HomeMy WebLinkAbout99-07037
0
C1
?` • LISTING CONTRACT XLS
EXCLUSIVE RIGIIT TO SELL REAL PROPERTY
This farm recommended and approved for, but not restricted to use by the members of the Pennsylvania Association of REALTORSO (PAID.
I BROKER (Company)
2 LICENSEE(S) , d 2
a SELLERr f = C?f7/1'rl
a
s 1. PROPERTY
4
LISTED PRICE $ .52OC7 a a
6 Address e /' 6 s
6
7 Municipality (city, borgygln, township)
s County (' ?j Jm Ra-f A 1) School District AJ G e
9 Zoning and Present Use
16 Identification Number (For example, tax identification number; parcel number; deed book, page, recording date) 9
1e
n
It 2. STARTING & ENDING DATES OF LISTING CONTRACT (also called "Term") 11
12
u A. No Association of REALTORS0 has set or recommended the teml of this contract. By law, the length or term of a listing u
la contract may not exceed one year. Broker and Seller have discussed and agreed upon the length or tern of this contract. 14
1s B. Starting Date: This Contract starts when signed by Broker and Seller. u otherwise stated here: 15
16 C. Ending Date: This Contract ends on P / 1
17 6
/
1e 17
19 le
zo 3. PURPOSE OFTHIS CONTRACT Seller is hiring Broker to market Property and to find a buyer. Seller will refer all offers 19
20
21 and inquiries to Broker. Seller allows Broker to use print and/or electronic advertising, including interior and exterior 21
22 photographs. Broker is acting as Seller Agent, as described in the Consumer Notice
.
23 4. BROKER'S FEE No Association of REALTORSm has set or rccommeyde?the Broker's Fce. Broker and Seller have 22
23
24 negotiated the fee that Seller will pay Broker.The Broker's Fee is a of/from the sale price and 2e
25 paid by Seller.
26 S. COOPERATION WITH OTHER BROKERS Licensee has explained Broker's company policies about cooperating with 26
26
27 other brokers. Broker and Seller agree that Broker will pay from Broker's Fcc a fee to another broker who procures the buyer 27
,
2e is a member of a Multiple Listing Service, and who:
29 A. represents the Seller (SUBAGENT). r.7 2e
ao 0 No s If Yes, amount: of/from the sale price. 29
31 B: represents a buyer (BUYER'S AGENT). A Buyer's Agent, even if compensated by Broker or Seller, will represent ao
22 the interests o he buyer. ,.7
0
21
i- 31
32
as
l
No Yes If Yes, amount: /o of/from the sale price.
36 C. does not reprwnl either the Seller or a hu ei- RANSACTION LICENSEE).
'
0 77
74
No 4t]
as
Ycs If Yes, amount: n of/from the sale price.
76 6. PAYMENT OF BROKER'S FEE a6
37 A. Seller will pay Broker's Fee it Property, or any ownership interest in it, is sold or exchanged during the term of this 36
3e Contract by Broker, Broker's agents, Seller, or by tiny other person or broker, at the listed price or any price 37
a
39 acceptable to Seller. e
49 B. Seller will pay Broker's Fce if negotiations that are pending at the Ending Date of this Contract result in a salt 39
.
a C. Seller will pay Broker's Fee of er the Ending Date of this Contract If? ao
a (1) A sale occurs within 490 days of the Ending Date, AND 41
as (2) The buyer was shown or negotiated to buy the Property during the term of this contract. 42
al Seller will not owe Broker's Fee if the Properly is listed under an "exclusive rigid to sell contract" with another 17
as broker at the time of the sale. 44
46 7. BROKER'S FEE IF SALE DOES NOT OCCUR as
e7 A. Seller will pay Broker's Fee if a ready, willing, and :1171e 171ycr is found by Broker or by anyone, including Seiler 46
.
ee A willing buyer is one who will pay the listed price or more for the Properly, or one who has submitted an offer accepted 42
ae
/9 by Seller.
sa B. If the Propcrtko?ny part of it is taken by any govemmclll for public use (Eminent Domain), Seller will pay Broker /9
st o OEM= any money paid by the government. Sit
52 C. If a buyer signs an agreement of sale then refuses to buy the Property, or if a buyer is unable to buy it because of failin st
g
sa to do all the thiDgS required of the buyer in Ilse agreement of sale, Seller will pay Broker:
?z !
1
' 52
53
of/from buyer
se (
)
s deposit monies, OR
ss (2) the Broker's Fee in Paragraph 4, whichever is less. 5a
56 g• DUAL AGENCY Seller agrees that Broker may also represent the buyer(s) of dre Property. Broker is a DUAL AGENT 66,
57 when representing both Seller and the buyer in the sale of a property. 56
se Designated Agency: 57
59 l Applicable. se
66 Applicable. Broker may designate licensees to represent the separate interests of Seller and the buyer. Licensee (identi- e9
61 fled above) is the Designated Agent, who will act exclusively as the Seller Agent. If Property is introduced to the buyer 60
61
62 by a licensee in the Company who is not representing the buyer, then that licensee is authorized to work on behalf of Seller
.
63 If Liccnsce is also lire Buyer Agent, then Licensee is a DUAL. AGENT 52
.
64 9. BROKER'S SERVICE TO BUYER Broker niay provide services to a buyer for which Broker may accept a fee
Such 6a
61
.
65 services may include, but are not limited to, tlced/documcnt preparation; ordering certifications required for closing; financial 65
66 services; title transfer and preparation Services; ordering insurance, construction, repair, or inspection services. Broker will 66
57 disclose to Seller if any fees are to be paid by Buyer.
Be 10, OTHER PROPERTIES Seller agrees that Broker may list other properties for sale and that Broker-may show other prop- 67
6e
69 erlies to prospective buyers.
70 if. CONFLICT OF INTEREST A conflict of interest is when Broker or Licensee has a financial or personal interest where 69
70
71 Broker or Liccnsce cannot put Seller's interests before any other. If Broker, or any of Broker's salespeople, has a conflict of 71
72 interest, Broker will notify Seller in n timely manner.
_ 72
73 Seller Initials Page I or 3 Braker/Licensee Initials 73
Psnnsylvanla Association of COPYRIGHT PENNSYLVANIA ASSOCIATION OF REAI.TORSm 1996
RS01
U
®
REA
U
Nww uW?r?rr 60Vx1
`1e 12. SETTLEMENT & POSSESSION / / 74
75 A. Preferred Settlement Dale: U ,;,/) r?E 75
76 B. Scllcr will give possession of the Properly to Buyer at settlement or oil 16
77 C. (1) If Ilia Property, or any part of it, is rcnted, Scllcr will give any leases to Broker before signing this Contract. 71
7e (2) irony leases are oral, Seller will provide ;I written summary or the terms, including amount of rent, ending date, and 78
79 Tannin's responsibilities. 71
80 (3) Seller will not abler into or renew any lease during the term of this Contract except as follows: e0
at 81
at 13. TITLE 87
93 A. At settlement, Seller will give full rights of ownership (fee simple) to it buyer except as follows: 07
e4 ( I ) Mineral Rights Agreements at
e5 (2) Other e5
B. B. Selas:
y w f
I? afi
at
e7 Yes ? No Mortgage %v h
E
Be Address Phone
e9 I
Acct. H Amount of balance $ e9
9o Lr Ycs ? No Equity loan with 90
91 Address Phone 91
92 Accl. it Amount of balance $ 97
93 Ycs ? No Seller authorizes Broker in receive mortgage payoff and/or equity loan payoff information from 93
94 the lender. 94
95 ? Yes ? Past Due Taxes Amount owed $ 96
96 ? Yes E No Judgments Amount $ 96
91 Type 91
9e ? Yes No Municipal Assessments Amount $ 9e
99 ? Yes ? No Othcr 99
100 Amount $ 100
101 C. If Seller, at any time on or since January 1, 1998, has been obligated to pay support under an order that is on record in any tat
102 Pennsylvania county, list the county and the Domestic Relations Number or Docket Number: 107
107 Id. MULTIPLE LISTING SERVICE (NILS) (Complete if Broker is a member of an MLS) 103
m4 ? Broker will use a Multiple Listing Service to advertise the Property to other real estate salespersons, who can tell their lot
105 clients and customers about it. Seller agrees that the NILS. the Broker, and the Licensee arc not responsible for mistakes to$
106 in the MLS description of the Property. 106
101 ? Broker will not use a Multiple Listing Service to advertise the Property to other real estate salespersons. 107
toe 15. PUBLICATION OF SALE PRICE 100
109 A. Seller is aware that newspapers may publish the final sale price after settlement. 109
ro B. Scllcr will alto publishing of the sale price after Seller accepts an Agreement of Sale. 110
111 ? Yes No III
ut 16. SIGVS & KEYS Seller allows (where permitted): 117
I? B -Yes ? NgiSale Sign 0"Yys• ? No Sold Sign
- 1n
114 ice es ? No Lock Box
? Yes a Key in Off III
115 ? Yes ? No 115
n6 17. ITEMS INCLUDED IN THE PRICE OF THE PROPER'T'Y 116
117 A. Included in the sale and purchase price are all existing items permanently installed in the Property, free of liens, including n1
118 plumbing; healing; lighting fixtures (including chandeliers a nd ceiling fans); water treatment systems; pool and spa equipment; lie
119 garage door openers and transmitters; television antennas; shrubbery, plantings, and unpotted trees; any remaining healing and 114
1111 cooking fuels stored on the Property at the time orseulement; wall to wall carpeting; window covering hardware, shades, and vn
171 blinds; built-in air conditioners; built-in appliances, and the range/oven. Also included: 121
172 172
173 B. ? See attached shoat for additional items included in the sale. 113
124 18. ITEMS NOT INCLUDED IN THE PRICE OF TILE PROPERTY 174
1?5 The following items are not included in the purchase and price of the Property: 175
176 A. 126
171 nil
178 B. Items retired by the Seller Ila
129 C. ? Sec attached sheet for additional items not included in the sale. 179
130 19. SELLER WILL, REVEAL DEFECTS & ENVIRONMENTAL HAZARDS 13n
131 A. Seller (including Sellers exempt from the Read Estate Seller's Disclosure Act) will disclose all known material defects u1
132 and/or environmental hazards on a separate disclosure statement. A material defect is a problem or condition that: 131
133 (1) is a possible danger to those living on the Property, or 1.33"
134 (2) has a significant, adverse effect on the value of time Property. 1.11
135 B. If Seller fails to tell of known material defects and/or environmental hazards, 115
135 (1) Scllcr will not hold Broker or Licensee responsible in any way; 136
(2) Seller will protect Broker and Licensee from any claims, lawsuits, and actions that result; 131
131 (3) Seller will pay all of Broker's and Licensee's costs that result. This includes attorneys' fees and court-ordered pay- 1,1
138 rents or settlements (money Broker or Licensee pays to end it lawsuit or claim).
117 20. 111 PROPERTY 1VAS IIUII.T IIEFORE 1978 The Residential Lead-Based Paint Hazard Reduction Act says that any Scller
uo of property built before 1978 must give the buyer an EPA pomphlct titled /'rntect Your Fnmity From Lead in Your Hon1e. The
'
141 he' Scllcr knows about lead-based paint and lead-based paint hazards that
Seller also must tell the buyer and the Broker what [lie 141
1'11 arc in or on the property being sold. Scllcr must tell the buyer how the Seller knows that Icad-based paint and ]cad-based paint t47
1'1.1 hazards are on the property, where the lead-based paint and lead-based paint hazards are, the condition of the painted surfaces.
141 and any other information Seller knows about lend-based paint and lead-based paint hazards on the property. Any Seller of a 11 t
145 pre-1978 structure must also give the buyer any records and reports that the Seller has or can get about Icad-based paint or
lab lead-based paint hazards in or around the property [icing sold, the common areas, or other dwellings in multi-family housing,
141 According to the Act, a Seller must give a buyer 10 days (unless Scllcr and the buyer agree to a different period of time) from 1 a
1te the time an Agreement of Sale is signed to have a "risk assessment" or inspection for possible Icad-based point hoards done 'is
lag on the property. Buyers may choose not to have the risk assessment or inspection for lead paint hazards done. If ilia buyer 119
15o chooses not to have the assessment or inspection, the buyer must inform the Scllcr in writing of the choicet The Act does nor Isit
151 require the Scller to inspect for lead paint hazards or um correct lead paint hazards on the property. The Act does not apply to to
157 housing built in 1978 or liter. 152
153 Seller Initials Page 2 of 3 Broker/Licensee Initials 151
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21. DEPOSIT MONEY 154
A. Broker, or any person Seller and the buyer name in the Agreement of Sale, will keep all deposit monies paid by or for the Iss
buyer in an escrow account. If held by Broker, this escrow account will be held as required by real estate licensing laws 15a
and regulatinns. Seller agrees that the person keeping the deposit monies may wait to deposit any uncashed check that is 1s7
received as deposit money until Seller has accepted an offer. Ise
B. If Seller joins Broker or Licensee in a lawsuit for the return of deposit monies. Seller will pay Broker's and Licensee's 159
attorneys' fees and.costs. 160
22. RECOVERY FUND Pennsylvania has a Read Estate Recovery Fund (the Fund) to repay any person who has received a final 151
court ruling (civil judgment) against a Pennsylvania real estate licensee because of fraud, misrcpresenmtion, or deceit in a real 167
estate transaction. The Fund repays persons who have not been able to collect thejudgment after trying all lawful ways to do 167
so. For complete details about the Fund, call (717) 783-3658, or (800) 822.2113 (within Pennsylvania) and (717) 783.4854 154
(outside Pennsylvania). 165
23. TRANSFER OF THIS CONTRACT 166
A. Broker will notify Seller immediately in writing if Broker transfers this Contract to another broker when: 167
(1) Broker stops doing business, OR 168
(2) Broker forms a new real estate business, OR 159
(3) Brokerjoins his business with another. 170
Seller agrees that Broker may transfer this Contract to another broker. Broker will notify Seller immediately in writing 171
when a transfer occurs or Broker will lose the right to transfer this Contract. Seller will follow all requirements of this In
Contract with die new broker. 177
B. Should Seller give or transfer the Property, or an ownership interest in it, to anyone during the term of this Contract, all 174
owners will follow the requirements of this Contract. 175
24. NOTICE TO PERSONS OFFERING TO SELL OR RENT HOUSING IN PENNSYLVANIA Federal and state laws 176
make it illegal for a seller, a broker, or anyone to use RACE, COLOR, RELIGION or RELIGIOUS CREED, SEX, DISABI- 177
LITY (physical or mental), FAMILIAL STATUS (children under 18 years of age), AGE (40 or older), NATIONAL ORIGIN, v0
USE OR HANDLING/TP AINING OF SUPPORT OR GUIDE ANIMALS
or the FACT OF RELATIONSHIP OR ASSOCI In
,
-
ATION TO AN INDIVIDUAL KNOWN TO HAVE: A DISABILITY as reasons for refusing to sell, show, or rent properties, too
loan money, or set deposit amounts, or as reasons for any decision relating to the sale of property. lot
25. NO OTHER CONTRACTS Seller will not enter into another listing agreement with another broker chat begins before the 107
Ending Date of this Contract. 107
26. ADDITIONAL OFFERS ONCE SELLER ENTERS INTO AN AGREEMENT OF SALE, BROKER IS NOT REQUIRED 184
TO PRESENT OTHER OFFERS. 185
27. ENTIRE CONTRACT This Contract is the entire agreement between Broker and Seller. Any verbal or written agreements 186
that were made before are not a pan of this Contract. 107
28. CHANGES TO THIS CONTRACT All changes to this contract must be in writing and signed by Broker and Seller. lee
29. SPECIAL INSTRUCTIONS The Office of the Attorney General has not pre-approved any special conditions or additional 189
terms added by any parties. Any special conditions or additional semis in the Contract must comply with the Pennsylvania 19a
Plain Language Consumer Contract Act. 191
192
193
ADDITIONAL INFORMATION (OPTIONAL) 194
195
30. TAXES, UTILITIES, & ASSOCIATION FEES
A. At settlement, Seller will pay one-half of the total Real Estate Transfer Taxes, unless otherwise stated here:
B. Real Estate Property Tax Assessment $
Wagc/Income Tax
C. Estimated Utilities (trash, water, sewer, electric, gas, oil, etc.)
Yearly Taxes $
Per Capita Tax
D. Association Fees $ Include:
E. Other
31. BU R FINANCING Seller will accept the following arrangements for buyer to pay for the Property:
Cyyr?h
12' yer will apply for a mortgage. Typc(s) of mortgages acceptable to eller arc:
? D No Conventional D Yes o FHA
&fes D No VA D Yes D No
D Seller's help to buyer (if any): _
212 Seller has read the Consumer Notice as adopted by the State Real Estate Commission at 49 Pa. Code §35.336. 217
213 All Sellers must sign this Contract.
214 NOTICE
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226
227
728
229
230
SELLER 4 t-JA
Name (print) _
Mailing Address
Phone Us _
SELLER X
Name (print) _
Mailing Address
Phone Hs
BROKER (Company Name)
ACCEPTED BY
Mailing Address
Phone Hs
DATE 225
FAX It
FAX 11
213
L QUESTIONS, SELLER IS ADVISED TO CONSULT AN ATTORNEY. 214
C7 DATE // 2 f O 215
SSH 716
E-Mail 216
219
DATE 220
SSk 221
222
E-Mail 723
224
FAX It E-Mail
2:e
229
Page 3 of 3 230
?•?5•02 ?
Ho>IESAIJ! SERVICES
GROUP
November 16, 2001
Dear Rob,
R IIROOKWOOD AVENUr. SUITE A
CARLI5I V, P:1 (7017
BUS. (717) 245.2100
PA. (717) 245.0687
E-MAIL iraivcBhnnms,,Ic.com
The first 2 listings are not good comps. I just wanted to show that even big
houses in high-end neighborhoods do not sell much over $300K in our area."
When doing my search. I didn't use any maximum price and these are the ones
that came up.
Listing #4 is also prime area. 45 is probably our best comparable. 96 shows that
even a new house (lot is 12.6 acres) sells for under $300K. Numbers 7 - 10 are all in the
Mechanicsburg area.
Please call me when you receive this with any questions you might have.
Best wishes,
Ginny Mowery
r
FOP. OVER 90 YEARS. ? AIARISO REAL ESTATE REAL EASY."
PETITIONER<5.;.
EXHIBIT
4.15.02 L-a
Each Office is Independently Omed Ard ODerated.
V 1J
f/
LN: 10024342 1 Single Family FULL Format PT: SF / SPT: SF -+
-----------------
--------------------------
ST: SETT LD: 11/28/97 LDR: 12/11/97 List Price: $ 379000 1
I MT: 735 OMD: 12/03/99 XD: Orig Price: $ 465000 1
I UD: 02/08/00 CLD: 02/04/00 FC 1 Sale Price: $ 295000 1
I SO: RSR SA: 63505 SA2: Cntr Price: $ I
I SAC: 2.5 BAC: 2.5 OAC: TLC: LT: ERS i
----------------------------+
I Address: 2 MEADOW VIEW CT
City: MECHANICSBURG State: PA ZI? Code: 17055-
Subdivision: PENINSULA Area: 6
Map Page: Map Coords: I
County Code: CUMB Prop ID No: 00
1 Municipality: SILVER SPRING
I
IRoad Frontage:
-----------------------------------+
----------------------------------------
I Remarks: SOUTHWESTERN COUNTRY-CONTEMPORARY IN CUMBERLAND VALLEY I
1 SCHOOLS. MAGNIFICANT HOME-A-RAMA HOME W/DRYVIT, STONE & I
1 CEDAR. 1200 SQFT WRAP-AR. BEAUTIFULLY APPOINTED CONTEA?PORARYI
STONE, WRAPAROUND MAHOGANY VERANDA. COURTYARD OUTSIDE W/FPLCI
1 LGTHNG. INTERIOR EXQUISITELY FINISHED 2/HDWD FLRS, GRANITE I
COUNTRS S ND GLSS WIND. HOME-A-P.AMA "C7%TL1EYT." I
------ ---------------------------------+
I SA Show Instr: CALL LIST OFFICE,CALL LI* Lock Bor. Desc: CPLB I
I BA Show Instr: CALL LIST OFFICE,CALL LI* Occupied (O/T/V): ------+
-------------------------------------------------------
Photo Code: PHOTO TAKEN
I Photo Instr:
_ _ _ _ --------------------+
I List Office: RSR Name: P.OTHMAN/SCHU BERT Phone: 717-763-1212 1
I List Agent: 64129 Name: ROTHMAN, GREG Phone: 717-761-1212 11
1 List Agent Voicemail: 558-7016
I List Agent EMail: WGreg1966@AOL.COM Phone:
I List Agent2: Name: Owner Name: Owner Phone: i
I
I Directions: CARLISLE PIKE, N/SAM?LE BRIDGE, R/BRIDGEPORT, L/MEADOWVIE4I
I Directions2: TO HOME.
Possession:
----------
----------------------------------
Acres: 0.59 1
1 Tot Square Feet: 3700 Source: MEASURED 1
I Lot Dimen: Lot SgFt: 25513
Prepared by: G(nny Mowery on November 15, 2001
. I
( New Construction: C -------
-------------------------------- ( No Rooms. 11 Full Baths: 2 Spaces (Covered: 1 Uncovered:
I No Bedrooms: 4 Half Baths: 1 No Fireplaces:
I Year Built: 1990, Other Baths: Warranty:
I No Stories: 2.0 Tot- Baths: 3 HandiCap Modified: -----------+
-----------------------------------
Full Bath Level: U/M
Half Bath Level: 14
-----+
---------------------------------------
+---------•---------------------
Information Deemed Reliable But Not Guaranteed. ?age 1 of 2
LN: 10024342 1 Single Family FULL Format ----- PT: - SF / SPT - SF
+-----+----------------------------------------+
I Rm NameI Dimen ILevell Desc -----------------------------------------+
+--------+-----------+-----+------
I Liv 117'8X15'6 I M I FIREPLACE,WOOD FLOOR
I Din 110'4X11'9 1 M I WOOD FLOOR
I Fam 118'X1316 1 M i CEILING FANS,WOOD FLOOR, BALCONY/ DECK
I Den I I
I Kit 111'X13'2 I M I WOOD FLOOR
I' Mbr 1 12'7X15'4 1 H I WALK-IN CLOSET,WALL TO WALL CARPET, BALCONY/
I I I DECK
I BR1 115/5X12/7 I U I WALK-IN CLOSET,WALL TO WALL CARPET I
I BR2 11217X13 I U I WALK-IN CLOSET,WALL TO WALL CARPET I
BR3 115'4:14'1 1 U i CEILING FANS,'WALL TO WALL CARPET
I BR4 I I
I OR1 MEDI 1514X2116 I U I WALL TO WALL CARPET 1
I OR2 FOYI 6'6X2216 I M I
---------------------------+
I OR3 LOFT 815X7'6 I U I WALL TO WALL CARPET
----+-----+--------------------
I HO Assoc (Y/N): N Assoc Fee Incl:
I HO Assoc Fee:
--------------------------------------------+
=--------------------- ---------
I Tax Amount: Disclosure Form: Y -------+
-----------------
I Tax Year: 1995 ----------------1
---------------------------------------------------
I School District: CUMB
-----------------------------------------------------------------+
r Icc Financing: CONVENTIONAL, CAS?1
I Amenities: GOLF COURSE,CLUB HOUSE 1
I Appliances: MICROWAVE,REFRIGERATOR
1 Basement: FULL
I Construction: FRAME
I Cooling. CENTRAL AIR
I Electric: 200+ AMPS
Equipment: CENTRAL VACUUM,SMOKE DETECTORS, WHIRLPOOL/ HOT TUB,GARAG*
I Exterior: CEDAR,ST000O,STONE
Exterior Feat: PORCH,2RTIO,DECK,LANDSCAPED
Fence Desc: NONE
I Flooring: WALL TO WALL CARPET,WOOD,TILE
I Foundation: 1
I Heatina: FORCED AIR,GAS
I Interior Feat: PATIO DOORS,WET BAR,WALK-IN CLOSET S, SKYLIGHT, VAULTED C*
I Lot Desc: LEVEL
I
I Miscellaneous:
I Other Rooms: AOTER,FORMAL DINING RM,BREAKFAST NOOK,LAUNDRY/UTILITY
I Parking:
I Roof: COMPOSITION
Style: CONTEMPORARY
Prepared by: Ginny Mowery on November 15, 2001
I Water Sevier: PUBLIC SEWER,PUBLIC WATER
I Waterfront: Desc: NONE
I Zoning: RESIDENTIAL
I Farms:
I Outbuild:
--------------------------------------------------------
Informat.i.on Deemed Reliable But Not Guaranteed
I
I
I
I
I
___________i.
Page 2 of 2
Prepared by: G1nny Mowery on November 15, 2001
1L?
