HomeMy WebLinkAbout99-05834
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IN THE COURT OF COMMON PLEAS OF
JOHN E. MUMMA CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff CIVIL ACTION - LAW
VS. NO.99-5834 CIVIL 19
IN DIVORCE
MAUREEN ANN MUMMA
Defendant
STATUS SHEET
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JOHN E. MUMMA, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99 - 5834 CIVIL
MAUREEN ANN MUMMA,
Defendant IN DIVORCE
TO: Maria P. Cognetti Attorney for Plaintiff
Donald T. Kissinger Attorney for Defendant
DATE: Thursday, July 26, 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.
DATE COUNSEL FOR PLAINTIFF ( )
COUNSEL FOR DEFENDANT ( )
NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTI1, 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 PHE'I'RIAL
STATEMENTS WILL BE ISSUED AT THE MATER'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 IMME'DIA'TELY.
THE CERTIFICATION DOCUMENT SHOUL,U BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
.II_IAR[! P. CoGN]E' Il'1[ & As5®CIATES
2 Attorneys and Counselors at Law Practice Limited to Matrimonial Law
Maria P. Cognetti*
Aaomey at Law
•Fcllow, American Academy of
Matrimonial Lawyers
August 6, 2001
E. Robert Elicker, 11, Divorce Master
Cumberland County
9 North Hanover Street
Carlisle, PA 17013
RE: MUMMA V. MUMMA
Our File No. 93
Dear Mr. Elicker:
Karen A. Sheriff
Paralegal
Christopher T. Zweifel
Paralegal
Enclosed please find Plaintiffs Discovery Certification. Should you have any questions,
please do not hesitate to contact us.
Very truly you ,
r,/, i
Maria P Cogr)ct
MPC/res
Enclosure
cc: John E. Mumma, w/enclosure
Donald T. Kissinger, Esquire, w/enclosure
210 Grandview Avenue, Suite 102 ? Camp Hill, PA 17011
Telephone (717) 909-4060 ? Fax (717) 909-4068
Email CognettiLaw a aol.com
AUG 0 7 2001,
JOHN E. MUMMA,
Plaintiff
VS.
MAUREEN ANN MUMMA,
Defendant
TO: Maria P. Cognetti
Donald T. Kissinger
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 5834 CIVIL
IN DIVORCE
Attorney for Plaintiff
Attorney for Defendant
DATE: Thursday, July 26, 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.
DATE COUNSE FOR PL INTIFF (x)
COUNSEL FOR ENDANT ( )
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.
JOHN D. KILLIAN
SMI'rll B, GEPI TART
TIIOMAS W. SCOTT
JANE: C.OWEN PENNY
TERRENCE J. MCGOWAN
PAIIIA J. WDERMOTr
J. PAUL IIELVY
MICHAELI. OTONNOR
HEA'T'HER M. FAUST
THE LAW FIRM OF
KILLIAN & GEPHART, LLP
218 PINE STREET
P. O. BOX 886
HARRISBURG, PENNSYLVANIA 17108.0886
TELEPHONE (717) 232-1851
FAX NO. (717) 238.0592
www.killiangephart.com
August 20, 2001
E. Robert Elicker, 11, Esquire
Office of the Divorce Master
Cumberland County Court of Common Pleas
9 North Hanover Street
Carlisle, PA 17013
Re: John E. Mumma P. Maureen Ann Mumma
No. 99-5837; In Divorce (Cumberland Co.)
Dear Master Elicker:
Enclosed you will find my Certification indicating that discovery is not complete
in the above-captioned action.
JPH/ph
Enclosure
cc: Maria P. Cognetti, Esquire
Ms. Maureen Mumma
AUG 212001
I
JOHN E. MUMMA, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99 - 5934 CIVIL
MAUREEN ANN MUMMA,
Defendant IN DIVORCE
TO: Maria P. Cognetti Attorney for Plaintiff
Donald T. Kissinger Attorney for Defendant
DATE: Thursday, July 26, 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:
RRRRR(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.
SEE ATTACHED.
August 20, 2001
Re: John E. Mumma v Maureen Ann Mumma
No. 99-5837; In Divorce (Cumberland Co.)
DEFENDANT'S STATEMENT AS TO THE STATUS OF DISCOVERY
On March 2, 2001, Defendant served Interrogatories and a Request for Production
of Documents upon Plaintiff. To date, the only response which Defendant has received
regarding the Request for Production of Documents is a statement from Plaintiff's
counsel to the effect that there are boxes of documents in her office which Defendant's
counsel may review. Counsel for Defendant has not yet had an opportunity to travel to
Plaintiff's counsel's office to review these documents; however, it is expected that this
will be done in the near future. Plaintiff has not provided a response to the Request for
Production of Documents indicating what documents are not being produced or made
available along with the basis for non-production as required by Pa.R.C.P. 4009.12(b).
With regard to the Interrogatories, Plaintiffs answers are grossly inadequate. For
example, in spite of the fact that Plaintiff is asked (Interrogatory No. 20) to identify any
interest in real property which he has (and there are multiple parcels of real property at
issue in this case), Plaintiff fails to identify the parcels of real property. He simply
indicates that Defendant is to "[s]ee Financial Statements provided in response to
Request for Production of Documents."
When asked whether he owns any artwork with a value in excess of $300
(Interrogatory No. 24), Plaintiff indicates that "[e]verything of value is in possession of
Maureen Mumma," in spite of the fact that he took valuable items of property at the time
the parties separated in 1991.
After reviewing the boxes of documents which are currently at Plaintiffs
counsel's offices, this statement will be updated.
Respectfully submitted,
1% '
a
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
August 20, 2001 1/ 1/
( )
DATE VCCO SEL FORKAINTIFIF
SEL FO DEFENDANT (XX)Q
Paul Helvy, Esq.
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.
THE LAW FIRM OF
KILLIAN & GEPHART, LLP
THOMAS W. SCOTT 218 PINE STREET
JANE CiOWEN PENNY P. O. BOX 886
TERRENCE 1. MCGOWAN HARRISBURG, PENNSYLVANIA 17108.0886
J. PAUL HELVY -- -------- O(CoWwl
MICHAEL. J. O'CONNOR TLLEPHONE (717) 232-1851 JOHN D. KILLIAN
HEATHER M. FAUST FAX NO. (717) 238-0592 SMITH B. GEPHART
www.killiangephart.com
October 8, 2003
Office of the Divorce Master
ATTN: Traci Colyer
Cumberland County Court of Common Pleas
9 North Hanover Street
Carlisle, PA 17013
Re: John E. Mumma v. Maureen Ann Mumma
No. 99-5837; In Divorce (Cumberland Co.)
Dear Traci:
Per our telephone conversation of yesterday, enclosed please find two copies of
the fully-executed Property Settlement Agreement in the above-captioned action. This
matter was bifurcated, and as you can see in Exhibit "A" of the agreement, the Decree in
Divorce was entered on September 20, 2001.
If you need anything further to close your file in this matter, please do not hesitate
to contact our office.
Very truly yours,
Peggy Hile, Secretary to
J. PAUL HELVY, ESQ.
JPH/ph
Enclosures
cc: Maria P. Cognetti, Esquire (w/o enc.)
Ms. Maureen Mumma (w/o enc.)
THE LAW FIRM OF
SMI'HI B. GEPHART KILLIAN & GEPHART, LLP
THOMAS W. SCOTT 218 PINE STREET
JANE GOWEN PENNY P. 0. BOX 886
TP.RRENCEJ. McGOWAN HARRISBURG, PENNSYLVANIA 17108-0886
PAULA L wrimmOIT ---------- Of c...:
1. PAUL HELVY TELEPHONE (717) 232-1851 JOHN D. KILLIAN
MICHAELJ. O'CONNOR FAX NO. (717) 238.0592
HEATHER M. FAUST www.killiangephart.com
January 30, 2003
E. Robert Elicker, II, Esquire
Office of the Divorce Master
Cumberland County Court of Common Pleas
9 North Hanover Street
Carlisle, PA 17013
Re: John E. Mumma v Maureen Ann Mumma
No. 99-5837; In Divorce (Cumberland Co.)
Dear Mr. Elicker:
The following is an effort to clarify the issues involved in the above-captioned
action and to advise you of the expert witnesses which will be called at the hearing
scheduled on March 3 and 4, 2003.
Real Estate. Contrary to Attorney Cognetti's assertion that the parties have agreed
to split the difference on various real estate appraisals, at this time, the only agreement
which the parties have reached regarding real estate value is that the Perry County
property has a value of $39,500. Unless the parties are able to reach an agreement
between now and the date of the hearing, we will be calling Larry Foote to testify
regarding the values of the various items of marital real estate, which include:
Kronenber Building, uilding, 2-8 South Hanover Street, Carlisle;
Exigent Building, 102-Rear Baltimore Ave., Mount Holly Springs;
1255 Claremont Road, Middlesex Township;
740-742 Allen Road/duplex, South Middleton Township; and
Wertzville Road, vacant land (21 acres), Silver Spring Twp.
Jewelry and Furs. The parties have not reached an agreement regarding the value
of the jewelry and firs; consequently, we will be calling the testimony of David Sack of
E. Robert Elicker, II, Esquire
January 30, 2003
Page 2
Jack Kellmer Co. to testify regarding the jewelry. Mr. Sack is from Philadelphia;
consequently, I would prefer to take his testimony telephonically absent an objection
from the Divorce Master or opposing counsel. Ms. Mumma is in the process of getting
one of the furs appraised. We have an agreement on the other four furs in question. I
anticipate calling a furrier from New York City, again telephonically absent an objection,
regarding the fur.
Personalty. We will present the testimony of Dusty Chapman regarding the
appraisal which he had previously conducted.
Debt. Attorney Cognetti notified me via correspondence received in our office on
January 27, 2003, that she has an eight-inch stack of documentation which I can come to
her office and view. I have asked her to provide me with a copy of this documentation.
Once I have had an opportunity to review that documentation, I will be in a position to
indicate exactly what witnesses we will call regarding the issue of the debt associated
with the Kronenberg Building.
IRAs. At this time, it is anticipated that we may be calling David Bihl, CFP, to
testify regarding a current value of those IRAs and CDs which were accumulated during
the course of the marriage.
Insurance policies. We anticipate that David Bihl will also testify regarding the
current value of that portion of the cash value of the insurance policies which
accumulated during the course of the marriage.
Of course, I anticipate presenting the direct testimony of Ms. Mumma and a cross
examination of Mr. Mumma as well.
It is my understanding that we are in the process of scheduling another prehearing
conference to discuss this matter. I look forward to meeting with you and Attorney
Cognetti at that time.
JPH/ph
cc: Maria P. Cognetti, Esquire (via FAX)
Ms. Maureen Mumma
MARIA P. COGNE= & ?Assocums
Attorneys and Counselors at Law Practice Limited to Matrimonial Law
Maria P. Cogneni' Karen A. Sheriff
Altomey at law Paralegal
*Fellow. American Academy or
Matrimonial Lawyers
'Fellow, Inlemational Academy of
Matrimonial lawyers
January 27, 2003
E. Robert Elicker, II, Divorce Master
Cumberland County
9 North Hanover Street
Carlisle, PA 17013
RE. MUMMA v. MUMMA
Our File No. 93
Dear Master Elicker:
Candith Y. Hill
Paralegal
Pursuant to the plan laid out at the October 4, 2002 Pre-Trial Conference, I am writing to
provide you with my list of the expert witnesses I expect to call at the hearing scheduled for
March 3 and 4, 2003.
Real Estate
The parties have agreed to split the difference on the previously obtained real estate
appraisals for the properties located at Claremont Road, Carlisle, Allen Road, Carlisle, and North
Baltimore Avenue, Mount Holly Springs. We will be calling Don Paul Shearer to give expert
testimony concerning the remaining three (3) properties. As a reminder, Defendant previously
concurred with our appraised value for the property located in Perry County.
Jewelry and Furs
To date, the parties have not come to an agreement as to the value of the jewelry and furs
in this case. Therefore, we will be calling Linda Cummingham, from Mountz Jewelers, to give
her expert testimony with respect to the jewelry. We will be calling Charles L. Simpson, Sr.,
from Charles Furriers, to give his expert testimony with respect to the furs.
210 Grandview Avenue, Suite 102 ? Camp Hill, PA 17011
Telephone (717) 909.4060 ? Fax (717) 909-4068
Email CognottiLaw@aol.com
.'%k
.,
E. Robert Elicker, II, Divorce Master
January 27, 2003
Page 2
Personal Property
At this point, the parties have not agreed as to the value of the personal property.
Therefore, we will be calling Erica Wineske, from Cordier Antiques and Fine Art, to give her
expert testimony.
Debt
We have just received the last of the documentation we need to verify the marital debt,
including debt owed by the entity known as Liberty Holding Company. With respect to the debt
owed by Liberty Holding Company to Carlisle Electric, Inc., we will be calling the Custodian of
Records for Carlisle Electric, Inc. to testify with respect to said debt.
IRAs
You may recall from my November 7, 2002 correspondence to you that Mr. Helvy
intended to undertake his own valuation of the IRAs owned by the parties. We continue to await
the results of his valuation to determine whether we will accept his value or pursue our own
valuation. In the event we cannot concur with Mr. Helvy's valuation, it is our intent to jointly
use James Smeltzer, CPA, according to the plan discussed at the Pre-Trial Conference.
I will be taking the direct testimony of the Plaintiff as well as the Defendant on cross-
examination.
Please let me know if there is anything further you require at this time. Your attention to
this matter is, as always, very much appreciated.
