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IN THE COURT OF COMMON PLEAS
PAMELA A. BRADLEY,
Plaintiff
VERsus
KENNETH P. BRADLEY
OF CUMBERLAND COUNTY
STATE OF PENNA.
Defendant
CIVIL
DECREE IN
DIVORCE
AND NOW, Cxhl%4,. 2002 , IT IS ORDERED AND
DECREED THAT
PAMELA A. BRADLEY
AND- KENNETH P. BRADLEY
A14E DIVORCED FROM THE BONDS OF MATRIMONY.
, PLAINTIFF,
DEFENDANT,
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
DEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET DEEN ENTERED;
All economic claims have been settled.
BY THE COURT:
PROTHONOTARY
No. 99-6497
PAMELA A. BRADLEY,
Plaintiff
VS.
KENNETH P. BRADLEY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 6997 CIVIL
IN DIVORCE
ORDER OF COURT
S day of alhlk,
AND NOW, this
2002, the parties and counsel having entered into an
agreement and stipulation resolving the economic issues on
September 29, 2002, the date set for a four-party
conference, the agreement and stipulation having been
transcribed, and subsequently signed by the parties and
counsel, the appointment of the Master is vacated and
counsel can conclude the proceedings by the filing of a
praecipe to transmit the record with the affidavits of
consent of the parties so that a final decree in divorce can
be entered.
BY THE COURT,
AlAn
GeoYg Coffer, P J.
cc: Mindy S. Goodman
Attorney for Plaintiff
Carol J. Lindsay
Attorney for Defendant
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PAMELA A. BRADLEY,
Plaintiff
Vs.
KENNETH P. BRADLEY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 6497 CIVIL
IN DIVORCE
THE MASTER: Today is Tuesday, September 24,
2002. This is the date set for a conference with counsel and
the parties with reference to the above captioned divorce
proceedings.
Present in the hearing room are the
Plaintiff, Pamela A. Bradley, and her counsel Mindy S.
Goodman, and the Defendant, Kenneth P. Bradley, and his
counsel Carol J. Lindsay.
This action was commenced by the filing of a
complaint in divorce on October 26, 1999, raising the economic
claims of equitable distribution and counsel fees and
expenses. No claim has been raised by either party for
alimony.
The master has been advised that the parties
will sign and file affidavits of consent and waivers of notice
of intention to request entry of divorce decree so that the
divorce can be concluded under Section 3301(c) of the Domestic
Relations Code.
The parties were married on July 10, 1986,
and separated October 27, 1999. There is one child of the
r
marriage, Jared Bradley, born June 3, 1992.
The Master has been advised by counsel that
an agreement has been reached with regard to the outstanding
economic issues. The agreement is going to be placed on the
record in the presence of the parties. The agreement as
placed on the record will be considered the substantive
agreement of the parties not subject to any changes or
modifications except for correction of typographical errors
which may be made during the transcription. After the
agreement has been transcribed and reviewed for typographical
errors, the parties will affix their signatures affirming the
terms of settlement as stated on the record.
Upon receipt by the Master of the signed
agreement, the Master will prepare an order vacating his
appointment. Counsel will then be able to file a praecipe
transmitting the record to the Court requesting a final decree
in divorce. Ms. Lindsay.
MS. LINDSAY: The parties have agreed as
follows:
1. Husband will retain the marital residence at 821
Pheasant Drive North, Carlisle, Pennsylvania, and he will
refinance the mortgage on the loan, which is in joint names,
or obtain a release of wife's obligation on the mortgage
within two years. Notwithstanding that, husband will make an
application for another mortgage within one year of today's
date. Upon the refinance or release of the mortgage on the
marital home, wife will tender to husband a deed. In the
interim, husband will pay the mortgage, taxes, and insurance
and will indemnify and hold wife harmless on account of any
loss resulting from the marital home.
In the event that husband fails to refinance or
obtain a release of wife's obligation within two years as set
out above, husband will place the house on the market and sell
it in order to achieve the goal of obtaining•a release of
mortgage for the wife.
2. The parties have satisfactorily divided their vehicles:
Wife retains the 1994 Pathfinder; husband the 1988 Nissan
wagon and motorcycle. Both parties will execute any documents
required by the other within ten (10) days of a request in
order to transfer the vehicles into the names of the party
retaining it in equitable distribution.
3. Both parties have PSERS pensions. Wife's counsel will
provide a Domestic Relations order which will roll over
$5,000.00 from husband's PSERS pension into wife's PSERS
pension or such other qualified plan as the state will permit.
4. Each of the these parties has a benefit which they
obtained during military service in terms of a Veteran's
benefit or a pension and each waives any interest he or she
may have in the military benefit of the other.
5. Husband will retain his life insurance policy with
Metropolitan Life and wife waives any claim she has for any
interest in that policy. However, husband will be solely
responsible for any debt incurred in loans against the life
insurance policy.
6. Credit in the overall settlement set out herein is
given to wife for $5,893.00 on a joint CBW Schools Federal
Credit Union loan which she avers is paid in full at this
time, and also for two credit cards, one a Visa and the other
a Discover Card with a total indebtedness of $2,000.00.
Husband is given credit here today for payment of a loan with
Capital one with a date of separation balance of approximately
$4,400.00. Although both parties aver these obligations have
been paid in full, they will indemnify and hold the other
harmless against any claim by any of the creditors involved on
the debts that they have agreed to pay.
7. Husband will pay to wife $7,500.00 within sixty (60)
days of the date of this agreement.
8. The parties waive any claim that they may have for
attorney fees and costs.
9. Wife will receive the hot tub which is currently in
husband's possession but all other personalty shall remain the
sole and separate property of the party in whose possession it
is as of today's date. Absent an agreement of the parties to
the contrary, wife will remove the hot tub within three (3)
months.
10. Except as herein otherwise provided, each party may
dispose of his or her property in any way and each party
hereby waives and relinquishes any and all rights he or she
may now have or hereafter acquire under the present or future
laws of any jurisdiction to share in the property or the
estate of the other as a result of the marital relationship
including without limitation, statutory allowance, widow's
allowance, right of intestacy, right to take against the will
of the other, and right to act as administrator or executor in
the other's estate. Each will at the request of the other
execute, acknowledge, and deliver any and all instruments
which may be necessary or advisable to carry into effect this
mutual waiver and relinquishment of all such interest, rights,
and claims.
MS. LINDSAY: Mr. Bradley, you have been in
the conference room here with me today as I dictated the terms
of agreement with Pamela; is that correct?
MR. BRADLEY: That is correct.
MS. LINDSAY: And did you hear all of those
terms?
MR. BRADLEY: Correct.
MS. LINDSAY: Are they acceptable to you?
MR. BRADLEY: They are acceptable.
MS. LINDSAY: Is there anything you did not
understand?
MR. BRADLEY: No.
(A discussion was held off the record.)
MS. GOODMAN: Ms. Bradley, were you present
in the room when each of the provisions of the agreement were
is
read into the record?
MS. BRADLEY: Yes.
MS. GOODMAN: Do you have any questions about
any of the provisions that were read onto the record?
MS. BRADLEY: No.
MS. GOODMAN: Do you accept the provisions as
stated?
MS. BRADLEY: I accept them.
MS. GOODMAN:' And do you consent to the
divorce?
MS. BRADLEY: I consent to the divorce.
I acknowledge that I have read the above
stipulation and agreement, that I understand the terms of
settlement as set forth herein, and that by signing below I
ratify and affirm the agreement previously made and intend to
bind myself to the settlement as a contract obligating myself
to the terms of settlement and subjecting myself to the
methods and procedures of enforcement which may be imposed by
law and in particular Section 3105 of the Domestic Relations
Code.
WITNESS:
vy Mindy S.
Attorne(-
Carol J.
Attorney
DATE:
Goodman
for Plaintiff
/0702-11 i dsay
fo Def dant
41?u
Pamela A. Bradl
Kenneth P. Bradl
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PAMELA A. BRADLEY,
Plaintiff
V.
KENNETH P. BRADLEY,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6497
: CIVIL ACTION - LAW
: IN DIVORCE
PRACEIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the Court for
entry of a Divorce Decree:
1. Ground for divorce: irretrievable breakdown under 3301(c) of the Divorce
Code.
2. Date and manner of service of the Complaint: Certified Mail, Restricted
Delivery, Return Receipt Requested signed by Defendant on November 8, 1999 and
attached as part of the record.
3. Date of execution of the affidavit of consent required by 3301(c) of the
Divorce Code: by Plaintiff -24-02 ; by Defendant -24-02
4. Related claims pending: NONE
5. Date Plaintiffs Waiver of Notice in 3301(c) Divorce was filed with the
Prothonotary: 9-24-02 ; by Defendant 9-24-02
Respectfully submitted,
Datc:10 -1-I Z N-6=, a, aMZV r19-
Mindy S. Goodman, Esquire
I.D. No. 78407
2215 Forest Hills Drive - Suite 35
Harrisburg, PA 17112
(717) 540-8742
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PAMELA A. BRADLEY, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. QQ - 097 l.'IUt1 ?f?Lrr1
KENNETH P. BRADLEY, : CIVIL ACTION -LAW
Defendant : IN CUSTODY
ORDER OF COURT
AND NOW, upon consideration of the attached Complaint, it is hereby
directed that the parties and their respective counsel appear before the Custody
Conference Officer, on the ?L__j- day of , t1?GN , ??Xoat
&.M. for a Pre-Hearing Custody Conference to be held at
G (MP klt C Nk6c1L:&mi ,- urg, Pennsylvania.
At such Conference, an effort will be made to resolve the issues in dispute; or if
this cannot be accomplished, to define and narrow the issues to be heard by the
Court, and to enter into a Temporary Order. All children age five or older are to
be present at the Conference. Failure to appear at the Conference may provide
grounds for entry of a temporary or permanent Order.
FOR THE COURT:
DATE: 1 J?? `) `I 'mtC? s o Q _ ?]rmci'a-,
Custody Conference Officer
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
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PAMELA A. BRADLEY,
Plaintiff
V.
KENNETH P. BRADLEY,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO.
: CIVIL ACTION - LAW
: IN DIVORCE & CUSTODY
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, Including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of
the marriage, you may request marriage counseling. A list of marriage
counselors is available in the Office of the Prothonotary, Dauphin County
Courthouse, Front and Market Streets, Harrisburg, PA 17101.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR
ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF
THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 248-3166
PAMELA A. BRADLEY, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. . NO.
KENNETH P. BRADLEY, : CIVIL ACTION - LAW
Defendant : IN DIVORCE & CUSTODY
NOTICIA
Le han Demando a usted en la corte. SI usted quiere defenderse de estas
demandas expuestas en las paginas siguientes, usted Ilene viente (20) dias de
plazo al partir de la fecha de la demands y Is notificacion. Usted dove presenter
una apariencia excrita o an persona o por abogado y archivar an to corte an
forma escrita sus defensas o sus objeclones a las demandas an contra de su
persona. Sea avisado que si usted no se defiende, la corte tomara medidas y
puede entrar una orden contra usted sin previo aviso o notificacion y por
cuaiquier queja o aiivio qua as pedido an Is peticion do demanda. Usted puede
perder dinero o sus propiedades o otros derechos Importanates pare usted
LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL
SERVICIO, VAYA EN PERSONA 0 LLAME POR TELFONO A LA OFICINA
CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR
DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
PAMELA A. BRADLEY,
Plaintiff
V.
KENNETH P. BRADLEY,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 9 9 G `/97 Tcv-
: CIVIL ACTION - LAW
: IN DIVORCE & CUSTODY
COMPLAINT IN DIVORCE
DIVORCE
AND NOW, comes the Plaintiff, PAMELA A. BRADLEY, by her attorney,
Mindy S. Goodman, Attorney at Law, and seeks to obtain a decree in divorce
from the above-named Defendant, upon the grounds hereinafter set forth:
1. The Plaintiff, PAMELA A. BRADLEY, is an ad u;: individual who
currently resides at 821 Pheasant Drive North, Carlisle, Cumberland County,
Pennsylvania 11013.
2. The Defendant, KENNETH P. BRADLEY, is an adult individual
who currently resides at 821 Pheasant Drive North, Carlisle, Cumberland County,
Pennsylvania 17013.
3. The Plaintiff's Social Security Numbers is 163-60-9331.
4. The Defendant's Social Security Number is 04748-3380.
5. The Plaintiff and Defendant are sui Juris, and both have been bona
fide residents of the Commonwealth of Pennsylvania for a period of more than
six months immediately preceding the filing of this Complaint.
3
8. The Plaintiff and Defendant were married July 10, 1988, in Ft. +.
Benjamin Harrison, Marion County, Indianapolis, Indiana.
7. The Plaintiff avers that there is one child born of the parties under x
the age of 18, namely:
Name: Date of Birth:
Jared Neil Bradley June 3, 1992
8. Neither Plaintiff nor Defendant is in the military or naval service of
the United States or its allies within the provisions of the Soldiers' and Sailors'
Civil Relief Act of the Congress of 1940 and its Amendments.
9. The cause of action and section of the Divorce Code under which
the Plaintiff is proceeding is:
23 Pa. Cons. Stat. § 3301(c) or, In the alternative, 23 Pa. Cons.
Stat. § 3301(d). The marriage of the parties Is Irretrievably broken.
10. There have been no prior actions of divorce or annulment between
the parties in this or any other jurisdiction.
11. Plaintiff has been advised of the availability of counseling and that
Plaintiff may have the right to request the parties to participate in counseling.
WHEREFORE, Plaintiff requests This Court enter a Decree of Divorce in
her favor.
COUNTI
EQUITABLE DISTRIBUTION
12. Paragraphs 1 through 11 of this Complaint are incorporated herein
by reference as though set forth in full.
13. Plaintiff and Defendant have acquired property, both real and
personal, during their marriage, from the date of their marriage until the date of
their separation.
14. Plaintiff and Defendant have been unable to agree as to an
equitable division of said property.
WHEREFORE, Plaintiff requests your Honorable Court to equitably divide
all marital property.
COUNT II
ALIMONY PENDENTE LITE, SUPPORT, COUNSEL FEES AND EXPENSES
15. Paragraphs 1 through 14 of this Complaint are incorporated herein
by reference as though set forth in full.
16. By reason of this action, Plaintiff will be put to considerable
expense in the preparation of her case, in the employment of counsel, and the
payment of costs.
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17. Plaintiff is without sufficient funds to support herself and to meet the
costs and expenses of this litigation and is unable to appropriately maintain
herself during the pendency of this action.
18. Plaintiff's income is not sufficient to provide for her reasonable
needs and pay attorneys' fees and the cost of this litigation.
19. Defendant has adequate earnings to provide support and alimony
pendente lite for Plaintiff and to pay her counsel fees, costs and expenses.
WHEREFORE, Plaintiff requests your Honorable Court to compel
Defendant to pay Plaintiff alimony pendente lite, support, counsel fees, costs and
expenses of this action.
COUNT III
CUSTODY
20. Paragraphs 1 through 19 of this Complaint are incorporated herein
by reference as though set forth in full.
21. Plaintiff seeks primary custody of the parties' minor child, Jared Neil
Bradley.
22. The child is presently in the custody of Pamela A. Bradley, the
Plaintiff In this case.
6
23. During the past five years, the child has lived with the following
persons and at the following address:
Pamela A. Bradley and 821 Pheasant Drive North
Kenneth P. Bradley Carlisle, PA 17013
23. Plaintiff has not participated as a party, witness, or in any other
capacity regarding custody in this or any other court.
24. Plaintiff does not have any information of any custody proceeding
concerning said children pending in a court of this or any other state.
25. Plaintiff knows of no person not a party to this proceeding who has
physical custody of said child or claims to have custody or visitation rights with
respect to this child.
WHEREFORE, Plaintiff requests your Honorable Court to award primary
physical custody of the child, Jared Neil Bradley, to the Plaintiff subject to
reasonable visitation rights to Defendant.
Respectfully submitted,
Mindy S. Goodman
Attorney at Law
Attorney I.D. No. 78407
2080 Linglestown Road
Harrisburg, PA 17110
(717) 540-8742
Attorney for Plaintiff
VERIFICATION
I verify that the statements made in the Complaint for Divorce and
Custody are true and correct. I understand that false statements herein are
made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom
falsification to authorities.
Pamela A. Bradley
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PAMELA A. BRADLEY, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 97--6497
KENNETH P. BRADLEY,
Defendant
CERTIFICATE OF SERVICE
I, Mindy S. Goodman, Attorney at Law, certify that on the 5t' day of
November, 1999,1 served a true and correct copy of the Complaint in Divorce
upon the Defendant, Kenneth P. Bradley, by depositing the same In the United
States First Class Mail, send Certified, Restricted Delivery, Return Receipt
Requested. A copy of the Return Receipt is attached hereto.
1 verify that the statements made in this Certificate of Service are true and
correct. I understand that false statements herein are made subject to the
penalties of 18 Pa. Cons. Stat. § 4904, relating to unsworn falsification to
authorities.
Mindy S. Goodman
Attorney at Law
ID No.78407
2215 Forest Hills Drive - Suite 35
Harrisburg, PA 17112
(717) 540-8742
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Pamela A. Bradley, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO 81.8497
Kenneth P. Bradley,
Defendant : CIVIL ACTION - LAW
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint In Divorce under Section 3301(c) of the Divorce Code was filed on October
27,1999.
2. The marriage of plaintiff and defendant is Irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. 1 consent to the entry of a final Decree in Divorce after service of notice of Intention to
request entry of the Decree.
I verify that the statements made in this Affidavit are true and correct to the best of my
knowledge, Information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa.C.S. 4904 relating to unswom falsification to authorities.
Pamela A. Bradley, Plaintiff
Date: ;y saa< 0>
WAIVER OF NO1IC9 OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 33010 OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses it I do not claim them before a divorce is granted.
3. 1 understand that I will not be divorced unlit a Divorce Decree is entered by the Court
and that a copy of the Decree will be sent to me Immediately after It is filed with the
Prothonotary.
I verify that the statements made In this Affidavit are true and correct to the best of my
knowledge, Information and ballet. I understand that false statements herein are made subject to the
penalties of 18 Pa.C.S. 4904 relating to unswom falsification to authorities.
Pamela. Bradley, Plaintiff
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Pamela A. Bradley, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. -6497
Kenneth P. Bradley,
Defendant CIVIL ACTION • LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October
27. 1999.
2. The marriage of plalntiff and defendant Is Irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. 1 consent to the entry of a final Decree in Divorce after service of notice of Intention to
request entry of the Decree.
I verity that the statements made In this Affidavit are true and correct to the best of my
knowledge, Information and belief. 1 understand that false statements herein are made subject to the
penalties of 18 Pa.C.S. 4904 relating to unswom falsification to authorities.
Kenneth P. Braley, Defb nt
Date: = ` - 0.4
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 33010 OF THE DIVORCE CODE
1. 1 consent to the entry of a final Decree of Divorce without notice.
2. 1 understand that 1 may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before u divorce is granted.
3. 1 understand that I will not be divorced until a Divorce Decree is entered by the Court
and that a copy of the Decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made In this Affidavit are true and correct to the best of my
knowledge, Information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa.C.S. 4904 relating to unswom falsification to authorities.
Kenneth P. Bradley, Defend
JaDate: :'1 ?J }?yr 0912.
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF .. PENNA.
PAMELA A. BRADLEY,
N O. 99-6497 CIVIL
Plaintiff -
VERSUS
KENNETH P. BRADLEY,
Defendant
DECREE IN
DIVORCE
AND NOW, 2002 IT IS ORDERED AND
DECREED THAT PAMELA A. BRADLEY , PLAINTIFF,
AND KENNETH P. BRADLEY DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
All economic claims have been settled.
BY THE COURT:
ATTEST: J.
PROTHONOTARY
PAMELA A. BRADLEY, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. :NO. 99-6497
KENNETH P. BRADLEY, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
SOCIAL SECURITY DISCLOSURE
Plaintiff provides the Court with the following Information in accordance
with the laws of the Commonwealth of Pennsylvania:
Plaintiffs Social Security Number is 163-60-9331.
Defendant's Social Security Number is 047-48-3360.
Respectfully submitted,
Mindy S. Goodman
Attorney at Law
2215 Forest Hills Drive - Suite 35
Harrisburg, PA 17112
(717) 540-8742
Attorney for Plaintiff
PAMELA A. BRADLEY, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 99-6497
KENNETH P. BRADLEY,
Defendant
PRAECIPE TO WTIHDRAW
Plaintiff, Pamela A. Bradley, by and through her attorney, Mindy S.
Goodman, Attorney at Law, hereby withdraws any and all claims she has made
for Equitable Distribution, Alimony, Alimony Pendente Lite, and Counsel Fees.
Mindy S. Goodman
Attorney at Law
ID No. 78407
2215 Forest Hills Drive - Suite 35
Harrisburg, PA 17112
(717) 540-8742
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PAMELA A. BRADLEY IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff CIVIL ACTION - LAW
VS. NO. 99-6497 CIVIL 19
KENNETH P. BRADLEY IN DIVORCE
Dcfcndant
STATUS SHEET
DATE:
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PAMELA A. BRADLEY, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99 - 6497 CIVIL
KENNETH P. BRADLEY,
Defendant IN DIVORCE
TO: Mindy S. Goodman , Attorney for Plaintiff
Johnna J. Kopecky , Attorney for Defendant
DATE: Tuesday, April 16, 2002
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(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.
s za
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
DATE COUNSEL FOR PLAINTIFF ( )
COUNSEL FOR DEFENDANT ( )
NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
LAW OFFICES
SAIDIS, SHUFF, FLOWER & LINDSAY
A PROFESSIONAL CORPORATION
26 WEST HIGH STRErr
JAMES D. FLOWER CARLISLE, PENNSYLVANIA 17013
JOHN E. SLIKE TELEPI IONS: (717) 243.6222 - ILACSINIILE: (717) 243.6510
ROOERTC. SAIDIS EMAIL: clindsay6ss0-law.com
GEOFFREY S. SHUFF www.501-law.c0111
JAMES D. FLOWER, JR.
CAROL), LINDSAY
KARL M. LEDEROHM
THOMAS E. FLOWER
October 9, 2002
Traci Colyer
Office of Divorce Master
9 North Hanover Street
Carlisle PA 17013
RE: Bradley v. Bradley
No. 01-6497 Civil
Dear Ms. Colyer:
WEST SHOREOFFICE:
2109 M ARKEr STREET
CAMP HILL, PA 17011
TELEPIIONE: (717)737.3105
FACSIMILE: (717)737.3407
REPLY TO CARLISLE
Enclosed please find 2 copies of the Conference Statement of Kenneth and Pamela
Bradley and a check from Mr. Bradley for $12.50.
Thank you for your help.
Very truly yours,
SAIDIS, SHUFF, FLOWER & LINDSAY
Sharon A. Morrell, Paralegal
x: Mindy S. Goodman, Esquire
PAMELA A. BRADLEY,
Plaintiff
Vs.
KENNETH P. BRADLEY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 6497 CIVIL
IN DIVORCE
THE MASTER: Today is Tuesday, September 24,
2002. This is the date set for a conference with counsel and
the parties with reference to the above captioned divorce
proceedings.
Present in the hearing room are the
Plaintiff, Pamela A. Bradley, and her counsel Mindy S.
Goodman, and the Defendant, Kenneth P. Bradley, and his
counsel Carol J. Lindsay.
This action was commenced by the filing of a
complaint in divorce on October 26, 1999, raising the economic
claims of equitable distribution and counsel fees and
expenses. No claim has been raised by either party for
alimony.
The Master has been advised that the parties
will sign and file affidavits of consent and waivers of notice
of intention to request entry of divorce decree so that the
divorce can be concluded under Section 3301(c) of the Domestic
Relations Code.
The parties were married on July 10, 1986,
and separated October 27, 1999. There is one child of the
marriage, Jared Bradley, born June 3, 1992.
The Master has been advised by counsel that
an agreement has been reached with regard to the outstanding
economic issues. The agreement is going to be placed on the
record in the presence of the parties. The agreement as
placed on the record will be considered the substantive
agreement of the parties not subject to any changes or
modifications except for correction of typographical errors
which may be made during the transcription. After the
agreement has been transcribed and reviewed for typographical
errors, the parties will affix their signatures affirming the
terms of settlement as stated on the record.
Upon receipt by the Master of the signed
agreement, the Master will prepare an order vacating his
appointment. Counsel will then be able to file a praecipe
transmitting the record to the Court requesting a final decree
in divorce. Ms. Lindsay.
MS. LINDSAY: The parties have agreed as
follows:
1. Husband will retain the marital residence at 621
Pheasant Drive North, Carlisle, Pennsylvania, and he will
refinance the mortgage on the loan, which is in joint names,
or obtain a release of wife's obligation on the mortgage
within two years. Notwithstanding that, husband will make an
application for another mortgage within one year of today's
date. Upon the refinance or release of the mortgage on the
marital home, wife will tender to husband a deed. In the
interim, husband will pay the mortgage, taxes, and insurance
and will indemnify and hold wife harmless on account of any
loss resulting from the marital home.
In the event that husband fails to refinance or
obtain a release of wife's obligation within two years as set
out above, husband will place the house on the market and sell
it in order to achieve the goal of obtaining a release of
mortgage for the wife.
2. The parties have satisfactorily divided their vehicles:
Wife retains the 1994 Pathfinder; husband the 1988 Nissan
wagon and motorcycle. Both parties will execute any documents
required by the other within ten (10) days of a request in
order to transfer the vehicles into the names of the party
retaining it in equitable distribution.
3. Both parties have PSERS pensions. Wife's counsel will
provide a Domestic Relations Order which will roll over
$5,000.00 from husband's PSERS pension into wife's PSERS
pension or such other qualified plan as the state will permit.
4. Each of the these parties has a benefit which they
obtained during military service in terms of a Veteran's
benefit or a pension and each waives any interest he or she
may have in the military benefit of the other.
5. Husband will retain his life insurance policy with
metropolitan Life and wife waives any claim she has for any
interest in that policy. However, husband will be solely
responsible for any debt incurred in loans against the life
insurance policy.
6. Credit in the overall settlement set out herein is
given to wife for $5,893.00 on a joint CBW Schools Federal
Credit Union loan which she avers is paid in full at this
time, and also for two credit cards, one a Visa and the other
a Discover Card with a total indebtedness of $2,000.00.
Husband is given credit here today for payment of a loan with
Capital one with a date of separation balance of approximately
$4,400.00. Although both parties aver these obligations have
been paid in full, they will indemnify and hold the other
harmless against any claim by any of the creditors involved on
the debts that they have agreed to pay.
7. Husband will pay to wife $7,500.00 within sixty (60)
days of the date of this agreement.
8. The parties waive any claim that they may have for
attorney fees and costs.
9. Wife will receive the hot tub which is currently in
husband's possession but all other personalty shall remain the
sole and separate property of the party in whose possession it
is as of today's date. Absent an agreement of the parties to
the contrary, wife will remove the hot tub within three (3)
months.
10. Except as herein otherwise provided, each party may
dispose of his or her property in any way and each party
hereby waives and relinquishes any and all rights he or she
may now have or hereafter acquire under the present or future
laws of any jurisdiction to share in the property or the
estate of the other as a result of the marital relationship
including without limitation, statutory allowance, widow's
allowance, right of intestacy, right to take against the will
of the other, and right to act as administrator or executor in
the other's estate. Each will at the request of the other
execute, acknowledge, and deliver any and all instruments
which may be necessary or advisable to carry into effect this
mutual waiver and relinquishment of all such interest, rights,
and claims.
MS. LINDSAY: Mr. Bradley, you have been in
the conference room here with me today as I dictated the terms
of agreement with Pamela; is that correct?
MR. BRADLEY: That is correct.
MS. LINDSAY: And did you hear all of those
terms?
MR. BRADLEY: Correct.
MS. LINDSAY: Are they acceptable to you?
MR. BRADLEY: They are acceptable.
MS. LINDSAY: Is there anything you did not
understand?
MR. BRADLEY: No.
(A discussion was held off the record.)
MS. GOODMAN: Ms. Bradley, were you present
in the room when each of the provisions of the agreement were
read into the record?
MS. BRADLEY: Yes.
MS. GOODMAN: Do you have any questions about
any of the provisions that were read onto the record?
MS. BRADLEY: No.
MS. GOODMAN: Do you accept the provisions as
stated?
MS. BRADLEY: I accept them.
MS. GOODMAN: And do you consent to the
divorce?
MS. BRADLEY: I consent to the divorce.
