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Home My WebLink About94-01085 .. .. , , .*~'~~ro**~~_~***_~_*~*),~~:~:_:_.._~~~~'. ,', -..-.-...-.----- . -----~-- --- --.-- . to ~ . " ,', ~ ,', ~ IN THE COURT OF COMMON PLEAS *1 ~I V{ ,', ~ ~ '.' OF CUMBERLAND COUNTY ~ PENNA, STATE OF ~i '.' ~ CAROL S. BRICKER, plaintiff Nil. , 1085 CIVIL (<]4 ~ ~ ~, \'t'rsll~ ~ KENNETH E. BRICKER, JR. ~ Defendant ~ ~ ~! "/ ~I " DECREE IN , D f V 0 R ecA- it. '2.', UI eu. AND NOW. . . . . . . . . .1. . . . . . . . . .. " 19....... it is ordered and decreed thnt ........ .~~r~.~ .~:. ~~~~~.e~ ~ . .... ... .......... ". plaintiff, and. . . . . .. . . . . . ~~.n~~~~ .~: . ~.~~~~~.r,. . ~~:. . . . . . . . . . . . . . . . . ., defendant. ore divorced from the bonds of matrimony. ~ .. $ ~ 8 ,', ~ ~ ~ The court retnins jurisdiction of the following claims which have been raised of rp.cord in this action for which a final order has not yet been entp.red; ~ ~ * All economic issues raised of record are resolved by the agreement'ieached'by'the'parties'on'Marcn'jb~"1~95'berore'Special Di-vorce .Master. .E. . Robert. Elicker ,. I.I. .. A .true .and .corr.ect. ~QPY. of the ag ent is attached as Exhibit "A". i '.' w '.' ~ .' ~ ~. ~ '.' :J;;:1?"IU:IU~ C' /<-k.~: /-'~""~JY J. ';<:;t./). J~ ~"" .k ,%;&: "op~ /' 1)rot'flonolary * ~ .Y~ . '7 ~ ~ ...~.~.~~~~********~*~.~~*~..~.' ~ '.' ;i! '.' ~ '.' ~ '.' i ',' i ',' ;i! " ;i! '.' .', ~ .', ~ ;i! '.' ~ W ':> ~ '.' $ i.- ~ i ,~ i '.' .. ($ !~ (~ I' ~ '.' * * I: I~ )',' (~ !'.. I :~ /,', i~ I i.. i~ I,', ;:!- :* ~ ~ ~ ;( If, fs ad dyp I'f~ ~ 4- ./'1k {If' 9j"' 'f1k /H.~ ~ ciIf r ~ ~ .. ;. ~ . ",-' .. . CAROL S. BRICKER, : IN THE COURT OF COMMON PLEAS OF plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . . VB. . NO. 1085 CIVIL 1994 . . . KENNETH E. BRICKER, JR., . . Defendant : IN DIVORCE THE MASTER: Today is Thursday, March 30, 1995 Present for a conference scheduled this date are the parties, Carol S. Bricker and Kenneth E. Bricker, Jr. Present on behalf of Carol S. Bricker is her counsel Theresa Barrett Male and present for Kenneth E. Bricker, Jr. is Barbara J. Yunis. A divorce complaint was filed on March 7, 1994, raising grounds for divorce of irretrievable breakdown of the marriage. The complaint did not raise any economic issues. The wife, however, subsequent to the filing of the complaint, on November 9, 1994, filed a petition raising economic claims of equitable distribution, alimony, alimony pendente lite, and counsel fees and expenses. The parties were married on May 12, 1990, and separated December 31, 1993. Prior to the marriage of the parties, the parties did live together since August of 1988. Following the pre-hearing conference held on February 17, 1995, counsel have engaged in negotiations with respect to the outstanding issues and have obtained necessary data to continue the process of negotiations. The Master has been advised that the case has been resolved with respect to the EXHIBIT I ^ . ~ outstanding economic claims and counsel are going to place the agreement on the record in the presence of the parties. The agreement, as placed on the record, will be considered the substantive agreement of the parties and not subject to any modifications except for correction of typographical errors which may be made in the transcription. Therefore, what we place on the record today except for typographical corrections will be the substantive agreement of the parties, not subject to modification. We are going to have the agreement transcribed today and ask the parties and counsel to return to review the draft for any errors that may have been made in the transcription; after those errors have been corrected, if any, the parties will affix their signatures along with counsel in affirmation of the agreement that was previously entered on the record. The Master will then prepare an order vacating his appointment in the proceedings. The Master will also file with the order the affidavits of consent of the parties which have been signed and dated March 30, 1995, so that the divorce can be concluded under Section 3301(c). Ms. Male. MS. MALE: 1. The parties previously owned improved real estate situate at 1333 Zimmerman Road, Carlisle, Cumberland County, Pennsylvania. The property was sold to Edwin Z. Horst, Jr. and Lydia J. Horst, with the settlement date of March 24, 1995. Proceeds from the sale have been held in escrow by the settlement agent, Mike Hanft, Esquire. . . The proceeds total $78,936.33. The parties have agreed to distribute those proceeds as follows: 60% to husband for a total of $47,361.80 and 40% to wife for a total of $31,574.53. 2. with respect to personal property, all tangible personal property in husband's possession will be his sole property without claim or offset by the wife with the exception of the following items: Television, television stand, lights, dishes, glasses, two vacuum cleaners, one dresser, a dress, patio furniture, ironing board, bassinet, jackets and coats, Christmas ornaments, and other miscellaneous items. Those enumerated items are awarded to wife and wife acknowledges that she has received those items prior to today's settlement. All tangible property in wife's possession will remain wife's sole and separate without claim or offset by husband. 3. In terms of intangible personal property, the parties have acquired during the marriage stock, most of which is held by wife in custody for the children, Lindsey and Katie. Husband holds some stock in a custodial account for Katie. The parties have agreed to maintain those accounts solely for the use of the children's education, support and maintenance. The parties agree that husband and wife shall be able to utilize in their sole discretion the funds which each currently holds in accounts for the children. 4. with respect to debts and liabilities husband will satisfy the MasterCard balance and will not seek any reimbursement from wife toward that bill. He will reimburse wife $250.00 towards Lindsey's orthodontic bill and $350.00 towards Lindsey's expenditures related to a family pet. The parties acknowledge that approximately $700.00 of the MasterCard balance was charged for repairs to wife's vehicle; therefore, there will be no exchange of monies between the parties. In other words, the $250.00 and $350.00, which husband otherwise would have paid to wife is essentially being applied to the $700.00 charge for repairs to her car. . 5. Wife will retain possession of the 1990 Tempo and husband has agreed to execute the title to the car today. 6. Wife has agreed to contribute 50' toward household expenses while the house was being marketed for sale. The parties, through counsel, have reviewed the charges incident to that and have agreed that wife's contribution is $328.70. In order to contribute that amount wife has agreed to credit the arrears on husband's child support order, which is docketed to Cumberland County, No. 27 of 1994 DRO No. 22,217 in that amount of money. 7. Neither party will pursue any additional economic claims and wife specificallY withdraws her claims for alimony, alimony pendente lite, and counsel fees. 8. With the exception of the marital debts and liabilities previously discussed, there are no other debts or obligations incurred during the marriage for which the parties are responsible. They are, however, responsible for any liabilities incurred in their own names since their separation date. 9. Previously, during the pre-hearing conference with the Master, counsel had discussed a possible issue as to cash or surrender value of life insurance policies. Both parties are satisfied that there are no life insurance policies with any cash or surrender value acquired during the marriage or otherwise subject to distribution. 10. Husband had received a withdrawal from his SERS pension in the sum of $3,988.18. Wife waives any and all claims with respect to those monies. 11. Wife has an IRA which she acquired prior to the marriage. There has been no value placed on the IRA prior to this settlement agreement but husband expressly waives any claims which he may have had to the increase in value of the IRA if indeed any increase had occurred. 12. At the time of separation husband received approximately $104.48 in a Meridian Bank checking account and a savings account balance of $77.28. Wife waives any claims to those monies. 13. 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 rights 1 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, dower, curtesy, 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 interests, rights, and claims. MS. MALE: Ms. Bricker, have you been present while I've described the terms of the agreement which we reached? MS. BRICKER: Yes. MS. MALE: Do you accept the terms of this agreement as legally binding on you? MS. BRICKER: Yes. MS. MALE: Do you understand the terms of the agreement as we have outlined it here? MS. BRICKER: Yes. MS. MALE: And have we had an opportunity to discuss it prior to meeting today? MS. BRICKER: Yes. MS. MALE: Are you satisfied with the settlement as we've stated it on the record? MS. BRICKER: Yes. MS. YUNIS: Mr. Bricker, were you present here today to hear this property agreement? MR. BRICKER: Yes. . 1 MS. YUNIS: Do you understand the terms of the agreement? MR. BRICKER: Yes. MS. YUNIS: Do you agree with these terms? MR. BRICKER: Yes. MS. YUNIS: Did you discuss with me the various legal ramifications of the document? MR. BRICKER: Yes. MS. YUNIS: Are you satisfied with this agreement? MR. BRICKER: Yes. MS. MALE: Mr. ~icker, do you understand that the agreement is legally binding on both you and Carol as of today, regardless of whether you come back and sign the agreement later on? MR. BRICKER: Yes. MS. MALE: And, Carol, do you also understand that? MS. BRICKER: Yes. 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 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. WITNESS: ?fd~~!1; Attorney for Plaintiff DATE: ~\\\I~\~, j((96 00s. ~~~o.'. Carol S. Bricker . B~~~q;~ Attorney for Defendant , . JO - 9 ? ~ t.lJ~;?,,- Kenneth E. Bricker, Jr. ,. .' THERESA BARRE1T MALE COUN5I!LOR AT LAW 10SOUTH MARKET SQUARE SUITE 500 HARRI58URG,PA 17101 . . " . . Theresa Barrett Hale Supreme court #46439 10 South Market Square suite 500 Harrisburg, PA 17101 (717) 233-3220 Attorney For Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-1085 civil Term CAROL S. BRICKER, Plaintiff KENNETH E. BRICKER, JR., Defendant CIVIL ACTION - DIVORCE PRAECIPE TO TRANSMIT RECORD 1. Ground for divorce: irretrievable breakdown under section 201(c) [now 3301(c)] of the Divorce Code. 2. Date and manner of service of the Complaint: On March 12, 1994 by certified mail, return receipt requested per the affidavit of service filed of record. