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Home My WebLink About85-1280 ED K. BALL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. Np, 1280 - 85 CIVIL 19 ROSILAND J. BALL, Defendant IN DIVORCE STATUS SHEET DATE: ~ ACTIVITIES: 8/5/99 ;. PRETRIAL STATEMENTS DUE 9/10/99. ~. ---~ ., . . - _..__ -----_ ,- , ;_ ~ r k-,~ ~ ~ ~~ ,~ ~ c;r -~ ~ ~ f ~, 01 ~ ~~ ~ . ~ OFFICE OF DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEAS 9 North Hanover Street Carlisle, PA 17013 (717) 240-6535 E. Robert Elicker, 11 Divorce Master Traci Jo Colyer Office Manager/Reporter August 5, 1999 Robert C. Sardis, Esquire SAIDIS, MASLAND & SHUFF 26 West High Street Carlisle, PA 17013 RE: Ed K. Ball vs. No. 1280 Civil In Divorce West Shore 697-0371 Ext. 6535 Gary L. Weber, Esquire 10 West Third Street Williamsport, PA 17701 Rosiland J. Ball 1985 Dear Mr. Saidis and Mr. Weber: By order of Court of President Judge George E. Hoffer dated July 22, 1999, the full-time Master has been appointed in the above referenced divorce proceedings. I have recently received a copy of the documents in the file, which were on microfilm, from-the Prothonotary. A divorce decree was entered November 22, 1988, preserving the economic issues of equitable distribution, alimony, alimony pendente lite, and attorney fees and costs. Attorney Weber's name was noted on the motion for appointment of Master as counsel for the Defendant. Mr. Weber was mentioned as counsel in the order of Court of November 3, 1988, and did accept service of the petition for bifurcation. Obviously, I am puzzled as to why this case has taken so long to come to resolution on the economic issues but that will be revealed, I am sure, in the course of the information provided by the pretrial statements. I am directing each counsel in accordance with P.R.C.P. 1920.33(b) to file a pretrial statement on or before Friday, Mr. Saidis and Mr. Weber, Attorneys at Law 5 August 1999 Page 2 September l0, 1999. Upon receipt of the pre-trial statements, I will immediately schedule a prehearing conference with counsel to discuss the issues and, if necessary, schedule a hearing. Very truly yours, E. Robert Elicker, II Divorce Master NOTE: Sanctions for failure to file the pre-trial statements are set forth in subdivision (c) and (d) of Rule 1920.33. THE ORIGINAL PRE-TRIAL STATEMENT SHOULD BE FILED IN THE MASTER'S OFFICE AND A COPY SENT DIRECTLY TO OPPOSING COUNSEL. * FAILURE TO FILE PRETRIAL STATEMENTS AS DIRECTED BY THE MASTER MAY RESULT IN THE MASTER '` APPOINTMENT BEING VACATED. LAW OFFICES BARBARA SUMPLE-SULLNAN s49 BRIDGE STREET NEW CUMBERLAND, PENNSYLVANIA 17070-1931 PHONE (717) 774-1445 FAX (717) 774-lose August 31, 1999 E. Robert Elicker, II, Esquire Divorce Master 9 North Hanover Street Carlisle, PA 17013 Re: Ball v. Ball Dear Mr. Elicker: I have been contacted by Ms. Rosiland Ball to represent her in the divorce action. It appears that her Attorney, Mr. Weber, may have hired and transferred her case for handling to Attorney Masland in 1988. I have requested from his office her file. To date, it has not been located. As you know, Mr. Saidis, who represents Mr. Ball, is in the same office as Mr. Masland. I have learned in a conversation with Mr. Saidis today that aPre-Trial Statement in this case is due on Friday. Since we have no information, Mr. Saidis has agreed to allow me a reasonable extension to respond. I understand that he will file his Pre-trial giving the list of assets and other information he may have so I have a starting point with Mrs. Ball. Hopefully, this matter can be fully addressed without much discovery and litigation. I have communicated the above to you by telephone and you have granted me the continuance on filing the Pre-Trial for Ms. Ball. I expect that I should be able to file same 45 days after receipt of Mr. Saidis' Pre-Trial Statement. Thank you for your cooperation. Very trlaly y rs, : , i ~, ' J" % /`,;' f ~~; Barbara Sumple-Sullivan BSS/ld cc: Robert C. Saidis, Esquire Ms. Rosiland Ball ED K. BALL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW N0. 1280 Civil 1985 ROSILAND J. BALL, Defendant IN DIVORCE NOTICE OF PRE-HEARING CONFERENCE TO: Robert C. Saidis Counsel for Plaintiff Barbara Sumple-Sullivan Counsel for Defendant A pre-hearing conference has been scheduled at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania, on the 10th day of April, 2000, at 9:30 a.m., at which time we will review the pre-trial statements previously filed by counsel, define issues, identify witnesses, explore the possibility of settlement and, if necessary, schedule a hearing. Very truly yours, Date of Notice: 11/1/99 E. Robert Flicker, II Divorce Master OFFICE OF DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEAS 9 North Hanover Street Carlisle, PA 17013 (717) 240-6535 E. Robert Elicker, 11 Divorce Master Traci Jo Colyer Office Manager/Reporter September 1, 1999 Barbara Sumple-Sullivan Attorney at Law 549 Bridge Street New Cumberland, PA 17070 RE: Ed K. Ball vs. Rosiland J. Ball No. 1280 Civil 1985 In Divorce Dear Ms. Sumple-Sullivan: West Shore 697-0371 Ext. 6535 I am writing in response to your letter of August 31, 1999. Inasmuch as Mr. Saidis has concurred in your request for additional time to file a pretrial statement, I have no objection to allowing you an extension to Friday, October 29, 1999. Hopefully, after receiving Mr. Saidis' pretrial statement, you will both be able to determine what discovery, if any, needs to be completed before the conference which will be scheduled upon receipt of your pretrial statement. Very truly yours, E. Robert Elicker, II Divorce Master cc: Robert C. Saidis, Esquire ~~'~.-- +r'' 1 { (~ 1,, ~~~~~ Y ' ~~.~- ~i~~ IY V4f3~ ifs ~iUu~^~ IN Tl1E COURT OF COPIMON PLEAS OF CL'PffsERLAND COUNTY, PENNSYLVANIA f~, ~ . Fd K_ Ball Plaintiff vs. Rnai 1 and .7 Ralf Defendant - CIVIL ACTION - LAW N0. 1280-Civil 19 R, MOTION FOR APPOINTMENT OF MASTER ' Ed K, Ball (Plaintiff) (D), moves t:he court to appoint a master with respect to the following claims: ( ) Divorce (.X) Distribution of Property ( ) Annulment ( ) Support (X ) Alimony (X ) Counsel Fees (X ) Alimony Pendente Lite ( ) Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claims (s) for which the appointment of a master is requested. (2) The defendant (has) (h appeared in the action (personally) (by r attorney, Gary L. Weber ,Esquire). (3) The staturory ground(s) for divorce (~) (are) 201D diverr.P granted October 18, 1988 (4) Delete the inapplicable paragraph(s): (a) The action is not contested. (b) An agreement has been reached with respect to the following claims: Entry of the divorr.P OrtnhPr 1R, 1ARR (c) The action is contested with respect to the following ClalmS: all n~ thA ahnva (5) The action ~~~) (does not involve) comn_lex issues of law or fact. (6) The hearing is expected to take 1 (3 (days). (7) Additional information, if any. relevant to the motion: Date: July •~` Attorney for (Plaintiff) (~~~~ is ORDER APPOINTING MASTER AND NOW ~ ,19~,_ appointed m ter ith respect to the following claims Esquire, CUMBERLAND ~'~% ,-~, ~~ _~.;~t~:i~~_. ,o r ~' OO i~ ~ -y v~ 0 ~ 0 ~ ~ ~~ ~ ~ ; ~- k~ c ~ _,., , -_ 3 Y . ; _._ ;~, ED K. BALL, Plaintiff , vs. ROSILAND J. BALL, , Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 1280 - 85 CIVIL ACTION - LAW IN DIVORCE ORDER AND NOTICE SETTING HEARING TO: Ed K. Ball plaintiff Robert C. Saidis Counsel for Plaintiff Rosiland J. Ball Defendant Gary L. Weber Counsel for Defendant You are directed to appear for a hearing to take testimony on the outstanding issues in the above captioned divorce proceedings at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania on the day of at a.m., at which place and time you will be given the opportunity to present witnesses and exhibits in support of your case. By Date of Order and Notice: By: Cciurt , rge E. Hoffer, President Judge Divorce Master IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 TELEPHONE (717) 249-3166 LAW OFFICES BA1~B AR A SUMPLE-SULLNAN 549 BRIDGE STREET NEW CUMBERLAND, PENNSYLVANIA 17070-1931 PHONE (n~) n4-t44s FAX (n7) 774-lose March 30, 2000 E. Robert Elicker, II, Esquire Divorce Master 9 North Hanover Street Carlisle, PA 17013 Re: Ball v. Ball No. 1280 Civil 1985 Dear Divorce Master Elicker: Enclosed please two (2) copies of the Marital Settlement Agreement in the above-captioned action. I have forwarded an original to the Prothonotary's office so that it may be filed of record. Thank you for your assistance in this matter. BSSfIw Enclosures cc: Robert C. Saidis, Esquire Rosiland Ball Barbara Sumple-Sullivan .:.y ;~. .~, .X. .,~. .;,~. .~ .x. .M. .~. .~ .;et• :r.• :,.;. .~. .,yi •:~• •:K• .:vb :'~:• ~ '•x•: ;Vp: wt . :V-\ . ;'i-\ •9U? ;~ .rcc ~'~' ~ _._._. "__ ._ _.,_____ . _ i t~ ~,•. ~; ~:E '.. '' dN THE COURT OF COMMON PLEAS r+ ,t ~~ OF CI.Jf~fE3E~LAl~JD CO~.JNTY ~ ~ f. STATE OE PENNA. !; ;a . , EU ii. BALL, 1 ~ hlaint:ff `tt• l,.~,t3U C'.1v.i1. ~c) ti5 ~f i ~~ RUSILANp J, BA1,L, i~ r!~ L'cfendant ~r DECREE !N ~~ DfVUR~E~~C~,L.~P,~'1, . ~` ~ ~ . 19813, ... , it is ordered and n AND NOW, .....~.vvs~mt~cr, .... decreed that ...1~,-~ K ..1~f1)~1, .. ....... ...................... . plaintiff, 's,' rt ~ r and ........ JtuSII~A~P. ,~ .. tint,,.. ............... ........... . defendant, +~ are divorced from the bonds of matrimony. k, 'r'; The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet r: been entered; ~ y ~: „Equ.i.tah.te,dis.tributign.of,m.rlrit~~l,.pr•,c~p4rt,y,,,~z,l,i,mon•y,,,a,1,i,mQny { pen~ientr 1ite, at.tornr,v~' tern, and costs, pursuant to Urder of Coy rt c2atc~d Navembrr 3, 198L~ • • . t 1~ Q y C o t wStt et. ~ r (;~. , : ~. it Prothonotary ~ / ~> / it• ~i. 91G •;Ai. .r. ..M:• •X• .;0:• ~9R.....~C. .;,~. .~. .w;• •Ai .qIC. •;~;• r ~ 1 A"i 9Yi ~• ED h. $AL1,, IN THE COURT OF CO`i~~ION PLEAS OF' Plaintiff CUhiBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW Yt'J .;1 L, (1wU i/ Lt~LL, n n(n ~T T+ 1(1 tJJ ~1\v i..~v l V 1._. Defendant IN DIVORCE ORDER OF COURT AND NOW, this ~ day of November 1988, the defendant having Mailed to appear personally or through counsel at the time and place set ~~ j~for the return of. t;~e Rule in this case, it is hereby ordered and `decreed that the divorce action entered in this case is bifu*cated such ithat the parties may proceed to finalize the divorce action pursuant to lthe appropriate section of the Divorce Code of 1980 as amended and ~lfurther that the court retains jurisdiction of all other collateral fi issues raiseo in tine pleauing5 l~~ ~nis case. It is further noted by the court that Bradley L. Griffie, Esquire, 'counsel for the Plaintiff, indicates to the court that Gary L. ti'~eber, Esquire, counsel for the Gefendant, has contacted him by telephone to advise him that the defendant would not be opposing this action. i BX THE COURT, ~ r , c_7 ' r-7 _ l - r" t J . .,, ~- 7 ~ ~~~ ~~ ~, h:l) K. fi~1i.L, Plaintifi• .` THE COL'FT OP C0;•~~tON PLEAS OF CL:SBERLI;7D COfJN'[~', FEN;7S1'LV:INIA N0. 12ti0 CIVIL 1985 Vg. f)c~.°endant :~ the Yrnthonotary: ?~1ECI?E TC TRA:~S:tI i RECORD Transmit the record, together wiCh the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Ser_tion (2C1(.:)) (~~X~Q'iX) of the Divorce Code. (Strike out inapplicable section.) 2. Date .and manner of sen~ice of the complaint: Certified mail, restr:ictcd delivery to Defc'nciant on i~tay 3, 1985. , 3. (Complete efCher paragraph (a) or (b) .) (a) Dstr_ of execution n° the affidavit of consent r~_~c~ired by Section 2Gllc) of the Divorce Code: by the olaintift` November 17, 1988 ; b, defendant__ November 16. 1.988 ____ (b) (1) Date of execution of the plaintiff's affidavit required by Section 2Ql~d) of tFz~ Civorce Co~1e:, (2) ate of service cf the plaintiff's affidavit upon tl:e deie:tdant: a. Related clai,:.s pending: equitable distribution of marital property, alimony, alimony penciente lite, attorneys' fees, ana costs, pursuan to C)rder of Court dated November a, 1986 -----_ Attorneq for Plaintiff) _ ~~ F:O t;. fsAl,1,, IN 1'}fl•.' r'OUR'1' OE' r'ODiMON PL,1AS OF I''. a : r.• ; f f ~'UMEiF:RLAND ~'OUN'1'ti', PP,NNSYLVAN 1 A .,. . ~'IVIL Ar"T']ON - LAW NO. ~~~d r'1VIL :9$5 ROSILAND J. 1iALL, 4 D~>fF~ndan•_ IN DIVORCE NOTTCE '1'O lll_;FENU ANC ~'1,A1M ItIGilTS Yc,u havf~ b,„,•n sued in r-r,ur~.. 1f yc~u wish ~-~ d~fPnd acta.inst th~> c ',~.ims sc" f~,r?.h in •.hc> f:~' 'owing pagf>~;, you mus*._ takr prc~,mp;. ac*i~n. You ~-3 r:f-• w~3t~n~d -.ha- if you fai' '.n dr, ;r>, rho r~a:;r, wi',' prr~cF~d w.ith~ur. yr~i,r and a dc~r'rc~F~ r,f divr,rr-c~ nr tannulmc~n~ may br, c~nt.nrr>d against you by r_h~ cur.-.. A judgmc>n:. may a:su be-~ ~~nt.c~tF~d against. yni.! fc~r any tether cla?.m ~>r. r~•]i~f rc~yuc>st~>d ir, ._h,,s,. napr•rs by t.hr~ Pla.i-n~if.f. You may losF~ m~nr-y nr pr~p~,r~t.y ,~r r,~.h,~r t iqh~ s impr,t:t.~n~ t.c~ yc,u, Lnc~lud.iny ru:,tidy ~r vii>iurcinn ~f. your: r-hi~dr~>n. !ah•>n thc~~ ground f~~t ., h,, divc,rr-c• is ind.ign.i±..ies car .irt:el:.r.i~vabi~ brc~,~kd~~wn of ~hc~ mar:!:iagc,, you may rnguF>s'. marr.iag~> ~~~uns~]..ing. A lisr ~~f m;~,rrtag,~ c•,~unn•~>~nrr~ .., avaiab'F> in t.hr> Uffir•~ nf: the Prnthc~nr',tary at ~_hr~ E•'ir:>'_ F,~,~r, r'i.rmbc>r.:alyd Cr,,.rn•:y !'~urth~use, S~uc,h Hanover Str~>Pt_, r'~,r: ?._.,'r~, Yr>nnsv=van.ia 1.70: 3. fE' ','OU DO NOT I''iLE A r"LATM FOR ALIMONY, DiV1S1ON OF MARITAL PROPERTY, LAWYER'S FEfS OR EXI'I:NSf,S I3 E•:FORE; A DIVORCE OR ANNULMENT iS GRANTED, YOU MAY LC._~F, TfIE: FIGHT TO ~'LA?M ANY OE' THEM. Y' Ci SfIJUI,U '1'Af:I? THIS PAS[:R TO YOUR LAWYER AT ONCE. IF YOU DO NOT IIAVI•: A LAWYE:4' Oft ~'ANNO'I' AFF'oltD ONE, GO TO OR TELEPHONE TiTE OFFICE SET FOR'PH Rc:L~"7W TO FIND OUT WHERE YOU ''AN GET LEGAL HELP. ~~ CurnbF~riand r'r7un-.y ~~nur~ rldminisrrat~r cumbc>;~ ;and c'ciun-.v ~"r~uc-.hnusn - S,~u~_h flannvc~>r:~ S':t ~ ~~_ Car. '::s'r~, F~,~nnsy.'.-vania 17013 (717) 249-11.3. '~l7) t~c,7-0371 ~~ ,~ IN 'I'E?~ ''OURT OF COMMON FLEAS OF F'D K. BALL, - P~ainr.~ff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL A^_TION - LAW N0. CIVIL 1985 ROSILAND J. BALL, Def~~ndan~ 1N DIVORCE COMPLAiPdT TN DIVORCE:; COUN'1' I _. Pla.in~iff .is Ed K. Hall an adult .individual currently r?sidinq at 157 North }lanwFr. S~r.F~F~t, Car?.islF~, Cumberland Cnunty, F'r'nn5ylvania. 2. Def.endan~ is Resiland ,7. Bail, an adult indi-.ldual cuL~rently resid.i-nq at 339 Ninth StreF~t., New Cumberland, Cumberland County, Penn- sylvan:-a. 3. Plainr.:if:f and De fend3nt are bona fide rc~sidc~nts of thF~ Common- i wealth cif Pennsylvania .end have been sc~ fnr. at least six months imme- d.iately previ<~u:; to the f.`.il.ing tc~ this rnmpla.int. A. Plaintiff and Defendan`. w~~r~~ ma r. r..ied on July 2, 1966 in W.i l l iamspc~r; , P~-~nnsy van is . 5. There have b~~~~n n~ p, :ter ac-ti~ns fir divorce c, r. annulment. br~~wr-en thF~ parties 6. Thc~ Def~~ndan~. i:, net a membc>r ~f the Armed FOrCPS of the Un'.r.cd S tate~ c~~ nC.:r•7 f Am ~ P'..' ~~r .L~..S ~, :r'5. 7. P . ~, ins. f f Ei~~s br.f.n adv.-;ed c,f !.he avai labi.l i.i_y «f: counseling anc' ~.he right- '. c, regtaF>s' . ghat the r-n,rr'. requ.ir.e the part ies to panic- ,, i E3. P:a.in-..f.f and I)ef~~ndan'. ar.-F-~ rt.9.rens ~f the United States j cif Am~~r:i r-a ~ 9. Th+, par•_i+.~;' mn rriay,. :5 irr.~,~.r i~•vably br_ek~~n. 10. Plaintiff desires a divorce and it is believed that defendant will after ninety (9U) days t:rom the date of the filing of this complaint consent: to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree ire divorce under section 201 (c} of the Divorce Code. I VERIFY TIfAT THE ST'A'TEMENTS MADE IN TFIE FOREGOING COMPLAINT ARE TRUE AND CORRECT. I UNDi:RSTAND 'PRAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO T'f:E PI•:NAi.,TIE:S OF' 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICA- 'LION TO AU'I'HORITIIS. J; DATE : ~ /~ 9 &'~ ~/~j ____ ~~ ED K. BALL, Plaintiff ;~ y ` . Griff.re E ui.rr. Griffie & Turo 200 North Hanover. Street Carlisle, Pennsylvania ]?013 (717) 243-5551 ,„ ED K. BALL, Plair:ti f f v. ROSILAND J. FALL, Defendan± I J THE COURT OF COMMON PLEAS ~I C JMBERLAND COUN'T'Y, PENNSYLVAN [~~. C [ V I L ACTION •- 'LAW N 1 l 280 CIVIL 1 985 I J DIVOP.CE AFFIDAVIT OF SRVICE AND NOw, this 8th of May, 1985, cones Bradley ~. Griffie, Esqui~•e, Att.orn<_y for Plaintiff in the above-captioned action, and states that. hf~ I persona]]y mziled a true and correct ropy of a COMPLAINT IN DIVD:"tCE ! Filed in the above-captioned aCtiC7n tc Defendant, 12osiland hall, :339 Pdinth Street, New Cumberland, Pennsylvania 17090, by certified rra~] '~ rct.urn receipt. requested. A copy of :,aid receipt is attached he r.e~to j indicating service was made on May 3, 1935. [irad 1 e~ L. Gri f:~f Esquire GrifFic & Turo 200 ~7o~t.h Hanover Street Car]isle, Pennsylvania 17013 (7171 243-5551 Sworn and subscribed t_o r`C'LO` ~` '~~i~ t_h ~; ,k~~?day of May, 198. /~ N tary^lb, is V/ LF.7GHAt:"J =: ,, „y,a~y Pub iC My commission expires: C3:i:;io, G:•~fi,c,-~~ Cc., Pa. ~~"y Comm:;s~on Expire: Aup~gt 29, 198fl '~ ~~°t . SENDS H: CattWaa iawtu 1, 2, 3 and 4, Put your eddraw In aea "f1ETUAN Tp° wac• nn tM rowrfo a:do, f allure to do Mb aWtl pro^snt MN c r a trom nNt~ roturrtorD to You TM raptr~ rX ~laa will D~CVkM ou !aa nartN or tM son dMhrar ' :o anq tn. acre o~ ,$IN~r~apOlt in9 aMeKlrr M asWtado. ConaWr owttnastw for t and ct+ac~ x.tKl ip wrvkolsT raryueatad. 5. 'R' Show to whom, daa and adana of dNivary. 2. ~' Raatrictad ONivary. ~.,f1n5cN Addy+r~+ 20.~ .~ ~ ~ ~G~t2t.Cl.Lr2:'C ~ ~)~~~1 //~ ~r~ I ~~~,~ l: 4. Typo of Sarweo: Birtkl• NumDar As~t~sd IMUrsO ',nom .;:'"(/ :~_;;'~~ Ctrrttltad G7 COD lll.~3! Expttbw hMi! AttNyt Oblarn Ir~nafutll of adOrt+lLaa~,tlsRrlt atoll DATE DELIVEi~,Q Siena .. AnOr "4pMtUrM -~ AganT ~ ._ `~ 7, Data at DMiiv~ry ," _,..~ ~..-~ U,, 'I ~ ~ ~" ~ ~ ~~ l~h 1 ~ w ~"' ~ d. Addrwaw'f Adarsu r fLQ{tri(, 0 !Y ,, ii µ. z m F' ~~(]~ 2°1 386 RFCElPT FOR CEF~~FtED MAIL r in .r .~ .. ~,.. , ,,. ._. i i. i j , ~ _. i ' i ti I I•:D K. BALL, IN THE CO['RT OF COMMON PL.EP.S OF Flair;tiff CUMBERLAND COUNTY, PENNSYI,VP.NIA ~~, CIVIL ACTION - LAW ', NO. 1280 C I`JIL 1985 ROSILAND .3. BALL, Der"~~ndan~ IN DIVORCE. AFFIDAVIT OF COUNSELING 1. I have been advised of the avai labi_lit~~ of marriage counseling and understand that I may request *.hat the court. requi r.e that my spouse and 1 par*_ici.pat.e i.n counsel i.ng. 2. I understand thar_ the ccurt mai.ntai.ns a list of marr..i.age counselors ' i.n ~_hc Prothonotary's Office of. Cumberland County, which list i.s avaz]ab]e to mF~ upon request. 3. Being so advised, I do nat. request that. the court roqua.re that my spouse and I partici.patF~ i.n counseli.ng prior. to a divorce decree be.i.ng handed down by * hr co+.~r ~_ . I VERIFY THAT THE STATEMEN'T'S MADE IN THE FOREGOING AFFIDAVIT ARE .TRUE AND CORRECT. I UNDERSTAND 'T'HAT FALSE STAPEME;NTS HEREIN ARE MADE 5UI'JEC'I' TO THE PENALT T E;S OF 18 Pa . C . S . ~ 4904 RELAT 7 NG TO UNSWORN FALS I F ICA- TION '[O AU1'FIORITIES. ~~ ~/ ~/ /I `/ ED K. BALL EU K. BALL, I'lai.nti ff v. . ROSILAND J. BALL, Defendant IN THE COURT OF COMMON PLEAS OF CCMBEF2LAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1280 CIVIL 1985 IN DIVORCE AF`F' I DAV I'I' OF CONSEN'P L. A Camplaint in Divorce under Section 201 (c) of the Divorce' Code was filed or, Apri.] 29, 198>. 2.. The mar.riag~ of Plain',:iff and D!~fendant is .i.rr.etr.i.evab]y broken and ninety (90) days have elapsed from the date of the fi.li.ng of the Complaint. 3. I cansen*_ to thr. entry of. a f.ina] Decr.c~c of Di.vorcc. 4. I understand that_ I may Iosc rights conce.r:n.i.ng al.i.mony, d.i.vi.si.on of proper*_y, ]awyrr.s' fees or expenses if. I da not claim them befar.e a divorce i.s granted. I VEF2IFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDS;RS'1'AND TfiAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PF:NAi,TIES OF' 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICA- TION TO AUTHORITIES. f;D K. BALL i ~r , '~ ~• I -.,^_~_,.`._-~._ _1 N_. .'Y. ___._ ___.~-_._. ~,'1l ll:: nth ~ "nf•r* i !I r? ~; ~~.'C .t;l~ ~ ~('i I Cyr ,~-~~ r' ?~ t.}', F, ~' ^~~~(~r~,~ rr~,?~, ,, ., fi <~!'. or. April 2y, ly~s5. +i ! „fr ~ ~~ ~, ;~.~ •, 1; .,~ •vi f•F (>~" t}ie ~'omp.l;t.i nt gar . r.:r -ir i c' ,". .. m• ~' inlay 3, lyt~5. r ,., , , . r,~ ;.; ,;•, r)" • ~ n` ^'' ~ar(t I)r,,'~nr?rrn'~ ~. ~ rr~rtri ~vrth?.y ~~ },r~l'• ,. 't , . . n r'. 't C r, r) ., 1~n . , . Vt •'1, ,~ „- ri ('C•nI^ ~'~}1 (' l~ +~(' n'' ~~1~ I flj' }-~)n I !~nCiD' ~'1':. ~ ~ 'iiir~+.'r:, .;a h.~~ t. .f~.. ' !~~ 1 O;;(` .'1 ~Ttj~;;' CC1nC!'r1'ii n~ "~ j CiOr1,Yt r~ _t'1.' ~ O',. O~ D. rtiLtlr'~,,Y, ~..'.1~I~:'. ., ~r.n: nj• r>~(DCr1;1C':, j.r• T Cj0 r]O~'~ C`i'jl.!'I t.~!r~~ ~)r'. (1' r~: 'Ort:(' L, r;r:!il'.r1C~. rrl ; !~!)T"i;tt,•t' *C) {,i;r~ „' 1•.~ C)t• ^ `•:^'1~ r~C(•rlrr--~ ~"~ r?J VC)T'CE'. /~ 1lnrjr`. ~ 'rl!_' t.'i. ] n` ,i r; Oi' 71.111'IC111y~ ,'1~ l 1:!011;/ :)('Rl~r..-i+. l~li ,~ 1^,'.ri .~1 f1 .'O"r`1.!'V C~1• C'Cl!lr:;'r~l a•r~(~„ ~~1• r..v~t'rj^!':' }1(1:.. Cl("),. 2n'r•r', ~'I r..fj f ~~~'~ ~)%!r' (`r)I11'~, ti)r~llr'r` ~.}tr' t'(11,r~~ nr .. ~l llfl~ d~=?Cr(?t? ~ ~ r~ . A' ,'~• ;i !' r~~t'. f r, r~l 'i i C^. !tl,V !ir `11i`Tr '.J1 ~'. )- }1 t' LOS+:. /',l~ _' 1("~'!, `t'.. fir't.'1`r`C? n~r .ifl r, '1V',1~}1});1;+,y Or 1;IrtT'T'lil.(~P (•r~tjt!t ~~' . n~ :r,r: ~ '~,'!' r ~ • .~? '~ }i•~' ~ t^ 'V rr~tif_•-f~ ';}t r.'; +,Ei~~ court r~~qt: , rF• ';h, rev , , o:~~ : ~nrj T ;)~ r'. i ~ ~:~~pn',~_r . n c~l,.n sr~.lin~. P~~1 n~ ,;,) r,,,t,rl: ~ ~ tlC, nn` j• r~,lr,,,f, +-}~(,'- 11},' ("(,tli•t. rant, ; r!. !}it,a- ff1V .~pou:.. .~ r.~? pr ,•t. ir, i tt.~~,. , ri ~oiir.:i~l ~ i r,~~ prior '; f) ;~ rl . vnrC(' (l~crer--~ T n~~'•tr ~.fif~~, t}-r. ~r.:it;r~,^r_.r~i,^ (^,'fjl~ ire ~,}~,j;, 'If'~1'~1!.V'.~', ,'1T•(? 4T'17r~ ~i rlii!~ Cr~r T lln!'' .. ' fir-' '~'1;:~ r•.~'1 ~.f, .'..ri;t'i'1F'fl`;., }lf?T'':'.1 p ;1TC' r,1;1.lif' ,..1}~. '. .. ~'.I(' nr_rfl'. ~ ,. i•r• ~ ~~ D'f. n.". ,~n('~'.I Clrt l;n~.~ j•C_.171.t".1..r1('. tl) ~~ ~ ~, SAiD]5, t:`;11)O tlfl': ?ri : _1_~..~+_~ .11'~/~..~ 1_~y11:L~.r ~-•j '~e',~~~~`~ ~--~ -~`-~~~=•~~ - sfc MA':: ? ND tire„ . ~ :tp:{ ?3'~i DhfF~;l!?1t11~.fi,,•~.~ 2G W. Hi n ~ reef Carlisle, '';. j ED K. BALL, IN TIII: COURT OI' C0;•1D10N PLEAS OT' P l zt i n t i f f CUb1I3ERLA:VD COU^ITF , PP;NNSYLVAN i A ~•c. CI1'IL ACTION - LAIC '~0. 120 CI1'IL, lE)H~ ROS I LAND J . IiALi~ , Defendant IN nIVORCE I~NTI;1' OF APPEARANCE "f0 TIIE PRO'fIIONOTAItY Enter my apz;carance for the defendant R~Siland J. 13a1I in the above captioned matter. Date : 11;~y 1~1 , 198:"i ~; ~~(,L"7~ ~'L'7 ~iart.i. ~1. Find I.D. #075L7 Att:ornev for Defendr~tnt Prothonotary Court. .~idmini5tratc~r hlaintiff's Atternev I, C[i... _ .. .... ~ n~-..' .ti .. .~ !I'. I JVII~..'4\. ~.C. ~.. . .~, I 'i s *~~, ~~. ~ ,. ~~ 1;U K. I3Ar,1~. IN 'I'IfI? COURT OI~ COMP.ION PL,I;AS I' l a i n t i f f OF CU!t13ERLA`~D COUNTY , PA ~•s. CIVIL r1CTI0N - LAST .`30. 1280 CIVIL 1965 ItOS I LAND J . i ALL , Defc~ndnnt IN DI~'ORCF. NOTICF_ TO DF.FL.ND AND CL.'1ID1 RIGHTS Yc,t! have been sued in Court.. 1 f you wish to defend al;ainst the claims tic•t. forth in the folloti4•inf* p.Ll;e~, }'nu must take prompt act.iczn. You tu•c• v,arned that. i f you fail t<~ do so, the case may Itrocc~ed withc>ut you and n dec:r•ce of d vnree or annu7mr.nt ratty be ~~nt.c•rr~cl ai~stinst you for tray nt;her cl;t'~m or rclic~f renuested i.n the~;e ]~t?prrrs icy the I'ln.intiff. ~'ou may lose money or property or other ril;hts important to you, inc;lud.nlr custody or visitation of ~•c~t.tr c•hilclren. lYhr~n the T;rounds for tlu:~ divorce i~, indilrniti.es or i rrc~ t ri r•v ah 1 e breakdown n f thc~ mt~~ rri tti;e , you rutty request; marriage counsel in l,. l1 list of mar rial;e counselors is ;!vai_lablc' i.n the Off + cc~ o f' thc~ 1`rot,hon<~ta r•y ~ t the Ct.tmk~er7 and County Court Ilouse , Carl i~1e, Pennsylvania 1.70 1.,^>. IY Y OU [X) NOT T'ILl? rl CT,AI51 i'OR AI_,ID10Nti', DIVISION 01' PROP.f;R'CYI LAK'Y1':R' S I~I;I:S OR h~Y1tiNSI;S i3I?I'OR}: A DIVORCI: Oli ANN[JL~IENT IS x~RAN'1'I;D, YOU ~1A1' LOS1: Tlil~; RIGHT TO CLAIM ANY OI' TiIP:nR. i YOI1 SHOTIi_~D 'fAK1': '['fIIS 01tI)I~.R 'I'0 YOIiN. LAIVYI;R A'r ONCE. IF YOU I~ NOT ]IAVI: t1 T.,rlj1'Y1TT OTI ('ANNOY AFFORD ONF , GO TO 012 7'RI,T:P1IONfi TIi OFFIC'[; SP,'I' 1~OR'I'I1 BI?I.,OR' 'I'0 FTND OUT S5'NT;RT~; YOU CAN GF',f T_,I?~fAL 1iFLP. Prothonot:;try Cumberland County Court, Ilc~usr~ C:!rlistc~, P~•nnsyl~•ania 17x1].3 Tc~7 e);honc~ Nri . (71 7 } fi5~7-0371. Snsciuehanna 1.,eF,*al Services :?OS I;a.st S4at;er Str~e.t Lock iiaven, Pennsv]vani•r. 17745 'i'c~lephone Nn. (737) 74,3-9520 ,, _ 13v G~IG(,~ ~ ~. rfart'.n 41. Fine, IJsquire Attort 'y for Defendant I . D.:` 07527 rt,~,~. ~', i ?i ~;~:zi' ED K . CALL. , T ~' '1'Ili' C(~i'il'I' Oi' CO~tr".ON PLA'AS l~ L~+ i n t i f f OI~ C'-'!i[tI'.RL~AVI+ COUNTI' , 1'A vs _ CI1't 1. ACTION - laAlti NO. 120 CI1'I1. 1~tR5 11OSIL:IND •`. BALL, De fendar,t I'd 1)'I4'OFtCi•: A:v`SR'ER AtiD COUNTER-CLAi"1 1. Adrnitted. Defendant resides at ;t3P Fast. Ninth Street, Nc+~• Cr.zmtze nand, Fcnr.sylvania 17070. 'L. Defendant admits Plaintiff and Defendar~.t have bean. bczn~r fide residenr,s in the Commczmcealth of Pcnnsylvar~itz for at least sic mrznthG immediately Prior t<~ filint; of this C'<m+Plaint. ' I i 3. Dcfendan t;+dm i is 1' l a i n t, i f f r+nd Dr. fendar t rzrc not ~. minors car i.ncc~mnetc~nt . ~~ ~1. Defc ndartt a.dmit;s thc~ marriage was can .Jc:ly 2, 1~6G. ;"i. 'There are Prr~sently t.hrec~ mi.nc~r rhilclren who live with the Defendant +vhosc names arcs: i. Gret;c~ry }:. I3a 1 1 A~*e 10 2nd year in co1lc~~e Born 1/16/G7 Gavin I•:. I?al 1 Af*c~ 10 Born 4/].1/70 Genni fer R. 13x11 Af;r 1~l Born D/13/72 i. 6. Dei'c~ndant, admits this action i~; not collusive. 7. I'lainti ff brryu~ht thiti action as of the above term and number in Cumberl,znd Countt•, Pennsylvania. 8. Defendant denies thc• t*rc~unds fr+r divorce set i'orth in the 1>l,iinti ff's Cr,mPlaint. 1YIII?,RIsFO1tI;, Defendant requests Plaintiff's Complaint be i'. ~~~, dismissed. ti;hATl.". A! [INi . -,q..~. , . ~. ~l~~t,.~ lJtir -~ w,«, „9.,,,, ~„ '; '~iart4n ri. FinE~, EsRuire Attorney for I)efendunt ~~~ I.D. X07527 c I;I) K. C3ALL, IN T11I: Cn['RT ()1~ COFil1O!~ PI.I;AS Plaintiff OF Ci.'~rI3ERLAND COL"_VTy' , PA vs. C11'IL ACTION - LAIY ~ Nn. 1280 CIVIL. 1985 i ~~ ROSILAND •J. BALL, Defe.7dant IN DIVnRCF COUNTERCLAIM ~~ 9. 1'he Defendant is Rosh and .J . I3a11 , an adu] t i.nd vi dual ~ ,. who currently rrsidcs at 339 fiast Ninth Street, New Cumberland, '~ I'cnn5ylvania 17070. 0. The Ptaintif'f is Ed K. I3a11, an adult individual n~ho ~ curr.c~ntly resides at Carlisle, Pennsylvania. il. The brfendant has been a bona fide resident of the i Commomceal±h of Pennsylvania :for at least six months immedi.atr'ly ~' preccdinf; the filing oi' this Comhl:tint. i 12 The FLaintiff has been rt bnna f.idc' rrsidcnt of the I; Cammomvcrnlth of Pennsylvania for at Least si.x months immediately ~' ~ precedinf; the filing of this Complaint. I ~~ 13. Defendant and Plaintiff wc~rc married on Ju1p 2, 1966, t1 in Pennsvlti•ania. i'~ ii 1~1. Th~~rc has i~een no prior actions commenced for divorce or annulment oi' marriage he.t,ween the parties in this or any other ~~ ' jurisdiction. ~; ' 15. The Defendant; has bean advised ni' the availo,biJ.ity oi' cotrnselin~ and the Defc~r.dant reco~ni~es she has the riF*ht to request this Honorable Court: to require the parties to '` participate in .:ct:nselin~~. i IdART:N N Fi.yf ~~r oni~e- •tnta~ I.,. wow w•..,,q, p. .. t I COl'NT I J ~ DIVORCE: Section 201(c. i ].6. i~ara~:rtcphs 9 throucrh 15 inclus;ivc rim incorporated ;~ !' herein by rei'c~rc~nce hereto and are maclc~ a part hereof. I; '~ 17. The marriage is i rrt~trieaably hrokc~n and the parties are !,~i estrtcn~;ed clue to marital difficulties with no reasonable expec- ~' tat ions of rc~con<• i 1 irrt ion as provi clod by the' Di vorcc~ Code of 180 , i !', Sc~c t ion 201(c) . 