I acknowledge that I have read the above
stipulation and agreement, that I understand the terms of
settlement as set forth herein, and that by signing below I
ratify and affirm the agreement previously made and intend to
bind myself to the settlement as a contract obligating myself
to the terms of settlement and subjecting myself to the
methods and procedures of enforcement which may be imposed by
law and in particular Section 3105 of the Domestic Relations
Code.
WITNESS:
Mindy S. Goodman
Attorney for Plaintiff
Carol J. Lindsay
Attorney for Defendant
DATE:
Pamela A. Bradley
Kenneth P. Bradley
4b
E. Robert Elicker, 11
Divorce Master
Traci Jo Colyer
Office Manager/Reporter
September 25, 2002
Mindy S. Goodman
Attorney at Law
Northwood office
2215 Forest Hills
Suite 35
OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240.6535
West Shore
697.0371 Ext. 6535
Carol J. Lindsay
Attorney at Law
Center SAIDIS, SHUFF, FLOWER & LINDSAY
Drive 26 West High Street
Carlisle, PA 17013
Harrisburg, PA 17112
RE: Pamela A. Bradley vs. Kenneth P. Bradley
No. 99 - 6497 Civil
In Divorce
Dear Ms. Goodman and Ms. Lindsay:
Enclosed is a draft of the agreement which you put on
the record on September 24, 2002. Please review the draft
for any corrections with the understanding that no
substantive changes can be made.
After you have reviewed the draft, give us a call so
we can make appropriate corrections. We will send the
corrected original to the Plaintiff's attorney for signature
who then can transmit the original to the Defendant's
attorney for signature. When I receive a signed copy of the
document, I will then obtain a Court order vacating my
appointment.
Thank you for your continuing cooperation in bringing
this matter to settlement.
Very truly yours,
E. Robert Elicker, II
Divorce Master
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PAMELA A. BRADLEY, :IN THE COURT OF COMMON EA/ ?
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : NO. 99-6497
KENNETH P. BRADLEY, : Civil Action - Law
Plaintiff : Divorce
PLAINTIFF'S PRETRIAL STATEMENT
In accordance with Pa.R.C.P. 1920.33, Plaintiff files this Pretrial Statement
and serves a copy of said Pretrial Statement upon Johnna J. Kopecky, Esquire,
counsel for Defendant, and represents as follows:
1. List of Assets -
A. Marital Assets:
Item Description Names of Date of Current
Number of Property all Owners Acquisition Value
1. Marital Residence
Amount of Lien
$88,260.00
Joint During Marriage $121,000
Date/Holder of Lien Current Eouity
Wells Fargo Property in
Husband's
possession; equity
is $32,740. Wife
claims rental value
as Husband has
had exclusive
possession since
separation in
October of 1999.
Number
2.
Real Property
Amount of Lien
N/A
Joint 1990
Date/Holder of Lien
Value
$15,000
Current Equity
Property sold In
2000, parties
divided proceeds
equally
Item Description Names of Date of Current
Number of Property all Owners Acaulsition Value
3. 1994 Nissan Pathfinder Joint Marital $8,000
Amount of Lien Date/Holder of Lien Current Eauity
Unencumbered N/A $8,000 - Vehicle
destroyed,
insurance
paid $8,000 tj Wife
Item Description Names of Date of Current
umber of Propert y all Owners Acquisition Value
4. 1988 Nissan Wagon Husband Marital $2,000
Amount of Lien Date/Holder of Lien Current Equity
Unencumbered N/A $2,000. Vehicle in
Husband's
exclusive
possession.
2
Number of Prooertv all Owners Acquisition Value
5. 1990 Yamaha Cycle Husband Marital $750
Amount of Lien Date/Holder of Lien Current Eauity
Unencumbered N/A $750- Husband
Item Description Names of Date of Current
Number of Property all Owners Acquisition value
6. Hot Tub Joint Marital $4,000
Amount of Lien Date/Holder of Lien Current Equity
$7,944.70 Bob's In Towne Spas - $6,944.70 Husband in
possession
Discover - $1000.00
Item Description Names of Date of Current
Number of Prooert v all Owners Acquisition Value
7. Washer/dryer set Joint Marital $200
Amount of Lien Date/Holder of Lien Current Equity
Unencumbered N/A $200 - Wife
Item Description Names of Date of Current
Number of Property all Owners c uisition Value
8. Kitchen furniture Joint Marital $100
Amount of Lien Date/Holder of Lien Current Equity
Unencumbered N/A $100-Wife
3
Item Description Names of Date of Current
Number of Prooert v all Owners Acquisition Value
9. Microwave Oven Joint Marital $25
Amount of Lien Date/Holder of Lien Current Equity
Unencumbered N/A $25 - Wife
Number of Property all Owners Acquisition Value
10. Computer Joint Marital $150
Amount of Lien Date/Holder of Lien Current Equity
Unencumbered N/A $150 - Wife
Number of Propert y all Owners c uisitio Value
11. Video Camera Joint Marital $100
Amount of Lien Date/Holder of Lien Current Eaulty
N/A N/A $100- Husband
12. Dishwasher
Amount of Lien
N/A
all Owners
Joint
Date/Holder of Lien
N/A
Marital $100
Current Eauity
$100- Husband
4
Item Description
umber of Prooert
v
13. Refrigerator
Amount of Lien
N/A
Names of
all Owners
Joint
Date/Holder of Lien
N/A
Date of Current
Acquisition Value
Marital $600
Current Eauity
$600- Husband
Number of Property all Owners Acquisition Value
14. Freezer Chest Joint Marital $50
Amount of Lien Date/Holder of Lien Current Eauity
Unencumbered N/A $50- Husband
Item Description Names of Date of Current
Number of Prooert v all Owners Acquisition Value
15. Carpet Cleaner Joint Marital $100
Amount of Lien Date/Holder of Lien Current Eauity
Unencumbered N/A $100 - Husband
Number of Property
16. Snowblower
Amount of Lien
Unencumbered
Joint
Date/Holder of Lien
N/A
c uia sition Value
Marital $150
Current Eauity
$150 - Wife
5
r .
Number of Propert y all Owners Acoulsition Value
17. Living Room Furn. Joint Marital $500
Amount of Lien Date/Holder of Lien Current Eauity
Unencumbered N/A $500- Husband
Number of Property all Owners Acquisition Value
18. Bedroom Furn. Joint Marital $200
Amount of Lien Date/Holder of Lien Current Eauity
Unencumbered N/A $200- Husband
19. Waterbed
Amount of Lien
Unencumbered
Joint
Date/Holder of Lien
N/A
Marital $100
Current Eauity
$100- Husband
Number of Propert
y
20. Misc. Tools
Amount of Lien
Unencumbered
Joint
Date/Holder of Lien
N/A
Marital $600
Current Equity
$600- Husband
6
Item Description Names of Date of Current
Number of Prooert v all Owners Acquisition Value
21. Two Television Sets Joint Marital $100
Amount of Lien Date/Holder of Lien Current Equity
Unencumbered N/A $50- Husband
$50 - Wife
Number of Prooert v all Owners c uisition value
22. Met Life Life Ins. Husband Marital $19,141.56
Amount of Lien Date/Holder of Lien Current Eauity
N/A N/A $19,141.56 - Husband
Item Description Names of Date of Current
umber of Prooertv all Owners Acquisition value
23. State Retirement Husband Marital $10,000
Amount of Lien Date/Holder of Lien Current Eauity
N/A N/A $10,000 - Husband
24. Military Retirement
Amount of Lien
N/A
all Owners
Husband
Date/Holder of Lien
N/A
Partially Marital Pays
$1300 a mo.
Current Eauity
Husband's control
7
B. Non-Marital Assets:
1. Wife has pension with Commonwealth of Pennsylvania
valued at approximately $3,000. All funds In Wife's pension contributed after the
date of separation.
2. Husband has additional pension funds with the
Commonwealth of Pennsylvania valued at approximately $4,500. These funds
were contributed after the date of separation.
II. EXPERT WITNESSES -
Plaintiff does not anticipate calling any expert witnesses at this time;
however, Plaintiff reserves the right to supplement this list as needed prior to the
date of hearing.
III. SUMMARY WITNESSES OTHER THAN PLAINTIFF -
Plaintiff does not anticipate calling any other summary witnesses other
than the Plaintiff; however, Plaintiff reserves the right to supplement this list as
needed prior to the date of the hearing.
IV. EXHIBITS -
Defendant has not provided Plaintiff with an Inventory and Appraisement
or an Income and Expense Statement; however, by letter dated April 15, 2002,
Johnna J. Kopecky, Counsel for Defendant, Indicated that there was not a great
8
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deal of discrepancy on the personal property listed in Plaintiffs Inventory and
Appralsement except with regard to the value of Defendant's life Insurance
policy. Consequently, Plaintiff marks the letter of April 15, 2002 as Plaintiffs
Exhibit 1, a statement regarding the value of the life Insurance policy as Plaintiffs
Exhibit 2, and statements regarding Defendant's retirement benefits with the
Commonwealth as Exhibit 3. Plaintiff reserves the right to supplement this list as
needed prior to the date of the hearing.
V. Income-
Plaintiffs gross annual income:
a. Department of Veterans Affairs - $ 6,288.00
(Benefits will be reduced to $5,688 once
divorce is finalized.)
b. Commonwealth of Pennsylvania - $29,977.78
TOTAL GROSS INCOME $36,265.78
Plaintiffs deduction from Gross Income:
a. Federal Income Tax Withheld - $ 3,529.50
b. Social Security Tax Withheld - $ 1,956.46
C. Medicare Tax Withheld - $ 457.56
d. State Income Tax Withheld - $ 883.60
e. Local Tax Withheld - $ 315.50
f. Retirement - $ 1,577,72
g. Occupational Privilege Tax - $ 10.00
h. Union Dues - $ 360.56
TOTAL TAXES WITHHELD $ 9,090.90
9
Defendant's gross annual Income:
a. Defense Finance and Accounting Service - $13,989.72
b. Commonwealth of Pennsylvania- $26,478.96
TOTAL GROSS INCOME $40,468.68
Defendant's deduction from Gross Income: Defendant has provided insufficient
information to outline his deductions.
VI. Retirement Benefits -
Plaintiff has retirement benefits through her employment with the
Commonwealth of Pennsylvania. Plaintiff did not commence employment with
the Commonwealth until after the date of separation; consequently, none of
Plaintiffs benefits are marital.
Defendant has retirement benefits through the military and his employment
with the Commonwealth of Pennsylvania. The military benefits are paid monthly.
In spite of multiple requests for Information sufficient to determine the marital
portion of the military, Defendant has failed to provide such Information and
therefore Plaintiff claims that all of the military pension should be viewed as
marital.
Defendant has retirement benefits through her employment with the
Commonwealth of Pennsylvania. The value of the marital portion of the benefits
has been determined to be approximately $10,000. Defendant, by letter of April
15, 2002 and marked for identification as Plaintiffs Exhibit 1, has failed to take
Issue with Plaintiffs determination of the value of the marital portion of retirement
benefits. In determining the value of Defendant's retirement benefits with the
Commonwealth, Defendant provided Plaintiff with statements from 1997, 1998
and 2001. It appears from the statements that there is an Increase of
approximately $1,500 annually in the value of the pension, and the 1999 value
would therefore be estimated at $10,000.
VII. Counsel Fees -
Plaintiff is requesting reimbursement of counsel fees In the amount of $5,000.
Plaintiff has had to expend money on counsel fees unnecessarily as a result of
Defendant's failure to cooperate and provide documentation as requested. For
example, when Defendant did not provide requested information voluntarily,
Plaintiff filed a Request for Production of Documents, which were to be answered
within thirty (30) days of filing. Defendant failed to respond to the Request for
10
Y
Production of Documents and Plaintiff was forced to expend additional sums by
filing a Motion to Compel Production. Those documents that were ultimately
provided were Inadequate to fully determine the value of the marital property.
Plaintiff has filed and served on Defendant an Inventory and Appraisement as
well as an Income and Expense Statement; however, Defendant has failed to file
similar documents and has failed to provide Plaintiff with copies of these
documents.
An itemized list of charges is attached hereto.
VIII. Marital Debt -
Item Description Name of Name of Outstandina
u be of Deb Creditors Debtors Balance
1. Mortgage Wells Fargo Joint $88,260
When Debt Incurred Liability as of Sep.
Marital $90,000
2. Hot Tub Debt Bob's Spas/Discover Joint $3,500
When Debt Incurred
Marital
Liability as of Sep.
$7,944.70
Item Description Name of Name of Outstandina
umbe of Debt Creditors Debtors Balance
3. Roof and Deck C-B-W Schools Joint $1000
Fed Credit Union
When Debt Incurred
Marital
Liability as of Sea.
$5,893.04
IX. Proposed Resolution -
Plaintiff proposes the following:
a. MARITAL RESIDENCE -
1. The marital residence should be sold and the net
proceeds divided equally between the parties once the mortgage
and all closing costs have been paid. (In the alternative, if
Defendant would like to retain the marital residence, Defendant
should pay to Plaintiff the sum of $16,370, which represents one-
half of the equity in the marital residence.)
2. Husband should pay to Wife the sum of $11,200 as
rental value for that period in which he had exclusive possession of
the marital residence.
b. MOTOR VEHICLES -
1. The parties should each retain their motor vehicle and
be solely responsible for any encumbrance thereon.
C. PERSONAL PROPERTY -
1. Wife should retain the Hot Tub, which is presently
located at the marital residence. Wife has been solely
responsible for the loan since the date of separation in spite
of the fact that Defendant has had sole use and enjoyment
of the tub. Wife will be responsible for the balance of the Hot
Tub loan.
2. Each of the parties should retain the household Items
of personal property that are presently in his or her
possession, in spite of the fact that Husband has retained
the majority of the household Items of value.
d. LIFE INSURANCE -
1. Husband should pay to Wife the sum of $8,500, which
represents one-half of the surrender value of the Met Life
Insurance Policy as of the date of separation.
12
e. RETIREMENT BENEFITS -
1. Husband should transfer the sum of $5,000 from his
retirement plan with the Commonwealth of Pennsylvania to
Wife's retirement plan with the Commonwealth of
Pennsylvania.
2. Wife should be entitled to receive one-third of the
military pension paid to Husband on a monthly basis. The
military can pay one-third of the monthly benefit directly to
Wife.
3. Each of the parties shall retain their retirement
benefits with the Commonwealth of Pennsylvania that were
acquired after the date of separation.
f. ATTORNEY'S FEES -
1. Husband should pay to Wife the sum of $5,000, which
represents a portion of the amount that Wife has expended
In attorney's fees since the commencement of the divorce
action through its completion.
Respectfully submitted,
Mindy S. Goodman
Attorney at Law
ID No. 78407
Northwood Office Center
2215 Forest Hills Drive - Suite 35
Harrisburg, PA 17112
(717) 540-8742
Attorney for Plaintiff
13
LAW OFFICES
SAIDIS, SNUFF, (LOWER & LINDSAY
A PROFESSIONAL CORPORATION
26 WEST HIGI I STREET
JAXIES D. FLOWER CARLISLE, PENNSYLVANIA 17013
JOI IN E. SLIKE TELEI'I IONS: (717) 243-6222. FACSIMILE: (717) 243.6486
ROBERT C SAIDIS ENTAIL: allornoydWI-law.COm
GEOFFREY S. SNUFF wa wssR•L?w.com
JAMES D. FLOWER, JR.
CAROL. J. LINDSAY
101 WNA J. KOPECKY
KARL ht. LBDEBOI ISI
JOSEPI I L. I IITCHINGS
THOINIASE. FLOWER
FORRFS-1• N. TROursIAN,11
April 15, 2002
Mindy S. Goodman, Esquire
2080 Linglestown Road
Harrisburg, PA 17110
Dear Mindy:
WEST SIIOREOFFICF:
2109 MARKET STREET
CAMP I TILL, PA 17011
1 ELEI'I IONS: (717)737-3405
FACSIMILE: (717)737.3407
REPLY TO CARLISLE
am enclosing some information a copy of the 2001 Statement of Account from Mr.
Bradley's retirement, along with his 2001 Income Tax Return.
As far as the retirement that Mr. Bradley is receiving, he does not receive statements but
only shows a net deposit of $1,050.00 each month directly Into his account. He advises
that he pays $75.00 a month for the survivor benefit plan, for which Ms. Bradley is the
beneficiary. He is going to try to see if he can get a statement advising this, and as far as
he knows, she will remain on here with Jared as the secondary beneficiary.
will be sending in a Pre-Trial Statement and an Income and Expense Statement to the
Master. While we do not have a great deal of discrepancy on the personal property that
you listed, the major error In client's inventory and appraisemenl is the fact that you have
the $19,141.56 net life Insurance listed as an asset, when it is in fact, this is the amount of
the loan that he owes. He Is a paying a monthly amount toward that; however, Met-Life is
not requiring a certain minimum amount that he needs to pay each month.
If you have any questions regording this Information, kindly advise, but perhaps this would
greatly change Ms. Bradley's request for a lump sum cash payment for equitable
distribution of the marital assets.
Very truly yours,
SAIDIS, SHU LOW 8 INDSAY
Joh a J. Kop ky
JJK/ahg
Cc: Ken Bradley
Enclosures
y ??nlrns,
tiXl1? ??
In Force Life Insurance Policy Illustration Version 1 2.9
Metropolitan Life Insurance Company Invalid after 06/30/2000
New York, NY 10010
Insured: KENNETH P. BRADLEY
Policy Number: 855015434UL
Issue Date: 11/21/1985
Policy Type: Flexible Premium Life(UL)t Form no. 7UL-90
Risk Class: Male Standard Age 31
Issue State: Pennsylvania
Death Benefit Option B Death benefit equals Specified Face Amount
plus the Accumulation fund
Values as of 11/22/1999:
Existing Accumulation Fund: $19,135.81
Premium Paid to Date: $17,526.44
Outstanding Policy Loan: $8,121.06
Current Death Benefit: $111,014
Illustrated Coverage
Base Policy - Current Specified Amount $100,000
What This Illustration Shows
This illustration shows values over time for the MetLife universal life insurance policy
and riders shown above on a guaranteed and a non-guaranteed basis. This illustration:
. reflects any withdrawals or loans made prior to the date of the illustration
does not change any terms of your policy
was designed to help you understand how this policy works and is NOT a projection of how it
will perform.
Please note: The policy information and values shown above were manually input by your sales
representative. This information was used to compute the values in the illustration. Please
compare, with your sales representative, the information and values shown above to the most
recent annual statement you receive from MetLife. If you have any questions, please ask your
sales representative.
Date Prepared: 11/23/1999 Page 1 of 05 99032X26(exp0600)MLIC-LD
In Force Life Insurance Policy Illustration Version 4 2.9
Metropolitan Life Insurance Company Invalid after 06/30/2000
New York, NY 10010
Insured: KENNETH P. BRADLEY Policy Number: 855015434UL
This illustration reflects the policy's values assuming you pay all amounts shown in the Premium
Outlay column at the beginning of each policy month, and that any withdrawals and/or loans
illustrated are made at the beginning of the policy year.
The policy's guaranteed values, under the above stated assumptions, will never be less than
those shown.
The non-guaranteed values shown in this illustration further assume that the illustrated
interest rate and the current cost of insurances rates will continue unchanged for all years
shown. This is not likely to occur, and actual results may be more or less favorable than those
shown,
If the interest rate shown decreases and/or current cost of insurance rates increase, the
planned premium outlay may need to be increased and/or continued beyond the number of years
shown in order to keep this policy in force or attain the non-guaranteed values and benefits
shown in this illustration.
In addition, the extent to which you borrow or withdraw your policy's cash value will also cause
your cash values and death benefits to vary. The cash value and death benefit columns in this
illustration show the effect of any and all charges applicable to this policy.
This illustration does not test this policy for Modified Endowment Contract (MEC) status.
Please consult your tax or legal advisor.
Illustration prepared by:
NAME
ADDRESS
(MetLife Representative: you MUST enter your business address in the spaces above.)
Date Prepared: 11/23/1999 Page 2 of 05 99032X26(exp0600)MLIC-LO
In Force Life Insurance Policy Illustration Version ! 2.9
Metropolitan Life Insurance Company Invalid after 06/30/2000
New xork, NY 10010
Insured: KENNETH P. BRADLEY
Policy Number:
855015434UL
Column Definitions
The cash value and death benefit amounts shown in this illustration reflect illustrated
withdrawals, illustrated policy loans, and loan interest. Cash values and death benefits shown
also reflect any withdrawals and loans made prior to the date of the illustration.
PLANNED ANNUALIZED PREMIUM OUTLAY - This column reflects the total of the monthly premiums paid
during the policy year.
POLICY VALUES BORROWED - The amount of the policy loan taken at the beginning of the current
policy year plus any loan interest due that has not been paid in cash.
ANNUAL LOAN INTEREST - The loan interest due at the beginning of the current policy year, based
on the total loan outstanding at the end of the prior policy year.
GUARANTEED COLUMNS - All values and benefits described below assume maximum cost of insurance
charges and guaranteed minimum interest rates (48) credited starting from the date of this
illustration.
PAID FOR YOU FROM POLICY VALUES - This column includes the sum of the expense charges and cost
of insurance charges (for the base policy and any illustrated riders) that is in excess of the
net premium (premium outlay less premium load), and is being paid for by monthly deduction from
the policy's accumulation fund. This column also includes any loan interest not paid in cash.
(GUARANTEED) REMAINING CASH VALUE - MetLife guarantees to pay you this amount on surrender of
this policy. The amount shown reflects any applicable withdrawal charge.
(GUARANTEED) REMAINING DEATH BENEFIT - MetLife guarantees to pay this amount if the insured dies
while this policy is in force.
(NON-GUARANTEED) COLUMNS - All values and benefits described below are NOT GUARANTEED and
reflect the current non-guaranteed cost of insurance charges and a non-guaranteed interest rate
of 5.158 on amounts over $1,000 in the accumulation fund. If there is a loan against this
policy, interest on that portion of the accumulation fund over $1,000 that equals the loan will
be at a rate we set. This rate will not be less than 48 per year.
PAID FOR YOU FROM POLICY VALUES - This column includes the sum of the expense charges and cost
of insurance charges for the base policy and any illustrated riders that is in excess of the net
premium (premium outlay less premium load), and is being paid for by monthly deduction from the
policy's accumulation fund. This column also includes any loan interest not paid in cash.
(NON-GUARANTEED) REMAINING CASH VALUE - The amount available on surrender of this policy. The
amount shown reflects any applicable withdrawal charge.
(NON-GUARANTEED) REMAINING DEATH BENEFIT - The amount payable if the insured dies while this
policy is in force.
Date Prepared: 11/23/1999 Page 3 of 05 99032K26(expO600)MLIC-LD
In Force Life Insurance Policy Illustration
Metropolitan Life Insurance Company
New York, N.Y 10010
Insured: KENNETH P. BRADLEY
Current Specified Face Amount:
Death Benefit Option B
Yr
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
Age
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
748
75
Planned
Annualized
Premium
Outlay
1,1886
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
--Beg
Policy
Values
Borrowed
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
?olicy Number:
855015434UL
$100,000
Premium Payment Mode: Check-O-Matic
--------Guaranteed---------- --------- NON-GUARANTEED -----
4.009 5.759
--End of Year--- --End of Year--
of Yr.--
Annual
Loan
Int.
0
598
601
601
601
601
601
601
601
601
601
601
601
601
601
601
601
601
601
601
601
601
601
601
601
601
601
601
601
601
This amount does not reflect
to the date this illustration
The first time a -0- appears
policy will lapse based on th
applicable cost of insurance
Paid For
You From Remaining
Policy Cash Death
Values Value Benefit
0 12,297 112,297
902 12,803 62,803
930 13,298 63,298
964 13,784 63,784
999 14,254 64,254
1,037 14,704 64,704
1,078 15,130 65,130
1,122 15,528 65,528
1,171 15,892 65,892
1,225 16,215 66,215
1,282 16,493 66,493
1,347 16,716 66,716
1,417 16,875 66,875
1,494 16,963 66,963
1,579 16,967 66,967
1,672 16,877 66,877
1,773 16,679 66,679
1,884 16,361 66,361
2,005 15,907 65,907
2,138 15,298 65,298
2,285 14,516 64,516
2,447 13,535 63,535
2,627 12,332 62,332
2,824 10,880 60,880
3,036 9,153 59,153
3,261 7,127 57,127
3,495 4,781 54,781
3,737 2,093 52,093
0 0 0
0 0 0
Paid For
You From Remaining
Policy Cash Death
Values Value Benefit
0 12,793 112,793
791 13,779 63,779
805 14,804 64,804
829 15,871 65,871
850 16,976 66,976
871 18,124 68,124
898 19,310 69,310
926 20,535 70,535
961 21,795 71,795
995 23,091 73,091
1,037 24,419 74,419
1,086 25,774 75,774
1,135 27,156 77,156
1,183 28,567 78,567
1,239 30,002 80,002
1,294 31,463 81,463
1,365 32,934 82,934
1,435 34,418 84,418
1,512 35,909 85,909
1,596 37,398 87,398
1,694 38,871 88,871
11800 40,320 90,320
1,920 41,729 91,729
2,048 43,087 93,087
2,196 44,370 94,370
2,353 45,565 95,565
2,518 46,659 96,659
2,696 47,632 97,632
2,877 48,475 98,475
3,093 49,143 99,143
premiums, withdrawals, or loans during this policy year prior
was prepared.
in the death benefit column indicates the year that your
e premium shown, the indicated interest rate, and the
charges unless a higher premium is paid.
The guaranteed columns shown above include maximum cost of insurance charges and guaranteed
minimum interest rates starting from the date of this illustration. Non-guaranteed columns
reflect the current cost of insurance charges and the interest rate shown, WHICH CANNOT BE
GUARANTEED. NON-GUARANTEED INTEREST AND INSURANCE RATES ARE LIKELY TO BE CHANGED BY METLIFE
OVER TIME. YOUR POLICY'S ACTUAL NON-GUARANTEED VALUES AND BENEFITS WILL BE MORE OR LESS
FAVORABLE THAN THOSE SHOWN ABOVE.
Version 1 2.9
Invalid after 06/30/2000
Date Prepared: 11/23/1999 Page 4 of 05 99032X26(exp0600)MLIC-LD
In Force Life Insurance Policy Illustration Version t 2.9
- Metro politan Life Insurance Company Invalid after 06/30/2000
New Xork, NY 10010
In sured: KENNETH P . BRADLEY Policy Number: 855 015434UL
Cu rrent Specified Face Amount: $1 00,000
Death Benefit Opti on B Premium Payment Mo de: Check -O-Matic
--------Guaranteed---------- --------- NO N-GUARANTEED .....
4.006 5.759
--Beg. of Yr.-- --End of Year--- --End of Year--
Planned Paid For Paid For
Annualized Policy Annual You From Remaining You From Remaining
Premium Values Loan Policy Cash Death Policy Cash Death
Yr Age Outlay Borrowed Int. Values Value Benefit Values Value Benefit
45 76 0 0 601 0 0 0 3,319 49,617 99,617
46 77 0 0 601 0 0 0 3,566 49,863 99,863
47 78 0 0 601 0 0 0 3,831 49,851 99,851
48 79 0 0 601 0 0 0 4,119 49,541 99,541
49 80 0 0 601 0 0 0 4,438 48,884 98,884
50 81 0 0 601 0 0 0 4,767 47,850 97,850
51 82 0 0 601 0 0 0 5,129 46,383 96,383
52 83 0 0 601 0 0 0 5,517 44,433 94,433
53 84 0 0 601 0 0 0 5,931 41,943 91,943
54 85 0 0 601 0 0 0 6,364 38,864 88,864
55 86 0 0 601 0 0 0 6,794 35,164 85,164
56 87 0 0 601 0 0 0 7,252 30,780 80,780
57 88 0 0 601 0 0 0 7,954 25,419 75,419
58 89 0 0 601 0 0 0 8,611 19,073 69,073
59 90 0 0 601 0 0 0 9,312 11,640 61,640
60 91 0 0 601 0 0 0 10,082 2,986 52,986
61 928 0 0 601 0 0 0 0 0 0
The first time a -0- appears in the death benefit column indicates the year that your
policy will lapse based on the premium shown, the indicated interest rate, and the
applicable cost of insurance charges unless a higher premium is paid.
