HomeMy WebLinkAbout03-489710
ERIN WENTZ, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
BRIAN WENTZ, NO. 2003- 4/9'gICIVIL TERM
. Defendant IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the
claims set forth in the following pages, you must take prompt action. You are warned that
if you fail to do so, the case may be entered against you by the Court. A judgment may
also be entered against you for any other claim or relief requested in these papers by the
Plaintiff. You may lose money or property or other rights important to you, including
custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown
of the marriage, you may request marriage counseling. A list of marriage counselors is
available in the Office of the Prothonotary, Cumberland County Court House, Carlisle,
Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW
TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Lawyers Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff
PETER J. RUSSO, ESQUIRE
PA Supreme Court ID: 72897
SCOTT A. STEIN, ESQUIRE
PA Supreme Court ID: 81738
3800 Market Street
Camp Hill, PA 17011
(717) 591-1755
ERIN WENTZ, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
BRIAN WENTZ, NO. 2003 -`1497 CIVIL TERM
Defendant IN DIVORCE
COMPLAINT IN DIVORCE
UNDER SECTION 3301(C) AND 3301(d) OF THE DIVORCE CODE
AND NOW, COMES, the above-named Plaintiff by and through Law Offices
of Peter J. Russo, P.C., and seeks to obtain a Decree in Divorce from the above-named
Defendant, upon the grounds hereinafter more fully set forth:
1. Plaintiff is an adult individual domiciled at 526 Evergreen Road, New
Bloomfield, Perry County, Pennsylvania and is a citizen of the United States.
2. Defendant is an adult individual whose mailing address is P.O. Box 343,
New Bloomfield, Perry County, Pennsylvania and is a citizen of the United States.
3. Plaintiff has been a bona fide resident of the Commonwealth of
Pennsylvania for 6 years and has resided continuously therein for at least six months
prior to filing of this Complaint.
4. Plaintiff and Defendant were married on August 18, 2001 in Perry County,
Pennsylvania.
5. There are no children of the parties under the age of eighteen (18).
6. There has been no prior action for divorce by either parry against the other.
7. Neither Plaintiff nor Defendant is in the Armed Forces of the United States
or any of its allies.
8. Plaintiff avers that the marriage between the parties is irretrievably broken.
9. Plaintiff has been advised that counseling is available and that Plaintiff may
have the right to request that the court require the parties to participate in counseling, but
does not request the same.
10. Plaintiff and Defendant have property which will be subject to a property
settlement agreement addressing support issues, which will be filed herein at the
appropriate time.
WHEREFORE, Plaintiff, Erin Wentz, prays that a decree be entered in favor of the
Plaintiff and against Defendant dissolving the marriage between the two parties.
Respectfully submitted,
Law Offices of Peter J. Russo, P.C.
By: /S /??O"''/ ?'//
colt A. Stein, Esquire
3800 Market Street
Camp Hill, PA 17011
(717) 591-1755
Date: 7 - a - 03
LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff
PETER J. RUSSO, ESQUIRE
PA Supreme Court ID: 72897
SCOTT A. STEIN, ESQUIRE
PA Supreme Court ID: 81738
3800 Market Street
Camp Hill, PA 17011
(717) 591-1755
ERIN WENTZ, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
BRIAN WENTZ, NO. 2003 - CIVIL TERM
Defendant IN DIVORCE
VERIFICATION
I, Erin Wentz, verify that the statements made in the foregoing document are true
and correct. I understand that false statements made herein are subject to the penalties
of 18 Pa.C.S. §4904 relating to Unswom Falsification to Authorities.
Date:
iEY n Wentz
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ERIN WENTZ,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
: NO: 20034897 CIVIL TERM
CIVIL ACTION
BRIAN WENTZ,
: IN DIVORCE
Defendant.
TO: Erin Wentz
c/o Scott A Stein, Esquire
3800 Market Street
Camp Hill, PA 17011
NOTICE TO PLEAD
You are hereby notified to plead to the within document within twenty (20) days after service
hereof, or a default judgment may be entered against you.
Respectfully submitted,
MANCKE, WAGNER & SPREHA
By
c and Wagner, Esquire
I.D. #23103
2233 North Front Street
Harrisburg, PA 17110
(717) 234-7051
Attorneys for Defendant
DATE: 2 11 0
ERIN WENTZ,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
v : NO: 2003-4897 CIVIL TERM
CIVIL ACTION
BRIAN WENTZ,
. IN DIVORCE
Defendant.
