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HomeMy WebLinkAbout04-5638VONDA L. FARLLING, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 04- 5'6 3 S' CIVIL TERM GEORGE A. FARLLING, SR., Defendant : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may 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. 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 CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PENNSYLVANIA 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 Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: 717-249-3166 ' k Wayne V Shade, Esquire 4" 7C Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 WAYNE F. SHADE Attorney for Plaintiff Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 VONDA L. FARLLING, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 04- Sb 3 8 CIVIL TERM GEORGE A. FARLLING, SR., Defendant : IN DIVORCE COMPLAINT COUNTI DIVORCE 1. Plaintiff in this Action in Divorce is VONDA L. FARLLING, an adult individual who resides at 701 Bloserville Road, Newville, Cumberland County, Pennsylvania 17241. 2. Defendant is GEORGE A. FARLLING, SR., an adult individual and citizen of the United States of America who may be served at G.A. Farlling Garage, 654 Bloserville Road, Newville, Cumberland County, Pennsylvania 17241. 3. Defendant has been a bona fide resident of Cumberland County, Pennsylvania, for more than six months previously to the filing of this Complaint and continuing to the commencement of this Action in Divorce. 4. WAYNE F. SHADE Plaintiff and Defendant were lawfully joined in marriage on November 21, 1965, Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 in Bloserville, Cumberland County, Pennsylvania. 5. The parties have been living separate and apart since on or about August 20, 2004. 6. Plaintiff avers as the grounds on which this action is based that the marriage of the parties is irretrievably broken. In the alternative, Plaintiff avers as the grounds on which this action is based that Defendant has committed adultery and has otherwise offered such indignities to the person of the Plaintiff, the innocent and injured spouse, as to render the condition of Plaintiff intolerable and the life of Plaintiff burdensome. 7. There have been no prior actions for divorce or annulment of this marriage in Pennsylvania or in any other jurisdiction. 8. This Action in Divorce is not collusive. 9. Both parties to this Action in Divorce are legally capable of managing their own concerns. 10. Defendant herein is not a member of the armed forces of the United States of WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 America. -3- 11. There were two children born to the parties, both of whom are independent adults. 12. Plaintiff has no adequate means of support for herself. 13. 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. WHEREFORE, Plaintiff demands judgment dissolving the marriage between the parties. COUNT II EQUITABLE DISTRIBUTION 14. The averments of Paragraphs 1 through 13 inclusive above are incorporated herein by reference as though fully set forth. 15. Plaintiff and Defendant possess various items of marital property which are subject to equitable distribution by the Court. WHEREFORE, Plaintiff demands judgment equitably distributing all marital property owned by the parties and such further relief as the Court may deem equitable and WAYNE F. SHADE Attorney at Law Just. 53 West Pomfret Street Carlisle, Pennsylvania 17013 -4- COUNT III ALIMONY AND ALIMONY PENDENTE LITE 16. The averments of Paragraphs 1 through 13 inclusive above are incorporated herein by reference as though fully set forth. WHEREFORE, Plaintiff demands judgment compelling Defendant to pay to Plaintiff alimony and alimony pendente lite. COUNT IV COUNSEL FEES, EXPENSES AND COSTS 17. The averments of Paragraphs 1 through 13 inclusive above are incorporated herein by reference as though fully set forth. WHEREFORE, Plaintiff demands judgment compelling Defendant to pay counsel fees, expenses and costs of Plaintiff. Wayne hade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 -5- I verify that the statements made in this pleading 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: November 4, 2004 4"o Vonda L. Farlling WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 F 361 (J W d V V `A, ? a Q w C) R ?. l N CZ) f ldJ ?eM L? C-7 ` f -71 f '} VONDA L. FARLLING, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 04-5638 CIVIL TERM GEORGE A. FARLLING, SR., Defendant : IN DIVORCE AFFIDAVIT OF SERVICE WAYNE F. SHADE, ESQUIRE, certifies that he is counsel for Plaintiff in the above-captioned matter, that he did, on November 9, 2004, serve the Complaint in Divorce in the above-captioned matter upon Defendant by certified United States mail, postage prepaid, return receipt requested, addressee only, and that the same was received by Defendant on November 10, 2004, as evidenced by the return receipt card attached hereto bearing Certified No. 7099 3400 0018 5044 8561. It is understood that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: November 17, 2004 4z" Z?_ Wayn . Shade WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 a ..0 Ln r .o - Postage $ .60 0 `r' Certified Fee 2.30 - ' 6 t t F R R i NOV64, j i 9 , c4 urn ee e ece p (Endorsement Required) 1.75 e 2004 ra p O Restricted Delivery Fee (Endorsement Required) 3.50 O Total Postage & Fees $ 8.15 C3 = m Reci ient s Name (Please Print Clearly (to be completed by mailer) deorge Farlin g Sr- ? A Cr _ . ----- - ---- ----------------------- Street, Apt. No.; or PO Box No. 654 Bioserville•.RO le , PA 17241 ,'IN Cortoete ft". 1. 2, end S. Atic ,_ f Item 4 If Restiiated 0*11very is deshed. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to' the back of the mailpiece, or on the front If space permits. 1. Article Addressed to: George A. Farlling, Sr. G.A. Farlling Garage 654 Bloserville Road Newville, PA 17241 r.a '?7 flY CA3 ( r) CO ? Agent ? Addressee a. Received by (Pft) d Narrre) C. of Delivery D. Is delivery address different Tian item 11 Tes If YES, enter delivery address below: No 3. Service Type X1 Certified Mail ? Express Mail ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. 'Pip 2. Article Number 7099 3400 0018 5044 8561 (rranebr iron swvko label) PS Form 3811, AWW 2Wi poraesic i4mum Receo, ,Deere oe-lµas3s VONDA L. FARLLING, Plaintiff, V. GEORGE A. FARLLING, SR., Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-5638 IN DIVORCE PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please enter my appearance on behalf of Defendant, GEORGE A. FARLLING, SR, in the above-captioned action. Dated: December 1, 2004 Respectfully submitted, CALDWELL & KEARNS By: Stanley J. A. a kowski, Esquire Attorney I.D. 437422 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 04786/81735 (`? !", J C? ? `C°' t ? :-? ? ...r.. _"? ?? ? r C•-? _. . _ _' r i l1 ? ? -i? ????i ? ? . ' ?' .-- { ? , ? 11-1' ? a _ ?- ., C?,? .. ? r i?E .-c .?.? i V ^'i' 7 VONDA L. FARLLING, Plaintiff V. GEORGE A. FARLLING, SR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-5638 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE PRAECIPE FOR WITHDRAWAL OF COUNSEL AND APPEARANCE OF COUNSEL TO THE PROTHONOTARY: Please note my withdrawal as counsel for Vonda L. Farlling, Plaintiff in the above matter. Dated: 6G, 1a c 1' BY: Wayrfe F. Shade, Esquire Pa I.D. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 (717) 243-0220- Kindly enter our appearance on behalf of Vonda L. Farlling, Plaintiff in the above matter. Dated: I 6. e ,- O'BRIEN, BARIC AND SCHERER BY: ! Michael-A. AScherer Pa I.D. 61974 19 West South Street Carlisle, PA 17013 (717) 249-6873 rn VONDA L. FARLLING, Plaintiff, V. GEORGE A. FARLLING, SR., Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-5638 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S MOTION TO COMPEL .ANSWERS TO DISCOVERY DIRECTED TO PLAINTIFF AND NOW, comes Defendant, George A. Farlling, Sr., by and through his attorneys, Caldwell & Kearns, P.C., and makes the following motion to compel Plaintiffs answers to discovery directed to Plaintiff, averring in support thereof as follows: On or about October 14, 2005, Defendant served upon Plaintiffs counsel discovery in the form of and titled Defendant, George A. Farlling's Interrogatories to Plaintiff- First Set. See Exhibit "A" attached hereto and incorporated herein by reference. 2. By letter dated November 17, 2005, Defendant's counsel reminded Plaintiff's counsel that a response to Defendant's discovery request was overdue and requested such response within seven (7) business days thereof. See Exhibit "B" attached hereto and incorporated herein by reference. To date, Plaintiff has failed to provide responses to Defendant's discovery request. 4. Plaintiff s counsel has not asked for nor has been granted an extension to answer the discovery requests. 5. Plaintiffs responses to Defendant's discovery requests were originally due on or about November 13, 2005. 6. Pennsylvania Rule of Civil Procedure 4005 authorizes any party in an action to serve written interrogatories upon an adverse party. ,,/G,, bit ? VONDA L. FARLLING, Plaintiff V. GEORGE A. FARLLING, SR., Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-5638 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE DEFENDANT, GEORGE A. FARLLING'S INTERROGATORIES TO PLAINTIFF - FIRST SET To: Vonda L. Farlling c/o Michael A. Scherer, Esq. O'Brien, Banc & Scherer 19 W. South Street Carlisle, PA 17013 PLEASE TAKE NOTICE that you are required by Pennsylvania Rules of Civil Procedure to file your Answers in writing and under oath to the attached Interrogatories within thirty (30) days from the date of service thereof and also required thereby to serve a copy thereof upon the undersigned representing the Plaintiff in this action. You are further notified that if you later receive or learn of any information not supphed in your Answers to these Interrogatories, you are required by the Rules of Civil Procedure to supply the undersigned with such information in the form of supplemental Answers to these Interrogatories. Date: October 14, 2005 R ully s mitt?dd By: Stanley J. ,Laskowski, Esquire Attorney I.D. No. 37422 Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 (717) 232-2766 (fax) Attorney for Defendant, George A. Farlling, Sr. DEFENDANT'S INTERROGATORIES TO PLAINTIFF DEFINITIONS The following definitions are applicable to and incorporated by reference into each interrogatory: A. The term "Mrs. Farlling", as used herein, means the Plaintiff, Vonda L. Farlling, and each and every one of his current or former agents, employees, attorneys and other persons acting or purporting to act on her behalf. B. The term "Mr. Farlling", as used herein, means the Defendant, George A. Farlling, Sr., and each and every one of her current or former agents, employees, attorneys and other persons acting or purporting to act on his behalf. C. The term "Business", as used herein, means any other commercial enterprise and each and every one of their subsidiaries, affiliates and divisions, wholly owned or not, past and present, and each and every one of their predecessors and successors in interest, and any present and former officers, directors, agents, employees, attorneys and other persons acting or purporting to act for or on their behalf. D. The term "person", as used herein, means any natural person, partnership, corporation, or other business entity and all present and former officers, directors, agents, employees, attorneys and others acting or purporting to act on behalf of such natural person, partnership, corporation or other business entity. E. The term "document", as used herein, means the original and all copies of any written, printed, typed or other graphic matter of any kind or nature and any other tangible thing in the custody or control of Mrs. Farlling or known by Mrs. Farlling to exist, including but not limited to: 1. All contracts, agreements, letter agreements, representations, warranties, certificates and opinions, I 2. All letters or other forms of correspondence or communication, including envelopes and notes, telegrams, cables, telex messages and messages, including reports, notes, notations and memoranda of or relating to telephone conversations or conferences; 3. All memoranda, reports, test results, financial statements or reports, notes, scripts, transcripts, tabulations, studies, analysis, evaluations, projections, work papers, corporate or partnership records or copies thereof, expressions or statements of policy, lists, comparisons, questionnaires, surveys, charts, graphs, summaries, extracts, statistical statements or records, compilations and opinions or reports of consultants or appraisals; 4. All desk calendars, appointment books and diaries; 5. All minutes, records or transcripts of meetings and conferences, and lists of persons attending meetings or conferences, 6. All reports and summaries of interviews and negotiations, 7. All books, articles, press releases, magazines, newspapers, booklets, brochures, pamphlets, circulars, bulletins, notices, instructions and manuals, 8. All microfilms, phonographs, tapes, punch cards, magnetic tapes, discs, (whether floppy or hard) data cells, drums, print-outs and other data compilations from which information can be obtained; and 9. Drafts of any document, revisions of drafts of any document and original or preliminary notes. F. The term "identify" when used with respect to a document, means to state the date; author; addressee, type of document (e.g. 