the totaL) . . , . . . . . . . . . . . . . . . . . ... 10
1.ft'-fK'
For Paperwork Reduction Act Notice, see instructions.
Cat. No. 11700N
Form 2106 (2004)
"'~iilil,,",.~iH/,1&<iiht',l. >lA;",,, ',- <,;'" "h1-IJ;;W;-,.~.~,"-ji!"&.!"-_;hi'lk,_~,,~'~lk,,,;_1i~"""i, ,!;,d"if<-j;.';\d.i;;.<;:0.1.~ "
FO':"-l.,21 06, (2004)
Vehicle Ex , nsl;!S
Sectioli A-Generallnformat'on.(You must complete this section if you
are claiming vehicle expenses,)
11 Enter the date the vehicle was placed in service 11 / / / /
12 Total miles the vehicle was driv:en during 2004 . 12 miles miles
13 Business miles included on Iin~12. . . . . 13 miles miles
14 Percent of business use. Divide;!ine 13 by line 12 . 14 % %
15 Average daily roundtrip Comml.\ling distance. . . 15 miles miles
16 Commuting miles included on line 12. . . . . . . 16 miles miles
17 Other miles. Add lines 13 and 16 and subtract the total from line 12. 17 miles miles '
,
18 Do you (or your spouse) have another vehicle available for personal use? . 0 Ves 0 No
19 Was your vehicle available for Personal use during off-duty hours? 0 Ves 0 No
20 Do you have ,evidence to support your deduction? . , . . . . . . 0 Ves 0 No
21 If "Ves," is the evidence written?, . , . . . . . , . . . . . . 0 Ves 0 No
Section B-5tandlJrd Mileage'Fliite (See the instructions for Part II to find out whether to complete this section or
Section C.) ,
22 Multiply line 13 b 37.5$ (;375)
Section C-ActualEx enses
'""lllll!lilril\fi'l""""'-='li.1I~,~~g;""I~.iJl.itil!!
(
"
Page 2
(a) Vehicle 1
(b) Vehicle 2
23 Gasoline, oil, repairs, vehicle
insurance, etc.
24a Vehicie rentals. . .
b Inclusion amount (see instructions) .
c Subtract line 24b from line 24a .
25 Value of employer-provided
. vehicle (applies only if 100% of
annual lease value was included
on Form W-2-see Instructions)
26 Add lines 23, 24c, and 25. ,
27 Multiply line 26 by the
percentage on line 14
28 Depreciation (see instructions) .
29 Add lines 27 and 28. Enter total
here and on line 1. .. .. 29
Section D-Depreciation of Vehicles (Use this section only if you owned the vehicle and are completing Section ,C
for the vehicle.) , ' ,
(a) Vehicle 1 (b) Vehicle 2
30 Enter cost or other basis (see
instructions) . . . . . .
31 Enter section 179 deduction
and special allowance (see
instructions) . . . . . .
32 Multiply line 30 by line 14 (see
instructions if you claimed the
section 179 deduction or
special aliowance) . . .. 32
33 Enter depreciation method and
percentage (see instructions) .
34 Multiply line 32 by the percentage
on line 33 (see instructions) . .
35 Add lines 31 and 34 . . . .
36 Enter the applicable limit explained
in the line 36 instructions .
37 Multiply line 36 by the
percentage on line 14
38 Enter the smaller of line 35 or
line 37. Also enter this amount
online28above.... .
. u.s. GPO, :lOO4. 303.552
- ,~~~-~-~ ^ .,= ~">.,-",.-~,
(i) """""'.._....... Fonn 2106(2004)
<> __ H~~ ^.
RE;rURNBY AI-'HIL 15, 200510:
CAPITAL TAX COLLECTIONBUREAU"'"
"
See Page 2 of Instruction Sheets
t\ \n\s pac\<.eLtpf mai\ing add.ress labels Q.!:
see back of return for addresses,
phone numbers, and office hours.
2UU4
LOCAL EARNED INCOME
TAX RETURN (FORM 531)
CONSTITUTE PROOF OF FlUNG, THE TAXPAYER'S COPY MUST
YAUDATEO BY THE BUREAU. TO HAVE YOUR COPY VAUDATED
MAIL, RETURN BOTH THE BUREAU'S AND TAXPAYER'S COPIES
)NG WITH A SELF ADDRESSED STAMPED ENVELqPE.
www.captax.com
W-2 EARNINGS (From attached W-2's)
EMPLOYEE BUSINESS EXPENSES (Attach Federal Form 21"06 &S~te SChedule VE)
TAXABLE W-2 EARNINGS LESS EBE's (Subtract Un" 2 from LIrie1)
OTHER TAXABLE EARNED INCOME (NO INTERESTORDIVIDeNDS) L1STTYPE:
TOTAL TAXABLE EARNED INCOME (Add Lines 3 and 4)
NET PROFIT FROM BUSINESS, PROFESSION, OR FARM, andlor K~l t~65 an of . e
NET LOSS(ES} from business, Profession or Farr'!'l', ~n I r I:1a;~~ a or e che ules
Subtract Line 7 from Une 6 (IF LESS THAN ZERO, ENTER ZERO)
U RED R,IN ATl N PU P S NLY:. nter et. Sub.c_h_aprer_S t!Qloration pass~ hruNet pr 1. S
"OrT our"PA-40retum. . . . ',' ",: - ,'- - - . ,-',':_,-, . J'-~' '.", -~,.,
TOTAL TAXABLE: EARNED INCOME ANpNET'PROFITS (Acid Dnes'g"I(.d 8)
ENTER TAX RATE AS A DECIMAL (from the "TAX RATE TABLE" found on the last page ofthis form packet)
TAX LIABILITY: Multiply Line 10 by Une 11
TOTAL LOCAL INCOME TAXES WITHHELD EXCEPT PHILADELPHIA INCOME TAX (From attached W-2's, Box 19)
QUARTERLY PAYMENTS AND/OR LAST YEAR'S OVERPAYMENT CREDITED TO THIS YEAR
TS FOR TAX I PHIU\ ANDI S TH HAN PA (A A H SCH.) O/GR RE OR ER I ED
RESIDENTS OF THE HARRISBURG KEYSTONE GPPO UIV/TV ZOO KO
TOTAL WITHHOLDINGS & PAYMENTS (Add Lines 13, 14 arid 15),
TAX BALANCE DUE (Subtract Une 16 from Line 12) PAYMENT NOT NECESSARY iF LESS THAN $1,00
,JNTEREST & PENAL TY.(Se~ 1r;lSlruc!iQrysJ ",.,~,,,.,,'.,'".,, """,,,,,,,,,,,~<,,,,,",.,,,",
TOTAL BALANCE: DUE (Add Lines 17 and 18) Make check payable to 'CTCB" Oi,^~~ECK SECUR
OVERPAYMENT (Subtract Une 12 from Line 16) IF LESS 1HAN ZERO, ENTER ZERO
OVERPAYMENT T E REFUNDE
ues ,
" ..,,-..~,j .
ENTER. "TAXPAYER"
"SPousE" OR "BOTH"
CHECK ONE
CHECKING SAVINGS
ROUTING NO.
ACCOUNT NO.
'CT
JSIT
.RMATION
OVERPAYMENT TO BE CRE:DITED TO NEXT YEAR'S TAX
OVERPAYMENT TO BE CREDITED TO SPOUSE'S BALANCE; DUF FOR THI,5 FILING YEAR
IPAUTY ,'_
{TOWN~f:IIP. BOROUGH, OR ClTY)'''~
31 SCUT~ ~ID~Lit~~'l~P
YOUR CTC8 ACCOUNT
NUMBER (IF KNOWN)
SPOUSE'SCTCBACCOUNT
NUMBER (IF KNOWN)
0)
@
35ne.4>~':l)!;'j
YOUR NAME
(LAST, FIRST, 'MI)
, SPOUSE'S NAME
(LAST, ARST, MI) ,
TAX. OFRCE USE ONI-V - UO NOT WRITE IN TMI~ AHt::A.
'" ,- . ~", ..,.,., .,.~. ~'. ~'-v
. ", ,
x
1
2
3
4
5
6
7
8
9'
10
11
12
13
14
15
16
17
18 ,.
19
20
21
78"'
7f'
'".-,'
f.'i'
"
,
,'. .I
,
,
I
.;z sro/s '
, &0
/.; r
</'13
r
'/93
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..
"".:,,-
1,')";'
Ma~R
v
22
23
,1n~~:S if!;rl ~t{) '~'
',...-:
.'-' ~ '~.
1/E YOU MOVED FROM THE
3INNING OF THE TAX FilING _'.
!\R TO PRESENT?
O YES- IFYES,COMP.u:TE$CHEDl,I\..EP. " HOME
.- ~ '.', ,.,,;-, '";:~""'"1'ON'BAC~P&:'BUREAtJ.'S.GOp;'()-f,,'~-'~- ,""- ADDRESS
t NO OF'RETuRN." - -.. ' .
~8 CAHUlJN U;;:
t'~:~tr'r :'S.t:.:~t.. -~~".~.'-' ~-,,-: ~.., " ,-~ ~'-'. P ;t j "'1 Ii: 1 j - ,;: 1. ~.'~
JSE'S SIGNATURE (QNL Y IF ALSO FILING ON THIS FORM)
OATE
YOUR 0 A N
A'((~t.<< (j'Vs."-
SPdUSE'S-OCCUPATIOIi (CNlY IF ALSO FlUNG ON THIS FORM)
PREPARER'S NAME (PLEASE PRINT)
FIRM"S NAME- (OR ENTER "S:E." IF Si::_LE:S'MPLOYEDj
UTAXPAVER'SCOPY
PAID PREPARER'S PHONE NUMB~R
~~$f4t''',l'!#,iiliI.;~iil~;t''''',T..,o.l''";",,",,t.@,O!iI:i;!,it;tj;U;i!iiil1i~;3illl!.i''''",,,,",Ui,,,,,~h'I"',""."";o%,,,l;o /:t~;;,;-',j',,'i"Y1:1i;;~~'~~~ "il1ll1/""'- -.'-'" iIll',~;'I~~f&~-' ....." ."""''''''Ul!!i6i!lllill
,
CAPITAL TAX COLLECTION BUREAU'S MEMBER MUNICIPALITIES AND DIVISION INFORMATION
['he following municipaiities 'are served by the Capital Tax Collection Bureau. Shown below are the municipalities served by our Harrisburg,
:arlisle and Central Dauphin Divisions, Also shown are our Divisions' office hours, phone numbers, and various mailing addresses. OUt
)ivisions' office locations are shown under the column to the right entitled, "If NO Payment or NO Refund/Credit". Mailing address labels
Ire also provided on page 3 of the Instruction Sheets included in this form packet. If they are missing, please address your filing to the
:OITect Division and mailing address as described below. There are 3 distinct addresses for mailing your return(s) based on whether you are
I) making a tax payment with your return, (2) requesting a tax refund or credit on your return, or (3) filing your return with no payment 01
'efund request. If a payment is enclosed with your return use the "PAYMENT ENCLOSED" addressllabel even if your spouse is also filing
m the same retom :and has a refund/credit, or no payment or no refui1d/credit. likewise a REFUND/CREDIT label/address takes precedence
>ver a "No Payment or NO Refund/Credi!" spousal situation. -i
Cdpltal T.IX ctollectlOo BUle(lll - Ccul1sie Dj\IJ)lnn (7171) 2i13-372S OJ 1-877-227-5348 H(~LlIS NIall, S 30dl1l-4pm, Tut: Fn. ~LlIn-4pl1l
:be Carlisle DIVISIOn serves residents of the 0 owing municipalities:
CUMBERLAND COUNTY , FRANKLIN COUNTY
:arlisle Borough L. Mifflin Tnwnship N. Newton Township Shippensbnrg Township Orrstown Boroill!b
~ooke Township Mt Holly Springs Borongh Penn Township Sonthamnton Townshin Sonthamoton Townshin
)ickinson Township Newbnrg Borongh S, Middleton Township U Frankford Township ShippeIisbnrg Borou.h
{ooewell Township Newville Borough S. Newton Township U. Mifflin Township
.. Frankford Township N. Middleton Townsbip Shiooensbnrg Borongh W. Pennsboro Township
~ II
'inal Returns (Form 531) for residents of the municipalities directly above shonld be mailed to appropriate address as shown below:
If PAYMENT Enclosed: If Requesting REFUND/CREDIT: If NO Payment and NO Refund/Credit:
CAPITAL TAX COLLECTION BUREAU CAPITAL TAX COllECTION BUREAU CAPITAL TAX COLLECTION BUREAU
PO BOX 400 PO BOX 698 19 S HANOVER ST STE 102
CARLISLE PA 17013-0400 CARLISLE PA 17013-0698 CARLISLE PA 17013-3336
'h Harrisb D'"
'de
f
e or. IVlSlon serves res!! nts 0 the followmg muniCiPalIties:
DAUPHIN COUNTY PERRY COUNTY JUNIATA COUNTY
farrisburg City I Reed Township All Municioalities Greenwood Townshio
fighspire Borough I Steelton Borough
'lnal Returns (Form 531) for residents of the municipalities directly above should be mailed to appropriate address as shown below:
If PAYMENT Enclosed: If Requesting REFUND/CREDIT: If NO Payment or NO Refund/Credit:
CAPITAL TAX COLLECTION BUREAU CAPITAL TAX COLLECTION BUREAU CAPITAL TAX COLLECTION BUREAU
PO BOX 60547 PO BOX 60689 2301 N 3RD ST
HARRISBURG PA 17106-0547 HARRISBURG PA 17106-0689 HARRISBURG PA17110-1893
I" .CapJtal If8X Cbllectlon BUlC{lU - Central D(wphll1ID1VISJ0I1 (71V) 545-2791 HaUlS l\110n, 8 30am-4pm 'Tue-Fu, 8am-4pm I
lle Ce:mtral Dau'phin'Division serves residents of the fOllowing municipalities:
DAUPHIN COUNTY
lauphin Borough Middle Paxton Townshi Penbrook Boron h West Hanover Townshi
.ower Paxton Townshi~ Paxtan Boroll h Swatara Townshi
'inal Returns (Form 531) for residents of the municipalities directly above should be mailed to approptiate address as shown below:
If PAYMENT Enclosed: If Requesting REFUND/CREDIT: If NO Payment or NO Refund/Credit:
CAPITAL TAX COILECTION BUREAU CAPITAL TAX COILECTION BUREAU CAPITAL TAX COllECTION BUREAU
PO BOX 6477 PO BOX 6626 425 PRINCE ST
HARRISBURG PA 17112-0477 HARRISBURG PA 17112-0626 HARRISBURG PA 17109-1734
LOCAL Ell' (SCHEDULE P) - PARTIAL YEAR RESIDENT PRO-RATION WORKSHEET
,pecial Note: At the VERY MINIMUM you should complete all the applicable shaded sections on the Schedule P. If you have problems completing sections that
"luire calculations, fv,e your total annual figures on the 531 final return and we'll do the pro-ration based on the information you have provided in the shaded
locks, Otherwise, complete all necessary sections (shaded & unshaded) and feel free to give us a call with any questions. An enhanced, self calculating Excel
ersion of the Schedule P is available on our website at www.captax.com.
lS!ructions: Use I Schedule P per taxpayer. Partial year residents must file a return with each tax office of the area you resided in during, the year. Unless the
mployer provided separate W-2 forms for each area of residence, you are required to prorate earnings, net profits, and unreimbnrsed business expenses and tax
'ithholdings based on the number of months (or days) you lived in each area and the number of months (or days) you worked for each employer. You ~nst also
rorate any other taxable income and your business net profit(s)lloss(es), Complete the worksheet to determine your prorated taxable income for each location
[Idlor different tax rate. When calculating your pro-ration percentage (%), be sure to only use like days as found in the rows (W-2 Wages, Other Income. Net
rofit & Net Loss) and the columns (LocationlRate), Number of Months: Cuunt as full month any partial month that you moved into prior to the 16th of the month,
ad any partial month that you moved out of after the 15th of the month. Use this same logic in caiculating months worked for each employer. This rule is
~ne.rally p~rmitted, hm,:ever, if the other tax office you're required to file with does not accept this method, or if tax rates differ in the area you lived, you may be
~Ulred to use a pro~ra.tIon method to the day versus to the month. We will advise you and adjust your return if this is the case.
"~c ~,~, _ '.~~'."'_' ~ <_.__~,_ "."'.,', ..,._"'''' r'__"_' 'C~.'" _,~ _
.
.
~ 1 040 u:s:';dl~id;=iJ;c~:;al;;i.n;;e~:;; ~@04
Label
(See
instructions
on page 16.)
Use the IRS
label.
Otherwise,
please print
or lype.
Presidential
Election C;:ampaign ~. '
(See page 16.) r
Educator. ex'penses (see Page 26), . "_.
Certain business expenses of reservists. performing artists, and .
, fee-basis. govern~ent officials. Attacry Form ,2~ 06 or 2106-;2
25 . IRA deduction (see page"26) .
26 Studet)t loan inter:est deduction (see page 28) .
27 Tuition 'and !ees. de~ucti~n (see page 29) .. .
28 Health. savings account"deduction. Attach Fqr!l1 88.89'.:
29 Moving expenses. Attach Form 3903
30 One-haff of self-employment tax. Attach Schedule SE .
31 Self-employed health insuranc'e deduction (see page 30)
32 Self-employed SEP. SIMPLE. and qualified plans .
33 Penalty on early withdrawal of savings
34a Alimony paid b Recipient's SSN ..
35 Add lines 23 through 34a . ,_
36 Subtract line 35 from line 22. This is your adjusted gross income'
For Disclosure, Privacy Act. and Paperwork Reduction Act Notice, see page 75.
Filing Status
Chec~ only
one box.
Exemptions
If more than four
dependents, see
page 18.
Income
Attach Form{s)
W-2 here. Also
attach Forms
W-2G and
1099-R if tax
was withheld.
If you did not
get a W-2,
see page 19.
Enclose, but do
not attach, any
payment. Also,
pleas_e use
Form 1040-V.
Adjusted
Gross
Income
"
(2)
._...~\ ....,_ :_'<',)".J'" ,'. .
IRS Use On1y---Oa not Writ9 or stap!9 In this -space.
L
A
B
E
L
For Ihe year Jan. 1-Dec. 31. 20_04, or o\her tax year beginning
Your first name and initial Last name
,....
,2004.ending
,20
OMS No_ 1S45~a074 '
Your social security number
.,
...7IJs.k:::t i:?~().5-j
Spouse's social security number;
,
;; ~
~ "Important! ".A.:~
','", ",' """,,"1
You must enter- :" :,.~' :3;
, YOUrS,SN(S) abov,.,e.,".'..,)",'~i,,:~ " '
you....: "_ 'Spouse <~:_ _1:",-
Note. Checking "Yes" will not change your tax or reduce. Y9u'r refund. " '\<"'- '
Do you, or your spouse if filing a joint return, want $3 to go to' this fund? ' ': ....--~ D'Ye~~1~:fN~. Cry~~ 'b:r4ii~-:
1 o single ' . " , ,,' <~4;lQ...He~d of h~~hQiil (with q;.liiYi~iipeiso~). {Se~pagei7J!.~
2 D Married filing jointly (even if only-~ne' had 'income) -- - ,~'~,-'--- the 9UaljfYi~g person' is ~'child bU~ not yciur depehden(eht.iii'
3 0: Marrle~Ufijog sep~teIY, Enter sPo~~e's SSN above. ,,'.- ~:._,- -.-this Child's,name' here. ~ 'I _.N.
and full' name here. .. :'-;: '5- 0' Qualifyi~g wlcio~(er). with'oepimde'nt-childC(See -Page 17).~~;~
- Y~~~self;jf someone' cc;m cl~im -yo~' ~:~ depe~c:r~_ni:~:~~;"O,~t ,~tl:eC~':b?~,'.6~' '..:-<: ~~~ a~ci~ed . I, ~ ~
Spouse. '~-""":~.-..;,~.,,~_"._.' '" No. of children ~. ~
. ~ 3) Oependent's ~on 6c who: ~
'c Dependents: (2) Dependent's I I ' . ,. ed"=
. , reat onshlp to. IV ""'''1 you
(1) First name Last name , .social seturity num~~r --.. - ou ". 'J . _ did not live With ~_ '::::;:WZ~
>h nil: L Z 9 . " ;S-S"'7 S,.' Ii- 1,[ ~u due '0 <f,,",rc."~
J!J "Z. ", or separation.. ~
o [see page 18t. ,- .' ~
'0' ,- Dependents. a'n--6C'~
',n_o~.~ntere~ ab~ ~j
o .:.'", 'J
".~ " ,- ";;' ,,,,,,,'AdQ numbers Ora
-;": ~..,-< '''';;,linesabove ....,:
If a 'joint retum, spouse's first name and initial
Last name
H
E
R
E
Home address (number-and street). If you have a P.O. box. see page 16.
S;-
City, town or post office. state, and ZIP code. If you have a foreign address, see page 16.
\I~ P
Apt. no.
6a
b
d Total number of exem Hons claimed -,
A'_;':_':~"_"
.'~-
7 'Wag~, salaries,. tips, etc. Attach Form(s) W-2
Sa -, Taxable, interest: Attach Schedule B jf ~quired .'
b T3x~exem~ interest :00 not in.clude on line 8a . .,
9a O;'dinary'~ivlden,ds:.~ttaCh Schedule B if ~equir~d .... '.-
b QuaJifie,i'dividends (see page20) ,9b '., ,
10 ,Taxable refunds., credits.. or offsets- of: state, a.nd local !n~~~,_.~e,~ J7e~_ p~g~ 20)
11 Alimony received, , , . ~ "'.;,--:~:' ~<-..._-: .<:".
12 B~siness income or (Ioss).'Attach Schedule C or C-EZ: ,'~'.::->,: _', >'- '> ~ '/'. '..:' ,
.13 Capital gain or (loss). Attach Schedule D. jf.r~quired.'"~.not,r~yi!ec:?, ~.he,ck h~~,~ ~ rr
..14 Othergainsor(losses).AllachForm47g7. " , ,,', ;_...,':,...
.15a IRAdistributioos . .-I15al L-J -bTaxableamount(seepage22r
16a Pensions arid annuities 16a L-J/,b T~~ble'amount (see page 22)~
, , ,- " ' " '"". '..',., " ,,' ,- - ,'- , ~-
17 ~ental real ,estate, royalties. p~ershlps. S corporations. trust~. ~~c. Attach S?he9Ule E,
-18 F~rm ,income or: Ooss). Atta?h Scttedule F . .
19 Unemployment compensation '. ~ .'. ".'~ . ',' P, . . -..-,
20a Social security bl;lnefits, '; 120a I, _ ., 1 "'btaxablea~~un{"{Seepage24)~.
21 Other incom'e:. list'type' and amount (see page 24) "'_'_"_".nU'__",""_~___"__~""'..~
22 Add the amounts in the far right column for lines 7 through 21. This is our total income ..
'23
"
., /,
10
11
12
13
14
15b
16b
17
18
'19
20b
,21
22
"j
~
r
,
23
24
24
25
26
27
28
29
30
31
32
33
34a
~
Cat. No, 113208.
Fonn 1040 (2004)
Exhibit "e"
;~i,,<in,::,~""_~ o,_,!;.:I;":l,,,nhiHilifh!?i,i' ",,-,, ,; ,-"i.o;UHj;j,i3:'i'~;~,"":J""~O":' ,,-c: _, c' -,," ":",<1-,'",
37 AmoLinl from line 3!l (adjusted gross income) . . .. ",j,;,;,.;';,'o'
38a Check { 0 You were born before Janu,ary 2,1940, 0 Blind,'} ,-l',."O",Iii,,1 b.o,' "xe,.""""., ,',.".
if: 0 Spouse was born before January 2, 1940, 0 Blind. checked ~.. 388
If your spouse itemizes on a separate return or you were a dual-status alien, see page 31, Mc#~ti~-8fh.~~;,:i~~~~;'
, : ,_::,,,-:,:-,,, '-,"',':,-,.,:~~"-:-'~,"-'.-':..''''.''':<,,:
Itemized deductions (from Schedule A) or your standard dedudionJs,~i>JEittii1:"'9t~r;:
Subtract line 39 from line 37 , . ,', "'ii, ',ie,,>-;"
If line 37 is $107,025 or le.s, multiply $3,100 by the tolal numberofJJ<e" ',' ""S:CI~i;n'a,
'line 6d., If line 37 is over $107,025, see,' the worksheet on page 33-r~-;:.;~;,~~:~~~N:k"J~~,.~V~;~~;
'_ ,- _ ,,' __ _,_' - -', _::: '_, ,- ,_,>-;"'i:r,:!,~,"'d:~,:;,,.'::~,-;~.;;'
4? 'Taxable income. Subtract line 41 'from line 40. If Iin,e' 41 is more.th~i:r~n~:e)Jq~;~,'_~~t'
43!Tax i.ee page 33). Check.;f any tax is from: a 0 Form(.) 8814 I? q;:~P\~;4~]~~;ii
44 'Alternative minimum tax (see page -35). 'Attach - Form' 62510,. "_: ;'<~~:::-"-;;&f::f~2~;~~~,;;~:~;f;\:~'if;,
45'.", "A' ,d',d"'IInes"43 arJd 4'4 ." " "i'/.';:'
. ','. ., ,-.:- ~' -. -'.- -> .
,46: Foreign la)( ,credit Attach Form 1116 if required,
47 Credil fbr childancl de~nd""l care expense.. AllachFor(!) 2441
48 Creditf~r theelderty orl!'~disOOlediAllachSchedule R.
48 EduCationcrSdits.AttachForm 8863 , " . .. ,.'
50 Reti~ment sa~ings" Ccl~t~~utions credif:A.ttaeh Form, ~880~ '-
51 Child tax credit(see page 37) ..
52 Adopii6ncrediLAttach%rrn8839.' '. ' . ','
53 Credits from: a 0 Form 8396, !inForm 8859.
Me' other credits. ChecKapplicabie OOx(es):' a 0 Form 3800",
" br;J Form 8801 c 0 Specify
55 Add iines 46 through .54. Th~se are your total credits
56 Subtract line 55 from line 45. If line 55 is more than line 45,
57 Self-employment taX-.:Attach,Schedule SE::. . . . ."', .":)~:'~i*~,~~~%.f~f#t:;f~::~~~~:
'__, '" ,.-' , '_ ,:,':';}'>"'.,~',':-7:c,"~\-:;';'.oi"'r;:-_~"-'w,',
58 Socjal ,security .3pd M!Kticare tax on tip income not r~portedto ,emp~,?y~t~~~"~~:~~M'~:tl~-
59 Addttionaitax on IRAs, other qualified retirement plans, elc.Aitil9~'ifoirii:5329,j!",;
60 ,Advance earned income" credit payments frol11_ Form(s}: W-2_' -~_'-
61 Household,employmelillaxes. Attach Schedule H
62 Add lines 56 through 61. This is your tolallax
Payments 63 Federal income tax withheld from FormsW-2 and,1 099
_ _. ~ 64 2004 estimated tax'payments and amount applied from 2003 return
If you have a _65a Eamed income credit (EIC) . . . .: -'._ _-. i .
qUaJifyin~ ' , .... 65b
child, attach b Nontaxable combat pay election, ...
S~~,~.ule EIC. 66 , Excess, social security and lier1, RRTA lax wtthheld (.ee page 54). "aif:
67 Additional child lax credil.,Aiiach Form 8812 . . . .'&7'"
68 Amount paid -with reqiJest-for extension to file (see page 54}.',:, "66:,'
69 Other p'Y/TIents from: ", e OFonn 2439, b 0 form 4136 c 0 form 8885 ',,; .61k
70 Add Iiries 63, 54" 65a, and 66 through 69. These are your totid'l1aYrii~rjiS ',~,'i',;:*;i:;,N'; ';"
Refund 71 If line 70 is more than nne 62,.U , line 62 from line 70. Thi.)s:th~~rI]9~~i~. ,id
Direct deposit? 72a Amount ot line ,71 you. want nded to you -, ~:: ;;~;~~;:t~:,;(~{~:i;:r-.: '?f.--~~~-~~: ,'::~i.
See page 54 ~b Routing number ~ cType:DCheci<ih'9'<Ds.-~~g&;,~1,,'
;~~,:~ Ji~.' ~d Account num~r ' ' , . "i~~~i
73 Amount of line 71 cuwanta Iiedto r2005estimatedlax ~ ','73'. ',' " ' ' ': '" ..'
74_ Amount you owe. Subtract line 70 from line 62. For detail~ on. hQw,:to pay_";~,, pag~:5.5);t_ ,':;,- ~,:;7~~'\
75 Estimated tax penaity (see page 55). .. ,_..,' 75 - ,
Do you want 10 allow another person to discuSs Ihis return wilh the I.AS (s~e pag~56)?2DW~s;CQOlpfetelt!il'fQllpWiri~/O;fjir
~:~nee'~ , ~~~ne ~ ( )' ".,"",., '~=i~~~~~~~;;~..~:;
Un~er penalties of perjury, I declare that I have exa!'lined this return,and acco~panying:_~cJ:1edules: and__~t~. SJid ~ -the b&,rt ,of-,fflY, f<riqwl~ge:~d
belief, they are true, correct, and complete. Declaration of preparer (other than taxpaYer). is: ~',o_1) all in~~n _~,~_hl~h. prepai'eT ,~:ariy !<ndWledge,
.,,-, ,-,--,-,",-" --- ---, --,-- ,--'-'-','--',' -"""..,
Your signature Date Daytime phone number
~ Spouse's s;gnature, It a joint retum, both must sign. Date
~,=:~"b
: for- 39
:, 40.
'" . People who
i checked any 41
~'; box on line
i; 38a or- 38b or
;' who can be
o claimed as a
i!_ dependsnt,
. see page 31.
~ . All others:
{1 Single or
~-;_ Married filing
~i separately,
~ $4.850
;; Married filing
i~ jointly_ or
~~ Qui:llifyilig
~~ widow(er),
\i $9,700
t,; Head of
\-~ househc)ld,
" $7,150
~:~~~'-;049_ (2~04)
Tax and
Credits
Other-
Taxes
Amount
You Owe
Third Party
Designee
Sign
Here
Joint return?
See page 17.
Keep a copy
for your
records.
Paid
Preparer's
Use Olllly
'Jilii~~lilfjjll~iIIi_iilllll~rtl!~i"'.\;l;..J.J'-'illifJ~li!l;r'ilW!r_~lliillmv.-'
~fIi"-"~~~S!
.r.
-'1{
l
!
I
,t
,
:~
~~
~
~.
-'I
~
':1
Preparer's ~
signature ,
Firm's name (or ~
yours if self-employed),
address. and ZIP code
:~i'
Date
Fonn 1040 (2004)'
- -_. ~~"~ ~^" -, ~ . "",.,,,-~~,,-~
I
SCHEDULES A&B
(Form 1040)
Department of the Treasury (P)
Internal Revenue" Service
Name(s) shown on Form 1040
Medical
and 1
Dental 2
Expenses 3
4
Taxes You 5
Paid
(See
page A-2.) 6
7
8
9
Interest 10
You Paid 11
(See
page A-3.)
Note.
Personal 12
interest is
not
deductible, 13
14
Gifts to 15
Charity
If you made a 16
gift and got a
benefit for it. 17
see page A-4. 18
Casualty and
Theil Losses 19
Job Expenses 20
and Most
Other
Miscellaneous
Deductions
21
(See 22
page A-5.)
23
24
25
26
Other 27
Miscellaneous
Deductions
Total 28
Itemized
Deductions
.~ .
_1
.
Schedule A-Itemized Deductions
iSchedule B is on back)
.' "-':""
~ -I
~ ""'ir1
OMB No. 1545-0074
~@04
Attachment
~ Attach to Fonn 1040. ~ See InstruCtions for Schedules A and B (Fonn 1040). Sequence No. 07
Your social security number
~i)S ;:5"7- :'79a.r
Caution. Do not inClude expenses reimbursed or paid by others.
Medical and dental expenses (see page A-2) . . .
