HomeMy WebLinkAbout05-0867J
ANDREW S. GASSAWAY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. :NO. 057- yl ?7 CIVIL TERM
JENNIFER M. GASSAWAY,
Defendant : IN LAW - 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 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, First Floor, Cumberland County Courthouse,
I Courthouse Square, Carlisle, Pennsylvania.
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, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT
HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR MO
FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
ANDREW S. GASSAWAY,
Plaintiff
V.
JENNIFER M. GASSAWAY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL TERM
IN LAW - DIVORCE
COMPLAINT IN DIVORCE
AND NOW COMES the Plaintiff, ANDREW S. GASSAWAY, by his counsel,
William L. Grubb, Esquire, and complains of the Defendant, JENNIFER M.
GASSAWAY, as follows:
COUNTI
COMPLAINT UNDER SECTION 3301 (c) OR
3301 (d) OF THE DIVORCE CODE
1. Plaintiff is ANDREW S. GASSAWAY, who currently resides at 252 East
Crestwood Drive, Camp Hill, Cumberland County, Pennsylvania, 17011.
2. Defendant is JENNIFER M. GASSAWAY who currently resides at 10
Naragansett Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17050.
3. Plaintiff has been a bona fide resident in the Commonwealth for at least
six months immediately previous to the filing of this complaint.
4. Plaintiff and Defendant were married on July 6, 1991, at Wyomissing,
Berks County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the
parties.
6. Neither party is in the Armed Services of the United States or its allies.
7. The marriage is irretrievably broken.
8. 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.
9. Plaintiff requests the Court to enter a Decree of Divorce.
WHEREFORE, Plaintiff prays this Honorable Court to enter an Order dissolving the
marriage between the parties.
COUNT II
EQUITABLE DISTRIBUTION
10. Plaintiff incorporates the allegations of paragraphs one (1) through nine
(9) by reference as if set forth at length herein.
11. During the course of the marriage, the parties have acquired numerous
items of property, both real and personal, which are held in joint names and in the
individual names of the parties hereto.
12. The Plaintiff and the Defendant have been unable, as of the date of this
complaint, to agree as to an equitable division of said property.
WHEREFORE, Plaintiff prays this Honorable Court, after requiring full
disclosure by the Defendant, to equitably divide the property, both real and personal,
owned by the parties hereto as marital property
Respectfully submitted,
Date: ot=;b 5
U- 4 4:?5
William L. Grubb, Esquire
I.D. # 72661
3803 Gettysburg Road
Camp Hill, PA 17011
(717) 763-5580
Attorney for Plaintiff
VERIFICATION
I, ANDREW S. GASSAWAY, verify that the statements made in this document
are true and correct. I understand that false statements herein are made subject to
penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities.
Date: 2L, f
Andrew S. Gassaway, Plaintiff
CERTIFICATE OF SERVICE
I, WILLIAM L. GRUBB, Esquire, certify that I have served a copy of the
foregoing document on the individual listed below by depositing the same in the United
States Mail, Certified, First Class, restricted delivery, postage prepaid, at Camp Hill,
Pennsylvania:
Jennifer M. Gassaway
10 Naragansett Drive
Mechanicsburg, PA 17050
Date:. t (o, Z?•S
William L. Grubb, Esquire
3803 Gettysburg Road
Camp Hill, PA 17011
?/
v p
? gJ
G
R? ?
G o
O
e
o
o
?
Si
? `o
??
??'- ?'
? °?
0
??
=ti
-, ?.,
,. , , ;
=,?
? ?
_ ;? _..,
?, r _.
?_
?; .
,,
y ,-
`;
_f,
_.t
u
Andrew S. Gassaway,
Respondent, Plaintiff
V.
Jennifer M. Gassaway,
Petitioner, Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-867 CIVIL TERM
CIVIL ACTION - CUSTODY
COMPLAINT FOR CUSTODY
1. Petitioner is Jennifer M. Gassaway, an adult individual whose residence is
at 10 Naragansett Drive, Mechanicsburg, Cumberland County, Pennsylvania.
2. Respondent is Andrew S. Gassaway, an adult individual whose residence
is at 252 East Crestwood Drive, Apt C-6, Camp Hill, Cumberland County, Pennsylvania.
3. Petitioner seeks custody of her children: Nicholas A. Gassaway, born
November 8, 1992, Christopher D. Gassaway, born October 27, 1994, Thomas M.
Gassaway, born May 13, 1996 and Brian W. Gassaway, Born October 20, 1998,
currently residing at 10 Naragansett Drive, Mechanicsburg, PA 17050.
4. The children are presently in the custody of Petitioner.
5. The children have resided at the following addresses:
Name
Nicholas A. Gassaway
Christopher D. Gassaway
Thomas M. Gassaway
Brian W. Gassaway
6. The relationship of the Petitioner to the children is that of natural mother.
Address
Dates
13142 Lauren Lane, Midlothian, VA July 00-June 03
10 Naragansett Drive, Mechanicsburg, PA July 03-Present
7. The relationship of the Respondent to the children is that of natural father.
7. The relationship of the Respondent to the children is that of natural father.
8. The Petitioner has not participated as a party or in any other capacity, in
other litigation concerning the custody of the children in this or any other Court.
9. Petitioner has no information of a custody proceeding concerning the
children pending in a Court of this Commonwealth.
10. The best interest and permanent welfare of the children will be served by
granting the relief requested because the Petitioner is the primary care giver with
respect to the children.
11. Each parent whose parental rights to the children have not been
terminated and the person who has physical custody of the children have been named
as parties to this action. No other persons are known to have or claim to have any right
to custody or visitation of the children other than the parties to this action.
WHEREFORE, Petitioner requests your Honorable Court grant the Petitioner's
request for shared Legal Custody and Primary Physical Custody of the four minor
children with liberal visitation between their father/Respondent herein.
Respectfully Submitted
TURO LAW OFFICES
D -
-I 1?
Date
Orden R. Wales-E"
28 South Pitt Street'
Carlisle, PA 17013
(717) 245-9688
Attorney for Petitioner
VERIFICATION
I verify that the statements made in the foregoing Custody Complaint are true
and correct. I understand that false statements made herein are subject to the penalties
of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities.
Date Je6nifer Gassaway de
CERTIFICATE OF SERVICE
I hereby certify that I served a true and correct copy of the Complaint in Custody
upon Andrew S. Gassaway, by depositing same in the United States Mail, first class,
postage pre-paid on the day of /< 2005, from Carlisle,
Pennsylvania, addressed as follows:
Andrew S. Gassaway
252 East Crestwood Drive Apt c-6
Camp Hill, PA 17011
TURO LAW OFFICES
Carlisle, PA 17013
(717) 245-9688; FAX 717.245.2165
a
-f
c
ANDREW S. GASSAWAY IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V. 05-867 CIVIL ACTION LAW
JENNIFER M. GASSAWAY
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW, _ Wednesday, March 02, 2005 upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, April 07, 2005 _ at 8:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: ts1 Hubert X. Gilrop, 9 y
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO 1-0 OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South BedtOrd Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
f7A
17 ^?
"
Z 't 6? G` 4YrY 71-104
So r r
r? ??
G? J?2
Andrew S. Gassaway,
Respondent, Plaintiff
V.
Jennifer M. Gassaway,
Petitioner, Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-867 CIVIL TERM
CIVIL ACTION - CUSTODY
PRAECIPE TO TRANSMIT CUSTODY ORDER
TO THE PROTHONOTARY:
AND NOW this 28th day of March, 2005, the Petitioner, Defendant submits a
mutually agreed upon Custody Stipulation/Order and requests that this Honorable Court
the attached Custody Order.
Date
Respectfully Submitted
TURO LAW OFFICES
G6len R. Waltz, Es r
28 South Pitt Str ft
Carlisle, PA 17013
(717) 245-9688 ext 22
Attorney for Defendant
r; ^j C7
-ct
c'+
c
c
- -rr
=. rid
ri,
Andrew S. Gassaway, : IN THE COURT OF COMMON PLEAS
Respondent, Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 05-867 CIVIL TERM
Jennifer M. Gassaway, : CIVIL ACTION -CUSTODY
Petitioner, Defendant
CUSTODY STIPULATION
Date
The parties stipulate to the attached Court Order.
Andrew S. Gassaway
31,asLo A14?_
Date Jennifer M?Gassaway v
? Cr
?- -^1 F
r,::
?> P'.
c?c
,_ ?
??'C. c-1
;?- Ci
, '.
j t?
w ?
f '
Z
?
P?
ANDREW S. GASSAWAY,
Plaintiff
V.
JENNIFER M. GASSAWAY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-0867 CIVIL TERM
IN LAW - DIVORCE
PROOF OF SERVICE BY MAIL
I hereby certify that a true and correct copy of the Complaint In Divorce filed in
the above matter, was served on JENNIFER M. GASSAWAY by prepaid, first class,
certified mail, return receipt requested, deliver to addressee only, at 10 Naragansett Drive,
Mechanicsburg, Pennsylvania, 17050, on February 16, 2005. Addressee acknowledged
receipt of the same on February 19, 2005, as shown by the return receipt card attached
hereto as Exhibit "A".
I verify that the statements made in this document are true and correct. I
understand that false statements herein are made subject to penalties of 18 Pa. C.S. §
4904, relating to unsworn falsification to authorities.
Date: Z
William L. Grubb, Esquire
I.D. 72661
3803 Gettysburg Road
Camp Hill, PA 17011
(717) 763-5580
¦ Complete Items t, 2, and 3. Also complete
Item 4 If Restricted Delivery is desired.
¦ Print your name and address on the reverse
so that we can return the card to you.
¦ Attach this card to the back of the mailplece,
or on the front if space permits.
I. ••Article Addressed to: G
.Jgls)NiFEx M- Ca.?S AWA
/o NaCA4ArJ5Crr -M4r
??? 1s c NrvJI r,S S ,21? n Pp 17 0V
?p,yd Agent
Addressee
Rec tved by (Printed Name) C. Date Del
0.. b de9veryadtireea different item 1? C7` to
jklONWO-tivery address below. Flo
F®191005
IS Return Recelpt for Merchandise
1] Insured Mail Li C.O.D.
4. Reebloted DeMvery? (Extra Fee) _ ja'pae
2. Article Number 7003 2260 0002 1615 5891
(Transfer fiom seMCe labeq.
P3 1,. , Donnraofieufrn Reodpt •r 10@aaa md4w0
Exhibit "A"
ANDREW S. GASSAWAY,
Plaintiff
V.
JENNIFER M. GASSAWAY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-0867 CIVIL TERM
IN LAW - DIVORCE
AFFIDAVIT OF MARRIAGE COUNSELING
ANDREW S. GASSAWAY, being duly sworn according to law, deposes and says:
1. I have been advised of the availability of marriage counseling and understand that
I may request that the court require that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the Office of
the Prothonotary, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down by the court.
I understand that false statements herein are made subject to the penalties of Pa.
C.S. §4904, relating to unsworn falsification to authorities.
Date: $l?
Andrew S. Gassaway, Plaintiff
MAR 2 8 Zbuf e
Andrew S. Gassaway,
Respondent, Plaintiff
IN THE COURT OF COMI
CUMBERLAND COUNTY
N PLEAS
_NNSYLVANIA
V.
Jennifer M. Gassaway,
Petitioner, Defendant
TO THE PROTHONOTARY:
NO. 05-867
CIVIL ACTION -
AND NOW this 28th day of March, 2005, the Petitioner,
mutually agreed upon Custody Stipulation/Order and requests that
the attached Custody Order.
Date
Respectfully Submitted
TURO LAW OFFICES
Gdlen R. Waltz, Es r
28 South Pitt Str
Carlisle, PA 17013
(717) 245-9688 ext 22
Attorney for Defendant
VIL TERM
submits a
Honorable Court
-a>
c? -al
Y
-? m
• ,
_KJ
-r.
C `.!J
s-'
Andrew S. Gassaway, : IN THE COURT OF COM40N PLEAS
Respondent, Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
Jennifer M. Gassaway,
Petitioner. Defendant
NO. 05-867
CIVIL ACTION -
CUSTODY ORDER
AND NOW, This ? day of
upon consideration of the attached stipulation by the parEies di pnylrg
agreement of the parties hereto, the following is Ordered and Directed:
2005
1. The mother, Jennifer M. Gassaway, and the father, A drew S.
Gassaway, shall enjoy shared legal custody of children, Nichol s A. Gassaway,
born November 8, 1992, Christopher D. Gassaway, born Octo er 27, 1994,
Thomas M. Gassaway, born May 13, 1996 and Brian W. Gass way, Born
October 20, 1998. Major decisions concerning their children, in luding, but not
necessarily limited to, the children's health, welfare, education, religious training
and up bringing shall be made by them jointly, after discussion nd consultation
with each other, with a view toward obtaining and following a h rmonious policy
in the children's best interest. Each party shall not impair the of er party's rights
to shared legal custody of the children. Each party shall not ali nate the
affections of the children from the other party. Each party shall otify the other of
an activity or circumstance concerning their children that could easonably be
expected to be of concern of the parent then having physical c stody. With
regard to any emergency decisions which must be made, the p rent having
physical custody of the children at the time of emergency shall a permitted to
make any immediate decisions necessitated thereby. However, that parent shall
inform the other of the emergency and consult with him or her soon as
thereafter possible. Each party shall be entitled to complete an full information
from any doctor, dentist, teacher, professional or authority and have copies of
any reports given to either party as a parent.
2. Primary physical custody of the children shall be in thelmother.
3. The father shall have the following periods of partial cu tody:
a. Every other weekend beginning Friday at 5:15 PM to unday at
5:15PM;
b. One overnight evening during the week (Wednesday) from the
conclusion of the Wednesday school day until the be inning of the
Thursday school day.
L TERM
4. The holiday custody schedule shall be as follows:
The holidays are defined as New Year's Eve/New Year's Day, Easter, Memorial
Day, July 4m, Labor Day, Thanksgiving, Christmas Eve and C? ristmas Day and
the day after Christmas.
Mother shall always have custody of the children New ears Eve from
5:15p.m. through New Year's Day to 5:15p.m. When New Ye is Day occurs on
a Friday, Saturday, Sunday or Monday, mother shall have cus ody of the children
the entire New Year's weekend.
Memorial Day and its attendant weekend shall be dedic ted to mother
who shall always have custody of the children for the entire M morial Day
weekend.
July 4th and Labor Day holidays and their attendant we ends shall be
dedicated to the father who shall always have custody of the c ildren for these
weekends and holidays.
The following holidays shall alternate and rotate: Than giving, Christmas
and Easter.
Mother shall have custody of the children Thanksgiving ve, 200I from
5:15p.m. to Thanksgiving Day at 12:00p.m. (noon) and fathers all have custody
of the children from Thanksgiving Day from 12:00p.m. (noon) t rough Sunday at
5:15p.m. or Monday at 5:15p.m. when Monday is part of the T anksgiving school
holiday.
Mother shall have custody of the children Christmas Ev 2005 from the
time the children awaken on Christmas Eve to Christmas Day t noon and Father
shall have custody of the children from Christmas Day noon ti a to the next day
until 5:15PM.
Mother shall have custody of the children from 5:15p.m. he Eve of Easter.
2006, until Easter Day at 12:00p.m. (noon); father shall have c stody of the
children from Easter Day at noon until 5:15p.m. or Monday at 5 15p.m. when
Monday is part of the Easter school holiday.
This schedule shall rotate and alternate on a yearly basi .
5. Mother shall have physical custody of the children
8:OOPM on Mother's Day and Father shall have physical cu
from 8:OOAM until 8:OOPM on Father's Day
6. For each of the children's Birthday, the non-custodial
custody of the birthday child for a period of 2 hours for either k
7. Exchange of custody shall occur at the custodial p?
unless other arrangements are made and agreed to by both
alternate place for the exchange of custody. The party recei
children shall provide the transportation.
8:OOAM until
of the children
shall have
or dinner.
residence,
s for an
astody of the
8. Neither parent shall do or say anything which may estringe the children
from the other parent, injure the opinion of the children as to
hinder the children's free and natural development of the chi
respect for the other parent.
9. The custodial parent shall inform the non-custodial p
of all medical appointments and all problems pertaining to the
10. Both parents shall have liberal and reasonable teleF
the children when the children are in the custody of the other
shall have two (2) consecutive or non consecutive vacation m
children; each party shall provide the other parent 30 days a(
of the vacation plans, destination and telephone number whe
reached in the event of an emergency.
11. Both parties may alter this schedule as they may ag
parties cannot agree, the schedule outlined in this order shall
other parent or
n's love and
immediately
ne contact with
rent. Each party
ks with their
nce written notice
children can be
however, if the
12. This order is entered pursuant to the agreement of t e parties in
matter and in the event either party desires to modify this orde , tha arty
petition the court to have the case again scheduled with the ?o it pur ni
applicable law. f
By the
i
i?:??+`+LI`a"•..;,iuric ?I,l aQ
:?':;!??tC? UJ?i?
Andrew S. Gassaway,
Respondent, Plaintiff
V.
Jennifer M. Gassaway,
Petitioner. Defendant
IN THE COURT OF COMA
CUMBERLAND COUNTY.
NO. 05-867
CIVIL ACTION -
CUSTODY STIPULATION
The parties stipulate to the attached Court Order.
Date
3 /1 .r/vim
Date
Andrew S.
Jennifer M.
PLEAS
NSYLVANIA
L TERM
MAR 2 8 20®5
J y
Yom,
g_
d?
RECEIVED APR 12 2005 Gi--'
I
ANDREW S. GASSAWAY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v : CIVIL ACTION - LAW
JENNIFER M. GASSAWAY, NO. 05-867
Defendant IN CUSTODY
COURT ORDER
AND NOW, this (( day of April, 2005, the Conciliator being advised that the
parties have reached an agreement, the Conciliator relinquishes jurisdiction.
?-If -o S
Date
Hubert X.
2i,QS Ai'it 13 [1 1-1 9-. 23
ANDREW S. GASSAWAY,
Plaintiff
V.
JENNIFER M. GASSAWAY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-0867 CIVIL TERM
IN LAW - DIVORCE
INVENTORY AND APPRAISEMENT
OF
ANDREWS. GASSAWAY. PLAINTIFF
Plaintiff files the following inventory of all property owned or possessed by either
party at the time this action was commenced and all property transferred within the
preceding three years.
Plaintiff verifies that the statements made in this inventory are true and correct.
Plaintiff understands that false statements herein are made subject to the
penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities.
Date: U !?1 e' ' ?T G?1
Andrew S, Gassaway
ASSETS OF THE PARTIES
Plaintiff marks on the list below those items applicable to the case at bar and
itemizes the assets on the following pages.
( X) 1. Real property
( X) 2. Motor vehicles
( X) 3. Stocks, bonds, securities and options
( ) 4. Certificates of deposit
( X) 5. Checking accounts, cash
( X) 6. Savings accounts, money market and savings certificates
( ) 7. Contents of safe deposit boxes
( ) 8. Trusts
( ) 9. Life insurance policies (indicate face value, cash surrender value
and current beneficiaries)
( ) 10. Annuities
() 11. Gifts
( ) 12. Inheritances
() 13. Patents, copyrights, inventions, royalties
( ) 14. Personal property outside the home
() 15. Business (list all owners, including percentage of ownership, and
officer/director positions held by a party with company)
( ) 16. Employment termination benefits--severance pay, worker's
compensation claim/award
() 17. Profit sharing plans
() 18. Pension plans (indicate employee contribution and date plan vests)
( X) 19. Retirement plans, Individual Retirement Accounts
( ) 20. Disability payments
( ) 21. Litigation claims (matured and unmatured)
( ) 22. MilitaryN.A. benefits
( ) 23. Education benefits
( ) 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)
( X) 26. Other (see attached list)
10 'Il dt y T U A
y r '.tij O 'oi<I< wow Io m o v`v z
p m(? Za,mD o
12, o 3I°mo a5 3@i (Io N 3
? T N N. N
'
i3 3 3 m
4 C li? 3 Iq 2 t3. ] 0 5"m m N. m N S 5 8 8 0
L
NIA m ?Z3
ow w 10,
W O m OI # m N ^? O
O (f O 01 N W 6j
N ON W bW » W m
I I {O O m I I '. '. i
O
?+ '' II 'w'\ w ? w w w'! II ' wl` W w v
> d a-0 A L A S _ A A A A L
I W M?Ni (A'. ffllM ffl (A diWY
N.w,w AIA ??. Ol !J ?u
w m
N (O O W L? W A m O O C
? III I li ..III I
W uF» «?w?u. (n«?fn1 W IV+ w ? Iw ww«?fn
I I I ? I I? II ?I
m ulw w W'w,Fn?in _? w w w w «Ic
17
II f
II I I I III I II ' I I
. ooo
I I I
A w_
I I I m N
I O
I I
m 4o 1. m_ 3 3?.
