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HomeMy WebLinkAbout05-3676EDWARD G. WONSOCK, PLAINTIFF V. CHRISTINE B. WONSOCK, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005 - 36-7CIVIL TERM IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator's Office, Fourth floor, Cumberland County Courthouse, Hanover and High Streets, 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 NOTICE QFF AVAILABILITY 9F COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(c) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. EDWARD G. WONSOCK, PLAINTIFF V. CHRISTINE B. WONSOCK, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005 - 3(17G CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE 1. The Plaintiff is Edward G. Wonsock who resides at 69 Creekbank Drive, Mechanicsburg, Cumberland, Pennsylvania 17050. 2. The Defendant is Christine B. Wonsock who resides at 7400 - 32nd Court, Vero Beach, FL 32967. 3. The Plaintiff has been a bonafide resident of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 24, 1982 in Bethesda, Montgomery County, Maryland. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. There were no children born of this marriage. 9. The Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 10. Plaintiff requests the court to enter a decree of divorce. /h 2) - )wJOtr.CdL Thomas D. Gould Attorney for Plaintiff I.D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Date: 7-I(T 6?5' 4rV4 Wonsock u, N C7 n d EDWARD G. WONSOCK, PLAINTIFF V. CHRISTINE B. WONSOCK, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005 - 3676 CIVIL TERM IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in October 1995 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Date: DWARD G. WONSOCK ? o O 't3 tii`- G mr IZI f.: ? yy W -G F TF ESI ATAAILE1GmvahCurcentM 1752.1 Pal C,.d 9/20104 0 06PM Revised. 8R2I05 LUPM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant EDWARD G. WONSOCK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 05-3676 CIVIL ACTION - LAW CHRISTINE B. WONSOCK, Defendant IN DIVORCE PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTSON DEARDORFF WILLIAMS & OTTO on behalf of Defendant in the above matter. Dated: ? I R1 b? MARTSON DEARDORFF WILLIAMS & OTTO By Je ifer ars, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Thomas D. Gould, Esquire 2 East Main Street Shiremanstown, PA 17011 MARTSON DEARDORFF WILLIAMS & OTTO ncia D. Eckenroad Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: (? /p n x-? =iti ? n °r .,? ? ? =t? } `L '? t.,3 ?Y , ? . f? ? ` l1 ??'4? - ` ?: .. y a , :f `:: N ?'a P\PILES\DATA ILE\G er l\Curtant\11952.1..,1a Crcmtt 9/20/04 0:06PM Revleed. 8123/05 3:35PM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant EDWARD G. WONSOCK, Plaintiff V. CHRISTINE B. WONSOCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3676 CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S ANSWER PLAINTIFF'S COMPLAINT WITH COUNTER CLAIM 1- 10. Pursuant to Pennsylvania Rule of Civil Procedure 1920.14, an answer to the allegations of an action for divorce is not required, and such allegations are deemed denied. COUNT II REQUEST FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502(A) OF THE DIVORCE CODE 11. The prior paragraphs of this Answer and Counterclaim are incorporated herein by reference thereto. 12. Defendant requests the Court to equitably divide, distribute or assign the marital property between the parties without regard to marital misconduct in such proportion as the Court deems just after consideration of all relevant factors. WHEREFORE, Defendant respectfully requests the Court to enter an order of equitable distribution of marital property pursuant to Section 3502(a) of the Divorce Code. COUNT III REQUEST FOR SPOUSAL SUPPORT AND/OR ALINIONY PENDENTE LITE AND ALIMONY UNDER SECTIONS 3701 (A) AND 3702 OF THE DIVORCE CODE 13. The prior paragraphs of this Answer and Counterclaim are incorporated herein by reference thereto. 14. Defendant is unable to sustain herself during the course litigation. 15. Defendant lacks sufficient property to provide for her reasonable needs and is unable to sustain herself through appropriate employment. 16. Defendant requests the Court to enter an award of spousal support and/or alimony pendente lite until final hearing and thereupon to enter an order of alimony in her favor pursuant to Sections 3701(a) and 702 of the Divorce Code. WHEREFORE, Defendant respectfully requests the Court to enter an award of spousal support and/or alimony pendente lite until final hearing and thereupon to enter an order of alimony in her favor pursuant to Sections 3701(a) and 3702 of the Divorce Code. COUNT IV REQUEST FOR COUNSEL FEES. COSTS AND EXPENSES UNDER SECTIONS 3104(A)(1), 3323(B) AND 3702 OF THE DIVORCE CODE 17. The prior paragraphs of this Answer and Counterclaim are incorporated herein by reference thereto. 18. Defendant has employed Jennifer L. Spears, Esquire, to represent her in this matrimonial cause. 19. Defendant is unable to pay her counsel fees, costs and expenses and Plaintiff is more than able to pay them. 20. Plaintiff is employed and has the ability to pay Defendant's counsel fees, costs and expenses. 21. Reserving the right to apply to the Court for temporary counsel fees, costs and expenses prior to final hearing, Defendant requests that, after final hearing, the Court orders Plaintiff to pay Defendant's reasonable counsel fees, costs and expenses. WHEREFORE, Defendant respectfully requests that, pursuant to Sections 3104(a)(1), 3323(b) and 3702 of the Divorce Code, the Court enter an order directing Plaintiff to payDefendant's reasonable counsel fees, costs and expenses. COUNT V REQUEST FOR CONTINUED MAINTENANCE AND BENEFICIARY DESIGNATIONS OF EXISTING POLICIES INSURING LIFE OF COUNTERCLAIM-DEFENDANT UNDER SECTION 3502(D) OF THE DIVORCE CODE 22. The prior paragraphs of this Answer and Counterclaim are incorporated herein by reference thereto. 23. During the course of the marriage, Plaintiff has maintained certain life insurance policies for the benefit of Defendant. 24. Pursuant to Section 3502(d), Defendant requests Plaintiff be directed to continue maintenance of said policies for the benefit of Defendant. WHEREFORE, Defendant respectfully requests that, pursuant to Section 3502(d) of the Divorce Code, the Court enter an order directing Plaintiff to continue to maintain certain life insurance policies for the benefit of Defendant. COUNT VI REQUEST FOR APPROVAL OF ANY SETTLEMENT AGREEMENT AND INCORPORATION THEREOF IN DIVORCE DECREE UNDER SECTIONS 3104(A)(1) AND (3) AND 3323(B) OF THE DIVORCE CODE 25. The prior paragraphs of this Answer and Counterclaim are incorporated herein by reference thereto. 26. The public policy of the Commonwealth of Pennsylvania encourages parties to a marital dispute to negotiate a settlement of their differences. 27. While no settlement has been reached as of the date of the filing of this Answer and Counterclaim, Defendant is and has always been willing to negotiate a fair and reasonable settlement of all matters with Plaintiff. 28. To the extent that a written settlement agreement. might be entered into between the parties prior to the time of hearing on this Answer and Counterclaim, Defendant desires that such written agreement be approved by the Court and incorporated in any divorce decree which may be entered dissolving the marriage between the parties. WHEREFORE, if a written settlement agreement is reached between the parties prior to the time of hearing on this Answer and Counterclaim, Defendant respectfully requests that, pursuant to Sections 3104(a)(1) and (3) and 3323(b) of the Divorce Code, the Court approve and incorporate such agreement in the final divorce decree. MARTSON DEA -RDORFF WILLIAMS & OTTO By Jenni er . Sp ,ars, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Date: ?IzvS VERIFICATION Jennifer L. Spears, Esquire, ofthe firm ofMARTSON DEARDORFF WILLIAMS & OTTO, attorneys for Defendant in the within action, certifies that the statements made in the foregoing Answer with Counter Claim are true and correct to the best of her knowledge, information and belief. She understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. Ti? jo - Jei. Spears, Esquire CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Answer with Counter-Claim was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Thomas D. Gould, Esquire 2 East Main Street Shiremanstown, PA 17011 MARTSON DEARDORFF WILLIAMS & OTTO y cia D. Eckenroad n East High Street Carlisle, PA 170,13 (717) 243-3341 Dated: August 26, 2005 l ? Fv ? \ v w G w P. \BLES\DATAPILE\Gen.[\Curtent\11752.1-at8davit I QewM 9/20/N 0 '.06PM Rev cd: 8/22/05 1.26PM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant EDWARD G. WONSOCK, Plaintiff V. CHRISTINE B. WONSOCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3676 CIVIL ACTION - LAW IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE Check either (a) or (b): > (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-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 unswom falsification to authorities. Date:?cW OKA Jennifer . S ars, Esquire Attorney or Defendant Christine B. Wonsock NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you should not file this counter-affidavit. a c? ,a S" , ?. -n ms- nJ l? j.? ? ? f ??-- -y} - ? 1`YI pl `?? ? ' J :. ClJ EDWARD G. WONSOCK, Plaintiff V. CHRISTINE B. WONSOCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3676 CIVIL ACTION - LAW IN DIVORCE I l tl S (.u' el-j iy1 DEFENDANT'S INTERROGATORIES DIRECTED TO PLAINTIFF TO: EDWARD G. WONSOCK, Plaintiff, and his attorney, Thomas Gould, Esquire Enclosed are Interrogatories propounded by Defendant to be answered under oath by the aforesaid Plaintifl'pursuant to Pa. R. C P. No. 4005, within thirty (30) days from the date of service hereof. A copy of said Answers shal I be served upon counsel for Plaintiff at the address below. These Interrogatories shall be deemed to be continuing Interrogatories and if, between the time of your Answers to said Interrogatories and the time of trial of this case, you or anyone acting in your behalf learn of any further information not contained in your said Answers, you shall promptly im-nish said information to the undersigned by supplemental answers. References to Plaintiff and/or Defendant shall be interpreted as singular or plural, depending upon the particular circumstances of each case. The term "description" or "describe" as used herein shall mean that the Defendant shall set forth the name and address of the author or originator, dates, title or subject matter, the present custodians of the original and of any copies and the last known address of' each custodian. "Document" shall mean any written, printed, typed or other graphic matter of any kind, whether handwritten, typed or printed, whether distributed or undistributed. It shall include without limitation letters, memoranda, articles, studies, notebooks, diaries and notes, as well as all mechanical and electronic sound recordings or transcripts thereof in the possession or control of the defendants or KllO r. all also „f d`J., en S by nIgo, r-rr it is marl Wn by them to exist. ti Shau alov mean all cOpi„o whw% e; the subject matter and substance of the communication; and the identity of any document or writing which embodies, records, reflects, or otherwise refers to such oral communication. whatever means made. As used herein, the words "identify" or "identity" shall mean the following: a. When used with reference to a natural person, shall mean that the answer shall state in each instance his full name, pres,^nt or last known residence address, and his occupation or business, including the name and address of his present and prior employer, his present and prior employment positions and business affiliations, including the dates of each. When used with reference to any particular person, the information other than the frill name need be given only once. In any instance where you are asked to identify a natural person and you are unable to do so by name, you should so state, and in lieu of the namc, state the job title, department and or division of said person. b. When used with reference to a corporation, partnership, association, joint venture, firm or other business enterprise or legal entity, shall mean that the answer shall state in each instance the full name and address of such entity, its affiliation, including in the case of a corporation, its parent, if any, and in the case of a partnership or joint venture, its partners or members of the venture, and a briefdescription of the primary business in which such entity is engaged. With respect to any particular entity, the information other than the full name need be given only once. C. When used in connection with a writing, document, or report, shall mean that the answer shall state in each instance, whether or not such document is known to he in existence at the dine of making the answer, and (i) the date, type of document (e.g. letter, memorandum, telegram, etc.), author, addresses, and all recipients; (ii) the