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Home My WebLink About02-1560DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIANE L. GREENE, Plaintiff V. ROBERT F. GREENE, Defendant : NO. I O Z- O : : CIVIL ACTION - LAW : DIVORCE NOTICE 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 divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIANE L. GREENE, Plaintiff V. ROBERT F. GREENE, Defendant : : CIVIL ACTION - LAW : DIVORCE COMPLAINT AND NOW, this day of , 2002, comes the Plaintiff, DIANE L. GREENE, by attorney, DIANE G. RADCLIFF, ESQUIRE, and files this Complaint in Divorce of which the following is a statement: COUNT I: DIVORCE 1. The Plaintiff is DIANE L. GREENE, an adult individual residing at 12 West Pine Street, Enola, Cumberland County, Pa 17025. 2. The Defendant is ROBERT F. GREENE, an adult individual residing at 312 Eutaw Street, New Cumberland, Cumberland County, PA 17070. 3. Plaintiff and/or Defendant have been bona fide residents of the Commonwealth for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on February 2, 1977 at New Cumberland, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to -2- DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 7 o participate in counseling. The Defendant is not a member of the Armed Services of the United States or any of its Allies. The Plaintiff avers that the grounds on which the action is based are: a. That the marriage is irretrievably broken; Or in the alternative, b. That the parties are now living separate and apart, and at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. Or in the alternative, c. That Defendant has offered such indignities to the person of the Plaintiff, the innocent and injured spouse, as to render condition intolerable and life burdensome, and that this action is not collusive. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. 9 o 10. COUNT II: EOUITABLE DISTRIBUTION Paragraphs 1 through 8 are incorporated by reference hereto as fully as though the same were set forth at length. Plaintiff and Defendant have acquired property and debts, both real and personal, during their marriage from February 2, 1977 until October 6, 2001, the date of separation, all of which are "marital property" or "marital debts". -3- DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 11. Plaintiff and/or Defendant have acquired, prior to the marriage or subsequent thereto, "non-marital property" which has increased in value since the date of marriage and/or subsequent to its acquisition during the marriage, which increase in value is "marital property". 12. Plaintiff and Defendant have been unable to agree as to an equitable division of said property and debts as of the date of the filing of this Complaint. WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital property and debts of the parties. Respectfully submitted, Phone: (717) 737-0100 Fax: (717) 975-0697 -4- DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 VERIFICATION DIANE L. GREENE verifies that the statements made in this Complaint are true and correct. DIANE L. GREENE understands that false statements herein are made subject to the penalties of 18 4904, relating to unsworn falsification to Pa.C.S. Section authorities. DIANE L. GREENE -5- Diane L. Greene 3.26.02. Income and Ex~,ense .Statement IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIANE L. GREENE, Plaintiff ROBERT F. GREENE, Defendant NO. 02- ~ CIVIL TERM CIVIL ACTION - I_~W DIVORCE INCOME AND EXPENSE STATEMENT OF DIANE L GREENE I verify that the facts set forth in the following Income and Expenses Form, including all attachments thereto, are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. DIANE L. GREENE - i - Diane L. Greene 3.26.02. Income and Exp~nse Statement PART I. INCOME MENT INFORMATION: EMPLOYER: PA Department of Transportation ADDRESS: 1101 South Front Street, Harrisburg, PA 17104 POSITION: Clerk 3 PAYROLL NUMBER: 056704 PAY PERIOD: bi-weekly B. EMPLOYMENT INCOME: (BASED ON 2001 W-2 STATEMENT) GROSS PAY PER PAY PERIOD 37,141.81 37,141.81 ITEMIZED DEDUCTIONS FICA OR SE TAX (2,302.84) (2,302.84) MEDICARE OR SE TAX (538.58) (538.58) FEDERAL TAX (4,585.48) (4,585.48) STATE TAX (1,040.07) (1,040.07) LOCAL TAX (312.78) (312.78) MANDATORY RETIREMENT (1,857.09) (1,857.09) UNION DUES (504.66) (504.66) VOLUNTARY RETIREMENT HEALTH INSURANCE MISC DEDUCTION BANKRUPTCY CHAPTER (214.00) 13 PAYMENT MISC. DEDUCTION (specify) : TOTAL DEDUCTIONS (11,355.50) (11,141.50) NET PAY PER YEAR 25,786.31 26,000.31 NET PAY PER MONTH 2,148.86 2,166.69 - 2 - Diane L. Greene 3.26.02. Income and Expense Statement CALCULATION OF DIANE GREEN'S AVERAGE GROSS PAY 1/1/02 to 3/15.02 GROSS 8,584.62 6.00 1,430.77 715.39 3,100.00 37,200.02 FEDERAL TAX (845.42} 6.00 (140.90) (70.45) (305.29) (3,663.49) FICA (532.22) 6.00 (88.70) (44.35) (192.19) (2,306.29) MEDICARE (124.46) 6.00 (20.74) (10.37) (44.94) (539.33) STATE (240.39) 6.00 (40.07) (20.03) (86.81) (1,041.69) LOCAL (85.88) 6.00 (14.31) (7.16) (31.01) (372.15) UNION DUES (118.26) 6.00 (19.71) (9.86) (42.71) (512.46) MANDATORY (536.51) 6.00 (89.42) (44.71) (193.74) (2,324.88) RETIR~.NT NET TOTAL 6,101.48 6.00 1,016.91 508.46 2,203.31 26,439.75 - 3 - Diane L. Greene 3.26.02. Income and Expense Statement INTEREST DIVIDENDS PENSIONS ANNUITIES SOCIAL SECURITY RENTS ROYALTIES EXPENSE ACCOUNT GIFTS UNEMPLOYMENT COMPENSATION WORKMAN' S COMPENSATION INCOME TAX REFUNDS SUPPORT OR ALIMONY COMMI SS IONS TIPS OTHER SPECIFY: TOTAL OTHER INCOME $0 · 00 $0 · 00 - 4 - Diane L. Greene 3.26.02. Income and Exp~nse Statement PART II. EXPENSES DESCRIPTION MONTHLY AMOUNT Rent $200.00 First Mortgage Second Mortgage/Home Equity Loan Maintenance And Repairs Electric Gas oil Telephone $40.00 Water Sewer Trash Public Transportation Lunches $75.00 Other Employment Expenses $50.00 Specify: travel on Penndale for PA D.O.T. Real Estate Taxes Personal Property Taxes Income Taxes Not Withheld $25.83 Per Capita/Occupation Taxes Diane L. Greene 3.26.02. Income and Exp. ense Statement DESCRIPTION MONTHLY AMOUNT Homeowners Insurance Automobile Insurance $175.00 Life Insurance Accident Insurance Health Insurance Other Insurance $75.00 Specify: Long term care insurance Payments $250.00 Fuel $100.00 Maintenance And Repair $50.00 License And Registration $3.00 Doctor $50.00 Optical $25.00 Dental $8.33 Orthodontic Hospital Medicine $15.00 Special Needs/Therapy Etc. Specify: Diane L. Greene 3.26.02. Income and Expense Statement DESCRIPTION MONTHLY AMOUNT Private School Parochial School College/Vocational Religious Training or Education Books/Fees And Supplies Other Educational Expenses Clothing Food Barber And Hair Dresser Memberships $150.00 $250.00 $50.00 $4.50 Household Help Child Care Newspapers/Magazines/Books Entertainment Pay TV Vacations Gifts Legal Fees Charitable Contributions Other Child Support (not the subject of this action) $10.00 $100.00 $100.00 $125.00 $10.00 - 7 Diane L. Greene 3.26.02. Income and Exp~nse Statement DESCRIPTION MONTHLY AMOUNT Other Spousal Support or Alimony (not the subject of this action) $25.0O Garage Rent Storage Unit $87.00 TOTAL EXPENSES $2,053.66 Diane L. Greene 3.26.02. Income and Exp~nse .Statement PART III. PROPERTY OWNED TYPE DESCRIPTION V~LUE H W JT Checking Focus Fifty 200.00 X Savings Credit Union Stocks/bonds Real Estate Other PART IV. INSURANCE TYPE COMPANY POLICY NO. H W C Hospital/Blue X X Cross Medical/Blue X X Shield X X Health Accident Disability Income X X Dental X X Vision Other-Specify *H=Husband; w=Wife; J=Joint; C=Child Diane L. Greene 3.26.02. Income and Exp. ense .Statement PART V. SUPPLEMENTAL INCOME STATEMENT [X] CHECK HERE IF NOT APPLICABLE (a) This form is to be filled out by a person: (1) Who operates a business or practices a profession, or (2) Who is a member of a partnership or joint venture, or (3) Who is a shareholder in and is salaried by a closed corporation or similar entity. (b) Attach to this statement a copy of the following documents relating to the partnership, joint venture, business, profession, corporation or similar entity (check block to indicate the document is attached): (1) The most recent Federal Income Tax Return. [ ] attached (2) The most recent Profit and Loss Statement. [ ] attached (c) (d) Name of Business: Business Address: Business Telephone: (e) (f) Nature of Business (check one) [ ] 1. Sole Proprietorship [ ] 2. Partnership [ ] 3. Joint Venture [ ] 4. Professional [ ] 5. Corporation [ ] 6. Other Name of accountant, controller or other person in charge of financial records: Business Income: 1. Annual income from business: 2. How often is income received: 3. Gross income per pay period 4. Net income per pay period 5. Specify deductions, if any: - 10 - DIANE L. GREENE, Plaintiff ROBERT F. GREENE, Defendant : IN THE cOURT OF coMMON pLEAS OF : cUMBERLAND COUNTY, pENNSYLVANIA : NO. 02-1560 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE I hereby certify that a true and correct copy of the Complaint in Divorce has been served upon the Defendant by Certified Mail, Restricted Delivery on the 13th day of April, 2002. The return receipt for said mailing is attached hereto as Exhibit ~A" and made a part hereof. Respectfully submitted, Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID ~ 32112 Attorney for Plaintiff - 1 ,lo $ q · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired, · print your name and address on the reverse o that we can return the card to you. · ,~tach this card to the back of the mailpiece, or on the front if space permits. '1 Agent address betow: I-I No i'-J Retur~ Receipt for Merchandise Restricted f~li~ry? ~xtra Fee) PS Form 3~] ], JUly m~ EXHIBIT "A" 102595-99-M-1789 Diane L. Greene/4.18.02 Pre-Tr~a] Statement/ revised 5/14/02 DIANE L. GREENE, v. ROBERT F. GREENE, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-1560 CIVIL TERM : : CIVIL ACTION - LAW · IN DIVORCE pT.AINTIFF'S PRE-TRIAL STATEMENT Plaintiff, Diane L. Greene, by her attorney, Diane G. Radcliff, Esquire files this Pre-Trial Statement· TABLE OF CONTENTS I. BACKGROUND INFORMATION 2-3 II. LISTING OF MARITAL ASSETS AND DEBTS 4-11 III. LISTING OF PERSONAL PROPERTY 12-16 IV· LISTING OF MARITAL DEBTS 17-21 V. PENSIONS 22 VI. LISTING OF NON-MARITAL ASSETS AND DEBTS 23 VII. INCOME AND EXPENSE 24-26 VIII. COUNSEL FEES AND COSTS 27 IX. EXPERT WITNESSES 28 X. OTHER WITNESSES 28 XI. PROPOSED RESOLUTION 29 XII. LISTING OF PROPOSED EXHIBITS 30 DATED: Respectfully Submitted, ~IA~E--G~'~TJ=I~, ESQUIRE 34~'~d~e Road Ca~p Hill,3pA _~7011 Ph~rrc~: ,~) 737-0100 Attorney for Plaintiff Diane L. Greene/4.18.02 Pre-T~al Statement/ revised 5/14/02 I. BACKGROUND INFORMATION A. PARTIES: NAME ADDRESS AGE ' DATE OF BIRTH PLACE OF BIRTH 3OCIAL SEC~ITYNUM-B~R HEALTH EMPLOYER OCCUPATION ESTIMATED ANNUAL INCOME LENGTH OF RESIDENCY IN PA EDUCATIONAL BACKGROUND Robert F. Greene 312 Eutaw Street New Cumberland, PA 17070 Diane L. Greene 12 West Pine Street Enola, PA 17025 46 55 December 11, 1954 June 27, 1946 Lexington, KY Harrisburg, PA 207-44-5552 184-38-0275 Alcoholism, depression Good Unemployed PA D.O.T. Master automotive Clerk III mechanic $37,141.41 $36,000.00 per year earning capacity Approximately 14 years All life 11th grade High school graduate Jessica Greene CHILDREN OF THIS MARRIAGE: 2~ Verna Elizabeth Ann Greene Bobbie Sue Greene 20 19 03/05/78 o9/ol/8O 04/28/82 Emancipated Emancipated Emancipated Ce MARRIAGE INFORMATION: February 2, 1977 New Cumberland, PA October 6, 2001 Wife left due to husband's physical and mental abuse and when she discovered husband had sexually abused her daughter from a former marriage. Page 2 Diane L. Greene/4.18.02 Pre-Tr~l Statement/ revised 5/14/02 De PRIOR MARRIAGES: CHILDREN OF OTHER RELATIONSHIPS/MARRIAGES: 2 (both emancipated) 1 (emancipated) F. PROCEEDINGS INFORMATION: Diane L. Greene Robert F. Greene April 2, 2002 April 13, 2002 Certified Mail Restricted Delivery fault divorce; indignities; equitable distribution N/A /A /a N/A N/A N/A Husband filed for spousal support. His claim for support was denied on the basis of non-entitlement. Page 3 Diane L. Greene/4.18.02 Pre-Tr~l Statement/ revised 5/14/02 II. MARITAL ASSETS AND DEBTS ?ING OF THE MARITAL ASSETS AND DEBTS OF THE PARTIES: NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION LIABILITY LIABILITY TO HUSBAND TO WIFE l~~~ ~WGMAC Mortgage Est 1-ANew 312 EutaWcumberland,StreetpA ' (56,000.00) 90,000.00 · NET EQUITY 12,000.00 12,000.00 6,000.00 6,000.00 2-A Husband s 1990 3 25 02 1 780.00 Chevy Astro Van Vehicle ~,oan ~/A 0.0 0 NET VAL~ 1,780.00 1,780.00 1,780.00 2-B Wife and N/A daughter s joint 1997 H~ndai Elantra w~ ~o~ o. o0 NET V~UE 0.00 0.00 0.00 Page 4 Diane L. Greene/4.18.02 Pre-Tr~al Statement/ revised 5/14/02 NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION LIABILITY LIABILITY TO HUSBARD TO WIFE 2-C Husband's 1989 3.25.02 Chevy Blazer Vehicle Loan N/A 0.00 NET VALUE 1,480.00 1,480.00 1,480.00 2-D Husband's Harley 3.1.02 6,160.00 Davidson motorcycle Vehicle Loan N/A 0.00 NET V~UE 6,160.00 6,160.00 6,160.00 2-~ Joint utility TBD trailer 2-F Trailer N/A 0.00 ~ET V~H~ TBD TBD TBD 3-A Joint PSECU 10.5.01 838.73 838.73 838.73 checking account Page 5 Diane L. Greene/4.18.02 Pre-Tr~l Statement/ revised 5/14/02 NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION LIABILITY LIABILITY TO H~SBAND TO WIFE 3-B ~ife' s Waypoint 10.5.01 615.80 615.80 615.80 Bank checking 3-C gife' s Waypoint 9.30.01 1,234.43 1,234.43 1,234.43 Bank Savings account 4-A Wife's SERS To be divided To be divided To be To be Retirement Plan at retirement at retirement divided at divided at retirement retirement 4-B Husband's PSECU Est. 5,000.00 5,000.00 5,000.00 Household Goods 5-B Wife's Household Est. 4,950.00 4,950.00 4,950.00 Goods Page 6 Diane L. Greene/4.18.02 Pre-Tr{~l Statement/ revised 5/14/02 NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION LIABILITY LIABILITY TO HUSBAND TO WIFE 6-A Bank of America Est. (1,678.73) (499.59) 0.00 (499.59) joint credit card 6-B Choice Visa Est. (1,667.00) 0.00 0.00 0.00 3oint credit card 6-C Discover Card Est. (2,682.98) (569.31) 0.00 (569.31) joint credit card 6-D First USA joint Est. (4,413.00) 0.00 0.00 0.00 credit card Page 7 Diane L. Greene/4.18.02 Pre-Tr:al Statement/ revised 5/14/02 NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION LIABILITY LIABILITY TO HUSBAND TO WIFE 6-E Home Depot Est. {1,422.00) 0.00 0.00 0.00 3oint credit card 6-F Providian Est. (1,658.97) (493.71) 0.00 (493.71) joint credit card Page 8 Diane L. Greene/4.18.02 Pre-T~al Statement/ revised 5/14/02 NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION LIABILITY LIABILITY TO HUSBAND TO WIFE 6-J Waypoint Bank Est. (2,809.12) (835.99) 0.00 (835.99) joint credit card : ::::: ::: :: :: : :::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::: 6-~ Resurgent CA Est. (212.18) (63.14) 0.00 (63.14) joint credit card 6-~ ~ ~e ~. ~2~2.00) 0.00 0.00 0.00 joint credit card 6-N Walmart Est. (91.00) (91.00) 0.00 (91.00) joint credit card 6-0 1~ Union National Est. (833.00) 0.00 0.00 0.00 B~nk joint credit card Page 9 Diane L. Greene/4.18.02 Pre-T~:al Statement/ revised 5/14/02 NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION LIABILITY LIABILITY TO HUSBAND TO WIFE 6-P Fleet Est. (3,000.00) 0.00 0.00 0.00 joint credit card 8-Q citi Corp Est. (1,661.00) 0.00 0.00 0.00 joint credit card 6-R ATT Universal Est. (1,461.00) 0.00 0.00 0.00 joint credit card 6-S Lowes Est. TBD TBD TBD Husband's credit card TOTAL OF ASSETS AND LIABILITIES 38,420.29 31,123.73 7,296.56 Totals from above 38,420.29 31,123.73 7,296.56 Amount Due in 50/50 Division 19,210.15 19,210.15 Adjustment Figure (11,913.59) 11,913.59 Totals from above 38,420.29 31,123.73 7,296.56 Amount Due in 45/55 Division 17,289.13 21,131.16 Adjustment Figure (13,834.60) 13,834.60 Totals from above 38,420.29 31,123.73 7,296.56 Amount Due in 40/60 Division 15,368.12 23,052.17 Adjustment Fiqure (15,755.61) 15,755.61 Page 10 Diane L. Greene/4.18.02 Pre-Trial Statement/ revised 5/14/02 NOTES 1. 2. The adjustment figures are for illustration purposes only. If adjustments are required, it is suggested that the adjustment should be made first from the sale of the marital home, second from Defendant's IRA, and third from the distribution of Plaintiff's pension contribution account. If the distribution is determined to be 60% to wife and 40% to husband and the distribution is to be from wife's retirement contribution account, then Wife is to elect any option that gives her the right to withdraw at least $39,389.02 (40% = $15,755.61 and 60% = $23,633.41) from her contribution account. Wife is to retain her 60% share of $23,633.41. Wife is also to retain husband's 40% share of $15,755.61 to make the 60/40 adjustment figure set forth at the end of this schedule. The marital portion of all monthly payments are then to be divided 60% to wife and 40% to husband. This may have to be refined to account for the non-marital portion of the retirement earned after separation. See Section XI for Plaintiff's resolution position. The following is a delineation of Wife's bankruptcy payments @29.76% on the dollar. Jr. Bank of America 4024-1160-0380-6237 Jt. Choice Visa 4428-1350-0454-6446 Jr. Discover Card Jt. First USA 4417-1228-2110-4248 Jr. Home Depot 5174-6000-04100 $1,678.73 $499.59 $1,667.00 No proof of claim filed $2,682.98 $569.31 $4,413.00 No proof of claim filed $1,422.00 No proof of claim filed Providian $1,658.97 $493.71 4428-4713-7561-9270 PSECU $732.84 $218.09 184-38-0275 PSECU Visa $7,261.01 $2,160.88 184-38-0275 $1,821.11 Sears 0363599073675 $541.96 Waypoint Bank $2,809.12 $835.99 Resurgent CA $212.18 $63.14 TOTALS $26,358.94 $5,382.67 Page 11 Diane L. Greene/4.18.02 Pre-Tr~l Statement/ revised 5/14/02 III. LISTING OF PERSONAL PROPERTY THE FOLLOWING IS A LISTING OF THE PERSONAL PROPERTY OF THE PARTIES: A. MARITAL PROPERTY IN HUSBAND'S POSSESSION 1. Sofa Joint Husband $250.00 Estimate 2. ~ecliner chair Joint Husband $25.00 Estimate 3. 27" color tv Joint Husband $100.00 Estimate 4. Surround sound Joint Husband $100.00 Estimate system 5. VCR Joint Husband $100.00 Estimate 6. Lamp Joint Husband $25.00 Estimate 7. King-size waterbed Joint Husband $200.00 Estimate 8. Papa-saw chair Joint Husband $50.00 Estimate 9. Vanity Joint Husband $100.00 Estimate 10. Gun cabinet Husband Husband $150.00 Estimate 11. 4 rifles Husband Husband $1,500.00 Estimate 12. 4 dressers Joint Husband $200.00 Estimate 13. Computer Joint Husband $500.00 Estimate 14. Boat motor & Joint Husband $1,500.00 Estimate trailer 15. Large chest freezer Joint Husband $200.00 Estimate 16. Small chest freezer Joint Husband $50.00 Estimate 17. Marble collection Joint Husband $1,500.00 Estimate 18. Marble game in tin Joint Husband $250.00 Estimate box 19. wood lathe Joint Husband $150.00 Estimate 20. wood planer Joint Husband $150.00 Estimate 21. Snow blower Joint Husband $300.00 Estimate Page 12 Diane L. Greene/4.18.02 Pre-Tr~al Statement/ revised 5/14/02 A. MARITAL PROPERTY IN HUSBAND'S POSSESSION 22. Lawn mower Joint Husband $200.00 Estimate 23. Gas grill Joint Husband $50.00 Estimate 24. Park bench Joint Husband $50.00 Estimate 25. Porch furniture Joint Husband $100.00 Estimate 26. Microwave Joint Husband $300.00 Estimate 27 Household tools, Joint Husband $1,000.00 Estimate drills, saws, etc. 28. Dishes, glasses, Joint Husband $25.00 Estimate pots & pans 29. Refrigerator Joint Husband $100.00 Estimate 30. Fishing rods & Husband Husband $200.00 Estimate equipment 31. Computer desk Joint Husband $150.00 Estimate 32. Entertainment Joint Husband $200.00 Estimate center 33. Refrigerant gauge & Husband Husband $90.00 Estimate hose 34. Husband' s mechanics Husband Husband $1,050.00 Appraisal tools 35. Husband's power and Husband Husband $2,000.00 Estimate other tools 36. Wife's property in Wife Husband 0.00 These it~- are van including 3 requested by bins of pictures, wife state parking pass, handicap placard for car pool and legal documents SUBTOTAL MARITAL PERSONAL PROPERTY IN $9,865.00 HUSBAND' S POSSESSION Page 13 Diane L. Greene/4.18.02 Pre-Trial Statement/ revised 5/14/02 B. NON-MARITAL PROPERTY IN HUSBAND'S POSSESSION BA~ ~OR ~UA 1. Floor swing Wife Husband $50.00 This was made Estimate by wife' s father for her. This it.s should be returned to her. 2. 20 silver dollars Children Husband $200.00 These were Estimate given to the children by their grandfather for Christmas. Husband needs to provide th~ to the children. 3. 4 State Hood Children Husband $100.00 Bought (Gift) Estimate quarter sets for the children. Husband needs to provide th~ to the children. 4. China closet Husband Husband TBD Husband's pre- Estimate marital. Bought from uncle Henry 5. ~tique box with Wife Husband TBD Wife's non- Estimate silverware marital - came from wife's father' s family. Wife wants this it~ returne~ to her. S~TOTAL NON-~IT~ PERSON~ PROPERTY $350.00 IN HUSB~'S POSSESSION Page 14 Diane L. Greene/4.18.02 Pre-Tr~l Statement/ revised 5/14/02 C. MARITAL PROPERTY IN WIFE'S POSSESSION 1. Sofa & love seat Joint Wife $350.00 Estimate 2. Accessory tables Joint Wife $150.00 Estimate 3. 2 lamps Joint Wife $50.00 Estimate 4. Washer Joint Wife $100.00 Estimate 5. Dryer Joint Wife $100.00 Estimate 6. Dining room table & Joint Wife $350.00 Estimate chairs 7. Roll top desk Joint Wife $50.00 Estimate 8. Victrola Joint Wife $50.00 Estimate 9. Trash compactor Joint Wife $50.00 Estimate 10. Set of dishes Joint Wife $50.00 Estimate 11. 19" tv Joint Wife $150.00 Estimate 12. Husband's tool box Husband Wife $3,500.00 Appraisal SUBTOTAL WIFE' S ~RITAL PROPERTY $4,950.00 D. NON-MARITAL PROPERTY IN WIFE'S POSSESSION 1. Secretary desk Wife Wife TBD Wife's pre- marital 2. Bedroom furniture Wife Wife TBD Wife's pre- marital 3. Cedar chest Wife Wife TBD Gift to Wife and made by father 4 Grandfather clock Wife Wife TBD Gift to Wife · and made by father Page 15 Diane L. Greene/4.18.02 Pre-T~''l Statement/ revised 5/14/02 D. NON-MARITAL PROPERTY IN WIFE'S POSSESSION Xc+.u zo 5. Rocking chair Wife Wife TBD Gift to Wife and made by father 6. Armoire Wife Wife $100.00 Gift to Wife Estimate from children SUBTOTAL WIFE' S NON-MARITAL PERSONAL $100.00 PROPERTY Page 16 Diane L. Greene/4.18.02 Pre-Tr' 1 Statement/ revised 5/14/02 IV. MARITAL DEBTS THE FOLLOWING IS INFORMATION PERTAINING TO THE PARTIES' MARITAL DEBTS: Page 17 Diane L. Greene/4.18.02 Pre-Tr' '1 Statement/ revised 5/14/02 Page 18 Diane L. Greene/4.18.02 Pre-Tr' ~1 Statement/ revised 5/14/02 Page 19 Diane L. Greene/4.18.02 Pre-Tr' 1 Statement/ revised 5/14/02 Resurgent CA Est. During 212.18 212.18 marriage Bank One Est. During See See Comments marriage comments ~cov' s Est. During marriage 30.00 30.00 See Comments See Comments See Comments Walmart Est. joint credit card 1st Union Est. National Bank COMMENTS,,~ ii' ?The ~ii!