HomeMy WebLinkAbout99-06877v
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IN THE COURT OF COMMON PLEAS
OFCUMBERLAND COUNTY
STATE OF PENNA.
CHRISTOPHER M. BeLIEU,
Plaintiff No. 99-6877
VERSUS
FIONA J. BeLIEU,
Defendant
DECREE IN
DIVORCE
AND NOW, IT IS ORDERED AND
DECREED THAT CHRISTOPHER M. BeLIEU, PLAINTIFF,
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AND FIONA J. BeLIEU,
. DEFENDANT,
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I ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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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; mJ?V'?.SL
THE AGREEMENT DATED MAY 7, 2003, IS INCORPORATED BUT NOT MERGED AND
MADE A PART OF THE RECORD.
BY THE COURT:
ATTEST; J.
/ PROTHONOTARY
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?,.et.-?
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A G R E E M E N T
THIS AGREEMENT, made this --f- day of i" 2003,
by and between FIONA J. BeLIEU, of Cumberland Count , Pennsylvania,
(hereinafter referred to as "Wife"), and CHRISTOPHER M. BeLIEU, of
Cumberland County, Pennsylvania, (hereinafter referred to as "Hus-
band") ;
W I T N E S S E T H:
WHEREAS, Husband and Wife were lawfully married on August 25,
1984, and
WHEREAS, two children have been born of this marriage, RACHEL
CATHERINE BeLIEU, born on March 15, 1988, and MICHAEL THOMAS BeLIEU,
born on May 25, 1991; and
WHEREAS, diverse unhappy differences, disputes and difficulties
have arisen between the parties and it is the intention of Wife and
Husband to live separate and apart for the rest of their natural
lives, and the parties hereto are desirous of settling fully and
finally their respective financial and property rights and obligations
as between each other including, without limitation by specification:
the settling of all matters between them relating to the ownership and
equitable distribution of real and personal property; the settling of
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all matters between them ..elating to the pasr., present and future
support, alimony and/or maintenance of wife by Husband or of Husband
by Wife; the settling of all matters between them relating to the
past, present and future support and/or maintenance of the children;
the implementation of custody/visitation arrangements for the minor
children of the parties; and in general, the settling of any and all
claims and possible claims by one against the other or against their
respective estates.
NOW THEREFORE, in consideration of the premises and of the mutual
promises, covenants and undertakings hereinafter set forth and for
other good and valuable consideration, receipt of which is hereby
acknowledged by each of the parties hereto, Fife and Husband, each
intending to be legally bound hereby, covenant and agree as follows:
1. Disclosure of Assets. Each party asserts that he or she has
made a full and fair disclosure of all of the real and personal
property of any nature whatsoever belonging in any way to each of them
of all debts and encumbrances incurred in any manner whatsoever by
each of them, of all sources and amounts of income received or receiv-
able by each party, and of every other fact relating in any way to the
subject matter of this agreemenn. These disclosures are part of the
consideration made by each party for entering into this agreement.
2. Advice of Counsel. Each party has been represented by an
independent attorney, who was selected by the party whom he or she
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represents, in the negotiation and preparation of this agreement.
This agreement has been fully explained to each party by that party's
attorney. Each party has carefully read ::his agreement and is com-
pletely aware, not only of its contents, but also of its legal effect.
3. Lawfulness of Separation. It shall be lawful for each party
at all times hereafter to live separate and apart from the other party
at such place as he or she may from time to time choose or deem fit.
The foregoing provisions shall not be taken as an admission on the
part of either party of the lawfulness or unlawfulness of the causes
leading to their living apart.
n. Freedom from Interference. Each party shall be free from
interference, authority, and contact by the other, as fully as if he
or she were single and unmarried except as may be necessary to carry
out the provisions of this agreement. Neither party shall molest the
other or attempt to endeavor to molest the other, nor compel the other
to cohabit with the other, or in any way harass or malign the other,
nor in any way interfere with the peaceful existence, separate and
apart from the other.
5. Release of Claims. Wife and Husband each do hereby mutually
remise, release, quit-claim and forever discharge the other and the
estate of such other, for all time to come, and for all. purposes
whatsoever, of and from any and all rights, titles and interests, or
claims in or against the property (including income and gain from
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property hereafter acCrlli.n(4) OL -he other or a-jiLnst the (-State of
such other, of whatever nature and wheresoever situate, which she or
he now has or at any time hereafter may have, against Such Other, the
estate of such other or any part thereof, whether arising out of any
former acts, contracts, engagements or liabilities of such other or by
way of dower or curcesy, or ciaims in the nature of dower or curtesy
of widow's or widower's rights, family exemption or similar allowance,
or under the intestate laws, or the right co take against the spouse's
will; or the right to treat a lifetime conveyance by the other as
testamentary, or all other rights of a surviving spouse to participate
in a deceased spouse's estate, whether arising under the laws of (a)
Pennsylvania, (b) any state, co:mnon•::ealth or territory of the United
States, or (c) any other country, or any rights which Wife may have or
at any time hereafter have for past, present or future support or
maintenance, alimony, alimony pendente lite, counsel fee.3, costs or
expenses, whether arising as a result of the marital relation or
otherwise, except, and only except, all rights and a^reements and
obligations of whatsoever nature arising or which may arise under this
agreement or for the breach of any thereof. It is the intention of
Wife and Husband to give to each other by the execution of this
agreement a full, complete and general release with respect to any and
all property of any kind or nature, real, personal or mixed, which the
other now owns or may hereafter acquire, except and only except all
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rights and agreements and obligations of whatsoever nature arising or
which may arise under this agreement or for the breach of any thereof,
subject, however, to the implementation and satisfaction of the
conditions precedent as set forth herein above.
6. Warranty as to Future Obligations. Each party represents
that they have not contracted any debt or liability for the other for
which the estate of the other party may be responsible or liable, and
that except only for the rights arising out of this agreement, neither
party will hereafter incur any liability whatsoever for which the
other party or the estate of the other party, will be liable. Each
party agrees to indemnify or hold the other party harmless from and
against all future obligations of every kind incurred by them, includ-
ing those for necessities.
7. Personal Property. Wife and Husband do hereby acknowledge
that they have heretofore divided the marital property including, but
without limitation, jewelry, clothes, furniture and other personalty
and hereafter Wife agrees that all of the property in the possession
of Husband shall be the sole and separate property of Husband; and,
Husband agrees that all property in the possession of Wife shall be
the sole and separate property of Wife. Each of the parties does
hereby specifically waive, release, renounce and forever abandon
whatever claims, if any, she or he may have with respect to any of the
above items which are the sole and separate property of the other.
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8. Automobile to Husband. Husband currentl
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ves a company
vehicle. He possesses no lena.1 in e•e5t
_n r._S car..
9. Automobile to Wife. The 71ife shall be the sole owner, free
and clear from any claim on the -part of the Husband, of the 1996
Chrysler Minivan. Husband shall deliver executed certificate of
title, sales and use tar. form and any other documents necessary to
convey title within ten days of request by Wife after Wife has paid in
full the current motor vehicle loan for said automobile.
10. Property Not Provided For. The parties hereto agree that
they have, by the terms of this agreement, settled, to their mutual
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satisfaction, all rights that either may have in their property,
whether owned by them jointly or separately, real and personal, and
wheresoever situated. Any property not specifically provided for in
this agreement, which the Husband or 'life owns or has the right to
control or possess, shall be and remain his or her property, free and
1! clear from any claim on the part of the other.
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11. Real Estate. Prior to the final. execution of this
agreement, the parties sold the _Dal property os.,ned by them at 55
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Hickory Road, Carlisle, Cumberland County, Pennsylvania. Both parties
are satisfied that the proceeds were divided fairly and that this
finalizes their agreement respect CO the division of the dSSetS
and equity acquired in marital residence.
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12, Waiver of Alimony. The parties herein ackno:eledge that by
this agreement they have each respectively secured and maintained a
substantial and adequate fund with which to provide themselves suffi-
cient financial resources to provide for their comfort, maintenance
and support in the station of life in which they are accustomed. Wife
and Husband do hereby waive, release and give up any rights they may
respectively have against the other for alimony, support, alimony
pendente lite or maintenance. It shall be from the date of this
agreement the sole responsibility of each of the respective parties to
sustain themselves without seeking any support from the other party.
13. Pensions and Retirement. Husband agrees to transfer one-
half interest of his Air Force pension to Wife. Husband and wife
shall cooperate with each other to provide the Air Force with such
documentation as is necessary for such allocation of appro-ximately
one-half per month to Wife. It is the understanding of the parties
that the pension division will be prepared, executed and monitored by
the United States Air Force with no cost to either party. Husband and
his attorney agree to take responsibility to ensure that this
provision is accomplished.
Husband waives any and all claim, right, or interest which he may
have in any pension of 6life.