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by. section 3301(c) of the Divorce Code: by Plaintiff: March 30, 1995; by Defendant: March 30, 1995. (b) (1) Date of execution of Plaintiff's Affidavit required by section 3301(d) of the Divorce Code: N/A (2) Date of service of Plaintiff's Affidavit upon Defendant: N/A 4. agreement 30, 1995, Related claims pending: The parties entered into an and stipulation resolving the economic issues on March the transcript of which is filed of record. 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of .aid aotic. under .ection "Ol(dl(ll~ th.~vorc. Code, NtA / _/lzJdM.LZ( ~ Attorney 'For Plaintiff Ln en - ;,. or>- ." ,.. ..:.- Ult.. .! !;" ;,: ;. ~' .... I ~ - .! iE I.D I") C"") '. C, .1-- . .."I r-- ,'1. 1'-" ,: ;':'l\. t;t; a: "- """" . . " . ) . - -::r en -, "" " <;"-'"l~.t:e ~ ~0 'f) ~" \" ~~.~-./ -.....:... Zl. 'Cl c.v ." ,- .r.~ :z:- .... - 0- ,.1 ,~f ~ .';:f;,_; ~~ M ." N 0< - .~ ' ~.. .d~~ ~ ..... ---; <, ---~ ,.. .'- ~::B r- ," ..':..-'" ,. ~.-'- ... ... = IA.~ Q' -- ~ ~ ~ ~. '~~~'0 t- <-() t.o~ f1l ~ ~ < ~ .. III ~ ~ ~ ~ ol" Z Z ~ ~ ! ~ S ~ E ~ ~ p Z cI &i ~ ~ ~ u. . .. 0 rof f1l ~ Z ~ ~ ~ 0 Z :r. .I: ~ . o. t I ". , CAROL BRICKER Plainti f[ IN TilE COURT OP COMMON PLEAS OP CUMBERLAND COUNTY, PENNSYLVANIA vs. KENNETII E. BRICKER, JR, Defendant CIVIL ACTION - LAW NO. /OK'JCIVIL 1994 IN DIVORCE NOTtCR TO IIRIIRND AND CI.AIH RIGIITS You have been sued In court. II you wlnh to defend against the claims set forth in the foregoing pages, you muut take prompt action, You are warned that if you fail to do so, the case may proceod without you and a decree in divorce or annulment may be entered against you by the court. A Judgmont may also be entered against you for any lather claim or rolief re1luosted In those papors by the plaintiff. You may lose money or Iproperty or other rlghtu Important to you, Including custody or visitation of your IChildren, When the ground lor tho divorce In IndIgnities or irretrievable breakdown of the Imarriage, you may rOlluont marrlago counsoling, A list of marriage counselors is availablo in the OUlco 01 tho I'rothonotnry nt: , Ii , Oll Ico 01 tho Prothonotary Cumborland County Court 1I0use Carllslo, Pennsylvania 17013 IP YOU DO NOT IIll.E A CI.AtM ~'OR A1,IMONY, DIVISION OP PROPERTY, LAWYER'S PEES OR EXPENSES BEPORE A IIIVORCE OR ANNULMENT 19 GRANTED, YOU MAY L09E TilE RIGIIT TO CLAIM ANY I OF TIIEM, I I i YOU 9110ULD TAKE TII19 I'AI'ER TO YOUR I.AWYER AT ONCE. IF YOU DO NOT IIAVE A LAWYER OR i CANNOT AFFORD ONE, GO TO OR TELEPIIONE TilE OFPICE 9ET FORTII BELOW TO PIND OUT WHERE YOU i CAN GET LEGAL IIELP, i: Court Administrator, Pourth Ploor Cumborland County Court 1I0use Carlisle, Pennsylvania 17013 Tolophone: (717) 240-6200 . 1 , . . . CAROL BRICKBR Plaintiff IN THB COURT OF COMMON PLBAS OF CUMBBRLAND COUNTY, PBNNSYLVANIA vs. KBNNETH B. BRICKBR, JR. Defendant CIVIL ACTION - LAW NO. CIVIL 1994 IN DIVORCB NOTICB OF AVAILABILITY OF COUNSBLING TO THB WITHIN-NAMBD DBFBNDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code. you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office. 13 North Hanover Street, Carlisle. Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling I within twenty days of the date on which you receive this notice. Failure to do so will I constitute a waiver of your right to request counseling. 1 II II I' Ii I' ,I I: 2 , . CAROL BRICKER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW KENNETH E. BRICKER, JR. Defendant NO. CIVIL 1994 IN DIVORCE COHPLAINT IN DIVORCE UNDER 8ECTION 330l(c) OR 330l(d) OF THE DIVORCE CODE AND NOW comes the above-named Plaintiff, CAROL BRICKER, by her attorneys, Andes, Vaughn & Bangs, and makes the following Complaint in Divorce: 1. The Plaintiff is CAROL BRICKER, an adult individual who currently resides at 1106 Musket Lane, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is KENNETH E. BRICKER, JR., an adult individual who currently resides at 1333 Zimmerman Road, Carlisle, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Common- wealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 12 May 1990 in Mechanicsburg, 5. There have been no prior actions of divorce or annulment between the parties. 6. This marriage is irretrievably broken. 8. The Plaintiff requests this Court to enter a Decree of Divorce. 3 .' . , , WHBII.BPORB, Plaintiff requests this Court to enter a decree in divorce pursuant to the Divorce Code of Pennsylvania. I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are sUbject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). oS - .<j - '1"-/ Date 0.0 ~^"rn ./': CAROL BRICKER 4 .... ......;-..--., .' . Theresa Barrett Male Supreme Court 146439 10 South Market Square suite 500 Harrieburg, PA 17101 (717) 233-3220 Attorney For Plaintiff CAROL S. BRICKER, plaintiff . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-1085 Civil Term . . : v. . . . . KENNETH E. BRICKER, JR., Defendant . . CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSBHT 1. A Complaint in Divorce under section 3301(c) of the Divorce Code was filed on March 7, 1994. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made sUbject.,.to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities. Date: (\\c..\'i\~~, ?-.o\ IC\C\ () O,S2S, K \.,,~Q, '" Carol S. Bricker = ..... ~ :a:: ~,.. "'>-. ..c.... .... ::~ .... ...J~(<r: "'-t..:... - 0 . ... ~%(:"j.J ..... r:" ~J ,_._ "'.,. .f ...J...... ;~~~t ":;1 ~'-' <:> ~ - s: e- N o -:r '. .' . " Theresa Barrett Male Supreme Court 146439 10 South Market Square suite SOO Harrisburg, PA 17101 (717) 233-3220 Attorney For Plaintiff CAROL S. BRICKER, plaintiff . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-1085 Civil Term . . v. . . , , , KENNETH E. BRICKER, JR., Defendant . . CIVIL ACTION - DIVORCE - , I 1 1 AFFIDAVIT OF CONSENT , .1 I i I 1. A complaint in Divorce under section 3301(C) of the Divorce Code was filed on March 7, 1994. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4.- I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities. Date: J-:>t'-?~ ~ t. t)~.fA- Kenneth E. Bricker, Jr. ..... en - >-.. ,c to_ ""'1':'," ,,-~~::-.i:: t..~ ::.f'.(~' ~ i:,--)u" ".,T.... . .j.' .r "I' -. . ".-'- "~:ei...,; .1. X.;.... ~~l ~...) :z:: e- N <:> -::r = ~ 0:.: .... = '. " , . - ,. . .. 1 , ." & , .- . - CAROL BRICKER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW '<+-Ioas ~.:r~ NO."t"41To CIVIL 1994 IN DIVORCE KENNETH E, BRICKER, JR, Defendant AFFIDAVIT OF SERVICE BY CERTIFIED HAIL LOU ANN GRISSINGER, being duly sworn according to law, deposes and says as follovs: 1. That she is an employee of Andes, Vaughn & Bangs, attorneys for the Plaintiff herein, 2. That on March I 0, 1994, she delivered to the U. S. Postal Service in I , iiLemoyne, Pennsylvania, as certified mail (Receipt No. P274290732 ) return receipt Ii requested, addressed to the Defendant herein, a true and correct copy of the Complaint I! " liin Divorce filed in the above-captioned action duly endorsed with a Notice to Defend II I! and Claim Rights. il I! 3. Said return receipt card is attached hereto as Exhibit A Shoving a date of " Ii iidelivery to the Defendant of March 12, 1994. II !'II Lo~~d~~/~r(Sl I,svorn to and subscribed :: before me this 2.,.t day : of M"^c.~ ,1994. J , ; L~~ '. Notary Publ , Nolarla' Sool ! I LyrnKirdef~Countv ~'ExpilllsAug 17,1g/)G '. " . .' . :_",'rMt"~",",:,',..~".'r,,,,^~...,.,>_--~~Nl~';Y"~'~;::"""'"~~ ~ .~ ~~~ .1' ,_ ..~; ~ ~r(r"-.~7~ "k.:.JJ~:J;c~ r_f .u.lJ .r_ 1l:=ii~;~,;ii;~i;:J;~'!;f;~f~i~;,;ri,::~~ti~i~f~~~;t"",I rpg-.imi~5=~.r:~~';~~il~.ii \;~ t......,~>.-.;.:... . '.' --'.. .... '... " ""/""""""'0';'1' ;:>.Jt~;W!!lO:~ROcoIPtR__:'On""lI\IlIplocIboiaw""lnIcloi1umbo< .2;~ RnulC:tllli D~li~.ry}':' ;V . 1,-".,,\'.~',ThlR""". ..~WIll_..._.....nIcIoW..de_ond'...del .. 'C'. ..,' ..-'. - ",p' j'i I ll:i.:-:.... ,,". . . .... . . .' . , .' Con.ult oatm.ot., 'or' "-'.. 'y: E:~;'Ar1l~ Add,...ad to: . 48. Ar1lel. .'. ' ,,',"'/~1',",: ~1i ~i~~. BRICKER, JR. . 4;'S~~~2;:' 732'--.. ,.;.., '~?l;:~J\ \'1\.11 'i;;r''-i\'~v . o Rogl.t.,ad e. 0 '.n.urad .. '7;"" ll~e?ffftit;~e.e t;N ')' ~::::.l. &8 ~..... ,if. \ 1" ':efT . 1. D.t. of D.llv.ry. :>~; rl~...".;;.";;':' ~:lU!'.lo' .' '"l"1Jl ~. ".... 8. Add:.!'.." Add.... (OnlY If ,oqu~t~i~ " !~ '.- '. /I' . .nd ,..1. p.ldl '" :,.," I (!I, ,/, ". ~ ',' ',' I I::f:~~~~'..:ii~i~'~'~~' ~~~~~~1 ,.....".....-~.,,""'.;.,.,.,"<.,...;;,,:.) EXHIBIT "A" CAROL S. BRICKER, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VB. KENNETH E. BRICKER, JR., Defendant NO. 1085 CIVIL 1994 : IN DIVORCE STATUS SHEET DATE: ;-/ '- --. QM/ 4..JtV-' . ,,-.......{- }1lJ.tDlkb -:T,-f (i (u t( s ,-j . / '"" .~ A/ I \,)11(' f,( i .." :. 11/\ (; \i)\J:rJ t \ U I ,- '\., (': O. . "~l' ( t . . \ _ '.\ ; ~ . i . ". ". " -' . , , \ \ ).l\\ \ i" <lnJ C ' ! ,1 \ \J ,,' ...... "- -.' .-' ..--- ., " / ! . .". ') \J.; .~ """ '" OFFICE OF DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEAS 55 West Church Avenue Carnsle. PA. 17013 (717) 240.6535 West Shore 697.0371 Exl. 6535 E. Robert Elicker, II Divorce Masler Trecl Jo Black Office Manag8r/RBpo~er November 16, 1994 Theresa Barrett Male Attorney at Law 10 South Market Square suite 500 Harrisburg, PA 17101 Barbara J. Yunis Attorney at Law GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 RE: Carol S. Bricker vs. Kenneth E. Bricker, Jr. No. 94-1085 Civil Term In Divorce Dear Ms. Male and Ms. Yunis: By order of Court of President Judge Harold E. Sheely dated November 10, 1994, the full-time Master has been appointed in the above referenced divorce proceedings. A divorce complaint was filed on March 7, 1994, raising grounds for divorce of irretrievable breakdown of the marriage. On November 9, 1994, the Plaintiff filed a petition raising additional claims, namely, equitable distribution, alimony, alimony pendente lite, and counsel fees and expenses. I assume both parties are willing to sign affidavits of consent or, in the alternative, one of the parties will file an affidavit under section 3301(d) so that divorce grounds are not at issue. The motion for appointment of Master indicates that Barbara J. Yunis represents the Defendant; I request that Ms. Yunis enter an appearance on behalf of the Defendant if she is, in fact, going to be representing him. In accordance with P.R.C.P. 1920.33(b) I am directing each counsel to file a pre-trial statement on or before Friday, December 16, 1994. Upon receipt of the pre-trial statements I " ;, Ms. Male and Ms. Yunis, Attorneys at Law 16 November 1994 page 2 will immediately schedule a pre-hearing conference with counsel to discuss the issues and, if necessary, schedule a hearing. Very truly yours, E. Robert Elicker, II Divorce Master NOTE: Sanctions for failure to file the pre-trial statements are set forth in subdivision (c) and (d) of Rule 1920.33. THE ORIGINAL PRE-TRIAL STATEMENT SHOULD BE FILED IN THE MASTER'S OFFICE AND A COPY SENT DIRECTLY TO OPPOSING COUNSEL. ,..""