O
n°
III 'I i
w.w w?
N N NIN
O O O'O
AA A'A
f 1i 1WW
Il
? 0 am p inyN
N D
q 6
Q
N C N 0'
N
m u a
CD
N S
v m
?
? C
m ?
I I
I',Iw?
w m ?
I? __ OJ<
m m
AIC
?1? w1.l IW
NNtO A JO W Iwo ' p)A' m
A AIA AIIAJ J N J W? yW NIA w W O I ti
0000(n 111}N NANInNNAO N.? WW O '
O O N W A O? N'N O W W O ro-0 OI(r O '
I II, I I Ii Il ! I III, IIw j 11
N
;_ i I I I
Wlfy wlwly v+tn?vi `»?mww wv+l w', e. wwlwlw_w
N N N A''+ J O W?' W+ q A I VWi
AAA A A J J N V m' OI N O N (d V
W l??wlwl w?v+w ?nwwwtn v,www 4w 1«,- ? ? I?
I I I I I I
W
N
a
Ia
O '.? N 'mm I' p I '
N
d
a Z
D
D
N 6,0
m ? y
3 ? f
m n m
c "
m m 0
6 ? W
a°F
a o
? c
f ?
N?
m
N
f
N
I
of { _
D I
rll
III
N
pj a
J ?
w -.
O N
J S
a?
w k0
b
N
w
lU
j€I
N O1
N? I?I J
w
Q^' N
J li
NI
I ai ? i mK m. J s? o
I I w? ? I m`wSw D? m ml m
o Is II ', I4 m o'' F o'
I J p I I <' '31 0
? I I w I
A O
11IN N N N N N N
I II III I jl II ? I? I I I
I I I i! ' I
Ili' I
I N
O
'I ?' 1NNNN(N.MNN..N
-_L11 1 I
III II I i ? ? I ? '
o.l o` I ? foumiN°m .'>°.o?'? I I I ? I.
I f ?,, ? ', ? ? ' III
I j I I I I I ' ',,
I
?I I I ? I fi
II I I II I? II ?? ? II
3' I
w
?I
N
J
O
d
aZ
D P
D
Da_ b
= C J 0
n
3
n ? m
Q d N
< ? w
a
00
a G <
c
F
N
N
d
d
^? d
i'7 c
. -s?
` a
?? ?? ?
?
_?i,;
1
:? ??
??C
l
?
i
Y-
•:
I. 1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION: LAW
Plaintiff -5,
Street Address ;? .5-Z -;UT Cyo?J_i>r-
Afl Cn
City- State -Zip Code f r? nr }f,'t ?A
VS.
Defendant Je ?+.t, r`L'. IY(. ?? sst.wrt.
a J:
Street Address /O `/n?q?cnse77t Dr.
City -State - Zip Code o7i a,{ , 1,4
NO. roc - as
05- -- U E3
G? 7
ACTION IN DIVORCE
Attorney for Plaintiff ?• r ?f a L , tt U b Attorney for Defendant 6?ex/&;,j 1 ?.q C_ t z
Street Address 3 S C 3 tI ?r 9,/
Street Address .9g> _f, /,1, tlk S},
City - State - Zip Code C t n r f/•` t/s CA / 70 t!
Phone Number -7(,3 5 j ?'O
City- State - Zip Code C e, i, s ?C l??{ ) 71945
Phone Number a y i q to g
INVENTORY AND APPRAISEMENC
OF
DEFENDANT
DEFENDANT 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.
DEFENDANT understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating
to unsworn falsification to authorities.
?.
ASSETS OF PARTIES
DEFENDANT marks on the list below those items applicable to the case at bar and itemizes the assets on the following
pages. If an item has been appraised, a copy of the appraisal report is attached/
( / ) 1. Real property
2. Motor Vehicles
( -21 ) 3. Stocks, bonds, securities and options
( - ) 4. Certificates of deposit
( ?2a i 5. Checking accounts, cash
(.2 6. Savings accounts, money market and savings certificates
(- ) 7. Contents of safe deposit boxes
( ) 8. Trusts
( 3[a"?? 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries)
( -) 10. Annuities
( -) 11. Gifts
( ) 12. Inheritances
( - ) 13. Patents, copyrights, inventions, royalties
( ) 14. Personal property outside the home
( ) 15. Businesses (list all owners, including percentages of ownership, and officer/director
positions held by a parry with company)
( - ) 16. Employment termination benefits - severance pay, workman's compensation claim/award
(- ) 17. Profit sharing plans
( - ) 18. Pension plans (indicate employee contribution and date plan vests)
(.2.2 --y) 19. Retirement plans, individual retirement accounts
( - ) 20. Disability payments
(- ) 21. Litigation claims (matured and unrnatured)
( - ) 22. Military/V.A. benefits
(- )23, Education benefits
( j ) 24. Debts due, including loans, mortgages held
( ) 25. Household furnishings, personality (include as a total category and attach itemized list of
v o ? ? o y o
w =. O
w
~ N
O (D
O v C
)>
N 3, ? 7 d ? ? N
? a 7 ?. N O
'O.
7 O
t
o ff
N
a
a. °" <n
m A " °
' m
o
° ?' m e
q m° r. w m m n to
mo
m 3o-a
,
a ?
D
°
D m m o 1
? a a w
,
o cn G
a ^
_
0000
°>
O
00
Z
w
m
m
W
w
F
r
O
SD
m?
om
?A
mo
O m
m{_
q Z
-1 =
O=
Z
m
wzl
m
A
O
O
S
v
O
C
N
N
S
? G
m
co
m
G1 -a
v
A o
p
? C A
r
m
z
N -1
A m
.b
m
N
N O
N C
n q
r
m
O
N ?
e0 =
Z
O
w T
N m
w ."U
A n
m
N
w O
cn Z
? D
N
w
a
MARITAL PROPERTY
DEFENDANT lists all marital property in which either or both spouses have a legal or equitable interest individually or with
any other person as of the date this action was commenced:
ITEM NUMBER / ITEM NUMBER 2 ITEM NUMBER 3
/a .?
DESCRII)TION
N uss ??:1 v
1,117 h?da FFttmd
/ y?7 GM[ S'c.6c,?L
OFPROPERTY
NAMES OF dre nT?., k? Tc ??-+z^yt? ?r ,/v
ALL OWNERS 4v ,4„ +s
DATE OF
ACQUISITION s 66 a
COST OR VALUE
AS OF DATE OF 4S Oo0
ACQUISITION
VALUE AS OF Irc d L +r <ir' i ra< ,,, fz
DATE ACTION 4Ia y ?-) tou e n
COMMENCED a a sa) 044X"'. n Z s zc h)
AMOUNTS OF 15,2c/53. oS- JJ $
ANY LIEN
NATURE OF ANY
LIEN
EFFECTIVE DATE
OF LIEN
HOLDER OF LIEN , d t6????c •,rf. e
ITEM NUMBER ITEM NUMBER S ITEM NUMBER L
DESCRIPTION ??? a
y
C?°^ may
OF PROPERTY
NAMES OF Ghdrs ?rPw Je,, ;/v
ALL OWNERS
DATE OF
ACQUISITION
COST OR VALUE
AS OF DATE OF
ACQUISITION
VALUE AS OF
C'
DATE ACTION ??
COMMENCED
AMOUNTS OF
ANY LIEN _
NATURE OF ANY
LIEN J
EFFECTIVE DATE
OF LIEN
HOLDER OF LIEN
ITEM NUMBER ITEM NUMBER ITEM NUMBER
DESCRIPTION
c ?cu t G"?
I? vrnlas C?ryS?
I ?( I
OF PROPERTY
NAMES OF
?enni
(?r'?
Ardre
ALL OWNERS
DATE OF
ACQUISITION
COST OR VALUE
AS OF DATE OF
ACQUISITION
VALUE AS OF
DATE ACTION
COMMENCED C
AMOUNTS OF
ANY LIEN
NATURE OF ANY
LIEN _
EFFECTIVE DATE _
OF LIEN _
HOLDER OF LIEN
ITEM NUMBER Id ITEM NUMBER I ITEM NUMBER ix
DESCRIPTION =n i e/ J° J L k u. t
OF PROPERTY
NAMES OF h?lrz grlezcu ig"dreW
ALL OWNERS
DATE OF
ACQUISITION
COST OR VALUE
AS OF DATE OF
ACQUISITION
VALUE AS OF
DATE ACTION Iv, ?'L7 47
(ot) `l, 7!77. If'/
COMMENCED e
AMOUNTS OF
ANY LIEN _
NATURE OF ANY
LIEN
EFFECTIVEDATE
OF LIEN
HOLDER OF LIEN -- --
ITEM NC bIBER I'I EM NTFNIBER U ITEM NUMBF.R,2-
DESCRIPTION
N C ?" "
T ,'cnn
W nom f
OF PROPERTY
NAMES OF A Ar,.
F}ndre+.J
s?-ndr??
ALL OWNERS
DATE OF
ACQUISITION
COST OR VALUE
AS OF DATE OF
ACQUISITION
VALUE AS OF
DATE ACTION -3; -23v. 74)
COMMENCED r
AMOUNTS OF
ANY LIEN _
NATURE OF ANY
LIEN -
EFFECTIVE DATE _
OF LIEN -
HOLDER OF LIEN -
ITEM NUMBER a2 7 ITEM NUNMER ITEM NUMBER
_
O elm uu Cl.ck Sr fa z, 5""n
N
DESCRIPTI
OFPROPER'TY _
?it
-Fro a5 2,.x 9,,-' -7 4W-0 7l -ra 687
NAMES OF r?v.Ar. ?ru Terr:4%r
ALL OWNERS ffT ^^? Tzn ??+r
DATE OF
ACQUISITION
COST OR VALUE
AS OF DATE OF
AC USITION
VALUE AS OF
DATE ACTION /144 .(aD 1036,13 cSOJ1.15
COMMENCED
AMOUNTS OF
ANY LIEN
NATURE OF ANY
LIEN
EFFECTIVE DATE
OF LIEN _
HOLDER OF LIEN _
IT7=MNUMBER,?S ITEM NUMBER zb ITEM NUMBER
V (a AY" 14 VCw,y uanI- W YdSor 11 Lu? ;3a,,JL.'
DESCRIPTION
OFPROPERTY
3? RF7443VSro
73 tiC1,24IV a9s/o SAS„
(b 11 ? 6 F 7 F
NAMES OF ?.d re,d rzc.. ¢
AJiL%
d
ALL OWNERS Te=,? Tern;
DATE OF
ACQUISITION
COST OR VALUE
AS OF DATE OF
ACQUISITION
VALLT AS OF
I
/8a91 QJL
,G?fr. szp a W, l1
y
DATE ACT
ON
CO_-MNfENCED
AMOUNTS OF
ANY LIEN
NATURE OF ANY
LIEN.
EFFECTIVE DATE
OF LIEN
HOLDJi12 OF LIEN -` --_ -
77 ITEM NLT.MBF..R,)g' ITEM NUMBER A IMM NUMBER 30
Oi,V-arc. Sa ?S i C G r-4 7fcl
DESCRIPTION -l330l
35--41 goo5-gb359-4,
OF PROPERTY l6L?to?Fv2753 ,
NAMES OF Aid ru.J A dreal
ALL OWNERS
F
ITION
R VALUE
F
ASOFDATEOF
SITION
VALUE AS OF
DATE ACTION tl,OGD', u L?s 6`17.1{3
COMMENCED 6
AMOUNTS OF _
ANY LIEN -- -
MATURE OF ANY
LIEN
EFFECTIVE DATE
OF LIEN
HOLDER OF LIEN ?'
ITEM NUMBER 31 ITEM NUMBER 3,Z ITEM NUMBHR33
vcx..,j -tJ,,.eso. a
A ?,';le , Vow?uG„e? - Sfan
DESCRIPTION
OF PROPERTY
jc
`IrtG4¢"7OD9 0
aAal3G7a?1
SG o9fiji24/?/d4
NAMES OF
?artw
r°n :?
J „Hilo
ALL OWNERS
DA17E OF
ACQUISITION
COST OR VALUE
AS OF DATE OF
AC U15ITION
VALUE AS OF
DATE ACTION 26 DiP, &3 33oS "73
COMMENCED
AMOUNTS OF f
ANY LIEN -
NATURE OF ANY _
LIEN
EFFECTIVE DATE - ? _
OF LIEN
HOLDER OF LIEN -
ITEM NUMBER3`f ITEM NUMBER:35' ITEM NUMBER 3&
Vm. ua,4-W,w+?a ?t C,C,,.,cf-tis
DESCRIPTION E_',.QR
ra srd'f SG 31 D
OFPROPERTY J3-°79L4?f 3a? i
NAMES OF PP
T :^^;tY
ire
/? ,dr?u
ALL OWNERS
DATE OF
ACQUISITION
rt - * F
COST OR VALUE
AS OF DATE OF
ACQUISITION
VALUE AS OF
DATE ACTION .12,7-T 9 , b5
COMMENCED
AMOUNTS OF _
ANY LIEN -
NATURE OF ANY
LIEN
- _
EFFECTIVE DATE
OF LIEN -
HOLDER OF LIEN -
ITEMNUMBER3'1 ITEMNUMBER3P ITEMNUMBER
Nat was L.R L ?. Nah' Ord t F? =ri,
DESCRWTION
OFPROPERTY L-U53 a80a300 Lmsag?aaS
NAMES OF
Sz
ALL OWNERS ??
DATE OF
ACQUISITION
COST OR VALUE
AS OF DATE OF
ACQUISITION
VALUE AS OF
DATE ACTION
COMMENCED W
AMOUNTS OF
ANY LIEN
NATURE OF ANY
LIEN
EFFECTIVE DATE
OF LIEN
HOLDER OF LIEN
Monthly Mortgage Statement 02/24/04
Wells Fargo }come Mortgage Inc
Correspondence
PO Box 10335
Des Moines IA 50306-0335
IBWNDXCT
/7080128573839021#
Customer Service
Online Loan Number
yourwelisfargolmortgage.com 0128573839
Pbone
(866) 234-8271
Fax
(866) 278-1179
TTY Deaf/Hard of Hearing
(800) 934-9998
To Purchase or A;efinance
015548 (800) 778-4968
ANDREW S GASSAWAY
JENNIFER M GASSAWAY
10 NARAGANSETT DRIVE
MECHANICSBURG PA 17050-7900
IIII III III IIIIIIIIII VIII VIII VIII IIIII I loll ]III I IIII I IIIII
Send Payments To
P.O. Box 17339
Baltimore, MD 21297
Overnigbi mail payments
666 Walnut Street
Suite 400
Des Moines, IA 50309
Property address
10 NARAGANISETT DRIVE
MECHANICSBURG PA 17050
Principal balance as of 02/24/04 Important Messages
$152,453.05
Contact Customer Service
for your payoff balance.
Payment (Principal Interest) $832.08 Interest rate
Optional Product(s) $ .00 5.000%r
Current Monthly Payment $832,08 Interest paid - year-to-date
Overdue Payment(s) $ .00 $1+272.8'9
Unpaid Late Charge(s) $ .00
Other Charges $ ,00
Total Payment Due 04/01/04 $832.08
Activity Since Your Last Statement
Date Description Total Principal Interest Escrow Late charge Other
04/24.PAYMENT $832:08 $196:04 $636:04
......... .......................................
Interest Paid in the amount of $4,607.11
is included on your IRS Form 1098 for Tax Year 2003.
(Keep opP r "mum, for your records.)
07455MBNM 07455MBNM2
Please Imlurse This Portion With Your Payment
Total Payment Due 04/01/04 $832.08
ANDREW S GASSAWAY
JENNIFER M GASSAWAY
After 04/18/04 Add Late Fee
$41.60
10 NARAGANSETT DRIVE Total Amount Due After 04/16/04: $873.68
MECHANICSBURG PA 17050
)q.,,,..h<k m..
ho-, a d,„"w', w, Monthly Payment
I"Jfc rcd uv rhr
x Pont amt
708 Loan Number: 0128573639
Customer Service: (856) 234-8271
I IIIIIIIIIIIIII)Illll)I)11111'1111II ll III IIII IIIIIIIIIIIII III
WELLS FARGO HOME MORTGAGE INC
PO BOX 17339
BALTIMORE MD 21297-1339
IIIIII 11111 111 111111111111 11111
1'I?'e spmii? ?JJinon.il
fuGmdv...JvnAe nnnpmiiied wflill
l he
applieJ first "? a">
o? rsrvWinl:.hnrgs.
Late Charges
Additional Principal
Additional Escrow
Other Charges
Total Amount Enclosed
(PLEASE DO NOT SEND CASH)
708 0128573839 5 10 00 00083208 00087368 00083208 00000000 8
Mail
FAUMER
FAULKNER NISSAN
2650 Paxton St. - P.O. Box 2861
HARRISBURG, PA. 17105
(717) 558-8220
2060 Paxton St. P.O. Box 2861
HARRISBURG, PA. 17105
Phone 717-238-7324
O FAULKNER HONDA O
2020 Paxton St. - P.O. Box 2861
HARRISBURG, PA. 17105
(717)232-8800
PLEASE ENTER MY ORDER FOR THE FOLLOWING
PRIOR NAME _ ^C
jENN1I-tR li UF1 DATE
25 'E' "Of
? NEW or ? USED ? DEMO ? CAR ? TRUCK USE: _
YR.-, . MAK MODEL TYPE
"iU AS`E4 OfR STREET
10 NARAGA;jSE-1T EllR1VE
COLOQ
?:
L VER
TRIM MILEAGE
cl CITY f STATE FA 70
11ECHAid1CSs iR? 1 y 1 ZIP
VIN T O
4 N U E
b S 5 4 6 1 PHONE
RES. ifi
"1/t)C"-54g4 PHONE
BUS. (71')541-
7GI
J
4. O 0 7 1
1 1 . i
ESMAN
ST IKSjj''11D.? SAI TO BE DEUVEREDD ON OR ABOUT " AGE DATE OF BIRTH
2
U
(_?it/3t l2,l3R'?l?T r_11111.`.Ir ' R 25 SEI 2004 NO.
DESCRIPTION • TRADE PRICE OF VEHICLE: 34163.00
YR.? MAKE MODEL TYPE
,. 0"C SU3?iRBr,yl r;p Rebate Amount 5000.00
COLOR TRIM MILEAGE
011 J N
R 13
vl ! G
K F is 1 6 8 4 1d G S 1 4 3 1 3
TITLE NO. PLATE NO. EXP. DATE
/?
..1:. . V i I hl)G "Gil 492r
OWNER LOAN It
UENHOLDER PHONE
ADDRESS SPOKE WITH
AMOUNT GOODTIUL PER DIEM VERIFIED BY
EXTENDED
COLLISION COVERAGE WARRANTY TYPE_
NAME OF AGENT PHONE
7 MONTHS MILES
t4T1E R r;1SE4. 71
76, 0191_;
ADDRESS Cash Price of Vehicle a Accessories 29163.00
Sales Tax 1505
78
POLICY NUMBER
.18 37 v `JH 513 US COLLISION DEDUCTIBLE REGISTRATION TITLE TRANSFER ENCUMBRANCE .
22SO 6.00 5.00 33.50
jNSU-PANCE CO.
, 110Nr1itE SPOKE WITH
Documentary Fee
65.00
EFFECTIVE DATE EXP. GAT J
-
VERIFIED By
Messenger Fee
•-
WARRANTY
Notary Fee
° FACTORY WARRANTY - The factory warranty constitutes all of the warranties with respect to Ore sale of this • = PA NEW CAR T 1 RE TAX S.00
temttems. The seller hereby expressly disclaims all warranties, either expressed or implied including any
1 implied warranty of merchantability or fitness for a particular purpose, and the seller neither assumes nor O i L 13'v E DEALER SERVICE FEE
11.00
authorizes any other person to assume for it any liability in connection with the sale of this itemrtlems.
? USED CAR WARRANTY - Used car is covered by a limited warranty detailed in a separate document.
ON L I N E REGISTRATION FEES
15-45
? AS IS - This motor vehicle is sold "AS IS" without any warranty either expressed or implied. The purchaser
will bear the entire expense of repairing or correcting any defect that presently exists or that may occur in Total Price 30792,73
the vehicle.
