HomeMy WebLinkAbout00-05004IN THE COURT OF COMMON PLEAS
Merle K. Ludwig, Jr.,
Plaintiff
VERSUS
Tierna J. Ludwig,
Defendant
DECREE IN
No. 5004 Civil Term 2000
DIVORCE
AND NOW, ?L, `lrvt'iy T ??? , IT IS ORDERED AND
DECREED THAT Merle K. Ludwig, Jr. , PLAINTIFF,
AND
Tierna J. Ludwig
,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;
None.
By THE COURT:
,TTE : J.
' PROTHONOTARY
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MERLE K. LUDWIG, JR., IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. No. 00 - 5004 Civil Term
TIERNA J. LUDWIG, ACTION IN DIVORCE
Defendant
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information to the Court for entry
of a divorce decree:
Code.
1. Ground for divorce: irretrievable breakdown under §3301 (c) of the Divorce
2. Date and manner of the service of the Complaint: Delivered by certified mail,
restricted delivery. return receipt requested, delivered on: Ju 4?, D,(, ?.OOp
3. Date of execution of the affidavit of consent required by 3301(c) of the
Divorce Code:
By Plaintiff: M 0 y a 9" C?k, pp
By Defendant: Zv 1? f 7 j®® I
4. Related claims pending: None.
5. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the
Prothonotary: /9-,
Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the
Prothonotary: /1l 301 a00 1
Date: 8, as, ® 1
Ja a Adams, Esquire
I.D No. 79465
South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
Attorney for Plaintiff
MERLE K. LUDWIG, JR.,
Plaintiff
VS.
TIERNA J. LUDWIG,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 50- S'U oy
ACTION IN DIVORCE
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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 proceed without you and a decree of divorce or annulment may be entered against you by the
Court. A judgment may also be entered against you for any other claim or relief requested in
these papers by the Plaintiff. You may lose money or property or other rights important to you,
including custody or visitation of your children.
Where the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is available at the
Office of the Prothonotary, Cumberland County Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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
MERLE K. LUDWIG, JR.,
Plaintiff
vs.
TIERNA J. LUDWIG,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. GU - 5 vv-F eu; d
ACTION IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Merle K. Ludwig, Jr., an adult individual, who has resided at 921 Trindle
Road, Mechanicsburg, Cumberland County, Pa. 17055, since 1998.
2. Defendant is Tierra J. Ludwig, an adult individual, who has resided at 600 Bay St.,
Mechanicsburg, Cumberland County, Pa. 17055, since 1977.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at
least 6 months immediately previous to the filing of this Complaint.
4. The Plaintiff and the Defendant were married on March 21, 1970 in Cumberland
County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. Plaintiff has been advised that counseling is available and that plaintiff may have the
right to request that the court require the parties to participate in counseling; however, Plaintiff
waives his right for counseling.
Plaintiff and Defendant had one child together, Merle K. Ludwig, III, who is an adult
individual and is 29 years old.
8. Plaintiff and Defendant are both citizens of the United States of America.
9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States
of any of its allies.
10. The Plaintiff avers that the grounds on which this action is based are: That the
marriage is irretrievably broken.
WHEREFORE, Plaintiff requests the court to enter a decree in divorce.
I verify that the statements made in this Complaint are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn
falsification to authorities.
e K. Ludwig, Jr., Plaintiff
Respectfully submitted,
Date: `" \ 3 - 0-0
n¢ Adams, squire
. No. 79465
7 South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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MERLE K. LUDWIG, JR., IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. : No. 00 - 5004 Civil Term
TIERNA J. LUDWIG, ACTION IN DIVORCE
Defendant
AFFIDAVIT OF CONSENT
1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on July 17, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed
from the date of the filing and service of the Complaint.
3. 1 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 also understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification
to authorities.
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Merl K. Ludwig, Jr., Plaintiff
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER §3301(c) OF THE DIVORCE CODE
1. 1 consent to entry of a final decree of divorce without notice.
2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or
expenses if I do not claim there before a divorce is granted.
3. 1 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 18 Pa. C.S. §4904 relating to unsworn falsification
to authorities.
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Date: S ap,
/ a 0 erl K. Ludwig, Jr., PI intiff
MERLE K. LUDWIG, JR.,
Plaintiff
vs.
TIERNA J. LUDWIG,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000-5004 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
17 July 2000 and was served upon the Defendant on or about 26 July 2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing of the complaint and the date of service of the
complaint on the Defendant.
3. 1 consent to the entry of a final decree in divorce either after service of a Notice of
Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of
Intention to Request Entry of the Decree.
4. 1 have been advised of the availability of marriage counseling and understand that
the Court maintains a list of marriage counselors and that I may request the Court to require
my spouse and I to participate in counseling and, being so advised, do not request that the
Court require that my spouse and I participate in counseling prior to the divorce becoming
final.
I verify that the statements made in this Affidavit are true and correct and 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 TIERNA J. L CG
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MERLE K. LUDWIG, JR.,
Plaintiff
vs.
TIERNA J. LUDWIG,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000-5004 CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. 1 consent to the entry of a final decree in divorce without notice.
2. 1 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.
3. 1 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 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
TIERNA J. U WIG
MERLE K. LUDWIG, JR., IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. : No. 00 - 5004 Civil Term
TIERNA J. LUDWIG, ACTION IN DIVORCE
Defendant
AFFIDAVIT OF SERVICE
AND NOW, this July 31, 2000, I, Jane Adams, Esquire, hereby certify that
on July 26, 2000, a true and correct copy of the NOTICE TO DEFEND and COMPLAINT were
served, via certified mail, restricted delivery, return receipt requested, addressed to:
Tierna Ludwig
600 Bay St.
Mechanicsburg, Pa. 17055
DEFENDANT
Respectfully Submitted:
ane Adams, Esquire
I.D. No. 79465
117 South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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MERLE K. LUDWIG, JR.,
Plaintiff
VS.
TIERNA J. LUDWIG,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 00-5004 CIVIL TERM
IN DIVORCE
DEFENDANT'S PETITION FOR ECONOMIC RELIEF
AND NOW comes the above-named Defendant, by her attorney, Samuel L. Andes,
and makes the following Petition for Economic Relief:
COUNT I - EQUITABLE DISTRIBUTION
1. During the course of the marriage, the parties have acquired numerous items of
property, both real and personal, which are held in joint names and in the individual names
of each of the parties hereto.
WHEREFORE, Defendant prays this Honorable Court, after requiring full disclosure by
the Plaintiff, to equitably divide the property, both real and personal, owned by the parties
hereto as marital property.
COUNT II - ALIMONY
2. Defendant lacks sufficient property to provide for her reasonable needs in
accordance with the standard of living of the parties established during the marriage.
3. Defendant is unable to support herself in accordance with the standard of living of
the parties established during the marriage through appropriate employment.
4. The Plaintiff is employed and enjoys a substantial income from which he is able to
contribute to the support and maintenance of Defendant and to pay her alimony in
accordance with the Divorce Code of Pennsylvania.
WHEREFORE, Defendant prays this Honorable Court to enter an Order awarding
Defendant from Plaintiff permanent alimony in such sums as are reasonable and adequate to
support and maintain Defendant in the station of life to which she has become accustomed
during the marriage.
COUNT III - ALIMONY PENDENTE LITE
5. Defendant is without sufficient income to support and maintain herself during the
pendency of this action.
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6. Plaintiff enjoys a substantial income and is well able to contribute to the support
and maintenance of Defendant during the course of this action.
WHEREFORE, Defendant prays this Honorable Court to order Plaintiff to pay her
reasonable alimony pendente lite during the pendency of this action.
COUNT IV - COUNSEL FEES AND EXPENSES
7. Defendant is without sufficient funds to retain counsel to represent her in this
matter.
8. Without competent counsel, Defendant cannot adequately prosecute her claims
against Plaintiff and cannot adequately litigate her rights in this matter.
9. Plaintiff enjoys a substantial income and is well able to bear the expense of
Defendant's attorney and the expenses of this litigation.