present or last-known location and custodian of the document and all copies thereof; and (iii) the title and tiling or identifying number of all other means of identifying it with sufficient particularity to satisfy the requirements of its inclusion in a request for production of docmnents pursuant to Rule 4009 of the Pennsylvania Rules of Civil Procedure. d. When used in connection with an oral communication, shall mean that the answer shall state in each instance (i) the identities of the persons communicating; (ii) the recipient and intended recipient of the communication; (iii) the identity of each person present or otherwise aware of the substance of the communication; (iv) the date and time when and place where it was made; (v) the subject matter and substance of the communication; and (vi) the identity of any document or writing which embodies, records, reflects, or otherwise refers to such oral communication. e. When used with reference to a contract agreement, or understanding or any modification or amendment thereof shall mean that the answer shall state in each instance (i) the date on which such contract, agreement, or understanding or any modification or amendment thereof was first made or entered into, (ii) the duration of the contract, agreement, or understanding or any modification or amendment thereof; (iii) the identities of the parties to such contract, agreement or understanding or any modification or amendment thereof; (iv) whether the contract, agreement, or understanding or any modification or amendment thereof was oral or written, and if written, (v) the identity of each document that embodies, records, contains or otherwise reflects such contract, agreement or understanding or any modification or amendment thereof. Answer each interrogatory in the space following the interrogatory, Supplemental sheets maybe attached for answers which require additional space. Pleasc take notice that you are required to serve upon the undersigned your answers in writing within thirty (30) days pursuant to the Pennsylvania Rules of Civil Procedure. These Interrogatories are deemed continuing and supplemental answers should reasonably be provided. Unless otherwise specified, response to the following Interrogatories shall gig e the requested information for the period from September 30, 1995, to the present (hereinafter sometimes referred to as the "lime period"). It is hereby certified that a true and correct copy of these Interrogatories was mailed to counsel for the Plaintiff on this date by the undersigned on the below date. Interrogatory No. I State your full legal name, address at which you reside, social security number, date and place of birth., as well as your educational background. Answer: EDWARD G. WONSOCK 69 CREEK BANK DRIVE MECHANICSBURG, PA 17050 SS# 202-28-6587 DOB: 07/22/1937 BORN: MAHANOY CITY, PA EDUCATION: JD UNIVERSITY OF BALTIMORE, 1972 BA UNIVERSITY OF BALTIMORE 1973 Interrogatory No. 2 State the name, age, gender, and relationship to you of each person residing with you. a. Are any of those individuals employed? If so, by whom, and state the amount of his or her annual income. b. Do any of those individuals have any source of income, other than their employment? If so, how much on an annual basis, and from what source? C. Do any o. t1lCSe mdl`.'ldaals ;..,nlrlh?wte to the bn1crbnlrl rxnrncec') ,-- Answer: NONE Interrogatory No. 3 What is the date that you consider the date of separation? a. Please state the facts and circumstances and list any documents that support the establishment of the date you allege to be the separation date. b. Please provide any documents in your possession that support the date you allege to be the separation date. C. Please list the names of all witnesses you intend to call at trial to support the date you allege to be the separation date and indicate the tenor of their testimony. Answer: 1992 a. Wife moved out of the marital home without the intent of returning. Wife moved to Florida to live with parents Wife opened separate accounts in Florida Wife stopped contributing to marital household expenses. Wife stopped sharing marital bedroom & bed Wife ceased sexual relations with Husband Wife has all documents related to her separate accounts Husband has no record of any contributions from wife for marital expenses c. Wife's parents and neighbors and husband's neighbors and co-workers. Interrogatory No. 4 Please fully complete the Income and Expense statement attached to these interrogatories, that is marked Schedule A. Answer: See attached I & E form which was not included with Interrogatories. Interrogatory No. 5 a. b. C. If you have a written contract, please attach. Are you presently employed? (Full and part-time employment included.) If your answer is in the affirmative, state fully for each employment: 1) The full name, address, and telephone number ofyour place of employment. 2) The date you commenced your employment. 3) Your job title or position. Do you have any written or oral employment contracts with your present employer? Answer: Not employed Interrogatory No. 6 Since the date of your marriage to Defendant, did you transfer any property in which you had claimed an interest without receiving fair market value as consideration for the transfer? Answer: No Interrogatory No. 7 Ifso, for each. item ofproperty transferred, state: a. A complete description of the property. b. The name and address of each transferee. C. The reason for the transfer. d. "The amount of consideration received for the transfer. C. Whether the written consent of Plaintiff was obtained for such transfer. f The basis for valuing the asset transferred. Answer: N/A Interrogatory No. ° Ave you entitled to receive any deferred compensation by reason of your present or past employment? Ifso, please state the nature and amount ol'deferred compensation, and when you anticipate receiving such deferred compensation. If the answer is in the affirmative, kindly provide documentation of the deferred compensation plan. Answer: No Interrogatory No. 9 For each of your previous employments (including periods of self-employment) during the past 12 years, please state: a. The name and address of your employer. h. The inclusive dates of employment. C. The nature, title, and description of the work performed. d. The gross annual compensation for each calendar year of such employment. C. The net annual income from such employment. d. If terminated, the reason for termination of your previous employment. Answer: a. Montgomery County Public School Montgomery County, MD b. 0611961 to 1211999 C. Site development coordinator d. Unavailable, but see enclosed tax reurns e. See tax returns G Retired Interrogatory No. 10 a. Does any business or individual or other entity owe you any money, whether resulting from loan, undistributed profit, dividend, or other form of credit, to which you are now entitled or will be entitled in the future? What is the date upon which that debt was incurred? (List dates for all) b. What is the due date for the payment(s) of the aforesaid? Answer: No Interrogatory No_ 1 1 Have you loaned or given money or property having a value in excess of $500.00 to relatives, friends, or anyone else since the date of your marriage to Defendant? Answer: Yes, to Grandchildren Interrogatory No. 12 If so, for each person receiving such money, state: a. The name and address of the person. b. Whether the money was a gift or a loan. C. The total amount loaned or given. d. The date of each loan or gift. C. The reason for each loan or gift. f. A description ol. any consideration or evidence of indebtedness received in exchange for such loan or gift. g. If a loan, detail the amount ofthe obligation, the loan paymerts, and current balance due. Answer: Gift to each grandchild at graduation Sean in 2001 and Brandon in 2004 Interrogatory No. 13 Are you within the past 12 years the owner, individually or with others, of any interest in any securities, or in any mutual fund, including but not limited to, stock funds, money market funds, bonds, municipal bond funds, gold funds, etc.? If so, please list the names of those securities or funds. Answer: Yes T. Rowe Price Fidelity Investment Interrogatory No. 14 If you have disposed of any (marital or nonmarital) property, real or personal, since 1994, having a value in excess of $300.00, detail the following: a. Description of the item, b. When the item was sold, loaned, leased, or gifted, c. What consideration was received by you for the item, d. Where the proceeds of sale were deposited, C. In whose name they were deposited. Answer: a. Condo # 2417 at 5500 Friendship Blvd, Chevy Chase, MD b. 10/2004 C. $475,000.00 d. Net proceeds $330,000.00 divided equally between Husband & Wife e. Each party received their own funds Interrogatory No. 15 List all banks, savings and loans, credit unions, and financial institutions in which you individually, orjointly with another, have or had, from 1994 to the present, an account in which funds are or were held or upon which you had signature. Answer: Bank of America - acct # 7083108742 M & T Bank - acct # 9833888903 Interrogatory No. 16 Do you own or have you owned within the past 12 years, individually or jointly with another, any certificates of deposit, treasury notes, or other depository receipt of any kind? Answer: No Interrogatory No. 17 If you listed a response to the preceding interrogatory, please state: a. In whose names are these documents registered? b. What is the current face value of these instruments'? c. If there is a maturity date I-or these instruments, what are those dates? d. What is the location of these instruments? Answer: N/A Interrogatory No. 18 a. Igo you now or have you at any time since the date of marriage, maintained or had access to a safe deposit box? If so, please detail the contents at the time opened, and the date of separation. b. Detail all items you have removed from the safe deposit box during the six months prior to the date of separation to the present. Answer: No Interrogatory No. 19 Since the date of marriage, have there been accounts at a savings or commercial banking institution, brokerage firm, or any other type of financial institution, on which your name did not appear but in which you deposited any funds? If so, please designate by account number and name of financial institution, and indicate the name(s) under which the account is listed, and for the amounts in those accounts. Answer: No Interrogatory No. 20 If you have removed any funds from any source since the date of your marriage, please respond to the following questions: r ll a, r.ist an GI t u5c sources ` oni a w hiG1. ? you vu have :aitl?dravv- finds; ul , b. What were the dates of these removals? C. Indicate the amount ofthe funds withdrawn from each of the above sources; d. In whose possession and where are those funds? e. In whose name were the funds listed prior to their removal? f. What were the purposes for those withdrawals? Answer: a. Tax free bond acct b. July 2004 C. $120,000.00 d. Wells Fargo Mortgage Company C. Husband f Purchased home Interrogatory No. 21 Does any person, firm, or business entity hold any property for your benefit? Answer: No Interrogatory No. 22 State whether you have during the past 12 years made a gift to any person other than your spouse, in cash or in kind, having a value of $500.00 or more. Answer: No Interrogatory No. 23 a. It' you have any interest in any qualified or unqualified deferred compensation arrangement or retirement program, including, but not limited to, IRA, Keogh Plan, 401(k) Plan, military retirement, savings plan, annuity benefits, retirement plan, pension plan, profit sharing plan, stock bonus plan, stock option plan, or thrift plan, defined benefit, or defined contribution plan (excluding social security benefits), with your present employer, or any previous employer, please designate and indicate the name and type of the retirement plan. t u . 7 . h„ „d , a 4, v. aVe you eleeo receive in cive you ,i,w.,. 