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Home My WebLink About04-2503 II FRED A. URICH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. KAREN S. URICH, Defendant IN DIVORCE / CUSTODY NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302 (d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. II FRED A. URICH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 0 'i - ~503 KAREN S. URICH, Defendant IN DIVORCE / CUSTODY COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, FRED A. URICH, by his attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is FRED A. URICH, an adult individual who currently resides at 345 East Crestwood Drive in Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is KAREN S. URICH, an adult individual who currently resides at 36 Sherwood Circle in Enola, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 29 November 1985 in Summerdale, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I - IRRETRIEVABLE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree in Divorce. II WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the Divorce Code of Pennsylvania. COUNT II - EQUITABLE DISTRIBUTION 9. 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. Plaintiff prays this Honorable Court, after requiring full disclosure by the Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as marital property. COUNT III - ALIMONY 10. Plaintiff lacks sufficient property to provide for his reasonable needs in accordance with the standard of living of the parties established during the marriage. 11 . Plaintiff is unable to support himself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 12. The Defendant is employed and enjoys a substantial income from which she is able to contribute to the support and maintenance of the Plaintiff and pay him alimony in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding Plaintiff from Defendant permanent alimony in such sums as are reasonable and adequate to support and maintain Plaintiff in the station of life to which he has become accustomed during the marriage. COUNT IV - ALIMONY PENDENTE LITE 13. Plaintiff is without sufficient income to support and maintain himself during the pendency of this action. 14. Defendant enjoys a substantial income and is well able to contribute to the support and maintenance of Plaintiff during the course of this action. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay him reasonable alimony pendente lite during the pendency of this action. II I, COUNT V - COUNSEL FEES AND EXPENSES 1 5. Plaintiff is without sufficient funds to retain counsel to represent him in this matter. 16. Without competent counsel, Plaintiff cannot adequately prosecute his claims against Defendant and cannot adequately litigate his rights in this matter. 1 7. Defendant enjoys a substantial income and is well able to bear the expense of Plaintiff's attorney and the expense of this litigation. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay the legal fees and expenses incurred by Plaintiff in this litigation of this action. VI - CUSTODY 18. The parties are the parents of two children, an adult son, Torrey M. Urich, and a minor daughter, Shannon N. Urich, born 23 January 1990. 19. During the past five years, the child has resided with the following parties at the following addresses: May 2004 to present 36 Sherwood Circle Enola, PA Defendant August 1 990 to May 2004 36 Sherwood Circle Enola, PA Plaintiff & Defendant Birth to August 1 990 224 Columbia Avenue Enola, PA Plaintiff & Defendant 20. The Plaintiff has not participated as a party or in any other way in any litigation concerning the custody of the children in this or any other court. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of this or any other jurisdiction. Plaintiff knows of no other person not a party to this action already who has physical custody of or claims to have custody or visitation rights to the said children. 21. The Plaintiff resides at the address listed above with the parties' adult son. The Defendant resides at 36 Sherwood Circle with the parties' minor daughter. 1/ II 22. Plaintiff seeks an award of shared legal and physical custody of the child, for the following reasons: A. He has always been involved in the child's life; and B. He wants to maintain a close father-daughter relationship; and C. He wants to maintain a close relationship between the two children; and O. The court's involvement is necessary to assure him regular and frequent custody contact with the child because the mother has not fostered or encouraged the relationship. WHEREFORE, Plaintiffs, asks this court to award him shared legal and physical custody of the parties' minor daughter. ~ "N){) ~ ~.~s~ Attorney for Plaintiff Supreme Court 10 # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: !r;/I}()Y ~rJ:u:JZ ~ '- oJ' '"b ^(\ ~ ~ -;:::- 0, ')..) \....... ('" " L..l v ~. ...!) .... ~, t' L.l ~ t l ~-~ 0 .:' -1\ -,;:... r :~~. 1 ; ~ ~ , . r~ C~, .:: ...,-;.;, " Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FRED A. URICH, vs. CIVIL ACTION - LAW NO. 04-2503 CIVIL TERM KAREN S. URICH, Defendant IN DIVORCE I CUSTODY MOTION FOR CUSTODY CONCILIATION CONFERENCE AND NOW comes the above-named Plaintiff, by his attorney, Samuel L. Andes, and moves the court to assign the custody claim raised in Count VI of his Divorce Complaint, a copy of which is attached hereto, to be assigned to Bi conciliator and scheduled for a conference so this matter can proceed. 10 June 2004 ~~~~ Attorney for Plaiintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 II :i EXHIBIT A FRED A. URICH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. o ~ CIIVIL ACTION - LAffJ :i2 ~ 04- ::;:V t: :-t ~.?'.._; .... r'l!1 NO. '25D3.- u1?il ~ ~~f-;J ..:-;: -. L.) ;:-Jr' ~:.:: I:,. ::.:; Co.) Defendant INI DIVORCE / ~~;~TO~ i~;~~ NOTICE TO DEFEND AND CLAIM RIGHTS :=~ CJ :t; \.C.i KAREN S. URICH, You have been sued in court. If you wish to defend against the claims set forth in the foregoing 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 in 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. When 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 in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 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 Assoeiation 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 FRED A. URICH, Plaintiff IN THE COURT OF COMMON Pl.EAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVil ACTION - lAW Defendant NO. or2-5D3 C.\.~l~....., IN DIVORCE / CUSTODY KAREN S. URICH, NOTICE OF AVAilABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302 (d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counselin!~ prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and vou are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. FRED A. URICH, Plaintiff IN THE COURT OF COMMON Pl.EAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. KAREN S. URICH, Defendant IN DIVORCE / CUSTODY COMPLAINT IN DIVORCI; AND NOW comes the above-named Plaintiff, FRED A. URICH, by his attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is FRED A. URICH, an adult individual who currently resides at 345 East Crestwood Drive in Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is KAREN S. URICH, an adult individual who currently resides at 36 Sherwood Circle in Enola, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 29 November 1985 in Summerdale, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I - IRRETRIEVABLE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the Divorce Code of Pennsylvania. COUNT I( - EQUITABLE DISTRIBUTION 9. 