WHEREFORE, Defendant prays this Honorable Court to order Plaintiff to pay the legal
fees and expenses incurred by Defendant in the litigation of this action.
I verify that the statements made in this Petition for Economic Relief are true and
correct. I understand that any false statements in this Petition are subject to the penalties of
18 Pa. C.S. 4904 (unsworn falsification to authorities).
DATE: 2Z Sep 2s7 c7c7
TIERNA J. LU IG
L. Andes
Attorney for Defendant
Supreme Court ID 17225
525 North 12th Street
Lemoyne, PA 17043
IN'TBE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Merle K. Ludwi,ga Tr_
Plaintiff
VS.
Tierna J. Ludwig,
NO. 5004 s -_ 2000
MOTION FOR APPOINTMENT OF MASTER (:
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Plaintiff (Plaintiff) Defendant), moves the coj#F toFippotht
a master with respect to the following claims: -%
( ) Divorce Grounds: 3301d. (x) Distribution of
i6erCy
( ) Annulment (x) Support _
'_- -
(x ) Alimony ( x) Counsel Fees --'
(x ) Alimony Pendente Lite (x) Costs and Expenss_ - "
and in support of the motion states:
(1) Discpvery is complete as to the claims(s) for which the
appointment of a master is requested.
(2) The defendant has (LKs VjW appeared in the action (personally)
(by his attorney, Samuel L. Andes, ,Esquire).
'(3) The staturory ground(s). for divorce (is) (are) 3301d
date of separation August 1 398.
(u) Delete the inapplicable paragrapnls):
(a) The action is not contested.
(b) An agreement has been reached with respect to the
following claims:
(c) The action is contested with respect to the following
claims: `
(5) The action ( (does not involve) complex issues of law
or fact.
(6) The hearing is expected to take 3 (hours) (IFS.
(7) "' Additional information, if any. relevant to the motion:
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Ludwig
(Plain !izf),M-brie K.
(Defendant)
ORDER APPOINTING MASTER
AND NOW WAX 02
Esquire,
is appointed master with respect to the following claims:
By the C **04?
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MERLE K. LUDWIG, JR.,
Plaintiff
VS.
TIERNA J. LUDWIG,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00 - 5004 CIVIL
IN DIVORCE
ORDER OF COURT
AND NOW, this day of
2001, the parties and counsel having entered into a
agreement and stipulation resolving the economic issues on
April 6, 2001, the date set for a four-party conference, the
agreement and stipulation having been transcribed, and
subsequently signed by the parties and counsel, 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 of the
parties so that a final decree in divorce can be entered.
BY THE COURT,
J.
cc: Jane Adams
Attorney for Plaintiff
Samuel L. Andes
Attorney for Defendant
5_Vil01
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MERLE K. LUDWIG, JR., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
Vs. NO. 00 - 5004 CIVIL
TIERNA J. LUDWIG,
Defendant IN DIVORCE
THE MASTER: Today is Friday, April 6, 2001.
This is the date we had set for a conference with counsel and
the parties to discuss the outstanding economic issues.
Present are the Plaintiff, Merle K. Ludwig,
Jr., and his counsel Jane Adams, and the.Defendant, Tierna J.
Ludwig, and her counsel Samuel L. Andes.
This action was commenced by the filing of a
divorce complaint on July 17, 2000, raising grounds for
divorce of irretrievable breakdown of the marriage. The
Master has been advised that the parties are going to sign
affidavits of consent and waivers of notice of intention to
request entry of divorce decree so that the divorce can be
concluded under Section 3301(c) of the Domestic Relations
Code.
On September 26, 2000, wife filed a petition
raising economic claims of equitable distribution, alimony,
alimony pendente lite, and counsel fees and expenses.
The parties were married on March 21, 1970,
and separated August 19, 1998.
The filing shows that an affidavit of
separation dated September 1, 2000, was clocked in in the
Prothonotary's office on September 5, 2000, signed by Mr.
Ludwig stating that the date of separation was in August of
1998. Inasmuch as the parties are going to consent to the
divorce, we do not need to proceed with the Section 3301(d)
requiring a separation in excess.of two years.
The Master has been advised that the parties
have reached a settlement with respect to the outstanding
economic issues. An agreement is going to be placed on the
record in the presence of the parties. The agreement as
placed on the record will be considered the substantive
agreement of the parties not subject to any changes or
modifications except for correction of typographical errors
which may be made during the transcription.
Following the statement of the agreement on
the record, the agreement is going to be transcribed and sent
to counsel for review for typographical errors. After any
corrections of typographical errors have been made as
necessary, the parties and counsel will affix their
signatures. The signing will be simply to affirm the terms
of settlement as stated on the record at this time inasmuch as
the parties are bound by the settlement as stated on the
record when they leave the hearing room today even though
there has been no signing of the agreement.
Following receipt by the Master of a
completed copy of the agreement, the Master will prepare an
order vacating his appointment and counsel can then file a
praecipe transmitting the record to the Court requesting a
final decree in divorce. Mr. Andes.
MR. ANDES: The parties have agreed to
resolve all the economic issues arising out of their marriage
and this divorce action on the following terms:
1. Mr. Ludwig, hereinafter referred to as husband, will
transfer to Mrs. Ludwig, hereinafter referred to as wife, the
marital residence situate at 600 Bay Street, in Mechanicsburg,
Cumberland County, Pennsylvania. Wife's attorney shall
prepare a deed and submit it to husband's attorney. Husband
will execute the deed and return it to wife's attorney within
thirty (30) days of today's date.
2. The property at 600 Bay Street is currently encumbered
by a home equity loan owed to PNC Bank on which there is a
balance of approximately $19,000.00 or $20,000.00 owed at the
present time. Husband shall pay and satisfy that home equity
loan in accordance with its terms, by making all payments due
under that loan and debt until it is paid in full and husband
shall further indemnify and save harmless wife from any loss,
cost, or expense caused to him by his failure to pay and
satisfy that obligation in accordance with its terms.
Further, husband shall make reasonable and continuing efforts
to arrange to have the residence at 600 Bay Street refinanced
and wife removed from any liability for the lien of that debt,
it being the intention of the parties that wife and the
property be released from the lien as soon as conveniently
possible. To the extent that husband is entitled to claim a
deduction for the interest paid on the home equity loan, he.
shall be entitled to do so and wife will not claim such a
deduction as a result of payments made by husband. Further,
wife shall cooperate in husband's efforts to obtain
refinancing of the property and any efforts he makes to deduct
the interest.
3. Husband has pension benefits with his present employer,
Fry Communications, and with a prior employer, Hempt Brothers,
Inc. Wife does hereby waive, release, and relinquish any
claim to or interest in those pension benefits and confirms
them to be the sole and separate property of husband free of
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any further claim by her.
4. With the exception of some items of personal interest
to husband, which the parties will identify and agree upon
within thirty (30) days, all of the household furnishings and
other contents of the residence at 600 Bay Street in
Mechanicsburg shall be and remain the sole and separate
property of wife, and husband hereby waives and releases any
further claim to them.
5. The parties shall divide and distribute the motor
vehicles they own as follows:
A) Wife shall be and remain the owner of the 1991
Buick automobile currently operated by her or any proceeds of
its sale;
B) Husband shall be and remain the owner of the 1984
Chevrolet pickup truck currently operated by him or any
proceeds of its sale;
C) Husband shall be and remain the owner of the 1998
Harley Davidson motorcycle currently titled in his name free
of any further claim by wife, to include the proceeds of the
sale of that vehicle;
D) Husband shall be and remain the owner of the 1936
antique Ford automobile now located at the garage at the
residence at 600 Bay Street, Mechanicsburg, Pennsylvania, free
of any further claim by wife, to include any proceeds of its
sale. Further, husband shall remove that vehicle from the
residence on or before the 7th day of May 2001.
