HomeMy WebLinkAbout05-5089
FRIEDMAN & KING, P.C.
John F. King, Esquire
ID #61919
600 N. Second Street
Penthouse Suite
P. O. Box 984
Harrisburg, PA 17108
Tel.: (717) 236-8000/Fax: (717) 236-8080
Attorney for Plaintiff
v.
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05 - SoP? C!{"u;L~~~
COMPLAINT IN DIVORCE
MOLLY H. WILSON,
Plaintiff
RICHARD D. WILSON,
Defendant
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take prompt action. You are warned that if you fail to do so, the
case may proceed without you and a decree of divorce or annulment may be entered against
you by the court. A judgment may also be entered against you for any other claim or relief
requested in these papers by the Plaintiff. You may lose money or property or other rights
important to you, including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is available in
the Office of the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square,
Carlisle, P A.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR
ANNULMENT IS ENTERED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF
THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
Telephone (717) 249-3166
MOLLY H. WILSON,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. O~ -SQP? C/(Ji~~
COMPLAINT IN DIVORCE ' J
RICHARD D. WILSON,
Defendant
COMPLAINT UNDER SECTION 330Hc) AND SECTION 330Hd)
OF THE DIVORCE CODE
I. Plaintiff is Molly H. Wilson, who currently resides at 267 Hillcrest Rd.,
Camp Hill, Cumberland County, Pennsylvania 17011, since October of 2002.
2. Defendant is Richard D. Wilson, with an address of 18 E. Lisburn Rd.,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
3. The parties have been bona fide residents in the Commonwealth for at least
six (6) months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on December 28, 1993, in
Arlington, Virginia.
5. Plaintiff avers that there are children of the parties under the age of eighteen
(18), namely: Logan A. Wilson (dob 12/11/95), Connor R. Wilson (dob 7/13/97), and Peyton
C. Wilson (dob 12/20/02).
6. There have been no prior actions of divorce or for annulment between the
parties.
7. Plaintiff has been advised that counseling is available and the Plaintiff may
have the right to request that the Court require the parties to participate in counseling.
8. The marriage is irretrievably broken.
9. Neither Plaintiff nor Defendant are active in the military service of the
United States.
10. The parties separated on August 26,2005.
WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce.
COUNT I
CUSTODY
11. The prior paragraphs of this Complaint are incorporated herein by
reference thereto.
12. Plaintiff seeks custody of the following children:
NAME
PRESENT RESIDENCE
AGE
9
Logan A. Wilson
Peyton C. Wilson
267 Hillcrest Rd.
Camp Hill, PA 17011
267 Hillcrest Rd.
Camp Hill, PA 17011
267 Hillcrest Rd.
Camp Hill, PA 17011
8
Connor R. Wilson
2
The children were not born out of wedlock.
The children are presently in the custody of the Plaintiff, Molly H. Wilson, who
resides at 267 Hillcrest Rd., Camp Hill, P A 17011.
During the past five (5) years, the children have resided with the following
persons and at the following addresses:
NAME RESIDENCE DATE
Molly H. Wilson and 420 Reeser Rd. 2000 - 10/02
Richard D. Wilson Camp Hill, PA 17011
Molly H. Wilson and 267 Hillcrest Rd. 10/02 - 8/26/05
Richard D. Wilson Camp Hill, PA 17011
Molly H. Wilson 267 Hillcrest Rd. 8/26/05 - present
Camp Hill, PA 17011
The mother of the children is the Plaintiff, Molly H. Wilson, currently residing
at 267 Hillcrest Rd., Camp Hill, PA 17011. She is married to the Defendant.
The father of the children is the Defendant, Richard D. Wilson, with an
address of 18 E. Lisburn Rd., Mechanicsburg, PA 17055. He is married to the Plaintiff.
13. The relationship of the Plaintiff to the children is that of Mother. The
Plaintiff currently resides with the following persons:
NAME RELATIONSHIP
Logan A. Wilson
Connor R. Wilson
Peyton C. Wilson
Son
Son
Son
14. The relationship of the Defendant to the children is that of Father. The
Defendant currently resides with the following persons:
NAME
Unknown
RELATIONSHIP
15. Plaintiff has not participated as a party or witness, or in another capacity, in
other litigation concerning the custody of the children in this or another court.
Plaintiff has no information of a custody proceeding concerning the children
pending in a court of this Commonwealth or any other state.
Pli.!.intiff does not know of a person not a party to the proceedings who has
physical custody of the children or claims to have custody or visitation rights with respect to
the children.
16. The best interest and permanent welfare of the children will be served by
granting the relief requested because the Plaintiff/Mother has been the primary caregiver of the
children since their birth, and Plaintiff/Mother resides in the marital residence.
17. Each parent whose parental rights to the children have not been terminated,
and the person who has physical custody of the children, have been named a party to this
action.
WHEREFORE, Plaintiff requests the Court to grant primary physical custody of
the children to the Plaintiff/Mother.
COUNT II
REOUEST FOR EOUlTABLE DIVISION OF MARITAL PROPERTY
PURSUANT TO 23 Pa.C.S.A. ~ 3502(a)
18. The prior paragraphs of this Complaint are incorporated herein by
reference thereto.
19. The Plaintiff and Defendant have legally and beneficially acquired property,
both real and personal, during their marriage.
20. The Plaintiff and Defendant have been unable to agree as to equitable
distribution of the said property to the date of the filing of this Complaint.
WHEREFORE, the Plaintiff, Molly H. Wilson, requests this Court to equitably
divide all marital property.
COUNT III
REOUEST FOR ALIMONY PENDENTE LITE AND ALIMONY
UNDER ~~ 370Ha) AND 3702 OF THE DIVORCE CODE
21. The prior paragraphs of this Complaint are incorporated herein by
reference thereto.
22. The Plaintiff is unable to sustain herself during the course of litigation.
23. The Plaintiff requests the Court to enter an award of alimony pendente lite
until final hearing, and thereupon to enter an order of alimony in her favor, pursuant to
Sections 370l(a) and 3702 of the Divorce Code.
WHEREFORE, Plaintiff respectfully requests the Court to enter an award of
alimony pendente lite until further hearing, and thereupon to enter an award of alimony in her
favor, pursuant to Sections 3701(a) and 3702 of the Divorce Code.
COUNT IV
REOUEST FOR COUNSEL FEES. COSTS AND EXPENSES
UNDER ~~ 3104(8)(1). 3323(b). 3702 AND 4351(8) OF THE DIVORCE CODE
24. The prior paragraphs of this Complaint are incorporated herein by
reference thereto.
25. Plaintiff has employed John F. King, Esquire to represent her in this
matrimonial cause.
26. Plaintiff is unable to pay her counsel fees, costs and expenses, and
Defendant is more than able to pay them.
27. Defendant is employed and has the ability to pay Plaintiff's counsel fees,
costs and expenses.
28. Reserving the right to apply to the Court temporary counsel fees, costs and
expenses prior to final hearing, Plaintiff requests that, after final hearing, the Court order
Defendant to pay Plaintiff's reasonable counsel fees, costs and expenses.
WHEREFORE, Plaintiff respectfully requests that pursuant to Sections
3104(a)(l), 3323(b), 3702 and 4351(a) of the Divorce Code, the Court enter an order directing
Defendant to pay Plaintiff's reasonable counsel fees, costs and expenses.
COUNT V -
REOUEST FOR CONTINUED MAINTENANCE AND BENEFICIARY DESIGNATIONS
OF EXISTING POLICIES INSURING LIFE AND HEALTH OF
PLAINTIFF AND THE MINOR CHILDREN
UNDER SECTION 3502(/)) OF THE DIVORCE CODE
29. The prior paragraphs of this Complaint are incorporated herein by reference
thereto.
30. During the course of the marriage, Defendant has maintained certain life and
medical insurance policies for the benefit of Plaintiff and the parties' minor children.
31. Pursuant to Section 3502( d), Plaintiff requests Defendant be directed to
continue maintenance of said policies for the benefit of Plaintiff and the parties' minor children.
WHEREFORE, Plaintiff respectfully requests that, pursuant to Section 3502(d) of
the Divorce Code, the Court enter an order directing Defendant to continue to maintain certain
life and medical insurance policies for the benefit of Plaintiff and the parties' minor children.
Respectfully submitted,
Date~~~1?tXJ)
17108
VERIFICA nON
I, Molly H. Wilson, hereby acknowledge that I am the Plaintiff in the foregoing
action; that I have read the foregoing Complaint in Divorce; and the facts stated therein are
true and correct to the best of my knowledge, information and belief.
I understand that any false statements herein are made subject to penalties of 18
Pa. C.S. Section 4904, relating to unsworn falsification to authorities.
Dated:~:rJ, ~
j;jjjj;/(J
Molly H. Wilson
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v,
MOLL Y H. WILSON
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
V,
05-5089 CIVIL ACTION LAW
RICHARD D. WILSON
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW.
Wednesday, October 05, 2005
, upon consideration of the attached Complaint,
it is herehy directed that parties and their respective counsel appear before Melissa P. Greevy. Esq.
, the conciliator.
at
MDJ Manlove's, 1901 State St., Camp Hill, PA 17011 on
Friday, November 04, 2005
at 11:00 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished. to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age fIve or older may also be present at the conference. Failure to appear at the conference mav
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Proteetion from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/
Melissa P. Cree Es
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court. please contact our office, All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the
scheduled conference or hearing,
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE, IF YOU DO NOT
HA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-5089 (Civil Term)
CIVIL ACTION - LAW
IN DIVORCE
MOLLY H. WILSON,
Plaintiff
RICHARD D. WILSON,
Defendant
INCOME AND EXPENSE STATEMENT
OF
MOLLY H. WILSON
I verify that the statements made in this Income and Expense Statement 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:
10.20-05
#J!W
Molly H. Wilson, Plaintiff
Employer: UCP Central PA
Address: 44 S. 38th St., Camp Hill, PA 17011
Type of work: Director of Childhood Programs
Payroll Number: 225-17-1238
Pay Period (weekly, biweekly, etc.):
Gross Pay per Pay Period:
Itemized Payroll Deductions:
Federal Withholding:
Social Security:
Local Wage Tax:
State Income Tax:
Retirement:
Savings Bonds:
Credit Union:
Life Insurance:
Health Insurance:
INCOME
Other (specify):
Medicare
P A SUl/SDI
Net Pay per Pay Period:
Other Income:
Week
Interest
Dividends
Pension
Annuity
Social Security
Rents
Royalties
Expense Account
Gifts
Unemployment Compo
Workmen's Comp.
Total
TOTAL INCOME
$0
$ 1,769.25
$
$
$
$
$
$
$
$
$
157.13
109.69
35.40
54.30
$ 25.66
$ 1.59
Month
$1,385.48
Year
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
$46,000.00 per year
.
EXPENSES
Home
Mortgage/rent
Maintenance
Utilities
Electric
Gas
Oil
Telephone
Water
Sewer
Employment
Public Transportation
Lunch
Taxes
Real Estate
Personal Property
Misc. Taxes
Income
Insurance
Homeowners
Automobile
Life
Accident
Health
Other
Automobile
Payments
Fuel
Repairs
Weeklv
Monthlv
Yearly
$1,418.79
$ 50.00
$ 255.00
$ 150.00
$ 40.00
$ 38.33
Paid with mortgage payment
Paid with mortgage payment
$ 150.00
$ 55.10
$ 415.00
$ 150.00
$ 40.00
EXPENSES
Weekly
Monthly
Yearlv
Medical
Doctor
Dentist
Orthodontist
Hospital
Medicine
Special needs (glasses,
braces, orthopedic
devices)
$25.00
Education
Private school
Parochial school
College
Religious
Personal
Clothing
Food
Barber/hairdresser
Credit payments
Credit cards
Charge account
Memberships (gym)
$ 100.00
$ 400.00
$ 40.00
$ 400.00
$ 44.00
$ 120.00
Loans
Credit Union
Miscellaneous
Household Help
Child Care
Papers/books/magazines
Entertairunent
Pay TV
Vacation
Gifts
Legal Fees
Charitable Contributions
Other Child Support
Alimony Payments
$ 850.00
$ 4.00
$ 120.00
$ 70.00
Other
TOTAL EXPENSES:
$ 4,935.22
PROPERTY OWNED:
Ownership
Description Value HWJ
Checking account 0
Savings accounts $ 25.00 J
Credit Union
Stocks/bonds
Real estate House $180,000.00 J
Other
TOTAL $180,025.00
INSURANCE:
Company
Policy No.
Hospital
Tricare Prime
488747234
Blue Cross
Other
Medical
"
"
Blue Shield
Other
Health/ Accident
Disability Income
Coverage
HWC
HWC
HWC
United Concordia Group 846172000 H W C
Dental
Other
H husband
Wwife
J joint
C child
SEIH 8Y: ORRSTOWN BANK SILVER SPRING
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20. Sociaf!8C~ btlnefits. . . . . . 20. l" I b Taxable amount (seelnsn} . . 2Gb
21 OIhef incolfJ8 . 2'
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28 Student loan inlllfest deduQloo (sea In. 211
27 Tultlon 8nd _ daducllon (...a lnatrua 27
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Z8 Moving expon.... _ Form 3903. . 28
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32 SeJf..employad 5EP, SIMPLEi. and, quallllf' pI...s . . , . . .. 32
33 Penalty on earty wlthdrawet of 'GavlOgs . t: . . . . . . . . . ,. 33
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SENT BY: ORRSTOWN BANK SILVER SPRING
; 717 791 27B4
Richard 0 & Moll H Willon .
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49 Child tax credit (see instfuc:tio(ls) , . ,Ii. . . .
50 Adoption credit Attach Form 8839. . ... .iL. , .. ,...'. .,
51 Cr8dlb; from: ... OFl;lrm 8396 b 0 Form 885*, ,.,..........
52 Dlhet credits. Ch~ck applicable bO.1:(es): '~O Form 3800
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58 Advance earned inGome credit payments fri)m Form(s) W.2 . . - .. . . . . .", ..'
59 Household employment taxes. Atta(;h SChe#Mtt H ......, ,..,....." .,."
60 Add IiflClS 54-59. Thi$ i~ urtotll t.u . .. i.
61 rederal incomB lax withheld from Forms 2 and 1099. 61
62 2003 c:lob'mlltoo tax puymenb and umotlnt applied fro~12OO2 return . . 62
I 63 ~rMdincom.c::Ntdit(EJc).... ._......~t........... 63
I 64 Excess social securHy Ind tier 1 RRTA tax wit/lhflld (seij instfU(:tions) . 64
65 Additional child tax credit. Attach Form 881~ ...,...". 65
66 Amourrl: pel'lll with request ror t!rtHnsloJl to file (see in uctioflS). S6
67 QUltr pmts; fron); " 0 form 2439 b 0 ~nn ..1 ~ 0 Form 88B5 67
68 Add fllles $1 thro h 61.l"he$e are ur tota, a . ... .... ..,., ..
69 If lme 68 ;1 more than 1I11~ sa, subtract line 60 from 1/ 6S. This is the amount you overpaid , .
70. Amount Of line 69 you want retunct.d to . , , . . . , . -
~ b Routillg number ... 2313&2241 ~ c T "'
. d Account number . . , 2337&0
71 Amount or line 69 you w~nt .all'plied to Y\U 2004 ~i tax . ' .'" 71
n Aml:ud: you (I~. Sllbtra~ line &8 from line 60, For d.ih on mw !,l,1 pay, ~ee instructlons .
73 Es.timated tax e-nal .see instructions) . . . ; 73 I
Oo,yol.l want to :;illow another person to discus.s is relurn with the IRS
(see lnstructions)? ...... ..,.....',..,.... ',H ".,... ... ., , .., ". 0 Yes. Complete the following.
Dt::J~~." ~ Per!looallMnll1lcatian
!l::Ime I)()~ nw'r'lbar'1 ~
l,I~r ~f\Ilnloo Of O&i'JUf'y, I d/l"bMll th:ot J hlI~ colmll1ined \his r urn.....d oca:ur~l1)'ing $l;he~ >lncl ~tiI'OrrIQrTti, ~ ~ 1~ !xl:;1 Q+ my ~,1Itl(l
befie1,1:l1!tYilrlltTUl, correct. anacQr'l"lPlC~.~IQl1I)'!lfe~. (Qt.h:orNn~i;~'mall~Q!'\'lIichpl1lpaf'&ft.lsM\Y~'
11
Your SlgIllltul'e j: tQte Your OCCl.patlOn Dayfime phone nlJT1bel-
~ ~
. All others;
SinCJle or Married
filing sepi;lrately,
$4,150
Milnied filing
JOintly.: ()I
Q!Jalif'ling
wtdow(eor),
$9,500
Head of
I ~~~MohOld,
L-
Other
Taxes
Payments
j( you have a
qualifying
Child, attach
Scht!:duH.:! EIC.
Refund
Direct dt:lPOSiP
Site instructions
and fill in 70b,
70c, and 70d.
Amount
You Owe
Third Party
Designee
Sign
Here
Joint return?
S~e instruc1ions.
K&fiP a copy
for yOUf (ecords.
Paid
Preparer's
Use Only
Spu~e'S ~i~lun~', II II Pint retLm, bl1th mUllt S/Ofl.
~
""..
"
i:
7;MAY-3.05 11 :16;
44
46
46
47
48
49
50
51
1 200.
1.600.
~
53
.. 54
55
56
~7
58
59
..'" 60
15 367.
.. sa
69
..'" 70.
PAGE 7/13
16 9~9.
96 6 5.
15.2 O.
8] 3 5.
13 964.
13 9.4.
2.8 O.
11 1 4..:.
11 1 4.
15 3 7.
4 2 3.
4,2 3.
o Savings
IE! No
Const run i on Su
$pwse's ~hOI'l
f'>re(l.are~3; IlL
-..
ii
i'
~1li'i:KIIl..,m1Q\o}"'GQ
Fitm',~
:~~~~OO}'"
addrtlSs,anc:l
ZIP cod,!'
$~lf,pr~ ared
"
FD~ll:2:
,
I
Olfl6/().4
"'"
"""""""
MAY 03,2005 11:20
717 791 2784
7
form 1040
03)
I
Page 7
; 717 791 2794
7;MAY.3.05 '1 :17;
PAGE 9/13
SENT BY: ORRSTOWN BANK SILVER SPRING
Fl fIT) 1040 2004
TlIxand
Credits
lItllt>d.t<l
o.duc:Uon
10<-
. People who
c:t'H1lcted any box
en Iln@ 388 or
38b or who can
be claimed as a
dependent. ....
Intitruc.tions.
. All othot'$:
Single or Married
filing separatQfy.
14.650
MarrlodflUog
jo4na_~~r
a""lIIy1ng
widow(erJ.
$9.700
Head of
hooRehokl.
$7.150
Other
Taxea
P IO}'meI1ts
H~have8
qua~ng
dllld.allildl
SCheduJoEIC.
Rlffund
Oln>ct dopos~?
Saelnetr_
end flU In 72b.
12(;. Bnd 72(1-
Amount
You Owe
, third party
Desl nM
Sign
Here
Joint return?
Se6 InolruClions.
Keep a ~
for your records
Paid
Pmpall>f'8
Use Only
Pa e 2-
530.
Richard D ~ Moll ~ Wi1so
~7 Amountlmmlh... 36 (edjusled IV_In' me) . . . . . . . . . . . . , . . . . . . . . . .
38. Check {Bvo,,- WQre born before J uary 2.1940, B 611rld. Total Ixuce$
1< a_waebomba nuary2, 1940. Bllnd,"-" 3&.
b tf your SPOUM llemttes on Ii! separa1e nWum. or you were a duaHlotatus
a~.86elnstnJetlon8andch6Ckhere J:\. . . . . . . . '" . . . ~ . . . . . . .. ~ Ub 0
38 __(fromScho<JuJo...,...JOtaI~_(...Jeftmargln). . ' . . . . . . . . .
.to Subtraetlin$ $9 from line 37 . . . . .~J\. . . . . . . . . . . . . . . . . . . . . . . '" . . . .
41 It Dna 31 iu. $107,02501' 18u.u., multiply 100 by the lotal number of exemptIOns daim&d
onlln&8d,H&ne37iaoverS107.025.6 thcwori<s;~tintheln.stt'UC'lton5,.....".. 41
42 T__SoIlJo<l1lne41 Irom tine 4D. Ii
43 ~~~~::"a:=7a:::~ ~ 'd~~i~l~ ~.D'f~4~1'l'. ...,....
.... A_tlva minimum tax (oee inabucl1ll"a). Anach Fe"" 6251
046 Addines4Sand44.. ....... -1'-..... . . .. . .
'" F0l'81gntaxctediLAttactlfOnn1116l' . ired..,..... 4{ri
47 Crodil""ehIld...._.....""'_ F....2441 , . . .. 47
48 Credit for th$ elderty or 1M disabled, oh Schedule R , . ,. 48
. d
49 EdtK::a.tiOn credtts. At\8d;, ftQrm &663, '!I' . . . . '.' , . . .. 49
50 ReIiremef1t savings contmulfOllI& credit !t'tIach FOJTT1 8880. ." SO
51 Cl\l1dm~cl"9d:lt{tieeif1strucl1on8)" d.I:. , . . 51
52 Adopllon or<<Ii\. Attach Form ll&39. . . ~ . . . 52
53c...lilolrom;aDF0l1118396 bD 81lS9........ 53
M 0Ih... "",<lIIa. Checl< applicable box(..); ! . 0 f""" 3IIJO
b 0= oDSpodfy , , 54
~5 Add tin.. 46lhrough 54. The.., ore you ontdlla . . . . . . . . . . . . . . .