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, Plaintiff prays this Honorable Court, after requiring full disclosure by the Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as marital property. COUNT III - ALIMONY 10. Plaintiff lacks sufficient property to provide for his reasonable needs in accordance with the standard of living of the parties established during the marriage. 11. Plaintiff is unable to support himself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 12. The Defendant is employed and enjoys a substantial income from which she is able to contribute to the support and maintenance of the Plaintiff and pay him alimony in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding Plaintiff from Defendant permanent alimony in such sums as are reasonable and adequate to support and maintain Plaintiff in the station of life to which he has become accustomed during the marriage. COUNT IV - ALIMONY PENDENTE LITE 13. Plaintiff is without sufficient income to support and maintain himself during the pendency of this action. 14. Defendant enjoys a substantial income and is well able to contribute to the support and maintenance of Plaintiff during the course of this action. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay him reasonable alimony pendente lite during the pendency of this action. COUNT V - COUNSEL FEES AND EXPENSES 1 5. Plaintiff is without sufficient funds to retain counsel to represent him in this matter. 16. Without competent counsel, Plaintiff cannot adequately prosecute his claims against Defendant and cannot adequately litigate his rights in this matter. 17. Defendant enjoys a substantial income and is well able to bear the expense of Plaintiff's attorney and the expense of this litigation. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay the legal fees and expenses incurred by Plaintiff in this litigation of this action. VI - CUSTODY 18. The parties are the parents of two children, an adult son, Torrey M. Urich, and a minor daughter, Shannon N. Urich, born 23 January 1 H90. 19. During the past five years, the child has resided with the following parties at the following addresses: May 2004 to present 36 Sherwood Circle Enola, PA Defendant August 1990 to May 2004 36 Sherwood Circle Enola, PA Plaintiff & Defendant Birth to August 1990 224 Columbia Avenue Enola, PA Plaintiff & Defendant 20. The Plaintiff has not participated as a party or in any other way in any litigation concerning the custody of the children in this or any other court. The Plaintiff has no information of a custody proceeding concerning the children pending in a court of this or any other jurisdiction. Plaintiff knows of no other person not a party to this action already who has physical custody of or claims to have custody or visitation rights to the said children. 21. The Plaintiff resides at the address listed above with the parties' adult son. The Defendant resides at 36 Sherwood Circle with the parties' minor daughter. 22. Plaintiff seeks an award of shared legal and physical custody of the child, for the following reasons: A. He has always been involved in the child's life; and B. He wants to maintain a close father-daughter relationship; and C. He wants to maintain a close relationship between the two children; and D. The court's involvement is necessary to assure him regular and frequent custody contact with the child because the mother has not fostered or encouraged the relationship. WHEREFORE, Plaintiffs, asks this court to award him shared legal and physical custody of the parties' minor daughter. _0 1~()-.~9 ~~s~ Attorney for Plaintiff Supreme Court ID # 17225 525 North ., 2th Street Lemoyne, Pa 17043 (717) 761-5361 I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities), Date: 1,;./ I J () Y f / c/aUJ'Z ~RICH f? "" f:: C") J,- '1 -=I :T_~ ri1~! ,"n_ -'..,.n :'i':J ~-)C) c. :? ,'. '.:i -;' ) '''1 c. FRED A. URICH, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-2503 KAREN S. URICH, Defendant : CIVIL ACTION - LAW : IN DIVORCE/CUSTODY ACCEPTANCE OF SERVICJE I, Marianne E. Rudebusch, Esquire, attorney for Defendant, Karen S. Urich, hereby accept service of the Complaint in Divorce filed by the Plaintiff, and certifY that I am authorized to do so. By: ~~~ [- QoUb~c4. Marianne E. Rudebusch, Esquire 4711 Locust Lane Harrisburg, P A 17][ 09 717-657-0632 Id. No. 63522 Dated: ~((}1 (") ..., <=> 0 c = -,.. ~ .e- wUJ L. :t:n nJ c:: ~;J;,,' Z m,.- "'-~ -om ~~: 0 g6 r:c ~ ~,~ " . -,., -,;;-" ;;'1<' \ ~; :::I:: ;"=20 L.:..o Znl Pc:' ~ 0 Z --, 'J:;:.. ~ .:;:- ~iJ 0 -< FRED A. URICH PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 04-2503 CIVIL ACTION LAW KAREN S. URICH DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, Juue 17, 2004 , upon consideration of the attached Complaint, , the conciliator, at 12:00 PM it is hereby directed that parties and their respective cOlmsel appear before ~)awn S. Sunday, Esq. at 39 West Maiu Street, Mechanicsburg, PA 17055 on Wednesday, July 14, 2004 for a Pre-Hearing Custody Conference. At such conference, an ellort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The eourt hereby directs the parties to furnish any and all existing Protection froID Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 bours prior to scheduled hearinl!;. FOR THE COURT. By: Isl Dawn S. .\lunday, F-sq. Custody Conciliator mhc The Court of Common pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS P MER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN A TroRNEY 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249..3166 ~~flv .~ ~ 4rt.v /;(). ~/.I/ ~~?~ ~ ~r/'~/.? ~ y'?~ 4-rW-rn; /ltJ.N'~ '~'''\!1;"11 c:, 'N:1d Vii 'I. "1/\...,, \I, ~.. '",lnC'''; r"lc,~:q:w\m l\J.Jtlj.'...I'.1'", .....', S S :OIIlV B I Nnr 'lOOl AtJVlONOHIOtkl 3Hl ~o 381::1:!0-03ll:1 7) FRED A. URICH, Plaintiff : IN THE COURT 011 COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 04-2503 KAREN S. URICH, Defendant : CIVIL ACTION - LAW : IN DIVORCE/CUSTODY DEFENDANT'S ANSWER AND COUNTER-CLAIM TO PLAINTIFF'S COMPLAINT IN DIVORCE AND NOW, comes the Defendant, Karen S. Urkh, by and through her attorney, Marianne E. Rudebusch, Esquire, and respectfully files this Answer and Counter-Claim as follows: I. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. No answer required. COUNT I IRRETRIEVABLE BREAKDOWN 8. No answer required. COUNT II EOUlTABLE DISTRIBUTION 9. Admitted. COUNT III ALIMONY 10. Denied. It is denied that P1aintifflacks sufficient property to provide for his reasonable needs in accordance with the standard of living of the parties established during the marriage. 11. Denied. It is denied that Plaintiff is unable to support himself in accordance with the standard ofliving of the parties established during the marriage through appropriate employment. 12. Admitted in part. Denied in part. It is admitted that the Defendant is employed. It is denied that Defendant enjoys a substantial income from which she is able to contribute to the support and maintenance ofthe Plaintiff an pay him alimony in accordance with the Divorce Code of Pennsylvania. COUNT IV ALIMONY PENDENTE LITE 13. Denied. It is denied that Plaintiff is without sufficient income to support and maintain himself during the pendency of this action. 14. Denied. It is denied that Defendant enjoys a substantial income and is well able to contribute to the support and maintenance of Plaintiff during the course of this action. COUNT V COUNSEL FEES AND EXPENSES 15. Denied. It is denied that Plaintiff is without sufficient funds to retain counsel to represent him in this matter. 16. No answer required. 