The parties will make, execute, acknowledge, and
deliver any title documents or other documents required to
confirm ownership of the vehicles in accordance with this
paragraph. The parties represent that, except for the Harley
Davidson motorcycle, none of the vehicles are encumbered or
subject to any debt. Husband acknowledges that the Harley
Davidson motorcycle is subject to a debt in his own name alone
and he agrees that he shall pay and satisfy that debt in
accordance with its terms and shall indemnify wife and save
her harmless from any loss, cost, or expense caused to her by
his failure to do so.
6. Husband has tools and related automobile equipment and
similar items in the garage at 600 Bay Street in
Mechanicsburg. The parties have agreed that wife shall retain
bicycles, a snow blower, and assortment of yard tools, and
various other household items which are located in the garage
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but that the other items shall be and remain the property of
husband, who shall remove them from the garage no later than
the 7th day of may 2001. The parties will cooperate to
arrange a convenient time for him to come and remove those
items.
7. The parties currently owe a credit card debt to Bank
Card Services of Wilmington, Delaware, on which the balance
owed at this time is approximately $2,750.00. Husband shall
pay and satisfy that debt in accordance with its terms and
shall indemnify and save wife harmless from any loss, cost or
expense caused to her by his failure to do so. The parties
both represent that neither of them have incurred any charges
on that account since the date of separation and the parties
agree that neither of them shall incur any debts on that
account after the date of this agreement. As soon as possible
after today, that account will be closed and neither party
shall have rights to use it in the future. Both parties will
cooperate to change the address on the account and close the
account as soon as practical after today.
8. Husband and wife are parties to an action for spousal
support currently pending before this Court and filed to No.
719 S 2000 (PACES NO. 033102553), which obligates husband to
make a monthly payment of approximately $725.00 per month.
The parties agree that, as of today, the arrearage on that
order shall be adjusted to be $500.00 and that husband shall
make the payments due on that order through the end of April
2001. The order shall terminate effective 30 April 2001 and
husband shall have no obligation to make payments on the order
thereafter other than any arrearages owed at that time. Both
parties shall notify the Domestic Relations Office that the
order is to be terminated after the payment of any arrearages
and husband agrees and promise to make payment of all
arrearages under that order no later than 31 May 2001.
Otherwise, both parties waive any further claim against the
other to spousal support, alimony pendente lite, or alimony,
such waiver to be effective upon the entry of a final decree
in divorce by this Court.
9. Husband shall pay wife the sum of $2,400.00 as part of
the equitable distribution of marital property in this case.
Husband shall make that payment no later than 6 June 2001
directly to wife.
10. With the exception of the provisions of this agreement,
each of the parties waives any further right to have their
marital property divided or distributed by the Court or to
participate in litigation before this Court regarding the
distribution and division of their property or the assignment
of their debts and obligations.
11. Further, each party hereto waives any further claim to
counsel fees, expenses, or any other economic benefit due them
under the Divorce Code.
12. Both parties acknowledge that they are represented by
attorneys and that they have had a full and ample opportunity
to discuss the economic aspects of this case with their
attorney and to get information about the assets and
liabilities of the parties so that they have entered into this
agreement fully informed both as to their rights and as to the
assets and liabilities which are affected by this agreement.
Knowing that, the parties voluntarily waive the right to have
the Court make any further distribution of their assets which
will award any alimony, alimony pendente lite, counsel fees
and expenses, or spousal support.
13. The parties will conclude this divorce by filing
consents which shall be filed by both parties no later than
the 7th day of May 2001. At the time the Court enters a final
decree in divorce, the Court shall incorporate this agreement
into the decree but this agreement shall not merge into that
decree and shall be fully enforceable by the parties as a
contract or by subsequent Court order as permitted by the
divorce code.
14. Except as herein otherwise provided, each party may
dispose of his or her property in any way and each party
hereby waives and relinquishes any and all rights he or she
may now have or hereafter acquire under the present or future
laws of any jurisdiction to share in the property or the
estate of the other as a result of the marital relationship
including without limitation, statutory allowance, widow's
allowance, right of intestacy, right to take against the will
of the other, and right to act as administrator or executor in
the other's estate. Each will at the request of the other
execute, acknowledge, and deliver any and all instruments
which may be necessary or advisable to carry into effect this
mutual waiver and relinquishment of all such interest, rights,
and claims.
MR. ANDES: Mrs. Ludwig, you've been sitting
here the whole time that I talked, did you hear what I said?
MRS. LUDWIG: Yes.
MR. ANDES: Do you understand it?
MRS. LUDWIG: Yes.
MR. ANDES: Do you have any questions about
it?
MRS. LUDWIG: No.
MR. ANDES: Is it what we discussed today?
MRS. LUDWIG: Yes.
MR. ANDES: And we've been here for a little
over an hour and you and I have met numerous times before, are
you satisfied that you understand what we are doing?
MRS. LUDWIG: Yes.
MR. ANDES: And are you satisfied to settle
the case on these terms?
MRS. LUDWIG: Yes.
MS. ADAMS: Merle, you've been siting here
for the better part of an hour, did you hear everything that
Mr. Andes said?
MR. LUDWIG: Yes, ma'am.
MS. ADAMS: Did you understand everything
that he said?
MR. LUDWIG: Yes, ma'am.
MS. ADAMS: Do you agree to everything in the
agreement?
MR. LUDWIG: Yes, ma'am.
MS. ADAMS: Do you have any questions
regarding the agreement?
MR. LUDWIG: No, ma'am.
I acknowledge that I have read the above
stipulation and agreement, that I understand the terms of
settlement as set forth herein, and that by signing below I
ratify and affirm the agreement previously made and intend to
bind myself to the settlement as a contract obligating myself
to the terms of settlement and subjecting myself to the
methods and procedures of enforcement which may be imposed by
law and in particular Section 3105 of the Domestic Relations
Code.
WITNESS: DATE:
01 V,--O
U ` C1
ane Adams Me le K. Ludwig, Jr.
ttorney for Plaintiff
Sam 1 L. Anhes Tierna J. udwig V
Attorney for Defendant
MERLE K. LUDWIG, JR., : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : No. 00 - 5004 Civil Term
TIERNA J. LUDWIG, ACTION IN DIVORCE
Defendant
AFFIDAVIT OF SEPARATION
1. The parties to this action separated in August 1998 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 my 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. §4904 relating to unworn
falsification to authorities.
Date: l ' COO ddA-9-, o n o
Merl K. Ludwig, Jr.
ah?a4br - au?us' ...
L_a
C6
CT, zo
MERLE K. LUDWIG, JR., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 00 - 5004 CIVIL
TIERNA J. LUDWIG,
Defendant IN DIVORCE
TO: Jane Adams Attorney for Plaintiff
Samuel L. Andes Attorney for Defendant
DATE: Monday, October 30, 2000
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
yTn T1'rnnnvs+? nrenT C'TL' CIIJ
(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.
66 `
.,
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
DATE
Cq' Wo-es
C0 SEL F PLAINTIFF ( )
COUNSEL FOR DEFENDANT (x )
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.
r
}
MERLE K. LUDWIG, JR.,
Plaintiff
VS.
TIERNA J. LUDWIG,
Defendant
TO: Jane Adams
Samuel L. Andes
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00 - 5004 CIVIL
IN DIVORCE
, Attorney for Plaintiff
, Attorney for Defendant
DATE: Monday, October 30, 2000
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.
r
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
1103°00
DATE
CO NSEL FOR LAINTIFF
SEL FOR DEFENDANT ( )
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.
1 ?-6T?,
MERLE K. LUDWIG, JR.,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
VS.
TIERNA J. LUDWIG,
Defendant
CIVIL ACTION - LAW
NO. 00-5004 CIVIL TERM
IN DIVORCE
DEFENDANT'S PRE-TRIAL STATEMENT
Defendant, by her attorney, Samuel L. Andes, files this Pre-Trial Statement in
accordance with Pa. R.C.P. 1920.33(b):
1. ASSETS. Attached hereto and marked as Schedule 1 is a list of the marital
assets and debts of the parties as known to the Defendant. Please note that the assets
are subject to a private agreement reached between the parties, at the time of their
separation, which provided for a division or distribution of those assets. That agreement
is addressed in Section 11 of this Pre-Trial Statement.
