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Home My WebLink About01-4129 ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~+.~~+.+.~~+.~~+.+.+.~~~+.~+.~~~~~~+.~~+.~+.+.+.+.+.+.+.~~~ IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. DIANE F. GOOD No. 4129 2001 VERSUS ESRCM E. GOOD DECREE IN DIVORCE AND NOW, M2JL4 it.{ , IT IS ORDERED AND 2003 AND DIANE F. GOOD ESRCM E. GOOD , PLAI NTI FF, DECREED THAT , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRI MONY, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None. The Property SettlEment AgreEment between the parties shall be incorrorated into the final decree for purposes of enforcEment, but shall not merge with the final Decree in Divorce. PROTHONOTARY J. ~:? .:?Z ~, ,11/ Z'::?7fil./ r;.:?, . r v ,v U _' ;r-?L-. LG!..) C fZ~~ rY;:'>-~ f}'Z? '?/ ~"VMI C.~7 JC??7 'Lv?!,!.[ 7 "'07 y . , {/ ? . 7 tt' ( " ".. ~ DIANE F. GOOD, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION - LAW :IN DIVORCE ESROM E. GOOD, Defendant :NO.01-4129 RETIREMENT BENEFITS ORDER AND NOW, this ~ day of -'A V~ , 2001 pursuant to the request of the parties, the Stipulation attached hereto as Exhibit A is hereby entered as an Order of this Court. The terms of the Stipulation are incorporated, but not merged, into this Order. BY THE COURT: Cp D~ Gn \'\ .-;"., l2. ~/ I L I ,) , --- D \ ~'f" '8 (~ l\.?N tJM"." J. r (('liVe- fit I iL<~ _ I _ U ' jlY;- "Vd Zf:Z hi Lf:>JllW Eo , ;\ \rt'.l\-/!\l,t.~-:~ "~'\ ; ,. ,j .,....., " '. .-,-",.,~,,_r""').) ,- "', ~ ; , ~ " :"_/ " '- "..J '"' , , ' ',. r "l ..., ---- -.----------- -------------- --------- DIANE F. GOOD, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION - LAW :IN DIVORCE ESROM E. GOOD, Defendant :NO.01-4129 STIPULATION FOR THE ENTRY OF A RETIREMENT BENEFITS ORDER AND NOW, this JLP'~day ofAAruV1 f1 ' 200~ the parties, Diane F. Good, Plaintiff, and Esrom E. Good, Defendant, do hereby agree and stipulate as follows: 1. The Defendant, Esrom (hereinafter referred to as "Member"), is a participant in the Federal Retirement Thrift Savings Plan (hereinafter referred to as "TSP"). 2. SERS, as a creature of statute, is controlled by Statute, 5 V.S.C. ~~8435(c), 8467 and 5 C.F.R. part 1653, subpart A. 3. Member's date of birth is September 15, 1948, and his Social Security number is 502-56-6181. 4. The Plaintiff, Diane F. Good (hereinafter referred to as "Payee"), is the former spouse of Member. Payee's date of birth is August 5, 1955, and her Social Security number is 182-46-4277. 5. Participant's last known mailing address is: Mr. ESTom E. Good 150 N. 63rd Street Harrisburg, P A 17111. - 1 - EXHIBIT I,A' 6. Payee's current mailing address is: Ms. Diane F. Good 1029 Hemlock Lane Enola, PA 17025 It is the responsibility of Payee to keep a current mailing address on file with TSP at all times. 7. It is agreed that Plaintiff, Diane F. Good, shall be awarded a lump sum payment of $12,000.00 from the Thrift Savings Plan of Esrom E. Good as of the Date of the attached Order. 14. It IS specifically intended and agreed by the parties hereto that this Stipulation: (a) Does not require TSP to provide any type of benefit, or any option. not otherwise provided under the Retirement Code; and (b) Does not require TSP to provide increased benefits (determined on the basis of actuarial value). 15. The parties intend and agree that the terms of this Stipulation shall be approved, adopted and entered as a Retirement Benefits Order. The parties hereby authorize Plaintiffs Counsel to present this Stipulation to the Court, together with a motion requesting both that this Stipulation be entered as an Order of Court, and that the terms hereof be incorporated, but not merged, into the Order. 16. The Court of Common Pleas of Cumberland County, Pennsylvania, shall retain jurisdiction to amend any Retirement Benefits Order incorporating this Stipulation, but only for the limited purpose of establishing or maintaining it as a Retirement Benefits - 2 - Order. The Court shall have no power, however, to alter any of the terms of this Stipulation, including without limitation the manner in which the marital property component of Participant's retirement benefit, and the equitable distribution portion payable to Payee, shall be calculated. 17. Upon entry as a Retirement Benefits Order, certified copies of the Retirement Benefits Order and this Stipulation and any attendant documents shall be served upon TSP immediately. The Retirement Benefits Order shall take effect immediately upon its approval by TSP, and upon TSP's approval of any attendant documents, and it shall remain in effect until further Order of Court. WHEREFORE, the parties hereto, intending to be legally bound by the terms of this Stipulation, have hereunto placed their hands and seals the day and year first above wri tten. u. O~I,J r ,tlA-t'V ~ ,~ Diane F. Good, Plaintiff/Payee lchael S. Travis, Esquire 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 Attorney for Esrom E. Good - 3 - ... , . PROPERTY SETTLEMENT AGREEMENT This is a Property Settlement Agreement entered into this dYfi7 day of h 1)/IA.C'f! 2003, by and between ESROM E. GOOD, of Dauphin County, Pennsylvania (hereinafter referred to as "Husband"), and DIANE F. GOOD, of Cumberland County, Pennsylvania (hereinafter referred to as "Wife"). WITNESSETH: WHEREAS, Husband and Wife were lawfully married on May 23, 1981, and; WHEREAS, two children have been conceived of this marriage: Christopher M. Good whose date of birth is October 27, 1983 and Ryan P. Good whose date of birth is June 3, 1986; and WHEREAS, unhappy differences have arisen between Husband and Wife In consequence of which they are now living separate and apart from each other; and WHEREAS, Husband and Wife are now in the process of obtaining a divorce, and, consequently, they desire to settle and determine finally and for all time both their respective financial and property rights and obligations, including any and all claims which either of them may have against the other, including, without limitation: 1. The settling of all matters between them relating to the ownership of real and personal property, including property heretofore or subsequently acquired by either party; 2. The settling of all disputes, rights and/or interests between them arising out of or by reason of their marriage, including, but not limited to, all matters relating to equitable distribution of marital property, alimony pendent elite, spousal support and counsel fees; and 3. In general, the settling of any and all actual and possible claims by each party against the other or against their respective estates. NOW THEREFORE, in consideration of this Property Settlement Agreement, and of the mutual promises, covenants and undertakings set forth herein, and incorporating the above "WHEREAS" clauses herein by reference, the parties hereto, each intending to be legally bound hereby, covenant and agree as follows: 1. SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place as he or she may from time to time choose or deem fit. The foregoing provisions shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of the causes leading to their living apart. 2. INTERFERENCE: Each party shall be free from interference, authority and contact by the other, as fully as if he or she were single and unmarried except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other or attempt or endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the other's peaceful existence, separate and apart from the other. 3. WIFE'S DEBTS: Wife represents and warrants to Husband that since the separation she has not and in the future she will not contract or incur any debt or liability for which Husband or his estate might be responsible, and that she shall indemnify and save harmless Husband from any and all claims or demands incurred by her. 4. HUSBAND'S DEBTS: Husband represents and warrants to Wife that since the separation he has not and in the future he will not contract or incur any debt or 2 liability for which Wife or her estate might be responsible, and that he shall indemnify and save harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. 