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Home My WebLink About04-0680 Stephanie V. Sorensen, IN THE COURT OF COMMON PLEAS Plaintiff: CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. c>LI - t...ro C,'v~L ~VV) Larry W. Sorensen, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgement may also be entered against you for any other claim.or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at: The Office of the prothonotary, Dauphin County Courthouse, Front and Market Streets, Harrisburg, Pennsylvania 17101. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 MEYERS. DESFOR. SALTZGlVER " BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG. PA 17108 (717\ 236-9428 . FAX (7171236-2817 Stephanie V. Sorensen, Plaintiff: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. Larry W. Sorensen, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICIA LE RAN DEMANDADO A US TED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomaro medidas y puede entrar una orden contra usted sin previa aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion do demanda. Usted puede perder dinero 0 sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 MEYERS, DESFOR. SALTZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG. PA 17108 (717) 236.9428 . FAX (717) 236.2817 Stephanie V. Sorensen, Plaintiff: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04 - I..ro 0IJLL l~ Larry W. Sorensen, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301CC) OR CD) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Stephanie V. Sorensen, by and through her attorneys, Meyers, Desfor, Saltzgiver & Boyle and files the following Complaint in Divorce and in support thereof avers as follows: 1. Plaintiff is Stephanie V. Sorensen, an adult individual who currently resides at 405 Third Street, New Cumberland, Pennsylvania. 2. Defendant is Larry W. Sorensen, an adult individual who currently resides at an unknown location. Defendant works and owns Highland Gardens located at 423 South 18th Street, Camp Hill, Pennsylvania. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 15, 1975, at Steelton, Pennsylvania, Dauphin County. 5. There have been no prior actions of divorce or annulment between the parties. MEYERS, DESFOR. SALTZGIVER " BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG. PA 17108 . (717) 236.9428 . FAX (717) 236.2817 6. The marriage is irretrievably broken. 7. The Defendant is not a member of the United States Army or its allies. 8. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request the court require the parties to participate in counseling, being so advised, Plaintiff waives that right. 9. Plaintiff requests the Court to enter a Decree of Divorce pursuant to Section 3301(C) or 3301(D) of the Divorce Code. WHEREFORE, Plaintiff, Stephanie V. Sorensen, respectfully requests this Honorable Court enter a Decree in Divorce pursuant to Section 3301(C) or 3301(D) of the Divorce Code. COUNTS COUNT I INDIGNITIES 10. Paragraphs one through nine of the Complaint are incorporated by reference as if fully set forth herein. 11. The grounds upon which this action is based are indignities pursuant to Section 3301{a) (6) of the Divorce Code. During the marriage, the Defendant has committed such indignities against the Plaintiff so as to make her life burdensome and intolerable. 12. Plaintiff requests the Court issue a decree in divorce based upon indignities pursuant to section 3301{a) (6) of the Divorce Code. WHEREFORE, Plaintiff, Stephanie V. Sorensen, respectfully MEYERS. DESFOR. SALTZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236.9428 . FAX (717) 236-2817 requests this Honorable Court to issue a Decree in Divorce divorcing him from the bonds of matrimony pursuant to Section 3301(a) (6) of the Divorce Code. COUNT II EOUITABLE DISTRIBUTION 13. Paragraphs one through twelve of the Complaint are incorporated by reference as if fully set forth herein. 14. During the marriage, Plaintiff and Defendant have acquired various items of marital property, both real and personal, which are subject to equitable distribution under the Divorce Code. 15. Plaintiff requests that this Honorable Court equitably distribute all marital property pursuant to the Divorce Code. WHEREFORE, Plaintiff, Stephanie V. Sorensen, respectfully requests this Honorable Court equitably distribute all property, both real and personal, tangible and intangible, acquired by the parties during their marriage. COUNT III ALIMONY PENDENTE LITE. COUNSEL FEES AND EXpENSES 16. Paragraphs one through fifteen of the Complaint are incorporated by reference as if fully set forth herein. 17, By reason of this action, Plaintiff will be put to MEYERS, DESFOR. SALTZGlVER " BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG. PA 17108 (7171236.9428 . FAX (711) 236~2817 considerable expense in the preparation of this case, in the employment of counsel, and the payment of costs. 18. Plaintiff is without sufficient funds to support herself and to meet the costs and expenses of this litigation, and unable to appropriately maintain herself during the pendency of this action. 19'. Plaintiff's income is not sufficient to provide for her reasonable needs and pay her attorneys' fees and the costs of this litigation. 20. Defendant has adequate earnings to provide support and alimony pendente lite to the Plaintiff and to pay her counsel fees, costs and expenses. WHEREFORE, Plaintiff, Stephanie V. Sorensen, respectfully requests this Honorable Court compel the Defendant to pay Plaintiff alimony pendente lite, support, counsel fees, costs and expenses of this action. COUNT IV ALIMONY 21. Paragraphs one through twenty of the Complaint are incorporated by reference as if fully set forth herein. 22, Plaintiff lacks sufficient property to provide for her reasonable needs. 23. Plaintiff is unable to sufficiently support herself through appropriate employment. 24. Defendant has sufficient income and assets to provide MEYERS. DESFOR. SALTZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG. PA 17108 (717) 236-9428 . FAX (717) 236-2817 continuing support and to pay alimony to the Plaintiff. WHEREFORE, Plaintiff, Stephanie V. Sorensen, respectfully requests this Honorable Court compel Defendant to pay alimony to Plaintiff. Respectfully submitted, ~l . ~~r~ne A. Boy e, Esqu~re Meyers, Desfor, Saltzgiver & Boyle Attorney I.D. #76328 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717)236-9428 Attorney for Plaintiff MEYERS. DESFOR. SALTZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 ' HARRISBURG. PA 17108 (717) 236-9428 ' FAX (717) 238-2817 ( VERIFICATION I, Stephanie V, ~OrpnRPn , verify that the statements made in this Complaint In Divorce are true and correct to the best of my knowledge, information and belief. I understand that falsE statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: 2/13/2004 J~V~~ (X) Plaintiff ) Defendant MEYERS, DESFOR. SALTZGIVER & BOYLE 410 NORTH SECOND smEET ' P.O. BOX 1062 . HARRISBURG. PA 17108 (717) 236-9428 . FAX (717) 236-2817 ^Rl ....... ~ ~<>o \i'-"-O ~ ( "'"9. III V? o -4Q., - 0-..0 () ? . t/) 6 g D I C2 g '(, /\ · .... ~ ii~....',; (( 0i f:]) , -...J (0) -- . ~-; 'J "fl~ J~ r- 9 ,,,-.~ : '):T1 0:; ~ .,-... ~2 N -~ Stephanie V. Sorensen, Plaintiff: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04-680 Civil Term Larry W. Sorensen, Defendant CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that on this ~ day of February, 2004, the original and two (2) copies of the attached Interrogatories were sent certified mail and regular U.S. mail, postage prepaid, to: Larry W. Sorensen Highland Gardens 423 South 18'" Street Camp Hill, Pennsylvania 17011 -~, e Catherine A. Boyle, Es Attorney for Plaintiff 35 MEYERS, DESFOR, SALTZGIVEA & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 236-2817 () ...., 0 = c-: "" -n :<-;:;", ..r- ..., ::;:f ,",') fil~ CD N -om --1' _'.J (", ~~C) :? :::r~~ f'..!Cl -:- ;.=-:n"'j c,~ U -'.:....... ::-;;! :< en ~:o .< , , Stephanie V. Sorensen, Plaintiff: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04-680 Civil Term Larry W. Sorensen, Defendant CIVIL ACTION - LAW IN DIVORCE I hereby certify on this CERTIFICATE OF SERVICE {1~ day of February, 2004, that the foregoing Request for production of Documents was sent certified mail and regular U.S. Mail, first-class, postage pre- paid to: Larry W. Sorensen Highland Gardens 423 South 18tl. Street Camp Hill, Pennsylvania, therine A. Attorney for MEYERS, DESFOR. SALTZGIVER &; BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236.9428 . FAX (717) 236-2817 ~ (') "" 0 '= c: = ," C~ ",... -1') '~'.. "TJ 'j:! f ~!, , n I r-'1 n'lfll CO 1'" -f'Jfi3 ~;] c..., C:) ::-fSf.