'letter"), to identify its last known custodian and location: and to state the exhibit number of the document if it has been marked during the course of a court proceeding. ii G. The term "identify", when used with respect to an individual, means to give the person's full name; all known aliases, present or the last known business and home address, and present position or business affiliation. H. The term "identify", when used with respect to any other person, means to give the person's official, legal and formal name and/or the name under which the person acts or conducts business; the address of the person's place of business, profession, commerce or home, and the identity of the person's principal or chief executive officer or person who occupies the position most closely analogous to a chief executive. 1. The term "relate(s) to", or "refer(s) to" as used herein, means constitute(s), define(s), discuss(es), involve(s), concern(s), contain(s), embody(ies), reflect(s), identify(ies), state(s), analyze(s), mention(s), respond(s) to, refer(s) to, pertain(s) to, deal(s) with, comment(s) upon, or in any way logically or factually connect(s) with the matter described in the Interrogatory or the Request. J. The term "benefit plan", as used herein, means any plan, program, benefit, entitlement or policy including but not limited to. 1. All, retirement benefit plans, all retirement programs, plans and/or programs of all types, bonus plans or programs, defined benefit plans or programs, defined benefit pension plans or programs, unit credit plans or programs, defined contribution pension plans or programs, career average benefit plans or programs, non-employee retirement income security act plans, incentive plans or programs, thrift plans or programs, union plans or programs, savings plans or programs, salary reduction plans or programs, deferred compensation plans or programs, excess benefit plans or programs, offset plans or programs, top hat plans or programs, suppilemental benefit plans or programs, vested severance pay plans or programs, all types of pension plans or programs, contributory plans or programs, non- contributory plans or programs, vested benefit plans or programs, in unvested benefit plans or programs, stock ownership plans or programs, saving plans or programs, federal or state plans or programs, or profit sharing plans or program, 2. All medical insurance plans, policies or programs, life insurance plans, policies or programs, and all other insurance plans, policies or programs (including; but not limited to such things as annuities), 3. All medical benefits, dental care benefits, disability benefits, survivors' benefits, social security benefits, retirement benefits and annuities, and 4. All amendments, past, present and presently proposed to plans, programs, benefits, entitlements and policies mentioned above in paragraphs 1. through 3. and all amendments, past, present and presently proposed to plans, programs, benefits, entitlements and policies not mentioned above but related or in any way similar to such plans, programs, benefits, entitlements and policies. K. The term "participant" and all of its grammatical derivatives (i.e. participate, participates, participating, participated etc.) when used with respect to a person's participation in benefit plans, means a person who is involved in, covered by, a beneficiary of, protected by, contributing to, receiving money from, accepting coverage by or in any way becoming or being associated with any benefit plan. L. The term "you" or "your" refers to the person to whom these Interrogatories are addressed. M. The term "vested", when used with respect to a person's relationship to a benefit plan, describes a condition in which a participant in a benefit plan has any measure of autonomy or control over the funds contained within a benefit plan, or a condition in which a percentage of a participant's benefit becomes non-forfeitable. The term "unvested" when used with respect to a person's relationship to a benefit plan, describes rv a condition in which a participant in a benefit plan has no autonomy or control over the funds contained within a benefit plan or a condition in which a participant's benefit is forfeitable. RULES OF ONSTRUCTION In construing these Interrogatories; A. The singular shall include the plural and the plural shall include the singular. B. A masculine, feminine or neuter pronoun shall not exclude the other genders. C. All verbs are intended to include all tenses. D. "Any" as well as "all" shall be construed to mean "each and every." E. "And" as well as "or" shall be construed disjunctively as well as conjunctively, as necessary, in order to bring within the scope of these requests all information that might otherwise be construed to be outside their scope. F. Unless otherwise specified in the Interrogatory, each Interrogatory shall extend to all information and documents which have been, will be or are presently available to, in the possession of, or subject to the control of Mrs. Farlling. INSTRUCTIONS FOR INTERROGATORIES A. Each Interrogatory is to be answered in writing and under oath within thirty (30) days after service of the interrogatories. B. In answering these Interrogatories, you shall furnish all information in your possession and in the possession of your representative, agents, attorneys or employers. C. Each Interrogatory shall be answered separately and as completely as possible. The fact that investigation is continuing or that discovery is not complete is not an excuse for failure to answer each Interrogatory as fully as possible. If you are unable to answer an Interrogatory after you have attempted to obtain the information, answer to the extent possible. State what information you have concerning the unanswered portion, specify why you are unable to answer the remainder, and specify how you attempted to obtain the unknown information. D. If any form of privilege or other protection from disclosure is claimed as a ground for withholding responsive information contained in a document, set forth with respect to the document, the date, title, identity of the author, subject matter (without revealing the information for which privilege is claimed), and all facts or bases on which you claim the privilege. The claim should contain such specificity as to permit the court to make a full determination of its validity. E. For each Interrogatory: 1. Identify the person who has answered the Interrogatory. 2. Identify each document relied on, or which forms a basis for the answer, or which corroborates the answer given. Cite the specific pages of each document on which you rely. 3. Identify each person who assisted or participated in preparing and/or supplying any of the information given in answer to, or relied upon in preparing answers to, the Interrogatory. V1 INTERROGATORIES State your full name, address, and social security number, and if you have ever used or been known by any other name or alias, state such other name or names and the period during which such names were used. ANSWER: State your educational background, including the name of each college, university, graduate, technical, or trade school attended. ANSWER: 3. a) Are you presently employed? (Full and part-time employment included.) b) If your answer is in the affirmative, state fully and provide for each employment: The full name, address, and telephone number of your place of employment. i) The date you commenced your employment. iii) Your job title or position. iv) Attach proof of earnings from each employment (e.g., payroll stubs) for the past six (6) months. ANSWER: 4. For any/all of your previous employments (including periods of self-employment) during the past five years, please state: a. The name and address of your employer. b. The inclusive dates of employment. C. The nature, title, and description of the work performed. d. The gross annual compensation for each calendar year of such employment. ANSWER: 2 5. a) Attach copies of your complete personal federal and state income tax returns, with W-2 forms, schedules. and any amendments, for the past three years. b) Have all federal, state, and local income taxes been paid in full as the amounts set forth in the personal tax returns indicate? If not, state amounts due and the tax year(s) for which due. ANSWER: 6. Have you received or were you entitled to receive any bonuses during the past three (3) years? If so, state the amount of bonus received or amount you are entitled to receive, and detail when each was received or when you expect to receive the bonus. Summarize the terms of the bonus arrangement, including how the bonus was calculated. ANSWER: 3 7. Are you entitled to receive any deferred compensation by reason of your present or past employment? If so, please state the nature and amount of deferred compensation, and when you anticipate receiving such deferred compensation. ANSWER: 4 8. a) If you have any interest in any qualified or unqualified deferred compensation arrangement or retirement program, including, but not limited to, IRA, Keogh Plan, 401(k) Plan, military retirement, savings plan, annuity benefits, retirement plan, pension plan, profit sharing plan, stock bonus plan, stock option plan, or thrift plan (excluding social security benefits), with your present employer, or any previous employer, please designate and indicate the name and type of the retirement plan and provide a copy of the Summary Plan description and statements of the Plan for the past three (3) years. b) Have you elected to receive or have you received proceeds from any retirement benefit plan(s) as set forth in 7 or 10(a) above prior to the date of separation, to the present? If so, please state the type, nature and amount of benefits elected and the date(s) of such election. c) Do you have any accumulated vacation, sick, or leave benefits? If so, please state and detail each accumulated benefit(s). d) Have you borrowed against any of the aforementioned retirement plans? If so, please state the date, amount and purpose of such borrowing. ANSWER: 5 9. If there are any insurance policies on your life, state as to each policy: a) The owner and his or her address, b) The face amount, c) The present cash surrender value (attach proof), d) The cash surrender value on the date of separation (attach proof); e) The cash surrender value on the date of your response to these Interrogatories (attach proof); f) The beneficiaries; g) The date of policy purchase; h) The name of the insurance company which issued such policy, and the present location and the name, address, and phone number of the person having possession, custody and control of such policy. ANSWER: 6 10. List all banks, savings and loan institutions, trust companies, credit unions and other financial institutions in which you, jointly with others or individually, have or had accounts with, between January 1, 2003, and the date of answering these Interrogatories. State the account number and type of each account, the address of the financial institution in which each account is located, and the name, address, of any other person who has or had authority to draw funds from any such account(s), and the name(s) in which each account was held on date of separation and is held at the present time. For each amount set forth its balance at date of separation and the balance on the date of answering these interrogatories. ANSWER: 7 11. List all stocks, bonds, treasury notes, certificates of deposit, government bonds, annuities, money market and other securities you own or have owned, whether individually or jointly, and whether your interest is legal or beneficial from January 1, 2003 to the date of answering these Interrogatories, stating as to each such stock, bond, certificate of deposit, governmental bond, annuity, or other security, the name and address of the corporation or entity, the number of shares and par value (of stock), or the amount of such bond or certificate of deposit, and the name(s) in which each account is held. For each account set forth the balance on date of separation and the balance on the date of answering these interrogatories. ANSWER: 8 12. If since January 1, 2003, you have liquidated, sold, or disposed of