14. Medical Insurance. Wife agrees to provide medical insurance
for the children with a policy cOntain'_.n.g minimum provisions as would
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be covered by a standard Blue Cross - Blue Shield policy so long as it
is covered by her employer with no cost to her. Should the need arise
to revisit the health insurance, both parties agree to abide by the
Domestic Relations order regarding responsibility and the percentage
of obligation for any uninsured or extraordinary medical expenses for
the children. Husband shall be solely responsible for all orthodontic
expenses for MICHAEL THOMAS BeLIEU. Wife shall be solely responsible
for all orthodontic expenses for RACHEL CATHERINE BeLIEU. All other
expenses, other than orthodontia shall be treated by as the Office of
Domestic Relations determines by the percentage allocation.
15. Consultation. Husband and ',,life shall have shared legal
custody of the children and agree to confer with each other on all
matters of importance relating to the children's health and to keep
one another informed of the progress of the children's education and
social adjustments.
16. Dependency Exemptions. ;life shall be entitled to claim all
dependency exemptions for both RACHEL CATHERINE BeLIEU and MICHAEL
THOMAS BeLIEU.
17. Custody. Husband and Wife shall share legal custody of
their minor children. :'Life small have primary physical custody of the
minor children subject to the Husband's liberal custodial and
visitation rights. Either party shall be permitted to visit with the
children as often as he or she and the children may desire and
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consider to be in t"hei.r best interests all e!1 i.n the custody of the
other party. Tt is the intention of the oarties to remain as flexible
as possible so as to serve the best interests of the children.
The parties agree to accommodate the annual extended
vacation that the children enjoy :ith their maternal grandparents and
relatives living in England.
The parties agree that neither may relocate the children
outside of central Pennsylvania ::ithout the express consent of the
other or by Order of Court. it is the intention of both parties to
share equally in the decision making processes of raising their
children.
18. Life Insurance Policy. The parties agree to take out life
insurance policies naming each other as the sole beneficiary and the
children as contingent beneficiaries. Wife agrees that she will
purchase a $50,000 life insurance policy naming Husband as the sole
beneficiary. Husband agrees teat he purchase a $100,000 life
insurance policy naming Wife as the sole beneficiary. Each party
agrees to keep the policies current and provide receipts of all paid
premiums to each other upon demand by either party. Both parties
further agree to elect the other party to have equal notice rights so
that the policy shall not laps-. .._thout laast 30 days prior notice
from the insurance company to the primary and the contingent
beneficiaries
The purpose of thew policies is to ensure that the
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children will be properly taken care of in the event of either of the
parent's death.
19. Payment of Attorney Fees. each party of this agreement
hereby agrees that each of them will be solely responsible for the
full payment of all attorney's fees and other costs heretofore and
hereafter incurred, respectively, by each of them in connection with
the negotiation, preparation, and execution of this agreement, and in
connection with any action commenced by either party with respect to
the divorce of the parties. Each party further agrees hereby to
indemnify and hold the other party harmless from any demand, claim,
loss, cost and expense (including additional attorney's fees) arising
from a failure to pay all of the aforesaid attorney's fees and other
costs.
20. Informed and Voluntary Execution. Each party to this
agreement acknowledges and declares that he or she, respectively:
A. Is fully and completely informed as to the facts
relating to the subject matter of this agreement and as to the rights
and liabilities of both parties.
6. Enters into this agreement voluntarily after receiving
the advice of independent counsel, free from fraud, undue influence,
coercion or duress of any kind.
C. Has given careful and mature thought to the making of
this agreement.
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D. Has carefully read each provision of this agreement.
E. Fully and completely understands each provision of this
agreement.
21. Mutual Cooperation. The Husband and the Wife shall each
concurrently herewith, or at any time hereafter on the demand of the
other, execute any other documents or instruments, and do or cause to
be done any other acts and things as may be necessary or convenient to
carry out the intents and purposes of this agreement.
22. Severability. If any provision in this agreement is held by
a court of competent jurisdiction to be invalid, void, or
unenforceable, the remaining provisions shall nevertheless continue in
full force and effect without being impaired in invalidated in any
way.
23. Reconciliation. If there should be a reconciliation of the
parties after the date of execution of this agreement, this agreement
shall nevertheless continue in full force until it is modified or
abrogated by another written instrument to that effect signed by each
of the parties hereto.
24. Future Earnings. All income, earnings or other property
received or acquired by either party to this agreement on or after the
date of execution of this agreement shall be the sole and separate
property of the receiving or acquiring party. Each party, as of the
effective date of this agreement, does hereby and forever waive,
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release and relinquish all right., title anti _.nterest in all such
income, earnings or other property so _eceiveci or acquired by the
other.
25. Waiver of Rights. Each of the parties hereby irrevocably
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waive all rights which he or she may have to request any court to
equitably distribute the marital property of che parties or to have
alimony, alimony pendente lite or counsel fees awarded to either
party, it being the express intention of the parties hereto to fully
settle all claims which they have with respect to each other in this
agreement. Each of the parties further agree to consent to the entry
of a Decree in Divorce.
26. Waiver of Breach. The waiver of anv term, condition, clause
or provision of this agreement small in no way be deemed or considered
a waiver of any other term, condition., clause or provision of this
agreement.
27. Survival of Acrreement. if any term, condition, clause or
provision of this agreement shall, by its reasonable interpretation,
f.
be intended to survive and extend beyond the termination of the
marriage relationship presently existing between the parties hereto,
said term or terms, condition or conditions, clause or clauses,
provision or provisions, shall be so construed, being the express
intention of both parties hereto to have this agreement govern their
relationship no,..,, or hereafter, irrespective of their marital status.
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28. Jurisdiction. This agreement shall be construed under the
laws of the Commonwealth of Pennsylvania, and both parties consent and
agree to the jurisdiction of the Court of Common Pleas of Cumberland
County, Pennsylvania, on account of any suit or action brought with
respect to this agreement or any provisions or matters referred to in
any provisions thereof.
29. Agreement Binding on Parties and Heirs. This agreement
shall be binding in all its terms, conditions, clauses and provisions
of the parties hereto and their respective heirs, administrators,
e:.ecutors and assigns.
30. Divorce. Husband and [life agree, upon the expiration of the
ninety (90) day waiting period, to e::ecute all Affidavits of Consent
and other documentation necessary to have a divorce decree entered
pursuant to Section 3301(c) of the Divorce Code of Pennsylvania on the
ground that the marriage is irretrievably broken.
31. Headings. The headings or captions preceding the paragraphs
in this agreement are inserted for convenience of reference only and
shall not be construed in interpreting this agreement.
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_._.. ..^-l i1wM?A4Ye!M1.LMY??NY!R:X'G.!F.'?Y_^.!'IlR?R!CO _ ? _Y T??A?1
IN WITNESS WHEREOF, the parties have hereunto set their hands and
seals the day and year above first written.
Fiona J. BeLieu
Eliza]/Eti B. S ne, Esquire Christopher M. BeLieu
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C1\dlv% It ransmltpr.,)uc I pq\7-97
W
CHRISTOPHER M. BeLIEU,
Plaintiff
V.
FIONA J. BeLIEU,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6877
ACTION IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court
for entry of a divorce decree:
1. Ground for divorce: irretrievable breakdown under § (3301(c))
(3301(d)(1)) of the Divorce Code. (Strike out inapplicable section).
2. Date and manner of service of the complaint: NOV. 18. 1999. U.S. MAIL. SPECIAL DELIVERY
RESTRICTED DELIVERY. POSTAGE PREPAID
3. Complete either paragraph (a) or (b)
(a) Date of execution of the affidavit of consent required by
§ 3301(c) of the Divorce Code: by Plaintiff by Defendant
(b) (1) Date of execution of the affidavit required by § 3301(d) of the
Divorce Code:
(2) A. Date of filing of Plaintiff's affidavit upon respondent:_
B. Date of service of Plaintiff's affidavit upon respondent:
9. Related claims pending: ALL CLAIMS SETTLED
5. Complete either (a) or (b) :
(a) Date and manner of service of the notice of intention to file praecipe
to transmit record, a copy of which is attached:
(b) Date Plaintiff's Waiver of Notice in § 3301(c) Divorce was filed with
the Prothonotary:
Date Defendant's Waiver of Notice in § 3301(0 Divorce was filed with
the Prothonotary:
;(PLAINTIFF)
ELI
Court No. 60251
7E, LAF"ER,a- "SKEKLETSKI
ATTORNEYS AT.'LAW',
414 BRIOftE STREET
cNE W CUMBERLAITD,. PA 17070 _ r
CHRISTOPHER M. BeLIEU,
Plaintiff
v.
FIONA J. BeLIEU,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUidBERLAND COUNTY, PENNSYLVANIA
NO. CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims
set forth in the following pages, you must take prompt action. You are
warned that if you fail to do so, the case may proceed without you and a
Decree of Divorce or annulment may be entered against you by the Court. A
judgment may also be entered against you for any other claim or relief
requested in these papers by the plaintiff. You may lose money or property
or other rights important to you, including custody or visitation of your
children.
When the ground for the divorce is indignities or irretrievable
breakdown of the marriage, you may request marriage counseling. A list of
marriage counselors is available in the Office of the Prothonotary at the
Cumberland County Courthouse, Carlisle, PA 17013. .
