HomeMy WebLinkAbout94-01778
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THE LAW OFFICES OF PATRICK F. LAUER, JR.
2108 MABKET STREET, AZTEC BUILDING
CAMP HILL, PENNSYLVANIA 17011
(717) 768-1800 FAX (717) 7~7
1.800-822+LAW
ll32 N. B--d B~
HarriIIburr. PA 17102
(n7) 282-7747
~--u.t~ CouIIlIel
v.ttbew J, F...-....". ElIq,
8 B. IJaDovao B~
CarIiIIe, PA 17018
(717) 24lHlII71
(BePb' to Camp BDl~)
August 31, 1998
Cumberland County Courthouse
Attn: The Honorable Kevin Hess
One Courthouse Square
Carlisle, PA 17013
Re: Hempt vs. Hempt
Docket No.: 1778 Civil 1994
Dear Judge Hess:
You may recall that a custody hearing had been scheduled for August
18, 1998. Counsel in this matter had asked that you continue the
hearing generally pending an attempted resolution to be worked out
with mediation with Dr. Stanley Schneider.
The Hempts have met with Dr. Schneider on the August 26. Dr.
Schneider feels that they have made some progress towards reaching
a stipulation. He asked that they return on September 15, 1998 to
continue the mediation process.
On behalf of Attorney Cognetti and myself, I ask that you hold off
on taking any action in the matter for now to allow Dr. Schneider
to complete the mediation process.
In the meantime, if you have any questions or concerns, please do
not hesitate to contact either Attorney Cognetti or myself.
Sincerely yours,
-r}1(/itIIlU4[bA/;l;;u,~ 1J1,,,ji&
Matthew ~Eshelman, Esq.
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cc: file
Maria Cognetti
Michael Hempt
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MICHAEL A. HEMPT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
CONNEE L. HEMPT,
Defendant 94-1778 CIVIL TERM
IN RE: CUSTODY AGREEMENT
ORDER OF COURT
AND NOW, this 17th day of April, 1998, upon
agreement of the parties, it is hereby ordered and directed as
follows:
1. This Court's prior orders dated December 6th,
1997, and November 12th, 1997, are vacated.
2. The father, Michael A. Hempt, and the mother,
Connee L. Hempt, shall continue to enjoy shared legal custody of
Corrine D. Hempt, born February 22, 1982, Julie L, Hempt, born
May 25, 1984, Erin M, Hempt and Michael A, Hempt, Jr., (twins)
born August 28, 1986. The parties each are specifically
permitted to access the records of any medical care provider to
these children.
3, The mother shall have primary physical
custody of the children.
4. Toward the end of summer of 1998, the parties
shall submit the twins for a custody evaluation to be performed
by Stanley Schneider, Ph.D., who was selected by mutual
agreement of the parties. The purpose of the evaluation shall
be to assess the advisability of a transfer of primary custody
and to assess what course of action may be in the best interest
of the children.
The focus of the evaluation shall be on the
children, with the parties participating only to the extent
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required by the evaluator. The parties shall cooperate with
each other and the evaluator in scheduling the children for
evaluation sessions. The parties shall share all costs of the
evaluation equally. Costs of calling Dr. Schneider to testify
in the event a hearing becomes necessary shall be born by the
party calling him,
5. The father shall continue to have custody of
the children during three weekends per month from Friday at 5:00
p.m, until Saturday at 5:00 p.m, The specific dates for weekend
custody shall be arranged by the parties with the father
providing reasonable notice as to when he desires to schedule
weekend periods of custody,
Commencing with the 13th day of June, 1998, the
father shall enjoy periods of partial custody with Michael from
Saturday at 5:00 p,m, through Saturday at 5:00 p.m. and
alternating every other week thereafter. Commencing the 13th
day of June, 1998, the father shall enjoy periods of custody and
visitation with Erin Hempt from Saturday at 5:00 p.m. through
Saturday at 5:00 p.m, and every fourth week thereafter. The
three daughters shall enjoy periods of custody and partial
visitation with father from Thursday at 5:00 p.m. through
Saturday at 5:00 p,m, during each week that Michael is in the
care and custody of his father,
It is the intent of the parties that through the
summer months that the weekend visitation schedule be changed
such that all four children are together each weekend in an
alternating basis such that wherever Michael is spending his
period of visitation, the remaining children are also.
6. The holidays of Memorial Day, 4th of July,
and Labor Day shall be alternated between the parties. Holidays
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shall be defined as beginning at 9:00 a.m. and ending at 9:00
p.m. the end of the holiday, Even numbered years mother shall
have Memorial Day and Labor Day and father shall have the 4th of
July. In odd numbered years father shall have Memorial Day and
Labor Day, and mother shall have the 4th of July.
With regard to the Easter holiday, mother shall
be entitled to the Easter Holiday and the accompanying spring
break. With regard to Thanksgiving, mother shall have
Thanksgiving day until 3:00 p.m, Father shall have Thanksgiving
day from 3:00 p.m. until 9:00 p,m. If the weekend following the
holiday is father's, then he shall keep the children until the
conclusion of his weekend,
With regard to the Christmas holiday, on even
numbered years father shall have Christmas Eve from 5:00 p.m.
until 10:00 p,m., and Christmas day from 3:00 p.m, until 10:00
p.m. In odd numbered years father shall have Christmas Eve from
5:00 p,m. until Christmas day at noon. Mother shall have the
balance of the Christmas holiday.
7, During exchanges of custody, the parties
receiving custody shall remain in his or her residence, and the
party transporting the children shall remain in his or her car,
8. In the event the parties are unable to
resolve the outstanding custody issues by agreement at or near
the completion of the custody evaluation, a hearing in this
matter is scheduled before the Court for Friday, August 14,
,1998, commencing at 10:30 a,m. in Courtroom Number 4 of the
Cumberland County Courthouse.
9. This order is entered pursuant to an
agreement of the parties reached in open court. The parties may
modify the provisions of this order by mutual agreement. In the
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absence of mutual agreement, the terms of this order shall
control.
By the Court,
Matthew Eshelman, Esquire
2108 Market Street
Aztec Building
Camp Hill, PA 17011
For Plaintiff
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K7A. Hess, J.
Maria P. Cognetti, Esquire
P.O, Box 689
Harrisburg, PA 17108-0689
For the Defendant
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Dr. Stanley Schneider
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THE LAW OFFICES OF PATRICK F. LAUER, dB.
2108 MARKET BTREET, AZTEC BUILDING
CAMP HILL, PENNSYLVANIA 17011
(717) 763-1800 FAX (717) 7113-4247
l-lIOIH122+LAW
9S2 N, R-nnil Street
HarrIaburg. PA 17102
(717) 282-7747
~---:.tA Ccnm8el
Matthew J, F....."'nuo", Eaq,
8 S. Haoover Street
CIIrUaIe, PA 17018
(717) 24H971
(BepIy to Camp Hill Address)
August 13, 1998
Bon. Kevin A. Bess
Cumberland County Courthouse
Carlisle, PA 17013
(fax) 240-6462
Re: Michael Bempt vs. Connee Bempt
Custody Bearing Friday 8/14 10:30arn
Dear Judge Bess:
You may recall our phone conference of Wednesday afternoon where
Attorney Cognetti and I indicated my client's desire for a full
custody evaluation.
Please accept this correspondence with the attached, proposed
order, as a stipulation of the parties to reschedule conditionally
the hearing currently scheduled for Friday morning. The proposed
order addresses the conditions necessary for our clients to agree
to rescheduling the hearing.
Please reschedule the hearing
convenience. In the meantime,
concerns, please do not hesitate
for your earliest possible
if you have any questions or
to contact me.
Sinara' Y~f
Hatthn> J "h~aq.
and
ole f~r rl..,'ft,('a!G o/I!
Maria P. Cognetti, Esq.
MJElpl
Enclosure
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MICHAEL A. HEMPT,
Petitioner
I IN THE COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I No. 1778 - CIVIL - 1994
I
I CIVIL ACTION - AT LAW
I CUSTODY
VS.
CONNEE L. HEMPT,
Respondent
ORDER
day of
AND NOW, this
1998, upon
representation of counsel of the parties that the following Order
is in the best interest of the children in the above-captioned
matter, this Court's Order of April 17, 1998, shall continue in
effect subject to the following modifications:
1. Father's period of annual-vacation visitation shall run
from Saturday, August 15, 1998, at 5:00 p.m. until Saturday,
August 22, 1998, at 5:00 p.m., at which time the school-year
visitation schedule shall resume. The sUDUller-vacation visitation
schedule set forth in the Order of April 17, 1998, shall resume
each year on the first Saturday following the end of school.
2. During the school-year, the father shall also have
custody of Michael A. Hempt, Jr., on those weekends during which
the father already is regularly scheduled to have the other
children for the additional period of Thursday at 3: 00 p.m
through Friday at 5:00 p.m.
3. The parties agree to give serious consideration to the
expressed desires of the children concerning periods of
visitation and custody set forth by this Court.
4. While Mother feels that another custody evaluation is
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not in the best interests of the children; however, Father, at
his sole expense, may have an additional custody evaluation
performed. This evaluation may include all four children.
5. The hearing on this matter currently scheduled for
August 14, 199B, at 10:30 a.m., is rescheduled for the
day of
199B, at
o'clock ____.m. in
Courtroom Number Four of the Cumberland County Courthouse,
Carlisle, Pennsylvania.
BY THE COURT:
Hon. Kevin A. Hess, J.
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11108 MARKE'I' t1'I'RE1'T, A?'J'EC mID.DING
CAMP 1llLL, PENN::lYloVANlA 17011
(717) 76.1.lllOO ~'AX (717) 7G3-42~ 7
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C1tfoply to (;11I111> lIiII Aililn,vl)
August 13, 1998
Hon, Kevin A. Hess
Cumberland County Courthouse
Carlialc, VA 17013
(fax) 240-6462
Re: Michac1 Hempl. VII, COlllll.e Hempt
CUlltody Henring Friday 0/14 IO:lOnm
Dear Judge HeuD:
You may recall our phone cou"f",,,",,,, of Wl!dr",..di'Y "ttr.ornoon wlwr"
Attorney Cognetl.i and I 1,"..1 i <:,,1..,,1 lilY "I i ,'"1,' II c1""iI'c for a filii
custody evaluation.
Plcaue accept thilJ corrclJp"ll<h~r":l! wi l.h t.he at.t.:1ched, prel,,,,,,,,,1
order, as u ntipul.,tion nf t.II" IMlli."" 1.0 1",;c:I",c1I1I,~ condition,Jlly
tilt! lIearing currently tlchudllll!d lor Frid.:1Y mOrn,L1H). TIll! propnned
order addrefl9cs the condiLinnn nn~nao.:1ry for UUI cl il!lItn I.n ngrc:c:
to rcscheduling tbe hearing.
Pleaoe reschedule the h~uri nq for Y'.)ur
convenience, In the mf~c.llll.iltu,~, i I you h....vt~
concer.ns, pleane do not ho"ilalv 1.0 (:Olll..,..,t, mc,
Cull i !'!HI. po/wible
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MICHAEL A. Il~MPT,
Pol:iti<:'ln"r
IN THE COURT OF COMMON rLEAS Of
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CON NEE L. H~MI~,
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ANU NOW, I.hill _, ,
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repreucntal.ion of counool <>1 Lho pOlrt.ieo that the fo1lowiu<j Otder'
is in tho best. intorollL lIf tho c:hildlCHI in 1.1", nhovl;'-captiulwd
m"ttcr, th18 COllrcl.'.. 01'der of April 1'/, 1990, IIh..11 C:OIlI.iIlIlO ill
effect subject to the followllI<jlllOc!if;c:lIl.ionn:
1, l-'athor'u pnrind nf ,'''''"..11-vc.l(;C\lj'.HI vit.dl.dliol1 Hh;t11 fUfI
from Saturday, ^lIqllnt 1~, 199U, "l ~:oo (1,'", IIl1l.i I ""turd,,}',
^U9ust; 22, 1998, ;11. C,:ClCl l",lll" "L wlLl.d, lLIII,. Lh" ~<:huul-y"...,
vioitation ochl.ldulc: :shull rnllllmo. "h" numm"r v"c"t,inn vinit"t.;,-,n
schedule Get forth in thc Orde:r of ^pri I ) '/, 1990, nhllll TIllllIlll"
each year on thc f irul. S..,1.11 ('(f;I'o' 101 low i III) t.h.1 ,,"rl of :)ch~lI)l,
2, During thn lIc:hool'y";lC, t,h,' {e,ther 9hal1 also huvc
custody or Michael ^. Ih:mpL, J1'., on those: w....kc!/Idn dllr'i'\CJ whi"h
the father already ill rcgularly schcdul ed l,o hil\'!! t.h" "t.h'H'
children for the .."hlit.;o/l,,1 period of 'I'hll,,,d,,y Ill, 1:1l1l p,,"
throllgh Friday at. 5:0Cl p,m,
3. Thn pnrLios aql'fH~ t.o I)ive serious cnn:;id'HatiCl/l 1,0 LIII,'
expressed clnuiro9 of l.he chi Jdrnn I:OIIC:"1l1in<) pcriodH or
visltal.Lon and clIlll.ody set fOIt.h hy Lhi9 Court.
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4. WhiJA Mothur f('l'l$ th.lt anol.h"r' "u"tody evollllll,ion in
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not in the bout intercBts of the child~on; howlIvor, FathHr, at
hly 8010 oxpanllu, may lIi1v" olI1 ,l(hlit.ion,oI ...'ulIl.OI'ly ..v..lul.I.I'~n
performod. Thiu cvalulIl.ion "h'Y ill"lull,' ..II IOllr ,,1I1lu11III,
5. 'l'he hOllring on I.hi.(1 moltl.t!I' e:lIl-l't;olllly ...:II",lul...u rllr
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August 14,1998, at. 10:30/1,11I.,1:3 rCllclwdule,d tOI 1.11"
day o!
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MICHAEL A. HEMP!', . IN THE COURT OF cn-lMON PLEAS OF
.
plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. . NO. 94-1778 CIVIL TERM
.
.
.
CONNEE L. HEMP!' , . CIVIL ACTION - LAW
.
Defendant . IN CUSTODY
.
QU)BR OP OOURT
AND toi, this " ~
consideration of the attached
and directed as follows:
<'lay of ']>c.u..It-- , 1996, upon
custody COnciliation Report, it is ordered
1. This Court's prior order dated February 7, 1995 and paragraph
2 of this Court's Order elated December 19, 1994 are vacated.
2. The Father, Michael A. Hempt, and the Mother, COMee L.
Heapt, shall continue to enjoy shared legal custody of COrinne D. Henpt,
born February 22, 1982, Julie L. Hempt, born May 25, 1984, Erin M. Hempt
and Michael A. Hempt, Jr., (twins) born August 28, 1986.
3. The Mother shall have primary physical custody of the
Children.
4. The parties shall submit the Children for a custody
evaluation to be performed by Stanley Schneider, PhD who was selected by
mutual agreement of the parties. The purpose of the evaluation shall be to
determine the Children's feelings and attitudes with respect to both the
current custody arrangement and a potential shared custody arrangement.
The focus of the evaluation shall be on the Children, with the parties
participating only to the extent required by the evaluator. The parties
shall cooperate with each other and the evaluator in scheduling the
Children for evaluation sessions. The parties shall share all costs of the
evaluation equally.
5. The Father shall have custody of the Children during three
weekends per month from Friday at 5:00 p.m. until Saturday at 5:00 p.m.
The specific dates for weekend custody shall be arranged by the parties
with the Father providing reasonable notice as to when he desires to
schedule weekend periods of custody.
6. During the Christmas holiday in 1996, the Father shall have
custody of the Children on Christmas Eve from 3:00 p.m. until 10:00 p.m and
on Christmas Day from 3:00 p.m. until Decl!llber 26 at 3:00 p.m., if the
Father is not required to work on Decellber 26. If the Father does work on
Decl!llber 26, the parties shall make arrangements for return of custody to
the Mother on Christmas night. The Mother shall have custody of the
Children from Christmas Eve at 10:00 p.m. until Christmas Day at 3:00 p.m.