17. Denied. It is denied that Defendant enjoys a substantial income and is well able to bear the expense of Plaintiffs attorney and the expense of this litigation. COUNT VI CUSTODY 18. Admitted. 19. Admitted. 20. Denied. Defendant is without sufficient knowledge to form a belief as to the truth of this averment and therefore, it is denied. 21. Admitted. 22. A. Admitted in part, denied in part. It is admitted that Plaintiff has always been involved in the child's life, however, the Defendant has always been the primary caretaker. B. Admitted. C. Admitted. D. Denied. It is denied that the court's involvement is necessary to assure him regular and frequent custody contact with the child because the mother has not fostered or encouraged the relationship. COUNTER CLAIM COUNT I CLAIM FOR ALIMONY PENDENTE LITE UNDER SECTION 3702 OF THE DIVORCE CODE 23. Defendant hereby incorporates by reference all of the averments contained in paragraphs I through 22 of this Answer and Counterclaim. 24. Defendant does not have sufficient funds to support herself during the pendency of this action. 25. Plaintiff is well able to pay support to Defendant. 26. Defendant requests this Court to grant her aliimony pendente lite. COUNT II CLAIM FOR COUNSEL FEES. COSTS AND EXPENSES UNDER SECTION 3702 OF THE DIVORCE CODE 27. Defendant hereby incorporates by reference all the averments contained in paragraphs I through 26 of this Answer and Counterclaim. 28. Defendant does not have sufficient funds to pay the counsel fees, costs and expenses incidental to this action. 29. Plaintiff is well able to pay Defendant's counsel fees, costs and expenses incidental to this matter. 30. Defendant requests this Court to grant her counsel fees, costs and expenses incidental to this action. COUNT III CLAIM FOR ALIMONY UNDER SECTION 3701 OF THE DIVORCE CODE 31. Defendant hereby incorporates by reference alii of the averments contained in paragraphs 1 through 30 of this Answer and Counterclaim. 32. Defendant does not have a sufficient source of income or earning capacity at the present time to maintain the standard of living enjoyed by the parties during their marnage. 33. Plaintiff does have a sufficient source of income and earning capacity to aid Defendant in maintaining the standard ofliving enjoyed by the parties during their marriage. COUNT IV CLAIM FOR INDlGNITUIS UNDER SECTION 3301 (a)(2) and 3301(a)(6) OF THE DIVORCE CODE 34. Defendant hereby incorporates by reference all of the averments contained in paragraphs 1 through 33 of this Answer and Counterclaim. 35. Plaintiff committed adultery. 36. The Defendant avers as the grounds on which the action is based that the Plaintiffhas offered such indignities to the person of the injured and innocent spouse, namely Defendant, as to render her condition intolerable and life burdensome. This action in divorce is not collusive. WHEREFORE, Defendant respectfully requests this Honorable Court to enter a Decree: a. dissolving the marriage between the Plaintiff and Defendant under Sections 3301(a)(2) and 3301(a)(6) of the Divorce Code; and b. equitably distributing all property owned by the parties hereto; and c. directing the Plaintiff to pay alimony pendente lite to Defendant; and d. directing the Plaintiffto pay Defendant's counsel fees and expenses incidental to this divorce action; and e. granting alimony to Defendant; and f. to grant primary physical custody of the parties minor child to the Defendant with partial physical custody to the Plaintiff; and g. for such further relief as the Court may determine to be equitable and just. Respectfully Submitted, ~^NW' t. 2"riL~~~ Marianne E. Rudebusch, Esquire 4711 Locust Lane Harrisburg, P A 17109 (717) 657-0632 Id. No. 63522 Dated: ~ . 17 - Qt.1 FRED A. URICH, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-2503 KAREN S. URICH, Defendant : CIVIL ACTION - LAW : IN DIVORCE/CUSTODY VERIFICATION I verify that the statements made in the foregoing afl~ true and correct. I understand that false statements herein are made subject to the penaltks of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. By: v.. Ci-""' c;:;'lJ~L.. Karen S. Urich Date: (0 \ n \,oolf :"] ._< "'-> = c.-=:l o ,., II.." nl-_J ,- -ryrn '.:;C"J ,-" r >--.1<:) "'.,- ., i-') ~d ',,,:.i..'3 C-;nl .:.;~ ~';_1 .< <.- c: d~ N 7) ~'-~ (,.) f" o FRED A. URICH, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 04-2503 KAREN S. URICH, Defendant : CIVIL ACTION -LAW : IN DIVORCE/CUSTODY INVENTORY UNDER RULE 1920.33 Defendant, Karen S. Urich, files the following invenltory 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. Defendant verifies that the statements made in this inventory are true and correct. Defendant understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: ~'n \ "/0<.:>\.(.._ By: ~_~ (L-- 1 Karen S. Urich ASSETS OF PARTIES DEFENDANT MARKS ON THE LIST BELOW THOSE ITEMS APPLICABLE TO THE CASE AT BAR AND ITEMIZES THE ASSETS ON THE FOLLOWING PAGES. (XX) 1. Real Property (XX) 2. Motor Vehicles (XX) 3. Stocks, bonds, securities and options (XX) 4. Certificates of Deposit (XX) 5. Checking accounts, cash (XX) 6. Savings accounts, money market and savings certificates ( ) 7. Contents of safe deposit boxes) ( ) 8. Trusts ( ) 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) (XX) 10. Annuities ( ) 11. Gifts ( ) 12. Inheritances ( ) 13. Patents, copyrights, inventions, royalties ( ) 14. Personal property outside the home ( ) 15. Businesses (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) (XX) 19. Retirement plans, Individual Retirement Accounts ( ) 20. Disability payments ( ) 21. Litigation claims (matured and unmatured) ( ) 22. MilitaryN.A. benefits ( ) 23. Education benefits (XX) 24. Debts due, including loans, mortgages held (XX) 25. Household furnishings and personalty (include as a total category and attach itemized list if distri- bution of such assets is in dispute) ( ) 26. Other MARITAL PROPERTY DEFENDANT 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 OF THE SEPARATION OF THE PARTIES: ITEM NUMBER DESCRIPTION OF PROPERTY NAMES OF ALL OWNERS 1. 36 Sherwood Circle Fred A. Urich Enola, P A Karen S. Urich 2. 1996 Chevy Suburban Fred A. Urich Karen S. Urich 2. 1994 Chevy Astro Van Fred A. Urich Karen S. Urich 2. 2003 S 10 Truck Fred A. Urich Karen S. Urich 2. I 997Mallard Travel Trailer Fred A. Urich Karen S. Urich 3. U.S. Savings Bonds Fred A. Urich Karen S. Urich 4. CD's with Waypoint Bank and Fred A. Urich Fulton Bank Karen S. Urich 5. Checking Account wi Waypoint Fred A. Urich Karen S. Urich 5. $2,800.00 in cash in lock box Fred A. Urich Karen S. Urich 6. Savings Account wi Waypoint Fred A. Urich Karen S. Urich 10. Annuity wi Prudential Financial Fred A. Urich 10. Annuity wi TransAmerica Fred A. Urich 10. Annuity wi Hartford Fred A. Urich 19. IRA wi New York Life Fred A. Urich 19. IRA wi New York Life Karen S. Urich 19. 401(k) wi Empire Blue Crossl Karen S. Urich Blue Shield 19. Roth IRA wi M&T Securities, Inc. Fred A. Urich Karen S. Urich 19. Putnam Retirement Savings Plan Fred A. Urich 25. Household goods and furnishings Fred A. Urich Karen S. Urich NON-MARITAL PROPERTY DEFENDANT LISTS ALL PROPERTY IN WHICH A SPOUSE HAS A LEGAL OR EQUITABLE INTEREST WHICH IS CLAIMED TO BE EXCLUDED FROM MARITAL PROPERTY: ITEM NUMBER DESCRIPTION OF PROPERTY REASON FOR EXCLUSION PROPERTY TRANSFERRED DEFENDANT LISTS ALL MARITAL PROPERTY U'J WHICH EITHER OR BOTH SPOUSES HAD A LEGAL OR EQUITABLE INTEREST INDIVIDUALLY OR WITH ANY OTHER PERSON AND WHICH HAS BEEN TRANSFERRED WITHIN THE PRECEDING THREE YEARS: ITEM NUMBER DESCRIPTION DATE OF OF PROPERTY TRANSFER CONSII>ER- PERSON TO ATION WHOM TRANSFERRED LIABILITIES DEFENDANT LISTS ALL LIABILITIES OF EITHER OR BOTH SPOUSES ALONE OR WITH ANY PERSON AS OF THE DATE OF SEPARATION: ITEM DESCRIPTION NUMBER OF PROPERTY NAMES OF ALL CREDITORS NAMES OF ALL DEBTORS 24. 