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle. PA 17013
Telenhone: (717) 249-3166
fl\di v\b,IS000ni.d i:•
CHRISTOPHER M. BeLIEU,
Plairltiff
v.
FIONA J. BeLIEU,
Defendant
Itt THE COURT OF COMMON PLEAS OF
CUMMRLt+ND COUNTY, PENNSYLVANIA
CIVIL ACTION LAP1
IN DIVORCE
COMPLAINT
1. The Plaintiff in this action is CHRISTOPHER M. BeLIEU, an
adult individual, who currently resides at 1114 Bradley Drive, Apt. G-
211, Carlisle, Cumberland County, Pennsylvania, 17013.
2. The Defendant in this action is FIONA J. BeLIEU, an adult
individual, who currently resides it 55 Hickory Road, Carlisle,
Cumberland County, Pennsylvania, 17013.
3. Both the Plaintiff and the Defendant have been bona fide
residents of the Commonwealth of Pennsylvania for at least six (G)
months immediately previous to the filing of this complaint.
°•- The Plaintiff and Defendant were lawfully joined in marriage
on August 25, 1984, in Bath, England.
5. There have been no prior actions of divorce or for annulment
between the parties hereto in this or an;, other jurisdiction.
6. The Plaintiff avers as tile- grounds upon which this action is
based is that the marriage between the parties hereto is
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irretrievably broken.
7. The Plaintiff avers there were two children born of this
marriage.
8. The Plaintiff has been advised that counseling is available
and that the Plaintiff may have the right to request that the court
require the parties to participate in counseling.
9. The Plaintiff requests the court to enter a decree of
divorce.
I verify that the statements made in this complaint are true and
correct. I understand that false statements herein are made subject
to the penalties of 18 P.C.S. §4904, relating to unsworn falsification
to authorities.
CHRISTOPHER M. BeLIEU, Plaintiff
Date : // MO C C/°
STONE LaFAVER & SHEKLETSKI
By_
Elizabetfr'ul3 Stone, Esquire
Supze e Court SD 46,0251
414 Bridge Street-;"-P.O. Box E
New Cumberland; PA 17070
Telephone/'717-774-7435
Attorneys for Plaintiff
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CHRISTOPHER M. BELIEU,
Plaintiff
FIONA J. BeLIEU,
vs.
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 -6877
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under 53301(c) of the Divorce Code was filed on
November 15, 1999.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety
days have elapsed from the date of fling 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 unsworn falsification to
authorities.
Fiona J. BeLieu, Defendant
Date: ?,t,.0-, -r I SAIDIS
SHUFF, FLOWER
& LINDSAY
ATIDRSEVS•AT•IA%V
26 IV. High Street
Carlisle, PA
?_
CHRISTOPHER M. BeLIEU,
Plaintiff
v.
EIONA J. BeLIEU,
Defendant
: IN THE COURT' OF COP•IP10N PLEAS
: CUP-0BERLTMM COUNTY, PENNSYLVAN_
NO. 99-5877 CIVIL TERM
CIVIL ACTICII - III DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce u n der 5 3301(c) of the Divorce Code
was filed on November 15, 1999, and served November 18, 1999.
2. The marriage of plaintiff= and defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing the
complaint and service of the coma l aint.
3. I consent to the entry of a final decree of divorce after
service of notice of intention to request entry of the decree.
4. I understand that I may lose rights concerning alimony,
division of property, .lawyer's fees or expenses if I do not claim them
before a divorce is granted.
I verify that the statements made in this affidavit are true and
correct. I understand that false statements herein are made subject
to the penalties of IS Pa. C.S. 5 4 904 relating to unsworn falsifica-
tion to authorities.
sl.Zl??s
Date
CHRIST PHER M. BeLIEU, Plaintiff i
CHRISTOPHER hl. BeLIEU,
Plaintiff
v.
FIONA J. BeLIEU,
Defendant
Ill TliF. COURT OF COMt•IODI PLEAS OF
: CUMBERLAND COU11T'i , PEt*JSYLVANIA
PIO. 99-6877 CIVIL TERM
CIVIL ACTIOPl - LAW
IM DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without
notice.
2. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim them
before a divorce is granted.
3. I understand that I will not be divorced until a divorce
decree is entered by the Court and that a copy of the decree will be
sent to me immediately after it is filed with the Prothonotary.
I verify that the statements made in this affidavit are true and
correct. I understand that false statements herein are made subject
to the penalties of 18 Pa. C.S. § 4909 relating to unsworn falsifica-
tion to authorities.
c?•
Date CHRISTOPHER M. BeLIEU, Plaintiff
CHRISTOPHER M. BELIEU,
Plaintiff
FIONA J. BeLIEU,
VS.
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 -6877
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
93301(c) OF THE DIVORCE CODE
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 if I do not claim them before a divorce is granted.
3. 1 understand that I will not be divorced until a Divorce Decree is entered
by the Court and that a copy of the Decree will be sent to me immediately after it is
filed with the Prothonotary.
authorities.
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 unsworn falsification to
Fiona J. BeLieu, Defendant
Date: ,- z (-? n a
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATTOILYEYS•AT•L{0.'
16 W. Nigh Street
Carlisle, PA
.. ,;
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STONL,I LAFAVER ,& SEI6KLL'TSKI? rq y•
a f0?-,?' '
A PROFESSIONAL CORPORATION
ATTORNEYS AT LAW
1 414 BRIDGE STREET
NEW GUMRRRLAND. PA 17070 -
CHRISTOPHER M. BeLIEU, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V NO. 99-6877 CIVIL TERM
FIONA J. BeLEIU, CIVIL ACTION - LAW
Defendant IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA)
) SS:
COUNTY OF CUMBERLAND )
I, Elizabeth B. Stone, of Stone LaFaver & Shekletski, attorneys
for the plaintiff hereby certify that I served the Complaint in
Divorce in the above captioned matter on the defendant, Fiona J.
BeLieu, at 55 Hickory Road, Carlisle, PA !7013, by United States
Certified Mail, postage prepaid, restricted delivery, on October 18,
1999, as evidenced by the attached Certified Mail return receipts.
ELIZABE-Ta B.
Att nev at
SWORN TO AND SUBSCRIBED
before me this day
of ?l)Ct•: . ?•..- 1999.
Not ' y Public
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us feipt taI Service
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t9rs. Fiona S. BeLieu
Slreal b r:um0ar
55 Hickor Road
Post Olt ce State, b ZIP Cade
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STONE LAFAVER & SIIEKLETSKI
ATTORNEYS AT LAW
DAVID H. STONE
GERALD J. SHEKLETSKI
ELIZABETH B. STONE
414 BRIDGE STREET
POST OFFICE BOX E
NEW CnH111:n LANII. PA 17070
www,smnclaw.net
September 26, 2002
OF COUNSEL
CHARLES H. STONE
JON F. LAFAVER
TELEPHONE 17171774-7435
FACSIMILE 17171774-3889
E. Robert Elickcr, Esquire
Divorce iYlaster's Office
9 North Hanover Street
Carlisle, PA 17013
Rc: Belieu v. Belicu
Dear Master Elickcr:
As per my discussion with Tracy in your office, the parties have reached a settlement
cast; therefore there is no need for a Pre-Trial 1-learingon the
agreement in the above-captioned
Illy
issue of Alimony that is currently scheduled for Friday, September 26, 1001 at text t several d9:00 a.m. m. WItheisn I
understanding that the agreement will lie signal by the parties in the e n
receive this agreement, I will forward a copy to your office.
Thank you for the opportunity to settle this case, without the need fora hearing.
Very truly yours,
v,rONE LaFAVER & SHEKLETSKI
EBS/hncp
Enclosure
cc: Mr. Christopher BeLicu
Attorney Carol Lindsay
s
CHRISTOPHER N. BeLIEU, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 99 - 6877 CIVIL
FIONA J. BeLIEU,
Defendant IN DIVORCE
CONFERENCE WITH
COUP?SEL AND PARTIES
TO: Elizabeth B. Stone
Christopher M. BeLieu
Carol J. Lindsay
Fiona J. BeLieu
Counsel for Plaintiff
Plaintiff
Counsel for Defendant
Defendant
A conference has been scheduled at the Office of
the Divorce Master, 9 North Hanover Street, Carlisle,
Pennsylvania, on the 27th day of September 2002, at 9:00
a.m., with counsel and the parties to discuss the
outstanding economic issues to determine if there is a basis
of settlement of claims. If issues remain after the
conference, a hearing will be scheduled at another date.
Very truly yours,
Date of Notice: 7/1/02
E. Robert Elicker, II
Divorce Master
CHRISTOPHER M. BeLIEU IN THE couRT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plainllff CIVIL, ACTION - LAW
99 - 6977
VS. NO. CIvIL 19
["IONA J. BcLIEU IN DIVORCE
Defendant
STATUS SHEET
nAmV- I ACTIVITIES:
Cd••/i•.?pr,<p..l!• ??rv??_
. d•Nnt:?/, C/tti?,,?tJlCt?;+LC/.?t_r_?.t.:.l. F?(c%I
C" L)
CHRISTOPHER M. BeLIEU, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99 - 6877 CIVIL
FIONA J. BeLIEU,
Defendant IN DIVORCE
TO: Elizabeth B. Stone
Attorney for Plaintiff
Carol J. Lindsay Attorney for Defendant
DATE: Monday, June 10, 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.
i
i
?t
MNEW
(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.