any deposit accounts, stocks, bonds, certificates of deposit, government bonds, annuities, or other securities, for each disposition, sale or transfer, state: a) The type and number of securities sold. b) The name of the issuing entity. c) The date of the sale. d) The sales or transfer price. e) The name and address of the broker through whom the sale or transfer was made. f) The net gain or loss resulting from the sale or transfer. g) The name and address of purchaser or transferee, if known. h) Attach a copy of any written agreement or sales confirmation pertaining to any such transaction. ANSWER: 9 13. a) Do you presently maintain any credit cards for your personal use? b) Do you have the use of credit cards supplied by your employer? If your answer to (a) and/or (b) is in the affirmative, for each card state: a) The name of the issuer. b) The card number. c) To whom the card is issued. d) The name and address of each person who may use the card. e) The present balance of the account. ANSWER: 10 14. Have you loaned or given money or property to relatives, friends, or anyone else since January 1, 2003? If so, for each person receiving such money, state: a) The name and address of the person. b) Whether the money was a gift or a loan. c) The total amount loaned or given. d) The date of each loan or gift. e) The reason for each loan or gift. f) A description of any consideration or evidence of indebtedness received in exchange for such loan or gift. ANSWER: 15. Since the date of your marriage to Plaintiff, did you transfer any property in which you claimed an interest without receiving fair market value as consideration for the transfer If so, for each item of property transferred, state: a) A complete description of the property. b) The name and address of each transferee. c) The reason for the transfer. d) The amount of consideration received for the transfer. e) Whether the written consent of Plaintiff was obtained for such transfer. ANSWER: 12 16. Are there any agreements in existence involving the purchase or sale of any real property in which you are a party? ANSWER: 17. a) Do you now or have you at any time since the date of marriage, maintained or had access to a safe deposit box? If so, please detail the contents at the time opened, and the date of separation. b) Detail all items you have removed from the safe deposit box for six months prior to the date of separation to the present. ANSWER: 13 18. Since the date of marriage, have there been accounts at a savings or commercial banking institution, brokerage firm, or any other type of financial institution, on which your name did not appear but in which you deposited any funds? If so, please designate by account number and name of financial institution, and indicate the name(s) under which the account is listed. ANSWER: 14 19. If you are self-employed or engaged in any business or a profession as a sole proprietor, partner, or as a principal in a closely held corporation, please state the name of entity, and the form of the entity, i.e., sole proprietorship, partnership, corporation, and the date upon which you acquired an interest in that entity. a) Did you purchase your interest in that business or profession? If so, indicate the purchase price. b) If you did not purchase your interest, please indicate whether it was gifted or inherited, or what the source of your acquisition was. c) Identify the source of your acquisition. ANSWER: 15 n ,? n y Y 20, At any time during your marriage to Defendant, were you engaged in any other business enterprise individually or jointly with another? ANSWER: 21. If so, for each business or venture, state or provide the following: a. The name and address of the business or venture. b. The form of organization of the business or venture. c. The name of each officer or partner of the business or venture. d. The date on which your interest in the business or venture commenced. e. Your capital contribution to the business or venture. f. Your proportionate share in the ownership and profits of the business or venture. g. The annual gross receipts of the business or venture during each of the fiscal years in which you were involved in the business or venture. h. The present location of the records of the business or venture. i. The name and address of the person who has custody of the records of the business or venture. j. The name and address of each person who prepared the records of the business or venture. k. Attach a copy of the federal and state income tax returns for each fiscal year of such business or venture in which you were involved. ANSWER: 16 22. a) If a partnership, list the names and addresses of all partners (it less than ten), and the percentage of their interest in the partnership, including your interest, and attach a copy of the Partnership Agreement. b) If a closely-held corporation, (1) list the names and addresses of all directors and officers, and, (2) if less than ten, list the names of all shareholders and the percentage of their shareholdings, including your interest in the corporation. c) List the name and address of all financial institutions where the entities identified in a. and b. above transact business. d) If a corporation, please provide a copy of the following: i. Shareholders Stock Redemption or Buy/Sell Agreement. ii. Any employment contracts/agreements with the corporation. iii. Any agreement between you and the entity or you and other partnerships, including, but not limited to, those listed above. ANSWER: 17 23. Was any business mentioned in the preceding interrogatories discontinued, sold, or was your interest terminated? If so. state: a) The name of the business. b) The date of discontinuance, sale, or termination. c) The reason for discontinuance or termination. d) The amount of money you received as a result of the discontinuance, sale, or termination. ANSWER: is 24. Do you have an ownership in any gold, diamonds, or other precious gems or metals or jewelry, having a value of $300.00 or more for each item? If so, please describe each item and state its current market value. ANSWER: 19 I . 25. Do you own or have any interest in any property (real or personal), contract right, patent, chose in action, or expectancy of any kind, including an interest or right titled or held in the name of another, not previously identified in your answers to the preceding Interrogatories? ANSWER: Respectfully submitted, Date: _?G - 0? By: Stanley J. AWls s ki, Esquire Attorney I. D. # 37422 Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110-1533 (717) 232-7661 Attorney for Defendant, George A. Farlling, Sr. 20 VERIFICATION I verity that the statements made in these Interrogatories are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: _ Vonda L. Farlling CERTIFICATE OF SERVICE I, Stanley J. A. Laskowski, Esquire, hereby certify that on October & -- 2005, 1 served a true and correct copy of Defendant's Interrogatories upon the attorney for Plaintiff, Vonda L. Farlling by First Class United States mail addressed as follows: Michael A. Scherer O'Brien, Banc & Scherer 19 W. South Street Carlisle, PA 17013 By ??+ .. ???? b }?I .. JAMES R. CLIPPINGER CHARLE5 J. D[HART. III JAMES D. CAMPBELL. JR. JAMES L GOLDSMITH P. DANIEL ALTLAND JEFFREY T. Mc GUIRE• STANLEY J. A. LASKOWSKI DOUGLAS K. MARSIOO BRETT M. WOODBURN RAY J. MICHALOWSKI DOUGLAS L. CASSEL `BOARD CERTIFIED CIVIL TRIAL ABVOCATE CALDWELL & KEARNS A PROFESSIONAL CORPORATION ATTORNEYS AT LAW 3631 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17110-1533 November 17, 2005 Michael A. Scherer, Esquire O'Brien, Baric & Scherer 19 W. South Street Carlisle, PA 17013 RE: Farlling v. Farlling Cumberland County Docket No. 2004-5638 CIVIL TERM Dear Mike: OF COUNSEL RICHARD L KEARNS CARL G. WASS THOMAS D. CALDWELL JR. 11928 -?Doll 717-232-7661 FAX. 717-232-2766 thefin,OO ldwellkearns corn My client is desirous of proceeding with concluding this matter. Please forward your responses to the Interrogatories previously served within seven (7) business days of the date of this letter; otherwise, I have been instructed to proceed with the appropriate Motion to Compel. Furthermore, I have yet to receive your client's response and position with regard to the proposed real estate values that I had previously sent to you. It is unfortunate that the costs of an appraisal must now be incurred. Please confirm whether or not it is your client's intention to proceed with the appraiser. If you have any questions or would like to discuss this matter further, please contact me. Very truly yours, Stanley J. A. Laskowski CALDWELL & KEARNS SL/se cc: George A. Farlling, Sr. 04786/95116 CERTIFICATE OF SERVICE AND NOW, this 15 day of December 2005, I hereby certify that I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U.S. Mail at Harrisburg, Pennsylvania, postage prepaid, addressed to: Michael A. Scherer, Esquire O'Brien, Baric & Scherer 19 W. South Street Carlisle, PA 17013 CALDWELL & KEARNS By: V ??? VONDA L. FARLLING, Plaintiff, V. GEORGE A. FARLLING, SR., Defendant. A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-5638 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE RULE TO SHOW CAUSE AND NOW, this Z/'day of Dc4,ky , 2005, a Rule is issued upon Plaintiff to show cause why Defendant's Motion to Compel Answers to discovery directed to Plaintiff should not be granted. Rule returnable within z- D days of service hereof. BY THE COURT: J. 1? /L_f 1 I SJ f? ? C L: I I WN I Z 3S, a S+IC, Z VONDA L. FARLLING, Plaintiff, V. GEORGE A. FARLLING, SR., Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-5638 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE MOTION FOR APPOINTMENT OF MASTER GEORGE A. FARLLING, SR., (Plaintiff) (Defendant) moves the court to appoint a master with respect to the following claims: (X) Divorce (X) Distribution of Property ( ) Annulment ( ) Support (X) Alimony (X) Counsel Fees (X) Alimony Pendente Lite (X) Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claim(s) for which the appointment of a master is requested. (2) The Defendant (has)(has-net) appeared in the action (personally) d (by phis attorney, Stanley J. A. Laskowski, Esquire). (3) The statutory ground(s) for divorce (is) (are) irretrievable breakdown. (4) Delete the inapplicable paragraph(s): (a) The action is not contested. (b) An agreement has been reached with respect to the following claims: N/A (c) The action is contested with respect to the following claims: Divorce, Alimony, Alimony Pendente Lite, Distribution of Property, counsel Fees, Costs and Expenses. (5) The action does not involve complex issues of law or fact. (6) The hearing is expected to take al (hems) (days). (7) Additional information, i evant to the motion: Date: ^d7 Stanle J. A skowski Es uire Attorney ID No. 37422 3631 N. Front Street Harrisburg, PA 17110 (717) 232-7661 Attorney for Defendant ORDER APPOINTING MASTER AND NOW , 2006, , Esquire is appointed master with respect to the following claims: By the Court: J. CERTIFICATE OF SERVICE AND NOW, this 5`h day of February, 2007,1 hereby certify that I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U.S. Mails at Harrisburg, Pennsylvania, postage prepaid, addressed to: Michael A. Scherer, Esquire O'Brien, Baric and Scherer 19 West South Street Carlisle, PA 17013 CALDWELL & KEARNS By: r U 04786/102916 r? ? :J ?, _ - ? -.._., ? "'fit?' ? '? `l?T r_?_1 r ? ?:.?T ?.?"J -? f.L , , - "L"' ? _) tom:. t ' . . LLy l=-+' L::. ?. ?.?y ' __.? 3=" _ T--- 4} ?? --C ` Stanley J. A. Laskowski, Esquire Attorney I.D. No. 37422 Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 (717) 232-2766 (fax) Attorneys for Defendant, George A. Farlling, Sr. VONDA L. FARLLING, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. GEORGE A. FARLLING, SR., Defendant. : NO. 2004-5638 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S PETITION FOR INJUNCTIVE RELIEF TO PREVENT DISSIPATION OF MARITAL ASSETS BY PLAINTIFF AND NOW, comes Defendant, George A. Farlling, Sr., by and through is counsel, Stanley J. A. Laskowski, Esquire and files this Petition for Injunctive Relief and in support thereof, avers as follows: 1. Petitioner is George A. Farlling, Sr., who currently resides at 654 Bloserville Road Newville, Cumberland County, Pennsylvania, 17241. 2. Respondent is Vonda L. Farlling, who currently resides at 701 Bloserville Road Newville, Cumberland County, Pennsylvania, 17241. 3. Respondent filed a Complaint in Divorce requesting economic relief, including a count for Equitable Distribution. 