HomeMy WebLinkAbout03-3005
vs.
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
LORRAINE K. GLUMAC,
PI ai ntiff
CIVIL ACTION - LAW
NO. 03- 30P5
CIVIL TERM
THOMAS E, GLUMAC,
Defendant
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims set forth in the
foregoing 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 in divorce or annulment may be entered against
you by the court. A judgment may also be entered against you for any other claim or relief
requested in these papers by the plaintiff. You may lose money or property or other rights
important to you, including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the Office
of the Prothonotary at:
Office of the Prothonotary
Cumberland County Court House
1 Courthouse Square
Carlisle, Pennsylvania 17013
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
3ELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone: (717) 249-3166
1
LORRAINE K. GLUMAC,
Plaintiff
)
)
)
)
)
)
)
)
)
vs.
THOMAS E. GLUMAC,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
CIVIL ACTION - LAW
NO. 2003-3005 CIVIL TERM
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the Court for entry of a
divorce decree:
1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c).
2. Date and manner of service of the Complaint: Acceptance of Service filed by Plaintiff's
counsel indicating service on or about 7 Tuly 2003..
3. Complete either Paragraph (a) or (b):
(a) Date of execution of the Affidavit of Consent required by Section 3301 (c) of
the Divorce Code: By Plaintiff: 22 December 2005 By Defendant: 19 December 2005
(b) (1) Date of execution of the Affidavit required by Section 3301 (d) of the
Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit
upon the Respondent:
4. Related claims pending: None.
5. Complete either (a) or (b):
(a) Date and manner of service of the Notice of Intention to File Praecipe to
Transmit Record, a copy of which is attached:
(b) Date Plaintiff's Waiver of Notice in Section 3301 (c) Divorce was filed with
the Prothonotary: Dated 22 Decernber 2005 and filed contemporaneously herewith
Date Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the
Prothonotary: Dated 19 December 2005 and filed contemporaneously herewith.
Date: 22 December 2005
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Attorney for Plaintiff
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LORRAINE K. GLUMAC,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
VS,
: IN DIVORCE
THOMAS E. GLUMAC,
Defendant
: DOCKET NO. 03-3005 CIVIL TERM
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under Section 3301(c) ofthe Divorce Code was filed on June
25,2003.
2. The maniage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of service of the Complaint.
3. I consent to the entry of a final decree of divorce.
4. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are rnade subject to the penalties of 18 Pa. C.S.A. S 4904 relating to
unsworn falsification to authorities.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I rnay lose rights concerning alirnony, division of property, lawyer's
fees or expenses ifI do not c1airn thern before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the court
and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary.
I verify that the staternents made in this waiver are true and correct. I understand that
false staternents herein are made subject to the penalties of 18 Pa.C.S.A. S 4904 relating to
unsworn falsification to authorities.
Date: December 19, 2005
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Thomas E. Glurnac
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LORRAINE K. GLUMAC,
Plaintiff
) IN THE COURT OF COMMON
) PLEAS OF CUMBERLAND COUNTY,
) PENNSYLVANIA
)
) CIVIL ACTION - LAW
)
) NO. 03-3005 CIVIL TERM
)
) IN DIVORCE
I
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vs.
THOMAS E. GLUMAC,
Defendant
AFFJDA VIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
25 June 2003.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of both the filing and service of the complaint.
3. I consent to the entry of a final decree in divorce after service of a Notice of
Intention to Request Entry of the Decree.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree in divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees, or expenses if I do not claim them before a divorce is granted,
3. I understand that I will not be divorced until a divorce decree is entered by the
court and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this Affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S, Section 4904
relating to unsworn falsification to authorities.
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LORRAINE K. GLUMAC
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LORRAINE K, GLUMAC, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND COUNTY,
) PENNSYLVANIA
)
vs. ) CIVIL ACTION - LAW
)
) NO. 03- 300s' CIVIL TERM
THOMAS E. GLUMAC, )
Defendant ) IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed in
the Court of Common Pleas of Cumberland County. This notice is to advise you that in
accordance with Section 3302(d) of the Divorce Code, you may request that the court
require you and your spouse to attend marriage counseling prior to a divorce being handed
down by the court. A list of professional marriage counselors is available at the Domestic
Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this
list is kept as a convenience to you and you are not bound to choose a counselor from this
list, All necessary arrangements and the cost of counseling sessions are to be borne by you
and your spouse.
If you desire to pursue counseling, you must make your request for counseling within
twenty days of the date on which you receive this notice. Failure to do so will constitute a
waiver of your right to request counseling.