CHRISTOPHER BELIEU V. FIONA BELIEU
DOINI: AUGUST 25, 1984
DOS: JUNE 5, 1999
INCOME (monthly net)
Wife
2,046.10
+ 553.80
2,599.90
Husband
4,919.13
- 553.80
4,365.33
(based on bonus in 2001 of S16,000
in 2000 bonus was S24,000)
ASSETS
Home
Vehicles
Accounts
IRA
10,800.00 (29%)
PENSION:
'/a marital x 1107.60 = 430.70 /2 =415.35
WIFE
22,000.00
1,000.00
4,000.00
27,000.00 (71%)
By giving Wife Y entire pension (not just marital portion) Husband pays Wife 66% of
marital portion.
Children aged 14 and 11
HUSBAND
8,000.00
5,000.00
2,000.00
Present spousal support: 471.64; spousal with ''/-. pension S170.
LAW OFFICES
SAIDIS, SHUFF, FLOWER & LINDSAY
A PROFESSIONAL CORPORATION
26 WEST HIGH STREET
JAMES D. FLOWER CARLISLE, PENNSYLVANIA 17013
JOHN E. SLIKE TELEPHONE: (71i? 243-6211 - FACSIMILE: (71i? 243-6456
ROBERT C.SAIDIS EMAIL: clindsaye'ssfl-la%vxotn
GEOFFREY S. SHUFF www.sst1-Iaw.C0111
JANIES D. FLOWER, JR.
CAROL J. LINDSAY
JOHNNA J. KOPECKY
KARL NI. LEDEBOHNI
JOSEPH L. HITCHINGS
THOMAS E. FLOWER
FORREST N. TROUCMAN, 11
June 20, 2002
Elizabeth B. Stone, Esquire
STONE LAFAVER & SHEKLETSKI
414 Bridge Street
P. 0. Box E
New Cumberland, PA 17070
Re: BeLieu v. BeLieu
No. 99 - 6877
Dear Elizabeth:
II
WEST SHORE OFFICE:
2109 MARKET STREET
CAMP HILL, PA 17011
TELEPHONE: (717)7373405
FACSIMILE: (717)737-3407
REPLY TO CARLISLE
Discovery in this case has proceeded informally and I assume that will continue as we
prepare for the Master's hearing. Please let me know if your client requires formal discovery.
Would you please provide me:
1. A copy of Chris' federal income tax return for 2001.
2. Chris's pay stub for the last pay period in May, 2002.
3. Retiree account statement for 2002 provided by Defense Finance and Accounting
Service.
Thank you for your help.
Very Ifuly yours,
SAIDIS, SHUFF, FLOWER & LINDSAY, P.C.
Carol J. Lindsay
CJUtjb
cc: Fiona BeLieu
E. Robert Elicker, II, Esq. (Div Mast)
(I??! 1 0 2002
CHRISTOPHER M. BeLIEU, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99 - 6877 CIVIL
FIONA J. BeLIEU,
Defendant IN DIVORCE
TO: Elizabeth B. Stone
Attorney for Plaintiff
Carol J. Lindsay Attorney for Defendant
DATE: [Monday, June 10, 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.
J&
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
I DATE COUNSEL FOR OLAINTIFF?( )
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.
CHRISTOPHER M. BeLIEU,
Plaintiff
VS.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 -6877
FIONA J. BeLIEU,
Defendant IN DIVORCE
CERTIFICATION FOR DISCOVERY
(a) See attached letter to counsel.
(b) Discovery will be complete upon provision of the documents requested.
r ?
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- ----------- -
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1
f
CHRISTOPHER M. BeLIEU, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99 - 6877 CIVIL
FIONA J. BeLIEU,
Defendant IN DIVORCE
TO: Elizabeth B. Stone Attorney for Plaintiff
Carol J. Lindsay Attorney for Defendant
DATE: Monday, June 10, 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.
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
DATE
COUNSEL FOR - PLAINTIFF ( X)
COUNSEL/FOR DEFENDANT ( )
l
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.
IV THE COURT OF COMMON PLEAS OF
CL^IBERLAND COUNTY, PENNSYLVANIA
CHR15'rOPHER M. BeLIEU
Plaintiff
VS.
FIONA J. BeLIEU
N0. 99-6877 rb? P999
MOTION FOR APPOINTMENT OF ?CASTER
CHRISTOPHER M. BeLIEU (plaintiff) (D t ), moves the court to appoint
a master with respect to the following claims: ( X) Distribution of Property
( ) Divorce
( ) Annulment ( ) Support
( X) Alimony ( ) Counsel Fees
( ) Alimony Pendente Lite ( ) Costs and Expenses
and in support of the motion states:
(1) Discovery is complete as to the claims(s) for which the
appointment of a master is requested.
(2) The defendant (has) (fitkao appeared in the action (pacZanaddy)
Carol Lindsay, Esquire ,Esquire).
(by his attorney,
(3) The statutory ground(s) for divorce (Yid (are)3-jQI• r i jna (d)
(4) Delete the inapplicable paragraph(s):
(a) The action is not contested.
(b) An agreement has been reached with respect to the
following claims:
(c) The action is contested with respect to the following
claims: ALIMONY AND EQUITABLE DISTRIBUTION
(5) The action ( N3u)M) (does not involve) complex issues of law
or fact.
(6) The hearing is expected to take one half day (kR)lkf:) (days).
(7) Additional information, if any. relevant to the motion:
Date: June 5, 2002
,l
AND NOW G
is appointed ma ter with respect
in
By the Court:
ii
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:,
., -
,;
_ ,
,;
CHRISTOPHER M. BeLIEU,
Plaintiff
V.
FIONA J. BeLIEU,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6877
CIVIL ACTION - LASS
IN DIVORCE
NOTICE OF INTENTION TO REQUEST
ENTRY OF S 3301(4) DIVORCE DECREE
TO: Fiona J. Belieu
c/o Carol J. Lindsay, Esgc re
SAIDIS, SNUFF, FLO21ER :, LINDS ,'i, P.C.
26 :Vest High Street
Carlisle, Pennsylvania 17;;!3
YOU HAVE BEEN SUED 1N AN .._. ON FOR D_VOK. E. .;q1
answer the Complaint or file . Ca nt•er f i_i< _.. _w
affidavit. Therefore, ca or after May 27, i 1!." ..
request the tort to enter a fin... anTiv-, in _•_ .•__;--.
IF YOU DO HOT FILE tiic Prothonotary of the C-:".. _ :i:'::•:
With your signature notarized or erVied, pr C. !_:7Un tip::-:'•.:.i i'J 1. C.',
the above date, the Court can enter a final Decree ;
Unless you have already filed 'with the Court a writunn ?..K .m !. ..
economic relief, you must do so by the above dare or n w!
grant the divorce and you will lose forever rhn inhi nk ...
economic relief. The fillna of the _ to ]nun '
not protect your economic ciaimy. A COJ!; ER-AF', i.... .. NP! 'A . - NA!
FILE WITH THE PROTHONOTARY OF THE COURT ATTA....:.u in ...:.. V A.
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, Pennsylvania 17013
(717)299-3166
MAY 7, 2002
-2-
fl\elv\I-inte.,t dnt
¦..
CHRISTOPHER M. BeLIEU,
Plaintiff
V.
FIONA J. BeLIEU,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6877
CIVIL ACTION - LAW
IN DIVORCE
NOTICE
If you wish to deny any of the statement set to-1-h in r_! is
Affidavit, you must file a Counter-Affidavit within tro:u :ry
after this Affidavit has been served on you, or tht: st tt:um r. wi 1 I I;,•
admitted.
STONE LaFAVER ,St1 LETSKI
Attorneys f p
By
t1ft?:a'!'H Y. S;y)tll;
{-torney C I
I. D.
i;6 I
4111 Bdgi St.r .r, F:
New Itnb, r].rlnci,
I
f1\tl1v\0':.i Nm<?d,tliv<c'4ti'?'•5??=
CHRISTOPHER M. BeLIEU,
Plaintiff
v.
FIONA J. BeLIEU,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6077
CIVIL ACTION - LAW
IN DIVORCE
AMENDED COMPLAINT
1. The plaintiff i.;; -z'-is action Js
c;p r
- eTIcU, an adult
l. l 1.
c :.1"'t• La::e,
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^ CGll1nC: or' n 13,
s
s
urrently - ,es
individual, o:ho c _
a .
.
.
Cumberland County, Pennsyl;'ani , 17007.