Enter amount from Fonn 1040, line 37 2
Multiply line 2 by 7.5% (.075), . . . . . . .. 3
Subtract line 3 from line 1, If line 3 is more than line 1, enter -0- .
State and local (check only one box): I y Ie 4:>
a)g Income taxes, or ,} 5 &" " -3
b Xl General sales taxes (see page A-2)
Real estate taxes (see page A-3), . . .
Personal properly taxes . . . . . .
Other taxes. Ust type and amount ~. _.. __ _ ___... __ __ '"___
Add lines 5 through 8 , . . . . . . . . . . .
Home mortgage interest and points reported to you on Form 1098
Home mortgage interest not reported to you on Fonn 1098. If paid
to the person from whom you bought the home, see page A-4
and show that person's name, identifying no., and address ~
D;!;t
11
Points not reported to you on Form 1098. See page A-4
for special rules, . . . . , . . . , . ., 12
Investment interest. Attach Form 4952 if required. (See
page A-4.). . . . . . . . . . . . . ,. 13
Add lines 10 through 13 . . . . , . . , . . .
Gifts by cash or check. If you made any gift of $250 or
more,seepageA-4.t.!'Jl-itJ(o~~t-. . ...
Other than by cash or check. If any gift of $250 or more,
see page A-4. You must attach Form 8283 if over $500
Carryover from prior year
, Add lines 15 through 17 . . . . . . . . . . .
)~oo
Casualty or theft loss(es). Attach Form 4684. (See page A-5:) .
Unreimbursed employee expenses-job travel, union
dues, job education, etc. Attach Form 2106 or 2106-EZ
if required. (See page A-6.) ~ _...__..__.....______......__
'-I f' 'It
Tax preparation fees. . . . . . . . . . ."
Other expenses-investment, safe deposit box, etc. List
type and amount ~________________________.________...____.
Add lines 20 through 22 . . . . '3' . . . .
Enter amount from Fonn 1040, line 37 24 7 f <' l(
Multiply line 24 by 2% (.02) . . . . . . . .. 25
Subtract line 25 from line 23. If line 25 is more than line 23, enter -0- . .
Other-from list on page A-6. List type and amount ~ .-_......___....._...__....._.
'7S?
--....---...-----------------------------..-------------
Is Form 1040. line 37, over $142,700 (over $71 ,350 if married filing separately)?
D No. Your deduction is not limited. Add the amounts in the far right column }
for lines 4 through 27. Also"enterthis amount on Form 1 040, line 39.' ~
D Yes. Your deduction mey be limited. See page A-6 for the amount to enter. '
For Paperwork Reduction Act Notice, see Form 1040 instructions.
Cat No 12613Z
~~_..
. _.~ " ..:... ;~'"
.~ ;l 00
Schedule A (Fonn 1040) 2004 ,
~!lO:~"ri"".b:,tr.';ic~iii>,ili~,U:h~ "..,--+'1,',:
:,,'.;::,-',\11' m:.J,[!,'.C,,!'HTh:.b' <"','B,"~" ,",' ;>
""";o"-,,,,;,,;,;;.,,,~,.,-;,,,.JH'i'#Ji~mi!f ~"~""""'-""'IIiI_~~~"'rilO!I~';!i~,"~'~I"" ~,'~
....
".~
IliJl.~.~
.
OMB No. 1545-0074
Page 2
Schedules A&B (Form 1 04~) 2'004
Name(s} shown on Form 1040. Do not enter name and social security number if shown on ,other side.
Part
Intere
(Seep"
and the
instruct
Form 1
line 8a.
Note. I
received
1099-INT
1099-0
substitu
stateme
a broke
list the
name a
payer an
the tota
shown
form.
Part
Ordin
Divid
(See pa
and the
instruct
Form 1
line'9a.
Note. If
received
1099-0
substitu
stateme
a broke
list the
name as
payer a
the ordi
dividend
on that
Your social security number
Schedule B-Interest and Ordinary Dividends
Attachment
Sequence No. 08
of If interest is from seller-financed mortgage and the Amount
1 List name payer. any a
I t>uyer used the property as a personal residence, see page B-1 and list this
st interest first. Also, show that buyer's social security number and address ~
ge B-1 ~ ---- - -- ----- - -- - - - - --- - - -- - -- - -- - -- - -- - --- ---- - ---..- - -.. .~~._. .-. .-. .-... -.- -. - -~- -... .--
.- .-.. -... .-.... ._~_.._... .-.. .~........ ----.-. - -_...- -.- - --. -- - -- - - -- -. --- .~- ._~-~.. .-. ..-
ions for __A ._. _. _.. ... .__.... .__._.___ ._. ........_ ..._. - __ - __~
040, .~. .~. h _ __ .._ .~... __ _ __ .~_. ... .......
) -----.-....---------....------.------- ..... - ._~.... ...... ---- -. ... .-. -. - -- -- - ----- - - - -- .-.
..-... .-.. - -.... ..-.-..... ..- -. -- --- - - - - --- -- - - - -- - -.. - --- -.- -- -- -. .~--~- -.. -. -. -- - - - -- --- -
1
...-...-.--..-.-...-------.....-...... .............-...-.----.--..--.--...--.....-""--..-.-.
-<<- - ...-... --. .-<< -....... ._---... -- -.- -... --. --. - - .-.- --- -.- .-- -- - -~- - -- -- --. .--- -- .-- ----
t you .. --- .-.... -.- ... - .--.-. .~.."".. .-.-. -....... ._-. --- -..- - -.... --. - --. -. .---.- ..- .-. - -- --..
a FQrm
Form ..~-_.. - - - - -- ---- --- --. - - - - - -- - -- - -- - --- - - -- - --- - ... -~ - --- --- - - -_.~--~. --.--. -- -.. ..-... -.-
,
10, or . .----.-----.-----------.-------------------------<<---- ------------.-------.-------.--------
te - - -. -... -- -. -. ......."". -- - .~..... ... .-..""."" -. .-.. .-.. .-. .-. .-. -.. -"" -"""".... ..... - -.."".
nt from
rage firm, -- - ----- - -- -<<- - -- - - .-. -. -. --. ..- - -- --. -.- - --_..- --- -. - -.. - -_..- -.-- -.-. .-.- -. ..-_... .-..~..
firm's . .-... ..... -... ... - __A .... _~. _... .~. ____ _~_ - _. - __ - ___. - ____ __ - __. - - - _'_ _._ _____. ___ __ __ _.. .._
s the
d enter ..-----------.--------.-.--........--..-.-.--.....-...-...-..."".-_...._........._......._~-
i interest .""....... - - - --. - -- - - -- - - - - -.- - -- - -~- -.- - - - - ---.. .-... --. - - _.- -...-.-.-..""... ... .-.--.- -- - ~
on that 2 Add the amounts on line 1 2
3 Excludable interest on series EE and I U.S, savings bonds issued after 1989.
Attach Form 8815 3
4 Subtract line 3 from line 2. Enter the result here and on Form 1040, line 8a ~ 4 ,
Note. If line 4 is over $1,500, you must complete Part III. Amount
II 5 List name of payer ~ .~--_.._-----------------.-----. ...._...__...........~..___n.___
.~_ __ ___. - ._. ._...... ..:.~. - ___ - __ - __. - __ - __ - -<<0. _. ._v. _..__. .~..... _~_ ___ _ __ ___ __ _ __ _. _.. __.
ary .,-~--------<<-.-...._-'"_...._.----------------"-_....._.................__._---------.-....-
ends _._______.._._.__....___...____________..._.........~.._..~__.n__.__n____.._..._.._.......
ge B-2 ------._-...-......_----- ---------...-...-.-....-----------.".------------............---.-.
---.---.-.-.-..--.--------- _. _.... _.. ... .~.. __ - _v. ____<<_n________'_._...._.....h..__~..__..
ions for
040. ...-.....~_.._---------_.-....~..--._--------_....._._.--...._.....~...~----._...-..--..---_.
) -....- ._..~.~.. - - - - - --- -. -........ - - - - -- - - - - - --. -. .... ... ..-. ..-... --- --- - -. - -. .'....- ......-
.---.-...-.----------........-.--- n________.._._...._~.....h__~______._....__._...._......
--".-'..' -- - -- - ---- - .-. --.. -.. - -. - -.-- --. -_.-.... - --.. .---... - -- - -.- --- ... -.- .~- .~--.... - --
--.-.......--.---....-....---..<<------.........-.----...-------..........._._--.~_.._-------
you 5
a Form ..-. --- - -- -- -.... ..... --- - - - - -.. -...--. ._~.~~-- .-- --- --... -.... - --- -- - -- -.-. -- ..--_...'. .---
IV or -..-...---- -._.._......._____....._...._..__________........__h_.____.__.___n.__...._.____
te ._______..____._....~.____._......_._..___.____....._.....__.______n_.._..___'.._n_______.
nt from
rage firm, ..-.--------- -.-.....-------- ... ... _~. ._v. __ _ ___ _ _ _ ..... Ow _ _ __. n __~. n _ _ __ _ __.. ._. __ _ _ n _._
firm's ....-.--.......-....-.........-.--------.........----.-----..-............-.-----.-.....----
the _____._.....________...._._____n.____.__......_____........_._._........__.___.......__.___
nd enter
nary _.___.__........._____.._._.__.________._......__n.............__.......___..__.___._.____.
s shown --..-.-.......-------...-.-----.-.........----- __...__._n_._.......______..__......___.... .
form. - -, ....... .~._- _____......n________.....h______....___.____.~.....___.....__...._._.......
... ..- --- -. ---- .....~ .---- - --- ..... ... .-.. -. -..... ..-- - - -.. .--- -- ----... .-- -.-. .--... ---.-..
6 Add the amounts on line 5. Enter the totai here and on Form 1040, line 9a ~ 6
Note. If line 6 is over $1,500, you must complete Part III.
You must complete this part if you (a) had over $1,500 of taxable interest or ordinmy dividends; or (b) had
a foreign account; or (e) received a distribution from, or were a grantor of, or a transferor to, a foreign trust.
7a At any time during 2004, did you have an interest in or a signature or other authority over a financial,
account in a foreign country, such as a bank account, securities account, or other financial account?
See page 8-2 for exceptions and filing requirements for Form TD F 90-22.1.
b If "Yes," enter the name o/the foreign country ~ ......._____.___._..........._______.............,......
8 During 2004, did you receive a distribution from, or were you the grantor of, or transferor to, a
forei n trust? If "Yes," ou ma have to file Form 3520; See a e B-2
For Paperwork Redl,lctiol1 Act Notice. see Form 1040 instructions.
Part IIII
Foreign
Accounts
and Trusts
(See
page B-2.)
(i) Printed on recycled paper
Schedule B (Form 1040) 2004
'u.s. Government Printing Office: 2004 - 303.538
"< _, r",~.~,Y,= _ .'~ _ ..
"" "...~~~~
~_....
~~
'.
'o....~ .,.,,"=.;,.,'~,i'~' ,,~,~-, ~r~~-='''(:-:!;j:--
.
Form
21:06
Employee Business Expenses
OMS No, 1545-0139
.... See separate instructions.
~@04
Deparlment of the Treasury
Internal Revenue Service (2)
Your name
Attachment
Sequence No. 54
Social security number
~OS:5).i qCjoS-
~ Attach to Form 1040.
.J () N e..s ~~p:i~n i~ which D" ~c~": ;~enses
.. Employee Business Expenses and Reimbursements
Step 1 Enter Your Expenses
Column A
Other Than Meals
and Entertainment
Column B
Meals and
Entertainment
'"
1 Vehicle expense from line 22 or line 29, (Rural mail carriers: See
instructions.) . . . . . . . . . . . . . . . . ., 1
2 Parking fees, tolls, and transportation, including train, bus, etc., that
did not involve overnight travel or commuting to and from work.. 2
3 Travel expense while away from home overnight, including lodging,
airplane, car rental, etc. Do not include meals and entertainment. 3
4 Business expenses not 'included on lines 1 through 3. Do not
include meals and entertainment. , . . . . . . . . . .
Sf;;J./
..:.1{ J I
5 Meals and entertainment expenses (see instructions). . . . .
6 Total expenses. In Column A. add lines 1 through 4 arid enter the
result. In Column B, enter the amount from line 5 . . , . .. 6
Note: If you were not reimoursed for any expenses in Step 1, skip line 7 and enter the amount from line 6 on line 8.
Step 2 Enter Reimbursements Received From Your Employer for Expenses Listed in Step 1
7 Enter reimbursements receivecj, from your employer that were not
reported to you.in box 1 of Form W-2. Include any reimbursements
reported under .code "L" in box 12 of your Form Wc2 (see
instr~ctions) ......,...........7
Step 3 Figure Expenses To Deduct on Schedule A (Form 1040)
8 Subtract line 7 from line 6. If zero or less, enter -0-. However, if
line 7 is greater than line 6 in Column A, report the excess as
income on Form 1040, line 7 . . . . . . . , . , .,.
Note: Ifboth columns of line a are zero, you cannot deduct
employee business expenses. {Stop here and attach Form 2106
to your return. "
9 In Column A, enter the amount from line 8, In Column B, multiply
line 8 by 50% (.50). (Employees subjE>ct to Department of
Transportation (D01) hours of service limits: Multiply meal
expenses incurred while away from home on business by 70% (.70)
instead of 50%. For details, see instructions.) . . . . . , .
~/37
5~;l1
), 13 7
;),')1/
10 Add the amounts on line 9 of both columns and' enter the total here, Also. enter the total on
Schedule A {Form 10401. line 20. (Reservists, qualified performing artists, fee-basis state or
local government officials, and individuals with disabilities: See the instructions for speciai rules
on where to enter the tota!.) . . . . . . . . . . , . . . . . . . . . . ~ 10
For Paperwork: Reduction Act Notice, see instructions.
Cat. No. 11700N
(/~Lj8'
Form 2106 r.
~ATh~!lI'_~fi!J~"Wi'l!!;\~" '. :Hi"',jl":t"""''';t~"':;''',''''~:.ic'H~;..>^;'JiL'''',;t,,,iJ'''';_ 'dV"""AJ.'""""M;;!W~g~~P-""""';'.mL_.II~_mrtlMiiiii:~il'r~!ill>1!!~~lli'i' ~ -<
Form 2'1_~6, (2004) -,I
Vehicle exen$~l;
section A-General Jnforniiation (You must complete this section if you
are claiming vehicle expenSel;.)
11 Enter the date the vehicle was placed in service 11 / / / /
12 Total miles the vehicle was driven during 2004 . 12 miles miles
13 Business miles included online 12. . . . . 13 miles miles
14 Percent of business use. Divide line 13 by line 12 . 14 % %
15 Average daily roundtrip commuting distance, , . 15 miles miles
16 Commuting miles included on line 12. . . . . 16 miles miles
17 Other miles. Add lines 13 and 16 and subtract the total from line 12. 17 miles miles"
18 Do you (or your spouse) have another vehicle available for personal use? . 0 Yes 0 No
19 Was your vehicle available for personal use during off-duty hours? 0 Yes 0 No
20 Do you have evidence to suppqrt your deduction? . . . . . , . . 0 Yes 0 No
21 If "Yes," istne evidence written? . . , . . . . . . . . . . . 0 Yes 0 No
Se~iC>n B-Stalldard Mileage Rate (See the instructions for Part II to find out whether to complete this section or
Sectiqn C.)'
22 Multi lyline13 by 37.5<1: (.375)
Section c...,..ADtUlIl ElC ~nSllS
u:
I
A
-
Page 2 .
(a) Vehicle 1
(b) Vehicle 2
23 Gasoline, oil, repairs, vehicle '
insurance, etc.
24a Vehicle rentals. . .
b Inclusion amount (see instructions) .
c Subtractline24bfrornline24a .
25 Value of employer-provided
vehicle (applies only if 100% of
annual iease value was included
(In Form W-2-see instructions)
26 Add lines 23, 24c, and 25. .
27 Multiply line 26 by Ihe
percentage on Une 14
28 Depreciation (see instructions) .
29 I\dd lines 27 and 28. Enter total
here and on line 1. .... 29
Section D-Depreciation of Vehicles (Use this section only if you owned the vehide and are completing Section C
for the vehicle.)
(a) Vehicl 1 (b) Vehicle 2
30 Enter cost or other basis (see
instructions) . , . . . .
31 Enter section 179 deduction
and special allowance (see
instructions) . . . . , .
32 Multiply line 30 by line 14 (see
instructions if you claimed the
section 179 deduction or
special ailowance) . . .. 32
33 Enter depreciation method and
percentage (see instructions) .
34 Multipiy line 32 by ths percentage
on line 33 (see instructions) . .
35 Add lines 31 and 34 . . . .
36 Enter the applicable limit explained
in the line 36 instructions .
37 Multiply line 36 by the
percentage on line 14
38 Enter the smaller 01 line 35 or
line 37, Also enter this amount
online28above..., .
Form 2106 (2004)'
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Personal Property
Air compressor ($450.00)
Salamander ($160.00)
Hand Saw ($15.00)
Screw drivers ($20.00)
Wrench set, cremos ($24.00)
Riding Lawn Mower ($1500.00 new in 2000)
Push mower
Shovel
Rake
Garden tools
Freezer
Stove
Dryer
1979 Snowmobile
19mm Pistol ($300.00)
Drill press
6' wooden ladder
2' wooden ladder
Blue tool chest 4 drawer
Exhibit "E"
, , ~ ,
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PUTNAM
U{VESTMENTS
.
2005 YEAR-TO-DATE STATEMENT
111/2005 3/31/2005
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Client number:
0335519073
ValueofyqurPtlo,am ,,',' '
a,~ollnt.;aSbf3~ft2oq~" '
':$1,875~O~ "
".. - ,'''',.".. ,
GERALD W JONES
38 CARLTON AVE
CARLISLE PA 17013-3114
1...111...111......11..11...11....11...11.1..1..11.1..1.1..1.1
Representative:
MR. TROY H.LANDIS
1-717-24S-9522
Investment firm:
AMERICAN PORTFOLIOS
FINANCIAL
SERVICES INC
For Putnam assistance: 1-800-225-1581
www.putnam.com
Have you made your 2004 IRA contribution? If not, you have until April 15th. If you're thinking about making your 2005 IRA contribution,
remember that th~ limit has incr:~sed to $4,000. ,?r$4.,~~O_~~;.. investors who a~ ~ge 50 and older.
Summary of your Putnam accounts
TRADITIONAL IRA
Fund name
Beginning balance
(as of 111/2005)
Additions
Exchanges
in/out
Withdrawals
E~...nings Total value
2ainlloss (as of 3/31/2005)
Putnam Utilities Growth &
Income Cl-A
--
$1,869,94
$0,00
$0,00
$0.00
$5.08
$1.87~.02
T ota~ year to date
Total this quarter
$1,869.94
$1,869.94
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$5.08
$5.08
$1,875.02
$1 ,875.02
IRA contributi()Os for tax year 2004
IRA contributions for tax year 2005
$0.00
$0.!l0
'P!JTNAMI.)TI~I'nbGP,&IN<::CL'A , ,
'Acco~i1,t ~u!llb~r::A~O:~ -20,s-,sf;9~O~ ;BBB6 .'"
Ac~ounJ' open iI"",,:q3117atiqq ,
Date
0110112005
0313012005
Account activity detail
Be?,:innin.e: Balance
Dividends Reinvested
Price Date: 03121 12005
($ .048000 Per Share)
Ending Balance
Amount
Share
. price
'10.26
10.27
Number
of shares
8.75
0.852
Share
balance
182.255
183,107
Total
value
$1.869.94
03/311200S
10.24
183.107
$1,875.02
111I1111111~1I11~11111111I111I11I1111I1!1I1!1I1111"11111I11I1!1I11II
PAGE I OF3
Exhibit "F"
RLl2044 028 HJ 0056256
4, >
2005 YEAR-TO-DATE STATEMENT
1/1/2005 - 3/31/20C5
.',",'.
HISTORY OF YOUR INVESTMENT IN THIS ACCOUNT
Initial amount + Additional + Exchanges Withdrawals = Net amount + Earnings = Total value of your
invested on investments invested gainlloss account on
0211611994 3/31/2005
$969.67 $0.00 $0.00 $Ii 0.00 $359.67 $1,015.35 $1,375.02
Capital gains and dividends distributed in cash sj~ce initial investment $0.00
FUND INVESTMENT PERFORMANCE
Fund name
Putnam Utilities Gr& fne Cl-A
Fund
inception
dat~_
1111911.990
I year
5 years
annualized
JIIAV
17.13%
pop
I l.03%
NAV
0.52%
,pop
MO.5Z%
I 0 years/life
annuaJize~ _
NAV
8.04%
POP
7..~t6Jb
If "N/A" appears in any box, performance was either not available or not reported at the time this statement was produced. or the fund has
not been in operation long enough for performance to be reported. See reverse for information on performance.
PAGE 20F3
~ ~,,~~-~~ ~
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THE CENTRAL PENNSYLVAl,IA TEk~STERS RETIREMENT INCOME PLAN 1987
MAII.ING ADDRESS: P.O. BOX 15223 STR:>ET ADDlmSS
READING, PA 19612-5223
J_O:i5 SPRING STREET
rY0MISSING, PA 19610
2003 ANNUAL EMPI,OYEE BENE"I~' STATE~"I:,1'.~
.;;'/2084
JONES GERALD I,t
38 CARLTON AVE
CARLISLE PA 17013
1. BIRTH DATE
2. SPOUSE NAME
3. SPOUSE BIRTH DATE
4. SPOUSE SOCIAL SECURITY NO.
5. REPORTED DATE OF HIRE
6. VESTED STATUS
7. ESTIMATED NORMAL RETIREMENT DATE
SOCIAL S5CUt<.I'I'-{
205-52-9905
J.0:03/1%0
I,OH.RIE ANN JONES
0'1/22/1961
~B4-5J-1623
06/02/1994
10,1% VEST'ED
11/01/2017
/
8. ,LATE CONTRIBUTIONS/AD,]TJSl'l\!EN~'S ,'OR PR,.,OR YEARS
$.00
9. ACCOUNT ACTIVIT~
A. ACCOUNT BAlJU~CE AS OF 12/31/2002
B. NET EARNINGS FOR 2003
C. ACCOUNT BAL~ICE AS OF 12/3i/2003
$73;921.01 * INCLUDES #8
13,335.63
$8'1,256.64
10. GROSS ~JALIZED RATE OF RETURN FOR THE TOTAL PLAN FOR 2003
11. NET Al%IUALIZED lCATE OF RETURN FOR THE TOTAL PLAN FOR 2003
(AFTER INvESTMENT AND ADMINISTRATIVE EXPENSES ARE DEDUCTED)
12. NOTE
SINCE NET EARNINGS WERE ACTUALLY CREDITED TO YOUR ACCOUN'r BASED ON QUARTERLY
RATES OF RETU~~, THE NET ANNUALIZED RATE OF RETURN CANNOT BE USED TO VERIFY
THE "NET EARNINGS" AMOUN'r ABOVE. YOUR ACCOUNT BALANCE ABOVE IS SUB':iECT TO
ADDJ1'IONS, DELE~'IONS AND CORRECT:I:ONS.
17.'1 %
1'1.4 %
Exhibit "G"
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GERALD W JONES
38 CARLTON AVE
CARLISLE PA 17013
Tax Deferred Annuity
STATEMENT
Annuitant
GERALD W JONES
Beginning Account Balance 03/28/2004.............,.......,........... $6,621,89
Additional Premium Deposited ................................................... $0.00
Interest Earned ..............,.........................,...,...........,.............. $231.76
Withdrawals ...............................,.... ,. ....... ..... ........ .... ..... ........ ..... $0,00
Ending Account Balance 03/28/2005 ...................................... $6,853.65
Policy Number Policy Date
255145 03/28/1994
Plan Type Plan Name
IRA Alliance PO
,Your Net Cash Surrender Value (account balance less applicable surrender
charges) as of 03/28/2005 is $6,785.11 and as of 03/28/2004 was
$6,489.45. The difference between the Net Cash Surrender Value and the
Ending Account Balance is the surrender charge you would have incurred if
you had surrendered your policy as of 03/28/2005.
3.50% Interest
Rate Guaranteed
To 03/28/2006
American Investors Life Insurance Company, Inc. is a national provider of
retirement annuities. Fixed annuities combine the advantages of tax-
deferral with protection from market risk. Tax-deferral means you pay no
current income taxes on interest earnings in your annuity until you actually
withdraw those earnings. Maximize the earning power of your dollars
through the advantages of tax-deferral!
This statement is for your
personal information and is not
to be filed for income tax
purposes. The accumulated
interest is tax deferred and is not
reportable until withdrawn. All
interest rates are effective annual
rates.
~...
AMERICAN /INvEsTORS
." I.IFE INSlJRANCECOMPANY, INC-
...AMER[}s _
If you have questions, please contact our Home Office at
(888) 266-8489,
555 S. Kansas Avenue, P.O. Box 2039
Topeka. KS 66601-2039
(785) 232-6945 . (785) 295-4495 Fax
Exhibit "R"
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JUN-03-~0~ 1.:08 FROM:NAOA APPRAISAL GUIDE 7145566u"28
/ Vehicle Summary N.A.D.A, Values
I
l'
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NADA MASTER ACCOUNT
8400 Westpark Drive
McLean VA 22102
703-821-4609
613/2005
TO: 17172491437 P.2/2
Page 1 of!
Region: Eastern March, 2001 Slock #:
V chicle Description: 1994 FORD TRUCK VIN:
EXPLORER-V6
WGN 4D 4WD
MSRP: $19,900 Weight: 4.053
Mileage: 28,000
&tlill Ira,de-Jn Lam
Base Value $8.975 $7,000 $6,300
OptiooalEquipmeot
XLTTrim $325 $325 $325
Option Total $325 $325 $325
MileaRe Adjustment $1,675 $1,675 $1,675
Total N.A.D.A. Official Used Car Guide $10,975 $9,000 $8.300
Values
^" NAnA values Qfcrcpnnl!;ll with l'Iemlis5ionaf
N.A.D.A. ODil:iul lfS\lJ eM Guide'" Company Cup)'rie,blltl NADASC 1000
http://www.nada.eom/h2bNVtusedCar/reportslnadaval.htm
6/3/2005
Exhibit "I"
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Minimum Payment $
Customer's Signature.
Social Security No::J n ') - ~) :l-"IGI .'j";
Maximum Balance $
"
Date
Amount
Purchased
Date
Amount
Purchased
Dealer's
Initials.
Balanc:e
Deeler's
Initials
Paid
Balance
Paid
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FAILURE TO COMPLY WITH THE ABOVE TERMS WILL RESULT IN CANCELLATION
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Social Security
Maximum Balance $
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Purchased Date Paid Balance
I Purchased Initials
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LORRIE A. JONES,
Petitioner
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001-1579 CIVIL TERM
GERALD W. JONES,
Respondent
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under ~ 3301 (c) of the Divorce Code was filed March 19,
2001.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final Decree in Divorce after service of notice of intention to
request entry of the Decree.
I verify that the statements made in this Affidavit are true and correct to the best of my
knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities.
Date: Od ~ ()5 L~l{!!i!- a .y/lUL)
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER~ 3301 ecl OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a Divorce Decree is entered by the Court
and that a copy of the Decree will be sent to me immediately after it is filed with the
Prothonotary ,
I verify that the statements made in this Affidavit are true and correct to the best of my
knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities.
Date: Od~ OS- UfllUO Q,~
Lorrie A. Jones
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LORRIE A. JONES,
Petitioner
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001-1579 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
GERALD W. JONES,
Respondent
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under ~ 3301 (c) of the Divorce Code was filed March 19,
2001.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final Decree in Divorce after service of notice of intention to
request entry of the Decree.
I verify that the statements made in this Affidavit are true and correct to the best of my
knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities.
c~~
Gerald W. Jones
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER!i 3301 lel OF THE DIVORCE CODE
Date: _lOt.{ 0 S
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a Divorce Decree is entered by the Court
and that a copy of the Decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this Affidavit are true and correct to the best of my
knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S, 4904 relating to unsworn falsification to authorities.
6..-.-.._--<-~ .
Gerald W. Jones
Date: t 0
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
LORRIE ANN JONES
No.
01-1579
VERSUS
GERALD WADE JONES
DECREE IN
DIVORCE
AND NOW,
p~ '70.
LORRIE ANN JONES
, ?-ooS, IT IS ORDERED AND
DECREED THAT
, PLAI NT! FF,
AND
GERALD WADE JONES
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
The terms of agreement reached by the parties before the Divorce Master and reduced to
writing on October 4, 2005 are incorporated, but not merged, into this Decree in Divorce
By THE COURT:
J.
ROTHONOTARY
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ATI'ORNEYS-AT.LAW
26 W. High Street
Carlisle. P A
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LORRIE A. JONES,
Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001-1579 CIVIL TERM
v.
GERALD W. JONES,
Respondent
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Kindly transrnit the record, together with the following information, to the Court
for entry of a Decree in Divorce:
1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c) of
the Divorce Code.
2. Date and manner of service of the Complaint: Defendant accepted
service of the Complaint on March 20, 2001, via certified mail, restricted delivery,
Proof of service was filed with the Court on March 27, 2001.
3. Date Affidavit of Consent required under Section 3301 (c) of the Divorce
Code was filed with the Prothonotary:
By Plaintiff: October 5, 2005
By Defendant: October 5, 2005
4. Related claims pending: The terms of agreernent reached by the parties
before the Divorce Master and reduced to writing on October 4, 2005 are
incorporated, but not merged, into the Decree in Divorce,
5. Date Waiver of Notice under Section 3301 (c) of the Divorce Code was
filed with the Prothonotary:
By Plaintiff: October 5, 2005
By Defendant: October 5, 2005
, Esquire
SAIDIS, SHU ,FLOWER & LINDSAY
26 West High Street
Carlisle, PA 17013
(717) 243-6222
Dated: ///~/()S-
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SHUFF, FLOWER
& LINDSAY
A'ITORNEVS-AT.LAW
26 W. High Street
Carlisle, P A
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CERTIFICATE OF SERVICE
I hereby certify that on this 2""Z-day of 05, a true and
correct copy of the foregoing document was serv upon the party listed below, via
First Class Mail, postage prepaid, addressed as follows:
Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle, PA 17013
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LORRIE A JONES,
Plaintiff
vs.
GERALD W. JONES,
Defendant
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01 - 1579 CIVIL
IN DIVORCE
ORDER OF COURT
AND NOW, this
!S'Y"\-
day of
~U.All )
2005, the parties and counsel having entered into an agreement
and stipulation resolving the economic issues on October 4,
2005, 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.
cc: Carol J. Lindsay
Attorney for Plaintiff
Karl E. Rominger
Attorney for Defendant
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BY THE COURT,
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LORRIE A. JONES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 01 - 1579 CIVIL
GERALD W. JONES,
Defendant
IN DIVORCE
THE MASTER:
Today is Tuesday, October 4,
2005. This is the date set for a hearing in the above
captioned divorce proceedings. Present in the hearing room
are the Plaintiff, Lorrie A. Jones, and her counsel Carol J.
Lindsay, and the Defendant, Gerald W. Jones, and his counsel
Karl E. Rominger.
The parties were married on July 5, 1982, and
separated March 31, 2001. The parties are the natural
parents of two children, both of whom are still minors. The
older child lives with the father and the younger child
lives with the mother.
The divorce complaint was filed on March 19,
2001, raising grounds for divorce of irretrievable breakdown
of the marriage. The Master has been provided affidavits of
consent and waivers of notice of intention to request entry
of divorce decree signed and dated today by both parties.
The affidavits and waivers will be filed with the
Prothonotary's office by the Master's office so that the
divorce can conclude under Section 3301{c) of the Domestic
Relations Code.
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An amended complaint in divorce was filed an
September 23, 2004, raising claims on behalf of wife of
equitable distribution, alimony, and counsel fees and costs.