AN W .R
M ADDITIONAL COUNTS
ANSWER
AND NOW, comes the Defendant, Brian Wentz, by and through his attorneys,
Mancke, Wagner & Spreha, and files the following Answer:
I. Admitted.
2. Admitted.
3. Admitted.
4. Admitted.
5. Admitted.
6. Admitted.
7. Admitted.
8. Denied. It is denied that the marriage is irretrievably broken.
9. No answer is required.
10. Admitted in part, denied in part. It is denied that there is any marriage
settlement agreement that has been executed by the parties.
WHEREFORE, Defendant requests this Court to enter a Decree in Divorce
accordingly.
ADDITIONAL COUNTS
COUNT?
EQUITABLE DISTRIB -U N_
11. Paragraphs 1 through 10 above are incorporated herein by reference and made
a part hereof.
12. During the marriage, Plaintiff and Defendant have acquired various items of
marital property, both real and personal, which are subject to equitable distribution under
Section 401 of the Divorce Code of 1980.
COUNT II
ALIMONY PENDENTE LITE
13. Paragraphs 1 through I 1 above are incorporated herein by reference and made
a part hereof.
-2-
14. The Defendant is without sufficient funds to support himself and unable to
appropriately maintain himself during the pendency of this action.
15. The Defendant's income is not sufficient to provide for his reasonable needs.
16. The Plaintiff has adequate earnings to provide support for the Defendant.
WHEREFORE, Plaintiff prays this Honorable Court:
(a) Enter a Decree in Divorce;
(b) Compel the Defendant to pay alimony pendente lite to the Plaintiff;
(c) Equitably distribute all property, both real and personal, owned by
the parties;
(d) Grant such further relief as the Court may deem equitable and just.
Respectfully submitted,
Mancke, Wagner & Spreha
7
at r, Esquire
I.D. #23103
2233 North Front Street
Harrisburg, PA 17110
(717) 234-7051
Attorneys for Plaintiff
Date:
-3-
VERIFIC TA_ION
I verify that the statements made in the foregoing
document 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: ??'6
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ERIN WENTZ,
Plaintiff
v.
BRIAN WENTZ,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO: 2003-4897 CIVIL TERM
CIVIL ACTION
IN DIVORCE
AND NOW, comes your Petitioner, Brian Wentz, by and through his attorneys,
Mancke, Wagner & Spreha, and files the following Petition for Alimony Pendente Lite:
1. Your Petitioner, Brian Wentz, is the Defendant in the above-captioned divorce
action.
2. The Respondent, Erin Wentz, is the Plaintiff in the above-captioned divorce
action.
3. A Complaint in Divorce was filed in the Court of Common Pleas of
Cumberland County on September 17, 2003.
4. On March 1, 2004, Petitioner herein filed an Answer to the Complaint in
Divorce and under Count II, raised an issue of alimony pendente lite.
5. The Petitioner herein is without sufficient funds to support himself and not
appropriately able to maintain himself during the pendency of this action.
6. The Petitioner's income is not sufficient to provide for his reasonable needs.
7. The Respondent has adequate earnings to pay alimony pendente lite unto the
Petitioner.
WHEREFORE, Petitioner prays this Court to grant his Petition for Alimony
Pendente Lite.
Respectfully submitted,
Mancke, Wagner & Spreha
agner, Esquire
I.D.#23103
2233 North Front Street
Harrisburg, PA 17110
(717) 2344-7051
By _
. Richard W
Attorneys for Petitioner
Date:
?TTT
VERIFICATION
I verify that the statements made in the foregoing
document 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.
? J
DATE: -7- /2 -oy
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ORIGINAL
ERIN WENTZ,
PLAINTIFF
IN THE COURT OF COMMON
CUMBERLAND COUNTY, PET
,VANIA
V.
BRIAN WENTZ,
DEFENDANT
NO. 2003 - 4897 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
NOTICE OF ELECTION TO RETAKE FORMER NAME
Notice is hereby given that the Defendant in the above matter, hereby elects
hereafter use her former name of Erin Kramer Payne and gives this written notice
intention in accordance with the provisions of 54 Pa.C.S.A. § 704(a).
DATED: J 2? CS
8ffn-K. P. Wentz
TO BE KNOWN AS
.I? ? C?rx2J?
Payne
Sworn to and subscribed
before me this e-jo.- day
of 2005.
