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HomeMy WebLinkAbout02-2542MARGARET M. KIPPS Plaintiff JEFFREY A. KIPPS Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA. : CIVIL ACTION - LAW : DIVORCE NOTICE YOU I{AVE BE~/~ Su~u 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 in 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, includig custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the office of the Court Administrator, 4th Floor, Cumberland County Courthouse, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM A/qY 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: Court Administrator 4th Floor Cumberland County Courthouse Carlisle, PA 17013 717.240.6200 MARGARET M. KIPPS : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNA. : JEFFREY A. KIPPS : CIVIL ACTION- LAW Defendant : DIVORCE through Offices, Harrisburg, Pennsylvania, and files the following: COUNT I DIVORCE PI]RSUANT TO SECTION 3301(c) OF THE DIVORCE CODE COMPLAINT AND NOW, comes Plaintiff, Margaret M. Kipps, by and her attorney, James W. Abraham, Esquire, Abraham Law 1. Plaintiff, Margaret M. Kipps, is an adult individual who currently resides at 3063 Ritner Highway, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant, Jeffrey A. Kipps, is an adult individual who resides at 516 Crains Gap Road, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff and Defendant have been bona fide residents of the Cormnonwealth of Pennsylvania for at least six (6) months ir~aediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on March 24, 1990 in Carlisle, pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Defendant may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are not members of the Armed Forces of the United States. W~n~REFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce dissolving the marriage. CO~]I~T II - II, DIGNITIES 9. Defendant has caused such Plaintiff which has made life burdensome Plaintiff, the innocent and injured spouse. indignities against and intolerable for W~EREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce dissolving the marriage. DATE: 5/24/02 Respectfully submitted: James W. Abraham, Esq. Abraham Law Offices 513 North Second St. Harrisburg, PA 17101 (717) 232-7825 Attorney for Plaintiff Margaret M. Kipps VERIFICATION verify and confirm that I have reviewed the foregoing document and the statements therein are true and correct to the best of my knowledge, information and belief. I further understand that any false statements made herein are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities · CERTIFICARTE OF S~l~VlC~ I, James W. Abraham, Esquire, the undersigned, hereby certify that I have served a true and correct copy of the foreoing document, by certified mail, to the following person at the following address on the date stated below: Jeffrey A. KIpps c/o Cletus Kipps 516 Crains Gap Road Carlisle, PA 17013 ATE: 5/24/02 James W. Abraham, Esquire MARGARET M. KIPPS Plaintiff/Petitioner JEFFREY A. KIPPS Defendant/Respondent · IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA. : : NO. 02-2542 : : CIVIL ACTION - LAW · DIVORCE PETITION FOR SPECIAL RELIEF FOR EXCLUSIVE POSSESSION OF MARITAL RESIDENCE (Pursuant to Pa.R.C.P. 1920.43 and 23 Pa.C.S.A. Section 3323(e)) TO THE HONORABLE. THE JUDGES OF SAID COURT: 1. Plaintiff/Petitioner, Margaret M. Kipps (hereinafter "Wife") is an adult individual who currently resides at the former marital residence, located at 3063 Ritner Highway, Carlisle, Cumberland County, Pennsylvania. 2. Defendant/Respondent, Jeffrey A. Kipps (hereinafter "Husband") is an adult individual whose address is 479 Wolfs Bridge Road, Carlisle, Pennsylvania. 3. The parties have two (2) minor children from this marriage, Joseph Allen Kipps, born July 22, 1990, age eleven (11); and Ashley Nicole Kipps, born April 24, 1993, age nine (9). 4. Husband and Wife's date of final separation occurred on or about early October, 2001 when Husband left the marital residence. The children remained with Wife at the time of separation and have continued in Wife's primary physical custody through the present. MARGARET M. KIPPS Plaintiff/Petitioner JEFFREY A. KIPPS Defendant/Respondent : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA. : : NO. 02-2542 : : CIVIL ACTION - LAW · DIVORCE RULE AND NOW, this ~%~day of ~ ~ , 2002, a Rule is hereby issued upon Defendant/Respondent, Jeffrey A. Kipps, to show cause as to why the relief requested in the Petition hereto should not be granted. This Rule is returnable within days from the date of service upon Defendant/Respondent. 5. On May 24, 2002, Wife filed for divorce and as alleged therein, Wife believes and therefore avers that Husband co~,u,itted indignities as to Wife, including but not limited to, the indignity of Husband's relationship with another woman prior to separation. 6. After separation, Husband's indignities and hostile, reckless and egregious behavior continued as Husband, while vacationing in Myrtle Beach, South Carolina with his girlfriend on or about May 17, 2002, forged Wife's name on a credit card application for Husband's own personal gain and benefit, with complete and reckless indifference to wife. A true and correct copy of the MBNA credit card application completed by Husband is attached hereto and made part hereof as Exhibit "A". 6. From the date of separation until Wife's filing of divorce, Husband lived away from the marital residence and would go to the marital residence for purposes of visiting with the parties' children. 7. During the aforesaid time period, Wife repeatedly requested that Husband visit with the children at his own residence as Husband, by re~ining at the marital residence, was causing stress, emotional trauma and confusion with the children and was otherwise subjecting the children to a hostile environment in view of the marital difficulties of Husband and Wife. 8. On or ~hout the time in which Wife filed for divorce on May 24, 2002, Husband retained Attorney Herbert C. Goldstein of Harrisburg, Pennsylvania as counsel in the divorce action. 9. By agreement of the parties through their respective counsel, Husband agreed to Wife having exclusive possession of the marital residence, except for picking up the children for visitation away from the former marital residence. A true and correct copy of Wife's counsel's letter of May 28, 2002 and Husband's counsel's letter of June 10, 2002, confirming the agreement for Wife's exclusive possession of the marital residence, are attached hereto as Exhibit "B". 10. In order to facilitate the agreement for Wife's exclusive possession of the marital residence, Husband and Wife agreed, by and through their counsel, to schedule a time for Husband to go onto the marital residence and remove certain items of property agreed to by the parties, which they agreed to do on Saturday, June 13, 2002. See Attorney Goldstein's letter of June 10, 2002, Exhibit "B" hereto. 11. On June 13, 2002, Husband met with Wife and removed several items of property from the marital residence, some of which was agreed to by Wife. 12. On June 13, 2002, Husband caused greater stress, hostility and confusion for the children as Husband used and instructed the parties' eleven (11) year old son to take pictures of property in each room of the residence to take inventory thereof and unnecessarily placed their son in the middle of the parties' dispute; and unnecessarily subjected their son to the parties' hostility and conflict. 13. Thereafter, Husband was not satisfied with the items removed on June 13, 2000 and without prior notice to Wife, Husband attempted to sneak into the attic through the garage during a custody exchange to remove more personal property, again using the parties' eleven (11) year old son as a decoy to pre-occupy and distract Wife, however, Wife discovered Husband in the attic and no property was removed. 14. Thereafter, Husband was not satisfied with the items removed by agreement and therefore, Husband, knowing that Wife was on vacation in Ocean City, Maryland during the week of July 1 through July 9, entered the premises on two (2) different days during said week and it is believed and therefore averred, that Husband removed more property from the residence. 15. Wife submits that special relief is warranted to exclude Husband from the marital residence, due to: A. the egregious conduct of Husband's use of the parties' twelve (12) year old son by placing him in the middle of his parents' conflict as stated hereto; B. the hostile and volatile environment Husband's presence creates for the children; C. the egregious and hostile actions in Husband's removal of property from the marital residence by stealth and deception, in reckless indifference to Wife; Do the reckless and unpredictable actions of Husband as illustrated by Husband's egregious decision to forge his Wife's name for his own benefit; and by Husband's complete and blatant disregard of his agreement to give Wife exclusive possession of the marital residence. 16. Husband's unpredictable and completely untrustworthy behavior has left Wife no alternative but to seek a court order to preclude Husband from them arital residence as he originally agreed to do, so as to preclude further emotional damage and stress to the children and maintain the children in an emotionally stable environment. 17. Husband's unpredictable and completely untrustworthy behavior has caused unnecessary stress and au_xiety for Wife as she now has the constant worry and concern that Husband, on any given day while Wife is working or away from her residence, will continue to raid the marital residence and remove property and possibly improperly convert said property. 18. Wife submits that granting the Petition does not cause prejudice to Husband who has secured a separate residence and any possible prejudice is greatly outweighed by the detriment to the children caused by Husband's entry onto the marital residence for non-custodial exchange purposes. WHEREFORE, Plaintiff/Petitioner Margaret M. Kipps, respectfully requests Your Honorable Court to grant the following relief: 1. Award Wife exclusive possession of the former marital residence and the surrounding property; 2. Preclude Husband from entering the fo£mer marital residence or entering onto said surrounding property except for custody exchanges; 3. Order Husband to return to Wife any property taken from the marital residence except for the items taken on June 13, 2002. 4. This Order shall remain in effect until further order of Court. Respectfully submitted: James W. Abraham, Esquire Abraham Law Offices 513 North Second St. Harrisburg, PA 17101 (717) 232-7825 Attorney for Plaintiff/ Petitioner, Margaret M. Kipps DATE: 7/11/02 VERIFICATION hereby verify and confirm that I ~i'~--~ , the undersigned, have reviewed the foregoing document and the statements therein are true and correct to the best of my knowledge, information and belief. I further understand that any false statements made herein are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. 5/10.,6~002 EA# 02."17~3 $ ~$ I L~MES W ABRAHAM ~.TTORNEY AT LAW BRAH M LAW OFFICES 513 NORTH SECOND STREET HARRISBURG, PA 17101 (717) 232-7825 FAX: (717) 232-7827 9 SOUTH WATER STILEET HUMMELSTOWN. PA i 703~ (717) 566-955u * Reply' to Harrisburg May 28, 2002 HAND DELIVERED Herbert C. Goldstein, Esq. 204 State St. Harrisburg, PA 17101 RE: Kipps v. Kipps Dear Corky: Pursuant to our telephone conversation, enclosed please find a true and correct, date-stamped copy of the Complaint in Divorce filed in Cumberland County. I have enclosed an Acceptance of Service for your review and/or signature if acceptable. As we also discussed, this case is relatively straight- forward and hopefully, the parties can reach a resolution on all matters without extensive litigation. However, in the interim, my client is requesting that since the parties are now physically separated, Mr. KiDps would ~erclse vls~tatio~_~q~' t-~h~ ~ild~en on his own, outside thu. ~mer marital residence; and that ne otherwise exclude himself from t~e residence as it will only cause friction between the Aarties~Of course, if there is a special reason or need to be at ~_~ar~ai ~ide~c~_my client will.~e haD~y to a~s~Odate him~ ~ith ~op~ notice. If this is a problem, please ao . As always, please do not hesitate to contact me in regard to any aspect of this case. Sincerely, James W. Abraham JWA:da Enclosure c: Margaret M. Kipps THE LAW OFFICES OF HERBERT CORKY GOLDSTEIN, ESQUIRE 204 State Street P.O. Box 10363 Harrisburg, PA 17~5-0363 Direct Line: (717) 236-6491 Fax: (717) 233-6740 June 10, 2002 Attorney James Abraham 513 North Second Street Harrisburg, PA 17101 Re: Kipps Dear Jim: 1. Jeff agrees for now to keep away fxom their home, but he will always be allowed, without interference~ to pick-up and bring back his children. By his agreeing to _havin_g_l~)S~.q~inn now. he gives up none of his equity in the house. 2. It is agreed that the house will be appraised. We cannot use the tax assessment value, as that is not atme market figure. 3. It is agreed that your client, Margaret, will maintain' the house, the pool, the landscaping, and the grass. Jeff would have gladly done it, but your client doesn't want him to do it. But, she must do it and not.let the house and grounds deteriorate so it will be appraised for a much lower market value. 