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Home My WebLink About99-05578 i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. t 4 Rf ICCTT.T. R , mlu"' Z14 NO • lggq_qSR Plaintiff VERSUS SANMA M _(a'[lJ.SIIATT nafanAant DECREE IN DIVORCE AND NOW, oleo3 ?.?"?P./?i IT IS ORDERED AND DECREED THAT RiI M, T R arms ATT.. TTT , PLAINTIFF, AND_ SANDRA M mjTSI ATr 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; The parties have executed a Property Settlement Agreement which shall ATTEST: J PROTHONOTARY Iv • 3' /v .O3 `tcs >? a7yl ??re? PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 3800 Market Street Camp Hill, PA 17011 (717)591.1755 Attorney for Plaintiff RUSSELL R. GUTSHALL, III IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW SANDRA M. GUTSHALL NO. 1999 -5578 CIVIL TERM Defendant 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. Ground for divorce: Irretrievable breakdown under Section 3301( c ) of the Divorce Code. 2. Date a nd to anner o f s ervice o f t he C omplaint: Susan Kadel effected an Acceptance of Service of October 2. 2000 , on behalf of her client, Sandra M. Gutshall. 3. Date of execution of the plaintiffs affidavit required by Section 3301(c) of the Divorce Code: August 20, 2003 Date of service of plaintiffs affidavit on defendant: August 20.2003 Date of execution of the defendant's affidavit required by Section 3301(c) of the Divorce Code: August 20, 2003 4. Related claims pending: None Resp ctfully- Date: 9 suluu' Peter J. Russo ? I b?e3 -?, '.r ?. ? __ CV. ?: ._ ?'i :.J C_) RUSSELL R. GUTSHALL, III, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. : NO. 99 .SS)l CIVIL TERM SANDRA M. GUTSRALL, Defendant : IN DIVORCE NOTICE TO DEFEND AND AIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you. 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, Cumberland County Courthouse, High and Hanover Streets, Carlisle, Pennsylvania. 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 (717) 249.3166 Le han demandado a usted en Is Corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dies de plazo al partir de la fecha de la demands y Is notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en Contra de su persona. Sea avisado que si usted no se defiende, la cone tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion do demands. Usted puede perder dinero o sus propiedades o otros derechos importanates para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 RUSSELL R. GUTSHALL, III, Plaintiff V. SANDRA M.GUTSHALL, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW :NO. y'q_ SS 7P CIVILTERM IN DIVORCE COUNTI DIVORCE AND NOW comes the above Plaintiff, Russell R. Gutshall, III, by his attorney, Kathluen Carey Daley, Attorney at Law, and seeks to obtain a decree in divorce from the above-named Defendant, upon the grounds hereinafter set forih: 1. The Plaintitl; Russell R. Gutshall, III, is an adult individual who resides at 26 Stewart Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendanrt Sandra M. Gutshall, is an adult individual who resides at 26 Stewart Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Plaintiff and Defendant are sui juris, and both have been bona fide residents of the Commonwealth of Pennsylvania for a period of more than six months immediately preceding the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 24, 1969, in Boiling Springs, Cumberland County, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its Amendments. 6. The cause(s) of action and section(s) of Divorce Code under which Plaintiff is proceeding are: A. Section 3301(c). The marriage of the parties is irretrievably broken. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an Affidavit. B. Section 3301(d). The marriage of the parties is irretrievably broken. The Plaintiff and Defendant separated on August 26, 1999. 7. There have been no prior actions in divorce between the parties. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request the parties to participate in counseling. 9. The parties may enter into a written agreement with regard to support, alimony and property division. In the event that such an agreement is executed by the parties, the agreement may be incorporated by the Court into the final Decree of Divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce, divorcing Plaintiff and Defendant. COUNT H EQUITABLE DISTRIBUTION 10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference as though set forth in full. 11. Plaintiff and Defendant have acquired property, both real and personal during their marriage from the date of their marriage, May 24, 1969, until the date of their separation, August 26, 1999. 12. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital property. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unswom falsification to authorities. Date: 1? /t? q By: -=& Russell R. Gutsh , III, Plaintiff By: 64e' Kathleen Carey Daley, E uir Attorney No. 30078 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 Attorney for Plaintiff V h a 8;zz ? m 0 a n :? N RUSSELL R. GUTSHALL, III, Plaintiff, V. SANDRA M. GUTSHALL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA No. 99-5578 CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVICE I, Susan M. Kadel, Esquire, do hereby accept service of the Complaint in Divorce in F the above-captioned divorce action filed on September 13, 1999 on October 2, 1999. I certify that I am authorized to accept service on behalf of my client, Sandra M. Gutshall, Defendant, therein. Date: Kadel, squire Attorney for or Defendant, Sandra M. Gutshall James, Smith, Dietterick & Connelly PO Box 650 Hershey, PA 17033 (717) 533-3280 Attorney I.D. No. 44837 ?• i= Y F- LI.G-; 1? C? Ur '. > ' ` ' ? '<: .. . ? 1 ` J u.. " .? J L ? ;ii' '. O.. - ? ?? U ;> '? U PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 RUSSELL R. GUTSHALL, III Plaintiff V. Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SANDRA M. GUTSHALL NO. 1999 -5578 CIVIL TERM Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO ENTER DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 13, 1999. 2. The marriage is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a Final Decree of Divorce without further notice. 4. I understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses if I do not claim them before a divorce is granted. 5. 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's Office. 6. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. I understand that the court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me on request. 7. Being so advised, I, Russell R. Gutshall, III, do not request that the Court require my spouse and me to participate in counseling prior to a divorce decree being handed down by the Court. 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 unswom falsification to Authorities. August 20, 2003 ,? . DATE RUSSELL R UTSHALL, III • ?_: U 7 N ?? C J }.. lj: .: n n _:i, ? r c.. 'ice L4' :IIZ ?'.. v •7 o v RUSSELL R. GUTSHALL, III, Plaintiff, V. SANDRA M. GUTSIIALL, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA No. 99-5578 CIVIL TERM IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 13, 1999. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety 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 of divorce after service of Notice of Intention to request entry of the Decree. 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 may Icse rights concerning alimony, division of ptoperty. lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 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 above are true and correct. I understand that faise state, ents herein are made subject to the penalties of 18 Pa. C.S.A. 549D4, relating to unswom falsification to authorities. Date: W(?4n/ aU ?U03 Sandra M. Gutshal efendant 21 ? 1 r - . J ? Cl) U IN THE COURT OF COMMON PLEAS OF (`?V S?I/vV `r ?'V//???'??I/,1. CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW /^J vsh.'' 1( NO. qq 1y?7th CIVIL. 19 '? ?Jyy?D rn? I Au???, ,(? IN DIVORCE STATUS SHEEIT C DATE' ACT!. V 1'1'llib : „-R• a?? c!`0 " ^ a6(t ?--? u y cow //ina alb aPn Zn LAI AYA04. A, ?/l'7?C 3 41 ,fin v i . Dell" ?1¢, e ?(ru, *(L^ emu." r RUSSELL R. GUTSHALL, III IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW Vs. NO. 99-5578 CIVIL 19 SANDRA M.GUTSHALL IN DIVORCE Defendant STATUS SHEET DATE: I ACTIVITIES: n . In ?1Al - I o Q p? 6`I* ?vo, 05 .Gig .a '. few 10 ' ?S2,-5 1G1?1 z5 ?r QAd0VAVb u 'sl ?6 21 V"' ?G I ?? ?G ?, L/ 1 ?l rY?,oy I *m• Q. CI e log is ? ?ca?PW- w RUSSELL R. GUTSHALL, III, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99 - 5578 CIVIL SANDRA M. GUTSHALL, Defendant IN DIVORCE TO: Peter J. Russo Attorney for Plaintiff Susan M. Kadel Attorney for Defendant DATE: Monday, August 6, 2001 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. a (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. DATE COUNSEL FOR PLAINTIFF ( ) COUNSEL FOR DEFENDANT ( ) NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. RUSSELL R GUTSHALL M : IN THE COURT OF COMMON PLEAS OF Plaintiff ; CUMBERLAND COUNTY, PENNSYLVANIA VS. SANDRA M. GUTSHALL Defendant : NO. 5578 192L MOTION FOR APPOINTMEN Russell R. Gutshall. III (Plaintiff) (13efendaM), me respect to the following claims: (X) Divorce ( X ) ( ) Annulment ( ) (X) Alimony ( X ) ( ) Alimony Pendete Lite ( X ) C OF MASTER ves the court to appoint a master with Distribution of Property Support Counsel Fees Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claim(s} for which the appointment of a master is requested. (2) The Defendant (has) Gws-aet) appeared in the action (PeFsenally) (by her attorney, Susan Kadel . Esquire). (3) The statutory ground(s) for divorce (is) (are) 3301(d) (4) Delete the inapplicable paragraph(s): (a) (b) (c) The action is contested with respect to the following claims: fact. (5) The action (invelves) (does not involve) complex issues of law or (6) The hearing is expected to take 4 (hours) (days). (7) Additional information, if any, relevant to the motion: Date:, .3D' ORDER APPOINTING MASTER AND NOW 20?} Esquire, is appointed master with re ect to the following claims: 6,1 5^?? C BY T?"" kr? J. rt1?r ,. fPl ' UJ (•?.. 4 ? ? 2i I ? 1 1 ? 1 r r RUSSELL R. GUTSHALL, III Plaintiff V. SANDRA M.GUTSHALL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-5578 CIVIL TERM IN DIVORCE INCOME AND EXPENSES STATEMENT INVENTORY AND APPRAISEMENT of Plaintiff RUSSELL R. GUTSHALL, III Plaintiff V. SANDRA M. GUTSHALL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.99.5578 CIVIL TERM IN DIVORCE INCOME AND EXPENSES STATEMENT INVENTORY AND APPRAISEMENT AND ASSETS OF PARTIES NOTICE BOTH PARTIES TO A DIVORCE ACTION ARE REQUIRED TO FILE WITH THE PROTHONOTARY AN INVENTORY AND APPRAISEMENT OF ALL PROPERTY OWNED OR POSSESSED AT THE TIME THE ACTION COMMENCES AND ALL PROPERTY TRANSFERRED WITHIN THE PRECEDING THREE (3) YEARS. YOU MUST COMPLETE THIS FORM AND FILE IT WITHIN SIXTY (60) DAYS OF RECEIPT OF THIS STATEMENT. IN ADDITION TO FILING THIS COMPLETED FORM WITH THE PROTHONOTARY, YOU MUST ALSO SERVE A TRUE AND CORRECT COPY OF THIS FORM ON THE OTHER PARTY TO THE DIVORCE, PURSUANT TO RULE OF COURT. THIS STATEMENT SHALL INCLUDE THE INFORMATION REQUESTED AS ATTACHED. YOU MAY NEED ADDITIONAL ROOM TO COMPLETE THIS FORM. PLEASE KEEP EACH CATEGORY SEPARATE AND FOLLOW THE FORM AS CLOSELY AS POSSIBLE. IF YOU DO NOT FILE THE INVENTORY AND APPRAISEMENT AS REQUIRED, SANCTIONS MAY BE IMPOSED AGAINST YOU BY THE COURT. INCOME AND EXPENSE STATEMENT Both parties to a divorce action are required to file with the Prothonotary a complete income and expense statement. You must complete this form and file it within 30 days of receipt of this statement. If you are self- employed or if you are salaried by a business of which you are owner in whole or in part, you must also fill out the Supplemental Income Statement. INCOME Pay Period: (weekly, bi-wj Gross Pay per Pay Period: Itemized Payroll Deductions: Federal Withholding Social Security Local Wage Tax State Income Tax Retirement Savings Bonds Credit Union Life Insurance Health Insurance Other (PAC/UM PA Unemployment Flex Credit Before Tax Savings After Tax Savings Occupational Tax Medicare Net Pay per Period $ 825.91 $ 202.31 $ 33.15 $ 90.61 $ 1175.00 $ 43.37 $ 340.13 $ 21.00 $ (305.55) $ 47.32 $ 835.34 3 SOCIAL SECURITY NO.: 193-36-3669 DATED: ]'J5-0 INCOME FROM ALL SOURCES: WEEK MONTH YEAR Interest $ $ $ 130.00 Dividends $ $ $ Pension $ $ $ Annuity $ $ $ Social Security $ $ $ Rents $ $ $ Royalties $ $ $ Expense Account $ $ $ Gifts $ $ $ Unemployment Compensation $ $ $ Workmen's Compensation $ $ $ Other $ $ $ Total $ $ $ 130.00 TOTAL INCOME $ $ $ 130.00 4 EXPENSES: WEEK MONTH YEAR Home Mortgage $ $ 1,650.00 $ 19.800.00 Rent $ $ $ Maintenance $ $ $ 300.00 Utilities Electric $ $ 180.00 $ 2,160.00 Gas $ $ $ Oil $ $ $ Telephone $ $ 25,00 $ 300,00 Water $ $ 50.00 $ 600.00 Sewer $ $ 17.00 $ 204.00 Employment Public Transportation $ $ $ Lunch $ $ 100.00 $ 1,200.00 Taxes Real Estate $ $ $ Personal Property $ $ $ 25,00 Income $ $ $ Insurance Homeowners $ $ $ Automobile $ $ $ 1,168.00 Life $ $ 28.65 $ 344.00 Accident $ $ $ Health $ $ $ Other $ $ $ Automobile Payments $ $ $ Fuel $ $ 125.00 $ 11500.00 Repairs $ $ $ 11500.00 Medical Doctor $ $ $ 200.00 Dentist $ $ $ 500.00 Orthodontist $ $ $ Hospital $ $ $ Medicine $ $ $ 200.00 5 Special needs ( ) $ $ $ Education Private School $ $ $ Parochial School $ $ $ College $ $ $ Religious $ $ $ Personal Clothing $ $ $ 11000.00 Food $ $ 200.00 $ 2.400.00 Barber/Hairdresser $ $ $ 234.00 Credit Payments $ $ $ Credit Card $ $ $ Charge Account $ $ $ Memberships $ $ $ 50.00 Loans Credit Union $ $ $ Loans Miscellaneous Household Help $ $ $ Child Care $ $ $ Papers/Books/Magazines $ $ $ 100.00 Entertainment $ $ $ 500.00 Pay TV $ $ 35.00 $ 420.00 Vacation $ $ $ 500.00 Gifts $ $ $ 1.000.00 Legal Fees $ $ $ 500.00 Charitable Contributions $ $ $ 200.00 Other Child Support $ $ $ Alimony Payments $ $ $ Other Total Expenses $ $ $ 36.905.00 6 RUSSELL R. GUTSHALL, III Plaintiff V. SANDRA M. GUTSHALL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-5578 CIVIL TERM IN DIVORCE INCOME AND EXPENSES STATEMENT INVENTORY AND APPRAISEMENT OF PLAINTIFF Plaintiff, Russell R. Gutshall, III, files the following Inventory and Appraisement of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three (3) years. Plaintiff verified that the statements made in this Inventory and Appraisement are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities. Plaintiff ASSETS OF PARTIES Plaintiff, Russell R. Gutshall, III, marks on the list below those items applicable to the case at bar and itemizes the assets of the following pages. If an item has been appraised, a copy of the appraisal report is attached. (X) 1. Real Property (X) 2. Motor Vehicles ( ) 3. Stocks, bonds, securities and options ( ) 4. Certificates of deposit 7 ( ) 6. Savings accounts, money market and savings certificates (X) 7. Contents of safe deposit boxes ( ) 8. Trusts (X) 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. Business (list all owners, Including percentage of ownership, and offioar/director positions held by a party with company) ( ) 16. Employment termination benefits - severance pay, workmen's compensation claimlaward ( ) 17. Profit sharing plans (X) 18. Pension plan (indicate employee contribution and date plan vests) ( ) 19. Retirement plans, Individual Retirement Accounts ( ) 20. Disability payments ( ) 21. Litigation claims (matured and unmatured) ( ) 22. MilitaryN.A. benefits ( ) 23. Education benefits (X) 24. Debts due, including loans, mortgages held (X) 25. Household furnishings and personalty (Include as a total category and attach Itemized list if distribution of such asset is in dispute) ( ) 26. Other 8 Plaintiff, Russell R. Gutshall, III, marks on the list below those items applicable to the case at bar and itemizes the assets of the following pages. SECURED (X) 1. Mortgage ( ) 2. Judgments ( ) 3. Liens ( ) 4. Other secured liabilities UNSECURED (X) S. Credit card balances ( ) 6. Purchases (X) 7. Loan Payments ( ) 6. Notes payable ( ) 9. Other unsecured liabilities CONTINGENT OR DEFERRED ( ) 10. Contracts or Agreements ( ) 11. Promissory Notes ( ) 12. Lawsuits ( ) 13. Options ( ) 14. Taxes ( ) 15. Other contingent or deferred liabilities 9 ?i a °a w 6 0 0 a 0 0 T G m .7 L a A 0 '.rJ 3 K Q a N a •0 a X ? a.+ W z u w a a m a a a N a a a a a a I ?I w G ? z ? ? ? ? a z ? 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GUTSHALL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 5578 CIVIL IN DIVORCE AND NOW, this _// 1* day of , 2003, counsel having advised the Master's office on November 18, 2002, that the above captioned case was settled, and no agreement having been provided the Master's office, the appointment of the Master is vacated. BY THE COURT, cc: ?Peter J. Russo Attorney for Plaintiff ,/Susan M. Kadel Attorney for Defendant fly IrEff NNW M C& er, P.J. Oy-I?-0-3 RUSSELL R. GUTSHALL, III, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 99 - 5578 CIVIL SANDRA M. GUTSHALL, Defendant IN DIVORCE CONFERENCE WITH COUNSEL AND PARTIES TO: Peter J. Russo Counsel for Plaintiff Russell R. Gutshall, III Plaintiff Susan M. Kadel Counsel for Defendant Sandra M. Gutshall Defendant A conference has been scheduled at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 18th day of November 2002, at 9:00 a.m., with counsel and the parties to discuss the outstanding economic issues to determine if there is a basis of settlement of claims. If issues remain after the conference, a hearing will be scheduled at another date. Very truly yours, Date of Notice: 9/25/02 E. Robert Elicker, II Divorce Master ?rY RUSSELL R. GUTSHALL, III Plaintiff VS. SANDRA M.GUTSHALL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 99 - 5578 • NO. CIVIL 19 1N UIVORCh STATUS sHEur M Y. Rasom ATTORNEY AT LAW Suite 200.5010 East Trindie Road Mechanicsburg, PA 17050 Q(/leer In Carlisle, PA Thursday, September 19, 2002 E. Robert Elicker, II Divorce Master 9 N. Hanover Street Carlisle, PA 17013 RE: GUTSE ALL V. GUTSUALL Dear Mr. Elicker: PHONE: (717) 591.1755 FAX: (7171591-17S6 Please be advised that the mountain land in the above referenced matter has been sold and the parties have few remaining issues which require resolution. In effort to effectuate a resolution to the outstanding issues, I am asking that a conference be held so that we can narrow and/or settle those issues. Should you have any questions or concerns, please feel free to contact me. Very truly yours, PJR/alg Peter J usso CC: Susan Kadel Russ Gutshall 0 Nay. I??C?oor, TOO Irmo S? o-z? f i Date of Marriage: May 24, 1969 Date of Separation: Husband claims - August 6, 1999 Husband filed for divorce September 13, 1999 1. Marital Home 26 Stewart Drive Carlisle, PA 17013 2. Prudential IRA (W) (no post-separation contributions) December 31, 1999 - $4,918.91 December 31, 2001 3. Pioneer Fund (V) September 30, 1999 - $1,202.33 December 31, 2001 4. Prudential We Insurance (W) Policy #73431910 Cash surrender value - September 25, 1999 - $2,738.27 Cash surrender value - June 25, 2001 5. Sprint Retirement Plan (H) September 23, 1999 June 30, 2001 - $27,054.22 March 31, 2002 - $16,047.44 6. Cornerstone Federal Credit Union a.) Savings Account (H) b.) Christmas Clubs (H) c.) Vacation Clubs (H) d.) Checking Account (H) 7. Prudential Life Insurance Policies (H) (2 policies) $235,000.00 $4,435.37 $1,198.66 $2,622.62 $72,457.00 $67.57 $1,818.23 $3,396.07 $576.99 $1,597.58 $4,107.12 Total: $334,557.00 Additional Assets: 1. Mountain land (5.8 acres) (estimated net: $30,304.27) / 2 = $15,152.13 Port Royal, PA 2. Sprint Pension Plan (l) (*Also want survivor benefits for Wife) December 31, 1999 - monthly accrued benefit $2,814.00 8. 1987 Ford Aerostar Van (W) paid off 9. 1988 Ford Ranger Pick-up Truck (H) paid off 10. 1/3 interest in 1973 Starcraft Pick-up Camper 11. Household goods and fumishings 12. Longaberger Collection (Vi) 12 baskets 13. Gums and fishing equipment (H) 14. Utility Trailer (H) $780.00 $3,000.00 $1,000.00 -0- -0- $2,500.00 I 1. Cornerstone Federal Credit Union Line of Credit 2. First USA Credit Card 3. Discover Card 4. MBNA Card 5. CUNA Mortgage (3/8/02 balance) $3,389.00 $4,810.38 $875.86 $1,105.40 $138,765.79 $148,946.43 Total Assets: (-) Debts: Net Assets: 60% 40% $334,557.00 $148,946.00 $185,611.00 $111,366.60 $74,244.40 To Wife Marital home $235,000.00 To HHughAnndd Sprint Retirement Plan $72,457.00 Prudential IRA $4,435.37 Credit Union Savings $67.57 Pioneer Fund $1,198.66 Christmas Clubs $1,818.23 Prudential Life $2,622.62 Vacation Club $3,396.07 Van $780.00 Checking Account $576.99 Prudential Life Insurance (1) $1,597.58 (2) $4,107.12 Ford Pick-up $3,000.00 1/3 interest in camper $1,000.00 Utility trailer $2,500.00 Total: $244,036.65 $90,520.56 (-)Debts mortgage ($138,765.79) Credit cards ($10,180.64) $105,270.86 (56.7 1% distribution) $80,339.92 Office of Divorce Master 9 North Hanover Street Carlisle, Pennsylvania 17013 RUSSELL R. GUTSHALL, III 26 STEWART DRIVE CARLISLE, PA 17013 A ? INSUFFICIENT ADDRESS G O ATTEMPTED No SUCH NT KNOWN E3 OTHER OS QWUN DELI E FONWRNOOORESSED '4W i !tl:tl RUSSEL R. GUTSHALL, III, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 99 - 5578 CIVIL SANDRA M. GUTSHALL, Defendant IN DIVORCE CONFERENCE WITH COUNSEL AND THE PARTIES TO: Peter J. Russo Russell R. Gutshall, III Counsel for Plaintiff Plaintiff Susan M. Kadel Sandra M. Gutshall Counsel for Defendant Defendant A conference has been scheduled at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 31st day of May 2002, at 9:00 a.m., with counsel and the parties to discuss the outstanding economic issues to determine if there is a basis of settlement of claims. If issues remain after the conference, a hearing will be scheduled at another date. Date of Notice: April 22, 2002 Very truly yours, E. Robert Elicker, II Divorce Master 0 8 >1 o ? m 78 a a a , , 4 a a Fc? H? H? CD O p O O O O O t? O M N 0 0 0 0 O O O N N a H r O O O O O O O v 1 V i 000 y y 00 00 Oo Oa 00 o ? 00 C 6s C u9 O 69 O O C 69 G O O O M M a O t n +1 to ._ . ? N W1 O M 00 O V? O %ci It a y? y? N 7 1e O b9 VM9 fA 0 69 Wf M 69 00 M 00 en 69 N V3 6 Vf 69 69 O 0 O 0 O 0 O .-? O ON O? t., v1 O O O O 0 O 0 O 0 O 0 O O O O O O O t` l? N ON O O ` h h D\ 0 CD N •,Z y C y9 C O O 69 O d\ t` t %0 G 69 C to O O C O O O C y9 C O O fH C 69 t` 00 t- 00 IT O\ vi O r M N In r O\ h n to rs %0 to N N N b 7 d' V1 ?f 6q ? U% 6s C; N ^ Vf 6 9 V 69 U 9 Vf N N O O O O - O rn m r- Vl r- O M N O O O O O O O O O O O O O O a O 00 0 o O n b ? 06 C O C C C O O O a N O O v t, V1 69 M 00 ?O CD CD V1 0 N (= O -- 0 O? O r r. -- V' 69 M 4 V! 00 69 ? M 06 CD en en Vf NN 69 69 Vf 69 69 69 6 9 00 CD fA 00 r 00 00 !w 00 N M P O O OO p o O 0 O O O O O O M O O O O O 0 O 0 O O M M I yg o C C C c c C C C O C C C C b9 N i fH 69 fig 69 69 69 y9 69 fA fA f/a 69 69 vi O O .? 0^0 C O O O t` M 0 0 O O O M 00 O O C O O N 0 0 0 0 0 0 O DD M O O O O V Q\ t- ' ?o 00 O C O Cl O C C vl O` O O V A 6.j M O r- O !` O, n V 1 t-? O M •••? DD O b O V1 C O O C O 11 O O N W M •- 00 O .-' N M N N b en a O N 00 O M N M M V r 00 Vi 69 fn 69 y9 69 fA fA 69 fA y9 Vi 69 Vi 69 69 66 69 Wi 69 7 vl C O ^' ?~++ 4 Q ? A A ? A S S U a a ? ? ] o E w w ? w w? W w c A U> ° a vFi E :3 s 2! 4) 4) 4L) u c o a x a U [- e (U U ? 0 0 = G c a v n A o dl 'a o , u o o 2 2 e o ? = a O ti A fn UQ U U6 Uw UU a a cn x .. -, h UU u.C7 . AC7 C7 F Suite 200. $010 East Trindle Road Mechanicsburg, PA 17050 OJ/lees in Carlisle, PA ATTORNEY AT LAW Wednesday, August 22, 2001 Susan M. Kadal, Esquire James, Smith, Durkin & Connelly 134 Sipe Avenue Hummelstown, PA 17036 RE: GUTSHALL v. GUTSHALL Dear Ms. Kadal: PHONE: (717) 591.1755 FAX: (717) 591-1756 Attached please find a copy of a Proposed Distribution of Assets in the above-captioned matter. Obviously, if we can sell the marital residence and the land, your client can have the $60,913.92 in cash. In the alternative, I look forward to your suggestions. There are also several items of person property that my client wishes to retain: a Family dishes a Wooden bowl made by Mr. Gutshall a Grandfather's butcher block e Guns a Some photographs of children, as well as his hunting and fishing photos a His TV a Tools # Gvrli3 It is Mr. Gutshall's intent that any items belonging to the children will remain with them. Hopefully, this matter can be concluded. Please review the attached and convey your thoughts. In the meanwhile, should you have any questions or concerns, please feel free to contact me. Very truly yours, Peter . Russo, Esquire <2 - Please Reply To: MECHANICSBURG OFFICE PROPOSED DIVISION OF ASSETS GUTSHALL Y. GUTSHALL MARITAL ASSETS ASSET VALUE MARITAL PORTION Marital Home $235,00000 $ 235 000.00 Unimproved Mtn. Land $14,000.00 $ 14 000.00 Difference in Value of Vehicles Owned by the Parties $1,000.00 $1,000.00 Sprint Retirement $24,740.01 $24,740,01 Cornerstone FCU Checking Acct. $ 576.99 $ 576.99 Cornerstone FCU Savings Acct. $ 67.57 $ 67.57 Cornerstone FCU Christmas Club Acct. $ 1.818.23 $1,818.23 Cornerstone FCU Vacation Club Acct. $3,396.07 $3,396.07 Prudential Life Insurance Policy $1,600.00 $1,600.00 Prudential Life Insurance Policy $4,500.00 $4,500.00 Safety Deposit Box Contents $ 200.00 $ 200.00 Household Goods & Furnishings $8,000,00 $8 OOO.bo 1/3 Interest in Camper Trailer $100.00 $100.00 Longaberger Basket Collection $3,000.00 $3,000.00 Jewel Collection $3,000.00 $3,000.00 Subtotal $300,998.87 $300,998.87 Divided Equally Portion to Each Party $150,499.43 $150,499.43 MARITAL OBLIGATIONS Marital Oblieation Value at Amount Amount Difference Separation A¢reed to Paid by be Paid Husband Mortgage on Marital Residence $150,000.00 $150 000.00 Cornerstone FCU Line of , Credit $3,389.83 I0d 0 $3,389.83 $0.00 First USA Card $4,810.38 $4,810.38 $0.00 Discover Card $875.86 $875.86 $0.00 MBNA American Visa Card $1,105.40 $1,105.40 $0.00 PNC Bank Personal Loan $2,246.88 $2,246.88 $0.00 or Daughter's Education TOTAL OBLIGATIONS $162,428.35 $12,42815 $150,000.00 Obligations Divided Equally TOTAL OBLIGATION PER $81.214.18 $6 214.18 DIVISION OF ASSETS ITEM MR. GUTSHALL MRS. GUTSHALL One Half of Marital Assets One Half of Marital Debt $150,499.43 $81,214.18 $150,499.43 $81,214.18 Subtotal $69,285.25 $69295.25 %2 Amounts Paid b H $6,214.18 $6,214.18) 'h Amounts Retained b W $2,607.15 $2,607.15 Amounts Held in Escrow TOTAL DUE $78.106.58 $60463.92 RUSSELL R. GUTSHALL, III, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 99 - 5578 CIVIL SANDRA M. GUTSHALL, Defendant IN DIVORCE RESCHEDULED CONFERENCE WITH COUNSEL AND THE PARTIES TO: Peter J. Russo , Counsel for Plaintiff Russell R. Gutshall, III , Plaintiff Susan M. Kadel Counsel for Defendant Sandra M. Gutshall Defendant A conference has been scheduled at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 1st day of August 2002, at 9:00 a.m., with counsel and the parties to discuss the outstanding economic issues to determine if there is a basis of settlement of claims. If issues remain after the conference, a hearing will be scheduled at another date. Very truly yours, Date of Notice: E. Robert Elicker, II June 6, 2002 Divorce master RUSSEL R. GUTSHALL, III, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 99 - 5578 CIVIL SANDRA M. GUTSHALL, Defendant IN DIVORCE CONFERENCE WITH COUNSEL AND THE PARTIES TO: Peter J. Russo Counsel for Plaintiff Russell R. Gutshall, III Plaintiff Susan M. Kadel Counsel for Defendant Sandra M. Gutshall Defendant A conference has been scheduled at the office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 31st day of May 2002, at 9:00 a.m., with counsel and the parties to discuss the outstanding economic issues to determine if there is a basis of settlement of claims. If issues remain after the conference, a hearing will be scheduled at another date. Very truly yours, Date of Notice: E. Robert Elicker, II April 22, 2002 Divorce Master MAY. -29, 02 (WED) 12.43 JAMES SMITH DURKIN k CONNELLY TEL1717 533 3280 P,002/OD2 IID/gh Uk 141St PAA ,a, ,.-,1 w.?? ter- - ArrORNBY AT LAW Malu10D • SeI4 >Rsctt1ln01c Rat PHONE: (717) 601475F aacbcdabars, PA 17oab FA%: (7171 Sf1.17Sb oDWt nl C'WHek,1% Tuesday, May 189 2002 2. Robert Elieker, H Divorce Master 9 N. Hanover street Carlisle, PA 17013 Rai CUTSH ILL v, GUTSHALL Dear Mr. Blieker: I write concerning the conference adwiluled for May 31, 2002. Our office has requested a conrinuen= Opposing counsel, Susan M. Kadel, Esquire, has agreed to the continuance, by placing her aignatu)e below. I understand that Tracy is out until Tuesday, and therefore we oaimot reschedule until then. Both parries will appreciate a now confercace date act as quickly as time permits you to do so. Thank you for your cooperation in this matter. gsd6rEsquire, Counsel for Defendant Very truly yours, lb" MWW944- Melissa M. Mehafft Paralegal oe: Susan M. Kadel, Esquire Russell R. Outshalb III OFFICE OF DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEAS 9 North Hanover Street Carlisle, PA 17013 (717) 240-6535 E. Robert Elicker, II West Shore Divorce Master 697-0371 Ext. 6535 Traci Jo Colyer Office Manager/Reporter February 19, 2002 Peter J. Russo, Esquire Susan M. Kadel 5010 E. Trindle Road Attorney at Law Mechanicsburg, PA 17050 JAMES, SMITH, DURKIN & CONNELLY P.O. Box 650 Hershey, PA 17033-0650 RE: Russell R. Gutshall, III vs. Sandra M. Gutshall No. 99 - 5578 Civil In Divorce Dear Mr. Russo and Ms. Kadel: It appears as if discovery is nearly complete and that what has to be exchanged between counsel can be done before a pre-hearing conference. Consequently, I am going to proceed with a directive for pretrial statements. A divorce complaint was filed on September 13, 1999, raising grounds for divorce of irretrievable breakdown of the marriage and the economic claim of equitable distribution. I assume that the parties will sign affidavits of consent and waivers of notice of intention to request entry of divorce decree or in the alternative have been separated for a period in excess of two years so that the divorce can proceed under either Section 3301(c) of 3301(d) of the Domestic Relations Code. On October 18, 1999, the Defendant filed a petition raising additional economic claims of alimony, alimony pendente lite, and counsel fees and expenses. In accordance with P.R.C.P. 1920.33(b) I am directing each counsel to file a pretrial statement on or before Friday, March 15, 2002. Upon receipt of the pretrial Mr. Russo and Ms. Kadel, Attorneys at Law 19 February 2002 Pace 2 statements, I will immediately schedule a pre-hearing conference with counsel to discuss the issues and, if necessary, schedule a hearing. Very truly yours, E. Robert Elicker, II Divorce Master NOTE: Sanctions for failure to file the pretrial statements are set forth in subdivision (c) 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. IAMl5 SMITH DuKKIN & CONNELLY UP Sumo M. Kudd smk@jsdlcgal.com .Ir_RSN.FA February 13, 2002 " . E. Robert Elicker, II Divorce Master 9 North Hanover Street Carlisle, PA 17013 Re: Russell R. Gutshall, III v. Sandra M. Gutshall No. 99-5578 GARY L, JAMES Dear Mr. Elicker: MAa J SMRH, JR. KAREN DNRKIN JOHN J. C@WELLY, JR. I am writing in response to the certification filed by Peter J. Russo, counsel for STEVEN A. SNNE SCOTT A DIETTEmoK Plaintiff in the above-captioned matter. I believe that discovery is substantially GREGORY K. RICHARDS RICHARD L DAHLEN completed, however, there are several additional documents which I have requested that J . K A AN W M Plaintiff's counsel voluntarily provide me in preparation for a hearing in this matter. If ANDE ARA . DE ARLMAN DONNA M. MULLIN that information is voluntarily provided, I could expect to be prepared for a pre-trial EDWARD P. SEEBER NEIL W. YARN conference within one month. If it is necessary to file a Motion for Additional BERNARD A. RYAN, JR. Discovery, which I have no reason to believe will be necessary, it would delay the OF COUNSEL: A E B proceedings. NDREW ARBIN Sincceerrell Susan M. Kadel SMK:has cc: Peter J. Russo, Esquire Sandra M. Gutshall RUSSELL R. GUTSHALL, III, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 99 - 5578 CIVIL SANDRA M. GUTSHALL, Defendant IN DIVORCE NOTICE OF PRE-HEARING CONFERENCE TO: Peter J. Russo , Attorney for Plaintiff Susan M. Kadel , Attorney for Defendant A pre-hearing conference has been scheduled at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 22nd of April, 2002, 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: 3/27/02 E. Robert Elicker, II Divorce Master AUG 1 7 2001 RUSSELL R. GUTSHALL, III, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 99 - 5578 CIVIL SANDRA M. GUTSHALL, Defendant IN DIVORCE TO: Peter J. Russo Attorney for Plaintiff Susan M. Kadel Attorney for Defendant DATE: Monday, August 6, 2001 CERTIFICATION OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. Defendant has not yet received information regarding the Plaintiff's retirement benefits through his employer as well as information regarding any and all investment accounts and his income information. (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. Defendant currently has outstanding discovery requests in the form of Interrogatories and Request for Production of Documents directed to the Plaintiff. It is expected that discovery can be completed within sixty (60) days, provided that Defendant provides full and complete responses to the discovery. sol DATE SEL FOR PLAINTIFF ( ) COUNSEL FOR DEFENDANT (X ) NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. t FEB 1 2 2002'i RUSSELL R. GUTSHALL, III, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 99 - 5578 CIVIL SANDRA M. GUTSHALL, Defendant IN DIVORCE TO: Peter J. Russo Susan M. Kadel Attorney for Plaintiff Attorney for Defendant DATE: Monday, August 6, 2001 CERTIFICATION I certify that discovery is complete as to the claims for which the master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. a ? 