HomeMy WebLinkAbout99-00305
MARITAL SICI'TLEMENT AGI{lmME
TillS AlJlUHvl HNT, llIadc Ihis_~)(:L~__~ day 0"-') \JI\QOO I, by and bctwccn
Raymond Timponc, hcrcinallcr rcferrcd 10 as "llusband", and Knrcn Tilllponc, hcrcinancr referred
to us "Wilo",
WITNESSETlI:
WIIHIUiAS, Ilusbaud and Wifc wcrc Inwltilly marricd on Oetobcr 14, 1970; nnd
WI IEREAS, certain diflcrcnces arosc bClwl'cn thc pnrtics us u rcsull of which thcy
scparatcd on .Innnury I, 1999, and uow live scpurate and npurl Ii'olll onc anothcr, and arc dcsil'Ous
ofscttling fully 1II1llfinally their respective linuneial and propcrty rights und obligations as betwecn
cadI other, including, withoutlilllitati()u by specification: thc se"t,ng of all nHltlers betwccuthcm
relating to lhe past, preseut and future support and/or nHlinteuanec 01' Wik by Husbaud or of
lIusband by Wire; and iu gcneral thc settling ofuny and all elllillls and possible claims by one
ngainst the other or against their respective estatcs Illr equitable distribution of alllllarital property;
and a resolution of alllllutllal respollsibilities und rights groll'ing out of the marriage relationship
uny provisions of prior ugrccment bdwecnthemto lhe eontrury notwithstanding; nnd
WIlE/WAS, the purties hereto, uner being properly udvised by their respeetivc
counsel, Ilusbund, by his allorney, Hdwurd.l, Weintraub, Hsquire, und Wile, by her altolllcy, SHllluel
Milkcs, Hsquire, have COIllC to the lilllowing agrecnwnl.
NOW TIIEREFOIW, in consideration or the abovc rccitals and the following
covenants uud prolllis('s IlIl1tllully made and mutually to Ill' kept, thc partics hereloforc, intcuding
to bc Icgully bouud und 10 Icgally bind their hcirs, succcssors uud assigns thercby, covcnant, promise
uud agree liS fillloll's:
I, SE/'i/IIA nON:
It shllll bc lawlili Illr cach purty ut alltilllcs Ilercaner to livc sepuf'ate and IIpurt
fro III the othcr us such plueo or places us he or shc may fl'llllltime to tilllC choose or dCClllli1.
2. IN11iIlFFlmNC/:':
Huch pllrly shall be Ii'ee from interf('rcuce, allthority lIlId cOlltact hy the olhn,
liS hilly as if' he 01' sill' were single lIud lIllIllllITied, except as Illay be neccssary to carry olltlhe
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provisions ol'this Agrccment. Ncither parly shall huruss Ihc other nor cndeavor to molest the other.
nor \:ompel the olhcr 10 eohubit with the other nor in any way malign Ihe other, nor in IIny wny
interfere with Ihe peaceful \'xistenc\), sepllrllte and apnrlli'omlhe other In allrespeets as if he or she
were single Ilnd lIIulllllTied,
J. WIFEW mllJTS:
Other than the debts iudiented in Paragraph 5 below Wife represents nnd
wnrranls to Ilushllnd that sillce Janullry I, 1999, she has not, IInd in the future, she will not, eontrnet
or Incur IIIlY debt or lillbility Illr which Husband or hi.q cstate might he responsible and shllll
indemni(y IInd save lIusballd harmless frollllluy and ull eluims 01' demunds made against him by
reason of debts 01' obi igations i nClll'red by her.
4. HUSBAND'S f)EH1:~':
Other thun the dehts indicated in Puragraph 5 below, Husband represents und
warl'llnts to Wife that since Junuary I, 1999, he has not, und in the future he will not, eonlraet or
inelll' llllY debt or liability for which Wifc 01' her estate might be responsible and shall indelllnify and
save Wife harmless f1'om any and all claims 01' demllnds made ugainst hcr by reason of debts 01'
obligntions ineuned by him,
5. OUTSTANDING' MARITAL DElJTS:
Husband and Wife acknowledge and ugree thut they hllve no outstanding
,
mllritnl debts and obligatiolls of the Husband and Wife incurred prior to the signing of this
agreement, except as follows:
DESCRIPJlON
A, Flcel Mortgage
U, Dallphill Credit Lille
C Lillcoln Cllr Loan
\), Ilolldn CUI' Loun
E. JC Penny
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AMOUNT
PERSON(S) NOW
IlliSl'.oNSIIlLll
$125,955
H+W
$22,234
H+W
$6,032
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$1, 155
$90
W
W
$428
W
2
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April 5,200 I
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The pUl1ies ugree that Ihey shull he jointly responsihle Ibr t1w puyment of debls A und
B us hereina!\er provldcd, Husband shull he responsible for puying dllht C uud Wife shull he
I'esponslble Ibr puyitlg debts D, E und F, Wife acknowledges thnl she incurred $11,262 of debt B
al\cr the parties sepurnled, Ibr which Husband shull receive anlllljuslment as hercinuller provided,
Euch purty agrees to pay Ihe outslanding joint debts us allocated and further agrees
to indemnify lAnd save hunnless the olher Ibm any liubilily Ill!' snch debts or obligutions,
In the event that either purty contrueted or Incul'I'ed any debts, other thun those
speclfieully identified herein since Jannury I, 1999, the purty who ineul'I'ed the debt shull be
responsible for ils payment regurdless oflhe name In which the uceountmuy have bcon chnrged nnd
agrees 10 indemnify nnd hold hurmless the other for any liubility Ibr such debts,
6. MUTUA.L RELEA.SE:
Except ns provided In this Agreement, each party wui ves his or her right to
alimony and any further distribution of property becuuse both ngree that this Agreement provides
for an equituble distribution of their mUrltnl property in aceOl'dunce with the Divorce Codc of 1980.
Subjcct to the provisions of Ihis agreemenl, each party has released und discharged, and by this
Agreement docs lor himself or herself, and his or her heirs, legal rcpresentatives, executors,
adminisll'iltors and assigns, release und discharge the other of und Ihull all cuuses ofuction, claims,
rights or demands whutsoever In law Ill' equity, which either of the parties ever had or now has
against lhe other, except uny 01' ull cuuse or cnuses of action for divorce and exeeplln any or all
~auses of uetion for breach of any provisions of this Agreement. EUl'h party also waives his 01' her
right 10 request marilal counseling plll'sullnl to 23 Pu,C,S,A, Section 3302,
7. EQUI1/1/JLE L>JSTRllJUTION:
The Jlurties intend for this Agreement 10 refleel till' equitable distribution
scheme in the Preliminary Equitable Distribution Annlysis of Febl'llllry 21, 2001 ultached herelo as
Exhibil "A", plll'suanl to which Wife shall receive 60% of their nelmaritnl estate, less credits of
$13,499 due to lIusband,
A. Wife clll'renlly occupies the parlies fon11er marital residence at 3822
Claverlon Road, Mecha11lesbllrg, Cumberland County, Pennsylvllnia, which WllS listed for sale for
$210,000 is under Agreemellt of sale, with closing anticipated on 01' about March 30, 2001. At
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April 5, 2001
c10Hiug the lirHt lIIortgage 10 Fleet of approximately $125,\155 and Ihe parlieH Dauphin eredilline
ofaPPl'Ox.imulely $22,234 securcd by II sccond 1II000Igllge shllll be slllisfled, liS willull olher liens und
encumbrances of rceord, Aller pllying all expenses of sale, Ihe net proceeds shall bc divided 60%
to Wife alld 40% 10 Hllsbllnd, Any tux 01' insurllnell eserow shalllllso be dislribulf.ld 60% to Wife
und 40% to Husbund, Wife shull be responsible for alllllorlgllge puymellts, tuxes, insnl'llnee und
routine Oluintenunee from (dnte of her re-oeeupuncy) unlil closing,
IJ. COl/tel/ts of rile Mal'/tlll Resldel/ce IIl/d Otllel' R/!.vldel/ce,I' of Wife:
As of the date of the execution of lhis Agreemenl, Husbund shall set
over, transfer und ussign to Wife ull of hin righi, title, eluimund interest inund to the furniture,
furnishings, lixlures, goods, appliunces, equipment and pcrsonul items within the fOrlller mnrilul
residence uud <lny other residence Illuintuined by Wife,
C. COI//ellis ofHlIshl/lul',I' ResltJel/ce:
As of the dute of the execution of this Agreelllent, Wife shall set over.
tmnsfer and ussign to I-Illsbllnd all of her right, tille, c1uim uud interest in nnd to the furnilure,
furnishings, fixtul'Cs, goods; upplianccs, equipment and personal items within Husband's residence.