".
7. During exchanges of custody, the party receiving custody
shall remain in his or her residence and the party transporting the
Children shall remain in his or her car.
8. In the event the parties are unable to resolve the
outstanding custody issues by agreement at or near canp1etion of the
custody evaluation, counsel for the parties may contact the Conciliator to
schedule an additional Conference.
9. This order is entered pursuant to an agreement of the parties
at a CUStody Conciliation Conference. The parties may modify the
provisions of this Order by mutual agreement. In the absence of mutual
agreement, the terms of this Order shall control.
BY THE CXXJRT,
L
cc: Matthew J. Eshelman, Esquire - Co el for Petitioner/Father
Maria P. Cognetti, Esquire - Counsel for Respondent/Mother
".
MICHAEL A. HEMPT, . IN THE COURT OF CXXolMON PLEAS OF
.
Plaintiff . CUMBERLAND CClllNTY, PENNSYLVANIA
.
.
.
VS. . NO. 94-1778 CIVIL TERM
.
.
.
CONNEE L. HEMP!' , . CIVIL ACTION - LAW
.
Defendant . IN CUSTODY
.
PRI<R JUDGB: Kevin A. Hess
QJSTOOY aH:ILIATICIf SlMIARY RBl'CRr
IN AOCX:tUlllNCB Wl'l'IJ cnmBRLAND CXXN1'Y RlJLB OP CIVIL PRe) 'l<IaJRB
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. 'llte pertinent information concerning the Children who are the
subjects of this litigation is as follows:
RAMS
BIRTBDATE
aJRRPBl'Ly IN QJSTOOY OP
Corinne D. Hempt
Julie L. Hempt
Michael A. Hempt, Jr.
Erin M. Henpt
February 22, 1982
May 25, 1984
August 28, 1986
August 28, 1986
Respondent/Mother
Respondent/Mother
Respondent/Mother
Respondent/Mother
2. A Conciliation Conference was held on Decenber 3, 1996, with the
following individuals in attendance: the Father, Michael A. Hempt, with
his counsel, Matthew Eshelman, Esquire, and the Mother, Connee L. Hempt,
with her counsel, Maria P. Cognetti, Esquire.
3. 'llte parties agree to entry of an Order in the form as attached.
~
Date
'I. /9r&
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Dawn S. Sunday, Esqu re
Custody Conciliator
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MICHAEL A. HEMPT,
Plaintiff
IN THE COURT OF c:cM1ON PLEAS OF
: CUMBERLAND CClUNTY, PENNSYLVANIA
.
.
:
vs.
: NO. 94-1778
CIVIL TERM
.
.
CONNEE L. HEMPT,
Defendant
: CIVIL ACTION - LAW
IN CUS'roDY
.
.
aIDER OFaxJRT
AND tol, this /~ rA day of VJ1VII..vr~ , 1997,
upon consideration of the attached CUstody Conciliation Report, it is
ordered and directed as follows:
1. A Hearing is scheduled in Cou}:'t Room # ~ ' of the
CUrN:lerland County Court House on the ---.L TC"} day of i jJ. ,
1998, at q: 3 0 o'clock, Co\, .m., at Which time testimony w 11 be taken in
this case. At the Hearing, the Father, Michael A. Hempt, shall be
deemed to be the moving party and shall proceed initially with testimony.
Counsel for the parties shall file with the Court and opposing counsel a
Memorandum setting forth each party's position on custody, a list of
witnesses who will be called to testify at the Hearing, and a summary of
the anticipated testimony of each witness. These Memoranda shall be filed
at least ten (10) days prior to the Hearing date.
2. Pending further Order of Court or agreement of the parties,
this Court's prior Order dated December 3, 1996 shall remain in effect.
BY THE COURT,
J.
cc:
Matthew J. Eshelman, Esquire - Counsel for Father
Maria P. Cognetti, Esquire - Counsel for Father -
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MICHAEL A. HEMPT,
Plaintiff
: IN THE COURT OF <:aolMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs.
: NO. 94-1778
CIVIL TERM
.
.
CDNNEE L. HEMPT,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
PRIOO JUDGB: Kevin A. lfess
ClJS'l'OOY CXH:ILIATION &J!MARY REPCRr
IN ACalUl/\NCB WITH ClJlIBERLAND ClCDll'Y RULE OF CIVIL ~'O<I tlR8
1915.3-8, the undersigned CUstody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the
subjects of this litigation is as follows:
twlB
Dl\TE OF BIRTH
alRRENl'LY IN CIJS'OODY OF
Corinne D. Hempt
Julie L. Hempt
Michael A. Hempt, Jr.
Erin M. Hempt
February 22, 1982
May 25, 1984
August 28, 1986
August 28, 1986
Defendant/Mother
Defendant/Mother
Defendant/Mother
Defendant/Mother
2. An extended Conciliation Conference was held in this matter on
August 6, 1997 during which the parties were able to work out most aspects
of an ongoing custody schedule. After two hours in Conference, it was
agreed that counsel for the parties would continue to negotiate the
remaining aspects of a CUstody Order. The Conciliator held the matter open
pending further negotiations by the parties and counsel and no proposed
Order was submitted illlllediately following the Conference. Subsequently,
the Father's counsel advised the Conciliator that the parties had a
fundamental disagreement as to how much discretion should be afforded the
Children in establishing custody arrangements, and requested that a Hearing
be scheduled. As the Mother and her counsel were willing to attempt a
further conciliation, an additional Conference was scheduled and was held
on November 3, 1997, with the following individuals in attendance: The
Father, Michael A. Hempt, with his counsel, Matthew Eshelman, Esquire and
the Mother, Connee L. Hempt, with her counsel, Maria Cognetti, Esquire.
3. The parties were not able to reach an agreement at the Conference
and it will be necessary to schedule a Hearing.
4. The Father's position on custody is as follows: The Father does
not seek a specific schedule to replace the existing custody arrangement
whereby he has custody of the Children on three out of four weekends.
,'.
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However, the Father feels that it should be up to the Children as to when
and how often they spend time with the Father and the Mother. The Father
preferred not to have specified weekday periods of custody and instead
sought to have an arrangement whereby the schedule would be flexible to
allow the Children to spend time with the Father when they wanted. The
Father proposed that the custody arrangement be designated as "shared
physical custody". Finally, the Father proposed that the parties' son
would reside with the Father and attend school in the Father's school
district beginning with the 1998/1999 school year based upon the Father's
belief that it is the Child's preference to do so.
5. The Mother's position on custody is as follows: The Mother does
not believe it would be in the Children's best interests to place them in
the position of having to decide when and how often to spend time with each
parent. The Mother believes that such an arrangement would place too great
a responsibility on the Children, would force them to choose between their
parents, and would further exacerbate the problems the parties already have
in COIIIl1Ill1icating with each other in making arrangements. The Mother feels
that, due to the parties' inability to cOlllDunicate, the custody
arrangements should be specific and predictable. The Mother does not
believe it would in their son's best interest to change either his primary
custody arrangement or his school enrollment.
6. The parties' main custody dispute involves the issue of how much
discretion should be afforded to the Children, at ages 11, 13 and 15, in
establishing ongoing custody arrangements.
7. The Conciliator recOlllllends an Order in the form as attached
scheduling this matter for Hearing.
).JO'fem ht/
Date
if, /997
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CUstody Conciliator
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DECREE IN
DIVORCE
AND NOW, ..~..?:~.. ,... 19 .9,~ ,.. ,
it is ordered and
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decreed that ..C:l?~~~~, !",~t-!~:.., .. .... .. ,.. .., .. ,........,...., plaintiff,
and, !,gC;:I;l!-,F;I;o, 1\,-, ,1j~~,~1'""""",."""""""" ,."",'. defendant,
are divorced from the bonds of matrimony.
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The court retains jurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet
been entered;
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PROPERTY 9ETTI,EMENT AGREEMENT
THIS AGREEHENT, made this '23~day of ~~I ,199"g1 is by and
between:
HICHAEL A. HEHPT, of 505 Third Street, New Cumberland.
Pennsylvania, party of the first part, hereinafter referred to as
"Husband": and
CONNEE L. HEHPT, of 3790 Mountain View Road, Mechanicsburg.
Pennsylvania, party of the second part, Ilereinafter referred to as
"Wife."
WITNESSETH:
WHEREAS, the parties hereto are husband and wife, having been
married on 22 July 1978 and are the parents of four minor children:
Corinne D, Hempt, born 22 February 1982, ,Julie L. Hempt, born 25 May
1984, Erin ~lichelle Hempt and Mil:hael A. Hempt, Jr., both born 28 August
1986 (hereinafter referred to as "children"); and
WHEREAS, certain diffil:ulties have arisen bet.ween the parties
hereto which have made them desirous of living separate ilnd apart from
one another and Wife has initiated an action in divorce against Husband
to No. 94-1778 Civil Term before the Court of Cm~wn Pleas of Cumberland
County, Pennsylvania; and
WHEREAS, t.he part.ies hereto, Wife heing l'('II\'eSlmled by Maria P.
Cognetti, Esquil'e, i1llCl Hlwhand by Samuel [" Andes, Esquire, have each
exchanged full and complete informatioll as to the property, assets, and
liabilities owned and owed by each and have disclosed to each other and
Ito their respective attorneys full information as to the financial
Istatus of hoth part. iUIl hen,to: ali<I
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WlIERBA8, the parties hereto have mutuillly enlllred Int.o an agreement.
for t.he division of their aBsots, t.he provisIon fur the liabilities they
owe, and provision for the resolut.lon of their mutual differences, after
both parties have had fuil and ample opportunity to consult with their
respective attorneys, and the parties now wish to have that agreement
reducad to writing.
NOW, TlIBRBFORE, the partiea hereto, in consideration of the above
recitals, the mutually made and to he kept promiaes set forth
hereinafter, and for ot.her good and valuable considerations, and
intending to be legally bound and to legally bind their heirs,
successors, assigns, and personal representatives, do hereby covenant,
promise, and agree as follows:
1. This agreement shall not. make any disposition of the parties'
claims regarding custody of or support for their minor children, both of
which are the subject of orders entered in other lit.igation pending
between the parties.
2. The parties acknowledge t.hat they are cmrrently purchasing that
property situate at and known and nnmbered as 3790 Mountain View Road,
MechanIcsburg, Pennsylvania, pursuant. to an agreement of sale with Mr.
and Mrs, William Raudahaugh and that there is a balance owed on that
obligation in excess of $30,000.00. Wife agr(leS that she shall, within
ninety (90) days of the date of thia agreement, obtain financing from a
hank or mortgage company in an amount sufficient to pay the balance owed
to the Radabaughs in full and 1.0 pay t.he slim of money to Huaband as
provided in Paragraph 3 hOI"eof and, upon Wife's completion of aueh
refinancing, so that. t.he Ralldaballghs are paid in full and Husband is
roleased from any fut't.hel' ohligation to them, and the payment t.o lIullband
of the aum lH'ovided In P1u'1IlJt'aph 3 hereof. lIusbllnd shall make, execule
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and deliver to Wife or her attorney his deed to grant and convey all of
his right, ti tle, and interest ill and to Lhe pl'operty to WHe. Wife
represents to Hunband that she hall made a I 1 payments due to Mr. and Ml'S.
Raudabaugh on the salell agreemellt obliyation and promises that she will
make all further payments due until Blwh time as the remaining balance
ill satisfied in accordalll:e with this paragraph ann Wife further agrees
that she will indemnify and save harmless Husband from any loss, cost,
or expense caused to him by her failure to make such payments strictly
in accordance with the agl'eement with the Raudabaughs until such time as
that debt Ls [laid and satisfled in full and Husband is relieved from any
further liability therefor,
3. Wife shall pay to Husband, as equitable distribution of the
parties' marital property, the sum of Forty-Two Thousand ($42,000.00)
Dollars. Wife will make such payment contemporaneously with the
delivery of the deed to the property at 3790 Mountain View Road as
contemplated by Paragraph 2 hereinabove.
4, Husband does hereby grant, convey, transfer, assign, and
deliver and set-over unto Wife the following assets, which said assets
shall be and remain the sole and separate property of Wife hereafter,
free of any clalm by or interest of Husband, regardless of whether such
assets were deemed by either of the parties to be marital property or
non-marital property before:
A. Wife's interest in her account within the
Pennsylvania Blue Cross VIP Plan.
B. Wife's account or benefits within the Pennsylvania
Blue Shield profit-sharing, pension, retirement, or similar
tax-deferred benefit plan,
C. The 1991 custom Chevrolet van currently in Wife's
possession. Husband will execute the title to the vehicle
upon request.
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D. The 1980 Chevrolet Suburban automobile currently
titled in both parties' names. Husband will execute and
deliver the title to the vehicle to Wife as soon as she
presents the title to him for execution.
And further, Husband does hereby waive, release, relinquish, and
surrender forever any and all claim to or interest in said assets, which
shall be and remain the sole and separate property of Wife hereafter.
5. Wife does hereby grant, convey, transfer, assign, and deliver
and set-over unto Husband the following assets, which said assets shall
be and remain the sole and separate property of Husband hereafter, free
of any claim by or interest of Wife, regardless of whether such assets
were deemed by either of the parties to be marital property or non-
marital property before:
A, Husband's 25 percent interest in a hunting cabin
owned with members of his family.
B. Husband's interest in the Employee Savings and
Protection Plan with Carolina Freight Systems.
C. lIusband's retirement benefits wi.th the Teamsters
Pension Fund.
D. The balance within Husband's acconnt with the
Teamsters and Cheauffeurs Federal Credit Union,
E. Husband's IRA with Dauphin Deposit Bank.
F, A 1988 Yugo sedan now or formerly titled in Hushand's
name,
And further, Wife does hereby waive, l'I~lease, relinqu.ish, an() surrender
forever any and all claim to or interest in said assets, which shall be
and rema.in the sole and separate property of ffiJsband hereafter,
6. The parties hereto mutually agree that they have effected a
sat.isfactory division of the furniture, household furnish.ings,
appliances, and other household and personal property he tween them and
they mutually agree that each party shall, from and after the date
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hereof, he the sole and separate owner of all such tangible personal
property presently in his or her possession, whether said property was
heretofore owned jointly or individually by the parties hereto, and this
agreement shall have the effect of an assignment or receipt from each
party to the other for such property as may be in the individual
possessions of each of the parties hereto, the effective date of said
bill of sale to be contemporaneous with the date of the execution of
this Agreement.
7. The parties acknowledge that they are aware of the income,
education, income potential, and assets and holdings of the other or
have had full and ample opportunity to become familiar with suell items.
Both parties acknOWledge that they are able to support and maintain
themselves comfortably, without contrihution from the other beyond that
as provided for in this Property Settlement Agreement, .upon the income
and assets owned by each of them. The parties hereby acnept the mutual
covenants and terms of this Agreement and the benefits and properties
passed to them hereunder in lieu of any and all further rights to
support or alimony for themself, counsel fees, and alimony pendente lite
at this time and dUl'ing any and all further or future actions of divorce
brought by either of the parties hereto and the parties do hereby
remise, release, qui t claim, and l'elinquillh forever any and all right t.o
support, alimony, alimony pendente lite, counsel fees and expenses
beyond those provided for IIer81n, durlug the pendency of or as a result
of ilny such actions, as provi ded hy the Di von:e Code of Pennsyl vania or
any othel' applicable statute, at this time and at ilny time in the
future.
8. Except as herein otherwise provided, each party heret.o may
dlspllue of his or her propel'ty in any way, and each (lilrty hel'flby
5
expressly waives and relinquislles any and all rights he or she may now
have or hereafter acquire, under the present or future laws of any
juriodiction, to share in the property or the estate of the other as a
result of the marital relationship, including, without limitation, the
right to equitable division of marital property, alimony, alimony
pendente lite, and counsel fees, except an provided for otherwise in
this Agreement, dower, courtesy, statutory allowance, widow's allowance,
right to take in intestacy, right to take against the will of the other,
and right to act as administrator or executor of the other's estate, and
each will, at the request of the other, execute, acknowledge, and
deliver any and all instrtlments which may be necessary or advisable to
carry into effect this mutual waiver and relinquishment of all such
interests, rights, and claims.