LN: 10056940 1 Single Family FULL Format PT: SF / SPT: SF--+
------
----------
LD: 07/18/00 LDR: 07/18/00 List Price: $ 375000 1
I ST: SETT Ori Price: $ 375000 I
MT: 9 OMD: 07/27/00 XD: Sale Price: $ 350000 1
UD: 09/0i/00 CLD: 08/31/00 FC Cntr Price: $
I
SO: THOMP SA: 62262 SA2:
TLC: 3.0 LT: ERS I
I SAC: 3.0 BAC: 3.0 OAC: -----i.
---------------
-----------------------
i Address: 1540 FOX HOLLOW CIRCLE
I City: MECHANICS BURG State: PA ZIP Code: 17055-
I Subdivision: HIGH MEADOW Area: 6
Map Page: Map Coords:
I County Code: CUMB Prop ID No: N
I Municipality: LOWER ALLEN
IRoad Frontage: _ _ --------------------+
+-------------
I Remarks: OUTSTANDING CONTEMPORARY W/INCP,EDIBLE VIEW-IMMACULATE I
MOVE-IN CONDITION,GRANITE FOYER, 2 STAIRWAYS, 5 FULL & 2 I
HALF BATHS, LOTS OF WINDOWS & CLOSETS, PRIVATE SETTING, Cpl-
GROUND POOL,TENNIS COURT, HDWD., TILE CORIAN,WET BAR,
CEDAR CLOSETS, 2 DECKS & SO MUCH MORE. SELLER WILL ENTERTAINI
ALL REASON BLE OFFERS. DON'T MISS TI?I:, ^i;?!
i -----+
I SA Show Instr: CALL LIST OFFICE,KEY IN * Lock Box Desc: Id0 LB
EA Show Instr: CALL LIST OFFICE,KaY IN occupied (O/T/V): V -----------+
----------------------------
1
+-------------
I Photo code: PHOTO TAKEN
I Photo Instr: -----------------+
---------------------------------
f I List Office: C21PI Name: C-21 PISCIONERI Phone: 717-737-5442 I
I List Agent: 64245 Name: THOMAS, SUSAN Phone: 717-761-5942
I List Agent Voicemail: 441-5410
I List Agent Et4a-1: Name: Phone:
List Agent2: Owner Phone:
1 Owner Name:
I Directions: 158 WESLEY EX.L/WESLEY, R/LISBURN, L/ FOX HOLLOW,L/HIGi1N1EADOrr1,R
I Directions2: FOX HOLL
I Possession: SETT -------- ------------------------+
------------------------------
+------------ i
Acres: 0.97 1
+_j 1
1 Tot Square Feet: 5202 Source: PUBLIC RECORDS
I Lot Dimen: Lot SgFt:
Prepared by: Glnny Mowery on November 15, 2001
mew construction: I
+-------------------
Full Baths:
5
paces (Covered: 2 Uncovered: )I
I No Rooms: 11
3 Half Baths: 2 2
Fi-r
I No Bedrooms:
Built: 1987 Other Baths: y: N I
o
Warranty:
I Year
0
2
i Tot Baths: 7 N
FlandiCa- Modified
--
.
es:
No Stor --- -- ------ ---------------
--
--------
--------------------- --------
Lull Bath Level: L&2
Half Bath Level:
- L&1
--------
--------
Information Deemed Reliable But Not Gua_an'eed. Pace 1 of 2
LN: 10056940 1 Single Family FULL Format PT: SF / SPT: SF
--------+
I Rm NameI Dimen ILevel! Desc ------__ ________+
-----
.I"_-------r
WINDOW TREATMENT, WALL TO {9A
I FIREPLACE
I Liv I 23X29 ,
I H
.BALCONY/DECK
I I CARPET
I I
113X19 ,
I M I WINDOW TREATMENT,WALL TO WALL CARPET,BALCONY/
I Din
124X27 I I DECK
I L I FIREPLACE, WINDOW TREATMENT,WALL TO MALL CARPETI
I Fam
1 9X11 I M I WINDOW TREATMENT,WALL TO WALL CARPET I
I
I Den
115X20 I M I CEILING FANS,CERAMIC TILE FLOOR,WINDOW
I Kit I I TREATMENT, DINING AREA,PANTRY
I
30
I 15X I U I SKYLIGHT, CEILING FANS,WALK-IN CLOSET,CED: R I
.
I Mbr I LINED CLOSET,W INDOW TREATMENT,WALL TO WALL
I CARPET 1
BR1 I
I BR2 113X17 I I
I L I WINDOW TREATMENT, WALL TO WALL CARPET I
I BR3 113X.17 I L I WINDOW TREATMENT, WALL TO WALL CARPET
BR4 I
I OR1 OFCI 13X19 I I
1 M 1 WINDOW TREATMENT,WALL TO WALL CARPET I
I OR2 LAU1 8X9 I L I VINYL FLOORING
WINDOW TREATMENT,WALL TO WALL CARPET,I
I M I SKYLIGHT
I OR3 MEDI 12X18 ,
I I BALCONY/DECK
I
------------------------------------------- - ------+
-----
HO Assoc(Y/N): N I
Assoc Fee Incl:
HO Assoc Fee: ----- __________+
-----------------------------
------------------- ------------
Disclosure Form: 'L
6493
Tax Amount: - --
r '
Tax Year: 99/00
____+
-----------------------------------
-----------------
I School District: W SH __________+
----------------------
___ _
I Acc-Financing CONVENTIONAL,CASH 1
I Amenities:
A
pliances: POOL,TENNIS COURTS
COUNTERTOP RANGE,WALL OVEN,INDOOR GRILL, MICROWAVE, DISH- I
ETE-
p
Basement: EXPOSED/WALKOUT, FULL, FINISHED, INTERIOR ACCESS, CONCR
I Construction: FRAME I
I Cooling: CENTRAL AIR,CEILING FAN
I Electric: CIRCUIT BREAKERS
SMOKE DETECTORS, SECURITY SYSTEM,GARAGE
CENTRAL VACUUM
I Equipment: ,
I Exterior: CEDAR,WOOD
EXISTING STORM WINDW,EX.ISTING STORM DOORS*
TENNIS COURT
Exterior Feat: ,
Fence Desc: WOOD,RAIL
WELL TO WALL CARPET,WOOD,CERAMIC TILE,VINYL
1 Flooring:
Foundation:
i CONCRETE I
HEAT PUMP, FORCED AIR, ELECTRIC
*
ng:
I Heat
ior Feat:
I PATIO DOOP.S,WET BAR,rWALK-IN CLOSETS, SKYLIGHT, ALL WINDO
nter
I
I Lot Desc: SLOPING, VIEWS, CUL DE SAC
Prepared by: Glary Mowery on November 15, 2001
w4
I
I Miscellaneous:
I Other Rooms: FAMILY ROOM, LIBRARY/STUDY, OFFICE /COMPUTER RM,REC/PLAY I
I Parking: PVD DR,ATT,2 CAR GAR,GAR
I Roof: COMPOSITION
I Style: CONTEMPORARY
I Water Sewer: SEPTIC, WELL i
I Waterfront Desc:
I Zoning: RESIDENTIAL
I Farms:
I Outbuild: _+
-----------------------
------------------------------------
Information Deemed Reliable But Not Guaranteed. Page of
Prepared by. Glnny Mowery on November 15, 2001
i
4
??Ll ?Iv
LN: 10071250 1 Single Family FULL Format PT: SE / SPT: SE
--- -------- ---- -------
+ LD 09/07/01 LDR: 09/07/01 List Price: $ 272000 1
I ST: "UCON prig Price: $ 272000 1
I MT: 11 Ot4D: 09/18/01 XD: Sale Price: $
1
1 UD: 09/24/01 CLD: FC
I
Cntr Price: $
SO: RMREAL SA: 60568 SA2: TLC: 3.5 LT: ERS I
I SAC: 3.5 3AC: 3.5 OAC: ------------------------------}
-------------------
+----------------------
86 OLD STONEHOUSE RD 17013- I
1 Address: 48B--
1 City: CARLISLE State: PA ZIP Code: 1
Area: 6
1 Subdivision: Map Page: Map Coords: I
1
County Code: CUN1B Prop ID No: 38-8-571-11A 1
1 I
I Municipality: SILVER SPRING
(Road Frontage: -----------------------------------}
+-------------
1 ACRES
Remarks: WTIH0EASYYJACCESSOTOFCARLISLE, MECHANICLEGANCE
I
I NEW OIL FURNACE TO BE INSTALLED, NEW TILE FL IN KITCHEN AND I
DINETTE AREA. NEW WOOD FLS IN UPSTAIRS BDRM. A BEAUTIFUL I
RAISED FIREPLACE IN LIV RM W/VAULTED CEILINGS OVERLOOKING I
WOODS. EXPERIGidCE PEACE & QUIET ON RAISED JC-PFEN Pn=:. I
__ _ ---------------+
---------------------------------
I SA Show instr: CALL LIST OFEICE,APPOINT* Lock Box Desc: ON LIGHTPOST
BA Show Instr: CALL LIST OFFICE,APPOINT* Occunied-(0/T/V)_ O- - - ---+
--------------------------------------------
I Photo Code: PHOTO TAKEN
I Photo Instr: _ -------------------------------------
----- +---------
I List Office: CBHSG4 Name: COLDWELL BANKER HOM* PPhone: 717-245-2100
hone: 717-243-7760 I
I List Agent: 67753 Name: HOCK, KAY 1
I List Agent Voicemail: 245-2100X107 1
1 List Agent Entail: Name. Phone: 1
1 List Agent2: Owner Phone: 1
Owner Name: BIDDLE
I Directions: 641E, L/OLD STONEHOUSE, APPROX 1 MI TO DIRECTIONAL,R/ON 1/4
I Directions2: MI DRWAY
I Possession: SETTLE J -;;+
----------------------------- rr
I Acres: 3.00
Source: PUBLIC RECORDS
I Tot Square Feet: 3170' Lot SgFt:
I Lo*_ Dimen:
Prepared by. Ginny Mowery on November 15, 2001
I
I New construction: -- ------i-
1
--------
1 No Rooms: 12 cull Baths: 2 Spaces (Covered: 1 Uncovered
I No Bedrooms: 9 Half Baths: 1 No Fireplaces: Y
Year Built: 1982 Wier Baths: Warranty: 1
----:---- Modified----------------------
I No Stories: 3.0 Tot Baths: -3------
-----------------------------
Full -----
+------ Bath Level: U
Half Bath Level: M __ _ _ _ _
-----------
-----------------
Pa
Information Deemed Reliable But .4ot Guaranteed. ge 1 of 2
LN: 10071250 1 Single Family FULL Format PT: SF / SPT:_----+
-----------------------------------------
+--------+-----------+---- I
I Rm Namel Dimen ILevell Desc ------------ -_________-_+
------
I Liv 120' X 20' I bi I FIREPLACE,WALL TO WALL CARPET I
I Din 19' X 12' 1 Pd I WOOD FLOOR
I Fam 118' X 90' 1 L I WALL TO WALL CARPET
1 Den 117' X 16' 1 L I CEILING FANS,WALL TO WALL CARPET I
I Kit 110' X 13' I M I CERAMIC TILE FLOOR,DINING AREA
I Mbr 115' X 17' 1 U i WALK-IM CLOSET,BALCONY/DECK I
I BR1 I I I
BR2 113' X 19' I M I WALL TO WALL CARPET I
I BR.3 113' X 18' 1 U I CEILING FANS, WOOD FLOOR I
BR9 113' X 15' 1 I CEILING FANS,WOOD FLOOR. I
10R1 OTHI 7' X 10' I M I CERAMIC TILE FLOOR. I
I'0R2 LAUI 10' X. 12' 1 L I VINYL FLOORING
1083 OTHI 11, _{ 11' 1 L I HOT TUB/SPA
-+ __ ------------------------------------------------
---------------------------
I HO Assoc (Y/N) : N Assoc Fee Incl:
I
I HO Assoc Fee: IT -----------------+
-------------------------------------------
+-----------: 3066 Disclosure Form: Y I
--Amount:
I Tar. Year: 2001 -------------+
--------------------------------------------------------------
_________-+
I School District: CUMB 1
------------------------------------------------
I Acc Financing: CONVENT TONAL, VA, CASH
I Amenities: i
I Appliances: RANGE,WALL OVEN,!-!;-CROWAVE,DISn",1ASHER,DISPOSAL, RoF? 7!(- '
I Basement: EXPOSED/WALKOUT, EXTERIOR ACCESS, FULL, PARTIALLY FINISHE*
I Construction: WOOD 1
I Cooling: I
I Electric: 100 AMPS,200+ AMPS
I Equipment: WHIRLPOOL/HOT TUB,GAR.AGE DOOR OPENER,CEILING FAN] 1
I Exterior: BRICK,CEDAR
I Exterior Feat: EXISTING STORM WINDW,EXISTTNG STORM, DOORS, PORCH,BALCON*
I Fence Desc:
I Flooring: WALL TO WALL CARPET, WOOD, CERAMIC TILE,VINYL 1
I Foundation: CONCRETE, BLOCK 1
I Heating: BASEBOA- DS, ELECTRIC, OIL
I Interior Feat: PATIO DOORS,WALK-IN CLOSETS, ALL. WIN DOW TREATMENTS,VAUL*
I Lot Desc: WOODED I
I Miscellaneous: I
I Other Rooms: LAUNDRY /UTILITY, BREEZEWAY I
I Parking: ATT,2 CAR GAR 1
I Roof: ASPHALT/FIBERGLASS
I Style: CONTEMPORARY
I Water Sewer: PRIVATE SEWER, PRIVATE WATER, WELL
I Waterfront Desc: b as zoos
Prepared by. Ginny Mowery on Novem er ,
I Zoning; RESIli;•:NTIAL
I Farms:
I outbuild:
---------------------------------------------------g-------+
Information Deemed Reliable But Not Guaranteed. Page 2 of 2
Prepared by., Ginny Mowery on November 15, 2001
--+
LN: 10051968 1 Single Family FULL-Format-----PT:_SF- /-SPT_-SF
?, Lp; 03/02/00 LDR: 03/06/00 List Price: $ 284900 I
+-__-_-----__ 284900 1
1 ST: SETT Orig Price: $
MT: 15 OMD: 03/17/00 XD: 1 Sale Price: $ 275000 1
1
? UD: 04/14/00 CLD: 09/14/00 SA2. Cntr Price: $
SO: GAUG3 SA: 66700 TLC: LT: ERS
SAC: 3.5 BAC: 3.5 OAC: --------------------------
------------------------------------ I Address: 1123 ROCKLEDGE DR
PA ZIP Code: 17013- I
CARLISLE State: 1
I City: Area. 7 I
Subdivision: Map Page: Map Coords: 1
1 Prop ID No: 0 I
1 County Code: CU,MB 1
1 Municipality: SOUTH MIDDLETON
IRoad Frontage: -------------------------------------------------------
-------- EXCEPTIONAL CEDAR HOME IN RURAL SOUTH MIDDLETON TOWNSHIP.
Remarks:
3.5 XC ACRES, 3 TWO CAR GARAGES FOR ALL YOUR STORAGE NEEDS,
E
4 BEDROOMS AND 4 FULL BATHS, GLORIOUS MASTER SUITE ON MAIN I
LEVEL, 2ND FLOOR MASTER SUITE W/BUILT-INS & PRIVATE DECK. I
16X32 INGROUND POOL S4UNALApDOLAPABLEO&R10aRD SLEA EEDITGIOOIFR
w/WET BAR, H()T TUB, -------------------
------- ------------
-------------------
I SA Show Instr: CALL LIST OFFZCE,APPOINT* Lock Box Desc: CPL I
-_----------_+
BA Show Instr: CALL LIST OFFICE,APPOINT? occupied
------------------------ 1
-----------------------
1 Photo code: SUBMITTED
1 Photo --------------------------+
Znstr:
+-- Name: JACK GAUGHEN ERA Phone: 711-243-8080 1
List Office: GAUG3 Name: WIMER, DEBORAH E Phone: 717-486-7669
1 List Agent: 66700 1
1 List Agent Voicemail: 293-3072X237 com
I List Agent Entail: deb.wimer@jgr Phone: 249-6125
List Agent2: 65817 Name: BILL MYERS
Owner Phone: 249-7319
Oirner Name: AUST 1
1 Directions: WALNUT BOTTOM RD L/GARLAND R/ROCKLEDGE (PAST MARSH) HOME ON
Di 1
1 Directions2: LEFT.
+
-------------------
I Possession: SETT _____--
+------------------ Acres: 3.99 I
I Source: APPROXIMATE
I Tot Square Feet: 3600 Lot S ct:
I Lot Dimen: N ember 15 2001
prepared by: Glnny Mowery on ove
I New Construction:
------------------------- ----------------------------------------------------
I No Rooms: 11 Full Baths: 4 Spaces (Covered: 6 Uncovered: )1
! I No Bedrooms: 4 Halt Baths: No Fireplaces:
I Year Built: Other Baths: Warranty: Y
I No Stories: 1.5 Tot Baths: 4 HandiCap Modified: N )
+--------------•---------------------------------------------
! I Full Bath i,evel: UML
I Half Bath Level:
i +------------------------------------------------------------------9-------+
Information Deemed Reliable But Not Guaranteed. Page 1 of 2
LN: 10051968 1 Single Family FULL Format PT: SF / SPT: Sr-'
+--------+-----------+-----+-----------------------------------------------+
I Rm NameI Dimen ILevell Desc I
+--------+-----------+-----+-----------------------------------------------+
I Liv 121X17 I M I WOOD/COAL STOVE, CEILING FANS, WINDOW TREATMENT,I
I I I I WALL TO WALL CARPET, BALCONY/DECK
I Din 114X12 I M I WALL TO WALL CARPET,BAY/BOW WINDOW,BALCONY/ 1
I I I I DECK
I Fam 12SX23 I L I SKYLIGHT, CERAMIC TILE FELOOR,WALL TO WALL
I I I I CARPET, HOT TUB/SPA,STEAM/SAUNA
I Den 18X6 I L I WALL TO WALL CARPET
I Kit 117X14 I M I WOOD FLOOR,BAY/BOW WINDOW
I Mbr 1 24X12 I M I SKYLIGHT, CEILING FANS,WALK-IN CLOSET,WALL TO I
I I I I WALL CARPET,BAY/BOW WINDOW 1
I BR! 112X12 I M I WALL TO WALL CARPET
I BR2 I i1Xli I M I WALL TO WALL CARPET
I BR3 1 15.5X11 1 U I SKYLIGHT,WALL TO WALL CARPET, BALCONY/ DECK
I BR4 I I I 1
I ORl LAUI 7X.7 1 M I CERAMIC TILE FLOOR
I OR2 PLY[ 17X13 I L I WALL TO WALL CARPET
I OR3 I I I
+--------+-----------+-----+-----------------------------------------------'
T
I HO Assoc (Y/Pi): N Assoc Fee Incl:
I HO Assoc Fee: 1
+--------------------------------------------------------------------------+
I Tax Amount: 2514 Disclosure Form: Y I
+--------------------------------------------------------------------------+
I Tax Year: 99/00 1
*-----------------------------------------
I School District: S MI I
+----------------------------------
I P.cc Financing: CONVENTIONAL, CASH I
I Amenities: POOL 1
I Appliances: RANGE, DISHWASHER, WATER SOFTENER
I Basement: EXPOSE D/WP.LKOUT,EXTERIOR ACCESS, PARTIAL, FINISHED, INTER* I
I Construction: FRAME I
I Cooling: HEAT PUMP,CENTRAL AIR,CEILING FAN 1
I Electric: CIRCUIT BREAKERS 1
I Equipment: SATELLITE DISH,SHOKE DETECTORS, SECURITY SYSTEM,SAUNA/S* I
I Exterior: BLOCK, CEDAR, STUCCO
I Exterior Feat: DECK, BALCONY, INGROUND POOL, LANDSCAPED, OUTSIDE LIGHTING 1
I Fence Desc: PARTIAL, PRIVACY, OTHER
I Flooring: WALL TO WALL CARPET, PARQUET, CERAMIC TILE,SLATE 1
I Foundation: BLOCK 1
I Heating: HEAT PUMP, ELECTRIC, WOOD, SOLAR I
I Interior Feat: PATIO DOORS,STOVE, WOOD/COAL,WET BAR,WALK-IN CLOSETS,S* I
I Lot Desc: LEVEL, SLOPING, VIEWS
I Miscellaneous:
I Other Rooms: GREAT ROOM,FAMILY ROOM, LOFT, REC/ PLAY ROOM,FORMAL DININ* I
Prepared by., G1nny Mowery on November 15, 2001
I Parking: PVil DR, ATT, DET, 3+ CAR GAR, OFF STREET, INTEGRAL I
I Roof: ASPHALT/ FIBERGLASS
I Style: CONTEMPORARY
I Water Sewer: SEPTIC, WELL
I Waterfront Desc:
I Zoning: RESIDENTIAL,
I Farms:
I Outbuild:
---------------------------------------------------+
Information Deemed Reliable But Not Guaranteed. Page 2 of 2
Preoared bv: Ginny Mowery on November 15, 2001
L[d: 10040,079 1 Single Family FULL Format PT: SF / SPT: SF
----------------------------+
+----------------------------------------------
I ST: SETT LD: 04/14/99 LDR: 04/14/99
1 MT: 15 OMD: 04/29/99 XD:
I UD: 06/21/99 CLD: 06/16/99 FC 3
1 SO: RMREAL SA: 64938 SA2:
I SAC: 3.5 SAC: 3.5 OP.C: TLC:
+----- - ---------
I Address:
I City:
I Subdivision:
I
I County Code:
I Municipality
(Road Frontage
List Price: $ 309900 1
Orig Price: $ 309900 1
Sale Price: $ 290000 1
I
Cntr Price: $
LT: ERS I
-----------------------+
1271 KUHN RD
BOILING SPRINGS State: ?A ZIP Code: 17007- I
WHITE ROCK ACRES Area: 6 I
Map Page: Hap Coords: I
CUMB Prop ID No: 22120348120 & 121 I
MONROE
300' 1
+---------- ----------------------------------------------------+
I Remarks: "UNIQUE, DISTINCTIVE, MAGNIFICENT" BEST DESCRIBES THIS REDWOODI
CONTEMPORARY DESIGNED BY FRED HARLE & BUILT TO THE HIGHEST I
STANDARDS. FEATURES AN OPEN FLOOR PLAN,LOFTS,5 DECKS,REFLEC-1
TING POOL,HOT TUB & WALLS OF GLASS. SITUATED ON 5.7 ACRES OFI
LUSH TREES & LANDSCAPING JUST 12 MINUTES FROM MECHANICSBURG I
OR CARLISLE IN THE Ci:NBERLAND VALLEY SCHOOL DISTRICT. I
-----------------------------------------+
I SA Show Instr: CALL LIST OFFICE,APPOINT* Lock Box Desc: NONE I
I BP. Show Instr: CALL LIST OFFICE,APPOINT* Occupied (O/T/V) : 0 I
+-------------------------------------------------------
I Photo Code: PHOTO TAKEN
I Photo Ir.str:
---- ---------------
I List Office: RMREAL Name RE/MAX REALTY Phone
I List Agent: 64938 [dame: SHUMAKER, DON Phone
I List : I
Voicemail: 761-6300 X3164
Anent
--------------------
I
--------------------
717-761-6300 1
717-732-4998 1
I List Agent EPlail:
I List Agent2: Name: Phone:
I Owner Name: WELCH,FRANK/MARIA Owner Phone: 717
1 Directions: 15S,R/GRANTHP.M,L/WMS GROVE RD,R/RT.74,L/CP.EEK
1 Directions2: ON RIGHT
I Possession:
-------------------------------------
Acres: 5.74
I Tot Square Feet: 4000 Source: OWNER
I Lot Dimen: Lot SgFt:
Prepared by: Ginny Mowery on November 15, 2001
I
I
I
258 9378 I
RD,L/KUHN,HSE I
I
I
---------------+
I New Construction: _I
---------------------
No Rooms: 9 Full Baths: 3 SpaGeS (Covered: Uncovered: )I
I No Bedrooms: 4 Half Baths: 1 No Fireplaces: -
I Year Built: 1960 Other Baths: Warranty:
I No Stories: 3.0 Tot Baths: 4 Handicap Modified: N +
--------------------------------------
Full Bath Level: 1
Half Bath Level: 1
I +
--------------- ----
Information Deemed Reliable But Not Guaranteed. Page 1 of 2
LN: 100409'19 1 Single Family FULL Format PT: SF / SPT: SF
-----+
I Rm Name) Dimen )Level] Desc
----------------------------+
I Liv I I M I FIREPLACE,CEILING FANS,WOOD FLOOR,BALCONY/ I
I ] DECK,INTERIOR BALCONY
I Din I I M I WOOD FLOOR
I Fam I I M I WOOD/COAL STOVE,CEILING FANS,WOOD FLOOR, I
I I I I BALCONY/DECK, INTERIOR BALCONY I
I Den I I U I SKYLIGHT,BALCONY/DECK I
I Kit I I M I WOOD FLOOR 1
Mbr I I U I BALCONY/DECK 1
I
BP2 I U I BALCONY/DECK 1
I BR3 I" I L I WALL TO WALL CARPET
I BR4 I I L I WALL TO WALL CARPET
I OR1 LOFT I U I 1
I
I OR2 I I I
I OR3 I I I
----- ----------------------------+
I HO Assoc (Y/N); Assoc Fee Incl:
) Y.0 Assoc Fee:
+--------------------------------------------------------------------------+
I Tax Amount: 2769 Disclosure Form: Y I
-----------------------------------------------------------+
1
I Tax Year: 1993 1
------------------------------------------------------------------
I School District: CUMB
----------------------------------------------------+
-
-
I Acc Financing: -----
-
CONVENTIONAL, CASH, PRIVATE, LEASE PURCHASE !