n. Motor Vell/cle,I':
With respeet 10 the motor vehicles owned by one 01' both of the parlies,
they agree us follows:
(I) Husband :;hallreluin the 1993 Lincoln,
(2) Wife slmllrelain the 1996 Honda,
(3) All autonlObile litles and insul'Unee policies will be corrected
to refleetlhe ownership of each vehicle,
E. JIII/h'/d/1II1 RI>t/l'emeM ricco/tilts, I'el/s/ol/.I' AIIII Employme/lt
Bel/eftt.v:
Husband is entitled to a pension of undetermined value fhllll SI'X
Corporation, the successor eOlllpuny of General Signal, by whom J lusband wus employed during
the mllrriage, Husband may also have II pension 1'1'0111 previous employmcnt by Marathon
Corporation. Ilusbund shull exercise dne diligence 10 obtain dala Oil these rctirel11cntllssets IInd to
supply it to coullsel for Wife, Should Wife und her counsel lit her cost prcpare IInd oblain fI
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Qualified Domestic Relatious Order. Husband will cooperate in dividing Ihesl) retirement assets,
40% tu Husband IInll 60% to Wife. Ifno Qualified Dumestic Relllllous Order Is entered, through
no faull of Husband, he shall retain 100% of these retirementas3ets,
The parties have uulRA IIccount inllusbllnd's nallle with Morgan Stanley
Dean Witter with II fluctuating balance us of March 16.200101'$98,070, copy ofstlltement ulIaehed
liS Exhibit "/3," Wife shall supply Husband with idenlifying informalion 01111 new sepllrate IRA
account to be (lpened by her and upon execution of this agreement Husband shall promptly cause
to be rolled over to Wife's IRA sixty-two percent (62%) of his Morgan Stanley IRA. being $61,170
oflhe $98,070 present IRA. aOer deducting creditH due HUHband totaliug $18,075,all as more fully
described in the Preliminary Equitable Distribution Analysis of April 5, 200 I, attached hereto liS
Exhibil "A",
F, .Iolllt Balik alld Charge AccOIlllt.11
All joint bank and charge accounts, credil card acconnts and any olher
joint accounls shall be terminaled and each party shall lake those sleps necessary to have the other
removed as a responsible party from any such account. Bolh parties shall retain all of the curreut
balauces iu their current savjugs and chccking accounts,
G. Property to W(lel
The parties agree Ihat Wife shallllwn, posses, and enjoy Ii'ee Ii'omauy
claims of Husband, the properly awarded to her by the terms of Ihis Agreemcnt, Husband hereby
quitclaims, assigns and conveys 10 Wife all such property togelher with any ins\lranee policies
covering (hat property, ;,nd any e~crow accounts relaling to that properly, This Agreemenl shall
constitute a sumclent bill of sale to evidence flw transfer of nn)' nnl! all righls in SUi'll properly from
Ilusbnnd to Wife,
H. 1'/'11/11'/'0' to Ill/shlll/d:
The parties agree tllllt I lusband shall own, possess, find ClUoy Ii'ee Ihlln
any claims of Wife, the properly awarded 10 her by Ihe (erms of this Agreement. Wife hereby
quitclaims, nssigns nnd conveys 10 Husband al/ such properly logether wilh nny insumnee policies
covering thnt propcrly, and any escrow accounts rolaling to (hat property, This Agreement shull
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conslitute u silflicient hill of'~alc 10 evid'"nce the tmnsf'cr of'uny und all righls in slwh propelly from
Wife 10 Ilushand.
Specificully, Ilusbund shull reccive the Januury 1,1999 Money Murke! Account
hulance of upproxil11ulely $2,500, the cash surrender vulues of $6,161 and $6,569 respeelively of his
Norlhwest Muluallusul'illlce policies ulllllhe $12,400 l11urilal portion of his relocation bOllus. Wife
ucknowledges receiving frol11llushund lhc sum 01'$2,000 in lieu of allY interesl in Husband's stock
options, all of' which he shall relainus his separale properly,
I. lIf/seellllllCol/s 1'/,(I/ICI'(I':
All properly not specil1eully addressed herein shall herealler be owned
by lhe party to whol11 the property is tilled, und ifulllitled, the purly in possession, This Agreement
shull constilute u surficielll bill of' sule 10 evidence the trunsfer of any and all rights ill such property
fl'Om each to the olher.
,J. Tax Liability:
The parties believe and ugree lhul the division of property heretofore
made by this Agreemenl is anon-luxuhle division of properly belween co.owners rather thlln a
laxuble sale or exchange of such properly, Buch purly promises nolto luke any position with respect
to the adjusted busis of the property assigned I him or her with respeelto any other issue which is
ineonsistenl wilh the position set forlh in the preceding senlence on his or her Federal or Slate
incol11e tax returns,
8. UI'Ii INSURANCE:
Euch parly shall eonlinue 10 own uny life insurance policies currently in
effeel, without restriction ns to lhe designation of' heneficiuries, Within thirty (30) duys IIller
execution of Ihis Agreement, Ilushand, who is 53, shall use his besl effort to oblain at rcasonubly
affordable premiums and 10 lhcreaner lIIainlain lerlll life insurunce ol'initially $500,000 decreasing
in equul incrcnwnls III $250,000 when Hnsband is 65 nnd mainlained nl $250,000 thercaftcr,
irrcvocahly designating Wife us his beneliciary und alleasl unnuully upon request supplying Wife
wilh el'idclK'e Ihallhis eovernge is in efree\.
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April 5, 200 I
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9.
ALIMONY:
Ilusbuud shull puy to Wife indellnltc modilluble ulimony In the u!l1uunt of
$3,150 pcr month con!l1lCneing on the Ilrst day of the first !I1onth following eX(iclltion of this
Agreement pnrsllunt to u Stiplllution for Agrecd Ordcr of Alimony Pendcntc Lite and Alimony, to
be prepared by counsel for Wife, rcviewed by counsel to Ilusband und prolllptly filed through the
Office of /)omestit; Relutions ofCulllberland County, As additional Alimony, Wife shall receive
35%. of any net bonuses 01' income frolll prollt sharing paid by his employer to Husband, withintcn
(10) duys of reccipt of each bonus, with dOCllmeutalion to Wife of cach gross bonus, Alimony shull
terminate in the cvent of the Wifc's death, eohubitalion 01' relllarriage, For tax purposf~s, allali!l1ony
paymeuts are intended to be deductible by Ilusband and includible us ineollle to (he Wife,
Wife acknowledg\'s and agrees that the provisions of this Agreelllent
providing for the waiver of alimony to her by her Ilusbund me fair, adequate, and satisfactory to her
and are based upon her actual need, her Husband's ability to pay, the duration of the parties'
marriage and other relevant filetors whkh have been taken into consideration by the parties,
Although the approval of this Agreement hy a eO\ll't of colllpetent jurisdiction in connection with
this aelion in divorce 01' annullllent Illed by Husband or Wife shall be deemed un order of the court
and may be enforced as provided in 12 Pa,C,S,A. Section 370 lIas alllended, this Agreement, insofar
as it pcrtains only to support for Wife and the payment of alimony following the entry of a final
Doeree in Divorce between the parties, may not be modilled, suspended, terminated, or reinstated
at the instance of request of the Wife or Ilusband, 01' subject to further order of any court upon
changed circumstances of the Wife 01' Husband of a substantial or continuing nat\ll'e, 01' for any
reason claimed by Wifc whatsoever, Upon that condition, Wifc hereby acccpts the provisions of
this Agreclllcnl in licu of and in full and linal settlement and satislhction of all claims and demands
that she may now or hereaftcr have againstllusband or her support and maintenance of herself and
Illr alimony, and Ilusband and Wife fitrthcr voluntarily and i',lelligcntly waivcs and relinquishes any
right to scek a 1ll0diliL'ntion, suspension, termination, reinstitution, or other eomt ol'\lcr with respect
to th~ terms of this Agrccnll'nt pertaining to the payment of support to Wife 01' the paymcnt of
alimony by Husband.