PURCHASER'S - -
SIGNATURE X Trade-In 4000.00
USED CARCONTRACTUAL DISCLOSURE STATEMENT *Payoff Amoum Less Payoff
THE INFORMATION YOU SEE ON THE WINDOW FORM FOR THIS - Is Subject To
VEHICLE IS PART OF THIS CONTRACT. INFORMATION ON THE Verification Net Trade In 4000.00
WINDOW FORM OVERRIDES ANY CONTRARY PROVISIONS IN THE ?•-,-
CONTRACT OF SALE. Deposit 3000.00
If you cancel this purchase agreement or refuse to take delivery of the vehicle '-
ordered, except as permitted by law, you shall, at our option, forfeit as damages '- 'Cash on Delivery
the amount of $
PURCHASER'S Net +DeposB+CCasho. = Total Down Payment
Trade y i 000 (JO
SIGNATURE X Un aid Balance of Total Price
p 2
752 . 73
PUrChBSer I,¢re0y aCkngNe0ga510IhB eCOVe cleuSB. 2
Purchaser agrees that this order includes all of the terms and conditions on both the face and reverse side hereof, that this order cancels and supersedes any
prior agreement and as of the date hereof comprises the complete and exclusive statement of the terms of agreement relating to the subject matters covered
hereby. This order shall not become binding until accepted by the dealer or his authorized representative. You, the buyer may cancel this contract and receive
a full refund any time before receipt of a copy of this contract signed by an authorized dealer representative by giving written notice of cancellation to the dealer.
Purchaser by his execution of this order acknowledges that he has read its terms and conditions and has receiveda true. copy of thiaorder.
PURCHASER'S , u r 0 r. Eij:. - '
SIGNATURE X ' t`... !47 .? - I, DATE"' - t)"• ACCEPTED BY DATE1 9;
ORDER TOLL FREE: 1-800-344-0996 FAX: 111800-531-9055
Rasmrmoc
I
F -
z
I
O
U
U
Q
LL
O
F-
LU
75
W
1-7
Q
U)
?i
O
gu
bbo
pY
H
:£
C. v
(? E
C]
3
co
O
W
W
LL_
2
Z
W
Ofhwo00
o.s ORRoo N
q
o m m 0 Q0
N O m
N N
m
A
a? o ?
g
s
s
OnooOO
O O N O o r
N
Q
oWViooo
N
<
m
m
N O
N m
v
c
B
B
m
m
s
E
Q
O
w ? t4
w ?
d
zwFt
WSZ m
ozoi--
W
-X Z
mad?
Q
1- 0 JYp?W? n
n
?Q<DO>
z2 W J 2? o
W
a a
a
O
?
pw
j
XH
Op
< 2 W `! LL O
1N3al3
0
O W m
W
w ?a
ro
OoWx
x?¢-1
g
N r d
N
n
lcl?
a
m
N
a
OI
N
0
p
LL
w
2
J
aN
0
A
0
0
(0 ?2 y
RW
U?Z
O:x ?: QU
CS
¢Z03
ZLU?Cz
o>Q>a
Z P3C-
;K Ec
ZW 8
C>r
jam`
O:? WWi-L-j
?¢ jZ
?wa°z8
W?QR
10 LiI :5
:7j
Cui
C
OZZf
2ylS>¢
WWco
h'Qu
osoa Vd eunaS3INVN03W
NO 113SNVBVSVN 01
AVMVSSV9 3 M3JlNN3f
3
f4
a
w
w
Q
W
LL
z
z
W
<
c
o
U
?
O
D CO
UU
b o
o
E o
W W
? O
O O O
o r
N
IY
0
0
0
00
00
00
N CI
OI
N r
x
20
xU
z co
w
w ¢p
z
z ~
w
1
w ?U
< s?
3 as
< 00
0
W
2Q?
yza?
> w
4 m W
tu >.
LU Z Q. CE
?
?Ry
w
co
0 Go
?mCC
U
8Jp
W Z U
y
z
R4?jyJ
SJgj
?wz°e
pUp>r:
n
Z L
I? Intel.
ANDREW S GASSAWAY
10 NARAGANSETT
MECHANICSBURG PA 17050
Computershare Trust Co., Inc.
2 North LaSalle Street
Chicago Illinois 60602
Within the US, Canada & Puerto Rico: 800 298 0146
Outside the US, Canada 8 Puerto Rico: 312 360 5123
Facsimile: 312 601 4335
www.computershare.com
f omputershare ( 60
For a change of address or to obtain a form, please
INTC visit us at www.computershare.com or call us at the
above telephone number.
Holder Account Number
C 0002107287 I N D
Ilrrlllrrrlll11111111111111r1111r1,IIIIrrll1?11111111111111?11
SSNRIN Certified Yes
Uncertified accounts are subject to withholding taxes
on dividend payments and sales proceeds.
I Intel Corporation -Dividend Reinvestment Plan Statement
Intel Corporation doubles the quarterly cash dividend from $0.02 per share to $0.04 per share per quarter. The payment date is March 1, 2004 to holders
of record of the Common Stock as of Feb. 7, 2004.
Information
Record Date: 07 Feb 2004 Holder Account Number:C 0002107287
raFyment Class Description Shares/Units Participating Dividend Gross Deduction I Deduction Net
Date in Dividend Reinvesment Rate ($) Dividend ($) Amount ($) Type Dividend ($)
01 Mar 2004 Common
Transaction History
365.159919
0.040000 14.61
14.61
From: 01 Jan 2004
To: 01 Mar 2004
Date
01 Mar 2004
Dividend Reinvestment 14.61
14.61 29.1108a8 0.501874
Summary of Holdings Date: 01 Mar 2004 001 CS030 RPS.DL.INTC.75737_6%%1506%1507/iI
Certificated Shares/Units Direct Registration/ Dividend Reinvestment Closing Price Per
Held By You I Book ShareslUnits Shares/Units Total Shares/Units Share/Unit ($) I Value ($)
Transaction Description I Transaction Deduction Deduction Net I Price Per I Total
Amount ($) Amount ($) Type Amount ($) SharefUnit ($) ShareslUnits
0.000000 5.661793 365.661793
J
Z
O
U
U
U_
O
W
W
Q
o oaooo
000000
O O N O O O
N
r
at
O
°o o?o°o°o
00(000G
N
h
N
=W
m5ozjm
z~00co 2
41
m<<Do>
z W J Z?
OW-now
8 Op?X-
qMW `! LL O
iN3W3d
4
N
7
N
Y
.Q.
s
m
m
O
m
C
N
d
U
s
d
s
0
d
n
a
V
a
a
n
n
103W
OICIM
0
0
o?
o?
0
d
0
0
V
N
?U
Qa
?W
y
Oz
LL W
a
ZW>
J z ~
QU
mw
Q
$?w
a-0
0
z
Mw
C.5 Z
Oa?
¢2N°Z
14 L?cZ
>co
Q ?03
ll: U ? Q N
03
w
ui
o?wW(-
?¢ CL Z
wR°z8
w?f¢2
?'0
uZ OHcc
wQ(0zGTi
3(w)0f
I N
W
G 00 U
'Y
W
4
N
cf?
c
:s
O '?F U
`v Y
Y
L
E
1"'I 4
T?^
Opp
:Q
4
3?q
(o
co
6
Q
a
Ik a
n
S
I
a a?
O a
:?1 a
YN ZI
?a o
f?5 d
cp??? 1
a $
W
Tm
4
Z 7 y
2 p ?
m$ j
=ma10
¢tt
¢V-LU
a h
s Wu
Imu
W g?s(
?s` 4 jgp
4?C7 U
W a J N
O<
L.q?j
TL "K z w
F ?
N
W
N
¢
W
W
¢
W
N
a
w
1
a
z
O
a
z_
Y
r
0
Z
O
a
¢
c
u
c
z
a
a
U
a
C
0
?. V Z S
o `
j
F
.e
ci K
.1
f u V?
24]p
F C] U F
3 yg
? 6 ? F
Q V 2
?,?
?
V' V'.. 'n '.n n 0 0 - Q Q
0
oa Ln r
nnrn o'o oo
I 1 0 N
•+O NM M MM
1 I N N N N N
M M M - O
O
p
0
n FF
Z
ti F
>?
QoIL €
a
a ;
?
rnwz
Qyn'
Q. 1
(A UU
y
?
C
Ch 3C
z
a
'
W Q d I. a
M 2 2 o
? o =i u
In 2 Q^s'
z o
5 ?
w
o 5, 21
Direct Purchase Plan Account Statement
cost-tresis records,;s '
IMPORTANT;' F;ata40Wta( Ill fob your trlveslmo .tax 014
Questions: U.S. telephone number: 800-522-9114 Outside U.S.: 651-554-3875
For online account information, please visit www.shareowneronline.com
Fax number for transaction requests: 651-450-4085 Cusip # 589331107
ccount Summary MERCK
ANDREW S GASSAWAY Share Balances
10 NARAGANSETT OR Direct Purchase Plan
MECHANICSBURG PA 17050-7900 Certificate(s)
Direct Registration
Total Shares
Current Dividend
Year-to-Date Amounts Record Date
Gross Div/Cap Gains Reinvested $57.98 Payable Date
Federal Tax Withheld $0.00 Dividend Rate
Nonresident Alien Tax Withheld $0.00 Account Value
Cash Investments $0.00 Market Value Date
Service Charges Paid by You $2.31 Market Value Price
Commissions Paid by You $0.02 Account Market Value
MERCK & CO., INC.
STOCK INVESTMENT PLAN `a
Page 1 of I
Account# 4000023165
April 2r 2004
Record Date Current
48.652 49.277
30.000 30.000
0.000 0.000
78.652 79.277
03/05/04
04/01/04
$0.37
D4/01/04
$44.79
$3,550.82
Year-to-Date Activity
Transaction or Transaction Gross Amount of Service Net Amount of Price Shares Increased Total Shares
Settlement Date Type Transaction Charge Transaction per Share or Decreased Held in Plan
ORWARD 48.065
Div Reinvested iffl $1.15 1127 $47.2253 48.652
Div Reinvested i. $1.16 $7 . $44.7403 h 49.277
Merck & Co., Inc. is participating in the Direct Registration System ("DRS"). You may choose to have your Plan and/or DRS shares electronically delivered to or
from your shareowner account. For information concerning authorization of electronic share movement, please contact your Broker/Dealer.
Market purchases & sales are posted to your account as of the settlement date. The settlement date is the date the plan administrator receives
the shares or cash proceeds from the broker. Settlement date is three business days after the purchaselsell date.
------------------------Detec"ere .- --------
Transaction Request
MERCK 0020
ANDREW S GASSAWAY
10 NARAGANSETT DR
MECHANICSBURG PA 17050-7900
? Please change my address as indicated.
•
0020400010231650050000100001
OPTIONAL CASH PURCHASE ELECTION
? Enclosed is a check made payable to Shareowner Services
for: $ CT7717-1 . m
Minimum $50.001 Maximum $50,000.00peryeer
Shareowner Services will make every effort to process your purchase
instructions upon receipt of your properly completed request which
includes account number or SSN and plan name. We will not be
liable for any claim arising out of failure to purchase shares on a
certain date or at a specific price.
Requests submitted on this form will only affect Direct Purchase
Plan shares, not shares held in DRS.
Il?il imi 0 0aii llau lull pm ilia iii/IIII Illaii ilau ilia 0 IIII
01 per 48
NORDSTROM INC
P.O. BOX 3314
SOUTH HACKENSACK, NJ 07606-1914
41000562
IMPORTANT TAX INFORMATION DATE\
ISSUE 03/15/2004
COMMON
[
. OF SHARES OWNED
120 ACCOUNT KEY
CURRENT DIVIDEND DP/IDEND PAID Y.T.D. GASSAWAY-ANDRS0000
$13.20 $13.20 Ple..e detach and retain th i. form for
TAX WITHHELD
$0.00 LAX WITHHELD Y.T.D.
$0.00 ......card.. Total dividends paid tp
yoV dming ft. telendar yur will be
reported to internal R.vend. se.vm..
* * * Fast, Smart & Easy * * *
Get your shareholder information on-line via a secured Internet site:
Information Available Transactions; Available
Account detail • Change your address
Certificate history • Consent to view proxy material on-line
Book entry history • Request certificate issued from book entry shares
Dividend check history . Request a dividend check replacement
Tax information Form 1099 . Request a duplicate Form 1099
Historical stock price information a Dividend payment election
• And more
Visit us on the web at:
www.melloninvestor.com
Click on Investor ServiceDirect "and
follow the easy instructions to establish
a PIN and you're on your way.
Or contact us at 1-800-318-7045
001-035-65566410
I...III,..Ilira..i.I.II...IeI.II.I..ll.aell......llllea.lle..i
ANDREW S GASSAWAY
10 NARAGANSETT DR
MECHANICSBUR PA 17050-7900
NAME AND ADDRESS AS IT APPEARS IN OUR RECORDS
0004213
B PNC
The PNC Financial Services Group
Computershare Trust Co., Inc.
2 North LaSalle Street
Chicago Illinois 60602
Within the US, Canada 8 Puerto Rico: 800 982 7652
Outside the US, Canada 6 Puerto Rica: 312 360 5235
Facsimile: 312 601 4335
For a change of address please call the above number.
ANDREW S GASSAWAY
13142 LAUIEN LANE
MIDLOTHIAN VA 23113-3144
PNC
IIIII IIIIII111II 111111 III IIIII IIIIIIIIII IIIIIIII1111IIIIIIIIII
Holder Account Number
C 0000295477 IND
SSKMN Certified Yes
Uncertified accounts are subject to withholding taxes
on dividend payments and sales proceeds.
The PNC Financial Services Group, Inc. - Dividend Reinvestment Plan Statement
Dear Shareholder,
If you have questions regarding your account, contact Computershare shareholder services at 1.8019-982.7652.
-?vidend Information Record Date: 14 Apr 2004 Holder Account Number:C 0000295477
Payment ( Class Description Shares/Unks Participating I Dividend I Gross I Deduction I Deduction I Net
Date in Dividend Reinvesment Rate ($1 Dividend ($',I Amount i$) Type Dividend (S)
24 Apr 2004 Common
61.110819 0.500000 30.56
30.56
Transaction History From: 01 Jan 2004 To: 26 Apr 2004
Transaction Deduction Deduction Net Price Per Total
Date I Transaction Description I
Amount ($) I
Amount ($) Type,
Amount ($) I
I
SharelUnit ($)
Shares/Units
26 Jan 2004 Dividend Reinvestment 30.28 30.28 55.125000 0.549297
26 Apr 2004 Dividend Reinvestment 30.56 30.56 52.515000 0.581929
Summary of Holdings Date: 26 Apr 2004 OOICSM-RPS.DL.MC.1355I9 4&MgS3M59831I
Certificated Shares/Units Direct Registration/ Dividend Reinvestment Closing Price Per
Held By You I Book Shares/Units I Shares/Units Total Shares/Units SharelUnit ($) I Value ($)
40.000000 0.000000 21.692748 61.692748 52.400000 3,232.70
Page 1 of3 ?J)
E"TRADE Securities LLC
10877 White Rock Road
Rancho Cordova, CA 95670
1-800-786-2575 Member NASD/SIPC
Sweep Deposit Account is a bank deposit account at an affiliate, E'TRADE Bank,
a Federal savings bank, Member FDIC. Bank deposits are FDIC-insured up to
$100,000.
Account Statement
Please refer to the Terms and Conditions link for a complete discussion of terms
and conditions governing your account.
For the account of:
ANDREW SPRINGER GASSAWAY &
JENNIFER GASSAWAY JTWROS
10 NARAGANSETT DR
MECHANICSBURG PA 17050-7900
PRINT •FRIENDLY What do ouwanttosee
VERSION Terms&_Conditions Y
Account Number For the Period
4903-2846 03-01-04 Through 03-31-04
Account Value Summarv
Description Amount
Total Account Valuation
This statement's closing equity $11,942.60
Last statement's closing equity 12,273.32
Net Change in Equity $(330.72)
Security Values not a deposit-not FDIC-insured-may lose
value
Stocks Long $ 11,182.89
Total Long Value 11,182.89
Net Market Value $11,182.89
Closing Money Balances
Sweep Deposit Account $759.71
Net Closing Money Balances $759.71
Return to Top..A
Income & Expense Summary
F ription Current Period Year to Date
1
ividends (Taxable) $ 0.00 $21.60
Express Link
¦ Monthly £
¦ Trade Cor
¦ Tax Recol
¦ Pasted Ct
d1l HOW Dt
view-KY-10101
Statement
Request Du[
hftps://www.onlinefinancialdocs.comltflfanmedia?tx=Router&cz=6180417041300&setdb... 11/16/2004
Page 2 of 3
Interest (Taxable) 0.10 0.29
Net Income $0.10 $21.89
Return to Too A
money Hct1VILy summary
Description Amount
Combined Opening Balance $759.61
Debits
Total Debits $0.00
Credits
Dividend and Interest Income 0.10
Total Credits $0.10
Combined Closing Balance $759.71
Return to TOPA
Daily Account Activity
investment ACawtynot a aeposmrn
Acct Activity/
Trade Transaction Qty
Type Date
DIVIDEND AND INTEREST
rule-msured•may lose value
Description Price Debit Credit
E'TRADE
Cash 03/31/04 Interest FINANCIAL 0.10
SWEEP DEPOSIT
ACCOUNT
SWEEP DEPOSIT ACCOUNT ACTIVITY•FDIC-Ins ured
E'TRADE
Cash 03/31/04 Reinvest Div FINANCIAL 0.10
SWEEP DEPOSIT
ACCOUNT
Sweep Deposit Account is a bank deposit account at an affiliate, E`TRADE Bank,
a Federal savings bank, Member FDIC. Bank deposits are FDIC-insured up to
$100,000.
Return to Too A
Account Positions
Qty Acct
Long Security Symbol/
(Short) Type Description CUSIP
Stocks Long
216.220 Cash BEST BUY BBY
CO INC
Mkt. Value Total Div / Estimated
Price Long Portfolio CPN Annualized
(Short) % Yield Income
51.7200 11,182.89 100.00 0.773 86.00
httns•//wwwnnIinP.finAnrlAlllnrCrnm/if/fanmPAia9ty-RnntPrR,n?-l1Rindt70A11AA.Q _+Ak 11114/lnne
Page 3 of 3
Total Security Value - Stocks Long $11,182.89 100.00 $86.00
Total Long Value $11,182.89 100.00 $86.00
RgWrI to Top A
Other Information
Current rates as of 03131104
Credit Interest Checking
$0-$2500 .00%APY
$2500+ .20%APY
Credit Interest Plus
$0-$2500 .00%APY
$2500+ .12%APY
Sweep Deposit Account
Annual Percentage Yield Earned .15%APY
Margin Interest Rates
Less than $50,000 8.99%
$50,000 to $99,999.99 7.99%
$100,000 to $249,999.99 6.99%
$250,000 and above 5.99%
Retum_to_Toa-A
E*TRADE Clearing LLC (ETC), member NYSE/NASD/SIPC, carries your account and acts as your custodian
for funds and securities deposited with us directly by you, through E*TRADE Securities or as a result of
transactions we process for your account. Any inquiry regarding positions and balances only, may be directed
to ETC at 916-864-8399. All other inquiries regarding your account or the activity therein should be directed to
E-TRADE Securities LLC.
tiome I Accounts I Investing I Banking I Lending i Plan_$.Advice ( QQntactlls I Site --- Map
Investment Products: • Not FDIC Insured • No Bank Guarantee • May Lose Value
Securities products and services offered by E*TRADE Securities, LLC (member NASD/SIPC) are not insured by the FDIC, are not guarantees
obligations of E*TRADE Bank, and are subject to investment risk, including possible loss of the principal invested.
System response and account access limes may vary due to a variety of factors, including trading volumes,
market conditions, system performance, and other factors.
Stalgment of Financial Qonl.tiQn I About. Brokerage Insurance I User Agreement 1 Privacy Statement
® 2002 E*TRADE Securities LLC. All rights reserved. Version 1.0.
https://www. onlinefinancialdoes. comltflfanmedia?tx=Router&cz=61 8041 7041 300&setdb... 11/16/2004
-=- Commerce Commerce Bank/Harrisburg N.A
100 Senate Avenue
4! Bank Camp Hill 17011
888-937-0004
JENNIFER M GASSAWAY
ANDREW S GASSAWAY
10 NARAGANSETT DRIVE
MECHANICSBURG PA 17050
Page 1 of 4 -
STATMIENT DATE
01/21/04
.0536249279
ACCOUNT NO.
