HomeMy WebLinkAbout04-1505TIMOTHY ALLEN WOLF,
Plaintiff
vs.
KAREN MARIE WOLF,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2004 - /S6S Civil Term
CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the
claims set forth in the following pages, you must take prompt action. You are
warned that if you fail to do so, the case may be entered against you for any other
claim or relief requested in these papers by the Plaintiff. You may lose money or
property or other rights important to you, including custody or visitation of your
children.
When the ground for the divorce is indignities or irretrievable breakdown of
the marriage, you may request marriage counseling.
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
(717) 249-3166
1-800-990-9108
TIMOTHY ALLEN WOLF,
Plaintiff
vs.
KAREN MARIE WOLF,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2004 - /S?NS Civil Term
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION 3301(c)
OF THE DIVORCE CODE
1. The Plaintiff is Timothy Allen Wolf, an adult individual whose current
address is 1320A Oak Lane, New Cumberland, Cumberland County,
Pennsylvania 17070, and whose social security number is 101-62-3145.
2. The Defendant, Karen Marie Wolf, is an adult individual, whose current
address is 1629 Airport Drive, Mechanicsburg, Cumberland County,
Pennsylvania 17050, and whose social security number is 062-60-0278.
3. Plaintiff and Defendant were married on October 20, 1990, in Buffalo, New
York.
4. Plaintiff and Defendant have resided in the Commonwealth of Pennsylvania
for a period of at least six (6) months prior to this filing.
5. Defendant is not a member of the Armed Services of the United States or its
allies.
6. Plaintiff is a citizen of the United States and Defendant is a citizen of the
United States.
7. There has been no prior action for divorce filed in any jurisdiction.
8. Plaintiff has been advised of the availability of marriage counseling, and has
waived said right.
9. There is one minor child born of the marriage; namely: Kaitlyn Marie Wolf,
born October 17, 1996.
10. Plaintiff avers that the grounds on which this action is based are:
(a) That the marriage is irretrievably broken.
WHEREFORE, Plaintiff respectfully requests your Honorable Court to grant
a Decree in Divorce.
Respectfullxsubmitted,
i
B)
;biane M. Dils, Esquire
1017 North Front Street
Harrisburg, PA 17102
(717) 232-9724
I.D. No. 71873
Date: 0/0),
VERIFICATION
I verify that the statements made in this Complaint in Divorce are
true and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
1
TIMO'1 N T10 F
Date: April 7, 2004
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RECF!vFD OCT 10 20055
Y'
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
TIMOTHY ALLEN WOLF,
Plaintiff ) NO. 2004-1505 CIVIL TERM
V. )
KAREN MARIE WOLF, ) CIVIL ACTION - LAW
Defendant ) IN DIVORCE
ORDER OF COURT
AND NOW, this / Z ` day of OCUale/ , 2005, upon
consideration of the foregoing Stipulation for Exclusive Possession, the Court hereby ORDERS
and DECREES that the terms and conditions of said Stipulation are hereby incorporated into and
made a part of this Order. Defendant, Karen Marie Wolf, shall have exclusive possession and
use of the Marital Residence located at 1629 Airport Drive, Mechanicsburg, Cumberland County,
Pennsylvania 17050 pending further Order of Court or agreement of the parties.
BY THE COURT:
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TIMOTHY ALLEN WOLF,
Plaintiff
V.
KAREN MARIE WOLF,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2004-1505 CIVIL TERM
CIVIL ACTION - LAW
: IN DIVORCE
PRAECIPE FOR WITHDRAWAL OF APPEARANCE
To the Prothonotary:
Kindly withdraw my appearance on behalf of Defendant, Karen Marie Wolf, in the
above-captioned matter.
DATED: September 12, 2006
Donald issinger, Esquire
Howett, Kissinger, Conley & Holst, P.C.
130 Walnut Street
P.O. Box 810
Harrisburg, PA 17108
(717) 234-2616
PRAECIPE FOR ENTRY OF APPEARANCE
To the Prothonotary:
Kindly enter the appearance of Elizabeth S. Beckley, Esquire, Thomas A. Beckley,
Esquire, and Beckley & Madden, of Counsel, on behalf of Defendant, Karen Marie Wolf, in the
above-captioned matter.
DATED: September 12, 2006
Of Counsel
BECKLEY & MADDEN
212 North Third Street
P.O. Box 11998
Harrisburg, PA 17108-1998
(717) 233-7691
lizabeth eckley, Esqui
Thomas A. Beckley, Esquire __?
CERTIFICATE OF SERVICE
I, Elizabeth S. Beckley, hereby certify that a true and correct copy of the foregoing
document was served upon the following and in the manner indicated below:
VIA FIRST CLASS MAIL
Diane M. Dils, Esquire
Law Offices of Dils & Dils
1400 North Second Street
Harrisburg, PA 17102
Dated: September 12, 2006
Eliz th S. Be ey, Esquire
?_j •...?
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1.,._. _-
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Commonwealth of Pennsylvania
County of Cumberland, ss:
TIMOTHY ALLEN WOLF, In the Court of Common Pleas of
Plaintiff Cumberland County, Pennsylvania
vs. NO. 2004 - 1505 Civil Term
KAREN MARIE WOLF, CIVIL ACTION - LAW
Defendant DIVORCE
Motion for Appointment of Master
( X ) Plaintiff ( ) Defendant moves the court to appoint a master with respect to the following
claims:
( X ) Divorce
( ) Annulment
( ) Alimony
( ) Alimony Pendente Lite
and in support of the motion states:
( X) Distribution of Property
( ) Support
( ) Counsel Fees
( ) Costs and Expenses
1. Discovery is complete as to the claim(s) for which the appointment of a master is requested.
2. The Defendant ( X ) has ( ) has not appeared in the action ( ) personally ( X ) by his attorney, Elizabth S.
Beckley, Esquire.
3. The statutory ground(s) for divorce (is) (are) Irretrievably broken, indignities.
4. Check the applicable paragraph(s) by check mark:
( ) The action is not contested.
( ) An agreement has been reached with respect to the following claims:
( X ) The action is contested with respect to the following claims:
EQUITABLE DISTRIBUTION
5. The action ( ) involves ( X ) does not involve complex issues of law or fact.
6. The hearing is expected to take... (hours) . `/z. (days).
7. Additional information, if any, relevant to the Motion: None
Date: -)/0-2
Diane M. Dils, Esquire
Attorney for ( X) Plaintiff
Attorney for ( ) Defendant
AND NOW, , 2007,
to the following claims:
Esquire, is appointed Master with respect
BY THE COURT
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Arthur K. Dils, Esquire DILS AND DILS 1400 North Second Street
Diane M. Dils, Esquire Harrisburg, PA 17102
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
TIMOTHY ALLEN WOLF
Plaintiff
vs. NO. 2004-1505 Civil Term
KAREN MARIE WOLF
Defendant
INCOME AND EXPENSE STATEMENT
UNDER Pa.R.C.P. 1920.31(a)(1)
This Form Must Be Completed
(If you are self-employed or if you are salaried by a business of which you are the owner in whole or
in part, you must also fill out the Supplemental Income Statement which appears on the last page
of this Income and Expense Statement.)
