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HomeMy WebLinkAbout99-02263 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SANDRA M. ZEIGLER, Plaintiff NO. 99-2263 CIVIL TERM V. CIVIL ACTION - LAW IN DIVORCE LARRY G. ZEIGLER Defendant PRAECIPE OF TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301 (clof the Divorce Code. 2. Date and manner of service of the complaint: A. Date: November 16, 1999 B. Manner: Certified Mail, Restricted Delivery 3. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: a. Plaintiff: December 7, 2000 b. Defendant: November 20, 2000 QE Date of execution of the Plaintiff's affidavit required by Section 3301{d) of the Divorce Code and date of service of the Plaintiff's 3301 (d) affidavit upon the Defendant: a. Date of execution: n/a b. Date of filing: n/a c. Date of service: n/a 4. Related claims pending: No issues are pending. All issues have been resolved pursuant to the Marriage Settlement Agreement between the parties dated November 13, 2000 which Agreement is to be incorporated into but not merged with the Divorce Decree. 5. Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301(dl (I) (i) of the Divorce Code: a. Date of Service: n/a b. Manner of Service: n/a QE Date Waiver of Notice in Section 3301 (c) Divorce was filed with the prothonotary: a. Plaintiff's Waiver: December 13, b. Defendant's Waiver: November 3 , :; " ", SANDRA M. ZEIGLER, Plaintiff '~~i, --;', -.Il : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNlY, PENNSYLVANIA v. : NO. qf - ;22.&.3 ~ LARRY G. ZEIGLER, Defendant : CIVIL ACTION : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HA VB BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. Ajudgment msy also be entered against you for any other claim or reliefrequested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Dauphin County Courthouse, Harrisburg, P A IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (71 7) 249-3166 1-800-990-9108 8. Plaintiff has been advised that counseling is available and that she may have the right to request that the Court require the parties to participate in counseling. COUNT. DIVORCE: INDIGNITIES C ~:-: , .:. 9. The Defendant, Larry G. Zeigler, has offered such indignities to Plaintiff, the innocent and 'i: ; ',: injured spouse, so as to render her condition intolerable and life burdensome. ,,' ~:. :_i WHEREFORE, Plaintiff requests this Court to enter a Decree of Divorce dissolving the marriage between the parties pursuant to 23 Pa. C.S.A. ~3301(a)(6). " ,'l COUNT II DIVORCE: NO FAULT 10. The marriage is irretrievably broken; the parties separated June 9,1997. Wherefore, Plaintiff requests this Court to enter a Decree of Divorce dissolving the marriage between the parties pursuant to 23 Pa.C.SA ~3301(c) or 3301 (d)(I). COUNT II EOUlTABLE DISTRIBUTION OF MARITAL PROPERTY . (: :. 11. During the course of the marriage the parties have acquired various items of both real and personal property which are subject to equitable distribution by this court. WHEREFORE, Plaintiffprays this Court to equitably distribute the marital property pursuant to 23 Pa. C.S.A. ~3S02. COUNT IV ALIMONY PENDENTE LITE. COUNSEL FEES. COSTS AND EXPENSES 12. Plaintiff is without sufficient funds to support herself and to pay counsel fees, and the costs and expenses incidental to this divorce action. -4- 1r. C') ..1: .:1 t-- UJ0 N (.)." l':~. . "._1.. ~-.l..-_ c;);-; 8F :n -., [".1: (~_. L.-. ,-- C., ...;~ II 0", 0 0"' HM-'XI,UI'AO"ILO" OfHIItO~CY.IA1ddnS,.,:,',;.LlI,:,,jO'l';LO l!'t1S""" ;; ..;J ~ ~ V) < . .(J~ \~ .~ r<"\ C. .~ .' .re '" '--) :.; (\ <> : '. ~ e;~ VJ .1 ~ ~ ~ . ::~ \S- ., .-_..... ~ ~ .~. J r- 0- <.) - l:'- al tx:, (- ~\~ e:.c w 0 n: E o < ~~~ z ~ -J W lD ~ 0, W ... II V oJ m c( :n en)o to ~ M ~~WOXZI'" w'" z - ~ z c( CD w '" :> ex: I- . Q. r:. <( 0 Ul q . - a.I-OD..~ ~ lI) .( ~ ffi 0 ..J 11l [, ~ ~ < J: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SANDRA M. ZEIGLER, Plaintiff NO. 99-2263 CIVIL TERM V. LARRY G. ZEIGLER Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301{c) of the Divorce Code was filed on April 15, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated:()ru..?, ~ , ;~~~h >- \J:) E c;:; c /:.:.:: "'- tLi!:: 9 "":J --l'" ~~:;) I:': "- ~?; ~;-. , -- or.: (~'j:-l "'1':;:- :-'l~ .,.., ;2s! E~;'- '-."0) --1-... -- G:': <..J '1.:<: ~lJLU f::: t,..., ~~ Q I.I~ <::> ~j 0 <::, 0 ~ C") ~ N i',- M 5:!: ~o )....... :c '-'~ -q .,-;!. (L, il c).-' T C) 0 AS;: M ~:J~ ::- c.d.. L-... 0 ~. ,_. :z: :< u.. g a 0 ~ ..0 i=: ~:': c: z ~ 9 ~$ . . . - ~ ~_"21 :C t)?Z ,..:-..:. .- CI~ c. ':.)'C n ..:~: [j; E-~::' ~z: '-31 w :-()u.. ... \..0- ~O- 0 "",:: ~) . C> -) () c::> [) >- CO') ~ ~ N g~ ,- M ~R ,<- ::c -I) i5r~: Q,.. QI ~O <::l ~ )(;:; M ::J'. ::0- lE -.Ll/ u.. -. 0 rn (.,.- -. :z a u. <:> 0 <:) . , c- .. "- ", ". ~ ;' t~ ! ~~~. C , l',. ~.:l t, ~'.. , , t.:") 11!( -, (t... l r--:: c J -- "- J'. e) c . . ,::::~e ~~~ ~dl,;'~~Q3~~~ ~~i.~~./' I'" ii lU ~ II: < 0 3 ~ Z iii :r < ~ < ~ I/) oJ ~ 10 > 0 lU ~ II " ~ ~ ~ > m < Ul m ~ PI ~ " Z 1\J l/l > ~ 0 z ~ ~ ~ < al ~ ;: z ~ a. E; II Ul 0 .; ~ ~ 0 0: ~ 0 II Z ~ !2 ~ 0 I/) '" m r ::! ~ a. ~ ~ . < :I: . MILSPAW & BESHORE ATIORNEYS AT LAW 130 STATE STREbT P.O. BOX 946 HARRISBURG, PA 17108-0946 DAWN L. LlSI 717.236.Q181 FAX 717-2)6.07'J1 Imlllp.:.w@mblawnrm,com ., '''''' f, . 1.'...-". " " l' , ~ t# , LUTHER E. MILSPAW,jIt. MARVIN BESHORE February 11,2000 ~; ~ Curt Long, Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, P A 17013-3387 ) In re: Zeigler v. Zeigler 99-2263 Civil Action In Divorce Dear Mr. Long: " ;~ l': Enclosed is a Motion for Withdrawal of Appearance and Order for filing, along with a copy of same. Please time and date stamp the copy and return it to our office in the enclosed, stamped envelope. Thank you for your attention to this request. Very truly yours, MILSP A W & BESHORE "vt_JJ~ Elizabet . Gable Legal Assistant to Luther E. Milspaw, Jr. lepg LAW O"IC.. JOHN .. Mo\NCKI. PO. ftlCHAftD WAONlEft DAVID IE. HEft.HEY WILLIAM T. TULLY MANCKE, WAGNER, HERSHEY 8c TULLY IUI NO"T" '''ONT .T"lU """""..U"G. PA 17110 AftlACOOl,717 234.70151 November 30, 1999 E. Robert Elicker, Esquire 9 North Hanover Street Carlisle, PA 17013 Re: Zeigler v. Zeigler No. 99-2263 Dear Mr. Elicker: Enclosed herein please find the certification I signed regarding the above- captioned matter. The parties have met and I believe we are satisfied that we are aware of all the financial infonnation relevant to this matter, and therefore, I am not aware of any discovery that is outstanding. Your attention is appreciated. Sinc.c:relY.'/ // 6:i' ~/ [.. . P., charg agner PRW/dks Enclosure cc: Luther E. Milspaw, Jr., Esq. MR. MILSPAW AND MR. WAGNER, ATTORNEYS AT LAW 4 FEBRUARY 2000 PAGE 2 and, if necessary, schedule a hearing. Very truly yours, :~ E. Robert Elicker, II Divorce Master NOTE: Sanctions for failure to file pretrial statements are set forth in subdivision (cl and (d) of Rule 1920.33. THE ORIGINAL PRETRIAL STATEMENT SHOULD BE FILED IN THE MASTER'S OFFICE AND A COPY SENT DIRECTLY TO OPPOSING COUNSEL. FAILURE TO FILE PRETRiAL STATEMENTS AS DIRECTED BY THE MASTER MAY RESULT IN THE MASTER'S APPOINTMENT BEING VACATED. SANDRA M. ZEIGLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW LARRY G. ZEIGLER, Defendant NO. 99 - 2263 CIVIL IN DIVORCE NOTICE OF PRE-HEARING CONFERENCE TO: Diane G. Radcliff , Counsel for Plaintiff P. Richard Wagner , Counsel for Defendant A pre-hearing conference has been scheduled at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 10th day of JUly, 2000, at 9:30 a.m., at which time we will review the pre-trial statements previously filed by counsel, define issues, identify witnesses, explore the possibility of settlement and, if necessary, schedule a hearing. Very truly yours, Date of Notice: 3/30/00 E. Robert Elicker, II Divorce Master i (') ~ ('J ~~ '" 81 - ~ U--'" a.. . J- t=. ~i ~c- c:> ,~~ LLJI.'- M Fld >- ! ..1-...- c:> ~- ,.- x ~ c:> c:> ~ C') ~i N "" ~ ~~, ::C .~~ 0.- O~ 0 <::> 3~ Zf (") w . ~ :;,!t,.\.-. ~ U-:l:. ,-. :=: a ~ g FiLED-CHiC': OF T!-:~ PC:'): I :r;~::JrMW 99 NO'/22 Ai, 10: 86 CUM3::F,U .:J COiJNTY PENNSYLVAN'A .'>-- "'J Et: ,- U;. ,-- 1'.J5~) f) . . ..)a.. ; , r-r. f' - .. '. ,~ . , ~ : ,~ t r'; 0, I..L,,-. ~.-I , u.:~!., r:' C~ '/:.:: r,_ =1.; 0 en :'~i (J', '.J ",' .'1. (',:' ,.-" ,~\) I ' ~, -, ..- : O'j '''' , . , . '~J >' ~ Cl..:;\, F~:i";> . '-" ," :~. _I ", : ~ ,~tL\',,~";.\ SECTION I GENERAL PROVISIONS 1.01. INCORPORATION OF PREAMBLE The recitals set forth in the Preamble of this Agreement are incorporated herein and made a part hereof as if fully set forth in the body of the Agreement. 1.02. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS This Agreement shall not be considered to affect or bar the right of Husband and Wife to an absolute divorce on lawful grounds if such grounds now exist or shall hereafter exist or to such defense as may be available to either party. This Agreement ia not intended to condone and shall not be deemed to be condonation on the part of either party hereto of any act or acts on the part of the other party which have occasioned the disputes or unhappy differences which have occurred or may occur subsequent to the date hereof. 1. 03. DIVORCE DECREE The parties acknowledge that their marriage is irretrievably broken and that they will secure a mutual consent no-fault divorce decree in the above captioned divorce action. Upon the execution - 3 - of this Agreement, or as soon as possible under the terms of said Divorce Code if said documents can not be signed upon the execution of this Agreement, the parties shall execute and file all documents and papers, including affidavits of consent, necessary to finalize said divorce. If either party fails or refuses to finalize said divorce or execute and file the documents necessary to finalize the divorce, said failure or refusal shall be considered a material breach of this Agreement and shall entitle the other party at his or her option to terminate this Agreement. 1.04. EFFECT OF DIVORCE DECREE Unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final Decree in Divorce may be entered with respect to the parties. 1.05. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE The terms of this Agreement shall be incorporated into any Divorce Decree which may be entered with respect to them. 1.06. NON-MERGER This Agreement shall not merge with the Divorce Decree, but rather, it shall continue to have independent contractual significance and each party shall maintain their contractual remedies as well as court remedies as the result of the aforesaid -4- incorporation or as otherwise provided by law or statute. 1.07. DATE OF EXECUTION The "date of execution", "execution date" or "date of this Agreement" shall be defined as the date of execution by the party last executing this Agreement. 