2
II
LORRAINE K. GLUMAC, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND COUNTY,
) PENNSYLVANIA
)
vs. ) CIVIL ACTION - LAW
) ./
) NO. 03- .3 o-tJ ~ CIVIL TERM
THOMAS E. GLUMAC, )
Defendant ) IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, LORRAINE K. GLUMAC, by her attorney,
Samuel L. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is LORRAINE K. GLUMAC, an adult individual who currently resides at
815 Allenview Drive, Mechanicsburg, Cumberland County, Pennsylvania.
2. The Defendant is THOMAS E. GLUMAC, an adult individual who currently resides
at 686 Lynes Road, Dillsburg, York County, Pennsylvania.
3. Both the Plaintiff and Defendant have been bona fide residents of the Common-
wealth of Pennsylvania for at least six months immediately previous to the filing of this
Complaint.
4. The Plaintiff and Defendant were married on 12 June 1976 in Carlisle,
Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. This marriage is irretrievably broken.
3
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7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff
may have the right to request that the Court require the parties to participate in counseling.
8. The Plaintiff requests this Court to enter a Decree of Divorce.
WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to the
Divorce Code of Pennsylvania.
Sa el L, Andes
Attorney for Plaintiff
Supreme Court ID 17225
525 North 12th Street
Lemoyne, PA 17043
(l
I verify that the statements made in this Complaint are true and correct, I understand
Ithat any false statements in this Complaint are subject to the penalties of 18 Pa. C,S. 4904
(unsworn falsification to authorities),
DATE: &-~O-D3
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LORRAINE K. GLUMAC
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LORRAINE K, GLUMAC,
PLAINTIFF
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 03-3005 CIVIL TERM
THOMAS E. GLUMAC,
DEFENDANT
IN DIVORCE
ACCEPTANCE OF SERVICE
I, THOMAS E. GLUMAC, hereby accepts service of the original Complaint in Divorce
and acknowledge receipt of a copy of the same.
Date:
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Thomas E. Glumac
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LORRAINE K. GLUMAC,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLA.~D COUNTY, PENNSYLVANIA
vs.
: CIVIL ACTION - LAW
THOMAS E, GLUMAC,
Defendant
: DOCKET NO. 03-3005 CIVIL TERM
: IN DIVORCE
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter the appearance of LUTHER E. MILSPA W, JR., Esquire, as attorney for
Defendant in the above captioned matter.
Respectfully submitted,
August 20, 2003
BY
Luther E. Milsp w, Ir., Esquire
LD. # PAI9226
130 State Street
Harrisburg, PA 17101
(717) 236-3141; FAX 717-236-07 1
E-mail: Lmilspaw(wmblawfirrn.com
Attorney for Defendant
LORRAINE K. GLUMAC,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
VS.
: CIVIL ACTION - LAW
THOMAS E. GLUMAC,
Defendant
: DOCKET NO. 03-3005 CIVIL TERM
: IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this 20th day of August, 2003, I, Elizabeth M. Patterson, Paralegal to Luther
E. Milspaw, Jr., Esquire, hereby certify that on this day I served the foregoing Entry of
Appearance by depositing the same in the U.S. mail, postage pre-paid, at Harrisburg,
Pennsylvania addressed as follows:
Samuel L. Andes, Esquire
525 North Twelfth Street
P.O. Box 168
Lemoyne, P A 17043
BY:
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Elizabeth M. Patterson, Paralegal
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LORRAINE K. GLUMAC,
PLAINTIFF
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
THOMAS E. GLUMAC,
DEFENDANT
NO. 03-3005 CIVIL TERM
IN DIVORCE
ACCEPTANCE OF SERVICE
I, THOMAS E. GLUMAC, hereby accepts service of the original Complaint in Divorce
and acknowledge receipt of a copy of the same,
Date:
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Thomas E, Glumac
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
LORRAINE K. GLUMAC,
Plaintiff
CIIVIL ACTION - LAW
THOMAS E. GLUMAC,
Defendant
NO. 03-3005 CIVIL TERM
IN DIVORCE
MOTION FOR HEARING ON REOUEST FOR ALIMONY PENDENTE LITE
AND NOW comes the above-named Plaintiff, by her atto:mey, Samuel L. Andes, and moves the
Court and the Domestic Relations Office to schedule a conference and, if necessary, a hearing, on her
request for alimony pendente lite as set out in Count III of her Petition for Economic Relief, a copy of
which is attached to this motion.
el L. Andes
Attorney for Plaintiff
525 North 12th Stret:t
Lemoyne, P A 17043
(717) 761-5361
J!
LORRAINE K. GLUMAC,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
THOMAS E. GLUMAC,
Defendant
NO. 03-3005 CIVIL TERM
IN DIVORCE
PLAINTIFF'S PETITION FOR ECONOMIC RELIEF
AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, and
makes the following Petition for Economic Relief:
COUNT I - EQUITABLE DISTRIBUTION
1. During the course of the marriage, the parties have acquired numerous items of
property, both real and personal, which are held in joint names and in the individual names
of each of the parties hereto.
WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by
the Defendant, to equitably divide the property, both real and personal, owned by the
parties hereto as marital property.
