HomeMy WebLinkAbout99-01953
SHARON L, CORREA, a/kia,
SHARON L. PSZCZOLKOWSKI,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs,
NO. 99 - 1953 CIVIL
THOMAS C. PSZCZOLKOWSKI,
Defendant
IN DIVORCE
TO: Joanne Harrison Clough
Attorney for Plaintiff
Thomas S, Pszczolkowski
Defendant
DATE: Thursday, February 28, 2002
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(al 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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SHARON L, CORREA, A1K1A
SHARON L, PSZCZOLKOWSKI
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
THOMAS C. PSZCZOLKOWSKI
DefOlldwll
NO, 99-1953
CIVIL ACTION - LAW IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
AND NOW, r~~ cfl / .2002, comes the undersigned anamey for the plaintiff
and certifies to the Court that the a ve action in Divorce is at issue; that no issue has been directed by the Court to
be tried by jury, and therefore respectfully moves the Court for appointment of a Master, The following matters are
at issue between the plaintiff and the defendant:
(x ) Grounds for divorce; (x) Alimony Pendente lite,
( ) Support; Counsel fees;
(x ) Alimony; ( ) Paternity;
(x ) Equitable dislribution of ( ) Custody;
property; ( ) Other
A bifurcated Divorce Decree was entered November 13, 2001, Court has retained Jurisdiction of the
fol/owlng claIms: alimony, counsel fe..., costs and expen..es and equitable distribution,
Service of the complaint was made on the above named defendant on April 23, 1999 by First Class United
States Mail and Sheriff delivery~
An appearance on behalf of the defOlldant has been withdrawn by Slephen J, D, Zuranin, Esquire and
DefOlldant is pro se, The following anameys have been interested in other matters arising between the plaintiff
and defendant: Kathleen Daily, Esquire, Kirsten Reinhart, Esquire, "l
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Contest is not indicated, ~~.
Joanne Harrison Clough
Anomey for Plaintiff ,
AND NOW, if ~ <{AU ,..;? ~..- ,2002, r: JZ-/~.{f c;~tL d6A .
, Esq" is hereby appainf.,,] Master in this proceeding to hear the testimony ,md return the record
and a transcript to the Court together with report and recommendation,
BY THE COURT:
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SHARON L. CORREA, a/k/a
SHARON L. PSZCZOLKOWSKI,
PENNSYLVANIA
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
v.
: No. 99 - 1953
THOMAS C. PSZCZOLKOWSKI,
Defendant
: CIVIL ACTION. LAW
: IN DIVORCE
MOTION FOR HEARING ON PETITION FOR BIFURCATION
AND NOW this 2!2.'tGy of September, 2001 comes, Sharon L. Correa, by and througb
her attorneys Reager & Adler, PC, and requests a bearing on bel' Petition for Bifurcation for
bifurcation of tbe divorce in tbe above captioned matter and in support thereof avers as follows:
1, Plaintiff, Sbaron L. Correa, filed a Motion For Bifurcation on or about January 19.
2001.
2, A Rule to Show Cause was issued by the Court on January 22,2001.
3, Defendant Thomas C, Pzczolkowski filed an Answer on February 22,2001.
4, The parties subsequently agreed to settlement terms but Defendant has refused to
sign the settlement agreement.
3, Plaintiff filed a Potition for Contempt on or about
August 20/ 1999, duo to Defendant's wIllful failure to list the
marital home for sale after ho was unablo to refinance the
mortgage on the marital home pursuant to the terms of the Order
of Court dated June 10, 1999,
4. The parties reached an agreement relative to
Plaintiff's Petition for Contempt on August 31, 1999, the terms
of which Were incorporated into an Order of Court entered by the
Honorable Edgar B. Bayley, A copy of the Order of Court dated
August 31, 1999, marked Exhibit "B" is attached hereto and
incorporated herein.
August 31, 1999, "the parties agree that defendant, Thomas C.
Pszczolkowski, shall cooperate in the showing of the property and
5, Pursuant to paragraph 2 of the Order of Court dated
maintaining it in suitable condition for showings, Defendant is
in POssession of the real estate, and the major burden of
maintaining the property shall rest with him,"
1999, by Steve Thompson of PrUdential Thompson Wood Real Estate,
the listing agent handling the sale of the marital home, who
indicated that he felt the Defendant was "attempting to sabotage"
6, Counsel for Plaintiff was contacted on October 13,
the sale of the marital home in the following ways:
a. Defendant has refused to leave the marital
home during showings and follows the potential buyers
through the home, pointing out the home's deficiencies.
Showings, including but not limited to repairing a leak in the
garage and keeping the property neat and clean,
11, Defendant has willfully violated the Court's Order
of August 31, 1999, by failing to cooperate in the showing of the
property and maintaining it in a suitable condition for showings,
12, Defendant continues to refuse to leave the marital
home during Showings to potential buyers and to allow the
installation of a lock box on the property, despite the
recommendation of the listing agent.
13. Plaintiff believes and therefore avers that
Defendant's actions constitute an attempt to frustrate the sale
of the marital home,
14, Plaintiff believes and therefore avers that
Defendant's failure to cooperate with the recommendations of the
listing agent constitute an attempt to frustrate the sale of the
marital home,
15, Defendant's willful disregard for the terms of the
Court's Order of August 31/ 1999, has forced Plaintiff to spend
in excess of $500 on attorney's fees in the preparation,
drafting, and filing of this Petition for Contempt and Special
Relief.