Very truly yours
Maria P. Cognetti
MPC/waw
cc: John E. Mumma
J. Paul Helvy, Esquire
MARIA P. CO(uNETTII & ASSOCIATES
Attorneys and Counselors at Law
Maria P. Cognetti•
Attorney at law
'Fellow, American Academy of
Matrimonial Lawyers
'Fellow. International Academy of
Matrimonial Lawyers
November 7, 2002
E. Robert Elicker, 11, Divorce Master
Cumberland County
9 North Hanover Street
Carlisle, PA 17013
RE. MUMMA V. MUMMA
No. 99-5837
Our File No. 93
Dear Master Elicker:
Karen A. Sheriff
Paralegal
Candith Y. Hill
Paralegal
You may recall that, with regard to the above-referenced matter, you had requested that
Attorney Helvy and I get back to you with regard to our respective positions on the various
issues. I believe you had also requested that we submit the discussed Stipulation to you by
sometime in mid-October. Therefore, since we have passed your deadlines, Attomey Helvy and I
thought it would be appropriate to at least get a status letter to you to let you know that we are
working on this matter.
I can therefore advise you of the following:
Should the need arise to go with the concept of a court-
appointed real estate person, the parties have agreed to use
the services of Jeff Walters.
Practice Limited to Matrimonial Law
210 Grandview Avenue, Suite 102 ? Camp Hill, PA 17011
Telephone(717)909-4060 ? Fax (717) 909-4068
Email CognettiLaw@aol.com
E. Robert Elicker,11, Divorce Master
November 7, 2002
Page 2
2. We are discussing the concept of simply splitting the
difference on some of the properties thereby avoiding some
unnecessary work.
3. With regard to the issue of the valuation of the various and
sundry IRAs, Mr. Helvy has undertaken his own valuation.
If that turns out to be unacceptable to the parties, we are
contemplating the use of James Smeltzer, CPA, in that role
as opposed to Mr. Oszustowicz.
4. At this point in time, both of us are in the process of
completing our individual real estate valuation process.
5. Finally, as you know, Mr. Helvy has submitted his Pre-Trial
Statement and the various personal property appraisals are
underway.
If you require any further information from us at this point in time, please feel free to
contact either one of us. Thank you for your assistance in this matter.
Very truly your
Maria P. Co netti
MPC/waw
cc: J. Paul Helvy, Esquire
John E. Mumma
MARIA P. ICOGNETTI & ASSOCIATES
Attorneys & Counselors at Law
210 Gmndvicw Avenue, Suite 102 ? Camp Hill, PA 17011
Telephone (717) 9094060 ? Fax (717) 9094068
Email CogncuiLaw(a?aol.com
Maria P. Cognetti'
Attorney at Law
Practice Limited to Matrimonial Law
Karen A. Sheriff
Paralegal
'Fellow, American Academy of
Matrimonial Lawyers
*Fellow, lntemational Academy of
Matrimonial Lawyers
February 21, 2003
E. Robert Elicker, II, Divorce Master
Cumberland County
9 North Hanover Street
Carlisle, PA 17013
RE: MUMMA v. MUMMA
Our File No. 93
Dear Master Elicker:
Candith Y. Hill
paralegal
Thank you for the use of your conference room and your assistance in moving this matter
towards settlement. I am happy to report that the parties have agreed to the terns of the Property
Settlement Agreement, which we are in the process of drafting.
In that regard, I would ask that you please continue the Master's hearing, scheduled for
March 4 and 5, pending execution of a Property Settlement Agreement. Once accomplished, we
will forward two (2) copies of the executed Property Settlement Agreement to your office.
Very truly yours
Maria Pte. C ldgnetti
MPC/waw
cc: J. Paul Helvy, Esquire (via facsimile)
John E. Mumma
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OFD., PENNA.
? txt.
John E. Mumma
ntiff
N O. 99-5834
Civil
VERSUS
Maureen Ann Mumma
Defendant
AND NOW, ?0 rc,w Zc'
DECREED THAT John E. Mumma
AND Maureen Ann Mumma
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
, PLAINTIFF,
DEFENDANT,
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;
Alimony, Alimony Pendente Lite, and Cousel Fees, Costs, and
Expenses) and Equitable Distribution.
BY THE COURT:
ATTE
DECREE IN
DIVORCE
2001
IT IS ORDERED AND
J.
PROTHONOTARY
74e
MARIA P. COCirNE'II"1 I & ASSOCIATES
Attorneys and Counselors at Law
Maria P. Cognetti•
Attomey at I.aw
'Fellow, American Academy of
Matrimonial Lawyers
August 22, 2001
Mr. Curtis R. Long, Prothonotary
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
RE. MUMMA V MUMMA
Docket No. 99-5837 Civil Term
Our File No. 93
Dear Mr. Long:
Karen A. Sheriff
Paralegal
Christopher T. Zweifel
Paralegal
Pursuant to Judge Hess's Order of August 17, 2001 enclosed please find two (2) original
Divorce Decrees for signing. Once signed, kindly return one of the Decrees to me in the self-
addressed, stamped envelope provided.
Should you have any questions, please do not hesitate to call me. Thank you for your
attention to this matter.
Very truly yours,
A/I-PST /l y(? ;
aren A. Sheriff
Paralegal
Enclosures
cc: John E. Mumma
J. Paul Helvy, Esquire
Practice Limited to Matrimonial Law
210 Grandview Avenue, Suite 102 ? Camp Hill, PA 17011
"telephone (717) 909.4060 ? Pas (717) 909.4068
Email CogneniLaw@aol.com
II 1WpNLCA0IN.Jummx Mv6rc Complum wpd
JOHN E. MUMMA,
Plaintiff
V.
MAUREEN ANN MUMMA,
Defendant
Srymmbr 16, IM
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. qq - g p? y at-,,?L
CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in Court. If you wish to defend against the claims set forth in
the 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 divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is available
in the office of the Prothonotary at the Cumberland County Courthouse, Carlisle,
Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYERIS 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
H \WPTLEAOINGUIUmm. q,9 .. Cumpbim .,d
SeE, .m 16. 1999
JOHN E. MUMMA, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. rev--
MAUREEN ANN MUMMA, CIVIL ACTION -LAW
Defendant IN DIVORCE
COMPLAINT IN DIVORCE
Plaintiff is JOHN E. MUMMA, who has resided at E 112, 1418 Bradley
Drive, Carlisle, Cumberland County, Pennsylvania, for the last eight years.
2. Defendant is MAUREEN ANN MUMMA, who has resided at 55 Green
Ridge Road, Mechanicsburg, Cumberland County, Pennsylvania, for the last sixteen
years.
3. Plaintiff and Defendant have been bona fide residents in the
Commonwealth for at least six (6) months immediately previous to the filing of this
Complaint.
4. The Plaintiff and Defendant were married on March 12, 1963, in Glasgow,
Scotland.
5. There have been no prior actions of divorce or for annulment between the
parties.
Neither of the parties in this action is presently a member of the Armed
if WpWLEAMNG`Mumme Urea Cmnplum rpd &pmmber Id, 1999
Forces.
7. The Plaintiff and Defendant are both citizens of the United States.
8. Plaintiff has been advised of the availability of marriage counseling and that
he may have the right to request the Court to require the parties to participate in such
counseling. Being so advised, Plaintiff does not request that the Court require the parties
to participate in counseling prior to a divorce decree being handed down by the Court.
COUNT I - DIVORCE
9. The Plaintiff avers that the grounds on which the action is based are as
follows:
(a) That Defendant has offered such indignities to the Plaintiff, the
injured and innocent spouse, so as to make Plaintiffs condition burdensome and life
intolerable;
(b) The marriage is irretrievably broken; and
(c) The Plaintiff and Defendant have been living separate and apart for a
period in excess of two (2) years.
COUNT II - EQUITABLE DISTRIBUTION
10. During the marriage, Plaintiff and Defendant have acquired various items of
marital property, both real and personal, which are subject to equitable distribution under
It MpVLE DJ.WdWummc M;mce rMplum wpd
Chapter 35 of the Divorce Code.
WHEREFORE, Plaintiff requests this Honorable Court:
(a) Enter a decree of divorce;
sapmmsm In, 1M
(b) Equitably distribute all property, both personal and real, owned by
the parties; and
(c) Grant such further relief as the Court may deem equitable and just.
Respectfully Submitted,
Dated: September 14, 1999 By:
Sup. Ct. I.D. #27914
200 North Third Street
Twelfth Floor
P.O. Box 689
Harrisburg, PA 17108-0689
(717) 232-2103
COGNETTI & BRADERMAN
/ ??Gta
Maria P. C gnetti E quire
11 \WpTLEADIN(OMumme M;wee Cwnpltlne wpd
Septemb 14. IM
VERIFICATION
1, JOHN E. MUMMA, hereby verify and state that the facts set forth in the
foregoing document are true and correct to the best of my information, knowledge and
belief. I understand that false statements herein are made subject to the penalties of 18
Pa. C.S.A. §4904 relating to unsworn verification to authorities.
/JOHN E. MUMMA
DATE: 9? jy?
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JOHN E. MUMMA, IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 99-693-7- G&Y6k]
MAUREEN ANN MUMMA, CIVIL ACTION -LAW
Defendant IN DIVORCE
AFFIDAVIT OF SERVICE
I, MARIA P. COGNETTI, ESQUIRE, do hereby certify that a true and correct
copy of the Complaint in Divorce was served upon the Defendant by certified mail, return
receipt requested, on the 2401 day of September, 1999. The original signed return receipt,
number P 397 743 725, is attached hereto and made a part hereof.
Sworn to and subs ibed
befo?j e? ??e this / day
ofM_, 1999.
Notary Public
My Commission Expires:
Nomrlel Seel
KW A. Sheriff, Notary Public
FlarAaburp, R7=2=,
My CDmmleelon E 2002
Maria P. Co netti, ire
Sup. Ct. I.D. #27914
200 North Third Street
Twelfth Floor
P.O. Box 689
Harrisburg, PA 17108-0689
(717) 232-2103
Memoer, Ingn"9eenotNotaries
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Nm Recslpl witl allow to wh m the mods was deMmd and the date
M.
I also Moth to receive the
following services (for an
extra fee):
1. ? Addressee's Address
2.'ILI Restricted Delivery
cult poabltaster for f110s6naster fOr fee.
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JOHN E. MUMMA, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
50b'\
V. NO. 99-5634
MAUREEN ANN MUMMA,
Defendant. CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO THE DEFENDANT
If you wish to deny any of the statements set forth in this Affidavit, you must file a
counter-affidavit within twenty (20) days after this Affidavit has been served on you, or
the statements will be admitted.
PLAINTIFF'S AFFIDAVIT UNDER
SECTION 3301(d) OF THE DIVORCE CODE
1. The parties to this action separated on v` /% 90 and have continued to
live separate and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. I understand that I may lose rights concerning alimony, division of property,
attorney's fees or expenses if I do not claim them before a divorce is granted.
I verify that the statements made in this Affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S
4904 relating to unswom falsification lo authorities.
HN E. MUMMA
Date: -2 5 o 0
CERTIFICATE OF SERVICE
I, H. Allison Wright, hereby certify I did serve the following individual in the
following manner with a copy of the within document:
Service By First Class Mail To-
Donald T. Kissinger, Esquire
Howett, Kissinger & Conley, P.C.
130 Walnut Street
P.O. Box 810
Harrisburg, PA 17108
MARIA P. COGNETTI & ASSOCIATES
Attorneys for John E. Mumma
By:
H. Allison Wright
I.D. No. 60311
210 Grandview Avenue, Suite 102
Camp Hill, PA 17011
(717) 909-4060
Date: November 2, 2000
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JOHN E. MUMMA, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. CIVIL ACTION - LAW
NO. 99 - 5834 CIVIL
MAUREEN ANN MUMMA,
Defendant IN DIVORCE
CONFERENCE WITH
COUNSEL AND THE PARTIES
TO: Maria P. Cognetti
John E. Mumma
Counsel for Plaintiff
Plaintiff
J. Paul Helvy
Maureen Ann Mumma
Counsel for Defendant
Defendant
A conference has been scheduled at the Office of
the Divorce Master, 9 North Hanover Street, Carlisle,
Pennsylvania, on the 19th day of February 2003, at 1:30
p.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
February 10, 2003 Divorce Master
IN THE COURT OF COMMON PLEAS OF
JOHN E. MUMMA CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
V.
MAUREEN ANN MUMMA NO. 99 - 5834
IN DIVORCE
ORDER AND NOTICE SETTING HEARING
TO: John E. Mumma
Maria P. Cognetti
Maureen Ann Mumma
J. Paul Helvy
, Plaintiff
, Counsel for Plaintiff
Defendant
, Counsel for Defendant
You are directed to appear for a hearing to take testimony on the outstanding
issues in the above captioned divorce proceedings at the Office of the Divorce Master, 9
North Hanover Street, Carlisle, Pennsylvania, on the 4th & 5th day of
March
2003 at 9:00
a.m., at which place
and time you will be given the opportunity to present witnesses and exhibits in support
of your case.
By the Court,
George 1E.offer, President Jud
Date of Order and
Notice: 10/4/02
By:
Divorce Master
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE, CARLISLE, PA 17013
TELEPHONE (717) 249-3166
OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240-6535
E. Robert Elicker, II
Divorce Master
Traci Jo Colyer
Office Manager/Reporter
April 11, 2002
West Shore
6970371 Ext 6535
Maria P. Cognetti J. Paul Helvy, Esquire
Attorney at Law KILLIAN & GEPHART
210 Grandview Avenue 218 Pine Street
Suite 102 P.O. Box 886
Camp Hill, PA 17011 Harrisburg, PA 17108
RE: John E. Mumma vs. Maureen Ann Mumma
No. 99 - 5834 Civil
In Divorce
Dear Ms. Cognetti and Mr. Helvy:
I have reviewed letters that both counsel provided regarding the
discovery dispute that has arisen regarding various documents and
financial information. I am going to withdraw the directive for pretrial
statements for April 26, 2002, and issue another directive for pretrial
statements to be filed on or before May 28, 2002. 1 expect that both
counsel will either resolve the discovery issues between themselves or
that immediately a petition will be filed with the Court for a discovery
review by one of the judges so that these matters can be laid to rest with
an order directing whatever needs to be done to accomplish the
outstanding general and specific requests of the wife.