4. Their house will be sold and the net proceeds divided equally. However, either spouse can buy the other spouse out of their aA share. If Margaret wants the house, she must keep the house at a quality level, and not let it become run down, so the appraised value will be lower. It was Jeff's money that bought the house and he, himself, built the pool. All he wants is his aA fair share of the real market value. 5. Margaret can keep all the furniture and furnishings, but Jeff wants his own stuff. Margaret can also keep all the equipment that is used to maintain the house and the grounds. Jeffwants his weights, gun cabinet, some photographs and family videos. 6. Their pensions are about equal, and Margaret's is probably more, but each may keep their own pension. 7. Jeffwill continue to pay to Margaret $200.00 a week in child support. However, this is to be reviewed as we move ahead. Attorney James Abraham Page 2 June 10, 2002 Jeff will ~o for however Ion it takes 8. ~ am hopeful ,tl3ere will not be any problems~. 9. Jeff will keep Margaret and the kids on his medical, dental, and eye insurance program. He will continue all coverage for the ~ds after the Divorce. 10. Jeff will keep his Harley and dirt bikes. 11. The vehicles have been divided. I am hopeful that you and I will be able to resolve this matter, without the necessity of a Master's Hearing, etc For the sake of the children, I hope both of our clients will respect each other and not "use" the kids to get hack at each other. Now and when this is over, I am hopeful that Margaret and Jeff will work together to resolve this without any further tension. Jim, call me. Respectfully, ~DSTEIN, ESQ. HCG:hf CERTIFICA~ OF SERVICE I, James W. Abraham, Esquire, the undersigned, do hereby certify that I have served a true and correct copy of the foregoing document, by certified mail, on the date indicated below, to the following person(s): Jeffrey A. Kipps 479 Wolfs Bridge Road Carlisle, PA 17013 DATE: 7/11/02 James W. Abraham, Esq. SAIDIS SHUFF, FLOWER & LINDSAY ATrORI~YSeAT*LAW 26 W. High Street Carlisle, PA MARGARET M. KIPPS, Plaintiff/Respondent VS. JEFFREY A. KIPPS, Defendant/Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 2002 -2542 CIVILTERM : : IN CUSTODY COMPLAINT FOR PARTIAL CUSTODY Highway, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant/Petitioner is Jeffrey A. Kipps, Bridge Road, Carlisle, Cumberland County, Pennsylvania. The Plaintiff/Respondent is Margaret M. Kipps, residing at 3063 Ritner residing at 481 Wolfs 3. The Petitioner seeks custody of the following children, Joseph A Kipps, born July 22, 1990, and Ashley N. Kipps, born April 24, 1993, who resides at 3063 Ritner Highway, Carlisle, Pennsylvania. The children were not born out of wedlock. The children are presently in the custody of Respondent, who resides at 3063 Ritner Highway, Carlisle, Pennsylvania. During the past five years, the children has resided with the following persons and at the following addresses: NAME Jeffrey A. and Margaret M. Kipps Margaret M. Kipps ADDRESS 3063 Ritner Highway Carlisle, PA 17013 3063 Ritner Highway Carlisle, PA 17013 FROM/TO Birth to 10/20/O 1 10/20/01 present SAIDIS SHUFF, FLOWER & LINDSAY ATI'ORNEYS*AT*LAW 26 W. High Street Carlisle, PA The mother of the children is Respondent, Margaret M. Kipps, currently residing at 3063 Ritner Highway, Carlisle, Pennsylvania. She is married. The father of the children is Petitioner, Jeffrey A. Kipps, currently residing at 481 Wolf's Bridge Road, Carlisle, Pennsylvania. He is married. 4. The relationship of the Plaintiff to the children is that of mother. The Plaintiff currently resides with the following person(s): the children, Joseph A. Kipps, and Ashley N. Kipps. 5. The relationship of the Defendant to the children is that of father. The Defendant currently resides with the following person(s): none 6. Petitioner has not participated as a party or witness, or in any other capacity in other litigation concerning the custody of the children in this or another jurisdiction. 7. The Petitioner has no information of a custody proceeding concerning the children pending in a court of the Commonwealth. 8. The Petitioner does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 9. The best interest and permanent welfare of the children will be served by granting the relief requested because: a) It is in the children's interests to have an ongoing and mutually enriching relationship with Petitioner. SAIDIS SHUFF, FLOWER & LINDSAY A'I~OR~S JAT'LAW 26 W. High Street Carlisle, PA 10. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children has been named as parties to this action. WHEREFORE, the Petitioner requests this Court to grant partial physical custody of the children to the Plaintiff. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: J. Lindsay,'"Esquire ID# 44693 26 West High Street Carlisle, PA 17013 (717) 243-6222 VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Jeffre~ ~,. Kipps Date: SAIDIS SHUFF, FLOWER & LINDSAY ATtORNeYS*AT*LAW 26 W. High Street Carlisle, PA MARGARET M. KIPPS PLAINTIFF JEFFREY A. KIPPS DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-2542 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, August 06, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gflroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, August 22, 2002 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilrov. Esa. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available t~o disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 AUG MARGARET M. KIPPS, Plaintiff JEFFREY A. KIPPS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02 - 2542 CIVIL IN CUSTODY CO~TO~ER AND NOW, this~ ..day of ~ , 2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: The Mother, Margaret M. Kipps, and the Father, Jeffrey A. Kipps, shall enjoy shared legal custody of Joseph A. Kipps, born July 22, 1990; and Ashley N. Kipps, born April 24, 1993. 2. During the school year physical custody shall be handled as follows: A. Mother shall enjoy primary physical custody of the minor children. Father shall enjoy periods of temporary physical custody on alternating weekends from Friday after work until Sunday at 8:00 p.m., and every Tuesday and Thursday evening from after work until 8:00 p.m. e Physical custody during the summer months shall be handled pursuant to a future court order or agreement by the parties subject to the scheduling of a second custody conciliation conference as set forth below. 4. The holiday schedule for the parties shall be as follows: The Easter holiday shall be handled such that the parties split custody on that day, with the timeframes being from 8:00 a.m. until 3:00 p.m. and 3:00 p.m. until 8:00 p.m. Those timeframes shall be alternated with Father having Easter morning in 2003. For Thanksgiving in even numbered years, Father shall have custody from 9:00 a.m. until 3:00 p.m. on Thanksgiving Day, and Mother shall have custody from 3:00 p.m. until 9:00 p.m.; in odd numbered years, the parties shall alternate this schedule. 7e De Fe For New Year's Day in even numbered years, Mother shall have custody from 9:00 a.m. until 3:00 p.m. and Father shall have custody from 3:00 p.m. until 8:00 p.m. The parties shall alternate this in odd numbered years. For July 4, Labor Day and Memorial Day, the parties shall alternate these holidays from 9:00 a.m. until 9:00 p.m. with Mother having Labor Day 2002. The Christmas holiday shall be handled with the parties splitting the time from December 24~ at Noon until Christmas Day at Noon and Christmas Day at Noon until December 26~ at Noon. The parties shall alternate this schedule with the Mother having the first segment in 2002 and the Father having the second segment in 2002. Notwithstanding the forgoing, Mother shall always have custody from 4:00 p.m. until 10:00 p.m. on Christmas Eve, and Father shall always have custody on Christmas Day from Noon until 5:00 p.m. Father shall always have custody on Father's Day and Mother shall always have custody on Mother's Day. The timeframe shall be from 9:00 a.m. until 9:00 p.m. G. The parties shall share equally the children's birthdays and will ensure that each parent has an opportunity with the children on the parent's birthday. Transportation for exchange of custody shall be shared between the parties, with the receiving party picking the children up and the normal point of pick- up being at the parent's home. Both parents shall enjoy reasonable telephone contact with the minor children when they are with the other parent. Neither parent will say anything within the hearing of the children nor will they pe:~idt anyone else to make any comments within the hearing of the children which shall demean the other party or attempt to diminish the love and affection the children have for both of their parents. The parties may modify this schedule as they agree. Absent an agreement, this schedule shall control. CC: Legal counsel for the parties shall conduct a telephone conference call with the conciliator on Friday, January 17, 2002 at 8:30 a.m. The purpose of this conference call shall be to address the issue of custody during the summer. In the event the parties cannot reach an agreement at that point, the conciliator will proceed with scheduling the case for a hearing solely on the issue as to how physical custody shall be handled in the summer. BY ~ J. /Carol J. Lindsay, Esquire flames Abraham, Esquire 4NIz/C'I?(;H,,O!~,; . ,, MARGARET M. KIPPS, Plaintiff JEFFREY A. KIPPS, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION- LAW : : NO. 02 - 2542 CIVIL : IN CUSTODY Prior Judge: CONCILIATION CONFERENCE SUMMARY R~ PORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Joseph A. Kipps, born July 22, 1990; and Ashley N. Kipps, born April 24, 1993. 2. A Conciliation Conference was held on August 22, 2002, with the following individlmlS in attendance: The Father, Jeffrey A. Kipps, with his counsel, Carol J. Lindsay, Esquire; and the Mother, Margaret M. Kipps, with her counsel, James Abraham, Esquire. 3. The parties agree to the entry of an order in the for~i~ as attached. DATE ~--~ ~-"~ uire ~C usUbt;r~yX~ o~sq SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA MARGARET M. KIPPS, Plaintiff/Respondent VS. JEFFREY A. KIPPS, Defendant/Petitioner : IN THE COURT Of COMMON PLEAS Of : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 20(:)2 - 2542 CIVIL TERM : IN DIVORCE DEFENDANT'S MOTION TO COMPEL DISCOVERY NOW COMES Jeffrey A. Kipps, Defendant above, and moves this Honorable Court as follows: 1. The parties hereto are husband and wife, having been joined in marriage on March 24, 1990. 2. The parties have been separated for approximately two years. 3. On or about January 9, 2003, Defendant served on Plaintiff a Request for Production of Documents. A copy of the Request for Production of Documents is attached hereto as Exhibit "A". 4. On February 28, 2003, Plaintiff answered the Request for Production of Documents, a copy of which answers are attached hereto as Exhibit "B". 5. In response to a request for statements of retirement information from Respondent's employer to obtain a value of a 401(k) plan and a pension plan as of the date of separation, Petitioner was provided only the 401(k) plan information. 6. On March 12, 2003, Petitioner sought a copy of the personnel policy book which would indicate what retirement benefits were available to confirm that there was no pension plan. SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Streel Carlisle, PA 7. On May 5, 2003, Petitioner renewed his request in light of his discovery that Respondent's employer does have a pension plan. 8. As of the date of this Petition, Respondent has not been provided with a copy of the pension plan or a statement as to Respondent's entitlement in the plan sufficient to obtain an appraisal. 9. Respondent's response to a second Request for Production of Documents provided a single page printout containing no identifiers (name or Social Security Number as to whose statement it is or whether it is a 401(k) statement at 10. On May 5, 2003, Petitioner sought the most recent statement Respondent was provided from her employer as; to her 401(k) retirement savings plan balance. 11. Attached hereto is a Motion for the appointment of a Master which has been filed by Petitioner. WHEREFORE, Petitioner prays this Honorable Court to issue a Rule upon the Respondent to show cause why the discovery requested should not be provided. SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for Defendant By: " Car~'J) Ein'~Eay, ~-squire ID¢'44~93 26W~'est High Street Carlisle, PA 17013 (717) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. /:' ' ' Je~eyA. Kipps Date: ~'//~/~ 3 SAIDIS SHUFF, FLOWER & LINDSAY 26W. High Street Carlisle, PA MARGARET M. KIPPS, Plaintiff VS. JEFFREY A. KIPPS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2002- 2542 CIVIL TERM : IN DIVORCE AND NOW, THIS CERTIFICATE OF SER~V~CF: DAY OF I \ A~ CAROL J. ,2003, I, I '-~- LINDSAY, ESQUIRE, OF THE LAW FIRM OF ~1S, SHUFF, FLOWER & LINDSAY, ATTORNEYS, HEREBY CERTIFY THAT I SERVED THE WITHIN DEFENDANT'S MOTION TO COMPEL DISCOVERY THIS DAY BY DEPOSITING SAME IN THE UNITED STATES MAIL, FIRST CLASS, POSTAGE PREPAID, IN CARLISLE, PENNSYLVANIA, ADDRESSED TO: MARGARET M. KIPPS c/o James W. Abraham, Esquire 513 North Second Street Harrisburg, PA 17'101 SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for Defendant By: C aF'olfi./Eind §a y, Es q'i~ire ID# 4~693 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA MARGARET M. KIPPS, Plaintiff VS. JEFFREY A. KIPPS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO, 2002- 2542 CIVIL TERM TO: MARGARET M. KIPPS C/O James W. Abraham, Esquire 513 North Second Street Harrisburg, PA 17101 DEFENDANT'S REQUEST FOR PRODUCTION OF DOCUMENTS PURSUANT TO PA. R.C.P. 4009, YOU ARE HEREBY REQUESTED TO PRODUCE THE BELOW LISTED DOCUMENTS AND/OR ITEMS FOR PURPOSES OF DISCOVERY AT THE OFFICE OF SAIDIS, SHUFF, FLOWER & LINDSAY, 26 WEST HIGH STREET, CARLISLE, PE, NNSYLVANIA 17013. THIS MATERIAL WILL BE EXAMINED AND/OR PI4OTOCOPIES. SAID DOOUMENTS OR TANGIBLE THINGS ARE TO BE PRODUCED WITHIN THIRTY (30) DAYS OF THE DATE OF SERVICE HEREOF AND SUPPLEMENTED THEREAFTER IN ACCORDANCE WITH PA. R.C.P 4009. A coPY, AS FILED, OF YOUR 2001 FEDERAL AND STATE INCOME TAX RETURNS WITH W-2S AND 1099 FORMS ATTACHED. COPIES OF STATEMENTS OF RETIREMENT INFORAMTION FROM SPRINT SUFFICIENT TO OBTAIN A VALUE OF A 401(K) PLAN AS OF THE DATE OF SEPARATION AND A PENSION PLAN AS OF "HE SAME DATE. RESPECTFULLY SUBMITTED, SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for Defend/an(; I '- Cbat~olb. IL~dsa~,, E~squire ID# 44698 26 W~' High Street Carlisle, PA 17013 717) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA MARGARET M. KIPPS, Plaintiff VS. JEFFREY A. KIPPS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 2002-2542 CIVIL TERM : : CERTIFICATE OF SERVICE AND NOW, THIS Z~ DAY OF ~'~i~[~i¢/~./.,~./-/'..'