10 0a DATE COUNSEL FOR PLAINTIFF (?- COUNSEL FOR DEFENDANT ( ) NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. RUSSELL R. GUTSHALL, III Plaintiff V. SANDRA M. GUTSHALL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-5578 CIVIL TERM IN DIVORCE INCOME AND EXPENSES STATEMENT INVENTORY AND APPRAISEMENT Of Plaintiff RUSSELL R. GUTSHALL, III Plaintiff v SANDRA M. GUTSHALL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-5578 CIVIL TERM IN DIVORCE INCOME AND EXPENSES STATEMENT INVENTORY AND APPRAISEMENT AND ASSETS OF PARTIES NOTICE BOTH PARTIES TO A DIVORCE ACTION ARE REQUIRED TO FILE WITH THE PROTHONOTARY AN INVENTORY AND APPRAISEMENT OF ALL PROPERTY OWNED OR POSSESSED AT THE TIME THE ACTION COMMENCES AND ALL PROPERTY TRANSFERRED WITHIN THE PRECEDING THREE (3) YEARS. YOU MUST COMPLETE THIS FORM AND FILE IT WITHIN SIXTY (60) DAYS OF RECEIPT OF THIS STATEMENT. IN ADDITION TO FILING THIS COMPLETED FORM WITH THE PROTHONOTARY, YOU MUST ALSO SERVE A TRUE AND CORRECT COPY OF THIS FORM ON THE OTHER PARTY TO THE DIVORCE, PURSUANT TO RULE OF COURT. THIS STATEMENT SHALL INCLUDE THE INFORMATION REQUESTED AS ATTACHED. YOU MAY NEED ADDITIONAL ROOM TO COMPLETE THIS FORM. PLEASE KEEP EACH CATEGORY SEPARATE AND FOLLOW THE FORM AS CLOSELY AS POSSIBLE. IF YOU DO NOT FILE THE INVENTORY AND APPRAISEMENT AS REQUIRED, SANCTIONS MAY BE IMPOSED AGAINST YOU BY THE COURT. INCOME AND EXPENSE STATEMENT Both parties to a divorce action are required to file with the Prothonotary a complete income and expense statement. You must complete this form and file it within 30 days of receipt of this statement. If you are self- employed or if you are salaried by a business of which you are owner in whole or in part, you must also fill out the Supplemental Income Statement. INCOME Pay Period: (weekly, bi-w( Gross Pay per Pay Period: Itemized Payroll Deductions: Federal Withholding $ 825.91 Social Security $ 202.31 Local Wage Tax $ 33.15 State Income Tax $ 90.61 Retirement $ Savings Bonds k Credit Union $ - 1175.00 Life Insurance $ 43.37 Health Insurance $ 340.13 Other (PAC/UW) $ 21.00 PA Unemployment $ Flex Credit $ (305.58) Before Tax Savings $ After Tax Savings $ Occupational Tax $ Medicare $ 47.32 Net Pay per Period $ 835.34 3 SOCIAL SECURITY NO.: 193-36-3669 DATED: -7-35--v INCOME FROM ALL SOURCES: WEEK MONTH YEAR Interest $ $ $ 130.00 Dividends $ $ $ Pension $ $ $ Annuity $ $ $ Social Security $ $ $ Rents $ $ $ Royalties $_ $ $ Expense Account $ $ $ Gifts $ $ $ Unemployment Compensation $ $ $ Workmen's Compensation $ $ $- Other $ $ $ Total $ $ $ 130.00 TOTAL INCOME $ $ $ 130.00 4 EXPENSES: WEEK MONTH YEAR Home Mortgage $ $ 1.650.00 $ 19.800.00 Rent $ $ $ Maintenance $ $ $ 300.00 Utilities Electric $ $ 180.00 $ 2.160.00 Gas $ $ $ Oil $ $ $ Telephone $ $ 25.00 $ 300.00 Water $ $ 50.00 $ 600.00 Sewer $ $ 17.00 $ 204.00 Employment Public Transportation $ $ $ Lunch $ $ 100.00 $ 1,200.00 Taxes Real Estate $ $ $ Personal Property $ $ $ 25.00 Income $ $ $ Insurance Homeowners $ $ $ Automobile $ $ $ 1,168.00 Life $ $ 28.65 $ 344.00 Accident $ $ $ Health $ $ $ Other $ $ $ Automobile Payments $ $ $ Fuel $ $ 125.00 $_ 1,500.00 Repairs $ $ $ 1.500.00 Medical Doctor $ $_ $ 200.00 Dentist $ $ $ 500.00 Orthodontist $ $ $ Hospital $ $ $ Medicine $ $ $ 200.00 5 Special needs ( $ $ $ Education Private School $ $ $ Parochial School $ $ $ College $ $ $ Religious $ $ $ Personal Clothing $ $ $ 1.000.00 Food $ $ 200.00 $ 2.400 00 Barber/Hairdresser $ $ $ . 234.00 Credit Payments $ $ $ Credit Card $ $ $ Charge Account $ $ $ Memberships $ $ $ 50.00 Loans Credit Union $ $ $ Loans Miscellaneous Household Help $ $ $ Child Care $ $ $ Papers/Books/Magazines $ $ $ 100.00 Entertainment $ $ $ 500.00 Pay TV $ $ 35.00 $ 420.00 Vacation $ $ $ 50000 Gifts $ $ $ 11000.00 Legal Fees $ $ $ 500.00 Charitable Contributions $ $ $ 20000 Other Child Support $ $ $ Alimony Payments $ $ $ Other Total Expenses $ $ $ 36.905.00 6 RUSSELL R. GUTSHALL, III Plaintiff V. SANDRA M. GUTSHALL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-5578 CIVIL TERM IN DIVORCE INCOME AND EXPENSES STATEMENT INVENTORY AND APPRAISEMENT OF PLAINTIFF Plaintiff, Russell R. Gutshall, III, files the following Inventory and Appraisement of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three (3) years. Plaintiff verified that the statements made in this Inventory and Appraisement are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities. Plaintiff ASSETS OF PARTIES Plaintiff, Russell R. Gutshall, III, marks on the list below those items applicable to the case at bar and itemizes the assets of the following pages. If an item has been appraised, a copy of the appraisal report is attached. (X) 1. Real Property (X) 2. Motor Vehicles ( ) 3. Stocks, bonds, securities and options ( ) 4. Certificates of deposit 7 ( ) 6.. Savings accounts, money market and savings certificates (X) 7. Contents of safe deposit boxes ( ) 8. Trusts (X) 9. Life insurance policies (indicate face value cash surrender valu d , e an current beneficiaries) ( ) 10. Annuities ( ) 11. Gifts ( ) 12. Inheritances ( ) 13. Patents, copyrights, inventions, royalties ( ) 14. Personal property outside the home ( ) 15. Business (list all owners, including percentage of ownership, and officer/director positions held by a party with company) ( ) 16. Employment termination benefits - severance pay, workmen's compensation claim/award ( ) 17. Profit sharing plans (X) 18. Pension plan (indicate employee contribution and date plan vests) ( ) 19. Retirement plans, Individual Retirement Accounts ( ) 20. Disability payments ( ) 21. Litigation claims (matured and unmatured) ( ) 22. MIIItaryN.A. benefits ( ) 23. Education benefits (X) 24. Debts due, including loans, mortgages held (X) 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such asset is in dispute) ( ) 26. Other 8 Plaintiff, Russell R. Gutshall, III, marks on the list below those items applicable to the case at bar and itemizes the assets of the following pages. SECURED (X) 1. Mortgage ( ) 2. Judgments ( ) 3. Liens ( ) 4. Other secured liabilities (X) 5. Credit card balances ( ) 8. Purchases (X) 7. Loan Payments ( ) 8. Notes payable ( ) 9. Other unsecured liabilities CONTINGENT OR DEFERRED ( ) 10. Contracts or Agreements ( ) 11. Promissory Notes ( ) 12. Lawsuits ( ) 13. Options ( ) 14. Taxes ( ) 15. Other contingent or deferred liabilities W O a 0 0 a ° 0 •s ..y o? .C 0 3 .8 Q a N i A a v w? ] ? U w a a a ? ? a a a ° W ? a a z ? ? a a a a ? z ? ? z a 8 8 N N t1 N N O C C C ? ? g g S O p? g N pp O ' Q ° U N N M p 8 n h p g pp O e1 V1 V1 w wo I 'I $ o . ? 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GUTSHALL, Defendant/Petitioner IN THE COURT Or COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION CIVIL ACTION - LAW NO. 99-5578 CIVIL TERM ORDER OF COURT AND NOW, this 2nd day of December, 1999, based upon the Court's determination that Petitioner's monthly net income/eaming capacity is $974.39 per month and Respondent's monthly net income/earning capacity is $4,528.21 per month, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $453.00 a month payable bi-weekly as follows; $208.47 bi weekly ($185.46 bi-weekly for alimony pendente lite and $23.01 bi-weekly on arrears). First payment due with next pay date. Arrears set at $806.00 as of December 2, 1999. The effective date of the order is October 18, 1999. This order is based upon the parties residing in the marital home and husband making direct contribution to all household expenses. Husband is to make a lump sum payment of $403.00 to wife, through the parties' attorneys, on or before December 17, 1999. Wife's attorney is to report to DRO that said payment has been made for due credit. Husband is to make direct payment on the amount of 31% of any net bonus to wife and to provide verification of said bonus and payment to DRO within five days of receipt of any bonus. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C.S.§ 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the PA SCDU to Sandra Gutshall: . Payments must be made by check or money order. All checks and money orders must be made payable to PA SCDU and mailed to: PA SCDU P.U. Box 69110 Harrisburg, PA 17106-9110 Payments must include the defendant's PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. Unreimbursed medical expenses that exceed $250.00 annually are to be paid 0% by the respondent and 100% by petitioner. The plaintiff is responsible to pay the first $250.00 annually in unreimbursed medical expenses. Petitioner to provide medical insurance coverage. Within thirty (30) days after the entry of this order, the Petitioner shall submit written proof that medical insurance coverage has been obtained or that application for coverage has been made. Proof of coverage shall consist, at a minimum, of 1) the name of :he health care coverage provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims should be made; 5) a description of any restrictions on usage, such as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms. This Order shall become final ten days after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary for a hearing de novo before the Court. DRO: R. J. Shadday BY THE COURT, Mai ed pies on Petitioner to: < Respondent Samuel Andes, Esquire Kathleen Carey Daley, Esquire 4k? Edward E. Guido J. CY tt) U.I r7 "f 1 J un' J.i ? ,rz V a M cn U -• b a `r c r- Fn - , z j LZ ?+-'L V z' Z i LIJ 'C'' LC? rn U B ? RUSSELL R. GUTSHALL, III, Plaintiff, V. SANDRA M. GUTSHALL, Defendant J , .c IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA No. 99-5578 CIVIL TERM IN DIVORCE DEFENDANT'S PRE-TRIAL STATEMENT Date of Marriage: May 24, 1969 Date of Separation: September 13, 1999 Divorce Complaint filing date: September 13, 1999 Sandra M. Gutshall is currently 54 years of age having been born on June 29, 1948. Russell R. Gutshall, III, is currently 54 years of age having been bom on February 3, 1948. 1. ASSETS A. Marital Property Value 1. Marital Home $235,000.00* 26 Stewart Drive Carlisle, PA 17013 * Pursuant to market analysis performed by William L. Shearer, Jr., CRS, on behalf of Plaintiff. 2. Mountain Land (5.8 acres) Port Royal, PA $35,000.00* * Recommended listing by Century 21 Realtor 3. Prudential IRA (W) $4,435.37 (no contributions or withdrawals (as of 12/31/01) post-separation) I 4. Pioneer Fund (W) $1,198.66 (no contributions or withdrawals (as of 12/31/01) post-separation) 5. Prudential Life insurance (W) $2,738.27 Policy # 73431910 Cash Surrender Value 09/25/1999 6. Sprint Retirement Plan (H) $72 457.00 (need current statement from Defendant) (9/23/1999) 7. Sprint Pension Plan (H) $2,854.00 (Defined Benefit Plan) (accrued monthly benefit as of 12/31/00) Plaintiff has not yet provided Defendant with Date of Separation accrued benefit. 8. Cornerstone Federal Credit Union (H) (Date of Separation Values) a. Savings Account $67.57 b. Christmas Club $1,818.23 c. Vacation Club $3,396.07 d. Checking Account $576.99 9. Prudential Life ksurance Policies (2) (11) a. # 24 901305 $4,107.12 (10/27/99) b. # D80 905 186 $1,597.38 (10/27/99) 10. 1987 Ford Aerostar van (w) $780.00 - Blue Book Value 11. 1988 Ford Ranger - Pick-Up Truck Need mileage information from Plaintiff to determine value 12. 1/3 interest in Starcraft Pick-Up Camper (H) $750.00 13. Utility Trailer (I4) $2,500.00 14. Guns and Fishing equipment (li) To be provided 15. Fishing Boat/Trailer (H) To be provided 16. Custom Golf Clubs with Accessories (I? To be provided 17. Longaberger Baskets (12) (W) $500.00 B. Non-marital Property 1. TIAA-CREF Account (W) $2,154.05 (12/31/01) This asset was acquired in its entirety after separation. 2. EXPERT WITNESSES The Defendant may present the testimony of a real estate appraiser if the parties cannot agree on a value for the marital home and mountain land properties. 3. NON-EXPERT WITNESSES Wanita Stewart 1314 Wilson Street Chambersburg, PA Ms. Stewart is Russell R. Gutshall's paramour and will be called to testify regarding her relationship with Mr. Gutshall prior to the parties' separation. Defendant knows of no other non-expert witness at this time with the exception of the parties. However, Defendant reserves the right to supplement this answer should such become available. 4. EXHIBITS (a). Sandra Gutshall's 2001 W-2 (Exhibit A) A . ' (b). Sandra Gutshall's 2001 Federal Income Tax Return (to be provided when prepared) (c). Sandra Gutshall's recent paystub (Exhibit B) (3/1/02 stub attached) More recent paystubs will be submitted at the hearing (d). Sandra Gutshall's 2000 W-2 and Federal Income Tax Return (Exhibit C) (e). Current CUNA mortgage statement - not provided as not in Defendant's possession (f). Prudential Statements for Sandra Gutshall (Exhibit D) (g). Credit Card and Cornerstone Federal Credit Union Statements (Exhibit E) (h). Prudential Life Insurance Statement for Defendant (Exhibit F) (i). Prudential Life Insurance Statement for Plaintiff (Exhibit G) (j). Card from Wanita Stewart to Russell Gutshall (Exhibit I) (k). Letter from Russell Gutshall to Wanita Stewart (Exhibit I) (I). Plaintiffs W-2's and Federal Income Tax Returns for 1998, 1999, 2000 and 2001 (not attached as in excess of three pages) (m). List of guns owned by Russell Gutsball (Exhibit J) (n). Pioneer Investments Statements (Exhibit K) (o). TIAA-CREF Statement (Exhibit L) (p). Sprint Retirement/Pension Statements (Exhibit M) 5. INCOME Sandra Gutshall is employed as an administrative assistant in the admissions office at Dickinson College. She is employed full-time and works 35 hours per week at the rate of $10.20 per hour for a weekly gross of $357.00 and an annual gross of $18,564.00. A . d Al I Her only other source of income is spousal support from Russell Gutshall in the amount of $453.00 per month pursuant to Order dated December 2,1999. The guideline amount of support was $1,421.53, however, as the parties were and continue to reside together, Plaintiff received a credit for his direct contribution to the household expenses, including his payment of the mortgage. 6. EXPENSES Sandra Gutshall intends to offer testimony of her expenses in support of her claim for alimony. An expense statement will be submitted well in advance of a hearing. 7. PENSIONS/RETIREMENT A. Plaintiff. Russell .ntah II Plaintiff has both a Retirement Plan and a Pension Plan through his employer. As of September 23, 1999, Mr. Gutshall's retirement plan had a balance of $72,457.27. After the parties' separation, Mr. Gutshall unilaterally removed funds from the retirement plan. Mr. Gutshall also has a Pension Plan through his employer and his monthly accrued benefit as of December 31, 2000 was $2,854.00. Plaintiff has not provided a statement regarding the date of separation accrued benefit. B. Defendant. Sandra Gutshall Defendant has a marital IRA with Prudential having a value of $4,435.37 as of December 31, 2001. Defendant also has a TTAA-CREF plan through her employer at Dickinson College. This account was valued at $2,154.05 as of 12/31/01 and is not marital as it accrued post-separation. 8. COUNSEL FEES Defendant is seeking reimbursement of counsel fees, costs and expenses. Documentation of the same will be submitted prior to the hearing. 9. MARITAL DEBTS A. CUNA Mortgage Plaintiff receives the mortgage statement and the last statement provided to Defendant was the August 2, 2001 statement showing a principal balance of $141,634.64. An updated statement is requested. B. Cornerstone Federal $3,389.00 Credit Union (H) C. First USA Credit Card (J) $4,745.81 (9/28/99) D. Discover Card (H) $845.04 (10/9/99) E. Sprint MBNA Card (H) Defendant believes that Husband is reimbursed by his employer for charges to this card and, accordingly, it would not be marital debt. 10. PROPOSED RESOLUTION v Defendant proposes that she retain the marital residence as part of the distribution of marital property. The Defendant further proposes that the marital property of the parties as identified by the Master be divided sixty (60%) percent to Defendant and forty (40%) percent to Plaintiff. Defendant is requesting alimony for an indefinite period of time in an amount commensurate with the support guidelines at the time of the Master's Hearing. Defendant also requests that Plaintiff be directed to maintain life insurance to secure the alimony payment in the event of Plaintiff's death. Respectfully submitted, Dater !d ewZ By: Susan M. Kadel, a Attorney for Defend P.O. Box 650 Hershey, PA 17033 (717) 533-328 PA I.D. No. 44837 Sandra M. Gutshall JAMES, SMITH, DURKIN & CONNELLY Exhibit "A" Py To Bo Filled N playee'o WE No. 2001 1 f 11166.111106 aOOnuolnumov 1 ve,, a, Din•rcamp, 2 ooor4lrnm.M.wt NI it 14 1 boa sear yWaleo sea secwr ymawt 0 mpayer numa r 20295.07 1258.27 23-1365954 a Ialom.w401snd Up, I Medicare lax wlnnllo 20295.07 294.26 o Employers name, aadre,o, ana ZIP ease Diekihaen Dollape ?0 Box 177.3 Cerl.iale, PA 17013-28% d Bmproy's's"Ps"Iseaunlyndmost 167-40-0748 e Mploye,4 Dome. admoe, and I eggs Sandra B GutshaLL 26 Stewart or. Corl.iate, M 17013 7 social security lips a Allonad tips a Advance tic payment t0 Oopment nu owng11 11 Nonaua1111ag plans 13em.emp. 11111.131. ard-panyslakpey 12, C 8.32 x 12b E 873.60 140ther Townshi p t2o Carlisle 12d PA 11622107 20286.75 568.01 u 110 b rte pi to out. wages, Uaa. boa 17 lat. Ineama ak .01M ,9pgna W 1g LpRII.cOm11 aA 20 Locality alms 20286.75 202.96 Legal 10.00 Dcaltaat rcrm w-. m,.p•.o.... cv...m.?„ , This intormstlon Is being furnllnaa to tM Ihtrmal R"Onus 6mm11. PY For to PLO B 2001 °6 11 ooa a (Iwo T an back of Cam 4 e ¦ COawel number t WaOU, ups, otner op lop. f Pasant income sec wnnn.lo 19421.47 2523.87 3 oust secanlYweOu A edculssurriviammthnel9 0 Employer 10 numb. 20295.07 1258.27 23 1365954 1 seedloaro wave, and Use a MselaaretAx Whnnsld 20295.07 294.26 e mPloe,Mnom.. atlafe,4.ing 2lP cage Dickinson CoLLepe Po Box 1775 Carl.iaLe, PA 17013-2696 a limploy11r849ca12eduntyn"imbu 167-GO-0748 e Enlployere name. adamn, and ZIP coda Sandra h 6utshaLL 26 Stewart or, Carlisle, PA 17013 7 600411seurnYllps a Allocated UPI 9 Advance EIC Paymsel to neponaent care o11ndea i t NengWlllled pans 32 8 i3 put. Emp. Rst.pan 3rd-Deny too, pay 121 C . X t2b E 873.60 140"r Township sec carlfele cad .PA 11622107 20286,75 568.01 168tau tmptolmranetolo testeawae,e. tips. sic, 171ut11reametae to LOalwages,Upp, sic. WL0u11ncomoul 201.09 MYnAm2 20286.75 202.96 Local 10.00 oeeu t a4I1W-2Waalanc na manm.m -- - Demo lumtln rG to IR3. II rose sea r,pYlr.g a Ills i as ratan. a NOdp,nge l. mlerm.4I, is Copy 2 TO Be Filed WIN Imployae' ate, 4 . 22'001 01,11 1119. C o gal I ca u Tax lilabim R L imi-cool, Dgnu .r MI I Wages, lips. olMr comp- f Foaenllncame xMthnela 19421,47 2523.87 o ao0m6scurnywape, 4 aalluaPMyok Wnnea 0 employer) number 20295.07 268.27 23-1365954 1 MIdi"18WR9seAPCliv11 a M•mMr.u:wltnn.w 20295.07 294.26 c Employers name, adores, Ina 21P coal Dickinson Cal Lepe PC Box 1773 Carlisle, PA 17013-2896 0 glop 101,284 socallecutny numuw 167-40-0748 e Employev, name, socrne. and ZIP cod, Sandra II SutshaLL 26 Stewart Dr. Carliste, PA 17013 7 local security ape aAlloafse lip' 1AOrne, 910 payment Ic.......ntwn.en111u 11 NonquAlIlled piano 1glaL fiMo. net.pan 3rd,panyaolt pay sea C 8.32 x 12b E 873.60 1a Other 7ownehip 12c Carlisle Ifs PA 11622107 20286.75 568.D1 t6 solo EmproYre4lutelp to Gat. wages. too, ltd, 17aunlnpoaeaM to Laal wain, apg, eta. WLbulmoomear 311 LOR4tYMms 20286.75 202.% Local 1D.00 occ t rmmw [wen one iaA ewwm•m -f" Filed WIN Employee's UUN, 09PY 2 To B 2001 QMB-ao. 154006 1 C er Laval Inca Tax Raturn a Control numpor 1 W4oe,,Up4 otsercomP. 0 ' 2 Peaemllncem• aaw110ha1d A7 i9 Z 2523.87 3 69041 sociality wages 4 Secauvoulhyaatvnhheld 9 Employer lip number 20295.07 1258.27 23-1365954 6 Mselun wages@no Ups 20295.07 6 Medical 141 w1111n614 294.26 e employees "Mo.&Odran,IngZIP coo, Dickinson COLLoge PD Box 1773 Carl.73Le, PA 17013-2896 9 EmplcysenUomalncYrltyn9mser 167-40-DT48 r Employers hams, 1041e,6 and 21P code Sandra N Gutshalt 26 Stewart Dr. Carlisle, ?A 17013 / go dial security lips I Angatal tips 6 A9vne• tiu payment I D D•Pndent sue Wants 11 IIPn91mllilltl Ouse 139ut.Emp. Rat.pan era-partysickpay U. C 8.32 x 120 E 873.60 14 oto.r lownshiP see Carlisle 123 PA 11622107 20286.75 568.01 166ata Emplovu'11141H0 16llgs w40se, Opa.Ilc. 178Yxincoal uA 16 LORI Wage. M. W. 19 iamincome aA 20 16.0aIIty Mme 20286.75 202.96 Local. 10.00 Occu t r arm vv. w.p. m. ,.. o,.,........ Exhibit "B" i i i i i i m .. rv Ln z_' z iL LL Q J W.WQ M 2 S 0 C m d %A Q W P. = O W Y } = Z Z i i 'Ae m;. ?N• l Yfii KiN ?.. • w L ? Jr lwe i Exhibit "C" ?i C-- C Fur EMPLOYEE'S RECORDS 20 0 ?MB No. 1 9 u Cott v =-, 1 Wssr. W, cuter comp. ] .Gerd Ynp is W. 6M.u ol wspn 2 Scosl "a my . So "M"W. W 6 Empny.r ID nomar r, 0 1019. 7n 6 16.mnan tmtp..nc np 6 L1.aaow W W44We a Empbysys n.IM, s6pI.Y..M ZI .666 Dickinson College P. O. Box 1773 Office of Financial Operations Carlisle, PA 17013-2B96 a m- o"" social.6comy mrnn.r 167-40-0748 6 Empoy«.. n,v,m, Woman. w a ma Sandra M Gutshall 26 Stewart Dr. Carlisle PA 17013 7 Scotia sastmy PW 6 A4=10 1w P Atl mr,oa EIC pym6n1 16 O.p.rtc?tt e.r. W. 11 Nonc,"Id p puu 12 BWW6. np6r46I n 60. 1 16 BM M1.in. Iw Oo6 13 to Ocur E 378.00 Townshi Name: Carlisle 16 ulworY .nWOY66 .USp sNnn plan L61p1 n0. 6mq mmp. PA 11622107 16334.50 457.34 100 E rQ6Rl O.7 17 9lsu'.."OP34., 50 16 sm 4rwm. W 19 Loos41y rani 20 Lo41 vs96., to. 6n. 21 Local Noon W Local 16334.50 163.41 IQ QQ1 66w6..1. ra er.m...n, This nlorimUM u aslrq Iwn.MO W INS IRS. 4 I sn r6.ulrM to 61.. W plum. • ngy4op..m wakylc swoon may G 6rma.6 M you 61tw mxwru 0 outmost end you Us W MM oepamnenl of to Tnesury. Intend lc w eenlde 11040 U.S. Individual Income Tax Return '2000 (300 Your first name kw? Me 19.) SANDRA Use the IRS label. Other- wise, pteue print or type. Presidential Election Cal (number or post M.I. Last name 01.1111A M GUTSHALL first Hare M.I. Las: name Suffix ind street). If you have a P. O. box, see page 1 B. Apt. no. Stale ZIP code Your social security no. 167-00.0748 Spouse's social security no. You MUST enter your SSN(s) above. NOTE. Checking "Yes" will not change your tax or reduce your refund. You Do you, or your spouse If filing a joint return, want $3 to go to this fund? 10 ?yw Spam* No I IYea I INo 1 5ingle Filing 2 Married filing joint return (even ff only one had income) Fert name: Wt name: Status 3 X Married filing separate return. Enter spouse's SSN above and full name here. ? RUSSELL F GUTSHALL III 4 Head of household (with qualifying person). (See page 19.) If the qualifying person is a child but not your Check only dependent, enter this child's name here. ? ssN: one box. 5 Qualif in widow er with dependent child ears ouse died ? See a e 1 . an MX Yourself. If your parent (or someone else) can daim you as a dependent No. of boxes checked Exemptions on his or her tax return, DO NOT check box Be. . . . . . . on Be and 61d b ?S owe . . . . . . No. of your children ........... c if more than alx dependents, see page 20. p Dependents: 1 First name Last name (2) Dependent! nodal security number ?)D•PendanCa Ht eae.I. r•Isaoruhlp Ilylne child lr to ou child m aedh on so who: • intad Wien You • ad not inn; with you die m dn.rce or aepaatldn Dependents an 6c not entered above Add numbers entered on 1 d Total number of exemptions claimed Imes above • • • ' 7 15 Income 7 Wages, salaries, tips, etc. Attach Form(s) W-2 . . . . • • • • • • Be Ba TAXABLE Interest. Attach Schedule B if required . . . . . Attach b Bb TAX-EXEMPT Interest. DG NOT include on Ilne Be . . . 9 Forms W-2 ¦nd w-20 hen. 9 Ordinary dividends. Attach Schedule B If required . of state and local income taxes (sae page 22) t ff 10 -- Alan •aachFarml •) 10 se s Taxable refunds, credits, or o 4 11 vw toss- withheld. Qheld. 11 12 Alimony received . . . . . . • • • • • • ' ' ' Business income or (loss). Attach Schedule C or GEZ . . . . h 0- 0 12 113 13 ere Capital gain or (loss). Attach Sch. D if required. I(nol required, check 1 4 arou dld nix o.t. w-2 seepig. 21. 14 Other gains or (losses). Attach Form 4797 .b Taxable amount . . . . 15b 15a Total IRA distributions . . . . 158 to Taxable amount 18b 18a Total pensions and annuities . 1Be 17 17 Rental real estate, royalties, partnerships, S corporations, trusts, etc. Attach Schedule E . . . . 18 18 Farm income or (loss). Attach Schedule F . . . . • • . • • • . ' ' . . 19 9 endaae. but da 19 Unemployment compensation ' . ' ' to Taxable amount efits ?20s b it 2 ._ notae.cn•any 20a 21 en y Social secur 5) s page 2 List type and amou as ( ee -°--°-- Other Income ,,. ` paymenc Alen, . pleus we _ ....... .............. .......................... ........ ..................... __.__.___?.?_.._. n? T6i<1<vour TOTAL INCOME _ .. 2 . 22 23 IRA deduction (see page 21) . . . . . . . . . . . . 24 Adjusted 24 Adjus Student loan Interest deduction (see page 27) . . • • 53 5 25 Medical savings account deduction. Attach Form 88 2 Gross 26 Moving expenses. Attach Form 3903 27 come In 27 One-half of self-employment tax. Attach Schedule SE 28 Self-employed health insurance deduction (see page 29) . 28 `.! 29 Self-employed SEP, SIMPLE, and qualified plans 29 30 30 Penalty on early withdrawal of savings 31a 31a 111- Alimony paid b Recipient's SSN 32 Add lines 23 through 312 ' our ADJUSTED GRO Thi i ' ' SS INCOME . ? 33 s s y Subtract line 32 from line 22. ae• ril.aleauro. Privacy Act. and Paperwork Reduction Act Notice, a" page 56. (HTA) Fem,1040(2000) SANDRA M GUTSHALL 16740-0748 Tax and J4 Amount from line 33 (adjusted gross income) Credits 330 Check If YOU ware B5 or older, ?Bllnd; SPOUSE was 85 or alder Q Bllnd 34 7 . 21 094 , . Add the number of boxes checked above and enter the total he - re ? 35a S b If you are memed filing separately and your spouse itemizes deductio ns, Standard <_ or you were a dual-status alien, sae page 31 and check here . ? 35b D eduction 36 Enter your ITEMIZED DEDUCTIONS from Schedule A, Ilne 28 OR STANDARD DEDUCTIO , N far Most shown on the left. BUT see page 31 to find your standard deduction If you People checked any box on line 35a or 35b OR If someone can claim you as a dependent . . , . 36 4 3115 Single: 37 Subtract line 36 from line 34 . . . . . . . . . . . . . . . . . 37 . . . . . . . . . . E4 400 38 If line 34 is $96,700 or less, multiply S2,800 by the total number of exemptions claimed 16 on One ad. If line 341s over $96,700, see the worksheet on page 32 for the amount to enter 38 Head of 39 TAXAB E 2 L INCOME. Subtract line 38 from line 37. if line 38 Is more than line 37 enter.0. 39 household: . 40 TAX J 13 56 450 (see pg 32). Check If any tax is from a Q Form(a) 8814 b n Form 4972 40 , . 41 Altern ti i i 2 a ve m n mum tax Attach Form 6251 . . . . . . . . 41 M 42 Add line 40 d 41 amed filing s an . . . . . . . . . . . . . ? 42 2 jointly or 43 Forei n t dit At F Oualf/ i g ax cre tach orm 1116 If required . . . , . . 4 43 y ng 4 Credit for child and dependent taro expenses Attach Form 2441 L44 I widow(er): . . . . . 45 _ $7,360 Credh for the eldedy or the disabled. Attach Schedule R 46 45 .1. Education credits. Attach Form 8863 . 47 46 Marded filing Child tax credit (see page 36) . . . . . . . . . . . 47 separately: 48 Adoption credit Att h F 8839 E3 675 ac orm . qg , 49 Other. Check If from a ? Form 3800 b E] Form 8396 n c []Form 8801 d Q Form (specify) 49 S^( 50 Add lines 43 through 49. These are your TOTAL CREDITS . . , 5 50 1 Subtract line 50 from line 42. If line 50 Is more than line 42, enter -0 . ? 51 2096 52 Seg-employment tax. Attach Schedule BE 52 Other 53 S i oc al security and Medicare tax on by Income not reported to employer Attach Form 4137 53 . . Taxes 54 T IR e ax on As, other r tirement plane, and MSAs. Attach Form 53291f required 54 . 55 Ad vance earned Income credit payments from Form(s) W-2 . . 55 . . . . . . . . . . . . 56 H h ld ouse o employment taxes. Attach Schedule H . . . . . . . , . . . 57 A 56 dd lines 51 through 56. This is our TOTAL TAX . be 57 2 098 Payments 58 Federal Income tax withheld from Forms W-2 and 1099. I f 56 1 996 . you have • qualilying 59 2000 estimated tax payments and amount applied from 1999 return . 59 T chid. Nash 8011 Earned income credit (EIC) . . . I 8011 ? Schadtile Elc• b Nontaxable earned income: amount .?I I *' and type-Do 81 Excess social security and RRTA tax withheld (see page 50) 61 62 Additional child tax credit Attach Form 8812 . . 62 63 Amount pald with request for extension to file (see pa a 50) 63 > r . . , , 64 Other payments. Check if from a ? Farm 2439 b?Forrn 4136. 64 85 Add lines 58, 59, 8011 and 81 throw h 64. Thus are your TOTAL PAYMENTS . Do 85 1 998 Refund 66 If line 55 Is more than line 57, subtract line 57 from line e.S. This Is the amount you OVERPAID. e a 67 66 a Amount of line 66 you want REFUNDED TO YOU . ? b ex r o.r 67a p iaei Routing number ? e Type: ? Checking Sevings an page ao d Account number .rd na n ere, ".'?,?.. e7p, ami are. _ 88 Amount of One 66 you went APPLIED TO YOUR 2001 ESTIMATED TAX . ? 66• Amount 69 If line 57 is more than line 65, subtract line 65 from line 57. This is the AMOUNT YOU OWE. You Owe For details on how to pay, see page 51 . . . , . . . . . . . . . . ? 7 69 100 0 Estimated tax penalty, Also include on line 69 70 tit at __?.. Here _..--- ---- _ , ...,.,..,e, ,,,.,.wv rewm Eno accompanying aoneauw anti at temenb, and to the but of my knowledge and ballot, they are bag, comet, and complete. Dedambon of prepare( lother than taxpayer) is based an ad inform ti f hl a on o w m empa Your signature Date Your occupation nor has any knowledge. Daytime phone no. J0M1 iiinil See Poe. 19. ' CLERK Kama ropy Spouse's signature. If a joint return, BOTH must sign. (Date Spouse's occupation Home phone no. for you rece(da. ( May the IRS discuss this return with the preparer shown below (see page 52)? Elyse ON, Paid Preparers Dare Check 8 = I Praperer's SSN or PTIN signature 4/10/2001 setf p loyed Q /00056641 Prepsrerrs Firm's name (or GROUP'S TAX B PAR L SERVICE EIN 23-2933775 Use Only yours If self-employed), ' 524 SOUTH PITT ST. Phone no 717.246.8681 . address, and ZIP coda CARLISLE State _ PA ZIP code 17013 Form 1040(2000) SCHEDULE A Schedule A - itemiied Deductions ome No 114 (Forth 1040) 2000 a.o.rtm.nl of ft Tr W Atannont s.ewese M. i l A . Imu. Mill Attach to Form 1040. See Instructions for Schedules A end B (Form 1060. 07 Name(s) shown on Form 1040 Your social security number SANDRA M GUTSHALL 167.40.0746 Medical Caution: Do not include expenses reimbursed or paid by others. and 1 Medical and dental expenses (see page A-2) 1 1.238 Dental 2 Enter amount from Form 1040, line 34. 2 21,094 Expenses 3 Multiply line 2 above by 7.5% (.075) . . . . . . . . . . . 3 1.582 4 Subtract line 3 from line 1. If line 3 is more than line 1, enter.0 . . 4 Taxes You 5 State and local income taxes . . . . . . . . . . . . . 5 823 Paid 6 Real estate taxes (see page A-2) . . . . . . . . . . . . 6 7 Personal property taxes . . . . . . . . . . . . . . . 7 287 (See 8 Other taxes. OPT___________________ $ 10 ..... Pegs A-2.) ......... ....••• ..........................................$...._.__......... 8 10 Interest 10 Home mcrtgage Interest and points reported to you on Form 1098 . . . . You Paid 11 Home mortgage interest not reported to you on Form 1098. If paid to the person from whom you bought the home, asp page (See page A.1.) A.3 and show that person's name, Identifying no., and address. Nam Addreee ............... ........ .... Note. TN ............................... .............................. Personal 12 Points not reported to you an Form 1098. See page A-3 Interest is for special rules not 13 Investment interest. Attach Form 4952 If required. (See deductible. page A-3.) . . . . . . . . . . . . . . . . . . . . Gifts to 15 Gifts by cash or check If you made any gift of $250 or Charity more, see page A4 . . . . . . . . . . . . . 15 1,425 16 Other than by cash or check. If any gift of $250 or more, If you made a gift see page A-4. You MUST attach Form 8283 If over $500 18 and got a benefit for 17 Carryover from prior year . . . . . . . . . . . . . . . 