The Master has been advised that after
considerable negotiations in this case, the parties have
reached an agreement with respect to all of the outstanding
economic issues. The 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. The parties and
counsel are going to return later today to review the
transcribed agreement and make typographical corrections as
necessary. They will then be asked to sign the agreement
affirming the terms of settlement as stated on the record.
However, it is specifically noted that when the parties
leave the hearing room today they are bound by the
substantive terms of the agreement even though there is no
subsequent signing of the agreement by the parties affirming
the settlement.
Upon receipt by the Master of the completed
agreement, the Master will prepare an order vacating his
appointment and counsel can then file a praecipe
transmitting the record to the Court requesting a final
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decree in divorce. Mr. Rominger.
MR. ROMINGER:
1. Husband agrees to make a direct cash payment to wife in
the amount of $55,000.00 within 45 days of today's date.
2. Husband agrees to prepare a QDRO to provide wife with
$55,000.00 of his Teamster's pension within two weeks of
today's date.
3. Husband agrees to convey all of his interest in two
IRAs now in his possession and listed on the property
statement of Plaintiff, being an American Investors IRA and
a Putnam IRA and will complete all documents necessary to
make the transfer or prepare any Court order if either would
require within two weeks of today's date.
Mr. Jones warrants that he has not removed any monies
from the American Investors IRA since March 28, 2005, when
it had a value of $6,853.65. Nor has he removed any monies
from the Putnam IRA since March 31, 2005, when it had a
value of $1,875.02. Wife will be receiving these two IRAs
reduced in value or increased in value only by market
conditions.
4. Husband shall agree to the entry of an alimony order in
the amount of $825.00 per month to be administered or
attached to the Domestic Relations Office of this county.
This is an indefinite alimony order and subject to
modification upon a change of circumstances and termination
upon the death of either party, cohabitation by wife with a
member of the opposite sex or remarriage of wife.
The alimony shall be effective October 1, 2005;
wife will advise the office of Domestic Relations that her
spousal support shall terminate on the same date and if any
over collection is made, it will be credited appropriately.
5. It is the intent of the parties that each party will
keep all tangible personal property now in their possession
and all vehicles now in their possession, and remain
responsible for all debts now in their name. Additionally,
at the time of the payment of the $55,000.00 lump sum to
wife, husband will refinance and remove wife from any
obligation to the marital residence.
6. Wife shall execute a deed at the time of the refinance
and receipt of the lump sum payment transferring her
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interest solely to husband. The deed will be prepared by
husband's counsel.
7. Except as specified above, both parties waive any and
all claims they may have as to any retirement or other
accounts held by the other for any purpose.
8. The parties expressly waive any further claims for
counsel fees or costs which they may have as against the
other.
9. Wife will retain the 1994 Ford Explorer and husband
will retain the 2000 Chevy pick-up, the 1972 Chevy pick-up,
and the 2001 Triumph motorcycle. Similarly, wife will
retain the two bank accounts which were in her individual
name at Waypoint and the $25.87 remaining in the Member's
1st Federal Union account as of the time of separation and
husband will retain his Waypoint account.
10. 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.
MS. LINDSAY, Lorrie Jones, did you hear the
agreement as it was dictated by Mr. Rominger and by me?
MS. JONES: Yes.
MS. LINDSAY: And did you understand it?
MS. JONES: Pretty much so except for some of
that stuff at the end. r understood.
MS. LINDSAY: Okay. Let me explain what that
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stuff at the end is about. That is some magic language
that's in there so that if you didn't get divorced between
now and -- if somebody died, one of you died, between now
and the date you were divorced, you might have a claim on
the estate of the other. What this is doing is waiving any
claims you have on the estate of the other for that period
of time. Once you are divorced you don't have a claim --
MS. JONES: Okay.
MS. LINDSAY: Do you have any questions in
addition about what I just said and Mr. Rominger just
dictated?
MS. JONES: No.
MS. LINDSAY: And are you in agreement that
the agreement as dictated is the agreement you want to make?
MS. JONES: Yes.
MR. ROMINGER: Gerald, have you heard the
agreement as dictated into the record?
MR. JONES: Yes.
MR. ROMINGER: And are you in agreement with
the contents of it?
MR. JONES: Yes.
MR. ROMINGER: Do you understand it?
MR. JONES: Yes.
MR. ROMINGER: Do you agree fully and
faithfully execute it?
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MR. JONES: Yes.
(Whereupon, a discussion was held off the
record. )
MS. LINDSAY: In the event, that one party to
this agreement fails or refuses to abide by a term or to
comply with a term hereof, and the other party seeks Court
intervention in order to enforce the agreement, the party
who has breached the agreement shall be responsible for the
attorney fees and costs of the other party expended to
enforce the agreement.
MR. ROMINGER: The only caveat would be
force'majeure and impossibility of paying as defenses.
MS. LINDSAY: If one of you do not adhere to
your deal here and the other guy has to go to Court to
enforce the attorney fees and costs, Karl's addition was
something like Hurricane Katrina comes along and it cannot
be done.
(Whereupon, a discussion was held off the
record. )
MS. LINDSAY: It is understood that
impossibility shall not be a defense to the payment of
$55,000.00 as set out in this agreement by husband to wife.
THE MASTER: You understand what they just
talked about?
MR. JONES: Yeah.
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MS. JONES: Okay.
MR. ROMINGER: Mr. Jones, are you satisfied
with your representation? Do you believe that you have been
adequately advised entering into this agreement?
MR. JONES: Yes.
MS. LINDSAY: The same question?
MS. JONES: Yes, definitely.
I acknowledge that I have read the above
stipulation and agreement, that I understand the terms of
settlement as set forth herein, and that by signing below I
ratify and affirm the agreement previously made and intend
to bind myself to the settlement as a contract obligating
myself to the terms of settlement and subjecting myself to
the methods and procedures of enforcement which may be
imposed by law and in particular Section 3105 of the
Domestic Relations Code.
WITNESS:
DATE:
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'Lorrie A. one
J
/Karl E. Rominger
Attorney for Defendant
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Gerald W. Jones
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In the Court of Common Pleas of
CUMBERLAND
County, Pennsylvania
DOMESI1C RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Phone: (717) 24Q.6225
Fax: (717) 240-6248
Defendant Name: GERALD W. JONES
Member ID Number: 2301100755
Please note: AU correspondeuce must inelude the Member ill Number.
MODIFIED ORDER OF ATIACHMENT OF UNEMPLOYMENT BENEFITS
Plaintiff Name
LORRIE A. JONES
LORRIE A. JONES
Financial Break Down of Multinle Casl'S on Attachment
PACSES Docket
Case Number Number
394107723 01-1579 CIVIL
850103327 00270 S 2001
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Attachment AmountlFreauencv
B25.00 !.MONTH
637. 00 ~MONTH
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TOTAL ATfACHMENT AMOUNT: $
1,462.00
Now, by Order of this Court, the Department of Labor and Industry, Bureau of Unemployment
Compensation Benefits and Allowances (BUCBA), is hereby directed to attach the lesser of $ 337 .38
per week, or 50. 0 %, of the Unemployment Compensation benefits otherwise payable to the Defendant,
GERALD W. JONES Social Security Nwnber 205-52-9905 , Member
ID Number 2301100755 . BUCBA is ordered 10 remit the amount attached to the Department of Public
Welfare (DPW). DPW shall forward the amount received from BUCBA to the Domestic Relations Section of this
Conn for support and/or support arrearages.
If the Defendant's Unemployment Compensation benefits are attached by another Court or Courts for
support and/or support arrearage, DPW may reduce the amount attached under this Order so that the total amount
attached does not exceed the maximwn amount subject to garnishment pursuant to 15 U.S.C. ~ 1673(b)(2) and 23
Pa. C.S. ~ 4348(g).
This Order shall be effective upon receipt of the notice of the Order by the BUCBA and shall remain in
effect until the Defendant's entitlement to Unemployment Compensation benefits, under the Application for
Benefits dated FEBRUARY 15, 2004 is exhausted, expired or deferred.
BUCBA shall comply with this Order, unless it is amended or vacated by subsequent Order of this Court.
All questions, challenges or obligations to this Order shall be directed to the Domestic Relations Section of this
Court.
BY THE COURT
Date of Order:
OCT 1 1 2005
_in~:
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JUDGE
DID: R. J. Shadday
Service Type M
Form EN-034
Worker ID $IATT
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LORRIE ANN JONES,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CIVIL ACTION - LAW
vs.
: NO. 01 _JS7? CIVIL TERM
GERALD WADE JONES,
Defendant
: IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following pages, you must take prompt action. You are warned that if you fail to do so, the case may
proceed without you and a decree of divorce or annulment may be entered against you by the Court. A
judgment may also be entered against you for any other claim or relief requested in these papers by the
Plaintiff. You may lose money or property or other rights important to you, including custody or visitation
of your children.
When the grounds for divorce is indignities or irretrievable breakdown of the marriage, you may
request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the
Cwnberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU
MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator - Fourth Floor
Cwnberland County Courthouse
Carlisle, Pennsylvania 17013
Telephone (717) 240-6200
The Court of Common Pleas of Cwnberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our office.
All arrangements must be made at least 72 hours prior to any hearing or business before the court. You
must attend the scheduled conference or hearing.
James J. Kayer, Esquire
Attorney for Plaintiff
4 East Liberty Avenue
Carlisle, P A 17013
(717) 243-7922
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LORRIE ANN JONES,
Plaintiff
vs.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO, 01 - /571 CIVIL TERM
GERAW WADE JONES,
Defendant
: IN DIVORCE
COMPLAINT IN DIVORCE
UNDER SECTION 3301(c) and 3301(d) OF THE DIVORCE CODE
COMES NOW, Plaintiff LORRIE ANN JONES, through her attorney, James J. Kayer, Esquire and
avers as follows;
COUNT I - DIVORCE
1. Plaintiff is Lorrie Ann Jones, an adult individual, whose current address is 88 Pinedale Road,
Carlisle, Cumberland County, Pennsylvania, 170 \3.
2. Defendant is Gerald Wade Jones, an adult individual, whose current home of record is 38 carlton
Avenue, Carlisle, Cumberland County, Pennsylvania, 17013.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six
months immediately previous to the filing of this Complaint.
4, The Plaintiff and Defendant were married on July 5, 1982 in Cumberland County, P A.
5. There have been no prior actions of divorce filed in this matter.
6. Plaintiff and Defendant are not members of the United States Armed Forces,
7, The marriage is irretrievably broken, and the parties are proceeding under Section 330l(c) and
Section 3301(d) of the Divorce Code.
8. 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.
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WHEREFORE, Plaintiff requests the court to enter a decree of divorce.
Respectfully submitted,
Date: ) / /'1/0 I
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VERIFICATION OF PLEADINGS
The foregoing document is based upon infonnation which has been gathered by my cOLU1Sel
and myself in the preparation of this action. The language of the document may, in part, be the
language of my COlUlsel and not my 0\\11. I have read the statements made in this document and to
the cxtent that it is based upon information which I have given to my counsel, it is true and correct
to the best of my knowledge, information and belief. To the extent that the contents of the
statemcnts are that of counsel, I have relied upon counsel in making this Verification. I understand
that false statements herein are made subject to the penalties of 18 PA. C.S. 84904, relating to
unsworn falsification to authorities.
Date: 0/1 (p / () I
! 01.11 lL () q (JY{J/)
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LORRIE ANN JONES,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CNIL ACTION - LAW
vs.
: NO. 01 - 1579
CIVIL TERM
GERALD WADE JONES,
Defendant
: IN DIVORCE
AFFIDAVIT OF SERVICE BY MAIL
PURSUANT 1'0 Pa. R.C.P. 1920.4(a)(1)0i)
COMMONWEALTH OF PENNSYL VANIA
: SS.
COUNTY OF CUMBERLAND
I, James 1. Kayer, Esquire, being duly sworn according to law, deposes and says that he
is the attorney for plaintiff, Lorrie Ann Jones, and that he did serve a true and correct copy of the
Complaint in Divorce that was filed in the above matter, by U.S. Mail, postage prepaid, certified
with restricted delivery, return receipt requested, unto the Defendant Gerald Wade Jones, on
March 20, 2001. The receipt form is attached hereto.
re me is 21st day of March 2001
NOTARIAL SEAL
Vickie J. GroUP, Notary Public
Borough of Carllsla, County of Cumberland
My Commission Expires Aug. 30, 2004
, -j.<C~mplete-items < 2, and 3. Also complete
~ item 4 if Restricted Delivery is desired. .
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mailpiece, X
or on the front if space permits.
1. Article Addressed to:
~ W.~ct$.s
38Cb~l-mt0 ~Ul2.
t~USL.P-- PA- nOl ~
3. Service Type
~ed Mail 0 Express Mail
rJ Registered ~ Receipt for Merchal1dise
o Insured Mail 0 C.O.D.
4. Restricted Delivery? (Extra Fee) a. ,.....'"
2. Article Number (Copy from service label)
.:"7... 1.4~7~,7_ '"-II#{
If.~ F,orm 3B;l1".-.!uly 1999 _ Domestic Return Receipt
102595-99~'1789
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LORRIE A. JONES,
Petitioner
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001-1579 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
GERALD W. JONES,
Respondent
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under ~ 3301 (c) of the Divorce Code was filed March 19,
2001.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final Decree in Divorce after service of notice of intention to
request entry of the Decree.
I verify that the statements made in this Affidavit are true and correct to the best of my
knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities.
Date:_IO J..{ OS C~~
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WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER!i 3301 Ie} OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a Divorce Decree is entered by the Court
and that a copy of the Decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this Affidavit are true and correct to the best of my
knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities.
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LORRIE A. JONES,
Petitioner
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001-1579 CIVIL TERM
GERALD W. JONES,
Respondent
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under ~ 3301 (cl of the Divorce Code was filed March 19,
2001.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final Decree in Divorce after service of notice of intention to
request entry of the Decree.
I verify that the statements made in this Affidavit are true and correct to the best of my
knowledge. information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities.
Date: Oct. ~ OS J... (J(;'l<-L (] ,(btLW
Lorrie A. Jones I
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDERli 3301 tel OF THE DiVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a Divorce Decree is entered by the Court
and that a copy of the Decree will be sent to me immediately after it is filed with the
Prothonotary.
,,,,,"--.~,' .
I verify that the statements made in this Affidavit are true and correct to the best of my
knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities.
Q.>~
Date: od ~ O~
Left III {;
Lorrie A. Jones
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LORRIE ANN JONES,
Plaintiff
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GERALD WADE JONES,
Defendant
TO THE PROTHONOTARY:
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: IN THE COURT OF COMMON PLEAS OF
: CIVIL ACTION - LAW
: NO. 01 - 1579 CIVIL TERM
: IN DIVORCE
PRAECIPE
Please withdraw my appearance as counsel of rec
Date: b 12/1101
Please enter my appearance as counsel of record for the ab
Date: 8 - "'-0 {
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hereby certify that
I served a true and correct
copy of the
foregoing Praecipe upon all parties of record via United States
Mail, postage prepaid, addressed as follows:
Philip Spare, Esquire
44 West Main Street
Mechanicsburg, PA 17055
SAIDIS, SHUFF, FLOWER & LINDSAY
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SHUFF, FLOWER
& LINDSAY
ATIORNEYS-AT.LAW
26 W, High Street
Carlisle. P A
Lorrie A. Jones,
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Petitioner
v.
No. 2001-1579 Civil Term
Gerald W. Jones,
Civil Action - Law
In Divorce
Respondent
PETITION FOR SPECIAL RELIEF
AND NOW, comes Lorrie A. Jones, by and through her counsel, Said is, Shuff,
Flower & Lindsay and petitions this Honorable Court as follows:
1. The parties hereto are husband and wife having been joined in
marriage on July 5, 1982 and having separated on or about March 15, 2001.
2. The parties are owners of a home at 38 Carlton Avenue, Carlisle,
Cumberland County, Pennsylvania.
3. At the time of their separation Petitioner left the marital home with the
parties two children and Respondent has resided in the marital home ever since.
4. The marital home has been appraised and has a value of approximately
$80,000. It is encumbered by a first mortgage with a payoff of approximately
$8,300.00 and a second mortgage with a payoff of approximately $25,500.00. The
second mortgage was used to finance a car driven by Respondent.
5. Since the parties' separation and through June, 2003, Respondent has
been making the first and second mortgage payments on the marital home.
6. Respondent has not made the payments on the marital home for July,
August and September. In order to try to protect her credit rating, Petitioner has
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made those payments.
II
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SAlOIS
SHUFF, FLOWER
& LINDSAY
ATIORNEYS-AT.LAW
26 w. High Street
Carlisle. PA
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7. Some time in the summer of 2003 Respondent also removed from the
marital home, upon information and belief, with his girlfriend.
8. The marital home is a significant marital asset.
9. Petitioner is a kitchen worker at Carlisle Hospital and is unable to
maintain payments both for the mortgages on the marital home and her own
apartment.
10. On September 4, 2003, the undersigned transmitted to attorney for
Respondent a listing Agreement so that the house could be sold. To date, there has
been no response to the request to put the marital home on the market.
11. Petitioner will be substantially harmed if the marital property is lost in
foreclosure.
WHEREFORE, Petitioner prays this Honorable Court to issue a Rule upon
Respondent to show cause why he should not sign the Listing Agreement presented
to him on September 4, 2003 and proceed to an Agreement to sell the property to a
qualified buyer.
SAlOIS, SHUFF, FLOWER & LINDSAY
Attorneys forplaintiff
By:
SAlOIS
SHUFF, FLOWER
& LINDSAY
A1TORNEYS'AT'LAW
26 W, High Street
Carlisle. P A
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VERIFICATION
I verify that the statements made in this Petition for Special Relief are true and correct.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section
4904, relating to unsworn falsification to authorities.
Dated:
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Lorrie A. Jones, Petiti ner
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Lorrie A. Jones,
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Plaintiff
v.
No. 2001-1579 Civil Term
Gerald W. Jones,
Civil Action - Law
In Divorce
Defendant
CERTIFICATE OF SERVICE
AND now, this /' q day Of~ vuJ9~-
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2003, I, Carol J. Lindsay, Esquire, of the law firm of S IS, SHUFF, FLOWER &
LINDSAY, Attorneys, hereby certify that I served the within Petition for Special Relief
this day by depositing same in the United States Mail, First Class, Postage Prepaid, in
Carlisle, Pennsylvania, addressed to:
Karl E. Rominger, Esquire
ROMINGER & BAYLEY
155 S. Hanover Street
Carlisle PA 17013
By:
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LORRIE ANN JONES,
Petitioner
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-1579 CIVIL TERM
CIVIL ACTION - LAW
GERALD WADE JONES,
Respondent
IN DIVORCE
IN RE: PETITION FOR SPECIAL RELIEF
ORDER OF COURT
AND NOW, this 6th day of October, 2003, in
accordance with the agreement of the parties as announced in open
court and in their presence, it is directed that the Respondent
attempt to refinance the marital home so that the debt thereon
would be in his name alone.
If he is unable to do so, and in
the meantime, irrespective of the matter of refinancing, the
Respondent agrees to pay both of the existing obligations on the
real estate, one a mortgage and one a line of credit, on or
before the day each is due. In the event the Respondent should
be in default of either payment for a period of more than 5 days,
it is directed that he enter into a listing agreement for the
sale of the property.
By the Court,
. A i-
A. Hess, J.
~ndSay Gingrich Maclay, Esquire
2109 Market Street
Camp Hill, PA 17011 ,
For the Plaintiff /
~arl Rominger, Esquire
, 155 South Hanover Street
~arlisle, PA 17013
For the Defendant
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26 W, High Street
Carlisle, P A
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SEP 2 4 2003
Lorrie A. Jones,
: In the Court of Common Pleas of
: Cumberland COljnty, Pennsylvania
Petitioner
v.
: No. 2001-1579 Civil Term
Gerald W. Jones,
: Civil Action ~ Law
: In Divorce
Respondent
ORDER OF COURT
AND NOW, this .;2$f-A day of Jo..nJ:i/Jrl..A e ;'z) , 2003 upon
, f
consideration of the within Petition, a Rule is issued on Respondent to show
cause why the relief requested should not be granted.
Rule returnable at a hearing set for the ,,--t!J day of {(kt~ 1'/1 ~
at the Courthouse at Carlisle, Pennsylvania at II; f 5 o'clock <a....m. J..Yl
C/C- 11-1 ,
BY THE COURT
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LORRIE ANN JONES,
Petitioner
CIVIL ACTION - LAW
v.
No. 2001 -1579 (Civil Term)
GERALD WADE JONES,
Respondent
(In Divorce)
IN RE: PETITION FOR SPECIAL RELIEF
AGREEMENT AND STIPULATION OF COUNSEL
THIS AGREEMENT and STIPULATION OF COUNSEL is entered into this /l'/i
day of October, 2003, by and between Lindsay Gingrich Maclay, Esquire, counsel for
Lorrie Ann Jones (hereinafter referred to as "Petitioner"), and Karl E. Rominger, Esquire,
counsel for Gerald Wade Jones, (hereinafterreferred to as "Respondent").
NOW THIS AGREEMENT WITNESSETH THAT:
WHEREAS, the parties jointly hold title to a home, more specifically described as
38 Carlton Avenue, Carlilsle, Peunsylvania (hereinafter referred to as the "Marital Home"),
which is currently encumbered by a jointly-held first mortgage and a jointly-held second
mortgage, in the form of an open line of credit which is secured by the Marital Home;
WHEREAS, the parties are in the process of Divorce proceedings docketed at the
above-referenced term and number;
WHEREAS, Petitioner has obtained alternative housing for herself and her children
and has been residing in this alternative housing for a period of over two (2) years;
WHEREAS, Respondent, had for a period of time, lived in the Marital Home but
subsequently had vacated same;
WHEREAS, Petitioner, for a number of months, was making the monthly mortgage
payments on both mortgages on the Marital Home;
.
SAlOIS
SHUFF, FLOWER
& LINDSAY
ATTORNEYS-AT-LAW
26 W. High Street
Carlisle. PA
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WHEREAS, Petitioner could no longer afford to make the monthly mortgage
payments;
WHEREAS, Petitioner filed a Petition for Special Relief with this Court, at the
above-referenced term and number, asking to force Respondent to sign an Agreement of
Sale for the Marital Home;
WHEREAS, prior to the scheduled Hearing on this matter, counsel for Petitioner
and Counsel for Respondent were able to reach an agreement with regard to this matter;
WHEREAS, said Order was dictated on the record and was subsequently entered on
October 6, 2003 (a copy ofthe October 6, 2003 Order is attached hereto as Exhibit "A" and
incorporated as if fully set forth herein);
WHEREAS, counsel in this matter wish to clarifY the agreement reached prior to the
October 6, 2003 Hearing in this matter;
NOW, THEREFORE, counsel for Petitioner and Respondent hereby clarify the
terms of the October 6, 2003 Order and agree as follows:
1. Except as otherwise provided herein, this Stipulation and Agreement will be
read in conjunction with the October 6, 2003 Order issued by the Honorable Kevin A. Hess;
and
2. If and when Respondent is able to refmance the Marital Home into his name
only, he will refinance enough of the equity to payoff Petitioner's interest in the marital
estate, which proceeds will be held in escrow until such time as a final resolution is reached
with regard to equitable distribution; and
3. Respondent specifically agrees to pay the first mortgage on or before the 1 ,t
of every month, the date said payment is due; and
II
.
SAlOIS
SHUFF, FLOWER
& LINDSAY
ATIORNEVS1ATlLAW
26 w. High Street
Carlisle. P A
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4. Respondent specifically agrees to pay the second mortgage on or before the
19th of every month, the date said payment is due; and
5. The last line of the October 6th Order, which reads "[i]n the event the
Respondent should be in default of either payment for a period of more than 5 days, it is
directed that he enter into a listing agreement for the sale of property" is superseded by the
following: "[i]n the event the Respondent should fail to pay either mortgage on its
respective due date, it is directed that, within five (5) days of a request by Petitioner to do
so, Respondent enter into a listing agreement for the sale of the Marital Property."
6. In the event that the Marital Home is listed for sale, at the same time as
Respondent signs the Agreement of Sale, Respondent agrees to provide Petitioner with a set
of working house keys to the Marital Home.
IN WITNESS WHEREOF, counsel for the parties have hereunto set their hands and
seals the day and year first written, above.
J-
Kat1 E. Rominger, Esquire
ROMINGER & BAYLEY
155 South Hanover Street
Carlisle, Pennsylvania 17013
Attorney for Respondent
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t
LORRIE ANN JONES,
Petitioner
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-1579 CIVIL TERM
CIVIL ACTION - LAW
GERALD WADE JONES,
Respondent
IN DIVORCE
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ORDER OF COURT
AND NOW, this 6th day of October, 2003, in
accordance with the agreement of the parties as announced in open
court and in their presence, it is directed that the Respondent
attempt to refin2~ce the marital ho~e so that the debt thereon
would be in his name alone.
If he is unable to do so, and in
the meantime, irrespective of the matter of refinancing, the
Respondent agrees to pay both of the existing obligations on the
real estate, one a mortgage and one a line of credit, on or
before the day each is due. In the event the Respondent should
be in default of either payment for a period of more than 5 days,
it is directed that he enter into a listing agreement for the
sale of the property.
By
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Court,
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~dsay Gingrich Maclay,
~109 Market Street
. Camp Hill, PA 17011
For the Plaintiff
Esquire
Karl Rominger, Esquire
155 South Hanover Street
Carlisle, PA 17013
For the Defendant
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LORRIE ANN JONES,
Petitioner
CIVIL ACTION - LAW
v.
No. 2001-1579 (Civil Term)
GERALD WADE JONES,
Respondent
(In Divorce)
IN RE: PETITION FOR SPECIAL RELIEF
ORDER ADOPTING STIPULATION OF THE PARTIES
AND NOW, to wit, this LZ d day of Orhl. '^
, 2003, upon consideration
of the foregoing Stipulation and on Motion of Lindsay Gingrich Maclay, Esquire, counsel
for Petitioner, Lorrie Ann Jones, and on Motion of Karl E. Rominger, Esquire, counsel for
Respondent, Gerald Wade Jones, it is hereby ORDERED, ADJUDGED and DECREED
that the terms, conditions and provisions of the foregoing Stipulation, dated October JLf1!!-
2003, are adopted as an Order of Court, which is to be read in conjunction with the October
6, 2003 Order entered in this matter, as if set forth herein at length.
BY THE COURT,
/JJ
cc: Xmdsay Gingrich Maclay, Esquire
,.Karl E. Rominger, Esquire
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Lorrie A. Jones,
: In the Court of Common Pleas of
: Cumberland County, Pennsylvania
Petitioner
v.
: No. 2001-1579 Civil Term
Gerald W. Jones,
: Civil Action - Law
: In Divorce
Respondent
PETITION TO COMPEL DISCOVERY
ANO NOW, comes the Petitioner, Lorrie A Jones, by and through her counsel,
Saidis, Shuff, Flower & Lindsay and petitions this Honorable Court as follows:
1. The parties hereto are husband and wife having been joined in marriage on
July 5th, 1982 and having separated on or about March 15th, 2001.
2. On or about May 8th, 2003 Petitioner served on Respondent a request for
Production of Documents and a set of Interrogatories, a copy of which is
attached hereto as Exhibit "A".
3. More than 30 days have passed and the Respondent has not produced the
documents requested nor has he answered the Interrogatories.
WHEREFORE, the Petitioner prays this Honorable Court to issue a Rule upon
the Respondent to show cause why he should not be required to produce the
documents requested and answer the Interrogatories.
SAlOIS, SHUFF, FLOWER & LINDSAY
Attorneys for Plaintiff
By:
o . Lind ay, Esquire
I 44693
26 West Hi h Street
Carlisle, PA 17013
(717) 243-6222
SAlOIS
SHUFF, FLOWER
& LINDSAY
ATIORNEYS-ATeLAW
26 W. High Street
Carlisle, PA
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VERIFICATION
I verify that the statements made in this Petition for Special Relief are true and
correct. I understand that false statements herein are made subject to the penalties of
18 Pa. e.s. Section 4904, relating to unsworn falsification to authorities.
Dated: I~ /:::23 ,10.5
"
SAIDlS
SHUFF, FLOWER
& LINDSAY
ATIORNEYSIATlLAW
26 W. High Street
Carlisle, P A
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LORRIE ANN JONES,
Petitioner
v.
GERALD WADE JONES,
Respondent
AND
now,
.~r -e Vi'- be r
CIVIL ACTION - LAW
No. 2001 - 1579 (Civil Term)
(In Divorce)
CERTIFICATE OF SERVICE
this
/2Qj/....
of
day
, 2003, I, Carol J. Lindsay, Esquire, of the law
firm of SAlOIS, SHUFF, FLOWER & LINDSAY, Attorneys, hereby certify that I
served the within Request for Production of Documents this day by depositing
same in the United States Mail, First Class, Postage Prepaid, in Carlisle,
Pennsylvania, addressed to:
il
Karl E. Rominger, Esquire
Rominger & Bayley
155 S. Hanover Street
Carlisle, PA 17013
SAIDIS, SHUFF, FLOWER & LINDSAY
Attorneys for Plaintiff
By: IU
Caro, J Lindsay, Esquire
10# 93
26 est High Street
Carlisle, PA 17013
(717) 243-6222
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Lorrie A. Jones,
'V
m-: 3 0 2003 )I
Petitioner
: In the Court of Common Pleas of
: Cumberland County, Pennsylvania
v.
: No. 2001.1579 Civil Term
Gerald W. Jones,
Respondent
: Civil Action - Law
: In Divorce
.oRDER OF COURT
.
AND NOW, this 3"1 day of 1)~
, 2003 a Rule is issued
upon the Respondent to show cause if any why he should not be required to
provide the discovery requested.
Rule returnable 20 da)'of
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BY THE COURT
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ROBERT C. SAlDlS
GEOFFREY S. SHUFF
JAMES D. FLOWER, jR
CAROL). LINDSAY
MATTIffiW). ESHEIoMANt
KIRK S. SOHONAGE
THOMAS E. FLOWER
LINDSAY GINGRICH MACLAY
jACLYNSMITH
LAW OFFICES
SAIDIS, SHUFF, FLOWER & LINDSAY
A PROFESSIONAL CORPORATION
26 WEST illGH STREET
CARLISLE, PENNSYL VANIA 17013
TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486
EMAIL: altorney@ssfl-Iaw.com
www.ssfl~Iaw.com
CAMP IDLL OFFICE:
2109 MARKET STREET
CAMP HILL, P A 17011
TELEPHONE: (717)737-3405
FACSIMILE: (717)737-3407
tBoardCel1ifiedCreditors'
Rights Representation
REPLY TO CARLISLE
July 19, 2004
The Honorable Kevin A. Hess
Cumberland County Courthouse
One Courthouse Square
Carlisle, Pennsylvania 17103-3387
Re: Jones v. Jones (In Divorce)
Docket No. 2001-1579 (Cumberland County)
Dear Judge Hess:
Perhaps you will recollect that on May 27, 2004 the parties in this case met for a
hearing on a Petition for Contempt and Modification of a Custody Order. Gerald Jones
was seeking primary physical custody of the parties' two children, Tiffany and Megan.
As a part of the hearing, you spoke with Tiffany Jones, age 16, in chambers. After your
conversation with Tiffany, Mr. Rominger, who represents Gerald Jones, and I, with the
help of Dr. Schneider, reached an agreement, the gravamen of which was entered on
the record. Counsel agreed to flush out the agreement with a stipulation which could be
entered as a court order.
At the request of Mr. Rominger I prepared the stipulation. I forwarded it to him on June
10,2004. I have had no response from Mr. Rominger regarding the Stipulation. I wrote
him again on June 22, 2004 asking him for a response. I have not heard from Mr.
Rominger and I suspect the reason is that he has not heard from his client.
$
Irk
(V~'!<;:')
In the meantime, Mr. Jones has failed to appear for 4 alternating weekends to pick up
his children. My client goes to the former meeting place and Mr. Jones does not appear
and then she returns home, the meeting place under the agreed upon new
arrangement. Mr. Jones does not appear, he does not answer phone calls and he does
not call his children. Needless to say this is distressing to the children who wanted to
have contact with their father. It is also surprising because Mr. Jones was seeking
primary physical custody of the children and then entered into an agreement in court for
partial custody arrangement.