56 Subtntct line 55 from lMi 45. If"Tle 55 is ore than 11nl:'t 4..~, enter -().. . ., . . , , .
57 SBII.....pIay1nellI...._SdteduJeSE..~... . . . . . . . . . . . . . . . . . . . . .
58 S<lCiaI..ccriIy.ndMed.........ijpirol... '-'""1O~._.Fonn4131 .... , . .
at AddRlonallaionlRAs.D!twquilllflP.c:l~ rtS,etc.AnschForm53i9lhequirro , . , . . . . . .No
.eo Advanoo earned inc:orne aedlt paymGl'l 0 Form(s} W.2 , , , , . , , . . , . , . , .
'1 Household empk)ymenttuM. Attach S tIldule H . . . , , . . . . , . ' . . . , , . . . " , ,
62 Add n.... 56-61. TI1i<~ _.......
83 Federal Income tax wllhhald from F~.:J ~ and 109Q , ,
64 2004 estimated IBl payrn!'nts and al'f'lOUnt awI~\~ 2003 return . ,
OS.. E8rnad J_ ....m (EIC1. . . . . . '
b NOfQ.able ~ plIy d8cti0n. " . ~ $5b
lID Exce$""""I_Ulity.nd....tRIlTA.... (...-no) 66
ffT Addltlonal ch~d tax cmdlt. Attach Form 12...,... e7
D8 Amuuntl"'..wUh_faf.....,.ion"'fiJel _ens)...... 88
a9 OIhetJlR1l'Jron< _ Q:ormZ439 b OF"'*"lfi . OForm8ll85 69
70 :n:e83.D4=1I ~~11~~.. . . . . l', " . . " " . . . . . .. . . . . . . . .
11 If lioo 10 is noll:!h!In line &. suDma 11M 6l line 10, lhis is lhe amouri you 0WfJIIliid . . . . ,
na. AmQ\4n\ of line 71 you want fCIrfur'HHd 1:0 . . . , . .
.. b Routing number. . " . . 23138224 ~ e T Ill: Checking
.. dAo:Qoun\numbBr. . . . .233780
13 A/tiOUnt oIlioe 71 Willi'll 10 2G85
14 _ JllU _. Subinla line 19 from line 62.
15 Estimated tux 81 Sf:WIln$fNotion$
1lol"".......__""""".."''''''IlliS''''''''.
~I '
...me -
Ur0ct8r~lttiMt!lfpotJljury.j~Ih8tlhll'le~th6f
w.r, 1tJg~ IlrtllnM. ~ alKi oompkJ6Do.l)e(:lllratlcn!;lf
YDtII"lUg1\1ltWe
.
SpOlla,/I'. ';llnllllU"'" it ujolnl relum, but" m.- ~<l.
.
6,637 .
0,893.
5,500.
5 393.
2 )19.
1,200.
3,000.
."
.200.
119.
282.
951.
)52.
53
6<1
OS.
12,686.
1
686.
1334.
,334_
o Savings
taz.. .73
_oolmw"'JIOl'....lnsIruo:Iions
.......... 75
ll1eIRS("'_Ilol7 .
~... number N
rn.rn:I~YIf1Q"'1__.nd~andlOlhlJbelItrlm)lk~WId
to (~he:rUKIfltalc:p2l)'II'1l&~Qltafllrrfcrm8ljoodwnldlPft'INIl'lllrhlll."ll)'k~Q"
;:' 0M6 Yo,u~1lJlI(tIoIl Oujltln'llt~numb<<!
!
~~a ~
Ffl1fl'llVinWI Self-Pre ared
~urar ....
~~).
ZlI'_
ii
I
I;
li
.,...
Construction
--
In.s:truocor
i;
EIN
""",,"00.
Form ..
(2004)
"
fiDwl1\z 11t1<l1G4
!
Ii
Page 9
MAY 03,2005 11:21
717 791 2784
7
7;MAY.3.05 11 :18;
SENT BY: ORRSTOWN BANK SILVER SPRING
S(.;HEDULE A
. IFonn 10010)
; 717 791 2794
I'
.1
It11Zed Deductions
il'" ch to FQI'm t04O..
for Sdtodulo A (F""" 104ll).
o.pattmam f;!ItfM, TroMalllJ
lnt8maJ~IlLB&etv1C6 [rilPl
~ame(t.J MQWfI OIl Form 100.1
Richard D
M.dIcal
and
00....1
Expen-w
Your deduCUon it/. not limited. Add amCUnta in !he far right colUmn
fQ, linea 4 lhrough 27. AI5Q. enter amounr on Form 1 ~O, line 39.
Your dedllCiion may be gmltec1, Se nsIroctkm& forttte e.mountklenlBr.
I,
"
BAA. ForP~.aIiN6dl.RedudJon Act ~... Form 1C)1O.....+uons...
I
T.... You
Pajd
(Soe
instruCUClnlli.)
In1antot
YouP.ld
(5..
fn$Vuctioos.)
N_.
Pe""",..
1n~.i11l
not
dedudiblo
_to
CIuIr1ty
If )'Cl'u made
aiJlftand
got a benefit
toru, Aa~
imlotructlon&.
ea_tty and
T1Ml1 LDueo
Job Expon.... 20
_nd_
Other
11I10""""",,,,,,"
Deductions
(5..
Ineuucdons.)
OUwr
Mltlcolle\'M'oUS
Deductions
Total
ttemJMd
Deduction.
"" S..I,..
"
I'
& 111011 H WilBon
Caution. Do not lneluda $xpenses n!tJm~ or paid bY' olhe($.
1 Madical anddemaJ """"""'("'IflOl1J<llO"'} , . .'. . . . , . . . , .
2 Er'ltef8rnourti'Om F<<ll'I 1040, line 31 ... %
3 Mulllplyllne2by7.S%(,075). . . . . . . .h,
.. S....btract IIno 3 fA:lrYlline 1. ff line 3 j$ mare Doe 1 ofrtor....o-
S S"'~te and - (<he<k only..... """); n r
" Income 1axe~ or 1\
b Generat aa1$u taxeB (8&l!I in05rrvctiona)\j _
6 Rell' Mtale IUxs.s (a.ee in$tructkJns) , , . .!L .
I'
7' Person-.propertyl8.X8S . . . . . . .J'.. . . , . . .
8 Othertaxe.8. Usf fypear'ld emounf ~ _J~ _ __ __ _ _ __
5
6
7
9 Addiiri"-S-lh- h8-:-:-::-:-.. .-. ,-:
10 Home mtg illlO<eOl am jMli""...... Jo JOIlCl\ F
11 HomEt mortgage Int8l'Et$1 not reportBd 10 you
W paid to 1he pe....,., Imm whom you bought
InetNctions and sI'lo\ly that person's namo,
and addrea$ ...
0IIJl.......
Form 1098.
e home, BOO
n1lfying number.
I'
Ii
"
--------------------~----~-----
"
--------------------*----------
1.\
--------------------~----------
12 /i,jm$" ...m;;.~foyooOii ["oIm 1098:-S; i.;;.;Jliidruies -.-. -: -: -:- -:-:-
13 Investment interest. Attach Form 4QS21f ;;;fj;d.
(Seoi'-.) . . . . . , . . . . . . . . . , , H' . . . . . , . .
14 Add"""" 10 I!1rough 13 . . . . . . . . . . ., , . . . . . . . .
1:5 GiftB by cash 01 dleck. tf you maoo arly gift 'I $250 or morc,
16 ::=;:~~~;~..lf~~.9~~.$JL'~ . . .. . ,
morB, sae Inotruc1ioos. You mwn.BltaId'l F~8283lf
over$500 . . . . . . , . . . . . . . . . , Ii. . . . . . . .
\'
17 Canyo'lfQt from prior year I) .
18 Add lInM 15 thr h 17 . I.
19 Casual or theft k:l
G$ , Attach Form 46.84, See IMl(uctions..
Unrelmbur&ed emp'oyee 8Xp&nS$8 - job ttG ,union dues,
jc)b edOCBtion, etc. Att8ch Form 2106 Of 21 Z ff
required. (See InstnJctioM.) ... F
----r:----.-----
======:========::::=~=========:
21 Tn. prop....lJon fees. , . . . . . . . . . . ." . . . , , . . , . .
22 Othef @)tp&n8eD - investment, safe deposit ~x;. etc. List
typeandsl'rlOunt ~ _________.J!__________
"
-------~------------~----------
23 Addlln..20lhrough22 . . . . . ~i' . . . . . . . . . .
:z.c Eftoefamoot1\1romFoonlO4O,1Jne3., . . Ii
2S Multiply Ii"" 24 by 2'''' (.02) .., ,
2.6 Subirac1 line 25 from tine 23. if line 25 ~a m
27 Other from list in lfle Ino:lrucUons_ lib! type, amount ..
,
-------------------- 1------------------------
28 I. Fonn 1040, line 37. over $142,700 (0"'" $~ ,350 ff MFS)?
IKIN..,
OYoo-
FDwX'lOl l1JmlO4
~
MAY 03,2005 11:21
717 791 2784
10 958.
7
PAGE 10113
OMBfW.>..l
200,
07 i
1 S94.
1 ,968.
1
,
Schedule A (Fonn 1 c10) 2004
Page 10
SENT BY: ORRSTOWN BANK SILVER SPRING
S':':HI!DULE SE
(Font> 10'"
; 717 791 2784
7;MAY-3.05 11 :18;
PA3E 11/13
0ftrIm~" ufthl) T.--;I}'
InL!WMIR\&wnllllSn....io!o
L
Self~mployment Tax
II
I
OMBNo.1 74
~ Attach to Form 1040. ...
IMtrucUona fur Sc:t.dule BE Form 10040).
Soda! 89CUrlty numb$/' of pertKJn
with seIf..mplaymem Income ...
200.
17'
~. af P8IllOfl WlUl Ntt"lWllflloytMnt l~rn.lall thcMrn on Form 1040)
Moll
H Wilson
225-17-1238'
Who Must File Schedule SE
You mu6f:flle Schedule BE jf; Ii
. You had net eaml!1Qs from setfooempJoyment from othet then dhurch employee incomu (line 4 of Short Schedute SE ot &116 4c of
Long Sdledule SE) of $400 or more or ;;
. You had chutcf1 employM Income of $108.28 or more, 'ncomJlfrom services you porformed eB e rniJ'lister or a member af a religious
order" not chuM emplO)'88 Income (see Instructions). !i
Note. Even It you had s 1013$ or a 3mall amount of Income from ~mpIoyment. it may be tv your beneflt to rile Schftdl..lla SE and \.I&EJ
either 'opUonal method' in Part II of Long Schedule SE (Me insttu, ,'00$).
ExcepUon. If your only 581f--empbyment Income W811 from tf8min as a minister, mQf'l'100r or a retiglou$ order, or Christian ScIence
pMCtif;:tQn&r.OO you ftIed Form 4361 and rec:aivOO' IRS approval n 10. be IlIxcd on thoM earnings, do not me SGhedule SE. Inate-ad,
write 'Ex<<t1pt ~ Form 4361' 0f1 Form 1040. line 57. (
,
Iby I UM Short Schedule SE or Must I Use Long uIG BE?
Did You R8ce Wag_ or TIps In 20041
"
No
WaG the total of your wages and tips ~ubJaet 10 sodal
59Curily Of railroad retirement lax plu. your f'tEll oomingtJ
lrarYI self-employment more than $87,900?
,
i:
v..
Am )Iou a mlni$'ler', member of a religious order, Dr
Christian Science practitioner who received IRS appl'OVEll
not to be taxed on earnings from ttreoo 8OUfCeS, but you
owe oetr...employrnent tt~ on o1tler eamlnQ~?
No
No
Are you u81nq one of the optional methods to figure your
net eamings (see Instructions)?
No Did you receive tips 6Ubj&ct to &OOialsecurlty or Medicare
tax that you did nat A!lport to your employer?
No
Old you receive eh-..rch t;imployee Inoomc reported On
Fontl W-2 of $108.2S or morn?
You Msy UM Short Schedule BE Below
Ii
Ii
I:
You Mu.t UM Long Sdutdule SE
No
"
I'
q
SectIon A - Short Schedule SE. cauUon. Read .bow #..... ij you """ 0.. Short SOhedul. SE.
"
Net farm profll Of (loss) h'om Schedule F, Ilna 36. and farm PitnershiPS. Schedul8 K~1 (Form 1 (65),
box 14, eodo A . . . . . . . . . . , , . . . , . . . . . . . H . . . . . . . ' . . . . . . . . . . . . 1
2 Net profit or (IOGA) from S(".hedlJle C. line 3'!.i Schedule C~EZ~\le 3, SchCi!dule K-1 (Form 1065}, box 14, coda
A (_thon lonn.,g); and _to K-1 ("onn 1005-8). b /9 Minis...,. and momba,. of ..1'9lous orders,
see Inatruotion.s for amounts 10 roport on true. line See lnstru ons for other Inc:ome to report , . . . . . . , 2
3 COmbinellnes1and2......,......,...,. E...,.",...,..... 3
I!
4 Net aaml"G* (rom ""..mployment. Uultiply Une 3 by 92.3~% (.9235). If 19t11!li than $400. do not nJe
thlfl,:&chedule;youdonotowesMf-Gmploymanttax.....;~.".,.. .,........ ... . .... 4
5 SeIt..rnploymenf. tax. If1he amount on line.4 is: ::
. $87.900 or less, multiply lirw 4 by 15.3% (153). Enter the ~8l.I1t here and,," Form 1040, llno 57. 1
. More than $87,900. mll'tiply.ljn~ 4 by 2.9% (.02li}. Than, a" $10.899.60 to the resull Enter the- _' . . .
total here and on Form 10.e.o, Uno ~. !:
6 Deductton for ""HOW of ..W......ploymant!.ox. Mul~ply Ilnil5 by 50% (.5),
Enter the result hara al)d 011 Fonn 10.t0. line 30 . . . . .. ........ 6
SAA Far P.perwort( R4MtuetlM Act Hoke, Me Form 1fMO ~ns.
I!
I:
il'"DtA1101 05I0e.(H
I
995.
,995.
.842.
i
,I
!!
MAY 03,2005 11:22
717 791 2784
7
Page 11
SENT BY: ORRSTOWN 8ANK SILVER SPRING
o.p.rtmeot Of the Tr_l~
lnlillmal RfrvenuttSeMco!t ge}
NBrm(&) ohown on FDfIfI tCWO
Richard D & Moll
; 717 791 2784
11
Child and D~pendent Care Expenses
"
... tttach to Form 1CM.O.
separate InstnJdJone.
7;MAY-3-05 11 :19:
PAGE 12/13
:~2441
OMBNo.1~a
.
200!4,
21
YilIU/' ucW HCI#tI:y nunriHr
488 74 7234
H Wilson
,
_ J'OfIINg/n: You IlOGCIID und8rl' nd lIle foHowIng tsnn., See __ in lhQ In.IruGliOrtll
. De_me.. _, ~PInM(.1 . au._E_,
Persons or OrganiiQItions Who Provld the Care - You mUllt complete thlo part
(II ed Jh bolto 2) I'
)"QU "" more space, use . 010 pagEl ,
1 (.a, Care provider-'9; name i (blAddrn... (e) lde~no (d) AmOlj~aid
(no_. street, tno.. city. state, and ZIP code) (SSJ<l or EI ) (seoln.1riJ ""0)
Defense Depot Susq PA ~~il_diI.!.s.. !l.~_____________
New Cumb, land PA 17070 23-1420602 13 .i090. 66
------~--------------- i
J: ,
Old you rocetvQ
d.pend.nt care bvnorttD1
"
i!
ii
i
No
Y..
~
..
Compkite only Part II below.
Compl8t8 Part III on page 2 nexl;
Ca""on. If the care wOO provided In your home. you may owe 8m ymenllaxG$. See the Instructtons for FOI'TJ'I 1 040, ~ne 81.
_ Credit tor Child and Dependent Ca.... Ex nS85
2 InfoflTl8tion about r uAl . . If have "& than two 001
(a) Qualify~ng person's Ol!lmft
ana:, see tho Instructions..
(b) O~alifyjng paraon'6 60cial
s9Ct.lrlty number
'3 273.
19,818._
r
16 000.
'2,100.
An;t
Last
Lo an Wilson 251-97-9078
See Additional Qual' in Peroon s
3 Add the smol,lnbl; in column (c) ofJlnA 2.00 IlCIt entermoro ~Qn $3,000 fot-OrtEt qualifying pt;ll'5on or $6.000
tor 1M) or more persons. If you ~Plft~ Pert III, 9nIP.r the tt'JUr'lt from line 32 . . . . . . . . T . . . . .
... Enmryour..rJ18dlneom..Seefl'l$lructions...,... _1:. , . . . , . . , . . . . . . . . . . . , . . . .
5 If man1Eld tiling jOinUy, eotat' your spouse's earned JnOOl'l'\El (Jfl~ur epooae 0& a student
or Wl!l& diool!lbted. see the instructions); .U olh&ra, er'lt$r the aiilount from line 4 . . . . . , .
8 Enter the Inhillqt of line 3,4, or 5. . . . 1:
3
4
7 EnMr thA- amount from Form 1040, line 37 . i~ . . .. . 7 107 530.
I
II
e Enter on line a the decimal amount shown bEllow that a~ie~jto the amount on line 7
tflh... 7 I.: I! trOne 1 hl:
But not De_of I; But not Oed....
o...r ov... -.. o...r ovor amaunt18
$0- 15,000 ,35 ./: $29.000- 31.000 .27
15,000 - 17,000 .34 1: 31,000- 33,000 .26
17.000 - 19.000 .33 I 33,000 - 35.000 25
'9,000- 21,000 .32 !' 35,000 - 37,000 24 0.20
21.000 - 2<1,000 31 37,000 - 39.000 ,23
23,000 - 25,000 30 j! 39.000 - 41.000 .22
Z5.OOO - 27.000 .29 41,000 - 43.000 21
27,000 - 29,000 .Z8 43,000 - No limit ,20
215 247.
16 1000.
51- Multiply rlne e by the decimal amount on line 8 If yOU paid 2
10 Enter the amOt/tlt from Form 1040, line 45, minus any
11 CI"edIt tor d1Ud .00 .pvndent. caN .xpMIses. Entl!lr tn.
h&mao(lonForm1040 110847....... .......,
BAA F()( P'8p8rwork RtKIuctl.... Act ~ I" M,...... In
3 expenses in 2004. see the instrucUons.
"" Form 1040;!ne 46. . . . . . . . ,
IlGf of I1ne 9 or line 10
e ,200.
10 1 319.
t1 200.
Form 2 1 (2(l()4)
,
,
,
!'
1~121l111Sr'04
I:
I'
II
MAY 03,2005 11:22
717 791 2784
7
Page 12
SENT BY: ORRSTOWN BANK SILVER SPRING
717 791 2784
7;MAY-3.0511:19;
PAGE 13/13
-
Oftpartnw'ltrttnaTr-.ury
InbsrMI RolWMu. 8eNa
Nl!Im.lJfp~r
Net pr~fit From Business
("Ie PToprl.......hlp)
lI>- Partnenhlp.. j04ntwftrtUfM. etc, mlMt No Fonn 1065 or 10EiS-B.
~ Attach to Fon1Il040 ...1041. ~ s.. Instructl"",,_
OMS No. 1 4
..SCHEDULE C-EZ
(Fonn 1040)
200~
09Ai
Moll H Wileon
_ Generallnfonnlllion
i:
"
fij..m.l-..rIly...........IUN)
225-17-1238
i!
You May U.... _r
Schedule C-EZ
Instead of
Schedule C
Only If You:
. Had buslneu expenses of $5, q
or lest. ~!
. Had no employees during the y~ar J
. Are not requff'ed to file Fonn 4582, ~
Oepred2ltioM and Amortization, for (
this bualness. SA. the InslnJetkina :
for Schedule C, 1100 13, to find out :
if you mUiJtflle.
"
. Use the cash method of aCCOUrtin9"
. Old not haV8 an Inwntary at a~
Ume during the year. Ii
. Old not h.(we a floE'It 10M from Y4Pr
business. 1:
"
. Had onlV one bus/ne" as 6 ~
proprietor. ji
i
And You:
. Do not dAduct expanses tor busl-
ness use of your home.
. Do not have eoor year unallowed i
p~jve activity 108$($ from this
buSlOeBS.
A Princlp~t bUl'iint'lAA (J( J"rofeseion, including product or eervio+!
Consultin i;
C Business name. Ifno S6p8l'8te bU~MS!I name, IMYS bLllnk.li
Moll H Wilson n
E Business address (Including suite or room number). Addm not required if same as on Form 1040. page 1.
267 Hillcrest Road Camp Hill PA 170~1
City, town or post office. stal:8, and ZIP end. r:
Camp Hill PA 17011 I
_F1lIu....YourNeIProflt !:
B Entcw eodo from Instttu:ttlom:
,. 624-410
D Employer ID number fe, N). tr any
i;
i
1 Groa. ~Ipw. CIIutton. If this inCOOie W8& re= to r40n Form W~2 and the 'Statutory
employue' box on that fonn was checked. 888 cry lay.... In th8 Instrudions for ~D '1
Schedule C.llne 1, and chCIGk hoM. . . . . . . . . , . . t . , , , . . , . . . . . . . . . - -. 1 995.