~ Fleet Est. During marriage 91.00 During 833.00 marriage During 3,000.00 marriage iti Corp Est. During marriage 1,661.00 91.00 See Comments See Comments See Comments See Comments See Comments See Comments See Comments Page 2 0 Diane L. Greene/4.18.02 Pre-Tr~ 1 Statement/ revised 5/14/02 Page 2 1 Diane L. Greene/4.18.02 Pre-Tr'~l Statement/ revised 5/14/02 V. PENSIONS AND RETIREMENT BENEFITS THE FOLLOWING IS A LISTING OF THE PENSIONS AND RETIREMENT PLANS OF THE PARTIES: Page 2 2 Diane L. Greene/4.18.02 Pre-Tr~ ~1 Statement/ revised 5/14/02 VI. NON-MARITAL ASSETS AND DEBTS THE FOLLOWING IS A LISTING OF THE NON-MARITAL ASSETS AND DEBTS OF THE PARTIES: Floor swing 20 silver dollars Wife Husband $50.00 Children Husband $200.00 State Hood quarter sets lina Closet Children Husband $100.00 Husband Husband TBD box with silverware wife Husband TBD Secretary desk Bedroom furniture Cedar chest Grandfather clock Rocking chair Wife Wife TBD Wife Wife TBD Wife Wife TBD Wife Wife TBD Wife Wife TBD This was made by wife's father for her. This item should be returned to her. These were given to the children by their grandfather for Christmas. Husband needs to provide them to the children. Bought (gift) for the children. Husband needs to provide them to the children. Husband's pre-marital. Bought from Uncle Henry. ~ife's non-marital - came from Tife's father's family. Wife wants these items returned to her. Wife's pre-marital Wife's pre-marital .ft to Wife and made by father Gift to Wife and made by father .ift to Wife and made by father Armoire Wife Wife $100.00 Gift to Wife from children Page 2 3 Diane L. Greene/4.18.02 Pre-T~'~l Statement/ revised 5/14/02 VII. INCOME AND EXPENSES THE FOLLOWING IS A LISTING OF THE INCOMES AND EXPENSES OF THE PARTY (PARTIES): A. EMPLOYMENT INFORMATION AND INCOME: PARTY Diane L. Greene EMPLOYER: PA Department of Transportation ADDRESS: 1101 South Front Street, Harrisburg, PA 17104 POSITION: Clerk III PAYROLL NUMBER: 056704 PAY PERIOD: Bi-weekly GROSS PAY PER PAY PERIOD 37,141.81 ITEMIZED DEDUCTIONS ~ FICA OR SE TAX (2,302.84) MEDICARE OR SE TAX (538.58) FEDERAL TAX (4,585.48) STATE TAX (1,040.07) LOCAL TAX (312.78) MANDATORY RETIREMENT (1,857.09) UNION DUES (504.66) VOLUNTARY RETIREMENT HEALTH INSUPJ~NCE MISC DEDUCTION CHAPTER 13 PAYMENT (2,568.00) MISC. DEDUCTION (SPECIFY) TOTAL DEDUCTIONS (13,709.50) NET PAY PER PAY YEAR 23,432.31 NET PAY PER MONTH 1,952.69 Page 24 Diane L. Greene/4.18.02 Pre-T? '1 Statement/ revised 5/14/02 CALCULATION OF DIANE GREEN'S AVERAGE GROSS PAY 1/1/02 TO 3/15/02 GROSS 8,584.62 6.00 1,430.77 715.39 3,100.00 37,200.02 FEDERAL TAX (845.42) 6.00 (140.90) (70.45) (305.29) (3,663.49) FICA (532.22) 6.00 (88.70) (44.35) (192.19) (2,306.29) MEDICARE (124.46) 6.00 (20.74) (10.37) (44.94) (539.33) STATE (240.39) 6.00 (40.07) (20.03) (86.81) (1,041.69) LOCAL (85.88) 6.00 (14.31) (7.16) (31.01) (372.15) UNION DUES (118.26) 6.00 (19.71) (9.86) (42.71) (512.46) MANDATORY (536.51) 6.00 (89.42) (44.71) (193.74) (2,324.88) RETIREMENT NET TOTAL 6,101.48 6.00 1,016.91 508.46 2,203.31 26,439.75 D. EXPENSES DESCRIPTION MONTHLY AMOUNT Rent $200.00 Telephone $40.00 Lunches $75.00 Other Employment Expenses $50.00 Specify: travel on Penndale for PA D.O.T. Per Capita/Occupation Taxes $25.83 Automobile Insurance $175.00 Other Insurance $75.00 Specify: Long term care insurance Page 25 Diane L. Greene/4.18.02 Pre-Tr'-i Statement/ revised 5/14/02 DESCRIPTION MONTHLY AMOUNT Payments $250.00 Fuel $100.00 Maintenance And Repair $50.00 License And Registration $3.00 Doctor $50.00 Optical $25.00 Dental $8.33 Medicine $15.00 Clothing $150.00 Food $250.00 Barber And Hair Dresser $50.00 Memberships $4.50 Newspapers/Magazines/Books $10.00 Entertainment $100.00 Vacations $100.00 Legal Fees $125.00 Charitable Contributions $10.00 Garage Rent $25.00 Storage Unit $87.00 TOTAL EXPENSES $2,053.66 Page 2 6 Diane L. Greene/4.18.02 Pre-T' ~.1 Statement/ revised 5/14/02 VIII. COUNSEL FEES THE FOLLOWING IS A LISTING OF THE COUNSEL FEES AND EXPENSES INCURRED BY THE FILING PARTY IF A CLAIM HAS BEEN MADE FOR COUNSEL FEES AND COSTS: No claim has been made by Plaintiff for counsel fees and costs and therefore this section has not been completed. illl 'i N/A HOURLY RATE $175.00 Per Hour COSTS Costs are billed at actual cost ~T~ AMOUNT OF FERS AND N/A COSTS C~IMED TO DATE OF THIS PRE,TRIAL S ANTICIPATED FEES ~ Hourly rate for estimated 10 hours and actual cost for any COSTS pending appraisals iTEMiZATION OF SERVICES N/A R~ERED Page 27 Diane L. Greene/4.18.02 Pre-Tr'-1 Statement/ revised 5/14/02 IX. EXPERT WITNESSES THE FOLLOWING IS A LISTING OF THE EXPERTS WHO THE PARTY INTENDS TO CALL TO TESTIFY IN THIS CASE: Available **Additional experts who may be called to testify are not known at this time. There is a reservation of the right to call additional expert witnesses upon proper notification to the other party once those expert witnesses are identified and retained. X. OTHER WITNESSES THE FOLLOWING IS A LISTING OF THE ANTICIPATED WITNESSES OTHER THAN EXPERTS WHO WILL BE CALLED TO TESTIFY IN THIS CASE: set forth in the divorce code **Additional witnesses who may be called to testify are not known at this time. There is a reservation of the right to call additional witnesses upon proper notification to the other party once those witnesses are identified and agree to testify. Page 28 Diane L. Greene/4.18.02 Pre-Tr'~l Statement/ revised 5/14/02 XI. PROPOSED RESOLUTION THE FOLLOWING IS THE PLAINTIFF'S POSITION REGARDING RESOLUTION OF THE ECONOMIC ISSUES PRESENTED IN THIS CASE: Ao DIVORCE: A divorce decree should be entered under either Section 3301(c) or 3301(a) (6). Be EOUITABLE DISTRIBUTION: The parties' marital assets and debts should be divided and distributed 60% to wife and 40% to husband in accordance with the schedule included in the Exhibit Section of the Pre-Trial Statement. Ce ALIMONY PENDENTE LITE: No claim has been raised by Plaintiff or Defendant for Alimony Pendente Lite. ALIMONY: No claim has been raised by Plaintiff or Defendant claim for alimony. Ee COUNSEL FEES AND COSTS: No claim has been raised by Plaintiff or Defendant costs. for counsel fees and Page 29 Diane L. Greene/4.18.02 Pre-Tr',l Statement/ revised 5/14/02 XII. PROPOSED EXHIBITS THE FOLLOWING IS A LISTING THE PROPOSED EXHIBITS TO BE SUBMITTED AT THE HEARING IN THIS CASE. EXHIBITS ARE ATTACHED OR TO BE SUPPLIED AS INDICATED BELOW. THERE IS A RESERVATION OF THE RIGHT TO SUBMIT ADDITIONAL EXHIBITS UPON PROPER NOTIFICATION TO THE OTHER PARTY. Wife's Income and Expense Statement Wife'S Pay Stubs 2 3 4 Order 5 GMAC and Fairbanks mortgage statements and mortgage foreclosure documents 6 Kelley Blue Book valuation sheets for Chevy Astro Van s 2001 Federal and State Tax Returns Kelley Blue Book valuation sheets for Chevy Blazer Kelley Blue Book valuation sheets for Harley Davidson motorcycle X X X X TO BE SUPPLIED CLOSER TO HEARING DATE X X X 9 PSECU joint checking account statement X 10 Wife's Waypoint checking account statement X 11 Wife's Waypoint savings account statement X 12 Wife's SERS pension statement X 13 Husband's PSECU IRA statement Wife's Listing and Valuation of Personalty Wife's bankruptcy documents IWife's proposed distribution schedule 14 15 16 X X TO BE SUPPLIED UPON PRODUCTION BY HUSBAND WIFE'S LISTING IS ATTACHED; APPRAISAL TO BE SUPPLIED IF DISPUTED Page 3 0 Diane L. Greene/4.18.02 Pre-Tr~1 Statement/ revised 5/14/02 3 o SANCTIONS Under Rule 1920.33(c) it is provided that if a party fails to file either an Inventory as required by subdivision (a) or a Pre-Trial Statement as required by subdivision (b), the Court may make an appropriate Order under Rule 4019(c) governing sanctions. Under Rule 1920.33(d) (I) a party who fails to comply with the requirement of subdivision (b) of this Rule (the filing of a Pre-Trial Statement with the information set forth in subparagraph (b)) shall, except upon good cause shown, be barred from offering any testimony or introducing any evidence in support of or opposition to the claims for the matters not covered therein. Under Rule 1920.33(d) (ii) a party shall, except upon good cause shown, be barred from offering any testimony or introducing any evidence that is inconsistent with or which goes beyond the fair scope of the information set forth in the Pre-Trial Statement. Diane L. Greene/4ol8.02 Pre-T- '-al Statement/ revised 5/14/02 CERTIFICATE OF SERVICE ESQUIRE, hereby certify that I have t ~ved a copy of the within Pre-Trial Statement, by mailing same by first class mail, postage prepaid, addressed as follows: Robert F. Greene 312 Eutaw Street New Cumberland, PA 17070 Supreme Court ID # 32112 Phone: (717) 737-0100 Fax: (717) 975-0697 3.26.02. Income and Expense Statement IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIANE L. GREENE, Plaintiff V. ROBERT F. GREENE, Defendant NO. 02- iS O CIVIL ACTION - LAW DIVORCE CIVIL TERM INCOME AND EXPENSE STATEMENT OF DIANE L GREENE I verify that the facts set forth in the following Income and Expenses Form, including all attachments thereto, are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. DIANE L. GREENE Exhibit 1 Wife's Income & Expense Statement 3.26.02. Income and Expense Statement PART i. INCOME A. EMPLOYMENT INFORMATION: EMPLOYER: PA Department of Transportation ADDRESS: 1101 South Front Street, Harrisburg, PA 17104 POSITION: Clerk 3 PAYROLL NUMBER: 056704 PAY PERIOD: bi-weekly B. EMPLOYMENT INCOME: (BASED ON 2001 W-2 STATEMENT) GROSS PAY PER PAY PERIOD 37,141.81 37,141.81 ITEMIZED DEDUCTIONS FICA OR SE TAX (2,302.84) (2,302.84) MEDICARE OR SE TAX (538.58) (538.58) FEDERAL TAX (4,585.48) (4,585.48) STATE TAX (1,040.07) (1,040.07) LOCAL TAX (312.78) (312.78) MANDATORY RETIREMENT (1,857.09) (1,857.09) UNION DUES (504.66) (504.66) VOLUNTARY RETIREMENT HEALTH INSURANCE MISC. DEDUCTION BANKRUPTCY CHAPTER (214.00) 13 PAYMENT MISC. DEDUCTION (specify): TOTAL DEDUCTIONS (11,355.50) (11,141.50) NET PAY PER YEAR 25,786.31 26,000.31 NET PAY PER MONTH 2,148.86 2,166.69 - 2 - 3.2~'02. Income and Expense Statement CALCULATION OF DIANE GREEN'S AVERAGE GROSS PAY 1/1/02 to 3/15.02 DESCRIPTION YTD FACTOR BIWEEKLY WEEKLY MONTHLY YEARLY GROSS 8,584.62 6.00 1,430.77 715.39 3,100.00 37,200.02 FEDERAL TAX (845.42) 6.00 (140.90) (70.45) (305.29) (3,663.49) FICA (532.22) 6.00 (88.70) (44.35) (192.19) (2,306.29) MEDICARE (124.46) 6.00 (20.74) (10.37) (44.94) (539.33) STATE (240.39) 6.00 (40.07) (20.03) (86.81) (1,041.69) LOCAL (85.88) 6.00 (14.31) (7.16) (31.01} (372.15) UNION DUES (118.26) 6.00 (19.71) (9.86) (42.71) (512.46) 1W_ANDATORY (536.51) 6.00 (89.42) (44.71) (193.74) (2,324.88) RETIREMENT NET TOTAL 6,101.48 6.00 1,016.91 508.46 2,203.31 26,439.75 - 3 - 3~2~'~02. Income and Expense Statement D. OTHER INCOME: DESCRIPTION MONTHLY YEARLY INTEREST DIVIDENDS PENSIONS ANNUITIES SOCIAL SECURITY RENTS ROYALTIES EXPENSE ACCOUNT GIFTS UNEMPLOYMENT COMPENSATION WORKMAN'S COMPENSATION INCOME TAX REFUNDS SUPPORT OR ALIMONY COMMISSIONS TIPS OTHER SPECIFY: TOTAL OTHER INCOME $0.00 $0.00 3.26'.02. Income and Expense Statement PART II. EXPENSES DESCRIPTION MONTHLY AMOUNT HOME EXPENSES: Rent $200.00 First Mortgage Second Mortgage/Home Equity Loan Maintenance And Repairs Electric Gas Oil Telephone $40.00 Water Sewer Trash EMPLOYMENT Public Transportation Lunches $75.00 Other Employment Expenses $50.00 Specify: travel on Penndale for PA D.0.T. Real Estate Taxes Personal Property Taxes Income Taxes Not Withheld Per Capita/Occupation Taxes $25.83 - 5 - 3.26~02. Income and Expense Statement DESCRIPTION MONTHLY AMOUNT INSURANCE: Homeowners Insurance Automobile Insurance $175.00 Life Insurance Accident Insurance Health Insurance Other Insurance $75.00 Specify: Long term care insurance AUTOMOBILE EXPENSES: Payments $250.00 Fuel $100.00 Maintenance And Repair $50.00 License And Registration $3.00 MEDICAL EXPENSES NOT REIMBURSED BY INSURANCE: Doctor $50.00 Optical $25.00 Dental $8.33 Orthodontic Hospital Medicine $15.00 Special Needs/Therapy Etc. Speci fy: 3.2~.02. Income and Expense Statement DESCRIPTION MONTHLY AMOUNT EDUCATIONAL EXPENSES: Private School Parochial School College/Vocational Religious Training or Education Books/Fees And Supplies Other Educational Expenses PERSONAL EXPENSES: Clothing $150.00 Food $250.00 Barber And Hair Dresser $50.00 Memberships $4.50 CREDIT CARDS AND LOANS: NO Creditor Bal~ncel 1. MISCELLANEOUS EXPENSES: Household Help Child Care Newspapers/Magazines/Books $10.00 Entertainment $100.00 Pay TV Vacations $100.00 Gifts Legal Fees $125.00 Charitable Contributions $10.00 Other Child Support (not the subject of this action) ~ 7 - 3.25.02. Income and Expense Statement DESCRIPTION MONTHLY AMOUNT Other Spousal Support or Alimony (not the subject of this action) OTHER EXPENSES Garage Rent $25.00 Storage Unit $87.00 TOTAL EXPENSES $2,053.66 - 8 - PART III. PROPERTY OW-NED PROPERTY OWNED OWNERSHIP TYPE DESCRIPTION VALUE H W JT Checking Focus Fifty 200.00 X Savings Credit Union Stocks/bonds Real Estate Other PART IV. INSURANCE TYPE COMPANY POLICY NO. H W C Hospital/Blue X X Cross Medical/Blue X X Shield Health X X Accident Disability Income Dental X X Vision X X Other-Specify *H=Husband; W=Wife; J=Joint; C=Child 3.26.02. Income and Expense Statement (a) (b) (c) (d) (e) (f) PART V. SUPPLEMENTAL INCOME STATEMENT [X] CHECK HERE IF NOT APPLICABLE This form is to be filled out by a person: (1) Who operates a business or practices a profession, or (2) Who is a member of a partnership or joint venture, or (3) Who is a shareholder in and is salaried by a closed corporation or similar entity. Attach to this statement a copy of the following documents relating to the partnership, joint venture, business, profession, corporation or similar entity (check block to indicate the document is attached): (1) The most recent Federal Income Tax Return. [ ] attached (2) The most recent Profit and Loss Statement. [ ] attached Name of Business: Business Address: Business Telephone: [ ] [] [ ] 3. [ ] 4. [ ] 5. Nature of Business (check one) 1. Sole Proprietorship 2. Partnership Joint Venture Professional Corporation Other Name of accountant, controller or other person in charge of financial records: Business Income: 1. Annual income from business: 2. How often is income received: 3. Gross income per pay period 4. Net income per pay period 5. Specify deductions, if any: ~ 10 - CU~'~UNWkALIH Uh FA - E~PLOYE STATE'~E~T PAY PERIOD ENDING: 12-07-01 PAY DATE: '-28-01 VT#: 190802280000 DEPT: 008 CDC: 072. EMP#: 056704 POS#: 056629 SSN: 184-38-0275 B/U: A1 PAY RANGE: 04 STEP: 16 LEVEL: O0 TRANSPORTATION DRIVER LICENSING DIANE L GREENE i2 W PINE STREET ENOLA PA 17025 STATE PAID BENEFITS HORKERS COMP SOCIAL SECURITY ~EDICARE TOTAL STATE PAID BENEFITS 3.97 10.70 2.50 17.17 STATEMENT :::::::::::::::::::::::::::: TH)8 PAY DT Y~AR TO DATE GROSS EARNINr* MINUS DEDU FED WTM TX M oo SOC SEC TX SOC SEC/MED TX STATE HTH TX PA LOC MG TX-RES PA 21 909 RET P/U CON STATE EWP NET EARNINGS: PLUS REIMBURSEMENTS 172.53 NS 24.58 6.20000% 10.70 1.A5000% 2.50 2.80000% 4.83 1.00000% 1.73 5.00000% 8.63 119.56 37,141.88 4,325.48 2,302.84 538.58 1,040.07 58.68 1,857.13 SERVICE CREDIT: 0 YR 0 PP END :::.. LEAVE· USAGE REPORTED ~::. : ::::?::. ::ii:::!: I :?::! : HOURS EAVE ACTIVITY .;.:.! ALANCE LAST STATEMENT CCRUA[ THIS PP V REPORTED THIS PP DJUSTMENTS ALARCE THIS STMT :.~' :ACCRUAL RATE: .ANNUAL i SICK..?::;' ..:.PERSONAL .00 I .00 .00 .ooi ,oo .oo .00 ~ .O0 .00 .oo I .oo .oo t ANNUAL .;:.:.00% SICK .:i.i: .00%.:]i:. ::::r.::i: · TOTAL CHECK AMOUNT : :::::i.:::.i:ii.:$ ..!. : 119.56 Pp END IBREAKDOHN GROSS EARN HOURS: j:¥.:: 2.50 5.00 TOTAL GROSS EARNING$~I'HIS:PAY : :.. :'"RATE.~:' GROSS 17.25 43.13 25.88 129.40 172,53 SENIORITy:iNFOR~ATIOW'i~i~i ESSAGE CENTER: LOCAL WAGE TAX COUNTY/HUNICIPALITY: CUMBERLAND COUNTY FHT TAX GROSS: 163.90 EAST PENNSBORO THP. Commonwealth of Pennsylvania Ho State Job Net-' http://j o bn et.scsc.sta te. pa. us Search for State Jobs from around ~ sDonso~ed by the the Commonwea/th at one web site. 'State Owl Serwce Commission Exhibit 2 Wife's pay stubs COmmONWEALTH OF PA - E~PLOY£ STATEMENT PAY PERIOD ENDING: 12-07-01 PAY DATE: -21-0! VT#: 190802190000 DEPT: ooa CDC: 072~ EHP#: 056704 POS#: 056629 SSN: 18&-38-0275 B/U: A! PAY RANGE: 04 STEP: 16 LEYEL: O0 TRANSPORTATION DRIVER LICENSING DIANE L GREENE 12 W PINE STREET ENOLA PA 17025 HEALTH BENEFITS ANN NED HOSP LIFE INSURANCE NORKERS COMP SOC!AL SECURITY HEDICARE CAPITAL BLUE CROSS RET EMP HLTH PROG (REHP) TOTAL STATE PAID BENEFITS 190.00 135.00 3.39 29.74 80.21 18.76 $ 457.10 SERVICE CREDIT: 21 YR 6 PP GROSS EARNIP' MINUS DEDL ~NS FED HTH TX H O0 SOC SEC TX 6.20000% 50C SEC/MED TX 1,15000% STATE MTH TX PA 2.80000% LOC MG TX-RES PA 21 909 1.00000% RET P/U CON STATE EMP BANKRPTCY ORDER C DEHART III-MID OIST PA DN DUES AFSCME - 13 2534 FED NTH TX-ADD NET EARRINGS: 1,293.75 147.16 80.21 18.76 36.23 12.94 64.69 107.00 19.41 lO.OO 797.35 PLUS REIMBURSEMENTS 36,969.35 4,300.90 2,292.14 536.08 1,035.24 56.95 1,848.50 428.00 ~9~.25 2GO.O0 REG SAL 75.00 17.25 1,293.75 IALANCE LAST STATEMENT 220.88 445.83 ~CCRUAL THIS PP 5.78 3.75 .V REPORTED THIS PP .00 .00 kDJUSTHENTS .00 .00 TALANCE THIS STHT 226.66 449.58 IESSAGE CENTER: LOCAL RAGE TAX COUNTY/NLINICIPALITY: FHT TAX GROSS: 1,229.06 22.50 .00 .00 .00 22.50 CUMBERLAND COUNTY GENERAL NONSUPV 5,224 CREDIT DAYS EMP MILITARY DAYS J 0 CA.IT DAYS CREDIT DATE I 12-07-01 EAST PENNSBORO TMP. Commonwealth of Pennsylvania p~ State job Net- http://jobnetscsc, state, pa. us Search for State Jobs from around by the the Commonwealth at one web site. 'State Ovtl Service Com'~ -' "- ' - mission COMMONWEALTH OF PA - EMPLOYE STA~E~E~N-Y' PAY PERIOD ENDING: 11-23-01 PAY DATE: -07-0I VT#: 190802020000 DEPT: 003 CDC: 072~ EMP#: 056704 POS#: 056629 SSN: 184-38-0275 B/U: A1 PAY RANGE: 04 STEP: 16 LEVEL: O0 TRANSPORTATION DRIVER LICENSING DIANE L GREENE 12 W PINE STREET ENOLA PA 17025 ~EALTH BENEFITS kNN NED HOSP .IFC INSURANCE 40RKERS COMP ;OCIAL SECURITY 4EDICARE CAPITAL BLUE CROSS RET EMP HLTH PROG (REHP) TOTAL STATE PAID BENEFITS 190.00 135.00 3.39 29.74 80.21 18.76 $ 457.10 SERYZCE CREDIT: 21 YR 5 PP ~p :ENI~ ;:ii!ii i::::ii!~iii ::iii[~AVEi USAGE?REPORT~!::iiiii::iiii~::ii::ili::?::::i::::::::::i::i!iiiiii:::?i::ii!i !i~i~iii!!iHoUR~ iii?:::ill kLANCE LAST STATEMENT J 222.60 :CRUAL THIS PP J 5.78 REPORTED THI'S PP J .00 )JUSTMENTS I ,00 ~LA#CE THIS STMT ~ 228.38 ~SSAGE CENTER: FHT TAX GROSS: / I GROSS EARNIHr' J MINUS DEDL NS J FED NTH TX M O0 SOC SEC TX 6.20000% SOC SEC/RED TX 1.45000% ETATE NTH TX PA 2.80000% LOC WG TX-RES PA 21 909 1.00000% RET P/U CON STATE EMP 5.00000% BARKRPTCY ORDER C DEHART III-MID DIST PA UN DUES AFSCME - 13 2534 FED MTH TX-ADD 442.08 J 22.50 3.75 J .00 .oo I .oo .oo I .oo 445.83 J 22.50 LOCAL WAGE TAX COUNTY/MUNICIPALITY: CUH6ERLAND :OURTY 1,229.06 NET EARNINGS: PLUS REIMBURSEMENTS ;:TH! S;: PA~:! DT 1,293.75 147.16 80.21 18.76 36.23 12,94 64,69 107. O0 19,41 10.00 797.35 YEJ[R 'TO :':DATE: 35,503.07 4,129.16 2,201.23 514.82 994.18 42.28 1,775.18 321.00 474.84 250. O0 L-23-01 REG SAL 75.00 17.25 1,293.75 .... i!! :: !.!!i 'i:.. ~oTAL GRO$$::.EARMING-q .THIS:.i:~'~:i: GENERAL NONSUPV EHP HiLITARY DAYS CREDIT DATE 5,214 CREDIT DAYS 0 CREDIT DAYS 11-23-01 EAST PENNSBORO TMP. DON'T LOSE $87~000 FROM YOUR RETIREMENT! Act 2001-09 increases the penSion benefit for eligible ernl~[oyees, but ONLY IF THEY SEND AN ELECTION FORM TO SLURS, AND ONLY lY SELLS RECEIVES THE FORM BY DECEMBER 31,2001. Have you sent yours? Here's a comparison of the presem value of an average SERS member's armnity under the new Class AA vs. Class A if they retire in just nine more yearn:-.;.. ~. Class AA $438,936 ] ' ' · [. Class A $351,149 IMPORTANT! IfSERS doesn't receive your election -- Difference $ 87,787 by December 31, you never get another chance! If you haven't made your election or if you have any questions, please call SEt~S at 1-800-633-5461. Do it now! COmmONWEALTH OF PA - E~PLO?E STATE~ PAY PERIOD ENDING: 11-23-01 PAY DATE: -14-01 VT#: 190802100000 DEPT: 008 CDC: 0723. EMP#: 056704 POS#: 056629 SSN: 184-38"-0275 B/U: A1 PAY RANGE: 04 STEP: 16 LEVEL: O0 TRANSPORTATION DRIVER LICENSING GROSS EARNINc HINUS DEDb NS FED NTH TX M O0 SOC SEC TX 6.20000~ SOC SEC/HED TX 2.45000% STATE NTH TX PA 2.80000% LOC NG TX-RES PA 21 909 1.00000% RET P/U CON STATE EMP 5.00000% DIANE I GREENE 12 W PINE STREET ENDLA PA 17025 3.97 10.70 2,50 NET EARNINGS: NORKERS COMP SOCIAL SECURITY MEDICARE PLUS REIMBURSEMENTS TOTAL STATE PAID BENEFITS SERVICE CREDIT: 21 YR 5 PP 'PsiEND. :: L1-23-01 ANNUAL 7.50 172.53 35,675.60 24.58 4,153.74 10.70 2,211.93 2.50 517.32 4,B3 999.01 1.73 44.01 8.63 1,783.81 119.56 BREAKDOHN :GROSS::SEARN ~ 2.50 5.00 17.25 43.13 25.88 129.40 OT-1.0 0T-1.5 EAST PEN#SBORO TNP. ALANCE LAST STATEMENT 228.38 445.83 22.50 CCRUAL THIS PP .00 .00 .00 V REPORTED THiS PP 7.50 .00 .00 DJUSTNEHTS ,00 .00 .00 ALANCE THIS STHT 220.88 445.83 22.50 ESSAGE CENTER: LOCAL HAGE TAX COUNTY/MUNICIPALITY: CUHBERLAND COUNTY FHT TAX GROSS: 163.90 DON'T LOSE $87~000 FROM YOUR RETIREMENT! Act 2001-09 increases the pension benefit for eligible employees, but ONLY IF THEY SEND AN ELECTION FORM TO SLURS, AND ONLY IF SERS RECEIVES THE FORM BY DECEMBER 31,200t. Have you sent yours? Here's a comparison of the present value of an average SERS member's annuity under the new Class AA vs. Class A if they retire in jnst nine more yea~.~.;. Class AA $438,936 · Class A $351,149 IMPORTANT! IfSERS doesn't receive your election Difference $ 87,787 by December 31, you never get another chance! If you haven't made your election or if you have any questions, please call SERS at 1-800-633-5461. Do it now COMMONWEALTH OF PA EMPLOYE .... :::~:" ...................... ':: .......... : ............ GROSS EARNIF 1,293.75 3~,036.7 PAY PERIOD ENDING: 11-09-01 PAY DATE: .21-01 MINUS DEDL VT#: 190801840000 DEPT: 008 CDC: 0723b FED NTH TX N O0 147.16 3,957.4. ,SOC SEC TX 6.20000% 80.21 2,110.3: ENP#: 056704 POS#: 056629 $SN: 184-38-0275 SOC SEC/NED TX 1.45000% 18.76 493.5~ B/U: A1 PAY RANGE: 04 STEP: 16 LEVEL: O0 STATE HTH TX PA 2.80000% 36.23 953.1: TRANSPORTATION DRIVER LICENSING LOC NG TX-RES PA 21 909 1.00000% 12.94 27.6: ~ RET P/U CON STATE ENP 5.00000% 64.69 1,701.8~ BANKRPTCY ORDER C DEHART III-HID DIST PA 107.00 UN DUES AFSCME - 13 2534 19.41 455.4~ FED hTW TX-ADD 10.00 240.0( DIANE L GREENE 12 W PINE STREET ENOLA PA 17025 NET EARNINGS: 797.35 qEALTH BENEFITS CAPITAL BLUE CROSS 190.00 kNN HED HOSP RET ENP HLTH PROG (REHP) 135.00 _IFE INSURANCE 3.39 qORKERS COMP 29.74 ;OCZAL SECURITY 80.2? 