11 --1 .CS On. ny .remc.. benefit plan(s) as set forth in 56a above for the period six months prior to the date of separation, to the present? C. Do you have any accumulated vacation, sick, or leave benefits? If so, please detail, d. Have you borrowed against any of the afhrementioned retirement plans`? e. Have you taken any action to delay the receipt of retirement benefits'! Answer: a. Fidelity 401(k) b. No C. No d. No e. No Interrogatory No, 24 Have you filed a financial statement or loan application with any lending or credit institution during the past five years? If so, please name the lending or credit institution, and attach all such financial statements or loan applications to your answers to these Interrogatories, and state the amount, term(s), and purpose(s) of loan. Answer: Yes, to purchase home - Wells Fargo Mortgage Ycs, to purchase land in New Hampshire - M&T Bank Interrogatory No. 25 Since the date of your marriage to the Defendant, did you prepare or have prepared, any records, accounts ,journals, or similar documents showing income, expenses, assets, or liabilities? If so, describe each record and state the name and address of the person having present custody of the record. Answer: No Interrogatory No. 26 List all outstanding debts you are obligated to pay, having a balance in excess of`5300.00 for each debt, including unpaid federal, stale, and local income and real estate taxes, and which have had an outstanding balance for more than thirty days. Answer: Home mortgage Home equity loan Ford Moior Credit Chase Master Card M&TBank $160,000.00 $ 100,000.00 $ in,noo.nn $ 1,000.00 $300,000.00 Interrogatory No. 27 Is it your position that any physical, mental, or emotional disability impairs your earning capacity? Answer: Heart condition Interrogatory No. 28 Please estimate the current market value of your household contents including, but not limited to furnishings, personal effects, or other personal property (excluding jewelry). Answer: Marital none Purchased for new home $20,000.00 Interrogatory No. 29 Do you have any interest in a stamp, coin, wine, toy, sports memorabilia, weapon, vintage automobile, or other collection not described in your answer to the preceding Interrogatory? If so, please describe the type of collection. Answer: No Interrogatory No. 30 Have you received anything of value from any source, including, but not limited to, gilts, judgements, settlements, litigation, devise, bequest, legacies, insurance proceeds, loans, dividends, or interest, not previously set forth in this interrogatory? If so, state: a. Source of fund or property; b. Reason for receipt; C, Amount received; d. When and where received; e. Present location of whatever was received. Answer: a. Father's estate b. Death c. $6,000.00 in real estate d. 1988 e. Located in Mahanoy City, PA Interrogatory No, 31 State the aggregate amount of your cash on hand or in safekeeping, exclusive of savings and checking accounts in banks or savings institutions, and the location of that cash. Answer: None Interrogatory No. 32 Have you taken any vacations during the past five years, including attendance at meetings, conventions, or seminars, in a city other than that of your residence? If so, please state the location and date(s) of the trips. Answer: None Interrogatory No. 33 Do you claim that there is property in existence, whether owned individually or with another person, that is your separate property, and not rnarital property, as defined in the Pennsylvania Divorce Code? If so, for each and every item of such property, state: a. Description of the property. Present location and the name and address of person in possession and the basis for such right of possession. Basis for your contention that it is not marital property. d. What you contend to be the present fair market value of the property and basis of'your answer. e. Description and current amount of each lien, pledge, mortgage, other encurnbrances, or claim against the property. The purchase price and terms of purchase if other than a cash transaction. U. Dale of acquisition. b f. Present location and the name and address of person in possession and the basis for such right of possession. C. Basis for your contention that it is not marital property. d. What you contend to be the present fair market value of the property and basis of your answer. C. Description and current amount of each lien, pledge, mortgage, other encumbrances, or claim against the property. f. The purchase price and terms of purchase if other than a cash transaction. G. Date of acquisition. h. Method of acquisition including the source of funds used to purchase the property. i. The name, address, and relationship to you, if any, of all owners ofreeord of the property. j. Is your ownership interest in that asset recorded in any public record document? If so, please provide full information relative to recordation. Answer: a. Residence - # 328 69 Creek Bank Drive, Mechanicsburg, PA Father's home - 328 W. South Street, Mahanoy City, PA Investment Property - Tamworth, NH b. See above c. Purchased with nonmarital money after separation or inheritance d. Residence $270,000.00 Father's home - none Unknown C. Home mortgage S 160,000.00 Home equity loan $100,000.00 M&T construction loan $ 300,000.00 f Home - $270,000.00 Father's home - $ 12,000.00 - bought out siblings' interest Investment - to be determined g. Home 2004 Father's home 1988 Investment 2005 h. Home - sale ofCondo Father's home - inheritance Investment- purchase wfloan 1. None j. Yes Cumberland County & Schuylkill County COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND Edward Wonsock, being duly sworn according to law, deposes and says that the facts set forth in the foregoing Answers to Interrogatories are true and correct. Edward Wonsock Sworn to and subscribed before me this -A day of dYIC ?CC 2006 ?Lt l t '-?U COMMONWEALTH OF PENNSYLVANIA Notarial Seal Leda M. Gould, Notary Pubic Shiremanstown Bore, Cumberland County My Commission Expires Apr. 29, 2008 Member. PennsyNaniz Assor.Tatlon Ot Notaries -J (?) ?? ^{1 ?:} ? ? ? ? ? ?1 :a C_' -.. ..- . EDWARD G. WONSOCK LN THE COURT OF CO1!VLMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff Vs. CHRISTINE B. WONSOCK9 : Docket No. 05-3676 Defendant MOTION FOR APPOINTMENT OF MASTER CHRISTINE WONSOCK, aril) (Defendant), moves the court to appoint a master with respect to the following claims: Divorce (4Distribution of Property () Annulment (c)CSupport Alimony (x Counsel Fees () Alimony Pendente Lite ?YCosts and Expenses and in support of the motion states: (1) Discovery is complete as to the claims (s) for which the appointment of a master is reque114n (2) The %as) Ajmr*A appeared in the action imay? (by his attorney, Thomas Gould, , Esquire). (3) The Staturory ground (s) for divorce {i (are) irretrievable breakdown (4) Delete the inapplicable paragraph(s): a. The action is not contested. b. An agreement has been reached with respect to the following claims: N/A c. The action is contested with respect to the following claims: See above (5) The action (involves) (does not involve) complex issues of law or fact (6) The hearing is expected to take 4-5 (7) Additional information, if any, relevant to Date: April 9. 2008 Print Attorney Name ......... Jennifer L. Attorney for ki AND NOW, , 20 , is appointed master with respect to the following claims: Esquire By the Court: rs, Esquire IMP?ferAant) (hours) *b9v)x the motion: J. cxa r_ . "TA a APR 17 2008 /r// EDWARD G. WONSOCK Plaintiff : IN THE COURT OF CONLMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Vs. CHRISTINE B. WONSOCKY : Docket No. 05-3676 Defendant MOTION FOR APPOINTMENT OF MASTER CHRISTINE WONSOCK, Oaa ) (Defendant), moves the court to appoint a master with respect to the following claims: 11 Divorce (4Distribution of Property () Annulment ?? Support Alimony (x Counsel Fees (} Alimony Pendente Lite ?YCosts and )expenses and in support of the motion states: (1) Discovery is complete as to the claims (s) for which the appointment of a master is reques (2) The ?a n ' as) AjMAg& appeared in the action f ikjtagy) (by his attorney, Thomas Gould, , Esquire). (3) The Staturory ground (s) for . divorce () (are) irretrievable breakdown (4) Delete the inapplicable paragraph(s): a. The action is not contested. b. An agreement has been reached with respect to the following claims: N/A c. The action is contested with respect to the following claims: See above (5) The action (involves) (does not involve) complex issues of law or fact (6) The hearing is expected to take 4-5 (hours) x (7) Additional information, if any, relevant to the motion: Date: April 9, 2008 Print Attorney Name AND NOW, is appointed master Jennifer L. Attorney for 0 respect to the ronowing ciazms: Esquire By th ourt: cm J. t/1 O e0 C'o C, CIO N WAX r In the Court of Common Pleas of CUMBERLAND Phone: Plaintiff Name: Defendant Name: Docket Number: PACSES Case Number: Other State ID Number: County, Pennsylvania Fax: EDWARD C. WONSOCK CHRISTINE B. WONSOCK 2005-3676 (lease note: AD correspondence must include the PACSES Case `umber. Income and E=nse Statement THIS FORM MUST BE FILLED OUT (If you are self-employed or if you are salaried by a business of which you are owner in whole or part, you must also [ill out the Supplemental Income Statement which appears on page two of this income and expense statement.) INCOME STATEMENT OF CHRISTINE B WONSOCK Section 1: Imome and Imuranc INCOME Employer Retired Federal Police Otti-cpr ?pdi ca i rti Gahi i i t37) Address Type of Work Payroll No. Gross Pay per Pay Period S Pay Period (wkly., bi-wkly., etc.) Federal Withhold' - -S 257.9 Sociat Seen ' S LACAJ Wall* Tax $ State Income Tax S Retirement S Savings Bonds $ Credit Union S Lift Intaraace S Health Tmuranmmedicare $96.40 Other Deductions (specify) S S Net Pay per Pay Period S OTHER (Fit[ in A roriatts Column) INCOME WEEK ;MONTH YEAR tnterest $ $ S Dividends Pension Annuity 18.072 Smial Securit pants Ro attics Expense Actount 6itts Priem iiovment LVi?rkrtu:n's Compensation 4her )ihcr _ -- r0TAL l91':1L INCOME 1 _ S S 1i g 1.089 E TY Ownership ' PROP R OWNED DESCRIPTION VALUE H W J Checking Accounts S Savings Accounts 3 bank CDs 80,000 Credit Union Sticks, imds Real Fatale Other COTAL !$280,000 if liusnand, fib' I =1oint SrrVt':C l".pe %I Penn IN 000 Worker ID _I_t)I Income and Expense Statement PACSES Case Number Section III: Experts Instructions: Only show extraordinary expenses in this section unless you filled out Section It on page two. The categories in BOLD FONT are especially important for calculating child support. If you are requesting Spousal SupporvAPL or if you assert your case cannot be determined according to the guideline grids or formula. this section must he tally completed. (Fill in Appropriate Column) EXPFNSES WEEK MONTH YEAR Homo mortgage/Rent S S S Maintenance t' Electric S S S Gas oil Telephone Water Sewer Employment Public Transport. $ ! S Lunch a Real caste $ $ S Personal Property f race Hotneowner's $ S $ Automobile Lilb Accident He" 96-40 Other Automobile Payments S S S Fuel Repairs Me ica Doctor S S 9r, 5n S Dendst 37.67 Orthodontist Hospital Medicine 30. .Special needs (glasses, braces, orthoudk Y t EXPENSES (Fill in Appropriate Column) (continued) WEEK MONTH YEAR d ca ' Prt•ate Sdww S S ; Pareckidi SckM Collep Ref iota Pvrsomd CClothing s $ n-am s Food Ractia/ Hairdre 137.00 Cmdk Payments Credit Card -Membership Loam credit union S s s mlwellmwus Rousehold Help S S S Child can Ps"rsiboob marazim F.reemioment . Pa Tv Vacation Gifts 20.0 Legal fees grits R n u'll i 20.0 c w ebl wir Swart tmy PwrMeaft Other s s s Total WEEK MONTH YEAR Ex erases: s S $ 1 verify :hat the +uitements made in this Interne and Expense Statement are true and correct. I understand that taise statemcnts herein are ubject to the criminal penalties of 18 Pa. C: S. 3 4V4, relating to ?msworn falsification to authorities. Uute Plaintiff or Defendant Scr-"ce I'\'Pe 1t Page 3 if 3 Form IN008 Worker ID ?i X01 Income and Expense Statement PACSES Case Number Coverage' INSURANCE COMPANY POLICY M H W C Hoe ita Blue Cross Other Medical Btu Shield Other 11ealth/Accident Disability Income Dental Other * H-Husband; W-Wife; C-Child Section II: Supplemental Inatome Statement a. This form is to be filled out by a person C] (1) who operates a business or practices a profession, or n (2) who is a member of a partnership or joint venture, or C] (3) who is a shareholder in and is salaried by a closed corporation or similar entity. b. Attach to this statement a copy of the following documents rotating to the partnership, joint venture, business, profession, corporation or similar entity: (t) the most recent Federal Income Tax Return, and (2) the most recent Profit and Lou Statement C. Name of business: Address and telephone number: d, acute o usiness (clieck one C] (1) partnership (2) joint venture (3) profession (4) closed corporation (5) other C. Name of accountant, controller or other person in charge of financial records: f. Annual income from business: Vii) How often is income received? 1) Gross income per pay period: 1) Net income per pay period: 4} Specified deductions, if any: n. i f3 Fociri IN-008 Service rvpc ?t Worker ID 2;301 r-a '? ?? ?? ?w;, _,,,. ??? .?" ?? t ?; :?c? ? _, .?, ° -.' tit? .r ? ?- - ,? ..-- F:\FILES\Chcnts\11752 Wonsock\l 1752.1invwtorympd Jennifer L. Spears, Esquire MA.RTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. No. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant EDWARD G. WONSOCK, Plaintiff V. CHRISTINE B. WONSOCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3676 CIVIL ACTION - LAW : IN DIVORCE INVENTORY OF DEFENDANT PURSUANT TO Pa. R.C.P. 1920.33(a) Defendant 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. Defendant verifies that the statements made in this inventory are true and correct. Defendant understands that false statements herein are made subject to the penalties of 18 Pa. CS. 4904 relating to unsworn falsification to authorities. Christine B. Wonsock, Defendant Date ? ? ' U ? ? U 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. (X ) 1. Real property ( ) 2. Motor vehicles ( ) 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 () 10. Annuities ( ) 11. Gifts (X) 12. Inheritances ( ) 13. Patents, copyrights, inventions, royalties ( ) 14. Personal property outside the home ( ) 15. Businesses ( ) 16. Employment tennination benefits-severance pay, workers' compensation claim/award ( ) 17. Profit-sharing plans (X ) 18. Pension plans (indicate employee contribution and date plan vests) (X ) 19. Retirement plans, Individual Retirement Accounts (X ) 20. Disability payments ( ) 21. Litigation claims (matured and unmeasured) ( ) 22. MilitaryN.A. benefits ( ) 23. Education benefits ( ) 24. Debts due, including loans, mortgages held (X ) 25. Household furnishings and personalty ( ) 26. Other 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 ( ) 1. Mortgages O 2. Judgments () 3. Liens () 4. Other secured liabilities UNSECURED O 5. Credit card balances O 6. Purchases () 7. Loan payments () 8. Notes payable () 9. Other unsecured liabilities CONTINGENT OR DEFERRED () 10. Contracts or agreements () 11. Promissory notes () 12. Lawsuits () 13. Options O 14. Taxes () 15. Other contingent or deferred liabilities 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 Description Names of Value Number of Property all Owners 1 Mechanicsburg Home Husband (Used money from T. Rowe Price account for down payment) 1 Sale of joint Marital Residence Husband/Wife $164,000.00 (each) 1 New Hampshire Home Husband (Possibly non-marital) 12 328 West South Street, Mahayana City Property Husband (inherited in 1988, then purchased siblings' interest) 18 Aetna Pension - in pay status Husband $60,000.00/year (approx.) 19 Fidelity Husband $270,000.00 (approx. 2003) 19 T. Rowe Price Husband $201,689.00 (approx. 2003) 20 Federal Disability Pension Wife $17,000.00/year NON-MARITAL PROPERTY Defendant lists all property in which a spouse had a legal or equitable interest which is claimed to be excluded from marital property: Item Description Names of Reason for Number of Property all Owners Exclusion 1 New Hampshire property Husband Purchased post-separation Mechanicsburg residence Husband Purchased post-separation with marital assets) 4 Arbor Federal CD Wife Post-Separation 5 Aarbar Federal checking account Wife Post-Separation 6 Aarbar Federal savings account Wife Post-Separation 6 World Savings Bank Money Market Wife Post-Separation 1,12 Mahoney City property Husband Part was bequeathed to Husband's siblings 18 Aetna Pension Husband Pre-marital component 20 Federal Disability Pension Wife Pre-marital component LIABILITIES Item Description Names of all Balance at Number of Liabilities Creditors Separation €?- m ?i --r {? ? i. ? ;?,? ??, -fi° v? _ , ?, ??: , ` ? ?__ ?..? ?, } ?? rya `? ?._ 'z INCOME AND EXPENSE STATEMENT OF G, Yv e>AI 0 Cl-- SSN 4a2 . 2$ - 4097 DR# DATE ,Z 4i-" f 2 a4$ THIS STATEMENT MUST BE FILLED OUT (If you are self-employed or if you are salaried by a business of which you are owner in whole or in part, you must also fill out the Supplemental Income Statement which appears on the last page of this Income and Expense Statement.) INCOME (a) Employer & Address - Job Title/Description Pay Period (weekly, bi-weekly, monthly) Gross Pay per Pay Period .................................................................................................................... $ 4 Payroll Deductions: Federal Withholding $ /- D©op `?° Social Security ...........................$ Local Wage Tax ..........................$ State Income Tax .......................$ Retirement ..................................$ Health Insurance ...-.-.__ ..............$ 341-0111 Other (specify) ............................$ Net Pay per Pay Period .................................... ............... _.................................... (b) Other Income Week Month InterestlDividends ......................$ Pension/Annuity .......... ..............$ VVorkmci's Compensation ........ $- .........................$ Social Security ...........................S Rents/Royalties ..........................S Expense Account .......................$ Gifts .............................................S Unemployment Cosm.pensation.$? ......................... $ $ $ Total, Other Income .......................$ $ $ $ go Z73 INCOME AND EXPENSE STATEMENT OF .ED 4afi9e4 G , yc/®?v'So.G I verity that the statements made in this Income and Expense State- ment are true and correct. I understand that false statements herein are made subject to the penalties of IS Pa.C.S. 4900 relating to unsworn talsification to authorities. 9 . Oahe lZ ?435 r )trQO !'''-°? ta?ntitt or Oetendant 34/. _.$372'/• Year S $ $ S S $ $ $ S Household Week EXPENSES Home ..................................... e/PhwA a Mort $ ... g g Maintenance GD!V '?sz ......•.. S Utilities (telephone, heating electric, etc.) ........................................ $ Employment (transportation, lunches) ............................................... S Taxes Real Estate ............................ $ Personal Property ................................... - $ Income .................................... $ Insurance Homeowners _ ......................................... $ Automobile ................................... _......... S Life/Accident/Health .............................. $ Other ........................................................ S Automobile (payments, fuel, repairs) ................... _............................ $ Medical Doctor, Dentist, Orthodontist r ...... ...... Hospital ................. ...... --................ ......... S Special (glasses, braces, etc.) ............... S Education Private, Parochial School „.................... S College ......................... _.._.......... ............ S Personal Clothing .4 Nj.?......e £Tg. S Food ................. ... .... ..... .._._............... $ Other (household supplies, barber, etc.) ....... _...... _ ......................... $ Credit payments and jgAQs ........ ...... .... S Miscellaneous Household help/child care ................ _... S Entertainment (inc. papers, books, vacation, pay TV, etc.) ..._....... $ Gifts/Charitable contributions ..._......... S Legal Fees ................?......__................ S Other child supportialimony payments ............ ........__ ................... $ Other (specify) .............. ....... „.._............... $ Total Expenses ........... ..._ ._..?......... S Child Week S s Household Month S ?G6g S 2.5D. Child Month S S S S $ S $ $ pO ' $ $ S S . $ S S $ $ 2S $ $ S=-- S s s s- S S S S _ S $ $ $ 225': $ S S S $ $ .2D. $ S s s S $ $ $ --.. S S $ $ Z moo, $ ?57.'?• Z $ $2 -• $ $ $ /OQC7s ', $ $ G/A s $ S S S S S S S -- S S - $ sS??/, s PROPERTY OWNED Description Checking Accounts ........ Savings Accounts ........... Credit Union .................... Stocks/Bonds .................. Real Estate .................... . '9 GE2? AAAI & ...................... Other //J? Total, Property ..................... INSURANCE Company - f? L C ? Hospital ?rJ?l.4 Medical .M.?l?19 S.?RL?!{?AIE??' Health/Accident .............. Disability Income ............ Other (dental, etc.) .......... ('H - Husband, W - Wife, J - Joint, C - Child) Value ate. $ 3 S ? S? S 4 S S S S S 3 Policy No. SUPPLEMENTAL INCOME STATEMENT Ownership' H W J Coverage H W C _- X A. This form must be filled out by a person who (check one): (1) operates a business or practices a profession; or (2) is a member of a partnership or joint venture; or (3) is a shareholder in and is salaried by a closed corporation or similar entity. B. Attach to this statement a copy of the following documents relating to the business, profession, partnership, joint venture, corporation or similar entity. (1) the most recent Federal Income Tax Return, and (2) the most recent Profit and Loss Statement. C. Name and Address -of business: Telephone Number D. Name and Address (if different than C) of accountant, controller or other person in charge of financial records: E. (1) Annual income from business ........................................................... S --- (2) How often is income received? ............ ........................ _.......................... _.... _..... .............. S (3) Gross income per pay period ......... ....................._................._....................................... $ (4) Net income per pay period .... -........._.--..-. ............... ........_................. _......... ...................... S (5) Specific deductions if any .......... ......... ...... ........ ............... ....................... ......_-._........_.... S KNOWN ASSETS OF PARTIES Edward G. Wonsock 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 appraised report is attached. (x ) ( X ) 2. ( ) 3. (x> ( ) 6. ( ) 7. ( ) 8. 10. 11. 13. 14. 15. ( ) 16. ( ) 17. (? ) 18 X 20. 21. 22. 23. 24 CZ5 1) 26. Real property Motor vehicles Stocks, bonds, securities and options Certificates of deposit Checking accounts, cash Savings accounts, money market and savings certificates Contents of safe deposit boxes Trusts Life Insurance policies (indicate face value, cash surrender value, and current beneficiaries) Annuities Gifts Inheritances Patents, copyrights, inventions, royalties Personal property outside the home Businesses (list all owners, including percentage of ownership, and officer/director positions held by a party with company) Employment termination benefits-severance pay, workman's compensation claim/award Profit sharing plans Pension plans (indicate employee contributions and date plan vests) Retirement plan, Individual Retirement Accounts Disability payments Litigation claims (matured and unmatured) Military/V.A. benefits Education benefits Debts due, including loans, mortgages held Household furnishings and personalty Other MARITAL PROPERTY LIST ALL MARITAL PROPERTY IN WHICH EITHER OR BOTH SPOUSES HAVE A LEGAL OR EQUITABLE INTEREST INDIVIDUALLY OR WITH ANY OTHER PERSON AS OF THE DATE OF SEPARATION OF THE PARTIES: ITEM # Description Date Acquired Purchased Current Price Value 2uo ? 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W ° (A ~ N i o m O O 0 o ? o v < y OD (A V o . mm 3 0 3 O {y K D -< m c) w a l 0 - CL w e n C> ? o m -_ O = co m 3 m = 3. , ?? m c a _ m 11 ID ? 0- n ?, m `n m CL < m ca D N O O V N N W N , OD V rn < N CO W O m A A 00 x 3 a o m W A a w 4 W is ? t0 ma O m j O C) s rn m x A m 0 O M Q m CL M O o a w O a N W 60 A co w ° C N O W A N -i w OD N 0 m p n N (O W DD N ?< 00 S, O O a w W?w to F= m 0 D M 0 O O Z O O r r O m m r --i D Z D m m z C cn C7 O n C U) O 0 D Z 00 C r 0 O1 N W Ln Ln kD c7i W W Ln ?1 m ?1 O` 0 0 0 a 3 Q O a (p v m O ? 'a c ? ? y ?3 V O tq A p A (p o y. y m O c K 0) m 0 0 * =J0D Z m ?p CD 0 CD D C Z X ;r, r) G) 0 (/) D70O O O ADO (D CD (D (a Q3 mD (D 0 C Q) U) CL m? CD_ A ? 0 CD 00 00 OO-n NCn? A A ? AA nnn 7l 0 m r v 3 Z cn m C n m U) 3 O Ic S N h' 0 3 OD u7 ao ? n M _W N O C> mt C> /* v =y =rt EDWARD G. WONSOCK, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 05-3676 CIVIL TERM CHRISTINE B. WONSOCK, IN DIVORCE DEFENDANT AFFIDAVIT OF SERVICE I, Thomas D. Gould, attorney for Plaintiff, in the above captioned action for divorce, hereby certify that a conformed and certified copy of the Complaint in Divorce was served upon the Defendant by depositing the same in the United States mail, certified, restricted delivery, on July 20, 2005 pursuant to Rule 1920.4 of the Amendments to the Pennsylvania Rules of Civil Procedure relating to the Divorce Code. As indicated by the postal return receipt attached hereto, the Complaint was received by the Defendant on July 25, 2005. Thomas D. Gould r ¦ Caornph to Items 1, 2; old 3. Also complete item 4 If Pas&WW DWvwy b desired: • Prtrtt your nano aid address on the reverse so tied we can return the cad to yoq, • Mtwh this card to ft back of the rnWoeoe, or on I* front if apace permits. 1. Amble Addressed to: C? I ? f 1 ??Y ? Y' V %SQ?ra!" 7YO0 - 32 N4 Cottrf Ora 124&LA, PL 32 4b 7 z. PS ID # 36508 - ^? maw treet "AAk. PA 17011 ? Agent 51 B. PleceNed by (PAnted Memel , Darts i.6-6 ci ?n 14' ri 5 b. Is d*.Wy address dierent from item 1?' O Yes If YES, enter delivery address below: E9 0-- 3. SWVICe TWO IA4ertflfed Md ? Dpraes Mad 0 Re&bersd 15y31a m Receipt for NreiairrMrdre 0 buzed Mad ? C.O.b. ? r 4. Reeblcted oeyyery? (151" Fee) 106-024A-1540 rC `{r. - 7 U EDWARD G. WONSOCK, Plaintiff V. CHRISTINE B. WONSOC , Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005 - 3676 CIVIL ACTION - LAW DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was fi ed on July 20, 2005. 2. The marri ge of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service f 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 acknowledge that p rsuant to Rule 1920.42(e) I have waived the requirement that I eceive 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 subject to the penalties o 18 Pa. C.S. Section 4904 relating to unsworn falsification to a thorities. f d` '?o © I DATED: / EDWARD G7. WONSOCK F! La THE F ?YTIMY 2009 APR 14 AM 10. 