36 Sherwood Circle Enola, PA Waypoint Bank Fred A. Urich Karen S. Urich '" = "'" -""" '- t~~:~ :;~. o -n :r.." n',- ,-- l1cTl cue? l~)C ~J",~ (~:IJ "';;;.0 f,>c;rn ;;:~ :;J ...<: N ~) (..) N FRED A. URICH, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-2503 KAREN S. URICH, Defendant : CIVIL ACTION - LAW : IN DIVORCE/CUSTODY CERTIFICATE OF SERVICE ~ AND NOW, this .J;L day of ~ _, 2004, I, Katherine A. Frey, Secretary to Marianne E. Rudebusch, Esquire, Attorney for th(: Defendant, hereby certify that a copy of the Answer and Counterclaim has been served, by depositing a copy of the same in the United States mail, first class, postage prepaid, at Harrisburg, Pennsylvania, to the following addressee: Samuel L. Andes, Esquir,e 525 North Twelfth Street P.O. Box 168 Lemoyne, P A 17043 Attorney for Plaintiff BY~IJ.-~~ Katherine A. Frey "" = <= ...- <- c:: :.;;.:: o -n .-1 :C..,., n1- ,..... -nm ;;!}C? ::::~c\ ~~~~ ~5rn :=:;! ;.0 -<: N CD -..... .", :1:': ~ N FRED A. URICH, Plaintiff/Petitioner IN THE COVIn OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE KAREN S. URICH, DefendantlRespondent NO. 2004-2503 CIVIL TERM IN DIVORCE Pacses# 432101;480 ORDER OF COURT AND NOW, this 8th day of, 2004, upon consideration of the attached Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shaddav onA",,".t 18.2004 at 9:00A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (I) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 191O.11~ (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required docwnents, the Court may issue a warrant for your arrest. BY THE COURT, George E. Hoffer, President Judge Mail copies on 7-8-04 to: Petitioner < Respondent Samuel Andes, Esquire Marianne Rudebusch, Esquire f:1 ~l;:lL RL...." Co"",- 0:;;;- Date of Order: Julv 8. 2004 YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FISD OUT WHERE YOU MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIA nON 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 CC361 o c: -<.:" ..c:.::': -< ...., = = .c- <- ,- r= r lD !f; =t." m- ~O~ JJT ~~~E ~;;~~ (5m ;~I ~i1 -< ~ -l.-':.. C:.) .r.- N In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION FRED A. URICH ) Docket Number 04-2503 CIVIL Plaintiff ) vs. ) PACSES Case Number 432106480 KAREN S. URICH ) Defendant ) Other State ID Number ORDER AND NOW, to wit on this 4TH DAY OF AUGUST, 2004 IT IS HEREBY ORDERED that the 0 Complaint for Support or 0 Petition to Modify or 0 Other REQUEST FOR APL filed on 06/10/04 in the above captioned I matter is dismissed without prejudice due to: THE PETITIONER WITHDRAWING HIS REQUEST FOR ALIMONY PENDENTE LITE. () c: ....., c:.~ ,-~:.::o ..c- z::= G"J I U1 o The Complaint or Petition may be reinstated upon written application of the plaintiff petitioner. DRO: RJ Shadday xc: plaintiff defendant Samuel Andes, Esquire Marianne Rudebusch, Esquire BY THE COURT: rt~. ~;s JUDGE /I. ~ Service Type M ........~._,.i~,.;_~......;...L,......~.- .~ !!~ L/ - 0'( Form OE-506 Worker ID 21005 ...,., o ""1' ::-1 'r11 :!J (-- -rJnl ~.b C'J o"L -i\~ ;/':?r~ ::',.5n1 "I f'" :x: .,~: G) c.) \.D ;';." ~:;';.;1<t f"~ r't e ci "" c.-> "'" C<:"" ~:::, (i'"J I 01 -Ci :;..'.:, o ~r'\ ~_.~ ~r~ -;1 rf\p: -orrl "'nO ..) , (::"~\~1?1 .:e':)~L~ ~".--:,{n ':::~~ ~~ c..:? U> o.D AUG 1 B 2004 \f 'f FRED A. URICH Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 04-2503 CNIL ACTION LAW KAREN S. URICH Defendant IN CUSTODY ORDER OF COURT AND NOW, this Z q ... day of A I 1M yo , 2004, upon consideration of the attached Custody Conciliation Report, it IS ordered and directed as follows: 1. The parties and the Child shall participate in a course of therapeutic family counseling (for a minimum of three sessions) with a professional who is listed under the Mother's insurance coverage. The purpose ofthe counseling shall be to address concerns which have arisen with regard to the Child in connection with the parties' separation. The parties shall follow the recommendations ofthe counselor as to the frequency of sessions and the participants (including third parties, if recommended) in each session. The Mother shall be responsible to pay any costs of counseling which are not covered by insurance. 2. The Mother, Karen S. Urich, and the Father, Fred A. Urich, shall have shared legal custody of Shannon N. Urich, born January 23, 1990. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms ofthis paragraph each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. 3. The Mother shall have primary physical custody of the Child. 4. The Father shall have partial physical custody of the Child on the following weekends from Saturday at 10:00 a.m. through Sunday at 8:00 p.m.: August 7-8, 2004, August 28-29,2004, and September 11-12, 2004. Thereafter, beginning on September 24, 2004, the Father shall have custody of the Child on alternating weekends from Friday at 5:30 p.m. through Sunday at 8:00 p.m. Beginning on August 4, 2004, the Father also shall have custody of the Child every Wednesday evening from 5:30 p.m. through 8:00 p.m. V'lnJ o'~ ., 'I \,1;] <,,,,- ~1 ~~ ~. 11UOl .In - 5. The parties shall share having custody of the Child on holidays as follows; A. Christmas: In even numbered years, the Mother shall have custody ofthe Child from Christmas Eve at 12:00 noon through Christmas Day at 12:00 noon, and the Father shall have custody from Christmas Day at 12:00 noon through December 26 at 12;00 noon. In odd numbered years, the Mother shall have custody of the Child on Christmas Eve from 12:00 noon through 9:00 p.m. and the Father shall have custody from Christmas Eve at 9;00 p.m. through Christmas Day at 9:00 p.m. B. Thanksgiving: In every year, the Mother shall have custody of the Child on Thanksgiving Day until 4;00 p.m. and the Father shall have custody on Thanksgiving from 4:00 p.m. until 9:00 p.m. C. Easter: The Mother shall have custody ofthe Child every year over the Easter weekend. In the event the Easter weekend falls on the Father's regular alternating weekend period of custody, the parties shall make arrangements for the Father to have a make-up weekend period of custody either the weekend immediately preceding Easter or the weekend immediately following Easter. D. Memorial Dav/Indeoendence Dav/Labor Dav: In even numbered years, the Mother shall have custody of the Child for Memorial Day and Labor Day and the Father shall have custody for Independence Day. In odd numbered years, the Father shall have custody of the Child for Memorial Day and Labor Day and the Mother shall have custody for Independence Day. The period of custody under this provision shall run from 5:30 p.m. on the evening before the holiday through 8:00 p.m. on the day of the holiday. E. Mother's DavIFather's Dav: In every year, the Mother shall have custody ofthe Child on Mother's Day and the Father shall have custody on Father's Day from 10;00 a.m. until 8;00 p.m. F. Child's Birthdav: In even numbered years, the Father shall have custody of the Child on her birthday from 5:30 p.m. until 8:30 p.m. and in odd numbered years, the Mother shall have custody of the Child on her birthday from 5:30 p.m. through 8:30 p.m. G. The holiday custody schedule shall supercede and take precedence over the regular and vacation custody schedule. 6. Each party shall be entitled to have custody of the Child for two non-consecutive weeks each summer upon providing at least 30 days advance notice to the other party. The party providing notice first shall be entitled to preference on his or her selection of vacation dates. Each party shall schedule his or her periods of vacation under this provision to include that party's regular weekend periods of custody. 