2. EXPERT WITNESSES. The Defendant anticipates that the parties will be able to
agree upon the identity and value of most of the assets. If they cannot, she reserves the
right to call to testify, at the hearing, the following expert witnesses:
A. A real estate appraiser to establish the value of the residence.
B. If necessary, an appraiser of personal property to establish the
value of the household furnishings and of the tools and equipment owned by
Plaintiff located at the property.
C. If necessary, an appraiser to establish the value of the Plaintiff's
antique automobile.
In addition, the Defendant reserves the right to call any other expert witnesses as may be
II necessary to respond to Plaintiff's case in chief.
Page 1 of 4
III
3. FACT WITNESSES. At this time, Defendant anticipates only calling herself as a
fact witness in the case. She reserves the right, however, to call such other fact
witnesses as may be required to respond to Plaintiff's case in chief.
4. EXHIBITS. At the hearing, Defendant anticipates offering the following exhibits
into evidence:
A. A copy of the handwritten agreement dated 9 August 1998,
signed by both of the parties, a copy of which is attached hereto.
B. A copy of the reassessment of the marital residence dated 1 July
2000, a copy of which is attached hereto.
C. A statement showing the value of the Defendant's retirement
account with FRY Communication as of 31 August 1998, a copy of which is
attached hereto and statements subsequent to that date from which the
parties or Master can calculate the present value of the marital portion of
that retirement account.
D. A statement from Hempt Bros., Inc. retirement plan showing the
present value of Plaintiff's interest within that plan. A copy of the statement
showing the value as of 1 August 2000 is attached hereto.
E. Copies of paycheck stubs and other documents to verify each of
the parties' incomes at the time of the hearing.
F. Copies of tax returns to show the parties incomes from all sources.
In addition to the above, the Defendant reserves the right to offer into evidence such
additional exhibits as may be necessary to respond to Plaintiff's case in chief, Copies of
the above exhibits are attached hereto and marked, collectively, as Exhibit 4.
5. INCOME STATEMENT. The parties appeared before the Domestic Relations
Office of Cumberland County in September of 2000 and the Domestic Relations Office
calculated the incomes of the parties. At that time, they calculated that Mr. Ludwig's
Page 2 of 4
monthly net income was $2,818.05 and Mrs. Ludwig's monthly net income was
$1,092.36. Those determinations were based upon the Income and Expense Statement
filed by Mrs. Ludwig at that conference, a copy of which is attached hereto and marked
as Exhibit 5.
6. EXPENSE STATEMENT. Please see the preceding section.
7. PENSION INFORMATION. Defendant has no pension benefits. Plaintiff has
pension benefits from his present employer, Fry Communications, Inc., and from a prior
employer, Hempt Bros., Inc. Defendant believes the Hempt Bros. pension can be valued
by a report from Hempt Bros. itself and expects that the Plaintiff will present such a
report at the hearing. Plaintiff's account in the Fry Communications retirement plan is a
defined-contribution plan and can be valued by determining the value of the account at
the time of separation and adding to that balance investment results to the time of
hearing. That is how Defendant anticipates valuing these assets.
8. COUNSEL FMS. Defendant has engaged her attorney at the rate of $175.00
per hour and anticipates that her total counsel fees, through the hearing, will exceed
$4,000.00. She will present detailed statements of those fees in support of her claim at
the hearing.
9. PERSONAL PROPERTY. Defendant believes that the parties have tentatively
agreed upon a division of the items of personal property (household furnishings and
appliances and tools). If they have not, or if there is any dispute over the value of those
items, Defendant proposes that the items all be appraised so the Master will have a value
of the items to be retained by each of the parties.
10. MARITAL DEBTS. The only marital debts known to Defendant are listed on
Schedule 1 which is attached hereto.
11. PROPOSED RESOLUTION OE ECONOMIC ISSUES. At the time they
separated the parties worked out a private agreement whereby Defendant was to get the
Page 3 of 4
marital residence, free of all debt, plus one half of Plaintiff's pensions and retirement
accounts. Plaintiff would retain his antique automobile and tools and Defendant would
receive the other contents of the house. Defendant proposes that equitable distribution
be resolved by implementing that agreement.
Defendant is not able to support herself from employment or from the marital
assets and will require alimony from Plaintiff after the date of divorce. She will also
require financial assistance to obtain medical insurance on herself. Accordingly, she
proposes that she receive alimony in the amount of $750.00 following the divorce.
Because this is a long term marriage and she has no prospects of changing her financial
situation in the foreseeable future, Defendant proposes the alimony be for an indefinite
term.
el L. Andes
Attorney for Defendant
Supreme Court ID 17225
525 North 12th Street
Lemoyne, PA 17043
(717) 761-5361
Page 4 of 4
SCHEDULE 1
Asset Value Date of Marital Portion Liens Amount of
Valuation Lien
Residence at 600 Bay $79,150.00 7/1/2000 100% (subject to Home equity loan $19,000.00
Street, parties' private owed to PNC Bank (approx.)
Mechanicsburg, PA agreement of 9
August 1998)
Plaintiffs pension with $5,502.00 8/1/2000 100% No liens known
Hempt Bros., Inc.
Plaintiffs retirement $5,067.18 11/31/1998 100% No liens known
account with Fry
Communications
Contents of home Unknown but Yet to be done 100% (subject to No liens known
believed to be agreement)
less than
$5,000.00
Husband's tools and Unknown but Yet to be done 100% No liens known
related equipment in believed to be
garage at residence in excess of
$10,000.00
1936 Antique Ford $20,000.00 or Yet to be done 100% No liens known
automobile more (approx.)
Wife's 1991 Buick Unknown Yet to be done 100% No liens known
Husband's 1984 Unknown Yet to be done 100% No liens known
Chevrolet pickup truck
1998 Harley Davidson $12,000.00 8/1998 100% This vehicle is
Motorcycle soft tail subject to a loan
model but Defendant has
no direct
knowledge of that
There are no non-marital assets of any significance known to Defendant.
Except for the above, the only debts of the parties, to Defendant's knowledge, is a PNC Bank
MasterCard which carried a balance, at the time of separation, of approximately $3,000.00. Defendant does
not know the current pay status of that debt.
_.
_V ^ ? _E
---
`t
THIS IS NOT A TAX BILL
MAILING DATE: July 1, 2000
District: 10 - HAMPDEN TOWNSHIP
School..: CUMBERLAND VALLEY SD
Location:
600 BAY STREET -
& BRANDY LANE
LOT 1 & 15 PH 3 PO 92
TAXABLE
UNIT/LOT ID..: L-0001 +
Land Size....: .28 acres
Property Types R
Residential With Buildings
Control No: 10008337
CUNZQUM'T
Pennsylvania law requires that all real estate be valued as of the most recent county-wide reassessment. The last
reassessment, or tax base year, was 1974, Since the last reassessment In 1974, properties have been assessed at 25% of the
1974 value (the 'Pre-Determined Ratio'?. The new tax base year will be the Year 2000, with the new assessed values
becoming effective for the 2001 tax year. The Pre-Determined Ratio has been changed to 100%. Your new assessed value
equals your Year 2000 market value. - - - - - - -
It is very important for you to know that when the new 2000 tax base is determined after this reassessment, all taxing
districts are required bylaw to lower the m1fiage rate by the same proportion that the tax base went up. The law
provides that In the first year after reassess ent (200 f), the county and all townships and boroughs may not increase overall
revenue by more than rive percent (5%) and school districts may not increase overall revenue by more than ten percent (10%).
The county and the other taxing bodies will make these decisions next year, and may choose not to increase overall revenue.
Of course, some individual's faxes will go up or down by more than those percentages.- The essential point is that an
increase in market values does not necessarily mean a corresponding increase in taxes. Individual changes in taxes
will depend upon a specific property's change as compared to the overall change for the taxing district.