WHEREFORE, Plaintiff respectfully requests this
Honorable Court:
SHARON L. CORREA a/k/a
SHARON L. PSZCZOLKOWSKI,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v,
CIVIL ACTION - LAW
NO, 99-1953
THOMAS C. PSZCZOLKOWSKI,
Defendant
IN DIVORCE
STIPULATION FOR AGREED UPON ORDER
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AND NOW, comes the Plaintiff, Sharon L. corre~F~/~a :~P-
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Pszczolkowski, and, in consideration of the Petition foj~\9peC'ial:':,~;
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Relief Pursuant to 23 Pa, C.S,A, 53323 (f) filed by the P-l~n&.i:ff:~
on April 27, 1999, and without admitting or denying any o~ th~ ~
Sharon L. Pszczolkowski, and the Defendant, Thomas C.
averments contained therein, stipulate as follows:
1. The Defendant shall continue to reside at 818
Indiana Avenue, Lemoyne, Cumberland County, Pennsylvania (the
"Property"), and shall continue to be responsible for the
payments of the mortgage on the Property.
2. The Defendant shall endeavor, in order to remove
the Plaintiff from the liability for the same, to obtain a
written financing commitment to refinance the loan to Commerce
1999.
Bank, which is secured by the Property, on or before June 25,
3, Within fortY-five (45) days after the expiration of
the time period set forth in paragraph 2 above, the Defendant
will close on the refinanCing of the Commerce Bank loan secured
by said mortgage on the Property, On or before said closing, the
Plaintiff agrees to sign a deed, and such other documents as are
SHARON L, CORREA,
a/kia, SHARON L.
PSZCZOLKOWSKI,
Plaintiff
IN THE COURT Of COMl10N PLEAS Of
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
v,
THOMAS C, PSZCZOLKOWSKI,
Defendant
NO, 99-1953 CIVIL TERM
IN RE: CONTEMPT
ORDER Of COURT
AND NOW, this 31st day of August, 1999, this matter
having been called on a petition by plaintiff, Sharon L,
Correa, to hold defendant, Thomas C, Pszczolkowski, in
contempt, and the parties having reached an agreement to
resolve the dispute, IT IS ORDERED:
1, The parties shall list the marital home located
at 818 Indian Avenue, Lemoyne, Cumberland County, Pennsylvania,
for sale with Steve Thompson of Prudential Thompson Wood Real
Estate, Mr, Thompson is currently scheduled to look at the
property on September 1st at 10:00 a,m" and both parties shall
cooperate in facilitating his examination of the property,
2, The parties agree that defendant, Thomas C.
Pszczolkowski, shall cooperate in the showing of the property
and maintaining it i~ suitable condition for showings,
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Defendant is in possession of the real estate, and the major
burden of maintaining the property shall rest with him,
3, Both parties shall have access to the real estate
agent, and they shall be updated through that individual as to
potential buyers.
4. Plaintiff's daughter, Ramona Rausch, who is an
agent for Prudential Thompson Wood Real Estate, shall not be
involved in the examination of the property or otherwise go
onto the p~operty personally to show the property to any
C;<h-,bt 1\5 //
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Thank )UU for your llllcntion 10 lhls maller, Any help you can 8i\~ me wouW be 81CII11y
appreciated,
clcly,
eve Thompmn
\~sociale Broker
mdcnlial Thompson Wood
REAL ESTATE AGENTS CALLS AND VISITS
nm rM.L VISIT AGF.NT R.:MARKS
lI'l/I~/'I'1 X BIl.L 101)Y SET APPOINTMENT fOR '1-15
11'1/1519'1 X GREG ROTHMAN 1 RSR THE COUPLE DOSE NOT SEAM VERY
INTERESTED IN THE HOUSE, GREG USE TO
WORK WITII SHARON, I fEEL HE WAS SENT
HERE TO CHECK TIflNGS Olrr.
11'1/24/99 X BILl. ZODY SET APPOINTMENT fOR 9-25
09/25199 X BlLLZODY SHOWS HOUSE
10/01/99 X BlLLZODY SET APPOINTMENT fOR 10/2
10102199 X BlLLZODY WOMEN SHOWS UP WITH 2 SMALL KIDS,
SHE DOSE NOT WATCH TIlEM TDO GOOD
AND THEY ARE RUNNING ALL OVER THE
HOUSE TOUCHING THINGS
10/09199 X ALICE ONEIL I TIlOMPSON CALLED AT NOON TO SHOW THE HOUSE
AT 4:00 PM AND DID'T LEAVE A RETURN
PNONE # - I WAS OUT Of TOWN
101lJ/99 X ALICE ONEIL I TIlOMPSON GAVE ME A BAD TIME ABOlrr SHOWING
TIlE HOUSE ON 10/15 , I TOLD HER I WAS
GOING TO A BOAT SHOW IN MO" SHE
TOLD ME TIlERE WAS NO BOAT SHOW
10114/99 X BILL ZODY SET APPOINTMENT fOR 10114
10/14/99 X SANDY ORT I DETWEILER JUST LOOKING
AGENT NOT ABLE TO WALK AROUND
TOO MUCH HAD ME HELP SHOW THE
HOUSE
10/18/99 X
10119199 X
10119199
11/01199 X
11/01199 X
11/01199
11101/99 X
11/02/99 X
11/02/99 X
11103/99 X
11105199 X
111117/99 X
11/07/99
11109199 X
11111/99
X
X
BILL ZODY APPOINTMENT SET fOR 10-19
BILL ZODY APPOINTMENT WILL BE LATE
BlLL ZODY SINGLE WOMEN JUST LOOKING
LAURA ZODY APPOINTMENT SET fOR II-I (2 HOUR NOTICE:
LAURA ZODY APPOINTMENT SET fOR 11-2
BOB HUGHES I GAUGHEN YOUNG COUPLE JUST LOOKING
BOB HUGHES I GAUGHEN APPOINTMENT SET fOR 11-2 AT 10:30 AM
BOB HUGHES I GAUGHEN SINGLE WOMEN JUST LOOKING
BILL ZODY SET APPOINTMENT fOR 114
BILL ZODY CANCEL APPOINTMENT SET fOR 114
THOMPSON WOOD REALTOR SET APPOINTMENT fOR 11-7
BILLZODY MAYBE AN APPOINTMENT 11-7
KEN DILTZ I THOMPSON WOMEN JUST LOOKING ') \ If.,. lol ~ s
PAULA 1 THOMPSON CALLED TO SET AN APPOINTMENT fOR 11-1 L
I RETURNED HER CALL AND SAID I WAS OUT
Of TOIVN THUR. I COULD SHOIV THE HOUSE
WED. fRI. (EVENING) OR ANYTIME SAT" SHE
NEVER RETURNED MY CALL.