17 JOD Expenses 20 Unreimbursed employee expenses -job travel, union and Most dues, job education, etc. You MUST attach Form 2108 Other or 2106-EZ if required. (See page A-5.) Miscellaneous $ Deductions $ ..... 20 . ----- -• --- 21 Tax preparetion fees 21 50 22 Other expenses - investment, safe deposit box, etc. List type and amount SAFE DEP BOX $ 32 (See LEGAL FEES $ _ 2.300 ....................................................... page A-5 for .................. .....---•-- 22 2.332 expenses to 23 Add lines 20 through 22 . . . 23 2.382 deduct hero.) 24 Enter amount from Form 1040, line 34 24 21,094 25 Multiply line 24 above by 2% (.02) . . . . . . . . . . . 25 422 26 Subtract line 25 from line 23. If line 25 is more than line 23, enter -0. Other 27 Other - from list on page A-5. List type and amount Miscellaneous •- Deductions $ Total 28 Is Form 1040, line 34, over $128,950 (over $64,475 if married filing separately)? Itemized =X N0. Your deduction is not limited. Add the amounts in the for right column for Deductions lines 4 through 27. Also, enter this amount on Form 1040, line 36. =YES. Your deduction maybe limited. Seepage A-8 for the amount to enter. For Paperwork Reduction Act Notice, see Form 1040 Instructions. (WA) Schedule A (Form 1040) 2000 an Your Schedule B - Interest and Ordinary Dividends Interest 1 . List name of paver. If any interest is from a seller-financed mortgage and the buyer used the property as a personal residence, see page B-1 and list this interest first. Also, show that buyer's social security number and address (Sn page B-1 and the Instructions . for Form 1040, ........ ....................................... M&T BANK .. .................•-•••••'•••••••••-'- .......• line fin.) ••'••.. -'••'•_.._......____......_.......... ................................. .... . Note. If you .. ........... ..._.................................... ......................................................_...__......_.._.._......._.......... 1 received a Form .......... ....°.. . . . 1088-INr, Form .. .. . .. ______°___.._-..........___°____...____..........._.....°•-• 1089.OID, or substitute statement from a brokerage Ilan, Ilat the We name an the Is Continuation schedule for interest income ------------------------------------- 11 payer and enter c Interest income from K-1 s . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 the total Interest d Subtotal . . . . . . . . . . . . . . . . . . . . . . . . . it shown on that a Interest excluded from federal income . . . . . . . . . . . . . . . . . . . . 1i form. 2 Subtract line 1e from line 1d . . . . . . . . . . 2 3 Excludable interest on series EE and I U.S. savings bonds Issued after 1989 from Form 8815, line 14. You MUST attach Form 8815 . . . . . . . . . . . . . . . . . . . . 3 Ordinary 5 List name of payer. Include only ordinary dividends. If you received any capital gain Dividends distributions, see the instructions for Form 1040, line 13 (San pegs B-1 and the Instructions PIONEER FD CL A ____________________________________________._.....________......_.............____....._.. for Form 1040, line 8.) .."• ...................................................................................... Note. If you received s Form 109&DIV or substitute ........................................................................................... 5 statement from .__°_.°"•_.°_..""•••""._°°"'•.° .....................°--___..._........_._..."' a brokerage firm, list the firm's name as the payer ._ end enter the ordinary dividends _________________________________________________________________________________________ sham on that Is Continuation schedule for dividend income . at form, c Dividend Income from K-Is . . . . . . . . . . . . . . . . . . . . . . . . . . 5t d Subtotal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5t a Dividends excluded from federal income . . . . . . . . . . . . . . . . 5t 8 Subtract line Be from line 5d. Enter the result here and on Form 1040. line 9 . . . . . . . 6 Part III You must complete this pan If you (a) had over $400 of interest or ordinary dividends; (b) had a foreign Foreign account; or (c) received a distribution from, at were a grantor of, or a transferar to, a foreign trust. Yes Accounts 7a At any time during 2000, did you have an interest in or a signature or other authority over and a financial account in a foreign country, such as a bank account, securities account, or Trusts other financial account? See page B-2 for exceptions and filing requirements for Form TD F 90-221 Is If "Yes," enter the name of the foreign country (Sn 8 During 2000, did you receive a distribution from, or were you the grantor of, or transferor to, a page B-2. foreign trust? If "Yes," you may have to file Form 3520. See Pepe B-2 For Paperwork Reduction Act Notice, we Form 1040 Instructions. WA) Schedule B (Farm i J PLEASE 0000114173 DO NOT USE YOUR 2000 PAMr 4 MCI L-- LAbdEL 167-40-0748 GU 193-36-3669 EX RS R GUTSHALL SANDRA M A FS M FY 26 STEWART DR. SC 21110 CARLISLE PA 17013 PH 0 1A 16335.00 1B 0.00 1C 16335.00 2 205.00 3 96.00 4 0.00 5 0.00 6 0.00 7 0.00 8 0.00 9 16636.00 10 0.00 11 16636.00 12 466.00 ----------------------AS-E -F-O-LDHIS -- PA---GE--A --- LONG--T ----LIN--E ------------------- PLE Local Information. Enter where you lived as of 12131100. Extension, (Mark this space.) School District: CARLISLE Amended Return, (Mark this space.) School Code: 21110 FteealYevFibr, (Mark this space.) County. CUMB• Munidpaltty. CARLISLE BORO. Type Flier. (Fill-in only one eholee.) S Single Residency Status. (Mark the Comet Space) J Mewled, Filing Jointly R X Resident M X Married, Filing Separately NR Nonresident F Final P Pan You Resident D Deceased From: To: Date of Death 1a Gross Compensation, from PA Schedule W-2S, or your Forms W-2 or other statements . . . . . . . . . . . . 1a 16335.00 1b Unralmbursed Employee Business Expenses, from PA Schedule UE . . . . . . . . . . . . . . . . . . . . 1b 1e Net Compensation. Subbed Une l to from Une l a . . . . . . . . . . . . . . . . . . . . . . . . . . . tc 16335.00 2 Interest Income. Complete and enclose PA Schedule A If over $2,500 . . . . . . . . . . . . . . . . . . . 2 2 05 ..00 3 Dividend Income. Compete and enclose PA Schedule B B over $2,500 ... ... . . .. ...... . . . 3 96.00 4 Net Income or Loan from Operation of Buslnees, Profession, or Farts . . . . . . . . . . . . . . . . . . . . 4 5 Net Gain or Lose from the Sale, Exchange, or Disposition of Property . . . . . . . . . . . . . . . . . . . . 5 6 Net Income or Lou from Rents, Royalties, Patents, or Copyrights . . . . . . . . . . . . . . . . . . . . . 6 7 Estate or Trust Income. Complete and enclose PA Schedule J . . . . . . . . . . . . . . . . . . . . . . . 7 6 Gambling and Lottery Winnings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 : 9 Total PA Taxable Income. Add only the positive Income amounts from Unes 1 c, 2, 3, 4, 5, 6, i, and 8. y DO NOT ADD any losses reported on lines 4, 5, or 8 . . . . . . . . . . . . . . . . . . . . . . . . . . .9 16636.00 10 CONTRIBUTIONS TO YOUR MEDICAL SAVINGS ACCOUNT. Sae the Instructions. . . . . . . . . . . . t0 11 ADJUSTED PA TAXABLE INCOME. Subtract Una 10 from Une 9 . . . . . . . . . . . . . . . . . . . . 11 16636.00 12 PA TAX LIABILITY. MULTIPLY LINE 11 BY 2.8% (0.028). ALSO ENTER ON LINE 13, SIDE 2. . . . . . . . . . 12 466 00 . y ,. . EC FC < ' 0000114173 ?? ?????? ?? 0000114173 ;, 0000214171 J 2000 PA PAGE 2 OF 2 GUTSHALL SANDRA 11 167-40-0748 13 466.00 14 457.00 15 0.00 16 0.00 17 0.00 18 0.00 19 0.00 20A 00 208 00 21 0.00 22 0.00 23 0.00 24 0.00 25 0.00 26 0.00 27 0.00 28 457.00 29 9.00 30 0.00 31 0.00 32 0.00 33 0.00 34 0.00 35 0.00 36 0.00 37 0.00 13 Total PA Tax Liability. ' Enter your tax liab0lly from Una 12 on Side 1 . . . . . . . . . . . . .. . . . . . . . . . . . . 13 466-00 14 Total PA Tax Withhold, from W-2, PA Schedule W-2S, or your Forms W-2, or other statements.. . . . . 14 457.00 16 Credit from your 1999 PA Income Tax Return . . . . . . . . . . . ... 15 16 2000 Edmated Installment Payments . . . . . . . . . . . . . . . . . 16 17 2DOD Extension Payment . . . . . . . . . . . . . . . . . . . . .. 17 18 Nonresident Tax Withheld on your PA Schedule(s) NRK-1. . . . . . . . . .18 19 Total Estimated Payments and Credits. Add Unes 15, 16; 17, end 1B . .. . . . . . . . . . . . 19 Tar forgiveness Credit. Complete lines 20a, 20b, 21, and 22 Read Instructions. 20a Filing Status: Unmarred or Separated Marled Deceased . . . . . . . . . 20e 20b Dependants, Pert B, Una 2, PA Schedule SP . . . . . . . . . . . . . . . . . . . . . . . . . .20b 21 Taal Eligibility Income, Pert C, Una 11, PA Schedule SP . . . . . . . .. . . . . . . . . . . . . 21 22 Tax Forgiveness Credit from Part D, Una 16, PA Schedule SP . . . . . . . . . . . . . . . . . . . 22 23 Total Credit for Taxes Paid to Other States or Countries. Enclose your PA Schedule G or RK-1 . . . . . 23 , 24 PA Employment Incentive Payments Credit. Enclose your PA Schedule W, RKA, or NRK-1 . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . 24 25 PA Jobs Creation Tax Credit, from enclosed certificate or PA Schedule RK-1 or NRK-1. . . . . . . . . 25 26 PA Waste Tre Recycling Irwestmenl Tax Credit, from enclosed certMeate or PA Schedule RK-1 or NRK-1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 27 PA Resaaroh and Development Tax Credit, from enclosed certificate or PA Schedule RK-1 or NRK-1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 28 TOTAL PAYMENTS and CREDITS, Add Unes 14, 19 and 22 through 27 . . . . . . . . . . . . . 28 4 S7 . 0 0 29 TAX DUE. If Una 131s more than Line 28, enter the difference here. . . . . . . 29 9.00 30 OVERPAYMENT. If Una 28 is more than Una 13, enter the difference here . . . . . . . . . . . . 30 31 REFUND -Amount of Una 30 you want ass check mailed back to you. .. . . . . . . . Refund 31 32 CREDIT - Amount of Una 30 you want as a credit to your 2001 estimated tau account . . . . . . . . . . 32 33 DONATION - Amount of Una 30 you want to donate to the WILD RESOURCE CONSERVATION FUND. .33 34 DONATION -Amount of Una 30 you want to donate to the UNITED STATES OLYMPIC COMMITTEE, PA DIVISION . . . 34 35 DONATION -Amount of Una 30 you went to donate to the ORGAN DONOR AWARENESS TRUST FUND 35 36 DONATION -Amount of Una 30 you went to donate to the KOREAMETNAM MEMORIAL, INC. . . . . 36 37 DONATION -Amount of Una 30 you want to donate to the BREAST AND CERVICAL CANCER RESEARCH .37 The total of lines 31 throuch 37 must saual line 30 Your swwwre D.n Your Oeeuo.e.n CLERK Smww. sgmW .smite lolmw Dow soon.:. oonsaw 'M1 r.r or CO Norm Oln.r 111.11 tum"Kal Prewsm, or Comm" Nam (R. Pm,) GROUP'S TAX & PAYROLL SERVICE Wb 04110/01 Timor, NYMoir? 717-245.8581 agmun m m. rny.r.r t?w..?.o 1 0000214171 0000214171 , SANDRA M GUTSHALL 16740-0748 RETURN BY APNIL16,2001FOLLOWING THE TAX YEAR TO: CAPITAL TAX COLLECTION BUREAU SEE BACK OF RETURN FOR PHONE NUMBER AND OFFICE HOURS LOCAL EARNED INCOME TAX RETURN (FORM 531) 2000 owxamunreoaarreFa.Na+AeFAYafWFYWaTnvAaAllannR BMW. Te ruva rgncerrvALRAnoer arananew amRnq euuureAw TWAYenfWPIall AnVAPOnSMSTAV11PPNNyN SOC. SEC. N0. SOC. SEC. NO. A HUSBAND AND WIFE MAY BOTH FILE ON THIS FORM. HOWEVER. TAX CALCULATIONS MUST BE REPORTED IN SEPARATE COLUMNS. JOINT FILING (I.e., COMBINING INCOME. ETC.) IS NOT PERMITTED. 167-40-0746 1 W4 EARNINGS (Fiam attached W7a) 1 16 335.00 2 EMPLOYEE BUSINESS EXPENSES (Attached Fadanl Fom12108 8 Stale Schedule US) 2 3 TAXABLE W2 EARNINGS (Subtract UN 2 fleet Una 1) 3 16 335.00 4 OTHER TAXABLE EARNED INCOME (NO INTEREST OR DIVIDENDS) Complete Section B on Beek 4 S TOTAL TAXABLE EARNED INCOME (Add Ums 3 and 4) a 16 336.00 PROFESSION OR FARM (Attach Fedenal and/or State Schedules r F Andlor K-1 MCI! 8 NEI LC39S FROM BUSINESS 8 , ENTER ZERO 7 SUBTOTAL (Subtract Um a Item Line S) IF LESS THAN ZERO 7 16 335.00 . B NET PROFIT FROM BUSItIESR PROFESSION OR FARM (Attach Fedeml and/or State Schadulatr-F-11flIllr K.1(10 B B TOTAL TAXABLE EARNED INCOME AND NET PROFITS Add Unee 7 and B a 16 335.00 10 TAX LIABILITY: 1%OFLINE B u18 Um9b .01 10 163.35 TOTAL LOCAL INCOME TAXES WITHHELD EXCEPT PHILADELPHIA INCOME TAX(Fmmattached W7e.SoX21) 11 163.41 11 12 QUARTERLY PAYMENTS AND/OR LAST YEARS OVERPAYMENT CREDITED TO THIS YEAR 12 13 CREDITS FOR TAXES PAID TO PHILADELPHIA AND/OR STATES OTHER THAN PA (ATTACH LOCAL SCH. G) ED RESIDENTS OF THE HARRISBURG KEYSTONE OPPORTUNTY ZONE (KOZ) F 13 AND/OR CREDITS FOR CERTI I 14 TOTAL WTHHOLDINGS S PAYMENT'S Add Linn 11, 12 and 13 14 163.41 PAYMENT NOT NECESSARY IF LESS THAN $1.00 14 h U 10 NC U 16 ots m ) 18 TAX BALA E DUE (Subtract m i 18 1 1 ons) to INTEREST B PENALTY (Sea lnsouct 17 TOTAL BALANCE DUE Add Ume 15 and 15) Make Clerk payable to'CTCB• 17 , ENTER ZERO IF LESS THAN ZERO U 4 18 0.06 , m 1 ) 18 OVERPAYMENT (Subtract Une 10 from 1B 18 OVERPAYMENTTO BE REFUNDED NEXT YEARS TAX T 20 20 OVERPAYMENTTO BE CREDITED O eY nvocoavMFMTTn RP rRPnITPn TO RPOURE'S BALANCE DUE FOR THIS FILING YEAR 21 TYPE OR PRINT INFORMATION BELOW. IF PRE-PRINTED. CHECK FOR ACCURACY AND MAKE CORRECTIONS "ERE NECESSARY. SPOUSES NAME, 3IGNATURE, D OTHER INFORMATION SHOULD BE PROVIDED ONLY IF HE OR SXE IS ALSO FILING ON THIS FORM. YOUR RESIDENT MUNICIPALITY TAX OFFICE (TOWNSHIP, BOROUGH, OR CITY) DAYTIME PHONE NUMBER USE ONLY YOUR SOCIAL SECURITY NUMBER (YOUR NAME GUI SMALL QPJNLJ V4 SPOUSES SOCIAL SECURITY NUMBER SPOUSES NAME FlRST MI HAVE YOU MOVED FROM THE COMPLETE HOME 26 STEWART DR. YES IF YES BEGINNING OF THE TAX FILING , ^ f-?m? SECTIONS A 6 C ON ADDRESS CARLISLE, PA 17013 / YEAR TO PRESENT? v REVERSE OF THIS FORM. r UNDER PENALTIES OF PERJURY. I HEDULES AND STATEMENTS DECLARE THAT I HAVE EXAMINED THIS RETURN AND ACCOMPANYING SC, AND TO f= Exhibit "D" N S O ? O:^il: R sew N W <>>3s: In< Zm-i xm< ,Ujx m O ~ O?9' V.: 09 Q22QW >m.C» sO?p J = 2D -U ZlnM - N m; a a2?QCDQ In Y: CL L) co cm 0 Cj to ?' r o E o z C1 U 3C: is N Q Al T v 9):, N O M 9 ?''i'i! r M N a ,_ m?% w E a $ ° C? Grls. »)m e o o >: 0E 5-? LL 3 ya a3R o U N r ;z::•.in:: o CO io-` w a u ?L LL O. Y C W CD = R []: 26T CC O C O 7 a tai O '? T •; a } z m? 0 a` 8 Lan ?, c i0 A . a ` w LL M 0 cc O. 'O L)s a U R PZ<g J 7?a •? 3 C E ez¢w:5 ??r7 = O a C.G O O am°? t?ni TO. a O U N 2 •pm m U Ln ` U IM U 7 p tl1p=p 2OL L O a y 0 9D?z aaa Q F- . W aU v T U > mR < Q a rn I V I I I I I 0 N N ' W ? gnn ?_ C 3 w0 H -m m rc W c r a Tn LC N c m m m U g m m ypN1? U?. m °m N F E? H y o o? i ?ayyy{? t'C Na m G o ? L7 E 0 g m O T a Q c 0 v a a m H d O 0tl? M NN NO m0 0 F {? m Ob q 1O. S. NM m Cb N O m N C N .P zU Y J 3a ? m NN z ^m8 mrn cc 0s mg 00 jLL S.t Q q C M A p 5 00 Y? gE? W63 mm Np EE CHIm by' c as='m 03.5 5 A9 erC d?, N ? Q C d s IfLN'N 21002000 LO/IO/l? a C1 W ?p p W b O 'z Y O; az U y 2 0 op ZZ Q to Q¢J ? Z > w= O m moso? Q J ) f- jr CL ? cc w w413-j r_D ZWQ 21?fap NU N CD E ?F+ N CD L ? so L. r Cr . C m O . . 3m O R ? w m ? E N m ? ®= e ? O c ¢,.c = p C mo ? E .5, L LLw -a as ? -• a O 3 rn L In iT .09 gal ? _ ? C l0 m a C A O ao ee°ac= s (/> = > p C 9 o O a . L e ;2w V 05 C Ca iO Nr?l''L7 l0¢( O Q p s w F . G, r N N Ob m LO C C 7 0 O N O ?Ik U. m U. t C W c m Q V a L E 7 N C 7 O V Q m c R w N M a N m N N 8 C; 4 U N 7 °a ?QQp ca?? 9xcq? " FSo 3'mx y Wwg wmg, >a limo N C 3 0 0 H a f7 O y ?EE i i RS P? a• s? ?A oog ?y y o o e EP R e. 2.8 0L aE v V Q 0 s O c g ? O S y92 q1q!H A aa'li pia oWom weov N o °b o 0 MYMM No mum My?? ^a o P cc 6 O ? c a!i pp ' ,2 n ra a ' ., e e e N rm N? 1 0.2 G .E s F8F 0 • c? V LL4 V 6 Ci 9 0 e p t JIM r • • e s ,11 ps A ? A N W O ? ? O r a epme N a:.w ?o ?p 0 pE N eo?? n? z s ? s U E d o 7 ?mii Qp@i? e Pd l y R . ap . _ P B C F 0 p r ? y 6 g d o M •nw w dim Exhibit "E" LIMA" IC-000C IUC IC-4i rll VIVh111011 VVLLGUC 1110YLL III C40 IIUC •ww Closing Data: October 9,1999 Page I of 2 Cashbook SonusWAward Hapa)rua rocab ^asbb quallllsdpurchun $0.00 $0,00 BOnu?e OaahbackBonae award earned $0.00 $0.00 x•77 CaehbaekBonuo anniversary date: July9 rzcua?a? Discover Card ACCOUn Summary aoboumnumber 6011 0022 6060 2024 previous balance $965.01 paymentduudaN Novomber0, 1099 paymenbandomdlk - 24.00 minlmurrtpsymontdw 424.00 credit omit 12,000.00 Purchases + 0.00 oledll avallable $0,00 Cash advances + 0.00 cash WWII limit 11,000.00 balance transient + 0.00 csahcredit available $0.00 FINANOECHAHOE6 + 10.97 newbalanoe =. $545.04 You may be able to avoid Periodic Finance Ohatgra, an the reverse aide for details. ransec Ions _ Payments and Credits Oct 6 PAYMENT • THANK YOU $ •24.00 1'he Dally Periodic Rate and corresponding Annual Percentage Rate Ihal apply topurchases mayvary. Stsbackfor Additional Inleml4lion, W. Ourrawfols ahowyourourrntphona number as (717) 246.6602, If this is not coraotplesse update It In the address M change aria above. llf Ma Cashback Bonus(R) Countealvnl Every time you use your DlaroverR) Card, ycuil be entered far the chants IV ?iwin$1MILLION andaNowYear'slrlptoNowYork. No purchasensossaaary. Void whomprehibhed. U.S.residents l8 or older. Ferrules, call f-BBB-646.82S9. Endd4loovary tram f2110-I2n7r99depending on method of entry. Pies" mallyourpayment a minimum of 7.10 days before the due dae ahown on your statement to allow ume for mail delivery. Thleb espeWallylmponanldudng the Hollday Besean. You may.al00 make yourpaymalll electrenleally using SmarhhedkjSM) In the Account Center at www.discoverearl.cam. r. J4 X1111\ /L LVVL IVY IL'7V 111 V/VI\IIIVII VVYYLVL 11\II\YY I11 L7J IIVL 1, JJ l ? tiYa,?',Y1C"uE i03:96??'1 ' eRP riot USA: I.0Pn•955.49DD AC NVRID2R pS 4m. MALL9trn ou w P4R4 tMAMANLLLT 7ATlnN1'nUP CD,1TR 44171124 M 106621 {,Ono 02n n 0 IMSN99 00110110 CARDMRMOCRACrIVITY SUMMARY TRANP. ICOT. RAIRDNDDNIIMPNS NAMPmI PWRACTION DISCI MON AmmXT DATR DAT7 119112 00112 7441713201D111XHR.Y INT•771ANKYOU rP 91IMCn 09125 09/21 DIC RA7E 'FINANC'E CHARGE' 92.52 PRMDU30ALANOR •PURCa1ARR1 us aCAM ADVAMM 4PINANCK CHARGItR .PAYMR is AND NRW'DALAW.9 AND A05U5TM&7T6' 474115 O.00 0.00 00.51 L'RIDIIT 94,9 4,745,47 CARDMEMPERNEWS REMINDER: THE FOREIGN CURRENCY EXCHANGE FEE, DISCLOSED IN TILE FEBRUARY 1990 CHANGE IN TORMS NOTICE FOR TRANSACTIONS MADE OUTSIDE 71M UNITED STATUS, WILL GO INTO EFFECT IN NOVrMBER 1009. wd r,jmalal la: PIRST USA BANK NA, P.O. BOX 15153, WILMINGTON, DE 19266.5152 PERIODIC RATE MAY VARY rNANOP AVELADR ONLY RNANCR DAILY CORRWMI)MD PPNOW WAR01 RUMMMY MC19 CYCLP rI1DDIC RATS ANNUAL PAW4TAOR MTP FINANCR CHARGE PORawn CWit 1,761.09 3,970.77 aLM 0.00 .06292X41 d16393% 11.09"/0 11199116 36.61 6111 ANNUAL PIRCIINTAGE RATP 34.9122 Tou.m com PINANCECIIAKUIC 96.51 PeNama INWAn tat /M UPA Rank. NA, P.O. PA- 1150 WUmlanam DD 101MON First USA Bank) N.A. t CWA A4NP OW Urba Taman afrm eel Wdil Um. MamknrDIC See reeenr dde fat Impnrlnnt 1Dforlni lnn InC1UdInR nntlCr R4mal RnmlRl renml, WIN SLOnD,000 INSTANT'LYI VISIT V VW,17RSTUSA.COM TTy PNTFR TIP; FIRST USA INSTANT WIN GAME AND SWEEPSTAKES. WIN A TRP'. A . COMPTim, CASH AND MOIU; ALL WITH TITP CLICK Of YOUR MOU,9E1 SEE 1VW W.FPISTUSA.COM FOR MORE DFTAU AND TO ENTFRTODAYI TC1 RECEIVE OUR EXCLUSIVr CAXDM[HMOLR1 OPEP.RS AND DISCOUNTS, REGISTER YOUR EMAIL ADDRESS AT W1VW.SPECUILVAI,UE4.COM TODAYI 1430 PIID I Ir C 7 Page I nr 1 3155 9007 X114 109 050971 01AA5530 $4141 Thank you for continuing to use your First USA Credit Card. We value the relationship we have built with you and your continued business is important to us, Please let us know if there is anything we can do to service your account. SEND INQUIRIES TO: CORNERSTONE r...0.. 'Federal Credit Union 1 .r.1.=... rAj A(emberfoundrd-&"&ebnred. P.O. BOX 1711 CARLISLE. PA 17013 717.246.1"1 IIIIIII IIIIIIaIIt IIIII III III IIJIIIs IIIIIIIII IIIJIIIIIIIIIIII RUSSELL R GUTSHALL III SANDRA M GUTSHALL 38 P. 0. BOX 885 CARLISLE PA 17013-0885 II1 RMRQ U N IMPORTANT INFORMATION NOAR(XNp yOUR RKm TO Owwm RLLm IRRORt 2111 RMABIVIoncFlEt IMPORTANT INFORMATION IN CAN OP URORO OR OU99TKM ABOUT YOUR ILICTRONIO TRAUVER11 IDINOND WITH LITTER/ 7Y PNu1ORLANCI TOURNOCO AlNVONAREOOBNCRAE. A PTPORMACCO U PNTOR IS PRINTED ON THE REVERa6 SSN: 193-36.3669 143 08/01/1999.- 08/3111999 OWNERDNN+Of IINAR1. DIPODIT AND CE"F=TE ACCOUNT/ SHOWN ON TI I4rATEMENT 19 AMOUNT SHARE 01..REGULAR SHARE ACCOUNT 08-01 PREVIOUS BALANCE 08-02e ATM WITHDRAWAL -100.00 EFT 5 EAST GATE DRIVE CARLISLIE PA' 08-06 TRANSFER IN , 300.00 08-09e ATM WITHDRAWAL -100.00 EFT 5 EAST GATE DRIVE CARLISLIE PA 08-16e ATM WITHDRAWAL -100.00-EFT 5 FAST GATE DRIVE CARLISLIE PA . - OB-16e ATM WITHDRAWAL -100.00 EFT 5 EAST GATE DRIVE CARLISLIE PA :- --- 08.20 TRANSFER IN 300.00 - 08-19e ATM WITHDRAWAL, -60.00 EFT - 5 EAST GATE DRIVE CARLISLIE PA - - 08-23e ATM WITHDRAWAL -100.00 EFT 5 EAST'GATE DRIVE CARLISLIE PA 08-23e ATM WITHDRAWAL -100.00 EFT 5 EAST GATE DRIVE CARLISLIE.,,,. 'PA,. 08-30e ATM WITHDRAWAL. 100 00 lFT ' 5 EAST GATE DRIVE CARLISLIE, PA 08-31 NEW BALANCE .- _..__ > YEAR-TO-DATE DIViDENDS_THIS A y3A « - SHARE OB..CHRISTMAS CLUB ACCOUNT 08-01 PREVIOUS BALANCE 08-06 TRANSFER IN 75100" 08-20 TRANSFER IN :75 00 . =.` 08-31 NEW BALANCE n >> YEAR-TO-DATE DIVIDENDS .THIS ACCOUNT y ,;..l, 18.23 << - - - SHARE 09..VACATION CLUB A000UNT ; - - - • - 08-01 . PRFVIOUS BALANCE . . „ ' 08-02 WITHDRAWAL ' " 1580.97"' CUNA MORTGAGE PAYMENT - 08-06 TRANSFER IN 777.50 `- 08-20 TRANSFER IN 777.50. 08-31 NEW BALANCE >> YEAR-TO-DATE DIVIDENDS THIS ACCOUNT 51.15 « • . . . . . . . . . . . . . . . . . . SHARE 07..SHARE DRAFT ACCOUNT . . . . . . . . . . . . . . . . "•• CONTINUED NEXT PAGE '•* N077CE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION BALANCE 227.57 127.57 427.57 327.57 227.57 127.57 427.57 367.57- '267.57 -167.57 67.57 67.57 1688.23 1743.23 1818.23 °1818.23- 3422.04 1841.07 2618.57 3396.07 3396.07 CRNNI ain?GnlClr? Vr NL.L.UUIVI SEND MIOU/R/ES TO: CORNERSTONE . Federal Credit Union Memberfoun"- Snake based. P.o. DOX 1181 CARLISLE. PA 17013 717,749.1x1 RUSSELL R GUTSHALL III PAGE 2 SANDRA M GUTSHALL P. 0. BOX 885 CARLISLE PA 17013-1350 143 08/01/1999 08/31/1999 OWNERSHIP OF SHARE. DEPOSR AND CERTWMTE ACCOUNTS SHOWN ON THIS STATEMENT IS NOTTRANSPENBABLE EXCEPT ON THE BOOKS OF THE CREW UNION, TRANSACTION DATE TRANSACTION DESMP71ON TRANSACTION AMOUNT PRINOMI PA7MF9Tr "? 10AM1 FINANCE CHARGE BALANCE 08-01 PREVIOUS BALANCE 1028.39 08-02e POS DEBIT -47.00 EFT 981.39 THE OLD FISHING STCARLISLE PA 08-03e POS DEBIT -23.92 EFT 957.47 THE HOME DEPOT 412MECHANICSBURGPA 08-03e POS DEBIT -25.09 EFT 932.38 THE HOME DEPOT 412MECHANICSSURGPA 08-06 DEPOSIT 1946.74 EFT 2879.12 SPRINT/UNITED REG SALARY 08-06 TRMSFER.OUT -1315.39 1563.73 08-06 POS'DEBIT -12.75 EFT 1550.98 SHEETZ INC 195. CRIMECHANICSBUR PA 08-06 DRAFT N 1223 0011383850 -17.05 1533.93 08-10 DEPOSIT 418.71 1952.64 08-10 DRAFT b 1230 0011470470 ' -51.94 1900.70 08-10 DRAFT k 1222 0011243710 -54.51 1846.19 08-10e POS DEBIT -12.30 EFT 1833.89 SHEETZ INC 70 CRINSHIPPENSBURG PA 08-11e DRAFT k 1226 0031331470 -24.63 1809.26 08-11e DRAFT k 1228 0017239180 -28.65 1780.61 08-11e DRAFT N 1231 0017217720 -64.48 1716.13 08-11e DRAFT N 1225 0021189610 -194.00 1522.13 08-11e DRAFT N 1229 -0011013100 -223.67 _ 1298.46 08-11e POS DEBIT -34.84 EFT 1263.62 WAL MART MECHANICSBURGPA 08-12 DRAFT N 1227 0017088070 -16.91 1246.71 08-12e WITHDRAWAL --192.00. •1054.71 FIRST USA PHONE PAY 08-13 DRAFT # 1224 0028130120 '. -6.00:. ; .. .•.1048.71 08-13 DRAFT k 1232 0028136470 -418:84` ° 629.87 08-16e POS DEBIT -11.48 EFT 618.39 SHEETZ INC 195 CRIMECHANICSBUR PA 08-20 DEPOSIT 1843:17 EFT 2461.56 SPRINT/UNITED REG SALARY 08-20 TRANSFER OUT 1315.39 1146.17 08-24 DRAFT k 1233 0009091490 -47.67 1098.50 08-25 DRAFT k 1234 0009005420 -148.36 950.14 08-26e POS DEBIT -14.00 EFT 936.14 SHEETZ INC 263 CRICARLISLE PA + 08-27e POS DEBIT -21.91 EFT 914.23 *** CONTINUED NEXT PAGE *** i ... unrn . ..uuuu.v . BFND INOtNR1FS i0 1. ., : CORNERSTONE, 'Federal Credit Union Memberfounded- SnWte band. PA.BCX11B1 CARLISLE. PA 17017 717.24&199 RUSSELL R GUTSHALL III SANDRA M GUTSHALL P.O. BOX 885 CARLISLE PA 17013-1350 PAGE 3 . Y ay, L'N', k 4 dBJ??311?1??? njj..?^^^^^04i. QyQy??, 143 08/01/1999 - 08/31/1999 SHOWN ON THIS STATEMENT 3 BOOKS OF THE CREDO' UNION. BALANCE GIANT FOOD #112 CARLISLE PA 08.31 DRAFT # 1235 0017064430 -150.00 764.23 08-31 DRAFT 0 1236 0017063650 -187.24 576.99 08.31 NEW BALANCE 576.99 >> YEAR-TO-DATE DIVIDENDS THIS ACCOUNT 16.76 << DRAFT# AMOUNT DRAFT# AMOUNT DRAFT# AMOUNT DRAFT# AMOUNT 1222 54.51 1226 24.63 1230 51.94 1234 148.36 1223 17.05 1227 16.91 1231 64.48 1235 150.00 1224 6.00 1228 28.65 1232 418.84 1236 187.24 1225 194.00 1229 223.67 1233 47.67 . . . . - . - - - - - - - - - - - - - - - - - - - - - - - - - - - - - LOAN 05*..LOAN ACCOUNT TYPE: LINE-OF-CREDIT **** ANNUAL PERCENTAGE RATE **** 12.004 PERIODIC RATE OF .032876796 THIS LOAN IS A VARIABLE RATE LOAN. THE PERIODIC RATE MAY VARY. 08-01 PREVIOUS BALANCE 3479.78 08-06 TRANSFER IN 60.89 44.87 16.02 3434.91 08-20 TRANSFER IN 60.89 45.08 15.81 338L.63 08-31 NEW BALANCE 389.83 >> YEAR-TO-DATE FINANCE CHARGES THIS LOAN 254.29 << - TOTAL DIVIDENDS EARNED THIS YEAR $ 99.74 TOTAL FINANCE CHARGES PAID THIS YEAR $ 254.29 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - CORNERSTONE'S 25TH ANNIVERSARY CELEBRATION IS UNDERWAY - ENDS SEPT. 24TH JOIN THE CELEBRATION BY: *REFERRING A FAMILY MEMBER OR CO-WORKER *SIGNING UP FOR NO FEE CHECKING OR A NO FEE VISA CREDIT CARD (ASK ABOUT SPECIAL BENEFITS FOR COLLEGE BOUND STUDENTS) *TAKING ADVANTAGE OF LOAN REFINANCING @ LOWEST RATES EVER FOR MOST CFCU LOANS MANY MORE WAYS TO WIN WITH GREAT PRIZES, GREAT SERVICE, AND GREAT VALUEI CALL 1-888-7186786 OR 249-1661(LOCAL) OR BETTER YET, STOP BY FOR DETAILS IIII *** CREDIT UNIONS*** 'WHERE PEOPLE ARE WORTH MORE THAN MONEY' Exhibit "F" Prudential V Financial SANDRA M GUTSHALL 26 STEWART DR CARLISLE PA 17013 Dear: Ms.Outshall Contract Values Quotation Policyowner: Sandra Gutshall Insured: Sandra Gutshall Policy Number: 73431910 c; T,,. The Prudential Insurance Company of Amodca spodol services Unit `12001 County Road 10 Plymouth. MN 56442 www.pmdenUal.com February 25, 2002 We recently received a request for a quotation of values for the above referenced policy to be sent to you. The following values are approximate as of September 25,1999 Gross Cash Value $2,225.28 A haft ualue'';i $ .'i212.99 .;.,.... Tertii'IftitH&iDivi'dend ..'r: ;,.' ' $ 3a0:00 Imo, ..,t6ca>aa ::;•:?:oan ,;; $ .....a.oo To 2t1' s91t Vahe" 2,738 27 If you have questions, or if you require additional information, please contact our Customer Service Office at 1-800-778-2255. Any one of our representatives will be happy to assist you. Thank you for doing business with Prudential. Sincerely, Stacy Bauernschmin Service Administrator CaeeW Deer: 751 Bind dank. IawrA, N 07102,1777 JAN-21-02 10:37 AM PRUDENTIAL YOCKIN P Ipl. January 21, 2002 Permanent I.Ife Insurance PrudentW Q& Financial Beneflts Policy Owners Name Contact Now Policy Number Policy Data Face Amount Outowdina Loan as of 6252001 Est. Cuh Value as of 6125/2001 Annual premium as of 625/2001 Beneficiary Issuing Company Total Annual Premium: Total Cash Value: Mutual Funds Assets Owner Account Number Fund Name Share u of 9242000 Current Value as of 9242000 Total Value Mutual Funds: Total Investment Value: 717 697 1451 P.02 Poe 141`2 Prepared By Bob Yockin (717)897.2200 (717) 255.3143 Date Prepared Jarusary 2t, 2002 Year rare 4f,lwada h Sandra M Gutswl wahmahk c"Wralaep Wp SandraMOuadall 6-li slwatapt 73431910 ?JAOY"t WA vow 6125/1985 artdran4fhause*,, For $12.000.00 amw nt OMMOa caw row Ptud gW aspemwathe 52,622.62 208.68 Robert C Anderson if The Prudential Insurance Co. of America 208.68 2,622.62 Flatonelelaawhtoand MWXbWtwted5AWWWAy Sandra M Outshdl change. 8tawea nwkw 03800682526 yawetrctWJrarthuto 'tsar wahyn Pr"A" tlel 317 995 . Parted rquansd $4.355.89 aeDnxatmtrt. $4,355.89 $4,355.89 Exhibit °°G" Ltl/1r1177`? 1:: 4! ra r19U47tl5 I li. pFf tllMb PAL+, tlb TLT 097 lop" ?•P? CC7?27-4t fe 101 AM ?11UDENTf HL VOCrfN , QUOTATION OF VALUES PRUDENTUAL INSURED RUSSELL R GUJTSHALL 3RD OCT W, low POLICY M 801 801 OPFIOE W SH PREMIUM 1 t a.3D MOD! M AGE AT ISSUE Et POLICY STATUS "am PAYING ?7 9 tY J OROSI CASH VALUE 1 PLWFUA CASH VALUE 1 PLUS-AOOUM DIV / PLUFLRiM8110 TERM DW S PLUS•TERMINATION DIV S LESS-OUTSTANDING DEBT S CASH VALUE PAYABLE I CURRENT PRGMIUM RETURN S ADVANCE PREMIUM RETURN S Sano!LcLory: Sandra Gutshall * ISCATSN?SURRE&A VALUE.LE, WHEN OUOTE Spouse 1s the autoratic ADDRESS OF OWNERIINSURED named beneficiary under as STEWART DRIVE ZVWj,jj3Xinh Do11cy. CAR, IS E PA 1"13 ant ASSIGNMENT DATA CLASS NOW POUCY RIGHTS RESTRICTIONS NONE POLICY IOND PM6 LOW ONIDEND OPTION ass F M301 RA16 RATING NONE PUA 84601306 W SH C p CAL ? OALC AD 001 DATE NOV I7, IM NOV 117, ION sn1.33 OAsm ON TERM OP DATE AUG S, 2030 1125. 12 EXPIRY DATE OF W INS AID S, 2030 O,SO AMOUNT OF INS EXTENDED II: 8802,61 DIED P.E. PAYABLE ON ROPY DATE S 0.00 184,57 PAID-UP INS VAL.UE•RPU S SIORDD 0 00 AMOUNT OF LOAN VALUE S 3OL34 , 4107.72 LOAN INTEREST TO DATE 6 ODO l 0.00 AMOUNT OF LOAN AVAILABLE" S Nua (;NCI. LN VAL OF DN08) 0,00 NET LN AVAIL EXOL IXVDS S ESW16 8910M 3o AMT OF 10 5 5000,00 LOAN INTEREST RATE L% +rV Y CHANW1 pW?HEN DATE M AS OF DATE. A DASH LOAN OAMT BE CRANI7D AFTER PREMIUM GRACIE PERIOD. 600 USER 10 :008014- `SECOND CO" !ldiGE'n tssir c7Lt:.ic 01 WPM sSL L'8 14SWI lm)QW ad 6210T G"'LZ 17C LWIIIICCC :. .,I IAIA4V.10C rL .MrrM1RD ra V? 00T-3T-Le Sates NM PRUDeNTInL POCK" TIT eeT 3401 P•61 Piet Conftct Yak= QuotaM/on tobuwro dwvmowswmr ,aesewrew w n snor RI?aMT YOOKIN w am e9d P = W MEADOW DRIVE RUESsE77l¢¢U. C?1R *VTSMyAAELL ]RD MEONAN0MBURG PA 17066 t11LSS Yh'?61 OSa-171.4 (71n7)11?eYt7•?W6t0 ON RUEOELLNR a1UT6H?AL0L M OObber 27.16ee You rm mn* requeow IMom it on on ail ft wows co your permanent woranca contract. N of Gotobef 26,16W thaws values Were: E1,f6aJI0 Cash value $11PAS Can valor d p "-w addibmf haurawo Ohl amount Of WWI-* eddldsnal Imwrenee prateodon is 6al7.ea) ODA Temtnaaaa dtvodend 11,507.66 Tdal deeh payable an su weneMr The arl0Yru1 Of the 1srminallon dMdwd dwO abe" depends on when he policy 4 surreadeeed. K you surrender your dontre06 you dlolld retaee that • you oral lows the 82,e42.01) M40O d odd•tp Yuorance amount • W 14 III&MAO adanded term pmandon available through April 97, 3017 win be loll. • you wld loss the annul d insurance pwAam you now have. • any net paln on surrender may, be salyeot b led" Inoonw UK An sl4matNe tD surrender Is to We a carat ban of up to 61,40a.n. This WM COnth4e your InWIMOO pre40M lees the amount d tho WW loan and boriM. The option b repay the PMiiWeynce of inwbll?lly. Intor= aet an this lea f rt crontract values w he ,00% anofhsdnp b far reapply mad stow e rarr"Aw of this denbad year. t m*V loan funds really wa sble for urdweew of rallons 4 One of the Imponant prowla4 Or Yeurpenhenent Ise swu?enoe oontnoL In ardor to rsetm flat tons* of your COMNat for your barWolaMe or for your am lutue toe, you can repay some or all of your loan. Ar cOw aEematfve Is b teke the cash value of M or put at your pakt-W adel ww stsurenus. V you rb, Wen my be a lnaabie amwK I paneswel r TNt PAUO6NTIAL INW PANCC COMPAW OF AWKICCA POW RA12 WON no t1A6 RN OPSmATOM. Pr WAU11mlTOw PA 11034 alce'd TSP1/696TLT6 01 S= o&. SSE NMItl1T a )mw HA 6rtol 6161 4Z Y!0 la/1//1D:b 1L:41 ..%l4a4Db6 Ktl2.A"A1Kb OCT-$7-1/0 L0330 AM rmunUNTIAL VOCKIN TIT 69T 1407 0 Pn&ntW RUSSELL R GVMi144yA`[LL SRO RRL?ZILL PA13 T011-17f, R RtmtiLL R QVIhIALL 3110 cmbu 27. Tm r'AIr nn •.04 YOU r"" y roWMbd lnfornlavw On all fhs vduM d your pMnKMnt NMUana d?n?0. As a oomw as, lase dree valve a a 0: 19.11&33 CNh valve 11.119,12 00h vskm d palGup adalmal Yreurmt9 flue amount of pa" addtdOnaf Irouronoe PR*KM r N In AV9.aO) 6154. TarmhuLon d vmmd 111b,107.12 Tom cash psyabe an surtAnder Th9 amoued of tlw tarmlrb9on dMftnd show aoan dspende an Toren Ve 00110Y ID arrarldww. 1 you aarMKIGf your ***not. you should realms ghat, you WIN we 11ta 86,102.00 reduced Pald-up htumnos anMaOL - or the GOAR.06 amn9W term probolion waludb through AuOust It. 2WO wdl be MOL YOU Tel loo The amours of manna prow don you now roe. • cry net pun on arnnder may be aubla0l b bdwai laooms tox An al`meft to surrender Is 101ab a oonv= bee of up to $3,932.24. TNt wit OMMW your manna prowwon, loot the amant of Be bW ban and INefall The down b ropey M No la Rue hAn Clvw you dy appoft*to rN a a your b9 cw*oat vthlas WWAW htft b T"PPly trod $Nw avWrrloe albars"Illy. inteaa M urban RAM bes.ow%. Navbg ban hash madly eva2able for rnfareattn aluttbna to one of ms Importard orovlalane of your pWrhMdlt db bauronos amtraol in order to melon 91t oonem d your conpact tar your bnsdouuha or tar your awn norm un, you can ropy tan or ad of your ban AnWW alwnetNe b b bia tba cash vales of all or pan of your ps" Amgbnaf Mmanas. It you do, vmlm way be a taabte Onaunt (omwnued) THE FRUMNTInL AMralA =COMPANY OF AMERIW ciDlibwa volu" QUOta*0 fvm w wawaarH)w AwmeomwAw WI~ FAME"YCOKIN w 3w IMF WOW MEADOW OIavE MROWCJUURG PA 17066 mn dfl 4m f aMGl Mta W N1 000 M MM o011RAT10W, FT WASMOTON PA 190114 lawe'.u TwrLeU%TG M ass r9:. GTL WJGIvr-t 13w& tlal 90:0: rw6T a ltll//17y7 ":4/. I1 i14vi`JNd Wkfa. AFFA1kS MA& NA OC7-9T?7b LOfR• AM PRUORNTIAL. YOOKtN T'ST NT 2403 P.62 INSURED RUBES" R DUrSHALL $Rt7DUOTAT1oN OF VALUES OOCTT 97. to 1 POLIOY D10 /00 isS OPPIOE W am PRE" 1 I BJE, MODE M AGE AT 188UE 06 POLICY 1TATU8 PRISM PAYING POLICY 7 11 A OCT17 1 11 D10006I SO 061011 CASH VALUE I PLUSftA CASH VALUE / PLUSACCUM DIV t PLUS-UNEXPIRED TERM DIV { PLUS-TERMINATICN DIV { LEI&DVISTANDINO DEBT 1 OASH VALUE PAYABLE { CURRENT PREMIUM RETURN' { ADVANCE PREMIUM RETURM { PAIC•TO-DATE CALC PAIC6TO-GATE CALC AS OF DATE NOVIT. Ian NOV 1?, 190 OCTE8,1/11 Ib10.20 CASH ON TERM EXP DATE APR 11. AM' IVA7 EXPIRY DATE OF WT INS APR 27, 2017 0.00 .E PA D ON of 0't AE P C04FIY DATE LE S f 10. PAID-UP INS VALUE-RPU b 11Al.0c 00 0.58 AMOUNT OF LOAN VALUE 1 14" 1 LOAN INTEREST TO DATE b 0.01 0 0 AMOUNT OF LOAN AwLABLLm 1 141&6 , (NCL LNVAL OF DIVDB) 010c NET LN AWA1. EXGL DIVDS b 116LIV, <ADD TO 'IW VALUE;uMLE' WHEN QUOTE ADDRESS OF ~EPANSUMM ROME MATEWART DRIVE CARLNII.E PA 17071 OR OWNER INSURED ISIIONNI CIARY DATA AME SANDRA SUT'SHALL ??TIONBHIP CLASS POLICY RIGhTB RESTRICTIONS RATING • NONE PUA OLABS p LISA OR UNIFORM ACT ASSIGNMENT DAtA HONE NONE, POLICY MIN0 LOG RIDER WIND OLT DIVIDEND OPTION 066 F 66701 RA12 LO/d0'd AMT OF INS 1 0000.00 MAXIMUM LOAN INTEREST RATE 8.