4. Petitioner requests that a judgment be entered against the above-named parties and both shall be prohibited from: a) Selling, transferring, encumbering, concealing, assigning, removing or in any way disposing of any property, real or personal, belonging to or acquired by, either party, except: i) As required for reasonable expenses of living; ii) For payment of reasonable attorney's fees and costs in connection with the actions; iii) By written agreement of both parties; or iv) By order of the Court. b) Incurring any further debts that would burden the credit of the other party, including, but not limited to the borrowing against any credit line secured by the marital residence, or other jointly-owned property, unreasonably using credit cards or cash advances against such credit or bank cards. C) Changing the beneficiaries of any life insurance policy, pension or retirement plan, or pension or retirement investment account, except with the written consent of the other party or by order of the Court. d) Causing the other party to be removed from coverage from an existing insurance policy, or permitting such coverage to lapse, including medical, dental, life, automobile and disability insurance. The parties shall maintain all insurance coverage in full force and effect as has existed since the date of their separation. WHEREFORE, Petitioner respectfully requests that this Honorable Court grant the Petition for Injunctive Relief and enjoin and restrain the parties from encumbering, dissipating, selling or otherwise alienating any and all of the assets of the parties. Date: 0?'2 -o 7 111392 C y sub fitted, By: Stanley J. A. a owski, Esquire Attorney I. D. # 37422 Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110-1533 (717) 232-7661 Attorney for Defendant, George A. Farlling, Sr. 2 JAN-16-200,7 TUE 03:38 PM FAX No. P. 05 V% IC n0NN The undersigned hereby verifies that the facts set forth in the foregoing document are true and correct to the best of his knowledge, information and belief and further states that false statements heroin arc made subject to the paWties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Dated: 7 George Farlling, Sr. CERTIFICATE OF SERVICE AND NOW, this 5ch day of February 2007, I hereby certify that I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U.S. Mails at Harrisburg, Pennsylvania, postage prepaid, addressed to: Michael A. Scherer, Esquire O'Brien, Baric and Scherer 19 West South Street Carlisle, PA 17013 CALDWELL & KEARNS By: N ? -rt C_. - -.-, :? f' j ? ---- - ? ? ? , _y -i' _ -- , N yx-,;. 7 ? . . j .?J • ? VONDA L. FARLLING, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2004-5638 CIVIL TERM GEORGE A. FARLLING, SR., CIVIL ACTION - LAW Defendant. IN DIVORCE INVENTORY AND APPRAISEMENT OF GEORGE A. FARLUNG, SR. Defendant, George A. Fariling, Sr., files the following inventory and appraisement 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 and appraisement are true and correct. (Plaintiff )(Defendant) understands that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Dated: 161 George A. Fariling, Sr., Defendant ASSETS OF PARTIES Defei. dant, George A. Farlling, Sr., marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. If an item has been appraised, a copy of the appraisal report is attached. (X) 1. Real property (X 2. Motor vehicles (X) 3. Stocks, bonds, securities and options ( ) 4. Certificates of deposit (X) 5. Checking accounts, cash (X) 6. Savings accounts, money market and savings certificates (X) 7. Contents of safe deposit boxes O 8. Trusts (X) 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) (} 10. Annuities (X) 11. Gifts (X) 12. Inheritances () 13. Patents, copyrights, inventions, royalties (X) 14. Personal property outside the home (X) 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, workman's compensation claim/award () 17. Profit sharing plans (X) 18. Pension plans (indicate employee contribution and date plan vests) () 19. Retirement plans, individual retirement accounts () 20. Disability payments () 21. Litigation claims (matured and unmatured) (} 22. MilitaryN.A. benefits () 23. Education benefits (X) 24. Debts due, including loans, mortgages held (X) 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute () 26. Other LIABILITIES OF PARTIES Defendant, George A. Farlling, Sr., marks on the list below those items applicable to the case at bar and itemizes the liabilities on the following page. SECURED (X) 1. Mortgages () 2. Judgments () 3. Liens () 4. Other secured liabilities UNSECURED (X) 5. Credit card balances () 6. Purchases (X) 7. Loan payments () 8. Notes payable () 9. 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United States Savings Bonds T,-,m-d to Vonda Lee Fulling Date Serial # Bond Amount 7-1987 L288214867EE $50.00 801987 L297866261 EE $50.00 9-1)87 L300385591EE $50.00 10- 1 987 L300385612EE $50.00 11-1987 L300385638EE $50.00 12- ! 987 L310012132EE $50.00 1-11,88 L310012160EE $50.00 2-11,88 L319293433EE $50.00 3-1 x,88 L319293454EE $50.00 5-1988 L363676029EE $50.00 5-1988 L363676047EE $50.00 6-1988 L363676069EE $50.00 7-1988 L363676094EE $50.00 8-19:38 1-363676113EE $50.00 9-1938 L363676141 EE $50.00 10-1'>88 L363676163EE $50.00 1 1_t??gg L384253821EE $50.00 12_1?,gg 1-384253876EE $50.00 1.1989 L384253896EE $50.00 2-1989 L384253910EE $50.00 3.1989 L384253923EE $50.00 4-1989 1-384253938EE $50.00 5-1989 L388930280EE $50.00 6-198'3 L388930293EE $50.00 8-1980 L388930307EE $50.00 8-1981 L388930319EE $50.00 10-1989 L388930333EE $50.00 10-1989 L388930345EE $50.00 11-1989 L390488384EE $50.00 12-1989 L390 888462EE $50.00 1-1 990 L390488476EE $50.00 2-1990- L390488486EE $50.00 3-1990 L390 888498EE $50.00 4-1990 L390488507EE $50.00 6-1990 L390488516EE $50.00 6-1990 L390488525EE $50.00 8-1990 L390488534EE $50.00 8-1990 L390488543EE $50.00 9-1990 L442609113EE $50.00 12-1990 C236982491 EE $100.00 2-1991 C269068495EE $100.00 3-1991 C2691 5 1 394EE $100.00 5-1991 C269151455EE $100.00 7-1991 C269151516EE $100.00 9-1991 C270998200EE $100.00 11-1991 C270998239EE $100.00 1-1992 C270998279EE $100.00 3-1992 C270998319EE $100.00 5-1992 C270998357EF $100.00 7-1992 C320289266EE $100.00 9-1992 C320289292EE $100.00 12-1992 C321478001 EE $100.00 1-1993 C321478042EE $100.00 3-1993 C413195293EE $100.00 5-1993 C427237130EE $100.00 7-1993 C433231129EE $100.00 9-1993 C433653555EF $100.00 11-1993 C435004079EE $100.00 1-1994 C447710647EE $100.00 3-1994 C464376760EE $100.00 6-1994 C472664710EE $100.00 7-1994 C480542976EE $100.00 9-1994 C486882341 EE $100.00 11-1994 C494176103EE $100.00 1-1995 C508590059EE $100.00 3-1995 C51507721 1 EE $100.00 6-1995 C529634007EF $100.00 7-1995 C53241277 ] EE $100.00 9-1995 C538036078EE $100.00 11-1995 C545423596EE $100.00 1-1996 C55377922SEE $100.00 3-1996 C560905314EE $100.00 5-1996 C568409876EE $100.00 7-1996 C576647757EE $100.00 9-1996 C580561277EE $100.00 11-1996 C592519687EE $100.00 1-1997 C59743 8820EE $100.00 3-1997 C605282487EF $100.00 5-1997 C610831759EE $100.00 7-1997 C614125348EE $100.00 9-1997 C620239702EE $100.00 11-1997 C628440094EE $100.00 1-1998 C632994282EE $100.00 3-1998 C638798678EE $100.00 6-1998 C64612421 SEE $100.00 7-1998 C649670063EE $100.00 10-1998 C654633980EE $100.00 11-1998 C659576795EE $100.00 1-1999 C662 000 1 90EE $100.00 3-1999 C664577105EE $100.00 5-1999 C667039898EE $100.00 7-1999 C668758900EE $100.00 9-1999 C675782636EE $100.00 11-1999 C684069496EE $100.00 1-2000 C686042587EE $100.00 3-2000 C691696427EE $100.00 5-2000 C693863356EE $100.00 7-2000 C695364999EE $100.00 9-2000 004799108EE $100.00 11-2000 C706485426EE $100.00 1-2001 C711245694EE $100.00 3-2001 0712697051 EE $100.00 5-2001 C724633130EE $100.00 7-2001 026148160E,E $100.00 9-2001 C727824888EE $100.00 11-2001 0729057771 EE $100.00 1-2002 C740915078EE $100.00 3-2002 C742257569EE $100.00 5-2002 C743919970EE $100.00 7-2002 C745400560EE $100.00 9-2002 C746654166EE $100.00 11-2002 C756461 1 1 9EE $100.00 1-2003 C758378631 EE $100.00 3-2003 C759740234EE $100.00 5-2003 C761085230EE $100.00 7-2003 C774696468EE $100.00 9-2003 C775808336EE $100.00 11-2003 C:779549089EE $100.00 1-2004 C782353378EE $100.00 3-2004 C785367232EE $100.00 5-2004 C789868316EE $100.00 7-2004 C791967015EE $100.00 9-2004 C795308272EE $100.00 im . - f CERTIFICATE OF SERVICE AND NOW, this 5`h day of February, 2007, I hereby certify that I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U.S. Mails at Harrisburg, Pennsylvania, postage prepaid, addressed to: Michael A. Scherer, Esquire O'Brien, Baric and Scherer 19 West South Street Carlisle, PA 17013 CALDWELL & KEARNS By: f.L ( A '?k' 04786/102916 w RJ --? l~ ?_? ? i ? _? ? ^"; i t: -? .. . ? C_. ?:: ',.; .... -' -i1 -"? ...I ? ?{ , , t I VONDA L. FARLLING, Plaintiff, V. GEORGE A. FARLLING, SR., Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-5638 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE INCOME AND EXPENSE STATEMENT OF GEORGE A. FARLLING, SR. Defendant files the following Income and Expense Statement and verifies that the statements made herein are true and correct. Defendant understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. ?- Dated: -161-67-7 Georg A. Far ling, efendant INCOME: Employer: Self Farllin 's Garage Address: 654 Bloserville Road Type of Work: Automobile Repairs Payroll Number: N/A Pay Period (Weekly, Biweekly, etc.): N/A Gross Pa Per Pa Period: Itemized Payroll Deductions: Federal Withholding Social Security Local Wage Tax State Income Tax Retirement Savings Bonds Credit Union Life Insurance Health Insurance Other (specify) NET PAY PER PAY PERIOD: OTHER INCOME: WEEK MONTH YEAR Interest $434.00 Dividends $ 29.00 Pension Annuity Social Security Rents Royalties Expense Account Gifts Unemployment Comp. Workmen's Comp. Federal Employees Retirement System Support from Spouse TOTAL INCOME EXPENSES: WEEK MONTH YEAR HOME Mortgage/Rent $ 400.00 $4,800.00 Maintenance Utilities Electric $ 34.00 $ 408.00 Gas Oil $ 150.00 $ 900.00 Telephone $ 80.00 $ 960.00 Water Sewer EMPLOYMENT Public Transportation Lunch TAXES Real Estate $1,001.00 Personal Property $ 20.00 Income Taxes $10,498.00 INSURANCE Homeowners $ 809.00 Automobile $ 803.00 Life $ 92.00 Accident Health Other Antique Auto Ins. $ 199.00 AUTOMOBILE Payments Fuel $4,575.00 Repairs $1,200.00 MEDICAL Doctor $ 30.00 Dentist Orthodontist Hospital Medicine Special Needs (glasses, braces, orthopedic devices) $ 250.00 EXPENSES: WEEK MONTH YEAR EDUCATION Private School Parochial School College Religious PERSONAL Clothing $ 200.00 Food $4,800.00 Barber/Hairdresser $ 120.00 CREDIT PAYMENTS Credit Card $8,400.00 Charge Account Memberships LOANS Credit Union MISCELLANEOUS Household Help Child Care Papers/Books/Ma azines Entertainment Pa TV $ 900.00 Vacation $1,250.00 Gifts/Church $2,600.00 Legal Fees $3,600.00 Charitable Gifts Other Child Support Alimony Payments TOTAL EXPENSES PROPERTY OWNED:* Description Value Ownership* H W J Checking Accounts Savings Accounts Credit Union Stocks/Bonds Real Estate Other - TOTAL *See Inventory & Appraisement INSURANCE: Company Policy No. Ownership* H W C Hospital Blue Cross Other Medical Blue Cross Other Health/Accident Disability Income Dental Other-Life/E e *H=Husband; W=Wife; J=Joint; C=Child SUPPLEMENTAL INCOME STATEMENT (a) This form is to be filled out by a person (check one): X (1) who operates a business or practices a profession, or _ (2) who is a member of a partnership or joint venture, or _ (3) who is a shareholder in and is salaried by a closed corporation or similar entity. (b) Attach to this statement a copy of the following documents relating to the partnership, joint venture, business, profession, corporation or similar entity: (1) the most recent Federal Income Tax Return, and 2005 (2) the most recent Profit and Loss Statement. (5-31-2006) (c) Name of business: Farlling's Garage Address and 654 Bloserville Road, Newville, PA 17241 Telephone Number: 717-776-3614 (d) Nature of business (check one): (1) partnership (2) joint venture (3) profession (4) closed corporation (5) other (e) Name of accountant, controller or other person in charge of financial records: Jeffrey S. Cohick, EA (f) Annual income from business: See attached. (1) How often is income received: (2) Gross Income Per Pay Period: (3) Net Income Per Pay Period: (4) Specified Deductions, if any: 04786/102911 6 Cohick & Associates July 31, 2006 Mr. George A Farlling Farlling's Garage 654 Bloserville Road Newville, PA 17241 Dear Mr. Farlling; I have compiled the accompanying interim financial statements as of May 31, 2006. A compilation is limited to presenting in the form of financial statements information that is the representation of management. I have not audited or reviewed the accompanying financial statements and, accordingly, do not express an opinion or any other form of assurance on them. Management has elected to omit substantially all of the disclosures required by generally accepted accounting principles. If the omitted disclosures were included in the financial statement, they might influence the user's conclusions about the company's financial position, results of operations, and changes in financial position. Accordingly, these financial statements are not designed for those who are not informed about such matters. I L_ Enrolled Agent Bookkeeping, Accounting and Tax Services 390 Alexander Spring Road, Carlisle, PA 17013 Phone (717) 249-5321 Fax (717) 249-5830 GEORGE A FARLLING GARAGE 654 Bloserville Road Newville, PA 17241 May 31, 2006 BALANCE SHEET ASSETS Current Assets Cash $1,934 Employee Advance 304 Total Current Assets $2,238 Fixed Assets Fixtures & Equipment $130,969 Less: Accumulated Depreciation (113,067) Total Fixed Assets 17,902 Total Assets LIABILITIES AND EQUITY Current Liabilities N/P First Commonwealth Bank Payroll Taxes Payable Sales Tax & PTA Tax Total Current Liabilites EQUITY Capital Current Profit (Loss) Total Equity $2,510 986 1,132 $ 20,140 $4,628 ($9,084) 24,596 $15,512 Total Liabilities and Equity $ 20,140 Prepared without audit, from information supplied by client GEORGE A FARLLING GARAGE 654 Bloserville Road Newville, PA 17241 For Period Ending May 31, 2006 OPERATING STATEMENT Income Revenue Total Income Cost of Goods Sold Purchases PA Emissions Program Total Cost of Goods Sold Gross Profit Operating Expenses Wages Freight & Postage Payroll Taxes Real Estate Taxes Outside Services Equipment Rental Dues & Subscriptions Utilities Telephone Advertising Office Expense Legal & Accounting Operating Supplies Small Tools Maintenance & Repair Insurance Health Insurance Vehicle Expense Bank & Credit Card Fees Business Meals Amortization Depreciation Laundry & Cleaning Total Operating Expenses Net Income (Loss) $97,315 $97,315 $35,957 $36,682 $60,633 $15,516 78 1,571 261 814 310 20 587 1,235 2,333 497 1,696 436 1,170 210 3,353 930 2190 401 234 764 479 $36,037 $24,596 Prepared without audit, from information supplied by client 5251FAR02TP E 1040 Department of the Treasury - Internal Revenue Service 20051 99 IRS Use Only - U.S. Individual Income Tax Return Do not write or staple in this space For the year Jan 1-Dec. 31. 