"
2 Total expen... (Jiee inslructions). If more than $5,000, youltnust use. Schedule C . - . - . . - 2
.,
3 Net proflt. $ubnct line 2. fron1l1ne 1. If less lhan zero, you ~ use Schedule C. Enter on Form 1040.
line 12, and .Iso on SchtH.:tukl SE.."'" 2. (St&t::1 emplQ do not reportfhis. al1'lOUnt on Sehedule SE. I
Une2.Estatesandtrus1s enteron Fonn 1041 line ~,\. . ;Ii.. . . ." ...' , . ., ,., , . ., . . .. 3 11.995 _
_ Information on Your Vehicle. Complete * part only lfyou 8m daiming car or Iruck expenses on lile 2. I
i
L
II
.. WhendJdYCUPlsocyour'll'fth:IcleInsef'\'kl!sbb~~?(monlh.day.ytl&l').. ~__~__....~____
Ii
:5 OfthEt total number of miles you drove yourvehfde during 2~, enter the number afmlles ycu used your VRhlcle for:
"
b commuting E
~ --t~'~ - - -- --
I,
6 Do you (or your tipouse) have noolher vehide available for 1rsonal uss?
Ii
7 We. your ~k:Je a'II'Ullabae for ptnOnBiI use during o1f-duty ~I'S? . . . .
j:
.. .Il..
I.
):
btf"YeG:ktfheevidenoewrltllN1? .. . . .. ... ...f.
8AA Fat P.pel'WOrlc; ~uetlDl'l Act NotIca. ... f'm1n 10.f0 In dlone.
aBUlllnes"
o Other
8. 00 you have evldenC8 to support your dedl,lction?
Dves ItJ No
Dvoa PNo
o V.. PNO
V.. No
Schedule C-EZ (Form 040) 2004
~"$.xu 1)g{17J0.4
MAY 03,2005 11:23
717 791 2784
7
Page 13
.lV77.l
... .....0..... ... .....~-
iliA YER'S name, street address, city, state, and ZIP code Gross distribntion OMB No. J545..o119
Defense Finance and Accounting Service $ 20676.24 Distribution From
US Military Retirement Pay tz. Taxable amount 2004 Pensions, Annuities,
PO Box 7130 Retiremeot or
London, K Y 40742-7130 $ 20676.24 Profit-Sharing Plans.
PAYER'S Federal identification RECIPIENT'S identification r Ta:u.ble amount not determined r Total Distribution 1RAs, Insurance
umber number b Contracts. etc.
34~0727612 488747234
RECIPIENT'S name, address, and ZIP code Federal Income tax withbeld r ~istribUtion code
RICHARD D WILSON $ 2351.40 Copy 2
267 J-llLLCREST RD File this copy with your
Yourpe~ntageoftotaldistn~ution % state, city,or local
10 Stlte iocorne tax withbeld 11 State/Payer's stlte number income tax return
CAMP HILL PA 17011-1908 $0.00 wheo required
$000
RETIRED 01012004-12312004
r CORRECTED (if checked)
12/08/2004
Form 1099-R
Department of the Treasury - Internal Revenue Sen'ice
IPA YER'S name, street address, city, state, and ZIP code Gross distribution OMB No. 1545-0119
Defense Finance and Accounting Service $ 20676.24 Distributiou From
US Military Retirement Pay a Taxable amount 2004 Pensions, Annuities,
PO Box 7130 Retiremeut or
London, KY 40742-7130 $ 20676.24 Profit-Sharing Plans,
PAYER'S Federal identification ~~IPIENT'S identification r Taxable amount not determined r Total Distribution IRAs, Insurance
Inumber umber b Contracts, etc.
34-0727612 488747234
iRECIPIENT'S uame, address, and ZIP code WFederal Income tax withheld Distribution code
RICHARD D WILSON $ 2351.40 7 Copy B
267 HILLCREST RD 19 Your pe~ntage oftotal distribution Report this income on
% your Federal tax return.
JO State income tax withheld 11 StatelPayer's state number This information is
CAMP HILL PA 17011-1908 $0.00 being furnished to the
Internal Revenue
$0.00 Servi.ce.
RETIRED 0]012004-12312004
r CORRECTED (if checked)
12/ 08/ 2004
Form 1099-R
Department of the Treasury - Internal Revenue Service
PAYER'S name, street address, city, state, and ZIP code Gross distribution OMB No. 1545..0119
Defense Finance and Accounting Service $ 20676.24 Distribution From
US Military Retirement Pay a Taxable .amount 2004 Pensions, Annuities,
PO Box 7130 Retirement or
London, KY 40742-7130 $ 20676.24 Profit-Sharing Plans.,
AYER'S Federal identification RECIPIENT'S identification r Taxable amount not determined r Total Distribution IRAs, Insurance
umber umber b Contracts, etc.
34-0727612 488747234
IRECIPIENT'S name, address, and ZIP code Federal Income tax withheld r ~istribution code
RICHARD D WILSON $ 2351.40 Copy C
267 HILLCREST RD For Rec:eipieut's Records
Your percentage of total distribution % This infonnation is
o State income tax withheld II StateJPayer's state number being furnished to the
CAMPHILLPA 17011-1908 Internal Revenue
$ 0.00 Service.
$0.00
RETIRED 01012004~123J2004
r CORRECTED (if checked)
12/08/2004
Form 1099-R
Department oftbe Treasury - Internal Revenue Service
https://mypay.dfas.mil/FI099R_ RCPS.ASPX? AccessString=RCPS&gIobalid=DNETO I S22005040213 ...
4/2/2005
/
I
/
-..
., -lntllr"t11 HevanuB Service
PAvER'S name, stroet address, city, state, and ZIP code 1 Gran distribution Distributions From
OMS No. 1545-0119 Pensions, Annuities,
RELIANCE TRUST COMPANY , 9257.19 2004 Retirement or
3300 NORTHEAST EXPRESSWAY 2. Taxable amount Profit -Sharing Plans,
ATLANTA, GA 30341 9257.19 Form 1099-R IRAs, Insurance Contracts, etc.
,
2b l.ucabill amount 0 Total I]J
not determinCld distribution Copy C
3 Cllpital gain (included " 4 federal income tax For Recipient's
PAYER'S Federal identification number I RECIPIENT'S identilication number box 2a) withneld
58-1428634 488-74-7234 , .00 , 1851.44 Records
RECIPIENT'S name, strut address (including apt. noJ, city, state, and ZIP code 5 Em~loyu contribu!ions 6 Net unrOlliized appreciation in
of lOsuranca premiums employer's sClcurities
, .00 , .00
01-0001-2306-01-0Q2306 7 Distribution codllls) IRA/SEP
RICHARO 0 WILSON SIMPLE 8 OTHER
267 HILLCREST RO 1 0 Tilis information is
PA 9110 5609 , .00 % beingfurnisnedto
IneinlClrllal
CAMP HILL, PA 17011-1908 9. Your percentagll o. total 9b Total employee contributions Revenue Service.
distribution
% , .00
1."111..,111,.,...11",11,..111,1..11,,,1,,1,,11,,111,11,1.,1 10 State '" withheld 11 Sutll/Payer's state number 12 State distribution
, 259.20 ,
13 Local ,,, witnhClId 14 Name of locality 15 Local distribution
Account number loptional)
1505531 , .00 ,
,
!
)
OVOID
o CORRECTED
Form 1099-R
Department of the Treasury-Internal Rev..nue Slifvlce
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UCP CENTRAL PA
PAYROLL ACCOUNT
925 LINDA LANE
CAMP HILL, PA 17011
Taxable Marital Status: Single
Exemptions/Allowances:
Federal: 7,$50 Additional Tax
State: N!A
Local: 7,1% Additional Tax
Earnings
Regular
PTO
Holiday
I ns Ben Waiver
Social Security Number: XXX-XX-1238
rate hours this period
23.5897 70.00 1,651.30
23.5897 5.00 117.95
~i'i\~~!\(ii\ji"""" ..............;U<.;.~l&l$~)~W
Deductions
Statutory
Federal Income Tax
Social Security Tax
Medicare Tax
P A State Income Tax
Lower Allen Income Tax
PA SUI/SDI Tax
Other
Checking
-1,385.48
-157.13
-109.69
-25.66
-54.30
-35.40
-1.59
M~!!\iI~W\??........ .,..;;U\i@W$P';;!lP;
Earnings Statement
~
@
Period Ending:
Pay Dale:
10(01 (2005
10(07(2005
MOLLY H WILSON
267 HILLCREST RD
CAMP HILL, PA 17011
year to date
6,947.23
117.95
176.91
30.00
7.272.09
Other Benefits and
Information
Eib Balance
Plo Balance
this period
total to date
9.54
10.60
Important Notes
VOID AFTER 1 80 DAYS
588.48
450.87
105.45
223.27
145.46
6.54
Your federal taxable wages this period are
$1,769.25
,
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UCP CENTRAL PA
PAYROLL ACCOUNT
925 LINDA LANE
CAMP HILL, PA 17011
Taxable Marital Status; Single
Exemptions/Allowances:
Federal: 7,$50 Additional Tax
State: NJA
Local; 7,1% Additional Tax
Earnings
Regular
Holiday
Ins Ben Waiver
Social Security Number: XXX-XXL 1238
rate hours this-_ period
23.5897' 67.50 1,592.30
23.5897 7.50 176.91
30.00
$f9~i!.i'ililYiJ"""""" ...................... }.~t;7~~;?'i
Deductions
Statutory
Federal Income Tax
Social Security Tax
Medicare Tax
PA State Income Tax
Lower Allen Income Tax
PA SUI/SDI Tax
-161.62
-111.55
-26.09
-55.24
-36.00
-1.62
Other
Checking
-1,407.09
!iHf}~;!!9
N,WililY'
...........-.-......,...
Earnings Statement
~
@
Period Endingi
Pay Date.
09/17/2005
09/2312005
MOLLY H WILSON
267 HILLCREST RD
CAMP HILL, PA 17011
yaar to date
5,295.93
176.91
30.00
5,502.84
Other Benefits and
Information
Eib Balance
Pia Balance
.this period
- total to date
6.36
10.40
Important Notes
VOID AFTER 180 DAYS
431.35
341.18
79.79
168.97
110.06
4.95
Your lederal taxable wages this period are
$1,799.21
,
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"1!J91 ADP, Ir>;:
$1.;'407 . 09
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NON~NeQQJI~~~E
UCP CENTRAL PA
PAYROLL ACCOUNT
925 LINDA LANE
CAMP HILL, PA 17011
Taxable Marital Status: Single
Exemptions/Allowances:
Federal: 7,$50 Additional Tax
State: NJA
Local: 7,1% Additional Tax
Earnings
Regular
Social Security Number: XXX-XX-1238
rate hours this period
23.5897 60.00 1,415.41
g;fil~ik:gihF..".'. .........................iiIIil1i"U$ji\j?
Deductions
Statutory
Federal Income Tax
Social Security Tax
Medicare Tax
P A State Income Tax
Lower Allen Income Tax
PA SUI/SOl Tax
Other
Checking
-1,130.05
-104.03
-87.76
-20.52
-43.46
-28.32
-1.27
N@I~~y.............. .....i(.......................i....iI.?$P)!i9...
Earnings Statement
~
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Period Ending:
Pay Date:
09/03/2005
09/09/2005
MOLLY H WILSON
267 HILLCREST RD
CAMP HILL,PA 17011
year to date
3,703.63
3,703.63
Other Benefits and
Information
Eib Balance
Pto Balance
this, period
total. to date
3.18
5.20
269.73
229.63
53.70
113.73
74.06
3.33
Important Notes
VOID AFTER 180 DAYS
Your federal taxable wages this period are
$1,415.41
,
,
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Cll!RIADPlrc
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....lransit ~ABA
231,3 ~224f
'{
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NON;.NEGOTI~BI+~
"",.,."/ ;
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Earnings
Regular
Deductions
Earnings Statement
~
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UCP CENTRAL PA
PAYROLL ACCOUNT
925 LINDA LANE
CAMP HILL, PA 17011
Period Ending:
Pay Date:
08/20/2005
08/26/2005
Taxable Marital Status: Single
Exemptions/Allowances:
Federal: 7,$50 Additional Tax
State: NIA
Local: 7,1% Additional Tax
MOLLY H WILSON
267 HILLCREST RD
CAMP HILL,PA 17011
Social Security Number: .xxx-XX.1238
rate hours this period
23.5897 47.50 1,120.50
Gcf1i~,~."'.~ay...i.::"::"'"",, . .......:.:.:.:....::.i*'..ijc?p/$l....
year to dats
2,288.22
2,288.22
Other Benefits and
Information
Eib Balance
Pto Balance
this period
total to date
9.54
15.60
Statutory
Federal Income Tax
Social Security Tax
Medicare Tax
PA State Income Tax
Lower Allen Income Tax
PA SUI/SOl Tax
165.70
141.87
33.18
70.27
45.74
2.06
Important Notes
VOID AFTER 180 DAYS
-65.70
-69.47
-16.25
-34.41
-22.40
-1.01
Other
Checking
-911.26
N~k~~y\}.../"""" ...........:...:...:.......:.:.:iii\iI@iqg.
Your federal taxable wages this period are
$1,120.50
,'''~,
0199lAOP,'r-c
./"
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, =~ = ~-
NbN~NEGbTIAaLE
UCP CENTRAL PA
PAYROLL ACCOUNT
925 LINDA LANE
CAMP HILL, PA 17011
Taxable Marital Status: Single
Exemptions/Allowances:
Federal: 7,$50 Additional Tax
Stata: N/A
Local: 7,1% Additional Tax
Earnings
Regular
Social Security Number: XXX-XX-1238
rate hours this period
23.5897 40.50 955.41
ii!j@~~/R~Yi;':::' . ........::~$):!ljl
Deductions
Statutory
Federal Income Tax
Social Security Tax
Medicare Tax
PA State Income Tax
Lower Allen Income Tax
PA SUIISDI Tax
-50.00
-59.24
-13.85
-29.34
-19.10
-0.86
Other
Checking
l'!~fR~y/f
~::,:,:::::>:.,_....;.
'_""d"_""'"
.':.:-:.,.;.;.,.,.;.;.:.;.:.;.'.,.,
-783.02
$!l)Q!l/
Earnings Statement
tiJ1,P
@
Period Ending:
Pay Date:
08/06/2005
08/12/2005
MOLLY H WILSON
267 HILLCREST RD
CAMP HILL,PA 17011
year to date
1,167.72
1,167.72
Other Benefits and
Information
Eib Balance
Pto Balance
this period
tata I to date
6.36
10.40
100.00
72.40
16.93
35.86
23.34
1.05
Important Notes
VOID AFTER 180 DAYS
Your federal taxable wages this period are $955.41
\~t~{:/(T/'~:}){~l~fi~~~~;;jj"i:. ~,:\), ; !\?,); i
': '\" " '~ " '"",:"", " , \92S tiNQ,!\~~LANE /' ~- :.;~___:"Wl' ", ("/0,' jA."
. ~l i ,'; i \ ,;,~:\[~:~:~ii::a::::~:~' ,"
(-..,.., "">-"//1i. ,.,. """ -.
,.' MOL' YH WJLSON
/ ',,'~ (; '\., .,~. .
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g1991ADP.lrc
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'" ."
'\ \"'.
,//M", "; I:
''v
'., -". ,,",1
{;[ ~'''_'hJ} j~
"'''^,J.-' 'amount
'c $783 ,02
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NON~~E<i(jTIA~~~
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MOLLY H. WILSON,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-5089 (Civil Term)
CIVIL ACTION - LAW
IN DIVORCE
RICHARD D. WILSON,
Defendant
CERTIFICATE OF SERVICE
I, John F. King, Esquire, hereby certify that on October 27,2005, I served a
copy of the within Income and Expense Statement of Molly H. Wilson, by depositing same in
the United States Mail, first class, postage prepaid, addressed as follows:
Mr. Richard D. Wilson
18 E. Lisburn Rd., Suite 201
Mechanicsburg, P A 17055
FRIEDMAR&~NG.- P.C.
. !
Jo F.King, EsqUire
6 0 N. Second Street
Venthouse Suite
P. O. Box 984
Harrisburg, PA 17108
(717) 236-8000
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Plaintiff
Nnv 1 l l005
IN THE COURT OF ~~PE.€A~H)I~
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-5089 CIVil TERM
MOllY H. WilSON,
v.
CIVil ACTION - lAW
RICHARD D. WilSON,
IN CUSTODY
Defendant
ORDER OF COURT
iI
AND NOW, this i t r~ day of November, 2005, upon consideration of the
attached Custody Conciliation Summary Report, it is hereby ordered and directed as
follows:
1. Leqal Custody. Molly H. Wilson and Richard D. Wilson shall have shared
legal custody of the minor children, logan A. Wilson, born December 11, 1995; Connor R.
Wilson, born July 13, 1997; and Peyton C. Wilson, born December 20, 2002. Each parent
shall have an equal right, to be exercised jointly with the other parent, to make all major
non-emergency decisions affecting the children's general well-being including, but not
limited to, all decisions regarding their health, education and religion. Pursuant to the terms
of 23 Pa. C. S. 95309, each parent shall be entitled to all records and information pertaining
to the children including, but not limited to, medical, dental, religious or school records, the
residence address of the children and of the other parent. To the extent one parent has
possession of any such records or information, that parent shall be required to share the
same, or copies thereof, with the other parent within such reasonable time as to make the
records and information of reasonable use to the other parent.
2. Physical Custody. Mother shall have primary physical custody subject to
Father's rights of partial custody which shall be arranged by the mutual agreement of the
parties with the appropriate flexibility in consideration of Father's traveling schedule for
work.
BY THE COURT:
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Dist:
.~F. King, Esquire. P.O. Box 984, Harrisburg. PA 17108
fi,hard D, Wilson. 18 East Lisburn Road, Mechanicsburg, PA 17055
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MOLLY H. WILSON,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. 05-5089 CIVIL TERM
v.
CIVIL ACTION - LAW
RICHARD D. WILSON,
IN CUSTODY
Defendant
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the children who are the subject of this
litigation is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN THE CUSTODY OF
Logan A. Wilson
Connor R. Wilson
Peyton C. Wilson
December 11, 1995
July 13, 1997
December 20, 2002
Mother
Mother
Mother
2. Mother filed a Complaint in Divorce with a count for custody on September 29,
2005. A Custody Conciliation Conference was scheduled for November 4, 2005. Attending
the conference were: the Father, Richard D. Wilson, who participated pro 5e; the Mother,
Molly H. Wilson, and her counsel, John F. King, Esquire. This was the parties' first Custody
Conciliation Conference.
The parties reached an agreement in the form or:2r as attached.
/ /' '/J
/ ! / ,0 rh (~ E;J;yV:';, 7J7-L/ {%f
Date Melissa Peel Greevy, Esqu~
Custody Conciliator
3.
ead:262541
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-5089 (Civil Term)
CIVIL ACTION - LAW
IN DIVORCE
MOLLY H. WILSON,
Plaintiff
RICHARD D. WILSON,
Defendant
INVENTORY
OF
MOLLY H. WILSON
Plaintiff, Molly H. Wilson, files the following inventory of all property owned or
possessed by either party at the time this action was commenced and all property transferred
within the preceding three years.
Plaintiff, Molly H. Wilson, verifies that the statements made in this inventory are true and
correct. Plaintiff understands that false statements herein are made subject to the penalties of 18
Pa.C.S. ~ 4904 relating to unsworn falsification to authorities.
Date:
I-(;OG
11/It;;p
Molly H. Wilson, Plaintltt
ASSETS OF THE PARTIES
Plaintiff marks on the list below those items applicable to the case at bar and itemizes the
assets on the following pages.
(XX) 1.
(XX) 2.
( ) 3.
( ) 4.
(XX) 5.
(XX) 6.
( ) 7.
( ) 8.
(XX) 9.
( ) 10.
( ) 11.
( ) 12.
( ) 13.
( ) 14.
*(XX) 15.
( ) 16.
( ) 17.
( ) 18.
(XX) 19.
( ) 20.
( ) 21.
(XX) 22.
( ) 23.
(XX) 24.
(XX) 25.
( ) 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
Business (list all owners, including percentage of ownership, and officer/director
positions held by a party with company)
Employment termination benefits-severance pay, worker's compensation
claim/award
Profit sharing plans
Pension plans (indicate employee contribution and date)
Retirement plans, Individual Retirement Accounts
Disability payments
Litigation claims (matured and unmatured)
Military IV. A. benefits
Education benefits
Debts due, including loans, mortgages held
Household furnishings and personalty (include as a total category and attach
itemized list if distribution of assets is in dispute)
Other
*15. Husband sole owner of TelKore
..
MARITAL PROPERTY
Plaintiff 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
Number of Propertv All Owners
1. Marital Property H&W
2. Personalty H&W
3. Motor Vehic1es H
4. Military Pension H
5. Retirement Account W
.
NON-MARITAL PROPERTY
Plaintiff lists all property in which a spouse has a legal or equitable interest which is
claimed to be excluded from marital property:
Item
Number
Description
of Property
Reason for
Exclusion
N/A
Item
Number
N/A
Description
of ProDertv
PROPERTY TRANSFERRED
Date of
Transfer
Consider-
ation
Person to Whom
Transferred
LIABILITIES
Item Description Names of Names of
Number of Propertv All Creditors All Debtors
I. Mortgage on Marital H&W
Residence
2. Revolving Credit H&W
3. Auto Loans H
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-5089 (Civil Term)
CIVIL ACTION - LAW
IN DIVORCE
MOLLY H. WILSON,
Plaintiff
RICHARD D. WILSON.
