HomeMy WebLinkAbout01-03601
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NATALIE ANNE TAYLOR
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
01 - 3601
VB.
WILLIAM TAYLOR
NO.
CIVIL
19
IN DIVORCE
Defendant
STATUS SHEET
DATE:
ACTIVITIES:
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NATALIE ANNE TAYLOR,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 01 - 3601 CIVIL
WILLIAM TAYLOR,
Defendant
IN DIVORCE
TO: Diane G. Radcliff
, Attorney for Plaintiff
P. Richard Wagner , Attorney for Defendant
DATE: Wednesday, April 2, 2003
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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DIANE G. RADCLIFF, ESQUIRE
Attorney at Law
3448 Trindle Road
Camp Hill, Pennsylvania 170 II
Phone: (717) 737-0100
Facsimile: (717) 975-0697
February 2, 2004
E. Robert Elicker, II, Esquire
Cumberland County Divorce Master's Office
9 North Hanover Street
Carlisle, PA 17013
Re: Natalie A. (Taylor) Acri vs. William Taylor v. Thomas and Jean Blaine
Cumberland County Divorce Action No. 01-3601
Dear Divorce Master Elicker:
I am pleased to advise you that the parties have amicably resolved their differences
and entered into a Marital Agreement on February 2, 2004. Two (2) copies of that Marital
Agreement are enclosed with this letter.
In accordance with your standard procedure, I trust that you will secure the entry of
an order revoking your appointment.
Very truly yours,
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DGRldr
cc: P. Richard Wagner, Esquire
Natalie A. Acri
Thomas and Jean Blaine
File 28-02D
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NATALIE ANNE TAYLOR,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
PIaintift7Respondent,
v.
: NO: 01-3601
: CIVIL TERM
WILLIAM TAYLOR,
: IN DIVORCE
DefendantIPetitioner.
ORDER
AND NOW, this I Z. .... day of S!cro ~
2003, upon Petition of
William Taylor, a Rule is hereby issued upon the Respondent, Natalie.Anne Taylor,
and her par~nts, Thomas Blaine and Jeanile Blaine, to show cause why, if any, they
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shouid'~ot be joined as ~dispensable parties in the above-captioned divorce
proceeding.
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BY THE COURT:
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NATALIE ANNE TAYLOR,
: IN TIlE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
PIaintifi7Respondent,
v.
: NO: 01-3601
: CIVIL TERM
WILLIAM TAYLOR,
: IN DIVORCE
DefendantlPetitioner.
PETITION TO JOIN INDISPENSABLE PARTY
AND NOW, comes your Petitioner, William Taylor, by and through his
attorneys, Mancke, Wagner & Spreha, and files the following Petition to Join
Indispensable Party:
1. Your Petitioner, William Taylor, is the Defendant in the above-captioned
divorce action.
2. The Respondent, Natalie A. Taylor, is the Plaintiff in the above-captioned
divorce action.
3. Petitioner and Respondent herein are involved in the above-captioned
divorce proceeding having had a pre-hearing conference with the Master on
Monday, August 25, 2003.
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4. To properties are involved in the divorce proceeding, 63 N. 31 st Street,
Camp Hill, Cumberland County, Pennsylvania, and 103 N. Second Street,
W onnleysburg, Cumberland County, Pennsylvania.
5. Petitioner herein is asserting an interest in both properties, the
W onnleysburg property having his name on the Deed, and the Camp Hill property
having only the name of the Respondent's parents, Thomas Blaine and Jeanne
Blaine, having as an address 1709 Kent Road, Camp Hill, Cumberland County,
Pennsylvania.
6. Petitioner asserts that Petitioner and Respondent purchased property at
103 N. Second Street, Wonnleysburg, Cumberland County, Pennsylvania, for
which there is a mortgage on the property.
7. Petitioner asserts that Petitioner and Respondent lived at that property
until approximately 1996 when Petitioner and Respondent moved to 63 N. 31 st
Street, Camp Hill, Cumberland County, Pennsylvania, to a property which
Petitioner asserts ownership.
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8. From 1990, when the parties purchased the Wormleysburg property,
Petitioner has been paying the mortgage on the property, and continued to do so
until January of 2001.
9. In 1996, the W onnleysburg property was vacated by Petitioner and
Respondent, and the property was rented out to tenants, with tenants paying a
monthly rental.
10. The monthly rental was paid to Thomas Blaine and Jeanne Blaine, the
Respondent's parents; notwithstanding that the mortgage was still being paid by the
Petitioner herein.
11. The Respondent's parents, Thomas and Jeanne Blaine, used the rental
proceeds from the Wormleysburg property to pay the mortgage on the Camp Hill
property in which the Petitioner and the Respondent were residing.
12. At all times from the inception of both purchases, the Petitioner was lead
to believe by Respondent and Respondent's parents that Camp Hill and
W ormleysburg properties were both properties of Petitioner and Respondent only.
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13. Since the filing of the divorce action, Respondent and her parents have
now taken the position that the Petitioner has no interest in the Camp Hill property
and only a limited interest in the Wonnleysburg property.
14. Petitioner asserts that he has paid the mortgage from the inception of the
purchase of the Wonnleysburg property through January 2001, and further, that the
rental income from the W onnleysburg property was used by Thomas Blaine to pay
the mortgage on the Camp Hill property.
15. Petitioner believes and therefore avers that he has an equitable, if not
legal, interest in both properties.
16. Thomas Blaine and Jeanne Blaine are not parties to the divorce action.
17. Both properties in question contain the name of Thomas Blaine and
Jeanne Blaine on the Deed.
18. Petitioner believes and therefore avers that both are indispensable parties
to the divorce proceeding in order for the court to fashion an equitable distribution
order considering both properties.
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19. Petitioner believes and therefore avers that Thomas Blaine and Jeanne
Blaine of 1709 Kent Road, Camp Hill, Cumberland County, Pennsylvania, should
be joined as indispensable parties in the divorce proceeding.
WHEREFORE, Petitioner requests this Court to grant relief in the form of
joining the indispensable parties.
Respectfully submitted,
Mancke, Wagner & Spreha
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3103
2233 North Front Street
Harrisburg, P A 17110
(717) 234-7051
Attorneys for Petitioner
Date: 1/ g I fJ3
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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.
Section 4904, relating to unsworn
DATE:
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PEN NA.
NATALIE ANNE TAYLOR,
Plaintiff
No. 01-3601 CIVIL TERM
VERSUS
WILLIAM TAYLOR,
.
Defendant
DECREE IN
DIVORCE
.
AND NOW,
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DECREED THAT
NATALIE ANNE TAYLOR
PLAINTIFF,
AND
WILLIAM TAYLOR
DEFENDANT,
. ARE DIVORCED FROM THE BONDS OF MATRIMONY.
.
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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;
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OTHONOTARY
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IN THE COURT OF COMM.ON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
NATALIE ANNE TAYLOR
Plaintiff
V.
No. 01-3601 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
WILLIAM TAYLOR
Defendant
PRAECIPE OF TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with tbe following information, to the court for entry of a divorce decree:
1. GROUND FOR DIVORCE:
Irretrievable breakdown under Section 3301(d) of the Divorce Code.
2. DATE OF FILING AND MANNER OF SERVICE OF THE COMPLAINT:
a.
b.
c.
d.
e.
f.
Date of Filing of Complaint:
Manner of Service of Complaint:
Date of Service of Complaint:
Date of Filing of Amended Compliant:
Manner of Service of Amended Complaint:
Date of Service of Amended Complaint:
June 11,2001
Acceptance of Service by Defendant's Attorney
June 18, 2001
January 29, 2003
Regular First Class Mail upon Defendant's Attomey
January 29,2003
3. DATE OF EXECUTION OF THE AFFIDAVIT OF CONSENT REQUIRED BY SECTION 3301 (C) OF THE
DIVORCE CODE:
a. Plaintiff: March 15, 2003
b. Defendant: March 21, 2003
OR
DATE OF EXECUTION OF THE PLAINTIFF'S AFFIDAVIT REQUIRED BY SECTION 3301(D) OF THE
DIVORCE CODE AND DATE OF SERVICE OF THE PLAINTIFF'S 3301 (D) AFFIDAVIT UPON THE
DEFENDANT:
a. Date of Execution: N/A
b. Date of Filing: N/A
c. Date of Service: N/A
4. RELATED CLAIMS PENDING:
Equitable Distribution, Counsel Fees, Costs and Expenses. Divorce Bifurcated as per 3/21/03 Order
5. DATE AND MANNER OF SERVICE OF THE NOTICE OF INTENTION TO FILE PRAECIPE TO
TRANSMIT RECORD, A COPY OF WHICH IS ATTACHED, IF THE DECREE IS TO BE ENTERED
UNDER SECTION 3301(D)(I)(I) OF THE DIVORCE CODE:
a. Date of Service: N/A
b. Manner of Service: NI A
OR
DATE WAIVER OF NOTICE IN SECTION 3301(C) DIVORCE WAS FILED WITH THE
PROTHONOTARY:
a. Plaintiffs Waiver: March 21, 2003
b. Defendant's Waiver: March 21, 2003
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DCLIFF, ESQUIRE }
3 e Road
Camp Hill, PA 17011
Supreme Court ID # 32112
Phone: (717) 737-0100
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NATALIE A. TAYLOR,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY , PENNSYLVANIA
el.>'llY~
01- .Jle.or
NO.
WILLIAM S. TAYLOR,
Defendant
IN DIVORCE
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim 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 aunu1ment may be entered against you
by the Court. A judgement 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 gro\UleH'ordivorce is indignities or irretrievable breakdown of the marriage, you
may request marriage counseling. A list of marriage counselors is available in the Office of the
Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION 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 TillS PAPER TO YOUR LAWYER AT ONCE. 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
2 LffiERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
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NATALIE A. TAYLOR,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01- 3(,DI C~<..rrpu-
WILLIAM S. TAYLOR,
Defendant
IN DIVORCE
COMPLAINT
I. The Plaintiff is Natalie A. Taylor, Social Security number 202-46-5020, who
currently resides at 63 North 31" Street, Camp Hill, Cumberland County, Pennsylvania 170ll.
2. The Defendant is William S. Taylor, Social Security number 194-52-1745, who
currently resides at 427 South York Street, Mechanicsburg, Cumberland County, Pennsylvania
17055.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on October 13, 1989 at Dauphin County,
Pennsylvania.
COUNT I - DIVORCE
5. Paragraphs I through 4 of this Complaint are incorporated herein by reference as
though set forth in full.
6. There have been no prior actions of divorce or for annulment between the parties.
7. Divorce is sought pursuant to the provisions of the Divorce Code, Sections
3301(c) and 3301(d), in that:
a) The marriage is irretrievably broken.
b) Plaintiff and Defendant have lived separate and apart since January
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31,2001 and continue to do so.
8. The 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.
9. Defendant is not a member of the armed services.
WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree of Divorce.
COUNT II - EOUlTABLE DISTRIBUTION
10. Paragraphs I through 9 of this Complaint are incorporated herein by reference as
though set forth in full.
11. Plaintiff and Defendant have acquired property, both real and personal, during
their marriage from October 13,1989, until January 31,2001, the date of their separation, which
property is "marital property".
12. Plaintiff and Defendant may have owned, prior to the marriage, property which
has increased in value during the marriage and/or which has been exchanged for other property,
which has increased in value during the marriage, all of which property is "marital property".
13. Plaintiff and Defendant have been unable to agree as to an equitable division of
said property prior to the f1ling of this Complaint.
WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital
property .
Respectfully submitted,
Date (., '1- 01
!b~}4r
24 North 32nd Street
Camp Hill, PA 17011
(717) 737-1956
Attorney for Plaintiff LD. #59020
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VERIFICATION
I, NATALIE A. TAYLOR, verify that the statements made in the foregoing Complaint 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 6,-0'1- 0 I
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ATALIE A. TAYLOR
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NATALIE A. TAYLOR,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 01-3601 CIVIL TERM
WILLIAM S. TAYLOR,
Defendant
IN DNORCE
AFFIDAVIT OF ACCEPTANCE OF SERVICE
I, Richard Wagner, Esquire, accept service of the Divorce Complaint on behalf of
William S. Taylor, Defendant, in the above-captioned case and verify that I am authorized to do
so.
I verify that the statements made in this affidavit are true and correct. I understand that
'false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn
falsification to authorities.
DATE
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. 33 North Front Street
Harrisburg, PA 17110
Attorney for Defendant
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
NATALIE ANNE TAYLOR
,
Plaintiff
v.
: NO. 01-3601 CIVIL TERM
WILLIAM TAYLOR,
Defendant
: CIVIL ACTION - LAW
: DIVORCE
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following
pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you
and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered
against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property
or other rights important to you, including custody or visitation of your children.
When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request
marriage counseling. A list of marriage counselors is available in the Office ofthe Prothonotary at the Cumberland
County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES
OR EXPENSES BEFORE THE FINAL 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
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
NATALIE ANNE TAYLOR
,
Plaintiff
v.
: NO. 01-3601 CIVIL TERM
WILLIAM TAYLOR,
Defendant
: CIVIL ACTION - LAW
: DIVORCE
AMENDED COMPLAINT
AND NOW, this ~ay of~ ()n ~, 2003, comes the Plaintiff, Natalie Anne
Taylor, by her attorney, Diane G. Radcliff, Esquire, and files this Amended Complaint in Divorce
of which the following is a statement:
COUNT I
DIVORCE
1. The Plaintiff is Natalie Anne Taylor, an adult individual residing at 1755 Tarry Hall Road,
Millersburg, PA 17043.
2. The Defendant is William Taylor, an adult individual residing at 455 South York Street,
Mechanicsburg, PA 17055.
3. Plaintiff and/or Defendant have been bona fide residents of the Commonwealth for at least six (6)
months previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on October 13, 1989 at Harrisburg, P A .
5. The parties have lived separate and apart since January 29,2001.
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6. There have been no prior actions of divorce or annulment between the parties.
7. Plaintiff has been advised of the availability of counseling and the right to request that the Court
require the parties to participate in counseling.
8. The Defendant is not a member ofthe Armed Services of the United States or any of its Allies.
9. The Plaintiff avers that the grounds on which the action is based are:
a. Section 3301(c) Mutual Consent No-Fault: The marriage is irretrievably broken;
b. Section 3301(d) Non-Consent No-Fault: The marriage is irretrievably broken and the
parties are now living separate and apart. Once the parties have lived separate and apart for
a period of two years, Plaintiff will submit an Affidavit alleging that the parties have lived
separate and apart for at least two (2) years and that the marriage is irretrievably broken.
WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce, divorcing the
Plaintiff and Defendant.
COUNT II
EQUITABLE DISTRIBUTION
10. Paragraphs I through 9 are incorporated by reference hereto as fully as though the same were set
forth at length.
11. Plaintiff and Defendant have acquired property and debts, both real and personal, during their
marriage from October 13, 1989 until January 29, 2001, the date of separation, all of which are
"marital property" or "marital debts".
12. Plaintiff and/or Defendant have acquired, prior to the marriage or subsequent thereto, "non-marital
property" which has increased in value since the date of marriage and/or subsequent to its
acquisition during the marriage, which increase in value is "marital property".
13. Plaintiff and Defendant have been unable to agree as to an equitable division of said property and
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debts as of the date of the filing ofthis Complaint.
WHEREI'ORE, Plaintiff requests this Honorable Court to equitably divide all marital property and
debts of the parties.
COUNT III
ALIMONY PENDENTE LITE
14. Paragraphs I through 9 are incorporated by reference hereto as fully as though the same were set
forth at length.
15. Plaintiff lacks sufficient property to provide for her reasonable means and is unable to support
herself through appropriate employment.
16. Plaintiff requires reasonable support to adequately maintain herself in accordance with the standard
ofliving established during the marriage.
WHEREFORE, Plaintiff requests this Honorable Court to enter an award of alimony pendente lite.
COUNT IV
COUNSEL FEES, COSTS AND EXPENSES
17. Paragraphs I through 9 are incorporated by reference hereto as fully as though the same were set
forth at length.
18. Plaintiffhas employed Diane G. Radcliff, Esquire, as counsel but is unable to pay the necessary and
reasonable attorney's fees for said counsel.
19. The Plaintiff is in need of hiring various experts to appraise the parties' marital assets and does not
have the funds to pay the necessary and reasonable fees.
WHEREFORE, Plaintiffrequests this Honorable Court to enter an award of interim counsel fees,
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costs and expenses and to order such additional sums hereafter as may be deemed necessary and appropriate
and at final hearing to further award such additional counsel fees, costs and expenses as are deemed
necessary and appropriate.
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VERIFICATION
Uru.r1d...d
I, Natalie Anne Taylor, verify that the statements made in thi~Complaint are true and correct. I
understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904,
relating to unsworn falsification to authorities.
'--7~ ~q
NATALIE ANNE TAYLOR ~
Date:
/ IN! 03
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NATALIE ANNE TAYLOR,
Plaintiff
NO. 01-3601 CIVIL TERM
CIVIL ACTION - LAW
V.
IN DIVORCE
WILLIAM TAYLOR,
Defendant
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce
Code was filed on June 11, 2001.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of
filing and service of the Complaint.
3. I consent to the entry of a final Decree 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. 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: 3/lsj~3
/
~~
NATALIE ANNE TAYLOR
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NATALIE ANNE TAYLOR,
Plaintiff
NO. 01-3601 CIVIL TERM
CIVIL ACTION - LAW
V.
IN DIVORCE
WILLIAM TAYLOR,
Defendant
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce
Code was filed on June 11, 2001.
2.
The marriage of Plaintiff and Defendant
broken and ninety (90) days have elapsed
filing and service of the Complaint.
is irretrievably
from the date of
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. 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:
3
163
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NATALIE ANNE TAYLOR,
Plaintiff
NO. 01-3601 CIVIL TERM
CIVIL ACTION - LAW
V.
IN DIVORCE
WILLIAM TAYLOR,
Defendant
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER SECTION 3301(0) OF THE DIVORCE CODE
1. I ~onsent to the entry of a final decree in divorce without
notice.
2.
I understand that I may lose rights
division of property, lawyer's fees or
claim them before a divorce is granted.
concerning
expenses if
alimony,
I do not
3. I understand that I will not be divorced until a divorce
decree is entered by the Court and that a copy of the decree
will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904 relating to
unsworn falsification to authorities.
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NATALIE ANNE TAYLOR
Dated:
3J;y /D.3
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NATALIE ANNE TAYLOR,
Plaintiff
NO. 01-3601 CIVIL TERM
CIVIL ACTION - LAW
V.
IN DIVORCE
WILLIAM TAYLOR,
Defendant
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER SECTION 3301(0) OF THE DIVORCE CODE
1. I consent to the entry of a final decree in divorce without
notice.
2.
I understand that I may lose rights
division of property, lawyer's fees or
claim them before a divorce is granted.
concerning
expenses if
alimony,
I do not
3. I understand that I will not be divorced until a divorce
decree is entered by the Court and that a copy of the decree
will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904 relating to
unsworn falsification to authoritie
Dated:~a( ( 63
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NATALIE ANNE TAYLOR,
Plaintiff
NO. 01-3601 CIVIL TERM
CIVIL ACTION - LAW
V.
IN DIVORCE
WILLIAM TAYLOR,
Defendant
INVENTORY OF NATALIE ANNE TAYLOR
Plaintiff files the following inventory of all property owned or possessed by either party at
the time this action was commenced and all property transferred within the preceding three years.
Plaintiff verifies that the statements made in this inventoi} 1 true and correct. Plaintiff
understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section
4904 relating to unsworn falsification to authorities.
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PLAIN II.;F '
Dated:
Dated:
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ASSETS AND LIABILITIES OF PARTIES
Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets
and debts on the following pages:
(X) 1.
(X) 2.
() 3.
() 4.
() 5.
() 6.
() 7.
() 8.
0 9.
() 10.
() 11.
() 12.
() 13.
() 14.
() 15.
() 16.
() 17.
(X) 18.
() 19.
() 20.
() 21.
() 22.
() 23.
() 24.
(X) 25.
() 26.
(x) 27.
(X) 28.
(X) 29.
Real property and Real Estate Mortgages
Motor vehicles and Vehicle Liens
Stocks, bonds, securities and options
Certificates of Deposit
Checking accounts, cash
Savings accounts, money market and savings certificates
Contents of safe deposit boxes
Trusts
Life Insurance policies (indicate face value, cash surrender value and current beneficiaries)
Annuities
Gifts
Inheritances
Patents, copyrights, inventions, royalties
Personal property outside the home
Business (list all owners, including percentage of ownership, and officer/director positions
held by a party with company)
Employment termination benefits - severance pay, worker's compensation claim/award
Profit sharing plans
Pension Plans (indicate employee contribution and date plan vests)
Retirement plans, Individual Retirement Accounts
Disability payments
Litigation claims (matured and unmatured)
Military/VA benefits
Education benefits
Debts due, including loans, mortgages held
Household furnishings and personalty (include as a total category and attach itemized list
if distribution is in dispute)
Other assets
Loans
Credit Cards
Other Debts
Page 2
.-- .
I. MARIT A
Plaintiff lists all marital property in which either or both spouses have a~Jegal or equitable interest,
individually or with any other person as of the date of separation and, all marital liabilities owed by either or both
spouse-s, individually or with any other person as of the date of separation:
MARITAL PROPERTY AND LIABILITIES
NO
VALUE OF
ASSET OR
LIABILITY
REAL ESTATE AND REAL ESTATE MORTGAGEl:i (INVENTORY #1)
ITEM 1. (REAL ESTATE #1)
DESCRIPTION OF
PROPERTY OR LIABILITY
DATE OF
VALUE
NET VALUE
PROPOSED
DISTRIBUTION
TO HUSBAND
PROPOSED
DISTRIBUTION
TO WIFE
103 Noah 20' Street
Wormleysburg, Pa
Tax #47-20-1858-029
7.1.00
55,060,00
Mortgage
Acc!. #!1
12.31.02
(17,656.06)
Excess-down Payment Made by
Pa rents
(1,107.12)
2001 loss
(1,419.73)
(3,210.78)
(739.82)
30,926.49
15,463.25
15,463.25
15,463.25
2002 loss
2003 loss for 6 months
Net Eqully
Half of Equity
COMMENTS:
This property was acquired on 6/8/90 for $55,900.00, The property is held in the joint names of the parties (50%) and wife's
parents (50%). There was a $1,000.00 deposit and $6,107.12 paid in closing costs for a total of $7,1 07.12. The remainder was
financed with a mortgage in the amount of $49,900.00. The closing costs were paid $3,000.00 by the parties and $4,107.12 by
wife's parents, Thomas and Jean Blaine ($1,107.12 difference)
Until 1996 the mortgage payments were paid by Husband and Wife since there were residing in the property.
7.1.00 aM 1/1/02 tax assessment value is $55,060.00. ..[
12.31.00 mortgage balance @ $25,874.57..[
12.31.01- mortgage balance @ $21,979.84. ..[
12.31.02 mortgage balance @ $17,656.06..[
NATALIE (TAYLOR) ACRI VS. WILLIAM TAYLOR
001'1 10/13/89
DOS 1/29/01
Page 3
MARITAL PROPERTY AND LIABILITIES
NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED
PROPERTY OR LIABILITY VALUE ASSET OR DISTRIBUTION DISTRIBUTION
LIABILITY TO HUSBAND TO WIFE
Rents for 2001 -
Rent $7,140.00
Expenses ($4.665.00)
Net Before Depreciation $2,475.00 -,
-
Mortgage Principal Payments ($3.894.73) -
Net Loss (-$1,419.73)
Rents for 2002
Rent $7,140.00
Expenses 1$6.027.00)
Net Before Depreciation $1,113.00
Mortgage Principal Payments 1$4.323.78)
Net Loss (-$3,210.78) -
Estimated Rents for 2003
Rent $7,140.00 -
Expenses ($8.619.63)
Net Loss (-$1,479.63)
The breakdown of the estimated expenses for 2003 are as follows:
Mortgage payments =$534.08Imonth wlo escrows or $6,408.96/yr.l -
2003 County-Municipal taxes face = $208.56..[
2002 School taxes face = $556.11 ..[
2003 Insurance = $402.00. ..[
Sewer@ est. based on 2002 = $440.00..[
Misc. Exp @ est. based on 2002 = $212.00..[ ..