7. Unless otherwise agreed between the parties, the party receiving custody ofthe Child shall be responsible to provide transportation for the exchange of custody. 8. Each party shall ensure that the Child has a private bedroom of her own at that party's residence during periods of custody. 9. This Order is entered pursuant to an agreement of the p,mies at a custody conciliation conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, cc; Samuel L. Andes, Esquire - Counsel for Father Marianne E. Rudebusch, Esquire - Counsel for Mother ./1~ J. FRED A. URICH Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 04-2503 CIVIL ACTION LAW KAREN S. URICH Defendant IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Shannon N. Urich January 23,1990 Mother 2. A conciliation conference was held on August 4, 2004, with the following individuals in attendance: The Father, Fred A. Urich, with his counsel, Samuel L. Andes, Esquire, and the Mother, Karen S. Urich, with her counsel, Marianne E. Rudebusch, Esquire:. 3. The parties agreed to entry of an Order in the form as attached. ~}rNOf- Date /:2. jrxJt/ . ~ Dawn S. Sunday, Esqlllr Custody Conciliator FRED A. URICH, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-2503 KAREN S. URICH, Defendant : CIVIL ACTION - LAW : IN DIVORCE/CUSTODY PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY OFCUMBERLlINI:COUNTY, PENNSYLVANIA: Please withdraw the appearance of Marianne E. Rudebusch, Esquire on behalf of the Defendant in the above referenced matter. Respectfully Submitted, Dated: (IZiff ()(' I h~ r e.ouCJlH~-' Marianne E. Rudebusch, Esquire 4711 Locust Lane Harrisburg, P A 17109 (717) 657-0632 Id. No. 63522 ENTRY OF APPEARANCE Please enter the appearance of James R. Demmel, Esquire, Esquire on behalf of the Defendant in the above referenced matter. Respectfully Submitted, Dated: ~/211{)r- e . Demmel, Esquire Smigel, Anderson & Sacks 4432 North Front Street, 3" Floor Harrisburg, P A 17110 (717) 234-240 I Id. No. qoq Ii c) ,~~ CJ"> CJ -n (..0 ?~?'> LC:, (~ CO /JRD/smm//June 3, 2005 4:55 PM FRED A. URICH, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-2503 KAREN S. URICH, DEFENDANT CIVIL ACTION - LAW IN DIVORCE/CUSTODY CERTIFICATE OF SERVICE I, James R. Demme1, Esquire, counsel for Defendant in the above captioned matter, do hereby certify that I served a true and correct copy of the foregoing Praecipe for Withdrawal/Entry of Appearance on the following persons by depositing same in the U.S. Mail, first class, postage paid on the l day of June, 2005, addressed as follows: Marianne E. Rudebusch, Esquire 4711 Locust Lane Harrisburg, P A 17109 Samuel L. Andes, Esquire 525 North Twelfth Street P.O. Box 168 Lemoyne, P A 17043 SMIGEL, ANDERSON & SACKS, LLP By: Q Ja es . Demme1, Esquire I.D. #: 90918 4431North Front Street Harrisburg, PAl 711 0 (717) 234-2401 Attorney for Defendant n c.= ~~~ '"""t,~ r-= IT,'" -.,"- ,. U? ::::.",: '--- ....., ~:'E; ~ ,...;) c:::> 1.:=::> c:n t_ c:: :t:.:. o .....n -I :I-n rne :00 3::J , (:~6 {~~ .5,:~ rii ~.~ 2.0 :< I ~ -0 :I: w .. .&:" OCT 2 7 200Y SMIGEL, ANDERSON & SACKS, LLP James R. DemmeJ, Esquire lD #90918 4431 North Front Street Harrisburg, PA ]7110-]709 (717) 234-240 I idcmmel(a:~sasllD.C()m Attorneys for Defendant FRED A. URICH, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2004-2503 KAREN S. URICH, DEFENDANT CIVIL ACTION - DIVORCE DEFENDANT'S PRETRIAL STATEMENT PER Pa.R.C.P. 1920.33(b) AND NOW, comes Defendant, KAREN S. URICH, by and through her counsel, SMIGEL, ANDERSON & SACKS, LLP, and files this Pretrial Statement as follows: 1. ASSETS - See Defendant's Inventory attached hereto as Exhibit A. This replaces Defendant's Inventory filed on June 21, 2004. Defendant reserves the right to update her inventory prior to the hearing. II. EXPERT WITNESSES - 1. Real estate appraiser - To establish fair market value and fair rental value of marital residence. 2. Personal Property Appraiser - To establish fair market value of personal property, including household furnishings, collections, and vehicles. " Defendant believes the parties may agree on the values of the marital home and/or personal property without the need for expert valuations, but in the absence of such agreements, Defendant reserves the right to call such experts to testify in her case. III. WITNESSES - In addition to herself, Defendant anticipates calling the following fact witnesses: 1. Wilhelmina Potteiger - To testify regarding the ownership of various accounts held in Plaintiffs name. 2. Holly McKean - To testify regarding Plaintiffs current living situation, including his income and expenses. Defendant reserves the right to call additional witnesses as necessary to establish her case. IV. EXHIBITS - Defendant expects to offer into evidence the following exhibits: 1. Income tax returns, pay statements, and other documentation to establish the parties' incomes and expenses during the marriage and currently. 2. Account statements to establish the value of financial accounts. Defendant reserves the right to offer into evidence additional exhibits as necessary to present her case. V. INCOME - See Defendant's Income & Expense Statement attached hereto as Exhibit B. Defendant reserves the right to update her Income & Expense Statement prior to the hearing. VI. EXPENSES - See Defendant's Income & Expense Statement attached hereto as Exhibit B. Defendant reserves the right to update her Income & Expense Statement prior to the hearing. VII. PENSION - Both parties' pension plans are defined contribution plans that can be valued by using the account statements. Defendant does not anticipate the need to have an expert value the '. pensions. Defendant reserves the right to have an expert value any of the pensions if necessary to present her case. VIII. COUNSEL FEES - Defendant has made a claim for Plaintiffto pay her reasonable counsel fees, costs and expenses. Defendant reserves the right to present evidence of the counsel fees, costs and expenses she has incurred in defending against this action. IV. VALUE OF DISPUTED PERSONAL PROPERTY - Defendant believes the parties should be able to agree on the values ofthe personal property. lfnot, Defendant intends to have an expert appraise the personal property and reserves the right to offer evidence of the personal property value at the hearing. IX. DEBTS - See Defendant's Inventory attached hereto as Exhibit A. X. PROPOSED RESOLUTION - The value of the marital assets should be divided evenly, with each party receiving 50% of the total value. Defendant should be awarded the marital home. The funds held in Plaintiffs name, allegedly for the benefit of his aunt, should be considered marital property since they were gifts by his aunt to both parties. Plaintitr s claim for alimony should be denied because he has no need for alimony and is cohabiting with his paramour, Holly McKean. SMIGEL, ANDERSON & S , LLP -~..~ BY:~."\ Ja es -: Demmel, Esquire LD. #90918: 44 orth Front Street Harrisburg, P A 17110 (717) 234-2401 Attorney for Defendant ------- - .