The ESTIMATED impact statement printed below is our best estimate of change, based on 2000
COUNTY tax figures. This estimate does not include any borough, township, or school district impact.
ESTIMATED COUNTY TAX IMPACT: Current 2000 County mills = 27.500
Adjusted 2000 County mills = 1.858
Parcel Identifier:
10-22-0521-010.
2000 Assessed Value Old Assessed Value
Market Value 2000 Market x 100%) (1974 Market x 259'0
Land _ 14;250 14,250 520
Buildings 64,900 64,900 4,460
TOTAL 79,150 79,150 4,980
2000 Clean and Green Values
Land NOT NOT NOT
Buildings T
APPLICABLE 77
APPLICABLE APPLICABLE
TOTAL
Clean and Green values apply to some farm and forest land. Such values
become effective only upon application and approval. All applications must be
received by the Assessment Office by 4`.30 p.m. on October 15, 2000, Those
previously approved for Clean and Green do not need to re-apply.
$ 137 i 2000 Comity-Tax-BEFORE Reassessment:` --
$--- 147 : 2000 County Tax AFTER Reassessment.
mar= ?
FRY COMMUNICATIONS, INC. RETHIEMRNT PLAN
Employee Benefit Statement for the Period: 07101/1995 - 0813111998
Employee Employer
Deferral Match TOTAL
BEGIN BALANCE 0.00 0.00 0.00
CONTRIBUTION 4,488.36 485.28 4,973.64
LOAN 0.00 0.00 0.00
FORFEITURE 0.00 3.99 3.99
WITHDRAWAL 0.00 0.00 0.00
TRANSFER 0.00 0.00 0.00
OTHER 0.00 0.00 0.00
GAIN/(LOSS) 175.84 14.46 190.30
END BALANCE 4,664.20 503.73 5,167.93
VESTED PERCENTAGE 100} 80%
VESTED AMOUNT 4,664.20 402.98
Investment
CrabbeEq Fd Pur HeartVal LoomisS Stabval TOTAL
BEGIN BALANCE 0.00 0.00 0.00 0.00 0.00 0.00
CONTRIBUTION 1,243.67 1,243.67 248.49 497.43 1,740.38 4,973.64
LOAN 0.00 0.00 0.00 0.00 0.00 0.00
FORFEITURE 1.00 1.00 0.20 0.41 1.38 3.99
WITHDRAWAL 0.00 0.00 0.00 0.00 0.00 0.00
TRANSFER 0.00 0.00 0.00 0.00 0.00 0.00
OTHER 0.00 0.00 0.00 0.00 0.00 0.00
GAIN/(LASS) (137.38) 183.18 (11.85) 29.12 127.23 190.30
END BALANCE 1,107.29 1,427.85 236.84 526.96 11868.99 5,167.93
VESTED AMOUNT 1,085.63 1,400.19 232.23 516.68 1,832.46 5,067.18
END SHARES 77.978 75.071 8.644 44.320 1868.990
Hempt Bros., Inc. Retirement Plan
The following is the accrued benefit information for Merle Ludwig Jr:
Accrued monthly pension as of "ANW-0
Present value of above pension* as of 8- 1.2000
The accrued pension is payable at age 65.
The normal form of payment is a Life Annuity.
The accrued pension is 100% vested.
$ 144.64
$ }
?a
* The present value calculation has been made based upon the assumptions promulgated
by the. Pension Benefit Guaranty Corporation for annuity valuations. The interest
rate is 7.10% per year for 25 years followed by 6.25% per year. The mortality is
in accordance with the 1983 Group Annuity Mortality Table male rates.
Current Age : 51
Date of Birth: 9- 1.1949
(Divorce:314)
y
In the Court of Common Pleas of CUMBERLAND County,. Pennsylvania
DOMESTIC RELATIONS SECTION'
P.O. BOX 320, CARLISLE, PA. 17013
Phone: (717) 240-6225 AUGUST 11, 2000 Fax: (717) 240-6248
Plaintiff Name: TIERNA J. LUDWIG
Defendant Name: MERLE K. LUDWIG JR
Docket Number: 00719 S 2000
PACSES Case Number: 033102553
Other State ID Number:
Please note: All correspondence must include the PACSES Case Number.
Income and EMeense Statement
THIS FORM MUST BE FILLED OUT
(If you are self-employed or if you are salaried by a business of which you are owner in whole or part, you must
also fill out the Supplemental Income Statement which appears on page two of this income and expense
statement.) _ ._-
INCOME STATEMENT OF + I eP N-1 A Ll J 71 l L) l r_
Section I: Income and Insurance
INCOME: //? l 77- ?N
Employer 6&0 .,L? ea) S. t/ S.C.)rJ SU nJ 6 A-j
Address 610(o & THA i-D E PA I S 1 c oG I?AGtt6 TRL, M6Ct4-?[C
Type of Work L-Er'L UScKLtpc-;-z-
Payroll No. Gross Pay per Pay Period $ \ 0 V 5 Pay Period (wkly., bi-wkly., etc.) W K L. ? Z 30°-0 6 f?
(31- LJ KI.,J
Itemized Payroll Deductions: ?j e °t_ CQ P 1 ?S !J F t^d-?1\? I [JCs S STA TKn/1 fem.\T
Federal Withholding $ Social Security $ Local Wage Tax $
State Income Tax $ Retirement $ Savings Bonds $
Credit Union $ Life Insurance $ - Health Insurance $
$ $
Other Deductions (specify) $ $
Net Pay per Pay Period $
OTHER (Fill in Appropriate Column)
INCOME WEEK MONTH YEAR
Interest $ $ 3
Dividends
Pension
Annuity
Social Security
Rents
Royalties
Expense Account
Gifts
Unemployment
Workmen's
Compensation
Other
Other
TOTAL $ $ $ b
TOTAL INCOME $
NT-D &P1P -aV-tLN ff6t-
) ?I o
Service Typefi M /
PROPERTY Ownership
OWNED DESCRIPTION VALUE H W J
Checking Accounts 0 K DEIAL $ N:1 A/I ,
Savings Accounts 0 -06- l Q Q
Credit Union
Stocks/Bonds
Real Estate phsontj 00 0 -Az
Other
TOTAL I $ ') I -) 41
fAx. yl:a?'A?)
* H=Husband; W=Wife; J=Joint
Form IN-008
Worker ID 21206
Income and Expense Statement
PACSES Case Number 033102553
Coverage *
INSURANCE COMPANY POLICY N H T w-
Ho '
Blue Cross'
L.aJC
OSS
Other 1 Lam,
Me'
Blue Shield ;?
1e)lU 1?t
O er CokL ? uo [f
Health/Accident
Disability Income ()N (-.
Dental .
Other nlaN t
* H=Husband; W=Wife; C=Child
Section II: Supplemental Income Statement
a. This form is to be filled out by a person
? (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:
e most recent Federal Income Tax Return, and
(2) th ost recent Profit and Loss Statement
c- Name of bus as:
Address and telep number: 1
d. Nature of business (check
E] (1) partnership
? (2) joint venture
? (3) profession
? (4) closed corporation
? (5) other
e. Name of accountant, controller or er person in charg f financial records:
i
i
f. Annual income from business:
(1) How often is income received?
(2) Gross income per pay period:
(3) Net income per pay period:
(4) Specified deductions, if any:
Page 2 of3 Form IN-008
Service Type M Worker ID 21206
Income and Expense Statement
PACSES Case Number 033102553
Section III: ExiDenses
Instructions: Only show extraordinary expenses in this section unless you filled out Section II on page two. The catcgories
in BOLD FONT are especially important for calculating child support. If you are requesting Spousal Support/APL or if
you assert your case cannot be determined according to the guideline grids or formula, this section must be fully completed.
(Fill in Appropriate Column)
EXPENSES
WEEK
MONTH
YEAR
Home
Mortgage/Rent $ $ $ S
Maintenance
Utilities
Electric t) $ $ $ .