Repairs est. based on 2002 = $392.00 ..[
MOTOR VEHICLES AND VEHICLE LIENS (INVENTORY #2)
ITEM 2 (VEHICLE #1)
1991 DO'dge Caravan TBD
COMMENTS:
Wife used this vehicle. It was titled in the name of husband's mother. After separation wife returned this vehicle to husband's
mother since she threatened to have her arrested if she id not. It is undetermined if the parties have any legal or equitable
interest in this vehicle.
ITEM 3 (VEHICLE #2)
Husband's Old Ford Truck
COMMENTS:
This is an older vehicle and probably of minimal value. -
NATALIE (TAYLOR) ACRI VS. WILLIAM TAYLOR
DOM 10 /13/ 8 9
DOS 1/29/01
Page 4
. ,
. --'
MARITAL PROPERTY AND LIABILITIES
NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED
PROPERTY OR LIABILITY VALUE ASSET OR DISTRIBUTION DISTRIBUTION
LIABILITY TO HUSBAND TO WIFE
,-
EMPLOYMENT PENSION & RETIREMENT PLANS (INVENTORY #18)
ITEM 4 (RETIREMENT #1)
Husband's SERS Pension 1.29.01 73,657.70 73,657.70 73,657.70
COMMENTS:
12.31.99 present value assigned by the State Is $48,566.11.
1.29.01. present value assigned by State is $73,657.70 including contribution account of $18,799.80
This pension has not yet been valued by an actuary. Actuarial value may be more or less toan above stated amount.
,
HOUSEHOLD GOODS AND FURNISHINGS (ATTACHED LIST IF IN DISPUTE) (INVENTORY #25)
ITEM 5 (PERSONAL PROPERTY #1)
Husband's Household Goods
N/A
N/A
N/A
COMMENTS:
Wife believes distribution shouid remain as Is. Therefore no dollar figure has been Inserted hereiQ.
ITEM 5 (PERSONAL PROPERTY #2)
Wife's Household Goods
N/A
N/A
N/A
Wife believes distribution shouid remain as is. Therefore no dollar figure has been inserted herei'2'
CREDIT CARDS, LOANS AND OTHER DEBTS (INVENTORY #27,28 &29)
ITEM 6 (DEBT #1)
VISA
N/A
N/A
This aCJ::.ount had a balance of $2,000.00 at or near separation. The creditor sued both of the parties and lost. It is therefore
believed that neither party has any liability for this debt. _
ITEM 7 (DEBT #2)
Thomas and Jean Blaine
92-96
(16,074.35)
Wife's parents lent husband various sums of money to be determined but no less than $16,074.35 including:
Cash deposited into account @ $6,910.00.[ =
Shell Oil for repairs to auto@ $510.00.[ =-
Credit Card and misc. bills $6,520.35 ,f -
Attorney Fees @ $1,000.00..[ -
Auto Repairs @ $1,134.00 .[
TOTALS
TOTAL OF ASSETS AND LIABILITIES
89,120.95
73,657.70
15,463.25
NATALIE (TAYLOR) ACRI VS. WILLIAM TAYLOR
DOM 10/13/89
DOS 1/29/01
Page 5
. .
MARITAL PROPERTY AND LIABILITIES
NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED
PROPERTY OR LIABILITY VALUE ASSET OR DISTRIBUTION DISTRIBUTION
LIABILITY TO HUSBAND TO WIFE
- ,-"....,..~,~-,-. ._~~ _~.-''':"= --"::_~~"="_.__'n__ _::tl.;.iT""'2:""- -~- ~_..
PERCENTAGE OF DISTRIBUTION -~
Totals fr9m above 89,120.95 73,657.70 15,463.25
Percentage of Total Net Marital Estate 82.65% 17.35%
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ADJUSTMENT FOR 50150 DIVISION
Totals from above 89,120.95 73,657.70 15,463.25
Amount Due in 50/50 Division 44,560.47 44,560.47
Adjustment figure for 50150 Division (29,097.23) 29,097.23
. - ..._-, "-, ~-- - ___......._~);i:;~.".~:::, - .~- ' '
ADJUSTMENT FOR 45155 DIVISION
Totals from above 89,120.95 73,657.70 15,463.25
Amount Due in 45155 Division 40,104.43 49,016.52
Adjustment Figure for 45155 Division (33,553.27) 33,553.27
~~ ..
ADJUSTMENT FOR 40/60 DIVISION
Totals {rom above 89,120.95 73,657.70 15,463.25
Amount Due in 40160 Division 35.648.38 53,472.57
Adjustment Figure for 40160 Division (38,009.32) 38,009.32
NATALIE (TAYLOR) ACRI VS. WILLIAM TAYLOR
DOM 10/13/89
DOS 1/29/01
Page 6
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COMMENTS:
1. The adjustment figures are for illustration purposes only and are not to be deemed a representation by
the submitting party that an adjustment should be made or the amount of any adjustment.
NATALIE (TAYLOR) ACRI VS. WILLIAM TAYLOR
DOM lC)/13/89
DOS 1/29/01
Page 7
. .
< ~.
II. LISTING OF HOUSEHOLD GOODS AND CONTENTS
Plaintiff lists all household goods and contents in which either or both spouses have a legal or equitable interest,
individually or with any other person as of the date of separation, the total value of which iS$pecified in Section I. above:
(Note: Exclusions from marital property include property acquired before marriage, property acquired after
separation, or property acquired during marriage by way of gift or inheritance from third party not a spouse. For
gifts and inheritance also specify the source person).
HOUSEHOLD GOODS AND CONTENTS
NO. DESCRIPTION OWNER POSSESSOR VALUE COMMENTS AND/OR METHOD OF
BASIS FOR EXCLUSION VALUATION AND
IF CLAIMED TO BE NON SUPPORTING
MARITAL DOCUMENTATION
N/A
NATALIE (TAYLOR) ACRI VS. WILLIAM TAYLOR
DOM 10/13/89
DOS 1/29/01
Page 8
III. NON-MARITAL PROPERTY AND L1ABH...ITIES
Plaintiff lists all property and/or debts in which a spouse had a legal or equitable interest or owed as of the date
of separation which is claimed to be excluded from marital property.
(Note: Exclusions from marital property include property acquired before marriage, property acquired after
separation, or property acquired during marriage by way of gift or inheritance from third party not a spouse. For
ifts and inheritance also specify the source person).
NON-MARITAL PROPERTY AND DEBTS
DESCRIPTION OWNER POSSESSOR VALUE COMMENTS ANDIOR METHOD OF
BASIS FOR EXCLUSION VALUATION AND
IF CLAIMED TO BE NON SUPPORTING
MARITAL DOCUMENTATION
63 North 31" Street Thomas Thomas and 127,000.00 Property belong" to wife's Est.
Camp Hill, Pa 17011 and Jean Jean Blaine's Parents
Tax #01-21-0273-272 Blaine rental
COMMENTS:
This property was acquired on 6/14/96 for $79,OOO.00.,f Wife's parents, Thomas and Jean Blaine paid the $3,000.00 deposit
and $15,525.79 in down payment and closing costs for a total of $18,525.79.,f The remainder was financed by a mortgage in
the amount of $63,000.00 @$577.31/moJ
This property is titled in the names of wife's parents, Thomas G. Blaine and Jeanne R. Blaine.,f Wife's parents have all of the
mortgage payments, taxes and insurance since date of purchase.
7.1.02.Tax assessment value is $127,010.00,f -
2.10.03 mortgage baiance = $51,298.83 ,f
DOS mortgage balance @ $56,798.00
Mortgage payment = $577.31 w/o escrows.,f
2003 County-Municipal taxes = $542.71 per yr. Face ($45.23 per month},f
2002 School taxes = $1,413.62 per yrface ($117.80 per mo.},f
2002 Insurance = $437.00 per yr. ($36.42 per month)
TOTAL monthly costs wlo utilities and repairs = $776.76
Wife and her parents, Thomas and Jean Blaine, claim this property belongs to her parents, that the parties have no interests in
this property, and that this property is not subject to equitable distribution. The property was purchased by wife's parents as an
investment to be able to fund the parties' chiidren's college education. --
Husbao_d claims this property is a marital asset. It is wife's position that if it was intended that either of the parties have an
interesl in Ihis property it would have been a gift to wife of no more than a half share.
NATALIE (TAYLOR) ACRI VS. WILLIAM TAYLOR
DOM 10 / 13 / 8 9
DOS 1/29/01
Page 9
. ,
IV. PROPERTY TRANSFERRED
Plaintiff lists all property which was transferred within 3 years of the date of the commencement of this action orwas transferred since
the date of separation:
PROPERTY TRANSFERRED
NO. DESCRIPTION OF TRANSFER CONSIDERATION TRANSFEREE COMMENTS
PROPERTY DATE
None Known
NATALIE (TAYLOR) ACRI VS. WILLI~l TAYLOR
DO['1 10 / 13 / 8 9
DOS 1/29/01
Page 10
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CERTIFICATE OF SERVICE
AND NOW, this dlSJay of May, 2003, I, DIANE G. RADCLIFF, ESQUIRE, hereby
certify that I have this day served a copy of the within INVENTORY, upon the following set
forth person, by mailing same by first class mail, postage prepaid, addressed as follows:
P. Richard Wagner, Esquire
2233 North Front Street
Harrisburg, PA 17110
Respectfully submitted,
/
NATALIE (TAYLOR) ACRI VS. WILLIAM TAYLOR
DOM 1 0 /13 / 8 9
DOS 1/29/01
Page 11
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Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - LAW
NO. 01 - 3601 CIVIL
WILLIAM TAYLOR,
Defendant
IN DIVORCE
NOTICE OF PRE-HEARING CONFERENCE
TO: Diane G. Radcliff
, Attorney for Plaintiff
P. Richard Wagner
, 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 August 2003, at
1:30 p.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: 6/16/03
E. Robert Elicker, II
Divorce Master
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OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240-6535
E. Robert Elicker, II
Divorce Master
Traci do Colyer
Office Manager/Reporter
West Shore
697-0371 Ext. 6535
May 19, 2003
Diane G. Radcliff
Attorney at Law
3448 Trindle Road
Camp Hill, PA 17011
P. Richard Wagner
Attorney at Law
MANCKE, WAGNER & SPREHA
2233 North Front Street
Harrisburg, PA 17110
RE: Natalie Anne Taylor vs. William Taylor
No. 01 - 3601 Civil
In Divorce
Dear Ms. Radcliff and Mr. Wagner:
I have received an amended decree in divorce dated April 21, 2003,
indicating that the economic claims pending and preserved for the
Master are equitable distribution and counsel fees and costs.
In accordance with P.R.C.P. 1920.33(b) I am directing each counsel
to fIle a pretrial statement on or before Friday, June 13,2003. Upon
receipt of the pretrial 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
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19 May 2003
Page 2
NOTE:
Sanctions for failure to file the pretrial statements are set
forth in subdivision (cl and (d) of Rule 1920.33.
THE ORIGINAL PRETRIAL STATEMENT SHOULD BE FILED
IN THE MASTER'S OFFICE AND A COPY SENT DIRECTLY
TO OPPOSING COUNSEL.
FAILURE TO FILE PRETRIAL STATEMENTS AS DIRECTED
BY THE MASTER MAY RESULT IN THE MASTER'S
APPOINTMENT BEING VACATED.
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
.
.
PENNA.
STATE OF
.
.
NATALIE ANNE TAYLOR,
.
Plaintiff
No. 01-3601 CIVIL TERM
.
.
VERSUS
WILLIAM TAYLOR,
.
Defendant
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DECREE IN
DIVORCE
.
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IT IS ORDERED AND
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AND NOW,
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DECREED THAT NATALIE ANNE TAYLOR
, PLAINTIFF,
AND WILLIAM TAYLOR
, 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;
.
EQUITABLE DISTRIBUTION, COUNSEL FEES AND COSTS
.
.
.
.
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By THE COURT:
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PROTHONOTARY
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APR 1 6 ZDD3 ~
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
NATALIE ANNE TAYLOR,
Plaintiff
NO. 01-3601 CIVIL TERM
CIVIL ACTION - LAW
V.
IN DIVORCE
WILLIAM TAYLOR,
Defendant
MOTION AND AUTHORIZATION
AND NOW, to wit, this /ol{hdayof (lph'L ,2003, we, the undersigned legal counsel for
the parties, hereby move and authorize this Honorable Court to enter an Amended Decree in
Divorce amending the Divorce Decree entered on March 26, 2003 to specifically provide for
retention of jurisdiction over the claims of equitable distribution, counsel fees and costs heretofore
raised of record prior to the entry of the March 26,2003 Divorce Decree.
Respectfully submitted,
. RADCLIFF, ESQUI
48 Tri e Road
Camp Hill, PA 17011
Attorne for Plaintiff
\
RD WAGNER, ESQUIRE
2233 North Front Street
Harrisburg, PA 17110
Attorney for Defendant
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYL VANIA
,
NATALIE ANNE TAYLOR,
Plaintiff
NO. 01-3601 CIVIL TERM
CIVIL ACTION - LAW
v.
IN DIVORCE
WILLIAM TAYLOR,
Defendant
MOTION FOR APPOINTMENT OF MASTER
Natalie Anne Taylor, Plaintiff, moves the Court to appoint a Master with respect to the following claims:
[ ] Divorce [ ] Distribution ofproperty
[ ] Annulment [ ] Support
[ ] Alimony [X] Counsel Fees
[ ] Alimony Pendente Lite [X ] Costs and Expenses
In support of the Motion the Plaintiff states:
1. Discovery is complete with respect to the claims for which the appointment of the Master is requested.
2. The Defendaot [X] has [ ] has not appeared in the action [] personally [X] by his attomey, P. Richard Wagner, Esquire.
3. The statutory ground for the divorce is/are: Section 3301 (c) No-Fault
4. Check the applicable paragraphs:
[] The action is not contested.
[] An agreement has been reached witb respect to tbe following claims:
[X] The action is contested with respect to tbe following claims: All claims
5. The hearing is expected to take one (1) day.
Date: .3...
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6.
Additional inti rmation, if any, relevant to the motion:
e
ORDER APPOINTING MASTER
AND NOW, 1M ~ /2003, E. Robert Elicker, II, Esquire, is appointed Master with respect to tbe following claims:
,
[ ] Divorce
[ ] Annulment
[ ] Alimony
[ ] Alimony Pendente Lite
[X] Distribution of Property
[ ] Support
[X] Counsel Fees
[X] Costs and Expenses
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LAW OFFICES
MANCKE, WAGNER, TULLY & SPREHA
JOHN B. MANCKE
P. RICHARD WAGNER
WILLIAM T. TULLY
EDWARD F. SPREHA, JR.
2233 NORTH FRONT STREET
HARRISBURG,
PA
17110
PHONE (717) 234~70S1
FAX (717) 234-7080
April 7, 2003
E. Robert Elicker, Esquire
9 North Hanover Street
Carlisle, P A 17013
Re: Taylor v. Taylor
No: 01-3601
Dear Mr. Elicker:
Enclosed herein please find the Certification on behalf of my client, William
Taylor.
Your attention is appreciated. /"---7
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Enclosure
cc: Diane Radcliff, Esq. (w/encl.)
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NATALIE ANNE TAYLOR,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 01 - 3601 CIVIL
WILLIAM TAYLOR,
Defendant
IN DIVORCE
TO: Diane G. Radcliff
Attorney for Plaintiff
P. Richard Wagner , Attorney for Defendant
DATE: Wednesday, April 2, 2003
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.
1/1/!J 7;
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COUNSEL
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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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DIANE G. RADCLIFF, ESQUIRE
Attorney at Law
3448 Triodle Road
Camp Hill, Pennsylvania 17011
Phone: (717) 737-0100
Facsimile: (717) 975-0697
April 7, 2003
E. Robert Elicker, II, Esquire
Cumberland County Divorce Master's Office
9 North Hanover Street
Carlisle, PA 17013
Re: Nata~ie Anne Tay~or (now Nata~ie Acri) VS. Wi~~iam Tay~or
Cumber~and County Divorce Action
Docket No. 01-3601 Civi~ Term
Dear Divorce Master Elicker:
I am enclosing with this letter the signed Certification of
Completion of Discovery
Very
truly yours,
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DGR/dr
Enclosures:
Discovery Certification
cc: P. Richard Wagner
Natalie Taylor Acri
File 28-02D
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NATALIE ANNE TAYLOR,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 01 - 3601 CIVIL
WILL1AM TAYLOR,
Defendant
IN DIVORCE
TO: Diane G. Radcliff
, Attorney for Plaintiff
P. Richard Wagner , Attorney for Defendant
DATE: Wednesday, April 2, 2003
~ ~ CERTIFICATION
.~---'Jx. t/I certify that discovery is complete as to the claims
" 'for which the Master has been appointed.
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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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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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SOCIAL SECURITY INFORMATION SHEET
PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1, ALL DIVORCES MUST INCLUDE THE
PARTIES' SOCIAL SECURITY NUMBERS. PLEASE FILL IN THE APPROPRIATE
INFORMATION AND RETURN TO THE PROTHONOTARY'S OFFICE.
DATE March 21, 2003
COUNTY Cumberland County, PA
DOCKET NUMBER No. 01-3601 Civil Term
PLAINTIFF'S NAME Natalie Anne Taylor
PLAINTIFF'S SS # 202-46-5070
DEFENDANT'S NAME William Taylor
DEFENDANT'S SS# 194-52-1745
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NATALIE ANNE TAYLOR,
Plaintiff
NO. 01-3601 CIVIL TERM
CIVIL ACTION - LAW
V.
IN DIVORCE
WILLIAM TAYLOR,
Defendant
RE; BIFURCATION
ORDER
AND NOW, this iV' day of h)tJ<..c.ir ,2003, in consideration of the within Stipulation, IT IS HEREBY
ORDERED AND DECREED THAT:
1. This divorce action is hereby bifurcated so that a divorce decree under Section 3301(c) of the
Divorce Code can be entered with reservation of jurisdiction over all claims raised by either party
prior to the entry of said decree.
2. The parties have executed and filed or shall execute and file, their respective Affidavits of Consent,
Waivers of Notice ofIntention to Request Entry of Divorce Decree. Upon entry ofthis Order and
filing of the Affidavits and Waivers aforesaid, Plaintiff shall prepare and file all documents
necessary to secure the entry of the bifurcated divorce decree.
3. Pending further order of this Court, neither party will transfer any property or asset that is subject
to equitable distribution, or claimed to be subject to equitable distribution by either party. Further
neither party will incur any indebtedness, liens encumbrances or judgments against any such
property or asset.
4. Pending further order of Court neither party will change any beneficiary designation on any life
insurance policy or retirement death benefits as such designation was immediately prior to the
parties separation. If such beneficiary designation has been changed, within five (5) days of the date
of this Order the party responsible for the change will change that designation back to the
designation immediately prior to the parties separation.
5. Wife will file a Motion for Appointment of Master on all outstanding claims on the date ofthe entry
of this Order.
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6. Under and subject to the foregoing terms, this Court will enter the Divorce Decree under Section
3 3 0 1 (c) of the Divorce Code upon presentation of appropriate and required documents and papers.
That divorce decree shall contain a specific reservation of jurisdiction over all claims raised by
either party prior to the entry of said decree.
BY THE COURT:
4J-
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Distribution to:
ATTORNEY FOR PLAINTIFF:
Diane G. Radcliff, Esquire
3448 Trind1e Road
Camp Hill, PA 17011
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ATTORNEY FOR DEFENDANT:
P. Richard Wagner, Esquire
2233 North Front Street
Harrisburg, PAl 711 0
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
NATALIE ANNE TAYLOR
,
Plaintiff
NO. 01-3601 CIVIL TERM
CIVIL ACTION - LAW
V.
IN DIVORCE
WILLIAM TAYLOR,
Defendant
RE: BIFURCATION
STIPULATION
s"'t ()
AND NOW, this 2.1 day of (har~ , 200~ come the Plaintiff, Natalie Anne Taylor and the
Defendant, William Taylor, and stipulate and agree as follows;
1. This divorce action shall be bifurcated so that a Divorce Decree under Section 3301(c) of the
Divorce Code can be entered with reservation of jurisdiction over all claims raised by either party
prior to the entry of said decree.
2. The parties agree that their marriage is irretrievably broken and that they consent to the divorce.
Concurrently with the signing of this Stipulation the parties shall execute and file their respective
Affidavits of Consent, Waivers of Notice ofIntention to Request Entry of Divorce Decree. Upon
entry of the Order bifurcating this divorce action, Plaintiff, shall prepare and file all documents
necessary to secure the entry of the bifurcated Divorce Decree.
3. Pending further order ofthis Court, neither party will transfer any property or asset that is subject
to equitable distribution, or claimed to be subject to equitable distribution by either party. Further
neither party will incur any indebtedness, liens encumbrances or judgments against any such
property or asset.
4. Pending further order of Court neither party will change any beneficiary designation on any life
insurance policy or retirement death benefits as such designation was immediately prior to the
parties separation. If such beneficiary designation has been changed, within five (5) days of the date
of this Order the party responsible for the change will change that designation back to the
designation immediately prior to the parties separation.
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5. Wife will file a Motion for Appointment of Master on all outstanding claims on the date of this
Stipulation and the order to be entered pursuant hereto.
6. The parties authorize the Court to enter an order incorporating the terms ofthis Stipulation.
IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year
below written.
PLAINTIFF'S ATTORNEY:
PLAINTIFF:
G. DCLI/cF.ESQm
2> ILL (j :)
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NATALIE ANNE TAYLO
3/ Lt /Zl ~
Date:
Date:
DEFENDANT'S ATTORNEY:
DEFENDANT:
Date:
CRA WAGNER, ESQUIRE
Date: 3( 2-t f 03
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LAW OFRCES
JOHN B. MANCKE
P. RICHARD WAGNER
EDWARD F. SPREHA. JR.
MANCKE, WAGNER & SPREHA
2233 NORTH FRONT STREET
HARRISBURG. PA 17110
PHONE (717) 234-7051
FAX (717) 234-7080
June 13,2003
Hand Delivered
E. Robert Elicker, Esquire
9 North Hanover Street
Carlisle, PA 17013
Re: Taylor v. Taylor
Dear Mr. Elicker:
Enclosed herein please find the Pre-Trial Statement on behalf of my client,
William Taylor.
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Your attention is appreciated.
PRW/dks
Enclosure
cc: Diane G. Radcliff, Esq. (w/encL)
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NATALIE ANNE TAYLOR,
Plaintiff
NO. 01-3601 CIVIL TERM
CIVIL ACTION - LAW
V.
IN DIVORCE
WILLIAM TAYLOR,
Defendant
INCOME AND EXPENSE STATEMENT OF NATALIE ANNE TAYLOR
I verify that the facts set forth in the following Income and Expenses Form, including all
attachments thereto, 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: J/I/OJ
71_d'e.'&~
NATALIE ANNE TAYLOR
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PART I. INCOME
A. EMPLOYMENT INFORMATION:
EMPLOYER: Halifax School District
ADDRESS: Halifax, PA
POSITION: Substitute Teacher
PAYROLL NUMBER: 202-46-5070
PAY PERIOD: Biweekly
B. EMPLOYMENT INCOME:
DESCRIPTION AMOUNT
GROSS PAY PER PAY PERIOD 320.00
FICA OR SE TAX (19.84)
MEDICARE OR SE TAX (4.64)
FEDERAL TAX
STATE TAX (8.96)
LOCAL TAX (3.20)
MANDATORY RETIREMENT
UNION DUES
VOLUNTARY RETIREMENT
HEALTH INSURANCE
NET PAY PER PAY PERIOD 283.36
NET PAY PER MONTH $613.95
Note: Plaintiff was off of work until mid-February, 2003 due to ill health. She returned to
work on a part time basis against her physician's instructions. This employment will end as
of the end of March, 2003. She will not be returning to work after that date due to health
problems. Her anticipated income for 2003 from the above will be $1 ,300.00 and no more
than an additional $700.00 for occasional part time work after April 1 , 2003.