2. The defendant in this action is F1011A J. BeLIEU, an adult
individual, o-:ho currently res4-d es at 5-? Li;nestone ?oad' Carlisle,
Cumberland County, Pennsylvania, 17013- 43:6•
COUNT II
Request for Decree of Divorce Under
Section 3301(d) of the Divorce Code
r
?. Paraoraohs 3 throUah i O ^-e Jr1. C1 '_113 ?. UOi^D 1c.1ilL ?.=C
rated by reference herelll F:s 1:,-Ducl ['. L::l=y 52C rOr Cf1 lc!:jtf?.
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pr:_.-:i of at
:t- :1
least ...
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P FicC EcOR'r
of DiVOr ,'e pLIr5Li Lint _.cr_e
a De -, !
,r th st11C° :1'?-:Cic; l1C _u _t?!tG ..?
state:cents t. _.-=i:', made suojec, to
I verify correct. I understand that
tG
l F.C.S.
the penalties of 3
auttlorities.
Date:
l
STONE LaFAVER & SHEKLETSKI
E t .. c. ..
f . D i;; olYi 51
2.0. Ci0}:
91•??1 dga Streer., 70
i]e,4P -fl and, F iV
PL.
Elf/phone: 717-779-7935
-2-
CHRISTOPHER M. BeLIEU,
i
i Plaintiff
V.
FIONA Z BeLIEU,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 99-6877
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT UNDER §3301(d) OF
THE DIVORCE CODE
1. The parties to this _.:7C' . opar-ved ? -
- - 0" Or .fL-•!.. .7UE7e 1,
1999, and have contincad to 1 separate and c[Td::T- of
least two years.
2. The marriage is i.rrenrievabiy broken.
3. I understand that i ra,-:'_' _osa __ con _,rning ai'_mony,
division
OY property, lawyer's _.e° O!- i.::O?IIS%. _, if claim
before a divorce is granter.i.
VERIFICATION
1, the undersigned, here verify than the r .
this affidavit are true and cor.r c'. t understd.:
that false state-
ments herein are made subject [O the penalLie, Uf 8
relating to unsworn fals_iicanion ,.. Vuriti•es.
i
Date Chrisnopher K,
II
CHRISTOPHER M. BeLIEU,
Plaintiff
V.
FIONA J. BeLIEU,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6877
CIVIL ACTION - LAW
IN DIVORCE
NOTICE OF INTENTION TO REQUEST
ENTRY OF 15 3301(d) DIVORCE DECREE
TO: Fiona J. BeLieu
c/o Carol J. Lindsay, Esquire
SAIDIS, SHUFF, FLOWER & LINDSAY, P.C.
26 West High Street
Carlisle, Pennsylvania 17013
CHRISTOPHER M. BELIED, Defendant, intends to file with the Court
the attached Praecipe to Transmit Record on or after May 27, 2002,
requesting that a final Decree in Divorce be entered.
STONE LaFAVF,R & SHEKLETSKI
Attornevs or Plaintiff
By /
EL ' B• H B. STONE
-ctor ey a- LaW
I.D. #60 1
919 BriOge Street, P.O. Box E
Ne Cumberland, PA 17070
TelepKone: 717-779-7935
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CHRISTOPHER M. BELIEU,
Plaintiff
FIONA J. BeLIEU,
VS.
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 -6877
IN DIVORCE
COUNTER AFFIDAVIT UNDER SECTION 3301
t. CHECK EITHER (A) OR iBi:
Lew I do not oppose the entry of the divorce decree.
(b) I oppose the entry of a divorce decree because: (CHECK 01.1nI OR onH,i:
(i) The parties to this action have not lived separate and
apart for a period of at least two years; and
(ii) The marriage is not irretrievable broken.
SAIDIS
SNUFF, FLOWER
& LINDSAY
ATRIRSFI'S•AT•L\N
26 IV. Iligh Sireei
Carlisle, PA
2. CHECK EITHER JA) OR (B).
(a) I do not wish to make any claims for economic relief. I understand that I
may lose rights concerning alimony, division of properly, lawyer's fees
or expenses if I do not claim them before a divorce is granted
(f5) I wish to claim economic relief which may include alimony, division of
V property, lawyer's fees or expenses or other important rights.
VERIFICATION
I, the undersigned, hereby verify that the statements made herein are true and
correct. I understand that false statements herein are made subject to the penalties of
18 Pa. C.S. § 4904, relating to unsworn falsification to authorities.
Fiona J. BeLieu
Date: ?) 15 O
'1
??? /
?J
LAW OFFICES
SAIDIS, SNUFF, FLOWER & LINDSAY
26 W. HIGH STREET 2109 MARKETSTRF.Er
CARLISLE, PA 17013 CAMP HILL. PA 17011
PHONE(717)243.6222 PHONE (717) 7374405
CERTIFIED COPY:
CHRISTOPHER M. BELIEU,
PLAINTIFF
VS.
FIONA J. BELIEU,
DEFENDANT
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 99 -6877
IN DIVORCE
ANSWER TO COMPLAINT IN DIVORCE
NOW COMES, Fiona J. BeLieu, Defendant above, by and through her counsel,
I!
SAIDIS, SHUFF, FLOWER & LINDSAY, and answer the Complaint and make a
i?
counter-claim as follows:
1. Admitted.
ll
2. Admitted.
r,
J! 3. Admitted.
II 4. Admitted.
5. Admitted.
i
i
6. Admitted.
7. Admitted.
i
t
8. Admitted.
9. Admitted.
SAIDIS WHEREFORE, Defendant prays this Honorable Court to enter a Decree in
SHUFF, FLOWER
& LINDSAY
A7TOR%Ti S.AT•IAIY Divorce divorcing Plaintiff from Defendant.
26 W. High Street
Carlisle, PA
4
COUNTER-CLAIM
COUNT I - EQUITABLE DISTRIBUTION
10. In the course of their marriage, the parties acquired certain property, both
personal and real.
WHEREFORE, Defendant prays this Honorable Court to equitably divide their
property.
COUNT H - ALIMONY
11. Defendant is without the ability to provide for her reasonable needs after
the entry of a Decree in Divorce.
WHEREFORE, Defendant prays this Honorable Court to enter an award of
alimony.
SAIDIS, SHUFF, FLOWER & LINDSAY, P.C.
ATTORNEYS FOR DEFENDANT
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATrORNTYS•AT•LAW
26 W. High Street
Carlisle, PA
BY:
COUR-O.J. LINVSAY, ESQUIRE
tt 44693
26 WEST HIGH STREET
CARLISLE, PA 17013
(717) 243-6222
VERIFICATION
?I
I, THE UNDERSIGNED, HEREBY VERIFY THAT THE STATEMEENTS WADE HEREIN ARE TRUE
II
AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE
i
i; PENALTIES OF 18 PA. C.S. § 4904, RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES.
ii
FIONA J. BELIEU
DATE: 1
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATi0RYE1'S•.{T•L{ll'
26 W. Illgh Strecr
Carlisle. PA
CHRISTOPHER M. BELIEU,
PLAINTIFF
FIONA J. BELIEU,
vs.
DEFENDANT
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION -LAW
: NO. 99 -6877
IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, THIS cye7
DAY OF
2002, I, CAROL J. LINDSAY, ESQUIRE, OF THE LAW FIRM OF SAIDIS, SHUFF, FLOWER &
LINDSAY, P.C., ATTORNEYS, HEREBY CERTIFY THAT I SERVED THE WITHIN ANSWER TO
COMPLAINT IN DIVORCE AND COUNTER-CLAIM THIS DAY BY DEPOSITING SAME IN THE UNITED
STATES MAIL, FIRST CLASS, POSTAGE PREPAID, IN CARLISLE, PENNSYLVANIA, ADDRESSED
TO:
ELIZABETH B. STONE, ESQUIRE
Stone LaFaver & Shekletski
414 BRIDGE STREET
P. O. Box E
NEW CUMBERLAND, PA 17070
SAIDIS
SHUFF, FLOWER
& LINDSAY
Xr
26 1V. High Street
Carlisle, PA
SAIDIS, SHUFF, FLOWER & LINDSAY, P.C.
ATTORNEYS FOR DEFENDANT
BY: / j
CAROL . LINDSAY, QUIRE
IW 693
26 WEST HIGH STREET
CARLISLE, PA 17013
(717)243-6222
?-.
:::.?
_._
,_ .?
IV THE COURT OF MMON PLEAS OF
CLMERLAND COUNTY, PENNSYLVANIA
CHRISTOPHER M. BeLI
Plaintiff
VS.
FIONA J. BeLIEU
NO. 99-6877 xb&c T999
MOTION FOR APPOINTMENT OF MASTER
CHRISTOPHER M. BeLTEU (Plaintiff) ( ), moves the court to appoint
a master with respect to the following claims:
( ) Divorce ( X) Distribution of Property
( ) Annulment ( ) Support
( X) Alimony ( ) Counsel Fees
( ) Alimony Pendente Lite ( ) Costs and Expenses
and in support of the motion states:
(1) Discovery is complete as to the claims(s) for which the
appointment of a master is requested.
(2) The defendant (has) M#91) appeared in the action (paeaesaMly)
(by his attorney, Carol Lindsay, Esquire Esquire).