5. OUTST ANDING JOINT DEBTS: All debts, obligations or liabilities incurred at any time in the past by either of the parties will be paid promptly by the party which incurred such debt, obligation or liability, unless except as otherwise specifically set forth in this Agreement. Each of the parties hereto further promises, covenants and agrees that each will now and at all times hereafter save harmless and keep the other or his or her estate indemnified and saved harmless from all debts or liabilities incurred by him or her, as the case may be, and from all actions, claims and demands whatsoever with respect thereto, and from all costs, legal or otherwise, and counsel fees whatsoever appertaining to such actions, claims and demands. Neither party shall, after the date of this Agreement, contract or incur any debt or liability for which the other or his or her property might be responsible, and shall indemnify and save harmless the other from any and all claims or demands made against her or him by reason of debts or obligations incurred by her or him, and from all costs, legal costs and counsel fees incurred in connection therewith unless provided to the contrary herein. Husband agrees to be solely and separately responsible for any and all corporate tax debts which have arisen or which may in the future as a result from the filing of any tax returns up and until the date of separation, January 3, 2001, and save harmless Wife from any and all claims or demands made against her by reason of such tax debts or obligations and from all costs, legal costs and counsel fees incurred by Wife in connection therewith. 3 6. SAVINGS, CHECKING, AND INVESTMENT ACCOUNTS: Husband and Wife are owners of individual savings, checking and investment accounts at various institutions, and Husband hereby releases all claims in and to all accounts in the name of Wife, and Wife hereby releases all claims in and to all accounts in the name of Husband, and each party shall retain as his or her separate property each account currently titled to that party. Husband and Wife agree to sign, upon request and after execution of this Agreement, any titles or any other documents reasonably necessary to give effect to this Section. In addition, Husband and Wife agree that Husband will be the sole and separate owner of all shares of stock in the Silver Hills Mining Stock. 7. HUSBAND'S RELEASE: Husband does hereby release, remIse, quitclaim, and forever discharge Wife and the Estate of Wife from any and all claims that he now has or may hereafter have against Wife, or in, to, or against her Estate or any part thereof, whether arising out of any former contracts, agreements, engagements, or liabilities of Wife, or by way of dower or claim in the nature of dower, spouse's right or under any intestate laws or the right to take against Wife's Will, or for equitable distribution, support, alimony, alimony pendente lite, or maintenance of any other nature whatsoever, excepting only those rights accruing to Husband under this Postnuptial Agreement. 8. WIFE'S RELEASE: Wife does hereby release, remise, quitclaim, and forever discharge Husband and the Estate of Husband from any and all claims that she now has or may hereafter have against Husband, or in, to, or against his Estate or any part thereof, whether arising out of any former contracts, agreements, engagements, or liabilities of Husband, or by way of dower or claim in the nature of dower, spouse's right or under any intestate laws or the right to take against Husband's Will, or for equitable 4 - , distribution, support, alimony, alimony pendente lite, or maintenance of any other nature whatsoever, excepting only those rights accruing to Wife under this Postnuptial Agreement. 9. MUTUAL INDEMNIFICATION: Each party represents that no debts, liabilities, or obligations have been incurred or contracted for for which the other party or the Estate of the other party may be responsible or liable, except those specifically identified in this Agreement. Each party hereto shall hereafter keep the other and his or her heirs and personal representatives indemnified and saved harmless against and from all debts and liabilities contracted for or incurred by or on behalf of the indemnifying party, and against and from all actions, proceedings, claims, demands, costs, attorneys' fees and expenses incurred in respect to any such debts or liabilities, excepting, however, obligations of the parties hereto to each other under this Agreement. 10. CHILD/SPOUSAL SUPPORT: Husband and Wife agree that Husband shall pay child support in the amount of $1,000.00 per month until June 1, 2002. Beginning June 1, 2002, Husband agrees to pay child support in the amount of $600.00 per month for Ryan until he reaches the age of 18 or graduates from high school, whichever happens later. Husband and Wife also agree that Husband shall waive any over-payment made prior to October 1, 2002, and Wife will waive all claims for spousal support now or in the future. 11. DIVISION OF PERSONAL PROPERTY: The parties have divided between them, to their mutual satisfaction, their personal property and the personal effects, household furniture and furnishings, and all other articles of personal property which have theretofore been used by them in common, and neither party will make any 5 claim to any items of personal property which are now in the possession or under the control of the other. Should it become necessary, the parties each agree to sign any titles or documents necessary to give effect to this paragraph upon request. 12. PENSIONIRETIREMENT ACCOUNTS: Husband and Wife agree that Wife shall maintain her retirement account with her employer as her sole and separate property and Husband waives any claim in the same. Husband and Wife also agree that Wife shall receive the sum of $12,000.00 from Husband's Federal Retirement Account known as the "Thrift Savings Plan". Wife will receive this as a direct cash payment and will be solely and separately responsible for any income tax and fees, as directed by the Thrift Savings Plan. Husband and Wife shall effectuate this transfer pursuant to and in accordance with the terms of the Stipulation for the Entry of a Retirement Benefits Court Order ("the Stipulation," herein) executed by the parties contemporaneously with their execution of this Agreement. A copy of the Stipulation is attached hereto as Exhibit A and incorporated herein by reference. Husband and Wife agree that Wife's Counsel shall submit the Stipulation to the Court of Common Pleas of Cumberland County, Pennsylvania, requesting that the Stipulation be entered as an Order of Court. 13. LIFE INSURANCE POLICIES: Husband and Wife agree to WaIve any and all claims and relinquish all rights and interest they may have in any and all life insurance policies of the other. 14. COUNSEL FEES: Husband and Wife agree to pay their respective counsel fees and hereby waive any claim against the other for the same. 6 15. BREACH: If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, to sue for specific performance, and to seek such other remedies or relief as may be available to him or her, and the party breaching this contract shall be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement. 16. BANKRUPTCY: If Husband files for bankruptcy within five (5) years of the date of this Agreement, this Agreement shall constitute conclusive evidence of the parties' intent that the obligations of this Agreement are in the nature of equitable distribution and are not dischargeable in bankruptcy under the current bankruptcy law or any amendment thereto. If any payments made to Wife are deemed a preference by a court of competent jurisdiction in bankruptcy, the parties agree that this Agreement shall be null and void as a resolution of Wife's economic claims in a divorce action filed in the Court of Common Pleas in and for Cumberland County, Pennsylvania at Docket Number 01-4129. Wife shall have the right to prosecute her economic claims in the divorce action as if this Agreement had not been entered and any order of support in any form shall be effective retroactive to the date of discharge or the date of receipt of any payment Wife is required to repay. If Husband's bankruptcy petition does not, in any way, alter, change or disrupt the terms and conditions of this Agreement, then this Agreement shall remain in full force and effect. 17. ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge, and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. 7 18. VOLUNTARY EXECUTION: Wife has employed and had the benefit of counsel from Elizabeth S. Beckley, Esquire, as her attorney. Husband has employed and had the benefit of counsel from Michael S. Travis, Esquire, Esquire, as his attorney. Each party acknowledges that he or she fully understands the facts and has been fully informed as to his or her legal rights and obligations, and each party acknowledges and accepts that this Agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and/or with such knowledge as each party desires, and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. Also, each party hereto acknowledges that under the Pennsylvania Divorce Reform Act, the Court has the right and duty to determine all marital rights of the parties, including divorce, alimony, alimony pendente lite, equitable distribution of all marital property or property owned or possessed individually by the other, counsel fees and costs of litigation and, fully knowing the same and being advised of his or her rights thereunder, each party hereto still desires to execute this Agreement, acknowledging that the terms and conditions set forth herein are fair, just, and equitable to each of the parties, and each party waives their respective right to have the Court of Common Pleas or any Court of competent jurisdiction make any determination or order affecting the respective parties' right to a alimony, alimony pendente lite, equitable distribution of all marital property, counsel fees and costs of litigation. 