The guaranteed columns shown above include maximum cost of insurance charges and guaranteed
minimum interest rates starting from the date of this illustration. Non-guaranteed columns
reflect the current cost of insurance charges and the interest rate shown, WHICH CANNOT BE
GUARANTEED. NON-GUARANTEED INTEREST AND INSURANCE RATES ARE LIKELY TO BE CHANGED BY METLIFE
OVER TIME. YOUR POLICY'S ACTUAL NON-GUARANTEED VALUES AND BENEFITS WILL BE MORE OR LESS
FAVORABLE THAN THOSE SHOWN ABOVE.
Date Prepared: 11/23/1999 Page 5 of 05 99032X26(exp0600)MLIC-LD
COMMONWEALTH OF PENNSYLVANIA
STATE EMPLOYS PLOYEES' RETIREM1DNT SYSTEM
TOLL FREE 1.800.633.5461
w .Wrs.sute.j%Lus 2&5
2001 STATEMENT OF ACCOUNT
For: KENNETH P BRADLEY
BASIC DATA
Personal Data
Social Security Number: 047.48.3360
Sex: MALE Birth Date: 09•AUG-1954
Coverage Type: FULL
Contribution Rate: 5.00%
Counseling Center: HARRISBURG
Normal Retirement Date: 09•AUG-2014
Final Averse Sala : 526,60132
2001 Retirement Covered Earnings: S21872.62
Total SSI Ncn•Covered Earnings:
Joint Coverage Conversion Amount:
Mandatory Debt:
Service Purchase Debt:
Service Credit as of December 31, 2001•
Class Years Service Class Years of Service
A-60 10.0681
TOTAL S ERVICE 10.0681
' If you are eligible to purchase creditable state and/or
non-state service. contact your Retirement Coun•elor for
information on purchasing service. All requests to
purchase service must be filed while you are an active,
contributing member.
•' Information filed on a Nomination of Beneficiary(ies)
form before 1993 or since December 31, 2001, or involving
special circumstances (such as the designation of an estate
or trust as your beneficiary) may not appear. A marimum
of 10 beneficiaries may be shown here; however, you may
have more beneficiaries in your retirement record. Keep
your beneficiary nomination current. You may change your
beneficiary nomination at any time by filing a new
Nomination of Bentficlary(tes) form with SERS. Forms are
available from your agency Personnel Offce or your
regional SERS Retirement Counseling Center. Please contact
us If you do not want your beneficiary(les) listed on future
statements.
SERSOA
IIII (IIII II I I? III III I I? lill IIII IIII IIII III III lilt IIII Ilill IIII liil II II IIII
Account Balance
Regular
Contribution SSI
Contribution
December 31, 2000, Balance 12 046.71
Contributions 51 393.66
Lump Sum Payments
Arrears Payments
Credited Interest 5509.68
YTD Ad'ustmerts'•"
December 31, 2001, Balance S13.950.05
TOTAL DEDUCTIONS 513 950.05
Arrears Balance as of December 31, 2001
Regular SSI
Taxable Breakdown of Your Account ••••
Taxable Contributions $11,533.88
Pre 87 Non-Taxable Contributions
Post 86 Non-Taxable Contributions
Credited Interest Taxable $2,426.17
December 31, 2001, Balance S13,950.05
•'• YTD (Year-To-Date) Adjustments reflect corrections to
your account for which you already have received
notification.
" SERS is a defined benefit plan under Internal
Revenue Service Code Section 401 (a).
SPECIAL CONDITION'S
The following special conditions apply to your benefit
estimate or reasons estimates were not calculated.
I3101mr
3
IIII IIII IIII IIII lilll IIII l ill ?l 111 111111111 loll
1997 STATEMENT of ACCOUNT
For: KENNETH P BRADLEY
Your statement contains three sections: SECTION 1: BASIC DATA
SECTION II: ESTIMATED RETIREMENT BENEFITS AS OF DECEMBER 31, 1997
SECTION III: ESTIMATED RETIREMENT BENEFITS PROJECTED TO NORMAL RETIREMENT
SECTION 1: BASIC DATA --?
Personal Data
Social Security Number: 047-48-3360
Sex: MALE
Binh Date: 09-AUG-1884
Coverage Type: FULL
Contribution Rate: 5.00%
Counseling Center: HARRISBURG
Normal Retirement Date: 08-AUG-2014
Final Average Salary: $21.767.49
1997 Retirement Covered Earnings: 522.779.37
Total SSI Non•COVered Earnings:
Joint Coverage Conversion Amount:
Mandatory Debt:
Service Credit as of Dec. 31. 1997•
Class Years of Service Class Years of Service
A-60 e.o681
TOTAL SERVICE 6.0081
Account Balance
Regular
Contributions SSI
Contributions
Dec. 31,1996,13alance $5,701.38
Contributions $1.130.07
Lump Sum Payments
Arrears Payments
Credited Interest $252,57
YTD Adjustments %%
Dec. 31, 1997, Balance $7, 153.03
TOTAL DEDUCTIONS $7.153.03
Arrears Balance as of Dec. 31, 1997
Regular SSI
Taxable Breakdown of Your Accounto%%
Taxable Contributions $5,354.81
Previously Taxed Contributions
Credited Interest (Taxable1 $798.22
Dec. 31, 1997, Balance $7 t53.03
SPECIAL CONDITIONS
Due to the following reasonts), special conditions apply to
your benefit estimates or estimates have not been calculated.
YOU have Insufficient service credits to qualify
for a regular retirement benefit.
'If you are eligible to purchase creditable state and/or non.
state service. contact your Retirement Counselor for
information on purchasing service. All requests to purchase
service must be fled while you are an active, contributing
member.
• • Information filed opt a Nomination of Benefciary(ies) form
before 1993 or since Dec. 31, 1997, or involving special
circumstances (such as the designation of an estate or trust as
your benefcvary) may not appear. A maximum of 10
beneficiaries mqv be shown here: however, you may have
more beneficiaries in sour retirement record Keep your
benefician. nomination current. You may change your
beneflelary nomination at any time by fling a new
Nomination of Benefleiury(les) form with SERS. Forms are
avallable from your agency Personnel O/f ce or your
regional SERS Retirement Counseling Center. Please
contact us If you do not want your benefclaty(les) listed on
future Statements.
%%YTD (Year. To-Date) adjustments reflect corrections to your
account for %hich you alrcadv have received notification.
%%%%SERS is a defined benefit plan under Internal Revenue
Seri-ice Code Section 401 (a).
1998 STATEMENT of ACCOUNT
For: KENNETH P BRADLEY
Your statement contains three sections: SECTION I: BASIC DATA
SECTION II: ESTIMATED RETIREMENT BENEFITS AS OF DECEMBER 31, 1998
SECTION III: ESTIMATED RETIREMENT BENEFITS PROJECTED TO NORMAL RETIREMENT
SECTION I: BASIC DATA
Personal Data
Social Security Number: 047-48-3880
Sex: MALE
Binh Date: 09-AUG-1854
Covera c Tv e: FULL
Contribution Rate: 5.00%
Counselors Center: HARRISBURG
Normal Retirement Date: 09-A G-2014
Final Average Salary: $22,822.82
1998 Retirement Covered Earnings: $23,918.10
Total SSI Non-Covered Earnings:
Joint Coverage Conversion Amount:
Mandatorv Debt:
Service Credit as of Dec. 31, 1998•
Class Years of Service Class Years of Scrvice
A-80 7,0881
TOTAL SERVICE 7.0881
Account Balance
Regular
Contributions SSI
Contributions
Dec. 31. 1997, Balance $7, 153.03
Contributions S1.195.91
Lump Sum Pavirients
Arrears Pa ments
Credited Interest $308.48
YTD Adjustments 0
Dec. 31. 1998. Balance $8,858.43
TOTAL DEDUCTIONS 118,888.43
Arrears Balance as of Dec. 31. 1998
Rccular SSI
Taxable Breakdown of Your Account %%%%
Taxable Contributions S7,150.72
Previously Taxed Contributions
Credited Interest (Taxable) $1.107.71
Dec. 31, 1998, Balance $8,858.43
SPECIAL CONDITIONS
Due to the following reason(s), special conditions apply to
your benefit estimates or estimates have not been calculated
You have insufficient service credits to qualify
for a regular retirement benefit.
*If you are eligible to purchase creditable state and/or non.
state servire, contact your Retirement Counselor for
injbrmatimt on purchasing service. All requests to purchase
service must be filed while you are an active, contributing
member.
•• Information filed on a Nomination of Beneficiarp(ies) form
before 1993 or since Dec. 31. /998, or involving special
circumstances (.such as the designation of an estate or trust as
your beneficiary) may not appear. A maximum of /0
beneficiaries may be shown here: however, you may have
more beneficiaries in Your retirement record. Keep your
beneficiary nomination current. You may change your
beneftclarv nomination at any time by filing a new
Nomination of Beneficiary(ies) form with SERS. Forms are
available from your agency Personnel Office or your
regional SERS Retirement Counseling Center. Please
contact us if you do not want your benefrcfary(ies) listed on
future Statements.
4YTD (Year-To-Date) Adjustments reflect corrections to your
account for which you already have received notification.
%* OSERS is a defined benefit plan under Internal Revenue
Service Code Section 401 (a).
1 0 A O Dep:rtme nor the Tmesury-rm«w R.w Sore.
?} U.S. Indlvldual Income Tax Return
Label
(see L
instructions A
on page 19.) E
Use the IRS L
label. H
Otherwise, E
please print R
or type. E
Presidential '?-
Election Campaign
Filing Status
Check only
one box.
Exemptions
1
2
3
4
0
It more than six
dependents,
see page 20.
Dependents:
n Fla norm list rums (2) Dependent's
total sovalty nurOmr, (3) ependmtF
fewordNit to
YOU 41 Meiasrbl,
calf Mx fN11a
ardl mr
letrud -Urt d l G f) 9 l I3 G n ?d'r c'
?
:?,
d Total number of exemptions Claimed
Income 7 Wages, eateries, tips, etc. Attach For(e) W2 ,
ee Taxable interest. Attach Schedue B N required"
Attach b ITax-exempt Interest. Do not Include online 8a , . 18b I I
Fors W2 and
g
Ord" dividends. Attach Schedule B N required
,.
W2O here.
Also attach 10 Taxable refunds, credits, or onsets of state and local Income taxes (see page 22). ,
,
Form(s) 1099-A 11 'Ahmony recdved
If tax was 12 'Buslness Income or Pose). Attach Schedule C or C•EZ'
withhold, 13 'Capital gain or pose). Attach Schedule
D If required,' If not required, chedrhero1?1;:;
14 .
Other gains or.possee). Attach Form 4787 .
If you did not 18s ;TotalIRA 'dtatribUtbm*,' 188bTazableamouMism pap 23)
get a W-2,
sae page 21. 18a Total pernbro end amulties. 18a It Taxable amount (see page 23) ;
17 Rental real estate,
royalllea; partnerships, S corporations, trusts, etc. Attach Sdiadule E"
Enclose, but do 18 i Farjn
it" or (bas). Attach Schedule F . . . . .
'
not attach, any 19 ' ,
.
iUnarnployrrient compensation ' •• -•-••
payment. Also,
please use
2a' •. .••
. Social "Ily benefits . I We I I I b Taxable amotxt (see page'25)"
Form 1040-V. .21 Other Incane,,Lbl type and amount (sea page 27) ..................................... 4.
.22 Add the amounts In the far right column for lines 7 throuah 21. This Is Your total Income ?
M IRA deductbnYeos page 27) . . 23
Adjusted 24-" shiclant ioo Interim deduction (see page 2e). . . . 24
Gross 25 MS1?dea, Lori Attach Form ee53 r 25
Income 2e MoYbg expands. Attach Form 3903 28
27 One-half of self-employment tax. Attach Schedule SE 27
28 . Sent-employed health Insurance deduction (see page 30) 28
29 Self-employed SEP, SIMPLE, and qualified plans 29
30 - Penalty on eery withdrawal of savings , . , 30
31s Amory paid b Reciplent's SSN ? 31 s
32 Add lines 23'through 31a . , . . . . . . .
8a
IRS the
oMU 140. 1545-0074
Your soelel seeurhy number
13V Stn Ito 1 ' 163 60.933/
PAMELA A BRADLEY
1637 MOUNT 1205E nVE
YORK PA 1.7403-2957 R : Spouse's social security number
S
Impli'rtant! e
You must enter
your SSN(s) above,
Note. Chocking *Yes' will not change your tax or reduce your refund.
Do ou, or your spouse if fiilin o joint return, want S3 to to this fund? . You , Spouse
? Elyse No- Clyde ElNo
Shale ..
Married filing joint return (even If only one had Income)
Married filing separate return Enter spouse's social securit
above and tug name here
no
?
.
y .
X Head of household (with qualifying person). (See page 18.) If the qualirying person Is s child but not your dependent,
enter this child's name here. ?
Oua1i widow a with dependent child ears se died P- See page 19.
Yourself. If your parent (or someone else) can claim you as a dependent on his or her tax
to um, do not chock box Ba . , , , , . ,
b ass
C
No. of losses
check" a
'se led Sit
No. el Yen
ddtdns on Its
roe:
e lived who res I
• IN not IM with
Ya dss to diverts
of separstloo
lam Pals 10) _
Dgmadeeb a k
eel metered Abe"
Add numbers
eMmn on o1
nee sees ?
33 Subtract line 32 from tine 22. This is your adjusted gross Income . ? 1 33 1 30 0!,--' IY9
For Disclosure, Piivacy Act, and Paperwork Reduction Ad Nodca, sae page 72. Cat. No. '11320111 Farm 1040 pcioq
Form 1040 (2001) &P 2
-
-
Tax and .1? Arrauntfrom ,laie33(ad)ustedgross income) .
-.
.
. . .34 3U -1 y
Credits .
-3 Check H: ? You were 65 or older, ? Blind; ? Spouss was 65 or oiler, ? Blind.
Standard Add the number of boxes chocked above and enter the total here . . ? 36e
Deduction b H. you are married fling separately and your spouse itemizes deductions
or
for- ,
you were a dual-status alien, am page 31 and check hero ? 35b ?
chec end and
y Itemized deductions (from Schedule A) or your standard deduction (see left margin), , 1
box on line
35
35b 37
.' •' Subtract line 36 from line 34 . . . . . . . . . .
•,-
". •' 37
a or
or
who can be 38 .J
,
If One 34 le $99,725 or less, multiply $2,900 by the total number of exemptions claimed on
claimed as a
dependent
t:; .. ' One 6d. If line 34 Is over $99,725; a" the worksheet on a 32 !
.o., , , P09 '. 38 OO '
,
see page 31. 39 Taxable Income. Subtract line 38 from line 37. If line 38 Is more than lure 37, enter -0- 39 7 J
e AN others: 40. . Tax'(see (rage 34 Check 0 arty tax is from e ? Form(s) 8814 b ? Form 4912 40 ?' .
Single, 41 . Altamative minimum tax (am page 34). Attach Forrn 6251 ..
...
• 41
Head of 42 Add lines 40 and 41 . . . . .
. . . . . .. . . . 42 6,11.1
household, 43 Foreign tax credit. Attach Form 1116 If required - , . .. 43
$6,650 44 Credit for chili and dependent care expanses, Attach Form
2441 44
Method filing
lanty or
;0; .
-
'. Credit for the, alloy or. the disabled. Attach Schodule.R.
•
45
Qualifying 45 Education credits. Attach Form 8683 , . .. 45
$7.600 '47, Rats reduction credit. Sao the warkeheat on page 38 . 47
Married
...
148.x. -Child tax credit (me page 37) - .. .: , 46
filing
se
aratel
r
- )Wc +tlon rxdlt: Attach Form 8839 ,
.
-• 49
y,
p
$3,800 ..
.,
.50 Other, credits from: a ? Form 3808 .: b ? Form 8396
'o? Form SSO1is d ? Form (seedy) 50
51
° ' Add Ines 43,through 60. Those are your total credits
'
' 61 `)
52
Subtract Ihie 61Yrom line 42. If line
61 Is more than line 42, enter -0- . . . . . ?, Re r a• m
Other 53 .• Self-emplajmiend tax. Attach Schedule BE , . . . . . . . _..
Taxes ;fit; -;. Soc!al•sewrHy and Medians tax on tip Income rat reported to employer. Attach Form 4137 ,
W. -,,Tax on "Ifibd,plens, Includkq IRAs, and other tax-favored accounts. Attach Form 5329 H required .
X58 Advance earned Income credit payments from Form(s) W-2 . . . . . . . .
1 - ,57; Housithold employment taxes. Attach Schedule H ... . . . . . . . . .
Payments 59 Federal Income tax withheld from Forme W2 and 1099 O
50 2001 atimeted taxi psyrnems and amount applied tram 2060 return
. 80
, _
ll you have a 610 Earned beanie critm (EIC) - -
...
.:
• 51a
qualiyIng b Nontaxable owned income LSIb ( -
(
.
(.
child, attach -
Schedule EIC. 52 Fxcess soclsl security and RRTA tax withhold (see pogo 51) / /
52 /
.
63 Additional child tax cradh- Attach Form 5812 . ,
83
84 Amount "pall with request for extension to file (sea page 51), 84
65 Other paymptts; Check, H from ¦ ? Form 2439 b 0. Form 4136.
68 'Add Orree 59. 50. 51 a. and 52 through 65. These are vour total 65
navrn
aMa '
. ? 'ww
a a a
en
Refund 67 H line 66 is more than line 58, subtract line 58 from line 66. This is the amount you overpaid `7 3 S C
Dkect 6Ba _ Artaunt of fl" _97 u want refunded to you d
,. -.; ? 58a 9 9 a
deposit? See 0, b Floulklg nugtber. '-l / 3 1 - 8 7 11- c Type:® Checking ? SaMI)pa_;,
e 51 and
ill n 68b, ? d ;Account number I / 1 9 10 1 01013 u O 9
68C• and 68d• 59 knountollinea7you wantapplied to w2002satimotedtax 0- 5t2
Amount 10 Amount you owe. Subtract One 65 from liene .For details on how to pay, we page 52 ? .. '-.70
You we 71 Estimated tax penalty. Also Include onlin 70`1-.., , ) 71
Third party._ yo_u wa nt to allow another person to, discuss this return with the IRS (spa page &3)?, ?, Yei Corpplate the following. ? No
Designee Design" .6 Phan Personal wkvltl6aum
name • ? m. ? ( 1 number (Pat) ?
Sign under Ir.reki? of parpry,l aarJere ihet 1 heve exartarted d,la nun and aoconperOV,p deaxa ant statemeitti are a raw bee a m,• laxrwledps era
traasl. lfrky era true, oorrsd,
Hare and corrpiele. Declaration of Mw (other then taWM is toed on as Mvmation of ~ p, apse has cry knowledge.
to e
Joint return? Yaw Oels Your occupation Daytime grans number
See peps 19.' r d/11119 a b-X":o r!u ( 1i 1) 19 9 - .7,1.3 ;f
Keep a copy Spouse's spnatwe. If ¦ pint retu tit must syn. Date Spouse's occupation
for your
records.
Date Check II Pretwer'e SSN o PTIN
Paid preparer's
spnalws Check pbysd ?
11,
Preparer'6 Firm's name to
Use Only !aura n.axMempbydl.? [IN
Form 1040 (2001)
SUMMARY OF EMPLOYE PAYROLL DEDUCTIONS
FOR CALENDAR YEAR 2001
Your payroll record for the calendar year 2001
shows that you had the following deductions from
your gross pa y. The amounts shown are a year-to- date
total for eac h deduction type listed.
DEDUCTION YEAR-TO-DATE DEDUCTION YEAR-TO-DATE
TYPE AMOUNT TYPE AMOUNT
FED WTH TX 3.529.50 SOC SEC TX 1,956.46
SOC SEC/MED TX 457.56 STATE WTH TX 883.60
LOC WG TX-RES 315.50 OCC PRIV TX 10.00
RET P/U CON 1,577.72 UN DUES 360.56
Instructions$ (Alen see Notice to
Employee on back of COPY 81
lox 1. [Mar this amount on the Wages line
of vow tax return.
lox 2. Enter this amount on the Federal
Income tax Withhold IIM of your tax return.
lox 1. Enter this Stru nt on the advonts
awned income eredll paWncnt$ line of
your form 1040 W 1040A.
Son to. This amount Is the total dependent
we behellts vow employer paid to you Of
Incurred an Your behalf (lnaluding amounts
from a section 125 k tatefla) platy. Any
amount over 55,000 also Is Included In box
1. You nwet complete btlWdule 2 (form
1044A) or forts 2441, Child and Dependant
Cara 5xpenses, to cOnWAe ally taxable and
rxmlexabls amounts.
Rex 12. The following Iles explains the codes
ehewn In box 12. You may need this
Information 10 complete Your lox rolun.
Notet 11 a year follows Cede D, E, F. G. w or 6,
you made a make-up pension contribution for a
prior yowls) when you ware In m111twY urvloe.
To flours whether you made excess deferrals,
canllow those amounts for the year shown, not
the current You. 11 M vow Is shown, the
contributions we for the currant Year.
E - Ilenive deferrals under a section 40301
clay, rradvallm agreement
IielnelWbglnonalimive defOffs 16 10 8 5SClIO bone
457N defected compensation pion
p -Excludable moving expense reimbursements
paid directly 10 empldYee Inot Included In boxes 1,
3x51
0 - MIIItaty employes basic housing, subsistence,
and combat zone. compensatlon (use this amount it
VW quality for Etc)
which you belong) we 9~611y 11MI1ed to '
$10,500. Elective deferrals far Section 403M
contracts we limited to $10,600 011,50 In
Come cues; see pub. 571). The limit for
section 4671M plane Is $5,50, Amounts
over those limits net be Included In Income.
bee -WO048, selwles. TIM. eta.' In the perm
1040 Instruction$.
NoteI Ku Co C e1 form W-2 for at leas
veers Is vans Iacocca
t?
I$rxrlty barn tae u.o eew_audl(-,.:
voe In rocslvnnc eoolel ese1rl Iy 11/s/'
let 13. 11 the "Retirement plan' box is checked,
special limits may apply to the amount of
iredlllenal IIIA cmtllbmlons you may deduct. Mao,
Inc deellve deferrals in box 12 WOOru D, E, F. G, K
and 61 (lot all employers, and for all such plane le
(ljylew iM IntormatlH onowm on low onnua_mer
worbre over 261 boclu $atwlty ItaymH6
Form 2441
D.peb.w• d w Trusuy
MwrW hvnu. S. i. 1941
Narrols) anoint on Form 1040
Child and Dependent Care Expenses
2001
Anau.nerx
sequence No. 21
Your social security numbee
r
Before you begin: You need to understand the following terms. See Definitions on page 1 of the Instructions.
a Dependent Care Benefits a Qualifying Person(s) a Qualified Expenses all Earned Income
I® Persons or Organizations Who Provided the Care-You must complete this part.
n...?.. -....., ... ..m thn hAtInm of nann 71
(a Cam
114" s
(number. street spt?roA?y, state. and ZIP code)
l41(SSNror EIN)
Ifae M4uctr tarn)
r e r Vii
Did you receive No -> Complete only Pen II below.
dependent Caro benents? Yes -0 Complete Pert III on the bock next.
Caution. If the
In
owe
If you have
for Form 1040. line 57.
W 011411" Persorts Herne I (M ouaslying p•rserl's social I Ira w,n•o .= secure number NctarW and paW 2001 or Drs
I .., y oaraon YNaO In coxrr•I (a)
earl-7yl3
3 Add the amounts In column (c) of line 2. Do not enter more than $2,400 for one qualifying
person or $4,800 for two or more persons. If you completed Pen 111, enter the amount
from the 24 . . . . . . . . . . . . . . . . . . . . . . . . . .
4 Enter your earned Income . . . . . . . . . . . . . . . . . . . . .
6 If men led riling a joint return, enter your spouse's earned Income (if your spouse was e
student or was disabled, see the Instructions); all others, enter the amount from
line 4 . . . . . . . . . . . . . . . . . . . . . . . . . . . .
6 Enter the smallest of the 3, 4, or 5
7 Enter the amount from Form 1040, line 34 . . . . 17 1 30 0.7 .i ' Iv
8 Enter online 8 the decimal amount shown below that applies to the amount online 7
If Vne 7Is: If the 71s:
But not Decimal out not Decimal
Ovsr over amount Is Over over amount Is
10-10,000 .30 520,000-22.000 .24
10.000-12.000 .28 22,000-24.000 .23
12,000-14,000 .28 24.1100-26,000 .22
14.000--16.000 .27 26,000-28,000 .21
16,000-48.000 .26 28,000-No limit .20
18.000-20,000 .25
9 Multiply line 6 by the decimal amount online 8. Enter the result here and on Form 1040,
line 44. But If this amount Is more than the amount on Form 1040, line 42, minus arty
amount on line 43, or you paid 2000 expenses In 2001, see the instructions for the amount
to enter on line 44 . . . . . . . . . _
0
00
.70 I -
a
.A0
a 3'/ od
Form 2441 (nor)
For Paperwork Reduction Act Notice, see page 3 or the Instructions. Cat. No. 11e82M
? Attach to, Form 1040.
? see
SUBJECT: 2001 FEDERAL TAXABLE WAGES
TO: PAMELA A BRADLEY
1637 MT ROSE AVE
YORK PA 17403
O21-20020
021-3-182-0036-1 43604
163.60-9331 503623 052597
The amount of Federal Taxable Wages shown to Block 1 of the attached W2 statement for most employes may
differ from the amount of gross Earnings you received during the calendar year. Any difference 1s a
result of one or more of the adjustments explained and calculated below:
If you have any questions, please contact your Personnel Office.
• • • • • • • • • CALCULATION SUMMARY
GROSS EARNINGS 31,555.50
MINUS:
• RETIREMENT PICKUP CONTRIBUTIONS (Non Heart 8 Lung, or Act 534/632 Earnings) . . . . 1,577.72
EQUALS:
FEDERAL TAXABLE WAGES 29,977.78
• • • SEE BACK FOR ADDITIONAL INFORMATION
ImploYer'e Identification Numbat Central Number I Wages, sips',otMr bompenutlen a. Federal Inatlfrte tax wilwAI4?
23-2172288 021-20020 28,877,7e .-3,52940
Imptoyara name, address, and ZIP code 3 social security wages a Social security sex withhold
COMMONWEALTH OF PENNSYLVANIA 31,556,60 1,866.46
DEPARTMENT OF PUBLIC WELFARE 5 Medicars wages and lips a Medicare tax withheld
i HARRISBURG PA 17120 31,655.50 457.56
Imployse's Social Security Number e.Adyance Etc Payment 10 Dependent Care benefits
1e3-eo-8331
mp??
PAM Ar t name and initial Less name
BRADLEY II Nonouslified plans 1i see instructions for Sox 12
.............»........._......_._._.__.....-.......__»........._.......,_..........._..__............_....._....
13 Statutory Retirement Third Patty
1637 MT ROSE AVE employee Plan site pay
YORK D ® ?
PA 17403
rase amav ]D Na. 15 Ilata wages, tip. etc. II stair income sex 18 Local wages, lips, etr. a Loa] income tar 20 Locality name
'
I 31,555.50 I 683.60 10.715.25 I 107.14 INORTH MIDDLETON TWIP
and Tax s eMelae Inasery.mwmd Perseus Urvws
.wnt2001 COPY C - FOR EMPLOYEE'S RECORDS(SEE NOTICE ON SACK OF CO?? ? OW Me. 160.0"
-"= • x~.r L.. r: ^ 503623 05ZI?"It9Y4•"IM!^Yia4k?`?eydyyYse.ryNa
nployat's IdonuNcauon Numbs# comr" Number Wages, lips, other. comp"set en 2 sodenl brcgno 4" witMele , „• •.
13-2172200 021.20020 29.977.78 . 3 020:60 _ ;;
M1
nPloyar's MOMS, address, and ZIP coda 3 Social security wages 4 Social security set withhold
XIMMONWEALTH OF PENNSYLVANIA 31,668.00 1,968.48
1EPARTMENT OF PU
BLIC WELFARE B Medicare wages and tips a Medium tax withhold
IARRISBURO PA 17120 31,666.00 467.66
nPloyes's Social Security Number 9 Advance EID Payment 10 Dependant care benefits
103-80-9331
nPloyes'allist name end Initial Lost name 11 Nonouutliad plans 12 See Instructions for Box 12
1AMELA A BRADLEY
»
«.
«.««._..«..«..«..........«_..._««.._....«.......... . ...................
1037 MT ROSE AVE ............. ««._»............
........
13 Statutory Retirement
employee Plan
Third Party
sick pay
FORK a O ?
eA 17403
n n ZIP Cod,
5
use 149
s lit No.
ie Sole wages, lip, etc.
...._.