~ . ""1:1 ;X::!", ~. ~_dc5 ' , ~:r;:,. '- ;-',::rq ~~~ c...) '-J ""- 5;! ::< (Jl ~X] Cl -< Stephanie V. Sorensen, Plaintiff: IN THE COURT OF COMMON PLEAS CUMBERL~ill COUNTY, PENNSYLVANIA vs. NO. 04-680 Civil Term Larry W. Sorensen, Defendant CIVIL ACTION - LAW IN DIVORCE PROOF OF SERVICE FOR REOUEST FOR PRODUCTION OF DOCUMENTS & INTERROGATORIES 358b 1~1540 MEYERS, OESFOR, SALTZGIVER ii. BOYLE 410 NORTH SECOND STREET. P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX {7i7l 2313-2817 Stephanie V. Sorensen, Plaintiff: IN THE COURT OF COMMON PLEAS CUMBERL~ill COUNTY, PENNSYLVANIA vs. NO. 04-680 Civil Term Larry W. Sorensen, Defendant CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I hereby certify on this J..~~ day of February, 2004 a copy of Proof of Service for Request of Production of Documents and Interrogatories was sent VIA U.S. Mail to: Larry W. Sorensen Highland Gardens 423 South 18'" Street Camp Hill, PA 17011 Respect::ully submitted, ~~a Catherine A. Boyle, squ MEYERS, DESFOR, SALTZGI & BOYLE Attorney I.D. #76328 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717) 236-9428 Attorney for Plaintiff MEYERS, DESFOR, SALTZGIVEA ~f.: BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 2313-2817 ,,~ C:~;J 0 (,;~) ..c.;- -n -'1 :;:1 , 1'1 " ( (::;J fn i:"'" r~.) ~jtj r {II ~. (". ! -'I''' ""iCJ "" , , :E' , , , f:'~) n i -. -', CO Stephanie V. Sorensen, Plaintiff: IN THE COURT OF COMMON PLEAS CUMBERLAJITl COUNTY, PENNSYLVANIA vs. NO. 04-680 Civil Term Larry W. Sorensen, Defendant CIVIL ACTION - LAW IN DIVORCE PROOF OF SERVICE COMPLAINT IN DIVORCE 3579 .-- MEYERS, DESFOR. SALTZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 .. HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 236-2817 Stephanie V. Sorensen, Plaintiff: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04-680 Civil Term Larry W. Sorensen, Defendant CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I hereby certify on this {). y<f!!i. day of February, 2004 a copy of Proof of Service for Complaint: in Divorce was sent VIA U.S. Mail to: Larry W. Sorensen Highland Gardens 423 South 18t[, Street Camp Hill, PA 17011 Respectfully submitted, r&k~ Catherine A. Boyle, Es MEYERS, DESFOR, SALTZG & BOYLE Attorney I.D. #76328 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717) 236-9428 Attorney for Plaintiff I MEYERS, DESFOR, SALTZGIVER ~( BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 23Ei-2817 -0 [2-1 2: 7' U? -... ~ ...J-."- ;z:, )> (..~ ~ c::~ c,~ ~ C) -on -I": r-; C;) r....,' C/', :C-:-. :-11 i-c'-~ -n III :"C,l..jJ (~:~ ~.~) _.,-, .. -1'-'l \ (~'j ,(-oj -;J f".) o STEPHANIE V. SORENSEN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, No. 04-680 Civil Teml LARRY W, SORENSEN, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Susan M. Kadel, Esquire, on behalf of the Defendant, Larry W. Sorensen, in the above-captioned action. Date: 4-~ ~ ~()(} '/ By:-, 4-/l /Cd./ L Susan M. Kadel, Esquire James, Smith, Dietterick & Connelly, LLP Post Office Box 650 Hershey, P A 17033 (717) 533-3280 PALD. No. 44837 (') ,-' ~~0 (;:: \ -~ "" c: );:,- ~::':>_:: ;J~c ?:; -< ....., = = .r- :x ;po = I ..- o 'T1 -t ffi-n .. -om 96 -J!.' L"):D 20 Om ,;;:;-i ,.> :.:J -< v ~ -'''" ~ en STEPHANIE V. SORENSEN, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. No. 04-680 Civil Term LARRY W. SORENSEN, Defendant. CIVIL ACTION - LAW IN DIVORCE MOTION TO COMPEL DISCOVERY PURSUANT TO Pa. R.C.P. 4019 AND NOW, comes Stephanie V. Sorenson, Plaintitfin the above captioned-action, by and through her attorneys, Meyers, Desfor, Saltzgiver & Boyle, and files this Motion to Compel Discovery Pursuant to Pa. R.C.P. 4019 and in support thereof, avers as follows: 1. Movant is Stephanie V. Sorensen, Plaintiff in the above-captioned action (hereinafter "Wife"). 2. Respondent is Larry W, Sorensen, Defendant in the above-captioned action (hereinafter "Husband"). 3. Wife filed the instant Complaint in Divorce on February 17, 2004, 4. Thereafter, on February 19, 2004, Wife served Husband with a Request for Production of Documents, pursuant to Pa, R.C.P. 4009.11. A copy of Wife's Request is attached hereto as Exhibit A. 5: Also on February 19, 2004, Wife served Husband with Interrogatories, pursuant to Pa. R.C.P, 4005. A copy of Wife's Interrogatories to Husband is attached hereto as Exhibit B. 6. More than thirty (30) days have passed since service of said Request and Interrogatories. Husband has not responded to Wife's Request for Production of MEYERS, DESFOR, SALTZGIVER & nOYLE 410 NORTH SECOND STREET. P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX {717\ ?~l':_':IH7 Documents, has not provided any documents to Wife and has not made any documents available for inspection, nor has Husband provided any response to the Interrogatories. 7. Wife's counsel forwarded correspondence to Husband's counsel on two occasions requesting that Husband respond to the discovery requests. Copies of those letters are attached hereto as Exhibit C and Exhibit D. 8. Pursuant to Pa. R.C.P 4019(c)(5), this Court has the ability to make such order with regard to the failure to make discovery, as is just. 9. Wife has incurred counsel fees related to the filing of this Motion, occasioned by Husband's failure to comply with the Rules of Civil Procedure. MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 236-:~817 WHEREFORE, Petitioner requests this Honorable Court the enter an Order directing Respondent to respond to the Interrogatories served on February 19, 2004, to provide or make available for inspection ail documents requested in the Request for Production of Documents served on February 19,2004 within 15 days and to pay Petitioner's counsel fees related to the filing of this Motion. Respectfully submitted Laurie . S Attorney LD. # 1382 Meyers, Desfor, altzgiver & Boyle 410 North Second Street P.O, Box 1062 Harrisburg, PA 17108 (717) 236-9428 Attorney for Petitioner MEYERS, DESFOR, SALTZGIVEA l!, BOYLE 410 NORTH SECOND STREET . P,O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 23f;-2817 Stephanie v. Sorensen, Plaintiff: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Ii I Larry W, Sorensen, I Defendant i I I I II vs. NO. 04-680 Civil Term CIVIL ACTION - LAW IN DIVORCE REOUEST FOR PRODUCTION OF DOCUMENTS TO: Larry W. Sorensen Highland Gardens 423 South 18'" Street Camp Hill, Pennsylvania I I Plaintiff by his undersigned counsel, hereby propounds the I following request for production of documents and tangible thingsl pursuant to Rule 4009.1 et seq. of the Pennsylvania Rules of I I Instructions and Definitions Civil Procedure. The documents and tangible things requested herein must be produced at the law offices of Meyers, Desfor, Saltzgiver & Boyle, 410 North Second Street, Harrisburg, Pennsylvania within thirty days. Each of the following requests is intended as a separate request. Where a request has subparts, please respond to each subpart separately and in full. Do not limit any response to thel numbered request as a whole. I I j objection fully and set forth the factual basis for your If you have any objection to any request, please state your objection in lieu of production of the documents. BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236.9428 . FAX (717\ 231~.?R17 You must file tf:A" 1 I i I I II and serve a written response to these requests within thirty days Ii II II I I j I I I of service of these requests Upon you, regardless of the time set for production of the documents and things requested herein. Youl day! I I I are reminded that any objections not raised within the thirty period provided for by Pa.R.C.p, 4009.12 will be deemed to have been waived by you. These requests are not only for documents and tangible things that are owned by you, but also for documents and tangible things that are in your possession, custody, or control. This means that you must produce all documents and tangible things that are responsive to a particular request and that are in your possession (regardless of whether they are your property), or over which you have control even if they are not in your possession. It also means you must produce documents and tangible things that are in the possession, custody, or control of your agents, employees, and/or attDrneys. I Before responding to these requests you are required to makej a diligent search of your files and records to ascertain whether you have documents that would be responsive to a given request. Your agents, employees, and attorneys must do the same. To avoid any possibility of confusion with respect to these I requests, please note that the following terms have the following III meanings in these requests, unless a particular request clearly indicates otherwise: 2 MEYERS, DESFOR, SALTZGIVER lit BOYLE 410 NORTH SECOND STREET. P.O. BOX 1062 . HARRISBURG, PA 17108 (717\ 236-9428 . FAX (717\ ?':lj~_'HI"'" i I I I .1 ,. !i have been addressed. :1 II II I Ii II 'I II II I I 1 I I 1TYoul1 or tlyourfl refer to the person to whom these requests "Person" means