Counsel have approximately six weeks to resolve this matter with
the Court and file their pretrial statements. I am not going to be get
bogged down in this office with these discovery issues which will
certainly delay our proceedings. I expect all of these matters to be
resolved by May 28, 2002, consistent with the Court's ability and
Ms. Cognetti and Mr. Helvy, Attorneys at Law
11 April 2002
Page 2
schedule to get the case on its discovery hearing list. The parties have
had more than enough time to address these issues previously. This
case has been pending more than two years.
Very truly yours,
E. Robert Elicker, II
Divorce Master
OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240-6535
E. Robert Ellcker, 11
Divorce Master
Traci Jo Colyer
Office Manager/Reporter
West Shore
697-0371 Ext. 6535
March 27, 2002
Maria P. Cognetti
Attorney at Law
210 Grandview Avenue, Suite 102
Camp Hill, PA 17011
J. Paul Helvy, Esquire
KILLIAN & GEPHART
218 Pine Street
P.O. BOX 886
Harrisburg, PA 17108
RE: John E. Mumma vs.
No. 99 - 5834 Civil
In Divorce
Dear Ms. Cognetti and Mr. Helvy:
Maureen Ann Mumma
Ms. Cognetti has inquired about why we have not moved this case
forward; Mr. Helvy states that there is some incomplete discovery. I have
been waiting for a letter from Mr. Helvy to whom I spoke on the phone
regarding some issues that he needed to have resolved in order to
complete some appraisals.
The parties are divorced and the economic claims preserved in the
decree are alimony, alimony pendente lite, counsel fees, costs, and
expenses, and equitable distribution.
It is my belief that either discovery should be complete or if it is not
complete, then the party that is not being provided the information
requested should file a petition with the Court. The party that is not
providing the information would then be under a Court order to provide
whatever is necessary. My understanding, with talking to both counsel,
is that Mr. Mumma has had appraisals of rental property, Mr. Helvy has
asked for financial data which has not been provided by Mr. Mumma,
and Mrs. Mumma does not want to incur the costs of formal discovery
motions.
Ms. Cognetti and Mr. Helvy, Attorneys at Law
27 March 2002
Page 2
In any event, I am going to direct pretrial statements. If this
discovery issue continues to be a problem, 1 will deal with it before the
pre-hearing conference inasmuch as the pretrial statements will give me
some indication as to what is not yet available.
In accordance with P.R.C.P, 1920.33(b) I am directing each counsel
to file a pretrial statement on or before Friday, April 26, 2002. Upon
receipt of the pretrial statements, I will immediately schedule a pre-
hearing conference with counsel to discuss the issues and, if necessary,
schedule a hearing. Counsel should also note on their pretrial
statements if there are outstanding discovery issues so I can deal with
those issues prior to the conference.
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.
JOHN E. MUMMA, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 99 - 5834 CIVIL
MAUREEN ANN MUMMA,
Defendant IN DIVORCE
NOTICE OF PRE-HEARING CONFERENCE
TO: Maria P. Cognetti , Attorney for Plaintiff
J. Paul Helvy , 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 4th day of October 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: 7/15/02 E. Robert Elicker, II
Divorce Master
44
OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240-6535
E. Robert Elicker, 11
Divorce Master
Traci Jo Colyer
Office Manager/Reporter
West Shore
697-0371 Ext. 6535
May 6, 2002
Maria P. Cognetti
Attorney at Law
210 Grandview Avenue
Suite 102
Camp Hill, PA 17011
J. Paul Helvy, Esquire
KILLIAN & GEPHART
218 Pine Street
P.O. Box 886
Harrisburg, PA 17108
RE: John E. Mumma vs. Maureen Ann Mumma
No. 99 - 5834 Civil
In Divorce
Dear Ms. Cognetti and Mr. Helvy:
The directive for pretrial statements to be filed on May 28, 2002, is
withdrawn.
When both counsel certify that discovery is complete, I will redirect
the filing of pretrial statements.
Very truly yours,
E. Robert Elicker, II
Divorce Master
%WTSnT'-jy" %Cf[mOi,maryUfomma.PpleWiny,VYa..4 SWamen,wpd
MARIA P. COGNETTI & ASSOCIATES
MARIA P. COGNETTI, ESQUIRE
Attorney I.D. No. 27914
210 Grandview Avenue, Suite 102
Camp Hill, PA 17011
Telephone No. (717) 9094060
Attorneys for Plaintiff
JOHN E. MUMMA,
Plaintiff
vs.
MAUREEN ANN MUMMA,
Defendant
7/I
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-50
CIVIL ACTION - LAW
IN DIVORCE
PLAINTIFF'S PRE-TRIAL STATEMENT
John E. Mumma, Plaintiff, by and through his attorney, Maria P. Cognetti, Esquire, files
the following Pre-Trial Statement:
TABLE OF CONTENTS
1. Background Information
II. Listing of Marital Assets and Debts
III. Listing of Personal Property
IV. Listing of Non-Marital Assets
V. Listing of Non-Marital Debt
VI. Pensions
VII. Income and Expenses
VIII. Counsel Fees and Costs
IX. Expert Witnesses
X. Non-Expert Witnesses
Xl. Listing of Proposed Exhibits
XII. Outstanding Discovery Issues
XIII. Proposed Resolution
1WSRV'.mM L.wWr.m u.Kr..me siaanani .,A
1. BACKGROUND INFORMATION
A. PARTIES
7/4102
HUSBAND Plaintiff
NAME John E. Mumma
ADDRESS P. O. Box 158, Carlisle, PA 17013
AGE 60
DATE OF BIRTH October 8, 1941
PLACE OF BIRTH Greencastle, PA
SOCIAL SECURITY NUMBER 198-32-7931
HEALTH Fair
EMPLOYER Carlisle Electric, Inc.
OCCUPATION Contractor
LENGTH OF RESIDENCY IN PA Since birth (except time spent in military)
EDUCATIONAL BACKGROUND 4 years of college
WIFE nt
NAME A. Mumma
ADDRESS n Ridge, Mechanicsburg, PA 17055
AGE
DATE OF BIRTH R
3, 1942
PLACE OF BIRTH , Scotland
SOCIAL SECURITY NUMBER 166
HEALTH
EMPLOYER Inc.
OCCUPATION of Exigent, Inc.
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LENGTH OF RESIDENCY IN PA Since 1964
EDUCATIONAL BACKGROUND 2 years of college
B. CHILDREN
NAME AGE DATE OF BIRTH CUSTODIAN
NONE
C. MARRIAGE INFORMATION
DATE OF MARRIAGE March 14, 1963
PLACE OF MARRIAGE Glascow, Scotland
DATE OF SEPARATION July, 1990
CIRCUMSTANCES OF SEPARATION Husband moved from marital residence
D. PRIOR MARRIAGE
I WIFE I
1HUSBAND 0
E. CHILDREN OF OTHER RELATIONSHIPS/MARRIAGES
WIFE None
1HUSBAND None
F. PROCEEDINGS INFORMATION
DATE ACTION COMMENCED September 22, 1999
DATE OF SERVICE OF COMPLAINT September 24, 1999
I
0
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7/02
SERVICE OF U.S. Certified Mail
ED IN DIVORCE
P 3301(c) & 3301(d) Divorce, and Equitable
Distribution
DATEAMENDED
COMPLAINT N/A
FILED
ISSUES RAISED IN AMENDED N/A
COMPLAINT
DATE OF FILING OF ANSWER November 27, 2000
AND/OR COUNTERCLAIM
ISSUES RAISED IN COUNTERCLAIM Divorce, Equitable Distribution, Alimony,
Alimony pendente lite, Counsel Fees and
Costs.
BIFURCATION GRANTED August 17, 2001
PREVIOUSLY RESOLVED ISSUES Divorce
II. MARITAL ASSETS AND DEBTS
The following is a listing of the marital assets and debts of the parties:
ITEM DESCRIPTION TOTAL HUSBAND'S WIFE'S COMMENTS
NO. VALUE POSSESSION POSSESSION
: w
?eab?state <f -? 1f 9 i (?
t
?
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,
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tl
IA. 55 Greenridge 745,000.00 745,000.00 Appraised
Rd. Mech. PA 7/20/00
IB. 1255 Claremont 385,000.00 385,000.00 Appraised
Rd., Carlisle, PA 5/26/00
1C. 740-742 Allen 115,000.00 115,000.00 Appraised
Rd., S. 5/26/00
Middleton Twp.
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ITEM DESCRIPTION TOTAL HUSBAND'S WIFE'S COMMENTS
NO. VALUE POSSESSION POSSESSION
1D. Kronenberg 850,000.00 850,000.00 Appraised
Bldg. (Titled to 5126100.
Liberty Holding $1,043.108.10
Co: parties have debt against
50% interest) this property
IE. 102-R N. 98,000.00 98,000.00 Appraised
Baltimore Ave., 6/9/00
Mt. Holly
Springs, PA
(Titled to
Exigent, Inc)
IF. Perry County 39,500.00 39,500.00 Appraised
Acreage 6/1/00
1G. 4A-4G Kevin 320,000.00 320,000.00 Appraised
Rd., Mech., PA 6/13/00-
conveyed
from joint to
Wife.
1H. Wertzville Rd. 158,000.00 158,000.00 Appraised
Acreage, Mech., 6/9/00-
PA conveyed
from joint to
Husband.
t t $alaC Accb1111tS ?t
,
r ?,,,, r .
2A.* York Federal 16,781.50 16,781.50 On 11/28/98
CD #2436
2B.* York Federal 35,230.60 35,230.60 On 6/16/98
CD #5539
2C.* Allfirst Joint Ck. 1160.85 1160.85 on 1/4/01, as
per Wife
2D.* M&'r Joint Ck. 1,504.04 1504.04 on DOS, as
per Wife
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1/4103
ITEM DESCRIP'r10N TOTAL HUSBAND'S WIFE'S COMMENTS
NO. VALUE POSSESSION POSSESSION
2E.* PNC Joint Ck. 200.00 200.00 on 1/01, as
per Wife
o-
? skopw
.
;,.X:,,
ga?44tr1x Brokerage ; n ?';
3A. 400 shares of 14,320.00 14,320.00 on 5/30/02
PP&L
3B.* Municipal 901.00 901.00 On 5/4/01 - as
Investment Trust per Wife
r?\a ,
4A.* York Federal 5,378.26 5,378.26 on 3/21/01
800-057044
4B.* York Federal 7,214.82 7,214.82 on 10/21/00
110-52166
4C.* Americhoice 44,099.03 44,099.03 In 2/01 -
(4 CDs) Rolled from
Allfirst-(W)
4D.* American Funds 16,316,96 16,316.96 6/5/02-
Rolled from
Allfirst-(W)
4E.* PNC Bank 17,901.37 17,901.37 on 5/21/02
4F.* First Union 2,105.60 2,105.60 on 12/31/00
Bank
4G.* York Federal 0 0 Rolled over
43314 and 7576 by Husband
to Legg
Mason
account, then
rolled over to
Amex
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ITEM
NO DESCRIPTION TOTAL HUSBAND'S WIFE'S COMMENTS
. VALUE POSSESSION POSSESSION
4H.* York Federal 0 0
Rolled over
by Husband
to Legg
Mason then
Amex Fund
4I.* Harris Savings 0 0
Rolled over
by Wife to
Cap. Mgmt.,
on 6/98
4J.* Franklin Utilities 17,635.22 17,635.22
On 3/31/02
4K. Allfirst 0 0
(formerly 1'1 Wife
National Bank of reinvested in
Maryland American
#8-700.616- Funds
7135132)
4L. Allfirst 0 0
(formerly I" Wife
National Bank of reinvested in
Maryland Americhoice
#712332,
7127506,
72699068 and
7312419)
4M.* Capital
Management 15,345.59
15,345.59
On 12/31/98-
Company Rolled over
from Harris
(Wife's
discovery
Household responses)
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SCRIP'T'ION TOTAL HUSBAND'S WIFE'S COMMENTS
VALUE POSSESSION POSSESSION
ff Deposit 0
Box-Farmers Contents are
t valued
elsewhere
herein.
5B. Safe Deposit 0
Box-PNC Bk. Contents are
valued
elsewhere
herein.
5C. Furnishings (in
Wife's Appraisal has
possession) been
conducted.
We are
awaiting
report.
5D. Jewelry (in
Wife's Wife has
declined
possession) request that
she submit
property for
appraisal by
Husband's
appraiser.
5E. Furs (in Wife's
possession) Wife has
declined
request that
she submit
property for
appraisal by
Husband's
x''?;
?tfe Insurance
"' ??1 appraiser.
"?;3
6A.* Prudential
Awaiting
information.
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ITEM DESCRIPTION TOTAL HUSBAND'S WIFE'S COMMENTS
NO. VALUE POSSESSION POSSESSION
6B.* Metropolitan Awaiting
information.
6C.* Provident 95,842.67 95,842.67 On 8/20/01
Mutual
r,? 13ustnesses Nu,F
7A. CEI, Inc. - (Wife Wife
possesses 1994 relinquished
Honda owned by her interest in
CEI, Inc.) this business
by agreement.
7B. Exigent, Inc. To be valued.
7C. Liberty Holding 0 Only value is
Co. real estate
previously
listed.
?r -,2 `Marital Debt w r w
8A. Mid Penn 764,679.98 764,679.98 3/22/01
#162867 (Kronenberg
(Held in name of Building)
Liberty Holding
Company-
parties have 50%
interest)
8B. Mid Penn 75,774.15 75,774.15 3/22/01
#0165670 (Kronenberg
(Held in name of Building)
Liberty Holding
Company-parties
have 50%
interest)
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ITEM DESCRIPTION TOTAL HUSBAND'S WIFE'S COMMENTS
NO. VALUE POSSESSION POSSESSION
8C. CEI, Inc. 187,594.00 187,594.00 6/18/02
(Liberty
Holding Co -
Kronenburg
Bldg.-parties
have 50%
interest)
8D. Novinger, Inc. 10,366.00 10,366.00 6/18/02
(Liberty
Holding Co.-
Kronenburg
Bldg. parties
have 50%
interest)
8E. Kelly Drywall 4,694.00 4,694.00 6/18/02
(Liberty
Holding Co.-
Kronenburg
Bldg: parties
have 50%
interest)
8F. Mid Penn 56,452.64 56,452.64 3/22/01
#0465546 (Allen Rd.)