% CURRENT LOAN INTSPA67 RATE S.% "VALUES MAY OMANOE WHEN DATE Pvtom CALC AS OF CA18 TEE, A ? OA8NN LOAN CAN'T BE GRANTED AFTER PREMIUM GRACE PERIOD. D00906116 W54 000 USER ID 1006DSA7 'ASECOND COPY ISVI4496TL76 0_ 8'.::C TM 51G N7SIN71 13)%W Uzi rmW 6661 Exhibit "H" -t^ -=? -?- ' .. -42 7th c -0 a f L r + a+ 2 ?n pp JC0 T ? s C 9 ?. i M V '°o i 0 ,+ v 7 s CL. 7 of 6 0 o . w .? mm j;`- a?a Eei1 .r N.., 3iep Am• N NN=C] r? ? w ? J O p w a u u (? $ xx ?O O- o r w E° O 3 ? p L N ?0 ? E i 3 3 ?1. o € 0 3 i n € 0 m Exhibit "I" 0,01 / J- A: _ ,'7yw/??/ril?y?_.r!?_1i,7iJr.? ??.?' .?_ ? ?...liii?.i?J??<ff' ? ?? r I ? GEC GC.?ieC+ / ?v??/Gi?%???. ? ??'< ?o /?.,yL.?? .?[ droll I er v 10, 411 u.unuwn VV"LlNL IIMV6L I11 C40 I1UL r. uJ Jinn 1G C.UVG IVL 1GIJ0 III UlNn111011 1,VLL-= IrtnvLL 111 9t40 I(ut n I I i r. lu <a8sr<l /??6L?+t?".SIG/fti= _ .ly'C?-r? l=rZ'^!c<ry. /?/+t+`<t?l?'?a ??at. Care- .. _.......... ?lTa?i?lr, '?i ??%?Z. ?<'?l?•? G!? lylrY-f? /%co=ty ?G?r..._.... plowl, • ZGC??.a?Gv? ?r ? C ,,y?ry.?r__ ..ec.. J?G+ '?C-.,. r t:a. Exhibit "J" 1?..t ..1'x(1,•: ;,.:-'''i• :;? "I "I 'IV, 11 JL Make/Model Serial# Mossberg Chuckster Model 640 - SerW# 654623 22 mag w\eeope Winchester M94 32 Winchester Special w\scope Serial#2359493 Remington M700 w\scope Seri4l#328029 Westernfield 550 AAA 12 ga. Pump (3 in.) None Ithaca M37 Peatherlite -12 ga. - (2 3\4 in.) Serial#830826.2 Rickard 28 gauge double barrel None i Winchester M24 16 gauge double barrel Serial# 103523 Thompson Center Renegade 50 cal. Serial# 68100 Stevens Model 940E - 20 gauge single barrel None Exhibit "K" Y1U1NhLR Account Statement Investments" Decembsr31,2001 wrt rer,..re raw. wws , ,.n••--- SANDRA N OUTSHALL 26 STEWART DR CARLISLE, PA 17013-1764 eta Cell Us 1-800.225.6292 p Retirement Accounts Cell 1-800.622.0176 l( 0 Visit us on-line www.pioneerfunds.com Your Representative 1304 SISTLINE BARBARA BMS-5197.0004 AMERICAN GENERAL SECURITIES INC BR PA008 CARLISLE 501 SOUTH HANOVER ST CARLISLE, PA 17013 bT !Na; '. 7op(Mill ?11 - +5.: , ore W. . psptDtsaebS?JFm9l?rtm ?"YS°`S`saa?z4tD nl" Is Chock out the winter issue of Pioneer News, which accompanies this statement You'll find information about new savings oppotWnifien for retirement plans, including Pioneer's innovative Uni-K, rho first 401(k) plan designed specifically for self-employed Individuals. The newsletter also provides information about year-end tax-related mailings from Pioneer. For more information about retirement plans, call your financial ) advisor, or contact the Pioneer Retirement Plans Account Information line at 1-800.622-0176. For information about your account or Pioneer funds, call your advisor or Pioneer at 1-80D-225.6292. You can also visit our web site at www.pioneerfunds.com. We wish you a happy,' healthy and prosperous 2002! Aim CWaery Pond Nye Account Addttlans NRaldrowsu chsn/stavslue .-_-.?. Girmorth and Income -. ...... .r... u?-r-,r.o - .en•unu.r T rO.Pr•Y.O . row rate s PIONEER FUND-MASSA _ 001.6206017071 91,347.36 $0.00 S0.00 SI48 70 ? Current Dudrter Totals 100mbn 1.2007.Oecember3l 2001) S1,095.07 SO 00 S O.00 Srm 59 kill PIONEER FUND-CLASS A - Overview Account Information Account No. 1 Account Open Data 01/06/1999 Other Information Sears on Deposit 30,1106 AccoontFosums Telephone Exchange Telephone Redemption Distribution options, Dnidends/Shon Term Cepal Goias AlinnstAlmost Long-Term recruit Guns Rein Year-to-Date Transaction Activity Dollar Share Number Total Shares Tool Account -Date Transaction Descriobon Amount . Para or Share fl.,.e V.I... 01 T ae leeln aa S 44.26 .]Olat2 .:: , -<S1'9eT;116". INNVES VESTED 50.0 50,91 S 33.94 0 023 VIDEND REINVESTED $1.52 S 41.59 0 037 N 50.92 S 33.61 0 OD NG TERM CE 7 59.07 S 38.40 0.236 I REINVESTED 50.0512 ONDEND 51.58 S 38.65 0.041 001106 dle adores S 39.91 Owner Eamins Summa Paid Year•To•Dete O vidend 26STEWARTDR ShartTmnCapitalGoiru $0.00 CARLISLE, PA 17013.1764 Long Term Capital Gains $9.07 nrt ww.,•a,m n.w raw , ,. n...... P N rSTATEMENT SANDRA M GUTSHALL .26 STEWART DR CARLISLE, PA 17013-1764 Debmbsr'31,1999 Page 1 of 2 Total Value of Account: $1,345.79 No one looks forward to tax season. At Pioneer, we hope we can make filing your taxes a little bit easier. Watch your mailbox for Pioneer's handy guide, Plain & Simple, Your 1999 Tax Forms, which walks you through the tax-related mailings you'll receive from Pioneer. ACCOUNT SUMMARY REGULAR ACCOUNT Questions? Call 1-800-225-6292 Growth and Income Your Repruentabve: OOa450 BISTLINE BARBARA 0555.5107409 PIONEER FUND-CLASS A AMERICAN GENERAL SECURITIES INC Aa00YM Number: 08017071 BR709000ARUSLE ftH HANOVER ST 501 SOI Account SANDRA M M 6UTSHALL Account Opened: 110199 CARUSLE. PA 17013 As of 12/d1r99 Year to Date Most Recent Quarter Beginning Value $0.00 $1,209.06 Additions (.) $1.336.60 561.63 withdrawals (•) $0,00 SO.00 Change In Value $1,345.79 $136.73 Dividends Pail $4,86 S1.69 Short-Torn Capital Gains Paid 50.00 50.00 Long-Term Caphal Gains Paid $59.94 859,94 Distribution Options Account Features DIVdends/Short-Term Capital Gains Reinvest/Relnveat Telephone Exchange Long-Torn Capital Gains Relnwot Telephone Redemption Other Information ' Shares on Deposit 28273 TRANSACTION DETAIL Growth and Income PIONEER FUND-CLASS A Account Number: 001.6206017071 Registration: SANDRA M GUTSHALL Date Transaction 1/1/99 Beginning Value 1/6189 PURCHASE BY CHECK 3/31199 DIVIDEND REINVESTED $0.03 6/30199 DIVIDEND REINVESTED $0.04 8/30/99 DIVIDEND REINVESTED 80.04 11/30/99 LONGTERM CG REINVEST $22244 12129/99 DIVIDEND REINVESTED $0.0599 12/31/99 Ending Value Dollar Share Amount Price S 43.33 $1.272.00 S 47.32 S.81 5 44.16 $1.08 S 46.36 $1.08 $ 44.62 $59.94 $ 46.48 $1.69 $ 46.29 $ 47.80 Number of Total Shares Account Shares Owned Value 0.000 $0.00 26.881 26.881 81,1118.89 0.018 26.899 $1,178.45 0.023 26.922 111,248.10 0.024 26.946 1.202. 1.290 29.238 1 .41 0.037 28.273 111,306.78 26.273 91,318.76 r1Y??1??YN?Y YIN >•, O\y IIeM )tllA I ] •••?••• R IbUNT STATEMENT SANDRA M GDTSRALL 26 STEWART DR CARLISLE, PA 17013-1764 November 30, 1999 . Page 1 ot2 Total Value of Account: $1,299.31 To help your year-end tax planning, Pioneer funds are distributing capital going in November - e month earlier than in peat yeare. We hope you find this change helpful. ACCOUNTSUMMARY REGULAR ACCOUNT Questions? Call 1-800-225.6292 ?''?[O]M end Inc rna PIONEER FUND-CLASS A Account Number. 001.6206017071 Registration: SANDRA M OUTSHALL Account Opened: 118AD9 As of 11/30)9 Year to Date Beginning Value SO OO Additions (+) $1,334.91 Withdrawals (-) 60.00 Change In Value $1,296.31 DW@nds Paid 52.07 Short-Term Capital Gains Paid $0,00 Long-Term Cophal Gains Peal We. 94 Y-f Rpramtd": 000060BISTUNE BARBARA 86663197.0004 AMERICAN GENERAL SECURITIES INC 81170900 CARLISLE 501 SOUTH HANOVER ST CARLISLE, PA 17013 Most Recent Quarter $1,209,06 $59.94 $0.00 $87.25 So 00 50.00 $59.94 TRANSACTION DETAIL Growth and Income PIONEER FUND-CLASS A Account Number. 001.6206017071 Rog' on: SANDRA M GU7'SHALL Date Transaction 1/1/99 Beginning value 1/6/99 PURCHASE BY CHECK 3/31/99 DIVIDEND REINVESTED 50,03 6/30/99 DIVIDEND REINVESTED 50,04 9/30199 DIVIDEND REINVESTED $0.04 11/30199 LONGTERM CG REINVEST 522244 11/30/90 Ending Value 11111111 Dollar Share Amount Price $ 43.33 $1.272.00 $ 47,32 $•81 $ 44.16 $1.06 S 46.36 $1.08 $ 44.62 $59,94 S 46.48 $ 46,91 Number of Total Shares Account Shares Owned Value 0.000 50.00 26.881 26.881 61,198.89 0.018 28,889 $1,178.46 0.023 26.922 $1,248.10 0.024 26. Me $1,202.33 1.280 28.238 $1,312.41 28.236 $1,296.31 Exhibit "L" Automated 24-Hour Information 800 842.2252 Personal Assistance SIX) 842.3776 M-F, 8am-1 lent ET S-S, 9am-6pm ET Ito III II I I 11111111111111 if III 111 1111 11111 SANDRA M GUTSHALL 26 STEWART DR CARLISLE PA 17013-1764 portfolio summary this quarter this year Beginning value as of: (09130101) $1.408.55 (12131100) $625.24 Changes during the period: E .plover contributions 249.90 873.60 Your contributions 249.90 873.60 Net investment gain/loss 245.70 -218.39 Ending value: $2,154.05 $2,154.05 total value as of 12131/01: $2,154.05 All of us at TIAA-CREF send best wishes for a healthy and happy new year. Take advantage of the new tax law... new limits allow you to increase contributions to your IRA and SRA and save even more for retirement in 2002. To learn more about the advantages of the new law and how to maximize your contributions, take a nwmeut to review die enclosed /n Brie: visit us at www.tiaa-cref.org or call us at 800 842-2776. your investment results & returns gainsllosses gains/losses value as of this quarter this year 12/31/01 Equities CREF Growth $245.70 -$218.39 $2.154.05 $245.70 -$218.39 $2,154.05 ImSL 141109 total value as of 12/31/01 $2,154.05 For rates of total return or current interest rates for all TIAA-CREF accounts as of 12/31/01, refer to the enclosed performance card. 101111??111p III?I Ilpl? I /III 1111111 /III III /III II III 111 iasssos Web Center October 1, 2001 - December 31, 2001 730 Third Avenue, New York, NY 10017-3206 www.dau-cref.org Exhibit "M" AOF Spri>;t 89974 NA4K RUSSELL R GUTSHALL P. 0. BOX 885 CARLISLE, PA 17013-0885 SPRINT RETIREMENT SAVINGS PLAN' PARTIAL DISTRIBUTION STATEMENT SOC. SEC. NO. : 193.36-3669 EMPLOYMENT DATE :09/15/1967 DIVISION NO. : SC K6 TRANSACTION DATE : 09123/1999 TYPE : PARTIAL DISTRIBUTION - NO DIRECT TRANSFER FUND INFORMATION SHARES CASH PRICF WITHDRAWN WITHDRAWN ;PRINT FON TRASOP 534.4900 108.727 53.750.00 THESE ARE THE FUNDS AFFECTED BY YOUR WITHDRAWAL SOURCE INFORMATION BEGIM'0'99 AMOUNT WITHDRAWN BAT AN CF. fRASOP S72A57.27 53,750.00 568,70737 THESE ARE THE SOURCES AFFECTED BY YOUR WITHDRAWAL DISTRIBUTION SUMMARY TAX INFORMATION BEGINNING BALANCE S72AS7.27 TOTAL DISTRIBUTION $3,750.00 LESS WITHDRAWALS ( 53,750.00) ENDING BALANCE $68,707.27 TOTAL TAXABLE AMOUNT 53,750.00 ORDINARY INCOME AMOUNT 53,750.00 CHECK INFORMATION RUSSELL R GUTSHALL CHECK DATE 09/2311999 GROSS AMOUNT 53,750.00 P. O. BOX 985 CHECK NUMBER 205871965 FEDERAL TAX $750.00 CARLISLE, PA 17013-0885 NEI AMOUNT 53,000.00 THIS IS YOUR CHECK INFORMATION !yi v?,r1' 7V D?vr'/fT?X ???? Z? v5? Foe ?v?a:,?y ?xo?eScs, x= M COPY C lot EMPLOYEE'S RECORDS Se. rlooce on den.., Mau .•..-r .» ww.?...... w..,? •.... l.•? I 23020 : . .. r r ? 7 s..`.I .. .r. Il.. ' w.e ,...u.. ..?..n n. z •...,. ye.m. I.. .nM, ... W-2 Wage and Tax Statement 2000 . 89898.67 23547.16 c tm.yr.,'. mm.. uon.. n. ilr uu SPRINT/UNITED MANACEMENt CO 8 AP N.... Pa. 3 S..,y ....tr 4 buu . avrm y..m... , 686 7 0 724.40 0 w. 115TH STREET 9 ....n.. ue ..Ms.. 5 M.M.... ..... .. nr. 6 m.a.y. u. .mm?ela OVERLAND PARK KS 66211 89898.67 1303.53 10 o.r.nee....r. s.n. ul. 11 ....... l... m... 12 e.nenl. Ilyluu. In b. SC me ZIP .... b wu4v. u.yM....?... 13 S.. Mon. I., e.. 13 14 omu RUSSELL R GUTSHALL 4B-1077227 C 609.14 U.w.. 120.00 P. 0. Box 885 d CARLISLE PA 17013-1764 193-36.3669 iS 4•r• M••• rrr W.•i N ? . Iy „ ry X 16 s?.. 1 S.rl.r.r'..^. Ln nums.. 17 ..... __ 18 sm. Inum. u. 19 e.m..l le.aur 20 1---- rq...ur4•1.. 21 uw ....... u. yw.r..p yr .w 0.8 Ms. 15.5-oooa pest. of IN Tru Bury if C3 CORRECTED if checked PAYER'S name. sum edaress, city, state. ;'3 otle, and telephone ro. Peyn's RTN (Optional) OMB No. 1545• CORNERSTONE FEDERAL U. 0712 5 EAST GATE DRIVE y? P.O BOX 1181 C5o00 Interest Incor CARLISLE PA 17013 (717) 249-1661 Form 1099-INT PAYER'S Federal penlifKetron number RECIS Identification number 1 Interest Income not included in box I 23-198719 9-366 S Cop RECIPIENT'S name. atlareas, one 21P code 30.55 For Redipi I Early wimtlrawal penalty 3 In, .... on U.S. Savings This Is Im 8ands and 7reas. Pan' ens ?° RUSSELL R. GUTSHALL III PO BOX 885 CARLISLE PA 17013 6 Foreign tax paid Account number Form FIDELITY INVESTMENTS INSTITUTIONAL OPERATIONS CO. 82 DEVONSHIRE STREET KWIC BOSTON, HA 02109 04.6568107 I 193.36-3669 89974, NA RUSSELL R GUTSHALL P. 0. Box 885 CARLISLE, PA 17013-1764 (Keep for your records.) S 19,528.00 a Twos mlpry S 19,528.00 so Teams amount ? nm "Ismine4 S 0.00 S •mylldnlG. ,. gWyeM. lxmium. y, S 0.00 s .vxnym ux. , e alurLB -?_ ? s x S ?S for your records.) wormatbn el being furnishes R "Until Revl S Investment expenses SeMee. if yo, required to Ne a el a neglinnr pare. 7 forego woody or U.S. pminson aner sanction me• imposed an you if Income is taxable the IRS determiMs it has not b Now Department of the Treasury -Internal Revenue Sw !2000 F!j? Tau, o.a4MMn ie...I Ms...lu nMlo 5.167.84 e Mlyym Ieq.Wnp1 . YOW, e... 'ores 0.00 Distribution, Fron Pensions, Annumu Retlnment o Profit-sharing Pls., IRAs, Insurane. Contracts, em For flee pleml'e Records This lelOtMation is wino lurnlshea to the Internal Revenue Service. S I I Retirement Benefits Benefits from the Retirement Pension Plan, the Retirement Savings Plan, and Employees Stock Purchase Plan combined with Social Security and your personal savings can provide you with financial security throughout your retirement years. Pension Plan and Social Security Your Current Status Each year you are earning (accruing) a .retirement benefit. S 2,854 was your estimated monthly accrued benefit as of 12/3112000 payable for your lifetime beginning at your normal retirement date of 03/012013 You are fully vested In your accrued benefit Payment of Pension Benefits If you are married when you retire, your pension benefit will be paid as a 50% joint and survivor annuity unless you and your spouse elect otherwise in writing. This form provides a reduced benefit to you for your lifetime and, in the event of your death, 50% of this benefit to your spouse for i his or her lifetime. Other forms of payment are also available and are described in detail in Your Employee Benefits Handbook on-line at http://ppld.corp.sprint.com/hrtDen/yeb/yeb.htmi. Calculation of Benefits +2 The benefits presented here are based on your compensation and personal Beta as of 12/312000 with calculations as of 121312000. Some prior pay rates may have been approximated. However, your actual pension benefit will be based on your eligible earnings prior to your retirement date. 183.36-3869 Your benefits are based on the following it Pension 09/1611967 Service Date Vesting 09/15/1967 Service Date 2000 Pensionable S 90,920 Earnings Date of Birth 0210311948 Spouse's Date 0629/1948 of Birth i i i i i i i 14 'Retirerhent Savings Plan Plan Highlights • You are eligible to Participate in the Retirement Savings Plan Immediately and will receive the company matching contribution after six months of service. • You may make pre-tax contributions of 1 % to 10% of pay through convenient payroll deductions, subject to the legal maximum Of 610,500 for 2001. • The company matches your contributions - the match varies (based upon Sprint's stock Performance) from 500 to 750 for each dollar you contribute, up to the first 6% of your eligible pay. • You may invest your contributions in a number of diverse Investment options. • You are always 100% vested in the value of your contributions to the Retirement Savings Plan. Generally, you become 100% vested in company contributions after 5 years of service. However, other vesting schedules may apply If you were employed by another company that merged with Sprint. Your Current Status You are currently contributing 0% of your eligible pay to the plan. As of 3/312001, your Retirement Savings Plan balance was: 6 pre-tax employee contributions and earnings 5 company contributions and earnings 6 24,740.40 TRASOP 6 24,740.40 total account balance You may request Retirement Savings Plan Information on-line at NetBenefits, www.401k.com, or by calling 1.800-877.401k (4015). 193.36-3669 P P 193-. r '. I I -w Sprints Sprint Retirement Savings Plan #BWNFXTG RUSSELL R GUTSHALL P. O. BOX 885 CARLISLE, PA 17013-1764 ENV#NA007183 NA 89974 E Retirement Savings Statement Apol 1, 2001 - June 30, 2001 Social Security Number: 193-36.3669 IT For information on your account, please call 1-800.877.401 k between 7:30 AM and 11:00 PM Control Time. Internet address: www.401 k.com A Message From Sprint Corporation You now have 30 investment options to choose from under the Retirement Savings Plan. The Sprint Company match will be 50% for 3rd quarter 2001. Sprint will match 50 cents for every $1.00 you contribute to the Sprint Retirement Savings Plan-up to 6% of your eligible pay during July, August and September 2001. The company matching conlrlbullon will be allocated 51 % Into the Sprint FON Stock Fund, and 49% Into the Sprint PCS Stock PCS Stock Fund. If you have any questions regarding this statement, call the Retirement Savings Plan Service Center at 1.800.877.401k (4015). Representatives are available to assist you from 7:30 a.m. to 11 p.m., Central Time. Your Account Summary Beginning Balance $24,740.41 Change In Market Value 2,313.81 Ending Balance $27,05422 Additional Information ? Vested Balance $27,054.22 ? Dividend & Interest $84.44 Your Personal Rate of Return This Period 9.4% Year to Date 11.5% Your Personal Rate of Return is calculated with the tirw-walghted formula, a formula widely used by financial analysts to calculate the Investment samings of a portfolio. It reflects the results of your investment selections as well as any activity In the account Thar, are other Personal Rate of Return formulas used that may yield different results. Remember that past padornanos is ro guarantee, or future results. Your Asset Allocation ® Sprint FON Stook 8M Sprint PCS Block 4W Your account Is currently allocated among the wet olaou specified above. Percentages and totals may not be exact due to rounding. Please read this statement carefully. Any error must be reported to FldeOty Imrntr ants within 90 drys. Sprint Retirement Savings Plan; P.O. Box OH 45277.0065 1of 8 Sprint Retirement Savings Plan Market Value of Your Account Displayed in this section Is the value of your account for the statement period, In both units and dollars. ASSET CLASS OPTIONS on Units on Price on Price on Market Value Market eee.eaa 999.616 4i14.99 $14.57 14,897.41 TRASOP 767.186 767.186 $12.83 $16.28 9,843.00 Remember that a dividend payment to mutual fund shareholders reduces the share prim of the fund, so 'a decrsass in the share price for the statement period does not necessarily reflect lower fund performance. Based an the dosing prim of $21.36 per share, your account equates to approximately 661.6555 shares of Sprint FON TRASOP Stock. Based on the closing prim of $24.15 per share, you account equates to approximately 517.1755 shares of Sprint PCS TRASOP Stock. Your Account Activity Use this section as a summary of transactions that occurred In your account during the statement period. Ending Balance $14,564.43 512,489.79 $27,05422 Dividenda interest $84.44 $0.00 $84.44 Your Contribution Elections as of 08/06/2001 This section displays which funds your contributions wig be invested In. Company nves me f Matching onr Sprint FON Stock nd 51% Sprint PCS Stock Fnd 49% Total 10091, Statement Period: 04/01/2001 to 06/3012001 Social Security Number: 193.36.3669 Your Account Information If Information below it incorrect, please contact your Benefits Office. General Information Participant Status Eligible Division SC K6 Deferrals Pre-Tax 0% 7183 NA007183 0001 20010807 NA41K 193363669 Sprint Retirement Savings Plan; P.O. Box 770003; Cincinnati, OH 45277.0065 Page 2 of 8 Sprint Retirement Statement Period: 04101/2001 to 06/30/2001 :? Savings Plan Social Security Number: 193.36.3669 I 1 Fund Performance mma ryof Investmant performance of all funds avallable A su In the plan. Funds you own we marked with an asterisk I' y y j]•:YYlE far >).I>A''?3 ..^i?ILfi ]..13N?•13'1 Ily;tr _ u t ? I iS nit 3yt EP i( 1,34 ) Iryi'J 1'».I. If ,,f njm YIY L ?1y,' R2 M{7C?C} P fJC? AT EA I NO ! » H. » w ro .] a , ] , :. ] ] 1 W:14 .t wM. NXH l j8s E . i J Cumulatln% ! Annual Top/ MIUm 11 AY ,Annusl Tola/Aslum%aaolooa*2w Meaplbp Investment NRS Coda) I JAfonm Y7D I Z 7000 1999 /09s fYas JYsr Sri, IOY er till, Date 1 ,f?ir,Jh i?..,7„E?rt»?'x•:.rl,..??f'? 3kt]6R? iA].IS, P...',h??xx°D?.71.? lui ]I.I.din.'m,x?ro??, ,' ,i?•"W,??'»;,?i»']'K ? t Con Cons s Growth Port 2 (2582' 1.8833 1.31 4 10.30 rJ 4.48 /B 6.69 9 10.30 3.38 5,,6161 7.46 7.67 WA 12AI/19 199C .... »]ya ,• t s 1? ] xg? r]m;r.•.r,•• 8lpnka ' o t' 13 1 AM I - N -?h 6 8r ;3 7 ? -? Fa * i1? ]A1N> 1 ! M a d Moderate Ground Port (22583) 2.65 -0.62 1 0 52 N/ WA 8.777 7 9. 8, -0..70 ,85 9.53 14?01 5.23 A 12131%1990 ' 9 ' Balanced Growth Port (22664) 3.12 .3.07 -1.47 12.88 17.56 -5.47 4.53 9.89 11.03 N/A 12J31/ 99C i.,.,. High Growth A G P t( 72 06 "f k ggress rowth or 22566) 5.54 -6.66 -9.42 22.2 22.10 -14.82 3.08 11. 13. WA 12/31/1990 , }'] ?? x '71 >%T] _. ] t ? ? ] ) ]]. 1' S Iwi •3 ? ]•y ST 1Ct C?S a - ; ? • 'TWOMM?' l . : s. ,1 , 1 . m i >. • Cumulatln% 1 I Annual Total Aolum% Avarpa Annual Total Aafum %asol0Y3d7001 Inesplbn I I !,' In metmant-(VRS Code) 7Monfh YTD riar SYsar t0Y sr 411, 1000 1099 f09e tYur J Data , ; Sri ? S ?.(19 tM.,4tnY,Y1&Pi8Yi£i»2R in >?«.r>31.5» I:)31'i3'S:{:a?lrrr37wis%]wmr..Jl?'iSni3'JfS]i"m'iR4Y'it';3ii::er'%i?i'`i6?e5?Y ]%i'3'tmw ]?.'r.'r{?7" jd 3Q Money Markel Fund Barclay Money Mk (22576) 1.15 2,63 6.55 5.25 5.66 6.12 5.76 5.72 5.19 WA 1213111990 7+Day Yield: WA Market Indicea- LB 1.3 Gov/Corp Bond index 1.32 4 33 6 08 3 15 6 98 9 48 6 53 6 58 6 47 WA . . . . . . . . Interest Income Fund PIMCO Sep Mgd I AW (22502) 1.67 4.56 7.87 3.74 6.80 9.24 6.55 7.37 7.54 WA 12131119W 7-Day Yield: WA p.......r:3:1!Y,?rSIY?.^+.,xxf'$]`f.t:>`.:']':•:'i::::):]::YfA^)Y.J••i:{."Jy::Y.'u.....OTC' .:':]:,Y.....f:l`:::>:Y:::::]::T.iki:il':'Y:A)Y.::%::.Y....».I.r.......r.....]::::I>:I:TY`::,'l.]::.Y],Y.:I r.RLI! .:3.:']]3'P1t]3:i.'33) pi C>.li.:..,e: 'i'.v .11M. ;r] _ti. Bond Fund PIMCO Sep Mgd B Aoct (22503) -0.07 280 11.89 -0.68 9.65 10.57 6.24 8.08 9.03 WA 17131119W .y Market lndicsa- LB Agg Bond Index 0.56 3.62 11.63 -0 82 8.59 11.23 6.26 7.48 7.87 WA , Silt o.C.k6 n?]».?i ?'n'. m..n .]3w,ne...i 3»tt]3l]u.:;z3c.w.: r Y -t3 n.]].:»..n.?]>]GY.:3kel 0%v%rx.G.. M.. .7. US Slack Index Fund Barclay Eq Index F (22577) 5.88 .6.68 -9.11 21.01 28.57 -14.78 3.90 WA WA WA 02/2811997 Marketlndices- SSP 500 5.85 -6.70 .9.10 21.04 28.68 -14.83 3.89 14.48 15.10 WA Small Cap Stock Fund Barclay Russ 2000 F (22578) 14.48 6.83 -2.94 20.63 •2.84 0.54 5.00 WA WA WA 12/31/1997 Market Indices, Russell 2000 Index 14.29 6.85 •3.02 21.26 -2.55 0.57 5.28 9.60 13.49 WA International Slk Fnd Barclay EAFE Eq Fnd (22579) -0.90 -14.54 WA WA WA .24.06 WA WA WA WA 0413012000 Market Indices- EAFE Index -0.90 -14.45 -14.01 27.22 20.27 .23.40 -1.02 3.10 6.49 WA ].:••: ]> a _. 3 .. i.-1.. r r i.r,3.%'x , p f:>Nwi»15-rr11i..1e ernl»U1?«91v n] Stock Funds Sprint FON Stock Fnd (92772) -2.15 6.52 .68.49 59.77 WA -56.20 .10.56 4.40 N/A 13.36 03101/1992 Sprint PCS Stock Fnd (92774) 26.30 17.93 •58.72 325.77 WA -58.03 WA WA WA 30.20 112311998 Sprint FON TRASOP (92770)- -2.24 6.41 WA WA WA -56.76 WA WA WA .16.92 112311998 Sprint PCS TRASOP (92768)' 26.89 18.14 WA WA WA .58.91 WA WA WA 44.28 1123/1998 Sprint PCS CESOP (20805) 27.00 18.25 WA WA WA WA WA WA WA WA 10131/2000 Sprint FON CESOP (20807) -2.33 6.35 WA WA WA WA WA WA WA WA 1013112000 7183 NA007183 0001 20010807 NA4K 193363669 Sprint Retirement Savings Plan; P.O. Box 770003; Cincinnati, OH 45277-0065 Page 3 of 8 Sprint Retirement Savings Plan Statement Period: 04/0112001 to 06/3012001 Social Security Number: 19336.3669 Fund Performance (continued) 13 UWrii?, %{oUry , nm?,ip, r: tEi. r»wn::-, n»,u»r+ ,. in.ju %as Investment IVRS Code/ 19ManLti 4tlw% nu-l' Rel 1" I AYure A7 YwrTofa YN mlo Year Ihf I In War P J, 2occ High Yield Bond Fund PIMCO High Yield (1) (93596) -1.17 2.78 -0.44 2.82 6.54 2.92 2.32 6.77 WA 8.98 12/1611992 Global Bond Fund Plmco Foreign Bond 1(91392) -0.41 3.02 9,86 1,67 10.03 8.99 6,25 9.24 WA 9,53 120311992 Emerging Mtk Debt Fund GMO Ernst Cry Debt Sh (22728) N/A WA WA WA WA 18.09 9.43 18.97 WA 20,06 0720/1998 Value Stock Fund 1 Barclay Russlo00 Val (22580) 4.98 -1.29 7.09 WA N/A 10.35 WA WA WA WA 0 613 0/1 9 9 9 Value Stock Fund 11 Fidelity Equity Inc (00023) 5.25 -1.05 8.54 7,15 12.52 10,07 5,19 13.33 15.45 14.14 05116/1966 Growth Stock Fund I Harbor Capital Appr (92171) 4.40 -1265 -17.00 45.81 36.80 .30,38 6.07 15.92 18.15 17.44 1212911987 Growth Stock Fund II Fidelity Magellan(00021) 7.18 -6.12 -9,29 24.05 33.63 -15.43 6.13 14.19 15.44 21.03 05/02/1963 Mid-Cap Growth SIR Fnd Fidelity OTC Port (00093) 19.40 -14.10 -26.81 72.53 40.38 40,94 8.65 13.48 15,51 17.87 12/31/1984 Aggreee Growth SIR Fnd White Oak Growth SIR (91784) 3.59 -30.89 3.60 50.14 39.50 44,81 6.17 16.95 N/A 18.29 08MY1992 Large Blend Block Fund Fidelity Divd Growth (00330) 7.68 -1.23 12.26 8.81 35.85 2.78 10.61 19,02 WA 21.02 042711993 Mid-Cap Value Slit Fund Am Cent Eq Inc Intl (22678) 7.03 5.41 22.14 0.01 WA 28.35 WA WA WA 11.17 07/0811998 Small-Cap Gwth SIR Fnd Barclay Russ 2000 Gr (22581) 17.95 -0.02 WA WA WA -23.20 WA N/A N/A N/A 03/3112000 Small-Cap Val SIR Fund DFA US Sm Cap Value (22869) 16.87 23.33 9.01 13.05 .7.30 27,31 9.88 15.02 WA 15.90 04MI11993 Global Equity Fund Janus Aspen Ww Gnh (92170) 4.00 -13.49 -15.67 64.15 28.92 -28.52 6.72 15.13 WA 18.46 0911311993 Intl Equity Growth Fnd Fidelity Overseas (00094) 0,00 -11.26 -18.33 42.89 12.84 -23,91 0.29 6.45 8.37 14.54 12/0411984 Intl Equity Value Fund Capita G Intl Eq (22349) 0,15 -11.33 WA WA N/A -27.06 6.67 10.64 12.52 14.23 0710111978 Emerging MR[ Eq Fund Capital G Em Mkt Eq (22350) 6,74 -2.29 WA WA N/A -30.01 4.45 -0.48 WA 8.72 11130/1994 Put performance Is no guarantee of future results. Total returns are historical and Include the change In share value and reinvestment of dividends and appal gain distributions, If any. Cumulative returns are reported as of the periods shown. Ufa of fund figures are from commencement data to the period shown. Due to regulatory requirements the average annual tow returns are reported as of the most recent calendar quarter for the periods shown and are calculated using a standard formula. The figures do not Include the effect of sales charges, If any, as those charges are waived for contributions nude through your company's employee bonsfit plan, If sales charges were Included, returns would have boon lower. Each funds there price (except money market funds), yield, and return will vary and you may have a gain or loss when you sell your shares. Non-Fidelity mutual funds are managed by non-Fidelity entities. Please consult the prospectus for more Information. If applicable, class of shares may very. Please consult your plan documentation for the spook class of shares avallable through your plan. Performance Information for nomFldelity mutual funds was provided by a third-party. Although data Is carefully verified, accuracy and completeness cannot be guaranteed. flW NA00/183 0001 20010807 NA4K 1933636f Sprint Retirement Savings Plan; P.O. Box 770003; Cincinnati, OH 45277.0065 Page 4 of Sprint Retirement Statement Period: 04/01/2001 to 06/3012001 Savings Plan Social Security Number: 193.363669 Fund Performance (continued) The actual perfomance of the Sprint FON common stock may vary slightly from the Sprint FON Stock Fund as the Fund holds a small Percentage of Its assets In cash lot purposes of liquidity. The actual padomnance of the Sprint PCS common stock may very slightly from tie Sprint PCS Stock Fund as the Fund holds a small percentage of Its assets In cash for purposes of liquidity. Fidelity Overseas Fund assessas a short-term trading foe of 1.0DY. for shares hold less than 30 days. ' The Lohman Brothers 1.3 year Government Corporate Bond Index Is an unmanagd Index comprised of government and corporate fixed-rata debt Issues. Issues trust hays at least one year, with up to but not Indding, three year maximum maturity. ' The Lohman Brothers Aggregate Bond index is a market value-welaahted performance benchmark for Investment grade fixed-rate debt Issues, Including govsmmenl, corporate, asset-backed securities, with maturities of at least one year. The S&P 500(R) Is a registered service mark of The McGraw-Hill Companies; Inc., and has been Ilemsed for use by Fidelity Distributors Corporation and Its affiliates, It Is an unmanaged Index of the common stock prices or 500 widely hold U.S. stacks. ' Russell 2000 Small Stock Index is comprised or ifs 2,000 smallest securities In the Russell 3000 Index, representing approximately 7% of the Russell 3000 total market capitalization, and Includes reinvestment of dividends. 'The Morgan Stanley Capful Intamalkxusl Europe, Australasia, Far East Index EAFE), Is an unmanaged Index of over 1,000 foreign common stock prices and includes Ifs reinvestment of dividends. The SAFE (R) Index Is a registered service mark of Morgan Stanley and has been licensed for use by FMR Corp. Unless specified, the Investment options offered through the Plan are neither sponsored by nor affiliated with Morgan Stanley. + Past performance Is no guarantee or future results. Total returns we historical and Include the change In share value and reinvestment of dividends and capital gain dialdbutions, If any. Cumulative volume an reported as of the periods shown. Ufa of fund figures are Irom commencement date to Be period shown. Due to regulatory requirements the average annual total returns are reported as of the most recent calendar quarter for the periods shown and are calculated using a standard formula. The figures do not Include the effect of sales charge, It any, as these charges am waived for contributions made through your company's employee benefit plan. If Was charges were Included, returns would have been lower. Each lull's share price, yield, and return will vary, and you may have a gain or loss when you sell your shares. The Pro-Mixed Portfolio Investment Options are not mutual funds. They are designed and constructed by Sprint for the specific use of fie Retirement Savings Plan, effective 7102/01."There is no historical performance for the Conservative Growth Portfolio. Performance Is based on a combination of the pariornance from the following representative benchmarks: 25% Lehman Brothers 3-Month Treasury BIII Index, 12Y.S&P 500 Index, 2-/.Russell 2000 Index, 6%MSCI EAFE Free Index, 35% Lehman Brothers 1.3 Year GovemmenVCorporsto Bond Index. and 20% Lehman Brothers Aggregate Bond Index.' There is no historical rbarformance for time Moderate Growth Portfolio. Performance Is based on a combination of the performance from the following representative nchmarks: 24% S&P 600 Index, 6% Russell 2000 Index, 11% MSCI EAFE Free Index, 30% Lehman Brothers 1.3 Year Govomment/Cotporalo Bond Index, and 30Y. Lehman Brothers Aggregate Bond Index. There is no historical performance lot the Balanced Growth Portfolio. Performance Is based on a combination of the performance from the following representative benchmarks: 38% S&P 500 Index, 7% Russell 2000 Index, 15% MSCI SAFE Free Index, and 40% Lehman Brothers Aggregate Bond Index. "There Ism historical performance for the High Growth Portfolio. Performance Is based on a combination of the performance from the Iotowlng representative benchmarks: 50% S&P 500 Index, 11% Russell 2000 Index, 19% MSCI SAFE Free Index, and 20% Lehman Brothers Aggregate Bond Index." There Is no historical ppsrfor ance for the Aggressive Growth Portfolio. Portornance Is based on a combination of the performance from the following representative benchmarks: 64% S&P 500 Index, 14% Russell 2000 Index, and 22% MSCI SAFE Free Index." The Russell 1000 Value Index measures the performance of those Russell 1000 companies with lower price-*book notice and lower forecasted growth values. The U.S. Stock Indaz Fund (Barclays' Equity Index Fund F) Is not a mutual fund and Is managed by Barclays' Global Investors, N.A. Actual performance is shown for 1 6 3 year performance information. Because 5 8 10 year performance does not exist for this fund, the 5 6 10 year perionnance Inlcmnal on represents the fund's benchmark index, the S&P 500 Index. Tha Value Stock Fund I (Barclays' Russell 1000 Value Index Fund *F') Is not a mutual fund and Is managed by Barclays' Global Investors, N.A. Actual anca Ia shown for 1 year pariormance Information. Because 3, 5 a 10 yostpodormance does not exist for this fund, the performance Z=tion represents the lunds benchmark Indaz, the Russell 1000 Value Index. The Russell 2000 Growth Index measures the perionmance of those Russell 2000 rompanies with Nghor price-to-book ratios and higher forecasted growth values.' The Sprint PCS and FON Stock Funds we not mutual funds nor diversified or managed Investment options.' The Bardays' Money Market Fund Is not a mutual lund and is managed by Barclays' Global Investors, N.A' The Interest Income Fund and Bond Fund (PIMCO Separately Managed Accounts effoctive 7001) are not mutual funds and are managed by Padfic Investment Management Company. The performance information featured Is based on the composite performance of PIMCO's separately managed accounts with slender Investment objectives. The Small Cap Fund (Bardays' Russell 2000 Index Fund'F) Is not a mutual fundand Is managed by Barclays' Global Investors, NA. Actual performance Is shownfor 1 a 3 year performance Information. Because 5 8 10 year porfor anco does not exist for this fund, the 5 & 10 year panomnamae Information represents thafund's benchmark index, the Russell 2000 Index.' The Inlematlonal Slack Fund (Bwdays' EAFE Equity Index Fund 'F) Is not a mutual fund and Is managed by Bwelayi Global Investors, N.A. Because performance does not exist for this fund, the performance Information represents the fund's benchmark index, the MSCI EAFE Free Index. 