INCOME AND EXPENSE STATEMENT OF TIMOTHY ALLEN WOLF
I verify that the statements made in this Income and Expense Statement are true and
correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
§ 4909 relating to unsworn falsification to authorities f
Date: 3 / Q 7
ane M. Dils
Attorney for Pkzf 0")
INCOME:
Employer: EDS
Address: 5400 Legacy Drive, H3-2A-82
City, State, ZIP Plano, TX 75024
Type of Work:
Payroll Number: 1150114
Gross Pay per Pay Period: $2,916.67
Page 1 of 8
Arthur K. Dils, Esquire DILS AND DILS 1400 North Second Street
Diane M. Dils, Esquire Harrisburg, PA 17102
ITEMIZED PAYROLL DEDUCTIONS: (Bi-Weekly)
NAME AMOUNT
F.I.C.A. $ 178.02
Social Security $ -
Local Wage Tax $ '
Occupational Tax $ -
State Income Tax $ 90.92
Federal Tax $ 534.17
Retirement $ -
Savings Bonds $ '
Union $ '
Life Insurance $ -
Health Insurance $ 45.31
Medicare $ 41.63
Unemployment Tax $ -
Disability Insurance $ -
City Taxes $ 28.71
Defferals $ 87.51
Garnishments (Child/Spousal Support) $ 564.32
Additional Fed Tax
Total Itemized Payrol l Deductions $ 1,570.59
Gross Pay Per Pay P eriod $ 2,916.67
Net Income Per Pay: $ 1,346.08
OTHER INCOME:
(Fill In Appropriate Column) WEEK MONTH YEAR
Alimony $ - $ $ '
Interest $ - $ - $ '
Dividends $ - $ $ '
Pension $ - $ - $ "
Annuity $ - $ - $ -
Social Security $ - $ - $ -
Rents $ - $ - $ -
Royalties $ - $ $ -
Expense Account $ - $ - $ -
Gifts $ - $ $ -
Unemployment Compensation $ - $ - $ -
Workmen's Compensation $ - $ - $ -
Misc.
Misc.
Misc.
TOTAL GROSS INCOME: $ - $ 5,833.34 $ -
TOTAL TAXES: $ - $ - $ "
TOTAL NET INCOME: $ - $ 2,692.16 $ -
Page 2 of 8
Arthur K. Dils, Esquire DILS AND DILS 1400 North Second Street
Diane M. Dils, Esquire Harrisburg, PA 17102
EXPENSES
(Fill In Appropriate Column) WEEK MONTH YEAR
HOME
Mortgage/Rent $ - $ 590.00 $ -
Maintenance $ - $ 50.00 $ -
Utilities $ - $ 60.00 $ -
Electric $ - $ 70.00 $ -
Gas $ - $ - $ -
Oil (Average) $ - $ - $ -
Telephone $ - $ 100.00 $ -
Water $ - $ 30.00 $ -
Sewer $ - $ - $ -
Trash $ - $ - $ -
Misc. $ - $ - $ -
Misc. $ - $ - $ -
EMPLOYMENT
(Fill In Appropriate Column) WEEK MONTH YEAR
Public Transportation $ - $ - $ "
Lunch $ - $ 120.00 $ -
Misc. $ - $ - $ -
Misc. $ - $ - $ -
Misc. $ - $ - $ -
TAXES
(Fill In Appropriate Column) WEEK MONTH YEAR
Real Estate $ - $ - $ -
Personal Property $ - $ - $ "
Income (Federal, State & Local) $ - $ - $ -
Other $ - $ - $ "
Other $ - $ - $ "
Other $ - $ - $ "
Other $ - $ - $ _
INSURANCE
(Fill In Appropriate Column) WEEK MONTH YEAR
Homeowners $ - $ - $ -
Automobile $ - $ 80.00 $ -
Life $ - $ 50.00 $ -
Accident $ - $ - $ -
Health $ - $ 100.00 $ -
Other $ - $ - $ -
Page 3 of 8
Arthur K. Dils, Esquire
Diane M. Dils, Esquire
DILS AND DILS
1400 North Second Street
Harrisburg, PA 17102
AUTOMOBILE
(Fill In Appropriate Column) WEEK MONTH YEAR
Payments $ - $ 350.00 $ -
Fuel $ - $ 125.00 $ -
Repairs (Average) $ - $ 75.00 $ -
Other $ - $ - $ -
Other $ - $ $ -
Other $ - $ - $ -
MEDICAL
(Fill In Appropriate Column) WEEK MONTH YEAR
Doctor $ - $ 70.00 $ -
Dentist $ - $ 75.00 $ -
Orthodontist $ - $ - $ '
Hospital $ - $ $ -
Medicine $ - $ 40.00 $ -
Special Needs (Glasses, Braces, $ - $ 10.00 $ -
Orthopecic Needs) $ - $ - $ '
Other $ - $ - $ "
Other $ - $ $ "
Other $ - $ - $ '
EDUCATION
(Fill In Appropriate Column) WEEK MONTH YEAR
Private School $ - $ - $ -
Parochial School $ - $ - $ -
College $ - $ - $ "
Religious $ - $ $ '
Charter $ - $ $ '
Other $ - $ - $ '
Other $ - $ $ '
Other $ - $ - $ "
PERSONAL
(Fill In Appropriate Column) WEEK MONTH YEAR
Clothing $ - $ 75.00 $ -
Food $ - $ 300.00 $ -
Barber/Hairdresser $ - $ 50.00 $ -
Other: $ - $ $ '
Other: $ - $ - $ '
Other: $ _ $ _ $ _
Other: $ - $ $ '
Page 4 of 8
Arthur K. Dils, Esquire
Diane M. Dils, Esquire
DILS AND DILS
1400 North Second Street
Harrisburg, PA 17102
CREDIT PAYMENTS
(Fill In Appropriate Column) WEEK MONTH YEAR
Credit Card Accounts $ - $ 750.00 $ -
Charge Accounts $ - $ 25.00 $ -
Memberships $ - $ _ $ _
Other: $ _ $ _ $ _
Other: $ _ $ _ $ _
Other: $ - $ _ $ _
LOANS
(Fill In Appropriate Column) WEEK MONTH YEAR
Credit Union $ - $ _ $ _
Home Equity Loan $ - $ _ $ _
Personal $ _ $ _ $ _
Other $ _ $ _ $ _
Other $ _ $ _ $ _
Other $ - $ _ $ _
MISCELLANEOUS
(Fill In Appropriate Column) WEEK MONTH YEAR
Household Help $ - $ _ $ _
Child Care $ - $ _ $ _
Papers/Books/Magazines (Average) $ - $ 20.00 $ -
Entertainment $ - $ 150.00 $ -
Pay TV $ _ $ - $ _
Vacation $ - $ 50.00 $ -
Gifts $ - $ 50.00 $ -
Legal Fees $ - $ 150.00 $ -
Charitable Contributions $ - $ 40.00 $ -
Other Child Support $ - $ _
Alimony Payments $ - $ _ $ _
Savings $ _ $ _ $ _
Other: $ _ $ _ $ _
Other $ _ $ _ $ _
Other $ _ $ _ $ _
Other $ _ $ _ $ _
TOTAL EXPENSES: $ - $ 3,655.00 $
Page 5 of 8
Arthur K. Dils, Esquire DILS AND DILS 1400 North Second Street
Diane M. Dils, Esquire Harrisburg, PA 17102
PROPERTY OWNED: SEE INVENTORY & APPRAISEMENT
NAME DESCRIPTION VALUE HUSBAND WIFE
Checking Acct. $ -
Savings Acct. $ -
Credit Union $ -
Stocks/Bonds $ -
Real Estate $ -
Other $ -
Other $ -
Other $ -
Other $ -
Total $ -
IINSURANCE:
NAME
Hospital:
Blue Cross
Other
Other
Other
Medical:
Blue Shield
Medicare
Other
Other
Other
POLICY
COMPANY NUMBER HUSBAND WIFE
OWNERSHIP
JOINT
COVERAGE
JOINT
POLICY
COMPANY NUMBER HUSBAND WIFE JOINT
AETNA
X
Page 6 of 8
Arthur K. Dils, Esquire DILS AND DILS 1400 North Second Street
Diane M. Dils, Esquire Harrisburg, PA 17102
INSURANCE: COVERAGE
POLICY
NAME COMPANY NUMBER HUSBAND WIFE JOINT
Health/Accident
Disability Income
Dental
Prescription
Other
Other
Other
Additional Comments:
Page 7 of 8
Arthur K. Dils, Esquire DILS AND DILS 1400 North Second Street
Diane M. Dils, Esquire Harrisburg, PA 17102
SUPPLEMENTAL INCOME STATEMENT
( a) This form is to be filled out by a person who (check one):
(1) Operates a business or practices a profession, or
(2) Is a member of a partnership or joint venture, or
(3) Is a shareholder in and is salaried by a closed corporation or similar entity.