LAURA ZODY I THOMPSON SET APPOINTMENT fOR 11-12
X
, DEFENDANT'S
, EXHIBIT '
X
111121')9 X OONNA FLETWO:)D IREMAX GUY JUST LOOKING
11I2~199 X PAULA / THOMPSON SET APPOINTMENT FOR 11.21.
11/26/')9 X PAULA / THOMPSON CANCEL APPOINTMENT
11126/99 X KEN / THOMPSON SET APPOINTMENT FOR 11.27
11/27/99 X KEN / THOMPSON OLDER COUPLE LOOKING
12/03/99 X PAULA I THOMPSON SET APPOINTMENT FOR 12.5
12/0~/99 X LAURA ZODY I THOMPSON SET APPOINTMENT FOR 12-6
12105/99 X ELIZ, KNOUSE I DETWEILER NEIGHBOR LADY JUST LOOKING
12105199 X PAULA I THOMPSON CONFIRM SHOWING FOR 12-6
12/06/99 X LORE1T A CAMPBELL I GUY JUST LOOKING
HOMESTEAD
12/14/99 X PAULA! THOMPSON SET APPOINTMENT FOR 12.1~
I2IJ~/99 X LEE SMITH I GAUGHEN COUPLE LOOKING
12/16/99 X BILL ZODY I THOMPSON SET APPOINTMENT FOR 12.18, DID NOT CALL
TO CONFERM
12/17/99 X BILL ZODY I THOMPSON SET APPOINTMENT FOR 12-18
12/18199 X BILL ZODY I 11l0MPSON COUPLE LOOKING
01/03/00 X KELLY I THOMPSON SET APPOINTMENT FOR 1-6 (NOON)
01/04/00 X LAURA I THOMPSON SET APPOINTMENT FOR 1-8 ( II AM)
01/05100 X BILL ZODY I THOMPSON SET APPOINTMENT FOR PHOTOS 1-6
01/06/00 X SCOTI I THOMPSON CANCEL PHOTO TAKING
01/06/00 X MUCHELLE/THOMPSON SET APPONTMENT FOR 1-6..., WILL CALL BAC~
01/06/00 X GALE ZELLERS I BROWNST. COUPLE LOOKING
01/06/00 X MICHELLE I THOMPSON SET APPOINTMENT FOR 1-6
:-iOTE: ~nCnF.l.LE IS STEVE TII0~IPSON
SECRETARy,sHESTATI:OTIIATl AM ALWAYS
COOPERATIVE IN SnOWING TIlE HOUSE
01/06/00 X W, scarr I COLDWELL COUPLE LOOKING
01/08/00 X C. BELLEM I THOMPSON COUPLE LOOKING
01/08/00 X S,DEVLIN I THOMPSON TAKE PHOTOS
01/19/00 X BILL ZODY I THOMPSON SET APPOINTMENT FOR 1-21
01/21100 X JOLLY I DETWEILER WOMEN LOOKING
01/31100 X KELLY/THOMPSON SET APPOINTMENT FOR 2-1
02/0 1100 X T,O'TooLE I GAUGHEN WOMEN WITH 3 KIDS LOOKING
02/09/00 X LAURA I THOMPSON SET APPOINTMENT TODAY IN 2 HOURS
02/09100 X J.CLARK I REMAX SINGLE WOMEN LOOKING
:mAIION L, COlllll';A, a/k/a,
SIIAllON 1" PSZCZOLKOWSK I,
Plalnti ff
IN 'I'IIE COUR'I' OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO, 99-1953 CIVIL
'1'1I0MAS C, Pf.iZCWl,KOWSK I,
Dofendant
CIVIL AC'I'ION - LAW
IN DIVORCE
PETITION FOR CONTEMPT
AND NOW comes th0 Petitioner, Sharon L. Correa, a/kia,
Sharon L. Pszczolkowski, hereinafter referred to as Plaintiff, by
and through her attorneys, the Law Offices of Silliker and
Reinhold, by Kristin R. Reinhold, Esquire, and respectfully
presents this Petition for Contempt, and in support thereof avers
the [ollowin9:
1. Plaintiff filed a Complaint in Divorce against the
Def:"ndant on or about April 6, 1999. Contemporaneously,
Plaintiff filed a Petition for Special Relief requesting the
Court compel the Defendant to list the marital home for sale, due
to Defendant's failure to make timely mortgage payments.
2. Prior to a hearing, Plaintiff and Defendant
executed a Stipulation for Agreed Upon Order which was entered as
an Order of Court on June 10, 1999, by the Honorable Edgar B.
Bayley. A copy of the Court's Order, marked Exhibit "A" is
attached hereto a~d incorporated herein,
3. Pursuant to Paragraph 2 of the Stipulation for
Agreed Upon Order, Defendant is to obtain a written financing
commitment to refinance the morlqaqn on the marital home in his
name solely on or before ./une! 25, 1999,
4, 1'0 dilt.e, Il,d end,)nt. has fa !led to prov ide Plaintiff
with il written flnancinq commitment. to refinance the mortgage on
the marital home.