Updated information requested, not received.
III. LISTING OF PERSONAL PROPERTY
ITEMS RETAINED BY HUSBAND
DESCRIPTION VALUE
None
?evrsxw.m;iy L,w?aiam n.,nmrv?swmm.n?tr,a?..nr?.?.?.i summam.ry
IV
L.NI
The followin g is a listing of the non-marital assets of the parties:
Description Basis of Exclusion Owner
107 N. Hanover St., Purchased post Husband
isle, PA separation
S. Hanover St., Purchased post Husband
sle, PA separation
F
e & Springfield Purchased post Husband
rly separation
Main St., Newville Purchased post Husband
separation
Bradley Dr., D213, Purchased post Husband
le, PA separation
Bradley Dr., El 12, Purchased post Husband
le PA separation
LISTING OF NON-MARITAL PROPERTY
\WpSRW--11 I.--WW-1 DnttuxyUlumm. Ap1.d,np1'mutl Sbmmrm wpd
]/4102
No. Description Basis of Exclusion Owner
7. (3) Mid Penn Checking Opened post Husband
Accounts separation
8. 333 Landisburg Road, Purchased post Husband and Janice
Shermansdale, PA separation Charette.
9. Business Partnership - Acquired post 50% Husband
LSP separation (1995) 50%J. Michael
Adler
10. Lawsuit Initiated post Husband
separation
11. Edward Jones single Opened post Husband
account separation
12. Edward Jones IRA Opened Post Husband
separation
13. Legg Mason Brokerage Opened Post Husband
account separation
14. American Express Opened post Husband
Financial Advisors separation
V. LISTING OF NON-MARITAL DEBT
No. Description Amount Basis of Exclusion Owner
l . Mid Penn Note 177,137.84 Obtained post Husband
#0165027 for 105/107 N. on 3/28/01 separation to
Hanover St., Carlisle, PA purchase non marital
property
2. Mid Penn Note 87,684.61 Obtained post Husband
#0165019 for 225 S. on 3/28/01 separation to
Hanover St., Carlisle, PA purchase non marital
property
mvrsuv"y law\CLmronKio,r?+?mm, nlindinymlm,ja snvmem .p
71Ln
3. Mid Penn Note 304,529,53 Obtained post Husband
#0165704 for Glebe on 3/28/01 separation to
Apartments purchase non marital
property
4. Mid Penn Note 19,632.58 Obtained post Husband
#0165043 for E 112 on 3/28/01 separation to
Bradley Dr., Carlisle, PA purchase non marital
property
5. Mid Penn Note 29,359.49 Obtained post Husband
#500012638 for separation to
Landisburg Rd., purchase non marital
Shermansdale, PA property
6. Mid Penn Note
#400005690 as a 9,250.51 Obtained post Husband
personal loan separation
7. M & T Bank Note 24,105.46 Obtained post Husband
#202822300 for D213
Bradley Dr., Carlisle, PA separation to
purchase non marital
property
8. Halifax Bank Note 284,405.57 Obtained post Husband
#81057 for 333
Landisburg Rd separation to and Janice
,
Shermansdale
PA purchase non marital Charette
, property
VI. PENSIONS
The following is a listing of the pensions of the parties:
PARTY
Husband
Wife
DESCRIPTION
None
None
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VII. INCOME AND EXPENSES
The following is a listing of the income and expenses of the parties:
7102
PARTY DESCRIPTION AMOUNT
Husband
Gross Monthly Income $8,483.34
Net Monthly Income 6,511.48
Monthly Expenses 7,815.28
Wife
Gross Monthly Income Unknown to Husband
Net Monthly Income Unknown to Husband
Monthly Expenses Unknown to Husband
VIII. COUNSEL FEES AND COSTS
The following is a listing of the counsel fees and expenses incurred, or to be
incurred by the parties:
PARTY DESCRIPTION DATES AMOUNT
Husband
Counsel Fees $14,540.50
Costs 7,323.00
Anticipated Fees 15,000.00
Anticipated Costs 20,000.00
Wife
Counsel Fees Unknown
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7/"2
PARTY DESCRIPTION DATES AMOUNT
Costs
Unknown
Anticipated Fees and Costs Unknown
IX. EXPERT WITNESSES
The following is a listing of the anticipated experts who will be called to testify in
this case:
NAME
Real Estate Appraiser
Jewelry Appraiser
Personal Property Appraiser
Fur Appraiser
Business Valuator
SUBJECT TO TESTIMONY
Value of parties' various real estate holdings
Value of parties' various pieces ofjewelry
Value of parties' furnishings, collectibles and art
Value of a number of furs
Value of various business interests, ifnecessarv
Additional experts who may be called to testify are not known at this time. If
such additional experts are retained, the Plaintiff reserves the right to call them as
witnesses upon proper notification to the Defendant.
X. NON-EXPERT WITNESSES
NAME SUBJECT TO TESTIMONY
John E. Mumma History of the marriage; identification and
valuation of marital assets and debts; other
relevant testimony relating to the factors set forth
in the Divorce Code.
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9(492
NAME SUBJECT TO TESTIMONY
Maureen A. Mumma, as of cross History of the marriage; identification and
valuation of marital assets and debts; other
relevant testimony relating to the factors set forth
in the Divorce Code.
Additional witnesses who may be called to testify are not known at this time. If
such additional witnesses are identified, the Plaintiff reserves the right to call them as
witnesses upon proper notification to the Defendant.
XI. LISTING OF PROPOSED EXHIBITS
The following is a listing of Exhibits which are anticipated to be submitted at the
hearing in this case:
NO. DESCRIPTION
1 Plaintiffs Income and Expense Statement
2 Plaintiffs Counsel Fees Statements
3 Plaintiffs 2001 W-2 Statements
4 Defendant's Income and Expense Statement
5 Copies of all Real Estate Appraisals
6 Copy of Jewelry Appraisal
7 Copy of Fur Appraisal
8 Copy of Personal Property Appraisal
9 Documentation of PP&L stock values
10 CEMI Stock Certificates
11 Traffic Control Systems Inc. Stock Certificates
12 Documentation of Municipal Investment Trust Fund
.1
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NO. DESCRIPTION
13 Documentation of Legg Mason Account
14 Documentation of Amex Account value
15 Documentation of Edward Jones Account value
16 Documentation of First Union Bank IRA Account value
17 Documentation of Harris Savings IRA account rollover
18 Documentation of Franklin Utilities Fund value
19 Documentation of York Federal CD value
20 Documentation of Allfirst Bank Checking Account value
21 Documentation of M&T Bank Checking Account value
22 Documentation of PNC Checking Account value
23 Documentation of Prudential Life Insurance Policies and cash values
24 Documentation of Metropolitan Life Insurance Policies and cash values
25 Documentation of Provident Mutual Life Insurance Policies and cash values
26 Documentation of Exigent, Inc. value
27 Documentation of Liberty Holding Company value
28 Documentation of CEI value
29 Agreement of the Parties with regard to CEI, Inc.
rties with regard to CEMI, Corp.
30 AgreemelfA
31 Agreemerties with regard to the Wertzville Road property
32 Agreemerties with regard to the Kevin Road Apartments
33 Documenork Federal IRA Account value
34 Documenllfirst Bank IRA Accou
nt value
35 Documenapital Management Company IRA Account value
36 DocumenC Bank IRA Account value
7/493
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7/"2
NO. DESCRIPTION
37 Individual Tax Returns of Wife
38 Individual Tax Returns of Husband
39 Individual Joint Tax Retuns
40 Corporate Tax Returns for Exigent, Inc.
41 Corporate Tax Returns for CEI
42 Partnership Tax Returns for Liberty Holding Company
If additional exhibits are identified, Plaintiff reserves the right to submit
additional Exhibits upon proper notification to Defendant.
XII. OUTSTANDING DISCOVERY ISSUES
A. Plaintiff has made contact with experts qualified to appraise personal
property, jewelry and furs. Personal property has been inspected and a report is being
prepared. To date, Defendant has been uncooperative with providing jewelry and furs for
appraisal.
B. Wife is in sole control and possession of all information pertaining to the
parties' various IRA accounts, life insurance policies, Exigent Inc., bank accounts, and
Certificates of Deposit. It will be necessary for Wife to supplement discovery with
updated values and supporting documentation.
XIII. PROPOSED RESOLUTION
A. EQUITABLE DISTRIBUTION
Plaintiff proposes a 50150 division of marital property.
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B. ALIMONY
Plaintiff proposes no award of alimony.
C. COUNSEL FEES AND COSTS
Plaintiff proposes no award of counsel fees.
714M
Respectfully Submitted:
MARIA P. COGNETTI & ASSOCIATES
Date: July 3 , 2002 By: X4L ?i
MARIA P. OGN 1, ESQUIRE
Attorney I.D. No. 27914
210 Grandview Avenue, Suite 102
Camp Hill, PA 17011
Telephone No. (717) 909.4060
Attorney for Plaintiff
VERIFICATION
1, John E. Mumma, hereby verify and state that the facts set forth in the foregoing
document are true and correct to the best of my information, knowledge and belief. I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to
unswom verification to authorities.
John E. Mumma
Date: -71 a/UZ
f
t
\MSDWMIi 1AWT1jml OiaionWum -AOlad,n ITFMIW Suamen, wpd 7/02
CERTIFICATE OF SERVICE
1, Maria P. Cognetti, Esquire, Attorney for Plaintiff herein, do hereby certify that
on this date I served the foregoing Plaintiffs Pre-trial Statement by depositing a true and
exact copy thereof in the United States mail, first class, postage prepaid, addressed as
follows:
J. Paul Helvy, Esquire
KILLIAN & GEPHART
218 Pine Street
Harrisburg, PA 17101
MARIA P. COGNETTI & ASSOCIATES
Date: July , 2002 By:
MARIA P. C GNE T , ESQUIRE
Attorney I.D. No. 27914
210 Grandview Avenue, Suite 102
Camp Hill, PA 17011
Telephone No. (717) 909-4060
Attorney for Plaintiff
:.
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MARIA P. COGNETTI & ASSOCIATES
MARIA P. COGNETTI, ESQUIRE
Attorney I.D. No. 27914
210 Grandview Avenue, Suite 102
Camp Hill, PA 17011
Telephone No. (717) 909-4060
Attorneys for Plaintiff
JOHN E. MUMMA, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 99-583Y c;,,.l
MAUREEN ANN MUMMA,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE TO WITHDRAW MOTION FOR SANCTIONS
AND TO COMPEL APPRAISALS
TO THE PROTHONOTARY:
Kindly withdraw, on behalf of John E. Mumma, Plaintiff herein, the Motion for Sanctions
and to Compel Appraisals hereto filed in this matter on September 3, 2002 and for which a
hearing is currently scheduled for January 3, 2003.
Date: November °'? 7 , 2002 By:
Respectfully Submitted:
MARIA P. COGNETTI & ASSOCIATES
MARIA 9. COGtEE TI, ESQUIRE
Attorney I.D. No. 27914
210 Grandview Avenue, Suite 102
Camp Hill, PA 17011
Telephone No. (717) 909-4060
Attorney for Plaintiff
CERTIFICATE OF SERVICE
I, Maria P. Cognetti, Esquire, Attorney for Plaintiff herein, do hereby certify that on this
date I served the foregoing Praecipe to Withdraw Motion for Sanctions and to Compel
Discovery, by depositing a true and exact copy thereof in the United States mail, first class,
postage prepaid, addressed as follows:
J. Paul Helvy, Esquire
KILLIAN & GEPHART
218 Pine Street
Harrisburg, PA 17101
MARIA P. COGNETTI & ASSOCIATES
Date: November 02 7 , 2002
MARIA P. COGILf I & ASSOCIATES
Attorney I.D. No. 27914
210 Grandview Avenue, Suite 102
Camp Hill, PA 17011
Telephone No. (717) 909-4060
Attorney for Plaintiff
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°A
JOHN E. MUMMA,
Plaintiff
vs.
MAUREEN ANN MUMMA,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
No. 99-583Y
CIVIL ACTION - LAW
IN DIVORCE
ORDER OF COURT
AND NOW, to wit, this t I °' day of 6M,6 u , 2002, upon consideration of
Plaintiffs Motion for Hearing, the hearing previously scheduled for November 25, 2002, at
10:00 AM, is rescheduled to the 3`a day of January, 2003, at 9:30 o'clock AM in Courtroom
Number 4, located at the Cumberland County Courthouse, Carlisle, Pennsylvania.
BY THE COURT:
The 136norable Kevin A. Hess
r-
NI[. RIA P. (COGNE TTI & A sSOC><ATES
Attorneys and Counselors at Law
Maria P. Cognetti•
Attorney at Law
Leigha M. Jennings
Attorney at Law
-Fellow, American Academy of
Matrimonial Lawyers
'Fellow, Inlemeliona! Academy of
Matrimonial Lawyers
October 17, 2002
The Honorable Kevin A. Hess
ATTENTION: Robbie
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
RE. MUMMA v. MUMMA
No. 99-5837
Our File No. 93
Dear Robbie:
Karen A. Sheriff
Paralegal
Candith Y. Hill
Paralegal
Enclosed please find three (3) original copies of an Order of Court which reflects the
rescheduled time for the hearing, previously scheduled for November 25, 2002 at 10:00 AM,
now scheduled for January 3, 2003 at 9:30 AM.
I am also enclosing a self-addressed, stamped envelope for your convenience in returning
a Court-conformed copy to me and a stamped envelope pre-addressed to opposing counsel for
your convenience in returning a conformed copy to him as well.
Please let me know if there is anything further you require. Your attention to this matter
is very much appreciated.