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J lusbnnd lIeknowledges and agrees thilt the provisions of this Agreement
IJl'Oviding Ibr equitable distribulion of lIIurital pl'Op\~rly arc Iilir, adequnle nnd sntisllletory 10 hlmnnd
me aeeepled by him in lieu of and in full and finnl selllementnnd sntisf\letion of lIny claims or
demllnds (hut he may now have or hereaner have against the Wife 1\>1' support, mnintcnllnee or
nlimony, Ilusbnnd flll'lher volunlarily nnd intelligently waives and relinquishes lIny righl to seck
from the Wife lIny pllymenl for support or alimony,
10. IIEAUlIINSUIlANCE:
Wife acknowledges that sill' has or will obtain her own health insuraaee via
her employment or shall otherwise obtain ii, with no obligalion by HlI'lband to pay for or provide
her hellllh insurnnce and no obligation to pay Wife's uninsured medical expenses,
II. ALlMONI' P/IN/JH.NTE Ll1'Ii', COUNSEL FEES AN EXI'ENSHS:
Husband and Wife lIeknmvledge and agr\'e that lhe provisions of this
Agreement pl'Oviding for lhe equitable dislribulion of marilal pl'Operty of the parlies are fair,
adequate und satisfaclory 10 them, Both plll'lies agree (0 accept lhe provisions set forth in this
Agreemcnt in lieu ofund in full and final seulement and slltisfllction ofull claims and demands (hat
eithl'l' may now or herellner have against the other for alimony pendente lile, counsel fees or
expenses or any other provision IClI' lheir support and maintenancc bcfore, dlll'ing and aner the
commencemenl of lhe proceedings for divorce or annulment bel ween the purties,
12. INCOME TAX IWl'URNS:
The parties have herelofore filed joinl federal and state (ux returns, Bolh
parties agrce lhal in Ihe event any deficiency in federal, slate or local incomc tax is proJlosed, or any
asscssmenl of any such tax is made ugainsl ellhcr of them, each will indcmnify and hold hlll'lnless
thc oth~r 1'1'0111 and againslany loss 01' liubility for any such lax deficiency 01' assessment and any
loss 01' liubilily f\lI' any such lax dcficicncy or assessmenland uny intercst, penally and expense
incurl'ed in l'OlllllJction thercwith, Such lax, illtCl'\1st, penalty or expcnse shall be paid solely and
enlirely by the individual whll is finally dctcl'mincd to be responsihlc f\lI' lhe actions,
misrcpresentations or Iililul'cs III disclose separale income resulling in lax liability, The parties filed
jointly in 11)<)<) IInd scpuratcly 2000 IInd lhereaner. Each shall be enlitled to claim the mortgage
inleresl deduclion l\lI' paymcnls lIetually mudI' by each sincc they separalcd on January I, 11)99,
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13,
W.1/VWl" OF C/.AIMS AGAINST HS1/l 1'Ji'S:
Exccpt liS hcrcin othcmisc pl'Ovidcd euch purty lI1uy dispose of his 01' h~1'
property inllny WilY, IInd ench purly hel'ehy wuivcs IInd rdinquishes IIny IInd 1111 rlghls Iw or she mllY
now hnve or hercllf'ler ucquil'e, uudel' Ihe preseut 01' fUlur~ lilli's of IIny jurisdiction, 10 shure in the
property or Ihe eslule oflhe other us ul'esull ofthc murilal rclutionship, including withoutlimllution,
dower, elll'tse)', stuhtlory allowance, widow's ullowancc, righllo take inlestlley, rigl1tlo lake uguinsl
thc will ofthe olher, and righlto act liS administralor 01' executor of the OtlWI 's eslute, Eueh will,
utlhe request ofthe other, execule, ucknowledge und deliver IIny IInd ull instruments which lI1uy be
necessary or advi.,ahle to curry illto effect this mutual waiver IInd relinquishment of 1111 such
interests, rights und claims IInd both pUl'lies willl'cvoke prior wills 01' teslameulury dueuments,
14. AORHEMENT NOTI'RE/)JCA1E1J ON /J/VORCli':
II is specifically understood und ngreed hy IInd between the purties hereto und
eueh uf the said pllrties docs hereby wurrant und represenl to Ihe olher, thut lhe exeeulion und
dellvl11'Y of this Agreemeut is not predicuted upon nul' Illude subjeetto uny ugreelllent for institulion,
prosecution, defense, or for the non-prosecution or non-defense ofllny aelion for divorce; provided,
however, that nothing conillined in this Agreemcnt shall prevcnl or preclude eilher of Ihe pllrties
hel'elo from commencing, instituting or prosecuting un uclion or uclions for divorce, eilhel' ubsolule
or otherwise, upon just, Icglllund propCI' grounds; nor to prevent either purty from dcfemling uny
such aclion which hus bl1en, 1lI1I)' or shull be instituted b)' Ihe other purly, or H'olllll1uking uny just
01' pl'Opel' defense thereto, II is wllrl'llnted, covenllnted IInd represented by Husbund IInd Wife, ellch
to Ihe other, thul Ihis Agreelllent is lawlill und enforeeuble und Ihis wurl'anty, covcnunt and
representlllion is Illude for the specific purpose of indudng Husband und Wife (0 eXl1cule Ihis
Agreement. Husband und Wife each knowingly and understandingly hel'chy wuives uny und ull
possible e1aillls that this agreemcnt is, for Hny reason illegal 01' Ibl' un)' I'cuson whatsoevcl',
uncnforccuble in whole 01' in part. } hlshand und WiI(~ each do hereby wurrant, covenanl and ngrce
thnt, in any Jlossihle cvenl, he and she arc and shnll forcver be eSlopped fi'olllusscrting uny illegality
or lInenf'oreeahility as to all or uny part of this Agrcelllent.
IS. SU/lSlJ'{!lIl:'Nl'lJ/VORCE:
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April 5, 200 I
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Wi('e lit Iwr (:osl by her counsel hils filed IInlletiolllbr divorce under Section
3301(e) o('the Divorce (;(1dc,
Silllnllllneously with lhe exeeulion 0(' this Agreement, both purties will
execute Affidavits o('Consentllnd Wuiv('rs o('Notiee 10 enable counsel for Wi('e to proceed with u
no-('ault divorce liS soon as possible, providing counsel 1(11' Ilusband with u duplieale decree,
Thc parlies furlher agree thai each of them shall be responsible for their own
allol'l1ey's ('ees, Wife ucknowledges receiving fi'OIn Husband $15,000 as udvaneed equitllble
distribution 10 PllY her counsel f(.(.s in this llIaller.
The parties shall be bound by the lerms of this ugreel11ent, which shall be
ineorporaled by reference into the DivOl'(.e Dccrce, shalluol be merged iu such Dceree, but shall in
1111 respects survive the sallie IInd be ('urlher binding as an enf()reeuble eonlraet, conclusive upon the
parties,
16. BREACII ANI) ENFORCEMENT:
(('eilher parly breaches any provision of this Agreement, Ihe olher parly shall
have the right at his or her c1ectlou, to sue (()r dalllages for such breach, 01' seck such other remedies
or relief liS may be responsible ('or payment of legal fces and costs incurred by the other in enforcing
his or her rights under lhls Agreement. Reasonable interest shall be ussessed from the date of
breach,
A, This Agreelllculmay be I:pecifieally enforced by eilher Husband or
Wife iu Equity, and the parties hereto agre(: lhat i(, nnactionto enforce this Agreement is brought
in Equity by either parly, lhe other parly will make uo objection outhe alleged ground of luck of
jurisdiclion 0(' said Coml 011 the ground thattlllOre is nn ndequale remedy at law, The parties do not
Intend or purport herehy to improperly con('er jmisdlcljon on a Court in Equity by this Agreement,
but they agree as provided herciu Illr lhe Ilmuu of equity Inmutuul recognition of the present state
of thc luw, und in rel.ognition or lhc gerwral.JurisdictiOIl of Courls in Equity over ngreclllent slleh
liS this one,
Il, NOlwithslnndillg ullylhillg 10 the conlrary herein, llusbund nnd Wife
I11UY utso proceed with un IIctioll al law Illr redress of his or her righls lindeI' thc terms of this
Agrcemenl, und ill such event it is speeilicnlly ulldcrstood nnd ugreed thnt le)r IIl1d in specific
((*,{;0111Itillls)
10
1~(lniliUIS)
Drlllll/2
April ~, 200 I
eonsidemtion of'the other provisions llnd cOl'enllnls oftllis Agreement, ellch shllll wnive IIny right
to II jury trial so liS to expedite Ihe hellring IIl1d disposition of' such ellse and so liS 10 IIvoid undue
lie IllY,
C, Elich party (llrlhcr hcr\1by IIgrees to PIlY IInd to sllve IIl1d hold hllrmless
the olher party fl'Ol11l1ny and III1I1Hol'l1ey's fees IInd costs of litigation that either may sustain, or
incur 01' become liable for, in any way whatsoever, 01' shall pay upon, or in terms 01' provisions of
this Agrcel11cnt by ('('ason of nny of the terms 01' provisions of this Agreel11ent by reason of which
either party shall be obliged to retain or engage counsel to initiat\1 01' l11aintnin 01' defend
proecedings against the olher at law or equity 01' both in any way whatsoever, provided that the party
who seeks to reeov(:r such atlol'lley's fees, and costs of litigationl11ust first be sueccssful in whole
01' in part, before there would be any liability for atlol'l1ey's fees and costs of litigation, It is the
speeif1c agreel11ent and intent 01' the parties that a breaching 01' wrongdoing party shall bear the
burdenllnd obligation of any and 1111 costs and expenses and counsel fees ineulTed by himself 01'
herself liS well liS the other party in endeavoring to protect and enfbree his or her rights under this
Agreement.
17. ADD1110NAL INSTRUMENT:
Each of the parties shall frollJ time to time, at the request of the other, execute.
acknowledge and deliver to the other party any nnd all further instruments that may b\ll'Oasonably
required 10 give full force and effect to the provisions of this Agreement.
Ill. VOLUNTARY EXECUl'ION:
The provisions of this Agreement and their legal effect have been fully
eXlllained 10 the parties by their respeclive counsel, and each party acknowledges thllt the Agreel11ent
is fail' and equitable, that ii, is being entered into voluntarily, with full knowledge of the assets of
both parlies, and thai il is not the result of any duress 01' undue influence, The parties acknowledge
that they have been fill'l1ish\1d with all infol'lnalionrelating to the financialllmlirs oflhe other which
has been requesl\,d by each of them or by their respeclive counsel.