Gas p(,
Oil 3 0
Telephone ,416
.?
Water 7j 2
sewer
Em lo. eat
Public Transport. $ $ $
-
Lunch (e
Taxes
Real estate $ $ $ y
Personal Property O O
Insurance
Homeowner's $ $ (p $ 1
Automobile
Life
Accident
Health
Other
Automobile
Payments $ - $ $
Fuel 1 O
Repairs ?p
Medical
Doctor $ $ $ Z O
Dentist q-12 0
Orthodontist
Hosptal
Medicine b
-)A 3. 1 V
3
bpwm needs
(glasses, braces,
ortho devic
00
EXPENSES (Fill in Appropriate Column)
(continued) WEEK MONTH YEAR
Education
Private School $ $ $
Parochial School
College
Religious
Personal
Clothing $ $ $ ')DO
Food ( 00
BarberY
ser
3 0 O
Credit Payments
Credit Card S
Charge
Memberships
Loans
Credit Union $ $ $
Miscellaneous
Household Help $ is $
Child care
Papers/books
Ma azines
Entertainment 0
Pay TV M&L
Vacation O
Gifts Soo
Legal fees
Cha
RaIr rtable
u' ns
710
` f7 O
1
Other . d
Alimony
Payments
Other
$ $ $ 0
Total WEEK MONTH YEAR
6
Expenses: $ $ $ 2L., W?k
I verify that the statements made in this Income and Expense Statement are true and correct. I understand that false
statementsherein,{are Usubject to the criminal penalties of 18 Pa14904 , relating to unswor falsification to authorities.
Date Plaintiff or Defeo
Page 3 of 3 Form IN-008
Service Type M Worker ID 21206
jphecnj?,
MERLE K. LUDWIG, JR.,
Plaintiff
VS.
TIERNA J. LUDWIG,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 00 - 5004 Civil Term
: ACTION IN DIVORCE
PRETRIAL STATEMENT BEFORE THE DIVORCE MASTER. PURSUANT TO P
RULE OF CIVIL PROCEDURE 1920.33
I.BACKGROUND.
Plaintiff, Merle K. Ludwig, Jr., filed a Motion for Appointment of the divorce master on
October 23, 2000 to address issued raised by the Defendant's Petition for Economic Relief. The
parties were married on March 21, 1970 and lived together until August 1998. The couple has a
son, Merle K. Ludwig, III who is twenty-nine years old and currently lives on his own. The
Defendant is fifty-two Years old and works at Fry Communications. The Plaintiff is fifty-one
years old. The following information is provided pursuant to Pa. Rule of Civil Procedure
1920.33.
H. LIST OF ASSETS.
A. MARITAL HOME. The marital home is located at 600 Bay Street, Mechanicsburg,
Pa. 17055. The residence was assessed at $79,150 in 2000 and there is currently a home
equity loan with PNC bank on the home in the amount of approximately $23,303.00.
There is no other mortgage on the home. The payments on this loan are $465.49 per
month.
B. VEHICLES.
1. 1991 Buick Regal. Purchased in 1991 at a yard sale for $8,900. This vehicle
is paid off but the amount owing on the Buick Regal was consolidated into a
home equity loan on the couple's house. The loan's current balance is
approximately $23,303.00.
2. 1936 Antique Ford. Purchased "as is" in 1991 for $7,900. The vehicle runs.
Plaintiff added only lights and wiring. The vehicle needs a new radiator to be
fully functional.
3. 1984 Chevy Truck. Purchased in 1988 for the amount of $3,900. There are no
loans on this vehicle, the vehicle is paid off.
4. 1998 Harley Davidson Motorcycle. Springer soft tail model. This vehicle was
purchased by Plaintiff for $13,000.00 in April 1998, four months before the
couple's separation: The payments are $300 per month. Plaintiff had little or no
equity in this vehicle as of the date of separation.
C. PENSIONS
1. Plaintiff has a retirement plan with Hempt Bros., Inc. with an estimated value
of $5,502 as of August 1, 2000. (See Exhibit A.)
2. Plaintiff has a Fry Communications Retirement plan with an estimated value of
$5067.18 through August 31, 1998. (See Exhibit B.)
D. CONTENTS OFTHE HOME AND GARAGE
The marital home is fully furnished. The home and its contents are currently in
Defendant's possession. The value of the furnishings is unknown. There are
miscellaneous tools and equipment in the garage, including a snow blower, and
bicycles.
III. EXPERTS.
Plaintiff is not planning to present expert testimony at this time; however, reserves the
right to retain an expert at a later time.
IV. EXHIBITS.
A. Hempt Bros., Inc. Retirement Plan Statement. (Exhibit A.)
B. Fry Communications, Inc., Retirement Plan Statement. (Exhibit B.)
C. Plaintiff s 1999 Federal Income Tax Return. (Exhibit Q.
D. Plaintiff's 1999 W-2 statements. (Exhibit D.)
E. Two Paystubs from Fry Communications. (Exhibit E.) Plaintiff reserves the right to
provide more recent paystubs at the hearing.
F. Marriage Settlement Agreement as drafted and signed by parties on August 9, 1998.
(Exhibit F.).
V. GROSS INCOME.
Plaintiffs gross wages for the year 1999 were $46,164. (Please see Exhibit C, D, and E.)
However, this income was based on Plaintiff working approximately 65 hours a week. Plaintiff
is currently fifty-one years old and due to health concerns is anticipating that he will not be able
to continue to work as a laborer for 65 hours a week. Plaintiffs hours have already started to
decrease along with his income. Plaintiff reserves the right to provide current paystubs at the
hearing.
VI. TESTIMONY.
It is anticipated that the Plaintiff will testify on his own behalf. He will testify with
regard to all relevant factors regarding the marital property and his personal income.
VII. PENSIONS.
A. Plaintiff currently has a Hempt Bros., Inc., Retirement plan which was valued at
$5,502 on August 1, 2000. (See Exhibit A.)
B. Plaintiff currently has a Fry Communications, Inc. Retirement Plan which was valued
at $5067.18 through August 31, 1998. (See Exhibit B.)
VIII. COUNSEL FEES.
Plaintiff has not made a claim for counsel fees.
IX. PERSONAL PROPERTY.
Defendant has retained possession of all items within the marital home and garage.
Plaintiff would like to obtain his tools and equipment from the garage.
X. MARITAL DEBTS.
A. There is currently a home equity loan with PNC bank on the home in the amount of
approximately $23,303.00. The payments on this loan are $465.49 per month. The
couple's 1991 Buick, which is currently in Defendant's possession, was financed with
this loan.
B. There is currently a PNC Mastercard balance of $3,000.
XI. PROPOSED RESOLUTION.
Defendant provided Plaintiff with a copy of a marriage settlement agreement drafted and
signed by'the parties on August 9, 1999. (See Exhibit F). This agreement did not contemplate
alimony or spousal support. However, Defendant filed for spousal support and is currently
receiving support in the amount of approximately $700 a month.
Defendant has proposed that she receive title to the marital home and retain all its
contents, as well as retain her 1991 Buick. Plaintiff would retain his pension, his antique car, his
motorcycle, his Chevy, and a few tools from the garage. The home equity loan would be split,
and Defendant would pay off the PNC credit card. In addition, Defendant has asked for $700
alimony for an indefinite term.
Plaintiff feels that this is an unreasonable settlement proposal. Under this proposal,
Plaintiff would relinquish approximately 90% of the marital asssets, pay off approximately 50%
of the marital debts, (including a home equity loan which paid off Defendant's Buick) and
provide;alimony in the amount of $700 a month for an indefinite term.
The $700 a month award was based upon Plaintiffs income while working 65 hours a
week. Plaintiff is advancing in age and will not be able to continue working 65 hours a week as a
laborer due to his advancing age and health concerns. He is anticipating a significant decrease in
income. His pension is very modest and he will need to be able to provide for his personal
expenses and accomodations during his later years. Defendant is capable of self-support,
although she currently only works part-time.