-..-....,.....--> ,.-,....,._'*'."....-.... VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL AC~ION - LAW CAROL S. BRICKER, Plaintiff . . . . : NO. 1085 CIVIL 1994 KENNETH E. BRICKER, JR., Defendant . . : IN DIVORCE NOTICE OF PRE-HEARING CONFERENCE TO: Theresa Barrett Male , Counsel for Plaintiff Barbara J. Yunis , Counsel for Defendant A pre-hearing conference has been scheduled at the Office of the Divorce Master, 9 North Hanover street, carlisle, Pennsylvania, on the 17th day of February, 1995, at 9:30 a.m., at which time we will review the pre-trial statements previously filed by counsel, define issues, identify witnesses, explore the possibility of settlement and, if necessary, schedule a hearing. Very truly yours, Date of Notice: 12/16/94 E. Robert Elicker, II Divorce Master ~~ (=== Harold E. Sheely, Judge CARlL S. BRICKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 1085 CIVIL 1994 KENNETH E. BRICKER, JR., Defendant IN DIVORCE ORDER AND NOTICE SETTING HEARING To: Carol S. Bricker Theresa Barrett Male Kenneth E. Bricker, Jr. Barbara J. Yunis Plaintiff Counsel for Plaintiff Defendant , Counsel for Defendant You are directed to appear for a hearing to take testimony on the outstanding issues in the above captioned divorce proceedings at the Office of the Divorce Master, 9 North Hanover Street. Carlisle. Pennsylvania. on the 28th day of April , 1995. at 9:00 a.m.. at which place and time you will be given tne oppo:rtunity to present witnesses and exhibit~ in support of your case. By the Court. Date of Order and Notice: 2117 /95 By: Divorce Master 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 Fourth Floor, East Wing Cumberland County Courthouse Carlisle, PA 17013 Telephone (717) 240-6200 .... vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 1085 CIVIL 1994 CAROL S. BRICKER, Plaintiff KENNETH E. BRICKER, JR., Defendant IN DIVORCE RE: Pre-Hearing Conference Memorandum DATE: Friday, February 17, 1995 Present for the Plaintiff, Carol S. Bricker was attorney Theresa Barrett Male, and present for the Defendant, Kenneth E. Bricker, Jr., was attorney Barbara J. Yunis. The parties were married on May 12, 1990, and separated December 31, 1993. A divorce complaint was filed on March 7, 1994, raising grounds for divorce of irretrievable breakdown of the marriage. The complaint did not raise any economic issues. Counsel have indicated that they will have their clients sign and file affidavits of consent prior to the hearing to be scheduled so that the divorce can proceed under section 3301(c) of the Domestic Relations Code. On November 9, 1994, the Plaintiff wife filed a petition raising economic claims of equitable distribution, alimony, alimony pendente lite, and counsel fees and expenses. with respect to the alimony claim counsel for wife has indicated she may offer testimony regarding marital misconduct assuming that that claim proceeds. We have discussed whether or not under the circumstances of this case the Master would recommend alimony in any event. If counsel for either party wishes to raise the issue of marital misconduct in the testimony, counsel are requested to provide opposing counsel the names of witnesses that are going to testify on that issue at least ten (10) days prior to the hearing. The parties are the parents of two children, Lindsey, born April 22, 1980, and Katie, born April 17, 1991. Lindsey was adopted and Katie is the natural child of the parties. Both children are in the custody of wife and husband contributes child support for the children in the amount of $80.00 per week. Wife is a high school graduate with LPN training Alternative nursing on a "call" basis. Counsel for have specific information regarding her income; best recollection is that her client makes and works in wife did not however, her approximately $1,000.00 per month net. She is going to verify this information and provide opposing counsel with the earning statement of her client. Wife does not complain of any health problems although she had been taking Prozac for depression. Wife resides at 1106 Market Lane, Mechanicsburg, Pennsylvania, where she lives with her parents and the children. Wife is 40 years of age. Husband is 37 years of age and resides at 489 Rich Valley Road, Carlisle, Pennsylvania, with his parents. He left the marital residence on February 3, 1995, in anticipation that the property was sold and the buyers would be taking possession. The Master has been advised that there may be some problem with the current sale and counsel are going to inquire of the realtor and their clients as to the status of the sale of the property. Husband works at Eat 'N Park as a clean up person and makes approximately $396.00 net every two weeks. He is in physically good health but has some emotional problems in which he at one point was taking Lithium. Husband is a high school graduate. The parties own a property at 1333 Zimmerman Road, carlisle, Pennsylvania, which as previously noted was under contract to be sold. Husband lived in the property until just recently and the house, if the current sale does not go through, will continue on the market until it is sold. It is listed with ERA Garman Reality. The house has an approximate market value of $105,000.00 and a mortgage payoff of around $18,000.00. The major issue in this case involves the contribution of approximately $60,000.00 which husband made to purchase the house prior to the parties' marriage. The question is how we are going to deal with husband's pre-marital contribution. The parties purchased the property as tenants in common in 1988 and then married in May of 1990 wherein the ownership of the property converted to tenants by the entireties. The Master indicated that considering the short time between the pre-marital contribution and the date of separation he would consider the source of funds contributed by husband in arriving at a percentage of distribution of the marital assets. In March 1990, which was prior to the marriage, wife was in an automobile accident and the proceeds from that accident which were received after the marriage in the approximate amount of $6,800.00 were contributed by wife toward improvements on the real estate. She is claiming that she should be entitled to some consideration for her contribution of the pre-marital or nonmarital funds to the marital residence. Husband worked as a corrections officer at the '- Cumberland County Prison. It appears, according to records provided by his counsel, that he was a participant in an SERS pension as opposed to the Cumberland county Employees Pension. In any event, after the termination of his employment husband withdrew the pension value and the net amount paid to him was $3,988.18. The only marital vehicle involved in this case is a 1990 Ford Tempo which is subject to a lien which wife has been paying. The vehicle in his her possession. Counsel are going to talk to each other about how to arrive at a value, perhaps averaging the wholesale and retail values. The current book values should be consulted and then the balance of the loan taken off to arrive at the net equity value for marital purposes. The household tangible personal property is apparently not going to be an issue and we do not need to have any values for the purposes of equitable distribution; however, there is an issue as noted in wife's pre-trial statement regarding some children's items that are in dispute. If that remains an issue we will deal with that at the hearing. Hopefully counsel will be able to resolve the ownership or possession of those items. Husband claims that each of the parties has some items of the children's property and that this is the property that he would like to retain, wife having previously received other items. wife has an IRA which was owned by her prior to the marriage. Counsel need to determine the increase in value of the IRA from the date of marriage to the date of separation. The IRA has not been increased in value as a result of any contributions made by wife from the date of the separation. Husband received possession of a Meridian Bank checking account and savings account at the time of separation. The checking account had a value of $104.48 and the savings account had a value of $77.28. Various stock accounts are listed in the pre-trial statements showing ownership with a parent and a child. Counsel are agreeable to allow those accounts to remain as previously established for the benefit of the children without considering any values of those accounts for purposes of the equitable distribution computation. The parties had a dog and some equipment. At the time of the separation. Husband took possession of the dog and the equipment which had a value of $350.00. Counsel for husband has listed two life insurance policies on the pre-trial statement. Counsel need to determine if the policies have any marital value, ie, dividends or interest earned during the marriage which increase the cash value. Counsel for husband listed a MasterCard debt and counsel for wife says that the charges on that account were not related in any way to the marriage. Husband has made payments on that card and in order to pursue his claim that wife should make a contribution to the payment of that debt husband should produce records of what was purchased on that card prior to the separation to see if those purchases relate to the marriage. A hearing is scheduled for Friday, April 28, 1995, at 9:00 a.m. Notices will be sent to counsel and the parties. E. Robert Elicker, II Divorce Master cc: Theresa Barette Male Attorney for Plaintiff Barbara J. Yunis Attorney for Defendant CAROL S. BRICKER, Plaintiff . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : . . vs. . . No. 94-1085 CIVIL TERM . . KEHHETH E. BRICKER, JR., Defendant . . CIVIL ACTION - DIVORCE PRE-TRIAL STATBMBHT OP DEFENDANT. ltBHHETH B. BRICltBR. JR. Kenneth E. Bricker, Jr., the Defendant in the above- captioned matter, by and through his counsel of record, Barbara J. Yunis, Esquire, files the following Pre-Trial Statement pursuant to Pa.R.C.P. No. 1920.33 (b): I. LIST OF ASSETS: A. Marital Assets Number DescriDtion of PrODertv OwnershiD Value 1. Real estate 1332 Zimmerman Road carlisle, PA 17013 Joint $110,000.00 4. PNC Bank Account '51-3038-0921 Joint 4,700.00 Husband and 865.00 daughter, Lindsey Bricker Husband and 183.62 daughter, Katie Bricker Joint 104.48 3. 1990 Ford Tempo PNC Bank Account #51-3-38-092l 2. 5. Meridian Bank Account, checking #5091-8378 6. Meridian Bank Savings '82-55772l-05 Joint 77.28 7. State Employee's Retirement System Husband 3,988.18 Number DescriDtion of Pronertv OwnershiD yalue 8. IRA Wife Increased value since marriage 9. state Farm Life Wife Interest Life Insurance Policy dividends since marriage lO. Contents of Safe Joint unknown Deposit Box at PNC Bank Boiling Springs 11. Various stock approx. value a-e is 8,370.13 a. lOO shares Dauphin Deposit b. 100 shares Brooklyn Union Gas c. 100 shares Tri continental Corp. a-e are d. 106 shares Proctor & Gamble owned by e. 60 shares PSE 7 G Plaintiff and daughter, Lindsey f. 3 shares Proctor & Gamble unknown g. 105 shares PSE & G unknown f & g are owned by Defendant and daughter, Katie B. Non-Marital Assets Number DescriDtion of ProDertv OwnershiD Value 1. Life Insurance Policy Husband 814.42 The marital residence is listed for sale with ERA Garman Realty for One Hundred and Ten Thousand Dollars ($110,000.00). The mortgage was Twenty Thousand six Hundred sixty-three Dollars and Forty-one Cents ($20,663.41) on December 31, 1994. As of December 1, 1994, the mortgage is approximately Eighteen Thousand One Hundred Dollars ($1~,100.00). As noted, there are several items for which values still need to be secured. Additionally, there are numerous items, including the stock, which is in Plaintiff's possession. At the time of the pre-trial conference on this matter, the Master will need to delineate who is responsible for the securing of documentation to reflect the values of those assets. II. Excert witnesses: It is not anticipated that there will be expert witnesses necessary in these proceedings. However, while it is presumed that a stipulation can be reached as to the value of the vehicle and other personal property, both tangible and intangible, the Defendant reserves the right to call expert witnesses in the event the parties cannot stipulate to the values. III. witnesses: It is anticipated that the defendant obviously will testify on his own behalf relative to his case. Furthermore, Defendant reserves the right to call additional witnesses and to provide their identity at a later time. IV. Exhibits: Defendant's Inventory & Appraisement will be presented as an exhibit in this case. The Defendant will also present the following exhibits: a. PNC Bank statements for money market accounts effective November 30, 1993, attached as Exhibit "A": b. Wife's state Farm Life Insurance Policy, attached as Exhibit "B": c. Defendant's state Employee's Retirement System, attached as Exhibit "C", and d. Meridian Bank statements for checking and savings accounts and mortgage balance as of the date of separation, attached as Exhibit "D"; and e. Defendant's Income and Expense statement, attached as Exhibit "E". The exhibits referenced above are not intended to be exhaustive and additional exhibits may be necessary based upon information secured at the pre-Trial Conference in this action. V. Gross income: Defendant is currently employed at Eat 'n Park and he is earning approximately Five Hundred and Twenty Dollars ($520.00) gross per month. VI. Income & EXDenses: Defendant's Income and Expense statement is filed contemporaneously with the filing of the Pre-Trial statement and is self-explanatory. VII. Pension: Defendant received a lump sum payment on April 4, 1994, of Three Thousand Nine Hundred Eighty-eight Dollars and Eighteen Cents ($3,988.18) from the state Employee's Retirement system. This represented the total amount of his contribution during his employment with the state. VIII. Counsel Fees: The Plaintiff is asserting a claim for counsel fees, however, Defendant's income is severely limited and he does not have the wherewithal or financial ability to pay for his own attorneys fees. Only through making extremely minimal payments against attorneys fees and the commitment that Defendant will use his limited marital assets he receives from the Master's Hearing to pay for counsel fees, was he able to have adequate representation. Thus, Defendant maintains that both parties are on an even par in defending or asserting their rights. IX. Personal Pronertv: Defendant is not aware of any dispute as to the !tems of tangible personal property. X. Marital debts: The following is a list of the marital debts that the Defendant is aware of: 1. Mortgage on the jointly owned property; 2. Car loan for the 1990 Ford Tempo which is approximately $2,500.00; 3. MasterCard with Bank of Delaware which has a balance of approximately Eight Hundred Fifty Dollars ($850.00). Defendant is assuming the debt with MasterCard while Plaintiff has been assuming the car payment loan. Furthermore, Defendant's maintaining the marital residence which includes the payment of the mortgage and taxes. XI. ProDosed Resolution of Economic Issues: Defendant would suggest paying Plaintiff a lump sum of Twenty-five Thousand Dollars ($25,000.00) for Plaintiff's interest in the marital property. Plaintiff would relinquish all right, title and interest in the marital residence, as well as her interest in the parties' personal property, and husband's retirement benefits. Husband would assume sole responsibility for the repayment of the mortgage with Meridian Bank and indemnify Plaintiff and hold her harmless from any liability. Plaintiff shall retain the 1990 Ford Tempo and assume the repayment of the loan with Dauphin Deposit Bank. Defendant agrees to waive all right, title and interest in aforesaid vehicle. Defendant shall assume responsibility for the MasterCard debt with the Bank of Delaware. Furthermore, Defendant shall waive all right, title, and interest he may have in the various stocks acquired during the marriage, as well as any increase value in Plaintiff's IRA. The parties shall each retain the personal property in his or her possession. In addition, Defendant would propose each party be responsible for their own attorney's fees, and the costs be borne equally. Respectfully submitted, GRIFFIE & ASSOCIATES Attorneys for Defendant DATE: /Zjt5/91 BY (i.~.~#, ~~ Barbara /.1 . unis, squire 200 North Hanover Street Carlisle, PA l70l3 (717) 243-5551 vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 94-1085 CIVIL TERM CIVIL ACTION - DIVORCE CAROL S. BRICKER, plaintiff KENNETH E. BRICKER, JR., Defendant CBRTIPICATB OF SERVICB The undersigned hereby certifies that I did, this day of , 1994, cause a true and correct copy of the Pre-Tr!al Statement and a copy of the Inventory and Appraisement of Defendant, Kenneth E. BriCker, to be served upon the attorney for Plaintiff, Carol S. BriCker, of record by the United States mail, first class, postage pre-paid, to the following address: Theresa Male, Esquire 10 South Market square Harrisburg, PA 17101 d Barbara J. u s, Esquire Griffie & Associates 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 DATE: IZjl5/1t! ,... .'._'_..w iJN(J~AN n~ "'Hullu .'IIlI.all'\ Statement 177 LINDSEY E BRICKER KENNErH E BRICKER, JR 1333 ZIHHERHAN RD CARLISLE PA 17D13-924b 1."111."111,,,,"11,.11,1.1,,,,1.1,1,,1.11"1,"11 LAST PAGE STATEHENT HUHBER 51-505a-o.~a STHT END DATE 11-50-.5 ENCLOSURES PAGE o 1 PREMIUM MONEY MARKET LINDSEV E BRICKER KENNETH E aRICKER, JR ACCOUNT NUttBER TAK ID IM\IlER LAST STHT END DATE 51-.s038-0''''8 192-Ioo-na7 lo-Z....5 fOR CUSTDnER SERVICE CALL 17171 258-5211> BDILING SPRINGS OffICE ACCOUNT SUMMARY Will ~I NITHDRANALS/DEa~~: I. ~~ .21 . PREVIOUS BALANCE St.S.D' DEPOSITS/CREDITS 2.11 I~ DAILY ACTIVITY E.PLANATloN OF TRANSACTION YOUR PREVIOUS STATEHENT IALANCE INrEREST PAYHENT CHECKS AND OTHER DEBITS DEPOSITS AND OTHER CREDitS 2.11 BALANCE aU.09 al>5.20 ACCOUNT INFORMATION HIN DAILY BALANCE AVG COLLEcrED BAL CHECKS AND DEBITS aU.n 8b5.15 o INTEREST PAID TNIS PERIOD INTEREST PAID THIS YEAR Z.l1 31.13 THE ANNUAL PERCENTAGE YIELD EARNED IAPYEI IS' THE HUHIER Of DAYS IN THIS INTEREST PERIOD IS: THE AVERAGE DAILY IALANCE USED fOR THE APYE ISI THE INTEREST EARNED DURING THIS PERIOD IS: 2,a2 % 32 IU.15 2,11 flU '11',1"'1':'.. "." EXIIIBIT "AU PNCJBANK S'\lllhll'lIl1;11 P.\ Statcmcnt 177 KATIE E BRICKER KENNETH E BRICKER, JR 1333 ZIMMERMAN RD CARLISLE PA 17013-9~4b 1,"111,"111",,"11,,11,1,1",,1,',1,,1,11"1,"11 LAST PAGE STATENENT MUnBER 51-3031-0'21 S TNT END DATE 11-31-93 EHCLDSURES PAGE . 1 PREMIUM MONEY MARKET KATIE E BRJCKER kENNETH E BRICkER. JR ACCOUNT NUttBER TAX ID HlmIER LAST STNT END DATE ACCOUNT SUMMARY 51-3038-0921 193-72....&21 lO-2:-r.3 fOR CUST~ER SERVICE CALL 17171 251-321& BDILING SPRINGS OffICE DEPOSITS/(REDITS .~4 I~ PREVIOUS BALANCE 115.18 ~ ~I WITHDRAWALS/DEIITS .00 ~L~I ~:':'l'S..62 DAILY ACTIVITY 1 I!ill [' 10-29 " 11-5. EXPLANATION OF TRANSACTION YOUR PREVIOUS STATENEHT BALANCE IHTEREST PAVNENT CHECkS AND OTHER DEBITS DEPOSITS AND OTHER CREDtT!l ,44 .ALANCE las.18 las.&2 I I HIH DAlLY BALAHCE ! AVG COLLECTED IlL : CHECkS AHD DEBIIS ACCOUNT INFORMATION 185.11 113.1' . INTEREST PAID THIS PERIDD INTEREST PAID THIS YEAR .44 &.77 THE ANNUAL PERCEHTAGE VIELD EARHED IAPYEI IS. TIlE NUMBER Of DAYS IN THIS INTEREST PERIOD IS: THE AVERAGE DAILY BALAHCE USED fOR THE APYE IS: THE INTEREST EARHED DURING THIS PERIOD ISI 2.77 X 32 113.19 ,44 "tl 'w~'n' II.., 'I'.' J.J i'l t; lllA l~ ll~ SlIlIIllt 1'1111011 P-\ StalemClll KENNETH E BRICKER, JR CAROL S BRICKER 1333 ZIMMERMAN RD CARLISLE PA 17013-9246 1,,,111,,,111,,,,,,11,,11,1,1.,,,1,1,1,,1,11,,1,,,11 STATEMENT HUHDER 51-4044-0045 CHECKING t NNE R CK , ~ CAROL S ORICKER STMT END DATE 00-2/r-93 -it04'1-00'l 200-<l2-30Dl 00-06-93 CCOUN N MDER TAX 10 HUHBER LAST STHT END DATE ACCOUNT SUMMARY ~ 6Illll!llI 11,561.37 PREVIOUS BALANCE 4211.02 DEPOSITS/CREDITS 8,673.37 UllllIWI 7 DAILY ACTIVITY vm QD-06 08-10 EXPLANATION OF TRANSACTION YOUR PREVIOUS STATEMENT DALANCE CIIECK 735 REF' 21174067 CHECK 736 REF' 22219754 CIIECK 759 REF' 21177109 CHECK 7311 REF' 21172377 CflECK 737 REF' 22754753 OEPOSIT REF' 21331394 OEPOSIT REF' 21.B0734 CIIECK 740 REF' 21613353 CHECK 741 REF' 22527246 CHECKS ANO OTHER OEBITS 2.00 3.60 45,64 50.00 110.00 08-11 08-12 08-13 08-16 08-19 0,370.15 10.00 ACCOUNT INFORMATION MIN OAILY BALANCE AVG CYCLE BALANCE AVG COLLECTEO BAL PNC AIM OEBITS HON-PHC ATM DEBITS TELEPHONE TFR DEIIITS 246.78 POINT OF SALE DEBITS 2,352.73 2,352.17 o o o ~ur.