Defendant
CERTIFICATE OF SERVICE
I, John F. King, Esquire, hereby certify that on January 11, 2006, I served a copy
of the within Inventory of Molly H. Wilson, by depositing same in the United States Mail, first
class, postage prepaid, addressed as follows:
Mr. Richard D. Wilson
18 E. Lisbum Rd., Suite 201
Mechanicsburg, P A 17055
(1;0. F. King, Esquire
6 N. Second Street
enthouse Suite
. P. O. Box 984
Harrisburg, PA 17108
(717) 236-8000
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MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT, made this 2r-fh day of Ar f' ~, , 200(, by and between MOLLY
H. WILSON, of Camp Hill, Cumberland County, Pennsylvania, and RICHARD D. WILSON,
whose business address is in Mechanicsburg, Cumberland County, Pennsylvania.
WITNESSETH:
WHEREAS, the parties hereto are husband and wife, having been lawfully married on
December 28, 1993; and
WHEREAS, the parties have lived separate and apart since on or about August 26,2005;
and
WHEREAS, three children were born of the marriage between the parties, namely, Logan
A. Wilson, born December 11, 1995, Connor R. Wilson, born July 13, 1997, and Peyton C.
Wilson, born December 20, 2002; and
WHEREAS, the parties hereto are desirous of settling fully and finally their respective
financial and property rights and obligations as between each other, including, without limitation,
the settling of all matters between them relating to the ownership of real and personal property,
the support and maintenance of one another, and, in general, the settling of any and all claims and
possible claims by one against the other or against their respective estates.
NOW THEREFORE, in consideration of these premises, and of the mutual promises,
covenants and undertakings hereinafter set forth, and for other good and valuable consideration,
the receipt and sufficiency of which is hereby acknowledged by each of the parties hereto,
Husband and Wife, each intending to be legally bound hereby, covenant and agree as follows:
Page 1 of 20
t. ..
1. PERSONAL RIGHTS. Husband and Wife may, at all times hereafter, live separate
and apart. Each shall be free from all control, restraint, interference and authority, direct or
indirect, by the other. Each may reside at such place or places as he or she may select. Each
may, for his or her separate use or benefit, conduct, carry on or engage in any business,
occupation, profession or employment which to him or her may seem advisable. Husband and
Wife shall not molest, harass, disturb or malign each other, nor compel or attempt to compel the
other to cohabit or dwell by any means or in any manner whatsoever with him or her. Neither
party will interfere with the use, ownership, enjoyment or disposition of any property now owned
by or hereafter acquired by the other. During the said separation, the parties shall have the right
to live as though they were unmarried, and their conduct during the separation shall not give rise
to additional grounds for divorce which do not presently exist. This Agreement shall not be
considered to affect or bar the right of Wife or Husband to a limited or absolute divorce on
lawful grounds if such grounds now exist or shall hereafter exist, or to such defense as may be
available to either party. This Agreement is not intended to condone and shall not be deemed to
be a condonation on the part of either party hereto of any act or acts on the part of the other party
which have occasioned the disputes or unhappy differences, which acts have occurred prior to or
which may occur subsequent to the date hereof.
2. CONSIDERATION FOR AGREEMENT. The consideration for this contract and
agreement is the mutual benefits to be obtained by each of the parties to the other. The adequacy
of the consideration for all agreements herein contained is stipulated, confessed, and admitted by
the parties, and the parties intend to be legally bound hereby.
Page 2 of 20
3. ADVICE OF COUNSEL. Husband acknowledges that this Agreement has been
prepared by counsel selected by Wife, to wit, John F. King, Esq., of the firm of Friedman &
King, PC. Husband is aware that he has the absolute right to be represented by sole and
independent counsel of his own choosing to advise him as to his rights and responsibilities in the
within action, and that he has been advised by counsel for Wife that he would be well advised to
secure said representation. Husband is aware that Wife's counsel represents only the interests of
Wife. Husband did not rely upon any assurances of Wife's counsel, nor did he confer with
Wife's counsel, prior to executing the within Agreement. Each party fully ~derstands the facts
and his or her legal rights and obligations, and each party acknowledges and accepts that this
Agreement is, in the circumstances, fair and equitable, and that it is being entered into freely and
voluntarily, and that the execution of this Agreement is not the result of any duress or undue
influence, and that it is not the result of any improper or illegal agreement or agreements. In
addition, each party understands the impact of the Pennsylvania Divorce Code, whereby 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, 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 waives his or her
respective right to have the Court of Common Pleas of Cumberland County, or any other court of
competent jurisdiction, make any determination or order affecting the respective parties' rights to
alimony, alimony pendente lite, support and maintenance, equitable distribution, counsel fees and
costs of litigation.
Page 3 of 20
4. DISCLOSURE OF ASSETS. Each of the parties hereto acknowledges that he or she
is aware of his or her right to seek discovery, including, but not limited to, written
interrogatories, motions for production of docwnents, the taking of oral depositions, the filing of
inventories, and all other means of discovery permitted under the Pennsylvania Divorce Code or
the Pennsylvania Rules of Civil Procedure. Each of the parties further acknowledges that he or
she has had the opportunity to discuss with counsel the concept of marital property under
Pennsylvania law, and each is aware of his or her right to have the real and/or personal property,
estate and assets, earnings and income of the other assessed or evaluated by the courts of this
Commonwealth or any other court of competent jurisdiction. The parties do hereby acknowledge
that there has been full and fair disclosure to the other of his or her respective income, assets and
liabilities, whether such are held jointly, in the name of one party alone, or in the name of one of
the parties and another individual or individuals. Each party agrees that any right to further
disclosure, valuation, appraisal or enwneration or statement thereof in this Agreement is hereby
specifically waived, and the parties do not wish to make or append hereto any further
enwneration or statement. Specifically, each party waives the need for copies of bank
statements, insurance policies, retirement plan statements or any other docwnentation. Each
party warrants that he or she is not aware of any marital asset which is not identified in this
Agreement. The parties hereby acknowledge and agree that the division of assets as set forth in
this Agreement is fair, reasonable and equitable, and is satisfactory to them. Each of the parties
hereto further covenants and agrees for himself and herself and his or her heirs, executors,
administrators or assigns, that he or she will never at any time hereafter sue the other party or his
or her heirs, executors, administrators or assigns in any action of contention, direct or indirect,
Page 4 of 20
and allege therein that there was a denial of any rights to full disclosure, or that there was any
fraud, duress, undue influence or that there was a failure to have available full, proper and
independent representation by legal counsel.
5. MUTUAL CONSENT DIVORCE. It is the intention of the parties, and the parties
agree, that by this Agreement they have resolved all ancillary economic issues related to the
dissolution of their marriage, and thus any divorce action with respect to these parties shall be
limited to a claim for divorce only. Wife has filed a divorce complaint in the Court of Common
Pleas of Cumberland County, Pennsylvania, docketed to number 05-5089. The parties agree that
each will execute an Affidavit of Consent and Waiver of Notice of Intention to Request Entry of
Divorce Decree in order that counsel for Wife may finalize the divorce action in a timely fashion.
Upon completion of the divorce action, counsel for Wife shall supply Husband with a copy of the
Decree.
6. EQUITABLE DISTRIBUTION.
A. Real estate: The parties are the owners of real estate located at 267 Hillcrest
Rd., Camp Hill PA 17011 (hereinafter called "subject premises"). Wife presently is, and has
been, in sole and exclusive possession of subject premises. Concurrent with the execution of the
within Agreement, Husband agrees that he will transfer all of his right, title and interest to
subject premises to Wife. Wife has been, and shall remain, solely responsible for all expenses
attendant to subject premises, including but not limited to real estate taxes, utilities, and
homeowner's insurance.
Page 5 of 20
The parties acknowledge that subject premises was used by Husband as collateral
when Husband secured one or more loans for the business known as Telkore, Inc. (said business
to be further discussed below). Within sixty (60) days of execution of the within Agreement,
Husband shall cause all such liens against subject premises to be removed, whether by
refinancing of said loans or by the execution of a release of liens by the loan-holder. Husband
shall indemnify and hold harmless Wife from any said liens, said indemnification to include
attorney's fees and costs.
Wife shall take any and all steps necessary to refinance the pres~nt mortgage
encumbering subject premises so that Husband is removed therefrom, within two (2) years of
execution of the within Agreement. The above notwithstanding, Wife shall not be obligated to
complete said refinance unless and until all liens against subject premises by virtue of the
dealings of Telkore, Inc. are removed.
B. Furnishings and personalty: The parties agree that they have divided by
agreement between themselves all personal property (other than that specifically set forth in the
within Agreement). Accordingly, Husband shall retain sole and exclusive ownership of all
personal property currently in his possession (other than that specifically set forth in the within
Agreement), free and clear of any right, title, claim and/or interest of Wife, and Wife shall retain
sole and exclusive ownership of all personal property currently in her possession (other than that
specifically set forth in the within Agreement), free and clear of any right, title, claim and/or
interest of Husband.
C. Motor Vehicles Other Than Motorcycle: Each party is the owner of a vehicle
titled solely in his or her name, and is currently in sole and exclusive possession of said vehicle.
Page 6 of 20
Each party shall be solely responsible for any encumbrances on the vehicle in his or her
possessIon.
D. Motorcyle: Husband retained the 1998 Honda Valkyrie motorcycle as his sole
and exclusive possession until Husband's recent post-separation transfer of said motorcycle. In
recognition of the fact that said motorcycle was a marital asset, Husband shall, concurrent with
execution of the within Agreement, pay Wife the sum of Three Thousand ($3,000.00) Dollars as
a partial distribution of the marital estate.
E. Husband's Business: The parties acknowledge that Husband is the sole
shareholder in a business operated by Husband known as Telkore, Inc. Wife waives any claim
which she could otherwise assert for ownership of said business, which said business shall
remain the sole and exclusive property of Husband. Husband shall indemnify and hold harmless
Wife from any debts of said business.
F. Life Insurance: Husband agrees, at Husband's sole expense, to maintain the
USAA life insurance policy presently insuring his life, with the children as beneficiaries (Wife
being named the children's guardian), in the current amount of One Million ($1,000,000.00)
Dollars, until such time as the youngest child has completed his undergraduate education, or until
said child has reached the age of22, whichever shall first occur. The required amount of One
Million ($1,000,000.00) Dollars may be proportionately reduced, if Husband so chooses, as each
child reaches the age of 22 or completes undergraduate education. Payments for the premium for
said policy shall continue to be electronically paid from Wife's checking account, and Husband
shall pay Wife the sum of One Hundred Sixty ($160.00) Dollars per month in reimbursement
therefor.
Page 7 of 20
Wife agrees, at Wife's sole expense, to maintain the USAA life insurance policy
(number A549574870) presently insuring her life, with the children as beneficiaries, in the
current amount of Seven Hundred Fifty Thousand ($750,000.00) Dollars, until such time as the
youngest child has completed his undergraduate education, or until said child has reached the age
of 22, whichever shall first occur. The required amount of Seven Hundred Fifty Thousand
($750,000.00) Dollars may be proportionately reduced, if Wife so chooses, as each child reaches
the age of 22 or completes undergraduate education.
Upon demand, the parties shall each execute an authorization allowing the other
party to obtain any and all information regarding said life insurance policy.
G. Retirement Accounts: Husband shall retain as his sole and exclusive property
the monthly retirement pay from the US Marine Corps. Said monthly payments shall be included
as income for Husband in any future Domestic Relations hearings. Said payments are presently
being electronically deposited into Wife's account, but upon execution of the within Agreement,
the parties shall take such steps as are necessary to redirect said payments to an account
controlled by Husband.
Wife shall retain as her sole and exclusive property the retirement account in her
name with TlAA CREF, with a present estimated value of$37,500.00.
H. Misc. Accounts: The parties, during their marriage, had certain joint banking
accounts, neither of which has any present value. Upon execution of the within Agreement, the
parties shall take steps to close said accounts and open separate banking accounts.
I. Marital Debt. At the time of separation (August 26, 2005) the parties were
jointly obligated under the following accounts:
Page 8 of 20
.'
USAA Mastercard no. 5458 8310 0319 9951
Chase Visa no. 4266 9010 24152324
Members First PSL no. 233780
8,044.00
5,200.00
5,000.00
2,532.00
$20.776.00
TIAA CREF no. 29559226001
TOTAL
Concurrent with the execution of the within Agreement, Husband shall contribute
the sum of$1O,388.00, representing one half of the above-listed accounts, and Wife shall assume
sole responsibility for said debts. Husband shall make said contribution either by paying
$10,388.00 to Wife, or by effectuating a balance transfer to roll over $10,388.00 of the above-
referenced debt to a debt vehicle on which Husband alone is responsible. From and after
Husband's said contribution, Wife shall indemnify and hold harmless Husband from any
responsibility for said debts, which indemnification shall include attorney's fees.
J. Liability Not Listed. Each party represents and warrants to the other that he or
she has not incurred any debt, obligation or other liability, other than those described in this
Agreement, on which the other party is or may be liable. A liability not disclosed in this
Agreement will be the sole responsibility of the party who has incurred or may hereafter incur it,
and such party agrees to pay it as the same shall become due, and to indemnify and hold the other
party and his or her property harmless from any and all debts, obligations and liabilities.
K. Indemnification of Wife. If any claim, action or proceeding is hereafter
initiated seeking to hold Wife liable for the debts or obligations assume by Husband under this
Agreement, Husband will, at his sole expense, defend Wife against any such claim, action or
proceeding, whether or not well-founded, and indemnify her and her property against any
Page 9 of 20
damages or loss resulting therefrom, including, but not limited to, costs of court and actual
attorney's fees incurred by Wife in connection therewith.
L. Indemnification of Husband. If any claim, action or proceeding is hereafter
initiated seeking to hold Husband liable for the debts or obligations assumed by Wife under this
Agreement, Wife will, at her sole expense, defend Husband against any such claim, action or
proceeding, whether or not well-founded, and indemnify him and his property against any
damages or loss resulting therefrom, including, but not limited to, costs of court and actual
attorney's fees incurred by Husband in connection therewith.
M. Warranty as to Future Obligations. Husband and Wife each represents and
warrants to the other that he or she will not at any time in the future incur or contract any debt,
charge or liability for which the other, the other's legal representatives, property or estate may be
responsible. From the date of execution of this Agreement, each party shall use only those credit
cards and accounts for which that party is individually liable and the parties agree to cooperate in
closing any remaining accounts which provide for joint liability. Each party hereby agrees to
indemnify, save and hold the other and his or her property harmless from any liability, loss, cost
or expense whatsoever, including actual attorney's fees, incurred in the event of breach hereof.
7. INCOME TAX. The parties have heretofore filed joint federal and state tax returns.
Both parties agree that, relative to any such previously jointly-filed returns, in the event any
deficiency in federal, state or local income tax is proposed or any assessment of any such tax is
made against either of them, each will indemnify and hold harmless the other from and against
any loss or liability for any such tax deficiency or assessment and any interest, penalty and
expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid
Page 10 of 20
solely and entirely by the individual who is finally determined to be the cause of the
misrepresentations or failures to disclose the nature and extent or his or her separate income on
the aforesaid joint returns.
The parties have filed ajoint return for 2005. A refund of$I,597.00 is
anticipated. Husband agrees, immediately upon receipt of said refund check, to endorse said
check to Wife, and upon Husband's endorsement thereof, Husband shall receive credit for
$798.50 (representing Husband's half of said check) against the $10,388.00 owed by Husband to
Wife in accordance with paragraph 61 herein. In the event said refund check is more or less than
anticipated, Husband's credit shall be adjusted accordingly, to equal one half of said refund.
Unless otherwise agreed by the parties, Wife will be entitled to claim all three
children as her dependents for income tax purposes. Husband agrees each year to sign any forms
required by the IRS to permit Wife to do so.
8. CUSTODY. The parties acknowledge that custody of their minor children is in
accordance with the Order of Court dated November 18, 2005, docketed to number 05-5089,
Civil Term, Court of Common Pleas of Cumberland County, Pennsylvania.
9. ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT. Husband and
Wife hereby expressly waive, discharge and release any and all rights and claims which either
may have now or hereafter by reason of the parties' marriage to alimony, alimony pendente lite,
spousal support and/or maintenance of other like benefits resulting from the parties' status as
husband and wife. Except as provided herein, the parties further release and waive any rights
they may have to seek modification of the terms of this paragraph in a court oflaw or equity, it
being understood that the foregoing constitutes a final determination for all time of either party's
Page 11 of 20
obligation to contribute to the support and maintenance of the other.
10. SUPPORT OF CHILDREN, HEALTH INSURANCE, COLLEGE EXPENSES,
AND MILITARY CARD:
A. Husband shall pay to Wife the sum of One Thousand Seven Hundred Fifty
($1,750.00) Dollars per month for support of the parties' three minor children. Concurrent with
execution of the within Agreement, Husband agrees to immediately establish an automatic
transfer from an account under Husband's control to Wife's checking account on the first
business day of each month, to effectuate said child support payment.
Husband shall have the right to seek a modification of said support amount
through Domestic Relations at such time as the middle child reaches the age at which no support
would be due and owing under then-current applicable Pennsylvania statutes.
B. Husband, at his sole expense, shall maintain Tricare Prime Health Insurance,
and Husband's choice of vision and dental insurance, for the three minor children until each child
has attained the age of 18 (or 22, should one or more children attend college or trade school).
Should Tricare cease to be available to Husband, Husband shall maintain the closest equivalent
medical insurance, at Husband's sole expense. Husband shall be solely responsible for all co-
payments, deductibles, and medical, vision or dental bills not covered by insurance, including
orthodontia and counselling and/or psychological or psychiatric care.
C. Wife shall, at her sole expense, assume the cost of Wife's medical insurance
effective the first day of the month following the entry of a final Decree in Divorce.
D. Immediately upon entry of a final Decree in Divorce, Wife shall cease using
her "military card" for access to the commissary and base, and shall surrender said card no later
Page 12 of 20
than the first day of the month following the entry of said Decree.
E. Husband shall be responsible to pay a portion of the expenses of each child to
attend the undergraduate college of said child's choosing, said expenses to include but not be
limited to tuition, room and board, books, and lab fees. Husband's contribution to said total
expenses shall be equal to Husband's proportionate share of the parties' combined gross annual
income, as evidenced by the previous year's federal income tax return. By way of example and
not by limitation, should Husband's gross annual salary then equal $100,000.00, and Wife's
gross annual salary then equal $50,000.00, the combined total gross annual income of the parties
would be $150,000.00, and Husband's income would equal 2/3 of said income, thereby
obligating Husband to pay 2/3 of the above-stated college expenses.
11. WAIVER OF INHERITANCE RIGHTS. Unless otherwise specifically
provided in this Agreement, as of the execution date of this Agreement, Husband and Wife each
waives all rights of inheritance in the estate of the other, any right to elect to take against the will
or any trust of the other, or in which the other has an interest, and each of the parties waives any
additional rights which said party has or may have by reason of their marriage, except the rights
saved or created by the terms of this Agreement. This wavier shall be construed generally and
shall include, but not be limited to, a waiver of all rights provided under the laws of
Pennsylvania, or any other jurisdiction.
12. WAIVER OF BENEFICIARY DESIGNATION. Unless otherwise specifically set
forth in this Agreement, each party hereto specifically waives any and all beneficiary rights and
any and all rights as a surviving spouse in and to any asset, benefit or like program carrying a
beneficiary designation which belongs to the other party under the terms of this Agreement,
Page 13 of 20
including but not limited to pensions and retirement plans of any sort or nature, deferred
compensation plans, life insurance policies, annuities, stock accounts, bank accounts, final pay
checks or any other post-death distribution scheme, and each party expressly states that it is his
and her intention to revoke by the terms of this Agreement any beneficiary designations naming
the other which are in effect as of the date of execution of this Agreement. If and in the event the
other party continues to be named as beneficiary and no alternate beneficiary is otherwise
designated, the beneficiary shall be deemed to be the estate of the deceased party.
13. RELEASE OF CLAIMS.
A. Wife and Husband acknowledge and agree that the property dispositions
provided for herein constitute an equitable distribution of their assets and liabilities pursuant to
Section 3502 of the Divorce Code, and Wife and Husband hereby waive any right to division of
their property except as provided for in this Agreement. Furthermore, except as otherwise
provided for in this Agreement, each of the parties hereby specifically waives, releases,
renounces and forever abandons any claim, right, title or interest whatsoever he or she may have
in property transferred to the other party pursuant to this Agreement or identified in this
Agreement as belonging to the other party, and each party agrees never to assert any claim to said
property or proceeds in the future. The parties have divided between them to their mutual
satisfaction all personal effects, household goods and furnishings and all other articles of
personal property which have heretofore been used in common by them, and neither party will
make any claim to any such items which are now in the possession or under the control of the
other. Should it become necessary, each party agrees to sign any title or documents necessary to
give effect to this paragraph, upon request. However, neither party is released or discharged from
Page 14 of 20
any obligation under this Agreement or any instrument or document executed pursuant to this
Agreement. Husband and Wife shall hereafter own and enjoy independently of any claim or right
of the other, all items of personal property, tangible or intangible, acquired by him or her from
the execution date of this Agreement with full power in him or her to dispose of the same fully
and effectively for all purposes.
B. Each party hereby absolutely and unconditionally releases and forever
discharges the other, and the estate of the other, for all purposes, from any and all rights and
obligations which either party may presently have or at any time hereafter will have for past,
present or future support or maintenance, alimony pendente lite, alimony, equitable distribution,
counsel fees, costs, expenses, and any other right or obligation, economic or otherwise, whether
arising out of the marital relationship or otherwise, including all rights and benefits under the
Pennsylvania Divorce Code of 1980, its supplements and amendments, as well as under any other
law of any other jurisdiction, except and only except all rights and obligations arising under this
Agreement or for the breach of any of its provisions. Neither party shall have any obligation to
the other not expressly set forth herein.
