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HomeMy WebLinkAbout84-3749DEBRA ANN BRINLEY, formerly DEBRA ANN HEINEMAN, Plaintiff vs. CARL WALTER HEINEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 3749 CIVIL 1984 IN DIVORCE ORDER OF COURT AND NOW this ~~ day of ~~~~~ ~ ~ , 2002, upon consideration of the attached Petition to Enforce Property Settlement Agreement, it is hereby directed that the parties and their respective counsel appear before the undersigned on / //U i V bf # ~ the :~r/G day of f ~ l.f ~~ G~[ ~ ~ , 2002 at l ° y~ o'clock ,~ .m. BY TIC` COURT, Distribution: / Samuel L. Andes, Esquire (Attorney for Plaintiff) 525 North 12"' Street, Lemoyne, PA 17043 Carl Walter Heineman (Defendant) 201 Walnut Street, Carlisle, PA 17013 ~,,La~it c ~.~ ..,~ ~~. -~- ~, ~ ~ .,~'.~ ~._ - 1~. , ~ ;_ h5 `i.._i,. , ~ .r Y -, yl ~-~, "'. l.4- yL}.. ~ V ~ ~~ ~ j ~y ~j.. V ~' DEBRA ANN BRINLEY, formerly DEBRA ANN HEINEMAN, Plaintiff vs. CARL WALTER HEINEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 3749 CIVIL 1984 IN DIVORCE PETITION TO ENFORCE PROPERTY SETTLEMENT AGREEMENT AND NOW comes Debra Ann Brinley, formerly Debra Ann Heineman, the Plaintiff in this matter, and petitions the court to enforce the terms of the parties Property Settlement Agreement and the final decree in divorce, based upon the following: 1. The Petitioner herein is the Plaintiff, Debra Ann Brinley an adult individual who resides at 29 Enck Drive in Boiling Springs, Pennsylvania 17007. 2. The Respondent herein is the Defendant, Carl Walter Heineman an adult individual who resides at 201 Walnut Street in Carlisle, Pennsylvania 17013. 3. The parties are formerly husband and wife and are the parents of one child, Abby Lynn Heineman, age 17, born 15 August 1984. 4. Shortly before the parties divorced, they entered into a Property Settlement Agreement which provided, among other things, for the payment of the college education of their daughter. Attached hereto and marked as Exhibit A is a copy of that Property Settlement Agreement, Paragraph 15 of which sets forth the obligation to contribute to the college education expenses of the child. 5. At the time of the divorce, the terms of the Property Settlement Agreement were incorporated into, but not merged into, an Order of Court. Attached hereto and marked as Exhibit B is a copy of that Order. 6. The said child graduated from high school in June of 2002 and is currently enrolled to attend Wilkes University, where she plans to study to be a pharmacist. The child is a good student and is well-qualified to attend such school and pursue such course of study. 7. Plaintiff and the child have performed and satisfied all of the conditions of Paragraph 15 of the Property Settlement Agreement, as incorporated into the final decree in divorce. As a result, Plaintiff is entitled to have Defendant pay one half of the child's college expenses in accordance with such agreement. 8. Plaintiff has requested that Defendant make his payment toward the college expenses of the child, as agreed, but Defendant has failed and refused to make any such payment. 9. Defendant, by his conduct, has breached the agreement between the parties and this court's decree in divorce. 10. Pursuant to Paragraph 24 of the Property Settlement Agreement between the parties, Defendant is obligated to pay the legal fees and expenses incurred by Plaintiff in enforcing the agreement. WHEREFORE, Plaintiff prays this court to enforce the Property Settlement Agreement of the parties, and the final decree in divorce in this matter, by compelling Defendant to pay one half of the higher education expenses of the parties' child and paying to Plaintiff the attorneys fees and costs she has incurred, and will incur, in enforcing the agreement. el L. Ande Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 VERIFICATION I verify that the statements made in this Petition are true and correct. I understand that any false statements in this Petition are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: a~o~ ~ ~ DEBRA. ANN BRINLEY ~l ~t ;~ t t ,~ ,, ~~~~ ,; Ey~1IBIT ~..,..~,~..~.~~ ~~~..,,~,~~,.~ r ......._ _.....__._ ...._..._...__. ,,,,..___.~ .,,~ .,,,,.. __... ,~_....__. ..,.~...,.,.,.~,.~,~,,,M,~ ,. Car4is1~~3 ,"_'_"_'"" DEBRA ANN HEII4EMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW IN DIVORCE CARL WP.LTER HEINEMAN, Defendant N0. 3749 CIVIL 1984 ORDER OF COURT p r'~. , ~._• ~~ f~~~ ~ C_ i Vii. ~(- c''.. 1~... AND NOW, this ~_, day of `~rQa~t, 1985, Debra Ann Heineman, by her attorney, Ruby D. Weeks, Esquire, and Carl W. Heineman, having been divorced and separated from the nuptial ties and bonds of matrimony by previous decree of this Court, hereby agree and consent to the entry of the signed decree for payment and enforcement of child support as provided in the Proper±y Settlement Agreement of February 14, 1985, which Agreement has not merged into the decree of divorce, and which Agreement is attached hereto and made a part of this Order for purposes of enforcement only, and IT IS ORDERED AND DECREED THAT: Husband shall pay to Wife for support and maintenance of the Child the sum of 535.00 per week. All financial obligations undertaken by Husband in this paragraph 13 shall be binding upon Husband's heirs, executors, administrators, successors and assigns, and shall constitute a charge against Husband`s estate. Husband agrees that the above provisions for support shall be: increased automatically as fo~lows: By the same proportion as any net salary increase received by tl~e father; *_hat is, for e>;ample, but not limited to, if he receives a 10~~ net salar•~~ increase, support will automatically also be increased by 1u ,. Husband is to provide L^7ife with statements of any such increases frem his employer within fifteen (15) days of his receipt of an increase. All financial obligations undertaken by Husband in this paragraph shall be binding upon Husband's heirs, executors, administrators, successors and assigns, and shall constitute a charge against Husband's estate. Husband agrees to be responsible for one-half the reasonable cost of undergraduate college education for the Child including but not limited to the following: tuition, room, board, books, supplies, fees, transportation, and clothing. Husband's obligation pursuant to this paragraph is conditioned upon his being consulted with respect to the choice of educational institutions and his approval thereof obtained, provided, however, that his approval shall not be unreasonably withheld, and providing that: the d~~rrdhtc~r h,l made ,3 re:~sonahle effort to obtain scholarship and other financial aid which shall first be deducted from the total cost of_ undergraduate college education. Husband does agree that the obligations imposed herein shall take precedence over any college expenses and costs for any adopted er step children of Husband. There is Curren*_ly on Order dated ~,~,~c,J~ ~ ~ 1985, which directs the Defendant to pay the ;35.00 per week child support as per the ,L attached Agreement and which assess~"aaainst Defendant an additional $10.00 per week toward arrearages of $420.00 for the period from June 11, 1985, through August 30, 1985, and this is docketed to No. 604 S 1985 (DR 12,660). ~~ ~+q 3 k~r ~H ' ~ .a ~\.13:~ ~ 1MT~ i9n~ iii.' 1 i f^{," ~~ G tY a3u~1"t;' ,~;~ ~ ~ ~~ J BY THE COURT, - ; _. J. '~ } ~~~ ~F l y t EXHIBIT ~r j~. k e 1,: __ 4 K~z :. ,r is-~'~~ ~' PROPERTY SETTLEMENT AGREEMENT ~ {l: ~ / THIS AGREEMENT , dated the ~Yr day of j ~,~"L--~ l ~-Y-ti-~ 198 a , .: ~~ by and between DEERA ANN HEINEMAN, formeriv residing at 1:115 Oak Street, Carlisle, Cumberland County, Pennsylvania, Social Security No. 176-53-575Q, hereinafter called the "Wife", and CARL 6JALTER HEINEMAN,. residing at 5~ East High Street, Apt. 3, Carlisle, Cumberland County, Pennsylvania, Social Security No. hereinafter called the. "Husband", echo agree as follo~,~s: 4J I T N E S S E T H 6dHEREAS, the parties are Husband and wife, having been married on July 19, 1930, in Carlisle, Cumberland County, Pennsylania. The parties separated October 13, 1984. wIILI~u'nS, tF:~re Have beer: issue of the marriage, to wit, ABBY LYNN HI/Ii]EM.~1N, born ?~u«u:,t 15, 1984, hereinafte*_- re;~erred to as the "Child'" WHEREAS, diverse unhappy differences, disputes, and difficulties have arisen between the parties, and it is the intention of G1ife and Husband to live separate and apart for the rest of their natural lives, and the parties hereto are desirous ~f settling fu]ly and finally their respective financial and property rights and obligations as between each other including, without limitation by specification: the settling of all matters between them relating to the ownership and equitable distribution cf real and personal property; the settling of all matters between them relating to the past, present and future support, alimony and/or maintenance of wife by Husband or -1- of Husband by Wife; the settling of all matters between them reiat_ing to the past; present and future support and/or maintenance of. the Child, the pa. ~;e. -l r::~ ~;~ ,.r,errj _.:e se~__ing of any and a_1 claims and possible claims by one against the other or against their respective estates. NOW THEREFORE, in consideration of the promises 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, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: 1. AGREEMENT NOT A BAR TO DIVOP.CE PROCEEDINGS This Agreement shall not be considered to affect or bar the right of Wite or Husband to a limited or absolute divorce on lawful grounds if such grounds now exist or shall hereafter e~:ist or to such defense as may be available to either part°.r. This Agreement is not intended to condone and shall not be deemed to be a condonation on the part of either party hereto of any act or acts on *_he part of the other party which have occasioned the disputes or unhappy differences which have occurred prior to or which may occur subsequent to the date hereof. The parties intend to secure a mutual consent, no-fault divorce pursuant to the terms of Section 201(c) of the Divorce Code of 1980. 2. EFFECT OF DECREE, NO MERGER It is specifically agreed, however, that a copy of this Agreement may be incorporated, by reference, into a divorce judgment or decree. This -2- incorporation, however, shall not be regarded as a merger, it being the intent of the parties to permit this Agreement to survive any such judgment, unless otherwise specifically provided herein, and for this Agreement to continue in full force and effect after such time as a final decree in divorce may be entered with respect to the parties. The parties agree that the terms of this Agreement shall be incorporated into any divorce decree which may be entered with respect to them for purposes of enforcement only of any provisions therein, but shall survive such decree. 3. EFFECTIVE DATE The effective date of this Agreement shall be the date upon which it is executed; however, the transfer of the property provided for herein shall only take place upon the entry of a final decree in divorce, unless olli~~~wir,c ii~~ii~~,~I~~,l. 'I'(i~_, :.u E,~~~-~1L E~iuvisivus ~a1 Liiis Ayreement shall take effect as indicated. Notwithstanding the foregoing, if a final decree in divorce shall not have been obtained within four (?) months from the date of execution of this Agreement, this Agreement shall be null and void. 4. DRTE OF EXECUTION The "date of execution" or "execution date" of this 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 "dar_e of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 5. DISTRIBUTION DATE Tire transfer of property, f~_inds and;or documents provided for herein -3- shall take place simultaneously with the execution of this Agreement. 6. ADVICE OF COUNSEL Wife and Husband declare that each has had a full and fair opportunity to obtain independent legal advice of counsel of her and his selection; that Wife has been independently represented by counsel and that Husband, cognizant of his right to legal representation, declares that it is his e~:press, voluntary and knowing intention not to avail himself of his right to counsel and chooses instead to represent himself with respect to the preparation and execution of this Agreement. 7. FINANCIAL DISCLOSURE The parties confirm that each has relied on the substantial ar_curacy cf the financial discloSllra_ of the other as an inducement to the execution of this ?agreement . 8. P[:RSONAT fZIGfiTS Wife and Husband may and shall, at all times hereafter, live separate and apart. They 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. They may reside at such place or places as they may select. Each may, for his or her separate use or benefit, conduct, carry on and engage in any business, occupation, profession or employment which to him or her may seem advisable. However, each party shall make best efforts to maintain employment of at least comparable benefits and salary as they now hold or for which they are in training. -4- 9. NO P~IOLESTATION Husband and Wife shall not molest or interfere with each other, nor shall either of them attempt to compel the other to cohabit or dwell with her or him, b}~ any means whatsoever. Neither party shall harass or be verbally or physically abusive to the other. 10. MU"'UAL RELEASES Husband and 6.7i.Fe each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and interests or claims in or against the property (including income and gain. from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which he or she now has or at_ any time hereafter rna•,~ have ag~rinst such other, thi> est,zte of sui~h other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or curtest', or claims in the nature of dower or curtest' or widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right to great a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse tc participate in a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania, (b) any State, Commonwealth or territory of the United States, or (c) any other country, or any rights which either party may have or at any time hereafter have for past, present or future support or maintenance, alimony, a].imor,y pendente life, counsel fees, ecuitar+le distrii~ution, costs or e>:penses, whether arising as a result -5- of the marital relation or otherwise, except, and only except, a:11 rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof. It is the intention of Husband and 6Vife to give to each other by the execution of this Agreement a full, complete and general release with respect to ar~y 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 thereof. 11. EQUITABLE DISTRIBUTION Or PROPERTY It is spec ifi.cal.i~.~ understood and agreed that this Agreement constitutes an equitable distribution of property, both real and personal, wli ic:ii w~i:; 1 c,~,l,i I I ~;~ ~iticl In:iicL i. c;.~~~1 t y acquirc;d by Husband and Wife or either of them during the marriage„ as contemplated by Tkie Act of April 2, 1980 (P.L. No . 26 ; known as "'i lie ~%ivorce. Code" ; ~3 P . S . i01 et seq. of the Commonwealth of Pennsvlvania. And furti-ier, that the parties have attempted to divide their marital property in a manner which conforms to the criteria set forth in §;401 of the Pennsvlvania Divorce Code, and taking into account the following considerations: the length of the marriage; the prior marriages of the parties; the age, health, station, amount and sources of income; vocational skills; employability; estate; liabilities and needs of each of the parties; the contribution of one party to the education, training, or increased earning power of the other party; the opportunity of each party for future -o- acquisition 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 marital property, including the contribution of a party as a homemaker; i:he value of the property set apart to each party; the standard of living of the parties established during the :r~arriage; and the economic circumstances of each party at the time the division of pzoperty is to become effective. (A) Personal Propert (1) Husband and Wife do hereby acknowledge that they have previously divided their tangible personal property including, but without limitation, je:eelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, pictures, books, works of art, savings bonds, and other personal property, and hereafter Wife agrees that all of the property in the possession of I-Iusband shall be the sole and separate property of Husband, and Husband agrees that all of the property in the possession of Wife shall be the sole and separate property of Wife,, except that the Ydife is to receive the 1983 Datsun Pulsar car, the master bedroom suite, the microwave oven, and all wedding gifts, including china, silver, and correllware. The parties do hereby specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other. This Agreement shall have the effect of an assignment or bill of sale from each part.; to the other for such property as -7- may be in the individual possessions of each of the parties hereto. (2} 6~]ife shall remove the above items within thirty (30) days of the date of this Agreement. Thereafter, each party shall own, have, and enjoy, independently of any claim of the other party, all items of tangible personal property of any kind, nature, and description wherever i.t is located, which are not owned or held by him or her or which may hereafter belong or come to him or her, with full power to him or her to dispose of that tangible personal property as fully and effectively in all respects and for all purposes as if he or she were unmarried. (B) Distribution of Chec};ing and Savings Accounts: For the mutual promises and covenants contained in this Agreement, Wife hereby waives all right, title, claim or interest she may have by equitable distribution or ni.hi~r~~i:>~~, in I h~~ l u1 1c~w~in~-~ l~,~rk racuu~.itiLs CAL llusband: (1) PZrm~r.'s Trost Company acct. No. 00581054, current balance unknown. This was previously a joint account. (2) PSESCU Acct. No. 0208423809, current balance of $49.79. Similarly, for the mutual promises and covenants contained in this Agreement, Husband hereby waives all right, title, claim, or interest he may have by equitable distribution or otherwise, in the following bank accounts of taife: (1) Farmer's National of Newville Acct. No. 83b2, current balance of 51,200.00. (2) Farmer's National of Newville Acct. No. current balance of X51.00. -8- ~,w.,,~..r_.._.