any natural person, corporation, unincorporated association, trust, partnership, and/or any other legally cognizable entity. It is contemplated that any corporation or other business entity acts only through its agents, officers, employees, and attorneys, and requests that apply to any such legal entity should be construed accordingly. "Plaintiff" means the plaintiff or plaintiffs named in this action. "Defendant" means the particular defendant or defendants in this action to whom this request is addressed, as set forth above. "Document II , "record", Irfile", and II report II all refer to and contemplate all written, recorded, or graphic information, whether preserved in writing, on magnetic tape, by electronic means, in photographic form, on microfilm or microfiche, computer disc, or by any other means of information retrieval or storage. "Identify" when used to referencE= to an individual means: (I) To state his/her fuLL name. (ii) Present residence or last known residence. Ii ,I Ii ! I: 3 MEYERS, OESFOR, SALlZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 .. HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 236-2817 The request lS as follows: 1. A copy of your most current pays tub showing a year to I II date figure, or copies of your pays tubs for the past twelve I months. I I 2. Copies of any and all documentation of income from any I I source received by you and/or anticipated by you for the year 2004, 3. Copies of all signed local, state, and federal tax returns for the last five years, including W-2 statements, K-1's, 1099's, RK-1's and any and all other attachments. 4. Copies of your signed local, state, and federal 2003 tax return, including all attachments, if complete. If not complete'l copies of any and all documentation necessary to complete your I I local, state and federal 2003 tax returns, including but not limited to your W-2 statement, K-1's, 1099's, RK-l's, and any other documents, attachments, and/or statements. 5, Copies of any personal financial statements prepared by you or for you for any reason, for the last five years. 6. Copies of all itemized monthly statements, including account number, of all checking accounts (both joint and individual), savings accounts, brokerage or security accounts, orl any other account held in any financial institution by you or for II your benefit or that you hold for the benefit of another or over which you have signatory power, for the time period January 1, , I " Ii Ii " 4 MEYERS, DESFOR. SALTZGIVEFt & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717\ 236.2817 I 2003 to the present. II II " II Ii , I , I I I I 7. Copies of all check registers, including account number, for all checking accounts held by you (either jointly or i i I the' I individually) or for your benefit, or that you hold for the benefit of another, or that you have signatory power over for time period January 1, 2003 to the p:~esent. 8. Copies of any and all month:cy itemized credit card account statements of any credit cards held for you or for your benefit or that you have use of or control over, or hold for the benefit of another, for the time perioq January 1, 2003 to the present, 9. Copies of all Certificates of Deposit from any banking or other financial institutions which are held in your name individually or jointly with another, or which is held for your benefit from January 1, 2003 to the present. I accounts, pension accounts, 401 (k) plans, profit sharing plans, i' 'I 10. Copies of all monthly statements for any retirement IRA'S, deferred compensation accounts, or other retirement vehicle from January 1, 2003 to the present. 11. Proof of beneficiary on any retirement accounts, I pension accounts, 401 (k) plans, profit: sharing plans, IRA's, I deferred compensation accounts or other retirement vehicle. II 12. Copies of documentation of any loans made by you to II another person or entity, including but not limited to when the II , , i I 5 , 1 MEYERS, DESFOR. SALTZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 .. HARRISBURG, PA 17108 (717) 236.9428 . FAX (717\ 236-2817 i i 1 I II I I ! [loan was given, i 1 I, II II I; I' I: il II II I' Ii I II II II I I I I the source of the funds, use of such funds, repayment schedule, and interest rate charged, for the time period January 1, 2003 to the present, 13 . Copies of documentation of any loans received by you from another person or entity, including but not limited to when the loan was given, the source of the funds, use of such funds, repayment schedule, and interest ratE, charged, for the time period January 1, 2003 to the present. 14. An itemization and accounting of any and all items you with any money transferred, redeemed or,receivedl purchased by from the use of marital assets or from the proceeds thereof, including identification of items purchased, costs and date of purchases and copies of all purchase documents. 15. Copies of all life insurance policies on which you are the owner, insured or beneficiary for the last five years, I including proof of beneficiary, face sheet and/or proof of cash I value. i' 16. Copies of any and all savine,s bonds or treasury bonds I which are presently held in your name or in your possession or which are held for your benefit. I II I you may have as a result of your employment, including but not I I I , I I I' i! Ii II !I " Ii " I: I' 17. Documentation of any benefits and/or perquisites which limited to amounts paid on your behalf, type of benefit and/or perquisite, daters) paid, etc. 6 MEYERS, DES FOR, SALTZGlVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 .. HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 236.2817 Ii Ii 'I Ii If I I fair market value and/or tax assessments of any marital real I II il I[ I I II Ij I , 18. If you have obtained any appraisals and/or estimate of estate or any other real estate in which you have any interest whatsoever, within the past five years, please supply a copy of same. 19. Copy of your current employment contract. 20. If you are alleging any physical or mental disability or impairment pursuant to this litigation, please provide a copy of any physician's or other medical practitioner's report or statement that has been given to you or prepared on your behalf in the past three years. Additionally, please supply copies of any medical records for any medical treatment or services which you have received due to any alleged disability or impairment over the past three years. 21. Copies of all signed local, state and federal tax returns, including any attachments, for the last five years for Highland Gardens and any other businesses in which you own an interest. 22. Copies of the 2003 tax return, including attachments, if complete, or any and all documentation necessary to complete the 2003 local, state and federal tax returns for Highland Gardens and any other businesses in which you own an interest. 23. Copies of any and all financial statements, internal 0 I II otherwise, audited or not, for the last five years, for Highland 7 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 2:16-2817 Gardens and any other businesses in which you own an interest. 24. Copies of the general ledger, for the time period January 1, 2003 to the present, from Highland Gardens and any other businesses in which you own an interest. 25. Copies of any and all account statements for any and all accounts owned and/or maintained by Highland Gardens and any other businesses in which you own an interest, for the time period January 1, 2003 to the present. 26. Copies of any and all balance sheets and profit/loss statements for the last five years for Highland Gardens and any other businesses in which you own an interest. 27. Copies of any shareholder's: agreements, stock option agreements, buy/sell agreements, and/or other agreements between you and Highland Gardens and/or you and any other businesses in which you own an interest, 28. Copies of any Articles of Incorporation and any amendments thereto for Highland Gardens and any other businesses In which you own an interest. 29. Documentation of any share transfers for Highland Gardens and any other business in which you own an interest. 30. Copies of all stock certificates for Highland Gardens and any other business in which you own an interest. 31. Copies of any and all minutes from any shareholder meetings, Board of Directors' meetings and any special and/or I Ii Ii II Ii 8 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG. PA 17108 (717) 236.9428 . FAX (717) 236-2817 Ii I I I ,I 1 other meetings held from January 1, 2003 to the present, for , i Highland Gardens and any other businesses in which you own and I II interest. II " I I II I I I i 32. Copies of any partnership agreements, and any amendments thereto, buy/sell agreement and/or any other agreements between you and Highland Gardens and any business in which you own an interest. 