9, Husband releases his inchoate intestate rights in the estate of
Wife and Wife releases her inchoate intestate rights in the estate of
Husband, and each of the parties hereto by these presents for himself or
herself, his or her Ileirs, executors, administrators, or assighs, does
,remise, release, quit claim, and forever discharge the other party
hereto, his or her heirs, executors, administrators, or assigns, or any
of them, of any and all claims, demands, damages, actions, causes of
action or suits of law or in equity, of whatsoever kind or nature, for
or because of any matter or thing done, omitted, or sllffered to be done
by such other party prior to tile date bereof; except that this release
shall in no way exonerate or discharge either party hereto from the
Obligations and promises made and i"~osed by reason of this agreement
and shall in no way affect any cause of action in absolute divorce which
either party may have againnt the other.
6
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10. The parties hereto mutually represent to the other than neither
of them has incurred any dehts in the name of the other not previously
disclosed or provided for in this agreement. Each of the parties hereby
repreaents to the other that nei ther one of them have incurred Ol'
contracted for debtll in the name of the other or for which the other is
or would be legally liable from and after the date of the parties'
separation. Both parties hereto mutually agree and promise that neither
will contract or otherwiae incur debts in the other's or joint names
without the prior permission and consent of the other party hereto.
Both parties hereto represent and warrallt to the other party that they
have not so contracted any debts unbeknownst to the other up to the time
and date of this Agreement.
11. Both of the parties hereto represent to the other that they
have made full disclosure of the assets and income and income sources
owned, controlled, or enjoyed by either of them and that neither party
hereto has withheld any financial information from the other. Each of
the parties represents that they have reviewed this iuformation with an
attorney of their choice, or had the opportunity to review this
information with an attorney of their choice and VOluntarily decided not
to do so.
12. In the event that any of the provisions of this agreement are
breached or violated by either of the parties, the other party shall be
entitled to enforce this agreement by an appropriate action in law or in
equity or to take any other action to wllich they are lawfUlly entitled
to enforce this agreement or otherwise protect their rights. In the
event that such action is commenced by one of the parties and the other
party is found to have breached or violated any of the terms and
provisions of this agreement, the purty having so violated or breached
the agreement, shall be responsible (or and shall promptly pay upon
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demand the reasonable attorney's fees incurred by the other party to
enforce their rights hereunder,
13. Tlte parties agree that they shall, upon the request of either
party's attorney, make, execute, acknowledge and deliver to their
attorney, for prompt filing with the court, affidavits of conaent and
any other document reasonably necessary to conclude the divorce. The
parties contemplate that the divorce will not be concluded until such
time as Wife has refinanced the house in accordance with Paragraph 2
hereof and made the payments to the Radabaughs and to Husband as
contemplated by this agreement. The parties agree, however, that tltey
will promptly provide to their attorneys all documents necessary to
conclude tlte divorce upon the request of their respective attorneys.
14. This Agreement sltall be interpreted and construed in
accordance with the laws of the Commonwealth of Pennsylvania.
15. If for any reason whatsoever any part of this Agreement shall
be declared void or invalid, ollly such part shall be deemed void and in
all other respec:ts tltis Agreement shall remain valid and fUlly
enfol'ceable.
16. The waiver of any term. condition, clause, or provision of
this Agreement shall in no way be deemed or considered a waiver of any
other term. condition, clause or provision of this Agreement.
IN WITNESS WHEREOF, the hands and
seals the day and year first above
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CON NEE l.. HEMPT
8
COMMONWEALTH OF PENNSYLVANIA )
( SS.:
COUNTY OF CUMBERLAND )
On thia, the .:zy.a..day of Abr"""",'f ' 19~t hefore me, the
undersigned officer, personally appeared MICHAEL A. HEMPT known to me
(or satisfactorily proven) to be the person whose name la subscrihed to
the within instrument, and acknowledged that said person executed same
for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
My
conf;;;:i ~'~~\*i res:
Noli.riaJSooI
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attc.....,.Iwb, EllPesI\l.o. 17.1gOa
COMMONWEALTH OF PENNSYLVANIA )
, (!IS,:
COUNTY OF CUlIBJ::l\...l\rmJ):JuPJlIN )
I
I On thia, the,;;)qlJ, day of &:inuA.~ , 1996, hefore me, the
undersigned officer, perGonall~-appear~ CONNEE L. HEMPT known to me (or
satisfitctorily proven) to be the person wh(ll;e name is subscribed to the
within instrument, and aeknowledged that said person exeeuted same for
thl! pUI'poser; there in contai lUll!,
TN WITNESS WHEREOF, 1 hereunto set my hand and official seal,
Kate liolo';81 SO"'
H ~ ~ Sl1orl:I, Notary Pu~ac
M Co Dr,s Uf!), Dauphin County
y mmlssfol1 Exnjr~s M:.rctl 0 "'98
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CONNEE HEMPT,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 94-1778 CIVIL TERM
MICHAEL A. HEMPT,
Defendant
: CIVIL ACTION. LAW
: IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record. together with the following infonnation, to the Court for entry of a
divorce decree:
1. Ground for divorce: Irretrievable breakdown under Scction 3301(c) of the Divorce
Code,
2. Date and manner of service of the Complaint: Service was accepted by the Defendant
on the 11th day of April, 1994, by certified mail, return receipt requested, receipt number P 413
868 995,
3, Date of execution of the Affidavit of Consent required by Section 3301(c) of the
Divorce Code: by Conne Hempt, Plaintiff, on May 29,1996; by Michael A, Hempt, May 3,
1996,
4. Related claims pending: None,
Respectfully submitted,
Dated: May 31, 1996
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MARIA P. COGNE
Sup, Ct.!. D, #27914
200 North Third Street, Twelfth Floor
p, 0, Box 689
Harrisburg, P A 17108-0689
(717) 232-2103
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CONNEI!: HI!:IlP!r,
Plaintiff
IN !rHI!: COUR!r OF COMMON PLBAS OF
CUMBERLAND COtlN!rlC, PENNSYLVANIA
CIVIL AC!rION - LAW
IN DIVORCE 71 CN, J
NO, qL(. 17 CIVIL 19
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MICBABL A. HEMP!r,
Defendant
NOTICE !r0 DEFEND AND CLAIM RIGH!rS
lCou have been sued in Court, If you wish to defend against the claims eet
forth in the following pages, you must take prompt action. lCou are warned that
if you fail to do so, the case may proceed without you and a decree of divorce
or annulment may be entered against you by the Court. A jUdgment may also be
entered against you for any other claim or relief requested in these papers by
the Plaintiff. lCou may lose money or property or other rights important to you,
including custody or visitation of your Children.
When the ground for divorce is indignities or irretrievable breakdown of
the marriage, you may request marriage counseling.
A liet of marriage
counselors is available in the office of the Prothonotary at the Cumberland
County Court House, carlisle, Pennsylvania, 17013.
IF lCOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTlC, LAWlCER'S
FEES, OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAlC LOSE THE
RIGHT TO CLAIM ANY OF THEM.
lCOU 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, Fourth Floor
Cumberland County Court House
Carlisle, Pennsylvania 17013
Telephone: (717) 240-6200
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COJDlI:B IIDIPT, I IN TBB couar or COIDlON PLBAB or
Plaintiff I CUJlBBRLIlND COIlJftY, PINNBYLVANIA
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y.. I CIVIL ACTION - lAW
I IN DIVORCE
MICBAIL A. IIDIPT, I
Defendant I NO. CIVIL 19
AFFIDAVIr OF MARRIAOZ COUNSELING
I, CONNEE HEHPT, being duly sworn according to law, deposa and eaYI
1. I have' been advhed of the availability of marriage counseling and
underetand that I may request that the Court require that my epouse and I
participate in counseling.
2. I underatand that the Court maintaine a 1iet of marriage counaelora in the
Prothonotary's Office, which list is available to me upon request.
3. Being so advised, I do not request that ths Court require that my spouse
and I participate in counseling prior to a divorce decree being handed
down by the Court.
I understand that false statements herein are made eubject to the
penalties of 18 Pa. C.S. 54904 relating to uneworn falsification to
authorities.
Datedl 4/7/94
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CONNEE HEHPT, Plai iff
Sworn and eubscribed,to
before me J:hil! 7tfJ
of CjJ~' < I'
/)- C' Ii 'iE.
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otary,
day 0,/
,194.
NOTARIAL Sl:JlL
MARYLYN A lJIPATO, ~ Public
Carble, Cumllcrland Ccunly
CornmluIon ~ JI. t2., 997
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IN !nIB COUR~ 0.. COICMON PLUS 0..
CUJIIIBRLUlD COtlH'1'Y, PIlJIIfSYLVAHIA
CIVIL AerIOH - LAW
IH DIVORCB
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IIICIIABL A. IIBIIPT,
Def.ndant
HO.
CIVIL 19
COMPLAINT IN DIVORCB
m !nIB BOHOIUUlLll:, !nIB JUDClI:8 0.. SAID COUR~I
AND NOW COMBS, CONNEE HEMPT, Plaintiff, by her attorney, Ruby D. Weeks,
Esquire, who avere as follows.
1. Plaintiff, CONNEE HEMPT, is an adult sui juris, who currently resides at
3790 Mountain View Road, Mschanicsburg, Cumberland County, Pennsylvania,
17055, eince 1981.
2. Defendant, MICHAEL A. HEMPT, is an adult sui juris, who currently resides
at 3790 Mountain View Road, Mechanicsburg, Cumberland County,
Pennsylvania, 17055, since 1981.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth
of Pennsylvania for at least six months immediately previous to the filing
of this Complaint.
4. The Plaintiff and Defendant were married on July 22, 1978, at Enola,
Cumberland County, Pennsylvania.
S. There have been no prior actions of divorce or annulment between the
parties in this or any othsr jurisdiction.
6. Nsither party is a membsr of the Armed Forcss of the Unitsd Statss.
COUNT I - INDIGNI~IES
3301 (al(61 of the Divorce Code
7. Paragraphs 1 through 6 are hereby incorporated by reference and made a
part hereof.
8. The averments under this Count are not collusive.
9. Defendant has offered such indignities to Plaintiff, the innocent and
injured spOuse, as to render her condition intolerable and life
burdensome.
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COUJI'T II - IRRBTRISV&RT.1! BRBAItDOWN
3301 Ie' of ~b. Divorce Cod.
10. Paragraphs 1 through 9 are hereby incorporated by reference and made a
part hereof.
11. The marriage ie irretrievably broken.
a. Plaintiff and Defendant have lived eeparate and apart since March
11, 1994.
12. Plaintiff hae been advised as to the availability of counseling and that
she may have the right to request that the Court require the parties to
participate in counseling.
13. Plaintiff requests the Court to enter a decree of divorce.
COUNT III - REOUEST FOR DIVISION OF PROPERTY
UNDER SBCTION 53502 OF THE DIVORCB CODB
14. Paragraphs 1 through 13 are hereby incorporated by reference and made a
part hereof.
15. The parties purchased or otherwise obtained during the course of their
marriage property which is considered "marital property".
16. Upon entry of a divorce decree, such property should be divided equitably
as is just and proper.
I verify that the statements made in this Complaint 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.
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Date.
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Ruby D. eeks, Esquire
Attorney for Plaintiff
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COHMOHWEAL~R OF PENNSYLVANIA
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The above named, CONNEE HEHPT, being duly sworn according to law, deposes
and says that the facts contained in the foregoing complaint are true and
correct, and the Complaint is not made out of levity or by collusion between her
and the said Defendant for the mere purpose of being freed and separated from
each other, but that it is brought in sincerity and in truth for the cause
mentioned in the said Complaint.
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Sworn and subscrib~d to
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CONNEE HEMPT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
ve.
MICHAEL A. HEMPT,
Defendant
NO. 94-1778
CIVIL TERM
AFFIDAVIT OF SBRVICB BY MAIL
PURSUANT TO PA R.C.P. 1920.4 la)ll)lii)
COMMONWEALTH OF PENNSYLVANIA
ss
COUNTY OF CUMBERLAND
I, RUBY D. WEEKS, ESQUIRE, Attorney for CONNEE HEMPT, being duly sworn
according to law, depose and say that a true and correct copy of the ComDlaint
in Divorce, wae eerved on MICHAEL A, HEMPT, at 3790 Mountainview Road ,
Mechaniceburg, Cumberland County, Pennsylvania, 17055, by mailing the eame to him
by certified mail, restricted delivery, No. P 413 868 995, on April 8, 1994.
Service was accepted on
ADril 11
, 19()4 .
V-1L~l..<<-o
Ruby D. Week , Esquire
Sworn and subscribed to
before me this j ;0....1- day",/
of Ap""'/ , 19.:z.:z...
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Notary Public ~
NatIIII SIll
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CaIIsIo IloIO, ClrT&Itand
My Comtrission E.presJan. 12, 1
TELEPH9NE 717:243,1294
d(t;f,!J !D. CWUk1
ATTORNEY AT LAW
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TEN WEST HIGH STREET
CARLISLE, PENNSYLVANIA 17013
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April 8, 1994
Hr. Hichael A. Hempt
3790 Hountain View Road
Hechanicaburg, PA 17055
Dear Hr. Hemptl
I am, by thia letter, aerving you with a copy of the Divorce' Complaint
brought by your wife, Conn.e Hempt. If you have .ny que.tione concerning the
Divorce Complaint, I eugg.et you contact your attorney, in that there are
epecific right. which you would be entitled to defend and claim, and there are
time limite for your doing so.
I would hope to hear from you or your attorney as soon as possible in the
hopee that we can equitably work out matter. between you and your wife ae quickly
ae poeeible, to prevent great emotional and financial expenae for both of you.
Sincerely,
~ If. "J~~ lto.uei4--
Ruby D. Weeks, E.quire
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COIlHBB IIBIIPT, I IN THB COURT 0.. CONNON PLBAS 0..
Plaintiff ICUMBERLAND COUNTY, PENNSYLVANIA
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.. . I CIVIL ACTION - LAW
I IN DIVORCB
IIICIIAJlL A. IIBIIPT, I
Dafandant INO. 94-1778CIVIL TERM
PRABCIPE TO WITHDRAW
TO TBB O....ICB 0.. THB PROTHONOTARY I
Pl.... withdr.w the .ppe.r.nc. of Ruby D. W..k., E.quir. .. coun..l
in the .bov. c.ption.d divorc. .ction.
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Ruby D. we; s, Esquir.
Attorn.y for Pl.intiff
PRABCIPB "OR ENTRY 0.. APPBARANCE
TO TBB O....ICB 0.. THB PRorJIONOTARYI
Pl..s. .nter my .ppe.rance .s counsel on beh.lf of CONNEE HEMPT, the
Pl.intiff named in the .bov. c.ptioned divorc. action.
D.tedl
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M.ria P. Cognetti, Esquire
Connee Hempt
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
J?1V
: NO. 94-~CIVIL TERM
CONNEE HEMPT,
Plaintiff
MICHAEL A. HEMPT,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
PETITION FOR ALIMONY. ALIMONY PENDENTE LITE.
AND COUNSEL FEES AND EXPENSES
AND NOW comes the Plaintiff, Connee Hempt, by her attomey, Maria P. Cognetti,
Esquire and petitions this Honorable Court for alimony, alimony pendente lite, and
counsel fees and expenses relevant to her Complaint in Divorce, and in support thereof,
respectfully represents as follows:
I. By reason of this action, Plaintiff has been put through considerable expense in
the preparation of her case and the employment of counsel and the payment of costs,
2. The Plaintiff is without sufficient funds to support herself and to meet the costs
and expenses ofthis litigation,
3. Plaintifl's income is not sufficient to provide for her reasonable needs and to
pay her attorney's fees and the cost of this litigation and Plaintiff is unable to
appropriately maintain herscl f during the pendency of this action,
4. Defendant has adequate earnings to provide for the Plaintitl's support and to pay
her counsel fees, costs and expenses,
5, PlaintitTlacks sufficient property to provide for her reasonable needs,
6, PlaintitTis unable to support herself through appropriate employment.