I Amenities:
1 Appliances: 1
RA.NGE,INDOOR GRILL, DISHWASHER, DISPOSAL, COMPACTOR,REFRI* I
I Basement: EXPOSED /WALKOUT, FULL, FINISHED
1 Construction: FRAME,WOOD
I Cooling: CENTRAL AIR, CEILING FAN, ZONED I
I Electric: 110 VOLTS,220 VOLTS,CIRCUIT BREAKERS,200+ AMPS I
I Equipment: SMOKE DETECTORS,WHIP.LPOOL/HOT TUB, HUMIDIFIER, GARAGE DO* I
I Exterior: REDWOOD 1
I Exterior Feat: EXISTING STORM WINDW,PATIO, DECK, BALCONY, HOT TUB,LANDSC* I
I Fence Desc: 1
1 Flooring: ['WALL TO WALL CARPET, WOOD, CERAMIC TILE I
I Foundation: CONCRETE,BLOCK 1
I Heating: CENTRAL HEAT,FORCED AIR,OIL
*
I Interior Feat: I
PATIO DOORS,STOVE, WOOD/COAL, SKYLIGHT, MASTER BATH,ELEC
I Lot Desc: WOODED,SLOPING,VIEWS 1
I Miscellaneous: 1
I Other Rooms: FAMILY ROOM, LOFT, OFFICE /COMPUTER RM,FOYER,FORHAL DININ* I
I Parking: 2 CAR GAR
1
I Roof: RUBBER
I Style: CONTEMPORARY
a.e„n..d hv: Ginnv Mowery on November 15,2001
it
I Water Sewer: PUBLIC SEWER,PUBLIC WATER
I Waterfront Desc:
I Zoning: RESIDENTIAL
I Farms:
I Outbuild:
+----------------------------------------------
Information Deemed Reliable But Not
I
I
I
I
I
-----------------------------
Guaranteed. Page 2 of 2
Prepared by: Ginny Mowery on November 15, 2001
X.
LN: 10054492 1 Single Family FULL Format PT: SF / SPT: SF
--------------------------------------------+
I ST: SETT LD: 05/05/00 LDR: 05/11/00 List Price: $ 339900 1
I NIT: 164 OMD: 10/16/00 XD: Orig Price: $ 345000 1
I UD: 12/15/00 CLD: 12/15/00 FC 1 Sale Price: $ 296000 1
I SO: EBENER SA: 67190 SA2: Cntr Price: $ I
I SAC: 2.5 BAC: 2.5 OAC: TLC: LT: ERS I
-------------------------------------------------+
I Address: 102 CARRIAGE LN 1
I City: CARLISLE State: PA ZIP Code: 17013- I
I Subdivision: Area: 7 I
Map Page: Map Coords: I
I County Code: CUMB Prop ID No: 08-10-0626-055
I Municipality: DICKINSON
(Road Frontage:
----------------------------------------------------F ----------+
I Remarks: TOTALLY PRIVATE 1-1/2 STORY HOME IN THE MIDDLE O. 12+ ACRES I
1 WITH A CONTEMPORARY FLAIR. STUNNING GREAT ROOM WITH 24' I
1 VAULTED CEILINGS. 5 CAR GARAGE, 19T FLOOR MASTER BEDROOM, 2 I
1 TYPES OF HEATING, PROPANE AND HEAT PUMP. FULLY EXPOSED REAR I
BASEMENT FOR POSSIBLE EXPANSION. SELLER WILL BUILD DECK OR. I
_ TVE BUYERS CREDIT FOR SAME. LOTS OF UP-GRADES TH::C try.^.p" . 1
------------------------------------------------- --------------------------+
I SA Show Instr: CALL LIST OFFICE Lock Box Desc: LB I
I BA Show Instr: CALL LIST OFFICE, Occupied (0/T/V): 0 I
-+
I Photo Code: PHOTO TAKEN 1
I Photo Instr:
-----------------------------------------------------+
I List Office: EBENER Name: GEORGE L EBENER _none: 717-243-6195 I
1 List Agent: 63561 Name: DIEHL, RODGER C. Phone: 717-776-4573 I
1 List Agent Voicemail: 243-6195X275
I List Agent EMail: ebener@p.net
I List Agent2: 63670 Name: LINDSEY, THOMAS Phone: 776-4831 I
I Owner Name: Owner Phone: I
I Directions: FROM CARL. RT ll/S 5 MILE L/MOOREDALE P./CARRIAG FIRST DRIVE
I Directions2: ON RIGHT
I Possession:
------------------------------------+
I Acres: 12.64 I
I Tot Square Feet: 3394 Source: OWNER I
I Lot Dimen: Lot SgFt: I
Prepared by: Ginny Mowery on November 15, 2001
I
I New Construction: _____-_-__+
------------------------i--- Spaces- --------- ---
I No Rooms: Full Baths: 1 No ace. (Covered: Uncovered: )
I No Bedrooms: 3 Half Baths: 1 o Fireplaces:
I
I Year Built: 1999 Other Baths: Warranty:
I No stories: 2.5 Tot Baths: 3 HandiCap Modified: )
-----------------------------+
-- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Full Bath Level: M/U
Half Bath Level: M
-------------
+----------- ------------+
-----------------------------------
-
Information Deemed Reliable But Not Guaranteed. Page 1 of 2
LN: 10054492 1 Single Family FULL Format PT: SF / SPT: SF
---------------------------- ------------------------------- --
I Rm Namel Dimen ILevell Desc _________________________+
+--------+-----------+-----+---------------------- I
I Liv I I I
I Din I I M I
I Fam I I M I
t Den I I I
I. Kit I I M I
I Mbr I I M I
I BR1 I I
I BR2 I I U I
I BR3 I I U I
I BR4 I I
I OR1 FOYI I M, I
I OR2 I I I I
I OR3 I I I
+-----+-----------------------------------------------+
+--------+-------- I
I HO Assoc(Y/N): N Assoc Fee incl:
I HO Assoc Fee: I
--------------+
I Tar. Amount: 3294 Disclosure Form: Y I
-------------------------------+
I Tax Year: 99/00
-------------------------------------------+
+-------------------------------
I School District: CARL
------------------------------+
I Acc Financing: C^NV.NTIONAL,CASH
I Amenities:
I
I Appliances: RANGE,COUNTERTOP RANGE,WALL OVEN, MICROWAVE, DISHWASHER,*
I Basement: EXPOSED/WALKOUT,FULL,GARAGE ACCESS
I Construction: FRAME
I Cooling: HEAT PUMP,CENTRAL AIR
I Electric: 200+ AMPS
I Eauipment: WHIRLPOOL/HOT TUB,SECURITY SYSTEM,GARAGE DOOR OPENER,C*
I Exterior:
I Exterior Feat:
I Fence Desc:
I Flooring: WALL TO LL CARPET,4)OOD
I Foundation: CONCRETE
I Heating: HEAT PUMP,FORCED AIR, ELECTRIC, PROPANE I
I Interior Feat: FIREPLACE, GAS,i9ALK-IN CLOSETS, VAULTED CEILINGS,MASTER*
I Lot Desc: WOODED
I Miscellaneous:
I Other Rooms: FOYER
I Parking: ATT,2 CAR GAR,3+ CAR GP.R,INTEGRAL I
I Roof: ASPHALT/FIBERGLASS
I Style: CONTEMPORARY
I Water Sewer: SEPTIC,WELL
Prepared bv: Ginnv Mowery on November 15, 2001
J r. I$=
I Waterfront Desc:
I Zoning:
I Farms:
I Outbuild:
+-----------------------------
Information Deemed
I
I
I
I
---------------------------------------------+
Reliable But Not Guaranteed. Page 2 of 2
Prepared by., Ginny Mowery on November 15, 2001
Single Family FULL Format PT_-SF--/-SPT__SF -+
LN: 10062398 1 ------
-----------------
List Price: $ 329900
ST: SETT LD: 01/05/01 LDR: 01/10/01 Orig Price: $ 329900 I
MT: 102 OMD: 09/17/01 XD: 1 Sale Price: $ 300000 I
UD: 05/29/01 CLD: 05/25/01 FC Cntr Price: $
S0 SA: 65298 SA2: TLC: LT: ERS
: THONIP
I
) SAC: 2.5 BAC: 2.5 OAC: 2.5 ---------------------------------+
-------------------
+-------- 635
- GAP RD
I Address: LErWISBERRy State: PA ZIP Code: 17339- I
I City: Area: 6 i
I Subdivision: Map page: Map Coords:
I prop ID No: 0 I
County Code: YORK p I
I Municipality: FAIRVIEW
--------------+
(Road Frontage: ------------------------------------------
+ CONTEMPORARY W/GEOTHERMAL HEAT. TOTAL ELECT
Remarks: IMMACULATE 9000SF ONLY S90/MONTH. LL FAMILY ROOM W/WOODSTOVE, HUGE WET BAR & I
GAMEROOM. 3.5 BATHS, MAIN LEVEL LAUNDRY, HUGE MASTER
SUITE 41/JACUZZI TUB, SOLID CHERRY CABINETS, LOFT OFFICE OR I
BR, FORMAL DR W/POCKET DOORS, PROFESSIONALLY DESIGNED
o-
pl/CERAMIC FLOORS & FP.ENCH DOORS-TO PATIO-MUCH-,lu___+
-------------------------
_sc• FRONT DOOR
+-------------- Lock Box. DP
SA Show Instr: CALL LIST OFFICE Occupied (O/T/V): 0 __+
BA Show Instr: CALL LIST OFFZC-------- --------------------------------
I
------------------
Photo Code: PHOTO TAKEN
Photo Instr: ---------------------------+
+--------------- ----------------------------- Phone: 717-766-0055 I
Phone: 717-932-0399 i.
I List Office: GRUG12 Name: JACK JACK ACK GAU f,GHEN ERA A
STEVEN
List Agent: 65783 I
List Agent Voicemail: steve6wisotzl:ey@jgr•com
I List Agent Email: Phone:
Owner ?hone:
I.List Agent2: Name:
Owner Name:
Directions: RTE 83 EX 16;R AT STOP ONTO FISHINGCP.EEK;L/PLEASANT VIEW;R/
Directions2: GAP -----
---+
I Possession: SETTLE _f __-
+------------ ,..
--------------- Acres: 8.00
I
I G?69 Source: OWNER I y
I Tot Square Feet: Lot SqF
Lot Dimen: 7
Prepared by: Glnny Mowery on November 15, 2001
I New Construction: 1
--------------------------------------------------------------------------+
I No Rooms: 15 Full Baths: 3 Spaces (Covered: 2 Uncovered: 4)I
1 No Bedrooms: 3 Half Baths: 1 No Fireplaces: 2 I
1 Year Built: Other Baths: Warranty: N I
I No Stories: 2.0 Tot Baths: 4 HandiCap Modified: N 1
+--------------------------------------------------------------------------+
1 Full Bath Level: ML I
Half Bath Level: M I
--------------------------------------------+
Information Deemed Reliable But Not Guaranteed. Page 1 of 2
LN: 10062398 1 Single Family FULL Format PT: SF / SPT: SF
+--------+-----------+-----+-----------------------------------------------+
I P.m Namel Dimen ILevell Desc I
+--------+-----------+-----+-----------------------------------------------+
I Liv 124X20 I M I FIREPLACE,SKYLIGHT I
I Din 112X11 I M I WOOD FLOOR I
I Fam 124X22 I L I I
I Den 124X20 I M I I
I Kit 112X24 I M I CERAMIC TILE FLOOR I
I Mbr 118X16 I M I CEILING FANS,WALK-IN CLOSET I
I BR1 I I I I
I BR2 112X11 I M I WALL TO WALL CARPET I
I BR3 124X20 I M I WALL TO WALL CARPET I
I BR4 I I I I
I OP.1 GRM1 30X3)5 I L I I
I OP.2 OTHI 24Y22 I L I WOOD/COAL STOVE, WALL TO WALL CARPET I
I OR3 LAUI 8X9 1 14 1 1
+--------+-----------+-----+-----------------------------------------------+
I HO Assoc(Y/N): N Assoc Fee Incl: I
I HO Assoc Fee: I
+--------------------------------------------------------------------------+
I Tai: Amount: 3500 Disclosure Form: Y I
+--------------------------------------------------------------------------+
I Tax Year: 2000 1
+--------------------------------------------------------------------------+
I School District: W SH I
+--------------------------------------------------------------------------+
AcC Financing: CONVENTrONAL I
I Amenities: I
I Appliances: RANGE,MICROWA.VE,DISHWASHER I
I Basement: EXPOSED/WALKOUT, EXTERIOR ACCESS, FULL, FINISHED, CONCRETE*
I
I Construction: FRAME I
I Cooling: HEAT PUMP,CENTRAL AIR I
I Electric: 200+ AMPS I
I Eauipment: SMOKE DETECTORS,WHIRLPOOL/HOT TUB,GARAGE DOOR OPENEP,,C* I
I Exterior: CEDAP.,WOOD I
I Exterior Feat: PORCH, PATIO, DECK, LANDSCAPED, OUTSIDE LIGHTING I
I Fence Desc: I
I Flooring: WALL TO WALL CARPET, WOOD, CERAMIC TILE I
I Foundation: CONCRETE I
I Heating: FORCED AIR,GEOTHERMAL,ELECTRIC I
I Interior Feat: WET BAR,WALK-IN CLOSETS, BEAMED CEILINGS,SKYLIGHT,VAULT* I
I Lot Desc: WOODED,LEVEL,SLOPING,VIEWS I
I Miscellaneous: I
I Other Rooms: GREAT ROOM,FANTLY ROOM, LOFT, LIBRARY/STUDY, OFFICE COMPU*
I Parking: PVD DR,ATT,2 CAR GAR,GAR I
I Roof: COMPOSITION I
I Style: CONTEMPORARY I
I Water Sewer: PRIVATE SEWER, SEPTIC, PRIVATE iWATER,WELL I
Prepared by., G1nny Mowery on November 15, 2001
I
Waterfront Dr_,sc: I
Zoning: RESIDENTIAL
Farms:
Outbuild: ----------------------------------------
----------- g-----------
+-----------
Information - Deemed -Reliable But Not Guaranteed. Page 2 of
Prepared by: Ginny Mowery on November 15, 2001
LN: 10052557 1 Single Family FULL Format PT: SF / - SPT: - SF-_+
---------------------------------------------------------------- -------
I ST: SETT LD: 03/21/00 LDR: 03/21/00 List Price: $ 310000 1
c OMD: 03/25/00 XD: Orig Price: $ 310000 1
1 MT:
I UD: 07/11/00 CLD: 06/01/00 FC 1 Sale Price: $ 312000 1
1
Cntr Price: $
I S0: THOwp SA: 60915 SA2: LT: ERS I
I SAC: 3.5 6AC: 3.5 OAC: 3.5 TLC :----- -------------------
------------------------------------ -----
1 Address: 14 STONE SPRING LN 1
I City: : CAMP HILL State: PA6 ZIP Code: 17011- I
1 Subdivision: Area:
1 Map Page: Map Coords:
1 County Code: CUMB Prop ID No: 10 20 1646 193 1
1 Municipality: HAMPDEN 1
(Road Frontage: ________________ --------------+
________________________F________-
I Remarks: LOVELY CUSTOM TRADITIONAL/CONTEMPORARY EXTERIOR ON 1.98
ACRES OVERLOOKING WATER. PARK-LIKE SETTING. INCREDIBLE I
1 LOCATION. OUTSTANDING CRAFTSMANSHIP AND QUALITY THRU-OUT. I
1 THE MASONARY WORK IN INCREDIBLE. DETACHED WORKSHOP WITH FP. I
HUGE GOURMET KROWN KIT. W/ISLAND, JENN AIR S BRKFST AREA. I
1 Gi:S -P LR. LL COULD BE iN-LAW SUITE W'/KIT. ENERGY EFPIG.?
_ __ ---------------------+
I SA Show Instr: CALL LIST OFFICE Lock Box Desc: CPML I
---------
1 BA Show Instr: CALL LIST OFFICE Occupied (O/T/V): O -_- --- --_+
----------------------------------------
I Photo Code: PHOTO TAKEN 1
I Photo Instr:
_ _ ----+
I List Office: GLISEI Name: JOHN GLISE REALTOR Phone: 717-761-6070 I
I List Agent: 62890 Name: GILMORE, REBECCA Phone: 717-761-6689
1 List Agent Voicemail: 761-6075 X 1012
1 List Agent Entail: Nam<. A 1
Phon_:
I List, Agent2: Owner Phone: 761-7876 I
I Owner Name: HESS
I Directions: MARKET ST TO R/OARS BRIDGE RD,L/(AT BRIDGE) TO STONE SPRING
I Direction-92: LANE
1 Possession: SETT
---------------------------------
+-------------- Acres: 1.98 1
Source: APPRAISER 1
I Tot Scuare Feet: 3772
I Lot Dimen: 102X525Y.253X444 Lot SgFt:
Prepared by. Ginny Mowery on November 15, 2001
I New Construction: I
+---------------------------------------------------------------
I No Rooms: 10 Full Baths: 3 Spaces (Covered: Uncovered: )1
I No Bedrooms: 5 Half Baths: 2 No Fireplaces: 2
1 Year Built: Other Baths: Warranty: N 1
I No Stories: 2.0 Tot- Baths: 5 Handicap Modified:
+-----------------------------------------------
I Full Bath Level: M/U I
I Half Bath Level: NI/U i
+-----------------------------------------------------------------------
Information Deemed Reliable But Not Guaranteed. Page 1 of 2
LN: 10052557 1 Single Family FULL Format PT: SF / SPT: SF
+--------+------- ----+-----+-----------------------------------------------+
I Rm Namel Dimen ILevell Desc I
+--------+-----------+-----+-----------------------------------------------+
I Liv I I M I GAS FIREPLACE
I Din I I M I WOOD FLOOR
I
I Fam I I L I
I Den I I
! I
I Kit I I
I M I CERAMIC TILE FLOOR I
I Mbr ! I U ! WALI, TO WALL CARPET I
I BR1 I I M I WALL TO WALL CARPET I
I BR2 I I U I WALL TO WALL CARPET I
I BR3 I I U I WALL TO WALL CARPET I
I BP•4 I I U I WOOD FLOOR
I OP.1 OFCI I
I M I WOOD FLOOR
I OR2 LAUI I
I N, I
I OR3 KZTI I
I L I
+ -+ I
-+ r
I HO Assoc(Y/N): Y Assoc Fee Incl:
I HO Assoc Fee: 55/yr
+----------------- --------------------
I Tar, Amount: 2530
Disclosure Form: 't
+----------------- --------
--------------
I Tax fear: 2000 --------------------
-----------
+----------------- ----------------------
I School District: ---------------------------
CUbiB
------------------ I
------------------------
Acc r^inancinn: -------------------------------
CONVENTIONAL,CASH
I Amenities: OTHER
I Appliances: RANGE, WALL OVEN, INDOOR GRILL, MICROWAVE, DISHWASHER
DISP* I
I Basement: ,
FULL,FINISHED,CONCRETE FLOOR
I Construction: I
FRAME
I Cooling: !
CENTRAL AIR
I Electric: 220 VOLTS,200+ AMPS
I Equipment: I
SMOKE DETECTORS, SECURITY SYSTEM, GARAGE DOOR OPENER
WAT* !
I Exterior: ,
REDWOOD,BRICK,CEDAR
I Exterior Feat: I
EXISTING STORM WINDW,EXISTING STORM DOORS, PORCH
PATIO
I
I Fence Desc: ,
,
I Flooring: 1
WALL TO WALL CARPET, WOOD, CERAMIC TILE,VINYL
I Foundation: BLOCK
I Heating: I
HOT WATER,OIL
I Interior Feat: FIREPLACE, GAS,SOME WINDOW TREATMENTS, VAULTED CEILINGS* I
I Lot Desc: WOODED,WATER FRONTAGE, FLOOD PLAIN,NO OUTLET STREET !
I Miscellaneous:
I Other Rooms: 1
REC/PLAY ROOM
I Parking: I
2 CAR GAR
I Roof: I
ASPHALT/FIBERGLASS
I Style: I
CONTEMPORARY, TRADITIONAL
I Water Sewer: I
PUBLIC SEWER, PRIVATE WATER I
Prepared by. Ginny Mowery on November 15, 2001
_ I
VIEW,OTHER I
Waterfront Deso: [,P.ONVGE, RESIDENTIAL ---------------+
Zonino,: ----------------- Page 2 of 2
Farms: ---------------- n--------
teed.
Outbuild------ --------- De- l Not Guara.
+ Information Deemed Reiable But
1 ?
by: Gfnny Mowery on November 15, 2001
prepared
S. t1
LN: 10065182 1 Single Family FULL Format PT: SF / SPT: SF
----------------------------------------------------
ST: SETT LD: 03/26/01 LDR: 03/26/01 List Price: $ 319900 1
I MT: 15 OtdD: 09/10/01 XD: Orig Price: $ 319900 1
I UD: 05/09/01 CLD: 05/07/01 FC 1 Sale Price: $ 316000 I
I
I SO: HUSRE SA.: 65933 SA2: Cntr Price: $
I SAC: 3.0 BAC: 3.0 OAC: TLC: 3.0 LT: EP,S---- --- I
--------- +
I Address: 120 S LEWISBERRY RD
I City: M=CHANICSBURG State: _A Z_P Cod_: 17055-
1 Subdivision: Area: 6
Map Page: Map Coords: I
I County Code: YORK Prop ID No: 38000PDO147CO000000
I Municipality: MONAGHAN I
(Road Frontage:
--------------------------------------------
I Remarks: CONTEMPORARY 2 STORY ON WOODED LOT ONLY MINUTES FROM
HARRISBURG AND CLOSE BY THE NEW GINAT AT 15-76. YOULL LOVE I
THE MASTER BEDROOM SUITE AND THE DECK. NEW KITCHEN HARDWOOD I
I IN LR & DR. STREAM ON PROPERTY BUT NO FLOOD INS. NEEDED. I
I
I I
-------------------------------------------------
I SA Show Instr: CALL LIST OFFICE Loci. Boy: Desc: CPMLS I
I BA Show Instr: CALL LIST OFFICE Occupied (0/T/V): 0 ----+
---------------------------------------------------------
I Photo Code: PHOTO TAKEN
I Photo Instr:
?
I List O-lice: P.SR Name: ROTH:IAN/SCHUEERT Phon_: 717-763-'_212
I List Agent: 60876 Name: WILLIAM ROTHMAN, BR' Phone: 717-761-4955 j
List Agent Voicemail: 558-5590 i
I List Agent Ellail:
I
Phone:,
I List Agent2: Name:
I Owner (Jame: GIBBONS, MILES L. JR Owner Phone: 691-7582 I
I Directions: OUT 15 TO 114 LEFT TO LEWISBERRY RD TURN LEFT GO 1.8MILES TO
I Directions2: HS ON R. I
I Possession: SETTLE ________________+
---------
---------------------------------------
I Acres: 6.69
I Tot Square Feet: 3820 Source: PUBLIC RECORDS I
I Lot Dimen: Lot SgFt:
Prepared by., Gfnny Mowery on November 15, 2001
I
-----
--
--
I New Construction:
----
----- - Uncovered: )I
2
s (Coed: -
ver
---
I
____
}----
g 8 ths: 3 Space
Full Baths:
No Fireplaces:
I
No Rooms:
s: N
Half Baths: 1
ranty: I
W
No Bedroom
Year Built: 1980 ar
Ote
h
Bhsns 9 HandiCap Modified: N ------ -_+
I No Stories: 2.0
--
o
Ba
_______-------------------------
I
--------
--- 1
Full Bath Level'
I Half Bath Level: _--------------
-----------
-------
+------------ va e 1 of 2
•
------------------------------
Deemed Reliable But Not Guaranteed.