5. Pursuant t.o Parilqraph 3 of the Stipulation, the
Defendant is to close on the refinancing of the mortgage on the
marital home within 45 doys after June 25, 1999,
6. Defendant hilS failed to close on the refinancing
of the mortgage on the marilal property to date.
7, Pursuant lo Paragraph 4 of the Stipulation, the
parties agree that they shall list the marital home for sale with
a real estate agent in the event Defendant fails to obtain a
written refinancing commitment by June 25, 1999 or fails to close
on said refinancing wilhin 15 days after June 25, 1999,
8. Defendant refuses to cooperate in the listing for
sale of the marital home.
9, Defendant is willfully violating the parties'
stipulation which was made an Order of this Court, by failing to
list the marital home for sale pursuant to the terms of the
stipulation,
10. In order for the parties to obtain the mortgage
and purchase the marital home located at 818 Indian Avenue,
Lemoyne, Cumberland COllnLy, Pennsylvania, Plaintiff had to place
a licn against hcr personal real pstatc, 10catcd at 226 Erford
Rood, Camp Hill, Cumbcrland County, Pcnnsylvania, which is pre-
marital property, Dnd pLcdge Lhe samc as collatcral,
11. Plaintiff is ill nced of funds to support herself
during the pendcncy of her divorcc action and is unable to borrow
against her rcal estate located at 226 Erford Road, due to the
licn against it involving the marital home located at 818 Indian
Avenue.
12. Defendant's willful disregard for thc terms of the
Court's Order of June 10, 1999, has forced Plaintiff to spend in
excess of $500.00 on attorneys fees in the preparation, drafting,
and filing of this Petition for Contempt.
WHEREFORE, Plaintiff respectfully requests this
Honorable Court:
A. Find the Defendant in Contempt of the Court's
Order of June 10, 1999,
B. Compel Defendant to cooperate in the listing and
sale of the marital home located at 818 Indian Avenue,
Lemoyne, Cumberland County, Pennsylvania,
C. Pay Plaintiff's attorneys fees in the amount of
$500.00, and
SHARON L. CORREA a/k/a
SHARON L. PSZCZOLKOWSKI.
Plaintiff
:11 THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYLVANIA
v.
CIVIL ACTION - LAW
NO. 99-1953
THOMAS C. PSZCZOLKOWSKI.
Defendant
IN DIVORCE
ORDER
AND NOW, this ~ day of
~
, 1999. IT IS
HEREBY ORDERED AND DECREED. that the terms and conditions of the
attached Stipulation For Agreed Upon Order. which is incorporated
herein by reference as if set forth in fUll. is approved and
adopted by the Court.
BY THE COURT:
Isl &Ir~ X3.~
J.
T"",: COpy FRIJM RECORD
/:1 T ,:;:. :', ,:1';'; nf, / i: c:' ';;1te ~9t my hand
d:,:d :,;,; ~:.al of .Bid Cuurt dt CarlislJ, Pa.
This...1.O,..i!:::." day OL"..~,,, ,.':.." 19...f.f.
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SHARON L. CORREA a/k/a
SHARON L. PSZCZOLKOWSKI,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
NO, 99-1953
THOMAS C. PSZCZOLKOWSKI,
Defendant
IN DIVORCE
STIPULATION FOR AGREED UPON ORDER
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AND NOW, comes the Plaintiff, Sharon L. Correa;.~/~a ~
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Sharon L. Pszczolkowski, and the Defendant, Thomas C. ~E; '7 :J2?
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Pszczolkowski, and, in consideration of the Petition fo~<SpeC':!.al:-~ii
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ReUef Pursuant to 23 Pa. C.S.A. 53323 (f) filed by the ~~nt.rff~ '
on April 27, 1999, and without admitting or denying any o~th~ ~
averments contained therein, stipUlate as follows:
1. The Defendant shall continue to reside at 818
Indiana Avenue, Lemoyne, Cumberland County, Pennsylvania (the
"Property"), and shall continue to be responsible for the
payments of the mortgage on the Property.
2. The Defendant shall endeavor, in order to remove
the Plaintiff from the liability for the same, to obtain a
written financing commitment to refinance the loan to Commerce
Bank, which is secured by the Property, on or before June 25,
1999.
3. Within forty-five (45) days after the expiration of
the time period set forth in paragraph 2 above, the Defendant
will close on the refinancing of the Commerce Bank loan secured
by said mortgage on the Property, On or before said closing, the
Plaintiff agrees to sign a deed, and such other documents as are
customary tor real estate transactions in the Central
Pennsylvania area, to transter her rights and interests in and to
the Property to the Defendant.
4. In the event that the Defendant: a. tails to make
any payment to Commerce Bank on or before any grace period
provided for in the mortgage documents; b. fails to obtain a
written financing commitment as set forth in paragraph 2 above
within the stated time period; or c, fails to close on the said
refinancing as set forth in paragraph 3 above within the stated
time period, the parties agree that the property will be listed
with a real estate agent, as agreed upon between the parties, and
if they are not able to agree, with the real estate agent
associated with Prudential Thompson Wood in Camp Hill
Pennsylvania, who has the highest amount of sales for the 1998
calendar year. The listing price shall be no less than
$170,000.00 and the term of the listing shall not exceed four(4)
months.
5, In the event the Property is sold pursuant to the
listing provided for herein, the net proceeds of the sale shall
be placed in escrow with a mutually agreeable escrow agent to be
distributed as the parties shall agree or as ordered by a court
of competent jurisdiction, each party specifically reserving any
and all rights to the same in the parties' above-referenced
divorce action.
6. The parties agree that this stipulation shall be
made an Order of the Court.