Very truly yours,
Candith Y. Hill
Paralegal
CYH/waw
Enclosures
cc: John E. Mumma (w/o enclosures)
Practice Limited to Matrimonial Law
210 Grandview Avenue, Suite 102 • Camp Hill, PA 17011
Telephone (717) 909-4060 ? Fax (717) 909-4068
Email CognettiLaw n aol.com
JOHN E. MUMMA, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. No. 99-583/
MAUREEN ANN MUMMA, CIVIL ACTION - LAW
Defendant IN DIVORCE
ORDER OF COURT
AND NOW, to wit, this day of ( C.L?D ?CEh? 2002, upon consideration
of the foregoing Motion for Hearing, a hearing is scheduled for the d 5th day of j ,.1 yn oti
2002, at lU :Vv o'clock _(?,.m. in Courtroom No. _ , located at the Cumberland
County Courthouse, Carlisle, Pennsylvania.
BY THE COURT:
A
Y
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?o .
yam) ?q
D
MARIA P. COGNETTI & ASSOCIATES
MARIA P. COGNETTI, ESQUIRE
Attorney I.D. No. 27914
210 Grandview Avenue, Suite 102
Camp Hill, PA 17011
Telephone No. (717) 9094060
Attorneys for Plaintiff
JOHN E. MUMMA, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. : No. 99-5837
MAUREEN ANN MUMMA, CIVIL ACTION - LAW
Defendant IN DIVORCE
MOTION FOR HEARING
AND NOW, comes Plaintiff, John E. Mumma, by his attorney, Maria P. Cognetti,
Esquire, and moves the Court to enter an Order setting the case for hearing and respectfully
represents that:
Plaintiff is John E. Mumma, who currently resides at 333 Landisburg Road,
Shermans Dale, Pennsylvania.
2. Defendant is Maureen Ann Mumma, who currently resides at 55 Green Ridge
Road, Mechanicsburg, Pennsylvania 17050.
3. On or about September 22, 1999, Plaintiff filed a Complaint in Divorce to the
above term and number. Said Complaint contained a claim for equitable distribution.
4. On September 2, 2002, Plaintiffs attorney filed a Motion for Sanctions to Compel
Appraisals in which he requested that Defendant be directed to cooperate with the appraisal of
the marital jewelry and furs which are subject to equitable distribution in this matter.
This Court issued a Rule to Show Cause on September 9, 2002 with a Rule
returnable of 20 days from service.
6. On or about September 27, 2002, Defendant's Answer to Plaintiffs Motion for
Sanctions and to Compel Appraisals was filed with the Court.
Based on Plaintiffs Motion for Sanctions and to Compel Appraisals, he is
requesting that this Court schedule a hearing on this matter.
WHEREFORE, Plaintiff prays this Honorable Court enter an Order setting this matter for
hearing.
Respectfully Submitted:
MARIA P. COGNETTI & ASSOCIATES
Date: October 3 , 2002 By:
MARIA . COG E TI, ESQUIRE
Attorney L D. No. 914
210 Grandview Avenue, Suite 102
Camp Hill, PA 17011
Telephone No. (717) 909-4060
Attorney for Plaintiff
CERTIFICATE OF SERVICE
I, Maria P. Cognetti, Esquire, Attorney for Plaintiff herein, do hereby certify that on this
date I served the foregoing Motion for Hearing by depositing a true and exact copy thereof in the
United States mail, first class, postage prepaid, addressed as follows:
J. Paul Helvy, Esquire
KILLIAN & GEPHART
218 Pine Street
Harrisburg, PA 17101
MARIA P. COGNETTI & ASSOCIATES
Date: October -4 , 2001 By:
MARIA P.7COGNK*I, ESQUIRE
Attorney I.D. No. 27914
210 Grandview Avenue, Suite 102
Camp Hill, PA 17011
Telephone No. (717) 909-4060
Attomey for Plaintiff
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MA10A P. COGNE-171 6 ASSOCIATES
AuornCI's and Counselors a/ Lau'
210 Grandview Avenue, Suite 102
Camp Iiill, PA 17011
(717) 909-4060 Fax(717)909-4068
JOHN E. MUMMA,
Plaintiff
V.
MAUREEN ANN MUMMA,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-W S&Y
CIVIL ACTION - LAW
IN DIVORCE
DEFENDANT'S ANSWER TO PLAINTIFF'S
MOTION FOR SANCTIONS AND TO COMPEL APPRAISALS
AND NOW comes the Defendant, Maureen Ann Mumma, by and through her
counsel, Killian & Gephart, LLP, and hereby answers Plaintiff's Motion for Sanctions
and to Compel Appraisals as follows:
I . Denied as stated. It is denied that the Plaintiff, John E. Mumma, resides at
P.O. Box 158, Carlisle, Pennsylvania. To the contrary, Mr. Mumma resides with his
paramour at 333 Landisburg Road, Shennans Dale, Pennsylvania.
2. Denied as stated. Defendant's correct address is 55 Green Ridge Road,
Mechanicsburg, Pennsylvania 17050.
3. Denied. It is specifically denied that the parties were married on March 12,
1963. To the contrary, the parties were married on March 14, 1963.
4. Admitted.
5. Admitted.
6. Admitted. By way of further answer, in spite of the fact that counsel for
Plaintiff certified that discovery was complete on August I, 2001, Plaintiff served a
Request for Production of Documents (Second Set) dated April 23, 2002, upon
Defendant and has continued to assail the Defendant with requests regarding the
valuation of the parties' personalty. A copy of Plaintiffs certification that discovery is
complete is attached hereto and marked as Exhibit A.
7. Denied as stated. Defendant's discovery certification is attached hereto and
marked as Exhibit B.
8. Admitted.
9. Denied as stated. After receiving opposing counsel's fallacious
certification that discovery was complete, the Master directed the parties to file pretrial
statements. On April 4, 2002, counsel for the Defendant forwarded correspondence to
the Master outlining the significant amount of information which had not been provided
to Defendant's counsel to date. On April 11, 2002, the Master indicated that the parties
should file their pretrial statements by May 28, 2002.
10. Admitted. By way of further answer, the Master issued a determination on
May 6, 2002, that "the directive for pretrial statements to be filed on May 28, 2002, is
withdrawn." Since the issuance of that determination, the Master has not directed the
parties to file pretrial statements.
11. Admitted.
12. Denied as stated. Although it is admitted that the Defendant has not filed a
pretrial statement with the Master, it is specifically denied that this fact constitutes a
"failure" on the part of the Defendant in that, as of the filing of this answer, there is no
directive from the Master to file a pretrial statement.
13. Admitted.
14. Admitted in part and denied in part. It is admitted that the parties own
substantial real estate. It is denied that the personal property, jewelry and furs which the
parties own is "substantial" given the overall value of the marital estate.
15. Admitted in part and denied in part. It is admitted that the Plaintiff has
completed real estate appraisals. It is further admitted that the Plaintiff has taken steps to
get the personalty appraised. It is specifically denied that the personalty is of
"considerable value."
16. Admitted.
17. Admitted.
18. Admitted.
19. Admitted.
20. Admitted.
21. Admitted.
22. Admitted.
23. Denied as stated. Counsel for Plaintiff fails to inform the court that while
3
the parties were communicating regarding the appraisal of the furs and jewelry, there was
also significant cooperation on the part of the Defendant with regard to the appraisal of
the personal property. Via Plaintiffs counsel's correspondence dated June 14th (Exhibit
F, Plaintiffs Motion), which did not arrive in Defendant's counsel's office until June
18th, Defendant was advised for the first time that the Plaintiff, who had vacated the
marital residence in 1991, planned on being present for the appraisal of the personalty.
This came as quite a surprise and shock to the Defendant. In Defendant's counsel's June
19th correspondence (Exhibit G, Plaintiffs Motion), wherein counsel for the Defendant
asked Plaintiff to behave himself at the appraisal, Plaintiff was advised that the
Defendant wished to deliver the jewelry and furs to the appraisals. It was explained that
rather than imposing a hardship on anyone, it would avoid the necessity of having an
appraiser or anyone else pick up the jewelry and furs, deliver them to the appraisal, and
then deliver them back to the Defendant.
24. Admitted.
25. Admitted.
26. Admitted.
27. Admitted. By way of further answer, on June 21, 2002, David Cordier's
assistant, Erica Wineske, returned to the Defendant's residence and spent several hours
during which the Defendant believed that the appraisal of the personal property was
4
completed. Consequently, any allegation that the Defendant has been less than
cooperative with the Plaintiffs efforts to appraise the personal property simply have no
foundation in fact.
28. Denied as stated. It is specifically denied that any property of any value
whatsoever was not available to be appraised cn June 20, 2002, when David Cordier and
his assistant conducted an inspection of the personal property.
29. Denied as stated. It is admitted that after fully cooperating with Plaintiffs
personalty appraiser, Defendant was again contacted by the same appraiser who asked to
come back yet another day. It was at this point that Defendant indicated that further
inquiries should be made through her counsel.
30. Admitted in part and denied in part. It is admitted that Plaintiff directed
correspondence providing a list of the property that needed to be inspected. It is
specifically denied that what has been attached as Exhibit J to Plaintiffs Motion is a full
and complete copy of that correspondence. Attached hereto and marked as Exhibit C is
the actual list of items which are to be appraised. A review of this list makes it clear that
there is nothing of any significant value which has not been appraised and that Plaintiffs
efforts to again gain access to the Defendant's home are for no other reason than to
harass and annoy the Defendant.
31. Admitted.
32. Although counsel for the Defendant has not conducted an investigation
into the qualification and reputation of Tanya Ulsh, it is admitted that she is ajewelry
appraiser.
33. Although counsel for the Defendant has not conducted an investigation
into the qualification and reputation of Charles E. Simpson. Jr., it is admitted that he is a
fur appraiser.
34. After reasonable investigation, Defendant does not have sufficient
knowledge to admit or deny this averment.
35. Denied. It is specifically denied that there has been no effort made by nor
cooperation received from the Defendant in completing the appraisals ol'thejewelry and
the furs. To the contrary, the Plaintiff has been advised on numerous occasions that the
Defendant would be happy to deliver the furs and the jewelry to the appraisals so that
they can be appraised so long as she is given the opportunity to keep the jewelry and the
furs in sight. For reasons which are inexplicable to the Defendant, the Plaintiff objects to
this process.
36. Denied. It is specifically denied that the Defendant has no intention of
complying with discovery requests or cooperating with obtaining the appraisals of
,jewelry, furs and personal property.
37. Denied. It is specifically denied that the Plaintiff is unduly prejudiced
without the appraisal of the limited number of items of personal property which have not
been appraised. It is further denied that the Plaintiff will be unduly prejudiced by
agreeing to allow the Defendant to be present while her jewelry and furs are appraised.
38. Denied. This paragraph contains an averment of law and as such requires
no answer. To the extent an answer is required, it is specifically denied that the
Defendant has engaged in vexatious conduct. It is further denied that the Defendant has
failed to cooperate with the Plaintiffs incessant demands.
39. Denied. After reasonable investigation, the Defendant is without sufficient
information to admit or deny this averment.
WHEREFORE, the Defendant respectfully requests this Honorable Court to
dismiss Plaintiffs Motion for Sanctions and to Compel Appraisals.
JHelvy, Esquire
dl' n & Gephart, L
2 Pine Street
P. O. Box 886
Harrisburg, PA 17108
(717) 232-1851
Attorney I. D. #53148
Dated: September 27, 2002
Attorneys for Defendant
EXMIIIT A
h1 D'd b0E ®a3u',t?y
i31H35 Q?OB _.._:!LV
JOHN E. MUMMA, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
Vs. NO. 99 - 5834 CIVIL
MAUREEN ANN MUMMA,
Defendant IN DIVORCE
TO: Maria P. Cognetti Attorney for Plaintiff
Donald T. Kissinger Attorney for Defendant
DATE: Thursday, July 26, 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.
/ /n /
DATE CC SE FOR PL INTIFF (x)
COUNSEL FOR ENDANT ( )
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 BO'T'H 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.
M J'd %OC ®Q d,
SiN35000M "eti
JOHN E. MUMMA,
Plaintiff
VS.
MAUREEN ANN MUMMA,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 5834 CIVIL
IN DIVORCE
TO: Maria P. Cognetti Attorney for Plaintiff
Donald T. Kissinger Attorney for Defendant
DATE: Thursday, July 26, 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:
XXXXX (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.
SEE ATTACHED.
August 20, 2001
Re: John E. Mumma v. Maureen Ann Mumma
No. 99-5837; In Divorce (Cumberland Co.)
DEFENDANT'S STATEMENT AS TO TNF ' AT ,',E DISCOVER V
On March 2, 2001, Defendant served Interrogatories and a Request f'or Production
of Documents upon Plaintiff. To date, the only response which Defendant has received
regarding the Request for Production of Documents is a statement from Plaintiff's
counsel to the effect that there are boxes of documents in her office which Defendant's
counsel may review. Counsel for Defendant has not yet hnd an opportunity to travel to
Plaintiff's counsel's office to review these documents; however, it is expected that this
will be done in the near future. Plaintiff has not provided a response to the Request for
Production of Documents indicating what documents are not heing produced or made
available along with the basis for non-production as required by Pa.R.C.P. 4009.12(b).
With regard to the Interrogatories, Plaintiff's answers are grossly inadequate. For
example, in spite of the fact that Plaintiff is asked (Inlerrog;uory No. 20) to identify any
interest in real property which he has (and there are mulliple parcels of real property at
issue in this case), Plaintiff fails to identi fv the parcels of real property. He simply
indicates that Defendant is to " [sjee Financial Staternenis provided in response to
Request for Production of Documents."
When asked whether he owns any artwork with a value in excess of $300
(Interrogatory No. 24), Plaintiff indicates that lewcnthing of value is in possession of
Maureen Mumma," in spite of the fact that he took valuable iterns of property at the time
the parties separated in 1991.
After reviewing the boxes of documents which are currently at Plaintiffs
counsel's offices, this statement will he upd;ued.