__ _,._ f (C) waiver o[ Interest in Retirement Funds: Each party waives the right to any interest in any retirement_ fund or account of the other party. (D) Motor Veriicles: A~ith respect to the motor vehicles owned by one or both of the parties, they agree as follows: (1) The 1983 Datsun Pulsar, currently jointly titled, shall become and remain the sole and exclusive property of the Lv'ife and shall be titled to her at Husband's expense. The Wife agrees to indemnify and hold harmless the Husband from any and all responsibility for the encumbrance on said vehicle with Drover's & Mechanics's Bank, which has a current balance due of 55,069.79 on the loan of August 1983. Monthly payments are 5153.63. (2) The 1977 Datsur., currently jointly titled, shall become and remain the sole and exclusive property of the Husband, and shall be titled to him at his own ea:~ense. There is not a lien on this vehicle. (E) Subsequently Acquired Property: Husband and Wife agrE:e to waive and re.Li~rquish any and all right that he or she may now have or hereafter acquire in ar.y real or tangible or intangible personal property subsequently acquired by the other part}~. Husband and Wife specifically agree to waive and r e 1 i nt~u i sli ,iny r i nth I, i n :>uch hrc~perty that may arise as a result of the marriage relationship, including, without limitation, dower, curtesy, right to equitable distribution under the Divorce Code statutory allowance, widow's allowance, right to take in intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's es'=ate; and each party will, at the request of the other, execute, achnowledg~, and deliver any and all instruments which may be necessary or -9- advisable to carry into effect the mutual waiver and relinquishment of such interest, rights, ar:d claims. (F) W3rranLV as to Existing Obligations: Each party represents that they have not heretofore incurred or contracted for any debt or liability or obligation for which the estate of the other party may be responsible or liable except as may be provided for in this Agreement. Each pasty agrees to indemnify or hold the other party harmless from and against any and all. such debts, liabilities or obligations of every kind which may have heretofore been inr_ur_red by them, including those for necessities, except for the obligations arising out of this Agreement. (V) Warranty as to Future Obligations: Wife and Husband esch covenant, warrant, represent and agree that each will now and at all times her-eafter save harmless and k,eeE~ the otttcr indernr~iC led trom ~-~l]. :9ebts, charges and liabilities incurred by the other after the execution date of t_t~i.s A~~ree~nent, e:•:cept as may be otherwise specifically provided for by the terms of this Agreement and that neither of them shall hereafter incur any liability whatsoe•~~er for whici-i the estate of the other may be liable. (H} Payment of Specified Obligations: During the course of the marriage, Wife and Husband have incurred certain bills and obligations and ha~~~e amassed a variety of debts, and it is hereby agreed, without the necessity of ascertaining for what purpose and to whose use each of the bills were incurred, that the parties shall each be solely responsible for bills, obligations and debts as set forth below: (1) Husband to be responsib]-e for VISA Acct. No. , -1G- ,,......nom. ..'.,,.~•..-v' n,w..= rt• - v current balance due of $ (2) The Husband agrees to indemnify and hold harmless the Wife from any and all responsibility for any balances due under the lease for rental of the apartment at 52 East High Street, Apt. 3, Carlisle„ Pennsylvania, which was previously the marital residence and in which the Wife and Child no longer reside. (3) Wire shall. assume the debt to Drover's & Mechanics's Sank for the 1983 ~ats~,n P~_~ 1 s~ r as stated prey i ously in paragraph 11 (D) ( ]. J at~ove. Each party agrees to hold the other harmless from any and all liability wizich may arise from the aforesaid bills and which, pursuant to the terms herein, are not the responsibility of the other party. 12. ~LINIONY l~~~th Ntir L ic:; ~,~,r~~c t.o w,~ive recei_~~t_ of alimony as well as the right to seek alimony in t}iis matter. 13. SUPPORT Husband shall pay to Wife for support and maintenance of the Child the sum of 535.00 per week. All financial obligations undertaken by Husband in this paragraph 13 shall be binding upon f-tusband's heirs, executors, administrators, successors and assigns, and shall constitute a charge against Husband's estate. 14. AUTOMATIC INCREASE IN AMOUNT OF SUPPORT Husband agrees that the above provisions for support shall be increased automatically as follows: By the same proortion as any net salary increase received b•: the father; that .is, for example, but no*._ limited to, if he -11- receives a ].0~ net salar~z~ increase, support will automatically also be increased by 10~. Husband is to provide Wife with statements of any such increases from his employer within fifteen (15) days of his receipt of an increase. All financial obliaations undertaken by Husband in this paragraph 14 shall be binding upon Husband's heirs, executors, administrators, successors and assigns, and shall constitute a charge against Husband's estate. 15. HIGHER EDUCATION EXPENSES OF THE CHILD Husband agrees to be responsible for one-half the reasonable cost of undergraduate college education. for the Child including but not limited to the following: tuition, room, beard, books, supplies, fees, transportation, and clothing. Husband's obligation pursuant to this paragraph is conditioned up,~n hi:; bring consulted with respect to the choice of educational i.r:sti.tutions and his approval thereof obtained, provided, however, that h!:; approval shall not be unreasonably withheld, and providing that the daughter has made a reasonable effort to obtain scholarship and other financial aid which shall first be deducted from the total cost of undergraduate college education. l3usband does agree that the obligations imposed herein shall take Precedence over any college expenses and costs for any adaf.>ted or :step children of Husband. 16. TAX RETURNS Husband and Wife agree to sign joint returns for the calendar year 1984, and if the parties are entitled to any refund hereunder, such refund shall be divided equally between the parties. Should there be a liability, the parties shall each pay one-half of any liability. -ice 17. INCOME TAX PRIOR RETURNS The parties have heretofore filed joint federal, state and local income tax returns. f~usband agrees that in the event any deficiency in federal, state, or local. income tax is proposed fer 1984 taxes or any previously filed returns, or any assessment of any such tax is made against laife by reason of her Having joined in the filing of said joint returns, Husband will indemnify ar.d hold Wife harmless from and against any loss or liability for any such tart deficiency or assessment and any interest, penally, and expense incurred in connection therewith, and such tax, interest, penalty or expense shall be paid solely and entirely by Husband, unless said tar„ interest, penalty or expense is finally determined to be attributable to misrepresentations or failures to disclose the nature and extent of Wife's sep~rat_~~ inc•onn~ ~u, ti~~~, ~,ir~ret;;_iic9 jninf. returns. 1S. DGPLNDENC`_' EXEMPTIONS For 1985 and thereafter, the ~/Jife shall solely be entitled to claim the Child as a dependent for income ta•r. purposes, and the Husband shall refrain from claiming the C~i_ild as a dependent on his income to}: returns from date of this Agreement forwazd. 19. MEDICAL INSURANCE The Husband and 6dife hereby agree to maintain medical insurance on the minor Child, in addition to the amount of support set forth in paragraph 13 above. Each party s;,.ali be entitled to any reimbursements or refunds paid by any major medical insurance carrier on account of said medical expenses in excess of the hospital and medical insurance coverage in the same ratio -13- .+...~.nna..~w~/wWr~cww++>~T"vY.'R°r:nit'n~Mxa^P!R~m'y.rWiMwtlltM:;4M''NMy~t'~*[!4RIq~~.:::N1'"M','M..."Mh4p... :: ~....f. ,..~.. ^"'1Ri;rsaR.+~A~74^ R?H?~A!kM^3a .... -.. ... .. ,,. Slfl~1`. as their payment of medical expenses bears to the Husband shall be required to submit a copy of any Wife quarterly, for purposes of filing Major Media Husband agrees to provide the Wife a copy of each reimburse Wife from such pavmetns within ten (10) for sums advanced by Wife. total medical expenses. insured medical bills to gal insurance claims. The such claim filed and will days of receipt of same, 20. CUSTODY AND VISITATION The parties agree that legal custody of the said Child shall be jointly with the Mother and the Father. However, the Mother shall have actual physical custody except as further stated. The Father shall have partial custody of the Child as follows: (A) Beginning December 22, 1934, every other weekend from 6:00 p.rn. F'rid~y t<~ 6;00 p.m. Sunday. (B) On the following alternate t-~olidays from 9:00 a.m. to 6:00 p.m. beginning with Easter 1985: Easter, Memorial Day, July 4th, Labor Day, Thanksgiving. (C) From 9:00 a.m. to 6:00 p.m. Christmas Eve and Father's Day. The Father, upon reasonable notice to the Mother, may have additional and other periods of ~:~isitation and/or partial custody as the parties, including the Child, can agree. It is further agreed that this Agreement or any subsequent Order of Custody and Visitation, shall be filed of record with the proper Court in whatever jurisdiction in ~;~hich the parties reside, as well as in Per.nsvlvania . -14- 21. ILLNESS OF CHILD Ir, tht°_ event o` any serious illness of the Child at any time, any party then having custody of the said child shall i,~:mediately comrnunica~te with the other party of the nature of the illness. During such illness, each party shall have the right to visit the Child as often as she or he desires, consistent with the proper medical care of the said Child. 22. CONSULTATION PRIVILEGES In addition to any provisions which may be contained herein regarding custody and visitation, the Husband shall have the following rights with respect to the Child: Reasonable telepone calling privileges; access to report cards and other relevant information concerning the progress of the Child in school; approval of extraordinary medical and/or dental treatment excr'pt in t he c~~1:Si' ~! tin emer~3ency and provided that such approval shall not be ur.rea.~onably wi±.hl-~eld; approval of summer camp and schools provided that such approval sra.11 not be unreasonably withheld. [wife shall confer with Husband on all matters of importance relating to the Child's health, maintenance and education with a view towards obtaining and following a harmonious policy in the Child's best interests and shall keep the Husband informed of the progress of the Child's education and social adjustments. 23. COUNSEL FEES Each party agrees to be responsible for his or her own legal fees and expenses. 24. BREACH OF AGREEMENT If either party fails in the due performance of obligations under this -1J- Agreement at their election, the non-breaching party shall have the right to sue for damages for breach of this Agreement or to rescind same and seek such legal remedies as may be available to them. The breaching party will be responsible for legal fees and costs incurred by the non-breaching party necessary to the enforcement of this Agreement. 25. INTEGRAT?ON This Agreement constitutes the entire understanding of the ,parties and supersedes any and all prior Agreements and negotiations between them. There are no representations or warranties other than these expressly set forth herein. 26. NO [VAIVEF. OF DEFAULT This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the tr=arms of this Agreement=. `Ph,e Failure of either part~~ tc insit upon strict performance of an4~ of the previsions of this Agreern~nt s'r-~a11 in no way affect the right of such party hereafter to enforce the same, nor shall the :vaiver of any breach of any provision hereof be construed as a waiver cf any subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. ?7. WAIVER OR MODIFICATION TO BE IN WRITING No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties, and no waiver of any breach hereof or default hereunder shall be deemed a waiver of ar.y subsequent default of the same or similar nature. 25. P4UTUAL COOPERATION EaC% DAL t\r Sf1~ l '. ~'. <~n`,' ._ ~ i"iE' and ~rOf'1 t1mE? `O t1mG }1(_'TC'uftC'r, take do}' -16- and ail steps and er,ecute, acr:nowledge and deliver to the other party any and all further i.r.struments andior documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of `phis Agreement. 29. PdOTICE FROVZSIONS Nctice to Husband shall be sent by certified mail, return receipt requested, to Carl 6J. Heineman, 52 East High Street, Apt. 3, Carlisle, Pennsylvania, 17013, or such other address as Husband from time 1.o time may designate in writing. Notir_e to Wife shall be snt by certified mail, return receipt requested, to Debra A. Heineman, 1115 Oak Street, Carlisle, Pennsylvania, 17013, and Ruby D. Weeks, Esquire, 4 North Hanover Street, Carlisle, Pennsylvania, 1701.3, or such other address as Wife from tis»e to time may designate in wr.itinq. 30. LAW CF PENNSYLVANIA APPLICABLE This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date of execution. of this Agreement. 31. AGREEMENT BINDING ON HEIRS This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successor-s an~1 ass ions . 32. SEVERABILITY If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or in~.~alid in law or other~~~ise, then only that term, condition, clause or provision shall be stricY.en from this -17- Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet her or his obligations under any one or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. 3~. HEADINGS NOT PART OF AGREEMENT Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part oi' this Agreement nor shall they affect its meaning, construction er effect. 3~. WARRANTY OF DISCLOSURE The parties warrant and represent that they have made a full disclosure of all assets prior to th^ execution of this Agreement. This Agreement between the parties is based upon this disclosure. IN WITNESS Lv'HEREOF, the parties hereto have set their hands and seals the day and year first above caritten. ^. ~~_ ) i~~~ L- L- ~t~/ ,~~F ~~(. ~ .l ~ 1 r \ ( SEAL ) Witness , C~r,1 Walter neman W ~ ~' 1 ~ ~i ~ ^`/~ i r/,f~ '~' ~ ' / ~?L~; /,s%1''^,( SEAL ) witness ~ Debra Ann Heineman -i~i- COMMONWEALTH OF PENNSYLVANIA ss COUNTY OF CUMBERLAND %/~ L~" ~ On this, the ~~ day of !"G~~~'L';~'~!'~1 19~-r before me, a ~/ Notary Public, the undersigned officer, personally appeared Carl Walter Heineman known to me tc be the person whose name is subscribed to the within Property Settlement Agreement, and acknowledged that he executed the same for the purposes thereir. contained. ~~, i =~ ~/ Notary Public KAREN! F, BYEitS, Notory Pvbiic ~ Forth Hanover St, Carlisle; Cumb~rfand Ciy., PA 17.;1;, My 7cerrn 'Expires I~CEfi s~~ i987 COMMONWEALTH) OF PENNSYLVANIA ss COUNTY OF CUMBERLAND On this, the -!' ~ day of _ 19~ before me, a Notary Public, tYie undersigned officer, personally appeared Debra Ann Heineman known to me to be the person whose name is subscribed to the within Froperty Settlement Agreement, and acknowledged that she executed the same for the purposes therein contained. .:_ .. _ , Notary Public SHARON ,~. MOSER, Notary Public .,,.a, My U~s'.:~s:.....; _ ,._ ~.,<<. ',4, 1985 ~~-~-~-~-°',. 1 VCari is~fl'~;-°#'a+t~~yay,1 ~ ~~l J Z'~~~t3°7 DEBRA ANN HEINEMAN, IN THE COURT OF COMMON FLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW IN DIVORCE CARL WP.LTER HEINEMAN, Defendant NO. 3749 CIVIL 1984 ORDER OF COURT ~._ ~~..