C. Except as set forth in this Agreement, each party hereby absolutely and
unconditionally releases and forever discharges the other, and his or her heirs, executors,
administrators, assigns, property and estate from any and all rights, claims, demands or
obligations arising out of or by virtue of the marital relationship of the parties, whether now
existing or hereafter arising. The above release shall be effective regardless of whether such
claims arise out of any former or future acts, contracts, engagements or liabilities of the other or
by way of dower, curtesy, widow's or widower's rights, family exemption or similar allowance,
Page 15 of 20
or under the intestate laws or the right to take against the spouse's will, or the right to treat a
lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to
participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any
state, commonwealth or territory of the United States, or any other country.
D. Except for the obligations of the parties contained in this Agreement and such
rights as are expressly reserved herein, each party gives to the other by the execution of this
Agreement an absolute and unconditional release and discharge from all causes of action, claims,
rights or demands whatsoever in law or in equity, which either party ever had or now has against
the other.
E. The parties agree to elect to have the provisions of Section 1041 of the Internal
Revenue Code apply to all qualifying transfers of property. The parties understand that Section
1041 applies to all property transferred between spouses or former spouses incident to divorce.
The parties further understand that the effects for federal income tax purposes of having Section
1041 apply are that (1) no gain or loss is recognized by the transferor spouse/former spouse as a
result of this transfer and (2) the basis of the transferred property in the hands of the transferee
spouse/former spouse is the adjusted basis of the property in the hands of the transferor spouse
immediately before the transfer, whether or not the adjusted basis of the transferred property is
less than, equal to, or greater than the fair market value of the property at the time of transfer.
The parties understand that if the transferee spouse/former spouse disposes of the property in a
Page 16 of 20
transaction in which gain is recognized, the amount of gain that is taxable may be larger than it
would have been if this election had not been made.
14. PRESERVATION OF RECORDS. Each party will keep and preserve for a period
of four (4) years from the date of their divorce decree all financial records relating to the marital
estate, and each party will allow the other party access to those records in the event of tax audits..
15. MODIFICATION. No modification, rescission, or amendment to this Agreement
shall be effective unless in writing signed by each of the parties hereto.
16. SEVERABILITY. If any provision of this Agreement is held by a court of
competent jurisdiction to be void, invalid or unenforceable, the remaining provisions hereof shall
nevertheless survive and continue in full force and effect without being impaired or invalidated
In any way.
17. BREACH. If either party hereto breaches any provision hereof, the other party shall
have the right, at his or her election, to sue for damages for such breach, or seek such other
remedies or relief as may be available to him or her. The non-breaching party shall be entitled to
recover from the breaching party all costs, expenses and legal fees actually incurred in the
enforcement of the rights of the non-breaching party.
18. WAIVER OF BREACH. The waiver by one party of any breach of this agreement
by the other party will not be deemed a waiver of any other breach or any provision of this
Agreement.
19. NOTICE. Any notice to be given under this Agreement by either party to the other
shall be in writing and may be effected by registered or certified mail, return receipt requested.
Notice to Husband will be sufficient if made or addressed to the following: 18 E. Lisburn Rd.,
Page 17 of 20
Suite 201, Mechanicsburg P A 17055, and to Wife, if made or addressed to the following: 267
Hillcrest Rd., Camp Hill PA 17011.
Notice shall be deemed to have occurred upon the date received by the recipient. Each
party may change the address for notice to him or her by giving notice of that change in
accordance with the provisions of this paragraph.
20. APPLICABLE LAW. All acts contemplated by this Agreement shall be construed
and enforced under the substantive laws of the Commonwealth of Pennsylvania (without regard
to the conflict of law rules applicable in Pennsylvania) in effect as of the date of execution of this
Agreement.
21. DATE OF EXECUTION. The "date of execution" or "execution date" of this
Agreement shall be defined as the date upon which the parties signed the Agreement if they do so
on the same date, or if not on the same date, then the date on which the Agreement was signed by
the last party to execute this Agreement.
22. EFFECTIVE DATE. This agreement shall become effective and binding upon both
parties on the execution date.
23. EFFECT OF DIVORCE, EFFECT OF RECONCILIATION, SURVIVAL OF
WARRANTIES. This Agreement shall remain in full force and effect and shall not be
abrogated even if the parties effect a reconciliation, cohabit as husband and wife or attempt to
effect a reconciliation. This Agreement also shall continue in full force and effect in the event of
the parties' divorce. There shall be no modification or waiver of any of the terms hereof unless
the parties in writing execute a statement declaring this Agreement or any term of this Agreement
to be null and void. If any term, condition, clause or provision of this Agreement shall, by its
Page 18 of 20
reasonable interpretation, be intended to survive and extend beyond the termination of the
marriage relationship presently existing between the parties hereto, said term or terms, condition
or conditions, clause or clauses, or provision or provisions, shall be so construed, it being the
express intention of both parties hereto to have this Agreement govern their relationship now and
hereafter, irrespective of their marital status.
24. HEADINGS NOT PART OF AGREEMENT. Any headings preceding the text of
the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference
and shall not constitute a part of this Agreement nor shall they affect its meaning, constructi~n or
effect.
25. AGREEMENT BINDING ON PARTIES AND HEIRS. This Agreement shall
bind the parties hereto and their respective heirs, executors, administrators, legal representatives,
assigns, and successors in any interest of the parties.
26. ENTIRE AGREEMENT. Each party acknowledges that he or she has carefully
read this Agreement; theat he or she has discussed its provisions with an attorney or his or her
own choice, and has executed it voluntarily and in reliance upon his or her own attorney, or has
waived the right to consult with an attorney despite being advised to do so; and that this
instrument expresses the entire agreement between the parties concerning the subjects it purports
to cover and supersedes any and all prior agreements between the parties. This Agreement
should be interpreted fairly and simply, and not strictly for or against either of the parties.
27. MUTUAL COOPERATION. Each party shall, on demand, execute and deliver to
the other any deeds, bills of sale, assignments, consents to change of beneficiary designations, tax
returns, and other documents, and shall do or cause to be done every other act or thing that may
Page 19 of 20
,
..
be necessary or desirable to effectuate the provisions and purposes of this Agreement. If either
party unreasonably fails on demand to comply with these provisions, that party shall pay to the
other party all attorney's fees, costs, and other expenses actually incurred as a result of such
failure.
28. AGREEMENT NOT TO BE MERGED. This Agreement may be incorporated
into a decree of divorce for purposes of enforcement only, but otherwise shall not be merged into
said decree. The parties shall have the right to enforce this Agreement under the Divorce Code
of 1980, as amended, and in addition, shall retain any remedies in law or in equity under this
Agreement as an independent contract. Such remedies in law or equity are specifically not
waived or released.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and
year first written above.
WITNESS:
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Richard D. Wilson
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Molly H. Wilson
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Page 20 of 20
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MOLLY H. WILSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 05-5089 (Civil Term)
RICHARD D. WILSON,
Defendant
CIVIL ACTION - LA W
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was
filed on October 5, 2005.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of filing 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: r( ] I O(
II/IIf/2t! -
Molly H. Wilson, Plaintiff
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 05-5089 (Civil Term)
RICHARD D. WILSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER 3301(C) AND 3301(0) OF THE DIVORCE CODE
1. I consent to the entry of a fmal 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 .
4. 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.
Date:
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Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 05-5089 (Civil Term)
RICHARD D. WILSON,
Defendant
CIVIL ACTION - LA W
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was
filed on October 5, 2005.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of filing the Complaint.
3. I consent to the entry of a fmal decree of divorce after service of Notice of
Intention to Request Entry of the Decree.
I verify that the statements made in this Affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904
relating to unsworn falsification to authorities.
DATED: S-2.0b
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Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 05-5089 (Civil Term)
RICHARD D. WILSON,
Defendant
CIVIL ACTION - LA W
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER 3301(C) AND 33010>) 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 .
4. 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.
Date: S-Z-O{.
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Richard D. Wilson
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 05-5089 (Civil Term)
: CIVIL ACTION - LA W
: IN DIVORCE
v.
RICHARD D. WILSON,
Defendant
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
: SS:
COUNTY
OF DAUPHIN
Personally appeared before me, a Notary Public, in and for said Commonwealth
and County, John F. King, Esquire, Attorney for the Plaintiff, who, being duly sworn
according to law, deposes and says that a Certified copy of the Complaint in Divorce in the
above-captioned matter was served upon Defendant, Richard D. Wilson, by Certified Mail,
Restricted Delivery, as evidenced by the attached Certified Mai d, on 1 0/11 /05.
Sworn and subscribed to
before me this dj~
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Notary Public .
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COMMONW!ALtt-t or rI::NN!!SVlVANIA
NOTARIAL SEAL .
BARBARA E. PALMER, Not~ry Public
City of Harrisburg! Da~fhI02;0~~~
My commission Expires may ,
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MOLL Y H. WILSON,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
: NO. 05-5089 (Civil Term)
: CIVIL ACTION - LAW
: IN DIVORCE
RICHARD D. WILSON,
Defendant
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MOLLY H. WILSON,
Plaintiff
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
: NO. 05-5089 (Civil Term)
: CIVIL ACTION - LA W
: IN DIVORCE
RICHARD D. WILSON,
Defendant
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court for entry of a
divorce decree:
Code.
1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce
2. Date and manner of service of the complaint: certified mail, restricted delivery,
10/11/2005.
3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the
. Divorce Code: by Plaintiff 5/3/06; by Defendant 5/2/06.
4. Related claims pending: There are no related claims pending.
5. (Complete either (a) or (b).)
(a) Date and manner of service of the notice of intention to file praecipe to transmit
record, a copy of which is attached:
(b) Date Plaintiffs Waiver of Notice was filed with the Prothonotary: 5/31/06
Date Defendant's Waiver of Notice was filed wi
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VERSUS
RICHARD D. WILSON
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DECREE IN
DIVORCE
AND NOW, J l1. n C- ry
Molly H. Wilson
DECREED THAT
Richard D. Wilson
AND
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, PLAINTIFF,
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
The attached marital settlement agreement is incorporated,
but not merged, and made a part of this Decree in Divorce.
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PROTHONOTARY
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MOLLYH. WILSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-5089 (Civil Term)
CIVIL ACTION - LAW
IN DIVORCE
v.
RICHARD D. WILSON,
Defendant
PETITION FOR CONTEMPT FOR DEFENDANT'S FAILURE TO COMPLY
WITH THE MARITAL SETTLEMENT AGREEMENT ENTERED OF RECORD
TO THE HONORABLE, THE JUDGES OF THE SAID COURT:
AND NOW COMES the Petitioner, Molly H. Wilson, Plaintiff in the above
matter, by and through her attorneys, Friedman & King, P.C., and brings this Petition for
Contempt, averring as follows:
1. Petitioner, Molly H. Wilson, currently resides at 267 Hillcrest Rd.
Camp Hill, PA 17011.
2. Respondent, Richard S. Wilson, has a business address of 18 E. Lisburn
Road, Suite 201, Mechanicsburg, PA 17055, and is the ex-husband of Petitioner.
3. Petitioner and Respondent executed a Marital Settlement Agreement, dated
April 25, 2006, which was incorporated, but not merged, and made a part of the Decree in
Divorce granted on June 7, 2006. A copy of said Marital Settlement Agreement and Decree in
Divorce are attached hereto, and collectively marked as Exhibit" A".
4. Petitioner was and is represented by John F. King, Esquire, and Respondent
was and is believed to be unrepresented.
5. Petitioner and Respondent knowingly and voluntarily entered into said
agreement, with the understanding that it would be incorporated into their divorce decree.
"
,
6. Respondent has failed to pay to Petitioner the following:
A. $3,000.00, as required by paragraph 6(0) of said Marital Settlement
Agreement; and
B. $10,388.00, as required by paragraph 6(1) of said Marital Settlement
Agreement.
7. As per the Marital Settlement Agreement, specifically paragraph 6A, "The
parties acknowledge that subject premises was used by Husband as collateral when Husband
secured one or more loans for the business known as Telkore, Inc. (said business to be further
discussed below). Within sixty (60) days of execution of the within Agreement, Husband shall
cause all such liens against subject premises to be removed, whether by refinancing of said
loans or by the execution of a release of liens by the loan-holder." Respondent has failed to
have the liens removed.
8. As per the Marital Settlement Agreement, specifically paragraph 10(A),
"Husband shall pay to Wife the sum of One Thousand Seven Hundred Fifty ($1,750.00) Dollars
per month for support of the parties' three minor children. Concurrent with execution of the
within Agreement, Husband agrees to immediately establish an automatic transfer from an
account under Husband's control to Wife's checking account on the first business day of each
month, to effectuate said child support payment." Husband has failed to set up said automatic
transfer to effectuate said child support payment.
9. Petitioner has been forced to incur attorney's fees, costs and expenses in
enforcing her rights under Exhibit" A"in the amount of Four Hundred Eighty ($480.00)
Dollars, and would be forced to incur significant additional attorney's fees, costs and
expenses if Respondent is not compelled by this Honorable Court to fulfill his responsibilities
under Exhibit A.
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10. Petitioner will incur additional attorney's fees through the hearing date of
this action.
II. Respondent is required to pay all attorney's fee, costs and expenses
incurred due to Respondent's breach of the Marital Settlement Agreement, as per paragraph
17 of Marital Settlement Agreement.
WHEREFORE, Petitioner respectfully requests Your Honorable Court to grant
the following relief:
A. Find Respondent in contempt of court for his failure to comply with
the terms of the Marital Settlement Agreement, which agreement was incorporated but not
merged with the Decree in Divorce.
B. Issue Order compelling Respondent to inunediately pay to Petitioner
the sum of $13,388.00.
C. Issue Order compelling Respondent to remove any and all such liens
against premises situate 267 Hillcrest Road, Camp Hill, PA.
D. Issue Order compelling Respondent to establish an automatic transfer
from Respondent's account to Petitioner's checking account to effectuate said child support
payment in the amount of $1,750.00 per month.
E. Order Respondent to pay Petitioner's attorney's fees in the amount
of Four Hundred Eighty ($480.00) Dollars, plus costs and expenses, plus additional attorney's
fees (in an amount to be determined at hearing) incurred in enforcing the terms of the
agreement.
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F. Such other relief as this Court deems appropriate.
Respectfully submitted,
FRIEDMAN & KING, P.C.
o.rei).A2,,# (PI ~
VERIFICATION
I, Molly H. Wilson, hereby acknowledge that I am the Petitioner in the foregoing
action; that I have read the foregoing Petition for Contempt for Defendant's Failure to Comply
with the Marital Settlement Agreement Entered of Record; and the facts stated therein are true
and correct to the best of my knowledge, information and belief.
I understand that any false statements herein are made subject to penalties of 18
Pa. C.S. Section 4904, relating to unsworn falsification to authorities.
Dated:
~
Molly H. Wilson ~
5jJlJp
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
MOLLY H. WILSON
VERSUS
RICHARD D. WILSON
.
.
.
AND NOW, June 7
.
.
DECREED THAT
PENNA.
No.
05-5089 Civil
.
.
.
DECREE IN
DIVORCE
2006
, IT IS ORDERED AND
Molly H. Wilson
, PLAINTIFF,
AND
Richard D. Wilson
, DEFENDANT.
.
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
The attached marital settlement agreement is incorporated
but not merged, and made a part of this Decree in Divorce.
.
.
.
.
.
.
By THE COURT:
J. Wesley Oler, Jr.
ATTEST:
,
J.
.
.
PROTHONOTARY
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NUUUTAL SETTLEMENT AGREEMENT
THIS AGREEMENT, made this 2rth day of Ar f'; I ,20ot, by and between f10~Y
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H. WILSON, of Camp Hill, Cumberland County, Pennsylvania, and RICHARD D. WILSO~,:
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whose business address is in Mechanicsburg, Cumberland County, Pennsylvania.
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WHEREAS, the parties hereto are husband and wife, having been lawfully married cfit'
December 28, 1993; and
WHEREAS, the parties have lived separate and apart since on or about August 26, 2005;
and
WHEREAS, three children were born of the marriage between the parties, namely, Logan
A. Wilson, born December 11, 1995, Connor R. Wilson, born July 13,1997, and Peyton C.
Wilson, born December 20, 2002; and
WHEREAS, the parties hereto are desirous of settling fully and finally their respective
financial and property rights and obligations as between each other, including, without limitation,
the settling of all matters between them relating to the ownership of real and personal property,
the support and maintenance of one another, and, in general, the settling of any and all claims and
possible claims by one against the other or against their respective estates.
NOW THEREFORE, in consideration of these premises, and of the mutual promises,
covenants and undertakings hereinafter set forth, and for other good and valuable consideration,
the receipt and sufficiency of which is hereby acknowledged by each of the parties hereto,
Husband and Wife, each intending to be legally bound hereby, covenant and agree as follows:
Page 1 of 20
. ,
1. PERSONAL RIGHTS. Husband and Wife may, at all times hereafter, live separate
and apart. Each shall be free from all control, restraint, interference and authority, direct or
indirect, by the other. Each may reside at such place or places as he or she may select. Each
may, for his or her separate use or benefit, conduct, carry on or engage in any business,
occupation, profession or employment which to him or her may seem advisable. Husband and
Wife shall not molest, harass, disturb or malign each other, nor compel or attempt to compel the
other to cohabit or dwell by any means or in any manner whatsoever with him or her. Neither
party will interfere with the use, ownership, enjoymen~ or disposition of any property now owned
by or hereafter acquired by the other. During the said separation, the parties shall have the right
to live as though they were unmarried, and their conduct during the separation shall not give rise
to additional grounds for divorce which do not presently exist. This Agreement shall not be
considered to affect or bar the right of Wife or Husband to a limited or absolute divorce on
lawful grounds if such grounds now exist or shall hereafter exist, or to such defense as may be
available to either party. This Agreement is not intended to condone and shall not be deemed to
be a condonation on the part of either party hereto of any act or acts on the part of the other party
which have occasioned the disputes or unhappy differences, which acts have occurred prior to or
which may occur subsequent to the date hereof.
2. CONSIDERATION FOR AGREEMENT. The consideration for this contract and
agreement is the mutual benefits to be obtained by each of the parties to the other. The adequacy
of the consideration for all agreements herein contained is stipulated, confessed, and admitted by
the parties, and the parties intend to be legally bound hereby.
Page 2 of 20
'.
.
3. ADVICE OF COUNSEL. Husband acknowledges that this Agreement has been
prepared by counsel selected by Wife, to wit, John F. King, Esq., of the firm of Friedman &
King, PC. Husband is aware that he has the absolute right to be represented by sole and
independent counsel of his own choosing to advise him as to his rights and responsibilities in the
within action, and that he has been advised by counsel for Wife that he would be well advised to
secure said representation. Husband is aware that Wife's counsel represents only the interests of
Wife. Husband did not rely upon any assurances of Wife's counsel, nor did he confer with
Wife's counsel, prior to executing the within Agreement. Each party fully understands the facts
and his or her legal rights and obligations, and each party acknowledges and accepts that this
Agreement is, in the circumstances, fair and equitable, and that it is being entered into freely and
voluntarily, and that the execution of this Agreement is not the result of any duress or undue
influence, and that it is not the result of any improper or illegal agreement or agreements. In
addition, each party understands the impact of the Pennsylvania Divorce Code, whereby 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, 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 waives his or her
respective right to have the Court of Common Pleas of Cumberland County, or any other court of
competent jurisdiction, make any determination or order affecting the respective parties' rights to
alimony, alimony pendente lite, support and maintenance, equitable distribution, counsel fees and
costs of litigation.
Page 3 of 20
4. DISCLOSURE OF ASSETS. Each of the parties hereto acknowledges that he or she
is aware of his or her right to seek discovery, including, but not limited to, written
interrogatories, motions for production of documents, the taking of oral depositions, the filing of
inventories, and all other means of discovery permitted under the Pennsylvania Divorce Code or
the Pennsylvania Rules of Civil Procedure. Each of the parties further acknowledges that he or
she has had the opportunity to discuss with counsel the concept of marital property under
Pennsylvania law, and each is aware of his or her right to have the real andlor personal property,
estate and assets, earnings and income of the other assessed or evaluated by the courts of this
Commonwealth or any other court of competent jurisdiction. The parties do hereby acknowledge
that there has been full and fair disclosure to the other of his or her respective income, assets and
liabilities, whether such are held jointly, in the name of one party alone, or in the name of one of
the parties and another individual or individuals. Each party agrees that any right to further
disclosure, valuation, appraisal or enumeration or statement thereof in this Agreement is hereby
specifically waived, and the parties do not wish to make or append hereto any further
enumeration or statement. Specifically, each party waives the need for copies of bank
statements, insurance policies, retirement plan statements or any other documentation. Each
party warrants that he or she is not aware of any marital asset which is not identified in this
Agreement. The parties hereby acknowledge and agree that the division of assets as set forth in
this Agreement is fair, reasonable and equitable, and is satisfactory to them. Each of the parties
hereto further covenants and agrees for himself and herself and his or her heirs, executors,
administrators or assigns, that he or she will never at any time hereafter sue the other party or his
or her heirs, executors, administrators or assigns in any action of contention, direct or indirect,
Page 4 of 20
.,'
and allege therein that there was a denial of any rights to full disclosure, or that there was any
fraud, duress, undue influence or that there was a failure to have available full, proper and
independent representation by legal counsel.
5. MUTUAL CONSENT DIVORCE. It is the intention of the parties, and the parties
agree, that by this Agreement they have resolved all ancillary economic issues related to the
dissolution of their marriage, and thus any divorce action with respect to these parties shall be
limited to a claim for divorce only. Wife has filed a divorce complaint in the Court of Common
Pleas of Cumberland County, Pennsylvania, docketed to number 05-5089. The parties agree that
each will execute an Affidavit of Consent and Waiver of Notice of Intention to Request Entry of
Divorce Decree in order that counsel for Wife may finalize the divorce action in a timely fashion.