5 vfk::t?'i cu EDWARD G. WONSOCK, Plaintiff V. CHRISTINE B. WONSOCI, Defendantl IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005 - 3676 CIVIL ACTION - LAW DIVORCE 1. I consent1to the entry of a final decree without notice. 2. I underst nd that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divor e is granted. 3. I underst nd that I will not be divorced until a divorce decree is entered y the court and that a copy of the decree will be sent to me immed'ately after it is filed with the prothonotary. DATED: S 2.,A0'j U)el EDWARD G. WONSOCK 'kRy OF THE P ? 2009 APP 114 AM 10 Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant EDWARD G. WONSOCK, Plaintiff V. CHRISTINE B. WONSOCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3676 CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) AND § 3301(d) 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 waiver 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: ?}- - 0- O q / W. Christine B. Wonsock, Defendant T "N rppp5 RY 2099 APR 2 AN 11: 09 F:\F1LES\CGents\11752 Wonsock\11752.I.spccrehef.wpd Revised: 2/18/10 3:14PM Jennifer L. Spears, Esquire MARTSON LAW OFFICES I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant EDWARD G. WONSOCK, Plaintiff V. CHRISTINE B. WONSOCK, Defendant 2010 FEB 10 PN 1i. 20 C ,._ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3676 CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S PETITION FOR SPECIAL RELIEF AND FOR INTERIM COUNSEL FEES, COSTS AND EXPENSES 1. A Complaint in Divorce was filed in the matter on July 20, 2005. 2. The Divorce Master was appointed on April 18, 2008. 3. The parties were married on April 24, 1982 and separated either in 1995 or 2004 depending on the parties' testimony, an issue that has yet to be determined by the Divorce Master. 4. An initial hearing was held before the Divorce Master, E. Robert Elicker, III on the date of separation on or about April 7, 2009. 5. Following a subsequent conference with the Master, a hearing was scheduled for the pending claims of equitable distribution, alimony, counsel fees, costs and expenses on October 27, 2009. 6. Wife lives in Florida and is disabled. 7. Due to Wife's severe seizure disorder and numerous other serious health problems, Wife cannot travel to Pennsylvania for hearings and video conferencing was arranged at Wife's expense for the hearings on April 7 and October 27, 2009. 8. A conference was held between the Master, the attorneys, and at times Husband prior to starting an actual hearing on October 27, 2009. Counsel also conferred and negotiations were discussed. Wife was available via video-conferencing. 9. Aside from a condo owned by both parties, which was sold in 2004 and the proceeds of said sale were divided evenly between parties, Husband has had sole possession, title and control of all remaining marital assets, to include a pension and two retirement accounts, most of which he has depleted for his sole benefit and use. Only a portion of the Fidelity IRA remains, and Husband has completely depleted an account with T. Rowe Price. 10. The only other marital "asset" is a life insurance policy issued through Husband's former employer, the Board of Education of Montgomery County, Maryland, which has no cash value and is a small policy of about $18-20,000. Husband claims Wife is still listed as the sole beneficiary of this policy, and Wife requests that not be changed. 11. Counsel and Husband and Wife reached an agreement to settle all claims, which was not transcribed onto the record at the hearing because one detail had to be worked out on how to implement the agreement, and counsel for Husband had already drafted an agreement and was willing to revise that draft for the parties to review and sign. However, as indicated by the transcript referred to in Paragraph 12 and attached hereto, there was a meeting of the minds and resolution of all claims. 12. A colloquy of the agreement reached is now on the record from a conference held with the Divorce Master on February 17, 2010, and a copy of that transcript is attached hereto for reference as Exhibit A. 13. A review of the attached record indicates that Husband has attempted to re-negotiate the agreement and is now unwilling to follow through with the agreement with regard to one provision relating to the Fidelity IRA in his name. 14. Wife hereby requests that the pension payments (as part of equitable distribution) to Wife begin retroactively to November 1, 2009, and that this Court order that Husband make the payments directly, including all arrears, and continue to make the payments directly until the Divorce Decree is entered and the QDRO can be implemented. 15. In the alternative, if a Divorce Decree is not required prior to the entry of a QDRO, Wife requests that the QDRO be entered and Husband be required to make a direct payment on arrears retroactive to November 1, 2009, and ongoing direct payments until the QDRO is administered. 16. In the alternative, Wife requests that at least 50% of Husband's monthly pension payment be placed in escrow from this point forward so that Husband may not further use and dissipate the marital asset until this matter is resolved by agreement or further Order of court. 17. Additionally, Wife requests that the Fidelity account, the only remaining liquid marital asset and solely under Husband's control, be frozen to prevent any withdrawals by Husband until the matter is resolved by agreement or court order. 18. If Husband has made any withdrawals from the Fidelity account since September 30, 2009, Wife further requests that he be ordered to reimburse the account for those withdrawals immediately. 19. Following the conference with the Divorce Master on February 17, 2009, the Master indicated another hearing would have to be scheduled to resolve the claims. 20. Wife has expended thousands of dollars on attorney fees and costs and expenses for the prior hearings, preparation for them, and responding to Husband's subsequent attempts to re- negotiate the agreement reached on October 27, 2009. It is anticipated that Wife will spend another $5,000.00 on attorneys fees, costs and expenses, including the costs of video-conferencing for a future hearing before the Master, and possibly more if there are any additional hearings. 21. Wife has paid for the costs for video conferencing for the April, 2009 hearing due to the fact that she cannot travel to Pennsylvania. The costs of video conferencing for the April, 2009 hearing was $822.50 paid to Vero Beach Court Reporters and $300.00 paid to Cumberland County. Copies of these invoices will be provided prior to a hearing. 22. Wife paid for the costs of video conferencing for the October 27, 2009, hearing/conference. The costs of which were $485.00 paid to Vero Beach Court Reporters and $150.00 paid to Cumberland County. Copies of these invoices will be provided prior to a hearing. 23. Wife paid $550.00 to Conrad Siegel for the appraisal of Husband's pension, to which he did not contribute. A copy of this invoice is attached hereto as Exhibit "B." 24. Therefore, Wife requests that she be awarded $10,000.00 in interim counsel fees, costs and expenses to cover expenses relating to the past two hearings, of which she bore the sole expense, and a future anticipated Master's hearing. 25. Wife also requests that any hearing scheduled before this Court on this Petition which requires her presence be scheduled in the afternoon due to her medical conditions and medications she takes, and that video-conferencing be set up by the Court Administrator, the costs of which on WHEREFORE, Defendant Christine Wonsock hereby requests this Honorable Court enter an Order to distribute Husband's pension as agreed upon by the parties, freeze the Fidelity account held by Husband and direct Husband to pay a minimum of $10,000.00 in interim counsel fees, costs and expenses to Wife. MARTSON LAW OFFICES By Jennif Spears, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Date: February 18, 2010 EDWARD G. WONSOCK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 05 - 3676 CIVIL CHRISTINE B. WONSOCK, Defendant IN DIVORCE THE MASTER: Today is Wednesday, February 17, 2010. This is the date set for a conference scheduled at the request of the attorney for wife in the above-captioned divorce proceedings. Present are the Plaintiff, Mr. Wonsock, and his counsel Thomas D. Gould and counsel for the Defendant, Jennifer L. Spears. Mrs. Wonsock is not present, as she is in Florida and the last contact we had with her was through a video conference set up'through the courthouse. This case is ripe for the entry of a divorce decree as the parties have signed the documents consenting to the divorce and waiving notice of intention to request entry of divorce decree allowing the divorce to proceed under Section 3301(c) of the Domestic Relations Code. We had a hearing with testimony of the parties on April 7, 2009, and then a hearing was scheduled later on, at which time wife was available by video conference and Mr. Wonsock was present. The Master's notes indicate that that was on October 27, 2009. At the time of the second scheduled hearing, 1 EXHIBIT "A" the Master addressed the parties and counsel, and they entered into negotiations and advised the Master that they had settled the case with respect to the economic claims but that they needed to work out some methodology with regard to an account which was one of the marital assets. Consequently, the Master was advised that he would be provided with an agreement signed by the parties after the issue relating to the transfer of funds from an account had been addressed and the Master was going to vacate his appointment. The Master was not privy specifically to the terms of the agreement that the parties had reached on October 27, 2009, but both counsel were present with the parties' participation, and it was the Master's understanding that the case was settled. What the Master is going to do today is ask attorney Spears, whose client is not present, to put on the record her understanding of what the agreement was at the time of the scheduled hearing on October 27, 2009. After that is stated on the record, Mr. Gould can respond with comments. We are going to have the agreement transcribed and then sent to Mrs. Wonsock for her review and comment. The Master will then determine how he wants to proceed after the agreement is presented to the parties as the Master understood was previously agreed to on the 27th of October. 2 Mrs. Spears, would you go on the record and set forth the agreement that you understood you and Mr. Gould and Mr. Wonsock and your client had on that date. MS. SPEARS: The agreement that we reached was that wife would receive $1,500.00 per month from husband's pension from the Board of Education of Montgomery County, Maryland, which is administered by Aetna, to begin immediately, which would have been on or about November 1, 2009, by direct payments from husband until a QDRO is implemented. Counsel for wife will draft the QDRO (I did draft a QDRO). Husband's Fidelity account would be distributed so that each party receives $500.00 per month until it is depleted with a right of survivorship. As of September 30, 2009, the balance of that Fidelity account was $131,856.38. Husband was to not make any withdrawals. Subsequent to the conference we determined that because the Fidelity is an IRA in husband's name solely, we discussed that the entire account would be used in its entirety to open up an annuity for each party with the another party to be named irrevocably as sole beneficiary. Husband shall irrevocably name wife as sole beneficiary on his existing life insurance policy through 3 his former employment with the Board of Education of Montgomery County, Maryland. All other assets are to remain with the parties that had title and possession. THE MASTER: Ms. Spears, were there any other outstanding claims relating to alimony or counsel fees? MS. SPEARS: At the time we reached an agreement, this was the final agreement to resolve all claims. THE MASTER: So what you just stated on the record would have resolved the claims of equitable distribution, alimony and counsel fees? MS. SPEARS: It would have, yes. THE MASTER: Okay. This is your understanding of what the agreement was between you and Mr. Gould and his client and you discussed it with your client and it was also her understanding? MS. SPEARS: Yes. THE MASTER: Mr. Gould, you can go on the record and make comments relating to what Ms. Spears has stated and then we will proceed to have this transcribed. I do want to ask one final question just so it is clear on the record. Have any of the terms that you have set forth been implemented at this time? MS. SPEARS: Nothing has actually been 4 implemented. I've moved forward with the steps to do that. I drafted the QDRO which they have reviewed and said was acceptable but we cannot implement that until the divorce decree is entered. I did investigate how we can deal with the Fidelity account in the terms that we had discussed and did find that there is an annuity available for each of them through, I believe, it is New York Life Insurance that would do exactly what we