Respcctfitlly submitted,
J P
: uri-felvy, Esquire,,
ounsel for Defendant
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
August 20, 2001
DATE VC-NSEL SEL FOR INTI r FO DEFENDANT (XX)q
Paul Helvy, Esq.
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.
MJdti, ??bMO
S31H33W
Ci V .J V
Y
Y
5
MARIA P. C®GNEM & AsSociATES
Attorneys and Counselors at Law
Maria P. Cognetti'
Anomey at Law
'Fellow, American Academy or
Matrimonial Lawyers
August 1, 2002
J. Paul Helvy, Esquire
KILLIAN & GEPHART
218 Pine Street
Harrisburg, PA 17101
RE: MUMMA v. MUMNLIA
Our File No. 93
Dear Paul:
Practice Limited to Matrimonial Law
Karen A. Sheriff
Paralegal
Candith Y. Hill
Paralegal
I received a telephone call from Erica Wineske, of COrdier Antiques and Fine Art Gallery,
who is conducting the appraisal of the parties' personal property. Apparently she contacted your
client to arrange a time when she might make a follow up visit to complete her appraisal. She
was told by Maureen, somewhat rudely, that she was not going to cooperate any further at this
point. She instructed Erica to prepare a list of specific items that she needed to inspect and
submit that list to you.
While I think it is nonsense, I nevertheless, am enclosing said list. A second trip might
not have been necessary except many of these items were apparently not available for inspection
during the first visit. You should note that most, if not all, of the items listed are items that
appeared on Maureen's own list of property in her possession.
I have provided you the requested information and I now ask that you please instruct your
client to contact Erica Wineske at 731-1740 immediately
complete her appraisal to make arrangements for Erica to
.
Also, your client's position with respect to the appraisal of thejewelry and furs is
ludicrous. She should be strongly reminded that these items are all marital property and as such
my client is entitled to have them appraised by whomever he chooses. We have selected highly-
qualified and reputable experts to conduct thorough appraisals, which cannot be done with a
210 Gr Camp Hill, PA 17011
Te ax(717)909-4068
aol.com
J. Paul Helvy, Esquire
August 1, 2002
Page 2
cursory look. Your client's attempts to stonewall our efforts at gathering information essential to
our case are blatant and unacceptable. Nonetheless, it appears this will be just one more issue
which the Master will, unfortunately, have to deal with.
With respect to the 1993 and 1994 Exigent tax returns, which your client claims she
cannot locate, I expect she will make a more diligent effort and that I will be in receipt of them
shortly.
Very truly your
Maria P. C'ognetri
MPC/waw
Enclosure
cc: John E. Mumma (w/o enclosure)
"rl is 00 05:57a
p.2
Additions to Anoraisal Report
Rev. July 30, 2002
Family Room
Massage Recliner
Lamp
Fireplace Utensil Set
Wood Magazine Rack
Bear Picture
Entertainment Center
Living Room
Magazine Rack-Brass Swan .
Silk Plant On Chinese Bowl .
Silk Plant in Brass/Copper Vase
Dinin Room
Waterford Candlestick
12 Pc Stainless Cutlery Set
2 Silk Flower Arrangements
6 Pc Silverplated Goblet Set .
Foyer
Ceramic Set of Deer
Concrete Plant Stand
2 Sik Plants in Baskets
3 Portugese Watercolors
Reagan Library Print
Master Bedroom
UphoLst? fir
Brass Bedspread Stand
Standing Lamp
Cat Painting
Magazine Basket
Dresser Set
Wood Jewelry Box
Confidential Page 1
Catherine's Bedroom
2 Lamps
Mirror Plant stand
2 Brass Candlesticks
Li_ bract
Chair
_C=ane
Automobile
p. 3
Confidential
Page 2
CERTIFICATE OF SERVICE
I hereby certify that I have served a true and correct copy of the within document
upon the following by depositing a copy of same in the United States mail, postage
prepaid, addressed as follows:
Maria P. Cognetti, Esquire
Maria P. Cognetti & Associates
210 Grandview Avenue, Suite 102
Camp Hill, PA 17011
Peggy Hi e,"S?ecrretary to
J. Paul Helvy, Esquire
Killian & Gephart, LLP
218 Pine Street
P. O. Box 886
Harrisburg, PA 17108-0886
(717) 232-1851
Dated: September 27, 2002
c
c
r, r)
?r
J
JOHN E. MUMMA, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
Vs. NO. 99 - 5839 CIVIL
MAUREEN ANN MUMMA,
Defendant IN DIVORCE
ORDER OF COURT
AND NOW, this /d day of
2003, a divorce decree having been entered previously on
September 20, 2001, and the economic claims raised in the
proceedings having been resolved in accordance with a property
settlement agreement dated May 14, 2003, the appointment of the
Master is vacated.
BY THE COURT,
A44000-N
G or E f er, P J.
Cc: Xaria P. Cognetti
Attorney for Plaintiff
?J. Paul Helvy ( R
Attorney for Defendant
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\\Hteb\lamlly 1a'.\C11nn[ O1 recta ry\Hi=a-J\agnepent OF rope rt/ Settlement Ayreee.en U.u d
PROPERTY SETTLEMENT AGREEMENT
t=??E9??F??l
MAUREEN A. MUMMA
AND
JOHN E. MUMMA
Maria P. Cognetti, Esquire
MARIA P. COGNETTI & ASSOCIATES
201 Grandview Avenue, Suite 102
Suite 102
Camp Hill, PA 17011
mot. ..?_ .....? .. ....?,. n+..._-.:C
may lL M3
J. Paul Helvy, Esquire
KILLIAN & GEPHART, LLP
218 Pine Street
P.O. Box 886
Harrisburg, PA 17108-0886
For John E. Mumma For Maureen A. Mumma
\\ntee\[emL'y ls?\ea ent Dt re:[o ?Y\MUrtne-d\e0?exme,[fArpe[[y Snttlenent Ageeamnntl-pd Aey 10, :003
PROPERTY SETTLEMENT AGREEMENT
?? '
THIS AGREE:-0EDIT, made this day of e,1
,
2003, by and between MAUREEN A. MuMMA, of Cumberland County,
Pennsylvania (hereinafter referred to as "WIFE") and JCHN E.
MUMMA, of Perry County, Pennsylvania (hereinafter referred to as
"HUSBAND") :
WITNESSETH:
WHEREAS, the parties were married on March 14, 1963, in
Glasgow, Scotland; and
WHEREAS, no children have been born of this marriage; and
WHEREAS, a Decree in Divorce was entered on September 20,
2001; and
WHEREAS, differences have arisen between the parties as a
result of which thev are now divorced and now desire by tiIs
Agreement to settle all financial and property rights between
them.
NOW, THEREFORE, in ccnsideration of the premises and of the
mutual promises, covenants and undertakings hereinafter set forth
and for other good and valuable consideration, receipt of which
is hereby acknowledged by each of the parties hereto, HUSBAND and
\\YUe\bn=1% lay\CttanC Direc [a rY\MUmnn-.\a9rn?meab \ProP?r:y s<cclaem: a.nenc].?a
1 !py 14, 3001
- _ - w. - [r,
WIFE, each intending to be legally bound hereby covenant and
agree as foilows:
1. DIVORCE DECREE: On September 20, 2001, the Court
entered a Decree in Divorce and retained jurisdiction of certain
ancillary matters. A true and correct COPY of said Decree is
attached as Exhibit "A" and incorporated by reference as if set
forth fully herein.
Should any other decree, judgment or order be obtained by
either of the parties in this or any other state, country or
jurisdiction, each of the parties hereby consents and agrees that
this Agreement and all of its covenants shall not be affected in
any way, and that nothing in any suc" decree, judgment, order or
further modification or revisions thereof shall alter, amend or
vary any terms of this Agreement, whether or not either or both
of the parties shall remarry. It is the specific intent of the
parties to permit this Agreement to survive any judgment and to
be forever binding and conclusive upon the parties.
2. INCORPORATION IN DIVORCE DECREE: It is further agreed,
covenanted and stipulated that t
nis Agreement shall be
incorporated but not merged in the Decree in Divorce entered
September 20, 2001.
-2-
\\NfeE\lemi ly lav\e:4nC 0¢¢mry\Mume-J\eq;ern,nte \Pmpe[ty Sr. -.emcee A?: eaman:]..p" Mey 1e. 3001
3. EFFECTIVE DATE: The effective date of this Agreement
shall be the "date of execution" or "execution date," defined as
the date upon which it is executed by the parties if they have
each executed this Agreement at the same date. Otherwise, the
"date of execution" or "execution date" of this Agreement shall
be defined as the date of execution by the party last executing
this Agreement.
4. DISTRIBUTION DATE: The transfer of property, funds
and/or documents provided for herein, shall only take place on
the "distribution date" which shall be defined as the date of
execution of this Agreement unless otherwise specified herein.
5. MUTUAL RELEASE: EJSBAYD and WIFE each do hereby
mutually remise, release, quit-claim and forever discharge the
other and the estate of such other, for all time to come, and for
all purposes whatsoever, of and from any and all rights, title
and interest, or claims in or against the property (including
income and gain from property hereafter accruing) of the other or
against the estate of such other, of whatever nature and
wheresoever situated, w^:ich he or she now has or at any time
hereafter may have against the other, the estate of such other or
any part thereof, whether arising out of any former acts,
contracts, engagements or liabilities of such other or by way of
-3-
\\Nteo\Lam1:Y =av\C_:?n: Dl:oc:or/?uue.e-S\e.ronaeno P roFa[:y Set!:<aanc 29[111nn O.vPd may :4, 2003
dower or curtesy, or claims in the nature of dower or curtesy or
widow's or widower's rights, family exemption or similar
allowance, or under the intestate laws, or the right to take
against the spouse's will, or the right to treat a lifetime
conveyance by the other as a testamentary gift, or all other
rights of a surviving spouse to participate in a deceased
spouse's estate, whether arising under the laws of (a)
Pennsylvania, (b) any State, Commonwealth or territory of the
United States, or (c) any country or any rights which either
party may have or at any time hereafter shall have for past,
present or future support or maintenance, ali:,onv, alimony
pendente lite, counsel fees, division of property, costs or
expenses, whether arising as a result of the marital relationship
or otherwise, except, all rights and agreements and cblieations
of whatsoever nature arising or which may arise under this
Agreement or for the breach of any provisions thereof. __ is the
intention of HUSBAND and WIFE to give each other by the execution
of this Agreement a full, complete and general release with
respect to any and all property of any kind or nature, real,
personal or mixed, which the other now owns or may hereafter
acquire, except and only except all rights and agreements and
obligations of whatsoever nature arising or which may arise under
this Agreement or for the breach of any orovisien thereof. It is
further agreed that -.his Agreement shall be and constitute a full
-4-
\\NbO\[aally lau\Cl une Dice¢ory`.YUxaaJ\egreeaecca\i[Jpe:Oy Se;:leaan[ M?eeaen U.upE
Nay a. S?OJ
and final resolution of any and all claims which each of the
parties may have against the other for equitable division of
property, alimony, counsel f=es and expenses, alimony pendente
lice or any other claims pursuant to the Pennsylvania Divorce
Code or the divorce laws of any other jurisdiction.
6. ADVICE OF COUNSEL: The provisions of this Agreement
and its legal effect have been fully explained to the parties by
their respective counsel; MARIA P. COGNETTI, Esquire, for
HUSBAND and J. PAUL HELVY, Esquire, for KFE. htisannin .,,a %7, 11
acknowledge that this Agreement is not the result of any duress
or undue influence and that -t _s not the result of any collusion
or improper or illegal agreement or agreements. The parties
further acknowledge that they have each made to the other a full
accounting of their respective assets, estate, liabilities, and
sources of income and that they waive any specific enumeration
thereof for the purpose of this Agreement. Each party agrees
that he or she shall not, at any future time, raise as a defense,
or otherwise, the lack of such disclosure in any legal proceeding
involving this Agreement, with the exception of disclosure that
may have been fraudulently withheld.
7. WARRANTY AS TO EXISTING OBLIGATIONS: Each party
represents that they have not heretofore incurred or contracted
-5-
\\Nbb\,emlly law\Cltmt D3 rnctary?Au=ae J\egrms+nnts\Praparty SttUemvLL Agrnanena.vpd 4., 31, 2001
for any debt or liability or obligation for which the estate of
the other party may be responsible or liable except as may be
provided for in this Agreement. Each party agrees to indemnify
and hold the other party harmless for and against any and all
such debts, liabilities or obligations of every kind which may
have heretofore been incurred by them, including those for
necessities, except for the obligations arising out of this
Agreement.
8. WARRANTY AS TO FUTURE OBLIGATIONS: HUSBAND and WIFE
covenant, warrant, represent and agree that with the exception of
obligations set forth in this Agreement, neither of them shall
hereafter incur any liability whatsoever for which the estate of
the other may be liable. Each party shall indemnify and hold
harmless the other party for and against any and all debts,
charges and liabilities incurred by the other after the execution
date of this Agreement, except as may be otherwise specifically
provided for by the terms of this Agreement.
9. PERSONAL PROPERTY: The parties hereby divide their
personal property, including but not limited to, household goods
and furnishings, personal effects and all other items of personal
property used by them in common as follows: HUSBAND shall become
sole owner, and WIFE shall waive any claias to items listed in
-E-
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\\Nt5b\[nm LLY lav\C'iVnt O??e<[o[y\nmme-.\m?re a*.rn:a\Ypopr. ;Y Sc:lenent Aq.eemea:J.wptl veY IJ, OOJ
Exhibit "B", having an established total value of $5,076.90.
WIFE shall become sole owner, and HUSBAND shall waive any claims
to any other items still remaining in the marital residence,
located at 55 Green Ridge Road, Mechanicsburg, Pennsylvania,
including jewelry and furs.
WIFE agrees to gather the items listed in Exhibit B as well
as any other items of personalty of HUSBAND which stiff remain in
the marital residence. The parties agree that within one week of
the signing of this agreement, HUSBAND s:all pick up the items
listed in Exhibit B from, the garage of the marital residence.