. 17 State income tax to Local wsoas, tips, etc. IV Local income tax 20 Locality Rome
l
..
...
.«.....« ..................« ......»...»...........««..«....«...
FA 1
3567078 31,555. 0 ...-........... ...............«........
983.00
......,.........«..«....................«.,....
10,716.26
.«...........«««.»«-.««...».«.............«.-?.«»«............««««......-
107.14 N ORTH MIDDLETON T11P
•••w-a wwww mrwe tax Dsasnaelx at the lnaswy.edswtl pwtsee$I"*
Stetentlent2001 COPY 1 - TO BE FILED WITH EMPLOYEE'S CITY OR LOCAL TAX RETURN OW as.1NS4e11
IN%Inism alit. 11 being ISmbMd Is at k,tentl Relaxes Son,144
o)ty 2 To Be Filed Wlth Elnpioyee'e 0 af00.7 OMB No.
G 1
fate Clt or Local Income Tex Return 1545 0008
e Om10 Um el 1 wag", IOe.0lher comp. 2 Federal income tin W11046d
266 65.27 10.00
social ..corny wag" 4 Sour Behefty tax wHNW"
o Employer's ID no. 6S.27 S
23.1735375 5 Medicua wag" and tip 6 Medicare tax;; N
65.27 0.95
t Empoyar's name, address, and I code
THE W. W. GROUP, INC.
P. 0. BOX 9072
28555 ORCHARD LAKE ROAD
FARMINGTON HILLS MI 48333
d Employee's soda security number
163.60.9331
a Employee's name, address, and to code
PAMELA A BRADLEY
1637 NT ROSE AVE
YORK PA 17403
7 Saul aacwity ups B Allocated tpa B Advance TIC Payment
10 Deowdant cue bww1116 11 NWQU$htwd P4N 14 Other
128 Sw Mlrwl.e.sraw.lr b
i[ d
13 Siam" Employ" Rome mein Ran 3PsP
171 171 0
15 EmPmyws Flue ID axrl
.....? ................. 1 1810 wag", Ipa, sic'
......................
. M. rlconw tin
........................
1 a Local wag", ION, etc. I Lace IncaM 18% 20 Loc"ty name
.............65.27..... ...............0.65... . P•432A........ 23,1736325.
Iwrolnuroor n u
)RK AAEA EARNED INCOME TAX BUREAU EARNED INCOME TAX HE I UHN
15 NORTH DUKE-STREET, P.O. BOX 15627 33886
)RK, PA 17405-0168 - PHONE (717) 845-1584 FORM 214
:T n O*i COMPLETE ONLY IF YOU MOVED DURING THE TAx YEAR, AND ACCOUNT FOR ALL' 12 MOHM9.
1.OF I BUREAU I
TO
TO
TO
ERE YOU PRESENTLY RESIDE
SPRING GARDEN TWP
OUREAU
CODE
048 YORK SUBURBAN
ARCNT NAME A MAJ. ADOM31 • PY SOUS m,ec&a and cw0M So~ 1 m-.e 11 eesaw 1ele Ow" m Year 2001.
e1111e11eeeNlleeneeeeeRReAUT0ee5-DIGIT 17403
(A) BRADLEY PAMELA A
B
1637 MOUNT ROSE AVE
YORK PA 17403-2957
1111111111 11111111 11111 1111 1 1 loll 111111
ry [T SECTION a)
iM EtCfO10.' 1,EPA.E'xfWl? IIEVERSE.IDE PwOn.O NO"..'D
1. W2 Eaminjs. (from line 20 of section 0) reverse side) .....................
Enclose •2 Forms to esch employer.
2108\
al ForrTI
2. Less employee business expenses. ( EEAdOssee Feed 3903 forUMamnpE
3. Other taxable earned Income.(?els pion T ;, back. di or C°dul Q8 "')• • • • •/• • •
4. Net loss from Business, Farm, or Profession ( ENCLOSE LLl STATE OR iEDERALI
ENCLOSEA C.E.F. K.I. 'Report S Corp. loss on reverse only.
5. Total taxable earned Income. (Not less than zero.) .........................
6. Net profit from Business, Form, Or Profession ALL STATE OR FEDERAL
'Report S Corp. Income on reverse only. ( SCHEDULES C, E. F. K•1.
7. Total t p?e oTSd Ij nee ?Ngrnet profit. (Add lines 5 8 6) ...............
8. Taxliability, 1 % ofline 7 ............................................
9. Total local Income tax withheld as per enclosed W2's ......................
10 over2001 payment t transferred tax 2001 fax year. (Chock each applicable u box
11. Add lines 9 and 10 ....................................................
12. Refu%C[A1gTl iir a &WIIC ne 8) ......................................
113. Amount of refund to be transferred Into 2002 ..............................
14. Amount of refund to be transferred to spouse's 2001 tax duo ...............
15. Tax TFiESffTilWfi (L(rr&Rjp rI us line 11) .................................
16. Penalty after April 15, see Instructions ..................................
17. Interest after April 15, see Instructions ...................................
18. Total balance due. Add lines 15, 16 and 17 INCLUDE CHECK PAYABLE TO Y A E.I.T.B.-
102001
A-DO
2001
A O PERMANENTLY RETIRED OR O DISABLED AS OF JJ_
OR O ACTIVE DUTY MILITARY JJ-
D 0 PERMANENTLY RETIRED OR O DISABLED AS OF JJ_
OR 0 ACTIVE DUTY MILITARY JJ_
TAXPAYER
SOCIAL -60-9331
A 163
SECURITY NO.
TAXPAYER B
SOCIAL
qFrIIR Nn
163-60-9331
PAMELA A 0
1 av o f
2 - -
3
I - I
5 P 0 91/01 ;13
I
do, 840 = , ? I
1
8 ?o ?J0 i
pj
191
10 I
aog 136
13 I
14 j
- O -
• j I
I
?.18
DECLARE UNDER PENALTIES PROVIDED BY LAW. THAT THIS RETURN IS TRUE. COMPLETE AND CORRECT.
-REOUIRED
®SIONATUflE•TA%PAYER
®SIONATURE•TA%PAYEfl I
DAT
DATE
OCCUPATION EMAIL ADDRESS
Ca.te.,I rtAr
OCCUPATION EMAIL ADDRESS
UAYIIMt ItLt#`HUNCm .
9/2- Pty- 9.13-?
DAYTIME TELEPHONE NO.
PAID PRLPARER'S NAME. VLEASE PRINT PAID PREPARER'S TELEPHONE NUMBER Local Earned Income and Net Profits Tax
Complete and Return by Apol 15, 2002.
BUREAU'S COPY . . I a 1 -
OENERICTAX RETURN FORMS ARE NOT ACCEPTABLE WITHOUT PRIOR WRITTEN a F ..u I, , . ee,a1 •a Y
mployer's Identification Numeer Contial Nurneer 2906. 4406. etMr eompenuf en 2 federal liceme tax withheld
R
23-7172209 021-20020 .. '.: ,?b•
>''
mplorv's name. address. and Ilp code 2 Social caturrly wages a Social security lox withheld
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF PUBLIC WELFARE 5 Medicare wage% and ups 0 Medicare tee withheld
ORRISBURO PA 17120
Imitation's Social Security Number 11,41,06na LIC Paymenl_ TO oapendent core bonelils
153-50-9331 ..
mpldyes's first name and initial Lost name I1 NonouaNllad plans 17 See instructions for box 12
PAMELA A BRADLEY
..._...._._...«..»...»«.._«......... _...._.........___._ ..
...
.
.
.
.......
...
.._.._._.««_._.. 12 Statutory Ilollrement Third party
1537 MT ROSE AVE nmOleru Flan ales pay
YORK ? O Q
PA 17103
to*% and ZIP code
1 ulo lmatoyere to No. Id slots wages. tip. loc. 17 State income tae IS Local wages. Uat- etc. 19 Local income lit 70 LdcNlfy nerve
20,810.26 205.35 SPRING GARDEN TWP.
rmw-T wage ono Taft planwcal ellM Tmaery-Wand Raviwe sarvk$
Statowelont2001 COPY 1 - TO BE FILED WITH EMPLOYEEIS CITY OR LOCAL TAX RETURN pwof.IU$4 a
TNs i,lwwahae ll bale f hmisM/ N too 2damd Rnaeee serAre
I
aETURN BY APRIL 15, 2002 TO: HIS AREA.
n.t TAX OFFICE USE ONLY • DO NOT WRITE I
PITAL TAX COLLECTION BUREAU 2001 T
See Page 2 of Instruction.Sheets LOCAL EARNED INCOME
Is packet for mailing address labels 4i TAX RETURN (FORM 531)
see back of return for addresses,
phone numbers; and offico lours.
1TRUTE PROOF:OF TILING, THE TAXPAYER'S.COPY MUST
)ATED BY THE aUREAU. YO HAVE YOUR QpOPT VALIDATED
RETURN BOTH THE BUREAU'S AND TAX?AYERS CONES
KITH A SELF ADDRESSED STAMPED EHVfLOPE
www.captax.com
F F A • B
163 60 9331
e
f-2 EARNINGS (From attached W2's) :.................................................... I f0 LS I
MPLOYEE BUSINESS EXPEN86S (Attach Federal Form 2106 b State Schedule UE) .............. 2
AXABLE W-2 EARMNGS (SUbIrACt Line 2 from Lino 1 3 0 4:Q
ITHER TAXABLE EARNED INCOME (NO INTEREST OR DIVIDENDS) Complete Section A on Back ... 4 1 1:
.1
OTAL TAXABLE EARNED INCOME (Add Lines 3 and 4) ...................................... 5 0 J I '
OR FARM (AnXh Federal anNp State Schedules C, F ena'a K•I(ID65)) ..
PROFESSION
IET LOSS FROM BUSINESS 6 '
,
,
IUBTOTAL (Subtract Line 6 from Line 5) IF LESS THAN ZERO, ENTER ZERO ..................... 7 I?1 I
.I
BUSINESSiPROFESSION, ORFARM JAWFederal ard'oState Sched*&C,F"'mK•1(1065))
JET PROFIT FROM
8 1 1
1
,
-OTAL TAXABLE EARNED INCOME AND NET PROFITS Add Lines 7 and 0 ....... I
I •
:LATER TAXABLE RATE • .07 FOR DAUPHIN, PAXIANG, AND PENBROOX BOROUGHS, LOWER PAXTON, MIDDLE PAXTON. to 1 '
:WATARAORWEST HANOYERTOWNSHIFSICENTRAL DAUPHIN SCHOOL DISTRICT) -ALL OTHERS.01 .............. I I S:
rAX LIABILITY: Multi I Line 9 b Line 10 ........ • T'
OT AL LOCAL INCOME TAXES WITHHELD EXCEPT PHILADELPHIA INCOME TAX (From allached W2's, Box 19)..... t2 V
DUARTERLY-PAYMENT&AND/pRLAST YEAR'S OVERPAYMENT CREDITEDTOTHISNEAR-.,...•. 13 •• I •'I.??7
MEDITS FOR TAXES PAID TO PHIUDELP,HU AND/OR STATES OTHER THAN PA (ATTACH SCH. G) AND/OR CREDITS FOR CERTIFIED 14 1 1
TESIOENTS OF THE HARRISBURG KEYSTONE OPPORTUNITY ZONE IKOZ).............................................
1
I
.. ...........................
TOTAL WITHHOLDINGS 8 PAYMENTS Add Lines 12,13 and 14 .. 15 - 0
TAX BALANCE DUE [Subtract Une:15 from Une 11) PAYMENT NOT NECESSARY IF LESS THAN $1.00..0 ........ 16 1 I '
INTEREST & PENALTY (See Instructions) .................................................. 17 •:'
TOTAL BALANCE DUE Add Linos 16 and 17 Make check payable to'CTCB....................... 18 -? -T I I ?;1
OVERPAYMENT (Subtract Line I1 from Line 15) IF LESS THAN ZERO, ENTER ZERO ....Q ........ 19
OVERPAYMENT.TO BE REFUNDED ...... HAVE IT DIRECTLY DEPOSITEDI ................. 20 I .
DIRECT DEPOSITINFORMATION
CIRCLE ONE:.... CHECKONEE ROUTING NO. ACCOUNT NO.
TAXPAYER •. •. 'C 4CCKIWO SAVINGS -
A B BOTH;<:':O iO
A B BOTH.r :•: jd '
OVERPAYMENT TO BE CREDITED TO NEXT YEAR'S TAX ................................. 21 I .
nvFRPAYMENT TO BE CREDITED TO SPOUSE'S BALANCE DUE FOR THIS FILING YEAR ...... 22 i 1'
• • • • • • • • • e F F • • •
YOUR RESIDENT MUNICIPALITY •'
(TO'MISHIP, BORQUGH. OR CRY) DAYTIME PHONE NUMBER
TAX OFFICE
l+BYCOJBD•>????;?1+?ALL FOR* ADC iE7
NORTH MIDOLE70N WP 7?9 •y99_ ?c?3 USE ONLY 933180466550213638
YOUR SOCIAL SECURITY . A 163
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FIRST
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AST BRADLEY PAMELA A O3 P41
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- RAST.FIHST.
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E YOU MOVED FROM THE : VIES IF YES. COMPLETE SCHEDULE P HOME 1637 MOUNTR05E AVE
INNING OF THE TAX FILING' eb PROVIDED WITH THIS RETURN ADDRESS YORK PA 17403-29!
R TO PRESENT?
• • F F I • F
16 TUBE
J DATE'
V YOUR OCCUPATION
r
. :
ISE'6 SIGNATURE (ONLY IF AL50 FILI 'NI t115 FORM, D E SPOUSE'S OCCUPATION (ONLY IF ALSO FILING ON THIS FOR M)
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COMMONWEALTH OF PA - EMPLOYE STATEMENT IH II PLY OF VALID
OUL
GROSS EARNINGS 1.16I.90 -
11.771.77
PAY ?ERI00 ENDING: W-15-02 PAY DATE: 05-03-02 NIMUS OEDIlCTIONf
VTrt 151107110000 DEPT: 021 CDC[ 17604 FED KIM IN M 01 100.11 1.004.11
SOC sic TX 6.20000% 71.40 705.11
ENPft 507{7] Pout 052557 SSNt 1{7-60-5]71 SOC SIC/1411) TK 1.45000% L.71 161.55
B/Ut FI PAY RANGES M STEP: 7 LEVEL: 00 STATE HT
NTH TK
PA 1.10000%
75.11
718.51
PUBLIC WELFARE LANCASTER CAD - MM LOC BIG TX-RES PA 67 001 1.00000% 12.45 117.77
NET P/U CON STATE IMP 6.75000% 71.07 710.15
UN DUES PSSU 0{61 14.54 170.75
ST EMP CONS AP 7.00 27.00
PAMELA A BRADLEY
1037 MT ROSE AVE
YORK PA 17403
MET EARNINGSt 522.52
'STATE PAID BENEFITS PLUS REIMBURSEMENTS
HEALTH BENEFITS CAPITAL BLUE CROSS 150.00
ANN RED HOSP NET EMP HLTH PROD (REHPI 135.00
LIFE INSURANCE 3.35
IS C"
I
S
S 29.61
OC
A
L
f SECURITY
71.40
MEDICARE 11.74
TOTAL STATE PAID BENEFITS- 5 454.74
,' .-- PAID LEAVE STATEMENT TOTAL DIRECT DEPOSIT AMOUNT f 522.52
SERVICE CREDIT: 2 YR 12 PP
PP END' LEAVE USAGE REPORTED HOURS: PP END BREAKDOWN GROSS EARNr HOURS .: - RATE GROSS
04-11-02 ANNUAL 1.50 04-15-02 REG SAL 75.00 14.16 1.264.50
04-1"2 SICK 1.67
04-15-02 SICK FAMILY 5.67
. TOTAL GROSS EARNINGS THIS PAY S 1,264.50
LEAVE ACTIVITY ' ANNUAL -'SICK '. .. PERSONAL . SENIORITY . INFORMATION
BALANCE LAST STATEMENT $6.27 30.77 .00 SOCIAL REHAB $EBY NONSUPV 4S0 CREDIT DAYS
ACCRUAL THIS PP 2.03 7.75 7.50
LY REPORTED THIS PP 1.50 7.50 .00 EMP MILITARY DAYS 0 CIIED17 DAYS
ADJUSTMENTS .00 .00 .00 CREDIT DATE 01-15-02
BALANCE THIS STMT 54.10 17.02 7.50
,..ACCRUAL RATES ARNUAL 2.7 SICK . 5.0 0%
MESSAGE CENTER: LOCAL WAGE TAX COUNTY/MUNICIPALITY: YORK COUNTY SPRING GARDEN IMP.
FKT TAX GROSSt 1,185.47
;u%. 6.2^t!2 7:I9AY ILANCAST:R CAD 7*7 299 756;
LMVar taaaoaa4 of .
Veterans Affairs
J P KENNEDY FED BLDG
BOSTON EA 02203
PAMELA A BRADLEY
1637 NODNT ROSE.AVE
YORK PA 17403
NO 76; ?. 2 -
Deeemzer 27, 2001
FILE NUMBER
163 60 931
P A BRADL
DEPARTMENT OF VEMPAINS AFFAIRS BENEF17S INCREASED
Congress
benefits from D6d and the President has signed into law an act increasing service-coaamtod ist.
Your
new be less if YIDU cur ently haveeaamouunt tiondLcLW from however e..& your actual dep=t may
The proviqsions of the new law app to vetaaas eatitlad to service-connected disability
eommpUon. reviving spouses children eatit!cd to dependency and indemnity
aV?Aencubeaefto verify accuracy your information ?cont?a contained in to be Matched with the follo
Ube other agency:
L Department of Defense to verity a return to active military service,
2. Department of Defame to obtain accurate information concerning waiver of compc=tioa
benefits for those vateram who waive VA compmution benefits whie on Reserve Traming
Duty.
3• social Security Administration to determine whether a veteran being yid at the
100-percent sae because of uaemployability is receiving subsmatial earned income.
4. Reread of Prison$ and Social Sentrity Administration ;o deurmine if a beneficiary is
israrsorated in cotes of 60 days.
S. Social Security Administration to verify the accuracy of eligibility to benefits from the
supplemental security Income program. '
eligiU. Department of H? and Human Services to assist the states in determining
ry fm Ptebu programs.
7. Department of Mueation to verify veteran status of applicants for financial asshta=
Pleue advise a immediately if you go on active duty in the Armed Fortes or if there is any
derby your derma t address or omfarital status If you are receiving additional benefits for
any change is air $taws.
If you am a veteran who owns or wants to open or acpand a small business, VA's C=tet for
Veterans Enterprise can offer assistance. Tile Center was establLhad to help veteran anall
business o?vne?s lam about federal contracting OF You may call 1-866-584-2344
tomlla, t7AZ1 X5-8336 or visit their weWite at°ttpc//www.vetbiz goy to learn about
WnVA&
Any questions or correspondence Should be submitted to the VA Regional Office handling
of8? purest your Hbom& earing not know which regional 1 quL ?- dial the th handles your Toll Frei Number.
e
DEPARTMENT OF VHT[RANS AFFAIRS
VA FORM 04-Aval-I
page ranant of In Tmu" - Ie,b,nal Rg,a Sam"
Label
(S«.we,uttvw.)
Use the
IRS label.
Otherwise,
please print
or type.
Y"
Prwsldennd CARLISLE
Election
Campaign , Note:Checking'Yes'
(S« onovw%ona.) n........
Name
??_ ? ?•_:>> ? JJ it
• Important! A
You must enter your social
security cumber(s) above.
tax or
1 Singl
Filing Status e ^a
2 Married filing taint return (even it only one had income)
3 Married filing separate return. Enter spouse's SSN above & full name here .. ?
Check only 4 Head of household (with qualifying person). (See Instructions.) If the qualifying person is a child b
t
u
not your
one box.
dependent, enter this child's name here ?
""
t
?
_ 5 r r Cualitpra •wldow(er) Wrtn Jepena cn: child _'year soause died ) (Sae instructions )
Exemptions 6a Yourself. If your parent (or someone else) can claim you as a dependent on his or No. of aax«
her tax return, do not check box 6a
........... to«e,te ea
..................................
.
sat«w .... I
....... ........... ....
Nw e,i Y«r
to WX
eDependenls: (2) Dependent's (3) Dependent's (4) a st.ae,:
social security relationship aoep„y a Yrae
number to you N
y
'?
pp
aka you.....
First name Last name
t
(oe, nmt) a
.04 at
era ankIr«
If more than are, to divans
six dependents, acre nba
(«a ru.) , , .
see Instructions. a«.etata
as et aN
«YrN.lure, .
d Total number of exemodons claimed .... lu annNn
«Yna on
...
. . . . . . .
7 Wages, salaries, tips, etc. Attach Form(s) Wt..'.'.. ......................
Income
.
7
. can ttwva .
?
1
2
.
• • • . • ...
Be Taxable inter
st
Att
h S 5 113.
e
.
ac
chedule B it required ...... • • .• " "
. a
................. .
I'
Attach Forms Is Tax-exempt interest. Do not include on line 8a ........... . .
BbI
-2nd
2G
9 Ordinar
di
id s
?:
"
a
?
v
y
ends. Attach Schedule B if required ....................... 9
R if 10 Taxable refund
F
1099
d
t
orm(s)
.
s, cre
i
s, or onsets of state and local income taxes (see instructions) 10
.....
tax was withhold. 11 Alimon
rec
i
d
y
e
ve
.... .......................
.............. .....
12 Business in
l 11
come or (
oss). Attach Schedule C or C•E2 ................... . ..
It you did not
. 12
.
.......
13 Capital
am
r
l
At
h S
g
(
o
oss).
tac
get a W2, see
chedule 0 if required. II not required, check here ........... ? 11 13
instructions
14 Other
i
l
.
ga
ns or (
osses). Attac h Form 4797 ..
15a Total IRA di
t
b
t
............. . . 14
s
ri
u
ions .....
16a Total
n
& 15al Is Taxable amount (see mstrs) .. 15b
pe
sions
annuities . 16aI Is Taxable amount (see •nstrs,) 13 495
17 Rental real
t
t .
es
a
e, royalties, partnerships, S corporations, trusts, etc. Attach Schedule E
.. Enclos
18 F
b
t d
r
e,
u
o
a
m income or Voss). Attach Schedule F ................ 4
...... .......... . ........ not attach, any 19 U
l
nemp
oyment compensation ............
Also
.....
.
.... .
p
am
t
, 20
.
S
l
,
a
au
xable
p
saurirytenefits ..... [20a Is Taxable
e
leas use
amount (See sea m3trS)strs) p (
Far
m 10404
21 Oth
r 20b
.
e
income _______________
22 Add the amounts in the far n ht column for lines 7 throw h 21
This is our total income ? 22
.
23 IRA deduction (Sao instructions) .........
23
?.
.r 38 608.
..................
A usted 24 Student loan interest deduction (see instructions) ........... 24
Gross ,
25 Archer MSA deduction. Attach Form 8853 .................. 25
Income
<=
26 Moving expenses. Attach Form 3903..........
.......... . .. 26
_;.
27 One-half of self-employment tax. Attach Schedule SE ....... 27
28 Self-employed health insurance deduction (see instructions) . 28
29 Self-employed SEP, SIMPLE, and qualified plans ........... 29
30 Penalty on early withdrawal of savings ...........
3
31 a Alimony paid Is Recipient's SStI .... ? 31&1
,::..
32 Add lines 17 Wough]Ia ....... ..................... .............. ....
. ...........
33 S 32
ubtract line 32 from line 22. This is our ad usted ras%Income .... ? 33 38 608
DAA For Disclosure, Privacy Act, and Paperwork Reductlon Act Notice
sea Instructions .
,
, Form 1040 (2001)
FDIADi l2 1211 W I
i
•r um rw %'W" huuecrn r onnvLCI U41-410-SSbU Pa OZ
Tax and 34 Amount from line 33 (adjusted gross income) ......................................... 3d 9A. ring
Credits 35a Check if: U You were 65/older, U81irid; U Spouse was 65/older, ? Blind.
Add the number of boxes checked above and enter the total here ............ 35a
D
Standard Is It you are married Alin qq separately and your spouse itemizes deductions,
D
eduction or you were a dual status alien, see instructions and check here ............. 35b E]
for -
• People who 36 Itemited deductloas (from Schedule A) or your standard deduction (see left margin) .................... 36
h
k
660.
c
ec
ed any box
li 37 Subtract line 36 from line 34 ........................................................ 37 29 948.
35b
es wwo can
be claimed as a 38 If line 34 is $99,725 or less, multiply $2,900 by Cie total number of exemptions claimed
an line 6d. If line 34 is over $99,725, see the worksheet in the instructions ............... 38
bl
I
S
39 U
2,900.
dependent, see
instructions. sa
e
ncome.
ubtract line 33 from line U.
If line 38 is more than line 37, enter •0• ...................................................... 39
27,048.
others:
d 40 Tax (see instil). Uiax it any tax is from a ? Form(s) 8814 b ? Form 4911 ....................... 40 4,054.
Si
le 41 Alternative minimum tax (see instructions). Attach Form 6251
$4,550 42 Add lines 40 and 41 .............................................................. ? 42 4,054.
Head of 43 Foreign tax credit. Attach Form 1116 if required ............. 43
household,
$6
650 44 Credit for child and dependent we everses. Attach Form 2411 .......... 44 '
, 45 Credit far the elderly or the disabled. Attach Schedule R ..... 45
Married filing 46 Education credits. Attach Form 8863 ....................... 46
uill or
Q
uahlyi^9
47 Rata reduction credit. See the worksheet ................ .
47
widow(s),
600
$7 48 Child tax credit (see instructions) .......................... 48
'
Married filing
separately,
1 SUM 49 Adoption credit. Attach Form 8839.......... .•.. .
50 Oth r credits Irom a Form 3800 Is []Form 83%
e [] Form 8801 d 8 Form (specify) 49
AOn x
'
51 Add lines 43 through S0. Thee are your total credits ....................... ..................... 51
52 Subtract line 51 from fine 42. If line 51 is more Iran line 42. enter •0• .................. ? 52 4,054.
53 Self-employment tax Attach Schedule SE ..................................................... 53
Other 54 Social security and Medicare tax on tip income not reported to employer. Attach Form 4137 ................. 54
Texas 55 Tax on qualified plans, including IRAs, and offer tax-favored accounts. Attach Form 5329 it required ........... 55
56 Advance earned income credit payments from Form(;) 002 ............................ 56
57 Household employment taxes. Attach Schedule H ..................................... 57
58 Add lines 52.57. This is your total tas ..................................................... ? 58 4,054.
Payments 59 Federal income tax withheld from Forms 002 and 1099 ...... 59 3.436.
It you have a 60 2001 estimated Us payments and amount applied from 2000 return ........ 60
Qualifyi 61 a Earned Income credit (EIC) ...... .... ................. . 61a No
child, attach r Is Nontaxable earned income ......1 61 b1
Schedule EIC,
I 62 Excess social security and RRTA tax withheld (see irl ... 62
63 Additional child tax credit, Attach Form 8812 ............... 63
64 Amount paid with request for extension to file (see instructions) .......... 64
65 Other payments. Check if from ..... a []Form 2439
Is Farm 4136 ........................................
65
rlx40112 I2110a1 66 Add lines 59, 60, 61a, and 62 through 65. These are your
total payments ....................................................... ........... ? 66 3, 436.
Refund 67 If line 66 is mcre than line Se, subtract line S8 from line 66 This is the amount you overpaid ... ............. 67
Direct deposit? 68a Amount of line 67 you want refunded to you ... •• ............ ........... ? 688
See instructions ? Is Routing number ....... ? e Type: ? Chocking [] Savings
and fill In 6Bb,
68c
and 68d. ? d Account riumber .......
, 69 Amount of line 67 you want a Iled to our 2201 intimated tax ....... ;:169
A
Amount
70C k ouM you ubfixt line 66 from line 8 For details on haw to pay, see instructions ....
........... ? 70
618 .
You Owe 71 Estimated tax penalty. Also include on line 70 .......
71
s.*.a.
Third Party Do you want to allow another person to discuss this return with the IRS (see instructions)? ......... Yes. Complete vie following. No
Designee o r"•p Phone PW I
tanbpn
. ?
Urdu oN41EM of Ponury. I declim, nlal l flare arlTMte e1,/,*W led accatn"my" WpA,IIt &M 1hIpTNlb. and b TI eMl of TI•Wla.iedee t,le
are cue
ton
d and cbn
ci
M
hb
f
d
l
Wall
b
0
gi
b
d
n
Here ,
e
.
e
am
Pmua Ia
ase
on e
n a
,
o
le fun bepara) n
p
r . rn prepare
uban a
aa"WwMedes.
ereturn?