( b) Attach to this Statement a copy of the following documents relating to the partnership,
joint venture, business, profession, corporation or similar entity:
(1) The most recent Federal Income Tax Return, and
(2) The most recent Profit and Loss Statement
( c) Business:
Street Address:
City, State & Zip
Email:
( d ) Nature of business (check one):
(1) Partnership
(2) Joint Venture
(3) Profession
(4) Closed Corporation
(5) Other
( e) Name of Accountant, Controller, or other person in charge of Financial records:
(f) Annual Income from Business:
(1) How Often Is The Income Received?:
(2) Gross Income Per Pay Period:
(3) Net Income Per Pay Period:
4 Specified Deductions, If An :
Page 8 of 8
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LAW OFFICE OF DILS & DILS
DIANE M. DILS, ESQUIRE
1400 North Second Street
First Floor Front
Harrisburg, PA 17102
(717) 232-9724
I.D. No. 71873
Attorney for Plaintiff, Timothy Allen Wolf:
TIMOTHY ALLEN WOLF, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs.
KAREN MARIE WOLF
Defendant
NO. 2004-1505 Civil Term
CIVIL ACTION - LAW
IN DIVORCE
INVENTORY AND APPRAISEMENT
OF
TIMOTHY ALLEN WOLF
Plaintiff files the following Inventory and Appraisement of all property
owned or possessed by either party at the time of this action was commenced and
all property transferred within the preceding three (3) years.
Plaintiff verifies that the statements made in this Inventory and
Appraisement are true and correct.
Plaintiff understands that false statements herein are made subject to the
penalties of 18 PA §4904 relating to,ynsworn falsification of authorities.
Y: /C
Diane M. Dils, Esquire
Attorney for Plaintiff
ASSETS OF PARTIES
Plaintiff marks on the list below those items applicable to the case at bar and
itemizes the assets on the appraisal report is attached.
(X ) 1. Real Property
(X ) 2. Motor Vehicles
(X ) 3. Stocks, Bonds, Securities and Options
( ) 4. Certificates of Deposit
(X ) 5. Checking Accounts, Cash
( ) 6. Savings Accounts, Money Market and Savings Certificates
( ) 7. Contents of Safe Deposit Boxes
( ) 8. Trusts
( ) 9. Life Insurance Policies, (Indicates face value, cash surrender
value and current Beneficiaries)
( ) 10. Annuities
( ) 11. Gifts
( ) 11- Inheritances
( ) I.':,. Patents, Copyrights, Inventions, Royalties
( ) 14. Personal property outside of the home
( ) 1 `. Business (list all owners, including percentage of ownership,
and officer/director positions held by a party with company)
( ) 16. Employment termination benefits - Severance Pay, Workman's
Compensation Claim/Award
( ) I'-. Profit Sharing Plans
( ) 18. Pension Plans (Indicate employee contribution and date plan
vests)
( ) 19. Retirement Plans, Individual Retirement Accounts
( ) 20. Disability Payments
( ) 21. Litigation Claims (Matured and Un-matured)
( ) 22. MilitaryN.A. Benefits
( ) 23. Education Benefits
(X ) 24. Debts due, including loans, mortgages held
(X ) 25. Household furnishings and personalty (include as a total
category and attach itemized list of distribution)
( ) 2E. Other
Arthur K. Dils, Esquire DILS AND DILS 1400 North Second Street
Diane M. Dils, Esquire ATTORNEYS AT LAW Harrisburg, PA 17102
MARITAL PROPERTY
Plaintiff lists all marital property in which either or both spouses have alegal or equitable interest
individually or with any other person as of the date this action was commenced.
ITEM
#
DESCRIPTION OF PROPERTY NAMES
OF ALL
OWNER
S H.W.J
DATE OF
ACQUISITION CURRENT
VALUE OF
ASSET
AMOUNT OF
LIEN
1 1629 Airport Road, Mechanicsburg, Pa J 2000 $182,000.00 $90,226.00
2
IRA Members 1st Husband cashed in
$9,080.00 in 2005 J
Husband
's Name
D/M-D/S
$9,080.00
$ -
3 401(k H D/M-D/S $28,600.00
4 Savings Account - Wife Withdrew
$3,900.00 leaving outstanding joint bill
payments to bounce
J
D/M-D/S
$7,800.00
5
Bidwell Investments Ownership with
Friends
H 1/5
Owner
D/M-D/S D/S - $3,409.00
01-06
$36,000.00
6 1997 Blazer Automobile J D/M-D/S $3,600.00
7
Personal Property
W Husband believes parties can agree to mutually
distribute
8
9
10
$ 231,080.00 $ 90,226.00
TOTAL MARITAL PROPERTY $ 321,306.00
Arthur K. Dils, Esquire DILS AND DILS 1400 North Second Street
Diane M. Dils, Esquire ATTORNEYS AT LAW Harrisburg, PA 17102
NON-MARITAL PROPERTY
Plaintiff lists all property in which a spouse has a legal or equitable interest which is claimed to be
excluded from marital property.
ITEM
#
DESCRIPTION OF PROPERTY NAMES
OF ALL
OWNERS
H.W.J
DATE OF
ACQUISITION CURRENT
VALUE OF
ASSET
AMOUNT OF
LIEN
1 NONE
2
3
4
5
6
7
8
9
10
11
12
TOTAL NON-MARITAL
PROPERTY -
Basis for Exclusion:
1. Pre-Marital Property
2. Gift
3. Acquired after Separation
4. Property excluded by Agreement of the Parties
5. Property disposed of in Good Faith for Value Prior to Divorce Suit
6. Inheritance
Arthur K. Dils, Esquire DILS AND DILS 1400 North Second Street
Diane M. Dils, Esquire ATTORNEYS AT LAW Harrisburg, PA 17102
PROPERTY TRANSFERRED
Plaintiff lists all marital property in which either or both spouses have legal or equitable interest
individually or with any other person and which has been transferred within the preceding three years.