have stated, in that they each would receive $500.00 per month and whichever party out lived the other would receive as the sole beneficiary the remainder of the other annuity. THE MASTER: So after you had done your research, following the hearing date, you had concluded that you would be able to accomplish the intention of the agreement through the methodology that you have just indicated? MS. SPEARS: Yes. THE MASTER: So that the terms of the agreement could be carried out? MS. SPEARS: Yes. THE MASTER: And at this point, because nothing has happened since October 27, 2009, there is an arrearage on the agreement? MS. SPEARS: Yes. 5 THE MASTER: Mr. Gould, I'll let you go on the record and you can make your comments and then, as I said, I am going to have this transcribed and forwarded to Mrs. Wonsock for her review. MR. GOULD: My understanding was that there was a general agreement on how to resolve this thing between the Wonsocks. And generally she is accurate in the sense that there was an agreement that Mr. Wonsock would -- there would be a QDRO entered to take $1,500.00 of his retirement account per month. I prepared an agreement saying that would happen. Opposing counsel prepared the QDRO and we said that is fine and we thought that was going to happen right away. It didn't happen. There was no agreement that I know of that said it was going to be retroactive to any particular date or anything. The Fidelity account, which was an account that had about $130,000.00 in it, there was discussions about how to divide that up and since Mr. Wonsock had indicated that he needed at least $500.00 a month for his budgetary purposes, there was a discussion about whether they could find an annuity to have that happen and initially that is what we had talked about, having an annuity of $500.00 a month -- each of them buying an annuity with this $130,000.00, have two separate annuities, paying each of them $500.00 a month. We didn't know how long it would last 6 but it would last until some point. After we had the conference, we then investigated trying to find one. We couldn't find one initially. We had a financial advisor involved. He could not get one that was going to meet those qualifications. When that happened, Mr. Wonsock and I then talked about what the other options would be, at which point, he said, it seems to me it would make a lot more sense if we just divide that (about $65,000.00 each), she takes hers and if she wants to buy an annuity, that's fine; I'll use my money however I wish to. That was proposed and they said, well, we don't want to do that and they went looking and they did find a New York Life that appeared to be able to do that. In looking at that we realized that that $500.00, not only was it costing money, the interest on the $130,000.00 was 2%. Mr. Wonsock said that doesn't make any sense, we could do much better than that. We wrote a letter to counsel saying, hey, why don't we just divide it. He'll take his half; she can have her half. Husband has no other funds available. All he has is a social security, his retirement fund, and then an annuity of $500.00. If an emergency came up and he needed $1,000.00, he couldn't have $1,000.00. We thought that would make sense. The only advantage to Mrs. Wonsock would be that if Mr. Wonsock died before the annuity was paid, then she would get something 7 and we didn't feel that that was a good idea to have the incentive that Mr. Wonsock die for her to get additional money. That was the discussion and that is what we got hung up on. The only issue is whether it's the most appropriate use of the $130,000.00 that's in there, whether it be to purchase two separate annuities with that money to pay each $500.00. Mrs. Wonsock does not need $500.00 a month. There is no an advantage to her to have that. Mr. Wonsock would like to have the advantage of being able to use more than $500.00 if he so chooses or less than $500.00, depending on what his needs may be. We have attempted to have further discussions about the advantages and disadvantages to not having annuities at being locked in at $500.00 a month for about 11 or 12 years for each of our parties because it wasn't to our client's advantage to do that. My client might need more. Her client doesn't need $500.00. MS. SPEARS: First I just want to state that I object to any characterization about whether my client has any need or use for the $500.00 per month. THE MASTER: It isn't relevant. I understand that. MS. SPEARS: With the Fidelity IRA, we investigated different types of annuities and the 8 information we had about the New York Life annuity, actually we had that information by November 23, 2009, and the paperwork made it clear that that annuity would be in effect for each of them for approximately 12 years before the money would be depleted. There have been several attempts by Mr. Gould and Mr. Wonsock to renegotiate the agreement that was reached on October 27, 2009, and after consideration of the terms that they were requesting to renegotiate, we rejected that and since then there have been several of the exact same terms attempted to be renegotiated. Our understanding and our agreement on October on 27th was that each party would receive the exact same amount, the amount that was agreed upon was $500.00 per month, that neither party could take out more, and that the account would not just be divided equally; that there would be a right of survivorship because my client wanted more than half of the account and did not agree to just split the account. So the attempt to renegotiate the terms were not the intent or the understanding of the parties on the date that the agreement was reached. THE MASTER: So your client, as I understand it, wanted to have the arrangements set up with each of them getting the $500.00 so she could preserve a right of survivorship in the account? MS. SPEARS: Yes. 9 THE MASTER: In the event of Mr. Wonsock predeceasing her? Now, if she predeceased him, would he also have the right of survivorship? MS. SPEARS: Yes. It worked both ways, and that was her concession to get the right of survivorship from him, was that it would have to work both ways. The only intent was just that there was a controlled amount so that, for instance, Mr. Wonsock couldn't take his half, even with a right of survivorship, and then withdraw thirty or forty thousand in one month while she was taking a controlled amount every month. It was so that they each had monthly equal access. THE MASTER: And that upon death of either one, the survivor would get the balance of the account? MS. SPEARS: Yes. THE MASTER: All right. Thank you, counsel. cc: Thomas D. Gould, Attorney for Plaintiff Edward G. Wonsock, Plaintiff Jennifer L. Spears, Attorney for Defendant Christine B. Wonsock, Defendant 10 Conrad Siegel A C T U A R I E S The Employee Benefits Company Jennifer L. Spears, Esq. Martson Law Offices 10 East High Street Carlisle, PA 17013 Re: Actuarial Services Rendered Through March 22, 2009 Wonsock v. Wonsock 501 Corporate Circle • P.O. Box 5900 • Harrisburg, PA 17110-0900 Phone (717) 652-5633 Fax (717) 540-9106 www.conradslegel.com Invoice Date 3/25/2009 Invoice No. X042:20090767 Calculation of Present Value of Future Pension Payments and Accumulated Value of Past Pension Payments for Mr. Wonsock's Retirement Income Report Dated March 17, 2009 Total Invoice EXHIBIT "B" 50.00 S P?, 3/, 3 Please include the invoice number on your remittance and mail to the attention of Beth Fetterhoff. Interest will accrue at a rate of 1.5% per month on balance outstanding more than 30 days. CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Petition for Special Relief and for Interim Counsel Fees, Costs and Expenses was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Thomas D. Gould, Esquire 2 East Main Street Shiremanstown, PA 17011 MARTSON DEARDORFF WILLIAMS & OTTO By T Eckenroad Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: February 18, 2010 F:\F1LES\CGents\11752 Wonsock? 11752.1.pra Revised: 218/10 3:49PM Jennifer L. Spears, Esquire MARTSON LAW OFFICES I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant FILED- F 2G10 FEB 18 Psi 1$. 16 LO , EDWARD G. WONSOCK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 05-3676 CIVIL ACTION - LAW CHRISTINE B. WONSOCK, Defendant IN DIVORCE PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: You are directed to make part of the record the attached transcript of the conference before the Divorce Master on February 17, 2010. MARTSON LAW OFFICES By Jennife Ltivil ears, Esquire Ten East Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Date: February 18, 2010 EDWARD G. WONSOCK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 05 - 3676 CIVIL CHRISTINE B. WONSOCK, Defendant IN DIVORCE THE MASTER: Today is Wednesday, February 17, 2010. This is the date set for a conference scheduled at the request of the attorney for wife in the above-captioned divorce proceedings. Present are the Plaintiff, Mr. Wonsock, and his counsel Thomas D. Gould and counsel for the Defendant, Jennifer L. Spears. Mrs. Wonsock is not present, as she is in Florida and the last contact we had with her was through a video conference set up through the courthouse. This case is ripe for the entry of a divorce decree as the parties have signed the documents consenting to the divorce and waiving notice of intention to request entry of divorce decree allowing the divorce to proceed under Section 3301(c) of the Domestic Relations Code. We had a hearing with testimony of the parties on April 7, 2009, and then a hearing was scheduled later on, at which time wife was available by video conference and Mr. Wonsock was present. The Master's notes indicate that that was on October 27, 2009. At the time of the second scheduled hearing, 1 the Master addressed the parties and counsel, and they entered into negotiations and advised the Master that they had settled the case with respect to the economic claims but that they needed to work out some methodology with regard to an account which was one of the marital assets. Consequently, the Master was advised that he would be provided with an agreement signed by the parties after the issue relating to the transfer of funds from an account had been addressed and the Master was going to vacate his appointment. The Master was not privy specifically to the terms of the agreement that the parties had reached on October 27, 2009, but both counsel were present with the parties' participation, and it was the Master's understanding that the case was settled. What the Master is going to do today is ask attorney Spears, whose client is not present, to put on the record her understanding of what the agreement was at the time of the scheduled hearing on October 27, 2009. After that is stated on the record, Mr. Gould can respond with comments. We are going to have the agreement transcribed and then sent to Mrs. Wonsock for her review and comment. The Master will then determine how he wants to proceed after the agreement is presented to the parties as the Master understood was previously agreed to on the 27th of October. 2 Mrs. Spears, would you go on the record and set forth the agreement that you understood you and Mr. Gould and Mr. Wonsock and your client had on that date. MS. SPEARS: The agreement that we reached was that wife would receive $1,500.00 per month from husband's pension from the Board of Education of Montgomery County, Maryland, which is administered by Aetna, to begin immediately, which would have been on or about November 1, 2009, by direct payments from husband until a QDRO is implemented. Counsel for wife will draft the QDRO (I did draft a QDRO). Husband's Fidelity account would be distributed so that each party receives $500.00 per month until it is depleted with a right of survivorship. As of September 30, 2009, the balance of that Fidelity account was $131,856.38. Husband was to not make any withdrawals. Subsequent to the conference we determined that because the Fidelity is an IRA in husband's name solely, we discussed that the entire account would be used in its entirety to open up an annuity for each party with the another party to be named irrevocably as sole beneficiary. Husband shall irrevocably name wife as sole beneficiary on his existing life insurance policy through 3 his former employment with the Board of Education of Montgomery County, Maryland. All other assets are to remain with the parties that had title and possession. THE MASTER: Ms. Spears, were there any other outstanding claims relating to alimony or counsel fees? MS. SPEARS: At the time we reached an agreement, this was the final agreement to resolve all claims. THE MASTER: So what you just stated on the record would have resolved the claims of equitable distribution, alimony and counsel fees? MS. SPEARS: It would have, yes. THE MASTER: Okay. This is your understanding of what the agreement was between you and Mr. Gould and his client and you discussed it with your client and it was also her understanding? MS. SPEARS: Yes. THE MASTER: Mr. Gould, you can go on the record and