//// , 2003, I, CAROL J. LINDSAY, ESQUIRE, OF THE LAW FIRM OF-~SAIDIS, SH,U.~' FLOWER & LINDSAY, ATTORNEYS, HERESY CERTIFY THAT I SERVED THE WITHIN DEFENDANT'S REQUEST FOR PRODUCTION OF DOCUMENTS THIS DAY BY DEPOSITING SAME IN THE UNITED STATES MAIL, FIRST CLASS, POSTAGE PREPAID, IN CARLISLE, PENNSYLVANIA, ADDRESSED TO: MARGARET M. K~PPS C/O James W. Abraham, Esquire 513 North Second Street Harrisburg, PA 17101 SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for Defendant Carol J. L ,i~say, Esqui're ID# 4469~ 26 Wed High Street Oartisle, PA 17013 (717) 243-6222 MARGARET M. KIPPS Plaintiff Vo JEFFREY A. KIPPS Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 2002 - 2542 CIVIL ACTION - LAW DIVORCE PLAINTIFF'S ANSWER TO DEFENDANT'S REOUEST FOR PRODUCTION OF DOCUMENTS 1. See attached true and correct copy of Plaintiff's 2001 federal, state and local tax returns with W-2s. 2. See attached true and correct copy of Plaintiff's 401(k) retirement plan statement through her employer for January, 2003. DATE: 2/28/03 ABR3LqAM LAW OFFICES James W. Abraham, Esq. 2157 Market St. Camp Hill, PA 17011 (717) 763-1700 Attorney for Plaintiff, Margaret M. Kipps Fo,m 1040 U.S. Individual Income Tax Return 2001 Label Use the IRS label, Otherwise, please pnnt or type. Presidential Election For the year Jan ] . Dec 31, 2001, or other tax year becnning ,2001, endin9 ,20 OMB No 154a.o07~ Jeffrey A Kipps Margaret M Kipps 3063 Rttner H~h~ay Carlisle S:ate ZIP Code PA 17013 168-48-3562 Spouses Social Security Number 184-54-9105 · Important! · securdy number(s) above Campaign (See instructions ) 1 Filing Status 2 3 Check only 4 one box 5 Exemptions You Check~ng change your tax or reduce your refund. Note: aot Spouse Do you, or your spouse if filing a io,nt return, want $3 to go to this fund? ~' No  Single MalT]ed flhng jomt return (even if only one had income) Marbed filing separate return Enter spouse's SSN above & full name here Head of household (with qualifying person) (See instructions,) If the qualifying person is a child but not your dependent, enter this child's name here ~' k~. Quabfylng widow(er) with dependent child (year died ~- spouse ) (See instructions) 6a her tax return, do not check box 6a x~a Yourself. if your parent (or someone else) can claim you as a clependent on his or --[ No. of boxes m NO, of your If more than srx dependents, see instructions. b ~ Spouse -- c Dependents: (1) First name Last name 5oseph Kipps Ashley Kipps (2) Dependent's social security number 172-72-9592 182-74-7365 (8) Dependent's 6c who: D a ugh t e r o~ separation ) d Total number of exemptions claimed 2 2 Add numbers FI~41 Income Atlach Forms W-2 and W-2G here. Also attach Form(s) 1099-R if tax was withheld. If you did not get a W-2, see instructions Enclose, but do nota~ech, any payment Also, please use Form 1040-V, Adjusted Gross Income 7 Wages, salaries, tips, etc. Attach Form(s) W-2 .... 7 85, 948 8a Taxable interest, Attach Schedule B if required 8a 449 b Tax-exempt interest, Do not include on line 8a ....... 8b 9 Ordinary dividends. Attach Schedule B if required ..... ~~ ''~ 10 Taxable refunds, credits, or offsets of state and local income taxes (see ~nstructions) 10 62 11 Ahmony received 12 Bus,ness income or (Loss). Attach Schedule C or C-EZ 12 13 Capital gan or (loss), Attach Schedule D if required If no requ red, check here · [] 13 14 Other gains or (losses), Attach Form 4797 114 15aTotalIRAdisthbutions 15a b Taxabl~amoun (see ns's) [ lab 16aTotaipens~ons&annuities 116ar I b Taxabl(,' amount (see instrs) t6b 17 Rental real estate, royalties, partnerships~ 18 Farm income or (loss), Attach Schedule F 19 Unemployment compensation 20a Social security benefits L 20al I b Taxable amount (see instrs) 21 Other income 22 Add the amounts in the far right column for lines 7 through 21. Tbs is your total income 86,4~9. 24 Student loan mterest deduction (see instructions) 2824 25 Arche~ MSA deduction. Attach Form 8853 25 26 Moving expenses. Attach Form 3903 26 27 One-haft of self.employment tax Attach Schedule SE 27 28 Self-employed health insurance deduction (see instructions) 29 Self employed SEP, SIMPLE, and qualified plans 3129a 30 Penalty on early withdrawal of savings 30 3l a Arlmony prod b ReClpient's SSN · 32 Add hnes 23 through 3la 33 Subtract line 32 from hne 22. This is your adjusted gross income ~- 86, 459 BAA For Disclosure, Privacy Act, and Paperwork Reduction Act Notice, see instructions. Form 1 040 (200 I) Fo~m ]040 (200]) Jeffre), A & Plar~aret N Kipps ]68-48-3562 ~aae2 Tax and 34 Amour~t from line 33 i~diusted gross in'come) I ~4 86.45~9 Credits SSa Check if: [] You were 65/older, [] Blind; [] Spouse was 65/older, [] BI,nd Add the number of boxes checked above and enter the total here ~' 35a L~ r ,.,^.~..[Standard b ]f you are married firing separately and your spouse itemizes deductions, I~o;~cti°n _ or you were a dual-status alien, see instructions a~d check here ~ · People who 36 Itemized deductions (from Schedule A) or your standard deduction (see reft margin) 36 9,04 8 checked any box ~ Subtract line 36 from bna 34 135b or who can 38 If line 34 is $99,725 or less, multiply $2,900 by the total number of exemptions claimed :::: :: be claimed as a on line 6d. If line 34 is over $99,725, see the worksheet in the instructions 38 1 i . 600 dependent, see 39 Ta~able income. Subkact hne 38 from line 37 instructions If hne 38 is more than line 37, enter -O 39 6 5, 8 1 1 Single: 40 T~x(seeinstrs) Check if any tax is from a ~Form(s)8814 b ~Form4972 40 12,452 · All others: 41 Alternative minimum tax (see instructions). Attach Form 625] i$4.550 42 Add hnes ~ and 4] ~ 42 12,452 Headof 43 Fore,gn tax credit Attach Form ]l]6ifnequ,red 43 $6.650 household, ~ Credit fo~ child dod depende*d care expenses Attach Fo[m Z44~ ~ 263, 45 Credit for the elderly or the disabled. Attach Schedule 45 iointlyMarnedorfiling 46 Education credits. Attach Form 8863 46 Qualifying 47 Rate reduction credit. See the worksheet 47 $7wid°w(er)'.600 [ 48 Child tax credit (see instructions) 48 I , 2 00. Marned flhng 49 Adoption credit. Attach Form 8839 49 50 0ti,er credits from a ~ Form 3800 b ~ Form 8396 $3,800 c ~ Form 8801 d ~ Form (specify) 50 ' 51 Add hnes 43 th[ough 50 These are your toter credits 51 i , 4 ~3 52 Subtract line S] from line 42.1f line 51is more than line 42, enter.0. ~ 52 10,989 58 Se[f.employment tax Attach Schedule SE 53 Other 54 Social security and Medicare tax on tip ~ncome not reported to employer. A[[ach Fo[m 4137 54 Taxes 55 Tax on qualified p[ans, including IRAs, and other tax-favored accounts Attach Form 5329 if required 55 56 Advance earned income credit payments from Form(s) W-2 56 57 Household employment taxes. Abach Schedule H 57 58 Add lJnes 52-57 Thisisyouctetaltaz ~ 58 10,989 Payments 59 Federal income tax withheld from Forms W-2 and ]099 ' 59 ~ 1 , 840 Iff you have a b 60 200] estimated tax payments and amount applied from 2000 return 60 quali~ing 61 a Earned income credit (EIC) 61 a NO child, attach ~ b Nontaxable earned ,ncome I 6~ bI Schedule EIC. _ 62 Excess social security and RRTA tax withheld (see instrs) 62 63 Additional child tax credit. Attach Form 88]2 63 64 Ameunt paid with request for extension to file (see instructions) 64 65 Other payments. Check if from a ~ Form 2~9 b ~ Form 4~36 65 FDIAO~I2 ]2/]0/0] 66 Add hnes 59, 60, 6~a, and 62 through 65. These are your total payments ~ 66 1} , 840 Refu nd 67 If ]me 66 rs more than Jii~e 58, subtract line 58 from line 66 This i~ the amount you o~erpaid 67 8 5 ] . Direct deposit? 68a Amount of line 67 you want refunded to you ~ 68a 8¢ 1 . See instructions ~ b Routing number ~ c Type: Checking Sawngs 68c, and 68d 69 Amount o~ line 67 you wan[ applied to your Z0O2 estimated tax >¢ 69 I Amount You Owe Third Party Designee 70 Amount you owe. Subtract flee 66 from line 58 For derails co how to pay, see instruc:lons ~-?0 ! 71 Estrmated tax penalty. Aisc include on line 70 I 71 Do you wa*qt to allow another person to discuss this re[urn with the IRS (see instrucbons)? [] Yes. Complete the follow~ng, xl~ No Sign Here Joint return? See ~nstructions. Keep a copy for your records. Paid Preparer's Use Only Spo~rse's Signature If a Joint Return. Both Must Sign Ele,:t tic,an siege,ur. I1' LU Ann Siegfried s"lf'emploved).~I' 101 East High St zip Code Carlisle Set ,'ice Rep EIN PA 17013-3015 Phone No 23-2262892 (717) 243-8314 Schedule A (Form 1040) Internal Revenue Se~lce (99) Itemized Deductions "Attach to Form 1040. See Instructions for Schedule A (Form 1040). OMB No ~545 0074 2001 07 Jeffrey A & Margaret M Kipps 168-48-3562 Medical Caution. Do not include expenses reimbursed or paid by others ............... :::::::: : and 1 Medrcal and dental expenses (see illstructions) 1 Dental J I 3 Mulbply hne 2 above by 7.5% (,075) 3 4 Subtract hne 3 from line f, Jf line 3 is more than line I, enter 0 4 Taxes You 5 State and local income taxes 5 3, 342 Paid 6 Real estate taxes (see instructions) 6 1, :142 (See 7 Personal property taxes 7 436 OPT 20. 8 20 9 Add hnes 5 through 8 9 4, 940 Interest 10 Home mtg interest and points reported to you on Form 1098 10 2,6 1 3 ::::::'::::: 11 Home mortgage interest not reported to you on Form 1098 if pa,d to the person !!i!i:?i!!!i Note. 11 ::: Personal 12 Points not reported to you on Form 1098 See instrs for spcl rules 12 not t 3 Investmmqt interest Attach Form 4952 il reqmred :::: :: deductible. (See mstrs ) 13 14 Add lines t0 through 13 14 2,613. Gifts to 15 Gifts by cash or check If you made any gift of $250 or mere, ii!J?:J[ Charity see Instructions 15 320. If you made .~6 Other than by cash or check. If any gift of $250 or a gift and more, see instructions, You must attach Form 8283 if iF:::::/:::::::: got a benefit over $500 16 instructions, 17 Carryover from pnor year 17 18 Add lines 15 through 17 18 745. Casualty and Theft Losses 19 Casualty or theft Iossles) At!ach Form 44584. (See instructions,) 19 Job Expenses 20 Llnrelmbursed employee expenses - ob travel, union dues, .................. and Most Job education, etc. You must attach Form 2106 el 2106-EZ Miscellaneous if required, (See insmuctions.) See Statement 2,370. 20 2,370. 21 Tax preparation fees 21 109. {See 22 Other expenses - investment, safe deposit box, etc List :.iiii?:::]i::: ::::: to deduct 22 here,) 23 Add i s 20 th ugh 22 23 2, 479 , 24 Er~teramounttr0mF0rm1040,1ine34 24 86,459.::¥::,::::::::: 25 Multiply hne 24 above by 2% (02) 25 I, 729. 26 Subtract hne 25 fi'om line 23, If line 25 is more than line 23, enter -0- 26 7 Other 27 ethel - from list in the instructions, List type and amount '- 27 Total 28 Is Form 1040, line 34, over $132,950 (over $66,475 if MFS)? J Itemized Deductions [] No, Your deduction is not limited. Add the amts in the far right col / for hnes 4 through 27. Also, enter this amt on Form 1040, hne 36. 28 9 04 8 ~1 Yes. Your deduction may be limited See instructions for the amouqt to enter __J ' ' BAA For Paperwork Reduction Act Notice, see Form 1040 instructions, FDIA3301 01/07/02 Schedgle A (~or,-r ~ '- *'~ ' Schedule A & B (Form 10~J}) 2001 OMB ~o l~4S.oOya Paqe 2 Jeffrey A & Margaret M KJpps Schedule El - Interest and Ordinary Dividends O8 Part I Interest for Form 1040, hne 8a.) Lrst name of payer If any interest is from a seller-financed mortgage and the buye* used the property as a personal residence, see the instructions and list tins interest f~rst Also, show that buyer's social security number and address Cornerstone FCU ' Belco 2 Add the amounts on line 1 3 Excludable interest on series EE and [ U,S. savings bonds ssued a ter ]989 fram Form 88]5, line 14. You must attach Form 8815 4 Subtract line 3 from hne 2. Fnter the result here and on Form 10a), line 8a Amount 196. 253. 1 449. 