18. The Defendant requersts this Court to enter a Decree in ;~ i` Divorce. I'; i' i' COUNT II i~ n ~~. DIVORCE: Sr~ction ^01~r?? (1) f ~~ ____. i, ~~ 19. I~nrah*rnph5 ~) through 15 inclusive' arc Incorporated herein ,II by re}'erence hereto and are made a part hereof. !' 20. Defendant reduests the Court to enter a Decree of Divorce ;~. j CO(?NT III t ~; bIVORCI Section 201(aZ (6) i ~i '„ 21 . Para};raphs 0 throu};h 1~1 inclusive are incorporated herein ~ by reference hereto and made a part hereof. 22. In r•iolation of thc~ P1ai.ntiff':~ marriage vows and the I'~ '~ la•.vs of the Commonwealth of Ponnsy]-vania, the Plaintiff has offered such indi};nities to the parson o the Defendant, the !~ innocent rrnd inured 5peusc~, as to render her condition into- M:,R7iN M. FINF. i A-t Cw.af• A` t.Aw i1 1 lerablc and Iifc burdensome. Wll'_IAM S•~OP' r• 1''~_I I' I' `I II m- e„- 4 23. This action is not collctsiva~. '~ 24. The Defendant requests t;he Court to enter ~ Decree in i~ Divorce. ~~ ~i ~; 'i COUNT IV ~1 EQUITABLE DISTRIBUTION OF PROPERTY j 25. Paragraphs 9 through 15 incluGive are incorporated herein by reference herc~ty and are made ,l part hereof. 26. During thc:~ courses of this ma.rr.iage, the parties hereto have accumulated certain items of personal property, which pro- ; perty is subject to equitable distribution by this Court. ~, 27. The-~ Defendant requests the Court to equit,nbly divide, distribute rind/or a:sign t}:c mar.ital property of the parties. couNT v ~II,I`~tONY PE7~DE:dTE LIT?'t REASONABLE ATTORNEY'S FEES AND COSTS OF SUIT I~, 28. Paragraphs 9 through 15 inclusive are incorporated herein II by rcfrrence hc~rc~tc~ and made a part hereof. i ~I 29. Th<~ Defendant i:~ without funds to support herself and to meet t:he co t5 a.nd exper.se5 of this litigation and is unable to maintain herself di.7rinn t;he pendency of this action. i 30. As a result of thc~ fr>regoing, the Defendant requests I! t,hi:~ Cc,urt to issue rin Order ru~~arding her a7 imony pendente l.ite l~ j' and directintr thc~ Plninti ff to nriy Defy ndant's counsel fees and Cast:,. MAF7riN M F~NC I~ ~,. nn+r.• .aw I~~, •21 rte.; w. ••nlf• it li i~~ ~~ ~~ CO1'1'1' ~'I ~ ~. ' i ALI>?OAF ~;, I'arat;rar,>h~ g through 75 inclusive are incorl?<,rtttecl ~ herein by reference hereto and made a Dart hereof. 32. The De fendan f. 1 asks suff i ci cent propert}• , i ncl udinl; , but nr,t. l imi tied to. the }-property to be distribtztc?d pursuant t<, Count IV of this Cc,m}tlaint, to provide for hc,r rr~asonable nreds and 'i_5 ; unalilc~ tc> su}~pc>rt hc~rsc~] f t.hrau~h <tpPropriate c~mploymc'nt. .',3. Thc~refc~re, ;7c''c~ndant rc7uests this Court to determine the nature, ar.iount, duration and manner of payment c>f <t.l.im~ny, purtiuctnt to Sc,ctian 507. oC thr Divorce Code oi' 1.980. 1ti}II;12}:FO}3E, the I~r~i'c~ndttnt rc0ue~:ts this Honorable Court to: ; t1. Enter an Order dissolving: the marriage between rhea two ~~~ part.ic~s, I i 1;, Fnt,or an Order diroctinl; the Plaintiff' to pap the 1)c~fendant rci im<~rrp g>c~ndc=ntc~ 1 i to during' the pendency of this suit rind to pay the }7c~fendant'~ counsel feces and costs of this suit. C. Enter stn Order c~duita.bly distributinf; the real. and Ij pcrsc,nal marital propc~rt}• of the partf.es. h, }~;nter an Grder ~twardinf; the Plaintiff permanent alimony in th~• am<,unt, nature and duration as this Court determines just anti rc•a~onablc~. F.. Enter an Order rr~lative to such ther matters pertaining tic, such marriaf:c .,r.d clivr,rce <tuthc,rizes by l.aw and which fairly •~ ~ and e~prditieus1y mad- be determined and disposed of by such act. • btart in "1. Fine , Fs~uire - Attorney for Derendant .`~ I . D. #07527 COMMONWEALTH OF PENNSYL4ANIA SS COUNTY OF LYCOMING ROS I LAVn .T . BULL , being duly sworn according to law, deposes and says that the facts set forth in the foregoing Counter-Claim are true and correct to the best of her knowledge information and belief. 1 r~ ~ i ~ ,l / ~~~ r osiland J. II 1 Sworn to and subscribed before me this ~~r~ ~ day Of f~11~T,115t ~ g $J /,~ - }' COrf1m15SlOn eXDlrE?S Jule 27, 1987. r ,..~:i~t:~ ~.cn'^:. ,,.: ~}:rtvTct. i-,5 ~ _ „ _ •_•• _ i Answer and Cotinterclai.m ;r~~, ,, . _ .. ~~: ~,`G;i Piainti ff's Attorney ~ .. . , _~iE~ c! ~,. i•. ;_il.,. _ ,.'!'.._ C'~[ ~)' "iCit' ... ,f:f' ..1 ..C'.} ,~t7tC'^+ }}1}'1 x'10^t~~~.C }l 1 R ., X Xi7C~YLY' ,, . , c~ r r, , ~ . ~ .. ~ . .,.. o ~~,,:'~,i, T3radley L. Grifflc of GP,IFFL3~ &. TIJRO, 200 North Ilanover Street, Car]islc, Pcnnsy7viinia. X7013. btartin ?.i, fine, P;s~uire O ' . _ ~~ - ED K. BALL,, IN THf; COURT OF r:OMMON PLEAS Of~ Plain'=:ff CUME3ERLr1ND COUNTY, PENNSYLVANIA vs. CTVIL ACTON - LA4J RO5iLAND J. BALi„ NC. 1280 CIVIL 1'985 Defendant IN DIVORCE t?NSWF;k TO DEFENDANT' S ANSIn'ER AND COUNTERCLAIM ... Admitted. 2. Admi~:ed. 3. Admitted. 4. Adm::.ted. 5. Admitt^d. 5. Admitted. 7. Admitted. 8. Denied. I~ is denied that Defendant has in fact denied th~~ ,qr~+und f~~r c.iivr~r•~c~ set f~~r '.n Plaintiff's C~mp7ai.nt. in that Dcf:endant a 11e~7es thr~ same grrn~nds in her Counterclaim filed in this actin. ldflf,Rl?f'i~IZf:, Pl~3intiff r~~quest5 your Honorable Court t~ enter a divnrc-e undf~r. Section 201 (c) of the Div~r.ce Code. 9. Admitted. _'0. Adm:.~~ed. ~. Admitted. '.2. Admi`_~ed 13. Admitted .d. Admitted. COUNT I _6. P?~~n'_~ff', ~~nswers to Defendant's paragraphs 9-15 are incor- posted her.~ein by ref~~ren~:e as if set_ forth in their full text. _ 7 . Adm . t'_ed . 8 . Adm i '.' ~~d COUNT I1 ~F~. f~ic3LrltLff'~ dP.SiJF`L"~: `:.n D~~f(`RdaR~''> pijrdgC'a~tl:+ 9-i~J dCE' 1RCnY' r_nt~atr'd h~~reir~ by rr•fs•renr'c~ as if stmt firth i.n their: f u. 1 text. 2U. 1,dmi'.:ted. COUNT III 21. Plain'iff's an~:wers `_~ Dr,fendan'.:'s paragraphs 9-_.~ are inc~r- pF~rated her.~in by ref~rc`n<•,` as if sc`t f~r.th i.n their fu'.1 text. 22. Dc~niF~d. (t is denied that Plaintiff' has F:~mmittrd any indiq- unities whatsr,eve~r rc~•lative '_~ Defendant. It is further denied that ~,Dc`fendant is the innocc`nt and injured sp~usr. 1t is further denied `_hat thy` Plaintiff has dine anyth.inq to cause Dnf.cndant's rond.itiorl to b~-~ intF~lrrab]e rand i fe burdF`ns~mr`. ?.3. Admittr`d. 24. l~dm:.ttF~d. COUNT IV 25. Plai.ntiff's answers ::~ Def.endant's paragraphs 9-a5 ar.e incor- L~nr.atc`d herein by referF~nc,:` as it sc`': firth in their. f.ul7. text. 26. Admitted. C'QUNT V 2R. P;a'_n'~iff's answr.•r.s to Defendant's paragraphs 9-15 are incor- ~~'pnrate`d herein by reference as if set firth in their full text. 29. Denied. 1t s dc`nied that Defendant is without sufficient (funds tF~ support herse:f and/nr to mee'~ the` cysts and expenses of litiga- `__inn and/nr. ~.; unable to maintain herself during the pendency of this act~nn. 3r}, D~:nic•d. IL is denied `.hat ..hc' Defendant is «~nttt'.e.d to an Order fnr a'_imnny penden'_~~ _'_'.:<~ nr an Order fc,r counsel fees and costs. 'It is av•~rred rather that Defendant ic; gainfully employed as well as i ~r;-;r s~,'~ owner of t~='r~a~r; va:uab'n assts which a"_nw her a cnmf.~rtable ~ financial support ,t:, wr~:l as arcr~ss fc~r funds fnr counsel fees and CnStS. COUNT VI 31. Plaintiff's answe rs to Dc•fendan`_' s paragraphs 9-15 are inc-nr- ~pnr.ated herF~in by r•F•fr,rt,rtr-F, a:, if scat: forth in t.heit' ful] text. 32. Denied. It is denied that Defendant lacked suftic.ient property stn nrnvidF~ for her rcasnnablc~ needs. It is further. denied that Defendant 'lacks sufficient property to be able to suppnt•t het.sF~lf. It is furthc~t: denied t hat D~fer,dant has b,,en unable to obtain appropriate c'mplc~ymc~nt ',:o supper.` hc~rsc~]f. I: is i.s av<~trod rather. that: Defendant has suff.:.cient property to prr,•/ide fnr• h~r.• rr~asonable need, and i.s further' gainfully 'k~mplnyed at this tirn r~. 33. DEnied as Stated. TL is admitted that Defendant has made such a requrst but denied ghat Defcndan`~ is entitled to any alimony whatsoever pursuant to `hn Di.vr~rr-c• C.nde of 1980. tPHE?REFORF;, P]aintiff reques':.s this {lnnorab].e Court to enter an ,t,rder: dissolving `~hn p_rrtios' mar.ri~rge and enter. an order equitably uividing the part:ios' property, while at the same time entering an ~'~.•der dism:.ssinq Defendant's .aim for alimnny~ counsel foes and expenses. t, ~' Rospec~tfu].]y submitted, ~' Bradl y L. Gri ~ Esquire I ~'i Griffin & Tur ~' 200 North Hanover Street. Ca r.li.sle, Pennsylvania 17013 t7'7) 243-5551 I VER I E•'Y 'T'HA`I' 'I'EIE S'I'ATi:M~~'N'I'S MAD1: I N TN}~ F(.IRE•.GO I NG ANSWER ARE TRUE AND CORRECT. I UNUERSTAiJD TiiAT E'ALSF. STATI:MI:N'E'S 1!L•:REIN MADE ARE SUBJECT TO TFIE PENALTIES OF' PA.C'.S. §4904 RELATING; TO UNSWORN FALSIFTCATTi)N ;~~ AUTFiORIT~ES. `. / /~ % / /, / .DATE : J U~~7- ~S- .~._. , ~C ~ ~~~ ' .~ CEniirlED TFi!~ COPY ED K. BALL, Plaintiff vs. F:OSILAND J. BALL, Defendant AIT~~~:^;;Y F+'~ f'L~;,~^,TIFF- .~ IN TFiE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, P:ENNS~'~:'""IA N0. 1280 CIVIL ACTION - 1985 IN DIVORCE INT'E Ri2OC;ATORIE~ PROPOUNDED BY DEFENDANT TO BE ANSWERED B`I PLAINTIFF !~AHTry ti~ r ~Hf :, - , ,.,, . ~F. w,~~:,,,,..,.w. TO: Ed K. Ba11 c/o Griffie & Turo, Bradely L. Griffie, Esq. 200 North Hanover Street Carlisle, Pennsylvania 17013 Enclosed herewith arc Interrogatories propounded by Def^n- dant to be answered by Plaintiff, under oath, within thirty (30) days from the date of service: hereof, pursuant to the Pennsyl- vania Divorce Codc, the Pennsylvania Supreme Court Rult~s and the Lycoming County Court Rules. tJe request that a cony of the An- swers be served upon all counsel of record. Each Interrogatory hereinafter set forth not only calls for the knowledge of Plaintiff., but also for all information that is available to Plaintiff by reasonable inquiry, including inquiry of any representative or attorney. These Interrogatories shall be deemed to be continuing. If between the time of your answers, and the time of the trial of this case, you, or anyone acting in your behalf, learn of any additional information not contained inyour answers, you shal]. promptly furnish such info r.mation to the undersigned by supple- rnental answers. If objection is made to any of the following Interrogatories or. if any Interrogatory i.s not answered in full, state the spec- ific grounds for the objection and answer such Inter.rogatary to the extent to which there is no objections. Zf privilege is al- l~ged as to any information or documents requested, fully identif A the information or documents for which privilege is asserted, stating specifically the grounds for each such privilege assertec Failure to films a written ~'lnswer to these Interrogatories within thirty (30) days could result in sanctions being entered against you, which could include dismissal of your action or claim. ~-' ~ ~~ rti Margin M. Fine, Esq. I.D. # 07527 ' 1 1 I~ I ....1 ... r I! a. 'I .. I•. ~ ~•~ ~{ 'i {~. r. ~~ 1 r jllr .r aa~~l(:• l'. .. tier. r ~ .. ~1 ~. ~ l'.. i 1r._i.... ~• c. The nar.{e anal rc•lationshil~ to you of rnctil person rc:si.dinc~ with you; . d. Yaur eocial sccurit}• nur{bcr; e. Your age and date of birth; f.. Your present and past military status; 2. State your residence addresses from the time conm{encing three years prior to the dates of the marital offense or cause of actior{ charged in the Con{plaint, up to the present time, indica- ting periods of residence at each address. 3. State ttio name, agF~s ar~d birthdatc~s, and present addresses of all children born or adopted during this marriage, incticatiny who has custody of each dependent child; whether any dependent child is in need of unusual or extr rlinary medical rare or mental care or has special financial r :ds. 4. except far your spouse and children, do you have any other dependents? 5. I f your answer is ir. the aff irn{ative, for each such dependent, state: a. T}~e dependent's full name and address; 1. I (,1. '1':' dI1!!")L1Tlt. :~~ n~onE`}' C"{t)r'ii')^(~ l~}~ }~:'U j'":. S;~Ciil' }I ]. 11 °iU+)~~ff~ t. 01 'ICIt Un(~(•11r~(~rlf ~ e. The inc:on+e (taxable and non-t~+r:a)?le) received each month i~}~ or nn ixrhal f of the dependent inc.l udi ng an itcn+izc:d descriF>tion thcrcaf ; 6. Are you, or are any of your dependents, presently or within the past ten (lU) years under tie care of a physician, psychologist, psychiatrist, chiropractor, therapist or other health-care provider? a. The nan+e, address and telephone numb;,r of each health-care provider; b. The date you or your dependents first consulted or were seen by any health-care provider for your medical and/or emotional problem; c. The last time you or your dependents consulted or were seen by any doctor or health-care.- provider for your medical and/or emotional problem; d. The r,~edical diaynosis and proynosis of your ox' your dependent°s condition; e. Havr you or any of your dependents, within the last three (3) years, taken any prescription medication pre- scribed by a doctor ? ~~ j) 1 ~ ,~ I 'i 7 i i ~' 1 ~..~, ~ I ~'. ~ - ~ •~' i i. .~, i,i t~r1!1~ ~. ., ~ .. .. ~ ~. ' ~ l_c1 i Ll'U t ~ i '~'i ~ ~ _. ~ h. 1 t" :;o, ~•' aLc the t3at.cs of hus~~i t~ilizat ion, the rc-~ason for ttic, hosi :liz4~ion, the date of. di.:.,char-ge rind the c' actor prir.:arily re~i~~nsiblc for your care during the, hospital- s ~-ition. i_. S*_=ite the sun: or. suT;:s of money expended by you for all of 'd7e above health care and the portion thereof, if any, that was covered by any type of r.:edical/hospital insurance or any other tyNe of insurance. f3. List all cr,~ploy^rs and/or jobs (full and part-time) that you have had during the course of your marriage. 9. Fvr each c~:ployer and/or job, state a. The full name, address and telephone nur,~ber of your employer; b. The date you con:nienced your employment; c, Your job title or position and your duties and rF_S~OT1S1b111t1r5; i I ~~ d. Your ~:ployee or payroll number; i e. The nar,:e, address and position of your irm~ediate supervisor; ~I ~' I~ 1' ~~ ~'ii: ~.:`•.,~ t'ri'.,j }:.i VC` 71:j l: 1 f 1_'il C11 UL d.I c'~'~1'.}.Gy'iil~"`rlt cur~tl:act~ wi..:: y:, .: ..,_:ri .. _~l.uj _. h. T` rca:~on for termination of each job. 1L. 1~re you or ware you compensated on a straight salary basis for. each jab held? 11. If your answer is in the affirmative, state fully: a. Your gross salary per hour, wecY, or month; i h. Tho number of hours pe::r week that you normally work or worked; c. W}rether you reeeive or received additional compen- sation for overtime work, and if so, the rate of pay received for overtir.fe w-~rk and the average number of hours of overtime you work or worked per week or month; II d. The dates on which you are paid for both regular ' ', and overtime work; 1 I ;, e. The amount of your gross earnings to date from ___, t}~is source during this calendar year; f. The arlount of your gross earnings from this source for each year that you have been csrlployed; -r . -, ., i! i tI ~!1 .~: ~ ~ ~r ~i',_ ~. v.lt r. ;or, T I ~ "~ t,~' ~,. I~~.., IUD InPr- VI ~; c~ .~ _ _ .-,.:i.:..:,~, , .:~~~ :~ ~ ti,`tr` ar,ri ~, ~~1:-y i~ ., t, rl~,- ..i, C ' j ~, _. 2. illness; 3. disciplinary action; 4. inclement weather; 5. seasonal lay-offs; 6. absence for personal reasons other than illness (~.~cplain) ; ~. The exact amount of your take-home pay for each of the past 15 pay periods and designate the pay-periods involved. j. The ar,ount deducted from your gross salary per pRy period for each of the following 1, federal income tax; 2. state income tax ; 3. social security contribution; 5 M r~ b . i ~ .. i ~ .. t'-1 7, p?'Ol-1L"Stlai ll:J plan or uLher ret.ircn+~~nt plans; 8. union dues or a~sc~sn+er.tc; 9. credit union payn+ents (give details); 10. wage assignr.+ents (give details) ; 11. charitable contributions; 12. savings plans; i s i 13. En+ployees welfare fund; 1S . any other (specify i.n detail) ; ~~ 1 k, i4hat benefits does your en+ployez (s) provide for you and your fan+ily? Please include, b t do not limit your answers to, health insurance, life insurance, any pension or profit--sharing plans or retiren+e:it income programs, automobile usage, c~cpense accounts or credit cards, disability benefits, etc ~! , I~ f i ~. 1. ;.~:_' ~II::C ^f. ;, L;, il_! tI~UtCC: 1)V y,.+U tU C~1C~1 SUCH plan; 3. L}~c c~~rrunL valt;c o~ your account unc7cr each sacir nl<rn; 4. the named beneficiary; ! plan; 5, the Hance and address of the location of eacYt 1.2. From your present a~~ployment as answered in previous interrogatories, are you partly or fully compensated on a com- ~ r,rission or other incentive basis? ~ 13. I~ Lire answer to t}~c preceding interrogatory i3 affirnr alive, stata the antlual conu,~ission received for each year of t:nrpioyment. it 14. If. you owr: any par~_nership or proprietary interest,, state ~~ a. 'Phe value of any inventory or business equipment) b. ThC date and amount of purchase of such inventory or ~.~u ipnrent ; 1 ~.:. I 7 i~ 1 ' ._ .. ~ • i. ~. ..} r,...~ i ~1~ L) Ul` C)~. F~EtC'}. 21_. "1 a~ t}~•::~~_;;~ 1 }i~,t? U[1 th^ ~_l t;': `-; C)1 ~i (_;Ci ~i tP ~_ i 15. Ar~• you nor., or ha~lc~ you ever fix: en <zn of f. i cer, cli.rrct.,r or L>artner, (lir,lited or general) in any corporation, firm, part- n~rsiiih, or lir.li,~cti Vi::rltUrC? If so, state a. The nature of your ownership interest in such business; i b. The position held by you; ~. If officer or director, the years you held such position as officer or director; d. Compensation received from sucrr business interest; ~~ ~I e. Ccrlpensation received as officer or director; 1. t;. Lo you or your far,lily have an ownership interest in any other corporation, partnershif~, proprietorship, or limited venturE If so, state: Ii a. The nature of such interest; l b. The market value of such interests; ~~ a •. ~ b II ~?' ~ d .. 1 t ~ r . ~ - , Ir ~i ~~ ;~i ~ ~~ ,... ~.: ~ ,. . r - ~, ic~;r ~ ,. it i-~ - y-.,~.r-~;, _. ,. fv; ~.~..I~ .. ` ' r ~ ,~ .,~ , ~., l}:~ datC o~ ~~. •}. t r r;.. ~ i i n.. v- v+~.~rlr~l~Pli~~ > ttterc`~' , b. the a:,rount of sale:; F}rice l ~1y~lble to you; c. the ter;:;s of oath ~~yrecrnc.nt oI. Sale; 18. For each corporation in which you function as an officer or di.re~tor, or any business entity in which you function as an owner, please r.take available for inspection with regard to each corporation and partnership: a. The stock ledger Y~ook; b. The corporate n;inute book; c. A list of all officers and directors; d. A list of all partners, general and limited= e. Tho r.rost recent financial stater.tents~ including balance sheets; f. The books of original entry, including but not ].inlituc} to t;trL cash disburser.tent journal anti the general ledger; g. Copies of partnership, corporate and income tax returns for the last three years; li ~~ 9 r. 1 •~ .1 j sale ' j. Copies of all d~c~l~, ra -Lyagca, ~u.rccr,lr .: of. , a:~c} oLhr.r docur,~ents PPrtainiZg to th~~ ass~t4 ownc:cl Ly any busines~ er.tit.y i-:, w~;~ich you have an owner.slii.p i.nter.est; k. 1111 correspondence, r~cmor~~nd~~, and all other orriti.nc~s pr.rtaining to any real estate which is owned by any business entity in ~Jhich you have an o~~mcrsY,ip interest; 1. Copies of all pension and profit sharing plans; n~. Copies of all deposit slips r,iade by each corpora- tion or partnership to the business account; 19. Uid you receive any other earned income within the past five years? ~ For each such income, state i a. The amount of such compensation; b. The nature of the 4x~rk performed by you; c. T}ie narie and address of your g:tployer where applic- able; 20. 11re you entitled to receive any names from any Defer Cor.lpensarion 1lgreeruent? t7. i'i7:r E,,i; I.i~.~ .~ir~;ii~:•j ~uCil ~~~~'a~~',. ~~~ • I c. 'I'hr: a^;nur:!. you <-~re to rc~c~~9 vc under such ve~t~rreQ Co:.~~ens~:~.i.c,n i+grcc~n;cnt; I it 21 . tare you racei v .nc~ ~~ny roy~t.l ty incon~c? III I f' so, Eor eaclt such incar~e state ii a. The nature of such income, including the nature of any cun;penscttian, ~,x~rk, or patent fror.; t•~hich such incor.;e arose; b. The amount of such income yearly; i i x i 7 1 c. The terms of any agreement in relation to such compensation, work ar patent; 22. If there is a wage attachment or other order to pay out of earnings effective against you, state how much is taken from your earnings each week, for whose benefit, and what is the balan e; ,I due. • ' 23. Please list the name of your: j. a. accountant (s) ; i -; q; '~ 4` b, stockbroker(s); c. investment advisor (s) ; _ _ II „ 1 ~ r 1 1. 1~ ' 1 ~i ~ ...~ Ii~.,l ~.~ ~ ~~• ~1. ,. t' 1 ~- Iii, ~ ,- l 11 i ~ ~ (yr ~ 1.1 j i :~ ~i ,. - (' ~r I '-• ~ ..~ ~ ~ ' f ~ I'. ~ .~i ~i 1.1' . 1, .. b, ro;;r~ filcu in; c. Naples and acidres es of attorneys for. each party; d. Nature of determination or other results of each proceeding; 25. State the total ar,iount of money per r,~onth expended by you for the support of yourself, your spouse, and children for *~e last three years; 26. If you contribute to anyone's support or welfare, not previously rlentioned herein, please state: a. The name and address of those whorl you support; b. Their relationship to you; c. Amount and freduency of support payments; it d, t•7hether voluntary or by Court order;) e. Nar,~e and address of Court and every attorney involved; 3.2 I~ 1 `1 ~ II Iii. `..;;1•'F' ~".t7" :.1;C':, d:,I,l 1r'~,.;t1~.7<>flti C)f ~.'.:j' C1112.1.~, `uOC.'it i g~"Ct; f!t 1. ~' UI~ (l`~.Ilt:'7 W] ', tU W~7Ctl :%'.l 2,j~~n(~; Aaso, for cac.h c177b, state: a. Thc~ initiation fee for e<~lc:h; b. The annual fee for each; r. The ar.iount of additional n:oncy that you spend for each; 29 . List any gifts or contributions n:a~3e by you in excess of t'rre sur.~ of $100.00 within the past three years; F'or e~~ch such gift or contribution, state: ~~. The name of the donee; b. The reason fcr :,uch gift; c. Ttie amount of such gift; rt. tr;hether or not any gift tax ret" rn was filed in respect to such gift; 30. Have you r:ade any application for indebtedness within the past five years:' 13 i .. ~' .. - ~ r ~~ t, ~I c. 'iiu~ pur~•us~~ £:~r table-}; ~:,,~•l~ ]~~~n t.1s rec1uestec~; c3. Tiic~ di.~-T>o:~ition of such ~~i~}~lication; e. Please attach a coF~y of each such application to your anstrers to these interrocJatories; 31. List all safety deposit bo~:es otnu~d by you individually or jointly with another party or~any other safe deposit kx~x over which yeu have accF~ss. Y~'or each such safety deposit box, state: a. The location of each such l.~ox; b. The number of such box; i~ I c. Whether the box ~~ held individually or j~.intly; ~) ~I d. The contents of such box; 32. List all personal credit cards owned by you individually or jointly with another person. iI I ~ ' i • .~ i , ~.. ., t, ,. ~, f( u ~ c~. '.h~~ current- };.:.i<:r.c:~ ~.:L.1 u;.~n ~•<<;.:li ~~~+~}r card; c}. F'lr.a~c attac}r your n,anthly sta;:ct;ionts for the last j thref~ years fc;~ ~aclr card; 33. List all savincfs, cor,s,ercial or chcc}:ing accounts in your. name, solely or jointly wit}t atrother, wLth an}• bank or financial institution: F•'or each account , sty-rte a. The nar.~e and ac:dress of the bank or financial insti tut.ion; b. The tyre of account; c. The nar,~es on the account; d. The person authorized to draw on the account; e. The date the account was opened; f. The date the account was closed; -'~ - i5 - ~~ i !! ! , '!'~ 1 i l~ U'. rI ~ ~. t.~ ..t' cr~.'i.~~„'!. . _: t.., r1i~ 1 ~ .i., ,.. ~ .'I ~- ~, ..v.. i! t ~'. ... t r .. ;I' . ! ~~ l 3't. ifave there ~Y,~,n ~?nv kx,u}: ac:~•c,unt:: during thr course ~ of yoitr :! r ic,c~i: on wh.icl: your n~tn;^ did nut. al,I~ear, in. e:h.icl, • you d~'I,~acl ter! money? ~,. '1'lu, name z,nd address of tl,c' l~~~nk; r I.,. Each nanrc under which the account stood; c. The account number; cl. The-. apj:'roxirr.ate date and amount of each deposit; e. The reason for each deposit; 3~. Have there been an}• bank accounts during the course of your marriage on which your nar.,e did not apF,ear, tit frorl whi ch you withdre~l money by check or other. rrett>,od? .~ If so, for each suctr account, state: a. The nar,,e and address of the bank; .{ .' ' :; b. Each nar.re under which the account stood; c. The date and ar.rount of each withdrawal by you; _ i i ~ - 1 ` _ _-- --- ~ ~ . , , ..,, ..u 1 . . ,. , _.. 31,. ~.~ 'j .. O".... _:f:UCr; 1 , i:F:7._i~1~ ~It~FC. :iF~ll('$vi Lllr' 1 ~' ~~ ~~ ~: o, for ea::h srnLity to ~rhich you u~m ., ~clF security, ~? cas~• st~lty a. Thc~ nalFF~, of `~:le cor}:oration or the is~:uer; U. The nu:~lber of shams and the f.acc~ ~u-Fount of sucI~ security; c. Th~~ date such security was }purchased; d. The maturity date of such security, if ap}~licak~le; e. The ct;rrent r.tarket value of such securities; f. The dividends paid by each such security for each of the last five years; 37. Are any of the shares of stoc}; ocmed by you listed in the preceding interrogatory subject to any cross purchase or rederl}~tion agreement? ~ of so, state ~1 a. The date of such agreement; I b. The parties to such agreement; ~i _ 1 +r i ~~1. StltP L/fi~-'~~L'Y j'C?u k~l~~^ I'".~" rln,1• ][l`!t.`~'-P.'.`•Tlf":7 Cyr $.IOI).U'1 OT iiiU~C dLI]`.l il`J tt1^ CnLtt-:;n U~ }'1'.(L' 'r".L<IrJI'. ` Tf so, plc-rase state: a. The type a,~c3 name bf the investment; u. The date ~f acquisition; c. The value at the tide of acquisition; d. The consideration; e. The institution or person with wtlorl the investment cvas initiai.ll placed; f. The date of disposition; g. The value at the tir,ie of aisF~osition; h. The amount of rloney or outer consideration realized at the time of disposition; i . What was done on t~l the proceeds or other considera- tion . ~ , ~~ . _ ,, ~,,: „=: ,~ y ~.. ,'. -- s. -_ '~'',~ o o° , ... . ,~:~ - .. .. .. ,a:..:.. .._ .. ,.. ~r.. b. The date of maturi ty of s~2rli i ~i~Li w~.ie~~t ; c. Ti:c ar,~ount of interest F,ay~~h.lc~ to you yearly under. such ir:struc:~etit; d. the nature of the sale or transaction (type of r.ierchandise sold) from whir.h said instrur.~ent arose; e. The date the instrument was ac~~uired by you; 4U. Please attach to these interrogatories a copy of your current financial stater.~ent. 41. Have you at any time within the past three years re- cei ved any i.ncon~e, dividends or return of capital from any corp- oration (close or professional) in which you gave a 5~ or more own•.rshit~ interest? 4?.. Iter,iize all incor,~e benefits, cash and non-cash, not alr~~a~ly included in your answers to any preceding interrogatory, ~ suc~i as, }x~t not limited to, pension plans, annuities, inheri- I tanc~s, retirer.oent plans, social security benefits, lottery prizes, bank interest, dividends, etc., and for each, please .list ~ - .._ . ~ a. Source of the benefit; i ~~ - t ~ - '~' f' , ,7 r; c., t' r' .~ ~ ..~ thnut (t 1ii~`-inn tc3 r'S'nri+++~~~, ,lea: _ ~_: .:~_.;?~ co; is .. c,r at., ~~1~.::,.; i 43. Dues or }k+~: any cord,oration (in ~rhich yc, oc:n at leasL- ~`~, canership interest) , partnership, joint venture or s~ 1c pro- prietorshi~~ referred to in t .c preceding interrogat~,rie:; ~r do or have you individually or with anyone else now hold or have telct any interest in a,iy real :-pro}~crty at any time during the: ;,ast thr~~c years? (Interest in real },ro}-crty as used herein shall n+ean any- interest, ec~uitaY,lc or legal, whether or not of record, whether or not expressed in writing, whether contingent ar vested, w~iether executory or not, and shall include any property interest t~rluch may now be under T,green~ent or. oj~tion) . 