- 2 -
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C. OTHER INCOME:
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INTEREST
DIVIDENDS
PENSIONS
ANNUITIES
SOCIAL SECURITY
RENTS
ROYAL TIES
EXPENSE ACCOUNT
GIFTS
UNEMPLOYMENT COMPENSATION
WORKMAN'S COMPENSATION
INCOME TAX REFUNDS
CHILD SUPPORT 881.00 1 0,582.00
COMMISSIONS
TIPS
OTHER
SPECIFY:
TOTAL OTHER INCOME $881.00 $10,582.00
- 3 -
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PART II. EXPENSES
Note: Expenses in Household Column representtotal expenses for the household. These
are included since they are shared between Plaintiff and her fiancee.
DESCRIPTION HOUSEHOLD MONTHLY
AMOUNT AMOUNT
HOM,E EXPEN'SES:
Rent $400.00
First Mortgage $1,133.00
Second Mortgage/Home Equity Loan
Maintenance And Repairs $50.00
Electric $250.00 $100.00
Gas
Oil
Telephone $25.00
Water
Sewer
Trash
EMPLOYMJ;NT
Public Transportation
Lunches
Other Employment Expenses
.
TAXES:
Real Estate Taxes Included in
mortgage
Personal Property Taxes
Income Taxes Not Withheld
Per Capita/Occupation Taxes
- 4 -
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DESCRIPTION HOUSEHOLD MONTHLY
AMOUNT AMOUNT
INSUMNCE: :1
Homeowners Insurance $450.00
Automobile Insurance
Life Insurance $30.00
Accident Insurance
Health Insurance
Other Insurance
AUT:~MSBILE E~P:EiN'SIS$:
Payments
Fuel $150.00
Maintenance And Repair $42.00
License And Registration $3.00
ME~ICAL"E*PEN$ESN'ti)tR:iSW~fS1~i~'$lli~
BY U'\IiSURANCE:
Doctor $20.00
Optical $10.00
Dental
Orthodontic
Hospital
Medicine $30.00
Special Needs/Therapy Etc.
- 5 -
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DESCRIPTION HOUSEHOLD MONTHLY
AMOUNT AMOUNT
EDWCATIONAl EXPEISIS'8S: "
, ,
Private School
Parochial School
CollegeNocational
Religious Training or Education
Books/Fees And Supplies $10.00
Other Educational Expenses $120.00
School Lunches
PERSONAL EXPENSES:
Clothing $150.00
Food $600.00 $400.00
Barber And Hair Dresser $50.00
Memberships $41.00
Other Personal Expenses $40.00
Children's activities
CREIilIT CARIilS AN'Iil'b:0Af$lIS: ,
,
No Ctedilpt ' . 'Btl!la!lli'G'e
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1. Hecht's 1000 $60.00
MISCEllANEOUS! E*~;EN'SE!S:
Household Help
Child Care
Newspapers/Magazines/Soaks $10.00
Entertainment $75.00
Pay TV
Vacations $250.00
Gifts $375.00
- 6 -
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DESCRIPTION HOUSEHOLD MONTHLY
AMOUNT AMOUNT
Legal Fees $200.00
Charitable Contributions
Other Child Support
Other Spousal Support or Alimony
Veterinary Bills $60.00
TOTAL EXPENSES $2,651.00
- 7 -
PART III. PROPERTY OWNED
PROPERTY OWNED OWNERSHI
P
TYPE DESCRIPTION VALUE H W JT
Checking
Savings Belco $50.00 x
Credit Union
Stocks/bonds
Real Estate 103 N. 21st Street, Wormleysburg, PA $7,500.00
Other
PART IV. INSURANCE
INSURANCE INFORMATION COVERAGE
TYPE COMPANY POLICY NO. H W C
Hospital PA Blue Cross 194521745 x x x
Medical PA Blue Cross 194521745 x x x
Health Accident
Disability Income
Dental PA Blue Cross 194521745 x x x
Vision
Other-Specify
*H=Husband; W=Wife; J=Joint; C=Child
- 8 -
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PART V. SUPPLEMENTAL INCOME STATEMENT
[I] CHECK HERE IF NOT APPLICABLE
(a) This form is to be filled out by a person:
(1) Who operates a business or practices a profession, or
(2) Who is a member of a partnership or joint venture, or
(3) Who is a shareholder in and is salaried by a closed
corporation or similar entity.
(b) Attach to this statement a copy of the following documents relating to the partnership, joint venture,
business, profession, corporation or similar entity (check block to indicate the document is attached):
(1) The most recent Federal Income Tax Return. [] attached
(2) The most recent Profit and Loss Statement. [ ] attached
Business Address:
(c) Name of Business:
Business Telephone:
(d) Nature of Business (check one)
[] 1. Sole Proprietorship
[] 2. Partnership
[] 3. Joint Venture
[] 4. Professional
[] 5. Corporation
[] 6. Other
(e) Name of accountant, controller or other person
in charge of financial records:
(f) Business Income:
1. Annual income from business:
2. How often is income received:
3. Gross income per pay period
4. Net income per pay period
5. Specify deductions, if any:
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NATALIE ANNE TAYLOR,
Plaintiff
NO. 01-3601 CIVIL TERM
CIVIL ACTION - LAW
V,
IN DIVORCE
WILLIAM TAYLOR,
Defendant
RE: BIFURCATION PETITION
\....
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RULE
AND NOW, to\vit, this~ day of ,42tH/ad!! ,2003, upon consideration of the within
Petition, a Rule is entered upon the Respondent to show cause why the divorce proceedings should
not be bifurcated and a Decree in Divorce under Section 3301(d) of the Divorce Code entered with
reservation of jurisdiction over the economic issues raised in this case.
RULE RETURNABLE at a hearing to be held on the R{.u day of '?YfLd /i /lAJ
2003, at 9.' 30 o'clock ..iL.M, in Courtroom '-f of the Cumberland County
Courthouse, Carlisle, Pennsylvania. The parties are directed to appear at that date, time and place
and give testimony and/or argument on their respective positions as to why the relief requested in
the within Petition for Bifurcation should or should not be granted.
BY THE COURT:
J.
Distribution to:
ATTORNEY FOR PLAINTIFF:
Diane G, Radcliff, Esquire
3448 Trindle Road
Camp Hill, PA 17011
~ ~ct~3'03
ATTORNEY FOR DEFENDANT:
P. RiChard Wagner, Esquire
2233 North Front Street
Harrisburg, PAl 7110
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OF
F'i)< [?(~~.17~..:;_~~l~:~OTf\t1Y
03 FE? - 3 tIt'i j I: ? 3
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
NATALIE ANNE TAYLOR,
Plaintiff
NO. 01-3601 CIVIL TERM
CIVIL ACTION - LAW
V,
IN DIVORCE
WILLIAM TAYLOR,
Defendant
RE: BIFURCATION PETITION
FINAL ORDER FOR BIFURCATION OF DIVORCE PROCEEDINGS
AND NOW, this day of ,2003, in consideration of the within
Petition, IT IS HEREBY ORDERED AND DECREED that:
1. The above-captioned divorce action is hereby bifurcated so that a divorce decree can be
entered with reservation of jurisdiction over all claims raised by either party prior to the entry
of said decree.
2. Upon presentation of the proper documents and papers as required by the Pennsylvania Rules
of Civil Procedure, this Court will enter a Divorce Decree under Section 3301(d) of the
Divorce Code with reservation of jurisdiction over any economic issues raised by either party
prior to the entry of the divorce decree.
BY THE COURT:
J.
Distribution to :
ATTORNEY FOR PLAINTIFF:
Diane G. Radcliff, Esquire
3448 Trindle Road
Camp Hill, PA 17011
ATTORNEY FOR DEFENDANT:
P, Richard Wagner, Esquire
2233 North Front Street
Harrisburg, PA 17110
~
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
NATALIE ANNE TAYLOR,
Plaintiff
NO. 01-3601 CIVIL TERM
CIVIL ACTION - LAW
V.
IN DIVORCE
WILLIAM TAYLOR,
Defendant
RE: BIFURCATION PETITION
PETITION FOR BIFURCATION OF DIVORCE PROCEEDINGS
AND NOW, to wit, this~;aay of~, 2003_, comes the Petitioner, Natalie Anne Taylor,
by her attorney, Diane Q, Radcliff, Esqui&; and files this Petition for Bifurcation and represents
that:
1. Your Petitioner, Natalie Anne Taylor, is the Plaintiff in the above-captioned matter.
(Petitioner is hereafter referred to as "Wife").
2. Your Respondent, William Taylor, is the Defendant in the above-captioned matter.
Respondent is hereafter referred to as "Husband"),
3. The parties were married on October 13, 1989 and were separated on January 29,2001.
4. The Complaint in Divorce was filed by Wife on II, An Amended Complaint in Divorce was
filed by Wife on II raising the following claims:
a. Divorce under either Section 3301 (c) or Section 3301 (d) on the basis thatthe marriage
is irretrievable broken;
b. Equitable distribution.
5. The Divorce Complaint was duly served upon Husband on June 18, 200 I by acceptance of
service ofthe Divorce Complaint by Defendant's attorney, P. Richard Wagner, Esquire, on
that date. The Acceptance of Service is filed of record in this case. The Amended Complaint
in Divorce was served upon Defendant's attorney, P. Richard Wagner, Esquire, on II.
- 1 -
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6. No Answer or Counterclaim has been filed by Husband to the Divorce Complaint or to the
Amended Complaint in Divorce
7. The parties have lived separate and apart since January 29,2001 and will have lived separate
and apart for a period of at least two (2) years as of January 29, 2003,
8. The parties' marriage is irretrievably broken.
9. On or before the date of the filing of this Petition, Wife has or will have filed a 3301(d)
Affidavit alleging that the parties have lived separate and apart for a period of at least two
(2) years and the parties' marriage is irretrievably broken.
10. Wife desires that this case be bifurcated because:
a. Wife desires to remarry immediately;
b. Wife's is not able to work and has been financially supported by her fiancee,
c. Wife suffers from a medical condition which endangers her life, and if she would die
before the entry of the divorce decree, she would not be able to secure equitable
distribution of the parties' marital assets.
d. Because of Wife's health conditions she needs to be on her fiancee's health insurance
plan and cannot do so unless they are married.
e. Wife's fiancee has also financially supporting the parties' three (3) minor children,
since the support paid by Husband is insufficient to meet the needs ofthose children.
f. Wife and Wife's fiancee are not able to have the income tax savings that would result
if Wife and her fiancee were married, which taxes savings are needed to help support
their household.
11. The parties do not own any property jointly with the exception of a rental unit which is
owned jointly with Wife's parents. Husband and Wife's share of that real estate is owned as
Tenants by the Entireties, The only other major asset is Husband's pension which is owned
solely by Husband. If Wife were to die before the entry of the divorce decree and/or an order
bifurcating the parties' marital assets, Wife or her estate would not be able to secure equitable
distribution of the marital assets since such equitable distribution rights terminate upon her
- 2 -
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death unless with action has been bifurcated and a divorce decree entered before death
12. Husband and Wife have been unable to agree as to equitable distribution of their marital
assets and debts, and as the result it is not likely that the parties will be able to be divorced
for an additional period of no less than nine (9) months which period is the estimated time
period to complete the Divorce Master's hearing and determination on the equitable
distribution claim,
13. Husband is not dependent upon Wife for his support,
14. Husband has separate medical insurance coverage for himself.
15. Wife is currently covered under Husband's health insurance, but will be able to obtain health
insurance through her fiancee's employment as soon as she is able to marry her fiancee
which will occur as soon as the divorce decree is entered. In the interim, Wife is able to
obtain Cobra coverage health insurance under Husband's employment insurance policy upon
divorce,
16. Wife cannot remarry and obtain the benefits resulting from that remarriage as set forth above
unless this case is bifurcated.
17. Neither party will be prejudiced by the bifurcation of these proceedings by the allowance of
the entry of Decree in Divorce under Section 3301(d) of the Domestic Relations Code.
18. Plaintiff s Attorney previously requested that Husband and Wife agree to a bifurcation ofthe
within proceedings and was informed that husband would not agree.
19. A copy ofthis Petition was provided to Husband's Attorney, P, Richard Wagner, Esquire,
on II under cover of letter bearing the same date,
20. The judges involved in this or any other related proceeding involving the parties are as
follows:
a. The Honorable, Edward E, Guido entered the March 12,2002 child support order in
the support action docketed to No. 00118 s 2001, Pacses No. 407103038.
WHEREFORE, your Petitioner, Natalie Anne Taylor, respectfully requests that this
Honorable Court to enter an Order bifurcating the divorce proceeding and, in accordance with the
Affidavit filed and upon presentation ofthe proper documents to enter a Decree of Divorce for the
- 3 -
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Petitioner under the Section 3301(d) with reservation jurisdiction over the economic issues
heretofore raised by either party.
Respectfully submitted,
- 4 -
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NATALIE ANNE TAYLOR,
Plaintiff
NO. 01-3601 CIVIL TERM
CIVIL ACTION - LAW
V.
IN DIVORCE
WILLIAM TAYLOR,
Defendant
RE: BIFURCATION PETITION
VERIFICATION
I verify that the statements made in this Petition for Bifurcation are true and correct. I
understands that false statements herein are made subject to the penalties of 18 Pa,C,S, Section
4904, relating to unsworn falsification to authorities,
~rhx/itFy >
NATALIEANNETAYLO ,
Petitioner
Date: ~
- 5 -
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CERTIFICATE OF SERVICE
I, DIANE G, RADCLIFF, ESQUIRE, hereby certify that on January 28, 2003, I served a
true and correct copy of the foregoing Bifurcation Petition upon Defendant's Attorney, P. Richard
Wagner, Esquire, by fax and by mailing same by first class mail, postage prepaid, addressed as
follows:
P. Richard Wagner, Esquire
2233 North Front Street
Harrisburg, PA 17110
Respectfully submitted,
~Y---{
CLIFF, ESQUIRE
448 Trindl Road
1,PA1701l
Phone: (717) 737-0100
Fax: (717) 975-0697
Supreme Court ID # 32112
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NATALIE ANNE TAYLOR,
Plaintiff
v,
: NO. 01-3601 CIVIL TERM
WILLIAM TAYLOR,
Defendant
: CIVIL ACTION - LAW
: DIVORCE
CERTIFICATE OF SERVICE
I, DIANE G. RADCLIFF, ESQUIRE, hereby certify that on January 29, 2003, I
served a true and correct copy of the Plaintiff's Amended Complaint in Divorce upon P.
Richard Wagner, Esquire, Attorney for Defendant, William Taylor, by mailing same by first
class mail, postage prepaid, addressed as follows:
p, Richard Wagner, Esquire
2233 North Front Street
Harrisburg, PA 17110
G. DCLIFF, ESQUI
, (lIe Road
Camp Hill, PA 17011
Phone: (717) 737-0100
Fax: (717) 975-0697
Supreme Court ID # 32112
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
NATALIE ANNE TAYLOR,
Plaintiff
v.
: NO. 01-3601 CNIL TERM
WILLIAM TAYLOR,
Defendant
: CIVIL ACTION - LAW
: DIVORCE
CERTIFICATE OF SERVICE
I, DIANE G. RADCLIFF, ESQUIRE, hereby certify that on January 29,2003, I
served a true and correct copy of the Plaintiff's 3301(d) Affidavit upon P. Richard Wagner,
Esquire, Attorney for Defendant, William Taylor, by mailing same by first class mail,
postage prepaid, addressed as follows:
p, Richard Wagner, Esquire
2233 North Front Street
Harrisburg, PA 17110
R<~'~ful1Y~~~
DCLIFF, ESQUIRJ] {
448 Trind1 oad
Camp ill,PA17011
Phone: (717) 737-0100
Fax: (717) 975-0697
Supreme Court ID # 32112
Attorney for Plaintiff
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
NATALIE A. TAYLOR ) Docket Number 01-3601 CIVIL
Plaintiff )
VS. ) PACSES Case Number 487105227
WILLIAM S. TAYLOR )
Defendant ) Other State ID Number
ORDER
AND NOW, to wit on this
12TH DAY OF MARCH, 2003
IT IS HEREBY
ORDERED that the 0 Complaint for Support or 0 Petition to Modify or (i) Other
ALIMONY PENDENTE LITE
filed on JANUARY 29, 2003 in the above captioned
matter is dismissed without prejudice due to:
THE PLAINTIFF WITHDRAWING HER REQUEST FOR ALIMONY PENDENTE LITE CONFERENCE,
o The Complaint or Petition may be reinstated upon written application of the plaintiff
petitioner.
BY THE COURT:
DRO: RJ Shadday
xc: plaintiff
defendant
P. Richard Wagner, Esquire
Diane Radcliff, Esquire
Edward E.
JUDGE
Service Type M
Form 0&506
Worker ID 21005
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NATALIE ANNE TAYLOR,
Plaintiff
NO. 01-3601 CIVIL TERM
CIVIL ACTION - LAW
V.
IN DIVORCE
WILLIAM TAYLOR,
Defendant
APL
ORDER OF COURT
AND NOW, this day of ,2003, upon consideration of the
attached Petition for Alimony Pendente Lite, it is hereby directed that the parties appear before
, the Domestic Relations Conference Officer on
at o'clock ,m, at the Domestic Relations Office located at 13 North Hanover Street,
Carlisle, Pennsylvania for a conference, after which the Conference Officer may recommend that an Order
for Alimony Pendente and interim counsel fees and costs be entered.
Your are further ordered to bring to the conference:
(1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed,
(2) your pay stubs for the preceding six (6) months
(3) the Income and Expense Statement attached to this Order, completed as required by Rule 191-.1111;;1)
(4) verification of child care expenses
(5) proof of medical coverage which you may have, or may have available to you
If you fail to appear for the conference or bring the required documents, the court may issue a warrant for your
arrest.
FOR THE COURT
Date of Order:
Conference Officer
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NATALIE ANNE TAYLOR,
Plaintiff
NO. 01-3601 CIVIL TERM
CIVIL ACTION - LAW
V.
IN DIVORCE
WILLIAM TAYLOR,
Defendant
RE: BIFURCATION PETITION
PETITION FOR ALIMONY PENDENTE LITE
TO THE HONORABLE, THE JUDGES OF SAID COURT:
AND NOW, this _ day of , 2003 , comes the Petitioner, Natalie
Anne Taylor, who files the this Petition for Alimony Pendent Lite and respectfully represents that:
1. Your Petitioner, Natalie Anne Taylor, is the Plaintiff in the above-captioned matter.
(Petitioner is hereafter referred to as "Wife"). Wife resides at 1755 Tarry Hall Road,
Millersburg, P A.l7043,
2. Your Respondent, William Taylor, is the Defendant in the above-captioned matter.
Respondent is hereafter referred to as "Husbanfl'), Husband resides at 455 south
York Street, Mechanicsburg, PAl 7055.
3. The parties were married on October 13, 1989 and were separated on January 29,
2001.
4. The Complaint in Divorce was fIled by Wife on June 11, 2001. An Amended
Complaint in Divorce was filed by Wife on January 29,2003 raising the following
claims:
a. Divorce under either Section 3301@) or Section 3301 (d) on the basis that the
marriage is irretrievable broken;
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YOUR HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT
YOU. 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 MAY GET LEGAL HELP,
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland 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,
FOR THE COURT:
COURT ADMINISTRATOR
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
NATALIE ANNE TAYLOR,
Plaintiff
NO. 01-3601 CIVIL TERM
CIVIL ACTION - LAW
V.
IN DIVORCE
WILLIAM TAYLOR,
Defendant
RE: BIFURCATION PETITION
PETITION FOR ALIMONY PENDENTE LITE
TO THE HONORABLE, THE JUDGES OF SAID COURT:
AND NOW, this .a51;-Of ~l) <D W-, 2003 , comes the Petitioner, Natalie
Anne Taylor, who files the this Petition for Alimony Pendd-tt LIte and respectfully represents that:
1. Your Petitioner, Natalie Anne Taylor, is the Plaintiff in the above-captioned matter.
(Petitioner is hereafter referred to as "Wife"). Wife resides at 1755 Tarry Hall Road,
Millersburg, P A.l704 3.
2. Your Respondent, William Taylor, is the Defendant in the above-captioned matter.
Respondent is hereafter referred to as "Husband"), Husband resides at 455 south
York Street, Mechanicsburg, P A 17055.
3. The parties were married on October 13, 1989 and were separated on January 29,
2001.
4. The Complaint in Divorce was filed by Wife on June 11, 2001. An Amended
Complaint in Divorce was filed by Wife on January 29,2003 raising the following
claims:
a. Divorce under either Section 3301@) or Section 3301(d) on the basis that the
marriage is irretrievable broken;
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b. Equitable distribution.
c. Alimony pendente lite;
d. Counsel fees and costs,
4. Husband has not sufficiently provided support for Wife,
5. Wife is not on a financial par with Husband in prosecuting and/or defending this Divorce
Action, and is unable to support herself in accordance with the standard ofliving established
during the marriage.
6. This Petition is filed to secure the entry of an Order on the Plaintiff s claim for Alimony
Pendente Lite.
7. A background information sheet pertaining to this claim for Alimony Pendente Lite is being
filed with Domestic Relations concurrently herewith as required by Local Rules of Court,
8, The amount of Alimony Pendente Lite requested by the Petitioner is the maximum amount
provided for under the guidelines.
WHEREFORE, Petitioner prays that the Court enter an Order:
a. Requiring the Respondent to pay the Petitioner Alimony Pendente Lite in the
maximum amount provided for by law under the state support guidelines;
b, Requiring the Respondent to provide medical insurance and support for the
Petitioner.
Respectfully submitted,
DCLIFF, ESQUIRE
448 Tri oad
Camp Hill, PA 17011
Supreme Court ID # 32112
Phone: (717) 737-0100
Fax: (717) 975-0695
Attorney for Petitioner
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VERIFICATION
I verify that the statements made in this Petition for Alimony Pendent Lite 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,
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NATALIE ANNE TAYLOR
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CERTIFICATE OF SERVICE
I, DIANE G, RADCLIFF, ESQUIRE, hereby certify that on January 29, 2003, I
served a true and correct copy of the Petition for Alimony Pendente Lite upon the
Defendant's Attorney, P. Richard Wagner, Esquire, by mailing same by first class mail,
postage prepaid, addressed as follows:
p, Richard Wagner, Esquire
2233 North Front Street
Harrisburg, PA 17110
Respectfully submitted,
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CLIFF, ESQUIRE
448 Trindle oad
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Ca ',PAI7011
Phone: (717) 737-0100
Fax: (717) 975-0697
Supreme Court ID # 32112
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NATALIE ANNE TAYLOR,
Plaintiff
NO. 01-3601 CIVIL TERM
CIVIL ACTION - LAW
V.
IN DIVORCE
WILLIAM TAYLOR,
Defendant
NOTICE
IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS
AFFIDAVIT, YOU MUST FILE A COUNTER-AFFIDAVIT WITHIN TWENTY DAYS
AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL
BE ADMITTED.
AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE
1. The parties to this action separated on January 29, 2001 and
have continued to live separate and apart for a period of at
least two years.
2. The marriage is irretrievably broken.
3, I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not
claim them before a divorce is granted.
I verify that the statements made in this affidavit are true
and correct, I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904 relating to
Date:
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authorities.
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Natalie Anne Taylor
unsworn falsifications to
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NATALIE ANNE TAYLOR, * IN THE COURT OF COMMON PLEAS
Plaintiff, * tutvlberlo.nd COUNTY, PENNSYLVANIA
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VS, * No, 0\ - 3<.tJO\
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WILLIAM TAYLOR, * CIVIL ACTION LAW
Defendant * IN DIVORCE
PRAECIPE FOR WITHDRAW OF APPEARANCE
Please withdraw my appearance on behalf of Plaintiff, NATALIE ANN TAYLOR. in
the above captioned matter without prejudice.