(3) The statutory ground(s) for divorce (W (are)
(4) Delete the inapplicable paragraph(s):
(a) The action is not contested.
(b) An agreement has been reached with respect to the
following claims:
(c) The action is contested with respect to the following
claims: ALIMONY AND EQUITABLE DISTRIBUTION
(5) The action ( I02M)76) (does not involve) complex issues of law
or fact.
(6) The hearing is expected to take one half dad! (hRkgfi) (days).
(7) Additional information, if any. relevant to the motion:
Date: June 5, 2002
AND NOW
4 V , P
is appointed ma ter with respect
Esquire,
By the Court:
AAAjk
J
f!
U
.n
7
CHRISTOPHER M. BeLIEU,
Plaintiff
V.
FIONA J. BeLIEU,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-6877
CIVIL ACTION - LAW
IN DIVORCE
ANSWER TO DEFENDANT'S COUNTER- CLAIM
And now comes the Plainti i_i, christopher N. Belieu, by and
through his attorney, Stone Lauver 6 Shekletsk L, and sets forth
the following answer to Defendant's counter-claim.
10. Admitted. By :iay of further answer, Plaintiff avers that
the real and personal property has been equitably divided between
the parties, in that the re.,L ..state jointly n%,ned by the parties
was sold with the majority of. the portion given to the Defendant.
il. Denied. It is denied that the Defendant is without the
ability ..o provide for her reasonable needs after the Entry of a
Decree in Divorce, in that the Detendamu, ago 40 years old, is
gainfully employed and earning approximately $30, 000 per year
.
Further, Defendant will be receiving 702 of th e
Plaintiff's
military pension upon date of divorce.
-1-
i. .
".'herefore, in is respectfully requested chat this Cour
enter an award dismissing Defendant's Counter-Clain counts 10 an
11, and enter a Decree in Divorce.
I verify that the statements made in this complaint are true
and correct. 1 understand that false statements herein are made
subject to the penalties of 10 P.C.S. 54904, relating t.o unsworn
falsification to authorities.
Date: ?/(, alll (C /??
CHRISTOPHE r M. BeLIEU
STONE LaFAVER & SHEKLETSKI
By
?' Attorn
II.D. n
414-01
-2-
ETH/B.,STONE
qc- Law
of,
ge Street, P.0. Box E
erland, PA 17070
e: 717-774-7435
CERTIFICATE OF SERVICE
i, Elizabeth B. Stone, AtLornt?y at Law, of tte law firm of Stone
La Paver & Sheklets}:i, attorneys for Plaintiff, Christopher M. Belieu,
hereby certify that on this date I served a true and correct copy of
the within instrument on Defendant's counsel of record by first class
mail, postage prepaid, addressed as follows:
Carol J. Lindsay, Esquire
Saidis, Shuff, Flower & Lindsay26 West Nigh Street
Carlisle, PA 17013
Elizabeth..B. Stone, Esquire
Sup. C[. ;;60251
Stone LaFaver & Shekletski
414 Bridge Street
New Cumberland, PA 17070
DATE: 1?4?c S 41 2
STONE, LAPL"VER &- STIEKLrTSKT
ATTORNEYS AT LAW
DAVID H. STONE
GERALD J. SHEKLETSKI
ELIZABETH B. STONE
414 BRIDGE STREET
POST OFFICE BOX C
Ni:w Ccel Blun.n I'll. PA 17070
,%,,v slonelaw net
.Iune 7.2002
Tracy Collierl
E. Robert Slicker, lisquire
Divorce Master's Office
9 North I lanoyer Street
Carlisle, IIA 17013
Re: Relieu v. Ilelieu
Dcal-Tracy:
OFCOUNSEL
CHARLES H.STONE
JON F. LAFAVER
TELEPHONE 17171 774.7433
FACSIMILE 171717743869
I filed it Petition for Appointment of master on Wednesday. June 5, 2002, in the above-
captioned case. It is illy belief that this case is a one-issue case, that of alimony, and as such, I
do believe that it meeting prior to any pre-trial conlcrence with the \-lastcr might enable the
parties to reach a settlement without any need for a hearing-.
I have spoken with Attorney Carol Lindsay several times about the idea of presenting our
limited argument to Mr. Elicker in an informal setting so that we can get sonic Icedback on this
issue. I have read this letter to ATs. Lindsay. and she concurs.
Obviously, for purposes of scheduling \ve %vill need less than an hour of his time. Please
let us know. I do appreciate your altcntion to this matter.
\,cry truly yours:
_I .AA I:R S SI
S"TONG La
EBS/lntcp
cc: NIr. Christopher BeLicu
Attorney Carol Lindsay
EITSKI
RETIREE ACCOUNT STATEMENT
STATEMENT EFFECTIVE DATE NEW PAY DUE AS OP SSN
JAN 10, 2002 FEB 01, 2002 225 66 0899
PLEASE REMEMBER TO NOTIFY DFAS IF YOUR ADDRESS CHANGES DEFENSE FINANCE AND ACCOUNTING SERVICE
CLEVELAND CENTER (CODE PRR)
PO BO)( 99191
CLEVELAND OH x4199-1126
COMMERCIAL 1216) 522-5955
TOLL FREE 1-800-321-1080
.,? nu. v... TOLL FREE FAX 1-1100J6"559
MSG CHRISTOPHER M BELIEU USAF RET EMPLOYEE MEMBER SELF SERVICE (EIMSS)
9 LENOX CT hl.psllcm .dfn.milke hlml
M E C H A N I C S B U R G PA 17050-8215 1-877-DOD-EMSS (1-877-363-3677)
J'
.
'.
737, Z'. 7 Z
OLU "
NEW
ITEM OLD NEW ITEM
GROSS PAY
1,387.00
1,387.00
FITW
11
1,
037 0 3
144
00
COSTS
SBP 9 9 ALLOTMENTS/BONDS 1
. .
INCOME
TAXABLE 6 . 78
1,2 1,2
6.78
NET PAY 1,091.41 1,116.01
TAXABLE INCOME: 1,96:3$
b
FEDERAL INCOME TAX WITHHELD:
DIRECT DEPOSIT
FEDERAL WITHHOLDING STATUS: SINGLE
TOTAL EXEMPTIONS: 00
136
77
D
.
:
FEDERAL INCOME TAX WITHHEL
-SBP COVERAGE TYPE: SPOUSE ONLY ANNUITY BASE AMOUNT: 1, 88.02
% ANNUITY AMOUNT: 763.42
90.22 5
LY LOST
8
5
;
:
E ON
1
SPOUSE
59 ANNUITY AMOUNT: 485.
3
OUR RECORDS 00 NOT REFLECT A DATE OF BIRTH FOR YOUR SPOUSE. THE ANNUITY PAYABLE IS 55*`
THE ANNUITYY
AT AGE 62
S AGE 62
,
.
OF YOUR ANNUITY BASE AMOUNT UNTIL YOUR SPOUSE REACHE
OR UNDER THE TWO-TIER FORMULA. THAT RE-
SECURITY OFFSET
,
MAY BE REDUCED DUE TO SOCIAL
N ANNUITY THAT RANGES BETWEEN 35% ($ 485.81) AND 55% ($ 763.42)
SU
LT IN A
DUCTION MAY RE
OF THE ANNUITY BASE AMOUNT.
P ANNUITY AND THE SOCIAL SECURITY BENEFITS WILL PROVIDE TOTAL
THE COMBINATION OF THE SB
ND THE SOCIAL SECURITY ADMINISTRATION OF AT LEAST 55% OF YOUR BASE
F
DFAS
ROM
A
PAYMENTS
AMOUNT. THE ACTUAL ANNUITY PAYABLE IS DEPENDENT ON FACTORS IN EFFECT WREN THE ANNUITY
IS ESTABLISHED.
VIII pI VIII"III III III IIII DFAS-CL 7220/148 (REV 03-01) BELIE
DEPARTMENT OF THE AIR FORCE
305TH AMW/FMFS
2905 TUSKEGEE AIRMAN AVE
MCGUIRE AFS NJ OBS41-5013
O 7 0031964 LES
LIIIIII oil III IIF1III IIIIII III IT6IIII II$IIIIIII11„III III III
TERMINAL LEAVE RSC ADSN 4069
CHRISTOPHER M BELIEU
1414 BRADLEY OR G211
CARLISLE PA 17013-1272
ACCOUNTING SERVICE MILITARY LEAVE AND EARNINGS STATEMENT
DEFENSE FINANCE AND vRS SVC
ET
5 PERIOD COVERED
/DSSH
AOSN
BRANCH
FIRST, M0 SO C. SEC. NO. I GRAOE
NAME MAST I
DAY DA'E I I
I ;
,
ID 0 O
0
' DEDUCTIONS
ALLOTMEMS SUMMARY
ENRiLEMEMS
TYPE
AMOUNT
00
AMOU L
NT :TOi EN
0
TYPE AMOUNT TYPE DiSCU 1
"-
.