~ i~ ~ L. f'tl ~L ~_. ~l._. AND NOW, this ~ day of:`A•innfst, 1985, Debra Ann Heineman, by her attorney, Ruby D. Weeks, Esquire, and Carl W. Heineman, having been divorced and separated from the nuptial ties and bonds of matrimony by previous decree of this Court, hereby agree and consent to the entry of the signed decree for payment and enforcement of child support as provided in the Property Settlement Agreement of February 14, 1985, which Agreement has not merged into tY~e decree of divorce, and which Agreement is attached hereto and made a part of this Order for purposes of enforcement only, and IT IS ORDERED AND DECREED THAT: Husband shall pay to Wife for support and maintenance of the Child the sum of $35.00 per week. All financial obligations undertaken by Husband in this paragraph 13 shall be binding upon Husband's heirs, e:cecutors, administrators, successors and assigns, and shall constitute a charge against Husband`s estate. Husband agrees that the above provisions for support shall be increased automatically as follows: By the same proportion as any net salary increase received by the father; that is, for example, tut not limited to, if he receives a 10'o net salary increase, support will automatically also be increased by 1GS. Husband is to provide C^life with statements of any such i ~ - x_..... _ ..~. _..~. ~_ __ ~. _ ,_..__ r. . increases from his employer within fifteen (15) days of his receipt of an increase. All financial obligations undertaken by Husband in this paragraph shall be binding upon Husband's heirs, executors, administrators, successors and assigns, and shall constitute a charge against Husband's estate. Husband agrees to be responsible for one-half the reasonable- cost of undergraduate college education for the Child including but not limited to the following: tuition, room, board, books, supplies, fees, transportation, and clothing. Husband's obligation pursuant to this paragraph is conditioned upon his being consulted with respect to the choice of educational institutions and his approval thereof obtained, provided, however, that his approval shall not be unreasonably withheld, and providing t:h;r t. the r3;~liclhtc~r h,~s made ,3 rea,on~3hle eFfc,rt: to obtain scholarship and other fi-nanr_ial aid which shall first be deducted from the total cost of undergraduate college education. Husband does agree that the obligations imposed herein shall take precedence over any college expenses and costs for any adopted or step children of Husband. There is currently on Order dated ~~~a~,~'I a.~ 1985, which directs the Defendant to pay the $35.00 per week child support as per the l attached Agreement and which assess~"against Defendant an additional $10.00 per week toward arrearages of $420.00 for the period from June 11, 1985, through August 30, 1985, and this is docketed to No. 604 S 1985 (DR 12,660). ~~+ ,";'3~rr ~ ,., ~+t, of : r',° f :~, rte, ,'3~ ~3iit~:; s"~. Cam, , ~- ~_ - ,i! ~f iii iGlli;~r~7'y' 7~~r~ BY THE COURT, '~ J.,~ +{qy~/~ ~' ` ~ a + , ~ "': Y ~ ~ .. .. PROPERTY SETTLEMENT AGREEMENT TFIIS AGREEMENT, dated the .'rte `r ~ ~ i _--i i -rf day o f j .~,t L-.~ l cc":.T...:,~ 19 8 S, ~~ by and between DEBRA ANN HEINEMAN, formerly residing at 1115 Oak Street, Carlisle, Cumberland County, Pennsylvania, Social Security No. 176-52-5750, hereinafter called the "Wife", and CRRL WALTER HEINEMAN, residing at 52 East High Street, Apt. 3, Carlisle, Cumberland County„ Pennsylvania, Social Security No. hereinafter called the "Husband", ~aho agree as follows: 4J I T N E S S E T H 6dHEREAS, the parties are Husband and Wife, having been Riarried on July 19, 1980, in Carlisle, Cumberland County, Pennsylania. The parties separated October 13, 1984. lJllliltL:AS, there have been issue of the marriage, to wit, ABBY LYNN HEICdE"9AN , born August 15 , 1984 , hereinaf to*_- . re;°erred to as the "Child" . WHEREAS, diverse unhappy differences, disputes, and difficulties have arisen between the parties, and it is the intention of Wife and Husband to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other including, without limitation by specification: the settling of all matters between them relating to the ownership and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present and future support, alimony and/or maintenance of Wife by Husband or -1- ~~.. ,. of Husband by 6v if e; the settling of all matters between them relating to the past; present and future support and/or maintenance of the Child, the pa: CiE,s; -3r,d in ,aner:~., tt:e settling of any aad all claims and possible claims by one against the other or against their respective estates. NOSa THEREFORE, in consideration of the promises 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, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: 1. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS This Agreement shall not be considered to affect or bar the right of Wife or Husband t_o a limited or absolute divorce on lawful grounds if such grounds now exist or shall hereafter e~;ist or to such defense as may be available to either party. This Agreement is not intended to condone and shall not be deemed to be a condonati of any act or acts on the part of the disputes or unhappy differences which occur subsecuent to the date hereof. consent, no-fault divorce pursuant to Divorce Code of 1980. ~n on the part of either party hereto other. party which have occasioned the have occurred prior to or which may The parties intend to secure a mutual the terms of Section 201(c) of the 2. EFFECT OF DECREE. NO MERGER It is specifically agreed, however, that a copy of this Agreement may be incorporated, by reference, into a divorce judgment or decree. This -2- incorporation, however, shall not be regarded as a merger, it being the intent of the parties to permit this Agreement to survive any such judgment, unless otherwise specifically provided herein, and for this Agreement to continue in full force and effect after such time as a final decree in divorce may be entered with respect to the parties. The parties agree that the terms of this Agreement shall be incorporated into any divorce decree which may be entered with respect to them for purposes of enforcement only of any provisions therein, but shall survive such decree. 3. EI'FECTIVE DATE The effective date of this Agreement shall be the date upon which it is executed; however, the transfer of the property provided for herein shall only take place upon the entry of a final decree in divorce, unless ollic•twiru indi~~,ctc~l. 'I'hc_~ :;uE,pv~L p~uvisiuu~ c.~1 Luis Ayreement shall take effect as indicated. Notwithstanding the foregoing, if a final decree in divorce shall not have been obtained within four (4) months from the date of execution of this Agreement, this Agreement shall be null and void. 4. DATE OF EXECUTION The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which it is executed by the parties if tYiey have each executed the Agreement on the same date. Otherwise, the "dat:e of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 5. DISTRIBUTION DATE Tt~e transfer of property, funds andJor documents provided for herein -3- shall take place simultaneously with the execution of this Agreement. 6. ADVICE OF COUNSEL Wife and Husband declare that each has had a full and fair opportunity to obtain independent legal advice of counsel of her and his selection; that Wife has been independently represented by counsel and that Husband, cognizant of his right to legal representation, declares that it :is his express, voluntary and knowing intention not to avail himself of Yiis right to counsel and chooses instead to represent himself with respect t:o the preparation and execution of this Agreement. 7. FINANCIAL DISCLOSURE The parties confirm that each has relied on the substantial_ accuracy of 'the financial disclosure of the other as an inducement to the execution of this t~greernent . 8. PER50NAT RIGIiTS Wife and Husband may and shall, at all times hereafter, live separate and apart. They 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. They may reside at such place or places as they may select. Each may, for his or her separate use or benefit, conduct, carry on and engage in any business, occupation, profession or employment which to him or her may seem advisable. However, each party shall make best efforts to maintain employment of at least comparable benefits and salary as they now hold or, for which they are in training. -4- 9. NO MOLESTATION Husband and Wife shall not molest or interfere with each other, nor shall either of them attempt to compel tt:e other to cohabit or dwell with her or him, by any means whatsoever. Neit=her party shall harass or be verbally or physically abusive to the other. 10. MUTUAL RELEASES Husband and 6~1ifa each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and interests or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of orhatever nature and wheresoever situate, which he or she now has or at any time hereafter may have aq~~inst such oY.her, i.ha~ estate of ui.`.h other or an,~ part thereof, whether. arising out of any former acts, contracts, engageme~rts or li.ab.ilities of such other or by c•/ay of dower or curtest', or claims in the nature of dower or curtest' or widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's Will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse tc• participate in a deceased spouse's estate, whether arising under the laws of (a) Penr.syl~~ania, (b) any State, Commonwealth or territory of the United States, or (c) any other country, or any nights which either party may have or ate any time h~:reafter have for past, present or future support or maintenance, alimony, a7.imony pendente :Cite, counsel fees, equitable distriuution, costs or expenses, whether arising as a result -5- of the marital relation or otherwise, except, and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise ur~:;ier this Agreement or for the breach of any thereof. It is the intention of Husband and L9ife to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof. 11. EQUITABLE DISTRIBUTION OF PROPERT`1 It is spec ificall~_~ understood and agreed that this Agreement constitutes an equitable distribution of property, both real and personal, which w,r:~ I c:~~~i l i y ,+ncl I~uneL i.c i~.il ly acuuired by Husband and Wife or either of them during the marriage, .js contemplated by Tl~e Act of April 2, 1980 {p.L. No. 261 knokm as "'ilie I)ivorcr Code", 23 P.S. 101 et seq. of the Commonwealth of Pc-nnsvivania. And further, that the parties have attempted to divide their marital property in a manner which conforms to the criteria set forth in F;401 of the Pennsylvania Divorce Code, and taking into account the following considerations: the length of the marriage; the prior marriages of the parties; the age, health, station, amount and sources of income; vocational skills; employability; estate; liabilities and needs of each of the parties; the contribution o[ one party to the education, training, or increased earning power of the other party; the opportunity of each party for future -6- acquisition 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 marital property, including the contribution of a party 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 property is to become effective. iA) Personal Property: (1} Husband and Wife do hereby acknowledge that they have previously divided their tangible personal property including, but without limitation, jewelry, clot!1es, furniture, furnishings, rugs, carpets, Household equipment and appliances, pictures, books, works of art, savings bonds, and other personal property, and hereafter Wife agrees that: all of the property in the possession of ftusband shall be the sole and separate property of Husband, and Husband agrees that all of the property in the possession of Wife shall be the sole and separate property of Wife, except that the Wife is to receive the 1983 Datsun Pulsar car, the master bedroom suite, the microwave oven, and all wedding gifts, including china, silver, and correllware. The parties do hereby specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other. This Agreement shall have the effect of an assignment or bill of sale from each party to the other for such property as -7- may be in the individual possessions of each of the parties hereto. (2) P]ife shall remove the above items within thirty (30) days of the date of this Agreement. Thereafter, each party shall own, have, and enjoy, independently of any claim of the other party, all items of tangible personal property of any kind, nature, and description wherever .Lt is located, which are not owned or held by him or her or which may hereafter belong or come to him or her, with full power to him or her to dispose of that tangible personal property as fully and effectively in all z-espects and for all purposes as if he or she were unmarried. (B) Distribution of Checking and Savings Accounts: For the; mutual promises and covenants contained in this Agreement, Wife hereby waives all right, title, claim or interest she may have by equitable distribution or r>t.hcrw i :>c , i ii t hr. l u I i caw i ~i`-I I~~ink ,~ct:ui.inLs ~~~L llusbai~d: (1) Farmer's Trust Company Acct-. No. 00581054, current- balance unknown. This was previously a joint account. (2) PSESCU Acct. No. 0208423809, current balance of $4'9.79. Similarly, for the mutual promises and covenants contained in this Agreement, Husband hereby waives all right, title, claim, or interest he may have by equitable distribution or otherwise, in the following bank accounts of Wife: (1) Farmer's National of Newville Acct. No. 8362, current balance of $1,200.00. (2) Farmer's National of Newville Acct. No. Current balance of $51.00. -8- (C) Waiver of Interest in Retirement Funds: Each party waives the right to any interest in any retirement fund or account of the other party. (D) Motor Vehicles: Pdith respect to the motor vehicles owned by one or both of the parties, they agree as follows: (1) The 1983 Datsun Pulsar, currently jointly titled, shall become and remain the sole and exclusive property of the Wife and shall be titled to her at Husband's expense. The Wife agrees to indemni-fy and hold harmless the Husband from any and ali responsibility for the encumbrance on said vehicle with Drover's & Mecizanics's Bank, which has a current balance due of $5,069.79 on the loan of August 1983. Monthly payments are $153.63. (2) The 1977 Datsun, currently jointly titled, shall become and remain the sole and e;{elusive property of the Husband, and sha1:L be titled to him at his own er:pense. There is not a lien on this vehicle. (E) Subsequently Acquired Property: Husband and Wife agree to waive and relinquish any and all right that he or she may now have or hereafter acquire in any real or tangible or intangible personal property subsequently acquired by the other party. Husband and wife specifically agree to waive and relinyuislc ;cny ri~lht. ~n such prc.~pe~rty Chat may arise as a result of the marriage relationship, including, without limitation, dower, curl=esy, right to equitable distribution under the Divorce Code statutory allowance, widow's allowance, right to take in intestacy, right to take agai-nst the Will of. the other, and right to act as administrator or executor of the other's es~ate; and each party will, at the request of the other, execute, acknowledge, and deliver any and all instruments which may be necessary or -9- advisable to carry into effect the mutual waiver and relinquishment of such interest, rights, and claims. (F) Warranty as to Existing Obligations: hack party -represents that they have not heretofore incurred or contracted for any debt or- liability or obligation for- which the es Late of the other party may be responsible or liable except as may be provided for in this Agreement. Each party agrees to indemnify or hold the other party harmless from and against <3ny and all such debts, liabilities or obligations of every kind which may have heretofore been incurred by them, including those for necessities, except for the obligations arising out of this Agreement. (G) Warranty as to Future Obligations: Wife and Husband each covenant, warrant, represent and hereafter save harmless and keep charges and liabilities incurred tt7is A~~ret~ment, except as may t~~e terms of this Agreement and that liability whatsoever for which t; agree that each will now and at all times the other indemni.Cied Lrom all debts, by the other after the execution date of otherwise specifically provided for by the neither of them shall hereafter incur any ze estate of the other may be liable. (Et) Payment of specified Obligations: During the course of the marriage, Wife and Husband have incurred certain bills and obligations and have amassed a variety of debts, and it is hereby agreed, without the necessity of ascertaining for what purpose and to whose use each of the bills were incurred, that the parties shall each be solely responsible for bills, obligations and debts as seY_ forth below: (1) Husband to be responsible for VISA Acct. No. , -10- .. ..... .; ... .. .., ....,. .... .~ .... ...:- . a..r; '.rte .. s,, ~. ,.... , .m ~.~:.~.r . J". F ~. Af. ... current balance due of $ (2) The Husband agrees to indemnify and hold harmless the Wife from any and all responsibility for any balances due under the lease for rental of the apartment at 52 East High Street, Apt. 3, Carlisle, Pennsylvania, wh.ir..h was previously the marital residence and in which the Wife and Child no longer reside. (3) Wire shall. assume the debt to Drover's & Mechanics's Bank fo.r the 1983 Datsrrn Pulsar as stater] pre~ioi.rsly in paragraph 11(D)(1.) above. Each party agrees to hold the other harmless from any and all liability which may arise from the aforesaid bills and which, pursuant to the terms herein, are not the responsibility of the other party. 