ACCOUNT NUMBER 0536249279
PREVIOUS STATEMENT BALANCE AS OF 02/23/04 ... ....... ............... 2,414.79
PLUS 3 DEPOSITS AND OTHER CREDITS . ....... ............ 5,641.05
LESS 39 CHECKS AND OTHER DEBITS .... ....... ............ 6,035.71
CURRENT STATEMENT BALANCE AS OF 03/23/04 .... ....... ............... 2,020.13
NUMBER OF DAYS IN THIS STATEMENT PERIOD 29
---------------------------
*** CHECK TRANSACTIONS *** ------------------ ------- --------------- ---------------
SERIAL DATE AMOUNT SERIAL DATE AMOUNT
1896 03/10 100.00 1922 03/04 75.00
1904* 03/10 10.00 1923 03/22 26.00
1907* 02/26 13.80 1924 03/08 82.95
1912* 02/25 15.00 1925 03/10 15.00
1913 03/03 15.00 1926 03/10 10.00
1915* 03/10 10.00 1927 03/12 1,038.66
1916 03/01 25.00 1928 03/22 18.00
1917 02/27 10.98 1929 03/15 86.53
1918 03/01 18.00 1930 03/18 24.50
1919 03/02 17.75 1931 03/19 10.55
1920 03/23 38.00 1933* 03/23 15.00
1921 03/02 15.00 1940* 03/22 18.00
-------------------------------------
*** CHECKING ACCOUNT TRANSACTIONS ***
DATE DESCRIPTION
02/25 COL BILL PYMT-Edward J. Horan,
02/27 AC-CAPITAL BLUE CRO-PR PAYMENT
03/03 COL BILL PYMT-Talbots
03/08 COL BILL PYMT-Silver Spring To
03/11 COL BILL PYMT-VERIZON
03/11 COL BILL PYMT-VERIZON WIRELESS
03/11 COL BILL PYMT-Nationwide Mutua
03/12 AC-CAPITAL BLUE CRO-PR PAYMENT
03/12 DEPOSIT
03/15 COL BILL PYMT-St. Joseph's Sch
03/17 COL BILL PYMT-United Water Pen
03/17 COL BILL PYMT-Penn Waste, Inc.
03/17 COL BILL PYMT-PPL Electric Uti
03/17 COL BILL PYMT-Sam's Club/MCCBG
03/17 COL BILL PYMT-Home Depot Credi
03/17 COL BILL PYMT-St. Joseph's Sch
03/17 COL BILL PYMT-Chase PerfectCar
03/22 WTHDRL DDA 1201 03/19 15:09
5032 SIMPSON FERRY RD MECHA PA
DEBITS
75.00
51.00
119.15
75.96
81.59
309.62
2,615.61
406.00
730.00
28.37
36.70
270.76
348.86
350.00
730.00
1,059.98
60.00
CREDITS
2,619.44
---------------
*** BALANCE BY -------------
DATE *** ------------ --------- ------------- --------- ------------
02/23 2,414 .79 02/25 2,324.79 02/26 2,310.99 02/27 4
919.45
03/01 4,876 .45 03/02 4,843.70 03/03 4,777.70 03/04 ,
4,702.70
03/08 4,500 .60 03/10 4,355.60 03/11 3,888.43 03/12 5,871.38
03/15 5,054 .85 03/17 2,230.18 03/18 2,205.68 03/19 2,195.13
03/22 2,073 .13 03/23 2,020.13
~ m
N
?
h b h
? N
r N
m w ,n g
p, r ? m
p C m ?
1) O L
A O
'
13 ?
1%1 W
U
C > 41'
C N
Q 7
V u ?
`? ?
fJ " ? °
Q Q
LL 1-
O
N Z =
G
d co rn N
z
t0 co R ` o °
- O
Q J
U
r 0
U
? 1 m a >
y J o
w? U N W ° c
?e^ e6 m?z?Z$n
C
'
i.?
i o
Y
W
Gp?C c IMp.-m E
2"
cfd mfg u zmm
a
°
gHo
Nq
u.1 >0>
I0
`a
O
6.
U
x
yH
V L
0
4
N
r
0
O
LL Q
o Ir
m 1
O C3
0
N
oKGa
o R W =
nOZm
oa.qU
nW. t9-
40 juq
40 j ¢ Q
ch ZZW
O
O n ' e"
g
S
3.
m
K
Ti
m r,
N R m
9
O N
? ; L N
cm r
W .L.m L
j
W O
« « m
o N ?
? m c ? m
Cq
G ? N ' c
v 6
Y C
W W N
O ?
? m d
OW Y
U a ?
Y m 9
E - .r
u a d {w?
> C LW
O
C U ? ?
W O j C
O Y N
V
Z E
?
?
W J
W
Tumiu ?2
m
c v a .z u
CN r
mW W -. S
C
L Y
E?tO
O1 m$
d w o
rn«U
m m o
w WT;
m ? al
?5 0
o-
c W 'm 0
n m m "o
sE= a
16
G Y
W O ?
? W
a 0 L
Z 0,..
1+1 ? O
NU'
_ zVE
nvE
m 5 W
E 3 ?
cam- c
m ? m
?_ Y pi v
r
o m c
a W m
0 0
Ci w U
n
E E
°v
O 2
O
O N
T
Ot
j 9
3 . N
Q 0
? m
R n
Ao
E c
W
C Y
W
W
C O
N m0
W > >
c O n
t
` Y 9 6?
o
ro a
n n m_ c
? ? rno
c 'p t=
rB S aa7
yoy?b
r
M
W
1 W ':
•iY E
Y Y ::
? m o
f
u
r
MM
r
r
r
March 31, 2004, year-to-date Page 1 of 4
PORTFOLIO SUMMARY
THE?d11?Ud/CIGItfJU1;
ANDREW S GASSAWAY 8 Statement number: 001757538
JENNIFER M GASSAWAY (800) 662-2739 - Client Services
JT TEN WROS www.vanguard.com Website
10 NARAGANSETT OR
MECHANICSBURG PA 17050-7900 (800) 662-6273 - I ele-Account
°
TOTAL OF ALL ACCOUNTS
Value on 12/31/2003 Value on 3/31/2004
$ 10.144.83 $ 10,568.38
INVESTMENT ACCOUNTS CUSIP llcker Value on 12/3112003 Valueon3/31/2004
GNMA Fund Investor Shares 922031-30-7 VFIX $ 1,860.32 $ 1,889.82
Windsor II Fund Inv 922016-20-5 VWNFX 8,284611 8,678.56
Total investment accounts
$ 10,144.83 $ 10,568.38
Income year-lo-date $ 22.41 Portfolio allocation
Short-term investments 0.0%
Bonds 17.9
Stocks 82.1
100.0%
GET 50% OFF THE TURBOTAX FOR THE WEB SERVICE
Filing your income taxes doesn't have to be complicated or expensive. Starting in mid-January, all versions of
the TurboTax for the Web service will be available at 50% off federal filings for Vanguard clients who are
registered users of Vanguard.com. To get your discount--and your Vanguard tax and account statements--go to
vrww.vanguard.com/visit/taxcenter.
Vanguard and Vanguard.com are trademarks of The Vanguard Group, Inc. TurboTax for the Web is a service mark
and I urboTax is a registered trademark of Intuit Inc., and used with permission.
167221
1- 4
1894 1048 D1 9 X._
IINIIIIIIIIIII1IIIIIIIIIII1IIIIIIIIIIIIIIIIIIIIIIIIIIIIII111IIIIIIIIIIIIII
Commerce
IffBank
JEhrNIFER M GASSAWAY
ANDREA S GASSAWAY ---
10 NARAGANSETT DR.IVEE
MECHANICSBURG PA 17050
STATEMENT DAT!
03/'31/05
0626187678
ACCOUNT NO.
*** SAVINGS *** PREMIER SAVI*TGS BEGINNING RATE 0.99500
ACCOUNT NUMBER 0526187678
PREVIOUS STATEMENT BALANCE AS OF 02/28/05 ........................ 5,424.59
PLUS 1 DEPOSITS AND OTHER CREDITS 4.58
LESS 0 WITHDRAWALS AND OTHER DEBITS ................ .00
CARR.E'NT STATEMENT BALANCE AS OF 03/31/05 ......................... 5,429.17
NUMBER OF DAYS IN THIS STATEMENT PERIOD 31
----------------------------------------- -----
*** SAVINGS ACCOUNT 'T'RANSACTIONS ***
DATE DESCRIPTION DEBITS CREDITS
03/31 INTEREST_ PAYMENT 4.58
----.------------------------ '- - -------.1---------------------------.----------------
*** BALANCE BY DATE ***
02/28 5,424.59 03/31 5,429.17
PAYER FEDERAL ID MUMBER 23-2324730
INTEREST PAID YEAR TO DALE 13.30
------- --'---------.-----------
*** INTEREST EARNED THIS STATEMENT PERIOD ***
DAYS IN PERIOD 31
INTEREST EARNED 4.58
ANNUAL PERCENTAGE YIELD EARNED (APY).... 1.0096
- -- - -- - - - - - - - - - - - - - - - - - - - - - ---- - - - - - - - - - - -
'Commerce
Bank
ANDREW S GASSAWAY
10 NARAGANSETT DRIVE
MECHANICSBURG PA 17050
Commerce Bank/Harrisburg N.A.
100 Senate Avenue
Camp Hill, PA 17011
888-937-0004
STATEMENT DATE
03/31/04
1 0626407753
ACCOUhrr NO.
CYCLE-052
?Bl
*** SAVINGS *** PREMIER SAVINGS BEGINNING RATE 0.99500
ACCOUNT NUMBER 0626407753
PREVIOUS STATEMENT BALANCE AS OF 03128104 .00
PLUS 2 DEPOSITS AND OTHER CREDITS ................... 11,000.90
LESS 0 WITHDRAWALS AND OTHER DEBITS ................ .00
CURRENT STATEMENT BALANCE AS OF 03/31/04 ......................... 11,000.90
NUMBER OF DAYS IN THIS STATEMENT PERIOD 3
------------------------------------------------------------------------------------
*** SAVINGS ACCOUNT TRANSACTIONS ***
DATE DESCRIPTION DEBITS CREDITS
03/29 DEPOSIT 11,000.00
03/31 INTEREST PAYMENT .90
-----------------------------------------------------------------------------------
*** BALANCE BY DATE ***
03/28 .00 03/29 11,000.00 03/31 11,1000.90
PAYER FEDERAL ID NUMBER 23-2324730
INTEREST PAID YEAR TO DATE .90
----------------------------------------------------
*** INTEREST EARNED THIS STATEMENT PERIOD ***
DAYS IN PERIOD ......................... 3
INTEREST EARNED ........................ .90
ANNUAL PERCENTAGE YIELD EARNED (APY).... 1.008
----------------------------------------------------
MnTF• ece ecucooe cane vno wonerw a+mvneuwr,nu
CGM MUTUAL FUND
P.O. BOX 8511
BOSTON, MA 02266
Itttllltttll It,tlltltlllttltttllllttlltttllttttttlllltttlltttl
TTEEEFORRTHE IRAKOF TRUST CO
ANDREW S GASSAWAY
10 NARAGANSETT DR
MECHANICSBURG PA 17050-7900
CONFIRMATION 04/29/2004
The C(GM Inds
lQ LL
I Fund Ne. Account No.
I
Chk 091 State Street
ust
15.n and
k
QUESTIONS? CALL 1-800-343-5678 45 46233901 Trustee
8 Co.,
Confirm
Date _ Trade
Date Transaction Dollar Amount
of Transaction Share
Price Shares This
Transaction o a
Shares Owned
BEGINNING BALANCE 1,162.780
5/06 4/29 INCOME REINVEST 0.08 93.02 22.02 4.224 1,167.004
U
Dividends and Cap. Gains 93.02 Total Shares Held 1,167.004
2004 Contributions 2003 Contributions
Account Value: 1,167.004 Shares at $22.02 = $25,697.413
Primary JENNIFER M GASSAWAY Secondary NICHOLAS A GASSAWAY
Beneficiary Beneficiary
Pri. Benef. Birthdate
Sec. Benef. Birthdate
Participant Birthdate 08/08/1962
CGM MUTUAL FUND
STATE STREET BANK & TRUST CO
TTEE FOR THE IRA OF
ANDREW S GASSAWAY
10 NARAGANSETT DR
MECHANICSBURG PA 17050-7900
To Invest By Mail
Please make your check payable
to State Street Bank and Trust
Company. A return envelope is
enclosed tot your convenience.
ADDITIONAL INVESTMENT STUB
Fund No. Account No. Chk 09t
35 46233901 8
Rollover
STATE STREET BANK 8
TRUST COMPANY
P.O. BOX 8511
BOSTON, MA 02266
lll,tttdl6t61tllttillllll,111
S
2004 SHAREOWNER
CONTRIBUTION $
Total $ 'a "I
(Minimum Amount $50.00)
I?>?I??IVIII?III?IIIIIIIWI ?aU??
{} 0 12532510 000462339018 0000035
January - March 2004
T.RowePrice Wkiii
Statement Summary INVEST WITH CONFIDENCE
If you have questions please visit troweprice.com or call Investor Number 322679
owe Price Mutual Funds at 1-800-225-5132.
I Mutual Fund Portfolio Value: $60,671.12
Act now to beat the April 15, 2004, deadline to fund an IRA for
tax year 2003. The maximum contribution for Traditional and
Roth IRAs is $3,000 ($3,500 for investors 50 years or older).
Visit troweprice.com/ira or call 1-800-225-5132.
This Quarter Year-to-Date*
Beginning Value
............................................... $58,953.06
....................................... .... $58,953.06
.........
Additions 0.00 0.00
....
.
.
..
_............................ ................
Deductions ................__......................
0.00 ............._.....
.
.
.
0.00
..............................
.....................................
Income ..........................................
0.00 .
0.00
.....................
.
.
_ ................. ..........................
Market Fluctuation .............. ............................
...................
1,718.06 ..
.....
..
.
1,718.06
Ending Value -$60,671.12 $60,671.12
Qt Change $1,718.06 $1,718.06
*year-to-date income may include closed accounts no longer shown
on this statement.
#BWNDXKF
102862901 AT AUTO T10285017060-790010-1 Mt
llllllllll'11111111111111111111'VIII VIII II Il IIrlll ll llll lllll
T. Rowe Price Trust Co.
Cust For The IRA Of
Andrew 5 Gassaway
10 Naragansett Dr
Mechanicsburg PA 17050-7900
12131103 .3131104 Change % of
Retirement Value Value in Value Assets
T Rowe Price Mutual Funds
Capital Appreciation $58,953.06 $60,671.12 $1,718.06 100.0%
Total Market Value $58,953.06 $60,671.12 $1,718.06 100.0%
•
Page 1 of 2
January - March 2004
Mutual Fund Statement
T.RowePlrice
INVEST WITH CONFIDENCE
•
' •' ''' Account Number 400546359-6
T. Rowe Price Trust Co.
Cust For The IRA Of
Andrew S Gassaway
Tele*Access Code Date Activity This Quarter Amount Shares Share Price
38 1/1 Beginning Balance $55,164.94 3,152.282 $17.50
Ticker Symbol 3/31 Ending Balance $56,772.60 3,152.282 $18.01
PRWCX
There was no activity this period.
' •' ''' ' Account Number 522418417-6
T Rowe Price Trust Co
Cust IFor The Rollover IRA Of
Andrew 5 Gassaway
Tele*Access Code Date
Ocker Symbol
PRWCX
1/1
3/31
Activity This Quarter
Beginning Balance
Ending Balance
Amount
$3,788.12
$3,898.52
Shares
216.464
216.464
Share Price
$17.50
$18.01
There was no activity this period.
•
Page 2 of 2
o?(Q
O Ra
1u°
m
G
m
m
Y
F m
O'?
4 N
m
?r 3
.v rn
pu4.U
`Z
?F
N
tn
W
P
to
r.
'#J'
w
6
v
N
H
Z
`L
C'.)
Q
4
W
C]
LL
r_
r
Q
N
Q
?C
F xQ.
U-
ti O
ZN
Wv
8 s
o
4 r
N?
5 U Z
IWJ^-QQ?
Z Z W
O ?
I
r °
? O
N ?
r
I?N
m
0
s r-
3 ?
r-
C.
m
c
m
d
oZ
e ° o
d t?+f,
O N lT2
-?
3 {}
Y 6 '?
Ta?
(F
1
t~ ?
I? r
c
Oro
O
'a
s
W6
It
K
N
N ?
M N
? w
ce)
° o
I
? a
0
T
c
m
v
a
m
3
N t
. r 3
D ?
V ?
r
di
m
N
L
O
O 0
a ^ m 3
}
o
m 'O
T m r
m R `tq
LL y
° m O
m
m
? ? c m
r' ? m 6f
LES
IO .m y G
CD V W
? LL ? m
m °g
3 ?
YI
Y ?
3 m
r
?
m ?
r NW o c
8 t.
O
0 °? A
94
a U "? w
Y ° H 1'AC
U
g "' w o ` LL F
,
one
m
Y
8
i
THManguardcRoue
JENNIFER M GASSAWAY
10 NARAGANSETT DR
MECHANICSBURG PA 17050-7900
June 30, 2004, year-to-date Page 1 of 1
TRANSACTION DETAIL
Statement number: 0105756852
(800) 662-2739 - Client Services
www.vanguard.com Website
q (800) 662-6273 - Tele-Account
Illllllrrrlllllrrlrllllrlllrrllllllllllrrlllrlllrllllrrlllr111
TDANSACTION ACTIVITY
Vanguard STAR Fund (IRA) Fund / Account no. 0056 / 09891266106
Trade date Transaction description Dollar amount Share price Shares transacted Total stares owned
Balance on 12/31/2003
6/25 Income dividend .18
Balance on 6/30/2004
$ 22,343.47 $17'20 1,299.039
233.83 171.53 13.339 1,312.378
$ 23,084.73 $17'.59 1,312.378
Year-lo-date Short-term gains / ConuAwtions & Distr ibution
Income dividends Long-term gains Distributions Year and type payable date
$ 233.83 $ 0.00 $ 0.00 2004 contributions
0.00 0.00 2003 contributions
0.00 2004 distributions
10
6/28/2004
Fund J Account no.
VANGUARD STAR FUND 0056 / 09891266106
*Do not after this Invest-By-Mail slip.
Wisil www.vanquard.com or call to change your address.
2004 Tax year contribution $ 0 x 0 0 0 .0
2004 Rollover $ 1:1 t1:11:1 ?)???.?R
2004 Custodial fee waived $ R X . DR] FRI
Total amount $ ?1???1???.??
VFTC - CUSTODIAN IRA
JENNIFER M GASSAWAY
Make checks payable to: The Vanguard Fiduciary Trust Company - 0056
THE VANGUARD GROUP
PO BOX 7800
PHILADELPHIA PA 19101-9892
1111111/1/ go go 11llllnu116611rrtdr l,1„61111111
00561 09891266106 259 1- 1
091974 1992 104B M1 10)(
-44;
T tHhultguaudcROUR
JENNIFER M GASSAWAY
10 NARAGANSETT DR
MECHANICSBURG PA 17050-7900
March 31, 2004, year-to-date Page 1 of 1 (a 1
TRANSAC`T'ION DETAIL 11((
Statement number: 018323706
(800) 662-2739 - Client Services
w
www.vanguard.com Website
w
2 (800) 662-6273 - Tele-Account
I?rrlllrrrlilrrrrlrlrllr,rlrrrlirl,rllrrrllrrrrrrllllrr,llr,rl
TRANSACTION ACTIVITY
Vanguard Windsor 11 Fund Investor Shares (Roth IRA) Fund / Account no. 0073 / 09964432618
Trade date Transaction descripton Dollar amount Share price Shares transacted Total shares owned
Balance on 12/31/2003
Balance on 3/31/2004
$2,627.W-
$2.752.06 $ ;17.75
99.173
99.173
Year-to-date Shat-term gains / Contritwtions & Distriwtlon
Income dirWends long-term gains Distributions Year and type
payable date
$ 0.00 $ 0.00 $ 0.00 2004 contributions N/A
0.00 0.00 2003 contributions
0.00 2004 distributions
Nationwide Insurance
Nationwide Financial
PO Box 182835
Columbus OH 43218-2835
ANNIVERSARY NOTICE
LI
Policy Number
L030496310
Total Amount Due
$0.00
ANDREW GASSAWAY
13142 LAUREN LANE
MIDLOTHIAN, VA 23113
Date Prepared
APR 16, 2002
(o
a
°o
0
0
m
m
S
0
N
w
See back of this notice for important phone numbers and other information about your insurance.
Current dividend option: accumulate dividend at interest
Current anniversary dividends and their distribution are earned and available when:
1. The anniversary date is reached and
2. Premiums are paid to the anniversary date.
Current anniversary dividend .................................................................................................. $19.37
Anniversary Interest on previously accumulated dividends ..................................................... $1.72
Total accumulated dividends and interest .............................................................................. $48.57
Total Due This Statement
............................................................... $0.00
RETAIN THIS PORTION FOR YOUR RECORDS
XLBF02A RETURN THIS PORTION VVITH PAYMENT 00386051 8 N00
ANDREW GASSAWAY LIFE CUSTOMER NOTICE
13142 LAUREN LANE
COMES MIDLOTHIAN, VA 23113 7-
Total Amount Due j
IIIIIIIIER
$0.00
? INSURED: ANDREW GASSAWAY
? OWNER: ANDREW GASSAWAY Pali ccyy Number I
L030496310 I
For Policy Information
or Changes, Call: NATIONWIDE LIFE INSURANCE COMPANY
1-800-547-2280 PO BOX 742534
CINCINNATI OH 45274-2534
N
N
8
0
0
0
0
m
0
0
m
N
R
r--
r
Nationwide Insurance
Nationwide Financial
PO Box 182835
Columbus OH 43218.2835
ANNIVERSARY NOTICE
LIFE
Policy Number
L032802300
Date Prepared
JUL 10, 2002
Total Amount Due
$0.00
ANDREW GASSAWAY
13142 LAUREN LANE
MIDLOTHIAN, VA 23113
See back of this notice for important phone numbers and other information about your insurance.