A M)l L
CA-SOC SECU0.ITY
280.90 F
BAS
e 1. 17 AFAi ALLOT
69 AFAF ALLOT
37
;
66
4
232,00
.
2.00 -TOT OED
AM 705.00 FCA-MEDICARE
I
B .
29 AiAF ALLOT
8] .302-Z@-
00
1
2
.
0 STATE TAXES
.
0 SPEC DUTY PAY 37
000
FOR 200 .
U AFAF ALLOT
16 00
-TOT Alui
2
.
1 7
00
6
1
,
E CLOTHING 291.80 SGLI 5
AFRH
F 21.33 NET PUT 1 4
12 Z2
ENTAL
D
M MID-MONTH-PAY 831.27 -CR FWD
j
9
I
? •tOM VAl
K
L 1,134.72
M
N
0
1369.281 1708.00
L 4232.001 TAX r
TOTA
PERIOD
WAGE
FED
USE/LOSE
PAI TD M/S EX ADD( TAO
WAGE
D(
USED CR BAl ETS BAl lv LOST lv
OF Bat ERND AXES
T
?
LEAVE
MED WAGE YTD
SOC TAX YTD
TD 74
74
0
M/S E%I TAX YiD
YT
E RIOo WAGE
STATE ST
MED TAX YiD
J WAGE P
1
I
I
(
qGq WAGE PERIOD SOC WAGE Y TA%ES P 50
4
4
7,
TAXES 1 1599. 0 DEPNS 20 1FT5
1FTR BAS TYPE CHARITY YTD iPC PACIpN
pqy BAD TYPE BAG DEPN VHA zIP RENT AMT ISNI.w I 0
DATA
N A
N
Y 01
REI.tARKS: YTD EMTTLE 4^-3^ - 00 YTO DEDUCT S5,
NONCHARCEABLE LEAVE 991214-991217(0011
-FOR GENERAL INFORMATION ABOUT PAY AND IpA TE CHG BASIC PAY 00010110011
ALLOWANCES VISIT THE DFAS WEBSITE, PATE CHG BAH 00010110011
(015)
NWW.DFAS.MIL". 00010110011 (CARRY LEAVE FWD NEW PERIOD SVC
00010110201
RATE CHG BAS 00011610151
ENLIST EXTENDED RATE CHG BAH
BAN BASED ON N/DEP.
7070
ZIP I
CLOTHING MAINTENANCE 990201-000131(024) (
N A
0
11
M
10
0
98428
ACCT N
www-dfas.mil
DFAS IIX 1M1. m" -A
06/30/2002 02:10 7176917686 CHRIS BELIEU PAGE 01
Label
L
One, irstnrctbns A
on patio 1g.) e
Use the IRS u
bebol. H
Otherwise, e
plq,u,4 pint n
of typo. E
Prnidrtntial ti
Elecilon C,vnpnign
Filing Status
chock artily
one box.
Exemptions
it more man 5,x
dopendents.
see page 20.
J You Spouse
? ?Yas 0No ?Yoa C
Dependants:
nlRrelnd t l11 rein! 121 prFlnnrmS (3) 0apenaa rs
10d4 6eN /amber Idailoeshlel0.
u (1 a wthi'i
41UforOMam
mdl alt 219 21
?
171
?
?
u 1e1a1 name" On exCi-hP11pn5 caimeo
7 Wages. Selones, tips. etC. Attach Form(s) W-2 . . . . . .. . . . . . .
Income 8a Taxable interest. Attach Schedule 13 if required , . . . , ,
Ansch le Tax-exempt interest. Do not include on lirm 8a . . . 1 Ob I I
Forms W-2 and g Ordinary drvidonds. Attach Schedule 6 If required . . . . . . . .
W-213 here.
Also attach 10 Tmaole refunds, credits. or offsets of state and local income texas Isere page 2Z) .
-
Form(a) ID99-R 11 Alimony rocahed . . . . . . . . . . . . . . . . . . .
(I tux was 12 Business memo or C•oss). Attach Sctxdule C or C-EZ .-
withholtL
13
Capital gain or Qoss). Attach Schedule O if required. 11 not squired, chock hero ? ?
14 Other gains or (losses). Attach Form 4797 . . . . . . . . . .
If you did not tee Total IRA d-tnbutions , 1SA I I b Taxable amount (we page 23)
got a W-2.
see page 21. 16. Tome pensions and anfaxfias 160 - b Tamale amount (see page 23)
17 Rental marl estate. royalties, partnorehipe, S GGrporaliorS. trust., etc. Attach Schedule E
Enclose, but do 10 Fans income or (loss). Attach Schedule F . . . . . . . . . . .
not attach. any 19 tlnompioymem cdmpe roatien .
payment. Also,
please Use
20e
Social neeunty benCRli 1203 I 1 I b Tnxahle nmrwmt (Sew papa 25)
Form 10404. 21 Other income. List typo and amount (see pago 27) ....................................
22 • 'Add the amounts in the far daft column for final? through 21. This is vour total Income ?
No. N leer
cellars, an In
Win,
w to d rah 1n
• you net Rte to "
or s oar am"
(see page 2e1
ctNAd.m an In
not aatand Afton
awae
e red on,
11Mf above '•
23 IRA deduction (sea page 27) . u
Adjusted 24 Student ban interest deduction (doe pogo 281. . . ,
Gross 25 Archer MSA deduction
Attach Form 8353 24
2r
.
. . . .
.
Income 26 Moving expenses
Attach Form 3903 26
.
. . . . .
Anacn Schedule SE
27 One-half of self-emplcymant tax 27
.
.
11m hlaurance deduellon Nw page 30)
28 Self-employed ne 2a
t
.
29. Seit-emplcyeo SEP, SIMPLE;. and qualified plans
witted:awel of savings
30 Penton
, on earl
.
y
y
paid bRecioiem's SSN ? -- /-• i /r'' OS'R'a
31a
Alimon
310
y
.
s 23 through Sea . . .
32 Add Ilne
.
. . .
.13 Subtract line 32 from line 22. Thus is our adjusted rose
me 33 77,;?,?
I
For Disclosure, Privacy Act, and Papmwork Reduction Act Notlee, we pogo 72. Qt No.12--W. Fenn 040 (2001)
oepunrr.nt of rtw T,eawry-Imaw,N Revinu4 rXrvln
For e. ywr Jw. I-DM aL 2001, a rnroe La. m? "ir" _
Your (rat rams and W1181 left nrvne
"h r;.S l-ohe,-r
/t cl-L
It a 141n[ rerun, pduae 5 foal name 8ntl IntnM , Leai n1m1
.20
Your aordat security nsw
Spouelr aodni ttncurity number
? Important!
You must enter
your SSN(s) a0m.
Home aneteos (mlrnhtr and soeutl. It you have n In 0. Lot. tau wvu 19. I Apt. na.
/// .5i).r/r .y /c(n?.
cry, fawn a poor otru{;6tm, and 'Jp cotln it you Rue n lawgn ndd,., ..• pago to
Note. 6t+hcking -Yee' will not change your tax or reduce your rotund.
Do you. or your spouse if riling a loins ratum, want £3 to go to this fund?
1
2
3
4
fi
8a
h ? Spouse
c
Single
Marnod filing joint return (even it only ono had income)
Martine filing separate return Enter spouse's social oeclattv re. above and hdl name twc.?
Head of household (with qualifying person). (See pago 19.))f Iho qualifying person is a child but not your dependent,
enter this child's name hero. ?
Ouaf fymg widow(or) with dependent child (year spouse dicd ? ). (Son pnryl IQ) _
Yourself. If your parent (or someone also) can claim you as o dopondont on his or her tax No. of boxer
mtum, do not crack box w . . . . . . . . . . . .. . . .1 crowd on J
w mw bar _L
1
06130/2002 02:10 7176917686 CHRIS B_ELIEU
PAGE 02
par, 16x0 (20011
t
Tax and 34 An1Ount frm Ilan 33 (ndjuslW 0mca inccmo}
Crodits 35 8 Chnxk 11: ? You were 65 or older. 0 Blind: ? Sperm wos 65 or plant. ? Rand.
a
= Add the numbM of boxon checkud anove and enter the to'nt fare . . . , ? 330
1
. b d you Oro Mauled Ming sozar t'l find your ?pou5e iterni:eo d,ductlons
pr
for-
• People vm
u t ,
you wue a duW-5 aius alion. edx 33b (J
pilot 31 and cheek hero
chcclwd any
a6 .
ftemtACd daduedons (hem fschedulu A) or your standard deductlian (see 1611 margin)..
bon c, Gnv ?37
352 u 35b er Subtract line 36 from lino 34 , -
. .
.
'
My -, be
I 38 .
_
` ..
If line 34 is 499,726 or less, multiply 32,900 try rho Wild fxantwr of eaernpllors claimed an'
c
.lr i xi as a
rhiptil dani,
I .
lino 6d. If lino 34 ie over 609,725, sa+ rra wort,+h n g
o.,t on 1 n :12
li page 31. 138 Taxable Income, Subtract Ron 38 from line 37. If line 38 is mend than line 37, enter.