1.08. DISTRIBUTION DATE The transfer of property, funds and/or documents provided for herein shall only take place on the "distribution date" which shall be defined as the date of execution of this Agreement unless otherwise specified herein. 1.09. ADVICE OF COUNSEL The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, P. Richard Wagner, Esquire, for Husband, and Diane G. Radcliff, Esquire, for Wife. The parties acknowledge that they have received independent legal advice from counsel of their selection and that they fully understand the facts and have been fully informed as to their legal rights and obligations. They acknowledge and accept that this Agreement is, under the circumstances, fair and equitable and that it is being entered into freely and voluntarily after having received such advice and with such knowledge, and that "5 - execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. 1.10. FINANCIAL DISCLOSURE The parties confirm that each has relied on the substantial accuracy of the financial disclosure of the other, as an inducement to the execution of this Agreement and each party acknowledges that there has been a full and fair disclosure of the parties' marital assets and debts and the parties' respective incomes, which has been provided to each party. The parties further acknowledge that the financial disclosure has included the disclosure of the marital assets and debts set forth on the "Marital Distribution Sheet", attached hereto, marked Exhibit "A" and made a part hereof, and that it is the parties' intent to distribute those assets and debts in accordance with the distribution set forth therein. 1.11. DISCLOSURE AND WAIVER OF PROCEDURAL RIGHTS Each party understands that he or she has the right to obtain from the other party a complete inventory or list of all of the property that either or both parties own at this time oT. owned as of the date of separation, and that each party has the right to have all such property valued by means of appraisals or otherwise. - 6 - Both parties understand that they have the right to have a court hold hearings and make decisions on the matters covered by this Agreement. Both parties understand that a court decision concerning the parties' respective rights and obligations might be different from the provisions of this Agreement. Each party hereby acknowledges that this Agreement is fair and equitable, that it adequately provides for his or her needs and is in his or her best interests, and that the Agreement is not the result of any fraud, duress, or undue influence exercised by either party upon the other or by any other person or persons upon either party. Given said understanding and acknowledgment, both parties hereby waive the following procedural rights: a. Inventory: The right to obtain an inventory of all marital and separate property as defined by the Pennsylvania Divorce Code. b. Income and Expense Statement: The right to obtain an income and expense statement of the other party as provided by the Pennsylvania Divorce Code, except in instances where such an income and expense statement is hereafter required to be filed in any child support action or any other proceedings pursuant to an order of court. -7- c. Discovery: The right to have any discovery as may be permitted by the Rules of Civil Procedure, except discovery arising out of a breach of this Agreement, out of any child support action, or out of any other proceedings in which discovery is specifically ordered by the court. d. Determination of Marital and Non-Marital prooerty: The right to have the court determine which property is marital and which is non-marital, and equitably distribute between the parties that property which the court determines to be marital. e. Other Riohts and Remedies: The right to have the court decide any other rights, remedies, privileges, or obligations covered by this Agreement, including, but not limited to, possible claims for divorce, Spousal support, alimony, alimony pendente lite (temporary alimony), counsel fees, costs and expenses. J. . J.2 . BANKRUPTCY The parties hereby agree that the provisions of this Agreement shall not be dischargeable in bankruptcy and expressly agree to reaffirm any and all obligations contained herein. In the event a party files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party - 8 - shall have the right to declare this Agreement to be null and void and to terminate this Agreement in which event the division of the parties' marital assets and all other rights determined by this Agreement shall be subject to court determination the same as if this Agreement had never been entered into. 1.13. SOCIAL SECURITY BENEFITS The parties agree that, subject to the rules and regulations of the Social Security Administration, each of the parties shall continue to be eligible for Social Security benefits to which he or she would ordinarily be qualified as a party to a divorce after a marriage of ten (10) years or more in duration, if the parties' marriage is determined to be of ten (10) or more years in duration. 1.14. PERSONAL RIGHTS Husband and Wife may and shall, at all times hereafter, live separate and apart. They shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if they were unmarried. They may reside at such place or places as they may select. Each may, for his or her separate use or benefit, conduct, carry on and engage in any business, occupation, profession or employment which to him or her may seem advisable. Husband and Wife shall not molest, harass, - 9- disturb or malign each other or the respective families of each other nor compel or attempt to compel the other to cohabit or dwell ';~, " ,I~ by any means or in any manner whatsoever with him or her. 1.15. MUTUAL RELEASES Except as other wise expressly provided in this Agreement, Husband and Wife each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all pUrposes whatsoever, of and from the following: a. Claims Aoainst Prooertv or Estate: Any and all right, title, interest and/or claims in or against the other party, the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against such other party, the estate of such other party or the property of the other party or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other. b. Dower. Curtsev. Widows Riahts: Any and all rights and claims of dower or curtsey, or claims in the nature of dower or -10 - curtsey or widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will; c. Life Time Conveyances: The right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (I) the Commonwealth of Pennsylvania, (ii) State, Commonwealth or Territory of the United States, or (iii) any other country; d. Marital Riahts: Any rights which either party may have or at any time hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, equitable distribution, costs or expenses, whether arising as a result of the marital relation or otherwise. e. Breach Exce~tion: The foregoing shall not apply to all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is the intention of Husband and Wife to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only - 11 - except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provisions thereof. 1.16. WAIVER OR MODIFICATION TO BE IN WRITING No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 1.17. MUTUAL COOPERATION Each party shall, at any time and from time to time hereafter, take any and all steps and execute, acknowledge and deliver to the other party, any and all further instruments and/or document that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. 1.18. AGREEMENT BINDING ON HEIRS This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 1.19. INTEGRATION This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and - 12- negotiations between them. There are no representations or warranties other than those expressly set forth herein. 1.20. OTHER DOCUMENTATION Wife and Husband covenant and agree that they will forthwith (and within at least twenty (20) days after demand therefor), execute any and all written instruments, assignments, releases, satisfactions, deeds, notes, stock certificates, or such other writings as may be necessary or desirable for the proper effectuation of this Agreement, and/or as their respective counsel shall mutually agree, should be so executed in order to carry out fully and effectively the terms of this Agreement. 1.21. NO WAIVER OF DEFAULT This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. - 13 - 1.22. BREACH If for any reason either Husband or Wife fails to perform his or her obligations owed to or for the benefit of the other party and/or otherwise breaches the terms of this Agreement, then the other party shall have the following rights and remedies, all of which shall be deemed to be cumulative and not in the alternative, unless said cumulative effect would have an inconsistent result or would result in a windfall of the other party: a. Soecific Performance: The right to specific performance of the terms of this Agreement, in which event the non-breaching party shall be reimbursed for all reasonable attorney's fees and costs incurred as the result of said breach and in bringing the action for specific performance. b. Damaoes: The right to damages arising out of breach of the terms of this Agreement, which damages shall include reimbursement of all attorney's fees and costs incurred as the result of the breach and in bringing the damage action. c. Divorce Code Remedies: The right to all remedies set forth in Section 3502 (e) of the Pennsylvania Divorce Code, 23 PA. C.S.A. 3502{e), and any additional rights and remedies that may hereafter be enacted by virtue of the amendment of said -14- statute or replacement thereof by any other similar laws. d. Other Remedies: Any other remedies provided for in law or in equity. 1.23. LAW OF PENNSYLVANIA APPLICABLE This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 1.24. SEVERABILITY If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall remain valid and continue in full force, effect and operation. Likewise, the failure of either party to meet his or her obligations under this Agreement under anyone or more of the paragraphs hereunder, with the exception of the satisfaction of a condition precedent, shall in no way avoid or alter the remaining obligations of the parties. 1.25. HEADINGS NOT PART OF AGREEMENT Any headings preceding the text of the several paragraphs and subparagraphs hereof, are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor - 15 - shall they affect its meaning, construction or effect. 1.26. INCOME TAX MATTERS With respect to income tax matters regarding the parties the following shall apply: a. Prior Returns: The parties have heretofore filed joint federal and state returns. Both parties agree that in the event any deficiency in federal, state or local income tax is proposed, or any assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failure to disclose the nature and extent of his or her separate income on the aforesaid joint returns. b. Current Returns: The parties shall file individual Federal and State Income tax returns for the calendar year 2000. 