\ ~ / \ \b\ . (I If' ' Y (iNVENTORY & APPRAlSEMENT( ASSETS OF PARTIES Karen S. Urich marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. (X) I. (X) 2. (X) 3. (X) 4. (X) 5. (X) 6. () 7. () 8. () 9. (X) 10. () I!. () 12. () 13. () 14. () 15. () 16. () 17. (X) 18. (X) 19. () 20. () 2l. () 22. () 23. () 24. (X) 25. () 26. Real property Motor vehicles Stocks, bonds, securities and options Certificates of deposit Checking accounts, cash Savings accounts, money market and savings certificates Contents of safe deposit boxes Trusts Life Insurance policies (indicate face value and current beneficiaries Annuities Gifts Inheritances Patents, copyrights, inventions, royalties Personal property outside the home Businesses (list all owners, including percentage of ownership, and officer/director positions held by a party with company.) Employment termination benefits - severance pay, workman's compensation claim/award Profit sharing plans Pension plans (indicate employee contribution and date plan vests) Retirement plans, Individual Retirement Accounts Disability payments Litigation claims (matured and unmatured) Military/V.A. benefits Education benefits Debts due, including loans, mortgages held Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute Other 10/27/2005 Inventory and Appraisement MARITAL PROPERTY - URICH I Property Description T fu;""Y -- No. Date i Valued Value I I la 136 Sherwood Circle 07/21/2004 $ 166,000.00 $ 166,00000 -- f-----~ ~. I Blue Ridge Memorial Cemetery Lot 07/13/2004 $ 1,275.00 $ 1,275.00 Ie Blue Ridge Memorial Cemetery Vault 07/13/2004 $ 935.00 $ 935.00 -- 2a 1994 Chevy Astro Van - Husband To be determined To be determined 2b 1996 Chevy Suburban - Wife To be determined To be determined l---~ ~-J2003 Chevy S-10 Pickup - Husband To be determined~ To be determined J.'L_~alard 27' travel camper To be determined To be determine~~ 3 Iu.s. Savings Bonds 12/01/2004 $ 14,127~1 $_ ~2750 4a Fulton Bank CD #0352 OS/28/2004 $ 2,317.61 $ 2,317.61 4b Fulton Bank CD #0337 05/30/2003 $ 2,29146 $ 2,29146 .1- ~. Waypoint Checking #7146. Husband 02/23/2004 $ 642.60 $ 642.60 5b Waypoint Checking #2468 - Wife 02/23/2004 $ 35604 $ 356.04 5c Cash from lockbox - Husband $ 2,800.00 $ 2,800.00 02/23/2004 $ -- $ 6a Waypoint Savings #9894 - Husband 1,00477 1,004.77 6b Waypoint Savings #1263 - Wife 02/23/2004 $ 876.00 $ 876.00 lOa Prudential Annuity # 160 1 12/31/2003 $ 5,177.59 $ 5,177.59 lOb TransAmerica Annuity #2RB2 12/31/2003 $ 8,82202 $ 8,822.02 .lQc Hartford Insurance Annuity #6596 03/17/2004 $ 12,912.67 $ 12,912,67 IOd Bankers Life Annuity #5987 To be determined To be determined lOe Bankers Life Annuity #9000 To be determined To be determined 10f Prudential Annuity #4912 To be determined To be determined 18a Empire Blue Cross Pension - Wife 12/31/2003 $ 28,973.29 $ 28,973.29 18b RAB Retirement Plan - Husband To be determined To be determined 19a New York Life IRA #417 - Wife 12/3112003 $ 32,35207 $ 32,352.07 19b New York Life IRA #702 - Husband 12/31/2003 $ 1O,995~00 $ 10,995.00 19c M&T Bank Roth IRA #9121 - Husband 12/31/2003 $ 3,448.97 $ 3,448.97 19d M&T Bank Roth IRA #9130 - Wife 12/31/2003 $ 3,44897 $ 3,448.97 25a Household goods To be determined To be determined 25b Coin collection To be determined To be determined 25c Toy car collection To be determined To be determined 25d Gun collection To be determined To be determined 25e Baseball card collection To be determined To be determined 25f Comic book collection To be determined To be determined I LIABILITIES OF PARTIES Karen S. Urich marks on the list below those items applicable to the case at bar and itemizes the liabilities on the following pages. (X ) 1. () 2. () 3. (X) 4. () 5. () 6. () 7. () 8. () 9. () 10. () 11. () 12. () 13. () 14. () 15. SECURED Mortgages Judgments Liens Other secured liabilities UNSECURED Credit card balances Purchases Loan payments Notes payable Other unsecured liabilities CONTINGENT OR DEFERRED Contracts or Agreements Promissory notes Lawsuits Options Taxes Other contingent or deferred liabilities 10/27/200510:36 AM LIABILITIES AS OF SEPARATION ! I Balance ~~ No. Nature of Debt ~- 1 Mortgage - Marital Home $ 11,00000 2 Auto Loan - 2003 Chevy Pickup To be determined ~ t'h\b.t 13 INCOME STATEMENT OF KARFNS llRYCH Employer: Empire Medicare Services (Wellchoice, Inc.) Type of Work: Business Associate Pay Period: biweekly Gross Pay per Pay Period $1,494.98 Itemized Payroll Deductions $468.23 Federal Withholding $170.02 Social Security $99.01 Medicare $23.15 Local Wage Tax $25.55 State Income Tax $49.02 Benefits Costs $101.48 Net Pay per Pay Period $1,026.75 1----- EXPENSES I 1--- I Weekly (or) ~Il1 Monthly (or) Yearly -t- HOME I Maintenance $ 6.40 $ 27.73 $ 33274 Electricity $ 28.85 $ 125.00 $ 1,500.00 Telephone (landline & cell) $ 26.54 $ 115.00 $ 1,38000 Water $ 10.38 $ 45.00 $ 540.00 Sewer & Trash $ 6.92 $ 30.00 $ 360.00 EMPLOYMENT Lunches $ 2500 $ 108.33 $ ],300.00 TAXES -- -- Real Estate Taxes $ 36.54 $ 158.33 $ 1,900.00 Personal Propelty Taxes $ 1.85 $ 8.00 $ 9600 -- INSURANCE Homeowners Insurance $ 10.21 $ 44.25 $ 531c~ Automobile Insurance $ 9.69 $ 42.00 I $ 504.00 Life Insurance $ 3.77 $ 1635 $ 196.20 AUTOMOBILE Automobile Fuel $ 60.00 $ 260.00 $ 3,120.00 Automobile Maintenance $ 38.46 $ 166.67 $ 2,00000 MEDICAL Doctor $ 115 $ 5.00 $ 60.00 Dentist D- 1.92 $ 8.33 $ 100.00 1$ c--'--.. Medicine 1.92 $ 8.33 $ 100 00 Optharnologist 1$ 9.62 $ 4167 $ 500.00 EDUCATION Education Expenses $ 102 $ 4.42 $ 53.00 School Lunches $ 15.00 $ 65.00 $ 780.00 School Sports (Shannon) $ 6.34 $ 27.46 $ 329.50 PERSONAL I I Clothing $ 11.54 $ 50.00 $ 600.00 Food $ 65.00 $ 281.67 $ 3,38000 Barber/Hairdresser $ 3.85 $ 16.67 $ 200.00 Blockbuster $ 6.00 $ 26.00 $ 312.00 BJs Wholesale Club $ 0.67 $ 2.92 $ 35.00 Sarns Club $ 0.67 $ 2.92 $ 35~~ AM $ 1.21 $ 5.25 $ 63.00 MISCELLANEOUS Papers/Books/Magazines $ 1.85 $ 8.00 $ 96.00 Entertainment $ 2769 $ 120.00 $ 1,440.00 Pay TV $ 9.75 $ 4224 $ 506.88 Vacations $ 57.69 $ 250.00 $ 3,000.00 Gifts $ 38.46 $ 166.67 $ 2,000.00 Charitable Contributions $ 1.06 $ 4.58 $ 55.00 Total Exoenses $ 527.02 $ 2,283.79 $ 27,405.32 FRED A. URICH, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2004-2503 KAREN S. URICH, DEFENDANT CIVIL ACTION - DIVORCE CERTIFICATE OF SERVICE I, James R. Demmel, Esquire, counsel for Defendant in the above-captioned matter, do hereby certify that I served a true and correct copy of the foregoing Pre-Trial Statement on counsel for the Plaintiff by depositing same in the U.S. Mail, first class, postage paid, on the Z r day of October, 2005. addressed as follows: SAMUEL L. ANDES, ESQUIRE 525 NORTH 12TH STREET P.O. BOX 168 LEMOYNE, P A 17043 SMIGEL, ANDERSON & SACKS, LLP By: J 44 orth Front Street Harrisburg, PA 17110 (717) 234-2401 Attorney for Defendant . #: 90918 .,... tG t~, (,.-' u! ~__' "'u 1.1_ - ),-r=- {,,} (-j \:~;:-\L:. ~:]tJJ \...i- -1- ~: LL o en ';:.;J J" ,- r..:,- cn I -"- ~::;") ~.)~ ,",,'''''' ~;~~ = <.... , u .. FRED A. URICH, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2004-2503 KAREN S. URICH, DEFENDANT : CIVIL ACTION ~ DIVORCE (,FRTTFT(,A TF OF SFRVT('F. I, James R. Demmel, Esquire, counsel for Defendant in the above-captioned matter, do hereby certify that I served an original and one (I) copy of Defendant's Request for Production of Documents to Plaintiff on counsel for the Plaintiff by depositing same in the U.S. Mail, first /.) class, postage paid, on the ,L-. day of January, 2006, addressed as follows: SAMUEL L. ANDES, ESQUIRE 525 NORTH 12TH STREET P.O. BOX 168 LEMOYNE, P A 17043 SMIGEL, ANDERSON & SACKS, LLP By: /-~.'" (-...., \ i \ ./ : 1 .;:-1 *=-" J~R. Demme1, Esquire J.D. 90918 4431 ~h Front Street Harrisburg, P A 1711 0 (717) 234-2401 AttomeysfurDerendant - 9 - '-, , c.:: " " , " " " " " " " " " " II 'I Ii Ii " " 'I " I: " " " II " II " " " II Ii " I ~ FRED A. URICH, PLAINTIFF v. KAREN S. URICH, DEFENDANT ~ ~ : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2004-2503 : CIVIL ACTION - DIVORCE CFRTlFf('ATF OF SFRVTCF J, James R. Demmel, Esquire, counsel for Defendant in the above-captioned matter, do hereby certify that I served an original and one (1) copy of Defendant's Interrogatories to Plaintiff II II II " 'I II II " Ii " " " II II II " ,I II II " Ii " 'I I, II II Ii Ii II II II " II " I, II " " " II " " " I' II " 1\ II on counsel for the Plaintiff by depositing same in the U.S. Mail, first class, postage paid, on the f 1.