'The Small-Cap Growth Stock Fund (Barclays' Russell 2000 Growth Index Fund 'P) is not a mutual lund and Is managed by Barclays' Global Investors, N.A. Because performance does not exist for this fund, the performance information represents the fund's benchmark index, the Russell 2000 Growth Index. The Capital Guardian International (Non US) Equity Fund and the Capital Guardian Emerging Markets Equity Fund are not mutual funds and are managed by Capital Guardian Trust Company. The performance information featured is gross of Investment management leas, but not of custody, legal and audit lees. For more complete Information about any of the mutual funds available through the Plan, Including leas and expenses, call or write Fidelity for free prospectuses. Read them carelully before you make your investment choices. Fidelity Investments Institutional Services Company, Inc. 82 Davonshirs Street, Boston, MA 02109 2153420.001 7183 NA007183 0001 20010807 NA4K 193363669 Sprint Retirement Savings Plan; P.O. Box 770003; Cincinnati, OH 45277-0065 Page 5 of 8 Sprint Retirement Savings Plan Statement Period: 04/012001 to 06130/2001 Social Security Number: 193.36.3669 A Message From Fidelity Investing means accepting one important fact: most Investments can go up and down In value regularly - sometimes by a lot - even over short-term periods. Be realistic about the potential for growth for your Investments, and realistic about the risks. Over the last six years, stocks have performed unusually well with annual returns averaging about 20'x. However, stocks have had historical average annual returns of approximately 117.•. Remember that the best investment strategy Is to choose the right asset allocation of stocks, bonds and short-term Investments and to Invest for the long tens. Calf your plan's toff-tree number or visit Fidelity NstBenefits(sm) to review your asset allocation so you can be sure it's meeting your long-term needs. 'ibbolson Associates, 2001 average annual rate of return of stocks 1926.2000. Past performance Is no guarantee of future results. Stocks are represented by the Standard & Poor's 600 Index (S&P 500 Index). The S&P 500 Index is a registered service mark of The McGraw-Hill Companies, Inc., and is a widely recognized, unmanaged Index of 500 U.S. common stocks. Fidelity Investments Institutional Services Company 82 Devonshire Street, Boston, MA 02109 133000 I Sprint Retirement Savings Plan; vge, P.O. Box 770003; Cincinnati, OH 45277.0065 Page 6018. Sprint Retirement Savings Plan Statement Period: 04/01/2001 to o"012001 Social Security Number: 193.36-3069 Your Statement Glossary Average Annual Total Return: This number Is the average annual retrlm of your Involmsnt for the Periods Indicated. It is calculated by taking the funds price appreciation Plus dividends and Interest and navld It by the appropriate number of years. Please note that these numbers reaset put part omwrtee only and assume the reinvestment or all divnds and interest Your IndvlduAl Performance may not match these numbers exactly depending on the tiring of your Investment Change In Value: a change In value underlying Investments (stocks, bonds or ions Investme Uj eIndththe funds y e Account Summary section of your statement, this number their Is the total of all changes In all of your Investments due to these types of fluctuations. Dividends and Interest: A distribution of income from your fund(s) that Is a result or a distribution of earnings from Its underlying investments. This amount Is automatic ally reinvested Into your account. Market Value. Market value Is the dollar value of the Investments in your account. You an calculate your market value by using the following formula. Market value • Number of shares In your account x Price perehare of the kind. - Shares: Shams are your units of ownership or each investment In your account. ' Share Price: The value of one share of each Investment In our account Is called share price. It. Is determined by taking the total value of the whole mutual iven num 'r our com stock fu Is usin unit aetlvl7ln uw fund, a mancl ethod tltiat combines ccommon stock along with me Ysmall portion or short term Invest ents (sometlrtroc rotas d boas .cash ). The ash portion of the fund enables stock fund trading every business day, similar to mutual funds, rather than the typical three day settlement padod which occurs when stock Is traded on the open market. Unitization does not affect the value of your ownership in company slat only manner in which It is expressed Trade Date: _ This Is raw date a transaction In your account occurred Vested Balance: The vested part of your account balance is the portion of your account contributed by your company that you own. This balance usually Increases gradualty over time and Is basso upon your length or amployrant (and other factors) with your current employer. The amount that you have contributed yourself Is Always 1009: vested. •,N. nnwr.w uuut ZU010807 NA4K 193363669 Sprint Retirement Savings Plan; P.O. Box 77ooo3; Cincinnati, OH 45277.0065 Page 7 of 8 It Retirement rags Plan it Allocation: Investments may be divided Into three major asset classes: a, Bonds and Short-Term Inwsbnants. Thew asset classes sent the different types of underlying securities that may be held mutual fund(s) you own. Please note that you mar, be Invested "need or asset allocation fund where Me land hoings are ad In more than one asset class. In this saw, your fund will be yed In the asset class In which it most resembles. ? Stocks: Stocks can add a growth component to your portfolio. They represent ownership or equity In a company. Stocks have the potential to outperform other types of Investments over the rag-lerm. However, stocks tend to have wider price fluctuations over short periods of time than other securities. ? Bonds: Bonds can add an Income portion to your portfolio. They represent a loan to a corporation or government agency, and rovide the opportunity for higher current Income than short-tam Investments. Unlike short-term Investments, however, bond prices fluctuate with changes in Interest rates. ? Short Term: Short term Investments can add stability to your portfolio. They provide current Income and seek to preserve the value of your nvestment. They also tend to provide the lowest returns war the long-term. Examples of these investments Include certificates of deposit (CDs), Treasury bills, and money market Instruments. Statement Period: 04/0112001 to 06130/2001 Social Security Number: 193.36.3669 Market Indices: A market Index can measure the general trends in the performance of certain types of securities. You can use thou indices to compere he vested (average annual return) of the funds In which you are invested with the performance of ins appropriate market Index. ? Russell 2000 Index. This Is price-weighted average of 30 actively traded blue chip stocks, primarily Industrial stocks. You can use this Index to compare to the Performance of some of your stock funds. ? Lehman Bros. Aggregate Bond Index: This measures the total return of over 6,000 high-quality bond Issues, hGudnp government, corporate, and mortgage sectors. Bonds In this prlcaevelghtad Index have an average maturity of 10 years. ? Lehman Bros. 1.3 Yr Gov/Corp Bond: The Lehman Brothers 1.3 You Govamment/Corporats Bond Index Is a market value weighted performance benchmark for government and corporate fixed-rate debt Issues with maturides between one and three years. ? Standard and Poor's 500: An Infix of 500 stocks of large, established publicly traded firms. Because the Index is Capitalization weighted (the price of each $look Is multiplied by the number of shares outstanding), companies with the greatest market value have the greatest Influence on the Index. You can use this Index to compare to the performance of some of your stock funds. ? Mar an Stanley EAFEIndex: The EAFE Index (Morgan Stanley Capital International Europe, Australia, Far East index) is an unmanaged Index of over 1,000 foreign common stock prices and includes the reinvestment of dividends. It tracks 20 developed stock markets outside of North Amer ea 1183 NAUU/1133 UUU1 20010007 NA4K * Box 770003- Cincinnati Sprint Retirement Savings Plan; P.0Will 1111111I1Hill 11111111111111f111111111?111111111116111111111111fill 1111111111fill Page RUSSELL R. GUTSHALL, III, Plaintiff, V. SANDRA M. GUTSHALL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA No. 99-5578 CIVIL TERM IN DIVORCE CER ICATE OF SERVICE I, Susan M. Kadel, Esquire, of James, Smith, Durkin & Connelly, attorney for the Defendant, Sandra M. Gutshall, hereby certify that I have served a copy of the Defendant's Pre-trial Statement on the following on the date and in the manner indicated below: U.S. MAIL, FIRST CLASS, PRE-PAID Peter J. Russo, Esquire 5010 East Trindle Road, Suite 200 Mechanicsburg, PA 17050 ?uL DATE: JAMES, SMITH, DURKIN & CONNELLY By:??GG san . Kadel, Esquire Attorney for Defendant Post Office Box 650 Hershey, PA 17033 (717) 533-3280 PA I.D, No. 44837 N - Fn e ltu i ?l °j ? o U f .• RUSSELL R. GUTSIIALL, 111, Plaintiff/ Respondent VS. SANDRA M. GUTSHALL, Defendant /Petitioner DR 29,096 PACSES ID 582101624 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : DOMESTIC RELATIONS SECTION : CIVIL ACTION - LAW NO. 99-5578 CIVIL TERM ORDER OF COURT AND NOW, this 16`h day of March, 2000, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $974.39 per month and Respondent's monthly net income/earning capacity is $4,528.21 per month, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $453.00 a month payable monthly as follows: $403.00 per month for alimony pendente lite and $50.00 per month on arrears. The effective date of the order is February 24, 2000. Arrears set at $206.23 as of March 24, 2000. Husband is to make direct payment in the amount of 40% of any net bonus to wife and to provide verification of said bonus and payment to DRO withing five days of receipt of any bonus. This Amended Order is based upon an agreement of the parties. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa. C. S. § 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the PA SCDU to: Sandra Gutshall. Payments must be made by check or money order. All checks and money orders must be made payable to PA SCDU and mailed to: PA SCDU P.O. Box 69110 Harrisburg, PA 17106-9110 Payments must include the defendant's PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. fI Unreimbursed medical expenses that exceed $250.00 annually are to be paid 57% by the respondent and 43% by petitioner. The plaintiff is responsible to pay the first $250.00 annually in unreimbursed medical expenses. Respondent to provide medical insurance coverage as provided by his employer. This Order shall become final ten days after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary for a hearing de novo before the Court. DRO: R. I Shaddav Mailed copies on Petitioner 04' to: < Respondent LV Samuel Andes, Esquire Kathleen Daley, Esquire BY THE COURT, Edward E. Guido J. 3 ? (l; (1 ? ? ?J I ?/ I?oKU RUSSELL R. GUTSHALL, III IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW SANDRA M. GUTSHALL NO.99-5578 CIVIL TERM Defendant IN DIVORCE PLAINTIFF'S PRE TRIAL STATEMENT AND NOW COMES, Plaintiff, by and through his counsel, Peter J. Russo, and sets forth the following Pre Trial Statement: L ASSETS- Marital Property Item Value Lien HOUSE 235,000.00 145,000.00 5.8 acres of unimproved mtn. land 14,000.00 0.00 1987 Aerostar Van 2,000.00 0.00 1988 Ranger Sup Cab 3,000.00 0.00 Safety Deposit Box 200.00(estimate) n/a Sprint Retirement 75,354.27 n/a Cornerstone Fed CU Checking Acct. 576.99 n/a Cornerstone Fed CU Savings Acct. 67.57 n/a Cornerstone Fed CU Christmas Club Amt. 1818.23 n/a Cornerstone Fed CU Vacation Club Amt. 3396.07 n/a Prudential Life Ins Policy 5,000.00 n/a Prudential Life Ins Policy 5,000.00 n/a Sprint Life Insurance Policy 3 x pay n/a Sprint Life Insurance Policy 25,000.00 - Wife 10,000.00- each dependent n/a 1973 Starcraft Pick-up Camper 100.00 n/a Household goods and furnishings 8000.00 n/a Longaberger basket collection unknown n/a Jewelry collection unknown n/a ASSETS - Non-Marital Property Item Date ofAequisMon Value Basis Butcher Block prior to 1969 5.00 had ri or to marriage Wooden Bowl prior to 1969 5.00 made in hi school Family Dishware prior to 1969 10.00 family heirloom Guns prior to 1969 25.00 had prior to marriage Tools prior to 1969 10.00 had prior to marriage Additional Contributions After Date of Separation Unknown Acquired post separation II. EXPERT WITNESSES Plaintiff does not intend to call any expert witnesses to trial. Plaintiff reserves the right to amend this pre-trial statement to include any experts required to rebut the testimony of any Defense experts that may be called. III. WITNESSES Plaintiff intends to call the following witnesses to trial: a. Russell R. Gutshall - Plaintiff: Will testify as to the assets, his financial status, etc. b. Angela Bistiine - Parties' daughter who will testify as to the parties' relationship. C. Candice Overemiller - Parties' daughter who will testify as to the parties' relationship. d. Russell K. Gutshall IV - Parties' son who will testify as to the parties' relationship. e. Wants Stewart - Testify as to her relationship with the Plaintiff. Plaintiff reserves the right to amend this pre-trial statement to include any experts required to rebut the testimony of any Defense experts that may be called. IV. EXMB Plaintiff intends to introduce the following exhibits: a. Plaintiffs 2000 & 2001 W2's - Not Attached b. Plaintiffs 2000 & 2001 Federal Tax Return -Not Attached C. Plaintiffs Pay Stub - Not Attached d. Keystone Financial Account Statement for Defendant - Not attached e. Cornerstone FCU Statements - Not attached f. All documents identified by Defendant - Not attached V. INCOME OF PLAIN W Employer: SPRINT / United Mans ent Co. Job Titie/Description: Manager Payroll Number: 193363669 Pay Period: BI-WEEKLY Gross Pay per Pay Period: $3,314.56 ITEMIZED PAYROLL DEDUCTIONS: Federal Withholding $ 825.91 Social Security $ 20231 Local Wage Tax $ 33.15 State Income Tax $ 90.61 Retirement $ Savings Bonds $ Credit Union $ 1175.00 Life Insurance $ 43.37 Health Insurance $ 340.13 Other (PAC/UW) $ 21.00 PA Unemployment $ Flex Credit $ (305.58) Before Tax Savings $ After Tax Savings $ Occupational Tax $ Medicare $ 47.32 Net Pay per Period $ 835.34 VI. EXPENSE See Attached Income and Expense. VII. PENSION Plaintiff has a pension through his employer. Plaintiffs pension has been significantly reduced as a direct result of the fluctuation in the stock market. Defendant also has a pension through her employer. VIII. COUNSEL The parties are capable of paying for their respective counsel fees. IX MARTIAL DEBT Debt Amnunt Rnlnnna D......,,_. Cornerstone Fed CU. Mortgage on 26 Stewart Dr. 150,000.00 141,634.64 $ 1,650.00 - Paid by Plaintiff Cornerstone Fed CU - Line of Credit 3,389.83 0.00 Plaintiff id in full First USA Credit Card 4,81038 0.00 Plaintiff id in full Discover Card 875.86 0.00 Plaintiff paid in full MBNA America Visa Card 1,105.40 0.00 Plaintiff aid in full PNC Bank Personal Loan 2,246.88 0.00 Plaintiff paid in full XI, PROPOSED RESOLUTION Plaintiff proposes that the parties sell all of the real estate. From the proceeds, pay the balance of the outstanding financial obligations. Husband shall be credited for payments to creditors made by the Plaintiff. Defendant shall be provided $60,463.92 in cash. Res ectfull Peter J. Russo EXPENSES: WEEK MONTH YEAR Home Morose $ $ 1.650.00 $ 19800.00 Rent $ $ $ Maintenance $ $ $_ 300.00 Utilities Electric $ $ 180.00 $ 2.160.00 Gas $ $ $ Oil $ $ $ Telephone Wate $ $ 25.00 $ 300.00 r Sewer $ $ 50.00 $ 600.00 $ $ 17.00 $ 204.00 Employment Public Transportation $ $ $ Taxes Lunch $ $ 100.00 $ 19D0.00 Real Estate $ $ $ Personal Property $ $ $ 25.00 Income Insurance $ $ $ Homeowners $ $ $ Automobile $ $ $ 1.168.00 Life $ $ 28.65 $ 344.00 Accident $ $ $ Health $ $ $ Other $ $ $ Automobile Payments $ $ $ Fuel $ $ 125.00 $ 1500.00 Medical Repairs $ $ $ 1M.00 Doctor $ $ $ 200.00 Dentist $ $ $ 500.00 Orthodontist $ $ $ P i in $ $ $ ed c e $ $ $ 200.00 Special needs ( ) $ $ $ Education Private School $ $!_ $ Parochial School $ $ $ College $ $ $ Religious $ $ $ Personal Clothing $ $ $ .1.00.00 Food $ $ 200.00 $ 2&00.00 Barber/Hairdresser $ $ $ 23100 Credit Payments $ $ $ Credit Card $ $ $ Charge Account $ $ $ Memberships Loans $ $ $ 50.00 Credit Union $ $ $ Loans Miscellaneous Household Help $ $ $ Child Care $ $ $ Papers/Books/Magazines $ $ $ 100.00 Entertainment $ $ $ 500.00 Pay TV $ $ 35.00 $ 420.00 Vacation $ $ $ 500100 Gifts $ $ $ 1.00.00 Legal Fees $ $ $ 500.00 Charitable Contributions $ $ $ 200.00 Other Child Support $ $ $ Alimony Payments $ $ $ Oth er Total Expenses $ $ $ 36,905.00 RUSSELL R. GUTSHALL, III Plaintiff V. SANDRA M. GUTSHALL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-5578 CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I, Melissa M. Mehafl'ey, hereby certify that I am on this day serving a copy of the foregoing documents upon the person (s) and in the manner indicated below; Service by First-Class Mail, Postage Prepaid, and Addressed as Follows: Susan M. Kadel, Esquire P.O. Box 650 Hershey, PA 17033 ?-_ hn IYl Melissa M. Mehaffey, Pai g Date: March 15, 2002 RUSSELL R. GUTSHALL, III, ) Plaintiff ) ) VS. ) SANDRA M. GUTSHALL, ) Defendant ) NOTICE TO PLAINTIFF NAMED HEREIN: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-5578 CIVIL TERM IN DIVORCE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO, THE CASE MAY PROCEED WITHOUT YOU, AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. 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 I3AR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 RUSSELL R. GUTSHALL, III, Plaintiff VS. SANDRA M. GUTSHALL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-5578 CIVIL TERM IN DIVORCE PETITION FOR ECONOMIC RELIEF AND NOW comes the above-named Defendant, Sandra M. Gutshall, by her attorney, Samuel L. Andes, and files the following petition for economic relief in the above matter, based upon the following: 1. The Petitioner herein is the Defendant, Sandra M. Gutshall. 2. The Respondent herein is the Plaintiff, Russell R. Gutshall, III. 3. Plaintiff commenced this action by filing a Complaint in which he raised a claim for equitable distribution but no other economic claims. COUNT I - ALIMONY 2. Defendant lacks sufficient property to provide for her reasonable needs in accordance with the standard of living of the parties established during the marriage. 3. Defendant is unable to support herself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 4. The Plaintiff is employed and enjoys a substantial income from which he is able to contribute to the support and maintenance of Defendant and to pay her alimony in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Defendant prays this Honorable Court to enter an Order awarding Defendant from Plaintiff permanent alimony in such sums as are reasonable and adequate to support and maintain Defendant in the station of life to which she has become accustomed during the marriage. COURT II - ALIMONY PENDENTE LITE. 5. Defendant is without sufficient income to support and maintain herself during the pendency of this action. 6. Plaintiff enjoys a substantial income and is well able to contribute to the support and maintenance of Defendant during the course of this action. WHEREFORE, Defendant prays this Honorable Court to order Plaintiff to pay her reasonable alimony pendente lite during the pendency of this action. COUNT III - COUNSEL FEES AND EXPENSES 7. Defendant is without sufficient funds to retain counsel to represent her in this matter. 8. Without competent counsel, Defendant cannot adequately prosecute her claims against Plaintiff and cannot adequately litigate her rights in this matter. 9. Plaintiff enjoys a substantial income and is well able to bear the expense of Defendant's attorney and the expenses of this litigation. WHEREFORE, Defendant prays this Honorable Court to order Plaintiff to pay the legal fees and expenses incurred by Defendant in the litigation of this action. I verify that the statements in this Petition are true and correct. I understand that any false statement in this Petition are subject to the penalties of 18 PA. C.S. 4901 (unsworn falsification to authorities). Sandra M. Gutsh S L. Andes Attorney for Defendant Supreme Court ID # 17225 525 N. 12°i Street Lemoyne, PA 17043 (717) 761-5361 ?. Q 0 )(`l r Ci [ C: I1. U ? <7 • ( 4 r u] a U Q r Q Q 1 11 z 0 fp W Q w A ? e 14 .1 w e N a z m z W a x ° w a 0 a a 0. H og k Q e a Z H h a . a DEC 2 1?,IY(?' RUSSELL R. GUTSHALL, III IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW SANDRA M. GUTSHALL NO. 99-5578 CIVIL TERM Defendant IN DIVORCE ORDER AND NOW, this Zb day of December, 2001, upon consideration of Defendant's First Motion to Compel Answers to Plaintiffs Interrogatories Addressed to Defendant and Plaintiffs Request for Production of Documents Addressed to Defendant and Memorandum in support thereof, it is hereby ORDERED AND DECREED that the Motion is GRANTED and rti?m? Defendant, Sandra M. Gutshall shall-Q4411 aRd to Plaintiffs Interrogatories Addressed to Defendant and Plaintiffs Request for Production of Documents Addressed to -1wc..' YC L07 Defendant (served on October 17, 2001) within tea440} rs of the date of this Order or suffer appropriate sanctions by the Court. BY THE COURT Distribution: Susan M. Kadel, Attorney for Defendant Peter J. Russo, Attorney for Plaintiff (- R S ?z 3? -o l X RUSSELL R. GUTSHALL, III IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW SANDRA M. GUTSHALL NO. 99-5578 CIVIL TERM Defendant IN DIVORCE PLAINTIFF'S FIRST MOTION TO COMPEL ANSWERS TO PLAINTIFF'S INTERROGATORIES ADDRESSED TO DEFENDANT AND PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS ADDRESSED TO DEFENDANT Plaintiff, by his attorney, Peter J. Russo, Esquire, respectfully requests that your Honorable Court compel Defendant, Sandra M. Gutshall, to file full and complete Answers to Plaintiffs Interrogatories Addressed to Defendant and Plaintiffs Request for Production of Documents Addressed to Defendant, served on Defendant, on October 17, 2001, and in support thereof states the following: 1. On or about July 30, 2001, Plaintiff filed for an Appointment of Master. 2. On or about October 17, 2001, Counsel for Plaintiff served Plaintiff's Interrogatories Addressed to Defendant and Plaintiffs Request for Production of Documents Addressed to Defendant. (A true and correct copy of the Plaintiffs Interrogatories Addressed to Defendant, is attached hereto and marked as Exhibit "A". A true and correct copy of Plaintiff's Request For Production of Documents Addressed to Defendant, is attached hereto and marked as Exhibit `B".) 3. Although frequent demands have been made, both verbally and in writing, Defendant has not answered the Interrogatories and provided documents requested, nor have they filed objections to same, in violation of the Pennsylvania Rules of Civil Procedure. WHEREFORE, Plaintiff , Russell R. Gutshall, III, respectfully moves this Honorable Court to enter an Order directing that Defendant, Susan M. Gutshall, answer Plaintiff s discovery within (10) ten days or suffer further sanctions. Date: Respectfully submitted, Peter J. Russo 5010 E. Trindle Road Mechanicsburg, PA 17050 (717) 591-1755 RUSSELL R. GUTSHALL, III IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW SANDRA M. GUTSHALL NO. 99-5578 CIVIL TERM Defendant IN DIVORCE VERIFICATION I, Russell R. Gutshall, III, verify that the statements made in the foregoing document are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date: !d - < -°? s [ E? ? Russell R. Gutsha , I RUSSELL R. GUTSHALL, III Plaintiff V. SANDRA M. GUTSHALL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-5578 CIVIL TERM IN DIVORCE MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S FIRST MOTION TO COMPEL ANSWERS TO PLAINTIFF'S INTERROGATORIES ADDRESSED TO DEFENDANT AND PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS ADDRESSED TO DEFENDANT Plaintiff, by and through his attorney, Peter J. Russo, hereby moves this Court to enter an Order compelling Defendant to file full and complete Answers to Plaintiff s Interrogatories Addressed to Defendant and Plaintiffs Request for Production of Documents Address to Defendant, and in support thereof states as follows: Counsel served Plaintiffs Interrogatories Addressed to Defendant and Plaintiffs Request for Production of Documents Addressed to Defendant, upon Defendant on October 17, 2001. A true and correct copy of the aforementioned Discovery is attached hereto and marked as Exhibits "A" and "B., Pennsylvania Rule of Civil Procedure 4006 (a) (2) requires that an answering party supply responses and objections, if any, to written Discovery within thirty (30) days. Defendant has not answered the Interrogatories, objected or filed for a Protective Order in conjunction therewith. Plaintiff has made numerous verbal and written requests for answers to Interrogatories. The information requested contains necessary and relevant information with regard to claims being asserted in the within cause of action, These requests are reasonable in scope and number. It is imperative that Plaintiff receive the information requested forthwith in order to prosecute his case. Plaintiff is entitled to an Order compelling Defendant to answer Plaintiffs discovery request pursuant to Rule 4019 of the Pennsylvania Rules of Civil Procedure. WHEREFORE, Plaintiff respectfully requests that this Honorable Court Compel Defendant to answer fully and completely Plaintiffs Interrogatories Addressed to Defendant and Plaintiffs Request for Production of Documents Addressed to Defendant, within ten (10) days of the date of this Court's Order, or suffer appropriate sanctions upon application to the Court. Respectfully submitted, Peter J. Russo 5010 E. Trindle Road Date: Mechanicsburg, PA 17050 (717) 591-1755 EXHIBIT "A" RUSSELL 11. GL:TSIIALL. III, Plaintiff, SANDRA M. GUTSHALL, Defendant IN ill[ 'COL'R1 01 COMMON I'LL:\S CUMBERLAND COUNTY. . No. 99-5578 : CIVILTERNI : IN DIVORCE PLAINTIFF'S INTERROGATORIES ADDRESSED TO DEFENDANT (First Set) TO: SANDRA M. GUTSHALL C/o James, Smith, Durkin, & Connelly LLP Susan M. Kadel P. 0. Box 650 Hershey, PA 17033 The Plaintiff, Russell R. Gutshall, III, hereby serves upon the Defendant written Interrogatories to a party pursuant to Pa.R.C.P. 1920.22(b) and 4005 to be answered by the Defendant in writing and under oath. These Interrogatories shall be deemed continuing so as to require supplemental answers should Defendant obtain additional information which is responsive to these interrogatories. The Answers to the Interrogatories shall be inserted in the spaces provided in the Interrogatories. If there is insufficient space to answer the Interrogatories, the remainder of the Answer shall be supplied on a supplemental sheet. The Defendant shall file and serve a copy of the Answers within thirty (30) days after the service of the Interrogatories to the Law Offices of Peter J. Russo, 5010 East Trindle Road, Mechanicsburg, PA 17050. DEFINITIONS AND INSTRI C'FIONS Unless negated by the context of the Interrogatory. the following definitions arc to be considered w be applicable to all Interrogatories contained herein A "Documents" is an all-inclusive term referring to any writing and/or recorded graphic matter, however produced or reproduced. The term documents includes, without limitation, correspondence, memoranda, interoffice communications, minutes, reports, notes, schedules, analyses, drawings, diagrams, tables, graphs, charts, maps, surveys, books of account, ledgers, invoices, purchase orders, pleadings, questionnaires, contracts, bills, checks, drafts, diaries, logs, proposals, print-outs, recordings, telegrams, films, and all other such documents tangible or retrievable of any kind Documents also include any preliminary notes and drafts of all of the foregoing, in whatever form, for example: printed, typed, longhand, shorthand, on paper, paper tape, tabulating cards, ribbon blueprints, magnetic tape, microfilm, film, motion picture film, phonograph records, e-mail, diskette, CD-Rom or other form. B. With respect to documents, the tern "identify" means to give the date, title, author and addressee; identify with respect to documents further means: (1) to describe a document sufficiently well to enable the Interrogator to know what such document is and to retrieve it ftom a file or wherever it may be located; (2) to describe it in a manner suitable for use as a description in a subpoena, (3) to give the name, address, position or title of the person(s) who has custody of the document and/or copies thereof. C. "Identify" when used in reference to an individual means: (1) to state his/her full name; (2) present residence address or last known residence; (3) present or last known business address; (4) present employer or last known employer; (5) whether ever employed by any party to this action and, if so, the dates he (she) was employed by such party, the name of such party, and the last position held as an employee of such party. D. Whenever the expression "and/or" is used in these Interrogatories, the information called for should be set out both in the conjunctive and disjunctive, and wherever the information is set out in the disjunctive, it should be given separately for each and every element sc-Sht. E Whenever a date, amount or other computation or figure is requested, the exact date, amount or other computation or figure is to be given unless it is not known, and then the approximate date, amount or other computation or figure should be given or the best estimate thereof; and the answer shall state that the date, amount or other w1uputatwn or tifutc a :m F No answer is to be Icf blank If the answer to an Interrogatorv or subparagraph of an Interrogatory is "none" or "unknown", such statement must be written in the answer, If the question is inapplicable. "N'A" must be written in the answer If an answer is omitted because of the claim of pnvilege. the basis of the privilege is to be stated G. "Defendant" refers to William Lcc Freeman and/or agents or representatives acting on Defendant's behalf H. 'Plaintiff' refers to Floorcoverings International, Inc and/or agents or representatives acting on Plaintiffs behalf INTFRROG 17ORiES IP1RSf S1:11 Please state the full name and address cif all individuals providing information for the responses to these Interrogatories. 2. Please state the following employment information. (a) names, addresses and telephone numbers of your employers or whether you are self- employed; (b) hours and rate of pay or earnings, specifying gross average weekly salary, wages, commissions, overtime pay, bonuses and gratuities; and (c) pensions, stock-purchase options, retirement plans, insurance, profit-sharing or other benefit plans; state basic provisions and attach copies of any such plans. 3. Itemize all income, benefits, cash and non-cash, not already included in your answers to any preceding interrogatory, such as, but not limited to pension plans, annuities, inheritances, retirement plans, Social Security benefits, Worker's Compensation benefits, lottery prizes, bank interest, dividends, etc. during the last three years. Provide. (a) source of the benefit, (b) amount and frequency of each, (c) the basic terms, and (d) attach copies of any plans. Identut am safe aenosn box schtch you imce aione or ?