2005, or her tax year be inning 2005, ending 20 OMB No 1545-0074 Label L A Your first name and initial Last name Your social security number (See B GEORGE A FARLLING 190-34-5251 instructions on page 16 ) E If a joint return, sp. first name & initial Last name Spouse's social security number . L 164-36-5190 UsethelRS label. H Home address (number and street) If you have a P O box, see page 16 Apt no - You must enter A Otherwise, E 701 BLOSERVILLE ROAD our SSN s above please print or type. R City, town or post office, state, and ZIP code If you have a foreign address, see page 16. Checking a box below will not E NEWVILLE PA 17241 change your tax or refund. Presidential Election Campaign 01 Check here if you, or your spouse if filing jointly, want $3 to go to this fund (see page 16) ? You Spouse Head of household (with qualifying person) (See page 17) If 4 t 1 Single the qualifying person is a child but n er ot your dependent, en Filing Status 2 Married filing jointly (even if only one had income) this child's name here 00, Check only 3 X Married filing separately. Enter spouse's SSN above 5 Qualifying widow(er) with dependent child (see page 17) nnp Innr and full name here. 1110. VONDA L FARLLING _ 6a Exemptions b c If more than four dependents, see page 19. Yourself. If someone can claim you as a dependent, do not check box 6a Dependents: First name Last name (2) Dependent's social security number (3) Dependent's relationship to you (4) q for chi Child tax cr. 19 you d Total number of exemptions claimed . ... . 7 Wages, salaries, tips, etc. Attach Form(s) W-2 Income 8a Taxable interest Attach Schedule B if required Attach Form(s) b Tax-exempt interest. Do not include on line 8a I 8b W-2 here. Also 9a Ordinary dividends Attach Schedule B if required attach Forms b Qualified dividends (see page 23) I 9b I 29 W-213 and 1099-R if tax 10 Taxable refunds, credits, or offsets of state and local income taxes (see page 23) was withheld. 11 Alimony received 12 Business income or (loss) Attach Schedule C or C-EZ you did not 13 Capital gain or (loss). Attach Schedule D if required. If not required, check here Ll get a W-2, see page 22. 14 Other gains or (losses). Attach Form 4797 15a IRA distributions 15a b Taxable amount (see page 25) 16a Pensions and annuities 16a b Taxable amount (see page 25) Enclose, but do 17 Rental real estate, royalties, partnerships, S corporations, trusts, etc Attach Schedule E not attach, any 18 Farm income or (loss). Attach Schedule F payment. Also, please use 19 Unemployment compensation Form 1040-V. 20a Social security benefits IOaa b Taxable amount (see page 27) 21 Other Income. List type and amt. (see page 29) 22 Add the amounts in the far right column for lines 7 through 21. This is our total income 11. Boxes checked 1 on 6a and 6b No. of children on 6c who: k it child 9 lived with see 9 did not live with you due to divorce or separation (see page 20) Dependents on 6c not en- tered above Add numbers on lines above 11P. FF1 7 8a 434 9a 29 10 11 12 36,640 13 14 15b 16b 17 18 19 20b _ 21 22 37,103 23 Educator expenses (see page 29) 23 Adjusted 24 Certain business expenses of reservists, performing artists, and Gross fee-basis government officials. Attach Form 2106 or 2106-EZ 24 Income 25 Health savings account deduction. Attach Form 8889 25 26 Moving expenses. Attach Form 3903 26 27 One-half of self-employment tax. Attach Schedule SE 27 2,589 28 Self-employed SEP, SIMPLE, and qualified plans 28 29 Self-employed health insurance deduction (see page 30) 29 30 Penalty on early withdrawal of savings 30 31a Alimony paid b Recipient's SSN 31a 32 IRA deduction (see page 31) 32 33 Student loan interest deduction (see page 33) 33 34 Tuition and fees deduction (see page 34) 34 35 Domestic production activities deduction. Attach Form 8903 35 36 Add lines 23 through 31a and 32 through 35 36 21589 37 Subtract line 36 from line 22. This is our adjusted gross income ? 37 34,514 For Disclosure, Privacy Act, and Paperwork Reduction Act Notice, see page 78. Form 1040 (2005) DAA 5251FAR02TP Form 1040 zoos GEORGE A FARLLING 190-34-5251 Pa e 2 Tax and 38 Amount from line 37 (adjusted gross income) 38 34,514 Credits 39a Check I 8 You were born before January 2, 1941, Blind. l Total boxes if: 1 B Spouse was born before January 2, 1941, Blind. J checked ? 39a Standard b If your spouse itemizes on a separate return or you were a dual-status alien, see page 35 and check here ? 39b Deduction f 40 Itemized deductions (from Schedule A) or your standard deduction (see left margin) 40 5 000 or- P l h 41 Subtract line 40 from line 38 41 29, 514 . eop e w o checked any 42 If line 38 is over $109,475, or you provided housing to a person displaced by Hurricane Katrina, see page 37 Otherwise, multiply $3,200 by the total number of exemptions claimed on line 6d 42 3 200 box on line 39a or 39b or 43 Taxable income. Subtract line 42 from line 41 If line 42 is more than line 41, enter -0- 43 261 314 who can be 44 Tax (see page 37). Check if any tax is from a ? Form(s) 8814 claimed as a dependent, 36 b ? Form 4972 44 3 577 see page . . All others 45 Alternative minimum tax (see page 39). Attach Form 6251 45 Single or 46 Add lines 44 and 45 ? 46 3 577 Married filing separately, 47 Foreign tax credit. Attach Form 1116 if required ................... 47 $5,000 48 Credit for child and dependent care expenses. Attach Form 2441 48 Married filing 49 Credit for the elderly or the disabled. Attach Schedule R 49 jointly or Qualifying 50 Education credits. Attach Form 8863 50 widow(er). $10 000 51 Retirement savings contributions credit Attach Form 8880 51 , 52 Child tax credit (see page 41) Attach Form 8901 if required 52 Head of hou ehold. 53 Adoption credit. Attach Form 8839 53 $7.300 54 Credits from. a ? Form 8396 b Form 8859 54 55 Other credits. Check applicable box(es) a Form 3800 b ? Form 8801 c ? Form 55 56 Add lines 47 through 55. These are your total credits 56 57 Subtract line 56 from line 46. If line 56 is more than line 46, enter -0- ..... ? 57 3,577 Other 58 Self-employment tax. Attach Schedule SE 58 5,177 Taxes 59 Social security and Medicare tax on tip income not reported to employer. Attach Form 4137 59 60 Additional tax on IRAs, other qualified retirement plans, etc. Attach Form 5329 if required 60 61 Advance earned income credit payments from Form(s) W-2 61 Payments 62 Household employment taxes. Attach Schedule H 62 63 Add lines 57 - 62. This is your total tax ? 63 8 , 754 64 Federal income tax withheld from Forms W-2 and 1099 64 65 2005 estimated tax payments and amount applied from 2004 return 65 2,200 If you have a 66a Earned income credit (EIC) 66a qualifying b Nontaxable combat pay election ? 66b child, attach Schedule EIC 67 Excess social security and tier 1 RRTA tax withheld (see page 59) 67 68 Additional child tax credit. Attach Form 8812 68 69 Amount paid with request for extension to file (see page 59) 69 70 Payments from a ? Form 2439 b ? Form 4136 c ? Form 8885 70 71 Add In 64, 65, 66a, & 67 - 70 These are your total payments ? Refund 72 If line 71 is more than line 63, subtract line 63 from line 71 This is the amount you overpaid Direct deposit? 73a Amount of line 72 you want refunded to ou ? See page 59 ? b Routing number ? c T Checking Savings n and fill in 73b, 73c, and 73d ? d Account number 2.200 74 Amount of line 72 you want applied to our 2006 estimated tax ? 74 Amount 75 Amount you owe. Subtract line 71 from line 63 For details on how to pay, see page 60 ? 75 6 732 You Owe 76 Estimated tax penalty (see page 60) 76 1781 Third Party Do you want to allow another person to discuss this return with the IRS (see page 61)? X Yes. Complete the following. No Designee Designee's Personal identification number (PIN) 0' name ? PREPARER Phone no. ? Under penalties of perjury, I declare that I have examined this return and accompanying schedules and statements, and to the best of my knowledge and Sign belief, they are true, correct, and complete. Declaration of preparer (other than taxpayer) is based on all information of which preparer has any knowledge. Here Your signature Date Your occupation Daytime phone number Joint return? See page 17. SE - MECHANIC Keep a copy Spouse's signature. If a joint return, both must sign. Date Spouse's occupation for vour Paid Preparer's Date J 7Chk f Prepar er's SSN or PTIN Preparer's signature' JEFFREY S COHICK EA ployed ? P00009537 Use Only Firm's name (or COHICK & ASSOCIATES EIN 25-1589918 yours if self-employed)., 390 ALEXANDER SPRING ROAD Phone no. address' and ZIP code CARLISLE PA 17013-9129 717-249-5321 DAA Form 1040 (2005) 71 73a 5251FAR02TP , Schedules A&B Form 1040 2005 OMB No 1545-0074 Page 2 Namets) shown on Form 1040 Do not enter name and social security number if shown on other side GEORGE A FARLLING Your social security number 190-34-5251 Schedule B-Interest and Ordinary Dividends Attachment Y Sequence No 08 interest is from a seller-financed mortgage and the If an er 1 List name of a Amount y . p y Part I buyer used the property as a personal residence, see page B-1 and list this Interest interest first. Also, show that buyer's social security number and address ? CENT PA CONF-U METH 220 1 CORNERSTONE FCU e B S 29 - ee pag ( and the CORNERSTONE FCU-C/O FARLLING GARAGE 19 instructions for PRUDENTIAL INS CO 166 Form 1040, ., 8a li .) ne 1 ou te N If y . o received a Form 1099-INT. Form 1099-OID.or it t b u e su st statement from a brokerage firm, list the firm's th name as e payer and enter the total interest shown on that 2 Add the amounts on line 1 2 434 form. 3 Excludable interest on series EE and I U S. savings bonds issued after 1989 Attach Form 8815 3 4 Subtract line 3 from line 2. Enter the result here and on Form 1040, line 8a ? 4 434 you must complete Part III. If line 4 is over $1 500 Note Amount , , . 5 List name of payer ? Part 11 PRUDENTIAL - 37 SH 29 Ordinary Dividends e B-1 (See pa g and the instructions for Form 1040, ...... line 9a ) . 5 Note. If you received a Form 1099-DIV or substitute statement from a brokerage firm, list the firm's name as the payer and enter the ordinary dividends shown on that form. 6 Add the amounts on line 5. Enter the total here and on Form 1040, line 9a ... ? 6 Note If line 6 is over $1,500, you must complete Part III. You must complete this part if you (a) had over $1,500 of taxable interest or ordinary dividends. or (b) had Part III a foreign account or (c) received a distribution from or were a grantor of or a transferor to a foreign trust. Foreign 7a At any time during 2005, did you have an interest in or a signature or other authority over a financial /Accounts account in a foreign country, such as a bank account, securities account, or other financial account? and Trusts See page B-2 for exceptions and filing requirements for Form TD F 90-22.1 b If "Yes," enter the name of the foreign country ? (See g During 2005, did you receive a distribution from, or were you the grantor of, or transferor to, a 29 No X page B-2.) X foreign trusty If "Yes," you may have to file Form 3520 See page B-2 For Paperwork Reduction Act Notice, see Form 1040 instructions. Schedule B (Form 1040) 2005 DP.A 5251 FAR02TP FARLLING, GEORGE A 190-34-5251 Federal Statements Form 1040, Dividend Income Ordinary Qualified Payer Dividends Dividends PRUDENTIAL - 37 SH $ 29 $ 29 TOTAL $ 29 $ 29 5251FAR02TP SCHEDULE C (Form 1040) Department of the Treasury Internal Revenue Service Name of proprietor Profit or Loss From Business OMB No 1545-0074 (Sole Proprietorship) L2005 ? Partnerships, joint ventures, etc., must file Form 1065 or Form 1065-B. Attachment 01 09 Attach to Form 1040 or 1041. 