19. WAIVER OF LIABILITY: Husband and Wife each knowingly and understandingly waive any and all possible claims that this Agreement is, for any reason, illegal or, for any reason whatsoever of public policy, unenforceable in whole or in part. Husband and Wife each does hereby warrant, covenant and agree that, in every possible event, he or she is and shall forever be estopped from asserting any illegality or 8 unenforceability as to all or any part of this Agreement. 20. ENTIRE AGREEMENT: This Agreement contains the entire understanding of the parties, and there are no representations, warranties, covenants, or undertakings other than those expressly set forth herein. This Agreement shall be binding upon the parties hereto, and there respective heirs, executors, administrators and assigns. 21. MODIFICATION AND WAIVER: A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed by both parties with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 22. INV ALID PROVISIONS: If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise. then only that term, condition, clause or provision shall be stricken from the Agreement. and in all other respects the Agreement shall be valid and continue in full force. effect and operation. Likewise, the failure of any party to meet his or her obligations under any one or more of the Paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way void or alter the remaining obligations of the parties. 23. LAW OF AGREEMENT: This Agreement shall be construed according to the laws of the Commonwealth of Pennsylvania and the United States of America in effect at the time of the Agreement's execution. 9 24. DESCRIPTIVE HEADINGS: The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above-written. ~?~~ ESro[Ood l ~ Diane F. Good uZ lLJ COMMONWEAL TH OF PENNSYLVANIA COUNTY OF Cum be.rlc,flcl ) ) SS.: ) On this therJ<llf] day of rc h/U.Uf(} ,2003, before me, the undersigned officer, personally appeared Esrom E. Good, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. Notarial Seal Hope. A. Mattos, Notary Public Ca~p H,U 8.010, Cumberland County My C.ommlsslon Expires Oct. 1'1, 2004 Member, pennSYlVar;;;;-AsSOCiaiiOriOTNOianes '~f2-L /J. m#:'S Notary Public My Commission Expires: 10 COMMONWEALTH OF PENNSYL VANIA ) ) SS.: ) ,'" . COUNTY OF IJLtt-<Atf4-<-'1U vi .------ / On this the /1 -+lfJ day of i:t2tU.....-L1.L. , 2003, before me, the undersigned /1 officer, personally appeared Diane F. Good, known to me (or satisfactorily proven) to be the person ':Vhose name is subscribed to the within instrument, and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. L~ L.,JL',..;r.-L/ ~. / t- Notary Public I - ~>~.~-<../ My Commission Expires: l~--NlTIARlAL"SEAL~-"'O..OO~ GER/\LDINE J. SCRBACIC, Notary Public City of H:misburg, Dauphin County My C.ommission Expire', Nov, 20, 2006 __._~'~ ,.'" ~. '~"_-~' ~,_"_.'''-C ......"'"""""'...-.."''''-..........=--_''".,.,..~._'_.....~_~. 11 Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA DIANE F. GOOD, v. :CIVIL ACTION - LA W :IN DIVORCE ESROM E. GOOD, Defendant :NO.01-4129 RETIREMENT BENEFITS ORDER AND NOW, this day of ,200_, pursuant to the request of the parties, the Stipulation attached hereto as Exhibit A is hereby entered as an Order of this Court. The terms of the Stipulation are incorporated, but not merged, into this Order. BY THE COURT: , J. - I - t to. . Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA DIANE F. GOOD, v. :CIVIL ACTION - LAW :IN DIVORCE ESROM E. GOOD, Defendant :NO.01-4129 STIPULA TION FOR THE ENTRY OF A RETIREMENT BENEFITS ORDER AND NOW, this;)..4 day of L.!li '" ,20Q)the parties, Diane F. Good, Plaintiff, and Esrom E. Good, Defendant, do hereb agree and stipulate as follows: 1. The Defendant, Esrom (hereinafter referred to as "Member"), is a participant in the Federal Retirement Thrift Savings Plan (hereinafter referred to as "TSP"). 2. SERS, as a creature of statute, is controlled by Statute, 5 U.S.c. ~~8435(c), 8467 and 5 C.F.R. part 1653, subpart A. 3. Member's date of birth is September 15, 1948, and his Social Security number is 502-56-6181. 4. The Plaintiff, Diane F. Good (hereinafter referred to as "Payee"), is the former spouse of Member. Payee's date of birth is August 5, 1955, and her Social Security number is 182-46-4277. 5. Participant's last known mailing address is: Mr. Esrom E. Good 150 N. 63rd Street Harrisburg, P A 17111. - 1 - EXHIBIT 'A' <II I' . 6. Payee's current mailing address is: Ms. Diane F. Good 1029 Hemlock Lane Enola, P A 17025 It is the responsibility of Payee to keep a current mailing address on file with TSP at all times. 7. It is agreed that Plaintiff, Diane F. Good, shall be awarded a lump sum payment of $12,000.00 from the Thrift Savings Plan of Esrom E. Good as of the Date of the attached Order. 14. It IS specifically intended and agreed by the parties hereto that this Stipulation: (a) Does not require TSP to provide any type of benefit, or any option, not otherwise provided under the Retirement Code; and (b) Does not require TSP to provide increased benefits (determined on the basis of actuarial value). 15. The parties intend and agree that the terms of this Stipulation shall be approved, adopted and entered as a Retirement Benefits Order. The parties hereby authorize Plaintiff's Counsel to present this Stipulation to the Court, together with a motion requesting both that this Stipulation be entered as an Order of Court, and that the terms hereof be incorporated, but not merged, into the Order. 16. The Court of Common Pleas of Cumberland County, Pennsylvania, shall retain jurisdiction to amend any Retirement Benefits Order incorporating this Stipulation, but only for the limited purpose of establishing or maintaining it as a Retirement Benefits - 2 - ...' ~' \ , " . Order. The Court shall have no power, however, to alter any of the terms of this Stipulation, including without limitation the manner in which the marital property component of Participant's retirement benefit, and the equitable distribution portion payable to Payee, shall be calculated. 17. Upon entry as a Retirement Benefits Order, certified copies of the Retirement Benefits Order and this Stipulation and any attendant documents shall be served upon TSP immediately. The Retirement Benefits Order shall take effect immediately upon its approval by TSP, and upon TSP's approval of any attendant documents, and it shall remain in effect until further Order of Court. WHEREFORE, the parties hereto, intending to be legally bound by the terms of this Stipulation, have hereunto placed their hands and seals the day and year first above written. ~---- ~4/ Esrom E. Good, Defendant/Participant j)/V"~ ~ 1J&-t~ Diane F. Good, Plaintiff/Payee /:;~~;~,;-;. ~ -- ..r" /~,::~~:~~-/~",~v:/'~_:~~:/:/~ .." .v/ /'/ C /' Co" C" ,- ._/ -t<1ichael S. Travis, Esquire 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 Attorney for Esrom E. Good - / /7" :---1 /! I ' > 1 / / /! / L./ ~, 'l--., . 1:.- ,/ ElizsdJeth S. Beck , ui BECKLEY & MADDEN 212 N. Third Street P.O. Box 11998 Harrisburg, P A 17108 (717) 233-7691 Attorney for Diane F. Good - 3 - o VJ \.) t. ~ ~ " ;Y 9--~: ;~--: < C;, -.(.._" ~~~: i._ --- ~ ;- ',-'~ . ~;E L_~ _.~! -, N VI ~ .~ C) C~ '- '0 <<"'M) --<.. DIANE F. GOOD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE ESROM E. GOOD, Defendant : NO. 01-4129 PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following information, to the Court for the entry of a Decree of Divorce. 1. Ground for divorce: irretrievable breakdown of the marriage under Section 3301(c) ofthe Divorce Code. 2. Date and manner of service of the Complaint: the complaint was served on Esrom E. Good, on July 27,2001, by certified mail. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by plaintiff on March 10,2003; by defendant on March 6,2003. 4. Related claims pending: All economic claims have been resolved. 5. (a) Date plaintiff's Waiver of Notice March 10, 2003, and it is being filed contemporaneously herewith. (b) Date defendant's Waiver of Notice March 6,2003, and it is being filed contemporaneously herewith. DATED: OlIO JdJJ5 Respectfully submitted, of Counsel BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, P A 17108 (717)233-7691 ...-.r._~..