Date:.5,;J 3, O;J-.
PRAECIPE TO ENTER APPEARANCE
Please enter my appearance on behalf of Plaintiff, NATALI E TAYLOR, in the
above captioned matter.
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NATALIE ANNE TAYLOR, * IN THE COURT OF COMMON PLEAS
Plaintiff, * CUMBERLAND COUNTY,
* PENNSYLVANIA
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VS, * No. 01.3601
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WILLIAM TAYLOR, * CIVIL ACTION LAW
Defendant * m DIVORCE
PRAECIPE FOR WITHDRAW OF APPEARANCE
Please withdraw my appearance on behalf of Plaintiff, NATALIE ANN TAYLOR, in
the above captioned matter without prejudice.
Date:~ 'Z/
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Edward J. Weintraub, Esquire
PRAECIPE TO ENTER APPEARANCE
Please enter my appearance on behalf of Plaintiff, NATALIE TAYLOR, in the
above captioned matter.
Date: ~ /2.1/ D'"2/
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NATALIE ANNE TAYLOR,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintrrt:
v.
: NO: 01-3601
: CIVIL TERM
WILLIAM TAYLOR,
: IN DIVORCE
Defendant,
HUSBAND'S PRE-TRIAL STATEMENT
L FACTS:
Husband and Wife were married October 13, 1989, in Harrisburg, and
separated January 29, 2001. The parties separated because of a PF A, however, the
PFA was entered as a result of Husband finding the Wife in the backseat of Wife's
vehicle with another man at Kokomo' s engaged in sexual intercourse.
The divorce has been bifurcated and it is believed that the Wife has remarried
to a Dr, Acri,
The Wife is employed part-time with the Halifax School District, and
Husband is a legislative aide with the House of Representatives.
The parties have three (3) children born to the marriage, Katerine, Eden, and
Brooke.
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Husband currently pays child support in the amount of$870,OO per month
through the Court of Common Pleas of Cumberland County,
n. ASSETS:
In 1990, the parties purchased property in Wormleysburg, Pennsylvania, the
cost of which was approximately $55,000.00. There is a mortgage on that property,
In 1996, the parties purchased a second property in Camp Hill and moved to
the Camp Hill property,
Actual settlement on the Camp Hill property occurred while Husband was
incarcerated as a result of a Dill. Unbeknownst to the Husband, the Deed to the
Camp Hill property was put in the name of the Wife's parents,
The parties continued to own the Wormleysburg property, and rented the
same with the rental payments being applied to the mortgage on the Camp Hill
property,
During the time that the mortgage on the Camp Hill property was being paid
by the rent from the Wormleysburg property, Husband was paying the mortgage on
the Wormleysburg property.
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The rental and the purchases were "engineered" by Wife's father who also
was listed as a signer on the parties' bank accounts.
For example, on the day of separation, the father-in-law closed out the
account by writing a check to himself for the total amount of the proceeds in the
parties' bank account.
Moreover, just recently, Husband was wage attached to pay the taxes on the
Camp Hill property, even though it is alleged that the Camp Hill property is owned
by the in-laws,
There is limited household personal property between the parties.
IlL PENSIONS:
Husband has a pension through SERS which is valued at approximately
$18,000.00,
IV. INCOME AND EXPENSES:
Husband will file an Income and Expense Statement which is incorporated
herein by reference.
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V. PROPOSED RESOLUTION:
Husband shall retain his pension and receive 50% of the net equity in both
the Wormleysburg property and the Camp Hill property.
In the alternative, Wife's father-in-law must account for all the rental monies
received from the W ormleysburg property that were applied to the mortgage on the
Camp Hill property.
Respectfully submitted,
Mancke, Wagner & Spreha
Byg
p, Richard Wagner, Esquire
ID. #23103
2233 North Front Street
Harrisburg, PA 17110
(717) 234-7051
Attorneys for Husband
Date: t/;.5 /1>=5
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CERTIFICATE OF SERVICE
I, Debra K. Spinner, Secretary in the law firm of MANCKE,
WAGNER, and SPREHA, do hereby certify that I am this day serving
a copy of the foregoing document to the following persons and in
the manner indicated below, which service satisfies the
requirements of the Pennsylvania Rules of Civil Procedure, by
depositing the same in the United States Mail, Harrisburg,
Pennsylvania, with first class postage, prepaid, and addressed as
follows:
Diane G. Radcliff, Esquire
3448 Trindle Road
Camp Hill, PA 17011
By dflkJ cv::jf~
Debra K. Spinner, Secretary
MANCKE, WAGNER, & SPREHA
2233 North Front Street
Harrisburg, PA 17110
P. Richard Wagner, Esquire
Attorneys for Husband
DATE: t / /-0/0:-3
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NATALIE ANNE TAYLOR,
Plaintiff,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO: 01-3601
v.
: CIVIL TERM
WILLIAM TAYLOR,
: IN DIVORCE
Defendant.
INVENTORY OF WILLIAM $. TAYLOR
Defendant files the following inventory of all property owned or possessed by either
party at the time this action was commenced and all property transferred within the
preceding three years.
Defendant verifies that the statements made in this inventory are true and correct.
Defendant understands that false statements herein are made subject to the penalties of
18 Pa,C.S. Section 4904 relating to unsworn f sifi ton to ~utS
William S. Taylor, Defenda
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1.0. #23103
2233 North Front Street
Harrisburg, PA 17110
(717) 234-7051
Attorneys for Husband
Date: (;/01/ ~3
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ASSETS AND LIABILITIES OF PARTIES
Defendant marks on the list below those items applicable to the case at bar and
itemizes the assets and debts on the following pages:
(x) 1. Real property and Real Estate Mortgages
(x) 2. Motor vehicles and Vehicle Liens
( ) 3. Stocks, bOnds, securities and options
( ) 4. Certificates of Deposit
( ) 5, Checking accounts, cash
( ) 6. Savings accounts, money market and savings certificates
( ) 7, Contents of safe deposit boxes
( ) 8. Trusts
( ) 9, Life Insurance policies
( ) 10. Annuities
() 11. Gifts
( ) 12. Inheritances
( ) 13. Patents, copyrights, inventions, royalties
( ) 14. Personal property outside the home
( ) 15. Business
( ) 16. Employment termination benefits-severance pay, worker's compensation
( ) 17. Profit sharing plans
(x) 18. Pension Plans (indicate employee contribution and date plan vests)
() 19. Retirement plans, Individual Retirement Accounts
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( ) 20. Disability payments
( ) 21. Litigation claims (matured and unmatured)
( ) 22. MilitaryNA benefits
( ) 23. Education benefits
( ) 24. Debts due, including loans, mortgages held
( ) 25. Household furnishings and personalty
( ) 26. Other assets
(x) 27. Loans, Credit Cards and other Debts
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SECTION I
MARITAL ASSETS AND DEBIS
THE FOLLOWING IS A LISTING OF THE MARITAL ASSETS AND DEBTS OF THE
PARTIES:
MARITAL ASSETS AND DEBTS
DESCRIPTION OF
PROPERTY OR
LIABILITY
DATE
OF
VALUE
VALUE OF
ASSET OR
LIABILITY
NET VALUE
PROPOSED
DISTRIBUTION
TO HUSBAND
PROPOSED
DISTRIBUTION
TO WIFE
RJ:iU:.. E8 fA I! ANDRE;(( En-AtE MORtGA
ITEM 1 (REAL ESTATE #1)
Value
Mortgage
103 N. 2nd street
Wonnleysburg, PA
II 2nd Mortgage
Net Equity
6.8,90
55,900.00
55,900.00
55,900,00
Comments: This property was acquired on 6/8190 for $55,900.00, Husband paid the mortgage and taxes
from the date of acquisition until the date of separation on 1129/01.
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ITEM 1 (REAL ESTATE #2)
63 N. 31st street
Camp Hill. PA 17011
127,000,00
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MARITAL ASSETS AND DEBTS
DESCRIPTION OF
PROPERTY OR
LIABIUTY
/I Mortgage
/I 2'd Mortgage
Net Equity
DATE
OF
VALUE
VALUE OF
ASSET OR
LIABILITY
NET VALUE
PROPOSED
DISTRIBUTION
TO HUSBAND
PROPOSED
DISTRIBUTION
TO WIFE
(17,656.06)
109,343.94
109,343.94
Comments: This property was acquired while the Husband was in jail on a DUI. The parties moved into this
property shortly after acquisition. The mortgage was paid by using proceeds from item 1 real estate when it
was rented to other parties.
On June 14, 1996, when this property was acquired, Husband and Wife moved into the property. The
Wonnleysburg property was then rented to another party, The rent was collected by Wife's father and was
used to pay the mortgage on the Camp Hill property. There has never been an accounting by Wife's father
of all the rents that he received on the Wonnleysburg property, nor has there been any kind of accounting for
other monies that he took from Husband. (Examples of checks payable to himself from Husband's account
will be produced at the time of the hearing.)
MO'tOR VEJ-lICU,SANDVEHlcLE UENS (ItM1NTORV'2)
ITEM 2 (VEHICLE #1)
Wife's 1991 Caravan
II Vehicle Loan
Net Value
Comments:
junked
0.00
0.00
0,00
DESCRIPTION OF
PROPERTY OR
LIABILITY
ITEM 2 (VEHICLE #2
Husband's 1897 Ford
Truck
/I Vehicle Loan
Net Value
DATE
OF
VALUE
MARITAL ASSETS AND DEBTS
VALUE OF
ASSET OR
LIABILITY
NET VALUE
PROPOSED
DISTRIBUTION
TO WIFE
PROPOSED
DISTRIBUTION
TO HUSBAND
0.00
0.00
0.00
Comments: Needs transmission. Will be disposed of after eiti Financial is paid off since they hold the lien.
ITEM /I (VEHICLE #3)
Its
/I Vehicle Loan
Net Value
Comments:
ITEM II (VEHICLE #4)
Its
/I Vehicle Loan
Net Value
Comments:
ITEM II (VEHICLE #5)
Its
/I Vehicle Loan
Net Value
Comments:
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
MARITAL ASSETS AND DEBTS
DESCRIPTION OF DATE VALUE OF NET VALUE PROPOSED PROPOSED
PROPERTY OR OF ASSET OR DISTRIBUTION DISTRIBUTION
L1ABIUTY VALUE LIABILITY TO HUSBAND TO WIFE
i , PEMSrON ANDitt1i~p~ (,fM;'HORV 11111 &:19)
"
ITEM 18 (RETIREMENT #1)
SERS I 18,800.00 18,800,00
Comments: See the attached SERS indicating the value of the retirement account is $18,799,80. Husband
is unaware of where Wife obtained the number set forth in her Inventory,
. " -'-', .. "'H' "',,,'.,,"~ ,
-~-.
ITEM /I (RETIREMENT #2)
0.00
Comments:
---- ,- - ~.- -- _.,--~-- . - ~--'"-~--'------='~"- ,-,~-_-:.._<_:--,,:... ..-,"..;"
ITEM /I (RETIREMENT #3)
0.00
Comments:
, ,- --
ITEM /I (RETIREMENT #4)
0.00
Comments:
ITEM /I (RETIREMENT #5) u..
0.00
Comments:
_ _n~_.. __.__ -- -- .. " , -- - " -- .. ...
ITEM II (RETIREMENT #6) . un
0,00
MARITAL ASSETS AND DEBTS
DESCRIPTION OF
PROPERTY OR
LIABILITY
DATE
OF
VALUE
VALUE OF
ASSET OR
LIABILITY
NET VALUE
PROPOSED
DISTRIBUTION
TO HUSBAND
PROPOSED
DISTRIBUTION
TO WIFE
lOANS,CRi:t)ttC It
ITEM If IDEBT #1)
0,00
Comments: Evidence will reveal that M~. Blaine unilaterally collected the rental monies fro the
Wonnleysbu~g property, applied them to the Camp Hill mortgage, during which time Husband was
still paying the mortgage on the Wormleysburg property. M~. Blaine has yet to p~ovjde an
accounting of all the monies that he received fo~ the last seven (7) years, but it is believed to be in
excess of $38,000.00.
In addition, the taxes on the Camp Hill property were not paid by M~. Blaine, and Husband was
assessed the taxes on the property and his wages were garnished as is evidenced by his paycheck.
ITEM If (DEBT #2)
- - - _n _ _~ ___
---- - ~ -~~
--------- ----..
0.00
Comments:
ITEM If (DEBT #3)
_o~-:---
0.00
Comments:
-=
ITEM If (DEBT #4)
0.00
Comments:
ITEM 1/ (DEBT tIS)
MARITAL ASSETS AND DEBTS
DESCRIPTION OF
PROPERTY OR
LIABILITY
DATE
OF
VALUE
NET VALUE
VALUE OF
ASSET OR
LIABILITY
Total of Assets and liabilities
Totals from Above
Percentage of Total
Totals from above
Amount Due in 50/SO Division
Adjustment Figure for SO/50
ADJUSTMENT FO
Totals from above
Amount Due in 45155 Division
Adjustment Figure for 45/55
ADJUSTMENT 0
Totals from above
Amount Due in 40/60 Division
Adjustment Figure for 40/60
NOTES:
,
PROPOSED
OlsmlBUTION
TO HUSBAND
PROPOSED
DISmlBUTlON
TO WIFE
0.00 0.00
92,021,97 92.021.97
92,021.97 92,021.97
0.00 0,00
82,819.n 101,224.17
82,819.77 101,224.17
0.00 0.00
73,617.58 110,426.36
73,617.58 110,426,36
1. The adjustment figures are for illustration purposes only and are not to be
deemed a representation on the part of the Plaintiff/Defendant as to whether
an adjustment should be made or the amount of the adjustment, if appropriate.
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CERTIFICATE OF SERVICE
I, Debra K. Spinner, Secretary in the law firm of MANCKE,
WAGNER, and SPREHA, do hereby certify that I am this day serving
a copy of the foregoing document to the following persons and in
the manner indicated below, which service satisfies the
requirements of the Pennsylvania Rules of Civil Procedure, by
depositing the same in the United States Mail, Harrisburg,
pennsylvania, with first class postage, prepaid, and addressed as
follows:
Diane G. Radcliff, Esquire
3448 Trindle Road
Camp Hill, PA 17011
By
Afkdw ~ ~~
Debra K. Spinne , secretary
MANCKE, WAGNER, & SPREHA
2233 North Front street
Harrisburg, PA 17110
P. Richard Wagner, Esquire
Attorneys for Husband
DATE: 'l/; J /),3
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NATALIE ANNE TAYLOR,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS
cumBERLAND COUNTY, PENNSYLVANIA
NO, 01-3601 CIVIL TERM
WILLIAM SAMUEL TAYLOR ,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
INCOME AND EXPENSE STATEMENT
SUBMITTED BY:
Full Name of Defendant:William Samuel Taylor
Age :44
Present Address 427 S. York Street Telephone No,766-7094
Mechanicsburg, PA 17055
Status of Defendant's Health (Be Specific) Good
Name and Address of Defendant's Employer:
PA House of Representatives
Ma1n ~ap1tal BU11d1ng
Harrisburq, FA 17120
Length of Service With This Employer: 17 Years
BiWeekly
Monthly
Yearly
Gross Earned Income
$1497.00
Gross Earned Income
Total Gross Income
$1497.00
Deductions:
Federal
$132.62
State Inc, Tax
F.I.C,A.
$41. 92
$14.97
-0-
Hosp/Med. Ins,
Other Income
-0-
Dividends
-0-
Rents:
Royalties:
Expense Account:
Gifts:
Unemployment Compensation:
Current Expenses:
Home:
Mortgage
Maintenance:
Utilities:
Electric
Gas
Oil
~ "
Weekly
Weekly
Monthly Yearly
$200.00
Monthly
I~
"'" "'" ',--,_ 'r, n_VO ,_~, _.'"",, "
1l1r'fu;iJi
Yearly
Telephone
Water
Sewer
Employment:
Public Transportation
Lunch
Taxes:
Real Estate
Personal Property
Income
Insurance:
Home Owners
Automobile
Life
Accident
Health
Other
~ "--
Weekly
$30.00
"-.',
Monthly
$60.00
$70.00
'.:;
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ll[ ~~,i
Yearly
$540.00
Automobile:
Medical:
Education:
- . ""'-,-,"P'''', ",_,,'" '
Payment
Fuel
Repairs
Doctor
Dentist
Orthodontist
Hospital
Special Needs
(Glasses, Braces)
Private School
Parochial School
College
Religious
- '".,,-,-,',.,<, ",','"
Weeklv
$40.00
.. I , .-. . ~'" "
Monthly
$100.00
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"'-j>j'-,'
Yearlv
. ~
-.
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-'--',.
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Weekly
Personal:
Clothing
Food
$40.00
Barber/Stylist
Credit Payments
Credit Cards
Charge Accounts
Memberships:
Loans:
Credit Union
line of credit
*Citi Financial
Miscellaneous:
Household help
Child Care
Papers/Books/Magazines
Entertainment
Pay TV
Vacation
,
c-,
Monthlv
$240.00
Gifts
*Home Repairs Improvements at 63 N. 31st Street
16'x20' Deck
20'x24'Concrete Patio
privacy Fence Around Back Yard
Furniture
vacation to Florida $10,000.00 Balance
I
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Yearly
"
Other:
TOTAL EXPENSES:
L ~". ,- ~-, < ',' ,',_
Bi-WeekI:Y
$402.00
$
-, ,- - .~~
$
'--~-~-'_e s.;-~- ;';~i_ - " '_,,~~
$
Legal fees
Charitable Contributions
Other Child Support
Alimony Payments
Explain Fully All Entries Above:
.
".'-";"'""^","'-,,,,,-,,-
Defendant's Current Income: SEE ATTACHED
Gross Earned Income
Gross Unearned Income
Total Gross Income
Deductions
Federal
State Income Tax
F,I.C,A.
Hosp/Medical Insurance
Pension/Profit Sharing
Savings Bonds (None)
Other Child Support
Total Deductions
Other Income:
Interest
Divideds
Pension
Annuity
Social Security
Per Pav
$1497.00
$1497.00
$132.62
$41.92
$14.97
Weeklv
,,',..1-.
Monthlv
S92.81 - Social Security Tax
$21.71 - Medicare Tax
$9.3.56
$402.00
$799.59
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Yearlv
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If Defendant is not Emploved, Explain Fullv:
Defendant's Education, Training and Skills:
High School Graduate
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VERIFICATION
I verify that the statements made in this foregoing document
are true and correct. I understand that false statements herein
are made subject to the penalties of 18 Pa.C.S. ~ 4904, relating to
unsworn falsification to authorities,
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COMMONWEALTH OF PENNSYLVANIA
STATE EMPLOYEES' RETIREMENT SYSTEM
HARRISBURG REGIONAL COUNSELING CENTER
30 NORTH THIRD STREET, ROOM 319
HARRISBURG, PA 17101
717 783.9065
I ,80lJ-633.546 I
FA](: 717,783-9599
www.sers.state.pa.us
June 26, 2002
WILLIAM S, TAYLOR
427 S, YORK ST,
MECHANICSBURG PA 17055
SSN 194-52-1745
Dear Mr, Taylor:
Enclosed per your request, please find an estimate of the value of your retirement account
as of 01/29/200 1. Also, please find information concerning SERS' requirements for
Domestic Relations Orders. You should give this information to your attorney for
review. If the attorney has questions, helshe can contact our Legal Division directly,
I trust this information will be satisfactory for your needs,
Sincerely,
~~
Ufane Kuldish
Regional Manager
Harrisburg Regional Counseling Center
.
-~
COMMONWEALTH OF PENNSYL VANIA
STATE EMPLOYEES' RETIREMENT SYSTEM
HARRISBURG REGIONAL COUNSELING CENTER
3Q NORTH THIRD STREET, ROOM 319
HARRISBURG, PA 17101
TELEPHONE: (717) 783-9065
FAX: (717) 783,9599
TOLLFREE: 1'800-633-5461
www.sers.state.pa.us
June 26, 2002
WILLIAM S TAYLOR
427 S YORK ST
MECHANICSBURG PA 17055
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SSN# 194-52,1745
Dear Mr. TAYLOR:
The following information was used to calculate your retirement benefit estimate:
Proposed Date of Retirement: 01/29/2001
Total State Service
(current service period)
Final Average Salary
S51 Credited Service
Frozen Present Value
Frz Present Value Debt
Frozen Service Credits
Other Debts
14.6818
Total School Service
0.0000
$30.464,97
$0.00
$0,00
0,0000
$0.00
Your Birth Date 09/02/1958 Survivor's Birth Date
Your Sex M Survivor's Sex
Total Account Balance; $18.799.80 Non-Taxable Contributions: $0,00
Previously Taxed Contributions made after 12/31/86: $0.00
Total Service Credits = 14.6818
(Breakdown listed Below)
(Total excludes SSI service - class S)
Service:
Class
AA
Credits
14,6818
Special Comments:
Frozen Credits
0.0000
The following pages will provide you with various estimate amounts and a brief description of each option,
For a more detailed explanation of your retirement benefits and options, you should refer to your State
Employees' Retirement System Member Handbook or talk With your retirement counselor.
Please remember that many factors affect the computation of a retirement benefit. Changes-to your years
of service, Final Average Salary, retirement date and debts applied to your account can change your
benefit amount. This estimate is based on the information as it appears above. The actual computation of
your retirement benefit will use the final information available after your employment with the
Commonwealth has been terminated.
EST04
111111/111111111I11111111I111111111111111111111111I11111I11I1111111111
~-
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.00" ""H,
On the fOllowing page you will find an explanation of each option plan followed by estimaie amounts
for that option plan under different withdrawal of contribution and interest options. You will first see the
estimate amount with NO withdrawal. Then you will see the estimate for a PARTIAL WITHDRAWAL,
or ONLY NON.TAXABLE contributions. The last estimate amount for each option plan will be with a
TOTAL withdrawal.
Under current law, you may withdraw a lump sum from your account or in payments of up to four
installments and receive a reduced or adjusted annuity. Federal tax law allows you to directly
transfer your taxable contributions into an "IRA" type of account. The total amount of your withdrawal
cannot exceed your total contributions and interest.
WHEN WITHDRAWING NON.TAXABLE CONTRIBUTIONS, THEY MUST BE TAKEN IN ONE
PAYMENT WITH YOUR INITIAL ANNUITY CHECK, TO BE TREATED AS NON.TAXABLE.
NON.TAXABLE CONTRIBUTIONS NOT WITHDRAWN AT RETIREMENT AND PREVIOUSLY TAXED
CONTRIBUTIONS MADE AFTER 12/31/1986, ARE TREATED AS TAXABLE AT THE TIME OF
RECEIPT, HOWEVER YOU WILL RECEIVE AN ANNUAL EXCLUSION ON YOUR 1099R FORM
EACH YEAR UNTIL THE TOTAL AMOUNT OF YOUR PREVIOUSLY TAXED CONTRIBUTIONS HAS
BEEN RECOVERED.
.. Please remember that all option plan elections are final and binding,
However the law does permit retirees who have elected an Option 2 or Option 3 type survivor benefit
plan to change their option/survivor under certain specific circumstances:
1) Your designated survivor predeceases you.
2) You divorce your designated survivor,
3) You marry after the date of your retirement.