Current dividend option: use dividends to purchase paid-up additional insurance
Current anniversary dividend .................................................................................................. $8.26
Total anniversary paid-up additional insurance ....................................................................... $46.16
Total Due This Statement ........................................................................................
RETAIN THIS PORTION FOR YOUR RECORDS -
XLBF02A
ANDREW GASSAWAY
13142 LAUREN LANE
MIDLOTHIAN, VA 23113
RETURN THIS PORTIOr'! WV T H PAYMENT 00665709 6
LIFE CUSTOMER IVOTICE
Total Amount Due
$0.00
INSURED: ANDREW GASSAWAY
OWNER: ANDREW GASSAWAY
For Policy Information
or Changes, Call:
ALFRED M. TRANOUILLO
610-372-2771
Policy Number
L032802300
N00
I?I?rlrirl???l?lln??Irlrrlrrl?l?lrlrrrll??lrrl„II„I??II???II
NATIONWIDE LIFE INSURANCE COMPANY
PO BOX 742534
CINCINNATI OH 45274-2534
......... $0.00
(v)
?i`1639050015
LIFE-CUSTOMER-NO
j
Policy Number
L032802290
Nationwide. Insurance
Nationwide Financial
PO Box 182835
Columbus OH 43218-2835
ANNIVERSARY NOTICE
Date Prepared
JUL 30, 2004
Total Amount Due
$0.00
JENNIFER M GASSAWAY
13142 LAUREN LANE
MIDLOTHIAN, VA 23113
N
0
0
N
O
D
m
O
O
O
N
See back of this notice for important phone numbers and other information about your insurance.
Current dividend option: use dividends to purchase paid-up additional Insurance
Current anniversary paid-up ............................................ __.... ___.................................. $16.65
Total anniversary aid-up additional insurance ....................................................................... $291.74
(,Jj)
Total Due This Statement.... ........ ___ .................................................................................. $0.00
RETAIN THIS PORTION FOR "OUR RE CORDS --
THIS p ? 00660121 6 N00
` XLBF02A - - - - RETURN THIS PORTION iN li y F? ?YI,A,ENTI
JENNIFER MGASSAWAV LIFE CUSTOMER NOTICE
13142 LAUREN LANE
MIDLOTHIAN, VA 23113 --"--
I
r Total Amount Due
i? $0.00
i INSURED: JENNIFER M GASSAWAY
Nam OWNER: JENNIFER M GASSAWAY ` Policy Number
1_032802290
For Policy Information Irlrrirl l,r l ll?rrlrl,rlrrlrirlrl.rrll?rlrrl„Ilr?lr,ll„rll
or Changes, Call:
ALFRED M TRANQUILLO POTBOXW7442534FE INSURANCE COMPANY
610-372-2771 CINCINNATI OH 45274-2534
? r
NON-MARITAL PROPERTY (J I A
DEFENDANT lists all property in which a spouse has a legal or equitable interest which is claimed to be excluded from
marital property:
ITEM NUMBER ITEM NUMBER ITEM NUMBER
DESCRIPTION
OFPROPERTY
NAMES OF
ALL OWNERS
DATE OF
ACQUISITION
COST OR VALUE
AS OF DATE OF
ACQUISITION
VALUE AS OF
DATE ACTION
COMMENCED
AMOUNT OF ANY
LIEN
NATURE OF ANY
LIEN
HOLDER OF LIEN
EFFECTIVE DATE
OF LIEN
BASIS FOR
EXCLUSION
FROM MARITAL
PROPERTY
ITEM NUMBER ITEM NUMBER ITEM NUMBER
DESCRIPTION
OF PROPERTY
NAMES OF
ALL OWNERS
DATE OF
AC UISTTION
COST OR VALUE
AS OF DATE OF
ACQUISITION
VALUE AS OF
DATE ACTION
COMMENCED
AMOUNT OF ANY
LIEN
NATURE OF ANY
LIEN
HOLDER OF LIEN
EFFECTIVE DATE
OF LIEN
BASIS FOR
EXCLUSION
FROM MARITAL
PROPERTY
PROPERTY TRANSFERRED
(Defendant) lists all property in which either or both spouses had a legal or equitable interest individually or with any other
person and which has been transferred within the preceding three years.
ITEM NUMBER ITEM NUMBER ITEM Ni NMER
DESCRIPTION
I k'? n Acc„
199 -1
OFPROPERTY
NAMES OF
ALL OWNERS +U A A ew
DATE OF
ACQUISITION
DATE OF 4
TRANSFER
COST OR VALUE
cf'
AS OF DATE
ACTION
ACQUISITION
VALUE AS OF
OF
DATE
TRANSFER
AMOI JNT OF ANY
LIEN AS DATE OF
TRANSFER
NATURE OF ANY
LIEN AS DATE OF
TRANSFER
EFFECTIVE DATE
OF LIEN
HOLDER OF LIEN
LIABILITIES OF PARTIES
(Defendant) marks on the list below those items applicable to the case at bar and itemizes the liabilities on the following
pages.
Secured
)L Mortgages
( ) 2. Judgments
( ) 3. Liens
{ ) 4. Other secured liabilities
Unsecured
)5, Credit card balances
)6, Purchases
) 7. Loan payments
) 8. Notes payable
) 9. Other unsecured liabilities
Contingent or Defected
) 10. Contracts or Agreements
) 11, promissory Notes
) 12. Lawsuits
) 13. Options
) 14. Taxes
) 15. Other contingent or deferred liabilities
LIABILITIES
DEFENDANT lists all liabilities of either or both spouses alone or with any person as of the date this action was
commenced:
ITEM NUMBER I ITEM NUMBER ITEM NUMBER
DESCRIPTION ° n; 11L 3
OF LIABILITY Me ha«: s t dA 7c,
NAMES OF p +c
ALL
CREDITORS/DEBT
ORS
DATE s_ x•?3
LIABILITY
INCURRED
AMOUNT OF
LIABILITY ON
DATE INCURRED 1,5 4s3. °
& ACTION WAS
A?
COMMENCED
DATE BALANCE S I;2 0 3 3
IS DUE
PERIODIC
PAYMENT AND Y
AMOUNT
, r A .
ITEM NUMBER ITEM NUMBER ITEM NUMBER
DESCRIPTION
OF LIABILITY
NAMES OF
ALL
CREDITORS/DEBT
ORS
DATE
LIABILITY
INCURRED
AMOUNT OF
LIABILITY ON
DATE INCURRED
& ACTION WAS
COMMENCED
DATEBALANCE
IS DUE
PERIODIC
PAYMENT AND
AMOUNT
IZ-'- o 6
Date
Respectfully submitted,
TURD LAW OFFICES
Galen R. Waltz, Esq
28 South Pitt Str
Carlisle, PA 17
(717) 245-9688
Attorney for DEFENDANT
r. >
`
? _ -„
'
.,
r ., :<
c
Andrew S. Gassaway,
Respondent, Plaintiff
V.
Jennifer M. Gassaway,
Petitioner, Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-867 CIVIL TERM
ACTION IN DIVORCE
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY OF SAID COURT:
Please enter the appearance of Maria P. Cognetti, Esquire, on behalf of the Plaintifft in
the above-captioned case.
11 3c-)) o..
Date
Respectfully Submitted,
Maria P. Qognett)qu
Cognetti & Associates
210 Grandview Avenue
Suite 102
Camp Hill, PA 17011
PRAECIPE TO WITHDRAWAL
TO THE PROTHONOTARY:
Please withdraw my appearance in the above-captioned matter on behalf of the
Defendant.
D to
Respectfully Submitted
TURO LAW OFFICES
,Galen R. Wa]JzrEsqui
28 South Pitt Streets
Carlisle, PA 17013
(717) 245-9688
Attorney for Defendant
N
him
t) = -
3 l.:
i
-y
ur
?
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND SS:
ANDREW S. GASSAWAY,
Plaintiff
V.
JENNIFER M. GASSAWAY,
Defendant
NO. 05-867 Civil Term
CIVIL ACTION -LAW
IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
claims:
Jennifer M. Gassaway, Defendant, moves the court to appoint a master with respect to the following
(X) Divorce
( ) Annulment
( ) Alimony
( ) Alimony Pendente Lite
(X) Distribution of Property
( ) Support
( ) Counsel Fees
( ) Costs and Expenses
and in support of the motion states:
1. Discovery is complete as to the claims for which the appointment of a master is requested.
2. The non-moving party has appeared in the action through his attorney, William L. Grubb, Esquire.
3. The statutory ground(s) for divorce are: 23 Pa. C.S.A. Sec. 3301(c).
4. Check the applicable paragraph(s):
( ) The action is not contested.
( ) An agreement has been reached with respect to the following claims:
(X) The action is contested with respect to the following claim: division of property.
5. The action does not involve complex issues of law or fact.
6. The hearing is expected to take one (1) day.
7. Additional information, if any, relevant to the motion: none.
Date: Q la
MARIA P. C GN , ESQUIRE
Attorney for Defend
AND NOW, . 2006, Esquire, is appointed master
with respect to the following claims: divorce and distribution of property.
BY THE COURT:
J.
e
1 `? t
T , ?.t
MARIA P. COGNETTI & ASSOCIATES
MARIA P. COGNETTI, ESQUIRE
Attorney I.D. No. 27914
210 Grandview Avenue, Suite 102
Camp Hill, PA 17011
Telephone No. (717) 909-4060
Attorney for Defendant
ANDREW S. GASSAWAY, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
JENNIFER M. GASSAWAY,
Defendant
: NO. 05-867 Civil Term
CIVIL ACTION - LAW
IN DIVORCE
AMENDED INVENTORY AND APPRAISEMENT
OF
DEFENDANT. JENNIFER M. GASSAWAY
Defendant, Jennifer M. Gassaway, files the following Amended Inventory and
Appraisement of all property owned or possessed by either party at the date of separation and all
property transferred within the preceding three years.
Respectfully Submitted:
MARIA P. COGNETTI & ASSOCIATES
Date: /D ,? 5 1t?,6 By: 4VzA )??
MARIA P. O TTI, ESQUIRE
Attorney I.D. No. 914
210 Grandview Avenue, Suite 102
Camp Hill, PA 17011
Telephone No. (717) 909-4060
Attorney for Defendant
ASSETS OF PARTIES
Defendant marks on the list below those items applicable to the case at bar and itemize the
assets on the following pages.
(X) 1. Real property
(X) 2. Motor vehicles
(X) 3. Stocks, bonds, securities and options
( ) 4. Certificates of deposit
(X) 5. Checking accounts, cash
(X) 6. Savings accounts, money market and savings certificates
( ) 7. Contents of safe deposit boxes
( ) 8. Trusts
(X) 9. Life insurance policies (indicate face value, cash surrender value and current
beneficiaries)
( ) 10. Annuities
(X) 11. Gifts
( ) 12. Inheritances
( ) 13. Patents, copyrights, inventions, royalties
( ) 14. Personal property outside the home
( ) 15. Business (list all owners, including percentage of ownership, and officer/director
positions held by a party with company)
( ) 16. Employment termination benefits-severance pay, worker's compensation
claim/award
( ) 17. Profit sharing plans
( ) 18. Pension plans (indicate employee contribution and date plan vests)
(X) 19. Retirement plans, Individual Retirement Accounts
( ) 20. Disability payments
( ) 21. Litigation claims (matured and unmatured)
( ) 22. Military/VA benefits
( ) 23. Education benefits
( ) 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)
(X) 26. Other
MARITAL PROPERTY
Defendant lists all marital property in which either or both spouses have a legal or
equitable interest individually or with any other person as of the date this action was commenced:
Item
Number Description of Property Name of All Owners
1 10 Naragansett Dr., Mechanicsburg, PA Husband and Wife
3 Agere Systems Stock Husband
3 Avaya Stock (33 shares) Husband
3 CarMax Stock (31 shares) Wife
3 Circuit City Stock (100 shares) Wife
3 Crown Crafts Stock (52 shares) Husband
3 Daimler Chrysler Stock (85 shares) Husband
3 IBM Stock (8 shares) Husband
3 Intel Stock (365.661793 shares) Husband
3 Johnson & Johnson Stock (152 shares) Husband
3 Lucent Stock (400 shares) Husband
3 May Co. Stock (131 shares) Husband
3 Medco Health Solutions Stock (12 shares) Husband
3 Merck Stock (100 shares) Husband
3 Merck Stock (79.277 shares) Husband
3 Nordstrom Stock (120 shares) Husband
3 Pepsico Stock (30 shares) Husband
3 PNC Financial Stock (61.692748 shares) Husband
3 Tricon Stock (12 shares) Husband
3 Walmart Stock Husband
3 Etrade Account #6658-7663 Husband and Wife
5 Commerce Bank Checking #536249279 Husband and Wife
3
6 Commerce Bank Savings # 626407753 Husband
6 Commerce Bank Savings #626187678 Husband and Wife
6 Vanguard GNMA #36-9874439510 Husband and Wife
6 Vanguard Windsor H #73-9874439510 Husband and Wife
6 Solomon Smith Barney #739-01718-12 687
(Marital portion) Wife
9 Nationwide Life Insurance #L030496310 Husband
9 Nationwide Life Insurance #L032802300 Husband
9 Nationwide Life Insurance #L032802290 Wife
19 CGM #35-46233901 Husband
19 T Rowe Price #400546359-6 Husband
19 Vanguard Windsor II Roth IRA #9964470094 Husband
19 Vanguard Windsor II Roth IRA #9964432618 Wife
19 Vanguard Star #56-9891266106 Wife
19 Fidelity #2AB -367281 Wife
25 Household goods and personalty Husband and Wife
26 Life Insurance payments for Husband Wife
26 Auto Insurance payments for Husband Wife
NON-MARITAL PROPERTY
Defendant lists all property in which a spouse has a legal or equitable interest which
is claimed to be excluded from marital property:
Item Description of Property Reason for Exclusion
Number
6 Commerce Savings #626188635 Post-separation
19 Solomon Smith Barney #739-01718-12 687 Gift from Mother
F
(Non-marital portion)
PROPERTY TRANSFERRED
Item Description of Date of Person to Consideration
Number Property Transfer Whom
Transferred
2 1997 Honda Accord Unknown Car Dealer Unknown
2 1997 Chevy Suburban September 2004 Car Dealer $4,000.00
LIABILITIES
Description of Property Names of All Creditors Names of All Debtors
Mortgage on Marital Home Wells Fargo Husband and Wife
Credit Card Chase Husband and Wife
Credit Card First USA Husband and Wife
VERIFICATION
I, Jennifer M. Gassaway, hereby verify and state that the facts set forth in the foregoing
document are true and correct to the best of my information, knowledge and belief. I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to
unsworn verification to authorities.
Date: ! L ??+ ?, a a?a•
t Je fifer . Gassaway
"> a i-s l
`°_1
..?
a.
OCT So cuuo
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND SS:
ANDREW S. GASSAWAY,
Plaintiff
V.
JENNIFER M. GASSAWAY,
Defendant
NO. 05-867 Civil Term
CIVIL ACTION - LAW
IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
Jennifer M. Gassaway, Defendant, moves the court to appoint a master with respect to the following
claims:
(X) Divorce (X) Distribution of Property
( ) Annulment ( ) Support
( ) Alimony ( ) Counsel Fees
( ) Alimony Pendente Lite ( ) Costs and Expenses
and in support of the motion states:
1. Discovery is complete as to the claims for which the appointment of a master is requested.
2. The non-moving party has appeared in the action through his attorney, William L. Grubb, Esquire.
3. The statutory ground(s) for divorce are: 23 Pa. C.S.A. Sec. 3301(c).
4. Check the applicable paragraph(s):
( ) The action is not contested.
( ) An agreement has been reached with respect to the following claims:
(X) The action is contested with respect to the following claim: division of property.
5. The action does not involve complex issues of law or fact.
6. The hearing is expected to take one (1) day.
7. Additional information, if any, relevant to the motion: none.
Date: l Q a S- 0'67
MARIA P. COGNV 1'l i, ESQUIRE
Attorney for DefendinV
r
1 7-Z-1
AND NOW,?tZITY44AA' , 2006, L T el?' Ksquire, is appointed master
with respect to the following claims: divorce and distribution of property.
0
BY COUR
WNCAX!
J.
C7)
CL-
SJJL?_ ? _ r .-Y ?t
E3? ,ins ., ? ?r^
PA
ANDREW S. GASSAWAY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff I : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 05-0867 CIVIL TERM
JENNIFER M. GASSAWAY,
Defendant : IN LAW - DIVORCE
AMENDED
INVENTPRY AND APPRAISEMENT
OF
ANDREW'S. GASSAWAY, PLAINTIFF
Plaintiff files the following inventory of all property owned or possessed by either
party at the time this action was cmmenced and all property transferred within the
preceding three years.
Plaintiff verifies that the statements made in this inventory are true and correct.
Plaintiff understands that false stakements herein are made subject to the
penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities.
ASSETS OF THE PARTIES
Plaintiff marks on the list below those items applicable to the case at bar and
itemizes the assets on the following pages.
(X) 1. Real property
(X) 2. Motor vehicles
(X) 3. Stocks, bonds, securities and options
( ) 4. Certificates of deposit
(X) 5. Checking accounts, cash
( X) 6. Savings accounts, money market and savings certificates
( ) 7. Contents of safe deposit boxes
( ) 8. Trusts
( ) 9. Life insurance policies (indicate face value, cash surrender value
and current beneficiaries)
() 10. Annuities
() 11. Gifts
() 12. Inheritances
() 13. Patents, copyrights, inventilons, royalties
( ) 14. Personal property outside the home
( ) 15. Business (list all owners, including percentage of ownership, and
officer/director positions held by a party with company)
( ) 16. Employment termination benefits--severance pay, worker's
compensation claim/award
( ) 17. Profit sharing plans
( ) 18. Pension plans (indicate em loyee contribution and date plan vests)
( X) 19. Retirement plans, Indivi ual Retirement Accounts
( ) 20. Disability payments
i
( ) 21. Litigation claims (matured and unmatured)
( ) 22. MilitaryN.A. benefits
( ) 23. Education benefits
( ) 24. Debts due, including loans, mortgages held
( X) 25. Household furnishings ad personalty (include as a total category
and attach itemized list if distribu ion of such assets is in dispute)
(X) 26. Other (see attached list)
C
tt7 r
A ?
V
A
to O
R4
O
O
z
T
16
3
N
N
W
d
L
C
a
T
'O
m
tom.
C
d
d
a
a
Q
C
R
O
w
c
m
c
n
O
0
N
N
0
W
Lo
W
ix
y O
to
(D QD
r W
- V
t O
N O
M r
a 1n 1t1 t(y M
Lf CD
D V
r
V
'
n
M
M
O
t
o t
(D E R g )
N t
V O)
O
fo M t` t+ r V N N r N
? N
y
3
d1
x In
r i
d a
- - - - - - -
r
W)
O
M
co
M
n
(0
'
10
Of
0
O
C4
,
N
h
0
h-
tO
D7
r
M
M
V
O
01
O
to
(0
M
N
CD
ao
tD
M
N
N
(D -
O -
t N
o --
O
V - - - - - -
. -
o -
O -
O
N
N . r O) v
V N N N co O M N 01 N r O DI N N V ? Cn O
N V o0 M U) N O) r Cl) M y 0 (V r tri (0
G
R
a° w w en w w w w w w w w w w w w w w w
Q Lo 0 r to O N M K M O O r N O M tD O to co M to N M tD O O
r
C oo
M c')
L'
N (D
R m
?- o)
O V
V t`
r- n
tw to
O V N
O M
N '
V'
(a
Cri Q ?o IT
0 0
r M
O en
N M
r N
O tD
m c0
N LO
h
V
rn Cl)
r
N
tn
V ai M N Cl) n O r V M r M M N Ol v tn N r tn (
m
Z
W
w
w
w
w
w
LO
U3,
4&
64
401,
N (D
O
N
N
Lr)
tU
C
0
0 .0
7
a v
d c
O W w
a to O M 0 n 0 0 M N N O V O CO N CO O O Lo 00 co (+i N co O O O
0 M M M N M M W M tn M O d' M O N M O M N O O N O to c D) M N
O M (!i r ? t` tA to t- C7 t0 W V o r V N (D N ? Ct to V 0) n N
N
0
M V W r M M T t` r st r V N M r tn Q N N r to tD
a
Y
A
LL y w w w w w w w w w w w w w w w w w w w w w w w w w w w w w w w
°
° tD
0 0
0 0
0 W)
0 N
p w
0 t0
0 (D
0 CD
0 0
0 0
0 (D
0 (D
0 V
0 v
0 (0
0
(DO v
o v
0
c
D o
N o
N 0
N 0
N 0
N 0
N 0
N 0
N 0
N 0
N 0
N 0
N 0
N 0
` 0
N 0
N 0
1 0
N 0
N 0
N 0
N O
N O
,N? 0 0 0 0 0
'
7
A
M
R
(?