4EDICARE - 18.76 TOTAL STATE PAID BENEFITS $ SERVICE CREDIT: 21 YR ~ PP ~1"-09-01 REG SAL 75.00 17.25 1,293.7~ ~LA#CE LAST STATEMENT 219.B2 438.33 22.50 GENERAL NONSUPV 5,204 CREDIT DAYS :CRUAL THIS PP 5.78 3.75 .00 REPORTED THIS PP .00 .00 .00 FNP MILITARY DAYS 0 CREDIT DAYS )JUSTNENTS I .00 .00 ,00 CREDIT DATE 11-09-01 kLANCE THIS STHT 225.60 442.08 22.50 I ESSAGE CENTER: LOCAL WAGE TAX COUNTY/MUNICIPALITY: CUNBERLAND COUNTY FHT TAX GROSS: 1,229.06 EAST PE#NSBORO TNP. 2002 FEDERAL INCOME TAX WITHHOLDING Employees arc rc-~ninded ~o submit a new Form W-4, Fdpployee Withholding Allowance Certificate, for 2002 their withhold~g allowances have changed or will change for thc new yca~. Those employees claim~g totaJ exemption from fcdem! ~come tax withholding must file a ocw W-4 with their Personnel Office each yesr in order ~o continue that status; (You may claim exemption for 2002 if you bare ~o income tax liability ia 2001 and expect to havc none in 2002.) Failure to raffle for exemption by February IS, 2002, will result in filing stntus of single claiming zero oNowaaces and cause tax withholding. Filing a false or fi'auduient withholding ex~aptJoz~ cen~carc ca= resuJt i= serious legal penalties. Questions concerning Form W-4 should be directed lo your agency Persozmcl Of'rice. COMMONWEALTH OF PA - EMPLO~E PAY PERIOD ENDING: 11-09-01 PAY DATE: .-30-01 YT#: 190801930000 DEPT: 008 CDC: 0723~ EHP#: 056704 POS#: 056629 SSN: 184-38-0275 B/U: A1 PAY RANGE: 04 STEP: 16 LEVEL: O0 TRANSPORTATION DRIVER LICENSING DIANE L GREENE 12 W PINE STREET ENOLA PA 17025 ;i!;i STATE.::PAiD !B ENEF. ~ · 10.70 2.50 WORKERS COMP SOCIAL SECURITY MEDICARE TOTAL STATE PAID BENEFITS SERVICE CREDIT: 21 YR 4 PP L1-09-01 ANNUAL EAVE ACTIVI GROSS EARNI' MINUS DEDL iNS :ED NTH TX M O0 SOC SEC TX 6.20000% SOC SEC/MED TX 1.45000% STATE HTH TX PA 2.80000% LOC HG TX-RES PA 21 909 1.00000% RET P/U CON STATE EMP 5.00000% ALANCE LAST STATEMENT 225.60 442.08 22.50 CCRUAL THIS PP .00 .00 .00 V REPORTED THIS PP 3.00 .00 .00 DJUSTHENTS .00 .00 .00 ALANCE THIS STHT 222.60 642.08 22.50 NET EARNINGS: PLUS REIMBURSEMENTS OT-1.0 OT-1.5 2.50 5.00 172.53 34,209.32 24.58 3,982.00 10.70 2,121.02 2.50 496.06 4.8: 957.95 1.73 29.34 8.63 1,710.49 119.56 43.13 129.40 17.25 25.88 iii::;iiii!:!iii:;:i:ifi?; :ii:!i~::TOTAL.GROSS::EARNiMGS:THiS:pAy+::!!ili i::! .$ii :1[7 ~ ::.~i ;!? S EMI OR I TY :i ! NFORMAT ION ::F~i:: i. :: ESSAGE CENTER: LOCAL WAGE TAX COUNTY/MUNICIPALITY: CUMBERLAND COUNTY FHT TAX GROSS: 163.90 EAST PENNSBORO TWP. 2002 I~EDERA/, L'~CO~FIE TAX ~A~THHOLDI~G Employees are reminded to sub~t a new Form W~,~ploy~ With~ding ~lowance Ce~fl~le, for 2~2 if ·cir ~hol~g allowances ~ve c~ngcd or ~ll c~c for ~C new ~. ~ ~loyccs clang to~l exertion from federal ~co~ P~o~cl Office each ~a: ia order to c~ue ~t sa~. (You ~y cl~ ex.don for 2~2 if~u have lJab~w ~ 2~1 ~d ~pcct to have none in 2~2.) Failure to refile for exe~doa by Februa~ filing s~t~ of da~e clai~ag zero allowanc~ and ~use ~ withhelding. F~g a false or ~ud~t ~olding exertion c~ ~ ~It ~ s~ous legal ~Ides. ~do~ conc~g Fo~ W~ should ~ d~ted to ~ur ag~ P~I O~cc. GROSS EARNINGS 172.53 32,743,0 PAY PERIOD ENDING: 10-26-01 PAY DATE: ~1-16.-01 HIRUS DEDUCT)n3s VT#: 190801750000 DEPT: 008 CDC: 0723'~ FED NTH TX H O0 24.58 3,810.2, SOC SEC TX ,'6.20000% i0.70 2,030.1 EMP#: 056704 POS#: 056629 SSN: 184-38-0~/5 SOC SEC/HED TX 1.45000% 2.50 474.8, B/U: A1 PAY RANGE: 04 STEP: 16 LEVEL: O0 STATE HTR TX PA 2.80000% 4.83 926.8' TRANSPORTATION DRIVER LICENSING LOC WG TX-RES PA 21 909 1.00000% 1.73 14.6' RET P/U CON STATE EMP 5.00000% 8.63 1,637.1' DIANE L GREENE I2 W PINE STREET ENOLA PA 17025 NET EARNIHGS: 119.56 RKERS CONP 3.97 CIAL SECURITY I0.70 DICARE 2.50 TOTAL STATE PAID BENEFITS $ 17.17 SERVICE CREDIT: 21 YR , 3 PP -26-01 SICK FAHILY 2.00 10-26-01 DT-i.0 2.50 17o25 43.13 10-26-01 0T-1.5 5.00 25.88 129.40 ~'~'~;~i~!~ '~!~!~{i!!ii~ii~!~ ~"*!'"***'*' *':"~ ~'*' '*"'"':'":"*;!~'**":*:**'""*'" ':*:*'*:'**::' ~***'"'"*":'"~*::'*'::'*:' "*:: ::: ::!:!: :i:i:: :~¢~:~:~:~:***'"'"' "*'*****'**'""*" ............... .ANCE LAST STATEHENT 219.82 440.33 22.50 :RUAL THIS Pe .oo .oo .oo REPORTED THIS PP .00 2.00 .oo IUSTHENTS .oo .oo J .oo .ANCE THIS STMT 229.82 438.33I 22.~0 SAGE CENTER= LOCAL RAGE TAX COUNTY/HLIRICIPALITY: CUNBERLAND COUNTY EAST PENNSBORO TNP. NT TAX GROSS: ~63.~0 REMINDER: FCAP OPEN ENROLLMENT DURING NOVEMBER November is open enrollment month for the 2002 Family Care Account Program (FCAP). If you pay for the care of dependents so you can work, contact your Human Resource Office for additional information. COMMONWEALTH OF PA - EMPLOYE STATEMENf PAY PERIOD EMDIRG: 10-26-01 PAY DATE: -09-0~ VT#: ~90801660000 DEPT: 008 CDC: 072b~ EMP#: 056704 POS#: 056629 SSN: 184-38-0275 B/U: A1 PAY RANGE: 04 STEP: 16 LEVEL: O0 TRANSPORTATION DRIVER LICENSING DIANE L GREENE 12 W PINE STREET ENOLA PA 17025 HEALTH BENEFITS CAPITAL BLUE CROSS ANN MEO HOSP RET EMP HLTR PROG (REHP) LIFE INSURANCE 40RKERS COMP ;OCIAL SECUR!TY 4EDZCARE 190.00 135.00 3.39 29.74 ~0.21 1B.76 TOTAL STATE PAID BENEFITS SERVICE CREOIT: 21 YR 3 PP GROSS EARNINc- MINUS DEDL NS FED NTH TX M O0 SOC SEC TX 6.2000Cr% S0C SEC/MED TX 1.45000% STATE MTH TX PA 2.80000'4 LOC MG TX-RES PA 21 909 1.00000% RET P/U CON STATE EHP 5.00000% 1,293.75 147,16 80.21 18.76 36,23 12.94 64.69 UN DUES FED MTH TX-ADD BANKRPTCY ORDER C DEHART III-MID DIST PA AFSCME - 13 2534 NET EARNINGS: PLUS REIMBURSEMENTS 107.00 19.41 10.00 797.35 32,570.51 3,785.68 2,019.41 472.30 912.O6 12.94 1,628.54 107.00 436.02 230.00 REG SAL 75.00 17.25 1,293.75 ALANCE LAST STATEMENT 214.04 436.58 15.00 ZCRUAL THIS PP 5.78 3.75 7.50 REPORTED THIS PP .00 .00 .00 )JUSTMENTS .00 .00 .00 ~LANCE THIS STILT 219.82 440.33 22.50 ~SSAGE CENTER: LOCAL RAGE TAX COUNTY/MUNICIPALITY: FHT TAX GROSS: 1,229.06 GENERAL NONSUPV EMP MILITARY OAYS CREOTT DATE CUMBERLAND COUNTY EAST PENNSBORO THP. 5,194 CREDIT DAYS 0 CREDIT DAYS 10-26-01 REMINDER: FCAP OPEN ENROLLMENT DURING NOVEMBER November is open enrollment month for the 2002 Family Care Account Program (FCA.P). If you pay for the care of dependents so you can work, contact your Human Resource Office for additional information. " GROSS EARNINGS 172.53 31,276.7 PAY PERIOD ENDING: 10-12-01 PAY DATE: 11-02-01 MINUS DEDUCTIONS VT#: 190801570000 DEPT: OOB CDC: 0723~ IFED NTH TX M O0 24.58 3,638.5 SOC SEC TX 6.20000% 10.70 1,939.2 EHP#: 056704 POS#: 056629 SSN: 284-38-0~7~ SOC SEC/MED TX 1.45000% 2.50 453.5 B/U: A1 PAY RANGE: 04 STEP: 16 LEVEL: O0 STATE HTH TX PA 2.800007 4.83 875.8 TRANSPORTATION DRIVER LICENSING LOC NG TX-RES PA 21 805 1.00000% 1.73 312.7 RET P/U CON STATE EMP 5.00000% 8.63 1.563.8 DIANE L GREENE 312 EUTAW STREET NEW CUMBERLAND PA 17070 NET EARNINGS: 119.56 ~RKERS COMP 3.97 ~CIAL SECURITY 10.70 :DICARE 2.50 TOTAL STATE PAID BENEFITS $ 17.17 SERVICE CREDIT: 21 YR 2 PP , -12-01 ANNUAL 5.50 10-12-01 OT-I.0 2.50 17.25 43.13 10-12-01 OT-1,5 5.00 25.88 129.40 ANCE LAST STATEMENT 219.54 436.58 15.00 RUAL THIS PP .DO .00 .00 REPORTED THIS PP 5.50 .OO .OD UGTMENTS .00 ,00 .00 ANCE THIS STMT 214.04 436,5B 15.00 SAGE CENTER: LOCAL NAGE TAX COUNTY/MUNICIPALITY: CUHBERLAND COUNTY NEW CUMBERLAND BORO NT TAX GROSS: 163,90 ONLINE FORMS ARE AVAILABLE TO PEBTF MEMBERS The following PEBTF forms are available on the PEBTF web site and can be downloaded completed and printed from your computer: · PEBTF Emp oyee Enrol ment/Change Form (PEBTF-2) · PEBTF Major Medical Claim Form · PEBTF Medical Reimbursement Claim Form To use these forms: 1. Go to www. Debtf.orq and click on Publications/Forms. 2. Download the form and instruction sheet and save it to your computer. t 3, Type the information direcUy onto the form. 4. Print, sign and date the form. 5. Return the PEBTF-2 Form to your local Human Resource Office. 6., Mall the claim forms directly to the PEBTF with any necessary attachments. GROSS EARNZNG' Z, 293.7~ 3~, ~0~.2: PAY PERZOD ENOZNG: ~O-Z2-OZ PAY BATE: 26-0Z N~NUS DEDUC VT~: 190801480000 DEPT: 008 CDC: 07236 FEB ~H TX H O0 E~P~: ~6704 POS~: 0~6629 SSN: Z84-38-027~ 50C S~C/HED TX Z.4SO00~ ~8.76 B/U: A1 PAY RANGE: 04 STEP: ~6 LEVEL: O0 STATE ~H TX PA 2.8000~ 36.23 87~.0C 'RANSPORTATZO~ DRZYER L~CEHS~NG LOC HG TX-RES PA 21 805 1.0000~A 12.94 312.0 ~ RET P~ COH STATE EHP 5.00000% UN ~E5 AFSCHE - 13 2534 19.~1 FED ~H TX-ADD 10.00 220.0C DZANE L GREENE 3~2 EUTAW STREET NE~ CUMBERLAND PA ~TOTO NET EARH/NGS: 90~.35 :STATE PAID BENEFZTS :?~.?~?~: :~F: :;~::?::~: .: ~.~?.:~: ?; ~::?~[~ ,' PLUS REZHBURSEHENTS EALTH BENEFITS CAPITAL BLUE CROSS 190.00 ~H HED HOSP RET EHP HLTH PROG (REHP) 135.~ [FE ~NSURANCE 3.39 }RKERS COHP 29.74 ~DICARE 18.76 TOTAL STATE PAID BENEFITS $ 457.10 SERVICE CREDIT: 21 YR 2 PP 10-12~1 REG SAL 75.~ 17.25 1.293.75 LANCE LAST STATEMENT 213.76 432.83 1~.00 GENE~L NONSUPV ~,~84 CREDIT DAYS CRUAL THIS PP ~.78 3.75 R~PORTED THIS PP .00 .00 .00 ~HP HTL]TA~Y DAY~ 0 C~FDZT -nAYS JUSTHENTS I .00 .00 ~ .00 CR~T DATE 10-22-01 LANCE THIS ST~ 219.5~ 436.58 15.00 I SSAGE CENTER: LOCAL NAGE TAX COUNTY/HUNICIPAL]TY: CUMBERLAND COUNTY MEN CUHBERLANJ BORO FHT TAX GROSS: 1,229,06 ONLINE FORMS ARE AVAILABLE TO PEBTF MEMBERS The following PEBTF forms are available on the PEBTF web site and can be downloaded, completed, and printed from your computer: · PEBTF Employee Enrollment/Change Form (PEBTF-2) ~ · - PEBTF Major Medical Claim Form o PEBTF Medical Reimbursement Claim Form To use these forms: 1. Go to www. pebff.orq and click on Publications/Forms. 2. Download the fonn and instruction sheet and save it to your computer. 3. Type the information directly onto the form, 4. Print. sign and date the form. 5. Return the PEBTF-2 Form to your local Human Resource Office. -.. 64, .Mall the clal_.m !o. rms d!r. ect.~_.~o_~t.h.e PEBTF wilh,any necessary attachments. COMMONWEALTH OF PA - EMPLOYE STATEMENT ........................................................... GROSS EARNIP~' 1,293.75 29,810.4; PAY PERIOD ENDING: 09-28-01 PAY DATE 3-12-0! HINUS DED )NS VT#: 190801300000 DEPT: OO& CDC: 07k.. FED NTH TX M O0 147.16 3,466.7~ SOC SEC TX 6.20000% 80.21 ENP#: 056704 POS#: 056629 SSN: 184-38-0275 SOC SEC/MED TX 1.45000% 18.7s 432.21 S/U: A1 PAY RANGE: 04 STEP: 16 LEVEL: O0 STATE HTH TX PA 2.80000% 36.23 834.71 TRANSPORTATION DRIVER LICENSING LOC NG TX-RES PA 21 805 1.00000% 12.94 298.1: : RET P/U CON STATE EHP 5.00000% 64.69 1,490.5: UN DUES AFSCNE - 13 2534 19.4! 397.2C FED NTH TX-ADD lO.OU 210.0 DIANE L GREENE 312 EUTAW STREET NEW CUMBERLAND PA 17070 NET EARNINGS: 904.35 :i?:STATE PA~DiB~NEFITSiiiiii!~;ih~!ii~ii~i~i?i?~i?~:~!~i::i!}~!i~!~i~i!~:~:?:~!~ ;:~ !:!!i : PLUS REIMBURSEMENTS HEALTH BENEFITS CAPITAL BLUE CROSS 190.00 ANN NED HOSP RET EHP HLTH PROG (REHP) 135.00 LIFE INSURANCE 3.39 HORKERS COMP 29.74 SOCIAL SECURITY 80.21 MEDICARE 18.76 TOTAL STATE PAID BENEFITS $ 457.10 SERVICE CREDIT: 21 YR i PP pp:!iEND !'i! .:!??i;;ii!jliF;:kEA~E?iUSAGE?!:REpO~m'i~ !i :! i ~ ~ ~ !!~;!~i~i;HOURS:~; '::! pp;END::!i 8REAKDgNN GROSS! EARN !i?.:HOURS...?;i~i:~:i RATE :.: !.;: 09-14-01 ANNUAL 1.00 0~-28-0: REG SAL 75.00 ~7.25I, 1,293.75 TOTAL GRoss EARNINGS THZS:~PAY .:i+ii?!:;:! .'.:$:ii::ii:l 293~7~ )ALANCE LAST STATEMENT I 208.98 429.08 25.00 GENERAL NONSUPV 5,174 CREDIT OAYS ~CCRUAL THIS PP 5.78 3.75 .00 .V REPORTED THIS PP 1.00 .00 .00 EMP MILITARY DAYS 0 CREDIT DAYS ~DJUSTNENTS .00 .00 .00 CREDIT DATE 09-28-01 ,ALANCE THIS STHT 213.76 432.83 15.00 tESSAGE CENTER: LOCAL RAGE TAX COUNTY/MUNICIPALITY: CUMBERLAND COUNTY NEW CUMBERLAND BORO FHT TAX GROSS: ~,229.06 WHAT: Pcnnsy]vania Employees Bencfit Trust Fund (PEBTF) Open Enrollmem WHEN: October 22, 2001 to Novcmbcr 15,2001 COVERAGE EFFECTIVE DAT]~: January 1, 2002 6PTIONS: Health Maintenance Organization (HMO) Option, Point-of-Service (POS) Option, Basic (Blue Cross/Blue ShieId/PEBTF Major Medical) Option, and Personal Choice Option (for employees in the 5-coumy Philadelphia area). MAILINGS: Watch your mail for PEBTF Open Enrollment materials. You may also receive materials from thc health plans. Please READ AND SA~ THE MATERIALS. . MELeTINGS: Plan to attend a Health Fair if one is held in your ar~a. The PEBTF Open Enrollment Newsletter will include a list of the health fairs. P£BTF'-2 FORM: If you wish to transfer to anoiher health care plan during the Open Enrollment, contact your local Human Resources Office to obtain a PEBTF-2 Form. You mast return the completed PEB'rP.2 Form lo your local Human Resources Oftiee no luler than November 15, 2001. QLIF.5-~ION$: Contact the PEBTF at 1-800-522-'7277 if. yot.t-have questions. GROSS EARNIF~" 1~293.75 27,050.4 PAY PERIOD ENDING: 08-31-0! PAY DATE: -14'-01 MINUS DEDI )NS VT#: ~90800940000 DEPT: 008 CDC: 0723. FED HTH TX H O0 147.16 3,147.8 SOC SEC TX 6.20000% 80.21 1,677.1 EHP#: 056704 POS#: 056629 SSN: 184-38-0275 SOC SEC/MED TX 1.45000~ 18.76 392.2 B/U: A! PAY RANGE: 04 STEP: 16 LEVEL: O0 STATE HTH TX PA 2.80000% 36.23 757.4. TRANSPORTATION DRIVER LICENSING LOC MG TX-RES PA 21 805 1.0000¢4 12.94 270.51 I" RET P/U CON STATE EMP 5.00000% 64,69 1,352.5; UN DUES AFSCME - 13 2534 19,41 358.3~ FED NTH TX-ADD 10.00 190.0( DIANE L GREENE 312 EUTAW STREET NEW CUMBERLAND PA 17070 NET EARNINGS: 904.35 HEALTH BENEFITS CAPITAL BLUE CROSS 190.00 ANN MED MOSP RET EMP HLTH PROG (REHP) 135.00 LIFE INSURANCE 3.39 HORKERS COMP 29.74 SOCIAL SECURITY 80.21 HEDICARE ~ 18.76 TOTAL STATE PAID BENEFITS $ 457.10 SERVICE CREDIT: 20 YR 25 PP )8-17--01 ANNUAL 7.50 08-31-01 REG SAL 75.00 17.25 1~293.75 )8-17-01 PERSONAL 7.50 ~LANCE LAST STATEMENT 204.92 421.58 22.50 GENERAL NONSUPV 5,154 CREDIT DAYS :CRUAL THZS PP 5.78 3.75 .00 F REPORTED TH!5 PP 7.50 .00 7.50 EMP MILITARY DAYS 0 CREDIT DAYS )JUSTMENTS .00 .00 .00 CREDIT DATE 08-31-01 ~LANCE THIS STHT 203.20 425.33 15.00 ESSAGE CENTER: LOCAL WAGE TAX COUNTY/I~JNICIPALITY: CLIItBERLAND COUNTY Flit TAX GROSS: 2~229.06 NEW CUMBERLAND BORO. COMMONWEALTH OF PA - EMPLOYE STATEMENT PAY PERIOD ENDING: 08-17-01 PAY DATE '8-31-01 VT#: 190800760000 DEPT: 008 CDC: 07~ . EHP#: 056704 POS#: 056629 SSN: 184-38-0275 B/U: A1 PAY RANGE: 04 STEP: 16 LEVEL: O0 TRARSPORTATIOR DRIVER LICENSING DIANE L GREENE 312 EUTAW STREET NEW CUMBERLAND PA 17070 HEALTH BENEFITS CAPITAL BLUE CROSS ANN NED HOSP RET EHP HLTH PROG (REHP) LIFE INSURANCE HORKERS CORP SOCIAL SECDRITY HEDICARE TOTAL STATE PAID BENEFITS 190. O0 135.00 3.39 29.76 80.21 18.76 457.10 SERVICE CREDIT: 20 YR 24 PP ;ALANCE LAST STATEHENT J 199.14 417.83 .CCRUAL THIS PP I 5.78 3.75 .Y REPORTED THIS PP ! .00 .00 ,DJUSTNENTS ! . O0 . O0 ALANCE THIS STHT J 204.92 421.58 ............ ::::::::::::::::::::::::::::::::::::: ::::::::::::::::::::::::::::: :::::::: ::::::::,.:::;: =============================================== ESSAGE CENTER: LOCAL HAGE TAX COUNTY/HUNICZPALITY: FHT TAX GROSS: GROSS EARNIP~" MINUS DED OHS FED NTH TX M oo SOC SEC TX 6.20000% SOC SEC/NED TX STATE NTH TX PA 2.80000% LOC HG TX-RES PA 21 805 1.00000% RET P/U CON STATE ENP 5.00000% UN DUES AFSCME - 13 2534 FED HTH TX-ADD NET EARNINGS: PLUS REINBURSEHENTS TOTAL DIRECT DEPOS 1,293.75 25,756.70 147.16 3,000.72 80.21 1,596.98 18.76 373.50 36.23 721.25 L2.94 257.56 64.69 1,287.83 19.41 338.97 lO.O0 1BO.O0 904.$5 08-17-0 REG SAL 75.00 i!i!i!: ?::J!;iii:.i:' :: ?~OTAL:~ GRO$ ~:.ii yARN I #G~ ;~! ~:PA 17.25 1,293.75 22.50 GENERAL NONSUPY J 5,144 CREDIT DAYS .00 .00 ENP HILITARY DAYS [ 0 CREDIT DAYS .00 CREDIT DATE / 08-17-01 22.50 CUHBERLAND COUNTY NEW CUMBERLAND BORO 1,229.06 2001 State Employ,e,e Combined Appeal )' I~/!!1~11~ % Your Support is truly A Gift from the Heart" .,- .... ~' ! ~ ' / ! ¥ ¥ ¥ ¥ ¥ ¥ ¥ '.'~ [- ~..~~!A Areyoua"G~idelineGi~er"? · .:. ', .,':,,.: ~; . e , . · . . [ ~ ou/~,ECA Coor&nator ca?, reform you how easy zt is to become one/ ' ~ ...... - *'"';*~ '~ ' mc~dki~ff: 09/12/2001 ¥ End of Solicitation Period: 10/24/2001 PAY PERIOD ENDING: 08-03-0! PAY DATE: 08-24-01 YT#: 190800670000 DEPT: OOR CDC: 07236 EMP#: 056704 POS#: 056629 SSN: 184-38-01r~ B/U: A1 PAY RANGE: 04 STEP: 16 LEVEL: O0 TRANSPORTATIOH DRIVER LICENSING DIANE L GREENE S12 EUTAW STREET NEW CUMBERLAND PA 17070 ~KERS COMP :IAL SECURITY )ICARE 3.97 10.70 2.50 GROSS EARNINGS MINUS DEDUCTIONS FED I,rl'H TX N O0 SOC SEC TX :6.20000% SOC SEC/HED TX 1.45000% STATE NTH TX PA 2.80000% LOC NG TX-RES PA 21 805 1.00000% iRET P/U CON STATE EHP 5.00000% NET EARNINGS: PLUS REIHBURSEMENTS 172.53 2~.5B lO.TO 2.50 4.83 !.73 8.63 219.56 24,~62.95 2,853.56 1,516.75 354.74 685.02 244.62 1,223.14 'OTAL STATE PAID BENEFITS 17.17 SERVICE CREDIT: 20 YR 23 PP SICK SICK FAMILY 7.50 3.00 OT-i.O OT-~.5 2.50 5.00 25.BB 43.23 129.40 ~NCE LAST STATEMENT 199.14 428.33 22.50 :UAL THIS PP .00 .00 .00 :EPORTED THIS PP .OD 10.50 .00 ISTMENTS .00 .00 .00 ,NCE THIS STNT 199.14 417.83 22.50 AGE CENTER: LOCAL NAGE TAX COUNTY/MUNICIPALITY: T TAX GROSS: 163.90 CONBERLAND COUNTY HEN CUMBERLAND BORO uunnu~w~Ll~ uk FA - E~PLOYE STATEMENT PAY PERIOD ENDING: 08-03-01 PAY DATE '9-17-01 VT#: 190800580000 DEPT: 008 CDC: 07, ENP~: 056704 POS#: 056629 SSN: 184-38-0275 B/U: A1 PAY RANGE: 04 STEP: 16 LEVEL: O0 TRANSPORTATION ORIVER LICENSING DIANE L GREENE 312 EUTAW STREET NEW CUMBERLAND PA 17070 HEALTH BENEFITS CAPITAL BLUE CROSS ! 190.00 ANN HED HOSP RET EHP HLTH PROG (REHP) 135.00 LIFE INSURANCE I 3.39 40RKERS COHP / 29.76 ;OCIAL SECURITY ' / 80 21 4EDZCARE ~ 18'76 TOTAL STATE PAID BENEFITS GROSS EARNIN-~ HINUS DEDL FED NTH TX H O0 !SOC SEC TX 6.20000% SOC SEC/RED TX 1.~5000% STATE NTH TX PA 2.80000% LOC NG TX-RES PA 2! 805 1.00000% RET P/U CON STATE ERP 5.00000% UN DUES AFSCHE - 13 2534 FED NTH TX-ADD NET EARNINGS: PLUS REIHBURSENENTS 1,293.75 14.7.16 80.21 18.76 36.23 12.94 64.69 19.41 10.00 904.35 24,290.42 2,828.98 1,506.05 352.24 680.19 242.89 1,214.51 319,56 170.00 SERVICE CREDIT: 20 YR 23 PP REG SAL 75.00 17.25 1,293.75 kLANCE LAST STATEHENT 193.36 424.58 22.50 GENERAL NONSUPV :CRUAL THIS PP 5.78 3.75 .00 ! R£PORTED THIS PP .00 .00 .00 EHP H!LITARY DAYS )JUSTMENTS .00 .00 .00 CREDIT DATE kLANCE THIS STMT 199.14 428.33 22.50 ESSAGE CENTER: LOCAL HAGE TAX COUNTY/MUNICIPALITY:. FHT TAX GROSS: 1,229.06 CUMBERLAND COUNTY NEH CUMBERLAND BORO 5,13~ CREDIT DAYS 0 CREDIT DAYS 08-03-01 GROSS EARNINr 1,293.75 22,996., PAY PERIOD ENDING: 07-20-01 PAY DATE: 03-01 MINUS DEDU< 45 · YT#: 1,90800400000 DEPT: OOB CDC: 07236 FED HTM TX M O0 147.16 2,681.J SOC SEC TX 6.20000% B0.21 1,425.l EMP#: 056704 POS#: 056629 SSN: 184-38-0275 SOC SEC/NED TX 1.45000% 1B.76 333., B/U: A1 PAY RANGE: 04 STEP: 16 LEYEL: O0 STATE HTH TX PA 2.80000% 36.23 643.. ~ 'RANSPORTATIO# DRIVER LICENSING LOC NG TX-RES PA 21 805 1.00000% 12.94 229.. '~ RET P/U CON STATE EMP 5.00000% gN DUES AFSCME - 13 2534 19.41 300.] IFED HTH TX-ADD 10.00 160.C DIANE L GREENE 312 EUTAW STREET NEW CUMBERLAND PA 17070 NET EARNINGS: 904.35 EALTH BENEFITS CAPITAL BLUE CROSS MN NED HOSP RET EMP WLTW PROG (REHP) 135.00 [FE INSURANCE 3.39 3RKERS COHP 29.74 )CIAL SECURITY 60.21 EDICARE 18.76 TOTAL STATE PAID BENEFITS $ 457.10 SERVICE CREDIT: 20 YR 22 PP '-'-06-0! SICK 7.50 07-20-01 REG SAL 75.00 17.2§ 1~293.75 ( :RUAL'ANCE THIsLAST ppSTATEMENT 187.585.7B 428.333.75 15.007.50 GENERAL NONSUPV 5~124 CREDIT DAYS REPORTED THIS PP .00 7.50 .00 EWP MILITARY DAYS 0 CREDIT OAYS IUSTWENTS .00 .00 .00 CREDIT DATE 07-20-01 ANCE THIS ST~T 193.36 424.58 22.50 TAX GROSS: WAGE TAX COUNTY/MUNICIPALITY: CUMBERLAND COUNTY 1,229.06 NEW CUMBERLAND BORO GROSS EARND' 1,250.25 20,001.( PAY PERIOD ENDING: 06-22-01 PAY DATE ,'-06-0! MINUS DED~ )NS VT#: 190800050000 DEPT: 008 CDC: 072.~ FED NTH TX M O0 140.96 2,329.~ SOC SEC TX 6.2000~ 77.52 2,240.] EMP#: 056704 POS#: 056629 SSA: 18¢-38-0275 SOC SEC/MED TX 1.4500~4 18.13 290.D5 B/U: A2 PAY RANGE: 04 STEP: 16 LEVEL: O0 STATE NTH TX PA 2.80000% 35.02 560.C I TRANSPORTATION DRIVER LICENSING LOC HG TX-RES PA 22 805 2.00000~ 22.50 200.c ' RET P/U CON STATE EMP 5.00000% 62.51 l,O00.O UN DUES AFSCME - 23 2534 28.75 26!.6 FED NTH TX-ADD IO.O0 140.0 DIANE L GREENE 312 EUTAW STREET NEW CUMBERLAND PA 17070 NET EARNINGS: 874.87 i:: STATE iPAiD 8ENE~tTS:i!:!i!i;i?ii:i!i?~HHi:::?!:iii!i!::H L::::il ::::..:ii:z:: ::: )i!ii:i!i!!!ii.!?!i!iiiiiiiiiiiiiiii!iiil;!i:i!?i:il: PLUS REIMRURSEHENTS qEALTH BENEFITS CAPITAL BLUE CROSS !89.97 ~NN NED HOSP RET EMP HLTN PROG (REHP) !35,00 -IFE INSURANCE 3.39 40RKERS COMP 28.76 ;OCIAL SECURITY 77.52 4EDICARE ~ 18.13 TOTAL STATE PAID BENEFITS $ 652.75 i:iii?!i!i?i!!~?~i~iii!iiii?i!ii!5!:~i!::~:::::!~ii~:~??!!~?~i~!~!PA:D~EAvE:S~A~:g~x:~ ...................... :::::: !iiii~!ilFiiii~TA~:DIREC'[!'DEPOSITiAMOLIfl'T il !i :iil;~::::$ ?i!?! 87~;S7 .... , · SERVICE CREDIT: 20 YR 20 PP ': ......... ::' ' ":'::'¥: .... ::::::::::::::::::::: 06-22-0 REG SAL 75.00 Z6.67 1,2J0.25 ~LANCE LAST STATEMENT 176.02 422.32 ZS.O0 GENERAL NONSUP¥ 5,!04 CREDIT DAYS :CRUAL THIS PP 5.78 3.75 .00 'REPORTED THIS PP .00 .00 .00 ENP MILITARY DAYS 0 CREDIT DAYS JUSTMENTS .00 .00 .00 CREDIT DATE 06-22-0! LANCE THIS STMT !81.80 426.07 15.00 TAX COUNTY/NUNICIPALITY: CUMBERLAND COUNTY NEM CUHBERLAN BORO FNT TAX GROSS: !,287.74 Current Mailing Address and Retirement Information ~lease remember to maintain your current, accurate ad&ess on file, The--Penmylvania Employees Benefit Trust Fund, the State ~:mployees' Retirement System, the Prudential Insurance Company of America, and the Commonwealth all use your ma/ling address :s listed on the Integrated Personnel Payroll System. - .:' ine the upper le/~ comer of this Employee Statement to verify that your address is correct for U. S. Post Office mail delivery. If it ~- .... correct, contact your local Human Resources offic.e to make the necessary changes. ly now, affected employees should have received in.formation from the State Employees' Retirement System (SERS) regarding the e-c-efitly~nactei:l pension-legislat/on,-Act-2001~.9. If~o~a'-~"l~ affected by the new pension legislation and have not yet received an lection form. ~lease contact SERg imrnediat,:lv. COMMONWEALTH OF PA - E'I~'I. 0YE STATEMENT PAY PER~OD ENDING: 02-01--02 PAY DATE: 02-15-02 VT#: 190802910000 DEPT: ROE CDC: 07236 EMP#: 05&70~ POW: 0~6629 SSI/: 1S4`-38-0275 B/U: AZ PAY RANGE: 04 STEP: 17 LEVEL: O0 TRANSPORTATION DRIVER LZCENSZND DIANE L GREENE 12 W PZNE STREET ENOLA PA 17025 HEALTH BENEFITS AH# HED HOSP LEFE INSURANCE HORKER$ COK" NEDICARE CAPITAL GLUE CROSS RET EMP HLTHPROG (REHP) 290,00 135 · O0 S.BO 30.43 ........ G2.-07- 19.19 SERVICE CREDIT: Gl YR 10 PP GROSS EARNINGS HINUS DEDUCTEDNS FED NTH TX M O0 SOC SEC TX 6.20000% SOC SEC/MED TX 1.46000',~ STATE NTH TX PA 2,800G0% LOC ND TX-RES PA 21 909 RET P/U CON STATE EMP 6.25000~ ~ANKRPTCY ORDER C DEHART Ill-HID DIST PA UN DUES AFEOJE - 13 253~ FED HTH TX-AO0 NET EARNINGS: PLUS REIHBURSEHENTS 1,323.75 125.85 82.07 19.19 37,07 13.24` 82.73 107. O0 19.86 10. O0 826.74, 54~.0G 346.20 80.96 15&.37 34`6,99 4`28.00 40.00 REG GAL 17,65 1,323.75 BALANCE LAST STATEMENT 229.00 ~.83 ACCRUAL THIS PP ~.7N 3.75 LY 'REPORTED TH~S PP .00- .00 ADJUSTHENTS ,00 .00 BALANCE THIS STNT 234.78 4~9.58 MESSAGE CENTER: LOCAL RAGE TAX COUNTY/MUNICIPALITY: FNT TAX GROSS: ,00 GENERAL NONSUPV 7.50 · .00 EHP MILITARY DAYS .GO CREDIT DATE 7.50 5,2G~ CREDIT DAYS O CREDIT DAYS 02-01-02 CUNBERLARD COUNTY EAST PENNSBORO TNP, 'CORRONWEALTH OF PA - Et'~OYE STATERENT PAY PERIOD ENDING: 03-01-02 PAY DATE; 03-15-02 VT#: 190803270000 DEPT: OON CDC: 0723S EHP#: 054704 POS#: 056629 SEN: 184-3S-0275 B/U: A1 PAY RANGE; 04 STEP: 17 LEVEL: O0 TRANSPORTATIO# DRIYER LICENSING DIANE L GREENE t2 W PINE STREET ENDLA PA 17025 HEALTH BENEFITS CAPITAL GLUE CROSS AHN HED HOSP RET ERP HLTH PROS (REHP) LIFE INSURANCE NORKERS COMP SOCI ~ S'ECUR~TY - - ................ NEDICARE TOTAL STATE PAID BENEFITS SERVICE CREDIT= 22 YR 12 PP 190,00 1~ · DC 3,60 30.43 -$2~ 07- - 19.19 $ ~0.29 GROSS EARNIRGE MINUS DEI~TZON$ FED WTHTX M O0 SOC EEC TX 6,20000% EDC SEC/NED TX 1.45000% STATE NTH TX PA 2.80000% LOC NG TX,RES PA 21 909 1.00000% RET P/U CON STATE EI4P E.25OD0% BANKRPTCY ORDER C DEHART III-MID DIET PA UN DUES AFSCHE - 13 253~ FED NTH TX-AED NET EARNINGS: PLUS REIMBURSEMENTS 125.85 82.07 19.19 37.07 13.24 02.73 107.00 19.86 G2&.74 045.42 532.22 124.46 240.39 G~.G8 536.51 11B.26 60.00 REG S/iL 17.65 1,323.75' BALANCE LAGT STATENENT 2~0.06 453.33 ACCRUAL THIS PP 5.7G ..3.7~ L¥ REPORTED THIS PP .00 .DC ADJUSTHENTS .DU .00 BALANCE THIS STHT 23~5.N4 ~'7.0~ ~.$0 GENERAL BOMSUPV .00 · DO F~P 'MILITARY DAYS · DU CREDIT DATE 7.50 5,284 CREDIT DAYS 0 CREDIT OAYS OG-Oi-0S HESSAGE CENTER: LOCAL NAGE TAX COUNTY/NUNICIPALZTY: CUNBERLANO COUNTY EAST PEN#SEDRO TNP. FNT TAX GROSS: 1~241.02 ~OSS EARNINGS 1,323.7~ 7,08~.3~ PAY PER~ ENDING: 02-15-02 PAY DATE: 03~1-02 H;NUS DEOU~ZOHS VT~: 19080309~ DEPT: ~8 ~C: 072~ F~ N~ TX H O0 125.85 69~.7~ S~ SEC TX 6.2~ 82.07 ~39.22 EHP~: ~670& POSJ: 056629 SSN: ~-38-0275 S~ SEC~ED TX 1.~ 19.~9 102.71 B/U: A1 PAY ~E: ~ STEP: 17 LEVEL; ~ STATE ~H TX PA 2.8~ ~.07 198.38 T~NSPORTATIOH ~IVER LICEffSI~ L~ ~ TX-RES PA 21 909 1.~ ~3.2& 70.87 RET P/U ~ STATE ~P 6.25~ 82.73 IA~RPTCY O~ER C DE~RT ~II-KID DIST PA 107.~ UN DUES AFSCHE - 13 25~ 19.86 FED ~H TX-~D 10.00 50.00 DZANE L GREENE ~2 W P~NE STREET ENOLA PA 17025 NET EARNZNGS: 826.7~ H~LTH BENEFZTS ~PZT~ BLUE ~S ANN N~ HOSP RET E~ HL~ PR~ (R~) l~.OO LIFE ZNS~ANCE N~ZCARE 1~. 19 TOTAL STATE PAZD 8ENEFZTS $ SERVZCE ~ZT: 21 YR 11 PP '02-1~2 REG SAL 75.~ 17.&~ 1,323.T5 BA~NCE ~ST STATENE~ 227.~B ~9.58 7.~0 GENE~L ~SUP. V 5~27~ ~T OAYS ~CRUAL TH~S PP 5.78 3.7~ L~ REPORTED TH~S PP .~ .~ .00 ~P N~L~TA~ DAYS 0 CR~T DAYS ~dUSTHENTS .~ .~ .~ CREO~T DATE 02-1~ BA~NCE ~S ST~ 233.06 ~3.33 7.50 MESSAGE CENTER: L~L NAGE T~ ~/N~ZCZPALI~ C~BERLAND C~NTY EAST PENNSB~O TNP. F~ T~ GROSS~ Event Calendar 2002 January 1 NewYea~s Day 21 Martin Luther King, Jr., Day February 2 Groundhog Day 12 Lincoln's Birthday 12 Mardi Gras 13 Ash Wednesday 14 Valentine's Day 15 Susan B. Anthony Day 18 President's Day 22 Washington's Birthday March 17 St. Patrick's Day 20 Spring Begins 24 Palm Sunday 28 Passover 29 Good Friday 31 Easter Sunday April 1 April Fool's Day 7 Daylight Saving Begins 26 Arbor Day May 5 Cinco de Mayo 7 National Teacher Day 12 Mother's Day 18 Armed Forces Day 22 National Maritime Day 23 DIANE VACATION 24 DIANE VACATION 25 DIANE VACATION 26 DIANE VACATION June 14 Flag Day 16 Father's Day 21 Summer Begins July 4 Independence Day August September 2 Labor Day 7 Jewish New Year (Rosh ... 16 Yom Kippur 17 Citizenship Day 22 Autumn Begins October 14 Columbus Day 24 United Nations Day 27 Daylight Saving Ends 31 Halloween November 5 Election Day 11 Veterans Day 28 Thanksgiving Day 30 Hanukkah December 21 Winter Begins 24 Christmas Eve 25 Christmas Day 31 New Year's Eve AnyTime Year Event Calendar Printed March 19. 2002 i/ SUBUECT: 2001 FEDERAL TAXABLE WAGES 008-01115 TO: DIANE L GREENE 12 W PINE STREET ENDLA PA 17025 008-2-183-7200-1 07236 184-38-0275 058704 056629 The amount of Federal Taxable Wages shown in Block I of the attached W2 statement for most employee may differ from the amount of Gross Earnings you received during the calendar year. Any difference is a result of one or more of the adjustments explained and calculated below: If you have any questions, please contact your Personnel Office. * * * * * * * * * CALCULATION SUMMARY * * * * * * * * * GROSS EARNINGS MINUS: * RETIREMENT PICKUP CONTRIBUTIONS (Non Heart & Lung, or Act 534/632 Earnings) ....... EQUALS: FEDERAL TAXABLE WAGES * * * SEE BACK FOR ADDITIONAL INFORMATION * * 37,141.B8 1,857.13 35,284.75 nployer's Identification Number !3-2172299 nployer's name, address, and ZIP code :ONNONWEALTH OF PENNSYLVANZA )EPARTNENT OF TRANSPORTATZON ~ARRZSBURG PA 17120 Control Number 008-0111B nployee's Social Security Number 184-38-0275 nployee's first name and initial Last name )Z/UqE L GREENE 12 W PZNE STREET !NOLA ~A 17025 ,e's address and ZIP code 3 Social security wages 37, 141.88 Medicare wages and tips 4 Social security tax withheld 2,302.84 Medicare tax withheld 37,141.88 11 Nonqualified plans 13 Statutory Retirement Third Party employee Plan sick pay 538.58 10 Dependent care benefits 12 See Instructions tot Box De admenl of the Treasury - Internal Revenue Service Stateraent2001 COPY C - FOR EMPLOYEEtS RECORDS(SEE NOTTCE ON BACK OF COP~P B) OUSNo. lS4S.0Oea on n f I d I Ii1 al e Exhibit 3 Wife's 2001 Federal & State returns Department of the Treasury -- Iht' Revenue Serv¢~e Fo..' 1040 U.S. Individual Income Tax Retum 2001 Label Use the IRS label. Otherwise, please print or type. Presidential Election Campaign (See instructions.) Filing Status i For the year Jan ! - Dec 31, 2001, er other tax year beginni~l your First Name MI Last Name Diane L Greene If a Joinl Return, Spouse's First Name MI Last Name ending irs use only -- Do not write or staple in this space. , 20 OMB No, 1545-0074 Your 'C~5_.'_-! Secu ~,,y Number 184-38-0275 Spouse's ~ Secm~ty Number 207-44-5552 Home ~dr~ (n~r a~ st~0. If You ~ve a P.O. ~x, S~ Instr~t~o~. Apa~nt ~. 12 N. P~ne St. City, Town or Post Office. If You Have a Fore,jrt Address, See Instructions. Eno[a State ~P Code PA 17025 · Important! · You must enter your social security number(s) above. Note: Checking 'Yes' will not change your tax or reduce your refund. You Do you, or }~3ur spouse if filing a iointreturn, want :$3 to 9o to this fund? ......... ~ ~--] Yes ~'~ No 1 2 3 Check only 4 one box. 5 dependent, enter this child's name here ~ V -] Qualif'/incj widow(er) with dependent child (,year spouse died ~' ). (See instructions.) Exemptions 6a ~ Yourself. If your parent (or someone else) can claim you as a dependent on his or -'~ her tax return do not check box 6a b [-~ Spouse.. ......................................... --~- No.a~ ~n~ a= .... __1 children on Spouse ~--~ Yes ~'-~ No Single Married filing joint return (even if only one _h, ad income) Married filing separate return. Enter spouses SSN above & full name here ... ~ RobeFt Greene Head of household (with qualifying person). (See instructions.) If the qualifying person is a child but not your c Dependents: (2) Dependent's (33 Dependent's (4) V'~ ~c who: socia/security relationship I qualifying · lived number to you ; child for child tax credit with you ..... (1) First name Last name (see ins~) · did.at due ~o dJ~m:e SiX dependents, __ eflte~d abow . d Total numbe, of e~emptions claimed ? Wages, salades, tips, etc. ~ttech Form(s) W-2 ......................................... i ? 35,285. Income 8a Taxable interest. Attach Schedule B ff required ......................................... 8a Attach Forms b Tax-exempt interest. Do nat include on line 8a ............. W-2 mid W-2G 90rdinar~ div{dends. Affach Schedule B if required ' 9 here. Also attach ...................................... Form(s) 1099-R if 1G Taxable refunds, credits, or offsets et state and local income taxes (see' insb~ucfiens) .... 10 tax was withheld. 11 Alimony received .................................................................... 11 If you did not 12 Business income or (loss). Attach Schedule C or C*EZ ................................. 12 igeta W-2 see 13 Capita~gainnr(Ioss).A~chScheduleDifrequired. lf not require~, check here ........... ~" [] 13 nstructions. 14 Other gains or (losses). Attach Form 4797 15a Total IRA distributions .... [ 15, .............. b* ~;~;l~i; ~r~;r~t' i;~-~'i;l~i;;)':: 14 15b 16a Total pensions & annuities : 15a I b Taxable amount (see instrs) .. 16b 17 Rental real estate, royalties, pad~erships, S corporations, trusts, etc. Attach Schedule E . 17 Enclose, but do 18 Farm income or (loss). Attach Schedule F ............................................. 18 not attach, any 19 Unemp;oyment compensation payment. Also, ' ....................................................... 19 please use 20a Social securk~ benefits ...... I 26al I b Taxable amount (see instrs) .. 20b Form 1040-V. 21 0thor income 21 22 Add the amounts in the far right column for lines 7 through 21. This is ~t~t~ ~n-~-i~e ~' 22 35 ~ 285. 23 IRA deduction (see instructions) ........................... 2~ , Adjusted 24 Student loan interest deduction (see instructions) ........... 24 Gross 25 Archer MSA deduction. Attach Form 8853 ................. Income 25 I 26 Moving expenses. Attach Form 3903 ...... 26 27 One-half of self-employment tax. Attach Schedule SE ....... Z7 28 Self-employed heaJth insurance deduction (see instructions) .. 28 29 Self-employed SEP, SIMPLE, and qualified plans ........... 29 30 Penalty on early withdrawal of savings ..................... 31 a Nimoey paid b Recipieflt~ SSN .... ~' .. 32 Add lines 23 thr0u0h 3!a ....... ~ Subtract line 32 trom'l;ne 2~.' Lr~i; i~ ~'~)~; ad~;~t~d ~'r~-,~ il~;e 32 ...................... ~ ~ 35,285 BAA For Dtsdosure_ PHv~,'.u &ri ..~11~.~.4. ~.,d...~:.- · ~ ~m-~ ...... ' .................... ' Act Notice, see instructions. FDIA0112 12/10101 Form 1040 (2001) s~.~edule J~ Miscellaneous Itemized Deductions Statement 2001 Lines 20, 22, 27 "" Attach to return (after all IRS forms) Statement Name(s) Shown on Return Diane L Greene Social Security Number 184-38-0275 Employee Business Expenses - Subject to 2% Limitation Deductible expenses from Form 2106, line l0 less deductions for performing artists and handicapped employees claimed elsewhere ........... Other unreimbursed employee business expenses: Union and professional dues .................................................. Professional subscriptions ................................................... Uniforms and protective clothing .............................................. Job search costs .............................................................. Other: 3 Combine lines ] through 2e (to Schedule A, line 20) .......................... Miscellaneous Expenses - Subject to 2% Limitation Investment Check the box in investment column if an investment expense expense 4 Depreciation and amortization deductions .............................. 5 Casualty/theft losses of property used in services as an employee ....... 6 REMIC expenses, from Schedule E .................................... 7 Investment expenses related to interest and dividend income ......... 8 Expenses related to portfolio income, from Schedule(s) K.1 ............ 9 Miscellaneous deductions, from Schedule(s) K-1 ........................ 10 Excess deductions on termination, from Schedule(s) K-1 ............... 11 Other deductible expenses: a Investment counsel and advisory fees .................................. b Certain attorney and accounting fees c Safe deposit box rental fees ............................................ d IRA custodial fees ..................................................... · Tax preparation software and tax publications ........................ f Other: 1 2a 3 1,600, O0 12 Combine lines 4 through 11f (to Schedule A, line 22) ............ .............. Other Miscellaneous Deductions - Not Subject to 2% Limitation 13 Federal estate tax paid on decedent's income reported on this return ........ ' l 15 ~ 14 Impairment-related expenses of a handicapped employee, from Form 2106..I 14 15 Amortizable bond premiums on bonds acquired before ]0/23/86 .............. 15 16 Gambling losses .............................................................. 16 17 Casua/ty/theff losses of income-producing property ........... i .........: ..... 17 18 Other: 19 Combine lines 13.18 (to Schedule A, line 27) ............................... 19 1,600. O0 Diane L Greene 184-38-0275 Page? Tax and 34 Amount from line 33 ('" ' sled gross income) ...................................... I 34 35,285. Credits 3~a Check if: E~¥ouwe~65/older, [--~Biind; [--~Spousewas65/older, [_j~31ind. IStandard · Add the number of boxes checked above and enter the total here ............ "35a~ I b If you are married filing separately and your Spouse itemizes deductions, ~ I ~erdUCfi°n L or you were a dual-status alien see instructions and check here ~" 35b L__J - People who 36 Itemized deducUar~ (from Schedule A) or your standard dedudien (see left matin) .................... 36 7,830. checked any box -~7 Subtract line 36 from line 34 Eon line 35a or ......................................................... 37 27,455. ,35b er who can 38 if line 34 is $99,725 or less multiply $2,900 by the total number of exempt ohs claimed 'be claimed as a on line 6d. f ne 34 is over $99,725, see the worksheet in the instructions ............... 38 2,900. ' dependent see 39 Ta~le income. Sul~act line 38 from line 37. instructions, If tine 38 is mere than line 37, enter -0-. ...................................................... 39 24,555. 40 Tax (see inet). Check if any tax is fnma [] Form(s) 8814 13 [] Form 4972 ........................ 40 3,933. · All others: Single: 41 Alternative minimum tax (see instructions). Attach Form 6251 .......................... 41 $4,550 ! 42 Add lines 40 and 41 ............................................................... ~ 42 3,9_33. Head of 43 Foreign tax credit. Attach Form 1116 if required ............. household, i 44 Credit for child and depmldont care exl~ses. Attach Form 2441 .......... i 44 $6,650 45 Credit for the elderly or the disabled. Attach Schedule R ..... 45 Married filing 46 Education credits. Attach Form 8863 ....................... 46 ~ointly or uahfying 47 Rate reduction credit. See the worksheet .................. 47 widow(er), 48 Child tax credit (see instructions) 48 $7,600 ......................... 49 Adoption credit. Attach Form 8839 ......................... 49 Married filing 50 0thercredits from a [~Form3~0 b E~Form~396 $3,800: separately, c [] Form 88~I d La Form (specify) 50 51 Add lines 43 through 50. These are your total c~dits ............................................. 51 52 Subtract fine 51 from fine 4,?., If line 51is more than line 42, entar.0.. ............. m,- 52 3t933. 53 Sdf-employmonttax. Attach Schedule SE ...................................................... 53 Other 54 Social security and Medicaretax mt Up incame not reported to employer. Attach Form 4137 ................. 54 Taxes 55 Tax on qualified plans, including IR~s, and nthe~ fax.favored amounts. Attach Form 5329 if required ........... 55 56 Advance eemed income credit payments from Form(s) W-2 ............................. 56 57 Household employment taxes. Affach Schedule H ...................................... 57 58 k[ldlinesSZ-57. Thisisy0urt~taltaz ......................... m, 58 3,933. '%~yments 59 Federal income tax withheld from Forms W-2 and 3099 ..... 59 4,585. you have a I 60 2~01 estimated tax payments and amount app/ied from 2(~0 retorn ....... 60 qualifying -- 61 a Earned income credit (EIC) ............................... 61a child attachF b Nontaxable earned income ....... ] 61 bi Schedule EIC. 62 Excess social security and RRTA tax withheld (see instrs) . .. 62 63 Additional child tax credit. Attach Form 8812 ................ 63 64 Nnount paid with r~quest for estonsion to file (see instructions) .......... 64 65 Other payments. Check if from ..... a [] Form 2439 b [] Form 4136 ......................................... 65 FDIA0112 12./10/O1 66 Add lines 59, 60, 61a, and 62 through 65. These are your total payments ~, 66 4 585 Refund 67 If line 66 is more than line 5~, subtract line 5~ from line 66. This is the amonet you oveq~aJd .............. 67 6 52. Direct deposit? 68a Amount of lille 67 you want refunded to you ........................................ ~- 68a 652. See instructions ~ b Routing number.. 231372387 .- c Type: [] Checking [] Savings and fill in 68b, ' ..... 68c, and 68d. ~' dAccount number ....... 0100312230 69 Amonntofline67youwantap~liedte~lourZOOZedima~dta~ .... Amount 70 Amountyou owe. Subtract line 66 fr~m line 58. For details on how to pay, see instructions ............... ~ 70 YOU Ovl/e 71 Estimated tax penalty. Also include on line 70 ......... Third Party Do you want to allow onoth~ per~on to disca~ this r~rn ~ ~e IRS (sm insffu~ons)~ ........ ~ Yes. Complete t~ foll~ing. ~ No De~gnee D~ig~'s P~ Pemonal Ident~tion Sign Hem ....... ' ........ ~rrech a~ ~mpmte. ~cl~a[l~ 0i preparer tother ~n t~ayer) is based on all i~r~[ion of ~ich preparer h~ any ken. edge. Joint return? Your Sig~ture ~ Date Your ~alion Da~ime Pho~ Numar See instructions. K~p a copy for your records. ~ j ,:, r. Preparer's D~e~ck Pre.rat's SeN or P~N '~_ ,'epam~s Fin', Nam Self-Prepared (or~um Use Only ~d~, ~P ~de Phone Ne. Form 1040 (2001) Schedule A ~merna~ Revenue Service (~) Name(s) Shown or~ Form 1040 Itemized Deductions "' Attach to Form 1040. See Instructions for Schedule A (Form 1040). OMB No. 15~5-0074 2001 07 Your Secial Secu~t~ Numbar iane L Greene 184-38-0271 Medical Caution. Do not include expenses reimbursed or paid by others. and 1 Medical and dental exp~qses (see ins~ucti0ns) 1 Dental .......................... Expenses 2 Enter amount from Form i040, line 34 ..... J 2 J 3 Multiply line 2 above by 7.5% (.075) .......................... 4 Subtract line 3 from line 1, If line 3 is more than line 1, enter -0- . ................ 4 Taxes You 5 State and Iocat income taxes ................................. 5 1,3 5 3 Paid 6 Real estate taxes (see instructions) ........................... i 6 700 ?ee 7 Personal property taxes ...................................... 7 220 nstructions.) 8 Other taxes. List type and amount ,- I 9 ~dd line~'5-th-rough 8 ...... ................................................................... 9 2,273. Interest 10 Home n~O im'erest and points r~oi~ t~ you on Form 1098 10 4, $00. You Paid ................ 11 .Home ,mortgage !nt~r~t not mpor~ In ~u on Form 1098. ft i~id t~ the ~oo ~rom whom you oought the home, see instru~ons and show that person's name, ide~tifyiog numbe~, and address .- (See instructions.) ............................... : ---::: ................ ::: ...... Note, 11 Personal 12 Peint~'.~ r-~P~d~ t~ YO~- o-~ F'~r~ TO~. See i~"~'s for al~ rules ............ 12 interest is not 13 Inv~tmeet intemsL At'ach Form 4952 if required. deductible. (See inst~.) ................................................... 13 14 Add lines 10 through 13 ................................................................. 14 4,500. Gifts to 15 Gifts by cash or check. If you made any gift of $250 or more, ~ Charity see instructions ............................................. 15 130 'ou made 16 Other than by cash or check. If any gift of $250 or . gift and ' ~ got a benefit more, see instructions. You must attach Form 8283 if tor it see over $500 .................................................. 16 l nstructions. 17 Carryover from prior year ..................................... 17J 18 Add lines 15 through 17 ................................................................. 18 ].30. Casualty and Their Losses 19 Casualt7 or theft loss(es). Attach Form 4684. (See instructions.) ............... 19 Job __Exp~r,~,g$ 20 Unreimbursed employee expenses -- job travel, union dues, and Most job education, etc. You must attach Form 2106 or 2106-EZ Other Miscellaneous if required. (See instructions.) Deductions .............. :: 20 21 Tax preparation fees ......................................... 21 33. (See 22 Other expenses - investment, safe deposit box, etc. List instructions type and amount for expenses ............... to deduct See Statement 1T~'0-0~ 22 1,600 here.) 23 Add lines 20 through 22 2~ l, 633., 24 Enteramountfr0mF0rmlO40, line34 ..... J24 J 35,285.J 25 Multiply line 24- above by 2% (.02)J2:5 706, 26 Subtract line 25 from line 23. If line 25 is more than line 23, enter -0- . ...................... 26 927. Other 27 Other - from list in the instructions, List type and amount .. Miscellaneous ................ Deductions 27 Total 28 Is Form 1040, line 34, over $132,950 (over $66,475 if MFS)? Itemized Deductions [] No. Your deduction is not limited. Add the amts in the far right col for lines 4 through 27. Also, enter this amt on Form t C:~-O, line 36. L [] Yes. Your deduction may be limited. See instructions for the amount to enter.J 28 i , 7,830. BAA For Paperwork Reduction Act Notice, see Form 1040 instructions, FDIA0301 mm7102 Schedule A (Form 1040) 2001 ROBERT F. GREENE, Plaintiff IN THE COURT OF cOM~MON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · DOMESTIC RELATIONS SECTION DIANE L. GREENE, Defendant PACSES NO. 361104107 NO. 1073 SUPPORT 2001 INTERIM ORDER OF COURT AND NOW, this ~--~'f---~ day of April, 2002, upon consideration of the Support Master's Report and Recommendation, a copy of which is attached hereto as Exhibit "A", it is ordered and decreed as follows: The Plaintiff's claim for spousal support is denied, and his complaint is dismissed. The parties are hereby advised that they may file written exceptions to the Support Master's Report and Recommendation within ten (10) days of this order. Exceptions shall conform with the requirements of Rule 1910.12(0, Pa. R.C.P. If written exceptions are filed by any pady, the other party may file exceptions within ten (10) days of the date of service of the original exceptions. If no exceptions are filed within ten (10) days of this interim order, this order shall then constitute a final order. By the Court, CC: Robert F. Greene Diane L. Greene James L. McAneny, Esquire Diane G. Radcliff, Esquire DRO Exhibit 4 Support Order ROBERT F. GREENE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION DIANE L. GREENE, Defendant · PACSES NO. 361104107 · NO. 1073 SUPPORT 2001 SUPPORT MASTER'S REPORT AND RECOMMENDATION Following a hearing held before the undersigned Support Master on March 25, 2002, the following report and recommendation are made: FINDINGS OF FACT 1. The Plaintiff is Robed F. Greene, who resides at 312 Eutaw Street," New Cumberland, Pennsylvania. 2. The Defendant is Diane L. Greene, who resides at 12 West Pine Street, Enola, Pennsylvania. 3. The parties are husband and wife having married on February 2, 1977. 4. The parties separated on or about October 6, 2001, when the Defendant left the marital residence. 