COUNT II - ALIMONY
2. Plaintiff lacks sufficient property to provide for her reasonable needs in
accordance with the standard of living of the parties established during the marriage.
3. Plaintiff is unable to support herself in accordance with the standard of living of
the parties established during the marriage through appropriate employment.
4. The Defendant is employed and enjoys a substantial income from which he is
able to contribute to the support and maintenance of Plaintiff and to pay her alimony in
accordance with the Divorce Code of Pennsylvania.
WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding Plain.
tiff from Defendant permanent alimony in such sums as are reasonable and adequate to
support and maintain Plaintiff in the station of life to whiGh she has become accustomed
during the marriage.
COUNT III - ALIMONY PENDENTE LITE
5. Plaintiff is without sufficient income to support and maintain herself during the
pendency of this action.
6. Defendant enjoys a substantial income and is well able to contribute to the
support and maintenance of Plaintiff during the course of this action.
WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her
reasonable alimony pendente lite during the pendency of this action.
~~ ~-~
Samuel L. Andes
Attorney for Plaintiff
Supreme Court ID 17225
525 North 12th Street
Lemoyne, PA 17043
I verify that the statements made in this Petition for Economic Relief are true and
correct. I understand that any false statements in this Petition are subject to the penalties
of 18 Pa. C.S. 4904 (unsworn falsification to authorities).
DATE:
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LORRAINE K. GLUMAC
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LORRAINE K. GLUMAC,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
THOMAS E. GLUMAC,
Defendant
NO. 03-3005 CIVIL TERM
IN DIVORCE
PLAINTIFF'S PETITION FOR ECONOMIC RELIEF
AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, and
makes the following Petition for Economic Relief:
COUNT I - EaUITABLE DISTRIBUTION
1. During the course of the marriage, the parties have acquired numerous items of
property, both real and personal, which are held in joint names and in the individual names
of each of the parties hereto.
WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by
the Defendant, to equitably divide the property, both real and personal, owned by the
parties hereto as marital property.
COUNT II - ALIMONY
2. Plaintiff lacks sufficient property to provide for her reasonable needs in
accordance with the standard of living of the parties established during the marriage.
3. Plaintiff is unable to support herself in accordance with the standard of living of
the parties established during the marriage through appropriate employment.
4. The Defendant is employed and enjoys a substantial income from which he is
able to contribute to the support and maintenance of Plaintiff and to pay her alimony in
accordance with the Divorce Code of Pennsylvania.
WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding Plain-
tiff from Defendant permanent alimony in such sums as are reasonable and adequate to
support and maintain Plaintiff in the station of life to which she has become accustomed
during the marriage.
II
COUNT III - ALIMONY PENDENTE LITE
5. Plaintiff is without sufficient income to support and maintain herself during the
pendency of this action.
6. Defendant enjoys a substantial income and is well able to contribute to the
support and maintenance of Plaintiff during the course of this action.
WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her
reasonable alimony pendente lite during the pendency of this action.
Samuel L. Andes
Attorney for Plaintiff
Supreme Court ID 17225
525 North 12th Street
Lemoyne. PA 17043
I verify that the statements made in this Petition for Economic Relief are true and
correct. I understand that any false statements in this Petition are subject to the penalties
of 18 Pa. C.S. 4904 (unsworn falsification to authorities).
DATE:
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LORRAINE K. GLUMAC
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
LORRAINE K. GLUMAC ) Docket Number 03-3005 CIVIL
Plaintiff )
VS. ) PACSES Case Number 787106197
THOMAS E, GLUMAC )
Defendant ) Other State ID Number
ORDER
AND NOW, to wit on this
11TH DAY OF MARCH, 2004
IT IS HEREBY
ORDERED that the 0 Complaint for Support or 0 Petition to Modify or Ii) Other
ALIMONY PENDENTE LITE REQUEST filed on FEBRUARY 10, 2004 in the above captioned
matter is dismissed without prejudice due to:
THE PLAINTIFF NOT WANTING TO PURSUE AT THE PRESENT.
o . !he Complaint or Petition may be reinstated upon written application of the plaintiff
petItIOner.
BY THE COURT:
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'JUDGE
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plaintiff
defendant
Samuel Andes, Esquire
Luther Milspaw, Esquire
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Service Type M
Form OE-506
Worker ID 21005
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Commonwealth of Pennsylvania
County of Cumberland, ss:
LORRAINE K. GLUMAC,
Plaintiff
In the Court of Common Pleas of
Cumberland County, Pennsylvania
vs.
No. 03-3005 CIVIL TERM
THOMAS E. GLUMAC,
Defendant
Motion for Appointment of Master
LORRAINE K. GLUMAC, Plaintiff moves the court to appoint a Master with respect to the
following claims:
(X) Divorce
( I Annulment
(Xl Alimony
( ) Alimony Pendente Lite
(Xl Distribution of Property
( ) Support
(X) Counsel Fees
(Xl Costs and Expenses
and in support of the motion states:
1. Discovery is complete as to the c1aim(s) for which the appointment of a Master is
requested.