Jot
Your sgnawe bah Ywr Otmosbon
l Plane Wnba
See instructions. ? CLERICAL
Keep a copy spwu'a Synaa,h. If a Jauli Fevre, sea Mel Spn. bee sows: a Otmpaben n
for your records. ?
-
bale Pmanes SSN ar
PM
Paid PPS= ? ` 03/16/2002 a«k,fW#,np 194-42-9571
Presparerrs im's NNab MARSTO AX SERVICE
Use Only aaa?r.nposya)?817 FACTORY STREET [IN 23-2105115
1040 (2001)
4U1MUwa n
(Farm 1040)
e
of 11414 Ties
MnW Y?P? sauce
"09- mlr?
Itemized Deductions
Sao Instructions for t Schedule OA (Form 1
and
D
W ? uars, uo 1101 Include expenses reimbursetl or paid by others.
t Medical and denial
amensa (me instruction
en
Expenses s)
..................
2 Enter amount from Form I04Q line 34 ..... 2'
38 608
1
SOC
3 Multiply line 2 above by 7.5% (.015) .
4 Subtract line 3 from line I. If line 3 Is more than line 1, enter .0 . 3 2 , 896
Taxes You 5 Stela and local income taxes • • • • •
Paid ........................
6 Real estate taxes (see instructions) 5 004
(See ..........,
...............
7 Personal property taxes ...
.
6 596
instnxtions.) .......
A Outer taxes. List
...
type and amount 7
E F
PERSONAL OPT ------------ 9 Add lines 5 through a ....
------ 50_ A 250
Interest
You Paid ..........
10 Nome mt0 Intaesl and m 1 . ...............
points reponea to you on Form 1098 .
.....
. ..
10
..............
.............. . 5 810
11 Ilome mcdOW WNW not reported to you on Form I09a it paid to the
er
n
p
so
from whom you bought tM home, sa instrjcttons and sMw but person's name
(See ,
iden141119 number, and address ?
InsWctions.) ------------------------------- Sr`.
--------------------- F
------------
-
Nab. --
----------------
Personal
interest is __
-
12 Poinb Mat reported to you on Form )098. Sea insfrs far spd ru
Fes-
11
not .
13 Invutment interesL Attxh Form 4952 if required. 1Y
E
deductible. (See instrs.).........
......................
. ..................
14 Add lines 10 through 13 ............
............. 13
Gifts to
Charity ............
15 Gifts by cash or check. If you made any gift of $250 or more ............. .
.. ...
,
see instructions .........................
a yY you ama a 16 Other than by cash or check. If any gift of $250 or
got a benefit more, see instructions. You must attach Form 8283 if
for it, see
% over $500 .................................................. 16
instructl
. 17 Carryover from prior year ..
..................................
18 Add lines 15 throw in 17 ............
.......... 17
Casualty and ................ ............ ..........
T
heft Losses
19 Casual or theft loss(es), Attach Form 4684, (See instructions. ..
Job Expendun
and Most
Oth
20 Unreimbursed emplo ee expenses - job travel, union dues,
job education, etc. You must attach For
2106
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- - - - - - - - - - - - - - - - - - -
------------------- ------ _.
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1040, line 34, over $132,950 (over $66,475 if
®No. Your deduction is not limited. Add the amts in the far ri
for lines 4 through 27. Also, enter this amt an Form Ic2h col
line 36. 28
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CALL 1-800-321-1080 IF YOU HAVE A QUESTION ABOUT YOUR RETIRED 1099-R
Employer's Identification Number
23-2172209
Employer's name, address, and ZIP gods
COMMONWEALTH OF PENNSYLVANIA
INSURANCE DEPARTMENT
HARRISBURG PA 17120
Employea'a Social Security Number
047-48-3880
Employee's first name and Initial Lan name
KENNETH P BRADLEY
821 PHEASANT DR., N.
CARLISLE
009-00084 28,478.98
3 Social securely wag,
27,872.62
S Medlcale wages and
27,872.82
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employee Plan sick pay
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a Social security tax with;
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12 Sao Instructions for
is alte almeyers to me 19 Sala wages. I.P. etc. 17 State income lax 14. LOW wades, 1105, elc. 19LOgal income lax 20 Locality name
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I13 687078 27,872.82 780.14 27,872.82 278.78 PENN TWP
form M-2 Maps and Tax 0gmmu; der ml Nenwy. 1.11.81 eorlw ll,"m
Statauant7001 COPY B - TO BE FILED WITH EMPLOYEE'S FEDERAL TAX RF 7URN Oven. 11460008
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STATE E E.IIPLOYEESs RETIREMENT SYSTEM cs?
TOLL FREE: 1.800-633.5461
-Jers.su(F.pa.us
CLASS A vs AA - SPECIAL ESTIMATE COMPARISON
(Especial estimate letter provides Class A and Class AA comparison estimates based on a hypothetical retirement date
1=01. The estimated benefits will illustrate the benefit increase when Class AA is elected.
AGpred for: SSN: 047.48-3360
E Date of Birth: 08/09/1954
KEJNETH P BRADLEY Sex: MALE
821 PHEASANT DR N
CARLISLE PA 17013 Normal Retirement Date: 08/0912014
Counseling Center: HARRISBURG
I Class AA Election: NO RESPONSE
j' Information on how your estimates for Class A and Class AA were prepared is shown on the back of this page.
ACCOUiN I INr(J"IATION
dyea to audit: see special note on reverse) Class A Class AA
lVlth 2Pe Formula I With 2.55 Formula
3d State Service As Of 71'2/2001 9.7499 9.7499
!Sim Identified As Not Eligible For Class AA Formula (see note) 0.0060
1:W Average Salary As Of 7/ 2001 I 525,920.34 525,920.34
'3d Slember Contributions And Interest As Of 7/]/2001 .?.?. 512,977.36 512,977.36
?Ow WithM Withdrawal of Member's Money I I
=W%l SINGLE LIFE ANNMY 5192.37 5240.47
3hapdon provides the maximum monthly benefits to you for life. If
?m& before receiving in payments an amount equal to your total
mulcted deductions, the balance will be paid to your
itatiiciary(les).
W I RETIREMENT 5185.27 $231.59
31toption provides reduced monthly benefits to you for life. A
'dat Value is placed on your account. All payments you receive are
n wed from the Present Value. Any balance remaining at the time
fear death will be paid to your bendiciary(ies).
OPTION I PRESENT VALUE I $39,702.46 i S41,b28.16
E)titias Adjusted For a TOTAL Withdrawal Of I $12,977.36 812.977.36
MKMD - MAXIMUM SINGLE LIFE ANNL7TY I 5129.49 517739
3soption provides the maximum monthly benefits to you for life.
4a you take a total withdrawal. there is no death benefit payable.
ARSTED - OPTION I RETIREMENT 5124.71
$171.03
Ited tion provides reduced monthly benefits to you for life. A
Value Ls placed on your accounAll payments you receive are
from the Present Value. Ambalance remaining at the time
death will be paid to your ben e)iciary
lies).
ADJUSTED OPTION 1 PRESENT VALUE I $26,725.10 536,650.80
I1?81?1191?II?IIIIIIInI!lallilin!III!Illiall!IIII?I!lall?lll!IIIII
1111OOW1M33 01sm- 31629SER009.10.1509
OFAS-CL POINT OF CONTACT
DEFENSE FINANCE AND ACCOUNTING SERVICE TOLL-FREE 1-800-321-1080
CLEVELAND CENTER
PO BOX 99191 COMMERCIAL 12161 522-5955
CLEVELAND, OHIO 44199- 1126
REMINDER-THERE IS CURRENTLY AN OPEN TOLL-FREE FAX 1-800-469-6559 (NOT FOR VOICE
ENROLLMENT FOR SOP. IF YOU ARE NOT COMMUNICATION)
PARTICIPATING, OR NEED TO INCREASE YOUR
COVERAGE, THIS IS YOUR OPPORTUNITY TO
DO SO. THE OPEN ENROLLMENT ENDS TOLL-FREE NUMBER FOR CASUALTY REPORTING ONLY
.
FEBRUARY 29 2000. CONTACT YOUR 1-800-269-5170
NEAREST RAO/RSO FOR ADDITIONAL
INFORMATION.
A NEW SERVICE CALLED EMPLOYEE MEMBER SELF SERVICE (E/MSSI WILL SOON BE AVAILABLE
TO MILITARY RETIREES. E/MSS WILL ALLOW YOU TO ACCESS AND CHANGE SELECTED PORTIONS OF YOUR
RETIRED PAY ACCOUNT, EITHFR ON THE INTERNET, OR IF YOU DON'T HAVE INTERNET ACCESS, BY A TOLL-
FREE TELEPHONE NUMBER
IN THE NEAR FUTURE
Y
.
,
OU WILL RECEIVE YOUR NEW E/MSS PERSONAL
IDENTIFICATION NUMBER (PINT IN A LETTER FROM THIS CENTER, ALONG WITH INSTRUCTIONS THAT
EXPLAIN HOW TO USE E/MSS.
RETIREE ACCOUNT STATEMENT
SIATEMENI EFFECTIVE OATF NEW PAY DUE AS OF SSN
PAY ITEM OE9C81?PTIbN?Q9 '---JAN_ L-200_ML49_]
CROSS PAY It blf 1
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SOP COSTS ,
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TAXABLE INCOME 76,60
1,098.40 78,44
1,124.56 ALLOTMENTS/BONDS 121.04 .
121,04
_----- NET PAY 927.68 950.54
_
._.__
YEAR-TO-DATE SUMMARY INFORMATION AS FOLLOWS:
TAXABLE INCOME: 13,180.80 FEDERAL INCOME TAX WITHHOLDING: 596.16
NOTE: THESE AMOUNTS ARE. FOR INFORMATION ONLY. ANY CREDITS ISSUED AFTER DECEMBER I
FOR THE PRIOR TAX YEAR ARE NO
T REFLECTED IN THESE AMOUNTS. YOUR IRS 1099-R F'Olt TAX
YEAR 1999 WILL BE ISSUED TO YOU NO LATER THAN JANUARY 15, 2000.
PAYMENT ADDRESS
DIRECT DEPOSIT
TAXES -._.-?.-_?_....-?._._..-.- _? _... -._._-___..._..._..._.. .. ............
YOUR FEDERAL AND STATE WITHHOLDING STATUS, EXEMPTIONS AND AMOUNTS. - y
FEDERAL WITHHOLDING STATUS
: MARRIED
TOTAL. EXEMPTIONS: 01
FEDERAL INCOME TAX WITHHELD: 52.98
24899
PAMELA A. BRADLEY, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 99 - 6497 CIVIL
KENNETH P.' BRADLEY,
Defendant IN DIVORCE
CONFERENCE WITH
COUNSEL AND PARTIES
TO: Mindy S. Goodman Counsel for Plaintiff
Pamela A. Bradley Plaintiff
JofiriIIa-?J-"Kopecky Counsel for Defendant
Kenneth P. Bradley Defendant
A conference has been scheduled at the office of
the Divorce Master, 9 North Hanover Street, Carlisle,
Pennsylvania, on the 26th day of September 2002, 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: 9/6/02 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 Elicker, 11
Divorce Master
Traci Jo Colyer
Office Manager/Reporter
Mindy S. Goodman
Attorney at Law
Northwood Office Center
2215 Forest Hills Drive
Suite 35
Harrisburg, PA 17112
May 6, 2002
West Shore
697.0371 Ext. 6535
Johnna J. Kopecky
Attorney at Law
SAIDIS, SHUFF, FLOWER & LINDSAY
26 West High Street
Carlilse, PA 17013
RE: Pamela A. Bradley vs. Kenneth P. Bradley
No. 99 - 6497 Civil
In Divorce
Dear Ms. Goodman and Ms. Kopecky:
Both counsel have indicated that discovery is complete.
A divorce complaint was filed on October 26, 1999, raising grounds
for divorce of irretrievable breakdown and economic claims of equitable
distribution, alimony pendente lite, and counsel fees and expenses. No
claim has been raised for alimony.
I am going to proceed on the basis that there are no issues with
respect to grounds for divorce and that the parties will either sign
affidavits of consent or have been separated for a period in excess of two
years.
In accordance with P.R.C.P. 1920.33(b) I am directing each
counsel to file a pretrial statement on or before Monday, June 10, 2002.
Upon receipt of the pretrial statements, I will immediately schedule a
,
Ms. Goodman and Ms. Kopecky, Attorneys at Law
6 May 2002
PaSe 2
pre-hearing conference with counsel to discuss the issues and, if
necessary, schedule a hearing.
Very truly yours,
E. Robert Elicker, II
Divorce Master
NOTE: Sanctions for failure to file the pretrial statements are set
forth in subdivision (c) and (d) of Rule 1920.33.
THE ORIGINAL PRETRIAL STATEMENT SHOULD BE FILED
IN THE MASTER'S OFFICE AND A COPY SENT DIRECTLY
TO OPPOSING COUNSEL.
FAILURE TO FILE PRETRIAL STATEMENTS AS DIRECTED
BY THE MASTER MAY RESULT IN THE MASTER'S
APPOINTMENT BEING VACATED.
LAW OITIUS
SAIDIS, SHUFF, FLOWER & LINDSAY
A PROFESSIONAL CORPORATION
26 WEST' I IIGI I STREET
CARLISLE, PENNSYLVANIA 17013
JOHN E. SLIKL' TELEPHONE: (717) 243.6222 • FACSIMILE.: (717) 243.6486
ROIIERTC. SAIDIS IiA1AIL: attorncyQsstl•law.rom
GEOFFREY S. SHUFF we svss0•law,com
JAMES D, FLOWER, JR.
CAROL J. LINDSAY
JOtINNA J. KOPECKY
KARL M, LEDEBOHNI
THOMAS E. FLOWER
WEST SHORE OFFICE:
2109 MARKET STREET
CAMP I [ILL, PA 17011
TELEPHONE: (717)737-310.5
FACSIMILE: (717)737.3107
REPLY TO CARLISLE
E. Robert Elickcr, 11, Esquire
Office of Divorce Master
9 North Hanover Street
Carlisle PA 17013
RE: BRADLEY V. BRADLEY
Dear Attorney Elickcr:
September 17. 2002
DlvoRcE-DOCKET No. 99.6497
Confirming our phone conversation, the second pre-hearing conference at your Office in
the above referenced case has been rescheduled to Tuesday, September 24, 2002 at 10:00
a.m.
Thank you for your assistance in this matter.
CJ Uahg
Very truly yours,
SAIDI HUFF, F ER & LINDSAY
CWI!
Cc: Mindy
S. Goodman, Esquire
Ken Bradley
PAMELA A. BRADLEY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 99 - 6497 CIVIL
KENNETH P. BRADLEY,
Defendant IN DIVORCE
TO: Mindy S. Goodman
Johnna J. Kopecky
, Attorney for Plaintiff
, 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 6th day of September 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: 6/10/02 E. Robert Elicker, II
Divorce Master
W Riegler • Shienvold
& Associates
Custody Evaluation
Referred By:
Elliot Riegler, Ph.D. (1948-1999)
Arnold T. Shienvold, Ph.D.
Melinda Gash, M.S.
James Gash, L.S.W.
Michael J. Asken, Ph.D.
Bonnie Howard. Ph.D.
Amy K. Keisling, A.C.S.1V, L.S.W.
Tracy Richards, A.C.S.W., L.S.W.
Don Lawrence, L.S.W.
Dyanne Seymore, L.S.W.
Jeffrey Pincus, Ph.D.
Ann Vcrgalcs, A.C.S.W., L.S.W., B.C,D.
Robert H. Davis, Jr., M.D.
Pamela A. Bradley vs. Kenneth P. Bradley
Mutual consent of the parties
Referral Reason: To conduct a comprehensive custody evaluation and to make
recommendations regarding the most appropriate custodial
arrangements for Jared Neil Bradley, DOB 6/3/92
Individual Interviews: Pam Bradley 2/17/00, 3/6/00, 3/20/00
Ken Bradley 2/28/00, 3/9/00, 3/20/00
Jared Bradley 3/28/00, 4/3/00
Lome Barlett 3/27/00
Psychological Testing: Minnesota Multiphasic Personality Inventory-2 (MMPI-2)
* Ken Bradley mww?
* Pam Bradley PLAINTIFF'S
* Lorne Barlett It EXHIBIT
Bricklin Perceptual Scale
* Jared Bradley
Home Studies: Each parent was observed interacting with Jared in their
home. The (tomes were evaluated for safety factors.
Parent-Child Interactions: Each parent was observed interacting with Jared in the office
setting
Additional Information: I. Reference letter for Lorri Bartlett from John M. Ravin,
M. D.
2. Letter from Pam Bradley dated 25 February, 2000 to
Dr. Shienvold
Fax: (717) 540-1416 • (717) 540-1313 a 2151 Linglestown Road, Suite 200 • Harrisburg, Pennsylvania 17110
9 -Z
Bradley v. Bradley
Page 2
3. Office records for Jared Bradley from Dr. Kenneth Small
4. Jared's school progress reports and tic log
The recommendations at the conclusion of this report are based on all of these
sources of information.
Background:
Ken and Pam met in the army while both were stationed at Ft. Bragg, North
Carolina. As a result of their relationship, Ken was relieved of his duty and reassigned to
Niagra, New York. Pam reports that she and Ken had discussed her confusion over her
sexual identity, but she wanted children so they continued dating. The relationship
continued and they got married two months after she graduated from Shippensburg. The
date of the marriage was 7/10/86.
Ken was the primary custodian of his two children from a prior marriage. Pam
would help care for the children and took on primary responsibilities following their
marriage. She reports that during the relationship, Ken and she would maintain separate
finances, separate vehicles, and they would go on separate vacations. They both retired
from the service in 1991 and eventually they moved to the Carlise area. Pam began
working part-time for Weight Watchers, and Ken began his employment with the
Commonwealth's Department of Insurance.
It was after the move that Pam became pregnant with Jared. Both parent's report
being very excited about die pregnancy. The only disagreement came over Pam's
decision to be a stay at home mother. According to Pam, Ken wanted her to return to
work. She refused, but was providing babysitting at home. Pam reported that she
experienced stress throughout the marriage. She experienced psychosomatic problems
such as fibromyalgia. She also suffered from depression for which she took Prozac.
Because she was refusing to be sexually involved with Ken, he accused her of having an
affair with another man. It was at that point that she admitted to him that she felt she was
gay.
From that point forward the relationship continued to deteriorate. Ken wanted
Pam to get help from a psychologist in Philadelphia who would help her see that her
"identity issues were curable." Pam had hoped to wait to leave because of Jared's
problems. However, she ultimately decided to separate and move into her cousin's home.
Pam now has her own apartment in which she and Jared live.
Bradley v. Bradley
Page 3
Initially, Jared was living primarily with his mother and Ken was seeing him on a
variable schedule. Fie always had him Monday evenings and Saturday mornings when
Pam was working. Additionally, he would sec Jared several overnights when mutually
agreeable. After the conciliation conference, the current schedule was put into effect.
Under this schedule, Jared is with his father alternating weekends from Friday until
Sunday. Ile also spends Wednesday nights with his father and Monday evenings and
Saturday mornings as long as Pain is working at those times.
Pam is seeking primary physical custody of Jared. According to Pam, she has
always served in that role. Pam feels that Jared needs the consistency of a primary home,
especially because of his diagnosis of Attention Deficit Disorder. Pam reported that Ken
has always been very involved in working out at a gym and goes virtually every night and
Saturdays. Pam is concerned that Ken does not exhibit very good patience with Jared,
especially in the evenings when his medications arc wearing down. Finally, Pam is very
concerned about the things that Ken is telling Jared about her. She reports that Ken has
told Jared that Pam loves Loni more than she loves him. Additionally, she reported that
Ken has been reading the bible to Jared and telling him that the devil is in his mother's
heart. Pam believes that Jared is angry at his father because of his lack of patience with
him. Pam feels that Jared is more comfortable with her in the apartment than he was in
the house when his father was there.
Ken believes that he is "the more competent parent." lie feels that a shared
custodial arrangement is in Jared's best interest because it would allow him to "settle in."
Ken points out the he and Pam live in the same school district, less than one mile from
one another. Ken reports that tic was a single father for a very long time with his son and
daughter and that he did a very good job with them. lie feels that the fact that he was in
the special forces in the army adds greater credibility to his ability.
Ken is concerned about Pam's mental health. lie reports that "she became two
different people from August 29ih to August 30"." lie feels that she suffers from an
identity disorder and that she is easily influenced by others. Ken noted that Pam takes
Prozac and that she has suffered with other physical disorders. Ken is upset that Pam is a
self-proclaimed lesbian because he believes it will be a bad influence on Jared. Ken feels
that Pam is negatively influencing Jared because lie loves her and believes in her.
Ken denied that he was an absentee father. tic admitted that Pam was home with
Jared most of the time. In fact, he noted that Pain was an excellent mother with Jared,
and her step-children. However, he feels that he was an excellent father. In spite of the
Bradley v. Bradley
Page 4
fact that he would work out in the evenings, Ken proudly stated that his children never
missed an activity that was scheduled for them. Ken also denied that he had a difficult
time with Jared's ADHD. He does, however, question the severity of the disorder, and
resists any attempts by the school to say that Jared is either autistic or suffers with
Tourette's Syndrome.
Analysis and Recommendations:
Jared is a 7 year old boy who is in the 1" grade in the Carlisle Area School
District. Jared was diagnosed with Attention Deficit Hyperactive disorder when he was 5
years old. However, his parents noted that he was extremely active from age 2 forward.
As Jared got older his behavior became increasingly more difficult to manage. He was
aggressive with peers, unable to focus attention, highly distractablc, and in constant
motion. Jared has been under the care of Dr. Kenneth Small since 1997. In consultation
with the family physician Jared was placed on Ritalin. The result has been a dramatic
decrease in all of his inappropriate behaviors. Both parents have worked with Dr. Small
on behavioral interventions in order to help Jared. Jared has also been trained in
relaxation techniques. This part of treatment was added after Jared's teachers noted that
he had several tics.
Jared has made a relatively good transition to school. He is a basically shy boy
who has some difficulty in peer interactions. Nonetheless, he has developed friendships at
school and he appears to like the school environment. Jared has also had some difficulty
with reading comprehension that the school has noted and is working on improving. For
the most part, Jared is on grade level in all areas.
Jared presented as a talkative little boy who was comfortable separating from both
of his parents. He reported that he was in the I" grade at Crestview Elementary school.
He feels that his teachers are nice, but his friends can be bossy. He also indicated that
sometimes he hits himself in the head. He is not sure why. lie has a relatively good
understanding of when he visits with his father.
Jared stated that both of his parents tell him that they love him. He also loves
them. He really likes dinosaurs and he has multiple toys and videos about them. He
reported that his mother plays more board games with him than his father. He and his
dad go to the gym a lot so his dad can work out. He doesn't like to work out because it is
boring. Jared also stated that he likes his mother's apartment because "there is no daddy
there to boss me and mommy around." Jared stated that, "Dad doesn't boss me around
any more."
Bradley v. Bradley
Page 5
Jared reported that his father reads the bible to him. However, Jared indicated that
his father tells him that the "real bible is in your heart." Jared stated that his father has
told him that "the devil is inside of mommy." According to Jared, his father has told him
that if Lord continues to come over to his mother's home, the devil will still be in her.
This is very confusing to Jared who doesn't want to believe that his mother has the devil
in her. He wants "God" to be inside of mom.
Jared reported that his father does not like Lorri, but Jared thinks that she is
"nice." Jared indicated that his father thinks it is "really bad" that mom has a girlfriend.
Jared does not think that it is bad. Jared also has some understanding from his dad that
there is a "very bad disease" that you can get, but "mostly men get it." fie hopes that his
mother does not dic from a disease.
Jared stated that he likes to spend time with both of his parents. When asked his
three wishes, he stated, "A dinosaur toy, My mom, me and Lorri to live in a museum, and
God to get inside of mom and be there forever." Jared does not wish that his parents
were back together, but he reports that his father does.
Jared's interactions with his parents both in the office and the home are
noteworthy. Pam interacts with Jared in a relatively easy, comfortable style. She puts
limits on Jared's behavior when it is necessary, but does so in a supportive and reassuring
manner. Pam was comfortable in playing games with Jared at home and in the office and
Jared took pride in pleasing his mother. Pam was able to anticipate Jared's needs and
respond to them as they were expressed. Although generally active, Jared appears to be
calmer in his mother's care than his father's. It should be noted that on the day of his
home visit at his father's home, Jared had refused to go with his father. It was necessary
for Pam to bring him to Ken's home.
As noted above, Jared appears to be more hyper, and more anxious in his father's
care. This was particularly true in the office setting. Ken appears to enjoy his time with
Jared, but he also becomes frustrated more easily with Jared's lack of focus and attention.
Ken is also frustrated by Jared's lack of interest in athletics and outdoor activity. He
repeatedly attempted to engage Jared in that type of activity at the home, but Jared only
wanted to play with his dinosaurs. Ken also appeared to have more difficulty placing
routine limits on Jared, such as no kickball in the house.
Jared completed the Bricklin Perceptual Scale. It is apparent when reviewing his
scores that Jared secs little difference between his parents in the areas measured by this
Bradley v. Bradley
Page 6
instrument. The total points that he gave each of his parents were virtually equal.
However, in individual categories Jared scored his father as higher in 14, his mother
higher in 8 and there were 9 ties. This test is consistent with Jared's self assessment that
he enjoys his time with both parents and that both of them care for him adequately.
Ken Bradley is a 45 year old man who currently works for the Commonwealth.
Ken's job is basically from 8:30 AM to 4:30 PM five days per week. lie finds that
working out and taking Yoga are greatly relaxing for him and he engages in them 6 days
per week. Ken is not in another relationship at this time. fie has three children, two
grown children from his previous marriage and Jared. Ken considers himself an active
individual who enjoys athletics. He is also very focused on religious issues at this time.
Ken admitted that he reads the bible to Jared and attempts to teach him stories
about life through bible stories. He has told Jared that homosexuality is a sin in God's
eye. He has told him that the devil is in his mother when she acts that way. Ken has also
shared with Jared that if he and mommy get a divorce he will have to sell the home. This
fact disturbs Jared, greatly. Ken justifies his openness with his son by saying that Jared
has a right to know the truth. Ken is always honest with him.
Ken presented as an angry man who appears to be in significant emotional pain.
He tended to deny the emotional impact of the overall situation and re-direct his focus to
what he perceived as the emotional problems of Pam. Ken sees himself as righteous and
injured by the actions of Pam. He denies any depressive symptoms at this time.
However, he appeared to be relatively anxious during his interviews. Ken seems to be a
man who expresses himself in straight forward terms and his emotional expressions are
limited. Interpersonally, Ken appears to be an individual who prefers to keep to himself.
Ken completed the MMPI-2. His results are valid. The results of the test suggest
that Ken is mildly defensive and sees himself as virtuous, scrupulous and self-controlled.
Affectually, individuals with this profile may be chronically tense and experience
considerable turmoil including agitation, irritability, and nervousness. There may also be
strong feelings of hostility and resentment. Similar individuals tend to be rigid and
suspicious of others. They may also over-react to criticism. They have high energy
levels, but may, at times, lack impulse control. Relationship problems arc common and
they arc prone to being socially withdrawn or introverted. They may also experience
sexual problems because of problems with inadequacy. Social alienation and a lack of
rapport with others is common. Men with this profile tend to have ruminative and
obsessive thoughts. There is the possibility of poor judgment secondary to difficulties
Bradley v. Bradley
Page 7
with common sense. Projection is probable. Peelings of being mistreated and
suspiciousness are apparent. This profile is associated with significant psychiatric
problems ranging from severely neurotic to personality disorders.
Pam Bradley presented as a friendly, cooperative individual who was quite
anxious about the evaluation. She admitted to the fact that she is a lesbian, an issue she
has struggled with for most of her adult life. At this point in time, she expresses no
ambivalence about her sexual identity. Pam denied significant feelings of anxiety or
depression, except that which is experienced secondary to the marital break-up and
custodial dispute. Pam is a woman of at ]cast average intellectual ability. She is a
graduate of Shippensburg University. Pam's interpersonal skills appear to be well
developed and no deficits were noted in her cognitive abilities. Although Ken suggested
that she hated him, Pam did not exhibit the type of anger that would suggest that type of
emotion. She has a history of depression secondary to the marriage and has taken Prozac
for those symptoms. Pam also has a history of pain syndromes.