5. The Plaintiff filed a complaint for spousal support on December 17, 2001. The parties have three grown daughters. The Defendant has two older children from a prior marriage, a son and a daughter, both of whom resided with the parties throughout the marriage. The Plaintiff had a significant alcohol problem throughout the marriage. The Plaintiff was physically and mentally abusive to the Defendant and the children throughout the marriage. Examples of this abuse are as follows: A. The Plaintiff punched his wife in the stomach when she was pregnant with the parties' middle child. B. The Plaintiff repeatedly threw objects at his wife and the children, to include beer cans, ashtrays, and dishes. Exhibit "A" C. The Plaintiff disciplined the children by paddling them with a wooden board upon which was carved the words "Thy Rod," frequently causing welts and bruises on their backs, buttocks, and upper legs. D. The Plaintiff repeatedly referred to his wife, his stepdaughter, and his daughters as "bitch, ""slut," and "whore." E. The Plaintiff on one occasion struck his daughter, Jessica, Jn the head with a spatula causing her to bleed. F. The Plaintiff frequently required his daughters to bring him cans of beer while he was sitting on the toilet. G. On one occasion the Plaintiff required his daughter, Jessica, to sleep in a bed covered with pieces of broken glass. H. The Plaintiff repeatedly abused the family pets in the presence of his wife and children. I. On one occasion the Plaintiff threatened his wife and his daughters by pointing a rifle or shotgun at them, repeatedly cocking it, and saying that he would "take them all out." J. The Plaintiff repeatedly told his daughters and his wife that he regretted having had girls. K. The Plaintiff on repeated occasions dragged the children out of bed in the night, lined them up against a wall, and harangued them. L. The Plaintiff on one occasion threw his stepson down a flight of stairs. M. The Plaintiff on one occasion punched his wife as a result of which she sustained broken ribs. N. The Plaintiff frequently struck his wife causing bruises on her face and neck. O. The Plaintiff on one occasion pulled hair out of his wife's head during an argument. P. Over a period of approximately nine years the Plaintiff sexually abused his stepdaughter by forcing her to masturbate him, by ejaculating into her mouth, and by attempting anal intercourse. 10. The Plaintiff had been a master mechanic for several automobile dealerships until July, 2000, when he quit. 11. The Plaintiff began seeing a psychiatrist in 2000. 12. The Plaintiff began taking Zoloft, a medication prescribed for anxiety and depression. 13. In November, 2000, the Plaintiff began employment with a property maintenance company but quit after seven months. 14. In the summer of 2001 the Plaintiff with the encouragement of his wife began counseling with New Insights. 15. The Plaintiff quit counseling failing to complete the "12 step program." 16. In September, 2001, the Defendant's daughter, Deanna Faison, for the first time informed the Defendant about the incidents of sexual abuse that had occurred in the past. 17. 18. 19. 20. 21. 22. 23. 24. 25. When the Defendant confronted her husband with the information she had received from her daughter, the Plaintiff stated only that the daughter "would have to prove it." He did not deny the accusation. Shortly after this confrontation, the Defendant moved from the marital residence. In December, 2001, the Plaintiff told his daughter, Jessica, that he was "banging three broads now." On or about December 10, 2001, the Defendant went to the marital residence to exchange items of personal property with the Plaintiff. When she arrived three women were at the home with the Plaintiff. In December, 2001, the Plaintiff began having another woman, who he referred to as his "cleaning lady" stay overnight in the marital residence. This occurred two to three times per week. After the separation but prior to the filing of his complaint, the Plaintiff had sexual relations with a woman, not his wife. Prior to the separation, the Plaintiff began operating a property maintenance service as a sole proprietor, but he has had no income from that business since September, 2001. The Plaintiff has been living off of his pension fund when he quit Sutliff Automotive in July, 2000. The Defendant is gainfully employed with the Commonwealth of Pennsylvania. DISCUSSION In Pennsylvania a dependent spouse is entitled to support until it is proven that conduct of the dependent spouse constitutes grounds for a fault divorce and the party seeking to nullify the obligation bears the burden of proving the conduct claimed by clear and convincing evidence. Crawford v. Crawford, 633 A.2d. 155 (Pa. Super. 1993). Indignities are one of the grounds for a fault divorce. 23 Pa. C.S. Section 3301(a)(6). For indignities to lie, the proponent must not only prove a course of conduct by his/her spouse which made the proponent's life intolerable and his/her condition burdensome, but also that the proponent was the innocent and injured spouse. Beaver v. Beaver, 460 A.2d. 305 (Pa. Super. 1983). The Defendant presented credible testimony that her husband over a period of years was both physically and mentally abusive to her and her childl~en. Her testimony was supported by credible testimony by two of her daughters. Although denying that he committed any such abuse, the Plaintiff argues that if these acts were committed, they were done while he was intoxicated and, therefore, cannot constitute indignities. While it is true that many of the incidents occurred while the Plaintiff was consuming or had consumed alcohol, indignities committed while a party is intoxicated are not excused and can be a valid ground for divorce. Schrock v. Schrock, 359 A.2d. 435 (Pa. Super. 1976). Likewise, mistreatment of a spouse's child is an indignity to the child's parent and, thus, is a ground for divorce. McCaskey v. McCaskey, 385 A.2d. 378 (Pa. Super. 1978). The Plaintiff argues further that the incidents complained of occurred so far in the past that they cannot now be considered grounds for divorce. In essence the argument is that the Defendant should have left her husband when the acts occurred if they are to be considered indignities. When the party claiming the indignities is physically and financially able to leave the common residence but fails to do so, that factor may be considered in determining just how "intolerable" and "burdensome" her life was. Coxe v. Coxe, 369 A. 2d. 1297 (Pa. Super. 1976). While it is true that the Defendant did not pack up her children and move out when the abuse was a more common occurrence, the proverbial straw that broke the camel's back came when the Defendant first learned of the incidents of sexual abuse that the Plaintiff inflicted on her daughter in the 1980's and her husband's reaction when confronted with the allegations. The Defendant, quite simply put, could no longer tolerate being in her husband's presence after acquiring the knowledge of his past conduct. The testimony of the complaining witness, the Defendant's daughter Deanna, was credible as was the Defendant's testimony describing the Plaintiff's reaction when confronted by his wife. The testimony of the Defendant and her daughters supports a finding of indignities. The record is devoid of any allegations by the Plaintiff that his wife was not the "innocent and injured spouse." Consequently the Defendant has met her burden by clear and convincing evidence that her husband is not entitled to spousal support. In addition to the foregoing the record supports the fact that the Plaintiff has forfeited his right to spousal support by adulterous conduct after the separation. An order of support may be refused or vacated where the Claimant is guilty of infidelity. To sustain such a charge, however, the proof must be clear and convincing. Suspicion or speculation alone will not be sufficient. Commonwealth ex rel. McCuff v. McCuff, 175 A.2d. 124 (Pa. Super. 1961). While the Plaintiff was not physically caught with his pants down, the parties' daughter, Jessica, testified that he had stated in December, 2001, that he was "banging three broads now." This testimony was credible, especially when three women were present with the Plaintiff in the marital residence when the Defendant appeared there to exchange property on or about December 10, 2001. Further the Plaintiff's testimony that he had a "cleaning lady" come 2 or 3 times per week, and that the "cleaning lady," a local resident, paid rent to him to sleep overnight in his home is so unbelievable as to be ludicrous. Despite the Plaintiff's denial of having sexual relations with any woman since the separation from his wife in September, 2001, a finding has been made that the Plaintiff has forfeited his right to support by having sexual relations with a woman, not his wife, following the separation. RECOMMENDATION The Plaintiff's claim for spousal support is denied, and his complaint is dismissed. Date' Michael R. Rundle Support Master k~AY-I~-7OOZ t 0:09A~I FR0~CORR£CT101~$ GMAC MORTGAGE CO~,P' ~,~T][O~ Plaintb,, ROBERT F. G1EEENE DIANE L. GREENE Defendant(s). TO: ROBERT F. GREENE 312 EUTAW AVENtlE NEW CUMBERLAND, PA 17070 +7]~0~1 T-~S~ ~ OOZ/O0~ CUMBERLA-ND ~uw'~ l x No. 02-157~ MAY 10, 2002 DIANE L. GREENE 12 WEST PINE STREET ENOLA, PA 17025 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY 1NFORIVlA TION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED ,4 DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT R~AFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. * * Your house (real estate) at ~312 EUTAW AVENUE~ NEW CUMBERLAND, PA 17070~ is scheduled to be sold at the Sheriffs Sale on 9/4102 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enfo'-~rce the court judgment of $6~0,621.8~3 obtained by GMAC MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sherif£s Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and ~easonable attorney's fees due. To find out how much you must pay, you may call: {_215) 563-7000. You may be able to stop the sale by filing a petition asking the Court to strike or open the jud~,,ent, if the judgment was improperly catered. You may also ask the Court to postpone thc sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) Exhibit 5 Mortgage Foreclosure Docs. MAY-I~-~O0~ IO:O~AM FRO~-¢ORR£CTIONS +~17~858051 T-$~ PO0$/O0~ F-~8 YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE, DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your progeny will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriffthe full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. Il:the'amount due from~the Buyer is'not paid'to the Sheriff,'you-will remain the owner of the progeny as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid f~r your house. A schedule of distribution of the money bid for your house will be filed by the Sheriffwithin 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are flied with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways ofgening your home back, if you act immediately after the sale. 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) (800) 990-9108 MAY-la-2002 IO:09AM FROM-CORRECTIONS +7177838051 T-~§g P 004/004 ~-248 DESCRIPTION ALL THAT CERTAIN lot or piece of land situate in the Borough of New Cumberland, County of Cumberland, State of Pennsylvania, bounded and described in accordance with a survey and plan thereof made by Ernest J_ Walker, Professional Engineer, dated November 30, 1968, as follows: BEGINNING at the Southwestern corner of Eutaw and River Avenues and extending South 36 degrees West along the line of River Avenue one hundred forty (140) feet to a twenty (20) feet'wide alley: thence North 54 degrees West along line of said alley twenty-five (25) feet to Lot No. 35: thence North 36 degrees East along the line of said lot and passing through the center of the partition wall between the house hereon erected and the adjoining house on Lot No. 35, one hundred forty (140) feet to Eutaw Avenue; thence South 54 degrees East along the line of said Eutaw Avenue twenty-five (25) feet to the corner, the place of beginning. HAVING thereon erected a two and one-half story brick dwelling house ~own as No. 312 Eutaw Avenue, New Cumberland, Pennsylvania. BEING Lot No. 36 in Block H in the General Plan of George W. Buttorff's Addition to New Cumberland, which plan is recorded in Deed Book N, VOl. 5, pages 498 and 499. Tax Parcel #25-0006-122 TITLE TO SAID PREMISES IS VESTED IN R_o.~rt F. Greene and Diane L. Greene, his wife by Deed from Gordon M. Chilcote and Verna Iq. Chilcote, his wife dated 3/30/1977 and recorded 4/1/1977 in Deed Book B, Volume 27, Page 996. PROPER'fY KI~OW'N AS: 312 El.rr~t? AVF. U~ut;, NEV CUlfl~ERI, A,ND, pti. 17070 FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PH' kN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 0MAC MORTGA6E'COi~.PORATION 500 ENTERPRISE ROAD, SUITE 150 HORSHAM, PA 19044 Plaintiff ROBERT F. GREENE DIANE L. GREENE 312 EUTAW AVENUE NEW CUMBERLAND, PA 17070 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURe. NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY/ INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** 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 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 fights 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 C.~ GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOC/ATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 24%3166 Loan It: 306715982 COPY FROM RECORD IF THIS I~HE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. ~'1692 et'-seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. Plaintiff is GM_AC MORTGAGE CORPORATION 500 ENTERPRISE ROAD, SUITE 150 HORSHAM, PA 19044 The name(s) and last known address(es) of the Defendant(s) are: ROBERT F. GREENE DIANE L. GREENE 312 EUTAW AVENUE NEW CUMBERLAND, PA 17070 who is/are the mortgagor(s) and real owner(s) of the property hereinafter descri.bed. On 3/6/98 mortgagnr(s) made, executed and delivered a mortgage upon the premises hereinafter described to AMERICA MORTGAGE REDUCTION, INC. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1441, Page 1019. By Assignment of Mortgage recorded 8/24/01 the mortgage was assigned to PLAINTIFF which Assignment is'recorded in Assignment of Mortgage Book No. 680, Page 2714. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 10/1/01 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagnr to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. The following am0~ts are due on the mortgage: Principal Balance Interest 9/1/01 through 3/1/02 '(Pet: Diem $11.70) Attorney's Fees Cumulative Late Charges 3/6/98 to 3/1/02 Cost of Suit and Title Search Subtotal $56,000.25 2,129.40 1,000.00 123.18 550.00 $59,802.83 Escrow Credit 0.00 Deficit 0.00 Subtotal $ 0.00 TOTAL $59,802.83 The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event ora third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. § 1680.403c. 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff's written Notice to Defendants; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $59,802.83, together with interest from 3/1/02 at the rate of $11.70 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff d&ced Novambe~ 30, L968s &8 foL~s:-- ' ~o~.&nd panning ~h~ou~h ~he ~en~e~ o~ ~h~ p~on ~V~G cher4on e~ecCed a c~ and one-ha$~ scory, b~ck dveLL~n~ ~uee ~o~ ~. ~. 3LZ (' _ ' /u=av Ave~e~ NeW C~r~nd, ~lvan~. ...... PR1~LISES ON: 312 EUTATJ' AVENUE VERIFICATION KRISTINE WILSON hereby states that she is FORECLOSURE SPECIALIST of GMAC MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are n-ue and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: Kelley Blue Book Used Car Values Page 1 of 2 Kelley Blue Be k New Car Pricing Build a Cai' Incentives My Car's Value Used Cai' Retail Buy a New Car Buy a Used Car Sell Your Car Motorcycles Financing Insurance Lemon Check Warranties Accessories Car Revl ews Car Previews Decis~ on Guides Advice About: kbb Home The Trusted Resource Click on the image above to visit this advertiser Blue Book Trade-In Report Pennsylvania · March 25, 2002 1990 Chevrolet Astro Minivan Engine: V6 4.3 Liter Trans: Automatic Drive: Rear Wheel Drive Mileage: 150,000 Equipment 7-8 Passenger CS Air Conditioning Power Steering Power Windows Power Door Locks Tilt Wheel Cruise Control AM/FM Stereo Cassette B~ a New Car Buy a Used. Car List. Your Car For Sa!e Online Financing Quote !nsurance Quote Warranty Quote Payment Calculator ABS (4-Wheel) Roof Rack Privacy Glass Towing Pkg Alloy Wheels Consumer Rated Condition: Good "Good" condition means that the vehicle is free of any major defects. The paint, body and interior have only minor (if any) blemishes, and there are no major mechanical problems. !n states where rust is a problem, this should be very minimal, and a deduction should be made to correct it. The tires match and have substantial tread wear left. A clean title history is assumed. A "good" vehicle will need some reconditioning to be sold at retail; however major reconditioning should be deducted from the value. Host recent model cars owned by consumers fall into this category. Trade-In Value $1,780 http ://www.kbb. c om/kb/ki.dll/kw, kc. Exhibit 6 Kelley Blue Book valuation Chevy Astro van 0%20As~o&].. 03/25/2002 Kelley Blue Book Used Car Values Page 2 of 2 Trade-in value represents what you might expect to receive from a dealer for this consumer owned vehicle. Keep in mind that the dealer must then absorb the cost of making the vehicle ready for sale, advertising, sales commissions, arranging financing and insurance and standing behind the vehicle for any mechanical or safety problems. Get a Private Party Value Get Invoice & MSRP on New Cars Copyright © 2002 by Kelley Blue Book Co., All Rights Reserved. Mar-Apr 2002 Edition. The information in this report was printed from the Kelley Blue Book Web site (www.kbb.com) and is intended for the personal use of the customer only and may not be sold or transmitted to another party. We assume no responsibility for errors or omissions.(v.02030) http://www.kbb.com/kb/ki.dll/kw.kc.ur?kbb;922011 &t&278;Chevrolet; 1990%20Astro& 1 .'. 03/25/2002 Kelley Blue Book Used Car Values Page 1 of 2 Kelley Blue Boek The Trusted Resource New Car Pridng Build a Car Incentives My Car's Value Used Car Retail Buy e New Car Buy a Used Car Sell Your Car Matorcyd es Lemon Check Warrantl es Accessories Car Reviews Car Previews Decision Guides Advice About kbb Home Build htal~ Yoar Car Comparis~0n,~ Your Dealer Click on the image above to visit this advertiser Blue Book Trade-In Report Pennsylvania · March 25, 2002 1989 Chevrolet Sl0 Blazer Sport Utility 2D Engine: V6 4.3 Liter Trans: Automatic Drive: 4 Wheel Drive Mileage: 105,000 Equipment Air Conditioning Tilt Wheel Power Steering Cruise Control Power Windows AM/FM Stereo Power Door Cassette Locks Dealer's Be~t Price BUy a New Car Buy a..Used Car List Your Car For Sale Online Financing Quote Insurance Quote Wa rra nty Quote Payment Calculator Privacy Glass Towing Pkg Alloy Wheels Consumer Rated Condition: Fair "Fair" condition means that the vehicle probably has some mechanical or cosmetic defects, but is still in safe running condition. The paint, body and/or interior need work to be performed by a professional in order to be sold. The tires need to be replaced. There may be some repairable rust damage. The value of cars in this category may vary widely. A clean title history is assumed. Even after significant reconditioning this vehicle may not qualify for the Blue Book Suggested Retail value. Trade-In Value $1,480 Trade-in value represents what you might expect to receive from a dealer for this consumer owned vehicle. Keep in mind that the dealer mus g the vehicle ready for http://www.kbb.con~kb/ki.dll/kw, Exhibit 7 Kelley Blue Book valuation Chevy Blazer 989%20S10%2C.. 03/25/2O02 Kelley Blue Book Used Car Values Page 2 of 2 sale, advertising, sales commissions, arranging financing and insurance and standing behind the vehicle for any mechanical or safety problems. Get a Private Parb/Value Get Invoice & IvlSRP on New Cars Copyright © 2002 by Kelley Blue Book Co., All Rights Reserved. Nar-Apr 2002 Edition. The information in this report was printed from the Kelley Blue Book Web site (www.kbb.com) and is intended for the personal use of the customer only and may not be sold or transmitted to another party. We assume no responsibility for errors or omissions.(v.02030) Your Car Comperisr~u Your De~ler Be~t Price http://www.kbb.com/kb/ki.dll/kw.kc.ur?kbb;307636&t&278;Chevrolet; 1989%20S 10%20L 03/25/2002 Kelley Blue Book Incentives Used Car Retai~ Buy a New Car Buy a Used Car Sell Your ~otorcyd es Financing Lemon Cheek Wnrrantms Car Reviews Car Previews Decision Guides Advice Abo{~t kbb The Trusted Resource Blue Book Motorcycle Retail Report March 1, 2002 1995 Harley-Davidson XL Sportster 2-Cylinder 4-Stroke 883cc Motorcycle Financing Motorcycle Warranty Sell Your Motorcycle Motorcycle Bookstore Another Report Suggested Retail Value $6160 Suggested Retail represents the price a dealership might ask for this make and model. The retail price is not a trade-in or private-party value, but rather assumes that a dealer has absorbed the cost of making the unit ready for sale, advertising, sales commissions, arranging financing and insurance and standing behind the unit for any mechanical or safety problems. Suggested retail represents a fully reconditioned unit in excellent condition, with all original standard equipment. Mileage/condition and additional equipment may have a substantial impact on the value shown above. Actual dealer selling price may vary from this price. Copyright © 2002 by Kelley Blue Book Co., All Rights Reserved. JanApr 2002 Edition. The information in this repod is intended for the personal use of the customer only and may not be sold or transmitted to another party. We assume no responsibility for errors or omissions. http://www.kbb.com/kb/ki.dll/1 Exhibit 8 Kelley Blue Book valuation Harley Davidson motorcycle : 154& 1995;Harley-Davids 3/1/02 PSEC MEMBERNUMBER ZiANE L GREENE B[~BERT F GREENE i-: W ~iNE ST u Pk,.z PA 171/25-2828122 Page MEMBERNUMBER Page 2 ~', s~ Elf [escription Amount Balance ~.~ 0i ID 01 REGULAR SHARES Beginning Balance 107.3~ i 0 Whthdxawal Adjustment ATM REBATE-SEP 1.50 108.88 , )~, W~thdrdwal at ATM %00004002 100.00- 8.8:< ATH !10! S FRONT ST HARRISBURG PA '~ERH TP6834 ~ i PQ.'ment: Transfer From Share 04 100.00 ~10U~ . i ~ W~thdrawal at ATM %00005182 ~00.00- U.88 A'FM ll01 S FRONT ST HARRISBURG PA TERH TR6834 [~'~yment: Transfer Frem Share 04 ~ ~iment: Dividend 2.720'8 11.96 20.84 0.06 20.qQ Peucentage 'field Earned 2.64'/ from 10/01/01 through 10/31/01 Average Daily Balance of 27.13 }/TD: Yea~ to Date 37.94 ~ . su } ~]~ Des?~iption - :}! lC) 0~ CHECKING Beginning Balance l~ 01 {~el.!} Withdrawal Check Card 09/28 24226388G9EDZPSV8 5310 WAL MART MECHANICSBURG PA i: {~; Check 005373 l'l~ Chec]: 005371 ~ ,,~r clhec]l ~'~Q5~72 '' '"' Che.i~]i 005375 ~ ~' ~ ~;he.~k 005374 1~'12 P~yx,enh: PA TREASURY DEPT TYPE: PAfROLL ID: 1236003133 W~thdrawsl at ATM %00004891 .... ?ontinued on follewing page --- P~nount Balance 1004 ~ 59.72- 944 .85 35.00- 909.85 55.00- 854.85 35.00- S19.85 45.00- 4u.00~ 904 . 35 240.00- 1394.20 Exhibit 9 PSECU joint checking account statement PSE MEMBERNUMBER i ]A!}E i. GREENE ~ ,~ERT' F GREENE i W ~!NE ST E hi,LA PA 17025-2828122 Page UMBER Page 3 ~}es 2r iption ATH 1101 S FRONT ST HARRISBURG PA TERM TR6834 Withdrawal By Check 1000.00- 394.2111 Withdrawal Transfer To Share 01 100.00- 294.20 Withdrawal Transfer To Loan 01 150.00- 144.2(I Ci'le 2k 1~05377 62.24- 81.96 ~'! ~(!h 005376 50.00- 3i . ~ [ri/l~'::,,~,~jL at ATM ~00006044 20.00- 11.96 .