^ o v.l o <:; 9~t>" t'}~ ../ ~~~ ~~s~ ~ ... C! ;:r <:s N .t::. ~ ;3 ~__,___.__--- ~_ ...-00 c ~-l -:. '....) --- DIANE F. GOOD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE ESROM E. GOOD, Defendant : NO. 01-4129 PRAECIPE TO WITHDRAW EQUITABLE DISTRIBUTION, ALIMONY AND ALIMONY PENDENTE LITE, COUNSEL FEES, COSTS AND EXPENSES COUNTS TO THE PROTHONOTARY: Kindly withdraw the Equitable Distribution, Alimony and Alimony Pendente Lite, Counsel Fees, Costs and Expenses Counts filed in the above-captioned action. DATED: 3/loJJ.CoJ Respectfully submitted, of Counsel BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108 (717)233-7691 Q; UJ o S ..;;:~" g)}~ "':;;;r ~r -- 'j::: ~ 2;; p- ~ <;:l ..., (" T <5 '" ~ ~ ~ .c=" , L_ . . ) c:. .'0 ~~... Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA DIANE F. GOOD, v. :CIVIL ACTION - LA W :IN DIVORCE ESROM E. GOOD, Defendant :NO. 01 - -'II,).'! ~&'ot.l ~~ 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 for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, Pennsylvania 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA DIANEF. GOOD, Defendant :CIVIL ACTION - LA W :IN DIVORCE :NO. 01- '-II J q CtJ:t1 '-r~ v. ESROM E. GOOD, COMPLAINT AND NOW comes the Plaintiff, Diane F. Good, who, by and through her attorneys, Thomas A. Beckley, Esquire, Elizabeth S. Beckley, Esquire, and Beckley & Madden, of Counsel, files this Complaint, in which she avers that: 1. Plaintiff, Diane F. Good, is an adult individual residing at 1029 Hemlock Lane, Enola, Cumberland County, Pennsylvania 17025. 2. Defendant, Esrom E. Good, is an adult individual residing at 150 North 63rd Street, Harrisburg, Dauphin County, Pennsylvania 17111. 3. Both parties were bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of the original Complaint. 4. Plaintiff and Defendant were married on May 23, 1981, in Harrisburg, Pennsylvania. 5. There have been no prior actions in divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and that Plaintiff or Defendant has the right to request the Court to require the parties to participate in such counseling. COUNT I REQUEST FOR A NO-FAULT DIVORCE UNDER SECTIONS 3301(c) OR (d) OF THE DIVORCE CODE 8. The averments contained in Paragraphs I through 7 of this Complaint are incorporated herein by reference as though set forth in full. 9. Plaintiff's marriage to Defendant is irretrievably broken. 10. Plaintiff has been advised that counseling is available and that she may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, pursuant to 23 Pa.C.S.A. ~~3301(c) or (d), Plaintiff, Diane F. Good, respectfully requests the Court to enter a Decree of Divorce. COUNT II EQUITABLE DISTRIBUTION II. The averments contained in Paragraphs I through 10 of this Complaint are incorporated herein by reference as though set forth in full. 12. Plaintiff and Defendant have acquired property, both real and personal, during the marriage which constitutes marital property subject to equitable distribution under the Divorce Code. 13. Plaintiff and Defendant each owned, prior to the marriage, both real and personal property which has increased in value during the marriage, and/or which has been exchanged for other property which has increased in value during the marriage, all of which property is marital property, subject to equitable distribution under the Divorce Code. 14. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Plaintiff, Diane F. Good, respectfully requests the Court to divide all marital property equitably between the parties. 2 COUNT III REQUEST FOR ALIMONY 15. The averments contained in Paragraphs 1 through 14 of this Complaint are incorporated herein by reference as though set forth in full. 16. Plaintiff lacks sufficient property to provide for her reasonable means and is unable to support herself in accordance with the standard of living established during the marriage. 17. Plaintiff requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. WHEREFORE, Plaintiff, Diane F. Good, respectfully requests the Court to enter an award of alimony in her favor. COUNT IV ALIMONY PENDENTE LITE, COUNSEL FEES, COSTS AND EXPENSES 18. The averments contained in Paragraphs 1 through 17 of this Complaint are incorporated herein by reference as though set forth in full. 19. Plaintiff has employed counsel, but is unable to pay the necessary and reasonable attorney's fees for said counsel. 20. Plaintiff is unable to sustain herself during the course of this litigation. WHEREFORE, Plaintiff, Diane F. Good, respectfully requests the Court to enter an award of Alimony Pendente Lite, interim counsel fees, costs and expenses, until final hearing and thereupon award such additional counsel fees, costs and expenses as deemed appropriate. DATED: Gkl/q submitted, of Counsel BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108 (717) 233-7691 3 . ' VERIFICA nON I, Diane F. Good, hereby verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties 18 Pa. C. S, Section 4904, relating to unsworn falsification to authorities. DATED: U f;q( 0 l ~~~ 0;[ 1i~ Diane F. Good DIANE F. GOOD, vs. ESROM E. GOOD, To the Prothonotary: Plaintiff Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW : IN DIVORCE : NO. 01-4129 CIVIL TERM Entry of Appearance Please enter my appearance on behalf of the Defendant, Esrom Good, in the above captioned matter. Date: rj;)/ chael S. Travis Attorney for Defendant, Esrom Good DIANE F. GOOD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA VS. : CIVIL ACTION - LAW : IN DIVORCE ESROM E. GOOD, Defendant : NO. 01-4129 CIVIL TERM CERTIFICATE OF SERVICE I, Michael S. Travis, certify that I have this day served a true and correct copy of the foregoing document by first class mail, postage prepaid, on the following person, addressed as follows: Elizabeth S. Beckley, Esquire BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108 Dated: r;J ft / ~. ael S. Travis ID No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 Fax 731-9511 Attorney for Defendant C" - (} c;; ....~ _,j i'] p'l'" k~\ z.~. <[L ~8 .7C .~ ~ ';;..:.; \ _....1 -'0 :-;; C:J -:i - - (1"' - Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA DIANE F. GOOD, v. :CIVIL ACTION - DIVORCE ESROM E. GOOD, Defendant :NO.01-4129 AFFIDAVIT OF SERVICE I, Elizabeth S. Beckley, being duly sworn according to law, do depose and say: 1. I am an adult individual over eighteen years of age. 2. I served the Divorce Complaint of Diane F. Good upon Esrom E. Good, at 150 N. 63rd Street, Harrisburg, Pennsylvania 17111, on or about July 27, 2001, by certified mail, parcel number 7099 3400 0016 3620 9294, return receipt requested. Attached hereto is the return receipt (green card) signed by the Defendant. Sworn and subscribed to before me this ~ day of (D(li;;JM/ ,2001. .0L (SEAL) NOTARIAL SEAL MARY V. DAVIS, ~PubIlC ~ of HarrIsburg In County My Commission ExpIres 30, 2002 SENDER: COMPLETE THIS SECT/ON . Complete items 1,.2, and 3. Also complete item 4 if "Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: #' [~-L_m.J C /L~ /,FC /1. l~~~ /j~<iitfR(CTEo DELIVERY *- 3. Se~Type B'"Certified Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? -(Extra Fee) es 2. Article Number (Copy from service label) /,7'1 d!t~z) ('elite J,{,.J,,1 7.J- /'/ PS Form 3811, July 1999 Domestic Return Receipt IF '/31!rJ 102595-99-M.1789 0. r-J L--I s ;5 -rJf nl, ~-= : ZC (fJ~ [~C c';l- ~~~ -C ;: ~ I'v -f::- v.J "D ~ -< ~ ':".- Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA DIANE F. GOOD, v. :CIVIL ACTION - LA W : IN DIVORCE ESROM E. GOOD, Defendant :NO.01-4129 AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on July 3, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. Dated: 3 -/C)/t7.3 ~. cJ'~ y--l'v...t ~ . ! Diane F. Good . \. c ~ ".~) ~~'L t,~l \ : ~l "~.'.". ,,"": - (I: r:~ t_ ' /~ > '''::> { j", -----..-~_.- Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA DIANE F. GOOD, v. :CIVIL ACTION - LAW : IN DIVORCE ESROM E. GOOD, Defendant :NO.01-4129 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concernmg alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Dated: 3 -/0-03 (\ \, ; ------~/ · J _ ^ . ".j~,:, ,i I~j~~ 1--_ Diane F. Good o vJ o ~:; ...:: """t.1 i_:-"~' S2~:',;: 2~1' Cf) -,. ~ $l. .... r\ 7 _':,' r~':' \ -' L-. > ~ N V\ ~ 1 -',) f t: ~ Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA DIANE F. GOOD, v. :CIVIL ACTION - LAW : IN DIVORCE ESROM E. GOOD, Defendant :NO.01-4129 AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on July 3, 200 I. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Dated: <' ~ / //(P/o:? z~ z~J Esrom E. Good o ~ 92'i ~_../ ~ ,,+ ,~~ -~ ~~..- -~::... / J>-" c_ ::::) -:, c ",,) (J, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA DIANE F. GOOD, v. :CIVIL ACTION - LAW : IN DIVORCE ESROM E. GOOD, Defendant :NO.01-4129 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concernmg alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa,C.S. * 4904 relating to unsworn falsification to authorities. Dated: '7 ~ /0 :3 z~z~/ Esrom E. Good ~ v.J o ~~ ~~f, ~ j:) ., n y cT! . ~:~ -.'