7. Defendant has sufficient income and assets to provide continuing support for
the PlaintitT.
WHEREFORE, PlaintitTprays this Honorable Court enter an Order awarding
PlaintitTalimony, alimony pendente lite, counsel fees. expenses and costs,
Respectfully Submitted,
,
Dated: January 23, 1995
Maria p, gnetti,
Sup. Ct. I.D, #27914
132-134 Walnut Street
P.O, Box 689
Harrisburg, P A 17108-0689
(717) 232-2103
.,
VERI FICA TION
I, Connee Hempt, hereby verii)' and state that the facts set forth in the foregoing
document are true and correct to the best of my information, knowledge and belief. I
understand that false statements herein arc made subject to the penalties of 18 Pa,
C,S.A. ~4904 relating to unsworn verification to authorities,
&~~
DATE: "J~lqS
MCTICN FCR APPCINTMENT .oF MASTER
,MICHAEL A. HEMPT, (~:&~ (Defendant),
a master with respect to the following claims:
( ,) Divorce
( ) ,Annulment
( ) Alimony
-( ) Alimony Pendente Lite
and in support of the motion states:
(1) Discovery is complete as to the claims(s) for which the
appointment of a master is requested.
(2) The Plaintiff (has) (~H~t) appeared in
(by her attorney, MARIA P. COGNETTI
(3) The staturory ground(s) for divorce (is)
Section 3301 (e)
(4) Delete the inapplicable paragraph(s):
(a) The action is not contested.
(b) An agreement has been reached with respect to the
None
(c) The action is contested with respect to the following
equitable distribution
(5) The action (~~~ (docs not involve) complex issues of law
CONNEE HEMPT,
IN THE COURT OF COM."ION PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Plaintiff
vs.
:'
MICHAEL A; HEMPT,
Defendant
94-1778
.19
NC.
moves the court to appoint
(X)
( )
( )
( )
Distribution of Property
Support
Counsel Fees
Costs and Expenses
the action (~KK~
,Esquire),
(are)
following claims:
claims:
or fact.
The hearing is expected to take
Additional information, if
(~).
(6)
(7)
None
Date:
Samuel L. Andes
ORDER APPCINTING MASTER
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respec~ to the following claims:
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AND NOW ,~ c.,,-, ';).,~'
is appointed master with
Esquire,
By thi Court: ,
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
CIVIL ACfION . CUSTODY
94-1778 CIVIL TERM
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CONNEE HEMPT.
Plaintiff
MICHAEL A. HEMPT,
Defendant
ORDER
AND NOW. this
tf'
day of Novembcr, 1995. at the rcquest of counsel for the
defendant. hearing on the above malter set for December 14, 1995. is continued to Monday,
December 18. 1995. at 9:30 a,m. in Courtroom Number 4. Cumberland County Courthousc,
Carlisle. PA.
BY THE COURT.
Maria P. Cognelti, Esquire
For the Plaintiff CJ.ri
Samuel L. Andes. Esquire 1~
For the Defendant "/8/4'1
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CONNEE HEMPT,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94 - 1778
MICHAEL A. HEMPT,
Defendant
IN DIVORCE
AND NOW, this
ORDER OF COURT
(brf(
day of
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,
1996, the economic claims raised in the proceedings having been
resolved in accordance with a property settlement agreement
dated February 23, 1996, the appointment of the Master is
vacated and counsel can file a praecipe transmitting the record
to the Court requesting a final decree in divorce.
BY THE COURT,
.
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------
cc:
Maria P. Cognetti
Attorney for Plaintiff
Ci't<'ooJ ",..,WA~ "';/7/cU,.
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Samuel L. Andes
Attorney for Defendant
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CONNEE HEMPT,
PlaintitT
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO, 94-1778 CIVIL TERM
v,
MICHAEL A. HEMPT,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDA VIT OF CONSENT
I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was
filed on April 7,1994.
2, The marriage ofPlaintitTand Defendant is irretrievably broken, and ninety
(90) days have elapsed from the date of the filing of the Complaint.
3, I consent to the entry ofa final decree of divorce after service of notice of
intention to request entry of the decree,
I verifY that the statements made in this affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C,S. Section 4904
relating to unsworn falsification to authorities,
Date: ~/.l4/9b ~ d-l-
Connee Hempt, P1a;~
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Sworn to and subscribed
before me this ~ day
of ,1996,
NOI~rhl Sea'
f(~re~ A. Shariff, NO~1:Y PllbI'lC
M .msbll'll, Dauphin Collllly
Y CornmlBSIoii F.xpir.s March 9, 1 'lll8
MIlitia; ~AsGOi:iiiOi 0/ NoIlr1Oi
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CONNEE HEMPT,
PlaintilT
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO, 94-1778 CIVIL TERM
MICHAEL A, HEMPT,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
April?,1994,
2, The mwriage of Plain tilT and Defendant is irretrievably broken, and ninety (90)
days have elapsed from the date of the filing of 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,
attorney's fees or cxpenses if I do not claim them before a divorce is granted,
I verify that the statements made in this affidavit arc true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa,C,S, Section 4904 relating to
unsworn falsification to authorities,
Date: 3 MA'I f ~'t/'
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Ichael A, Hempt. Defendant
-'
Sworn to and subscribed
before me this ~ day
of /J1t'r Y , 1996,
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Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY. PENNSYLVANIA
v,
: NO, 94-1778 CIVIL TERM
MICHAEL A. HEMPT.
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY
OF DIVORCE DECREE UNDER
o 330J(c) OF THE DIVORCE CODE
4. I consent to the entry of a final Deeree of Divorce without notice,
S. 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,
6, I understand that 1 will nol be divorced until a Divorce Decree is entered by the
Court and that a copy of the Decree will be sent to me immediately after it is filed with the
Prothonotary,
1 verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa,C,S. ~ 4904 relating
to unsworn falsification to authorities,
DATE: S/oJfI It! (p
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CONNEE HEMPT.
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 94- 1778 CIVIL TERM
MICHAEL A, HEMPT.
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY
OF DIVORCE DECREE UNDER
~ 330Hel OF THE DIVORCE CODE
I. I consent to the entry of a final Decree of Divorce without notice,
2, I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted,
3, I understand that I will not be divorced until a Divorce Decree is entered by the
Court and that a copy of the Decree will be sent to me immediately after it is filed with the
Prothonotary,
I veritY that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of I 8 Pa.C,S, ~ 4904 relating
to unsworn falsification to authorities,
DATE: 3 MA'f 19%
'N\\~~.t a\\~
Michael A, Hempt, Defendant
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CONNEE L. HEMPT,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 94-1778 CIVIL TERM
MICHAEL A. HEMPT,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
INCOME AND EXPENSE STATEMENT
The following is the Income and Expense Statement filed by
Plaintiff, Connee L, Hempt, in the above-captioned divorce.
:
THIS PORM MUST BE FILLED OUT
(If you are self-employed or if you are salaried by a
business of which you are owner in whole or in part, you must
also fill out the Supplemental Income Statement which appears on
pages Band 9 of this Income and Expense Statement,)
INCOME STATEMENT OP
CONNEE L. HEMPT
Employer:
PA Blue Shield
Address:
1800 Center Street,
Type of Work:
~roarammer
Payroll Number:
Pay Period (weekly, biweekly, etc,):
Bi-weeklv
GROSS PAY PER PAY PERIOD:
$1,775.00
Itemized Payroll Deductions:
Federal Withholding:
$ 223.92
Social Security:
135.38
Medicare
Local Wage Tax:
17.75
State Income Tax:
49,70
Unemployment Tax
2.65
Retirement:
106,50
Savings Bonds:
Credit Union:
Life Insurance:
Health Insurance:
Other: (specify)
Dental Insurance 7.50
United Way 2.00
Shield Club .25
Add'l Fed Withholding 5.00
NET PAY PER PAY PERIOD: $1,224.35
OTHER INCOME:
~
Month
Ye.n
Interest
Dividends
$
$
$
Pension
Annuity
Social Security
Rents
Royalties
Expense Account
Unemployment Compo
Workmen's Compo
TOTAL OTHER INCOME:
TOTAL MONTHLY NET INCOME:
$
$ 2.652.76
EXPENSES
Weekly
Home
Mortgage
Maintenance
Repairs
Utilities
Electric
Gas
Coal
Telephone
Trash
Sewer
Employment
Public
Transportation
Lunch
Taxes
Real Estate
Personal Property
Income
Insurance
Homeowners
Automobile
L:.\~;t ;11J.~:,'
'- ',- .-.,",......~ ,o-A..,_""........ '.
Monthly
Yearly
528.53
50.00
100.00
120.00
18.50
18.00
11.00
65.00
123.00
16.00
24.50
52.00
EXPENSES
Weekly
Monthly
Yearly
Life
23.00
Accident
Health
Other
Automobile
Payments
Fuel
130.00
Repairs
12.50
Maintenance
10.00
Licenses/
Registration
4.00
Auto Club
Medical
Doctor/Dentist/
Orthodontist
50.00
Hospital
Medicine
18.00
Special needs
(glasses, braces,
orthopedic
devices)
Education
Private school
Parochial school
College
.
EXPENSES
Weekly
Monthly
Yearly
Religious
School lunches
25.00
Books/misc.
5.00
Personal
Clothing
150.00
Food
450.00
Barber/hairdresser
25.00
Personal Care
Laundry/dry
cleaning
15.00
Memberships
8.00
Hobbies
16.00
Credit payments
Credit card
200.00
Charge account
Loans or Debts
Credit union
Miscellaneous
Household help
Child care
90.00
EXPENSES
Weekly
Monthly
Camp
4.00
Pet Expense
12.50
papers/books/
magazines
5.00
Entertainment
100.00
pay TV
vacation
150.00
Gifts
30.00
Legal fees
360.00
Charitable
Contributions
5.00
Religious
Memberships
Children's
Allowances
52.00
Other Child
Support
Lessons for
Children
20.00
Other
Snorts & Snorts
Pictures
32.00
20.00
4.00
$ 3152.53 $
Ski Club
School pictures
TOTAL EXPENSES
$
Yearly
'~T'_C'.,. ..._......',...'........
>~-,,-"l~.",~_jf'
.
I understand that the statements made herein are subject to
the penalties of 18 Pa.C.S. ~ 4904 related to unsworn
falsification to authorities.
~ A
Con nee :.t~~~
I verify that I have reviewed this form with my client and to
the best of my knowledge the answers herein are true and correct.
.
,
CERTIFICATE OF SERVICE
Maria P. Cognetti, Esquire, Attorney for Plaintiff herein,
hereby certifies that she served the foregoing Income and Expense
Statement by placing a true and exact copy thereof in the United
States mail, postage prepaid, to the following address:
Samuel L. Andes, Esquire
ANDES, VAUGHN & BANGS
525 North Twelfth Street
P.O. Box 168
Lemoyne, PA 17043
~~.
Sup. Ct. I.D. #27914
132-134 Walnut Street
P.O. Box 689
Harrisburg, PA 17108-0689
(717) 232-2103
Dated: February 17, 1995
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(717) 232.2103
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v.
: NO. 94-1778 CIVIL TERM
'"..
CONNEE L. HEMPT,
PlaintilT
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
MICHAEL A. HEMPT,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
INVENTORY AND APPRAISEMENT
Of
CON~EE HEMPT
PlaintilT files the following Inventory and Appraisement of all property owned or
possessed by either party at the date of separation and all property transferred within the
preceding three years.
PlaintilTverilies that the statements made in this Inventory and Appraisement are
true and correct. PlaintilTunderstands that false statements herein are made subject to the
penalties of 18 Pa.C.S. ~4904 relating to unsworn falsilication to authorities.
~Uk~~
Connee L. Hempt, PlaintilT
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ASSETS OF PARTIES
Defendant marks on the list below those items applicable to the ease at bar and
itemizes the assets on the following pages. I f an item has been appraised, a copy of the
appraisal report is attached.
( X ) I. Real property
( X ) 2. Motor vehicles
( ) 3. Stocks, bonds, securities and options
( ) 4. Certilicates of deposit
( X ) 5. Checking accounts, cash
( X ) 6. Savings accounts, money market and savings certificates
( ) 7. Contents of safe deposit boxes
( ) 8. Trusts
( ) 9. Life insurance policies (indicate face value, cash surrender
value and current beneliciaries.
( ) 10. Annuities
( ) 11. Inheritances
( ) 12. Patents, copyrights, inventions, royalties
( ) 13. Personal property outside the home
~
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,
(') 14. Business (list all owners', including percentage of ownership
and officer/director positions held by a party with company.
( ) 15. Employment termination benefits. severance pay, workman's
compensation claim/award
( ) 16. Profit sharing plans
( ) 17. Pension plans (indicate employee contribution and date plan
vests)
( X ) 18. Retirement plans, Individual Retirement Accounts
( ) 19. Disability payments
( ) 20. Litigation claims (matured and unmatured)
( ) 21. MilitaryN.A. benefits
( ) 22. Education benefits
( ) 23. Debts you owe (and/or your wife or husband), including
loans, mortgages held, etc.
( ) 24. Household furnishings and personalty (include as a total
category and attach an itemized list if distribution of such
assets is in dispute
( ) 25. Other
.
MARITAL PROPERTX
Defendant lists all marital property in which either or both spouses huve u legul or
equitable interest individually or with any other person as llfthe date ofscpurutlon:
NATURE OF LIEN:
Mortgage
MARITAL PROPJo:RTY
I. REAL ESTATE
ITEM DESCRIPTION:
3790 Mountain View Road
Mechanicsburg, P A
OWNERSHIP:
Husband & Wife
POSSESSOR:
Wife
DATE ACQUIRED:
6/30/81
COST/ACQUISITION VALUE:
Approximately $69,000
DATE OF SEPARATION VALUE:
Unknown
PRESENT VALUE:
$95,000. See attached.
NAME AND ADDRESS
OF ANY LIEN HOLDER:
Wilbur Raudebaugh
EFFECTIVE DATE OF LIEN:
Approximately 1981
PRESENT AMOUNT OF LIEN:
$31,749.87 as of2/1/95
See Attached.
,.....
APPRAISAL REPORT
01
3790 Mountain Vlow Rood
Noehanleobura,'A 17055
Sumary Appralool "port
PREPARED FOR:
Connlo "..pt
3790 Mountain Vlow Rood
Noehanlelburs.'A 17055
AS OF:
January 25.1995
PREPARED BY:
Mark E. Hllbart & Alloclat.1
5221 SWIl""" porry Rood
Noehenlelburs. fA 17055
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".~. - 3790 VI.u '~A PA nn..
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--- ......... ....- 0......' "'....10-....1 r I~ ~ c:--;::~
". .'. I... ..h
N ~ "-... h'.......................... _.... ......,_
e ......,...........".............__: Property 11 located along Howlt_in View Road 1n Hampden
I Tovo.hlp.CUmberland Councy,Pennaylvan1a.
0
H 'tce.. "* -"10<<.... .......1....'.. ""..-'...................... __, 1..........-.... _c.., ---.......111_'. ......te.....w... '11_1.
B Property baa good ace... to employment and ..rvlc...
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~..__l...........~.~...................._...~a-....,l: Vlth the improving market. ..ller.
are not required to offer ..1.. or financing cona...lona. Financing i. r.adily availabla from
. variety of laure...
i, v.".. ...A .~~., A ~.~ "" .H... ~ ......
, .......-.-..f\Dt .I...............~.........~......H_O"......"---...o"" DYM 0...
U ,.....oII'I_.I....,........,.......""''''''''*INl".... N/A . AI/ItIf._.....~.,_I......"""""""....... N/A
D ......,.....- .-.- ,........ NIl..