Should any of these circumstances occur you should contact your regional retirement counseling
center, After receiving appropriate counseling you may elect to keep your check the same or elect
a new option plan. Your monthly annuity would then be recalculated based on your new option
election and your age as well as the age and sex of the new survivor,
IN ADDITION TO THE FIXED OPTION PLANS DISCUSSED IN THIS ESTIMATE LETTER, THE
STATE EMPLOYEES' RETIREMENT CODE ALSO PERMITS A MEMBER TO DESIGN HIS OR HER
OWN RETIREMENT OPTION PLAN. UNDER SPECIAL OPTION 4, A MEMBER MAY DESIGN THE
BENEFIT PLAN (OPTION) THEY DESIRE AND SUBMIT THE PLAN, THROUGH THEIR
RETIREMENT COUNSELOR, TO THE SERS ACTUARY, THE ACTUARY WILL APPROVE OR
DISAPPROVE THE PLAN BASED ON ITS ACTUARIAL EQUIVALENCY, SEVERAL RESTRICTIONS
DO APPLY. MEMBERS ARE ENCOURAGED TO ASK THEIR RETIREMENT COUNSELOR FOR
INFORMATION CONCERNING THESE BENEFITS AND SUBMIT ANY REQUEST AS EARLY AS
, POSSIBLE,
If you wish payments to be effective the day after your employment terminates (termination date as provided by
your agency), the Retirement Code requires that you file an Application for Annuity no later than 90 days after
the date of your termination from employment. Applying after the 90 days will result in your benefit
being effective the date your Annuity Application is filed with the SERS.
We require a certified copy of your Birth or Baptismal Certificate be attached to the application
as well as one for your named Survivor if you are electing an Option 2 or Option 3 type retirement
plan.
Should you have any questions, please contact me at the telephone number listed on the first page
of this estimate letter.
EST04
1111111111111111I11111111I111111111111111111111111I1111111111I11111111
,
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WILLIAM S TAYLOR
ESTIMATED BENEFITS - STANDARD OPTIOr-r-;
194-52-1745
MAXIMUM SINGLE LIFE ANNUITY WITHDRAWAL MONTHLY
AMOUNT BENEFIT
This plan provides the maximum arnount none $333,96
each month for life. If you die before receiving in
,
payments an amount equal to your contributions $0,00 $333.96
as they were at the lime of retirement, the (partial)
balance will be paid to your beneficiary(ies). You
may name one or more beneficiaries at any time. $18,799,80 $248. 72
(total)
I
OPTION 1 ANNUITY WITHDRAWAL MONTHLY PRESENT VALUE
This plan provides a reduced retirement AMOUNT BENEFIT TERM OF VALUE
allowance. In addition to monthly payments $325.65 $73,657,70
for life, a value is plaCed on your retirement none
account called the PRESENT VALUE, 18.8489 yrs
All payments to you are subtracted from the $0,00 $325.65 $73,657.70
Present Value. Any balance remaining at
your death will be paid to your beneficiary(ies). (partial) 18.8489 yrs
You may name one or more beneficiaries and $18,799.80 $242,53 $54,857,90
may change beneficiaries at any time, (total) 18,8492 yrs
OPTION 2 ANNUITY WITHDRAWAL MONTHLY SURVIVOR
This plan provides a reduced retirement allowance AMOUNT BENEFIT BENEFIT
for life, The amount of reduction is based on
your age and the age and sex of the person named none $0,00 $0,00
as your Designated Survivor Annuitant. Only one
person may be named as your Designated $0.00 $0.00 $0.00
Survivor Annuitant. At your death, that person will (partial)
continue to receive for life the same rnonthly
amount as was paid fo you, in addition to any $18,799,80 $0,00 $0,00
outstanding amounts payable to you, (total)
OPTION 3 ANNUITY WITHDRAWAL MONTHLY SURVIVOR
This plan provides a reduced retirement allowance AMOUNT BENEFIT BENEFIT
for life. The amount of reduction is based on none $0.00 $0.00
your age and the age and sex of the person named
as your Designated Survivor Annuitant. Only one $0.00 $0.00 $0.00
person may be named as your Designated (partial)
Survivor Annuitant. At your death, that person will
continue to receive for life one half of the same $18,799,80 $0,00 $0.00
monthly amount as was paid to you, in addition to (total)
any outstanding amount payable to you.
EST04
1111111111111111I11111111I111111111111111111111111I11111I1111I11111111
".....,'''''~
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01-42-92-02-3 ,~;J:S;LATIVE MANAGEMENTCl:lMr~. (R)
~(' 'I payroll Name .
EARNINGS I EMPLOYER PAlO BENEFITS
. ,. iHIS PAY YTD THIS PAY YTD
iB-
'02(~(03 194-52~17450024
Pay ~CJte
.~..
, DEDUCT IONS
,-I> THIS ~Ar
Appropriation
r
I
1 GROSS
FWT WAGES
SS WAGES
MED'WAGES
RET WAGES
NET PAY
02(04(03
Period End
1 ,497.00 4,417.00 SS/MED 114.52 337.90 FWT 132,62
1,403.44 4,140.94 M/H 430.00 1,290.00 SOC SEC TAX 92.81
1,497,00 4,417.00 LI FE 9.27 18.54 MEDICARE TAX 21. 71
" ,"497.00 4,417.00 DVP 176.00 528,00 STATE TAX 41.92
1,497.00 4,417.00 LOCAL TAX 14.97
OPT-HBG 10.00
UCC .30
620.34 TX SHT RET 93.56
GARNISHMENTS 468.77
william S. Taylor
427 S york Street
Mechanic~urg, PA 17055
<-
Soc' Sec Ntlrn
I
YTO,' I
387.46
273.85
64.05
'123:68 \
44.17
10.00
.88
276.06
1,339.08
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CERTIFICATE OF SERVICE
I, Debra K. Spinner, Secretary in the law firm of MANCKE,
WAGNER, and SPREHA, do hereby certify that I am this day serving
a copy of the foregoing document to the following persons and in
the manner indicated below, which service satisfies the
requirements of the Pennsylvania Rules of Civil Procedure, by
depositing the same in the United States Mail, Harrisburg,
Pennsylvania, with first class postage, prepaid, and addressed as
follows:
Diane G. Radcliff, Esquire
3448 Trindle Road
Camp Hill, PA 17011
By
/t/lkJc;( Jp~
Debra K. Spinner, Secretary
MANCKE, WAGNER, & SPREHA
2233 North Front street
Harrisburg, PA 17110
P. Richard Wagner, Esquire
Attorneys for Husband
DATE:
-1/1/03
/ I
"
,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
~I \\,DY~
NATALIE ANNE ACRI
formerly NATALIE ANNE TAYLOR,
Plaintiff
V.
WILLIAM TAYLOR,
Defendant
NO. 01-3601 CIVIL TERM
CJVJL ACTION - LAW
IN DIVORCE
PLAINTIFF'S PRE-TRIAL STATEMENT
Plaintiff, Natalie Anne Taylor, by her attorney. Diane G. Radcliff, Esquire files this Pre-Trial
Statement.
TABLE OF CONTENTS
- .
SECTION DESCRIPTION PAGE
I. BACKGROUND INFORMATION 2
II. LISTING OF MARITAL ASSETS AND DEBTS 7
III. LISTING OF PERSONAL PROPERTY . 12
IV. LISTING OF MARITAL DEBTS 13
,
V. PENSIONS 14
.
VI. LISTING OF NON-MARITAL ASSETS AND DEBTS 15
VII. INCOMES AND EXPENSES .- 17
VIII, COUNSEL FEES AND COSTS - 22
,-
IX, EXPERT WITNESSES . 23,\
X. OTHER WITNESSES - 24
XI. PROPOSED RESOLUTION 25
XiI. LISTING OF PROPOSED EXHIBITS - 26
Respectfully Submitted,
DATED:
fo !lL ( 63
3 nn Ie oad
C . , 17011
Phone: (717) 737-0100
Fax: (717) 975-0697
Supreme Court 10 # 32112
SECTION I.
BACKGROUND INFORMATION
A.. "PAin I t:::s
DESCRIPTION WIFE X HUSBAND
Name Natalie Anne Acri William Samuel Taylor
(First. Middle, Last) (formerly Natalie Anne Taylor) X
Maiden Name Natalie Anne Blaine
Home Phone 717-692-3009 717-766-7094
Cell Phone No. 717-215-8892 717-877-8191
Work Phone No. None
Social Security Number 202-46-5070 194-52-1745
Address 755 Tarry Hall Road 455 South York Street
(Including County) Millersburg, PA 17061 X Mechanicsburg, PA 17055
Perry County Cumberland County
Names and Relationship of Persons Katherine J. Taylor (Daughter) X Mother
Living with Party Eden D. Taylor (Daughter) Sister
Brooke A. Taylor (Daughter) Brother
Joseph Acri (Husband) X
Date Party Moved into this 8/10/02 1/29/01
Residence
Date PA Residency Began Entire Life (except college) Entire Life
Age 39 44
Date of Birth January 25, 1964 September 2, 1958
Place of Birth West Lawn, Pennsylvania Halifax, Pennsylvania
Race Caucasian Caucasian
Health Status Poor Good
Educational Background College: BA High School Graduate
Current Military Service N/A X N/A
Employer's Halifax School District House of Representatives
Name and Address
Occupation (Job Position) Part Time substitute Teacher Legislative Aid
Date Employment Commenced Currently unemployed 1987
Est. Income $0,00 to $1,300.00 - 2,000.00 per $36,600.00/yr
year. Currently Wife's health X
prevents her employment.
-
Grounds for Divorce
Prior Divorce Actions Between Parties
Number of this Marriage for Wife
Number of this Marriage for Husband
October 13,1989
Harrisburg, Dauphin County, Pennsylvania
January 29, 2001
Domestic Violence - PFA Order entered January
2001, Husband was removed from home, Criminal
charges filed. Wife dropped charges to get support,
3301 D - 2 year separation
o
1
2
Date of Marriage
Place of Marriage
Date of Separation
Statement of Marital Problems
c.
NAME AGE DATE OF BIRTH CUSTODIAN OR
EMANCIPATION
Katherine J. Taylor 12 September 14, 1990 Mother
Eden D, Taylor 11 November 18, 1991 Mother
Brooke A. Taylor 7 June 2, 1996 Mother
D.SU
Name of Party Paying Support
Beneficiaries of Support
Allocation
Agreement or Order
Date of Agreement or Order
Docket Number of Support Order
William Taylor
Katherine J. Taylor, Eden D, Tajllor, Brooke A. Taylor
$870.00 per month or $405,00 biweekly
Order
March 12, 2001
00118 S 2001
"
E. PRIOR MARRIAGES
PARTY NUMBER OF DATE OF MANNER OF TERMINATION
MARRIAGE TERMINATION
WILLIAM TAYLOR 1 Unknown Divorce
F. CHILDREN OF OTHER RELATIONSHIPS/MARRIAGES
PARTY NAME OF CHILD DATE OF BIRTH AGE CUSTODIAN OR
EMANCIPATION
None NfA NfA NfA NfA
G. SUPPORT/ALIMONY FOR PRIOR MARRIAGES/RELATIONSHIP
Name of Party Paying Support NfA NfA
Beneficiaries of Support NfA NfA
Allocation NfA NfA
Agreement or Order NfA NfA
Date of Agreement or Order NfA NfA
Docket Number of Support Order NfA NfA
Comments: NfA NfA
I H.~RMA'i5A':
1, COMPLAINT
Date of Filing of Complaint June 11, 2001
Date of Service June 18, 2001
Manner of Service Acceptance of Service by Defendant's Counsel
Type of Divorce Requested 3301 (c) and 3301(d) No-Fault
Economic Claims Raised Equitable Distribution
Date of Filing of Amended Complaint January 29, 2003 ,
Date of Service January 29, 2003
Manner of Service Regular mail upon Defendant's Counsel
Type of Divorce Requested 3301(c) and 3301 (d) No-Fault
..
Economic Claims Raised Equitable Distribution; APL Alimony; Counsel Fees
2. ANSWER, COUNTERCLAIM OR OTHER PLEADING RAISINcrECONO'Mr'C~
Type of Pleading None
Date of Filing of Pleading N/A
Type of Divorce Requested N/A
Economic Claims Raised N/A
3. INCOME AND EXPENSE STA~S
Date of Filing of Plaintiff's I&E Statement March 21,2003 ,
Date of Filing of Defendant's I&E Statement Not filed
._~ -~---- "
4. INVENTORIES
Date of Filing of Plaintiff's InventOl}' May 23, 2003
Date of Filing of Defendant's Inventory Not filed
5. 3301 C DOCUMENTS
Date of Plaintiff's 3301(c) Affidavit N/A
Date of Filing of Plaintiff's 3301 (c) Affidavit N/A
Date of Defendant's 3301(c) Affidavit N/A
Date of Filing of Defendant's 3301(c) Affidavit N/A
Date of Plaintiff's 3301(c) Waiver of Notice N/A
Date of Filing of Plaintiff's 3301 (c) Waiver N/A
Date of Defendant's 3301 (c)waiver of Notice N/A
Date of Filing of Defendant's 3301 (c) Waiver N/A
6. 3301 D DOCUMENTS
Date of separation January 29, 2001
Manner of separation (in house or physical) Physical
Date of expiration of 2 year separation period January 29, 2003
Date of Plaintiff's 3301(d) affidavit January 29, 2003
Date of filing of Plaintiff's 3301 (d) affidavit January 29, 2003
Date of service of 3301 (d) affidavit January 29, 2003
Manner of service of 3301 (d) affidavit Certified Mail upon Attorney for Defendant
Date of Plaintiff's notice of intent to request entry of 2/26/03
Divorce Decree and 3301(d) counter-affidavit
Date of service of Plaintiff's notice to request entry of 2/26/03 -
Divorce Decree and 3301(d) counter-affidavit
Manner of service of Plaintiff's notice to request Regular mail on Defendant's Attorney
entry of Divorce Decree and 3301(d) counter-affidavit
7. BIFURCATION
Has the case been bifurcated? Yes
Date of order granting bifurcation March 21, 2003
If bifurcation granted by consent or after hearing By Consent
Date of Divorce Decree March 26, 2003; Amended April 21, 2003
- -,
8, PREVIOUSLY RESOLVED ISSUES
Issue Resolved Divorce & APL
Resolution Divorce Decree granted on II: APL claim withdrawn
"
SECTION II
MARITAL ASSETS AND DEBTS
Rule 1920,33(b)(1): a list of the assets which may be in chart fonn Indicating their value, the date of valuation, whether
any portion is non..marital; and any liens and encumbrances thereon.
The following is a listing of the assets and debts of the parties:
MARITAL PROPERTY AND LIABILITIES
DESCRIPTION OF PROPERTY
OR LIABILITY
DATE OF
VALUE
VALUE OF
ASSET OR
LIABILITY
NET
VALUE
PROPOSED
DISTRIBUTION
TO WIFE
PROPOSED
DISTRIBUTION
TO HUSBAND
REAL ESTATE AND REAL ESTATE MORTGAGES (INVENTORY #1)
ITEM 1. (REAL ESTATE #1)
103 North 2nd Street 7,1.02 55.060,00
Worml~sbur~, PA
Tax #4 -20-1 58-029
@55,060.00
Mort9aei 12.31.02 balance 12.31.02 (17,656,06)
@17.6 ,06
Net Equity 37,403.94
Half of Equity for 50% 18,701,97
OWnerSh~
@$18,70 .97 (37,403,94/2)
Half of $1 , 1 07.12 Excess Down (553.56)
Payment Made by Wife's
Parents
@$553,56($1,107.12/2)
Net EaUity after Ad~stment 18,148,41
for Wi e's Parents cess
Palment of Closing Costs @
$1 ,148,41
Half of 2001 Rentai Loss of 2001 (709.87)
$1,419.73 Paid b~ Wife's
Parents@$709, 7 ($1,419.73/
2)
Half of 2002 Rental Loss of 2002 (1.600.89)
$3,201,78 Paid bb Wife's
Parents ~ $1,60 ,89
($3,201, /2)
Half of 2003 Rental Loss for 6 2003 (369.91)
Months of $739,82 Paid b{'
Wife's Parents @ $369.9
($739,82/2)
Net EqUi~ after Ad~ustment 15,467.74 15,467.74 15,467,74
for Renta Losses aid by
Wife's Parents 2001-2003
COMMENTS FOR WORMLEYSBURG PROPERTY:
MARITAL P
DESCRIPTION OF PROPERTY
OR LIABILITY
DATE OF
VALUE
VALUE OF
ASSET OR
LIABILITY
NET
VALUE
PROPOSED
DISTRIBUTION
TO HUSBAND
PROPOSED
DISTRIBUTION
TO WIFE
This property was acquired on 6/8/90 for $55,900.00..[ The property is held in the joint names of the parties
(50%) and wife's parents (50%), .[ There was a $1,000,00 deposit and $6,107.12 paid in closing costs for a
total of $7,107.12.,( The remainder was financed with a mortgage in the amount of $49,900.00, ,(The closing
costs were paid $3,000.00 by the parties and $4,107.12 by wife's parents, Thomas and Jean Blaine ($1,107,12
difference), .[
7.1.00 and 1/1/02 tax assessment value is $55,060.00..[
12.31,00 mortgage balance I $25,874.57.[
12.31.01 mortgage balance $21,979,84,.[
12.31,02 mortgage balance $17,656.06.[
Rents for 2001.[
Rent
Expenses
Net Before Depreciation
Mortgage Principal Payments
Net [oss
$7,140,00
~~4.665.00)
,475.00
f$3j894.73d
-$ ,419,7 )
Rents for 200U
Rent $7,140.00
Expenses ($6.027,00)
Net Before Depreciation $1,113.00
Mortgage Principal Payments ($4.323.781
Net [oss (-$3,210.78)
Estimated Rents for 2003 (Est.)
Rent
Expenses
Net Anticipated
Six Months of Net Loss
The breakdown of the estimated expenses for 2003 are as foilows:
Mortgage payments =$534.08/month wlo escrows or $6,408.96/yr..f
2003 County-Municipal taxes face = $208,56 .[
2002 School taxes face = $556.11 .[
2003 Insurance = $402.00. .[
Sewer @ est. based on 2002 = $440.00.[
Misc, Exp @est. based on 2002 = $212,00.[
Repairs est. based on 2002 = $392,00.[
MARITAL PROPERTY AND LIABILITIES
DESCRIPTION OF PROPERTY DATE OF VALUE OF NET PROPOSED PROPOSED
OR LIABILITY VALUE ASSET OR VALUE DISTRIBUTION DISTRIBUTION
LIABILITY TO HUSBAND TO WIFE
ITEM 2. (REAL ESTATE #2) ( See Comments)
63 North 31" Street 2002 127,010,00
camfoHiII, PA 17011
Tax 1-21-0273-272
@$127,010,OO
Mort~a~e balance as of 2/1 0/03 2,10,03 (51,298.83)
@$ 1, 98,83
Preliminary Net Equity 75,711,17
Down payment and closing 6.14.96 (18,525.79)
costs paid ~ Wife's parents
@$18,525, 9
Net Equity after Adlustment 57,185.38
for Relmbursemen of Down
~ayment and ClOSing Costs
aid by Wife's Paren s
Mo~a~e, taxes and Ins'8aid 2/1/01- (21,749,28) ,
b~ ,fe s parents after D S 5/31/03
1/1/01-5/31/03 ) ~ $2,749,28
$776,76/mo X 2 mol
Other expenses !:laid b~ Wife's 2/1/01- (2,800.00)
parents after DOS &2/1 01- 6/30/03
5/31/03) est. @ $ ( 100.00/mox
28 months)
Net Equity after A~ustment 32,636,10
for MortW'?,e and xpenses
Paid bli ie's :f<arents after
DOS ( /1/01-5/ 0103)
Cost of improvements made by (27,000,00)
Wife's parents post-separation
Net Equity after Adjustment 5,636.10
for Costs of Improvements
Made bX Wife's Parents after
DOS (2 1/01-5/31/03)
MOV\jla~e, taxes and ins, paid 8/1/96- (42,721.80)
bY: Ife s parents 7/1/96- 1/31/01
131/01
@$42,721,80 ($776.76/mo x
55)
Other ex~enses paid by Wife's 6/14/96- TBD
~arents /14/96 -1/31/01 @ 6/30/96
TBD
Net Equity after A~ustment (31,449.60) N/A N/A N/A
for MortW'?,e and xpenses
Paid by ie's Parents from
Purchase to DOS
MARITAL PROPERTY AND LIABILITIES
DESCRIPTION OF PROPERTY DATE OF VALUE OF NET PROPOSED PROPOSED
OR LIABILITY VALUE ASSET OR VALUE DISTRIBUTION DISTRIBUTION
LIABILITY TO HUSBAND TO WIFE
COMMENTS FOR CAMP HILL PROPERTY:
The above information is inserted for informational purposes only based on husband's claim that this
prorlle~ is a marital asset. The inclusion of this information does not chan~e wife's position that the
pa ies ave no interest in this property and it is not subject to equitable dis ribution.
Wife and her parents, Thomas and Jean Blaine, claim this property belongs to her parents, that the parties
have no interests in this property, and that this property is not subject to equitable distribution, The proper:\)r
was purchased by wife's parents as an investment to be able to fund the parties' children's college education,
This &ro&erty was ac~uired on 6/14/96 for $79,000,00..[ Wife's parents, Thomas and Jean Blaine fiaid the
$3,0 0, 0 deposit an $15,525.79 in down payment and closin~ costs for a total of $18,525.79..[ he
remainder was financed by a mortgage in the amount of $63,0 0.00 @$577,31/mo..f
This pro~erty is titled in the names of wife's parents, Thomas G. Blaine and Jeanne R. Blaine,.[ Wife's
parents ave all of the mortgage payments, taxes and insurance since date of purchase.
7,1.02.Tax assessment value is $127,010.00.[
2,10,03 mortga!be balance = $51 ,298.83.[ -
DOS mortgage alance@$56,798,OO
Mortgage payment = $577.31 wlo escrows. .[
2003 coun~-Municipal taxes = $542.71 per r Face ($45.23 per month).[
2002 Schoo taxes = $1,413.62 per yr face ( 117,80 per mo.).[
2002 Insurance = $437.00 per yr, ($36.42 per monthd
Total monthly costs wlo utilities and repairs: $776.7 . Utilities and normal repair ccsts are est, @$100,OO-
$130,00 per month. Since the parties' separation wife's parents have made improvements to the property@
$27,000,00+1-. -
-
EMPLOYMENT PENSION & RETIREMENT PLANS (INVENTORY #18)
ITEM 3, (RETIREMENT#1)
Husband's SERS Pension 1.29,01 73,657.70 73,657.70 73,657.70
COMMENTS FOR SERS PENSION:
12,31.99 present value assigned by the State is $48,566.11..[ n
1.29.01. present value assigned by State is $73,657.70 including contribution account of $18,799,80..f
This pension has not yet been valued by an actuary. Actuarial value may be more or less than above
stateCl amount.
HOUSEHOLD GOODS AND FURNISHINGS (ATTACHED LIST IF IN DISPUTE) (INVENTORY #25)
ITEM 5, (PERSONAL PROPERTY #1)
Husband's and Wife's NIA N/A N/A
Household Goods
COMMENTS FOR HOUSEHOLD GOODS:
Wife believes distribution should remain as is. Therefore no dollar figure has been inserted herein,
DESCRIPTION OF PROPERTY
OR UABILITY
TOTALS
TOTAL OF ASSETS AND LIABILITIES
PERCENTAGE OF DISTRIBUTI
Totals from above
Percentage of Total Net Marital Estate
ADJUSTMENT FOR SO/50 DIVI
Totals from above
Amount Due in 50/50 Division
Adjustment figure for SO/50 Division
ADJUSTMENT FOR 45/55 DMSI
Totals from above
Amount Due in 45/55 Division
Adjustment Figure for 45/55 Division
ADJUSTMENT FOR 40/60 DIVISION
Totals from above
Amount Due in 40/60 Division
Adjustment Figure for 40/60 Division
89,125,44 73,657,70 15,467,74
44,562.72 44,562.72
(29,094.98) 29,094.98
89,125.44 73,657,70 15,467.74
40,106.45 49,018.99
(33,551.25) 33,551,25
89,125.44 73,657.70 15,467,74
35,650.18 53,475.26
(38,007.52) 38,007,52
SECTION III.
LISTING OF HOUSEHOLD GOODS AND CONTENTS
AND OTHER PERSONAL PROPERTY
Rule 1920-33(b)(9): If there is a dispute as to tangible personal property, the list shall include the description, value,
method of valuation, and the evidence to be submitted including documentation in support of the valuation.