ITEM
#
DESCRIPTION OF PROPERTY
DATE OF
TRANFER
CONSIDERATON AMOUNT OF
ANY LIEN AT
DATE OF
TRANSFER PERSON TO
WHOM
TRANSFERRED
1 2000 Saturn Automobile Post D/S - $3.018.00
2
3
4
5
6
7
8
9
10
Arthur K. Dils, Esquire DILS AND DILS 1400 North Second Street
Diane M. Dils, Esquire ATTORNEYS AT LAW Harrisburg, PA 17102
LIABILITIES
Plaintiff lists all liabilities of either or both spouses alone or with any person as of the
date acttion was commenced:
ITEM
#
DESCRIPTION OF PROPERTY NAMES OF ALL
CREDITORS NAMES OF ALL
DEBTORS
H,W,J
AMOUNT OF
LIABILITY
1 Mortgage J $90,226.00
Debt aid b Husband since se aration
2
Credit Card
People's Bank
J See Attached
Chart
3
Credit Card
Providian
J See Attached
Chart
4
Credit Card
Citi Card
J See Attached
Chart
5
Credit Card
GM
J See Attached
Chard
6
7
8
9
10
Arthur K. Dils, Esquire DILS AND DILS 1400 North Second Street
Diane M. Dils, Esquire ATTORNEYS AT LAW Harrisburg, PA 17102
CREDIT CARD DEBT
AMOUNT
NAME OF CREDITOR
BALANCE DUE 06-03
PRINCIPLE PAID INTEREST PAID CURRENT BANK
TO DATE TO DATE BALANCE DUE
Peoples Bank $ 985.00 $ 985.00 N/A $ -
Paid by Husband
Providian $ 11,755.89 $ 6,537.88 $ 4,270.00 5136 (7/2007)
Paid by Husband
Citicard
Paid by Husband $ 3,055.30 $ 3,172.78 N/A $1,498.04 (7/2007))
Plus
(Post Separation
Charges by Wife) $ 1,585.54
GM $ 1,210.00 Unknown Unknown Unknown
Paid by Wife
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TIMOTHY ALLEN WOLF,
Plaintiff
VS.
KAREN MARIE WOLF,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2004 - 1505 Civil Term
CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the
claims set forth in the following pages, you must take prompt action. You are
warned that if you fail to do so, the case may be entered against you for any other
claim or relief requested in these papers by the Plaintiff. You may lose money or
property or other rights important to you, including custody or visitation of your
children.
When the ground for the divorce is indignities or irretrievable breakdown of
the marriage, you may request marriage counseling.
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
(717) 249-3166
1-800-990-9108
TIMOTHY ALLEN WOLF,
Plaintiff
vs.
KAREN MARIE WOLF,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2004 - 1505 Civil Term
CIVIL ACTION - LAW
IN DIVORCE
AMENDED COMPLAINT IN DIVORCE
AND NOW this day of July 2007 comes the Plaintiff, Timothy Allen
Wolf, by his Attorney, Diane M. Dils, Esquire, and respectfully avers the
following:
1. Paragraphs 1 through 10 in the Complaint in Divorce Under Section 3301(c)
of the Divorce Code are incorporated herein and made a part of herein by
reference.
11. Plaintiff hereby avers that the grounds on which this action is based are:
(a) That Plaintiff and Defendant have lived separate and apart for a period of
at least two (2) years, said date of separation being June 23, 2003.
WHEREFORE, Plaintiff, Timothy Allen Wolf, respectfully requests your
Honorable Court to enter a Decree in Divorce on the grounds that the parties have
been separated for a period of two (2) years.
1.
CLAIM FOR EQUITABLE DISTRIBUTION
12. Plaintiff hereby avers that Plaintiff and Defendant are the owners of real
estate which is subject to equitable distribution by your Honorable Court.
13. Plaintiff hereby avers that Plaintiff and Defendant are the owners of
numerous household furnishings, personal property, motor vehicles, and
other miscellaneous assets which are subject to equitable distribution by
your Honorable Court.
WHEREFORE, Plaintiff, Timothy Allen Wolf, respectfully prays your
Honorable Court to equitably distribute all assets between the parties.
Respectfully submitted,
A.
Diane M. Dils, Esquire
1400 North Second Street
Harrisburg, PA 17102
(717) 232-9724
I.D. No. 71873
Date:
2.
VERIFICATION
I verify that the statements made in the Amended Complaint in Divorce of the
Divorce Code are true and correct. I understand that false statements herein are
made subject to the penalties of 18 PA. C.S. Section 4904 relating to unsworn
falsification to authorities.
Date: July 3, 2007
CERTIFICATE OF SERVICE
I, Diane M. Dils, Esquire, hereby certify that a true and correct copy of the
within Amended Complaint in Divorce is being serviced upon the following
individuals by first class United States Mail by depositing same at the post office
in Harrisburg, Pennsylvania on the day of July 2007, as follows:
Elizabeth S. Beckley
Beckley & Madden
212 N. Third Street
Harrisburg, PA 17108-1998
Respectfully submitted,
rte,
B? DDils, Esquire
1400 North Second Street
Harrisburg, PA 17102
(717) 232-9724
I.D. No. 71873
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TIMOTHY ALLEN WOLF,
Plaintiff
VS.
KAREN MARIE WOLF,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNT', PENNSYLVANIA
No. 2004 - 1505 Civil Term
CIVIL ACTION - LAW
IN DIVORCE
NOTICE
If you wish to deny any of the statements set forth in this affidavit, you must
file a counter-affidavit within twenty days after this affidavit has been served upon
you or the statements will be admitted.
AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE
1. The parties to this action separated June 7-3 , 2003 and have
continued to live separate and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
I verify that the statements made in this affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.
C.S. Section 4904 relating to unsworn falsification to authorities. ___1 ?,? 0& tj
Date: `? l 31 10-7
Timot y olf, Plaintif
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Commonwealth of Pennsylvania AUG 10 2007
County of Cumberland, ss:
TIMOTHY ALLEN WOLF,
Plaintiff
vs.
KAREN MARIE WOLF,
Defendant
( ) Plaintiff
claims:
and in support of the motion states:
In the Court of Common Pleas of
Cumberland County, Pennsylvania
NO. 2004 - 1505 Civil Term
CIVIL ACTION - LAW
DIVORCE
Motion for Appointment of Master
) Defendant moves the court to appoint a master with respect to the following
( X ) Divorce
( ) Annulment
( ) Alimony
( ) Alimony Pendente Lite
( X) Distribution of Property
( ) Support
( ) Counsel Fees
( ) Costs and Expenses
1. Discovery is complete as to the claim(s) for which the appointment of a master is requested.
2. The Defendant ( X ) has ( ) has not appeared in the action ( ) personally ( X ) by his attorney, Elizabth S.
Beckley, Esquire.
3. The statutory ground(s) for divorce (is) (are) Irretrievably broken, indignities.
4. Check the applicable paragraph(s) by check mark:
( ) The action is not contested.
( ) An agreement has been reached with respect to the following claims:
( X) The action is contested with respect to the following claims:
EQUITABLE DISTRIBUTION
5. The action ( ) involves ( X ) does not involve complex issues of law or fact.
6. The hearing is expected to take... (hours). %2. (days).
7. Additional information, if any, relevant to the Motion: None
Date: - t/
Diane M. Dils, Esquire
Attorney for ( X) Plaintiff
Attorney for ( ) Defendant
AND NOW, 0, 2007,/? ??, Esquire, is appointed Master with respect
to the followin laims:
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TIMOTHY ALLEN WOLF, :IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent :CUMBERLAND COUNTY, PENNSYLVANIA
V. :CIVIL ACTION - LAW
:IN DIVORCE
KAREN MARIE WOLF,
Defendant/Petitioner :NO. 04 -- 1505
MOTION FOR APPOINTMENT OF MASTER
Karen Marie Wolf (Defendant/Respondent) moves the court to appoint the master
with respect to the following claims:
() Divorce () Distribution of Property
O Annulment O Support
( X) Alimony ( X) Counsel Fees
O Alimony Pendente Lite ( X) Costs and Expenses
and in support of the motion state:
1. Discovery is complete as to the claims for which the appointment of a
master is requested.