1.27. PRESERVATION OF RECORDS Each party will keep and preserve for a period of four (4) years from the date of their divorce all financial records relating - 16- SECTION II PROPERTY DISTRIBUTION PROVISIONS 2.01. FINAL EOUITABLE DISTRIBUTION OF PROPERTY The parties agree that the division of all property and debts set forth in this Agreement is equitable and in the event an action in divorce has been or is hereafter commenced, both parties waive and relinquish the right to divide and distribute their assets and debts in any manner not consistent with the terms set forth herein and further waive and relinquish the right to have the court equitably divide and distribute their marital assets and debts. It is further the intent, understanding and agreement of the parties that this Agreement is a full, final, complete and equitable property division. 2.02. AFTER-ACOUIRED PROPERTY Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all property, tangible or intangible, real, personal or mixed, acquired by him or her, since June 1997, the date of the parties' marital separation, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or -18 - she were unmarried and each party hereby waives, releases, renounces and forever abandons any right, title, interest and claim in and to said after acquired property of the other party pursuant to the terms of this Paragraph. 2.03. WAIVER OF INHERITANCE Each of the parties hereto does specifically waive, release, renounce and forever abandon any right, title, interest and claim, if any, either party may have in and to any inheritance of any kind or nature whatsoever previously, or in the future, received by the other party. 2.04. PERSONAL PROPERTY With respect to the tangible personal property of the parties including, but without limitation with specific reference to, jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, tools, pictures, books, works of art and other personal property ("the Personal Property"), the parties agree as follows: a. Division: Husband and Wife do hereby acknowledge that they have previously divided the Personal Property. Hereafter Wife agrees that all of the Personal Property in the possession of Husband shall be the sole and separate property of Husband; - 19- and Husband agrees that all of the Personal Property in the possession of Wife shall be the sole and separate property of Wife. b. Waiver: The parties do hereby specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may have with respect to the Personal Property which shall become the sole and separate property of the other. 2.05. VEHICLES, BOATS AND THE LIKE With respect to the vehicles, boats, snowmobiles, motorcycles and the like owned by one or both of the parties, or the trade in value thereof, identified and valued on Exhibit "A", incorporated by reference hereto, ("the Vehicles") if the Vehicles have been sold or traded in prior to the date of this Agreement, the parties agree as follows: a. Wife's Vehicles: The 1991 Honda shall be the sole and separate property of Wife. b. Husband's Vehicles: The 1995 Accura and the 1994 Regal Boat shall be the sole and separate property of Husband. c. Identification: Identification of a Vehicle herein shall include not only the Vehicle, but also the sale or trade-in value thereof if it had been sold or traded in prior to the - 20- date of this Agreement. d. Transfer of Titles: The titles to the Vehicles shall be executed by the parties, if appropriate, for effectuating transfer as herein provided on the date of execution of this Agreement and said executed titles shall be delivered to the proper party on the distribution date. e. Title and Power of Attornev: For purposes of this Paragraph the term "title" shall be deemed to include "power of attorney" if the title to the Vehicle is unavailable due to financing arrangements or otherwise. f. Liens: In the event any Vehicle is subj ect to a lien or encumbrance the party receiving the Vehicle as his or her property shall take it subject to said lien and/or encumbrance and shall be solely responsible therefor and said party further agrees to indemnify, protect and save the other party harmless from said lien or encumbrance. g. Waiver: Each of the parties hereto does specifically waive, release, renounce and forever abandon whatever right, title and interest they may have in the Vehicles that shall become the sole and separate property of the other party pursuant to the terms of this Paragraph. - 21 - 2.06. REAL ESTATE The parties are the owners of a certain tract of improved real estate known and numbered as 1702 Locust Street, New Cumberland, PA ("the Real Estate") having an approximate value of $80,000.00 and which is encumbered with a mortgage having an approximate balance of $50,000.00 ("the Mortgage"). With respect to the Real Estate and the Mortgage the parties agree as follows: a. Convevance: Husband shall make, execute and deliver all documents in the usual form conveying, transferring and granting to Wife all of his right, title and interest in and to the Real Estate, and Husband agrees that he specifically wai ves, releases, renounces and forever abandons all his right, title and interest therein. The deed of conveyance therefor shall be executed by Husband on the Date of this Agreement And delivered to Wife for recordation on that date. b. Liens and Encumbrances: The said conveyance shall be subject to all liens and encumbrances including, but not limited to, the lien of the Mortgage and further shall be under and subject to any covenants and restrictions of record. Wife shall hereinafter be solely responsible for the payment of the Mortgage and shall indemnify, protect and save Husband ~ - 22 - harmless therefrom. 2.07. RETIREMENT AND PENSION PLANS With respect to any Pension Plan, Retirement Plan, IRA Account, Profit Sharing Plan, 401-K Plan, Keogh Plan, Stock Plan, Tax Deferred Savings Plan, any employee benefit plan and/or other retirement type plans of the other party, whether acquired through said party's employment or otherwise, identified and valued on Exhibit "A", incorporated by reference hereto, ("the Retirement Plans"), the parties agree as follows: a. W~ivpr: Hereafter the Retirement Plans shall become the sole and separate property of the party in whose name or through whose employment said plan or account is held or carried and each of the parties does hereby waive any and all right, title, interest and claim in and to the Retirement Plans of the other party except as specifically hereafter provided in this Section. b. F.x~pptinn tn W~;vpr: The foregoing notwithstanding, and as set forth on Exhibit "A" attached hereto and made a part hereof, Wife shall be entitled to receive as her sole and separate property the amount of $200.00 per month of Husband's Police Retirement Plan, together with any and all cost of living - 23- adjustments hereafter arising, to be paid to her effective the date of the entry of the divorce decree and pursuant to a Qualified Domestic Relations Order to be entered in the above captioned divorce action. Pending approval of the QDRO by the Plan Administrator and commencement of payments to Wife by that Administrator, Husband shall make the payments directly to Wife. It is further acknowledged and agreed that Husband's Police pension is being paid and shall continue to be paid in the form of a joint survivor's annuity thereby entitling Wife to payment of a specified sum or portion of husband's retirement upon his death in accordance with the terms of the Plan and the election. The QDRO shall also contain provisions requiring to continuation of the joint survivor's annuity election and the specifying of Wife as the surviving spouse for purposes of that election. c. T~x"''' llpnn Withdraw,,': If either party withdraws any sums from the Retirement Plans distributed to him or her pursuant to the terms of this Section, that party shall be solely liable for any and all taxes and penalties resulting from that withdrawal. - 24- 2.08. BANK ACCOUNTS/STOCK/LIFE INSURANCE The parties acknowledge and agree that they have previously divided to their mutual satisfaction all of their bank accounts, certificates of deposit, bonds, shares of stock, investment plans and life insurance cash value, identified and valued on Exhibit "Au, incorporated by reference hereto, ("the Accounts"). Hereafter Wife agrees that all the Accounts held in the name of Husband shall become the sole and separate property of Husband; and Husband agrees that all the Accounts held in the name of Wife shall become the sole and separate property of Wife. Each of the parties does specifically waive, release, renounce and forever abandon whatever right, title, interest or claim, he or she may have in the Accounts that are to become the sole and separate property of the other pursuant to the terms hereof. 2.09. TAX PROVISIONS The parties believe and agree that the division of property made to be made pursuant to the terms of this Agreement is a non- taxable division of property between co-owners rather than a taxable sale or exchange of such property. Each party promises not to take any position with respect to the adjusted basis of the property assigned to him or her or with respect to any other issue which is inconsistent with the terms of this Paragraph on his or - 25- her applicable federal or state income tax returns. 