49. ~f your answer to t}ZC preceding interrogatory is in the affirniati.ve, state fully: a. Ahe nar,ie and address of. the entity or individual in whose nar+e tl~e property is titled; b. The address and legal description of the property; 45. Does or has any corporation (in which you oem at least 58 ownership interest) partnership, joint venture ar sole pro- prietors}tip referred to in the preceding interrogatories or do or leave you individually or cvith anyone else, leased or rented any property or part of such property :.o any person within the past three years; (Proper.ty shall be defined as .in interrogatory nur,+be r 4 3 . ) + 46. 1f ycur ansi~er is in the affirria :eve, state fully: (~ II a. The nar,+e and address of flee entity or individual in whose nar.+e the property is titled; - 20 - ,; t ~? `~ i- fi !~ • ..,: ~ ~ ~. ; v, ~. c~i l~. ~~~,~~~ , ,j / . ;ias: ~,:',•~ .,•,t i r~rr~t,~r~•, i~~fi~rt'c•ct tc, :in t.lt~~ »re<'eu i ttcl in±, rrc>clrtt ~., .. }^,~•;; ~~ r; -~r otli.~, .: i s.._ Y]-(in:+<<~rr~~d ,lur-7 tt~ th•~ mast LitL~~~ yuai~? 4ES. Tf your. an::wer is affirr.tatJvc, and if not held by you, ici~~nti.fy the entity r;a};incJ tl» sale or. transfer and state fully: a. Tate address anti Ieyal description of the property soJ.d or. transfcrrc:cl; b. The date of the sale or transfer; c. The name and address of each person receiving an interest in the property and ttte interest acquired by each such arson; d. The purchase price or other consideration received for tt?e sale or transfer; e. The amount of t~1e purchase price currently unpaid; A9, Does any cor,toration (in which you oam at least 5$ ownership interest), }~art-nership, joint venture or sole pro- prietorship referred to in preceding interrogatories or do you individually or with anyone else have anv agreement, written or oral, to purc}>,ase, sell or otherwise .cquire or transfer an interest in any real property? - 21 - . i r ~' • ~. ,irj... .. ~! t t) • . . .. ~ c. Ii 1_i u' ay~i:ur.,~.nL icy rr,~•:~rcl~,d, tl,-~ ~t-atc and county of r.ecc,rd~.n:j; d. 'lil~• ~~c~-r::~ a.^.c3 con~;i t.iuns of thc~ ~~rr~E:~~;.~~~r,t; ~. The nac,c and address of cacti person ~~hc Iras custody of the agreement or other docur,u.;ntary evidence concerning the arrecr,ent. If you will do so without a ldotion to Produce, attac}, a col>y of each such docur,,ent to your answers to these interrogatories. ~1. Uocs any corporation (in orhich you own at least 5~ ownersY.ip interest) , pa.rtnerslrip, joint venture or sole pro- prietorship referred to in t}re preceding interrogatories or do you individually or with anyone else, have an interest, or have they o.r you lead an interest anytime during Ure past three years, in an}~ stocks, bonus, or ot}re~r securities of any kind in arty governr,ent, governmental organizations, cor.,pany, firm or business incorporated or w~incorporated, foreign or domestic? 52. If you answer is in t}re affirr;lative, please state: ~~ a. The description and identification of tl•re security; ~ 1 b. The identity of any co-owner. ~ or interest holders; c. The present market value; ~, ~~ ',' I 5;, ;r{r,,tily ~~Ll L~~~a}: a;rd sa~•in~Js ~~ud loan association aL, .',iZi-:;;~;, ti;:'.:' CSC'I;:~;lt~, Ci:'-t1f1CaL:CS of d~' v:.lt, SaV111Cj:ii bonds, treasury notes, sa•rinrs c1uLs, thrift ,laps, r„or.ey ;.;~zrket funds and chec'r:in:~ accounts ir. your Hanle or in the nark oa any cori>- oration (in c:iiich yoU own at lcrast a 52 ownership interest) partncrshik%, joint venture, or sole proF~r.ietorship referred to in the ;>reccding interrogatories. 54. For each item identified in t}le k;rc:cedincr interroga- tory, state a. The location of tkie account or other item; b. The account number or other identifying nur.iber; c. The present balance therein, or value of any other iter.i; d. t•Iar,~e and address of each co-o~mer or person authorized to draw on the account; c. 2'hF, identity of any custodian of a passbook, c~rtif.icate, etc.; ~~ 55. List any and all aniounts owed to you cf tahatever nature, and for each list a. The identity of tho obligor or debtor; 23 •~! i~, ~,1 . L.i ~, ~. i. ~.:1;• r ,,; a1.1 cl~~~:u:.,~. ;~L:, rclr~'_i.:: tt,^ret.~ ~, 5~.;. Does any cor.F>orati.on ,(in whi-ch yeu c.:m at ~~r;t S~ o•::ncrshit intcr~st) partnership, joint vcntt.ire or sole pro- t,rictorshii. rc£erreci to in tl:c ~>rccedi.ng intcr.ro~,latoric~s or do you i.nCfiv.idu~il.ly have any ot.hcr Person:]. pt-oi,crty, tangible or int~~nrik,le, i::cludinc but not linliter_7 to such items as cash, furniture, eciuiptac:nt, jewelry, precious nleta.ls or stones, auto- rlobiles, trucks, aircraft or other recreational or transportation vehicles, courses of action, copyrights, patents, r,~inerat rights, tinier rights, or at~y other thing or thinys of value? 57. If pour ans~~er is in the affirmative, identify the entity and state full}~: a. A full descrii~tion o£ t11e asset and ttie titled owner; b. The present location of the asset; c. The date and method of acquiring the asset; d. The serial number or other identifying number of the asset; e. The purchase price or o her consideration furnished ~ for the' asset; f. The present value of the asset and state how value was calculated; --- - ~I -- . 2q '1 ~ ~'• - n' (,l it .~'llt'}f `'~i~: ~ ~~` 1^~..:!' ri '% ~ ~ ~ .. ~ - ~ r~i ~- .,~i ~..-~, i~ i t~ r ~ ~., ~ -'__.t1p, i 2.t•C} t0 lh t}1'_ j)_ r'^CC:~ f?`? ].ti ~..-YCiCjntf,t 1~'~> UI. ~, .VC yCill ~ ~~ inciivici.:,i!!~• c,r with anyone cls,~', c; ;.von, sold C)1: ot.lu~r4:isc trans-'~ I~ i't.rrE~ci t,:,y asact or thing of ~•..luc' t~> at!y N~ .::~'-1 c?r cnt:it}' fear i .less Lf~«n i.ts fair f;,arket value c:;irincj Lhe fast tl,rec~ ye~~rs? 'i II G0. Do you receive, or have you recci~rcd durin~; the past ~i Three y<:•ars, any gift, stiff-end, contribution, cor.~i~cnsation, ~ gratuities, lx-neiits, services or goods Egon, any source, business or othcn;ise, for ar,y o: t}lc follo~~iny personal e~;pcnses: a. Living accor.todations, inclu~.ling utilities and related expenses; b. Food, household products and sundries; c. 1lutor.iobiles; d. Clothing; I~ c. RMrca*ion, er.tertainr,on+~, (e.g. clu}~ n~cniberships, ' dues, etc.) it , f. Vacation or travel; l~ g. I•Iedical/dental care or insurance; h. Life insurance; 25 1 __ - 7 I ~ I F I ~ f I ~ i 1. U}11Cr (SpP.Clf}~') 6.1. F~. you t}rc holder- of any rental hroj~crty? If ~o, for. each property, st-at~: a. The type of such prohcrty (F:eal or personal) ; b. The location of such property; c. The date acquired; d, the net monthly rental to you for each piece of property; G2. Durinc the course of your marriage, have you owned any interest in real property? If so, for eacl~r parcel of property, state: a. The address; b. TYIe size; _, c. A description of each building, structure, er other in~prover.:ent presently on tine property; j [ ~...., r rf'ia !(~ adC1r~:.. Jt __'~.1~` U! ~)i.'1.~tr11 ~1'Oiil lJ}10,^.t tlt I •^ t;?t:~ t':"it11: U!1; g. T}r~ date and place the deed or other document of. title is locatod; }~. The present location of the deed or other document of title; i. The nar.~e and address of each owner and their respective oo~nership of such; j. The purchase price; k. I.7hat portion of the price c•~as in cash and what portion way financed; • 1. The details of financing and the present balance due on t}~e property; i~a. T}~e approximate fair market value at 1. time of acquisition; 2. time of separation; 27 G' . _ ,, .: u~,l t.~.rc.vr,, ; ..;n c:r L.:rti r._,~;:: c~;ll~i L, ho.td a^y I£ so, L~~r each item of prc.>F~~:rty, :~t.at.e ~~. Thy nar:~^ and ~~c3c:ress of e:u•1: such per_;r~n, farm or b!isin^_s> entity; k~enefit; 1~. A description of the property tieing held for your c. The conditions under. which tae property is held for your benefit; d, The approximate value of the property; 64. Are you holding any property for the }~enefit of another uer.son, in trust, or otherwise? If so, for each item of property, state: a. The nar,~e and address of ttrP beneficial owner; i b. ;1 descri tion of ttre ~' p prope rt}~ ; c. The value of the property: 1. at the tir.ie of acquisition; 28 i ', •. ~~ . ,, A' 6:~ . Sind ti~~ fi.linc,~ of tiac~ divorce c~:r~~~l.aint, di-~I you tr<<nsCcr ar;,~ ~~ro2~crty in which you coztLaineci an inLc:rGSt? If sa, for each ite;,~ o` ~~roF~ciLy tr~insf.erreci, state: a. A cor,,plete description of the ~~roperty; b. The narue and address of each transferee; c. 'I'he reason for the transfer; d. The amount of consideration received for each transfer; Gam. State o;raetfrer you have over purchased any real or personal pro~aerty ~A~ich teas been placed in t}ac: nar.ie cf your father, r,:other, or any tkri.rd party other than. your present spouse. V?. State wf~etheryou have sold, transferred or assigned any interest you may have owned in real property within the last five years. If so, state a. The interest held by fou; _ ,^ ,_ c. 'i'i.: lc>,..a`ir.~n t~~~ . 1.~. ,1 cL .,~•i ~~~ ... o? i~~ ~ x~t-opcr 'r'; d. T'.IC a:~{~roxi^.:at~~ ~~_~1 ? i n:.~ ;~rica~ <:nci your nc~t; proceeds frola t.i1C Sclln, trdI:: ~Cr UY ci5S1r,):.,ii tl t:; e. The nar,ies and addresses of the per~o.~ or person to whoa the real property vns sold, transf~rr.c~d or assic3ned; f. The date of acquisition; 6II. List all tangible personal. property, giving descrip- tion, date of acquisition and apprctiimate value presently held by you in your name alone, 69. List all tangible personal property, giving descrip- tion, date of acquisition, anti approximate value presently held by you jointly with your spouse. 70. List all tangible ,hrsonal property, giving descrip- tion of acquisition, and approxirate value presently hold by you jointly with any persor. other than your spouse, giving the name and address of that person. ~ 71. Are you the ovrner of any airplanes, boats, motor }Mimes, recreational vehicles, horses, or the like? If so, Yor each, state a. A description of each suc}1 item; b. Date of purchase; 30 ... •~ ;' I ~~ i. ,, ~ i~ ~~ +' ~ f. Z is n;arket v~luc; g. Whether held individually o!- jointly with another person; h. The nan;e of such joint owner; f 72. nre you t}ie owner of any paintings, ooins, stan;ps, jewelry, gold, antiques, or other such valuables and collectibles If so, for each suc}Z iten;, state a. The nature of such iten;; b, The location of such iten;; c, The date of purchase; d. Purchase price; e. The market value of such items; f. Any encuntibrances against such iten;s; - 31 - 1 ~', I ?3. ,-`Zte t~;'.ti:i_~i:~r yuu ha~.~ s;;.,l~i, tr~tr.•„ r• •? ~~; :~::ni~1nc~..~ a.:.y' 1P~ (" ';~" y0:: ]lllti' }2: VC' 041:;^~{ l.I: ; i',..`;t)1::1~ }~:'t)?V`Ti')' In ~}1•• ~.Atii tYl1 V(1d2"5 . If^,G, St~tC: a. Tltc i.ntcr.cst hr-~tc7 -by yuu; b. S•~hetl~er. h~•1~3 },y you alone: or. jointly with any other person, giving t}ic nar,re and address of those }?ersans; c. The approx~ntate sellirn7 price and your net; proceeds front the sale, transfer, or assignnt_nt; d. The name and address of the person or persons to 4~hort the property aras sold, transferred or assigned; e. A description o~ the property; f. Date of the transaction; 7A, Identify any and all liabilities or ol~ligat~:ons of 4rhate~~er nature, including a list of credit card accounts, that your r.tay have, wtlich are not disclosed in prior interrt~gatories, and for each, please state: a. The nature of the liability or obligatic+n; "~ b. Date ace}uired; - '2 - ~. r ~. ~ .,. .. 'rail. .tfi,ri:',.. L` I.._ L, , . ,. „' i .~ ; r, 1 :-] ~ 1 r t~rrl: Ul7 :.~j' ~ t. 111L: L).!i~l t~~I ... •..~j Ll'-:, ~r irr•r•/ ~1 Clrl;%; f. Tltr' acc' ~nt trurtbcr; ~I g. Tite amount and ~;ciuency of payrtcntc tliercon; I 75. rare you the beneficiary of any estate currently in probate? 76. Are you currently the beneficiary of any trust estate? j 77. Are you the grantor, beneficiary, or holder of a power of appointr.tent for any trust created by you, the members of your family, or by any corporation? I f so , for each such trust state a. The date of t!ie trust instrurient; b. The Warta of the settlor of each trust; c. The name of t}te beneficiary of such trust; -~ i4 ._ i Y { d. The amount of each trust corpus; - 33 - 1 , i i i . i . . , ~~ '~'~ I j •t. ,11. ~.. .. _. .1... ... d.. .'C• 1 ,! i~'li'. ~~i \•i}~If'il y'Cl'i :~`.. 41:,. ffffi , f~ ~. -,~.r ~ ~ rl~ti! I c•cr , O`" :•:) .' 7 t:..:~. 'r .. ,. 1 i,r C:.u ~. il,~!':L:~~ _ _ . a. ~;._ ic?'~r.city v£ Ulr i:lsuri:!Ilc,. ccnnhal!}' trnd 1:o1_~.cy } n!;,nl~~ r s b. Face amount; I c. Identity of the owner, insured and beneficiary ', and any relationship to you; d. Annual prer.liunls and tlu~ payor; e. The present cash surrender value; f. The date each policy gas purchased; 79. Has the name of any• beneficiary of any of the insurance policies referred to herein been clYanl,~ed during the last three years? E3U. Did you file Federal and State income tax returns for each of the past three years 7 I f so, state a. The full name and address of each return; i b. The filing status; ,.. ' i.i:~l~ r.... ,1 .r,. t•~, it.: lr: }'_ .. - I', 1„t~ ~l .. .,~ ...E '. .. _.. ' II ,. - ',, li it ' 87.. H~:v~ you kept any other books, rc`c»~il~ or written ,j r„c;torar.da of your income and Y~usiness affair::' 82, Fiave you at any time during the c_•oui~t of your marriaoe .Filed for an individual bankruptcy in the Ilan}:ruptcy Courts of the United States? 83. Gist all gifts that were given to yc~u individually. during the court of your marriage. 84. List all gifts that were given to ycur children and/or other dependents. 85. List all gifts to your spouse during the course of •the marriage. 86. Since the date•of your marriage, have you been ~lnvolved with, slept with or had sexusi relations with a,y other individuals othe- than dour husband? . ` 7. If so, please list: " I a. N~e of individual(s) b. Addresses ; ~y ' ,.;~ • ,' .:. ii - 3 5 - - --. -- .. ~l `` ~ . .. 4 A 1y ~+~1 S,'rii Y •,~ ®II~YORIIi~I~i ~- __ CERTIFICATE OF SERVICI's I hereby certify that on the/~~~`~ da•,~ of October , 1986, a copy of the attached INTEF.ROGI~TC~RIES was served upon the PLAINTIFF by depositing a true and correct copy of same in the United States b4ail, postage prepaid, at Williamsport, Pennsylvania, to their attorney of record, E3RADELY L. GRIFFIE, ESQ. 200 North Hanover Street, Carlisle, Pennsylvania 17013 ( /A , Martin M. Fine, Esq. I.D. # 07527 322 Court: Street Williamsport, Pennsylvania 17701 (717) 326-1761 ,' ,~• CEf''IF1ED TRUE COPY ATTORNEY FCR PLAINTIFF i i'ltGTIiI_,A~D IN Tf{~ C~tJF7I' OF CY1hP~YJIV PLFA.S Or CC~GNTY, PENNSYLVANIA ' ED K. BALL - . Plaintiff CASE NO . _{ '? R 0 vs. _ I~OSIL,AVD .T. BALL Defendant TRIAL ~SE.~RANDG2~1: PART Z CML ACTION: IN DIVORCE _ _ _ - C~1E~2AL INFOFMATIC;N _ __ N~'ti~IE OF PFIR'I'Y SUBMITTING : F.o s i l a n d .T. B a 7 7 ADDRESS: 339 Ninth Street, Vew Cumberland, FA 17070 ~~.r,vHO~ ~7~g2; 774-5279 DATE OF BIRTH: October 7,5 , 1947 LENGTEi OF RESIDENCE: PENNSYLVANIA: 37 yea.r~ 7j,`~~, Cp, ; 12?~ venr~ CUI1tB . -" DATE OF MARRIAGE: July 2,1966 PATE OF FINAL SEPARATION: PLACE OF MARRIAGE: SFil] iamsport, Penn5ylvrini<i NUhIBER OF MARRIAGES : 0 n ,:!•{IL!?REN OF MARRLAC~: Name: Birthciate: Custody of: Ci l^(1 ~p 7•p_ K, Bffll .T~min rv 1C, 1Ql:7 2 NAt~ OF FFIKPIAYER: _~lmeric:~n Or~~in~~ AvDRE~; ~ ~ ].0500 Amerir,an Rcl. CI vellnd Ohio JOB DESU'n17"I'ICYd OR TITLE: Part Time !.tercha.ndiser 1.);T~X'TFi 0:' 'SEnva~: Set,tember 19f30 - ,l yr~ S.S. M: 1.84-3R-5013 -z- IF' C7UT E:~i'IOYED, PLIW Et~R E:IP:AY~2~C: LEVf:Z OF IDUCATION ~~'D DEGREES: 2 yearrs col 1 eke '~ C7I':-ll;q TFA2NING AND/OR SKILLS: NOVF. ANY PLANS flJR FZI'IVRE EDUCATION: Ai ter the Children are educated I'd like to het my degree in basine~s. 5TA'IZJS OF EaALTH: Good SPECIFY CONI)ZTIONS AFFECTING ABILITY TO WpRK: Except children care - a~c~ 18, 1.5 and 12 DESCRIBE ST}'S3DARD OF LIVING DURING MARRIA~: tlvera~e DESCRIBE FEE; ARRAPIGFIvtFNI' WITH YOUR A'I'IC~RNE~': IIourl~ IN T[iE COURT OF' (:'C(~4~Y1tJ PI..f~1.S OF L'i(`CkiI27G C.'C)t.N'I^c', Pf~17SYI.VJ1NIl1 rD K. BALL CASE NO. ]280 _ Plaintiff vs. TRIAL I~IVIJRANC~1: PA:Q' II ROSILAND J. BALL Defendant CIVIL AI.TION: IN DIVORCE IPICCY~fE AND EXPENSES _ i Ca~lete the following Iruune aryl E~cpense Statement and attach t:o it: .~ ... } 1. Copy of your most recP,nt federal inecme ta.~c return. ' 2. Original or copies of any pay stubs or earnings state- ments for the east six tronths. (If you are self-cloyed or if you are salaried by a :xasiness of which you are owner in whole er, part, you must also fill out the Supplemental Incase Statement which appears an the last page of this Inccxne and Expenses Statement. ) Inca and Expanse St~termnt of: Flosiln,nd Ball I NCQ~ F.•nployer: American Grcetin~s Address: 10500 American Rd. Type of Work: ;.[erchandiser 1~art-time 30 hrs. Payroll Number: 4 5059 Pay Period (weekly, bi-wee}cly, etc.): weekly Gross Pay per Pay Period: $ 153.00 Itemized Payroll Deductions: Federal Withholding $ 12.59 Social Security Loc ~~ l wage T~vc State Incase Tax ~ sA Ret i rc~nent SdVlr1C~S FtOnds Crcx;it Union Life Insurance Health Insurance -V Other (spec;ify) Di Sabi I i tt~ 15 .00 ~. 5125.88 I al>o Bret 52,5.00 a iceek :cnrkin~ R hrs. o N ~ - n Saturday at the e . ~ ter. -2- Other Income: Inters:>t _ ~.. "'! • Divide~xjs stocks ' E Fens~on Annuity Fents Royalties Expense rk:count Gifts Unemplor•~nent Ccxnpensation 7Jorkmen's Compensation 'It> t, a 1 'iC'I'A L I ~;COM E; I t^Jeekly Monthly Yearly (Fill in appropriate column) S ~ S_ S 1.,883.00 s S S 1.883.00 EXl~ENS FS Home +~rtgagelrent +43intenance Utilities Electric Gas oil Telephone Water Sewer Employment FUblic tr~~nsportar_ion Wnch Taxes Real Estate Personal. property Income Insurance Homeowners Automobile Life Accident Health Other Automobile -3- YR~r~kty `bnt~~ Yearl 5111.0 g1,G92.00 g 613.7x1 836.26 37.1.? ~.' 3 8. 1" •} 5 7. 2 4 +.;100 kerosene 66.Of~ 79:1.00 201.76 . .____ 1 g6. 80 S S S 20.0^ 180.00 school -"-"` "x'73 .~" ~F e de r a 1 58.00 local. 5 $ gin mart~a~e " includes Ed's "~II7J= ---zTzo :-cnrz~7. ~o-re's) 50,00 i 0 S ~ Payments $ ~,~, 86 Z_ F1ae1 _,15 .00 ~Q_,QQ 720.00 ReraLrs 150.00? Medical ik:ctor S 5 S 20 other half Demist this for one onl~• covered by ~; ~ ~odontist -second child duel ~~~0-~ Ed's incur Nis vital +1e.~i,~ine ~ S~e~~tat needs lasses -all 3 kicLs 56 •0(5- ~races orthoF tc deVLCeS) r L c 1 s -4- F.XPF.~+SF:S (Cnnt.1: r+ecklY ~t~nchl~+ Yeah Education Private school S S S Parochial school _ College - one and t~1^o to attend 66.73 800.76 Religious Personal Clothir ~ S S S £ood X0.00 400 .00 4 , 800 .00 Barber/hairdresser 84.00 , Credit paymen~s - - - --• Credit Card 1?.0.00 _ Charge account ~'~- Membershios !~~ hii 1 k ~ ~~-" ~;'~ ~.l.J3RS Credit !pion S S S t4iscel.laneous ibusehold help S_ _ S S~ Child care Papersibooks/magazi.nes~postlfis T ____ ?9ft _ 00 Entertainment _ r~0.00 F00.00 Pay 'N ~ ~? ~2 _ ?~.1 - R4 Vacation 500 " Q~ Gifts ~ Legal fees _ Charitable contributions 500.00 Other child support Alimony payments ~' Othec 'Ibtal Expenses S S S S 115.00 1,523.4?, 19,5n0.35 PROPS:R'I'Y i;WNED: Description CYteck tng accounts Savings accounts C7ed>.t Cfiion Inheritance - Trust Stocks Stocks/'oonds Real estate_ ~ Double Ilouse c?ther 'Ib t a 1 I~~SL'RA~7CE: Company Policy ;vo. Coverage* N W C b~spital 81ue Cross FIis ~ther ~,H. 1~^G1s:'~~ Rc Sons Corr~any In`. , ~12d1Cc]l IIIS` ' Blue Shield CTther C.fI. ?taslnnci Rc ~nS Cotrip£u1V IIIS . Heal th / Ac:c>,dent Di,sabi 1 i ty Incane Dental - C.I1. Ai~island & Sons Canl?anv Ins. Daher - ~i - ~aluP c)wnership* H W J X t _ -= S 25,000.00 ~ - - X _ ^ X *f--:Husband; W=Wife; J=Joint; C=CYiild ~1 ~;' J~ .~ ~ -f~- SUPPLEb1E~TAL I`~CC;1F. 5TATf•:~1;:~'i (al This form is to L^e filled out by a oerson (check one': k/h ~~ (1) who operates a business or practices a prc~fes~ic,~t, •_,r i~ (Z) who is a member of a partnership or jc~u~t. ~en~ur :~,r ~ C L.,b~L CUr t.x~r .tf ~ n7 • • • • • • • [~ (3) ooho is a shareholder in and is saI ~-C? f'~.,by or similar entity. --- tb) Attach to this statement a copy of t:he fol.lawirx3 rjor~urFrntc ~^'.~'~•u~ t.;. ;}~e nartnersh tp, point venture, business, profession, ee:.r r~:ra' ~~• ~ ~r • Im, 1 ~r entity: fl) the most recent Federal Income Tax Return, and (2) the mr>st. recent Frofit and Loss StateTent. (;) :Name of business: ~c3dress and Telephone tiLunber: (d) ~;ature of bustne<;s (check one) ~~ (1) partnership (2) point vent.~,re ~_f (3) prof es:, t on (S) o*_her (f') ,kVrlf' Jf .I,_:i'~)11 ~I J ~ (t') .1rir.~ ~, irv•,"~~1• , do ~ :;y~ • -7- I verify that the statements made in this 'nccx~e and Expense Statement .ire true and correct. I understand all statements h~'rein are made subject to the penalitzes of 18 Pa. C.S. s~ 4904 relating to uns~aorn falsification to auth- oraties. Cate i 'fR1~~:CKRK (Defendant) -~_ ! _ i __ IP! TNE: COtJR`1' OF t'~?MM(k7 PLF..4S tit' i,Yt_'ck'k21G CC~tJ?lI'Y, PENNSYLVAN.CA ED K. BALI, Plainttff vs. ~~~SII_,AtiD .T, HALL Defendant CASE NO. 7 2 F 0 '1RIAi: MEbfORr1NGUM: PART III CIVI1 ACTION: IN DIVORCE I~~iVENiURY ADD APPRAISrMEYF (Platnttff) (i~fendant) f31es thF folla~~aing znventary and appraisement .~f all. p;aperty owned or passe=-scd by either party ~~t~ the time this action was commenced and all property transferred witt^in the prec•~ti~ing three years, (Pla~nttff) (Cx~ferxi,tntl vcrtfte,, t.ha*_ tte statements made in this inventory ~rnd apprc~tr~ermant ~.lrr. tnie and cnrre~ct. (Platnttf.f> (I~fendant) ur>clerstands that F_el:~• :~tat.ements herein arcx made subject to thr> penalities of 18 Pa. C.S. @ 4094 rel,ttinq to unsw~rn fc~lsiEtcation to authorities. f~0.Yld~ (Def enda ~t e: List no more than two or thrr t tem5 r>n eact- of the following schec9ules ex~:~pt Eor k;ausehold f~rntshings and k'ersonalty, tse addttronal schedule sheets :, .seeded. -2- ASS(rCS CF PAr~I'IES (Plaintiff) (Defendant) marks on the list below those items applicably to the case at bar and tt:ernizes the assets on the following pages. If an item has been appraiser3, a copy of the appraisal report is attached. ( X1 1. Real property 3 ( X) 2. .ht~tor Vehicles e ( X) ,3".- Stocks, bonds, securities and options . ( ) 4. Certificates of deposit ( X) 5. Checking accounts, cash i ) 6. Savings accounts, money market and savings r_~:rtificates ( ) 7. Contents of safe deposit boxes ( ) 8. Trusts II-? ( X} 9, Life Insurance policies (indicate facie v.~iue, .ash .surrender value and current bc.~neficiaries) ( ) 10. Mnuities ( ) 11. Gifts ( ) 12. Inheritances ( ) 13. Patents, copyr,ght., invEntions, royalitie, ( ) I4. Personal property outside the home t ) 15. Businesses (List all o:~ners, including percentage of ownership, and officer/9i rector poi>ittons held by a party wrthin company) . ( ) 16. F7nployment termination benefits--severance pay, workman's compensa- tion claim/award ( X) 17. Profit srtarinq plans ( X) 18. Pension plans (indicate employee contribution and date plan vests) ( };) 19. Retir~nent plans, L~dividual Reticemc~nt Accounts i ) 20. Disability payments ( ) 2.1. C•itigat~.on claims (matured and unmatured) ( ) 22, Military/V.A. benefits 23. D~ucation t~nefits ~ ( X) 24. Debts duo, includirxa loans, mortgages held r ( ) 1.5. Fbusehold furnrshirx7s and person•zlty (incl~~de as a total category and attach ztc~mizcd list if dtstributr.on < such assets is in dispute. ( 1 I'i . r?t h e r U~ -3- Hi1RITAL PR.~PF.R'{'Y __~ ; t L -- ~ 1 I (Plaintiff) (Defendant) lists all marital Groperty in which either or both spouses have a legal or equitable interest individually or Witt; any other person as of the date this action was commenced. .item Description ernes of late of Wmber of Property All G~.~ners Acqu.isit-ion ~]. lIouse Ed K. & Rosiland Ii. Ball Aug. 1972 Cost ~r Value Value as of Item as of Late Qite Ar:tion Nnount of ~.Lmber of Acct~sition ~_ Com.nenct-~d Any Lien ~0.(CC' rv #1 .x,13 , cJ00 .00 X25 , 000 .00 ~y, L~.~ Cv,-o,v~r1L i~ ~/! Item U~mbe r ;nature of Any Lien i;ffect:ve Dt3te ref Lien Folder of Lien Y _Q. "70,U-MARITAL. L'ROPE:I2;'Y (Plaintiff) (Cefcndant) lists all property in which a ^muse has a legal or equitable interest which is claimed to be excluded fronn marital prop- er ty . Item Number Cescription of P*operty Names of All Owners Date of Acquisition ~3 "" .. ~ . ' Stocks Rosiland B. Ball. Oct. 1972, t Cost or Value L'~a).ue as c+f Item as of Date [gate ~'~tian Amount of ;~.^nk~er of Acquisition ^~ Commenced Any Lien #3 528,700.00 $31,253.00 ' E~fect~.ve Item tiature of ate of lunber Any Lien Lien Item Number ~' f_: r Holder of Lien EkistS ~nr Ext'1~~^inn frnm Marital Property - S __ PR~:PF.RTY TRA`:SE'ERR~:) (Plaintiff) (L~fendant) lists all property In which either or both spouses had a legal or equitable interest individ~ially or with any other- per- son and which has been transferct~d within the prc~-eding three years: Item Description Names of Cate of Date of Number of Property A1' C\aners Ficauisit.ton 'Transfer t{ ~•t c ci rt Amount of Cost or Value Value as of any Lien Item As of Gate L~ite of at Date ~.lunber of r~cquisit.ion 'Transfer of 'Ik'ansfer Nature of .any Lien E~fc~ctive Item at iknte irate of Eblder of P?:,~t~er of 'It-ansf^r Lien Lien 'S' I t . , ~. _f;_ LZABILI7'IFS OF P~RI'IF•S (Plaintiff) (Defendant) marks on the list below those items applicable to the case at bar and itemizes the liab:~lities on the following pages: Se:.-ured ( }{) 1. mortgages • ~ ( ) 2. Judgments ( ) 3. t.~ens 11 r• ( ) 4, Other secur~Y3 liabilities Lk:secured i ii) 5. Credit. card balances ( ) 6. Purchases ( }~ ) 7. (.nan payments 3>arent: hlu~ Cojlc~c;c L~fln ( ) 8, dotes payable ( ) 9. Other unsecured liabilities Continent oc Deferred: ( ) 10. Contracts or Pgreements ( ) 11. Promissory notes ( ) 12. Lawsuits ) 13. Options ,, ) lA, 'T`axes ( ) 15. Other continent or deferred liabilities i; LIARII.ITIF~`: tPlaint>_ff) i[)efer~ant) lists all liabilities of either or both spouses alone or with any person as o£ the date this act>,on was commend Item i~escription I~3mes of all i~„tmber of Lsab>,lit~_ ~ Creditors L~btors l_ ~'.ortgat~e Colonial. ~1ort~a~e Service Co. 2 a _.~.ti~-~. 1-~Cnl ~ , Parent Plus .- C~/~ =i t- C C~mmonwell th Natinnal 13ank (College Loan -~ >> ~ t y Orthodonti~:t Ira <J. }1el].er D.D.S. 4 Credit Cards (See :attached Sheet) ~rnount of Liability Item Qate Li~~bili tv on Ikzte Incurred and ^~tmber was Incurred Action was Commenced ! ~' l ~> ~ / ~~ 1 tlu~us t . 1972 ~ 2 .~ AV ~ • S~ Au t 198] - $~t 03.40 ,? 'stay . ] 98~ $ 900 .00 Item I~te Ealance Periodic Payment Umber is A.te and Amount 1. 199? `~14] .00 <t, month 2 ~ ,1u~ust, 1JR9 ~ 06.7:; 11, month /f 3 J:tnuarv, 1.986 ~ 70.00 a month t i s i i ,.. .../ .~ ~'~_ _. U l 5 ?\ ~~ t ~' ~ ~ ~' , k~ "~ ,~ ~~ t.. , , ~ ,~ ~~ ~~r ._~ _ ~ ~~~ ~1' 6 LEA ~ . j_2L" f ~ t z,'~ ~ S ~~ ..• ~ r ~ ' ~ ~~ ~{ ~ s : .. . v ~~ 1 1 ~ +1 4 t T t ~~~~V .' W . A J D ~~/ t \.r '+f r ~~ a W a 0 d G I H N H~ L.. p O w G r O W ~ ~ C ~'' a i Q ~+. C O O v, •- ti ~ V ~ N :~ C O t.. -+ O N '+-+ +' ~ ~ O ~ c° ' ~ E C` OI ~ m V ~~ w ~+ O .-a d C ? O +~ .~ 1.. a~ .~ o ~ ~ v, ~~ '• e CERTIFiFC ~~.U ~ cirPY ..,.... AT70F.NE` FOR FI,UNTIFF Iii`,,, .:C,. j~ i N'i'l'}'RC>; ;'OI;I;:;~ ?'kU"UU~dDf ~) }~Y F)F.i~ 1_~Nn~.N'l' 'i': ~ !~' ' 1': f' I'. i ;' ~ I~'; 1 f ,,~ 11`!'1' 1 h' }•' T;) : I;c-1 K . t;~~ 1 1. c!o Gri f:fic. & 't'urn, }3rz~dcly L Gri fLi.e, Esq. !,; 200 North Eta novc~r Street Carlisle, 1'ennsylvani.~~ 17013 ii .