33. Copies of any and all appraisals from the last five years for any real estate in which Highland Gardens and/or any other of your businesses own an interest. 34. Copies of any and all leases for any real estate in which Highland Gardens and/or any other of your businesses own I ani I I interest, for the time period from January 1, 2002 to the present. 35. Copies of any and all leases to which Highland Gardens, or any other business in which you own and interest, is a party, for the time period January 1, 2003 to the present. 36. Copies of any and all mortgage statements for any real estate in which Highland Gardens and/or any other of your businesses own an interest, for the time period January 1, 2003 to the present. 37. Copies of the most recent tax assessments for any real I estate in which Highland Gardens and/or any other of your , II II , I , businesses own an interest. 9 MEYERS, DESFOR, SALTZGIVER ~k BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 23€i-2817 I j j I I II I, 1 last five years for any real estate in which Highland Gardens I II I! I II II II II Ii II I 38. Documentation of any major improvements made in the and/or any other of your businesses owns an interest. I I I I , ofl 39. Copies of any and all loan applications or other applications for any type of financing submitted by you or any your businesses to any financial institution in the last five years. 40, Copies of any and all exhibits you intend to offer at I trail, , I i I I I 41. Copies of your monthly itemized cellular telephone bills for the time period January 1, 2003 to the present. If you fail to produce the documents or things required by this Request for Production of Documents, you may be subject to the sanctions authorized by Rule 4019 of the Pennsylvania Rules of Civil Procedure. I 1 II I I, I ! MEYERS, DESFOR, SALTZGIVER & BOYLE /) r, /) By 1;/ U{l-~ U /V C~', Boyle, ES Attorney ID No. 76328 /( RE ]0 Ii I: , I,: MEYERS, DESFOR, SAlTZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 {717} 236-9428 . FAX (717) 2~16.2817 Stephanie V. Sorensen, Plaintiff: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04-680 Civil Term Larry W. Sorensen, Defendant CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I hereby certify on this l~~ day of February, 2004, that the foregoing Request for Production of Documents was sent certified mail and regular U.S. Mail, first-class, postage pre- paid to: Larry W. Sorensen Highland Gardens 423 South 18'" Street Camp Hill, Pennsylvania, J2J~., Catherine A. Boyle, Es Attorney for Plaintiff MEYERS, DESFOR, SALTZGIVER l~ BOYLE 410 NORTH SECOND STREET. P.O. BOX 1062 . HARRISBURG. PA 17108 (717) 236-9428 . Ft,X (717\ ?~!;_'~17 Stephanie V. Sorensen, Plaintiff: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04-680 Civil Term Larry W. Sorensen, Defendant CIVIL ACTION - LAW IN DIVORCE INTERROGATORIES TO: Larry W. Sorensen Highland Gardens 423 South 18u, Street Camp Hill, Pennsylvania PURSUANT TO THE PROVISIONS of Pa. R,C.P, 4005 and 4006, as amended, you are required to file the original, and serve a copy on the undersigned, of your Answers and Objections, if any, in writing and under oath, to the following Interrogatories, within thirty (30) days after service of the Interrogatories. The Answers shall be inserted in the spaces provided following each Interrogatory. If there is insufficient space to answer an Interrogatory, the remainder of the Answer shall follow on a supplemental sheet, These Interrogatories shall be deemed to be continuing in nature, in accordance with the provisions of Pa. R.C.P. 4007.4 as amended. If between the time of filing yoc:r original Answers to these Interrogatories, and the time of trial of this matter, you or anyone acting in your behalf learn the identity and location of additional persons having knowledge of discoverable facts and the identity of persons expected to be called as an expert witness at trial not disclosed in your Answers, or if you or an expert witness obtain information upon the basis of which you or he knows that an Answer was incorrect when made, or knows that an Answer though correct when made is no lonc:rer true, then you shall promptly supplement your original Answers under oath to include such information thereafter acquired, and promptly furnish such a Supplemental Answer on the undersigned. Respectfully submitted, Dated: ci?/;~doCf /x~> /~'~ UMv~lc " ~ Catherine A. Boyle, Es MEYERS, DESFOR, SALTZG & BOYLE Attorney I.D. #76328 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717) 236-9428 Attorney for Plaintiff / ,I .~ 1. State your name, home address, business address, social security number and the name of any person who has resided with you in the past six months. 3 2. Please indicate and itemize your yearly income from any source whatsoever, including wages, Ealaries, dividends and director's fees, as well as return on investment income or business investments, 4 3. As to any real estate in which you now or have had an interest in at any time during the last five years, whether in the United States or any other country, whether individually, jointly, in partnership form, in corporate form, as trustee for any person, as beneficiary under any trust or held by anyone for your beneficial interest, complete one of the information sheets attached hereto. (Note: use one form "A" for each Real Estate Interest,) 5 REAL ESTATE INFORMATION FORM "A" (INTERROGATORY NO. :>) (NOTE: Complete one Form "A" for each Rea:. Estate interest.) a. Address of property: b. Type of property: e.g., condo, single family residence, unimproved lot, commercial, etc,) c. Nature of your interest: d. Date of acquisition: e. Method of acquisition (purchase, inherited, gift) 6 f. Name(s) in which title recorded: g. Purchase price or value at acquisition: 1. Amount of down payment contributed by you: 2. Amount of down payment contributed by others; name these others: 3. Source of funds for purchase: h. Your best estimate of: 1. Present market value: 2. Market value at time of separation: 3. If owned prior to marriage, market value at time of marriage: 7 I, Present assessment for tax purposes; setting forth assessments for land and improvements separately: j. Name and address of any co-owners and extent and nature of their interest; k. Cost of maintenance of the residence, including, but not limited to repairs, utilities, mortgage, taxes and any other expenses; itemizing each item specifically: 8 1. If presently owned, list all improvements made to property since date of acquisition; giving date of improvement that was made, nature of improvement and costs thereof: m. As to any mortgage, encumbrance or lien of any nature, provide: 1. identity of mortgagee or holder of encumbrance: 2. identity of any co-mortgagors: 3. amount of original mortgage or encumbrance: 4. amount of present outstanding mortgage: 5. original term of mortgage: 6. remaining term of mortgage: 7. monthly payments: 9 n. Attach any appraisal of the property that has been made within the last three years. o. Attach a copy of settlement sheets for all purchases and sales. p. If the property or your interest therein has been sold or or otherwise transferred within the past three years, state: 1. date of sale or transfer: 2. identity of transferee(s) 3. consideration paid for transfer: 4. terms of sale or transfer: 5. whether any portion of the sale price is still due by way of note, bond or mortgage and, if so, state terms and amount due: 10 6. the disposition of the proceeds: q. If any real estate produces rental income or other income, as to each of the last three years, set forth: 1. address of property: 2. name and address of each person from whom rent or other income was received: 3. amount received from each person in each year: 4. portion of premises rented to each person: 5. itemization of all expenses of maintaining that real estate in each year: 11 4. If, within the last five years you have obtained rental income, state: a. location or identification of the rental property; b. name and address of each person from whom rental income was received; c. terms of any lease agreements with respect to each source of rental income; d. the amount of monthly rental income; and, e. how the property is titled. 