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'NT aUE
INII CUI:
REBAre INS
eSCROW AHT
LATE FEES
LOAN FEE:S
PREPYHT i'E:N
PAYOFF AHT
PAST CUE:
NEXT DUE:
LAST PYMT
PART!AL PO
SU.BCZ Pl'MT
LOllN AMT
ONADVANCED
NON-ACCR
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RES DUE
AMORT BAL
PE:R CLEM
1'6.~.2,"<l
117. .11
2,204.02
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145,056.09
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1,174,04
1,409.50
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~48,500.00
.00
.00
.00
,00
31,11523
Plaase note:
Dave Alnsden
cpr-rrRAC'1.: LJi'\ J. ~
AbVj\NCE: OATil:
':'t1RI'r'f DATE
s1' TRAil DA4E
rlHAINT DATE
st PRIll TRAil
P :Jb ?A:O TO
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A :a THRU DATE:
P ~TS ?AID TO
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The ~Ccount is now paid curranc; ne t
is due 6/1/99.
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Sll.l.IKER & REII'IIUI.D
ATTORNEYS If[ LAW ~
51)22 UNG1.ESTOWN ROAD'
~IARRISIJURO. PENNSYLVANIA 17112
TEI.EPIIONE (717) 611.1500
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14. Plaintiff asks Ihe court 10 exercise its equitable powers and direct Defendant to remove
himselfand his personal belongings from Ibe real property and to sign a listing agreemenl for Ihe sale
of the rcsl estate in order to preserve Ibe equity in the property from foreclosure,
WHEREFORE, Plaintiff, Sbaron L, Correa aIkIa Sharon L, Pszczolkowski, respectfully
requests Ihat this Honorable Court enter an order:
A, Directing Defendant to remove himself and all of his personal belongings from
Ibe real estate located at gIg Indiana Avenue, Lemoyne, Cumberland County, Pennsylvania, witbin
thirty (30) days of the date of this Order of Court;
D, Requiring Defendanl to execute a standard listing agreement for tbe sale oflbe
real property at a price agreed upon by the parties or, if unable to agree, a price fixed by Ihe selected
real estate agent;
C, Requiring Defendant to cooperate with the listing and showing oftbe marital
residence;
D, Requiring Defendant to cooperate fully and execute whatever documents are
necessary to effectuate a sale should a purchaser be found; and
E, Upon the sale of the home, distribute tbe proceeds in such a fashion as to
satisty all remaining joint debts of tbe parties, and deposit any remaining monies into an escrow
account until all equitable dislribution mailers in this case ore finalized,
Respeclfully submillcd,
DALEY LAW OFFICES
Katbleen Carey Daley, Esq 'e
Supreme Court I.D. No, 30078
] 029 Scenery Drive
Harrisburg, PAl 71 09
(717) 657-4795
Attorney for Plaintiff
VERI FICA TION
I verifY lhat the statements made in Ihis Petilion are true and correct. I understand tbat false
slatements herein are made subject to the penalties of 18 Pa,C,S,A, ~4904 relating to unsworn
falsification to autborities,
Date: ?5/77
"'faJPC.<,~)
/--. Sharon L, rrea aJkJa
Sharon L. Pszczolkowski
customary for real estate transactions in the Central
Pennsylvania area, to transfer her rights an~ interests in and to
the Property to the Defendant.
4. In the event that the Defendant: a. fails to make
any payment to Commerce Bank on or before any grace period
provided for in the mortgage documents; b. fails to obtain a
written financing commitment as set forth in paragraph 2 above
within the stated time period; or c. fails to close on the said
refinancing as set forth in paragraph 3 above within the stated
time period, the parties agree that the Property will be listed
with a real estate agent, as agreed upon between the parties, and
if they are not able to agree, with the real estate agent
associated with Prudential Thompson Wood in Camp Hill
Pennsylvania, who has the highest amount of sales for the 1998
calendar year. The listing price shall be no less than
$170,000.00 and the term of the listing shall not exceed four(4)
months.
5. In the event the Property is sold pursuant to the
listing provided for herein, the net proceeds of the sale shall
be placed in escrow with a mutually agreeable escrow agent to be
distributed as the parties shall agree or as ordered by a court
of competent jurisdiction, each party specifically reserving any
and all rights to the same in the parties' above-referenced
divorce action.
6. The parties agree that this Stipulation shall be
made an Order of the Court.
- 2 -
'1' ~H8 &17010 . WIK WENGER WEIDNEn-, P.g. :2
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flLOILO ,
I RL DISPLAY LOAN :1 BANK 0194
( FWD l- I
PERM RES ID MTe; FIXED 00033 3 3213 TO:-! PSZCZOLKO
LOAN BAL 146,542.70 C N RAeT DATE 11/:</97 L
INT DUE 717.41 A V~NCE DATE 11/14/97
INS DUE T RITY DATE 12/01/02
REBATE INS S TRAN DA'i'E OS/21/99
!:SCROW AMT 2,204.02 TAm "" 05/05/99
LATE S'EES .00 S PRIN TRAN OS/21/99
LOAN FEES : :'A:D TO 05/01/99
PREPYMT PEN .00 I r PAD TO 05/01/99
PAYOFF AMT 145,056.09 A :~ THRU DATE OS/23/99
PAST DUE .00 P ':>I S PAID TO 05/01/99
NEXT DUE 1,174.0< N ,~T DUE 06/01/m
LAST PYMT 1,409.50 L ~ T DATE 05121/99
PARTIAL PO .00 Rlo~HT TO CURE OO/OO/CO
SUBDZ PYMT .00 AlKlRT NEXT DUE: 06/01/99
LOAN AMT 148,500.00 ACCRUAL BASE 365/365
UNADVANCED .00 BR;'\NCH 2000
NON-ACCR .00 CLASS C1
MIN EARN .00 CO::'L CODE RE
RES DUE DIHECT/INDIR DIRECT ......