19, IiNTIIW AWWIiMENl':
This Agreement conlains the entire understanding of' the parties and there arc
no reprcsentntions, warranties, covenants 01' 1I1lllerlllkings olher than those expressly set fOl'th herein,
II
~"U;,,',)
'-'~'~~ '
(C-'/> ..4
',-, ,~,_,~(Il1itials)
,Drufi 1/2
April S, 2001
Husband und Wife acknowledge and agrce that the provisions ofthl:; Agreement with respect to the
distribution and divisions ofnUlritnlllnd seplll'llte prllpl1rty lire lilir, equitllble IInd slltisflletory to tholll
based on the length of their IIllIlTillge lint! other relevant factors which have been taken into
consideration by the parties. Both parties hereby accept the provisions of this Agreement with
respect to the division of property in lieu of IInd in full and linul selllelllentand sutlsflwtion of 1111
claims and delllands that they II1I1Y now hllve or herellfier have IIgainst the other for equitable
distribution of their property by lInd any court of competent jurisdiction pursuant to 23 Pa,C.S,A,
Section 3501 ct. scq, or any other laws, Ilusbllnd and Wife each voluntarily IInd intelligently waive
and relinquish any right to seck II court ordered detenninution and distribution of marital property,
but nothing herein contained shllll constitute n waiver by eillll'r party ofllny rights to seek the relief
of any eourtlc)r the purpose of enforcing the provisions of this Agreement.
20. DISCLOSURE:
lIusband lInd Wife representllnd warrant to the other that he or she has made
a full and eOlllplete disclosure to the other of all assets of any nature whatsoever in which either
party has an interest, the sources and ",nount of the income of such party of every type whatsoever
and of all other relevant and material facts relating to tlw subject malleI' of this Agreement.
21. MODIFICA110N AND WAIVER..
A modi liclltion or waiver of any of thc provisions of this Agreement shall be
effective only if made in writing lInd executed with the sallle formality as this Agreement. The
failure of either party to insistupou strict pcrformance on any of the provisions of this Agreement
shall not be construed as II waiver of any subsequent delillllt of the same or similnr nnture,
:22. PRIOR AGIWEMENT..
It is understood and agreed that any nnd all property selllell1entngreements
which may 01' have been exc/:uted prior to the dutc lInd time of this Agreement lire null and void lInd
have no effr.ct.
23. lJESCRIPl'lVE llEA/JJNG'S:
The descriptive headings used hcrein arc for convenience only, They have
no effect whatsoevr.1' in determining the rights or obligations of the parties,
24. INDEPENIJENT SEI'ARA7'Jj' COVENANTS..
/:] ,~ j
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12
~;ti""1
PRELIMINARY EQUI'I'AIILE D1STIUBUTION ANALYSIS
CLIENT: Raymolld Timpone I>ate of Marrlagc: 10114170
DAn: PREIJAREJ):4/Sl01 I>alc of I'lnnl Scpnrntlon: 11ll9.!!
EI>W ARI> J. Wl<:INTRAUIl & ASSOCIATES: I'rcparcd IlYLElW
-
ASSETS ESTIMATEI> '1'0 TO
VALUE HlJSIlANI> WIFE
Renl Propl'rty
Claverton Rd, Mechllnicsburg $193,000 $96,500 $96,500
$210,000 less $17,000 selling costs
Vehicles
'93 Lincoln Mark VIlI (.It) 9,630 9,630
'96 Honda Accord (11) 9,070 9,070
Stocks, Bonds, Securities
O,S, Electric Stock Plan .0.
( expired)
Checking Acct, Cash
Dauphin Dcposit\ .0.
Allfirst (Chk) (1t)
PNC Bank .0-
Money Markct (1-1) 2,500 2,500
-
Life Ins, Cash Surrender Val.
Northwestern Mutual 6,161 6,161
Northwestern Mutual 6,569 6,569
johnson&Higgins\KVI, term - O.
Employment benefits (Curtis)
Stoek Option Plan -0- -0. .0.
Rclo, bonuses 12,400 12,400
401K - O.
Pension
General Signal (H) ? 40% 60%
IRA, Retiremcnt Plans
IRA (market fluctuates) 98,070 18,825 79,245
Marathon Electric 40 I K - 0-
--
Household Property 100% 50% 50%
TOTAL ASSETS $337,400 $152,585 $184,815
EXIIIlIIT "A"
I.It\DJLlTms I!:STIMA n:n TO
VALlJE HUSBAND
Mortgages
Fleet $125,955 $62.978
Dauphin Deposit Credit Line $22,234u $10,972
Car Lonns
Lincoln $ 6,032 $ 6,032
Hondn $ 1,155
Cred itCards
},C, Penney's (W) $ 90
Bank Americn (JI) $ 428
TO
WIFE
$62,977
$11,262
$ 1.155
$ 90
$ 428
NET MARITAL EST ATE:
L181.5.llL
I'ERCENTAGE DISTRIBUTION
TO II or W
__A~ 60%
DOLLAR DISTRIBUTION
TO II or W
,
$-.11,6.ll3 HllB.2O.l
ADJUSTMENTS:
Counsel Fees Advanced Equitable Distribution
SII,774 Medical Expenscs draw
..SII ,262 Credit Line draw by Wife
aftcr Date of Final Separation
50% Mortgage paid by Husband I 1199 thm 11/00
(SI ,224/2=$612x 13)
50% Utilities and cable paid by Husband 11/99 thru
2/00 ($2,42112)
Husband's car and insurance paid by Wife
Stock Option in lieu of payment
Heating rcpair SECCU
Toilct repair by Wife ($276/2)
Garage door repaired by Wife ($19112)
COBRA
. Mortgage paid by Wifc
Credit line adjustment
TOTALS:
NET ADJUSTMENT DUE FROM WIFE TO HUSBAND:
Hushand M.W
$15,000
-0-
-0-
S7,956
$1,210
SI,OOO
$2,000
$1,330
SI38
$9.L__
SI,294
$810
$4,000
lli.J.61l $10.667
$13,499
· ADJUSTED DISTRlBUTION/OF IRA:
$18,825
ill.Q75
$,3.6.200
S98,070
.l8.%
$79,245
,18.0,75
- $aUO
$98,070
~lli
'1'fR.1'.2Ile1 1:22PM M9 ~ WlrTf.R 170
Aceouat WonudOD Symm Output
lor TONY KIRCHNER
NO.313 P.2/2
A 170 ".'7" 01'
'1'O'r 1'01 Mar CQll
JIltV ltDIMUy
1 '1'.D. CUIlIlAL
:I B.lI. CUlIIAL
3 ca A""~'rJl
. NmLY ACe XNC
:I 3/1'/~1 1 ~y . TtNIONI POI 09/07/.6
llOU: (US) 8.10 - 8U.. IICtCII ('21) 7St _ 1'141
1lWPwUA/n.Ar TU Ol'lltf IRA alRl\ooa
O-HlROO/rKIOl 0~o1/"'01 0-rI801
0.00 Cl Ei Nl'!' VAL LOllQ POSI'l'tOllU o. aa dR
0.00 CR .: Ml'.t'VAL ta>>a 0I'l't0lM 0.00 aa
o . 00 CJt. 7' lC'l'II ~,8 'IU-.......n 0 . 00 em
o . 00 CR E1 Na' VAL SIlOR'1' OP1'XOIII 0 , 00 em
12/21 SLD
Ulao ao'1'
0'/20 110'1'
, HIY IIlt'l' llAL ILAr U, 5131 0. VAx. 81LOlf roa I/RICJII) POUT om,y
10 Ml'l' ~ CUIl'NWlAL POSIT 85, ~130 CI. tl!IIIIIW;lJ) QADl/'IlJ8. 0+ '
11 '1'OTAL PSlIDtNO Da/al 0 ClR ACcr VAIl 1'.8, U/OO l1a,1I1QR
12 'I'D ACCT vr.(l...I"'.+h:l,O) '8,(170 CI MCT VAIl II,I! oa/Ol 10",57'CA
U '.lID LQW lIOZ.DCNI VAlo(S"".10) as,~i30 CIl PIO.T\1'I) CASH A1fl/JfJIit 0...
14 T1I :DITVIftJUlr.JI J'UMDS C h1,",,) 1.1, Clu CI PIaCBIrr DlVU'l'Ill (13 /12) lIS
Cl:lIJl n lI.IDllC'l'Z1L8 C~ (J 1'l%Ol n D1IDllC'l':L1ILB eM 0
amul Yl JqOJ DIIDlJ01' COllI':VRD (I WXO.R TR NON J)M'lI'CT COIl'1' 0
J)l"'TllDItl'l'IONS TRIS ~ C1 DU'l'JUBtlTXC>>Ta TRU Y!lAR 0
- - MC>>t or uc:mrr AC'l':r:v:I'l.'D1S . _
30 MSDlI IIIOIlXl) MOT /1.2/18 JHI:r
2511 MSIlW SIIALL au QR o./ao BOT
au M.tnw tim-CAP 1C1II 09/ao BOT
a 0 . 00 AMNtlAL MAml'Dll\Ro
7U 1M HSDlI mou.z. CAP
167 1M )lSDlI Mm-CAP _0
A 170 OU7U 011 JDll) 3/16/01 2 RAY Jl '1'1MJilONlI:
.lSS1I'.l' w.o.tlA'l:%~ POI DlfR iOSX'l'xoars
CAlIS ... 1INIt'1'. 13" liIQl1I'1'J:llS c 70t 1I0IIID8. In 0'l'lIBR. Ot
0, ctf8'1'01);IN; POSIUONS
DA'rB UIlDT rtr'f./'fJ4) SYHDL MGN PLAN JlI\
3/18 12,8S9.'''0 XLAP 128i'.7~a
3/16 3,an ,U':ax 12713'5110
3/16 1,02" %NLIlX 133091727
1/'-6 288 MC!3PBX 133088434
3/16 282 SMtlU 13)08G211.