Plaintiff would propose that the couple more closely follow the spirit of their original
agreement of August 9, 1998 as follows:
1. Defendant would retain the marital home and all the contents therein, including her
snow blower and bicycle.
2. Plaintiff would be permitted to remove his tools and equipment.
3. Defendant would retain the 1991 Buick.
4. Plaintiff would retain his Harley Davidson, Chevy, and Antique Ford.
5. Plaintiff would retain his pensions.
6. Defendant would pay off the PNC Mastercard balance.
7. The couple would equally split payments on the home equity loan currently on the
couple's home until the loan is paid off (in approximately four years.)
Respectfully submitted,
Date:/ ?- ?6 -- T>b
J e Adams, Esquire
.D. No. 79465
117 South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
Hempt Bros., Inc. Retirement Plan
The following is the accrued benefit information for Merle Ludwig Jr:
Accrued monthly pension as of 1. 1.1994 $ 144.64
Present value of above pension* as of 8. 1.2000 $ 5,502
The accrued pension is payable at age 65.
The normal form of payment is a Life Annuity.
The accrued pension is 100% vested.
* The present value calculation has been made based upon the assumptions promulgated
by the Pension Benefit Guaranty Corporation for annuity valuations. The interest
rate is 7.10% per year for 25 years -followed by 6.25% per year. The mortality is
in accordance with the 1983 Group Annuity Mortality Table male rates.
Current Age : 51
Date of Birth: 9- 1.1949
(Divorce:314)
Employee Employer
Deferral Match TOTAL
BEGIN BALANCE 0.00 0.00 0.00
CONTRIBUTION 4,488.36 485.28 4,973.64
LOAN 0.00 0.00 0.00
FORFEITURE 0.00 3,99 3.99
WITHDRAWAL 0.00 0.00 0.00
TRANSFER 0.00 0.00 0.00
OTHER 0.00 0.00 0.00
GAINMOSS) 175.84 14.46 190.30
END BALANCE 4,664.20 503.73 5,167193
VESTED PERCENTAGE 100% 80%
VESTED AMOUNT 4,664.20 402.98 5,067.18
of investment
CrabbeEq Fd Pur Heart Val LoomisS StabVal TOTAL
BEGIN BALANCE 0.00 0.00 0.00 0.00 0.00 0 .00
CONTRIBUTION 1,243.67 1,243.67 248.49 497.43 1,740.38 4,973,64
LOAN 0.00 0.00 0.00 0.00 0.00 0 .00
FORFEITURE 1.00 1.00 0.20 0.41 1.38 3 .99
WITHDRAWAL 0.00 0.00 0.00 0.00 0.00 0 .00
TRANSFER 0.00 0.00 0.00 0.00 0.00 0. 00
OTHER 0.00 0.00 0.00 0.00 0.00 0. 00
GAIN/ILOSS) (137.38) 183.18 (11.85) 29.12 127.23 190. 30
END BALANCE 1,107.29 1,427.85 236.84 526.96 1,868.99 5,167. 93
VESTED AMOUNT 1,005.63 1,400.18 232.23 516.68 1,832.46 5,067. 18
END SHARES 77.978 75.071 8.644 44.320 1868.990
??CH'I?IT
' - Department of the Treasury-Intemat Revenue Service
Farm Income Tax Return for Single and
1040EZ Joint Filers With No Dependents (m 1999 OMB No. 16454676
Use
the
IRS
label
here
Presidential
Election
Campaign
Income
Attack
Copy a of
Form(s)
W-2 here.
Enclose, but
do not staple,
any payment.
I
Note. You
must check
Yes or No.
Last name t? Your social security number
Your arst name and Inlw Merle K Ludwig Jr
R a joint nu m, spouse's oral name and WtW tASt name
Horne address (nuaWm and stree), if you have a P.O. box, see page 12. Apt no.
921 Wsf L %I, y lanEd r7'codat?ou have a forag page City, 12.
Mechanicsburg, Pa 17055-4093
Note. Checking TYes' will not change your tax or reduce your refund.
Do you want $3 to go to this fund? No,
want $3 to go to this fund? ?
i Total wages, salaries, and tips. This
should be shown in box l of your
W2 form(s). Attach your W-2 form(s). 1
2 Taxable interest. If the total is over $400, you cannot use
Form 1040EZ. 2
3 Unemployment compensation, qualified state tuition
program earnings, and Alaska Permanent Fund
dividends (see page 14). 3
4 Add lines 1, 2, and 3. This is your adjusted gross
income. 4
8 Can your parents (or someone else) claim you on their return?
Yes. Enter amount No. single, enter 7,050.00.
from worksheet / If married, enter 12,700.00.
on back. See back for explanation. 5
6 Subtract line 5 from line 4. If line 5 is larger than
line 4, enter 0. This is your taxable income. b. 6
Payments 7 Enter your Federal income tax withheld from box 2 of
and tax your W-2 form(s). 7
as Earned income credit (see page 15).
b Nontaxable earned income: enter type and amount below.
Type $ Be
9 Add lines 7 and 8a. These are your total payments. 9
SO Tax. Use the amount on line 6 above to find your tax
in the tax table on pages 24-28 of the booklet. Then,
enter the tax from the table on this line. 10
Refund
Have it
directly ?
deposited! See
page 20 and ?
fill in Ilb.
Ile, and lid.
11a If line 9 is larger than line 10, subtract line 10 from
line 9. This is your refund.
lla
b Routing number
c Type: d Account
Checking Savings number
4
Amount 12 If line 10 is larger than line 9, subtract line 9 from line
you owe 10. This is the amount you owe. See page 21 for 12
details on how to pay.
I have read this mtma. Under penatues of perjury, I declare that to the bed of my knowledge and belief the
return 11 true, eosrecf and accurately fiats all amounts and sources of income l received during the tax year.
Sign Your signature spouses signature ffjofat return, See page 11.
here
1 8 2 4 0 9 0 4 3
spouse's social security number
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717-761-1435 SAM ANDES
624 P01 NOV 13 '00 13:59
.
?AMCZ.o? J62
- G
542.
,c -
pc
?k?-d-rg?r ?
CERTIFICATE OF SERVICE
AND NOW, thisl? day of December, 2000 I, Jane Adams, Attorney for Plaintiff,
hereby certify that a copy of Plaintiff's PRE-TRIAL STATEMENT been duly served upon the
DEFENDANT by faxing such and placing such in the custody of the United States Postal
Service, via certified mail, postage pre-paid addressed to:
Samuel Andes, Esquire
525 N. 12th Street, P.O. Box 168
Lemoyne, Pa. 17043
VIA FAX AND FIRST CLASS MAIL
ane Adams, Esquire
I.D. No. 79465
117 South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
MERLE K. LUDWIG, JR., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 00 - 5004 CIVIL
TIERNA J. LUDWIG,
Defendant IN DIVORCE
CONFERENCE WITH
COUNSEL AND THE PARTIES
TO: Jane Adams
Merle K. Ludwig, Jr.
Counsel for Plaintiff
Plaintiff
Samuel L. Andes
Tierna J. Ludwig
Counsel for Defendant
Defendant
A conference has been scheduled at the Office of
the Divorce Master, 9 North Hanover Street, Carlisle,
Pennsylvania, on the 6th day of April, 2001, at 9:30 a.m.,
with counsel and the parties to discuss the outstanding
economic issues to determine if there is a basis of
settlement of claims. If issues remain after the conference
a hearing will be scheduled at another date.
Very truly yours,
Date of Notice: E. Robert Elicker, II
March 20, 2001 Divorce Master
MERLE K. LUDWIG, JR., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 00 - 5004 CIVIL
TIERNA J. LUDWIG,
Defendant IN DIVORCE
NOTICE OF PRE-HEARING CONFERENCE
TO: Jane Adams
Samuel L. Andes
, Attorney for Plaintiff
, Attorney for Defendant
A pre-hearing conference has been scheduled
at the office of the Divorce Master, 9 North Hanover Street,
Carlisle, Pennsylvania, on the 19th day of March, 2001, at
9:30 a.m., at which time we will review the pre-trial
statements previously filed by counsel, define issues,
identify witnesses, explore the possibility of settlement
and, if necessary, schedule a hearing.