12 5. Please list any and all life insurance policies on which you are the owner, insured, or beneficiary for the past three years. For each policy, state: a. the name of the policy and the folicy number; b. the face amount of the policy, c. the cash value of the policy; d. amount of any loan against said policy; e, the named beneficiaries of said policy; f, the annual premium payment for said policy, and name the payor; and g. identity of owner, insured, and beneficiary and any relationship to you. 13 6. Are you a member of any partnership or have you acquired any partnership interest within the past five years or has any partnership in which you were previously involved, dissolved, or disbanded within the past seven years? For each partnership, indicate: a. partnership name and location of business office; b. nature of the partnership's business; c. whether it is a general or limited partnership; d. state your percentage ownership interest; e. names and addresses of all other partners; f. name and address of the accountant for the partnership; g. state the date you acquired your initial interest, the cost and the percentage ownership and state the date, cost and percentage of any subsequent acquisitions; h. if you have sold within the past five years, or gifted or otherwise disposed of all or part of your interest, state the dates, percentage of interest involved and the terms of sale or other disposition; i. attach a copy of the current partnership agreement and any other agreements between you and the partnership or between you and the other partners (including but not limited to, employment agreements, buy/sell agreements); and J. If the partnership has dissolved, please state the reasons for dissolution and the proceeds or liabilities you received therefrom. 14 7. If you have at present, or if you have had within the last five years, an account with any security dealer or broker, state: a. the name of broker or dealer; b. business location. 15 8. Do you have an interest or holdings in any corporations of 5% or more or are you an officer in any corporations or have you been within the past five years cr has any corporation in which you have had such an interest dissolved or become defunct within the past five years? If so, for each corporation state: a. corporate name and location of business office; b. the nature of the corporation's business; c. your position with or interest in the corporation; d. the name and address of the chief financial officer of the corporation and the accountant of the corporation; e. the total number of outstanding shares owned by you at the present and the class of stock involved; f. the percentage of the total outstanding shares as owned by you at present; g. the date you acquired your initial interest, the cost and the number of shares acquired (if more than one acquisition date, set forth each acquisition date after the initial acquisition and number and cost of shares acquired) ; h. if, within the past three years you have sold, gifted, or otherwise disposed of all or part of your interest, state the dates, number of shares involved, and the terms of sale or other disposition; i. the names and addresses of the cther shareholders, the officers and the board of directors, indicating the number of shares held by each and his or her position with the corporation (note: if any of these persons are related to you, please so indicate and identify the relation) ; j. set forth details (including dates and amounts) of any loans by you to the corporation or any loans by the corporation to you or any redemptions, dividends or return of capital within the past three years; k, attach copies of any written agreements enforced 16 between you and the corporation, or between you and the other shareholders (including but not limited to, employment agreements, buy/sell agreements, stock option agreements) ; 1. list the date and amount of any capital contribution made by you to the corporation within the past three years; m. state the fiscal year utilized by the corporation for tax recording purposes; and n. if the corporation has become defunct, please state the reasons for its dissolution and any proceeds or liabilities which have been attributed to you therefrom. 17 9. Identify any automobile, truck, camper, mobile home, motorcycle, boat, airplane or vehicle of any nature that you own or any business owns for your benefit or that you have an interest therein and set forth (use supplemental sheets, if necessary) : a. make, model and year; b. date acquired; c. purchase price or value at acquisition; d. your opinion as to current fair market value; e. how title is held; f. name and address of any co-owners or interest holders; g, date and initial amount of any liens, present balance of any liens or encumbrances thereon, including identity of the lien holder; and h. attach copies of any appraisals. 18 10. Please list any and all checking accounts, savings accounts or brokerage accounts held by you, either in your name alone, jointly with another person, or which you have signature power over, or which are held for your benefit for the past five years. For each such account, state: a. the name of the institution where held; b. the account number; c. initial deposit and date account was opened; d. current balance in the account; and e. titled owners of said account. 19 11. Please list any and all pensions, retirement accounts, profit sharing accounts, 401K plans, IRA's or any other retirement vehicle which is held by you, or for your benefit, or which is held in your name individually or jointly with another person within the past five years. For each such retirement vehicle, please state the institution where held, the current balance therein and the value to you upon reaching retirement age. 20 12. List any and all witnesses, includin~ address and telephone numbers, whom you plan to call at a ~Iaster's hearing on equitable distribution and state what they will testify to. Please list all witnesses, whether expert or non-expert. 21 13. Do you anticipate receipt of any devise, bequest, gift or inheritance? If so, set forth: a. when receipt is anticipated; b. amount to be received; c. from whom the receipt is anticipated; and d, attach any documents in support of such bequest, devise, gift or inheritance. 22 14. List all trusts for which you are either the beneficiary, remainderman, settlor or grantor, and set forth: a. name of trust; b. location where trust corpus lS held; c. the nature of the trust corpus, including its value; and d. attach a copy of the trust instrument. 23 , , 15. State the extent, type and location of all books, papers, records, journals or other documents in your possession or control which would reflect your income or assets. Attach a copy of each such document, 24 , , , , , 16. State whether there is any money owin'j to you whether by an individual, partnership, or corporation, including but not limited to, judgments, notes, contract rights, loans, assignments, etc. and set forth: a. nature and amount of each obligation and date incurred, b. name and address of each debtor; c. conditions of payment; d. consideration given; e. collateral or security for obligations; f, current balance due; and g. any writing indicating proof of debt or obligation and attach. 25 . . . . , 17. Have any stocks, bonds, mutual funds or other investment vehicles been owned by you either jointly or individually or held for your benefit within the past five years? (Stock shall mean stock of any publicly traded commodity or corporation in which you own less than 5%). If so, please list and state: a. the face value; b. current value; c. date acquired; and d. value on date acquired. 26 , . ,. , 18. Set forth, in detail, any obligations which you owe to another individual or entity, whether individual or joint or joint and several, including, but not limited to, mortgages, conditional sales, security agreements, contract obligations, financing statements, promissory or judgment notes, including: a. names and address of each creditor; b. form of each obligation and date incurred; c. consideration received for the obligation; d. amount of original obligation; e. rate of interest; f, description of any security given; g. present unpaid balance of the obligation; and h. any security or collateral pledged. 27 " , 19. Do you have any other businesses or business interests not referred to previously in these interrogatories? (Business interest includes any venture which is pursued either individually or jointly with another individual or entity) Please list each business interest and indicated the value, as well as the yearly income therefrom. 28 " . 20, Set forth all gifts and inheritances received, either in money or some other form, from the date of your marriage until the present, providing: a. date received; b. item received and value at time received; c. value at time of separation; d. name and address of person, firm or corporation from which received; e. reasons or basis for receipt; f. if sold, date of sale; g. consideration received; and h. disposition of the proceeds. 29 ., . 