NOTARY PUBLIC VU
COt?vYYn,Oi,at-'-Ad of PEW YLVANA
NOTARIAL SEAL
Christie L. Underkotfler, Notary PubMc
Silver Spring Twp., Comtusribnd County
F,"v rn. qt^ ?4, 2JOB
retake and
her
ERIN WENTZ,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
V.
BRIAN WENTZ,
Defendant.
NO: 20034897
CIVIL ACTION - LAW
IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
BRIAN WENTZ, Defendant, moves the Court t
following laims:
(/? Divorce
O Annulment ( )
Alimony ( )
(X Alimony Pendente Lite ( )
appoint a Master with respect to the
Distribution of Property
Support
Counsel Fees
Costs and Expenses
and in support of the motion states:
(1) Discovery is complete as to the claim(s) for which the appointment ofa Master is
required.
(2) The Plaintiff has appeared in the action by her attorney, JOHN J. CONNELLY,
JR., ESQUIRE.
(3) The statutory ground(s) for divorce (is) (are): 3301(c) and 30(1
d)
(4) Delete the inapplicable paragraph(s): (a) The action is not contested.
(b) An agreement has been reached with respect to the following claims:
` I &a,(
(5) The action (irmakw) (does of involve) complex issues of law or fact.
(6) The hearing is expected to take 1 (days).
(7) Additional information, if any, relevant tpthu onNoneDate: ;L5 /oses
PagnerEsquire
A Defendant
ORDER APPOINTING M TER
AND NOW, u?+UL-3 2005, Z z&CJ Esquire, is
appointed master with t spect to the following claims: /pro
BY THE CO
J.
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45
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NO /M"
P. Richard Wagner, Esquire
Mancke, Wagner & Spreha
Supreme Court I.D. # 23103
2233 North Front Street
Harrisburg, PA 17110
Telephone (717) 234-7051
Fax (717) 234-7080
ERIN WENTZ,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
CIVIL ACTION - LAW
V. : NO: 2003-4897 CIVIL TERM
IN DIVORCE
BRIAN WENTZ,
Defendant.
INVENTORY OF DEFENDANT
Defendant files the following inventory of all property owned or possessed by
either parry at the time this action was commenced and all property transferred within the
preceding three years.
P. Ric ar agner, Esquire
Mancke, Wagner & Spreha
Supreme Court ID #23103
2233 North Front Street
Harrisburg, PA 17110
(717) 234-7051
Attorney for Defendant
Date: d9 D9?
ASSETS AND LIABILITIES OF PARTIES
Defendant marks on the list below those items applicable to the case at bar and
itemizes the assets and debts on the following pages:
() 1. Real property and Real Estate Mortgages
(x) 2. Motor vehicles and Vehicle Liens
() 3. Stocks, bonds, securities and options
O 4. Certificates of Deposit
(x) 5. Checking accounts, cash
() 6. Savings accounts, money market and savings certificates
() 7. Contents of safe deposit boxes
() 8. Trusts
O 9. Life Insurance policies
O 10. Annuities
O 11. Gifts
() 12. Inheritances
() 13. Patents, copyrights, inventions, royalties
(x) 14. Personal property outside the home
() 15. Business
() 16. Employment termination benefits-severance pay, worker's compensation
() 17. Profit sharing plans
() 18. Pension Plans (indicate employee contribution and date plan vests)
() 19. Retirement plans, Individual Retirement Accounts
O 20. Disability payments
O 21. Litigation claims (matured and unmatured)
() 22. MilitaryN.A. benefits
() 23. Education benefits
(x) 24. Debts due, including loans, mortgages held
() 25. Household furnishings and personalty
() 26. Other assets
(x) 27. Loans, Credit Cards and other Debts
SECTION 1
MARITAL ASSETS AND DEBTS
THE FOLLOWING IS A LISTING OF THE MARITAL ASSETS AND DEBTS OF
THE PARTIES:
I1l1?/=A MLAI oQTATC AWn 1?FAI FIRTATF MORTGAGES
11 1 V CI1 1 VIA 1 WI
DESCRIPTION OF
PROPERTY OR
LIABILITY I x? ?-
DATE OF
VALUE - -
VALUE OF
ASSET OR
LIABILITY _-_ _- - _ -
NET VALUE
PROPOSED
DISTRIBUTION
TO HUSBAND
PROPOSED
DISTRIBUTION
TO WIFE
ITEM - REAL ES TATE NIA
Value
1' Mortgage
2"' Mortgage
Net Equity
Comments:
.,r...?.."a pan ¦IIATAC VCult l C AKIn XIOWIM F 1 WNS
11 \ V V IN I v 1%1 a?