The following is a listing of the household goods and contents and other personal
property of ffie parties:
(Note: Exclusions from marital property include property acquired before marriage, property acquired
after separation, or property acquired during marriage by way of gift or inheritance from third party not a
spouse. For gifts and inheritance also specify the source person).
HOUSEHOLD GOODS AND OTHER PE S
DESCRIPTION
OWNER
POSSESSOR
VALUE
BASIS FOR EXCLUSION IF
CLAIMED TO BE NON-
MARITAL
METHOD OF
VALUATION AND
SUPPORTING
DOCUMENTATION
ITEM 1
N/A
Comments:
Wife feels the distribution of household goods and contents should remain divided as is. Therefore, no
information is inserted in this Section,
SECTION IV.
MARITAL DEBTS
Rule 1920.33(b)(10): the list of marital debts shall include the amount of each debt as of date of the separation, the
date on which the debt was initially incurred, the initial amount of the debt and its purpose, the amounts and dates of
payments made since the date of separation and the evidence that will be offered in support of the claim,
The following is a listing of the parties' marital debts:
DESCRIPTION PURPOSE DATE AMOUNT OF AMOUNT OF
INCURRED INITIAL DEBT AT
DEBT SEPARATION
ITEM 1,
Wormleysburg Purchase of 6.8.90 49,900.00 $25,874.57 See Comments
Mortgage Wormelysburg (12.31.00)
property
Comments:
The following comprises the $25,874.57 amount paid by Wife's parents set forth above:
50% of the $1,107,12 Down payment difference@$553.56
50% of the following rental losses paid 2001~-03 @ $2,680.67
Rents for 2001
Rent
Expenses
Net Before Depreciation
Mortgage Principal Payments
Net Loss
Rents for 2002
Rent
Expenses
Net Before Depreciation
Mortgage Principal Payments
Net Loss
Estimated Rents for 2003
Rent
Expenses
Net Anticipated
Six Months of Net Loss
$7,140,00
.'. ($4.665.001
$2,475,00
($3.894.731
(-$1,419.73)
$7,140.00
($6.027.00)
$1,113.00
($4,323,78)
(-$3,210,78)
$7,140,00
($8.619.631
(-$1,479.63)
(-$ 739.82)
SECTION V.
PENSIONS AND RETIREMENT BENEFITS
Rule 1920-33(b)(1): The Pre-Trial statement shall include the value of the pension or retirement benefits and the marital
portion thereof, and the facts and documentation upon which the party relies to support the valuation.
The following is a listing of the pensions and retirement plans of the parties:
DESCRIPTION
SUPPORTING FACTS OR
DOCUMENTATION
ITEM 1
Husband's SERS Pension
Comments:
73,657,70
73,657.70
state of Pennsylvania Statements
This pension has not yet been appraised.
SECTION VI.
NON-MARITAL ASSETS AND DEBTS
Rule 1920.33(b)(1)(ii): the listing of assets shall include a list of non-marital assets, their value, the date of valuation. and
any liens or encumbrances thereon.
The following is a listing of the non-marital assets and debts of the parties:
(Note: Exclusions from marital property include property acquired before marriage, property acquired after
separation, or property acquired during marriage by way of gift or inheritance from third party not a spouse.
For gifts and inheritance also specify the source person),
DESCRIPTION
OWNER
POSSESSOR
ITEM 1. (REAL ESTATE #2)
63 North 31" Street Thomas &
Camp Hill, PA Jean Blaine
17011
Tax #O1-21"()273-272
Thomas &
Jean Blaine
(Rental)
Mortgage balance as of 2/10/03
Preliminary Net Equity
Down payment and closing costs paid by Wife's
parents
Net Equity after Adjustment for
Reimbursement of Down payment and
Closing Costs Paid by Wife's Parents
Mortgage, taxes and Ins. paid by Wife's parents
after DOS (2/1/01-5/31/03) @$2,749.28
($776.76/mo X 28 mol
Other expenses paid by Wife's parents after DOS
(2/1/01-5/31/03) est. @$ ($1QO.OO/mox 28
months)
Net Equity after Adjustment for Mortgage and
Expenses Paid by Wife's parents after DOS
(2/1/01-5130103)
Cost of improvements made by Wife's parents
post-separation
Net Equity after Adjustment for Costs of
Improvements Made by Wife's Parents after
DOS (2/1101-5131103)
Mortgage, taxes and ins. paid by Wife's parents
VALUE
127,010,00
(51,298.83)
75,711,17
(18,525.79)
57,185.38
(21,749.28)
(2,800.00)
32,636.10
(27,000,00)
5,636.10
(42,721,80)
BASIS FOR EXCLUSION
IF CLAIMED TO BE NON
MARITAL
METHOD OF
VAWATlON AND
SUPPORTING
DOCUMENTATION
Owned by wife's
parents,
Deed; Note;
Mortgage;
Settlement Sheet;
Checks and the
like
"
NON-MARITAL PRoPERTY AND DEBTS
DESCRIPTION
OWNER
POSSESSOR
VALUE
BASIS FOR EXCLUSION
IF CLAIMED TO BE NON
MARITAL
METHOD OF
VALUATION AND
SUPPORTING
DOCUMENTATION
7/1/96-1/31/01
@$42,721.80 ($776,76/mo X 55)
Other expenses paid by Wife's parents 6/14/96 -
1/31/01 @ $TBD
Net Equity after Adjustment for Mortgage and
Expenses Paid by Wife's Parents from
Purchase to DOS
COMMENTS FOR CAMP HILL PROPERTY:
TBD
(37,085.70)
Wife and her parents, Thomas and Jean Blaine, claim this property belongs to her parents, that the parties
have no interests in this property, and that this property is not subject to equitable distribution, The property was
purchased by wife's parents as an investment to be able to fund the parties' children's college education.
This property was acquired on 6/14/96 for $79,000,00...[ Wife's parents, Thomas and Jean Blaine paid the
$3,000.00 deposit and $15,525.79 in down payment and closing costs for a total of $18,525.79...[ The
remainder was financed by a mortgage in the amount of $63,000.00 @$577.31/mo...f
This property is titled in the names of wife's parents, Thomas G, Blaine and Jeanne R. Blaine,..[ Wife's parents
have all of the mortgage payments, taxes and insurance since date of purchase, Total monthly costs w/o
utilities and repairs= $776.76. Utilities and normal repair costs are est. @$100,OO-$130,OO per month. Since
the parties' separation wife's parents have made improvements to the property @ $27,000.00+/-,
SECTION VII.
INCOME AND EXPENSES
Rule 1920,33(b)(5)(6}: The Pre-Trial Statement shall include the party's gross income from all sources, each payroll
deduction, and the party's net income, including the party's most recent federal and state income tax returns and pay
stubs. If the party intends to offer testimony as to his or her expenses, a current expense statement in the form required
by the practice and procedure is support actions must be supplied.
The following is Wife's Income and Expenses:
PART I. INCOME
EMPtoy"lE:NT INFORMAT.
Prior Employer: Halifax School District
Address: Halifax, PA
Position: Substitute Teacher
Payroll Number: XXXXX5070
Pay Period: Biweekly
EMPLOYMENT INC." _
DESCRIPTION AMOUNT
Gross Pay per Pay Period 320.00
FICA or Se Tax (19.84)
Medicare or Se Tax (4.64)
Federal Tax
State Tax (8,96)
Local Tax (3.20)
Mandatory Retirernent
Voluntary Retirement
Health Insurance
Net Pay per Pay Period 283.36
Net Pay per Month $613.95
Note: Plaintiff was off of work until mid-February, 2003 due to ill health, She returned to work on
a part time basis against her physician's instructions. This employment ended as of the end of
March, 2003. She will not be returning to work after that date due to health problems. Her
anticipated income for 2003 from the aoove will be $1,300.00. no further income is anticipated
due to health problems.
OTHER INCOME ,.., , ,
DESCRIPTION MONTHLY YEARLY
Interest
Dividends
Pensions
Annuities
Social Security
Rents
Royalties
Expense Account
Gifts
Unemployment Compensation
Workman's Compensation
Income Tax Refunds
Child Support 881.00 10,582,00
Commissions
Tips
Other
Total other Income $881,00 $10,582,00
PART II. EXPENSES
Note: Expenses in "Household Column" represent expenses for the household that are shared expenses
since they arere shared between plaintiff and her current husband.
DESCRIPTION HOUSEHOLD AMOUNT MONTHLY AMOUNT
HOME EXPENSES:
Rent $400,00
First Mortgage $1,133,00
Second Mortgage/Home Equity t.oan
Maintenance And Repairs $50,00
Electric $250.00 $100.00
Gas
"
DESCRIPTION , HOUSEHOLD A~ MONTH!.. Y AMOUNT
Oil
Telephone $25,00
Water
Sewer
Trash
EMPLOYMENT
Public Transportation
Lunches
Other Employment Expenses
TAXES: , , , H.,
Real Estate Taxes Included in mortgage
Personal Property Taxes
Income Taxes Not Withheld
Per Capita/Occupation Taxes
INSURANCE:
Homeowners Insurance $450.00
Automobile Insurance
Life Insurance $30,00
Accident Insurance
Health Insurance
Other Insurance
AUTOMOBILE EXPENSES:
Payments ,
Fuel $150.00
Maintenance And Repair $42,00
License And Registration $3,00
MEDICAL EXPENSES
Doctor $20.00
Optical $10.00
Dental
Orthodontic
DESCRIPTION H~ MONTHLY AMOUNT
Hospital
Medicine $30.00
Special NeedslTherapy Etc,
EDUCATIONAL EXPENSES:
Private School
Parochial School
CollegeNocational
Religious Training or Education
Books/Fees And Supplies $10.00
Other Educational Expenses $120,00
School lunches
PERSONAL EXPENSES:
Clothing $150,00
Food $600.00 $400.00
Barber And Hair Dresser $50,00
Memberships $41.00
Other Personal Expenses $40.00
Children's activities
-
CREDIT CARDS AND LOANS:
No Creditor Balance
1. Hecht's 1000 $60,00
MISCELLANEOUS EXPENSES:
Household Help
Child Care
Newspapers/Magazines/Books $10.00
Entertainment $75.00
Pay TV ' -
Vacations $250.00
Gifts $375,00
LegaiFees $200.00
Charitable Contributions
Other Child Support
"
,
DESCRIPTION HOUSEHOLD AMOUNT MONTHLY AMOUNT
Other Spousal Support or Alimony
Veterinary Bills $60,00
TOTAL EXPENSES $2,651,00
SECTION VIII.
COUNSEL FEES
Rule 1920.33(b)(8): If there is a claim for counsel fees the Pre-Trial statement shall include the amount of the fees to be
charged; the basis for the charge; and a detailed itemization of the services rendered.)
The following is a listing of the counsel fees and expenses incurred by Plaintiff:
DESCRIPTION DATES, I3ILLS AND CHARGES
Dates Services Were Rendered 6/18102-current
Hourly Rate $175.00 Per Hour
Costs Costs are billed at <lctual cost
Total Amount of Fees and Costs Claimed to $6,447.26
5131103
Anticipated Fees and Costs Hourly rate for estimated 25 hours @175.00/hrfora
total of $4,375,00 + actual ccst for any required
appraisals,
Itemization of Services Rendered Itemized statements have been attached to this Pre-
Triai statement which set fortb a detailed itemization of
the services that have been rendered in this case,
'.
SECTION IX.
EXPERT WITNESSES
Rule 1920.33(b)(2): The Pre-Trial Statement shall include the name and address of each expert the party intends to call
at trial as a witness. The report of each expert shall be attached to the Pre-Trial Statement The expert report shall
describe witness qualifications and experience and state the substance of the facts and opinions to which the expert
is expected to testify and a summary of the grounds of each opinion.
The following is a listing of the experts who the party intends to call to testify in this case:
NAME SUBJECT OF TESTIMONY REPORT ATTA~ REPORT TO BE
SUPPLIED
None known at this time"" To be determined None available at this To be supplied as soon
time as available
"Additional experts who may be called to testify are not known at this time, There is a reservation
of the right to call additional expert witnesses upon proper notification to the other party once those expert
witnesses are identified and retained.
SECTION X.
OTHER WITNESSES
Rule 1920.33(b)(3): The Pre-Trial statement shall set forth the name, address and a short summary of testimony of each
person, other than a party, whom the party intends to call at trial as a witness.
The following is a listing ofthe anticipated witnesses other than experts who will be called
to testify in this case:
NAME
Natalie Anne Acri
History of the marriage; Identification and valuation of marital assets and debts;
Other relevant testimony relating to the factors set forth in the divorce code
The finances of the parties and the acquisition and payments made regarding
the two real estate parcels in question in this case.
Thomas Blaine
'*Additional witnesses who may be called to testify are not known at this time, There is a reservation
of the right to call additional witnesses upon proper notification to the other party once those witnesses are
identified and agree to testify,
"
, ~>i: ~
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SECTION XI.
PROPOSED RESOLUTION
Rule 1920.33(b)(11): The Pre-Trial statement shall include a proposed resolution of the economic issues,
The following is the Plaintiff's position regarding resolution of the economic issues
presented in this case:
A. EQUITABLE DISTRIBUTION:
The parties' marital assets and debts should be divided and distributed in accordance with
the Distribution Schedule attached as Exhibit "5" to this Pre-Trial Statement:
B. COUNSEL FEES AND COSTS:
Plaintiff has raised claim for counsel fees and costs. This claim should be granted,
Plaintiff should be awarded $10,000.00 in counsel fees and costs.
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SECTION XII
PROPOSED EXHIBITS
The fqllowing is a listing the proposed exhibits to be submitted at the hearing in this case,
Exhi~!ts have been or will be supplied to Defendant as indicated beloW', Plaintiff reserves
the right to submit additional exhibits upon proper notification to Defendant.
NO. l!ES~~I~'I1"I(!)N SUPPUEIl Ii TO BE SUPPLIED
1 Wife's Income and Expense Statement X
2 Wife's 2002 Tax Returns X
3 Child Support Order X
4 Wife's Counsel Fees Bills X X
5 Wife's Proposed Distribution Schedule X
6 Settlement Sheet for Wormleysburg Property X
7 Deed to Wormleysburg Property X
8 Mortgage and Note for Wormelysburg Property X
9 Tax Assessment for Wormleysburg Property X
10 Mortgage Statements for Wormleysburg Property X
11 Wife's Parents Tax and Other Documents for X
Rental Loss for Wormleysburg Property
12 Settlement Sheet for Camp Hill Property X
13 Deed to Camp Hill Property X
14 Mortgage and Note for Camp Hill Property X
15 Tax Assessment for Camp Hill Property X
16 Mortgage Statements for Camp Hill Property X
17 Mortgage Payments for the Camp Hill Property X
18 Utilities/Repair/ Improvement Documents for the X
Camp Hill Property
19 Husband's State SERS Statements X
20 Proposed SERS QDRO X
Page 25
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CERTIFICATE OF SERVICE
AND NOW, this day of June, 2003, I, DIANE G. RADCLIFF, ESQUIRE, hereby
certify that 1 have this day served a copy of the within Pre-Trial Statement, by mailing same by first
class mail, postage prepaid, addressed as follows:
P. Richard Wagner, Esquire
2233 North Front Street
Harrisburg, PA 17110
\
. DCLlFF, ESQUI E
3448 Trindle Road
" A 17011
Supreme Court 10 # 32112
Phone: (717) 737-0100
Fax: (717) 975-0697
Page 26
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LAW OFFICES
JOHN B. MANCKE
P. RICHARD WAGNER
EDWARD F. SPREHA, JR.
MANCKE. WAGNER & SPREHA
2233 NORTH FRONT STREET
HARRISBURG, PA 17110
PHONE (717) 234-7051
FAX (717) 234-7080
June 30, 2003
E, Robert Elicker, Esquire
9 North Hanover Street
Carlisle, PA 17013
Re: Taylor v. Taylor
Dear Mr, Elicker:
Enclosed herein please find the Inventory and the Income and Expense
Statement on behalf of my client, William Taylor, in the above-captioned matter.
Your attention is appreciated.
a Wagner
PRW/dks
Enclosures
cc: Diane G, Radcliff, Esq. (w/encl.)
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LAW OFFICES
JOHJ"Ii B. MANCKE
P. RICHARD WAGNER
EDWARD F. SPREHA. JR.
MANCKE, WAGNER & SPREHA
2233 NORTH FRONT STREET
HARRISBURG, PA 17110
PHONE (717) 234-7051
FAX (717) 234-7080
November 14,2003
E. Robert Elicker, Esquire
9 North Hanover Street
Carlisle, P A 17013
Re: Taylor v. Taylor
No: 01-3601
Dear Mr. Elicker:
We have joined the parents of Natalie Taylor in the divorce action as indispensable
parties, which has been confirmed by Court Order of Judge Hess, dated November 10,
2003.
Therefore, I would appreciate if you could schedule a pre-hearing conference at
your immediate convenience.
Your attention is appreciated.
PRW/dks
Enclosure
cc: Diane G. Radcliff, Esq.
Mr. Bill Taylor
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NATALIE ANNE T,o,YLOR.,
: IN THE COU'RT OF COMMON PLEAS
: CUMBERLAND COIJNTY, PENNSYLVANIA
Plaintifi?Respondent,
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: NO: 0]-360]
: CIVIL TERM
\V1LLIAM TI'<,YLOR,
: IN DIVORCE
Defendant/Petitioner.
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THOWJJ;S BLAINE and .IRAN BLAINE,
Additional Defendants.
fJRDE~
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i\ND NOW, this }{thday o(~ \ov~m he..tt----. 2003, ,he Rule of
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September 12, 2003, is now absolute ll.Ild Thomas Blaine and Jean Blaine, his wife, are
joined as indispensable parries in the above-,;aptioned divorce action.
BY THE COURT:
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DIANE G. RADCLIFF, ESQUIRE
Attorney at Law
3448 Trindle Road
Camp Hill, Pennsylvania 17011
Phone: (717) 737-0100
Facsimile: (717) 975-0697
November 17,2003
E. Robert Elicker, II, Esquire
Cumberland County Divorce Master's Office
9 North Hanover Street
Carlisle, PA 17013
Re: Natalie A. (Taylor) Acri vs. William Taylor v. Thomas and Jean Blaine
Cumberland County Divorce Action No. 01-3601
Dear Divorce Master Elicker:
I am in receipt of Attorney Wagner's letter to you dated November 14, 2003,
requesting the scheduling of a pre-hearing conference in this case, I oppose that request for
the following reasons:
1. At the request of Defendant, William Taylor, Thomas and Jean Blaine were
joined as additional Defendants in this case by Order dated November 10,
2003 entered by Judge Hess;
2. The Rule 2252 of the Pennsylvania Rules of Civil Procedure requires that a
Complaint be filed against the additional Defendants.
3. Rule 2255 of the Pennsylvania Rules of Civil Procedure requires that the
procedure to be filed, including the pleadings, between the party joining an
additional defendant and the additional defendant shall be the same as though
the party joining the additional defendant were a plaintiff and the additional
defendant were a defendant.
4. As of the date of this letter no complaint or other pleadings have been filed by
the Defendant, William Taylor, against the Additional Defendants,
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E. Robert Elicker, II, Esquire
November 17,2003
5. Until the Complaint is filed, the additional Defendants will be denied their
right to raise defenses and/or counterclaims against the Defendant or in
response to his alleged cause of action against them. Also, until that complaint
is filed meaningful discovery cannot be conducted by the Blaines, which they
deem to be imperative in this case.
6, I have sent two letters to Attorney Wagner requesting the filing of the
Complaint against the Additional Defendants. In response to my first letter he
indicated he would not consider my request since I was not officially
representing the Blaines. I, therefore, mailed a Praecipe to enter my
appearance on their behalf which was sent to Attorney Wagner on November
17, 2003, and have again requested that he file the Complaint against the
Additional Defendants in this case. If he does not file his Complaint as
required by the Pennsylvania Rules of Civil Procedure, I will file a Petition
seeking the entry of a Rule against the Defendant to file that complaint.
7. Until the pleadings are closed as regards to the Additional Defendant, a pre-
hearing conference would be premature.
Thank you for your consideration of this letter. Should you have any questions or
comments about this situation, or require further information from me, do not hesitate to
contact me.
Very truly yours,
DGR/dr
cc: P. Richard Wagner, Esquire
Natalie A. Acri
Thomas and Jean Blaine
File 28-02D
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYL VANIA
NATALIE ANNE TAYLOR,
Plaintiff
No. 01-3601 CIVIL TERM
v.
CIVIL ACTION - LAW
WILLIAM TAYLOR,
IN DIVORCE
Defendant
v,
THOMAS BLAINE and JEAN BLAINE,
Additional Defendants:
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY OF THE SAID COURT:
Please enter the appearance of Diane G. Radcliff, Esquire, as attorney for the Thomas Blaine
and Jean Blaine, Additional Defendants, in the above captioned matter,
Respectfully submitted,
DI G ~~ {l
3448 Trindle oad
. , A 17011
PHONE: (717) 737-0100
J.D. No. 32112
Attorney for Thomas Blaine and Jean Blaine,
Additional Defendant's
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NATALIE ANNE TAYLOR,
PlaintifflRespondent,
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO: 01-3601
: CIVIL TERM
WILLIAM TAYLOR,
: IN DIVORCE
DefendantIPetitioner.
v.
THOMAS BLAINE and JEAN BLAINE,
Additional Defendants.
ORDER
AND NOW, this /0' day of
,.;~
,2003, the Rule of
September 12, 2003, is now absolute and Thomas Blaine and Jean Blaine, his wife, are
joined as indispensable parties in the above-captioned divorce action.
BY THE COURT:
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NATALIE ANNE TAYLOR,
PlaintifflRespondent,
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO: 01-3601
: CIVIL TERM
WILLIAM TAYLOR,
: IN DIVORCE
DefendantIPetitioner.
v.
THOMAS BLAINE and JEAN BLAINE,
Additional Defendants.
PETITION FOR RULE ABSOLlJTE
AND NOW, comes your Petitioner, William Taylor, by and through his attorneys,
Mancke, Wagner & Spreha, and files the following Petition for Rule Absolute:
1. Your Petitioner, William Taylor, is the Defendant in the above-captioned
divorce action.
2. Respondent, Natalie Anne Taylor, is the Plaintiff in the above-captioned
divorce action.
3. Petitioner filed a Petition September 12, 2003, seeking to join the Respondent's
natural parents, Thomas Blaine and Jean Blaine, his wife, as indispensable parties to the
divorce action on the basis that Thomas Blaine and Jean Blaine, his wife, are titled
oWJ1ers to certain property in which Petitioner asserts a marital interest.
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4. The Rule of September 12, 2003, was made returnable twenty (20) days after
service.
5. Service was made upon Thomas Blaine and Jean Blaine, his wife, on
September 18,2003.
6. No response or answer has been filed thereto.
7. Petitioner seeks to have the Rule absolute joining Thomas Blaine and Jean
Blaine, his wife, as indispensable parties to the above-captioned divorce action.
WHEREFORE, Petitioner prays this Court to grant his Petition for relief in the
form of joining Thomas Blaine and Jean Blaine, his wife, as indispensable parties to the
above-captioned divorce action.
Respectfully submitted,
Mancke, Wagner & Spreha
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.' P. Richard Wagner, Esquire
J.D. #23103
2233 North Front Street
Harrisburg, PA 17110
(717) 234-7051
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Attorneys for Petitioner
Date: /t13/~!3
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CERTIFICATE OF SERVICE
I, Debra K. Spinner, Secretary in the law firm of MANCKE,
WAGNER, and SPREHA, do hereby certify that I am this day serving
a copy of the foregoing document to the following persons and in
the manner indicated below, which service satisfies the
requirements of the Pennsylvania Rules of Civil Procedure, by
depositing the same in the United States Mail, Harrisburg,
Pennsylvania, with first class postage, prepaid, and addressed as
follows:
Diane G. Radcliff, Esquire
3448 Trindle Road
Camp Hill, PA 17011
By
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Debra K. Spinner/ Secretary
MANCKE, WAGNER, & SPREHA
2233 North Front Street
Harrisburg, PA 17110
P. Richard Wagner, Esquire
Attorneys for Defendant
DATE: //Ilf/d3
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYL VANIA
NATALIE ANNE TAYLOR,
now by marriage NATALIE ANNE ACRI
Plaintiff
No. 01-3601 CIVIL TERM
v.