2. The non-moving party has appeared in this action by his attorney, Diane
M. Dils, Esquire.
3. The statutory ground for divorce are: 3301 (c) and 3301 (d).
4. The action is contested with respect to the following claims: alimony,
counsel fees, costs and expenses and distribution of property.
5. The action does not involve complex issues of law or fact.
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6. The hearing is expected to take 1 - 1 1/2 days.
7. Additional information, if any, relevant to the motion: None.
DATED: Respectfully submitted,
of Counsel
BECKLEY & MADDEN
212 North Third Street 61izaKeth S. B?s1?lJ?
P.O. Box 11998
Harrisburg, PA 17108
(717) 233-7691
e?fhomas eckley
ORDER APPOINTING MASTER
BY THE COURT:
, J.
AND NOW this day of
2007, E. Robert Elicker, 11,
Esquire, is appointed master with respect to the following claims: counsel fees, costs and
expenses and alimony.
MOVING PARTY
Name: Karen Marie Wolf
Atty's Name: Elizabeth S. Beckley
Atty Address:
BECKLEY & MADDEN
212 North Third Street
P.O. Box 11998
Harrisburg, PA 17108
(717) 233-7691
NON-MOVING PARTY
Name: Timothy Allen Wolf
Atty's Name: Diane M. Dils
Atty Address:
Dils & Dils
1400 North Second Street
(First Floor Front)
Harrisburg, PA 17102
(717) 233-8743
2
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CERTIFICATE OF SERVICE
I, Elizabeth S. Beckley, Esquire, hereby certify that a true and correct copy of the
foregoing document was this day served upon the person and in the manner indicated
below.
SERVICE BY FIRST CLASS MAIL:
Diane M. Dils, Esquire
Dils & Dils
1400 North Second Street
(First Floor Front)
Harrisburg, PA 17102
DATED:
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TIMOTHY ALLEN WOLF, :IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent :CUMBERLAND COUNTY, PENNSYLVANIA
V. :CIVIL ACTION - LAW
JN DIVORCE
KAREN MARIE WOLF,
Defendant/Petitioner :NO. 04 -- 1505
PETITION FOR COUNSEL FEES, COSTS AND EXPENSES AND ALIMONY
AND NOW comes the Defendant/Petitioner, Karen Marie Wolf, who, by and
through her attorneys, Elizabeth S. Beckley, Esquire, Thomas A. Beckley, Esquire, and
Beckley & Madden, of Counsel, files this Petition for Counsel Fees, Costs and Expenses
and Alimony, in which she avers that:
1. Defendant/Petitioner, Karen Marie Wolf, is an adult individual residing at
1629 Airport Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050.
2. Plaintiff/Respondent, Timothy Allen Wolf, is an adult individual residing
at on Oak Lane, New Cumberland, Cumberland County, Pennsylvania 17070.
3. Plaintiff/Respondent filed a Divorce Complaint in this matter on or about
April, 2004, at the above-captioned docket number. Plaintiff/Respondent filed an
Amended Complaint in August, 2007.
4. Defendant/Petitioner lacks sufficient property to provide for her
reasonable means and is unable to support herself in the standard of living established
during the marriage through appropriate employment.
5. Defendant/Petitioner has employed counsel, but is unable to pay the
necessary and reasonable attorney's fees for said counsel.
6. Defendant/Petitioner requires reasonable alimony to adequately maintain
herself in accordance with the standard of living established during the marriage.
11. Plaintiff has adequate earnings to provide for the Defendant's/Petitioner's
support and to pay her counsel fees, costs and expenses.
WHEREFORE, Defendant/Petitioner, Karen Marie Wolf, respectfully requests
the Court to: (1) enter an award of counsel fees, costs and expenses as deemed
appropriate; and (2) enter an award of alimony in her favor.
DATED:
of Counsel
BECKLEY & MADDEN
212 North Third Street
P.O. Box 11998
Harrisburg, PA 17108
(717) 233-7691
2
Respectfully submitted,
bhr-n-aU( WtV U4:14 YCI UnU MA NU. eJeUdJb r. ue/U4
VERIFICATION
I, Karon M. Wolf, hereby verify that the statements made in the foregoing
document 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 18 Pa. C. S.
Section 4904, relating to unsvvorn falsification to authorities.
DATED: 10 -h0-
K?m M. Wolf
CERTIFICATE OF SERVICE
I, Elizabeth S. Beckley, Esquire, hereby certify that a true and correct copy of the
foregoing document was this day served upon the person and in the manner indicated
below.
SERVICE BY FIRST CLASS MAIL:
Diane M. Dils, Esquire
Dils & Dils
1400 North Second Street
(First Floor Front)
Harrisburg, PA 17102
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DATED:
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TIMOTHY ALLEN WOLF, :1N THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
V. :CIVIL ACTION - LAW
:IN DIVORCE
KAREN MARIE WOLF,
Defendant :NO. 2004 -1505 CIVIL
INVENTORY OF KAREN MARIE WOLF
Defendant, Karen Marie Wolf, files the following inventory of all property owned
or possessed by either party at the time this action was commenced and all property
transferred within the preceding three years.
DATED:
Kar n Marie Wolf
A ,
ASSETS OF THE PARTIES
Plaintiff marks on the list below those items applicable to the case at bar and
itemizes the assets on the following pages.
x 1. Real Property
x 2. Motor vehicles
x 3. Stocks, bonds, securities and options
4. Certificates of deposit
x 5. Checking accounts, cash
x 6. Savings accounts, money market and savings certificates
_ 7. Contents of safe deposit boxes
8. Trusts
_
x 9. Life insurance policies (indicate face value, cash surrender value and
current beneficiaries)
10. Annuities
_ 11. Gifts
_ 12. Inheritances
13. Patents, copyrights, inventions, royalties
- 14. Personal property outside the home
-
- 15. Business (list all owners, including percentage of ownership, and
officer/director positions held by a party with company)
16. Employment termination benefits -- severance pay, worker's
- compensation claim/award
17. Profit sharing plans
_
- 18. Pension plans (indicate employee contribution and date plan vests)
x 19. Retirement plans, Individual Retirement Accounts
20. Disability payments
x 21. Litigation claims (matured and unmatured)
22. MilitaryN.A. benefits
23. Education benefits
_
x 24. Debts due, including loans, mortgages held
x 25. Household furnishings and personalty (include as a total category and
attached itemized list if distribution of such assets is in dispute)
x 26. Other (Jewelry)
1
MARITAL PROPERTY
Plaintiff lists all marital property in which either or both spouses have a legal or
equitable interest individually or with any other person as of the date this action was
commenced:
Item Number Description of Propert v Names of all Owners
1. 1629 Airport Dr. Tim and Karen Wolf
Mechanicsburg, PA
2. 1997 Blazer Tim and Karen Wolf
2. 2000 Saturn Tim and Karen Wolf
3. Shares of EDS Stock Tim and Karen Wolf
3. Shares of Ciber Stock Tim and Karen Wolf
3. EDS Stock Dividends Tm and Karen Wolf
9. K of C Life Insurance Tim and Karen Wolf
19. IRA Tim and Karen Wolf
19. 401 K Tim and Karen Wolf
21. Accident Settlement Karen Wolf
25. Household Items Tim and Karen Wolf
(Wife believes parties can agree to mutually distribute)
25. jewelry Mens & Womens Tim and Karen Wolf
(Husband received his jewelry post separation. Husband later removed Wife's
jewelry from the marital residence and has failed to return the same)
NON-MARITAL PROPERTY
Plaintiff lists all property in which spouse has a legal or equitable interest which is
claimed to be excluded from marital property:
Item Number Description of Property
Reason for Exclusion
2
PROPERTY TRANSFERRED
Item Description Date of Person to Whom Value at date
# of Property Transfer Transferred of Nuisition
2. 1997 Blazer 12/03 Karen Wolf $23,254.62
2. 2000 Saturn 12/03 Tim Wolf bought new, unknown
Item Value as of Date
# of Transfer
2. $1,175
2. $3,000 ? - traded towards new vehicle - Husband also used $2,000 of GM credit
card points that were jointly accrued towards the purchase of 2 new Saturn
vehicles.