- Topography SlftNl.. t'n lPrnnt'
""AI.. 43,743,1 SO.P~. C.,..LIII DYM 00,,, Sill 1 A__.
"""'f..,....d_I~...~ -O-IrI...... Shop,
I..... ....._ Ii] L.... ~ Leo..__..-.IOIIf1ff........... 0.... O,ein.g.
"..-.....1.............. "-"... OO"".....1lIIiafII Vi.w ...
S Utili... PubJlc Other 00..... Typ. "'bIl. Priv,.. LlncJlCaplng
I onn ._ ~4\1...ilooIllla Dnw.., ...,_
T EI.ctrlcity Su..t Hacadam _.-
E 0.. CurbJautt., Nona
W.tll SldnrMk None FEMA Sp.t!. Rood H.,.rd Ar.. 0 V.. OONo
:~~:~..s.::,.r Str..t light. None FEMAZontC MapO.t;-.,..,....-;-..-'
1 ..., :.
c_~W'C........-._--.......-.................._...,--............"'.I: None apparent. Subject
however to relervatioMI ea_ementa. condition. and right of way of record.
a GENERAL, DES~:T10N EXTERIOR DESCRIPTION FaUNaATlDN_ BASEMENT "" INSULATION
E No. of UNt. Found.don Al~k SI.. A". Sq. Ft. Roo' ~
B No. of Stori.. nn. Eat.norWIlI. C"wl Splct t,L" '" Finl.hed " Ceiling
C Typ.IOI1./AtI.) Roo'Surf,cI I ~ Ba.em.nt 1.'..,,-' C.Iling Wall.
R
I DIIlgn 15tvll) A-I _, .....1 o...n....O..,.... Sump Pump w... Roor
p "-- Window Typ. D..-npne.. Aoo, "'~.. None
T Ag.tYII.) ~ StOrm/SCII'''' S.IU.ment Out.id. Entry Nn ",,-,
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a '" ,-.- . .. .... I" ;
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a 1217
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M Fini h r ........... ntAt4. t'~fll..".. 3 1'''O_'~I--: am".
p , ;', ,
R INTERIOR ......,....'1:_,_ HEATING KITCHEN EQUIP. ATTIC AMENITIES CAR STORAGE
a FloOI. Typ. :!: R.big."tor iii Nons Fillpllcl'.1 ,*** NoneliJ
V
e Wille Fu.l Rlng.fO""." 51.,. P.lio a".g. ...c:..
M fllm/Finllh Ck.pOI. Drop St., 00.. "'--
t Bath Floor COOUNG o..hwllher Scultl. Porch Covered
N C.nl'al'-..,...... ...--
T Iw.W_ec F.nlHood FlooI Fene. ......-
. Dool. ".",,;; V""" Other MlCIOW'YI H..t~ I~. lna:round C.rpon -;--
. PoA"" v... IW.'h.' , FIN h--" I nn..w.. .-
......_,........~..-.,.ll_,,_..IrISkylite . *** Pireplace 1. NOT u.able unle._ u.ed with a WOOd/coal
c insert.
0 C_to....l'-_.._........CO_~...'-I_.......II......U.._..............I,.._WC1>If\.~....._..u No evidence of
M functional or external oblole_cenc.. Subject i. in need of lome repairs and a complete
M
e re-decorating. Fire box in fireplace should be replaced, vell pump needa repaired.
N Landscaping should be up-graded. Subject i, tn Fair to Average Condition.
T
. /l4....._.._.I__~..........--..I..IIeo._.-.I_....._..I.I.._......_..._...._............_..._I'..I,..~I
~=;~~:~~ ~~~, no ^:i:~~1.e or apparent advers. environmental condition. that would negatively
II v U'" .~-- i.~....
.._..."'......ro.n M' .
..~..._...:...
Mark E. Hilbert & Assocletes
P'OP.,ty Dllcrlption
UNIFORM RESIDENTIAL APPRAISAL REPORT
IIEIIPT
FII. No. 9~010HH
..Iloctw""" llIJI4.1I."1.1
'.1,1
'_....'_ICO"...,1.1
<.w... ~. .,''W'>'
V~ SMUon
Mlrk E. Hilbert 8& Alloellte.
UNIFORM RESIDENTIAL APPRAISAL REPORT
11] HUl lAne
DIl'_"
e,p.K,L.
>d. No, 950l01Ul
ComnWlI)'1 on COil IoPPfOach ll"ch II I~'C' 0' cOil
1.llmlll. till Vel"l. lqu." '001 celc"I.Uon and 'or HUD,
VA, and FmHA. 1M ..~mal~ ,.mairlng .conomic Ill. 0'
Ih. proplIlyl: In reproduction COlt of
~roYe~nt. Karlhall 6 Svift Handbook
and locel contractora are referenced.
The depreciation of in Bround pool i.
reflected in the depreciation aection.
481] Brian DrIve
4B6l Vlra1n1a Road
UTlMATlD SITE VALUE.. .. .................... _ I
C ESTIMATI!D REPRODUCTION COST.NEW OF IMPROVEMENTS:
o OweWng 12U Sq. FI...' 43.85 _ . 54.023
· B...m.nt 1232 Sq. Ft..' 12 .00 _ 14 184
T Porch I!:nc1o.ed Poreh In Dr. Pool 20 000
A aa"gelC.rpon _ Sq. Fl. 0 .
p Tal" hUmll1d Colt NI"" .. . , . . . . . . . . . . . . . _ . 88.801
,
R PhVlICIl I F"ACllonel I bIll""
o tin 24 I
A Dlprecllllon 21. 313 _ . 21 113
~ Dlprecilled VeI"l 01 ImprOY""'nl. . . . . . . . . . . . . . . . . . _ .
"A..il"VaI"loISllIlmplOYlmenll ................ _ .
~1.lU_"- t~!'.;~..4::. ;'ttIt.t_~r: O~-~;
elC_.... ~,"H '..~~ ' '. . J;
c_...s..c.......-~""-...a~"'*"..~I''''',..,......,IUJ: Comparable.
.alea available vithin a rea.onable diltance of the lubject.
. ,
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Porch
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DOlI 20
DOH 52
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+1.200
+1.200
Pull
Pull
+1.500 Patio
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cho.en vere the best cloaed
A
N Subject il on veil/septic which i. typical of the neiQhborhood and doe. not adverlely tmpact
A marketability.
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The lack of storm lewerl, curba. gutterl. lidewelka, and/or atreet llQhtl il typical of the
ne1Qhborhood and doea not adverlely impact marketability.
The property' a heat1n&. and electrical Iyatema appear to be functionlna properly to the beat
of the apprailer'. knowledge and expertile.
It 11 noted that the price per aquare foot of Bro.. living ar.. for comparable No Ca).
___3______ varie. by more than '10.00 per lquare foot compared to the lubject. The comparable.
cholen are the belt available.
The vacant land in the ar.. il chang1ns to Itnale family and doe. not have a negative effect
on the value.
I am unable to verify the lnIulatlon 'R' factor. The prelence of 11lU!'.A..POllKAlDEHYDB FOAM
INSUUoTION could not be deumlnad. If UrPI b praaent. tha apprabel mar""t valua may be
adversely affected or voided. Any information about insulation atatad on the appra1aal v..
provided by inapection. awner. or asent, and 11 aSlumed to be accurate.
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do Ca
.
..tI.~UJtoll dUI....nn
'III"
"'n'.... ,.'" 1004 ..,
"-'--
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Milk E. Hilbert & Alloelllll
UNIFORM RESIDENTIAL APPRAISAL REPORT
fll. No. 850IOMH
i,;; have the neu..ary equlpunt to te.e for the pn.ence of .aII!!. If a future teat .how.
.~. unacceptable. level. pf ladon prl..nt. the appral.ed market value may be adver.ely effected or
voIded.
:. Ple..e be adv1led that In the market data analyd. arid, bathroexu are IdJuated for on the
A
'L'! f!.rat line and aro.. 11vinK aria/room count are adjuated tasether a. a _!nale adJu.tment on
i.;, the ucond line.
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&Ilel Ire flrm in the ana: however III&I\Y re.alel have FHA/VA and concelllon flnanclng.
'Ile. vere uaed after adjuatmenta vere can.ldered.
'lbe.e
All comparlble .ale. are .Itcled to the bl.t of the appral.er"
Ilnovledse,
VerlUcaclon of
0_.........0...
...............-
....,...,..".......
None
NIA
None
NIA
None
NIA
None
NIA
ANtyM.....,. _........-- 11......-............... "......,........,.. II...,. """..."..................... _""-' _,.."........ II ........,
N/A
aHDtCATED VALUE BY SALES COY'AIUION APPROACH.............................................. .
T.................. .....I.....,.,....,.........~.................... ......".....--.......................
e___.. ~_"ITh. appraiaer .'IUlUI a marketable title and that aU of the equipment a'loclaced
vlth the improvement 11 in vark!na order.
R """""-'io_:The uarket approach reinforced by thl COlt approlch La a aood indlcator of 'alr
~ Market Value. Thl face that the IIUer 11 or 11 not payina any portion of the clo.inS COltl
o ba. no efflct on thla apprll.al or rllale.
N T...~_ III _ ........,,_...-wI._.. ......"......, "*.._..... ,,_'..-t...... ,"IN ___tnlllllol...............,..................
"r. ......._..........'-I.....~tNI.......IrIIN..I.................."'.IIIf.........f_IODol."""""" 6/93
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I rwn ESllMATE T1iE
AS DfRNjD. OF THE RfAL PROPERTY mAT ts T1iE SUBJECT Of nas REPORT. AS OF
'0I.fi! OFINSl'<Cl1OH ANOTHf EfRCTlVE OATE OfllilS IW'OfI1lTO lIE . 95,000
~ NftWIIJI~~'t If "IQ~OI
.......
.-
D.. ",",I ....
.... e.w.c......
Clfll..~,
0... 0.....
-"-'
............4
........
.-
O_"'-1......J.nuarv 27.199S
lI_e.nh_,RL 000388-L
Ir-,.PA
11-,.
Olll..w-'
II...
II...
..tI.""""___ Ta JIoO.' 1l1.'....rr.,
"'...12
._....'....100<1..,
Mark E. Hllbart lit Associates
FiI.NO.~
I ::~~~:~~'~..gat~~~ ~lE:~~.rl.nd
hnder Conni. H t
Sial. PA
liD C:od. 17055
ADDENDUM B
APPRAISAL CERTIFICATION
I cortUy that, to tha b..t of my lo1ovl.cIa' and boll.f.
the ltat.ment. of fact contained in thb report are true and conlct.
tha reported ....ly.... oplnlona. and concl...1on. are lWtod only by tho toport.d
Illumptlona and Ualein. condltlona, and ar. 11I1 par.emal. unblalld prof.l.tonal analy...,
and conclualonl.
I have no (or tha ,poclfi.d) pre..nt or pro.pocUve Intore.t In tha proporty thet 10 tho
.ubJ.et of th10 report. and I have no (or tha .pocUlod) pora",,"l Intor..t or bl.. rith
r'.pect to the paRlI. 1nvolvld.
my compln.atlon b not conttnaant upon the reportlna of . prad.t.mined value or dlrection
1n valu that favorl the caUl. of thl client. the amount ot the value ..tlmataf the
It.ta1nzHnt of . Itlpulatact r..ult, or the occurrence of . lub..quent Ivant.
the apprabal ...lgtuunt v.. not ba..d on . requelted minimum valuation, I aplclflc
valuation. or the approval of . loan.
. my analy.... op1nlona, and conclullonl vare deVeloped, and ebb report baa bean prepared in
conformlty wlth tho Unlform Stondar41 of Prof"'l",,"l Approl.ol Pr.ctlco and .1.0
requirement. of the Code of Profe..ional Ethic. and the Standard. of Prota..ional Practica
of tho Appeal..l Inatltuto.
the uae of thla report b .ubject to the requlrementa at the Apprallal In.titute to review
by it. duly autbortsed repre.entati~..
I have (or have not) ..41 . por.onal In.poctlon of tho property that 10 tho .ubJ.et of th10
report.
no ono provlded .1gnlflcant profo..lonal ...l.toneo to tho per.on .1gn1ng thl. report. (If
there are exception.. the name. of each individual providing .ignUicant .llbtence muat be
.. Itated.)
a. of the date of thb report, I, _Mark E. HUbert
have completed thl requlrementa under the continuing education progrlJll of the Apprai.al
Inatitute.
A review of thb agreement of .ab. ba. been detemlned that peraonal property itUll, and/or
Inronalblo 1...... thet .re not rool property. HAVE NOT boon Includod In tho .Sr.......t of 0010.
Pononal proporty It..... and/or Inronalblo It.... HAVE NOT bo.n conold.rod In d.tot1llln1ng tha
.ubject. e.ttmAted markat value.
..................................................................................................
NO YES
l. _X_
2, _X_
], _X_
Th. aubJ.ct .old dur1ng tho lo.t year.
Bal. prlc. , Dato
Th. aubject va. li.ted for .al. .t the tlme of tn.pectlon.
U.t1ng prle. ,
The aubject va. tauter agreement at the tta. of inlpection.
Agr....nt price .
J.nuary_25 ,1995
Dat.
~~
Appr.1oorA ~,~.~
(X) dld ~~ ct property
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Mark E. Hilbert & Associates
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· "~f~~~'tl;;fiS~'l'l\1iA!:>>I)ENDUM;TQ:AP.PRAISAl;'.;
APPRAISAL REQUIREMENTS
MANDATED BY FIRREA
I cenifV \hIlthe Ippl-'." conform. 10 lhe Uniform Stand,rd, 0' PrO'"lional ApPf.... Practlc. IUSPAPJ promulgltfd
by 1M Appr.1aI atandard. Solid of 1M App,..... Fowndltion.
The ,ubi-CI 0 1111 Ii) U. noU Ii,tld fat ..... Ihlli't1ng pric. I. .
period of the ,witel proplny I,
. My ItbINl, of the "..aMbl, mtrtl.,tlng
If In ~p'oach 10 .....u. WI' not Uled, Iht following I, In I.planlltlon why 11 WI' nol con.ld.,ed.
COlt:
tMrk,t:
Income: n/a
The appral." ....gNnenl 0 ,..., IiJ CWII nolJ b..ed on ,.qua.ted minimum 01 spIcUle \llIu,tion 0' on the _'0'1.
0' . lOin.
I 0 1~"'.1 iii (htvI nol liNnei" lnlt,..tln the lOin ',.nlactiOR Ind do not Il'nd to baNl:!II" InV \Iuy from 1"-
vII". pleced on the PfOPlrtV.
I (i) (hanl 0 lh..... noU included I "pt'ltl ....."'"'n' ol~..onel property. fiJl1ur.., 01 Intangibla IIams w~ch
a,. a"ached to or localad on the- r... Pf~rty. Tha.. 111m' U Idol iJ Ido notJ alf.cl the INrkal v"u. of lha
r." prop.rtV.
Anv ct..liv. flnanclal or ..... cone...lons lhal ." known 10 lhe ~tli." ha", ba.n ~ju'lad In lhe comparabla. of lhi.
appr..a.I.
In P.rfCtming lhi. APIIt..... I w.. nolabl. 10 "~.w the:
Taxes
(in..rt N/A If In8Pj)licablal
Th. above llama .houtd ba obtalntd bV the I.ndar when t.v1a""ng the eppr.... ,&port.
Thi. appral." va.luatlon of lhe IUbjecl prop.rtv I. In an .... I." condidon II of the d.t. of Inspection.
I c.rtifv that I have the appropriate knowledga and axpari.ncathal wa. nec....ry 10 C~ata IhI. ..slgtvnant.
~
!lark .. Ube t .