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Judge Hess
July 19, 2004
Page 2
At the present time there is an outstanding court order which obliges my client to
provide him custody. I have offered Mr. Rominger the opportunity for a stipulation of
counsel which will simply permit Mr. Jones to his children as the parties can agree. I
have a concern that, since my client was charged with contempt of a custody order, that
she will be once again charged under the circumstances here.
I am writing to request a conference in chambers or by conference call with the court. If
it is Mr. Jones' intention not to see his children, I would like to get an order on the record
which frees my client of the obligation of driving to the pickup point or having the
children avaiiabie on alternating Fridays for pickup by Mr. jones.
I regret having to involve the court further in this matter but would appreciate your help.
Very truly yours,
sa~c& Lie'",
Carol J. Lindsay
CJL:ap
Ce: Lorrie Jones
Karl Rominger, Esquire
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SAlOIS
SHUFF, FLOWER
& LINDSAY
ATTORNEYS-AT-LAW
26 W. High Street
Carlisle, P A
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Lorrie A. Jones,
: In the Court of Common Pleas of
: Cumberland County, Pennsylvania
Plaintiff
v.
: No. 2001.1579 Civil Term
Gerald W. Jones,
: Civil Action - Law
: In Divorce
Defendant
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend a9ainst the claims
set forth in the following pages, you must take prompt action. You are warned that
if you fail to do so, the case may proceed without you and a decree of divorce or
annulment may be entered against you by the Court. A judgment may also be
entered against you for any other claim or relief requested in these papers by the
Plaintiff. , You may lose money or property or other rights important to you, including
custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counselin9. A list of marriage counselors is
dvailable in the Office of the Prothonotary at the Cumberland County Court House,
Carlisle, Pennsylvania, 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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
32 BEDFORD STREET
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
SAlDIS, SHUFF, FLOWER & LINDSAY
Attorneys for Plaintiff
By:
C rol . Lindsay, Esquire
I 693
26 West High Street
Carlisle, PA 17013
(717) 243-6222
II
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SAlOIS
SHUFF, FLOWER
& LINDSAY
A'ITORNEYS-AT-LAW
26 W. High Street
Carlisle. P A
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Lorrie A. Jones,
: In the Court of Common Pleas of
: Cumberland County, Pennsylvania
Plaintiff
v.
: No. 2001-1579 Civil Term
Gerald W. Jones,
: Civil Action - Law
: In Divorce
Defendant
AMENDED COMPLAINT IN DIVORCE
LORRIE JONES, Plaintiff, by her attorneys, SAlOIS, SHUFF, FLOWER &
LINDSAY, respectfully represents:
COUNT I
1. The Plaintiff is Lorrie Jones, an adult individual who currently resides
at 408 Walnut Street, Unit B, Boiling Springs, Cumberland County,
Pennsylvania, 17007.
2. The Defendant is Gerald Wade Jones, an adult individual who
currently reSides at 38 Carlton Avenue, Carlisle, Cumberland County,
Pennsylvania, 17013 .
3. The Plaintiff and Defendant both have been bona fide residents in the
Commonwealth of Pennsylvania for at least six months immediately
prior to the filing of this Complaint.
4. The Plaintiff and Defendant were married on July 5, 1982 in
Cumberland County, Pennsylvania.
5. That there have been no prior actions of divorce or for annulment
between the parties in this or in any other jurisdiction.
6, Plaintiff and Defendant are not members of the United States Armed
Forces.
7.
The Plaintiff avers that she is entitled to a divorce on the ground that
the marriage is irretrievably broken and Plaintiff is proceeding under
Sections 3301 (c) and/or (d) of the Divorce Code.
Plaintiff has been advised of the availability of marriage counseling
and of he right to request that the Court require the parties to
participate in marriage counseling, and does not request counseling.
8.
II
,
SAlOIS
SHUFF, FLOWER
& LINDSAY
ATTORNEYS-AT'LAW
26 W. High Street
Carlisle, P A
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WHEREFORE, Plaintiff requests the Court to enter a decree of divorce.
COUNT II. EQUITABLE DISTRIBUTION
9. The averments of Paragraph 1 through 8 are incorporated herein by
reference as though set out in full.
10. The parties have, during their marriage, acquired certain property,
both personal and real.
WHEREFORE, Plaintiff prays this Honorable Court to equitably divide the
parties' ~roperty.
COUNT III - ALIMONY, COUNSEL FEES AND COSTS
11. The averments of Paragraph 1 through 10 are incorporated herein by
reference as though set out in full.
12. Plaintiff is without resources sufficient to pay for reasonable needs.
WHEREFORE, Plaintiff prays this Honorable Court to award to alimony in an
amount sufficient to provide for reasonable needs, counsel fees and costs.
SAIDIS, SHUFF, FLOWER & LINDSAY, P.C.
By:
Dote'Sft, ~ '1 ZPPf
Carol J. Li s y, squire
ID # 446
26 West 'gh Street
Carlisle, PA 17013
(717) 243-6222
II
SAlOIS
SHUFF, FLOWER
& LINDSAY
ATIORNEYS-AT-LAW
26 W. High Street
Carlisle, P A
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VERIFICATION
I, the undersigned, hereby verify that the statements made herein are true
and correct. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. 9 4904, relating to unsworn falsification to authorities.
l~~
Lorrie Jone
Date: 9/CX3/0<.j
II
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IN RE: PETITION FOR A RULE ABSOLUTE AND HEARING
ORDER OF COURT
AND NOW, this 2nd day of December, 2004, action on the
within petition is deferred in accordance with the agreement
entered into by the parties, as announced in open court and
attached hereto. If this matter is not relisted for hearing
within sixty days, the petition to be deemed dismissed without
further order of court.
By the Court,
~rol J. Lindsay, Esquire
For the Plaintiff
~rl Rominger, Esquire
For the Defendant
Ad
Hess, J.
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LORRIE A. JONES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V
CIVIL ACTION - LAW
GERALD W. JONES,
Defendant
NO. 2001-1579 CIVIL TERM
IN DIVORCE
IN RE: TRANSCRIPT OF PROCEEDINGS
Proceedings held before the
HONORABLE KEVIN A. HESS, J.,
Cumberland County Courthouse,
Carlisle, Pennsylvania,
on Thursday, December 2, 2004,
in Courtroom Number 4.
APPEARANCES:
CAROL J. LINDSAY, Esquire
For the Plaintiff
KARL ROMINGER, Esquire
For the Defendant
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MS. LINDSAY: Good afternoon, Your Honor.
THE COURT: Good afternoon.
MS. LINDSAY: Your Honor, we are here on a
4 petition filed by Plaintiff Lorrie Jones, in the matter of
5 Jones v. Jones, No. 2001-1579, seeking a rule absolute on a
6 petition to compel discovery. Counsel and I have reached an
7 agreement that we can just put on the record, and I think we
8 can have this matter resolved.
9 THE COURT: All right.
10 MS. LINDSAY: Counsel will provide to us
11 within ten days Mr. Jones' 2003 Federal income tax return.
12 And he will also provide a release signed by Mr. Jones
13 within ten days, so that I can get from the Teamsters
14 pension plan administrators information regarding his
15 Teamsters retirement benefits.
16 Mr. Jones will also sign a release in favor
17 of our office to obtain bank statements for March 2001 for
18 any bank statements which he has.
19 And, finally, Mr. Jones has provided today to
20 me a copy of a release regarding personal injury proceeds.
21 And I can take care of that into the future.
22 Finally, there is the matter of attorney's
23 fees in trying to pursue all of this. We have agreed that
24 the amount of $350.00 would be the attorney's fees in this
25 case, but the matter of these fees can be reserved for the
2
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I Master to assign or determine.
2 THE COURT: Okay.
3 MS. LINDSAY: But we wanted to get the amount
4 on the record.
5 MR. ROMINGER: That's all correct, Your
6 Honor. And I just want to add, the 2003 tax return was
7 previously brought to but not exchanged at a support
8 conference, and so it is more of an oversight than it was
9 anything else. The Teamsters issue, my client did provide
10 what he did have from the Teamsters. But since counsel
11 wants a little bit more information, the release I think
12 will satisfy both sides in that respect.
13 THE COURT: Okay.
14 MR. ROMINGER: And otherwise the agreement is
15 completely correct.
16
THE COURT: Well, what I will do is simply
17 defer action on the petition in accordance with your
18 agreement. And if nobody approaches me about relisting the
19 matter for hearing, we will deem it dismissed.
20 And Now, this date, action on the within
21 petition is deferred in ,accordance with the agreement
22 entered into by the parties and announced in open court. If
23 this matter is not relisted for hearing within sixty days,
24 the petition to be deemed dismissed without further order of
25 court.
3
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1 MS. LINDSAY: Your Honor, could I just
2 request that the agreement be transcribed and attached? I
3 don't mean for you to redo it, but just so we all have it.
4 THE COURT: As a matter of fact we will just
5 add comma, attached hereto, after we make reference to the
6 agreement.
7 MS. LINDSAY: Thank you, Your Honor.
8 (End of proceedings)
9
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CERTIFICATION
I hereby certify that the proceedings are
contained fully and accurately in the notes taken by me on
the above cause and that this is a correct transcript of
same.
Barbara E. Graham
Official Stenographer
The foregoing record of the proceedings on
the hearing of the within matter is hereby approved and
directed to be filed.
/'l. (J'1- 1)'(
Date
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A. Hess, J.
Judicial District
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ATIORNEYS.AT-LAW
26 W. High Street
Carlisle, P A
Lorrie A. Jones,
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Petitioner
: In the Court of Common Pleas of
: Cumberland County, Pennsylvania
v.
: No. 2001-1579 Civil Term
Gerald W. Jones,
Defendant
: Civil Action - Law
: In Divorce
\
MOTION FOR APPOINTMENT OF MASTER
Lorrie A. Jones,. Petitioner, moves the court to appoint a master with respect to the following
claims:
) Divorce
( ) Annulment
( X ) Alimony
( ) Alimony Pendente Lite
and in support of the motion states:
( X ) Distribution of Propertv
( 1 Support
( X ) Counsel Fees
( X 1 Costs and Expenses
(1) Discovery is complete as to the claim(s) for which the appointment of a master is
requested.
(21 The Defendant, Gerald W. Jones appeared in the action and is represented by
counsel, Karl Rominger, Esquire
(31 The statutory ground(s) for divorce is/are .3301 (c) and/or (d)
(4) Delete the inapplicable paragraph(s).
(a) The action is not contested.
(b) An agreement has been reached with respect to the following claims:
NONE.
(c) The action is contested with respect to the following claims: ALL.
(5) The action complex issues of law or fact.
(6) The hearing is expected to take.
(7) Additional information, if any, rei va
Date:
Jv~rClf
Carol J. L' ds y, Attorney for Petitioner
ID # 446
26 W. High St.
Carlise, PA 17013
ORDER APPOINTING MASTER
-~ -II J J A )
1.5 day of ,~~/~~-
a..rJl4.J-1, Esquire. is appointed master with respect
By the Court,
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ROBERT C. SAIDIS
GEOFFREY S, SHUFF
JAMES D. FLOWER JR
CAROL), UNDSAY
BRIAN C. CAFFREY
GEORGE F,DOUGLAS, III
MAITHEW J. ESHElMANt
THOMAS E, FLOWER
)ACL YN SMITH
LAW OFFICES
SAIDIS, SHUFF, FLOWER & LINDSAY
A PROFESSIONAL CORPORATION
26 WEST HIGH STREET
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486
EMAlL: attorney@ssfl.law.com
www.ssfl~Iaw.com
CAMP HILL OFFICE:
2109 MARKET STREET
CAMP HILL, PA 17011
TELEPHONE. (717)73,7-3405
FACSIMILE. (717)737-3407
tBoardCcnificdC,cdLtOL'"
Rigl1lS Repre5entatioll
REPLY TO CARLISLE
May 18, 2005
Robert Elicker, Esquire
Office of the Divorce Master
13 N. Hanover St.
Carlisle, PA 17013
RE: Jones v. Jones
No. 2001-1579 Civil Term
Dear Mr.,Elicker:
Enclosed please find Plaintiff's Pre-Trial Statement in the above reference matter.
Very truly yours,
Saidis, Shuff, Flower & Lindsay
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Carol J. Lind --
OL:sarn
cc: Lorrie Jones
Karl Rominiger
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LAW OFFICES
SAIDIS, SHUFF, FLOWER & LINDSAY
A PROFESSIONAL CORPORATION
26 WEST HIGH STREET
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486
EMAIL: altorney@ssfI-Iaw.com
www.ssfl-Iaw.com
CAMP HILL dFFICE
2109 MARKET STREET
CAMP HILL, PA 17011
TELEPHONE: (717)737-3405
FACSIMILE: (717)737-3407
)OHN E, SLIKE
ROBERT C. SAlDIS
GEOFFREY S, SHUFF
JAMES D. FLOWER, jR
CAROL). LINDSAY
BRIAN C. CAFFREY
GEORGE F. DOUGLAS, III
MATTHEW j, ESHELMANt
THOMAS E, FLOWER
MARYLOU MATAS
SUZANNE C. HIXENBAUGH
tBo~rd Certified Creditors'
Rights Representation
REPLY TO CARLISLE
September 16, 2005
Robert Elicker, Esquire
Office of the Divorce Master
13 North Hanover Street
Carlisle, PA 17013
Re: Jones v. Jones
No. 2001-1579 Civil Term
Dear Mr. Elicker:
This is the date by which Mr. Rominger and I were to let you know if we were able to
settle the equitable distribution portion of the case, thus leaving the hearing for October 4, 2005
as a hearing on the issue of alimony, attorney's fees and costs.
I have provided a proposal for settlement to Mr. Rominger. He tells me that he will
review it with his client. Thus, at this point, we do not have an equitable distribution settlement.
If we should be able to negotiate one, we will let you know. I have some hope that we can settle
distribution, attorney's fees and costs. We know that the alimony portion of the case will not
settle. Thank you for your help.
Very truly yours,
R & LINDSAY
CJUbes
cc: Lorrie Jones
Karl Rominger, Esquire
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LAW OFFICES
SAIDIS, SHUFF, FLOWER & LINDSAY
A PROFESSIONAL CORPORA nON
26 WEST HIGH STREET
CARLISLE, PENNSYL VANIA 17013
TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486
EMAIL: attorney@ssfI-law.com
www.ssfl-Iaw.com
CAMP HILL OFFICE:
2109 MARKET STREET
CAMP HILL, PA 17011
TELEPHONE: (717)737-3405
FACSIMILE: (717)737-3407
JOHN E. SLIKE
ROBERT C SAlDIS
GEOFFREY S. SHUFF
JAMES D. FLOWER, JR
CAROL). LINDSAY
BRIAN C. CAFFREY
GEORGE F. DOUGLAS, III
MATTHEWJ. ESHELMANt
THOMAS E. FLOWER
MARYLOU MATAS
SUZANNE C. HIXENBAUGH
tBoardCertifiedCreditors'
Rights Representation
REPLY TO CARLISLE
September 20, 2005
Robert Elicker, Esquire
Office of the Divorce Master
13 North Hanover Street
Carlisle, PA 17013
Re: Jones v. Jones
No. 2001-1579 Civil Term
Dear Mr. Elicker:
No Pre-Trial Statement for Defendant has been filed in the above captioned case which
is set for a hearing on October 4, 2005. Neither has Mr. Jones filed a verified Income and
Expense Statement. Mrs. Jones will assert the remedies set out in Rule 1920.23(c) and (d).
Thank you for your help.
Very truly yours,
SAIDIS, SHUFF, FLOWER & LINDSAY
C~-
Carol J. Lindsay, Esquire
CJUbes
cc: Lorrie Jones
Karl Rominger, Esquire
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In the Court of Common Pleas of
CUMBERLAND
County, Pemnsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 326, CARLISLE, PA. 17613
Phone: (717) 240-6225
Fax: (717) 240-6248
Defendant Name: GERALD W. JONES
~emberIDNumber: 2301100755
Please note: All correspondence must include the Member ID Number.
MODIFIED ORDER OF ATTACHMENT OF UNEMPLOYMENT BENEFITS
Plaintiff Name
LORRIE A. JONES
LORRIE A. JONES
Financial Break Down of Multinle Cases on Attachment
P ACSES Docket
Case Number Number
394107723 01-1579 CIVIL
850103327 00270 S 2001
$
i
$
$
i
$
Attachment Amount/Freauency
825.00 !MONTH
637. 00 ~MONTH
/
/
%
/
/
/
TOTAL ATTACHMENT AMOUNT: $
1,462.00
Now, by Order of this Court, the Department of Labor and Industry, Bureau of Unemployment
Compensation Benefits and Allowances (BUCBA), is hereby directed to attach the lesser of $ 337.38
per week, or 50 . 0 %, of the Unemployment Compensation benefits otherwise payable to the Defendant,
GERALD W. JONES Social Security Number 205-52-9905 ,Member
ID Number 2301100755 . BUCBA is ordered to remit the amount attached to the Department of Public
Welfare (DPW). DPW shall forward the amount received from BUCBA to the Domestic Relations Section of this
Court for support and/or support arrearages.
If the Defendant's Unemployment Compensation benefits are attached by another Court or Courts for
support and/or support arrearage, DPW may reduce the amount attached under this Order so that the total amount
attached does not exceed the maximum amount subject to garnishment pursuant to 15 U.S.C. ~ 1673(b)(2) and 23
Pa. C.S. ~ 4348(g).
This Order shall be effective upon receipt of the notice of the Order by the BU CBA and shall remain in
effect until the Defendant's entitlement to Unemployment Compensation benefits, under the Applicatiou for
Benefits dated FEBRUARY 15, 2004 is exhausted, expired or deferred.
BUCBA shall comply with this Order, unless it is amended or vacated by subsequent Order of this Court.
All questions, challenges or obligations to this Order shall be directed to the Domestic Relations Section of this
Court.
BY THE COURT
Date of Order:
OCT 1 1 2005
Kev~:
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JUDGE
DRO: R. J. Shadday
Service Type M
Form EN-034
Worker ID $IATT
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsvlvania
Co.lCity/Dist. of CUMBERLAND
Date of Order/Notice 10/10/05
Case Number (See Addendum for case summary)
394107723
01-1579 CIVIL
o Original OrderlNotice
@ Amended OrderlNotice
o Terminate OrderlNotice
ABF FREIGHT SYSTEMS
PO BOX 10048
3801 OLD GREENWOOD RD 729
FORT SMITH AR 72917-0048
850103327
270 S 2001
RE: JONES, GERALD W.
Employee/Obligor's Name (last, Firsl, MI)
205-52-9905
Employee/Obligor's Social Security Number
2301100755
Employee/Obligor's Case Identifier
(See AddendlHll for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (last, First, MI)
EmployerMiithholder's Federai EIN Number
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's1obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ l,380.00permonthincurrentsupport
$ 82.00 per month in past-due support Arrears 12 weeks or greater? Qyes @ no
$ 0.00 per month in current and past-due medical support
$ 0 . 00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 1. 46 2 . 00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 337.38 per weekly pay period.
$ 674.77 per biweekly pay period (every two weeks).
$ 731.00 per semimonthly pay period (twice a month).
$ 1.462.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10l working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's! obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on page 2).
If remitting by EFTIEDI, please call Pennsylvania State Collections and Disbursement Unit (SCDUl Employer
Customer Service at 1-B77-676-95BO for instructions.
Make Remittance Payable to: PA seDU
Send check to: Pennsylvania SeDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER 10 (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BY THE COURT:
~. /?
Kev~. Hess,
~
Date of Order: OCT 1 1 2005
000.: R.J. Shadday
ServlceType M
OMS No.: 0970-0154
Form E~~Z8
Worker ID $IATT
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If, \;Mcked you are required. to provide a copy of this form to your employee. If yoVr employee works in a state that is
dll1erent from the state that ISSUed this order, a copy must be provided to your employee even if the box is not checked.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employee/obligor.
3.* Re....vrtil,g tile raydCi.telDdl:c vf Vv'itl ,hold;,lg. 'I~U l'IMl ,elJv,lll,'ll;; lJaydatelddte of yy;U,'lold;llg vvll'll;;ll ::l'll;;"d;"5 d,'ll;; paYIII'll;;IIl. Tile
paydalddate vf vv;~11IoIJ;1I5~! die date 011 VVI,id, cl.IIIOuhl vveb yyid,l''ll;;IJ ~VIII tll'll;; elllfJlvY'll;;e~ vvages. You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and forward the support payments.
4.' Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
THE EMPLOYEElOBUCOR NO LONCER WORKS FOR: 7102494440
EMPLOYEE'S/OBlICOR'S NAME: JONES. GERALD W.
EMPlOYEE'S CASE U)ENTIFIER: 2301100755 DATE OF SEPARATION:
LAST KNOWN f10ME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments. contact the person or authority below.
7. liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law govems unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment,
refusing to employ, or taking disciplinar; action against any employee/obligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9.' Withholding limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (1 S U.s.c. 91673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly eamings (ADWE). ADWE is the net income left after making mandator;
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more
than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more
than the amounts allowed under the law of the state that issued the order.
1 O. Additional Info:
'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
11.Submitted By: If you or your employee/obligor have any questions,
DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT
13 N. HANOVER ST by telephone at (717) 240-6225 or
P.O. BOX 320 by FAX at 17171 240-6248 or
CARLISLE PA 17013 by internet www.childsupport.state.pa.us
Page 2 of 2
Form EN-028
Worker 10 $IATT
Service Type M
OMS No,; 0970-0' S4
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ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: JONES, GERALD W.
PACSES Case Number 394107723
Plaintiff Name
LORRIE A. JONES
Docket Attachment Amount
01-1579 CIVIL$ 825.00
Child(ren)'s Name(s):
DOB
Elii~~:~:;~~:~;;.;~~l:;~~~~~i,;~~~~iidi;.;~i)r
identified above in any health insurance coverage available
through the employee's1obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
,::-:::,:,;:,-:,:;:",:".-:,::,-::";:::,=;:-::,,,:,:,,::,:::;:::::,:':',':;:.;,:,:::'".,:",:,::',,"'-::'::';::::'X:':',',,::.:-::::,:,;,'::.:::-:'::':"::::':':'::,:,::",::::,,:;::::::,:,::"::::::;:;::::::,:::,:"",,::::,,:,:.;.:,:,
O;i~h~~k;;d,"';~~"~'~";~i;;;d';~~~;~II"~'~"'~hil;;;~~;................'.."""
Identified above in any health insurance coverage available
through the employee's1obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
;::~:,::~::}:,::~:::),:(:,:,}(,:,r:~:}~:::::~,::::,:t?,:::::<:,(:::::,;:::::::::::::r:::::~:r:~::::::.:::::)::{;:::::;::}l:}}:;~:i:~:::::~t:::l:~:r:!:::Jt:::i:::i:1::::;:t!:~~{:;:l::~::::::;!::(:...
o If ch~"~, you ar~ requi;ji~~~~llih~chiid(re~i"
identified above in any health insurance coverage available
through the employee's1obligor's employment.
PACSES Case Number 850103327
Plaintiff Name
LORRIE A. JONES
Docket Attachment Amount
ooms 2001 $ 637.00
Child(ren)'s Name(s):
i~1i~i8i~lt.~r
DaB
""""""(f""'///"':'.""rr,:'r'rr~~:~'i~k~'~
D;~~~~~:~~:~~::~~;:;;;~:~:~;~;~:~~;;;;(~~;
identified above in any health insurance coverage available
through the employee's1obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0,00
Child(ren)'s Name(s):
DaB
o If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's1obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DaB
dW~~;~;~::.'~~~~:;;~f~;;:f;~~~;~I;I;~e~hild(r~~f);
identified above in any health insurance coverage available
through the employee's1obligor's employment.
Service Type M
OMB No.: 097()'()1 S4
Addendum
Form EN-028
Worker 10 $IATT
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of Pennsvlvania
Co./City/Dist. of CUMBERLAND
Date of OrderlNotice 10/10/05
Case Number (See Addendum for case summary)
394107723
01-1579 CIVIL
o Original Order/Notice
@ Amended Order/Notice
o Terminate Order/Notice
Employer/Withholder's Federal EIN Number
850103327
270 S 2001
RE: JONES, GERALD
W.
Employee/Obligor's Name (last. First, MI)
205-52-9905
Employee/Obligor's Social Security Number
2301100755
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (last, First, Mil
PENN NATIONAL INSURANCE
PO BOX 3880
HARRISBURG PA 17105-3880
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an OrderlNotice to Withhold Income for Support based upon an order for support
from CUMBERLAND County, Commonwealth of Pennsylvania. By law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 1,380.00 per month in current support
$ 82.00 per month in past-due support Arrears 12 weeks or greater? Oyes Q9 no
$ 0.00 per month in current and past-due medical support
$ 0 . 00 per month for genet! c test costs
$ per month in other (specify)
for a total of $ 1,462.00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 337.38 per weekly pay period.
$ 674.77 per biweekly pay period (every two weeks).
$ 731.00 per semimonthly pay period (twice a month).
$ 1.462.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate!date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee'sl obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on page 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCOU
Send check to: Pennsylvania SCOU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
DOO: R.J. Shadday
Service Type M
BY THE COURT:
~.
Kevin A~SS,
/9.4..
Date of Order: -DCL1 1 2005
OMB No.: G97(}.(}154
Judge
Form EN-028
Worker 10 $OINC
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: ",~.'O""1W$'/
,
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If.lihecked you are required. to provide a (:opy ofthis form to your employee. If your employee works in a state that is
dl erent from the state that ISsued this order, a copy must be provided to your employee even if the box is not checked.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employee/obligor.
3. * Repoll;115 llle rayJale/Date of'qyal Ii ,okJi"j5, YOu IlIU:Jt lepult tile l-'ayJalefdale uf vvil!,I,Oldi"j5 vvllell ~I::"r,dil,g till::" fJaylllellL Tile
paydate/datt of vv;L1lllold;1I5 is LIlt:: Jalc: 011 vvl.;",1 I dlllUUlIl vvd~ vvitl,l,eld hUll, tile ell'l-'Iuyee'~ vVaj5I::"~. You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the lime periods wilhin which you must implement the
withholding order and forward the support payments.
4. * Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
thi, employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 0064100092
EMPLOYEE'S/OBLlGOR'S NAME: JONES , GERALD W.
EMPLOYEE'S CASE IDENTIFIER: 2301100755 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. Liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment,
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law
governs unless the obligor i, employed in another State, in which case the law of the State in which he or she is employed governs.
9. * Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.s.c. 91673 (b)l; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more
than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more
Ihan the amounts allowed under the law of the state that issued the order.
10. Additional Info:
* NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
11. Submitted By:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE ATTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717\ 240-6248 or
by internet www.childsupport.state.pa.us
Page 2 of 2
Form EN-028
Worker ID $OINC
Service Type M
OMS No.: 0970-0154
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ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: JONES, GERALD W.
PACSES Case Number 394107723
Plaintiff Name
r,ORRIE A. JONES
Docket Attachment Amount
Ol=1579 CIVlr.$ 825.00
Child(ren)'s Name(s):
DOB
you are required to enroll the child(ren)
in any health Insurance coverage available
the employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
you are required to enroll the child(ren)
above in any health insurance coverage available
employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
If checked, you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
Service Type M
OMB No.: 0970-0154
PACSES Case Number 850103327
Plaintiff Name
r.ORRIE A. JONES
Docket Attachment Amount
00270 S 200l $ 637.00
Child(ren)'s Name(s):
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PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
Addendum
Form EN-028
Worker ID $OINe
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LORRIE A. JONES
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
VS.
NClr1 - 1579
IN DIVORCE
CIVIL
19
GERALD W. JONES
Defendant
STATUS SHEET
DATE:
ACTIVITIES:
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LORRIE A. JONES,
Plaintiff
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 01 - 1579 CIVIL
GERALD W. JONES,
Defendant
IN DIVORCE
TO:
Carol J. Lindsay
, Attorney for Plaintiff
Karl E. Rominger
, Attorney for Defendant
DATE: Friday, March 11, 2005
CERTIFICATION
[ ] I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
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(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
DATE
COUNSEL FOR PLAINTIFF
COUNSEL FOR DEFENDANT
NOTE:
PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE ,WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
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LORRIE A. JONES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 01 - 1579 CIVIL
GERALD W. JONES,
Defendant
IN DIVORCE
RE:
Pre-Hearing Conference Memorandum
DATE:
Monday, July 25, 2005
Present for the Plaintiff, Lorrie A. Jones, is
attorney Carol J. Lindsay, and present for the Defendant,
Gerald W. Jones, is attorney Karl E. Rominger.
The parties were married on July 5, 1982, and
separated March 31, 2001. They are the natural parents of
two children, Tiffany, born June 18, 1988, and Megan, born
June 14, 1992. The older child is currently residing with
the father and the younger child with the mother.
A complaint in divorce was filed on March 19,
2001, raising grounds for divorce of irretrievable breakdown
of the marriage. On September 23, 2004, an amended
complaint was filed raising economic claims of equitable
distribution, alimony and counsel fees and costs. Counsel
have indicated that they do not intend to present any
testimony on the factor of marital misconduct as that factor
may affect wife's alimony claim.
Wife is living at 408 Walnut Street, Unit B,
Boiling Springs, Pennsylvania. She resides with the younger
daughter. Counsel is going to provide wife's age at the
time of the hearing. Wife works as A dietary aide with the
Carlisle Regional Medical Center and her current net monthly
income as determined by the Domestic Relations Office is
$1,597.00. Wife has not raised any health issues and has
medical insurance available to her upon the entry of a
divorce decree. Wife has a high school diploma.
Husband is 51 years of age and resides at 38
Carlton Avenue, Carlisle Pennsylvania, where he lives with
the older daughter. Husband is a high school graduate and
is a truck driver for ABF. His net monthly income as
recently computed by the Domestic Relations Office is
$3,972.00. Husband has not raised any health issues which
affect his ability to perform his employment
responsibilities.
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The parties own real estate at 38 Carlton
Avenue, Carlisle, Pennsylvania. The real estate has been
appraised as of August 15, 2001. The updated appraisal is
approximately $10,000.00 less than the original appraisal.
There is a mortgage and a home equity loan against the
property.
The parties have listed a number of vehicles
and bank accounts on the pre-trial statement filed by wife.
Husband also has a retirement plan with the Teamsters Union
and an American Investors IRA and a Putnam IRA. Wife has a
401(k) plan with the Carlisle Hospital.
Husband's Masland retirement was cashed out
during the time the parties were living together.
Husband has apparently occupied the marital
home for a period of time while wife was making the mortgage
payments and wife is expecting a credit for her payments to
preserve the home.
The marital debt consists of the mortgage and
home equity loan.
There is no issue with respect to household
tangible personal property and no values will be used for
property which each party has in his or her possession in
the equitable distribution computation.
Counsel have indicated that they are working
on trying to settle the equitable distribution portion of
this case; however, the alimony and counsel fees portion of
the case will probability require a hearing.
Counsel are directed to provide the Master
with an agreement with respect to equitable distribution on
or before Friday, September 16, 2005. If an agreement is
provided then the hearing on October 4, 2005, will be
devoted to wife's claim for alimony and counsel fees and
costs. If however, we need to have a hearing on all of the
issues on October 4, 2005, we will begin that day with the
testimony of the expert witnesses with regard to the value
of the real estate. In any event, the Master should have a
current income and expense statement filed by September 16,
2005. Attorney Lindsay should also file a statement which
she will attach as an exhibit showing her computation for
her claim for counsel fees and costs so that Mr. Rominger
has an opportunity to review that exhibit prior to the
hearing.
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With respect to grounds for divorce, the
parties will provide the Master with affidavits of consent
and waivers of notice of intention to request entry of
divorce on or before September 16, 2005. The divorce can,
therefore, be concluded under Section 330l(c) of the
Domestic Relations Code.