LIABILITIES
Item Description Names of Names of
Number of Property All Creditors All Debtor
1. Mortgage ABN Amro joint
2. Credit Card GM joint
3. Credit Card Ford Citi joint until 3/04
4. Home Repair Septic Back up joint
5. Home Improvement Township mandated joint
sewer connection
6. Home Repair Heating/cooling joint
7. Home Repair driveway repair/sealing joint
3
CERTIFICATE OF SERVICE
I, Elizabeth S. Beckley, Esquire, hereby certify that a true and correct copy of the
foregoing document was this day served upon the person and in the manner indicated
below.
SERVICE BY FIRST CLASS MAIL:
Diane M. Dils, Esquire
Dils & Dils
1400 North Second Street
(First Floor Front)
Harrisburg, PA 17102
DATED: f lJ I ??
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TIMOTHY ALLEN WOLF, JN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
V. :CIVIL ACTION - LAW
:IN DIVORCE
KAREN MARIE WOLF,
Defendant :NO. 2004 -1505 CIVIL
INCOME AND EXPENSE STATEMENT OF KAREN MARIE WOLF
I verify that the statements made in this Income and Expense Statement are true
and correct. I understand that false statements herein are made subject to the penalties of
18 Pa.C.S. §4904 relating to unsworn falsification to authorities.
DATED: /
K enMarie Wolf
N
INCOME AND EXPENSE STATEMENT OF KAREN MARIE WOLF
SS# 062-60-0278
EMPLOYER & ADDRESS: CMU
1100 South Cameron St.
Harrisburg, PA 17104
JOB DESCRIPTION: Mental Retardation Supports Coordinator Supervisor
INCOME:
Pay Period - every 2 weeks
Gross Pay per Pay Period $1,751.04
Itemized Payroll Deductions:
Federal Withholding $266.06
Social Security $108.57
Local Wage Tax $35.02
State Income Tax $53.76
Retirement
Savings Bonds
Credit Union
Life Insurance
Health Insurance
OASDI/DIS
Other (HI) (Medicare)
Net Pay per Pay Period: $1,208.13
OTHER INCOME: Week Month Year
Interest $2.58
Dividends
Pension
Annuity
Social Security
Rents
Royalties
Expense Account
Gifts
Unemployment Comp.
Workmen's Comp.
Child and Spousal Support (includes mortgage contribution) $1,056.49/mo
TOTAL MONTHLY INCOME: $ 2,620.20 net
w/ child and support $3,676.69/mo
EXPENSES: Week
Mortgage/rent
Maintenance
Utilities
Electric
Gas
Oil
Telephone
Water
Sewer
Employment
Public Transportation
Lunch
Taxes
Real estate
Personal Property
Income
Other (per capita) School tax
Insurance
Homeowners
Automobile
Life
Accident
Health
Other
Automobile
Payments
Fuel
Repairs
Medical
Doctor
Dentist
Orthodonist
Chiropractor
Hospital
Medicine
Special Needs (glasses,
braces, etc.)
Month Year
$955.99
$350.00
$175
$55
$42.84
$200
$126.25
$35.77
$43.50
$62.26
$14.85
$328.37
$175
$100
$25
$25
Education
Private school
Parochial school
College
Religious
Other viola summer lessons and rental $29.83/mo
Week
Personal
Clothing
Food
Barber/hairdresser
Credit payments
creditcards
charge accounts
Memberships
Loans
Credit Union
Other
Miscellaneous
Household help
Child care
Papers/books/etc.
Entertainment
Pay TV
Vacation
Gifts
Legal Fees
Charitable contributions
Other internet
Loan
TOTAL EXPENSES:
PROPERTY OWNED:
Checking accounts
Savings accounts
Credit Union
Stocks/Bonds
Real estate
Life insurance
401 K
IRA
Bidwell Investments
1997 Blazer
2000 Saturn
Jewelry
GM Creditcard points
TOTAL VALUE OF PROPERTY:
Description
EDS, CIBER
1629 Airport Dr.
info held by spouse
info held by spouse
investment club
vehicle
vehicle (spouse's car)
info held by spouse
Month Year
$250
$400
$75
$650
$25
$25
$200
$12
$350
$80
$220
$20
$40
$$5,091.66
Value Ownership
$7800 joint
unknown
$180,000 ?
unknown
$35,000.00
$18,200.00
$36,000.00
$1125
?
$3,600
Real estate
joint
joint
joint
joint
H (joint)
joint
joint
joint
joint
$ need documentation from spouse
INSURANCE: Company Policy #
Coverage Capital Blue Cross Grp # 005075350000
Hospital ID# YWP80005552500
Blue Cross-
Other
Medical
Blue Shield
Other
Health/Accident
Disability Income
Dental Delta Dental
Vision NVA
Other
SUPPLEMENTAL INCOME STATEMENT
(a) This form is to be filed out by a person (check one):
(1) who operates a business or practices a profession, or
(2) who is a member of a partnership or joint venture, or
(3) who is a shareholder in and is salaried by a closed
corporation or similar entity.
(b) Attach to this statement a copy of the following documents relating to the
partnership, joint venture, business, profession, corporation or similar entity:
(1) the most recent Federal Income Tax Return, and
(2) the most recent Profit and Loss Statement.
(c) Name of business:
Address:
Telephone Number:
(d) Nature of business (check one)
(1) partnership
(2) joint venture
(3) profession
(4) closed corporation
(5) other
(e) Name of accountant, controller or other person in charge of financial
records:-
(f) (1)
(2)
(3)
(4)
Annual income from business:
Gross income per pay period:_
Net income per pay period:_
Specified deductions, if any:_
CERTIFICATE OF SERVICE
I, Elizabeth S. Beckley, Esquire, hereby certify that a true and correct copy of the
foregoing document was this day served upon the person and in the manner indicated
below.
SERVICE BY FIRST CLASS MAIL:
Diane M. Dils, Esquire
Dils & Dils
1400 North Second Street
(First Floor Front)
Harrisburg, PA 17102
DATED: YIK?
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TIMOTHY ALLEN WOLF, :IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
V. :CIVIL ACTION - LAW
:IN DIVORCE
KAREN MARIE WOLF,
Defendant :NO. 04 -- 1505
PRE-TRIAL STATEMENT OF KAREN MARIE WOLF
AND NOW comes the Plaintiff, Karen Marie Wolf, who, by and through her
attorneys, Elizabeth S. Beckley, Esquire, Thomas A.. Beckley, Esquire, and Beckley &
Madden, of Counsel, files the following pre-trial statement.
I. BACKGROUND
Mr. and Ms. Wolf were married on October 20, 1990. They separated in June,
2003, after several incidents of violence occurred and Ms. Wolf filed a Protection from
Abuse action. Ms. Wolf was granted a Protection from Abuse Order and she and the
parties' child remained in the marital residence. Mr. Wolf was held in Contempt of Court
several times for violating the Protection of Abuse Order. In October, 2005, the parties
entered into a Stipulation giving Ms. Wolf exclusive possession of the marital residence.