12. A~1MONY liot_h 1~~u t. ic:; ~nlr~_e to wtr ive rec:e i.pC of alimony as well as the right to seek alimony in this matter. 13. SUPPORT Husband shall pay to Wife for support and maintenance of ther Child the sum of $35.00 per week. All financial obligations undertaken by Husband in this paragraph 13 shall be binding upon Husband's heirs, executors, administrators, successors and assigns, and shall constitute a charge against Husband's estate. 14. AUTOMATIC INCREASE IN AMOUNT OF SUPPORT Husband agrees that the above provisions f_or support shall be increased automatically as follows: By the same proortion as any net salary increase received b~,~ the father; that is, for exarnpl.e, but not limited to, if he -11- receives a ].Os net salary increase, support will automatically also be increased by lOs. Husband is to provide Wife with statements of any such increases from his employer within fifteen (15) days of his receipt of an increase. All financial obligations undertaken by Husband in this paragraph 14 shall be binding upon Husband's heirs, executors, administrators, successors and assigns, and shall constitute a charge against Husband's est~ste. 15. HIGHER EDUCATION EXPENSES OF THE CHILD Husband agrees to be responsible for one-half the reasonable cost of undergraduate college education for the Child including but not :Limited to the following: tuition, room, board, books, supplies, fees, transportation, and clothing. Husband's obligation pursuant to this paragraph is conditioned up~~n hi;; being cnnsul.ted with respect to i_he choice o[ educational i.nsti.ttrt.ions and hi.s approval thereof obtained, provided, however, that his approval. shall. not be unreasonably withheld, and providing that the daughter has made a reasonable effort to obtain scholarship and other financial aid which shall first be deducted from the total cost of undergraduate college education. k]usband does agree that the obligations imposed herein shall take precedence over any college expenses and costs for any adopted or step children of Husband. 16. TAX RETURNS Husband and Wife agree to sign joint returns for the calendar year 1984, and if the parties are entitled to any refund hereunder, such refund shall be divided equally between the parties. Should there be a liability, the parties shall each pay one-half of any liability. -12-- orye+yaawr.nnwom..,~.Y....+.,.w.......e....,.i+.+nay.n.~..wr-a++.......~«w.w~+...oww..iwm+...ri.»....,•wan.+..~+..~. ..,...+.,.+s....<n-+,;r ...u.~-.,.+.m:+w+c.:..u;n.wiansn ~oe:,,_.~.+m~'rFL+."Awsa~ ti..Frtz~ri.eRU'=raxvrr ~.rnmin;.:_rt.>~y~.~°h!Txan-•4a~4'S. 17. IDICOME TAX PRIOR RETURNS The parties have heretofore filed joint federal, state and .local income tax returns. Husband agrees that in the event any deficiency in federal, state, or local income tax is proposed fer 1484 taxes or any previously filed returns, or any assessment of any such tax is made against Wife by reason of her having joined in the filing of said joint returns, Husband will indemnify and hold Wife harmless from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty, and expense incurred in connection therewith, and such tax, interest, penalty ar expense shall be paid solely and entirely by Husband, unless said tar„ interest, penalty or expense is finally determined to be attributable to misrepresentations or failures to disclose the nature and extent of Wife's sep,~ratR> inr~omr~ Dui 11~r ,ilores,iid }Dint returns. 1f3. DGPL•'NDENCY EXEh1PTIQNS For 19£35 and the-reafter, the Wife shall solely be entitled to claim the Child as a dependent for income tax purposes, and the Husband shall refrain from claiming tl~,e Child as a dependent on his income tax returns from date of this Agreement for~~rard. 19. MEDICAL INSURANCE The Husband and Wife hereiay agree to maintain medical insurance on the minor Child, in addition to the amount of support set forth in paragraph 13 above. Each party st:a11 be entitled to any reimbursements or refunds paid by any major medical insurance carrier on account of said medical expenses in excess of the hospital and medical insurance coverage in the same ratio -13- 3?'j+~.`+AF;~?R.i4'%~f~'~44 „9, :.!G`~" .~n~rr~P*7m..L.7:1+9'~l~rii~X~... +~N' ~ayyFpgcyuwwngypny¢.~., ypnyw~x.«+xY.mvraw!IxR4"FZ'A!~Fiv?+",'MRS;t"~.,MA+~*..~'.TL±~`.s'!'•1~t!fit'axrzt% Yt ~ ~-..:~•n,•i°~YMI~.N/.eS,:.T,W";S'+%%~'•M~.'+CfkWW%nr'1i°!M°..•,Y.~.. .,. 4'?°Ti 'x?~ _ as their payment of medical e~<penses bears to the total medica:t expenses. Husband shall be required to submit a copy of any insured medical bills to Wife quarterly, for purposes of filing Major Medical insurance claims. The Husband agrees to provide the Wife a copy of each such claim filed and will reimburse Wife from such paymetns within ten (10) days of receipt of same, for sums advanced by Wife. 20. CUSTODY AND VISITATION The parties agree that legal custody of the said Child shall be jointly with the Mother and the father. However, the Mother shall have actual physical custody except as further stated. The Father shall have partial custody of the Child as follows: (A) Beginning December 22, 1984, every other weekend from 6:00 p.m. F'riduy to 6.00 p.m. Sunday. (B) On the [~oLlowing alternate holidays from 9:00 a.m. to 6:00 p.m. beginning with Easter 1985: Easter, Memorial Day, July 4th, Labor Day, Thanksgiving. (C) From 9:00 a.m. to 6:00 p.m. Christmas Eve and g'ather's Day. The Father, upon reasonable notice to the Mother, may have additional and other periods of visitation and/or partial custody as the parties, including the Child, can agree. It is further agreed that this Agreement or any subsequent Order of Custody and Visitation, shall be filed of record with the proper Court in whatever jurisdiction in ~,ihich the parties reside, as well as in Pennsylvania. -14- 21. ILLNESS OF CHILD In thc- event o_` any serious illness of the Child at any time, any party then having custody of the said child shall immediately communicate with the other party of the nature of the illness. During such illness, each party shall have the right to visit 'the Child as often as she or he de:sir_es, consistent with the proper medical care of the said Child. 22. CONSULTATION PRIVILEGES In addition to any provisions which may be contained herein regarding custody and visitation, the Husband shall have the following rights with respect to the Child: Reasonable telepone calling privileges; access to report cards and other relevant information concerning the progress of the Child in school; approval of extraordinary medical and/or dental treatment except isr e hc~ c~~:;e> ~i tin emer~lenc;y and prnv ided that such approval shall not be unreasonably withl-~eld; approval. of summer camp and schools provided that such approval shall not be unreasonably withheld. t4ife shall confer with Husband on all matters of importance relating to the Child's health, maintenance and education with a view towards obtaining and following a harmonious policy in the Child's best interests and shall keep the Husband informed of. the progress of the Child's education and social adjustments. 23. COUNSEL PEES Each party agrees to be responsible for his or her own legal fees and expenses. 24. BREACH OF AGREEMENT If either party fails in the due performance of obligations under this -15- ..~nn«r.:..vr.w~-......,.. ........................rr.-~qk+~.+.4+!~.tr.....+....r ~w ....-..~.tamy m c.!n,,..ve..nl+CRS'~.tN.m'..y^PRM42•'f!f'~4'1~T §:.. +vM1'.a~.,-n. xr._.w~.w. ~~n..(_sTiY,a !njn.+tlisYY~!'9.'*^~'M'''A .rp K:~'~'!2 Agreement at their election, the non-breaching party shall have the right to sue for damages for breach of this Agreement or to rescind same and seek such legal remedies as may be a~•~ailable to them. The breaching party will be responsible for legal fees and costs incurred by the non-breaching party necessary to the enforcement of this Agreement. 25. INTEGRATION This Agreement constitutes the entire understanding of the parties and supersedes any and all prior Agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. 26. NO WAIVER OF DEFAULT This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the tc=,rms of this Agreement. Tfre Failure of either party to insist upon strict performance of any of the provisions of this Agreement shall. in no way affect the right of_ such party hereafter to enforr_.e the sarne, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. 27. WAIVF•.R OR MODIFICATION TO BE IN WRITING No mod ificatinn or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties, and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 25. MUTUAL COOPERATION Fact: party shall, at arrr time and Erorn time to time hereafter, take any -16- v~,e.~.ee...:yra.~ssm~,~e~!n•zm.n.~ar~?ram.;ma.~+cp'+~ba°~'~:''M'Frrc.+~rnrrt~+canna,,~..~~Mg,m*^.4F^lr'~m"=.•+e:.rnnbe~rz~aa?wna!n:,s~...»erarw+rvwsw~i ...~n.,•r.+a~«ea+~nc+e.r.+n+~.rmm!yr*x-r.~..sowwns.+~n.!!.wanamaq".°e. ~wxn.w:....o.aw and all steps and execute, acknowledge and deliver to the other party any ar,d all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. 29. NOTICE PROVISIONS Notice to Husband shall be sent by certified mail, return receipt requested, to Carl Vd. Heineman, 52 East High Street, Apt. 3, Carlisle, Pennsylvania, 17013, or such other address as Husband from time to time may designate in writing. Notice to Wife shall be snt by certified mail, return receipt requested, to Debra A. Heineman,. 1115 Oak Street, Carlisle, Pennsylvania, 17013, and Ruby D. Weeks, Esquire, 4 North Hanover Street, Carlisle, Pennsylvania, ].701.3, or such c>thcr address as Wife Eram time, to t.irne may designate in writing. 30. LAW OF PENNSYLVANIA APPLICABLE This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date of execution of this Agreement. 31. AGREEMENT BINDING ON HEIRS This Agreement sha]1 be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors ant assigns. 32. 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 -17- s~rnK~~tMn+k,bw/wr ~.+raai!~nec+fY2IMRM!~t~. _ ~.. .,.. ~ -... ... .. ,.. ._ .._. _.~- .-...~ .. _ __ .` ,.:.., .. _ .. ,. , .. .. Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet her or his obligations under any one or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. 33. HEADINGS NOT PART OF AGREEMENT Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall. not constitute a ;part of this Agreement nor shall they affect its meaning, construction ox: effect. 3~. 4dARRANTY OF DISCLOSURE The parties warrant and represent that they have made a ful.1 disclosure of all assets prior to t17e execution of this Agreement. This Agreement between the parties is based upon this disclosure. IN WITNESS tdHEREOF, the parties hereto have set their hands and seals the day and year first above written. ~, ;` ~ ~ G-t-~V ~~ ~~_,~'.-~.-~1 ( SEAL ) Witness 1 Cllr, Walter neman 4 ~,~ ~ ~ ~' .-_'r'-~`. ~r'~ ' ~,r/ ' r ~_ ~ F~~!' /!-''C,',~r,'rl°"''~( SEAL } Witness ~ Debra Ann Heineman -li;- COMMONWEALTH OF PENNSYLVANIA ss COUNTY OF CUMBERLAND %11 ~ ~ On this , the ,/ ~ day of /~~ ~~~•~'; t~,~' ~1 19 k~ before me, a J Notary Public, the undersigned officer, personally appeared Carl Walter Heineman known to me to be the person whose name is subscribed to the within Property Settlement Agreement, and acknowledged that he executed the same for the purposes therein contained. ` ~ ~ Notary Public KAREN) F. BYCRS, Notvty Public 4 ~Orih l"ianov~r St. Carlisle; Cumberland C4y., PA l T.i1 J My Xe~rt71 ~xpire+a f'e~ 23, 198T COf~IMON49EALT11 OF PENNSYLVANIA ss COUNTY OF CUMBERLAND - On this , the ~; ~~ day of ,-; ,j ~. 19:x'`- before me, a Notary Public, the undersigned officer, personally appeared Debra Ann Heineman known to me to be the person whose name is subscribed to the within Property Settlement Agreement, and acknowledged that she executed the same for the purposes therein contained. ~ ~ _~~ i - Notary Public SHARON .A. MOGER, Notary public Ca(1i5i2. 1985 y Gc,s~~. DAV.II~ P. JPEI~~TS 4 Janes circle Shippensburg, PA 17257-2165 Telephone: (717) 532-9537 March 14, 2002 Carl. W. Heineman 201 Walnut Street Carlisle, PA 17013 Re: Abby Lynn Heineman College expenses Dear lbir. Heineman, I represent your former wife Debra A. Brinley. Debra has consulted with me concerning your Property Settlement Agreement dated February 14, 1985 as it relates to college expenses for your daughter Abby. Paragraph 15 on page 12 contains the relevant provisions (a copy of which is enclosed for your reference). Under the terms of the agreement you and Debra are to share equally the costs ofAbby's college education- including but not limited to tuition, room, board, books, supplies, fees, transportation. Abby expressed interest in attending Wilkes University in Wilkes-Barre, Pennsylvania. She chase Wilkes in part because it offers smaller class sizes and is located in a less urban area than other schools such as Pittsburgh. She has now been accepted in the Pharmacy program at Wilkes. I would like to formally confirm your agreement with Abby's choice of college. With regard to the expenses of college Debra has already incurred a cod of $ 300 Therefore you owe her $150 at this time. The school has estimated tuition, room and board costs at $20,923 per year after deducting $6,000 per year for the scholarship. It is our understanding that this bill may be paid monthly. There will also be some other miscellaneous expenses such as books and parking. Rest assured that Abby has been trying to obtain scholarships. She has obtained one scholarship which as I indicated has been deducted from the above dollar figures. She has applied for several other scholarships, but she has had no response to date. b'inally there is the question of how you wish make payment of your obligation. Do you want to write your checks directly to Wilkes University, or da you want to pay Debra and she will then submit the full amount to the school? Please send me a written response to the matters that I have raised in this letter. Please let me hear fiam you within fourteen (14) days of the date of this letter. Sincerely, --7 ~:~ David P. Perkins Cc: Debra A. Brinley Z 31-JUL-2002 08:04: 03 `,d i l ices University fER.M: 2t3iD23C3 ~iiLLIiV~G INyDICiw PAGE 1 TSitCilL Abby L. die i.neman 211541014 ?9 Encic Ori ve 3oi11ng Springs, PA 17007 TE.iZ,"~ ITEM OATS DESCr~IPTI~J1`! CHAr~GES CRiEJITS -------- ----------- ------- - # PREVIOUS BILLE{7 SALAiVCE ~ 3OO.OU - CURRENT CHA4fiF5 I~iV~7ICC= DUMBER - ~ I~JOtdE:. ~ 200230 30-JUL-02 Dormitory Charges.. 2441.00 30-JUl-02 Dorm Damage ~Jeposit 50.00 30-JUl-02 Meal Alan 1493.00 30-JUl-02 Course/Lab Fee X0.00 30-JUL-02 Course/Lab Fee 40.x0 313-JiJL-132 , ~atri cul ati on Fee 1113..00 30-JUL-D2 Undergraduaie FT Tuition-Fail 8~97~3.Ot3 30-JUL-02 `Recreation Fee 12.00 30-JUL-02 General Ut-i versi ty Fee-E/T 27+D.t30 30-JUl-02 Activity Fee ~ 100;.40 30-JUl-02 Student Union i=ae 20.00 30-JUL-02 Technology Fee ~ 5 0.00 ~ CURRENT BILLED tiALAitiCi= ~ . 13304.00 -- AUTN1_IRIZED FlidAiNCiAL AIt3 -- 200230 W i t ices Achievement 5ci~ol arsh i p 3~ 000.00 ~ FINANCIAL AIO 3ALANG'E * ~ 31000.00 ---- McMU ITEMS ---- 2{]0230 30-JUL-t?2 Unsub Stafford loanPA/Federal 1313.00 ~~~~~ MEP~lLI BAL.A,f~CE ~~~~~ 1313.00 NOTE: Non-cashlcredits.are estimated based. on current term +charges PAST DUE: -300.00------ TOTAL OUEz 10'304.00 -------~~~~~*i=ALL': 2002 {3AlANCES Af~E . OUE AUGUST 12~ 2ff02.~~~~~~ (Except +For students ~~hohave approved financial arrangements or employers deferment an file) ~ ~ ~ CCiNTINlIEfl ~ ~ '~ _ +' 3 efollett: Urder History l '" Page 1 of 2 This site is a part of t{~e ~~ TEXTBOOKS MEDICAL SOFTWARE CAMPUS FACULTY COMMUNITY ' ~~ ~ ~ ~ ~ ~1. C'{J Cll 80oiKS SHOP SHOP b°°~~t~~~~t'"~-~` W'ELCOME TCD THE {~FFICIA~L ONLINE BOOKT~DRE ~t %; e~3 ~,, ~ _r,. L ~ ,'. _a,t'd!~ ~.I ~~ u,F; I r +_.',i I '_.:k ~1r;~1~J o't~': iC~i ORDER DETAIL Thanks for your order from efollett.com. If you have any more questions, please feel free to contact our customer service department. User Profile Order History You are logged in as abbywilkes@aol.com (lo out) I~ Order Number: 451023 Description RAVEN, BIOLOGY, New EBERHARD, GENERAL BIOLOGY LAB MANUAL: UPDATED VERS, New FADIMAN, EX LIBRIS (P), New DANGAREMBGA,NERVOUS CONDITIONS (P), New DOVE, THOMAS & BEULAH (P), New ROSE, GENEALOGY, New BOARD, THE BCG GENEALOGICAL STANDARDS MANUAL, New Reserve/Quote/Rental Total Shipping/Prepay Total: Discounts: Shipping Charges: Shipping Tax: Sales Tax: Order Tota{: Order shipping address: Abby L Heineman Qty Price Status Date Shipping R9ethc Shipped 1 $123.50 New Store Pickup 1 $60.50 New Store Pickup 1 $10.00 New Store Pickup 1 $14.00 New Store Pickup 1 $13.50 New Store Pickup 1 $17.95 New Store Pickup 1 $19.95 New Store Pickup $0.00 $259.40 -$0.00 $0.00 $0.00 0.00 $259.40 http://shop.efollett.com/htmlroot/tools/OrderDetail.j sp?orderAt=O 4 08/09/2002 ~i„lt~tt: t.h~~l~r L'«l~firnluliti,n ~ 4~ 1'at~c t v~ ~ # This ~,1~ ~s a earl ~~t t,~~ _ _ _ h-EQIC.4L SQfTMiARE i~Ahf.1'US ~~ ~ ~ ~ ~ ~. TEXEBOOKS FACUET'K tC?RAiMUPtITY l ! , ~ BC~GkS SHi.>i~ SH(3r' J r~t,~~'i.,.~,~:i`-V`-.~~.