A hearing will be scheduled on equitable
distribution and other claims for Tuesday, October 4, 2005,
or will be limited to testimony on alimony and counsel fees
in the event the Master has received an equitable
distribution agreement on or before September 16, 2005.
MS. LINDSAY: The parties will provide
updates of their IRA and wife's 401(k) plan by September 16,
2005, including copies of all statements from the date of
separation to the present or in the alternative a statement
from the plan administrator as to whether or not any
withdrawals have been taken from the plan since the date of
separation.
THE MASTER: Let the record show that Mr.
Rominger did not file a pretrial statement as directed in
May 2005 and that he provided a pretrial statement about an
hour before today's conference. The Master did not look at
the pre-trial statement and advised Mr. Rominger that he
could file the statement later with the exhibits attached if
he chooses to do so.
cc: Carol J. Lindsay
Attorney for Plaintiff
Karl E. Rominger
Attorney for Defendant
3
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LORRIE A. JONES
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
v.
GERALD W. JONES
: NO.
01 - 1579
: IN DIVORCE
ORDER AND NOTICE SETTING HEARING
TO: Lorrie A. Jones
Carol J. Lindsay
, Plaintiff
, Counsel for Plaintiff
Gerald W. Jones
Karl E. Rominger
, 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 of the Divorce Master, 9
North Hanover Street, Carlisle, Pennsylvania, on the 4th day of
October 2005 at 9:00 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 amJI25105
NotIce:
By:
Divorce Master
IF YOU DO NOT HA VB 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
32 SOUTH BEDFORD STREET, CARLISLE, PA 17013
TELEPHONE (717) 249-3166
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LORRIE A. JONES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - LAW
NO. 01 - 1579 CIVIL
GERALD W. JONES,
Defendant
IN DIVORCE
NOTICE OF PRE-HEARING CONFERENCE
TO: Carol J. Lindsay
, Attorney for Plaintiff
Karl E. Rominger
, 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 25th day of July 2005, 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: 3/24/05
E. Robert Elicker, II
Divorce Master
Carol J. Lindsay, Attorney for Plaintiff, filed a pretrial
statement on May 19, 2005.
Karl E. Rominger, Attorney for Defendant, has not filed a
pretrial statement as of the date of this notice.
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Jone$ v. Jones, Matter no. 01-1597
Date of Marriage 7/5/82; Date of Separation 3/31/01
Value to Value to
Descri ption of Items Marital Value Husband Wife
Real Estate
38 Carlton Ave, Carlisle (purch 12/85) (mortgage payoff: $22,362.00) $ 83,187.01 $ 83,187.01
appraised 8/15/01 by BHAgency $79,800-updated by increase in value
Fair Rental Value - 53 months @ $500 per month $ 26,500.00 $ 26,500.00
Vehicles
1994 Ford Explo~er~KBB value $ 3,307.00 $ 3,307.00
2000 Chevy pickup-K~B value $ 8,880.00 $ 8,880.00
2001 Triumph motorcycle (need model) - est. value $ 4,000.00 $ 4,000.00
,
1972 Chevy pick~4P - estimated value $ 300.00 $ 300.00
Bank Accounts
W-Waypoint #90336Q25 (as of 3/31/01) $ 566.00 $ 566.00
W-Waypoint #19JOOd3190 acct (as of 4/5/01) $ 390.00 $ 390.00,
, ;
JT-Members 1st FCU #101887 (as of 3/31/01) $ 25.87 $ 25.87.
H-Waypoint acct #0420 as.of 3/31/01 $ 72.90 $ 72.90
Retirl'!ment
H-Teamsters Local 776 Pension marital value through 08/31/05 $ 104,376.10 $ 104,376.10
H-American Investors IRA (as of 3/28/01) need present value (,.~6~ $ 5,9IMe $ 5,932.46
H-Putnam IRA (as of 3/31/05) $ 1,875.02 $ 1,875.02
W-401k Carlisle Hospital (as of 6/30/05) $ 2,388.07 $ 2,388.07
H-Masland Retirement - need info
Personalty $ - $ - $ -
TOTALS: $ 241,800.43 $235,123.49 $ 6,676.94
Eauitable Considerations
Reimbursement to Wife of payments made to preserve $ 3,127.74 $ 3,127.74
marital home while husband occupied it
.
Non Marital
Savings acct for daughter Tiffany ($1154.68 as of 12/31/99)
Savings acct for dauahter Megan ($668.57 as of 12/31/99)
Jones v, Jones
#01-1597
10/312005
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATI'ORNEVS'AT'LAW
26 W. High Street
Carlisle, PA
c'
,
Lorrie A. Jones,
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Petitioner
v.
No. 2001-1579 Civil Term
Gerald W. Jones,
Civil Action - Law
In Divorce
Respondent
PETITIONER'S PRE-TRIAL STATEMENT PER Pa.R.C.P.1920.33(b}
AND NOW, comes Petitioner, by and through her counsel, SAIDIS,
SHUFF, FLOWER & LINDSAY, and respectfully submits her Pre-Trial Statement as
follows:
I. BACKGROUND: parties were married on July 5, 1982 and have
been living separate and apart since on or near March 31, 2001. A Complaint in
Divorce was filed by Wife on March 19, 2001 and an Amended Complaint in Divorce
was filed by Wife on September 23, 2004. There are two children born of this
marriage, Tiffany Nicole Jones, age 16, born June 18, 1988 and Megan Rebecca
Jones, age 12, born June 14, 1992. By Order of Court of August 31, 2004, the legal
custody and primary physical custody of the children is with Wife. Wife is employed
as a dietary aide with Carlisle Regional Medical Center and has a net monthly
income of $1 ,453.44. Husband is employed at ABF and had a net monthly income
of $3,441.52 at the time of the last support conference.
II.
ASSETS: The assets of the parties are identified on the Asset/Debt
spreadsheet attached here as Exhibit "A"
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III. WITNESSES:
A. Lay Witnesses
1. Wife will testify on her own behalf.
2. Wife reserves the right to list other lay witnesses as needed
with notice to husband.
B. Expert Witnesses: Wife will call Douglas Heineman who
appraised the marital home if the parties cannot agree to value
and the fair market value of the home.
IV. EXHIBITS:
A.
B.
C.
D.
E.
F.
G.
H.
SAlOIS
SHUFF, FLOWER I.
& LINDSAY
ATIORNEYS.AT'LAW J.
26 W. High Street
Carlisle, P A
K.
Ii
Asset/Debt spreadsheet
Real Estate appraisal- to be updated
Mortgage statements - updated statements to be provided
Kelly Blue Book value for vehicles
Date of Separation Bank Account statements
Letter from Teamsters regarding pension value
Husband's American Investors IRA statement
Husband's Putnam IRA statement
Wife's 401(k) statement
Wife's Income and Expense Statement
Correspondence from Attorney Charles E. Schmidt, Jr.
SAlOIS
SHUFF, FLOWER
& LINDSAY
ATIORNEYS-AT-LAW
26 W, High Street
Carlisle. P A
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regarding Husband's awards from pending litigation.
L. Docket Entries for Divorce Action
M. Attorney's Fees - to be provided
V. INCOME: Wife works for Carlisle Regional Medical Center. Husband
is currently employed by ABF. Wife's tax return and income
statement will be provided at or before the hearing.
VI. MARITAL DEBT: listed on Exhibit "A", Wife's asset/debt
spreadsheet
VII. PROPOSED RESOLUTION: Wife requests 60% of marital property
in favor of Wife and an award of alimony in an amount sufficient to provide for her
reasonable needs, counsel fees and costs.
Respectfully submitted,
Saidis, Shuff, Flower & Lindsay,
Date:~
By:
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CAROL J. LI
10# 44693
26 West High Street
Carlisle, Pennsylvania 17013
(717) 243-6222
Attorney for Defendant
Ii
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATIORNEYS-AT.LAW
26 W. High Street
Carlisle, P A
Lorrie A. Jones,
Gerald W. Jones,
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Petitioner
In the Court of Common Pleas of
Cumberland County, Pennsylvania
v.
No. 2001-1579 Civil Term
Respondent
Civil Action - Law
In Divorce
CERTIFICATE OF SERVICE
If
DAY OF
AND NOW, THIS
2005, I, CAROL J. liNDSAY, ESQUIRE, OF THE lAW FIRM OF SAlOIS, HUFF, FLOWER &
LINDSAY, ATTORNEYS, HEREBY CERTIFY THAT I SERVED THE WITHIN PETITIONER'S
PRETRIAL STATEMENT THIS DAY BY DEPOSITING SAME IN THE UNITED STATES MAil, FIRST
CLASS, POSTAGE PREPAID, IN CARLISLE, PENNSYLVANIA, ADDRESSED TO:
II
Karl E. Rominger, Esquire
ROMINGER & BAYLEY
155 South Hanover Street
Carlisle, PA 17013
SAlOIS, SHUFF, FLOWER & LINDSAY
Attorneys for Petitioner
By:
Carol J.
10#44
26 West High Street
Carlisle, PA 17013
(717) 243-6222
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Jones v. Jones, Matter no. 01-1597 , I
,
Date of Marriage 7/5/82; Date of Separation 3/31/01
Value to Value to
Description of Items Marital Value Husband Wife
Real Estate i
38 Carlton Ave, Carlisle(purch 12/85) ,
appraised 8/15/01 by BHAgency $79,800-updated appraisal ordered
home eq. $40k ole; bal on 7/31/01 $25188.42
1st mtg Bal $16513.52 as of 7/31/01--updated mtg payoffs ordered
Fair Rental Value
!
Vehicles I $
.u.
1994 Ford Explorer-KBB value 3,307.00 $ 3,307.00
2000 Chevy pick up-KBB value 1$ 8,880.00 I $ 8,880.00
2001 Triumph motorcycle (need model) - est. value $ 4,000.00 , $ 4,000.00
1972 Chevy pick-up - need value
Bank Accounts
W-Waypoint #90336025 (as of 3/15/01) $ 513.47 $ 513.47 ,
W-Waypoint #1970003190 CD acct (as of 7/16/01) $ 639.20 ' $ 639.20
JT-Members 1st FCU #101887 (as of 3/31/01) $ 25,87 . $ 25.87
H-Waypoint ace! #0420 as of 3/31/01 $ 72.90 $ 72.90
Retirement !
H-Teamsters Local 776 Pension marital value (see exhibit) $ 83,667.57 ' $ 83,667.57
H-American Investors IRA (as of 3/28/01) need present value $ 5,932.46 $ 5,932.46
H-Putnam IRA (as of 3/31/01) need present value $ 1,967,79 $ 1,967.79
W-401k Carlisle Hospital (as of 10/1/01) !$ 2,035.4~ $ 2,035.40
H-Masland Retirement - need info ,
! !
-
,
Personalty $ - ! $ - $ -
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TOTALS: ~ $ 111,04~66 $ 104,520.72 $ 6,520.94
!
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Eouitable Considerations ,
Reimbursement to Wife of payments made to preserve .t _lJ 911~__ $ 3,191.19
marital home while husband occupied it
-- --
Non Marital
savings acct for daughter Tiffany ($1154.68 as of 12/31/99)
savings ace! for daughter Meqan ($668.57 as of 12/31/99) EXHIBIT
J A Jones v Jones
#01.1597
5/1812005
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Address .3lLCadton.A'lenue
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tcnder!Cll~nt LorriE'! A lonf'!!'>
CO,unty ~umb.ed~ Slale &.-
Zip Code .1Z013
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Cover Page
Cover Letter
Table of Contents
Appraisal SUmmary
Uniform Residential Appraisal Report
Text Addendum
Subject Photos
Bundlng Sketch
Comparable Photos
Location Map
Certification and Umiting Conditions
Invoice
Addenda
B.H Agency APPl'3isal Services
163 N. Hanover Street
Carllsle,Pa.17013
(717) 243-1000
This rDrll1 W3S
EXHIBIT
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APPRAISAL SUMMARY
Subject Address.. . ..... 3llcadJ:onAllenue
legal Descriplion. ... Soe-"ltac!Jed..d.e<d
Ci~. Ca[lisle
Counly ... ...... ............. e"m"",lon"
Slate.. . .. .... ........ I'a
Zip Code. ..... lZ.!!1~
Census Tract. ........ ..". 012~__..
MapReference. 22-0489-082 & 083
SalesPrice $. . . . . . . , ' .. -.Jj/~-_.
Date 01 Sale .... .., ,... N/A
-
Borrower/Clienl... . w.
....,
lender. ......... LOJJil>.ll..lon.es
Size (Square Feel). l3O.0
Price per Square Foot. . .. ,...1
location.... ........
Age.... .. ...~O
..... ..... .....
Condition. . ...... Ft'lir
Total Rooms. ... <
... .. .....
Bedrooms,..,.. . ,
.... .., .....
Baths............. .on
.....
Appraiser.. '.' .... D.2lliJ1as..R.J::telneman & G. Arthur CabuAAn
Date of Appraised Value. . . , . 08/.15'"'
FfnalEsllmateor Value. ......I 7.9,80D._...__,
DeslgnedI1fUn"edSyslemsSortwareCcmpanyI800)969-B721
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Kelley Blue Book - Trade-In Pricing Report - Ford, Explorer Page I of2
I
Kelley Blue Book
THE TRUSTED RESOURCE
-'tI""
c", .71::: ,""'" "fn"" ,;,;":'
J ____~..-' ,_-"-~
r I-:lO;,;;e-~NEwCAAS ~.~j.:.t::::t-t.fll"f.."" REVIEWS &. RATINCS ADVICE. FlNANClt.:O.& Y.
. - -- :; ~~ ..3I.JIlr.:.1.r.mr.r.l~T"~~_"'.IIT.l{il ~..,..hll.I1I~ICI~iliT!Ik1.'. Clillr;~Tt:ml.
advertisement
BLUE BOOK" TRADE-IN VAlUE
Pennsylvania. May 11, 2005
1994 Ford Explorer Sport Utility 4D
BLUE BOOK CL\SSIHI
ilst Your Cor FOl 5dl~
$e.?Lcb.J_Jslio91doLlbLs._C.<lI
!,.!sLYour Car For Sale Online
QU,i,ck",NeY!!,C?LP.I!ce:.Q!lole
EI~e CARFAX Record Check
Auto Loans from 4.49% APR
lD.s_uI?.o.9@~QuoJ~
f'.?Ym~nt.g.<lfuuJ<lJor
For one low price YOl
appear on both kbb.c
cars. com, Plus over:
Eopular websites,
~;:,
Engine: V6 4.0 Liter
Trans: Automatic
Drive: 4WD
Mileage: 72,000
- advertiseme
. m EXHIBIT
11)
3qOo
-=-<:1/15
;) t I I 8S
sQ;;2 .5
i-- (), I
07-S
04 , or ;1994%20Ex... 5/11/2005
Equipment
XL
Air Conditioning
Power Steering
AM/FM Stereo
Cassette
ASS (4-Wheel)
Consumer Rated Condition: Good
"Good" condition means that the vehicle is free of any major defects. This vehicle_has a
clean title historv , the paint, body and interior have only minor (if any) blemishes, and
there are no major mechanical problems. There should be little or no rust on this
vehicle. The tires match and have substantial tread wear left. A "good" vehicle will
need some reconditioning to be sold at retail. Most consumer owned vehicles fall into
this category.
Trade-In Value List Your Car For Sale Online $2,715
Trade-in Value is what consumers can expect to receive from a dealer for a trade~in
vehicle assuming an accurate appraisal of condition. This value will likely be less than
the Private Party Value because the reselling dealer incurs the cost of safety
inspections, reconditioning and other costs of doing business.
NEXT STEP: .:' Get New Car Pricing
http://www.kbb.com/kblki.dl1/kw.
Kelley Blue Book - Private Party Pricing Report - Ford, Explorer
Page I of2
.'
.~~~~
, HOMe,
.;""
n,t.75 ':~"~O~l~.>i
NEW CARS -.'Rl:b.ff.'a.;.. - REVIEWS &. RATINGS
"::iI,m~~.!il!1rJJ:.rjJ.....rr.lr;J
advertisement
)0 Se-arm USiilcar Listings
BLUE BOOK" PRIVATE PARTY REPORT
Pennsylvania' May 11, 2005
1994 Ford Explorer Sport Utility 4D
BLUE BOOK CLliSSlfiEi
Seartb U\2d {~l U!lin~,
..
Search Listing". for Tois Car
LJ~tYom".Car For saj!'i.pnline
Quick NeW.,Car Priq;Qqote W
FJfle.C.'\8E6X8-",C9Iq-Cb.~cJ5
Auto Loans from 4.49% APR ". d"
-- a verdsemer
Insurance Quote _"
Print "For Sale" Sign
EajllIlenLC.a.tguJatQ[
QUickly browse throu!
600,000 used vehicle
to find exactly the cal
you want,
Engine: V6 4.0 Liter
Trans: Automatic
Drive: 4WD
Mileage: 72,000
Equipment
XL
Air Conditioning
Power Steering
AM/FM Stereo
Cassette
- ABS (4-Wheel)
Consumer Rated Condition: Good
"Goocl" condition means that the vehicle is free of any major defects. This vehicle-has a
clean title historv. , the paint, body and interior have only minor (if any) blemishes, and
there are no major mechanical problems. There should be little or no rust on this
vehicle. The tires match and have substantial tread wear left. A "good" vehicle will
need some reconditioning to be sold at retail. Most consumer owned vehicles fall into
this category. -
Private Party Value Search Local Listinqs I List This Car for Sale $3,900
Private Party Value is what a buyer can expect to pay when buying a used car from a
private party. The Private Party Value assumes the vehicle is sold "As Is" and carries
no warranty (other than the continuing factory warranty). The final sale price may
vary -depending on the vehicle's actual condition and local market conditions. This
value may also be used to derive Fair Market Value for insurance and vehicle donation
purposes.
Get-a Used Car TradeMln Value
Getlhypi,~~ ,f!! MS_RP,QrLNew J;:.~_C$
Geta Person to Person Auto LQpO
,.,"!i",;!"I~I:""I,'~..IIIi\
http://www.kbb.com/kb/ki.dll/kw.kc.ur?kbb.P A;S94S07;P A041 & 17013 ;+p&722;F ord; f 994%20E... 5/11/2005
.Kelle)' Blue Baak - Trade-In Pricing Repart - Chevralet, Silverada 1500 Pickup
Page I af2
Kelley Blue Book
THETlWSTEt> RESOURCE
~"'">".,'..-~,'"' ~,r--".~lhh,;tGM
'i )'-;""~, ", ,;,.
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NE.W CARS .n~'1::lI."',':f,. -RfVU;:WS &. Rft:TIN(l.S ~ ADVICE ~ nNANCINC &. ,~
. ~:.:J-.r'_]j.;t,~(~~.' a.6i>c;rr!j""
HO"~
, .' . (lurcltD<ar.,p,.",QUOI!>
advertisement
FACT: CHEVY SllVERADO 1/2 TON PICKUPS HAVE A
HIGHER RESALE VALUE THAN FORD OR DODGE:
;:::'~'I{j~ silverado
'1iMed I'liI 1:lMllNul 20011- MY h3ilt.r,:m flllhllt!:e c;e iWItl tU.tlA Jll 2(1),( '!r.lld&~I" 1t.11tJl!l.
BLUE BOOK~ TRADE-IH VAl..UE
Pennsylvania. May 11, 2005
2000 Chevrolet Silverado 1500 Pickup long Bed
Se",rch Listings fer This Car
kj?L'(Q~LC,i'LfQrj:1gj!l,ODJin!l
Qyi~kNElW Carpri,ce Quo.te
fI5).e",.G6B.f_,L\!LReG.Q[.!:Lcl1.e.9.~
Auto. Laans frem 4.49% APR
Insurance Quete
J:IDimen.!,C",lcYl.atar
Engine: V8 4.8 Liter
Trans: Autamatic
Drive: 4WD
Mileage: 60,000
Equipment
Air Cenditioning
Pawer Steering
Tilt Wheel
AM/FM Stereo.
Cassette
Dual Front Air Bags
ABS (4-Wheel)
Sliding Rear Window
Consumer Rated Condition: Good
"Goed" canditien means that the vehicle is free af any majar defects. This vehiclEL-has a
clean title hister'y' , the paint, bedy and interier have anly minar (if any) blemishes, and
there are no. majar mechanical problems. There should be little er no. rust an this
vehicle. The tires match and have substantial tread wear left. A "gead" vehicle will
need seme recenditiening to. be said at retail. Mest censumer ewned vehicles fall into.
this categery.
Trade-In Value List Your Car Fer Sale Online $7,975
Tra~de-in Value is what cansumers can expect to. receive frem a dealer far a trade-in
vehicle assuming an accurate appraisal ef cenditian. This value will likely be less than
the Private Party Value because the reselling dealer incurs the cast ef safety
inspectians, recanditiening and ather casts ef deing business.
NEXT STEP: ," Get New Car Pricing
C1"I'05
-_ 7q15
O\~\O\O
cr6S
f-JCf
8,($ ~ 0
':~.-:~~~~.i~:~';:~j;'~~~l
http://www.kbb.com/kb/ki.dll/kw.kc.ur?kbb.P A;375298;P A041 & 1 70
8;Chevrelet;2000%... 5/11/2005
BLUE BOOK CLAS51F11
lilt r~Ut (ar fOI Sale
For one low price YOt
appear on both kbb.(
cars,com, Plus over:
popular websites.
~
- advertiseme
c~ silve
FACT:
CHEVY OFfE
MORE CREW I
THAN Atn'OI
,Kelley Blue Book - Private Party Pricing Report - Chevrolet, Silverado 1500 Pickup
Page 1 of2
,
. ~1~!!~U~s~~~
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-NEw-CARs ........1::1....f:t:f--..- REVIEWS l,RATINGS :" ADVICE
FlNANC1NG &. It
"~.T3;.i"mu
HOM~
.. .~, > Quid< I)b..aler Pti<O Quote
advertisement
> S..ldlllsod ear Usling.
FACT: CHEVY SILVERADO 1/2 TON PICKUPS HAVE A
HIGHER RESALE VALUE THAN FORD OR DODGE:
~~;:1silverado
"1tu:>l!d MI fihliWul 2004 llA'i hlMoh; rll]f..f1Lti!1 k: lit ;WId tUnA JlI 2(11)4, tl.tu.lb<-It) ~lutl1;,
BLUE BOOK" PRIVATE PARTY REPORT
Pennsylvania. May 11, 2005
2000 Chevrolet Silverado 1500 Pickup Long Bed
aWE BOOK CLASSIFlE:
Sa~tth Used (ar li!lin~~
$earchListings for Th,is Car
Ust You.r. C<!r..EQf.~J~LQ.olin"
Qj.ji9.KJ~eV!'.CarPrjce;Quote
E["sd;:p.,Rf=..M,8!;l.c.QJ1tQl]e9.~
Auto Loans from 4.49% APB
Ins,urance Quote
Print "For Saie" Sign
P,aYJDeDt.Q"lg.4Igtor
Quickly browse thrau!
600,000 used vehicle
to find exactly the cat
you want.
m
"~ advertiselTi~:!r
Engine: V8 4.8 Liter
Trans: Automatic
Drive: 4WD
Mileage: 60,000
Gf..ofbs silve.
Equipment
Air Conditioning
Power Steering
Tilt Wheel
AM/FM Stereo
. Cassette
Dual Front Air Bags
ABS (4-Wheel)
Sliding Rear Window
FACT:
CHEVY OFFE
MORE CREW (
THAN ANYOl\
Consumer Rated Condition: Good
"Good" condition means that the vehicle is free of ",ny major defects. This vehide~has a
clean title historv , the paint, body and interior have only minor (if any) blemishes, and
there are no major mechanical problems. There should be little or no rust on this
vehicle. The tires match and have substantial tread wear left. A "good" vehicle will.
need some reconditioning to be sold at retail. Most consumer owned vehicles falljnto
this category.
Private Party Value Search Local Listinos I List This Car for Sale $9,785
Private Party Vaiue is what a buyer can expect to pay when buying a used car from a
private party. The Private Party Value assumes the vehicle is sold "As.Js" and carries
no warranty (other than the continuing factory warranty). The final sale price may
vary depending on the vehicle's actual condition and local market conditions. This
value may also be used to derive Fair Market Value for insurance and vehicle donation
purposes.
G~.t..Invqi.t;;:E;!,,~,,~$RP on New Cars:
~et .9.J.l2&CE.r Trg.~LS!.:JD_V.9J.bL~
G..~t..a"p'~_[$qn, t9-PSlJ.S9lJ,Au,tQ..,l,0!3JJ
http://www.kbb.com/kb/kLdll!kw.kc.ur?kbb.PA;350723;PA041&1 70 13 ;+p&723 ;Chevrolet;2000... 5/1112005
~, waYROlnt
BANK
WOK FOR US. WE'LL GET YOU THERE.
p.o. Box 1711. Harrisburg. Pennsylvania 17105-1711
MernberFDIC
!
!
LORRIE A JONES
38 CARLTON AVE
CARLISLE PA 17013-3114
STATEMENT OATE
4/10/01
PAGE 1
0090336025
ACCOUNT NUMBER TYPE OF ACCOUNT:
TOTALLY FREE
INTEREST PAID
YEAR TO OATE
ANNUAL PERCENTAGE YIELD
EARNED (APYEJ
DAYS IN CYCLE
30
AVERAGE BALANCE
503.75
PREVIOUS BALANCE
509.48
DATE
3112101
3112/01
3112/01
3112101
3/15/01
3/16/01
3/19/01
3122/01
3122101
3128/01
4103101
4109101
DATE
3112/01
3112/01
DEPOSITS
700.00
INTEREST
.00
ENDING BALANCE
82UO
BALANCE
659.48
629.48
596.70
563.94
513.47
484.54
464.54
326.00
316.00
566.00
521.00
B21.00
WITHDRAWALS
3BB.48
CHARGES
.00
ACTIVITY DESCRIPTION
DEPOSIT
HIDlAND NATIONAL/INSURANCE
CHECK "1103
CHECK "1102
SPRINT-PA(12J/PHONE BILL
CHECK #1105
CHECK #1106
PPIElEC BIll
MIOLANO NATIONAL/INSURANCE
DEPOSIT
CHECK "1104
DEPOSIT
DEPOSITS
150.00
WlTHORAWAlS
30.00
32.78
32.76
50.47
2B.93
20.00
138.54
10.00
45.00
250.00
300.00
CHECK SUMMARY
* indicates skip in check numbers
DATE CHECK NO. AMOUNT
4/03/01 1104 45.00
3/16/01 1105 2B.93
CHECK NO.
1106
AMOUNT
20.00
CHECK NO.
1102
1103
AMOUNT
32.76
32.78
DATE
3/19101
--------------------------Pleas;-reVTe;~our privacy notTce-on-the reverse-STde-or-thTs-statement.
PLEASE NOTE: The Waypoint Super Sa,er interest rate will be updated
monthly instead of quarterly effective June 1. 2001.
Customer Service Toll-Free 1-866-WAYPOINT (I
www.wayp
EXHIBIT
~
ark Area 717/815-4500
JD-502(6/01)
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.' ACH<2T. CtiRUSLE HO" .
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': b>:ii::20 DEPclSn:, "
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T ran Amount P
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, 56&.16~, ,
,":535:1.6 ",,' '
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5000 Louise Drive
PO Box 40
Mechanicsburg, PA 17055
www.members1st.org
Member's
Statement
of Accoant
Account Number
TO
101887 01-01-01 03-31-01 of 1
Page
1",111",111"""11"11",11",,11,,,11,1,,1,,11,1,,1,1,,1,1
LORRIE A JONES
38 CARLTON AVE
CARLISLE
bers}>T
C DIT UNION
(717) 697-1161 or (800) 283-2328
(717) 697-4372 or (800) 283-4372
(717) 697-5312 or (800) 283-2328 ext. 5312
17) 795-6049 or (800) 237-7288
3881
PA 17013-3114
From
JOIN US FOR OUR ANNUAL MEETING
ON SATURDAY, APRIL 21ST AT.8:30
A.M. THE MEETING WILL BE HELD AT
THE NAVAL INVENTORY CONTROL
POINT OFFICER'S CLUB IN
MECHANICSBURG. CALL (717)795-
5128 OR (800)283-2328, EXT.5128
FOR RESERVATIONS.
T!lAiils?
::OATlt?
SUFFIX:OO SAVINGS
013101 DIVIDEND
020201 SHARE WITHDRAWAL
JOINT OWNERS: GERALD W JONES
Y-T-D DIVIDENDS,
TRUTH IN SAVINGS INFORMATION,
ANNUAL PERCENTAGE YIELD / 2.90%
ANNUAL PERCENTAGE YIELD EARNED / 2.87%
~~~ir ...:...:..!\!~ii#~
149.51
149.87
25.87
.36
-124.00
.36
------------------------------------------------------------- ------------
FOR 2001
* IRA YTD * OTHER YTD * TOTAL YTD * TOT
DIVIDENDS DIVIDENDS DIVIDENDS WITH
.00 .36 .36
L YTD t, TOT
OLDING FOR
.00
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L YTD t,
E I TURES
.00
....'.;Y ,'"
H~AlU WJOWES
38 CARL TON AVE
CARLISLE PA 17013-3114
ACCOUNT NUMBER TYPE OF ACCOUNT:
0090B50420
TOTALLY FREE
PREVIOUS BALANCE
71.90
DEPOSITS
.00
" ~
INTEREST PAID
YEAR TO DATE
STATEMENT DATE
3/09/01
ANNUAL PERCENTAGE YIELD
EARNED (APYEl
WITHDRAWALS
.00
DAYS IN CYCLE
1B
,,~ ,I " ,..., ,~~,~"j""~r""W~Jlf
PAGE 1
AVERAGE BALANCE
71.90
CHARGES
.00
Need cash? ApplJ for, Waypoint Lo,n Mond,y through Fridayb,fore
2:00 p.m. anp' we guarantee you a c.redit answer that same day or we'll
pay you 1100.00 in cash! Apply today!
INTEREST
.00
ENDING BALANCE
71.90
,,'
Marital Valu'e of Teamster's Pension
Balance as of January 31, 2005:
less 3/4 of 2001 contributions ($9,566.03):
less 2002 contributions:
less 2003 contributions:
less 2004 contributions:
Value less post separation contributions:
Balance as of Date of Separation (March 31, 2001):
I
EXHIBIT
f
_ ::'1':' "~, ;\. , "r ;~'i"~-\c""",'"' "
[ "
$ 98,076.73
$ 7)70.18
$ 7,138.98
$
pending
$ 83,667.57
$ 62,268.07
, ,w
, "g.i~"'I:,N;'
Jones v. Jones
#01-1579
5/12/2005
~"
,," -'...,',
"';"'/'.'d'~<..."~,;'" '," "'I;?r'
,
'l -'l1
'-" ., , FEB Z 8 200J
Central 'Pennsylvania Teamsters Pension 'Fund
JOSEPH J. SAMOLEWICZ, Admiriisfral6r
Board of Trl,lStees
WILLIAM M. SHAPPELL. Chainnan and Trustee
TOM J. VENTURA, Secretary and Trustee
KEVIN M. C1CAK, Trustee
TIfOMAS K. WOl'RING. Trustee
KEITJj-L. NOLL;-Trustee
PETER. G. HASSLER, Trustee
MIC!l4EL E IW&, "J)"U$tee
HOWARb W. RHiNIER. Trustee
MIKE JONES, Trustee
MARTIN L. CULLEN, ASsistant Adm1nistrator
1055 Spring Street, Wyomissing, PA 19610
Mailing Address: P.O. Box 15223
Reading, PA 19612-5223
Pfu:ine;6JQ.320~5505
TflLLFREEIN PA 1-800-343-0B6
TOLL FREE IN USA 1-800-331-0420
FAX; 61Q.320-9239
......
February 25,2005
Ms. Carol J. Lindsay, Esquire
26 West High Street
Carlisle,PA 17013
RE: Gerald Jones
SSN 205-52-9905
Dear Attorney Lindsay:
We wish to acknowledge receipt of your February 22,2005 letter regarding the above-
named Member.