Infomation
Single Family FULL Format PT: SF / SPT: - SF
----+
-------- - ---- --
LN: 10065182 1
--- -----------------
I
-+-----+----------
ILevell Desc ---------------------------+
Rm Namel Dimen
---- __ _ ------------
I
-------------
1 2 I
Liv 1 1 2 1
I Din 1 1 2 1
Fam I I I I
I Den I I 2 I
I Kit 1 1 3 1
Mbr I I 1 I
BR1 I I 1 1
BR2 I I 1 1
I BR3 I I I I
I BR9 I I I I
OR1 I I I I
I OR2 I I -----------+
-------
OR3 I
_
-- I
----------
------------- I
--+-----+------
+--------+ __
N Assoc Fee Incl: I
I HO Assoc (Y/1•t): ----_----___-+
---
I HO Assoc Fee:
------
--
------------------------------------
Disclosure Form: .f
--
+ +
-----------
3505
--------
I Tax Amount:
--
--------------
+------- 2001 -
---------------
Tax Year: :
I
------------
-------------
School District: N YO ---------------------------------------------------
C,"1NVE;NTIONAL
ac,. Fin3nr.i_nrt: DISHWASHER,DISPOSAL,COtIPA*
I Amenities: ICROWAVE,
Rp]CE,INDOOR GRILL,,
I Appliances:
I Basement: I
ME, METAL, CONCRETE
FR
I Construction: I
A
1 Cooling:
I Electric: 200+ AMPS
SMOKE DETECTORS, WH1RLPOOL/HOT TUB,SECUR*
VACUUM
I Equipment:
:
i ,
CENTRAL
PED,DE LIGHTING
VINYL OUTSIDE
LANDSCP
or
xte r
E
Feat:
i 1
.
STORM P;IN DW,DECK,
or
1 Exter
I Fence Desc: 1
TO WALL CARPET, WOOD, CERAMIC TILE,VINY
I
I Flooring-.
Fl WALL
BLOCK
I Foundation:
HEAT PUMP,ZONED
P7ALK-IN CLOSETS,SKYL*
WET BAR
I Heating:
Interior Feat: 1
,
PATIO DOORS,FREE STANDING,
FLOOD PLAIN
OPING
,
STREAM,WOODED,SL
Lot Desc:
I
Miscellaneous: _ I
1
-ORMAL DINING RNi,BREAKFAST NOOK, PANTRY
I Other Rooms: 2 CAR GAR I
1 Parking:
COMPOSITION,RUBBER,METAL
I Roof: CONTEMPORARY I
Style: SEPTIC,`67ELL
Water Sewer: Prepared by: Ginny Mowery on November 15, 2001
I Waterfront Desc:
I Zoning: RESIDENTIAL
I Farms:
I Outbuild:
+--------------------------------------------------------------------------i.
Information Deemed Reliable But Not Guaranteed. Page 2 of 2
Prepared by: Glnny Mowery on November 15, 2001
LN: 10038269 1 Single Family FULL Format PT: SF / SPT: SF
---------------------------------------------------------------+
I ST: SETT LD: 02/01/99 LDR: 02/01/99 List Price: $ 399000 1
1 MT: 226 OMD: 09/15/99 XD: Orig Price: $ 379000 1
1 UD: 02/08/00 CLD: 10/11/99 FC Sale Price: $ 325000 1
I SO: RSR SA: 69129 SA2: Cntr Price: $ I
I SAC: 3.0 BAC: 3.0 OAC: TLC: LT: ERS I
.r--------------------------------------------------------------------------+
1 Address: 599 E SIDDONSBURG RD I
I City: N,ECHANICSBURG State: PA ZIP Code: 17055- 1
I Subdivision: Area: 6 1
Map Page: ADC Map Coords: 29K6 I
I County Code: YORK Proo ID No: 380-QE-3B I
I Municipality: MONAGHAN I
(Road Frontage:
--+
I Remarks: CONTEMPORARY HOME ON PRIVATE WOODED LOT. OPEN FLOOR PLAN I
WITH MANY ATTRIBUTES TO ACCENT THIS CONTEMPORARY HOME, I
MULTIPLE DECKS, THREE FIREPLACES, HOT TUB, WET BAR, SPIRAL i
1 HARDWOOD STARICASE & MUCH MORE TO OFFER. CALL RSR FOR MORE 1
1 INFORMATION. 7'03-1212. I
I
-----------------------------------------------------+
I SA Show instr: CALL LIST OFFICE Lock Box Desc: CPLB I
1 BA Show Instr: CALL LIST OFFICE Occupied (O/T/V): V I
-----------------------------------------------+
I Photo Code: PHOTO TAKEN I
I Photo Instr:
-----------------------------------------------------------+
I List Office: RSR Name: ROTHMAN/SCHUBERT Phone: 717-763-1212 1
1 List Agent: 69129 Name: ROTHMAN, GREG Phone: 717-761-1212 I
I List Agent Voicemail: 558-7016 I
I List Agent Entail: WGreg1966@AOL.COM I
I List Agent2: Name: Phone: I
I Owner Name: MAGER Owner Phone: I
I Directions: 15 S TO 119 EXIT T/L GO 1.211 T/L LE°AISBERY RD 1M TO E.SIDDONI
I Directions2: PROP ON I
1 Possession: NEGO
---------------------------------------------------------+
Acres: 12.33 I
I Tot Square Feet: 3702 Source: I
I Lot Dimen: Lot SgFt: I
Preparod by., Ginny Mowery on November 15, 2001
1
--------------+
I New Conslr.uction: -----__-- -----------------------
Full Baths: 3 Spaces (Covered: 2 Uncovered: )I
I No Rooms: 12 3
No Bedrooms: 4 Half Baths: 1 No Fireplaces: N I
Year Built: 1983 Other Baths: Warranty:
I
I No Stories: 2.0---Tot-Baths_---- 9---HandiCap_biodified_--N---------------+
+------------ I
Full Bath Level: UL
Half Bath Level: M F
---
--------e-i-of 2
-----------------------------
Page
Information Deemed Reliable But Not Guarantee .
Single Family FULL Format PT: SF / SPT: SF
LN: 10038269 1 --------------------+
I Rm Namel Dimen ILevell ------- --+
--------------------------
+------ FIREPLACE,WOOD FLOOR,VINYL FLOORING, BALCONY I
Liv 11513X2114 i M i DECK
I
I
I I
am 12014X15'8 I L I FIREPLACE,WALL TO WALL CARPET, BALCONY/ DECK
l Din
Den 11115X1216 I U I WALL TO WALL CARPET, BALCONY/ DECK
I
I Kit 11811X2112 I M I CERAMIC TILE FLOOR,DINING AREA, BALCONY/ DECK
l Mbr 11514X12'9 I U I FIREPLACE, WALK-IN CLOSET,VINYL FLOORING,WALL
TO WALL CARPET
BR1 1 716X1213 I U I WALL TO WALL CARPET
I BR2 111'5X11'1 1 U I WALK-IN CLOSET,CEDAR LINED CLOSET,dALL TO
I I WALL CARPET
j BR3 i 10'3X15'6 1 U I WALK-IN CLOSET,CEDAR LINED CLOSET,WALL TO
WALL CARPET
I BRq 110'3X1516 i U I WALL TO WALL CARPET,INTEP.IOR BALCONY
I OR1 OFCI
1 OR2 OTHI L I WALK-IN CLOSET,WALL TO WALL CARPET
I
I OR3 BTHI 9X12'4 I I HO Assoc(Y/iv) -------------------+
___ ___ ___ ------------------
--------------------
+-- -+ N Assoc Fee Incl: I
l
l HO Assoc Fee: ---------- ----+
------------------------- -------_ Disclosure Form: Y
I Tax -----------
Tax Amount: 3395 ------------------+
I Tax Year: 98 --------+
---------------
-------------------------
I School District: N YO ---------_______________________+
Acc Financing: ADJUSTABLE, CONVENTIONAL, CASH I
i Amenities:
1 Appliances: COUNTERTOP RANGE, WALL OVEN, INDOOR GRILL, MICROWAVE, DISH*
I Basement: EXPOSED/ WALKOUT,EXTERIOR ACCESS, FULL, FINISHED
1 Construction: WOOD I
I Cooling: CENTRAL AIR,OTHER 1
I Electric: CIRCUIT BREAKERS, 200+ AMPS
I Equipment: SECURITY SYSTEM, SAUNA/STEAM ROOM, HUMIDIFIER 1
I Exterior: REDWOOD
I Exterior Feat: EXISTING STORM WIN Dtfi,DECK, BALCONY, HOT TUB,STORAGE SHED*
I Fence Desc:
I Flooring: WALL TO WALL CARPET, WOOD, CERAMIC TILE
l Foundation:
I Heating: HEAT PUMP,CENTRAL HEAT,SOLAR
l Interior Feat: FIREPLACE, GAS,WET BAR,WALK-IN CLOSETS, SKYLIGHT
Lot Desc: WOODED, LEVEL, VIEWS
I Miscellaneous:
J Other Rooms: FAMILY ROOM, LIBRARY/ STUDY, OFF! CE /COMPUTER RM
prepared by: Ginny Mowery on November 15, 2001
I Parking:
I Roof:
I Style:
I Water Sewer:
I Waterfront Desc:
I Zoning:
I Farms:
I Outbuild:
+-----------------
PVD DR,2 CAR GAR
RUBBER
CONTEMPORARY
SEPTIC, WELL
Information Deemed Reliable
I
I
I
I
I
I
I
I
-------------------------------------
But Not Guaranteed. Page 2 of 2
Prepared by: Ginny Mowery on November 15, 2001
Equity Calculation For Lauri Crochunis at 1209 Doubling Cap Road Newville, PA
Sales Price S 300,000. S285,000.
Less 6% Commission $ 18,000. S 17,100.
Less Closing Costs S Soo. $ 500.
Less I% PA Transfer Tax $ 3,000. $2,850.
Net after Commission & Tax $ 278,500. $264,550.
Less Principal on Mortgage $ 179,048 $179,048.
Net after Principal paid off S99,452. $ 85,502.
Divided equally by 3 owners (Robert W.
Crochunis, Robert V. Crochunis, Lauri K.
Crochunis) Divide by 3 Divide by 3
Remaining for each owner $ 33,151. $ 28,501.
Less Reimburse payments on Mortgage from
Lauri Crochunis as per court order starting
5/2002. $ 31,311. S31,311.
Equity of Lauri after Mortgage Payments. S 1,840. (S2,810.)
Less Notarized Electric reimbursement to Rob
Crochunis $ 2,510. $ 2,510.
Equity after Electric Pmt. ($670.) ($5,320.)
Less Atty. Fees from 1' court hearing $1,975. $1,975.
Final Equity on Property ($ 2,645.) (S 7,295.)
?nllctIt)
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IN
<.:•.
THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
it
STATE OF PENNA.
..... .LAURI..MY..CROCHUNIS,
u....99.-.7.0.3.2.. ...CIVI.L.
.
....... ........... ........ Plaintiff.
Versus
..... ROBERT. WALTER CROCHUNIS, ................ _.
..Defendant _-
i
i
DECREE IN
DIVORCE
AND NOW, ......... ?!??.. • 3 • . • • • • • . zO°? • . it is ordered and
decreed that ........... LAURI..KAY..CROCRUNIS ................ Plaintiff,
and ...................ROBERT .WALTER. CROCHUNIS• • • • • • • • • • • . defendant,
are divorced from the bonds of matrimony. it is further ordered that the
terms of the Marital Settlement Agreement of the parties dated Fcy to ' :-
2000, shall be inco_r rated he e n, but te`red for the. e f nforcement
The court retUins iurtscic?ton ofqirol?owing clat?ns w ic`h noveonly.
been raised of record in this action for which a final order has not yet o
been entered;
None
.........................................................................
....... ........................................... G
i
By T Court ((a
Attesl?
Ib
--
Prothonotary ffJJ
t?
?} .y;., {v. .p:. W. {.:• •:.i •;G:• {G:• W. .W. {G: •:.:• {Gi •:ti •:.:• CG:• •:G:• •:Gi •Y:•~:G:• LG:• i0:• •:O:• ev. V- •:O:•^:G:• :G:• •Y:•
MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT, made this AQ day of c
;ZQW between LAURI KAY CROCHUNIS, hereinafter refer d to as
(WIFE) and ROBERT WALTER CROCHUNIS (hereinafter referred to as
HUSBAND).
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on May 2.4,
1980, in Cumberland County, Pennsylvania; and
r`:; .
WHEREAS, disputes and difficulties have arisen between the
parties, and it is the present intention of Husband and 'Wife tto
live separate and apart, and the parties hereto are desirous 'cif
settling 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 past, present, and future support and/or maintenance of Wife
by Husband or Husband by Wife; the settling of all matters between
them relating to the equitable division of marital property; and,
in general, the settling of any and all claims and possible claims
by one against the other or against their respective estates; and
WHEREAS, Husband and Wife declare that each has had a full and
fair opportunity to obtain independent legal advice of counsel of
his or her selection; that Wife has been represented by Linda a.
Clotfelter, Esquire and that Husband has been informed that he has
the right to independent legal counsel, but he has chosen not to be
represented in this action. The parties represent and warrant that
they have fully disclosed to each other all assets of any nature
owned by each, all debts or obligations for which the other party
may be liable in whole or part, and all sources and amounts of
income. The parties acknowledge that they fully understand the
facts, and they acknowledge and accept that this Agreement, is,
under the circumstances, fair and equitable, and that it is being
entered into freely and voluntarily, with such knowledge and that
execution of this Agreement is not the result of any duress or !
,
undue influence and that it is not the result of any improper or
illegal agreement or agreements.
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, Husband and
Wife, each intending to be legally bound hereby, covenant and agree
as follows:
1. PERSONAL RIGHTS. It shall be lawful for Husband and Wife
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 parties shall be free from any control, restraint,
interference or authority, direct or indirect, by the other in all
respects as fully as if they were unmarried, except as may be
necessary to carry out the provisions of this Agreement. Husband
and Wife shall not molest, harass, disturb or malign each other or
the respective families of each other nor compel or attempt to
compel the other to cohabit or dwell by any means in any manner
whatsoever with him or her. The foregoing provision 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.
2. MUTUAL RELEASE. Husband and Wife each do hereby
mutually remise, release, quitclaim and forever discharge the
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 gains from property
hereinafter accruing) of the other of whatever nature and
wheresoever situate, which he or she now has or at any time
hereafter may have against such other, whether arising out of any
former act, contracts, engagements or liabilities of such other or
by way of dower or curtesy; or claims in the nature of dower or
curtesy or widow's or widower's rights, family exception or similar
allowance, or any rights which any party may now have or any time
2
f • • 1 f
hereafter have for past, present, future support, maintenance,
alimony, alimony pendente lite, counsel fees, costs or expenses,
whether arising as a result of the marital relation or otherwise;
except all rights and agreements and obligations of whatsoever
nature arising or which may arise under this Agreement or for
breach of any provision hereof. It is the intention of Husband and
Wife to give to each other, by the execution of the Agreement, a
full, complete and general release with respect to any and all
property of any kind or nature, real, personal or mixed, which the
other now owns or may hereafter acquire, except and only except all
rights and agreements and obligations of whatsoever nature arising
or which may arise under this Agreement or for the breach of any
provision hereof.
It is further specifically understood and agreed by and
between the parties hereto that each accepts the provisions herein
made by the other in lieu of and in full settlement and
satisfaction of any and all of their rights against the other for
any past, present and future claims on account of support and
maintenance; that it is specifically understood and agreed that the
payments, transfers and other considerations herein recited so
comprehend and discharge any and all such claims by each other
against the other, and are, inter alia, in full settlement and
satisfaction and in lieu of their past, present and future claims
against the other in account of maintenance and support, and also
alimony, alimony pendente lite, counsel fees, costs and expenses,
as well as any and all claims to equitable distribution of
property, both real and personal, and any other charge of any
nature whatsoever pertaining to any divorce proceedings which may
have been or may be instituted in any court in the Commonwealth of
Pennsylvania or any other jurisdiction, including any other counsel
fees, costs and expenses incurred or to be charged by any counsel
arising in any manner whatsoever, except as may be incurred in
3
connection with a breach of the Agreement as set forth hereinafter
in paragraph 18.
3. FINANCIAL DISCLOSURE. The parties waive their rights to
require the filing of financial statements by the other, although
the parties have been advised that it is their legal right to have
these disclosures made prior to entering into this Agreement and by
entering into this Agreement without reliance upon financial
disclosure, the parties are forever waiving their right to request
or use that as a basis to overturn this Agreement or any part
thereof.
4. INCOME TAX CONSIDERATIONS. The transfers of property
pursuant to this Agreement are transfers between Husband and Wife
incident to their divorce and as such are nontaxable, with no gain
or loss recognized. The transferee's basis in the property shall
be the adjusted basis of the transferor immediately before the
transfer. The transfers herein are an equal division of marital
property for full and adequate consideration and as such will not
result in any gift tax liability.
5. PENSION. PROFIT-SHARING. RETIREMENT CREDIT UNION OR
OTHER EMPLOYMENT-RELATED PLANS. The parties hereto expressly waive
and relinquish any right, claim, title or interest in any pension,
profit-sharing, retirement, credit union or other employment-
related plans in which the other has any interest by virtue of his
or her past or present employment, whether vested or unvested,
matured or unmatured.
6. EOUITABLE DISTRIBUTION OF MARITAL PROPERTY. The parties
have attempted to distribute their marital property in a manner
which conforms to the criteria set forth in Section 3502 of the
Pennsylvania Divorce Code and taking into account the following
considerations: the length of marriage; the fact that it is the
first marriage for Husband and Wife; the age, health, station,
amount and sources of income, vocational skills, employability,
estate, liabilities and needs of each of the parties; the
4
contribution of each party to the education, training or increased
earning power of the other party; the opportunity of each party for
further acquisitions of capital assets and income; the sources of
income of both parties, including but not limited to medical,
retirement, insurance or other benefits; the contribution or
dissipation of each party in the acquisition, preservation,
depreciation or appreciation of the marital property, including the
contribution of each spouse as a homemaker the value of the
property set apart to each party; the standard of living of the
parties established during the marriage; and the economic
circumstances of each party at the time the division of the
property is to become effective.
The division of existing marital property is not intended by
the parties to constitute in any way a sale or exchange of assets,
and the division is being effected without the introduction of
outside funds or other property not constituting marital property.
The division of property under this Agreement shall be in full
satisfaction of all marital rights of the parties.
A. MOTOR VEHICLES. The parties agree that each
shall have full and sole possession and shall become full and
sole owner of the vehicle presently within his or her
possession. On or before the date of the execution of this
Agreement, the parties shall execute the titles to the said
vehicles, if appropriate, so as to effectuate the transfer as
herein provided. Furthermore, each party shall become solely
responsible for the financial obligation associated with the
vehicle he or she is to retain pursuant to this Agreement, if
any, and each party agrees to indemnify and hold harmless the
other party from any and all liability therefor.
B. DISTRIBUTION OF PERSONAL PROPERTY. The parties
hereto mutually agree that they have effected a satisfactory
division of the furniture, household furnishings, appliances,
and other household personal property between them, and they
5
t
w?s?nsafnsa?ne?ian ? --
mutually agree that each party shall from and after the date
hereof be the sole and separate owner of all such tangible
personal property presently in his or her possession, and this
Agreement shall have the effect of an assignment or bill of
sale from each party to the other for such property as may be
in the individual possession of each of the parties hereto.
From and after the date of the signing of this Agreement,
both parties shall have complete freedom of disposition as to
their separate property and any property which is in their
possession or control, pursuant to this Agreement, and may
mortgage, sell, grant, convey, or otherwise encumber or
dispose of such property, whether real or personal, whether
such property was acquired before, during, or after marriage,
and neither Husband nor Wife need join in, consent to, or
acknowledge any deed, mortgage, or other instrument of the
other pertaining to such disposition of property.
C. DISTRIBUTION OF CASH ASSETS STOCKS AND BONDS. The
parties agree that they shall each retain an interest in the
joint bank account until such time as the marital residence is
sold. Upon the sale of the marital residence, any sums
remaining in the joint bank account shall be distributed
equally. The parties acknowledge herein that it is their
intent to have the funds of the joint bank account expended
for the expenses incident to the marital residence until sold.
D. REAL ESTATE. The parties acknowledge that they are
the joint owners of the marital residence situate at 1209
Doubling Gap Road, Newvil 1 e, Cumberland County, Pennsylvania.
The parties hereby agree that the marital residence shall be
listed for sale and sold as soon as is reasonably possible.
The parties further agree that the proceeds of the sale shall
be divided equally, subject to the terms below, after the full
payment of the following: the fees, costs, or expenses
incident to the transfer of the said marital residence, and
6
i
,i?
the first mortgage. Husband and Wife further stipulate and
agree that any expenses incurred to repair and/or prepare the
marital residence for the sale shall be paid by the proceeds
of the sale prior to the distribution of proceeds to the
parties.
From the date of this Agreement, Husband shall assume as
his sole obligation all of the expenses incident to the use
and ownership of the said marital home, including, without
limitation, any and all mortgage payments, taxes, liability
and fire insurance, utilities, sewer, water, refuse
collection, assessments, proper maintenance, repairs,
additions and improvements, and further covenants and agrees
to indemnify and hold Wife harmless from any such liabilities,
obligations or expenses or any claims or demands as a result
thereof. Husband represents and warrants that all such
mortgage payments, taxes, insurance and other expenses related
to the marital residence are paid in full up to and including
the calendar month in which this Agreement is executed. Any
such expenses which are unpaid shall be paid by Husband,
together with any applicable late charges within thirty (30)
days of this Agreement. The parties also acknowledge that
Husband shall have the sole right to claim any available tax
deductions associated with the said residence for any time
subsequent to the date of Wife's relocation and move from the
marital residence.
1. The parties stipulate and agree that neither
party shall cohabitate in the marital residence with any
person not a party to this Agreement without the prior
written consent of the other party. Cohabitation shall
be defined for purposes of this paragraph only, as
including a period of time excluding two (2) weeks and
the two (2) week period need not include fourteen (14)
consecutive overnight periods to be considered
7
"cohabitation." Any person not Husband or Wife that is
at the marital residence regularly and consistently for
a period of time excluding two (2) weeks shall be
considered "cohabitation" under the terms of this
Agreement and it includes any and all individuals
excepting Husband and Wife, the parties therein.
2. The parties hereto acknowledge that they have
a potential purchaser for a portion of the real estate
known as the marital residence. Accordingly, it is
agreed by Husband and Wife to execute an Agreement for
sale and Purchase of Real Estate with Dennis E. Burnhisel
(hereinafter known as "Buyer") regarding the tract of
undeveloped land which is part of the marital real estate
located on the side of Doubling Gap Road, opposite the
marital residence. The parties agree to sell said
property with any and all expenses incurred, including
but not limited to survey and subdivision costs, being
borne by Buyer. The parties hereto acknowledge that they
need to obtain a Partial Release of Mortgage regarding
said tract of undeveloped land, to proceed to sell same.
Accordingly, the parties stipulate and agree that they
shall cooperate as necessary to effectuate the completion
and filing of a Partial Release of Mortgage, and the
parties shall share equally the processing fee of M & T
Mortgage Corporation, as well as the preparation and
filing fees and costs for the Partial Release of
Mortgage. The parties further stipulate and agree that
the proceeds of the sale of the undeveloped tract of land
as described above, shall be the exclusive property of
wife as per the equitable distribution of marital
property addressed in this Agreement.
The parties further acknowledge herein that they do
not intend, in any way, to confer any third party
8
beneficiary rights upon Dennis E. Burnhisel, Buyer, as
the potential purchaser of the undeveloped tract of land,
as a result of the execution of this Agreement by Husand
and Wife.
E. DEBTS. Husband represents and warrants to Wife that
since the separation he has not, and in the future he will not
contract or incur any debt or liability for which Wife or her
estate might be responsible, and he shall indemnify and save
Wife harmless from any and all claims or demands made against
her by reason of such debt or obligation incurred by him since
the date of said separation, except as otherwise set forth
herein.
Wife represents and warrants to Husband that since the
separation she has not, and in the future she will not,
contract or incur any debt or liability for which Husband or
his estate might be responsible, and she shall indemnify and
save Husband harmless from any and all claims or demands made
against him by reason of such debts or obligations incurred by
her since the date of said separation, except as otherwise set
forth herein.
Husband hereby assumes and shall be solely responsible
and liable for the payment of the following obligations:
a. The mortgage and any and all other expenses related to
the marital residence until it is sold;
b. The personal loan for $42,000.00 owed to Robert V.
Crochunis; and
C. The 401(K) loan (since wife is waiving rights in same.)
Husband shall immediately upon execution of this
Agreement take such steps as are necessary to transfer
ownership of the said accounts and obligations to his name
solely, obtaining a full, complete and general release of Wife
from t he said creditors. In the event that the creditors
refuse for any reason to transfer the charge accounts to
9
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Husband's name absolutely and to release Wife from any
liability thereon, such accounts shall be immediately closed.
7. INCOME TAX INDEMNIFICATION. The parties acknowledge that
they have filed various joint state and federal income tax returns
during the course of their marriage. Husband acknowledges and
agrees that he has been in sole possession and control of all
records and information. Husband represents and warrants that all
payments of taxes, penalties or interest shown as due on the said
joint returns have been paid in full. Husband shall indemnify and
save Wife harmless from any taxes, penalties, interest, counsel
fees, auditor's fees or accountant's fees which may hereafter be
assessed or incurred in connection with any of the joint tax
returns previously filed by the parties.
8. LIFE INSURANCE. Husband and Wife acknowledge that they
each have one life insurance policy. Each shall maintain the
current life insurance coverage under the same terms and conditions
and shall continue to list the other party as sole beneficiary
until the divorce decree is issued.
9. COUNSEL FEES AND COSTS, Husband and Wife each agree to
pay and be responsible for their own attorney's fees and costs
incurred with respect to the negotiation of this property
settlement agreement and the divorce proceedings related thereto.