Januarv 25.1995
DATE
11111 appra1la1 report confOnlli to the Uniform Standard. of Profe..lona1 Appra1aal Practice
(USPAP) adoptad b)' the Appralld Foundatlon.
lbe builder/.ellar b peying
and/or $
" point. ($ )
in tone.ulon. on the .ubJect property.
lbe following pereOllll property. flxturu. and/or intanglble lCeIlll are not included in the
appra1aed value but are a part of the lale of the lubject property.
ITEII
1. aefrigerator
2. Range/Ovatl/llood
3. Dlahva.her/Dl.po.al
4. Walher/Dryer
ESTIllATED VALUE
$400,00
$425.00
$200.00
$400.00
It .hou1d be noted thet the appraber II creined in the valuation of aul Property. not
Per'OIIIl Property. therefora. the above e.t1mated value. IllIY heve dlcrepancle. from real
value.
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ProPtrty Addr...
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County
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BUILDING SKETCH
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INSTALLMENT SALES AGREEMENT
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THIS AGREEMENT, made this ;)\..1 day of Vk?_-
1981, by and between WILBUR E. RAUDABAUGH, of pden Town-
ship, Cumberland County, Pennsylvania, hereinafter referred
to as "Seller" and MICHAEL HEMPT and CONNEE L. HEMPT, hus-
band and wife, of Hampden Township, Cumberland County,
Pennsylvania, hereinafter referred to as "Buyers",
,
THE PARTIES HERETO, with intent to be legally bound,
do hereby agree, covenant and represent as follows:
1. SALE AND PURCHASE. The Seller shall sell and
convey to Buyers, who shall purchase all those certain lots or
pieces of ground with improvements thereon erected, commonly
known as 3790 Mountainview Road, Mechanicsburg, Cumberland
County, Pennsylvania, as more fully described as follows:
ALL THOSE TWO (2) certain pieces or parcels of
land situate in Hampden Township, Cumberland County,
bounded and described as follows:
TRACT NO.1: BEGINNING at an iron pin on the
Northern dedicated right-of-way line of Mountain
View Road, said iron pin being at the dividing
line between Lots Nos. 1 and 2 on the hereinafter
mentioned Plan of Lots; thence along the said
dividing line North 02 degrees 29 minutes 57
seconds West, one hundred eighty-four and thirty-
two hundredths (184.32) feet to an iron pin;
thence North 85 degrees 47 minutes 50 seconds
East, one hundred and zero five hundredths feet
(100.05) feet to an iron pin on the dividing
line between Lots Nos. 2 and 3 on the hereinafter
mentioned Plan of Lots; thence along said divid-
ing line South 02 degrees 29 minutes 57 seconds
East, two hundred nine and sixty hundredths
(209.60) feet to a point on the Northern dedi-
cated right-Of-way line of Mountain View Road;
thence along said Northern dedicated right-Of-way
line of Mountain View Road North, 79 degrees 55
minutes 27 seconds West, one hundred two and
forty-six hundredths (102.46) feet to a point on
the dividing line between Lots Nos. 1 and 2 on
the hereinafter mentioned Plan of Lots, the place
of BEGINNING.
BEING Lot No. 2 on the Final SUbdivision Plan for
Wilbur E. RaUdabaugh, said Plan being recorded
in the Cumberland County Recorder's Office in
Plan Book 32, Page 44.
HAVING THEREON ERECTED a dwelling house.
TRACT NO.2: BEGINNING at an iron pin on the
, \
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.1
.
. .
Northern dedicated right of-way line of Mountain'.
View Road, said iron 'pin Ueing on the dividing
. line between Lots Nos. 2 and 3 on the hereinafter
mentioned plan of Lots; thence along said dividing
line North 02 degrees 29 minutes 57 seconds West,
two hundred nine and sixty hundredths (209.60)
feet, to an iron pin; thence North 85 degrees
47 minutes 50 seconds East, one hundred and zero
and five hundredths (100.05) feet to a point;
thence South 02 degrees 29 minutes 57 seconds
East, two hundred sixty and fifty hundredths (260.50)
feet to a concrete monument on the Northern
dedicated right-of-way line of Mountain view Road;
thence along the said Northern dedicated right-of-
way line of Mountain View Road, North 79 degrees
55 minutes 27 seconds West, one hundred two and
forty-six hundredths (102.46) feet to a point
on the dividing line between Lots Nos. 2 and 3,
the place of BEGINNING.
BEING Lot No. 3 on the Final Subdivision Plan for
Wilbur E. Raudabaugh, said plan being recorded in
the Cumberland County Recorder's Office in plan
Book 32, Page 44.
BEING the same premises which Wilbur E. Raudabaugh
and Alma V. Raudabaugh, husband and wife, by their
deed dated February 2, 1981, and recorded in
the Office of the Recorder of Deeds of cumberland
County, in Deed Book "H", Volume 29, page 715,
granted and conveyed unto Wilbur E. Raudabaugh,
the Seller herein.
upon the following terms and conditions.
2. PURCHASE PRICE.
be SIXTY-NINE THOUSAND NINE
which shall be paid to the
The price or consideration shall
HUNDRED ($69,900,00) DOLLARS,
Seller by the Buyers as follows:
a. The sum of
DOLLARS, on the signing of
Estate, dated May l, 1981,
ledged; and
ONE THOUSAND TWO HUNDRED ($1,200.00)
the Agreement for Sale of Real
receipt of which is hereby acknow-
b. The sum of FIVE THOUSAND ($5,000.00) DOLLARS
on the signing of the Pre-settlement Lease Agreement, dated
June 2, 1981, receipt of which is hereby acknowledged; and
c. The sum of EIGHT THOUSAND EIGHT HUNDRED
($8,800.00) DOLLARS, at the time of signing this Agreement,
receipt of which is hereby acknowledged; and
d. the balance of the purchase money, FIFTY-
FOUR THOUSAND NINE HUNDRED ($54,900.00) DOLLARS, in one
hundred twenty (120) equal monthly installments of FOUR
HUNDRED TWENTY-THREE and 72/l00 ($423.72) DOLLARS, and
Mark E. Hilbert & Alloclates
'"~ No, 950101Gl
DEFINITION 9F MARK~ VALUE: The mo'l p'obebl. PliO' which. properly.~ bung In . comp.lun', Ind Opt" milke'
unci., aU caMillon. requisit. to. 'iii, ..... the bv.,., Ind ....er. tech ecllng pNd,ndv. ""twl~Qe"V.net '''UII'lIng the pilei i. not
,"Ielld by und~. .lImu6u.: ~Glt In u... d.I"'Itlon I. the OOnMtlMWllion 0' . .... II at . 'plcllied dill .nd 1M pI.Slng of tld, "om
,"111 10 bvy., und,' candiUoRl whtr.by: 11 I bu....r Ind .eII" If. typlollly mouvlled: 121 both parti.. '" w~ In'orfMd 01 w"lldvt.ed.
.net tech acting In whllt he oONld." hi: .w" bell lnl....l; 131 . f...oMlb6, time I' ".wld 10' Il.pOlUf' In the open ,,*,,'1; 14J paY'
rNnl I, rNd, In 'InN 01 Clth In U. So doll,,, 0' In ,,"'" 01 Iuulnclll "'lngtIMnl. Comptfeblt Ihe"tO: end 15) IhI plio. '.p"""f.
the nomwl con.ad,"tlon tor lhe p,optrty .okt unaff,cltd by .pecilll Of cr..lIve financing .. .... cone...ion.. gr.nlMl by anyone ."
..dlled with IhI .....
Ad,.,.UTMnl. 10 I~ cOlrCl.r.... mu'I 1M m4td. 'or .ped. Of cf..lln Ilne~ng or .... cone...iOM. No IdjU.lfMn,. .,. Mce...r;
lor lho.. co.l. wNch .,. nonnelly plld by...." .. . relUlI 01 Irldllion or I.w 'n . m.r\.. ....; ,~.. co.,. .re reldlly kI.nli'ilbl.
.inc. I~ .~I" P'Y' nl", CO.I. In ~rtu.uy "I ..... I"nllclion.. Ip.eI. or cr..lin finencJng IdfU'I""nl' c.n b. m4td, to the
COlrCl.,IbI. property by COlrCl"'fOn. to liNnc,ing t"",, otllfed by. third plftV 'netlluUonell,nd" lhell. nol Il".oy Invotwd In lhe
property 0' Iran..ction. Any edju.lmlnl .hou&d not 1M c..lNI.ted on , rntehenio.. dolt" ro, doH" CO'I 01 the llnaMlng 0' oone....on.
but the d~l" IfTWM,lnl of ,ny ldiu.lmInl .houkI epp,oaimel. I~ ""B...'. "lOlIon 10 the flMnclng 0' cone...ioN b..1d on the epp-
,1Ii..r'. tudgmenl.
.........._.It ..,
STATEMENT OF LIMITING CONDITIONS AND APPRAISER'S CERTIFICATION
CONTINGENT AND UMlnNO CONDlnONS: The IiPPf",,,', c.mlic,lIon thet eppe....ln lhe IPP'.... report I. tubteotto
the loIIowlng condlllo",:
1, The 'PIIr....r WIU nol b. "apaMibl. lor """'" of . IIQII nelu" Ihlt ''''CI .the, I~ property being IpPr...ed or the IICI. to il. The
'IIP'.,.r .."'",.. lhel the lid. I. good end """,.t~. ,nd. ther.for.. wliI nol rend" any oplnlONl about the till.. The property I. appo
r...ed on lhe b.... 01 " being under relpO~' OW","hIp.
2. The IPPf...r hi. provided I .hlch In lhe eppf... r~rt 10 .haw 'llProlUtnlit. dtmenaloM of t~ imprOYlfTMln... end IN tkllch I.
Included only 10 .."" lhe f.ld" ollhe feport In 'A~"Jlng the property.nd Und"ltendtng the epprlli.,,', dll.rmi",lIon 01111 Ii,..
3. The apprllil" hat ..wned lhe .v_abl. noad mIpI thet .... provided by lhe Fed".. lmergency Maneg.",.nt Agency lor ot~r d.t.
.ourc.I' .nd h.. noled In lhe eppr.... 'eport whither the tubtectlil. I. loc..ed In ,n Id.ntlfied Sped" Road Hlllrd Are.. Bec.....
IhI apprlil" I. nol . tufWVOr. he or lhe mek.. no gu.,.nt..., .ap".. or lmpIled. regarding thI. d.t.rmINlUon.
4. Th. .,pr....r w"l nol gin t.ltImony Of"''' 'n court b.c..... he or .hI med. ,n eppfllil" 01 thl P'op"ty in qu..llon. unl...
Ip'Citio "renge""nl. to do 110 hln IM.n mid, IMto"hand.
I. The .pprai.., hll ..tlrnaled IhI V"UI 01 IhII.net in thl co.t ",PfOICh It '" tight" .nd b..1 UII .nd th.lmp,on""nt. 11 thIi, con-
tributory vllu.. ThI.. ..p.,.... Vlllultione of thl land end lmprOvtrnlnl1 mu.t not 1M ulld In cOnjuncllon wl1h 'ny other wr... end
It.'nvlllid II they "' .0 Uled.
e. The Ippr....r hi. noted In the ~..... report MY ednr.. condrtion. lsuch... needed r.....". d..d.tion. lhe pre..ne. of hi,.,.
dCKlI WI"". loaio tubllane... I1c.1 ob..fYId during the Int,plction of the subject prop.rty Of IhlI hi Of .hllMc,,", .WII. 01 d..,ring
th. nolfNl rll'''ch Involved In p.rfonning the 'llPf..... UnI... olherwll' 1I.led 'n thlepprli... ''POrt. the eppr...r he. no know.
11d~ 01 .ny hickI.n or ul\IPPIl.nt conditiOtll 01 the property Of Idn". .nvirormenttl conditiCN'll (including thl pr...ne. of ht,lrdOU.
WIll... lolrio tubltlne... IIc.1 thel would mall. thl prop.rty more or I... vllu8bl.. .nd he. ..lUmed thll the" If' no It.lch condition.
Ind """'.. no gu.,.n.... or ""."....11... .ap".. or ~Id. 'qlfding the condillon 01 the pfOplrty. The .r.I" will nol tM rllpon-
Slbl. lor any lueh condillons thet do ,alII or lot any .nginuring or ...ting thet mlOht 1M "qulrlcl to ditcover whither .uch conditions
nill. how.. thlepPf..1f I, nol en 'Jq)lrtln IhllllkI ol.nvbotmln,1I halard.. IhI eppr.,1I "port mull nol b, COl\lldlled .. ,n
.nviroM'\lnl" .....lmInl of the property.
7. The; ..,pt..1f obl.ned thllnlOffMtlon. ..llfMt.., 'nd apinlo", thel wa" ,.p""1d In IhI 'llPr.,.. report I,orn .ourcII thlt he or
IhI con.id". 10 1M ,Mi~. end beIi...... them to tM lru. .nd conKt. The 8IlCIr...r do.. not ...ume re.poneibdity ror thllGCUflGY 01
I..,ch 11.",. thlt w." Iutflllhld by othlr p.rti...
8. The IPpr...r will not ClitclOIl the conllnt. or lheappr..... ''POrt ...cept II provided fat In the UNlorm SlInd,rd. 01 Prol...lonal
Appr.I" P"cUe..
e. The Ipprli..r hi. blled ti. or hlr 'Hr.." "port Ind v.u.tion condullon lo'.n 'PPf.... the. I. .ubject to 1I1I"lGtory comp-
Iltion. "p.re, or "tllllionl on the lleumpdon thet compl.tion 01 thllmprOYlmlnll wll b, performed In. wortmenlilr.. fnlnner.
10. The IPP""" mult provld. ti. or ~r prior wtinln co",.nt b.lo" thll.net,,/cli.nl .p.dlied In thlepprllll' report o.n dl.ltibut.
the ..,pr.I" "port (Including conclutloRl Ibout the p'operty ....... the 'Wr...r'. Idlntlty .nd prorltlionel d.lloneUant. Ind
"'"'ne.. to 'ny prolllllonll 'llPr.... orgenl,ltion. or t""irm with which thl ~rlli..r I. ...odlledl to Invon, olhlr then Ih.
bonowlI; th. mong.g.. or It I 'UCC'''O''lnet ....gnt: thl mortg'o.lnsurer: oo",ul1,nt.: pfol...lonel appr.... O'Olnlllllo",: Iny
Itll' or fed,,"'y approved finencl" lnatihdion: Of any depaftmlnt. egeney, Of' IRltf\IfMnl"ty of the Unltad SII... or .ny It'.. or thl
Dilujct 01 CoIumbi.; nc.pt thet the l.nder/eIMnt """ d1.lflbut. the property dllcrlption ..cllon 01 U,. IIpOrt only 10 d.11 coll,cllon or
llportlng "MceCI' Without having to obl.n the eppr...r', prior ""Iillln conllnl. 1M IPPr..,,', wlinln conunt end appro..... """"
1110 b. obllil\ld IMfofllhl eppr.." eM be conwYtld by '"YO'" 10 IhI publo Ilvough Idwttl"ng. public rll.llORl. new., ....., or
other medl'.
"ca.~,. llOlllJl.I...llll
..ct'_le. "",'tlt
._......_1004.."
Mark E. Hilbert &. Assoclatas
APPRAISER'S CERTIFICATION: The Appr..., urtll....m .gr... ttwl:
1. I hIi.... '....rched the .ubite. merlla. .f.' and I...... ..acled . mlnimwn of thr.. IIClnl ..... 01 proplrtl.. molt tlmll" and
proxlmalt to lhe aub)ecl prop.ny 'or DoMld.r.tion In 1M .... companion lnelysl. and he'lll rNd. . d~l.r .diu.tm.". when
approprlltl 10 ,tn.et the min.,. '.lOtion to tho..lt.mt of lillnmclnt \lafiatlon. II. lignlflce". II.m In I complrebll prop.ny I, luptr.
101 to, 01 mor. Inortbl. th.n, the tub}tc. prop."", I hive rMdl . ",gltivI edjultment to ,eduCt lhe .d1U'led ,II" price o' the compo
"tblt, and II . tignUie.ntll,", In I compallbl. ptoper1y 1,lnl,riot to, 01 I... t.vorlbl, U""'M .ubjlet property. I hlVI mad, . po.'