Upon completion of the divorce action, counsel for Wife shall supply Husband with a copy of the
Decree.
6. EQUITABLE DISTRIBUTION.
A. Real estate: The parties are the owners of real estate located at 267 Hillcrest
Rd., Camp Hill PAl 70 I I (hereinafter called "subject premises"). Wife presently is, and has
been, in sole and exclusive possession of subject premises. Concurrent with the execution of the
within Agreement, Husband agrees that he will transfer all of his right, title and interest to
subject premises to Wife. Wife has been, and shall remain, solely responsible for all expenses
attendant to subject premises, including but not limited to 'real estate taxes, utilities, and.
homeowner's insurance.
Page 5 of 20
The parties acknowledge that subject premises was used by Husband as collateral
when Husband secured one or more loans for the business known as Telkore, Inc. (said business
to be further discussed below). Within sixty (60) days of execution of the within Agreement,
Husband shall cause all such liens against subject premises to be removed, whether by
refinancing of said loans or by the execution of a release of liens by the loan-holder. Husband
shall indemnify and hold harmless Wife from any said liens, said indemnification to include
attorney's feesand costs.
Wife shall take any and all steps necessary to refinance the present mortgage
encumbering subject premises so that Husband is removed therefrom, within two (2) years of
execution of the within Agreement. The above notwithstanding, Wife shall not be obligated to
complete said refmance unless and until all liens against subject premises by virtue of the
dealings of Telkore, Inc. are removed.
B. Furnishings and personalty: The parties agree that they have divided by
agreement between themselves all personal property (other than that specifically set forth in the
within Agreement). Accordingly, Husband shall retain sole and exclusive ownership of all
personal property currently in his possession (other than that specifically set forth in the within
Agreement), free and clear of any right, title, claim andlor interest of Wife, and Wife shall retain
sole and exclusive ownership of all personal property currently in her possession (other than that
specifically set forth in the within Agreement), free and clear of any right, title, claim and/or
interest of Husband.
C. Motor Vehicles Other Than Motorcycle: Each party is the owner of a vehicle
titled solely in his or her name, and is currently in sole and exclusive possession of said vehicle.
Page 6 of 20
Each party shall be solely responsible for any encumbrances on the vehicle in his or her
possession.
D. Motorcyle: Husband retained the 1998 Honda Valkyrie motorcycle as his sole
and exclusive possession until Husband's recent post-separation transfer of said motorcycle. In
recognition of the fact that said motorcycle was a marital asset, Husband shall, concurrent with
execution of the within Agreement, pay Wife the sum of Three Thousand ($3,000.00) Dollars as
a partial distribution of the marital estate.
E. Husband's Business: The parties acknowledge that Husband is the sole
shareholder in a business operated by Husband known as Telkore, Inc. Wife waives any claim
which she could otherwise assert for ownership of said business, which said business shall
remain the sole and exclusive property of Husband. Husband shall indemnifY and hold harmless
Wife from any debts of said business.
F. Life Insurance: Husband agrees, at Husband's sole expense, to maintain the
USAA life insurance policy presently insuring his life, with the children as beneficiaries (Wife
being named the children's guardian), in the current amount of One Million ($1,000,000.00)
Dollars, until such time as the youngest child has completed his undergraduate education, or until
said child has reached the age of 22, whichever shall first occur. The required amount of One
Million ($1,000,000.00) Dollars may be proportionately reduced, if Husband so chooses, as each
child reaches the age of 22 or completes undergraduate education. Payments for the premium for
said policy shall continue to be electronically paid from Wife's checking account, and Husband
shall pay Wife the sum of One Hundred Sixty ($160.00) Dollars per month in reimbursement
therefor.
Page 7 of 20
Wife agrees, at Wife's sole expense, to maintain the USAA life insurance policy
(number A549574870) presently insuring her life, with the children as beneficiaries, in the
current amount of Seven Hundred Fifty Thousand ($750,000.00) Dollars, until such time as the
youngest child has completed his undergraduate education, or until said child has reached the age
of 22, whichever shall first occur. The required amount of Seven Hundred Fifty Thousand
($750,000.00) Dollars may be proportionately reduced, if Wife so chooses, as each child reaches
the age of 22 or completes undergraduate education.
Upon demand, the parties shall each execute an authorization allowing the other
party to obtain any and all information regarding said life insurance policy.
G. Retirement Accounts: Husband shall retain as his sole and exclusive property
the monthly retirement pay from the US Marine Corps. Said monthly payments shall be included
as income for Husband in any future Domestic Relations hearings. Said payments are presently
being electronically deposited into Wife's account, but upon execution of the within Agreement,
the parties shall take such steps as are necessary to redirect said payments to an account
controlled by Husband.
Wife shall retain as her sole and exclusive property the retirement account in her
name with TIAA CREF, with a present estimated value of $37,500.00.
H. Misc. Accounts: The parties, during their marriage, had certain joint banking
accounts, neither of which has any present value. Upon execution of the within Agreement, the
parties shall take steps to close said accounts and open separate banking accounts.
I. Marital Debt. At the time of separation (August 26, 2005) the parties were
jointly obligated under the following accounts:
Page 8 of 20
USAA Mastercard no. 5458 8310 0319 9951
Chase Visa no. 4266 9010 24152324
Members First PSL no. 233780
TIAA CREF no. 29559226001
TOTAL
8,044.00
5,200.00
5,000.00
2,532.00
$20.776.00
Concurrent with the execution of the within Agreement, Husband shall contribute
the sum of$IO,388.00, representing one half of the above-listed accounts, and Wife shall assume
sole responsibility for said debts. Husband shall make said contribution either by paying
$10,388.00 to Wife, or by effectuating a balance transfer to roll over $10,388.00 of the above-
referenced debt to a debt vehicle on which Husband alone is responsible. From and after
Husband's said contribution, Wife shall indemnify and hold hannless Husband from any
responsibility for said debts, which indemnification shall include attorney's fees.
J. Liability Not Listed. Each party represents and warrants to the other that he or
she has not incurred any debt, obligation or other liability, other than those described in this
Agreement, on which the other party is or may be liable. A liability not disclosed in this
Agreement will be the sole responsibility of the party who has incurred or may hereafter incur it,
and such party agrees to pay it as the same shall become due, and to indemnify and hold the other
party and his or her property harmless from any and all debts, obligations and liabilities.
K. Indemnification of Wife. If any claim, action or proceeding is hereafter
initiated seeking to hold Wife liable for the debts or obligations assume by Husband under this
Agreement, Husband will, at his sole expense, defend Wife against any such claim, action or
proceeding, whether or not well-founded, and indemnify her and her property against any
Page 9 of 20
damages or loss resulting therefrom, including, but not limited to, costs of court and actual
attorney's fees incurred by Wife in connection therewith.
L. Indemnification of Husband. If any claim, action or proceeding is hereafter
initiated seeking to hold Husband liable for the debts or obligations assumed by Wife under this
Agreement, Wife will, at her sole expense, defend Husband against any such claim, action or
proceeding, whether or not well-founded, and indemnifY him and his property against any
damages or loss resulting therefrom, including, but not limited to, costs of court and actual
attorney's fees incurred by Husband in connection therewith.
M. Warranty as to Future Obligations. Husband and Wife each represents and
warrants to the other that he or she will not at any time in the future incur or contract any debt,
charge or liability for which the other, the other's legal representatives, property or estate may be
responsible. From the date of execution of this Agreement, each party shall use only those credit
cards and accounts for which that party is individually liable and the parties agree to cooperate in
closing any remaining accounts which provide for joint liability. Each party hereby agrees to
indemnifY, save and hold the other and his or her property hannless from any liability, loss, cost
or expense whatsoever, including actual attorney's fees, incurred in the event of breach hereof.
7. INCOME TAX. The parties have heretofore filed joint federal and state tax returns. .
Both parties agree that, relative to any such previously jointly-filed returns, in the event any
deficiency in federal, state or local income tax is proposed or any assessment of any such tax is
made against either of them, each will indemnify and hold harmless the other from and against
any loss or liability for any such tax deficiency or assessment and any interest, penalty and
expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid
Page 10 of 20
solely and entirely by the individual who is finally determined to be the cause of the
misrepresentations or failures to disclose the nature and extent or his or her separate income on
the aforesaid joint returns.
The parties have filed ajoint return for 2005. A refund of$I,597.00 is
anticipated. Husband agrees, immediately upon receipt of said refund check, to endorse said
check to Wife, and upon Husband's endorsement thereof, Husband shall receive credit for
$798.50 (representing Husband's half of said check) against the $10,388.00 owed by Husband to
Wife in accordance with paragraph 61 herein, In the event said refund check is more or less than
anticipated, Husband's credit shall be adjusted accordingly, to equal one half of said refund.
Unless otherwise agreed by the parties, Wife will be entitled to claim all three
children as her dependents for income tax purposes. Husband agrees each year to sign any forms
required by the IRS to permit Wife to do so.
8. CUSTODY. The parties acknowledge that custody of their minor children is in
accordance with the Order of Court dated November 18, 2005, docketed to number 05-5089,
Civil Tenn, Court of Common Pleas of Cumberland County, Pennsylvania.
9. ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT. Husband and
Wife hereby expressly waive, discharge and'release any and all rights and claims which either
may have now or hereafter by reason of the parties' marriage to alimony, alimony pendente lite,
spousal support and/or maintenance of other like benefits resulting from the parties' status as .
husband and wife. Except as provided herein, the parties further release and waive any rights
they may have to seek modification of the terms of this paragraph in a court oflaw or equity, it
being understood that the foregoing constitutes a final determination for all time of either party's
Page 11 of 20
obligation to contribute to the support and maintenance of the other.
10. SUPPORT OF CIDLDREN, HEALTH INSURANCE, COLLEGE EXPENSES,
AND MILITARY CARD:
A. Husband shall pay to Wife the sum of One Thousand Seven Hundred Fifty
($1,750.00) Dollars per month for support of the parties' three minor children. Concurrent with
execution of the within Agreement, Husband agrees to immediately establish an automatic
transfer from an account under Husband's control to Wife's checking account on the first
business day of each month, to effectuate said child support payment.
Husband shall have the right to seek a modification of said support amount
through Domestic Relations at such time as the middle child reaches the age at which no support
would be due and owing under then-current applicable Pennsylvania statutes.
B. Husband, at his sole expense, shall maintain Tricare Prime Health Insurance,
and Husband's choice of vision and dental insurance, for the three minor children until each child
has attained the age of 1 8 (or 22, should one or more children attend college or trade school).
Should Tricare cease to be available to Husband, Husband shall maintain the closest equivalent
medical insurance, at Husband's sole expense. Husband shall be solely responsible for all co-
payments, deductibles, and medical, vision or dental bills not covered by insurance, including
orthodontia and counselling and/or psychological or psychiatric care.
C. Wife shall, at her sole expense, assume the cost of Wife's medical insurance
effective the first day of the month following the entry of a fmal Decree in Divorce.
D. Immediately upon entry of a fmal Decree in Divorce, Wife shall cease using
her "military card" for access to the commissary and base, and shall surrender said card no later
Page 12 of 20
'.' ,"
..'
than the first day of the month following the entry of said Decree.
E. Husband shall be responsible to pay a portion of the expenses of each child to
attend the undergraduate college of said child's choosing, said expenses to include but not be
limited to tuition, room and board, books, and lab fees. Husband's contribution to said total
expenses shall be equal to Husband's proportionate share of the parties' combined gross annual
income, as evidenced by the previous year's federal income tax return. By way of example and
not by limitation, should Husband's gross annual salary then equal $100,000.00, and Wife's
gross annual salary then equal $50,000.00, the combined total gross annual income of the parties
would be $150,000.00, and Husband's income would equal 2/3 of said income, thereby
obligating Husband to pay 2/3 of the above-stated college expenses.
I I. WAIVER OF INHERITANCE RIGHTS. Unless otherwise specifically
provided in this Agreement, as of the execution date of this Agreement, Husband and Wife each
waives all rights of inheritance in the estate of the other, any right to elect to take against the will
or any trust of the other, or in which the other has an interest, and each of the parties waives any
additional rights which said party has or may have by reason of their marriage, except the rights
saved or created by the terms of this Agreement. This wavier shall be construed generally and
shall include, but not be limited to, a waiver of all rights provided under the laws of
Pennsylvania, or any other jurisdiction.
12. WAIVER OF BENEFICIARY DESIGNATION. Unless otherwise specifically set
forth in this Agreement, each party hereto specifically waives any and all beneficiary rights and
any and all rights as a surviving spouse in and to any asset, benefit or like program carrying a
beneficiary designation which belongs to the other party under the terms of this Agreement,
Page 13 of 20
.,'
. ,
including but not limited to pensions and retirement plans of any sort or nature, deferred
compensation plans, life insurance policies, annuities, stock accounts, bank accounts, fmal pay
checks or any other post-death distribution scheme, and each party expressly states that it is his
and her intention to revoke by the terms of this Agreement any beneficiary designations naming
the other which are in effect as of the date of execution of this Agreement. If and in the event the
other party continues to be named as beneficiary and no alternate beneficiary is otherwise
designated, the beneficiary shall be deemed to be the estate of the deceased party.
13. RELEASE OF CLAIMS.
A. Wife and Husband acknowledge and agree that the property dispositions
provided for herein constitute an equitable distribution of their assets and liabilities pursuant to
Section 3502 of the Divorce Code, and Wife and Husband hereby waive any right to division of
their property except as provided for in this Agreement. Furthermore, except as otherwise
provided for in this Agreement, each of the parties hereby specifically waives, releases,
renounces and forever abandons any claim, right, title or interest whatsoever he or she may have
in property transferred to the other party pursuant to this Agreement or identified in this
Agreement as belonging to the other party, and each party agrees never to assert any claim to said
property or proceeds in the future. The parties have divided between them to their mutual
satisfaction all personal effects, household goods and furnishings and all other articles of
personal property which have heretofore been used in common by them, and neither party will
make any claim to any such items which are now in the possession or under the control of the
other. Should it become necessary, each party agrees to sign any title or documents necessary to
give effect to this paragraph, upon request. However, neither party is released or discharged from
Page 14 of 20
'.'
,
any obligation under this Agreement or any instrument or document executed pursuant to this
Agreement. Husband and Wife shall hereafter own and enjoy independently of any claim or right
of the other, all items of personal property, tangible or intangible, acquired by him or her from
the execution date of this Agreement with full power in him or her to dispose of the same fully
and effectively for all purposes.
B. Each party hereby absolutely and unconditionally releases and forever
discharges the other, and the estate of the other, for all purposes, from any and all rights and
obligations which either party may presently have or at any time hereafter will have for past,
present or future support or maintenance, alimony pendente lite, alimony, equitable distribution,
counsel fees, costs, expenses, and any other right or obligation, economic or otherwise, whether
arising out of the marital relationship or otherwise, including all rights and benefits under the
Pennsylvania Divorce Code of 1980, its supplements and amendments, as well as under any other
law of any other jurisdiction, except and only except all rights and obligations arising under this
Agreement or for the breach of any of its provisions. Neither party shall have any obligation to
the other not expressly set forth herein.
C. Except as set forth in this Agreement, each party hereby absolutely and
unconditionally releases and forever discharges the other, and his or her heirs, executors,
administrators, assigns, property and estate from any and all rights, claims, demands or
obligations arising out of or by virtue of the marital relationship of the parties, whether now
existing or hereafter arising. The above release shall be effective regardless of whether such
claims arise out of any former or future acts, contracts, engagements or liabilities of the other or
by way of dower, curtesy, widow's or widower's rights, family exemption or similar allowance,
Page 15 of 20
.,'
..'
or under the intestate laws or the right to take against the spouse's will, or the right to treat a
lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to
participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any
state, commonwealth or territory of the United States, or any other country.
D. Except for the obligations of the parties contained in this Agreement and such
rights as are expressly reserved herein, each party gives to the other by the execution of this
Agreement an absolute and unconditional release and discharge from all causes of action, claims,
rights or demands whatsoever in law or in equity, which either party ever had or now has against
the other.
E. The parties agree to elect to have the provisions of Section 1041 of the Internal
Revenue Code apply to all qualifying transfers of property. The parties understand that Section
1041 applies to all property transferred between spouses or former spouses incident to divorce,
The parties further understand that the effects for federal income tax purposes of having Section
1041 apply are that (1) no gain or loss is recognized by the transferor spouse/former spouse as a
result of this transfer and (2) the basis of the transferred property in the hands of the transferee
spouse/former spouse is the adjusted basis of the property in the hands of the transferor spouse
immediately before the transfer, whether or not the adjusted basis of the transferred property is
less than, equal to, or greater than the fair market value ofthe property at the time of transfer.
The parties understand that if the transferee spouse/former spouse disposes of the property in a
Page 16 of 20
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transaction in which gain is recognized, the amount of gain that is taxable may be larger than it
would have been if this election had not been made.
14. PRESERVATION OF RECORDS. Each party will keep and preserve for a period
of four (4) years from the date of their divorce decree all financial records relating to the marital
estate, and each party will allow the other party access to those records in the event of tax audits..
15. MODIFICATION. No modification, rescission, or amendment to this Agreement
shall be effective unless in writing signed by each of the parties hereto.
16. SEVERABILITY. If any provision of this Agreement is held by a court of
competent jurisdiction to be void, invalid or unenforceable, the remaining provisions hereof shall
nevertheless survive and continue in full force and effect without being impaired or invalidated
in any way.
] 7. BREACH. If either party hereto breaches any provision hereof, the other party shall
have the right, at his or her election, to sue for damages for such breach, or seek such other
remedies or relief as may be available to him or her. The non-breaching party shall be entitled to
recover from the breaching party all costs, expenses and legal fees actually incurred in the
enforcement of the rights of the non-breaching party.
] 8. WAIVER OF BREACH. The waiver by one party of any breach of this agreement
by the other party will not be deemed a waiver of any other breach or any provision of this
Agreement.
19. NOTICE. Any notice to be given under this Agreement by either party to the other
shall be in writing and may be effected by registered or certified mail, return receipt requested.
Notice to Husband will be sufficient if made or addressed to the following: ] 8 E. Lisburn Rd.,
Page]7 of 20
'.'
Suite 201, Mechanicsburg P A 17055, and to Wife, if made or addressed to the following: 267
Hillcrest Rd., Camp Hill PA 17011.
Notice shall be deemed to have occurred upon the date received by the recipient. Each
party may change the address for notice to him or her by giving notice of that change in
accordance with the provisions of this paragraph.
20. APPLICABLE LAW. All acts contemplated by this Agreement shall be construed
and enforced under the substantive laws of the Commonwealth of Pennsylvania (without regard
to the conflict of law rules applicable in Pennsylvania) in effect as of the date of execution of this
Agreement.
21. DATE OF EXECUTION. The "date of execution" or "execution date" of this
Agreement shall be defined as the date upon which the parties signed the Agreement if they do so
on the same date, or ifnot on the same date, then the date on which the Agreement was signed by
the last party to execute this Agreement.
22. EFFECTIVE DATE. This agreement shall become effective and binding upon both
parties on the execution date.
23. EFFECT OF DIVORCE, EFFECT OF RECONCILIATION, SURVIVAL OF
WARRANTIES. This Agreement shall remain in full force and effect and shall not be
abrogated even if the parties effect a reconciliation, cohabit as husband and wife or attempt to
effect a reconciliation. This Agreement also shall continue in full force and effect in the event of
the parties' divorce. There shall be no modification or waiver of any of the terms hereof unless
the parties in writing execute a statement declaring this Agreement or any term of this Agreement
to be null and void. If any term, condition, clause or provision of this Agreement shall, by its
Page 18 of 20
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.'
reasonable interpretation, be intended to survive and extend beyond the termination of the
marriage relationship presently existing between the parties hereto, said term or terms, condition
or conditions, clause or clauses, or provision or provisions, shall be so construed, it being the
express intention of both parties hereto to have this Agreement govern their relationship now and
hereafter, irrespective of their marital status.
24. HEADINGS NOT PART OF AGREEMENT. Any headings preceding the text of
the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference
and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or
effect.
25. AGREEMENT BINDING ON PARTIES AND HEIRS. This Agreement shall
bind the parties hereto and their respective heirs, executors, administrators, legal representatives,
assigns, and successors in any interest of the parties.
26. ENTIRE AGREEMENT. Each party acknowledges that he or she has carefully
read this Agreement; theat he or she has discussed its provisions with an attorney or his or her
own choice, and has executed it voluntarily and in reliance upon his or her own attorney, or has
waived the right to consult with an attorney despite being advised to do so; and that this
instrument expresses the entire agreement between the parties concerning the subjects it purports
to cover and supersedes any and all prior agreements between the parties. This Agreement
should be interpreted fairly and simply, and not strictly for or against either ofthe parties.
27. MUTUAL COOPERATION. Each party shall, on demand, execute and deliver to
the other any deeds, bills of sale, assignments, consents to change of beneficiary designations, tax
returns, and other documents, and shall do or cause to be done every other act or thing that may
Page 19 of 20
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be necessary or desirable to effectuate the provisions and purposes of this Agreement. If either
party unreasonably fails on demand to comply with these provisions, that party shall pay to the
other party all attorney's fees, costs, and other expenses actually incurred as a result of such
failure.