10. ALIMONY ALIMONY PENDENTE LITE COUNSEL FEES AND
EXPENSES. Both parties accept the provisions of their Agreement in
lieu of and in full and final settlement and satisfaction of all
claims and demands that they may now or hereafter have against the
other for alimony, alimony pendente lite, counsel fees or expenses,
or for any other provisions for support and maintenance before,
during and after the commencement of any proceedings for the
divorce or annulment between the parties.
11. DIVORCE. A Complaint in Divorce has been filed to No.
99-7037 Civil in the Court of Common Pleas of Cumberland County,
Pennsylvania, and either party shall be free to proceed without
10
further delay to secure the divorce. Both parties shall sign an
affidavit evidencing their consent to the divorce, pursuant to
Section 3301(c) of the Divorce Code. In the event, for whatever
reason, either party fails or refuses to execute such affidavit
upon the other party's timely request, that party shall indemnify,
defend and hold the other harmless from any and all additional
expenses, including actual counsel fees, resulting from any action
brought to compel the refusing party to consent. Each party hereby
agrees that a legal or equitable action may be brought to compel
him or her to execute a consent form and that, absent some breach
of this Agreement by the proceeding party, there shall be no
defense to such action asserted.
12. BANKRUPTCY. The parties further warrant that they have
not heretofore instituted any proceedings pursuant to the
bankruptcy laws nor are there any such proceedings pending with
respect to them which have been initiated by others. It is
stipulated and agreed by the parties that the terms of this
Agreement as they resolve the economic issues between the parties
incidental to their divorce and the obligations of the parties to
each other resulting therefrom shall not be dischargeable in
bankruptcy, should either party file for protection under the
Bankruptcy Code at any time after the date of execution of this
Agreement.
The payments called for in this Agreement are not intended to
be a debt which is affected by a discharge in bankruptcy and the
terms of this Agreement are not subject to discharge in bankruptcy
because the parties acknowledged that such are necessary for the
parties to meet their financial obligations and to support and
maintain their standard of living. The parties acknowledge that
there are not bankruptcy proceedings presently pending and they
agree not to file a bankruptcy action prior to the completion of
their respective obligations pursuant to this Agreement.
Furthermore, any debt addressed in this Agreement shall not be
11
discharged in a bankruptcy action filed by or on behalf of one of
the parties hereto. Also, if either party files for bankruptcy,
this Agreement shall constitute conclusive evidence of the parties'
intent that the obligations of this Agreement are in the nature of
maintenance and support are not dischargeable under current
bankruptcy law or under any amendment thereto. Further if either
party institutes any action in bankruptcy or any other bankruptcy
proceeding is instituted in which a party's right to have payments
made by the other becomes.a matter for judicial review, the parties
agree to consent to any motion filed by the other with the
bankruptcy courts, wherein the party may request that the
bankruptcy courts abstain from deciding the dischargeability of
said obligation and any other obligations to said party thereunder
in order to allow the appropriate Court of Common Pleas to rule
upon this issue.
13. RECONCILIATION. Notwithstanding a reconciliation between
the parties, this Agreement shall continue to remain in full force
and effect absent a writing signed by the parties stating that this
Agreement is null and void.
14. INCORPORATION IN FINAL DIVORCE DECREE. The terms of this
Agreement shall be incorporated but shall not merge in the final
divorce decree between the parties. The terms shall be
incorporated into the final divorce decree for the purposes of
enforcement only and any modification of the terms hereof shall be
valid only if made in writing and signed by both of the parties.
Any Court having jurisdiction shall enforce the provision of this
Agreement as if it were a Court Order. This Agreement shall
survive in its entirety, resolving the spousal support, alimony,
equitable distribution and other interests and rights of the
parties under and pursuant to the Divorce Code of the Commonwealth
of Pennsylvania, and no court asked to enforce or interpret this
Agreement shall in any way change the terms of this Agreement.
This Agreement may be enforced independently of any support order,
12
IF_ _.
i
divorce decree or judgment and its terms shall take precedence over
same, remaining the primary obligation of each party. This
Agreement shall remain in full force and effect regardless of any
change in the marital status of the parties. It is warranted,
covenanted and represented by Husband and Wife, each to the other,
that this Agreement is lawful and enforceable, and this warranty,
covenant and representation is made for the specific purpose of
inducing the parties to execute the Agreement.
15. DATE OF EXECUTION. The "date of execution" or "execution
date" of the Agreement shall be defined as the date upon which it
is executed by the parties if they have each executed the Agreement
on the same date. Otherwise, the "date of execution" or "execution
date" of this Agreement shall be defined as the date of execution
by the party last executing the Agreement.
16. FULL DISCLOSURE. Each party asserts that he or she has
made or shall make a full and complete disclosure of all the real
and personal property of whatsoever nature and wheresoever located
belonging in any way to each of them, of all debts and encumbrances
incurred in any manner whatsoever by each of them, and of all
sources and amounts of income received or receivable by each party.
17. ENTIRE AGREEMENT. This Agreement contains the entire
understanding of the parties, and there are no representations,
warranties, covenants or undertakings other than those expressly
set forth herein.
18. BREACH. If either party breaches any provision of this
Agreement, the other party shall have the right, at his or her
election, either to pursue his or her rights in having the terms of
this Agreement enforced as an Order of Court or to sue for specific
performance or for damages for such breach, and the party breaching
this Agreement shall be responsible for legal fees and costs
incurred by the other in enforcing his or her rights under this
Agreement.
13
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19. PENNSYLVANIA LAW. The parties agree that the terms of
this Agreement and any interpretation and/or enforcement thereof
shall forever be governed by the Laws of Pennsylvania.
20. WAIVER OR MODIFICATION TO BE IN WRITING. No modification
or waiver of any of the terms hereof shall be valid unless made in
writing and signed by both of the parties.
21. ADDITIONAL INSTRUMENTS. Each of the parties shall from
time to time, at the request of the other, execute, acknowledge,
and deliver to the other party any and all further instruments,
including deeds and other real estate-related documents, titles, or
other documents that may be reasonably required to give full force
and effect to the provisions of this Agreement.
22. SEVERABILITY. If any term, condition, clause or
provision of this Agreement shall be determined or declared to be
void or invalid in law or otherwise, then only that term,
condition, clause or provision shall be stricken from this
Agreement, and in all other respects this Agreement shall be valid
and shall continue in full force, effect and operation.
23. WARRANTY. Husband and Wife again acknowledge that they
have each read and understand this Agreement, and each warrants and
represents that it is fair and equitable to each of them.
24. DESCRIPTIVE HEADINGS. The descriptive headings used
herein are for convenience only. They shall have no effect
whatsoever in determining the rights or obligations of the parties.
14
IN WITNESS WHEREOF, and intending to be legally bound hereby,
the parties hereto have hereunto set their hands and seals the day
and year first above written. This agreement is executed in
duplicate, and each party hereto acknowledges receipt of a duly
executed copy thereof.
WITNESSES:
C ?
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/ LAURI KAY/CRO IS
ROBERT WALTER CRr HUNIS
C
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F.
COMMONWEALTH OF PENNSYLVANIA
:SS
COUNTY OF CUMBERLAND
On this LI tday of JZ0;1 ca,ti "?O- n
before me, the undersigned officer, p sonally appeared LAURI KAY
CROCHUNIS, known to me (or satisfactorily proven) to be the person
whose name is subscribed to the within Agreement, and acknowledged
that he/she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
lM- ? • j ld??'L'2o'7 NOTARY PUBLIC
Notarial Seal
Cynthia A. Rosborough, Notary Public
Silver Spring Twp., Cumberland County
My Commission Expires Aug. 5, 2003
Member, Pennsylvania Association of Notanes
COMMONWEALTH OF PENNSYLVANIA
:SS
COUNTY OF CUMBERLAND
On this /0 Tll day of re bryaA y t:7?n-a
before me, the undersigned officer, 1ersonally appeared ROBERT
WALTER CROCHUNIS, known to me (or satisfactorily proven) to be the
person whose name is subscribed to the within Agreement, and
acknowledged that he/she executed the same for the purposes therein
contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
NOTMZY PUBLIC
Notarial Seal
Cynthia A. Rosborough, Notery Public
Silvat Spring Twp., Cumberlantl County
My Commission Expires Aug. 5, 2003
Member, Pennsylvania AsSgtlalionot Notaries
16
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LAURI RAY CROCHUNIS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
Vs. NO. 99-7037 CIVIL
ROBERT WALTER CROCHUNIS, CIVIL ACTION - LAW
Defendant IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Kindly transmit the record, together with the following
information, to the Court for entry of a divorce decree:
1. The ground for divorce is irretrievable breakdown under
Section 3301 (c) of the Divorce Code.
2. The Complaint was filed on November 22, 1999.
3. Date and manner of Service of the Complaint: November
23, 1999, by Acceptance of Service, as evidenced by the Acceptance
of Service filed on December 7, 1999.
4. The Plaintiff's Affidavit of Consent was executed by the
Plaintiff on February 17, 2000, and filed on February 25, 2000. The
Defendant's Affidavit of Consent was executed on February 16, 2000,
and filed on February 25, 2000.
5. Plaintiff executed a Waiver of Notice of Intention to
Request Entry of a Divorce Decree under 3301 (c) of the Divorce
Code on February 17, 2000, and said waiver was filed on February
25, 2000. Defendant executed a Waiver of Notice of Intention to
Request Entry of a Divorce Decree under 3301 (c) of the Divorce
Code on February 16, 2000, and said waiver was filed on February
25, 2000.
6. There are no related claims pending. The parties have
resolved all related issues by written agreement
LAW OFFICES OF CRAIG A. DIEHL
Date: UO By:
nda A. of elter,
torney I.D. No. 729
J464 Trindle Road
Camp Hill, PA 17011
(717) 763-7613
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Cro chu.nl S (IN THE COURT OF COMMON PLEAS OF
PLAINTIFF,
Form 3
( C'tm 2.bLL COUNTY, PENNSYLVANIA
v.
(CIVIL DIVISION
/RaleA Wcaye.lr l lOCh?nl (NO: W-7037 ?e y
DEFENDANT.
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIM
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 VIS-
ITATION OF YOUR CHILD(REN).
WHEN THE GROUND FOR THE DIVORCE ARE INDIGNITIES OR IRRETRIEVABLE
BREAKDOWN OF THE MARRIAGE, YOU MAY REQUEST MARRIAGE COUNSELING. A
LIST OF MARRIAGE COUNSELORS IS AVAILABLE IN THE OFFICE OF THE PROTHONO-
TARYAT 0_I.IYV\?,Pr'In,nr1
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS
FEES, OR EXPENSES BEFOREA 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.
LAWYERS REFERRAL SERVICE
_P A L.au L r e fie,-,-,. N.
Telephone:
(Z- (0`1 - 7 3-j S
or Petitioner > C//
Address:_ 12.01\ Gap`} )cA
hlew?'i\\e 4A 11241
Telephone: -I 11-1 l(< - (n 5 15
123
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Form. 4
Kai, I o f h ^ , _ (IN THE COURT OF COMMON PLEAS OF
PLAINTIFF,
(---QUrm6Q1?0v_1&.COUNTY, PENNSYLVANIA
(CIVIL DIVISION
i.(?h a r W [,??' e.C ?"O C Yt 1 ri 15
DEFENDANT.
(NO: 09_ '7o3r1 CCtn.Q -
Ii-COMPLAINT IN DIVORCE
AND NOW COMES, the Petitioner, .-0.u_ c\ ro C A\ 0) by FILING PRO SE, SA YN who files this Complaint in Divorce a statement of which is as follow:
1. The Petitioner is L o.\jc t Kt, i A C ?A? un't S an adult individual currently residing
at_12,0q 11n 11 nCao 0n n A %,IN--, .:tt„ .m .-,A .
2. The Defendant
at 120Ck %)c
an adult individual currently residing
3. The Petitioner has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6)
months previous to the filing of this Complaint.
4. The Petitioner and Respondent were married on date: M n_ a '7 t} 1 Q d in the State
Of_T_!tonNu1Jctn;t?
5. There (is) are _9L child(ren) bom of this marriage. Name(s)
6. Neither party is a member of any branch of military.
7. The marriage is irretrievably broken.
8. The Petitioner, L ct"r t kau C t o C In u n t C respectfully requests this Honorable
Court to a grant this Divorce pursuant to Section 3301 (c), or in the alternative, Section 3301 (d) of
the Divorce Code.
;Resp ally submitted me:_L_0.y.lr't K , 11 r0CAVt._Y\1S
Full Address: 1202 T„ ,1„1 to. &3 n IcIA
Uews,tllc?"PP, 1'1241
Telephone: -11_ - l 1 - 5r r( S:
1 verify that the statements made in the Complaint are true and correct. I understand that false state-
ments made herein are subject to penalties of 18 Pa. C.S. . Section 490 relating to unstvom falsification to
authorities. `
Dated:
124
Birthdate(s):
Forin S
LCLSl,Y 1 Kr , \ ro t S (IN THE COURT OF COMMON PLEAS OF
PLAINTIFF,
( C u yn)0 u r 1 r y% N COUNTY, PENNSYLVANIA
v.
( CIVIL DIVISION
" pA et' ` W0.\1 r 1 roc h?.?.n S ( NO:
DEFENDANT.
AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
) ss:
COUNTY OF:
Before me, the subscriber, a Notary Public in and for said Commonwealth and
County, personally appeared 1_a-car' K. Ccvcl?o nl ar who being
duly sworn according to law, deposes and says that the facts contained within the foregoing
Complaint in Divorce are true and correct to the best of his/her knowledge, information, and
belief, and that he/she is authorized to make this Affidavit.
Sworn to and subscribed before me this
^ 4 h In9Cl
as day of
?L1-r-T l'1'1 K ?e--
NOTARY PUBLIC
NOTARIAL SEAL ;
ELAINE M. REGI, Nolary Pubhc
City of Carlisle. Cumberland County
My Commission EX01res Nov 6.2000 i
i
125
.r®
Form 13
CtuYJL r?c COUNTY COURT OF COMMON PLEAS
CIVIL COVER SHEET
Docket No.
I 1 (a) PLAINTIFFS DEFENDANTS
'i ?.- 0.t..t t' t KCI. CMG L?u.Y\ [ 5 ?Gb Lt"? tW 0.`-1 '?-? Coo ? `U.Y11 5
(b) PLAINTIFF'S ATTORNEYS (ADDRESS) DEFENDANT'S ATTORNEY'S (IF KNOWN (ADDRESS)
N /Pt N/A
IL MANDATORY ARBITRATION 111. ALTERNATE DISPUTE RESOLUTION REOUESTED
Does this fall tinder the mandatory arbitration Stunmary Jury Trial
j requirements per Local Rule 1301? Other: See "Guide to Alternate Dispute
ii Resolution Programs" Published by the
Yes or No County Bar Association
IV. CA?(;i) OF ACTION (Cite the statutes or rules of late under which you are filing and write a brief statement of
causes(s).)
2. c ce?ct evab\
V. GENERAL NATURE OF SUIT (Place an X in one area only that most accurately describes your case)
CONTRACT
_ Insurance
_ PA Bond
Collection Suits
_ Construction
Other - List in
IV above
REAL. PROPERTY
Condemnation
_ Foreclosure
_ Landlord & Tenant
_ Partition
Mechanics' Lien
Environment
_ Other - List
in IV above
Address of Property
Is this an
PERSONAL INJURY
Motor Vehicle DOMESTIC RELATIONS
Divorce
Product Liability _ Protection from Abuse
Medical Malpractice _ CustodyNisitation
Other Prof. Liability _ Other - List in IV above
Intentional _ Support
_ Premises
Other - List in OTHER STATIlTE_S
IV above _ Zoning Appeal
School Board Appeal
PRISONER PETITIONS _ License Suspension Appeal
_ Habeas Corpus -Assessment Appeal
Mandamus _ Other - List in 1V above
Other - List in
IV above _TAX I ITN &
TAX MATTERS
_ LABOR OTHER
List in IV above
ty case? Yes or No (b) Does it involve a g overnmental body? Yes or No
VI. ORIGIN (Mark only l)
1 Original _ 2 Removed from
Complaint Federal Court
of Writ
_ 3 Confessed _ 4 Transferred _ i Appeal
Judgments by From Another From
Complaint Disw.ct or Govt.
or Praecipe County (specify) Agency
6 Appeal to _ 7 Foreign
Court from Judgment
(a) Is this a CLASS ACTION YES oNO
(c) Amount demanded in complaint _
(b) Circle YES only if jury demanded in complaint:
JURY DEMAND: YES or NO
Will you accept 6 jurors? YES or NO
vnI or.I .? n r•eeCle\ In ANV 11 IIICP
nhCKFT NUMBER
136
Form 6
COUNTY COURT OF COMMON PLEAS
INTAKE
THIS FORM MUST BE FILLED OUT IF YOU ARE FILING A DIVORCE OR CUSTODY
ACTION IN THE PROTHONOTARY'S OFFICE:
TODAY'S DATE:
CASE NUMBER:
PLEASE CHECK ONE:
0 DIVORCE FILING - NO CHILDREN:
Q DIVORCE FILING - W/CHILDREN UNDER 18:
? CUSTODY FILING - W/CHILDREN UNDER 18:
PLAINTIFF/PETITIONER NAME AND ADDRESS:
Lam. u.t 1 Kat.? Cro c.1-tu.v?? S
N ?-w v;1\e, ?'1' A 1'l Z?1.1
DEFENDANT/RESPONDENT NAME AND ADDRESS:
?I.ob?rt VoAe-v Cco?hUr?S
\ Z.O ?oub 1 hc? Gc??'?' pc?
New v;\l??'i A 1rA2°\- \
?I
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LAURI RAY CROCHUNIS,
Plaintiff
VS.
ROBERT WALTER CROCHUNIS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
N0. 99-7037 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
ACCEPTANCE OF SERVICE
I, ROBERT W. CROCHUNIS, Defendant in the above-captioned
matter hereby accept service of the Complaint in Divorce filed by
Plaintiff. Service is accepted on the 2_S day of November,
1999.
14 2?1
BERT W. CROCHUNIS, Defendant
LAURI KAY CROCHUNIS,
Plaintiff
vs.
ROBERT WALTER CROCHUNIS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7037 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this 2ZA day of ,J?CE?YI Kul , 1999,
the undersigned hereby certifies that a true and correct copy of
the foregoing ACCEPTANCE OF SERVICE was served upon the opposing
party by hand delivery at the following address:
Robert W. Crochunis
1209 Doubling Gap Road
Newville, Pennsylvania 17241
Date:
Lauri Kay Crochu S??
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LAURI RAY CROCHUNIS,
Plaintiff
VS.
ROBERT WALTER CROCHUNIS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7037 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the
Divorce Code was filed on November _,'2- , 1999.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing
and service of the Complaint.
3. I consent to the entry of a final decree of divorce after
service of notice of intention to request entry of the decree.
4. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees and expenses if I do not claim
them before a divorce is granted.
I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. Section 4904, relating to
unsworn falsification to authorities.
Date:
KAY CRO(CVNI$; Plaintiff
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LAURI RAY CROCHUNIS,
Plaintiff
vs.
ROBERT WALTER CROCHUNIS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7037 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO
REQIIEST ENTRY OF A DIVORCE DECREE
UNDER , 3301 (C) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce
without notice.
2. I understand that I may 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. S 4904 relating to unsworn
falsification to authorities.
Date: ?1 DO
-i
LAURI KAY CR H S, Plaintiff
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LAURI RAY CROCRUNIS,
Plaintiff
vs.
ROBERT WALTER CROCHUNIS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7037 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the
Divorce Code was filed on November 1999.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing
and service of the complaint.
3. I consent to the entry of a final decree of divorce after
service of notice of intention to request entry of the decree.
4. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees and expenses if I do not claim
them before a divorce is granted.
I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. Section 4904, relating to
unsworn falsification to authorities.
Date:
rOB-?RT W. CRO HUNIS, Defendant
.L
LAURI RAY CROCHUNIS,
Plaintiff
Vs.
ROBERT WALTER CROCHUNIS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7037 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO
REQUEST ENTRY OF A DIVORCE DECREE
UNDER $ 3301 (C) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce
without notice.
2. I understand that I may 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. § 4904 relating to unsworn
falsification to authorities.
,
Date:
JzbBERT W. CROCHJNIS, Defendant
U
LAURIE KAY CROCHUNIS, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PA
VS.
NO. 99-7037 CIVIL
ROBERT WALTER CROCHUNIS,
Defendant : CIVIL ACTION-LAW
ORDER OF COURT
AND NOW, this _2jL( day of c [• , 2002, upon consideration of the
foregoing Petition for Contempt and to Modify Marital Settlement Agreement, a
hearing is scheduled for the day of :22Z d j,12-A 2002, Courtroom
at 10: jo A.M., Cumberland County Courthouse, Carlisle, Pennsylvania.
BY THE COURT,
J.
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D' nbution:
Jo -W. Purcelll, Jr., Esq., 1719 N. Front St., Harrisburg, PA 17102
mda A. Clotfelter, Esq., 3464 Trindle Rd., Camp Hill, PA 17011
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LAURI KAY CROCHUNIS,
Plaintiff
VS.
ROBERT WALTER CROCHUNIS,
Defendant
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7037 CIVIL
CIVIL ACTION-LAW
PETITION FOR CONTEMPT AND TO MODIFY
MARITAL SETTLEMENT AGREEMENT
1. The Petitioner is Robert Walter Crochunis, the Defendant in the above
captioned matter.
2. The Respondent is Lauri Kay Crochunis, the Plaintiff in the above captioned
matter.
3. On February 10, 2000, the parties entered into a Marital Settlement
Agreement (hereinafter "Agreement"), by which they apparently settled all of their
differences, and resolved all of the issues relating to their divorce, or so it seemed at
the time.
4. Pursuant to the Marital Settlement Agreement, a Divorce Decree was
entered on March 3, 2000, which Decree incorporated the Marital Settlement
Agreement therein. A copy of the Decree and Agreement is attached hereto as
Exhibit "A".
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5. Pursuant to paragraph 6(D) of the Agreement, the parties agreed that they
would sell the marital residence located at 1209 Doubling Gap Road, Newville,
Cumberland County, Pennsylvania, "as soon as is reasonably possible", with the
proceeds of the sale then being divided equally after deduction of the expenses listed
therein.
6. In addition, pending the sale, Husband agreed to assume the sole obligation
of all the expenses incident to the use and ownership of the marital home, including
but not limited to the mortgage payments, taxes, liability and fire insurance, utilities,
sewer, water, refuse, collection, assessments, proper maintenance, repairs, additions
and improvements.
7. In paragraph 6(D)(1) the parties further agreed that neither party would co-
habitate in the marital residence with any person not a party to the Agreement
without the prior written consent of the other party.
8. Pursuant to the Agreement Petitioner and Respondent entered into a
Listing Agreement with a reputable real estate broker, and placed the property on
the market for sale.
9. During the time that the party has been under Listing Contract, and
thereafter, for the past year and one half, Respondent has obstructed attempts to sell
the property, by making unreasonable demands on potential sale prospects, refusing
ar, I.
.4to show the home, refusing to re-list once the Listing Contract has expired, and
otherwise creating an inhospitable environment to sell the home.
10. Additionally, Respondent has had a male adult cohabiting with her in the
marital residence for a period in excess of two weeks, in violation of the provisions of
the Agreement.
11. The Respondent has an obligation to make a good faith effort to sell the
property.
12. The Respondent has not made a good faith effort to sell the property, in a
blatant attempt to keep the property from selling, which forces the Petitioner to
continue to pay all of the expenses of maintaining the home for the benefit of the
Respondent, in excess of the time frame contemplated by either party.
13. The Petitioner has recently requested the Respondent to enter into an
additional Listing Agreement, at a reduced listing price, upon the advice of the
realtor, which the Respondent has refused.
14. Pursuant to Paragraph 6(B) of the Agreement, the parties mutually divided
their personal property. Subsequent thereto, Respondent agreed to allow Petitioner to
store his personal property, already divided between the parties, in the marital home
until it could be retrieved by him, or the home was sold.
J
15. Since then, Respondent has refused to allow, and has discouraged
Petitioner from retrieving his personal property.
16. Paragraph 18 of the Marital Settlement Agreement provides that if either
party breaches any provision of the Agreement, the other party shall have the right to
seek specific performance, or seek damages for the breach, and the party breaching
the Agreement shall be responsible for the legal fees and costs incurred by the other
in enforcing his or her rights under the Agreement.
17. The Respondent is in breach of the Agreement, and is responsible for the
attorney's fees and costs incurred by the Petitioner to enforce the Agreement.