2.10. WIFE'S DEBTS Wife represents and warrants to Husband that since the . t parties' marital separation she has not contracted or incurred any debt or liability for which Husband or his estate might be responsible. Wife further represents and warrants to Husband that she will not contract or incur any debt or liability after the execution of this Agreement for which Husband or his estate might be responsible. Wife shall indemnify and save Husband harmless from any and all claims or demands made against him by reason of debts or obligations incurred by her. 2.11. HUSBAND'S DEBTS Husband represents and warrants to Wife that since the parties' marital separation he has not contracted or incurred any debt or liability for which Wife or her estate might be responsible. Husband further represents and warrants to Wife that he will not contract or incur any debt or liability after the execution of this Agreement for which Wife or her estate might be responsible. Husband shall indemnify and save Wife harmless from any and all claims or demands made against her by reason of debts or obligations incurred by him. 2.12. MARITAL DEBT - 26- During the course of the marriage, Husband and Wife have incurred certain bills and obligations and have amassed a variety of debts, identified and valued on Exhibit "A", incorporated by reference hereto ("the Marital Debts"), and it is hereby agreed, without ascertaining for what purpose and to whose use each of the Marital Debts were incurred, the parties agree as follows: a. Wi fR' Fl nRhtFl: Wife shall be solely responsible for the following bills and debts: 1. Any and all debts listed under the column designated as "Value to Wife" on the attached Exhibit "A"; 2. Any and all taxes resulting from her withdrawal of funds from her Retirement Plans set forth in Paragraph 2.07 herein; 3. Any and all other debts, liabilities, obligations, loans, credit card accounts, and the like incurred in Wife's sole name, and not otherwise provided for herein. b. HlI",band'Fl nl"htFl: Husband shall be solely responsible for the following bills and debts: 1. Any and all debts listed under the column designated as "Value to Husband" on the attached Exhibit "A"; 2. Any and all taxes resulting from his withdrawal of funds from his Retirement Plans set forth in Paragraph 2.07 herein; - 27- 3. Any and all other debts, liabilities, obligations, loans, credit card accounts, and the like incurred in Husband's sole name and not otherwise provided for herein. c. Ind~mnifi~~tion: Each party agrees to hold the other harmless from any and all liability which may arise from the aforesaid bills which pursuant to the terms herein are not the responsibility of the other party. d. C~n~~ll~tion of Joint nphtR: Any joint debt shall be canceled so that neither party can make any further charges thereunder, and if said charges are made in violation of this Agreement, then the party incurring said charge shall immediately repay the same. e. Non-niR~loR~d r,iahility: Any liability not disclosed in this Agreement shall be the sole responsibility of the party who has incurred or may hereafter incur it, and the party incurring or having incurred said debt shall pay it as it becomes due and payable. f. No FlIrth~r Joint n~ht: From the date of this Agreement, each party shall only use those credit card accounts or incur such further obligations for which that party is individually and solely liable and the parties shall cooperate in closing any remaining accounts which provide for joint liability. g. R~finan~~: In the event a party is assuming a liability for -28- 3.03. HEALTH INSURANCE The following shall apply regarding health insurance on the parties: a. H..alth Tn,,"ranc.. for 1':pnll"": Any party carrying health insurance on the other party shall continue to provide health insurance coverage on the other party until the date of the entry of the divorce decree. The party for whom that health insurance is provided shall be entitled to elect Cobra coverage under the other party's employment policy in accordance with federal rules and regulations provided that he or she shall be solely be responsible for the payment of the costs therefor. b. Heal th Tn,,"ranc.. fJoctlmentat;nn: Any party having the insurance coverage on the other party shall be required to provide the other party with all documentation pertaining to the insurance including, but not limited to, medical insurance cards, benefit booklets, claim submission forms and all statements pertaining to the determination of insurance coverage as to each claim made thereunder. THIS SPACE INTENTIONALLY LEFT BLANK - 31 - ITEM DESCRIPTION OF PROPERTY VALUE VALUE TO VALUE TO NO. OR LIABILITY Husband Wife l. REAL ESTATE AND MORTGAGES 1702 Locust Street 80,000.00 New Cumberland, PA Mtg on Locust Street lso.ooo eei a Net Equity for Locust 30,000.00 30,000.00 Street LIENS . . . '. .' . . 2. MOTOR. VEHICLES AND " . .,. . a.l Husband's 1995 Accura 11,800.00 11,800.00 a.2 WSFTCU Loan for Husband's (3,lOO.00) (3,lOO.00) Vehicle @342.00 per mo. b.l 1994 Regal Boat 32,000.00 32,000.00 b.2 Loan For Regal Boat (22, 500.00) (22,500.00) c Wife's 1991 Honda 7,000.00 7,000.00 (Insurance Value) 3. CHECKING ACCOUNTS AND ....... .... .. . . . .:i t ',".' ,.,. ,',,' . , ..: . . . ',',' CASH'.: .. , . . .. .' .. .' .:; " ,'.".,; , a Husband's PNC Checking 400.00 400.00 b Wife's Mellon Checking 188.66 188.66 I.. .. . ...' ...'..... .'. . ~. .1 -cc . "," . :-:- ... " 4. ~.lW;r~GS.Ac:c:OUNTS, .MONEY AAR~T?ANDSAVINGS .' . .- .. .. .' :'. CERTIFICATES . I. .' ., .' .: .. . '.. .' .. . . a Wife's Member's lB' 428.56 428.56 Savings Account b WSFTCU Savings Account Unknown Entire Value - 34- ITEM DESCRIPTION OF PROPERTY VALUE VALUE TO VALUE TO NO. OR LIABILITY Husband Wife 5. LIFE INSURANCE POLICIES a Wife's IDS (American Unknown Entire Value Express) Life Policy 6. PENSION PLANS a Wife's Blue Cross Pension 40,637.00 40,637.00 Plan 4/3/00 present value is b Husband's New Cumberland 1861.89/mo 1661.89/mo 200.00/mo Police Department Pension "',,,<, ." . '.' .7. H()l]SElIOLDGOODS .AND .' '., . FuRNISHINGS. .' ," . a Wife's Household Goods 5,465.00 5,465.00 B.. . CREDl;ir cARos . '.' .' .... a MasterCard (10,500.00) (10,500.00) b Sears 54-8413151048-0 (2,889.64) (2,889.64) 5/25/97 c Discover (1,950.00) (l,950.00) d Member's 1" Visa (3,604.75) (3,604.75) 4121-4499-9844-9032 6/97 e Corestates Premium Acct. (70.00) (70.00) 01-4902249-3 7/7/97 f Express (252.19) (252.19) 336-766-969 7/6/97 g Limited gold Card (346.11) (346.11) 203-065-347 7/30/97 h Optima True Grace Card (36.53) (36.53) - 35 - ITEM DESCRIPTION OF PROPERTY VALUE VALUE TO VALUE TO NO. OR LIABILITY Husband Wife 3730-292073-61005 6/12/97 i American Express (64.15) (64.15) 3720-364605-21002 6/17/97 j Boscovs (124.83) (124.83) 100698161 6/24/97 k Optima (1,347.73) (1,347.73) 3737-353356-21009 6/21/97 - 36- ....,',...'.,.,~...'-". SANDRA M. ZEIGLER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA i'i" .~;-! ;~ ~ ~ ~ ~ ~ v. v. : NO. 99-2263 : CIVIL ACTION LARRY G. ZEIGLER, Defendant : IN DIVORCE '. .'f, . PETITION FOR WITHDRAWAL OF APPEARANCE AND NOW comes Luther E. Milspaw, Jr., Esquire, and petitions for an Order permitting his withdrawal as attorney for Sandra M. Zeigler and in support thereof states the following: I. LutherE. Milspaw, Jr., Esquire is the attorney of record for SandraM. Zeigler in the above referenced divorce action. 2. Sandra M. Zeigler has discharged Luther E. Milspaw, Jr. as counsel of record and requested that he withdraw his appearance on her behalf. 3. Despite being advised to do so, Sandra M. Zeigler has not yet obtained counsel who has been willing to enter an appearance, although Mr. Milspaw has received correspondence from an attorney indicating that she was now representing Sandra M. Zeigler. A copy of that correspondence is attached hereto as Exhibit A. Mr. Milspaw has responded to that letter by a letter dated January 4,2000, attached hereto as Exhibit B. ,. , , SANDRA M. ZEIGLER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . , '/" v. : NO. 99-2263 LARRY G. ZEIGLER, Defendant . . : CIVIL ACTION . . : IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this II th day of February, 2000,1, Elizabeth M. Gable, Legal Assistant to Luther E. Milspaw, Jr., Esquire, hereby certify that I this day served the foregoing Withdrawal of Appearance, by depositing the same in the U.S. mail, postage pre-paid, at Harrisburg, Pennsylvania addressed as follows: Sandra Zeigler 100-E South First Street Lemoyne, P A 17043 P. Richard Wagner, Esquire Mancke, Wagner, Hershey & Tully 2233 North Front Street Harrisburg, P A 1711 0 E. Robert Elicker, Esquire 9 North Hanover Street Carlisle, P A 17013 Diane G. Radcliff, Esquire 3448 Trindle Road Camp Hill,PA 17011 MILSPA W & BESHORE Date: February 11, 2000 BY: rj,~ h1.A~ Eliz eth M. Gable Exhibit A i .. / \' . I' '. DIANE G. RADCLIFF 3448 Trindle Road Camp Hill, Pennsylvania 17011 Telephone (717) 737-0100 Voice Mail (717) 558-5518 Fax (717) 975-0697 December 20, 1999 P. Richard Wagner, Esquire 2233 North Front Street Harrisburg, PA 17110 Re: Sandra Zeigler v. Larry Zeigler Dear Rich: I have recently met with Sandra Zeigler who has decided to retain me to represent her in her domestic case. I would appreciate it if all future communication on this case be directed to this office. I have advised Attorney Milspaw this date of this change in representation. As soon as I receive his file, I will contact you regarding any additional information I may need to evaluate this case. In the interim, should you have any questions or comments pertaining to this letter, do not hesitate to contact me. Very truly \ DGR/dr Transmission by fax and mail cc: Sandra Zeigler :'f .,;~ ~~ ", W ~~ 2 .,," "'. :~ :~ 't .!" ~ , ~ .~! ( Exhibit B , .. ., J '- t .' - ~'-. , i J '.'~ , .1 CI <~) 6 w ~ 0: . 0 ~ ~ Z iii J: . w . , 1II oJ w \0 > 0 W ~ ~ v " W ~ 0\ > m . <J) ~ M ~ W x Z N '" > ~ 0 z ~ w . m " ~ z ~ a. ~ ~ <J) d ci " 0 a: ~ 0 ~ z II ~ M , 0 1II < m I ::! ~ a. it ~ ~ . J: , HM-ll'Ull' "'!).G'I~Il'",B [GllO' JIl-~'ltll o.n.l:lO~CY.\A~ns""o)'u"'1s.n... ,. FEB 2 2 2000LP '. '. Husband's income from his part-time job with the Cumberland County Sheriff's Department grosses him approximately $1,400.00 per month, with an approximate net income of $950.00 per month. Husband also has a pension through his fonner place of employment for which he receives $1,267.78 per month. Husband currently rents a property along with his girlfriend. II. ASSET~: The following are the primary assets of the marriage: Asset ValQt Lien A. The marital home situate at: 1702 Locust Street New Cumberland, P A 17070 $90,000.00 $50,000.00 B. 1999 Acura Integra $11,800.00 $ 3,100.00 Husband's vehicle C. 1996 Mercwy Unknown Unknown Wife's vehicle D. 1989 Regal Commador Boat $28,000.00 $22,500.00 E. Household furnishings $ 2,000.00 None '. '. AIm YIhIf .Ym F. Stereo Equipment, TV and Computer $ 750.00 -0- G. Appliances - washer, dryer and refrigemtor $ 600.00 -0- H. Hot tub $ 1,500.00 -0- I. Exercise Equipment $ 215.00 -0- J. Antique Desk of Husband Unknown -o- K. Lawn Equipment $ 400.00 -0- In Wife's possession L. Checking Account of Husband $ 400.00 -0- PNCBank M. Husband's Retirement through New Cumberland - 20% of which is non-marital $ N. Wife's Retirement through Capital Blue Cross and American Express Financial Advisors $ I 1 I , I I I I ._-"....'."....'.e'.'... '. .' III. MARITAL DEBTS: In addition to the aforementioned debts on the marital home, the boat and the car, there are the following debts: DeJlt Amoun~ A. Mastercard S 10,500.00 B. Sears Charge S 2,900.00 C. Discover Card S 1,950.00 IV. DQSBAND'S RETIREMENT: Husband bas a retirement through the New Cumberland Police Department for which he receives a monthly check in the amount of S 1,267.78. V. !NCOME AND EXPENSES: See the Income and Expense Statement filed by Husband. (Husband pays spousal support in the amount of $395.00 per month.) '. VI. PROPOSED RESO~VTION:: Wife's alimony claim would be denied since she is co-habitating with her boyfriend. The house be assigned to Wife who would assume the mortgage on the home, the boat would become the possession of the Husband, with the Husband assuming the indebtedness on the same. The parties would equally divide all other marital debts and any adjustment to which Husband would be entitled (because of the extensive equity in the home as compared to that of the boat) would be adjusted through the QDRO which would need to be put in place to distribute Husband's pension which is in pay status. Respectfully submitted, Mancke, Wa~r, Hershey & Tully /.r---) /:/.?