AMORT BAL .00 INT :RATE 07.'75000 90 180
PER DIEM 31.11523 NEGATIVE AMORT NO 0 0
Phase nota:
Dave Amsden
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1029 SCENERY DRIVE
HARRISBURG. PENNSYLVANIA 17109
(717) f>57-47~-5
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SHARON L. CORREA,
a/kIa, SHARON L.
PSZCZOLKOWSKI,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
THOMAS C. PSZCZOLKOWSKI,
Defendant
NO. 99-1953 CIVIL TERM
IN RE: CONTEMPT
ORDER OF COURT
AND NOW, this 31st day of August, 1999, this matter
having been called on a petition by plaintiff, Sharon L.
Correa, to hold defendant, Thomas C. Pszczolkowski, in
contempt, and the parties having reached an agreement to
resolve the dispute, IT IS ORDERED:
1. The parties shall list the marital home located
at 818 Indian Avenue, Lemoyne, Cumberland County, Pennsylvania,
for sale with Steve Thompson of Prudential Thompson Wood Real
Estate. Mr. Thompson is currently scheduled to look at the
property on September 1st at 10:00 a.m., and both parties shall
cooperate in facilitating his examination of the property.
2. The parties agree that defendant, Thomas C.
Pszczolkowski, shall cooperate in the showing of the property
and maintaining it in suitable condition for showings.
Defendant is in possession of the real estate, and the major
burden of maintaining the property shall rest with him.
3. Both parties shall have access to the real estate
agent, and they shall be updated through that individual as to
potential buyers.
4. Plaintiff's daughter, Ramona Rausch, who is an
agent for Prudential Thompson Wood Real Estate, shall not be
involved in the examination of the property or otherwise go
onto the property personally to show the property to any
SHARON L. CORREA. uIkIa.
SHARON L. PSZCZOLKOWSKI,
PlaintiIT
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY. PENNSYLVANIA
L
v.
NO. 99-1953 CIVIL
THOMAS C. PSZCZOLKOWSKI. : CIVIL ACTION - LAW
Defendant : IN DIVORCE
MOTION FOR CONTINUANCE
AND NOW comes the Plaintiff, Sharon L. Correa, a/k1a Sharon L.
Pzczolkowski, by and through her attorneys, The Law Officcs of SiIliker and Reinhold,
and respectfully presents this Motion for Continuance based upon the following:
4. Defendant's counsel. Steve Dzuranin. Esquire, has indicated that
I. Plaintiff filed a Petition for Contempt and Special Relief on or
about October 25, 1999.
2, A hearing has been scheduled before the Honorable Edgar B,
Bailey on November 12, 1999. at 9:30 a,m.
3, Plaintiff will be in Florida on November 12, 1999 and will not
return until November IS, 1999. due to a family mailer. Plaintiff is unable to change her
plans as she has already purchased airplane tickets,
he does not objcctto this continuance,
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A1TORN6VS AT LAW
5922 LlNGLESro:NN ROAD
HARRISnURO. PENNSYLVANIA 17112
TElEPIfONE(7J7) 67H5oo
NOV 1 Ii
SHARON L. CORREA a/kJa
SHARON L. PSZCZOLKOWSKI,
PLAINTIFF
V,
THOMAS C. PSZCZOLKOWSKI,
DEFENDANT
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY. PENNSYLVANIA
: 99-1953 CIVIL TERM
ORDER OF COURT
AND NOW, this 25th day of January, 2000, upon request of counsel, the
hearing scheduled this dated is continued to Wednesday, February 16, 2000, at 1:30
p,m., in Courtroom Number 2,
By the Court"
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Kristin R. Reinhold, Esquire
5922 Linglestown Road
Harrisburg, PA 17112
For Plaintiff
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Stephen J. Dzuranin, Esquire
508 North Second Street
Harrisburg, PA 17101
For Defendant
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9, There is no existing spousal support or alimony pmc/mf.'/ife claim and therefore
Defendant will suITer no prejudice of a divorce decree,
10, Since the divorce matter remains at issue as does the equitable distribution issue, no
prejudice would occur if a divorce were issued and the Court retained jursidiction of the
equitable distribution claim,
II. This Court is empowered to grant a divorce and reserve jurisdiction on the ancillary
economic issues of the matrimony case.
12. Concurrently with the filing oflhis document, Plaintiff has filed an affidavit under
3301 (d) under the Divorce Code as well as an Affidavit of Service,
WHEREFORE, Plaintiff requests this Honorable Court to bifurcate this matter so as to
permit the granting of a Divorce decree while retaining jurisdiction of the ancillary economic
issues.
Respectfully Submitted,
Dated: January 17,2001
REAGER & ADLER, PC.
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JO E H. CLOUG
Attorney I.D. No. 364 I
2331 Market Street
CampHill,PA 17011
(717) 763-1383
Attorneys for Plaintiff
SHARON L, CORREA, a/k/a
SHARON L, PSZCZOLKOWSKl,
Plaintill"
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: No, 99 - 1953
THOMAS C. PSZCZOLKOWSKl,
: CIVIL ACTION - LAW
Defendant
NOTICE
If you wish to deny any of the statements set forth in this Affidavit, you must file a
counter-affidavit within twenty (20) days after this Affidavit has been served on you, or the
statements will be admitted,
PLAINTIFF'S AFFIDAVIT UNDER
SECTION 3301(d) OF THE DIVORCE CODE
1. The parties to this action separated on d? J,jf I fr ,and have continued to live
separate and apart for a period of at least two ~
2, The marriage is irretrievably broken,
3, I understand that I may lose rights concerning alimony, division of property,
attorney's fees or expenses if! 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, ~4904 relating to unsworn
falsification to authorities,
Date: 1-(7- 0 I
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forth in the Plaintiff's Complaint, entering the divorce at this time may
effectively terminate that claim as to the Defendant.