%ah another. Provide (a) the name and location of the institution where the box is rented, (b) the name or names in which it is registered. (c) the number. (d) the contents and the value thereof if anv, (e) the identity of anyone who has access, and (0 the number of times it was visited in the last three years. Identify all shares of stock, securities, bonds and other investments (excluding real estate) in which you own or have an interest, either individually or with another. Provide: (a) the description and identification of the stock, bonds, securities or investments; (b) identity of any co-owners or interest holders; (c) the present market value; (d) the present location; (e) the amount and frequency of dividends or income payable; (0 the maturity date of any bond; (g) whether any stock, security, bond and investment is subject to any lien or security interest; and (h) the identity of any custodian of any certificate or evidence of such investments. li during the last three years you have sold, uanslirted. or oihenvtse d spow'; of air, 1:011e or interests in the following categories, automobile, truck. camper or an,, ,,the: •%;'e Of vehicle. household items, furniture, jewelry. furs, antiques, artwork. baskets, collections or other items, bank or savings and loan accounts, time deposits, certificates of deposit. savings bonds, treasury notes, savings clubs, thrift plans, money markets and rhrckine accounts; or stocks, bonds or any other investment excluding real estate. Provide (a) the item or interest; (b) identity of the transferee and your relationship thereto, (c) date transferred; (d) the value at transfer; (e) the consideration received, if any, and (t) the disposition of the proceeds. Identify any and all liabilities or obligations of whatever nature including list of credit card accounts, that you may have, which have not been previously disclosed. Provide. (a) date acquired, (b) the identity of the creditor or obligee, (c) the outstanding balance, if any, (d) the account numbers, and (e) any and all judgments relating thereto, iJent iii ,dl c.XpC(tn the PLti fit iff p lan, to use at trio, pru?idige (a) Pull Name, (b) Address. (c) Qualifications, (d) Describe the experts' expected testimom 9. Identify any and all exhibits the Plaintiff intends to introduce at trial 10. List all life insurance policies in which you are the owner, insured or beneficiary. Provide. (a) identity of insurance company and policy number; (b) face amount; (c) identity of the owner, insured and beneficiary and any relationship to you, annual premiums and the payor; and (d) the present cash surrender value. 1 I list ;utN and all property or things of uuuc %? ill eit \uu iit)I'l :- 'i ,.. , P" ,1,; (a) the location and nature of the property. (b) the identity of any custodian thereof, (c) date you became trustee, (d) value and cost of the property at commencement of the trust (e) how property was acquired and who paid the consideration, (f) the present value; (g) identity of the beneficiary and your relationship thereto. (h) the settlor and your relationship thereto. (i) the basic terms of the trust; and 0) a copy of the trust instrument. 12. List any and all property or things of value which is held in trust for your benefit. Provide. (a) the location and nature of the property; (b) the identity of any custodian thereof; (c) date you became a beneficiary; (d) the identity of the settlor and your relationship thereto; (e) value and cost of the property at commencement of the trust; (0 how property was acquired and who paid the consideration; (g) the present value; (h) the frequency and amount of income, if any, (i) identity of any other beneficiary and your relationship thereto; Q) the basic terms of the trust; and (k) a copy of the trust instrument. I.; If anv accounts or other receivables are owing to cou. prop idc (a) nature of the receivable, (b) identity of the obligor. (c) amount owing, and (d) the terms of payment 14. State what counsel fees and costs you have paid or have agreed to pay for services rendered in this matrimonial action. Respectfully submitted, Peter I Russo Date: 0 11-1 1 ) ` I RUSSELL R GU I SHALL. III. IN i I IL (OLR'I' Ul COMMON PLLAS PlaintilT, CtA113ERI.AND COUNTY, PI?NNSYLVANIA V. No 99-5575 SANDRA M. GUTSHALL, CIVIL TERM Defendant IN DIVORCE CERTIFICATE OF,VFR VICE I, Peter Russo, hereby certify that I am on this day serving a copy of the foregoing document upon the person (s) and in the manner indicated below: Service by First-Class Mail, Postage Prepaid, and Addressed as follows: James, Smith, Durkin, & Connelly LLP Susan M. Kadel P. O. Box 650 Hershey, PA 17033 Peter J. Russo Date: 10 I-T a 6a i EXHIBIT "B" RUSSELL R. GUTSHALL, III, Plaintiff, V. SANDRA M. GUTSHALL, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA No. 99-5578 CIVIL TERM IN DIVORCE PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS ADDRESSED TO DEFENDANT (First Set) TO: SANDRA M. GUTSHALL c/o James, Smith, Durkin, & Connelly LLP Susan M. Kadel P. 0. Box 650 Hershey, PA 17033 The Plaintiff, Russell R. Gutshall, III, hereby serves upon the Defendant written request to produce documents to a party pursuant to Pa.R.C.P. 4009 to be answered by the Defendant in writing and under oath. These Requests shall be deemed continuing so as to require supplemental answers should Defendant obtain additional information which is responsive to these requests. The Defendant shall file and serve a copy of the Answers within thirty (30) days after the service of the Interrogatories to the Law Offices of Peter J. Russo, 5010 East Trindle Road, Mechanicsburg, PA 17050. DEFINITIONS AND INSTRUCTIONS Unless negated by the context of the Interrogatory, the following definitions are to be considered to be applicable to all Interrogatories contained herein' A. "Documents" is an all-inclusive term referring to any writing and/or recorded graphic matter, however produced or reproduced. The term documents includes, without limitation, correspondence, memoranda, interoffice communications, minutes, reports, notes, schedules, analyses, drawings, diagrams, tables, graphs, charts, maps, surveys, books of account, ledgers, invoices, purchase orders, pleadings, questionnaires, contracts, bills, checks, drafts, diaries, logs, proposals, print-outs, recordings, telegrams, films, and all other such documents tangible or retrievable of any kind Documents also include any preliminary notes and drafts of all of the foregoing, in whatever form, for example: printed, typed, longhand, shorthand, on paper, paper tape, tabulating cards, ribbon blueprints, magnetic tape, microfilm, film, motion picture film, phonograph records, e-mail, diskette, CD-Rom or other form. B. With respect to documents, the term "identify" means to give the date, title, author and addressee; identify with respect to documents further means: (1) to describe a document sufficiently well to enable the Interrogator to know what such document is and to retrieve it from a file or wherever it may be located; (2) to describe it in a manner suitable for use as a description in a subpoena; (3) to give the name, address, position or title of the person(s) who has custody of the document and/or copies thereof. C. "Identify" when used in reference to an individual means: (1) to state his/her full name; (2) present residence address or last known residence; (3) present or last known business address; (4) present employer or last known employer; (5) whether ever employed by any party to this action and, if so, the dates he (she) was employed by such party, the name of such party, and the last position held as an employee of such party. D. Whenever the expression "and/or" is used in these Interrogatories, the information called for should be set out both in the conjunctive and disjunctive, and wherever the information is set out in the disjunctive, it should be given separately for each and every element sought. E. Whenever a date, amount or other computation or figure is requested, the exact date, amount or other computation or figure is to be given unless it is not known; and then the approximate date, amount or other computation or figure should be given or the best esuntate thereof, and the answer shall state that the date, amount ui other computation or figure is an estimate or approximation No answer is to be left blank. If the answer to an Interrogatory or subparagraph of an Interrogatory is "none" or "unknown", such statement must be written in the answer If the question is inapplicable, "N/A" must be written in the answer If an answer is omitted because of the claim of privilege, the basis of the privilege is to be stated. G "Defendant" refers to William Lee Freeman and/or agents or representatives acting on Defendant's behalf. H. "Plaintiff' refers to Floorcoverings International, Inc. and/or agents or representatives acting on Plaintiffs behalf. DOCUMENT REOUESTs I All documents identified or requested to be identified in Plaintifrs Interrogatories to Defendant. 2. Defendant's Federal Income Tax returns for the past three (3) years. 3. All documents that Defendant may use at trial of this action, whether or not a determination has been made to use the document as an exhibit. 4. All items that Defendant may use at trial of this action, whether or not a determination has been made to use the item as an exhibit. Date: I o 1 t e? l Respectfully submitted, Peter J. Russo RUSSELL R GUTSHALL, 111, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA v No. 99-5578 SANDRA M. GUTSHALL, CIVIL TERM Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Peter Russo, hereby certify that 1 am on this day serving a copy of the foregoing document upon the person (s) and in the manner indicated below: Service by First-Class Mail, Postage Prepaid, and Addressed as follows: James, Smith, Durkin, & Connelly LLP Susan M. Kadel P. O. Box 650 Hershey, PA 17033 Peter J. Russo Date: 1 ki `11 `} ero 1 RUSSELL R. GUTSHALL, III IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW SANDRA M. GUTSHALL NO. 99-5578 CIVIL TERM Defendant IN DIVORCE CERTIFICATE OF SERVICE This to certify that copies of the forgoing Plaintiffs Proposed Order, First Motion to Compel Answers to Plaintiff's Interrogatories Addressed to Defendant and Plaintiff's Request for Production of Documents Addressed to Defendant, and Memorandum of Law in Support of Plaintiffs Motion have been served on the following person via United State First Class Mail, postage prepaid, addressed as follows: Susan M. Kadel, Esquire James, Smith, Durkin & Connelly, LLP P.O. Box 650 Hershey, PA 17033-0650 Respectfully submitted, Melissa M. Mehaffey, Iv IF Paralegal Date: Y nl ? y f7 c • - a.. ?7J l! ?'-'_ ' CJ _C .. 2-? t:! L i= L; Q 2 " o U RUSSELL R. GUTSHALL, III Plaintiff V. SANDRA M. GUTSHALL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-5578 CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE This to certify that copies of the forgoing Plaintiffs Proposed Order, First Motion to Compel Answers to Plaintiff s Interrogatories Addressed to Defendant and Plaintiffs Request for Production of Documents Addressed to Defendant, and Memorandum of Law in Support of Plaintiffs Motion have been served on the following person via United State First Class Mail, postage prepaid, addressed as follows: Susan M. Kadel, Esquire James, Smith, Durkin & Connelly, LLP P.O. Boa 650 Hershey, PA 17033-0650 Respectfully submitted, Melissa M. Mehaffey, Paralegal Date: P ,-D AND McII[ET NOTIfI[D TO READ M LAW OMCE - I ,y ENaoefo WrtNI"' JAMES SM??rfH DURm & , Wf Ne[fEYC[ATIIr TNATTH;V:"' IN If, NTT LHER O DATE W EEimC[Nfllwr0 , , CONNELLY LLP A TRUE ANO CCHRZCT. Cow w 711[', F'%ULTlUDOMfNT MAY [[ ENTERED ORIGINAL flRD IN If ACTION, I ' INR. YOU, P. Q'n?( 6V -_^ 7" :p w 'ArtoAlaT HERSHEY, PENNWLvANm rmm w "^0"?`'• RUSSELL R. GUTSHALL,111, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. No. 99-5578 SANDRA M. GUTSHALL, CIVIL TERM Defendant, IN DIVORCE PRAECIPE TO WITHDRAW APPEARANCE TO THE PROTHONOTARY: Please withdraw my appearance as counsel for the Defendant, Sandra M. Gutshall, in the above-captioned action. JAMES, SMITH, DURKIN & CONNELLY Date Sat-IaeUL. Andes, Eldquire 525 North Twelfth Street Lemoyne, PA 17043 (717) 761-5361 Attorney I.D. No. /1155- PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Susan M. Kadel, Esquire, on behalf of the Defendant, Sandra M. Gutshall in the above-captioned action. Date: ?/ ' &I ?, U?? By: Kadel, Esquire 134 Sipe Avenue Hummelstown, PA 17036 (717) 533-3280 Attorney I.D. No. 44837 1 J C7 U ei RUSSELL R. GUTSHALL, III Plaintiff V. SANDRA M. GUTSHALL Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CIVIL ACTION NO.: 99-5578 IN DIVORCE WITHDRAWAL OF APPEARANCE AND ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly WITHDRAW the appearance of Kathleen Carey Daley on behalf of Plaintiff, Russell R. Gutshall, III and ENTER the appearance of Peter J. Russo, Esquire on behalf of Plaintiff, Russell R. Gutshall, III in the above-captioned matter. Dated G 130 jre, Dated &/a11/00 Res tfully su iffe Peter J. Russo, Esquire 61 West Louther Street Carlisle, PA 17013 Ktleen Carey Daley, 1 9 Scenery Drive Harrisburg, PA 17109 RUSSELL R. GUTSHALL, III Plaintiff V. SANDRA M. GUTSHALL Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CIVIL ACTION NO.: 99-5578 IN DIVORCE CERTIFICATE OF SERVICE NOW COMES, Peter J. Russo, Attorney for Plaintiff, and certifies that on this day he did serve the foregoing document via First Class Mail to: Samuel L. Andes, Esquire 525 North 12th Street Lemoyne, Pennsylvania, 17043 Peter J. Russo Date: :931 vo G =c te -?? a . - r n c ur ? IW c'_ O 6 c? U tl?f RUSSELL R ,tJT HALL III : IN THE COURT OF COMMON PLEAS OF `? Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. SANDRA M. iUT HALL Defendant : NO. 5578 1999 MOTION FOR APPOINTMENT OF MASTER Russell R. Gutshall III (Plaintiff) (Defence), moves the court to appoint a master with respect to the following claims: (X) Divorce ( X ) Distribution of Property ( ) Annulment ( ) Support (X) Alimony (X) Counsel Fees ( ) Alimony Pendete Lite ( X ) Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claim(s) for which the appointment of a master is requested. (2) The Defendant (has) (I?ae neF) appeared in the action (peessna4) (by her attorney, Susan Kadel _, Esquire). (3) The statutory ground(s) for divorce (is) (are) 3301 Q (4) Delete the inapplicable paragraph(s): (a) sleiots: (b) An agFeement has been reaehed with respeet--?? (c) The action is contested with respect to the following claims: All (5) The action (itwelves) (does not involve) complex issues of law or fact. (6) The hearing is expected to take 4 (hours) (gays). (7) Additional information, if any, relevant to the motion: Date jrMbl Attorney for ORDER APPOINTING MASTER AND NOW , 2C Lo i , E" , Esquire, is appointed master ih' sped to the following claims: e c!\ U 3"\ BY THE T (p J. <. RUSSELL IL GUTSHALL, Ill, IN THE COURT OF COMMON PLEAS OF Plaintiff/Rcspondent CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 99 - 5578 CIVIL TERM SANDRA M. GUTSHALL, IN DIVORCE Defendant/Respondent DR# 29,096 Pacses# 582101624 ORDER OF COURT AND NOW, this 8" day of November, 1999, upon consideration of the attached Petition for Alimony Pendante Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shad dav on December 2, 1999 at 9:00 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.110 (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, George E. Hoffer, President Judge Mail copies on Petitioner 11-8-99 to: < Respondent Samuel Andes, Esquire Kathleen Daley, Esquire Dale of Order: November 8. 1999 R. J. radday. Conference Officer YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (7(7) 249-3166 Vin, ?0`,?::? ("???ZPAY ?, ,• o;'f, _? ' ??,. .?;( }.,, RUSSELL R. GUTSHALL, III, Plaintiff VS. SANDRA M. GUTSHALL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-5578 CIVIL TERM IN DIVORCE MOTION FOR A HEARING AND NOW comes the above-named Defendant, Sandra M. Gutshall, by her attorney, Samuel L. Andes, and moves the Court to schedule a conference at the Domestic Relations Office, and a hearing before the Court if necessary, to hear Defendant's claim for Alimony Pendente Lite in this matter. Samue . des Attorney for Defendant Supreme Court ID # 17225 525 North 12°i Street Lemoyne, Pa 17043 (717) 761-5361 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Russell R. Gutshall, III Plaintiff NO. 99-5578 CIVIL TERM V. CIVIL ACTION - LAW SANDRA M. GUTSHAL IN DIVORCE Defendant DRS ATTACHMENT FOR APL PROCEEDINGS PETITIONER NAME Sandra M. Gutshall ADDRESS 100 Cranes Ga , Carlisle, PA 17013 BIRTH DATE 6 29 48 SOCIAL SECURITY NUMBER 167-40-0748 HOME PHONE 717) 293-9349 WORK PHONE (717) 245-1234 EMPLOYER NAME Dickinson Coll e EMPLOYER ADDRESS High and West College Street, Carlisle PA JOB TITLE/POSITION , Clerk DATE EMPLOYMENT COMMENCED GROSS PAY $280.00 per week NET PAY $210.00 week OTHER INCOME 61.00 month disahil' i-y ATTORNEY'S NAME L- Andn, ATTORNEY'S ADDRESS 525 N. 12th street, Lenoyne, PA 17093 ATTORNEY'S PHONE NUMBER ,.y,,, .,11 ...,. RESPONDENT NAME Russell R. Gutshall, III ADDRESS 26 Stewart Drive, Carlisle, PA 17013 BIRTH DATE 3 Februa 1948 SOCIAL SECURITY NUMBER -193-36-3669 HOME PHONE 243-9349 WORK PHONE 717 240-6502 EMPLOYER NAME Sprint EMPLOYER ADDRESS 1201 Walnut Bottan Road, Carlisle, PA JOB TITLE/POSITION Managgr DATE EMPLOYMENT COMMENCED 1968 ± GROSS PAY $81,000.00 or more NET PAY Unknown OTHER INCOME Unknown ATTORNEY'S NAME Kathleen Care Dale ATTORNEY'S ADDRESS 1029 Scenery Drive, Harrisburg, PA 17109 ATTORNEY'S PHONE NUMBER (717) 657-4795 MARRIAGE INFORMATION DATE OF MARRIAGE 24 May 1969 PLACE OF MARRIAGE Boiling Springs, PA DATE OF SEPARATION ADDRESS OF LAST MARITAL HOME 26 Stewart Drive, Carlisle, PA DESCRIPTION OF DOCUMENT RAISING APL CLAIM Petition for Econanic Relief DATE APL DOCUMENT FILED RUSSELL R. GUTSHALL, III, ) Plaintiff ) VS. ) SANDRA M. GUTSHALL, ) Defendant ) NOTICE TO PLAINTIFF NAMED HEREIN: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-5578 CIVIL TERM IN DIVORCE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN TILE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITI-I THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO, THE CASE MAY PROCEED WITHOUT YOU, AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGI ITS IMPORTANT TO YOU. 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 13AR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 RUSSELL R. GUTSFIALL, III, Plaintiff VS. SANDRA M. GUTSHALL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-5578 CIVIL TERM IN DIVORCE PETITION FOR ECONOMIC RELIEF AND NOW comes the above-named Defendant, Sandra M. Gutshall, by her attorney, Samuel L. Andes, and files the following petition for economic relief in the above matter, based upon the following: 1. The Petitioner herein is the Defendant, Sandra M. Gutshall. 2. The Respondent herein is the Plaintiff, Russell R. Gutshall, III. 3. Plaintiff commenced this action by filing a Complaint in which he raised a claim for equitable distribution but no other economic claims. COUNT I - ALIMONY 2. Defendant lacks sufficient property to provide for her reasonable needs in accordance with the standard of living of t he parties established during the marriage. 3. Defendant is unable to support herself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 4. The Plaintiff is employed and enjoys a substantial income from which he is able to contribute to the support and maintenance of Defendant and to pay her alimony in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Defendant prays this Honorable Court to enter an Order awarding Defendant from Plaintiff permanent alimony in such sums as are reasonable and adequate to support and maintain Defendant in the station of life to which she has become accustomed during the marriage. COURT II - ALIMONY PENDENTE LITE 5. Defendant is without sufficient income to support and maintain herself during the pendency of this action. 6. Plaintiff enjoys a substantial income and is well able to contribute to the support and maintenance of Defendant during the course of this action. WHEREFORE, Defendant prays this Honorable Court to order Plaintiff to pay her reasonable alimony pendente lite during the pendency of this action. COUNT III - COUNSEL FEES AND EXPENSES 7. Defendant is without sufficient funds to retain counsel to represent her in this matter. 8. Without competent. counsel, Defendant cannot adequately prosecute her claims against Plaintiff and cannot adequately litigate her rights in this matter. 9. Plaintiff enjoys a substantial income and is well able to bear the expense of Defendant's attorney and the expenses of this litigation. WHEREFORE, Defendant prays this Honorable Court to order Plaintiff to pay the legal fees and expenses incurred by Defendant in the litigation of this action. I verify that the statements in this Petition are true and correct. I understand that any false statement in this Petition are subject to the penalties of 18 PA. C.S. 4901 (unsworn falsification to authorities). Sandra M. Gutshal Samuel L. Andes Attorney for Defendant Supreme Court 1D # 17225 525 N. 12"' Street Lemoyne, PA 17043 (717) 761-5361 r CdC r'" N u, r l co k - ya 1.? ` a ?i1fL n a N f 0 w A a ? ti a " z .a y. w o m a??x W a x ° W O ? i a ti < o C1 Q H W J In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION SANDRA M. GUTSHALL ) Docket Number 99-5578 CIVIL Plaintiff ) Vs. ) PACSES Case Number 582101624/D290% RUSSELL R. GUTSHALL III ) Defendant ) Other State ID Number Order AND NOW to wit, this AUGUST 28, 2001 it is hereby Ordered that: DEFENDANT PAY PLAINTIFF, $348.58, DIRECTLY, FOR UNREIMBURSED MEDICAL EXPENSES FOR THE YEARS 1999 THROUGH THE PRESENT. THIS AMOUNT REPRESENTS THE FOLLOWING: 1999-- -0-. 1000-- $309.60 2001•- $38.98 THE SAID TOTAL OWED IS TO BE PAID IN FULL WITHIN 30 DAYS OF THIS DATE. THE CHIROPRACTIC EXPENSES AND THE DIVORCE GROUP THERAPY THROUGH THE YWCA ARE NOT CONSIDERED. DRO: R.T Shadday xc: Plaintiff defendant Susan &idel, Esquire Peter Russo, Esquire Service Type M BY THE COURT: Edward E. Guido JUDGE Form OE-001 Worker ID 21005 1AWN SMm I DURKIN & CONNELLY LLI' Susan M. I l smk@jsdlegal.com March 14, 2002 E. Robert Elicker, II Divorce Master 9 North Hanover Street Carlisle, PA 17013 Re: Russell R. Gutshall, III v. Sandra M. Gutshall No. 99-5578 Dear Mr. Elicker: Pursuant to your directive of February 19, 2002, I am hereby enclosing the original Pre-trial Statement for the Defendant, Sandra M. Gutshall, in the above- captioned matter. By copy of this letter I am providing the same to Plaintiffs counsel. Sincer usan M. Kadel SMK:has Enclosure cc: Peter J. Russo, Esquire Sandra M. Gutshall 'LL' V L':I t A /I I, PA IPIIV LS nn 14iCOIl id,l iQkl GARY L. JAMES MAX J. SMITH, JR. KAREN DURKIN JOHN J. CONNELLY, JR, STEVEN A. STINE SCOTT A. DIETTERICK GREGORY K. RICHARDS RICHARD L. DAHLEN SUSAN M. KADEL JARAD W. HANOELMAN DONNA M. MULLIN EDWARD P. SESSER NEIL W. YAHN BERNARD A. RYAN, JR. OF COUNSEL: ANDREW M. BARBIN IAMES SMm-I DURKIN & CONNELLY LLP Susan M. Kadd smk(7wjsd1cga1.conn August 15, 2001 E. Robert Eiicker, II Divorce Master 9 North Hanover Street Carlisle, PA 17013 Re: Russell R. Gutshall, III v. Sandra M. Gutshall No. 99-5578 Dear Mr. Elicker: Please find enclosed the original of Defendant's Certification. You will note that Defendant has certified that discovery is not complete in this case. By copy of this letter, I am serving the same upon counsel for the Plaintiff. Si Susan M. Kadel SMK:has A?n ru ?r' ..1'L9 . ?.. grtL PA UAI ;lot 4-1 GARY L. JAMES MAX J. SMITH JR. KAREN DURKIN JOHN J. CONNELLY, JR. STUART M. MAGDULE STEVEN A. STINE JOHN J. MCNALLY, III SCOTT A. DIMERICK GREGORY K. RICHAROs RICHARD L. DAHLEN SUSAN M. KADEL JARAD W, HANDELMAN DONNA M. MULLIN EDWARD P. SEEDER cc: Peter J. Russo, Esquire Sandra M. Gutshall k6tef Y. Russia ATTORNEY AT LAW Suite 200 • S010 East Trindle Road Mechanicsburg, PA 17050 QOrres in Cart6b, PA Tuesday, April 2, 2002 E. Robert Elicker, II Divorce Master 9 N. Hanover Street Carlisle, PA 17013 RE: GUTSHALL v. GUTSHALL Dear Mr. Elicker: PHONE: (717) 591.1755 FAX: (717) 591-1756 I write concerning the pre-hearing conference scheduled for April 22, 2002. Mr. Russo requests that the parties personally appear. Our hopes are to resolve the outstanding issues, and this may be more likely if the clients are directly involved. I will await a notice from your office. Very truly yours, x" tK MAUL Melissa M. Mehaffey Paralegal cc: Susan M. Kadel, Esquir: Russell R. Gutshall, III Please Reply To: MECHANICSBURG OFFICE MMwMwrwwwPVra.sr:?H^.. VNw M1A'.C.'M1 .t Mn•.. n, n„..y;?Y.? •............ ., v ...:. .. n(..... rvrrvT+?inr+waam LAW OFFICE ME YOU ARE N[R[RY NOTIFIED TO PLEAD TNEN[(O[CD WITHIN Is A DAYS OF IN p T'1.........,? y? WE HEREBY CERTIFY RECT OFF THE TN[ ORIGINAL ECT COPY IN H201 SERVICE HEREOF JA?V1F$SbffIF'I LApL L[:LVCK pL CQNNELLY [,LP TREE AND COR TWENTY A DRFAULT NAL . A DWEL YOU. JUDGMENT MAY BE ENTERED R[D FILED IN N THIS ACTION. TNISAalxst ou. P.O. Box Aill RT er ATTORNEY HERSHEY, PENNSYLVANIA 17010M Anollur SEP 17 2(h' I I. 1 i RUSSELL R. GUTSHALL, III, Plaintiff V. SANDRA M. GUTSHALL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99-5578 CIVIL ACTION - LAN! IN DIVORCE SPRINT RETIREMENT PENSION PLAN QUALIFIED DOMESTIC RELATIONS ORDER WHEREAS, Russell R. Gutshall, III (the "Participant"), and Sandra M. Gutshall (the "Alternate Payee") entered into a Property Settlement Agreement dated August 20, 2003 (the "Agreement"), in which they agreed to the division of marital property; and WHEREAS, the Agreement requires the entry of this domestic relations order (the "Order") to provide for the division and disposition of pension benefits accrued by the Participant; and WHEREAS, this Order is intended to be a qualified domestic relations order, as defined in Section 414(p) of the Internal Revenue Code of 1986, as amended (the "Code") and Section 206 (d) (3) of the Employee Retirement Income Security Act of 1974, as amended ("ERISA" ). NOW THEREFORE, It is hereby ordered as follows: 1. The Plan. This Order applies to benefits under the Sprint Retirement Pension Plan (the "Plan"). The Plan is an employee pension benefit plan qualified under Section 401(a) of the Code and subject to ERISA. 2. Identity of Participant. The Participant is Russell R. Gutshall, III, Post Office Box 885, Carlisle, Pennsylvania, 17013-1764, Social Security #193-36-3669. The Participant's date of birth is February 3, 1948. 3. Identity of Alternate Payee. The Alternate Payee is Sandra M. Gutshall, 26 Stewart Drive, Carlisle, Pennsylvania, 17013, Social Security #167-40-0748. The Alternate Payee's date of birth is June 29, 1948. 4. Amount to be Paid Alternate Payee. There is hereby assigned to the Alternate Payee and, as otherwise provided in the Order, the Plan shall pay to the Alternate Payee 50% percent of the value of the Participant's accrued benefit in the Plan, determined as of September 13, 1999. The dollar amount of the benefit payable to the Alternate Payee under the Order shall be adjusted for the Plan's actuarial assumptions based on, among other things, the time of payment elected by the Alternate Payee under Paragraph 5 below and the form of payment elected by the Alternate Payee under Paragraph 6 below. 5. Time of Payment. The Alternate Payee shall be entitled to commence distribution of the amount determined in this Order on or after the earliest retirement age (as defined in section 414(p)(4)(B) of the Code). 6. Manner of Payment. The Alternate Payee may elect to receive a distribution of benefits under this Order in any form of payment available to the Participant under the Plan; however, the Alternate Payee may not elect distribution in the form of a Qualified Joint and Survivor Annuity (as defined in section 417(b) of the Code) payable to the Alternate Payee and the Alternate Payee's spouse. Such election will be made at the time and in the manner prescribed for under the Plan. 7. Death of Alternate Payee. If the Alternate Payee dies after distribution of benefits has commenced under this Order, the form of payment elected by the Alternate Payee under Paragraph 6 above shall determine whether any amounts are owed to any beneficiary upon the Alternate Payee's death. If the Alternate Payee elects a form of payment under which benefits may be payable to a contingent annuitant or beneficiary following the Alternate Payee's death, the Alternate Payee will be permitted to designate a beneficiary without regard to any designation made by the Participant of a beneficiary with respect to the Participant's interest under the °lan. If the Alternate Payee dies before distribution of benefits has commenced under this Order, the Alternate Payee's interest under this Order will be forfeited. In other words, no survivor benefits will be payable upon the death of the Alternate Payee. 6. Death of Participant. To the extent applicable, the Alternate Payee shall be treated as the surviving spouse of the Participant under Section 414(p)(5) of the Code and Section 206(d)(3)(F) of ERISA with respect to the portion of the Participant's accrued benefit under the Plan which is assigned to the Alternate Payee pursuant to Paragraph 4 above. Therefore, if the Participant dies before the Alternate Payee has commenced distribution of benefits under this Order, the Alternate Payee will be entitled to the spousal allowance as provided under the Plan which is attributable to the portion of the Participant's accrued benefit assigned to the Alternate Payee under Paragraph 4 above. That spousal allowance is in the form of an immediate annuity for the life of the Alternate Payee. If the Participant dies after the Alternate Payee has commenced distribution of benefits under this Order, the Alternate Payee will be entitled to payment of benefits in the form elected by the Alternate Payee under Paragraph 6 above and the Participant's death will not effect such benefits. The Alternate Payee will not be entitled to the spousal allowance referred to in the previous paragraph. The Alternate Payee will not be entitled to any survivor benefits attributable to the Participant's benefits under the Plan (i.e., the portion of the Participant's accrued benefit which is not assigned under Paragraph 4 above) unless the Participant designates the Alternate Payee as a beneficiary in accordance with the terms of the Plan. 9. Administration of the Order. A true copy of this Order shall be served on the Plan Administrator. The Plan Administrator shall determine, within a reasonable period of time after delivery of this Order, whether the Order is a qualified domestic relations order within the meaning of Section 414(p) of the Code and Section 206 (d) of ERISA (QDRO). The Participant, the Alternate Payee, and the court intend this Order to be a QDRO. The parties agree that their mutual intent is to provide the Alternate Payee with a benefit under the Plan that fairly represents the Alternate Payee's marital share of the benefits as described under Paragraph 4. If this Order is determined not to be a QDRO, the Plan Administrator shall inform the parties of the reasons for that determination. The Court retains jurisdiction to amend the Order for purposes of establishing its status as a QDRO and the parties hereby agree to submit to and request the Court to modify the Order to make it a QDRO in such a manner that will reflect the parties' intent. 10. Rights of the Parties. The assignment under this Order shall be permanent. From the date of this Order (assuming it is determined to be a QDRO) and thereafter, the Participant shall have no further right or interest in the portion of the Participant's accrued benefit under the Plan which is assigned to the Alternate Payee pursuant to Paragraph 4 above, and the Alternate Payee shall have no further right or interest in the portior of the Participant's accrued benefit under the Plan which is not assigned pursuant to Paragraph 4 above. Nothing in this Order shall restrict the Participant's ability to obtain a distribution under the Plan or designate a beneficiary under the Plan, with respect to the Participant's remaining accrued benefit determined after the assignment to the Alternate Payee. 11. Information Furnished to the Alternate Payee. The Plan Administrator shall treat the Alternate Payee as a distributee of the Plan for purposes of all notices and election opportunities provided by the Plan to its participants. The Plan Administrator shall provide the Alternate Payee with annual reports and such other information as is fumished to participants in the Plan. The Alternate Payee should advise the Plan Administrator in writing of any change of name or address or any material fact which may affect the Alternate Payee's entitlement to benefits assigned under this Order. 