-) ~y/ / //. ./ .' ard -ef, Esquire , .0. #23103 ( 2233 North Front Street L./ Harrisburg, P A 1711 0 (717) 234-7051 Attorneys for Defendant Date: 5t'l/~l) / I ~ M ~ ,." .. 8~ ~~ ~ :;:: :? ~ 0:';; '_ O.J ;~? ....>- In 3~ ~ rr:iE 0:: rein UJ "'" tIJu.. :a: .~ l:5 0 a 0 ;. ..:. '. Ii> W ...J ~ 0 z...J . (!) ~ E ~ ~ <<ll ~ n~~U u (/)1'Ia: Za:~5 <CWAX ~J: ~SETS OF PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. If an item has been appraised, a copy of the appraisal report is attached. ( ) ( ) (x) (x) ( ) ( ) ( ) ( ) (x) (x) (x) (x) (x) ( ) ( ) (x) ( ) ( ) ( ) ( ) ( ) ( ) ( ) ( ) ( ) ( ) 1. Real Property 2. Motor vehicles 3. Stocks, bonds, securities and options 4. Certificates of Deposit 5. Checking accounts, cash 6. Savings accounts, money market 7. Contents of safe deposit boxes 8 . Trusts 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) 10. Annuities 11. Gifts 12. Inheritances 13. Patents, copyrights, inventions, royalties 14. Personal property outside the home 15. Businesses (list all owners, including percentage of ownership, and officer/director positions held by a party with a company) 16. Employment termination benefits - severance pay, workman's compensation claim/award 17. Profit sharing plans 18. Pension plans (indicate employee contribution and date plan vests) 19. Retirement plans, Individual Retirement Accounts 20. Disability payments 21. Litigation claims (matured and unmatured) 22. Military/V.A. benefits 23. Education benefits 24. Debts due, including loans, mortgages held 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute) 26. Other ITEM NO. -2- DESCRIPTION: Exercise EauiD. VALUE:$215.00 DATE OF VALUATION 2/23/00 NON-MARITAL PORTION: AMOUNT/NATURE OF LIEN(S): None ITEM NO. 12- DESCRIPTION:Antiaue Desk (Defendant's familvl VALUE: unknown DATE OF VALUATION 2/23/00 > , NON-MARITAL PORTION: AMOUNT/NATURE OF LIEN(S): ITEM NO. 11- DESCRIPTION:Lawn EauiDment VALUE: $400. 00 DATE OF VALUATION 2/23/00 NON-MARITAL PORTION: AMOUNT/NATURE OF LIEN(S): None ITEM NO. 11- DESCRIPTION:Defendant's Checkina Acct. - PNC Bank VALUE: $400.00 DATE OF VALUATION 2/23/00 NON-MARITAL PORTION: AMOUNT/NATURE OF LIEN(S): PROPERTY TRANSFERRED 1 l Defendant lists all property in which either or both spouses have a legal or equitable interest either individually or with any other person and which has been transferred within the preceding three (3) years: ~ (") ~ .:> r ~ B<l; "' ~ :r. 7,; )~ Q.. ~ 85:! In ......Cl) O. 5z a:~!-l 0:: fez lW.u ~- "-" I CJ.. t.- :l: ~ lJ.. 0 0 c (.) ~ ." ; '..m_'''.~:_.,_,.., Automobile: Payments Fuel 342.00 80.00 20.00 Repairs Medical Doctor 25.00 Dentist orthodontist Hospital special needs (glasses, braces) Education 10.00 Private School Parochial School College Religious Personal Clothing Food 25.00 100.00 Barber / stylist Credit Payments Credit Card 15.00 540.00min. Charge Acct. Memberships 15.00 Loans ~> :.. "11 . t!.t~ r:h~:r f':"~~l l~,I:d:' r(:4 f.,,,,,,,> ~. r-:<"'i r'w~ I;.. j;;. l;::~~ r'I,~':'0 llj rr'~\ ~' ;:~,S~ Ii" i;;:! ''''+', ",', ./l,( ;:?- ",i;:: ~?1! f~~.~ ~r.:; ~{* ~~; ;.'.;! ::",ii ,yX\ ,;(fJ ','J. . . VERn'ICATION r verif:y e!1at ce statements made ill e.!le foreqoinq dOC'.]lIIent are true and correct. I understand cat false statements herein are made subject t~ the penalties of 18 Fa.C.S. Section 4904, relating to unsworn :alsi=ication to aut!lori ties. '-" ;/ / Dated: // ~'.r' (/ 1JClO COUNTY OF CUMBERLAND CARLISLE, PA. DIRECT DEPOSIT ADVICE NON.NEGOTIABLE No.892790 I ADVICE OF DEPOSIT - VOID*VOID NOT NEGOTIABLE VOID*VOID 206-34-8145 01227 LARRY G ZEIGLER 4071 REGIMENT BLVD ENOLA, F'A 17025 f-. , , 54.50 12.53 REGUL 682.89 2224.01 I OTHER PAY (PRIOR PERIODS) 75.20 TOTAL 682.89 2299.21 OW"toI:eIllJ'I:I:llJ 02/04/00 00892790. PAIDTHAQUCH DATE ~1/29/00 POSllJON . NET PAY -- SH8005 206.-34-8145 PNCBK 5001872663 510.46 DATE AMOUNT 02/04/00 ****510.46 CURRENT YEAR TO DATE RETNT 34.14 114.96 FIT 60.10 216.00 SWT 19.12 64.37 FICA 42.34 142..55 FICAM 9.90 33.33 EI35 6.83 22.99 OPT:!. 510.46 TOTAL 172.43 LARRY G ZEIGLER VACAT = 51.98 ! SHERIFF 594 .. ::~O { - eo. ~~ ~ ~ N ".,~ z ;,,; :c ;r .- ~ r;,1~ ;: I.. ".Q In ::50 ,.; Ii" ~- I.. ... n.:z (, :'14 0;. tJ.'lff! .,- oe: ,... :.; ..., t3 .3 i3 " .. '.. 0:>- w:Jmg Z :J .;:: Cll-.~ ~ ~ ell ~ ~ ...:> It: c5 ~ . >- ~ rr ~ W W :> ~~J: ~ U U) 1'1 a:: Z a: R 0:: <CW"~ ~J: " .. B , OTHER INCOMll. DESCRIPTION INTEREST DIVIDENDS PENSIONS ANNUITIES SOCIAL SECURITY RENTS ROYALTIES EXPENSE ACCOUNT GIFTS UNEMPLOYMENT COMPENSATION WORKMAN'S COMPENSATION INCOME TAX REFUNDS SUPPORT OR ALIMONY COMMISSIONS TIPS OTHER (SPECIFY) TOTAL OTliER INCOMll MONTHLY YEARLY 395,14 $395.14 PART III. PROPERTY OWNED 'mi.', J'~"'''1l'~,.,.r;",.~~\C!.''tM:NM1.1!'~~':<h. :t!.">1I}'1:'~l'>J'PI;,'~':'~'.}(.:ll.y/,.".';J.'.r,*,!U'~ '~\'1' \:U''''~ ;'~~>J.t;,:.t~~. !r'- p ODIR"""~""""n"~~~'f1fk"t,1!,\"r.":.,;'I\"I:iJj" F'" ::.' W ':~70""""~H"D 'q ""'If: ...i:r..,.._,~II;i:;lx.-::;;-~~,&.t.'.u~.q:~f,i~,~.!I':"N..m;\'M'(FiI ~~~,.\VIit.>S:~j;} 'c1:'.J!IJJ.....!..;.:;]..:WG ~m.;:l:", It TYPE DESCRIPTION VALUE H W JT CHECKING HARRIS MINIMAl. x SAVINGS MEMBER'S 1sT 35.67 x CREDIT UNION STOCKS/BONDS REAL ESTATE OTHER PART T.V. INSURANCE -~. . ,.. ~'. ""iI.MI' . ."."",~~. '""'~".lClrtJ"'\."'''~.' .~., ""~' ""(j~.,g..'i~~'1j'J:"f,ti;;;I'.~"i;(\ :.'i':'*"'''''''~'"~'i'''"~.' mum",. .' . . "" <:t'.. 'ii' . ~"'" . ~",.~.. ,. "",.. >~'H)~' ..~ ~';M .~~'1 ./COVRRl\:" . ,^ ~~ " ' ''fol: " .\!,t.... ":: ~h."r,U -,i'.tri.iI.: J.~tM(.ffi~WJ~ ~.f.;l:'t,c; i\ro-~'!~' il~ U.,IoII;o~..w...",,~' " .,',ifJ TYPE COMPANY POLICY NO. H W C HOSPITAL/SLUE KlIP 143454 X CROSS MEDICAL/BLUE KlIP 143454 X SHIELD HEALTH ACCIDENT DISABILITY INCOME DENTAL KlIP 143454 X VISION EDS 207346222 X OTHER-SPECIFY , i , i *H=Husband; W=Wife; J=Joint; C=Child 1 PART V. SUPPLEMENTAL INCOME STATEMENT [Xl CHECK HERE IF NOT APPLICABLE (a) This form is to be filled out by a person: (1) Who operates a business or practices a profession, or (2) Who is a member of a partnership or joint venture, or (3) Who is a shareholder in and is salaried by a closed corporation or similar entity. (b) Attach to this statement a copy of the following documents relating to the partnership, joint venture, business, profession, corporation or similar entity (check block to indicate the document is attached): (l) The most recent Federal Income Tax Return. (2) The most recent Profit and Loss Statement. attached attached (c) Name of Business: Business Address: Business Telephone: (d) Nature of Business (check one) [ ] l. Sole Proprietorship [ ] 2. Partnership [ ] 3. Joint Venture [ ] 4. Professional [ ] 5. Corporation [ ] 6. Other (e) Name of accountant, controller or other person in charge of financial records: (f) Business Income: 1. Annual income from business: 2. How often is income received: 3. Gross income per pay period 4. Net income per pay period 5. Specify deductions, if any: ;~.' ., 1~ f! K j; .4' :: (' .', :~i '~ ,. .l ,. ;., ., J ;i , ;,: ::1 i ~ d I verify that the facts set forth in the foregoing Income and Expenses Form, including all attachments thereto, are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C,S. 4904 relating to unsworn falsification to authorities. o DATE: ~:::/~!od j",~~ SANDRA M. Z. G E ' () '" MOl SOO t. L r: ! 561. 35 ,. 13,533.61 ! , ::~!:I! r' 028 ZEIGLER,SANDRA M CURRENT 723.94 Y.T.D 17,884.37 207346222 689.61 17,121.37 123.26 3,580.76 mm~T 74.25 GROSS*" ~~H! tn!Ei1~ . ;~~E,iD* Er1$ $.f(JO LEOACY DRIVE; H3-IA,.Q PLANa TEXAS lSCZ4 (17Z) $(U.6OCO DATA SYSTEMS 34.33 774.61 lU m~K)PLAN ~l~U ~fjA!~~ 1tB:la f~. STATEMENT OF EARNINOS AND OlDUCTtON3 028 207346222 11/05/99 MOl SOO ZEIGLER,SANDRA M ELECTRONIC DATA SYSTEMS- CURRENT 801. 94 764.49 148.43 37.45 616.06 Y.T.D 18,686.31 17,.885.86 3,729.19 812.06 14,149.67 liT 8U8 '!I:ll-I''''''"' 'l:jl .11"'" i~~:H GROSS** 88U2 I~~ ~j~~i ~!it~ ~:JUj OA ~ B D* 1HJg _!'.! ~LE~C:YQRIVE. H:.~.U p~ TElCAS 1SO:" (m, 6lUo6OCO 028 207346222 ZEIGLER, SANDRA. M CURRENT 798.28 760.98 Y.T.D 19,484.59 18,646.84 STATEMENT OF EARNINGS AND DEDUCTIONS MOl SOO . A ELECTRONIC DATA SYSTEMS 147.49 37.30 6~3.49 3,876.68 849.36 14,7 3.16 m~T 8U~ 7~qg mfKJPLAN 7~~: 2~ ~~H1~~it~ ~8~E~D* GROSS** -":'i':,> ,- . ".~~;"~.;' '~:!.."':~J. ",,"4ii!f'" :".,,; --',.:., !~~:;~,.,;;. .~ii~~-*:;.;, . ':~'_' ;_:","c!-:i.;~~l...-'" ':'-. -,. . IDS ua,.imAwollrn;H.JoZAolI'nAHo TDGVTJCtI#(mT"1Of.fOCD. .,". !ni tijf;~il~ lS4:~8 ~B~~ 1 JINf lJ61.98 280. . ~.. .:l:f. . I .~.~. d. :.~~_'.f.:' ~.. . I . ;~':.i {:~: .~.'. ~._o, <ARNI~:AHtJ .,.,.,20: -::-,<:- ..~ i , 028 207346222 l2/06/99 MOl SOO ZEIGLER,SANDRA M ELECTRONIC DATA SYSTEMs ClJRRENT 39nO 369.0~ 44.,0 ,0.97 3g4.9~ V.T.D 19,87 . 9 19,015.8 3,920. 8 8 0.33 15,0 8.0 EI~~T 40.00 :iU I"'" illl m~l~k~ JIlJi: GROSS*" O~ i~iP.~ EDS SIaJ UlMey O"'VI, H:J.ZA.., ".....NO TlXAs lsaU (m) I(U.SOOO STATEMIHT 0' tARN/NOS AND otDucnOfG 028 207346222 ZEIGLER. SANDRA M CURRENT 665.44 633.45 V.T.D 20,540.03 19,649.32 12/21/99 MOl SOO ELECTRONIC DATA SYSTEMS 113.14 31.99 520'21 4,033.92 902.32 15,608. 0 m~iET 68.25 GROSS*" 611~. ~ft m~K)PLAN 665: 44 D~~J~~ ~~ OA~~~ 8t A~D* !Ui mf:i~ 14H~ ~B~1 ::~t~ 1!D.s s.u:o LEGACY OR/VE. HJ.ZA.n PLANa TDGA.s lSOZ" (!11Z) GlU-~ Nrz TTnN Tn STATEMENT OF EARN/NOS AHO OEDUCTlONS 028 207346222 ZEIGLER,SANDRA M CURRENT V.T.D 1,174.80 1,174.80 Ol/05/00 MOl SOO o . NA ELECTRONIC DATA SYSTEMS 1,104.88 1,104.88 250.04 250.04 69.92 69-.92 .~T 1~U8 1,ng:88 m~K)PLAN 1,1k~8 ~~~~U~ ijgf{2~: ~N~ I~K)PLAN 19p~ ~~t1~~ . Jdg BuiliDr GROSS- "';'" ,~:., ,.:7~ ~:.:; ; ':~~::i\~': ~~'., ,'._ _ ,:.:. ~'~.06..:j., . '.. ..~~. :, ,..'~'~'''.:'~;2Y:~.:;~~ ' .::~-.' . . .. - "1$.:' .' . M.-_".~.~..:j . ... -~. ~::~}f.'1>')'"";~~:?~ . ., .~.....~:-':'"- . . 028 207346222 Mal soo ZEIGLER, SANDRA M ELECTRONIC DATA SYSTEMS CURRENT 7~3.6g 729.3g 138.92 ~4.28 l,UUS V.T.D 1,9 8.4 1,834.2 388.96 1 4.20 liT 8Ug ;;l!'1i U I"W :ll.ll GROSS** 1: I A ~i~~ . .. ~ oe ~ IDS s.QJ L!QACY DRIVE, Hj.ZA,.1Z "!.AHa TfXAS 150:4 (171' &u-4OI>> 02.8 ZEIGLER,SANDRA M 2.0734622.2 CURRENT 780.00 V.T.D 2,738.46 725.87 2,560.13 137.99 526.95 Ht~~iP.T 80.00 GROSS** 7~~J8 IfKJPLAN 780.00 Ht~ ~i\ N ~m~ . 8~ oe~HI ..... _ rr:.~ S4CO L.!GACY DRIVe, Hj.2A-1Z PLANQ TEXAS 15014 (Vl2J GlUofJOOO 02.8 ZEIGLER,SANDRA M 207346222. CURRENT 780.00 V.T.D 3,518.46 710.27 3,270.40 135.65 662.60 Ht~h:T 80.00 GROSS** 7~U8 ~~iKJPLAN 780.00 ~H ~ gn ~~~~ ij8~fOMH1 . ; . ~. . " .,:;-" .:.~~:~'~.-- .. ;. -~'f'~. '~';..:.'.*~;~~. .... lOS uoo L!'~CY DRIVE. H",ZA.IZ PIANO TEXAS TSat4 (1111 ~ .5TATtMlNTO' rAltH/No.s AND DlDUCT10~ ------------ . Mal SOO ELECTRONIC DATA SYSTEMS 54.13 178.33 587.88. 2,033.18 u:~g l~iPLAN ~H ~. ~ ~~ 1~1:iI CA OAS!