:'l/ltS 1,757 PRIMe 127UUQ)
3/15 837 8llTaX 132l19UilS
tNGnom/
Drv RB PRICB V71LUli PO!'.:tel' .
1.00 12.BU....
1 111.07 U,3U.i1
3. 8.4' ',ua,u
1 17.:1.2 ',nO.56
1 U.74 5,5~6.69
1 ~.U 15,,,U.U
1 J.6.06 10,230.22
fr- ~~cr 3
Alolto~ Slanll)l D.o. WI1rtr Collfidettlilll fMla . HM all DJftcl4lll4lllJ/\e~'
hee 1 all
Mona." MarC\ll',2OO1
. 3111 pm
TOTAL P.05
8. The marriage between the parties hereto is irretrievably broken.
9, Plaintiff requests the Court to enter a decree of divorce.
COUNT II . FAUUr GROUNDS FOR DIVORCE
10. During the course of the marriage, and leading to the separation of the
parties, husband engaged in various forms of wrongful conduct, including maintaining
relations with at least one female before the separation of the parties.
COUNT III . EQUITABLE DIS'rRIBUTION
11. Plaintiff incorporates herein the prior paragraphs above by reference.
12, The parties are the owners of personai property subject to equitable
distribution between them as maritai property,
13. The Plaintiff reqnests the Court to equitably divide such items of maritai
property between them,
COUNT IV . ALIMONY AND ALIMONY PENDENTE LITE
14. Plaintiff incorporates herein the prior paragraphs by reference.
15. During the course of her marriage, the Plaintiff has been financially
dependent upon the Defendant,
16. The Plaintiff is unable to support herself in the lifestyle to which she was
accustomed during the marrillge of the partios.
17. The Defendant is financially able to assist and support his wife, '1'he
Plaintiff is in need of alimony pendente lite to maintain herself during the course of
this action Ilnd to permanent alimony thereafter if she is t.o maintain her lifestyle.
COUNT V . OOUNS\<jL l"EI<JS, COSTS AND EXPENSES
18, Plaintiff incorporates herein tho prior parllgraphs above by reference,
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vr<<
IN THE COURT OF COMMON P
CUMBERLAND COUNTY, PENNSYLVANIA
PlninlilT/Petllloner
VS,
CIVIL ACTION. DIVORCE
RAY'FIMPONE
Defendant/Respondent
NO, 99 - 30~ CIVIL TERM
IN DIVORCE
DR# 2H.~03
Pncscs# 24911111923
ORDER OF COURT
AND NOW, Ihis 14'" day of April, 1999, npon eonsideration of the altached Pelition for Alimony
Pendente Lite amI/or counsel fees. II is hereby directed that the parties andlheir respective counsel a~pear
before &L.Shaddav on May 10, 1999 a19:00 A,M, for a conference, at 13 N, Hanover SI" Carlisle, PA
17013, after which Ihe conference officer may recommend that an Order for Alimony Pendente Lile be
entered,
YOU arc further ordered 10 bring to the conference:
(I) a tme copy of your most recent Federal Income Tax Return, including W.2's as filed
(2) your pay slubs for Ihe preceding si., (I>) lIIonlhs
(3) Ihe Income and Expense Statement altached to this order, compleled as reqnired by Rnle
1910,11((',
(4) verilication of child care expenses
(5) proof of medical coverage which you may have, or may have available 10 you
IF yon fail to appear for the conference or bring the reqnired documenls, Ihe Conrt may issue n
warranl for yonr arrest.
BY THE COURT,
George E, HolTel', President Judge
-,
ec: Petilloner \
Respondent ) f"t..L,SL",j
Samnel Milkes. Esq, c.., ,\I"G.~,\
Edwnrd Weintraub, Esq,) 'III"I~'\
'!
Date of Order: .AmilJi.. 1999
I
-..."...... .
R. J, Shaddav, Conference OlTlcer
YOU HAVE THE RIGIIT TO A LAWYER. WHO MAY ATTEND THE CONFERENCE AND
REPRESENT YOU, U' YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE O.'.'ICE SET .'ORTH BELOW TO .'IND OUT WHERE YOU MAY GET
LEGAL HELP,
CUMBERLAND COUNTY BAR ASSOCIATION
2 LiBEKTY AVE,
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
',-
7. 'rhe Defendant has now stopped providing the amol1nt of support and
. contributions toward marital debt which he had previously been paying and which are
necessary to meet Plaintiff's basic expenses,
8, These contributions are vital to Plaintiff's day-to-day survival and are
necessary to avoid debt problems for the parties.
9, Initially when the Defendant accepted the position in California, the
parties agreed that they were continuing to work on the marriage anrl intended the
marriage to survive this move.
10. Since this move, Plaintiff has become aware of various actions of the
Defendant which she considers to constitute indignities under the Divorce Code.
11, The Plaint.itI's discovery of Defendant's actions has caused her great
mental anguish, to the extent that she has been hospitalized more than once.
12. These events have caused the Plaintiff to be unable to secure income
of her own and have caused her, through the hospitalizations and related counselling,
to incur significant financial liabilities,
13, This divorce action is expected to involve complicated and technical
alJpects of representation since it is believed that the Defendant has concealed assets
and other vital inforlllution relating to this divorce action. Therefore, the discovery
process and the litigation process will be more involved than usual, These beliefs are
not merely baseclupon hunches, but lU'e baseclupon discoveries already made,
14, The Plaintiff is in need of financial support in the amount of $8,000
on a monthly basis, to IIll\et her daily expenses and to assure that the marital debts
lU'e being paid.
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7, The Defendant has now stopped providing the amount of support and
con'tributions toward marital debt whicb he had previously beon paying and which are
necessary to meet Plaintlft's basic expenses,
8, These contrlbut.ions are vital to Plaintlft"s day.to-day survival and are
necessary to avoid de bt problems for the parties.
9, Initialiy when the Defendant accepted the position in Califol'l1ia, the
parties agreed tbat they were continuing 1,0 work on the marriage and intended the
marriage to survive this move.
10, Since this move, Plaintiff has become aware of various actions of the
Defendant which she considers to constitute indignities under the Divorce Code,
11. The Plaintiff's discovery of Defendant's actions has caused her great
mental anguish, to the extent that she has been hospitalized more than once.
12. These eVi.>nts have caused the Plaintiff to be unable to secure income
of her own and have caused her, through the hospitalizations and related counselling,
to incur significant financial liabilities,
13, This divorce action is expected to involve complicated and technical
aspects of representation since it is believed that the Defendant has concealed assets
and other vital information relating to this divorce action, Therefore, the discovery
process and the litigation process will be more involved than usual. These beliefs are
not merely based upon hunches, but are based upon discoveries already made,
14, The Plaintiff is in need of financial support in the amount of $8,000
on a monthly basis, to meet her daily expenses and to assure that the marital debts
are being paid,
7. Denied. Defendent has consistently provided Plaintiff with sufficient
support to meet her marital needs and has consistently made payments on marital
debt.
8. Admitted.
g. Admitted.
10. Denied. Defendant Is without Information as to what actions Plaintiff
considers Indignities under the Divorce Code.
11. Admitted In part, denied In part. Defendant Is aware that Plaintiff was
hospitalized once, but Is without Informatlun that she has been hospitalized more than
once. While Defendant understands and admits that the end of their marriage may
have caused Plaintiff great mental anguish, he denies that his actions toward the end
of the marriage have caused Plaintiff's mental difficulties, which were abundantly
apparent throughout their marital history.
12. Denied. Defendant believes and therefore avers that Plaintiff has earning
capacity and has recently been gainfully employed, despite her mental problems.
Defendant Is without information as to any financial liabilities incurred by Plaintiff since
their separation.
13. Denied. Most information regarding the parties' marital assets has been
and continues to be In the control of Plaintiff. Defendant specifically denies that he
has concealed marital assets. Prior to the filing of the instant Petition, Defendant,
through his counsel, offered to voluntarily produce all relevant financial data. It Is
therefore specifically denied that discovery and litigation will be necessary at all, let
alone more involved as usual as alleged by Plaintiff.
KAREN TIMPONE
Plaintiff
: IN THE COURT 01" COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO, fJg-a05
CIVIL Tl<JRM
RAY TIMPONE
: IN DIVORCE
Defendan I.
IN'rERROGA'rORIES AND REQUES'l' FOR PIWDUC'!'ION OJ!' DOCUMENTS
Plaintiff, by her attorney, Samuel W. Milkes, Esq" JACOBSEN & MILKES,
hereby requests that Plaintiff, to whom these interrogatories are addressed, answer
fully, In writing and under oath, the following interrogatories pursuant to the
Pennsylvania Rules of Civil Procedure.