~ WEL~~ME T~ THE OFFICIAL ONLINE B(?Q~I~STaRE Please make certain your order is correct- If everything is correct, please scroll to the bott< page and click "submit" to process your order, You are Ingged In as abbywllkes r~aoLcom (logout) HILL, GENkkA1 CHEMIS [ ttY WI SUt U HUNS M.aNUA~ New Reserve/Quote/Rental Total: Shipping/Prepay Total: Product Total- Sales Tax: C)rcier 7~otal: Credit Card Charged: Card Number (Last Four Dlglts) Expiration Date (MM/YYYY): Billing Address Abby L Heineman 29 Enck Drive Boiling Springs, PA 17007 usa ~~` _<<. u-~ i ~' ::j it w. ..;~ ~~ ?,_r4;` ,,,,,,s ] $14y ~~ Prepay ~~1 i)::: $1~9.OCf Do you have special requirements or needs we'll need to know about to fulfill your order? If so, then please enter them here... 1~5p c:naracter rr~axtri,un,) Submit htths~_/%shop-etiillrtt.cunrihin~lr~wtfltwls:'Or~icxC'uutinu~tiun,jsp ly CuitionPayT~ Financial Solutions For Automated Information: www.TuitionPay.corn or (R8$) AMS-PLAN (267-7526) The TuitionPay Monthly Plan '-- Wilkes Universifiy Billing Information: Sh>tdcnt [nformation: Mrs. Debra A. Brinley Abbyl-Ieincman 29 Enck Dr Graduationl'ear:2.0U8 Boiling Springs , PA 17 0 0 7 Academic Year: 2002-2003 School NICE #:003394 :'This sT2jtefnent.cavers>tr~nsl~ctions tlirbU3h: ' 117/27/2002 909143891 000947 P ;Payment Due pate 118/15/20112 Amouni Due $18118.91) Account Ntmk)er 9U 14299119 1 t]ate'of Last Payment Amount of Last Payment Life Insurance Unemployment l:nsurance 07/27/2002 $3t-72.0U IN F(11iC>r: NOT APPLICAI3I,}: ''Total'F1an ,~lrrouht 'Total Arnountf?~ald to pate Present Balance if payment:received after'due date, la#e fee is;. $18013.00 $3622.00 $14481.110 $.IIU **MESSAGES** 08/15/2002 Education Expenses Livoice Detail $18118.90 itioni'ay~° The TuitionPay Monthly Plan Wilkes tJnivcrsity Payment que'pate` (18/15/20112 Ampunt Due X1808.)0 Account Number 91114299119 1 w 07/3712002 000)47 F 909143 891 07/27/2(>n3 •Pleasa detach and return with your check •Pleasa make all shacks payabla to Pled National Bank •Pleasa include your account number on your chick • Please do not staple or paper clip check to this stuU Billing Information: Student Information: Mrs. Debra A. Brinley Abby Heineman 29 Enck Dr Graduation Year: 3008 Boiling Springs, I'A 17007 Academic Ye~u-: 3002 X003 Phone #: 717 ?49-4793 P{ease indicate any change of address /expected ~~~~~~~~~~~~~~~~~~~~~~i~~~~~~~~~(~~~~~~~'~~~~~~~~~~~ year of graduation / or phone number below, FLEET NATIONAL SANK , P.O. BOX 9028 BOSTON,MA 02205-9028 PETITIONER'S EXHIBIT ~~\ One AMS Piace . ~'~"~' P.O. Box 100 u~ttonPay~M frnanclar$arutrone Swansea, MA 02777 Mrs. Debra A. Brinley 9(1129909 07/27J2(?02 llate Amount Payment Schedule 08115/2002 $1808.90 09/15/201)2 $18L0.30 1 0/1 51201)2 $1810.30 1 I / 15/2002 $1810.30 12115/2002 $1810.30 01/15/2003 $18L0.30 02/15/2003 $]810.30 03/15/2W3 $1810.30 Messages +. ' t EXTRA COPY RE: 2001 Tax Returns PREPARED FOR: CARL HETNEMAN SSN: 208-42-3809 PRINTED ON: April 11, 2002 PREPARED USING: TaxCut EXTRA COPY OF TAX FORMS FOR YOUR RECORDS TAX FORMS IN YOUR RETURN 1. Form 1040 - US Individual Income Tax 2. Schedule A - Itemized Deductions **************** DO NOT MAIL THIS PAGE **************** • , ,. ~o n m 3 Q m m t! z C z C u u m C i i , A w .>«P ~ N a ~ ~ c N m o yy ~ ~ .D a^ O 3 m CA 0 ~ ~ ~ N rrl N ~ 3 - - V Om 03 V m N Q p 3 C ~ m W 3 j ~ o ^ m m m ~ m m tn~ ~ 2 ~ '~ ~ to 07 7C `mG ~ O O f ro m ~ ~ o T mz a ~ m ~ (D N (Q m m ~ 7 3 m N m m ~ rri (D m O z 'O X ~ m m W O i7 ~ c 3 ;Nm a m m D~to v oo D6~ "- m ~~ m O)-p z m a v~ N m ~ d v cD Gr m 3 ~ ~" m ~ ~ O~ m ~ O n m IOn m m W .fD. a n W a O m ~' N m ~ H o H ~ ~ m N W r ' m N ~ m e^ ~ Op N c0. rp A n y ~ ~ m H ~um, i m .o c. o S m o m ma m Nm V F N n ~l ~ Ny J , o ' r [n ~ 3 ~ c m p m ro O m O ~~ O~ W o O ~ m m ~ a m O N j O F m O~ p m F ~ v O O n O rp o y 0 ~' m ' , N ~ N V m m ',O '^ O ^ ~ m p Od ~ 10 O x rn ;O O m O n Ot A N .aa ..,,,~ 10 ~ N T ~ D a ^ m ,V ~ _N S rn m. < _ n N m d m ~ _ m av ~ ~ ~ ~ . ,y ~. j } r ~ ~ ~ x Af ~ ~ ' Jm o~i ~ ;N _ ° m O O? j ai j x O Ox ~ m 3 m N O ^ ~ m o ~c 3 m O a F. 0 ~ O F. t 7 ' O Q X N m ~ m G ~ a ~ ~~ D W N ~ ~ i p o a m m n ~ .'~ ' - ~N b O ~ 7'I 3 ~ K C 3 "~ 3m C O a t ~ o N a~ o m ~' ~ o N ~ c ~ m c° 41 . m 7 n ~ Q. 3 m c N m K ~ a m p v~ rM m m d ~ m ~ p' x O G ~ ~ d. ~ ~ o m m ~ o `O- ~ ro m ': ~ 0 ~ O 1 EMPLOYEE W-2 WAGE SUMMARY 2001 The chart be I ow indicates your 2001 voluntary payroll adjustments which are 0028-8496 000100 included (+), excluded (-), or did not affect IN/A) your federal wages (Box 1) and state wages. YOUNG MENS CHRISTIAN ASSOC 311 S. WEST STREET VOLUNTARY ADJUSTMENTS YTD AMOUNT FEDERAL WAGES PA WAGES CARLISLE PA 17013 RETIREMENT 853.90 N/A N/A OPT 10.00 N/A N/A UNITDWAY 104.16 N/A N/A FEDERAL WITHHOLDING EXEMPTIONS M 0 CAPTLCMPGN 125.04 N/A N/A PA WITHHOLDING EXEMPTIONS M 0 REGULAR WAGES FOR 2001 17256.18 LEISA R HEINEMAN 201 WALNUT ST CARLISLE PA 17013 Form W-2 Wage and Tax Statement 2001 Copy C, for employees records 01364 PAYROLLS BY ~~~~}~~ a Control number Vaid c Employer's name, address, and ZIP code Department of the Treasury -Internal Revenue Service 0028-8996 000525-000100 YOUNG MENS CHRISTIAN ASSOC DMB No. 1545-0008 b employer: iaenurmaepp ~ ether U d empmree•s a .m : urger n meer 311 S . WEST STREET 23-1386198 188-54-5617 CARLISLE PA 17013 I Wages, tips, other compensation 1725 2 Federal income [ax withhel 7 4 13 Statutory Retirement Thirtl-party 6.18 . 184 employee phn aicR p,v 3 Social security wages 4 Social security [ax withhel X 17256.18 1069.E 12 See lnstrs. for Box 12 14 Other a Employee's name, address, and ZIP code 5 Medicare wages and tips 6 Medicare [ax withhel LEISA R HEINEMAN 17256.18 250.: 201 WALNUT ST 7 Social security tips 8 Allocated tips CARLISLE PA 17013 9 Advance EIC payment 10 Dependent care benefits 11 Nonquali led plans 15 Stale Employer's state I.D. No. 16 State wages, tips, etc. 17 State income [ax 18 Local wages, tips, etc. 19 Local income tax 20 Locality name PA 11634276 17256.18 483.20 17256.18 172.57 PA CARL This intormalion is being furnished to the Internal Aerenue Service ri ~ O~O Label ( L A (See 13 instructions.) E L Use thelRS label. H Otherwise, R please print ~ E or type. Presidential Election Campaic (See instructions.) Filing Status Check only one box. Department of the Treasury-Internal Revenue Service ^ O 0 U.S. Individual Income Tax Return L (99) For the year Jan. 1-Dec. 31, 2001, or other tax year beginning , 2001, ending Your first name and initial Last name CARL W HEINEMAN If a joint return, spouse's first name and initial Last name LEISA R HEINEMAN Home address (number and street). If you have a P.O. box, see instructions. 201 WALNUT STREET City, town or post office, state, and ZIP code. If you have a foreign address, see instructions. CARLISLE PA 17013 1 2 3 4 5 IRS Use Only--Do not write or staple in this space 20 OMB No. 1545-0074 Your social security number 208-42-3809 Spouse's social security number 188-54-5617 Apt. no. . Important! ~ You must enter your SSN(s) above. You Spouse Note. Checking "Yes" will not change your tax or reduce your refund. Do you, or your spouse if filing a joint return, want $3 to go to this fund? ... ... .. .. .. - ^ Yes X^ No ^ Yes ~ NO Single Married filing joint return (even if only one had income) Mottled filing Separate return. Enter spouse's SSN above & full name here - Head of household (with qualifying person). (See instructions.) If qualifying person is a child but not your dependent, enter this child's name here.- Qualifying widow(er) with dependent child (year spouse died - ). (See instructions.) Exemptions If more than six dependents, see instructions 6a ~X Yourself. If your parent (or someone else) can claim you as a dependent on his or her tax No. of boxes return do not check box 6a ~ checked on b ^X Spouse , 6a and 66 . - No. of your C Dependents: (2) Dependent's 13) Dependent's (4) X if qualifying children on 6c (1) First name Last name social security number relation ship to crelditf(see instaX o wh°: JAMES SHIRLEY 170-64-7528 SON CHRISTINE HEINEMAN 209-72-7456 DAUGHTER X: • lived with you 2 2 • did not live with you due to divorce or separation (see instructions) Dependents on 6c not entered above Add numbers entered on d Total number of exemptions claimed lanes above - Income 7 Wages, salaries, tips, etC. Attach Form(s) W-2 . . . . . . . . . . . . . . . I 7 8a Taxable interest. Attach Schedule B if required 8. Attach bTax-exempt interest. Do not include on line Sa ~ 8b I 0 ~ Forms W-2 and W-2G here. 9 Ordinary dividends. Attach Schedule B if required 9 Also attach 10 Taxable refunds, credits, or offsets of state and local income taxes (see instructions) 10 Form(s) 1099-R 11 Alimony received 11 if tax was 12 Business income or (loss). Attach Schedule C or C-EZ 12 withheld. 13 Capital gain or (loss). Attach Schedule D if required. If not required, check here - ~ 13 14 Other gains or (losses). Attach Form 4797 14 If you did not 15a Total IRA distributions .......... 15a b Taxable amount (see inst.) 15 get a W-2, 16a Total pensions & annuities ........ 16a 0 b Taxable amount (see inst.) 16 see instructions. 17 Rental real estate, royalties, partnerships, S corporations, trusts, etc. Attach Schedule E 17 Enclose, but do 18 Farm income or (loss). Attach Schedule F 1g not attach, any 19 Unemployment compensation . 19 payment. Also, please use 20a Social security benefits 120a I b Taxable amount (see inst.) 201 Form 1040-V. 21 Other income. List type and amount (see instructions) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 21 22 Add the amounts In the far right column for Imes 7 through 21. This Is vourtotal income - 22 946 0 0 0 22 0 0 58, 968 23 IRA deduction (see instructions) 23 01 AdJUSted 24 Student loan interest deduction (see instructions) . . . . . . . . . 24 GrOSS 25 Archer MSA deduction. Attach Form 8853 . . . . . . . . . . . . . 25 0! Income 26 Moving expenses. Attach Form 3903 . . . . . . . . . . . . . . 26 of 27 One-half of self-employment tax. Attach Schedule SE 27 0 28 Self-employed health insurance deduction (see instructions) 28 0' 29 Self-employed SEP, SIMPLE, and qualified plans 29 0 30 Penalty on early withdrawal of savings 30 Oi 31a Alimony paid b Recipient's SSN - 31a _j 32 Add lines 23 through 31a 32 0 33 Subtract line 32 from line 22. This is your adjusted gross income - 33 58, 968 KIA For Disclosure, Privacy Act, and Paperwork Reduction Act Notice, see instructions. Form 1040 (2001) F.onis1040(2001) CARL W HEINEMAN 208-42-3809 Paget Tax and 34 Amount from line 33 (adjusted gross income) . . . . . . . . . . . . . . . . . . . . . . . . . . 34 58, 968 Credits 35a Check if: ~ You were 65 or older, ~ Blind; ~ Spouse was 65 or older, ~ Blind. 0 Add the number of boxes checked above and enter the total here - 35a Standard b If you are married filing separately and your spouse itemizes deductions, or Deduction for- you were adual-status alien, see instructions and check here - 35b • People who 36 Itemized deductions (from Schedule A) or your standard deduction (see left margin) 36 12, 304 checked any ~ ~ ~ 37 4 6 , 6 6 4 box on line 37 Subtract line 36 from line 34 . . 35a or 35b or 38 If line 34 is $99,725 or less, multiply $2,900 by the total number of exemptions claimed on who can be line 6d. If line 34 is over $99,725, see the worksheet in the instructions _ 38 11, 600 claimed as a ~~~ 3 5, 0 6 4 depedent, 39 Taxable income. Subtract line 38 from line 37. If line 38 is more than line 37, enter -0- 39 see instrucs. 40 5 , 2 61 • All Others: 40 Tax (See instructions). Check if any tax is from a ~ Form(s) 8814 b ~ Form 4972 0 Single, 41 Alternative minimum tax (see instructions). Attach Form 6251 41 $4,550 42 Add lines 40 and 4i - 42 5, 261 household, 43 Foreign tax credit. Attach Form 1116 if required 43 0 $6,650 44 Credit for child and dependent care expenses. Attach Form 2441 44 Married filing 45 Credit for the elderly or the disabled. Attach Schedule R 45 jointly or 46 Qualifying 46 Education credits. Attach Form 8863 widow(er), 47 Rate reduction credit. See the worksheet in the instructions 47 $7,600 ~ ~ 48 6 0 0 Married 48 Child tax credit (see instructions) filing 49 Adoption credit. Attach Form 8839. 49 separately, 50 Other credits from: a ~ Form 3800 b ~ Form 8396 $3,800 50 ~ ~ c ~ Form 8801 d ~ Form (specify) 51 Add lines 43 through 50. These are yourtotal credits 51 600 52 Subtract line 51 from line 42. If line 51 is more than line 42, enter -0- - 52 9 , 6 61 53 Self-employment tax. Attach Schedule SE 53 Other 54 Social security and Medicare tax on tip income not reported to employer. Attach Form 4137. . . . 54 Taxes 55 Tax on qualified plans, including IRAs,and other tax-favored accounts. Attach Form 5329 if required 55 56 Advance earned income credit payments from Form(s) W-2 56 0 57 Household employment taxes. Attach Schedule H .- 57 0 58 Add lines 52 through 57. This is yourtotal tax 58 4 , 6 61 Payments 59 Federal income tax withheld from Forms W-2 and 1099. . . . . . . . . . 59 4 , ' 60 2001 estimated tax payments and amount applied from 2000 return 60 If you have a 61a Earned income credit (EIC) 61a -~ qualifying L61 b I child, attach b Nontaxable earned income Schedule EIC. 62 Excess social security and RRTA tax withheld (see instructions) 62 0 63 Additional child tax credit. Attach Form 8812 63 64 Amount paid with request for extension to file (see instructions) 64 65 Other payments. Check if from a ^ Form 2439 b ^ Form 4136 65 66 Add lines 59, 60, 61 a, and 62 through 65. These are yourtotal payments - gg 4, 812 Refund Direct deposit? See instructions and fill in 68b, 68c, and 68d Amount You Owe 67 If line 66 is more than line 58, subtract line 58 from line 66.This is the amount you overpaid . 68a Amount of line 67 you want refunded to you - - b Routing number - c Type: ~ Checking ~ Savings - d Account number 69 Amount of line 67 you want applied to your 2002 estimated tax - I 69 I 0 70 Amount you owe. Subtract line 66 from line 58. For details on how to pay, see the instructions - 71 Estimated tax penalty. Also include on line 70 I 71 1 70 Third Party Do you want to allow another person to discuss this return with the IRS (see instructions)?^ Yes. Complete the following ^ No Designee Designee's Phone Personal indentification ~~ name - no. - number (PIN) - Sign Under penalties of perjury, I declare that I have examined this return and accompanying schedules and statements, and to the best of my knowledge and belief, they are true, correct, and complete. Declaration of preparer (other than taxpayer) is based on all information of which preparer has any knowledge. Here Joint return? Your signature Date Your occupation Daytime phone number See instructions. HEARING AIDES _ Keep a copy Spouse's signature. If a joint return, both must sign. Date Spouse's occupation for your records. SECRETARIAL Paid P Preparer's signature ' ' Date Check if self-employed ^ Preparer's SSN or PTIN reparer U l O s Firm's nam e (or SELF-PREPA RED EIN n y se yours if sel address, a , f-em toyed), nd ZIP code Phon e no. KIA Form 1040 (tool) 'SCHEDULES A&B Schedule A-Itemized Deductions OMB No. 1545-0074 (Form 1040) (Schedule B is on page 2) 2001 Department of the Treasury Internal Revenue Service (s9) - Attach to Form 1040. - See Instructions for Schedules A and B (Form 1040). Attachment Sequence No. 07 Name(s) shown on Form 1040 your social security number CARL W HEINEMAN 208-42-3809 Medical Caution: Do not include expenses reimbursed or paid by others. and 1 Medical and dental expenses (see instructions) 1 0 Dental 2 Enter amount from Form 1040, line 34 2 58, 968 Expenses 3 Multiply line 2 above by 7.5% (.075) 3 4, 9 2 3 4 Subtract line 3 from line 1. If line 3 is more than line 1, enter -0- 4 0 Taxes You 5 State and local income taxes 5 ?, 602 Paid 6 Real estate taxes (see instructions) 6 0 7 Personal property taxes 7 (See instructions.) 8 Other taxes. List type and amount - --------------- ---------------------------------- 8 0 9 Add lines 5 through 8 9 3, 602 Interest 10 Home mortgage interest and points reported to you You Paid on Form 1098 10 8, 213 (See 11 Home mortgage interest not reported to you on Form 1098. If paid instructions.) to the person from whom you bought the home, see instructions and show that person's name, identifying no., and address - Note: ------------------------------------ Personal ------------------------------------ interestis ------------------------------------ 11 0 not 12 Points not reported to you on Form 1098. See instructions deductible. for special rules 12 0 13 Investment interest. Attach Form 4952 if required. (See instructions.) 13 14 Add lines 10 through 13 14 8, 213 Gifts to 15 Gifts by cash or check. If you made any gift of $250 or Charity more, see instructions . . . . . . . . . 15 4 8 9 If you made a 16 Other than by cash or check. If any gift of $250 or more, gift and got a see instructions. You must attach Form 8283 if over $500 16 0 benefit for it, 17 Carryover from prior year 17 0 see instructions. 18 Add lines 15 through 17 18 4 8 9 Casualty and Theft Losses 19 Casualty or theft loss(es). Attach Form 4684. (See instructions.) 19 0 Job Expenses 20 Unreimbursed employee expenses-job travel, union and Most dues, job education, etc. You must attach Form 2106 Other Miscellaneous or 2106-EZ if required. (See instructions.) - ----------- ' Deductions ----------------------------------- ----------------------------------- 20 0 (See 21 ______________ Tax preparation fees 21 instructions for expenses to 22 Other expenses-investment, safe deposit box, etc. List deduct here.) t e and amount - YP _______________________ 22 0 23 Add lines 20 through 22 23 0 24 Enter amount from Form 1040, line 34 24 58, 968 25 Multiply line 24 above by 2% (.02) 25 1, 179 26 Subtract line 25 from line 23. If line 25 is more than line 23, enter -0- 26 0 Other 27 Other-from list in the instructions. List type and amount - ~scellaneous Deductions ----------------------------------- ------- -~--- ----------------------------------- ------- ---- 27 0 Total 28 Is Form 1040, line 34, over $132,950 (over $66,475 if married filing separately)? Itemized Deductions ~ No. Your deduction is not limited. Add the amounts in the far right column for lines 4 through 27. Also, enter this amount on Form 1040, line 36. ..