WHEREFORE, the Petitioner requests this Honorable court to:
A. Schedule a hearing on the Petitioner's Petition and thereafter to; and
B. Enter an Order holding the Respondent in contempt of Court; and
C. Order the Respondent to execute any and all documents necessary to list
the property for sale at a reasonable price and to enjoin her from rejecting any
reasonable offer made, or in the alternative, enter an order allowing the Petitioner to
enter into all contracts necessary to sell the property without the consent or
.dsignature of the Respondent, at a price at least sufficient to cover the payoff of
mortgages and settlement costs; and
D. Enter an Order absolving the Petitioner from any continuing obligation to
pay the costs and expenses of maintaining the marital home pending the sale of the
real estate; and
E. Enter an Order allowing Petitioner to retrieve his personal property from the
marital home; and
F. Enter an Order enjoining the present male co-habitant from living in the
marital home; and
G. Enter an Order awarding counsel fees and costs to the Petitioner; and
H. Grant such further relief as the Court deems equitable and just.
Respectfully submitted,
PURCELL, KRUG & HALLER
Lfgtm W-Purcell, Jr.
D.#29955
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
916011
STATE OF qtr=:, PENNA.
.... LAURI . KAY.. CROCHUNIS............. .............._... !I
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Pla.in.t i,f f . .................................
Versus
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....RODERT..WALTER•.C.ROCHUNIS .......................
-........ ...Def.endant .
No ...... 9.9-..7.03.7 ..CIVSL.
DECREE IN
D I V ORCE
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AND NOW,...... Narch:3 ................. .zooo•, it is ordered and
decreed that .......... LAURI..KAY. CROCHU.NIS ................. Plaintiff, ;.
4
••
g and . ..............ROBERT. TIALTER CROCP.UNIS ............... defendant,
are divorced from the bonds of matrimony. it is fu.:ther ordered that
the terms of the Marital Settlement Agreement of the parties dated
d 2000, all be co rated he e n but t red for t}?e .?v poly If nforcement
ur "rRo s iurlsKY15n of die" o?owing c al s w icn Piave
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been raised of record in this action for which a final order has not yet ro
been entered;
..................None................................................... ,
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? By The Court: `
c /s/ Kevin A. Hess
Attest: +
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Fro;^onolary
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CEnTIFIED COPY
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Exhibit "A"
MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT, made this ?[) day of I2-41, 00-4
Et,.,,, between LAURI KAY CROCHUNIS, hereinafter referred to as
(WIFE) and ROBERT WALTER CROCHUNIS (hereinafter referred to a:;
HUSBAND).
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on.May 24,
1980, in Cumberland County, Pennsylvania; and
WHEREAS, disputes and difficulties have arisen between the
parties, and it is the present intention of Husband and Wife, to
live separate and apart, and the parties hereto are desirous of
settling 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 past, present, and future support and/or maintenance of Wife
by Husband or Husband by Wife; the settling of all matters between
them relating to the equitable division of mariL-al property; and,
in general, the settling of any and all claims and possible claims
by one against the other or against their respective estates; and
WHEREAS, Husband and Wife declare that each has had a full and
fair opportunity to obtain independent legal advice of counsel of
his or her selection; that Wife has been represented by Linda a.
Clotfelter, Esquire and that Husband has been informed that he has
the right to independent legal counsel, but he has chosen not to be
represented in this action. The parties represent and warrant that
they have fully disclosed to each other all assets of any nature
owned by each, all debts or obligations for which the other party
may be liable in whole or part, and all sources and amounts of
income. The parties acknowledge that they fully understand the
facts, and they acknowledge and accept that this Agreement, is,
under the circumstances, fair and equitable, and that it is being
entered into freely and voluntarily, with such knowledge and that
execution of this Agreement is not the result of any duress or
undue influence and that it is not the result of any improper or
illegal agreement or agreements.
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, Husband and
wife, each intending to be legally bound hereby, covenant and agree
as follows:
1. PERSONAL RIGHTS. It shall be lawful for Husband and Wife
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 parties shall be free from any control, restraint,
interference or authority, direct or indirect, by the other in all
respects as fully as if they were unmarried, except as may be
necessary to carry out the provisions of this Agreement. Husband
and Wife shall not molest, harass, disturb or malign each other or
the respective families of each other nor compel or attempt to
compel the other to cohabit or dwell by any means in any manner
whatsoever with him or her. The foregoing provision 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.
2. MUTUAL RELEASE. Husband and Wife each do hereby
mutually remise, release, quitclaim and forever discharge the
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 gains from property
hereinafter accruing) of the other of whatever nature and
wheresoever situate, which he or she now has or at any time
hereafter may have against such other, whether arising out of any
former act, contracts, engagements or liabilities of such other or
by way of dower or curtesy; or claims in the nature of dower or
curtesy or widow's or widower's rights, family exception or similar
allowance, or any rights which any party may now have or any time
2
hereafter have for past, present, future support, maintenance,
alimony, alimony pendente lite, counsel fees, costs or expenses,
whether arising as a result of the marital relation or otherwise;
except all rights and agreements and obligations of whatsoever
nature arising or which may arise under this Agreement or for
breach of any provision hereof. It is the intention of Husband and
Wife to give to each other, by the execution of the Agreement, a
full, complete and general release with respect to any and all
\ property of any kind or nature, real, personal or mixed, which the
other now owns or may hereafter acquire, except and only except all
rights and agreements and obligations of whatsoever nature arising
or which may arise under this Agreement or for the breach of any
provision hereof.
It is further specifically understood and agreed by and
between the parties hereto that each accepts the provisions herein
made by the other in lieu of and in full settlement and
satisfaction of any and all of their rights against the other for
any past, present and future claims on account of support and
maintenance; that it is specifically understood and agreed that the
payments, transfers and other considerations herein recited so
comprehend and discharge any and all such claims by each other
against the other, and are, inter alia, in full settlement and
satisfaction and in lieu of their past, present and future claims
against the other in account of maintenance and support, and also
alimony, alimony pendente lite, counsel fees, costs and expenses,
as well as any and all claims to equitable distribution of
property, both real and personal, and any other charge of any
nature whatsoever pertaining to any divorce proceedings which may
have been or may be instituted in any court in the Commonwealth of
Pennsylvania or any other jurisdiction, including any other counsel
fees, costs and expenses incurred or to be charged by any counsel
arising in any manner whatsoever, except as may be incurred in
3
connection with a breach of the Agreement- as set forth hereinafter
in paragraph 18.
3. FINANCIAL DISCLOSURE. The parties waive their rights to
require the filing of financial statements by the other, although
the parties have been advised that it is their legal right to have
these disclosures made prior to entering into this Agreement and by
entering into this Agreement without reliance upon financial
disclosure, the parties are forever waiving their right to request
or use that as a basis to overturn this Agreement or any part
thereof.
4. INCOME TAX CONSIDERATIONS. The transfers of property
pursuant to this Agreement are transfers between Husband and wife
incident to their divorce and as such are nontaxable, with no gain
or loss recognized. The transferee's basis in the property shall
be the adjusted basis of the transferor immediately before the
transfer. The transfers herein are an equal division of marital
property for full and adequate consideration and as such will not
result in any gift tax liability.
5. PENSION PROFIT-SHARING RETIREMENT CREDIT UNION OR
OTHER EMPLOYMENT-RELATED PLANS. The parties hereto expressly waive
and relinquish any right-, claim, title or interest in any pension,
profit-sharing, retirement, credit union or other employment-
related plans in which the other has any interest by virtue of his
or her past or present employment, whether vested or unvested,
matured or unmatured.
6. E UITABLE DISTRIBUTION OF MARITAL PROPERTY. The parties
have attempted to distribute their marital property in a manner
which conforms to the criteria set forth in Section 3502 of the
Pennsylvania Divorce Code and taking into account the following
considerations: the length of marriage; the fact that it is the
first marriage for Husband and Wife; the age, health, station,
amount and sources of income, vocational skills, employability,
estate, liabilities and needs of each of the parties; the
4
contribution of each party to the education, training or increased
earning power of the other party; the opportunity of each party for
further acquisitions of capital assets and income; the sources of
income of both parties, including but not limited to medical,
retirement, insurance or other benefits; the contribution or
dissipation of each party in the acquisition, preservation,
depreciation or appreciation of the marital property, including the j
contribution of each spouse as a homemaker the value of the J
property set apart to each party; the standard of living of the
parties established during the marriage; and the economic
circumstances of each party at the time the division of the
property is to become effective.
The division of existing marital
property is not intended by
the parties to constitute in any way a sale or exchange of assets,
and the division is being effected without the introduction of
outside funds or other property not constituting marital property.
The division of property under this Agreement shall be in full
satisfaction of all marital rights of the parties.
A. MOTOR VEHICLES. The parties agree that each
shall have full and sole possession and shall become full and
sole owner of the vehicle presently within his or her
possession. On or before the date of the execution of this i'
Agreement, the parties shall execute the titles to the said
vehicles, if appropriate, so as to effectuate the transfer as
herein provided. Furthermore, each party shall become solely
responsible for the financial obligation associated with the
vehicle he or she is to retain pursuant to this Agreement, if
any, and each party agrees to indemnify and hold harmless the
other party from any and all liability therefor.
B. DISTRIBUTION OF PERSONAL PROPERTY. The parties
hereto mutually agree that they have effected a satisfactory
division of the furniture, household furnishings, appliances,
and other household personal property between them, and they
5
mutually agree that each party shall from and after the date
hereof be the sole and separate owner of all such tangible
personal property presently in his or her possession, and this
Agreement shall have the effect of an assignment or bill of
sale from each party to the other for such property as may be
in the individual possession of each of the parties hereto.
From and after the date of the signing of this Agreement,
both parties shall have complete freedom of disposition as to
their separate property and any property which is in their
possession or control, pursuant to this Agreement, and may
mortgage, sell, grant, convey, or otherwise encumber or
dispose of such property, whether real or personal, whether
such property was acquired before, during, or after marriage,
and neither Husband nor Wife need join in, consent to, or
acknowledge any deed, mortgage, or other instrument of the
other pertaining to such disposition of property.
C. DISTRIBUTION OF CASH ASSETS STOCKS AND BONDS. The
parties agree that they shall each retain an interest in the
joint bank account until such time as the marital residence is
sold. Upon the sale of the marital residence, any sums
remaining in the joint bank account shall be distributed
equally. The parties acknowledge herein that it is their
intent to have the funds of the joint bank account expended
for the expenses incident to the marital residence until sold.
D. REAL ESTATE. The parties acknowledge that they are
the joint owners of the marital residence situate at 1209
Doubling Gap Road, Newville, Cumberland County, Pennsylvania.
The parties hereby agree that the marital residence shall be
listed for sale and sold as soon as is reasonably possible.
The parties further agree that the proceeds of the sale shall
be divided equally, subject to the terms below, after the full
payment of the following: the fees, costs, or expenses
incident to the transfer of the said marital residence, and
I
6
the first mortgage. Husband and Wife further stipulate and
agree that any expenses incurred to repair and/or prepare the
marital residence for the sale shall be paid by the proceeds
of the sale prior to the distribution of proceeds to the
parties.
From the date of this Agreement, Husband shall assume as
his sole obligation all of the expenses incident to the use
and ownership of the said marital home, including, without
limitation, any and all mortgage payments, taxes, liability
and fire insurance, utilities, sewer, water, refuse
collection, assessments, proper maintenance, repairs,
additions and improvements, and further covenants and agrees
to indemnify and hold Wife harmless from any such liabilities,
obligations or expenses or any claims or demands as a result
thereof. Husband represents and warrants that all such
mortgage payments, taxes, insurance and other expenses related
to the marital residence are paid in full up to and including
the calendar month in which this Agreement is executed. Any
such expenses which are unpaid shall be paid by Husband,
together with any applicable late charges within thirty (30)
days of this Agreement. The parties also acknowledge that
Husband shall have the sole right to claim any available tax
deductions associated with the said residence for any time
subsequent to the date of Wife's relocation and move from the
marital residence.
1. The parties stipulate and agree that neither
party shall cohabitate in the marital residence with any
person not a party to this Agreement without the prior
written consent of the other party. Cohabitation shall
be defined for purposes of this paragraph only, as
including a period of time excluding two (2) weeks and
the two (2) week period need not include fourteen (14)
consecutive overnight periods to be considered
7
"cohabitation." Any person not Husband or Wife that is
at the marital residence regularly and consistently for
a period of time excluding two (2) weeks shall be
considered "cohabitation", under the terms of this
Agreement and it includes any and all individuals
excepting Husband and Wife, the parties therein.
2. Tile parties hereto acknowledge that they have
a potential purchaser for a portion of the real estate
known as the marital residence. Accordingly, it is
agreed by Husband and Wife to execute an Agreement for
Sale and Purchase of Real Estate with Dennis E. Burnhisel
(hereinafter known as "Buyer") regarding the tract of
undeveloped land which is part of the marital real estate
located on the side of Doubling Gap Road, opposite the
marital residence. The parties agree to sell said
property with any and all expenses incurred, including
but not limited to survey and subdivision costs, being
borne by Buyer. The parties hereto acknowledge that they
need to obtain a Partial Release of Mortgage regarding
said tract of undeveloped land, to proceed to sell same.
Accordingly, the parties stipulate and agree that they
shall cooperate as necessary to effectuate the completion
and filing of a Partial Release of Mortgage, and the
parties shall share equally the processing fee of M & T
Mortgage Corporation, as well as the preparation and
filing fees and costs for the Partial Release 'of
Mortgage. The parties further stipulate and agree that
the proceeds of the sale of the undeveloped tract of land
as described above, shall be the exclusive property of
Wife as per the equitable distribution of marital
property addressed in this Agreement.
The parties further acknowledge herein that they do
not intend, in any way, to confer any third party
8
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beneficiary rights upon Dennis E. Burnhisel, Buyer, as
the potential purchaser of the undeveloped tract of land,
as a result of the execution of this Agreement by Husand
and Wife.
E. DEBTS. Husband represents and warrants to Wife that
since the separation he has not, and in the future he will not
contract or incur any debt or liability for which Wife or her
estate might be responsible, and he shall indemnify and save
Wife harmless from any and all claims or demands made against
her by reason of such debt or obligation incurred by him since
the date of said separation, except as otherwise set forth
herein.
Wife represents and warrants to Husband that since the
separation she has not, and in the future she will not,
contract or incur any debt or liability for which Husband or
his estate might be responsible, and she shall indemnify and
save Husband harmless from any and all claims or demands made
against him by reason of such debts or obligations incurred by
her since the date of said separation, except as otherwise set
forth herein.
Husband hereby assumes and shall be solely responsible
and liable for the payment of the following obligations:
a. The mortgage and any and all other expenses related to
the marital residence until it is sold;
b. The personal loan for $42,000.00 owed to Robert V.
Crochunis; and
C. The 401(K) loan (since wife is waiving rights in same.)
Husband shall immediately upon execution of this
Agreement take such steps as are necessary to transfer
ownership of the said accounts and obligations to his name
solely, obtaining a full, complete and general release of Wife
from t he said creditors. In the event that the creditors
refuse for any reason to transfer the charge accounts to
9
Husband's rf name '..absolutely and to release Wife from any
liability thereon, such accounts shall be immediately closed.
7. INCOME TAX INDEMNIFICATION. The parties acknowledge that
they have filed various joint state and federal income tax returns
during the course of their marriage. Husband acknowledges and
agrees that he has been in sole possession and control of all
records and information. Husband represents and warrants that all
payments of taxes, penalties or interest shown as due on the said
joint returns have been paid in full. Husband shall indemnify and
save Wife harmless from any taxes, penalties, interest, counsel
fees, auditor's fees or accountant's fees which may hereafter be
assessed or incurred in connection with any of the joint tax
returns previously filed by the parties.
8. LIFE INSURANCE. Husband and Wife acknowledge that they
each have one life insurance policy. Each shall maintain the
current life insurance coverage under the same terms and conditions
and shall continue to list the other party as sole beneficiary
until the divorce decree is issued.
9. COUNSEL FEES AND COSTS. Husband and Wife each agree to
pay and be responsible for their own attorney's fees and costs
incurred with respect to the negotiation of this property
settlement agreement and the divorce proceedings related thereto.
10. ALIMONY ALIMONY PENDENTE LITE COUNSEL FEES AND
EXPENSES. Both parties accept the provisions of their Agreement in
lieu of and in full and final settlement and satisfaction of all
claims and demands that they may now or hereafter have against the
other for alimony, alimony pendente lite, counsel fees or expenses,
or for any other provisions for support and maintenance before,
during and after the commencement of any proceedings for the
divorce or annulment between the parties.
11. DIVORCE. A Complaint in Divorce has been filed to No.
99-7037 Civil in the Court of Common Pleas of Cumberland County,
Pennsylvania, and either party shall be free to proceed without
10
W.-
further delay to secure the divorce. Both parties shall sign an
affidavit evidencing their consent to the divorce, pursuant to
Section 3301(c) of the Divorce Code. In the event, for whatever
reason, either party fails or refuses to execute such affidavit
upon the other party's timely request, that party shall indemnify,
defend and hold the other harmless from any and all additional
expenses, including actual counsel fees, resulting from any action
brought to compel the refusing party to consent. Each party hereby
agrees that a legal or equitable action may be brought to compel
him or her to execute a consent form and that, absent some breach
of this Agreement by the proceeding party, there shall be no
defense to such action asserted.
12. BANKRUPTCY. The parties further warrant that they have
not heretofore instituted any proceedings pursuant to the
bankruptcy laws nor are there any such proceedings pending with
respect to them which have been initiated by others. It is
stipulated and agreed by the parties that the terms of this
Agreement as they resolve the economic issues between the parties
incidental to their divorce and the obligations of the parties to
each other resulting therefrom shall not be dischargeable in
bankruptcy, should either party file for protection under the
Bankruptcy Code at any time after the date of execution of this
Agreement.
The payments called for in this Agreement are not intended to
be a debt which is affected by a discharge in bankruptcy and the
terms of this Agreement are not subject to discharge in bankruptcy
because the parties acknowledged that such are necessary for the
parties to meet their financial obligations and to support and
maintain their standard of living. The parties acknowledge that
there are not bankruptcy proceedings presently Pending and they
agree not to file a bankruptcy action prior to the completion of
their respective obligations pursuant to this Agreement.
Furthermore, any debt addressed in this Agreement shall not be
11
a
i I
discharged in a bankruptcy action filed by or on behalf of one of
the parties hereto. Also, if either party files for bankruptcy,
this Agreement shall constitute conclusive evidence of the parties'
intent that the obligations of this Agreement are in the nature of
maintenance and support are not dischargeable under current
bankruptcy law or under any amendment thereto. Further if either
party institutes any action in bankruptcy or any other bankruptcy
proceeding is instituted in whicli a party's right to have payments
made by the other becomes a matter for judicial review, the parties
agree to consent to any motion filed by the other with the
bankruptcy courts, wherein the party may request that the
bankruptcy courts abstain from deciding the dischargeability of
said obligation and any other obligations to said party thereunder
in order to allow the appropriate Court of Common Pleas to rule
upon this issue.
13. RECONCILIATION. Notwithstanding a reconciliation between
the parties, this Agreement shall continue to remain in full force
and effect absent a writing signed by the parties stating that this
Agreement is null and void.
14. INCORPORATION IN FINAL DIVORCE DECREE. The terms of this
Agreement shall be incorporated but shall not merge in the final
divorce decree between the parties. The terms shall be
incorporated into the final divorce decree for the purposes of
enforcement only and any modification of the terms hereof shall be
valid only if made in writing and signed by both of the parties.
Any Court having jurisdiction shall enforce the provision of this
Agreement as if it were a Court Order. This Agreement shall
survive in its entirety, resolving the spousal support, alimony,
equitable distribution and other interests and rights of the
parties under and pursuant to the Divorce Code of the Commonwealth
of Pennsylvania, and no court asked to enforce or interpret this
Agreement shall in any way change the terms of this Agreement.
This Agreement may be enforced independently of any support order,
12
I \
divorce decree or judgment and its terms shall take precedence over
same, remaining the primary obligation of each party. This
Agreement shall remain in full force and effect regardless of any
change in the marital status of the parties. It is warranted,
covenanted and represented by Husband and Wife, each to the other,
that this Agreement is lawful and enforceable, and this warranty,
covenant and representation is made for the specific purpose of
inducing the parties to execute the Agreement.
15. DATE OF EXECUTION. The "date of execution" or "execution
date" of the Agreement shall be defined as the date upon which it
is executed by the parties if they have each executed the Agreement
on the same date. Otherwise, the "date of execution" or "execution
date', of this Agreement shall be defined as the date of execution
by the party last executing the Agreement.
16. FULL DISCLOSURE. Each party asserts that he or she has
made or shall make a full and complete disclosure of all the real
and personal property of whatsoever nature and wheresoever located
belonging in any way to each of them, of all debts and encumbrances
incurred in any manner whatsoever by each of them, and of all
sources and amounts of income received or receivable by each party.
17. ENTIRE AGREEMENT. This Agreement contains the entire
understanding of the parties, and there are no representations,
warranties, covenants or undertakings other than those expressly
set forth herein.
18. BREACH. If either party breaches any provision of this
Agreement, the other party shall have the right, at his or her
election, either to pursue his or her rights in having the terms of
this Agreement enforced as an Order of Court or to sue for specific
performance or for damages for such breach, and the party breaching
this Agreement shall be responsible for legal fees and costs
incurred by the other in enforcing his or her rights under this
Agreement.
13
19. PENNSYLVANIA LAW. The parties agree that the terms of
this Agreement and ally interpretation and/or enforcement thereof
shall forever bq governed by the Laws of Pennsylvania.
20. WAIVER OR MODIFICATION TO BE IN WRITING. No modification
or waiver of any of the terms hereof shall be valid unless made in
writing and signed by both of the parties.
21. ADDITIONAL INSTRUMENTS. Each of the parties shall from
time to time, at the request of the other, execute, acknowledge,
and deliver to the other party any and all further instruments,
including deeds and other real estate-related documents, titles, or
other documents that may be reasonably required to give full force
and effect to the provisions of this Agreement.
22. SEVERABILITY. If any term, condition, clause or
provision of this Agreement shall be determined or declared to be
void or invalid in law or otherwise, then only that term,
condition, clause or provision shall be stricken from this
Agreement, and in all other respects this Agreement shall be valid
and shall continue in full force, effect and operation.
23. WARRANTY. Husband and Wife again acknowledge that they
have each read and understand this Agreement, and each warrants and
represents that it is fair and equitable to each of them.
24. DESCRIPTIVE HEADINGS. The descriptive headings used
herein are for convenience only. They shall have no effect
whatsoever in determining the rights or obligations of the parties.
\ 14
. V .
IN WITNESS WHEREOF, and intending to be legally bound hereby,
the parties hereto have hereunto set their hands and seals the day
and year first above written. This agreement is executed in
duplicate, and each party hereto acknowledges receipt of a duly
executed copy thereof.
WITNESSES: i -
6611)L L,
:LAURI KAY CROC? UNIS r
is G
7 ? ' z
jOB?ERT WALTER CR CHUNIS
15
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1i t
COMMONWEALTH OF PENNSYLVANIA
:SS
COUNTY OF CUMBERLAND
On this /C'7'- day of ebrieeL,
before me, the undersigned officer, ersonally appeared LAURI KAY
CROCHUNIS, known to me (or satisfact rily proven) to be the person
whose name is subscribed to the within Agreement, and acknowledged
that he/she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
NOTARY PUBLIC
Notarial Seal
Cynthia A. Rosborough, Nolary Public
Silver Spring Twp.. Cumberland County
My Commission Expires Aug. 5, 2003
Member, Pannsylvanla Association of Nolanes
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
:SS
On this / 72v day of F"e/JVG(a.u? !Z'Z
before me, the undersigned officer;./ personally appeared ROBERT
WALTER CROCHUNIS, known to me (or satisfactorily proven) to be the
person whose name is subscribed to the within Agreement, and
acknowledged that he/she executed the same for the purposes therein
contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
NOT AY PUBLIC /
C nthia q, NolarialSeal
Y Rosborough, Notary Public
Silver Spring Twp., Cumberland Comity
My Commiss(on Expires Aug. 5, 2003
IAember, PennsyNanlaAssoclalion°tN°larles
16
T
VERIFICATION
I verify that the statements made in the foregoing Petition for Contempt and to Modify
Marital Settlement Agreement 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.
Dated: 12 20 /20 o i
OBERT WALTER C OCHUNIS
,. w
CERTIFICATE OF SERVICE
I, Carol A. Masich, secretary to John W. Purcell, Jr., Attorney for the Defendant,
hereby certify that a true and correct copy of the foregoing was served on the Plaintiff by
forwarding said copy to her attorney at the following address, by first class U.S. Mail on
January 10, 2002:
Linda A. Clotfelter, Esquire
3464 Trindle Road
Camp Hill, PA 17011
Attorney for the Plaintiff
za-- A cl • ar) cue ic?.
Carol A. Masich, Se rotary to
JOHN W. PURCELL, JR.
I.D. NO. 29955
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LAURI KAY CROCHUNIS, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PA
VS. : NO.. 99-7037
ROBERT WALTER CROCHUNIS, : CIVIL ACTION-LAW
Defendant
ORDER OF COURT
AND NOW, this - =` day of 3117.,.., 2003, upon consideration
i
of the foregoing Petition for Contempt and Special Relief, a hearing is scheduled for
the 9 L da of
1 Y C 1,i 2003, at 2:3c• , q .M., Courtroom No. y
Cumberland County Courthouse, Carlisle, Pennsylvania.