2. The Defendant has appeared in the action by his attorney, Luther E. Milspaw, Esquire.
3. The statutory ground(sl for divorce are: 3301 (d) of the Divorce Code.
4. Check the applicable paragraph(s).
( ) The action is not contested.
( ) An agreement has been reached with respect to the following claims:
( X) The action is contested with respect to the following claims: AI L
5, The action does not involve complex issues of law or fact.
6. The hearing is expected to take 1 days.
7. Additional information, if any, relevant to the motion:
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A ttomey for Plaintiff
AND NOW, 2005,
Esquire, is appointed Master with respect to the following claims: divorce, distribution of property,
alimony, counsel fees, costs and expenses.
BY THE COURT,
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LORRAINE K. GLUMAC,
Plaintiff
vs.
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 03-3005 CIVIL TERM
THOMAS E. GLUMAC,
Defendant
IN DIVORCE
NOTICE TO DEFENDANT
If you wish to deny any of the statements set forth in this Affidavit, you must file a
Counter Affidavit within twenty (20) days after this Affidavit has been served on your or the
statements will be admitted.
PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE
1. The parties to this action separated in mid June 2003 and have continued to live
separately and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
I verify that the statements made in this Affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to
unsworn falsification to authorities.
Date: J~ qu.ru. ~OD5"
dcftAf)l-'~_ r~
LORRAINE K. GLUMAC
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
LORRAINE K. GLUMAc,
Plaintiff
CIVIL ACTION - LAW
1\10. 03-3005 CIVIL TERM
THOMAS E. GLUMAC,
Defendant
IIN DIVORCE
PLAINTIFF'S PETITION FOR COUNSEL FEES AND EXPENSES
AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, and makes the
following Petition for an award of counsel fees and expenses in this matter, based upon the following:
1. The Petitioner herein is the Plaintiff. The Respondent herein is the Defendant.
2. Plaintiff has been compelled to retain counsel to represent her interests in this matter. The
job of her counsel has been complicated by Defendant's lack of cooperation involuntarily exchanging
information and responding to communications from her counsl~1.
3. In addition to counsel fees, Plaintiff will incur substantial other expenses including appraisal
fees and the like.
4. Much of the cost which Plaintiff will incur to conclude this matter has been caused or
aggravated by Defendant's failure or refusal to cooperate. As a result of that, Plaintiff is without
sufficient funds to pay her attorney fees and the other costs of this action without contribution from
Defendant.
5. Defendant is gainfully employed and enjoys a substElntial income from which he can well
afford to contribute to the costs incurred by Plaintiff to litigate this matter.
WHEREFORE, Plaintiff asks this court to award to her her reasonable attorneys fees, costs,
and expenses incurred in the litigation of this matter.
~.,~~
<--'2 " - ()
Samuel L. Andes
Attorney for Plainti'Ff
Supreme Court ID # 17225
525 North 12th Stre,et
Lemoyne, Pa 17043
(717) 761-5361
II
I'
I verify that the statements made in this document are tl"ue and correct. I understand that any
false statements in this document are subject to the penalties of 18 Pa. C.S. 4904 (unsworn
falsification to authorities).
Date: .::r t.( r1 f
3 . 2.Ul )S-
I
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LORRAINE K. GLUMAc
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Commonwealth of Pennsylvania
County of Cumberland, ss:
LORRAINE K. GLUMAC,
Plaintiff
In the Court of Common Pleas of
Cumberland County, Pennsylvania
vs.
No. 03-3005 CIVIL TERM
THOMAS E. GLUMAC,
Defendant
Motion for Appointment of Master
LORRAINE K. GLUMAC, Plaintiff moves the court to appoint a Master with respect to the
following claims:
I:
I
(X) Divorce
( I Annulment
(X) Alimony
( ) Alimony Pendente Lite
(X) Distribution of Property
( ) Support
(X) Counsel Fees
(X) Costs and Expenses
and in support of the motion states:
1. Discovery is complete as to the c1aim(s) for which the appointment of a Master is
requested.
2. The Defendant has appeared in the action by his attorney, Luther E. Milspaw, Esquire.
3. The statutory ground(sl for divorce are: 3301 (d) of the Divorce Code.
4. Check the applicable paragraph(s).
( ) The action is not contested.
( ) An agreement has been reached with respect to the following claims:
( )( I The action is contested with respect to the following claims: AI L
5. The action does not involve complex issues of law or fact.
6. The hearing is expected to take 1 days.
7. Additional information, if any, relevant to the motion:
2'3 JU'7E' 2.Q).,-
Date
,~~~~
Sam , Andes
Attorney for Plaintiff
/? ,.., ell (J/ . .