?
M
('?
M
M
a
M
a
M
a
M
a
(
7
a
?
M
a
M
a
N
a
M
a
M
M
M
a
M
a
M
a
M
a
M
a
M
a
M
a
M
(?
M
(h
M
(n
M
f?
M
(?
?
M
M
M
>
Q - - - - - - - - - - - - - - -
7
y N
C co
+' C o)
C
O
0)
•(0
co
co
LD
(D h N
r y n DI
h n
co M
co
m
N
•
V
v
tb
Y Go C
~
co
Go 00 U,
O
y
d
. a ? J M (`00 m E M N N 0 CD O O
C p
U 7 a N
)- r (o
O to
Y l0
m # p
y co
Y w
Y
..d..
O
N
(O+1
N
M
. ` O
Ol U y
d U
Q y
'6 } LL
?
S
'2 O V
V n
ap C
M tU
C
O
Z '0
C_ c
a c
m t0
U) N
v 0
N
O
ao
O
co
V
d NU U C O O V U U O
F a to pW? y
y
? E v y O F ? M M
-
to
o
Q N
t 0
> C
O
L
p"
W
~
Z
lll
'
F"
Z
O
O
Y F
(n
Z ?
c O
a `
d y t
?6
0
c 2
M ,
y ?
I `
N L?I
c O
a 0
# ?
# J
#
W N a 2 U x ? } , 3 ? 0 W 0 L) O m E Ot
c Z= E > > E E ;; 13 5 >
V) N To E C), rn p w Q a O z U } D 0
a U U Q !? d F E > o c c E E G
d
u
_
u
a o v ? rf Of Q QC? c? ? o m ? 3 ? ? z a aa.. ? 3 v 0W L) n0
» y U U U
-1
a.
a.
a.
r N M N ID n ao 0)
c
O
O
? U
fA C
N A
A ?
3
;U
A ?
A O
cc O
Ln
O
O
Z
A
3
A
a
w
A
C9
vi
d
a
Q o
? N
'O N
da
w-o
"
m NW
4) w
Q
Q
'a
A
w
C
C
JA vri o
v m ? ?
= t% w w
d
w
d ro
?h w
04
N C14
co m
ce) CIA
n Ul)
00 0>
h 00
O
D
o
o
0
co
M C6 O N N N d
V
. C
O
ro p I
J
r2 O. w V> w Vj w V) w V> w V) w V1 N V3, wI fA w w V? w w Vi w w w N w w N N w N Vi N V) N !9 N Vi . -
cv ° M N co m O
07 ° r o ° ti
C, co tO N N N
V
d
Z W
w
w
N
w
N
f9
w
b4
N
w
w
N
N
VII
V1 _
1r
w
M
N
N
N
V!
w
w
f9
N
w
N
(9
w
N
w
fA
w
N
N
w
w
w
fD
N
cli
a
C
o f
c w
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
w
- - - - - - - - - - - - - - N 000 M m
N
OODD 0)
W O h C C h
Cl) co O N N N co
d
Y
to
to
?
d
U. to N Vy w b3 V) V) w
13 m m v v c It
p C
N
0
0
0
N
N
r
R R A ? fV M
52 M
) a M
M co
? Q
^
N
+
° C
7
?
m d 0 O
C E O T
o
E
r
°k d
t C
o
t W .?' co
v m
-? d
C s Qa ° o ro .
c
d
„
O
_
t o
d
n
r
?4v
o°,v
O1
`?
o c
o o ?
? p
Z Lf
( ID r
# N
rn c
?
9 E
Im a
E
o H
D
IT (0
C, OD
c
C E ro ° ° N d ro
y u w
c
o c
ro M o 0, C
a v `
"
°
n
E
E
c
0 1z E C? .
N
u o
o 6 m
E
o «
C
a+ ?
o
? Q N
P y
P
?
n.
V
C
Q
Z
o
ai
a
r d
E
c e A
O e t
W m N
co M
a m
d~°,?o > > w O
m 0 d
Q
W
H
c t .d..
N w
O
+' '? O M
C
?
N
N N
V 10
'O
d 7
O L
« ro
C f'
O
Q < (? a a m W 9L p
j
Q: (?
U F N
V f?
J O r- 7 > LL. O J f W D S O W r
0
vi
-4?
r O
N
N N
N M
N 7
N n
N ?D
N
VERIFICATION
I, Andrew S. Gassaway, hereby verify and state that the facts set forth in the foregoing
document are true and correct to the best of my information, knowledge and belief. I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to
unworn verification to authorities.
n
Date: Z,. / - f c? 7 G"
Andrew S. Gassaway
n cN-a O
c? -n
ANDREW S. GASSAWAY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 05-0867 CIVIL TERM
JENNIFER M. GASSAWAY,
Defendant : IN LAW - DIVORCE
PLAINTIFF'S PRETRIAL STATEMENT
Andrew S. Gassaway, Plaintiff, by and through his counsel William L. Grubb,
Esquire, hereby files this Pretrial Statement pursuant to Pa. R.C.P. 1920.33 and
respectfully states as follows:
STATUS OF THE CASE
The parties were married on July 6, 1991, were separated on March 31, 2004, and
are the parents of four (4) minor children. A custody Stipulation and Order is in place
since March 28, 2005. A Complaint in Divorce was filed on February 16, 2005, and
served upon the Defendant on February 19, 2005, via US Mail, certified, restricted
delivery. The Complaint In Divorce was filed under Section 3301(c) or Section 3301(d)
of the Divorce Code, with an additional Count for Equitable Distribution.
The Plaintiff resides at 12 Keefer Way, Mechanicsburg, Pennsylvania. The
Defendant continues to reside in the marital residence at 10 Narragansett Drive,
Mechanicsburg, Pennsylvania.
Counsel for Defendant filed a Motion for Appointment of Master on October 27,
2006, with respect to the claims of (1) Divorce and (2) Distribution of Property, and the
1
Motion was granted on November 1, 2006, with the Court appointing Robert E.
Elicker,II, Esquire, as Master for this matter.
Certifications that the Discovery is complete were signed by Counsel for the
Defendant on November 20, 2006, and by Counsel for the Plaintiff on February 25, 2007.
MARITAL ASSETS VALUE
DATE
1 10 Naragansett Dr. 2004
Residence
2 1997 Honda Accord 3/31/04
1997 Suburban 3/31/04
3 STOCKS
Carmax 3/31/04
Circuit City 3/31/04
Crown Crafts 3/31/04
4 CDs
5 Checking Accts.
E* Trade 6658-7663 3/31/05
Commerce 3/31/04
536249279
6 Savings & Certificates
Solomon Smith Bny. 3/31/04
Vanguard GNMA 3/31/04
36-9874439510
Vanguard Windsor II 3/31/04
73-9874439510
Commerce 3/31/04
626187678
Commerce 3/31/04
626188635
7 Safe Deposit
8 Trusts
9 Life Insurance
#L032802290 12/31/06
#L032802300 12/31/06
NET VALUE NET
VALUE DATE VALUE
95,744 12/01/06 152,744
4,385 4,385
8,530 8,530
3195 12/31/06 3,195
5,990 12/31/06 5,990
442 12/31/06 442
9295 12/31/06 9,295
4,188 12/31/06 4,188
15,023 15,023
2,965 12/31/06 2,965
11,281 12/31/06 11,281
15,552 15,552
16,448 16,448
998 12/31/06 998
730 12/31/06 730
2
#L030496310 12/31/06 1,520 12/31/06 1,520
10 Annuities
11 Gifts
12 Inheritances
13 Patients
14 Property out of home
15 Business
16 Employment Term.
17 Profit Sharing
18 Pension Plans
19 Retirement Plans
CGM 35-46233901 12/31/06 35,822 12/31/06 35,822
Vanguard Roth IRA 12/31/06 6,039 12/31/06 6,039
996447009
Vanguard Windsor H 3/31/04 2,752 3/31/04 2,752
73-9964432618
Vanguard Star 6/30/04 23,085 6/30/04 23,085
56-9891266106
Fidelity 2AB-367281 3/12/04 20,099 3/12/04 20,099
20 Disability Payments
21 Litigation Claims
22 Military Benefits
23 Education Benefits
24 Debts Due
25 Household
Furnishings
26 Other
Engagement ring 3/31/04 4,500 3/31/04 4,500
TOTAL 255,415 345,583
NON-MARITAL VALUE NET NON-MARITAL
ASSETS DATE VALUE PORTION MARITAL
3 Stocks
Agere 12/31/06 211 150 61
Avaya 12/31/06 461 461
Daimler Chrysler 4/6/05 3,778 3,778
IBM 12/31/06 777 197 580
Intel 12/31/06 7,651 7,399 252
J & J 2/28/05 10,043 7,364 2,679
Lucent 12/31/06 1,020 1,020
May Co. 3/31/04 4,530 4,530
Medco 12/31/06 641 641
Merck 12/31/06 3,911 2,615 1,296
3
Nordstrom 12/31/06 11,842 2,145 9,697
Pepsi 12/31/06 3,188 1,245 1,943
PNC 12/31/06 3,643 2,253 1,390
Tricon 12/31/06 706 456 250
Walmart 12/31/06 5,030 1,094 3,936
19 T Rowe Price 12/31/06 83,189 9,457 73,732
400546359-6
TOTAL 140,621 44,805 95,816
EXPERT WITNESSES
The Defendant may call:
Robert K. Banzhoff, appraiser
The Defendant reserves the right to call additional expert witnesses upon
reasonable notice to Plaintiff.
LAY WITNESSES
The Defendant may call:
Andrew S. Gassaway, Plaintiff
Jennifer M. Gassaway, Defendant (as on cross examination)
James M. Gassaway, II
The Plaintiff reserves the right to call additional witnesses upon
reasonable notice to Defendant
The Plaintiff reserves the right to supplement this statement prior to trial.
EXHIBITS
Plaintiff intends to present the following Exhibits:
1. Husband's Federal Income Tax returns for various years.
2. Plaintiffs Answers to Request for Production of Documents
3. Defendant's Answers to Request for Production of Documents
4. Appraisal for marital residence
5. Bank statements and check registers of Defendant.
The Plaintiff reserves the right to introduce and use additional exhibits upon
reasonable notice to Defendant.
4
INCOME
As determined at the August 21, 2006 support conference, Husband has a net
monthly income of $3,622.42 per month, and Wife a net monthly income of $6,936.27.
EXPENSES
Husband has submitted an expense report at the support conference on August 21,
2006, and will submit an updated expense report at the time of the pre-trial conference.
PENSION INFORMATION
Plaintiff and Defendant IRA or other retirement type accounts are listed in Marital
Assets.
COUNSEL FEES
No claim has been made by either party for counsel fees as of this date.
DISPUTED ECONOMIC ISSUES
1.) The marital residence is encumbered by a mortgage of approximately
$152,256.00 as of the date of separation. An appraisal performed on the residence on
December 1, 2006 returned a value of $305,000.00, thus the net value of $152,744.00.
Mrs. Gassaway has enjoyed the continued use the marital residence since the date of
separation, and has been paying the mortgage of approximately $800.00 per month and
utility payments. Husband considers this a more than fair exchange for the actual rental
value of the property. Mrs. Gassaway believes the property to value at $248,000.00, less
costs of sale, therefore netting a much lower number.
2.) During the course of the marriage Mrs. Gassaway opened an account at
Commerce Bank in August, 2003, #626188635, with marital funds in an attempt to
conceal assets. It is the position that these funds are marital in nature.
3.) Mrs. Gassaway is the owner of an account with Solomon Smith Barney which
had been a gift from her mother. During the course of the marriage, Mrs. Gassaway
removed funds from that account for use in the marriage. At a later time Mrs. Gassaway
deposited marital funds into that account, thus converting the nature of the account to that
of marital.
5
4. Mr. Gassaway wishes to acquire the rights to all income tax deductions, credits
and exemptions associated now and forever for two of the children of the marriage,
Christopher D. Gassaway and Thomas M. Gassaway, and Mrs. Gassaway shall be entitled
to all income tax deductions, credits and exemptions associated now and forever for two
of the children of the marriage, Nicholas A. Gassaway and Brian W. Gassaway.
MARITAL DEBT
1. 10 Naragansett Drive
VALUE DATE AMOUNT
3/31/04 $152,256.00
PROPOSED RESOLUTION OF ECONOMIC ISSUES
The Plaintiff proposes the following resolution of the economic issues:
To be distributed MARITAL
to wife: VALUE
1. Residence, 10 Naragansett Drive 152,744
2. 1997 Suburban 8,530
3. Commerce #626187678 (50%) 7,992
4. Nationwide Life Ins. L032802290 998
5. Vanguard Windsor 11 73-9964432618 2,752
6. Vanguard Star 56-9891266106 23,085
7. Fidelity 2AB-367281 20,099
8. Engagement ring 4,500
TOTAL 220,700
To be distributed MARITAL
to husband: VALUE
1. 1997 Honda 4,385
2. Stocks
Agere 61
Avaya 0
6
Carmax 3,195
Circuit City 5,990
Crown Crafts 442
Daimler Chrysler 0
IBM 580
Intel 252
J & J 2,679
Lucent 0
May Co. 0
Medco 0
Merck 1,296
Nordstrom 9,697
Pepsi 1,943
PNC 1,390
Tricon 250
Walmart 3,936
E*Trade 6658-7663 9,295
Commerce #536249279 4,188
Smith Solomon Barney 15,023
Vanguard GNMA 36-9874439510 2,965
Vanguard Windsor 1173-98744395 10 11,281
Commerce #626187678 7,560
Commerce #626188635 16,448
Nationwide Life Ins. L032802300 730
Nationwide Life Ins. L030496310 1,520
CGM IRA 35-46233901 35,822
T Rowe Price 73,732
Vanguard Roth IRA 9964470094 6,039
TOTAL 220,699
Husband reserves the right to supplement this memorandum should additional
discovery material become available.
Respectfully submitted,
William L. Grubb, Esquire
I.D. # 72661
3803 Gettysburg Road
Camp Hill, PA 17011
(717) 763-5580
Attorney for Plaintiff
7
ANDREW S. GASSAWAY,
Plaintiff
V.
JENNIFER M. GASSAWAY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-0867 CIVIL TERM
IN LAW - DIVORCE
CERTIFICATE OF SERVICE
I, WILLIAM L. GRUBB, Esquire, certify that I have served a copy of the
foregoing Plaintiff's Pre-trial Statement on the individual listed below by depositing the
same in the United States Mail, First Class, postage prepaid, at Camp Hill, Pennsylvania:
Maria Cognetti, Esquire
Cognetti & Associates
210 Grandview Avenue, Suite 102
Camp Hill, PA 17011
Date: ?3 Z&J 7 (SLR L
William L. Grubb, Esquire
3803 Gettysburg Road
Camp Hill, PA 17011
8
VERIFICATION
1, ANDREW S. GASSAWAY, verify that the statements made in this document
are true and correct. I understand that false statements herein are made subject to
penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities.
Date: --13 --0 1
Andrew S. Gassaway, Plaintiff
9
n N
C? ++??
l1r
c? -T7
?
'
?- t' Q .?y.
MARIA P. COGNETTI & ASSOCIATES
MARIA P. COGNETTI, ESQUIRE
Attorney I.D. No. 27914
210 Grandview Avenue, Suite 102
Camp Hill, PA 17011
Telephone No. (717) 909-4060
Attornev for Defendant
ANDREW S. GASSAWAY,
Plaintiff
V.
JENNIFER M. GASSAWAY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-867 Civil Term
CIVIL ACTION - LAW
IN DIVORCE
DEFENDANT'S PRE-TRIAL STATEMENT
Jennifer M. Gassaway, Defendant, by and through her attorney, Maria P. Cognetti, Esquire,
files the following Pre-Trial Statement:
TABLE OF CONTENTS
1. Background Information
II. Listing of Marital Assets and Debts
III. Listing of Personal Property
IV. Listing of Non-Marital Assets
V. Pensions
VI. Income and Expenses
VII. Counsel Fees and Costs
VIII. Expert Witnesses
IX. Non-Expert Witnesses
X. Listing of Proposed Exhibits
XI. Proposed Resolution
I. BACKGROUND INFORMATION
A. PARTIES
HUSBAND
NAME Andrew S. Gassaway
ADDRESS 12 Keefer Way, Mechanicsburg, PA
AGE 44
DATE OF BIRTH August 8, 1962
PLACE OF BIRTH Philadelphia, PA
SOCIAL SECURITY NUMBER 196-46-6621
HEALTH Good
EMPLOYER Ames True Temper
OCCUPATION Accountant
LENGTH OF RESIDENCY IN PA 34 years
EDUCATIONAL BACKGROUND College
WIFE
NAME Jennifer M. Gassaway
ADDRESS 10 Naragansett Drive, Mechanicsburg, Pa
AGE 40
DATE OF BIRTH March 16, 1967
PLACE OF BIRTH Rapid City, South Dakota
SOCIAL SECURITY NUMBER 205-52-5241
HEALTH Good
EMPLOYER Capital Blue Cross
OCCUPATION Director, EIM Corporate Anlaytics
LENGTH OF RESIDENCY IN PA 25 years
EDUCATIONAL BACKGROUND College
B. CHILDREN
NAME AGE DATE OF BIRTH CUSTODIAN
Nicolas A. Gassaway 14 November 8, 1992 Wife
Christopher D. Gassaway 12 October 27, 1994 Wife
Thomas M. Gassaway 10 May 13, 1996 Wife
Brian W. Gassaway 8 October 20, 1998 Wife
C. MARRIAGE INFORMATION
DATE OF MARRIAGE July 6, 1991
PLACE OF MARRIAGE Wyomissing, Berks County, PA
DATE OF SEPARATION August 2003
CIRCUMSTANCES OF SEPARATION Irretrievable breakdown
D. PRIOR MARRIAGE
WIFE N/A
HUSBAND N/A
E. CHILDREN OF OTHER RELATIONSHIPS/MARRIAGES
WIFE N/A
HUSBAND N/A
PROCEEDINGS INFORMATION
DATE ACTION COMMENCED February 16, 2005
DATE OF SERVICE OF COMPLAINT February 19, 2005
MANNER OF SERVICE OF
COMPLAINT Certified mail
ISSUES RAISED IN DIVORCE
COMPLAINT Divorce and Equitable Distribution
DATE AMENDED COMPLAINT FILED N/A
ISSUES RAISED IN AMENDED
COMPLAINT N/A
DATE OF FILING OF ANSWER
AND/OR COUNTERCLAIM N/A
ISSUES RAISED IN COUNTERCLAIM N/A
BIFURCATION N/A
PREVIOUSLY RESOLVED ISSUES N/A
II. MARITAL ASSETS AND DEBTS
The following is a listing of the marital assets and debts of the parties:
rFEM DESCRIPTION TOTAL
NO. VALUE
LA 10 Naragansett Dr.,
Mechanicsburg, PA
$248,000.00
H W
COMMENTS
X I Wife's appraisal. 3/28/04
2.A 1997 Honda Accord $4,385.00 X Husband traded in his vehicle but has
refused to disclose the value received.
$4,385 represents NADA value.
2.B 1997 Chevy Suburban $4,000.00 X Wife traded in her vehicle and
received $4,000 on 9/25/04.
3.A Agere Systems Stock X Number of shares unknown
3.B Avaya Stock (33 shares) $393.03 X As of 4/5/07
3.C CarMax Stock (31 shares) $778.72 X As of 4/5/07. Currently held in Janney
Montgomery Scott # PHZ9 3562-2922
3.1) Circuit City Stock (100 $1,821.00 X As of 4/5/07. Currently held in Janney
shares) Montgomery Scott # PHZ9 3562-2922
3.E Crown Crafts Stock (52 $248.56 X As of 4/5/07
shares)
3.F Daimler Chrysler Stock $7,018.45 X As of 4/5/07
(85 shares)
3.G IBM Stock (8 shares) $769.68 X As of 4/5/07
3.H Intel Stock (365.661793 $7,086.52 X As of 4/5/07
shares)
3.1 Johnson & Johnson Stock $9,316.08 X As of 4/5/07. Stock was held in
(152 shares) Janney Montgomery Scott # PHZ9
3562-1200. Husband sold all shares
3/2005.