- day of January, 2006, addressed as follows: I SAMUEL L. ANDES, ESQUIRE 525 NORTH 12TH STREET P.O. BOX 168 LEMOYNE, P A 17043 SMIGEL, ANDERSON & SACKS, LLP (:---~ \\.. (--".i ". .. \.. I -..; By: (-J~;1t.-temm~i:Es~ui~e iD. 90918 \. 44~1 orth Front Street Harrisburg, P A 1711 0 (717) 234-2401 Attorneys for Defendant t-H (-- ^" ,"" 0) SMIGEL, ANDERSON & SACKS, LLP James R. Dernmel, Esquire ID #90918 4431 North Front Street Harrisburg, P A 17110-1709 (717) 234-2401 idemmel(ivsasllp.com Attorneys for Defendant FRED A. URICH, PLAINTWF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2004-2503 KAREN S. URICH, DEFENDANT CNIL ACTION - DNORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301(c) of the Divorce Code was filed on June 3, 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. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: CD I I I 0 ~ ~~ ~ J~ Karen S. Urich, Defcndan a ~~: -:::::1 -<. l'.) = => ~ L c:: z: o .." --l :C-n m;= -;:J~ .. CJ .......~I :') --L, =j~.f: ,- ,.~ -~ 1 Jc'") Zrn S? ~ =< I N :!::: ...;..;.:.. \.D -.J /JRD/smm/lMay31,200611:31 AM SMIGEL, ANDERSON & SACKS, LLP James R. Demme1, Esquire ID #90918 4431 North Front Street Harrisburg, PA 17110-1709 (717) 234-2401 idemme!u/;sasl\p.com Attorneys for Defendant FRED A. URICH, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2004-2503 KAREN S. URICH, DEFENDANT CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 63301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary . I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: fR I, I () " I'-..) = '= 0-. C- C ::,f: o "Tl :;:J Ri::!J r- -'~J Q..l ~~~ c;;;c') :.5fn :--1 J" :n -< I N J::;."t ::t: ,..::> -.I FRED A. URICH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04 - 2503 CIVIL KAREN S. URICH, Defendant IN DIVORCE ORDER OF COURT AND NOW, this ,Bt-t day of ~ Lto entered into an 2006, the parties and counsel having agreement and stipulation resolving the economic issues on June 1, 2006, the date set for a Master's hearing, 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. cc: .;Samuel L. Andes Attorney for Plaintiff ~ ~mes R. Demmel Attorney for Defendant \.9 ~f;) <<\ o .ry (-...1' U.. l." -T" >= !.L (-::~ ~ w_ (;::) LC' c::; ,..... (3 , " " . ." - FRED A. URICH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 04 - 2503 CIVIL KAREN S. URICH, Defendant IN DIVORCE THE MASTER: Today is Thursday, June 1, 2006. This is the date set for a hearing in the above-captioned divorce proceedings. Present in the hearing room are the Plaintiff, Fred A. Urich, and his counsel Samuel L. Andes, and the Defendant, Karen S. Urich, and her counsel James R. Demmel. This action was commenced by the filing of a complaint in divorce on June 3, 2004, raising grounds for divorce of irretrievable breakdown of the marriage. The Master has been provided an affidavit of consent and waiver of notice of intention to request entry of divorce decree signed and dated today by the Defendant; Mr. Andes, counsel for the Plaintiff, indicated he will file his affidavit and waiver within the next couple of days with the Prothonotary so that the divorce can proceed under Section 330l(c) of the Domestic Relations Code. The complaint also raised economic claims of equitable distribution, alimony, alimony pendente lite, and counsel fees and expenses. 1 " . ; The parties were married on November 29, 1985, and separated April 2004. The parties have two natural children, and the one child is emancipated, the other child, a daughter, resides with the wife. The Master has been advised that after negotiations today and previously, the parties have reached a comprehensive 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 stated 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. Counsel have requested that the transcribed agreement be sent to counsel for review for typographical errors, counsel will make any corrections as required, and then the parties will be asked upon receipt of a completed document to sign the agreement affirming the terms of settlement as stated on the record. However, it is specifically noted that in the event the agreement is not signed affirming the terms of settlement, nevertheless, the parties are bound by the terms of settlement with respect to the substantive agreement as stated on the record when they leave the hearing room today. Upon receipt by the Master of a completed agreement, the Master will prepare an order vacating his 2 " M~I(~~ 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 the economic claims in this matter and to conclude the divorce on the following terms: 1. The parties have agreed that they will divide their marital property, which is identified on the document we will attach as Joint Exhibit A to the transcription of this stipulation by the wife receiving those items listed in the column which is identified "distribute to wife" and with husband receiving those items identified "distribute to husband". Many of those assets have already been distributed in the sense that they are already held in the names of one of the parties. However, to complete that transfer the parties will do the following within thirty (30) days of the date of this agreement: a) Transfer the title to the 1996 Chevrolet Suburban motor vehicle to wife and the title to the 1994 Chevrolet Astro van and the llalara- camper trailer to husband. They will do that by wife taking the titles to those vehicles in her possession to the Triple A and signing whatever documents are necessary there to complete the transfer, after which husband shall separately come to Triple A and complete the documents and sign the documents necessary to complete the transfer. The parties understand that it is possible that neither of them has the title to the 1994 van in which event they will execute whatever documents are required to have a duplicate title issued in husband's name alone. b) Husband will obtain the documents necessary to transfer the cemetery lot and vault to his name alone and present them to wife to be completed and signed by her and returned to husband. Husband will then be responsible to file the documents necessary to complete the transfer of those assets into his name alone. c) Wife shall take whatever action is necessary to transfer to husband's name alone the U.S. savings bonds currently registered in her name. In the event that husband's participation in that transaction is required, she 3 , ~.~ fr- l will notify him of that and make arrangements to get those documents signed and delivered to husband or to the transfer agent so that the transfer can be made without delay. d) Wife shall deliver to husband the certificates of deposit held with Fulton Bank and execute and deliver to husband any documents necessary to transfer those to his name alone in the event that they are held in her name or in joint names. e) Wife shall cause her attorney to prepare a deed to transfer 36 Sherwood Circle to her name alone and her attorney shall deliver it to husband's attorney. Husband shall sign and acknowledge the deed and it will be held by his attorney until delivered by husband's attorney to wife's attorney at the time wife refinances the house to fund the cash payment to husband provided for below. 