28. AGREEMENT NOT TO BE MERGED. This Agreement may be incorporated
into a decree of divorce for purposes of enforcement only, but otherwise shall not be merged into
said decree. The parties shall have the right to enforce this Agreement under the Divorce Code
of 1980, as amended, and in addition, shall retain any remedies in law or in equity under this
Agreement as an independent contract. Such remedies in law or equity are specifically not
waived or released.
IN WI1NESS WHEREOF, the parties hereto have set their hands and seals the day and
year first written above.
WITNESS:
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Richard D. Wilson
4(jII1C~
Molly H. Wilson
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Page 20 of 20
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MOLLY H. WILSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-5089 (Civil Term)
CIVIL ACTION - LAW
IN DIVORCE
v.
RICHARD D. WILSON,
Defendant
CERTIFICATE OF SERVICE
I, John F. King, Esquire, hereby certify that on July 6,2006, I served a copy of
the within Petition for Contempt for Defendant's Failure to Comply with the Marital
Settlement Agreement Entered of Record, by depositing same in the United States Mail, first
class, postage prepaid, addressed as folIows:
Mr. Richard D. Wilson
18 E. Lisburn Rd., Suite 201
Mechanicsburg, PAl 7055
FRIEDMAN & KING, P.C.
Jo
6 N. Second Street
Penthouse Suite
P. O. Box 984
Harrisburg, PA 17108
(71 7) 236-8000
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RE C E IV ED JUL 11 ?OG5y
MOLLY H. WILSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-5089 (Civil Term)
CIVIL ACTION - LAW
IN DIVORCE
v.
RICHARD D. WILSON,
Defendant
ORDER
AND NOW, this 13 It day of J vI '1
, 2006, Upon consideration of
Petitioner's Petition for Contempt for Defendant's Failure to Comply with the Marital
Settlement Agreement Entered of Record, it is hereby ORDERED that a hearing is scheduled
to be heard before -4 ..I/d~d, ~d r.v , in Court Room -L of
the Cumberland County Courthouse, I Courthouse Square, Carlisle, PA 17013, at
j:3o ;.m. on the
4ti day of ~dA ,
,2006.
BY THE COURT:
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MOLLY H. WILSON,
Plaintiff
: IN THE COURT OF COMMON
: PLEAS CUMBERLAND COUNTY,
PENNSYLVANIA
v.
NO. 05-5089 (Civil Tenn)
RICHARD D. WILSON,
Defendant
CIVIL ACTION - LAW IN
DIVORCE
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance in the above-captioned matter as counsel on
behalf of the Defendant, Richard D. Wilson.
Respectfully submitted,
By:
~
Katherine A. Procopio
Attorney J.D. No. 94756
141 East Main Street
Mechanicsburg, PA 17055
717-691-9112
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Dated: July 31,2006
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MOLLY H. WILSON
Plaintiff
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CIVIL AcrION - LAW
v
sow;
NO. 05 Qg89 (Civil Term)
RICHARD D. WILSON
Defendant
IN DIVORCE
CERTIFICATE OF SERVICE
I hereby certifY that on July 31,2006 I deposited in the U. S. mail, pursuant to Pa. R.C.P
1920.4 and 1930.4 one copy for delivery by certified mail, return receipt requested, and hereto
attached, and one copy for delivery by regular mail, true and correct copies of the foregoing
Praecipe for Entry of Appearance upon the person indicated below.
John F. King
600 North 2111.I Street, 5th Floor
PO Box 984
Harrisburg, P A 17108
Date:~
therine Procopio, Esquire
Attorney J.D. No. 94756
141 East Main Street
Mechanicsburg, P A 17055
717-691-9112
Attorney for Defendant
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MOLLY H. WILSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 05-5089 CIVIL TER~1
RICHARD D. WILSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
ORDER OF COURT
AND NOW, this 4th day of October, 2006, upon
consideration of Plaintiff's Petition for Contempt for Defendant's
Failure To Comply with the Marital Settlement Agreement Entered of
Record, and following a hearing held on October 4, 2006, the
Defendant is adjudicated in contempt, and the sanction of the Court
is that the Defendant undergo imprisonment in the Cumberland County
Prison for a period of 6 months. The conditions of purge with
respect to this sentence are as follows:
1. That Defendant pay the sums of $480.14 and
$1,115.40 to Plaintiff as reimbursement for lost interest and
attorney's fees occasioned by Defendant's violation of the order
herein within 45 days of today's date, subject to a credit of
$798.50; and
2. That Defendant secure the removal of Plaintiff as
an obligor or guarantor on certain debts to PNC Bank in the
approximate total amount of $52,000, and the removal of the marital
residence as security for said debts within 55 days of today's
date.
In the event that Defendant has not timely complied
with both of these conditions of purge, he shall appear in
Courtroom No.1, Cumberland County Courthouse, Carlisle,
Pennsylvania, on Tuesday, December 12, 2006, at 9:30 a.m. for
commitment of sentence.
The conditions of purge provided for herein above
shall continue in full force and effect during any period of
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imprisonment, and compliance therewith shall result in Defendant's
release.
~n J. King, Esquire
600 North Second Street
Penthouse Suite
P.O. Box 984
Harrisburg, PA 17108
For the Plaintiff
~therine Procopio, Esquire
141 East Main Street
Mechanicsburg, PA 17055 ~
For the Defendant
pcb
By the Court,
tV'? 6/1
ley Oler, J ., J.
MOLLY H. WILSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 05-5089 CIVIL TERM
RICHARD D. WILSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
MOTION FOR ORDER TO PURGE CONTEMPT
Defendant, by and through the undersigned counsel, hereby moves this Court to purge the
Order of this Honorable Court dated October 4, 2006 and avers as follows:
1. The movant is the Defendant, Richard D. Wilson, represented by Katherine A.
Procopio, Esquire.
2. The respondent is the Plaintiff, Molly H. Wilson, represented by John J. King.
3. A contempt Petition was filed by Plaintiff on July 13,2006.
4. A hearing was held and an Order issued, a copy of which is hereto attached as Exhibit
"A."
5. The Parties have stipulated to certain facts and beliefs in a Stipulation Agreement
dated December 7,2006, a copy of which is hereto attached as Exhibit "B."
6. Counsel for the Plaintiffhas reviewed the complete contents of this Motion and has
further affirmed that the Plaintiff concurs with this Motion.
WHEREFORE, Defendant respectfully requests this Honorable Court to order that
Defendant has purged himself of the Contempt found by this Court in its Order dated October 4,
2006, and to further order that the Defendant is relieved of his obligation to appear for
sentencing on December 12,2006 at 9:30 am.
,
Respectfully Submitted,
~kflI
Katherine Procopio, Esquire
P A Attorney ID No. 94756
5247 Simpson Ferry Road
Mechanicsburg, P A 17050
717-766-8169
For the Defendant
~
Exhibit A
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-5089 CIVIL TERM
MOLLY H. WILSON,
Plaintiff
RICHARD D. WILSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
ORDER OF COURT
AND NOW, this 4th day of October, 2006, upon
consideration of Plaintiff's Petition for Contempt for Defendant's
Failure To Comply with the Marital Settlement Agreement Entered of
Record, and following a hearing held on October 4, 2006, the
Defendant is adjudicated in contempt, and the sanction of the Court
is that the Defendant undergo imprisonment in the Cumberland County
Prison for a period of 6 months. The conditions of purge with
respect to this sentence are as follows:
1. That Defendant pay the sums of $480.14 and
$1,115.40 to Plaintiff as reimbursement for lost interest and
attorney's fees occasioned by Defendant's violation of the order
herein within 45 days of today's date, subject to a credit of
$798.50; and
2. That Defendant secure the removal of Plaintiff as
an obligor or guarantor on certain debts to PNC Bank in the
approximate total amount of $52,000, and the removal of the marital
residence as security for said debts within 55 days of today's
date.
In the event that Defendant has not timely complied
with both of these conditions of purge, he shall appear lO
Courtroom No.1, Cumberland County Courthouse, Carlisle,
Pennsylvania, on Tuesday, December 12,1 2006, at 9:30 a.m. for
commitment of sentence.
The conditions of purge provided for herein above
shall continue in full force and effect during any period of
,.
release.
imprisonment, and compliance therewith shall result in Defendant's
John J. King, Esquire
600 North Second Street
Penthouse Suite
P.O. Box 984
Harrisburg, PA 17108
For the Plaintiff
Katherine Procopio, Esquire
141 East Main Street
Mechanicsburg, PA 17055
For the Defendant
pcb
By the Court,
(V';7 (j I{
ley Oler, J 'f J.
~ ~r:ORD
:J my hand
..If\ .,;;:sle, Pa.
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Exhibit B
MOLLY H. WILSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 05-5089 CIVIL TERM
RICHARD D. WILSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
STIPULATION AGREEMENT
AND NOW, this 7th day of December, 2006, certain
actions having been taken by the Defendant, Richard D. Wilson
pursuant to the Order of this Honorable Court dated October 4,
2006, the above-named parties, by and through their legal
counsel, Katherine A. Procopio, Esq. for Defendant and John F.
King, Esq. for Plaintiff, do hereby agree as follows:
1. Defendant paid the sum of $480.14 and $1,115.40,
subject to a credit of $798.50 on November 13, 2006
via check made out to Friedman and King, PC; and
2. Defendant secured the removal of the Plaintiff as an
obligor or guarantor on certain debts to PNC Bank in
the approximate total amount of $52,000, and secured
the removal of the marital residence as security for
said debts as evidenced by facsimile from PNC Bank
dated November 24, 2006, which is attached hereto as
Exhibit A.
The parties hereby further agree, by and through their
respective legal counsel, that no other actions are required to
be taken by the Defendant, Richard D. Wilson, to satisfy the
issues raised by Plaintiff in the above-referenced Contempt
"
action initiated by Plaintiff. The parties further agree, by
and through their respective legal counsel, that no other
actions are required to be taken by the Defendant to allow for a
ruling from this Honorable Court that the Defendant has purged
himself of the Contempt previously ruled by this Honorable
Court.
WHEREFORE, Defendant by and through his legal counsel,
respectfully requests this Honorable Court to order that
Defendant has purged himself of the Contempt found by this Court
in its Order dated October 4, 2006, and further to order that
the Defendant is relieved of his obligation to appear for
sentencing on Dec. 12, 2006 at 9:30 am.
Signe
Signed: lifMJJ
~
John J. King, Esq.
600 North Second Street
Penthouse Suite
P.O. Box 984
Harrisburg, PA / Q 01
Attorney 1D: C?' { l L l
Attorney for the Plaintiff
Katherine A. Procopio, Esq.
5247 Simpson Ferry Road
Mechanicsburg, PA 17050
Attorney 10: 94756
Attorney for the Defendant
.........,I,jUI'J
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Exhibit A
0PNCBANK
Novembcr 24,2006
Telkore fne
5247 Simpson Ferry Road
Mechallicsburg, P A 17055
Re: Loan #32104269/602391318,602363515
267 Hlltcrest Road, Camp H111, P A
Dear Sir:
This loan is paid and cancelled and cannot be drawn upon:
PNC Bank, NA is in the process of releasing the following collateral:
Business AsselS and a mortgage dated July 31,2004 i/a/o $35,000_00 rectFded August
16,2004 ill Cumberland County in Mortgage book 1 '1.77 Page 2018.
A mortgage dated July 31,20041/3/0 $28,000.00 recorded August 16,2004 in
Cumberland county in Mortgage Bt)ok 1877 Page 2026.
If you have any question~, please do not hesitate to contacl me at (215) 74 )-6886.
Sincerely,
...J.{' ',,4 ,
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Denise W orek
Collateral Specialist
M~mbcr 01 Till! PNC Financial Services Group
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MOLLYH. WILSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DEe 1 1 20DV
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v.
NO. 05-5089 CIVIL TERM
RICHARD D. WILSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
ORDER
AND NOW, this ~ay of D,. L
, 2006 upon consideration of
Defendants Motion for Order to Purge Contempt, it is hereby ORDERED that Defendant is
purged of the Contempt found by this Court in its Order dated October 4th 2006, and further,
Defendant is relieved of his obligation to appear for sentencing on Dee 12,2006 at 9:30am.
BY THE COURT:
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Katherine A. Procopio, Esquire
141 East Main Street
Mechanicsburg, PA 17055
(717) 645-0718
k orocopio@comcast.net
IN THiE COURT OF COMMON PLEAS OF
CUMBERLAND, PENNSYLVANIA
MOLLY WILSON,
Plaintiff
No. 05-5089
v.
CIVIL ACTION - LA W
RICHARD WILSON,
Defendant
(In Divorce)
~CIPE TO WITHDRAW APPEARANCE
TO THE PROTHONOTARY:
Kindly withdraw the ~ppearance of Katherine A. Procopio, Esquire, on behalf of the
Defendant, Richard Wilson, in the above-captioned matter.
Date: 3/!:407 By: ~"__
, , Katherine A. Procopio, Esquire )
Supreme Court J.D. #94756
141 East Main Street
Mechanicsburg, Pennsylvania 17109
(717) 645-0178
~CIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter the appe*ance of Daley Zucker Meilton Miner & Gingrich, LLC and
Quintina M. Laudermilch, Esquire, on behalf of the Defendant, Richard Wilson, in the above-
captioned matter.
Date: 3/,J/fY7
I
By:
DALEY ZUCKER MEILTON
MINER & GINGRICH, LLC
,,,.....,
~/I~;~
Q mtma M. Laudermllch, EsqUIre
Supreme Court J.D. #94664
1029 Scenery Drive
Harrisburg, Pennsylvania 17109
(717) 657-4795
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CERTIFICATE OF SERVICE
I, Katherine A. Procopio, Esquire hereby certify that on this R day of
fmrch
, 2007, I served a true and correct copy of the foregoing Praecipe to
Withdraw Appearance/PraeciJjle for Entry of Appearance by U.S. First Class Mail, postage pre-
paid, addressed as follows:
John F. King Esquire
FRIEDMAN & KING, P.c.
600 N. Second St., 5th Floor
Harrisburg, Pennsylvania 17101
Attorney for Plaintiff
/tf!!A '
a erine A. Procopio, Esquire
Supreme Court J.D. #94756
141 East Main Street
Mechanicsburg, P A 17055
(717) 645-0178
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FILED-OFFICE
CIF TE1E P R 0 T H0 4C TA, R
Quintina M. Laudermilch, Esquire f;
DALEY ZUCKER MEILTON 'N 1i t JUL 27 AM : 1
MINER & GINGRICH
635 N. 12TH Street, suite 101 CUMBERL NO C JJIIT%'
Lemoyne, PA 17043 E N iN j `f LVAA I A
(717) 724-9821
t1audermiIch@dzmm€1aw.corn
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MOLLY H. WILSON,
Plaintiff No. 2005-5089
V.
CIVIL ACTION - LAW
RICHARD D. WILSON, (In Custody)
Defendant
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Petition and Notice are
served, be entering a written appearance personally or by attorney and filing in writing with the
court your defenses or objections to the claims set forth against you. You are warned that if you
fail to do so the case may proceed without you and a judgment may be entered against you by the
court without further notice for any money claimed in the Petition or for any other claim or relief
requested by the Petitioner. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
0,rv?_k%7 ().W fA
(z61 ?(o ?1 37 S
NOTICIA
Le han demando a usted en la corte. Si usted quiere defenderse de estas demandas
expuestas en las paginas siguientes, usted tiene (20) dias de plazo al partir de la fecha de la
demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por
abogado y archiver en la corte en forma escrita sus defensas o sus objeciones a las demandas en
contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas u puede
entrar una orden contra usted sin previo aviso o notificacion y por cualguir queja o alivio que es
pedido en la peticion de demanda. Usted puede perder dinero o sus propiendades o otros
derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE
ABOGADO 0 SI NO TIENE EL DINERO SOFICIENTE DE PAGAR TAL SERVICO, VAYA
EN PERSONAL 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGAUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
Respectfully submitted,
DALEY ZUCKER WILTON
MINER & GINGRICH, LLC
Date:
Wintina M. Laudermilch, Esquire
Attorney I.D. No. 94664
635 N. 12th Street, Suite 101
Lemoyne, PA 17043
(717) 724-9821
Quintina M. Laudermilch, Esquire
DALEY ZUCKER MEILTON
MINER & GINGRICH
635 N. 12TH Street, Suite 101
Lemoyne, PA 17043
(717) 724-9821
tlaudermilch(adzmmelaw com
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MOLLY H. WILSON,
Plaintiff
V.
RICHARD D. WILSON,
Defendant
No. 2005-5089
CIVIL ACTION - LAW
(In Custody)
PETITION TO MODIFY CUSTODY
AND NOW, comes the Defendant, Richard D. Wilson, by and through his counsel and
files the following Petition to Modify custody and in support thereof avers as follows:
The Plaintiff, Molly H. Wilson, is an adult individual who currently resides at 267
Hillcrest Road, Camp Hill, Cumberland County, Pennsylvania, 17011 (hereinafter "Mother").
2. The Defendant, Richard D. Wilson, is an adult individual who currently resides at
665 Woodburne Road, Lewisberry, York County, Pennsylvania, 17339 (hereinafter "Father").
3. The parties are the parents of three minor children, namely Logan A. Wilson, born
December 11, 1995 (15 years old), Connor R. Wilson, born July 13, 1997 (14 years old), and
Peyton C. Wilson, born December 20, 2002 (8 years old).
4. The terms of the parties' current custodial arrangement are outlined in a custody
Order entered by the Honorable J. Welsey Oler, Jr. dated November 18, 2005. A copy of the
Order is attached hereto as Exhibit "A" and incorporated by reference.
5. Pursuant to the current custody Order, the parties share legal custody of Logan,
Connor and Peyton and Mother has primary physical custody with Father having periods of
physical custody by mutual agreement of the parties.
6. Since the entry of the Order, there has been no consistent custodial schedule and
Father's physical custody of the children has been limited by Mother to one day per week, as
long as Mother's schedule allows for the visit.
7. Mother has not allowed the children to spend any overnight time with their Father
and she has not allowed Father to have physical custody of the children on holidays or for
vacations.
8. Father is required by Mother to provide all of the transportation for any visits that
he may have with the children.
9. Although the parties' share legal custody of the children pursuant to the current
order, Mother fails to provide Father with any information regarding the children's activities,
school or medical appointments.
10. Father is seeking to maintain shared legal custody of the children and to establish
a regular, consistent custodial schedule, which will allow him to have overnight visits, vacations
and to establish a regular schedule for holidays.
11. Father is also requesting that the transportations for any visits be shared by the
parties.
12. The best interest and permanent welfare of the children will be served by granting
the relief requested because:
a. Father has a strong and loving bond with the children;
b. Father believes the children will benefit from spending time with their Father
on a regular and consistent basis; and
c. Father does not believe that Mother fosters or encourages the relationship
between the children and their Father.
WHEREFORE, Defendant respectfully requests that this Honorable Court enter an Order
granting Father partial physical custody of the children on a schedule consistent with the best
interest of the child.
Respectfully submitted,
DALEY ZUCKER MEILTON
MINER & GINGRICH, LLC
Date: °? i / By:L ?c
1.
Q G- a- M. Laudermilch, Esquire
Attorney I.D. No. 94664
635 N. 12th Street, Suite 101
Lemoyne, PA 17043
(717) 724-9821
Attorneys for Defendant
VERIFICATION
I, Richard D. Wilson, verify that the statements made in this Petition to Modify Custody
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-V • I ?'"` AO LCD ?
Richard D. Wilson, Defendant
Exhibit "A"
MOLLY H. WILSON,
Plaintiff
Nov ?.._ m._.. M ).pry _._....,_,
IN THE COURT OF ash""^?^I PLEA „r-!
CUMBERLAND COUNTY, PENNSYLVANIA
V.
RICHARD D. WILSON,
Defendant
ORDER OF COURT
NO. 05-5089 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
AND NOW, this J Ph day of November, 2005, upon consideration of the
attached Custody Conciliation Summary Report, it is hereby ordered and directed as
follows:
1. Legal Custody. Molly H. Wilson and Richard D. Wilson shall have shared
legal custody of the minor children, Logan A. Wilson, born December 11, 1995; Connor R.
Wilson, born July 13, 1997; and Peyton C. Wilson, born December 20, 2002. Each parent
shall have an equal right, to be exercised jointly with the other parent, to make all major
non-emergency decisions affecting the children's general well-being including, but not
limited to, all decisions regarding their health, education and religion. Pursuant to the terms
of 23 Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining
to the children including, but not limited to, medical, dental, religious or school records, the
residence address of the children and of the other parent. To the extent one parent has
possession of any such records or information, that parent shall be required to share the
same, or copies thereof, with the other parent within such reasonable time as to make the
records and information of reasonable use to the other parent.
2. Physical Custody. Mother shall have primary physical custody subject to
Father's rights of partial custody which shall be arranged by the mutual agreement of the
parties with the appropriate flexibility in consideration of Father's traveling schedule for
work.
Dist:
John F. King, Esquire, P.O. Box 984, Harrisburg, PA 17108
Richard D. Wilson, 18 East Lisburn Road, Mechanicsburg, PA 17055
CERTIFICATE OF SERVICE
I, Tonya S. Daugherty, hereby certify that on this day of
2011, a true and correct copy of the foregoing Petition was placed in the United States Mail,
Postage pre-paid, addressed as follows:
John F. King, Esquire
4076 Market Street
Camp Hill, PA 17011
Attorney for Plaintiff
Tonya S. D kghtery
MOLLY H. WILSON
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
r-,
V. 2005-5089 CIVIL ACTION LAW'
RICHARD D. WILSON rn
IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Tuesday, August 09, 2011 upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator,
at_ _ 4th Floor, Cumberland County Courthouse, Carlisle on _ Wednesday, August 24, 2011 at 8:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: _ /s/ Hubert X. Gilro Es q.