~~,~ARY OF CHECKS-. C"ECK W!lIlli 735 736 737 DATE AIl!!1!IlI WI! 2.00 08-lD 3.60 08-10 lID.OO OB-ll CHECK Ul!IIW 73B 739 7'10 DATE !I1l!l!lII UlI! 50.00 OB-10 '15.64 08-10 0,370.13 08-16 . GAP IN YOUR-CIIECK-SEqUENCE YOU MAY WISH TO REqUEST ACCOUNT DISCLOSURES REqUIRED BY THE TRUTH IN SAVINGS ACT, CONTAINING TERMS, FEES AND RATE INFORMATION FOR YOUR ACCOUNT. CALL DR VISIT YOUR LOCAL BRANCH OFFICE. THE ENCLOSED PAMPHLET CONTAINS GENERAL INFORMATIOH ABOUT TRUTH IN SAVIHGS. I~'l .1"'" ..' '11.'. .. I' (- ,:-ct~'"'::t -, .) --- - 177 LAST PAGE ENCLOSURES PAGE 7 1 OR C STOM S V C CA L 17171 250-3216 BOILING SPRINGS OFFICE WITHDRAWALS/DEBITS ,00 NEll IIALANCE 540.02 OEPOSITS ANO OTHER CREDITS BALANCE '1211.02 0,370.13 303.24 326.70 246,78 0,616.91 11,920.15 598 . 02 540.02 o CHECK I!l!IlIWl 741 DATE !I1l!l!lII WI! 10.00 011-19 .. - '~'- - '.'- KENNETH E. SRICKER, JR. CAROl. S, BRICKER 1333 ZIMMERMAN ROAD CARLISLE. PA 17013 740 ~ 1:)/ .,13 !2:..!mn 1Il ::J.:-.:""U A e.f)._~ ~~ I Sl8'J70.iJ . ---c::r . ~ :..~--;-"k.;1t_~...g~.A~ !.tOol"" Ch:NU UUnk,NA _.. . _. .. ~_' :3'10 .:z.lflj,7 ./-/ ~..e./~",c~.1h- I:o:i l:i l2 7 :i81: 077 00 l"l 78 "II'''lo 7..0 ,"ooo08:i 70 l:il" _ __...."., '.~.'."'._" . ~Ol '.. ~ - - "..'~..i._.___ .., - -- r ~ I .\I.,...a'''''jl .', l',',) J".... ""', OAfl IS "tal "._,((;1(0 (Jill I...S ",)Iu:f . ONE .STATE FARK DRIVE ..,."'. CONCORDVILLE PA 19339-0001 .".so' APR. '19. 1993 POLICY I,OAH '\ll" III '''f'''...... '0" 1 2 WO..IHS 01".10("0 fO "lOUCI "'EulU" 142.50 NOTICE OF PAYMENT DUE DUE DAlE KAY 10, 1993 'A' IHIS ""OUN' $142.50 INSURING CAROL R BRICKER POLICY NUMBER LF-OB29-0956 POLICY INFORMATION $50,000 FIVE YEAR WPD DIVIDENDS PRIOR ACCUMULATION INTEREST ADDED AT 8.50' CURRENT DIVIDEND CURRENT ACCUMULATION POLlCV 0'" TE MAY 10, TERM 82.92 7.05 46.00 135.97" 1986 INSURANCE AMOUNT AS OF KAY FIVE YEAR TERM TOTAL INSURANCE 10, 1993 50,000.00 50,000.00 .. ANY ACCUMULATED DIVIDENDS WILL BE ADDED TO THE INSURANCE AMOUNT YOUR BENEFICIARY WILL RECEIVE OR TO YOUR TERMINATION VALUE. AGENT:DAVE KILLER AREA CODE:717 TELEPHONE:249-4251 211..'.1 ILOOO'" EXHIBIT "B" ~ ~, CHANGE OF BENEFICIARY ANDIOR SETTLEMENT SPECIFICATIONS A SEPARATE FORM IS REOUIRED FOR EACH INSURED PERSON WHOSE BENEFICIARY IS TO BE CHANGED. DO NOT SEND THE POLICY UNLESS REQUESTED. To: ~lale Farm Life Insuranc}j compa'1Y,{ 0 Slate Farm Life and Accident Assurance Re: Insured Person C..o.M--t: .f5;vl(:. ~ Policy No. {sl I request payment of any sum payable on the insured person's death be ma e s shown elow. Payment will be subject to any assignment. Any prior provisions for payment upon the insured person's death are revoked, when this request is recorded. For Additional Insured's or Children's rider, the rider's beneficiary provisions are revoked, and the polley's beneficiary provisions will control. "Additional Insured", "Insured Child", or "Annuitant", will be used in place of "Insured." COMPLETE SECTIONS FOR ALL BENEFICIARIES, EVEN IF UNCHAIIlGED, GIVING THE FULL NAME, AGE. ADORESS IIf different from the Insured'sl AND RELATIONSHIP TO THE INSURED PERSON FOR EACH, FOR CHILDREN AS A CLASS, NAME THOSE NOW LIVING. 8ENEFICIARIES I METHODS OF SETTLEMENT PRIMARY - Name, Age, Relationship, Address I' Check one: ti Interest Option 0 One Sum 0 Other-Explain: Taxpayer Identilication Number (II aVBilable) . \ f<2A1flC1.il f:...,,o.,;tyhv; ~3) l Yll..I.Eba.r\d . I I I SUCCESSOR-Name, Age, Relationship, ~yess I ( 'i'xpayer Identification~Um~(l1 avail'l9le :J~ I l"l.-) L0d E.. )yu. T Fa. e.5"~) &. ((,f/) \'TI:4d -fo. s: it e ~.I"! Method 01 settlement fo, Successor if no Primary survives Insured Person. Check one: l1Pnterest Option 0 One Sum 0 Oth~r-ExpIBln: FINAL- Name, Age, Relationship, Address Taxpayer Identification Number (II available) One Sum Settlement Only Unless changed by this request: If Primary Beneficiary survives the insured person, any payment due a Successor Beneficiary will be In one sum, Two or more surviving beneficiaries of a class will share equally. If children of a person are named as a class, only children born to or legally adopted by that person will be included as beneficiaries. Family Income Rider Benefits will be paid in monthly payments to the beneficiary with present value available in one sum. Any beneficiary to whom a "time clause" applies will be deemed not to have survived the insured person if that beneliciary is not living on the 30th day after insured person's death. Special Provisions: The Company will not be responsible for use of any sum payable by a trustee. Payment to a trustee will fully discharge all liability of the Company to the extent of such payment. If the trust Is not In force, or if qualifying conditions for trust under Will are not met, paymenr will be made to the succeeding beneficiary, if any. Qualifying Conditions for Trust under Will. The Will must be admitted to Probate within 180 days after Insured person's death, and trustee must qualify within 1 year after insured person's death. This change of beneficiary and/or settlement specifications will be effective when recorded by the Company. If the policy requires endorsement, recording and mailing a copy of this form (and endorsement form, if any) to me will constitute the endorsement. /..(22. 9-;1. Dated on c.;. - D".~ ?at Witness YI $'1"""'. I C,IV · SOl" !\'t I . lO' JJ . Policyowner 'r, I ~, 1\ . ~'I r ~I " - S,gn8IU'. FOR REGI NAL OFFICE USE.ONLy.,*-;~~.~r~'nii<:7~ ~hange ~I beneficiarY Recorded En'dorsed p~,i';:;;;;J,i;e~~~~~' o Change name . Recorded Endorsed 0 Policyholder ""\'\ f ... ../0 0 Agent .:....~o.:.. :. Ii" Policy not sent in . .... .0' 0 Otherwise' ~.. Reco ~y: A~. ~L. ! UI. a..~ _~ -se"Hl: AY Stat. farm LIf. Inlur.ne. Company Stltl F8rm L1fl Ind Accldlnt Assurlnce Complny Date ~, ~;7 . q ^ STATE FARM LIFE INSURANCE COMPANY 38-2841 OWNER'S SOCIAL SECURITY NO. 178-38-6114 USE REVERSE SIDE FOR CORRECTION OF SOCIAL SECURITY NO. ONE STATE FARK DRIVE CONCORDVILLE PA 19339-0001 04/02 RPU ANN CONTACT 'NSUN'Na CAROL R BRICKER .aL'CY NUMBER LF-0613-9470 1".111",111".",11"11,1,1",,1,1,1..1,11.,..11,,.11,...111 CAROL R BRICKER 1333 ZIKKERKAN ROAD CARLISLE PA 17013-9246 "-"'---\ 1 );~~~-., · 1,IIII,I,I,II,"I1,I.liri;mnOl,IL,II"",II,1 STATE FAR~ L'i?E-=:'. I ONE STATE IFARK'DRIVE CONCORDVILbS-P~~9339-2000 ! ; ..-r/~ ':: ;~'}.~':_ :!....iI'~;'it ~-.:._:~: ;';~~".~':''''':~m nUs POfmOII ,CiA .,0.. RICOI'D' .,.,- MT\IVI THil MO't'I.wmt Nlf 'AnuI'. . .l': . - '.:".}i;:t-.: ...::~~; ~:, ;. ;J'''~<~~':';' .;' - '.' '"::..: ",~,,,;.: 'to'. ~l:.. ;) tl'. . . : " ..... ~l.'.:;;~.. .'0 '. . :.. ..: '.. ~':: :~.'; ?' /..:' , :.:: . . .~:' ~;.~. ~;-., ! :.. AU AMOUNTI U"CT TO ~ICATIOII MO 'AYIIPT 0' PIlIIMIUIII TO ,.. DUI DATI l- . . .~ . .", TlWISAc:T1OlI AITIJI_" ".. . ONBc S'rA'rB.FARX' DRIVB .i....' '.' litIS DA"IS IIOT .... ,,." ". '-' .', ,.. ','. I CONCORDVILLE PA 19339-0001 .mEmD a. "'IS IlClTU APR. 2, 1993 ..' .... NO'rICE OF YOUR POLICY'S STATUS W YOU HAVI MOVIe. 'l1A1l CONTACT YOU" AG(NT SHOWN llELOW 0" llElE "IVI"S! 1101 INSUftING . ..... CAROL R BRICKER 'OLley NUMIIJt LF-0613-9470 'OLlCY OAn APR. 5, 1982 'OLley INfORMATION FLEXIBLE PREKIUK ANNUITY ,. .... . .'. A. . . ;~~fJ~: TOTAL VALUE OF CONTRACT AS OF APR. 5, 1992 $6,585.06 INTEREST EARNED ON THAT TOTAL VALUE AS OF APR. 5, 1993 341.69 TOTAL VALUE OF CONTRACT AS OF APR. 5, 1993 (1) 6,926.75 TO KAKE SURE YOUR RETIREKENT FUND IS THERE WHEN YOU NEED IT, CONTRIBUTIONS SHOULD BE KADE ON A REGULAR BASIS. THE INTEREST RATE FOR PAYKENTS RECEIVED IN OUR REGIONAL OFFICE DURING APRIL IS 4.30'. PRESENTLY, THE INTEREST RATE AND GUARANTEE PERIOD OF AT LEAST ONE YEAR ARE SET THE FIRST OF EACH KONTH AND APPLIED TO PAYKENTS RECEIVED THAT KONTH. TO TAKE ADVANTAGE OF THE CURRENT INTEREST RATE. SIKPLY. ATTACH. YOUR.,CHECK TO THE STUB POR!tlON_OF .THIS NOTICE AND RETURN IT TO OUR OFFICE. SEE CONTRACT FOR WITHDRAWAL CHARGE, IF ANY. COMMONWl!A1,TH OF ~5YLVANIA STATE EMPLOYES' RETIREMENT SYSTEM '.0. lOX nt7 IIAIlIUSluac. nNNSYtVANIA InOl-nt7 TEUlPHONlb n7.m-tUJ SERSoI96 .~ ~ ~ 4 L .:!., 1~?4 KENNETH E. E:HCl<EF. ~EM=ER SS# 2C5 42 30~1 1333 ZI~MERMAh R~AD CARl.! Sl..E ?A 1:'013 DEAR RECIPIENT: ENCLOSED IS A LUMP SUM PAYMENT IN THE AMOUNT OF 53,988.18 . THIS REPRESENTS A WITH~RAWAL OF'YOUR TOTAL CONTRI3UTIONS AND INTEREST LESS THE MANDATORY 20: WHICH IS WITHHELD FOR FEDERAL :NCO~E TAX ?UF.P~SES. IF Y~U ~ERE A MEA~E~ OF THE ilETi~!HE~T SYSTEM JEF~?E J~~UA~Y 1, 19;~, YO~P CONTRI:UTIO~S PillaR TC Th~T ~ATE ~E~E T~XED AS PART OF Y:Uil GlOSS I~CO~E AT THAT TI~E. T~!ilEFOiE, ~O T~XES A~E 5S:NG ~ITHhELC ON THAT PORTIJ~ OF YQU~ CJNTRISUT:~NS. HJ~EVE~, ~NY CJ~TiI~UTI:~S ~ACE ON ~R AFTi~ JA~UAiY 1, 1932, PLUS ~LL I~TEqEST CilSDITE~ TJ Y:U~ ACCOUNT, A~S F~~l..Y TAXA~LE F~~ FE)ERAL INCOME TAX PU,i'.:S!S. 7ri!S ?~Y~E~T HAS ~E~:( ~E?~~T~) TO T~E INTE;~~L ~~V~~UE S~~V::S. :F A 1J.,-~ FO~~ IS NOT E~CL:S!O ~!i~ iHIS L!TTE~, y~~ ~:LL ~EC~:V! CNE P~:J~ T' JA~U.~Y 31 JF ~j~~T y~:~, ~:T~ T~~ '1!:~S!l;Y I.~^ ~:,F-:~:';;"T:'J" R:~A;!O:\'~ !-:: :~Y'~:'~i. 1.:1:;= C~:.::\,-r i..:',., j"~:?.: .:..:: .: :;".~.:/L":'''':~ S7~T~:" L.;C.ll T.1X:~ ~'. ~'IY :.~"':r:7S :~::; ,. ,'\ oJ , 7;:,,; ~'fZ7:"'. 7h~~ L~TT~A A~~ T~~ 1:;O-~ FOR,~ T~Ar YOU ~!C~:V~, :H~~L'.. ~~?T ::; ~ Z'F~ FL'C~, ~S V:J hILL S!EJ TH~ :~F~?~~T:O~ ~H~'i F:L N~ t)~~ Fl~~~AL :~C:~~ T:~ ~:TU~~. TH:S:5 r~1 C~LV ~CT::~ y U ~!LL ~~~~:VI. T~!~~::; ;~.~~ C~~~i~ F:~ !~C~ F!:J!~T :F ;~FL C~i! :~I::~::":.\i:':'\. ;;:\:::~!LY, LINOA M. ~ILLER, DIRECTOR :ENEFIT DETE~MISAT!ON DIVISION G .. J . ....ldlen ...,. ,.. All ....11 .fE~!"'OR AI!'I!AI!N(I! ~, 1~8IW~,~~D .....L~k8MIt..o. --- - _l trl~- "I. .,..,.~.... .,.,.....,. ..- : ~.t.,..,. CHl!CICING I'I.AHlI Il'l\I IHH I'I.AHlI Cl!MI"IC"TI!I IleTJIlI!MI!NT IIlIIINGI IN!~JT IIC&:OUHTS 1~~'rijAro6D iml ~--------_.---.-.---------------. - 0.00 - 10...... - ~----------o:oo-!---------;;:ii-~ ~---------------.---------------~ - 0.00 - 0.00 - ~_._-------O:OO-!----------O:OO-~ ~---------------.--------------_. LIMI!I Of' CAl!DIT LOAN IICCOUNTI E~W DU~~ING :------------.0.1---------.0:00.: ~_._---------.--.--------------_. I"TI'lLLMI!NT LllAHI r,l~? DUi~~ING ~._-..--._-._.--I-.-------------. . Z,..OO,~~ ZO."3.'" - ~---------_. ~---.--------------_. , INRNCJI'lL PAOf'IU! ~~l, AC~~TI .TOTI'lL __ANCI!II ~---------------. - t.t.7'- .---------------. p---------------. . ZO.,,]..., - .---------______4 II'DATI! -----------------------------.