~ ~ • I ~. • ,.,1'I~l,n~.,. j i t i :Enclosed herewith are Intcrroc;xtories Propounded by Defen- ~ dart to be answered by Plaintiff, cinder. oath, within thirty (30) days from the date of. service hereof, pursuant to the Pennsyl- vania Divorce Coda, thr Pennsylvan:_a Supreme Court Ru:1es and the Lycoming County Court Rules. ~Je r~:auest; that a cony of the An-- ' ~ swc~rs be served upon all counsel o`' record. Each Interrogatory hereinafter" set forth not onl!,~ calls for the knowledge of Plaintiff,,but al:,~ for all information that i.s available to Plaintiff by reasonab:;,.e inquiry, including inquiry of any representative or attorney. ~' ~ These Interrogatories =hall b~: deemed to be continuing. If bet:.ween the time of your answers, ,end the time of the trial of this case, you, or anyone acting i,~ your behalf, learn of any II additional inEor.mation not contain~sd inyour answers, you shall ~~ promptly furnish such information `;o the' undersigned lay supple- ~~ mental answers. • ~~ If objection is made tc~ any o`: the following Interrogatories ~I or if any Interroctc~tory is not ans~~ered in full, state the spec- ~'~ ifi..c nrot;nds for the objection and ens e>r such Interrogatory to MARTIN ra. ripe I IIl E;' extent t0 WI1xC}'1 t}l t?rE' 1~~ RCJ ~Jb "~eCt10nS If pri Vl:i F±ge 18 dl- •n~~rr.e~ .~ w ,,,~,,,,,,,,,,,,., lecled as to any information ~~r doe invents requested, fully id~~n~i~` .~~ wILLiAMf IOwT •1~T •J~ ~ j ~,~~ .. s ~~lyy. i I „i~j A~tA~n ~1lli- _ _ ..~, J P ', ~ li ~i !i~.~ l'li~ 'i{ i lC)u' it"} '~':>'. ~.. i C. ~ i ~~ .. i Ili (~ i ~ I -1 ~ ~~. ; ~~, ,.It cl~'1 1(11 (~l I~ C ~ .~ i lil . 11 ~I I1~ '441II ~i _ ... I ht-ir•t:in i`'. I~ine, F:~ci. I1 ~~ I.!). Y (17517 ~ ~' .~ ~~ I ~4 t ,~ ~~ MARTIN N FINE ~~ k : .,.,~,,.... "w rj i_. ~~t.o~A., A..,. f r I l 7 ... .. .~. I 1 1 ~ ~ ~. 1). ~~C::: .. ~)I~t'ti ~'11r }:J a'.~'_. .._~ ~Illc! .~l~i r•~C.il C): :~. ., LC1 C111~, at that auc;r _ ~ ;; c. Thin nar,le and rcla :ionship to yc)u of each ~n'rson resi.dinq with you; , d. Your ~cial secur__ty t,ur.iUer; e. Your age and date of birth; f. Your present and east r.ulitary status; Y b 2. State your residence addresses from the time cona~~encing three years prior to the date c;~f the marital offense or cause of action charged in the ComF>laint, up to the present time, indica- ting periods of residence at each address. 3, State the Hanle, ages and bi.rthdates, and present addresses of all children born or adopted during t,..his marriage, indicating who has custody of each dependent child; whether any dependent child is in need of unusual or extraordinary medical care or mental care or has special financial needs. ~~ 4. Except for your spouse and children, do you have any other dependents ? 5. If your answer is in tYte affirniative, for each such dependent, state: a. The dependent"s full name and address; 1 ~~ ~~ i ~. ~ ~ ~, '~ ~~~ ~' l.. V~~. , ~.. ~L`:1 ~:~ 1, L. `~~~ ~. t; t, ..(~ ~~I ; t i i i 4 Ci. Z~}li) A?".~iltlnt. Vi. LtU!1Cj' E•~:}~ 'li'.iC.} }~y' VUtI j - i;:v:`t }1 ].Il ~ sup~vrt of sorb dr:Ft~~nclc~nt.; e. T` ^ income ( t ~xak~le and roan-t~:x~~h] e ) recc:i ve~~ each month by or on behalf of the dependent includa ng an itcn~ize~d description thereof; 6. Are you, or are any of your dependents, presently or within the past ten (10) years under t}rc care of a ;physician, psychologist, psychiatrist, chiropractor, therapist or other health-care provider? II a. T2~e name, address and telephone number of each health-care provider; b. The date you or your dependents first consulted cr were seen by any health-care provider for your niQdical and/or emotional problem; c. The last time you or your dependents consulted or were seen by any doctor or health-care providez for your medical and/or emotional problem; d. The medical diagnosis and prognosis of your or your dependent's condition; e. Nave you or any of your dependents, within the last three (3) years, taken any presc: ,.ption medication pre- scribed by a doctor? r 1 i i j~ I ,i 'j. 11'~ )~..~ ~): ~1'i',' C' ~,•J!;,~ Cf~.•f •. •i~r j. i~ ., }~ ~~1~ ;i ~ ~~t;1~~ I... ;' (~ `:J ~ is it „ t ~ _):;"'.~ {_elt ~ - `, ~!. :' I ~1 li. If sv, r`a`_~ th^ dateG ~t h~~st~.it 11i-r.at.or,., Ute re~~:on for tl~~. horaitalizatian, tlae date of cli.scharc~e ar,cl the doctui prin.,~Zrily rasr~nsi.ble for your care during the hospital- ization. i . State tl~c sum or su:~,s cif r.,oney c~:~~ended by you for all of the abovF• health care and the: portion thereof, i.f any, that was covered by any type of medical/hospital insurance or any other type ~f insurance. f3. List all cn,ployers and/or jobs (f~.ill and part-time) that you have had during the course o€ your marriage. 9. For each ~,ployer and/or jab, state a. The full name, address and telephone number of your employer; b. The date you cor,tmenc:ed your employment; 3 c. Your job title or position z,nd your duties and responsibilities; ~~ d. Your employee or payroll number; ,} e. The nan,e, address and position of your ir.~;,ediate supervisor; 1 ' ~ ;: If ~~ ~..s' c•. t ~ .. ~- I! g. 1•. _~cii..r }•u~ vc ct :y w~itte;; oz' o;'~r]. cn~f~l.c.r,nu~nt cant r-rr-t:s with yau~ ~: ~r.cn cr,tpln}'E~r. 1i. The reason for terr,tination Uf each ;orb. 10. Arc you or wrre you compensated on a straight salary basis for each -job held? 11. If your answer is in the affirn,ativc, state fully: a. Your gross salary per hour, week or month; b. The number of hours per week. that you normally work or worked; c. Whether you receive or received additional. compen- sation for overtime work, and if so, the rate of pay received for overtime work and the average number of hours of overtime you work or worked per week or nrunth; d. The dates on which you are paid for both regular and overtime work; e. The amount of your gross earnings to date from this .source during this calendar year; f. The amount of your gross earnings from this source for each year that you have been employed, i • I I , I ' I -. ~ ~j I I ~ .. t' ,.., f r_". 1^~; ,- .., ~: l u. ~I ', (il 1 !' 1 Cpl I ri4/-I ~;,:~ { .~ .~. th_ 'rosi:.,,;t~~ ~,n,~l~tu o ,.-• ~..,_ .,tll•ir•~~ Ju>,t f:or i 1. J%:1`ivL Ci!:;~ at'^s~ , t 2. illne ~s; 3. disciplina:Yy aci i~an; 4. inclement ~aeathc r; 5. seasonal l~iy-offs; 6. absence f~i• pErsonal reasons other than illness (es:plair) ; r 1 i. Tl~e exact an~o~zr.t of your take-home pay for each of the past 15 pay periods and clesignat:e the pay-periods involved. j. The ar,lount deducted from your gross salary per pay period for each of the following 1. federal income tix; ~ i 2, state incc>nle tax 3. social security ~:ontribution; 5 ,j ., ~J. ~;•rl! .;. (l.i L.)1 cl is (:;) ~ 7. pxo~it-s,rc~ri.ng L~l~r cr oth~_r r.ctirement plans; Q. lltllOn dues or assessments; 9. credit uni.an payments (give details); 10, waye assiynments (give details); 11. charitable contributions; 12. savings plans; 13. Qnployees welfare fund; 14. any other (specify in detail); k. What benefits noes your employer (s) provide for t~ you and your family? Please include, but do not limit your '~ answers to, health insurance, life insurance, any pension or -~----~: ~~ profit sharing plans or retirement income programs, automobile usage, expense accounts or credit cards, disability benefits, etc ~~ ~::~ 6 Plan; ~ such plan; 1"~. .i._ - ~ .. cl l .. . 1. i.1r` .. :~ ri! ~i~~. Li _ Ali l_~. l'.,,. ~ ... .111; ?.. ~hc ~ • nin+~s can ~r i bt• i.•_.:+ 1'1 y' ~l, t~.~ c~<lcn ::~ Ir-11 3. the current value of your account unc7cr each 4. the named benei:ici.ary; 5. the Hanle and address of the location of each plan; 12. From your present ~ip.loyment as answered in previous nterrogatori.es, are you partly or fully compensated on a com- ission or other incentive basis :? 13. If the answer to the preceding interrogatory is affirn~- tive, state the annual conm~ission received far each year of mplcyment. 14. If you o~m any partnexeihip or proprietary interest, tate a. The value of any irrventoz~y or business ec~u.ipment; b. The date and amount. of purchase of such inventory r c~uipnlent; 7 m _._.._- e. i~ c::~ r~:it. ~.~~~ 1. :.~. _i.:~n G.. Ca~i: i~ _ ... ~ `, ~l~_~° .; r i'-red 15, tlrc~ you now, ur 1~vF_ yc~~ ever tx:en an of.`.icer, director or ~k~T-tner--, (lir,~i.tcd or ~~eneral) in ~cny corporation, firm, part- ' nersY:ip, or- lincitcd venture? If so, state a. The nature of your ownership interest in such business; b. The position held by ycu; c. If officer or director, the years you held such position as officer or director; d. Compensation received from such business interest; e. Cc~cpensation received as officer or direotor; 1G. Do you or your family hecve ~n ownership interest in any other corporation, partnership, propr.~etorship, or limited ventur ? If so, state: a, The nature of such i.nte.~:est; b. The n><irket value of such i ,terests; B 6 i t 1 e i t t .~ ii ~ .. I i~ i 11 ~ If _ ~I ~.. '1'ii : ;t r• ui .- ~~it i c . , "i~:; , ,., v' c~r;ll,„ •-;li.i j, i ~itui_u.~ L.; }~. 'i'h_ t,;:;v~int ot: s~il~s k l i.ce }:~,yaL].~ f.o ;r~u I c. The tcr~.:ts o: each Ac~rcenlent< of Sa1c; 18. For each corporation in which you function as an officer or director, or any business entity in which you function as an oHmer, please r.~ake available for inspection with regard to each corporation and partnership: a. The stock ledger book; b. The corporate nu.nute hook; c. A list of all officer, and directors; ' d. A list of all partners, general and lirlited; e. The rlost recent financial stater.ients, including balance sheets; I' 1 f. The books cf original entry, including but not limited to the cash disbursc~nlent jou:rna'. and the general ledger; g. Copies of partnership, corporate and incon>.e tax `• returns for the last three years; ~,, :, S~ 9 4 r ~ . ~. l ~ ~ ~ • 1 ~. - ). 1 .. I I ... ., 1. ~ It ~1. i. , i ~~ /1 1 ('(>i ~~OLc.. ~_l;)i t. .ll , ...} .._ -. ::!ll. ~.~tl 'i' ..~ - iii I l'•~., j. Co~~ies ~< '. c'..~dc, r.~.~~rt~}: ~..~, <<., ~cn:^nt: , of: sale, t ar.cl oth/•r docur~ent^ p•,•-l;. ,1 i.r:~JNtci thr~ ~~~,. ~•ts nt.n,~cl 1,y Z ry bus.ines entity in ~•~?iich you have an <~~•~n~rshi}> int~~r.c~st; k. All cozrt~spondence, r.ieniorar.da, anti all other wxitinys pertaining to any real estate which is owned b;,' any business entity in ~~hich you have an ownership _.nterest; 1. Copies of all pension and Frofit :.haring }Mans; m. Copies of all deposit sli}~s n~ac]e by each c::orpora- tion or partnership to the business account; 19. Did you receive any other earne3 income within, the past five years? For each such incor.~e, state a. The amount of such compensation; b. The nature oL the ~•lork }~erf~~rmed by you; II c. T}le narie and address of your er.~ployer where applic- able; 20. Are you entitled to receive ar rionies from an.y ~eferre~ Cor,ipensation Agreement? •• ;, ,, . ., i~ ~~ I' li I L. lf~i' ~u~.~Utl:lt_ yUU u:. c' trT rC`C :'~'r• Ui~'~i•[- 5~~~;il L)i: c:l"rE'.CI ' Co ij~cnsa~_ i r>n ~~yrccr.~.r•nt; 21 . T,rr_• you receiving any roy~tlt.y : nco~n^? Ii so, for each such irtcon~~ sL~~te: a. The nature of such income, including the nature of any compensation, e~Trk, or patent fror.~ ~•~ktich such income arose; b. The amount of such income ~~early; c. The terms of any agreement in relation to such compensation, work or patent; 22. If there is a wage attachment ~~r other order to pay out of earnings effective against you, state how much is taken from your earnings each week, for whose berief.it, and what is the balan due. 23. Please list the nanie of your: a. accountant (s) ; ~' b. stockbroker(s); c. investment advisor (s) ; _ ~ ~ _ s t i ¢e ^ ,r _. ,,.,-.,yr. !~. I' it .~. 1;... cj` r„-~,~-c~~~! :.. , ~. Court filed in; c. Names and addresses of attorneys for each party; d. Nature of determination or other results of each proceeding; 25. State the total ar.~ount of nH~ney per month expended by you for the support of yourself, your spouse, and children for the last three years; 26. If you contribute to anyone's support or welfare, not previously mentioned herein, please state a. The name and address of those whorl you support; h. Theix relationship to you; c. Amount and frequency of support payments,; d, Whether voluntary or by Court ordez; u --- 1 ~ e. Name and address of Court and every attorney involved; 12 li _ _ .. O~ 1 - .. I li I 1 r • .. ,. I ~ ~r 'I - I . r. i • ~ .. i i 2c:. `' I -s t.r *. h.• n..-. • . ~~nri J.C• :,r i i u:t:, r.' .tn,~ cl ui~^ t soC ~ tl 1, <1:..i1)_i-•L1C O'' C>llt••t~:_i.SC`r to 4/~"11CI1 'yaa 7.JC'~U:1(J; ]1tSC:, f0:" G.l~.h CI.UIJ, :~tilt.~' a. 'I'he i.nita.a±: ion f~~e for each; b. The annual fee for each; each; c. The arlount of additional money that you spend for 29. List any c3ifts or contributions made by you in excess of the sum of $100.00 within the past three years; For each such gift or contribution, state: a. The name of the donee; b. The reason for such gift; c. The amount of such gift; r~ d. Whether or not any gift tax return was filed in respect to such gift; 30. Fiave you r,,ade any application for indebtedness within the past five years? ' 1 3 i .. .. (~ i ..,. -- i(' ~~ !J. .~:. ~i,.,v.:.:% Ui. J.fl~l:'fit...~~~itr.g'. L ;11'.•tiCCai c. i}~F, i,ul-i'u:c fc~r t;fich sucif lv... tails rc:yt:cstcd; d. Tits disposition of. such ap}>l.ic lion; L. Please attach a coF~y of each such application to your anst~ers to these interrogatories; 31. List all safety deposit boxes acmes. by you individually or jointly with anot}1er party or any other s~.fe deposit box over which you have access. For eac11 such safety deposit box, :Mate: a. The location of each such Llox; b. The number of such box; c. 4liret]rer the box is held individually or jointly; d. The contents of such box; 32. List all personal credit cards owned by you individuall: or jointly with another person. f I ~, ri ... ~ ~I 1'_.. '1 ~. ')'. 'I;_ C.~ L'.. •'l.r ~ I I).• 111 I ~ (. ~ , c. 'ih', L •)rr~rnL t.:~rl%)r2c~~• o•.1eLi rr;>vr r~)~lr sircir c~+ra; R b I d. F'1~'_~:,~ attac}r your n:o:.l.},ly stcitc~t::::nt:: for, llie .lest three years for caolr c~srci; 33. List all savings, corm~ercial or chec}:ing accounts in your nar.~e, solely or jointly with anct}rer, with any Uank or financial ins tituti.on For each account, state: a. The name and ac:dress of the )ran}: or financial institution; U. The type o~ account; c. The nar,~es on the account; d. 'Phe person authorized to draw on the account; i e. The date the account c~as open~:d; f. The date the account was c1osE~d; - 15 - 1 t I i fl ~ 3~,. I?a•rc. t:~er~ beer. any L~%~nk accounts c:urS r~,~ ;.h~, course of your n~<<cci:~cJe on wlii.c}r your n_irie c.ic} no }. a?>~~ear, .in wh~eh you deF~ositec{ 1:SOi1Cy7 , ~~. 7'h~~ na;~~ and acl^rc^~s of the Lean}:; b. Each nar,~e under which the account stood• c, The account nunrLer; c}. The aprroxinrate date and amount of each deposit; e. The reason for each deposit; 35. Have there been any bank accounts during the course of your marriage on which your narie did not ap},~ear, but front which you withdrew nr~ney by check or other r.rethod7 If so, for each such account, state: a. The nar,ie and address of the Lank; b. Each name under which ti7e account stood; i:t c. The date and ar,rount of eact withdrawal by yo~c; 15 - 1~ ~ ~. ~ ' , I' i~ I ,, ~. ~ ., .... ... ~ ~ ~ I ~~^'.~ , 1.!It~i. I. i i,~~ ~ .,.1. . .. _ G t..} 11L;e. ~ .1 .L± .;~, !„i r:~cl: ~~ ity t:o w<<icll yv.t c~.:r~s~_u:ll s«_~curity, please st~r.• a. `i'iIr' nar;la of tlfe cor.poratian car t}IC issuer; b. Tht~ nur,lber of s}far.es anU i.l~e face arlount of such security; c. The date such security wa:~ purc}iased; d. The r,faturity date of such security, if applicable; r~. The current r.larket value c>f suc}i securities; f. The dividends paid by each such security for each ~f the last five years; 37. Are any of the shares of stoc}~: o~~med by you listed in the preceding interrogatory subject t:o any cross I>urchase ~r reder,IZ~tion agreement? If so, state a. The date of such agreement:; b. The parties to such agrccr,fent; .. ~ t ~.. f I ; 1 { i~ I! II !i' II }:~.. St•~~,:. C'. LiIIU :.Il`.- ) }. _ .. .. y' .ffit`l ;ltS O{ $:i !)i_i (1.1 Il U~ r;:_.c. ~~ clllr.i I:c~ , ., <::~•.• ~~~f }': ... ..,_t~ Y ~ ~:•~•... If ~o, plc w~e state: a. i'iI~ t}'f>c and nar.:e 'c,~ thc in•,~esLi:,~I~t; b. The date ~f acc~ui.sition; c. the value at the tinge of acctuisition; d. The consideration; e. The _nstitution or person Faith catior.g the investment was initia111 placed; f. The date of disposition; g. The value at the tinge of dis~,osition; }~. The angount of ngoney or ott~ez• consideration realized at the time of disposition; tion. i. What was done wit~I t}ie l~roce~eds or other considera-~ - ' '' - ~~ i : ,~ r ~~ L. L. 'i~~~~~ cl,ltc o~ ma~ur.it~, of ~;.i~~;~ ;ns;l ~-~.,r~~•n; ; c. The ar:~oui:~ of. interest p~a.rable L-o yoti yc~a.rly under such in~trur.~c•nt; d. 11~e nature of the sale or transacticn (type of r.ierchandise sold) .from which said instrument arose; e. The date the instrument was acquired by you; 40. Please attach to these interrogatories a copy of your current financial stater.ie.nt. 41. Piave you at any time within t}ie past three years re- ceived any incon~, dividends or return of capital front a;ny corp- oration (close or professional) in w}~ich you have a 5~ o:r r,~ore ownershi~~ interest? 42. Iter,iize all income benefits, cash and non-cash,, not already included in your answers to any preceding interrogatory, 9uc11 as, but not limited to, pension plans, annuities, inheri- ~ tances, retirer.~ent plans, social security benefits, lottery ~ prizes, bank interest, dividends, etc., and for each, please list a. Source of the benefit; i ~, _ .. .. .. ~ J'~ .. S 1 ~~ I i I li yUU vl '_11 ClJ =~C~ :+!. i'.h~~il~ ~, ilU~ Ii);1 4i) 1'iU~. ~:;''', r'lcas.~ L':~'r.i_;i: c<~;~i.e:; ~,f ~JTiy t~~,J~~:.. ~i3. IJOCC 0;: 11aS FI:.y COrjlUrcttlUn (1Il V/11 J.CIl yUU U+••n at lca~t 50 owncrshiY~ intr~r~~st} , partner"s-hi}~, joint: venture ur ~•olc: 1>ro- prictor~hip referred to in the Preceding :intcrrogatori.es or do cr have you individual].,: or. with al~yone cls~ poor hold or have geld any interest in any real ~rai~crty at any time duri.ny the past three years? (lnterest in real. tirot~erty as used }terei.n shall Iuean any interest, equitable or legal, whether. ar not of record, whether or r,~,t expressed in writing, whether c:ontinyent or vested, whether eaccutory or not, and shall include any proper t, interest wlu.Gh niay now be under 1lgreenient or ot>tion) . 44. If your answer to the p.I:ecei9ing interrogatory is in the affirmative, state fully: a. The name and address of the entity or individual in :hose nar.ie tPle property is titled; b. The address and legal description of the property; 45. Does or his any corporation (in which you oVrn at least 52 ownership interest) partnership, joint venture or sole pro- prietorship referred to in the preceding interrogatories or da or have you individually or with anyone else, leased o.r rented an}~ property or pant of such property ~o any person within the past tllrec years: (Property shall be defined as in interrogatory nur,iber 43. ) i ~~ 4G. If your ans~:er is in the affirr.Jative, state fully: a. The na;.Je and acidness of the entity or individual in o>}~vsc~ name the property is titled; t . ~ ~ ~ ~ i ~ l i i i 47. II~•; ,ny re 11 I>roi-~•--rly rc(err~~l to _i ~ the i,rcc'ccii:,-J ~ interro~atc.~ri.c~> L~c~en solu or otherwise tr.ar~sf erred c:urinc_J tyro Fast U~r.ec J~.~T's: 4it. If your answer. is affrr.~at-i.vc, and if not heJ.ci Ly you, identify the emit}~ ma}:ing t}~e sale or t.r.ansf~r an'' Gtate fully: a. 'l'ire address ~rr~ci l~~al ci~scrii~t:i~~ri of tlio i~LUj~er-ty sold or transferred; I b. The date of the sale or transfer; c. The nar;~e anti address of each person receiving an interest in the propertl an~i tyre interest acquired by each such person; d. The purchase price or other consideration received for t}re sale or transfer; e. The amount of the purchase pricy currently unpaid; 49. Does any core oration (in t,~hich yon: ~~.m at least S$ vwnershi,p interest), partnership, joint vc.ntu:re or solo pro- prio _~~rs~hip referred to in preceding in terrog,~tori.es or do you ind? v: dually or with anyone ~clse have a.ny ayreer,~ent . written i or o: a1, to purchase, sell or otherwise acquire or transfer ~ an i-rteAest in any real property? r I ~; - 21 - i `r ;7 i r i i i i i i' ., i Mi :. ~i'1. •'!~' ~t'.:!~ inl~l:~(',, U; ~ :_t('ll ~, ~ ..:~1~ b t~ .1 ., ~: 1'~ V ~:. ii f.itC. ~t~J1~E'CnlCtlt_ 1.~, :CCCG:.-C~E':~, ti1C' ~:t:~1t_C ~!"1~l COL`nt~' JI of recorclinc~; d. '1'h~~ terms and co>tdit i ons of the agr.ecr,~ent; e. The name and address of each person ~~ho ltas custody of t}le agrcer.~ent or other docu ;ientary evidence concerning the agreement. If you will do so without a P-lotion to Produce, attach a co~~y of each such document to your answers to these interrogatories. 51. Uoes an}~ corporation. (in which you own at least: 5~ ownership interest), partnership, joint venture or sole F~ro- prietorship referred to in ttte preceding interrogatories or do you individually or with anyone else, have an interest, or have they or you lead an interest anytime during the past tllrec: years, in any stocks, bonus, or other securities of any kind in any governr.lent, governmental organizations, company, firr,l or business incorporated or tugincorporated, foreign or domestic? 52. If you answer is in the affirmative, please state: a. The description and identification of the security; b. The identity of any co-owners or interest 'holders; ii c. The present market value; ~7 ~. , I ;i ~ . _. ~_,._.:t 1..,~ . , ~ 5',. I':~ns~ify a.tl ban}: <us<i .:.t~.•:n~1s as:: L:~an n: _oc.i~,i•.ic~r~ ~ aCCUt1:1tS, i:.lIItC CI~•f~US1tS, C:Crt1.l LC~~tC':i Uf C~.t{lU.`~1. i. , V1ng5 L7UIlC~f,, treasury notes, sctvin7s cluk~s, thr? fit. }?'_ar:-;, r.:olsey r.ktYket ftlncis and chc•ckin~l accounts in yostr r,ar,;e or in t IC nclric of any co.rp•- oration (in ~~}rich you o;rn at l~_ast a 5 v o•.a;~ ,r:>hiF~ intcres t ) partnnrstii i., faint venturf~, or sc~lc pro~~ri ctursYi.i~~ referred to in t}te ~~recedinc~ interrogatories . 54. For each itetu identified in the ~~receding inter.roga- tort', state a. The location of t}ie account or other item; b. The account number or other _Ldentifying nur.~ber; i teri; c. The present balance therein, or value of any other d. idan~e and address of each co-owner or person authorized to draw on the account; e. The identity of any custodian of a passbook, certificate, etc.; i 55. List any and ali amounts owed to you of whatever natare, and for each list: a. The identity of the obligor or deLtor; 23 . ... f i ~ II ~~ I~ i ~ ! .., ~.r .l' ~~ .. ~1: , I I' 1 I d. f:n1• tool <.I l doru:,ln1 ~, rc~~,' i_n~l til~~t:ul.c~; 56. Does a;,y corporation ,(i.n ~•~}iicil you o~•~n at least 5~ oamc~rship interest) j~ar.tnership, joint ventur.c or sole pro- prietorship referred to in the preeedincl in ter. r.oclatories or do you individually have a, other personal. property, tanc~iLlo or i.ntangil,le, including but not Iin,ited to such itcr,,s as cash, furniture, equipr.,ent, jewelry, precious metals or stones, auto- mobiles, trucks, aircraft or other recreational or transportation vehicles, courses of action, copyrights, patents, ~;~ineral rights, tinier rights, or any other thing or things of ~~alue? 57. If your ansc~er is in the affirmative, identify the entity and state fully: a. A full description cf tlic asset and tt~~e titled oomer; b. The present location of the asset; c. The date and method of acquiring the asset.; z i d. The serial rn~n,ber or other identifying nur,,ber of the asset; e. The purchase price or other consideration furnished for the asset; f. The present val~.ie of the asset and state how value was calculated; 24 . ' . ~• it ,...,,,, . ~ r .., , ,• ... ~~). 1lFtS v'?2~• ;:GiE~V: .1L1Ut1 ~lti ~',,' ,.i~. y.~L. ,r r'li ~!~. ~i•il.~. ~, ~,'. G..n,,.. ~-;;tll~: ! it r_ti.r _ _iL) i4lL 1 I1...-r lll, ~Cr ~ i~ i Vi ~ ~-~' . ._,.'~ i' }-):~~~i+i. .i C`t- or:.,liF> refcrr.c~~i` to in tl::: "c~,ciil:~i _i.,lli~rzt'~;atc,l.;..:~ or }::wu you inuividusily o~ with tlnyor,c else, giv:~n, sold or otllc`.rwisc tr~lnrs- ferrcd any asset or t11ir.~ of. va?.r~` Lo ~:::y t,c.l'~;n?, or entity for less t}:~,,1 its fair r,tarket value: du? it;~ the p~:sL t.'nr~.c years? E,U. Do you recciv~, or }save: you zcccivc~d daring tlic east three years, any gift, stipend, contrihutiotl, cor,li~ensation, gratuities, }xxnefits, services or goods fron, any source, business or otherwise, for arty of t}>e following personal expenses: a, Living accorlodatioa~s, including, utilities and related expenses; b. Food, household products and sundries; c. Autor.tobiles; d. Clothing; e. Recreation, entertainreent, (e.g. club n,entberships, dues, etc.) f, Vacation or travel; g. Medical/dental care or insurance; h. Life insurance; 25 ~~~ ~. I ~! N 1, Ui.l lC'1 (:~ZJ ,:cl L j~ 61. Art you t}~e holder of acly .r.ent.~l. F>~a}~crty? If so, for each propcr:ty, state: a. The type of such property (k;eal or pcr ona].) ; b. the location of such property; c. The date accJuired; d. Ache net monthly rental to you for each piece of property; G2. Duri.ng the course of your rlarriage, have you o«nc:d any interest in real property? If so, for earn parcel of property, s:.ate a. The address; " b. The size; c. A description of each buil~~ng, structure, o~ other inlprover,lent presently on file property; f ,. •• .~. .. ...l 1.1 • I ... '.)~ ~ I ' 1I (I 1. :~1:~ r~_1;.. Cin~i a:~c~i ~' o• ..l~l t '1 c)r i)~~~...c.~n 1] cll~~ whom Llt~. ~~ .ral .i C1.-~1 ~)~.: ~ci; g. Tls,~ data <~ncl p1acF~ the decd or other dOCUIlICIlf: of title i:~ located; h. The present locrltion of t}ie deed or other document of title; i. The name and address of each owner and t}leir respective oamership of such; j. T..~ purchase price; k. Z•; hat portion of the price ~•~a s in cash and what portion was financed; 1. The details of financing and the present balance due on the property; ni. Tlie approxim ate fair r,~arket value at 1. time of acquisition; 2. time of separation; i. I~ 1 2 , .. U , . ~ . :~~~, ti , n. c,r t~:i i>>;i; .,., c:•tkt.i , lu,lc: ~~:.. ii :..o, fc;r c~_ici~ iLcr~~ or p.rt~F,~~zty, sL,~Lc: a. Tlw r.:~:.~c anu address of e~.ch rzich ~~cr,on, fir;a OI' ~LlS1Ili:S;i entity; benefit; b. A description of the property bci ng held for your c. The conditions under which t}le property is held for your benefit; d. The approximate value of the property; 64. Aze you holding any property for the benefit of another person, in trust, or otherwise? I f so, for each item of property , state a. The name and address of the beneficial owner; b. A description of ttie property; c. The value of the property: 1. at the tir,ie of acquisition; i i j {~ ~i ;~ ~! ~; ~: i' II 28 1~, ~ ' 1~ ~ ~1 ~_ '~ ~_ i ~ .. ~ , 65. ~~ince tht filing of t`,,^ ciivorcu c-,r.~:l~~,int, did you tr.an:;fcr amp F>1'C~4•CrLy .1 :1 4i}'t.LC}1 yOt: COnt=17.7ir~tl r?1~ Llil.('."~'~~t . I f so, for- ezeh item o` }~ro;:crty 'sans; f e.r rc~cl, st~.~ik~~ a. n con~;~J ete description of the }~royerty; b. The narue and address of each *,xansferee; c. The reason for the transfer; d. T}iE: amount of consideration received for each transfer; ~G . State whet}rer you have ever: purchased any real. or }ersonal. property od~ich has been placed in t}re name of. your father, r,~other, or any third party other than , c~u.r present spouse. I! G7. State 4.t~et}ier you have sold, trar;s fr~t:red or assigned any interest you niay have owned in real prof~erty within the last fivr--~ years. ~i I I f so, state : a. The interest held by you; _ -, li i~ ii u I 1 ~ i . • C~ i i i i cl. '1'hc• •~:,rox.i:., : 4L tc~ .,^, ] i n;, 1~_.. ~ ,-~~:~. ;v:, , t~ ~t= ~~~ccc~r.d £ror, the sole, ':y-'a r:sf~~r or ass>i~ur,GnY; c. T're nar,~.e~: and acldre::~c,: of tlt~~ Fx,:~~an or pcrruns ~'~ to caho.~, th~ r.eal p ro;~er.ty 4rts s~.,ld, trarts.ferred ~r assigned; f. The date of acquisition; 6B. List all tangible personal property, giving desc;r:_p- tion, date of acquisition and al,proxin,ate value pre:>ently held by you in your name alone. 69. List all tangible pczsonal property, giving descrip- tion, date of acquisition, anti approximate value prE~sently held by you jointly wit} your spouse. 