- 28 12, 304 Yes. Your deduction may be limited. See instructions for the amount to enter. KIA For Paperwork Reduction Act Notice, see Form 1040 instructions. Schedule A (Form 1040) 2001 EY,TRA COPY RE:2001 Tax Returns PREPARED FOR: CARL HEINEMAN SSN: 208-42-3809 PRINTED ON: April 11, 2002 PREPARED USING: TaxCut Pennsylvania EXTRA COPY OF TAX FORMS FOR YOUR RECORDS TAX FORMS IN YOUR RETURN 1. Form PA40 - PA Tax Return - Individual Income Tax Return 2. Wage Statement Summary - Wage Statement Summary 3. Schedule W-2 Worksheet - Wage Statement Worksheet **************** DO NOT MAIL THIS PAGE **************** PLEASE DO NOT USE YOUR 010D115146 LABEL PA-4o R 2001 PAGE 1 OF 2 208-42-38D9 HE 188- 54-5617 EX 0 RS R HEINEf1AN CARL W A D FS J HEINEMAN LEISA R FY 0 XX 201 WALNUT STREET SC 21110 CARLISLE PA 17013 PN 717-258-5789 1A 58946.00 LB 0.00 1C 58946.00 2 0.OD 3 0•DO 4 0.00 5 0.00 6 0.00 7 0.00 8 0.00 9 58946.00 10 0.00 11 58946.00 12 1650.OD PLEASE FOLD PAGE ALONG THIS LINE Local Information. Enter where you lived as of 12/31/2001 Extension, (Mark This Space) School District: Car 1 1 5 1 e Area Amended Return, (Mark This Space) School Code: 21110 Fiscal Year Filer, (Mark This Space) county: CUMBERLAND Type Filer. (Fill-in only one circle) Municipality: CARLISLE S Single Residency Statu s. (Mark the Correct Space) J X Married, Filing Jointly R X Resident M Married, Filing Separately NR Nonresident F Final Return, Indicate Reason: p Part Year Resident D Deceased From: Date of Death: To: 1 a Gross Compensation. See the instructions ..................................................................................................... ...... 1 a 5 8 9 4 6. 0 0 1 b Unreimbursed Employee Business Expenses. See the instructions ............................................................... ...... 1 b 0 ' 0 D i s p ........................................................................................ Net Com ensation. Subtract Line 1 b from Line 1 a. ...... 1 c 5 8 9 4 6. 0 0 2 ......................... Interest Income. Complete and submit PA Schedule A if over $2,500 . .................................. ...... 2 0 • 0 D 3 p ..................................................... Dividend Income. Com lete and submit PA Schedule B if over $2,500. 3 ...... D • 00 4 Net Income or Lass from the Operation of Business, Profession, or Farm . .................................................... ...... 4 0 ' D 0 5 9 P P Y . .......................................................... Net Gain or Loss from the Sale, Exchan e, or Dis osition of Pro ert 5 ...... 0 ' 0 0 6 Net Income or Loss from Rents, Royalties, Patents, or Copyrights ................................................................. ....... 6 D • 00 7 p ................................................................... Estate or Trust Income. Com lete and enclose PA Schedule J. 7 ....... D ' 0 0 8 Gambling and Lottery Winnings . ................................................................................................................... ....... 8 9 Total PA Taxable Income. Add only the positive income amounts from Lines 1c, 2, 3, 4, 5, 6, 7, and 8. ................................. DO NOT ADD any losses reported on Lines 4, 5, or 6 . .................................. ........... ....... 9 5 8 9 4 6.0 0 10 Contributions To Your Medical Savings Account. See the instructions . .................................................. ....... 10 D • 0 D 11 Adjusted PA Taxable Income. Subtract Line 10 from Line 9 . ...................................................................... ....... 11 5 8 9 4 6.0 0 12 PA Tax Liability. Multiply Line 11 by 2.8% (0.028). Also enter on Line 13, Page 2 . .................................. ....... 12 1650.00 EC FC 0100115146 ~ ~ ~ ^ ^ ^ ^ ~ ~ ~ 01,00115146 J 0100215144 200,E PA-40 PAGE 2 OF 2 HEINEMAN CARL W 208-42-3809 13 1650.00 14 1651.00 15 0.OD 16 0.00 17 0.00 18 0•DO 19 D•00 20A 00 20b 00 21 D•00 22 0.00 23 0.00 24 0.00 25 0.00 26 0.OD 27 1651.00 28 0.00 29 1.DD 30 1.00 31 D•00 32 0.00 33 0.00 34 0.00 35 0.00 36 0.00 13 Total PA Tax Liability. Enter your PA Tax Liability from Line 12 on Page 1 ........................................... 13 16 5 D • D 0 14 Total PA Tax Withheld. See the instructions ................................................ 14 1651 • DD 15 Credit from your 2000 PA Income Tax Return ............................................... 15 16 2001 Estimated Installment Payments .................................................... 16 D • D D 17 2001 Extension Payment ............................................................... 17 18 Nonresident Tax Withheld on your PA Schedule(s) NRK-1. (Nonresidents only) .................... 18 19 Total Estimated Payments and Credits. Add Lines 15, 16, 17, and 18 . ......................... 19 D • D 0 Tax Back/Tax Forgiveness Credit. Complete lines 20a, 20b, 21, and 22. Read instructions. 20a Filing status: UnMarried or Separated Married Deceased ............. 20a 20b Dependents, Part B, Line 2 PA Schedule SP ............................................... 20b 21 Total Eligibility Income, Part C, Line 11, PA Schedule SP ...................................... 21 22 Tax Back/Tax Forgiveness Credit from Part D, Line 16, PA Schedule SP .......................... 22 23 Total Credit for Taxes Paid to Other States or Countries. Submit your PA Schedule G or RK-1......... 23 D • D D 24 PA Employment Incentive Payments Credit. Submit your PA Schedule W, RK-1 or NRK-1............ 24 25 PA Jobs Creation Tax Credit. Submit your certification or PA Schedule RK-1 or NRK-1 ............... 25 26 PA Research and Development Tax Credit. Submit your certification or PA Schedule RK-1 or NRK-1.... 26 27 TOTAL PAYMENTS and CREDITS. Add lines 14 and 19 and 22 through 26 ....................... 27 16 51 • D 0 28 TAX DUE. If Line 13 is more than Line 27, enter the difference here . ............................ 28 D • D D 29 OVERPAYMENT. If Line 27 is more than Line 13, enter the difference here ....................... 29 1 • D D The total of Lines 30 through 36 must equal Line 29. 30 Refund -Amount of Line 29 you want as a check mailed to you ......................... Refund 30 1 ' D D 31 Credit -Amount of Line 29 you want as a credit to your 2002 estimated tax account ................. 31 D • D D 32 Donation -Amount of Line 29 you want to donate to the Wild Resource Conservation Fund. ....... 32 D • D D 33 Donation -Amount of Line 29 you want to donate to the United States Olympic Committee. ........ 33 D • D D 34 Donation -Amount of Line 29 you want to donate to the Governor Robert P. Casey Memorial Organ Donor and Tissue Awareness Trust Fund .......................................... 34 D • D D 35 Donation -Amount of Line 29 you want to donate to the KoreaNietnam Memorial, Inc . ............ 35 D • D D 36 Donation -Amount of Line 29 you want to donate to Breast and Cervical Cancer Research Fund. ... 3g D • D D Under penalties of perjury, I (we) declare that I (we) have examined this return, including all accompanying schedules and statements, and to the best of m (our) belief they are true, correct, and complete. Your Signature: Date: Your Occupation. HEARING AIDES Spouse's Signature, ii filing jointly: Date: Spouse's Occupation: SECRETARIAL Pre arer or Com an Name other than tax a er s based on all information of which the re arer has an knowled e. Preparer or Company Name (Please Print): Dale: Telephone Number: Signature (Optional): 0100215144 0100215144 0101915148 WAGE STATEMENT SUMMARY(os-oi> 2001 Name as shown first on the PA tax return: Social Security Number: HEINEMAN, CARL W 208-42-3809 HEINEMAN, LEISA R 188-54-5617 Instructions. Do not submit your Form(s) W-2 if using this schedule. Enter the required information from each Form W-2, and keep your original forms. Important. Your PA and federal compensation may be different. Caution. Do not use this schedule: (1) If your Form(s) W-2 shows that you earned income in another state -you must submit your actual Form(s) W-2 or (2) If you believe an amount on your Forrn(s) W-2 is incorrect -you must submit the actual Form(s) W-2 with a written explanation from your employer. If you have compensation from forms other than Forms W-2, complete PA SCHEDULE MC below. Number of Form(s) W-2 ' If you need more space, you may copy this schedule or prepare your own schedule in this format. Married Taxpayers Filing Jointly: Indicate whether the Form(s) W-2 are for the primary taxpayer listed first on the PA-40 (T) or spouse (S) T/S (a) EIN from box b (b) Federal wages from box 1 (c) PA compensation from box 16 (d) PA tax withheld from box 17 T TP - Wages See Wks. 58,946 1,651 Total. Add the amounts in column (c) and (d). $ 58, 94 6 $ 1, 651 Caution. The Department reserves the right to request your actual W-2 and 1099 forms. 0101915148 0101915148 J SCHEDULE W-~2 Wkst. Name(s) as shown on HEINEMAN, C_ARLW- i-3EINEMAN,' LEISA R WAGE STATEMENT WORKSHEET PA tax return SSN zt~a-~z-~s~? 188-54-56,, (a) (b) (c) (d) (e) T/S Employer's Name EIN from box B Fed. wages from box 1 PA taxable comp. box 16 PA tax withheld box 17 1 T FIRST PkESSYTEB.IAN 23-1429895 14;C90 14,G90 395 2 T BROWN OPTICAh 23-.2106861 27,600 27,600 %"73 3 T YMCA 23-1386198 17,256 17,256 483 4 5 6 7 ~ 8 9 ~ ~ ~ -- 10 ~ ~ j 11 12 --- , ~ - 13 14 -- - -- 15 16 -- - ---_ ~ 17 - 18 Schedule W-2 Worksheet Summary: 1. 2. Taxpayer Subtotal :................. Spouse Subtotal :.................. ............ ............. ........... .......... ' 58,946 G 1,'651 0 ' ~ 0101,91,5],48 WAGE STATEMENT SUMMARY 2001 PA Schedule W-2S (09-01) Name as shown first on the PA tax return: Social Security Number: HEINEMAN, CARL W 208-42-3809 HEINEMAN, LEISA R 188-54-5617 Instructions. Do not submit your Form(s) W-2 if using this schedule. Enter the required information from each Form W-2, and keep your original forms. Important. Your PA and federal compensation may be different. Caution. Do not use this schedule. (1) If your Form(s) W-2 shows that you earned income in another state -you must submit your actual Form(s) W-2 or (2) If you believe an amount on your Form(s) W-2 is incorrect -you must submit the actual Form(s) W-2 with a written explanation from your employer. If you have compensation from forms other than Forms W-2, complete PA SCHEDULE MC below. Number of Form(s) W-2 3 If you need more space, you may copy this schedule or prepare your own schedule in this format. Married Taxpayers Filing Jointly: Indicate whether the Form(s) W-2 are for the primary taxpayer listed first on the PA-40 (T) or spouse (S) T/S a EIN from box b b Federal wages from box 1 c PA compensation from box 16 (d) PA tax withheld from box 17 T TP - Wages See Wks. 58,996 1,651 Total. Add the amounts in column (c) and (d}. $ 5 8 , 9 4 6 $ 1, 6 51 Caution. The Department reserves the right to request your actual W-2 and 1099 forms. D1,D1,915148 D1D1915148 scHEOU~Einr-zwkst. WAGE STATEMENT WORKSHEET NamL(s)'as sown on your PA tax return SSN ~HEIPIEMAN, CARL W HEII~~~lAN, LnISA R 2U8-4~-3r>.~ic 188-5?-5b1~ (a) (b) lc) (d) (e) T/S Employer's Name EIN Fed. wages PA taxable PA tax from box B from box 1 comp. withheld box 16 box 17 1 T FIRST. PRESBYTERIAN ~ 23-1429845 ~14 ~~0 ~ i 14'090 i 3^~ 2 T BRflGIN OPTICAL X23-2106L~61 __ 2i~a~0 2% 0 _--i,'3 3 T YMCA ~23-1386198 1i,256 1i 17,25 6 483 4 5 6 j ~ { - - - i - 8 ~ ~ ~~ 9 - - ~i -- 10 - 11 12 - --- ~ --- -_ -- - i - 13 14 ~ - 15 - - 16 17 ~ - - 18 ~ - J --- --- i - - Schedule W-2 Worksheet Summary: 1. Taxpayer Subtotal :................. ............ ........... ~ 58,946 1,651 2. Spouse Subtotal :.................. ............. .......... ,~ o RETURN BY APRIL 15, 2002 TO: Crj oo ~ TAX OFFICE USE ONLY - DO NOT WRITE IN THIS AREA. CAPITAL TAX COLLECTION BUREAU (~ See Page 2 of Instruction Sheets LOCAL EARNED INCOME in this packet for mailing address labels or TAX RETURN (FORM 531) see back of return for addresses, phone numbers, and office hours. ~ CONSTITUTE PROOF OF FILING, THE TAXPAYER'S COPY MUST E VALIDATED BY THE BUREAU. TO HAVE YOUR COPY VALIDATED Y MAIL, RETURN BOTH THE BUREAU'S AND TAXPAYER'S COPIES LONG WITH A SELF ADDRESSED STAMPED ENVELOPE. W VII VII . C a p t a X. C O I'il - ~ ~ fr.r4f, ~ d A ~ @ 8 ~, ~~ §~ ~ G 6 ! ' Q ~ ~~y.. ~ ~ 'y::_ I W-2 EARNINGS (From attached W-2's) ..................................................... 1 i ~"") ~..`~. b l Uc: EMPLOYEE BUSINESS EXPENSES (Attach Federal Form 2106 & State Schedule UE) .............. 2 I I 3 TAXABLE W-2 EARNINGS (Subtract Line 2 from Line 1) ....................................... 3 ~ I \'1 ~c b I 1 OTHER TAXABLE EARNED INCOME (NO INTEREST OR DIVIDENDS) Complete Section A on Back ... 4 I I ~\ b ~ I - I i TOTAL TAXABLE EARNED INCOME (Add Lines 3 and 4) ...................................... 5 I \1 a.S I/ I G(.' I I i NET LOSS FROM BUSINESS, PROFESSION, OR FARM (Attach Federal and/or State Schedules C, F and/or K-t(1o65)) .. 6 I i ~ SUBTOTAL (Subtract Line 6 from Line 5) IF LESS THAN ZERO, ENTER ZERO ..................... 7 I 41 ~~~ b j UC I I 3 NET PROFIT FROM BUSINESS, PROFESSION, OR FARM (Attach Federal and/or State SchedulesC,FandlorK-1(1065)) 8 I I ) TOTAL TAXABLE EARNED INCOME AND NET PROFITS Add Lines 7 and 8 ..................... 9 I ~~-\ I I ~"'t, 1, .~IUU ENTER TAXABLE RATE - .o~ FDR DauPHIN, PAxrANG, AND PENBROOK BOROUGHS, LOWER PAXTON, INIDDLE PAXTON, 10 O SW1i r p:FiA- (fR WEST IiANiit(ER TOWNSHIPS (C[NTRAL DAUPHEN SCHOOL DISTRICT) -ALL OTHERS O7 I I , . ....................... . I TAX LIABILITY: Multiply Line 9 by Line 10 ................................................... 11 ~ I \ I ~ ~ ~ TOTAL LOCAL INCOME TAXES WITHHELD EXCEPT PHILADELPHIA INCOME TAX (From attached W-2's, Box 19) ..... 12 \ I ~ \ ~ ~I ~ ~ QUARTERLY PAYMENTS AND/OR LAST YEAR'S OVERPAYMENT CREDITED TO THIS YEAR ...... 13 ~ I ' I CREDITS FOR TAXES PAID TO PHILADELPHIA AND/OR STATES OTHER THAN PA (ATTACH SCH. G) AND/OR CREDITS FOR CERTIFIED I I RESIDENTS OF THE HARRISBURG KEYSTONE OPPORTUNITY ZONE (KOZ) .... 14 ~ ......................................... TOTAL WITHHOLDINGS & PAYMENTS (Add Lines 12, 13 and 14) ............................... 15 ~ I I \~~, S' TAX BALANCE DUE (Subtract Line 15 from Line 11) PAYMENT NOT NECESSARY IF LESS THAN $1.00 .. O ........ 16 I O I "` INTEREST & PENALTY (See Instructions) 17 I I I TOTAL BALANCE DUE (Add Lines 16 and 17) Make check payable to "CTCB" ...................... 18 I i ) OVERPAYMENT (Subtract Line 11 from Line 15) IF LESS THAN ZERO, ENTER ZERO ....~ ........ 19 , ~~ C> I ) OVERPAYMENT TO BE REFUNDED ......HAVE IT DIRECTLY DEPOSITED! ................. 20 I I DIRECT DEPOSIT INFORMATION I CIRCLE ONE CHECK ONE ROUTING NO. ACCOUNT NO. TAXPAYER CHECKING SAVINGS A B BOTH ~ ~ A B BOTH D ~ ,.: OVERPAYMENT TO BE CREDITED TO NEXT YEAR'S TAX ................................. 21 I I r I ' OVERPAYMENT TO BE CREDITED TO SPOUSE'S BALANCE DUE FOR THIS FILING YEAR ...... I 22 I ~ ~ - YOUR RESIDENT MUNICIPALITY DAYTIME PHONE NUMBER -- o (TOWNSHIP, BOROUGH, OR CITY) . TAX OFFICE ~ _ 1.. ", i_E:.~,.~. i°' 'r' Y, ~.k°: USE ONLY . ~Y ,< ?~^,=5+~ ~ ''.,l '~'t`: «' ~ ~ , , B ,1. : Y ,.,al, ,, YOUR SOCIAL SECURITY ~ A ,- YOUR NAME ~ NUMBER ~ a / / ~ '< ~ c`. ~7 `~ ~ * (LAST, FIRST, MI) - h! ., F" (: r f~ ~,, !F r: ~ F.: ~ t SPOUSE'S SOCIAL ~ SECURITY NUMBER . (. C3 j. ; r~ . / x: ~ / ;: t.. -p SPOUSE'S NAME " \"-/ ~ (LAST; FIRST, MI) ; ~ ~ x,r n n,. ~. t ' r. ;,. r^ .- , .~,i NE YOU MOVED FROM THE rJ" yES IF YES, COMPLETE SCHEDULE P HOME :GINNING OF THE TAX FILING PROVIDED WITH THIS RETURN. ADDRESS "° '°' ~ ~ `"' C' ?" ~ } - AR TO PRESENT? ~ NO i . M r ~ ~ :.~ ~,. `.: lv, ~, ~ t :.[ ,: ,. „ d ~.. ti ! ~ Q • i t JR SIGNATURE DATE YOUR OCCUPATION FUSE'S SIGNATURE (ONLY IF ALSO FILING ON THIS FORM) DATE SPOUSE'S OCCUPATION (ONLY IF ALSO FILING ON THIS FORM) PREPARER'S NAME (PLEASE PRINT) FIRM'S NAME (OR ENTER "S.E" IFSELF-EMPLOYED) PAID PREPARER'S PHONE NUMBER TAXPAYER'S CQPY RECIPIENT'S/LENDER'S name, address, and telephone number OMB No 1545-O9ot WELLS FARGO FINANCIAL AMERICA, Caution: The amount shown may not belullydeducfiblebyyou.Limits ~ . •.•- I N C based on the loan amount and the . 206 8TH STREET cost and value of the secured Property may apply.A/so,youmay CORRECTED - CopyB only deduct interest to the extent it i d b (IF CHECKED) For Pa er Y DES MOINES IA 50309-0000 was ncurre y you, actually paid by , you, and not reimbursed by another 717 -7 61-7 0 4 0 person. RECIPIENT'S Federal identification no. PAYER'S social security number 1 Mortgage interest received from payer(s)/borrower(s)' CALENDAR YEAR 42-1185651 208-42-3809 $ 1,479.48 2001 PAYER'SIBDRROWER'S name, street address (incl. apt. no.), city, state, and ZIP code 2 Points paid on purchase of principal residence (See Th Box 2 on back.) e information in boxes 7, z, and a is important tax information and is being furnished to the Infernal $ Revenue Service. If you are ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ i ~ ~ ~ ~ ~ ~ ~ i ~ ~ ~ ~ ~ ~ I ' I I ' I I I I I I I I' I I~ I I I I ' I III 3 Refund of ove aid interest See Box 3 on back. ~ ( ) r999encatpe'nalt return, e ne I y nr ether HEINEMAN,MR,CARL W $ auction may be imposed on you s ifthalRSdeterminesthat an nd t f t lt 2 01 WALNUT S T Q u erpaymen ax resu o s because you overstated a CARLISLE PA 17013-3869 POINTS IN BOX 4 NOT REPORTED deduction for this mortgage interest or for these points or because you tlid not Account number (optional) TO IRS. NOT TO BE INCLUDED ON report this refund of interest on your return 52560543 611 - R LINE 10. IRS PUB 936 37.43 . Form (Keep for your records.) 