.ti.... Idjultment to 11101.... thlldiu"td ,el" pric, of the comp.,IbI,.
2. I htI.... ,...." Inlo oonlid.r.tion the 11G10" tMI hot.... an ImpICI on ValuI In my dawlopmtnl of the .,timllt 01 mllklt '1111"1 In 1M
tppl.... r.port. I have nol knowingly wllhMld any IigRllie.nllnlormaUon hom lhe appral." r.porl, .nd I beli.ve, 10 lhe b..l 01 my
knowledg.. lhel ... 1l.llNNnl. .nd InforTnlUon In lhe .ppr.N1 "pon "' IN' .nd eouKI.
3. I .t.ted In lhe appr.... "port only my own pel'Onal, unbl..Id, and plof...lonal .nalpi., opinion., .nd eonolulion., which ar. .ub-
leCI only 10 lhe eonllnoenl and IimIllng oondlllona ....dliad In lhi. lorm.
4. I heve no pr...nl or pro.pecllwInllll.1In lhe plop.rty lhal I. the lUbitOllO lhi. IIpon, .nd I hlv. no pr...nl 0' p,o.p.eUve per.
.onal Intt".1 0' tit.. with r..peello lhe panlclpanllln 1M 1I1N1C1I0n. I dad nol ball, elthe, p.n.lal1y 0' oompl.llly, my .n"p,
.nd/or lhe ..timat. ollNlrk'l v"u.ln lhe appflli... llpon on lhe flC', 0010', religion, .... hendiC8p, f.mU.. .1.lu., 01 nallon" origin
or IIIMr 1M pro.p.cll.... owne" Of oocup'III' 01 lhe ....bjlel propeny 01 olth. pllllnl OW".II 0' oocup.nl. of lhe prop.rtI11 In lhe
vicinity ollhl .ubleCI properlY.
IS. I Mv. no pr,"nl Of conl."...led luhU. inl"..lln lhe .ubitel prOJll'rly, and neilher my curllnl Of finulI "",,,oynMnl nor my
comp.nlltion for performing lhi. IPP'.'" i. conti.nl on the 'Wrlli.1d v"u, at lhe prOJll'l1y.
e. I w.. nol r.qulred 10 r.port. pred.l.rmlned ...""'. or dlr.ctlon In velu. IMII.Wllthe Caull 01 lhe di.nl 0' .ny rallied p.ny,
Ih. amounl ollhe v"u, ..lImIt., the .U.rwnenl at . .padlio f..utl, OIlhe occurr.ne. at . tubllqu.nl .venlln order 10 rectlve my
camp'M.llon 'nd/or ampIoymenllor p'rforming lhe '"'f..... I did nol b... lhe IPPrtl... "port on . "qu"lad minimum v"u.lion. .
.p.cifio v.u.tion. 01 the need 10 appro.... . .J!ftlfio mortgaga loan.
7. I p.rlonntd lhi. apprtllllln conformilY with the UnlfOlm St.ndard. 01 Prof,"iontl Appr..a1 Pr.clic. Ihll Wtl. edOPltd .nd plO<
mulg.led by lhe Appr.N1 allnd.rd. Bo.rd 01 The Appr.." Found.llon .nd Ihll WII' In plac. II 01 lhe .If.clive d.t. 01 thi. tpp,..t1,
with th. ..c.plion 01 lhe d.p.nuII provision 01 U\O" Sttndlld.. whioh do.. nol tppIy. I .cknowledg.lhel .n ..lImalt 01 . ,...on-
~. lime '01 ,.po.ullln IhI op.n mark'l I. . condllion In the d.lln1tion 01 ""rk.1 ...aIu. .nd the lllimal. I dav.loped I. conll.l.nl
wllh the mark.ting time notld in lhe neighborhood IIction of lhi. "pori, unl... I h..... othtlwi.. .t.led In lhe "concili,lIon ..clion.
8. I hav. p,"onally in.p.eled tht int.rIor and ..I.rior ar... olltlt ."b1-cl property.nd thl ..t.rio, 0' all propartiaati.led I' complr'
..,... In the apprlli.81rtport. I rurtMr c.rtily IMII h8w noted Iny appar,nl or known ed....,.. condillons In the .ubJ-ellmproWlMnla.
on lhe subjlel ..t',or on Iny tilt within lhe Immtdi,t. vlclnlly ollhe .ubJ,cl property 01 wNch I am IWllt and he.... mad. edJU.tmant.
lor tM" Ildvtllt. condiUon. in my .ntIV1i. Ollhl p'operIY ValUI 10 the 1...nIINII h*' merk.t .Wllnel 10 support lham. I "'.... a1'0
eomm.nted .boYllhe .1I.el ollhe adve'" condlllon. on lhe mark.tabdlly ollhl subjecl p'orerty.
9. I p.,.onelly prlpared aU conclullons Ind opil'llons eboullM ..a1 ..l.t. lhal w... ..llonh In Ih. 'Pilf.." Itport. If I relied on lig-
nifie.nt prol..lional ..till'nc. IIom.ny Individual ollndivlduall In tht performanc. 01 the IPpr.." Of IhI pltparatlon of Iht IIPPr.."
Itpon, I h..... named .uch IndlvldulU.1 Ind di.do.ed thl .pacilic Itlk. parformed by lham In lhe ..concili.tion ..clion ollhi. IPp,.,t1
repon. I c.rtily lhal .ny lndi'tidual '0 ,.-nad I. quelilied 10 perform the I..k.. I....... nol euthoriltd .nyone 10 mek. . chang. 10 .ny
It 11m In lhe Itpon: theltlolt. If In u""'thollled chang. I. mad. 10 the 'PPr..alltport. I willlak. no ...ponaibllity 10' il.
SUPERVISORY APPRAISER'S CERTIFICATION: II. auP'M'ory ,",f.'" tlgntd lhe app,..., report, hi o,.he c.nill.,
.nd ,ore.. lhal: I directly ""paM" the ,",I.'" who pI.ptled lhe appr.." report, hwt ".....wed lhe IPP'.'" 'eport, eo'" with
the tllttmtnl. and conclulions ollhe appl..tf, agll. 10 be bound by the Appl...". C.nlne.lloM numbeled 4 through '7 abow, .nd
.", tlklng luU r..ponlibillty lor thltppr.'t1 Ind IhI 'lIP'.'" 'eport.
ADDRESS OF PROPERTY APPRAISEO:
APPRAISER~: ~.. ~-L
$lgntIUI.:_ _ ~V_
N....: Kaf
Oil' Signed: Januarv 27 1995
Silt. Cennicltion No.: RL 0OO388..L
or St'l. UCln.. No.: RB~029755-A
Sill.: Penn.vlvanl.
Expiration D.t. 01 C.rtilictUon Of Uc.nll: 6/30/95
3790 Mounuln View Road. Mechanle.bunr.PA
SUPERVISORY APPRAISER lonly" "qul,,,,,:
Slgnatult:
Nama:
D.t. Signed:
Sll" C.rtilication No.:
0' Stitt UcaAle No.:
Statt:
E~lIlion D.t. 01 C'11I1ic.tlon 01 Uc.n..:
U o.d 0 Old NOlln.p.et IhI Plopeny
.._"'M'......II.U
MC..~TII'IOIIIJ1.I....nu
MC'f.,"~CI '...:t 1II:t
,_.........1004. ..u
. QUALIFICATIONS OF APPRAISER
.
Mark E. Hilbert. CRMA. ICA. GRI
Broker Appraiser
Educldon:
_1 Ilat.to Ponnoylvanla ntlo In........., Hard.burl
_1 IlItato Theot)' and Pr.ctlc.
_1 IlItato Law
_1 IlItato Hath
_1 IlItato Apprllall I
_1 l!atatl Advancld Apprll.ll
Standarda of Profo.llonal Prlctlco . Plrt A
Standarda of Prot.,.lanal Practice . Part B
Harkot l!atraction.
rannio Hal RaYlaw SDinar
Profuslonll Memberships Ind Dellgnedons:
Slnlor Hallhor - Intornational Oraani..tion of Iloal IlItato Apprllalra
American Frltlmity of RaIl l!atatl Apprli.orl
Oraduate ...1 l.tltl Inatltute
Candidato Apprllall Inatltuto
Harrbburl 10lrd of a..ltora
Pannaylvania Board of Ralltor.
Pennaylvanla Aliloclatlon of Ilultora
Hational Alloclation of _ltora
Pannaylvanla St.to COrtificltion Numhor - lL-000388L
experience:
C.K. Detwonor Rail Il.tatl Inc.
Harch 1971 to April 1976
Stuard Derrick Rad Il.tato Inc.
Apdl 1976 to OCtober 1981
1IE/IfAX Rallty Alloolat..
OCtober 1981 to robrult)' 1986
Hark I. HUbert 6 Ioo.oolat..
robrult)' 1986
Reel Estlte Licence: Mlrch 1971
Alloclete Broker: April 1978
Apprllslng since 1979
Appral311 experience:
Appra1aala for: ltrlt IDOrta.... ..cond IIOR&&II, equity loana, employ..
tranaflrl/rlloc.tlonJ. dllll. ludly. condo.
CUIIlberland. York. Dauphin .nd Parry Countla..
Completed AIIlgnments for:
Banb, Savina. and Loan_, HortalSI Broun, aelocatlan Companl... Trult
Departmentl and Attorney..
Client Lilt Iv'llable upon reque.t.
.
"',.L ..
l\fARITAL PROPERTY
I. REAL ESTATE
ITEM DESCRIPTION:
Cabin propcrty
Clinton County
OWNERSHIP:
Husband
Robcrt Hempt
Tim Lampree
Charles Durbeck
POSSESSOR:
Husband
Robert Hempt
Tim Lampree
Charles Durbeck
DATE ACQUIRED:
Approximately May, 1987
COST/ACQUISITION VALUE:
Unknown, information requested from Husband
DATE OF SEPARATION VALUE:
Unknown, information requested from Husband
PRESENT V AWE:
Unknown, information requested from Husband
NAME AND ADDRESS
OF ANY LIEN HOLDER:
None
EFFECTIVE DATE OF LIEN:
NATURE OF LIEN:
i
.
;
.
t
~.
r
.
~
f
PRESENT AMOUNT OF LIEN:
1
~
.
\
,
....<,'.,At
MARITAL PROPERTY
2. MOTOR VEHICLES
ITEM DESCRIPTION:
1991 Chevy Conversion Van
OWNERSHIP:
Husband & Wife
POSSESSOR:
Wife
DATE ACQUIRED:
Approximately 1991
COST/ACQUISITION VALUE:
Approximately $26,000
DATE OF SEPARATION VALUE:
Unknown
PRESENT VALUE:
Approximately $13,500.00; See attached.
NAME AND ADDRESS
OF ANY LIEN HOLDER:
None
EFFECTIVE DATE OF LIEN:
NATURE OF LIEN:
PRESENT AMOUNT OF LIEN:
. .
Lawrence
Chevrolet, GEO, Inc.
May 27, 1994
To Whom it May Concern:
Using the 1994 May NADA Book as a Guide, we have determined the
value of one 1991 Chevrolet Van, Vehicle Identification Number
1GBEG25X2M7100223 to be $13,500.
rS~':
\ nest Leo
'sales Manager
LAWRENCE CHEVROLET, GEO, INC.
--.- CHEVROLET
~ 6445 Carlisle Pike · Mechanlcsburg. PA 17055 · 717-766-0284
...1'
~~:':~':;';_~.~_~"'';.'"''N.~ :oi'#B
~';
..,,-
MARITAL PROPERTY
2, MOTOR VEHICLES
ITEM DESCRIPTION:
1981 Yugo
OWNERSHIP:
Husband
POSSESSOR:
Husband traded
DATE ACQUIRED:
Approximately 1992
COST/ACQUISITION VALUE:
Unknown
DATE OF SEPARATION VALUE:
Unknown
PRESENT VALUE:
Unknown, information requested from Husband
NAME AND ADDRESS
OF ANY LIEN HOLDER:
EFFECTIVE DATE OF LIEN:
NATURE OF LIEN:
PRESENT AMOUNT OF LIEN:
e.-o*"
..
" -.,
.'
MARITAL PROPERTY
f
2. MOTOR VEHICLES
I
I
,
,
I
ITEM DESCRIPTION:
1980 Suburban
,
I
I
i
OWNERSHIP:
Husband & Wife
POSSESSOR:
Wife (however, Husband has only keys)
DATE ACQUIRED:
Approximately 1988
COST/ACQUISITION VALUE:
Unknown
DATE OF SEPARATION VALUE:
Unknown
PRESENT VALUE:
Approximately $1,425.00 per NADA Official
Used Car Guide, See attached
NAME AND ADDRESS
OF ANY LIEN HOLDER:
None
EFFECTIVE DATE OF LIEN:
NATURE OF LIEN:
PRESENT AMOUNT OF LIEN:
.:- -.:o"'t'. .... ~~ "",.~..__,-." .,-': .
<< CHEVROLET 1981.80
.oar - 'ODr -
Tnf." TY,. N. MSJrI. ....' ~r"M" TV". N.
Il1S1 ClIlY1our.cooll"oI 8ao ClIEnOlET-ttoIl....
nl:AllIlO 11I1 1110 na....... CIb " CI. 17141
1171 _llcIliIL... . ....WIO 1110 1210 ""'" Cl,. Cab I' CI.
1211 -.It>tri ....WIO 7117 liD , 10' of 7....... ,.. ,.a.... r.p.. 7111
KID/II .WEI
'''1 11III, .....CII 8711 CHIYROLIT
:rOil IIIII'.IID...... .....11I lUll 4017
.10 'AlII rN .. ..... GtI 11114 1177 .110 """'.. .lI. 11171
"I ,...1.............. I:AIlIIO
'., IDa It>tri,......,,..... .......011 7441 1lO7 UI lodM ""'"
III en'...I..._...... ...".,011 IlOI lOll D1UIUZII ... . .......WIO 11m
1011 ...... .......".". .....".011 'III 1011 1100 1IlItz....... ....... ............CI'
.ra VAl 'II r.. 1111 1110~.1ID. ........ .. ....11I Iml
III ,...1............... ..........GlI 11711 OlAlII rN
110 It>tri't....... ..... ....GIC 7117 Ill' 110 ,.... .... ....... ........ .......011 11111
III 1eN,........... .. . .......,GIC '417 400 It>tri't..... .......
..........-. GIl III!
lOll ...... ......... ............... ......."...".GIC 11I7 411 ..... It>tri,.. .. ......011 7010
IU'UWlII,'11 r.. 'AI 'II T..
11'0 _CIO.,... ......ClI mn .171 ,no ,......... GlI 1110I
1111 Wutl.. elO..... ..........CH '771 .IH 400 It>tri't...
CIO "ClU' II TN 100 .-It>tri,.. ...GlI Ill!
1021 ""'" 111'......, .. ....Cl4 11011 1111 UIIQII-"TII ....011 7111
1010 ""'" ,'....,..... ... ............ .....,..Cl4 lOtS III' 1010_CI0.. .....ClI 16111
etO "ClU'" TII 1771 lno _.. CIO.. ....... . ..... ...CII 7011
lnl IlcIlc> ,....".......... .............. ....,...C14 l1lot I "ClU' II TII
1400 llcIup..... Glb ,. ._._.... .........CII 711I I'oa na.. Ill' .....,CII llOll
C3:~cM'l'Y.~" CIIl 1'..... ... ........CII IIZI '.n !\WjI,' ... ..CI. 1171
"ClU' 'II Tn
1110 IlcIlc> ................... ............. ......Cl4 Sllot 11I0 i~g na.. ::n.Cib' '.. ..............CI. 11777
lITI 1lcIlc>..... CIb ,. ........ ,........ ....,.,Cll 711I
lln IlcIlc> Cmr CIb 2...."."...................CJI 'm 1010 =Cl..CIIl ' .................CI. 1111
DoUt 10' of 7"..... V.. '" DIn.. r.p., . 10' of I,,"'~ ,..r", .1itUi'!nIiW" CI. Ill'
Il1S0 CHIYROLIT 'll ,rns CHIYROLIT '
lUV III
:rID llcIup................. ..........,114 SUIl 111I nO,' ,no IlcIlc> .......lI0 SIIII
n UIIIO .1Ii WIlla ..