111' See Instructions for Schedule C Form 1040. Sequence No Social security number (SSN) GEORGE A FARLLING 190-34-5251 A Principal business or profession, including product or service (see page C-2 of the instructions) B Enter code from pages C-8, 9, & 10 AUTO REPAIR-SERVICE ? 811110 C Business name If no separate business name, leave blank D Employer ID number (EIN), if any G A FARLLING GARAGE 25-1454872 E Business address (including suite or room no )? 654 BLOSERVILLE ROAD City, town or post office, state, and ZIP code NEWVILLE PA 17241 F Accounting method: (1) X Cash (2) Accrual (3) Ll Other (specify) 10, G Did you "materially participate" in the operation of this business during 2005? If "No," see page C-3 for limit on losses OX Yes H No H If you started or acquired this business during 2005, check here ? Part I Income 1 Gross receipts or sales. Caution. If this income was reported to you on Form W-2 and the "Statutory employee" box on that form was checked, see page C-3 and check here ? .... ........... El 1 278 ,006 2 Returns and allowances 2 3 Subtract line 2 from line 1 3 278 ,006 4 Cost of goods sold (from line 42 on page 2) 4 132 617 5 Gross profit. Subtract line 4 from line 3 5 145, 389 6 Other income, including Federal and state gasoline or fuel tax credit or refund (see p age C-3) 6 7 Gross income. Add lines 5 and 6 ... . . . ? 7 145, 389 Part II Expenses. Enter expenses for business use of our home only on line 30. 8 Advertising 8 4,178 18 Office expense 18 2, 556 9 Car and truck expenses (see 19 Pension and profit-sharing plans 19 page C-3) 9 20 Rent or lease (see page C-5): 10 Commissions and fees 10 a Vehicles, machinery, and equipment 20a 11 Contract labor (see page C-4) 11 b Other business property 20b 12 Depletion 12 21 Repairs and maintenance 21 2, 103 13 Depreciation and section 179 22 Supplies (not included in Part III) 22 2, 739 expense deduction (not 23 Taxes and licenses 23 5 173 included in Part III) (see page C-4) 13 1,149 24 Travel, meals, and entertainment: a Travel 24a 275 14 Employee benefit programs (other than on line 19) 14 21156 b Deductible meals and entertainment (see page C-5) 24b 15 Insurance (other than health) 15 6,495 25 Utilities 25 4 113 16 Interest: 26 Wages (less employment credits) 26 44, 824 a Mortgage (paid to banks, etc.) 16a 27 Other expenses (from line 48 on b Other 16b 417 page 2) 27 291 475 17 legal and professional services .. 17 3 096 28 Total expenses before expenses for business use of home. Add lines 8 through 27 in columns ? 28 108, 749 29 Tentative profit (loss) Subtract line 28 from line 7 29 36,640 30 Expenses for business use of your home. Attach Form 8829 30 31 Net profit or (loss). Subtract line 30 from line 29. • If a profit, enter on Form 1040, line 12, and also on Schedule SE, line 2 (statutory employees, see page C-6). Estates and trusts, enter on Form 1041, line 3. 31 3616-4-0- 0 If a loss, you must go to line 32. 32 If you have a loss, check the box that describes your investment in this activity (see page C-6). • If you checked 32a, enter the loss on Form 1040, line 12, and also on Schedule SE, line 2 32a e All investment is at risk (statutory employees, see page C-6). Estates and trusts, enter on Form 1041, line 3- 32b Some investment is not • If you checked 32b you must attach Form 6198. Your loss may be limited at risk For Paperwork Reduction Act Notice, see page C-7 of the instructions. Schedule C (Form 1040) 2005 DAA 5251FAR02TP GEORGE A FARLLING 190-34-5251 Schedule C (Form 1040) 2005 AUTO REPAIR-SERVICE Page 2 Part III Cost of Goods Sold (see page C-6) 33 Method(s) used to value closing inventory a XX Cost b F1 Lower of cost or market c 11 Other (attach explanation) 34 Was there any change in determining quantities, costs, or valuations between opening and closing inventory? If "Yes," attach explanation F1 Yes X? No 35 Inventory at beginning of year. If different from last year's closing inventory, attach explanation 35 0 36 Purchases less cost of items withdrawn for personal use 36 129,032 37 Cost of labor. Do not include any amounts paid to yourself 37 545 38 Materials and supplies 38 39 Other costs SEE STATEMENT 1 39 3,040 40 Add lines 35 through 39 40 132,617 41 Inventory at end of year 41 0 42 Cost of goods sold. Subtract line 41 from line 40. Enter the result here and on page 1, line 4 . . .. 42 1 132 , 617 Part IV Information on Your Vehicle. Complete this part only if you are claiming car or truck expenses on line 9 and are not required to file Form 4562 for this business. See the instructions for line 13 on page C-4 to find out if you must file Form 4562. 43 When did you place your vehicle in service for business purposes? (month, day, year)? 44 Of the total number of miles you drove your vehicle during 2005. enter the number of miles you used your vehicle for: a Business b Commuting (see instructions) c Other 45 Do you (or your spouse) have another vehicle available for personal use? 46 Was your vehicle available for personal use during off-duty hours? 47a Do you have evidence to support your deduction? b If "Yes," is the evidence written? Yes Yes Yes Yes No No No No Part V Other Expenses. List below business expenses not included on lines 8-26 or line 30. OUTSIDE SERVICES 2 ,755 SMALL TOOLS 4 ,981 FREIGHT & POSTAGE 211 TELEPHONE 2 ,924 VEHICLE EXPENSE 11 ,863 EDUCATION & TRAINING 75 BANK AND CREDIT CARD FEES 853 DUES & SUBSCRIPTIONS ........... .. ... . . .. 176 . . .... . . ..................... ......... LAUNDRY AND CLEANING 2 ,474 ....... .. . ........... .. .. .... ......... .. .. OTHER MISC ADV 1 ,330 AMORTIZATION 1 833 48 Total other expenses. Enter here and on page 1, line 27 48 1 2 9 , 4 7 5 DAA Schedule C (Form 1040) 2005 5251 FAR02TP FARLLING, GEORGE A 190-34-5251 Federal Statements AUTO REPAIR-SERVICE Statement 1 - Schedule C, Cost of Goods Sold, Line 39 - Other Costs Description PA EMISSIONS PROGRAM TOTAL Amount $ 3,040 $ 3,040 5251 FAR02TP FARLLING, GEORGE A 190-34-5251 Federal Statements AUTO REPAIR-SERVICE Schedule C Line 14 - Employee Benefit Programs _ Description Amount EMPLOYEE HEALTH INSURANCE $ 2,156 TOTAL $ 2,156 AUTO REPAIR-SERVICE Schedule C, Line 15 - Insurance Description Amount INSURANCE $ 6,495 TOTAL $ 6,495 AUTO REPAIR-SERVICE Schedule C Line 23 -Taxes and Licenses Description Amount FICA & MEDICARE $ 3,429 UNEMPLOYMENT TAXES 693 REAL ESTATE TAXES 1,051 TOTAL $ 5,173 5251FAR02TP SCHEDULE SE OMB No 1545-0074 (Form 1040) Self-Employment Tax 2005 Depart ment of the Treasury Attachment 7 Internal Revenue Service ss 00, Attach to Form 1040. 10, See Instructions for Schedule SE Form 1040. Sequence No Name of person with self-employment income (as shown on Form 1040) Social security number of person GEORGE A FARLLING with self-employment income 10, 190-34-5251 Who Must File Schedule SE You must file Schedule SE if • You had net earnings from self-employment from other than church employee income (line 4 of Short Schedule SE or line 4c of Long Schedule SE) of $400 or more, or • You had church employee income of $108.28 or more. Income from services you performed as a minister or a member of a religious order is not church employee income (see page SE-1). Note. Even if you had a loss or a small amount of income from self-employment, it may be to your benefit to file Schedule SE and use either "optional method" in Part II of Long Schedule SE (see page SE-3). Exception. If your only self-employment income was from earnings as a minister, member of a religious order, or Christian Science practitioner and you filed Form 4361 and received IRS approval not to be taxed on those earnings, do not file Schedule SE. Instead, write "Exempt-Form 4361" on Form 1040, line 58. May I Use Short Schedule SE or Must 1 Use Long Schedule SE? Did You Receive Wanes nr Tins in ?nnr? No Are you a minister, member of a religious order, or Christian Science practitioner who received IRS approval not to be taxed on earnings from these sources, but you owe self-employment tax on other earnings? ,? No Are you using one of the optional methods to figure your net earnings (see page SE-3)? W No Did you receive church employee income reported on Form W-2 of $108.28 or more? * No You May Use Short Schedule SE Below Yes { You Must Use Long Schedule SE on page 2 1 Section A-Short Schedule SE. Caution. Read above to see if you can use Short Schedule SE. 1 Net farm profit or (loss) from Schedule F, line 36, and farm partnerships, Schedule K-1 (Form 1065), box 14, code A 2 Net profit or (loss) from Schedule C, line 31; Schedule C-EZ, line 3; Schedule K-1 (Form 1065), box 14, code A (other than farming); and Schedule K-1 (Form 1065-B), box 9. Ministers and members of religious orders, see page SE-1 for amounts to report on this line. See page SE-2 for other income to report 3 Combine lines 1 and 2 4 Net earnings from self-employment. Multiply line 3 by 92 35% ( 9235) If less than $400, do not file this schedule, you do not owe self-employment tax 5 Self-employment tax. If the amount on line 4 is 0 $90,000 or less, multiply line 4 by 15.3% ( 153). Enter the result here and on Form 1040, line 58. • More than $90,000. multiply line 4 by 2.9% (.029). Then, add $11,160.00 to the result. Enter the total here and on Form 1040, line 58. 6 Deduction for one-half of self-employment tax. Multiply line 5 by 50% (.5). Enter the result here and on Form 1040, line 27 For Paperwork Reduction Act Notice, see Form 1040 instructions. T No No Did you receive tips subject to social security or Medicare tax that you did not report to your employer? Yes I Was the total of your wages and tips subject to social security or railroad retirement tax plus your net earnings from self-employment more than $90,000? Yes Yes 2 36,640 3 36,640 ? 1 4 1 33 , 837 Yes 5,177 2,5891 Schedule SE (Form 1040) 2005 DAA 5251FAR02TP . ' Form 1040 Net Earnings from Self-Employment Worksheet 2005 J Name _ Taxpayer Identification Number GEORGE A FARLLING 190-34-5251 Taxpayer Spouse Farm profit or (loss) Schedule F Farm Partnerships - Schedule K-1, box 14, code A Auto expense from farm partnerships Amortization from farm partnerships Depreciation & Section 179 from farm partnerships Depletion from farm partnerships ( y Other expenses from farm partnerships ( ( j Home office expenses from farm partnerships Unreimbursed partnership expenses from farm partnerships ( ..... ................ ( 1 Farm adjustment to SE Income .. ... ........... .. . ... Net farm profit or (foss) - Schedule SE line 1 0 0 Nonfarm profit or (loss) ScheduleC 36, 640 Nonfarm partnerships - Schedule K-1, box 14, code A Auto expense from nonfarm partnerships Amortization from nonfarm partnerships Depreciation & section 179 from nonfarm partnerships Depletion from nonfarm partnerships Other expenses from nonfarm partnerships Home office expenses from nonfarm partnerships Unreimbursed partnership expenses from nonfarm partnerships Employee business expenses from Form 2106 Nonfarm adjustment to SE income ........... ... Self-employment income reported as other income Self-employment income from contracts and straddles Minister wages Minister household allowance Net nonfarm profit or (loss) - Schedule SE line 2 36 , 640 0 Net profit (loss) from self-employment activities - Schedule SE line 3 36.640 0 Church employee income - Schedule SE line 5a I 190345251 FARLLING GEORGE 0500110184 PA-40 - 2005 Pennsylvania Income Tax Return ENTER ONE LETTER OR NUMBER IN EACH BOX. Do Not Use Your Preprinted Label A Occupation SE - M E C H A Occupation 701 BLOSERVILLE ROAD NEWVILLE PA 17241 717-776-3614 21050 1 a Gross Compensation Do not include exempt income, such as combat zone pay and qualifying retirement benefits See the instructions 1b Unreimbursed Employee Business Expenses. 1c Net Compensation. Subtract Line 1b from Line 1a. 2 Interest Income. Complete PA Schedule A if required. 3 Dividend and Capital Gains Distributions Income. Complete PA Schedule B if required. 4 Net Income or Loss from the Operation of a Business, Profession, or Farm. 5 Net Gain or Loss from the Sale, Exchange, or Disposition of Property. 6 Net Income or Loss from Rents, Royalties, Patents, or Copyrights. 7 Estate or Trust Income. Complete and submit PA Schedule J. 8 Gambling and Lottery Winnings. Complete and submit PA Schedule T. 9 Total PA Taxable Income. Add only the positive income amounts from Lines 1c, 2, 3, 4, 5, 6, 7, and 8. DO NOT ADD any losses reported on Lines 4, 5, or 6. 