AND NOW, -t 2005, L.> ~ ~
Esquire, is appointed M er with respect to the following claims: divorce, distribution of property,
alimony, counsel fees, costs and expenses.
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LORRAINE K. GLUMAC,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 03 - 3005 CIVIL
THOMAS E. GLUMAC,
Defendant
IN DIVORCE
ORDER OF COURT
AND NOW, this
;7ftc
day of Ill; /(' 1.4):' /d.V,
2005, the economic claims raised in the proceedings having been
resolved in accordance with a property settlement agreement
dated December 19, 2005, the appointment of the Master is
vacated and counsel can file a praecipe transmitting the record
to the Court requesting a final decree in divorce,
BY THE COURT,
Samuel L, Andes
Attorney for Plaintiff
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Luther E. Milspaw, Jr.
Attorney for Defendant
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PROPERTY SETTLEMENT AGREEMENT
THIS AGREEMENT, made this I q#-. day of Decervvbt/!.. ,2005, is by and between:
I THOMAS E, GLUMAC, of 686 Lynes Road, Dillsburg, Pennsylvania, 17019, party of
I the first part, hereinafter referred to as "Husband"; and
I. LORRAINE K. GLUMAC, of 815 Allenview Drive, Mechanicsburg, Pennsylvania,
'\17055, party of the second part, hereinafter referred to as "Wife."
I WITNESSETH:
WHEREAS, the parties hereto are husband and wife, having been married on 12 June
, 1976 and are the parents of three children, all of whom are emancipated, Michael Glumac,
Andrew Glumac, and Eryn Glumac.
WHEREAS, certain difficulties have arisen between the parties hereto which have made
them desirous of living separate and apart from one another and Wife has initiated an action in
divorce filed to No. 03-3005 before the Court of Common Pleas of Cumberland County,
Pennsylvania;
WHEREAS, the parties hereto, Wife being represented by Samuel L. Andes, Esquire,
and Husband by Luther E. Milspaw, Jr., Esquire, have each exchanged full and complete
information as to the property, assets, and liabilities owned and owed by each and have
disclosed to each other and to their respective attorneys full information as to the financial
status of both parties hereto; and
WHEREAS, the parties hereto have mutually entered into an agreement for the division
of their assets, the provision for the liabilities they owe, and provision for the resolution of
their mutual differences, after both parties have had full and ample opportunity to consult
with their respective attorneys, and the parties now wish to have that agreement reduced to
writing.
NOW, THEREFORE, the parties hereto, in consideration of the above recitals, the
mutually made and to be kept promises set forth hereinafter, and for other good and valuable
Page 1 of 11
considerations, and intending to be legally bound and to legally bind their heirs, successors,
II
I
I
assigns, and personal representatives, do hereby covenant, promise, and agree as follows:
1. REAL EST ATE. The parties acknowledge that they own a single-family residence
situated on a tract of land containing approximately four acres and an adjacent tract of land
containing approximately nine acres, title to which is currently held in their joint names and
,
I against which there are presently no liens. Wife shall convey to Husband, to be his sole and
I separate property, both tracts of real estate subject to all encumbrances, easements, restrictions,
I or other matters of public record as of the date of this agreement. Husband will cause deeds
II to be prepared for the two properties. Wife will execute and acknowledge the deeds and
I deliver them to her attorney to be held in escrow until such time as all the documents are filed
Ii to conclude the divorce, at which time the deeds will be released to Husband or his attorney
without further authorization from Wife. Husband acknowledges that he has occupied the
I property since the parties separated in the summer of 2003 and that he has paid all expenses
and liabilities arising out of the ownership or occupancy of the property and he further agrees
to pay as they may become due all taxes, assessments, or other charges or liabilities arising out
of the ownership or occupancy of the property from and after the date of the parties'
separation in the summer of 2003 and to indemnify and save Wife harmless from any loss,
cost, or expense caused to her by his failure to do so.
2. HOUSEHOLD FURNISHINGS AND TANGIBLE PERSONAL PROPERTY. The
parties hereto mutually agree that they have effected a satisfactory division of the furniture,
household furnishings, appliances, and other household and personal property between them
and they mutually agree that each party shall, from and after the date hereof, be the sole and
separate owner of all such tangible personal property presently in his or her possession,
whether said property was heretofore owned jointly or individually by the parties hereto, and
this agreement shall have the effect of an assignment or receipt from each party to the other for
such property as may be in the individual possessions of each of the parties hereto, the
effective date of said bill of sale to be contemporaneous with the date of the execution of this
Agreement.
Page 2 of 11
3. MOTOR VEHICLES. The parties agrees that they will dispose of and transfer
their motor vehicles as follows:
A. Husband will retain ownership and title to the Honda 52000 and the
2002 Honda Accord currently in his possession.
B. Wife will retain ownership and title to the 1999 Honda CRV currently
in her possession.