Pam's MMPI-2 profile is valid. She has taken a somewhat defensive approach to
answering questions. Individuals answering in this manner are generally psychologically
naive. The naivete is associated with a generally optimistic attitude. Women with this
profile often reject traditional feminine values and pursue occupations or activities
typically associated with males. They arc individuals who prefer to be alone or with
small groups. These individuals tend to avoid unpleasant issues by using denial or an
overly positive perception. There is no psychiatric diagnosis associated with this profile.
Given all of these factors, it is recommended that Jared Bradlev remain in the
primary physical custody of his mother. It is recommended that his fathcr continue to
have visitation with him on alternating weekends and every Wednesday from after school
until Thursday morning. Additionally, Jared should spend the Monday evening following
a non-custodial weekend with his father, from aller work until 7:30 PM. Holidays should
be shared equally, and both parents should be allowed up to two weeks of vacation time
with Jared in the summer.
There are multiple reasons for this recommendation. Most importantly, Pam has
always served in the capacity of primary custodian and she has demonstrated herself to be
a competent and loving parent. Even Ken would agree with this statement as it relates to
the time preceding her announced sexual preference. On the other hand, Ken has been
less involved in the daily care giving for Jared and he appears to be less comfortable in
that role than is Pam.
Bradley v. Bradley
Page 8
Secondly, Jared has been diagnosed with severe ADHD. There is no question
about that diagnosis. Children with this disorder need stable and consistent routines in
their lives. Although Pam can tend towards being overprotective of Jared, as noted by
Ken with respect to foods and activities, in general she insures that Jared's routines are
stable and that his educational, physical and emotional needs arc cared for. Pam has
made certain that Ken has been included in all important decisions regarding Jared. She
has encouraged the father-son relationship, in spite of the feedback that she receives from
Jared regarding Ken's statements about her.
Finally, Ken has been exhibiting extremely poor judgement regarding the
information that he is sharing with his son. lie appears to have little understanding that
Jared is far too young to be able to understand that which his father is saying.
Additionally, Ken is promoting propaganda associated with his believes, not facts or
"Truths." The result of Ken's conversations with Jared is to create confusion and fear in
him. This judgement is so poor that if Ken is unwilling to change the behavior, it is
recommended that his time with Jared be further limited. It is also strongly recommended
that Ken seek individual counseling to help him deal with the hurt and sense of betrayal
that he feels. The counselor should also work with Ken to recognize that which is
appropriate and inappropriate for young children.
One final note. Issues have been raised about Lorie Barlett's involvement with
Jared. Ms. Barlett allowed herself to be evaluated in spite of the fact that her relationship
with Pam is quite new and her relationship with Jared is relatively minor. Ms. Barlett
was open in her approach to the evaluation. She received an excellent reference from Dr.
Ravin, a psychiatrist with whom she works at the Terraces. Currently, Lome is a
graduate student in clinical psychology, and works for the Boys and Girls Club of
America. Lome has a previous marriage, but now is comfortable as a lesbian. She feels
that she has a close relationship with Jared, although it is relatively new. There was
nothing within the clinical interviews or psychological testing of Lome that would cause
a change in the custodial recommendation for Jared to be primarily with his mother.
:5 Noo
Dated
?42 z?,-,-- IL .- C7
Arnold T. Shienvold, Ph.D.
Jun 14 00 OSt47e Riegler, Shienvold L nsso 717-540-1416
h
ARNOLD TERRY SHIENVOLD, PH.D., BCFE
2151 Linglestown Road
Harrisburg, PA. 17110
717-540.1313
EDUCATION
Pennsylvania License,N PS-003203-L 1979
University of Alabama 1977
Tuscaloosa, Alabama
Major. Clinical Psychology
Degree: Ph.D.
Speciality: Child Clinical
University of Alabama 1976
Tuscaloosa, Alabama
Major. Clinical Psychology
Degree: M.A.
Colgate University 1972
Hamilton, New York
Degree: A.B.
PROFESSIONAL EXPERIENCE
Private Practitioner Sept. 1980 - Present
Riegler, Shienvold & Associates
2151 Linglestown Road, Suite 200
Harrisburg, PA.
Ad unct Professor January 1996 -
Widener School of Law Sept 1997
Clinical Direct or Oct. 1985 -July 1987
Behavioral Medicine and Psychological Services, Ltd.
Cental Pennsylvania Cardiac Pulmonary Vascular Physicians, Ltd.
Lemoyne, PA.
P.2
Jun 14 00 09t49a Riesler, Shlenvold L nsso 717-540-1416
P.ate..2
Consult
Central Dauphin School District
Harrisburg, PA.
Co-Director
Center for Behavioral Medicine
Polyclinic Medical Center
Harrisburg, PA.
ronsultant
Cardiac Treatment Centers
Camp Hill, PA.
Aug. 1982 - June 1987
1982 -1985
Sept. 1978 -1985
Adilmct Professorship Aug. 1977 - July 1984
Department of Behavioral Science, Dept. of Family Practice
Hershey Medical Center
Hershey, PA.
Resource PsycholoQiat
Ridgecrest Children's Center for Emotionally Disturbed Children,
Tuscaloosa, AL
Developing treatment plates for 10 -13 year old children, training staff
in implementation and providing individual and group psychotherapy.
PROFESSIONAL AFFILIATIONS
Board of Governors, American Academy of Family Mediators 1996 - Present
Association of Family and Conciliation Courts 1993 - Present
Diplomate, American Board of Forensic Examiners 1996 - Present
Academy of Family Mediators - Practitioner Member 1985 - Present
Pennsylvania Psychological Association - Fellow 1985 - Present
American Psychological Association 1976 - Present
Association of Family and Conciliation Courts 1993 - Present
p.3
.. ....a,.o Z;K
Jun 14 00 09348a Rlegler, Shlenvold & Rsso
Page 3
WORKSHOP PRESENTATIONS:
717-540-1416 p.4
Presenter Evaluating Mobility Cases, AFCC Conference
June 1999
Presenter Ethical Issue in Custody Evaluation and Mediation
Michigan Association Court Mediators, September 1999
Presenter Evaluative Mediation, Wisconsin Association of
Mediators, November 1999
Presenter The use of Question in Family Mediation
Virginia Mediation Network, November 1999
Co-Presenter Ethics Forum, Academy of Family Mediators,
San Diego, CA. 1996,1997
Workshop Leader Pulling the Data Together, AFCC Custody Conference,
Breckinridge, Colorado, September 1997
Workshop Leader Evaluative Mediation, Academy of Family Mediators
Cape Cod, July 1997
Workshop Leader Integrated Model of Custody Resolution, Association
of Family and Conciliation Courts, Clearwater, FL.
January 1996
Panel Member Hot Issues in Custody, Pennsylvania Bar Institute
Fall 1995
Institute Leader Duel Roles in Custody Conflicts, Academy of Family
Mediators Conference, Cincinnati, OH., July 1995
Presenter Family Mediation - Central Pennsylvania Paralegal
Association, October 1993
Jun 14 00 09:48& R1&gl&r, Shlonvold L nsso 717-540-1416
PSgflA
Panel Member Conflicts, Problems and Ethics in Custody Evaluations
June 1995. Pennsylvania Psychological Association
Annual Meeting, Harrisburg, PA.
Workshop Panelist High conflict custody cases: Association of Family and
Conciliation Courts annual conference, New Orleans, LA.
April 1993
Workshop Panelist Custody Litigation, Evaluation, Mediation:
Cumberland County Family Law Division, May 1992
Workshop Panelist The Use of Psychological Testing in Custody Evaluation,
Pennsylvania Bar Association, May 1991
Seminar Leader Psychologists in Family Medicine. Society of Teachers
of Family Medicine, San Diego, CA. May 1978
Seminar Leader Stress Reduction, Hershey Medical Center
Hershey, PA. 1978
Shienvold, A.T. Why research is not done in family practice residencies.
Presented at Pennsylvania Consortium of Family Practice
Residencies, Hershey, PA. September 1977
Shienvold, A.T. and Resident view of their behavioral education. Association
Asken, M.A. of behavioral Sciences in Medical Education.
October 1977.
P.5
Shienvold, A.T. Medical Psychology: The role of the psychologist within
the hospital. Presented at Northeastern Association of
Operating Room Technicians, Harrisburg, PA. February 1978.
Shienvold, A.T. A dual focus behavioral science curriculum. Symposium
of APA meeting. Toronto, Canada 1978
Jun 14 00 09t49a Riegler, Shienvold & Rsso 717-540-1416
PUBLISHED ARTICLES
Shienvold, A.T. Family Practice Residents Perception of Behavioral Science,
Asken, M.A. Training: Relevance and Needs. Journal of Family Practice.
Cincotta, J.
Bryan, T.F. Behavioral Medicine: A Review. Primary Care,
Asken, M.A. November 1978
Shienvold, A.T.
HONORS
President Academy of Family Mediators, 1999 - Present
Treasurer Academy of Family Mediators, 1997 -1998
Chairman Ethics Committee and Conference Committee for
Academy of Family Mediators, 1996 -1999
Approved Consultant Academy of Family Mediators, 1993 to present
p.6
Member Dauphin County Task Force to create a parent education
curriculum for divorcing parents. September 1993 to present.
PAMELA A. BRADLEY, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-6497 CIVIL TERM
KENNETH P. BRADLEY,
Defendant Civil Action Law
PREHEARING MEMORANDUM OF THE
DEFENDANT, KENNETH P. BRADLEY
AND NOW comes the Defendant, Kenneth P. Bradley, by and
through his attorneys, Saidis, Shuff & Masland and presents the
following pre-hearing memorandum:
1. Factual/Procedural History
The parties are the natural parents of one child, JARED
NEIL BRADLEY, who was born June 3, 1992. The parties were
married on July 10, 1986, and separated on October 27, 1999.
Since the parties' separation, Mother has had primary
physical custody of the child, and Father has periods of
partial physical custody namely weekends Friday after school
until Sunday at 7:00 p.m., each Saturday morning from 7:30 a.m.
until 1:00 p.m., every Wednesday from after school until
Thursday morning and for a time period, each Monday evening
from after school until 8:00 p.m.
The parties live in very close proximity to each other,
SAIDIS,
SHUFF &
MASLAND
ATTORNEYS-AT-LAW
16 W. High street
Carlisle, PA
and they are in the same school district.
The parties could not agree at a custody conciliation, and
a psychological evaluation was performed on the parties by Dr.
Arnold T. Shienvold, who basically recommended that the current
custody schedule remains in effect. Father still seeks shared
physical custody as well as shared legal.
1. Kenneth P. Bradley, Defendant and Father of the
child.
2. Mary Bowser, Jared's maternal grandparent who could
testify as to the interactions with the parties over
the years.
3. H. Robert Bowers, Jared's paternal grandparent who
could testify as to the interactions with the parties
over the years.
4. Valerie J. Bradley, daughter of the Defendant who
could testify as to the interactions with the parties
when all lived together.
5. Donna and George Colvin, the niece of the Defendant
and her husband who is familiar with the interactions
of the parties.
6. Rose Treaster, a babysitter of the child who is
familiar with the interactions of the parties as
well.
III. Proposed Resolution of the Case
It is proposed that the parties share physical and legal
SAIDIS,
SHUFF &
MASLAND
ATTORHM-ATNAW
26 W. 111th Siren
Carlisle. PA
custody of the child, on a week-on week-off basis with an
alternate weekend night visit with the non-custodial parent.
Respectfully submitted,
SAIDIS, SHUFP JMA$Im1L
By:
uo na J.,/Deity, q.
2 W. High Stre
Carlisle, PA 17013
717-243-6222
Attorney for Defendant
PAMI'LA A. BRADLEY,
Plaintiff
VS.
KENNETH P. BRADLEY,
Defendant
IN TI IE COURT OF COMMON PLEAS
CUMBERLAND COUNW, PENNSYLVANIA
NO. 99-6497 CIVIL TERM
Civil Action - Law
Custody
PRE-TRIAL MEMORANDUM
AND NOW, carries the Plaintiff, PAMELA A. BRADLE=Y, by and through
tier attorney, MINDY S. GOODMAN, Attorney at Law, and files the followinlt Pro-
Trial MomorandUfn.
L Staternanl of lho Case:
Plaintiff and Defendant are the natural parents of Jared Neil Bradley, born
.June 3, 1992. Jared in a happy, well-adjusted child who suffers with and is being
treated for Attention Deficit hyperactivity Disorder, and who lives primarily with
his mother.
11y Order of Febmary 23, 2000, Plaintiff retained primary physical custody
of the child and Defendant retained partial physical custody as follows:
a. Allornatiny wookends from Friday after school until Sunday
nt 7:00 p.m.
b. Saturday morning% from 7:30 a.m. until Saturday altomoon
at 1:00 p.m. ?? r•n c.,F. I/
t
A?? k
?:Y:
C. Wednesday after school until Thursday morning prior to
school.
d. Monday evening after school until 0:00 p.m. until March dti
when the Monday visits were to cease.
I. -Is-SUP:
Whether the Plaintiff should retain primary physical custody of the minor
child subject to partial visitation with the Defendant.
Ill._ _-Stipulated_lssijes and_Facts:
a. Mother has had primary physical custody of the minor child
since the parties separated in the early fall of 1999.
b. At the initial custody conference in this case held on January
27, 2000, the parties agreed to have a custody evaluation conducted.
Oink t e•ustod evaluation was rerforme•d by Dr Arnold Shienvold who
., c .. y. ..f.
recommended that Plaintiff retain primary custody of the minor child and
that Defendant have partial physical custody, which is to be limited if
Defendant is unable to refrain from making harmful statements to the child
about his mother, the Plaintiff.
k
rte
IV. Witnesses:
n. Plaintiff will testify as the child's mother concerning her
day-to-day care and maintenance of the child, the child's positive physical
7
and emotional responses to mother being the primary caretaker, the
detrimental impact that the statements of the child's father is having on the
child both physically and emotionally, and the positive nature of the
iclationship that the child has with Lorrie Bartlett, who is the significant
other of the Plaintiff.
Plaintiff will also testify about what she believes to be a workable cim.lo fial
arrangement that she believes is in the child's best interest and still allows
for continued growth of the relationship between Defendant and his non.
b. Dr. Arnold Shienvold, the custody evaluator, will testify
concerning his evaluation, report and recommendations regarding child
custody.
C. Lorrie Bartlett will testify about her relationship with the child
and her observations about the Plaintiff being a good, raring, competent
parent to the child.
d. The child is eight (8) years old, expressive, and capablo of
discussing this situation with the Honorable Judge I less in chamber... The
child will not be present during the hearing, but will be at the courthouse
and available to speak with the Judge, if so required.
e. Plaintiff reserves the right to supplement this list as the
nerd may arise al the hearing.
a
V. Exhibits:
a. Custody Evaluation Report and Recommendation.
b. Defendant reserves the right to supplement this list of exhibits in as
the need may arise at the hearing.
VI.._ _I'roposed Resolution:_
Taking into consideration that Plaintiff has been the primary caretaker of
the, child since his birth coupled with Dr. Shienvold's report and recommendation
after having conducted a full custody evaluation in this case, the Plaintiff
proposes that the following recommendation of Dr. Shienvold be entered as an
order of Court:
a. Plaintiff/Mother shall retain primary physical custody of the
minor child.
b. Defendant/Father shall have partial physical custody an.
follows:
1. Alternating weekends from Friday after school until
Sunday evening at 7:00 p.m.
2. Every Wednesday after school until Thursday
morning. If father is going to the gym for a workout, he shall drop
the child at his mother's horse prior to the workout and pick him up
after his workout is complete.
4
All
3. Monday evening following father's non-custodial
weekend from after schnol until 7:30 p.m., except on those
orcasions when father will he going to the gym and leaving the
child with the health club daycare provider.
C. Holidays shall be shared equally between the parties.
d. Each party shall be allowed up to two weeks of vacation time
with the child in Ilia summer.
e. If Defendant/Father does not refrain from making the
negative comments about Plaintiff/Mother, Defendant's partial visitation
with the minor child should be further limited.
Respectfully submitted,
Mindy S. Goodman
Attorney at Law
Attorney I.D. #78407
2080 Linglestown Road
Harrisburg, PA 17110
(717)540-874'2
Attorney for Defendant
.? o
DATE: - 17
5
PAMELA A. BRADLEY. )
Plaintiff )
VS. )
KENNETH P. BRADLEY, )
Defendant )
IN TI IE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 99-6497 CIVIL TERM
CIVIL ACTION - LAW
ORDER
AND NOW, this day of '9127 a , 2000, upon receipt of the
Conciliator's Report, it appearing that a (tearing is necessary, it is hereby ordered as follows:
A hearing is scheduled for the L?%y of 2000,
at ', 0-6 o'clock A M., in Court Room Number '?( of the
Cumberland County Court House, Carlisle, Pennsylvania. Both parties, through
counsel, will provide each other and the court with a list of witnesses ten (10)
days prior to the date 4 f the hearing along with a statement as to their expected
testimony. Additionally, both parties will submit their proposal for a resolution of
the matter.
Pending said hearing, the schedule contained in the Order of February 23,
2000, shall remain in full force and clTect.
Mindy S. Goodman, Esquire
Johnna Deily, Esquire
mlb
BY'f1IE COURT
KE A... I IIESS, J).
Li
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tr
11 cy,
U (-7 V
PAMELA A. BRADLEY,
Plaintiff
VS.
KENNETH P. BRADLEY,
Defendant
JUDGE PREVIOUSLY ASSIGNED:
IN TI IE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 99-6497 CIVIL TERM
CIVIL ACTION - LAW
The I lonombie Kevin A. I less
CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITII CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the child(ren) who is(are) the subject of this
litigation is as follows:
NAME BIRTI (DATE CURRENTLY IN
CUSTODY OF
Jared Neil Bradley June 3, 1992 Plaintiff
2. A Conciliation Conference was held on May 11, 2000, and the following individuals
were present: the Plaintiff and her attorney, Mindy S. Goodman, Esquire; the Defendant and his
attorney, Johnna Deily, Esquire.
3. Items resolved by agreement: See attached Order.
4. Issues yet to be resolved: See attached Order.
5. The Plaintiffs position on custody is as follows: Mother believes that the current
custodial arrangement is in the best interest of the minor child. She notes that the child has
special needs because of his diagnosis with ADI ID. She has been the primary caretaker
child and she ensures that he has the stable environment necessary to take care of those needs :?-?
Additionally, the Mother is very much concerned by the actions of the Father.
Specifically, Father has been reading passages of the Bible to the son and indicating that the
"devil is inside of Mommy" because Mother has, after a long struggle with her sexuality,
determined that she is a lesbian and has a significant relationship with another woman. Mother
believes that the actions by the Father are harmful to the son which was also confirmed by the
evaluator.
Mother cooperated with having an evaluation done by Arnold Shicnvold, Ph.D., and is in
agreement with his recommendation which is to maintain the status quo.
6. The Defendant's position on custody is as follows: Father disagrees with the
recommendation of Dr. Shienvold. He wants a week-on, week-off arrangement. He
acknowledges that his son has special needs.
Father also acknowledges reading Bible passages to his son and indicating that his
Mother has the devil in her as a result of her self-proclaimed sexuality switch. Father does not
believe that it is a problem for him to express his views to his son and does think that his
Mother's actions in expressing her homosexuality is wrong.
7. Need for separate counsel to represent child(ren): Neither party requested.
8. Need for independent psychological evaluation or counseling: None requested and the
?t
Conciliator does not believe any is necessary.
9. A hearing in this matter will take one-half day.
10. Other matters or comments: The parties separated in November, 1999. They have
one minor child who is going to be eight. The child is diagnosed and being treated for ADHD.
The parties agreed to have an evaluation completed by Dr. Shicrrvold. Dr. Shienvold
unequivocally indicated that Mother should retain primary physical custody of the child subject
to the schedule that was set up at the previous conciliation,
Apparently the major issue in this case involves Mother's sexuality. Mother apparently
was struggling with her sexuality for years and now acknowledges that she is a lesbian. Father
cannot seem to accept this. lie apparently has told the minor child that his Mother has the devil
in her and that she can be cured from this affliction. Dr. Shienvold is adamant in his
recommendation that the Father must understand that he should not be taking this type of
position with the minor child and that it is detrimental for the minor child. In fact, Dr. Shienvold
said that if the Father continues with this type of behavior, then his time with the child should be
decreased.
Father does not think that he is doing anything wrong and is adamant about his views
towards the Mother's sexuality.
Given the fact that the parties involved themselves in a complete evaluation and that
Dr. Shienvold made a very clear recommendation in this case, the court will have to look
carefully as to why Father believes it is in the best interest to have a week-on, week-off
arrangement. If Dr. Shienvold's observations turn out to be accurate, then the Father must
understand that while he may not like Mother's decision regarding her sexuality, her sexuality in
and of itself is not a basis for the Court to review the custodial arrangement. On the contrary, if
Father continues with his behavior in this case, the Court needs to look at the recommendations
of Dr. Shienvold to limit the Father's contact with the child since apparently his continued
insistence upon attacking Mother's sexuality with the child is affecting the child.
Date: May 17, 2000
I ?jv
Michael L. Bangs
Custody Conciliator
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PAMELA A. BRADLEY : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : 99-6497 CIVIL
: CIVIL ACTION - LAW
KENNETH P. BRADLEY, : IN CUSTODY
Defendant
ORDER
AND NOW, this 1 y ? day of July, 2000, after hearing and careful consideration of the
testimony adduced, it is ordered and directed that the parties shall share legal custody of the
minor child, Jared Neil Bradley, born June 3, 1992.
1. Primary physical custody of said child shall be in his mother, Pamela A. Bradley,
subject to periods and conditions of partial custody in his father, Kenneth P. Bradley, as follows:
a. On alternating weekends from Friday alter school until Sunday at 7:00 p.m.
b. From Saturday morning at 7:30 a.m. until Sunday afternoon at 1:00 p.m.
c. Every Wednesday from after school until Thursday morning.
d. Such other times as the parties shall agree.
2. During what remains of the summer of 2000, the father shall have the right to one full
week of custody as the parties shall agree and, if they cannot agree, to consist of a full week in
August either beginning with or ending with a period of the father's alternating weekend of
partial custody.
3. The parties shall share major holidays as they shall agree and in the event of a
disagreement, either party may request the return of this matter to the conciliator. From and after
January 1, 2000, the parties shall alternate periods of custody during the summer vacation from
school with exchanges in custody to occur on Sundays at 6:00 p.m. unless the parties otherwise
?.... -.r; ..I?f.`.??.
??ragr
• `1
agree. Custody shall commence in the father on the first Sunday following the last day of
school.
Mindy S. Goodman, Esquire
For the Plaintiff
Johnna Deily, Esquire
For the Defendant
:rlm
BY THE COURT,
CQpLf? ??
7-0-QD
RX9
PAMELA A. BRADLEY
Plaintiff
VS.
KENNETH 11. BRADLEY,
Defendant
: IN THE COURT OP COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: 99.6497 CIVIL
CIVIL ACTION - LAW
IN CUSTODY
ORDER
AND NOW, this 12. v' day of July, 2000, a portion of our earlier order having been
entered in error, it is directed that paragraph I.b. of the order of July 14, 2000, be modified to
read:
"From Saturday morning at 7:30 a.m. until Saturday afternoon at 1:00 p.m. on those
Saturday momings when the mother works."
BY THE COURT,
Mindy S. Goodman, Esquire
For the Plaintiff
Johnna Deily, Esquire
For the Defendant
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PAMELA A. BRADLEY IN THE COURT OF COMMON PLEAS OF
PLAINTIFF : CUM BERLAND COUNTY, PENNSYLVANIA
V.
KENNETHP.BRADLEY
DEFENDANT 99-6497 CIVIL ACTION LAW
. IN CUSTODY
ORDFR OF COURT
AND NOW, Friday, February 23, 2001 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear befarcJaeguellne M. Verney, Esq. , the conciliator,
at 41h Floor, Cumberland County Courthouse, Carlisle on Wednesday, March 14, 2001 at 1:30 p.m.
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
FOR THE COURT,
By: /s/ faconelineAL Verney- Esal
Custody Conciliator ??x
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the
scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW'TO FIND OUT WHERE YOU CAN GE"I' LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
PAMELA A. BRADLEY,
Plaintiff
V.
KENNETH P. BRADLEY,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:NO. C17- 4'yQ7 l-it ic'm V?-j
: CIVIL ACTION - LAW
: IN DIVORCE & CUSTODY
AND NOW, upon consideration of the attached Petition for Modification of
Custody, It Is hereby directed that the parties and their respective counsel appear
before the Custody Conference Officer, on the day of
2001 at -.M. for a Pre-Hearing Custody Conference to be held
at
Pennsylvania. At such Conference, an effort will be made to resolve the Issues
in dispute; or if this cannot be accomplished, to define and narrow the Issues to
be heard by the Court, and to enter Into a Temporary Order. All children age five
or older are to be present at the Conference only if requested by the conference
officer. Failure to appear at the Conference may provide grounds for entry of a
temporary or permanent Order.
DATE:
FOR THE COURT:
Custody Conference Officer
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
PAMELA A. BRADLEY,
Plaintiff
V.
KENNETH P. BRADLEY,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO.
: CIVIL ACTION - LAW
: IN DIVORCE & CUSTODY
AND NOW, the Plaintiff, PAMELA A. BRADLEY, by and through her
attorney, Mindy S. Goodman, Attorney at Law, files a Petition for Modification of
Custody against Defendant, and in support thereof avers as follows:
1. The parties are the natural parents of one minor child, born of
wedlock, whose name and date of birth Is as follows:
JARED NEIL BRADLEY Born June 3, 1992
2. Plaintiff, PAMELA A. BRADLEY, is an adult individual currently
residing at 39 Winchester Gardens, Carlisle, Cumberland County, Pennsylvania
17013.
3. The Defendant, KENNETH P. BRADLEY, is an adult individual
currently residing at 821 Pheasant Drive North, Carlisle, Cumberland County,
4
Pennsylvania 17013.
4
4. By Court Order dated July 14, 2000, the Honorable Kevin A. Hess '&
?r.
ordered that the parties share legal custody of the minor child and that Plaintiff be i
awarded primary physical custody subject to periods of partial custody with t
Defendant as outlined in the Order.
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6. Plaintiff seeks to modify the Court Order and requests that she be
granted primary legal custody in addition to primary physical custody and In
support thereof avers as follows:
a. The minor child suffers with Attention Deficit Hyperactivity
Disorder and Tics Toulerette's Syndrome, and It is Plaintiffs belief that
Defendant is in denial about the extent of his son's condition and therefore
is not capable of making appropriate decisions regarding the child's
medical care and treatment.
b. Jared has always had difficulty with his social skills, and he
has been working with Dr. Small in this regard since Jared was five years
of age. His medical care providers, Kenneth G. Small, Ph.D. and Linda J.
Clark, M.D., have Indicated that in addition to one-on-one care with his
psychologist, Jared should be receiving special care and services through
his elementary school to assist him with developing appropriate social
skills. (A copy of letters from Jared's treating medical care providers are
attached hereto as Exhibit A.)
C. Jared's school has the ability and desire to do a Child Study
Team analysis to determine what services they have to offer Jared.
d. Defendant is unable or unwilling to recognize that Jared has
a problem with his socialization skills, he will not cooperate with the school
in getting Jared enrolled in the recommended programs; and because the
parties share legal custody, the school is unable to help Jared without
Defendant's consent.
e. If the parties continue to share legal custody, the minor child
will be denied the recommended care and services which are essential to
his successful development, and the parties will likely be engaged in
litigation each and every time the child's teachers and/or medical care
providers recommend some course of treatment for this child.
7. If Plaintiff is granted primary legal custody, she will make certain
that Defendant is continually updated on the child's progress, the Defendant will
be informed of anything and everything that is recommended for the child, and
the Defendant's concerns and comments will be welcomed by the Plaintiff;
however, In order to advance the best interests of the child, the final decision
making authority should rest with Plaintiff.
WHEREFORE, the Plaintiff respectfully requests this Honorable Court to
grant Plaintiff's request for primary legal custody of the parties' minor child.
Respectfully submitted,
?????? Cyrnc. ? r
Mindy S. Goodman, Esquire
Attorney ID No. 78407
2080 Linglestown Road
Harrisburg, PA 17110
(717) 540-8742
Attorney for Plaintiff
VERIFICATION
I verify that the statements made in the foregoing document are true and
correct. I understand that false statements made herein are subject to the
penalties of 18 Pa.C.S. § 4904, relating to unswom falsification to authorities..