10 Medical Savings Account. CAUTION: See the instructions. Enter the amount from your Federal Income Tax return. Do not deduct medical expenses or insurance. 11 Adjusted PA Taxable Income. Subtract Line 10 from Line 9. • f N Extension N Amended Return R Residency Status PA Resident/Nonresident/Part-Year Resident from to M Single/Married, Filing Jointly/Married, Filing Separately/Final ReturnlDeceased Date of death N Farmers a EC Page 1 of 2 FC I 1a 0 1b 0 1C 0 2 434 3 29 4 36640 5 0 6 0 7 0 8 0 9 37103 10 0 11 37103 L. 0500110184 ?1_ _1__ 1 1 1 1 ? 0500110184 J • 0500210190 PA-40 - 2005 Social Security Number 190345251 Name(s) GEORGE A FARLLING 12 PA Tax Liability. Multiply Line 11 by 3.07 percent (0.0307). 13 Total PA Tax Withheld. See the instructions. 14 Credit from your 2004 PA Income Tax return. 15 2005 Estimated Installment Payments. 16 2005 Extension Payment. 17 Nonresident Tax Withheld from your PA Schedule(s) NRK-1. (Nonresidents only) 18 Total Estimated Payments and Credits. Add Lines 14, 15, 16, and 17. Tax Forgiveness Credit. 19a Filing Status: 01 Unmarried or Separated 02 Married 03 Deceased 19b Dependents, Part B, Line 2, PA Schedule SP 20 Total Eligibility Income from Part C, Line 11, PA Schedule SP. 21 Tax Forgiveness Credit from Part D. Line 16. PA Schedule SP. 22 Resident Credit. Submit your PA Schedule(s) G and/or RK-1. 23 Total Other Credits Submit your PA Schedule OC. 24 TOTAL PAYMENTS and CREDITS. Add Lines 13 and 18, 21, 22, and 23. 25 TAX DUE. If Line 12 is more than Line 24, enter the difference here. 26 Penalties and Interest. See the instructions If attaching form REV-1630, mark the box. N 12 1139 . 13 0 14 0 15 1450 16 0 17 0 18 1450 19a 00 19b 00 20 0 21 0 22 0 23 0 24 1450 25 0 26 0 27 0 28 311 29 0 30 311 31 0 32 0 33 0 34 0 35 0 27 TOTAL PAYMENT. Add Lines 25 and 26. 28 OVERPAYMENT. If Line 24 is more than the total of Line 12 and Line 26, enter the difference here. The total of Lines 29 through 35 must equal Line 28. 29 Refund - Amount of Line 28 you want as a check mailed to you. Refund 30 Credit - Amount of Line 28 you want as a credit to your 2006 estimated account. 31 Amount of Line 28 you want to donate to the Wild Resource Conservation Fund. 32 Amount of Line 28 you want to donate to the Military Family Relief Assistance Program. 33 Amount of Line 28 you want to donate to the Governor Robert P. Casey Memorial Organ and Tissue Donation Awareness Trust Fund. 34 Amount of Line 28 you want to donate to the Juvenile (Type 1) Diabetes Cure Research Fund. 35 Amount of Line 28 you want to donate to the Breast and Cervical Cancer Research Fund. Your Signature I Date { Spouse's Signature, if filing jointly Preparer's Name and Telephone Number 717-249-532 Page 2 of 2 Preparer's SSN/PTIN/EIN 251589918 0500210190 0500210190 J RETURN BY APRIL 17, 2006 TO: CAPITAL TAX COLLECTION BUREAU CARLISLE DIVISION PO BOX 400 CARLISLE PA 17013-0400 PHONE: (717) 243-3725 LOCAL EARNED INCOME TAX RETURN (FORM 531) (Non-Act 24) 2005 www.captax.com TO CONSTITUTE PROOF OF FILING. THE TAXPAYER'S COPY MUST BE VALIDATED BY THE BUREAU TO HAVE YOUR COPY VALIDATED BY MAIL, RETURN BOTH THE BUREAU'S AND TAXPAYER'S COPIES ALONG WITH A SELF ADDRESSED STAMPED ENVELOPE j ? i . • " i • A it • B . ? 190-34-5251 000-00-0000 1 W-2 EARNINGS (From attached VV-2's) 1 2 EMPLOYEE BUSINESS EXPENSES (Attached Federal Form2106 & State Schedule UE) 2 3 TAXABLE W-2 EARNINGS LESS EBEs (Subtract Line 2 from Line 1) 3 0.00 0.00 4 OTHER TAXABLE EARNED INCOME (NO INTEREST OR DIVIDENDS) LIST TYPE 4 5 TOTAL TAXABLE EARNED INCOME (Add Lines 3 and 4) 5 0.00 0:00 6 NET PROFIT(S) FROM BUSINESS, PROFESSION OR FARM (Attach Federal and State Schedules C, F and/or K-1 (1065)) 6 36 640.00 7 NET LOSS(ES) FROM BUSINESS, PROFESSION or FARM (Attach Federal and State Schedule C, F and/or K-1 1 7 8 Subtract Line 7 from Line 6 (IF LESS THAN ZERO. ENTER ZERO). 8 36,640.00 0.00 9 REQUIRED FOR INFORMATION PURPOSES ONLY: Enter Net, Subchapter S Corporation pass-thru Net Profit(s)/Loss(es) as reported on your PA-40 return 9 I 10 TOTAL TAXABLE EARNED INCOME AND NET PROFITS (Add Lines 5 and 8) 10 40.00 36,6 0.00 11 TAX RATES - The Tax Rates Appear Automatically Based on Your Correct Resident Municipality Selected in Line No 24. 11 ! 1.65% l 1.65% 12 TAX LIABILITY Multiply Line 10 by Line 11 12 604,56 ' 0.00 13 TOTAL LOCAL INCOME TAXES WITHHELD EXCEPT PHILADELPHIA INCOME TAX (From attached Vi 's, Box 19) 13 14 QUARTERLY PAYMENTS AND/OR LAST YEAR'S OVERPAYMENT CREDITED TO THIS YEAR 14 550.00 15 CREDITS FOR TAXES PAID TO PHILADELPHIA AND/OR STATES OTHER THAN PA (ATTACH SCH G) AND/OR CREDITS FOR CERTIFIED RESIDENTS OF THE HARRISBURG KEYSTONE OPPORTUNITY ZONE (KOZ) 15 16 TOTAL WITHHOLDINGS & PAYMENTS (Add Lines 13,14 and 15) 16 550.00 0.00 17 TAX BALANCE DUE (Subtract Line 16 from Line 12) PAYMENT NOT NECESSARY IF LESS THAN $1 00 17 54.56 0.00 18 INTEREST & PENALTY (See Instructions) 18 1g TOTAL BALANCE DUE (Add Lines 17 and 18) Make check payable to "CTCB" 19 54.56 0.00 20 OVERPAYMENT (Subtract Line 12 from Line 16) IF LESS THAN ZERO. ENTER ZERO 20 0.00 0.00 21 OVERPAYMENT TO BE REFUNDED 21 0,00 0,00 1 Taxpayer "A".. "B", or "BOTH" Savings or Checking Acct. ROUTING NO ACCOUNT NO- rt ? . 22 OVERPAYMENT TO BE CREDITED TO NEXT YEAR'S TAX 221 1 23 OVERPAYMENT TO BE CREDITED TO SPOUSE'S BALANCE DUE FOR THIS FILING YEAR lil , l " 23 W A li Mil ?622; YOUR RESIDENT MUNICIPALITY (TWP, BORO, OR CITY) DAYTIME PHONE NUMBER; 24 UPPER FRANKFORD TOWNSHIP 1205 (717 776-3614 25 YOUR SOCIAL SECURITY NUMBER A 190-34-5251 YOUR NAME (L, F, MI) FARLLING, GEORGE A 26 SPOUSE'S SOCIAL SECURITY NUMB B SPOUSE'S NAME (L, F, MI) HAVE YOU MOVED OYES If YES, you must complete a single Schedule FROM THE BEGINNING P and a separate final return (Form 531) for OF THE TAX FILING O NO each CTCB municipality in which you resided YEAR TO PRESENT? during the tax year. HOME ADDRESS 654 BLOSERVILLE ROAD NEWVILLE, PA 17241 KNOWl EA . Ag?WF? THEY AII?E TRUE CORRII?qT AND • , YOUR SIGNATURE X DATE YOUR OCCUPATION SE SPOUSE'S SIGNATURE (ONLY IF ALSO FILING ON THIS FORM) X DATE SPOUSE'S OCCUPATION (ONLY IF ALSO FILING ON THIS FORM) PAID PREPARER'S NAME (PLEASE PRINT) SEFFREY S COHICK EA FIRM'S NAME ( OR ENTER "S E " IF SELF EMPLOYED) COHICK & ASSOCIATES PAID PREPARER'S PHONE NUMBER 717-249-5321 BUREAU'S COPY r ? w CERTIFICATE OF SERVICE AND NOW, this 5th day of February, 2007, I hereby certify that I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U.S. Mails at Harrisburg, Pennsylvania, postage prepaid, addressed to: Michael A. Scherer, Esquire O'Brien, Baric and Scherer 19 West South Street Carlisle, PA 17013 CALDWELL & KEARNS By: 04786/102916 u FEB 0 7 VONDA L. FARLLING, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-5638 CIVIL TERM GEORGE A. FARLLING, SR., Defendant. CIVIL ACTION - LAW IN DIVORCE MOTION FOR APPOINTMENT OF MASTER GEORGE A. FARLLING, SR., (PlaintjM (Defendant) moves the court to appoint a master with respect to the following claims: (X) Divorce (X) Distribution of Property ( ) Annulment ( ) Support (X) Alimony (X) Counsel Fees (X) Alimony Pendente Lite (X) Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claim(s) for which the appointment of a master is requested. (2) The Defendant (has)(has-not) appeared in the action (personally) ad (by phis attorney, Stanley J. A. Laskowski, Esquire). (3) The statutory ground(s) for divorce (is) (are) irretrievable breakdown. (4) Delete the inapplicable paragraph(s): (a) The action is not contested. (b) An agreement has been reached with respect to the following claims: N/A (c) The action is contested with respect to the following claims: Divorce, Alimony, Alimony Pendente Lite, Distribution of Property, counsel Fees, Costs and Expenses. (5) The action does not involve complex issues of law or fact. (6) The hearing is expected to take al ) (days). (7) Additional information, if evant to the motion:_ Date: -YJ7 , Stanley J. A skowski Esquire Attorney ID No. 37422 3631 N. Front Street Hamsburg, PA 17110 (717) 232-7661 Attorney for Defendant ORDER APPOINTING MSTER AND NOW 7 , 200,7 ?te- e Esquire is appointed master with respect to the following claims: ,&ef 41 i?f CERTIFICATE OF SERVICE AND NOW, this 5`h day of February, 2007, I hereby certify that I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U.S. Mails at Harrisburg, Pennsylvania, postage prepaid, addressed to: Michael A. Scherer, Esquire O'Brien, Baric and Scherer 19 West South Street Carlisle, PA 17013 CALDWELL & KEARNS BY: f 04786/102916 FEB 0 7 2007 VONDA L. FARLLING, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2004-5638 CIVIL TERM GEORGE A. FARLLING, SR., CIVIL ACTION - LAW Defendant. IN DIVORCE ORDER AND NOW, this '7* day of , 2007, upon consideration of the Petition for Injunctive Relief, it is hereby ORDERED and DECREED that a hearing shall be hard in Courtroom No. 3 in the Cumberland County Courthouse on the / S day of 2007, at •'t? o'clock p.m. in order to determine whether the above-named parties will enjoined and restrained from encumbering, dissipating, selling or otherwise alienating all marital assetsof4w s un 1. e r , agreemno approval; +----Fen?o f-a ju end aft ; or BYJHE C6n,, o , J. Distribution: Stanley J. A. Laskowski, Esq. 3631 North Front Street, Harrisburg, PA 17110-1533 Michael A. Scherer, Esquire, 19 West South Street, Carlisle, PA 17013 , ?-DF.U 7 7 1 ( rf VONDA L. FARLLING, Plaintiff, V. GEORGE A. FARLLING, SR., Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-5638 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE ORDER AND NOW, this! daY of February 2007, upon consideration of Defendant's Petition for Injunctive Relief to Prevent Dissipation of Marital Assets and agreement of the Parties, it is hereby ordered and decreed that he Parties are hereby enjoined and restrained from encumbering, dissipating, selling or otherwise alienating all marital assets of the Parties as set forth in the Stipulation attached hereto, incorporated herein by reference and made a part of this Order. J. Distribution: V/tanley J. A. Laskowski, Esquire, 3631 North Front Street, Harrisburg, PA 17110-1533 VK4ichael A. Scherer, Esquire, 19 West South Street, Carlisle, PA•?170 3 04786/113818 80 :? Hd U 033 LOUZ Alb"lu i E,.iw HI JO DJOUA?31!A FEB-1372007 TUE 10:59 AM VONDA L. FA.RLLING, Plaintiff, V. GEORGE A. FARLLING, SR., Defendant FAX NO. P. 02 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 2004-5638 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE STIPULATION FOR AGREED ORDER AND NOW, this /,0/ day of February 2007, the parties hereby stipulate and agree as follows; 1. Neither party shall sell, tmsfer, convey, assign, alienate, encumber, dissipate or otherwise transfer any marital assets without the written consent of the other party or Court order; 2. Neither party shall incur any further debts that would burden the credit of the other party, including, but not limited to the borrowing against any credit line secured by the marital residence or other jointly-owned property, unreasonably using credit cards or cash advances against such credit or bank card; 3. Neither party shall change the current beneficiaries of any life insurance policy, pension or retirement plans, pension or retirement investment accounts, employment benefits, except with the written consent of the other party, or by order of Court; 4. Neither party shall change the current insured under an existing insurance policy, nor permit such coverage to lapse, including medical, dental, life, automobi le and disability insurance; 5. This Stipulation shall rernain in effect until further written agreement of the parties or order of Court; . F EB-13-2007 `SUE 10 : 59 AM FAX NO. P. 03 6. This Stipulation is entered into without prejudice to the parties' rights in the pending action; 7. Nothing in this Stipulation is intended to interfere with or prohibit the ordinary course of business and daily operations of Farlling's Garage, Bloserville, Pennsylvania, by Defendant, George A. Fa.rlling; and 8. Nothing in this Stipulation is intended to interfere with or prohibit the ordinary, course of business and daily operations of Bloserville Storage, Bloserville, Pennsylvania, by Plaintiff, Vonda L. Farlling. 04786/113816 Defend' nt's Attorney: VONDA L. FARLLING, Plaintiff V. GEORGE A. FARLLING, SR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-5638 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on November 9, 2004. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. 1 consent to the entry of a final decree in divorce without notice. 4. 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. 5. 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. 6. 1 have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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. i _ Date: 6 - a - ('t Vonda L. Farlling ?, `? ?}=; Wit .? ? ;; „ "? ?