12. Miscellaneous Provisions. This Order does not require the Plan to provide any type or form of benefit, or any benefit option, not otherwise provided under the Plan. This Order does not require the Plan to provide increased benefits (determined on the basis of actuarial value). This Order does not require the Plan to provide benefits to the Alternate Payee which are required to be paid to another alternate payee under another order previously determined to be a QDRO. O ED at Cumbe[land County, 201 Participant: Russell R. tshall, III Date: Attorney for Participant Lie- Peter J. Russo, Esquire R? o9-ig 03 Pennsylva ' is day of r6r.N1A6°" do , JUDGE Alternate Payee: Sandra M. Gutski-I Date: 09-. /a- ed Attorney for Alternate Payee: usan M. Kadel, Esquire 1? .. -'V f`h ? ?,? / l ? ? ;' ? .) ?.'? ,. „?, ?,., i RUSSELL R. GUTSHALL, III, : THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. SANDRA M. GUTSHALL, Defendant NO. 99 - 5576 CIVIL . IN DIVORCE ORDER OF COURT AND NOW, this day of o z , 2003, the economic claims raised in the proceedings having been resolved in accordance with a property settlement agreement dated August 20, 2003, 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, cc: Peter J. Russo Attorney for Plaintiff Susan M. Kadel Attorney for Defendant Ge g o Ae, P I RUSSELL R. GUTSHALL, III IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW SANDRA M. GUTSHALL NO. 99-5578 CIVIL TERM Defendant IN DIVORCE PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT is hereby made and entered into this "!p O /- day of 2003, by and between SANDRA M. GUTSHALL, "Wife," and RUSSELL . GUTSHALL, III, hereinafter "Husband." Witnesseth: Whereas, marital differences and difficulties have arisen between the Parties, and Whereas, Parties have separated physically and intended to continue to live apart and desire to forever completely settle, determine and provide for the support of Wife, separation of their marital and nonmarital, real and personal, belonging to either and/or both of the parties hereto and all other rights, entitlements, benefits, and privileges involved between the parties hereto arising directly or indirectly out of the marriage relationship, and Whereas, Parties have had adequate time and opportunity to consult with separate legal counsel of their own, and Whereas, both Parties acknowledge that they are satisfied with the legal advice they have received and understand the full importance of the Agreement they are entering into; Now, Therefore, the parties, in consideration of the foregoing premises, and the mutual promises and undertakings hereinafter set forth, agree as follows: 1. RIGHT TO LIVE SEPARATE It shall be lawful for Husband and Wife at all times hereinafter to live separate and apart from each other and to reside from time to time at such place or places as he and she shall respectively deem fit, free from any control, restraint or interference, direct or indirect, by each other. The foregoing provisions shall not be taken to be any admission on the part of either Husband or Wife of the lawfulness or unlawfulness of the causes leading to their living apart. 2. FREEDOM FROM INTERFERENCE Each party shall be free from interference, authority and contact by the other as if he or she were single and unmarried except as necessary to carry out provisions of this Agreement. Neither party shall harass the other or attempt to endeavor to harass the other, nor compel the other to cohabit with the other, or in any way malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 3. DISTRIBUTION OF VEHICLES Wife shall assume all payments, including all loan, insurance and repair bills connected with any and all vehicles presently in her possession including, 'out not limited to, her 1987 Aero Star Van. Husband shall assume all payments, including all loan, insurance and repair bills connected with any vehicles presently in his possession including, but not limited to, his 1988 Ford Ranger Pickup. Pursuant to Paragraph 3, Wife shall execute the motor vehicle title to the 1988 Ford Ranger Pickup in favor of Husband and Husband shall execute the motor vehicle title to the 1987 Aero Star Van in favor of Wife. The parties shall complete this process on or before July 15, 2003. 4. DISTRIBUTION OF POSSESSIONS As of the date of the execution of this Agreement, the parties shall transfer and assign their rights, title, claim and interest in specific property. Wife shall have as her own, free and clear of any claims of Husband, all of the items, household goods, furniture, furnishings, appurtenances, and appliances which are in her possession. Husband shall have as his own, free and clear of any claims of Wife, all of the items, household goods, furniture, furnishings, appurtenances, and appliances which are in his possession. 5. DISTRIBUTION OF PERSONAL PROPERTY With the exception of those items set forth in Exhibit A, it is further agreed that both Husband and Wife shall retain as his or her own any and all personal effects, clothing, and personal jewelry currently in their possession. The parties further agree that any property not assigned in this Agreement, as marital or nonmarital property will be deemed the property of the physical possessor of said property. EXCHANGE OF THESE PERSONAL ITEMS SHALL TAKE PLACE NO LATER THAN AUGUST 31, 2003. A mutually convenient date and time shall be established by the parties and Husband shall remove all of the items set forth in this agreement by the end of the time period established by the parties. At the conclusion of that scheduled time period, Husband shall not be permitted to re-enter the marital residence to remove any item without the express permission of Wife. 6. RETIREMENT ACCOUNTS The parties shall keep all IRA's, 401k's and other retirement accounts which are held in their names as personal property, free and clear of claims from the other party with the exception of the Husband's Sprint Pension Plan. Husband's Sprint Pension Plan shall be divided pursuant to a Qualified Domestic Relations Order which shall award Wife fifty percent (50%) of Husband's pension benefit effective September 13, 1999. Wife shall take all steps necessary to cause said Qualified Domestic Relations Order to be drafted, entered as an Order of Court and delivered to Husband's pension administrator within forty five (45) days of the execution of this Agreement. 7. JOINT ACCOUNTS The parties shall stop using all joint bank and charge accounts, credit card accounts and any other joint accounts shall be terminated and each party shall take those steps necessary to have the other removed as a responsible party from such accounts. The parties further specifically agree that all bank, savings, cash and checking accounts shall become the sole property of party named on the account. 8. MARITAL LIABILITIES Unless otherwise set forth herein, Wife assumes full responsibility for any indebtedness which she has contracted or incurred in her name, alone or jointly, after the date of separation. Unless otherwise set forth herein, Wife represents and warrants to Husband that, since the filing of the divorce action, she has not contracted or incurred any debt. or liability, for which Husband or his Estate might be responsible, and shall indemnify and save Husband harmless from any and all claims or demands made against him or his Estate by reason of debts or obligations incurred by Wife and/or assumed herein. Unless otherwise set forth herein, Husband assumes full responsibility for any indebtedness which he has contracted or incurred in his name, alone or jointly, after the date of separation of this Agreement. Unless otherwise set forth herein, Husband represents and warrants to Wife that, since the filing of the divorce action, he has not contracted or incurred any debt or liability, for which Wife or her Estate might be responsible, and shall indemnity and save Wife harmless from any and all claims or demands made against her or her Estate by reason of debts or obligations incurred by Husband and/or assumed herein. 9. OTHER MARITAL ASSETS During the course of this marriage, the parties purchased a marital residence located at 26 Stewart Drive, Carlisle, PA 17013. The parties have agreed that Wife shall assume sole ownership of said marital residence. Wife shall refinance the mortgage on the marital residence within ninety (90) days of the execution of this Agreement. Wife shall hold Husband harmless from any obligation associated with the marital residence. Husband shall execute a decd in favor of Wife contemporaneously with the execution of the mortgage that releases the CUNA mortgage. At the time of Wife's refinance of the marital residence, Husband shall be made a payee on the HUD-1 Settlement Sheet in the amount of Seven Hundred Dollar ($700.00). Once Wife refinances the CUNA mortgage or once alimony commences, whichever is sooner, Wife shall be solely responsible for all maintenance, expenses, taxes, utilities, payments, etc, related to 26 Stewart Drive, Carlisle, PA. Husband has maintained a real estate tax escrow fund. This real estate tax escrow fund has been used to pay all real estate taxes. At times, this real estate tax escrow fund has been over-funded to insure funds would be available in the event of a tax increase. Upon the refinance of the marital residence, Wife shall be entitled to retain the funds in the real estate tax escrow account which are equal to the per diem real estate taxes on the property beginning in the current tax year through the date of settlement. Any funds which exceed that amount shall be returned to Husband. In the event Wife is unable to refinance the existing CUNA mortgage and a default of said mortgage occurs, Wife shall inform Husband of the default within 5 days of each notice received by CUNA. Husband shall have the right to cure any default and recoup any funds advanced to avoid a default when the subject property is sold or refinanced. During the course of this marriage, the parties purchased approximately 5.8 acres of vacant mountain land in Port Royal, PA. The aforementioned mountain land was sold via private sale. Peter J. Russo, Esquire, is escrowing the proceeds of the sale of the mountain land. Upon Wife's execution of this agreement, Peter J. Russo, Esquire shall release the proceeds of the mountain land sale to Husband. Wife is currently in possession of the parties' children's birth records. Notwithstanding the fact that Wife is in possession of those birth records, both parties retain their respective rights to pursue or defend litigation relating to said birth records. 10. TAX LIABILITY The parties hereto believe and agree that the division of property heretofore made by this Agreement is a non-taxable division of property between co-owners rather than a taxable sale or exchange of property. Each party promises not to take any position with respect to the adjusted basis of the property assigned to him or her with respect to any other issue which is inconsistent with the position set forth in the preceding sentence on his or her Federal or State income tax return 11. MUTUAL RELEASE Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all caused of action, claims, rights or demands whatsoever in law or equity, which either of the parties ever had or now has against the other, except any or all causes of action for divorce and except any or all caused of action for any breach of any provision of this Agreement. Each party also waives his or her right to request marital counseling pursuant to Pennsylvania's Divorce Code. 12. ALIMONY Husband shall pay Wife One Thousand Four Hundred Dollars ($1,400.00) per month as alimony until Husband retires from Sprint or reaches age 65, whichever occurs later. Both parties acknowledge and agree that the provisions of this Agreement providing for alimony are fair, adequate and satisfactory based on actual need, ability to pay, duration of the marriage and other relevant factors taken into consideration by the parties, Although the approval of this Agreement by a court of competent jurisdiction in connection with this action in divorce filed by Husband or Wife shall be deemed an order of the court and may be enfore-1 dus Agreement, insofar as it pertains only to spousal support and the payment of alimony following the entry of a final Decree in Divorce between the parties, may be modified, suspended, terminated or reinstated at the instance of request of either party, or subject to further order of any court upon changed circumstances as contemplated by the Divorce Code. Alimony shall be made payable through Cumberland County Domestic Relations. Alimony shall commence and spousal support shall terminate within on August 1, 2003 or the date of Wife's refinance settlement, whichever is sooner. Husband shall secure a term life insurance policy which shall indemnify Wife for an amount equal to the total alimony payments until Ilusband reaches age 65, Husband shall have the right to decrease the amount of benefit by $16,800.00 each year. If Husband reaches age 66 and is still employed at Sprint, he shall maintain a benefit for Wife equal to one year's alimony or $16,800.00. This insurance benefit of $16,800.00 shall renew each year Husband continues to be employed at Sprint after age 66. 13. ALIMONY PENDENTE LITE COUNSEL FEES AND EXPENSES Both parties hereby acknowledge and accept that the provisions of this Agreement providing for the equitable distribution of marital property are fair, adequate and satisfactory to them. Both parties agree to accept the provisions of this Agreement in lieu of and in full and final settlement and satisfaction of all claims and demands that either may now or hereafter have against the other. 14. INCOME TAX RETURNS Husband and Wife agree to individual tax returns for 2003 and thereafter until their divorce is final. Each party shall be solely responsible for any and all Federal, State and Local tax liability beginning in 2003 and thereafter. Each party shall have the exclusive right to any and all refunds based on their Federal, State and Local tax returns beginning in 2003 and thereafter. 15. WAIVER OF CLAIMS AGAINST ESTATES Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby 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, dower, curtsey, statutory allowance, widow's allowance, right to take intestacy, right to take against the will of the other, and right to act as administrator or executor of the other's estate. Each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims and both parties will revoke prior wills or testamentary documents. 16. AGREEMENT NOT PREDICATED ON DIVORCE It is specifically understood and agreed by and between the parties hereto and each of the said parties does hereby warrant and represent to the other, that the execution and delivery of this Agreement is not predicated upon nor made subject to any agreement for institution, prosecution, defense, or for the non-prosecution or non-defense of any action for divorce; provided, however, that nothing contained in this Agreement shall prevent or preclude either of the parties hereto from commencing, instituting or prosecuting any action or actions for divorce, either absolute or otherwise, upon just, legal and proper grounds; nor to prevent either party from defending any such action which has been, may or shall be instituted by the other party, or from making any just or proper defense thereto. 17. SUBSEQUENT DIVORCE A divorce proceeding was filed by Husband against Wife in Cumberland County and docketed at 99-5578. The parties hereby mutually consent to a divorce and the entering of a divorce decree on the no-fault grounds that their marriage is irretrievably broken pursuant to §3301(c) of the Pennsylvania Divorce Code. Parties herein shall execute Affidavits of Consent and a final decree in divorce will then be obtained. 18. BREACH AND ENFORCEMENT If either party hereto breaches any of the provisions of this Agreement, the other party shall have the right to bring any actions or actions in law or equity for such breach, and the breaching party shall be responsible for the payment of all costs and reasonable legal fees incurred by the other party in enforcing his or her rights under this Agreement. It is expressly understood and agreed by and between the parties hereto that this Agreement may be specifically enforced by either party in Equity, and the parties hereto agree that if an action to enforce this Agreement is brought in Equity by either party, the other party will make no objection on the alleged ground of lack of jurisdiction of said Court on the ground that there is an adequate remedy at law. The parties do not intend or purport hereby to improperly confer jurisdiction on a Court in Equity by this Agreement, but they agree as provided herein for the forum of equity in mutual recognition of the present state of the law, and in recognition of the general jurisdiction of Courts in Equity over agreements such as this one. 19. RE-ACKNOWLEDGMENT Each party acknowledges that it may be appropriate and required that this Agreement be re-acknowledged at some time in the future before the Clerk of the Commonwealth Court. Clerk of Orphans Court or some other Court, and each party agrees that they will re-acknowledge their signature before the Clerk of such Court upon request of the other party so that this Agreement may comply with the acknowledgment rules and provisions of any such Court. 20. ADDITIONAL INSTRUMENTS Each of the parties hereto agrees that he or she will join in the execution, acknowledgment and delivery of any deed or other document which may be reasonably necessary to carry out the intent of this Agreement, and, in the event either of the parties hereto would not join in the execution, acknowledgment and delivery of such instrument, then such party does hereby irrevocably appoint the other party hereto as his or her Attomey-in-Fact to execute, acknowledge and deliver such instrument hereby ratifying all that such other party hereto may do by virtue hereof with a copy of this Agreement to be a sufficient Power of Attorney to carry out the intent and purpose of this paragraph. Nothing contained in this section shall affect the right of one party to expressly include or exclude, as the case may be, the other party as beneficiary in any will, insurance policy or other document whether the same is presently in effect or would become effective in the future. 21. VOLUNTARY EXECUTION The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective legal representatives, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, with full knowledge of the assets of both parties, and that it is not the result of any duress or undue influence. The parties acknowledge that they have been famished with all information relating to the financial affairs of the other which has been requested by each of them or their respective counsel. 22. ENTIRE AGREEMENT This Agreement contains the entire understanding of the parties and there are not representations, warranties, covenants or undertakings other than those expressly set forth herein. 23. DISCLOSURE Each of the parties hereto acknowledges that there has been full disclosure of all relevant matters of each party to the other party, that each of the parties s fully cognizant of his and her legal rights and liabilities with respect to the terms and conditions of this Agreement, that he and she understand the legal effect of this provisions of this Agreement and acknowledge that this Agreement is fair and equitable to each of the parties hereto, and that this Agreement was entered into voluntarily and without any undue influence or duress upon either party hereto. 24. MODIFICATION AND WAIVER This Agreement shall constitute a full, complete, and total binding Agreement between the parties concerning support, maintenance, alimony and property settlement, and is precluded from modification EXCEPT if the parties specifically agree to modify this Agreement. Any and all modifications to this Agreement shall only be by written agreement containing the same formalities as this Agreement and shall exhibit the notarized signatures of both parties, along with two witnesses. The parties specifically agree that they may rescind this Agreement only by written agreement containing the same formalities as this Agreement which shall exhibit the notarized signatures of both parties, along with two witnesses. Any waiver of a breach of any provision of this Agreement shall not constitute an ongoing waiver. 25. PRIOR AGREEMENTS This Agreement constitutes the entire understanding and agreement between the parties hereto, and there are no other representations, warranties, covenants, understandings or agreements other than those expressly set forth herein. 26. INCORPORATION INTO DECREE OF DIVORCE Unless as otherwise provided herein, this Agreement shall be incorporated in and made a part of any Decree that might be entered in any dissolution proceeding between the parties hereto upon the filing by either or both parties of an executed copy of this Agreement in such action and same may be incorporated by reference into any such Decree or court order. 27. DESCRIPTIVE HEADINGS The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 28. INDEPENDENT AND SEPARATE COVENANTS It is specifically understood and agreed by and between the parties hereto, that each paragraph shall be deemed a separate and independent covenant and agreement. 29. APPLICABLE LAW This Agreement shall be interpreted in accordance with the laws of the Commonwealth of Pennsylvania. 30. VOID CLAUSES 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 be valid and continue in full force, effect and operation 31. AGREEMENT BINDING ON HEIRS This Agreement shall inure to the benefit of and shall be binding upon the parties hereto, their heirs, executors, administrators, successors and assigns. 32. EFFECTIVE DATE This Agreement shall be considered to be effective at 12:01 a.m. on the date set forth on page one of this Agreement. G In Testimony Whereof, witness the signature of the parties hereto thisday of 2003. Witne s SANDRA M. GUTS LL Witness RUSSELL R. G SHALL, III COMMONWEALTH OF PENNSYLVANIA hu' SS. COUNTY OF C Rd,AND On this, the q'Ok day of ( ;(:(cC 6a:? , 2003, before me, a Notary Public, personally appeared SANDRA M. GUTSHALL and in due form of law acknowledged the foregoing Property Settlement Agreement to be her act and deed, and desired that the same might be recorded as such. Sworn to and subscribed before me this a°h4ay of August, 2003. -- Kw`? -'re- Notary Public LTH OF PENN YLVANI NOTARIAL SEAL MICHELLE ELLIOTT, NOTARY PUBLIC HUMMELSTOWN, DAUPHIN COUNTY MY COMMISSION EXPIRES JUNE 9 200 STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. On this, the day of J U 2003, before me, a Notary Public, personally appeared RUSSELL R. GUTSHALL. III and in due form of law acknowledged the foregoing Property Settlement Agreement to be his act and deed, and desired that the same might be recorded as such. Sworn to and subscribed before me this 3 L%y of A Ses; 2y003. r Notarial Seal Debra A. Micklo, Notary Public South Middleton 'lCumberland Court MY CommissioI?, ires Oct. 29, 2006 Member, PannsyNariaAssoclaboncf lanes Notary Public EXHIBIT A Husband shall receive the following items: 1) Husband's family dishes located at 26 Stewart Drive, Carlisle, PA 2) Wooden bowl made by Husband in high school 3) Husband's Grandfather's Butcher Block 4) Husband's gun collection It is noted that Husband shall return the following guns to Wife The "Youth" model purchased for Wife .22 semi automatic Ithaca Pump Shotgun 5) All photos shall be made available to Husband separated into two categories: Photos Husband can retain To include most hunting photos Photos Husband can duplicate 6) 20' TV in Husband's room 7) All tools and the workbench with the exclusion of the following items: A set of Flat head screwdrivers A set of Phillips head screwdrivers A set of box wrenches An adjustable wrench A set of hammers A hand saw and a hack saw A set of wooden saw horses Hand garden tools The nail and screw organizer Wheel barrel The riding mower The orange push mower A six foot wooden ladder A six foot aluminum ladder One two foot stepladder 8) Oak lumber in the garage. 9) The fishing equipment and tackle. 10) The hunting items including the deer antlers, two mounts and turkey tails. 11) The contents of the lock box at M&T Bank with the exception of the original Hospital Birth Records of the parties' children. Wife has represented that she has not entered the lock box in the past 12 months to remove any items from the lock box. 12) The 14 foot aluminum flat bottom fishing boat & motor with trailer and fishing equipment. 13) The utility trailer. All items with the exception of the lock box shall be exchanged by August 31, 2003. Once the lock box has been emptied and the contents transferred to Husband, the parties agree that the lock box account shall be closed at husband's expense. O? a U: ? y_ LL:?.; N .J y. U f' ?1_ .. ` ? ? 7 ? .? ?' ? ?;? _ ..?? ? - t is i. "? n. i r? ?.: V; n]i ? v U ?. In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION SANDRA M. GUTSHALL ) Docket Number 99-5578 CIVIL Plaintiff ) VS. ) PACSES Case Number 582101624 RUSSELL R. GUTSHALL III ) Defendant ) Other State ID Number ORDER AND NOW, to wit, on this 12TH DAY OF DECEMBER, 2003 IT IS HEREBY ORDERED that the APL order in this case be O Vacated or OSuspended or ®Terminated without prejudice or Q Terminated and Vacated, effective DECEMBER 1, 2003 , due to: THE PARTIES' PROPERTY SETTLEMENT AGREEMENT OF AUGUST 20, 2003 AND MS. GUTSHALL REFINANCING THE MARITAL HOME ON NOVEMBER 21, 2003. THERE IS A CREDIT OF $316.84 ON THE ALIMONY PENDENTE LITE ACCOUNT THAT WILL BE DIRECTED TO THE ALIMONY ACCOUNT. DRD: RJ Shadday xc: plaintiff defendant Peter Russo, Esquire Susan Kadel, Esquire Service Type M BY THE COIl Edward E. (Lido JUDGE Form OE-504 Worker ID 21005 n' .r Cl) -- } L ? ry[ I.L :'.. T G? p li] ? J LLLIJ W r p :.. (1. 4- o ] CJ N V LAW OFFICES OF PETER J. RUSSO, P.C. BY: Elizabeth J. Saylor, Esquire PA Supreme Court ID: 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: Isaylor@pjrlaw.com Attorneys for Plaintiff RUSSELL R. GUTSHALL, III Plaintiff V. SANDRA M. GUTSHALL Defendant T1 T1 T 4 f „n yV ' + F IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 99-5578 CIVIL TERM : IN DIVORCE PLAINTIFF'S PETITION FOR SPECIAL RELIEF PURSUANT TO 23 PA. C.S. 0143105(C). 3701(8), AND 3701(E) OF THE DIVORCE CODE AND NOW comes the above-named Plaintiff, Russell R. Gutshall, III, by and through his attorney, The Law Offices of Peter J. Russo, P.C., and avers the following: 1. Plaintiff/Petitioner Russell R. Gutshall, III and Defendant/Respondent Sandra M. Gutshall, formerly husband and wife, were divorced on September 30, 2003. A copy of the Decree in Divorce, signed by the Honorable Judge Guido, is attached as Exhibit A. 2. The economic issues incident to the parties' separation and divorce were resolved in a Property Settlement Agreement dated August 20, 2003 and filed of record on September 5, 2003 (hereinafter "Agreement"). A time-stamped copy of the Agreement is attached as Exhibit B. 3. Paragraph 12 of the Agreement entitled "Alimony" in pertinent part states: "Husband shall pay Wife One Thousand Four Hundred Dollars ($1,400.00) per month as alimony until husband retires from Sprint or reaches age 65, whichever occurs later. Both parties acknowledge and agree that the provisions of this Agreement providing for alimony are fair, adequate and satisfactory based on actual need, ability to pay, duration of the marriage and other relevant factors taken into consideration by the parties. Although the approval of this Agreement by a court of competent jurisdiction in connection with this action in divorce filed by Husband or Wife shall be deemed an order of the court and may be enforced as such, this Agreement, insofar as it pertains only to spousal support and the payment of alimony following the entry of a final Decree in Divorce between the parties, may be modified, suspended, terminated or reinstated at the instance of request of either party, or subject to further order of any court upon changed circumstances as contemplated by the Divorce Code." 4. 23 Pa. C.S. §3105(c) of the Divorce Code states that "in the absence of a specific provision to the contrary appearing in the agreement, a provision regarding the disposition of...alimony...shall not be subject to modification by the court." See Cole/la v. Colella, 72 Pa. D. & CAth 158, 163 (2005), citing 23 Pa. C. S. §3105(c). 5. Under 23 Pa. C.S. §3105(c), the language of the Agreement unequivocally permits modification. See Id. at 163-165. 6. The Agreement language "may be modified, suspended, terminated or reinstated at the instance of request of either party, or subject to further order of any court upon changed circumstances as contemplated by the Divorce Code" clearly refers to 23 Pa. C.S. §3701(e). See Id. 2 7. 23 Pa. C.S. §3701(e) states "An order entered pursuant to this section is subject to further order of the court upon changed circumstances of either party of a substantial and continuing nature whereupon the order may be modified, suspended, terminated or reinstated or a new order made." See !d. at 164. 8. At the time the parties entered into the PSA, Husband was employed at Sprint and earning approximately $65,000.00 annually. 9. Husband's position at Sprint has been eliminated due to the economy. 10. Husband's final pay from Sprint (later becoming Embarq and now Centuryl-ink) was December 3, 2010. 11. Husband's official retirement date is January 1, 2011. 12. Husband is 62 years of age. 13. Husband suffers from health related issues concerning both his heart and his back. 14. Husband believes and thus avers that his age and health have prevented and will continue to prevent him from securing a comparable income. 15. Upon retirement, Husband's net income will be approximately $1,500.00 per month, leaving him with only $100.00 per month to pay for monthly expenses, following his alimony payment to Wife. 16. Some of Husband's monthly expenses have increased since 2003. 17. Husband has experienced changed circumstances of a substantial and continuing nature warranting a modification of alimony in consideration of the relevant factors set forth in 23 Pa. C.S. §3701(e). See Cole/la v. Co/e//a, 72 Pa. D. & CAth 158 (2005) and Kokolis v. Kokolis, 83 Pa. D. & CAth 214 (2006). 3 WHEREFORE, Plaintiff/Petitioner respectfully requests that this Court grant his petition for special relief and terminate, or in the very least suspend or modify, his alimony obligation to Wife. LAW OFFICES OF PETER J. RUSSO, P.C. C-:: Attorneys for Plaintiff Peter J. Russo, Esquire ID # 72897 Elizabeth J. Saylor, Esquire ID # 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 PH: (717) 591-1755 FX: (717) 591-1756 Date: aoI1-u 4 EXHIBIT A p IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. No. 1 ggQ_SS7st VERSUS DECREE IN DIVORCE oa3u Sof.'*4 AND NOW, IT IS ORDERED AND DECREED THAT PLAINTIFF, AND cn?n M rs.,+e• ur 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; The parties have executad a Property Settlenent Agreement which shall ATTEST: • PROTHONOTARY T)Z, EXHIBIT B RUSSELL R. GUTSHALL, III IN THE COURT OF COMMON PLEAS OF Pidndff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW SANDRA M. GUTSHALL NO. 99-5578 CIVIL TERM Defeadent IN DIVORCE PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT is hereby made and entered into this ao /- day of 2003, by and between SANDRA M. GUTSHALL, "Wife," and RUSSELL GUTSHALL, III, hereinafter "Husband." Witnesseth: Whereas, marital differences and difficulties have arisen between the Parties, and Whereas, Parties have separated physically and intended to continue to live apart and desire to forever completely settle, determine and provide for the support of Wife, separation of their marital and nonmarital, real and personal, belonging to either and/or both of the parties hereto and all other rights, entitlements, benefits, and privileges involved between the parties hereto arising directly or indirectly out of the marriage relationship, and Whereas, Parties have had adequate time and opportunity to consult with separate legal counsel of their own, and Whereas, both Parties acknowledge that they are satisfied with the legal advice they have received and understand the full importance of the Agreement they are entering into; Now, Therefore, the parties, in consideration of the foregoing premises, and the mutual promises and undertakings hereinafter set forth, agree as follows: 1. RIGHT TO LIVE SEPARATE It shall be lawful for Husband and Wife at all times hereinafter to live separate and apart from each other and to reside from time to time at such place or places as he and she shall respectively deem fit, free from any control, restraint or interference, direct or indirect, by each other. The foregoing provisions shall not be taken to be any admission on the part of either Husband or Wife of the lawibiness or unlawfulness of the causes leading to their living apart. 