70. List all tangible personal property, giving descr:Lp- tion of acquisition, and appror,ir.,ate value presentl;- held b.r you jointly with any person other than your spouse, diving the name and address of that person. ~~ 71. Are you the owner of any airplanes, boats , motor I~ `ion,es, recreational vehicles, horses, or the like? l If so, for each, state: a. A description of each sucl, ite*,; b. Date of purchase; 30 !~. .. ,. ,. .11'. i I i i M ~ i f. Its r.r<~ri`tit value; g. Wh~:ther held iilu.ividual].y ur. jointly wi.til another person; h. The name of such joint owner; 72. nre you the o•,aner of any paintings, coins, stamps, jewelry, gold, antiques, or other such valuables and collectibles' If so, for each such item, state: a. The nature of such item; b. The location of such item; c. The date of purchase; d. Purchase price; e. The market value of such items; f. Any .encumbrances against su~~h items; +. ~~ k ,, :~ - 31 - l.3. StAt~~' .:{1C~.it~,.ii `ful: }1;iVt- .,'+i({, ~.~'+lI'. •{i•..- ~t~r{ 7i- ,4~~;11C:., F][ly ]ilk-CYCfi~ j%C.1U' hlcty ~1:7VC C+'.':[!r_:_~ X11 L;•.7~~1~~i ~. i+i U(•i`It-~' 1I1 +t:: li..l:it tilU y~c1Z~`_i. If so, stag a. The interest held ,by you; b. Whither held by you alone or jointly wit}i any other person, giving the name and address o:` those persons; c. The approximate selling price and your net proceeds from the sale, transfer, or assignment; d. The nar.le and address of the person or persons to whorl the property ~•ras sold, transferred or ~issiyned; e.. A description of the property; f. Date of the transaction; 74. Identify any and all liabilities cr ovligations of whatever nature, including a list of credit card accounts, that yot' rlay nave, ~iicti are riot disclosed in prior interrogatories, ali a for each, please state a. The nature of the liabilit:Y or obligation; b. Date acquired; - 32 - 1. ,~ .. , i ~ ~ 7. c ~~ ~~r;c~t. ~, I I f. 'i'he account nurit~:~~~; g. The amount and frequency oL- payr~cnts thcr.con; 75. Are you the beneficiary of any ~ .,Late currently in probate? 7G. Are you currently the beneficiary of any trust estate? 77. Are you tt~e grantor, beneficiary, or holder of a power of appointr.~ent for any trust created by you, the members of }•our. fancily, or by any corporation? If so, for each such trust state a. The date of the trust instrument; b. The name of the settlox~ of each trust; c. The nar,ie of the beneficiary of such trust) d. The an~ount of each trust corpus; - 33 - • .. ~ _ ; ~' ~~ ~ I. ~ :~ .'... 1~1~'!_ rl'.t. ::i(t 1ti:....tP.::t.' ~•'IClc .~ ]It .:~'til'•~ )'O:1 ill-~_, `-t~~. ~ C":111(_':., 1.11:.: 1.:l CCI, G1. :a.':..., ~' 1;.}'~ i]11:~ jl,; f~.,~ i, Ui .'il `.; •.' .`~~.~~... . I 1 a. i'il~• i~; ntit y r,t tht~ it:::urrl~',: _. c~n;,;~aay laid ~w.].i Cy I ~ nur,lir: i ; b. Face attlount; c. Identity of tYte c~mcr, insured and bcnefic:iary and any relationship to yau; d. Annual premiums and t1~e payer; e. The present cash surrender value; f. The date each policy eras purchased; 79. Has the name of any' beneficiary of any of the insurance policies referred to herein been changed during the last three years? EiO. Did you file Federal and State income tax returns for each of the past thr~.e years 7 Z f so, state a. The full nar:le and address of each return; i • b. The filing status; h ! ~.. i .~ 'r: .1 ~ I ,. ~ .. ..~. ~ ~ ~ ~ tai ... '1 it^C-r i.. ,. ~ 1)l iii it _. ~~.. ~ .:)T } Ill la .. ~. _... .1., c .. ... tea. li<<vc you k~ _ any other book:, r~~co:d~: or wri.Ltcn mernar.anda of Jour inc;;:rle ac,d b`..sine'~,s aff~irG? 82, }lave au at any time during the court of your marriage filed for an individual bankruptcy in the I3~~nkruptcy Courts of the United States? 83. List all gifts that were given to you individually. during the court o£ your marriage. 84. List all gifts that were~give:n to your children andlor other dependents. 8S. List all gifts to your spouses during the course of the marriage. 86. Since the date•of your marriage, have you been invcTlved with, slept with or ha.f sexual relations with any other individuals other than your husband? 87. If so, please list: ~- 1 .rr~'_ a. •N~Ve cf individual(s~ b. Addresses 35 - . Cf~;E'.'1'I I~ I Cfl`1`]~; 0~' ~ 1~.ItV I LI; I hert•hy certify that. o~i t:he cL•~~~ oi' October , 1986, a copy o£ thc~ attached INTEr.l2UGAT012Ir.S ~ca5 served upon the PLAI~;TIFF by d~~posi tiny a true and correct copy of same i.n tree United States h1ai1, postage prepaid, at ~i'Illamsport, Pennsylv~.ni.a, to their attorney of record, BRADELY L. GRIFE'IL, ESQ. 200 North Hanover Street, Carlisle, Pennsylvania 1.7013 Iiy Martin M. Fine, Esq. I.D. #,! 07527 3~'2 Court Street Williamsport, Pennsylvania 17701 (.'17) 326-1.761 r ~~ CERTiFkD TR1~E COPY i ATTORNEY FOR PtAI~l11FF t ~ r. L ti, ~ i '!~ t 1>,11,;. D><'li`~iF: OF P1~R'i'Y SL7L'.•{ITT I NC; : 1? ,, ~ i 1 a n rl , f . l3. ,1 1 ADDRESS: %~i0 Ninth ,^>trcrt, Nc~~• Curnbr~rl:rncl, I'~l 17070 TF:LE.PHONF. i~.r+1gER; ?7~I-5279 DATI< OF BIRTE{: Oct~bcr ?5 , 1.917 LENG'T'H OF RESIDENCE: PE*3f35YLV11NIA: 37 yezrs ?j,'~s~, CO, ; 12~ yea.rs CUbil3 . DATE OF ~E : July 2 , 19 6 G IDATE OF F I NAI, SEPARATION p~~ pF MARRL~GE: SYilliam>Port, PennSylvanil NUhIDER OF MARRi}1GES: Onc .2fILDREN OF ~SFIRRIAOE: Name: IIirthdate: Custody of: C'ire ~Qry K. >~ n 1 't L'tIlt.~Y ~ E L6 ? Cnvjn F- R 11 Anri] 11 197D C,r~nni fr,r R_ Rnl l ,_Cr•r5tnmhnr 1,'~~ 137 NAME OF QKPI.AYER : .~~ r i ~ (', r e e t i n~ s ADDRESS: .10500 American Rd.. C1 vr~Iand. Ohio 1 JOB DESCRIPT'IC;N OR TITLE: Part Time Merchandiser LEZJ(;I'Ei OF SERVICE: Senter"ber, 1980 - ~1 vrs. S.S.N: 1.84-38-5013 A?:f PL11.'v'S EC~R FLTIfiLF: FPC,GITIG.'V: /1ftc~r thr~ rhildre~n ,~rc~ c~duc:itcd I ' cl 1 i l:r' to pct my denrc~c~ i n bur. i nc~~::; , STt,TUS OF F~~1I.T'}f: Gooti SPF7CIFY COI'fiITIGNS AFF'EX.'I'ING ABILITY Tfl W1DF'.K: I' ~ccpt chi. ].dram care - age 18, 15 and ?2 DESCRIBE STANDARD OF LMNG DURING hSARRIAGE;: ~lvera~e DESCRIBE FEE; ARRANGEt~NT WI'IT-i YOU'R ATIC~F~'S' : ~~ D u r 1 Y ._ ~~ l r .. ,.,il .~~ ,. •,. . .,r ~ i!, .. ~'~ •`l: ICJ I~~,f,l:.~~.. r Cc~~~lt~te thy: fo,lc;«iny Inc~.rr:, u;:~i E:~~ ~n~e Sty+tFZ~r_r.t. r.;.i :~tt,:~c:h to .it: t ~ l.. Cc~;>y of yc:ui- m~:;t. rec~;:L' fe~lcral inc:r_~r~~ x rr~tu;-n. ' 2. Or icr i n:,i or c~hi~~s of piny pay stubs or eurn.irys statc- :rcnt~: i~~r tht: ~~st six ;:onths. (IC •yoi.: ~,r~ s:`if-~_l;~l,~<<~: or if you ~r~~ s~il~nricc3 by a busi.;itss of which }~cni art a~::~:r ?.n ~.:t:c~le ~r part, you rn.ast also fill out the Supplemental Inccn~ 5tatcr~nt whic'n ~~Nr~tars on the 1•:ist page of this Inccrr~ aril Expenses Stat«.~rr_nt. ) Inccre and Exx~nse Stat«:Jn,nt of: _n~,~(~~;~,~_ I tiCf.Y.¢; Fi:~lo}•er: ^tlmeric:an Grectini;`i~ __ ^~~__ Address: 10500 rlmoric.tn Rcl. 'Type of .work: l.terchandiser~lrt--tir~;e 30 hrs! Payroll Ntanber: 45039 `~ Pay Period (weekly, bi-weekly, et:c.} : wcc~kl.v Gross Pay Fer Pay Period: $ 153.00 I t^^tized Pay:-o11 C~cluct ions Fec}eral withholding $ 12..59 Sxial S~ari.ty ~ Luca 1 wage T tx t State Inccme Tax ~ q rq Retirement _ Savings Bonds ~ _ Credit Unian Life Insurance f is i 1 th Insurance Ot~cr (sja~c;ify) Oi~;:ibi 1 i tt 1~i.00 ___ ---- ~125.3R -~.- I ;i l tir, :~c~ t ~:?5 . r)~ ;~ ;vc•ek ~.cc,rk i 1~- ~? h r~:. ra . ,.... ., n SaturrtZV at the ~/ ~• ~.. •, ...,'fit:. ~R•I~iV ~. li. 7f1 ~ ~ %(1.1 ~i? Cc~i;.~~tl) _ ir~'v ~ -- S-__ _ _..--- - a _-- - - An: ~u t t y Social ~~c~~rity --`~ Events _~_~.._____ __._-__--- Pol a 1 t i.~s ~~._._..._ ~~~_,. _._.____~_... EXpense ACCO~,IRt ~~~ G i ` k s `., _~ .__. thempioy-rent C~m~x,~nsation ^~r_ _ _ Workmen's Compensation ~______,_ __ --~---- 'Ibtal S ~ ~~ S 5 1 883,00 'POTA L I ?;('Oht E : 5 ;. ~ i' i -- ~. t: t .~ j i ~ 1 ~~ l I - ~~ .. • I .. ~ ~' .S ' _ _ _.. r'l l1! ~fii _ __ Ott:~•C _ ~_ ~ L.f ~ . hf) -~~-~------..._. f:P',~) r~~f rrl: •r1 4 lun•:n _- --- -- -- - - `-~O , f)(l.._.. _ _i RC) . OO,~;C11t~Oi 'l'.Ixas <~c~~ Rezl F: t 5 ~ 5 2R7.~1(l in mortf*~e __ . ._ -_ - - _ ___.~_. ___ .-..- - ~ Q ~Q Personal Prc:F:•:r t~' ___ _______~ ____ .--_--_ ___ -~'T~Oay- federaal Incorrt, ---- ---_-_ _ -_--- ---- ~~~ ~; t 1 L' e Insurance 58.00 :Local Fiomeo'.~mers ~, $ gin mort~a~e _ ~ "~?:~'tJ=includes Ed' Au tomub>_ 1e ---- _-__ -Z*~~i3--O'C~'t~'7.20-T'c1' s ) Life _ Acc dent ~ ,_.~ _ Flea 1 t h Other Automobile • '50.00 600.00 Pigments 5 S 151.86 ~„•, 82~ . ~2 F1.re l ,1:5.00 ~_~ 720 .00 Repa>,rs 150.00 _ ~~>t ,l Lc~i 1 Cbctor S S S ~Q8.40 other hal. ~~ t~nt>.st t1ti~; fr~r t7n r nrttv------•-, ~(-~ ~.overed b " -~~_- ~ Ort.hcxlonrist -5c,ec,ncl chil d clue -+ ]Ed's insu ~bsp>_ t.~ i ____ ~t~~d t.c >. ne l-- i ~ _.r:,t?C1 al nek"'CjS ~C{LdS;;t.S EL )_1 .3 K1C1S ~7C7.1. • VV "~ ' .rac ~ ~ orthof~Tc~ devices) i I ' 1 Crcd t t ~;n}: ,crn ~ ~; Credit Cara C;Iaryc.r acc'uun~ hkYn R~ r ~ h 1 r ,:-; !,t i 1 }: [ aan;> Cred t t CYI ton S • ~;'I fl l :1.'(1.00 .~___.___._ ___~_..._-~--- -3~0~5~,O~S~ S ~liscel lancnus Ebusehold help S `~ C?ii Id care -_.--- PaFerslrrcks /magaztnes~pc>S tn~.~._,-`~- F~Jtertai;vrent Pay TV -_ Vacation _ Gifts ~__ Lega 1 fees Charitable contributions - Other chLld support _ Alimony payments Other 'Iota 1 ExI-,enses S ____.___ -29~i...D.C? 50C~ . 00 S S S g 115 .O C1 1 , 5 2 3 . ~l ?, 19 , 5 ~~ (:) . ~3 5 ----t-= - _•-- i 7th ~ __.__ ._ _... .~... i!~t %1 r ItiSURA~K'E: Crxnp<~ny ~~ ~~ .. .... Coveragf~* ff W C Polrcy Pn :bspital Blue Cross His _......_ Other ~.H.~~~L4~7~1. Cc Sims ___ Cnr~pnn}~ Ins. , `•tedical lti~ f31ue Shield _ _ _,.. Other ~,~,_ ~1.~;1,~~ R~ Sc.'n~ Company inG. heal th i Acc iden t __ , ____ Disability Income ~_ ____ Uenta 1 C. ti. 5i.~51and ~i Sons Ccxr~?:vey ins. ~.. Other ~ - - K. _ ._.. X *H=f-h~sband; W=Wife; J~lornt; C=~trild .' 4-~r ~: r rr t- ~ .;il3,.t'(t'.,icTc•c i^< <Gxl 1:. ii,,; ~I,t~, ~f .,. ; tai '.a;:~ ii ,,t :,~ .r.,..~ - ~ ~:~ r s i.^~ t ~~ c•n t i .y (h) ~.t*Z-„ to tilt:, ;sr,,t~.,rr_,nt -t cr,ny ~~; li,c foll~wirct r3u~ ~rnnnt~ ^~,•..r t ~hr-• p~~rrr,rr.;hty, ~otnt ~~•~ntur~~~, hrrstn~,>;~ I-ro£,~.,.;;~n, ~~~,~ , ~:r-a. ~r , ~r ~t~n, I ~t enttty: (11 the -,ost r<~cent Etc?~~r-~1 1•nCV(PC 'C,.ix .~t~,trn, ar.c3 (2) the most recent Profit and [.Ass StatF~;r~,nt . (c) .Fame of business: Pc3dress and 'T'elephone hltmber: (d) ~:ature ~~f bu:;tne~:.~ (^.he~~k ~~r,e) te) `;arn+~ .~t r.~~,r,~i ctttier •t~r..~. rP~•~~r•3., (1) partnership • [~ (2) joint ~.entr,re (r 1 1t . r L ~ (3) proEes:;trm C, (S) othc,~t i , r •,;~ r lc~j , 3 , • i ~ i ~ . ~, . t ~Xj i . ,, ~ ., ;n;, tt ,n ~: i .. S. i f ;~' i i ,~~ .I ~1( I ~ __. --- -.. --~ --- --~ .., ~,~ .r r t .. r' ` (Pla:,~tiff) (~~iendt~nt) files the follc~winq inventory and apprai:emcnt ,.~f all property owned or possr'ss~c' by either party at the time this action was axnmenced and all property transferred within th~~ preceding three years. ~_ (Plaintiff) (L~.ferdant) ver,fies that the statE~ments made in this 1 inventory and appr<~isement are tnae and correct, . (Plaintiff) (CeEenc9ant ) understands that false statements herein are m,r9~~ subject to the penalities +~ of 18 Pa. C.S. ®4094 relatinq to unsworn falszf~cation to authorities. ~ZUYIQKi~1iQ. Defendant ) 'a ~bte: List rto more than two or thre items on e~ich of the Following schedules except for Household Fhrnishings and Personalty. Use xlditional schedule sheets if .needed . . ~~ ;: i ,~ { s_• !'.~ i... i. ,. ~ .' { ) 4. C.rCC '~ [ !.i'.rt.•ti .,r r{..;Y,:;l.t • ( ~•) 'i . Ctilc_• n 11:.2 ar-~' ,[l; . c' r:";'1 ( 1 ~i. ~~~•!^n~, :r,•r•~,!~nts, ~~~,!,.,,,• m~irket .u~d .;.w!ras~ c-.~t-t1i ic~itt~s ( ) Crr`..:t. of s:~:~~ ~•:~L~~.:it 'r~,x~ , ( ) 8. 'IYu~ts li-? ( X) 9. Life Insurance ~ltctes (indicate face vaiue, ~.a:~n surrender value and current beneficz~jrzes) t ) .10. Annuities ( ) 11. Gifts ( ) 12. Inheritances ( ) 13. Patents, copyrights, tnventtons, royaltr.tes ( ) 14. Personal property outside the hca~e • ( ) 15. Businesses (list all a~~T~ers, including percentage of ownership, and officer/9irector positions held by a party wt.thLn company) ( ) 16. Eh:ployment termination benefits--•severance pay, workman's compensa- tion claim/award • d ( Y) 17. Profit sharing plans { ~O 18. Pension plans (indLCate employee contribution aril date plan vests) ( :~) 19. Rettr~~snent plans, Individual Retirement Accounts ( ) 20. Disability payments - t ) 21. Ltttgatton claims (matured .end unmaturerl) ( ) 22. !1ilttary/V.A. benefits ( ) 23 . EYluca t ton benefits ~ ( Y) 24. Debts due, including loans, mortgages held - } ( ) 25. fbuseh~~ld Eurnishtrr4s and person.ilty (include as a total category • and ntf ~~h ire`mized list tE di:;trtbutton of such assets is in dispute. ( 1 ~! 75. ether t ~•. L .11`c~ ,„ try . ~ `'.~ a~. c~•... f~ ;1ti-in ,,] I.nu>,r~ ::r1 i:. ,:. 1;~,~:i Ir~ncl Y. I;:~l l 11111;. 1~~:' Cost or Value Value as of Item as of Ik~te D,~te F1r_tion ,knount o£ ~Lmber of Accra is i t ion Cr.~l.rr,nce~~ nny Lien #1 X13,900.00 '. $25,000.00 Effective Item Nature of l~r,e of ;`Umber Any LLen Lien i i t Folder of Lien „_. ~,,~_. ~r ..~., + ._ i. r + Cc~Gt or V~+luc• Item as o: Date ~.1~mber of r~cquL~irion 3 828,700.00 Item ~.lunbe r Item ~~~ ,r .~ __` ~~ L s. 7 i ;r 2 r i~ tiature of Anv Lien A:1 ~~..i .~r:: n ,. L rri :' . ;t ___`--- - ~1.~ I. I ~)7.:~ V<,1u~ a~ of R~tc r`,ction rv*;aunt o£ Ccmmcn~~~d~! ~_ ~_Lien 53::. , 253.00 ' 'r.Ef °Ctlve Da to of Eiolder o£ Lien L1en &~si~ Fir Exc-l~~-;ins, frrYn Marital Property ~~ i' ~, r Fmount of Cost or Value Value as of. any Lien Item t~s of Date Date of at C1~te ~a:mr,~r of ,'acquisition 'IYansfer of 1YansfEr ~iture of any Lien E:ffect.ive Item .~t note C~~te of Holder of ;a.,mber of 'IYansfAr Lien __Lien ;!. i i ~~ i~~ 1 l l ~ 1 i, c~,~t~r,,.-i 1 +i :.t:stcurc•cl : , { }~ ) S , CrEdi t card ba 1 ~n~es ( 1 6. Purchases ( ~{ ) 7. tan payments Parent Plus Cc>1 l e);o l,~nn { ) 8. ~Ates payable ( ) 9, Other unsecured lt.~hilities ^.ontingent or Deferred: t l 10. Ccmtr~cts ar r'ygreer,~ents t ) 11. Promissory notes ( ) 12. Lawsuits { ) 13. Opticns t ? 14. Taxes N ~ ~ ) 15. Other continent or deferred liabilities • .. i -- - E i _- ~. i •' ~- ~ 1 ..1 •~_ _: .' .. r J ~`~ 1.1 ~. ~ I . t ..~fl'1 ~ ,i .~(~ I~a.rc•nL I'1 u': Uri.llr,cl"ntiat Cr~~c1 i t C'a rcl~ ('orntlu_>~t~:~c•,11 ..h `;;tt.ic~n~t1 I;,t~:l: It•tt J. 11r.r1JCt• U.I),S. <<rxxtnt, of Liability Item [htc L:~t~ni 1 ~ tv nn [~~tr. Incurr?d and tUmber :gas IncurrF=? Action ;~•as Commenced ~ ~ 1 t1u~;u~t . 1972 yt ~ ~~ 2 Ati~i~s't . 1.981 $~1 , 003.00 .. 3 11ay . J.984 ~ 900.00 I Pm Date P~alance Periodic Payment hUmber. is Q~e and Pmount 1 1997 X141.00 a month - 2 Au~us t , 1.939 ~ 66.73 a month ~ ,, ,, ~~ 3 Januart~ , 1936 ~ 70.00 a month ~ - r,_- ._ .. . __ i i ' '~';a ,,` - . ' r ~~ ~~ ~ _ ~~~'•• V ~ SA ~~'~ (11 ram < <_ ~~, ~.c r~ ~~ t , ~. ~ . c,,,t -- n T ., E? ~-r ~.,=, it L• il~n~~lE~,~-Y:~ :~~~~~~~ t.~,`~ `~~ (~ ° : ; , '` Vii` ~ ~ ~ , ~~~. ~ ~~ ~ ~ i ~, ,.rt. ~ „~: ' . , ~ ~ . t ` ~ ~ ~ l i ~1 ~', i >> ~~ ~ .. i 4 2 ~~ [^ .> r O a w ~. I ~~ (h r+ Q O ;: ., ~~ t .. ~- I c, `~ Z~ u, ~ F ~ v I` ~ ~ . 1 4' ? 1 (., ,J C1 c c ~. W a~ O ,7 Q ri C n C -, W ~i ..~ -. ~ al T~ t V: O ~ d O + ~ ~, u C~ a LL .~ o ~. ~ U v, U 'r ~ ~ F i~ I', I ~3D K. BALL, Plaintiff i J v. !ROSILAND J. BALL, Defendant J - IN THE COURT OF COil9ivi0N PLc.AS OF CUh1BERLAND COUNTY, PENNSYLVANIA CIVIL ANION - LAW N0. 1280 CIVIL 1985 I:J DIVOi1CE ORDER OF COURT AND NOW, this ~~'~ day of October, 1988, upon presentation and consideration of the within Petition, a Rule is entered upon the !' Defendant t.o show cause, if any she has, as to why this action should root be bifurcated and the court should not enter a Decree in Divorce i;pursuant to Section 201 (d) of the C~ivorce Code. i I Tne Rule is returnable to Courtroom Number `~ in the Cumuerland 4 County Courthouse, Car] isle, Pennsylvania on ~`-'~"`Jt"'~`~`~~ the 3~ aa,~ of '~ 1988 at .~ ~'~c.~ o'clock ~7.m. P~ ~'.yc.'a L~%~ y GY TH"r'. CUURT, ~~ I~ ;! '~ J . ,.; Brad:ey L. Griffie, Esq. Atr.y. for PlaintiffjPetitioner o c,° Gary I . F~eber, Esquire `-L' A,~,,~. for Defendant/Respondent ~ ~. ~ y- Z ~~:. zc~ , Y ~ m x o- --~ '{7 i ~ ~ '~; ;' L•'D X. BALL, IN THI; COURT OF CO6;ivi0N PLEAS OF Plaintiff CUtdBEl2LAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAYY i2OSILAND J. BALL, N0. 12F;0 CIVIL 1985 Defendant IN DIVORCE PETITION FOR BIFURCATION 1. Your Petitioner i~ the Plaintiff in the above-captioned action, Ed K. Ball , who currently r:~sides at 157 North lIanaver Street, .;Carlisle, Cumberland County, Pennsylvania. 2. Respondent in the Defendant in the above-captioned action, 'Rosiland .J. Ball, who currently resides at 339 East Ninth Street, New Cumberland, Cumberland County, Pennsylvania. 3. Petitioner filed an action for divorce through your Honorable ;.Court to the above docketed number on April ''?.9, 1985. 9. Respondent filed an Answer and Counterclaim to said Complaint .and served a copy of said Answer and Counterclaim upon the Petitioner on or about September 24, 1985, through her counsel, Wlartin bi. Fine, ,Esduire of 322 Court Street, 1Villiamsport, Pennsylvania. By fc.~rrespondence dated October 9, 1985; November 4, 1985; January 3, 1986; ;'February 10, 1986; and February L8, 1986, counsel for Petitioner att~.mpted to secure the cooperation of counsel for Respondent without res;~~nse from Respondent.'s counsel. 5. At the request of counsel for r;:espondent, information reg~rc'.ino Petitioner's pension, profit sharing, retirement accounts and related financial matters were forwarded to counsel for Respondent in the fall fo 19[36. ~/ 6. Despite requests for additional negotiations, no fruitful negotiations occurred through the remainder of 198E and through 1987 in this case. 7. In late 1987 or early 1988, counsel for Respondent passed away. 8. By correspondence dated May 3, 1988 and June 13, 1988, counsel ';for Petitioner attempted to secure the name of Respondent's new counsel. 9. By correspondence dated June 21, 1988, Jeseph F'. Orso, Jr., ', Esquire contacted counsel for Petitioner ana advised that he was !irepresenting Respondent. !~ 10. Counsel for Petitioner provided voluminous documents to r~. icounsel for Respondent to advise him of the current status of the above- ;captioned case. 11. By correspondence dated Septem~er 7, 19$8, counsel for ,Petitioner was advised that Respondent is now represented by Gary L. Weber, Esquire of the firm of Mitchell, Mitchell, Gray and Gallagher. 12. By correspondence dated Septtrnber 29, 19$8, counsel for llRespondent has forwarded a proposal to counsel for Petitioner which 'causes Petitioner to believe ti~at the parties will be unable to resolve 'this matter through negotiation. 13. The parties have been separated since April 1983. t4. Neither party will be harmed in anv manner whatsoever if the cou^,. permits the oifurcation of the parties' divorce action and the entry of a divorce basea upon Section 201 (d) of the Divorce Code. ~, 3 i ~ i WHERErORE, Petitioner requests your Honorabl Court to issue a Rule Ito Show Cause with a rule returnable at a date certain, at which time " ~ I i the Court Nill review the issue of bifurcation and the entry of a ~ Divorce Decree pursuant to Section 201(d) of the Divorce Code. ~~ I Respectfully submitted, I GRIFFIE, TURO & GRELL Br~I"ey-~ fie, Esquire 200 North Hanover Street Carlisle, Pennsylvania 17013 (71?) 243-5551 !' I VERIFY TFiAT THE STATEMENTS MADE IN THE FOREGOING PETITIUN ARE i; ;~ TEZUE ANU CORRECT. I UNDERSTAND 1'NAT FALSE STATEMENTS HEREIN i~1AUr, ARE SUBJECT TO THE PENALTIE OF 18 PA.C.S. §9904 RELATING TU UNSWORN FALSIFICA- '' TION TU AUTHUKITIES. EU K. BALL -,:~ rD K. B~~LL, !N THE COURT OF CO1'itdON PLEAS Ur Plaintiff C'JPiBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTIOi1 - LAW ROSILAND J. BALL, N0. 1280 CIVIL 1985 Defendant DIVORCE CERTIFICATE OF SnRVICE I, Bradley L. Griffie, Esquire hereby certify that I did the day of October 1988 cause a true and correct copy of a Petition for Bifurcation filed in 'the above-captioned action to be served upon the following person by placing said document it the United States Mail, first class and po;~tage prepaid direct to his office address as follows: Gary L. Weber, E;;quire P.O. f3ox 15E~ 18 West Third Street Williamsport, PA 17703 }3radley L. Griffie, Esquire ~; ED f:. BALL, IN THE COURT OF CObi610N PLEAS OF ' Plaintiff CU~iBER1~AND COUNTY, PENNSYLVAtiIA v. CIVIL ACTION - LAW iROSILAND J. BALL, N0. 1280 CIVIL 1985 Defendant IN DIVORCE ;~ ~; ORDER OF COURT AND NOW this ~ ~ da of November 1988 the defendant havin Y g ;!failed to ap~;ear personally or thraul;h counsel at the time and place set i for the return of the Rule in this case, it is hereby ordered and i~ ;decreed that the divorce action entered in this case is bifurcated such j that the parties may proceed to finalize the divorce action pursuant to i!the appropriate section of the Divorce Code of 1980 as amended any !!further that the court retains jurisdiction of alI other collateral. j'issues raised in the pleadings in this case. it I, It is further noted by the court that Bradley L. Griffie, Esquire, ;counsel for the Plaintiff, indicates to the court that Gary L. Weber, :';Esquire, counsel for the Defendant, has contacted him by telephone to aUVise him that the defendant would not be opf;osin,; this action. ;~ BY THL' COUi['f , ~~ ._ ~- J ~ f , i ~ 5 LAW OFFICES SAIDIS, SHUFF &MASLAND A PROFESSIONAL CORPORATION JOHN E. SLIKE 26 WEST HIGH STREET • POST OFFICE BOX 560 ROBERT C. SAIDIS CARLISLE, PENNSYLVANIA 17013-2956 GEOFFREY S. SHUFF ALBERT H. MASLAND TELEPHONE: (717) 243-6222 • FACSIMILE: (717) 243-6486 JOHNNA J. DEILY EMAIL: law@ssmattys.com RICHARD P. MISLITSKY -~~ JAMES E. REID, JR. ~~ KARL M. LEDEBOHM JOSEPH L. HITCHINGS MARK W. ALLSHOUSE September 8, 1999 Mr. E. Robert Flicker, II Divorce Master 9 North Hanover Street Carlisle, PA 17013 RE: Ball vs. Bail No. 1280 Civil 1985 Dear Mr. Flicker: Enclosed please find the Pretrial Statement as directed in the above captioned matter. WEST SHORE OFFICE: 2 U)9 MARKET STREET CAMP H[LL, PA 17011 TELEPHONE: (717) 737-3A05 FACSIMILE: (717) 737-3407 REPLY TO CARLISLE This will confirm Attorney Sumple-Sullivan's understanding that I have agreed to a continuance of 45 days, in which time she must file her pretrial statement. Very truly yours, SAIDIS, SHUFF & MASLAND -'" _ .-- Robert C. Saidis RCS/j e cc: Ed K. Ball enclosure t CERTIFIED AS A CIVIL TRIAL ADVOCATE BY THE NATIONAL BOARD OF TRIAL ADVOCACY A PENNSYLVANIA SUPREME COUR'C ACCREDITED AGENCY tt L.L.M. IN TAXATION ED K. BALL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW ROSILAND J. BALL NO. 1280 CIVIL 1985 Defendant IN DIVORCE CERTIFICATE OF SERVICE T, Judith A. Ebersole, do hereby certify that I served the below-named party by First class mail, and postage prepaid the Pretrial Statement addressed as follows on the 8th day of September 1999: Barbara Sumple-Sullivan Attorney at Law 549 Bridge Street New Cumberland, PA 17070 DATED : ,,, '~Gj"~iyr'{~C~ ,%1~ /i~ f ~~~ C~` ~~~- i:~ L~S~C~.. 1` ~ 'Judith A. Ebersole SAIDIS, SHUFF & MASLAND 26 West High Street Carlisle, PA 17013 . . ~~'d 9~4(4f ~~ ED K. BALL, ROSILAND J IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW BALL NO. 1280 CIVIL 1985 Defendant IN DIVORCE PRETRIAL STATEMENT (a) Marital Residence (1) 339 9th Street, New Cumberland,PA. A copy of the deed attached is Exhibit "A". (2) Value as of 12/21/88, $49,000.00. A copy of appraisal attached is Exhibit "B". (3) A copy of the mortgage dated August 23, 1972, is attached as Exhibit "C". (b) Husband's Pension from C.H. Masland & Sons, now Lear Corporation. (1) Parties were married on July 2, 1966 in Williamsport, PA. They separated in April of 1983 and were subsequently divorced on October 18, 1988. The portion of the husband's pension earned from his employment with C.H. Masland & Sons to the date of separation. (2) Plaintiff was hired at C.H. Masland & Sons on June 28, 1971. A copy of the last statement available to Plaintiff dated December 31, 1985, which is the closest to the time of separation in his possession, is attached hereto and marked Exhibit "D". AND NOW comes the Plaintiff through his Attorneys SAIDIS, SHUFF & MASLAND, files the following pretrial statement pursuant to Pa. R.C.P. 1920.33 (b): 1. List of Assets: The parties have been separated since April of 1983. The only assets of significance, which remain to be resolved, are the marital residence and the portion of the pension earned during the marriage. 2. Expert witnesses: (a) Steven W. Barrett, Real Estate Appraiser. A copy of his report is attached as Exhibit "B". (b) Harry Leister, Actuary, who will testify as to the value of the portion of husband's pension earned during the marriage. A copy of his report is not currently available. 3. Other Witnesses: None, other than herein stated. 4. Exhibits, in addition to those attached, there shall be• (a) An updated appraisal. (b) A written report concerning husband's pension. (c) Expenses, husband does not intend to offer any testimony as to his expenses, unless it is in rebuttal. 5. Pension: See comments to Paragraph lb of this pretrial statement. 6. Counsel Fees: Not applicable. 7. Tangible personal property: Not applicable. 8. Marital Debts: The mortgage referred to in Paragraph 1.(a)(3), is in the name of husband and wife. At or about the time of the divorce decree, the inventory and appraisement listed the following joint debts with approximate balances owed: (a) VISA 1st card $1993.00 (b) MasterCard MD Bank N.A. $1680.00 (c) Hess's $ 487.00 (d) J.C. Penny $ 315.00 (e) Pomeroys $ 135.00 (f) Sears (waterheater) $1124.00 (g) Commonwealth Nat. Bank $3000.00 (College Loan) It is believed, all debts except for the College loan were incurred during the course of the marriage. The parties divided these debts and the husband, for more than 10 years, believed that the matters have been concluded. 9. On or about July 12, 1999, Sears Roebuck & Co. filed a claim against plaintiff; Ed K. Ball for the sum of $7758.36, for principal, attorneys fees and costs resulting from the Sears Credit Card referenced above. The case has been appealed by the Plaintiff who anticipates that wife shall be added as an additional defendant. 10. Proposed resolution: Plaintiff husband would suggest a resolution in this matter, that would permit defendant wife to retain the marital residence at 339 9t~' Street and refinance the same, which would pay any and all debts on which ex-husband continues to be liable. Husband shall retain that portion of his pension earned during the marriage, free and clear of any claim by wife. Respectfully submitted: / °' Robert C. Saidis, Esq. ® STEVEN W. BAARETT REAL ESTATE su~~~ - ~~~t~~_u~_ - ~~~_u,t_~ty REALTOR' 124.128 NORTH HANOVER STREET 1~~V/~L~~ CARL.I5LE, PA 17013 .~,..~...~ (717) 243-6&46 December 30, 1988 Attorney Brad Griffie 200 North Hanover Street Carlisle, PA 17013 Re: Appraisal Ba11, Ed 339 Ninth Street New Cumberland, PA Dear Attorney Griffie: In compliance with your request, I have personally inspec*_ed the above captioned property to estimate its present market value. The value shown has been arrived at after careful study of the location and type of improvements, their present physical condition and their present use. Therefore, I believe it to reflect..a true measure of the present day market value as of December 21, 1988. . Value Reported: rORTY-NINE THOUSA~`ID DOLLARS ($49,000) I Hereby certify that I have no financial interest, present or contemplated, in this property and that neither the employment to make the appraisal nor the compensation therefrom is contingent upon the value reported. Sincerely, STEVEN W.. BARRETT, SRA, CRA APPRAISER Exhibit "B" I G1 I A I O I N I A I m I ..