Very truly yours,
Date of Notice: 1/11/01
Jane Adams, Attorney for
statement on December 15,
Samuel L. Andes, Attorney
pre-trial statement as of
E. Robert Elicker, II
Divorce Master
?laintiff, filed a pre-trial
2000.
for Defendant, has not filed a
the date of this notice.
Y1A1ji?- K
?ua?le P,
L . ' `(W
VS.
L^ylVrl Cf tA"JQWI
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. M- 0?? CIVIL 19
IN DIVORCE
STATUS SHEET
DATE:
ACTIVITIES:
M'
Is
r
-4 wu.(
MERLE K. LUDWIG, JR.,
Plaintiff
VS.
TIERNA J. LUDWIG,
Defendant
TO: Jane Adams
Samuel L. Andes
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00 - 5004 CIVIL
IN DIVORCE
, Attorney for Plaintiff
, Attorney for Defendant
DATE: Monday, October 30, 2000
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.
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
DATE COUNSEL FOR PLAINTIFF ( )
COUNSEL FOR DEFENDANT ( )
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.
JANE ADAMS
ATTORNEY AT LAW
117 SOUTH HANOVER STREET
CARUSLE, PA. 17013
(717) 245-8508 (71 7) 245-8538 FAx
WWW.ADAMSLAW.NEr
November 3, 2000
Robert Elicker, II, Esquire
Divorce Master
9 N. Hanover St.
Carlisle, Pa. 17013
Re: Ludwig v. Ludwig
No. 00 - 5004 Civil Term
Dear Mr. Elicker:
Enclosed please find a Certification indicating that discovery is complete in the above-
captioned matter. I would be interested in getting a hearing date regarding this matter at your
earliest possible convenience.
Please contact me if you have any questions regarding this matter.
Thank you for your kind cooperation regarding the above.
Very truly yours,
J e Adams, Esquire
/JA
cc: Merle Ludwig
SAMUEL L. ANDES
ATTORNEY AT LAW
525 NORTH TWEIXTH STREET
P.O. BOX 166
LEMOYNE, PENNSYLVANIA 17043 TELEPHONE
(717) 761-5361
FAX
14 November 2000 (717) 761-1435
E. Robert Elicker, II
Office of the Divorce Master
9 North Hanover Street
Carlisle, Pa 17013
RE Ludwig Vs. Ludwig
No. 00-5004 Civil Term
Dear Mr. Elicker:
I represent the Defendant in the above matter. Enclosed is my
discovery certification in the above case. I assume the Plaintiff will agree
and, if that is the case, you can schedule a date for us to file our Pre-Trial
Statements.
Sincerely,
Samuel L. Andes
amh
cc: Tierna J. Ludwig
Jane Adams, Esquire
a'b
OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240-6535
E. Robert Elicker, 11
Divorce Master
Traci Jo Colyer
Office Manager/Reporter
November 15, 2000
Jane Adams
Attorney at Law
117 South Hanover Street
Carlisle, PA 17013
West Shore
697-0371 Ext. 6535
Samuel L. Andes, Esquire
525 North Twelfth Street
P.O. Box 168
Lemoyne, PA 17043
RE: Merle K. Ludwig, Jr. vs. Tierna J. Ludwig
No. 00 - 5004 Civil
In Divorce
Dear Ms. Adams and Mr. Andes:
Counsel have returned the certification documents indicating that there are
no outstanding discovery issues. Therefore, I am going to proceed with the
directive for the filing of pretrial statements.
A divorce complaint was filed on July 17, 2000, raising grounds for divorce
of irretrievable breakdown of the marriage; an affidavit was filed on September 5,
2000, indicating that the parties separated in August 1998.
On September 26, 2000, the Defendant filed a petition raising the economic
claims of equitable distribution, alimony, alimony pendente lite, and counsel fees and
expenses.
In accordance with P.R.C.P. 1920.33(b) I am directing each counsel to file a
pretrial statement on or before Friday, December 15, 2000. Upon receipt of the
Ms. Adams and Mr. Andes, Attorneys at Law
15 November 2000
Page 2
pretrial statements, I will immediately schedule a pre-hearing conference with
counsel to discuss the issues and, if necessary, schedule a hearing.
Very truly yours,
E. Robert Elicker, II
Divorce Master
NOTE: Sanctions for failure to file pretrial statements are set
forth in subdivision (c) and (d) of Rule 1920.33.
THE ORIGINAL PRETRIAL STATEMENT SHOULD BE
FILED IN THE MASTER'S OFFICE AND A COPY SENT
DIRECTLY TO OPPOSING COUNSEL.
FAILURE TO FILE PRETRIAL STATEMENTS AS DIRECTED
BY THE MASTER MAY RESULT IN THE MASTER'S
APPOINTMENT BEING VACATED.
4,h
OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240-6535
E. Robert Elicker, 11
Divorce Master
Traci Jo Colyer
Office Manager/Reporter
West Shore
697-0371 Ext. 6535
April 9, 2001
Jane Adams, Esquire Samuel L. Andes, Esquire
Attorney at Law 525 North Twelfth Street
117 South Hanover Street P.O. Box 168
Carlisle, PA 17013 Lemoyne, PA 17043
RE: Merle K. Ludwig, Jr. vs. Tierna J. Ludwig
No. 00 - 5004 Civil
In Divorce
Dear MS. Adams and Mr. Andes:
Enclosed is a draft of the agreement which you put on
the record on April 6, 2001. Please review the draft for
any corrections with the understanding that no substantive
changes can be made.
When you have reviewed the draft give us a call and
let us know if you want us to send the original to the
Plaintiff's attorney for signature who then can transmit the
original to the Defendant's attorney for signature. When I
receive a signed copy of the document, I will then obtain a
Court order vacating my appointment.
Thank you for your continuing cooperation in bringing
this matter to settlement.
Very truly yours,
E. Robert Elicker, II
Divorce Master
SAMUEL L. ANDES
ATTORNEY AT LAW
525 NORTH TWELFTH STREET
P, 0. BOX 168
LEMOYNE, PENNSYLVANIA 17043 TELEPHONE
(917) 761-5361
21 May 2001
E. Robert Elicker, II, Esquire
Office of the Divorce Master
9 North Hanover Street
Carlisle, PA 17013
RE: Ludwig vs. Ludwig
2000-5004
Dear Mr. Elicker:
FAX
(717) 761-1435
Enclosed is the transcript of the agreement reached before you on 6 April
2001 in the above case, which has now been signed by both parties and their
attorneys. Please be certain you file this copy with the court, because it is the only
copy signed by both parties.
Please vacate your appointment so that the parties can conclude the divorce.
Thank you for your cooperation.
Sincerely,
Samue- I L. Andes
le
Enclosure
cc: Jane Adams, Esquire
Mrs. Tierna Ludwig
SAMUEL L. ANDES
ATTORNEY AT LAW
525 NORTH TWELFTH STREET
P. O. BOX 168
LEMOYNE, PENNSYLVANIA 17043 TELEPHONE
(717) 761-5381
F?
30 January 2001 (717) 761-1435
E. Robert Elicker, II
Office of the Divorce Master
9 North Hanover Street
Carlisle, Pa 17013
RE Ludwig Vs. Ludwig
No. 00-5004 Civil Term
Dear Mr. Elicker:
Enclosed is, belatedly, the Pre-Trial Statement which I file on behalf of
the Defendant in the above matter, Tierna J. Ludwig.
Both sides have now filed Pre-Trial Statements. If you have not
already done so, please schedule a Pre-Trial Conference and notify counsel
of the time and date. Thank you for your cooperation.
Sincerely,
I L. Andes
amh
cc: Tierna J. Ludwig (w.enclosure)
Jane Adams, Esquire (w.enclosure)