~ ~~~~ll lk 2 STATEMENT OF EARN/No.s ANoomUC110HS Mal SOO ELECTRONIC DATA SYSTEMS 69.73 248".06 574.62 2,607.80 ~1Jg liJPLAN kg:, '~ 27'~ B~~ 2~~:~! CA OA~~ .. . . . .. , ~ :E;:,\~~~Z~' <.~1;;:;t,"~g~:.:<~?~-if . iTATDtI'NT.O"/lAItHING:IANtlDlrlUC770~~_ ).. 02!r 207346222 MOl SOO ZEIGLER,SANDRA M ELECTRONIC DATA SYSTEMS CURRENT 7.87.31 717.14- 137.50 70.17 579.U Y.T.O 4,305.77 3,987.54 800 .10 318.23 3,187. ~T 80.75 'II:!, mf""'" il:il 1;"" GROSS** 787.31 !~eiB ~U~ . ~~ ~ OMBr~ 2~~J, CA 0 ~, ED8 54CO LEGACY DRIVE, H3-Z,A.1Z PLANO TEXAS 7$(114 (f7Z' $04.fOOO ----------- . STATtMENT OF EARNlNG:S ANa DEDUCTlOm d Total number of exem trons claImed 7 Wages. salaries, tips, etc. Attach Form(s) W ~ 8a Taxable Interest. Attach Schedule B It reqUtr~': . b Tax..xempt interest. Do not Include on hne r<;, 9 OrdInary dividends. Attach SChedule B If reQ.J "ed 10 Taxable refunds, credits. or offsets 0' slate ('Ir.: leea, Income taxes (see Instructions) 11 Alimony receIved 12 Business Income or (loss). Attach Schecule : or C.EZ . . 13 CapItal gain or (loss). Attach Schedule 0 It f~qUlrea. If not requIred, checK here . 0 14 Other gains or (losses). Attach Form 4797 , . ..., ... . ...... ... . 15a Totar IRA distrIbutions. ....1 15.1 I b Taxable amount (see rnstrs) 16a Total pensions & annuities . ~~ b Taxable amount (see rnstrs) . 17 Rental real estate, royalties, partnerShips, S r:lroorat!ons, trusts, etc. Attach Schedule E 18 Farm income or (loss). Attach ScneduJe F . 19 Unemployment compensation ...,. 20a Social securily benefits ..... I 20al 21 Other income. list type & amount (see mSlrs) 22 Add the amounts In the far n ht colum~ lorl:~~; :; tlir~uah- 21.-Thl;t;' -ot7r totall;c;;me - ~ 23 IRA deduction (see Instructions) 23 24 Student loan Interest deductIon (see InslrUc::(,"S) 24 25 Medical savIngs account deduction. Attacn FO"J'''11 8853 2S 26 MOVing expenses. Attach Form 3903 26 Z1 One. half of sell.employm~nt tax. Attach Scn~'Jule SE Z1 28 Self.emoloyea health insurance deduction (se"l InstructIons) 28 29 Keogh and selt.employed SEP and SIMPLE :Ians 29 30 Penalty on early withdrawal at savIngs 30 31 a Alimony paId b Recipient's SSN . . 31.1 32 Add hnes 23 through 31a 33 Subtract line 32 from line 22. Th,s IS your adjusted gross income BAA For Disclosure, Privacy Act, and Paperwork Reduction Act Notice,s.. instructions. FOIAOI'2 1lJ16/99 '.",m 1 040 label (5.. '"Swellons.) Us. the IRS Ilbll, Otnerwlse. please prlnl or type. Presidential Election Clmpllgn (S.. IflstM:tloros.) Filing Status Check only one box. Exemptions It more than IX dependents. ,;ee Instructions. Income Attlch Copy B of your Forms W.2 Ind W.2G here. Also attach Form(s) 1099-R If tax was withheld. It you did not get a W.2. see Instructions. EnClose, but do not staple, any payment Also, please use Form 1040-V. Adjusted Gross Income E Oep.rtm.nl 01 ". Tr..wry - Inl..".1 Rhentjl S'Me. U.S. Individual Income Tax Return 199 IRS 11M CH'''", - Do nol ..r,l. or sbilll. In II., SUtl 1999 For the ear Jan 1.0ee 31. 1999, or other tax ear !'Jeanlnln Your Fir'1t HI",. MI LISI N...... . 1999. end,n OMS No 1545.00'" YIIllr 'oel., SKIl~ Hum".r Sandra II. Jo,"t R.k.lm, SpOlll.', F'f11 N.",. Zel 'ler ~nIN,.... M ., 207-34-6222 5pOll.... Socl., SUllnty Hllmblf Hom. Add,." '"",mb... lIrod strlll). If 'You 11..... II P 0 60' 5.. , '''""Clloros 206-34-8145 A Important! ... You must enter your SOCI81 security number(s) aDove. Ve, No "1I.rtm.nINo 100 S First Street City, Town or Post Olfln "'You Hav, . Forll9" Acldrns. S.. In~"..ebo"l E Sl.Itl ZlP COlli Lemo ne .... Do you want $3 to go to thiS fund? . . .,. It a oInt return. does our SPouse want $3 to Ill, 10 tnlS fund? Single Married filing ,oInt return (even II only one nad In::ome) Married tiling separate return. Enter SpOIl:;e's SSN aoove & fUll name here ~ La r r v G Ze 1 g 1 e r Head at household (Wltn qualifyIng persor",. (See Instructions.) If the QualIfyIng person IS a Child but not your dependent, enter thiS cnlld's name nere ~ QuaIl In WIdOW ef) with dependent ::nlll: rear soouse dIed ~ 19 ). (See Instrucllons.) Yourself. If your parent (or someone els~ can Clatm you as a decendenl on hIS or her tax return, do not cheCk box 6a b n Spouse PA 17043 HotI:o..ekll19 'Y".",llnolekal19' yourtlIO'''du;, you1,,"'......O x 1 2 3 4 5 6a ~NO.OIIIOJllS eft.eltadon . i. ..11111 ..- No.ofYOllf (4) I' :~~:~ on qu.lilyln!l child. IIv.d lot ch,ld tax MtiYOII I~~~~J:~:) e llld not UIlI wttl!yolldll.to divorceD,..". .ralonll.. Instnlctlonl) ~I c Dependents: (2) Deoenoent's socIal security numOer II (3) Oependenfs relatJonsl1lp to you (1) First name last name I_I I I D,pendsnl, o.icno, .11It.,... ,Iurvl AddllUmltl,. Int""'Oll . IIn...bolll I 8bl 7 8. I b Taxable amOllnt (see Instrs) 9 10 11 12 13 14 1Sb 16b 17 18 19 20b 21 22 26.219. 4.743, 32 ~ 33 26,219. Form 1040 (1999) Sandra M Zei ler 34 Amount rrom line 33 (ad,usted gross Income) 35. Check ": 0 You were 65/0ld8r, OSIII'ld: 0 Spouse was 65/0108(, 0 Blind. Add the number at boxes cnecked above Clnrl OJnter the total here .. 35. b It you are married frhng separately and YOLlr ~lJouse Itemizes deductIons IV1 or you were a dual-status al,en, see InstrucllO~ 1$ and cl1eck here , . .. 3Sb ~ 36 Enter your Itemized deductions trom SCnflaul,~ A, line 28, Or stlnd.rd deduction shown on the lett. But see Instructions to llnu -lour standard deduction II you cneCked any box on line 358 or 35b or If someone c:an r:lalm you as a dependunt ~ Subtract line 36 trom line 34 38 If line 34 IS $94,975 or re:iS, mulllply $2.750 by the lelJI n~rnber of exemptions claimed on line 6d. 111mB 34 1$ over $94.975, .see the ..wrksheelm the ,nstruchons lor thllJmounl !o enler . .. ,.... ..,... ... 39 Tax.ble income. Subtract line 38 trom hn~ 37. Jl hne 38 IS more than line 37, enter .0. 40 Tu (see Inslrs). Check if any tax tsfrom a OForm(s) !814 b o Form 4972 41 Credit for cl1ild and dependent care expenses. Attach r-,rm 2441 41 42 Credit tor the elderly or the dIsabled. AUac" :)t:hedule R . 42 43 Child tax credit (see Instructions) 43 44 Education credits. Attach Form 8863 44 4S Adoption credit. Attach Form 8839 45 46 Foreign lax credit. Attach Form 1116 If reouuEd. 46 47 Other. Check it from.,. BForm 3800 b (]Form 8396 c 0 Form a801 d Form (specify I _ 47 48 Add hnes 41 Il1rougl147. Tl1ese are your total credlh 49 Subtract tine 48 tram Une 40. If line 48 IS mOl t- than line 40, enter .0. 50 Self-employment tax. AI1ach Schedule So . 51 Alternative mInimum tax, Attach Form 625i 52 Social security and Medicare tax on tIP Income not reoorte110 employer. Attach Form 4137 53 Tax on (RAs, other retIrement plans, and II.$As. Anach Form 5329 It required. 54 Advance earned Income credit payments Irorn Form(s) W.2 55 Household employment taxes. Attach ScneClol" H S6 Add lines 49.55. ThiS is yOur totJI tll 57 Federal Income tax withheld trom Forms W,2 .:lnd 1099 58 1999 eslimaled tax payments and amount applied from '9!Jg return 59. EJmed Income credit. Attach Schedule EIC If you have.:. I!uahfyrng CMlld. b Nontaxable earned income: amount , . and type . ~ 60 Additional chlid tax c;eClit. AuaCh -F;;r;' 881;'7' - - - - - -- 61 Amount paid wllh request tor extension 10 fHe (see lM~llu:.lons) 62 Excess social security and RRT A tax WIlnneld (see mstrs) 63 Other payments. Check if from , 0 ~r)lm 2439 b 0 Form 4136 64 Add lines 57, 58, 59a, and 60 through 63. Tl1ese are your totalpavments ,. '............ "". , .. 65 If line 64 is more tl1an hne 56, subtract line 56 Irom IlMf';l ThIS IS the amounl you OvefJJJld 66a Amount of line 6S you want Refunded to You ~ b Routing number ~ d Account number fi7 Amount ot line 65 you want Applied to Your 2000 Estimlted Tu . __I 67 1 68 If line 56 is more than line 64, subtract Ime f,J from line 56. ThIS IS the Amount You I Owe. For details on how to pay, see InslruC!"1S . __ 68 1,086. 69 Estimated tax penaltv. Also Include on line :'~ ..1 69 I %fJWf&tim%ilMmW~@ftt&f&ti Und., p.nalti.,; 01 p.rrury. I declar. Ihat I have examined thiS rUm, ~nd ~ccomllanYlnl} sch.dules and slalem'nts. :lnd to tho besl 01 my knowlll'dI}' and belief. they are tnle. correcl. and comll!lll. O'clarahon olllr,p~rl!' (olner trI:ln tUDayer) .s. based on alt Inlorma\Jon 0' WhIch Drepar,r lias ~nr knowledl}' Form 1040 1999 Tax and Credits 5tlndlrd Deduction lor Mast , People Single: $4.300 Hoad ot household; $6.350 MaUltld tiling JOintly or Qualifying wJcJow(er): $7.200 Mamed tiling separately: $3.600 Other Taxes Payments Re(und Have it directly deposited! Soe instructilJns and flU In 66b, 66c, and 66d. Amount You Owe Sign Here JOint return? See InstructIOns, Keep a copy for your records, Paid Pre parer's Use Only S7 58 1. 760. 59. 60 61 62 63 . c iyoe; o CheCKIng ~ o SavIngs Your Signature Date YourOcCtJpatlon ~ Spouse's SIgn. lure. II a JOlnl Retur". BoUl Must Sll,n ~ Dal' Telemarketin Spouse', Occupation Prep.t.r's.... Sigl\lltute .... Firm'cName (at yours if Slrf..mployed) and Address jDat' I I Check tlself.emDlored n bead. .. Self-prepared FOIAO' ~2 11115199 207-34-6222 34 Pace 2 26 2]9. ~ 36 4.492. [ ., 21. 727 . 38 2.750. 39 18,977 . 40 2.846. 48 ~ 49 50 51 52 53 54 55 ~ 56 2.846. 2.846. ~ 64 65 66. I. 760. Oartlm,hlepllon, Number (opllonal) t*"'''~iW..%.W>:::::,-;;''':i.:W.''''Wi'WJi':>.' j,a'f1fit.w id~l~,dWllitf Jt*'m;:._%W.f:*'~t-t,:,:.tv@<<,~W;;;": Preparer's SSN or PTIN Form 1040 (1999) Sandra M Zeigler 1702 Locust Street New Cumberland, PA 17070 1998 U. S. INDIVIDUAL INCOME TAX RETURN SUMMARY Adjusted Gross Income Taxab I e Income Tota I Tax Tota I Payments Refund Effective Tax Rate $ 21.458 $ 12,508 $ 1,866 $ 2.060 $ 194 14.92 % INSTRUCTIONS FOR MAILING YOUR RETURN , Your federal Form 1040 shows a refund of $194, Please mail your return to the following IRS address postmarked by Thursday, April 15, 1999. ~ , ;, . Internal Revenue Service Philadelphia, PA 19255-0002 Be sure to sign and date your return and Include the proper amount of postage on the envelope. KEEP THIS PAGE FOR YOUR RECORDS -- DO NOT MAIL. ~.~i~;:~;~9~ '.~~..I~~..~.~~!~.nt 19 9 9 ',.." , ," .. _...........-.""_w.._~ '~.".;,,;~~2: ..,';;..;'r...;u:::::::::::::~~!i,(i~:~:.~iiiiii>.~!~~~:!ij~AL,;;.....;~.'u::I.."" "',' "i;~:~:- 'j ;':"'~:=~:'::~."::;9~ ~9 "I ~ AITE A'lii"H'DQR':r.'i:~RP "':'::"':Z')~~'2~~~34'i ....... ...,."'<<;..- ;".<",,,.~.;~,.,.,,,.,.; PD BOX 3USC ...........".... ... . . .~.~~,~.:.~,~."...."..... 113.:U IIARRU8URG PA Z07.34.~~1:! ~" ,-"';., ;.,',.;.;.." ,;> : ~., :,~':';",:;;;~~''''''''''''''''''''''. 11105 .........;.;..:.;.;:,. 182"~'~''''..1'.'.''''~'. 2'.'''' .."..........' ...,..................................... .............................."... "".'~~' ':;,.: ~~;..,;. ..~.;'~. ~.' ':'''<:.,,'';' .,'.-;., ',", ~^NDRA H lr!HiI.fIl 17l)l I.l)cun !n' Nnw CUMBERLAHD P^ 17070 !:l);", ,'. u.. .........,......................... :,...,.\.........:--0,. .........,................... : :'.' '.:{}~ ,,'. ;'" : ',., ," '~ ':'/' ......,.......i",::.. 1826.25 Sl.lfi 1403 23.\2 WSI ''''.., .... CtLl'j:.! rlJ !in F;Jl'ttl ;>Iron t:~Ir:I~-\'~ 1 ~h::Cl il;:;'~l:1t l'H 1;1'1111:': ':;:.' .. 