• I n . 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NNdd m - N• + ~(11m (0 df71 WUIm NfD ~7 UI Wt]1N OONN(ON 47.ON .7 (7f fON appm+ mcodn747m000 raffia 0000000 aN47m000 0000000 m00 Nm~ w~+U7-+mm000 Ommcnm+000 47~7g1 07mm 0000000 0000000 IO~+m4700pp a17tm+000 0000000 0000000 Exhibit "D" A N O O ~ rw O D Z 47 r N Vf Uf N •~ I m 7C mi A N r~ m t71 i 2 o { f C C Z 3 ~ n I Q1 A m { A O T O Z O i I O I OOnO C I n A\ n n I rA0 r ' I a0+ S v .. I Z C\ ~ - InZm n I m1U1 A ~ C7 -~ n I r I n ~.. rn c0 O 1 0 n r O n I Z .-. n '- N 7C I ~ A z ra I A 3 O A I Z O I W - •1 4e IC O 1 1 D N m m i A O A O Z I Z O i v 7C 1 N C L7 "' ~ Vf ~•, ~ W 1 7a Z v7 N J n I ... < O O r I Zm r M n r I^ N O ?: -~ 1 1 A D ..m I r; ~ I O m • m \ O I N Z 'y N ~+ I of ~ m p I " `^ ~ QS p m C C7 dA I ~ n C •~ I mA A a S Irma 1 I C -+ Z m •ti I Z £ N A < I O m m l u7mm m ~ I ZA 73, r I N n _ Z O Z n , ~+ G7 -+ I O of m I A O \ I T m NO 1 m A m ~+ I m ~ m S i C r I A m A I m A m IN O w 1 ~HN I ..Z-r I ~ r A I TVI ~+ I OmCQ m - I A A C m m < ~ N i g . .. .. A I ac~o < IrmZ I N N c7 \ A .. m a - d I O d;' I mnN m O I nc~\ 1 i D O Z 2W N i C '7 y I m -~ N 47 ' . ~ •: i '' Ct., ~ ~. ~2o~--lt.i''~, ~~;t 9-i'f- flit-= .z - ~; _ . , ; MLD63 3 70 ~ ~ . 60160 , ;. TIiI9 MORTGAGE made the ~.~-i ~~ day of c r.'._ y-:;:/ ; 10 72, botwoen ED K. BAIL aril ROSI[.AND $. ,.-.. -his wife. of the Borough of 'New Cumberlattc[, County'of Cumberland, State of Pennsylvania (herolnaftor eglled "Mortga'gor") and THE C[.ARKL' MORTGAGE COMP~1NY~ a New'Jeraey Corporation , (herolnaftor called "htortgagoe"). ' . ', WfLEREA9, Mortgagor by 1te note (hereinafter called "Note") bearing even dAte~ herewith 1a Indebted to Mortgagee in the principal sera of THIRTEEPI THOUSAND, TOUR iIUNDRF•.D and 00(100 ilollan [E 13,400.00 ) lawful money of the United hates of America, advanced or !o he advanced by Mortgaged to Mortgagor according. to rho terms' and condition's of the Note to which refen:nee is hereby ntnde, any uhpaid remaining belande provided for In the Note or herein being payable not inter than $p~tem~er l9t , 109• NOW, TIiF.121i?''URF„ in consideration of :;aid indvl,tcilness'dnd for bclicr accur{n'g the (tayment of rho enmo, and the lntetest thereon, turd nli OlI1C1' xUtnA provided fur in the Nolc Ur hcr,:in, l0 11(ortt;agec, atid.the pcrformnnco of rho cuvcnnnta and ngrecmcnts hercinnftcr expresseJ, Plorlgugor dues hereby grunt, cmtvcy and mortgngo Unto Diortgtigoe tho' real property (hcreinnflcr tulle<I "Lahti") described in the pnrngruph hereof numbered °d, TOGF,THEIt 1VITil uny turd all buildings and improvcnlcnts erected or herelnaflet erected thereon. TOGE1'l1Eit 1V 1'fll ady anti nfl fixtures, and all mndlincry, equipment, ahd'other articles of property, whether real etiGito or not, now or nt any time hcrer+fler attached to or siwatcd in or upon, anti used or useful in the operation of, the Larid or the buildings rtnd improvements crcclcd or hvrrttllcr crettcJ thereon or of any buxinesx_now or hcrcnftcr operntdtl by the owner or any occupant of the morlgugcd properly or fury port Utcnmf. TOG1:1'11FIt (VI'1'll'ull building nn,tcrhlls, fixtures, ntachlner~ and equlpntent delivered on alto to the Land durinl1~~ the • course of construction of uny buildings ur improventcnts nr tharcufter, t[ igtended for addition lhere,to, or incorporntlon therein dr thereon, or if suitable for any such use. 'f'OGL•:CI11s12 1b'IT1! nil text singe-nr the lcnemcnts, hcredllantenks and nppurtennnccs belonging to the T.nnt1 br anyy part thereof, hcrt•by mortgaged Ur intended ao to bc, or in nnyivixe appertainlnt; thereto (hx•tuding but not limited to nI) incmne, rents, turd profits :ui:ting thercfrnm), all nUccts, ullcys, paxsugexf ways, watercourses, all atlu•r tl>ihla, Iibcrtlt•x anti privileges of tvhnlsoever kind Ur charuclcr,'the reversions mtd remainders, anti all the estntd, tight, title, nttcrest, property, possession, c•Iainl and demand t+•hntsocccr, ns tvcll at I;nv as in equity, of Mortgagor, in anti to all of the foregoing or mty or every part thereof (said Land, buildings, improvements, fixunrs, machinery, equipment, tmuvncnts, turd tither property Interests being hereinafter collcrtively called "Premises°1• . TO IL11'1•; ANU '1'O HOLD the Premise$ unto the Murtgagoo to ILa own prapcr use and behoof forever. AND Mortgagor covenants and agrees with Mortgagee, ns follows: ' rl. 1Vnrrxnty of 'l'ifts. 9lvrtgngur wnrrnnts and will wan'nnt spcciuily the properly hereby convd'gcd. 2. 1'xyment of Sams Scented. Mdrtgagor Shull pay l0 61nrt~ngce the principal of anti Intrrcil upon the Notc according to !hc lernls df the Note secured hereby, rensonublc chnry;es Oxcd by Dlorlgugcc to satisfy and discharge thix Mm'lgttge • of record, anti all other sums herc•hy xecured; anti shall keep and perform every other covenant anti agreement of such Nule .end ' tills MOrtgAgC.. 'w> 3. 11'astc, Mnintcnnncc, fomplinncc and h,spection. M1tnrlgagur shall abstain fr•nnr rtnd not ~x•rmlt the conunissi0n of feasts in or about lhr Premises; shall nut remove or demolish, or oiler the utructurnl ehnrarler of, nay. building nt any lima crcclcd nn the Premises without Ulc prior written nntscnl of Murtgnt;ce; shall maintain the i'reliliscs in good condition anti repair; rensonrtble wear :uul tear excepted; anti shall compl}• with any municipal ordinance or reputation alTecling the Premises within 30 days after notice thvrcnf; provided, hoa•,•vcr, that if ATUrtgngnr shall in good faith, anti h}• proper Icgul action, contest hay such ordinance or rcgulatimt, nr the v:llidily thereof, than Mortgagor shall trot be required to con.ply thet•ewilh so lung ns sorb contest opernu•s to prevent enforcement, nn~l is mninL•,ined and prosccutod wiUt diligc•nc•c, turd shall not have been terminnU•d or dixconlinurd ^dcersrly to \lortgagor. M1I<nlfptgce ;hall Intvc the right, but not the duty, to enter upon. Lhe 1'remisex nt any rcasot~ablt• hour to inspcc•t the order, condition and repair therr'U(. \\ •-9. Insurnntr. ATut•ttp+t;or shall keep the building:; nod intl,roventc•nlx on the Land contlnttouxly Insured against loss by fire` with exUnnled coverage, in such tutu! nnuuutt u:, Murtgtlgve may from tints to time require (but st+c•h amount shall in uo event e ccrd the full L•lir insurable value of said buildings anti improvements), Ineciness interruption insurance, turd nl;ninst other huznrds ns Afortgngce may rcusunnbly require. The policy or pUlic•ics for such instu'unce shall be nu+lntnined in lull force and infect until such tints ns the indebtedness hereby sec•urc•d is fully repaid. ,VI pnliriex, inr•luding trot not limited to policies for any nntoturte carried in excess of the nforesnid minimum anti policies nut sperifirully required by Mortgagee, shall be with an insurance e•untpnny or compunics, turd in form, snlisfm•tory to 9lortgngec, anti shall be deposited, Ftt'emiumx paid, with M1fortgngeu. Thu TUNS, if uny, shall ' be pn}•ublc to Mortgagee according to the furors of a stand:u'd nx,rtgr+gee douse, not subjject to full contribution, ot• of such other fans as shall be sntisf:u•tory to Morlgtfgee. Mnrlgngee shall htt.c the right to nly,l}• fife prnctn•ds of any such insurance, nt its election, either to reduce the indc•btednrss scented hcrcbt• or to restore the 1'rentises. All renewal politics shall be Jetiverrd, , premiums paid, G, Mnrtgagcc ut least ten dtr$s before the rxpirntion of the old policies. If Mnrtgngec becomes the owner of the Premises or nn}• par! thereof h}• foreclosure ur otherwise, suds policies shall hre.omu the absolute lu•oporty of ltiortgngee.. _ , 5. Taxes and Other Charges. \lmtgagor shall pay all coal eatnto taxes, water anti server coats other similar clnirna anti liens assessed or which Holy be assessed at;ninst the I'remiscs or nay' part thereof, without arty deduction, defnlcntion or nhntcntrnt, oat Inter lh:ut ten day. titters the daft,: on which sorb lnxcn, venter and xetrcr rents, Bairns anti limn commence to hear interest or petutllies, and not later than such dates shall produce to llforigngec receipts for lha payment therdof in lull anti shall pay every otht•r L•ts, nsscssrnent, claim, lien er rneumhruncc whidt may nt any tin+c be or become a lien upon the Premieca • prior to the lien of this 1lurtgagc•; provideJ, however, that if hfortgngor shall in pond forth, anti by proper legal action, contest ' rely such lases, claims, liras, cnrumbrnnrr•s ur other charges, or the validity thereof, anti shall have estnbllxhed rat its hooka, or by deposit of rush with blurtgagce (ns \Tortgagcc Holy steel), n rrscrve for the payment thereof In aueh amount na 1Stortgagee may require, that AL,rtgngor :au,ll not bu rwlcired to pay the some, or tct produce such receipts, during the tralntenance of said reserve and ns long ns sorb contest operates to to event collection, and is maintained nnJ prosecuted with diligence, acrd shall not have been tcrminnted or discontinued advcrscly to M1{ortt;ngor. 0. T•'scrow hands. Nithout limitint; the eRcct of Parngrapha land 6 hereof, Dortgagor shall pay to ltiiortgngeo monthly nt the time when such monthly installment of principal and interest is payable, en amount equal to 1/12 of rho annual premiums fur such fire rtnd extended coverage insurance anti such annual real estate taxes, venter rents, sewer yenta, apeclul nssrssmenla, and any other tax, nssessntent, cbtim, lien or encumbrance which may nt any limo be or become a lien upon the Premises prior to the lien of this Mortgage, anti on denvnxl from limo to time slutll pay to Dlortgngee additional auras recce- - nary to pay such premiums anti other payments, ail ns estimnled by Iortgagee, the rnnounts ao paid to be securay for such ppremiums anti other pnyntt•nts •uuf to he used in pnymcnt thereof. No amount so paid shall bd deemed to ho !rust fu:uls but rosy be cominglcd with general funds n[ Mortgrtgec, anti no interest shall bo payable thereon. If, pursuant to any provision of this ' Aforlgngc, the whole nnxrunt. of said principal debt remaining becomes due an<) payable, D1oHgngee shall have the tight at Its election to apply any nnmunts so ltcld against the entire indebtedness accurod hereby, 7. Fulurc Impnsitiona. Tf at any time the United Shltes Government or any doparhnerit or bureau thereof shall require internal revenue stomps on the Notc secured hereby upon Armand hortgagor shall pay for dame: and on default of such pnyntent tvithilt ICi cloys otter +iemnnd fry stone, the hofJer of the Note may pay for aueh xtnmps anti add the amount so paid to the principal indr•bledness evidenced by the Note r+nd secured by this SLor!gnge, and raid additional principal shall bear interest nt the rate of 8% per annum, if any Inw nr ordinance adopted hcrenftcr imposes a tax on Mortgngoe with zeahect to the Premises, the value of .Mm•tgugor's equity therein, the amount of the Indebtedness accurod hereby, the Nota, or th(a Mortgage, Rlortgngee shall base the right at its cleclion from tune to limn to give Mortgagor fi0 days written notice to pa each indebtedness secured hereby, tvhrrcupon such indebtechtess shall become due, payable and collectible ut the explratlon df such p2rlod of fi0 days, unless prior them n, Inu•fully and ttithout violation of usury Inwa, biortgaKnr hex paid uny ouch tax in full as rho dame bec6tne • clue and payable, in which event spch nvticc shall be deemed to havo heart rexcindcd with re pact to any tight of hiortt%ngee hereunder arising by reason of the tax xo paid. NU prepayment charge or premium shall r,pply ~o any pnymcnt of rho indebtedness j secured hereby purxvnnt to any such notice, it the payment is madd bolero the explrutlon o/ aueh period of 00 days. ' H. 9ceuritq Agreement; Additional 9ccvrlty. Tlds Nfortgege creatda n sc•:vrity'nteteet In the property lndudcd in Premisca and constitutes n security ngrecrncnt under the Uniform Commerclnl Codc. bfortl:pgor shall execute, file end reltle such financing stnlements or other security ngrcementa ns Mortgaged}ahull require from time to lime with respect to property ' Includdd in Premises. C r r} )'~~E U ~>1~ i BOUi( JJt) '4 .:- ~ , Exhibit '+C° - ' r ;. • _.. 0. l.raara. Ne exlating or future tense for 1. term in excess of two years, er at an nnnunl rent in excess of =5,000., or which ntfects moth than ten per cent of the gross income of the premises, And which covers the premises or property or nny port thereof, or nny facilities or business located or operated thereon or therefrom, shall be cancelled, surrendered, or ,nodificd without rho written eoment of ,Atertgal;cc. Mortgagor shall notify the Afortga,;ec immediately o[ any dcfnult Asserted by nny tenant. If Atortgngor fails t0 CIIrC aUCh dC(aUlt On Il9 part, 111 Inndlord in nny of tlrc lenses, then ;•Tortgagor expressly aulhorites Mortgngce, nt,its option, to cure Hoch default in order to prevent tc•rminnlion of nny Icnsc by Any tenant. 1f any such tense is Assigned to Atortgngoc by sepnrnlc instrument of assir;nment, And tf, byy reason of dcfmllt of Aiortgat;or in the pcrformnnce of nay such Icnsc, the tenant has the right to cnnccl ouch lease m to claim nny diminution of or ol[sct against future rcnlr, then, at the option of Atortgngec, such dcfnult shall be. a defmllt under the Notc and this ylort-;A-;c. 30. RIRhI to Remedy Defects, If Alortt:agor fails to pay nn}• tax, claim, lien or en^umt+rnnce ,which shall be or become prior in lien to this Mertgngr, or to pay any insurance premium ns nforesnid, or to keep the 1'remiscs in 'repair, ns aforesaid, or commits or permib waste; thin Afortgngce, rat its optimr, may pay avid claim, lien, cncumbrnnce, tax, assessment ar premium, with right o[ eubrogntion thcreunrler, may make such repr,irs and take such steps ns it deems ndvisnhle to prevent or cure such waste, and may np pear in any ne!fon or proceeding with respect to un}• of the foregoing and retain cminscl therein, and take such action therein ns ltlortgngce deems ndvisnhle, nod for Any of said purposes ;•IortrArre may ndvAnce such sums of money ns it deems necessary, Atortgngor twill pay to M11ortRnt{ee, immediately and without cicnvuul, all sums of moos}• ndvnnced by Mortgngce pursuant to thin pnrngrnph, together with interest on Inch auch ndvnnce rat the rote n( $x per annum, and all such sums and interest thereon ahnll be eccurcrl hereby. 11. Condemm~lien. if nny port of ten f'remisrs is condemned, except As hr.reinnfter provided In this covenant, all prOCCCd9 shall he applied nest to pay the indehtrdnesa secured beech}'. 1`o sclllement for the d:+nurges sustained thereby shall be mode by Atortgngor without Atortgngee's prior a•rltten npprncnt thereof. If the nmmurt of nn initial award of damages for tfie eondemnatlon is insulllctent to pay ter nmmnlt of rho inrlcbterMcss secured hereby ir. full with interest and costs, AiorlgAgec shall havo the right to Ne nn nppeol or such other legal proceedings ns It•I;al counsel may ndvisc to he npproprinte nndcr the cireumstnnces in the name e[ Atortgngor or of A[orttrngee (for which nctinn Mort.gngec or such counsel ns it chooses is hereby irrevocably nppolnlcd attorney in fact far Atortgngor), and to prosecute some to 1in:,1 cmlclusimr or otherwise die: +ose thereof, in n•hich event the cxpceses n[ the nppeol m• other apppropriate Icgn) prncr•odint;s, inclncling but oat limited to coci{ISCI fees, shall he first pnld out of the proceeds, and no credit shall F,a Riven on nrcount, of the nv+rtr;ngc rlobt other than n cn•dit for the nmmmt, it nny, wherebyy tea final proceeds exceed all such expenses. Nothing in this covenant or elsc+vhcrc in this Atartt;agc shall limit rights otherwieo nvnllable rtt law to Afortgngec, including but oat limited to riF;hta to intervene ns n party to nny condcmnntion proceeding. 12. Dcfnult and Remedies. The following shall constitute 1?cents of Default hereunrlcr: ' n. Tho failure of Atortgngor to pay any inatnllment of principal or interest when the some is pnynble. b. The failure of Atortgngor to pny'nny other sum required to be paid in t}re Notc or in this Aforlgagc when the • same ie pnynhlc. • c. The failure of A1ortRagor to pcrfonn any cm,vennnt or agreement in the Note or in this ATortgngc. d: Any assignment tar the benefit of Mortgagor's creditors, or ether prececdings intended to liquidate or • rehabilitate Mortgngor'a estate, or AtortgnFor's becoming insolvent within the meaning of the federal bankruptcy • law, • e. Tho occurrenco of any F.ven! of Default as defined in the Note. Upoh the hnpperting of anv one or more of said F,vcnts of Default, the entire unpnirl hnlnncc of the principal, the Accrued intEreat, and all other sums r.eeured by this Mortgage shell, at the option of Aimtt:ngce, become immediately due and payable without notlee er demnntl, and in any such F.vent of Ucfnult Atorlgagcr. may forthwiU,: (1) Tereclosure. Institute nn nctinn of mortgage forcclosurr•, or lake such other Action, ns the lnn• may Allow,.rit lmv '; F,; ~, er 1n equity, fnr the enforcement thereof and renlizntion otr Ule mm'tgnge security or nny other security ,which • ~ , Is herein or elseu•herc provided [or, and proceed ther•con•to finAl judgment and cxrcntion thereon tar the entire unpakl hnlnncc of enirl prlhripnl sum, with Irlto,'osE AL the rote stipulated in the Nntc to ter. dote o[ dcfnult and thct•enftcr at the rote Aof ~ per annum, togcthcr with all other sums secured by this Aimtga(;c, all ' •' eontn of suit interest rat f ~ per annum mt nny jadgmrnl obtained by ATortgagcc from and after the ' t' • ` dote o[ any Slherill"s fiats n he !'remises (which may he sold in one' parcel or in such pnrccL;, manner or order ae Mortgagee shall elect) until actual payment is made by the Sheriff of the full amount due Mnrtgngee, and • '• • nn attorney's cottnnlasion far collection which shall be five per cent of the total of the foregoing sums, bat not less than ~r/no., without further stay, any inw, usAge or custom to the contrary nohvithstanding; or ' , ' (2) Tntry; lleeeiverahip, Enter into possession of the tremises, with or without legal Action, and by force if necessary; • Icnsc the some; collect all rents noel profits therefrom and, after deducting all costs of collection And ' admrnistrnlion expense, apply the act rents and proms to the pnymcnt of taxes, realer And server rents, charges • '' and claims, Insurnnee premiums and all gj}rer carrying chnrFes (including but oat limited to ngenls'compensalion and fees and costs of counsel and rt2ci,crs) and to the maintenance, repair or restoration of the Premises, or on account and in reduction of the princijtn) or• interest, or principal and interest, hereby secured, in such order ' and amounts as Al.,rlgngee to M1tortRntree a sale discretion nmy elect; and hove n receiver appointed to enter Into possession of the Premises, collect the rents and profits therefrom, and apply Ure same As the court may direct. Alortgngce ahnll be liable to nccmrnt only fnr rents and profits ncUrnlly recr.ived b}• Afortgagee. fnr such purposes Atortgngor hereby authorises nny nttornry of nny court of record to nl,p^nr for Atortgngor to sign nn agreement for entetina nn nnticnhle action of ejectment for possession of the Premises, and t.o confess judgment therein against Mortgagor In favor of hlort>;agce, whereupon n writ may forthwith issue fnr the immcdinte posses- ` lion of the Premises, without any prior tt•rrt or proceeding tvhntsoever; and for so doing 'thin AlortgAge or n copy hereof verified by nnidnvit shall be a sunlcicnt wamm~t. ' 11. Adsignment of Lcnscs and Rcnls" after ~Dcfnult. As furthersecbrity tar pnymcnt of the Indebtedness and performance oP the obllgntions, covenants mu) Agreements Frcurcr) beret+y, Aimtg!ngor hereby assigns to Mmtgngec all leases nlrcndy in cxlstcncc and to be crentrd In the future, logethc•r with all rents to hrcome due under existin(• or future lenses. This nsslgnment, however, shat) he operallve only in the Cvent of the occurrence of n dcfnult hereunrlcr, or under the Note ar other instrument eollnteral hereto, remaining uncured rat the 'expirnlion of the grace period, if nny, provided above in respect to such dcfnult; and in nny Auch case Mortgagor he,•eby confers on• AlortgAgre the exclusive pml•cr, to he used or not in its sole discretion, to act as agent, or to appoint a third person to act as ngeht for Afortgngor, with power to t:+kr- possession of, and collect all rents ar{sing from, the itemises and apply such rents, at the option of MortgAi;ce, to the pnymcnt of the mortgn-;c debt, taxes, costs of maintenance, repairs, expenses incident to mnnng}ng and other expenses, in such mdcr n[ priority ns Atortgngor may in its solo discretion determine, and la turn nny hnlnncc rcrnnining over to Atortgngor; bat such collection of rents shall not epCratC Aa hn rtnirmancc of the tenqIll or tense in the event Atortgngor's .title t0 trle Pre t1119e9 should hC acq VlrCd by AlOrtgagCe. Atortgngco shall be linblc'to nccnunt only for rents and profits actUnllV rCfC1VCd by Alortgagee. In Cx!`rClSin(! At1V of the pnlVCrs ' 1n this paragraph contained, Alorlgngec may also 4atct pdsscssimr of, ro,d for these purposes use. Any and all personal property contained in the Cremises and used by Atortgngor in the rcptnl or lensing thereof nr nn}• purl thereof. IA, Cmmsrl Fers.' if Morlgngec becomes n potty (by intcrvcntimr or nthcnvisel to any nctinn ar proccerling nRect- ingg the Premises or Ule title thereto or Atortgngce's interest undee• this Marfrngcror cmpln}•s An nttornc}• to collect. nny of the in- detitrdness or to enforce performnnee of rtes obligations, eocennnts nml ngrcemchta secured hereby, Atortgngor shall reimburse Mortgagee, forthwith open written notice and avithout further demand, far all rcnsonnble costs, charges and counsel fees incurred hp Alorlgn ee, In any such erase, whether or no! suit be commenced, and the amne shall he secured hereby ns n further charge and Ilea open the Premiscs. ' 16. Nellre. A notice which Is mailed eertined moil !n Atortgngor or !n the person or persons a•hn ore then the owner or owners of Lhq I'rcmiaes rat the Premises rat at aucfi other nddress ae A[orlgagor sholl dcsignnte to Afortgngce in writing shall be sull{cient notlee when required under, this Afortgnge. 18. CumulaHre Righln and itpmrdics. The rights and remedies of Atorigngce as provided herein, or In said Note, and !ho watrnnt thet•eiri eentained, stroll be cumulative And concurrent, and play be pursued singly, successively or together rat rho sole discretion of Atortgngoe, and may 1+e exercised as often ns occnsiotl therefor shall occur, and the failure to exercise any auch right qr ~cmrdy shall In no event be construed ns n waiver or release of the some. 1T, \Vnlrer of Defense and ('ertnln tintless. Alm•tt;ngor hereby a•nivcs and releases (n? n11 errors, rlefecls and • imperfeetlons in any lrroecedings (nstltuted by AtortgaRee under ih~n Atatgnge, (hl all benct'it that might accrue to Atortgngor by t•irluc of any present or future h,ws exempting the Premises, or nny port of the pr'OCCPdR arlVlllg front any sale thereof, from attachment, levy or ante under execution, cr providing far nny stay of execution exemption from civil pxocess, or extension of time for pnymcnt, and (c) alt notices not hereinclsew9tete specifically required, of ~lortgngar's defaults; ar of Mortgagee's exercise, of election to exorcise, any option under this Atortgagc. ' .lA, Satislne4on_flf_this_Alerfgage. If Atortgngor complies ,with the provisions of this Atort.gAge and pays to Ator!- gngce sAld prinetpnl sum, and all other sums pnynhte by Atortgngor to ATmtgngee as are hereby secured, fn accordance with the provlsiens of rho Note mid In the mnnncr and at the t(mes thereto set forth. a•ithalt deduction, irnud or dalny, then and Pram thenceforth this Morttgage, and the estate hereby grahted, ahnll cease and becmne void, nnylhing hereinbcfore tontained to the contrary notwlthstnndlhg. 10. Income sort i/xprnse $lalemrnl. \Vlthin CO days otter the end of each rascal }•enr of Atortgngor occurring during the term of the loon hereby scented, Atortgngor r.t its otvn expense ahnll furnish Lo Alorlgngce n dctniled etrtcment by nn Independent eertined public acrountnnt of the income and expenses of the hremiacs during auch fiscal yens. tegetber with n balance sheet and rent schedulo• Zo• Conslruetten. The a•m•ds "Alortgngnr" and "Atortgngoe" include singulnr or petrol, IndividaAl or torporntion, and the reepeclive belts cxceutora, adminlelrntore, aueeessere and assigns of Atortgngor and Morttrsgce, as the ensc may bc. '1'hc ttse of any Render w plea to alt genders, If morn llult one party Is Homed as AtnMcr, the ohllQatron hereunder of each auch party Is )olnt and eevoral. 21. Gptlana. The enpllm,s hereto ore inserted only for rnnveni~nce of reference and In no way deRne, Ilml! or deeeNbe the scope or Intent of this Alortgnge or any particular pnra)trnph oc Aeclion hereof, nor the proper construetlon hereof. 82. Thla AiertgaRe being Intended to be a purchnee mbncy mortgagq under the preelelone of the Lien Priority Laa•, ws - - --llmcndcd. BOOK 5Jr~ F~G~ 6'~3 • • 23, Transfer of Title. Any transfer by solo, gift, devise, ol~eratian of la~v or othurwlse of the fee ~ltle interest in dll or ' any portion of the morlgnged premises shall have tho some cunsequrncrs ax an evurit of default respecting the Indehtednenn secured . hereby and upon such booster, Diortg~gee, without prior notice or the elapse of rtny period oI genre or thu right to cure, ~thall hnvr the rig~t to decixre all sums srcurect hereby immrdintcly due and .payable, and, upud fnihu'e by Uiurt~n{tor to make such pxymrnt within thirty days of written demand thrreforr, Jlortgagrr shall.huve thu ri{tht to exercise xll t•eme•~hcs provided in the Notr, this Aortgage, or otherwise nt law. 2A, bcecriplion of 1'remiaex. The following is the ~;cul, property liurcinbefore exiled "Land" fnduded In the nun'tgngrd Premises. • • • .; • ALL THAT CERTAIN lot or tract- of land situate iri Nest Cumberl'an8, Cumberland , County, Pennsylvania bounded and described in accordance with a Survey by . • Gerrit J. Betz, 'Registered Surveyor, dated August 10, 1972, as follpwe to wit;. BEGINNING at,a point on the Northern line of 9th Stt:eet at a distance of ninety feet measured in an Easterly direction by-same from the Nbrtheaet corner of 9th Street and a thirteen and.five-Cenths feet wide alley (said-._ alley having been increased in width from ten feet by the addition of the, Western one and five-tenths feet of LoC No. 38 and the EAetem two feet .of Lot No. 61-A on the Plan of: Lots hereinafter mentioned);.T1lENCr North thirty degrees, ten minutes-West along aline paiallol with said alley one hundred feet to a point on rite Southerly line of a ten feet w3de•alley; • TIiENCE North fifty nine degrees, fifty minutes Eaet along the Southerly • lice of 'said ten feet wide alloy twenty two .and five-tenths >`eet to a ~ point on a line running rhea the center of. the partition wall of the'- double house erected on the Lot herein described and rife adjoining-.Lot • on the East; THENCE South thirty degre>?s, ten `minutes Eaet along the said last mentioned line one hundred feet to a point on the Northerly • line of 9th Street-; TIIENC_L_ South fifty. nine degrees, fifty minutes ' • .,, •~ West along the Northerly 1Jne of 9th Street, twenty two and five-tenths, 1 :~ feet to a point at the place of Beginning. ~ ~E; '•-~ • _ ;'r BEING: the Eastern eight and five-tenths feet of Lot No, 37 and the Weatern~•::'" fourteen feet of Lot No. 36 on•the Plan of Lots known•ne Seven Maples No.l•-~` said Plan being. recorded in the Cumberland County Recorder's Office in Plan Book 1, Page 94. li 1~EING known as No. 339 9th Street.. ',~.