make comments relating to what Ms. Spears has stated and then we will proceed to have this transcribed. I do want to ask one final question just so it is clear on the record. Have any of the terms that you have set forth been implemented at this time? MS. SPEARS: Nothing has actually been 4 implemented. I've moved forward with the steps to do that. I drafted the QDRO which they have reviewed and said was acceptable but we cannot implement that until the divorce decree is entered. I did investigate how we can deal with the Fidelity account in the terms that we had discussed and did find that there is an annuity available for each of them through, I believe, it is New York Life Insurance that would do exactly what we have stated, in that they each would receive $500.00 per month and whichever party out lived the other would receive as the sole beneficiary the remainder of the other annuity. THE MASTER: So after you had done your research, following the hearing date, you had concluded that you would be able to accomplish the intention of the agreement through the methodology that you have just indicated? MS. SPEARS: Yes. THE MASTER: So that the terms of the agreement could be carried out? MS. SPEARS: Yes. THE MASTER: And at this point, because nothing has happened since October 27, 2009, there is an arrearage on the agreement? MS. SPEARS: Yes. 5 THE MASTER: Mr. Gould, I'll let you go on the record and you can make your comments and then, as I said, I am going to have this transcribed and forwarded to Mrs. Wonsock for her review. MR. GOULD: My understanding was that there was a general agreement on how to resolve this thing between the Wonsocks. And generally she is accurate in the sense that there was an agreement that Mr. Wonsock would -- there would be a QDRO entered to take $1,500.00 of his retirement account per month. I prepared an agreement saying that would happen. Opposing counsel prepared the QDRO and we said that is fine and we thought that was going to happen right away. It didn't happen. There was no agreement that I know of that said it was going to be retroactive to any particular date or anything. The Fidelity account, which was an account that had about $130,000.00 in it, there was discussions about how to divide that up and since Mr. Wonsock had indicated that he needed at least $500.00 a month for his budgetary purposes, there was a discussion about whether they could find an annuity to have that happen and initially that is what we had talked about, having an annuity of $500.00 a month -- each of them buying an annuity with this $130,000.00, have two separate annuities, paying each of them $500.00 a month. We didn't know how long it would last 6 but it would last until some point. After we had the conference, we then investigated trying to find one. We couldn't find one initially. We had a financial advisor involved. He could not get one that was going to meet those qualifications. When that happened, Mr. Wonsock and I then talked about what the other options would be, at which point, he said, it seems to me it would make a lot more sense if we just divide that (about $65,000.00 each), she takes hers and if she wants to buy an annuity, that's fine; I'll use my money however I wish to. That was proposed and they said, well, we don't want to do that and they went looking and they did find a New York Life that appeared to be able to do that. In looking at that we realized that that $500.00, not only was it costing money, the interest on the $130,000.00 was 20. Mr. Wonsock said that doesn't make any sense, we could do much better than that. We wrote a letter to counsel saying, hey, why don't we just divide it. He'll take his half; she can have her half. Husband has no other funds available. All he has is a social security, his retirement fund, and then an annuity of $500.00. If an emergency came up and he needed $1,000.00, he couldn't have $1,000.00. We thought that would make sense. The only advantage to Mrs. Wonsock would be that if Mr. Wonsock died before the annuity was paid, then she would get something 7 and we didn't feel that that was a good idea to have the incentive that Mr. Wonsock die for her to get additional money. That was the discussion and that is what we got hung up on. The only issue is whether it's the most appropriate use of the $130,000.00 that's in there, whether it be to purchase two separate annuities with that money to pay each $500.00. Mrs. Wonsock does not need $500.00 a month. There is no an advantage to her to have that. Mr. Wonsock would like to have the advantage of being able to use more than $500.00 if he so chooses or less than $500.00, depending on what his needs may be. We have attempted to have further discussions about the advantages and disadvantages to not having annuities at being locked in at $500.00 a month for about 11 or 12 years for each of our parties because it wasn't to our client's advantage to do that. My client might need more. Her client doesn't need $500.00. MS. SPEARS: First I just want to state that I object to any characterization about whether my client has any need or use for the $500.00 per month. THE MASTER: It isn't relevant. I understand that. MS. SPEARS: With the Fidelity IRA, we investigated different types of annuities and the 8 information we had about the New York Life annuity, actually we had that information by November 23, 2009, and the paperwork made it clear that that annuity would be in effect for each of them for approximately 12 years before the money would be depleted. There have been several attempts by Mr. Gould and Mr. Wonsock to renegotiate the agreement that was reached on October 27, 2009, and after consideration of the terms that they were requesting to renegotiate, we rejected that and since then there have been several of the exact same terms attempted to be renegotiated. Our understanding and our agreement on October on 27th was that each party would receive the exact same amount, the amount that was agreed upon was $500.00 per month, that neither party could take out more, and that the account would not just be divided equally; that there would be a right of survivorship because my client wanted more than half of the account and did not agree to just split the account. So the attempt to renegotiate the terms were not the intent or the understanding of the parties on the date that the agreement was reached. THE MASTER: So your client, as I understand it, wanted to have the arrangements set up with each of them getting the $500.00 so she could preserve a right of survivorship in the account? MS. SPEARS: Yes. 9 THE MASTER: In the event of Mr. Wonsock predeceasing her? Now, if she predeceased him, would he also have the right of survivorship? MS. SPEARS: Yes. It worked both ways, and that was her concession to get the right of survivorship from him, was that it would have to work both ways. The only intent was just that there was a controlled amount so that, for instance, Mr. Wonsock couldn't take his half, even with a right of survivorship, and then withdraw thirty or forty thousand in one month while she was taking a controlled amount every month. It was so that they each had monthly equal access. THE MASTER: And that upon death of either one, the survivor would get the balance of the account? MS. SPEARS: Yes. THE MASTER: All right. Thank you, counsel. cc: Thomas D. Gould, Attorney for Plaintiff Edward G. Wonsock, Plaintiff Jennifer L. Spears, Attorney for Defendant Christine B. Wonsock, Defendant 10 CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Thomas D. Gould, Esquire 2 East Main Street Shiremanstown, PA 17011 MARTSON DEARDORFF WILLIAMS & OTTO By ricia D. Eckenroa Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: February 18, 2010 EDWARD G. WONSOCK, Plaintiff VS. CHRISTINE B. WONSOCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 05-3676 CIVIL IN RE: DEFENDANT'S PETITION FOR SPECIAL RELIEF AND INTERIM COUNSEL FEES COSTS AND EXPENSES RULE TO SHOW CAUSE AND NOW, this 2 11 ` day of February, 2010, upon consideration of the foregoing petition, it is hereby ordered and decreed as follows: 1. A rule is issued upon the plaintiff to show cause why the petitioner is not entitled to the relief requested; 2. the respondent shall file an answer to the petition within twenty (20) days of service; 3. the petition shall be decided under Pa. R.C.P. No. 206.7; 4. argument shall be scheduled if requested in any answer; and 5. notice of the entry of this order shall be provided to all parties by the petitioner. BY THE COURT, M4, T cam. A,Ny J 7 Kevin ess, J. co r_. - , ` CD zx .< EDWARD G. WONSOCK, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2005 - 3676 CIVIL RER1j? v Zt 'r? `7 '_i CHRISTINE B. WONSOCK, IN DIVORCE him DEFENDANT r CY_) PLAINTIFF'S REPLY TO DEFENDANT'S PETITION FOR SPACIA4 RELIEF AND INTERIM COUNSEL FEES, COSTS AND EXPENSES r'--' AND NOW comes the Plaintiff/Respondent, Edward G. Wonsock, by and through his attorney, Thomas D. Gould, and files this answer to Defendant/Petitioner's petition. 1. Admitted 2. Admitted 3. Admitted. By way of further answer, Wife left the marital home in 1989 or 1990 to live with her parents in Florida. 4. Admitted 5. Admitted 6. Admitted. By way of further answer, Wife became disabled during the marriage in 1987. 7. Admitted 8. Admitted 9 Admitted that the only jointly owned property, the condo in which Husband resided in prior to his marriage, has been sold and the proceeds were evenly divided between the parties. It is admitted that before his marriage, during the marriage and continuing after separation Husband maintained various financial accounts and that before, during and after separation he had total and exclusive control of his funds. Admitted that over the years Husband invested and utilized his funds for his personal use. By why of further answer, Wife before, during the marriage and after separation maintained her separate financial accounts and had total and exclusive control the use of her funds. Admitted that over the years Wife invested and utilized her funds for her own personal use. It is admitted that funds in Husband's T. Rowe Price fund has been spent. It is admitted that Husband's sole remaining funds accumulated before his marriage and during his marriage are in his Fidelity IRA. 10. Admitted that Husband has a term life insurance policy through his former employer with a value of $18-20,000.00 and that Wife is the beneficiary. 11. Admitted that at the scheduled Divorce Master's hearing on October 27, 2009, there were discussions in an attempt to reach a resolution of all the economic claims in the divorce. It is admitted that no agreement was placed on the record, because details had to be worked out. Admitted that Husband's attorney offered to put the proposed agreement on the record to insure that there was a "meeting of the minds" between Husband and Wife. It was determined that there were issues to be resolved and no agreement was set forth. Admitted that there was a partial transcript of some of the conversations with the Divorce Master on Wednesday February 17, 2010. Denied that the transcript states that Husband and Wife had a meeting of the minds. By way of further answer, Husband who was requested to be present at the conference with the Divorce Master on February 17, 2010, was not permitted to testify as his understanding of the substance of the discussions that took place on October 27, 2009. 12. Admitted that there was a discussion at the Divorce Master's office where each attorney, only, was permitted to attempt to recollect what transpired on October 27, 2009. Admitted that Exhibit A is a copy of a transcript of some of the discussions that occurred at the Divorce Master's office on February 17, 2010. 13. Denied. The transcript, although not complete, indicates that on October 27, 2009 Husband and Wife had a discussion about a possible resolution that needed to be further investigated and the details worked out. Admitted that following the meeting on October 27, 2009, after further investigation and noting difficulties in attempting to reach the desired results, Husband offered alternative choices for consideration by Wife. Husband's attorney contacted Wife's attorney with the alternatives. Wife's attorney refused to relay Husband's suggestions to Wife. 14. This is not a statement of fact. It is a "request" to which no response is required. In the event an answer is required, Wife is not entitled to any distribution from a marital asset until an order from the court or an agreement by the parties. Husband has been willing to agree to pay Wife a portion of his pension as part of a total resolution of the equitable distribution of the marital estate. No final resolution has been consummated. 15. This is not a statement of fact. It is a "alternative" request to which no response is required. In the event an answer is required, Wife is not entitled to any distribution from a marital asset without an order from the court or an agreement by the parties. Any approved QDRO may provide for Wife's requests. 