. -.- 1~; ~> ...... () r-v v'1 \S ) -\,...J._j ',) ( , ' .... . DIANE F. GOOD, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA Defendant :CNIL ACTION - LAW :IN DNORCE :NO. 01- 1f1d."1 C,"u:L '7-~ v. ESROM E. GOOD, PLAINTIFF'S RESPONSE TO DEFENDANT'S MOTION TO COMPEL PLAINTIFF TO ANSWER INTERROGATORIES AND NOW comes the Plaintiff, Diane F. Good, who, by and through her attorneys, Thomas A. Beckley, Esquire, Elizabeth S. Beckley, Esquire, and Beckley & Madden, of Counsel, files this Response to Defendant's Motion to Compel Plaintiff to Answer: 1. Admitted. 2. Admitted. 3. Admitted. 4. Denied. To the contrary, Counsel for the Plaintiff has provided Counsel for Defendant requested information prior to Defendant's discovery requests. 5. Admitted. 6. It is admitted that Plaintiffs Counsel received a copy of the letter attached as Exhibit A to Defendant's Motion to Compel Plaintiff to Answer Interrogatories. 7. Denied. Plaintiff is without sufficient information to form a a belief as to the truth or accuracy of this allegation, and therefore said allegation is denied. By way of further response, Plaintiff has served her Response to Defendant's Interrogatories on May 24,2002. 8. Denied. Defendant has suffered no prejudice whatsoever. This case has not yet been listed for a Master's hearing, furthermore, without both parties' consent a divorce could not be entered at this time as the parties' have not lived seperate and apart for at least two years. WHEREFORE, Plaintiff, Diane F. Good, respectfully requests the Court to Dismiss Defendant's Motion to Compel Plaintiff to Answer Interrogatories as moot. DATED: 5"-)L/-{1) Res~. ~~:bmitted, ~~ ~~~--~--_/ Thomas A. Beckley of Counsel BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, P A 17108 (717) 233-7691 2 VERIFICATION I, Diane F. Good, hereby verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. DATED: ,<::; --JL(&)- CJ. ~~ ~ 7-. Diane F. Good CERTIFICATE OF SERVICE I, Elizabeth S. Beckley, Esquire, hereby certify that a true and correct copy of the foregoing document was this day served upon the person and in the manner indicated below. SERVICE BY FIRST CLASS MAIL: Michael S. Travis, Esquire 4076 Market Street, Suite 209 Camp Hill, PA 17011 DATED: ~-~ s ~ N 0> <(J CJb '"0:) ~ c-' C.'- ~. :::< :'.) (.)) '! _[I . --...1""" :.<.) ) j-n .:~'I :D -< (::) DIANE F. GOOD, PlaintifflPetitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE ESROM E. GOOD, DefendantJRespondent NO. 2001-4129 CIVIL TERM IN DIVORCE DR# 31919 PacseS# 991104715 ORDER OF COURT AND NOW, this 8th day of August, 2002, upon consideration of the attached Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.l Shadday on September 9, 2002 at 9:00 A.M. for a conference, at 13 N. Hanover St., Carlisle, P A 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11<9 (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, George E. Hoffer, President Judge Mail copies on 8-9-02 to: Petitioner < Respondent /[ ~// ......</-. 'oJ Date of Order: August 8, 2002 y, Conference Officer YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP. , ~ ,y u , 'v~ ' , fcj~k(/ CUMBERLAND COUNTY BAR ASSOCIATION 2 LffiERTY A VB, CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 \,.'\ ;'-1\} l\\ \sr\~-~'3d ^,' '-''-'..' "n'"' . :..;_.-.~-~j\~ tv ,.., ' , ':1",,\ . .~ .') ;;.d ('. :J;YJ {,O _._-~-'-~~ ._~-,~._.~.,"'--~--- .. e e ill.} /1///.-7/( . ! ' l/ /' J Plaintiff :IN THE COURT OF COMMON PLEAS OF '- ! fl' Y :CUMBERLAND COUNTY, PENNSYLVANIA DIANE F. GOOD, v. :CIVIL ACTION - LAW :IN DNORCE ,:3 I 9/7 ESROM E. GOOD, Defendant :NO. 01 ... -'l1J..'j C;o,L J-~ NOTICE TO DEFEND AND CLAIM RIGHTS r ._, YOU HAVE BEEN SUED IN COURT. If you wish to defend against thd.claims set forth in the following pages, you must take prompt action. You are warned fha't, if ybU fail to do so, the case may proceed without you and a decree of divorce or annulment ma,y be entered against you by the court. A judgment may also be entered against fOt-any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, Pennsylvania 17013 IF YOU DO NOT FILE A CLAIM FOR, ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE TIDS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHOl'TE THE OFFICE SET FORTH BELO~! TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA DIANE F. GOOD, v. :CIVIL ACTION - LAW :IN DIVORCE ESROM E. GOOD, Defendant :NO. COMPLAINT AND NOW comes the Plaintiff, Diane F. Good, who, by and through her attorneys, Thomas A. Beckley, Esquire, Elizabeth S. Beckley, Esquire, and Beckley & Madden, of Counsel, files this Complaint, in which she avers that: 1. Plaintiff, Diane F. Good, is an adult individual residing at 1029 Hemlock Lane, Enola, Cumberland County, Pennsylvania 17025. 2. Defendant, Esrom E. Good, is an adult individual residing at 150 North 63rd Street, Harrisburg, Dauphin County, Pennsylvania 17111. 3. Both parties were bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of the original Complaint. 4. Plaintiff and Defendant were married on May 23, 1981, in Harrisburg, Pennsylvania. 5. There have been no prior actions in divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and that Plaintiff or Defendant has the right to request the Court to require the parties to participate in such counseling. -- e e COUNT III REQUEST FOR ALIMONY 15. The averments contained in Paragraphs 1 through 14 of this Complaint are incorporated herein by reference as though set forth in full. 16. Plaintiff lacks sufficient property to provide for her reasonable means and is unable to support herself in accordance with the standard of living established during the marriage. 17. Plaintiff requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. WHEREFORE, Plaintiff, Diane F. Good, respectfully requests the Court to enter an award of alimony in her favor. COUNT IV ALIMONY PENDENTE LITE, COUNSEL FEES, COSTS AND EXPENSES 18. The averments contained in Paragraphs 1 through 17 of this Complaint are incorporated herein by reference as though set forth in full. 19. Plaintiff has employed counsel, but is unable to pay the necessary and reasonable attorney's fees for said counsel. 20. Plaintiff is unable to sustain herself during the course of this litigation. WHEREFORE, Plaintiff, Diane F. Good, respectfully requests the Court to enter an award of Alimony Pendente Lite, interim counsel fees, costs and expenses, until final hearing and thereupon award such additional counsel fees, costs and expenses as deemed appropriate. DATED: G/Jr/oj R~ sub~tted, ~%~~- as A. Beckley of Counsel BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, P A 17108 (717)233-7691 3 VERIFICA TION I, Diane F. Good, hereby verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. DATED: u/fq{ 0\ ~H.J uz Jl-J Diane F. Good DIANE F. GOOD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW ESROM E. GOOD, Defendant NO. 01-4129 CIVIL TERM ORDER OF COURT AND NOW, this 17th day of May, 2002, upon consideration of Defendant's Motion To Compel Plaintiff To Answer Interrogatories, a Rule is hereby issued upon the Plaintiff to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. BY THE COURT, ~lizabeth S. Beckley, Esq. 212 North Third Street P.O. Box 11998 Harrisburg, P A 17108 Attorney for Plaintiff > tJJfW~ 1~~ 0.5 . I '7 .0:<. At( Michael S. Travis, Esq. 4076 Market Street Suite 209 Camp Hill, PA 17011 Attorney for Defendant :rc V1NV/\l,\Si\jN3d )\.jJ\!nC;~) ~'r;:)-:S~/'Jn8 "'" : I ! ~ L \:! + "':-'" :'1 u . " ~' ~ t r~, L DIANE F. GOOD, Plaintiff/Respondent MAY 1 ~ : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 01-4129 CIVIL ESROM E. GOOD, DefendantlMovant : IN DIVORCE ORDER OF COURT AND NOW, this day of , 2002, upon consideration ofthe allegations set forth in the attached Motion to Compel Answers to Written Interrogatories, it is hereby ORDERED AND DIRECTED as follows: Plaintiff shall answer Defendant's written interrogatories within fifteen (15) days of this Order of Court. By the Court, J. Elizabeth S. Beckley, Esquire Attorney for Plaintiff/Respondent Michael S. Travis, Esquire Attorney for Defendant/Movant DIANE F. GOOD, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 01-4129 CIVIL ESROM E. GOOD, Defendant/Movant : IN DIVORCE RULE TO SHOW CAUSE AND NOW, this _ day of , 2002, upon consideration of the allegations set forth in the attached Motion to compel Answers to Written Interrogatories, a Rule is issued upon Plaintiff to show cause why she should not be required to file a written response to Defendant's Interrogatories. days of service. Rule Returnable within By the Court, J. Elizabeth S. Beckley, Esquire Attorney for Plaintiff/Respondent Michael S. Travis, Esquire Attorney for Defendant/Movant DIANE F. GOOD, PlaintiffJRespondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 01-4129 CIVIL ESROM E. GOOD, Defendant/Movant : IN DIVORCE CERTIFICATE OF CONCURRENCE OR NON-CONCURRENCE I, Michael S. Travis, hereby certify that I served a copy ofthe attached Motion upon Elizabeth Beckley, Esquire, on April 23, 2002. I further state that as ofthe date of filing the attached Motion, Elizabeth Beckely, Esquire did not concur with the contents of the attached Motion prior to the filing on the date set forth below. Date: >- 1.1 ~ o,l. ~. Attorney for Defendant 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 Michael S. Travis ID No. 77399 4076 Market Street. Suite 209 Camp Hill, P A 170 II (717) 731-9502 DIANE F. GOOD, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 01-4129 CIVIL ESROM E. GOOD, Defendant/Movant : IN DIVORCE MOTION TO COMPEL PLAINTIFF TO ANSWER INTERROGATORIES Defendant, Esrom E. Good, by and through his attorney, Michael S. Travis, files this Motion to Compel Plaintiff, Diane F. Good, to answer Defendant's Interrogatories and in support thereof respectfully states as follows: 1. Movant is Esrom E. Good, Defendant in the above-captioned divorce action. 