Under no circumstances shall HUSBAND be perm'-teed, at that time,
to enter the marital residence. Once HUSBAND has had an
opportunity to view the property set out for hi;;, by WIFE he
shall, within 10 days thereof, notify his counsel as to whether
he wishes access to the marital residence for the purpose of
determining whether there are any other items of personal
property therein. Counsel for both parties shall the,-. determine
a time and date, no more than 30 days from notice to WIFE, for
the inspection of the home by HUSBAND. When this occurs counsel
for both parties are to be present. This process shall take no
more than two hours. Should HUSBAND determine that there are
items of personalty in the home those items may be removed with
the consent of WIFE. Should WIFE not agree that any such item is
HUSBAND's personal property the disposition of such item shall be
-7-
\\xGe\!am :Y .au\[llm: o4 ee :oo y\nwmme-.\n?n emen b\i roVar C/ sr::4an: Apreemnn:J.?p`1 Ys a. :a0]
, Y
left up to the sole discretion of the Master. The Master's
determination on any such issue shall be final and binding on the
parties.
All property being transferred to HUSBAND under this
paragraph shall be transferred in good condition.
All other items of personal property have been divided
satisfactorily by the parties and neither shall make any claim to
any such property presently in possession of the other.
Should it, at any time, become necessary for either party to
execute any titles, deeds or similar documents to give effect to
this paragraph, it shall be done immediately upon request of the
other party.
10. DIVISION OF REAL, PROPERTY: HUSBAND agrees to transfer
all his right, title and interest in and to the following real
estate properties, now titled in the name of HUSBAND and WIFE as
tenants by the entireties, to WIFE and agrees to immediately
execute now, and in the future, any and all deeds, documents or
papers necessary to effect such transfers of title upon request:
(a) 5S Green Ridge Road, Mechanicsburg, Cumberland
County, Pennsylvania;
(b) Property situated at M-ddle Road and Orchard
Drive, Juniata Township, Perry County,
Pennsylvania (also known as Sky:ine Corner);
-8-
%%Ntanfamily law\e::an: O1 [. r.[cry\Mwme-J\p semen:a\irgper p/ S•:clezenr AgreaaanG3.wpd 34. 2003
(c) 4A - 4G Kevin Road, Hechanicsburg, Cumberland
County, Pennsylvania.
HUSBAND further acknowledges that he has no claim, right,
interest or title whatsoever in said properties and further
agrees never to assert any claim to said properties in the
future. HUSBAND agrees to execute a deed for each such property
conveying his interest to WIFE.
WIFE shall hereafter be solely responsible for all past,
present and future costs, expenses and/or liabilities
attributable to said properties. In the event that there are any
debts against any of the properties bearing HUSBA.ND's name, WIFE
shall, within sixty (60) days of the execution of this Agreement,
take all steps necessary to remove HUSBAND'S name from said debts
so as to have HUSBAND completely and fully released of any and
all liability he may have with regard to the said debts.
WIFE agrees to transfer all of her right, title and interest
in and to the following real estate properties, now titled, or
formerly titled, in the name of HUSBAND and FiIFE as tenants by
the entireties to HUSBAND and agrees to immediately execute now
and in the future any and all deeds, documents or papers
necessary to effect such transfers of title upon request:
(a) 1255 Claremont Road, Middlesex Township,
Cumberland County, Pennsylvania;
-9-
\\Ntab\aemlly lew\Client Direccory\MU -]\cgpeemenp\Prper:y Seta cnm[ TgreemeaU.wpa
xey le, ]OD]
(b) Properties situated at 74C through 742 Allen Road,
South Middletown Township, Cumberland county,
Pennsylvania;
(c) Property consisting of 21.04 acres situated along
State Route 944 (Wertzville Road), Silver Spring
Township, Cumberland County, Pennsylvania.
WIFE further acknowledges that, she has no claim, right,
interest or title whatscever in said prcperties and further
agrees never to assert any claim to said properties in the
future. WIFE agrees to execute a deed for each property, as
necessary, conveying her interest to HUSBAND.
HUSBAND hereby covenants and agrees to assume and pay in
full the remaining balance of the mortgage row existing and
presently constituting a lien and encumbering the property
located at 740-742 Allen Road, such mortgage being owed and
payable to Mid-Penn Bank, and further covenants and agrees that
he will indemnify and save WIFE harmless from any and all
liability, expense, cost, or loss whatsoever, as a result of his
non-payment of, or non-performance of, said mortgage and said
mortgage conditions. HUSBAND shall, within sixty (60) days of
the execution of this Agreement, take all steps necessary to
remove WIFE's name from the Mid-Penn Bank mortgage so as to have
WIFE completely and fully released of any and all liability she
has or the said mortgage.
-10-
\\N Ub\:an::Y lev\C::an[ L+[yc:a r•/\Hpp a-J\e2 uaarn[a'. P::pu o, 5<::: eSrn: Mamma vPC luy W. 2003
11. REAL ESTATE PARTNERSHIP/KRONENBERG BUILDING: HUSBAND
and WIFE are owners of a one-half interest in the real estate
partnership known as Liberty Holdina Comoanv, which consists of
the Kronenberg Building, located at 2-8 Hanover Street, Carlisle,
Cumberland County, Pennsylvania. WIFE agrees to transfer any and
all of her marital right, title an interest in and to t,rat
partnership and Kronenberg Building to HUSBAND. WIFE agrees to
immediately execute now and in the future, any and all deeds,
documents or papers necessary to effect such transfer of title
upon request. WIFE further acknowledges that she has no claim,
right, interest or title whatsoever in said partnership and
Kronenberg Building and further agrees never to assert any claim
to such asset in the future. HUSBAND shall hereafter be solely
responsible for all present and future costs, expenses or
liabilities attributable and/or resulting from HUSBAND's interest
in Liberty Holding Company and Kronenberg Building. HUSBAND
shall, within sixty (6C) days of the execution of this Agreement,
take all steps necessary to remove WIFE's name frorr. any liability
whatsoever associated with their ownership interest in this
property so as to have WIFE comnie*_ely and fully released of any
and all liability she has on the said mortgage.
12. EXIGENT BUILDING: The parties agree that WIFE has an
interest in a business known as Exigent, Inc., which owns real
?NKterf\teully la•\G:ent GIIeCGr7\9c A-J\49reement3\2:opecty 5ett:eee Agreer<nt 1. ry] Me9 14, :OOI
estate located at 102-R North Baltimore Avenue, Mount Holly
Springs, Cumberland County, Pennsylvania, which shall become or
remain the sole and exclusive property of WIFE. HUSBAND
acknowledges that he has no further claim or interest in such
business or property and agrees that he will not assert any claim
to said business or property in the fiture.
HUSBAND agrees to immediately execute now and in the future,
any and all deeds, documents or papers necessary to effect such
transfer of title upon reauest. WIFE shall hereafter be solely
responsible for all past, present and future costs, expenses or
liabilities attributable and/or resulting from WIFE's interest in
Exigent, Inc. and Exigent Building. WIFE shall, within sixty
(60) days of the execution of this Agreement, take all steps
necessary to remove HUSBAND's name from any liability whatsoever
associated with their ownership interest in this business so as
to have HUSBAND completely and fully released of any and all
liability he has on the said business.
13. PRIOR DISTRIBUTIONS MADE BY AGREEMENT OF THE PARTIES:
The parties acknowledge that their agreement herein for the
equitable distribution of their marital estate takes into account
and reaffirms the following prior distributions and waivers made
by prior agreement between the parties:
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\\NbE\[um Iy :e. a:ten[ ....... [s\P:aperty Se R:eemma Aq: eemen U.vpq Nny 14, 3003
(a) By agreement of the parties dated on or about
March 13, 2000, WIFE was credited with al_
interest in the property situated at 4=. - 4G Kevin
Road, Mechanicsburg, Cumberland County,
Pennsylvania.
(b) By agreement of the parties dated on or about
March 13, 2000, WIFE waived any and al- title and
interest in and to the business entity known as
Carlisle Electric, Inc. and acknowledged that
HUSBAND was ands to remain the sole owner of
said business.
(c) By agreement Of the parties dated on or around
March 10, 2000, WIFE waived any present or future
interest to property situated at 333 Landisburg
Road, Shermansdale, Perry County, Pennsylvania,
purchased post secaration and titled to John. E.
Mumma and Janice M. Charette.
(d) By agreement of the parties dated on or around
July 25, 1951, WIFE waived any and all present or
future interest to property situated at 105 - 107
North Hanover Street, Carlisle, Cumberland County,
Pennsylvania, purchased post secaration and titled
to HUSBAND.
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\\x[rt`.fueay levy.-)Wt D .aceory\H'saa-1\agra e¢enb\Proaer[%snct:amnne Tq rnamen:].rP? Mey ta, .?a]
(e) By agreement of the parties dated on or around
July 25, 1991, WIFE agreed to convey title to the
jointly owned property situa-ed along State Route
944 (Wertzville Road), Silver Soring Township,
Cumberland County, Pennsylvania, from HUSBAND and
WIPE by tenants by the entir=ties tc HUSBAND.
14. INDIVIDUAL BANK ACCOUNTS: HUSBAND and WIPE acknowledge
that they each possess certain bank accounts and the like in
their respective names. They hereby agree that each shall become
sole owner of their respective accounts and they each hereby
waive any interest in, or claim to, any funds held by the other
in such accounts.
15. JOINTLY OWNED BANK ACCOUNTS: HUSBAND agrees that WIFE
shall retain as her separate property any and all suns of cash in
the parties' joint bank accounts as follows:
(A) AllFirst Bank, checking acccunt, No. 6221601;
(B) M&T Bank checking account, No. 1-10795;
(C) PNC Bank checkina account, No. 50-0210-4885;
(D) Waypoin- Bank chec ing account, No. 0090781832.
The parties agree that W:FE promptly shall withdraw all sums
now remaining in the joint accounts and shall open other
accounts, as she so desires,-r. her name alone. The parties
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\\Ntab\[enllY law'dl,en[ DYeCter/\ttuxa-S\aVreementa\Property Set::Vmen: A':eemena.wptl „ Nay li. 3003
agree to promptly cooperate in closing all joint accounts. 'T'his
must be accomplished within ten (10) days of signing.
16. CERTIFICATES OF DEPOSIT: The parties agree that the
Certificate of Deposit, purchased by WIFE on or about July 25,
2002, through Waypoint Bank, No. 5000057044, stall remain the
sole and exclusive property of WIFE. HUSBAND acknowledges that
he has no further claim or interest in said Certificate of
Deposit and agrees that he will not assert any claim in the
future.
17. PP&L STOCKS: The parties
shares of PP&L stock. It is agreed
her sole and separate property, all
waives any right, title, claim or i
shall cooperate in effectuating the
WIFE.
are the joint owners of 400
that WIFE shall receive, as
400 shares and HUSBAND hereby
.terest t:neretc. The parties
transfer of said stock to
18. MUNICIPAL, INVESTMENT TRUST FUND: HUSBAND and WIFE
acknowledge that as of the date of separation WIFE was the owner
of three (3) units of Municipal Invest!nent Trust Fund, which have
since been liquidated, and the funds retained by WIFE.
\\N[a0\Lez: Y/ lerrC;: an: J.:ec:a'/\MUmme-d\ar'raamen[a?iraPe: b/ Sec[:cnec dC[x amen U..p.:
nev 11, 2003
19. DISTRIBUTION OF INDIVIDUAL RETIREMENT ACCOUNTS TITLED
TO WIFE: HUSBAND hereby acknowledges and agrees that WIFE shall
retain, as her separate prcoerty, free and clear from any claim,
right, title or interest on the part of HUSBAND, her Individual
Retirement Accounts. HUSBAND herebv acknowledges that he has no
further claim, right, title or interest whatsoever in the
Individual Retirement Acccunts of WIFE, and further agrees never
to assert any claim to the ass=_t in the future.
20. DISTRIBUTION OF INDIVIDUAL RETIREMENT ACCOUNTS
PURCHASED POST SEPARATION BY WIFE FOR HUSBAND: :he parties hereby
acknowledge and acree that WIFE purchased, post separation but in
H.USBAND's name, the following Individual Retirement Acccunts:
(a) Allf irst Bank IRA, No. 8-700-'016-7315140, valued on
December 31, 2002 at $6,657.63;
(b) Waypoin- Bank IRA, No. 1100052167, valued on December
31, 2002 at $8,291.45; and
(c) ?NC Ira, No. 75100012578
, valued on March 4, 2003 at
approximately $6,3='.'.3.13.
HUSBAND agrees to "rollover" said IPAs to IRA. accocnts in
WIFE's name and further agrees to waive any claim he may have to
said IRAs. HUSBAND further agrees to sign and deliver -o WIFE's
counsel any documents necessary to effectuate this "rollover."
WIFE agrees that she shall assu-,.e the rescens_bility and cost for
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\\8Gb\tab1ly taw:,el.r.c CI:eC[Of'/\MUmmu-I\n V: aezen tf\i:oPa[:/ Set:l-,ent Aq,ea,ent3.ry.f yay tl, 3003
the preparation of any and all documentation necessary to
effectuate said "rollover." Such documentation shall be
presented to HUSBAND for his execution within 3C days of the
signing of this Agreement. If, for whatever reason, the
appropriate documentation has not been forwarded to HUSBAND by
year end, 2003, he shall have no further responsibility to
transfer said IRAs to WIFE. Furthermore, should there be any tax
consequences whatsoever, to HUSBAND, en account of these
transfers, WIFE agrees to be solely respcnsible for payment of
any such taxes.
21. DISTRIBUTION OF AMEX INDIVIDUAL RETIREMENT ACCOUNT
TITLED TO HUSBAND: W_-FE hereby acknowledges and agrees that
HUSBAND shall retain as his separate property free and clear from
any claim, right, title or interest on the part of WIFE his AMEX
Individual Retirement Account. WIFE hereby acknowledges that she
has no further claim, right, title or interest whatsoever in the
AMEX Individual Retirement Account of HUSBAND and further agrees
never to assert any claims to the asset in the future.