16. This is not a statement of fact. It is another "alternative" request to which no response is required. In the event an answer is required, even under the proposed settlement Wife would only receive $1,500.00 monthly from Husband's pension, requiring Husband to withhold 50% would be contrary to proposal. 17. This is not a statement of fact. It is another %%request" to which no response is required. In the event an answer is required, the Fidelity IRA was before marriage, during marriage and after separation a separate individual retirement account from which Husband has used funds to meet his financial obligations. Any restrictions on the use of his IRA funds would be detrimental to his financial health. 18. This is not a statement of fact. It is another "request" to which no response is required. In the event an answer is required, under ERISA rules Husband is required to take withdrawals from his IRA. Husband understands that he is accountable to Wife and this Court for any funds removed from his Fidelity IRA account. 19. Admitted. The Divorce Master stated that he does not have a record that a final agreement was reached at the time of the October 27, 2009 scheduled hearing and that he would need to hold a hearing to gather evidence upon which to render a report and recommendation on the equitable distribution claims. 20. After reasonable investigation Husband is without knowledge or information sufficient to form a belief as to the truth of the averment. By way of further answer, only two hearings were scheduled by the Divorce Master and Husband was ready, willing and able to testify. The first hearing was abruptly stopped due to Wife having a seizure which was beyond the control of Husband. The second hearing was not conducted due to negotiations and discussions. Husband had requested meetings and discussions between Husband and Wife outside the Divorce Master hearing process. Wife refused any informal meetings or discussions. 21. Admitted that Wife chose to appear by teleconference and paid the costs associated with that choice. Husband is without information or knowledge as to Wife's expenses. 22. Admitted that Wife chose to appear by teleconference and paid the costs associated with that choice. Husband is without information or knowledge as to Wife's expenses. 23. Admitted that Wife elected to have Husband's pension appraised. Husband cooperated fully with Wife to assist her in obtaining his pension information. 24. This is not a statement of fact. It is another "request" to which no response is required. In the event an answer is required, any expenses incurred by Wife were not due to any unusual, dilatory or vexatious action on the part of Husband and therefore Wife should be responsible for her own attorney fees and costs. Wife has sufficient funds in her various accounts from which to pay for the costs and expenses that she has incurred. 25. My copy of the Petition does not include a complete paragraph 25. That portion that was provided is not a statement of fact. It is another "request" to which no response is required. In the event an answer is required Husband does not object to an afternoon hearing if deemed necessary by this Court. Husband does object to being responsible for any of Wife's costs associated with any further action on her Petition. WHEREFORE, Plaintiff /Respondent, Edward G. Wonsock, hereby requests that this honorable court dismiss Defendant's/Petitioner's petition and return this matter to the Divorce Master to take testimony and receive evidence to allow him to issue a Report and Recommendation on the pending claims in this divorce. •ii" 16. J? Thomas D. Gould Attorney for Plaintiff I.D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 Thomas D. 2 E. MAIN STREET ATTORNEY AT L4 W (717 SHIREMANSTOWN, PA 17011 ) 731.1461 FAX 761-1974 March 12, 2010 HONORABLE KEVIN A. HESS CUMBERLAND COUNTY COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PA 17013 Re: Edward G. Wonsock v. Christine B. Wonsock Docket # 05-3676 Divorce - Petition For Special relief Dear Judge Hess: Pursuant to your February 24, 2010 Order, enclosed is Plaintiff's Answer to Defendant's Petition For Special Relief and Interim Counsel Fees, Costs and Expenses. Respectfully, Thomas D. Gould CC. Jennifer L. Spears, Esquire Edward G. Wonsock F:\F1LES\C1iem\11752 WOMOCkV 1752. Lorder Revised: 12129/10 2:11PM DEC 2 9 zuiu EDWARD G. WONSOCK, Plaintiff V. CHRISTINE B. WONSOCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3676 CIVIL ACTION - LAW IN DIVORCE ORDER C,L-W-KED Z0 f k0Tfi0fJ0Tft1gJV tae . CQ 4 D is AND NOW, this 71' day of December, 2010, the economic claims raised in the proceedings having been resolved and Affidavits of Consent having been filed, the appointment of the Divorce Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. BY THE COURT, President Judge cc: Aomas D. Gould, Esquire - Attorney for Plaintiff ,,Jennifer L. Spears, Esquire - Attorney for Defendant F:1 N 1732 wmrockM 1732.1.crdv Row: 1Zw10 2:11pm DEC 2 9 2010 EDWARD G. WONSOCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 05-3676 a-w-KED 1.0 : CIVIL ACTION - LAW fk0T fj0wTftRy CHRISTINE B. WONSOCK, Defendant IN DIVORCE • a Q t 0 ORDER 1s AND NOW, this 7 1 ` day of December, 2010, the economic claims raised in the proceedings having been resolved and Affidavits of Consent having been filed, the appointment of the Divorce Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. BY THE COURT, President Judge cc: Aomas D. Gould, Esquire - Attorney for plaintiff Jdennifer L. Spears, Esquire - Attorney for Defendant F:\FILESTlients\11752 Wonsock\11752. Lpratransmit Revised: 12/29/10 10:40AM Jennifer L. Spears, Esquire MARTSON LAW OFFICES I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant EDWARD G. WONSOCK, Plaintiff v. .,. j 1 -L--Jll=r1 1'0Fr'r' EO OEC 29 P 2: S 1J f$ER . > ii i 0Ui%,, E' I EN NJ }'L IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3676 CIVIL ACTION - LAW CHRISTINE B. WONSOCK, : Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Via Certified Mail, Restricted Delivery on July 25, 2005. 3. Date of execution of the Plaintiff's affidavit of consent required by Section 3301 (c) of the Divorce Code; April 8, 2009; Date of execution of Defendant's Affidavit of Consent Under §3301(c) or (d) of the Divorce Code: October 6, 2008. 4. Related claims pending: All claims have been resolved. 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: April 14, 2009; Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: April 28, 2009. Date: December 29, 2010 ?B l liar 2010 DEC PH 2: ! `f i;UMBE AN ? ll " PE SY1wVA ' to V=Olks Spears, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant MARTSON W OFFICES By Jennifer EDWARD G. WONSOCK IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTINE B. WONSOCK NO. 05-3676 DIVORCE DECREE AND NOW, it is ordered and decreed that EDWARD G. WONSOCK , plaintiff, and CHRISTINE B. WONSOCK , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None. By the Court, Atte Prothonotary Atakee * &PY mm hof yo 4*y S'paus F:\F1LES\C1ients\11752 Wonsock\11752.Lgdro Revised: 12/29/10 1:59PM ILE0-GF1.IcE Jennifer L. Spears, Esquire ; :.- ¢ i4 L. , P , 111;, _..! MARTSON DEARDORFF WILLIAMS OTTO GILROY & FAL#?J?, ? _ r MARTSON LAW OFFICES I'll I.D. 87445 '`'!P^f8 t L) WjLjiv I... 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant EDWARD G. WONSOCK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTINE B. WONSOCK, Defendant NO. 05-3676 CIVIL ACTION - LAW : IN CUSTODY ELIGIBLE DOMESTIC RELATIONS ORDER Upon consideration of the Decree in Divorce entered in the above-captioned case, it is this day of ids, 61 , 20 it , ORDERED, 1. This Order relates to the disposition of certain benefits of EDWARD G. WONSOCK to be provided by the Montgomery County Public Schools Employees Retirement and Pension System ("participant's plan"), which is already in pay status. 2. The parties hereto were married on April 24, 1982, and this Order is entered incident to a final Decree in Divorce entered on 3. The PARTICIPANT is identified as follows: Name: Edward G. Wonsock Address: 69 Creek Bank Drive, Mechanicsburg, PA 17050 Date Of Birth: 7/22/1937 Social Security No.: 202-28-6587 MCPS ID No.: 2382 4. The ALTERNATE PAYEE is identified as follows: Name: Christine B. Wonsock Address: 740032 d Court, Vero Beach, Florida 32967 Date Of Birth: 10/30/1949 Social Security No.: 213-56-4215 e 5. The ADMINISTRATOR of the MCPS Employees Retirement and Pension System is identified as follows: Montgomery County Public Schools Employee and Retiree Service Center 7361 Calhoun Place, Suite 190 Rockville, Maryland 20855 6. To accommodate the marital property distribution between the parties, IT IS HEREBY ORDERED AS FOLLOWS: A. Allowance. The ALTERNATE PAYEE'S share of the PARTICIPANT'S allowance is declared to be: 1. $1,500.00 per month. B. Refund of accumulated contributions. Not applicable. C. Pre-retirement death benefit. ii. If applicable, the PARTICIPANT shall designate and maintain the ALTERNATE PAYEE as the sole primary beneficiary of the pre- retirement death benefit, for the ALTERNATE PAYEE'S lifetime. D. Post-retirement survivor benefit. Not applicable. E. Method and timing of payments; restrictions. MCPS is hereby directed to make payments of the ALTERNATE PAYEE'S share directly to the ALTERNATE PAYEE. Payments to ALTERNATE PAYEE shall commence as soon as possible and immediately upon the acceptance and administration of this Domestic Relations Order by the Plan Administrator. F. Obligations of Alternate Payee. It is the obligation of the ALTERNATE PAYEE to promptly: (a) provide MCPS a certified copy of this Order, and modifications or amendments hereto; (b) notify MCPS in writing of any change of name or address; and (c) comply with all reasonable requests from MCPS for information and documentation necessary for processing of all or any portion of a PARTICIPANT'S plan benefit to the ALTERNATE PAYEE. G. Obligation of Participant. It is the obligation of the PARTICIPANT to promptly: (a) notify MCPS in writing of any change of name or address; and r 1 .y (b) comply with all reasonable requests from MCPS for information and documentation necessary for processing payment of all or any portion of a PARTICIPANT'S plan benefit to the ALTERNATE PAYEE. Additionally, the PARTICIPANT is responsible for completing and submitting any applications or forms required by MCPS to effectuate any provision of this Order, including, but not limited to, any form required by MCPS to designate the ALTERNATE PAYEE as beneficiary. If the PARTICIPANT takes any action in contravention of any provision of this Order, including, but not limited to, this Paragraph 6, the PARTICIPANT shall bear the sole and exclusive liability for such action, and not MCPS. H. Tax Consequences of payments. All payments to the ALTERNATE PAYEE by MCPS shall be includable in the taxable income of and taxable to the ALTERNATE PAYEE. After-tax contributions shall be allocated to the parties in the same proportion as the total amount of the ALTERNATE PAYEE'S share bears to the PARTICIPANT'S total plan benefit. 1. No requirement to retire. No provision of this Order shall be construed to require the PARTICIPANT to retire at any particular age or length of service. 7. If the ALTERNATE PAYEE dies before commencement of payments to the ALTERNATE PAYEE, no benefits shall be paid to or for the benefit of the ALTERNATE PAYEE, his/her estate, heirs, successors, personal representatives or assignees. If the ALTERNATE PAYEE dies after the commencement of payments to the ALTERNATE PAYEE, no further benefit shall be paid to the ALTERNATE PAYEE, his/her estate, heirs, successors, personal representatives, or assignees. 8. This order is not intended, and shall not be construed in such a manner as to require the Plan to: (a) provide any type or form of benefits, or any option not otherwise provided for under the Plan, (b) provide increased benefits determined on the basis of an Actuarial Equivalent value, (c) pay benefits to the ALTERNATE PAYEE that are required to be paid to another alternate payee under another Order, or (d) create a right in any benefit except to the extent the PARTICIPANT is vested in such benefit. Notwithstanding anything else in this Order, the sum of the Actuarial Equivalent value of benefits to be paid to the ALTERNATE PAYEE pursuant to this Order and the r Participant shall be no greater that the Actuarial equivalent value of the benefits that would have been paid to the PARTICIPANT under the Plan but for this Order. 9. This Court retains jurisdiction to amend this Order for the purpose of its acceptance and/or administration by MCPS or to effectuate the terms of the parties' Settlement Agreement and/or Judgment of Divorce. BY THE COURT, , J. Consented ac to form PARTICIPANT /Attorney for Participant ?;? b. Thomas D. Gould, Esquire 2 East Main Street Shiremanstown, PA 17011 (71 731-1461 /) 1? . . .. /\ ALTERNATE PAYEE istin,B. W, Attorney for Alternate Payee i' V / Jennifer . Spears, Esquire 10 East High Street Carlisle, PA 17013 ?}. (717) 243-3341 l , ``? "CIO C