C. Each of the parties will be responsible to pay any debt, expense or
liability arising out of their ownership of the vehicles described herein, from the
date of their separation and into the future and shall further indemnify and save
the other party harmless from any loss, cost, or expense caused to the other party
by their failure to do so.
The parties agree that they will make, execute, acknowledge and deliver any and all
documents necessary to fully implement the ownership of the motor vehicles as set forth
herein.
4. ASSETS TO BE TRANSFERRED TO OR RETAINED BY HUSBAND. The
parties agree that Husband shall be the sole and separate owner of the following assets,
whether those assets are now held in joint names or the name of either of the parties
individually:
A. Husband's benefits within the Pennsylvania State Employees
Retirement System earned during the marriage;
B. Husband's retirement accounts with TIAA-CREF subject, however, to
the provisions of Paragraph 6 hereof;
C. Husband's money purchase plan with Vanguard Funds subject,
however, to the provisions of Paragraph 6 hereof;
D. Husband's profit-sharing plan with Vanguard Funds subject,
however, to the provisions of Paragraph6 hereof;
E. Husband's individual retirement account with Janus Funds;
F. Husband's Certificate of Deposit with Citizens Bank;
Page 3 of 11
Ii
G Husband's checking account with PNC Bank;
H. U.S. Savings Bonds currently in Husband's possession or registered in
his name.
The parties agree that they will make, execute, acknowledge and deliver, within thirty (30)
days after the date of this agreement, all documents necessary to transfer such items to
Husband's name alone and for Wife to waive any further claim to or interest in such assets and
Wife does hereby acknowledge those assets to be the sole and separate property of Husband
from and after the date of this agreement.
5. ASSETS TO BE TRANSFERRED TO OR RETAINED BY WIFE. The parties agree
that Wife shall be the sole and separate owner of the following assets, whether those assets are
now held in joint names or the name of either of the parties individually:
A. Wife's account within the Pennsylvania Public School Employees'
Retirement System earned during the marriage;
B. Wife's 403(b) account with Vanguard Funds;
C. Wife's individual retirement account with Janus Funds;
D. Wife's money market account with the Pennsylvania State Employees'
Credit Union or the proceeds of that account when it was liquidated or when
withdrawals were made from it;
E. Wife's 23-month Certificate of Deposit with Susquehanna Valley
Federal Credit Union or the proceeds of that CD when it was liquidated;
F. Wife's checking account with Members first Federal Credit Union;
G. Wife's regular savings account with Members First Federal Credit
Union;
H. Wife's money management account with Members First Federal
Credit Union;
1. Wife's II-month Certificate of Deposit with Members First Federal
Credit Union;
Page 4 of 11
. !
J. Wife's 48-month "bump-up" Certificate of Deposit with Members First
Federal Credit Union;
K. Wife's 24-month "bump-up" Certificate of Deposit with Members First
Federal Credit Union;
L. Wife's 21-month Certificate of Deposit with Members First Federal
Credit Union;
M. Wife's 9-month Certificate of Deposit with Members First Federal
Credit Union;
N. U.s. Savings Bonds currently in Wife's possession or registered in her
name,
The parties agree that they will make, execute, acknowledge and deliver, within thirty (3D)
days after the date of this agreement, all documents necessary to transfer such items to Wife's
name alone and for Husband to waive any further claim to or interest in such assets and
Husband does hereby acknowledge those assets to be the sole and separate property of Wife
from and after the date of this agreement.
6. ROLLOVER OF RETIREMENT FUNDS. Husband shall, promptly after the
execution of this agreement, transfer from one or more of his tax-deferred retirement accounts
listed above to a tax-deferred retirement account in Wife's name, designated by Wife, assets
having a value as of 31 October 2005 of One Hundred Forty-Four Thousand Seven Hundred
Twenty-One and 26/100 ($144,721,26) Dollars. The transfer will be made as a tax-free rollover
transfer and, to the extent that a Qualified Domestic Relations Order, or other order or
document is required to make the transfer without tax consequences, the parties will cooperate
to obtain that order and its entry and will share equally the cost of preparing and
implementing the order.
7.' CASH PAYMENT TO WIFE. Husband shall, within fifteen (15) days of the
execution of this agreement, make the following cash payments to Wife:
Page 5 of II
II
II
I
A. The sum of Thirty-Nine Thousand Four Hundred and Nine 68/100
($39,409.68) Dollars which is required to make an even division of the marital
property of the parties based upon their negotiations and the values they have
used in those negotiations.
B. Twelve Thousand ($12,000.00) Dollars, which represents a credit due
Wife for his use and occupancy of the real estate after the parties' separation.