~ FH !I0] S FRONT ST HARRISBURG PA FERM TR%834 W~Vhd~awal Transfer To Share 01 11.96- Payment: Dividend' 1.000% 0.26 0.26 Annual Percentage Yield Earned 0.99% from 10/01/01 through 10/31/01 Based en Average Daily Balance of 309.22 Ending Balance 0.20 Dividend YTD: Year te Date 24.55 l!, m!3sr _%nount Number Amount Number As~ount Number ~u~taur~t ',, 5}i i .~r_ .00 005373 35.00 005375 45.00 005377 62.24 , ~.' 3-:2 i_{5.00 005374 45.00 005376 50.00 '' ~ ANNUAL PERCENTAGE RATE 12.900'% +~* Periodic Rate (Daily) . P. sr EfP [)escription Principal *FIN CHG~ Balance ! 8] 1D (11 PSL LOAN (Open End) Beginning Balance l'l.l P~yments Transfer From Share 04 145.65- 4.35 ~] E lding Balance 732.84 --- 2{~nti~lued on following page --- LOOK FOR US. WE'LL GET YOU THERE. RO. Box 1711, Harrisburg, PennsuIvania 17105-1711 Member FDIC BETH A GREENE DIANE L GREENE 820 D WINDSOR PLACE HECHANICSBURG PA 17055 STATE PAGE 1 FOCUS ACCOUNT TYPE OF ACCOUNT: 0100312230 FOCUS 50 FREE INTEREST PREVIOUS BALANCE DEPOSITS 1,079.66 2,216.67 DATE ACTIVITY DESCRIPTION 10/01/01 OVER CT DEBIT 10/03/01 CHECK ~5011 10/04/01 CHECK ~5007 10/04/01 CHECK ~5008 10/05/01 CHECK #5009 10/09/01 DEPOSIT 10/09/01 POS PURCHASE CHK/EFT TRANS 188600 1886 WAL-SAMS MECHANICSBURG PA 10/10/01 POS PURCHASE CHK/EFT TRANS 000229 GIANT FOOD #113 SI ENOLA PA 10/10/01 CHECK ~5010 10/11/01 CHECK ~5012 10/12/01 DEPOSIT 10/12/01 POS PURCHASE CHK/EFT TRANS 009668 GIANT FOOD #056 NEW CUMBERLAN PA 10/15/01 DEPOSIT 10/15/01 POS PURCHASE CHK/EFT TRANS 090013 AMES DEPT STORO001 CAMP HILL PA 10/15/01 POS PURCHASE CHK/EFT TRANS 023629 GROUND ROUND 99748 CAMP HILL PA 10/15/01 CHECK #5013 10/16/01 POS PURCHASE CHK/EFT TRANS 011655 TDYS R US ~8315 CAMP HILL PA 10/16/01 CHECK #5022 10/16/01 CHECK ~5014 10/17/01 CHECK #5016 10/17/01 CHECK ~5023 10/18/01 CHECK #8020 10/18/01 CHECK ~5019 10/18/01 CHECK ~5021 10/19/01 CHECK ~5018 INTEREST PAID YEAR TO DATE 1.56 ANNUAL PERCENTAGE YIELD EARNED (APYE) ,66 ~ DAYS IN CYCLE 28 AVERAGE BALANCE 517.35 WITHDRAWALS CHARGES INTEREST ENDING BALANCE 2,302.65 .00 .26 993.94 DEPOSITS 70.00 1.000.00 WITHDRAWALS 200.00 50.00 109.96 55.00 33.00 BALANCE 879.66 829.66 719.70 701.70 59.88 641.82 41.57 600.25 15.gO 584.35 259.43 324.92 1,324.92 19.59 1,305.33 1,747.63 88.05 1,659.58 46.62 1,612.96 12.95 1.600.01 86.81 1,513.20 442.30 685.00 828.20 130.00 698,20 50.00 648.20 13.25 634.95 48,31 888,84 37.01 549.63 30.00 519.63 35.00 484.63 OD-502 (6/01) Customer Service Toll-Free I-E Exhibit ! 0 Wife's Waypoint bank checking account stmt. York Area 717/815-4500 Yiwau i.n t LOOK FOR UC;. WE'LL GET YOU TH(ERE. P.O. Box 1711. Harrisburg, PsnnsuIvanla 17105-1711 Member FDIC BETH A GREENE DIANE L GREENE 820 D WINDSOR PLACE MECHANICSBURG PA 17055 STATEMENT DATE 10/26/01 FOCUS 50 FREE INTEREST 0100312230 PAGE 2 ENCLOSURES 18 DATE 10/22/01 10/22/01 10/22/01 10/23/01 10/23/01 10/26/01 10/26/01 10/26/01 10/26/01 - - ACCOUNT 0100312230 CONTINUED - - ACTIVITY DESCRIPTION POS PURCHASE CHK/EFT TRANS 052421 GIANT FOOD ~056 NEW CUMBERLAN PA CHECK ~5017 CHECK ~5015 POS PURCHASE CHK/EFT TRANS 089815 GIANT FOOD ~113 SI ENOLA PA CHECK ~5024 DEPOSIT POS PURCHASE CHK/EFT TRANS 023075 GIANT FOOD #056 NEW CUMBERLAN PA INTEREST EARNED DEBIT CARDHOLDER FEE DATE CHECK NO. ~OUNT 10/04/01 5007 109.96 10/04/01 5008 55.00 10/05/01 5009 33.00 10/10/01 5010 15.90 10/03/01 5011 50.00 10/11/01 5012 259.43 DEPOSITS WITHDRAWALS 21.48 30.00 20.00 24.02 85.86 704.37 12.96 .26 1.00 CHECK SUMMARY * indicates ski~ in check numbers DATE CHECK NO. A~OUNT DATE CHECK NO. 10/15/01 5013 12.95 10/18/01 5019 10/16/01 5014 130.00 10/18/01 5020 10/22/01 5015 20.00 10/18/01 5021 10/17/01 5016 50.00 10/16/01 5022 10/22/01 5017 30.00 10/17/01 5023 10/19/01 5018 35.00 10/23/01 5024 BALANCE 463.15 433.15 413.15 389.13 303.27 1,007.64 994.68 994.94 993.94 AMOUNT 37.01 48.31 30.00 685.00 13.25 85,86 Need a cozy, quiet mountain getaway this winter? How about a new sun porch to enjoy all year long? Do you need to replace your 15-year-old washer and dryer? All these are possible and more. How? With a Home Equity Line of Credit from Waypoint Bank. The equity in your home holds the key for all kinds of possibilities -- anywhere, anytime, anything. To apply, stop by your local branch or call our Customer Service Center at 1- (866) 929-7646. Customer Service Toll-Free 1-866-WAYPOINT (I-866-9;~9-7646) · In York Area 717/815-4500 ~D-502 (6/01) vvvvw.waupoint bank.corn BETH A GREENE DIANE L GREENE 820 D WINDSOR PLACE MECHANICSBURG PA 17055 STATEMENT DATE PAGE 1 SAVER'S ADVANTAGE 5500012691 ACCOUNT TYPE OF ACCOUNT: INTEREST PAID ANNUAL PERCENTAGE YIELD DAYS IN CYCLE AVERAGE BALANCE YEAR TO DATE EARNED (APYE) 5500012691 SAVER'S ADVANTAGE 3.24 1.50 ~ 21 1,211.B5 PREVIOU,~m.B~LAN.C~' DEPOSITS WITHDRAWALS CHARGES INTEREST ENDING BALANCE .00 lO.O0 .00 1.52 1,165.96 DATE ACTIVITY DESCRIPTION DEPOSITS WITHDRAWALS BALANCE 10/22/01 WITHDRAWAL lO.O0 1,164.42 10/31/01 INTEREST EARNED 1.53 1,165.96 Need a cozy, quiet mountain getaway this winter? How about a new sun porch to enjoy all year long? Do you need to replace your 1S-year-old washer and dryer? All these are possible and more. How? With a Home Equity Line of Credit from Waypoint Bank. The equity in your home holds the key for all kinds of possibilities -- anywhere, anytime, anything, To apply, stop by your local branch or call our Customer Service Center at 1- (866) 929-7646. Exhibit 11 Wife's Waypoint Bank savinQs account COM~'6J~,T=,~LT~ OF VEN',~SYLV,~ STATE EMPLOY'EF_$, RETIREMENT SYSTEM 30 NORTH THIRD STREET - PO BOX HARRISBURG. PENNSYLVANIA TOLL FREE: 1-800-633-5461 STATEMENT OF ACCOUNT for DIANE L GREENE 12 W PINE ST ENOLA PA 17025 This Statement of Account provides calculations based on information that your employer reported to SERS through December 31, 2001. It is especially important to study your statement because your account could have been affected by the changes the Pennsylvania Legislature made to the administration of benefits in the retirement system. Please read further to learn about some of the changes and about improvements SERS is making in customer service. Amendments to the State Employees' Retirement Code This legislation has important implications for all active, contributing members of the State Employees' Retirement System, including: · Reducing the service requirement for vesting and early retirement to five years · Opening a window period from July 1, 2001 to December 31, 2003 to elect multiple service credit · Adding more flexible provisions for the purchase of service · Potentially applying actuarial increases for members who are over age 70 Act 2001-9 also made Class AA service credit available to most Class A members, which includes the majoriW o~ state employees. Members of the Judiciary, State Police, members of Classes C and D-3, and Vestees were not eligible to elect Class AA service credit. The Class AA Maximum Single Life Annuity, the basic retirement benefit, accrues at a 25% higher rate than the basic Class A benefit. The formula for calculating the Class AA benefit is 2% x years of service x Final Average Salary (typically the average of the three highest years of compensation) x 1.25 multiplier. The employee contribution rate for Class AA service credit increased to 6.25% of compensation. Retirement benefits of Class A members who did not elect Class AA will continue to be calculated under the 2% x years of service x final average salary formula, and their contribution rate will remain 5% of compensation. The increased basic formula became effective July 1, 2001, and the increased contribution rate became effective with the first pay received in January 2002. Additional contributions will not be required on salary, received prior to January, 1, 2002. SERSOC *2LOOO&848* Exhibit 12 Wife's SERS pension stmt. 020'z" 1545-SERSOA_~._ 153~, Multiple Service Act 2001-9 opened a window period for active, contributing members of SERS to elect multiple service credit. The window period will close on December 31, 2003. Multiple service is the combining of credited service with SERS and the Public School Employees' Retirement System to receive a combined benefit at the time of retirement. If you rendered service in a Pennsylvania Public School as an educator, office employee, school bus driver, or in another capacity, you may be eligible to become a multiple service member. Please complete the enclosed multiple service request form and forward it to SERS, 30 North Third St., PO Box 1147, Harrisburg, PA 17108-1147. Your request must be received while you are an active contributing member of SERS and prior to December 31, 2003. Updated Member Handbook and Redesigned Web Site SERS has updated and revised the Member Handbook, replacing its predecessor. Among the many Changes are detailed explanations of Act 2001-9. The Member Handbook is available at the SERS Central Office, Retirement Counseling Centers, and at www.sers.state.pa.us. To request a copy of the Member Handbook, please return the enclosed form. In a continuing effort to communicate complete, accurate, and timely information, SERS has redesigned its web site to outline retirement issues you may have at various points in your career. The web site also contains many SERS forms and a benefit estimate calculator. If you have any questions about this Statement of Account or desire benefit estimates under different retirement options, you may telephone your SERS Retirement Counseling Center at 800-633-5461. For more information about account statements, visit the web site under "Account Login". This Statement of Account contains personal and confidential information about your SERS retirement account. You should maintain it with other important financial information. These calculations are subject to final audit by SERS in accordance with applicable laws. P~rsonal Data iSocial Security Number: Sex: FEMALE Birth Date: Coverage Type: . Contribution Rate: Coun~!ing Center: Nor_mM Retirement Date: .. Fin~! Average Salary: 200t Retirement covered Earnings: Total SSI Non-Covered Earnings: Joint Coverage Conversion Amount: Mancl~tory Debt: Service Purchase Debt: Cla~ AA-60 ~rvice Cr/aiii as c Years of Service 21.1228 COMMONWEALTH OF PENNSYLVANIA STATE EMPLOYEP~, RETiREMEN1, SYSTEM TOLL FREE: 1-800-633-5461 2001 STATEMENT OF ACCOUNT For: DIANE L GREENE 154-38-027~ 27.JUN. 194 FULL 6.25% HARRISBURG 27-JUN.2006 $36~031.5( $37,141.~ BASIC ~mb~t 31~ 2001. Class Years of Service 'rOTAL ERVICE ( * .If you are eligible to purchase creditable state and/or. non-state service, contact your Retirement Counselor for information on purchasing service. All requests to purchase sen, lee must be filed while you are an actfi, e, c°ntrlbta~O'.g member. ** Information filed on a Nomination of Beneficiary(ies) form before 1993 or since December 31, 2001, or involving special circumstances (such as the designation of an estate or trust as your beneficiary) may not appear A of 10 beneficiaries m~v be s~,~,,,- ~- .... ' max/mum ~ -- . ."'7" . ,~.~rett tt~r¢; nowever you ma benet~ciar~ n~,~t,~a~_ _n~ current. You. may change your Nomtnation o£ B--~n-' ...... n,y time._ ~y filing a new ~ -,,=~,~xy{tes9 jorm wttl~ SERS. Forms are available from your agency Personnel Office or your regional SERS Retirement CounSeling Center. Please contact us if you do not want your beneficiary(les) listed on future statements. Account Balane~ Regular SS/ -- Contribution Contribution. December 31, 2000, Balance i $31,512.11 ~Contributions $1~$7.13 Lump Sum Payments Arrears Payments Credited Interest _YTD Adiuatments*** . $1~297.27 December 317 2001, Balance $34~6~.51 TOTAL DEDUCTIONS $34~666.$1 Taxable Br~kOown of Your Account "Taxable contributions $24~181.32 Pre 87 Non-Taxable contributions ., Post 86 Non-Taxable Contributions Credited Interest (Taxable) December 31~ 2001~ Balance $427.70 $427.70 $9,62s.79 *** YTD (Year-To-Date) Adjustments reflect corrections to your account for which you already have received notification. **** SERS i~ a defined benefit plan under Internal Revenue Service Code Section 401 (a). SPECIAL CONDITIONS The following special conditions apply to your bene~ estimate or reasons estimates ~v~re not calculated: I IIII] ]lill lll lllll lllll lll! llll J Jl Jll lJ Jl jl J[ll lJ Jl j j '2L000~,40. o2{r'" 1545-$ERSO A.~,. 153~ 2001 STATEMENT OF ACCOUNT STIMATED REIIREM~NT BENEI~I'S Estimated Retirement Benefits are provided if you have at least five years of credited service or you have reached Normal Retirement Date and have at least three years of credited service. Note: If you have credited service as a Multiple Service member (service in both SERS and the Public School Employees' Retirement System (PSERS)), your estimate does not include your PSERS contributions. Your service may be overstated if in any calendar year you have concurrent service. Normal Retirement Date: 27-JUN-2006 Options with N._.QO Withdrawal of Member's Money MAXIMUM SINGLE LIFE ANNUITV This plan provides the maximum amount each month for life. If you die before receiving in payments an amount equal to your total accumulated deductions, the balance will be paid to your beneficiary(les). You may name one or more beneficiaries at any time. As of 12-31.01 As of 06-27,06 $1,194.13 $1,992.32 .O!~_ON 1 RETIREMENT This plan provides reduced 'monthly benefits to you for lii*e. A''~ Present Value is placed on your account. All 'payments you receive are subtracted from the Present Value. Any balance remaining at the time of your death will be paid to your beneficiary(les). You may name one or more beneficiaries and may change beneficiaries at any time. OPTION 1 PRESENT VALUE ~DISABIL/TY RET/REMENT You must be certified by SERS Medical Examiners as physically or mentally incapable of performing current job duties and have at least five years of credited service (except State Police and Enforcement Officer-category employees, who have no minimum service requirement). Only active, contribu' members or those on leave ,.4,~.~_. ....... ting · -.--,,m pay may appty for Disability Retirement. You cannot withdraw your accumulated deductions if you take Disability Retirement. DEATH IN STATE SERVICE If you are vested and die while an active employee, it will be assumed you retired under Option 1 the day before your death. The Present Value of your annuity will be payable to your beneficiary(les). If you are not vested, your accumulated deductions will be payable to your beneficiary(les). $1,111.91 $209,531.41 $1,585.60 $209,531.41 $1,860.80 $341,549.80 Options Adjusted for a TOTAL Withdrawal of ADJUSTED. MAXI34'L.~M SINGLE LIFE AN~i Iy This option provides the maximum monthly benefit to you for life. When you take a total withdrawal, there is no death benefit payable. ADJUSTED. OPTION I RETIREMEN-r This option provides reduced monthly benefits to you for life. A Present Value is placed on your account. All payments you receive are subtracted from the Present Value. Any balance remaining at the time of your death will be paid to your beneficiary(les). ADJUSTED OPTION 1 PRESENT VALUE As of 12-31-01 $34,666.51 $996.56 $927.95 $174,864.90 As of 06-27-06 $52,733.97 $1,684.71 $1,573.50 $288,815.83 S~RSOB (. DIANE L. GREENE, V. ROBERT F. GREENE, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-1560 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE A. MARITAL PROPERTY IN HUSBAND'S POSSESSION NO DESCRIPTION OWNER POSSESS VALUE COMMENTS METHOD OF OR AND/OR VALUATION BASIS FOR AND EXCLUSION IF SUPPORTING CLAIMED TO DOCUMENTATIO BE NON N MARITAL 1. Sofa Joint Husband $250.00 Estimate 2. Recliner chair Joint Husband $25.00 Estimate 3. 27" color tv Joint Husband $100.00 Estimate 4. Surround sound Joint Husband $100.00 Estimate system 5. VCR Joint Husband $100.00 Estimate 6. Lamp Joint Husband $25.00 Estimate 7. King-size Joint Husband $200.00 Estimate waterbed 8. Papa-saw chair Joint Husband $50.00 Estimate 9. Vanity Joint Husband $100.00 Estimate 10. Gun cabinet Husband Husband $150.00 Estimate 11. 4 rifles Husband Husband $1,500.00 Estimate 12. 4 dressers Joint Husband $200.00 Estimate 13. Computer Joint Husband $500.00 Estimate 14. Boat motor & Joint Husband $1,500.00 Estimate trailer 15. Large chest Joint Husband $200.00 Estimate freezer 16. Small chest Joint Husband $50.00 Estimate freezer 17. Marble Joint Husband $1,500.00 Estimate collection 18. Marble game in Joint Husband $250.00 Estimate Exhibit 14 Wife's Valuation of Personalty Page I A. MARITAL PROPERTY IN HUSBAND'S POSSESSION NO DESCRIPTION OWNER POSSESS VALUE COMMENTS METHOD OF OR AND/OR VALUATION BASIS FOR AND EXCLUSION IF SUPPORTING CLAIMED TO DOCUMENTATIO BE NON N MARITAL tin box 19. Wood lathe Joint Husband $150.00 Estimate 20. Wood planer Joint Husband $150.00 Estimate 21. Snow blower Joint Husband $300.00 Estimate 22. Lawn mower Joint Husband $200.00 Estimate 23. Gas grill Joint Husband $50.00 Estimate 24. Park bench Joint Husband $50.00 Estimate 25. Porch furniture Joint Husband $100.00 Estimate 26. Microwave Joint Husband $300.00 Estimate 27 Household Joint Husband $1,000.00 Estimate tools, drills, saws, etc. 28. Dishes, Joint Husband $25.00 Estimate glasses, pots & pans 29. Refrigerator Joint Husband $100.00 Estimate 30. Fishing rods & Husband Husband $200.00 Estimate equipment 31. Computer desk Joint Husband $150.00 Estimate 32. Entertainment Joint Husband $200.00 Estimate center 33. Refrigerant Husband Husband $90.00 Estimate gauge & hose 34. Husband's Husband Husband $1,050.00 Appraisal mechanics tools 35. Husband's power Husband Husband $2,000.00 Estimate and other tools 36. Wife's property Wife Husband 0.00 These items in van are including 3 requested by bins of wife pictures, state parking pass, Exhibit 14 Wife's Valuation of Personalty Page 2 A. MARITAL PROPERTY IN HUSBAND'S POSSESSION NO DESCRIPTION OWNER POSSESS VALUE COMMENTS METHOD OF OR AND/OR VALUATION BASIS FOR AND EXCLUSION IF SUPPORTING CLAIMED TO DOCUMENTATIO BE NON N MARITAL handicap placard for car pool and legal documents SUBTOTAL MARITAL PERSONAL PROPERTY IN $9,865.00 HUSBAND'S POSSESSION B. NON-MARITAL PROPERTY IN HUSBAND'S POSSESSION NO DESCRIPTION OWNER POSSESS VALUE COMMENTS METHOD OF OR AND/OR VALUATION BASIS FOR AND EXCLUSION IF SUPPORTING CLAIMED TO DOCUMENTATIO BE NON N MARITAL 1. Floor swing Wife Husband $50.00 This was Estimate made by wife's father for her. This items should be returned to her. 2. 20 silver Childre Husband $200.00 These were Estimate dollars n given to the children by their grandfather for Christmas. Husband needs to provide them to the children. Exhibit 14 Wife's Valuation of Personalty Page 3 NO DESCRIPTION OWNER POSSESS VALUE COMMENTS METHOD OF OR 'AND/OR VALUATION ~ASIS FOR AND EXCLUSION IF SUPPORTING CLAIMED TO DOCUMENTATIO BE NON N MARITAL 3. 4 State Hood Childre Husband $100.00 Bought Estimate quarter sets n (Gift) for the children. Husband needs to provide them to the children. 4. China closet Husband Husband TBD Husband's Estimate pre-marital. Bought from Uncle Henry 5. Antique box Wife Husband TBD Wife's non- Estimate with silverware marital - came from wife's father's family. Wife wants this item returned to her. SUBTOTAL NON-MARITAL PERSONAL PROPERTY $350.00 IN HUSBAND'S POSSESSION C. MARITAL PROPERTY IN WIFE'S POSSESSION NO DESCRIPTION OWNER POSSESS VALUE COMMENTS METHOD OF OR AND/OR VALUATION BASIS FOR AND EXCLUSION IF SUPPORTING CLAIMED TO DOCUMENTATIO BE NON N MARITAL 1. Sofa & love Joint Wife $350.00 Estimate seat 2. Accessory Joint Wife $150.00 Estimate tables 3. 2 lamps Joint Wife $50.00 Estimate 4. Washer Joint Wife $100.00 Estimate 5. Dryer Joint Wife $100.00 Estimate 6. Dining room Joint Wife $350.00 Estimate table & chairs 7. Roll top desk Joint Wife $50.00 Estimate 8. Victrola Joint Wife $50.00 Estimate 9 Trash compactor Joint Wife $50.00 Estimate Exhibit 14 Wife's Valuation of Personalty Page 4 C. MAriTAL PROPERTY IN WIFE'S POF~SSION NO DESCRIPTION OWNER POSSESS VALUE COMMENTS METHOD OF OR AND/OR VALUATION BASIS FOR AND EXCLUSION IF SUPPORTING CLAIMED TO DOCD-~ENTATIO BE NON N MARITAL 10 Set of dishes Joint Wife $50.00 Estimate 11 19" tv Joint Wife $150.00 Estimate 12 Husband's tool Husband Wife $3,500.00 Appraisal box SUBTOTAL WIFE'S MARITAL PROPERTY $4,950.00 D. NON-MARITAL PROPERTY IN WIFE'S POSSESSION NO DESCRIPTION OWNER POSSESS VALUE COMMENTS METHOD OF OR AND/OR VALUATION BASIS FOR AND EXCLUSION IF SUPPORTING CLAIMED TO DOCUMENTATIO BE NON N MARITAL 1. Secretary desk Wife Wife TBD Wife's pre- marital 2. Bedroom Wife Wife TBD Wife's pre- furniture marital 3. Cedar chest Wife Wife TBD Gift to Wife and made by father 4. Grandfather Wife Wife TBD Gift to Wife clock and made by father 5. Rocking chair Wife Wife TBD Gift to Wife and made by father 6. Armoire Wife Wife $100.00 Gift to Wife Estimate from children SUBTOTAL WIFE'S NON-MARITAL PERSONAL $100.00 PROPERTY Exhibit 14 Wife's Valuation of Personalty Page 5 04/15/2002 3:00 PM CharLes J. DeHart, CASE REPORT FROM 10/15/2001 TO 04/15/2002 CASE # 10105545 '.NE L GREENE ATTORNEY: PET FILED 10/15/2001 JUDGE JAMES M. BACH, ESQUIRE PLAN FILED 10/15/2001 STATUS 1 12 W PINE STREET COMMENTS: DATE 1ST MEETING 12/06/2001 TRUSTEE EXP % 2.20 ENOLA PA 17025 0103025535 DATE CONFIRMED 12/26/2001 TRUSTEE COMP % 2.20 DATE CLOSED PAYMENT 214.00 PAYMENTS/MO 1 PERCENT PLAN 100.00 M[N BAL 0.00 UNDIST FORWARD 214.00 PAGE 1 DATE AMOUNT DATE AMOUNT DATE AMOUNT DATE AMOUNT DATE AMOUNT DATE AMOUNT 10/29/01 107.00 11/14/01 107.00 11/27/01 107.00 12/10/01 107.00 12/27/01 107.00 01/08/02 107.00 01/24/02 107.00 02/05/02 107.00 02/20/02 107.00 03/05/02 107.00 03/19/02 107.00 04/02/02 107.00 C[m Cred Name C[ Pr Md Per Mo Amt Sch Appr Debt Frg Amt Due Iht Ernd Amt Paid Balance Assigned St 000 JAMES M. BAC 09 12 101GMAC 01 24 COMMENT ..... > O-Surrender 102 FAIRBANKS CA 01 24 COMMENT ..... > O-Surrender 103 WAYPOINT BAN 01 24 COMMENT ..... · O-Surrender 104 WAYPOINT BAN 01 24 COMMENT ..... · O-Surrender 201PSECU 03 33 202 PSECU 03 33 203 BANK OF AMER 03 33 ~n4 SEARS 03 33 DISCOVER 03 33 206 RESURGENT CA 03 33 207 PROVIDIAN NA 03 33 208 WAYPOINT BAN 03 33 999 **DIANE GREE 08 50 TOTAL NET RECEIPTS - TOTAL PAID TRUSTEE COMP - TOTAL PAID TRUSTEE EXP - TOTAL PAID CREDITORS - UNDISTRIBUTED FORWARD - PLAN BALANCE - % TO UNSECURED - TOTALS: 0.00 2,000.00 2,000.00 0.0 2,000.00 0.00 1,022.91 977.09 0.00 1 0.00 56,552.09 0.00 0.0 0.00 0.00 0.00 0.00 0.00 2 0.00 21,086.80 0.00 0.0 0.00 0.00 0.00 0.00 0.00 2 0.00 4,655.49 0.00 O.O 0.00 0.00 0.00 O.O0 0.00 2 0.00 5,597.10 0.00 0.0 0.00 0.00 0.00 0.00 0.00 2 0.00 7,261.01 7,261.01 O.O 7,261.01 0.00 0.00 7,261.01 0.00 1 0.00 7-32.84 732.84 0.0 732.84 0.00 0.00 732.84 0.00 1 0.00 1,678.~ 1,678.D O.O 1,678.