------------------------------------------------------- ~VLl/ANli HAS IlDOPTI!D~IO All II Nl!N AREII CIIN! ,.011 IT' SDUTNl!lIlOTI!RN IlI!OUI"....I!l! LlJDINO PlIILA LPHIII COUNTY. THI ~"I!CTS ,lIME Nl!AIDIAH Lgo;AT 0Ifll. PLIAllI! ALL DlAECTOIlY AG; TANel! FOIl DETAIL'. .' H .. EXIIIBI'r "0" . H .. ;, ....rldlan '-'.'811 IMll I'lWlI! 2 I~~I~~,~W .'I.ICI _L~~8Mlt.OI -- --- .., ..~ .. u. ~iilnM"''''J . ....nt,.... .. _ ....... CMIC1CI.. to" -a1lI ----.......-----...--.----------. mlAa ILI~~mllT. 1..1 ~. a 1O"'r:Oi .3.J.. 13...... CMlCICS "'ID ---------- IU_U ~TI NCUIT - -.l!R DATI - tI:ll: It' if~!, AMOUNT : _IIIR DATI 'fl:'!: lIS 81~g~ . GAP I" II!lIUINCl NCUIT to.og ....0 In 1~1 ~ILV m. JIallCTlClMS ------------------ MYa fJl.UIICTIClN. i'I~n ~HI IIlLAHCe -i~-:~;1!i-Gi~iNO-~--------------------------------.!-------------!-------;:~:~~!--------~;I:ig- ,~_ ICS ..00 "'1.00 - 11'1.00- - II .10 I ~ . 11.00 . 12.00- - 10 'iI ,~~ 1_ IT - ~'I.'IZ- ?II. I.U 1- 20.00 . m'OO- - ,,,. o,~o,- I( 3110.00 .00' 311. Ol~or ICS ".1" '''.00 '10,00: 7,'..: '0.....11 01'1"- NO IflUltG 10.....8 ~I_ QIIJ J1{ ~.----------------------------------------------------------------------------------- 'T~flMlNT ~IHOa 1IZ-'I'I77Z1-G'I --------------------------------- TAlC lD IIIGI...IHG ~ ~ ~~r.eBU'TS INll:io KIM:a ~"R 01' DA* IN STATIMlNT PERIOD JJ lHT'PAID TH PERIOD 0.00 CURRENT INT ST RATI .~~."7' AVERAGI Cll'clll TED IlALANCI z.Z' ~D 'H ~1~ISbD _D 0 :r,' 2011'I23001 IU.72 eoo.H 113' , :sot 77.2t1 DAILY TMIlACTlClNI ------------------ . H1THDRAMALS DeposITS DATI r._ JIIIlCTIClN Deans CRED TS IIlLANCE -,2;i;f----NN-NG-~------------------------------.--!--.----------!-------------!--------"~:;-- I~~I! . - '100 ~. "n lie "..".NT TO IHIlTALL, LOAN ..200..201112- ..".". . . I~:n ,_ - - 300 00' "n 'Ii \' z- _' ' - ..".,,- ' - 7 :2t1 , r NlJ ...."..,1 . - . 7 .28 COtlTlHUED . . . I .. . ..... ... ....~ ~.;.,-......",.,,^ .,.c. ,..",~,.,' {Iiit:::'._. ,;?~~;. ii::'il-UoIliIG ML.JKI COMr I~D , . , I It . ... - --. . Meridian _..... IMII a:f1l. I.tmif" .III CIIt 81iilrwwt'':Y, . ~ I'fW;e :J I~If.f=t.."ir Al!'I!IlCNCI 1Ul1e1~k8MIt..o, r "100-0ta0' .. N.100.00 ~ OIlJlArI. ".=T. IO.MJ.'" ... ZJ '=l .."." JiTl 02"""'" ...." TI'III ID .,.." 20""00' l5iW' ~ " , -, ~'. " A~ J .. INCOME AND EXPENSE STATEMEN"r OF SSN 208 42 --. OR' CATE . - THIS STATEMENT MUST BE FILLED OUT KENNETH E. BRICKER, JR. 3001 . (If you are self-employed or If you are salaried by a business ot which you are owner In whole or In part, you must also "" out the Supplemental Income Statement which appears'on the last page ot this Income and Expense Statement.) INCOME (a) Wages/Salary Employer & Address Job Title/Description Pay Period (weekly, bl.weekly, monthly) Gross Pay per Pay Period .................................................................................................................... S 480.00 Eat 'N Park Restaurants. 1251 Harrisburq Pike. Carlisle. PA diswasher Payroll Deductions: Federal Withholding ..................$ Social Security ...........................$ Local Wage Tax ..........................$ State Income Tax .......................$ Relirement ..................................$ Health Insurance ........................$ Other (specify) .....;;,~.p.p.,~,':.!:......$ s tat e un e n:'.~.~.?X.~.:.?.;....$ .........................$ bi-weekly 27.40 36.71 4.S0 13.44 -0- -0- ISO.OO .72 216.93 Net Pay per Pay Period ......................................................................................................................., $ (b) Other Income InteresUOividends ......................$ Pension/Annuity .........................$ Social Security ...........................$ Rents/Royalties ..........................$ Expense Account .......................$ Gifts .............................................$ Unemployment Compensation .$ Workmen's Compensation .......,$ Total, Other Income .......................$ Week Month Year $ S $ S S S S S s s s s s s s s s s ,. _ INCOME AND EXPENSE STATEMENT OF 'J-~.......4"- t t)-wJ~ ~ I ve"fV Ihalthe slatemenlS made in this Income and Explnse Slat.. menl are true and cer'ect. I understand tnat 'alsl statements herein are made Subjecl to the Plnallles of 18 Pa.C.S. .90. relallng to unSWQrn falsi fica lion to authorities. Dlte: 1.:1-/). '1'/ PilI nUll or OellnOlnt EXIlIBIT "E" Household Week :.'. C:1Ud Week Housenold MontlT ClUd Montn EXPENSES Home MortgaglllRent' ., , .... Maintenance " Utilities (lelephone. heatl!'lg .ele~nc:.'tc:.l employment (transllortatlon.. luncnes, S $' . $ 419.67 $ $ .$ $ 101:50 $ $ $ $ 113.65 $ $ 11.33 S $ $ S 17.00 S S S S $ S S $ 80.00 S S S S S S S s s iaxes Real Estate._ P'!~onal Pre celt'( . Income._ Insurance Homeowne~ AutomOollll LHeJAc:::dent/Healll1 . Olher ... AutOmooile (payments. luel. recalt'S) __._._...__ s S $ -- s s s s s s s S $ S S S $ S S S S S $ S 90.00 S 90.00 s s s s Medical Ooc:or. Oentlst. Crtnodontlst '_'__ S Hosollal . ___ S Scec:al (glasses. oracas. atc.) .. $ . E~ucatlcn Pnvate. P:uoc:1ial 5coool College ...--:.._ P'!rsonal s .__ S c:otnlnc; .._.___..______ .S Feed ...._____._. . _' S Olner (houSenold SUCllUlIS. bartler,lItc.).____ C;edll ~ayments and loans Miscellaneous Housenold Mellllc:1i1d care "_'__ S entertainment (Inc:. Ilalle~. bOOKS. vacation. pay TV, etc.).._ S Gitts/C:"Iam3Cle contribution$. S Legal F'!es S Other Child suoPdrtiallmony payments ..__ .' Olher (scecify)_ s s 25.00 s S $ _ S S $ 60.00 S S s S 6.00 S S S S S $ 50.00 -- $ S $ S S S iotal E.~penses .__.. __ S S 884.15 S -_. . PROPERTY OWNED Checking Accounts ........ Description MeridiAn Bank Value S 300.00 S S S S S S S Ownership. H W J x --- ........ Savings Accounts ........... --- --- ........... Credit Union .................... --- .................... Stocks/Bonds ................,. .................. --- x Real Estate ...................... 13~' 7.;mm~rm~n Qn~A ".:a...1iale$1nc::.nnn no ...................... s s s s --- Other ................................ --- .............,...,.............. Total, Property..................... INSURANCE Company Policy No. Coverage' H W C Hospital........................... Medical............................ Health/Accident .............. Disability Income ............ Other (denIal, elc.) .......... ("H . Husband, W . Wife, J . Joint. C . Child) --- --- SUPPLEMENTAL INCOME STATEMENT A. This form must be filled out by a person who (check one): _ (1) operates a business or practices a profession; or _ (2) is a member of a partnership or joint venture; or _ (3) is a shareholder in and is salaried by a closed corporation or similar entity. B. Attach to this statement a copy of the following documents relating to the business, profession, partnersnip. joinl venture, corporation or similar entity. (1) the most recent Federal Income Tax Return, and (2) the most recent Profit and Loss Statement. C. Name and Address of business: Telephone Number D. Name and Address (If different than C) of accountant, con trailer or other person in charge of financial records: E. (1) Annual income from business ............................................................................................. S (2) How often is income received? ............................................................................................ S (3) Gross income per pay period ............................................................................................... S (4) Net income per pay period ................................................................................................... S (5) Specific deducllons If any .................................................................................................... S .... ~ g S l::~~ .c !ii>o~ '" a:'Cra .. !i!3:co ll' ~1~5Lg lJl " III W OQ)'" a:: Ill..... ~ 0.3 ~ t- .-tUJ:I: . . . . .i /,ll/S/4q ""[1_ ; CIVIL ACTION - DIVORCE Theresa Barrett Male Supreme Court 146439 10 South Market Square suite 500 Harrisburg, PA 17101 (717) 233-3220 Attorney For Plaintiff CAROL S. BRICKER, Plaintiff . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-1085 civil Term . . v. . . KENNETH E. BRICKER, JR., Defendant . . PRE-TRIAL STATEMENT OF CAROL S. BRICKER Background Information Date of Marriage: May 12, 1990 Date of separation: December 31, 1993 Number marriage: Third for Plaintiff; first for Defendant. Children: 4/17/91). Lindsey Bricker (DOB: 4/22/80) and Katie Bricker (DOB: Per agreed order, Wife has primary physical custody. Child/spousal support: Per court order dated May 18, 1994, Husband pays unallocated child and spousal support of $80 per week. Wife: Carol S. Bricker [DOB: 4/16/54; SS# 178-38-6114] resides at 1106 Musket Lane, Mechanicsburg, Cumberland county, Pennsylvania 17055 with her parents and the parties I children. LPN (pre- marriage). Employed on a "call" basis by Alternative Nursing. Husband: Kenneth E. Bricker, Jr. [DOB: 11/8/57; SS# 208-42-3001] resides at 1333 Zimmerman Road, Carlisle, Cumberland County, Pennsylvania 17013. High school graduate. Fired in 1993 from position as guard at Cumberland County Prison. Now employed at Eat 'N Park. Related Court Actions: Wife and husband are the plaintiff and defendant respectively in a protection from abuse/custody action docketed to Cumberland County No. 94-140-Civil Term. personalty: . 1990 Ford Tempo (J) . 1982 Subaru Brat (H) 3,875 575 . . Marital Assets Real Estate: Marital residence - 1333 zimmerman Road, Carlisle, PA . purchased: 1988 (JT) . Fair market value: $105,000 . Encumbrances: Mortgage balance: $21,000 . Net Equity: $84,000 pension/Retirement Benefits . Cumberland county Pension Distribution to Husband 4,500 Estimated Value of Marital Estate $92,950 Non-Marital Assets . IRA (W) (Pre-marital) . PSEG Custodian Acc't (Lindsey) . PSEG Custodian Ace' t. (Katie) . P & G custodian Acc't (Lindsey) . BU custodian Acc't (Lindsey) . Tri-Cont. custodian Acc't (Lindsey) . Dauph. Dep. Cust. Acc't (Lindsey) . Fidelity custodian Acc't (Katie) $7,234 66 shs 2.5 shs 97.4 shs 2.1 shs 110 shs 2.1 shs $1,100 Disputed Personal property Wife requests the following: . the children's toys (GAR) . other toys (BSMT) . Chest of drawers . Katie's toys (DR) . Katie's crib . 