DESCRIPTION OF
PROPERTY OR
LIABILITY
DATE OF
VALUE -
VALUE OF
ASSET OR
LIABILITY -
NET VALUE
PROPOSED
DISTRIBUTION
TO HUSBAND
PROPOSED
DISTRIBUTION
TO WIFE
(VEHICLE #7) 19 86 FORD F25 0
Husband 7-2-05
Vehicle Loan 0
Net Value 2500.00
Comments:
(VEHICLE #2) FOR D F260 LT
Husband' &
Wife's
Vehicle Loan
Net Value
Comments: This truck is in wife's name and was bought before separation.
INVENTORY #3 & #4 STOCKS, SECURITIES, INVESTMENTS &
r_r-RTIPMATFS OF DEPOSIT PROPOS DESCRIPTION OF DATE OF v VALUE OF NET VALUE D STRIBU ED DISTRIBUTION
PROPERTY OR
LIABILITY
VALUE
ASSET OR
LIABILITY
TO HUSBAND PROPOSED
TO WIFE
NODE
Comments:
INVENTORY #5 & #6 CASH, CHECKING ACCOUNTS AND SAVINGS
A r- r- 1111 hi TA
DESCRIPTION OF
PROPERTY OR
LIABILITY DATE OF , -
VALUE VALUE OF
ASSET OR
LIABILITY NET VALUE PROPOSED
DISTRIBUTION
TO HUSBAND PROPOSED
DISTRIBUTION
TO WIFE
Checking
My name 7-2-05 326700 326.00
Comments: I had to open this When she closed our joint account.
lknieWTfI dt7 rnkITFNTI4 III SAFETY DEPOSIT BOXES
DESCRIPTION OF
PROPERTY OR
LIABILITY DATE OF
VALUE VALUE OF
ASSET OR
LIABILITY NET VALUE PROPOSED
DISTRIBUTION
TO HUSBAND PROPOSED
DISTRIBUTION
TO WIFE
NONE
Comments:
11J111=A1TnRV #ft TRI ISTS
... .
DESCRIPTION OF
PROPERTY OR
LIABILITY
DATE OF
VALUE
VALUE OF
ASSET OR
LIABILITY
NET VALUE
PROPOSED
DISTRIBUTION
TO HUSBAND
PROPOSED
DISTRIBUTION
TO WIFE
NONE
Comments:
•.v?uri. rev a/n 1 IGC IwIC11De1JrP Pt11 ICIFS
ITV V GIV I VI%I fr
=DESCRIPTION ?u u.
E F
VALUE vv..r...__ .
LOF
ASSET OR
LIABILITY
NT LU
OSED
DISTR BUTTON PROPOSED
DISTR BUTION
TO WIFE
NONE
Comments:
IKnICKI'MOV 04n eNINI111TIFS
DESCRIPTION OF
PROPERTY OR
LIABILITY DATE OF
VALUE VALUE OF
ASSET OR
LIABILITY FNETV)LUE PROPOSED
DISTRIBUTION
TO HUSBAND PROPOSED
F DISTRIBUTION
TO WIFE
NONE
Comments:
IKIxlCKITAGV 4#44 r.IFTS nNCRFASE IN VALUE ONLYI
DESCRIPTION OF
OPERTY OR
PR
LIABILITY DATE OF
VALUE VALUE
OOF R
ASSET
LIABILITY
NETVALUE
PROPOSED
DISTRIBUTION
TO HUSBAND
PROPOSED
DISTRIBUTION
TO WIFE
NONE
Comments:
INIVFNTCIRV 019 INHERITANCE (INCREASE IN VALUE ONLY)
•• DESCRIPTION OF
PROPERTY OR
LIABILITY DATE OF
VALUE VALUE OF
ASSET OR
LIABILITY NET VALUE PROPOSED
DISTRIBUTION
TO HUSBAND PROPOSED
DISTRIBUTION
TO WIFE
NONE
Comments:
INVENTORY #13 PATENTS, COPYRIGHTS, INVENTIONS &
Gf1VAl TICC
DESCRIPTION OF
PROPERTY OR
LIABILITY DATE OF
VALUE VALUE OF
ASSET OR
LIABILITY NET VALUE PROPOSED
DISTRIBUTION
TO HUSBAND PROPOSED
TDISTRIBUTION
TO WIFE
NONE
11 11 1
-
t 1 11 ? T7
==
ts:
...,?..?.,s.. ??. ococnKIei PRnPFRTY OUTSIDE HOME
DESCRIPTION OF
ROPERTY OR
LIABILITY DATE OF
ALUE VALUE OF
SSET OR
LIABILITY NET VALUE
PROPOSED
BUTION
TR
TDIPSR
OPOS
HUSBAND
ST R BUTION
TO WIFE
Tools 7-2-05 $500-$600
Comments: There are still tools at wife's house that I could not get.