~ • BEING the same premises which Robert E. Braun , by Indenture bearing ~.• date the -•l-z-tl~ day of 1~~,j~-/~ ,A.D.2972, and duly intended to be ' ' ' forthwith recorded in the Office of the Recorder of Deeds, in and for the County of Cumberland, grantee! and conveyed unto the said MORTGAGORS. TOGETIIER with the free and conmion use, right, liberty and privilege of the said alley as and for a passageway and watercourse at all times hereafte>s, ~. forever. ' A N D1, • c ~ • ~ a ~~~ ~ hl ~ b . ~` r op iy^ i ; W -[; ~ O l~0 [A ~c70~ ''1 i . - ~'q ~ ~:~ A r~ n :C to 4,., ~ ~ s -.md ~'~ - - .. ~ ~ , ~ . ' v-~ y N0~7 ~ .. ~ rV T `fNy .. , ~ • Ir j f ~ jyl„ _, , .2. .. '.. ~ .. ~ ... L~ t I . 1' ~, Zia IN WITNESS WHEREOF, this Mortgage has been dulq executed se of the day snd yesr fla t above written ~•' ,: ~••~: - Signed, Sealed. sod Dclive-ed ~ ~ i • ' in the presence of: • ~' ~ ~ i t ti' ~~. ~ ~ F . '.i air ~. ;,, •• ~~ ~~ ~,,, f,~.t ,4 ~ ~„ • t ~ ,yah~, i' f ;',, try; ~ i ! , ~ t ~ t ~ ~ '~.•• , i ? ' !~-' ~ ,, (Seal)' i Witnesses ,/ Lid .K. Ball ~ ~;~. ~ ~ ! ~/' ~v • i r = ~ ~ ~F.1~_[t£ er G+[_ J. E ml~ ~ ..~^(3aR1) ; '. Roailand B. Ball ~ ,: , ,: . ~; . .. alilii< 553 pncE '(l-l ~. f f 2 i { 1 On this, the .~-~ttr'day of ~~~~~~"~/ lA 72 ,before me, the underntgned oRleer, personally appeared CD K. BALL and ROSILAND B. , his wife _ ""'''h., known to me (or antietaetorily proven) t~he~tlie herson6lvhoae name a are aabecrlbed to the withln (natrnment, end acknowledged that ho executed the same for the puYpoeeq ;tficteiq fontilined, ' c,. .. ~, - ~, IN WiTNE99 WHEREOF, I hereunto act my hand and official aeal. ;; ", •;:~, ' •i~~f: " ~:'~'r My Commin{on Explreet ~ ~~~-:.'i~~i ~;:, r i1 BTATC Of /" ~ ' ,5$. COUNTY Of On this, the day of , 1!) ,before Ins, the undersigned oliicer, personally appeared ho acknowledged himself l.o be of a corpo ~n, and that he, ae ouch ollicer, being authorized to do eo, executed the foregoing instrument for the purpoaee therein co ed by signing the name of the eorporetion by himself as each oflieer. IN WITNESS, WFjj:R F, i hereunto sot'mg hand and oflielei seal. NOTARY PVRLiC My Commleelon Expires: 1 The preclee reeldenee snd complete goat office sddreea of the within-named 1lfortgngee is SOU Chestnut Street,Philadelphis~ ~i -7~ENT OE'~'f lfE MORTOAOF.C w ~ . e '[7i , tti ~ ~ ~ P+ L ~ d C O • ~ - Q U l .O u L 7~ v q .. ~ y i-. r• ' .A, ~ V) V O1 u ~~....,~~//~~ .~ V•1 t ' ~ ~ l ., O ~ ~ ~ ~ a p ~ ', ~ ~ ~ ;r, ~ m •~+ v y a \~ ~ ~ ~ o to ~ d R+ . ~ ~ ~ I s. O~ O rM'1 -C ~ td W /~~ ~q N y O a t/1 O O d ' ts] ~ W G1 U `. ., t W ' a o x1Q~~r~e~ in the OfAee for recording of deeds 1n and for the County of ~ ~~ ~ ' D "~ in Mortga ge Rook No. ~ ~J F "age xcc. ~fttltl~~ my hand and seal of Ofiice thla ~~ ~ day of ~ ; Anno Domini 19 /02. V _. ( t • ~~ ~-CSC--V" • ~'C.f'~L/ aoor< 553 r~cE 6115 1 RERECORD! FOFCDEEDSHE C~PENHSYL aH,sHT~ NO. 936 Auc ~~ 3 07 PH'tt FEE-SIMPLE DEED-T~pewrite~ . ~~~t~ ~Yt~~'~~t~~~`~', ~~'~Mlp ~I~~ a~.3ul, doy o/ ~~~ y-acs Tbovtond Ninr HuwdrtJ and Seventy-Tw0 ~PtlUppll ROBERT E . BRAUN ~~~~ A N D ED K. BALL and ROSILAND B., his wife, parties of ~w fbr yror o/ our Lord Owe o/ lbs fttond port, l~~t~lP~~etl~ Tbol Jbr toil port o/ Ibt ~inl purl, /or and iw contidrroliow of I& rnm o/ Fourteen Thousand Nine Hundred ( $14 r 900.00) Dollart, lowjui monry o/ fbr Unilyd Sfolrt of Amrrite, wrlf and traly paid by fbr raid earl ie8/ for atone pa-l to for told pa-l y of fbr firtl part, •t and brjorr Ibs traiina and driivtry o/ Ibar prrtrnlt, lbo rartpt wbrrtoj tt brrrby tcknowlydgrd, he drantrd, bor~sinra, told, dirnrd, enjto~rd, rrltard, conveyrd and confirmrd and by Ihrtr prrtrnH do ,Front, bo.x.in, trH. olirn, rn/ro6, retntr, ronvry, end ron(trm unla Ihr toid porl ie8 e/ !hr rrtond port their btin and utidnt, ~ll that certain lot or tract of land situate in New Cumberland, Cumberland County, Pennsylvania bounded and described in accordance with a survey by G. J. Betz, R. S. dated August 10, 1972 to witi BEGINNING at a point on the Northern line pf 9th Street at a distance of 90 feet measured in an Easterly direction by same from the Northeast corner of 9th Street and a 13.5 feet wide alley (said alley having been increased in width from 10 feet by the addition of the Western 1.5 feet of Lot f1o. 38 and the Eastern 2 feet of Lot. 61-A on the Plan of Lots hereinafter mentioned); TIiENCE North 30 degrees 10 minutes West along a line parallel with said alley 100 feet to a point on the Southerly line of a 10 feet wide alley; TiiENCE North 59 degrees 50 minutes EAst along the Southerly line of said 10 feet wide alley 22.5 feet to a point on a line running thru the center of the partition wall of the double house erected on the. Lot Herein described and the adjoining Lot on .the East; TilENCE South 30 degrees 10 minutes East along the said last mentioned line of 100 feet to a point on the Northerly line of 9th Street; TlIENCE South 59 degrees 50 minutes West along the Northerly line of 9th Street 22.5-feet to a point at the place of BEGINNING. BEING the Eastern 8.5 feet of Lot No.37 and the Western 14 feet of Lot No. 36 on the Pla;i of Lots known as Seven Maples No.l, said Plan ,. :~ ii t 1 (; 1 Yi t 4 !, i being recorded in the Cumberland County Recoraer's Offrce in Plan ; Book 1, Page 94. BEING known as No. 339 9th Street. f BOOK 7°24PAGE 94B Exhibit "A" r r ~ ~ 4 ~ .. .... ' Cumb, Co., Pa. 7c~ Rr•1 E.Irlr Tr.e.Ar T.r i f Crx~, Cr. fleet. GI, Apl, Ry i i t.; ~r ~itiR--a ~ r~~~-.,t School Dist. Cumb. Co., Pa 1 X R•N Ed•1• Tr•m1•r T•r v Co~6. Ce. 07rr. Cel, Avf. ~S ~nget(~rr ui1J~ all and rinaulsr, /ht frnrmrnh, brndiNmrxlr and appurlrnancrr to Ibr tame brlonglna or in anywhr apprrlalnlnd, and fbt -rvrnlon and rrvrrrloxr, remainder and rrmaindrrr, -rnlr, irrurt, end proFlr rbr-ro/; Aulglntl d1 fbr rrlaN, rlahl, Nllr, Inlrrrrl, properly, claim axd demand whslrorr~rr, Gefb.l» lam .nd rqulfy, o/ lbr u/d pnf o/ the F-rl part, e/, 1», to or eul n/ Ibr ra/d premiere, and rutty par- end parcel Ibrrrel (eta j~Mi[p 11111 Zl1 linll rhr reld prrmhn, w~lrb all and rlnawler Jhr appxrlrnanur, wnlo Ib. uld pe-l ie8 0/ lbr mend earl, their brlrr end aeelanr, to and /or llx only proper rue and brboo/ e/ Ilx rald part iea o/ Ihr -rccnd pa-l, their brlrr and auldnr /orwn, ~tlb rt/E SAID party of the first part, his -xln, rxiculer- a»/ adminHlralore, do ea by Ibnr prrnwh, rovrnanf, Grant tnd aartr fo and wilb fbr ~•!d parlie9 0/ for rrrond parr, their brlrr and ueiaxr, loaf r!x rald party of the first part, his -irlrr alt and elnawh- the brrrdllamrnh end p-rmlerr brrrixabonr drenlbrd and arenlyd er mrnHonrd, and rnlrndrd ro to br, wl/b app-rrlrnencrr, xnlo lbt rald par! ieg o/ fhr lrcorrd pert, their brier end areldne, agalraJ the said party o/ tht frrrf per! rend }~ j,g brier end egai»el all snd every oNxr Perron or prrronr u~bornrorrrr, /nv/ally dsiming o- !o Bairn Iht tame or any part Ihrrro/, ,ball snd wNl, by lbru prruxh, tVARRANT AND FOREVER DEFEND ~)ll ~!~ilfllE'iiii ~~(~C1:C[t~ lbr raid pot y n/ the fi-rl pert bn berrwn/o rrl band and red 'fbr de end ~rar fief abot~r wrlUrn. r .....A-fith~~.. rc*;_uti.....~%..,. (SEAL) ..:.. - .. ''' `{y3 » rC~~. 1 Signed, Sealed and Delivered ~ `~ ;' .. in the Presence of ; - : ~;E , : 1'rV,:::: f~~ ,(~ ~ r .. 900K7``~~ .r .• .'y . f111~ i , c .._ ............................_....,.......................................... (SEAL) . . P CAE ~4~ ' ~ ,._.. r ~ ~ ; ~ j 7 COMMONWEALTH OF PENNSYLVANIA A ~ ~/... COUNT]' OF ...~~~2`-::::~-~.`•' ........................._..._. ~. On tbif, !be ........F~.~uY... dry of ............L:~rG-.. ...-~:f ........................_................, P9ZZ...r br/on tnr ......._ ............................_........................................_............. ..... ..,........... ........................ Jbr vxdrrtPanrd ogicsr, prrsonrfly rQprrrrd ......RO$ERT...E„• •IiRAIJN .........:........_...-...._......................_........_..... ......_......__.... ......... . 4MOUrn to xrr (or saris/aclo-ily rrorrn) to br thr ~rnox .................... wbostxrsnt .................... substrlGrd to,tbr,~ u.itbin ixttrumrnt, and atkxowlydgrd Neat .......... ht ....,..... tzrcuttd 11.v srmr /or for purCost.•Ibririri;tab rrord~" •~'• IN q'ITNF.55 WHEREOF, 1 brreunto ut my baud yxd official sera. ~J~', ~~i':i~- ;:a,~ •~• :~•:'~~~'; .J.~`?~~..+Cs:L.~..l~~:f!-f,3::...1.~!_.~;r'~/'rte "''~.• .. ~fy toniixissiox rx plres:..l..:l. ~. ~~.„~: ~;~:.~ ..:11 ,z...f.:....:..~ ;' >r ..•1.•bnrby cnti/y thrt the P.rnu Rrsidrxcr o/ Jbt Graxtrr, in /br wil/hin UrE~4:•i{ .....:~n..~~,'..q~,p~:`,• y Actorncy for 1`irsnsre. .. rn ~'I' ~ ~ d z M~ W HW A W m a°. ~ a Ga ~ , 1 ~ 4 • ` C H fj O . H w ~t a b~ .b 3 ~ ~ ~ ~ ~ ' t I `~~ Ri i az o b ~ o ~ .^ r fJ] ^1f ~i ~ Y Q -~ V I ! I f"'Ij ~ a O ~11 W 44 ma~yy i1 ~~ ~ .q 1Y M O •s.- '~~77 i i ~ ~u v a a ~ ,~ ~ V, o g o • Qi. 3j ; ~ ~ ~ ~ . ,FC{ a m z ~ •~ ' ~ W .~ e A pq '8 ii Epp ~ ., a ~ V ~ ~rQQ: U ~ ~ ~ 14 D tt. V ~ C S V Cd~j ONW@ALTN OF PENNSYLVANIA SS: ~, ~,~~:~a.2.... ~~:G~~sc..c~ CO UNTY, RCGI5~ERE0 HV THE B8AOU6H OF NEW~--CUWBEALAND . Socrwry _ .~. der r-~~ to/ 1ht Vice ~or Recording of Deeds, ,14orf'gaget, rtr., in and ~or the CauJt~ ..lGc.a:~-t~:4S~:(:~5:?:~.~:~iu, Deed [3ook ......~.~Vol..~..~._. Pagr .. ~ ...~y . (, ~ } / ~~ltfitp>a~-- M3~ Har:d arrd Seal of O~'ict, this ..........................................r".....~..i ./da ~ o _..---.. ~ ..................... Anna Domirri 19 ~~~ ..- ./ sooKT24PACE :950 ._... . .. _. • ' f: LiV . r111A. l~~L' t WtJIIL'.[~a7.{~ . .. t~.J 4'+V 1 . JUTS • A1JD ~ ~LIINS 1QUI't'Y;~ U~ P,OOK'~"• ..;.I~NT • ~ 5~. 1983 ~i:o present •" ~ 9. 7128!81- 4, js/2714'S~ 8 JG7~t, I300KS s .. 4. 1978-198'L ' ,~ ~ •' .. I'resenL !~ /25/57 1. . ~ s _, ~ ~ . ~ 8. G/15/76- 3. 1/7,9/40- 1.1/189 7/10/81 12/31/44 7/8/47 . 7, 1/1/70- 2, 6/14/?.0- t~/27/76 12/31/39;. • G: 1 j21 jS8- ~ 1, 9/19/08~:;~: 11/10/69 X2/31/19: . . ~' S. 3/19/46- 10/28/S7 *Federal 'I.'ax Liens 6 years l~ 2/20/32-- . *JudgmenCs efCecbive 5 years 11/9J~45 *begin 1978 'riuxiic~~al Liens _ ..• ,. IItJYGR s ~,,~ ~ . 1' o„ ,~' ~, ~:' O~dNF.I1S: /~ ~ Q ~, 'Ib s ~ - - Zb: '~0: .;a ;•.:.. ., -' _, - )wrieYe r ~~rior Deed (e y r Datea r AddreeA /Lot No. I c5 r ~~ i-r-an-to-r~~ 1904 - ' 1 1955 - Mortc a or 1904 - 1973- 1957- 195G- reed , Oul-':) ^ Crecerrl- ' 903 - 19'G, ~ ~ L•"rid I~urcttase I~ric~ -- hreQent_ ~ 19(13 1972 End eye y ~ ~ 1 ~ ( ~~ ~ S ~(~ ~ ~ ~ . / (~ teed Uook Mortgage {3ovk {'age Leader: Oates recorded: ~~ ~-~- _5 L .~ ~.G~ ~-~ S~ . {{elease r . Acct N ~~~1 .5_.S 3 "+~~D~ ~ ~ ~~ -u s ~ l v,- ~ , , .-- ~ r.~. IC • ~- • Cc.D `ate'} ~r1l--`~G`f . 5 l-Z--7 ~J .ecellaneous 19E14 - 19'13- 1954- 1954- ~~ E~resent 19H3 1972 End- iye ~ ~ / // r- f ' i .gc. ~lvvk /~ antes r cations ter ~~ Secured Trangactivne Uvc~.k.-e-~t I~rernisee Uate .) ~~. LAW OFFICES BABBAI3.A SUMPLE-SULLIVAIV 549 BRIDGE STREET NEW CUMBERLAND, PENNSYLVANIA 17070-1931 PHONE (717) 774-1445 FAX (717) 774-7059 October 29, 1999 E. Robert Elicker, II, Esquire Divorce Master 9 North Hanover Street Carlisle, PA 17013 Re: Ball v. Ball No. 1280 Civil 1985 Dear Divorce Master Elicker: Enclosed please find Defendant's Pre-Trial Statement as required pursuant to your letter dated September 1, 1999. Very trul yo t ~ F ~' Barbara Sumple-Sullivan BSS/lw cc: Robert C. Saidis, Esquire (w/enclosure) Rosiland Ball (w/enclosure) ED K. BALL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA ~. NO: 1280 Civil 1985 ROSILAND J. BALL, Defendant PRETRIAL STATEMENT 1. Assets. It is believed that all assets of the parties have been distributed to the satisfaction of the parties with the exception of the marital residence and the marital portion of Husband's employment benefits from C.H. Masland & Sons, Inc. (now Lear Corporation}. The marital residence is located at 339 9"' Street, New Cumberland, Pennsylvania. After the separation, Wife along with the parties' children resided in the marital residence. Wife continues to reside in the marital residence. The value as of the date of separation in April, 1983 was not determined at that time. Wife will need to hire an appraiser to do a forensic study. Husband has a fair market value of the marital residence of record by his appraisal of $49,000 as of December 21, 1988. Since the separation, Wife has expended ir. excess of $18,000 in improvements on the home. The balance of the parties' mortgage as of the date of separation was $10,597.56. Wife has paid the mortgage since separation. There appears to be three (3) components of Husband's employment benefits. They are SARP, Security Plan and Profit Sharing. The value of the marital portion must be determined as well as any increase on same since date of separation. Wife has requested that Husband forward a copy of the valuation prepared by Mr. Leister. 2. Witnesses. Lav: a. Defendant b. Plaintiff, as on cross. c. Others to be identified. Expert: If the parties cannot agree on the value of the remaining assets, said experts shall testify and submit their values at trial. Wife reserves the right to identify additional witnesses prior to trial. consider the length of the parties' marriage, Wife's contribution to the marriage and Husband's superior financial position. Wife is unable to offer a specific resolution until the exact nature and value of Husband's employment benefits and income are determined. Wife is in need of monthly assistance through alimony pendente lite and alimony. submitted, DATE: October 29, 1999 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court LD. 32317 Attorney for Defendant -3- ED K. BALL, Plaintiff v. ROSILAND J. BALL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 1280 Civil 1985 CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing PRETRIAL STATEMENT, in the above-captioned matter upon the following individual(s) by first class mail, postage prepaid, addressed as follows: Robert C. Saidis, Esquire Saidis, Shuff & Masland 26 West High Street P.O. Box 560 Carlisle, PA 17013 DATED: October 29, 1999 ~,1~ /' - ~' ;` s, / ~ ~ _._ Barbara Sumple-Sullivan, Esquire Attorney for Defendant 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court LD. No. 32317 ED K. BALL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, F?ENNSYLVANIA Vs. N0. 1280 CIVIL 1985 ROSILAND J. BALL, Defendant IN DIVORCE ORDER OF OURT AND NOW, this day of , n November 22, 1988, the economic claims raised in the 2000, a divorce decree having been entered prey ously o proceedings having been resolved in accordance with a marital settlement agreement dated March 22, 2000, the appointment of the Master is vacated. J. cc: Robert C. Saidis Attorney for Plaintiff Barbara Sumple-Sullivan Attorney for Defendant ~~ o~ a ~~5 BY THE COURT, ,~: ,~_ ~,~~ ~s, ,. ~ ~. ::, } MARITAL SETTLEMENT AGREEZViENT THIS AGREEMENT, made this 2~~ day of f~,{ h~t2(,l,{ 2000, by and between ED K. BALL, hereinafter referred to as "HLrSBAND", and ROSILAND J BALL, hereinafter referred to as "WIFE". WITIVESSETH, That: WHEREAS, the parties hereto are husband and wife, having been lawfully joined in marriage on July 2, 1966, in Williamsport, Pennsylvania, separated in April of 1983, and divorced on November 22, 1988. WHEREAS, it is the intention of the parties to settle fully and finally their respective financial and property rights and obligations as between each other arising out of the marriage relationship or otherwise, including without limitation (1) the settling of all matters between them relating to the ownership of real and personal property, (2) the settling of aII matters between them relating to the past, present and future support andior maintenance of HL"SI3.A~D and WIFE; and (3 j the settling of all matters between them relating to any and alI ri~,hts. titles and interests, claims and possible claims in or against the estate of the other. NOW THEREFORE, with the foregoing recitals being hereinafter incorporated by reference and deemed an essential part hereof in consideration of the foregoing recitals, the mutual promises, covenants and undertakings herein set forth, and for v~ood and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto. HUSBAND and WIFE, each intending to be legally bound hereby, covenant and a~_~re~ as f~~llu~~~ ,. 1. ADVICE OF COUNSEL HUSBAND and WIFE declare that they have each had a hill and fair opporrtunity to obtain independent legal advice of counsel of their selection. ROS1LAti~ 1 B.aLL has been independently represented by Barbara Sumple-Sullivan, Esquire. ED K. BALL is cognizant of his right to legal representation and declares that he has been independently represented by Robert C. Saidis, Esquire. Each party further declares that they are executing this agreement freely and voluntarily, having obtained such knowledge and disclosure of there legal rights anal obligations and that they acknowledge that this agreement is fair and equitable and is not the result of any fraud, coercion, duress, undue influence or collusion. 2. PERSONAL RIGHTS HUSBAND and WIFE may and shall, at all times hereafter, live separate and apart. Each shall be free from all control, restraint, interference or authority, direct or indirect, by the other in all respects as if she or he were unmarried, except as may be necessary to carry out the provisions of this Agreement. Each may reside at such place or places as she or he 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. This provision shall not be taken, however, to be an admission on the part of either HUSB~~~"D or WIFE of the lawfulness of the causes which led to, or resulted in, the continuation of their livin~7 apart. HLSB:-~'~~~D and WIFE shall not molest, harass, or malign the other or the respective families of each other, nor compel the other to cohabit or dwell in any manner with him or her, nor in any way interfere with the peaceful existence, separate from each other. 3. DEBTS Each party represents that they have not contracted any debt or liability for the other for which the estate of the other party may be responsible or liable except as otherwise provided herein, and that except only for the rights arising out of this Agreement, neither party will hereafter incur any liability whatsoever for which the other party or the estate of the other party will be liable. Each party agrees to indemnify and hold harmless from and against all future obligations of every kind incurred by them, including those for necessities. The parties acknowledge that they were defendants in a civil suit brought by Sears. Roebuck and Company filed in the Court of Common Pleas of Cumberland County to Docket Number 99-202. Sears, Roebuck and Company requested in their civil suit repayment of FIVE THOUSAI~'D NINE HUNDRED SIXTY SEVEN DOLLARS AND NINETY S>=:V~N CENTS ($5,967.97) for non-payment of the parties' Sears Credit card. Sears, Roebuck and Company has accepted the sum of FOUR THOUSAND TWO HUNDRED DOLLARS (54,200.00) as payment in full for this debt. HUSBAND has paid this sum directly to Sears, Roebuck and Company. This civil suit has been resolved and WIFE agrees to be liable on this or any other debt to Sears, Roebuck and Company. WIFE further acknowledges that this credit card and all joint credit card accounts have been paid in full and closed. To the best of the parties' knowledge, the parties atlirm no other joint debts exist. 4. W:~IVER OF APPRAISAL AND INVENTORY The parties acknowledge and agree that they have each had an opportunity to value or have appraised any and all marital property, and they do hereby waive a formal appraisal and inventory of same, and no statement or representation by either party as to value shall be deemed a misstatement or misrepresentation to the other or be deemed fraudulent. 5. MARITAL AND NON-MARITAL ASSETS HUSBAND and WIFE do hereby acknowledge that they have heretofore divided the non- marital assets and marital assets including but without limitation, business interests, jewelry.. clothes, furniture, stocks, bonds, pensions and other assets wherever situated whether real, personal or mixed, tangible or intangible, and HUSBAND agrees that all assets in the possession of WIFE shall be the sole and separate property of WIFE; and, WIFE agrees that all assets in the possession of HUSBAi~1D shall be the sole and separate property of HUSBAND. Each of the parties does hereby specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may have with respect to any of the above said items which are the sole and separate property of the other. This document shall constitute a bill of sale for said sole property. 6. REAL ESTATE The parties jointly own property located at 339 9"' Street, New Cumberland, Pennsylvania. Said house is not encumbered by a mortgage. HIJSB~=AND agrees to convey his interest in this real estate to WIFE. HUSBAND agrees to execute a deed simultaneously with this Agreement in the form attached hereto as Exhibit "A" wherein he assigns, conveys and transfers to WIFE all of his right, title and interest in the marital real estate. WIFE agrees to assume responsibility for any liabilities associated with this real estate, such as taxes and insurance and agree to hold HUSBAND harmless for said debts. --~ 7. MOTOR VEHICLES The parties agree that each shall become the sole and exclusive owner of their respective vehicles. The tiles shall be executed by the parties, if appropriate, in order to effectuate transfer as herein provided. 8. PENSION Each party hereby waives any and all claims that he or she may have against the other to any pension, employee saving or other stock benefit program of the other. if applicable. ~~~ IFE specifically waives any interest she may have in any employment benefits that HUSBAND has through his employer, CH Masland's & Sons, Inc., now Lear Corporation, including but not limited to the Lear Corporation Salaried Retirement Savings Plan and any other pension benefits. WIFE agrees to execute any documents HUSBAND's employer may require to effectuate the provisions of this paragraph. 9. INSURANCE. BANK ACCOUNTS AND INVESTiVIENTS Each party shall have sole possession of any life insurance policies, bank accounts and/or in their own names. 10. LUtiIP SLi tii Simultaneously with the execution of this Agreement in consideration of WIFE's waiver of all rights arising from the marital relationship, except as provided herein, HUSB~'~1D shall pay WIFE the sum of EIGHT HUNDRED ($500.00) DOLL~EZS. 11. 1VLUTUAL WAIVER AND RELEASE OF RIGHTS -AND CL~=#IMS CONFERRED BY THE PENNSYLV~NIa DIVORCE ACT OE 1980, AS AMENDED HUSBAND and WIFE acknowledge and agree that the provisions of this Agreement are fair, adequate and satisfactory to them. Both parties agree to accept the provisions set forth in this agreement in lieu of and in full and final settlement and satisfaction of ail claims and demands that either may now or hereafter have against the other for equitable distribution, alimony, alimony pendente lite, counsel fees, costs and expenses or other provisions for their support and maintenance before, during and after the commencement of any proceeding for divorce or annulment between the parties. L. AFTER ACQUIRED PERSONAL PROPERTY/FUTURE EARI~IINGS Each of the parties shall hereafter own and enjoy independently of any claim or ri~,ht of the other, all items of personal property, tangible or intangible, hereafter acquired by HUSBAND or WIFE, with full power in him or her to dispose of the same as fully and et~ectively, in all respects and for all purposes, as though he or she were unmarried. Z3. ALIMONY, SUPPORT AND MAINTENANCE Both parties acknowledge and agree that the provisions of this Agreement providing for equitable distribution of marital property are fair, adequate and satisfactory to them and are accepted by them in lieu of and in full and final satisfaction of any claims or demands that either may now or hereafter have against the other for support, maintenance or alimony. HUSBAND and WIFE fi~rther, voluntarily and intelligently, waive and relinquish any right to reel: ti-om the 6 other any payment for spousal support, alimony and maintenance. 14. DIVORCE A decree in divorce was entered in this matter on November 22, 1988. Said decree shall not suspend, supersede or affect the terms of this Agreement. 15. OTHER DOCUII~IENTATION HUSBA'v"D and WIFE covenant and agree that upon request of the other party, they will forthwith execute and deliver to the other party, any and aII written instruments, assignments. releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this Agreement. 16. MUTUAL WAIVER AND RELEASE OF RIGHTS AND CLAIit~IS Iti' ESTATE Each party hereby releases, waives and relinquishes any and all rights which he or she may now have, or may hereafter have, against the other party under the present or future laws of any jurisdiction (a) to share in the estate of the other party upon the other party's death and (b) to act as executor/rix or administrator/rix of the other party's estate. I7. MUTUAL RELEASE HUSBAND and WIFE 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 she or he now has or at anv time hereafter may have against such other, the estate of such other or any part thereof., whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of equitable distribution, dower or curtesy, or claims in the nature of dower or courtesy of vv~ido~~'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 to 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 and rights which HL'SBAVD or WIFE may have or at any time hereafter have for the past, present or future support or maintenance, alimony. alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, 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, Each of the parties hereto further covenants and agrees for himself and herself and his or her heirs, executors, administrators and assigns, that he or she will never, at any time hereafter, sue the other party or his or her heirs, executors, administrators and assigns, for the purpose of enforcing a~1~~ ~,fthe ri~~hts relinquished under this para«raph. Each of the parties tzirther covenants and agrees that he or she will permit any will of the other to be probated and allow administration upon his or her personal, real or mixed estate and allow effects to be taken out by the person or persons who wotfld have been entitled to do so had HUSBAND or WIFE died during the lifetime of the other. Each of the parties hereby releases, relinquishes and waives anv and all right to act as executor or executrix or administrator or administratrix of the other's estate. It is the intention of HUSBA1~iD and WIFE to give to each other by the execution of this Marital Settlement 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 anv thereof. 18. SUCCESSOR'S RIGIITS AND LIABILITIES This Agreement shall, except as otherwise provided herein, be binding upon and inure to the benefit of the parties hereto, their respective heirs, executors, administrators, successors or assi~~ns. 19. SEVERABILITY If any provision in this Agreement is held by a court of competent jurisdiction to be invalid, void, or unenforceable, the remaining provisions shall nevertheless continue in full force and effect without being impaired or invalidated in any wav. 20. ENTIRE AGREEMENT HLJSBAwD and WIFE do hereby covenant ana warrant that this Agreement contains all of the representations, promises and Agreements made by either of them to the other for the purposes set forth in the preamble hereinabove; that there are no claims, promises or representations not herein contained, either oral or written, which shall or may be chard=ed or 9 enforced or enforceable unless reduced to writing and signed by both of the parties hereto. 