449 . Note. If hne 4 ~s over Sa)O, you must complete Part III Part Il Ordinamj Dividends for Form 104,9, line 9) List name of payer, Include only ordinary dividends, if you received ary capJtal gain distrJbubons, see the instructions for Form 1040, line ]3 . ~ .............. Amount Part Ill Foreign Accounts Note. If line 6 is over Sa)O, ~/ou must complete Part Ill. You must complete this part if you (a) had over $400 of taxable interest or ordinary d~wdends; (b) had a fore,ge account; or (c) received a distribution from, or were a grantor of, or a transferor to, a fore~gn trust and Trusts (See rnstrucbons ) fo~ excepbons and filing requirements for Form TD F 90-22. b If 'Yes,' enter the name of the foreign country ~ If 'Yes,' you may have to file Form 3520 See instructions BAA For Paperwork Reduction Act Notice, see Form 1040 instructions. FD[A0401 10/01/0] Schedu;e B (Fc, m !0a)'; 2,9C i Cnterna~ Revenue Service (99) Child and Dependent Care Expenses ~' Attach to Form 1040. ~' See separate instructions, 2001 21 Jeffrey A & Nargaret M Kipps Before you beg/n: You need to understand the following terms. See Definitions in the instructions, · Dependent Care Benefits · Qualifying Person(s) · Qualified Expenses · Earned Income I~:.~:: ?=i ] Persons or Organizations Who Provided the Care - You must complete this part (If you need more space, use the bottom of page 2.) 1 (a) Care provider's name (b) Address (c) Identdylng number (d) Amount pa~d (no, street, apt no., city, state, and ZiP cocle) (SSN or EIN) (see ~nsbucbons) Bethel Christian Academy ~1~41_2__Ho_l_lL/_P_i_ke- ........... Carlisle, Pa 23- 1982986 1,316 Did you receive [ No ~- Complete only Part II berow dependent care benefits? t Yes -- I~ Complete Part III on page 2 next Caution: If the care was provided In your home, you may owe employment taxes, See the instructions roi Form 1040, hne 57. Credit for Child and Dependent Care Expenses 2 Lnformation about your qualifying person(s). If you have more than two qualifying persons, (a) Qualifying person's name (b) Qualifying person's social security number First Last Joseph Kipps 172-72-9592 Ashley K pps 182-7z.- 7365 3 Add the amounts in column (c) of line 2. Do not enter more than $2,400 for one qualifyirg person or $4,800 5 If marned fihng a joint return, enter your spouse's earned income (if your spouse was a student or was disabled, see the ~nstructions); all others, enter the amount from line 4 6 Enter the smallest of line 3, 4, or 5 7 Enter the amount from Form 1040, line 34 7 86,459 8 Enter on hne B the decimal amount shown below that applies to the amount on line 7 J(c) Qualified expenses you recurred and paid m 2001 for the person listed in column (a) 658. 658. 1,316. 51,624. 35,458. 1.316. If line7is: If line7is: Decimal Decimal But not amount But not amount Over over is Over over is $0- 10,000 .30 10,000 12,000 29 12,000 J4.000 .28 14,000- 16.000 .27 ]6,000- ]8,000 .26 18,000- 20,000 .25 $20,000 - 22,000 .24 22,000 - 24,000 .23 24,000- 26,000 .22 26,000- 28,000 ,21 28,000- No limit ,20 Multiply line 6 by the decimal amount on line 8, Enter the result here and on Form line ~¢. But if this amount ~s more than the amount on Form 1040, line 4-2, minus any amount on line 43, oryou paid 2000 expenses in 200], see the instrucbons for the amount to enter on line 44 0.20 263. BAA For Paperwork Reduction Act Notice, see separate instructions, Folm 2441 (2091: Schedule A Miscellaneous Itemized Deductions Statement 200'1 Lines 20, 22, 27 ~ Attach to return (after ail iRS forms) Statement Name(s) Shown on Return Jeffrey A & Margaret I'1 Ktpps Sooal Seeur ~ty Number 168-48-3562 Employee Business Expenses - Subject to 2% Limitation Unreimbursed employee expenses from Form 2106 Excluded expenses from Form 2555 Other unreimbursed employee business expenses: Union and professional dues .... Professional subscriptions Uniforms and protective clothing ...... Job search costs Other: small tools 4 Total unreimbursed employee business expenses (combine lines ' - 3e) Miscellaneous Expenses - Subject to 2% Limitation Investment Expense 1,823. 258. 289. 2,370. 5 Depreciation and amortization deductions 6 Casualty/theft losses of property used in services as an employee 7 REMIC expenses, from Schedule E 8 Fnvestment expenses related to interest and dividend income 9 Deductions related to portfolio income, miscellaneous deductions, and excess deductions on termination, from Schedule(s) K-1 10 Miscellaneous deductions excluded on Form 2555 11 Other miscellaneous expenses: a Investment counsel and advisory fees ...... b Certain attorney and accounting fees .... c Safe deposrt box rental fees d IRA custodial fees e Other: 12 Total miscellaneous expenses (combine lines 5 through l~e) Other Miscellaneous Deductions - Not Subject to 2% Limitation 13 Federal estate tax paid on decedent's income reported on this return 14 Miscellaneous deductions excluded on Form 2555 15 Impalrment-rerated expenses of a handicapped employee, from Form 2106 16 Amortizable bond premiums on bonds acquired before 10123/86 17 Gambling losses (to the extent of gambling income) '18 Casualty/theft losses of income-producing property Other miscellaneous deductions: 19 20 Total other miscellaneous deductions (combine lines 13 through 19) , 20 PLEASE 0100115013 DO NOT USE YOUR ~.~OOl PA-40 LABEL Page 1 of 2 168-48-3562 KI 184-54-9105 EX 0 RS KIPPS JEFFREY A A 0 FS KZPPS MARGARET M FY 0 XX 3063 RITNER HIGHWAY SC 21050 CARLISLE PA 17013 PN lA 88081.00 lB 2370.00 1C 85711.00 2 449.00 3 .00 4 .00 5 .00 6 .00 7 .00 8 ,00 9 86160.00 10 .00 11 86160.00 12 2412.00 R J Please fold page along th~s line Local Information, Enter where you hved as of 12/31/01. SchoolD~stnct: Bi& Sprin& School Code: 211050 Counb/: Cumberland Municipality: ~4 Pennsboro Residency Status. (Check the correct box) r X Pennsylvania Resident NR Nonresident P Part-Year Resident From: To: Extension, (check th~s box) Amended Return, (check thrs bo>:) Fiscal Year Filer, (check this box) Type Filer. (Cheek only one box) S Single J X Married, Filing Jointly M Married, Filing Separately F Final Return. indicate reason: D Date of death Gross compensation See instructions la Unrelmbursed employee business expenses See instructions 1 b Net compensation, Subtract line lb from line Ia lc rnterest income Complete and submit PA Schedule A, Jf over $2,500 2 Diwdend income, Complete and submit PA Schedule B, if over $2,500 3 Net income or loss from the operation of a business, profession, or farm 4 Net gain or loss from the sale, exchange, or disposition of property 5 Net ~ncome or loss from rents, royalties, patents, or copyrnghts 6 Estate or trust income Complete and enclose PA Schedule J 7 Gambhng and lottery winnings 8 Total Pennsylvania taxable income. Add only the positive income amounts from hnes lc 2, 3, 4, 5, 6, 7, and 8, Do not add any losses reported on lines 4, 5, or 6 9 Contributions to your Medical Savings Account, See instructions Adiusted Pennsylvania taxable income. Subtract line 10 from line 9 ~2 Pennsylvania tax liability. Multiplylinell by 2.8% (0,028). Also enter on line13, page2 PAIA04]2 ]2/2]/01 EC FC 12 0100115013 88,081 00 2,370 00 85,711 00 449 00 O0 00 00 O0 ,00 .00 $6,160.00 .00 86,160.00 2,412 .00 I 0t0021~011 2001 PA-40 Page 2 of 2 KIPPS JEFFREY 13 2412.00 14 2467.00 15 16 .00 17 .00 18 19 .00 20A 00 200 21 .00 22 .00 23 24 .00 25 .00 26 27 2467.00 28 .00 29 30 55.00 31 .00 32 33 .00 34 .00 35 36 .00 A 168-48-3562 .00 .00 00 .00 .00 55,00 ,00 .00 13 Total Pennsszlvania tax liability. Enter your Pennsylvania tax liability from line 12 on page 1 13 14 Total Pennsylvania tax withheld. See instructions 14 15 Credit from your 2000 Pennsylvania income Tax Return 15 16 2001 estimated ~nstallment payments 16 17 2001 extension payment 18 Nonresident tax withheld on your PA Schedule(s) NRK-1. (Nonresidents only) 18 19 Total estimated payments and credits. Add lines 15, 16, 17, and 18 Tax Forgiveness Credit. Complete lines 20a, 2Ob, 21, and 22, Read the ~nstructions 20 a Filing Status: Unmarried or separated Married Deceased 20 20b Dependents, Part B, line 2, PA Schedule SP 20b 21 Total elig,bility income, Part C, hne ] ], PA Schedule SP 21 22 Tax Forgiveness Credit from Part D, line ]6, PA Schedule SP 22 23 Total credit for taxes paid to other states or countries, Submit your PA Schedule G or RK-i 23 24 Pennsylvania Employment Incentwe Payments Credit. Subrmt your PA Schedule W, RK-I or NRK.I 24 25 Pem~sylvama Jobs Creah0rl Tax Credit Submd you¢ certification or PA Schedule RK-1 or NRKd 25 26 Pennsylvania Research and Development Tax Credit Submit your certificatm or PA Schedule RKd or NRK.1 26 27 Total Payments and Credits. Add lines 14 and 19 and 22 through 26 27 28 Tax Due, If line 13 is more than line 27, enter the difference here 28 29 Overpayment. If line 27 ~s more than line 13, enter the difference here 29 The total of lines 30 through 36 must equal line 29. 30 Refund - amount of hne 29 you want as a check mailed to you Refund 30 31 Credit - amount of lire 29 you want as a credit to your 2002 estimated tax account 31 32 Donation - amount of line 29 you wart to donate to the Wild Resource Consercation FLInd 32 33 Donation - amount of hne 29 you want to donate to the United States Olympic Committee 33 ~4 Donation - amount of line 29 you want to dona e o the Governor Robed P. Casey Memorial Organ and Tissue Donation Awareness Trust Fund S4 35 Donation - amount of hne 29 you want to donate to the KoreaNietnam I~lemorial, Inc 35 36 Donation - amount of hne 29 you want to donate to Breast and Cervical Cancer Research 36 2,4].2 .00 2,467 .00 .00 .00 .00 .00 .00 O0 O0 O0 O0 O0 O0 O0 O0 2,467 O0 O0 55 O0 55 00 00 .00 .00 .00 .00 .00 Under penalties of perjury, I (we) declare that I (we) have exam ned this return, including all accompanying schedules and statements, and to the best of my (our)belief they are true, correct, and complete. Wa§net's Tax Service East Hish St Carlisle PA 27013-30],$ 03/06/02 (7~7) 243-83]4 Your Occupation El. eot r 1c~an Lu Ann Siegfried 0100215011 0100215011 PA Schedule UE Allowable Employee Business Expenses PA~,0 UE (09/0) PA DEPARTMEN)T OF REVENUE 0101715019 5effrey A KJpps 168-48-3562 UntitIed Part A. Employee Business Expenses. Caution. You may not use line 4 of Form 2106 or Form 2106EZ. You must itemize these expenses m Part G of th~s schedule Vehicle expenses. Standard mileage rate. Filing tip, rt you do not file Form 2]06 or 2106EZ, enter your total business miles and multiply by the federal standerd rmleage rate Enter the result on line ], 1 Enter the amount from your Form 2106 or line t of Form 2106EZ Vehicle expenses. Actual travel and mileage expenses, 2 Enter the amount from youl Form 2106, Make the following adjustments 2 3 Add back the inclusibn amount, Th~s adjustment does not apply for Pennsylvania purposes 3 4 Depreciation. You may use any generally accepted method, if not using your Form 2}05, enter your depreciation expense and complete line 5 4 5 Depreclabon method 6 Actual travel and mileage expenses for Pennsylvania purposes. Total lines 2, 3, and 4 6 7 Parking fees, tolls, and transportabon. Enter the amount from your Form 2]06 or Form 2]06EZ 7 8 Away from home overmght. Enter the amount from your Form 2106 or Form 2]06EZ 8 9 Meals and entertainment expenses Enter the amount from your Form 2106 or Form 2106EZ 9 10 Total e×penees for Part A. Add lines ] or 6 and 7, 8, and 9 ........ Part B. Direct Employee Business Expenses. i ] 1 Union dues. List umon name(s) end amount(s) paid. Enter total Attach additional sheet:s, if needed Na~T~e of union(s) and amount(s) 12 Work clothes and uniforms. Required as a condition of employment and not suitable for everyday use, Descnpt~on 13 Small tools and supplies. Required as a conditron of employment and not provided by your employer, Description t4 Professional license tees, malpractice insurance, and fidelity bond premiume, Required as a condition of yocr employmen] Description 14 15 Totalexpenses for PaMB. Add lines 11, 12, 13, and 14 15 Part C. Office or Work Area Expenses. You must answer All three questions or the clepartment wirl disallow your expenses. C] Does your employer requ,re you to maintain a suitable work area away from the employer's premises? C1 F~ 1 Yes c2 rs this work area the principal place where you perform the duties of your employment? C2 ~ 1 Yes C3 Do you use this work area regularly and exclusively to perform the duties of your employment? C3 1 Yes If you answer Yes to All three questions, continue If you answered No to Any question, you may not claim at home expenses. Actual office or work area expenses. Enter expenses for the entire year and then calculate the business port,on. a Depreciation expense (homeowners only) b Real estate taxes c Mortgage interest (homeowners onJy) d Utihties e Property ~nsurance ..... f Property maintenance I[errize the type & amt of maintenance expenses incurred g Other app0rti0nable expenses Itemize tile type &amt of these expenses h Rent (renters only) i Total Add fines a through h Enter the total here j Bus~ness percentage of property Divide the ora square fooageo your work area byth~ oa squa'e footage of your enbre property. Round to 2 decimal places j kApportonedexpenses Multiply fine l by the percentage on line j k I Total office supplies Itemize supplies you purchased exclusively for use in your ofhce or , work area Total 16 Total expenses for Part C. Add lines k and I 16 J 1,823 258 2,081 2No 2 No 2 No 11 12 0101715019 PAIA]41212/21/0] 0101715019 PA Schedule UE Allowable Employee Business Expenses PA~0 UE (09101) EA DEPARTMENT OF REVENUE Jeffrey A Kipps Part D. Movinq Expenses. 0~0181~017 OFF]CIA£ USE ONL ( a Enter the number of miles from your old home to your new workplace : a b Enter the number of miles from your old home to your old workplace b c Subtract line b from hne a and enter the difference c Jf hne c is 50 miles or more, continue, If not at Feast 50 miles, you may not clam mowng ex;enses. 