2. Respondent is Diane F. Good, Plaintiff in the above-captioned divorce action. 3. The above-stated action for divorce includes related economic claims, including equitable distribution of property brought by Plaintiff. 4. Defendant, through counsel, repeatedly requested information necessary to prepare his case for trial. No response was received. 5. On March 11, 2002, the Defendant, by and through counsel, served an original and two sets of written Interrogatories upon Plaintiffs counsel, Elizabeth Beckley, Esquire. 6. On April 11, 2002, Defendant requested that Plaintiff complete the interrogatories. Defendant's transmittal letter of April 11, 2002 is attached hereto as Exhibit A. 7. Defendant is unable to move his case forward to trial without the requested information. 8. The failure ofPlaintiffto timely respond to the written interrogatories of Defendant prejudices Defendant in the preparation of his case and his ability to evaluate and respond to the claims of Plaintiff. WHEREFORE, Defendant respectfully requests that this Honorable Court enter the following Order: a. In accordance with Pa. R.C.P. No. 4019, Plaintiff is directed to Answer Defendant's Interrogatories forthwith, or in the alternative, prohibit Plaintiff as a non-compliant party from introducing any evidence, documents or testimony, which would have been provided to Defendant in Answers to the Interrogatories; and b. Granting Defendant the reasonable expenses, including attorney fees, incurred, in preparing and presenting this Motion and obtaining an Order of Court for compliance purposes; and c. Entering such further relief and granting such sanctions against Plaintiff as the Court may deem just and proper. Respectfully submitted, Date: ,,, I ~.o;)-. ~ ~squire 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 DIANE F. GOOD, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 01-4129 CIVIL ESROM E. GOOD, Defendant/Movant : IN DIVORCE VERIFICA nON I verify that the statements made in the foregoing Motion to Compel Answers to Interrogatories are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated: j~7~/~ z;~ Z ~~'&-/ Esrom E. Good, Defendant ~-@ MICHAEL S. TRAVIS ATTORNEY AT LAW 4076 MARKET STREET, SU ITE 209 CAMP HILL, PA 17011 TELEPHONE (717) 731-9502 FAX (717) 73/-9511 April 11,2002 Elizabeth S. Beckley, Esquire BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108 Re: Diane Good v. Esrom Good, No. 01-4129, In Divorce Answers to Interrogatories Directed to Plaintiff Dear Ms. Beckley: According to my records answers to Interrogatories Directed to Plaintiff are due. Please provide verified answers to the requested interrogatories within ten (l0) days so that we may avoid seeking relief from the court. Thank you for your attention to this matter. Very truly yours, MSTIhm j pc: Esrom Good DIANE F. GOOD, Plaintiff/Respondent vs. ESROM E. GOOD, Defendant/Movant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : No. 01-4129 CIVIL : IN DIVORCE CERTIFICATE OF SERVICE I, Michael S. Travis, certify that I have this day served a true and correct copy of the foregoing document by first class mail, postage prepaid, on the following person, addressed as follows: Dated: ..- ::> - I S -- 6"'2- Elizabeth S. Beckley, Esquire BECKLEY AND MADDEN 212 N. third Street P.O. Box 11998 Harrisburg, PA 17108 .cliael S. Travis ID No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717)731-9502 Fax 731-9511 Attorney for Debtor -- ----- -------- (') 0 (') c f'-.) 'T\ .- :C ""\"] " ::::~ :D IT, --< -''l r-- "'- - en :?: ~ -' 79 ({) C,,) _.'<.', .' () '.....,. -'"\ -r, "j.:':' -n L I"~ -~..\,~ ~;;;.. (~ ( --.\ i-n ;:," ". \"'-.) ~:;~ '- :~: ,) ~ry :..-~ (1' :::.:: - Mt: 4 2002 DIANE F. GOOD, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 01-4129 CIVIL ESROM E. GOOD, Defendant/Movant : IN DIVORCE RULE TO SHOW CAUSE AND NOW, this _ day of , 2002, upon consideration of the allegations set forth in the attached Motion to compel Answers to Written Interrogatories, a Rule is issued upon Plaintiff to show cause why she should not be required to file a written response to Defendant's Interrogatories. Rule Returnable within days of service. By the Court, J. Elizabeth S. Beckley, Esquire Attorney for Plaintiff/Respondent Michael S. Travis, Esquire Attorney for Defendant/Movant DIANE F. GOOD, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 01-4129 CIVIL ESROM E. GOOD, Defendant/Movant : IN DIVORCE RULE TO SHOW CAUSE AND NOW, this _ day of , 2002, upon consideration of the allegations set forth in the attached Motion to compel Answers to Written Interrogatories, a Rule is issued upon Plaintiff to show cause why she should not be required to file a written response to Defendant's Interrogatories. days of service. Rule Returnable within By the Court, J. Elizabeth S. Beckley, Esquire Attorney for Plaintiff/Respondent Michael S. Travis, Esquire Attorney for Defendant/Movant DIANE F. GOOD, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 01-4129 CIVIL ESROM E. GOOD, Defendant/Movant : IN DIVORCE RULE TO SHOW CAUSE AND NOW, this _ day of , 2002, upon consideration of the allegations set forth in the attached Motion to compel Answers to Written Interrogatories, a Rule is issued upon Plaintiff to show cause why she should not be required to file a written response to Defendant's Interrogatories. days of service. Rule Returnable within By the Court, 1. Elizabeth S. Beckley, Esquire Attorney for Plaintiff/Respondent Michael S. Travis, Esquire Attorney for Defendant/Movant DIANE F. GOOD, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 01-4129 CIVIL ESROM E. GOOD, DefendantlMovant : IN DIVORCE RULE TO SHOW CAUSE AND NOW, this _ day of , 2002, upon consideration of the allegations set forth in the attached Motion to compel Answers to Written Interrogatories, a Rule is issued upon Plaintiff to show cause why she should not be required to file a written response to Defendant's Interrogatories. Rule Returnable within days of service. By the Court, J. Elizabeth S. Beckley, Esquire Attorney for Plaintiff/Respondent Michael S. Travis, Esquire Attorney for Defendant/Movant DIANE F. GOOD, Plaintiff/Res pondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 01-4129 CIVIL ESROM E. GOOD, DefendantlMovant : IN DIVORCE RULE TO SHOW CAUSE AND NOW, this _ day of , 2002, upon consideration of the allegations set forth in the attached Motion to compel Answers to Written Interrogatories, a Rule is issued upon Plaintiff to show cause why she should not be required to file a written response to Defendant's Interrogatories. Rule Returnable within days of service. By the Court, J. Elizabeth S. Beckley, Esquire Attorney for Plaintiff/Respondent Michael S. Travis, Esquire Attorney for Defendant/Movant DIANE F. GOOD, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 01-4129 CIVIL ESROM E. GOOD, Defendant/Movant : IN DIVORCE RULE TO SHOW CAUSE AND NOW, this _ day of , 2002, upon consideration of the allegations set forth in the attached Motion to compel Answers to Written Interrogatories, a Rule is issued upon Plaintiff to show cause why she should not be required to file a written response to Defendant's Interrogatories. Rule Returnable within days of service. By the Court, J. Elizabeth S. Beckley, Esquire Attorney for Plaintiff/Respondent Michael S. Travis, Esquire Attorney for Defendant/Movant MA~ 2002 DIANE F. GOOD, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 01-4129 CIVIL ESROM E. GOOD, Defendant/Movant : IN DIVORCE ORDER OF COURT AND NOW, this day of , 2002, upon consideration of the allegations set forth in the