When the parties separated, Ms. Wolf was 36 years old and Mr. Wolf was 37 years old.
Mr. Wolf is employed by EDS. Ms. Wolf is employed by Case Management Unit.
Mr. and Ms. Wolf are the parents of one minor child, Kaitlyn Marie Wolf whose
date of birth is October 17, 1996. Mr. and Ms. Wolf share legal custody of their minor
child. Ms. Wolf has primary physical custody and Mr. Schue has partial physical custody
for the purpose of visitation pursuant to a Court Order entered on November 1, 2004, at
docket number 03 - 5240 of this Court.
1
II. STATEMENT OF MARITAL ASSETS
Marital Asset Approximated Value
1629 Airport Drive $182,000.00
Mechanicsburg, Pennsylvania
EDS Stock unknown
Ciber Stock unknown
K of C Life Insurance unknown
Member's 1St IRA $18,200.00
(Husband cashed in '/2 of this IRA)
2000 Saturn (Husband's vehicle) unknown
VIP 401K $35,000.00
Bidwell Investments $36,000.00
(Husband is one owner on this account. Upon information and belief, there are 4
other owners)
Joint Bank accounts $7,800.00
(Wife removed $3,900.00 from these accounts)
1997 Blazer (Wife's vehicle) unknown
Jewelry unknown
(Husband received his jewelry after separation. Husband entered the marital residence
after separation and removed Wife's jewelry)
GM Creditcard points
unknown
(Husband used some of the marital points to purchase a new vehicle post separation)
The value given for the marital residence is the amount given in a recent
appraisal. Defendant maintains the value is less than the appraised value due to the
significant cost of repairs that have been done and are needed.
2
We have assumed that the parties will each retain as their separate property the
personal property and household furnishings currently in their possession, we have not
included the value of any of these items in the marital estate.
III. STATEMENT OF MARITAL LIABILITIES
Marital Liabilities Amount
ABN Mortgage unknown
GM Creditcard $1,209
(Paid by Wife; however, Husband continued to charge on this card after
separation)
Ford Citi card $3,055.30
(Wife made payments from June, 2003 through February, 2004. Husband took
over the payments in February, 2004. Wife does not know if any additional debt was
added to this card)
Septic Back up $1,000.00
(Paid by Wife)
Township mandated sewer connection $9,400.00
(Being paid by Wife)
Heating/cooling system repair $4,200.00
Driveway repair unknown
For the items with an unknown value, Defendant will provide statements for the
items in her name, possession and control. It is requested that Plaintiff provide
statements for the items in his name, possession and control.
All of the debts listed above were incurred during the marriage and prior to the
parties' separation, and should, for that reason, be included in the marital estate.
3
IV. PROPOSED RESOLUTION
The following resolution is suggested:
(1) The marital residence be awarded to Defendant after
deducting the realtor's commission and closing costs and costs of repairs
indicated above from the proceeds;
(2) Ms. Wolf should receive 60% of the assets, while Mr. Wolf
will receive 40% of the assests;
(3) Ms. Wolf be awarded her counsel fees; and
(4) Ms. Wolf be awarded alimony for a period of time given
the length of the parties' marriage and the fact that when the parties
separated, Ms. Wolf was a stay at home mother and had to re-enter the
work force, thus her income earning potential is significantly less than Mr.
Wolf's.
V. WITNESSES
Ms. Wolf does not plan to employ an expert witness. She anticipates that the only
fact witnesses at trial will be herself and Mr. Wolf. Ms. Wolf reserves the right,
however, to call rebuttal witnesses as needed, and to supplement this list of witnesses if
necessary.
VI. EXHIBITS
The exhibits Ms. Wolf anticipates using are the following and will be produced
closer to trial:
A. Credit card statements showing the parties' debt as of the
date of separation and any additional debt put on the joint cards post
separation;
B. The parties' federal, state and local income tax returns for
2003 - present;
C. Mr. and Ms. Wolf's most recent pay stubs;
D. Current statement for the mortgage;
4
E. Summary of all sums paid by Ms. Wolf toward marital debt
since separation;
F. Statements showing the values of the various accounts
listed previously as of the date of separation and currently; and
G. Any exhibits needed to rebut claims made by Mr. Wolf.
Mr. Wolf should have copies of most of the foregoing exhibits as the parties have
voluntarily exchanged some information. Any that he does not have will be made
available to his Counsel prior to the hearing. Ms. Wolf reserves the right to supplement
this exhibit list, if necessary.
VII. INCOME AND EXPENSES
Ms. Wolf is providing Mr. Wolf with her income and expense statement filed in
this matter and has previously provided proof to him of her current income as the parties
came to an agreed upon support order at the beginning of this year.
VIII. ESTIMATED LENGTH OF HEARING
If this matter proceeds to a hearing, then Ms. Wolf estimates that the hearing will
take one half to one full day.
DATED: October 1, 2007
Of Counsel
BECKLEY & MADDEN
212 N. 3rd Street
P.O. Box 11998
Harrisburg, PA 17108
(717)233-7691
Respectfully submitted,
Aabeth ui e
omas . Bec , squire
Attorneys for Defendant
Karen Marie Wolf
5
CERTIFICATE OF SERVICE
I, Elizabeth S. Beckley, Esquire, hereby certify that a true and correct copy of the
foregoing document was this day served upon the person and in the manner indicated
below.
SERVICE BY FIRST CLASS MAIL:
Diane M. Dils, Esquire
Dils & Dils
1400 North Second Street
(First Floor Front)
Harrisburg, PA 17102
DATED: 14e11zth S. B c it
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TIMOTHY ALLEN WOLF,
Plaintiff
VS.
KAREN MARIE WOLF,
Defendant
. THE COURT OF COMMON PLEAS OF
. CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04 - 1505 CIVIL
. IN DIVORCE
TO: Diane M. Dils
Elizabeth S. Beckley
, Attorney for Plaintiff
, Attorney for Defendant
DATE: Tuesday, August 21, 2007
CERTIFICATION
[ ] I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
I
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
The parties met in January and agreed to voluntarily exchange information. To
date, we haven't received any documentation from Plaintiff.
We will need statements on all marital assets and liabilities from the date of
marriage, the date of separation and currently.
We anticipate that they will be provided before trial.
/n-/ 0-19T
DATE
UN L FOR P )
COUNSEL FOR DEFENDAN ( )
NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
CERTIFICATE OF SERVICE
I, Elizabeth S. Beckley, Esquire, hereby certify that a true and correct copy of the
foregoing document was this day served upon the person and in the manner indicated
below.
SERVICE BY FIRST CLASS MAIL:
Diane M. Dils, Esquire
Dils & Dils
1400 North Second Street
(First Floor Front)
Harrisburg, PA 17102
i
DATED:
iza th Neckl V
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n {tip
.. -?
i C-1
_r
6. The hearing is expected to take 1 - 1 1/2 days.
7. Additional information, if any, relevant to the motion: None.
DATED: Respectfully submitted,
of Counsel
BECKLEY & MADDEN
212 North Third Street 6E1izaKeth
P.O. Box 11998
Harrisburg, PA 17108
(717) 233-7691
Z,fhomas eckley
ORDER APPOINTING MASTER
AND NOW this qQ? day of 0 tfilbt? , 2007, E. Robert Elicker, Il,
Esquire, is appointed master with respect to the following claims: counsel fees, costs and
expenses and alimony.