9, Admitted in part and denied in part, Ills admitted that there is no existing
spousal support claim or alimony pendente lite claim made by the
Defendant. However, it is specifically denied that the Defendant will suffer
no prejudice by the entry of a divorce decree. To the contrary, entry of a
divorce decree will remove any remaining incentive of the Plaintiff to
finalize the equitable distribution and any other claims in the divorce
action, The Plaintiff Is currently represented by her fourth attorney since
commencing this case, The Defendant has made several settlement
offers to finalize the equitable distribution and other economic issues in
this case, the latest of which has been outstanding since September of
2000, The Plaintiff has refused to respond to that offer. Granting the
divorce will only serve to further stall the resolution of the economic
issues,
10, Denied, It is specifically denied that the granting of the divorce will not
prejudice the resolution of the economic distribution issue in the case, By
way of further answer, the Defendant incorporates his answer to
Paragraph 9 above herein by reference as if set forth In full.
11. Admitted, It is admitted that the Court is empowered to grant the divorce
and reserve jurisdiction on the ancillary economic issues of the matrimony
case. However, judicial economy requires that all issues be resolved
concurrently with the entry of a divorce decree, In the instant matter it is
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REAGER '& AOLER.6 P.C.
ATTORNEYS AT LAW
2331 MARKET STREET
CAMP HILL, PA 17011-4642
(7171763-1383
JAN 1 9 2aa1~
SHARON L. CORREA aJk/a
SHARON L. PSZCZOLKOWSKI,
PENNSYLVANIA
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
v,
NO. 99.1953
THOMAS C. PSZCZOLKOWSKI,
Defendant
Civil Action -Law
VERIFICATION
I, Stephen J, Dzuranln hereby verify that I have read the foregoing
Petition of Defendant's Counsel for Leave to Withdraw and hereby affirm and verify
that It is true and correct to the best of my knowledge, information and belief. I
verify that all of the statements made In the foregoing are true and correct and that
false statements made therein may subject us to the penalties of 18 Pa,C,SA
Section 4904, relating to unsworn falsification to authorities,
'/-'~~
, Esquire
Date: October 12, 2001
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SHARON L. CORREA a/kJa
SHARON L. PSZCZOLKOWSKI,
PENNSYLVANIA
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
v.
NO. 99-1953
THOMAS C. PSZCZOLKOWSK',
Defendant
Civil Action -Law
PETITION TO MAKE RULE ABSOLUTE
AND NOW, comes the Defendant's allorneys', Wix, Wenger & Weidner, and
Stephen J, Dzuranin, Esquire and hereby petitions this Honorable Court to make the
Rule To Show Cause issued in this mailer absolute and in support thereof states as
follows:
1, On or about October 15, 2001, the Petitioner filed a Petition of
Defendant's Counsel for Leave to Withdraw,
2. Pursuant to such Petition, this Honorable Court issued a Rule to Show
Cause why the relief set forth in said Petition should not be granted. Said Rule was
returnable seven (7) days after service,
3, On or about November 28, 2001, the Rule to Show Cause was sent for
service upon the Defendant, Thomas Pszczolkowski, by Certified Mail, return receipt
requested, Service was received by the Defendant on or about December 2, 2001 as
evidenced by the returned receipt, which is allached hereto as Exhibit "A" and is
incorporated herein by reference,
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SHARON L. CORREA, a/k/a
SHARON L. PSZCZOLKOWSKI,
PlaJntlff
v.
THOMAS C. PSZCZOLKOWSKI,
Defendant
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND CO.,PENNSYL V ANIA
: No. 99 - 1953
: CIVIL ACTION - LAW
: IN DIVORCE
INCO:ME AND EXPENSE STATE:MENT OF
SHARON L. CORREA
INCOME
Employer: Gracewood Groves
Address: Vero Beach. Florida
Type of Work: Telemarketinl!
Pay Period (weekly, biweekly, etc.): weekly
Gross Pay per Period:
Itemized Payroll Deductions
Federal Withholding
Social Security
Local Wage Tax
State Income Tax
Retirement
Savings Bonds
Credit Union
Life Insurance
Health Insurance
Other (specify)
Net Pay per Period:
$
280,00
$
$
20,03
21.42
1
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Other Income:
WEEK MONTH YEAR
Interest $ 1.00
Dividends
Pension $ 592,00
Annuity $ 500,00
Social Security
Rents $ 891.00
Royalties
Expense Account
Gifts
Unemployment
Comp,
Worker's Comp,
Child Support
Total 1 1 1.98400 1
TOTAL INCOME 1 2,222 55
EXPENSES WEEK MONTH YEAR
Home
Mortgage/rent $ 1,287,00
Maintenance $ 1,343,00
Utilities
Electric $ 62,00
Gas
Oil
EXPENSES WEEK MONTH YEAR
Telephone S 82,00
Water S 29,00
Sewer $ 55,00
Employment
Public
Transportation
Lunch
Taxes
Real Estate
Personal $ 67,00
Property
Income $ 26,00
Insurance
Homeowners
Automobile $ 51.00
Life $ 168,00
Accident
Health $ 278,00
Other
Automobile
Payments $ 258.00
Fuel $ 108,00
Repairs $ 67,00
Medical
Doctor $ 24,00
Dentist $1I2.00
EXPENSES WEEK MONTH YEAR
Orthodontist
Hospital
Medicine $ 38.00
Special Needs
(glasses, braces, $27,00
orthopedic
devices)
Education
Private School
Parochial
School
College $ 57,00
Religious
Personal
Clothing $ 45.00
Food $182.00
Barber/hairdresser $ 62,00
Credit Payments
Credit card $351.00
Charge Account
Memberships
Loans $ 877.00
Credit Union
Miscellaneous
Household help
EXPENSES
Child care
Papers/books
/magazines
Entertainment
WEEK
MONTH
YEAR
Pay TV
Vacation
Gifts
Legal fees
Charitable contributions
$ 138,00
$ 224,00
Other child support
Alimony payments
Other
Total Expenses
1
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6,01800 1
ll..llll
PROPERTY OWNED
DESCRIPTION
VALUE
OWNERSHIP
H W J
INSURANCE
COMPANY
POLICY NO,
COVERAGE
H W C
H (cancelled 11101)
Mutual of Omaha
ASSETS OF P ARTffiS
PlaintifT marks on the list below those hems applicable to the case at bar and itemize
the assets on the following pages.