17 Transportabon expenses ]n mowng household goods and personal effects 17 18 Travel, meals, and lodging expenses during the actual move from your old home to your new home 78 19 Total expenses for Part D, Add lines ]7 and 18 19 runes miles Part E, Education Expenses. You must answer All three questions or the department will d~sallow your expenses, E1 Did your employer or a law require that you obtain th~s education to retain your present pos,tion or iob? [~ 1 Yes [~ 2 No It you answer Yes, conbnue If you answer No, you may not claim education expenses, E2 Did you need this education to meet the entry level or mlnlmum requlrements to obtain yourjob? ~ 1 Yes ~ 2 No E3 Will this education program or course of study qualify you for a new business or profession? 1 Yes 2 No If you answer No to both questions, continue, If you answer Yes to either question, you may ~ot claim education expenses, 20 Name of college, university or educational institution 21 Course of study 25 Total expenses for Part E. Add hnes 22, 23, and 24 25 Part F. Depreciation Expenses. Do not include vehicles (use Part A) and office or work area (use Part C) expenses (a) Description of property (b) Cost or (c) Depreciation Depreciation (e) Secbon o her basis method (d) deduotion expense (f) Expense Add (d) + (e) Part G, ~/lisceJJaneous Expenses, Itemize the type and amount of your additional expenses, including expenses from Form 2106 or Form 2106EZ a smatl tools e 27 Total miscellaneous expenses for Part G. Add lines a through e 27 Total allowable Pennsylvania employee business expenses. You must also account for reimbursements, if 28 Total expenses. Add lines 10, 15, 16, 19, 25, 26, and 27 28 29 Reimbursements. Enter reimbursements that your employer did not report as taxable wages on your Form W.2 29 30 Net expense or reimbursement 30 If line 28 is More than line 29, enter the difference on line 30 and include on Kine I b, unr e~mbursed employee bus,ness expenses on your PA 40, If line 29 is More than line 28, enter the difference on line 30 and include the excess on line Ia, gross Pennsylvama compensat]Onr on your PA-a3 289 . 2,370.11 -- 2,37O. 0101815017 PAIA]41212/21]01 0101815017 J RETURN BY APRIL 15, 2002 TO: CAPITAL TAX COLLECTION BUREAU See Page 2 of Instruction Sheets in this packet for mailing address labels or see back of return for addresses, phone numbers, and office hours. CONSTITUTE PROOF OF FILING, THE TAXPAYER'S COPY MUST VALIDATED BY THE BUREAU. TO HAVE YOUR COPY VALIDATEa MAIL. RETURN BOTH THE BUREAU*S AND TAXPAYER'S COPIES ~LONG WITH A SELF ADDRESSED STAMPED ENVELOeE. ®01 LOCAL EARNED INCOME TAX RETURN CFORM 531) www.captax.com TAX OFFICE USE ONLY - DO NOT WRITE IN THIS AREA W 2 EARNINGS (From attached W-2's) ........................................... 2 EMPLOYEE BUSINESS EXPENSES (Attach Federal Form 2106 & S!~[te Schedule UE) 3 TAXABLE W 2 EARNINGS (SL~btract Line 2 from Line 1) 4 OTHER TAXABLE EARNED INCOME (NO INTEREST OR DIVIDENDS) Complete Section A on Back.. 5 TOTAL TAXABLE EARNED INCOME (Add Lines 3 and 4) ................................... E NET L©SS FROM BUSINESS. PROFESSION, OR FARM (A~tach Federal and/or Slate Schedules C, Fand/o~ K-1(10651) 7 SUBTOTAL (Subtract Line 6 from Line 5) IF LESS THAN ZERO, ENTER ZERO. 8 NET PROFIT FROM BUSINESS, PROFESSION, OR FARM (AMachFederaland/orStateSchedulesC Fand/orK.1(IO65) 9 TOTAL TAXABLE EARNED INCOME AND NET PROFITS (Add Lines 7 and 8).. 0 ENTER TAXABLE RATE - BB FOR DAUPHIN, PAXTANG, AND PENBR00K BOROUGHS LOWER PAXTON MIDDLE PAXTON SW~TARA OR WEST HANOVER TOWNSH PS CENTRALDAUPRNSCHOOLDISTRICT)-ALLOTHERS TAX LIABILITY: Multiply Line 9 by Line 10 2 TOTAL LOCAL INCOME TAXES WITHHELD EXCEPT PHILADELPHIA INCOME TAX (From a~ached W-2's. Box 19) 3 QUARTERLY PAYMENTS AND/OR LAST YEAR'S OVERPAYMENT CREDITED TO THIS YEAR .... 4 CREDITS FOR TAXES PAID TO PHILADELC)HIA AND/OR STATES OTHER THAN PA (AT[ACH SCH. G) AND/OR CREDITS FOR CERTIFIED RESIDENTS OF THE HARRISBURG KEYSTONE OPPORTUNITY ZONE [KOZ) TOTAL WITHHOLDINGS & PAYMENTS (Add Lines 12, 13 and 14) ............................. TAX BALANCE DUE (Subtract Line 15 from Line 11) PAYMENT NOT NECESSARY IF LESS THAN $1.00.. GI ........ INTEREST & PENALTY (See Instructions) ............................................ TOTAL BALANCE DUE (Add Lines 16 and 17) Make check payable to "CTCB". ................. OVERPAYMENT (Subtract Line 11 from Line 15) IF LESS THAN ZERO, ENTER ZERO C~ ........ OVERPAYMENT TO. BE REFUNDED ..... HAVE IT D RECTLY DEPOS TED! ............... DIRECT DEPOSIT INFORMATION CIRCLE ONE CHECK ONE ROUTING NO ACCOUNT NO 5 6 7 8 9 0 ¢, B BOTH ~ ~ ! I ! i OVERPAYMENT TO BE CREDITED TO NEXT YEAR'S T,~X ~ I OVERPAYMENT TO BE CREDITED TO SPOUSE'S BALANCE DUE FOR THIS FILING YEAR ~ YOUR RESIDENT MUNICIPALITY DAYTIME PHONE NUMBER (~OWNSHm, BOROUGH, OR CITY) i~L 5T PENF~SSC,-,-.,C YOUR SOCIAL SECURITY SROUSE'S SOCI^~ (~ SECURITY NUMBER :'[ EB ~ /r,~ /~ t%~ 4AVE YOU MOVED FROM THE [] YES 3EGINNING OF THE TAX FILING EAR TO PRESENT? [] NO IF YES, COMPLETE SCHEDULE P PROVIDED WrTH THIS RETURN, TAX OFFICE usa ONLY YOUR NAME SPOUSE'S NAME HOME )UR S!GN4TURE ~OUSE S S~SNATURE (ONLY IF ALSO FILING ON THIS FORM) DATE DATE FIRMS NAME (OR ENTER "S E ' IF SELF-EMPLOYED) YOUR OCCUPATION SPOUSE'S OCCUPATION (ONLY IF ALSO F LNG ON THIS FORM, Comroloumber CoPy C For EMPLOYEE'S RECORDS , OM8 No 1545-0008 (See Notice to, Employee on back of Copy B.) Employer identilica~ion number I Wages, tips, other compen~don 2 Federal income fax,withheld £mployess name,, address and ZiP code 3 Social $dcudty wages 4 Social security tax withheld ?~::': ,~ro:~'~.'{nc 51624.38 3200.71 ......... ?51624.38 748.~5 :: :,-,;U-~562 0. 14 Other 12c Employee s address and ZIP code ~~ ~ ...ii ...:.'~716 ?iL) 51624.38 ............. ........ ~.~.¢.~..~].~= .............. 5i624:38 516.26 50C~ I W=2Wage and Tax Form Statement PI3Bt Department of the Treasury--Internal Revenue Service This information is being furnished to the InternaJ Revenue So.ice If you are requiJed [o file a tax return a negligence penaJ y o o(her sanc on may be reposed on you Jf this income is Iaxable and you fail [o repod J[ 2001 7 ,o.,,, ..... ,,,,,p, w.,.,, ,,, .......... 34323.P"'"'°'~2, f ,- ................. 4,93.03~"' W-2 Wage and Tax Statement 3645? · 41 2260.36 12d Fidel/ly NetBcnefitg Page I of i s~INT CO~PORAT O~ Market Update DJIA haps://workplaceservices 103.fidelity.com/n¢Ibenefits/imegratedserv; ces/H°mePageServlet 1/27/03 CERTIFICATE OF SERVIC~ I, James W. Abraham, Esquire, the undersigned, hereby certify that I have served a true and correct copy of the foregoing document upon the following person at the following location on the date stated hereto: Carol J. Lindsay, Esq. Saids Shuff 26 West High St. Carlisle, PA 17013 DATE: 2/28/03 James W~ Abraham, Esq. MARGARET M. KIPPS Plaintiff v. JEFFREY A. KIPPS Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COU1TTY, PENNA. : NO. 2002 2542 : CIVIL ACTION - LAW : CUSTODY STIPULATION OF PARTIES The parties hereto stipulate as follows: 1. They are the parents of two children, Joseph A. Kipps, born July 22, 1990 and Ashley N. Kipps, born April 24, 1993. 2. The parties entered into an Agreement after conciliation for the entry of a Court Order for the custody of their children. A copy of the Court Order of August 24, 2002 is attached herto as Exhibit "A". 3. The terms of the Court Order shall remain in full force and effect with an additional term: to wit, the parties will alternate weeks of custody of the children during the summer commencing in 2003. In 2003, the alternating weeks of custody shall commence with custody in Father beginning on Friday, June 13, 2003. Mother shall have custody of the children from Friday, June 20, 2003 through Saturday, July 5, 2003. evening of June 24 and June 26, p.m.; and on Sunday, July 6, 2003 Father shall have custody on the 2003 from after work until 9:00 from 9:00 a.m. until 9:00 p.m. Mother shall then have custody from 9:00 p.m. July 6 through Friday, July 11, 2003. Thereafter, the alternating week schedule shall resume. 4. In years following 2003, the parties shall negotiate the beginning time for the alternating weeks of custody in the summer, taking into consideration the beginning availability of Father's parents as daycare providers during his weeks of custody and the 4th of July holiday as to Mother's family vacation plans when it is Mother's holiday. 5. Father may take the children on a one-week vacation during the school year with 30 days notice to Mother. 6. The terms of this Stipulation may be modified by agreement of the parties. 7. The parties intend the terms of this Stipulation to be entered as an Order of Court. Sunday, regular WITNESSES: Mar~ar~ M. Kipps !- ey A. Ki~5~ SAIDIS SHUFF, FLOWER & LINDSAY 2fiW. High Street Carlisle, PA MARGARET M. KIPPS, Plaintiff VS. JEFFREY A. KIPPS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2002- 2542 CIVIL TERM : IN DIVORCE NOTICE YOU ARE HEREBY NOTIFIED to plead to the within New Matter and within twenty (20) days after service of this Answer and New Matter. SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for Defendant v i~D~O~ 4J~ ~s'~'y, Esquire 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA MARGARET M. KIPPS, Plaintiff VS, JEFFREY A. KIPPS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 2002-2542 CIVIL TERM : : IN DIVORCE ANSWER AND COUNTER-CLAIM TO PLAINTIFF'S COMPLAINT IN DIVORCF NOW COMES Jeffrey A. Kipps, Defendant above, and answers the Divorce Complaint and states a counter-claim as follows: DIVORCE PURSUANT TO §3301(c) OF THI~ DIVORCE CODF 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. Admitted. WHEREFORE, Defendant requests this Honorable Court to enter a Decree in Divorce dissolving the marriage. SAIDIS SHUFF, FLOWER & LINDSAY 26W. High Streel Carlisle, PA COUNT II - DIVORCE PURSUANT TO 23 Pa. C.S.A./}3301 (a)(6)- INDIGNITIES 9. Denied that Defendant has caused such indignities against Plaintiff which has made her life burdensome and intolerable. Denied that Plaintiff is an innocent and injured spouse. COUNTER-CLAIM The averments in Paragraphs 1 through 9 are incorporated herein by 10. reference. 11. During the course of the marriage, the parties have acquired property both personal and real. WHEREFORE, Defendant prays this Honorable Court to equitably divide their property. SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for Defendant By: ID# 44~3 ] 26 W~t~h Street Carlisle, PA 17013 (717) 243-6222 VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. ,->"' J effre~A'~. Kipps SAIDIS SHUFF, FLOWER & LINDSAY 26W. High Street Carlisle, PA SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High $1reet Carlisle, PA MARGARET M. KIPPS, Plaintiff VS. JEFFREY A. KIPPS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2002- 2542 CIVIL TERM : IN DIVORCE _CERTIFICATE OF SERVICF AND NOW, THIS. .,,~-/L~ DAY OF ~ ,2003, I, CAROL J. LINDSAY, ESQUIRE, OF THE LAW FIRM ,o¢SAIDIS, SHUFF, FLOWER & LINDSAY, ATTORNEYS, HEREBY CERTIFY THAT I SERVFD THE WITHIN ANSWER TO COUNTER- CLAIM TO PLAINTIFF'S COMPLAINT FOR DIVORCE THIS DAY BY DEPOSITING SAME IN THE UNITED STATES MARL, FIRST CLASS, POSTAGE PREPAID, IN CARLISLE, PENNSYLVANIA, ADDRESSED TO: MARGARET M. KIPPS C/O James W. Abraham, Esquire 513 North Second Street Harrisburg, PA 17101 SAIDIS, SHIJFF, FLOWER 8, LINDSAY Attorneys for Defendant Carol J. Lindsay, Esquire ID# 44693 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA MARGARET M. KIPPS, Plaintiff/Respondent VS. JEFFREY A. KIPPS, Defendant/Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2002:- 2542 CIVILTERM : IN DIVORCE ORDER OF COURT AND NOW, this /z ~ day of __ ?,~,- , 2003, upon consideration of the within Motion to Compel, a Rule is issued upon Respondent, Margaret M. Kipps, to show cause why she should not provide the discovery requested. RULE returnable days from thE; date of service hereof. By the Court, SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA MARGARET M. KIPPS, Plaintiff/Respondent VS. JEFFREY A. KIPPS, Defendant/Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2002 - 2542 CIVIL TERM : IN DIVORCE ORDER OF COURT AND NOW, this / (,' day of_ ~'~,..~ 2003, ! upon consideration of the terms of the within SIipulation of the Parties, the terms hereof are hereby made an Order of Court. By the Court, SEP 17 OO3 MARGARET M. KIPPS, Plaintiff V JEFFREY A. KIPPS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 2002 - 2542 CIVIL : IN CUSTODY COURT ORDER AND NOW, this //fi/'t~7 day of September, 2003, the conciliator being advised the parties have reached an agreement, the conciliator relinquishes jurisdiction. BY THE COURT, ~uUsbteo~yX~t o r MARGARET M. KII~PS V. JEFFREY A. KIPPS/ ~fenlant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA. : NO. 2002 - 2542 CIVIL : DIVORCE ~LAINTIFF'S INCOME & EXPENSE STATEMENT Plaint the above-captioned Plaintiff pursuant to DATE: fi, Margaret M. Kipps, files the following Income & Expense Statement in ction In divorce in accordance with Pa.R.C.P. 1920.31 as verified by ~e signed Verification attached hereto and made part hereof. ABRAHAM LAW OFFICES James W. Abraham, Esq. 2157 Market St. Camp Hill, PA 17011 (717) 763-170O Attorney for Plaintiff, Margaret M. Kipps I ~ Sprh~t Sprint Payroll Advice of Deposit 10~/!8/~003 ! ~-~..l ! ~_1. !: 1~ !..! 