2!i21 ............................ ..... ,,' ;..(, ,:,.": ll'~ RlTr: ^IO IIt1tJiH$ CORP PO 'OX 3165 tlARR1S8URG f'^ 111 n.s ., f!.\"l:1I)U.s.tZ ....-..:;.;;.,..:~,. 207-3f'i . (,1i::Z "...., ,h.' '_.".. ..'................".. "";:~":. ~~ , '; :,. ," :'. SAHlllM K ZErGLE~ n02 l.OCUST 51 HEW CllHIIE:iU.AHl) rh 171170 '.:'~.::'~'" ' ..7.::::.:::;.;"'::.;:.~......;.,.... ... ,. . " .,'::; ,:.~:~.::~..::~::............,.... : 'd ';.,' :'.. ?~..."...~..~.~'~':i.:!oli'" . 1026.25 , 51.1~ ':::.~-2 \-'g,' .n~.:,:~~.~;~;~~~~~~::~:.:J._9...~....::::::..:..:.......,.'..: '.:'. W$l OMB No. 1545.oooa a Controlnumoe, 11 Wa;u. trcs. oli'9&491:'3 b Eme!,oyer's Iden~llcauon ~umlle' SCCl3l stQlnly2"!l'4' 2 2 . 7 7':> 2548221 D' o EmclOV&e s SOCl3l S8Qjn~ numOet 5 Mea:C3re wa9&S and lips 207 34 6222 20422.7 ''i;''''L'Ec't'1Hi'm:'C''8'A'TA SYSTEMS 5400 LEGACY DRIVE r . NO TX 75024 10~~nfC3ntbenetits 11 NonQUall'iedC1ans a Emolo~sr.ame.adatllss.andZlPCOCll -028 ~207346222- SANDRA M ZEIGLER APT. E 100 S. 1ST STREET LEMOYNE PA 17043 15S14llUIOrv .m..,.. o<<..,.a O,It".., -"~ 199916~IA' E W.2 Wage and Tax .2: Statement Copy C tor EMPLOVEE's RECORDS laStalulcometalt 571.8 20 LoeaJ "J. ~_ 20551.6 1&2':L25 JB:M.W; 1:','. "':"',,.; U1U.;!C; 18Z6.2!i :., ~ .".... -'" ....... tn.2" .....,:'"..., '!P.SY 11.!.:3 16."''' ...................... ltJ2t:.25 U. Z7 ......................... [;~.I..m...~~1 oi' ~:1I1 ~;.".w:r. .:nI~r''"'1 ~~::...ol ~to-"..>> 2 Fe<lefaIlncomel3ltWlllID8lcl 1684.22 ~ Sooalsecuntyt3lCWltlllleld l266.21 6 M&alCa/'8taxWltnheld 296.13 7SOClaJsecurnytIPS BAIIocaflKltlOS 9 AdvanceEJCpaymenl 12 8en8Ms u'lC:uded in f)OlC 1 11.61 13 S17lnliftS. 'or boll'" 3.44 14 Other 11 SllIllwageS.!ll:Is'lIlC. 20422.76 19 L.oca!!!)'name MECHANICSBRG 21 LotaIlrcome flU 205.52 1 panmenl U. rwUUf't-lntemal evenue This~ISbllnqfumilhedlOlhetntMn&l R~s.Mc8.lI'you'" requi~ to III a tax filUm, . M9figenco penaIry or oItNtt sancflOn may III , __u_ __ ._......... ;..__.. toO ..._..'" ..... ".... l.~ ,,. _" DIANE G. RADCLIFF 3448 TRINDLE ROAO CAMP HILL. PA 17011 17171737-0100 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SANDRA M. ZEIGLER, Plaintiff V. LARRY G. ZEIGLER Defendant NO. 99-2263 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE CERTrFICATION OF SOCIAL SECURITY ~ERS In accordance wi th the Rules of Civil Procedure, I, Diane G. Radcliff, Esquire, Attorney for the Plaintiff, hereby certify that the social security numbers of the parties are as follows: 1. Plaintiff: 207-34-6222 2. Defendant: 206-34-8145 Respectfully Road Hill, P A 17011 urt ID # 32112 Phone: (717) 737-0100 Fax: (717) 975-0697 Attorney for Plaintiff >: r- E 0__ c ~ J_ W_l~'~: 6 ::>::;:; C.117 ;~~(I (~)~ " .,.... )~ (~: ~ ,'") '. -f) ::~l ' .~;.:.= -- j"Z c c..: ,ill:a ,-, , -"'a.. Cl """- 1'- 0 :::> I~) 0 U .. ' SANDRA M. ZEIGLER, Plalatllf : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 99-2263 : avn. AcrION LARRY G. ZEIGLER, Defendant : IN DIVORCE PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO TIlE PROTHONOTARY: Please withdraw the appearance of LUTHER E. MILSPAW, JR, Esquire, as counsel for Plaintiff in the above captioned matter. Respectfully submitted, Dated: February 8, 2000 BY: Luther E. Milspa ,Jr., Esquire 130 Stale Street P.O. Box 946 Harrisburg, PA 17108 (717) 236-0781 Supreme Ct. # 19226 Attorney for Plaintiff - . SANDRA M. ZEIGLER, Plalntlll' : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. . . : NO. 99-2263 : CIVIL ACrION LARRY G. ZEIGLER, Derendant . . : IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this 8th day of February, 2000, I, E1izabeth M. Gable, Legal Assistant to Luther E. Milspaw, Jr., Esquire, hereby ccrti1Y that I this day served the foregoing Withdrawal of Appearance, by depositing the same in the U.S. mail, postage pre-paid, at Harrisburg, Pennsylvania addressed as foUows: Sandra Zeigler 100-E South First Street Lemoyne, PA 17043 P. Richard Wagner, Esquire Mancke. Wagner, Hershey & TuUy 2233 North Front Street Harrisburg, P A 17110 E. Robert Elicker, Esquire 9 North Hanover Street Carlisle, PA 17013 Date: February 8, 2000 BY ~ hr.~, E' M. Gable SANDRA M. ZEIGLER, IN THE COURT OF COMMON PLEAS OF Plaintiff : . CUMBERLAND COUNTY, PENNSYLVANIA . . NO. 99 - 2263 . vs. CIVIL ACTION - LAW LARRY G. ZEIGLER, . . Defendant IN DIVORCE ORDER AND NOTICE SETTING HEARING TO: Sandra M. Zeigler Diane G. Radcliff Plaintiff , Counsel for Plaintiff Larry G. Zeigler P. Richard Wagner , Defendant , Counsel for Defendant You are directed to appear for a hearing to take testimony on the outstanding issues in the above captioned divorce proceedings at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania on the l7th day of November ,2000, at 9:00 a.m., at which place and time you will be given the opportunity to present witnesses and exhibits in support of your case. r, President Judge Date of Order and Notice: 7110/00 By: Divorce Master IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA l7013 TELEPHONE (7l7) 249-3166 i> ( .,1 I ., , SANDRA M. ZEIGLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 99 - 2263 CIVIL ~~RY G. ZEIGLER, Defendant IN DIVORCE RE: Pre-Hearing Conference Memorandum DATE: Monday, July lO, 2000 Present for the Plaintiff, Sandra M. Zeigler, is attorney Diane G. Radcliff, and present for the Defendant, Larry G. Zeigler, is attorney P. Richard Wagner. This action was commenced by the filing of a divorce complaint on April l5, 1999, raising grounds for divorce of irretrievable breakdown of the marriage and indignities. Counsel have indicated that the parties will sign and file affidavits of consent and waivers of notice of intention to request entry of divorce decree prior to the hearing to be scheduled in these proceedings. The complaint also raised the economic claims of equitable distribution, alimony, alimony pendente lite, and counsel fees and expenses. With respect to the alimony claim raised by wife, her counsel has indicated she will probably withdraw that claim and counsel will file a praecipe with the Prothonotary indicating that withdrawal. Consequently, we are left with the equitable distribution claim and the counsel fees and expenses issue. separated June 9, 1997. They are the natural parents child, Heather, born June 6, 1979, who is emancipated. has two children from a prior relationship and husband three children from a prior relationship. The parties were married on June 4, 1977, and of one Wife has Wife is 56 years of age and resides at lOO E South First Street, Lemoyne, Pennsylvania, where she lives with a male friend. She is a high school graduate. Her current employment is with EDS Corporation as a PIC verifier. Her net monthly income is $l,273.74. She is currently paying for her medical insurance coverage in the amount of $22.93 biweekly. She has not raised any health issues. Husband is 55 years of age and resides at 407l Regiment Boulevard, Whelan Crossing, Enola, Pennsylvania, where he lives with a female friend. He is a high school graduate and is receiving a pension payment from his prior employment with the New CUmberland Police Department. The benefit payable monthly to him is $l,663.24. Currently he is working part-time as a deputy sheriff with the Cumberland County Sheriff's Department and nets approximately $950.00 monthly. He is currently paying for his medical insurance the sum of $l35.l0 per month. Husband has not raised any health issues. 3 Wife is receiving spousal support from husband in the amount of $395.46. The parties own a residence at l702 Locust Street, New Cumberland, Pennsylvania, which counsel are going to have appraised. Currently the home is subject to a home equity loan with an approximate payoff of around $53,000.00. Wife's son and family, from a prior marriage, are living in the home and we are uncertain as to whether the son is making any payments to wife as an occupier of the residence. He is supposedly doing repairs on the property but there has been no evidence provided as to what, if any, he has expended in terms of labor and materials for repairs. Apparently wife is paying the home equity loan to Mellon Bank in an approximate amount of $600.00 monthly plus paying the taxes and insurance. Included in the appraisal will be an opinion by the appraiser of the rental value for this property. , , f Wife has a 1996 Mercury v~hicle which she purchased after separation as a result of an accident with the marital vehicle, a 1991 Honda. She received $7,000.00 as a settlement with the insurance company which is the value we are going to use for that vehicle. Husband has a 1995 Acura Integra which has been stated on the pretrial statement with a value of $ll,300.00 and a payoff of around $3,lOO.00. Apparently there is a loan for the vehicle with the West Shore Federal Credit Union which husband is paying in the amount of $342.00 per month. Counsel can value the vehicle using any books that they want to employ in that valuation and hopefully will be able to stipulate to the value if they do not agree with the $ll,300.00 figure suggested on the pretrial statement. Husband is in possession of a boat (l989 Regal Commadore) which is docked at Fell's Point, Maryland. He has been making the monthly payments on the boat in the amount of $448.00. Counsel are going to have the boat valued. There is a loan that the parties took out originally for $40,000.00 which apparently has been reduced by the husband's payments. Counsel are going to verify the current amount on that loan which according to the pretrial statement is around $22,500.00. SANDRA M. ZEIGLER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 99.2263 LARRY G. ZEIGLER, Defendant : CIVIL ACTION : IN DIVORCE 1 PETITION FOR WITHDRAWAL OF APPEARANCE AND NOW comes Luther E. Milspaw, Jr., Esquire, and petitions for an Order pennitting his withdrawal as attorney for Sandra M. Zeigler and in support thereof slates the following: 1. Luther E. Milspaw, Jr., Esquire is the attorney of record for Sandra M. Zeigler in the above referenced divorce action. 2. Sandra M. Zeigler has discharged Luther E. Milspaw, Jr. as counsel of record and requested that he withdraw his appearance on her behalf. 3. Despite being advised to do so, Sandra M. Zeigler has not yet obtained counsel who has been willing to enter an IIppearance, although Mr. Milspaw has received correspondence from an attorney indicating that she was now representing Sandra M. Zeigler. A copy of that correspondence is attached hereto as Exhibit A. Mr. Milspaw has responded to that letter by a letter dated January 4, 2000, attached hereto as Exhibit B. Exhibit A Exhibit B $'it/o~rC. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SANDRA M. ZEIGLER, Plaintiff NO. 99-2263 CIVIL TERM V. LARRY G. ZEIGLER Defendant CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S PRE-TRIAL STATEMENT Sandra M. Zeigler, Plaintiff, by her attorney, Diane G. Radcliff, Esquire files this Pre-Trial Statement. TABLE OF CONTENTS ~"~';'~~"l\'>;,'ns",:,"'t' ';)'\'-i~: ~'~1,'j':-""'''':;'''.''':(J-Kt'''''''''~'~'( "" ',"., ..... .....,.,...;,. -',"":.." " " , ,\,. '1" I'" J,..,', ~",,"'lt ,'SRc:rJ:oNY:~ '!,,'i~,g.,;i~'er(~~,:::f.