Please be advised that Mr. Jones was not a participant under the Central PA Teamsters
Pension Fund until June 1, 1994. Therefore, there was no balance, under the Defmed Benefit
Plan or Retirement Income Plan 1987, as of July 5,1982. His balance, as of March 31, 2001,
was $62,268.07. His current balance, as of January 31, 2005, is $98,076.73. This balance does
not include any net gains or losses received after that date. Since the Fund was only valuated on
a quarterly basis prior to February, 2004, we are unable to provide you with a balance on the
exact date that you are requesting.
Please note tliat Mr. Jones is also covered under the Defined Benefit Plan effective
January 1, 2003. He is currently earning a monthly benefit that is equal to 1.25% of the total
contributions submitted on his behalf from January, 2003 forward. He currently has accrued a
benefit of$154.54 per month through January, 2005.
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Enclosed, herewith, please find a computerized copy of Mr. Jones' annual statements for
2001 through 2003. The2004statenient wiUbelnailed to allpaiticipartts beforeJune30, 2005.
If you would have MY additional questions, please feel free to contact the Pension Fund
Office.
We trust this information is sufficient.
Very truly yours,
Central Pennsylvania Teamsters
Pension Fund
~\\~.
Michelle Houck
Pension Benefits Manager
Enclosures
2001 Annual RIP 198~ Statement
04/04/2002
205-52-9905
JON.ES -GERALDW
38 GARLTON AVE
CARLISLE PA 17013
1. BIRTH DATE - 10/03/1960
2. SPOUSE NAME - LORRIE ANN JONE,S
3. SPOUSE BIRTHDATE- 07/22/1961
4. SPOUSE SOCIAL SECURITY NO. - 184~50-1623
5. R1CPORTED ,DATE or BIR1C - 06/02/1994
6. VESTED STATUS - 100% V1CSTED
7. ESTIMATED NORMAL RETIREMENT DATE - 11/01/2017
9. LATE CONTRIBUTIONS/ADJUSTMENTS TO PRIOR YEARS
225.30
10. DETAIL OF ACCOUNT ACTIVITY:
A. ACCOUNT BALANCE AS OF 12/31/2000 -
'B. CONTRIBUTIONS RECEIV1CD DURING 2001 -
C. NET EARNINGS ADD1CD DURING 2001 -
D. AGCOUNT BALANCE AS OF 12/31/2001 -
65,012.81 * INCLUDES #9
9,566.03
2,048.18-
72,530.66
RATE OF R1CTURN OF TOTAL FUND FOR 2001
CF6 - Main Selection
11. GROSS -3.10 % 12. NET -3.40 %
CF7 - Year Selection
,
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2002 Annual RIP 198" Statement
05;\3/2003
205-52-9905
oONES nGERALll WU
38 CARLTON AVE
CARLISLE PA 17013
1. BIRTH DATE - 10/03/1960
2. SP-OgSENAME -LORR-IE ANN JONES
:;1. SPOPSE I3IRTllDATE -07/22/1961
4. SPOUSE SOCIAL SECURITY NO. - 184-50-1623
5. REPORTED DATE OF HIRE - 09/02/1994
6. VESTED STATUS - 100% VESTED
7. ESTIMATED NORMAL RETIREMENT DATE - 11/01/2017
9. LATE CONTRIBUTIONS/ADJUSTMENTS FOR PRIOR YEARS
.00
10. DETAIL OF ACCOUNT ACTIVITY:
A. ACCOUNT BALANCE AS OF 12/31/2001 -
B. CONTRIBUTIONS RECEIVED DURING 2002 -
C. NET EARNINGS FOR 2002 -
D. ACCOUNT BALANCE AS OF 12/31/2002 -
72,530.66
7,138.98
5,748.63-
73,921.01
* INCLUDES #9
OPT 2 2,422.39
RATE OF RETURN OF TOTAL FUND FOR 2002
CF6 - Main Selection
11. GROSS -7.30 % 12. NET -7.60 %
CF7 - Year Selection
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2003 Annual RIF 1987, Statement
04/20/2004
205-52-9905
JONES GERALD W.,
38 CARLTON AVE
CARLISLE PA 17013
1. BIRTH DATE - 10/03/1960
2. SPOUSE NAME- LORRIE AN}! ,IONES
3. SPOUSE BIRTHDATE - 07/22/1961
4. SPOUSE SOCIAL SECURITY NO. -' 184-50-1623
5. REPORTED DATE OF HIRE - 06/02/1994
6. VESTED STATUS - 100% VESTED
7. ESTIMATED NORMAL RETIREMENT DATE - 11/01/2017
9. LATE CONTRIBUTIONS/ADJUSTMENTS FOR PRIOR YEARS
.00
10. DETAIL OF ACCOUNT ACTIVITY:
A. ACCOUNT BALANCE AS OF 12/31/2002 -
B. CONTRIBUTIONS RECEIVED DURING 2003 -
C. NET EARNINGS FOR 2003 -
D. ACCOUNT BALANCE AS OF 12/31/2003 -
73,921.01
.00
13,335.63
87,256.64
* INCLUDES #9
OPT 2 .00
RATE OF RETURN OF TOTAL FUND FOR 2003
CF6 - Main Selection
11. GROSS 17.70 % 12. NET 17.40 %
CF7 - Year Selection
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, . 2003 Estimated Defined .Benefit Statement
"1': 'Participant/spouse Info.
205-52-9905
,JONESGERALDWu
38 CARLTON AVE
CARLISLE PA 17013
. 05/0b/2004
1. BIRTH J2l\TE,. -u JD/03/19EiO,
2. REPORTED DATE OF HIRE - 06/02/1994
3.' VESTED STATUS -100% VESTED
4. SPOUSE NAME - LORRIE ANN JONES
5. SPOUSE BIRTHDATE - 07/22/1961
6. SPOUSE SOCIAL SECURITY NO. - 184-50-1623
II. Benefit Accruals through
Monthly Benefit
12131/1993
Plan Normal
I
Retirement Date
00/00/0000
III.
Future Service
Contributions
5,632.59
Benefit Accruals
Multiplier
1.25%
Summary for 2003
Monthly Benefit
70.41 ($140 CAP)
Normal Retirement Date
11/01/2025
CF6 - Main Selection
CF7 - Year Selection
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Tax Deferred Annuity
STATEMENT
Annuitant
GERALD W JONES
Policy Number Policy Date
255145 03/23/1 994
Plan Type
IRA
Plan Name
Alliance PO
T axpaye r LO,
205-52-9905
4,20% Interest
Rate Guaranteeo
To 03/28/2002
This statement is for your
personal infonnation and is not
to be filed for income tax
purposes. The accumulated
interest is tax deterred and is
not reportable until withdrawn.
All interest rates are effective
annual rates.
~-.
AMERICAN /lNvEsTORS
-r rJffilN.<;l.JlV,NCliCOMPMff.INC-
A. AMER[IS "'mp"""
5555. K3nsas Avenue. P.O. Box 2039
Topeka, KS 666U1-2039
(785) 232;6945 . (785) 295-4495 Fax
,
GERALD W JONES
38 CARLTON AVE
CARLISLE PA 17013
Beginning Account Balance 03/28/2000..........~...................... $5,687.89
Additional Premium Deposited .....................:............................. $0.00
Interest Earned ....................................................................... $244:57
Withdrawals... ........................................................................ ..... $0:00
Emling Account Balance 03/28/2001 ......................................$5,932.46
Net Cash Surrender Value (account balance less applicable surrender
charges) as of 03/28/2001 is $5,635.84 and~s of 03/28/2000 was
$5,346.62. The difference between the Net Cash Surrender Value and
the Ending Account Balance is the surrender charge you would have
incurred if you had surrendered your policy as of 03/28/2001.
American Investors Life Insurance Company, Inc. is a national
provider of retirement annuities. Fixed annuities combine the
ad"antagAs of hv_rlt:::.farro::aI with nrnto'f'ticn from- ~orvnt "I'col/ 1"'''_
"" oJ i.tA.oo\ .......v......... ..'" ,.... v~vV' " ,I 11 IiIU 1'\"".. 10.1". l"^.
deferral means you pay no current income taxes on interest earnings
in your annuity until you actually withdraw those earnings. Maximize
the earning power of your dollars through the advantages of tax.
deferral!
If you have questions, please contact our Home Office at
(800) 435-4884.
EXHIBIT
IG
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,
Year-to-Date Statement
January 1 . 2001 - March 3 I . 200 1
PUT N AM INVESTMENTS
GERALD W JONES
38 CARLTON AVE
CARLISLE PA 17013-3114
IClientnumber. 0335519073,1
Investment finTI:
HACKETT ASSOCIATES
Representative:
MR. TROY H. LANDIS
Representative phone number. 1-717-245-9522
For Putnam assistance: 1~80o-225-15al
www.pumaminvestments.com
"!?talvalue of
your portfolio
a80f 3/31/2001
" '<'v" '.'.
.."..~-:.......u.....................
.~.; $1,967.79
The Spring issue of Putnam EDGE provides perspective on the continuing volatility in the financial markets. Steven Orisraglio, Putnam's
Deputy Head of investments, discusses the ,ecent downturn and his outlook for the remainder of the year. Also in EDGE. what do
proposed new IRS regulations mean for your IRA?
SUMMARY OF ACCOUNT INFORMATION U.n..ry I. ~001 - March 31. ~OOI)
Tl"'aditionallRA
Fund n~e ,:;,' '/'.. .:;, '., ::'; . "
, , .'"
-.': -~" .. ,
Beginn~~g balance Additions
.(,." of 111}2001) " 'Year-to.date,
'Withdrawals" .
. 'Y~ar.to-da~::
,':.:hange in,.vaJu~~:, 1,' Total value"
""y'ear-tO-dab;;"'~''': "(<l;S,of31l1~QOI)
, " ~. -'" '-"._,,...
Puwam Utilities Gr'&: Inc Cl~A'
$2. I 52.4()
$0.00
$0.00
$0.00
$0.00
T o't3.l year to date
$2,152.40
- $184.61
$1.967.79
$1.967.79
T otaI for the quar1:er
Uanuary I M March 31)
$2.152.40
$0.00
$0.00
-$184.61
$1.967,79
IRA contributions for tax. year 2000
SO.OO IRA contributions for tax year 200 I
$0.00
,ACCOUNT ACTIVITY ,
EXHIBIT
\\
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Health Managemem Associates, Inc.
5811 Pe~can Bay Blvd
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Naples FL 34108-2711
Your Retirement Plan Financial StatemelitF;r~;P;j~dl0/1/2001-11J31i2001 Pogel
HEALTH MANAGEMENT ASSOCIATES RETIREMENT SAVINGS PlAN
lORR I E A JONES
408B WALNUT STREET
BOiliNG SPRGS PA 17007
Soc. Sec. Number.
.JirthDote:
- Dote of Hire:
____'pton Enlri Dote:
... , Location:
- -- Slolus:
184-50-1623
- 7/21/1961
7/31/1978
5/24/2001
858
ACIIVE
Plan Information That You Should Know
Logon to AnswerNet and make your retirement dreams come true. Financial Planner is a 401(k) financial
modeling/guidance tool that allows you to input all of your savings amotmts and get guidance on how you
should allocate your 401(k) contributions to the plan to achieve your retirement goals. To access Financial
Planner, logon on to www.cigna.com and choose AnswerNet. Financial Planner is located under 'Planning
Tools'. If you have questions on this product, please call AnswerLine at 1.800.253.2287 and speak with a
Retirement Accotmt Representative.
Your Account Summary
Your Plan ContnautloD Summary eomributfoas CoatribtrtiollS
lIIi,rer!od lWsfear
Your Contributions
EE PRE TAX $154.78 $254.12
Sublolol $154.78 $254.12
Company Contributions
CO STOCK MATCH $51.60 $84.71
Subtotal $51.60 $84.71
.tlli.~~IOQ.tt7'~tj
Change Ihis Period
;:::::::::::::;::::~;;
""""""$''''1'3;''1'''')$''''
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$202.61
(Giii!IiI.~tI~.lllZtQlillm@(:i:n$~~;;~f
Currenl Vested 8010nce $336.36
Your Port/olio Composition
By Investment Category
~ Guoronleed 76%
o Fixed Incom. 0%
II Boloncod 0%
!Ii Lorge Compony Stock 0%
~ Mi"",, Corr.p<lllY Sted< 0%
II \moll Compony Stock 0%
[]]] G1obo1/Foreign Stock 0%
IlIIII Olb" 24%
Ti\WI{~";rIDrttQ~llmM;:miIH:mMiiljll;:m~.iji;MM;i;$$.t.;t
R
This stolemenf mllY not reflecfyour recenffransadions and is bos edonprkesprovidedbylhird pllrly vendors IlS of the .
issuance of this statement. Any changes reported fo us in. unil(s~are vlllu~s subsequ~ntto the iS5ua.nce of this statement wIll,
be reflected in your next Financial Statement. Please venfy thiS mformotlon and notify your Benefits Manager or call CIGNA 5
AnsweTline@ifyoul1aveanyqueslions.
lIlD OGNA'sAnswerLine@ Ir::::1I OGNA Webs/te
/ill 1-800-253-2287 ~ www.cigna.com
CIGNA Retirement &
Investment Services
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HEALlH MANAGEMENT ASSOQAnS
--:lO/1/2001 -12/31/2001
. :::.=LORRIEJONES'=.:-
184-50-1623
. .,~~Page 3
Your Plan's Inv.stment Perlormanc.
lIisPeriod Siaat-,I r.Yaor mhod
011. Year ThreeT_ ' IlveY.. Siaatilaplfoo iIapIfooDatt
GUARANtIED
**GUARANT INCOME 1.48% 5.98% 5.98% N/A N/A N/A
FIXED INCOME
STSTBONDACCT -0.21% 8.44% 8.44% 6.11% 6.85% 6.85% 12/1/1996
BAlANCED
BAVMORGST,SSGA 7.25% -5.68% . -5.68% 3.69% 9.37% 10.96%
LIFETIME 20 11.24% -8.92% -8.92% 3.88% N/A 4.02% 4/30/1994
LIFETIME 30 10.00% -6.55% -6.55% 3.83% N/A 4.09% 4/30/1994
LIFETIME 40 8.76% -7.09% -7.09% 3.08% .. N/A 3.69% 4/30/1994
LIFETIME 50 7.52% . -4.21% -4.21% 3.09% N/A 3.84% 4/30/1994
lIFETlME60 4.15% -0.28% -0.28% 3.51% N/A 5.74% 4/30/1994
lA,RGE COMPANY sroCK
LG GROW/MORG ST 12.35% -15.18% . -15.18% 1.23% 10.11% 13.35%
LG VAVLEVIN 12.70% -3.72% -3.72% 8.67% 13.15% 15.65% 8/1/1997
5&P 500 INDEX 10.61% -12.13% -12.13% - 1.30% 10.39% 12.61%
MIDSIZE COMPANY STOCK
MD GROW/ARTISAN 24.77% -2.40% -2.40% 25.95% 30.66% 25.40% 5/31/1997
MD VAI,iWELL MGT 20.83% 8.90% 8.90% 17.65% . N/A . 16.75% 9/29/2000
SMALL COMPANY STOCK
SM GROWIH/lSCM 20.50% .8.86% -8.86% 16.39% N/A 14.43% 12/4/1997
SML VAVBERGER 26.28% . 21.85% ' 21.85% 22.45% 20.96% 19.91%
GL08AVFOREIGN STOCK
INT 8LD/8K IRE!. 7.47%. - 20.04% . 20.04% - 1.77% N/A 2.13% 12/5/1997
OTHER
HMA COMMON SIK - 11.37% - 11.33%' -11.33% -5.24%., 12.97% 23.49%
The returns quoted are net of investment-related fees and charges as well as current contract charges (includlngasset charges).
The actual rate of return for your account may differ from these results depending on the timing and amount of your
contrihutions and other transactions processed within your account, and whether contract charges have been higber or loWer
in the past. Historical returns reflect either actual account performance or a combination of actual account performance and
the investment manager's composite. which may consist of one account. Investments in the market.valued funds are subject to
tbe risk and rewards associated witb the securities market.
"NIA" indicates the fund was not In existence or data was not availahle at the time the statement was printed.
-rnEANHUAlIIII(!JVEYIIlD IDRlHEGUARAIIIEElIIHCDME ~6.DII%.
II
This statemenl may not reflectyouf lecenl Iransocfions and is bnsedon prkesprovided by Ihird party vendors CIS of Ihe
issuance of this statement. Any changes reported 10 us in. unil(s~are valu.es subsequ~nt to the issu~nce of this statement will,
be reflected in your next Financial Statement. Please verify thiS IIlformahon ond notify your Benehts Manager or call C1GNA s
AnswerUnei!l if you have any questions.
1limi\Il' CIGNA'sAnswerLlne@
III . 1-800-253-2287
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CIGNA Retirement &
Investment Services
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Rea~g ,Your Statement.
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Your Account Sununary
Opening Balance represents the V'.uuc: of your accOUnt as of the bc:ginning of the
statement period.
Closing Balance represents the v-Jlue of your accOUnt as of Lhe end of the
statement period.
Change This Period represents the difference between your Opening and
Cosing Balances. It represents the net clumge to your account for the statement
period.
Current Vested Balance represents the total amOUnt to which you would be
entided if you left yoUr current employment as of the end of the statement period.
Note if you were DOl 100% \'t!sted at the time you separated ftom service,
additional employer contributions made to your account will be subject to the
vesting at the time of separation from service. Therefore, your aCCOunt may
i.nclude noIP9t:sted dcllius, wbich will be removed from your attount upon the
distribution of your additional vested dolla.rs.
Your Plan ContribUtion Swnmary
Contributions ThIs Period are dollars received and deposited imo your accoum
during the statement period.
Contributions Tb/$ Year are dol1ars received and deposited imo your accOUnt
during the calendar year. Due to payroll timing, the figure here may not mateh the
W~2 provided by your employer at the end of the calendar year.
Your Portfollo Composition
This secpon graphically shows the W"d.y in which your ai:coUnt is cum:ndy invested.
It shows the percentage of your total accoum balance in each investment category.
Stable Value represents accounts invested principWly in high-quality fixed
income instrUments, such as intermediate term 'bonds and commercial mongages.
Tbe interest r.\te is declared periodically, and guarnnteed for a swed period.
Fixed Income represents funds dlat seek to invest in one or more types of bond
or fixed income securities such as corporate or govemmem debt obligations.
Fixed income funds typically generate a ponion of their total rerum by interest
payments.
Balanced represents funds that seek to invest a portion of their assets in bonds
and swcks to obtain the highest return consistent with a low-risk Strategy. A
balanced fund typicilly does not experience the Cull volatiUty of the stockmarket.
Large Cap Stock represents funds dIal seek to invest in companies "ith a market
capItalization of more than $5 billion. Stocks in these companies generally offer
the potential for long.tenn capital. appredation and may paydividentls.
Mid Cap Stock represents funds that seek to invest in companit:S with a market
capitali7.ation of'3 billion to $10 billion. Stocks in midsize companies generally
provide more potential for growth than large cap stocks, but may fluctuate more in
value. .
SmaU Cap Stock Small Cap Stock represems funds that seek to invest in
companies wim a market capita1i7.ation of less than $3 billion. Stocks in these
companies generally have a higher degree of risk and more vo1at:ile re[UtOS than
large or mid cap srocks.
Global/International Stock represents funds that seek to invest in companies
outside the Unired SmteS. International stock funds invest nearly 100% of their
assets in non-U.S. companies; Global stock funds invest in both non.U.S. and U.S.
companies.
Other represents investments in your company's stock. or other special equity
funds.
You: Account's (n\-'estmen[ PetfoniilUlCe
Your personali7.ed r;t.te of return is caJculared using:l doUar.weighted fonnula, a
fonnula used by various financ1al analyslS to calculate the investment earnings of a
portfolio. Your Ac.count's Investment Performance takes Into consideration your
Opening and Closing Balances, and cash activity such as contributions, loans, and
withdrawals, on the date the uansaction occuned. Other personal rate of return
calculations may yield different results.
Your Current Investment Elections
This section shows how you have chosen to direct your future contributions into
the various investment options offered within your plan.
This section also ineludes your percent vested, or the percent of your account
balance to which you are entitled as of this smtement period. You are always 100%
vested in your own cpntributions and earnings on those contributions.
Note U 'jQu were not 100% pelttnt vested at the time you seParated from service,
additional employer contributions made to your account will be subject to the
vesting at the time of separation from service. Therefore, your accOUnt may
include non.vested dol1ars, which wiU be: removed from your account upon the
distributiOn of your additional vested dollars.
Your Expense Sum.mary
This section reflects any tranSa.Ction-rela.red charges. in addition, thisscction
reflectS the commissions and/or fees chouged by an inVCSbllcm manager for - ~~
movement into orout of an investment option. ,_
Your Activity Sununary
Opening Balance represents the value of your account:lS of the beginnlngof the
statement period. ,',~'-"- ,~
Additions to Account are deposits made to youra.ccount during the statemePt
period. If applicable to your plan this would Include, but is not limited to, ,_
contributions, loan repayments, forfeiture reallocations, and lnlnsferred assC:ts.
Deductlonsfrom Account reflects deductions made from your accoont during
the statement period. This would include, but is not limited to, loans, expenses,
forfeitUres and distributions.
Tran~ers.from!to Account reOeas money movement you have directed
between investment options during the statement period.
Changes in Value reOect any dividends, e2111ingS, investnlem gains andlor losses
incurred during this statement period.
Clostng Balance represents the value of your account as of the end of the
statement period.
:Vour stock StunD1ib'y
Opening Shares represent the total number of shares held in}Uut invesanents
as of the beginning of the statement period.
Contributions: are the number of stw1::s received and deposited into )!Our
account during the statement period.
Deductions retlect shares removed from your account during the statement
period, as a result of a withdrawal. tranSfer, or loon. Deduaions as a result of
expenses are reflected in Your Expense Summary.
Loans reflect the change in shares resulting from loan grants, loan repayments,
and defaulted loans.
Croslng Shares are the total number of shares held in your investments as of the
end of the statement period.
Uninvested Casb reflects pending investments.
Per Sbare Value represents the v-ollue per share as or the-end oflhe smtement
period.
Market Value is the total. doUarvaiue of your investment as of the end of the
statement period, It is calculated by multiplying the closing share price by the "
closing share balance. This figure does not include any uansactions pelldin8 -
settlement. -- .-- --,
Your plan's la1>'eStment Pedormaace
This section provides historical fund ~I investment performance information for
all im-estment options offered within your plan by investment category. ' -" ,
Fund Inception Data represents either the date that: assets were fust invested in
a fund or the date a fund manager initiated the class of shares.
II
This statement may not reflect your recenttransadions and is based on prices provided by fhir~ party venda.fs as of the .
issuance of this statement. Any changes reportedta l,lsin unit/share values sl,lbsequent to the rssuance of thIs statement Will
be reflecte~ in your next Finomial Statement Please veTlly this information al\~ l\olif'j 'jOU( Renefi1s Mtmllget tlt {oil CIGHi\'s
AnswerUne@jf'jouhaveonyquestions.
"/'if CIGNA'sAnswerLine@
;,; 1-800-253-2287
CIGNA Retirement &
Investment Services
Sl
..........
CIGNA Websile
www.cigna.com
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CASE:
CIVIL ACTION - DIVORCE
No. CIVIL TERM
Date: Aua. 4. 2003
INCOME AND EXPENSE 5TA TEMENT
THIS FORM MUST BE FILLED OUT
INCOME STATEMENT OF: LORRIE JONES
I VERIFY THAT THE STATEMENTS MADE IN THIS INCOME AND EXPENSE STATEMENT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS
HEREIN ARE SUBJECT TO THE CRIMINAL PENALTIES OF 18 PA.C.S.s4904, RELATING TO UNSWORN FALSIFICATION TO AUTHORITY.
AUGUST 4. 2003
LORRIE JONES,
DATE
PLAINTIFF/DEFENDANT
INCOME:
EMPLOYER: SODEXHO
ADDRESS: CARLISLE. P A
TYPE OF WORK: LABORER
PAYROLL NO.
GROSS PAY PER PAY PERIOD $
PAY PERIOD (WKLY. BI-WKLY., ETC.)
ITEMIZED PA YROLL DEOUCTlONS
FEDERAL WITHHOLDING SOCIAL SECURITY LOCAL WAGE TAX
STATE INCOME TAX RETIREMENT SAVINGS BONDS
CREDIT UNION LIFE INSURANCE HEALTH INSURANCE
OTHER DEDUCTIONS UNION DUES OPTI-WAGETAX
(SPECIFY)
TOTALS
NET PAY PER PAY PERIOD $
Service Type
Page 1 of 5
Form IN - 008
Worker 10
i~~'ll!'
, '"....,......'.,'".,', .,....',.,',
...i,'
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Income and Expense Statement
PACSES Case Number:
Other (All in Appropriate Column)
Income WEEK MONTH YEAR
INTEREST
Dividends
Pension
Annuity
Social Security
Rents
Royalties
Expense Account
Gifts
Unemployment Compo
Workmen's Compensation
IRS Refund
Other
Other
TOTAL INCOME
EXPENSES (Fill in Appropriate Column)
WEEK MONTH YEAR
HOME
Mortgage/Rent 535.00
Maintenance 35.00
Utilities
Electric 75.00
Gas
Oil
Telephone 100.00
Service Type
Page 2 of 5
Form IN - 008
Worker 10
~",-,,, -
-<
<L
ci '~
Income and Expense Statement
PACSES Case Number:
EXPENSES (Fill in Appropriate Column)
continued WEEK MONTH YEAR
Water 20.00
Sewer
EMPLOYMENT
Public Transportation
Lu nch 60.00
TAXES
Real Estate
Personal Property
Income
INSURANCE
Homeowners
Automobile 40.00
Life
Accident
Health
Other
AUTOMOBILE
Payments
Fuel 120.00
Repairs 20.00
MEDICAL
Doctor
Dentist
Orthodontist
Service Type
Page 3 of 5
Form IN - 008
Worker 10
Income and Expense Statement
PACSES Case Number:
EXPENSES (Fill in Appropriate Column)
continued WEEK MONTH YEAR
Hospital
Medicine 225.00
SpecialNeeds(gmsse~
braces, orthopedic devices)
EDUCATION
Tutoring 25.00
College
Religious
.
PERSONAL
Clothing 60.00
Food 445.00
Barber/Hairdresser 30.00
Credit payments: 60.00
Credit Card
Charoe Account
Memberships
LOANS
Credit Union
MISCELLANEOUS
Household help
Child Care 300.00
Papers/Books/Magazines
Entertainment 60.00
Pay TV .
Vacation
Service Type
Page 4 of 5
Form IN - 008
Worker 10
. .
~'" ~1iI~ ~',"'T. i';1
Income and Expense Statement
PACSES Case Number:
EXPENSES (Fill in Appropriate Column)
continued WEEK MONTH YEAR
Gifts
Legal Fees 50.00
Charitable Contributions
Other: Child Support
Alimony Payments
OTHER:
Cell phone 50.00
Children's extra-curricular 20.00
activities
Life Insurance 45.00
Total Expenses
Service Type
Page 5 of 5
Form IN - 008
Worker 10
( . "
. .
I
.. 49"~- $:!:~t~_ Street", . . _ . ,__
Harrisburg,P,mrisylvania 1711)1
'''---717:232:6300''-- ..' ...-..........
. FAX 717.232.6467
www.srklaw.com
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April 11, 2005
Carol J. Lindsay, Esquire
Saidis, Shuff, Flower & Lindsay
26 West High Street
Carlisle, PA 17013
Re: Gerald Jones - Personal Injury Case
Dear Ms. Lindsay:
In response to your letter requesting information with respect to Mr. Jones'
personal injury claim, please note he received a check in the amount of
$17,321.50 for the third party settlement with Foremost Insurance., and an
additional sum of $32,167.11 from the VIM settlement with Penn National
Insurance. . .. ................. .............._..........
...,.,,~' .' ."......'..:.;'-,~ "_':;~"""-.."."q,",~ -:.-:,'';'''''''~'''''"''"'"'"'
In addition, we are currently in suit with Foremost Insurance in Dauphin
County on a coverage issue. Briefs have been filed and we are waiting for a
decision from the court. .
I hope this letter satisfies your requirements with respect to this case.
KRAMER, P.C.
CESI ksd
cc: Gerald W Jones
EXHIBIT
I K
14064905112005
PYS510
2001-01579
l"ii,
Cumberland County Prothonotary's Office
Civil Case Print
Page
1
.
.
. . ,
JONES LORRIE ANN (vs) JONES GERALD WADE
Reference No. . :
Case Type.....: COMPLAINT - DIVORCE
Judgment...... .00
J1,1dge Assigned:
Dlsposed Desc. :
------------ Case Comments -------------
Filed........ :
Time......... :
Execution Date
Jury Trial. . . .
Dtsposed Date.
Hlgher Crt 1.:
Higher Crt 2.:
3/19/2001
2:53
0/00/0000
0/00/0000
********************************************************************************
General Index Attorney Info
~~N~~N~g~~~ER~ PLAINTIFF KOPECKY JOHNNA J
CARLISLE PA 17013 LINDSAY CAROL J
JONES GERALD WADE DEFENDANT
38 CARLTON AVENUE
CARLISLE PA 17013
********************************************************************************
* Date Entries *
********************************************************************************
3/19/2001
3/27/2001
8/08/2001
8/08/2001
9/22/2003
9/25/2003
10/07/2003
10/16/2003
10/23/2003
12/29/2003
12/31/2003
9/23/2004
9/23/2004
9/29/2004
FIRST ENTRY
COMPLAINT - DIVORCE
-------------------------------------------------------------------
AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO PA R C P 1920 A 1 II FOR
COMPLAINT IN DIVORCE - BY JAMES J KAYER ESQ
-------------------------------------------------------------------
PRAECIPE FOR WITHDRAWAL OF APPEARANCE FOR PLFF BY JAMES J KAYER ESQ
-------------------------------------------------------------------
PRAECIPE FOR ENTRY OF APPEARANCE FOR PLFF BY JOHNNA J KOPECKY ESQ
-------------------------------------------------------------------
PETITION FOR SPECIAL RELIEF CAROL J LINDSAY ESQ
-------------------------------------------------------------------
ORDER OF COURT - DATED 9/25/03 - IN RE PETITION - A RULE IS ISSUED
ON RESPONDENT TO SHOW CAUSE WHY THE RELIEF REQUESTED SHOULD NOT BE
GRANTED - RULE RETURNABLE AT A HEARING SET FOR 10/6/03 AT THE
COURTHOUSE AT CARLISLE PA AT 11:15 AM IN CR 4 - BY THE COURT KEVIN
A HESS J COPIES MAILED
-------------------------------------------------------------------
ORDER OF COURT - DATED 10/6/03 - IN RE PETITION FOR SPECIAL RELIEF
- IT IS DIRECTED THAT THE RESPONDENT ATTEMPT TO REFINANCE THE
MARITAL HOME SO THAT THE DEBT THEREON WOULD BE IN HIS NAME ALONE -
BY THE COURT KEVIN A HESS J COPIES MAILED 10/7/03
-------------------------------------------------------------------
AGREEMENT AND STIPULATO OF COUNSEL IN RE PETITION FOR SPECIAL
RELIEF - BY LINDSAY GINGRICH MACLAY ESQ AND KARL E ROMINGER ESQ
-------------------------------------------------------------------
ORDER ADOPTING STIPULATION OF THE PARTIES - DATED 10/22/03 - IN RE
PETITION FOR SPECIAL RELIEF -IT IS HEREBY ORDERED AND ADJUDGED AND
DECREED THAT THE TERMS CONDITIONS AND PROVISIONS OF THE FOREGOING
STIPULATION DATED 10/14/03 ARE ADOPTED AS AN ORDER OF COURT - BY
THE COURT KEVIN A HESS J COPIES MAILED
-------------------------------------------------------------------
PETITION TO COMPEL DISCOVERY - BY CAROL J LINDSAY ESQ
-------------------------------------------------------------------
ORDER OF COURT - DATED 12/31/03 - A RULE IS ISSUED UPON THE
RESPONDENT TO SHOW CAUSE IF ANY WHY HE SHOULD NOT BE REQUIREED TO
PROVIDE THE DISCOVERY REQUESTED - RULE RETURNABLE 20 DAYS AFTER
SERVICE - BY THE COURT KEVIN A HESS J COPIES MAILED
-----------------------------------------------------------.--------
AMENDED COMPLAINT IN DIVORCE ADITIONAL COUNTS EQUITABLE
DISTRIBUTION - AND ALIMONY COUNSEL FEES AND COSTS - BY CAROL J
LINDSAY ESQ
-------------------------------------------------------------------
PETITION FOR A RULE ABSOLUTE AND HEARING - BY CAROL ,J LINDSA Y ESQ
-------------------------------------------------------------------
ORDER - DATED 9/28/04 - IN RE PETITION FOR A RULE ABSOLUTE AND
HEARING - ~ BRIEF ARGUMENT ON THE WITHIN PETITION FOR A RULE IS
SET FOR 12/2/04 AT 2:00 PM IN CR 4 CUMBERLAND COUNTY CARLIS"E PA -
BY THE COURT KEVIN A HESS J COPIES MAILED
-------------------------------------------1 I EXH~ 1-------
14064905112005
PYS510
2001-01579
~'-
~ - ~~~
Reference No. . :
Case Type.....: COMPLAINT - DIVORCE
Judgment..... .