1098 Department of the Treasury -Internal Revenue Service ~ ~ ~ x FOLD AND REMOVE YOUR BANKING EARNINGS HOURS RATE REGULAR 81.75 8.600 TOTAL EARNINGS EMPLOYER /NFORMAT/ON HUNG STATUS TAX TYPE CARLISLE YOUNG MEN'S CHRISTIAN SOC SEC ASSOCIATION MEDICARE 311 SOUTH WEST STREET M 00 +10 FEDERAL. CARLISLE,PA 17013 M 00 PA M 00 CARL PAY PERIOD 12/11/01 TO 12/25/01 CHECK DATE 12/31/01 CHECK # 26972 TOTAL WITHHOLDINGS PERSONALJNFORMATION ADJUSTMENTS LEISA R HEINEMAN RETIREMENT 201 WALNUT ST OPT CARLISLE PA 17013 UNITDWAY CAPTLCMPGN SS# 188-54-5617 EMPL# 000525 DEPT# 000100 TOTAL ADJUSTMENTS aavROUS er PAYCHEX' 0028 8496 0010 000100 NET PAY FOLD AND REMOVE AMOUNT YTD AMOUNT 703.05 703.05 17256.18 AMOUNT YTD AMOUNT 43.59 1069.89 10.19 250.23 75.15 1844.12 19.69 483.20 7.03 172.57 155.65 3820.01 AMOUNT YTD AMOUNT 35.15 - 853.90 - 4.34 - 104.16 - 5.21 - 125.04 - 44.70- 502.70 12343.07 RECIPIENTS/LENDER'S name, address, and telephone number ' rH~ MORTGAGE SERVICE CENTER POST OFFICE BOX 8469 CANTON, OH 44711 PHONE N0.1-800-421-8059 RECIPIENT'S Federal identification no. PAYER'S social security number 34-1231961 208-42-3809 PAYER'Slf30RROWER'S name, address, and zip code 12122 CARL W HEINEMAN LEISA R HEINEMAN 201 WALNUT ST CARLISLE PA 17013-3869 Ilfllllltlllllllflllltfllllllltlltllllitllllillllllllllltlllll 12/31/01 CORRECTED (if checked) MORTGAGE OMB No 'Caution: The amount shown may not be . 1545-0901 fully deductible by you. Limits based on the ~ NTEREST roan amount and the cost and value of the secured property may apply Also, you may .'700 only deduct interest fo the extent it was (r STATEMENT incurred by you, actually paid by you, and Substitute not reimbursed by another person. Form tu98 t MolYgage interest received from payer(s)/borrower(s)' C:O E3 py g $6,734.22 For Payer 2 Poin[s paid on purchase of principal The information in boxes t, residence (See Box 2 on back.) 2, and 3 is important tax $ 00 information and is bung furnished to the Internal 3 Refund of overpaid interest Revenue Service. It you are required to File a return, a (See Box 3 on back.) negligence penalty or other $ 00 sanction may he imposed on if th IRS d t i 4 Real estate taxes paid you e e erm nes that an underpayment of tax results because you 8 $1 3 6 0 7 5 overstated a deduction for , this mortgage interest or for Account number (optional) Loan type these points or because you did not report this refund of 15 6 5 01 - 9 C O N Y. R E S irate"St on y°ur rat"'°. (Keep for your records.) Department of the Treasury -Internal Flevenue Service Form 1098 Substitute ESCROW RECONCILIATION PRINCIPAL RECONCILIATION $348.37 BEGINNING BALANCE $88,805.71 BEGINNING BALANCE $1,381.14 + DEPOSITS $1,079.94 PRINCIPAL APPLIED $273.00 - HAZARD INS PAID $87,725.77 ENDING BALANCE $1,360.75 - TAXES PAID $95.76 *ENDING BALANCE $720.60 CURRENT PAYMENT $173.55 CURRENT ESCROW PMT PROPERTY ADDRESS: 201 WALNUT ST CARLISLE PA17013 *HELD FOR DISBURSEMENTS DUE NEXT YEAR -------------------------- 2001 INTEREST CALCULATIONS -------------------------- TOTAL INTEREST APPLIED 2001 (NEXT DUE DATE 01/01/02) $6,734.22 -------------- 2001 MORTGAGE INTEREST RECEIVED FROM PAYER/BORROWER(S) $6,734.22 IF YOU HAVE ANY QUESTIONS REGARDING THIS STATEMENT, PLEASE CALL 1-800-421-8059. ORIGINAL STATEMENT ~ 01/14/200: PRUDtiNTIAh INSURANCE CO OF AMERICA ° 'tD BOX' 7657 PHILADELPHIA, PA 19101-7657 22-1211670 2b Taxable amount ^ Total ^ eox ~ not determined distribution Distribution coda DIS COPY C For Recipien Records W HEINEMAN WALNUT ST ISLE PA 17013-3869 9a Your percentage of total tlisiribution 2001 FORM 1099-R OMB No. 1545-0119 Distributions From Pensions, '~, Annuities, Retirement or , Profit-Sharing Plans, IRAs, Insurance Contracts, etc. ' This information is being furnished to the '. Internal Revenue Service ~'. °'° ! PA/22121 DIS 21.72 21.72 ' ACCuUNT/CONTRACT NUMBER: 21344968 _ OFFICE: W SH___ PHONE: 1-800-778-2255 INSURED/ANNUITANT: CARL W HEINEMAN 21.72 21.72 ________ _______ Form Date t .Gross distribution 2a Taxable amount 2001 FORM 1099-R ORIGINAL STATEMENT 01/14/2002 OMB No 1545-0119 $ 2t .72 ~ 21.72 . 2b Taxable amount Total ^ ^ Distributions PAYER'S Name, Street Address, City, State, and ZIP code PAYER'S FederatID # not determined distribution From Pensions, PRUDENTIAL INSURANCE CO OF AMERICA 3 Capital gain 4 Federal Income tax Annuities, P 0 BOX 7657 22 -121 1670 (Included to box 2a) withheld Retirement or Profit-Sharin PHILADELPHIA, PA 19101-7657 $ g Plans, IRAs, 5 mployee contributions or insurance remiums 6 Net unrealfze appreciation l er's urities i em e Insurance Contracts, etc. p n p oy s c ' l RECIPIENT'S Name and Address i # - w r ,isn d to mein emel CARL W HEINEMAN $ $ Re"enve se'"i`a 201 WALNUT ST ~ oodebution s P -e Other COPY B CARLISLE PA 1 701 3-3869 J SIMPLE Report this income on your Federal tax 7 $ o~ return. If this form 9a our percentage of - `9b Total-employee.:dontributibns shows Federal Income tax withheld total distribution in Box 4, attach this $ copy to your return. 10 tare tax 11 State/Payer's ]2 State 13 Local tax 14.Nameot locality 15 Local distribution withheld state number "tlisteibubon withheld $ PA/221211670 $ $ $ vepartmem or me I reasury - mrernal rtevenue service omi: ate b: Gross distributon 2a Taxable amount 2001 FORM 1099-R ORIGINAL STATEMENT 01 / 14/2002 $ 21 .72 $ 21 .72 OMB No. 1545-0119 ' ' 2b Taxable amount .Total ^ Distributions PAYER'S Name, Street Address. City, State, and ZIP code PAYER S Federal # not determined ^ distribution From Pensions, PRUDENTIAL INSURANCE CO OF AMERICA 3 Capital gain 4 Federal income tax Annuities, P 0 BOX 7657 22 -121 1670 (Included in box 2a) withheld Retirement or Profit-Sharin PHILADELPHIA, PA 19101-7657 $ g Plans, IRAs, 5 Employee contributions 6 Net unrealized appreciation or insurance remi i e l r iti Insurance Contracts, etc. p ums mp oye s secur es n This information is being RECIPIENT'S Name and Address r~ furnished to the Internal CARL W HEINEMAN ~ L $ $ Revenue service 7 Distribution IRA/ a Other 201 WALNUT ST code nnP s COPY 2 CARLISLE PA 1 701 3-3869 l LE File this copy 7 $ % with your State, 9a Your percentage of 9b. Total employee contributions City, or Local total distribution income tax return, ~ when required. 10 fate tax 11 rate Payer's 12. tale 13 Local tax 14 Name of Iota ity 15 Local distribution withheld state number - distribution withheld $ PA/221211670 $ $ $ uepannienr ui uie i ie~ su y - uuernai rsevenue oervice We are in the process of reviewing our records to ensure that we have the most current and complete information. Based on our tax processing we either do no[ have your Taxpayer Identification Number (TIN) or we do not have a "certified" TIN. We are required by law to obtain and maintain this information in our records. If you do not provide us with this information, certain payments may be subject Yo backup withholding up to 31 %. For amounts paid after December 31, 2001, the backup wiihholdirtg rate wit! be 30 percent. In addition, the Internal Revenue Service may assess you a $50 penalty for failure to provide a taxpayer identification number, if applicable. 0014668 I I VlPORTANT ~ .335E COnIpB',E I I marked (~i) ~ eas on attached -9 Form, detach ~ oarfor3ti~ns and - - `"mom"9- H o o ~ - - - - - - Payer's Request for Taxpayer G«e Pfpay°~`° ~~ e~emb",z on Depanment of the Treasury 3025-2001 Middleman, Broker, S B h n Id ntificati N b tifi d C ts Internal R°venue 5ervlre er .'- inge a on °r on e um er an er ca Name as Shown on Account Admen sy; one°e 002 W SH (If joint account, list both names here then circle the name of the person or entity whose number you enter in Part I below) Contract Plumber Surname. _ CARL W HEINEMAN 213aas56 HEIN Pleas~ete each section of the Form WA below marked with the (red check) and he sure to sign and date the form. Separate the Fonn W-9 and insert i', into the return li envelope. The Form W-9 certifies your taxpayer identification number and that you are not subject to backup withholding. instructions: If you are a citizen or legal resident of the Unf[ed States, please provide your 9 digit Scciai Security Number (SSN) OR your Employer Identification Number (FIN) Thank you for furnishing this important information io us. You may receive additional tax statements from Prudential. `~ Please check appropriate box ~ IndividuaiiSole proprietor ~ Corprration ~ Partnership ^ Other ~ .............. ..................................... Address i ~ ^ Check Only if Address ~ ~ Change Requested ti ' Gly, S[a[e. and ZIP code f1 ~' _ rt I ,. - ~ I 1 TAXP?,tER ~CEIJTIFI A~:~f, P.Uf,1BEP -- En(er yoc: axpayer n,e vP rattan ntn i;;r m the poropn.ate cox. ror trio inumi uz:: tf s ~.; your a ~:~,i ecuri:r daft j( I. /„s ire .;_mpi from '.-ackr~~p turn in the ~ number. If you are a resicent al~en and you du nnl nave ar.d are noI eGgJ,e ?get an ~ w, vuur TIN s year IRS irdlvidual ,aapayer iden, -rali~c ~?ur,b .r ,ITlitll. ~ N ~hh^I r g under iR~ -e?, ~.1!ar ~~, s- onot t"ched envelope. ~ ~cciai s~conty number OR ~ Emplorer identification number I EXEMPT' in this box. - -L- ~ I CERTIFICATION -- Under penalties of perjury. I certify that: (1) The m;mber shown on this form is my turret! Taxpayer Identification Number (er ! am ~.vaiting for a number io be issued to me). and i (2) I am not subject to backup withholding either because I have not been notified by the Internal Revenue Servie2 (IRS. that . 3m subject to bzc;cup withhcidino as ~ ras!t I of a tailu=e ie repot ail 'interest cr dividends, or the IRS has notified me that i am no longer subjec^ to backup witLhniding nr i am exempt rrom bad<up withholding, and (">) t am a U. S. persnn (including a U.S. resident alien). ' r , iaaro~~ nsirt.r:~ions - Yo: i. u t cross cat Ite•r. ;e, it :ne -. ~ ".as nc2',.,,, r~u t- ,i iou ar sf.,, ~,., -, s,,,-~ht.p murh_ idi.,y ;.. ,: !-tat _ st,bneruen Jy '~.?e•? no,,, a_~:; I ice; t;?~r !F:S that you are not subl xt tc bacS<un withholding. do net cross cat item i?':. ~ ca,,,, - ,,l , I 4t>LUntC and Expense Statement PACSES Case Ntunber OTHER (Fill in Appropriate Co{umn) CNCOME WEEK MONTH YEAR lntCrCtit $ $ $ DiviJrnds Prnsic~n Annuity S~~cial Security Rents iZ~lydltlCJ Exllrnsr Account Gifts Unemployment Cunlpensation Workmen's CUIUpCn5apU11 IRS Refund Ottler Other TOTAL $ $ $ TOTAL IIVCOME $ (Fit! in Appropriate Column) EXPENSES WEEK MONTH YEAR Home Mclrtgagr/Rent $ $ $ Maintenance '- Utilities Electric Gas ~° Oil 1 . Telephone i~. , Page 2 of 6 Srtvice Type M Form IIV-008 Worker [D [ncotne anti Expense Statement PACSF.S Case Numbet (Fill in Appropriate Column) EXPENSES (continued) WEEK MONTH YEAR Water $ $ - $ Sewer Employment Puhlic Transportation $ $ $ Lunch ~ ~ ° " ~; Taxes Real Estate $ $ $ Personal Property Income Insurance Homeowners $ $ $ Automobile Life - Accident Health Other Automobile , ~ ' Payments $ $ $ Fuel Repairs - ` Medical Doctor $ $ $ Dentist ,~~ Orthodontist Page 3 of 6 Form 1N-008 Service Type M - Worker [D -. ltuome and Expense Statement PACSES Case Number ~ - - , ^ (Fill in Appropriate Column) EXPENSES (continued) WEEK MONTH YEAR Hospital MCdicine ~~ Special needs (glasses, hracr5, ortlu~pedic dCVll'CS) Education PnVatC SC11001 $ $ $ Parochial School Collrge Religious Personal Clothing $ $ p '~ $ Barber/Hairdresser Credit Payments: Credit Card Charge Account Memberships Loans Credit Union $ $ $ Miscellaneous Household Help $ $ $ Child Care PaperslBooks/Magazine Entertaiiunent `" Pay TV Vacation ~n , `~ Page 4 of b Form IN-008 Srrvicr Type M ~ Worker [D ., [ncun~e and Expetue Statement PACSES Case Number (Fill in Appropriate Column) EXPENSES (continued) WEEK MONTH YEAR Gifts Lr~al Fres Charitable Cuntributie~its ~[11Cr Clilld $Uppor[ Alinu~ity Payments k ej ~~ b, Other $ $ $ TOTAL EXPENSES $ $ $ Ownership s PROPERTY DESCRIPTION VALUE OWNED H W J Checking Accounts ~c $ "^' X _`~' Savings Accounts Nc~~l':~ Credit Union ~ ,1~; St~x;ks/Bunds i . tl i` Rea! Estate " Other TOTAL $ POLICY 1/ Coverage * INSURANCE COMPANY H W C Hospital Blue Cross Other Medical ~~ ~j ~ ~ ~~ ~ o ~ ~ _ < <~.:~ _ , Blue Shield Other * H - Husband W -Wife C - Combined J -Joint Page 5 of 6 Focm IN-008 Service Type M Worker ID Academic Programs Pre-Pharmacy ..,1 _ -,: ~.~7 N I V E p R l 7 7 Sh~pt:~~nst:~urg lirwersay >Pre-Pharmacy (curricular focus Page 1 of 2 If you envision a society of healthy individuals and communities serviced by consumer-responsive, prevention-focused, affordable health systems that foster human dignity, improved health status, and enhanced quality of life for all, consider a career in pharmacy. Pharmacists contribute to this vision by providing pharmaceutical care through efficient drug distribution and outcomes-oriented management of patients' drug therapies and they work to expand access to and promote the value of pharmacists' care-giving services in obtaining positive health outcomes through optimal use of medications. At Shippensburg University we provide pre-pharmacy advisors to students who declare an interest in the pre-pharmacy curricular focus and plan to enter a pharmacy school program. Advisors work with individual students to identify and schedule prerequisite courses required by pharmacy schools, provide guidance in preparation for entrance exams, pharmacy school application procedures, and current trends in pharmacy school admissions. Though most pre-pharmacy students are science majors (most often in biology or chemistry), apre- pharmacy student can major in virtually any discipline. Prerequisites for entry into pharmacy programs typically include 8 credits of biology, 16 credits of chemistry, 8 credits of physics, mathematics through college algebraltrigonometry, and perhaps one course in calculus. Additionally students are expected to complete general education courses, including humanities, social sciences, and courses emphasizing communications such as English composition and speech. Course prerequisites vary among pharmacy programs therefore pre-pharmacy students early in their first semester at Shippensburg are strongly encouraged to seek guidance from apre-pharmacy advisor and to examine the book, Pharmacy Schools Admissions Requirements, which is located in the Health Sciences Office. Through an affiliation between Shippensburg University and the University of Pittsburgh School of Pharmacy, students are able to earn their bachelor of science degrees in chemistry or biology and their doctorate of pharmacy degrees in seven years. In this 3+4 program, students take a prescribed outline of 90 credits, which. includes the general education requirements and core requirements for either the biology or chemistry major, during their first three years at Shippensburg. Students who meet the eligibility requirements of the articulation agreement then enter University of Pittsburgh's four-year pharmacy program leading to the Pharm.D. Eligibility requirements include following the undergraduate degree plan while maintaining a cumulative undergraduate GPA of at least 3.0, maintaining a cumulative GPA (with no grade less than C) in the pre-pharmacy core courses, and a favorable letter of recommendation. from the health sciences co-directors at Shippensburg. Pre-pharmacy students interested in this opportunity are strongly advised to maintain close communication with their pre- pharmacy advisor. In addition, Shippensburg pre-pharmacy students choosing other pharmacy schools have done exceptionally well. Within the last decade, all qualified students who http: //www.ship.edu/academic/pre_pharm.html 9/8/02 Academic Programs Page 2 of 2 programs have received acceptance. Some of the programs to which students have matriculated include Temple University, Philadelphia College of Pharmacy and Science (now University of Sciences in Philadelphia), Northeastern University, University of Pittsburgh, and University of Maryland. Leadership, community/human service, and a willingness to volunteer contribute to the personal qualities of successful pre-pharmacy students. Successful pre-pharmacy students plan a strategy early in their college career with regard to course sequences, preparing for and taking the GRE, internship experiences, and application to pharmacy schools. They also communicate frequently with their pre- pharmacy advisor. Science classes are small at Shippensburg University, usually having 12 to 16 studerts per laboratory section. Lectures and labs are taught by seasoned professors; not by graduate students. State-of--the-art laboratory equipment is available to students, giving them hands-on experience with current techniques. Faculty-directed undergraduate research is highly encouraged at Shippensburg. Each year between 6 and 12 undergraduate science students present the results of their research at regional, state, or national conferences. These experiences combine to contribute to the excellent quality of education available at Shippensburg. ~' Go to the Biology_Department Home. Page © Go to the Chem_istry_DePartment Ho_m__e Page Back to Academic__Programs Back to Home Page `r r '~ n~~u ~h Contact Shppensburg_Umversty This page is an official publication of Shippensburg University. l I e! ~~,,,,,,,, b AproudmemberofThe_StateSystemof_Higher_Education. 