21. Complete Form "8" attached hereto for any and all bond, stock and other securities, mutual funds, and money market funds in which you now have, or have held in the past three years, have had any interest whatsoever, whether individual, joint, or as custody or trustee for others or as beneficiary of an account held by another as custodian or trustee. (Include securities even if interest or dividends thereon are exempt from taxation.) (Note: use one Form "8" for each such interest.) Enter here the number of Form "B"'s attached. 30 Identity of Security or Issuer " , SECURITIES INFORMATION SHEET: Number of Shares or Principal Amount of Bonds FORM "B" (INTERROGATORY NO, 21) How Title Held and Name(s) of All Others in Title Date of Cost Purchase 31 . .! I Present Value Date of Sale ., . 22. Check which of the following have produced income or loss for you at any time during the past five years: Dividends Interest (including interest on tax exempt securities) Partnership in which you are a partner Pensions or annuities Consulting fees Director's fees Advisor's fees Profit on sale of assets (reported on Schedule "D" of your Federal Income Tax Return) Business income (reported on Schedule "C" of your Federal Income Tax Return) Alimony Unemployment Compensation Disability income payments Buy-out or pay-out from a business or professional group, association, partnership or corporation. Other, please specify. 32 23. State whether you are responsible for or the holder of any lines of credit, either individually or as a business partner or shareholder in any corporation or business. If so, for each such line of credit state: a. the bank through who said line of credit is issued; b. the total amount available on said line of credit; c. the total amount of credit currently being used on said line of credit; d. when line was opened; e. use of funds; f. repayment terms; and g. when loans from said line were taken. 33 " . , . 24. Do you claim to be personally responsible for any notes or personal loans loaned to you by another individual? If so, please: a. indicate that amount of said note; b, attach a copy of said note; and c. attach a copy of any check or other document indicating transfer sums to the defendant. 34 " , , . Stephanie V. Sorensen, Plaintiff: IN THE COURT OF COMMON PLEAS CUMBER~D COUNTY, PENNSYLVANIA vs. NO. 04-680 Civil Term Larry W. Sorensen, Defendant CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that on this I~lh day of February, 2004, the original and two (2) copies of the attached Interrogatories were sent certified mail and regular U.S. mail, postage prepaid, to: Larry W. Sorensen Highland Gardens 423 South 18'" Street Camp Hill, Pennsylvania 17011 ~/ Catherine A. Boyle, Es Attorney for Plaintiff 35 MEYERS, DESFOR, SALTZGIVEFI & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) ~~36-2817 . . . ~, , LAW OFFICES MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET P.O. BOX IOEie I. EMANUEL. MEYERS (1515-1970) BRUCE D. DES FOR LAURIE A. SALTZGIVER CATHERINE A. BOYLE HARRISBURG, PA. 17108 (717) 236-9428 FAX {7171 236-2817 WE8SlTE WWoN'.meyersdestor.com EMAIL lsattzgiverOmeyersdesfor.com cboyleCmeyersdesfor.com May 21,2004 FAX & MAll. Susan Kadel, Esquire JM1ES, SMITH DIETTERICK & CONNELLY, LLP P,O, Box 650 Hershey, PA 17033 RE: Sorensn v, Sorensen Dear Susan: I contacted you almost a month ago with an offer to settle this matter and have yet to hear from you regarding same. At this time, unless I hear from you otherwise. I will assume the offer has been rejected Accordingly, we are requesting that your client respond to our discovery request within the next thirty days, Thank you for your attention to this matter. Very truly yours. CAB/vjh cc: Stephanie Sorensen ( Boyle j) I' , .' LAW OFFICES MEYERS, DESFOR, SALTZGIYER & BOYLE 410 NORTH SECOND STRE.ET P.O. BOX 1062 I. EMANUE.LMEYERS(19IS-19701 BRUCE D. DESF'QR LAURIE A. SALTZGIVER CATHERINE. A. BOYLE HARRISBURG, PA. 17108 (717) 236-9428 September 23, 2004 FAX (7171236-2817 WE8SITE. YM'W.meyersdesfor.com EMAlllsaltzgiverOmeyersdestOl'.com cboyleOmeyersdesfor.com VIA FAX & MAIL Susan Kadel, Esquire JAMES, SMITH DIETTERICK & CONNELLY, LLP P.O. Box 650 Hershey, P A 17033 RE: Sorensn v. Sorensen Dear Susan: My office served Interrogatories as well as a Request for Production of Documents on your client, Mr. Sorensen, on February 19,2004. We have not received your client's answers to this discovery, to date. My partner, Catherine Boyle, forwarded correspondence to you on May 21, 2004, requesting that your client respond to the discovery request within thirty days. We still have not received your client's response to our discovery, Please be advised that if! do not receive your client's response to the Interrogatories as well as the Request for Production of Documents within fifteen days from today's date, that I intend to file a Motion to Compel with the Court, request counsel fees. and proceed accordingly. Thank you for your attention. Sincerely. LAS/vjh ce: Stephanie Sorensen . ... 1 ~ ... . I I I I I , II II 'I 1. II II II I, I II I Iii" d , to Pa. R.C.P. 4019 are true and correct to the bes I II' of my knowledge, information and belief. I understand that false I I 'I II I Ii I !I I jl I i. I Ii I Ii ' I' :1 I! i: 1'1 Dated: II I' ,! II VERIFICATION , verify that the statements made in this Motion toC'Oompel Discovery Pursuant statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. ItJ- jt(- ~ LJtJ SI ~~2Z~~ - ( X) Plaintiff Defendant MEYERS, DESFOR, SALTZGIVI:R & BOYLE 410 NORTH SECOND STREET . P.O_ BOX 1062 . HARRISBURG, PA 17108 (717) 236.9428 . FAX (717'1 236-2817 . ... . . .... . STEPHANIE V. SORENSEN, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 04-680 Civil Term LARRY W. SORENSEN, Defendant. CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I hereby certify on this -\S- ~ay of CJ .J3~ , 2004, that the foregoing Motion to Compel Discovery Pursuant to Pa. R.C.P. 4019 was sent via fax and first-class mail, postage prepaid, to: Susan Kadel, Esq. James, Smith, Dietterick & Connelly, LLP P,O. Box 650 Hershey, P A 17003 \ \ MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 236-2817 . . . ~ . n ,......... 0 - .~ (-:-J , U:" -" (..> ; c.) STEPHANIE V. SORENSEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYVLANIA v. CIVIL ACTION - LAW LARRY W. SORENSEN, Defendant NO. 04-680 CIVIL TERM ORDER OF COURT AND NOW, this 25th day of October, 2004, upon consideration of Plaintiff's Motion To Compel Discovery Pursuant to Pa. R.C.P. 4019, a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. BY THE COURT, ~ie A. Saltzgiver, Esq. 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 Attorney for Plaintiff ~san Kadel, Esq. James, Smith, Dietterick & Connell, LLP P.O. Box 650 Hershey, P A 17003 Attorney for Defendant > ~ ~ /0 .~7-0" :rc \r:/Vtf/l1\SNN::?d t : ~",--..-,"I r'" ',' "-, '~"'-" ......0 IWV1 !lI , ":'(1 '....!~"'''I\/I'' .... '-., -.' ,~. "-'.+. I LZ :2 I<Id a 1JO 7M2 1>.1'""-"'''' ',c'''J ~'_I'1 '0 !\\"/,.'lL'i'iU'-1i...UC jil. ::1- ]O/:i:iQ-'G37/j Stephanie V. Sorensen, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04-680 Civil Term Larry W. Sorensen, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 17,2004, The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S. S 4904 relating to unsworn falsification to authorities. Date: /;2 - 1'3 - /J.I=) . -~~/~ ~h~ Step nie V. Sorensen I i I L_ MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 236-2817 ~ ~. c.:-o Stephanie V. Sorensen, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04-680 Civil Term Larry W. Sorensen, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &330HC) OF THE DIVORCE CODE 1, 1 consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of l8 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Date /2 -/.3 -~5 P---~L~2U'~ ~L"'(l/~ ~, Sorensen MEYERS, DESFOR, SAlTZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 236-2817 ',\ " (.-' . . STEPHANIE V, SORENSEN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No, 04-680 Civil Tenn LARRYW. SORENSEN, Defendant CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT ]. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February] 7,2004, 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of both the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of Notice of Intention to request entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim thern before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verifY that the statements made above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. S4904, relating to unsworn falsification to authorities. Date: /-/8-06 W. Sorensen, Defendant c . " . MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT made this ~ day ofPe.c.Q.Mhef' , 2005 by and between Stephanie V. Sorensen (hereinafter referred to as "Wife") of 405 Third Street, New Cumberland, Pennsylvania and Larry W. Sorensen (hereinafter referred to as "Husband") with a mailing address of c/o Highland Gardens, 423 South 18th Street, Camp Hill, Pennsylvania. WITNESSETH: WHEREAS, Husband and Wife were lawfully married on October 15, 1977 in Dauphin County, Pennsylvania; and WHEREAS, one child has been conceived of this marriage; namely, Whitney Leigh Sorensen, born on August 26, 1985 and: WHEREAS, diverse differences and difficulties have arisen between the parties respecting their interests, rights and title in and to certain property, real and/or personal, owned by or in possession of the said parties to either of them; and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations and to amicably adjust, compromise and forever settle all property rights and all " II .) , rights in, to or against each other's property or estate of any kind or nature whatsoever, including property heretofore or subsequently acquired by either party and to settle all disputes existing between them, including any and all claims for Wife's and/or Husband's rights to equitable distribution, maintenance and/or support, alimony, alimony pendente lite, counsel fees and costs; and WHEREAS, the parties acknowledge and agree that in entering into this Agreement, including foregoing waivers, they are each relying on truth and completeness in all material respects as to all information provided by the other party hereto regarding the assets of such person. NOW THEREFORE, in consideration of the mutual promises, covenants and agreements hereinafter contained, each of the parties hereto intending to be legally bound hereby promises, covenants and agrees as follows: 1. DIVORCE: The parties agree that their marriage is irretrievably broken and that they mutually consent to a divorce and agree and have executed all necessary Affidavits of Consent and Waivers of Notice forms required by the court for the entry of a mutual consent divorce. Both Husband and Wife have directed their respective counsel to immediately file with the Court said Affidavits and Waivers and file the appropriate documents to request a Decree in Divorce from the bonds of matrimony under Section 3301(C) of the Divorce Code. 2 " 2. FULL FORCE AND EFFECT: This Agreement shall continue in full force and effect until such time of final Decree in Divorce is entered. 3. AGREEMENT TO CONTINUE IN EVENT OF DIVORCE: In the event that the marriage of the parties hereto is terminated by divorce, this Agreement shall nevertheless remain in full force and effect, and shall survive such decree and shall not in any way be affected thereby, except as provided for herein. 4. INTERFERENCE: Each party shall be free from interference, authority, and contact by the other, as fully as ifhe or she were single and unmarried except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 5. WIFE'S DEBTS: Wife represents and warrants to Husband that since the date the divorce was filed, to wit, February 17,2004 she has not and in the future she will not, contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save harmless Husband from any and all claims or demands made against him by reason of debts or obligations incurred by her. 3 " 6. HUSBAND'S DEBTS: Husband represents and warrants to W.ife that'since the divorce was filed, to wit, February 17,2004 he has not and in the future he will not, contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. 7. DISCOVERYIFINANCIAL DISCLOSURE: The parties agree and acknowledge that they have each had the opportunity to conduct discovery and investigation of the assets of both parties. Wife acknowledges that she had the opportunity to conduct discovery of Husband's assets. Wife acknowledges that she has issued various requests for information to Husband. Husband acknowledges that he had the opportunity to conduct discovery of Wife's assets. Husband acknowledges that he has issued various requests for information to Wife. The parties agree and acknowledge that they have made full and fair disclosure of all of their assets and income to the other party. The parties acknowledge that they have both been given the opportunity to conduct investigation into all assets, whether separate or marital, prior to entry into this agreement. Both Husband and Wife acknowledge they have had full and fair disclosure of all assets prior to execution of this agreement. Furthermore, the parties acknowledge that they have both had full disclosure as to both parties income and financial condition. 8. MUTUAL RELEASES: Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself and his or her 4 , " heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all causes of action, claims, rights, or demands, whatsoever in law or equity, which either of the parties ever had or now has against the other, except any or all causes of action for termination of the marriage by divorce or annulment and except any or all causes of action for breach of any provisions of this Agreement. Husband and Wife specifically release and waive any and all rights he or she might have to raise claims under the Divorce Code of 1980, as amended in 1988, including, but not limited to claims for equitable distribution of marital property, support, alimony, alimony pendente lite, counsel fees or expenses. The fact that a party brings an action to enforce the property agreement as incorporated in the divorce decree, under the Divorce Code of 1980, as amended in 1988, does not give either party the right to raise other claims under the Divorce Code, specifically waived and released by this paragraph and all rights and obligations of the parties arising out of the marriage shall be determined by this Agreement. 9. RELEASE OF TESTAMENTARY CLAIMS: Except as provided for in this Agreement, each of the parties hereto shall have the right to dispose of his or her property by Last Will and Testament or otherwise and each of them agree that the estate of the other, whether real, personal or mixed, shall be and belong to the person or persons who would become entitled thereto as if the decedent had been the last to die. This provision is intended to constitute a mutual waiver by the parties of any rights to take against each other's Last Wills under the present or future laws of any jurisdiction whatsoever and is 5 .. . intended t~ confer third-party beneficiary rights upon the othe~ heirs ~d beneficiaries of each. 10. AGREEMENT BINDING ON HEIRS: The parties acknowledge that except as provided for in this Agreement, each of the parties shall have the right to dispose of their respective property by Last Will and Testament, and that each party waives the right to take under the Will of the other. This Agreement shall be binding on the respective heirs, executors, administrators and assigns of the parties thereto. 11. ENTIRE AGREEMENT: This Agreement represents the entire agreement between the parties. There are no representations, promises, agreements, conditions, or warranties between the parties other than those set forth herein. 12. LEGAL ADVICENOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel. The Wife has employed and has had the benefit of counsel of Catherine A. Boyle, Esquire, as her attorney. The Husband has employed and has had the benefit of counsel of Susan M. Kadel, Esquire, as his attorney. Each party acknowledges that they have received independent legal advice from counsel and that each party fully understands the facts and have been fully informed of their legal rights and obligations, and each party acknowledges and accepts that this Agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received 6 such advi~e and with such knowledge, and that execution of this. Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. Also, each party hereto acknowledges that he or she has been fully advised by his or her respective attorney of the current Pennsylvania Divorce Law, and his or her rights thereunder, each party hereto still desires to execute this Agreement acknowledging that the terms and conditions set forth herein are fair, just, and equitable to each of the parties and waives their respective right to have the Court make any determination or order affecting the respective parties' right to a divorce, alimony, alimony pendente lite, equitable distribution of all marital property, counsel fees and costs and expenses. 13. DIVISION OF PERSONAL PROPERTY: The parties have divided between them, to their mutual satisfaction, the personal effects, household furniture and furnishings, and all other articles of personal property which have heretofore been used by them in common. Should it become necessary, the parties each agree to sign any titles or documents necessary to give effect to this paragraph. 14. EOUITABLE DISTRIBUTION: a. The parties shall divide the Morgan Stanley account #410-051455-006 with an approximate current value of $70,933.00, with Husband receiving $52,408.00 and wife receiving the remaining balance. 7 .' . b. The Parties shall divide equally the following assets: 1. Morgan Stanley account #410-051456-006 with an approximate value of $26,852.00. 