DI~I~INITIONS AND INSTRUCTIONS
Unless negated by the context of I. he interrogatory, the following definitions are
to be considerod to be applicable t.o all interrogatories contained herein:
(A) "Documents" is an all-inclusive term referring to any writing and/or recorded
or graphic matter, however produced or reported, The term "documents" includes,
without limitation, correspondence, memoranda, interoffice communications, minutes,
reports, notes, schedules, analyses, drawings, diagrams, tables, graphs, charts, maps,
surveys, books of account, ledgers, invdces, purchase orders, pleading, questionnaires,
contracts, bills, checks, drafts, diaries, 10l:(s, proposals, print-outs, recordings,
telegrams, films, tax returns, and financial statements, and all other such documents
tangible or retrievable of any kind. "Documents" also include any preliminary notes
and drafts of all the foregoing, in whatever form, printed, typed, longhand, ~horthand,
on paper, paper tape, tabuluting cards, ribbon blueprints, magnetic tape, microfilm,
film, motion pictme film, phonograph records, or other form.
(B) With respect to documents, tho torm "identify" means to givo the date, title,
author and addresseo; "identify" with respoct to documents fUl'thor means:
(i) To doscribo a document sufficiontly WIJII to enablo the interrogator
to know what such document is and to retrieve it from a file 01' wherover it may
be located;
(Ii) To describe it in a mannoI' suitable for use as u descript.ion in a
subpoena;
Wi) To give the nume, address, position or title of the pel'son(s) huvlng
custody of the document and/or copies thereof.
. ..-
..
",'
5, For the premises lit the preseut IIddress Wht'l'll you l\I'(l lIotulIlly l'oslillng,uud IIny sueh
resldenlJos sinee YOllr sepul'lltlon from you I' wift', S(.t fOl'lh till' III1)(lUnt of reut on II
yearly und monthly hllSis, tllll dlltl' of OOllllnenOtmwnt of allY lease /lnd dllte of
temlinallou of ClIl'rent leuso, uud 1111 (\outrihutions, if IIny, Iwing mude by uny pel'soU
01' persous, husiuess 01' eUl'(lorlltiou to the cost of mlllntellllnetl of this I'llsidenoe,
I have resided st two addre.... .inc. arriving in Culi[orni., The present uddres8
is 39t Eastridge Drive, San Hamon, CA 94583, The monthly rent is $1415 and the
furniture rental is $383. My current en~loyer pays $1383 plus a taR grDsn up Buch
that I pay $415 out of pocket. Lease initiated 10/7/98 and is for one year.
Initial address was Coutrll Brook ApartmentH, U COHtl1 lllvd, San Ramoa, CA. Rent
aad furniture was approximately $1750 per month and was puid direttly by the
company to a relocation coordinator. Payment was tre.ted as income and grossed up
for taxes. My employer handled the lellse, Occupancy was from 4/19/98 until 10/7/98.
6. If you ure employed or have been employed within the pllSI yelll', set forth the
followiug for elloh of yoUI' employer(s):
lI. Positiou held with employer, how long so employed, IInd whether you hllve
entered into Ilny written employment ugreement with your employer, If YOll
huve or hud u written employment ngl'eement, ullueh u oopy of the ugreoment
lind/or agreements,
Employment during the lll~t year - only one employer.
VP General Manager; en~loyed siace April 20, 1998; no written employment
agreement with employer.
b.
What is YOllr
employment?
, . k'l
pleeewor ,
Current aalary- $155,000 per year, calculated for payroll purposes as an
hourly rate but paid weekly, Ilssuming 52 weeks per year and 40 hours per
'Il,eek. No commi~BiDns 0;: plqce work. ,
I'or ouch pay pel'lod, and II'0m Jllnu!lI"y I, 1998 (01' sueh earlier dute ns you
scpnl'Uled fl'Om youl' employment) until the dnle these Intel'rognlories me
answer'cd, state: the pay period; the gl'Oss puy reeeived; the honrs wOl'kerl; an
itcmizntion of eneh (it'duellon dedueted from tlie gross sallll'Y, speeifying the
1H1lure of and amounl of eneh deduetion, and the net sulary I'eel,ived, Inelurle
in this I'Csponsp, rt'gulnr earnings, IlOnuses, I't'ntul pUYIllI'nls, IInd any olher
forms of ineonw 01' eompensulion J't'eeivt'd from your t'mployt,l',
eUI'l'enl snlary
Is your snlnl'Y
or YOUI' sn1ary upon scpal'lltion froll! this
based on hourly rate, eonllnissions and/or
c.
(1) In Ihis response, illtdlldl' any honus medved, any htlllsing, tl'llvel,
01' olher al1owunet,. uuy profit shuring, any stoek opt ions, any pnymenls
to third pnl'ties on YOUI' Iwhulf, uny non-mom'tury Iwnel'ils, sueh as
aulonlOhilt' ullowanee, or nll'dienl insnl'mllle und any other henefit
rcoeivt'd, having UnY t'eolHlllIit: vulllt' whnlsoever, Inelude in this
I'csponse till' valill' or uny sueh f01'1lI of eomp"nsntion 01' Iwnefit,
APR"28-1999 08:49
ClRTlS PMC
P.02/15
,
In the Court of Common Pleas of CUMBERLAND County, PennlylvlDla
OOI\fD'TIC llUATIONS
r,o, lOll 32', CAllLISl.E, 'A. 1101J
I'lloael (717) Z40-fU5 Fall: (717) 240-4248
APRIL 14, U99
Plalmlff Name: ICAUN TIMPONE
Defendanl Namc: RAY l!. TIMPONE
Dockcl Number: 99 305 CIVIl.
PACSES Case Number: 2Ul00923/~i1,,,,~
Other Slate 10 Number:
PIeIIe lOtel All c_._. - -" . _1iIdade lIMl rACS!S C... ~I
mCI_ and ElQ)MI_ Stat_.n~
nilS fORM MUST BE PlLI.ED OUT
(If you art self-eqlloyed 01 If you are sabrled by I businesa of which YOll art OWlltil' In whole 01 pan, you must
also IIU oUlthe SupplemeDllllncome SlIlellllllll whlcb appws on the IasI pa,e of Ibis blCome IIld hpellSe
'SIIlemeDl. )
INCOMBSTATBMBNTOF Ralf 1;, 7/moone
I
I verify tbalthe IlaleDlelll8lll1de In IbislllComr. and BxpellSll SWemeDllle lIue and correct. I undersWld thai
false '~1lIeDlS berdn are subjec;110 lbe criminal penalties of 18 Pa, C.S, . 4904, leladnlllo unsworn
fa1sIfll:illoD lO aulborities, ~ a... ~
t./J~5J99 _~~
Dale . P I 1 Defendant
INCOME: /'l L. .L .J "1'"':_
Employer (... U 1-', I S Ih <; T HJ me Jl '1"5 , ....J.--f) L.
Address -.;< 00 K IS C D ~-/'fJ.-t-' K, sr D,' N V ,~ 54 9
TYJlC of Work /V1 (1 (Ill tJ P ,....
t':1<U/P, J .2980 gO 1..-
(layroll No, Gross Pay per Pay Period $ _~__Pay Period (wkly" bi.wkly., elc.) we.E>.I(,/~
lcembed Payroll Dedw:llons:
Pederal WllbboldiDll $75,3 Social SecuritY $ng IAcaI WI,e T~
SlIre Income Tax SUO Retlrclllell~O' ""-. $ I'7q Savina. Bonds
ClCiIlc Union $ We IDSUllDCe $ Heahb In.~rance
Odler DeducdoDS (specify) $
S
$
$
$
NOl Ply per Ply Period $
1~()O.fiO
SelVlce Type M
Ponu IN -008
WOlker to 21205
~
::-
,
~
tllCOmc lIIll ExpellSe SlIlomeIM
P,04/1S
PACSES Case NUmbllf 349l.00933
-----
EXPENSES .- (FIUln Appropriale Column)
(continued) WEEK MO~D ~c.J)" YEAR
-- CA PA
.- 1
Walef S S S
,
Sewer I
-- -.
I ..-
-- ,
Employmelll
Public TransporIldon $ S S
--
LIllICh I~O , ,
,_. -
!
~ !
Real Bswe S S .150 ~ S
PelliOaaI propeny ---
lllCome -
-
InsIl\'allCle
. o:r"flT ---- 5, 0 l\(
Ho1llCOWlIen -lib-Lie y $ S $
AUlOmobll~~~J; v '.2.00
Life :J:ndlvuJU4..1 SO ~ -_.,-,.-
:!,ccldciDl
Health
Other - --
Automobile i
PaymentS $ $ . f- t: .r; 'II( $
Fuel 11\(') ..
RepaJrs 50 -
1--.. ---_._.~-
Medlw --- -----
DOCIOl $ e!- ,5 . $
.
Dentist 50
>-'--- .. .
Ordlodowlsl
If Av+ aWo\
Page 3 01 6
q,olWfa
Worker ID ~1205
S..rvlce Type M
I fK;Ome l/Id IiXp:lDIC Swemcnl
PACSES Case Number 249100923
-
EXPENSES (FlU In ADO!OOriale CoIUDlll)
(contlnuerl> WEEK MONT~Il1f ,.c, YEAR
,
cn ~_ ---
H06p11il
Medicine ISO
--
Special needs <.lweI,
brlCe., onhopcdlc 50
devicn)
--
Education
Privllt $chool S $ $
Parochial School
Colleta 10m J:~ 00 ([S1)
RalislollS
--
PenonaJ
-- -
ClolblDg S $ /00 $
..