0-~2:~!. ~ ['crsonal lnRmnation no~ shown as per the preference selected on the l,ogin screen )RGANIZ 4, TION EMPLOYEE 2HECKJADVICE FEDERAIJSTA EE PAY PERIOD ENDING CHECK DATE ~,IAILSTOP ID ID. ~/UMBER CODES 07/12/2003 07/18/2003 a. 762431 MO O00 NAME ORGANIZATION: ADDRESS: GROSSPA'~ DEDUCTIONS NETPAY FWTGRSYTD I FICAGRSYTD IMEDGRsYTD CURREN1 1411.12 338.43 1072.6,0 YEAa ro DATE 22374.73 22121.198 22~21.191 22121.1~ TYPE OF TYPE OF PA'*' IIOURS .~ROSS AMOUNT DEDUCTION CURRENT Y-T-D TAXABLE WAGE COMPIIOLI 8.00 141.1I FLXCREDITS -127.13 -1779.82 ?,EGULAR 40,00 705.56 MEDICAL 117.00 1638.00 PTO-SCH 32.00 564,45 RX PLAN 22.33 312.62 DENTAL 1.75 24.50 EMP LIFI~ .58 8.12 SUPL LTD 3.58 50.12 FICA 86.36 1371.51 1393.01 MEDICARE 20.20 320.76 1393.01 FEDERAL TAX ' ' ~ 135.40 2642.15 1393.01 ADDL FED TAX ,12.00 LOCAL TAX #1 22.98 368.57 1393.01 STATE TAX -PA 39.00 619.37 1393.01 SUT EMPL DED .31 4,53 -PA DEP LIFE ,17 2.38 UNITED WAY - 4.00 56.00 24 LOCAL TAX #2 10.00 AS O1: 0WI 2/2003 PTO AVAIl, [22.00 PTO USED 81.00 [ ** TOTAL** I 338,43 hrtp://sysw.corp.sprint,comJservlet/payroll. WebAdvice 7/21/03 Residence: Mortgage/Rent Maintenance Homeowners insurance Utilities: Electric Gas Telephone Water/Sewer Oil Personal: Food/Clothing Other Automobiles: Payments: Insurance: Repairs/MaintenanCe/Fuel: Medical: Doctor: Dentist/Orthodontist Hospital Medicine Special Needs (eye ~:are, etc.) Education: Private/Parochial School College: Credit Payments: Credit cards Charge accounts Memberships Outstanding Loans: Creditor: EXPENSES Month 720 110 100 50 900 130 200 20 50 Year 8,640 1,320 1,200 600 10,800 1,560 2,400 240 600 Miscellaneous: Household help: Child care: Pay/Cable/TV Legal Fees: Charitable contributions Vacation Entertainment Gifts Other (specify): Ext~a-curricular activities expenses for children. Support/Alimony 180 40 300 80 100 100 2,160 480 3,600 960 1,200 100 TOTAL EXPENSES: $ 3,080 $ 36,960 040 u.s, Individual Income Tax Return 2001 Label Presidential Electiom Campaign Filing Status Exemptions Attach Forms W-2 and W-2G here, Also attach Form(s) 1099-R if tax was withheld. get a w.2. sea Form 1040.V Adjusted Gross Ir~come For We year Jan I · Dec 31,200i, or olher tax year begmnln9 Jeffrey A Kipps Hargaret M Kipps 3063 Rltner iHlghway Cart~ste 168- 45- 3.~.5L PA 17013 You Spouse Note: Check,nc Od you, or ~ Single 2 Marrlec 3 Marries 4 __ Head o s i jOuanf¥ 6a xL~j Yourse b ~] Spous, (1) First n~me Joseph Kipps Ashley Kirps d Total numt 7 Wages, sam 8a Taxable iht b Tax-exemp 9 Ordinary dl 10 Taxable re 11 Ahmony re 12 Business ir 13 ~pltal gain o 14 Other gain 1Sa Total iRA ( 1fa Total pens 19 Unemployr 21 01her income 22 Add the ar 23 IRA deduc 24 Student Io 25 Archer MS 26 Mowng ex, 27 One half o 28 Self.ampi( 29 Sell.ample 30 Penalty or 31 a Ahmony paid 32 Add lies 23 33 ,2001, end,nc 'Yes will not change your tax or reduce your retund )duse if fdin~ a iomt return, want $3 to 9o to thrs fund? flhng tolnt return (even if only one had income) hilng separate return, Enter spouse's SSN above & full name here w __ household (with qualifying person), (See mstructlons,) If the QUalltylng oerson ant, enter this chdd's name here w '~(~ widow(er/ with dependent child ~ear spouse died ~ ) (See (4) (2) Dependent's (3) Dependenl's ~c who; 182-74-7365 Daughter X[ 1190: ~2 : 20b total income 22 u~ts mn the far right column for lies er of exemptions claimed )rres, tips, etc, Attach Form(s) W,2 )rest. Attach Schedule B if raquired ~nterest. Do not include on line 8a /idends. Attach Schedule B if required JndS, credits, or offsets of state and local income ~axes (see mstruchons) ;e~ved come or (loss), Attach Schedule C or C.EZ (10ss) Attach Schedule O if requited. M not required, check here Or (losses). Attach Form 4797 istnbUtlOnS 1Sa J b Taxable amount (see ,nst,'s) phs & annuities 6a I b Taxable amount (see mslrs; estate, royalties, partnerships, S corporations, trusts, etc Attach Schedule ~e or (loss), Attach Schedule F 'benehts I 20al I b Taxable amount (see ,nslrs; ion (see instructions). ~n ~nterest deducbon (see ~nstruchons) ~, deduction, Attach Form 8853 ,arises, Attach Form 3903 self.employment tax, Attach Schedule SE ed health insurance deduction (see mstructtons) ed SEP, SIMPLE, and qualified plans earJy withdrawal of savrngs b Reclp~ent's SSN ~ Ilrough 3la Subtract hne 32 from Iine 22, This is ),our adjusted cjross income BAA For Disclosure, Privacy Act, and Paperwork Reduction Act Notice, see instructions, ¢OIA0)12 12/)0/01 Tax and Credits Standard Deductioh Jeffrey A & Marc;aret M Kipps 168-48-3~6Z 34 Amount from line 33 (adjusted gross income) 35aChecl<,,: g You were 65/o,der, t--lei,nd; r~spoueewes65/older, Add the number of boxes checked above and enter the total here ~' 35a b.__~ J j b you e e lamed filing separately and your spouse itemizes deducbons, --,~. or you were q duel-status alien, see ins ruc ons and check he e --36 Itemized deductlons (from Schedule A) or ~mur atandard deduction (see left margm) --37 Subtract hne ~6 from line 34 I i 3~ If hne 3 ~s $~9,725 or ess, mulbply $2 900 by the totat number of exemphons c~a~med on hne 6d. if Jla 34 is over $99,725. see the worksheet in the ~ns rucbons 39 Taxable Incomei Subtract line 38 (rom line 37, G q I( hne 38 is more than hne 37, enter ,0. 40 Tax(seemstrs).Ohecklfanytaxisfrom a C] Form(s) 8814 b r-lForm4972 S5.556 ' S;.60C 41 Alternative rf 42 AdO lines ~0 43 Foreign tax c 4~ O'edil for chdd ~ I 45 Credit tor th~ 46 Education cr 47 Rate reductl( 48 Chdd tax cra 49 Adoption cra 50 OIher credils Irc C [] Form 88' inimum tax (see instrucbons) Attach Form 6251 and 41 'edit Attach Form I116ffrequ~red ~d dependent care expenses A~tach Form 2441 elderly or the disabled. Attach Schedule R ~d~ts. Attach Form 8863. n credit. See the worksheet fit (see instructions) lit. Attach Form 8839 a E~ Form 3800 b [] Form 8396 d L] Form (speci(y) ~'! 42 43 44 263 45 46 4? 48 !, 200 49 5O ~3,800 Other Taxes Payments Refund D~rect deposit? See ,nstrucbons 58c e;d 58c 51 Add hnes 43 thr 52 Subtract hne 53 Sell.emoloymer Soc~al secunly 55 Tax on qualihe( 56 Advance eel 57 Household 58 Add lines 52,5~ 59 Federal incc 60 ~00l estimated 61a Earned incc b Nontaxable 62 Excess soci 63 Additional c 64 Amount 0md w 65 Other paym b [] Form 66 Add lines 5~ total payme Amount 70 Amount you c YOU Owe 71 Esbmated Thi rd Party OD y~u wanl to allow Designee oe,,~.., Paid s~,*,,t~,, )' Preparer's Firm's Name W~ Use Only ,,lf,em¢oyed).~l' 1( h 50 These are your tata~ credits 51 from line 42. If tine 51 ts more than hne 42, enter .0. 51 'H 52 lax Attach Schedule SE d Medlars tax on tip income not reported to employer Attach Form 4t37 )lens, including IR,~, and other ~ax.favored accounts Attach Form 5329 if requ,red led income credit payments from Form(s) W.2 employment taxes. Attach Schedule H ..... This is ~ur total tax me tax withheld from Forms W.2 and 1099 I 1 , 840. [ax payments and amount applied from 2000 return "ne credit (EIC) !arned income ! 61 b1 ¢ security and RRTA tax withheld (see instrs) ~ild tax credit. Attach Form 8812 !nts Check d from a [] Form 2439 al36 .60, 61a, and 52 through 65. These are your 53 54 55 56 57 'No -e than line S8, subtract line 58 from line 66 This is the amounl you overpaid ! 67 ~[ 68a ne 67 you went refunded to you ) ,be, , c Type: []Checmng j-~ S av,ngs 67 you wan[ applied to your 2oo2 estlmaled tax t h~Other person b d[scuss this return with [he IRS (s~ mslrgcbons)? ~ Yes. Complete, ,e %. ~, ~ o~, Electrician' jService Rep ~ p,,o~_,,~ ss:,: :- · ' ElM ~ 23-2262892 Ann Siegfried net's Tax Service ~) 66 '' East High St lisle PA 17013-301S ::,~- 1040 Schedule A I Itemized Deductions I 2001 ~ Attach to Form ]040, -:.~,~,~ ~.~.,-.~ s,~..,~e (99} [ "See Instructions lot Schedule A (Form 1040). Jeffrey A & HarEaret H Klipps Caution. Do hal ~clude expenses reimbursed or pa~d by others. Medical Dental 3 Mumply I~ne 2 abo~e by 7.5% (,075) 4 Subtract hne 3 ftc line 1. If hne 3 is more than hne [, enter .0- 5 State and local ~n :ome taxes 3, 342. j Eec 7 Personalprooerb taxes 436. OPT 201 9 Add hmes 5 throu< h 8 Interest 10 Home mlg ~nterest an( )omb reported to you on Form 1098 ] 0 2. 6 1 3, i 1'~ Home mortgage micra t hal reported to you on Form t098. If pa~d to the person rom who . you bough ho,,a, ,ed i., rvctio,, ,how par,o*', ama, ........................... Note. 11 ............................... ~.~ ....... (Sac ,mis) t3 14 Add hnes 10 thro ~gn )3 Gills to 15 Girts by cash or ( '~eck If you made any gift of $250 or more, ~5 320 :f you made ]6 Other than by ca h or check If any gift of $250 or 18 Add hnes 15 thro J(~h )7 Casualty and Thef~ Losses 19 Casualty or theft Ioss~es~ Attach Form &584. {See mstrucbons,/ , and Most !ob education, et . You must attach Form 2 06 or 2106.EZ Other freou~red (See mstruchons) ~ M iscel,aneous ............... ............................... 21 See 22 Other expenses - ~nvestment, safe depostt box, etc bst for exoenses Z~, ..... uc, - ............... 2~ 2,4 9. ~,ere: 23 Add hnes 20 thr, ugh 22 i :ill 24 Enter amount from F )tm 1040, hne 34 24[ 8 6,4 5 9, 'iiiiii!!i;i 25 Multtdly hne 24; bove by 2% (,02) 25 26 Subtract hne 25 from hne 23. If hne 25 ~s mare than line 23, enter .0. I 26 - - , Miscellaneous - - - 27 Deductions .......................................... Total 28 Is Form 1040. II le 34, over $132,950 (over $66,475 it MFS)? i Itemized for Iin!s 4 through 27. Also, enter this am on Form 104~, ine 36 r- E~ Yes. Your reduction may be limited. See instructions for the amount to enter BAA For Paper'work Reduction Act Notice, see Form 1040 inatructions. FOIA0301 0W07~02 ';;-:.:¢ e A :: - ' ~ Schedule B - Interest and Ordinary Dividends 08 Part I 1 L st name o DaCca any nteres s from a seiler.hnanced morlgage and {ne buYe~ usec I the prooerty as ib personal ree~denee, sac the instrucbons and hs~ this rotates[ h~'s: ~,~so Interest show that buyer'~ soc~al securdy number and address ) _e Lc_o ........................................ 2 Add the amount n hmo I 2 3 Excludable inter ,=st on sones EE and I U.S, savings bonds ~ssued after 1989 from Form 88] 5, hne 14, You muat attach Form 8815 3 4 Subtract line 3 I om hne 2 Enter the result here and on Form 10do, bna 8a ~: 4 ,dO0, you must complete Part III 5 List name of Da: er, rnclude only ordinary dividends. [f you received any capital gain distributions, se ! the ~nstruct~ons for Form 1040, line 13 ~' .............. , 6 AdO the amour' s on hne 5 Enter the tota~ here and on Form 1040. line 9 ~" 6 Note. rf hne 4 is over: Part II Ordinary Dividends Part Ill Vou must complete ac¢ounl; or (¢) rece~ Foreign Accounts and Trusts (See Sdo0, you must complete Part III ti s pa ~ou (a) had over $400 of taxable interesl o1' oromnalv d~wderos: (b) ' ag ~; ': e; ' ,~d a distribution from, or were a granto o 7 a Al any bee dur ~r~ a foreign COL for excebt~one; b If Yes,' enter 8 Durra9 2001, If Yes,' you miry have to nd filing requirements for Form TO F 90.221 file Form 3520 See insfructions BAA For Paperwork Reduction Act Notice, see Form 1040 instructions, ~c,hecu e B . 2441 (99) Child and Dependent Care Expenses ~ Attach to form 1040, "See separate instructions. 2001 21 .;effrey A & Marfiaret M ~<ipps 8efo~'e.vou beg/n: You need ~o under~tand the Iollowmg terms. See Definitions m Ihs mstrucl~ons · Dependent Care Benefits · Qualifying Person(s) · Qualified Expenses Persons or Organiz,~dons Who Provided the Care - You must complete th,s par~ · Earned Income "' ,'ou need more space se the botto olpage 2) 1 (al Care provider s name (b) Address (no, street, apt no, city, state, and ZiP code) / 8ethe~ Chr stian Academ~, 1412 Holl~v_P_i_ke_ / (SSN or'EIN) see ';' .:': 23-]982986 D~d yot dependent [ ~i~ Cred t for Child and In%rmahon about ),our qualityin(. (al Qualif First Joseph Ashley Add the amounts in column (c) 0 )ependent Care Expenses person/s). If you have more than two quahfyln9 ,lng person's name Last Kipps Kipps (b) Quahfy,ng persons soo,al security number 172-72-9592 182-74-7365 tine 2, Do not enter more than $2,400 for one quaflfyrng person or $4,800 ~mpleted Part III, enter the amount from line 24 o' was ~, 5aOl.d. see the inslruch, ,ns); a others, enter the amount from line 4 ? Em;er the amount from Form )04(t, hne 34 ? 86, ~t59 / But not Over over $0- ~0,000 t 0.000 -- i 2,000 ~2 000- ~4.000 i4,000 - )6,000 16,000- 18,000 ;8000- 20,000 Decimal Decimal amount But not amount is Over over is 3O .29 28 27 ,26 .25 $20,000- 22,000 .24 22,000 - 24,000 23 24,000- 26,000 22 26,000- 28,000 .2) 28,000- No hilt 20 Jnt on line 8. Enter the result here and on Form than the amounl on Form 1040, line 42, remus any expenses in 2001, see lhe instructions for the amount BAA For Paperwork Reduction Act :(C) Qualified expe~ ce, see separate instructions, 8 × Schedule A I iscellaneous Itemized Deductions Statement 2001 Lines 20, 22, 27 "Attach to return (after al~ IRS forms) Statement .Teffre~ A & Mar_c~ret N ~ Employee Business Fkpenses - Subject to 2% Limitation i ]68-48-3562 1 2 Excluded expense.~ 3 Other unre~mburse( a Umon and professi, b Professional subsc~ c Umforms and prote d Job search costs e Olher: smart toots Unrmmbursed employee expenses from Form 2106 fi'om Form 2555 employee business expenses: ~nal dues ptions :five clothing 4 Total unreimburse, Miscellaneous Expens, 5 Depreciation and an 6 Casualty/theft Iosse.