Judge Assigned:
Disposed Desc.:
------------ Case Comments -------------
12/10/2004
12/06/2004
12/06/2004
12/15/2004
~. "'~w;!';._:
Cumberland County Prothonotary's Office
Civil Case Print
Page
2
MOTION FOR APPOINTMENT OF MASTER
.
. . . ~
JONES LORRIE ANN (vs) JONES GERALD WADE
DIVORCE
TAX ON CMPLT
SETTLEMENT
MASTER'S FEE
DIV PA SURCHG
JCP FEE
ADD'L COUNTS
JCP FEE
ADD'L COUNTS
JCP FEE
ADD'L COUNTS
JCP FEE
35.00
.50
5.00
125.00
10.00
5.00
10.00
10.00
10.00
10.00
10.00
10.00
.00
Filed........ :
Time......... :
Execution Date
Jury Trial. . . .
Disposed Date.
Higher Crt 1.:
Higher Crt 2.:
3/19/2001
2:53
0/00/0000
0/00/0000
35.00
.50
5.00
125.00
10.00
5.00
10.00
10.00
10.00
10.00
10.00
10.00
240.50
TRANSCRIPT OF PROCEEDINGS HELD BEORE KEVIN A HESS J THURSAY
12/02/04 IN CR #4 THE FORDGOIN RECORD OF THE PROCEEDINGS ON THE
HEARING IS HEREBY APROVED AND DIRECTED TO BE FILED KEVIN A HESS
JUDGE
ORDER OF COURT IN RE PETITION FOR A RULE ABSOLUTE AND HEARING
12/02/04 ACTION ON THE WITHIN PETITION IS DEFERRED IN ACCORDANCE
WITH THE AGREEMENT ENTERED INTO BY PARTIES IF THIS MATTER IS NOT
RELISTED FOR HEARING WITHIN SIXTY DAYS THE PETITION TO BE DEEMED
DISMISSED WITHOUT FURTHER ORDER OF COURT KEVIN A HESS JUDGE
COPIES MAILED 12/06/04
-------------------------------------------------------------------
ORDER APPOINTING MASTER - DATED 12/15/04 - E ROBERT ELICKER ESQ -
BY THE COURT - GEORGE E HOFFER PJ
- - - - - - - - - - - - - - LAST ENTRY - - - - - - - - - - - - - -
********************************************************************************
* Escrow Information *
* Fees & Debits Beq Bal Pvmts/Adi End Bal *
*****************************************~**************************************
240.50
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
------------
.00
********************************************************************************
* End of Case Information *
********************************************************************************
O'
',,"'
,
Income andExpe~se Statement
September 16, 2005
Plaintiff: Lorrie A.Jones
Defendant: GeraldW. Jones
PACSES Case No. 850103327
Docket No. 00270 S2001
IncOme Statement of Gerald W. Jones
Employer: ABF Freight Systems
P.O. Box 10048 .
Fort Smith, AR 72911c0Q48
Work: Truck Driver .
Net Pay per Pay Period $ 835.82
. Gross Income-$39,624.00 per year (2004 tax return)
Payroll Deductions: Credit Union-$60.00
PAOcc. pry. $10.60 a year
Union Dues-$53.00
Expenses: .
Support-$348.61-a Month
Home
Mortgage:
Maintenance
Monthly
$550
$300
Year
Utilities
Electric: '
Oil:
Telephone:
Water/Sewer:
$l20
$350
$80
$ll5 Every 3 Months
Insurance
Automobile:
$l,OOO
Automobile
Payments:
Fuel:
$350
$260
Parochial S.chool
Religious: '
$4;800
Personal
HaitlBarber
$50
. -.;; ,,~, ^,,' " .ih " ~. " .~"' - is. S
~l\~/rev
,'-0
Loans
Union Dues
Mise
Charity:
BFITrash
SaltMan
Monthly Year
$500
Total Expenses: . . $3,023.61
$300
$85 '
$l20
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<,--.
",""-~;,~ '4~'-:
$41,668.32
*Including Water/Sewer in monthly total
Date: ~)5
Respectfully Submitted;
Rominger, Bayley & Whare.
2~,:;,
155 South Hanover Street
Carlisle, Pa 17013
CourtID.81924
(7l7)241-6070
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OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240-6535
E. Robert Elicker, II
Divorce Master
West Shore
697-0371 Ex!. 6535
Traci Jo Colyer
Office Manager/Reporter
April 13, 2005
Carol J. Lindsay
Attorney at Law
SAIDIS, SHUFF, FLOWER & LINDSAY
26 West High Street
Carlisle, P A l7013
Karl E. Rominger
Attorney at Law
ROMINGER, BAYLEY & WHARE
l55 South Hanover Street
Carlisle, P A l7013
RE: Lorrie A. Jones vs. Gerald W. Jones
No. 01 - l579 Civil
In Divorce
Dear Ms. Lindsay and Mr. Rominger:
Attorney Lindsay has certified that discovery is complete. Mr. Rominger has not
returned the certification document. Nevertheless, I am going to proceed with this case
on the basis that there are no outstanding discovery matters and that we will not be
dealing with discovery issues at the time of the pre-hearing conference.
A complaint in divorce was filed on March 19, 200l, raising grounds for divorce
of irretrievable breakdown of the marriage. No economic claims were raised in the
complaint.
On September 23, 2004, an amended complaint was filed raising economic claims
of equitable distribution, alimony, and counsel fees and costs.
With respect to grounds for divorce, I assume that the parties are either going to
sign affidavits of consent or have been separated for a period in excess of two years.
In accordance with PRC.P. 1920.33(b) I am directing each counsel to file a
pretrial statement on or before Monday, May 9,2005. Upon receipt ofthe pretrial
, .'," -,,-'-" " ,
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-~ ,. "
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Ms. Lindsay and Mr. Rominger, Attorneys at Law
13 April 2005
Page 2
statements, I will immediately schedule a pre-hearing conference with counsel to discuss
the issues and, if necessary, schedule a hearing.
Very truly yours,
E. Robert Elicker, II
Divorce Master
NOTE:
Sanctions for failure to file the pretrial statements are set
forth in subdivision (c) and (d) of Rule 1920.33.
THE ORIGINAL PRETRIAL STATEMENT SHOULD BE FILED
IN THE MASTER'S OFFICE AND A COpy SENT DIRECTLY
TO OPPOSING COUNSEL.
FAILURE TO FILE PRETRIAL STATEMENTS AS DIRECTED
BY THE MASTER MAY RESULT IN THE MASTER'S
APPOINTMENT BEING V ACA TED.
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LORRIE A. JONES,
Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
vs.
CIVIL ACTION - LAW
Ol-1579 CIVIL
GERALD W. JONES,
Respondent
IN DIVORCE
IN RE: PETITION FOR A RULE ABSOLUTE AND HEARING
ORDER
AND NOW, this z~.. day of September, 2004, a briefargwnent on the within
petition for a rule is set for Thursday, December 2, 2004, at 2:00 p.m. in Courtroom Nwnber
4, Cwnberland County Courthouse, Carlisle, PA.
BY THE COURT,
~~ol J. Lindsay, Esquire
For the Petitioner
~l Rominger, Esquire
For the Respondent
'-1
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""~!!;~l~~':ilr---
~~'~-i?i;1!I~.k;.~.llcliJl'fflj"!!~t;o#1t~~IW~~Ja"',i!&Ij,jjHillffilI~~~",:h,~",,-I'hnfu~'~'tjft;,=
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p.~
JOHN E. SLIKE
ROBERT C. SAIDIS
GEOFFREY S. SHUFF
jAMESD. FLOWER,jR
CAROLj. LINDSAY
BRIAN C. CAFFREY
GEORGE F.DOUGLAS, ill
MATIHEWj. ESHElMANt
THOMAS E. FWWER
jACLYNSMITH
LAW OFFICES
SAlOIS, SHUFF, FLOWER & LINDSAY
A PROFESSIONAL CORPORATION
26 WEST HIGH STREET
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (717) 243-6= - FACSIMILE: (717) 243-6486
EMAIL: attomey@ssfl-Iaw.com
www.ssfl~Iaw.com
CAMP HILL OFFICE,
2109 MARKET STREET
CAMP HILL, P A 17011
TELEPHONE. (717)737-3405
FACSIMILE: (717)737.3407
tBoardCenifiedCrcdltors'
Rights Representalion
REPLY TO CARLISLE
April 8, 2005
Robert Elicker, Esquire
Office of the Divorce Master
13 N. Hanover St.
Carlisle, PA 17013
RE: JONES V. JONES
No. 2001-1579 CIVIL TERM
Dear Mr. Elicker:
On March 9, 2005 I returned a Certification of Discovery to you. I have not received
any notice that Mr. Rominger has done the same. Would you please issue a directive
for pre-trial statements? As you may recall, I filed for your appointment in December
and, because of a problem in the Prothonotary's office, you did not receive the file until
March. Thus, although it is not your fault or that of my client, there has been an
unusual delay in this case.
Very truly yours,
OL:ap
cc: Lorrie Jones
Karl..Rominiger
"7;F'
..
JOHN E. SLIKE
ROBERT C. SAIDIS
GEOFFREY S. SHUFF
lAMES D. FLOWER, JR
CAROL J. LINDSAY
BRIAN C. CAFFREY
GEORGE FDOUGLAS, III
MATIHEW I. ESHELMAN
THOMAS E. FWWER
J ACL YN SMITH
.',?"__o""
"_"_e..'
,,' ."'. ","
.,."
LAW OFFICES
SAIDIS, SHUFF, FLOWER & LINDSAY
A PROFESSIONAL CORPORATION
26 WEST HIGH STREET
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486
EMAIL: attorney@ssfI-Iaw.com
www.ssfI-Iaw.com
March 9, 2005
Robert Elicker, Esquire
Office of the Divorce Master
13 N. Hanover St.
Carlisle, PA 17013
RE: JONES V. JONES
No. 2001-1579 CIVIL TERM
Dear Mr. Elicker:
'L ",,-.~,., '" "'rl,.!,e;;,;;;,,,: " . "
CAMP fiLL OFFICE:
2109 MARKET STREET
CAMP HILL, P A 17011
TELEPHONE: (717)737-3405
FACSIMlLE: (717)737.3407
REPLY TO CARLISLE
Please find enclosed a Certification of Discovery in the above captioned case. Thank
you for your help.
OL:ap
cc: Lorrie Jones
Karl Rominger
/,:: '-:,; ..."
.'
'''.''j-,'. ,-
Very truly yours,
Saidis, Shuff, Flower & Lindsay
: > ~
~ ,L~ .,-, ' .' .t.;:'">.:;;i',, " "j
9j ti2J-f/ 0'; ~
LORRIE A. JONES, THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. NO. 01 - 1579 CIVIL
GERALD W. JONES,
Defendant IN DIVORCE
TO:
Carol J. Lindsay
, Attorney for Plaintiff
Karl E. Rominger
, Attorney for Defendant
DATE: Friday, March 11, 2005
CERTIFICATION
[ ~i I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
~/{q I ().?)
, DATE
NOTE:
PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS 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.
-',~
"''', ,
,
'J"';,,",,- '"-,"". ":"'~".'~__"'____ . ','--". <~'o"__,,'__~',,, "''"-__''-_'<"'^'''''~;",)
JOHN E. SLIKE
ROBERT C. SAlOIS
GEOFFREY S. SHUFF
JAMES D. FLOWER jR
CAROL j. LINDSAY
BRIAN C. CAFFREY
GEORGE F.OOUGLAS, III
MATTHEWj. ESHElMAN!
THOMAS E. FLOWER
jACLYN SMITH
LAW OFFICES
SAlOIS, SHUFF, FLOWER & LINOSA Y
A PROFESSIONAL CORPORATION
26 WEST HIGH STREET
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486
EMAIL: attomey@ssfl-Iaw.com
www.ssfl-Iaw.com
CAMP HILL OFFICE:
2109 MARKET STREET
CAMP HILL, P A 17011
TELEPHONE. (717)737--3405
FACSIMILE (717)737-3407
~
i,
,
tBoard Certified Creditors'
Rights Representation
REPLY TO CARLISLE
March 9, 2005
Robert Elicker, Esquire
Office of the Divorce Master
13 N. Hanover St.
Carlisle, PA l7013
RE: Jones v. Jones
NO. 2001-1579
DearMr. Elicker:
On December lO, 2004 I applied for your appointment as Master in the captioned case and
apparently you were so appointed on December l5, 2004. We had not received a Certification of
Discovery and when I called Tracy to inquire I learned that apparently the file had not been
forwarded to you.
Please use this letter as our statement that certification is complete in this case. I would
appreciate your issuing a directive for a pre-trial statement.
Verv trulv yours,
- .,
Saidis, Shuff, Flower & Lindsay
{~L
Carol J. Lindsay
CJL:ap
cc: Lorrit: Jones
Karl Rominiger
." ~ "
..
\
SAlOIS
SHUFF, FLOWER
& LINDSAY
ATIORNEYS.AT-LAW
26 W. High Street
Carlisle, P A
SEP 2 4 2004(
Lorrie A. Jones,
: In the Court of Common Pleas of
: Cumberland County, Pennsylvania
Petitioner
v.
: No. 2001-1579 Civil Term
Gerald W. Jones,
: Civil Action - Law
: In Divorce
Respondent
ORDER OF COURT
And now this _ day of
, 2004 upon consideration of the
within Petition the Rule of this court of December 31, 2003 is made absolute. A
hearing is set for the
day of
, 2004 in Courtroom
number 4 at which the Respondent need appear with the discovery requested
produced in full. At the hearing, this court will consider the request of the
Petitioner for attorneys fees incurred in the compelling of discovery.
By the Court:
J.
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SHUFF, FLOWER
& LINDSAY
ATIORNEV8-AT-LAW
26 W. High Street
Carlisle. PA
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Lorrie A. Jones,
: In the Court of Common Pleas of
: Cumberland County, Pennsylvania
:~
Petitioner
v.
: No. 2001-1579 Civil Term
Gerald W. Jones,
: Civil Action - Law
: In Divorce
Respondent
PETITION FOR A RULE ABSOLUTE AND HEARING
NOW COMES Lorrie A. Jones by and through her counsel Saidis, Shuff,
Flower & Lindsay and petitions this Honorable Court as follows:
1. On May 8, 2003 Petitioner served upon Respondent a Request for
Production of Documents and a Set of Interrogatories.
2. When the interrogatories were not answered and the documents not
produced, on December 31, 2003 Petitioner filed a Petition to Compel
Discovery.
3. On December 31, 2003 this Honorable Court issued a Rule to Show
Cause why the discovery requested should not be produced, making
the Rule returnable 20 days after service. A copy of the Petition and
Order of Court is attached hereto as Exhibit "A".
4. On January 6, 2004 the Court's order of December 31, 2003 was
served on counsel for the Respondent. A copy of the letter of service
is attached hereto as Exhibit "6".
5.
Subsequently, counsel for the Respondent provided a formal response
to the Request for Production of Documents and the Interrogatories.
The responses to the discovery request were inadequate in several
particulars including that set out in a letter to counsel of September 8,
2004 attached hereto as Exhibit "C",
II
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SAlOIS
SHUFF, FLOWER
& LINDSAY
A'ITORNEYS'AT'LAW
26 W. High Street
Carlisle, P A
. '.;,,,L,
6. On September 20, 2004, no informal response having been received, a
second Request for Production of Documents was served on the
Respondent.
7. Petitioner has incurred attorneys' fees in an attempt to secure the
discovery requested. The attorneys' fees are approximately $350.00.
WHEREFORE, Petitioner prays this Honorable Court to make the Rule
of December 31, 2003 absolute and to set a hearing at which Respondent
need appear and provide the additional discovery requested.
SAlOIS, SHUFF, FLOWER & LINDSAY
Attorneys for Petitioner
By:
II
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SAlOIS
SHUFF, FLOWER
& LINDSAY
ATIORNEYS.AT.LAW
26 W. High Street
Carlisle, P A
Lorrie A. Jones,
of
In the Court of Common Pleas
Plaintiff
Cumberland
County,
Pennsylvania
v.
No. 2001.1579 Civil Term
Gerald W. Jones,
Civil Action - Law
In Divorce
Defendant
AND now, this
CERTIFICATE OF SERVICE
2--0 day of
2004, I, Carol J. Lindsay, Esquire, of the law firm of SAID ,SHUFF, FLOWER &
LINDSAY, Attorneys, hereby certify that I served the within Petition for Rule
Absolute and Hearing this day by depositing same in the United States Mail, First
Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to:
Karl E. Rominger, Esquire
Rominger & Bayley
155 S. Hanover Street
Carlisle PA 17013
SAIDIS, SHUFF, FLOWER & LINDSAY
Altomeys 10, P . ~"";; ()~
By: . iLY "" '---
Carol J. Lin sa Esquire
ID# 44693
26 West High Street
Carlisle, PA 17013
(717) 243-6222
II
SAIDIS-
SHUFF, FLOWER
& LINDSAY
ATIORNEYS-AToLAW
26 W. High SlIeet
Carlisle,PA
Lorrie A. Jones,
!lEe 3 0 2003
Petitioner
: In the Court of Common Pleas of
: Cumberland County, Pennsylvania
v.
: No. 2001-1579 Civil Term
Gerald W. Jones,
: Civil Action - Law
: In Divorce'
Respondent
AND NOW, this
ORDER OF COURT
31st day of bec.ernbeR
, 2003 a Rule is issued
upon the Respondent to show cause if iJ,ny why he should not be required to
provide the discovery requested. f). S . .
o.:Le.f\ e.IW\~.:e...
Rule returnable 10' da)Eof fram thg cbts of
-s::F:iCQ horoof at tl lv, CUUlll JUU.;Je at COflisl9, Penngyl\/3ni3 at
..g'elo,-,h. .Tn.
BY THE COURT
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SAlDIS
SHUFF, FLOWER
& LINDSAY
ATIORNEysoAT'LAW
26 W. High Sireet
Carlisle, P A
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Lorrie A. Jones,
.
: In the Court of Common Pleas of
: Cumberland County, Pennsylvania
Petitioner
v.
: No. 2001-1579 Civil Term
Gerald W. Jones,
: Civil Action - Law
: In Divorce
Respondent
PETITION TO COMPEL DISCOVERY
AND NOW, comes the Petitioner, Lorrie A. Jones, by and through her counsel,
Saidis, Shuff, Flower & Lindsay and petitions this Honorable Court as follows:
1. The parties hereto are husband and wife having been joined in marriage on
July 5th, 1982 and having separated on or about March 15th, 2001.
2. On or about May 8th, 2003 Petitioner served on Respondent a requestfor
Production of Documents and a set of Interrogatories, a copy of which is
attached hereto as Exhibit "A".
3. More than 30 days have passed and the Respondent has not produced the
documents requested nor has he answered the Interrogatories.
WHEREFORE, the Petitioner prays this Honorable Court to issue a Rule upon
the Respondent to show cause why he should not be required to produce the
documents requested and answer the Interrogatories.
SAIDIS, SHUFF, FLOWER & LINDSAY
Attorneys for Plaintiff
By:
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SAllIS II
SHUFF, FLOWER II
& LINDSAY II
11
AITORNEYS-AT-LAW
26 W. High Street 1[1,,'
Carlisle, P A
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VER.IFICA liON
I verify that the statements made in this Petition for Special Relief are true and
correct. I understand that false statements herein are made subject to the penalties of
18 Pa. e.s. Section 4904, relating to unsworn falsification to authorities.
Dated:
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SAlOIS
SHUFF, FLOWER
& LINDSAY
'AiTORNEYS.AT.LAW
26 W. High Street
Carlisle, PA
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V ANlA
LORRIE ANN JONES,
Petitioner
v.
GERALD WADE JONES,
Respondent
AND
now,
~rev,,-lo-er
CIVIL ACTION - LAW
No. 2001 -1579 (Civil Term)
(In Divorce)
CERTIFICATE OF SERVICE
this
Qq)/....
day
, 2003, I, Carol J. Lindsay, Esquire, of the law
firm of SAlOIS, SHUFF, FLOWER & LINDSAY, Attorneys, hereby certify that I
served the within Request for Production of Documents this day by depositing
same in the United States Mail, First Class, Postage Prepaid, in Carlisle,
Pennsylvania, addressed to:
I
I
I
I
I
II
II
Karl E. Rominger, Esquire
Rominger & Bayley
155 S. Hanover Street
Carlisle, PA 17013
SAlOIS, SHUFF, FLOWER & LINDSAY
Attorneys for Plaintiff
/I~
By:.vf./?W
Carol J Lindsay, Esquire
10# 93
26 . estHigh Street
Carlisle, PA 17013
(717) 243-6222
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SAIDIS, SHUFF, FLOWER & LlNDSA~ llE
A PROFESSIONAL CORPORATION r
26 WEST IDGH STREET
.CARLISLE, PENNSYL V AI'\'IA 17013
TELEPHONE: (717) 243-6= - FACSIMILE: (717) 243-6486
EMAIL: affol'ney@ssfI-Iaw.com
WVITW.ssfl-Iaw.com
COP'l
)OHN E. SLIKE
ROBERT C.SAlDIS
GEOFFREY S. SHLJFF
J AlvlES D. FLOVYER, JR
CAROL). LIb!DSAY
MATIHEW).ESHELMANt
KIRK S. SOHONAGE
THOMAS E"FWWER
LlNDSA Y GINGRICH MACLAY
JACLYN SMITH
CAMP HILL OFFICE:
2109 MARl<ET STREET
CAI\1P HILL, FA 17D11
TELEPHONE, (717)737-3405
FACSIMILE, (717)737-3407
tBOllrd Cwried Creditors'
Rights~presentlllion
REPLY TO CARLISLE
January 6, 2004
Karl E. Rominger, Esquire
ROMiNGER & BAYLEY
155 S. Hanover Street
Carlisle PA 17013
RE: JONES V. JONES
Dear Karl:
Enclosed please find the Court's Order of December 31s', 2003 issuing a Rule on Gerald Jones
to show cause why he should not provide the discovery requested.
Very truly yours,
CJUap
cc: Lorrie Jones
EXHIBIT
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JOHNE.SURE
ROBERT C. SAIDIS
GEOFFREY S. SHUFF
JAMES D. FLOWER, JR
CAROL). LINDSAY
MATTHEW J. ESHELMANt
KIRK S. SOHONAGE
THOMAS E. FLOWER
UNDSAY GINGRlCHMACLAY
JACLYNSMITH
LAW OFFICES
SAIDIS, SHUFF, FLOWER & LINDSAY
A PROFESSIONAL CORPORATION
26 WEST mCH STREET
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (717) 243-6= - FACSIMILE: (717) 243-6486
EMAIL: attorney@ssfl-Iaw.com
www.ssfl-Iaw.com
F"r rn,', 0,"" y"
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CAMP IfiLL OFFICE:
2109 MARKET STREET
CAMP HILL, P A 17011
TELEPHONE: (717)737-3405
FACSIMILE: (717)737-3407
'tBoardCertifiedCreditors'
Rights Representation
REPLY TO CARliSLE
September 8, 2004
VIA FACSIMILE 241-6878 AND FIRST CLASS MAIL
Karl E. Rominger, Esquire
ROMINGER & BAYLEY
155 South Hanover Street
Carlisle, PA 17013
RE: JONES V. JONES
Dear Karl:
Lorrie has asked me to seek the appointment of the Master and I intend to do that. I will
be asked to certify discovery. I reviewed the discovery request that you sent to us last
February. I wi!' need to have that discovery supplemented and completed as to some
particulars. The original discovery was filed in 2003 and we need some additional
information. Please have Mr. Jones provide the following within the next two weeks:
1. A copy of his 2003 federal income tax return.
2. A copy of his present pay stub.
3. Statement from the Teamsters indicating whether he has any pension plan
other than the Teamsters Retirement Income Plan for which he provided
us a statement. That plan supplemented an earlier Teamsters plan, a
ddined benefit plan. Please have him provide a letter from the Teamsters
as to whether he is entitled to that defined benefit plan.
4. With regard to the Teamsters retirement income plan, you provide a
st::ltement for the value as of December 31, 2002. The parties separated
in March 2001. It would be probably be in Mr. Jones interest to provide a
copy of his statement for the end of 2000. Additionally, Lorrie is entitled to
any increase in value of the plan during the period of separation therefore
please have Mr. Jones provide the statement for December 31,2003 and
.-;."-,,','; ",
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Karl Rominger
September 8, 2004
Page 2;
I
ajetter from the Teamsters which indicate the interest on the account up
tdthe present.
5. Mr. Jones did not provide any bank statements and we need those to
know what the date of separation balances are on the account. If he does
not have the bank statements at home, please have him go to the bank
and have him obtain the March 2001 statements for any accounts in which
h~ has an interest individually or with anybody else.
Thank you for your assistance.
Very truly yours,
j
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Said is, Shuff, Flower & Lindsay
y
CJL:ap
Ce: Lorrie Jones
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ROBERT C. 5AlOIS
GEOFFREY 5. SHUFF
JAMES D. FLOWER, JR
CAROLj. LINDSAY
MATTHEW J. ESHELMANt
KIRK 5. SOHONAGE
THOMAS E. FLOWER
LINDSAY GINGRICH MACLAY
jACLYNSMITH
LAW OFFICES
SAIDIS, SHUFF, FLOWER & LINDSAY
A PROFESSIONAL CORPORA nON
26 WEST HIGH STREET
CARLISLE, PENNSYL VANIA 17013
TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486
EMAIL: attomey@ssfl-Iaw.com
www.ssfl-law.com
CAMP HILL OFFICE:
2109 MARKET STREET
CAMP HILL, P A 17011
TELEPHONE: (717)737-3405
FACSIMILE: (717)737-3407
tBoardCertifiedCreditors'
Rights Representation
REPLY TO CARLISLE
August 30, 2004
The Honorable Kevin A. Hess
Cumberland County Courthouse
One Courthouse Square
Carlisle, Pennsylvania 17103-3387
Re: Jones V. Jones (In Divorce)
Docket No. 2001-1579 (Cumberland County)
Dear Judge Hess:
I have reviewed the enclosed order with Mr. Rominger and he has no objection to it.
Would you kindly enter it as a resolution of the outstanding custody issue in this matter.
Thank you for your help.
Very truly yours,
wer & Lindsay
CJL:ap
Cc: Lorrie Jones
Karl Rominger, Esquire
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LORRIE A. JONES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
v
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 1579-2001 CIVIL TERM
IN DIVORCE
GERALD W. JONES,
Defendant
IN RE: PETITION TO ENFORCE MARITAL
SETTLEMENT AGREEMENT
ORDER OF COURT
AND NOW, this 12th day of December, 2005, this matter
having been called for hearing, the court being satisfied that
the defendant has not complied with the order of court in this
case, a contempt citation is issued. The defendant is ordered
and directed to appear on Thursday, January 12, 2006, at 9:00
a.m., in Courtroom No.4 of the Cumberland County Courthouse,
Carlisle, Pennsylvania, to show cause why he should not be
adjudicated in contempt. Upon the failure of the defendant to
appear at the January 12, 2006, hearing, a bench warrant will
issue for his arrest.
By the Court,
"./'Carol J. Lindsay, Esquire
For the Plaintiff
di
Hess, J.
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In the Court of Common Pleas of
CUMBERLAND
County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Phone: (717) 240-6225
Fax: (717) 240-6248
Defendant Name: GERALD W. JONES
Member ID Number: 2301100755
Please note: AU correspondence must include the Member ill Nwnber.
MODIFIED ORDER OF ATTACHMENT OF UNEMPLOYMENT BENEFITS
Financial Break Down of Multiple Cases on Attachment
Plaintiff Name
LORRIE A. JONES
LORRIE A. JONES
PACSES
Case Number
394107723
850103327
Bocket
Number
01-1579 CIVIL
00270 s 2001
Attachment Amount/FreQuency
$
f
$
$
f
$
825.00 IMONTH
555.00 fMONTH
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I
%
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TOTAL A'ITACHMENT AMOUNT: $
1,380.00
Now, by Order of this Court, the Department of Labor and Industry, Bureau of Unemployment
Compensation Benefits and Allowances (BUCBA), is hereby directed to attach the lesser of $ 318.46
per week, or 50. 0 %, of the Unemployment Compensation benefits otherwise payable to the Defendant,
GERALD W. JONES Social Security Number 205-52- 9905 , Member
ID Number 2301100755 . BUCBA is ordered to remit the amount allached to the Department of Public
Welfare (DPW). DPW shall forward the amount received from BUCBA to the Domestic Relations Section of this
Court for support and/or support arrearages.
If the Defendant's U nemptoyment Compensation benefits are allached by another Court or Courts for
support andlor support arrearage, DPW may reduce the amount allached under this Order so that the total amount
allached does not exceed the maximum amount subject to garnishment pursuant to 15 U.S.C. ~ 1673(b)(2) and 23
Pa. C.S. ~ 4348(g).
This Order shall be effective upon receipt of the notice of the Order by the BUCBA and shall remain in
effect until the Defendant's entitlement to Unemployment Compensation benefits, under the Application for
Benefits dated FEBRUARY 15, 2004 is exhausted, expired or deferred.
BUCBA shall comply with this Order, unless it is amended or vacated by subsequent Order of this Court.
All questions, challenges or obligations to this Order shall be directed to the Domestic Relations Section of this
Court.
BY THE COURT
Date of Order:
DEe 2 7 7005
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Service Type M
Form EN-034
Worker ID $IATT
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State Commonwealth of Pennsvlvania
Co./City/Dist. of CUMBERLI\ND
Date of Order/Notice 12/23/05
Case Number (See Addendum for case summary)
ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
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ABF FREIGHT SYSTEMS
PO BOX 10048
3801 OLD GREENWOOD RD 72 9
FORT SMITH AR 72917-0048
RE, JONES, GERALD W.
Employee/Obligor's Name (Last, First, Mil
205-52-9905
Employee/Obligor's Social Security Number
2301100755
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (Last, First, MI)
EmployerlVVithholder's Federal EIN Number
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMA TlON: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLI\ND County, Commonwealth of Pennsylvania. 8y law, you are required to deduct these
amounts from the above-named employee's/obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 1,380.00permonth in current support
$ 0 . 00 per month in past,due support Arrears 12 weeks or greater? 0 yes <Xl no
$ 0.00 per month in current and past-due medical support
$ 0.00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 1, 380.00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 318.46 per weekly pay period.
$ 636.92 per biweekly pay period (every two weeks).
$ 690.00 per semimonthly pay period (twice a month).