Food 400
BarberlHairdmltr .2.D
- .____.._u
CrecliIP~llllI:
Credit
Char,a ACl'OUDl
-~.-
Mcmbel3hlps ..
Loans
Credit Union $ $ $ --
L,f1e t:>f. cr~d,'+.. ~H;pse .rDI/fA-Ieral J ~ Ilfllt:~I'
-
- ..
Mlscdla.neous
Household Help $ $ S
--
CWld Care - .._---
--
PapelS/Dooks/M~Sazlnc rJ.O
....
EmenallWlCDI ~O()
- .._~---
Pay TV --.- .3$' ..
..,
Vacalion 10 ()
_.
rage 4 01 6
Fonn IN.Q08
Worl:erlD 21205
$trvke Type M
lncolllC .~ E~pII1IIIIl SIII.1JItl1ll
PACSES Case Number 249100923
-,-,--
Cont... .
INSuaANCE COMPANY
I' .~ ',\J.U. .1 No,.,-IhIAA!S1;, r
DlsabUlty IllOOme 1 F'.
Denlal m E. T 1-1 F C.
Olhcr 1-1 FE'. /Y) e:r /.,.1 Fit
. II . Husband W. Wife C. Combined J . Joint
H W C
Sllpplemflotallntomt Staltmenl
a. This form 1110 be filled out by a person
~1~ wbo operates a buslDeas or practices a profession. or
2 who Is . member of a partnership or jo1nt vtIIlUre, or
3 who Is . shareholder In and Is l8larieit by I closed corporation or Ilmllar entity.
b, Attach to thiS statement a copy of the foUowituI documents relallng to the parlnership. joint
vemure, business, profession, corporation or sTmllar entity:
(I) the mOlt recentPederallncome TIllt Return, and
(2) the most recentl'rofit and Loss Scatement
c. Name of business:
Address and telephone uumber:
d, Nature ofbuslness (check one)
(I) pannenh1p
(2) Joint venlUre
(3) profession
(4) closed corporation
(5) other
e. Name of accountant. controller or other penon in oharlle of fina1'lolal records:
f. Annual Income frolll business:
(1) How often is income received?
(2) Qross income per pay period:
--.-.-
(3) Net Income per pay period:
-
(4) Specified deductions. if any:
P"8~ 6 of 6
FOnn IN-OOS
Work~IID 21205
Service Type M
t;: -" ~
..:r. It'l ,.
~.., .. '$
'.l~~j3 M , )..
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KAREN TIMPONE.
IN THE COURT OF COMMON PLEAS
CUMBERLANDCOUNTY, PENNSYLVANIA
NO. 99.305
Plaintiff
v,
RA Y TIMPONE.
CIVIL ACTION. LAW
IN DIVORCE
Defendant
ORDER
AND NOW, this __iD -tJI_ day of ~tY\a.'<r
, 1999, upon
oonslderatlon of the within Motion for Continuance, it is hereby ORDERED that the
hearing soheduled In this matter for May 10, 1999, at 1 :30 p,m, is rescheduled for
the ~ day of, ~I /(0'''_1-__,1999, at JI 00 Q ,m, In Court Room
") ()
No, ~ of the Cumberland County Courthouse, Carlisle, Pennsylvania,
~-
J,
By the Court:
/
than f1ftaen duys lute (uside from the month of Muy 1999), Plaintiff shall give
Defendant five (fj)days written notice and the opportunity to cure his default before
Issuing any garnishment or at.tachment, The duration and amount of these payments
may be modified at the initiation of either paJ'ty, only by written llgreement of the
parties, or by Order of Court,
2, Effective and beginning the month of May 1999, Defendant shall pay
to Plaintiff the monthly amount of $1,000, for a period of fifteen months, as an
adVlUlce from equitable dist.ribution, for Plaintilr s use as counsel fees, costs and
expenses, or for any other purpose designated by Plaintiff, There shaIl be no other
payments for interim fees or costs, but the parties make no agreement as to whether
counsel fees or costs should be awarded Ill. the time of filial distribution in this case,
These payments shall be made on or before the first day of every mont.h, by regular
mail to the Plaintiff, at her home address,
3, Defendant. shall pay 100% of Plainti1rs reasonable medical expenses,
not covered by insurance, to inchtde reasonable psychiatric, dental and eye care,
beginning calendar year 1998, and on a continuing basis, 'fhe amount of any
continuing psychiatric expenses of Plaintiff to be paid by Defendant shall be capped
at the level equal to the Plaintiffs psychiatric expenses incurred over the past twelve
months, Plaintiff shall provide Defendant with a summary of her pl'ior twelve month
psychiatric expenses, Plaintiff shall be responsible for timely submission for all
available insurance coverage for these expenses, including all available for 1998,
4, In gel"\eraI, the parties shall each be responsible for payment of their
own living expensos, Specifically,.the Defendant shall be I'osponslble for the following
expenses:
a, Automobile Insurance on the Lincoln automobile,
b, Automobile payments on the Lincoln automobile,
c, Northwestern Mutual insurance.
d. O,S. Eloctric insurance,
Both parties shall promptly take any actions necessary in ordol' to implement
this paragraph, Including changing address, forwarding of papers, and transfer of
automatic bank account deductions,
5, Without prejudice to any acijustments to finaI equitable distribution,
the parties will execute forthwith, any title documents necessary to transfer title of I. he
Lincoln automobile to Husband and title to the Honda to Wife,
6. Plaintiff shaIl be responsible for routine maintenance of the marital
home located at 3822 Claverton Road, Mechanicsburg, Pennsylvania, where ahe
reaidea, Any reasonable amount expended on structuraI maintenance and repairs,
advanced by either party, shall be shared equitably upon final distribution, Both
partiea will provide the other with thirty (30) days prior notice of such anticipated
expenditures exceeding five hundred ($500) dollars, Defendant will pay the actuaI
coats of repairs, in an amount up to one.thousand.five.hundred ($1,500) dollars,
toward the cost of repair of the following two items, and these costs shaIl be shared
equitably as provided for above: Repair of roof and replacement of bathroom tl)ilet,
, 'AIF171?lIN,.
"'"'0....__.'...".;"..---,-..\..,.(,
PIHlnllrrlPctlllnncr
fN TilE COURT OF COMMON PU:AS OF
CIIMO.:RLAND CO\JNTY,I't:NNSVLVANIA
VS,
CIVIL ACTION. D1VORn:
RA V TIMPONE,
I)cfcndHnt/RcHlltlllllcnl I
NO, 99-JO~ CIVIL TERM
IN I)IVORCE
I)R#2H,~OJ
PnucH# 249lU092J
OIlDER OF COllRT
AND NOW, Ihis 22'''' day of November, 199'1, a pelilion has been OIed agllinHI yon, 10 mndi(y nn
exlsling Alimony Pelldenle l.ile Order. YOllnre ordered 10 IIppellr in persolllll the Domeslie Relllllons
Seelion, I) North Hallover Slreel, Carlisle, Pennsylvanill, olllJe<,emher 16, 1.222.1I11/1:.W ,~,M" for II
eonferellee IInd 10 remainnlllil dismissed b.\'lhe COllrt. If yo II fail 10 appellr as provided In this Order, IIn
Order for Modifiealioll may he emered agaillsl YOII
Yon arc flll'lher ordered 10 bring 10 the cOllfel'ellcc:
(I) a tllle copy ofyonr mosl recellt I'ederalllleome Tax Retnll1. IlIclllding W.2's as OIed
(2) your pay slnbs for Ihe preceding six ((,) monlhs
0) the IlIeome and E.spense Slalemelll ailached 10 Ihis order, completed as reqllired by Ihe Rnle
I 9 Ill. I I.
(4) veriOealioll of child care e,spenses
(S) proofofmediclIl coverage which yon may have, or mllY have nVllilable 10 yon
IF yon fall to appear for Ihe cOllference 01' bring Ihe reqllircd doelllllems, Ihe COli II mill' isslle a
II'lIl1anl for YOlllallest.
Copies mailed
11.22-9910:<
BY THE COURT,
George E. HolTer, PresideI'll Jndge
Petliioller
Respondelll
Edward Weilllrallb, Esqlllre
Samllel Mllkes, Esquire
'''/l 7 / <1 j I I
IL-J."::_-/ .I~!-._~ (~ ?}-:::
, R J ,lladday, Conferellce ofl!.~r .:: r:
r'll. .' 1'1
YOU HA VE THE RIGlIT TO A l.A WYER. WIIO MAY ATfEND THE CONFERENCE Al'IlQ (~ ' ,
REPIIESENT YOU. IF YOU DO NOT HA VE A LAWYER OR CANNOT AFFORD ONE.~O() TO oR : '('
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHElUi YOU MAY OiOi/LEOAI. '" Ii
HELP.,;"",,)
,~'," \".. ,!ifl
. .-1
::~2 i~ ~
Dille of Order' _/'o!Qycmber ~.L I '1'1'1
CUMBERLAND COUNTY BAR ASSOCIATION
2 L1BEIlTY 1\ VB,
CARLISLE. PENNSYLVANIA 171111
(717) H9.) 1(,(,
MAY-20-1999 14:12
JACOBSEN & M I LKES
717 249 8427 P.04
KAREN TIMPONE
PlaintltT
Defllndant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO, 99.305 CML TERM
: DR NO, 28503
: PACSES NO, 249100923
v.