21. BINDING EFFECT OF AGREEiyIENT/WAIVER This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon. strict performance of the provisions of this A~~reement shall not be construed as a waiver of anv subsequent default of the same or similar nature, nor shall such failure be construed as a waiver of any other term, condition, clause or provision of this Ay~reement. 22. BREACH If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as may be available to him or her, and the party breaching this contract shall be responsible for payment of reasonable legal fees and costs incurred by the other in enforcing their rights under this Agreement. 23. CONTROLLING LAW This Agreement shall be construed and ~~overned in accordance with the laws of the Commonwealth of Pennsylvania. 10 24. CONDITION PRECEDENT TO TAE AGREEMENT'S EFFECTIVENESS The parties acknowledge that this Agreement shall become effective when actually signed by both parties. WITNE S `! ED K. BALL WITNESS ROSILAND J. BAL 11 CONIlVtONWEALTH OF PENNSYLVr1NIA ) SS. COUNTY OF CUtiIBERLAND ) Before me, the undersigned officer, a Notary Public in and for said Commonwealth and County, personally appeared ED K. BALL, who being duly affirmed according to law, deposes and says that the facts and matter set forth in the within and foregoing Marital Settlement Agreement are true and correct to the best of his knowledge, information and belief. Affirmed and subscribed to before me this ~~ day of~~ ?000. Nor~aw, arx ~ ~aaai, nror~wr ~ueuc OTAR L c~wus~ soAO. cx.,~lrao ca~rtr u~r ooartirr s ~atu~ar so. ~oo+ IVty commission expires: (SEAL) COivIIv10NWEALTH OF PEN~iSYLVAIVIA ) SS. COUNTY OF CUMBERLAi~1D ) Before me, the undersigned officer, a Notary Public in and for said Commonwealth and County, personally appeared ROSILAND J. BALL, who being duly affirmed according to law, deposes and says that the facts and matter set forth in the within and foregoing iVlarital Settlement Agreement are true and correct to the best of her knowledge, information and belief. ~rmed and subscribed to before me this ~~~ day of t ~~2000. Notarial Seal Barbara Sumple-Sullivan, Notary Pubic New Cumberland Boro, Cumberland Cour, - Commission Expires November 15, 2CC+: N T Y PUBLIC My commission expires: (SEAL) l? EXHIBIT "A" THIS DEED MADE THE day of , ?000 BETWEEN ED K. BALL and ROSILAI~TD J. BALL, herein designated as the Grantors, AND ROSILAiND J. BALL, of New Cumberland, Cumberland County, Pennsylvania, herein designated as the Grantee; WITNESSETH, that in consideration of the sum of One (51.00) Dollar, in hand paid. the receipt whereof is acknowledged, Grantors do hereby Grant and com~ey to Grantee, her heirs and assigns. ALL that certain lot or tract of land situate in New Cumberland, Cumberland County. Pennsylvania bounded and described in accordance with a survey by G. J. Betz, R.S. dated :august 10, ] ~?? to wit BEGINNING at a point on the Northern line of 9"' Street at a distance of 90 feet measured in an Easterly direction by same from the Northeast corner of 9`'' Street and a 1 ~. ~ feet wade alley said alley having been increased in width from 10 feet by the addition of the Western l .~ feet of Lot no~ 3S and the Eastern 2 feet of Lot. 61-A on the Plan of Lots hereinafter mentioned); THENCE North 30 degrees 10 minutes West along a line parallel with said alley 100 feet to a point on the Southerly line of a 10 feet wide alley; THENCE North ~9 degrees 50 minutes East along the Southerly line of said 10 feet ~~,ide alley ?2.~ feet to a point on a line running thru the center of the partition wall of the double house erected on the Lot herein described and the adjoining Lot on the East; THENCE South 30 degrees 10 minutes East along the said last mentioned line of 100 feet to a point on the Northerly line of 9``' Street; THENCE South ~9 degrees 50 minutes West along the Northerly line of 9`'' Street 22.E feet to a point at the place of BEGINNING. BEING the Eastern 8.5 feet of Lot No. 37 and the Western 14 feet of Lot No. 36 on the Plan of Lots known as Seven Maples No. 1, said Plan being recorded in the Cumberland County R_ecorder's Office in Plan Book 1, Page 94. BEING known as No. 339 9`'' Street. BELNG the same premises which Robert E. Braun, by deed dated August 23, 197? and recorded .=~u«ust 24, 197? in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Record Book T24, Page 9~5, granted and conveyed unto ED I<. BALL and ROSILAND J. >3AL L. the Grantors herein. THIS TRANSFER IS EXEMPT FROM TRANSFER TAB SINCE IT IS A TRANSFER BETWEEN PERSONS WHO WERE PREVIOUSLY HUSBAND AND WIFE WHO HAVE SINCE BEEN DIVORCED TOGETHER with all and singular the buildings, improvements, ways, woods, waters, watercourses, rights. liberties, privileges, hereditaments and appurtenances to the same belonging or in anywise appertainin~~; and the reversion and reversions, remainder and remainders, rents, issues and profits thereof, and of every part and parcel thereof; A1ND also all the estate, right, title, interest, use, possession, prcperty, claim and demand whatsoever of the Grantors both in law and in equity, of, in and to the premises herein described and every part and parcel thereof with the appurtenances. TO H_=~VE AND TO HOLD all singular the premises herein described together with the hereditaments and appurtenances unto the Grantees and to Grantees' proper use and benefit forever. AND the Grantors, for their self, their successors and assigns, does covenant, promise and agree, to and with the said Grantee, her heirs and assigns, by these presents, that the said Grantors, their successors and assigns, all and singular the hereditaments and premises hereby granted or mentioned and intended so to be, with the appurtenances, unto the said Grantee, her heirs and assigns, against them, the said Grantors and their successors and assigns, and against all and very person and persons whomsoever lawfully claiming or to claim the same or any part thereof, by, from or under him, her, them or any of them, shall and will SLBJECT as aforesaid, FOREVER SPECL-ALLY WARRANT AND DEFEND. In all references herein to, any parties, persons, entities or corporations, the use of any particular gender or the plural or singular number is intended to include the appropriate Gender or number as the text of the within instrument may require. Wherever in this instrument any party shall be designated or referred to by name or general reference, such designation is intended to and shall have the same effect as if the words "heirs, executors, administrators, personal or legal representatives, successors and assigns' had been inserted after each and every such designation. IN `VIT~ESS `VHEREOF, the said Grantors have hereunto set their hands and seals the day and year first above written. Signed, Sealed, and Delivered In the Presence of WITNESS WITNESS ED K. BALL ROSILAND J. BALL COMILIONWEALTH OF PENIVSYL v4N"I~-1 ) ~~ ~ S.S COUNTY OF -~ On this day of , ?000, before me, a Notary Public, the undersigned officer, personally appeared, to me to be the person whose name is ED K. BALL subscribed to the within instrument, and acknowledge that he executed the foregoing DEED in the capacity therein stated and for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public My commission expires: (SEAL} COItiLYIONWEAT TH OF PENNSYI. i!4NL4 ) .ss. COUNTY OF ) On this day of , ?000, before me, a Notary Public, the undersigned officer, personally appeared, to me to be the person whose name is ROSILAND J. BALL, subscribed to the within instniment, and acknowledge that she executed the foregoing DEED in the capacity therein stated and for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and ot~icial seal. Notary Public My commission expires: (SE,~L) I hereby certify that the precise residence of the Grantee is: Rosiland J. Ball 3 ~9 9`'' Street New Cumberland, PA 17070 CO~I~~fONT~'EALTH OF PENNSYL vANIA ) S.S COUNTY OF CU~YIIs'ERI_f4Nl~ ) Recorded in the Office for Recording of Deeds in and for in Deed Book ,Page ,Volume Witness my hand and Seal of Office this _ day of 2000. Recorder 4 `. MARITAL SETTLEMENT AGREEMENT ., , , ia~o c l~~S THIS AGREEMENT, made this 2~- day of ~ ~~-~',(~ 2000, by and between ED K. BALL, hereinafter referred to as "HUSBAND", and ROSILANU J. BALL, hereinafter referred to as "WIFE". WITNESSETH, That: WHEREAS, the parties hereto are husband and wife, having been lawfully joined in marriage on July 2, 1966, in Williamsport, Pennsylvania, separated in April of 1983, and divorced on November 22, 1988. WHEREAS, it is the intention of the parties to settle fully and finally their respective financial and property rights and obligations as between each other arising out of the marriage relationship or otherwise, including without limitation (1) the settling of all matters between them relating to the ownership of real and personal property; (2) the settling of all matters between them relating to the past, present and future support and/or maintenance of HUSBAND and WIFE; and (3) the settling of all matters between them relating to any and all rights, titles and interests, claims and possible claims in or against the estate of the other. NOW THEREFORE, with the foregoing recitals being hereinafter incorporated by reference and deemed an essential part hereof in consideration of the foregoing recitals, the mutual promises, covenants and undertakings herein set forth, and for good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE, each intending to be legally bound hereby, covenant and agree as follows: 1. ADVICE OF COUNSEL HUSBAND and WIFE declare that they have each had a full and fair opportunity to obtain independent legal advice of counsel of their selection. ROSILAND J. BALL has been independently represented by Barbara Sumple-Sullivan, Esquire. ED K. BALL is cognizant of his right to legal representation and declares that he has been independently represented by Robert C. Saidis, Esquire. Each party further declares that they are executing this agreement freely and voluntarily, having obtained such knowledge and disclosure of there legal rights and obligations and that they acknowledge that this agreement is fair and equitable and is not the result of any fraud, coercion, duress, undue influence or collusion. 2. PERSONAL RIGHTS HUSBAND and WIFE may and shall, at all times hereafter, live separate and apart. Each shall be free from all control, restraint, interference or authority, direct or indirect, by the other in all respects as if she or he were unmarried, except as maybe necessary to carry out the provisions of this Agreement. Each may reside at such place or places as she or he 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. This provision shall not be taken, however, to be an admission on the part of either HUSBAND or WIFE of the lawfulness of the causes which led to, or resulted in, the continuation of their living apart. HUSBAND and WIFE shall not molest, harass, or malign the other or the respective families of each other, nor compel the other to cohabit or dwell in any manner with him or her, nor in any way interfere with the peaceful existence, separate from each other. 2 +-. 3. DEBTS Each party represents that they have not contracted any debt or liability for the other for which the estate of the other party may be responsible or liable except as otherwise provided herein, and that except only for the rights arising out of this Agreement, neither party will hereafter incur any liability whatsoever for which the other party or the estate of the other party will be liable. Each party agrees to indemnify and hold harmless from and against all future obligations of every kind incurred by them, including those for necessities. The parties acknowledge that they were defendants in a civil suit brought by Sears, Roebuck and Company filed in the Court of Common Pleas of Cumberland County to Docket Number 99-5202. Sears, Roebuck and Company requested in their civil suit repayment of FIVE THOUSAND NINE HUNDRED SIXTY SEVEN DOLLARS AND NINETY SEVEN CENTS ($5,967.97) for non-payment of the parties' Sears Credit card. Sears, Roebuck and Company has accepted the sum of FOUR THOUSAND TWO HUNDRED DOLLARS ($4,200.00) as payment in full for this debt. HUSBAND has paid this sum directly to Sears, Roebuck and Company. This civil suit has been resolved and WIFE agrees to be liable on this or any other debt to Sears, Roebuck and Company. WIFE further acknowledges that this credit card and all joint credit card accounts have been paid in full and closed. To the best of the parties' knowledge, the parties affirm no other joint debts exist. 4. WAIVER OF APPRAISAL AND INVENTORY The parties acknowledge and agree that they have each had an opportunity to value or have appraised any and all marital property, and they do hereby waive a formal appraisal and ,c inventory of same, and no statement or representation by either party as to value shall be deemed a misstatement or misrepresentation to the other or be deemed fraudulent. 5. MARITAL AND NON-MARITAL ASSETS HUSBAND and WIFE do hereby acknowledge that they have heretofore divided the non- marital assets and marital assets including but without limitation, business interests, jewelry, clothes, furniture, stocks, bonds, pensions and other assets wherever situated whether real, personal or mixed, tangible or intangible, and HUSBAND agrees that all assets in the possession of WIFE shall be the sole and separate property of WIFE; and, WIFE agrees that all assets in the possession of HUSBAND shall be the sole and separate property of HUSBAND. Each of the parties does hereby specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may have with respect to any of the above said items which are the sole and separate property of the other. This document shall constitute a bill of sale for said sole property. 6. REAL ESTATE The parties jointly own property located at 339 9"' Street, New Cumberland, Pennsylvania. Said house is not encumbered by a mortgage. HUSBAND agrees to convey his interest in this real estate to WIFE. HUSBAND agrees to execute a deed simultaneously with this Agreement in the form attached hereto as Exhibit "A" wherein he assigns, conveys and transfers to WIFE all of his right, title and interest in the marital real estate. WIFE agrees to assume responsibility for any liabilities associated with this real estate, such as taxes and insurance and agree to hold HUSBAND harmless for said debts. 4 7. MOTOR VEHICLES The parties agree that each shall become the sole and exclusive owner of their respective vehicles. The tiles shall be executed by the parties, if appropriate, in order to effectuate transfer as herein provided. 8. PENSION Each party hereby waives any and all claims that he or she may have against the other to any pension, employee saving or other stock benefit program of the other, if applicable. WIFE specifically waives any interest she may have in any employment benefits that HUSBAND has through his employer, CH Masland's & Sons, Inc., now Lear Corporation, including but not limited to the Lear Corporation Salaried Retirement Savings Plan and any other pension benefits. WIFE agrees to execute any documents HUSBAND'S employer may require to effectuate the provisions of this paragraph. 9. INSURANCE, BANK ACCOUNTS AND INVESTMENTS Each party shall have sole possession of any life insurance policies, bank accounts and/or in their own names. 10. LUMP SUM Simultaneously with the execution of this Agreement in consideration of WIFE's waiver of all rights arising from the marital relationship, except as provided herein, HUSBAND shall pay WIFE the sum of EIGHT FICJNDRED ($800.00) DOLLARS. 11. MUTUAL WAIVER AND RELEASE OF RIGHTS AND CI AIMS CONFERRED BY THE PENNSYLVANIA DIVORCE ACT OF 1980 AS AMENDED HUSBAND and WIFE acknowledge and agree that the provisions of this Agreement are fair, adequate and satisfactory to them. Both parties agree to accept the provisions set forth in this agreement in lieu of and in full and final settlement and satisfaction of all claims and demands that either may now or hereafter have against the other for equitable distribution, alimony, alimony pendente lite, counsel fees, costs and expenses or other provisions for their support and maintenance before, during and after the commencement of any proceeding for divorce or annulment between the parties. 12. AFTER ACQUIRED PERSONAL PROPERTY/FUTURE EARNINGS Each of the parties shall hereafter own and enjoy independently of any claim or right of the other, all items of personal property, tangible or intangible, hereafter acquired by HUSBAND or WIFE, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried. 13. ALIMONY SUPPORT AND MAINTENANCE Both parties acknowledge and agree that the provisions of this Agreement providing for equitable distribution of marital property are fair, adequate and satisfactory to them and are accepted by them in lieu of and in full and final satisfaction of any claims or demands that either may now or hereafter have against the other for support, maintenance or alimony. HUSBAND and WIFE further, voluntarily and intelligently, waive and relinquish any right to seek from the 6 such other, of whatever nature and wheresoever situate, which she or he now has or at any time hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of equitable distribution, dower or curtest', or claims in the nature of dower or courtesy of 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 to 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 and rights which HUSBAND or WIFE may have or at any time hereafter have for the past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, 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. Each of the parties hereto further covenants and agrees for himself and herself and his or her heirs, executors, administrators and assigns, that he or she will never, at any time hereafter, sue the other party or his or her heirs, executors, administrators and assigns, for the purpose of enforcing any of the rights relinquished under this paragraph. Each of the parties further covenants and agrees that he or she will permit any will of the other to be probated and allow administration upon his or her personal, real or mixed estate and allow effects to be taken out by the person or persons who would have been entitled to do so had HUSBAND or WIFE died during the lifetime of the other. Each of the parties hereby releases, relinquishes and waives any and all right to act as executor or executrix or administrator or administratrix of the other's estate. It is the intention of HUSBAND and WIFE to give to each other by the execution of this Marital Settlement 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. 18. SUCCESSOR'S RIGHTS AND LIABILITIES This Agreement shall, except as otherwise provided herein, be binding upon and inure to the benefit of the parties hereto, their respective heirs, executors, administrators, successors or assigns. 19. SEVERABILITY If any provision in this Agreement is held by a court of competent jurisdiction to be invalid, void, or unenforceable, the remaining provisions shall nevertheless continue in fiill force and effect without being impaired or invalidated in any way. 20. ENTIRE AGREEMENT HUSBAND and WIFE do hereby covenant and warrant that this Agreement contains all of the representations, promises and Agreements made by either of them to the other for the purposes set forth in the preamble hereinabove; that there are no claims, promises or representations not herein contained, either oral or written, which shall or may be charged or 9 enforced or enforceable unless reduced to writing and signed by both of the parties hereto. 21. BINDING EFFECT OF AGREEMENTIWAIVER This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature, nor shall such failure be construed as a waiver of any other term, condition, clause or provision of this Agreement. 22. BREACH If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as maybe available to him or her, and the party breaching this contract shall be responsible for payment of reasonable legal fees and costs incurred by the other in enforcing their rights under this Agreement. 23. CONTROLLING LAW This Agreement shall be construed and governed in accordance with the laws of the Commonwealth of Pennsylvania. 10 24. CONDITION PRECEDENT TO THE AGREEMENT'S EFFECTIVENESS The parties acknowledge that this Agreement shall become effective when actually signed by both parties. WITNE S ~~ l ~a~(~ ~~ 1~~~~ WITNESS ROSILAND J. BAL 11 r• COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND ) Before me, the undersigned officer, a Notary Public in and for said Commonwealth and County, personally appeared ED K. BALL, who being duly affirmed according to law, deposes and says that the facts and matter set forth in the within and foregoing Marital Settlement Agreement are true and correct to the best of his knowledge, information and belief. Affirmed and subscribed to before me this oZ~~~ day of ~~ 2000. ~~~~ -roT~ e~ ~ _ wwa ~. tom. INOTARY PU84~C OT AR L ~u8tlr e0~. SID 00ut~m' ' ur co~ussior, s ~wav so, aoo, My commission expires: (SEAL) COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND ) Before me, the undersigned officer, a Notary Public in and for said Commonwealth and County, personally appeared ROSILAND J. BALL, who being duly affirmed according to law, deposes and says that the facts and matter set forth in the within and foregoing Marital Settlement Agreement are true and correct to the best of her knowledge, information and belief. subscribed to before me this ~r~ da of ~s ~ C~~-!2000. Y N(~TAkY PUBLIC Notarial Seal Barbara Sumple-Sullivan, Notary Pub;+~ New Cumberland Boro, Cumberland Coun, Cammission Expires November 15, 20Cz, My commission expires: (SEAL) 12 EXHIBIT "A" ~. THIS DEED MADE THE day of , 2000 BETWEEN ED K. BALL and ROSILAND J. BALL, herein designated as the Grantors, AND ROSILAND J. BALL, of New Cumberland, Cumberland County, Pennsylvania, herein designated as the Grantee; WITNESSETH, that in consideration of the sum of One ($1.00) Dollar, in hand paid, the receipt whereof is acknowledged, Grantors do hereby grant and convey to Grantee, her heirs and assigns. ALL that certain lot or tract of land situate in New Cumberland, Cumberland County, Pennsylvania bounded and described in accordance with a survey by G. J. Betz, R.S. dated August ] 0, 1972 to wit: BEGINNING at a point on the Northern line of 9`~ Street at a distance of 90 feet measured in an Easterly direction by same from the Northeast corner of 9`'' Street and a 13.5 feet wide alley (said alley having been increased in width from 10 feet by the addition of the Western l .5 feet of Lot no. 3 8 and the Eastern 2 feet of Lot. 61-A on the Plan of Lots hereinafter mentioned); THENCE North 30 degrees 10 minutes West along a line parallel with said alley 100 feet to a point on the Southerly line of a 10 feet wide alley; THENCE North 59 degrees 50 minutes East along the Southerly line of said 10 feet wide alley 22.5 feet to a point on a line running thru the center of the partition wall of the double house erected on the Lot herein described and the adjoining Lot on the East; THENCE South 30 degrees ] 0 minutes East along the said last mentioned line of 100 feet to a point on the Northerly line of 9"' Street; THENCE South 59 degrees 50 minutes West along the Northerly line of 9"' Street 22.5 feet to a point at the place of BEGINNING. BEING the Eastern 8.5 feet of Lot No. 37 and the Western 14 feet of Lot No. 36 on the Plan of Lots known as Seven Maples No. 1, said Plan being recorded in the Cumberland County Recorder's Office in Plan Book 1, Page 94. BEING known as No. 339 9`" Street. BEING the same premises which Robert E. Braun, by deed dated August 23, 1972 and recorded August 24, 1972 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Record Book T24, Page 948, granted and conveyed unto ED K BALL and ROSILAND J. BALL, the Grantors herein. THIS TRANSFER IS EXEMPT FROM TRANSFER TAX SINCE IT IS A TRANSFER BETWEEN PERSONS WHO WERE PREVIOUSLY HUSBAND AND WIFE WHO HAVE SINCE BEEN DIVORCED TOGETHER with all and singular the buildings, improvements, ways, woods, waters, watercourses, rights, liberties, privileges, hereditaments and appurtenances to the same belonging or in anywise appertaining; and the reversion and reversions, remainder and remainders, rents, issues and profits thereof, and of every part and parcel thereof; AND also all the estate, right, title, interest, use, possession, property, claim and demand whatsoever of the Grantors both in law and in equity, of, in and to the premises herein described and every part and parcel thereof with the appurtenances. TO HAVE AND TO HOLD all singular the premises herein described together with the hereditaments and appurtenances unto the Grantees and to Grantees' proper use and benefit forever. AND the Grantors, for their self, their successors and assigns, does covenant, promise and agree, to and with the said Grantee, her heirs and assigns, by these presents, that the said Grantors, their successors and assigns, all and singular the hereditaments and premises hereby granted or mentioned and intended so to be, with the appurtenances, unto the said Grantee, her heirs and assigns, against them, the said Grantors and their successors and assigns, and against all and very person and persons whomsoever lawfully claiming or to claim the same or any part thereof, by, from or under him, her, them or any of them, shall and will SUBJECT as aforesaid, FOREVER SPECIALLY WARRANT AND DEFEND. In all references herein to any parties, persons, entities or corporations, the use of any particular gender or the plural or singular number is intended to include the appropriate gender or number as the text of the within instrument may require. Wherever in this instrument any party shall be designated or referred to by name or general reference, such designation is intended to and shall have the same effect as if the words "heirs, executors, administrators, personal or legal representatives, successors and assigns" had been inserted after each and every such designation. IN WITNESS WHEREOF, the said Grantors have hereunto set their hands and seals the day and year first above written. Signed, Sealed, and Delivered In the Presence of WITNESS WITNESS ED K. BALL ROSILAND 1. BALL 2 ~ ~. i COMMONWEALTH OF PENNS'YL VANIA ) SS. COUNTY OF ~-~ ) a~. On this day of , 2000, before me, a Notary Public, the undersigned officer, personally appeared, to me to be the person whose name is ED K. BALL subscribed to the within instrument, and acknowledge that he executed the foregoing DEED in the capacity therein stated and for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public My commission expires: (SEAL) COMMONWEALTH OF PENNSYL VANIA ) SS. COUNTY OF ) On this day of , 2000, before me, a Notary Public, the undersigned officer, personally appeared, to me to be the person whose name is ROSILAND J. BALL, subscribed to the within instrument, and acknowledge that she executed the foregoing DEED in the capacity therein stated and for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public My commission expires: (SEAL) I hereby certify that the precise residence of the Grantee is: Rosiland J. Ball 339 9rh Street New Cumberland. PA 17070 -, • f '~ COMMONWEALTH OF PENNSYL vANIA ) ) ss COUNTY OF CUMBERLAND ) Recorded in the Office for Recording of Deeds in and for in Deed Book ,Page ,Volume Witness my hand and Seal of Office this _ day of 2000. Recorder 4