8. WAIVER OF EOUlTABLE DISTRIBUTION. The parties acknowledge that each
of them have had a full and ample opportunity to consult with counsel of their choice
regarding their claims arising out of the marriage and divorce and that they have specifically
reviewed their rights to the equitable distribution of marital property, including rights of
discovery, the right to compel a filing of an Inventory and Appraisement, and the right to have
the court review the assets and claims of the parties and decide them as part of the divorce
action. Being aware of those rights, and being aware of the marital property owned by each of
I the parties, the parties hereto, in consideration of the other terms and provisions of this
I, agreement, do hereby waive, release and quitclaim any further right to have a court or any
I other tribunal equitably distribute or divide their marital property and do hereby further
waive, release and quitclaim any and all claim against or interest in assets now currently in the
possession or held in the name of the other, it being their intention to accept the terms and
provisions of this agreement in full satisfaction of all of their claims to the marital property of
the parties and the equitable distribution of the same.
9. WAIVER OF ALIMONY, SUPPORT AND ALIMONY PENDENTE LITE. The
parties acknowledge that they are aware of the income, education, income potential, and assets
and holdings of the other or have had full and ample opportunity to become familiar with
such items. Both parties acknowledge that they are able to support and maintain themselves
comfortably, without contribution from the other beyond that as provided for in this Property
Settlement Agreement, upon the income and assets owned by each of them. The parties
hereby accept the mutual covenants and terms of this Agreement and the benefits and
properties passed to them hereunder in lieu of any and all further rights to support or alimony
Page 6 of 11
'11
I,
II
for themself, counsel fees, and alimony pendente lite at this time and during any and all
further or future actions of divorce brought by either of the parties hereto and the parties do
hereby remise, release, quit claim, and relinquish forever any and all right to support, alimony,
alimony pendente lite, counsel fees and expenses beyond those provided for herein, during the
pendency of or as a result of any such actions, as provided by the Divorce Code of
Pennsylvania or any other applicable statute, at this time and at any time in the future.
10. WAIVER OF EST ATE RIGHTS. Husband releases his inchoate intestate rights in
the estate of Wife and Wife releases her inchoate intestate rights in the estate of Husband, and
each of the parties hereto by these presents for himself or herself, his or her heirs, executors,
administrators, or assigns, does remise, release, quit claim, and forever discharge the other
party hereto, his or her heirs, executors, administrators, or assigns, or any of them, of any and
all claims, demands, damages, actions, causes of action or suits of law or in equity, of
whatsoever kind or nature, for or because of any matter or thing done, omitted, or suffered to
be done by such other party prior to the date hereof; except that this release shall in no way
exonerate or discharge either party hereto from the obligations and promises made and
imposed by reason of this agreement and shall in no way affect any cause of action in absolute
divorce which either party may have against the other.
11. WAIVER OF PROPERTY CLAIMS AND EST ATE CLAIMS. Except as herein
otherwise provided, each party hereto may dispose of his or her property in any way, and
each party hereby expressly waives and relinquishes any and all rights he or she may now
have or hereafter acquire, under the present or future laws of any jurisdiction, to share in the
property or the estate of the other as a result of the marital relationship, including, without
limitation, the right to equitable division of marital property, alimony, alimony pendente lite,
and counsel fees, except as provided for otherwise in this Agreement, dower, courtesy,
statutory allowance, widow's allowance, right to take in intestacy, right to take against the will
of the other, and right to act as administrator or executor of the other's estate, and each will, at
the request of the other, execute, acknowledge, and deliver any and all instruments which may
Page 7 of 11
. I
be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such
interests, rights, and claims.
12. REPRESENT A TION AS TO NO DEBTS. The parties hereto mutually represent
to the other than neither of them has incurred any debts in the name of the other not
previously disclosed or provided for in this agreement. Each of the parties hereby represents
to the other that neither one of them have incurred or contracted for debts in the name of the
other or for which the other is or would be legally liable from and after the date of the parties'
.separation. Both parties hereto mutually agree and promise that neither will contract or
otherwise incur debts in the other's or joint names without the prior permission and consent of
the other party hereto. Both parties hereto represent and warrant to the other party that they
have not so contracted any debts unbeknownst to the other up to the time and date of this
Agreement.
13. DISCLOSURE. Both of the parties hereto represent to the other that they have
made full disclosure of the assets and income and income sources owned, controlled, or
enjoyed by either of them and that neither party hereto has withheld any financial information
from the other. Each of the parties represents that they have reviewed such information, as
well as the law of Pennsylvania as it relates to their rights, obligations, and claims arising out
of their marriage and of any divorce action which has or may be filed between the parties with
an attorney of their choice, or had the opportunity to review such matters with an attorney of
their choice and voluntarily decided not to do so. Further, the parties each acknowledge that
they are aware that they have the right to compel the other party to provide full financial
information about all assets owned by either party and all liabilities owed by either party and
have the right to have a court force such disclosure in a divorce action. Being aware of those
rights, the parties expressly waive the right to further disclosure or discovery regarding
marital assets, liabilities, incomes, and finances and agree that they are satisfied with their
understanding of their legal rights and obligations. Being so aware ,md satisfied, the parties
mutually accept the terms and provisions of this agreement in full satisfaction of any and all
Page 8 of 11
rights or obligations arising of their marital status or the divorce action now pending or to be
I,
I filed between them.