attached Motion to Compel Answers to Written Interrogatories, it is hereby ORDERED AND DIRECTED as follows: Plaintiff shall answer Defendant's written interrogatories within fifteen (15) days of this Order of Court. By the Court, J. Elizabeth S. Beckley, Esquire Attorney for PlaintifflRespondent Michael S. Travis, Esquire Attorney for DefendantIMovant DIANE F. GOOD, PlaintifflRespondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 01-4129 CIVIL ESROM E. GOOD, Defendant/Movant : IN DIVORCE ORDER OF COURT AND NOW, this day of , 2002, upon consideration of the allegations set forth in the attached Motion to Compel Answers to Written Interrogatories, it is hereby ORDERED AND DIRECTED as follows: Plaintiff shall answer Defendant's written interrogatories within fifteen (15) days of this Order of Court. By the Court, J. Elizabeth S. Beckley, Esquire Attorney for Plaintiff/Respondent Michael S. Travis, Esquire Attorney for Defendant/Movant DIANE F. GOOD, PlaintiffIRespondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 01-4129 CIVIL ESROM E. GOOD, Defendant/Movant : IN DIVORCE ORDER OF COURT AND NOW, this day of , 2002, upon consideration of the allegations set forth in the attached Motion to Compel Answers to Written Interrogatories, it is hereby ORDERED AND DIRECTED as follows: Plaintiff shall answer Defendant's written interrogatories within fifteen (15) days of this Order of Court. By the Court, J. Elizabeth S. Beckley, Esquire Attorney for PlaintifflRespondent Michael S. Travis, Esquire Attorney for Defendant/Movant DIANE F. GOOD, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 01-4129 CIVIL ESROM E. GOOD, Defendant/Movant : IN DIVORCE ORDER OF COURT AND NOW, this day of ,2002, upon consideration of the allegations set forth in the attached Motion to Compel Answers to Written Interrogatories, it is hereby ORDERED AND DIRECTED as follows: Plaintiff shall answer Defendant's written interrogatories within fifteen (15) days ofthis Order of Court. By the Court, J. Elizabeth S. Beckley, Esquire Attorney for PlaintifflRespondent Michael S. Travis, Esquire Attorney for Defendant/Movant DIANE F. GOOD, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 01-4129 CIVIL ESROM E. GOOD, DefendantIMovant : IN DIVORCE ORDER OF COURT AND NOW, this day of , 2002, upon consideration of the allegations set forth in the attached Motion to Compel Answers to Written Interrogatories, it is hereby ORDERED AND DIRECTED as follows: Plaintiff shall answer Defendant's written interrogatories within fifteen (15) days of this Order of Court. By the Court, J. Elizabeth S. Beckley, Esquire Attorney for Plaintiff/Respondent Michael S. Travis, Esquire Attorney for Defendant/Movant DIANE F. GOOD, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 01-4129 CIVIL ESROM E. GOOD, Defendant/Movant : IN DIVORCE ORDER OF COURT AND NOW, this day of , 2002, upon consideration of the allegations set forth in the attached Motion to Compel Answers to Written Interrogatories, it is hereby ORDERED AND DIRECTED as follows: Plaintiff shall answer Defendant's written interrogatories within fifteen (15) days of this Order of Court. By the Court, J. Elizabeth S. Beckley, Esquire Attorney for PlaintifflRespondent Michael S. Travis, Esquire Attorney for DefendantIMovant Michael S. Travis ID No. 77399 4076 Market Street, Suite 209 Camp Hill, PA l7011 (717) 731-9502 Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA DIANE F. GOOD, VS. : No. 01-4129 CIVIL ESROM E. GOOD, Defendant : IN DIVORCE INVENTORY OF ESROM E. GOOD Defendant, Esrom E. Good, 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.C.S. Section 4904 relating to unsworn falsification to authorities. ?~ 74..-/ Esrom E. Good, Defendant MARITAL PROPERTY - ITEM NO.2 Esrom E. Good 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: Description of Property: 1993 Plymouth Van Titled Owner: Esrom Good Date of Acquisition: Cost or value as of Date of Acquisition: Value as of Date Action Commenced: $ 1,800.00 MARITAL PROPERTY - ITEM NO. 19a Esrom E. Good 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: Description of Property: Federal Thrift Savings Plan (TSP) Address: United States Government Account Number: 502-56-6181 Name of Owner: Esrom E. Good Participant Statement attached hereto as Exhibit A .~ . . THRIFT SAVINGS PLAN ~ P ARTlelP ANT STATEMENT For the period: 11/01/2000 through 04/30/2001 TSP-8-A Your Thrift Savings Plan rrSP) account statement is issued by the National Finance Center for the Federal Retirement Thrift Investment Board. Review your statement carefully; to correct account information, contact your agency employing office. Failure to report errors timely may preclude correction of financial transactions. (Report contribution allocation or interfund transfer errors to the TSP Service Office, (504) 255-6000, within 30 days of receiving this statement.) Social Security Number: 502-56-6181 Date of Birth: 09/15/48 Retirement Coverage: FERS (K) Separation Status: Not separlted Beneficiary Designltion on File:* No Name: ESROM E GOOD Total Service Required for Vesting: 3 Years from 09/29/96 rrsp Service Computation Date) *If you choose to submit Ii Beneficiary Designation (Form TSP-3). you are responsible for its correctness and completeness. Ending Balance Source of Contributions Total Employee Agency Automatic (1%) Agency Matching 0.00 128.69 0.00 128.69 27. 11 0.00 0.00 27.11 0.30 3.50 0.00 3.80 27.41 132. 19 0.00 159.60 Beginning Balance G FUND Transactions This Period Government Securities Investment Fund Earnings This Period F FUND Beginning Ballnce Transactions This Period Fixed Income Index Investment Fund Elrnings This Period Ending Balance G Fund F Fund C Fund .48% 1.65% (7.87%) .48% 1.86% .50% 11,318.20 2, 331 .78 9,327.28 22,971.26 8,549.95 334.04 1 .336. 16 10.220.15 1,544.14- 288.48- 1,153.93- 2.986.55- 18,324.01 2,377.34 9,509.51 30,210.86 11,318.20 2.460.47 9,327.28 23.105.95 8.577.06 334.04 1,336.16 10.247.26 1.543.84- 284.98- 1,153.93- 2,982.75- 18.351.42 2,509.53 9,509.51 30.370.46 2001 Last 12 Months January February March April (May 'OO-Apr '01) .46% .42% .45% .43% 6.01% 1.65% .87% .51% (.42%) 1 2.46% 3.55% (9.12%) (6.33%) 7.78% (12.95%) Beginning Balance C FUND Transactions This Period Common Stock Index Investment Fund Earnings This Period Ending Balance Beginning Ballnce TOTAL ACCOUNT BALANCE Transactions This Period Earnings This Period Rates of Return ** (Numbers in parentheses are negative) Ending Balance 2000 November December "Actual ratas of return after admini.trativ. .xp.n.... Th. monthly rat.. of r.turn are u..d to comput. the actual .arning. on your account each month, as describ.d on the back of this stat.m.nt. Th. Last 12 Months rat.s show the Inv.stm.nt performance of only that portion of your account that was inv.st.d for the .ntire 12 months. B.caus. of the timing and amount of your transactions. you cannot us. the Last 12 Months rat.s to calculat. your actual earnings for the May 2000 - April 2001 period. Th.r. is no assuranc. that past rat.s of r.turn will b. r.pllcat.d In the futur., Participants can now invest in two new funds: the Small Capitalizetion IS) and the International III Stock Index Inv.stment Funds. Also, employee contribution limits are now 11% for FERS .mployees and 11% for CSRS employ.... R.ad the TSP Hiahliaht$ for mar. information. 45974338181N TO 03 1517 69001103 05/01 T-OOOO4628 01138645 1 AT 0.267 02 TSP Open Season is May 15 - Ju1y 31. To change the amount of future payroll contributions, ask your personnel office for the TSP Election Form (TSP-1). 111I11111.11111...1.1.1.1.111.11111..1..1..11.111.11.1...1.1.1 ESROM E GOOD 1029 HEMLOCK LANE ENOLA PA 17025-2043 To change the way your money is Invested, use the Thr1ftL1ne or the TSP Web site. They are the most efficient ways to make, change, or cance1 a contribution a110cation or lnterfund transfer request. ThriftLine: (504) 255-8777 - Web site: www.tsp.gov ~f"'\nI\A Tt"'!:"l l"I 1'0 '''''~ _ _...J ~ '"'''' ~\ JET AIL OF ACCOUNT ACTIVITY - Jame: ESROM E GOOD ctivity Payroll :ode Office Pay Date Process Date MONTH-END BALANCE OCT 2000 69001103 11/14/00 11/13/00 69001103 11/28/00 11/27/00 11/30/00 D D P E MONTH-END BALANCE NOV 2000 69001103 12/12/00 12/08/00 69001103 12/26/00 12/22/00 12/31/00 D D P E MONTH-END BALANCE DEC 2000 69001103 01/09/01 01/05/01 69001103 01/23/01 01/19/01 01/31/01 D D P E MONTH-END BALANCE JAN 2001 69001103 02/06/01 02/02/01 69001103 02/20/01 02/16/01 02/28/01 D D P E MONTH-END BALANCE FEB 2001 69001103 03/06/01 69001103 03/20/01 69001103 04/03/01 D D D P E MONTH-END 03/02/01 03/16/01 03/30/01 03/31/01 BALANCE MAR 2001 o 69001103 04/17/01 04/13/01 P 04/30/01 E MONTH-ENO BALANCE APR 2001 Employee 11,318.20 269.68 269.68 476.06 930.62- 11,403.00 269.68 269.68 952. 12 60.18 12,954.66 269.68 281 . 28 952. 12 486.09 14,943.83 285. 