4 place-settings (SS) Marital Debts . Mortgage ($21,000) . orthodontic bill for Lindsey ($500) . Purchase of dog, equipment and vet bills ($350) Non-Marital Debts . Bank of Delaware Mastercard (H) 2 . N/A Property Transferred Experts . None identified as yet witnesses . Plaintiff . Dave Barr (Realtor) . will supplement if necessary Alimony, APL , Counsel Pees and Expenses Wife has raised claims for alimony, alimony pendente lite, counsel fees and expenses. Exhibits . statements in support of custodial accounts . Confirmation of wages for both parties . Wife's statement for counsel fees and expenses . others as may be determined after the pre-trial conference Proposed Resolution . Husband to pay to Wife the sum of $42,600 (50% of the total marital estate minus the value of Wife's car) . Wife will waive all claims for alimony, APL and counsel fees and expenses if the master awards her 50% of the marital estate . Husband to reimburse Wife $250 (50% of Lindsey's orthodontic bill) . Husband to pay to Wife $350 to reimburse Lindsey for the dog, equipment and vet bills . Husband to deliver to Wife the personalty identified under "Disputed Personal Property" ~, Date: December 14, 1994 ;; l UII .....4 u:-ct. Theresa Barrett Male, Esq Supreme Court # 46439 10 South Market Sq. - Suite 500 Harrisburg, Pennsylvania l7101 (717) 233-3220 Attorney For Plaintiff 3 ~. THERESA BARRETT MALE COUNSELOR AT LAW 10SOUTHMARKETSQUARE SUITESOO HARRISSURG,PA 17101 .,.. , THERI!lIA BARRETT MALE COUNSELOR AT LAW 10SOUTH MARKET!lQUARE SUITE 110O HARRlseURG,PA 17101 .: Nav 10 ,3 50 PH '9~ \)~ffCE '.\i ',. " '-~H'~:;TAJ,~ (!HiLi :;i..f.~l; i~(\UtnY P[fi Ii S', t_' /1,\,:. ":I" CT> - >-,.. "'.. "":z: ""~.:;! oi:~':r. ~::2~~ of'~~ ..~: . ~..'l '. .~ ..... ,;z: _.'. .tIJZ :" '~c:l~ ..';x ;:) ::;u = ..:: <0 '" == CT> >- -'S! - . . . . THERESA BARRETT MALE COUNSELOR AT LAw 10 SOUTH MARKET SQUARE · SUITE 500 HARRISBURG. PENNsvLVANIA 17101 (717) 233-3220 FAX (717) 233-6862 December l4, 1994 E. Robert Elicker, II, Esquire Office of Divorce Master 9 N. Hanover street carlisle, PA 17013 ReI Bricker v. Bricker (No. 94-1085) Dear Mr. Elicker: Enclosed is the original of plaintiff's pre-Trial statement for filing in the above-referenced divorce action. sincere y, 1: 'L,,,.,--.~-u-tt Yh~ 4heresa Barrett Male//l TBM/sca Enclosures cc: Barbara J. Yunis, Esquire (w/enc) Carol S. Bricker (w/enc) "::r >-... en - ..'!' ~. -j- - -1'-.. "':"-":" l,.,h:.:,:' t 1.1) N ,:~ ,~~::-)~; 0-. ~ ":...J Oa ~ .j~ oJ) - -.'. ~ ':t -" if. CT> ... ;.'.,~:; ~..~ ~ :- '" I C> ~C,,) ~ 1\ ~ -- - ::t ~ 'fl ... ~~ : ~ i~~ s: .. ... !3 ~o ~ <1.z5L5 fa g l1I'~ a: tn~'"' ~ 0'; ~ ... '''''Hfl:J: .. ..... . .. -. .' ,. Theresa Barrett Male supreme Court 146439 10 South Market Square suite 500 Harrisburg, PA 17101 (717) 233-3220 Attorney For Plaintiff CAROL S. BRICKER, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-1085 Civil Term v. . . KENNETH E. BRICKER, JR., Defendant . . CIVIL ACTION - DIVORCE PETITION RAISING ADDITIONAL ECONOMIC CLAIMS Pursuant to Pennsylvania Rule of Civil Procedure 1920.13(b), Plaintiff Carol S. Bricker, by her attorney Theresa Barrett Male, Esquire, raises the following economic claims in the above- captioned divorce action: EOUITABLE DISTRIBUTION 1. During the marriage, Plaintiff and Defendant have acquired various items of real and personal property. WHEREPORE, Plaintiff requests the Court to enter an Order equitably dividing all the marital property. ALIMONY 2. paragraph 1 is incorporated by reference. 3. Plaintiff lacks sufficient assets to provide for her reasonable needs and is unable to support herself fully through appropriate employment. , ~ ^~".,--~.- , . 4. Defendant has sufficient assets to provide continuing support for Plaintiff. WBBRBPORE, Plaintiff requests the Court to enter an order granting her alimony. ALIMONY PENDENTE LITE. COUNSEL PEES AND EXPENSES 5. Paragraph 1 is incorporated by reference. 6. Plaintiff lacks sufficient assets to provide for her reasonable needs and is unable to support herself fully through appropriate employment. 7. Defendant has sufficient assets to provide continuing support for Plaintiff. 8. plaintiff has retained counsel to pursue this action and has agreed to pay her attorney a reasonable fee. 9. Plaintiff lacks sufficient funds to meet the costs and expenses of pursuing this action, including counsel fees and the costs to retain experts to value the marital assets. 10. Defendant has sufficient assets to provide alimony pendente lite, counsel fees, costs and expenses for Plaintiff. WBBREPORE, Plaintiff requests the Court to enter an order: (a) awarding Plaintiff alimony pendente lite, interim counsel fees and expenses; and 2 " (b) thereafter awarding Plaintiff such additional alimony pendente lite, counsel fees and expenses as the Court deems just and appropriate. L~~ Theresa Barrett Male, Esquire supreme Court #46439 10 South Market Sq.- Suite 500 Harrisburg, pennsylvania l7101 (717) 233-3220 Attorney For Plaintiff Dated: November 1, 1994 3 r~-".~\~~. .~,".;'.:'''T'>:'~.:'-.. ,: .":. . .. ".,\,.:.:..:.', ;'-'. "':"":.;"<.- VERIFICATION I, Carol S. Bricker, state upon personal knowledge or information and belief that the averments set forth in the foregoing document are true. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsifica- tion to authorities. (1 "Q c:;" ~ 1 :. ~ , ~ Carol S. Bricker Date: \ \\ \ \Cf.I ! .. -'.."~ ASSETS OP PARTIES Kenneth E. Bricker, Jr., Defendant, marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. Real Property Motor Vehicles (X) 1- (X) 2. (X) 3. ( ) 4. (X) 5. (X) 6. (X) 7. ( ) 8. (X) 9. ( ) 10. ( ) 11. ( ) l2. ( ) 13. ( ) 14. ( ) l5. stocks, Bonds, Securities, and Options Certificates of Deposit Checking Accounts, Cash Savings Accounts, Money Market and savings Certificates Contents of Safe Deposit Boxes Trusts Life Insurance Policies (indicate face value, cash surrender value and current beneficiaries) Annunities Gifts Inheritances Patents, Copyrights, Inventions, Royalties Personal Property Outside the Home Businesses (list all owners, including percentage of ownership and officer/director, positions held by a party with company ( ) 16. Employment termination benefits-severance pay, workers' compensation claim/award ( ) 17. Profit Sharing Plans ( ) 18. Pension Plans (indicate employee contribution and date plan vests) (X) 19. Retirement Plans, Individual Retirement Accounts ( ) 20. ( ) 21. ( ) 22. ( ) 23. (X) 24. ( ) 25. ( ) 26. Disability Payments Litigation Claims (matured and unmatured) Military/V.A. Benefits Educational Benefits Debts due, including loans, mortgages held Household furnishings and personality (include as a total category and attach itemized list if distribution of such assets is in dispute) other (Cemetary Plots) LIABILITIES OP PARTIES Kenneth E. Bricker, Jr., Defendant, marks on the list below those items applicable to the case at bar and itemizes the liabilities on the following pages. SECURED (X) 1. Mortgages ( ) 2. Judgments ( ) 3. Liens ( ) 4. Other Secured Liabilities UNSECURED (X) 5. Credit Card Balances ( ) 6. Purchases (X) 7. Loan Payments ( ) 8. Notes Payable ( ) 9. Other Unsecured Liabilities (College Loans for Children) CONTINGENT OR DEFERRED ( ) 10. Contract or Agreements ( ) 11. Promissory Notes ( ) 12. Lawsuits ( ) 13. Options ( ) 14. Taxes ( ) 15. Other Contingent or Deferred Liabilities MARITAL PROPERTY Kenneth E. Bricker, Jr., Defendant, lists all marital property in which either or both spouses have a legal or equitable interest, individually or with any other person, as of the date that this action Item Number Description of ProDertv l. Real Estate l332 zimmerman Road Carlisle, PA 17013 1990 Ford Tempo 2. 3 . stocks a. lOO shares Dauphin Deposit b. 100 shares Brooklyn Union Gas c. 100 shares Tri-continental Corp d. 106 shares Proctor & Gamble e. 60 shares PsE & G f. 3 shares Proctor & Gamble g. 105 shares PsE & G 5. Meridian Bank Checking was commenced: Names of All OWners Joint Joint wife & daughter, Lindsey wife, & daughter, Lindsey wife & daughter, Lindsey wife, & daughter, Lindsey wife, & daughter, Lindsey husband & daughter, Katie husband & daughter, Katie Joint Date of Acauisition 11/30/88 on or about May 8, 1990 August 1993 August 1993 August 1993 August 1993 August 1993 April 1993 April 1993 March 1990 .............-.......-;,.....,..,- Item Description of Names of Date of Number ProDertv All Owners Acauisition 6. a. PNC Bank Account husband & June 1991 1I51-3-38-092l daughter, Lindsey b. PNC Bank Account husband & June 1992 II 5l-3038-092l daughter, Katie c. Meridian Bank savings Joint March 1990 i/82-55772l-05 7. Contents of Safe Deposit Box unknown Joint January 1991 9. state Farm Life Life Insurance Policy Wife Prior to marriage (Interest dividends since date of marriage) (began working) Sept. l, 1990 State Employee's Retirement system Husband 19. a. IRA Wife Prior to marriage 24. b. State Employee's Retirement System a. Mortgage with Meridian Bank Dillsburg, PA b. Car loan with Dauphin Deposit c. MasterCard with Bank of Delaware Husband (began working) Sept. l, 1990 Joint Nov. 30, 1988 Joint May 8, 1990 Joint Sept. l, 1990 MARITAL PROPERTY (continued) Cost or Value Cost or Value Item As of Date of As of Date of 30 Days prior Number Acauisition secaration To Hearina l. $89,900.00 $110,000.00 $110,000.00 2. approximately 4,700.00 4,700.00 $lO,OOO.OO 3. a-e approximately unknown 8,300.00 f & g unknown unknown 5. n/a lO4.48 n/a 6. a. n/a S65.00 unknown b. n/a l83.62 unknown c. n/a 77.28 unknown 7. unknown unknown unknown 9. unknown unknown unknown 19. a. unknown unknown unknown b. n/a 3,988.18 n/a 24. a. $30,000.00 20,663.41 l8,100.00 b. approximately approximately $10,000.00 $2,500.00 unknown c. n/a l,300.00 850.00 MARITAL PROPERTY (continued) Item Non-Marital Amount of Nature of Holder Number Portion Anv Lien Anv Lien of Lien l. Pre- $60,000.00 $18,100.00 1st mortgage Meridian marital Bank, Dillsburg 2. None approximately loan Dauphin $2,500.00 Deposit 3. None N/A N/A N/A 5. None N/A N/A N/A 6. None N/A N/A N/A 7. None N/A N/A N/A 9. (a. ) None N/A N/A N/A 19. (a.) Increase N/A N/A N/A in value (b. ) None N/A N/A N/A 24. (a. ) $60,000.00 $l8,100.00 first Meridian mortgage Bank Dillsburg (b. ) None 2,500.00 loan Dauphin Deposit (c. ) None 850.00 credit Master card Card Bank of Delaware Item Number Description of Pronertv Names of All OWners Date of Acauisition NOH-MARITAL PROPERTY Kenneth E. Bricker, Jr., Defendant, lists all property in which a spouse has a legal or equitable interest, which is claimed to be excluded from marital property: NONE Item Number Cost or Value As of Date of Acauisition Cost or Value As of Date of Acauisition 30 Days Prior To Hearina NOH-MARITAL PROPERTY (continued) Kenneth E. Bricker, Jr., Defendant, lists all property in which a spouse has a legal or equitable interest, which is claimed to be excluded from marital property: NONE NON-MARITAL PROPERTY (continued) Item Number Amount of Anv Lien Nature of Arw Lien Effective Date of Lien Basis for Exclusion From Marital Pronertv NONE " f'," PROPERTY TRANSPERRBD Kenneth E. Bricker, Jr., Defendant, lists all property in which either or both spouses had a legal or equitable interest, individually or with any other person, and which has been transferred within the preceding three years. Item Number Description of ProDertv Names of All Owners Costs or Value Date of Acauisition NONE r.:..