~ 0.00 0.00 1,678.73 0.00 1 0.00 1,821.11 1,821.11 0.0 1,821.11 0.00 0.00 1,821.11 0.00 I 0.00 2,~2.98 2,682.98 0.0 2w682.98 0.00 0.00 2,682.98 0.00 1 0.00 212.18 212.18 0.0 212.18 0.00 0.00 212.18 0.00 1 0.00 1,658.97 1,658.97 0.0 1,658.97 0.00 0.00 1,658.97 0.00 1 O.O0 2,809.12 2,809.12 0.0 2,809.12 0.00 0.00 2,809.12 0.00 1 0.00 0.00 0.00 0.0 0.00 0.00 0.00 0.00 0.00 2 108,748.42 20,856.94 20,856.94 0.00 1,022.91 19,834.03 0.00 1,284.00 23.54 23.55 1,022.91 214.00 6,420.00 29.76 SPECIAL RECEIPTS - 0.00 BASE PLAN - 7,704.00 ........ TIER DATA ......... *** No Tiers Exhibit 1 5 Wife's bankruptcy documents ~- re DIANE L. GREENE Case No. Debtor SCHEDULE I. CURRENT INCOME OF INDIVIDUAL DEBTOR(S) The column labeled "Spouse" must be completed in all cases filed by joint debtors and by a married debtor in a chapter 12 or 13 case whether or not a joint petition is filed, Unless the spouses are separated and a joint petition is not filed. uetxor's Marital ~[atus: DEPENDEN'I'5 OF DEBTOR AND SPOUSE None. Separated Uccupation ULEEK III Name o~ bmployer GUMMONWbALI H OF PENNSYLVANIA How ~ong empmyee 21 Y~A~ Aearess o~ bmployer ~IV~P~NI OPPIGE G I ~. - 1t01 S. FRONT ST.-4TH FLR. Harrisburg, PA 17104-2516 Current monthly gross wages, salary, and corhmissions (pro rate if not paid monthly) $ r~ ';mated monthly overtime ..................................... $ 3TOTAL ................................................ LESS PAYROLL DEDUCTIONS [ :~ a. Payroll taxes and social security ............................. b. Insurance ............................................. c. Union dues ............................................ d. Other (Specify) SERS SUBTOTAL OF PAYROLL DEDUCTIONS ...................... I TOTAL NET MONTHLY TAKE HOME PAY ....................... I Regular income from operation of business or profession or farm (attach detailed I statement) .................................................. $ Income from real property ...................................... $ Interest and dividends ......................................... $ Alimony, maintenance or support payments payable to the debtor for the debtor's use or that of dependents listed above ................................. Social security or other government assistance (Specify) ............. Pension or retirement income .................................... Other monthly income (Specify) TOTAL MONTHLY INCOME TOTAL COMBINED MONTHLY INCOME $ 2,219.00 3,144.00 $ N/A 0.00 $ NIA 3,144.00 ~, NIA [ $ 726.00 $ 0.00 $ 42.00 t57.00 u.uu UZO. UU $ 2,219.UU $ NIA $ NIA $ NIA $ NIA $ NrA $ $ NIA $ $ $ $ $ $ 0.00 $ N/A 0.00 $ NIA 0.00 $ NIA 0.00 $ NIA 0.00 $ N/A 0.00 $ N/A 0.00 $ NIA 0.00 $ N/A 0.00 $' NIA Z,ZI~.UU ~, Ni/a. (Keport also on ~ummary or ~cneoules) .be any increase or decrease of more than 10% in any ofthe above categories anticipated to occur within the year following the filing f~'fhis document: ' DIANE L. GREENE Case No. Debtor SCHEDULE J. CURRENT EXPENDITURES OF INDIVIDUAL DEBTOR(S) Complet'c this schedule by estimating the average monthly expenses of the debtor and the debtor's family. Pro rate any payments made bi-weekly, quarterly, semi-annually, or annually to show monthly rate. [] Check this box if a joint petition is filed and debtor's spouse maintains a separate household. Complete a separate schedule of expenditures labeled "Spouse." Rent or home mortgage payment (include lot rented for mobile home) ....................... $ 800.00 Are real estate taxes included? Yes No X Is property insurance included.'? Yes No X Utilities: Electricity and heating fuel .............................................. $ 150.00 Water and sewer ...................................................... $ 60.00 Telephone .......................................................... $ 55.00 Other CABI. E ........ $ 50.00 Home maintenance (repairs and upkeep) ............................................ $ 0.00 Food ..................................................................... $ 400.00 Clothing ................................................................... $ 100.00 Laundry and dry cleaning ....................................................... $ 40.00 Medical and dental expenses ..................................................... $ 20.00 Transportation (not including car payments) .......................................... $ 120.00 ~ Recreation, clubs and entertainment, newspapers, magazines, etc ............................ $ 100.00 £haritable contributions ........................................................ $ 75.00 Insurance (not deducted from wages or included in home mortgage payments) Homeowner's or renter's ................................................. $ 20.00 Life ............................................................... $ o.oo Health ............................................................. $ 0.00 Auto .............................................................. $ lOO.OO Other ........ $ o.oo Taxes (not deducted from wages or included in home mortgage payments) (Specify) PERSONAL ........ $ 30.00 Installment payments: (In chapter 12 and 13 cases, do not list payments to be included in the plan.) Auto .............................................................. $ 0.00 Other ........ $ 0.00 Other ........ $ 0.00 Other ........ $ 0.oo Alimony, maintenance, and support paid to others ..................................... $ 0.00 Payments for support of additional dependents not living at your home ...................... $ 0.00 Regular expenses from operation of business, profession, or farm (attach detailed statement) ....... $ 0.00 Other BEAUTY SHOP ........ $ t5,00 Other ........ $ 0.00 TOTAL MONTHLY EXPENSES <Report also on Summary of Schedules) .................... I $ 1,935.00 J [FOR CHAPTER 12 AND 13 DEBTORSO.NLY] Provide the information requested below, including whether plan payments are to be made bi-weekly, monthly, annually, or at some other regular interval. A. Total projected monthly income ........................................ $ 2,219.00 [ nl. Total projected monthly expenses ....................................... $ 1,935.00 ~- ,J. Excess income (A minus B) ........................................... $ 284.00 D. Total amount to be paid into plan each Monthly ....... $ 214.00 (interval) In re DIANE L. GREENE Case No. Debtor SCHEDULE D. CREDITORS HOLDING SECURED CLAIMS State the name, mailing address, including zip code, and account number, if any, of' all entities holding claims secured by property of the debtor as of the date of filing of the petition. List creditors holding all types of secured interests such as judgment liens, garnishments, statutory liens, mortgages, deeds of' trust, and other security interests. List creditors in alphabetical order to the extent practicable. If all secured creditors will not fit on this page, use the continuation sheet provided. Ii`any entity other than a spouse in a joint case may be jointly liable on a claim, place an "X" in the column labeled "Codebtor," include the entity on the appropriate schedule of creditors, and complete Schedule H - Codebtors. If' a joint petition is filed, state whether husband, wife, both of them, or the marital community may be liable on each claim by placing an "H," "W," "J," or "C" in the column labeled "Husband, Wife, Joint, or Community." It' the claim is contingent, place an "X" in the column labeled "Contingent." If the claim is unliquidated, place an "X" in the column labeled "Unliquidated." If the claim is disputed, place an "X" in the column labeled "Disputed." (You may need to place an "X" in more than one of these three columns.) Report the total of' all claims listed on this schedule in the box labeled "Total" on the last sheet of the completed schedule. Report this total also on the Summary of Schedules. [] Check this box it' debtor has no creditors holding secured claims to report on this Schedule D. CREDITOR'S NAME AND MAILING B H TE CLAIM WAS INCURRED, ~/ L ADDRESS, INCLUDING ZIP CODE s W NATURE OF LIEN, AND [ ,'r [ ~ I ,P, I WITHOUT UNSECURED T J DESCRIPTION AND MARKET VALUE I ~/! ?, I -~ ! DEDUCTING PORTION IF ~ c OF PROPERTY I ~1, I E I VALUE OF ANY SUBJECT TO LIEN I" 1 °1 COLLATE L FAIRBANKS CAPITAL CORP. SECOND MORTGAGE 3815 SOUTH WEST TEN RESlDENCELOCATEDAT3~2EUTAW [ [ I SaltLakeCity, UT841'15 .- ST;,NEWCUMBERLAND, PA J I I J l. Value t00,000.00 I lll 20,789.°° 0.00 P. O. BOX 27834 RESIDENCE LOCATED AT 3t2 EUTAW I I I Newark, NJ 07101-7834 - ST., NEW CUMBERLAND, pA , Va, uBS 100,000.00_ IIII 56,000.00 0.00 :>. O. BOX 8517 1997 HYUNDAIALANTRA LOCATEDAT J I I Values 4,500.00 [ [ J [ 4,817.00 317~00 ,. o. BOX 85!7 19s5 VOLKSWAGEN JETTA LOCATED J I J J 0,ooo.0o tilt o.00 P continuation sheets a~ached Subtotal (To~I of~is p~e) [ 87,356.00 Total [ 87,356.00 (Repo~ on Summa~ of Schedules) Copyright (c) 1996-2000 - Best Case Solutions, Inc. - Evanston. IL - (800) 492-8037 Best Case Bankruplcy In re DIANE L. GREENE Case No. Debtor SCHEDULE F. CREDITORS HOLDING UNSECURED NONPRIORITY CLAIMS State the name, mailing address, including zip code, and account number, if any, of' all entities holding unsecured claims without priority against the debtor or the property of the debtor, as of the date of filing or' the petition. Do not include claims listed in Schedules D and E. If all creditors will not fit on this page, use the continuation sheet provided. If any entity other than a spouse in a.]oint case may be jointly liable on a claim, place an "X" in the column ]abeled "Codebtor," include the entity on the appropriate schedule of creditors, and complete Schedule H - Codebtors. If a joint petition is filed, state whether husband, wife, both of them, or the marital community may be liable on each claim by placing an "H," "W," "J," or "C" in the column labeled "Husband, Wife, Joint, or Community." If the claim is contingent, place an "X" in the column labeled "Contingent." If the claim is unliquidated, place an "X" in the column labeled "Unliquidated." lfthe claim is disputed, place an "X" in the column labeled "Disputed." (You may need to place an "X" in more than one of these three columns.) Report total of all claims listed on this schedule in the box labeled "Total" on the last sheet of the completed schedule. Report this total also on the Summary of Schedules. [] Check this box if debtor has no creditors holding unsecured nonpriority claims to report on this Schedule F. C Husband. W#e, Joint, or Communily C U D 0 0 N D H N L S E DATE CLAIM WAS INCURRED AND T P CREDITOR'S NAME AND MAILING s w CONSIDERATION FOR CLAIM. IF CLAIM a u ADDRESS INCLUDING ZIP CODE T J IS SUBJECT TO SETOFF, SO STATE. N U 'r AMOUNT OF CLAIM O C G I E R E D D N A AccountNo. 4024-1160-0380-6237 1996-2001 m T CREDIT CARD PURCHASES E D BANK OF AMERICA P. O. BOX 2930 Phoenix, AZ 85062-2930 1,714.00 Account No. 4428-1350-0454-6446 1996-2001 CREDIT CARD PURCHASES CHOICE VISA P.O. BOX 8109 South Hackensack, NJ 07606-8001 1,667.00 Account No. 6011-3008-8015-1772 1996-2001 CREDIT CARD PURCHASES 31SCOVER CARD =.O. BOX 15192 Nilmington, DE 19886-1020 2,711.00 ~ccount No. 4417-1228-2110-4248 t996-2001 CREDIT CARD PURCHASES "IRST USA ~.O. BOX 15153 ¥ilmington, DE 19886-5153 4,413.00 I .continuation sheets attached Subtotal ? (Total of this page) 10,505.00 Copyright (c) 1996-2000 - Best Case Solutions. Inc. - Evanston. IL - (800) 492-8037 SIN:21074 Best Case I]anktuptcy DIANE L. GREENE Case No. Debtor SCHEDULE F. CREDITORS HOLDING UNSECURED NONPRIORITY CLAIMS (Continuation Sheet) CREDITOR'S NAME AND MAILING ADDRESS INCLUDING ZIP CODE HOME DEPOT P O BOX 105980 - DEPT 51 Atlanta, GA 30353-5980 PROVIDIAN PAYMENT PROCESSING P O BOX 30176 Los Angeles, CA 90030-0176 PSECU 1 Credit Union Place Harrisburg, PA 17110-2990 Account No. 184-38-0275 PSECU VISA 1 Credit Union Place Harrisburg, PA 17110-2990 Husband, Wife, Joint, or Community DATE CLAIM WAS INCURRED AND CONSIDERATION FOR CLAIM. IF CLAIM 1S SUBJECT TO SETOFF, SO STATE. CREDIT CARD PURCHASES CREDIT CARD PURCHASES PERSONAL LOAN CREDITCARD PURCHASES AMOUNT OF CLAIM 1,422.00 1,659.00 750.00 3EARS CARD 3.0. BOX 182149 ~.olumbus, OH 43218-2149 CREDITCARDPURCHASES 7,201.00 3heet no. 1 of I sheets attached to Scheduleof 'ors Holding Unsecured Nonpriority Claims Subtotal (Total ofthis page) Total (Report on Summary ofSchedules) 1,821.00 Copyright (c) lS96-2000 - Best Case Solutions, inc. - Evanston, IL - (800) 492-8037 Best Case Bankruptcy DIANE GREENE/5/13/02 PROPOSED DISTRIBUTION SCHEDULE DIANE L. GREENE, Vo ROBERT F. GREENE, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-1560 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE PLAINTIFF'S PROPOSED SCHEDULE OF DISTRIBUTION The parties assets and debts are to be divided 60% to wife and 40% to husband in accordance with the following schedule: NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION LIABILITY LIABILITY TO HUSBAND TO WIFE New Cumberland, PA Fairbanks Mortgage Est. (22,000.00) i : :: NET EQUITY 12,000.00 12,000.00 6,000.00 6,000.00 NET VALUE 1,780.00 1,780.00 1,780.00 Exhibit 16 Wife's Proposed Distribution Schedule DIANE GREENE/5/13/02 PROPOSED ~TSTRIBUTION SCHEDULE · NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION LIABILITY LIABILITY TO HUSBAND TO WIFE 2-B Wife and N/A daughter's joint 1997 Hyundai NET VALUE 0.00 0.00 0.00 Husband's 1989 3 25 02 2 -c Chevy Blazer Vehicle Loan NET VALUE 1,480.00 1,480.00 1,480.00 :2-D Husband's Harley 3.1.02 6,160.00 Davidson motorcycle Vehicle Loan 0.00 NET VALUE 6,160 . 00 6,160 . 00 6,160.00 2-E Joint utility TBD trailer 2-F Trailer N/A 0.00 NET VALUE TBD TBD TBD DIANE GREENE/5/13/02 PROPOSED mYSTRIBUTION SCHEDULE NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION LIABILITY LIABILITY TO HUSBAND TO WIFE 3-A Joint PSECU 10.5.01 838.73 838.73 838.73 checking account Con=~ents: Husband to retain funds ~n this account previously received by him. 3-B Wife's Waypoint 10.5.01 615.80 615.80 615.80 Bank checking account Co~m~_~ente: Wife to retain funds in this a~oOunt previously received bY =her. 3-c Wife's Waypoint 9.30.01 1,234.43 1,234.43 1,234.43 Bank Savings account 4-A Wife's SERS To be divided To be divided To be To be Retirement Plan at retirement at retirement divided at divided at retirement retirement Comments= Wife's retirement is to be divided 60% to wi~e and 40% to Husband. Wife iS to elect any option that gives her the right to withdraw at least $39,389.02 (4~}% ~- $15,755.61 end 60% = .$:23,633.41) from her c°ntr~t~on account. Wife is ko retain her 60% share of $23;6'3.41. Wife--ls als° tO re~ain husband's 40% ,hare of $].5,755.61 to make t:he 50Z40 ad~jus~nt fi~re set forth at the tad of this schedule~ The marital port~on of, a~l monthly Payments ere then to be d~vided 60% ~o wi~e and 40% ~0 humband. 4-B Husband's PSECU Est. 5,000.00 5,000.00 5,000.00 IRA ffi 5-A Husband's Est. 9,865.00 9,865.00 9,865.00 Household Goods DIANE GREENE/5/13/02 PROPOSED ~!STRIBUTION SCHEDULE NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION LIABILITY LIABILITY TO HUSBAND TO WIFE 5-B Wife's Household Est. 4,950.00 4,950.00 4,950.00 Goods 6-A Bank of America Est. (1,678.73) (499.59) 0.00 (499.59) joint credit card 6-B Choice Visa Est. (1,667.00) 0.00 0.00 0.00 joint credit, card 6~C Discover Card Est. (2,682.98) (569.31) 0.00 (569.31) joint credit card 6-D First USA joint Est. (4,413.00) 0.00 0.00 0.00 credit card $-E Home Depot Est. (1,422.00) 0.00 0.00 0.00 joint credit card 6-F Providian Est. (:1.,658.97) (493.71) 0.00 joint credit card DIANE GREENE/5/13/02 PROPOSED mTSTRIBUTION SCHEDULE NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION LIABILITY LIABILITY TO HUSBAND TO WIFE 6-H PSECU joint Visa Est. (7,261.01) (2,160.88) 0.00 (2,160.88) 6-J Wa~oint Bank Est. (2,809.12) (835.99) 0.00 (835.99) joint credit card 6-K Resurgent CA Est. (212.18) (63.14) 0.00 (63.14) joint credit card 6-A Bank One Est. (242.00) 0.00 0.00 0.00 joint credit card DIANE GREENE/5/13/02 PROPOSED nTSTRIBUTION SCHEDULE NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION LIABILITY LIABILITY TO HUSBAND TO WIFE 6-M Wife's Boscov' s Est. (30.00) (30.00) 0.00 (30.00) 6-N Walmart Est. (91.00) (91.00) 0.00 (91.00) joint credit card 6-0 1't Union National Est. {833.00) 0.00 0.00 0.00 Bank joint credit card 6-P Fleet Est. (3,000.00) 0.00 0.00 0.00 joint credit card 6-Q Citi Corp Est. (1,661.00) 0.00 0.00 0.00 joint credit card 6-R ATT Universal Est. (1,461.00) 0.00 0.00 0.00 joint credit card 6 - S Lowe s E s t. TBD TBD TBD Husband's credit card TOTAL OF ASSETS ~ LIABILITIES 38,420.29 31,123.73 7,296.56 DIANE GREENE/5/13/02 PROPOSED ~STRIBUTION SCHEDULE NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION LIABILITY LIABILITY TO HUSBAND TO WIFE Totals from above 38,420.29 31,123.73 7,296.56 Amount Due in 40/60 Division 15,368.12 23,052.17 Adjustment Figure (15,755.61) 15,755.61~ 1The adjustment figure is to be paid to wife from husband's share of wife's contribution account of her state retirement. Wife's retirement is to be divided 60% to wife and 40% to Husband. Wife is to elect any option that gives her the right to withdraw at least $39,389.02 (40% = $15,755.61 and 60% = $23,633.41) from her contribution account. Wife is to retain her 60% share of $23,633.41. Wife is also to retain husband's 40% share of $15,755.61 to make the 60/40 adjustment figure set forth at the end of this schedule. The marital portion of all monthly payments are then to be divided 60% to wife and 40% to husband. Diane Greene/5.23.02. Motion for sanctions DIANE L. GREENE, Plaintiff ROBERT F. GREENE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-1560 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE PLAINTIFF'S MOTION FOR SANCTIONS PURSUANT TO RULE 4019 AND NOW, this __ day of , 2002, comes the Plaintiff, by her attorney, DIANE G. RADCLIFF, ESQUIRE, and files this Motion for Sanctions pursuant to Pennsylvania Rules of Civil Procedure, Rule 4019 and in support thereof represents the following: 1. On or about April 16, 2002, under cover of letter bearing the same date, Plaintiff, through her attorney, Diane G. Radcliff, Esquire, forwarded to the Defendant, an original and two copies of Plaintiff's Request for Production of Documents addressed to the Defendant (~Request for Production of Documents"). A true and correct copy of the cover letter dated April 16, 2002 is attached hereto marked Exhibit "A" and made a part hereof. A true and correct copy of the Request for Production of Documents is attached hereto marked Exhibit uB" and made part hereof. - 2 - Diane Greene/5.23.02. Motion for sanctions 2 o 5 ° Since the Request for Production of Documents was served upon the Defendant on April 16, 2002, Defendant, either individually or through his attorney, has not contacted the Plaintiff, either individually or through her attorney, Diane G. Radcliff, Esquire, nor has Defendant produced the documents requested in the Request for Production of Documents. The time period allotted under the Pennsylvania Rules of Civil Procedure for providing Request for Production of Documents has expired. Sanctions may be entered by the Court upon motion Pursuant to Rule 4019(a) (1) if a party, in response to a request for production or inspection made under Rule 4009, fails to respond that inspection will be permitted as requested or fails to permit inspection as requested [Pa.R.C.P. 4019~a) ~1) ~vii)]; Sanctions should be entered against the Defendant pursuant to Rule 4019 because Defendant has failed to produce the documents requested in the Request for Production of Documents nor served any objections thereto within the thirty (30) day time period prescribed in Pa. R.C·P. 4009.12, or any agreed - 3 - Diane Greene/5.23.02. Motion for sanctions upon extension of time. [Pa.R.C.p. 4019(a) (1)(vii)] 6. No judge has previously been assigned to this case. 7. On May 23, 2002, Defendant was advised of the intended filing of this Motion and has not provided a response thereto. It is therefore assumed that Defendant opposes this Motion. W-~EREFORE, pursuant to Pa. R.C.P. 4019, Plaintiff respectfully requests this Honorable Court to enter an Order requiring the Defendant to produce the documents requested in Plaintiff's Request for Production of Documents duly served upon the Defendant on April 16, 2002. Respectfully submitted, ELI~qRAD~L-~FF, ESQUIRE dle Road , PA 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 Attorney for Plaintiff Diane Greene/5.23.02. Motion for sanctions CERTIFICATE OF SERVICF AND NOW, this day of , 2002, I, DIANE G. RADCLIFF, ESQUIRE, hereby certify that I have this day served a copy of the foregoing document upon the following named person, by mailing same by first class mail, postage prepaid, addressed as follows: ROBERT F. GREENE 312 EUTAW STREET NEW CUMBERLAND, PA 17070 Respectfully submitted, RADC~, ESQUIRE Fax: (717) 975-0697 Supreme Court ID # 32112 - 5 - EXIqlRIT "A" DIANE G. RADCLIFF, ESQUIRE > 3448 Trindle Road Attorney at Law O1~0~ Camp Hill, Pennsylvania 17011 Phone: (717) 737-01 Facsimile: (717) 975-0697 April 16, 2002 Robert F. Greene 312 Eutaw Street New Cumberland, PA 17070 RE: Greene v. Greene Dear Mr. Greene: I am enclosing with this letter a copy of Mrs. Greene's Inventory which was filed with the Prothonotary on April 8, 2002. Also enclosed are copies of all of the documents in my possession which verify the values set forth on the inventory where indicated. I have also prepared and am enclosing an Original and two (2) copies of the Plaintiff,s Request for Production of Documents directed to the Defendant, Robert F. Greene. In accordance with Pennsylvania Rules of Civil Procedure, Rule 4009, the Defendant is allotted thirty (30) days in which to provide this office with copies of the documents requested or to make the same available to my office for copying. Pursuant to this discovery request you should note that I am specifically looking to obtain the following: 1. Statements for the two mortgages against the marital home as of date of separation and as of the current date. 2. An appraisal of your two automobiles and Harley Davidson Motorcycle if you disagree with the Kelley Blue Book values set forth on this Inventory. 3. Valuation of the joint utility trailer. Page 2 Statement of your PSECU IRA account as of the date of separation. Proof of any payments made by you on any of the marital obligations listed on the Inventory or any other obligations you claim are marital. Any other documentation which you intend to produce or use at the hearing in this case. Very truly yours, DGR/rzg Enclosure cc: Diane L. Greene DIANE G. RADCLIFF, ESQUIRE EXHIBIT "B" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIANE L. GREENE, Plaintiff ROBERT F. GREENE, Defendant : NO. 02-1560 CIVIL TERM : CIVIL ACTION - Y~AW : DIVORCE TO: PLAINTIFF'S REOUEST FOR PRODUCTION OF DOCUMENTR DIRECTED TO DEFENDANT ROBERT F. GREENE 312 Eutaw Street New Cumberland, PA 17070 You are requested, in accordance with Pa. R.C.P. No. 4009, within thirty (30) days available to Plaintiff's 3448 Trindle Road, Camp Hill, Pennsylvania, arrangements mutually satisfactory to the undersigned of service of this Request to make attorney, Diane G. Radcliff, Esquire, at or otherwise make for inspection and/or copying, the following requested documents. f~_A!qE--G.