ITEM DESCRIPTION TOTAL H W COMMENTS
NO. VALUE
3.J Lucent Stock (400 shares) $7,709.00 X As of 4/5/07
3.K May Co. Stock (131 $6,006.35 X As of 4/5/07
shares)
3.1, Medco Health Solutions $888.24 X As of 4/5/07. Currently held in Janney
Stock (12 shares) Montgomery Scott # PHZ9 3562-1200
3.M Merck Stock (100 shares) $4,537.00 X As of 4/5/07. Stock was held in Janney
Montgomery Scott # PHZ9 3562-1200.
Husband sold all shares 3/2005.
3.N Merck Stock (79.277 $3,596.79 X As of 4/5/07
shares)
3.0 Nordstrom Stock (120 $6,489.60 X As of 4/5/07
shares)
3.P Pepsico Stock (30 shares) $1,911.90 X As of 4/5/07
3.Q PNC Financial Stock $4,449.28 X As of 4/5/07
(61.692748 shares)
3.R Tricon Stock (12 shares) $3,231.00 X As of 4/5/07
3.S Walmart Stock $11,571.55 X As of 4/5/07
t0
4.. ?. r t `4i .. ry ?y; l,R.{? AGit 1 '
a.n1?YAaGa? ? , f y . }
K '1
4.A Commerce Bank Checking $7,985.31 X X As of 8/26/03
#536249279
43 Commerce Bank Savings $18,456.48 X X As of 8/31/03
#626187678
4.C Commerce Bank Savings # $11,000.90 X As of 3/31/04
626407753
S.A Nationwide Life Insurance $1,520.15 X As of 11/7/05
#L030496310
5.B Nationwide Life Insurance $729.92 X As of 11/7/05
#L032802300
5.C
1 Nationwide Life Insurance $998.92 X As of 11/7/05
#L032802290
ITEM DESCRIPTION TOTAL
H
W
COMMENTS
N O. VALUE
6.A guard GNMA #36-
! $2,997.66 X X As of 4/11/07
9874439510
6.B Vanguard Windsor II #73- $11,634.95 X X As of 4/11/07
9874439510
6.C Solomon Smith Barney $10,022.99 X As of 3/28/04. Account was opened
#739-01718-12 687 with $5,000 gift from Wife's mother.
(Marital portion) Wife closed account in 2004 at
Husband's insistence.
6.1) CGM #35-46233901 $35,822.00 X As of 12/31/06
6.E E-trade Securities account $9,810.70 X As of 1/31/07
6.F T Rowe Price $73,732.22 X Pre-marital value was $9,457.28.
#400546359-6 Value on 12/31/06 was $83,189.50
6.G Vanguard Windsor II Roth $12,038.51 X As of 12/31/06
IRA #9964470094
6.11 Vanguard Windsor II Roth $9,882.58 X As of 3/31/07
IRA #9964432618
6.1 Vanguard Star #56- $30,366.69 X As of 3/31/07
9891266106
6.J Fidelity #2AB -367281 $26,818.36 X As of 3/13/07
7.A Household items and X X Previously divided in kind
miscellaneous personalty
y t`k"?
"41G?lsc6l?anegllS a.? 't
} N
9.A Life Insurance payments $1,655.00 X Paid by Wife since separation
for Husband
9.B Auto Insurance payments $390.00 X Paid by Wife for 1 year following
for Husband separation
9.C Engagement Ring $4,500.00 X Husband's estimated value
III. LISTING OF PERSONAL PROPERTY
ITEMS RETAINED BY WIFE
DESCRIPTION VALUE
Previously divided in kind
ITEMS RETAINED BY HUSBAND
DESCRIPTION VALUE
Previously divided in kind
IV. LISTING OF NON-MARITAL PROPERTY
The following is a listing of the non-marital assets of the parties:
No. Description Basis of Exclusion Owner
1. Non-Marital portion of Gift Wife
Solomon Smith Barney #739-
01718-12 687
2. Pre-marital portion of T Rowe Pre-marital Husband
Price #400546359-6
3. Commerce Bank Savings Post-separation Wife
#626188635
V. PENSIONS
The following is a listing of the pensions of the parties:
PARTY DESCRIPTION
Husband N/A
Wife N/A
VI. INCOME AND EXPENSES
The following is a listing of the income and expenses of the parties:
PARTY DESCRIPTION AMOUNT
Husband
Gross Monthly Income $4,500.00
Net Monthly Income $3,300.00
Monthly Expenses Unknown
Wife
Gross Monthly Income $7,822.90
Net Monthly Income $5,228.62
Monthly Expenses $6,986.00
VII. COUNSEL FEES
The following is a listing of the counsel fees and expenses incurred, or to be incurred by
the parties:
PARTY DESCRIPTION DATES AMOUNT
Husband
Counsel Fees N/A
Costs N/A
Anticipated Fees and Costs N/A
Wife
Counsel Fees N/A
Costs N/A
Anticipated Fees and Costs N/A
VIII. EXPERT WITNESSES
The following is a listing of the anticipated experts who will be called to testify in this
case:
NAME SUBJECT OF TESTIMONY
A Real Estate Appraiser Value of the marital home.
Additional experts who may be called to testify are not known at this time. If such
additional experts are retained, Defendant reserves the right to call them as witnesses upon proper
notification to Plaintiff.
IX. NON-EXPERT WITNESSES
NAME SUBJECT OF TESTIMONY
Jennifer M. Gassaway History of the marriage; identification and
valuation of marital assets and debts; other relevant
testimony relating to the factors set forth in the
Divorce Code.
Andrew S. Gassaway, as of cross History of the marriage; identification and
valuation of marital assets and debts; other relevant
testimony relating to the factors set forth in the
Divorce Code.
Additional witnesses who may be called to testify are not known at this time. If such
additional witnesses are identified, Defendant reserves the right to call them as witnesses upon
proper notification to Plaintiff.
X. LISTING OF PROPOSED EXHIBITS
The following is a listing of Exhibits which are anticipated to be submitted at the hearing in
this case:
NO. DESCRIPTION
I Defendant's Income and Expense Statement.
2 Plaintiff's 2006 W-2 Statements and Federal Income Tax return.
3 Defendant's 2006 W-2 Statements and Federal Income Tax return.
4 Appraisal of the marital home.
5 DOS Statements for all bank accounts.
6 Statements for all investment/pension/retirement accounts.
7 Statements of trade-in values on the parties' vehicles.
8 Statements for all whole life insurance policies.
9 Statements indicating current value of all stocks.
If additional exhibits are identified, Defendant reserves the right to submit additional
Exhibits upon proper notification to Plaintiff.
XI. PROPOSED RESOLUTION
A. EQUITABLE DISTRIBUTION: 60/40 split of all marital assets in favor of Wife.
B. ALIMONY: N/A
C. COUNSEL FEES AND COSTS: N/A
Respectfully Submitted:
MARIA P. COGNETTI & ASSOCIATES
Date: 411310 By:
MARIA . CO ETTI, ESQUIRE
Attorney I.D. . Na/27914
210 Grandview Avenue, Suite 102
Camp Hill, PA 17011
Telephone No. (717) 909-4060
Attorney for Defendant
C? ?, -n
--' .-{
??
?
?
C .r
:.? ? ;'i
f?.l -li
-"" :-C
r,;, C.T i
ANDREW S. GASSAWAY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 05-0867 CIVIL TERM
JENNIFER M. GASSAWAY,
Defendant : IN LAW - DIVORCE
PRAECIPE TO ENTER AN APPEARANCE
and
PRAECIPE TO WITHDRAW AN APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance of self-representation as the above-captioned Plaintiff.
Respectfully,
Date: Andrew S. Gassaway, pro se
TO THE PROTHONOTARY:
Please withdraw my appearance as counsel of record for the above-captioned
Plaintiff.
Respectfully,
Date < < ,
William L. Grubb, Esquire
3803 Gettysburg Road
Camp Hill, PA 17011
I.D. 72661
(717) 763-5580
C c, Q
? t'??
??, -..?
? ?
,:
??: N
_. ?m
.? ? ?
t
^
Ham.. {?, ;? Z
??? ? ???
'?
ANDREW S. GASSAWAY, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
)
VS. ) CIVIL ACTION - LAW
NO. 05-867 CIVIL TERM
JENNIFER M. GASSAWAY, )
Defendant ) IN DIVORCE
PRAECIPE
TO THE PROTHONOTARY:
Please enter my appearance for the Plaintiff Andrew S. Gassaway in this matter.
D-"-
27 November 2007
t?wAel L. Andes
Attorney for Plaintiff
Supreme Court ID # 17225
525 North 12th Street
Lemoyne, Pa 17043
(717) 761-5361
gi
l
rol
t
ANDREW S. GASSAWAY,
Plaintiff
V.
JENNIFER M. GASSAWAY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: DOCKET NO. 05-867
CIVIL ACTION -LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
February 16, 2005.
2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days
have elapsed from the date of the filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn
falsification to authorities.
Date: 9- io -_-2c,ve ,u
JE*flFER M. GASSAWAY d
+v
m
w
c?
ANDREW S. GASSAWAY,
Plaintiff
V.
JENNIFER M. GASSAWAY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
DOCKET NO. 05-867
CIVIL ACTION -LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF DIVORCE DECREE UNDER
§ 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a Divorce Decree is entered by the
Court and that a copy of the Decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn
falsification to authorities.
Date: D - t, Or- n•, ?, 114. +t
JE IFER M. GASSAWAY
_N
m:n
2y
. _ Q
7-4
CA)
loop
ANDREW S. GASSAWAY, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 05 - 867 CIVIL
JENNIFER M. GASSAWAY, .
Defendant IN DIVORCE
ORDER OF COURT
AND NOW, this a?-a day of ?_
2008, the economic claims raised in the proceedings having been
resolved in accordance with a property settlement agreement
dated September 10, 2008, the appointment of the Master is
vacated and counsel can file a praecipe transmitting the record
to the Court requesting a final decree in divorce.
BY THE COURT,
?I GI)
Edgar B. Bayley, P.J.
cc: / muel L. Andes
Attorney for Plaintiff
,/aria P. Cognetti
Attorney for Defendant
0?/
cv
00
j
_.3
LLJ CL
' rll
LLJ 0- ,. TG'..
bL. 1.6.1
GO
rL
C)
N
PROPERTY SETTLEMENT AGREEMENT
THIS AGREEMENT, made this /U day of %."m 622008, is by and between:
ANDREW S. GASSAWAY, of 12 Keefer Way, Mechanicsburg, Cumberland County,
Pennsylvania, party of the first part, hereinafter referred to as "Husband"; and
JENNIFER M. GASSAWAY, of 10 Naragansett Drive, Mechanicsburg, Pennsylvania, party of
the second part, hereinafter referred to as "Wife."
WITNESSETH:
WHEREAS, the parties hereto are husband and wife, having been married on 6 July 1991 and are
the parents of four minor children: Nicholas A. Gassaway, born 8 November 1992, Christopher D.
Gassaway, born 27 October 1994, Thomas M. Gassaway, born 13 May 1996, and Brian W. Gassaway,
born 20 October 1998 (hereinafter referred to as "children"); and
WHEREAS, certain difficulties have arisen between the parties hereto which have made them
desirous of living separate and apart from one another and Husband has initiated an action in divorce filed
to No. 05-867 before the Court of Common Pleas of Cumberland County, Pennsylvania;
WHEREAS, the parties hereto, Wife being represented by Maria P. Cognetti, Esquire, and
Husband by Samuel L. Andes, Esquire, have each exchanged full and complete information as to the
property, assets, and liabilities owned and owed by each and have disclosed to each other and to their
respective attorneys full information as to the financial status of both parties hereto; and
WHEREAS, the parties hereto have mutually entered into an agreement for the division of their
assets, the provision for the liabilities they owe, and provision for the resolution of their mutual
differences, after both parties have had full and ample opportunity to consult with their respective
attorneys, and the parties now wish to have that agreement reduced to writing.
NOW, THEREFORE, the parties hereto, in consideration of the above recitals, the mutually
made and to be kept promises set forth hereinafter, and for other good and valuable considerations, and
intending to be legally bound and to legally bind their heirs, successors, assigns, and personal
representatives, do hereby covenant, promise, and agree as follows:
1. CHILD CUSTODY. This agreement makes no provision for the legal or physical custody of
the children. The parties agree that they will resolve those matters by their mutual cooperation outside of
-1-
this agreement. Otherwise, each of the parties reserves unto themselves all of their rights, remedies, and
claims regarding the legal and physical custody of their minor children.
2. CHILD SUPPORT. This agreement makes no provision for the financial support of the
parties' children. Husband and Wife acknowledge that they are parties to an action for child support
before the Court of Common Pleas of Cumberland County, Pennsylvania, and agree that they will resolve
matters relating to the financial support of their children through that action or through their mutual
cooperation and negotiation. Otherwise, the parties reserve unto themselves all of their rights, remedies
and claims regarding the financial support of their minor children.
3. MARITAL RESIDENCE. Husband covenants and agrees to convey to Wife, as her sole
and separate property, the real estate presently owned by the parties hereto as tenants by the entireties and
being known as 10 Naragansett Drive, Mechanicsburg, PA, subject, however, to all liens, encumbrances,
easements, and restrictions presently existing thereon. In furtherance of this Agreement, Husband
represents that he has, as of the date of this Agreement, executed, acknowledged, and delivered to his
attorney, a deed to said real estate, conveying the same as above described to Wife, and agrees that said
deed shall be held in escrow by his attorney pending the completion of the divorce action filed or
contemplated to be filed as aforesaid, by the entry of a final decree or order therein. Upon the completion
of said action in divorce, Husband's said attorney shall, without further direction or authorization from
Husband, deliver the said deed unto Wife's attorney.
4. DEBT AGAINST RESIDENCE. The parties acknowledge that the marital residence to be
transferred to Wife in accordance with the preceding paragraph is subject to a debt secured by a first
mortgage on the property, on which the balance owed is approximately $140,000.00. Wife shall, within
ninety (90) days of the date of this agreement, refinance that debt, or take such other action as may be
required to obtain Husband's unconditional release from liability on that obligation. Further, Wife shall
be responsible to pay, in accordance with their terms, all other debts, expenses, and obligations resulting
from her timely payment of all such obligations, debts, and expenses.
5. AUTOMOBILES. The parties shall transfer to Wife's sole ownership, and Husband hereby
I I waives any further claim to or interest in, the 1997 Chevrolet Suburban automobile retained by Wife at the
date of separation. The parties shall transfer to Husband's sole ownership, and Wife hereby waives any
further claim to or interest in, the 1997 Honda Accord automobile retained by Husband at the date of
-2-
separation. Each of the parties shall pay and satisfy, in accordance with their terms, any debts which
encumber the titles to the vehicles described in this paragraph and shall pay all other expenses and
liabilities arising out of their use or ownership of the vehicles since the date of the parties' separation and
shall further indemnify and save the other party harmless from any loss, cost, or expense caused to them
by their failure to pay such obligations as due. The parties will make, execute, acknowledge and deliver
all certificates of title and other documents necessary to complete the transfer of ownership as provided
for herein.
6. ASSETS TO BE TRANSFERRED TO OR RETAINED BY HUSBAND. The parties
agree that Husband shall be the sole and separate owner of the following assets, whether those assets are
now held in joint names or the name of either of the parties individually:
A. The two policies of insurance on Husband's life issued by Nationwide Life
Insurance Company (being a policy which ends with policy #2300 and a policy which ends
with policy #6310).
B. Husband's individual retirement account with CGM.
C. Husband's individual retirement account with T. Rowe Price.
D. Husband's Roth IRA with Vanguard Funds.
E. The joint investment account with E-Trade.
F. The joint Vanguard account identified as "GNMA 36-9874439510".
G. The joint Vanguard account identified as "Windsor 11 73-9874439510".
H. The corporate stock owned by Husband which is largely, entirely, or partly
non-marital. A list of the stocks owned by Husband is attached hereto and marked as
Exhibit A.
The parties agree that they will make, execute, acknowledge and deliver, within thirty (30) days after the
date of this agreement, all documents necessary to transfer such items to Husband's name alone and for
Wife to waive any further claim to or interest in such assets and Wife does hereby acknowledge those
assets to be the sole and separate property of Husband from and after the date of this agreement.
7. ASSETS TO BE TRANSFERRED TO OR RETAINED BY WIFE. The parties agree
that Wife shall be the sole and separate owner of the following assets, whether those assets are now held
in joint names or the name of either of the parties individually:
-3-
A. The policy of insurance on Wife's life issued by Nationwide Life Insurance
(being a policy which ends with policy #2290).
B. Wife's investment account with Solomon Smith Barney.
C. Wife's Commerce Bank account #7678.
D. Wife's Commerce Bank account #8635.
E. The proceeds of the joint checking account at Commerce Bank.
F. Wife's Roth IRA with Vanguard Funds.
G. Wife's IRA with Vanguard Funds.
H. Wife's IRA with Fidelity Investments.
The parties agree that they will make, execute, acknowledge and deliver, within thirty (30) days after the
date of this agreement, all documents necessary to transfer such items to Wife's name alone and for
Husband to waive any further claim to or interest in such assets and Husband does hereby acknowledge
those assets to be the sole and separate property of Wife from and after the date of this agreement.
8. AGREEMENT AS TO VALUES. The parties acknowledge that they exchanged extensive
information about the above assets and have had full opportunity to have those assets valued and to
receive the advice of their attorneys regarding the identity and value of the assets. The parties
acknowledge that they have not been able to agree upon a value for each of the assets but that they have
agreed upon the approximate total value of all of the assets and the division of the assets as outlined
above. Both parties acknowledge that they are sufficiently satisfied with the division of the assets that
further valuation is not necessary.
9. CASH PAYMENT TO HUSBAND. Wife shall pay to Husband the sum of Fifty Thousand
Two Hundred Forty-Three ($50,243.00) Dollars to complete the equitable distribution of the parties'
property. The payment will be made in cash or cash equivalent and shall be treated by both parties as
equitable distribution of marital property. Wife shall make the payment to Husband at the time that
Husband or his attorney delivers the deed to the marital residence in accordance with this agreement.
10. PERSONAL PROPERTY. The parties hereto mutually agree that they have effected a
11 satisfactory division of the furniture, household finnishings, appliances, and other household and personal
property between them and they mutually agree that each party shall, from and after the date hereof, be the
sole and separate owner of all such tangible personal property presently in his or her possession, whether
-4-
said property was heretofore owned jointly or individually by the parties hereto, and this agreement shall
have the effect of an assignment or receipt from each party to the other for such property as may be in the
individual possessions of each of the parties hereto, the effective date of said bill of sale to be
contemporaneous with the date of the execution of this Agreement.
11. WAIVER OF FURTHER CLAIMS FOR EQUITABLE DISTRIBUTION. The parties
acknowledge that each of them have had a full and ample opportunity to consult with counsel of their
choice regarding their claims arising out of the marriage and divorce and that they have specifically
reviewed their rights to the equitable distribution of marital property, including rights of discovery, the
right to compel a filing of an Inventory and Appraisement, and the right to have the court review the assets
and claims of the parties and decide them as part of the divorce action. Being aware of those rights, and
being aware of the marital property owned by each of the parties, the parties hereto, in consideration of the
other terms and provisions of this agreement, do hereby waive, release and quitclaim any further right to
have a court or any other tribunal equitably distribute or divide their marital property and do hereby
further waive, release and quitclaim any and all claim against or interest in assets now currently in the
possession or held in the name of the other, it being their intention to accept the terms and provisions of
this agreement in full satisfaction of all of their claims to the marital property of the parties and the
equitable distribution of the same.
12. WAIVER OF ALIMONY, SPOUSAL SUPPORT AND ALIMONY PENDENTE LITE.
The parties acknowledge that they are aware of the income, education, income potential, and assets and
holdings of the other or have had full and ample opportunity to become familiar with such items. Both
parties acknowledge that they are able to support and maintain themselves comfortably, without
contribution from the other beyond that as provided for in this Property Settlement Agreement, upon the
income and assets owned by each of them. The parties hereby accept the mutual covenants and terms of
this Agreement and the benefits and properties passed to them hereunder in lieu of any and all further
rights to support or alimony for themself, counsel fees, and alimony pendente lite at this time and during
any and all further or future actions of divorce brought by either of the parties hereto and the parties do
hereby remise, release, quit claim, and relinquish forever any and all right to support, alimony, alimony
pendente lite, counsel fees and expenses beyond those provided for herein, during the pendency of or as a
-5-
result of any such actions, as provided by the Divorce Code of Pennsylvania or any other applicable
statute, at this time and at any time in the future.
13. WAIVER OF FURTHER PROCEEDINGS BEFORE THE COURT. The parties hereby
represent that they have agreed to the foregoing division or distribution of property in an effort to resolve
all disputes relating to their marital property and obligations and to make an equitable distribution of their
marital property as contemplated by the Divorce Code of Pennsylvania. The parties acknowledge that
they have the right to ask a court of appropriate jurisdiction to make equitable distribution of their marital
property and to engage in formal litigation to have the court do so. Because of the division or distribution
of marital property to which they have agreed, as provided for in this Property Settlement Agreement, and
knowing their rights to have the court equitably distribute or divide their marital property following
litigation by the parties, the parties hereto do hereby waive and release any right to have the court make
such equitable distribution or for them to litigate any claims relating to equitable distribution in the
divorce action contemplated by the parties.