Pamela A. Bradley
5
KENNETH G. SMALL, Ph.D. AND ASSOCIATES
HUM IORA1.51EDICI\E
010 E. MAIN ST.
MECIIANICSBURG. PA 17055.6515
TELEPHONE: (717) 795.8588
FAX: (717) 795.0541
January 24, 2001
Mindy S. Goodman
Attorney at Law
2080 Linglestown Road
Harrisburg, PA 17110
Re: Jared Bradley
Dear Ms. Goodman:
I am writing to you at the request of Ms. Pam Bradley regarding her son Jared.
As you are aware, I have been providing outpatient psychological services to Jared
since June of 1997.
It is my professional opinion that Jared continues to exhibit significant social
skills deficits which impair his relationship with peers in his elementary school setting.
Jared has plateaued with regards to outpatient psychological services in remediating
his social skills deficits. As such, I believe that it is psychologically necessary for him to
undergo a child study team evaluation at his elementary school and consequent
services to remediate his social skills deficits. Otherwise, Jared will continue to suffer
from inadequate peer relationships which are necessary to successful development.
If I can provide you with any other information, please do not hesitate to contact
me.
Respectfully yours,
Kenneth G. Small, Ph.D.
Certified School Psychologist
Licensed Psychologist
KGS/jah
cc: Pam Bradley
DEPARTMENT OF THE ARMY
DUNHAM U.S. ARMY HEALTH CLINIC. DOOM M900AC
CARLISLE BARRACKS. PENNSYLVANIA 17013•0007
A TINT*"or January 16, 2001
Pediatric Clinic
SUBJECT: Medical Statement
TO WHOM IT MAY CONCERN:
Jared Bradley has Attention Deficit Disorder and Tics Toulerette. He needs social
-,kills training to htlp with both disurdels.
Linda J. Clark, MD
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PAMELA A. BRADLEY,
Plaintiff
V.
KENNETH P. BRADLEY,
Defendant
MAR 15 2001bP
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,PENNSYLVANIA
No. 99-6497 CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 14' day of 2001, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. The Order of Court of the Honorable Kevin A. Hess, dated July 14, 2000
shall be supplemented as follows:
A. Both parties shall meet with the child's guidance counselor to discuss the
child's study team evaluation.
B. Both parties shall cooperate in scheduling and will attend the study team
evaluation.
C. Neither party shall do anything that may estrange the child from the other
party, or injure the opinion of the child as to the other party, or may hamper
the free and natural development of the child's love or affection for the other
party.
BY THE COURT,
cc: Mindy S. Goodman, Esquire
Johnna Kopecky, Esquire
Hess, J.
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PAMELA A. BRADLEY,
Plaintiff
V.
KENNETH P. BRADLEY,
Defendant
PRIOR JUDGE: Kevin A. Hess
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,PENNSYLVANIA
: No. 99-6497 CIVIL ACTION - LAW
: IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3.8, the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the child who is the subject of this
litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Jared Neil Bradley June 3, 1992 Mother
2. A Conciliation Conference was held on this matter on March 14, 2001.
Mother, Pamela A. Bradley, was present with counsel, Mindy S. Goodman, Esquire, and
Father, Kenneth P. Bradley, was present with counsel, Johrma Kopecky, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
3-r 5 -ul
Date
1acgt cline M. Verney, Esquire
Custody Conciliator
PAMELA A. BRADLEY,
Plaintiff
Vs.
KENNETH P. BRADLEY
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6497
: CIVIL ACTION - LAW
: IN DIVORCE
ORDER OF COURT
AND NOW, this I ?` day of lbu.....,Lmr , 2001, It is
hereby ORDERED AND DECREED that Defendant shall
?-esp.. d to
at the Plaintiff's First Request for Production of
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Documents within We{5? days of this Order.
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PAMELA A. BRADLEY,
Plaintiff
VS.
KENNETH P. BRADLEY,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 99-6497 CIVIL TERM
: CIVIL ACTION - LAW
: DIVORCE
PLAINTIFF'S MOTION TO COMPEL
PRODUCTION OF DOCUMENTS
And now, this la`t t day ofd c •-r...1,..., , 2001, Plaintiff, by
and through her attorney, Mindy S. Goodman, Attorney at Law, files the Instant
Motion to Compel Production of Documents and In support thereof, avers the
following:
1. Plaintiff is Pamela A. Bradley, Wife, who currently resides at 1637
Mt. Rose Avenue, York, York County, Pennsylvania.
2. Defendant Is Kenneth P. Bradley, Husband, who currently resides
at 821 Pheasant Drive North, Carlisle, Cumberland County,
Pennsylvania.
3. The parties hereto are spouses, having been married on July 10,
1986 and separating in October of 1999.
4. On October 27, 1999, Plaintiff filed a Complaint in Divorce against
Defendant requesting, among other things, equitable distribution of
marital property and other ancillary economic relief.
5. In order to develop the economic claims properly, Plaintiff made
multiple requests for the voluntary exchange of financial
Information.
6. All requests for the voluntary exchange of financial information
were ignored by Defendant, and on October 8, 2001, Plaintiff filed
and served on Defendant Its First Request for Production of
Documents. A true and correct copy of Plaintiffs First Request for
Production of Documents and the transmittal letter serving said
First Request for Production of Documents is attached hereto as
Exhibit A and made a part hereof.
7. No objection were filed to Plaintiffs First Request for Production of
Documents, yet no documents were provided as requested.
8. Plaintiff cannot ascertain the value of the marital assets or make a
motion for the appointment of a special master unless and until
Defendant produces the requested documents.
9. An Order must now issue directing Defendant to answer Plaintiffs
First Request for Production of Documents.
WHEREFORE, Plaintiff prays this Honorable Court to Issue an Order
directing Defendant to produce in their entirety, all of the documents requested
by Plaintiff within five (5) days of the Order.
Respectfully submitted,
Mindy S. Goodman
Attorney at Law
ID No. 78407
2215 Forest Hills Drive - Suite 35
Harrisburg, PA 17112
(717) 540-8742
Attorney for Plaintiff
3
VERIFICATION
I verify that the statements made in the foregoing document are true and
correct to the best of my knowledge, understanding and belief. I
understand that false statements herein are made subject to the penalties
of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities.
Date: s ? e o /
Pamela A. Bradley
y
4
CERTIFICATE OF SERVICE
A true and correct copy of the foregoing document was delivered to the
person or office listed below by first class mall on the date indicated, as follows:
Johnna J. Kopecky, Esquire
Saldis, Shuff & Masland
26 W. High Street
Carlisle, PA 17013
Date: z-)--.j,
c ..C
Mindy S. Goodman
Attorney at Law
2215 Forest Hills Drive - Suite 35
Harrisburg, PA 17112
(717) 540-8742
P4
4
PAMELA A. BRADLEY,
Plaintiff
VS.
KENNETH P. BRADLEY,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 99-6497 CIVIL TERM
: Civil Action - Law
: Divorce
PLAINTIFF'S FIRST REQUEST FOR
THE PRODUCTION OF DOCUMENTS
To: Kenneth P. Bradley, Defendant
c/o Johnna J. Kopecky, Esquire
Saidis Shuff & Masland
26 West High Street
Carlisle, PA 17013
Dear Mr. Bradley:
Pursuant to Rule 4009.11 of the Pennsylvania Rules of Civil Procedure,
the above-named Plaintiff, by and through her attorney, Mindy S. Goodman,
Attorney at Law, hereby demands that the party to whom these Requests for
Production of Documents are addressed answer fully, in writing, and under oath,
with the signed Verification attached hereto, the following Documents Requests,
and make available for inspection and copying all documents responsive to these
Document Requests, within thirty (30) days as prescribed by Rule 4009.12 of the
Pennsylvania Rules of Civil Procedure.
DEFINITIONS AND INSTRUCTIONS
Unless negated by the context of the Document Request, the following
definitions are to be considered to be applicable to all requests contained herein:
(A) "Documents" is an all-inclusive term, referring to any writing and/or
recorded jr .graphic matter, however produced or reproduced. The term
"docv,nents" Includes without limitation, correspondence, memoranda, interoffice
r,mmunications, minutes, reports, notes, schedules, analyses, drawings,
diagrams, Invoices, purchase orders, pleadings, questionnaires, contracts, bills,
checks, drafts, diaries, logs, proposals, print-outs, recordings, telegrams, films,
tax returns, and financial statements, and all other such documents, tangible or
retrievable of any kind. "Documents" also include any preliminary notes and
drafts of all the foregoing, in whatever form, for example, printed, types,
longhand, shorthand, on paper, paper tape, tabulating picture film, phonograph,
records, or other form.
(B) With respect to documents, the term "identify" means to give the
date, title, author, and addresses; "identify" with respect to documents further
To describe a document sufficiently well to enable the
individual making the request to know what such document is and to retrieve it
from a file or wherever it may be located;
To describe it in a manner suitable for use as a description in
a subpoena; and
(3) To give the name, address, position, or title of the person(s)
who has custody of the document and/or copies thereof.
(C) Whenever the expression "and/or" is used in these Requests for
Documents, the information called for should be set out both in the conjunctive
and disjunctive, and wherever the information is set out in the disjunctive, it
should be given separately for each and every element sought.
(D) No answer is to be left blank. If the answer to a Document Request
or a subparagraph of a Document Request is "none" or "unknown," such
statement must be written in the answer.
(E) These Document Requests are continuing, and any Information
secured subsequent to the filing of your answers that would have been
includable in the answers had it been known or available, are to be supplied by
supplemental answers.
(F) If additional space is required for an answer, attach supplemental
answer sheets that clearly identify the Document Request number.
(G) If you object to any Document Request or if any information
responsive to any Document Request is withheld based on any claim of privilege
or protection from discovery of any kind, describe generally the information
withheld, state the privilege being relied upon, and identify all persons or entities
who have or have had access to said information. If you refuse to provide any
document on the basis of a claim of privilege or protection from discovery of any
kind, with respect to each such document, set forth the following information:
3
(a) the date of the document;
(b) its author(s);
(c) all recipients of the document;
(d) the present location and custodian of the document; and
(e) the basis for the claim of privilege or protection from
discovery.
To the extent that the claim of privilege or protection applies only to a
portion of the responsive documents, all portions for which privilege or protection
are not claimed must be produced.
(H) The terms "you" and "your" Include, without limitation, Plaintiff, and
her agents or other representatives acting or purporting to act on his behalf or at
his direction.
DOCUMENT REQUESTS
1. Copies of the federal and state Income tax returns filed by you for
the past three years, together with accompanying worksheets Including W-2
forms; copies of federal and state income tax returns and profit and loss
statements for any and all corporations, joint ventures, partnerships or other
corporate or business associations in which you hold an interest.
2. All documents and statements, issued by any bank, savings
institution, or other financial Institution from a date one year prior to October 1,
1999, through the present.
4
3. All documents and financial statements prepared by you or on your
behalf since October 1, 1999.
4. All loan applications and loan documents pertaining to any sums of
money borrowed or to be borrowed by you, individually or jointly with any other
person, or as guarantor from a date one year prior to October 1, 1999 through
the present.
5. All brokerage statements and documents pertaining to any
accounts in which you individually, or with others, had any interest from one year
prior to October 1, 1999 through the present.
6. All documents and securities, including tax-free bonds and funds, in
which you individually, or jointly with any other person, had any interest from one
year prior to October 1, 1999 through the present.
7. All documents and stock certificates, not in house accounts, in
which you individually, or jointly with any other person, had any interest as of
October 1, 2001.
8. All mutual funds statements and documents received by you since
October 1, 1999 through the present.
9. All treasury notes, treasury bills, U.S. Savings Bonds, corporate
bonds, and municipal bonds, presently owned or in which you, individually or with
any other person, had any Interest from October 1998 through the present.
5
10. All savings certificates or certificates of deposit, or other depository
receipts presently owned or in which you had any Interest on October 1, 1999
through the present.
11. All documents Including, but not limited to, any Individual retirement
account, pension or profit sharing plan, savings plan, Keogh, 401(k) Plan, annuity
benefits, retirement plan, military pension or retirement benefits, stock bonus
plan, stock option plan, thrift plan (excluding social security benefits), with your
present employer, or any previous employer, or regarding any other retirement
benefits in which you, individually or with others, have or had any interest with
benefits still due, Including the summary plan description, and other such
Information regarding the terms of the retirement plan, as well as annual
statements for the past four years, plus the statement closest to the date of
marriage and the statements immediately preceding and immediately following
the date of separation.
12. All financial statements or documents referring to any deferred
compensation plan, to which you were or are entitled by reason of any present or
past employment.
13. All documents sufficient to show your Income and earnings records,
including but not limited to payroll stubs or wage statements, any commission
statements Issued by any employer, or any 1099s Issued by any person or entity
for which you have performed services for the past thirty-six months.
14. Any employment contracts or commission contracts with either your
current or previous employer to which you were a party in the past four years.
15. Documentation verifying the sale by you of any asset having a
value in excess of $250.00 from two years prior to October 1, 1999.
16. The lease or deed for the premises where you are presently
residing and/or the lease agreements and deed for any and all real property titled
in your name individually or jointly with someone else.
17. If you have been involved in litigation as a Plaintiff in the past five
(5) years, a copy of the Complaint, and a copy of any written correspondence or
other documentation memorializing any settlement offers made by your or on
your behalf.
18. If you have been Involved in litigation as a Defendant in the past
five (5) years, a copy of the Complaint, and a copy of any written correspondence
or other documentation memorializing any settlement offers made by your or on
your behalf.
19. All mortgages and mortgage notes and/or bonds relating to any real
estate you presently own, and current statements showing balances on such
obligations.
20. All documents relating to the purchase of a motor vehicle presently
owned by you, or in which you had an interest during the past four years,
Including a copy of the title to the vehicle.
21. All life insurance and annuity policies in which you have any
Interest as an owner, Insured, or beneficiary, including any change of beneficiary
forms executed by you within the past six years, including any statements
concerning the cash value of the policies.
22. All appraisals of real estate or personalty performed in the past five
years, Including the real estate assessments performed In conjunction with the
county-wide reassessment.
23. A prospectus of all investments in which you had any interest for
the past five years.
24. All correspondence received by you from the Internal Revenue
Service or state revenue office during the past three years, except the
submission of income tax returns.
'12
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Mindy S. Goodman
Attorney at Law
Attorney ID No. 78407
2215 Forest Hills Drive
Suite 35
Harrisburg, PA 17112
(717)540.8742
Attorney for Plaintiff
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October 8, 2001
Johnna J. Kopecky, Esquire
Saidis, Shuff & Masland
26 W. High Street
Carlisle, PA 17013
RE: Bradley v. Bradley
Docket No. 99-6497
DearJohnna:
Enclosed Is Plaintiffs Request for Production of Documents. We have turned
over all Information you have requested, but have not received the same
courtesy in return. Therefore, we have no choice but to file formal discovery. If
the requested documentation is not provided with in thirty (30) days, we will
immediately file a Motion to Compel and will seek attorney's fees.
Thank you for your attention to this matter.
Very truly yours,
Mindy S. Goodman
MSGlbsg
Enclosure
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PAMELA A. BRADLEY,
Plaintiff
vs.
KENNETH P. BRADLEY,
Defendant
TO: Mindy S. Goodman
Johnna J. Kopecky
.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 6497 CIVIL
IN DIVORCE
, Attorney for Plaintiff
, Attorney for Defendant
DATE: Tuesday, April 16, 2002
/ CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(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.
E
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(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
DATE COUNSEL FOR PLAINTIFF dX)
COUNSEL FOR DEFENDANT ( )
NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
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PAMELA A. BRADLEY ,
Plaintiff
V.
KENNETH P. BRADLEY,
Defendant .
,1U,v
IN THE COURT OF COMMON P S
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-6497 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
PRE-TRIAL STATEMENT
AND NOW comes the Defendant, KENNETH P. BRADLEY, by and
through his attorneys, Saidis, Shuff, Flower & Lindsay, and
respectfully files the following Pre-Trial Statement:
1. BACKGROUND INFORMATION:
The parties were married on July 10, 1986, and separated
on October 27, 1999. They are the parents of one child, Jared
Bradley, D.O.B. 06-03-92.
Wife is employed by The Commonwealth of Pennsylvania, and
nets approximately $1,960.00 per month. She also receives
disability check of approximately $500.00 per month. Husband
is also employed by The Commonwealth of Pennsylvania a nets
approximately $1,738.00 monthly. In addition, he nets
approximately $920.00 per month for his military pension as he
is in pay status. Currently, the husband resides in the
SAIDIS
SHUFF, FLOWER
& LINDSAY marital home and has been paying all household expenses,
ATTORNLYVAT•IAW
26 W.1116AStreet including a mortgage, taxes, and utilities on the property. ,
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II. REAL PROPERTY:
The parties are the owners of real estate located at 821
Pheasant Drive North, Carlisle Pennsylvania $121,000.00.
There is a mortgage to Wells Fargo, a mortgage with an
approximate balance of $88,000.00, leaving approximately
$33,000.00 of equity. Husband has been paying all bills on
the marital home.
III. CASH AND INTANOIHLE PERSONAL PROPERTY:
a. Husband owns a Commonwealth of Pennsylvania State Employees
Retirement System, with a date of separation value of
$10,400.00 and a present value of $13,950.00.
b. Husband's Defense Finance and Accounting Service Military
Pension is currently in pay status.
c. Wife's Commonwealth Retirement, value unknown.
a. 1988 Nissan Wagon owned by the Husband with a current
value of $1,000.00.
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATIORN •ATKAW
26 W. IlIgh Sift"
Carlisle. PA
b. A 1990 Yamaha cycle, value negligible.
c. A hot tub with an approximate value of $8,000.00 to be
transferred to wife provided she pays the lien against the
hot tub.
d. All other items of personal property have been distributed
to each party.
II
V. LIABILITIES:
a. Mortgage to Wells Fargo, date of separation liability of
$121,000.00 and current balance $88,000.00.
b. Hot tub debt on a Discover card with a date of separation
value of approximately $8,000.00 with a current balance of
$3,500.00.
C. Federal Credit Union debt for the roof and the deck with a
date of separation value of $5,800.00 and the current
value is unknown.
d. Metropolitan Life Insurance - $19,000.00 loan against the
life insurance policy of Husband, of which approximately
$14,000.00 is marital debt.
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATTOIUZ:7•AT.IAW
26 W. IIISh Slree:
Carllde, PA
VI. WITNESSES:
The Defendant does not anticipate calling any witnesses
other than himself.
VII, EXPERT WITNESSES:
Not Applicable.
tx
VIII. RESOLUTION OF ECONOMIC ISSUESs
Husband will keep the real estate known as 821 Pheasant
Drive North in Carlisle, and will continue to assume the
liability on the property. In addition, he will keep his
military retirement, and his Commonwealth retirement, which
should be offset against wife's retirement, which she may
III
keep. Husband will agree to pay the loan on his life
insurance.
Wife will receive the hot tub that remains in the marital
residence and continue to pay the loan on the hot tub. She
will also repay the personal loan that is taken out in solely
her name, keep her pension, and all of the personal property
that she removed from the home.
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATIORNDVATNAW
26 W. 1119h Street
Carlisle, PA
4
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A-
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3
IV
SAIDIS
SHUFF, FLOWER
& LINDSAY
AATNAW
26 W. High Street
Carlisle. PA
Date 6. 70-02-
Respectfully submitted,
SAIDIS, SNUFF, FLOWER & LINDSAY
l
<72
Johnna, . Kope ky, squire
Attor ey I.D.# 53147
26 West High Street
Carlisle, PA 17013
(717) 243-6222
Attorney for Defendant
v
CASE:
CIVIL ACTION- DIVORCE
NO. 99 - 6497 CIVIL TERM
Date: 5123102
INCOME AND EXPENSE STATEMENT
THIS FORM MUST BE FILLED OUT
KENNETH P. BRADLEY
INCOME STATEMENT OF:
I VERIFY THAT THE STATEMENTS MADE IN THIS INCOME AND EXPENSE STATEMENT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS
HEREIN ARE SUBJECT TO THE CRIMINAL PENALTIES OF 18 PA.C.S.§4904, RELATING TO UNSWORN FALSIFICATION TOAUTHORITY.
dUhe ?/. 2-002
DATE
INCOME:
EMPLOYER' __PENNSYLVANIA INSURANCE DEPARTMENT
1AYROLL NO. GROSS PAY PER PAY PERIOD $KENNETH P. BRADLEY (SAM)
ADDRESS: 1326 STRAWBERRY SQUARE, HARRISBURG, PA_
TYPE OF WORK:_CLERICAL SUPERVISOR
+?1 420854 1094.25
PLAINTIFFI NDANT
PAY PERIOD (WKLY, BI-WKLY., ETC.)
61-WKLY
1 rEMOEO PAYROLL DEDUCTIONS
FEDERAL WITHHOLDING 95.63 SOCIAL SECURITY 83.71 LOCAL WAGE TAX 10.94
STATE INCOME TAX 30.64 RETIREMENT 54.71 SAVINGS BONDS
CREDIT UNION LIFE INSURANCE HEALTH INSURANCE
OTHER DEDUCTIONS
(SPECIFY)SUPPORT 255.94 UNION DUES 16.41 OPTI•WAGE TAX
TOTALS
NET PAY PER PAY PERIOD $ _546.27
Service Type Page 1 of 5 Form IN - 008
Worker ID
'"income and Expense Statement
011101640129108
PACSES Case Number.
Other (Fill In Appropriate Column)
Income WEEK MONTH YEAR
INTEREST
Dividends
Pension/military 1165.81 (gross) 13989.72 (gross)
Annuity
Social Security
Rents
Royalties
Expense Account
Gifts
Unemployment Comp.
Workmen's Compensation
IRS Refund
Other
.-Other
TOTAL INCOME
r"
EXPENSES (Fill in Appropriate Column)
WEEK MONTH YEAR
HOME
Mortgage/Rent 819.95 9839.40
Maintenance 50.00 600.00
Utilities
Electric 120.00 1440.00
Gas 80.00 960.00
Oil
Telephone 40.00 480.00
Service Type Page 2 of 5 Form IN - 008
Worker ID
!come and Expense Statement
PACSES Case Number:
EXPENSES (Fill In Appropriate Column)
continued WEEK MONTH YEAR
Water 69.00 828.00
Sewer
EMPLOYMENT
Public Transportation
Lunch 60.00 720.00
TAXES
Real Estate 21.08 252.90
Personal Property 117.00 1403.00
Income
INSURANCE
Homeowners 12.00 120.00
utomoblle 20.50 123.001bi•annual
Life 121.00 1452.00
Accident
Health
Other-SBP 75.62 907.44
AUTOMOBILE
Payments
Fuel 65.00 780.00
Repairs
MEDICAL
Doctor
Dentist
Orthodontist
Service Type Page 3 of 5 Form IN - 008
Worker ID
come and Expense Statement
PACSES Case Number.
EXPENSES (Fill In Appropriate Column)
continued WEEK MONTH YEAR
Hospital
Medicine
Special Needs (glasses,
braces, orthopedic devices)
EDUCATION
Private School
Parochial School
College
Religious
PERSONAL
Clothing 30.00 360.00
Food 200.00 2400.00
Barber/Hairdresser 10.00 120.00
redit payments:
Credit Card
Char a Account
Memberships
LOANS
Credit Unlon-CBW 67.00 804.00
Capital One 114.00 1368.00
MISCELLANEOUS
Household help
Child Care
Papers/Books/Magazines
Entertainment
Pay TV 28.00 336.00
Vacation
Service Type Page 4 of 5 Form IN - 008
Worker ID
Income and Expense Statement PACSES Case Number.
EXPENSES (Fill in Appropriate Column)
continued WEEK MONTH YEAR
Gifts
legal Fees 150.00 1800.00
Charitable Contributions
Other. Child Support 255.94ibMkly 511.88 6654.44
Alimony Payments
OTHER:
ie,?% otal Exponses
Service Type Page 5 of 5 Form IN - 008
Worker ID
MINDY S. GOODMAN
NITORNEY SHAW
NO R'n110O1)c 1:11CliCI•lvnN
22 15 FOREST 1111.1 S 1)RIM • SU1,11i 95
I IARIUS111111 1, IA 1711
17171540-H7421 • 17171 540-874:1 FAX
June 6, 2002
E. Robert Elicker, II, Esquire
Office of Divorce Master
9 North Hanover Street
Carlisle, PA 17013
RE: Bradley v. Bradley
Divorce
Docket No. 99-6497
Dear Mr. Elicker:
Enclosed Is Plaintiffs Pretrial Statement in the above-referenced case. A copy of
said Pretrial has been sent to Johnna J. Kopecky, Esquire, counsel for the
Defendant.
In order to facilitate scheduling of the pre-hearing conference and hearing, I am
giving advance notice that while I will be working throughout the month of June, I
will be off during the months of July and August on maternity leave. I respectfully
request that the pre-hearing conference be scheduled prior to June 27, 2002 if at
all possible.
Thank you for your attention to this matter.
Very truly yours,
Mindy S. Goodman
MSG/bsg
Enclosure
cc: Johnna J. Kopecky, Esquire
Pam Bradley
LAW OFFICES
JAMES D. FLOWER
JOHN E. SLIKE
ROBERT C. SAIDIS
GEOFFREY S. SHUFF
JAMES D. FLOWER, JR.
CAROL J. LINDSAY
JOHNNA 1. KOPECKY
KARL M. LEDEBOHM
JOSEPH L. HITCHINGS
THOMAS E. FLOWER
FORREST N. TROUTMAN,11
SAIDIS, SHUFF, FLOWER & LINDSAY
A PROFESSIONAL CORPORATION
26 WEST HIGH STREET
CARLISLE, PENNSYLVANIA 17013
TELEP1ONE: (717) 243.6222 - FACSIMILE: (717) 243-6486
EMAIL: altome),@ssR-law.com
wwwssR-law.com
June G, 2002
E. Robert Elicker II, Esquire
Office of Divorce Master
9 North Hanover Street
Carlisle PA 17013
Dear Mr. Elickcr:
WEST SHOREOFFICE
2109 MARKET STREET
CAMP HILL, PA 17011
TELEPHONE: (717)737.3405
FACSIMILE: (717)737.3407
REPLY TO CARLISLE
Enclosed please find a copy of the Pre-Trial Statement, along with the Income and Expense
Statement.
If you have any questions or need additional information, please do not hesitate to contact
me.
Very truly yours,
SAIDIS, SHUFF, FLOWER & LINDSAY
JohnnaJopccky
JJK/ahg
Cc: Mindy S. Goodman, Esquire (with enclosures)
Ken Bradley
Enclosures- Pre-Trial Statcmcnt
Income & Expense Statement
.
PAMELA A. BRADLEY, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANt4
VS. :NO, 99.6497
KENNETH P. BRADLEY, : Civil Action - Law
Defendant : Divorce
ORDER APPOINTING MASTER
AND NOW, this day of , 2002,
is appointed Master with respect to the
following claims: divorce, equitable distribution, counsel fees, costs and
expenses.
BY THE COURT:
?Mj A A A A*"%,
( V1 r i P J.
F1lEDt? I??
Or Ti + r1 ! '^NOT.4RY a
02 API? -9 AM 11:05
cuIV-6*E •,?j'W COUM
PCNNSYNNNA
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.Sx„
PAMELA A. BRADLEY,
Plaintiff
VS.
KENNETH P. BRADLEY,
Defendant
.NO. 99.6497
: Civil Action - Law
: Divorce
MOTION FOR APPOINTMENT OF MASTER
PAMELA A. BRADLEY, Plaintiff, by and through her altornoy, Mindy S.
Goodman, Attorney at Law, moves the Court to appoint a Master with rospoct to
the following claims: divorce, equitable distribution, counsel foes, costs and
expenses, and in support of the motion states:
1. Discovery appears to be complete as to the claims for which the
appointment of a Master is requested.
2. The Plaintiff has appeared In the action by her attorney, Mindy S.
Goodman, Attorney at Law.
3. The statutory ground for divorce Is 3301(c) and (d).
4. The action is contested with respect to Ilia following claims: The
majority of marital property Is presently In Ilia possession and
control of Defendant, who has axprossad no desire to enter Into
settlement discussions with Ilia Plaintiff. Additionally, Plaintiff
seeks attorney's fees and expenses because of the dilatory tactics
used by Defendant to prevent this matter from coming to a
conclusion. Defendant's failure to respond to basic discovery
requests has forced Plaintiff to spend money filing for additional
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
attorney's fees and special relief from the court in the way of a
motion to compel production of documents.