~ 7 REMIC expenses, tr~ 8 Inveslment expense: 9 Deductions related excess deductions 10 Miscellaneous dedL 11 Other miscellaneous a Inveslment counsel [ b Cerlam attorney and c Safe deposH box ren d IRA Cuslodlal Fees e ©lhe~ 12 Total miscellaneous Other Miscellaneous De employee business expenses (combine lines 1 · 3e) - Subject to 2% Limitation Investment Expense ortization deductions of property used in serwces as an employee m Schedule E related to interest and dividend income portfolio income, miscellaneous deductions, and i termination, from Schedule(s) K.1 ions excluded on Form 2555 expenses: nd advisory lees accounting fees al fees :penses (combine lines 5 through 11e) tuctions- Not Subject to 2% Limitation 13 Federal estate tax pa~ on decedent's income reported on this return 14 Miscellaneous deduct exWuded on Form 2555 15 Impairment.related e:, penses of a handicapped employee, from Form 2106 16 Amorhzable bond pre niums On bonds acquired before 10/23/86 17 Gambhng losses (to extent of gambling Income) 18 Casualty/theft Iosse producing property 19 Other mfscellaneous eductions: 4 i 2,370 6 7 8 10 12 13 14 15 16 17 18 19 20 Total other miscellaneous deductions (combine lines 13 through t9) 20 HarRaret .M Kip_ps Child and ,Dependent Care Expenses ~._~.~.,o, ,~,o~a~' . . ,.ch,o,o m 10,o. t 2002 Persons or Organizations 'Who Provided the Care - You mu, com.~leI~, this part ' Earned Income ......... .... Caution: I[ Ihs cafe wes provided in your [,; ai~ Credit t~or Chitd and De (a) Ou-3111y~nG ,~shte¥ ,oma, you may owe employment laxe$. See the instructions for Form 1040, I~ne 60. endent Care Expenses ~$ ]82-74; 7365 6 ~'ntcr the smallest of line3.4 m 5, J 7 Emer thc amount from Form 1040 lit' 36" , ". ' ,, ', 7 Fine ? is: $20,000 - 22,0(X~ ~..t 22,000- 24,000 2,~.OOO-- 26,000 22 :?$,000- No rlmit $0- 1O,00O 30 10,000- 12,000 ~ 12,000- 14,000 28 i 14,000- 16.000 27 I~,O00- 20000 .25 here er~d on Fo'm 040, ne 46 BAA For Pepm'Work Reduction Act Notice. (C) Qualified inmJrred and p~t~ in 100= 100. 36, ]94. 3~, × 020 20. 571. 20, Form 24~1 ~'o,..~ 8~JO / Credit for Qualified Retirement Savings Contributions '" ' ' 2002 of claim th~s cre~i~ ff any ol ~he ~oHowi- ~ ' ~ ~ 84- 54 - · YO~ a *tuden n ~0~ ~e i' 4 e~tension~)O.~your.~taxreum . $15,000 $ I~ 000 $16,250 $16.250 $22,500 $22,500 $24.375 $24,375 $25,000 $25,000 $30,000 $30,000 $32,500 $32,500 $37,$00 $50,000 _ $~0,000 .., ,0 __ __0 .0 ?0Nkgliply line ? by hne 9 ' ribufiene. F.r~ler the smaller of iir~e lO or line 13 here arid on -- Form 8880 II~r~aret /9 K~pps , 3 Number Of ~uaHfyihg ;hi~en: 2 x ~0. Enter U~e result ......... z 36,395. 4 Add lines 2 and 3. · Married IHing iOil widow(er) ~ $75 $1,000, inter the (ot~l ....... tly - $) ~0.000 DO0 arolely - $55.000 4 -. 96.395. 5 7,5.000 Line 45 (.in¢ -!6 Line 47 Line 48 Tip beiow, ~l.O00 (lot example, i~crease $425 o 2n hne 6 by 5% (,0§). Enter the result more th~n the amount on line 77 1040. line 44, or Form 1040A, line 28 ;orm 1040A: Line 3~ + m 8839 'edlt, Form 8396 92. 1. 200_~ 3., ;'00. Fornl I040A, line 33 112. ,:,,~.W-2 Wage and 'Tax Statement 2002 P12 23- 1175870 4173,65 ~3ol.os 538.16 co.~ O t 920.02 VERIFICATION I, M~rgaret M Kipps, the undersigned, hereby verify and confu'm that I have reviewed the foregO~g document and the information contained therein is true and correct to the ,[ best of my knowledge, information and belief. I further understand that any false statements l made herein are sub{ect to the penalties of18 Pa.C.S.A. Section 4904, relating to unswom falsification to auth~ties. Margaret M. Kipps CERTIFICATE OF SERVICE I, Jar a tree and correct cc the follow'rog addre,, Carol J. Lindsay, Es Saidis Shuff 26 West High St. Carlisle, PA 17013 DATE: 10/31/03 les W. Abraham, Esquire, the undersigned, hereby certify that I have served py of the foregoing document by first class mail to the following person at s on the date stated below: MARGARET M. KIPPS Plaintiff : I N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA. : NO. 2002 - 2542 CIVIL JEFFREY A. KIPPS Defenc ant :DIVORCE PLAINT~F'SllqVENTORY Plainti~, Margaret M. Kipps, files the following Inventory of all of the property owned or possessed b1 either party at the time this action was commenced and all property transferred within the ~receding three (3) years as verified by Plaintiffpursuant to the signed Verification attached hereto and made part hereof. DATE: ABRAHAM LAW OFFICES James W. Abraham, Esq. 2157 Market St. Camp Hill, PA 17011 (717) 763-1700 Attorney for Plaintiff, Margaret M. Kipps ASSETS OF THE PARTIES Plaintiffmarks on the following list those items applicable to the above-captioned action and itemizes th~ assets on the following pages. (x) 1. Real Property (x) 2. Motor Vehicles ( ) 3. Stocks, bonds,; ( ) 4. Certificate orb ( ) 5. Checking accot ( ) 6. Savings accoun ( ) 7. Contents of sat ( ) 8. Trusts ( ) 9. Life Insurance ( ) 10. Annuities ( ) 11. Gifts ( ) 12. Inheritances ( ) 13. Patents, copyr ( ) 14. Personal prope ( ) 15. Business (owne ( ) 16. Employment te~ ( ) 17. Profit sharing p (x) 18. Pension plans (~ (x) 19. Retirement Plar ( ) 20. Disability payn ( ) 21. Litigation claim ( ) 22. Military/V.A. ( ) 23. Education ben (x) 24. Debts due, inc (x) 25. Household furn distribution of~ (x) 26. Other: Tools ~,ecurities and options eposit nts, cash :s, money market and savings certificates deposit boxes olicies (face, cash surrender value/beneficiaries) fits, inventions, royalties ty outside the home ~s, percentage of, positions held) mination benefits/severance pay, workers comp. ans mployee contributions/date plan vests) S, IRAs ents ; (matured/unmatured) enefits its ding loans, mortgages shings and personalty (include as total category; attach itemized list if ssets is disputed. MARITAL ASSETS ,ITEM NO. 1 18 18 25 26 ITEM NO. 24 PROP marita Carlis] 2000 } Truck Addifi Sprim, Retiren House+ld Tools DESCI mortgal residen, ERTY DESCRIPTION residence 3063 Rimer Highway :, PA (equity $80,000) !arley Davidson ($15,000); 1994 Ford $10,000); 1996 Chrysler Minivan ($5,000) anal motorcycles ($2,000) [01(k) ($80,000) and deferred pension tent Annuity Plan furnishings ($5,000 FMV) MARITAL DEBTS ~TION CREDITOR marital CUNA Mutual ALL OWNERS Joint Joint Wife Husband Joint Joint DEBTORS .AMOUNTS Joim $35,000 ~ON-MARITAL ASSETS ITEM NO. 18 PROPERTY DESCRIPTION Pre-m~ Sprint 1989,~ 1990,~ xital portion of 401(k) and deferred pension from late of employment, thru [ate of marriage. _ALL OWNERS Wife NON-MARITAL DEBTS Plainti~is not aware of any non-marital debts, however, Plaintiffreserves her rights as to any claim ~r defense as to marital debts. .PROPERTY TRANSFERRED No prop Plaintiff is not aware of rights as to any claim ol ,'rty of the marital estate has been transferred or converted by Plaintiff. any other transfers or conversions by Defendant. Plaintiffreserves his defense as to property transferred or converted by Defendant. VERIFICATION I, Mbx~aret M. Kippo~ the undersigned, hereby verify and confn-m that I have reviewed the foregoing document and the ~nformat~on contained therein is tree and correct to the best of my knowledle, mformat~on and behef. I further understand that any false statements made herein are subi~ct to the penalties of18 Pa.C.S.A. Section 4904, relating to unswom falsification to auth, ities. Margaret 1~. Kipps CERTIFICATE OF SERVICE I, Jam~~ W. Abraham, Esquire, the undersigned, hereby certify that I have served a true and correct cop the following address Carol J. Lindsay, Esq. Saidis Shuff 26 West High St. Carlisle, PA 17013 DATE: 10/31/03 of the foregoing document by f~rst class mail to the following person at 3n the date stated below: James W. Abraham, Esquire SAIDIS SHUFF, FLOWER & LINDSAY ~o~,~ 26 W. High Street Carlisle, PA MARGARET M. KIPPS, Plaintiff/Respondent VS, JEFFREY A. KIPPS, Defendant/Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW · ' NO. 2002 - 2542 CIVIL TERM . : IN DIVORCE DEFENDANT'S MOTION TO COMPEL DISCOVERY NOW COMES Jeffrey A. Kipps, Petitioner/Defendant above, and moves this Honorable Court as follows: 1. The parties hereto are husband and wife, having been joined in marriage on March 24, 1990 and having separated on or about October 20, 2001. 2. The party's economic case is before the Divorce Master and should be scheduled for a pre-trial conference for December 8th, 2003. 3. On October 31st, 2003 Petitioner served on Respondent a Request for Production of Documents a copy of which is attached hereto as Exhibit '%". 4. Thirty days have passed and there has been no response to the document request. 5. The documents requested are required to value the Respondent's retirement benefits. WHEREFORE, Petitioner prays this Honorable Court to issue a Rule upon the Respondent to show cause why the relief requested should not be granted. SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for Defendant Carol J. ~inds~/~.Esq uire ID¢~446~3 26 ~ High Street Carlisle, PA 17013 (717) 243-6222 VERIFICATION SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA Date:_ I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. C~Llndsay ~ SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Slreet Carlisle, PA MARGARET M. KIPPS, Plaintiff VS. JEFFREY A. KIPPS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA .. : CIVIL ACTION - LAW : NO. 2002.2542 CIVIL TERM : : IN DIVORCE CERTIFICATE OF SERVICF AND NOW, THIS DAY OE ~.~-¥..t, 2004, I, CAROL J. LINDSAY, ESQUIRE, OF THE LAW FIRM loF~xSAIDIS, SHUFF, FLOWER & LINDSAY, A'I-rORNEYS, HEREBY CERTIFY THAT I SERVED THE WITHIN DEFENDANT'S MOTION TO COMPEL DISCOVERY THIS DAY BY DEPOSITING SAME IN THE UNITED STATES MAIL, FIRST CLASS, POSTAGE PREPAID, IN CARLISLE, PENNSYLVANIA, ADDRESSED TO: MARGARET M. KIPPS CIO James W. Abraham, Esquire 513 North Second Street Harrisburg, PA 17101 SAiDIS, SHUFF, FLOWER & LINDSAY Attomeys for Defendant L;ar ,d~<~l~indsay, Esquire ID# 4~r_~:~'3 ' 26 West High Street Carlisle, PA 17013 (717) 243-6222 MARGARET M. KIPPS, Plaintiff/Respondent VS. JEFFREY A. KIPPS, Defendant/Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2002 - 2542 CIVIL TERM : : IN DIVORCE ORDER OF COURT AND NOW, this .2t n _dayof__ ~',~,~,~ ~, 2004, upon consideration of the within Petition, a Rule is issued upon Respondent, Margaret M. Kipps, to show cause why she should not provide the discovery requested. RULE returnable days from the date of service hereof. By the Court, SAIDIS FLOWER LINDsAY SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA MARGARET M. KIPPS, Plaintiff JEFFREY A. KIPPS, VS. Defendant : iN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2002- 2542 CIVIL TERM : IN DIVORCE NOTICE YOU ARE HEREBY NOTIFIED to plead to the within New Matter and within twenty (20) days after service of this Answer and New Matter. SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for D_e~fendant iCDa~Ol4~dsa,, Esquire 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA MARGARET M. KIPPS, Plaintiff JEFFREY A. KIPPS, VS. Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2002 - 2542 CIVIL TERM : : IN DIVORCE AMENDED ANSWER AND COUNTER-CLAIM TO PLAINTIFF'S COMPLAINT IN DIVORCE NOW COMES Jeffrey A. Kipps, Defendant above, and answers the Divorce Complaint and states a counter-claim as follows: DIVORCE PURSUANT TO §3301(c) OF THE DIVORCE CODE 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. Admitted. WHEREFORE, Defendant requests this Honorable Court to enter a Decree in Divorce dissolving the marriage. SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High $1reet Carlisle, PA COUNTII-DIVORCEPURSUANTTO 23 Pa. C.S.A. §3301(a)(6) - INDIGNITIES 9. Denied that Defendant has caused such indignities against Plaintiffwhich has made her life burdensome and intolerable. Denied that Plaintiff is an innocent and injured spouse. COUNTER-CLAIM The averments in Paragraphs 1 through 9 are incorporated herein by 10. reference. 11. During the course of the marriage, the parties have acquired property both personal and real. 12. In preparation for the hearing in the captioned case, Defendant has incurred certain costs for appraising real and personal property. WHEREFORE, Defendant prays this Honorable Court to equitably divide their property and to award him costs. SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for De{~xdant Car. e'l J.I L]'ndsay, EsqUire I1~ 447~.W.e,st9H3igh Street Carlisle, PA 17013 (717) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY 26W. High Street Carlisle, PA VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. ~,/~'~ ~' Jeft~ey A. Kipps Date: /--/~' - C) d SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA MARGARET M. KIPPS, Plaintiff JEFFREY A. KIPPS, VS. Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2002 - 2542 CIVIL TERM : IN DIVORCE CERTIFICATE OF SERVICE AND NOW, THiS ~j DAY OF f~-~ , 2003, I, CAROL J. LINDSAY, ESQUIRE, OF THE LAW FIRM OF SAIDIS, SHUFF, FLOWER & LINDSAY, ATTORNEYS, HEREBY CERTIFY THAT I SERVED THE WITHIN AMENDED ANSWER TO COUNTER-CLAIM TO PLAINTIFF'S COMPLAINT FOR DIVORCE THIS DAY BY DEPOSITING SAME IN THE UNITED STATES MAIL, FIRST CLASS, POSTAGE PREPAID, IN CARLISLE, PENNSYLVANIA, ADDRESSED TO: James W. Abraham, Esquire 2157 MARKET STREET CAMP HILL, PA 17011 SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys f o ~X~t~ ~es6t. Lindsay, Esquire 93 High Street Carlisle, PA 17013 (717) 243-6222 82/83/2884 11:47 717243B510 SAIDIS SHUFF FLOWER PAGE 82/83 SAIDI$ SHI/FF, ~OWER & LINDSAY MARGARET M. KIPPS, Plaintiff vs. JEFFREY A. KIPPS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Cl~r/IL ACTION - LAW NO. 2002 - 2542 CIVIl. TERM IN DIVORCE PLAINTIFF'S AFFID__AViT OF CONSENT U~NpER _G33011c} C~F THE DIVORCE CODE ~AND WAIVE~ OF COUNSELING A Complaint in Divorce under §3301 (c) ef the Divorce Code was filed May 24th, 2002. The marriage of plaintiff and defendan~ ts irretrievably broken and ninetV days have elapsed from the date of filing and service of th~ Complaint. I consent to the entry of a final Oec~ae in Divorce after service of notice of intention to request entry of the Decree. I verify that [he statements made in this Affidavit 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 unswo~':~ falsification to authorities. -- - ~af~r~t~ipps. Plaintiff PLAINTIFF'~S WAIV~ER OF NOTICE OF INTENTION TO REQUEST .ENTRY OF ~. DIVORCE DE.C..REE UNDER § 3301 to.