BY 7T
r
J.
MOVING PARTY
Name: Karen Marie Wolf
v Atty's Name: Elizabeth S. Beckley
Atty Address:
BECKLEY & MADDEN
212 North Third Street
P.O. Box 11998
Harrisburg, PA 17108
(717) 233-7691
00 lies fn5.c1C(_,
l DV'4lD
/ 7
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2
NON-MOVING PARTY
Name: Timothy Allen Wolf
V'Atty's Name: Diane M. Dils
Atty Address:
Dils & Dils
1400 North Second Street
(First Floor Front)
Harrisburg, PA 17102
(717) 233-8743
?-- ? >-
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c??:
10/02/2009 13:53 FAY 7172332567 DILS & DILS 0 001
TIMOTHY ALLEN WOLF,
Plaintiff
vs.
KAREN MARIE WOLF,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2004 - 1505 Civil Term
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 8, 2004,
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing and service of the Complaint.
3. 1 consent to the entry of a final Decree in 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 made herein are made subject to the penalties of 18 Pa, C.S. 44904, relating to unswom
falsification to authorities.
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER SECTION
3301(c) OF THE DIVORCE CODE
I . T consent to the entry of a final Decree in Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or
expenses if 1 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 Waiver are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification
to authorities.
Date:
ALE -- ffilCE
OF THE PROTHONOTAPY
1009 OCT -2 PM 3: 13
1 itJjY? . L- yJ u -IuUN i 1
PENNSYLVANIA,
10/02/2009 13:53 FAX 7172932567 DILS & DILS Q] 002
TIMOTHY ALLEN WOLF,
Plaintiff
vs.
KAREN MARIE WOLF,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2004 -1505 Civil Term
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was tiled on Aril 8,
2004.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing and service of the Complaint.
3. 1 consent to the entry of a final Decree in 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 made herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn
falsification to authorities.
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER SECTION
3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree in Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or
expenses if 1 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 Waiver are true and correct. 1 understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification
to authorities.
Date: I ) "-
OF THE PROTHONOTARY
2009 OCT -2 PM 3= 13
Cumbll- -,L-.? -bO ?''.?UNIsY
PFNNSYLVANfA
TIMOTHY ALLEN WOLF, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 04 - 1505 CIVIL
KAREN MARIE WOLF,
Defendant IN DIVORCE
ORDER OF COURT
AND NOW, this Y day of l ? ,
2009, counsel and the parties having entered into an agreement
and stipulation resolving the economic issues on October 2,
2009, the date set for a conference, the agreement and
stipulation having been transcribed and signed by the parties,
the appointment of the Master is vacated and counsel can
conclude the proceedings by the filing of a praecipe to
transmit the record with the affidavits of consent and waivers
of the parties so that a final decree in divorce can be
entered.
BY THE COURT,
?,.. 1 C.v}
Edgar B. Bayley, P.J.
cc: Diane M. Dils
Attorney for Plaintiff
'Elizabeth S. Beckley
Attorney for Defendant t lez enz L LL
f
?q
jft
2009 P!07 30 '1 :{ 10: 2I,
GLii.' . i?
OF THE 1 i fVHV»Vl
2010 JAN -5 AN 11: 57
IPJABM:94D QTY
PQMn, MA
TIMOTHY ALLEN WOLF IN THE COURT OF COMMON PLEAS
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
VS.
KAREN MARIE WOLF
Defendant NO. 2004-1505 CIVIL TERM
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:
( X ) Irretrievably breakdown under Section ( X ) 3301(c)
Strike out inapplicable section)
2. Date and manner of service of the complaint: Acceptance of Service by
Defendant, April 15, 2004.
3. [Complete either Paragraph (a) or (b).]
(a) Date of execution of Affidavit of Consent required by Section
3301(c) of the Divorce Code by Plaintiff, October 2, 2009; by
Defendant, October 2, 2009
(b) (1) Date of execution of the affidavit required by Section
3301 (d) of the Divorce Code: N/A.
(2) Date of filing and service of the Plaintiff's affidavit upon
the respondent: N/A
4. Related claims pending: None.
5. Complete either (a) or (b)
(a) Date and manner of service of the notice of intention to file
praecipe to transmit record; N/A
(b) Date of Plaintiff s Waiver of Notice in 3301(c) Divorce was
filed with the Prothonotary: October 2, 2009
Date Defendant's Waiver of Notice in 3301(c) divorce was
filed with the Prothonotary: October 2, 2009
Respectfully submitted,
BY
Diane M. Dils, Esquire
1400 N. Second Street
Harrisburg, PA 17102
(717) 232-9724
I.D. No. 71873
Date: January 4, 2010
OF THE WgATMY
2010 JAN -g AM 11 s 56
TIMOTHY ALLEN WOLF,
Plaintiff
vs.
KAREN MARIE WOLF,
Defendant
OAftRL44) CO-M
PDNN5A"
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2004 - 1505 Civil Term
CIVIL ACTION - LAW
IN DIVORCE
ACCEPTANCE OF SERVICE
I, Karen M. Wolf, hereby accept service of the Complaint in Divorce under
Section 3301(c) of the Divorce Code on behalf of Karen Marie Wolf, the
Defendant, on the 15 day of April 2004.
BY:
, ?L -w
A aren M. W f
1 629 Airport Drive
Mechanicsburg, PA 17050
OF 71'fEH OARY
2010 JAN -5 AM 11: 57
PENNSUANA
TIMOTHY ALLEN WOLF IN THE COURT OF COMMON PLEAS
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
VS. .
KAREN MARIE WOLF
Defendant NO. 2004-1505 CIVIL TERM
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:
( X ) Irretrievably breakdown under Section ( X ) 3301(c)
Strike out inapplicable section)
2. Date and manner of service of the complaint: Acceptance of Service by
Defendant, April 15, 2004.
3. [Complete either Paragraph (a) or (b).]
(a) Date of execution of Affidavit of Consent required by Section
3301(c) of the Divorce Code by Plaintiff, October 2, 2009; by
Defendant, October 2, 2009
(b) (1) Date of execution of the affidavit required by Section
3301 (d) of the Divorce Code: N/A.
(2) Date of filing and service of the Plaintiff's affidavit upon
the respondent: N/A
i
4. Related claims pending: None.
5. Complete either (a) or (b)
(a) Date and manner of service of the notice of intention to file
praecipe to transmit record; N/A
(b) Date of Plaintiff's Waiver of Notice in 3301(c) Divorce was
filed with the Prothonotary: October 2, 2009
Date Defendant's Waiver of Notice in 3301(c) divorce was
filed with the Prothonotary: October 2, 2009
Respectfully submitted,
BY
Diane M. Dils, Esquire
1400 N. Second Street
Harrisburg, PA 17102
(717) 232-9724
I.D. No. 71873
Date: January 4, 2010
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
TIMOTHY ALLEN WOLF
V.
KAREN MARIE WOLF : NO.
2004 - 1505 CIVIL TERM
DIVORCE DECREE
AND NOW, e?s IZ'' Zbr 0 , it is ordered and decreed that
TIMOTHY ALLEN WOLF
KAREN MARIE WOLF
, plaintiff, and
defendant, are divorced from the
bonds of matrimony.
Any existing spousal support order shall hereafter be deemed an order for
alimony pendente lite if any economic claims remain pending.
The court retains jurisdiction of any claims raised by the parties to this action
for which a final order has not yet been entered. Those claims are as follows: (If no
claims remain indicate "None.")
/l/ dA1 r
By the Court,
Attes .
Prothono ary
T
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