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
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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
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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
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Wayn . Shade
WAYNE F. SHADE
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
17013
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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
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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
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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
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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.
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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 ??+
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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:
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04786/102916
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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:
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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. Other unsecured liabilities
CONTINGENT OR DEFERRED
() 10. Contracts or Agreements
() 11. Promissory notes
(} 12. Lawsuits
() 13. Options
( ) 14. Taxes
() 15. Other contingent or deferred liabilities
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,% d.
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
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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
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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,
`. ? ?
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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
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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
:. ,, ??".