BY THE COURT,
?s? yeti,.: G l?G•.?
J.
,,r,;)l,?J'N. h2ri0;, I hera Cq;G Set .?iy :iitl
d(iE i rl $^` i 01 Sii(! f Ciai at C:u'u'$t PE.
rbls dL' J 1 Z. i
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5,
Rathonotur
Distribution:
John W. Purcell, Jr., Esq., 1719 N. Front St., Harrisburg, PA 17102
Lauri K. Crochunis, pro se, 1209 Doubling Gap Road, Newville, PA 17241
y.nn?
LAURI KAY CROCHUNIS,
Plaintiff
VS.
ROBERT WALTER CROCHUNIS,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO.. 99-7037
CIVIL ACTION-LAW
r:
PETITION FOR CONTEMPT AND SPECIAL RELIEF
1. The Petitioner is Robert Walter Crochunis the Defendant in the above; .'
captioned matter.
2. The Respondent is Lauri Kay Crochunis the Plaintiff in the above captioned
matter.
3. The Defendant filed a Petition on January 14, 2002 for contempt and to
modify a Marital Settlement Agreement, and after hearing before the Court, the Court
entered an Order dated April 17, 2002, a copy of which is attached hereto and made a
part hereof.
4. Pursuant to the terms of the Order, the Plaintiff was required to cooperate in
the sale of the real estate, with the Defendant continuing to pay the mortgage, for
which he would be ultimately reimbursed out of the sale from the Plaintiff's portion of
the net proceeds. Furthermore, the Plaintiff was enjoined from interfering with the
showing of the property by the realtors, or imposing any preconditions on the same.
5. The realtors who testified at the first hearing, have since refused to be
involved in the ultimate sale of the property, as a result of the conduct of the Plaintiff.
6. The Defendant and Plaintiff were forced to find other realtors who were
willing to list and show the property for sale.
7. The Defendant and Plaintiff had retained two separate realtors since the
date of the last hearing, Vince Mellott at B & H Agency in Carlisle, PA, and Patrick
Smith at Homestead Group in Camp Hill, PA.
8. During the past year, the Defendant has continued to have problems
showing the property, as the Plaintiff continues to insist that some showings not
occur, while others occur only under her own conditions.
9. The Plaintiff has been responsible for upkeep and maintenance of the
property. She has failed to do so and the home is depreciating quickly in value
because of it. Both inside and outside of the home are cluttered with her possessions
and the realtors have said this must change, as the property shows very poorly when
she does allow showings to occur.
10. Both realtors are of the present opinion that the property will never sell as
long as the Plaintiff continues to reside in the property, especially if she continues to
reside there with Brian Flinchbaugh, who has continued to threaten both the
l
Defendant, and potential purchasers, verbally and with his presence.
11. At one point in time in October of last year, an offer was made on the
house for $300,000.00. While the Defendant was willing to accept the offer, the
Plaintiff insisted on making a counteroffer of $325,000.00, which Defendant
reluctantly agreed to do. In the process by Buyers decided not to purchase the
property.
12. Based on the Defendant continuing to make the mortgage payments in
accordance with the Court's Order of April 17, 2002, and on the assumption of a sale
price of $390,000.00, the Plaintiff is now "out of equity" in that she will receive no
funds from the sale of the premises, regardless of her input.
13. There is no logical or legitimate reason for Plaintiff to continue to reside in
the property in which she has no financial interest or stake, and which is continuing
to remain a drain on the finances of the Defendant, while at the same time continuing
to impede the sale of the property.
14. The Defendant has been patient for the past year in attempting to sell the
property, but the Plaintiff has not been cooperative, and continues to reside with a
man in violation of the Marital Settlement Agreement, a man who continues to
impede the sale of the property.
15. Based on the foregoing, the Defendant believes, as do his realtors, that the
property will sell quicker if the house is vacated by the Plaintiff, her possessions and
her paramour immediately, and the Defendant is allowed to put it in saleable
condition.
WHEREFORE, the Defendant requests this Honorable Court to schedule a
hearing, and thereafter, to hold the Plaintiff in further contempt of Court, and to order
the immediate vacation of the Plaintiff, her possessions and her paramour, Brian
Flinchbaugh, from the premises, granting sole possession and ownership of the
property to the Defendant, and to further allow the Defendant to transfer the property
to any buyer without the signature of the Plaintiff.
Respectfully submitted,
PURCELL,KRUG & HALLER
Jo W:-Purcell, Jr.
1.12(.29955
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
LAURIE KAY CROCHUNIS,
Plaintiff/Respondent
VS.
ROBERT WALTER CROCHUNIS,
Defendant/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-7037 CIVIL
CIVIL ACTION - LAW
IN RE: PETITION FOR CONTEMPT
ORDER
AND NOW, this /-V day of April, 2002, after hearing, the court finding that the
plaintiff,'respondent is in contempt of the marital settlement order in this case, she is thus
adjudged. Specifically, the court finds that she has obstructed the sale of the marital real estate
forcing the petitioner/defendant to continue to pay the expenses of maintaining the home for the
benefit of the respondent in excess of the time frame contemplated by either party. An
adjudication of contempt and the imposition of sanctions, including attorneys fees is deferred on
the following terms and conditions: ,
1. The defendant/petitioner is absolved from any continuing obligation to pay the costs
and expenses of maintaining the marital home pending its sale. Any mortgage payments made
after May 1, 2002, which are paid to prevent foreclosure, shall be reimbursed to the
defendant/petitioner at the time of the ultimate sale of the real estate as a cost thereof and prior to
the division of the proceeds.
2. The plaintiff/respondent is ordered and directed to execute any and all documents
necessary to list the property for sale at a price not less than $325,000. She is enjoined from
rejecting any reasonable offer made. She is further enjoined from interfering in any way
whatsoever with the view of the premises by prospective purchasers including the setting of
preconditions of any kind. The plaintiff/respondent may avoid the installation of a "lock box" by
assuring her presence at the real estate at such times as it is viewed by prospective purchasers
but, in no event, shall she interfere with the show of the real estate by the real estate agent.
3. The defendant/petitioner shall be permitted to enter onto the marital property with not
less than fourteen (14) days notice for the purpose of retrieving his personal property which is
the subject of these proceedings. Fie may enter upon the premises of the marital property at any
reasonable time with reasonable notice for reasons having to do with the sale of the real estate.
BY THE COURT,
Laurie Kay Crochunis
Pro Se Plaintiff/Respondent
John W. Purcell, Jr. Esquire
For the Defendant/Petitioner
Am
TRUE
In 7a;timony
and irrx seal
Kevi A. floss, J.
COP; FMIA rK'.ORD
v:hrcci,,l h--r-, 5n-., my h3nil
of said
Fill
VERIFICATION
I verify that the statements made in the foregoing Petition for Contempt and Special Relief
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.
Dated:_? .5 ZCG3 GrlilLl/??-1
RL)btK WALTER CR HUNIS
LAURI KAY CROCHUNIS,
Plaintiff
V.
ROBERT WALTER CROCHUNIS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
NO. 99-7037
:CIVIL ACTION
PLAINTIFF/RESPONDENT'S ANSWER TO
DEFENDANT/PETITIONER'S PETITION FOR
CONTEMPT AND SPECIAL RELIEF
1. Admitted.
2. Admitted.
3. Admitted.
4. Admitted.
5. Admitted and strict proof of the same is demanded at trial.
6. Admitted insomuchas other listing agents were obtained, it is denied that this is the
fault of Plaintiff/Respondent.
7. Admitted.
D
8. Denied and strict proof of the same is demanded at trial.
9. Denied and strict proof of the same is demanded at trial. By way further answer, the
home continues to suffer from and it has suffered throughout the tenancy of Plaintiff and
Defendant from deferred maintenance and deferred upkeep issues which affect the saleability of
the property.
10. Denied. By way of further answer, Plaintiff was without sufficient information to
admit or deny the opinion of the realtors. By way of further answer, it is denied that Brian
Flinchbaugh has threatened potential purchasers.
11. Admitted in part, denied in part. It is admitted that a counteroffer was made, and that
the buyers decided not to purchase the property. By way of further answer, the $300,000.00 sales
price after realtors fees, commissions, and satisfactions due and owing, would not have been
sufficient for the parties. ?t J_[
12. It is conclusory and speculative in nature nsomuchas requires no answer. 1
an answer is deemed necessary, it is denied that the sales price must be $300,000.00, and
therefore the rest of the paragraph is also denied.
13. Denied. By way of further answer, insurance requirements require that a person
reside in the building, and Plaintiff/Respondent continues to work on the maintenance and
upkeep of the property as she is able, and is in no way impeding the sale of the property.
14. Denied.
15. Is a conclusion based upon Defendant's belief.
16. Is specifically denied and strict proof of the same is demanded at trial.
WHEREFORE, Plaintiff/Respondent requests this Honorable Court dismiss
Defendant/Petitioner's request for Contempt and Special Relief.
NEW MATTER
17. Previous paragraphs are incorporated by reference.
18. The residence in question suffers from serious deferred maintenance issues.
19. At the time Plaintiff and Defendant moved into the home, the home was in need of
serious repairs and these deferred maintenance issues have continued to this day.
20. The house is located in a secluded area at the far end of the county and is a "unique"
property for which buyers are difficult to come by.
21. The square footage is in the neighborhood of 6,000 square feet, and the sire and
location of the property mean that most buyers who are financially able to purchase the same
would not be interested.
22. The combination of the large size, remote location, and possibly hundreds of
thousands of dollars in deferred maintenance issues combine to make the sale of this property
difficult.
23. The ongoing presence of Plaintiff in the property is essential to keep the property free
vandals, maintain insurance requirements, and otherwise protect the property.
24. It is unlikely the property will sell, even at $300,000.00, in the short term and the
continued presence of Plaintiff is not detrimental.
WHEREFORE. Plaintiff/Respondent requests that Defendant/Petitioner's for relief be
denied.
Respectfully submitted,
ROMINGER & BAYLEY
Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Plaintiff/Respondent
Date: August 18, 2003
??Y`?. wR
LAURI KAY CROCHUNIS,
Plaintiff
V.
ROBERT WALTER CROCHUNIS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7037
:CIVIL ACTION
CERTIFICATE OF SERVICE
I, Karl E. Rominger, Esquire, attorney for Plaintiff/Respondent, do hereby certify that I
this day served a copy of the Respondent/P1ainNff's Answer to Defendant/Petitioner's Request
for Contemp and Special Relief upon the following via facsimile at (717) 233-1149 and by
depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania,
addressed as follows:
John W. Purcell, Jr., Esquire
1719 North Front Street
Harrisburg, PA 17102
Dated: August 18, 2003
Karl E. Rominger, Esquire
Attorney for Plaintiff/Respondent
SOCIAL SECURITY INFORiItA"rION SHEfiT
PURSUANTT023 Pa.C.S.A. SPCHON4304.I (a)(_) :11_I_ DI\'ORCI S \IUSI
INCLUDE THE PARTIES SOCIAL SECURITY NU\713ER
PLEASE FILL IN THE APPROPRIATE INFOR\IATION AND RETURN TO THE
PROTHONOTARY'S OFFICE
DATE: c/171 o O
DOCKET NUMBER: zol
PLAINTIFF/PETITIONER SSA ??a7 l v?/ - 5o
NAME: 1 11_[AY, V....
DEFENDANT/RESPONDENTSS4 20 2-
NAME:
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LAURIE KAY CROCHUNIS, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS.
NO. 99-7037 CIVIL
ROBERT WALTER CROCHUNIS, : CIVIL ACTION-LAW
Defendant
ORDER OF COURT
AND NOW, this I 1/1?day of February 2002, upon consideration of the
requested counsel for a continuance, the hearing scheduled in the above matter is
rescheduled to the /sue day of Q rJ,ti w./J 2002, Courtroom 4, at 9,'30
4.M., Cumberland County Courthouse, Carlisle, PA.
BY THE COURT,
Distribution:
/lohn w. Purcell, Jr., Esq., 1719 N. Front St., Harrisburg, PA 17102
.4inda A. Clotfelter, Esq., 3464 Trindle Rd., Camp Hill, PA 17011
v/Lauie Kay Crochunis, Defendant, 1209 Doubling Gap Rd., Newville, PA
J.
C ppies?a?le?
17241 II oZ.19.0?
Or605 Q4?
LAURI KAY CROCHUNIS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
ROBERT WALTER CROCHUNIS,
Defendant:
NO: 99-7037 CIVIL
CIVIL ACTION - LAW
ORDER
AND NOW, this P day of 6p- :( , 2002, upon
consideration of the Motion to Make Rule Absolute of Petitioner Linda A. Clotfelter, Esquire, on
behalf of the Law Offices of Craig A. Diehl, attorneys for the above-named Plaintiff, Lauri K.
Crochunis, and interested parties' failure to object to same, said Rule is made absolute and
Petitioner's Motion to Withdraw as Counsel is granted.
BY THE COURT:
02 P.F s -tD ;iil ID: n7
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LAURI KAY CROCHUNIS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO: 99-7037 CIVIL
ROBERT WALTER CROCHUNIS,
Defendant: CIVIL ACTION - LAW
MOTION TO MAKE RULE ABSOLUTE
AND NOW, comes Linda A. Clotfelter, on behalf of Law Offices of Craig A. Diehl,
attorneys to the above named Plaintiff, Lauri K. Crochunis, and moves this Honorable Court to make
absolute its Rule on counsel's Motion to Withdraw as Counsel for the following reasons:
Petitioner, Linda A. Clotfelter, Esquire, and the Law Offices of Craig A. Diehl
(hereinafter referred to as "Petitioner") are counsel of record in the above-captioned
action, and have a business address of 3464 Trindle Road, Camp Hill, Cumberland
County, Pennsylvania 17011.
2. Respondent, Lauri Kay Crochunis (hereinafter referred to as "Respondent") is an
adult individual who currently resides at 1209 Doubling Gap Road, Newville,
Cumberland County, Pennsylvania 17241.
3. On or about February 27, 2002, Petitioner filed a Motion to Withdraw as Counsel in
this matter.
4. On or about March 5, 2002, the Honorable Judge Kevin A. Hess executed a Rule to
show cause why the relief requested in the Motion to Withdraw as Counsel should
not be granted. The Rule was returnable within fifteen (15) days of service thereof.
5. The Rule was served upon the parties on March 7, 2002, United States, first class
mail, postage prepaid, as follows:
Lauri K. Crochunis
1209 Doubling Gap Road
Newville, PA 17241
Plaintiff
John W. Purcell, Jr., Esquire
PURCELL, KRUG & DIALLER
1719 North Front Street
Harrisburg, PA 17102-2302
Counsel for Defendant
6. Parties in interest have failed to respond to this Court's Rule dated March 5, 2002.
Petitioner respectfully requests that this Court's Rule dated March 5, 2002, be made
absolute such that Petitioner's Motion to Withdraw as Counsel is granted.
WHEREFORE, Petitioner, Linda A. Clotfelter, Esquire, on behalf of the Law Offices of
Craig A. Diehl, attorneys for the above-named Plaintiff, Lauri K. Crochunis, respectfully requests
that this Honorable Court permit Petitioner to withdraw as counsel in this matter.
Respectfully submitted,
LAW OFFICES OF CRAIG A. DIEHL
Dated: J41 I 0
mda A. Clotfelter, Esquire
preme Court I.D. No. 725
464 Trindle Road
Camp Hill, PA 17011
(717) 763-7613
CERTIFICATE OF SERVICE.
I, the undersigned, hereby certify that on this date, a true and correct copy of the foregoing
LAURI KAY CROCHUNIS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO: 99-7037 CIVIL
ROBERT WALTER CROCHUNIS,
Defendant: CIVIL ACTION - LAW
document was served upon the opposing parties by way of United States First Class Mail, postage
prepaid, addressed as follows:
Lauri Kay Crochunis
1209 Doubling Gap Road
Newville, PA 17241
John W. Purcell, Jr., Esquire
PURCELL, KRUG & HALLER
1719 North Front Street
Harrisburg, PA 17102-2302
Counsel for Defendant, Robert W. Crochunis
LAW OFFICES OF CRAIG A. DIEHL
Dater
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By:
tephan' A. Moor , Legal Secretary
3464 Trindle Road
Camp Hill, PA 17011
(717) 763-7613
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LAURI KAY CROCHUNIS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO: 99-7037 CIVIL
ROBERT WALTER CROCHUNIS,
Defendant: CIVIL ACTION - LAW
AFFIDAVIT OF SERVICE
I, Linda A. Clotfelter, Esquire, do hereby affirm that I served the attached Rule upon all
interested parties on this date. The undersigned understands that the statements herein are made
subject to the penalties of 18 P.S. § 4904 relating to unswom falsification to authorities.
LAW OFFICES OF CRAIG A. DIEHL
i
Dated: 7 0
mda A. Clotfelter, Esquire
ttomey ID No. 72963
464 Trindle Road
Camp Hill, PA 17011
(717) 763-7613
LAURI KAY CROCHUNIS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO: 99-7037 CIVIL
ROBERT WALTER CROCHUNIS,
Defendant: CIVIL ACTION - LAW
RULE
AND NOW, this day of f ' ar( 1 2002, upon consideration of
the foregoing Motion to Withdraw as Counsel, a Rule is granted upon Plaintiff or any other party in
interest to show cause, if any be had, why the relief requested should not be granted.
Rule Returnable due fifteen (15) days from service.
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sof my hand
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LAURI KAY CROCHUNIS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO: 99-7037 CIVIL
ROBERT WALTER CROCHUNIS,
Betendant: CIVIL ACTION - LAW
CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that on this date, a true and correct copy of the foregoing
document was served upon the opposing parties by way of United States First Class Mail, postage
prepaid, addressed as follows:
Lauri Kay Crochunis
1209 Doubling Gap Road
Newville, PA 17241
John W. Purcell, Jr., Esquire
PURCELL, KRUG & HALLER
1719 North Front Street
Harrisburg, PA 17102-2302
Counsel for Defendant, Robert W. Crochunis
LAW OFFICES OF CRAIG A. DIEHL
ZALo,&- Date: By:
Stephanie A. Moore, Legal Secretary
3464 Trindle Road
Camp Hill, PA 17011
(717) 763-7613
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LAURI KAY CROCHUNIS, . IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO: 99-7037 CIVIL
ROBERT WALTER CROCHUNIS,
Defendant: CIVIL ACTION - LAW
RULE
AND NO W, this S L day of x'74. eh 2002, upon consideration of
the foregoing Motion to Withdraw as Counsel, a Rule is granted upon Plaintiff or any other party in
interest to show cause, if any be had, why the relief requested should not be granted.
Rule Returnable due frReen-ff5j days from service.
BY THE COURT,
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LAURI KAY CROCHUNIS, : IN THE COURT OF CONINION PLEAS OF
Plaintiff : CUNIBERLAND COUNTY, PENNSYLVANIA
v. NO: 99-7037 CI VIL
ROBERT WALTER CROCHUNIS,
Defendant: CIVIL ACTION - LAW
ORDER
AND NOW, to wit, this day of , 2002,
upon consideration of the foregoing Motion to Withdraw as Counsel it is hereby ORDERED and
DECREED that Linda A. Clotfelter, Esquire, is permitted to withdraw as counsel of record for
Plaintiff in the above-referenced matter.
BY THE COURT:
, J.
. P"Iti
LAURI KAY CROCHUNIS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO: 99-7037 CIVIL
ROBERT WALTER CROCHUNIS,
Defendant: CIVIL ACTION - LAW
MOTION TO WITHDRAW AS COUNSEL
AND NOW, comes Linda A. Clotfelter, Esquire, on behalf of the Law Offices of Craig A.
Diehl, attorneys forthe above-named Plaintiff, Lauri K. Crochunis, and moves this Honorable Court
for permission to withdraw as counsel for the following reasons:
Petitioner, Linda A. Clotfelter, Esquire, and the Law Offices of Craig A. Diehl
(hereinafter referred to as "Petitioner") are counsel of record in the above-captioned
action, and have a business address of 3464 Trindle Road, Camp Hill, Cumberland
County, Pennsylvania 17011.
2. Respondent, Lauri Kay Crochunis (hereinafter referred to as "Respondent") is an
adult individual who currently resides at 1209 Doubling Gap Road, Newville,
Cumberland County, Pennsylvania 17241.
3. On or about December 6, 1999, Respondent retained Petitioner to draft a Marital
Settlement Agreement and assist her with the completion of her no-fault divorce. At
the time Respondent retained Petitioner, Respondent agreed to pay Petitioner on an
hourly fee basis for services performed in representing Respondent.
4. Respondent has not made a payment on her account with Petitioner's firm since June
28. 2000. Certain sums since that date continue to remain outstanding on her
account.
?.
N7?111 --I-
5. On or about December 20, 2000, Petitioner's firm sent to Respondent
correspondence indicating that her account was past due. A true and correct copy of
the letter is attached hereto as Exhibit "A", and is incorporated herein by reference.
6. By correspondence dated January 14, 2002, and January 30, 2002, Petitioner sent to
Respondent via certified mail, return receipt requested, notice of the pending Petition
for Contempt and to Modify Marital Settlement Agreement and the upcoming
hearing. (See copies of the correspondence with return receipts attached hereto as
Exhibit "B" incorporated herein as if fully set forth.) Those letters asked Respondent
to notify Petitioner of Petitioner's status as counsel in this matter.
In response to Petitioner's letter, Respondent indicated to Petitioner that Respondent
would no longerbe utilizing the services of Petitioner and the firm in this proceeding.
Respondent's notice was given to Petitioner by telephone message, teleconference,
and by correspondence dated February 6, 2002, a copy of which is attached hereto
as Exhibit "C" and is incorporated herein as if fully set forth.
8. Respondent has indicated to Petitioner that she wishes to represent herself in this
matter and she intends to do so at the hearing scheduled to take place on March 28,
2002, at 10:30 a.m. before the Honorable Judge Kevin A. Hess.
WHEREFORE, Petitioner respectfully requests that Your Honorable Court enter an Order
permitting Linda A. Clotfelter, Esquire, and the Law Offices of Craig A. Diehl, to withdraw as
'"` +
counsel of record for Plaintiff/Respondent in the above-captioned matter.
Respectfully submitted,
LAW OFFICES OF CRAIG A. DIEVIL
Dated: aJ I o I =ndleRo uirc
. 72963
(717) 763-7613
Lent, Offices of
Craig A. Diehl
3464TrindIe Road
Camp Hill, Pennsylvania 17011
Telephone (717) 763-7613
Telecopier (717) 763-8293
Craig A. Diehl, Esquire, C.P.A.
Linda A. Clotfelter, Esquire
December 20, 2000
Lauri K. Crochunis
c/o Phil Loyola
1821 Pacific Coast Highway, 442P
Hermosa Beach, CA 90254
In Spring Grove. Pennsylvania
119 West Hanover Street
Spring Grove. PA 17362
Telephone: (717) 225-1929
RE: Invoice #4982 dated 7/21/2000
Invoice #5097 dated 8/24/2000
Total Amount Due $455.00
Dear Ms. Crochunis:
It has come to my attention that your account is past due. If you have already sent
payment, please disregard this letter. However, if this was an oversight, please forward payment
at this time.
Thank you for your attention to this matter.
Sincerely,
Ctcut? f1. /c)1d ./( '
Craig A. Diehl, Esquire
CAD:hcr
EXHIBIT "A"
Law Offices of
Poelape
Conlllad F.
Zyv
_ POetmuk
e Pectipt Foe Me
Total Postage N Feo I $
raig A. Diehl
3464 Trindle Road
II, Pennsylvania 17011-4436
ephone(717)763-7613
ecopier (717) 763-8293
Son? o? ' ',/ IJ n
....._VLS?LLr....I......1 .1.....w .l_5?....,..J..........
? svpat Apt tic -.o!8Ir.4I!?.IVt L?.c.L. ?.......I
LI of ZIPe ? l'J ?yy r
January 30, 2002
VIA U.S. CERTIFIED MAIL - RETURN RECEIPT REQUESTED
Lauri K. Crochunis
1209 Doubling Gap Road
Newville, PA 17241
Re: Crochunis v. Crochunis - Petition for Contempt
and to Modify Marital Settlement Agreement
Dear Ms. Crochunis:
In Spring Grove, Pennsylvania
119 West Hanover Street
Spring Grove, PA 17362
Telephone: (717) 225-1929
Please find enclosed the Order of Court we recently received on your behalf in the above-
referenced matter. As you can see, a hearing has been scheduled to take place on March 28, 2002
before the Honorable Judge Kevin A. Hess. It is imperative that you contact our office immediately
upon your receipt of this correspondence. As you can see, we have requested certification that you
have received this document. If you do not contact our office, we will have no other alternative but
to file a motion with the Court asking that we be permitted to withdraw as your counsel. Please note
that your Marital Settlement Agreement provides for the payment of attorney's fees in a situation
such as this one. Thus, it may be possible that the Court could find you in contempt of the terms of
the Marital Settlement Agreement that were incorporated into your Divorce Decree and they could
award Robert attorney's fees for this proceeding, in addition to potentially modifying the terms of
the Agreement and granting him such other relief as the Court may deem just and proper upon a
hearing.