-"'-: l. (a.) Description of Liabilitv Mortgage Car loan LIABILITIES Names of All Creditors/Debitors Date Liability Was Incurred Item NUmber 2. Meridian Bank Dauphin Deposit Nov. 30, 1988 May 8, 1990 various 24. MasterCard charqe Bank of Delaware LIABILITIES (oontinued) Amount of Liability Date Item on Date Incurred & Balance Periodic Pmt. Number Action Was Commenced Is Due and Amount l. $21,000.00 Ongoing 4l9.67 month (date of separation) 2. 2,500.00 ongoing 209.31 month 24. MasterCard with Bank ongoing 60.00 month of Delaware CAROL S. BRICKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 94-1085 CIVIL TERM CIVIL ACTION - DIVORCE vs. KENNETH E. BRICKER, JR., Defendant BNTRY OP APPBARANCB TO: LAWRENCE E. WELKER, Prothonotary December 5, 1994 Kindly enter my appearance as attorney for Defendant, Kenneth E. Bricker, Jr., in the above-captioned action. ~ L-L ' Barbara J. Y i, Esquire GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA l70l3 (717) 243-5551 -::r en - - ::-;? ,a M ::2 , -'- ..'1. ~_ .~ ~,=, '-> U-J ..' = , . CAROL S. BRICKER, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 1085 CIVIL 1994 . . . . vs. . . KENNETH E. BRICKER, JR., : Defendant IN DIVORCE . . THE MASTER: Today is Thursday, March 30, 1995 Present for a conference scheduled this date are the parties, Carol S. Bricker and Kenneth E. Bricker, Jr. Present on behalf of Carol S. Bricker is her counsel Theresa Barrett Male and present for Kenneth E. Bricker, Jr. is Barbara J. Yunis. A divorce complaint was filed on March 7, 1994, raising grounds for divorce of irretrievable breakdown of the marriage. The complaint did not raise any economic issues. The wife, however, subsequent to the filing of the complaint, on November 9, 1994, filed a petition raising economic claims of equitable distribution, alimony, alimony pendente lite, and counsel fees and expenses. The parties were married on May 12, 1990, and separated December 31, 1993. Prior to the marriage of the parties, the parties did live together since August of 1988. Following the pre-hearing conference held on February 17, 1995, counsel have engaged in negotiations with respect to the outstanding issues and have obtained necessary data to continue the process of negotiations. The Master has been advised that the case has been resolved with respect to the outstanding economic claims and counsel are going to place the agreement on the record in the presence of the parties. The agreement, as placed on the record, will be considered the substantive agreement of the parties and not subject to any modifications except for correction of typographical errors which may be made in the transcription. Therefore, what we place on the record today except for typographical corrections will be the substantive agreement of the parties, not subject to modification. We are going to have the agreement transcribed today and ask the parties and counsel to return to review the draft for any errors that may have been made in the transcription; after those errors have been corrected, if any, the parties will affix their signatures along with counsel in affirmation of the agreement that was previously entered on the record. The Master will then prepare an order vacating his appointment in the proceedings. The Master will also file with the order the affidavits of consent of the parties which have been signed and dated March 30, 1995, so that the divorce can be concluded under Section 3301(C). Ms. Male. MS. MALE: 1. The parties previously owned improved real estate situate at 1333 Zimmerman Road, Carlisle, Cumberland County, pennsylvania. The property was sold to Edwin Z. Horst, Jr. and Lydia J. Horst, with the settlement date of March 24, 1995. Proceeds from the sale have been held in escrow by the settlement agent, Mike Hanft, Esquire. The proceeds total $78,936.33. The parties have agreed to distribute those proceeds as follows: 60% to husband for a total of $47,361.80 and 40% to wife for a total of $31,574.53. 2. With respect to personal property, all tangible personal property in husband's possession will be his sole property without claim or offset by the wife with the exception of the following items: Television, television stand, lights, dishes, glasses, two vacuum cleaners, one dresser, a dress, patio furniture, ironing board, bassinet, jackets and coats, Christmas ornaments, and other miscellaneous items. Those enumerated items are awarded to wife and wife acknowledges that she has received those items prior to today's settlement. All tangible property in wife's possession will remain wife's sole and separate without claim or offset by husband. 3. In terms of intangible personal property, the parties have acquired during the marriage stock, most of which is held by wife in custody for the children, Lindsey and Katie. Husband holds some stock in a custodial account for Katie. The parties have agreed to maintain those accounts solely for the use of the children's education, support and maintenance. The parties agree that husband and wife shall be able to utilize in their sole discretion the funds which each currently holds in accounts for the children. 4. With respect to debts and liabilities husband will satisfy the MasterCard balance and will not seek any reimbursement from wife toward that bill. He will reimburse wife $250.00 towards Lindsey's orthodontic bill and $350.00 towards Lindsey's expenditures related to a family pet. The parties acknowledge that approximately $700.00 of the MasterCard balance was charged for repairs to wife's vehicle; therefore, there will be no exchange of monies between the parties. In other words, the $250.00 and $350.00, which husband otherwise would have paid to wife is essentially being applied to the $700.00 charge for repairs to her car. 5. Wife will retain possession of the 1990 Tempo and husband has agreed to execute the title to the car today. 6. Wife has agreed to contribute 50% toward household expenses while the house was being marketed for sale. The parties, through counsel, have reviewed the charges incident to that and have agreed that wife's contribution is $328.70. In order to contribute that amount wife has agreed to credit the arrears on husband's child support order, which is docketed to Cumberland county, No. 27 of 1994 DRO No. 22,217 in that amount of money. 7. Neither party will pursue any additional economic claims and wife specifically withdraws her claims for alimony, alimony pendente lite, and counsel fees. 8. with the exception of the marital debts and liabilities previously discussed, there are no other debts or obligations incurred during the marriage for which the parties are responsible. They are, however, responsible for any liabilities incurred in their own names since their separation date. 9. Previously, during the pre-hearing conference with the Master, counsel had discussed a possible issue as to cash or surrender value of life insurance policies. Both parties are satisfied that there are no life insurance policies with any cash or surrender value acquired during the marriage or otherwise subject to distribution. 10. Husband had received a withdrawal from his SERS pension in the sum of $3,988.18. Wife waives any and all claims with respect to those monies. 11. Wife has an IRA which she acquired prior to the marriage. There has been no value placed on the IRA prior to this settlement agreement but husband expressly waives any claims which he may have had to the increase in value of the IRA if indeed any increase had occurred. 12. At the time of separation husband received approximately $104.48 in a Meridian Bank checking account and a savings account balance of $77.28. Wife waives any claims to those monies. 13. 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 rights 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, dower, curtesy, 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 interests, rights, and claims. MS. MALE: Ms. Bricker, have you been present while I've described the terms of the agreement which we reached? MS. BRICKER: Yes. MS. MALE: Do you accept the terms of this agreement as legally binding on you? MS. BRICKER: Yes. MS. MALE: Do you understand the terms of the agreement as we have outlined it here? MS. BRICKER: Yes. MS. MALE: And have we had an opportunity to discuss it prior to meeting today? MS. BRICKER: Yes. MS. MALE: Are you satisfied with the settlement as we've stated it on the record? MS. BRICKER: Yes. MS. YUNIS: Mr. Bricker, were you present here today to hear this property agreement? MR. BRICKER: Yes. MS. YUNIS: Do you understand the terms of the agreement? MR. BRICKER: Yes. MS. YUNIS: Do you agree with these terms? MR. BRICKER: Yes. MS. YUNIS: Did you discuss with me the various legal ramifications of the document? MR. BRICKER: Yes. MS. YUNIS: Are you satisfied with this agreement? MR. BRICKER: Yes. MS. MALE: Mr. Bricker, do you understand that the agreement is legally binding on both you and Carol as of today, regardless of whether you come back and sign the agreement later on? MR. BRICKER: Yes. MS. MALE: And, carol, do you also understand that? MS. SRICKER: Yes. 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 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. WITNESS: ~~f;uu- Theresa Barrett Male Attorney for Plaintiff DATE: B/3'/1.r (~,(,s\~ ~ ,'~ Q. /, I I carolS. Br cker , ~ll3~~ Kenneth E. Bricker, Jr. '3.JP-'})- CAROL s. BRICKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 1085 CIVIL 1994 KENNETH E. BRICKER, JR., Defendant . . . . : IN DIVORCE ORDER OF COURT "-, ) vC' AND NOW, this ~') '---- day of rn'\LlA/\~1995, the parties and counsel having entered into an agreement and stipulation resolving the economic issues on March 30, 1995, the date set for a conference with counsel and the parties, 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, 1- ,((~;I ~ CL-<-,v _.~ I~ arold E. Sheely, P.J. cc: Theresa Barrett Male Attorney for Plaintiff Barbara J. Yunis Attorney for Defendant ~ ~Lk&. 3/~llljS. .;, 0>. )!' '.' 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