14. WAIVER OF ESTATE RIGHTS. Husband releases his inchoate intestate rights in the
estate of Wife and Wife releases her inchoate intestate rights in the estate of Husband, and each of the
parties hereto by these presents for himself or herself, his or her heirs, executors, administrators, or
assigns, does remise, release, quit claim, and forever discharge the other party hereto, his or her heirs,
executors, administrators, or assigns, or any of them, of any and all claims, demands, damages, actions,
causes of action or suits of law or in equity, of whatsoever kind or nature, for or because of any matter or
thing done, omitted, or suffered to be done by such other party prior to the date hereof; except that this
release shall in no way exonerate or discharge either party hereto from the obligations and promises made
and imposed by reason of this agreement and shall in no way affect any cause of action in absolute divorce
which either party may have against the other.
15. WAIVER OF OTHER PROPERTY CLAIMS AND ESTATE CLAIMS. Except as
herein otherwise provided, each party hereto may dispose of his or her property in any way, and each party
hereby expressly 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, the right to equitable division of marital
property, alimony, alimony pendente lite, and counsel fees, except as provided for otherwise in this
-6-
Agreement, dower, curtesy, statutory allowance, widow's allowance, right to take in intestacy, right to take
against the will of the other, and right to act as administrator or executor of the other's estate, and 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 interests,
rights, and claims.
16. DEBTS. The parties hereto mutually represent to the other than neither of them has
incurred any debts in the name of the other not previously disclosed or provided for in this agreement.
Each of the parties hereby represents to the other that neither one of them have incurred or contracted for
debts in the name of the other or for which the other is or would be legally liable from and after the date of
the parties' separation. Both parties hereto mutually agree and promise that neither will contract or
otherwise incur debts in the other's or joint names without the prior permission and consent of the other
party hereto. Both parties hereto represent and warrant to the other party that they have not so contracted
any debts unbeknownst to the other up to the time and date of this Agreement.
17. DISCLOSURE. Both of the parties hereto represent to the other that they have made full
disclosure of the assets and income and income sources owned, controlled, or enjoyed by either of them
and that neither party hereto has withheld any financial information from the other. Each of the parties
represents that they have reviewed such information, as well as the law of Pennsylvania as it relates to
their rights, obligations, and claims arising out of their marriage and of any divorce action which has or
may be filed between the parties with an attorney of their choice, or had the opportunity to review such
matters with an attorney of their choice and voluntarily decided not to do so. Further, the parties each
acknowledge that they are aware that they have the right to compel the other party to provide full financial
information about all assets owned by either party and all liabilities owed by either party and have the
right to have a court force such disclosure in a divorce action. Being aware of those rights, the parties
expressly waive the right to further disclosure or discovery regarding marital assets, liabilities, incomes,
and finances and agree that they are satisfied with their understanding of their legal rights and obligations.
Being so aware and satisfied, the parties mutually accept the terms and provisions of this agreement in full
satisfaction of any and all rights or obligations arising of their marital status or the divorce action now
pending or to be filed between them.
-7-
18. CONCLUSION OF DIVORCE. The parties acknowledge that this agreement is made in
contemplation of the conclusion by both of them of an action in divorce which has been filed or will be
filed shortly by one of the parties hereto. Both of the parties hereto agree that they shall,
contemporaneously with the execution of this agreement, execute and deliver to their respective attorney
or attorneys, an Affidavit of Consent under Section 3301(c) of the Divorce Code, consenting to the entry
of a final decree in divorce, and a Waiver of further notice for the entry of such decree. Both parties agree
that they shall accept the terms and provisions of this agreement in full satisfaction of any claims they may
have under the Divorce Code of the Commonwealth of Pennsylvania, including, but not limited to,
alimony, alimony pendente lite, counsel fees, equitable distribution, and the like.
19. BREACH. In the event that any of the provisions of this agreement are breached or violated
by either of the parties, the other party shall be entitled to enforce this agreement by an appropriate action
in law or in equity or to take any other action to which they are lawfully entitled to enforce this agreement
or otherwise protect their rights. In the event that such action is commenced by one of the parties and the
other party is found to have breached or violated any of the terms and provisions of this agreement, the
party having so violated or breached the agreement, shall be responsible for and shall promptly pay upon
demand the reasonable attorney's fees incurred by the other party to enforce their rights hereunder.
20. RELEASE. Each party does hereby waive, relinquish, and release any claim they have
against the other for bank accounts, stocks, bonds, and other and similar investment assets which are now
owned by or in possession of the other, regardless of whether such assets were owned by the parties
jointly or separately prior to the date of this agreement. Each party hereto does hereby waive and release
any claim they may have under the laws of the Commonwealth of Pennsylvania for the equitable
distribution or the other division of such assets or any claim to them as marital property.
21. CHOICE OF LAW. This Agreement shall be interpreted, applied and enforced in
accordance with the laws of, and by the courts of, the Commonwealth of Pennsylvania.
22. SEVERABILITY. If for any reason whatsoever any part of this Agreement shall be declared
void or invalid, only such part shall be deemed void and in all other respects this Agreement shall remain
valid and fully enforceable.
-8-
23. NON-WAIVER. The waiver of any term, condition, clause, or provision of this Agreement
shall in no way be deemed or considered a waiver of any other term, condition, clause or provision of this
Agreement.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first
above written.
r
Witness
Witn s
ANDREW S. GASSAWAY
JE IFER M. GASSAWAY
-9-
COMMONWEALTH OF PENNSYLVANIA )
( SS.:
COUNTY OF CUMBERLAND )
On this, the 2°1 day of A ?guS k , 2008, before me, the undersigned officer, personally
appeared ANDREW S. GASSAWAY known to me (or satisfactorily proven) to be the person whose
name is subscribed to the within instrument, and acknowledged that said person executed same for the
purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
LY."'. 92n?A
My Commission Expires:
0" EWU4 4,
Um M1r00?OM Alm.
COMMONWEALTH OF PENNSYLVANIA )
( SS.:
COUNTY OF CUMBERLAND )
On this, the /0Oday of NSY-kv- m 2008, before me, the undersigned officer, personally
appeared JENNIFER M. GASSAWAY known to me (or satisfactorily proven) to be the person whose
name is subscribed to the within instrument, and acknowledged that said person executed same for the
purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
My
Notarial Seal
Karen A Sheriff, Notary Public
Palmyra 6oro, Lebanon Cotx*
My Commisslon Expires May 16, 2010
Member, Pennsylvania Association of Notaries
-10-
EXHIBIT A
NAME SHARES
IBM 8
MAY COMPANY S&C NOW MACY'S 80
MERCK 93
MEDCO 24
PNC 26
WALMART 0
LUCENT - NOW ALCATEL LUCENT 79
AGERE - NOW LSI 24
AVAYA - SOLD TO PRIVATE CO 0
CIRCUIT CITY 222
CAR MAX 57
DAIMLER CHRYSLER 0
INTEL 387
JOHNSON & JOHNSON 0
NORDSTROM 240
PEPSI 0
YUM 25
CROWN CRAFTS 104
-11-
ANDREW S. GASSAWAY,
Plaintiff
vs.
JENNIFER M. GASSAWAY,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 05-867
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 16
February 2005 and served upon the Defendant within thirty days thereafter.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of both the filing and service of the complaint.
3. 1 consent to the entry of a final decree in divorce after service of a Notice of
Intention to Request Entry of the Decree.
WAIVED OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. 1 consent to the entry of a final decree in divorce without notice.
2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's
fees, or expenses if I do not claim them before a divorce is granted.
3. 1 understand that I will not be divorced until a divorce decree is entered by the court
and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this Affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating
to unsworn falsification to authorities.
011
0'&)r A/ 2 97
Dated: Andrew S. Gassaway
-t
'r?' --.f
.. .?
ANDREW S. GASSAWAY,
Plaintiff
VS.
JENNIFER M. GASSAWAY,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 05-867 CIVIL TERM
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). rp
2. Date and manner of service of the Complaint: I(c ? ?5 ? L'?' :PVA In :Z;
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: 13 Ckjt)b%e7AR7K by Defendant: 10 September 2008
(b) (1) Date of execution of the Affidavit required by Section 3301(d) of the Divorce Code:
(2) Date of filing and service of the Defendant's Affidavit upon the Respondent:
4. Related claims pending: None
5. Complete either (a) or (b):
(a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit
Record, a copy of which is attached:
(b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: filed contemporaneously with this Praecipe. Date Defendant's Waiver of Notice in
Section 3301(c) Divorce was filed with the Prothonotary: 23 September 2008
Date: 4 B
t'dnijel L. ndes
Attorney for Plaintiff
t,
T-A
-c'
cn
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
ANDREW S. GASSAWAY,
Plaintiff
VERSUS
JENNIFER M. GASSAWAY,
Defendant
No. 2005-867 CIVIL TERM
DECREE IN
DIVORCE
AND NOW,
DECREED THAT
AND
ANDREW S. GASSAWAY
-- 3: 3?•rn .
7008, IT IS ORDERED AND
JENNIFER M. GASSAWAY
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;
PROTHONOTARY
NONE
? ? .a?,?
? ??' °/
?o ??.-o/
r,
?, .. M
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ANDREW S. GASSAWAY,
Plaintiff
v.
JENNIFER M. VOGEL,
Defendant
No. 05-867
Petition for Contempt
1. Petitioner is Plaintiff ANDREW S. GASSAWAY, who currently resides at 19
Round Ridge Road, Mechanicsburg, Cumberland County, PA 17055.
2. Respondent is Defendant, JENNIFER M. VOGEL, who currently resides at 1
Tannenbaum Circle, Dillsburg, Cumberland County, PA 17019.
3. Petitioner and Respondent are the natural parents of the following child:
Name
BRIAN W. GASSAWAY
Age
15 years
4. A custody order was entered on 03/28/05, in the Cumberland County Court of
Common Pleas. A copy of the custody order is attached.
5. Respondent has willfully violated the custody order, as follows: Jennifer has
attempted to make major medical decisions for my son Brian without discussing and consulting
with me first. In Feb, I was notified by a school counselor that Jennifer had set up a meeting to
discuss Brian's performance. The school counselor contacted me to find out if I wanted to attend
since this meeting was set up without my knowledge. Shortly thereafter, I was notified by my son
Brian that Jennifer had taken him to the doctor to change his medication. Both meetings were
scheduled without my knowledge and while I was in Florida for five days. In July, I received a
call from Brian's pediatrician's office. They notified me that we(Jennifer and I) should contact a
psychiatrists to explore other medical options regarding his treatment. I asked Jennifer about the
call and she indicated that I missed nothing. Despite my numerous pleas to be involved she went
irr3.0 I k ccc
P- 309j o
Petition for Contempt Page 3 of 5
ahead and scheduled an appointment with a psychiatrist. My rights as Brian's father have been
compromised based on Jennifer's continued quest to seek medical treatment for Brian while
refusing to consult with me first. .
WHEREFORE, Petitioner respectfully requests that this Court find Respondent in
contempt of Court.
Date: Uh'i
ANDREW S. GASSAWAY, Plaintiff
Verification
I, ANDREW S. GASSAWAY, Plaintiff, verify that the facts stated in the foregoing
Petition are true and correct to the best of my knowledge, information and belief. Petitioner
understands that false statements therein are subject to the penalties of 18 Pa. C.S.A. §4904
relating to unsworn falsification to authorities.
Date: 7 /211/1
Oa �
ANDREW S. GASSAWAY, Plaintiff
Petition for Contempt Page 4 of 5
Andrew S. Gassaway,
Respondent, Plaintiff
v.
Jennifer M. Gassaway,
Petitioner, Defendant
IN THE COURT OF COMMON P 03
EAS 2 Z®�
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 05-867 CIVIL TERM
: CIVIL ACTION — CUSTODY
CUSTODY STIPULATION
The parties stipulate to the attached Court Order.
Date
7,)/0
Andrew S. Gassaway
3
1�:s'IG� rK
Date Jennifer M. Gassaway
Andrew S. Gassaway, : IN THE COURT OF COMMON PLEAS
Respondent, Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 05-867 CIVIL TERM
Jennifer M. Gassaway, : CIVIL ACTION — CUSTODY
Petitioner, Defendant
CUSTODY ORDER
AND NOW, This day of '1 ' LUUS . , 2005
upon consideration of the attached stipulation by the parties displaying
agreement of the parties hereto, the following is Ordered and Directed:
1. The mother, Jennifer M. Gassaway, and the father, Andrew S.
Gassaway, shall enjoy shared legal custody of children, Nicholas A. Gassaway,
born November 8, 1992, Christopher D. Gassaway, born October 27, 1994,
Thomas M. Gassaway, born May 13, 1996 and Brian W. Gassaway, Born
October 20, 1998. Major decisions concerning their children, including, but not
necessarily limited to, the children's health, welfare, education, religious training
and up bringing shall be made by them jointly, after discussion and consultation
with each other, with a view toward obtaining and following a harmonious policy
in the children's best interest. Each party shall not impair the other party's rights
to shared legal custody of the children. Each party shall not alienate the
affections of the children from the other party. Each party shall notify the other of
an activity or circumstance concerning their children that could reasonably be
expected to be of concern of the parent then having physical custody. With
regard to any emergency decisions which must be made, the parent having
physical custody of the children at the time of emergency shall be permitted to
make any immediate decisions necessitated thereby. However, that parent shall
inform the other of the emergency and consult with him or her as soon as
thereafter possible. Each party shall be entitled to complete and full information
from any doctor, dentist, teacher, professional or authority and to have copies of
any reports given to either party as a parent.
2. Primary physical custody of the children shall be in the mother.
3. The father shall have the following periods of partial custody:
a. Every other weekend beginning Friday at 5:15 PM to Sunday at
5:15PM;
b. One overnight evening during the week (Wednesday) from the
conclusion of the Wednesday school day until the beginning of the
Thursday school day.
4. The holiday custody schedule shall be as follows:
The holidays are defined as New Year's Eve/New Year's Day, Easter, Memorial
Day, July 4th, Labor Day, Thanksgiving, Christmas Eve and Christmas Day and
the day after Christmas.
Mother shall always have custody of the children New Years Eve from
5:15p.m. through New Year's Day to 5:15p.m. When New Year's Day occurs on
a Friday, Saturday, Sunday or Monday, mother shall have custody of the children
the entire New Year's weekend.
Memorial Day and its attendant weekend shall be dedicated to mother
who shall always have custody of the children for the entire Memorial Day
weekend.
July 4th and Labor Day holidays and their attendant weekends shall be
dedicated to the father who shall always have custody of the children for these
weekends and holidays.
The following holidays shall alternate and rotate: Thanksgiving, Christmas
and Easter.
Mother shall have custody of the children Thanksgiving Eve, 2005, from
5:15p.m. to Thanksgiving Day at 12:OOp.m. (noon) and father shall have custody
of the children from Thanksgiving Day from 12:OOp.m. (noon) through Sunday at
5:15p.m. or Monday at 5:15p.m. when Monday is part of the Thanksgiving school
holiday.
Mother shall have custody of the children Christmas Eve 2005 from the
time the children awaken on Christmas Eve to Christmas Day at noon and Father
shall have custody of the children from Christmas Day noon time to the next day
until 5:15PM.
Mother shall have custody of the children from 5:15p.m. the Eve of Easter.
2006, until Easter Day at 12:OOp.m. (noon); father shall have custody of the
children from Easter Day at noon until 5:15p.m. or Monday at 5:15p.m. when
Monday is part of the Easter school holiday.
This schedule shall rotate and alternate on a yearly basis.
5. Mother shall have physical custody of the children from 8:OOAM until
8:OOPM on Mother's Day and Father shall have physical custody of the children
from 8:OOAM until 8:OOPM on Father's Day
6. For each of the children's Birthday, the non-custodial parent shall have
custody of the birthday child for a period of 2 hours for either breakfast or dinner.
7. Exchange of custody shall occur at the custodial parents residence,
unless other arrangements are made and agreed to by both parties for an
alternate place for the exchange of custody. The party receiving custody of the
children shall provide the transportation.
8. Neither parent shall do or say anything which may estrange the children
from the other parent, injure the opinion of the children as to the other parent or
hinder the children's free and natural development of the children's love and
respect for the other parent.
9. The custodial parent shall inform the non-custodial parent immediately
of all medical appointments and all problems pertaining to the children.
10. Both parents shall have liberal and reasonable telephone contact with
the children when the children are in the custody of the other parent. Each party
shall have two (2) consecutive or non consecutive vacation weeks with their
children; each party shall provide the other parent 30 days advance -written notice
of the vacation plans, destination and telephone number where children can be
reached in the event of an emergency.
11. Both parties may alter this schedule as they may agree; however, if the
parties cannot agree, the schedule outlined in this order shall control.
12. This order is entered pursuant to the agreement of the parties in this
matter and in the event either party desires to modify this order, that party may
petition the court to have the case again scheduled with the court pursuant to
applicable law.
.!., COPY FROM RF'' E
._..::y whe eof, 1 here unto f,s, .. : y hard
•<<::. s,ai of S. id Cl; rt a Carlisle, Pa.
P?othonotary
By the Court,
417 0JB
ANDREW S. GASSAWAY
PLAINTIFF
V.
JENNIFER M. VOGEL
DEFENDANT
IN THE COURT OF COMMON PLEAS Oe
•
• CUMBERLAND COUNTY, PENNSYL�l IA c d- ;,
=rn C m-
z.'J r-- -, r.,.
2005-867 CIVIL ACTION LAW �r- w Vit:
r —IC)
IN CUSTODY ?.C -"CD --c; Ca '
-�,.
D r t'1
,...< --
ORDER OF COURT
AND NOW, Thursday, July 31, 2014 , upon consideration of the attached Complaint, it is
hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator,
at 4th Floor , Cumberland County Courthouse, Carlisle on Friday, August 29, 2014 8:30 AM
for a Pre -Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this
cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure
to appear at the conference may provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief
orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
You must file with the Court a verification regarding any criminal record or abuse history regarding you and
anyone living in your household on or before the initial in-person contact with the court (including, but not limited to,
a conference with a Judge or custody conciliator) but not later than 30 days after service of the complaint or petition.
No party may make a change in the residence of any child which significantly impairs the ability of the other party
to exercise custodial rights without first complying with all of the applicable provisions of 23 Pa.C.S. §5337 and
Pa.R.C.P. No. 1915.17 regarding relocation.
FOR THE COURT,
By: /s/
Hubert X. Gilroy, Esq. r
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with
Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled
individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior
to any hearing or business before the court. You must attend the scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN
ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
Ce'- /41/Ced
11(
‘I)eP
C I /boyeky
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
HENRY&DEBON,LLC
Gregory D. Henry, Esquire f r ry
Attorney I.D. No.. 57640 '° < :, '0�.
635 Walnut Street
Reading, PA ig6oi
(61o) 376-7411
ANDREW S. GASSAWAY, IN THE COURT OF COMMON PLEAS
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
V.
2005-867 CIVIL ACTION- LAW
JENNIFER M.VOGEL,
Defendant IN CUSTODY
TO THE PROTHONOTARY:
ENTRY OF APPEARANCE
Please enter my appearance on behalf of Jennifer M.Vogel, Defendant in the above-
captioned action.
I designate 635 Walnut Street, Reading, PA 196ol as the place within the
Commonwealth where papers,process and any gi)4fly notices ma be served.
Date: BY:
A ( —�
e nry, Esquire
Attorney for Defendant
ANDREW S. GASSAWAY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v: 2005-867 CIVIL ACTION - LAW
JENNIFER M. VOGEL,
Defendant : IN CUSTODY
COURT ORDER
AND NOW, this x, day of September, 2014, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed that the appointment of a Custody Conciliator in this case
is vacated. In the event either party wants to bring any issues before the Court in the future, that party
may file the appropriate petition with the Court.
cc: . Andrew S. Gassaway
Gregory D. Henry, Esquire
Co? CeS frLj
toPY
BY THE COURT
Judge
CC)
rri
cri
c:c)
ANDREW S. GASSAWAY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v : 2005-867 CIVIL ACTION - LAW
JENNIFER M. VOGEL,
Defendant IN CUSTODY
PRIOR JUDGE: The Honorable Edgar B. Bayley
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report:
The Conciliator conducted a conciliation conference in the above matter on August 29,
2014. There was a discussion about the Plaintiff withdrawing his Petition at the
conciliation conference, and the Conciliator received a September 2, 2014, letter from
the Plaintiff indicating he was withdrawing his Petition.
2. The Conciliator recommends an Order in the form as attached.
Date: September
, 2014
Hubert Gilroy, Esquire
Cust y Conciliator