22. MOTOR VEHICLES: The parties agree that WIFE is in
possession of a 1995 Fonda Accord, which is titled to the
business, owned by HUSBAND, and known as Carlisle Electric, Inc.
WIFE agrees to return the vehicle to Carlisle Electric, Inc.,
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\\Nbb`. temlly 1s.hCl: ant Dl ttc[m:y\NUmae-1\eq[aenen[a\P [e pe;[y Sa;; lnma i; A9namen[]..,jC
' N+v 14, ¢am
within five (5) days of the signing of this Agreement. Said
vehicle shall be returned to HUSBAND is good condition subject to
normal wear and tear.
23. CEMETERY PLOTS: The parties acknowledge that they
presently own two (2) cemetery plots 'located at Rolling Green
Cemetery. HUSBAND acrees to transfer all his right, title and
interest in and to said cemetery plots to WIFE and agrees to
immediately execute any and all deeds or documents necessary to
effect such transfer.
24. LIFE INSURANCE POLICIES: The parties aaree that HUSBAND
presently holds certain life insurance policies, namely
Prudential Whole Life, Metropolitan Life and Prcvident Mutual
Life, on his life. These po'_'c;es are presently it the
possession and control of WIFE. The parties further agree that
HUSBAND will retain the ownership of said policies and that any
cash value accruing to said policies shall remain his sole and
exclusive property.
25. OTHER ASSETS: The parties hereby agree that as to all
assets not specifically mentioned herein, of which no disposit-on
has been made under the terms hereof, and which are presently
titled in the sole name of one of the parties hereto, or if
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untitled, are presently in the sole possession of one of the
parties hereto, the party not having title or possession thereof
hereby waives, releases, relincuis;,es and forever abandons any
and all claim therein and acknowledges that the party having
title or possession of such item or items shall be the sole and
exclusive own=_r thereof.
26. CASH TO HUSBAND: In consideration for the conveyances
set forth herein, WIFE agrees to pay to HUSBAND the sum of Fifty
Five Thousand, Six Hundred Forty Eight Dollars and Ten Cents
($55,673.1C) [567,000.00 minus 511,326.90). WIFE agrees to pay
said sum to HUSBAND within thirty (30) days from the execution of
this Agreement.
27. AFTER-ACQUIRED PROPERTY: Each of the parties shall
hereafter own and enjoy, independently of
the other, all items of property, be they
mixed, tancible or intangible, which are
him or her, with full power in him or her
as fully and effectively, in all respects
as thcuch he or she were unmarried.
anv claim or richt of
real, personal or
:ereafter acquired by
to d-sgose of the same
and for all purposes,
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' her u, ¢ua3
28. MAILBOX: WIF= agrees to remove HUSBAND'S name from the
mailbox located at the former marital residence within one week
of the execution of this Agreement.
29. COUNSEL FEES: The parties hereby acknowledge that they
are represented by counsel of their own choice and that each is
responsible to pay their own at_crney for all attorney's fees and
legal expenses in conjunction with the negotiation and
preparation of this 'agreement, as well as other matters relating
to the parties' marital claims under the Divorce Code of 1980.
30. INCOME TAX PRIOR RETURNS: The parties have heretofore
filed joint Federal and State tax returns. Both parties agree
that in the event any deficiency i.n Federal or State income tax
is proposed, or any assessment of any such tax is made against
either of them, each will indemnify and hold harmless the other
from and against any loss or liability for any such tax
deficiency or assessment and any interest, penalty and expense
incurred in connection therewith. Sach tax, interest, penalty or
expense shall be paid solely and entirely by the individual who
is finally determined to be the cause of the misr=epresentations
or failures to disc'_ose the nature and extent of his or her
separate income on the aforesaid joint returns.
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\\N UO\[nmi:Y ?+•`Ctima Di nct?['/`.YUUmna-.P aN [rtam?a n+i[cPa[t? 9mtt 4an n: A,: aacnm:].upd K.Y 11, 3001
31. APPLICABILITY OF TAX LAW TO PROPERTY TRANSFERS: The
parties hereby agree and express their intent that any transfer
of property pursuant to this Agreement shall be within the scope
and applicability of the Deficit Reduction Act cf 1994
(hereinafter the "Act"), specifically, the provisions of sa-d Act
pertaining to the transfers of property between spouses and
former spouses. -he parties acree tc sign and cause to be filed
any elections or other documents required by the Internal Revenue
Service to render the Act applicable to the transfers set forth
in this Agreement without recognition of gain on such transfer
and subject to the carry-over basis provisions of the said Act.
32. TAX ADVICE: Both parties hereby acknowledge and
agree that they have had the opportunity to retain their own
accountants, certified public accountants, tax advisor, or tax
attorney with reference to the tax implications of this
Agreement. Further, neither party has been given any tax advice
whatsoever by their respective attorneys. Further both parties
hereby acknowledge gnat they have been advised, by their
respective attorneys, to seek their own independent tax advice by
retaining an accountant, certified public accountant, tax
attorney, or tax advisor with reference to the tay implications
involved in this Agreement. Further, the parties acknowledge and
agree that their signatures to this Agreement serve as their
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4., 11. 2CCJ
acknowledgment that they have read this particular paragraph and
have had the opportunity to seek independent tax advice.
33. WAIVER OF ALIMONY: HUS3M D and WIFE recognize and
acknowledge that the foregoing provisions for their individual
benefit are satisfactory with regard to their support and
maintenance, past, present and future. The parties release and
discharge the other abse'_utely and forever for the rest of their
lives from all plains and demands, oast, present or future, for
alimony or for any provision for support or maintenance, except
as specifically provided for herein. The parties further
acknowledge that in consideration of the transfers made herein
each completely waives and relinquishes any and all claims and/or
demands they may now have or hereafter have against the other for
alimony, alimony pendente lite, spousal support and couns=el fees,
except as specifically provided for herein.
34. BREACH: If either party breaches any provision of this
Agreement, the other party shall have the right, at his or her
election, to sue for damages for such breach or seek such other
remedies or relief as may be available to him or her, and the
party breaching this contract shall be responsible for payments of
reasonable legal fees and ccsts incurred by the c--her in
enforcing their rights under this Agreement.
\\Ybb\[a¢i 4/ InwtC LLenc O1[ectcrv\NU-wa-J\egeemeot3\P:0percy Set
::emen! A9 n ement). vpa
May ti. 2003
35. WAIVER OF CLAIMS: 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 shall now have or hereafter acquire, under the present and
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, curtesy, statutory
allowance, widow's allowance, widower's allowance, right to take
in intestacy, right to take against the Will of the other, and
the right to act as administrator or executor of the other's
estate. Each party 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.
36. ENTIRE AGREEMENT: This Agreement contains the entire
understanding of the parties and -here are no representations,
warranties, covenants or undertakings other than those expressly
set forth herein.
37. FINANCIAL DISCLOSURE: The parties confirm that they
have relied on the completeness and substantial accuracy of the
financial disclosure of the Other 'as an inducement to the
execution of this Agreement. The parties acknowledge that formal
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\\NbD\:+ml:Y lle nr Dltac for y?PUman-S'ayrw ementa\propa rtY Su[:: eaav Apreamec U..pd
1.1 14, 230)
discovery has been conducted and that both parties have filed an
Inventory and Appraisement as required by Secticr, 3505(b) of the
Pennsylvania Divorce Code. Notwithstanding the foregoi::g, the
rights of either party to pursue a claim for equitable
distribution, pursuant to the Pennsylvania Divorce Code, of any
interest owned by the other party in an asset of any nature at
any time prior to the date of execution of this Agreement that
was not disclosed to the other party cr his or her counsel prior
to the date of the within Agreement is expressly reserved. In
the event that either party, at any time hereafter, discovers
such an undisclosed asset, that party shall have the right to
petition the Court of Common Pleas of Cumberland County to make
equitable distribution of said asset.
The non-disclosing party shall be responsible for payment of
counsel fees, costs or expenses incurred by the other party in
seeking equitable distribution of said asset.
Notwithstanding the foregoing, the Agreement shall in all
other respects remain in full force and effect.
38. AGREEMENT BINDING ON HEIRS: This Agreement shall be
binding and shall inure to the benefit of the parties hereto and
their respective heirs, executors, administrators, successors and
assigns.
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\\NUp\4nay 1ae•.Cltan[ O:rec:ool \!I?:nna-.1\aS[eenent [\P:cpe[ty Se:; tope.[ ....... .vGa Nay 14. 3003
39. ADDITIONAL INSTRUMENTS: Each of the parties shall,
from time to time, at the request of the other, execute,
acknowledge and deliver to the other any and all further
instruments that may be reasonably required to give full force
and effect to the provisions cf this Agreement.
40. VOID CLAUSES: If any ter-, condition, clause or
provision of this Agreement shall be determined or declared to be
void or invalid in law or othera_se, 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 ooeration.
41. INDEPENDENT SEPARATE COVENANTS: I- is-specifically
understood and agreed by and between the parties hereto that each
paragraph hereof shall be deemed to be a separate and independent
Agreement.
42. MODIFICATION AND WAIVER: A modification or waiver of
any of the provisions of this Agre=ement shall be effec-ive only
if made in writing and executed with toe same formali-y as this
Agreement. The failure of either party to insist upon strict
performance of any of the provis-or-s of this Agreement shall not
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\\Ntsb\LdmIIy Jd Cl l dr(t Dl¢ecU q\NUmsd \d Creeme n:3\POperty is ti moot a0 ro esenU.vpE
9dy 11, 2003
be construed as a waiver of any subsequent defaults of the same
or similar nature.
43. DESCRIPTIVE HEADINGS
herein are for convenience only
The descriptive headincs used
They shall have no affect
whatsoever in de*_erminir.g the rights or obligations of the
parties.
44. APPLICABLE LAW: This Agreement shall be construed
under the laws of the Cornmonwealt:, of Pennsylvania and more
specifically under the Divorce Code of 1980 and any amendments
thereto.
IN WITNESS WHEREOF, the parties hereto have set their hands
and seals the date and year first above written.
?GGIl
WITNES
(SEAL)
JOHN E. MUMMA
WITNESS
4? Y !` G'i'.L plc l1' (SEF.L)
?4AUREEN A. MUMMA
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•;t•r 14, 2093
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF GLtR',8ER.I_r.?OnD )SS:
On this, the A day of q)atL , 2003 before me, a
Notary Public, the undersigned offi , personally appeared JOHN
E. MUMMA, known to me (or satisfactorily proven) to be the person
whose name is subscribed to the foregoing Property Settlement
Agreement and acknowledged that he executed the same for the
purposes therein contained.
seal. WITNESS WHEREOF, I hereunto set my hand and official
Notarial Seal
Karen A. Sheriff, Notary Public
Palmyra Boro, Lebanon County
PAY Cam"on Expires May 16, 2006
Member. "MyNWO Association of Notaries
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF
)SS:
On this, the /Cjff day of 2003 before me, a
Notary Public, the undersigned offi er, personally appeared
MAUREEN A. MUMMA, known to me (or satisfactorily proven) to be
the person whose name is subscribed to the foregoing Property
Settlement Agreement and acknowledged that she executed the same
for the purposes therein contained.
seal. WITNESS WHEREOF, I hereunto set my hard and official
Notary Public (?-
Notarial Seal
Rhonda L. Lang?Notaz Public
Harrisburg, Dauphin County
My Commission Expires Aug. 9, 2004
EXHIBIT "A"
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
t V+
John E. Mumma Q!`
Plaintiff I No . 99-5834 Civil
+ VERSUS I j
Maureen Ann Mumma
+ i
Defendant ?
DECREE IN
DIVORCE
AND NOW, September 20th 2001
IT IS ORDERED AND
DECREED THAT John E. Mumma
PLAI NTI FF,
AND Maureen Ann Mumma
, 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 FINALORDER HAS NOT
YET BEEN ENTERED;
Alimony, Alimony Pende
Expenses,. and Equitable Distribution.
BY THE COURT:
/s/ Kevin A. Hess 21
ATTEST:
J. Y
X.
PROTHONOTARY
CERTIFIED f
COPY ISSUED SEPTEMBER 21, 2001 Y
EXHIBIT "B"
\\NCab\fem:y lev?Clienr, p.r¢ca ry`.Mdmsa-J\eJreaauntf?Propec[•/ Se L'lamr nt A9 re xaxncl.vpc May 14, 21C1
EXHIBIT "B"
DISTRIBUTION OF PERSONAL PROPERTY TO HUSBAND
DESCRIPTION MARITAL
VALUE
1 Ronald Regan print, purchased by Husband 0; post
post separation., and currently maintained in separation
the marital residence, acquisition
2 "Bear" picture, purchased by Husband post 0; post
separation, and currently maintained in the separation
marital residence
. accuisition
3 All of Husband's personal effects, such as 0; personal
clothing, etc., currently maintained in the effects
marital residence.
4 All photos of Husband and Husband's family, 0; personal
currently maintained in the marital effects
residence.
5 All Navy memorabilia, including but not 0; personal
limited to uniforms, currently being effects
maintained in the marital residence.
6 All items, such as tools, belcngina to 0; personal
Carlisle Electric, Inc., currently maintained effects
in the marital residence.
7 Large Hereke silk wall hanging, currently $675.00
maintained in the marital residence, located
at date of separation in the gallery.
B Three (3) wooden pipes, currently maintained $35.00
in the marital residence and, located at date
of separation in the family room.
9 Wooden drafting table with stool, currently $137.50
maintained in the martial residence, located
at date of separation in the office/library.
10 Brass decorator bell from Scotland, currently $75.00
maintained in the marital residence
located
,
at date of separation on 2nd floor landing.
11 (24) loz. Kruaerands 0$350.20 cer oz. 54,204.40
(kt of c,4'4.80)
12 1994 Honda Accord $6,200.00
Total Value $11,326.90