5. The action does not involve complex issues of law or fact.
6. The hearing is expected to take one day.
Respectfully submitted,
Date: N • : -oz x
Mindy S. Goodman
Attorney at Law
ID No. 78407
2215 Forest Hills Drive - Suite 35
Harrisburg, PA 17112
(717) 540-8742
Attorney for Plaintiff
lk
t e
s
a
'3 a
CERTIFICATE OF SERVICE
I hereby certify that I served a true and correct copy of the Motion for
Appointment of Master upon Johnna J. Kopecky, Esquire by depositing same In
the United States Mail, first class, postage pre-paid on the 5th day of April, 2002,
addressed as follows:
Johnna J. Kopecky, Esquire
Saldis, Shuff, Flower & Lindsay
26 West High Street
Carlisle, PA 17013
Mindy S. Goodman
Attorney at Law
ID No. 78407
2215 Forest Hills Drive - Suite 35
Harrisburg, PA 17112
(717)540.8742
Attorney for Plaintiff
PAMELA A. BRADLEY,
Plaintiff
VS.
KENNETH P. BRADLEY,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99.6497
: Civil Action - Law
: Divorce
INVENTORY AND APPRAISEMENT
AND INCOME AND EXPENSE STATEMENT
OF PLAINTIFF. PAMELA A. BRADLEY
Plaintiff files the following Inventory and Appraisement of all property owned
or possessed by either party at the time this action was commenced and all property
transferred within the preceding three years.
Plaintiff verifies that the statements made In this Inventory and Appraisement
are true and correct. Plaintiff understands that false statements herein are made
subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification
to authorities.
0 ,
Pamela A. Bradley I
ASSETS OF PARTIES
Plaintiff marks on the list below those Items applicable to the case at bar and
itemizes the assets on the following pages.
X 1. Real Property
X 2. Motor Vehicles
3. Stocks, bonds, securities and options
4. Certificates of deposit
5. Checking accounts, cash
6. Savings accounts, money market and savings certificates
7. Contents of Safe Deposit Boxes
8. Trusts
X 9. Life Insurance policies (Indicated face value, cash value and
current beneficiaries)
10. Annuities
11. Gifts
12. Inheritances
13. Patents, copyrights, inventions and royalties
14. Personal property outside the home
15. Businesses (list all owners, including percentage of ownership,
and officer/director positions held by a party with company)
16. Employment termination benefits - - severance pay, Workman's
Compensation claim/award
17. Profit sharing plan
X 18. Pension plans (Indicate employee contribution and date plan
vests)
2
X 19. Retirement plans, Individual Retirement Accounts
20. Disability payments
21. Litigation claims (matured and unmatured)
X 22. MilitaryN.A. benefits
23. Education benefits
X 24. Debts due, Including loans, mortgages held
X 25. Household furnishings and personalty (Include a total category
and attach Itemized list of distribution of such assets In
dispute)
30. Other
ASSETS
Plaintiff lists all marital property in which either or both spouses have a legal
or equitable interest individually or with any other person as of the date this action
was commenced;
Item Description Names of Date of Current
Number o r ert all Owners c uisi ion Value
1. Marital Residence Joint During Marriage $121,000
Amount of Lien Date/Holder of Lien Current Eouity
$88,260.00 Wells Fargo Property in Husband's
possession; equity is
$32,740. Wife claims
rental value as
Husband has had
exclusive possession
since separation in
October of 1999.
3
Item Description
Number of Property
2. Real Property
Amount of Lien
N/A
Names of Date of
all Owners Acquisition
Joint 1990
Date/Holder of Lien
Current
Value
$15,000
Current Eauily
Property sold in 2000,
parties divided
proceeds 50/50
Item Description Names of Date of Current
Number of Property all Owners Acquisition Value
3. 1994 Nissan Pathfinder Joint Marital $8,000
Amount of Lien Date/Holder of Lien Current Equity & Ownership
Unencumbered N/A $8,000 - Vehicle
destroyed, Insurance
paid $8,000 to Wife
Item Description' Names of Date of Current
umber of Prooertv all Owners Acquisition value
4. 1988 Nissan Wagon Husband Marital $2,000
Amount of Lien Date/Holder of Lien Current Equity & Ownership
Unencumbered N/A $2,000. Vehicle in
Husband's exclusive
possession.
Item Description Names of Date of Current
umber of Property all Owners Acquisition Value
5. 1990 Yamaha Cycle Husband Marital $750
Amount of Lien Date/Holder of Lien Current Equity & Ownership
Unencumbered N/A $750- Husband
4
Item Description
Number of Prooert
v
6. Hot Tub
Amount of Lien
$7,944.70
Names of Date of Current
all Owners Acquisition Value
Joint Marital $4,000
Date/Holder of Lien Current Equity & Ownership
Bob's In Towne Spas - $6,944.70 Husband possession
Discover - $1000.00
Item Description
Number of Property
7. Washer/dryer set
Amount of Lien
Unencumbered
Names of
all Owners
Joint
Date/Holder of Lien
N/A
Date of Current
Acquisition Value
Marital $200
Current Equity & Ownership
$200 - Wife
Item Description
Number of Prooertv
8. Kitchen furniture
Amount of Lien
Unencumbered
Names of
all Owners
Joint
Date/Holder of Lien
N/A
Date of Current
Acquisition Value
Marital $100
Current Equity & Ownership
$100 - Wife
Item Description
Number of Property
9. Microwave Oven
Amount of Lien
Unencumbered
Names of
all Owners
Joint
Date/Holder of Lien
N/A
Dale of Current
Acquisition Value
Marital $25
Current E quity & Ownership
$25 - Wife
5
Item Description Names of Date of Current
Number of Propert y all Owners Acaulsillon Value
10. Computer Joint Marital $150
Amount of Lien Dale/Holder of Lien Current E guity & Ownership
Unencumbered N/A $150 - Wife
Item Description Names of Date of Current
Number of Property all Owners Acquisition Value
11. Video Camera Joint Marital $100
Amount of Lien Date/Holder of Lien Current E guity & Ownership
N/A N/A $100- Husband
Item Description Names of Date of Current
Number of Property all Owners Acquisition Value
12. Dishwasher Joint Marital $100
Amount of Lien Dale/Holder of Lien Current E guity & Ownership
N/A N/A $100- Husband
Item Description Names of Date of Current
Number of Property all Owners Acquisition Value
13. Refrigerator Joint Marital $600
Amount of Lien Date/Holder of Lien Current E auity & Ownership
N/A N/A $600 - Husband
6
Item Description Names of Date of Current
umber of Propert y all Owners Acquisition Value
14. Freezer Chest Joint Marital $50
Amount of Lien Date/Holder of Lien Current Eauity & Ownership
Unencumbered N/A $50- Husband
Item Description Names of Date of Current
Number of Property all Owners Acouisition Value
15. Carpet Cleaner Joint Marital $100
Amount of Lien Date/Holder of Lien Current Equity & Ownership
Unencumbered N/A $100- Husband
Item Description Names of Date of Current
Number of Prooertv all Owners Acquisition Value
16. Snowblower Joint Marital $150
Amount of Lien Date/Holder of Lien Current Equity & Ownership
Unencumbered N/A $150 - Wife
Item Description
Number of Propert
y
17. Living Room Furn.
Amount of Lien
Unencumbered
Names of
all Owners
Joint
Date/Holder of Lien
N/A
Date of Current
c uisition Value
Marital $500
Current Eauity & Ownership
$500- Husband
7
Item Description Names of Date of Current
Number o Pro ertall Owners Acquisition Value
18. Bedroom Furn. Joint Marital $200
Amount of Lien Date/Holder of Lien Current Equity & Ownership
Unencumbered N/A $200- Husband
Item Description Names of Date of Current
u ber of Property Owners c isition Value
19. Waterbed Joint Marital $100
Amount of Lien Date/Holder of Lien Current Equity & Ownership
Unencumbered N/A $100- Husband
Item Description
umber of Property
20. Misc. Tools
Amount of Lien
Unencumbered
Names of
all Owners
Joint
Date/Holder of Lien
N/A
Date of Current
Acquisition Value
Marital $600
Current Eauity & Ownership
$600- Husband
Item Description
Number of Propert
y
21. Two Television Sets
Amount of Lien
Unencumbered
Names of
all Owners
Joint
Date/Holder of Lien
N/A
Date of Current
Acouisition Value
Marital $100
Current Equity & Ownership
$50- Husband
$50 - Wife
8
Item Description Names of Date of Current
Number of Property Owners c ulsition Value
22. Met Life Life Ins. Husband Marital $19,141.56
Amount of Lien Date/Holder of Lien Current Equity & Ownership
N/A N/A $19,141.56 - Husband
Item Description Names of Date of Current
Number of Property all Owners c ulsition Value
23. State Retirement Husband Marital $10,000
Amount of Lien Date/Holder of Lien Current Eauity & Ownership
N/A N/A $10,000 - Husband
Item Description Names of Date of Current
Number of Prooert v all Owners Acquisition Value
24. Military Retirement Husband Partially Marital Pays $1300
monthly
Amount of Lien Date/Holder of Lien Current Equity & Ownership
N/A N/A Retained by Husband
ra?.,4
r-pya'?,y
l
LIABILITIES OF PARTIES
Plaintiff marks on the list below those items applicable to the case at bar and
itemizes the liabilities on the following pages.
SECURED
X 1. Mortgages
2. Judgments
3. Liens
4. Other secured liabilities
UNSECURED
X S. Credit card balances
X 6. Purchases
X 7. Loan payments
8. Notes payable
9. Other unsecured liabilities
CONTINGENT OR DEFERRED
10. Contracts or Agreements
11. Promissory notes
12. Lawsuits
13. Options
14. Taxes
15. Other contingent or deferred liabilities
10
3? a
rnY
LIABILITIES
Plaintiff lists all liabilities of either c
of the date the action was commenced.
Item Description Name of
Number of Debt Creditors
1. Mortgage Wells Fargo
When Debt Incurred
Marital
Item Description Name of
Number of Debt Creditors
2. Hot Tub Debt Bob's Spas/Discover
When Debt Incurred
Marital
r both spouses along or with any person as
Name of Outstanding
Debtors Balance
Joint $88,260
Liability as of Sep.
$90,000
Name of Outstanding
Debtors Balance
Joint $3,500
Liability as of Sep .
$7,944.70
Item Description Name of Name of Outstanding
Number of Debt Creditors Debtors Balance
3. Roof and Deck C-B-W Schools Joint $1000
Fed Credit Union
When Debt Incurred Liability as of Sep.
Marital $5,893.04
FINANCIAL STATEMENT OF PLAINTIFF
MONTHLY EXPENSES
Shel er:
a. Mortgage or Rent ............... $ 366.85
b. Sewer/Water .................... $ 10
42
C. .
Electric ....................... $ .
83
52
d. ..
Heat/Gas ..................... $ .
62
00
e. ...
Telephone ....................... $ .
31
17
f. Cellular Phone .................... $ .
63
63
g. Cable ....................... $ .
24
26
h. ....
Renter's Insurance ................. $ .
17.90
Transportation:
a. Auto Loan payments ............... $ 138.00
b. Auto Insurance .................... $ 100.00
C. Auto Expense ..................... $ 75.00
d. Travel Expenses ................... $ 50.00
Medical Care/Insurances:
a. Life Insurance .................... $ 67.46
b. Medical Insurance ................. $ -----
lothin :
a. Self ...................... ... ... . $ 100.00
b. Gifts, etc .. ...................... .$ 50.00
C. Dry Cleaning ..................... $ 35.00
Food:
a. Self.. ................. $ 300.00
b. Household Supplies ................ $ 250.00
12
P'e
Loans/Notes:
a. (list charge cards) . ............$ 315.00
Discover-$80.00
VISA - $160.00
Sears Mastercard - $75.00
b. Hot tub loan ...................... $ 7,944.70
C. Roof and Deck loan ................ $ 5,893.04
Miscellaneous:
a. Entertainment .....................$ 250.00
b. Barber/Beautician ..................$ 30.00
Child Care:
a. Court-Ordered Support ............. $ N/A
MONTHLY INCOME
Employer's Name: Commonwealth of Pennsylvania
Employer's Address:
Employment Income:
Gross ............................$
Net ............................. $
Dated: 4/0.4 Pamela
?J
13 3 monthly
9 6 o. jimonthly
113
A. Bradley, PlainB
13
VERIFICATION
verify that the statements made in Plaintiffs Inventory and Appralsement
and Income and Expense Statement are true and correct. I understand that false
statements and Incomplete production of documents herein are made subject to
the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to
authorities.
Pamela A. Bradley
ix
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LAW OITICI:S
SAIDIS, SHUFF, FLOWER & LINDSAY
A PROFESSIONAL CORPORATION
26 WI 8T HIGI 15T'REI'r
JAMIS D. FLOWER CARLISLE, PENNSYLVANIA 17013
JOHN E. SLIKE TELEPI LONE: (717) 243.6222- FACSINIII.E: (717) 243.6486
ROBERT C. SAIDIS EMAIL: otlornepOlssn-law.com
GEOFFREY S. SHUFF www.ssR-Lnv.com
JAMES D. FLOWER, JR.
CAROL J. LINDSAY
JOHNNA J. KOPECKY
KARL M. LEDEBOHM
JOSEPH L. HITCHINGS
THOMAS E. FLOWER
FORREST N. TROUTMAN, II
April 26, 2002
E. Robert Elicker, II Esquire
Office of Divorce Master
9 North Hanover Street
Carlisle PA 17013
Dear Mr. Elicker:
WEST_ SHORE OFFICE:
2109 MARKET STREET
CAMP I TILL, PA 17011
TELEPIIONE: (717)737.3405
FACSIMILE: (717)737.3407
REPLY TO CARLISLE
Enclosed is a copy of the Defendant's Certification that Discovery is complete. I
believe that you have received Plaintiffs Certification from Mindy Goodman,
Esquire, and a Pre-Hearing Conference can now be scheduled in this matter.
Very truly yours,
SAIDIS, SHUFF, FLOWER & LINDSAY
Jo 7a:K6'ecky
PAMELA A. BRADLEY, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99 - 6497 CIVIL
KENNETH P. BRADLEY,
Defendant IN DIVORCE
TO: Mindy S. Goodman Attorney for Plaintiff
Johnna J. Kopecky Attorney for Defendant
DATE: Tuesday, April 16, 2002
CERTIFICATION
certify that discovery iS complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLE^^3;
(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.
e a?w
a
N,
.•
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
4L- ZS-OZ ?..
DATE CO L F R LA i )
CO EL FO DEFENDANT (X
Z.
NOTE: PRETRIAL DIRECTIVES WILL NOT 3E ISSUED FOR THE
.!LING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFI'aD THAT DISCOVERY IS COMPLETE, OR OTHERWT_SE
AT THE MASTER'S DISCRETION.
AFTER RECEIVI G THIS DOCL^1E:1T FROM 30?H COUNSEL
OR A ?ARTY TO THE ACTION, I: NOT REPRESENTED BY
COUNSEL, IWICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FT-L_ZNG OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, I. BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIF., THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATE24ENT5 WILL BE ISSUED iMMEDIA?ELY.
THE CERTIFICATION DOC?4jME?PI SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN 740 (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
MINDY S. GOODMAN
/A17 1INEY AT LAW
NO MIWHIU011:10; CEW114
4! 15 FORE 1' 1111.1 ti UTAM., • sul l V YS
1IAIU(ISBUIM, IDA 17112
171 71 :'•40-N742 • (717) S40 M74:1 PAX
April 23, 2002
E. Robert Elicker, II, Esquire
Office of Divorce Master
9 North Hanover Street
Carlisle, PA 17013
RE: Bradley v. Bradley
Divorce
Docket No. 99-6497
Dear Mr. Elicker:
Enclosed is a copy of Plaintiffs Certification that Discovery is complete. The
original has been sent to the courthouse for filing and a copy has been sent to
opposing counsel, Johnna J. Kopecky, Attorney for Defendant.
Thank you for your attention to this matter.
Very truly yours,
Mindy S. Goodman
MSG/bsg
Enclosure
cc: Johnna J. Kopecky, Esquire
Pam Bradley
PAMELA A. BRADLEY,
Plaintiff
VS.
KENNETH P. BRADLEY,
Defendant
TO: Mindy S. Goodman
Johnna J. Kopecky
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 6497 CIVIL
IN DIVORCE
, Attorney for Plaintiff
, Attorney for Defendant
DATE: Tuesday, April 16, 2002
/ CERTIFICATION
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.
q Z 3 22- V\l?.. 70-..?
DATE COUNSEL FOR PLAINTIFF d>C)
COUNSEL FOR DEFENDANT ( )
NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
AVAL`IUI J. VUUUIVIHIV
ATTORNEYATLAW
NOR771WOODC x2rcum
2215 POREST =3 DRIVE • SUMS 55
HARRISBURG, PA 17112
(717) SW 9742
PAMELA A. BRADLEY,
Plaintiff
vs.
KENNETH P. BRADLEY,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99.6497
Civil Action - Law
Divorce
ORDER APPOINTING MASTER
Cc? AND NOW, this -- day of otic.Q , 2002,
c_otC{4,? ?oru Is appointed Master with respect to the
following claims: divorce, equitable distribution, counsel fees, costs and
expenses.
BY THE COURT:
PAMELA A. BRADLEY,
Plaintiff
VS.
KENNETH P. BRADLEY,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 99-6497 CIVIL TERM
CIVIL ACTION - LAW
CUSTODY
AND NOW, this 01RD
r a? day
of
F"?ra,,
, 2000,
upon review of the Conciliator's Report, it appearing that the
parties have agreed to the terms and provisions of this Interim
Order which was dictated in their presence and approved by them and
their counsel, it is hereby ordered and directed as follows:
1. The parties have agreed to participate in a custody
evaluation to be performed by Dr. Arnold T. Shienvold. Both
parties agree that they will cooperate in getting the evaluation
scheduled and completed. Both parties agree that they shall attend
all sessions as recommended by the custody evaluator. The custody
evaluator is to provide a report to both parties, their counsel„
and the conciliator. The parties shall evenly share in the cost of,
this evaluation.
2. The parties shall reconvene for another custody
conciliation before Michael L. Hangs, 8squire, on
?? , 2000, at Id. m.
3. Pending the completion of the evaluation, the parties
agree to the following interim custodial schedule:
A. The parties shall share legal custody of the minor
child, Jared Neil Bradley, d.o.b. June 3, 1992.
B. Father shall have periods of partial custody and
visitation on alternating weekends from Friday
after school until Sunday at 7:00 p.m. This
alternating weekend schedule shall commence
February 41 2000.
C. Father shall have Saturday morning from 7:30 a.m.
until Saturday afternoon at 1:00 p.m.
D. Father shall have every Wednesday from after school
until Thursday morning at which time he shall drop
the child back at school or the appropriate daycare
provider.
E. Father shall have every Monday evening from after
school until 8:00 p.m. This Monday evening shall
continue through March 6t" unless the parties
otherwise agree.
4. Mother shall have the child at all other times.
5. The parties understand that this is an Interim Order and
that it does not prejudice either one of them to raise any other
issues that they otherwise need to raise if this matter proceeds to
a full custody hearing.
BY THE COURT,
Mindy S. Goodman, Esquire
Attorney for Plaintiff
Johnna Deily, Esquire
Attorney for Defendant
mlb
,<A- -/9%/' J.
02 -C2 y-00
IRK9
I=
I?
PAMELA A. BRADLEY,
Plaintiff
VS.
KENNETH P. BRADLEY,
Defendant
JUDGE PREVIOUSLY ASSIGNED: None.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 99-6497 CIVIL TERM
CIVIL ACTION - LAW
CUSTODY
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the
following report:
1. The pertinent information concerning the child who is the
subject of this litigation is as follows:
k0
Jared Neil Bradley June 3, 1992
CURRENTLY IN
CUSTODY OF
Plaintiff
2. A Conciliation Conference was held on January 27, 2000,
and the following individuals were present: the Plaintiff and her
attorney, Mindy S. Goodman, Esquire; the Defendant appeared with
his attorney, Johnna Deily, Esquire.
3. Items resolved by agreement: See attached Order.
4. Issues yet to be resolved: See attached Order.
5. The Plaintiff's position on custody is as follows: See
attached Order.
6. The Defendant's position on custody is as follows: See
attached Order.
7. Need for separate counsel to represent child: Neither
party requested.
8. Need for independent psychological evaluation or
counseling: The parties have agreed to participate in a custody
evaluation to be performed by Dr. Arnold T. Shienvold. Both
parties agree that they will cooperate in getting the evaluation
scheduled and completed. Both parties agree that they shall attend
all sessions as recommended by the custody evaluator. The custody
evaluator is to provide a report to both parties, their counsel,
and the conciliator. The parties shall evenly share in the cost of
this evaluation.
Date: February/70 2000 VJU 2 4
Michael L. Bangs
Custody Conciliat
FEB LL 2000
I/
PAMELA A. BRADLEY, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 99-6497
KENNETH P. BRADLEY, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
ORDER
AND NOW, this 19' day of ,y„ ,./ , 2004, the
attached Stipulation and Agreement dated March 15, 2004, Is approved and is
Incorporated, but not merged, Into this Order of Court.
O\-0S
r
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1..
l
s-
;? r
2
PAMELA A. BRADLEY,
Plaintiff
V.
KENNETH P. BRADLEY,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6497
: CIVIL ACTION - LAW
: IN DIVORCE
STIPULATION FOR THE ENTRY OF "DOMESTIC RELATIONS ORDER"
AND NOW, this fie- " ` day of /Y1 c , c L , 2001,
PAMELA A. BRADLEY, Plaintiff, and KENNETH P. BRADLEY, Defendant, do
hereby Agree and Stipulate as follows:
1. The Defendant, KENNETH P. BRADLEY, (hereinafter referred to
as "Defendant Member") is a member of the Commonwealth of
Pennsylvania, State Employees' Retirement System (hereinafter
referred to as "SERS").
2. SERS, as a creature of stale, is controlled by the State Employees'
Retirement Code, 71 Pa. C.S.§§5101-5956 (hereinafter referred to
as "Retirement Code").
3. Defendant Member's date of birth is August 9, 1954, and his Social
Security Number is 047-48.3360.
4. The Plaintiff, PAMELA A. BRADLEY, (hereinafter referred to as
"Alternate Payee") Is the former spouse of Defendant Member.
Alternate Payee is also a member of SERS and her date of birth is
May 25, 1964 and her Social Security Number is 163.60-9331.
2
5
6.
Defendant Member's last known mailing address:
Kenneth P. Bradley
821 Pheasant Drive North
Carlisle, PA 17013
Alternate Payee's current mailing address is:
Pamela A. Bradley
16 Denmar Drive
Holtwood, PA 17532
It is the responsibility of the Alternate Payee to keep a current mailing
address on file with SERS at all limes.
7. Alternate Payee's share of the Defendant Member's retirement
benefit is five thousand ($5,000.00) dollars plus statutory interest
(presently 4%) from the date of divorce, October 29, 2002, to the
date of member's actual retirement.
8. Defendant Member's retirement benefit is defined as all monies
paid to or on behalf of Member of SERS, including any lump sum
withdrawals or scheduled or ad hoc Increases, but excluding the
disability portion of any disability annuities paid to Member by
SERS as a result of a disability which occurs before the Member's
marriage to Alternate Payee or after the date of the Member and
Alternate Payee's final separation. Member's retirement benefit
does not include any deferred compensation benefits paid to
Defendant Member by SERS. The equitable distribution portion of
the marital property component of Defendant Member's retirement
3
benefit, as set forth in Paragraph Seven (7), shall be payable to
Alternate Payee and shall commence as soon as administratively
feasible on or about the date the Defendant Member actually enters
pay status and SERS approves a Domestic Relations Order
Incorporating the Stipulation and Agreement, whichever is later.
9. Defendant Member hereby nominates Alternate Payee as an
Irrevocable beneficiary to the extent of Alternate Payee's equitable
distribution portion of Defendant Member's retirement benefit for
any death benefits payable by SERS. This nomination shall
become effective upon approval by the Secretary of the Retirement
Board, or his authorized representative, of any Domestic Relations
Order incorporating this Stipulation and Agreement. The balance of
any death benefit remaining after the allocation of Alternate
Payee's equitable distribution portion ("Balance") shall be paid to
the beneficiaries named by Defendant Member on the last
Nomination of Beneficiaries Form filed with the Retirement Board
prior to Defendant Member's death.
a. If the last Nomination of Beneficiaries Form flied by
Defendant Member prior to the Defendant Member's death
(1) predates any approved Domestic Relations Order
incorporating this Stipulation and Agreement, and (ii) names
an Alternate Payee as beneficiary, then: (1) the terms of the
4
Domestic Relations Order shall alone govern Alternate
Payee's share of any death benefit, and (2) for purposes of
paying the Balance via the last Nomination of Beneficiaries
Form filed with the Retirement Board prior to Defendant
Member's death, Alternate Payee shall be treated as if
Alternate Payee predeceased Defendant Member. No
portion of the Balance shall be payable to Alternate Payee's
estate.
b. In addition, Defendant Member shall execute and deliver to
Alternate Payee an authorization, in a form acceptable to
SERS, which will authorize SERS to release to Alternate
Payee all relevant information concerning Defendant
Member's retirement account. Alternate Payee shall deliver
the authorization to SERS which will allow the Alternate
Payee to check that she has been and continues to be
properly nominated under this Paragraph.
10. The term and amounts of Defendant Member's retirement benefits
payable to the Alternate Payee after SERS approves a Domestic
Relations Order incorporating this Stipulation and Agreement is
dependent upon which option(s) is (are) selected by Defendant
Member upon retirement. Defendant Member and Alternate Payee
expressly agree that Defendant Member, at the time of his
5
retirement, must elect to withdraw an Option 4 lump sum amount at
least equal to the amount described in Paragraph 7 herein. This
amount is to be paid to the Alternate Payee as her equitable
distribution portion and no further payments are to be made to the
Alternate Payee. The Defendant Member may select any
retirement option offered by SERS for his monthly annuity.
11. Alternate Payee may not exercise any right, privilege or option
offered by SERS, SERS shall Issue individual tax forms to
Defendant Member and Alternate Payee for amounts paid to each.
12. In the event of the death of Alternate Payee prior to receipt of all of
her payments payable to her from SERS under this Order, any
death benefit or retirement benefit payable to Alternate Payee by
SERS shall be paid to Alternate Payee's Estate to the extent of
Alternate Payee's equitable distribution portion of Defendant
Member's retirement benefit as set forth in Paragraphs Seven (7)
through Nine (9).
13. In no event shall Alternate Payee have greater benefits or rights
other than those that are available to Defendant Member. Alternate
Payee Is not entitled to any benefit not otherwise provided by
SERS. The Alternate Payee is only entitled to the specific benefits
offered by SERS as provided in this Order. All other rights,
6
14.
Privileges and options offered by SERS not granted to Alternate
Payee by this Order are preserved for Defendant Member.
It Is specifically intended and agreed by the parties hereto that this
Order:
a. Does not require SERS to provide any type of benefit, or any
option, not otherwise provided under the Retirement Code;
b. Does not require SERS to provide increased benefits
(determined on the basis of actuarial value) unless Increased
benefits are paid to Defendant Member based upon cost of
living or increases based on other than actuarial values.
15.
16.
The parties intend and agree that the terms of this Stipulation and
Agreement shall be approved, adopted and entered as a Domestic
Relations Order.
The Court of Common Pleas of Cumberland County, Pennsylvania,
shall retain jurisdiction to amend any Domestic Relations Order
Incorporating this Stipulation and Agreement, but only for the
purpose of establishing it or maintaining it as a Domestic Relations
Order; provided, however, that no such amendment shall require I
61
SERS to provide any type or form of benefit, or any option not
4
otherwise provided by SERS, and further provided that no such c.
,,. .
amendment or right of the Court to so amend will invalidate this
existing Order.
17. Upon entry as a Domestic Relations Order, a certified copy of the
Domestic Relations Order and this Stipulation and Agreement and
any attendant documents shall be served upon SERS Immediately.
The Domestic Relations Order shall take effect immediately upon
SERS approval and SERS approval of any attendant documents
and then shall remain in effect until further Order of Court.
WHEREFORE, the parties, Intending to be legally bound by the terms of
this Stipulation and Agreement, do hereunto place their hands and seals.
Mindy S. Good an Pamela A. Bradley
Attorney for Plaintiff/Alternate Payee Plaintiff/Alternate Payee
Carol J. Llgdsa ? \ Kenneth P. Bradley
Attorneyf6r D endant/Member Defendant/Member
8
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