• Ail orhun' 40 Tax (pee gaga 32). Check if any lax L, Perri a 0 Form(s) 6814 b 0 Form 4972 .
j 34,550 i di Altonlndve minimum tax (sae page 34): Attam-Foun e251 . . . ,
Head ct 42 Add fiats 40 and 41
.
? ? ? ? -
i hpov..hold, 43 f ctu9on lax natal. Attach Form 1116 if reclulrod 47
58 650
tAemad hurw3 44 Crilil for chiid and as
uerrJent taro nrpcnsrs. Attadt form 2441 ?
ntty or
Jifie 45 Credit for the aldery or the Aisanfxf. Attach SchedWO R
45
ludi'l lj 140 .
EducuUon c odds. Allacn fort, 6063 . . . . . . . .
,
' $7,600 47 Rxe reduclicn erupt Saa tin wonieai on page 36. . .
A7
Blamed 46 .
Cn'4d tax aedl (sao page 37) . . . 48.1
Ming
sep urru*. 40 ,
AdpplWn crotl4. Attach Form 8839. , 49
39.800 50 Other credits from: 0 0 Form 380D 4 0 Form 8386
cl Form 8801 d 0 Form (lgprrlty)_-___ 5D G
51 Add lines 43 through 50. These are yet total credits
52 Subtract We 51 from line 42. It line 51 i5 man than fin
42
d
, enter -0• . ?
Other 53 S---ii loyment tax Attach Schedule SF. , , , , , . . .
Taxes 54 Social security and I.tod;coro rill on tip intones not roponocl to 2mplo7rr Auto Form 4437 ;
W Tax on duailifv.d parts, norlidxp bill =0 Mar tax-favored account;. Attach Foml 5320,f radial ;
•;
56 _
Advance eammd a came credit payments from Fom(s) W-2. l
57 Household empioymont taxes. Affect) Schedule H I
58 ;.*
Add Polls 52 through 57. This In your total tax
Payments 59 Federal Income tax withhold from Forms W-2 and ;094 , 58 .
2 W 20Dt aurn7he0 tax li3y4nrnG and a'Ir ,t aop5ed from 2009 return 60
g ave a
m%fyi Mit Earned Income credit (BC) . 611
E
n
al h ftontaxable eafnIXl Income 81h
C EIC. 02 6ceew noclnl security and RMA tax withMld (coo page 51) /
63 Additional child tax credit. Attach Form 8812 . . 63
W Amount paid rvnh raguest for extension to fie (sea page 51) 64
65
66 Other paymer ls. Check if (tart a 0 Forth 2439 b 0 Farm 4138
Add H
l 05
i
l" 59, 60. 61 a, and 62 through 65. Flies el are our total paym ents - - . ??•. •) 6
Refund 67 If Tine Fib Is, more than I'm 58, suorract 1lnn 56 from ono 66. This 13 the amount you overpaid 6
Dvert 6aa Amount of Man 67 you want refund
6
- ., ....
d
to year
I. 6E
depose? Soo ?
pace 51 and to -
1
-
?
_
Roudrlg numbs LL I L I I I I I I t 0 T -0 0 savings
YDC:? (31eckr
flu in 58b. l- d Account Muroran I /
= '
Sac. and W.
00 .•.
Amdm MXnwnY.,nu...,,..,....?r_w ._.._.... w,.n.. __..-_-_.. - __ .'•'
runuum 70 Amourt you owe. Subtract lino 88 from fine 58. For details on Ibvit i pay, sae pogo 52. ?•',•.. 7.. i
Yeu Owe 71 ECimated tax tonally Also Include on Rea 70 I • - / ?
Third Pa Cb you watt to agow another person to dreu? tlaa ratum vntrl thaw IRS one
Party t Face 520 ?'.Ves;:(,pmpfq((x?hL Io1?.??
Designee Dest4rruB's Phana Pnecnet ile.ih:caibn ri•:• 'B'%F'; _!:,
name ? no. Ir f ) tdraingper
Sign Jnds Da vD ev a Perpxy, I oectirv that I here examhed too roam and oceartreanyr+g B r a ka 2rU n hemm a .wa to p Cyd;Br yi, c o+ e6
Here tra ' M" ale bud, coil gild camwe. Docuretvn et pepna fake than taxptytn 13 txuw on nut i o a M of which p jyjgwy
Joint return? Your signature Dale Your rcupattin I Dsyumee poem, number
Sea page 16.
hoop a copy - 0.;+ ?C) (` -s
fayour 5neu IgM2 x p tw t born t gn. U- r 7/71 ?11hll,
mus Mooing. I Paid a eperor's
Preparer's > g aturn
'
Use Onty Flrm
s Mama (a
younc IT nalf r.byndl
addteaa lino Z'P cNB
'n 4 aowlnn,rn PYm+y Ol"t, Mpf - .,7e.53
X
06/30/2002 02:10 7176917696
CHRIS BELIEU
SCHEDULES ABrB Schedule A--Itemized Deductions
(Form 1040) -- I (Schedule B Is on back)
p,prt,m.ar d „e Tnnv a 111 P. Attach to Form 1040. "* arr. Imsmlcliano for 8chodulen A and 9
Namut?) fMUm an Farm 1043
Medical 1
and
Dental 2
Fxpenaes 3
4
Taxes You
paid 6
(See 7
DaOe A•2.) 6
interest 10
You Pald 11
(See
A-3.)
or paid by others
1"
Caution. Do not include expenses reimbursed . "
Medical and dental expenses (see page A•2) . .
Enter amount from Form 1040. fine 34. 2 1 3
Multiply line 2 above by 7.50/b (.075) . '
it line 3 is more than line
Slate and local income taxes . , •
Real estate 10x05 (seo page A-2) , , • . • • .
personal Property taxes . • . • • • '
Other taxes. List type and amount ? ....................
............................
Add lines 5 thmu h-8 . '
Home mortgage interest and paints Wetted to you o 1For 1Fl p aid
Home mortgage interest not reported ? On Form 10"' It A-3
to the person from whom you bought and BOB M A-
and chow that person's name, identifying era
....................
Points not loportod to you on Form 1098. See P g
for Special rules. . • • • ' ' , uirod .
Investment Interest. Attach Form 4952 4 reQ (5e6
page A-3.)
Add lines 10 ftaouah 13 Ift of 5250 or
Gifts by cash or check. a you made any g .
more, see page A-4 . • • • , . '
Other than by cash or chack. If any grit of 5250 or more,
see page A4. You must attach Form 82831f over $500
7 Carryover from prior year , . • . . . ' -
a 16munh 17 .
Note.
personal 12
interval is
not
deductible. 13
alf'b to is
Charity
if you made a 16
get and got a
benefit fir d, 1
see page A-4. 1E
Theft arises 19 Casutrtty or mart ,??1?,,. • -
20 Unreimbursed employee expenses-lob travel, union
Job Expenses dues lob education. etc. You must attach Form 2106
and htttst A•5.) ? ..-...
,
Omer or 21OG-EZ it inquired. (See page
.............................
N1lscailaneous •••••--
Deducliofts
21 Tax preparation tees .
(Se 22 Other expenses-investment, safe deposit box. etc-t-lst
a . ..... .........................
papa A•5 for type and amount ?.........-
...........
........................................
expenses to
Deduct noro.)
, q? I_
23 Add lines 20 through 22 • - • . 24
24 Enter amount Its form 1840. 2%-0?`- / -
25 Multiply ene 24 above by of tt fine 25 is more than tin
-• IC}
PAGE 03
OM/D NO. 1615 Oa F+
Uoo? l
AnxGxnOnl I
soauenca No. 07
Your "cut nta,mty
7
26 Subtract line zo „ -.-. --
....'.
rom list on Papa A List type a amount ? ........................
... ................
Olhar 27 Other- f , ........
................. .. .
.................................
Mlsealiuneaus ................................. alely)?
Total 2a
itemized
Deductions
132,950 (over $66 ,475 if marned filing Soper
1040, line 34, over $
in the far right column
Is Form
No. Your seduction Is not limbed. Add the amounts 10ro, line 35.
Porter
for lines 4 throngn 27. Use, enter this amount on Yee. A-6 for the ortwum to enter.
Your deduction may be limited. See Daga
?
0172
?
schodule A (Fenn 1040) 2001
Cat. No rS
For Paperwork Roduction Act Notice, see Form 1044 I" t uctions.
CHRISTOPHER M. BeLIEU,
Plaintiff
VS.
FIONA J. BeLIEU,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 6877 CIVIL
IN DIVORCE
ORDER OF COURT
AND NOW, this N day of
2003, counsel having advised the Master's office by
correspondence on September 26, 2002, that the above
captioned case settled, and no agreement having been
provided the Master's office, the appointment of the Master
is vacated.
BY THE COURT,
cc: Alizabeth B. Stone
Attorney for Plaintiff
Carol J. Lindsay
Attorney for Defendant
GekArH ke J.
L -(r? RKS
oy -ly u4a,
CF ^?"PRY
03 PI 1 ? i 2: 22
PRMYLVANIA
?k`