NTORY #15 BUSINESSES
INVE
DESCRIPTI(111111) 1: T
PROPERTY OR
LIABILITY
7DATE OF
VALUE
VALUE OF
ASSET OR
LIABIL
NET VALUE
P
=DISTRPIBUTION
NONE
[Comments:
1k1%1CKITn0V -94A FMPI nYMENT TERMINATION BENEFITS OPOS
DESCRIPTION OF
PROPERTY OR
LIABILITY DATE OF
VALUE VALUE OF
ASSET OR
LIABILITY NET VALUE DI TR BU ED 0
TO HUSBAND ST DPROPO TI ON
TO WIFE
NONE
Comments:
u.? nII CLIARIWt. PI ANS
DESCRIPTION OF
PROPERTY OR
LIABILITY DATE OF
VALUE VALUE OF
ASSET OR
LIABILITY NET VALUE PROPOSED
DISTRIBUTION
TO HUSBAND PROPOSED
DISTRIBUTION
TO WIFE
NONE
Comments:
Y #18 & #19 PENSION AND RETIREMENT PLANS
NTOR
IVEN
DESCRIPTION OF
PROPERTY OR
LIABILITY
DATE OF
VALUE
VALUE OF
ASSET OR
LIABILITY
NET VALUE
D STR BUTION
TO HUSBAND
ST tl
T
NONE
Comments:
Y #2n DISABILITY PAYMENTS
INVENTOR
DESCRIPTION OF
P
DATE OF
VALUE
TVP UEF
SET
ABILITY
PROPOSED
DISTRIBUTION
TO HUSBAND
PROPOSED
DISTRIBUTION
TO WIFE
NONE
[Comments:
INVENTORY #21 LITIGATION CLAIMS
RY #23 EDUCATION BEN
Comments:
INVENTORY #24 DEBTS DUE PARTIES INCLUDING LOANS AND
MORTGAGES HELD
3 Loans 17-2-05 18,000.00
Comments: All loans were put in my name due to her mortgage and bankruptcy.
INVENTORY #25 HOUSEHOLD GOODS, FURNISHINGS, TOOLS,
#27 LOANS, CREDIT CARDS AND OTHER DEBTS
Comments.
NOTES:
The adjustment figures are for illustration purposes only and are not to be
deemed a representation on the part of theDefendant as to whether an
adjustment should be made or the amount of the adjustment, if appropriate.
SECTION II.
F
OTHER PERSONAL PROPERTY
THE FOLLOWING IS A LISTING OF THE HOUSEHOLD GOODS AND CONTENTS AND
OTHER PERSONAL PROPERTY OF THE PARTIES:
(Note: Exclusion from marital property include property acquired before marriage, property
acquired after separation, or property acquired during marriage by way of gift or inheritance
from third party not a spouse. For gifts and inheritance also specify the source person).
HOUSEHOLD GOODS AND CONTENTS AND OTHER PERSONAL PROPERTY
DESCRIPTION OWNER POSSESSOR VALUE EXCLUSION
CLAIMED TO BE
NON-MARITAL VALUATION METHOD OF
AND
SUPPORTING
DOCUMENTATIO
N
ITEM _
_
Saw Husband Wife 129.00 got before
marriage
T
COMMENTS: Could not get because locks were changed
ITEM
Alum. Ladder Husband Wife 100.00 Belongs to
my parents
COMMENTS: Could not get because locks were changed
ITEM
Photo Album Husband Wife personal
COMMENTS: Could not get because locks were changed
ITEM
COMMENTS:
SECTION III.
NON-MARITAL ASSETS AND DEBTS
THE FOLLOWING IS A LISTING OF THE NON-MARITAL ASSETS AND DEBTS OF THE
PARTIES:
(Note: Exclusion from marital property include property acquired before marriage, property
acquired after separation, or property acquired during marriage by way of gift or inheritance
from third party not a spouse. For gifts and inheritance also specify the source person).