11. American Funds account #58502210 with an approximate value of $60,405.67. lll. Putnam account #004179833 with an approximate value of$34,635.00. IV. All State Annuity #327571 with an approximate total value of $29,322.00; with approximately $14,633.00 being held in Husband's name alone and approximately $14,659.00 being held in Wife's name alone. c. Disposition of Real Property: The parties acknowledge that they jointly own the marital residence located at 405 Third Street, New Cumberland, Pennsylvania. There are no liens or other encumbrances against said property. The parties agree that said residence shall be transferred pursuant to the Trust Agreement executed by the parties on , 2005, and attached hereto as Exhibit "A." d. Pension Plans/IRAs: The parties acknowledge that the Wife presently has a Morgan Stanley IRA #410-018297which shall remain Wife's sole and exclusive property. The parties also acknowledge that Husband presently has an American Funds IRA #58506221 which shall remain Husband's sole and exclusive property. e. Business Interests: Husband shall keep as his sole and exclusive possession his business interest in Highland Stores, Inc. and any benefits and/or liabilities derived therefrom. f. Automobiles: Wife shall keep the 2004 Saab automobile as her sole and exclusive possession free of any claim or demand by Husband. Wife shall be solely responsible for any and all liens against said vehicle. Wife shall indemnify 8 . . . and save harmless Husband from any and all claims or demands made for said lien. Husband shall keep the Nissan X-Terra automobile as his sole and exclusive possession, free and clear of any and all claim or demand by Wife. Husband shall be solely responsible for any and all liens against said vehicle. Husband shall indemnify and save harmless Wife from any and all claims or demands made for said lien. 15. WAIVER OF RIGHT TO ALIMONY. ALIMONY PENDENTE LITE. COUNSEL FEES. COSTS AND EXPENSES: The parties hereby acknowledge that they each waive their right to request alimony, alimony pendente lite, counsel fees, costs and expenses from the other unless otherwise provided for in this Agreement. 16. 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 legal fees and costs incurred by the other. in enforcing their rights under this Agreement. 17. ADDITIONAL INSTRUMENTS: a. Each of the parties shall from time to time, at the request of the other, execute, acknowledge, and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. 9 . . . b. This Agreement shall be incorporated into a Divorce Decree but not merged therein. 18. MODIFICATION AND WAIVER: A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 19. DESCRIPTIVE HEADINGS: The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 20. VOID CLAUSES: If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects, this Agreement shall be valid and continue in full force, effect, and operation. 21. EXECUTION DATE: The execution date shall be defined as the date both parties have signed this Agreement. In the event that the parties do not sign this Agreement at the same time, the execution date shall be the date the last party has signed. 22. APPLICABLE LAW: This Agreement shall be construed pursuant to the laws of the Commonwealth of Pennsylvania. 10 . ..' ". ~" . . IN WITNESS WHEREOF, the parties have hereunto set their l;1ands and seals the day and year first above-written. _J~~ ~-h~? Steph e V. Sorensen 41'2/a.LL Susan M. Kadel, Esquire ~~ - ......-- L W. Sorensen ------ 11 -r' ," ~.J. l'-,..) r:-::) .'- ) c;;.~ o 'Tl :i! rn ;!1 ;r~ ~~".n -]J :~~1 ;~ um :~ ~ ..-0 -< -..... C0 > -,'" C') " (J1 C'. ~ AMENDMENT TO MARITAL SETTLEMENT AGREEMENT THIS AMENDMENT made this oZj"& day of /YJ Ct.j , 2006, by and between Stephanie V. Sorensen (hereinafter referred to as "Wife") of 405 Third Street, New Cumberland, Pennsylvania and Larry W. Sorensen (hereinafter referred to as "Husband") with a mailing address of c/o Highland Gardens, 423 South 18th Street, Camp Hill, Pennsylvania. WITNESSETH: WHEREAS, Husband and Wife entered into a Marital Settlement Agreement on December 14,2005; WHEREAS, the parties are desirous of amending Paragraph 14 (c) of their Marital Settlement Agreement. NOW THEREFORE, each of the parties hereto intending to be legally bound hereby promises, covenants and agrees as follows: 1. The parties acknowledge that they jointly own the former marital residence located at 405 Third Street, New Cumberland, Pennsylvania. There are no liens or other encumbrances against said property. 2. The parties agree that said residence shall be transferred from joint names into Wife's name alone. This transfer shall take place pursuant to a Special Warranty . . Deed to be prepared by Wife's counsel. 3. In exchange for transferring the residence, Wife shall pay to Husband one hundred ten thousand dollars ($110,000.00). 4. Wife shall obtain said funds to pay Husband through a loan taken against the former marital residence located at 405 Third Street, New Cumberland, Pennsylvania. 5. Said loan shall be in Wife's name alone and she shall be solely responsible for paying same. Husband shall cooperate to whatever extent necessary for Wife to obtain said loan. 6. The parties shall sign the Deed at the time Wife's loan is finalized. The funds shall be released to Husband as soon as same are available by Wife's lending institution. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above-written. ,~~~ea.-~~ Step ie V. Sorensen sd1d~ ~~-~ - ~~orensen ,. -. (") s: 1"-.) = = c:::n ~ :;;;.. -< o -fl I! n1::n r -arn ~ny ~~ 0,n ;::--1 :20 -< w ~ -....:.;.. co c..n -.J Stephanie V. Sorensen, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 04-680 Civil Term Larry W. Sorensen, Defendant CIVIL ACTION - LA W IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for Divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Served by Certified Mail. Restricted Delivery on February 20. 2004. Proof of Service was filed with the Prothonotary on February 25. 2004. 3. (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by the plaintiff December 13.2005; by the defendant January 18.2006. 4. Related claims pending: No other claims pending. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached, if the decree is to be entered under section 3301(d)(1)(i) of the Divorce Code. (Complete either (a) or (b).) ( a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG. PA 17108 (717) 236-9428 . FAX (717) 236-2817 .. (b) Date plaintiffs Waiver of Notice in ~ 3301(c) Divorce was filed with the Prothonotary: December 14.2005. Date defendant's Waiver of Notice in ~ 3301(c) Divorce was filed with the Prothonotary: January 23.2006. ~c Catherine A. Boyle, Esquire Attorney for Plaintiff 2 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG. PA 17108 (717) 236-9428 . FAX (717) 236-2817 .. Stephanie V. Sorensen, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 04-680 Civil Term Larry W. Sorensen, Defendant CIVIL ACTION - LA W IN DIVORCE CERTIFICATE OF SERVICE I hereby certify on thisOt 5 ~ day of ~ ~ , 2006 a copy of the forgoing o Praecipe to Transmit Record was mailed first-class, postage paid to: Larry Sorensen c/o Susan Kadel, Esq. James, Smith, Dietterick & Connelly, LLP P.O. Box 650 Hershey, P A 17003 Respectfully submitted, atherine A. Boyle, Esquire Attorney for Plaintiff MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 236-2817 r--.,., = c:.,:;> c:r. ~ ;X:;.... o -11 :r! f'n f!:! -0 f71 -0,'0 (~.i (~, t:J25 Or" .:;;~l ",- .:0 -< -<: W ;r:,.. ~-- 0') CJ1 Q) ~ ~.,,:.:.~ ~.s . . ~ IN THE COURT OF COMMON PLEAS ~ " ~ ~! OF COUNTY ~ ~ ~ ...'4 ~.~ ~l ~ ~.~ ~.~ ~ ~.~ I ~.~ ~.~ ~ ~ ~.s ~ a ~.~ ~~~ ~ ~ ~ ~.S , ~.; ~ i ...~ ~.~ " ~.~ ~\ i ~.~ ;..~ , CUMBERLAND STATE OF '* PENNA. .. .~:t~P.;tlCi!l~~___~t., _ _s.~J::'~I1_13~_rl!. m_.. _ _ _ _........ __ m_. _ _0. N (). .QA:':'.~.~.9....G,;iv.i.l...');'.~.:p:n ,..~J,._9,;i,;IJ.,ti.tt___.__ Versus .. ~Ci_r.:r:X.._ \i..___ _~~.r.ensen, .. J:) ef ~ Il<l Ci.I1 1:.. __ _ _ ;..~ * ~A ~ ~.~ i ~.~ DECREE IN DIVORCE AND NOW, .. .JLJ.))C-. .1................. ,~. .2006" it is ordered and decreed that ..... .~~~PP:~~~~. Y ~. ~.~~~P.s.~~. . . . . . . . . . . . . . . . . " plaintiff, and.............. .~~.:r:~Y. rt'... .$9;r.~~~~A....................., defendant, are divorced from the bonds of matrimony. The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; The Marital Settlement Agreement dated December 14, 2005, and the . . .. . . . . . . . . . . . . .. . . .. . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . .. . . . . .. . . . . . . . . . . . . . . , ~~~~~.n:t:. ~? .t:l:1e. ~~~~ :t.o:~. ~~.t:1::~~~~I?-~. !\Sf~~~~~I?-~. .~~~~? .~~Y. .~~!. .2.q06, are hereby incorporated but not merged herein. 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