` t:? T? ?7 ?: ??? ?` ,,?„ VONDA L. FARLLING, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2004-5638 CIVIL TERM GEORGE A. FARLLING, SR., Defendant CIVIL LAW -ACTION IN DIVORCE AFFIDAVIT OF CONSENT A Complaint n divorce under Section 3301(c) of the Divorce Code was filed on November / , 2004. 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. 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: Defend c?. 24 VONDA L. FARLLING, Plaintiff V. GEORGE A. FARLLING, SR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-5638 CIVIL TERM CIVIL LAW -ACTION IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTIONS 3301(c) AND 3301(d) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I 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: Defendant V e, `. ? ? .,.. z csti -? VONDA L. FARLLING, Plaintiff VS. GEORGE A. FARLLING, SR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04 - 5638 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this (,T* day of , 2008, counsel and the parties having entered to an agreement and stipulation resolving the economic issues on June 10, 2008, the date set for a Master's hearing, the agreement and stipulation having been transcribed, 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: W /Michael A. Scherer /?Attorney for Plaintiff "/Stanley J.A. Laskowski Attorney for Defendant CO Its rrIat? BY THE COURT, Q .- N a? Edgar B. Bayley, P.J CDR ;X= Z i FE -x * i _. -I C J.d' ?L LLJ 'w'7 1 a CV VONDA L. FARLLING, Plaintiff VS. GEORGE A. FARLLING, SR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04 - 5638 CIVIL IN DIVORCE THE MASTER: Today is Tuesday, June 10, 2008. This is the date set for a hearing in the above-captioned divorce proceedings. Present in the hearing room are the Plaintiff, Vonda L. Farlling, and her counsel Michael A. Scherer, and the Defendant, George A. Farlling, Sr., and his counsel Stanley J.A. Laskowski. This action was commenced by the filing of a complaint in divorce on November 9, 2004, raising grounds for divorce of irretrievable breakdown of the marriage. In addition, there were alternate grounds pled in the complaint of adultery and indignities; however, we do not need to deal with those grounds inasmuch as the parties have agreed to consent to the divorce. The Master has been provided affidavits of consent and waivers of notice of intention to request entry of divorce decree signed and dated by both parties today, June 10, 2008. The divorce will proceed under Section 3301(c) of the Domestic Relations Code and the Master's office will file the affidavits and waivers with the Prothonotary. The complaint also raised economic claims of 1 equitable distribution, alimony, alimony pendente lite, and counsel fees expenses and costs. The Master has been advised that after negotiations the parties have reached an agreement with respect to the outstanding economic claims. The 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. Consequently, when the parties leave the hearing room today, they are bound by the terms of the agreement even though they have not signed the agreement affirming the terms of settlement. The Master has advised the parties and counsel that they can return later today to review the agreement for typographical errors and then affix the signatures of the parties and counsel affirming the terms of settlement. Counsel and the parties are going to return at an appointed time, after the agreement has been placed on the record. The parties were married on November 21, 1965, and separated August 20, 2004. They are the natural parents of two children, both of whom are emancipated. The Master understands and the agreement will affirm that the claims for alimony and counsel fees are 2 going to be waived and we are left with an agreement with respect to the claim for equitable distribution. Upon receipt by the Master of the completed agreement, the Master will prepare an order vacating his appointment and counsel will then be able to file a praecipe transmitting the record to the Court requesting a final decree in divorce. Mr. Scherer. MR. SCHERER: 1. The parties are the joint owners of real estate located at 701 Bloserville Road, Bloserville, Pennsylvania. Husband shall become the owner of 701 Bloserville Road and wife shall convey her interest in said property to husband on the date of settlement as hereinafter described. There are no liens against 701 Bloserville Road. 2. The parties are the joint owners of real estate located at 654 Bloserville Road, Bloserville, Pennsylvania. There are no liens against 654 Bloserville Road. Husband shall become the owner of the real estate located at 654 Bloserville Road and wife shall convey her interest in said property to husband on the date of settlement as hereinafter described. 3. Husband is the sole owner of real estate located at 699 Bloserville Road. Wife shall hereby convey her marital interest in said real estate to husband. 4. The parties are the joint owners of a vacant lot of land in the Big Spring area consisting of approximately 2.3 acres. Wife shall become the sole owner of this piece of real estate and husband shall convey his interest in the real estate to wife at the time of settlement as hereinafter described. 5. Husband's counsel shall prepare the deeds for 701 Bloserville Road and 654 Bloserville Road which shall be ready for settlement as hereinafter described, and wife's counsel shall prepare the deed for the vacant lot in the Big Spring area, which shall be prepared in time for settlement as hereinafter described. 3 6. There are four financial accounts at Cornerstone Credit Union. They are accounts number 9077-1; 9077-7; 10587-1; 10587-2. All the Cornerstone accounts shall become the separate property of husband and wife waives any interest she has in these accounts. 7. There are two accounts at Adams County National Bank. The first account is No. 11672 and wife shall become the sole owner of that account and husband waives his interest in that account. The second account is No. 116289, which is the account for G.A. Farlling Garage and husband shall become the sole owner of that account and wife waives her interest in said account. 8. There are three accounts at Farmers National Bank, being accounts number 4453, 116300, and 193801. Wife shall become the sole owner of all of the Farmers National accounts and husband waives his interest in those accounts. 9. There is an account at the Franklin County Teacher's Credit Union and wife shall become the sole owner of that account. Husband waives his interest in the Franklin County Teacher's Credit Union account. 10. It is the intention of the parties that husband shall keep as his separate property all accounts relating to the operation of G.A. Farlling Garage and that wife keep as her separate accounts those that relate to the operation of the storage unit business. 11. There are United States savings bonds which shall become the sole property of wife and husband waives his interest in those bonds. 12. Husband operates a commercial enterprise known as G.A. Farlling Garage and there is certain equipment and tools associated with the operation of said business. Wife waives her interest in all of the equipment and tools and inventory and other items at the G.A. Farlling Garage and husband shall become the sole owner of all of the those items. 13. Wife presently drives a Chevrolet Monte Carlo and wife shall become the sole owner of that motor vehicle. Husband shall sign a title, if necessary, conveying his interest in the vehicle to wife at the time of settlement. Husband shall become the sole owner of the Buick automobile that he presently operates and wife waives any claim to said vehicle. 4 Wife shall become the sole owner of the GMC van and husband waives his interest in that vehicle. 14. Husband has collected various automobiles and race cars and racing equipment. Husband shall become the sole owner of said cars and equipment. Wife waives her interest in the collector automobiles, race cars and race equipment. 15. Husband is the co-owner of a mobile home with Louann Barridge. Wife waives any interest in the husband's ownership in said mobile home. 16. Wife has accrued four retirement accounts in connection with her employment with the Big Spring School District. Those accounts include an ING account, a Scudder account, a Scudder IRA, and a PSERS annuity. Wife shall become the sole owner of all of these accounts and husband waives his interest in these accounts. 17. Each party shall keep as their separate property any life insurance which exists in their respective names, free of a claim from the other party. 18. Husband has obtained and collected various farm machinery and he shall become the sole owner of said machinery. 19. The parties own burial plots at Cumberland Valley Memorial Gardens and each party shall become the owner of one burial plot. 20. Husband shall keep as his separate property items No. 1 through 19 on the list of non-marital property which was attached to husband's pretrial statement. To the extent that the property is located at 701 Bloserville Road, wife shall leave that property there when she vacates 701 Bloserville Road. Wife shall keep as her separate property the tangible personal property located at 701 Bloserville Road which has not otherwise been reserved to either party herein. 21. Husband shall pay wife the sum of $135,000.00 for equitable distribution at the time of settlement. The settlement date is set for August 15, 2008, at a time which will be convenient for the parties and counsel. Real estate taxes for 701 Bloserville Road shall be prorated to the time of settlement. And rents and expenses for the storage units shall be prorated as of that date as well. 5 22. The complaint raised the claims of alimony and counsel fees and wife waives those claims. 23. 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. SCHERER: Will you tell us your name, please? MS. FARLLING: Vonda Lee Farlling. MR. SCHERER: And you have been present this morning as we have discussed and negotiated this divorce case; is that right? MS. FARLLING: Yes. MR. SCHERER: And you and I have had various discussions this morning; is that right, regarding the settlement of this case? MS. FARLLING: Yes. MR. SCHERER: Do you understand the things that we have discussed this morning? MS. FARLLING: Yes, I do. MR. SCHERER: And you heard me dictate an agreement moments ago relative to the resolution of your 6 case, did you not? MS. FARLLING: Yes. MR. SCHERER: And is that agreement acceptable to you as dictated by me? MS. FARLLING: Yes, it is. MR. SCHERER: And is your acceptance to the agreement voluntary? MS. FARLLING: Yes. MR. LASKOWSKI: Can you state your full name, please? MR. FARLLING: George Arthur Farlling, Sr. MR. LASKOWSKI: Thank you. George, likewise, you were present today throughout these proceedings and in our negotiations with Mrs. Farlling and her counsel, were you not? MR. FARLLING: Yes. MR. LASKOWSKI: And we have reviewed today the proposed property division and that is to your satisfaction; is it not? MR. FARLLING: Yes. MR. LASKOWSKI: You were here when that agreement was dictated and read this morning, were you not? MR. FARLLING: Yes. MR. LASKOWSKI: And are those terms of the agreement satisfactory to you? 7 MR. FARLLING: Yes. MR. LASKOWSKI: With respect to that agreement, you voluntarily desire to enter into that agreement today? MR. FARLLING: Yes. THE MASTER: Thank you. 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: 44 J 1. ? ?ya?f3 4x M e A. Scherer Vonda L. Farlling Attorney for Plaintiff Stanley .A. Laskowski George A. arllrng, Sr. Attorney for Defendant 8 VONDA L. FARLLING, Plaintiff V. GEORGE A. FARLLING, SR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-5638 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant signed a certified mailing return receipt card on November 10, 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 on June 12, 2008; and Defendant on June 12, 2008. B. (1) date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: N/A (2) date of service of the Plaintiffs Affidavit upon the Defendant: N/A 4. Related claims pending: None. 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under section 3301(d)(1)(i) of the Divorce Code: The parties signed Waivers of Notice of Intent to Request Entry of Divorce Decree. Respectfully submitted, O'BRIEN, BARIC & SCHERER Michabl'A! Schbrer, Esquire 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 N f? -TI 1-0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. VONDA L. FARLLING, ..,A Plaintiff VERSUS GEORGE A. FARLLING, SR., NO. 2004-5638 Civil Defendant DECREE IN DIVORCE AND NOW, TL- IT IS ORDERED AND DECREED THAT VONDA L. FARLLING AND GEORGE A. FARLLING. SR ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; The parties Marital Settlement Agreement dated'June 121 2008 is T HE Cam. ATTEST: J PROTHONOTARY :. ,, ??".