} OF THE DIVORCE C_ODE 1. I consent to the entry of a final Decree of Divorce without notice. I understand that I may lose rights co,cerning alimony, division of property, lawyer's fees or expenses if I do not claim them beforn a divorce is granted. I understand that I will not be divorc,~,d until · Divorce Decree is entered by the Cou~ and that a copy of the Decree will b(~ sent to me immediately afler it is filed with the Prothonotary. J verify that the statements made in th s Affidavit are true and correct to the best of my knowledge, information and belie1' I understand that false statements herein are made subject to the penalties of 18 Pa. CS. 4904 rehfling to unsworn falsification to authorities ~a~g~re( ~lpps, Plaintiff 82/03/2004 11:47 7172436510 SAIDIS SHUFF FLOWER PAGE D3/03 SAIDiS SltUF~, FLOWI~R & LINDSAY CaHble, PA MARGARET M. KIPPS, Plaintiff vs. JEFFREY A. KIPPS, Defendant IN 'rile COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CI'FIL ACTION - LAW N(I.. 2002 - 2542 CIVIL TERM IN DIVORCE pEFENDANT'S AFFIDAVlT OF CONSE.NT UNDER §3301(c) OF THE DIVORCE CODE AND WAIVER~F COUNSELING A Complaint in Divorce under {}3301 (c) of the Divorce Code was filed May 24~, 2002, The marriage of plaintiff and defendant: ia irretrievably broken and ninet~ days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a final Decree in Divorce after sorvice of notice of intention to request entry of the Decree I verify that the statements made in this Affidavit are true and correct tO the best of my knowledge, information and belief. I unclerstand thal false staIemenfs herein are made subject to the penalties of 18 Pa.C,S, 4904 relating to unsworl~ falsification lo authorities. fJe~e~ A~ipps, Defend'at[t DEFENDANT'S .W. AIVER OF NOTICE OF INTENTION TQ. REQUEST ENTRY OF A D VOR~E DECREE UNDER_ _~ 3301 c~.!~)F THE D VORCE CODE 1, I consent Io the entry of a final Decree of Divorce without notice, I understand that t may Iose rights con,;aming alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I understand that I will not be dlvorce(~ until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent Ia me immediately after it is filed with the Prothonotary. I verif7 that the statements made in this Affidavll are true and correct to the best of my knowledge, information and belief. ~ understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unswom falsification to authorities Date: Je~rey'A. ~ipps, De fe~10/a~l / MARGARET M. KIPPS, : Plaintiff : JEFFREY A. KIPPS, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 2542 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this /~ day of ~~ , 2004, the parties and counsel having entered into an agreement and stipulation resolving the economic issues on February 3, 2004, the date set for a Master's hearing, the agreement and stipulation having been transcribed, and subsequently signed by the parties and counsel, the appointment of the Master is vacated and counsel can conclude the proceedings by the filing of a praecipe to transmit the record with the affidavits of consent of the parties so that a final decree in divorce can be entered. BY THE COURT, CC: James W. Abraham Attorney for Plaintiff Carol J. Lindsay Attorney for Defendant MARGARET M. KIPPS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW JEFFREY A. KIPPS, : NO. 2002-2542 CIVIL Defendant : IN DIVORCE THE MASTER: Today is Tuesday, February 3, 2004. This is the date set for a hearing on certain specific issues set forth in the Master's memorandum of December 8, 2003. However, the parties have spent considerable time with their counsel today working toward a resolution of all the issues, and the Master has been advised that a comprehensive settlement has been reached with respect to the outstanding claims raised in the action. Present in the hearing room are the Plaintiff, Margaret M. Kipps, and her counsel, James W. Abraham, and the Defendant, Jeffrey A. Kipps, and his counsel, Carol J. Lindsay. The complaint in divorce in this action was filed on May 24, 2002, raising grounds for divorce of irretrievable breakdown of the marriage and indignities. Before the parties leave today they will sign affidavits of consent and waivers of notice of intention to request entry of divorce decree and provide those signed documents to the Master, who will file them with the Prothonotary's Office. The divorce will be able to proceed, therefore, under Section 3301(c) of the Domestic Relations Code. The parties were married on March 24, 1990, and separated October 20, 2001. They are the natural parents of two children. Both the children are minors and are in the custody of wife. Husband filed a counterclaim in this action raising Husband provided the economic issue of equitable distribution. today a counterclaim asking for fees and costs. Neither party has filed a claim for alimony. The agreement is going to be placed on the record in the presence of the parties. The agreement placed on the record will be considered the substantiative agreement of the parties and will not be subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. The agreement as stated on the record after typographical errors have been corrected is the substantive agreement of the parties and will be transcribed and the parties will be asked to s!gn the agreement affirming the terms of settlement. However, even if a party does not sign the agreement, they are bound by the terms of the agreement as stated on the record today when they leave the hearing room. The agreement will be sent to counsel after it has been transcribed via the postal service for counsel to review for typographical errors, make corrections as required and then 2 the parties will be asked to affirm the settlement by signing the agreement. Upon receipt by the Master of a completed agreement the Master will prepare an order vacating his appointment and counsel can file a praecipe transmitting the record to the Master requesting a final decree in divorce. Ms. Lindsay. MS. LINDSAY: The parties have agreed to the equitable distribution of their property as follows: 1. Wife will receive the marital home located at 3063 Ritner Highway in Carlisle. Within 45 days of the date of this agreement wife will refinance the marital home so that husband is no longer liable thereon, and, at the time of refinance, will pay to husband $73,000.00. In order to facilitate the refinancing on the date of the refinance, husband will provide the deed to wife and the settlement agent will guarantee the payment of the $73,000.00 upon the passing of the recision period. Pending the refinance, wife will be solely responsible for payment of principal, interest, taxes and insurance and any expenses associated with the marital home and she will indemnify and hold husband harmless on account of any such expenses. 2. Wife will receive the 1996 Chrysler Town & Country. Husband will receive the 1994 Fl50 truck and the 1998 VW Fox. Within 10 days of the date of this agreement husband will execute any and all documents necessary to transfer his interest in the Chrysler to wife. On Wednesday, February 4, 2003, husband will pick up at wife's residence the garden tractor and its attachments, which shall be his separate property. 3. The parties have already satisfactorily divided their credit union accounts. Each will receive those accounts as a portion of the equitable distribution scheme set out herein. 4. Each of the parties will retain his or her interest in any 401Ks, pensions or stock option plans titled in their name and received through their employment. 5. The personalty of the parties has been satisfactorily divided. Husband has received $3,875.75 worth of personalty, and wife has received $5,802.00 worth of personalty. 6. Additionally, husband had a certificate of deposit which received premarital assets in 1990. Husband will receive the increase in value iR that premarital asset worth approximately $3,055.00. The money which husband is retaining as the increase in value ef the marital property, as well as the personal property values, have all been taken into account in the single $73,000.00 payment which wife is to make to husband. 7. Husband will retain his 2000 Harley Davidson motorcycle. 8. The parties warrant each to the other that there are no marital debts of which they are aware for which the other would be liable. Each will pay any obligation which is titled in his or her own name. 9. The husband withdraws his amended answer and counterclaim for attorney's fees and costs. 10. Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all right he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship, including without limitation, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate. Each will at the request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such rights, interests and claims. THE MASTER: with your client. MS. LINDSAY: Now, if you want to go on the record Mr. Kipps, you have been here as I read the terms of an agreement you have reached with your wife here today, is that correct? terms? MR. KIPPS: Yes. MS. LINDSAY: Did you hear and understand all the MR. KIPPS: Yes. MS. LINDSAY: Are they acceptable to you? MR. KIPPS: Yes. MS. LINDSAY: Do you have any questions about them? MR. KIPPS: No. I get $73,000.00 in cash, right? MS. LINDSAY: That is correct. MR. KIPPS: And the tractor, and then everything that is in my column stays mine, right? MS. LINDSAY: I believe that is correct. MR. KIPPS: Okay. THE MASTER: MR. ABRAHAM: Mr. Abraham. Margie, any and all claims or counterclaims in the divorce are resolved by a lump sum payment to Mr. Kipps in the amount of $73,000.00 at the time you refinance the marital residence, and then he will also be getting the garden tractor tomorrow night, and that resolves any and all claims in regard to your divorce, do you understand that? MS. KIPPS: Yes. MR. ABRAHAM: Do you have any questions for the Master? MS. KIPPS: No. MR. ABRAHAM: Very well.. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations Code.  ~____~ DATE: James W. Abraham Attorney for Plaintiff ~rg~et ~.' Kipps Attorney'  DATE: Defendant A. ~ipps LISA K. TROLINGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2003 - 2542 CIVIL TERM vs. GALEN G. TROLINGER, Defendant : IN DIVORCE PETITION FOR ALIMONY PENDENTE LITE Now comes Lisa K. Trolinger, by and through her counsel, SAlOIS, SHUFF, FLOWER & LINDSAY, and petitions this Honorable Court as follows: 1. The parties hereto are husband and wife, having been joined in marriage on August 28, 1982. 2. The parties separated on or about May 2, 2003. 3. Petitioner is without the ability to earn income sufficient to meet her reasonable needs and to pay attorney's fees WHEREFORE, Petitioner prays this Honorable Court to order alimony pendente lite in an amount equal to the Pennsylvania'State Support Guidelines and reasonable attorney's fees. SAlOIS, SHUFF, FLOWER & LINDSAY Attorneys for Plaintiff Petitioner SAIDIS SHUFF, FLOWER /-1 q ~o 5 & LINDSAY By: ATI'ORNEYS.AT.LAW 26 W. High Street Carlisle, P A Carol J. Linds 10 # 44693 / 26 West Hig eet Carlisle, PA 17013 (717) 243-6222 SAlOIS SHUFF, FLOWER & LINDSAY AnuRNEYS'AT'LAW 26 W. High Street Carlisle, PA 1\ VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904, relating to unsworn falsification to authorities. t.Jt.. )( .Jw~-r':CUJ Lisa K. Trolinger if Date: / J /1 J D ~ , . SAIDIS SHUFF, FLOWER & LINDSAY ATTORNEYS-Ar-LA W 26 W, High Street Carlisle, PA CERTIFICATE OF SERVICE I, Carol J. Lindsay, Esquire, of the law firm of SAlOIS, SHUFF, FLOWER & LINDSAY, Attorneys (//?IJVt:lI--tj hereby certify that on this :J tJ #; day of , 2005, served the within Petition for Alimony Pendente Lite this day by depositing same in the United States Mail, First Class, postage prepaid, in Carlisle, Pennsylvania, addressed to: Michael A. Scherer, Esquire O'Brien Baric & Scherer 17 West South Street Carlisle, PA 17013 SAlOIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: . Caro J. Un 10# 44693 26 West High Street Carlisle, PA 17013 (717) 243-6222 PETITIONER: DOB: ADDRESS: PHONE: ATTORNEY: DRS A'IT ACHMENT FOR APL PROCEEDINGS Lisa K. Trolinger 6/29/1960 300 3"' Street Boiling Springs, P A 17007 (717) 254-5850 SSN: 191-46-0963 Carol J. Lindsay, Esquire PETITIONER'S EMPLOYMENT: NET PAY: JOB TITLE: clerk Carlisle Pediatric Associates How LONG? one year $1,976.27 PER month OTHER INCOME: (INCLUDE AMOUNT AND SOURCE) Respondent: Galen G. Trolinger DOB: ADDRESS: PHONE: 7/28/1956 SSN: 194-52-0048 615 West Pine Street Mt. Holly Springs, P A 17065 ATTORNEY: Michael A. Scherer, Esquire RESPONDENT'S EMPLOYMENT: CARLISLE TIRE & WHEEL COMPANY How LONG? Over 9 years NET PAY: $2,757.77 PER month JOB TITLE: laborer OTHER INCOME: (INCLUDE AMOUNT AND SOURCE) WHEN MARRIED: AUGUST 28, 1982 WHERE: CARLISLE, PA DATE SEPARATED: MAY 2, 2003 WHERE LAST LIVED TOGETHER: 615 West Pine Street Mt. Holly Springs, P A 17065 FOR DRS INFORMATION ONLY n ~...:> n C~ , ,....;J ."n 0"'\ ~.- :::J ..-".~ -- , t"',) ( CJ -.c" , i r-; , , C.....)