NON-MARITAL PROPERTY AND DEBTS
DESCRIPTION OWNER POSSESSOR VALUE EXCBASIS FOR
LUSION IF
CLAIMED TO BE
NON-MARITAL METHOD OF
VALUATION AND
SUPPORTING
DOCUMENTATIO
N
ITEM
COMMENTS:
ITEM
COMMENTS:
ITEM
COMMENTS:
ITEM
COMMENTS:
ITEM
COMMENTS:
SECTION IV.
PROPERTY TRANSFERRED
The following is a listing of all property which was transferred within 3 years of the
date of the commencement of this action or was transferred since the date of
separation:
VERIFICATION
?_verifies that the statements made in this inventory are true and correct.
? nd? stands that false statements herein are made subject to the penalties of
18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities.
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P. Richard Wagner, Esquire
Mancke, Wagner & Spreha
Supreme Court I.D. # 23103
2233 North Front Street
Harrisburg, PA 17110
Telephone (717) 234-7051
Fax (717) 234-7080
ERIN WENTZ,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
CIVIL ACTION - LAW
V. : NO: 2003-4897 CIVIL TERM
IN DIVORCE
BRIAN WENTZ,
Defendant.
DEFENDANT'S INCOME AND EXPENSE STATEMENT
Full Name of Defendant: Brian Scott Wentz
Present Address: 173 Creek Road
Millerstown, PA 17062
Status of Defendant's Health (Be Specific) Good
Age: 33
Telephone No. (717) 589-3988
Name and Address of Defendant's Employer: Turbo Tek Restoration, Inc.
135 Windy Hill Road
Shermans Dale, PA 17090
Lenath of Service With This EmDlover: 8 Months
Weekly Monthly Yegly
Gross Earned Income 600.00
9 months a year
Gross Unearned Income
Total Gross Income 600.00
Deductions:
Federal 38.00
State Inc. Tax 19.00
F.I.C.A. 45.00
Hosp/Med. Ins.
Weekly Yearly
Dividends
Rent
Royalties
Expense Account
Gifts
Unemployment
Compensation: 354.00
3 months a year
Current Expenses:
Home:
Mortgage
Maintenance
Utilities:
Electric
Gas
Oil
Telephone 100.00 - 200.00
Water
Sewer
Employment:
Public Transportation
Lunch 50.00
Taxes:
Real Estate
Weekly Monthly Yearly
Income
Insurance
Home Owners
Automobile 900.00
Life
Accident
Health
Other
Automobile:
Payment 500.00
Fuel 120.00
Repairs 500.00
Medical:
Doctor 100.00 - 200.00
Dentist
Orthodontist
Hospital
Special Needs
(Glasses, Braces)
Education:
Private School
Parochial School
College
Religious
Personal:
Clothing 2,000.00 - 3,000.00
Food 75.00 - 100.00
Weekly Month( Yearly
Credit Payments
Credit Cards
Charge Accounts
Memberships 25.00 - 35.00
Loans
Credit Union
line of
credit
160.00
164.00
175.00
Miscellaneous
Household help 50.00 - 75.00
Child Care
Papers/Books/Magazine
IS
Entertainment 90.00
Pa N
Vacation 1500.00 - 2000.00
Gifts 500.00
Le al Fees 3500.00
Charitable
Contributions
Other Child Su ort
Alimony Pa
I TOTAL EXPENSES: $270.00 $1,274.00 $9,235.00
Defendant's Current Income:
SEE ATTACHED
Per Pa Weekly Monthly Yearly
Gross Earned Income 600.00
Gross Unearned Income
Total Gross Income 600.00
Deductions
Federal 38.00
State Income Tax 19.00
F.I.C.A. 45.00
Hosp/Medical Insurance
Pension/Profit Sharing
Savings Bonds (None)
Other 7.00
Total Deductions 109.00
Other Income:
Interest
Dividends
Pension
Annuity
social security
If Defendant is not Employed, explain fully:
Defendant's Education, Training and Skills:
VERIFICATION
I-elr f verifies that the statements made in this foregoing document 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.
tJl
-71
f? Y
C.J .J
C7 <
Curtis R. Long
Prothonotary
office of the Protbonotarp
?urrt?eria?nD ?ountp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
03 - IY847 CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573