12 285. 12 952. 12 1,430.34- 15,035.85 285. 12 285. 12 285. 12 952. 12 1,006.98- 15,836.35 285. 12 952. 12 1,277.83 18,351.42 For the period: 11/01/2000 through 04/30/2001 Source Social Security Number: 502 - 56 - 6181 Agency Automatic (1%) 2,460.47 26.97 26.97 0.00 185.02- 2,329.39 26.97 26.97 0.00 11.64 2,394.97 26.97 28.13 0.00 81.94 2,532.01 28.51 28.51 0.00 220.99- 2,368.04 28.51 28.51 28.51 0.00 143.63- 2,309.94 28.51 0.00 171.08 2,509.53 Agency Matching 9,327.28 107.87 107.87 0.00 742.54- 8,800.48 107.87 107.87 0.00 44.13 9,060.35 107.87 112.51 0.00 325.43 9 , 606 . 16 1 14 . 05 1 14 . 05 0.00 886. 14- 8 , 948. 12 114 . 05 114.05 114.05 0.00 576.86- 8,713.41 1 14 . 05 0.00 682.05 9,509.51 G Fund 128.69 0.00 0.00 1. 70 0.61 131.00 0.00 0.00 5.03 0.63 136.66 0.00 0.00 5.31 0.63 142.60 0.00 0.00 5.12 0.60 148.32 0.00 0.00 0.00 4.83 0.66 153.81 0.00 5.12 0.67 159.60 TSP-8-A Investment Fund Date of Birth: 09/15/48 Total F Fund 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 C Fund 22,977.26 404.52 404.52 474.36 1,858.79- 22,401.87 404.52 404.52 947.09 115.32 24,273.32 404.52 421. q:z 946.81 892.83 26,939.40 427.68 427.68 947.00 2,538.07- 26,203.69 427.68 427.68 427.68 947.29 1 , 728 . 13- 26,705.89 427.68 947.00 2,130.29 30,210.86 23,105.95 404.52 404.52 476.06 1,858.18- 22,532.87 404.52 404.52 952.12 115.95 24,409.98 404.52 421. 92 952. 12 893.46 27,082.00 427.68 427.68 952. 12 2,537.47- 26,352.01 427.68 427.68 427.68 952.12 1,727.47- 26,859.70 427.68 952. 12 2 , 130. 96 30,370.46 o . Deposit E . Earnings l . Loan P . Monthly loan payment summary S . In-service withdrawal Activity Codes T . Interfund transfar F . Forfeitad nonvested monies R . Restored amounts A . Adjustment C . Earnings correction Y . Earnings correction transfer V . Reversal of earnings correction B . Declared abandoned o . Court-orderad payment W . Post-employment withdrawal M . Minimum distribution N . Refunded excess deferral Monthly earnins,s are calculatad by multiplying the rate of return for the month shown by the sum of your prior month-end balance and one-half of the totsl of depOSIts and loan repayments during the month shown. Earnings are credited at the end of the month shown. Adjustments. earnings corractions, forfeitures, loans, restored amounts, and withdrawals affect your account for the calculation of earnings at the end of the month shown. lnterfund transfers also affect your account at the end of tha month shown. Pay date Is the date reported by your payroll office for daposits. Process date is the date deposits and loan payments were processed to your account by the TSP record keeper. C"",,O"I'I TC"O.O_'" IO~" ..._.... r::,,,,,,,,,,,\ . ., MARITAL PROPERTY - ITEM NO. 19b Esrom E. Good 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: Description of Property: Individual Retirement Account (IRA) Address: Metlife Investors Group USA c/o Metlife Investors Group P.O. Box 92193 Los Angles, CA 90009 Account Number: 502-56-6181 Name of Owner: Esrom E. Good Account Statement attached hereto as Exhibit B ~- ~-~ ~t . SECU.R,ITY FIRSTcROUP@ 030 -0009369 ACCOUNT STATEMENT THIS STATEMENT OF ACCOUNT IS ISSUEO BY SECURITY FIRST GROUP, INC. A MetLife Company ON BEHALF OF SECURITY FIRST GROUP, INC P.O. BOX 92193 LOS ANGELES, CA 90009 1-(800) 284-4536 SECURITY FIRST LIFE INSURANCE COMPANY Please direct any questions to the above address / phone number. POLICY NUMBER I A2041682 ESROM E GOOD 1029 HEMLOCK LANE ENOLA, PA 17025 CYNTHIA FOGARTY HARRIS SAVINGS BANK 3100 MARKET STREET CAMP HILL, PA 17011 TELEPHONE: 717-737-0457 THIS STATEMENT CONFIRMS TRANSACTIONS FOR THE PERIOD ~ SSN OR TAX-I.D. NO. CONTRACT NUMBER CERTIFICATE NUMBER FORM 1 01 TRANSActiON EfF.DATE . 3 TRANSAcnON''';' i~~~!\ I 135R2 .........................UMt.$~ii........i.......i...\....iACCOUNtVAI.1JES .mQ,;:~9ti~p.w..$V~~I!l~W ............... .ANNqITY INVESTMENT ACCOUNT SFT BOND SERIES 12/31/00 CURRENT VALUE 10.337222 1,284.5626 12,800.77 13,278.81 TOTAL ACCOUNT VALUE 12,800.77 13,278.81 IMPORTANT NOTICE-PLEASE REVIEW THIS STATEMENT CAREFULLY. ALLOCATIONS WILL BE CONSIDERED FINAL 60 DAYS FROM STATEMENT DATE. STATE PREMIUM TAXES, IF ANY, WILL BE DEDUCTED FROM THE ANNUITY VALUE AT TIME OF ANNUITIZATION. ******************************************************************************************************** * * * IMPORTANT NOTICE * * * * AtftJITIES, MUTUAL FUNDS, AND OTHER INVESTMENT PRODUCTS: * * ARE NOT INSURED BY THE FDIC OR ANY OTHER GOVERNMENT AGENCY. * * ARE NOT DEPOSITS AND ARE NOT GUARANTEED BY OR OBLIGATIONS OF ANY BANK. * * INVOLVE INVESTMENT RISKS, INCLUDING THE POSSIBLE LOSS OF PRINCIPAL. * * * ******************************************************************************************************** ..ftIS"I'()RYQF\............. ANNUrrv.VALue....... . ...-........._-............................ .............. ........ . .........~~~I~~!rI'~.............: ..........iI~!~~~.i...f...j.~.IIB=It..::f'...9"ly'~I~~..........~.............~(tt~A~~rrv.. 04/18/97 - 12/31/00 17,856.80 .00 2,422.01 13,278.81 PLEASE SEE REVERSE SIDE FOR INSTRUCTIONS ON HOW TO READ YOUR STATEMENT ST21 (7/9S) MARITAL LIABILITIES UNSECURED - ITEM NO. 24a Esrom E. Good 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: Description of Property: Credit Card Debt Address: Associates National Bank Account Number(s): /./,2.21-6/~()- Zorh.2~J6 Balance Due: $2,800.00 (As of: 'I/5t?J.z-) I Names of Account Holders: e ~ A OM 13. (;-0 ",I , . ., MARITAL LIABILITIES SECURED - ITEM NO. 24b Esrom E. Good 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: Description of Property: IRS tax lien( s) Address: u.s. Department of Justice Tax Division Civil Trial Section, Eastern Region P.O. Box 227 Ben Franklin Station Washington, D.C. 20044 Account Number: 502-56-6181 Name of all creditors: -. . T'; . . " t ~_\QJ . I I , II .. .- Michael S. Travis ID No. 77399 4076 Market Street, Suite 209 Camp Hill, P A 17011 (717) 731-9502 DIANE F. GOOD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 01-4129 CIVIL ESROM E. GOOD, Defendant : IN DIVORCE CERTIFICA TE OF SERVICE I, Michael S. Travis, certify that I have this day served a true and correct copy of the foregoing document by first class mail, postage prepaid, on the following person(s), addressed as follows: Elizabeth S. Beckley, Esquire BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, P A 17108 Date: 1/JII)1- ~~ViS ill No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 Attorney for Defendant , 0 rJ r.. ~ ..., ,.- N ? '0 ~ ~ '> r':) -C-"':; ~-~- -"' 'J ,".) ,p : ,,' r, . :, .r~~ . ) ,1 ',) .::.~ ... Diane F. Good, v. ) IN THE COURT OF COMMON PLEAS OF Plaintiff ) CUMBERLAND COUNTY, PENNSYL VANIA ) ) CIVIL ACTION - LA W ) IN DIVORCE ) Defendant ) NO. 01-4129 CIVIL TERM Esrom E. Good, NOTICE OF SERVICE OF INTERROGATORIES DIRECTED TO PLAINTIFF TO THE PROTHONOTARY: Please take notice that Defendant has served interrogatories to Plaintiff, Diane F. Good, upon her attorney, Elizabeth S. Beckley, Esquire. ~ ~. Mfchael S. Travis Attorney for Defendant 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 Date: 3/ /-o~ .. v. ) IN THE COURT OF COMMON PLEAS OF Plaintiff ) CUMBERLAND COUNTY, PENNSYL VANIA ) ) CIVIL ACTION - LAW ) IN DIVORCE ) Defendant ) NO. 01-4129 CIVIL TERM Diane F. Good, Esrom E. Good, CERTIFICATE OF SERVICE I, Michael S. Travis, certify that I have this day served true and correct copy ofthe foregoing document by first class mail, postage prepaid, on the following person, addressed as follows: Elizabeth S. Beckley, Esquire BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108 Dated: 3~ Ilc;J.. /~ /' ichael S. Travis ID No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717)731-9502 Fax 731-9511 Attorney for Defendant n (:."') c ) c: "0 i CJ -,; l.' N ,-nr' .....-- ~ -, ~ ".- " ;:,- - . ...... ~ .......1 '_.~ -- .' :-:-1' _ .i - ~ .' f.,) -).~~ -........ . , ~ r In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION DIANE F. GOOD ) Docket Number 01-4129 CIVIL Plaintiff ) vs. ) PACSES Case Number 991104715 ESROM E. GOOD ) Defendant ) Other State ID Number CONSENT ORDER AND NOW, to wit on this 9TH DAY OF APRIL, 2003 IT IS HEREBY ORDERED that the (iJ Complaint for Support or 0 Petition to Modify or 0 Other filed on AUGUST 8, 2002 in the above captioned matter is dismissed without prejudice due to: THE PARTIES SETTLING THE MATTER OUTSIDE OF THE DOMESTIC RELATIONS SECTION AND NOT PURSUING THE MATTER THROUGH THE DOMESTIC RELATIONS SECTION. (i) The Complaint or Petition may be reinstated upon written application of the plaintiff petitioner. DRO: RJ Shadday xc: plaintiff defendant Elizabeth Beckley, Esquire BY THE COURT: ~. /?~ JIf\. Vln . Hess JUDGE Service Type M !J..:"',-1~ lJ -Ii.).' -.......'(": I Form OE-505 Worker ID 21005 (,' ?-/ .. -< 11..0 4 ~ \4~ J ~ " ~- --SI "- -) I,: ~ f'J\ C) ~'''','