I 14. CONCLUSION OF DIVORCE. The parties acknowledge that this agreement is
'i made in contemplation of the conclusion by both of them of an action in divorce which has
been filed or will be filed shortly by one of the parties hereto. Both of the parties hereto agree
that they shall, contemporaneously with the execution of this agreement, execute and deliver
to their respective attorney or attorneys, an Affidavit of Consent under Section 3301(c) of the
I Divorce Code, consenting to the entry of a final decree in divorce, and a Waiver of further
Ii notice for the entry of such decree. Both parties agree that they shall accept the terms and
I provisions of this agreement in full satisfaction of any claims they may have under the Divorce
Code of the Commonwealth of Pennsylvania, including, but not limited to, alimony, alimony
pendente lite, counsel fees, equitable distribution, and the like.
15. RELEASE. The parties acknowledge that the purpose of this agreement is to
divide all of their marital property, resolve all of the economic claims between them, and
terminate and conclude any and all claims one party may have against the other. The parties
acknowledge that each of them has had ample opportunity to consult with an attorney of their
choice and to obtain legal representation with regard to this agreement and to the claims
which they are terminating hereby. Consequently, each of the parties, for themselves, their
heirs, successors, and assigns, does hereby accept the terms and provisions of this agreement
in full satisfaction of any claims, of any nature, they may have, or may ever have had, against
the other party and each of the parties does hereby waive, relinquish, release, and surrender
forever any claim they have against the other party, arising out of their marital relationship, or
any other dealing between the parties prior to the date of this agreement, provided, however,
that this release shall not exonerate either of the parties from the obligations they expressly
make in this agreement, which shall survive the date of this agreement until such obligations
are fully performed.
16. BREACH. In the event that any of the provisions of this agreement are breached
or violated by either of the parties, the other party shall be entitled to enforce this agreement
Page 9 of 11
by an appropriate action in law or in equity or to take any other action to which they are
lawfully entitled to enforce this agreement or otherwise protect their rights. In the event that
such action is commenced by one of the parties and the other party is found to have breached
or violated any of the terms and provisions of this agreement, the party having so violated or
breached the agreement, shall be responsible for and shall promptly pay upon demand the
reasonable attorney's fees incurred by the other party to enforce their rights hereunder.
17. CHOICE OF LAW. This Agreement shall be interpreted, applied and enforced in
accordance with the laws of, and by the courts of, the Commonwealth of Pennsylvania.
II
'i 18. SEVERABILITY. If for any reason whatsoever any part of this Agreement shall be
II declared void or invalid, only such part shall be deemed void and in all other respects this
II Agreement shall remain valid and fully enforceable.
,I 19. NON-WAIVER. The waiver of any term, condition, clause, or provision of this
Agreement shall in no way be deemed or considered a waiver of any other term, condition,
clause or provision of this Agreement.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and
year first above written.
iL t_~
THOMAS E. GLUMAC
W ess
fi ~;!. ..J:j~
LORRAINE K. GLUMAC
Witness
Page lO of II
II
II
I
I
COMMONWEALTH OF PENNSYLVANIA )
( 55.:
COUNTY OF DAUPHIN )
On this, the Iq+-hday oN'}CirY1Lu.r2005, before me, the undersigned officer,
personally appeared THOMAS E. GLUMAC known to me (or satisfactorily proven) to be the
person whose name is subscribed to the within instrument, and acknowledged that said
person executed same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
L
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I COMMONWEALTH OF PENNSYLVANIA
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ommission Expires: d
NOTARIAl. SEAL
TARA l EBRIGHT
Notary Publlc
liWlSTOWN BOROUGH. MIfFlIN COUNlY
My CommllSlon Explrel Octll. 2008
)
( 55.:
)
On this, the 20"'" day of Oe.ceMbe.e. ,2005, before me, the undersigned officer,
personally appeared LORRAINE K. GLUMAC known to me (or satisfactorily proven) to be
the person whose name is subscribed to the within instrument, and acknowledged that said
person executed same for the purposes therein contained.
COUNTY OF CUMBERLAND
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
MYCO!~i~~;
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Page 11 of 11
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IN THE COURT OF COMMON PLEAS ;
+
OFCUMBERLANDCOUNTY ;
+
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LORRAINE K. GLUMAC.
STATE OF PENNA.
No, 2003-3005
Plaintiff
VERSUS
THOMAS E, GLUMAC,
Defendant
DECREE IN
DIVORCE
AND
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_, IT IS ORDERED AND
2-~
2005
DECREED THAT
LORRAINE K. GLUMAC
, PLAINTIFF,
AND
THOMAS E. GLUMAC
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
NONE
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