CIVIL ACTION - LAW
WILLIAM TAYLOR,
Defendant
IN DIVORCE
v.
THOMAS BLAINE and JEAN BLAINE,
Additional Defendants
RULE
AND NOW, this 10' day of ~ ,2CC?> , upon consideration of the
within Petition, a Rule is entered upon the Defendant, William Taylor to file a Complaint
setting forth his claims against the Additional Defendants Thomas Blaine and Jean Blaine.
The Complaint shall be filed within twenty (20) days of the Additional Defendants' service
of this Rule upon the Defendant, William Taylor.
All proceedings in this action are stayed until the pleadings pertaining to the
Additional Defendants are closed and all discovery completed.
BY THE COURT:
Distribution to be made to:
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J.
Diane G. Radcliff, Esquire
3448 Trindle Road
Camp Hill, PA 17011
Attorney for Plaintiff and Additional Defendants
P. Richard Wagner, Esquire
2233 North Front Street
Harrisburg, PAl 711 0
Attorney for the Defendant
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,_.GUM8E.F{L;;.:.tU c.JUNTY
, PENNSYLVANIA
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
NATALIE ANNE TAYLOR,
now by marriage NATALIE ANNE ACRI
Plaintiff
No. 01-3601 CIVIL TERM
v.
CIVIL ACTION - LAW
WILLIAM TAYLOR,
Defendant
IN DIVORCE
v.
THOMAS BLAINE and JEAN BLAINE,
Additional Defendants
PETITION FOR RULE TO FILE A COMPLAINT
AGAINST Additional DEFENDANTS
AND NOW, this ~ day of ~...a "'^ ~ , 20~ comes the Additional
Defendants, Thomas Blaine and Jean Blaine, by their Attorney, Diane G. Radcliff, Esquire,
and files the above referenced petition and represent that:
1. Your Petitioners are Thomas Blaine and Jean Blaine, who are the Additional
Defendants in the within action. The Petitioners are hereafter referred to as
"Blaines").
2. Your Respondent is William Taylor, who is the Defendant in the within action. The
Respondent is hereafter referred to as "Taylor".
3. Taylor was previously married to Natalie Anne Acri, who is the Plaintiff in the within
action. Natalie Anne Acri is hereafter referred to as "Acri".
4. This is an action for divorce filed by Acri against Taylor, in which a claim has been
made for equitable distribution of marital property.
5. In this action various disputes have arisen pertaining to the identification of the
marital assets including, but not limited to, a property numbered as 63 North 31"
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Street, Camp Hill, P A 17011, which is owned by the Blaines and which property the
Blaines and Acri claim is not marital property, and on the contrary, which property
Taylor claims is marital property.
6. As the result of the foregoing disputes Taylor sought the entry of an order joining the
Blaines as Additional Defendants to this action and on November 10, 2003 an order
was entered by this Honorable Court joining the Blaines as Additional Defendants.
7. Pit.R.C.P. 1920.34. Joinder of Parties provides:
At any stage of an action, the Court may order the joinder of any
Additional person who could have joined or been joined in the action
and may stay the proceedings in whole or in part until such person has
been joined. The action may proceed although such person has not
been made a party if jurisdiction over that person cannot be obtained
and that person is not an indispensable party to the action.
Note: The joinder of persons other than husband and wife may be
essential in claims for child custody where neither has custody or
custody is claimed by others, or where persons other than the parties
have an interest in property which is the subject matter of a
distribution.
The intervention in an action by a person not a party is
governed by Rule 2326 et seq.
8. Pa.R.C.P. 1920.1. Definitions. Conformity to Civil Action provides:
(b) Except as otherwise provided in this chapter, the procedure in the
action shall be in accordance with the Rules relating to a civil action.
9. Pa.R.C.P. 2252. Right to Join Additional Defendants provides:
(a) Except as provided by Rule 1706.1, any defendant or Additional
defendant may join as an Additional defendant any person, whether or
not a party to the action, who may be
(1) solely liable on the plaintiffs cause of action, or
(2) liable over to the joining party on the plaintiffs cause of
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action, or
(3) jointly or severally liable with the joining party on the
plaintiff's cause of action, or
(4) liable to thejoining party on any cause of action arising out
of the transaction or occurrence or series of transactions or
occurrences upon which the plaintiff's cause of action is based.
Note: The joinder of an Additional defendant in a class action is limited
by Rule 1706.1 to the grounds set forth in subparagraphs (1) to (3).
(b) If the person sought to be joined is not a party to the action the
joining party may file as of course a praecipe for a writ or a complaint.
(1) If the joinder is by writ the joining party shall file a
complaint within twenty days from the filing of the praecipe for
the writ. If the joining party fails to file the complaint within the
required time, the plaintiff or the Additional defendant joined
may seek a rule to file the complaint and an eventual judgment
of non pros in the manner provided by Rule 1 037(a) for failure
to file a complaint.
(2) The complaint, in the manner andform required of the initial
pleading of the plaintiff in the action, shall set forth the facts
relied upon to establish the liability of the joined party and the
relief demanded.
10. Pa.R.C.P. 2255. Procedure provides:
(a) The procedure, including pleadings, between the party joining an
Additional defendant and the Additional defendant shall be the same as
though the party joining the Additional defendant were a plaintiff and
the Additional defendant were a defendant.
(b) No pleadings shall be filed between the Additional defendant and
any party other than the one joining the Additional defendant except
that the Additional defendant may file a counterclaim against the plaintiff
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(c) No judgment on the pleadings may be entered in favor of any party
against an Additional defendant for failure to answer the complaint of
the party joining the Additional defendant, but all allegations offact in
such complaint to which an answer is required and which are not
sufficiently answered shall be conclusive upon the Additional defendant.
(d) The plaintiff shall recover from an Additional defendant found
liable to the plaintiff alone or jointly with the defendant as though such
Additional defendant had been joined as a defendant and duly served
and the initial pleading of the plaintiff had averred such liability.
11. On November 6, 2003, Diane G. Radcliff, Esquire sent a letter to P. Richard Wagner
Esquire, requesting the filing ofthe Complaint by Taylor against the Blaines. A true
and correct copy of the November 6,2003 letter is attached hereto, marked Exhibit
"A" and made a part hereof.
12. On November 11, 2003, P. Richard Wagner, Esquire wrote to Attorney Radcliff
responding to her November 6, 2003 letter advising her that he would await to hear
from the Blaines' legal counsel before responding to the procedural question. A true
and correct copy of the November letter is attached hereto, marked Exhibit "B" and
made a part hereof.
13. On November 14, 2003 Attorney Wagner wrote to the Divorce Master asking for the
scheduling of a conference in this case. A true and correct copy ofthe November 14,
2003 letter is attached hereto, marked Exhibit "c" and made a part hereof.
14. On November 17, 2003, Attorney Radcliff wrote a letter to the Divorce Master
indicating that the conference could not be scheduled since Taylor had not filed his
complaint against the Blaines and discovery by them against Taylor had not been
completed. A true and correct copy of the November 17, 2003 letter to the Divorce
Master is attached hereto, marked Exhibit "D" and made a part hereof.
15. On November 17, 2003, Attorney Radcliff wrote a letter to Attorney Wagner advising
him of the entry of her appearance and again requesting the filing of the complaint
against the Blaines. A true and correct copy of the November 17, 2003 letter to
Attorney Wagner is attached hereto, marked Exhibit "E" and made a part hereof.
16. As of the date of the filing ofthis Petition, Taylor has not filed a Complaint against
4
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the Blaines.
17. Without the filing of a Complaint by Taylor against the Blaines, the Blaines will not
be able to:
A. Apprised ofthe claims Taylor is making against them;
B. Will not be able to defend themselves in this action;
C. Will be able to raise appropriate defenses to those claims.
D. Will not be able to conduct meaningful discovery
18. Pursuant to the foregoing Rules of Civil Procedure, the Defendant, William Taylor
is required to file a complaint against the Additional Defendants, Thomas Blaine and
Jean Blaine.
WHEREFORE, the Additional Defendants, Thomas Blaine and Jean Blaine, respectfully
requests this Honorable Court to enter a rule against the Defendant, William Taylorrequiring
him to file a complaint against the Additional Defendants Thomas Blaine and Jean Blaine
setting forth his claims against them, and to stay all proceedings until the pleading regarding
the Additional Defendants are closed and all discovery is completed.
Respectfully submitted,
~ . ~~;:t(
44 . e Road
Camp Hill, PA 17011
Phone: (717) 737-0100
Fax: (717) 975-0697
Supreme Court ID # 32112
Attorney for Additional Defendants
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VERIFICATION
We, Thomas Blaine and Jean Blaine, verify that the statements made in the foregoing
document are true and correct. I understand that false statements herein are made subject to
the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities.
J~~
THOMAS BLAINE
Date: J1- J-.;8 ~ e)
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JE BLAINE
Date: ~ d-ff/0;3
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EXHIBIT" A"
11/6/03 LETTER TO ATTORNEY WAGNER
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DIANE G. RADCLIFF, ESQUIRE
Attorney at Law
3448 Trindle Road
Camp Hill, Pennsylvania 17011
Phone: (717) 737-0100
Facsimile: (717) 975-069
November 6, 2003
P. Richard Wagner, Esquire
2233 North Front Street
Harrisburg, P A 17110
Re: Natalie Anne Taylor vs. William Taylor v. Thomas and Jean Blaine
Cumberland County Divorce Action No. 01-3601 Civil Term
Dear Rich:
I am in receipt of your letter to the Prothonotary of Cumberland County dated
November 3, 2003 together with the Petition for Rule Absolute enclosed therein. As I
informed you before, my clients, Mr. and Mrs. Blaine, have no opposition to be added as
parties' to this action.
I believe, however, that once they are added as parties', the procedure to be followed
would be the same as if they were added as an additional Defendant. That should require the
filing of a Complaint against them setting forth your claims. That would then give them the
opportunity to file a responsive pleading to that Complaint. Please advise me if you intend
on filing such a Complaint. If you do not, I will proceed with filing a Petition requesting that
the court enter an Order requiring that filing.
I will anticipate a response from you to this letter no later than November 14, 2003.
Very truly yours,
DIANE G. RADCLIFF, ESQUIRE
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cc: Natalie Taylor
Thomas and Jean Blaine
File 28-02D
Transmitted by Mail
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P. Richard Wagner, Esquire
November 6, 2003
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EXHIBIT "B"
11/11/03 LETTER FROM ATTORNEY WAGNER
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LAW OFFICES
MANCKE. WAGNER & SPREHA
JOHN 8. MANCKE
P. RICHARD WAGNER
EDWARD F. SPREHA, JR.
2233 NORTH FRONT STREET
HARRISBURG, PA 17110
PHONE (717) 234-7051
FAX (717) 234-7080
November II, 2003
Diane G. Radcliff, Esquire
3448 Trindle Road
Camp Hill, PA 17011
Re: Taylor v. Taylor v. Blaine
Dear Diane:
Thank you for your letter of November 6,2003. It was my distinct
impression that you had indicated in the past that you felt you could not represent
Mr. and Mrs. Blaine because of the potential conflict.
As such, I will await to hear from counsel for the Blaines concerning any
procedural question, otherwise, I intend to contact the Master and have this
scheduled as soon as reasonably possible.
Your attention is appreciated.
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11/14/03 LETTER TO DIVORCE MASTER
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MANCKE, WAGNER & SPREHA
2.233 NORTH FRONT STREET
JOHN B. MANCKe:
P. RICHARD WAGNER
EDWARD F. SPREHA, JR.
HARRISBURG,
FA
17110
PHONE (7f7) 234-7051
FAX (717) 2347080
November 14, 2003
E. Robert Elicker, Esquire
9 North Hanover Street
Carlisle, P A 17013
Re: Taylor v. Taylor
No: 01-3601
Dear Mr. Elicker:
We have joined the parents of Natalie Taylor in the divorce action as indispensable
parties, which has been confirmed by Court Order of Judge Hess, dated November 10,
2003.
Therefore, I would appreciate if you could schedule a pre-hearing conference at
your immediate convenience.
Your attention is appreciated.
Sincerely,
P. Richard Wagner
PRW/dks
Enclosure
cc: Diane G. Radcliff, Esq.
Mr. Bill Taylor
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EXHIBIT "D"
11/17/03 LETTER TO DIVORCE MASTER
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DIANE G. RADCLIFF, ESQUIRE
Attorney at Law
3448 Trindle Road
Camp Hill, Pennsylvania 17011
Phone: (717) 737-0 I 00
Facsimile: (717) 975-0697
November 17, 2003
E. Robert Elicker, II, Esquire
Cumberland County Divorce Master's Office
9 North Hanover Street
Carlisle, PA 17013
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Re: Natalie A. (Taylor) Acri vs. William Taylor v. Thomas and Jean Blaine
Cumberland County Divorce Action No. 01-3601
Dear Divorce Master Elicker:
I am in receipt of Attorney Wagner's letter to you dated November 14, 2003,
requesting the scheduling of a pre-hearing conference in this case. I oppose that request for
the following reasons:
1. At the request of Defendant, William Taylor, Thomas and Jean Blaine were
joined as additional Defendants in this case by Order dated November 10,
2003 entered by Judge Hess;
2. The Rule 2252 of the Pennsylvania Rules of Civil Procedure requires that a
Complaint be filed against the additional Defendants.
3. Rule 2255 of the Pennsylvania Rules of Civil Procedure requires that the
procedure to be filed, including the pleadings, between the party joining an
additional defendant and the additional defendant shall be the same as though
the party joining the additional defendant were a plaintiff and the additional
defendant were a defendant.
4. As of the date of this letter no complaint or other pleadings have been filed by
the Defendant, William Taylor, against the Additional Defendants.
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E. Robert Elicker, II, Esquire
November 17, 2003
5. Until the Complaint is filed, the additional Defendants will be denied their
right to raise defenses and/or counterclaims against the Defendant or in
response to his alleged cause of action against them. Also, until that complaint
is filed meaningful discovery cannot be conducted by the Blaines, which they
deem to be imperative in this case.
6. I have sent two letters to Attorney Wagner requesting the filing of the
Complaint against the Additional Defendants. In response to my first letter he
indicated he would not consider my request since I was not officially
representing the Blaines. I, therefore, mailed a Praecipe to enter my
appearance on their behalf which was sent to Attorney Wagner on November
17, 2003, and have again requested that he file the Complaint against the
Additional Defendants in this case. If he does not file his Complaint as
required by the Pennsylvania Rules of Civil Procedure, I will file a Petition
seeking the entry of a Rule against the Defendant to file that complaint.
7. Until the pleadings are closed as regards to the Additional Defendant, a pre-
hearing conference would be premature.
Thank you for your consideration of this letter. Should you have any questions or
comments about this situation, or require further information from me, do not hesitate to
contact me.
Very truly yours,
DIANE G. RADCLIFF, ESQUIRE
DGR/dr
cc: P. Richard Wagner, Esquire
Natalie A. Acri
Thomas and Jean Blaine
File 28-02D
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EXHIBIT "E"
11/17/03 LETTER TO ATTORNEY WAGNER
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DIANE G. RADCLIFF, ESQUIRE
Attorney at Law
3448 Trind1e Road
Camp Hill, Pennsylvania 17011
Phone: (717) 737-0100
Facsimile: (717) 975-069
November 17,2003
P. Richard Wagner, Esquire
2233 North Front Street
Harrisburg, P A 17110
Re: Natalie Anne Taylor vs. William Taylor v. Thomas and Jean Blaine
Cumberland County Divorce Action No. 01-3601 Civil Term
Dear Rich:
I am in receipt of your letter dated November 11, 2003. I have been advised that my
client, Natalie Acri, is willing to waive any potential conflict of interest as a result of
representing her parents in this matter as she agrees with the position that is being taken by
them in this case. I have, therefore, prepared and have sent to the Prothonotary a Praecipe
to enter my appearance on their behalf. A copy of those documents are enclosed with this
letter.
Now that I am officially representing the Blaine's, I again raise the issue that it is
necessary for you to file a complaint against the Blaine's as is procedure in adding Additional
Defendants. Please advise me whether or not you intend on doing so. If! do not hear from
you by November 21,2003, I will file a petition to compel the filing in such a complaint.
Very truly yours,
DIANE G. RADCLIFF, ESQUIRE
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P. Richard Wagner, Esquire
November 17,2003
Enclosures:
Praecipe for Entry of Appearance
11117/03 Letter to Prothonotary
cc: Natalie Taylor
Thomas and Jean Blaine
File 28-02D
Transmitted by Mail
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NATALIE ANNE TAYLOR,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Vs.
NO. 01 - 3601 CIVIL
WILLIAM TAYLOR,
Defendant
IN DIVORCE
ORDER OFCOtJRT
AND NOW, this
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decree having been entered previously on March
2004, a divorce
26, 2003, and the economic claims raised in the proceedings
having been resolved in accordance with a marital agreement
dated February 2, 2004, the appointment of the Master is
vacated.
BY THE COURT,
Cc:
~iane G. Radcliff
Attorney for Plaintiff
~. Richard Wagner
Attorney for Defendant
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OF THE PROTHONOTARY
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYL VANIA
NATALIE ANNE TAYLOR,
now by marriage NATALIE ANNE ACRI
Plaintiff
No. 01-3601 CIVIL TERM
v.
CIVIL ACTION - LAW
WILLIAM TAYLOR,
Defendant
IN DIVORCE
v.
THOMAS BLAINE and JEAN BLAINE,
Additional Defendants
MARITAL AGREEMENT
BETWEEN
WILLIAM S. TAYLOR
AND
NATALIE ANNE ACRI
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TABLE OF CONTENTS
INTRODUCTION AND PREAMBLE ............................................................ 1
SECTION I
GENERAL PROVISIONS ............................................................................... 2
1.01 Incorporation of Preamble ................................................... 2
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1.03 Date of Agreement ............................................................... 2
1.04 Distribution Date ................................................................. 2
1.05 Advice Of Counsel.............................................................. 2
1.06 Financial Disclosure ........................................................... 3
1.07 Disclosure and Wavier of Procedural Rights ...................... 3
1.08 Bankruptcy.......................................................................... 4
1.09 Personal Rights .................................................................... 4
1.10 Mutual Release .................................................................... 4
I. I I Income Tax Matters ............................................................. 5
1.12 Preservation of Records ....................................................... 6
1.13 Mutual Cooperation ............................................................. 6
1.14 Waiver or Modification to Be in Writing ............................ 6
I. 15 Agreement Binding upon Heirs ........................................... 6
1.16 No Waiver of Default .......................................................... 6
I. I 7 Breach .................................................................................. 6
1.18 Manner of Giving Notice ..................................................... 7
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1.19 Integration ............................................................................ 7
1.20 Law of Pennsylvania Applicable ......................................... 7
1.21 Headings Not Part of Agreement ......................................... 7
SECTION II
DISTRIBUTION OF PROPERTy................................................................... 9
2.01 Final Equitable Distribution of Property ............................. 9
2.02 After-Acquired Property.....,................................................ 9
2.03 W aiv~r, ofln4,~rit~nce .~.........".......~..,~...................".."......." 9 '__----"-----"-"_'_~~_
2.04 As Is Condition ....................................................................
2.05 Personal Property ................................................................. 9
2.06 Vehicles, Boats and the like ................................................ 10
2.07 Wormleysburg Real Estate .................................................. 10
2.08 Camp Hill Real Estate ......................................................... 11
2.09 Retirement and Pension Plans ............................................. 11
2.10 Bank Accounts, Stock and Life Insurance ........................... 11
2.11 Property Tax Provisions ...................................................... 12
SECTION III
DISTRIBUTION OF DEBTS............................................................................ 13
3.01 Wife's Debts ......................................................................... 13
3.02 Husband's Debts .................................................................. 13
3.03 Marital Debts ....................................................................... 13
3.04 Indemnification .................................................................. 14
11
SECTION IV
COUNSEL FEES, APL AND ALIMONy....................................................... 16
4.01 Waiver of Counsel Fees ....................................................... 16
4.02 Alimony, APL and Spousal Support ................................... 16
SECTION V
CLOSING PROVISIONS AND EXECUTION .............................................. 17
5.01 Counterparts ..................................................................... 17
5.02 Facsimile Signature ........................................................... 17
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5.03 Binding Effect ................................................................... 17
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INTRODUCTION
THfS AGREEMENT mod, (hi, ?-~y or-fI16lo");oo;t. by @d b"w,,"
NATALIE ANNE ACRI, (Wife") of243 North 24'h Street, Camp Hill, A 17011, and WILLIAM
s. TAYLOR, ("Husband ") of 455 South York Street, Mechani~sburg, P A170:l~___________..
WITNESETH:
WHEREAS, the parties hereto are husband and wife, having been married on October
13, 1989 in Harrisburg, Pennsylvania, separated on January 29, 2001 and were divorced on March
26,2003.
WHEREAS, There were three (3) children born of this marriage: Katherine J. Taylor,
born September 14,1990; Eden D. Taylor, born November 18, 1991; and Brooke A. Taylor, born
June 2, 1996, (the "Children").
WHEREAS, diverse and unhappy differences, disputes and difficulties have arisen
between the parties and it is the intention of Husband and Wife to live separate and apart for the rest
of their natural lives, and the parties hereto are desirous of settling fully and finally their respective
financial and property rights and obligations as between each other including, without limitation by
specification: the settling of all matters between them relating to the ownership and equitable
distribution of real and personal property; the settling of all matters between them relating to the
past, present and future support, alimony and/or maintenance of Wife by Husband or of Husband
by Wife; and in general, the settling of any and all claims and possible claims by one against the
other or against their respective estates.
NOW, THEREFORE, in consideration of the premises and mutual promises,
covenants and undertakings hereinafter set forth and for other good and valuable consideration,
receipt of which is hereby acknowledged by each of the parties hereto, Wife and Husband, each
intending to be legally bound hereby, covenant and agree as follows:
END OF INTRODUCTION
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SECTION I
GENERAL PROVISIONS
1.01. INCORPORATION OF PREAMBLE
The recitals set forth in the Preamble of this Agreement are incorporated herein and made a part
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1.02. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE
The terms of this Agreement shall be incorporated into the March 26, 2003 Divorce Decree entered
in the above captioned divorce action docketed to No. 01-3601 Civil Term. This Agreement shall
not merge with the Divorce Decree, but rather, it shall continue to have independent contractual
significance and each party shall maintain their contractual remedies as well as Court remedies as
the result of the aforesaid incorporation or as otherwise provided by law or statute. Unless
otherwise specifically provided herein, this Agreement shall continue in full force and effect after
such time as a final Decree in Divorce may be entered with respect to the parties.
1.03. DATE OF AGREEMENT
The "date of this Agreement" shall be defined as the date of execution by the party last executing
this Agreement.
1.04. DISTRIBUTION DATE
The transfer of property, funds and/or documents provided for herein shall only take place on the
"distribution date" which shall be defined as the date of execution of this Agreement unless
otherwise specified herein.
1.05. ADVICE OF COUNSEL
The provisions of this Agreement and their legal effect have been fully explained to the parties by
their respective counsel, P. Richard Wagner, Esquire, for Husband, and Diane G. Radcliff, Esquire,
for Wife. The parties acknowledge that they have received independent legal advice from counsel
of their selection and that they fully understand the facts and have been fully informed as to their
legal rights and obligations. They acknowledge and accept that this Agreement is, under the
circumstances, fair and equitable and that it is being entered into freely and voluntarily after having
received such advice and with such knowledge, and that execution of this Agreement is not the
result of any duress or undue influence and that it is not the result of any collusion or improper or
illegal agreement or agreements.