$ 1.380.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's/ obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on page 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
Date of Order:
nFr 2 7 7005
BY THE COURT:
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Form~~o~Co
Worker ID $IATT
Service Type M
OMS No.: 0970-0154
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If. checked you are required to provide a copy of this form to your employee. if your employee works in a state that is
different from the state that issued this order, a copy must be provided to your employee even if the box is not checked.
1. Priority: Withholding under this Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax ievies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employee/obligor.
3. * RepOll;llg Lilt:: r aydattfDate ofV/;tl,l,oIJ;llo. You IIIu5L 1t::I-1Vllll,e paydateJdate of vvitl,I,Oldil,g YVllel1 ;,t::"d;,Jg tile paYIIIt::IIl. Tilt::
payJatt/date of vv;1I11IoIJ;115;;' L1le date 011 yyl,;d, alllVUIIl vvc.5 yv;UlllelJ f,V,II tile t:llll-1lvyet::';:t YVd15e;,. You must comply with the law of the
state of the empioyee'slobligor's principal place of employment with respect to the time periods within which you must implement the
withholding order and fOlWard the support payments.
4.* Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this empioyee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must foilow
the law of the state of employee's/obligor's principal place of employment. You must honor all Orders/Notices to the greatest extent
possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 7102494440
EMPLOYEE'S/OBlIGOR'S NAME: JONES , GERALD W.
EMPLOYEE'S CASE IDENTIFIER: 2301100755 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhpld from lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment,
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsyivania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed governs.
9. * Withholding limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (15 U.S.c. 91673 (b)1; or 2) the amounts allowed by the State of the employee's/obligor's principal place of employment.
The Federal limit appiies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, iocal taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more
than the amounts ailowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more
than the amounts allowed under the law of the state that issued the order.
10. Additionaltnfo:
*NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
II.Submitted By: If you or your employee/obligor have any questions,
DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT
13 N.HANOVER ST by telephone at (717) 240-6225 or
P.O. BOX 320 by FAX at (7171 240-6248 or
CARLISLE PA 17013 by internet www.childsupport.state.pa.us
Page 2 of 2
Form EN-028
Worker ID $IATT
Service Type M
QMB No.: 0970-0154
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ADDENDUM
Summary of Cases on Attachment
Defendant/Obligor: JONES, GERALD W.
PACSES Case Number 394107723
Plaintiff Name
LORRIE A. JONES
Docket Attachment Amount
01-1579 CIVIL$ 825.00
Child(ren)'s Name(s):
DOB
PACSES Case Number 850103327
Plaintiff Name
LORRIE A. JONES
Docket Attachment Amount
00270 S 2001 $ 555.00
Child(ren)'s Name(s):
TIl'FM'Y,N'IC;PLE;(PN'ES,
MEG1\N.,.'''EaECCA",JONES..'..
DOB
96U~(8,~,
66114/92
you are required to enroll the child(ren)
in any health insurance coverage available
through the employee's!obligor's employment.
If checked, you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
Olf checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's1obligor's employment.
you are required to enroll the child(ren)
in any health insurance coverage available.
employee's!obligor's employment.
PACSES Case Number
Plaintiff Name
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
o If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's1obligor's empioyment.
If checked, you are required to enroll the child(ren)
in any health insurance coverage available
employee's!obligor's employment.
Addendum
Form EN-028
Worker ID $IATT
Service Type M
OMB No.: 0970-0154
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
State Commonwealth of P~nnsvlvania '6 '::)0 \ 06::':>7:\
Co./City/Dist. of CUMBERL1\ND 210 S 2cC', \
Date of Order/Notice 12/23/05
Case Number (See Addendum for case summary)
3C\ '--\ \0 '112:".>
0\" \5'\9 C,,,\ L.
o Original Order/Notice
o Amended Order/Notice
o Terminate Order/Notice
PENN NATIONAL INSURANCE
PO BOX 3880
HARRISBURG PA 17105-3880
RE: JONES, GERALD W.
Employee/Obligor's Name (last, First, MI)
205-52-9905
Employee/Obligor's Social Security Number
2301100755
Employee/Obligor's Case Identifier
(See Addendum for plaintiff names
associated with cases on attachment)
Custodial Parent's Name (last, First, MI)
EmployerNVithholder's Federal EIN Number
See Addendum for dependent names and birth dates associated with cases on attachment.
ORDER INFORMATION: This is an Order/Notice to Withhold Income for Support based upon an order for support
from CUMBERLIINIl County, Commonwealth of Pennsylvania. 8y law, you are required to deduct these
amounts from the above-named employee's!obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ 1, 380 . 00 per month in current support
$ 0 . 00 per month in past-due support Arrears 12 weeks or greater? 0 yes @ no
$ 0.00 per month in current and past-due medical support
$ 0.00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 1, 380. 00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 318.46 per weekly pay period.
$ 636.92 per biweekly pay period (every two weeks).
$ 690.00 per semimonthly pay period (twice a month).
$ 1.380.00 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the first pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state of your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's! obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on page 2).
If remitting by EFT/EDI, please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at 1-877-676-9580 for instructions.
Make Remittance Payable to: PA SeDU
Send check to: Pennsylvania SeDU, P.O. Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL. . ' 4-' ,
BY THE COURT, AI!'i .
DEe 2 7 2005 " ~' ,.,.
Date of Order: L----
VJl.An.i\ 1\ . \\I;)) ,
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Worker ID $OINC
Service Type M
QMB No.: 0970-0154
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o If.~hecked you are required to provide a copy of this form to your employee. If yoUr employee works in a state that is
different from the state that issued this order, a copy must be provided to your employee even if the box is not checked.
1. Priority: Withholding underthis Order/Notice has priority over any other legal process under State law against the same income.
Federal tax levies in effect before receipt of this order have priority. If there are Federal tax levies in effect please contact the requesting
agency listed below.
2. Combining Payments: You can combine withheld amounts from more than one employee/obligor's income in a single payment to
each agency requesting withholding. You must, however, separately identify the portion of the single payment that is attributable to each
employee/obligor.
3. * Repv,t;1I5lLc r C1yJdldDalc vf 'Iv';lI111VIJ;115. Yvu 1I1u;)lIC/JVll lIle payddttdJCltc vf vv;t1lllold;lIg YVIICII ;)CIIJ;lIg ll,c /JClYIIICIIt. TIle
tJ.1yddlelddlc of vv;tl,I,,,,IJ;I'5;;) tile JCllc VII vvl 1;"..1 I C1II1UUlll YVCl;) vval,l,dJ flVlll tile clllploycc';) vV""6C:l. You must comply with the law of the
state of the employee's/obligor's principal place of employment with respect to the time periods within which you must impiement the
withholding order and forward the support payments.
4.' Employee/Obligor with Multiple Support Holdings: If there is more than one Order/Notice to Withhold Income for Support against
this employee/obligor and you are unable to honor all support Order/Notices due to Federal or State withholding limits, you must follow
the law of the state of employee's/obligor's principal place of employment. You must honor all OrdersfNotices to the greatest extent
possible. (See 119 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 0064100092 .
EMPLOYEE'S/OBLlGOR'S NAME: JONES. GERALD W.
EMPLOYEE'S CASE IDENTIFIER: 2301100755 DATE OF SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. Lump Sum Payments: You may be required to report and withhold frOm lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. liability: If you fail to withhold income as the Order/Notice directs, you are liable for both the accumulated amount you should have
withheld from the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is emplOyed in another State, in which case the law of the State in which he or she is employed governs.
8. Anti-discrimination: You are subject to a fine determined under State law for discharging an employee/obligor from employment,
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the State in which he or she is employed govems.
9.' Withholding limits: You may not withhoid more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit
Protection Act (1 5 U.S.c. ~1673 (b)t; or 2) the amounts allowed by the State of the employee's!obligor's principal place of employment.
The Federal limit applies to the aggregate disposable weekly earnings (ADWE). ADWE is the net income left after making mandatory
deductions such as: State, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more
than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a state order, you may not withhold more
than the amounts allowed under the law of the state that issued the order.
10. Additional Info:
'NOTE: If you or your agent are served with a copy of this order in the state that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
11.Submitted By: If you or your employee/obligor have any questions,
DOMESTIC RELATIONS SECTION contact WAGE ATTACHMENT UNIT
13 N. HANOVER ST by telephone at (717)240-6225 or
P.O. BOX 320 by FAX at (717) 240,6248 or
CARLISLE PA 17013 by internet www.childsupport.state.pa.us
Page 2 of 2
Form EN-028
Worker 10 $OINC
Service Type M
OMS No.: 0970-0154
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ADDENDUM
Summary 01 Cases on Attachment
Defendant/Obligor: JONES, GERALD W.
PACSES Case Number 394107723
Plaintiff Name
LORRIE A. JONES
Docket Attachment Amount
01-1579 CIVIL$ 825.00
Child(ren)'s Name(s):
DOB
PACSES Case Number 850103327
Plaintiff Name
LORRIE A. JONES
Docket Attachment Amount
00270 S 2001 $ 555.00
Child(ren)'s Name(s):
TIFFANY NICOLE JONES
Mli:Gi\N...REllEljljA....dONES...........,'.
DOB
. ...,.............'..........,',......g~.~.i~~.~.~
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
If checked, you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
If checked, you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
you are required to enroll the child(ren)
in any health insurance coverage available
employee's/obligor's employment.
PACSES Case Number
Plaintiff Name
PACSES Case Number
Plaintiff Name
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
Docket Attachment Amount
$ 0.00
Child(ren)'s Name(s):
DOB
o If checked, you are required to enroll the child(ren)
identified above in any health insurance coverage available
through the employee's/obligor's employment.
o If checked, you are required to enroll the child(ren)
identified above in any heaith insurance coverage available
through the employee's/obligor's employment.
Addendum
Form EN-028
Worker ID $OINC
Service Type M
OMB No.: 0970.Q154
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LORRIE A. JONES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 01 - 1579 CIVIL
GERALD W. JONES,
Defendant
IN DIVORCE
THE MASTER:
Today is Tuesday, October 4,
2005. This is the date set for a hearing in the above
captioned divorce proceedings. Present in the hearing room
are the Plaintiff, Lorrie A. Jones, and her counsel Carol J.
Lindsay, and the Defendant, Gerald W. Jones, and his counsel
Karl E. Rominger.
The parties were married on July 5, 1982, and
separated March 31, 2001. The parties are the natural
parents of two children, both of whom are still minors. The
older child lives with the father and the younger child
lives with the mother.
The divorce complaint was filed on March 19,
2001, raising grounds for divorce of irretrievable breakdown
of the marriage. The Master has been provided affidavits of
consent and waivers of notice of intention to request entry
of divorce decree signed and dated today by both parties.
The affidavits and waivers will be filed with the
Prothonotary's office by the Master's office so that the
divorce can conclude under Section 3301(c) of the Domestic
Relations Code.
PLAINTIFPS
EXHIBIT
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An amended complaint in divorce was filed an
September 23, 2004, raising claims on behalf of wife of
equitable distribution, alimony, and counsel fees and costs.
The Master has been advised that after
considerable negotiations in this case, the parties have
reached an agreement with respect to all of the outstanding
economic issues. The 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. The parties and
counsel are going to return later today to review the
transcribed agreement and make typographical corrections as
necessary. They will then be asked to sign the agreement,
affirming the terms of settlement as stated on the record.
However, it is specifically noted that when the parties
leave the hearing room today they are bound by the
substantive terms of the agreement even though there is no
subsequent signing of the agreement by the parties affirming
the settlement.
Upon receipt by the Master of the completed
agreement, the Master will prepare an order vacating his
appointment and counsel can then file a praecipe
transmitting the record to the Court requesting a final
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decree in divorce. Mr. Rominger.
MR. ROMINGER:
1. Husband agrees to make a direct cash payment to wife in
the amount of $55,000.00 within 45 days of today's date.
2. Husband agrees to prepare a QDRO to provide wife with
$55,000.00 of his Teamster's pension within two weeks of
today's date.
3. Husband agrees to convey all of his interest in two
IRAs now in his possession and listed on the property
statement of Plaintiff, being an American Investors IRA and
a Putnam IRA and will complete all documents necessary to
make the transfer or prepare any Court order if either would
require within two weeks of today's date.
Mr. Jones warrants that he has not removed any monies
from the American Investors IRA since March 28, 2005, when
it had a value of $6,853.65. Nor has he removed any monies
from the Putnam IRA since March 31, 2005, when it had a
value of $1,875.02. Wife will be receiving these two IRAs
reduced in value or increased in value only by market
conditions.
4. Husband shall agree to the entry of an alimony order in
the amount of $825.00 per month to be administered or
attached to the Domestic Relations .Office of this county.
This is an indefinite alimony order and subject to
modification upon a change of circumstances and termination
upon the death of either party, cohabitation by wife with a
member of the opposite sex or remarriage of wife.
The alimony shall be effective October 1, 2005;
wife will advise the office of Domestic Relations that her
spousal support shall terminate on the same date and if any
over collection is made, it will be credited appropriately.
5. It is the intent of the parties that each party will
keep all tangible personal property now in their possession
and all vehicles now in their possession, and remain
responsible for all debts now in their name. Additionally,
at the time of the payment of the $55,000.00 lump sum to
wife, husband will refinance and remove wife from any
obligation to the marital residence.
6. Wife shall execute a deed at the time of the refinance
and receipt of the lump sum payment transferring her
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interest solely to husband. The deed will be prepared by
husband's counsel.
7. Except as specified above, both parties waive any and
all claims they may have as to any retirement or other
accounts held by the other for any purpose.
8. The parties expressly waive any further claims for
counsel fees or costs which they may have as against the
other.
9. Wife will retain the 1994 Ford Explorer and husband
will retain the 2000 Chevy pick-up, the 1972 Chevy pick-up,
and the 2001 Triumph motorcycle. Similarly, wife will
retain the two bank accounts which were in her individual
name at Waypoint and the $25.87 remaining in the Member's
1st Federal Union account as of the time of separation and
husband will retain his Waypoint account.
10. 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.
MS. LINDSAY, Lorrie Jones, did you hear the
agreement as it was dictated by Mr. Rominger and by me?
MS. JONES: Yes.
MS. LINDSAY: And did you understand it?
MS. JONES: Pretty much so except for some of
that stuff at the end. I understood.
MS. LINDSAY: Okay. Let me explain what that
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stuff at the end is about. That is some magic language
that's in there so that if you didn't get divorced between
now and -- if somebody died, one of you died, between now
and the date you were divorced, you might have a claim on
the estate of the other. What this is doing is waiving any
claims you have on the estate of the other for that period
of time. Once you are divorced you don't have a claim --
MS. JONES: Okay.
MS. LINDSAY: Do you have any questions in
addition about what I just said and Mr. Rominger just
dictated?
MS. JONES: No.
MS. LINDSAY: And are you in agreement that
the agreement as dictated is the agreement you want to make?
MS. JONES: Yes.
MR. ROMINGER: Gerald, have you heard the
agreement as dictated into the record?
MR. JONES: Yes.
MR. ROMINGER: And are you in agreement with
the contents of it?
MR. JONES: Yes.
MR. ROMINGER: Do you understand it?
MR. JONES: Yes.
MR. ROMINGER: Do you agree fully and
faithfully execute it?
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MR. JONES: Yes.
(Whereupon, a discussion was held off the
record. )
MS. LINDSAY: In the event, that one party to
this agreement fails or refuses to abide by a term or to
comply with a term hereof, and the other party seeks Court
intervention in order to enforce the agreement, the party
who has breached the agreement shall be responsible for the
attorney fees and costs of the other party expended to
enforce the agreement.
MR. ROMINGER: The only caveat would be
force'majeure and impossibility of paying as defenses.
MS. LINDSAY: If one of you do not adhere to
your deal here and the other guy has to go to Court to
enforce the attorney fees and costs, Karl's addition was
something like Hurricane Katrina comes along and it cannot
be done.
(Whereupon, a discussion was held off the
record. )
MS. LINDSAY: It is understood that
impossibility shall not be a defense to the payment of
$55,000.00 as set out in this agreement by husband to wife.
THE MASTER: You understand what they just
talked about?
MR. JONES: Yeah.
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MS. JONES: Okay.
MR. ROMINGER: Mr. Jones, are you satisfied
with your representation? Do you believe that you have been
adequately advised entering into this agreement?
MR. JONES: Yes.
MS. LINDSAY: The same question?
MS. JONES: Yes, definitely.
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:
od. 4) 05 j ~a. ~oYl d 1)
Lorrie A. Jone
tiff
....
(D/LI/[}I
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G,Q.r4-
K~. Rominger
Attorney for Defendant
7
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LORRIE A. JONES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS
NO. 01-1579
GERALD W. JONES,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
ORDER OF COURT
AND NOW, this 12th day of January, 2006, after
hearing, the Defendant is adjudicated in contempt. We award
counsel fees and costs in favor of the Plaintiff in the total
amount of $750 to be paid within 90 days of today's date.
Hearing with respect to the adjudication is continued
and the Defendant is directed to execute within 48 hours a release
in favor of the the Plaintiff so that she will have access to any
and all information concerning his current transactions with
Countrywide Bank and the matter to be relisted at the request of
either counsel.
By the Court,
~Ol J. Lindsay,
For Plaintiff
.Ai
~rl E. Rominger, Esquire
For Defendant
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: IN THE COURT OF COMMON PLEAS OF
. : CUMBERLAND COUNTY, PENNSYLVANIA
: NO.2001-l579
LORRIE A. JONES,
Plaintiff
GERALD W. JONES
Defendant
:. CIVIL ACTION- LAW
: IN DIVORCE
CENTRAL PENNSYLVANIA TEAMSTERS1987RETIRMENTlNCOMEPLAN
. OUALlFIEDDOMI<;STICRELATIONSORDER'
AND NOW, this 20' day of 111-."-1
, 2006, pursuant to the parties'
Agreementto the entry of the attached Central Pennsylvania Teamsters Retirement Income Plan
Qualified Domestic Relations Order, the following Order is entered
I. IDENTIFYING,INFORMATION:
1. The Participant is Gerald W. Jones:
The Participant's social security number is 205-52-9905.
The Participant's address is 38 Carlton Avenue, Carlisle, PA l7013.
The Participant's date of birth is 10/3/60.
2. The Altem\lte Payee is Lortie A. Jones.
The Alternate Payee's social security number isl84c50-1623.
The Alternate Payee's address is408B Walnut Street, Boiling Springs, P A 17007.
The Alternate Payee's date of birth is 7/22/61.
3. The parties were married on July 5, 1983 and separated on March 19, 2001.
4. The parties hlwe raised claims of equitable distribution of marital property
pursuantto the Pennsylvania Divorce Code.
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II. METHOnOF DIVIDING PARTICIPANT'S BENEFITS:
1. The Plan shall pay to the alternate payee a one timel~p sum of Fifty-five
Thousand ($55,000.00) Dollars of the Participant's vested accrued benefit under
the Plan as ordered by the Cumberland County Court of Common Pleas ,after a
Divorce Master's hearing on October 4, 2005, and as agreed to by the parties..
2. The Fund shail separately account for the benefits awarded in paragraph 1 of this
. . Section II as soon as administrable after this Order is deteimined to be a QDRO.
The Alternate Payee shall be credited with net income, loss or expense from the
date this Order.is determine~ to be a QDRO.
3. The Alternate Payee may elect to receive payment from the Plan in any form in
which benefits may be paid under the Plan to the Participant (other than in the
form ofa joint and survivor annuity).
4. The Alternate Payee may select a beneficiary to receive her benefits in the event
the Alternate Payee should die prior to receiving all of her benefits by filing a
Beneficiary Designator form with the Fund office. In the event the Alternate
Payee Should die prior to receiving benefits, the Plan shall pay benefits toa
beneficiary selected by the Alternate Payee on a BeneficiarY form provided by the
Fund office on request, or if no beneficiary is selected, to the Alternate Payee's
estate.
5. The Alternate Payee may elect to receive payment from the Plan at the
Participant'searliest retirement age, or, ifearlier, atthe earliest date permitted
under the Plan. Forpufposes of this. paragraph, the Participant's earliest
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retirement age means the eadierof (i) the date on which the Participant is entitled
to a distribution under the Plan, or (ii) the later of (a) the date the Participant
attains age SOor (b) the earliest date ortwhich the Participant could begin
receiving benefits under the Plan if the Participant separated from service.
III. OTHER PROVISIONS:
1. This Order is intended to constitute a Qualified DomesticRelations Order within
the meaning of Section 414{P) of the Internal Revenue Code of 1986,asamended
in Section 206(d) of the Employee Retirement IIicOlne Security Act of 1974, as
. amended, and shall be interpreted in a manner consistent with such intention.
2. The Court shall retainjurisdictioll to amend this Order to the extent necessary to
establish or maintain its status as .a Qualified Domestic Relations Order.
3. It is recognized that the Alternate Payee may elect to commence receiving
.' ., . . '
benefits before the Participant retires. If the Alternate Payee so requests, the
. Participantwillcooperate with the Alternate Payee in substantiating a claim or
application to the Fund and shall provide any documentation pr information
reasonably necessary to establish.their eligibilityJorbenefits.
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: IN THE COURT Of COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO.200l-l579
CIVIL ACTION-LAW
: INDIVORCE
LORRIE A. JONES,
Plaintiff
GERALD W.JONES
, Defendant
ANI? NOW, comes Gerald W. Jones, Defendant and Lorrie A. Jones, and respectfully
requests that this Honorable Court enter the following Qualified Domestic Relations Order:
I. IDENTIFYING INFORMATION:
1. The Participant is Gerald W.Jimes.
The Participant's social security number is 205-52-9905..
The Participant's address is 38 Carlton Avenue, Carlisle, P A 17013.
The Participant' sdate of birth is lO/3/60.
2. The Alternate Payee is Lorrie A Jones.
The Alternate Payee's social security number is 184-50-l623.
The AlternakPayee's address i~ 408BWalnut Street, Boiling Springs, PA. 17007.
The Alternate Payee's date of birth is 7/22/61.
3. The parties were married on July 5, 1983 and separated on March 19; 2001.
4. The partie~ have raised claims of equitable distribution ofmaritaI property
pursuantto thePenilsylvania Divorce Code.
II. METHOD OF DIv'IDING. PARTICIPANT' S BENEFITS:
1. The Plan shall pay to the a)tern~tepaye<o a (me time lump sum of Fifty-five
Thousand ($55,00d.00) Dollars of the Participant's vested accrued benefit ooder
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the PliUl as ordered by the Cumberland County Court of Common Pleas after a
Divorce Master's hearing on October 4,2005, and as agreed to by the parties..
2. The.Fund shall separately account for thebtmefits awarded in paragraph 1 of this
Section II as soon as administrable after this .order is det<;rmined to be a QDRO.
The Alternate Payee shallbecr<;ditedwith net income, loss or expense from the
date this Order is detenninedtobe a QDRO.
3. The Alterilate Payee may electto receive payment from the Plan in any form in
which benefits may be paid under the Plan to the Participant( otherthan in the
form of a joint and survivor annuity).
4. The Alternate Payee may select a beneficiary to receive her benefits in the event
the Alternate Payee should die prior toreceiving all of her benefits by filing a
Beneficiary Designator fOrm with the Fund office. In the event the Alternate
Payee should die prior to receiving benefits, the Plan shall pay benefits to a
ben<;ficiary selected by the Alternate Payee on a Beneficiary form provided by the
Fund office on request, or if no beneficiary is selected, to the Alternate Payee's
estate.
5. The Alterriatepayee may elect to receive payment from the Plan at the
Participant'searliestretirement age, or, if earlier, at the earliest date permitted
under The Plan. For purposes of this paragraph; the Participant's earliest
retirement age mea)1S the earlier of (i) the date on which the Participant is entitled
to a distribution under the Plan; Or (ii)the later of (a) thedate the Participant
attains age 50 or (b) the earliest date onwhichtheParticipant could begin
receiving benefits und<;rthe Plan iftheParticipan,t separated from service.
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III. OTHER PROVISIONS:
l. This Order is intended to constifutea Qualified Domestic Relations Order within
the meaning of Section 4l4(P) of the Internal Revenue Cdde of 1986, as amended
in Section 206(d) of the Employee Retirement In<;ome Security Act of 1974, as
amended, and shall be interpreted in a manner consistent with such intention.
2. The Court shall retain jurisdiction to amend this Order to the extent necessary to
establish or maintain its status as a Q).Illlified Domestic Relations Order.
3. It is recognized that the Alternate Payee may elect to commence receiving
benefits before the Participant retires. If the Alternate Payee so requests, the
Participant will cooperate with the Alternate Payee in substantiating a claim or
applicationtothe Fund and shall provide any documentation or infomiation
. .
reasonably necessary to establish. their eligibility for benefits.
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Gerald W. Jones .' .', ' ",'
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Date
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. Karl E. Rominger, Esquire
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Lorrie A. Jones . "., , "
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LORRIE A. JONES,
Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CNIL ACTION - LAW
Ol-l579 CIVIL
GERALD W. JONES,
Respondent
IN DIVORCE
IN RE: REOUEST FOR HEARING
ORDER
AND NOW, this '2 rI day of February, 2006, a brief hearing in the above
captioned matter is set for Wednesday, February l5, 2006, at 3:00 p.m. in Courtroom
Number 4, Cumberland County Courthouse, Carlisle, PA.
BY THE COURT,
Carol J. Lindsay, Esquire
For the Petitioner
Karl Rominger, Esquire
For the Respondent
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FlOWER &
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1aTORNE\'SoAT.lAW
26 West High Street
Carlisle,PA
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LORRIE A. JONES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001-1579 CIVIL TERM
v.
GERALD W. JONES,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
ORDER OF COURT
AND NOW, this ,;l,,;{nd day of ~~
, 2006, upon the
request of counsel, the hearing scheduled for February 15, 2006 at 3:00 PM is
hereby continued to the /7 -tI day of ~/~ , 2006 at .5; 38
o'clock 1M.
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LORRIE A. JONES,
Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
Ol-l579 CIVIL
GERALD W. JONES,
Respondent
IN DIVORCE
ORDER
AND NOW, this / 7'~ day of April, 2006, hearing in the above captioned matter
set for Aprill7, 2006, is continued generally, to be rescheduled at the request of either party.
BY THE COURT,
~ol 1. Lindsay, Esquire
For the Petitioner
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LORRIE A. JONES, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. CIVIL ACTION -LAW
NO.01-1579 CIVIL
GERALD W. JONES,
Defendant IN DIVORCE
IN RE: PETITION TO MODIFY ALIMONY
ORDER
AND NOW, this Z B' day of January, 2010, the petition of the defendant, Gerald W.
Jones, to modify alimony is DENIED.1
~ Carol J. Lindsay, Esquire
For the Plaintiff
/ Vincent Monfredo, Esquire
For the Defendant
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' We decline to act, at this time, on the plaintiff s request that alimony be increased. We are satisfied that the
defendant was entitled to prior notice of the plaintiff's request, in the nature of a petition, and the corresponding
opportunity to defend.
BY THE COURT,
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In the Court of Common Pleas of CI7MBERI,AND enl ~
DOMESTIC RELATIONS SECTION
17013
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13 N. HANOVER ST, P.O. BOX 320, CARLISLE, P s ~~
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Defendant Name: GERALD W . JONES ~,~, C°- n~ ~ rr
Member ID Number: 2301100755 ~
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Please note: All correspondence must include the Member ID Number.
ORDER OF ATTACHMENT OF UNEMPLOYMENT COMPENSATION BENEFITS
Financial Break Down of Multiple Cases on Attachment
Plaintiff Name
LORRIE A. JONES
PACSES Docket
Case Number Number
394107723 01-1579 CIVIL
Attachment Amount/Frequenc
$ 825.00 MONTH
$$$
$ /
$ ~
TOTAL ATTACHMENT AMOUNT: $ 825.00
Now, by Order of this Court, the Department of Labor and Industry, Office of Unemployment
Compensation Benefits (OUCB), is hereby directed to attach the lesser of $1.89.86
per week, or 50 %, of the Unemployment Compensation benefits otherwise payable to the Defendant,
GERALD W. JONES Social Security Number XXX-XX- 9905 ,
Member ID Number 2301100755 OUCB is ordered to remit the amount attached to the Department of
Public Welfare (DPW). DPW shall forward the amount received from OUCB to the Domestic Relations Section
of this Court for support and/or support arrearages.
If the Defendant's Unemployment Compensation benefits are attached by another Court or Courts for
support and/or support arrearages, DPW may reduce the amount attached under this Order so that the total
amount attached does not exceed the maximum amount subject to garnishment pursuant to 15 U.S.C. § 1673
(b)(2) and 23 Pa. C.S.A. § 4348 (g).
This Order shall be effective upon receipt of the notice of the Order by the OUCB and shall remain in
effect until the Defendant's entitlement to Unemployment Compensation benefits, under the Application for
Benefits dated FEBRUARY 21, 2010 is exhausted, expired or deferred.
OUCB shall comply with this Order, unless it is amended or vacated by subsequent Order of this Court.
All questions, challenges or obligations to this Order shall be directed to the Domestic Relations Section of this
Court.
BY THE COURT
Date of Order: r~~, ~ ~ ~ 2. u . J
DRO: R.J. SHADDAY
d~-~-e
ALBERT H. MASLAND,
JUDGE
Form EN-530 Rev.2
Service Type M Worker ID $ IATT
a! /
FILED-OFFICE
OF THE PROTHONOTARY
LORRIE A. JOjW,DEC 15 PP's 2: 5:0 IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CUMBERLAND COUNTY
V. PENTSYLVANIA CIVIL ACTION - LAW
NO. 2001-1579 CIVIL TERM
GERALD W. JONES, ;
Defendant IN DIVORCE
PRAECIPE TO WITHDRAW APPEARANCE
TO THE PROTHONOTARY:
Please withdraw my appearance as counsel of record for the Plaintiff, Lorrie A.
Jones.
Respectfully submitted.
SAIDIS SULLIVAN
Carol J. Lindsay wire
Supreme Court M. 44693
26 West High Street
Carlisle, PA 17013
717-243-6222
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance on behalf of the Plaintiff, Lorrie A. Jones, in the above
SAIDIS
SULLIVAN
LAW
26 West High Street
Carlisle, PA
captioned case.
Dated: j Zj 11i J7
Lorrie A. Jones, pro se
CERTIFICATE OF SERVICE
I hereby certify that on this / q day of December, 2010, a true and correct copy of
the foregoing document was served upon the party listed below, via First Class Mail, postage
prepaid, addressed as follows:
Vincent Monfredo, Esquire
Rominger & Bayley
155 South Hanover Street
Carlisle, PA 17013
SAIDIS, FLOWER & LINDSAY
t
Carol J. Lindsa s ire
Supreme Court o. 44693
26 West High Street
Carlisle, PA 17013
717-243-6222
SAIDIS
SULLIVAN
LAW
26 West High Street
Carlisle, PA
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
Phone: (717)240-6225 13 N.HANOVER ST,P.O.BOX 320,CARLISLE,PA.17013 Fax: (717)240-6248
Defendant Name: GERALD W. JONES
Member ID Number: 2301100755
Please note:All correspondence must Include the Member ID Number.
ORDER TO VACATE ATTACHMENT OF UNEMPLOYMENT BENEFITS
Financial Break Down of Multiple Cases on Attachment
PACSES Docket Attachment Ar r&
Plaintiff Nam Case Number Number *FreMncy.,
LORRIE A.JONES 394107723 01-1579 CIVIL 82MA MOWH
C::
TOTAL ATTACHMENT AMOUNT: $ 825.06
The prior Order of this Court directing the Department of Labor and Industry, Office of
Unemployment Compensation Benefits (OUCB), to attach$189.86 or 50% per week of
the Unemployment Compensation benefits of GERALD W. JONES, Social Security
Number XXX-XX-9905, Member ID Number 2301100755 is hereby vacated.
This Order to Vacate shall be effective upon receipt of the notice of the Order by the
Department and shall remain in effect until a further Order of the Court is filed.
BY THE COURT
Date of Order: APR 0 2 2013
4Ibert H. Masi-and— -JUDGE
Form EN-035
Service Type M Worker ID$1ATT