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
With Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
mist be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
, Carlisle, Pennsylvania 17013
16?4 Cor M'q1IB/ %U A 7 1?Telephone (717) 249-3166
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Quintina M. Laudermilch, Esquire J l a
t D ~ ~ 0 T;; I ; DALEY ZUCKER MEILTON
MINER & GINC3RICH L ~
635 N. 12T'-' Street, Suite 101
Lemoyne, PA 17043 ? C,~ ~r~~~i~,~
('717) 724-9821
tiaudermilch@dznunglaw.com
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MOLLY H. WILSON, :
Plaintiff : No.2005-5089
v. : CIVIL ACTION - LAW
RICHARD D. WILSON, . (In Custody)
Defendant :
STIPtiLATION AND AGREEMENT FOR CUSTODY
THIS STIPULATION AND AGREEMENT FOR CUSTODY is entered into this
day of _ , 2011, by and between Richard D. Wilson (hereinafter referred to
as "Father") and Molly H. Wilson (herein after referred to as "Mother").
1. It is the intention of the parties and the parties agree that they will have shared legal
custody of their children, Logan A. Wilson, born December 11, 1995, Connor R. Wilson, born
July 13, 1997, and Peyton C. Wilson, born December 20, 2002. The parties agree that major
decisions concerning the children, including, but not limited to, the child's health, welfare,
education, religious training and upbringing shall be made by them jointly, after discussion and
consultation with each other, with a view toward obtaining and following a harmonious policy in
the children's best interest. Each party agrees not to impair the other party's rights to shared legal
custody of the children. Each party agrees not to attempt to alienate the affections of the children
from the other party. Each party shall notify the other of any activity or circumstance concerning
their children that could reasonably be expected to be of concern to the other. Day to day decisions
shall be the responsibility of the party then having physical custody. With regard to any emergency
decisions which must be made, the party having physical custody of the children at the time of the
emergency shall be permitted to make any immediate decisions necessitated thereby. However, that
party shall inform the other of the emergency and consult with him or her as soon as possible. Each
party shall be entitled to complete and full information from any doctor, dentist, teacher,
professional or authority and to have copies of any reports given to either party as a parent pursuant
to 23 Pa.C.S. §5309. Further, the parties specifically agree that they shall notify the other pazent
prior to any scheduled medical, dental or vision appointment to allow the other parent the
opportunity to attend and/or participate in said appointment.
2. The parties agree that Mother shall have primary physical custody of the children.
3. Father shall have physical custody of the children on alternating weekends from
Friday at 5:00 p.m. until Sunday evening at 5:00 p.m. In the event the children are off from school
on a Friday preceding Father's weekend or a Monday following Father's weekend, that time shall
attach to Father's weekend such that the weekend will begin either Thursday at 5:00 p.m., and/or
end Monday evening at 5:00 p.m. Father's altemating weekends will begin with Father having
physical custody of the children the weekend of November 18, 2011
4. The parties are entitled to take up to one (1) week of uninterrupted vacation with the
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children. A week is defined as seven (7) da s and sha11 include the arties' re lar cu t'
Y p gu s odial
weekend. Each party shall provide the other with thiriy (30) days' advance notice of his/her
intention to exercise the extended custody period. In the event a parties' intended vacation will
occur during the school yeaz and require the children to be absent from school, the parties agree that
they shall follow the regulations established by Cumberland Va11ey School District regarding
educational trips; the parties shall minimize the number of absences of the children from school; and
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the parties sha11 review any specific academic problems being exhibited by the children prior to
making a decision to allow an absence from school for vacation/educational trip.
5. The parties agree that the holiday schedule shall be as follows:
A. The parties agree to alternate having physical custody of the children on the
following holidays: Easter, Memorial Day, 0' of July, Labor Day and Thanksgiving. Father shall
have physical custody of the children on Easter, 4`h of July and Thanksgiving in odd nuxnbered
years and Memorial Day and Labor Day in even numbered years. Mother sha11 have physical
custody of the children on Easter, 4t' of July and Thanksgiving in even numbered years and
Memorial Day and Labor Day in odd numbered years. Holiday shall be defined as starting at 9:00
a.m. the morning of the holiday, and ending at 5:00 p.m. on the evening of the holiday, except that
the holiday period for 4t' of July shall begin at 9:00 a.m. the morning of the holiday and end after
fireworks the evening of the holiday, but no later than 11:00 p.m. In the event a party's scheduled
Holiday period fa11s on the Friday preceding the party's regular weekend or a Monday following the
party's regular weekend, that Holiday time shall attach to the party's weekend such that the
weekend will begin either Thursday at 5:00 p.m., and/or end Monday evening at 5:00 p.m.
B. Mother shall have physical custody of the children every yeaz beginning
Christmas Eve at 2:00 p.m. until Christmas Day at 2:00 p.m. and Father sha11 have physical custody
of the children every year beginning Christmas Day at 2:00 p.m. until December 26t' at 2:00 p.m.
C. Father shall have physical custody of the children on Father's Day and
' Mother shall have physical custody of the children on Mother's DaY, which daYs shall be defined as
starting at 9:00 a.m. on the morning of the holiday, and ending at 5:00 p.m. in the evening of the
holiday.
6. The holiday schedule sha11 take precedence over the regular custody schedule.
7. Unless otherwise agreed to by the parties, the party receiving custody of the children
shall provide transportation for the exchange.
8. The parties agree that the children will not be permitted to sleep in a room in which
either pazent and an unrelated third party adult are also sleeping.
9. Both parties agree that they are relying on the custodial schedule set forth herein and
they expect the schedule to be followed by the other party. However, the parties acknowledge that,
from time to time, slight adjustments or modifications may be requested by the other party. The
parties agree to work together to reasonably attempt to accommodate said requests. In the event
either party needs to request a temporary modification to the schedule, or to request to switch
weekends with the other parent, that party shall contact the other party as soon as possible prior to
the requested change, so they can discuss the request and determine whether alternate atrangements
can be made. In the event either party will be delayed in arriving for a custodial exchange, the
delayed party shall immediately contact the other party to advise of the delay. In the event the delay
is less than 1 hour, the custodial period sha11 begin when the delayed party arrives. In the event the
delay is more than 1 hour, and said delay is caused by factors totally beyond the control of the
delayed pariy (i.e. flight delays caused by weather, or other acts of God), the parties shall
communicate to try and make alternate arrangements for the exchange, which alternate
, arrangements sha11 not be unreasonably denied. Failures to exercise custodY, for reasons other than
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the foregomg, shall be considered to be violations of the Agreement/Court Order. In the event an
entire period of visitation is missed for a reason beyond the control of the receiving party (i.e. flight
delays caused by weather, acts of God, etc.), the parent who missed said visitation shall be allowed
a makeup period, which period sha11 be determined by agreement with the other party, and which
shall be exercised within three (3) months of the missed period. Should a party miss more than one
(1) such period in any given six (6) month period, for a reason beyond the control of the receiving
party (i.e. flight delays caused by weather, acts of God, etc.), then all such additional periods sha11
not be subject to makeup, but rather shall be forfeited. Under no circumstance shall a period of
visitation missed for a reason other than one beyond the control of the receiving party, as defined
herein, be subject to makeup, but rather shall be a violation of the AgreementJOrder.
10. During any period of custody or visitation, the parties sha11 not possess or use
controlled substances or consume alcoholic bevera.ges to the point of intoxication. The parties shall
likewise assure, to the extent possible, that other household members and/or houseguests comply
with this prohibition.
11. Each party shall be required to inform the other party of the nature and quantity of
any firearms in the possession of the other. During any period of custody or visitation, the parties
sha11 secure, outside of the access of the children, all said firearms.
12. Neither party will smoke cigarettes or tobacco products nor allow others to smoke in
the presence of the children.
13. Each pariy shall be entitled to reasonable telephone or e-mail contact with the
children when they are in the custody of the other party. The parties shall provide to one another an
emergency contact telephone number, e-mail address or contact person.
14. Pursuant to 23 Pa.C.S. §5337, neither party shall relocate from a current address if
such relocation will necessitate a change in the custody schedule as set forth in this Order. In the
event of any intended relocation, all requirements outlined in 23 Pa.C.S. §5337 regarding
Relocation must be adhered to by the parties.
15. The parties shall refrain from making derogatory comments about the other party in
the presence of the children and to the extent possible shall prevent third parties from making such
comments in the presence of the children.
16. Should either party have the children spend overnight at a place other than their
primary residence, the other party will be given the address and telephone number where the
children are spending the night.
17. The parties hereby agree to minimize interference with the children's regularly
scheduled activities as much as possible
a. The parents shall organize ways for their child(ren) to maintain their
friendships, extracurricular activities, and other special interests, regardless of
which household they may reside.
b. Each parent shall provide the other with at least forty-eight (48)
hours advance notice of school or other activities and two weeks' notice whenever
possible.
c. Both parents shall honor and be supportive of the extracurricular
activities the child(ren) wishes to engage in.
d. Each parent shall confer with the other before arranging regularly
occurring extracurricular activities for their child(ren) which might interfere with
regular visitation.
e. During the times that the parents have physical custodial
responsibilities of their child(ren), each parent will make certain that the child(ren)
attends their extracurricular activities and transport the child(ren) on time to and
from games, practices and any activities that are scheduled so that they are able to
participate in those events.
18. The parties agree to organize ways for their children to maintain their friendships,
, extracurricular activities and other s ecial interests re ardless of which hou
P ~ S sehold they may be in.
It is also suggested that toys, clothing, etc. not become matters of contention.
19. It is understood and stipulated by the parties that upon mutual agreement an
expanded or altered schedule may be agreed upon between the parties and that such agreement
would be in the best interests of the children. In the absence of mutual agreement, the terms of
this Agreement shall control.
IN WITNESS THEREOF, intending to be legally bound, the parties have hereto set their
hands and seals on the day and year first written above.
Witness:
1
GL~G/ `,~~--p~l/• &-)e.Ld.ex
Richard D. Wilson
{ Molly H. Wilson
it
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MOLLY H. WILSON,
Plaintiff No. 2005-5089
C= ,
V. CIVIL ACTION - LAW
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RICHARD D. WILSON, (In Custody)
Defendant r, :X <-> -F
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ORDER
AND NOW, this ! ?Y' day of 2011, upon consideration of
the attached Stipulation and Agreement for Custody executed by the parties, it is hereby
ORDERED AND DECREED that said Stipulation is APPROVED and that its terms are hereby
ADOPTED as an Order of Court.
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RV TNF. C01TRT-
MOLLY H. WILSON IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
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2005-5089 CIVIL ACTION LAW
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RICHARD D. WILSON IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Wednesday, February 20, 2013 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator,
Thursday, March 21, 2013 10:30 AM
at 4th Floor, Cumberland County Courthouse, Carlisle on
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute-, or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/ Hubert X. Gilroy, Esq. ,??
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the
scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
o (' ? , ?
O C? 11-0 44, ?s9 .
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MOLLY H. WILSON,
Plaintiff No. 2005-5089 -
vs. CIVIL ACTION - LAW
RICHARD D. WILSON, (In Custody)
Defendant
PRAECIPE TO WITHDRAW APPEARANCE
Please withdraw the appearance of Quintina M. Laudermilch, Esquire of
Daley Zucker Meilton Miner& Gingrich on behalf of Defendant Richard D. Wilson in
the above-captioned action.
Qaintina M. Laudermilch, Esquire
Attorney I.D. 94664
Daley Zucker Meiltou Miner&Gingrich
635 N. 1211, Street, Suite 101
Lemoyne, PA 17043
(717) 724-9821
Dated: ��'//_P
PRAECIPE TO ENTER APPEARANCE
Please enter the appearance of Lynnore K. Seaton of Ream, Carr, Markey&
Woloshin LLP on behalf of Defendant Richard D. Wilson.
Lynnore K. Seaton
Attorney I.D. 210241
Ream, Carr, Markey&Woloshin LLP
119 E. Market Street
York, PA 17401
(717) 843-8968
Dated: u3 ��
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MOLLY' H. WILSON,
Plaintiff No. 2005-5089
Vs. CIVIL ACTION - LAW
R.ICHAR.D D. WILSON (In ('ustody)
Defendant
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on this date a true and correct copy of
the foregoing documents was served by first-class mail, postage prepaid upon the
following:
John F. King
John F. King Law, P.C.
4076 Market Street, ;Suite 1
Camp Hill, PA 17011
w
Lynnore K. Seaton, Esquire
Dated:
4 �^
lit-
3 MAR 27 fall 11 6
CJIMDERLfr NO COUNTY
FCNINSYLVAN1A
REAM, CARR, MARKEY& WOLOSHIN LLP
Lynnore K. Seaton, Esquire
119 E. Market Street
York, PA 17401
(717) 843-8968 FAX(877) 777-3923
lseatonlaw @gmail.com
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLVANIA
MOLLY H. WILSON,
Plaintiff No. 2005-5089
vs. CIVIL ACTION - LAW
RICHARD D. WILSON (In Custody)
Defendant
ANSWER TO MOTION FOR CONTEMPT FOR DISOBEDIENCE OF A
CUSTOY ORDER PURSUANT TO Pa.R.C.P 1915.12
AND NEW MATTER
AND NOW COMES the Respondent Richard D. Wilson, by and through his
attorneys, Ream, Carr, Markey & Woloshin LLP, hereby moves this Honorable Court for
a continuance and avers as follows:
1. Admitted.
2. Admitted.
3. Admitted.
4. Denied. Judge J. Wesley Oler,Jr. entered the most recent Custody Order on
November 18, 2011. By way of further answer,this was a modification of a prior
Custody Order dated November 18, 2005.
5. Denied. Father did not"willfully"fail to abide by the Order.
A. Admitted.
B. Admitted.
C. Admitted in part, denied in part. While it is admitted that these events
were scheduled, Father thought they were cancelled due to Mother's email
communication. Furthermore, Connor(who is 15 years old) did not mention
these activities to Father during the said weekend.
D. Denied. This one time inadvertent act did not interfere with Connor's
ability to participate in baseball. This is evidenced by the fact that Connor is
currently playing on both the Carmen Fusco team and the Cumberland Valley
High School team.
E. Admitted.
F. Admitted.
G. Admitted. By way of further answer, Mother's email included an
extensive list of activities for all the children. Mother consistently fails to obtain
Father's agreement prior to scheduling activities, as addressed below. This email
communication was indicative of this type of behavior. It included scheduling
new activities of the children during Father's time.
H. Admitted. By way of further answer, Father admits this can be
misconstrued; however, it was written in frustration due to Mother's violation of
the Custody Order. Father subsequently supported the activities in Mother's
email, despite the lack of his prior approval of some of the activities.
I. Denied. Some of the activities are new activities for both Logan and
Connor.
6. (Another Number 4 on Plaintiff s Motion.) Neither admitted nor denied. By
way of further answer, Mother is complaining of one event that was due to an error rather
than a course of conduct. Mother would not have incurred any fees had she simply
communicated with Father rather than filing a Motion for Contempt the first time she was
able to identify a harmless error.
FIRST NEW MATTER
COUNTERCLAIM FOR PLAINTIFF'S CONTEMPT
7. Paragraphs One through Six of the Answer are incorporated by
reference as if fully set forth herein.
8. The Custody Order granted the parties shared legal custody,
requiring the parties agree on major decisions regarding the children.
9. Paragraph 17 of the Custody Order specifically states: "Each parent
shall confer with the other before arranging regularly occurring extracurricular activities
for their children which might interfere with regular visitation.
10. Rather than discussing and agreeing to potential activities with
Father, Mother simply informs Father of activities, after the children are already enrolled.
Similarly, Mother allows children to withdraw from activities without agreement from
Father.
11. Paragraph 17 of the Custody Order also states: "Both parents shall
honor and be supportive of the extracurricular activities the child(ren)wishes to engage
in."
12. Mother schedules the children for so many activities that it seems
the children would rather relax while at their Father's home,rather than endure the
myriad of activities. This is evidenced by the fact that Connor did not inform his Father
of the practices that are the subject of Mother's Motion. This indicates that it is Mother
who is selecting the activities based upon her own preference, rather than the preference
of the children.
13. It is believed that Mother has chosen to allow the children to miss
some pre-arranged activities as well. For example, on January 20, Mother told Father
that Peyton was too tired to participate in"Hoop Fest" so he was not going. Father does
not keep track of missed practices, but it is believed that Mother has violated the Order's
requirement that each party"make certain that the children attend extracurricular
activities..."more than Father.
14. Paragraph 9 of the Custody Order states: "[t]he parties
acknowledge that, from time to time, slight adjustments or modifications may be
requested by the other party. The parties agree to work together to reasonably attempt to
accommodate said requests...In the event that delay is more than 1 hour, and said delay is
caused by factors totally beyond the control of the delayed party...the parties shall
communicate to try and make alternate arrangements for the exchange,which alternate
arrangements shall not be unreasonably denied."
15. In May 2012, Father gave Mother timely notice that he was going
to be late for the custodial exchange. It was due to a business meeting,which was a
circumstance beyond his control. Mother threatened that Father had to lose his custodial
time. She refused to allow another responsible adult to pick up the children for the
custodial exchange.
lb. In November 2012 Father was late for a custodial exchange. This
was also due to circumstances beyond his control(due to a flight delay.) Father gave
Mother timely notice of his delay. Mother once again refused to allow Father to arrange
for a responsible adult to pick up the children for his custodial time. She threatened
Father that he had to lose his entire weekend due to this delay.
17. In both events, Mother refused to reasonably accommodate Father
by allowing another responsible adult to pick up the children in lieu of Father. Mother
only allowed the children to go with Father later than scheduled after a considerable
amount of negotiating from Father.
18. Mother continues to refuse to allow Father to designate other
responsible adults to pick up the children for custody exchanges. Meanwhile, she
arranges for friends, neighbors, etc. to drive the children to activities during her custodial
time.
19. Mother was late for the custodial exchange on Christmas Day,
2012. Father accommodated Mother without threatening that she would lose her
custodial time all together.
20. On at least two occasions, Mother was not at her house when
Father arrived on time to pick up the children for his custodial time. Mother did not
previously inform Father she would not be there on time. Instead, Mother informed the
children that they were "not allowed"to go with Father until her return. While Mother's
delay was not excessive, there was no reason given for why the children(including the 17
year old child)were not allowed to leave with Father upon his arrival.
SECOND NEW MATTER
PETITION TO MODIFY CUSTODY
21. Paragraphs One through Twenty of the Answer and New Matter
are incorporated by reference as if fully set forth herein.
22. Based upon the Custody Order, Mother has primary custody of
the children. Father has partial physical custody on alternating weekends from Friday at
5:00 p.m. until Sunday at 5:00 p.m.. If a school holiday falls on Father's weekend,
Father's time includes either the prior Friday or following Monday. Father is also
entitled to one week of uninterrupted vacation time and alternating holidays.
23. Father is seeking additional time with the children, including
alternating weeks over the summer, every extended weekend and every school holiday
that extends beyond extended weekends.
24. Mother reaches out to friends,neighbors,etc. to provide
transportation of the children to and from their activities. Mother refuses to allow Father
to participate in transporting the children during her custodial time. Mother refuses to
reach out to Father first for transportation assistance.
25. Father is generally available to transport the children to and from
their activities during the week. Father would like to be the first contacted when Mother
needs assistance with transportation, so he can spend additional time with his children.
26. The best interest and permanent welfare of the children served by
granting the relief requested because:
a. The children have expressed a desire to spend more time with
Father.
b. Father and the children have a bond that will be strengthened with
additional time spent together.
C. Father's work schedule has adjusted to allow Father more time to
spend with his children than previously.
WHEREFORE,counsel for the Defendant requests that this Honorable Court enter
an Order:
1. Holding Mother in Contempt of Court;
2. Granting Father$750 in Attorney's fees for the cost of preparing and
filing this Petition;
3. Granting Father additional partial physical custody as follows:
a. Alternating weeks during the summer;
b. Every extended weekend created by a school holiday; and
c. Every Spring Break, Thanksgiving Break, Winter Break and any
other school holiday that includes more than just an extended
weekend.
4. Granting Father the Right of First Refusal if the children need
transportation to activities during Mother's custodial time;
5. Any other relief as the Honorable Court deems appropriate.
Respectfully submitted,
Date: Z>-'off �1�-
Lynnore K. Seaton
Attorney ID No. 210241
Ream, Carr, Markey & Woloshin LLP
119 E. Market Street
York, PA 17401
(717) 843-8968
(717) 846-4999 fax
lseatonlaw @gmail.com
Attorneys for Defendant
VERIFICATION
I 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
are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification
to authorities.
...�I►40
Richard D. Wilson
Dated 3—a LO —� 3
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLVANIA
MOLLY H. WILSON,
Plaintiff No. 2005-5089
vs. : CIVIL ACTION - LAW
RICHARD D. WILSON : (In Custody)
Defendant
NOTICE TO DEFEND
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE
CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION
WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED,
BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY
AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO
THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL
TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE
ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY
MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF
REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR
OTHER RIGHTS IMPORTANT TO YOU.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
I
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
1-800-990-9108
717-249-3166
i
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLVANIA
MOLLY H. WILSON, .
Plaintiff No. 2005-5089
vs. CIVIL ACTION - LAW
RICHARD D. WILSON (In Custody)
Defendant
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on this date a true and correct copy of
the foregoing documents was served by facsimile and first-class mail, postage
prepaid upon the following:
John F. King
John F. King Law, P.C.
4076 Market Street,Suite 1
Camp Hill, PA 17011
Y4'2-
Lynno K. Seaton, Esquire
Dated: 3