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1.06. FINANCIAL DISCLOSURE
The parties confirm that each has relied on the substantial accuracy of the financial disclosure ofthe
other as an inducement to the execution ofthis Agreement, and each party acknowledges that there
has been a full and fair disclosure of the parties' marital assets and debts and the parties' respective
incomes, which has been provided to each party.
1.07. DISCLOSURE AND WAIVER OF PROCEDURAL RIGHTS
,. .~.~RaGh.party~un€l~r'8-tan4s-that.he-0filhe-.ha&.the-1"-ight:--EH,t'Oobtain.fT0m4'he-~therparty-a.complete.'.
inventory or list of all of the property that either or both parties own at this time or owned as of the
date of separation; (2) to have all such property valued by means of appraisals or otherwise; (3) to
compulsory discovery to assist in the discovery and verification of facts relevant to their respective
rights and obligations, including the right to question the other party under oath; and (4) to have a
Court hold hearings and make decisions on the matters covered by this Agreement, which Court
decision concerning the parties' respective rights and obligations might be different from the
provisions of this Agreement.
Each party hereby acknowledges that this Agreement is fair and equitable, that it adequately
provides for his or her needs and is in his or her best interests, and that the Agreement is not the
result of any fraud, duress, or undue influence exercised by either party upon the other or by any
other person or persons upon either party.
Given said understanding and acknowledgment, both parties hereby waive the following procedural
rights:
A. Inventory: The right to obtain an inventory of all marital and separate property as
defined by the Pennsylvania Divorce Code.
B. Income and Expense Statement: The right to obtain an income and expense
statement of the other party as provided by the Pennsylvania Divorce Code, except
in instances where such an income and expense statement is hereafter required to be
filed in any child support action or any other proceedings pursuant to an order of
court.
c. Discovery: The right to have any discovery as may be permitted by the Rules of
Civil Procedure, except discovery arising out of a breach of this Agreement, out of
any child support action, or out of any other proceedings in which discovery is
specifically ordered by the court.
D. Determination of Marital and Non-Marital Property: The right to have the Court
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determine which property is marital and which is non-marital, and equitably distribute
between the parties that property which the Court determines to be marital.
E. Other Rights and Remedies: The right to have the Court decide any other rights,
remedies, privileges, or obligations covered by this Agreement, including, but not
limited to, possible claims for divorce, spousal support, alimony, alimony pendente
lite (temporary alimony), counsel fees, costs and expenses.
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1.08. BANKRUPTCY
The parties hereby agree that the provisions of this Agreement shall not be dischargeable in
bankruptcy and expressly agree to reaffirm any and all obligations contained herein. In the event
a party files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed
hereunder, the other party shall have the right to declare this Agreement to be null and void and to
terminate this Agreement in which event the division ofthe parties' marital assets and all other rights
determined by this Agreement shall be subj ect to Court determination the same as if this Agreement
had never been executed by the parties.
1.09. PERSONAL RIGHTS
Husband and Wife may and shall, at all times hereafter, live separate and apart. They shall be free
from any control, restraint, interference or authority, direct or indirect, by the other in all respects
as fully as if they were unmarried. They may reside at such place or places as they may select. Each
may, for his or her separate use or benefit, conduct, carry on and engage in any business, occupation,
profession or employment which to him or her may seem advisable. Husband and Wife shall not
molest, harass, disturb or malign each other or the respective families of each other nor compel or
attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with him
or her.
1.10. MUTUAL RELEASES
Except as otherwise expressly provided in this Agreement, Husband and Wife each do hereby
mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for
all time to come, and for all purposes whatsoever, of and from the following:
A. Claims Against Property or Estate: Any and all right, title, interest and/or claims
in or against the other party, the property (including income and gain from property
hereafter accruing) of the other or against the estate of such other, of whatever nature
and wheresoever situate, which he or she now has or at any time hereafter may have
against such other party, the estate of such other party or the property of the other
party or any part thereof, whether arising out of any former acts, contracts,
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engagements or liabilities of such other.
B. Dower. Curtesy. Widows Rights: Any and all rights and claims of dower or curtesy,
or claims in the nature of dower or curtesy or widow's or widower's rights, family
exemption or similar allowance, or under the intestate laws, or the right to take against
the spouse's will;
C.
IJfe Ti!lle<:onveyances :Ihe [igl).tJQ!r~at,a,)if(,llime(;on,:,eYi!!lQ,eJ;JY. th(,l(jl!Wra,s
testamentary, or all other rights of a surviving spouse to participate in a deceased
spouse's estate, whether arising under the laws of (I) the Commonwealth of
Pennsylvania, (ii) State, Commonwealth or Territory ofthe United States, or (iii) any
other country;
D. Marital Rights: Any rights which either party may have or at any time hereafter have
for past, present or future support or maintenance, alimony, alimony pendente lite,
counsel fees, equitable distribution, costs or expenses, whether arising as a result of
the marital relation or otherwise.
E. Breach Excention: The foregoing shall not apply to all rights and agreements and
obligations of whatsoever nature arising or which may arise under this Agreement or
for the breach of any provision thereof. It is the intention of Husband and Wife to
give to each other by the execution of this Agreement a full, complete and general
release with respect to any and all property of any kind or nature, real, personal or
mixed, which the other now owns or may hereafter acquire, except and only except,
all rights and agreements and obligations of whatsoever nature arising or which may
arise under this Agreement or for the breach of any provisions thereof.
1.11. INCOME TAX MATTERS
With respect to income tax matters regarding the parties the following shall apply:
A. Prior Returns: The parties have heretofore filed joint federal and state returns. Both
parties agree that in the event any deficiency in federal, state or local income tax is
proposed, or any assessment of any such tax is made against either of them, each will
indemnify and hold harmless the other from and against any loss or liability for any
such tax deficiency or assessment therewith. Such tax, interest, penalty or expense
shall be paid solely and entirely by the individual who is finally determined to be the
cause of the misrepresentations or failure to disclose the nature and extent of his or
her separate income on the aforesaid joint returns.
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B. Current Returns: The parties shall file individual tax returns for the current tax year
and for every tax year hereafter.
1.12. PRESERVATION OF RECORDS
Each party will keep and preserve for a period of four (4) years from the date of their divorce all
financial records relating to the marital estate, and each party will allow the other party access to
those records as may be reasonably necessary from time to time.
1.13. MUTUAL COOPERATION
Each party shall, at any time and from time to time hereafter, and within at least twenty (20) days
after demand therefor, take any and all steps and execute, acknowledge and deliver to the other
party, any and all further instruments and/or documents that the other party may reasonably require
for the purpose of giving full force and effect to the provisions of this Agreement.
1.14. WAIVER OR MODIFICATION TO BE IN WRITING
No modification or waiver of any ofthe terms hereof shall be valid unless in writing and signed by
both parties.
1.15. AGREEMENT BJlNDING ON HEIRS
This Agreement shall be binding and shall inure to the benefit of the parties hereto and their
respective heirs, executors, administrators, successors and assigns.
1.16. NO WAIVER OF DEFAULT
This Agreement shall remain in full force and effect unless and until terminated under and pursuant
to the terms of this Agreement. The failure of either party to insist upon strict performance of any
ofthe provisions ofthis Agreement shall in no way affect the right of such party hereafter to enforce
the same in the future, nor shall it be construed as a waiver of strict performance of any other
obligations herein, nor shall it be construed as a waiver of any subsequent default of the same or
similar nature.
1.17. BREACH
If for any reason either Husband or Wife fails to perform his or her obligations owed to or for the
benefit of the other party and/or otherwise breaches the terms of this Agreement, then the other party
shall have the following rights and remedies, all of which shall be deemed to be cumulative and not
in the alternative, unless said cumulative effect would have an inconsistent result or would result
in a windfall of the other party:
A. Specific Performance: The right to specific performance of the terms of this
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Agreement, in which event the non-breaching party shall be reimbursed for all
reasonable attorney's fees and costs incurred as the result of said breach and in
bringing the action for specific performance.
B. Damages: The right to damages arising out of breach ofthe terms of this Agreement,
which damages shall include reimbursement of all reasonable attorney's fees and costs
incurred as the result of the breach and in bringing the damage action.
C. Divorce Code Remedies: The right to all remedies set forth in Section 3502(e) of
the Pennsylvania Divorce Code, 23 P A. C.S.A. 3502( e), and any additional rights and
remedies that may hereafter be enacted by virtue of the amendment of said statute or
replacement thereof by any other similar laws.
D. Other Remedies: Any other remedies provided for in law or in equity.
E. Considerations for Reasonable Attorneys Fees: Any award of "reasonable
attorneys fees" as used in this paragraph shall be based on consideration of (1) the
hourly rate charged; (2) the services rendered; and (3) the necessity of the services
rendered. Determination of reasonableness shall not take into consideration the
amount or nature of the obligation sought to be enforced or any possibility of
settlement for less than the obligation sought to be enforced by the non-breaching
party.
1.18. MANNER OF GIVING NOTICE
Any notice required by this Agreement shall be sent to a party at the address listed herein, or such
other address as that party may from time to time designate.
1.19. INTEGRATION
This Agreement constitutes the entire understanding of the parties and supersedes any and all prior
agreements and negotiations between them. There are no representations or warranties other than
those expressly set forth herein.
1.20. LAW OF PENNSYL VANIA APPLICABLE
This Agreement shall be construed in accordance with the laws of the Commonwealth of
Pennsylvania.
1.21. HEADINGS NOT PART OF AGREEMENT
Any headings preceding the text of the several paragraphs and subparagraphs hereof, are inserted
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solely for convenience of reference and shall not constitute a part of this Agreement nor shall they
affect its meaning, construction or effect.
END OF SECTION I
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SECTION II
DISTRIBUTION OF PROPERTY
2.01. FINAL EQUITABLE DISTRIBUTION OF PROPERTY
The parties agree that the division of all property and debts set forth in this Agreement is equitable
and in the event an action in divorce has been or is hereafter commenced, both parties waive and
o. ,~~Jdinquish.-the ri ght 1o.iliIDdecaRd.4.istributeJheirassets~ancLdebtsj~)(-JUanner~notconsistentwjth
the terms set forth herein and further waive and relinquish the right to have the Court equitably
divide and distribute their marital assets and debts. It is further the intent, understanding and
agreement of the parties that this Agreement is a full, final, complete and equitable property
division.
2.02. AFTER-ACQUIRED PROPERTY
Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other,
all property, tangible or intangible, real, personal or mixed, acquired by him or her, since January
29, 200 l, the date of the parties' marital separation, with full power in him or her to dispose ofthe
same as fully and effectively, in all respects and for all purposes, as though he or she were
unmarried and each party hereby waives, releases, renounces and forever abandons any right, title,
interest and claim in and to said after acquired property ofthe other party pursuant to the terms of
this Paragraph.
2.03. WAIVER OF INHERITANCE
Each of the parties hereto does specifically waive, release, renounce and forever abandon any right,
title, interest and claim, if any, either party may have in and to any inheritance of any kind ornature
whatsoever previously, or in the future, received by the other party.
2.04. AS IS CONDITION
Except as otherwise specifically herein provided, and with respect to the transfer of any tangible
assets provided for in this Marital Agreement, the parties acknowledge that he or she have had the
opportunity to inspect and view the assets that he or she is to receive as his or her sole and separate
property and he or she is fully aware of the condition of such tangible asset and is receiving those
assets in "as is" physical condition, without warranty or representation by or from the other party.
2.05. PERSONAL PROPERTY
With respect to the tangible personal property ofthe parties including, but without limitation with
specific reference to,jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and
appliances, tools, pictures, books, works of art and other personal property ("the Personal
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Property"), the parties agree as follows:
A. Division: Husband and Wife do hereby acknowledge that they have previously
divided the Personal Property. Hereafter Wife agrees that all ofthe Personal Property
in the possession of Husband shall be the sole and separate property of Husband; and
Husband agrees that all of the Personal Property in the possession of Wife shall be the
sole and separate property of Wife.
B. Waiver: The parties do hereby specifically waive, release, renounce and forever
abandon whatever claims, if any, he or she may have with respect to the Personal
Property which shall become the sole and separate property of the other.
2.06. VEHICLES. BOATS AND THE LIKE
With respect to the vehicles, boats, snowmobiles, motorcycles and the like owned by one or both
of the parties, or the trade in value thereof, The parties acknowledge that there are no Vehicles to
be distributed between them.
2.07. WORMLEYSBURG REAL ESTATE
The parties are the owners ofa fifty percent (50%) interest in certain tract of improved real estate
known and numbered as !O3 North 2nd Street, Wormleysburg, PA, ("the Wormelysburg Real
Estate"), owned jointly with Wife's parents, Thomas and Jean Blaine as the owners ofthe other fifty
percent (50%) interest, and which is encumbered with a mortgage owed to M&T Bank, ("the
W ormelysburg Mortgage"). With respect to the W ormleysburg Real Estate and the W ormleysburg
Mortgage the parties agree as follows:
A. Conveyance: Upon the signing of this Agreement, Husband shall make, execute and
deliver all documents in the usual form conveying, transferring and granting to Wife
all of Husband's right, title and interest in and to the Wormleysburg Real Estate, and
Husband specifically waives, releases, renounces and forever abandons all Husband's
right, title, interest and claim therein.
B. Liens. Encumbrances and Expenses: The said conveyance shall be subject to all
liens and encumbrances including, but not limited to, the lien of the Wormleysburg
Mortgage, real estate taxes and any other municipal liens. The conveyance shall
further be under and subject to any covenants and restrictions of record. Wife shall
hereinafter be solely responsible for the payment of the Mortgage, real estate taxes,
other municipal liens and any and all other expenses associated with the
Wormleysburg Real Estate, whether incurred in the past, present or future, and shall
indemnify, protect and save Husband harmless therefrom.
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2.08. CAMP HILL REAL ESTATE
Wife's parents, Thomas and Jean Blaine are the owners of a certain tract of improved real estate
known and numbered as 63 N. 31" Street, Camp Hill, PA, (the "Camp Hill, Property") which is
encumbered with a mortgage owed to Commerce Bank ("the Camp Hill Mortgage"). With respect
to the Camp Hill Real Estate and the Camp Hill Mortgage the parties agree as follows:
A. Waivcer: Husband specifically waives, releases, renounces and forever abandons all
Husband's right, title, interest and claim in the Camp Hill Real Estate and to the
extent deemed necessary shall make, execute and deliver all documents in the usual
form conveying, transferring and granting to Wife all of Husband's right, title and
interest therein.
B. Liens. Encumbrances and Exnenses: to the extent the parties have any liability for
the expenses for the Camp Hill Real Estate including, but not limited to, the lien of
the Camp Hill Mortgage, real estate taxes and any other municipal liens, Wife shall
hereinafter be solely responsible for the payment thereof, whether incurred in the past,
present or future, and shall indemnify, protect and save Husband harmless therefrom.
2.09. RETIREMENT AND PENSION PLANS
Each ofthe parties does specifically waive, release, renounce and forever abandon all oftheir right,
title, interest or claim, whatever it may be, in any Pension Plan, Retirement Plan, IRA Account,
Profit Sharing Plan, 40 l-K Plan, Keogh Plan, Stock Plan, Tax Deferred Savings Plan, any employee
benefit plan and/or other retirement type plans of the other party, whether acquired through said
party's employment or otherwise, ("the Retirement Plans"). Hereafter the Retirement Plans shall
become the sole and separate property of the party in whose name or through whose employment
said plan or account is held or carried. If either party withdraws any sums from the Retirement
Plans distributed to him or her pursuant to the terms of this Paragraph, that party shall be solely
liable for any and all taxes and penalties resulting from that withdrawal. Pursuant to the foregoing
Husband shall receive and reain as his sole and separate property his SERS Pension, and Wife
waives, releases, renounces and forever abandons all right, title interest and claim therein.
2.10. BANK ACCOUNTS/STOCK/LIFE INSURANCE
The parties acknowledge and agree that they have previously divided to their mutual satisfaction all
of their bank accounts, certificates of deposit, bonds, shares of stock, investment plans and life
insurance cash value, ("the Accounts"). Hereafter Wife agrees that all the Accounts held in the
name of Husband shall become the sole and separate property of Husband; and Husband agrees that
all the Accounts held in the name of Wife shall become the sole and separate property of Wife.
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Each of the parties does specifically waive, release, renounce and forever abandon whatever right,
title, interest or claim, he or she may have in the Accounts that are to become the sole and separate
property of the other pursuant to the terms hereof.
2.11. TAX PROVISIONS
The parties believe and agree that the division of property made to be made pursuant to the terms
of this Agreement is a non-taxable division of property between co-owners rather than a taxable sale
or exchange of such property. Each party promises not to take any position with respect to the
adjusted basis of the property assigned to him or her or with respect to any other issue which is
inconsistent with the terms of this Paragraph on his or her applicable federal or state income tax
returns.
END OF SECTION II
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SECTION III
DISTRIBUTION OF DEBTS
3.01. WIFE'S DEBTS
Wife represents and warrants to Husband that since the parties' marital separation she has not
contracted or incurred any debt or liability for which Husband or his estate might be responsible.
Wife further represents and warrants to Husband that she will not contract or incur any debt or
liability after the execution of this Agreement for which Husband or his estate might be responsible.
Wife shall indemnify and save Husband harmless from any and all claims or demands made against
him by reason of debts or obligations incurred by her.
3.02. HUSBAND'S DEBTS
Husband represents and warrants to Wife that since the parties' marital separation he has not
contracted or incurred any debt or liability for which Wife or her estate might be responsible.
Husband further represents and warrants to Wife that he will not contract or incur any debt or
liability after the execution of this Agreement for which Wife or her estate might be responsible.
Husband shall indemnify and save Wife harmless from any and all claims or demands made against
her by reason of debts or obligations incurred by him.
3.03. MARITAL DEBTS
During the course ofthe marriage, Husband and Wife have incurred certain bills and obligations and
have amassed a variety of debts, ("the Marital Debts"), and it is hereby agreed, without ascertaining
for what purpose and to whose use each of the Marital Debts were incurred, the parties agree as
follows:
A. General Provision: Any debt herein described shall be deemed to include the current
balance owed on the debt. Unless otherwise herein specifically provided, there shall
be no adjustment for the payment of any portion of the Marital Debts that a party may
have made prior to the execution ofthis Marital Agreement, whether or not that debt
is specifically referenced in this Paragraph.
B. Wife's Debts: Wife shall be solely responsible for the following bills and debts:
1. Mortgage: The Wormleysburg Mortgage and the Camp Hill Mortgage as
provided in this Agreement;
2. Real Estate Expenses: Any and all expenses associated with the
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Wormleysburg Real Estate and the Camp Hill Real Estate as provided in this
Agreement;
3. Other Debts: Any and all other debts, liabilities, obligations, loans, credit
card accounts, and the like incurred in Wife's sole name, and not otherwise
provided for herein.
B. Husband's Debts: Husband shall be solely responsible for the following bills and
debts:
1. Taxes from Withdrawal of Retirement Funds: Any and all taxes resulting
from his withdrawal of funds from Husband's Retirement Plans as provided in
this Agreement;
2. Other Debts: Any and all other debts, liabilities, obligations, loans, credit
card accounts, and the like incurred in Husband's sole name, and not otherwise
provided for herein.
C. Indemnification: Each party agrees to hold the other harmless from any and all
liability which may arise from the aforesaid bills which pursuant to the terms herein
are not the responsibility of the other party.
D. Cancellation of Joint Debts: Any joint debt shall be canceled so that neither party
can make any further charges thereunder, and if said charges are made in violation of
this Agreement, then the party incurring said charge shall immediately repay the
same.
E. Non-Disclosed Liability: Any liability not disclosed in this Agreement shall be the
sole responsibility of the party who has incurred or may hereafter incur it, and the
party incurring or having incurred said debt shall pay it as it becomes due and
payable.
F. No Further Joint Debt: From the date ofthis Agreement, each party shall only use
those credit accounts or incur such further obligations for which that party is
individually and solely liable and the parties shall cooperate in closing any remaining
accounts which provide for joint liability.
3.04. INDEMNIFICATION
Any party assuming an obligation pursuant to the terms ofthis Agreement shall indemnifY, protect
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and hold the other party harmless from and against all any and all liability thereunder, including, but
not limited to, any attorney's fees and costs incurred by the other party as the result of defending
against the obligation and/or enforcing the provisions of this indemnification.
END OF SECTION III
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SECTION IV
COUNSEL FEES, APL AND ALIMONY
4.01. WAIVER OF COUNSEL FEES
The parties hereto agree and do hereby waive any right and/or claim each may have, both now and
in the future, against the other for counsel fees, costs and expenses.
4.02. ALIMONY. APL AND SPOUSAL SUPPORT
The parties hereto agree and do hereby waive any right and/or claim they may have, both now and
in the future, against the other for alimony, alimony pendente lite, spousal support and maintenance.
END OF SECTION IV
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SECTION V
CLOSING PROVISIONS AND EXECUTION
5.01. COUNTERPARTS
This Agreement may be executed in counterparts, each of which shall be deemed to be an original,
but all of which shall constitute one and the same agreement.
5.02. FACSIMILE SIGNATURE
Each party agrees to accept and be bound by facsimile signatures hereto.
5.03. BINDING EFFECT
BY SIGNING THIS AGREEMENT, EACH PARTY ACKNOWLEDGES HAVING READ AND
UNDERSTOOD THE ENTIRE AGREEMENT, AND EACHP ARTY ACKNOWLEDGES THAT
THE PROVISIONS OF THIS AGREEMENT SHALL BE AS BINDING UPON THE PARTIES
AS IF THEY WERE ORDERED BY THE COURT AFTER A FULL HEARING.
IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have
signed sealed and acknowledged this Agreement the day and year below written, which Agreement
has been executed in various counterparts, each of which shall constitute an original.
WITNESS:
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WILLIAM S. TAYLOR
Date: "2../2/" +
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NATALIE ANNE ACRI
Date: ?- ( 2-/ () y_
(SEAL)
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF C\..J.. YY\ ~A. .20L AI c1
On this the~d-day of kl:)('~, 200~before me the undersigned officer,
personally appeared, WILLIAM S. TAYLOR, lfuown to 7:t~ (or satisfactorily proven) to be the
person whose name is subscribed to the within Agreement, and acknowledged that he executed the
same for the purposes therein contained.
SS.
IN WITNESS WHEREOF, I hereunto set my hand and notarial seal.
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COMMONWEALTH OF PENNSYLVANIA
Notarial Seal .
, G Raddiff Notary PublIc
O,ane, , dC nty
H"116oro cumberian ou
~a~~Si~ Expires Jan. 11,2008 ,
Y . r Of Nntanes
b Ppnnsylvan18 ASSOGl'a Inn -- -
Mem ec -' .
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IN WITNESS WHEREOF, I have hereunto set my hand ~ial seal.
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COMMONWEALTH OF PENNSYLVANIA
Notarial Seal .
, G Raddifl Notary Public
Diane. ' d county
H1160r0 cumberian
:~~iSS;m; ExpireS Jan. 11.2008 ,
bY P8f\!l5ylvania ~!';socialion Of "-Iotanes
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
NATALIE ANNE TAYLOR,
now by marriage NATALIE ANNE ACRl
Plaintiff
No. 01-3601 CIVIL TERM
v.
CIVIL ACTION - LAW
WILLIAM TAYLOR,
Defendant
IN DIVORCE
v.
THOMAS BLAINE and JEAN BLAINE,
Additional Defendants
PRAECIPE TO WITHDRAW CLAIMS
TO THE PROTHONOTARY OF THE SAID COURT:
Please withdrawal all claims heretofore filed by a party against the Plaintiff, Defendant
and/or additional Defendants. All such claims have been resolved by the Marital Agreement
dated February 2, 2004 filed of record in this case.
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Respectfully submitted,
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DCLIFF, ESQUIRE (
3 8 Trindle ad
Camp Hill, PA 17011
Attorn for Plaintiff and Additional Defendants
ARD WAGNER, ESQUIRE
2233 North Front Street
Harrisburg, P A 17110
Attorney for Defendant
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