2. FREEDOM FROM INTERFERENCE Each party shall be free from interference, authority and contact by the other as if he or she were single and unmarried except as necessary to carry out provisions of this Agreement. Neither party shall harass the other or attempt to endeavor to harass the other, nor compel the other to cohabit with the other, or in any way malign the other, nor in any way interfere with the peacWW existence, separate and apart from the other. 3. DISTRIBUTION OF VEHICLES Wife shall assume 811 payments, including all loan, insurance and repair bills connected with any and all vehicles presently in her possession including, but not limited to, her 1987 Aero Star Van. Husband shall assume all payments, including all loan, insurance and repair bills connected with any vehicles presently in his possession including, but not limited to, his 1988 Ford Ranger Pickup. Pursuant to Paragraph 3, Wife shall execute the motor vehicle title to the 1988 Ford Ranger Pickup in favor of Husband and Husband shall execute the motor vehicle title to the 1987 Aero Star Van in favor of Wife. The parties shall complete this process on or before July 15, 2003. 4. DIS?ON OF POSSESSIONS As of the date of the execution of this Agreement, the parties shall transfer and assign their rights, title, claim and interest in specific property. Wife shall have as her own, free and clear of any claims of Husband, all of the items, household goods, furniture, furnishings, appurtenances, and appliances which are in her possession. Husband shall have as his own, free and clear of any claims of Wife, all of the items, household goods, furniture, furnishings, appurtenances, and appliances which are in his possession. 5. DISMBUTION OF PERSONAL PROPERTY With the exception of those items set forth in Exhibit A, it is further agreed that both Husband and Wife shall retain as his or her own any and all personal effects, clothing, and personal jewelry currently in their possession. The parties llr Cher agree that any property not assigned in this Agreement, as marital or nonmarital property will be deemed the property of the physical possessor of said property. EXCHANGE OF THESE PERSONAL ITEMS SHALL TAKE PLACE NO LATER THAN AUGUST 31, 2003. A mutually convenient date and time shall be established by the parties and Husband shall remove all of the items set forth in this agreement by the end of the time period established by the parties. At the conclusion of that scheduled time period, Husband shall not be permitted to re-enter the marital residence to remove any item without the express permission of Wife. 6. RMTIRBMENT ACCOUNTS The parties shall keep all IRA's, 401 k's and other retirement accounts which are held in their names as Personal property, free and clear of claims from the other party with the exception of the Husband's Sprint Pension Plan. Husband's Sprint Pension Plan shall be divided pursuant to a Qualified Domestic Relations Order which shall award Wife fifty percent (50%) of Husband's pension benefit effective September 13, 1999. Wife shall take all steps necessary to cause said Qualified Domestic Relations order to be drafted, entered as an Order of Court and delivered to Husband's pension administrator within forty five (45) days of the execution of this Agreement. 7. JOINT ACCOUNTS The parties shall stop using all joint bank and charge accounts, credit card accounts and any other joint accounts shall be terminated and each party shall take those steps necessary to have the other removed as a responsible party from such accounts. The parties further specifically agree that all bank, savings, cash and checking accounts shall become the sole property of party named on the account. 8. MARITAL LIABILITIES Unless otherwise set forth herein, Wife assumes full responsibility for any indebtedness which she has contracted or incurred in her name, alone or jointly, after the date of separation. Unless otherwise set forth herein, Wife mpromts and warrants to Husband that, since the filing of the divorce action, she has not contracted or incurred any debt or liability, for which Husband or his Estate might be responsible, and shall indemnify and save Husband harmless from any and all claims or demands made against him or his Estate by reason of debts or obligations incurred by Wife and/or assumed herein. Unless otherwise set forth herein, Husband assumes full responsibility for any indebtedness which he has contracted or incurred in his name, alone or jointly, after the ditto of separation of this Agreement. Unless otherwise set forth herein, Husband represents and warrants to Wife that, since the filing of the divorce action, he has not contracted or incurred any debt or liability, for which Wife or her Estate might be responsible, and shall indemnify and save Wife harmless from any and all claims or demands made against her or her Estate by reason of debts or obligations incurred by Husband and/or assumed herein. 9. OTHER MARITAL ASSETS During the course of this marriage, the parties purchased a marital residence located at 26 Stewart Drive, Carlisle, PA 17013. The parties have agreed that Wife shall assume solo ownership of said marital residence. Wife shall refinance the mortgage on the marital residence within ninety (90) days of the execution of this Agreement. Wife shall hold Husband harmless from any obligation associated with the marital residence. Husband shall execute a deed in favor of Wife contemporaneously with the execution of the mortgage that releases the CUNA mortgage. At the time of Wife's refinance of the marital residence, Husband shall be made a payee on the HUD•1 Settlement Sheet in the amount of Seven Hundred Dollars ($700.00). Once Wife refinances the CUNA mortgage or once alimony commences, whichever is sooner, Wife shall be solely responsible for all maintenance, expenses, taxes, utilities, payments, etc. related to 26 Stewart Drive, Carlisle, PA. Husband has maintained a real estate tax escrow find. This real estate tax escrow fund has been used to pay all real estate taxes. At times, this real estate tax escrow fund has been over-!laded to insure fiords would be available in the event of a tax increase. Upon the refinance of the marital residence, Wife shall be entitled to retain the funds in the real estate tax escrow account which are equal to the per than real estate taxes on the property beginning in the current tax year through the date of settlement. Any funds which exceed that amount shall be returned to Husband. In the event Wife is unable to refinance the existing CUNA mortgage and a default of said mortgage occurs, Wife shall inform Husband of the default within 5 days of each notice received by CUNA. Husband shall have the right to cure any default and recoup any funds advanced to avoid a default when the subject property is sold or refinanced. During the course of this marriage, the parties purchased approximately 5.8 acres of vacant mountain land in Port Royal, PA. The aforementioned mountain land was sold via private sale. Peter J. Russo, Esquire, is escrowing the proceeds of the sale of the mountain land. Upon VAM's execution of this agreement, Peter J. Russo, Esquire shall release the proceeds of the mountain land sale to Husband. Wife is currently in possession of the parties' children's birth records. Notwithstanding the fact that Wife is in possession of those birth records, both parties retain their respective rights to pursue or defend litigation relating to said birth records. 10. TAX LIABILITY The parties hereto believe and agree that the division of property heretofore made by this Agreement is a non-taxable division of property between co-owners rather than a taxable sale or exchange of property. Each party promises not to take any position with respect to the adjusted basis of the property assigned to him or her with respect to any other issue which is inconsistent with the position set forth in the preceding sentence on his or her Federal or State income tax return 11. MUTUAL RELEASE Subject to the provisions of this Agreement, each party has released and discharged, and t by this Agreement does for himself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all caused of action, claims, rights or demands whatsoever in law or equity, which either of the parties ever had or now has against the other, except any or all causes of action for divorce and except any or all caused of action for any breach of any provision of this Agreement. Each party also waives his or her right to request marital counseling pursuant to Pennsylvania's Divorce Code. 12. ALIMONY Husband shall pay Wife One Thousand Four Hundred Dollars (S 1,400,00) per month as alimony until Husband retires from Sprint or reaches age 65, whichever occurs later. Both parties acknowledge and agree that the provisions of this Agreement providing for alimony are fair, adequate and satisfactory based on actual need, ability to pay, duration of the marriage and other relevant factors taken into consideration by the panics. Although the approval of this Agreement by a court of competent jurisdiction in connection with this action in divorce filed by Husband or Wife shall be deemed an order of the court and may be cnffin-Mt u,is Agreement, insofar as it pertains only to spousal support and the payment of alimony following the entry of a final Decree in Divorce between the parties, may be modified, suspended, terminated or reinstated at the instance of request of either puny, or subject to further order of any court upon changed circumstances as contemplated by the, Divorce Code. Alimony shall be made payable through Cumberland County Domestic Relations. Alimony shall commence and spousal support :dull terminate within on August 1, 2003 or the date of Wife's refinance settlement, whichever is sooner. Husband shall secure a term life insurance policy which shall indemnify Wife for an amount equal to the total alimony payments until Flushand reaches age 65. Husband shall have the right to decrease the amount of benefit by $16,M).00 such year. If Husband reaches age 66 and is still employed at Sprint, he shall maintain it hencfit for Wife equal to one year's alimony or $16,800.00. This insurance benefit of $16,800.00 shall renew each year Husband continues to be employed at Sprint after age 66. 13. ALIMONY PENDENTE LITE, CO1ti1NSEL FEES AND EXPENSES Both parties hereby acknowledge and accept that the provisions of this Agreement providing for the equitable distribution of marital property are fair, adequate and satisfactory to A than. Both parties agree to accept the provisions of this Agreement in lieu of and in full and final settlement and satisfaction of all claims and demands that either may now or hereafter have against the other. 14. INCOME TAX RETURNS Husband and Wife agree to individual tax returns for 2003 and thereafter until their divorce is final. Each party shall be solely responsible for any and all Federal, State and Local tax liability beginning in 2003 and thereafter. Each party shall have the exclusive right to any and all refunds based on their Federal, State and Local tax returns beginning in 2003 and thereafter. 15. WAIVER OF CLAIMS AGAINST ESTATES Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby 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, dower, curtsey, statutory allowance, widow's allowance, right to take intestacy, right to take against the will of the other, and right to act as administrator or executor of the other's estate. Each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims and both parties will revoke prior wills or testamentary documents. 16. AGREEMENT NOT PREDICATED ON DIVORCE It is specifically understood and agreed by and between the parties hereto and each of the said parties does hereby warrant and represent to the other, that the execution and delivery of this Agreement is not predicated upon nor made subject to any agreement for institution, prosecution, defense, or for the non-prosecution or non-defense of any action for divorce; provided, however, that nothing contained in this Agreement shall prevent or preclude either of the parties hereto from commencing, instituting or prosecuting any action or actions for divorce, either absolute or otherwise, upon just, legal and proper grounds; nor to prevent either party from defending any such action which has been, may or shall be instituted by the other party, or from making any just or proper defense thereto. 17. SUBSEQUENT DIVORCE A divorce proceeding was filed by Husband against Wife in Cumberland County and docketed at 99-5578. The parties hereby mutually consent to a divorce and the entering of a divorce decree on the no-fault grounds that their marriage is irretrievably broken pursuant to 13301(c) of the Pennsylvania Divorce Code. Parties herein shall execute Affidavits of Consent and a fimal decree in divorce will then be obtained. 18: BREACH AND ENFORCEMENT If either party hereto breaches any of the provisions of this Agreement, the other party shall have the right to bring any actions or actions in law or equity for such breach, and the breaching party shall be responsible for the payment of all costs and reasonable legal fees incurred by the other party in enforcing his or her rights under this Agreement. It is expressly understood and agreed by and between the parties hereto that this Agreement may be specifically enforced by either party in Equity, and the parties hereto agree that if an action to enforce this Agreement is brought in Equity by either party, the other party will make no objection on the alleged ground of lack of jurisdiction of said Court on the ground that there is an adequate remedy at law. The parties do not intend or purport hereby to improperly confer jurisdiction on a Court in Equity by this Agreement, but they agree as provided herein for the forum of equity in mutual recognition of the present state of the law, and in recognition of the general jurisdiction of Courts in Equity over agreements such as this one. 19. RE-ACKNOWLEDGMENT Each party acknowledges that it may be appropriate and required that this Agreement be re-admowle:dge d at some time in the future before the Clerk of the Commonwealth Court. Clerk of Orphans Court or some other Court, and each party agrees that they will re-acknowledge their signature before the Clerk of such Court upon request of the other party so that this Agreement may comply with the acknowledgment rules and provisions of any such Court. 20. ADDITIONAL INSTRUMENTS Each of the parties hereto agrees that he or she will join in the execution, acknowledgment and delivery of any deed or other document which may be reasonably necessary to carry out the intent of this Agreement, and, in the event either of the parties hereto would not join in the execution, acknowledgment and delivery of such instrument, then such party does hereby irrevocably appoint the other party hereto as his or her Attorney-in-Fact to execute, acknowledge and deliver such instrument hereby ratifying all that such other party hereto may do by virtue hereof with a copy of this Agreement to be a sufficient Power of Attorney to curry out the intent and purpose of this paragraph. Nothing contained in this section shall affect the right of one party to expressly include or exclude, as the can may be, the other party as beneficiary in any will, insurance policy or other document whether the same is presently in effect or would become effective in the future. 21. VOLUNTARY EXECUTION The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective legal representatives, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, with full knowledge of the assets of both parties, and that it is not the result of any duress or undue influence. The parties acknowledge that they have been furnished with all information relating to the financial affairs of the other which has been requested by each of than or their respective counsel. 22. ENTIRE AGREEMENT This Agreement contains the entire understanding of the parties and there are not representations, warranties, covenants or undertakings other than those expressly set forth herein. 23. DISCLOSURE Each of the parties hereto acknowledges that there has been full disclosure of all relevant matters of each party to the other party, that each of the parties os fully cognizant of his and her legal rights and liabilities with respect to the terms and conditions of this Agreement, that he and she understand the legal effect of this provisions of this Agreement and acknowledge that this Agreement is fair and equitable to each of the parties hereto, and that this Agreement was entered into voluntarily and without any undue influence or duress upon either party hereto. 24. MODIFICATION AND WAIVER This Agreement shall constitute a full, complete, and total binding Agreement between the parties concerning support, maintenance, alimony and property settlement, and is precluded from modification EXCBPT if the parties specifically agree to modify this Agreement. Any and all modifications to this Agreement shall only be by written agreement containing the same formalities as this Agreement and shall exhibit the notarized signatures of both parties, along with two witnesses. The parties specifically agree that they may rescind this Agreement only by written agreement containing the same formalities as this Agreement which shall exhibit the notarized signatures of both parties, along with two witnesses. Any waiver of a breach of any provision of this Agreement shall not constitute an ongoing waiver. 25. PRIOR AGREEMENTS This Agreement constitutes the entire understanding and agreement between the parties hereto, and there are no other representations, warranties, covenants, understandings or agreements other than those expressly set forth herein. 26. INCORPORATION INTO DECREE OF DIVORCE Unless as otherwise provided herein, this Agreement shall be incorporated in and made a part of any Decree that might be entered in any dissolution proceeding between the parties hereto upon the filing by either or both parties of an executed copy of this Agreement in such action and same may be incorporated by reference into any such Decree or court order. 27. DESCRIPTIVE HEADINGS The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 28. INDEPENDENT AND SEPARATE COVENANTS It is specifically understood and agreed by and between the parties hereto, that each paragraph shall be deemed a separate and independent covenant and agreement. 29. APPLICABLE LAW This Agreement shall be interpreted in accordance with the laws of the Commonwealth of Pennsylvania. 30. VOID CLAUSES If any team, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that tern, condition, clause or provision shall be stricken from this Agreement and in all other respects, this Agreement shall be valid and continue in full force, effect and operation 31. AGREEMENT BINDING ON HEIRS This Agreement shall inure to the benefit of and shall be binding upon the parties hereto, their heirs, executors, administrators, successors and assigns. 32. EFFECTIVE DATE This Agreement shall be considered to be effective at 12:01 a.m. on the date set forth on page one of this Agreement. In T ay Whereof, witness the signature of the parties hereto this Y' of day 2003. Wr SANDRA M. GUTS L Witness RUSSELL R. G HALL, III COMMONWEALTH OF PENNSYLVANIA I??}• SS. COUNTY OF RUA,ND : On this, the dOlk day of_? U'2003, before me, a Notary Public, personally appeared SANDRA M. GUTSHALL and in due form of law acknowledged the foregoing Property Settlement Agreement to be her act and deed, and desired that the same might be recorded as such. Sworn to and subscribed ey before me this d"44 of August, 2003. ?44W-4& -a-w-r Notary Public C, NWE&IH OF (jrVA I NOTARIAL SEAL MICHELLE ELLIOTT. NOTARY PUBLIC IMY HUMMELSTOWN, DAUPHIN COUNTY SION EXPIRES 9 STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. On this, the day of J ULY , 2003, before me, a Notary Public, personally appeared RUSSELL R. GUT HALL. Ill and in due form of law acknowledged the foregoing Property Settlement Agee rent to be his act and deed, and desired that the same might be recorded as such. Sworn to and subsWbed before me this -Iffday ofjuqrah 2003. r Ww Notary Public -4" ikbra A 1 d k swil my C?? cal 2? Z006 EXHIBIT A Husband shall receive the following items: 1) Husband's family dishes located at 26 Stewart Drive, Carlisle, PA 2) Wooden bowl made by Husband in high school 3) Husband's Grandfather's Butcher Block 4) Husband's gun collection it is noted that Husband shall return the following guns to Wife The "Youth' 'model purchased for Wife .22 semi automatic Ithaca Pump Shotgun 5) All photos shall be made available to Husband separated into two categories: Photos Husband can retain To include most hunting photos Photos Husband can duplicate 6) 20' TV in Husband's room 7) All tools and the workbench with the exclusion of the following items: A set of Flat head screwdrivers A set of Phillips head screwdrivers A set of box wrenches An adjustable wrench A set of hammers A hand saw and a hack saw A set of wooden saw horses Hand garden tools The nail and screw organizer ... .... ....... . . .. ...7.1- ... ... ... ... ........ .w......i Wheel barrel The riding mower The orange push mower A six foot wooden ladder A six foot aluminum ladder One two foot stepladder g) Oak lumber in the garage. 9) The fishing equipment and tackle. 10) The hunting items including the deer antlers, two mounts and turkey tails. 11) The contents of the lock box at M&T Bank with the exception of the original Hospital Birth Records of the parties' children. Wife has represented that she has not entered the lock box in the past 12 months to remove any items from the lock box. 12) The 14 foot aluminum flat bottom fishing boat & motor with trailer and fishing equipment. 13) The utility trailer. All items with the exception of the lock box shall be exchanged by August 31, 2003. Once the lock box has been emptied and the contents transferred to Husband, the parties agree that the lock box account shall be closed at husband's expense. VERIFICATION I, Russell R. Gutshall, III, verify that the statements made in the foregoing document(s) are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: A-P Russell R Gu all, III • ' a w CERTIFICATE OF SERVICE 1, Ashley R. Malcolm, hereby certify that I am on this day serving a copy of the foregoing Plaintiff's Petition for Special Relief Pursuant to 23 Pa. C.S. §§3105(c), 3701(b), AND 3701(e) upon the person(s) and in the manner indicated below: US Regular Mail addressed as follows: Susan M. Kadel, Esquire James, Smith, Dietterick & Connelly 134 Sipe Ave Hummelstown, PA 17036 Counsel for Defendant Sandra M Gutshall 26 Stewart Drive Carlisle, PA 17013 Date: 1Jk --a\ -1 C) O&Qbj Z. WWCQLn?m Ashley . Malcolm, Paralegal 6 l ?> F RUSSELL R. GUTSHALL, III Plaintiff V. SANDRA M. GUTSHALL Defendant IN RE: DEC 222010 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-6578 CIVIL TERM IN DIVORCE TO 23 PA. §§ 3105(C), 3701(B), AND 3701(E) OF THE DIVORCE CODE AND NOW, this Pa day of kP-'-P"'A_ 2010 upon consideration of Plaintiffs Petition for Special Relief Pursuant to 23 Pa. C.S. §§ 3105(c), 3701(b) and 3701(e) of the Divorce Code, a Rule to Show Cause is issued directing . ° t , ? Defend ant/Respondent to show cause, if any, why the Court should not a 0 rfl,, mr z Plaintiff/Petition the relief requested. The Rule is returnable: n ? -a rn ° z C within days of this Order; OR zo a = D-n F; .... m at a hearing schedule for Jx&uiA,"- at 7 6 .m., in Courtroom Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. BY THE COURT: J. mcaw zumn M. KW. Est Snnd#&14. gotst wi, DeR Peter- J . -2usso, Fay 3 ia1a7??DO Distribution list: Peter J. Russo, Esquire, Law Offices of Peter J. Russo, P.C. 5006 E. Trindle Road, Suite 100, Mechanicsburg, PA 17050, Plaintiffs Counsel Susan M. Kadel, Esquire, James, Smith, Dietterick & Connelly, 134 Sipe Ave, Hummelstown, PA 17036 Sandra M Gutshall, 26 Stewart Drive, Carlisle, PA 17013 Susan M. Kadel, Esquire Attorney I.D. No. 44837 James Smith Dietterick & Connelly, LLP P.O. Box 650 Hershey, PA 17033 FILMW ICE OF THE PROTHONOTARY 2011 1':1.1-- S x,1111: 51 CUId BERLn',U hCOUNTY i" ENINS Y L\W(IIA RUSSELL R. GUTSHALL, III Plaintiff V. SANDRA M. GUTSHALL Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-5578 CIVIL ACTION -LAW IN DIVORCE MOTION FOR CONTINUANCE AND NOW, comes the Defendant, Sandra M. Gutshall, by and through her counsel, Susan M. Kadel, Esquire and the law firm of James, Smith, Dietterick & Connelly, LLP and files this Motion for Continuance as follows: 1. The Defendant, Sandra M. Gutshall, is represented by Susan M. Kadel, Esquire, in the above-captioned action. 2. The Plaintiff, Russell R. Gutshall, III, is represented by Peter J. Russo, Esquire, in the above-captioned. 3. On December 27, 2010, the Court entered an Order scheduling a hearing in this matter for Wednesday, February 9, 2010, at 8:45 a.m. before The Honorable Albert H. Masland. 4. Counsel for the Defendant will be out of the country on February 9, 2011, and will not be returning to the office until after February 28, 2011. 5. Because of the unavailability of Defendant's counsel, Defendant is requesting that the Court reschedule the hearing in this matter after February 28, 2011. 6. Peter J. Russo, Esquire, counsel for the Plaintiff, concurs in this request for a continuance. WHEREFORE, the Defendant, Sandra M. Gutshall, by and through her counsel, Susan M. Kadel, Esquire, requests that the hearing currently scheduled for Wednesday, February 9, 2011, at 8:45 a.m. be rescheduled after February 28, 2011. Respectfully submitted, JAMES, SMITH, DIETTERICK & CONNELLY, LLP Dated: January 5, 2011 By: 44?usmkadel, Esquire Attorney I.D. #44837 P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Defendant, Sandra M. Gutshall RUSSELL R. GUTSHALL, III : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 99-5578 SANDRA M. GUTSHALL : CIVIL ACTION -LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Susan M. Kadel, Esquire, of James, Smith, Dietterick & Connelly, LLP attorney for the Defendant, Sandra M. Gutshall, hereby certify that I have served a copy of the foregoing Motion for Continuance on the following on the date and in the manner indicated below: VIA U.S MAIL. FIRST CLASS. PRE-PAID Peter J. Russo, Esquire Law Offices of Peter J. Russo, P.C. 5006 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 JAMES, SMITH, DIETTERICK & CONNELLY, LLP Dated: January 5, 2011 By: Susan! M. Kadel, Esquire Attorney I.D. #44837 P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Defendant, Sandra M. Gutshall 0 7 2011 RUSSELL R. GUTSHALL, III : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-5578 CI SANDRA M. GUTSHALL : CIVIL ACTION -LAW Defendant : IN DIVORCE, r-- e o i. ORDER - ` ' AND NOW, this IL-day of , 2011, pursuant to Defendant's Motion for Continuance, the hearing currently scheduled for Wednesday, February 9, 2011, at 8:45 a.m. is rescheduled to . /1) 2011, at %; 3j) m•, in Courtroom of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. By the Court, Distribution: ? Susan M. Kadel, Esquire, P.O. Box 650, Hershey, PA 17033 '"'Peter J. Russo, Esquire, 5006 E. Trindle Road, Suite 100, Mechanicsburg, PA 17050 Npies o? r^? r= LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo, Esquire PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: prusso@pjrlaw.com Attorneys for Plaintiff RUSSELL R. GUTSHALL, III Plaintiff V. SANDRA M. GUTSHALL Defendant [7ILED-OFF ICE CI l MAR 18 A141I: 04 CUMBERLAND COUNTY PENNSYLVANIA : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 99-5578 CIVIL TERM IN DIVORCE ADDENDUM TO THE STIPULATED PROPERTY SETTLEMENT AGREEMENT WHEREFORE, the parties to this Addendum to the Property Settlement Agreement (hereinafter "Addendum") are Sandra M. Gutshall (hereinafter "Wife") and Russell R. Gutshall, III (hereinafter "Husband") WHEREFORE, said parties entered into a Property Settlement Agreement on August 20, 2003, filed September 5, 2003, and incorporated but not merged into the Decree in Divorce entered September 30, 2003 (hereinafter "PSA"). WHEREFORE, due to a change in circumstances, it is the desire of both parties hereto to amend only those paragraphs of the PSA that are set forth below, with all other provisions of the PSA remaining binding. NOW THEREFORE, in consideration of the mutual promises and covenants expressed herein, AND INTENDING TO BE LEGALLY BOUND HEREBY, the parties agree to amend the PSA as follows: 1. In consideration of the terms and mutual promises contained herein, upon the execution of this Addendum and the remittance of the funds required herein, this Addendum shall be merged with the original PSA executed by the parties and Husband shall withdraw his Petition for Special Relief. 2. Paragraph 12 of the PSA shall be stricken in its entirety and amended to read as follows: 12. ALIMONY Any and all Alimony previously agreed and owed shall forever cease effective March 2, 2011. The parties herein acknowledge that by this Addendum they have each respectively secured and maintained a substantial and adequate fund with which to provide themselves sufficient financial resources to provide for their comfort, maintenance and support, in the station of life in which they are accustomed. Wife and Husband do hereby waive, release and give up any rights they may respectively have against the other for alimony, alimony pendente lite, support or maintenance. It shall be from the date of this Addendum the sole responsibility of each of the respective parties to sustain themselves without seeking any support from the other party. 3. The following paragraph shall be inserted into the PSA as Paragraph 5.1 5.1 EQUITABLE DISTRIBUTION Husband agrees to pay to Wife, as and for equitable distribution, the sum of twenty seven thousand dollars ($27,000.00), which shall be paid through counsel, on or before April 1, 2011. It is understood by the parties, and the parties agree, that Husband's equitable distribution payment shall not constitute income to Wife. 4. All other terms within the PSA except for Paragraphs 12 therein shall be given full force and effect and remain binding on all parties hereto. 5. This Effective Date of this Addendum shall be 12:01 a.m. on the date on which the last party signs this document. THE REMAINDER OF THIS PAGE IS INTENTIONALLY LEFT BLANK. The parties to this Addendum have hereunto set their hands and seals on the I LI day of ft , 2011. Ird Witness for Sandra M. G tshall -' ' AM L, M" L Witne s for Russell R Gutshall, III Sandra M. Gutshall Russell R. Gut all, III COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND :SS. On this, the--L4 day of n o rA 2011, before me, a Notary Public, personally appeared Sandra M. Gutshall and in due form of law acknowledged the foregoing Agreement to be her act and deed, and desired that the same might be recorded as such. Sworn to and subscribed before me this -AL-%ay of `?T?a r-A , 2011. NotaryPublic COMMONWEALTH OF PENNSYLVANIA Notarial Seal Flora M. Vogt, Notary Public North Middleton Twp., Cumberland County My Commission Expires May 21, 2013 'Ad ember, Pennsylvania Association of Notaries COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND :SS. On this, the ILp day of &"M , 2011, before me, a Notary Public, personally appeared Russell R. Gutshall, III and in due form of law acknowledged the foregoing Agreement to be his act and deed, and desired that the same might be recorded as such. Sworn to and subscribed before me this 10 day of (?_? , 2011. Notary Pc COMMONWEALTH OF PEWMLVMA Notarial sw Ashley R. Maiodm, Notary Publk Hampden 1Wp., Cumbarl" County My Q=nWNon e0m Oct 12 2011 Member. PeA i Aijago- of Notarles RUSSELL R. GUTSHALL, III, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIAc-j? 4= :v ?a vs. CIVIL ACTION - DIVORCE MCC m -r x NO. 99-5578 CIVIL TER M SANDRA M. GUTSHALL, DIVORCE Defendant/Petitioner PACSES CASE: 582101624 !? ORDER OF COURT AND NOW to wit, this 27th day of April, 2011, it is hereby Ordered that the Cumberland County Domestic relations Section dismiss their interest in the above captioned Alimony matter pursuant to the Parties' march 14,2 011 Addendum to the Stipulated Property Settlement Agreement and their agreement to terminate the Alimony obligation, effective March 2, 2011. This Order shall become final twenty (20) days after the mailing of the notices of the entry of the Order to the parties unless either party files a written demand with the Office of the Prothonotary for a hearing de novo before the Court. BY THE COURT: Edward E. Guido, J. DRO: R.J. Shadday xc: Petitioner Respondent Susan M. Kadel, Esq. Peter Russo, Esq. Form OE-001 Service Type: M Worker: 21005