C!'l 1. Real property
C!'l 2, Motor vehicles
o 3, Stocks, bonds, securities and options
o 4, Certificates of deposit
o 5, Checking accounts, cash
o 6, Savings accounts, money market and savings certificates
o 7, Contents of safe deposit box
o 8. Trusts
o 9, Life insurance policies (indicate face value, cash surrender value and current
beneficiaries
o 10, Annuities
o I 1. Gifts
o 12. Inheritances
o 13, Patents, copyrights, inventions, royalties
o 14, Personal property outside the home
o 15, Business (list all owners, including percentage of ownership, and officer/director
positions held by a party with company)
o 16, Employment termination benefits - severance pay, workers' compensation
claim/award
o 17, Profit sharing
o 18, Pension plans (indicate employee contribution and date plan vests)
o 19, Retirement plans, Individual Retirement Accounts
o 20. Disability payments
o 21. Litigation claims (matured and unmatures)
o 22, Military/VA benefits
o 23, Education benefits
o 24, Debts due, including loans, mortgages held
IIlI 25, Household furnishings and personalty (include a total category and attach
itemization list if distribution of such assets is in dispute)
IIlI 26. Other (boat)
MARITAL PROPERTY
PlaintilflislS all marital property in which either both spouses have a legal or equitable
interest individually or with any other person as of the date this action was commenced:
Item No. Description of Property Names of all Ownel'll Value
818 Indiana Avenue, Lemoyne HUSBAND and Transferred to
PA WIFE Husband
No equity
2 28' Formula Boat HUSBAND and
WIFE
NON.MARITAL PROPERTY
Plaintiff lists all property in which a spouse has a legal or equitable interest which is
claimed to be excluded from marital property:
Item No.
Description of Property
226 Erford Road, Camp Hill
Reason for Exclusion
Prior acquired asset
AIl of wife's property, real and
personal was acquired prior to
marriage or post separation
PROPERTY TRANSFERRED
Item No. Description of Property Date of Person to Consideration
Transfer Whom
Transferred
I Marital Home 5/9/00 H&WtoH $1.00
1818 Indiana Avenue
Lemoyne, P A
2 198628' Formula Boat 6/99 H sold to $29,500,00
third party (payoff $24,865,68)
(H received $4,634,32)
4, The Plaintiff and Defendant were married on August 17, 1996 in Camp Hill,
PeMsylvania,
5, Neither Plaintift"nor Defendant is in the military or naval service of the United States
or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Aet of the Congress of 1940
and its Amendments,
6, The cause(s) of action and section(s) of Divorce Code under which Plaintiff is
proceeding are:
A, Section 3301(a)(6), Defendant has offered such indignities to the
Plaintiff, the iMocent and injured spouse, as to render her condition intolerable and
life burdensome,
B. Section 3301(c), The marriage of the parties is irretrievably broken,
After ninety (90) days have elapsed from the date of the filing of this Complaint,
Plaintiff intends to file an Affidavit consenting to a divorce, Plaintiff believes that
Defendant may also file such an Affidavit.
C, Section 3301(d), The marriage of the parties is irretrievably broken,
The Plaintiff and Defendant separated on July 1998,
7, There have been no prior actions in divorce between the parties,
8, Plaintiff has been advised of the availability of counseling and that Plaintiff may have
the right to request the parties to participate in counseling,
9, The parties may enter into a written agreement with regard to support, custody,
visitation of children, alimony and property division, In the event that such an agreement is executed
by the parties, the agreement may be incorporated by the Court into the final Decree of Divorce,
WHEREFORE, Pleintift' requests your Honorable Court to enter a Decree in Divorce,
divorcing Plaintiff and Defendant.
COUNT II
EQUITABLE DISTRIBUTION
10, Paragraphs I through 9 of this Complaint are incorporated herein by reference as
though set forth in full,
II, Plaintiff and Defendant have acquired property, both real and personal during their
marriage from the date of their marriage until July 1998, the date of their separation,
12, Plaintiff and Defendant have been unable to agree as to an equitable division of said
property,
WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital
property,
COUNT III
ALIMONY
13, Paragraphs I through 9 of this Complaint are incorporated herein by reference as
though set forth in full.
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SHARON L. CORREA, alkla,
SHARON L, PSZCZOLKOWSKI,
Plaint if f
VA,
THOMAS C, PSZCZOLKOWSKI,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 99 - 1953 civil
IN DIVORCE
ORDER OF COURT
AND NOW, this
(c; fl1
day of
h...~L
2002, the Plaintiff having filed a praecipe on March 15,
2002, withdrawing the economic claims raised by the
Plaintiff and preserved in the divorce decree entered on
November 13, 2001, and there being no economic claims raised
by the Defendant, the appointment of the Master is vacated.
BY THE COURT,
cc:
~anne Harrison Clough
v Attorney for Plaintiff
,)fhomas C. Pszczolkowski
Defendant
7 ~::-::;r Rtf
tatl-C8L ILlLI
~tolo'HOLI Vd "11H dVjv:l
!31U!S U~Ir9l~ lttl
MY! !V SA3NUOUV
'Jd 'Y31OV . Y3!lV3U
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i
~R 1 9 2002