~RADCLIFF, ESQUIRE ~%'~448 Tr,/~hdle Road Camp Hill, PA 17011 Supreme Court ID # 32112 Attorney for Plaintiff Date: April 16. 2002 2 o 3 o DEFINITIONS AND INSTRUCTIONS ~Document" or '~Documentation" means any written, printed, typed or other graphic matter of any kind or nature, including but not limited to, agreements, contracts, assignments, letters, telegrams, inter-office communications, memoranda, reports, records, transcripts, instructions, specifications, notebooks, diaries, minutes, photocopies, charts, graphs, notes, minutes of meetings, plans, descriptions, photographs, motions pictures, videotapes, mechanical or electronic sound recordings or transcripts thereof, computer records, disks tapes or other media and any other retrievable data, whether an original or a copy made by any means, including any non- identical copy (whether different from the original because of any alterations, notes, comments, or otherwise), together with any supplements or attachments thereto or enclosures therewith. "Date" means the exact day, month and year if ascertainable, or if not, the best approximation including relationship to events· "Person" means an individual, corporation, proprietorship, partnership, association or other entity. 4. "Plaintiff" shall mean the Plaintiff(s) to this litigation. 5. ~'Defendant" shall mean the Defendant(s) to this litigation. 6. '~Relate to" (or a form thereof) shall mean constituting, reflecting, representing, supporting, contradicting, referring to, describing, analyzing, noting, embodying, containing, mentioning, studying, recording, discussing, evaluating or relevant thereto. As indicated, the term necessarily includes information which is in opposition to as well as in support of the position or positions you have taken in this action. 7. '~Reflect" (or a form thereof) shall mean to embody, contain, record, note, refer to, relate, describe, be relevant to, state and/or mention. 8. Whenever the expression '~and/or" is used in these Requests, the documents called for should be set out both in the conjunctive and disjunctive, and wherever the documents is set out in the disjunctive, it should be given separately for each and every element sought. 9. Whenever a Request is framed in the singular, it shall also be taken in the plural or visa versa. 10. The use of any tense of a verb shall be considered to also include within its meaning all other tenses of the verb so - 3 - used. 11. With respect to any document or communication for which you claim a privilege, state the privilege involved, the factual and legal basis of the privilege, the identity of the document or communication, including the general subject matter, but not its substance, by stating (a) the date; (b) author or addressor; (c)addressee any recipients of all copies or of the communication; (d) the type of document (e.g. notes, letter, memorandum, telegram, photograph, brochure, chart) or some other means of identifying it; and (e) its present location or custodian. 12. No Request is to be without a response. If the answer to a Request or a subparagraph of a Request is 'lnone" or ~'unknown" such statement should be written in the responses. If the request is inapplicable, '~N/A" must be written in the answer. If a document is omitted because of the claim of privilege, the basis of the privilege is to be stated. 13. These Requests are continuing, and any documents secured subsequent to the filing of your answers which would have been included in the answers had it been known or available, are to be supplied by supplemental answers and/or documents. 14. If you object to the production of any document on the grounds that the attorney-client, attorney work-product or any other privilege which is applicable thereto, you shall, with respect to that document: a. State its date; b. Identify its author; c. Identify each person who prepared or participated in the preparation of the document; d. Identify each person who received it; e. Identify each person from whom the document was received; f. State the present location of the document and all copies thereof; g. Identify each person who has ever had possession, custody or control of it or a copy thereof; and h. Provide sufficient information concerning the document and the circumstances thereof to explain the claim of privilege and to permit the adjudication of the propriety of that claim. DOCUMENTS REQUESTED 1. INCOME: With respect to you income, please provide: a. Your complete tax return with all schedules and W-2 statements for the 2001 calendar year; b. Any documents verifying or indicating any other income you have received in the last year. 1. REAL ESTATE: With respect to any real estate in which you or your spouse had an interest as of October 6, 2001, (Separation Date), please provide: a. b. The deed. The mortgage and note for any mortgage against the real estate. Statements indicating balance owed on any mortgage as of October 6, 2001, (Separation Date) and as of the date of your answers to this Request. Any documents indicating the value of the real estate, including, but not limited to, any appraisals, comparative market analysis and/or the current and prior - 6 - tax assessments, as of: 1. The date of marriage, if premarital; 2. The date of acquisition; 3. October 6, 2001, (separation date), 4. As of the date of your answers to this Request 3. VEHICLES: With respect to any vehicle in which you had an interest as of October 6, 2001, (Separation Date) please provide any and all documents and/or statements showing or indicating: a. The purchase of the vehicle. b. The value of the vehicle as of: 1. October 6, 2001, (Separation Date); 2. Current Date. c. Any optional equipment or features on the vehicle and the vehicle milage. d. The balance owed on any loan for the vehicle as of: 1. October 6, 2001, (Separation Date); 2. Current Date. e. If the vehicle has been sold or traded in on or after October 6, 2001, (Separation Date), the value received from that sale or trade in. - 7 - 4. PENSIONS PLANS ~ RETIREM~k~T ACCOUNT~: With respect to any individual retirement account, 401K Plan, profit sharing plan, pension, ESOP or other tax deferred retirement plan ("Retirement Plans") in which you had an interest as of October 6, 2001, (Separation Date), please provide any and all documents and/or statements showing or indicating: So bo The value or balance of the Retirement Plan, as of October 6, 2001, (Separation Date). The value or balance of the Retirement Plans and all statements issued for the Retirement Plans after October 6, 2001, (Separation Date) to the current date. A//y benefit booklets and/or annual statements issued for the Retirement Plans as of October 6, 2001, to the present date. FINANCIAL ACCOUNTS: With respect to any financial accounts or holdings in which you or your spouse had an interest in including, but not limited to, checking accounts, savings accounts, certificates of deposit, investment accounts, or the like (~'Financial Holdings")as of October 6, 2001, (Separation Date), please provide any and all documents and/or statements showing or indicating: a. The value of or balance in the Financial Holdings as of October 6, 2001, (Separation Date) (include registers and statements); b. The disposition, status or value of the Financial Holdings after October 6, 2001, (Separation Date) to the present date. STOCKS AND SECURITIM~: With respect to any stock, 7 o stock investment account, stock plan, mutual funds or other securities or holdings ("Securities")in which you or your spouse had an interest as of October 6, 2001, (Separation Date), please provide any and all documents and/or statements showing or indicating: a. The number or shares and/or value of the Securities as of October 6, 2001, (Separation Date). b. The number or shares and/or value of the Securities issued after October 6, 2001, (Separation Date) to the present date (include all statements issued for the securities as of and after October 6, 2001, Date) to the present. (Separation With respect to any life insurance policy in which you and/or - 9 - your spouse had an interest, beneficiary, as provide any and indicating: whether as the owner, insured or of October 6, 2001, (Separation Date), please all documents and/or statements showing or The names of the policy owner, insured and beneficiaries; The cash value as of October 6, 2001, (Separation Date) The current cash value, 8. BUSINESSES: With respect to any business in which you and/or your spouse had an interest,, please provide any and all documents and/or statements showing or indicating: a. The nature of the business; b. The ownership of the business; c. The assets and debts of the business as of October 6, 2001, (Separation Date); d. The current assets and debts of the business; e. Any depreciation schedules for the assets of the business issued as of and after October 6, 2001, (Separation Date) to the present date. OTHER ASSETS: With respect to any other asset not otherwise specifically - 10 - delineated herein ("Other Assets") in which you and/or your spouse had an interest, please provide any and all documents and/or statements showing or indicating: a. The existence and value of the Other Assets as of October 6, 2001, (Separation Date). b. The disposition of the Other Assets after October 6, 2001, (Separation Date); c. The value of the Other Assets as of the current date. 10. NON-MARITAL ASSET~: With respect to any asset which you or your spouse have claimed as non-marital, in whole or in part, please provide any and all documents and/or statements showing or indicating: a. The value of the non-marital asset as of: 1. The date of marriage, if premarital; 2. The date of acquisition; 3. The current date. b. The balance owed on any liens or encumbrances against the non-marital asset as of: The date of marriage, if premarital; The date of acquisition; The current date. - 11 - 11. DEBTS: a. Documents confirming or demonstrating the existence and balance owed on any debts which you and/or the Plaintiff owed as of: 1o Date of marriage, if premarital; 2. October 6, 2001, (Separation Date); and, 3. Issued after October 6, 2001, (Separation Date) to the present date. b. Any and all documents and statements showing your payment, in whole or in part, or any of the aforesaid debts made on or after October 6, 2001, (Separation Date). 12. PROPERTY TRANSFERRED: With respect to any property transferred by you and/or your spouse on or after October 6, 2001, (Separation Date), or within three years of the date of commencement of the current action, please provide any and all documents indicating: a. The name of the transferor and/or transferee; b. The date of the transfer; c. The consideration for the transfer (value received by transferor); do Any additional terms of the transfer. 12 13. APPRAISALS, EXPERT REPORT~, ~ EX~IBIT~: With respect to any appraisals, market analysis,'reports of value, expert reports, exhibits or other documents, please provide any and all documents which indicate, show or demonstrate: a. Any information relevant to any issue in this divorce case including, but not limited to, any of the factors set forth in the Divorce Code to be considered in equitable distribution, alimony, alimony pendente lite, counsel fees and costs; the Separation Date; fault grounds for divorce; the value of any marital assets, and any marital debt owed, to the extent that documentation has not been otherwise requested herein. b. Any exhibits which you intend to produce at the trial or hearing in this case. - 13 - CERTIFICATE OF SERVIC~ AND NOW, this day of ~_)LA~ 2002, I, DIANE G. RADCLIFF, ESQUIRE, hereby certify that I have this day served a copy of the within REQUEST FOR PRODUCTION OF DOCUMENTS, by mailing same by first class mail, postage prepaid, upon the following named person(s), addressed as follows: ROBERT F. GREENE 312 Eutaw Street New Cumberland, PA 17070 Respectfully submitted, Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 Attorney for Plaintiff 14 DIANE L. GREENE, Plaintiff ROBERT F. GREENE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-1560 CIVIL TERM ORDER OF COURT AND NOW, this 4th day of June, 2002, upon consideration of Plaintiff's Motion for Sanctions Pursuant To Rule 4019, a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. Diane G. Radcliff, Esq. 3448 Trindle Road Camp Hill, PA 17011 Attorney for Plaintiff Robert F. Greene 312 Eutaw Street New Cumberland, PA 17070 Defendant, Pro Se BY THE COURT, /Wesley O lerF,~., J. irc Diane Greene/6.28.02.Praecipe Withdraw Economic Claims DIANE L. GREENE, Plaintiff ROBERT F. GREENE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-1560 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO WIT~IDRAW EQUITABLE DISTRIBUTION CLAIM TO THE PROTHONOTARY OF THE SAID COURT: Please withdraw the claim for Equitable Distribution previously filed by Plaintiff in her divorce Complaint filed in the above referenced case. Respectfully submitted, Camp Hill, PA 17011 PHONE: (717) 737-0100 Fax: (717) 975-0697 Voice Mail: (717) 558-5518 I.D. No. 32112 Attorney for Plaintiff - 1 - DIANE L. GREENE, Plaintiff ROBERT F. GREENE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERL~LND COUNTY, PENNSYLVANIA : : NO. 02-1560 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA : : SS.: COUNTY OF CUMBERLAND : Before me, the undersigned officer, personally appeared DIANE L. GREENE, Plaintiff in the above entitled case, who being duly sworn or affirmed according to law, deposes and says that the Defendant, Robert F. Greene is not in the military service of the United States of America, or any of its allies, at any time during these proceedings from the date of commencement of this action on April 2, 2002 to the date of this Affidavit on August 19, 2002, and has personal knowledge that the Defendant is now living at 312 Eutaw Street, New Cumberland, PA 17070 and is a resident of Cumberland County, Pennsylvania and is and has been either unemployed or is self employed doing maintenance work from the date of their separation to the date of this Affidavit. DIANE L. GREENE, Plaintiff Sworn to and subscribed before me this 19th day of August, 2002.~-~ ~0 t~P~b~l c ~_~s~ion expires: ~y ~ommma on Ex~re~ ~. 11, ~4 I Melllber, Pennsylvanle Assoctatfon of Nolarle~ DIANE L. GREENE, Plaintiff ROBERT F. GREENE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-1560 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this 14th day of August, 2002, I, DIANE G. RADCLIFF, ESQUIRE, hereby certify that I have this day served a copy of the Praecipe to Withdraw Equitable Distribution Claim filed with the Prothonotary on August 12, 2002, upon the Defendant, Robert F. Greene, by mailing same by first class mail, postage prepaid, addressed as follows: Robert F. Greene 312 Eutaw Street New Cumberland, PA 17070 Respectfully submitted, Camp Hill, PA 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 Attorney for Plaintiff DIANE L. GREENE, : Plaintiff : : Vs. : : ROBERT F. GREENE, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 1560 CIVIL IN DIVORCE MASTER'S REPORT Proceedings held before E. Robert Elicker, II, Master 9 North Hanover Street, Carlisle, Pennsylvania proceedings held on August 19, 2002, commencing at 9:05 a.m. APPEARANCES: Diane G. Radcliff Attorney for Plaintiff Robert F. Greene Defendant (Did not appear) PROCEDURAL HISTORY The divorce complaint was filed on April 2, 2002, raising grounds for divorce of irretrievable breakdown of the marriage and indignities. The complaint also raised an economic claim for equitable distribution. The Master was appointed on motion of the Plaintiffs counsel on April 24, 2002. The Master directed that pretrial statements be filed on or before May 28, 2002; a pre-hearing was set for June 28, 2002, at 9:30 a.m. Plaintiff's counsel appeared for the pre-hearing conference; neither the Defendant nor an attorney representing the Defendant appeared. Following the pre-hearing conference with Plaintiff's counsel, the Master scheduled a hearing on the indignities claim for Monday, August 19, 2002, at 9:00 a.m. Notice of the hearing was sent to the parties and counsel for Plaintiff. The notice to the Defendant was sent at his address at 312 Eutaw Street, New Cumberland, Pennsylvania by regular mail. The notice sent to the Defendant was not returned to the Master's office by the post office. This is the address that the Plaintiff's counsel and the Master have used during the course of the proceedings in this case to communicate with the Defendant. On August 12, 2002, the Plaintiff's counsel filed a praecipe withdrawing the claim for equitable distribution leaving for the Master's consideration the claim of indignities as grounds for divorce. Plaintiff, her witnesses, and counsel appeared for the divorce hearing on August 19, 2002, at 9:00 a.m. Neither Defendant nor an attorney on his behalf appeared for the hearing. Testimony was placed on the record, the record was closed, and the Master proceeded to prepare and file his report. FINDINGS OF FACT 1. The Plaintiff, Diane L. Greene, resides at 12 West Pine Street, Enola, Pennsylvania 17025; the Defendant, Robert F. Greene, resides at 312 Eutaw Street, New Cumberland, Pennsylvania 17070. 2. There are no jurisdictional issues in this case as both parties have resided in the Commonwealth of Pennsylvania for a period in excess of six months prior to the commencement of the divorce action. 3. The parties were married on February 2, 1977; they separated October 6, 2001. 4. Wife is 56 years of age and husband is 47 years of age. 5. The parties are the parents of three children, all of whom are emancipated. Wife has two children from a prior marriage and husband has one child from a prior mai~iage; these children also are emancipated. 6. The complaint in divorce was served on the Defendant by certified mall, restricted delivery on April 13, 2002. An affidavit of service with the attached return receipt card is made part of the record. 7. The notice of the hearing before the Master on August 19, 2002, was sent to the Defendant at 312 Eutaw Street, New Cumberland, Pennsylvania 17070. The notice was not returned to the Master's office by the postal service. 8. Wife left the marital residence on October 6, 2001, as a result of husband's physical and mental abuse of her and the children. The abusive conduct occurred over a substantial period of the marriage. 9. Husband's excessive use of alcohol resulted in incidents toward wife where husband hit, slapped, and punched her on numerous occasions. 10. As a result of husband's physical abuse toward wife, he broke wife's ribs and on another occasion a finger. 11. Husband punched wife in the stomach when she was pregnant. 12. Husband's physical abuse toward wife also involved dragging wife around the house by her hair, pulling her out of cars and pulling her by her hair and punching her. 13. Husband used abusive language toward wife calling her a slut, a whore, and a bitch. These comments were made during fights which occurred a couple of times a week. 14. Husband told wife that he did not love her and that he was disappointed that she gave birth to three girls rather than boys. 15. Husband's conduct toward the children was physically and emotionally abusive, hitting one of the children so hard that she had blood on her head. He would also drag the children out of bed and confront them in front of wife. On those occasions he would slap them and hit them with a board. On another occasion he threatened the family with a shot gun. 16. Husband would express his anger by throwing ash trays around the house, damaging windows, damaging the banisters and punching walls and kicking out the front door. 17. Not only did husband abuse the family members but he also abused the pets by hanging dogs on their chains. 18. Wife finally decided to leave husband when she learned that husband had sexually abused her daughter from a prior maa-~'iage. 19. During the course of the ma~-i-iage, wife made every effort that she could to keep the family together. Nothing in the record indicates that wife engaged in any conduct which would provoke husband's abusive conduct toward her and the family. ~CONCLUSION OF LAW Wife is an innocent and injured spouse and husband's conduct toward wife was of such a continuous nature as to make her life intolerable and burdensome. DISCUSSION The conduct which husband engaged in toward wife as set forth in the testimony and as outlined in the findings of fact hereinabove was of such a nature as to make wife's life intolerable and burdensome. Wife had to endure the continuing outrage of husband resulting in physical abuse and abusive name calling. Wife also had to endure the humiliation of husband's conduct toward the children in the household. The continuing nature of husband's conduct toward wife and the children and wife's knowledge of husband's sexual contact with the daughter of wife from a prior marriage finally caused wife to separate physically from husband and leave the marital residence. She finally realized that she could no longer endure on a dally basis the physical and emotional abuse that husband had wreaked on herself and the family. Nothing in the record indicates that wife in any way provoked husband's conduct. Wife made every effort by working and contributing income to the family to keep the family together. Nothing in the record would indicate that wife engaged in any conduct which would in any way excuse husband's conduct toward herself and the children. RECOMMENDATION Wife is entitled to a divorce on the grounds of indignities to the person under Section 3301 (a)(6) of the Domestic Relations Code. Respectfully submitted, E. Robert Elicker, II Divorce Master IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DIANE L. GREENE, Plaintiff Ve ROBERT F. GREENE, Defendant Case No.: 02-1560 Civil Term TO: It appearing that the Master's report in the above stated case has been filed for ten (10) days, that no exceptions have been filed thereto, and that all the requirements of law and Rules of Court have been met, you are hereby directed to submit the said case to the Court of Common Pleas of Cumberland County, Pennsylvania~_~. IANE ~~ ESQUIRE k 3~f~ind~ Road Cah~_~A 17011 (717) 737-0100 I.D. No. 32112 Attorney for Plaintiff Curtis R. Long PROTHONOTARY DATED: September 16, 2002 STATE OF iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNA. Plaintiff VERSUS ROBERT F. GREENE, Defendant NO. 02-1560 CIVIL TERM DECREE IN DIVORCE AND NOW,~ , ~-~.~L~, IT IS ORDERED AND DECREED THAT DIANE L. GREENE , PLAINTIFF, AND ROBERT F. GREENE , 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; No issues are outstanding. by ThE COURT: ~O Atte.~ · j. TARY