1871 Ofd Main Drive Shippensburg, PA 17257 Ph:717-477-SHIP (477-7447) ~ S2afch TDD: 717-477-1833 This page last updated: Thursday, 07-Mar-2002 16:47:26 EST http://www.ship.edu/academic/pre _pharm.html 9/8/02 Tuition and fee Schedule 2001.-02 Academic Year Page 1 of 2 r, st~~.; a ~~~. ,rs~; >Admmistration & Finance > Student Accounts > Tuition and Fees Shippensburg University's tuition and fees are set by the State System of Higher Education's Board of Governors. Fail 2(102 send Sltrin~; 20(13 Semeste~•s :Full-Time Tuition xnd Fees per semester. ~~?z l~'1'~!'U:111Uft' /ll/r Ctt11t": /w-/~~ c't'CC/1(s _ t`rf~k/UU/t' /~Ir/ II!)IC': ~~-~ ~ C)'Cc~7I~~. Undergraduate Graduate I'~~r :~c:mL~t~rP~r `~ PA Non PA Non Resident Resident Resident Resident Tuition Per Semester $2,189 $5473 $2627 $4204 Ed Services Per Semester $218 $218 $2.18 $218 Technology Fee Per Semester $50 $75 $50 $75 Health Service Per Semester $72 $72 $72 $72 Student Union {CUB) Per $102 $102 $102 $102 Semester Activity Per Semester $100 $100 Recreation Per Semester $20 $20 Tuition and Fees: $2,751 $6,060 $3,069 $4,671 Room Per Semester $1,458 $1,458 15 Meal Plan Per Semester $974 - __ $974 _ _ ___ ___ ._ _ __ On-campus Total: X5,183 $8,492 Stone Ridge Room Rate Per Semester $1,545 Stone Ridge Premium Room Rate Per $2,272 Semester F.~II '2002 and Spring 20(13: Part-'T'ime Tuition anal bees Underg raduate Grad uate PA Non PA Non Resident Resident Resident: Resident Tuition (per credit) $182 $456 $292 $467 Ed Services (per credit} $18 $18 $24 $24 Technology Fee $25 $38 $:>-5 $38 Student Union (CUB): 1 - 6 credits $51 $51 $S 1 $51 7 - 11 credits $76 $76 $76 $76 (7 - 8 graduate credits} Student Activity Fee: http: //www. ship. edu/admin/stuaccnts/t uition. html 9/8/02 Tuition and fee Schedule 2001-02 Academic Year 1 - 6 credits $41 $41 7 - 11 credits $71 $71 Student Recreation 1?ee: 1 - 6 credits $10 $10 7 - 11 credits $15 $15 This page last updated: Thursday, 29-Aug-2002 10:58:57 EDT Welcome Ttert;cn & Fees Tax-info Meal P_lan_ Refunds Contact Us __ Summer Tuition FAQs Ac_counts_H_o_me 3i-; P ~;ome __ Student Accounts PH: {717) 477-1211 FAX: (717} 477-4018 Email: dmcuts~wha_rfahip._edu ~ ~I'o nsb~ Ohl Contact_Sh+ppensburg Umvers~ This page is an official publication of Shippensburg University. . ~.Jpe l l V • , ~'.. , , , , ~ A proud member of The_State 5ystem_ot Higher_Educaton. 1871 Old Main Drive Shippensburg, PA 17257 Ph:717-477-SNIP (477-7447} ~ Search TDD: 717-477-1833 Page 2 of 2 http://www.ship.edu/admin/stuaccntsituition.html 9/8/02 t DEBRA ANN BRINLEY, formerly DEBRA ANN HEINEMAN, Plaintiff vs. CARL WALTER HEINEMAN, Defendant ORDER -+ AND NOW this /-td day of Au,6lL~s / , 2002, upon the request of Plaintiff, through her counsel, the hearing scheduled for August 26, 2002 in this matter is continued. The matter will be_~heard before the undersigned at %~~ o'clock ~.m. on/~Q the ~ day of ~, 2002. BY TH~COURT Distribution: ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ) CIVIL ACTION -LAW 1 NO. 3749 CIVIL 1984 IN DIVORCE /Samuel L. Andes, Esquire (Attorney for Plaintiff) P.O. Box 168, Lemoyne, Pa 17043 ~ Dale F. Shughart, Jr., Esquire (Attorney for Defendant) 35 East High Street, Carlisle, PA 17013 J. ~, Q/a~ i eS ~ ~ erJ 7 g -~L -o a (~~~ _. ~ 79 f ~ ~ ~~ .`~ ~'G ~sl~ G~ SAMUEL L. ANDES ATTORNEY AT LAW 525 NORTH TWELFTH STREET P. O. BOY LG8 LEMOYNE, PENNSYLVANIA 17043 TELErxoxE (ill) 761-5361 20 August 2002 FAX (7») 7G1-143s SENT BY FAX 8i REGULAR MAIL The Honorable Edward Guido Judge of the Court of Common Pleas Cumberland County Courthouse 1 Courthouse Square Carlisle, Fa 17013 RE: Brinley vs. Heineman No. 3Y49 Civil 1984 Dear Judge Guido: You have scheduled a hearing on my Petition to Enforce Property Settlement Agreement for 1:00 p.m. on Monday, 26 August 2002. Unfortunately, a conflict has arisen on my schedule which requires me to request a postponement. Dale F. Shughart, Jr. represents Mr. Heineman and he has consented to have the matter postponed. Moreover, the parties have recently exchanged some proposals and we have some hope that we can resolve the case without a hearing. In the meantime, my client is receiving at least partial payments on the amount she wants which removes some of the urgency of our request for a hearing. I have enclosed a proposed order that you can use to reschedule the matter if you are willing to do so. Please feel free to contact Dale F. Shughart, Jr., Esquire, or myself if you have any questions. Sincerely, L. Andes amh /Enclosure cc: Dale F. Shughart, Jr., Esquire (VIA FAX} Debra Ann Brinley ti_ ~~. DEBRA ANN BRINLEY, formerly Debra Ann Heineman, Plaintiff vs. CARL WALTER HEINEMAN, Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 3749 CIVIL 1984 : IN DIVORCE ANSWER TO PETITION TO ENFORCE PROPERTY SETTLEMENT AGREEMENT NOW, comes the Respondent, Carl Walter Heineman, Defendant above captioned, and answers the Petition filed by the Plaintiff as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Denied. On the contrary, the Respondent was not consulted about his daughter's choice of college. He was in fact advised on March 14, 2002 that she had selected Wilkes University at an annual cost of $26,923. Respondent does not believe this is a reasonable choice of an educational institution for his daughter, given his financial circumstances. 8. Denied. It is denied that Respondent is refusing to contribute to his daughter's college education. On the contrary, Respondent has been advised that the cast of room, board, tuition at Shippensburg University for enrollment in the year 2002 is .___ _ ~ ~ $5,183 per semester. He is prepared, to pay one-half of this amount, the sum of $431.92 per month and in addition t:o reimburse one-half the cost of books, supplies, miscellaneous fees and transportation upon being provided itemized bills detailing the reasonable total amount of such additional cost. Respondent has made a monthly payment of $431.92 to Petitioner for the first month of college expense. 9. Denied. On the contrary, Respondent has not breached his Agreement and contends to comply with his obligations thereunder by paying one-half of the reasonable cost of Abby's education. 10. Denied. On the contrary, Respondent has not breached nor does he intend to breach his agreement. NEW MATTER 11. An express term of the Agreement requires the Respondent be consulted. He was not consulted and in fact Abby has broken contact with him, despite his sincere and continuing efforts to have a relationship with her. In fact Abby refused to speak with her Father at his Father's funeral on February 20, 2002. 12. No information was provided to Respondent iri regard to her efforts to obtain financial aid other than that Abby apparently has a $6,000 scholarship. 13. No requests were made of Respondent regarding his financial situation. 14. Respondent has a minor daughter, Christina at home to support and earns an annual salary through two jobs of -2- ~'' approximately $40,000. His income is insufficient to pay college expenses in excess of $11,000 a year. WHEREFORE, Defendant/Respondent prays Your Honorable Court to dismiss Plaintiff's Petition. Respectfully submitted, ,_ j %" 1 % A> By: ~,~„~,F~ ~ r~~ Dale F. Shugh,~t, ~Jr. Supreme Courti,I.D! 35 East High Street, Suite 203 Carlisle, PA 17013 (717) 241-4311 VERIFICATION Carl Walter Heineman hereby verifies that the facts set forth in the foregoing Answer to Petition to Enforce Property Settlement Agreement are true and correct to the best of his knowledge, information and belief, and understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsifications. ' ~,^w ~ '~ `~~~ ~ DATE: August 16, 2002 -3- ~' r DEBRA ANN BRINLEY, formerly Debra Ann Heineman, Plaintiff vs. CARL WALTER HEINEMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 3749 CIVIL 1984 IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this 16th day of August, 2002, I, Dale F. Shughart, Jr., attorney for Defendant, hereby certify that I have served a copy of an Answer to Petition to Enforce Propety Settlement Agreement by facsimile and by mailing a copy of the same by United States mail, postage prepaid, addressed as follows: Via facsimile - 761-1435 Samuel L. Andes, Esquire United State Mail - First Class Samuel L. Andes, Esquire 525 North 12th Street P. O. Box 168 Lemoyne, PA 17043 ~~ ~ _ , i Ror*il~er~l"' ~,;~~~~ry~. Form Fi~100 SUITS, 19~`~ Case # -S 374g Date of Entry: ~ a a` 2:58 p Dec 2s 1 9 84 at M. Appearances: Plaintiff: Debra Ann Heineman Defendant: earl Walter Heineman t 3 ~, D '-~ `' ~-' ~ ~~ August 27, 1 85 -Affidavits filed Affidavits of Consent filed Property Settlement Agreement file Praecipe to Transmit Record filed ~s~ ~ PT ~ July 3, 2002 Petition to Enforce Property Settlement Agreement, filed. July 12, 2002, Order of Court, filed. IN RE: Petition to Enforce Property Settlement Agreement AIm ITT this 11th day of July, 2002, upon consideration of the attached Petition to Enforce Property Settlement Agreement, it is hereby directed that the parties and their respective counsel appear before the undersigned on Monday the 26th day ~ of August, 2002 at 1:00 o'clock p.m. ~ By the Court: Edward E. Guido, J. ~ Entry by Summons ( ) Complaint Petition Appeal Revival Action in Assumpsit Trespass Habeas Corpus Divorce Grounds Equity Mortgage Foreclosure Ejectment Quiet Title Replevin Condemnation 1 { { x Service by SHF: Date of ~ Return: Copies mailed 7f 12j02 August 16., 2002, Answer to Petition to Enforce Property Settlement Agreement, filed. Fiat U~ rorGt DEBRA ANN BRINLEY, formerly IN THE COURT OF COMMON PLEAS OF DEBRA ANN HEINEMAN, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff/Petitioner v. CIVIL ACTION - LAW CARL WALTER HEINEMAN, Defendant/Respondent NO. 3749 CIVIL 1984 IN RE: PETITION TO ENFORCE PROPERTY SETTLEMENT AGREEMENT ORDER OF COURT AND NOW, this 9th day of September, 2002, after hearing, it is ordered and directed as follows: 1. Defendant is directed to pay a sum equal to one half of the yearly cost for tuition, room, board and fees at Shippensburg University. Those payments shall be made in 10 equal monthly installments commencing in June 2002. They may be made directly to Wilkes College or to Plaintiff, who shall then pay them to Wilkes College. Thereafter, he shall continue making said payments based upon the cost of said expenses at Shippensburg University for so long as daughter is enrolled at Wilkes College. Provided, however, that after her first three years of college, the payments shall be based upon the=- tuition and other expenses at Duquesne University. 2. Defendant shall pay $250.00 per year for transportation expense, payable $125.00 on September .L of each year and $125.00 on January 10 of each year. Said payments may be made to daughter. 3. Defendant shall reimburse daughter one half the cost of all books and supplies within 30 days after he has received copies of the invoices therefor. 4. Defendant shall reimburse daughter one half of reasonable clothing expenses within 30 days after he h.as received copies of the bills therefor. 1! Samuel L. Andes, Esquire 525 North 12th Street Lemoyne, PA 17043 Attorney for Plaintiff/Petitioner ,.Dale F. Shughart, Jr., Esquire 35 East High Street Carlisle, PA 17013 Attorney for DefendantfRespondent c°~~ RKS y-'1!-oa srs ii ~ t ~. ~ ., F~ DEBRA ANN BRINLEY, IN THE COURT OF COMMON PLEAS OF Formerly :CUMBERLAND COUNTY, PENNSYLVANIA DEBRA ANN HEINEMAN, Plaintiff V. CARL WALTER HEINEMAN, NO. 3749 CIVIL 1984 Defendant CIVIL ACTION -LAW AMENDED ORDER OF COURT AND NOW, this 16TH day of SEPTEMBER, 2002, defendant's Motion for Reconsideration is granted insofar as our order of September 9, 2002, is amended to add the following language to paragraph 1: Provided, further, that defendant's obligation shall not extend beyond daughter obtaining sufficient credits for a four year undergraduate degree or its equivalent. In all other respects, our order of September 9, 2002, shall remain in full force and effect. By t ourt, Edward E. Guido, J. ~ Samuel L. Andes, Esquire For the Plaintiff .iDale F. Shughart, Jr., Esquire For the Defendant :sld ~~~ ~\~o i \. I.0 .. 1'. .. r~ (~..: ~. SEP 1 :3 ~Q11r DEBRA ANN BRTNLEY, IN THE COURT OF COMMON PLEAS formerly Debra Ann Heineman, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW NO. 3749 CIVIL 1984 vs. CARL WALTER HEINEMAN, IN DIVORCE Defendant ORDER OF COURT AND NOW, this day of 2002, based upon the attached Motion for Reconsideration filed on behalf of the Respondent, Carl Walter Heineman, by his attorney, Dale F. Shughart, Jr., Esquire, RECONSIDERATION of the Order of this Court dated September 9, 2002 be and is hereby GRANTED. By the Court, J. CC: Samuel L. Andes, Esquire Dale F. Shughart, Jr., Esquire DEBRA ANN BRINLEY, formerly Debra Ann Heineman, Plaintiff vs. CARL WALTER HEINEMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 3749 CIVIL 1984 IN DIVORCE MOTION FOR RECONSIDERATION PURSUANT TO PA.R.C.P. 1930.2 AND PA.R.A.P. 1701(b)(3) AND NOW, comes the Respondent, Carl Walter Heineman, by his undersigned attorney, Dale F. Shughart, Jr., Esquire, and respectfully requests Your Honorable Court to reconsider its Order of September 9, 2002 for the following reasons: 1. The Agreement of the parties, admitted in evidence, expressly provides that the Respondent is required to pay "one-half the reasonable cost of undergraduate college education" (emphasis added) for his daughter Abby. 2. The testimony in the case established unequivocally that Abby is enrolled in a six year program at Wilkes University, upon successful completion of which she will receive the Post Graduate Degree of "Doctor of Pharmacy". The evidence unequivocally establishes that the "Pre-Pharmacy" Program is a two year program and the "Doctor of Pharmacy" program is a four year program after the two year program. 3. It is believed and therefore averred that counsel for both parties agreed at the hearing that the obligation of the :Respondent would be for a period of four years, not the two year undergraduate program and not the six year doctoral program. y 4. Part of the rationale stated by the Court prior to entering its Order regarding the amount of the payment by the Respondent to Wilkes University or the Petitioner was based upon the precise language of the Agreement regarding potential educational costs for other children of the Respondent. 5. The record unequivocally establishes that the Respondent has another daughter, Christine, a ninth grade student at Carlisle Hospital, now age 14, who plans to pursue her own co]_lege career after graduation from high school in four years, immediately after Respondent's four year obligation to Abby is concluded. 6. The Record unequivocally establishes that the Respondent has insufficient funds to support two children in college at the same time. 7. It is believed and therefore averred that the evidence in the case and the agreements of counsel for both parties stated in open Court require that the obligation of the Respondent should terminate after paying for four years of undergraduate college education for his daughter, Abby, as otherwise set forth in the Order of September 9, 2002, a copy of which is attached hereto, made a part hereof and marked Exhibit "A". WHEREFORE, based upon the foregoing facts which are believed to be undisputed in the Record, the Respondent, Carl Walter Heineman, prays Your Honorable Court to grant Reconsideration, and to take further action in the matter, as the Court deems appropriate, alternatively requested as follows: -2- 1. To amend the Order of September 9, 2002 to expressly provide that the obligation of the Respondent shall not, exceed four years; or 2. To schedule an in Chambers conference with counsel for both parties; or 3. To schedule the matter for Argument Court; or 4. To schedule the matter for a further hearing; or 5. To grant such other relief as the Court deems appropriate. Respectfully submitted, ~, G~~ 1 Dale F. Shughart, r. Supreme Court I.D. :19373 35 East High Street, Suite 203 Carlisle, PA 17013 (717) 421-4311 VERIFICATION Dale F. Shughart, Jr. hereby verifies that the facts set forth in the foregoing Motion for Reconsideration are true and correct to the best of his knowledge, information and belief, and understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsifica ns. DATE: September 13, 2002 -3- DEBRA ANN BRINLEY, formerly Debra Ann Heineman, Plaintiff vs. CARL WALTER HEINEMAN, Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 3749 CIVIL 1984 IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this 13th day of September, 2002, I, Dale F. Shughart, Jr., attorney for Carl Walter Heineman, hereby certify that I have served a copy of a Motion for Reconsideration and proposed Order of Court by mailing a copy of the same by United States mail, postage prepaid, addressed as follows: Samuel L. Andes, Esquire 525 North 12th Street P. O. Box 168 Lemoyne, PA 17043 Dale F. Shughart, Jr., squire 35 East High Street, S to 203 Carlisle, PA 17013 (717) 241-4311