Again, we anticipate hearing from you regarding this matter. If we do not, we will be filing
a motion to withdraw as counsel.
Very truly yours,
.inda A. ClotC, )squ?ir/e ??VV
C
LAC/sam '-
Enclosure
EXHIBIT "B"
¦ Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
¦ Print your name and address on the reverse
so that we can return the card to you.
¦ Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
?}k?.?21 k- G??CN vr?.[I S
Z09 J?IRI ll?lG? CfPI'f7
flGOJ'IL,LGPA I?2L4I
Clearly) I B. Dale of
C3 Agent
C. fi7-;-.1 '
X ., 1-9 ennme.wr
Is delivery address different from item 17 ? Yes
If YES, enter delivery address below: ? No
3. Service Type
P Certified Mail ? Express Mail
? Registered ? Return Receipt for Merchandise
? Insured Mail ? CAA.
4. Reshicted Delivery? (Fxtm Feel ? Yes
2. Ankle Number IT 77 0label)
(7CCr Z? GCU00 2-'5i C' Sirl L
PS Form 3811, July 1999 Domestic Return Receipt 102595-00-M-0952
Lau, Offices of
aig A. Diehl
3464 Trindlc Road
T I, Pennsylvania 17011-4436
] Poempo f C?
C,OW Feo
Retnm PaalOt Faa
? (FSnomammit Rn7?rtao?
7 po%Wd tl oe,Nary Poo
] (Erwon. RORUVWt
Twm Poempo & Feee ^J
V on(. ... ?( i'I
January 14, 2002
VIA U.S. FIRST CLASS CERTIFIED MAIL
Lauri K. Crochunis
1209 Doubling Gap Road
Newville, PA 17241
1.1
In Spring Grove. Pennsylvania
119 West Hanover Street
Spring Grove, PA 17361
Tclephone:(717)225-1919
Re: Crochunis v. Crochunis - Divorce/Marital Settlement Agreement/Petition for Contempt
Dear Ms. Crochunis:
As you know, we had previously represented you in your divorce proceeding. Please find
enclosed for your information and review the Petition for Contempt and to Modify Marital
Settlement Agreement as filed by Robert Crochunis through counsel. I believe that the allegations
of the Petition speak for themselves.
It will be necessary to file a response to this Petition and to prepare for an appeal at a hearing
on the matter. The Court will then determine whether the Petition will be granted in whole or part.
It is my understanding that you had previously indicated to some of the support staff in this
office that you were no longer utilizing our firm for your divorce proceeding. At this time, we are
requesting that you contact our office in writing regarding your position on our employment as your
counsel. If you wish for our firm to represent you in this matter, we will require that your current
invoice be paid in full and that a retainer be submitted to this office. As I am sure you can imagine,
there will be some time, expense, and effort involved in defending the enclosed petition.
We look forward to hearing from you regarding this matter.
Very truly yours,
J,inda A. Clot le ter, Esquire
l ?
LAC/sam
Enclosures
Poetma -phone (717) 763-7613
Rem
!copier(717)763-5193
¦ Complete items 1, 2, and 3. Also complete
item 4 if Restdcted Delivery is desired.
¦ Pont your name and address on the reverse
so that we can return the card to you.
¦ Attach this card to the back of the mail piece,
or on the front if space permits.
1. Anicle Addressed lo:
(LAVR i k• C 4ZOGN L) I.S
I ,0&1 'DOU3U ICI Or C<AP
' NGWVI We QA Iq2-+'
AzInwalved by (Please Print C 1111W. YL°. -1
C. Signature
? Agent
dr.
D. Is delivery address tlilferent Iron item 19 ? Yes
It YES, enter delivery address below: ? No
3. Service Type
V Centied Mel ? Express Mail
O Registered ? Return Receipt far Merchandis[
? insured Mail ? C.O.D.
4. Restricted Delivery? (Extra Fce) ? Yes
2. Article Number (Copy from service lebey '
-7(900 7570 0ont) F21!2 02
PS Form 3811, July 1999 Domestic Return Receipt
102595.00-M-0952
is
Lauri Crochunis
1209 Doubling Gap Rd.
Newville, PA 17241
Law Offices of.- Craig A. Deihl
Attention: Linda Clotfelter/esquire
3464 Trindle Rd.
Camp Hill, PA 17011-4436
717-763-7613
Dear Linda,
I am submitting in writing that I am unable to
afford your services for retention concerning the
case of Crochunis vs. Crochunis. This being in
reference to the hearing that will be set before the
honorable Judge Kevin Hess on March 28th at
the Cumberland County Court House to
determine matters previously set forth within the
marital settlement agreement by the parties
involved.
EXHIBIT "C"
W
Thank you for your recent consideration in this
matter. However finances at this time have
hindered my ability to seek any counsel of choice.
Sincerely
Lauri Crochunis
Wednesday, February 06, 2002
cc. Linda Clotfelter
cc. Lauri Crochunisllkc
LAURI KAY CROCHUNIS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO: 99-7037 CIVIL
ROBERT WALTER CROCHUNIS,
Defendant: CIVIL ACTION - LAW
CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that on this date, a true and correct copy of the foregoing
document was served upon the opposing parties by way of United States First Class Mail, postage
prepaid, addressed as follows:
Lauri Kay Crochunis
1209 Doubling Gap Road
Newville, PA 17241
John W. Purcell, Jr., Esquire
PURCELL, KRUG & HALLER
1719 North Front Street
Harrisburg, PA 17102-2302
Counsel for Defendant, Robert W. Crochunis
Date: D
LAW OFFICES OF CRAIG A. DIEHL
By:
tepha ie A. Moo , L gal Secretary
3464 Trindle Road
Camp Hill, PA 17011
(717) 763-7613
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PURCELL, KRUG & HALLER
1719 NORTH FRONT STREET
HARRISBURG, PENNSYLVANIA
17102-2392
(717) 234-4178 - FAX 233-1149
March 7, 2002
Billed through 02/28/02
Bill number C02895-21561-002 JR
Robert W. Crochunis
3649 Allendale Circle
Pittsburgh, PA 15204
RE: Domestic
---------------------
Account balance as of bill number 001 dated 01/02/02
Payments received since last bill $ 262.50
$
Net balance of account i ------------
$ $ .00
FOR PROFESSIONAL SERVICES RENDERED
12/30/01 Revise Petition; forward to client with
01/24/02 correspondence
Telephone conference with client re: potential
buyer 50 hrs
01/24/02
01/29/02 Revise of a-mails from client •25 hrs
Review of Court Order; forward copy to client
with c 25 hrs
02/05/02 orrespondence
Review of various e-mails; Telephone c
f
35 hrs
02/06/02 on
erence
with client re: same
Preparation of Order re-scheduling hearing;
Correspondenc 50 hrs
02/23/02 e to Judge re: same
Forward Court Order to Client with
.50 hrs
correspondence .35 hrs
Total Fees for this bill
2.70 hrs
BILLING SUMMARY 460.00
John W. Purcell, Jr.
2.20 hrs 175 /hr
John W. Purcell
Jr
385.00
,
.
.50 hrs 150 /hr 75.00
TOTAL FEES FOR THIS BILL 2.70 hrs
$
460.00
•
Robert W. Crochunis
Bill number C02895-21561-002 JR
TOTAL OF FEES, COSTS AND EXPENSES
LESS TRUST ACCOUNT TRANSFER
TOTAL AMOUNT NOW DUE
BEGINNING TRUST ACCOUNT BALANCE
TRUST AMOUNT APPLIED TO THIS BILL
ENDING TRUST ACCOUNT BALANCE
PAGE 2
$ 460.00
------------
$ 460.00 CR
$ 00
------------
$ 737.50
$ 460.00 CR
$ 277.50
PURCELL, KRUG & HALLER
1719 NORTH FRONT STREET
HARRISBURG, PENNSYLVANIA
17102-2392
(717) 234-4178 - FAX 233-1149
January 2, 2002
Billed through 12/31/01
Bill number C02895-21561-001 JR
Robert W. Crochunis
3649 Allendale Circle
Pittsburgh, PA 15204
RE: Domestic
FOR PROFESSIONAL SERVICES RENDERED
12/02/01 Review of documents, e-mails, etc. from client
12/11/01 Dictate draft of Petition and correspondence to
client
Total Fees for this bill 1.75 hrs
BILLING SUMMARY
John W. Purcell, Jr. 1.75 hrs 150 /hr
TOTAL FEES FOR THIS BILL 1.75 hrs $
TOTAL OF FEES, COSTS AND EXPENSES
LESS TRUST ACCOUNT TRANSFER
TOTAL AMOUNT NOW DUE
BEGINNING TRUST ACCOUNT BALANCE
TRUST AMOUNT APPLIED TO THIS BILL
ENDING TRUST ACCOUNT BALANCE
.75 hrs
1.00 hrs
262.50
262.50
------------
262.50
------------
$ 262.50
$ 262.50 CR
------------
$ 00
$ 1,000.00
$ 262.50 CR
$ 737.50
Ilere Is a list of Items that 1 have been storing at 1209 Doubling Gap Road.:
• All tools manual & electric: sanders, planer, saws, drills, router, etc. & items in my work room where the
workbench and furnace are.
• The oak wood planks in the garage left over from flooring.
• All fr uncs and framed art that were separated into boxes marked with my name in the cedar closet.
• All my clothes, coats, etc.
• My desk in the den
• All office materials that were designated for me including large 4 drawer beige filing cabinet
• All books in the library that were on my shelves.
• All green fabric upholstered chairs with wooden amts.
• The two white leather upholstered chairs and small table in the den.
• Green leather couch, green leather high back chair, green leather short back chair.
• Coffee table and end table in big room
• Oak library table & table light with blue on that table.
• 4x4's on wood pile
• Bedroom set in master bedroom upstairs, including dresser, nightstands, king bed(fmnte, box springs,
malress)
• Agreed upon portion of dishes, glasses, china, kitchenware, towels, bedshects, etc.
• division of lawn and garden tools
• cub cadet riding mower
• Stihl and echo chain saws
• Stihl weed trimmer
• 2 large aluminum extension ladders
• framed duck prints
• large framed print in living room
• green desk and chair in big room
• kay murphy: spirit of pa framed print, house in winter framed print above green desk
• Equal share of quilts
• All personal items such as trophies, photos, etc.
• Small refrigerator in upstairs bedroom
• Long buffet table with black top in dining room
• Coffee table in living room
• Two desks in the garage.
• Large bowl fountain from entry way.
• Universal Gym set.
• Victrola and records
0 Microwave Oven.
s
'}•l5' 2 LlL?
,i
Electric Payments
Feb-00
Mar-00
Apr-00
May-00
Jun-00
Jul-00
Aug-00
Sep-00
Oct-00
Nov-00
Dec-00
Jan-01
Feb-01
Mar-01
Apr-01
May-01
Jun-01
Jul-01
Aug-01
Sep-01
Oct-01
Nov-01
Dec-01
Jan-02
Feb-02
Mar-02
$281.36
$195.44
$122.26
$103.16
$109.53
$87.25
$80.89
$37.65
$71.34
$332.27
$30.61
$195.44
$144.53
$144.53
$691.83
$169.99
$255.90
$217.72
$125.44
$138.17
$211.35
$313.18
$351.36
$425.00
$0.00
$0.00
Total
Total Payments
$4,836.20
Mortgage Payments Home Insurance
$1,811.40
$1,811.40
$1,811.40
$1,811.40
$1,811.40
$1,811.40
$1,811.40
$1,811.40 $940.00
$1,811.40
$1,811.40
$1,811.40
$1,811.40
$1,811.40
$1,811.40
$1,811.40
$1,811.40
$1,811.40
$1,811.40
$1,811.40
$1,811.40 $940.00
$1,811.40
$1,811.40
$1,811.40
$1,811.40
$1,811.40
$1,811.40
$47,096.40 $1,880.00
$53,812.60
9.15.02 L1-T-
Hotmail Message ' Page 1 of I
„s;
11? 1J,' Come home to MSN' ?u otaw i u m
Ix! Home Inbox Compose Address Book ry
webjourneys@hotmail.com
Save Address(es) Block - _ Previous Text I Close
From : Ginny Mowery ..5gmowery@pa.net> _
- To : webjoumeys@hotmalf.com.
Date : Fri, 23 Feb 2001 13:08:23.0400
Reply Reply All Forward Delete Put in Folder... P.rlnteCErlendlY Y.ension
Rob, As we discussed, my main problem with showing your home is that Laurie
is making it almost impossible to get anyone in it with her demands that we
have a pre-approval letter for any and all buyers. As agents, we are
responsible to pre-qualify our buyers before showing them properties. None
of us are in the business to shuttle people around and show them houses if
they can't purchase them; however, giving that information to a seller just
to show the house is giving away privileged information that we are not
allowed to give. That essentially, boils down to no one showing it because
no co-broke will give out that information. The other lesser problem is
that she insists in accompanying the showing through the house. My buyers
of this week mentioned that they were additionally uncomfortable with her
accompanying us.
Let me know if I can be of any assistance in these matters. Hopefully we
can have them resolved before I leave on 3/4/01. Thanks!
Ginny Mowery
Realtor
717/245-2100
Reply Reply All Forward Dele[e Put in Folder... prev_tqus Next 1 Close
Out
3
?}•tg•o2 MKT
http://lw3fd.law3.hotmaii.msn.comlcgi-bin/getmsg'?cumlbox=F996082422&a=fab5395 fe 108a... 4/7/02
LAURIE KAY CROCHUNIS,
Plaintiff/Respondent
VS.
ROBERT WALTER CROCI-IUNIS, :
Defendant/Peti tioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-7037 CIVIL
CIVIL ACTION - LAW
IN RE: PETITION FOR CONTEMPT
ORDER
AND NOW, this /7' day of April, 2002, after hearing, the court finding that the
plaintiff/respondent is in contempt of the marital settlement order in this case, she is thus
adjudged. Specifically, the court finds that she has obstructed the sale of the marital real estate
forcing the petitioner/defendant to continue to pay the expenses of maintaining the home for the
benefit of the respondent in excess of the time frame contemplated by either party. An
adjudication of contempt and the imposition of sanctions, including attorneys fees is deferred on
the following terms and conditions:
1. The defendant/petitioner is absolved from any continuing obligation to pay the costs
and expenses of maintaining the marital home pending its sale. Any mortgage payments made
after May 1, 2002, which are paid to prevent foreclosure, shall be reimbursed to the
defendant/petitioner at the time of the ultimate sale of the real estate as a cost thereof and prior to
the division of the proceeds.
2. The plaintiff/respondent is ordered and directed to execute any and all documents
necessary to list the property for sale at a price not less than $325,000. She is enjoined from
rejecting any reasonable offer made. She is further enjoined from interfering in any way
whatsoever with the view of the premises by prospective purchasers including the setting of
I I., r - , r;'. 1.
.: ?i! I :: I'.' C.
X01®
preconditions of any kind. "file plaintiff/respondent may avoid the installation of a `lock boa° by
assuring her presence at the real estate at such times as it is viewed by prospective purchasers
but, in no event, shall she interfere with the show of the real estate by the real estate agent.
3. The defendant/petitioner shall be permitted to enter onto the marital property with not
less than fourteen (14) days notice for the purpose of retrieving his personal property which is
the subject of these proceedings. He may enter upon the premises of the marital property at any
reasonable time with reasonable notice for reasons having to do with the sale of the real estate.
BY THE COURT,
/,uric Kay Crochunis
Pro Se Plaintiff/Respondent
'ehn W. Purcell, Jr. Esquire
/For the Defendant/Petitioner
x.
Kevi A
. . Hess, J.
L ?ie9•?2ci?R)A
g
Oy•17
Am
LAURI KAY CROCHUNIS,
Plaintiff
V.
ROBERT WALTER CROCHUNIS,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7037
:CIVIL ACTION
PLAINTIFF/RESPONDENT'S ANSWER TO
DEFENDANT/PETITIONER'S PETITION FOR
CONTEMPT AND SPECIAL RELIEF
1. Admitted.
2. Admitted.
3. Admitted.
4. Admitted.
5. Admitted and strict proof of the same is demanded at trial.
6. Admitted insomuchas other listing agents were obtained, it is denied that this is the
fault of Plaintiff/Respondent.
7. Admitted.
8. Denied and strict proof of the same is demanded at trial.
9. Denied and strict proof of the same is demanded at trial. By way of further answer,
the home continues to suffer from and it has suffered throughout the tenancy of Plaintiff and
Defendant from deferred maintenance and deferred upkeep issues which affect the saleability of
the property.
10. Denied. By way of further answer, Plaintiff was without sufficient information to
admit or deny the opinion of the realtors. By way of further answer, it is denied that Brian
Flinchbaugh has threatened potential purchasers.
11. Admitted in part, denied in part. It is admitted that a counteroffer was made, and that
the buyers decided not to purchase the property. By way of further answer, the $300,000.00 sales
price after realtors fees, commissions, and satisfactions due and owing, would not have been
sufficient for the parties.
12. It is conclusory and speculative in nature, and insomuchas requires no answer. If an
answer is deemed necessary, it is denied that the sales price must be $300,000.00, and therefore
the rest of the paragraph is also denied.
13. Denied. By way of further answer, insurance requirements require that a person
reside in the building, and Plaintiff/Respondent continues to work on the maintenance and
upkeep of the property as she is able, and is in no way impeding the sale of the property.
14. Denied.
15. Is a conclusion based upon Defendant's belief.
16. Is specifically denied and strict proof of the same is demanded at trial.
WHEREFORE, Plaintiff/Respondent requests this Honorable Court dismiss
Defendant/Petitioner's request for Contempt and Special Relief.
NEW MATTER
17. Previous paragraphs are incorporated by reference.
18. The residence in question suffers from serious deferred maintenance issues.
19. At the time Plaintiff and Defendant moved into the home, the home was in need of
serious repairs and these deferred maintenance issues have continued to this day.
20. The house is located in a secluded area at the far end of the county and is a "unique"
property for which buyers are difficult to come by.
21. The square footage is in the neighborhood of 6,000 square feet, and the size and
location of the property mean that most buyers who are financially able to purchase the same
would not be interested.
22. The combination of the large size, remote location, and possibly hundreds of
thousands of dollars in deferred maintenance issues combine to make the sale of this property
difficult.
23. The ongoing presence of Plaintiff in the property is essential to keep the property free
from vandals, maintain insurance requirements, and otherwise protect the property.
24. It is unlikely the property will sell, even at $300,000.00, in the short term and the
continued presence of Plaintiff is not detrimental.
WHEREFORE, Plaintiff/Respondent requests that Defendant/Petitioner's for relief be
denied.
Respectfully submitted,
ROMINGER & BAYLEY
Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Plaintiff/Respondent
Date: August 18, 2003
LAURI KAY CROCHUNIS,
Plaintiff
V.
ROBERT WALTER CROCHUNIS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7037
:CIVIL ACTION
CERTIFICATE OF SERVICE
I, Karl E. Rominger, Esquire, attorney for Plaintiff/Respondent, do hereby certify that I
this day served a copy of the Respondent/Plaintiffs Answer to Defendant/Petitioner's Request
for Contenrp and Special Relief upon the following via facsimile at (717) 233-1149 and by
depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania,
addressed as follows:
John W. Purcell, Jr., Esquire
1719 North Front Street
Harrisburg, PA 17102
Karl E. Rominger, Esquire
Attorney for Plaintiff/Respondent
Dated: August 18, 2003
LAURI KAY CROCHUNIS
Plaintiff
V.
ROBER'r WALTER CROCHUNIS,
Defendant
: IN TI-117 COURT' OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7037
:CIVIL ACTION
PLAINTIFF/RESPONDENT'S ANSWER TO
DEFENDANT/PETITIONER'S PETITION FOR
CONTEMPT AND SPECIAL RELIEF
1. Admitted.
?.. Admitted.
3. Admitted.
4. Admitted.
5. Admitted and strict proof of the same is demanded at trial.
6. Admitted insomuchas other listing agents were obtained, it is denied that this is the
fault of Plaintiff/Respondent.
7. Admitted.
8. Denied and strict proof of the same is demanded at trial.
9. Denied and strict proof of the same is demanded at trial. By way of further answer,
the home continues to suffer from and it has suffered throughout the tenancy of Plaintiff and
Defendant from deferred maintenance and deferred upkeep issues which affect the saleability of
the property.
10. Denied. By way of further answer. Plaintiffwas without sufficient information to
admit or deny the opinion of the realtors. By way of further answer, it is denied that Brian
Flinchbaugh has threatened potential purchasers.
11. Admitted in part, denied in part. It is admitted that a counteroffer was made, and that
the buyers decided not to purchase the property. By way of further answer, the $300.000.00 sales
price after realtors fees, commissions, and satisfactions due and owing, would not have been
sufficient for the parties.
12. It is conclusory and speculative in nature, and insomuchas requires no answer. If an
answer is deemed necessary, it is denied that the sales price must be $300,000.00, and therefore
the rest of the paragraph is also denied.
13. Denied. By way of further answer, insurance requirements require that a person
reside in the building, and Plaintiff/Respondent continues to work on the maintenance and
upkeep of the property as she is able, and is in no way impeding the sale of the property.
14. Denied.
15. Is a conclusion based upon Defendant's belief.
16. Is specifically denied and strict proof of the same is demanded at trial.
WHEREFORE, Plaintiff/Respondent requests this Honorable Court dismiss
Detendant/Petitioncr's request for Contempt and Special Relief.
NEW MATTER
17. Previous paragraphs are incorporated by reference.
18. The residence in question suffers from serious deferred maintenance issues.
19. At the time Plaintiff and Defendant moved into the home, the home was in need of
serious repairs and these deferred maintenance issues have continued to this day.
20. The house is located in a secluded area at the far end of the county and is a "unique"
property for which buyers are difficult to come by.
21. The square footage is in the neighborhood of 6.000 square feet, and the size and
location of the property mean that most buyers who are financially able to purchase the same
would not be interested.
22. The combination of the large size, remote location, and possibly hundreds of
thousands of dollars in deferred maintenance issues combine to make the sale of this property
difficult.
23. The ongoing presence of Plaintiff in the property is essential to keep the property free
from vandals, maintain insurance requirements. and otherwise protect the property.
24. It is unlikely the property will sell, even at $300,000.00, in the short term and the
continued presence of Plaintiff is not detrimental.
WHEREFORE, Plaintiff/Respondent requests that Defendant/Petitioner's for relief be
denied.
Respectfully submitted,
ROMINGER & BAYLEY
Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Plaintiff/Respondent
Dale: August 18. 2003
LAURI KAY CROCHUNIS,
Plaintiff
ROBERT WALTER CROCI-ZUNIS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7037
:CIVIL ACTION
CERTIFICATE OF SERVICE
1, Karl E. Rominger, Esquire, attorney for Plaintiff/Respondent, do hereby certify that I
this day served a copy of the RespondeadPlaintiffs Answer to DefendanUPelitioner's Request
for Contemp and Special Relief upon the following via facsimile at (717) 233-1149 and by
depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania,
addressed as follows:
John W. Purcell, Jr., Esquire
1719 North Front Street
Harrisburg, PA 17102
Karl E. Rominger, Esquire
Attorney for Plaintiff/Respondent
Dated: August 18. 200'
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LAURIE KAY CROCHUNIS,
Plaintiff/Respondent
VS.
ROBERT WALTER CROCHUNIS,
Defendant/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-7037 CIVIL
CIVIL ACTION -LAW
IN RE: PETITION FOR CONTEMPT
ORDER
AND NOW, this Z5_' day of August, 2003, the court finding that the
plaintiff/respondent has acted in violation of our order of April 17, 2002, and specifically, that
she has interfered with the view of the subject premises by prospective buyers by the setting of
preconditions and that she has rejected an offer of purchase which was reasonable, the court
finds that she is in contempt of our prior order. Adjudication of contempt and the imposition of
any course of sanctions is again deferred on the following terms and conditions:
1. Effective twenty (20) days from the date of this order, exclusive possession of the
premises located at 1209 Doubling Gap Road, Lower Mifflin Township, Cumberland County,
Pennsylvania, is awarded to the defendant/petitioner, Robert Walter Crochunis and the
plaintiff/respondent, Laurie Kay Crochunis and any guest of hers, shall vacate the premises on or
before the effective date.
2. The said Robert Walter Crochunis shall have exclusive authority to negotiate the
refinancing and/or sale of the subject premises and the plaintiff/respondent is directed to
immediately execute any and all documents necessary to effect the same.
3. Upon the failure of the plaintiff/respondent to comply with any of the foregoing
directives, the matter to be listed on further motion for adjudication of contempt and the possible
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imposition of sanctions and/or a direction that the sheriff or recorder of deeds, as appropriate,
undertake the necessary actions on behalf of the plaintiff%respondent.
BY THE COURT,
Karl E. Rominger, Esquire
For the Plaintiff/Respondent
John W. Purcell Jr., Esquire ,c,? aL«4u f•J? 01
For the DefendanUPctitioncr
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