RAY TIMPONE
STIPULATION OF THE PARTIES
COME NOW, the parties to the above matter, by their attorneys, Plaintiff
represented by Samuel W, Milkos, Jacobsen & Milkes, and Defendant represented by
Edward J, Weintraub, Law Office of Edward J, Weintraub, and stipulate that the
following agreement may be entered as an Order of Oourt, By entry Into this
Stipulation, the parties agree that the he~ng currently scheduled for May 24, 1999
before the Honorable Edgar B. Bayley, and the Domestic Relations Conferen.ce
scheduled for that same date may be cancelled, This Stipulation addrosses both the
Plainti1I's request for alimony pendente lite and her request for counslll fees, Thll
parties agree as follows:
1. Effective and beginning the month of May 1999, with no arrears,
Defendant shall pay to Plaintill' montWy alimony pendente lite in t.he amount of
$4,000, Except for the month ofMuy 1999, these payments shall be made on or before
the first day of eVHry month, by regular mail t.o thll Domestic Relat.ions Office of
Cumberland County, 'l'he May p!lyment shall be Illllde directly to Plaint.ill' and
Defendant is credited with any advance payments already made during the month of
May, for that month, There BhaU bo no garnishment or attaohment of wages, so long
as the Defendant remains current in those payments, such that no payment is more
MAY-20-1999 14113
JACOBSEN & 111 L.KES
7172498427 P,0S
than Meen days late (aside from the month of May 1999), Plaintur shall give
Defendant five (5) days written notice and the opportunity to cure W. default before
ISBning any garnishment or attachnlont, The duration and amount of theBe paymentB
may be modified at the initiation of either party, only by written agreement of the
parties, or by Order of Court,
2, Effective IUld beginning the month of May 1999, Defendant Ilhall pay
. .
to Plaintiff the monthly amount of $1,000, for a period of fifteen months, as an
advance lrom equitable distribution, for Plainti.ffs use as counsel fee a, costs and
expenses, or (or any other purpose deBignated by Plaintiff, There shall be no other
payments for interim fees or costs, but the parties make no agreement as to whether
counsel fees or costs should be awarded at the time of final distribution in this case.
These payments shall be lllade on or before the fll'st day of every month, by regular
mail to the Plaintur, at her home address,
3, Defendant shall pay 100% of Plaintitrs reasonable medical expenses,
not covered by insurance, to include reasonable psychiatric, dental and eye care,
beginning calendar year 1998, and on a continuing basis. The amount o( any
continuing psychiatric expenses of Plaintiff to be paid by Defendant shall be capped
at the levol o<!ual to the Plaintiff's psychiatric expenses incurred over the past twelvo
months, Plaintiff shall provide Dofendant with a summary of her prior twelve month
paychiatric expenBOs, Plaintiff shall be responsible for timely submisMon for all
available insurance coveragn for thesn expenses, including all available for 1998,
JACOBSEN & M I LKES
'lI'1 24'3 8427 P,06
~. In general, the parties shall each be respon.lble (or payment oftholr
own living expenses, Speoifically, the Defendant shall be ro.ponlJble (or the (ollowing
OJ:penses:
a. AutQmobile insurance on the Lfneoln automobile.
b, Automobile payment. 011 the Lincoln automobile,
c, Northwestern Mutual insurance,
, .
d, O,S. Electric insurance,
Both parties shall promptly take any action, neoessary in order to implement
this parllgraph, Including changing address, forwarding of papers, and transfer of
automatic bank Ilccount deductions,
5, Without prqjudice to any lUijustments to finaI equitable distribution,
tbe parties will exeoute forthwith, any title dooumentB neoessary to transfer title of the
Uncoln automobile to Husband and title to the Honda to Wife,
8, Plaintiff shall be responsible for routine maintenance of thomaritaI
home located at. 3822 Olaverton Road, Meohanicsburg, Ponnsylvanla, whoro she
rosldlls. Any reasonable amount expended on structuraI maintenance and repairs,
advanced by either party, shall be shared equitably upon filial distribution, Both
parties will pro vi do the other with thirty (30) daYB prior notice of such anticipated
expendlturos oxcoodtng fivo hundrod ($(iOO) doUars. Dofendant will pay tho actual
cosh of t'Opairfl, in an amount up to one-thousand-five-hundred ($1,600) dollars,
toward the cost of repair of tho following two itoms, and tbll8e costs shall be shared
aquitably 118 Jltovidad for lIbove: Repwr of roof and replacement of bathroom toilet.
>' ('0 ~~.
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LAW OFFICE
EDWARD .1. WEINTRAUB
2650 NOkTfl THIRD STREET
HARRISBURG. PENNSYLVANIA 17110
(717) 2:15.2200 FAX 17171 238.9280
o~I'I4'2001
-______~~1_.....,._M__~......'....._.~..'.._.,"""'.c~__~".___~"._"
~.,-"..~..~_...lUHil.---
KAltEN TIMPONE,
IN 'fHE COURT 011 COMMON PLEAS
CUMBERI.ANDCOlJNTY,
PENNSYI.V ANIA
PlAintiff
\'.
NO. 99-305 CIVIL n;RM
RA Y TIMPONE,
llR. NO. 28503
PACSES NO. 249100923
llefendont
STII'ULATIOl'lFOR AGREED_QRDER UFAUMONY
AND NOW, this ~ ~~~tDd~y of August, 2001, thc pm1ics with and through their
counsel hereby stipulatc and thc Court is hcrcby rcqucstcd to Order that thc Payor pay to
Plaintiff Alimony for her own support thc sum of$3,150 pCI' month commcncing July 1,2001,
bcginning thc first day of thc first month following the cxccution of thcir Marital Settlement
Agreement. As additional Alimony, Wifc shall rcccivc 35% of any net bonuses or incomc from
profit sharing paid by his cmployer to Husband, within ten (10) days of receipt of each bonus,
with documclltation to Wifc of each gross bonus,
Arrears are set at zero as of July I, 200 I. All tenns of this Order are subjcct to collection
and/or enforc\'mcnt by contempt proccedings, crcdit bureau reporting and tax rcfund omet
certification and will not bc initiatcd as long as obligor does not owe ovcrdue support, Failure to
make cach payment on time and in full will cause all arrcars to becomc subject to immediate
cCillcetion by all the mcans Iistcd abovc,
For the Support of;
Name
Date of Birth
Karen Timponc
Scptember 14,1949
The Dcfendant owes a total of $3, 150 per month payablc monthly; $3,150 for current
support and zero as of July I, 200 I for arrcurs.
.
Paymcnts lIIust be mudc by check or llIoncy Ord\ll', All chceks und money orders must be
mude puyuble to Karcn F, Timponc.
All payments received hy Pluintiff shull be reported by hcr us income und dcductible by
Defendunl.
Alimony shull tcrminutc in the evcntofthc Wife's dcath, cohubitution or rcmurriagc.
Defendant shull pay the following fees:
Eee~al Eec_Dcscription
$5,00 for Judicial Computer Fce
$25,00 for Court Cosls
Paymcut,Frcqucncy
Payuble at $5,00 per one time
Payable at $25,00 per onc time,
IMPORTANT LEGAL NOTICE
Parties must within seven days inform the Domestic Relations Section and the other
parties, in writing, of any material change in circumstanccs relevant to the level of support or the
administration of the support ordcr, including, but notlimitcd to, loss OJ' change of income or
employment and changc of personal address or chungc of addJ'css of any child recciving support,
A parly who willjill/y/ails 10 I'eporl a malerial change in cil'cumslances may be adjudged in
contempt 0/ COUI'I, and may be/ined 01' imprisoned,
Pennsylvania law provided thai ull support orders shall be rcviewcd at least once cvery
three (3) years ifsuch rcview is requeslcd by onc of the parties, (fyou wish to request a review
and adjustment of your order, you mllst do the following: call your altoJ'lley. An unrcprescnted
person who wants to modify (adjust) a support order should contaclthe domestic rclutions
section,
If Plaintiff, without thc rcquirement of prior noticc to Defendant, notllics Domestic
In the COllrt of Common PleWl of CUMO.:RJ.AND County, Pennsylvania
I>OMF:S'I'IC REUTIONS SECTION
KAREN TIMPONE ) Docket NUlllber 99 305 CIVIL
I'lallllll'l' )
vs, ) "ACSES Case NUlllher 249100923/028501
RAY E, TIMPONE )
Del'cudal1t ) Olhcr Slale I D NUlllher
ORDER
AND NOW, to wit. on this 17TH DAY OF OC1'OBER, 2001 IT IS HEREBY
ORDERED that the support order in this case be 0 Vacated or OSuspended or
(i)Terminated without prejudice or 0 Terminated and Vacated,
effective
JULY 1, 2001
. due to:
THE PARTIES' STIPULATION FOR AGREED ORDER OF ALIMONY, THE ALIMONY PENDENTE
LITE IS TERMINATED WITH NO BAL1\IlCE DUE AND THE AJ,IMONY IS TO BE PAID DIRECTLY
TO WIFE,
BY THE COURT:
000: RJ Slvlddl\y
xc: plAintiff
defenlMt
FAw/lJ:dWelntrllub, Esquire
Samuel i'lLll<es, Esqul re
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Funn OE-504
Worker ID 21005
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