2. As part of the equitable distribution of the marital property, wife shall pay husband a cash payment of $87,000.00. The payment shall be made upon her obtaining a mortgage on the residence at 36 Sherwood Circle which shall be accomplished within sixty (60) days of today's date. 3. There is a Section 525 college expense account with Putnam aeSsuRt created during the marriage and held in husband's name for the benefit of the parties' daughter Shannon. Husband shall within thirty (30) days of today's date take whatever action is necessary to transfer the account to Shannon's name alone if permitted under the plan and the law or, if not so permitted, transfer the account to wife's name in which event wife shall be responsible to hold and manage the account for the benefit of Shannon hereinafter. 4. All other claims, specifically including claims for alimony, counsel fees, rental value of the residence, and the equitable distribution of household goods, are hereby waived by both parties and the parties agree to accept the division of assets set forth in this stipulation as the final equitable distribution of their marital property and the resolution of all pending claims in this action. 5. The parties acknowledge that some of the claims they raised earlier in this case were resolved by a stipulation entered before the Master on April 4, 2006, and the parties acknowledge that stipulation, agree to be bound by it, and agree that it resolves some of the issues previously raised in the case. 4 ~ 6. 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: Mr. Urich, did you hear the stipulation that I just dictated on the record? MR. URICH: Yes. MR. ANDES: Have you reviewed the document we now marked as Joint Exhibit A? MR. URICH: Yes. MR. ANDES: As to the assets that you are to receive and those your wife is to receive? MR. URICH: Yes. MR. ANDES: Are you satisfied with this settlement as it has been recited today? MR. URICH: Yes. MR. ANDES: Are you willing to accept that as resolving all of the economic claims raised in this divorce action? MR. URICH: Yes. (An off the record discussion was held.) 5 .' MR. DEMMEL: The parties do hereby warrant, represent and declare and acknowledge and agree that each has been fully and completely informed of and is familiar with the real and/or personal property, earnings and income of the other and that each has made a full and complete disclosure to the other of his or her entire assets and liabilities and any further enumeration or statement thereof in this agreement is specifically waived. THE MASTER: Mr. Urich, you have heard the addition to the agreement? MR. URICH: Yes. THE MASTER: And you have answered Mr. Andes' questions regarding the statement of the agreement on the record previously, do you agree to this addition to the agreement? MR. URICH: Yes. THE MASTER: Do you understand it. MR. URICH: Yes. I guess it just is MR. ANDES: You've told the truth? MR. URICH: Yes. MR. DEMMEL: Mrs. Urich, you have heard and understood the agreement that has been put on the record today? MS. URICH: Yes. MR. DEMMEL: Do you agree to the terms of 6 "', .. this agreement as a final settlement of the divorce and related claims in this matter? MR. URICH: Yes. 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: ~ 30 ~11€~ ~lI1dL F'red A. Urich Attorney for Plaintiff emmel for Defendant 1\\\\11(" --Kcv-- ~ LJ--L Karen S. Urich 7 -~_.. ,.O~/~O/2006 10:57 AM Inventory and Appraisement - Karen Urich MARITAL PROPERTY - URICH No. Property Description Date EQulty Distribute Distribute -" Valued Value toWife to Husband la 36 Sherwood Circle 03/07/2006 $ 195,000.00 $ 195,000.00 $ 195,000.00 Ib Blue Ridge Memorial Cemetery Lot 07/13/2004 $ 1,275.00 $ 1,275.00 $ 1,275.00 lc Blue Ridge Memorial Cemetery Vault 07/13/2004 $ 935.00 $ 935.00 $ 935.00 -:-- 1994 Chew Astro Van - Husband 03/3112004 $ $ $ 2a - - - 2b 1996 Chevy Suburban - Wife 03/31/2004 $ - $ - $ - 2c 2003 Chevy S-IO Pickuo - Husband $ - $ ,- $ - 2d Malard 27' travel camper $ 5,000.00 $ 5,000.00 $ 5,000.00 3a U. S. Savings Bonds 03/1912006 $ 15,144.94 $ 15,144.94 $ 15,14494 3b Prudential Stock #4912 07/16/2004 $ 643.44 $ 643.44 $ 643.44 4a Fulton Bank CD #0352 03/22/2006 $ 2,401.59 $ 2,401.59 $ 2,401.59 4b Fulton Bank CD #0337 03/22/2006 $ 2,347.30 $ 2,347.30 $ 2,347.30 5a Waypoint Checking #7146 - Husband 02/23/2004 $ 642.60 $ 642.60 $ 642.60 5b Waypoint Checking #2468 - Wife 02/23/2004 $ 356.04 $ 356.04 $ 356.04 -:-. Cash from lockbox. - Husband $ 2,800.00 $ 2,800.00 $ 2,800.00 ~- 6a Wavooint Savings #9894 - Husband 02/23/2004 $ 1,004.77 $ 1,004.77 $ 1,004.77 6b Waypoint Savings #1263 - Wife 02/23/2004 $ 876.00 $ 876.00 $ 876.00 }(Ja Prudential Annuitv#1601 12/31/2005 $ 5,578.87 $ 5,578.87 $ 5,578.87 Wb TransAmerica Annuity #2RB2 12/3112005 $ 10,997.38 $ 10,997.38 $ 10,997.38 We Hartford Insurance Annuitv #6596 . 03/17/2004 $ 2,912.67 $ 2,912.67 $ 2,912.67 IOd Bankers life Annuity #5987 .. $ - $ - $ - 10e Bankers Life Annuitv #9000 ... $ - $ - $ - Wf Prudential Policv#21560876 18" Emoire Blue Cross Pension - Wire 12/31/2003 $ 28,973.29 $ 28.973.29 $ 28,973.29 1811 RAE Retirement Plan - Husband 12/31/2003 $ 116.84 $ 116.84 $ 116.84 1901 New York Life IRA #417 - Wife 12/3112005 $ 37,639.81 $ 37,639.81 $ 37,639,81 19iJ New York life IRA #702 - Husband 12/3112005 $ 12,764.65 $ 12,764.65 $ 12,764.65 19c M&T Bank Roth IRA #9121 - Husband 12/3112005 $ 3,672.97 $ 3,672.97 $ 3,672.97 .!2d M&T Bank Roth IRA #9130 - Wife 12/31/2005 $ 3,672.97 $ 3,672.97 $ 3,672.97 - Household goodslPersonal mooertv Alreadv divided ?< Already divided ::.:: -. -" Totals $ 334,756.13 $ 334,756.13 $ 266,518.11 $ 68,238.02 - 53/47 split - $ 177,420.75 $ 157,335.38 - (89,097.36) Difference $ 89,097.36 $ ~or ~~~ PL l.{ d 10& 1E- FRED A. URICH, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, ) PENNSYLVANIA I vs. ) CIVIL ACTION - LAW ) ) NO. 2004-2503 KAREN S. URICH, ) Defendant ) IN DIVORCE AFFIDA vir OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 3 June 2004, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree, WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301lcl 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 I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa, C.S, Section 4904 relating to unsworn falsification to authorities, 'r Is ~.tI C> Lo Dated: iii (l aJ FRED A, URICH --,-l :..::-~ c.) - \~':~- en r: Defendant ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FRED A. URICH, Plaintiff vs. CIVIL ACTION -LAW NO. 2004-2503 KAREN S. URICH, IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c). 2. Date and manner of service of the Complaint: Acceotance of Service flied bv Plaintiff's counsel on 10 June 2004 indtcattna service on Defendant. Drtor to 10 June 2004. 3. Complete either Paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code: By Plaintiff: 24 Julv 2006 by Defendant: 2 June 2004 (b) (1) Date of execution of the Affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: 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, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in Section 3301 (c) Divorce was flied with the Prothonotary: Dated 24 Julv 2006 and flied contemDOraneouslv herewith. Date Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: Flied on 2 June 2006. Date: 24 July 2006 -~ Samuel L. Ande Attorney for Defendant j ~- ,\' , 1 j J I j , j :1':;, " f " " cc- :::;1 . ;,;<oi c') IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. FRED A. URICH, Plaintiff N 2004-2503 O. VERSUS KAREN S. URICH, Defendant . DECREE IN DIVORCE . AND NOW, ~I FRED A. URICH ...;r cJ.' sJ~'/J1 2006 I , IT IS ORDERED AND . DECREED THAT , PLAINTIFF, AND KAREN S. URICH , 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 . . . ATTEST: J. ~b~~ROTHO'OTAR' P,/'''tl P ~ "?) r1J>fI ~ I}(J- ["'.~ ~ ~ ~ /tJ~ ~ -~ ~I?, f..,$ , .~, . . ,,, .' 4; ...;: )-:,..... " .....)' l' \ ,