~~~";:r:./! ~j:J(, (,;,~~,,';~;"DBSCRIP,TION\"":-:-' '::,:' <.....::!..'.:'.'~,;;,.';1,~1,:,.:.!-.';~}>..;~i,/:;~~...;.,..t.~.. ;,.,."r.(I,[;P.A... :.G.. B......(.-,::.j~.t~~ '. 1:i...1:;'\;,,..;,.,"......""'.........fJJ ,1;~1.r.,....l...Lin..,v;..,'Jj...;,..',";.',:.,,".\"',.-"',. -" "'~' -', .> ;'..,...,' ',:,'.'", ,'. ...." _,,'.. .... r .....v, I. BACKGROUND INFORMATION II. LISTING OF MARITAL ASSETS AND DEBTS III. LISTING OF PERSONAL PROPERTY IV. LISTING OF MARITAL DEBTS V. PENSIONS VI. LISTING OF NON-MARITAL ASSETS AND DEBTS VII. INCOMES AND EXPENSES VIII. COUNSEL FEES AND COSTS IX. EXPERT WITNESSES X. OTHER WITNESSES XI. PROPOSED RESOLUTION XII. PROPOSED EXHIBITS DATED: 3-10- oc) '.'p.."u11y ~ . FF, ESQUI E 48 Tr' le Road Camp 1ll, PA 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 Attorney for Plaintiff Page 1 ,. A. PARTIES: I. BACKGROUl~ INFORMATION -ff.ol:~~\}~"'1'"',f\}'~~HfrAB"*'~7~i;.~j}'R)JliM~'t:l{"~;?j!WJ.:iJ1di?!!i(\l:tift1\i1'"j~~.\il-ll)\'1il . WJ;.l.W&"{:!;rW7f~ . ~.., ~m,"Ko;J~.......zr~...:n1'!:"..,,';ll"'.M~H.....e"'Il.......,.....(.4'.....(f.W1f1lifi.Mi.~~.If.V""''<'~f'u~~ ~.Attlt~L~~WYirE~~~~'~~~j~?';~~r~~~~::J1~~{r~m~itl~#(~li;;fk~.~~1;"~if a~.~\i.if'W.rPJ1."".(ti:':-'''It'~"'''i~::'IlJ.ji,.;:::i:tt .~~lt.m-l.,~.~lll.t~(.!:1;;~;li ,:"j'!'I:,v.'ll"l'~i'\~\!@\!'~l.:rffi'~~.j Sandra Mae Zeigler 100 East First Street Lemoyne, PA 17043 56 5/17/43 York, PA 207-34-6222 NAME ADDRESS AGE DATE OF BIRTH PLACE OF BIRTH SOCIAL SECURITY NUMBER : HEALTH EMPLOYER OCCUPATION LENGTH OF RESIDENCY IN PA EDUCATIONAL BACKGROUND NAME ADDRESS AGE DATE OF BIRTH PLACE OF BIRTH SOCIAL SECURITY NUMBER HEALTH Larry Gilbert Zeigler 4071 Regiment Blvd. Enola, PA 17025 55 3/30/45 Harrisburg, PA 206-34-8145 Good Cumberland County Sheriff's Department Deputy Sheriff Entire Life High School Graduate Fairly good: has ~roblems with kidney stones; stomach d1sturbances and sleep disorder EMPLOYER EDS OCCUPATION PIC Verification LENGTH OF RESIDENCY IN PA Entire Life EDUCATIONAL BACKGROUND High School Graduate Page 2 ITEM DESCRIPTION OF PROPERTY VALUE NO. OR LIABILITY ll!l9"'!f,lJil 1'~X:F.E-l'1NS''''-''. ,. "~:"POi,iCIES"'. 'j I;,:;'.t~','j;:." ,.., __.........,....... ..,.,.."",~_,.,...,..~9.~",) ",_,' C-',_' ".' ...."t:..~:. ':'-:'~_-.:" Wife's IDS (American Unknown Express) Life Policy $1idt~ ~mnti:r:tES'i:)~;~'f{lki(\:' i" :'., .";.,',,, .>... .., :..",:.,;.',,::,. I.. ..'i'::"." ..;r '.:'. -":.1.'. .;,:,.....;:".."..: ,r'.;..:::'. ti~.._","",r ~=':~~'~"'h'" ^ ..~.';V.~.... ~t' 'l._ 'I.h 'HI: .: !"'>~>J.,.;,,-."",;, <,:,' I >~ -;'. ,:,:),\;~,:;;:::;':',l",,,':;'~.;:,: ,;: ';.j,.',,'~ >';/1;'.';;.: VALUE TO VALUE TO HUSBAND WIFE 7.S.,"JT;:Z,i"i;i:,f::,j(:::. x ~ None Known '--'-'''''~'''''''Mr.'''.'''-;."''''''...' 'ie',....," h"..".... .."'/::' ,,:r.,.i SPA. ::;:>; "OPYRIGHTS-",;;-",,,,,\.:,,,: ,,::.;;: ;..; <:ei" ,;i., g~""~~~'. .oN, i;:.'t~I...." "'.'''. .."."'I,/:::":..;;-.;,;,::.t;,:)(\",...,,,',.' ::;':i@ -r...v",-IONS~!& 'ROYALTIES;,".!'.'.:. .... 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None Known 'i...'.:,: ',"i;,'.:I"''-',i'';'''';'---'';''';';~'<;'f''',(I');~:0.q':; .'....:..~.~.,.:; ".'1:;, i;':"I",;!",""!'""r~;:"~'~1 .,.,,!- f\:.fh~, :,.:. '.,..>{ '~::;',' ::' :" :.-'!~;' ,:-';',~ /~;:.":,. {/i:'!":~i.~-.i\~\l' Page 6 ANTICIPATBD PBBS AND COSTS ITIlMIZATION OP SBRVICBS RBNDBRBD Hourly Rate And Actual Cost Copies of Bills to be supplied TBD TBD IX. EXPERT WITNESSES The following is a listing of the anticipated experts who will be called to testify in this case: jfl"."l'l?i! "'~'.1'.".'}. ...,. ~j!.~.__'..,"Ju."~'''.''..'i_ ......'.~. '. ..............,......, "'"....0...". """'~''':t.' .........'~.".l ~.. '."'.'".''''''.:..'!;:e''' _~ . . rwf."; .'''.\U;r~>.i:(\<~SOBJB~~.Orl.TBS'1'IKONr/'~ IRBPORT;IATTACHIliDi Il..PlJ.RiIo:fl ' , ':J';l F:: '.r'JiI'injl~1Is1 ,e (t~ .~IV'.l,\.t(~(~\..':.-"o::~~v/ .-.1".'i\H.'il~.li.:'!':> r\.:J'1 l:r:r;",'l..q"~'~!i/Ir'(,i.'" :)f;l';~f~~\:(", "Ij"') , '11~'~ ......". " ~. .':J\;,%f,'i~~rt:tr~'1.1,~:.;~\,i ,;i~:lh\kt,~l~~tt.<r[;~f,t;H 1.';,;,::~v>..;';::~'h:...r,'~'~~of'~~ll~ll :~j/~H'-;;.'i:I\~~i;j~~rk:J)r~'jo!j,.;\t~~f, ~~J!~'I.;_".t . None Known at This Time To Be Determined None Available at This Time To Be Supplied as Soon as Available Report to describe witness qualifications and experience and state the substance of the facts and opinions to which the expert is expected to testify and a summary of the grounds of each opinion. Additional experts who may be called to testify are not known at this time. There is a reservation of the r1ght to call additional expert witnesses upon proper notification to the other party once those expert witnesses are identified and retained, X. OTHER WITNESSES The following is a listing of the anticipated witnesses other than experts who will be called to testify in this case: ;!r.l:',," .~~'~..W!.,i't.!:."I<!.:J'.k~.',. '~Jl~' :!(.;'!i-,'N(, .ii;'i..',f"J\,M;:~J.?i\.i:~"i:U";.\';:~:JM,.j,'::.~' .{.',...'.~f,:I1l\,-;.~'o;,~',..,......v'.I:'~"~..'.p'r~~;t>l\l'.. ~~it{.~H..!~';{~li',.~JI,' , ;.J-iij{p,:.:r:"~i4:t:m.i;;".1,~.A;r;;;A';J". Tlj.~:.;r:l:S1JSJBCT;(OJr~i'1'B$TIHO~ .v,...,.._"'~ ' ,)')",9iiH:,,,1\1O;'.,f': _~ ',..,,:,.. >::Iti:i!",,! .-~,.~,;,......r~;,..,l.~.:.. 'i-"J .,.-.j,: ,l'"."",;"",,,,~~ ""~",."",..._,,!jJ,,,.,., "....",........,....l'.J.~j; t"'I'~ "","-"-,,,,--~., -,-., I " '~J" f,~ii;'.l.I.'\ ...,' ..," ~ '~]iW,;;~ ,:,' .:'w:.:.:?:~u'.: '.~: .: Sandra M. Zeigler History of the marriage; Identification and valuation of marital assets and debts; Other relevant testimony relating to the factors set forth in the divorce code Additional witnesses who may be called to testify are not known at this time. There is a reservation of the right to call additional witnesses upon proper notification to the other party once those witnesses are identified and Rgree to' testify. Page 11 10. Form of Payment to Alternate Payee: The Alternate Payee's benefit shall be distributed to her in monthly payments based on the life expectancy of such Alternate Payee. Any actuarial adjustment which might be necessary to convert Alternate Payee's benefits to one based on the Alternate Payee's lifetime should be applied to the Alternate Payee's benefits. I I. Lenl!:th of Time Benefits Will Be Paid to Alternate Payee: The benefits paid to the Alternate Payee shall be paid to her for her own separate, independent lifetime, ceasing at her death. As a result, should the Participant predecease the Alternate Payee after the Alternate Payee's benefit commencement date, her death shall not affect the Alternate Payee's right to continued benefits. 12. Earlv Retirement Subsidy: The Alternate Payee shall not be entited to a pro-rata share of any employer-provided early retirement subsidy provided to the Participant on the date of his retirement. 13. Pre-Retirement Death Benefits: The Alternate Payee shall not be treated as the surviving spouse of the Participant for any purpose under the Plan, 14. Susoension of Benefits: If the Participant's benefit ceases due to his return to employment, the Alternate Payee's benefits will not be suspended. 15. Death: In the event of the death ofa party hereto, the Plan shall be entitled recover any payments issued on the assumption that such person was alive. If Alternate Payee predeceases Participant prior to the commencement of her benefits, the Alternate Payee's portion of Participant's benefits, as stipulated herein, shall revert to the Participant, to the extent pennitted under the Plan. 16. Savinl!:s Clause: This Order is not intended, and shall not be construed in such a manner as to require the Plan: (a) to provide any type or fonn of benefit option not otherwise provided tmder the tenns of the Plan; In the event that the Plan Trustee inadvertently pays to the Alternate Payee any benefits that are to remain the sole property of the Participant pursuant to the tenns of this Order, the Alternate Payee shall immediately reimburse the Participant to the extent that the Alternate Payee has received such benefit payments, and shall forthwith pay such amounts so received directly to the Participant within ten (10) days of receipt. 20. Effect of Plan Termination: In the event that the Plan is tenninated, whether on a voluntary or involuntary basis, and the Participant's benefits become guaranteed by the Pension Benefit Guaranty Corporation ("PBGC"), the Alternate Payee's benefits, as stipulated herein, shall also be guaranteed to the same extent in accordance with the Plan's tennination rules and in the same ratio as the Participant's benefits are guaranteed by the PBGC. 21. IRC Section 415 Limitations: In the event that the Participant's accrued benefit is limited and/or reduced as the result of a benefit limitation irnposed under Section 415 of the Internal Revenue Code, as amended from time to time, then the Alternate Payee's share of the benefits shall also be limited and/or reduced in the same proportion and to the same extent as the Participant's benefits. 22. Overoavment: In the event that the Plan Administrator detennines that an overpayment has been made to the Participant and/or Alternate Payee for any reason, including but not limited to, a Plan Administrator's error in the Participant's pension calculation, or the Participant's retroactive eligibility for Social Security disability payments, and the parties cannot come to an agreement regarding their respective liability towards the Plan's recoupment of such overpayments, the Court shall reserve jurisdiction regarding the allocation of such repayments to the Plan between the Participant and the Alternate Payee. 23. Continued Jurisdiction: The Court shall retain jurisdiction with respect to this Order to the extent required to maintain its qualified status and the original intent of the parties as stipulated herein. The Court shall also retain jurisdiction to enter such further orders as are necessary to enforce the assignment of benefits to the Alternate Payee as set forth herein, including, but not limited to, the .'>- ~ rr; lr. r:': N =)~ n r-,:.... UJ... (;'~ } 0;;: ,... ..~~ (~; t: -." ''';'(r) (> .'. I ~j )..: I r:2 , , "" .:IIU -'- I'.~ ,fJn... . .-..: ~ II. 25 -;, 0 0 . " .,... ~ t,- wo _:1 ! ' N ::oi,,. '" ,. ) -"., '"J;":; ,_. ", ~.. r'"i;::j . ,- , , .., :,;iJ? , I " Cr. :iidi i - ~ flU:" > I.L C" ..~ U C. 0 '. WE DO HEREBY CERTIFY THAT THE WITHIN IS A TRUE AND COR. RECT COpy OF THE ORIGINAL FlL!D IN THIS ACTION <Y lAW OFFICES MANCKE, WAGNER, HERSHEY & TULLY AnORNEY 0:> W ...J "0 Z..J CJ'" (!)~F a ~ <<ll ~ s ,> ~ rr ::: w w ~ ~ ~ I 51 u rn 1'1 it Za:~5 <CW"X ~J: ~NII"".""",''''''''TQA..I " WRITTIN 1111'010111 TO THe """"'" ~ ~~ gw f~YU:z~ t.lAy II fHtlNO AQAlNST YOU " /1..._.