1010 _llcIup...... .....WIO SIll! Illl "10 lodM ""'" ...11IO 11111
KIOIII.UZII I lWEI .
Ilia 1ItIt,... .... ,.....CII 1121 loaD UlIt,.. ... . .. ....CII
1110 ~ .IID..... ....."....11I III1J "I! 1100 UIIItIt,.1ID
110 VAl II Tn , II.' 'AlII TII .....110 11m
T no ,..1.... ... .. .. .... .................GtI S17" 1111 1.0 ,.... .... '.. ...,....011
R .,1 It>tri,............. ......"...GIl 1747 llll 410, 00 It>tri't.. llIDt
III 1If.....lt>tri,.. .........,GIl 7154 .101 I'I. ITI ._ si*i... ..011 141I
U 110 VII 'II TII 'Ai'll Tn . .. . .....011 IIH
:rll ,..... ............... .........G1S 11111 1711 110 ,.... .. ....GlI 11104
C III It>tri,.. ............ ...."..GIl 7011 lOll m ::-'..:: si*i;..
K .1I11f_lt>tri,... ........... ...........GIl 7171 4101 . .....,GlI 1711
IUIUI..1 11,'11 TN 11.'11 rll .. GlI 1111
S 1411 _CIO... ClI 17111 1144 loa -..CIO . .CIO
1111 WlcJtIInClO .... ..........CH Illl .1lS OTl _.. CIO . 11110
cia PlCIU' II T.. PlCIU' II rll CIO Illl
'11 PlcIuplll' ... CII mOl l60t TOO PlcIuplW .CIO
.00 PIdup" .C14 1110 1717 TII PlcIup" .. SUI'
CIO PIC.U' 'II TII PlC.u, 'II rll ... CIO 441l 1775
1000 PlcIup I' ..,C14 SllII - 0"""", ..CIO llOll .Ill
1D.l1I1T f~ll0W IllEA!!
JANUARY H U ApttlL "$ S!( T11l1el U'Jl~1 'AlE fOI fORI WH~!l DIIY! VAl
UAJtY HIIU palL "$
,
PRESENT VALUE:
Unknown; information requested from Husband
MARITAL PROPERTY
5, CHECKING ACCOUNT
ITEM DESCRIPTION:
Mellon Bank checking
OWNERSHIP:
Husband & Wife
POSSESSOR:
Husband closed approximately 5/94
DATE ACQUIRED:
During marriage
COST/ACQUISITION VALUE:
N/A
DATE OF SEPARATION VALUE:
Unknown; information requested from Husband
NAME AND ADDRESS
OF ANY LIEN HOLDER:
None
EFFECTIVE DATE OF LIEN:
NATURE OF LIEN:
PRESENT AMOUNT OF LIEN:
MARITAL PROPERTY
6, SAVINGS ACCOUNT
ITEM DESCRIPTION:
PSECU savings
OWNERSHIP:
Wife
POSSESSOR:
Wife
DATE ACQUIRED:
During marriage
COST/ACQUISITION VALUE:
N/A
DATE OF SEPARATION VALUE:
Approximately $210.89 See attached.
PRESENT VALUE:
Approximately $230.00
NAME AND ADDRESS
OF ANY LIEN HOLDER:
EFFECTIVE DATE OF LIEN:
NATURE OF LIEN:
PRESENT AMOUNT OF LIEN:
P'SEC. J..
.lf0~
STATEMENT OF ACCOUNT
PJQe
1
PENNSYLVANIA
STATE EMPLOYEES
CREDIT UNION
MAIN OFFICE:
1 CREDIT UNION PLACE
HARRISBURG, PA 17110-2990
MAILING ADDRESS:
P.O. BOX 1006
HARRISBURG, PA 1710S-1006
IRA CONTRIBUTIONLMAD~
OVER THE SST ARE FOR 1994
ONLY. TO MAKE 1993
CONTRIBUTIONS, CALL~SECU.
JOINT OWNERS
ACCOUNT NUMBER
0170384583
SOCIAL SECURITY _
170-38-4583
STATEMENT PERIOD
From i To
010194:0331 94
· ....AMOl./NT" FINANCE FINES.. . BALANCE
. '. . . '.. "'" ..;.' CHARGE I.. .
1",111,.,111""1,1"1,1,,,1,1,,,11,,1,11.,1,1,1,,1
CONNEE L HEMPT
3790 MOUNTAIN VIEW RD
MECHANICSBURG PA 17055-2128
0101
0121
0131
0228
0331
0331
'./.-- '." DESCRIPTION
...y....... ... .... ..... ". '.'
S1 - REGULAR SHARES
PREVIOUS BALANCE
REACTIVATE ACCOUNT
DIVIDEND
DIVIDEND
DIVIDEND
NEW BALANCE CURRENT RATE 3.00%
CURRENT ANNUAL YIELD 3.04%
00
52
47
54
20~36
20~36
20~88
21q35
21089
21C 89
'. .
'^""''''''O'' mrCTl"
01.11.:': .':OArI":
0101
0331
S4 - MONEY HANDLER / CHECKING
~EVIOUS BALANCE .
NEW 8ALANCE CURRENT RATE 2.00%
CURRENT ANNUAL YIELD 2.02%
00
00
'.
TAX Y AR 1993: REPORTED DIVIDENDS
6.71 ; TOT L F INM CE CHARGES
0.10
TOTAL DIVIDEND YEAR-TQ.DATE
lor all savings eAcepl IRA.
DIvIdends shown, If S10 or o~er. will
be reported 10 lhe Internal Revenue
ServIce for thiS calendar year.
1. 53
TOTAL FINANCE CHARGE YEAR- TO-OA TE
'or all loans.
0.00
NOTICE: See reverSe Side lor Important lRfOrmatlon.
'INDICA TES EFFECTIVE DATE
-
f......~__.<
MARITAL PROPERTY
6, SAVINGS ACCOUN'(
ITEM DESCRIPTION:
Mellon Bank savings
OWNERSHIP:
Husband & Wife
POSSESSOR:
Husband closed approximately 5/94
DATE ACQUIRED:
During marriage
COST/ACQUISITION VALUE:
N/A
DATE OF SEPARATION VALUE:
Unknown; information requested from Husband
PRESENT VALUE:
Unknown; information requested from Husband
NAME AND ADDRESS
OF ANY LIEN HOLDER:
None
EFFECTIVE DATE OF LIEN:
NATURE OF LIEN:
PRESENT AMOUNT OF LIEN:
r~~;':" .-!.. ,.;",,.-v~~;,l,-,
MARITAL PROPERTY
18, RETIREMENT PLANS
ITEM DESCRIPTION:
P A Blue Shield
VIP Plan
OWNERSHIP:
Wife
POSSESSOR:
Wife
DATE ACQUIRED:
During marriage
COST/ACQUISITION VALUE:
DATE OF SEPARATION VALUE:
· $24,659.62 See attached
PRESENT VALUE:
$ 31,214.76
NAME AND ADDRESS
OF ANY LIEN HOLDER:
None, presently
EFFECTIVE DATE OF LIEN:
NATURE OF LIEN:
PRESENT AMOUNT OF LIEN:
.
Outstanding loan balance at date of separation was $1005.06 thereby reducing
value to $23,654.56
]OD~
M_~I.j
.
PENNSYLVAN.IA BLUE SHIELD
VOLUNTARY INVESTMENT PLAN
SUMMAltY OF ACCOUNT
JANUARY 1, 199.. . MARCH 31, 100-.
CONNEE L HEMPT
3790 MOUNTAIN VIEW RD
MECHANICSBURG PA 17055
SOCIAL SECURITY NUMBER: 170-38-4583
\'
I
. , .
. ", .' .. .. ~', ..' ,"
CURRENT VALUE OF YOUR ACCOUNT ON MARCH 31, 1994 ...
IDS CASH MANAGEMENT FUND $ 486.21
MNGD INCOME FUND $ 19,754.12
89 GIC FUND $ 3,221.88
90 GIC FUND $ 911.77
IDS STOCK FUND, INC. $ 285.64
TOTAL OF ALL ACCOUNTS $ 24,659.62
OUTSTANDING LOAN BALANCE $ 1,005.06
CURRENT ACCOUNT STATUS
YOUR CURRENT PARTICIPATION IN THE PLAN IS AS FOLLOWS:
YOUR PRE-TAX CONTRIBUTION RATE IS 5.0%
YOUR AFTER-TAX CONTRIBUTION RATE IS 7.0%
YOUR COMPANY MATCHES 33% OF THE FIRST 6% YOU CONTRIBUTE.
""urthrr Il1rnrmnllnll nil nnrk
III
]OD~
M~'.II
.
PENNSYLVANIA. BLUE SHIELD
VOLUNTARY INVESTMENT PLAN
SUMMARY OF ACCOUNT
JANUARY 1, 1994 . MARCH 31, 199<&
PAGE 2
CONNEE L HEMPT
SOCIAL SECURITY NUMBER: 170-38-4583
INVESTMENT I.'lLEcrIONS FOR FUTURE CONTRIBUTIONS ..
'~, ,. ' . ','-.. ',...~t . 'L . ., ~.:;
~. 1;
IDS CASH i1ANAGEMENT FUND 0%
MNGD INCOME FUND 100%
89 GIC FUND 0%
90 GIC FUND 0%
IDS MUTUAL 0%
IDS STOCK FUND, INC. 0%
IDS NEW DIMENSIONS FUND, INC. 0%
ACCOUNT BY MONEY TYPE
CURRENT VALUE
VESTED PERCENT
100.00%
100.00%
100.00%
100.00%
VESTED VALUE
4,721. 77
7,283.50
7,766.26
4,888.09
24,659.62
EMPLOYEE DEFERRAL
POST 86 AFTER-TAX
PRE 87 AFTER-TAX
EMPLOYER MATCH
$
$
$
$
$
4,721.77
7,283.50
7,766.26
4,888.09
24,659.62
$
$
$
$
$
TOTALS
PRE 1987 NET AFTER TAX CONTRIBUTIONS $
POST 1986 NET AFTER TAX CONTRIBUTIONS $
2,209.53
8,501. 59
"'lIrlh.,.. 11Ifurl11Rllnn 4111 nnrk
[.;'..~.:, ".'. ......-
MARITAL PROPERTY
18, INDIVIDUAL RETIREMENT ACCOUNT
ITEM DESCRIPTION:
Dauphin Deposit Bank IRA
OWNERSHIP:
Husband
POSSESSOR:
Husband
DATE ACQUIRED:
Approximately 1980
COST/ACQUISITION VALUE:
N/A
DATE OF SEPARATION VALUE:
Unknown. information requested from Husband
PRESENT VALUE:
Unknown, information requested from Husband
NAME AND ADDRESS
OF ANY LIEN HOLDER:
EFFECTIVE DATE OF LIEN:
NATURE OF LIEN:
PRESENT AMOUNT OF LIEN:
MARITAL PROPERTY
18, RETIREMENT PLAN
ITEM DESCRIPTION:
Carolina Freight ESP
OWNERSHIP:
Husband
POSSESSOR:
Husband
DATE ACQUIRED:
During marriage
COST/ACQUISITION VALUE:
DATE OF SEPARATION VALUE:
Unknown, information requested from Husband
PRESENT VALUE:
Unknown, information requested from Husband
NAME AND ADDRESS
OF ANY LIEN HOLDER:
Unknown, information requested from Husband
EFFECTIVE DATE OF LIEN:
NATURE OF LIEN:
PRESENT AMOUNT OF LIEN:
. ,
MARITAL DEBTS AND LIABILITIES
.'.'
,.
t.
Defendant lists all marital debts and liabilities in which either or both spouses have
an interest individually or with any other person as of the date of separation:
,.
.,
MARITAL DEBTS AND LIABILITIES
ITEM DESCRIPTION:
Mortgagc on 3790 Mountain View Rd.
Mcchnnicsburg. P A
DATE OF INCURRING DEBT:
Approximately 1981
AMOUNT OF ORIGINAL DEBT:
Approximately $54,000
AMOUNT OF DEBT AT DATE
OF SEPARATION:
Approximately $35,099.88, See attached
AMOUNT OF CURRENT DEBT:
$31,749.87 as of2/1/95, See attached
PERIODIC PAYMENT:
$528.53 per month
DEBTOR:
Husband & Wife
CREDITOR:
Wilbur Raudebaugh
CURRENT PAYOR:
'I
Wifc (Wife has paid since the parties separated)
AMORTIZATION SCIIEDULE
;r
MICHAEL HEMPT
Beginning Balance - $ 43,562.11
Payment Amount - $ 528.53
,
,
:
Page 01
Annual Interest Rate - 8.000\
Initial Due Date - 08/01/91
Due Date Date Pd Chk No, Payment Interest Principal
........ .-....- #a$Tk ........- ----.-.-. .-.------
08/01/91 m" "'.53 290.41 238.12
09/01/91 , J$~ 528.53 288.83 239.70
10/01/91 -528.53 287.23 241.30
'11/01/91 '0 528.53 285.62 242.91
12/01/91 ::Js119 _528.53 284.00 244.53
I,' . ----------- ----------- -----------
~ AnnUal Totals 2,642.65 1,436.09 1,206.56
,. ,.' _mm.______. .---------- -----------
.
01/01/92 Jl 528.53 282.37 246.16
02/01/92 528.53 280.73 247.80
03/01/92 ' ~ 528.53 279.08 249.45
04/01/92 ~ OOOg; 528.53 277.41 251.12
05/01/92 1I!.""6~ft 528.53 275.74 252.79
06/01/92 528.53 274.05 254.48
07101/92 fI 528.53 272.36 256.17
08/01/92 ;' S 528.53 270.65 257.88
09/01/92 528.53 268.93 259.60
10/01/92 528.53 267.20 261.33
11/01/92 II- . 528.53 265.46 263.07
12/01/92, II ,~;~ 528.53 263.70 264.83
----------- ----------- -----------
Annual Totals 6,342.36 3,277.68 3,064.68
_=_=aac:u:::-=_= m_=a======= =====_=__a.
-_.~=:=~:=!
43,323.9S
43,084.25
42,842.95
42,600.0e
42,355.5~
42,109.39
,41,861.59
41,612.14
41,361.02
41,108.23
40,853.75
40,597.58
40,339.70
40,080.10
39,818.77
39,555.70
39,290.S7
01/01/93 ~ 528.53 261.94 266.59 39,024.28
02/01/93 '(}o 528.53 260.16 268.37 38,755.91
03/01/93 .,. ;) 528.53 258.37 270.16 38,485.75
.04/01/93 -= 528.53 256.57 271.96 ,38,213.79
05/01/93 528.53 254.76 273.77 37,940.02
06/01/93 528.53 ,.. 252.93 275.60 37,664.42
(17101/93 ~ 528.53 251.10 277.43 37,386.99
08/01/93 528.53 249.25 279.28 37,107.71
09/01/93 528.53 241.38 281.15 36,826.56
10/01/93 MiE 528.53 245.51 283.02 .36,543.54
11/01/93 o ( 528.53 ( 243,62 284.91 36,258.63
12-/01/93 .1 528.53 241.72 286.81 35,971. 82
----------- ----------- -----------
Annual Totals 6,342.36 ~3,023.31 3,319.05
-
======I:n==== =========== =======e==_ )
01/01/94 "41"'~ ~ 528.53 239.81 288.72 35,683.10
02/01/94 jaI..q -= 528.53 237,89 290.64 35,392.46
03/01/94 '3t.'l",ql.\ ~'oS' 528.53 235.95 292.58 35,099.88
04/01/94 528.53 234.00 294.53 34,805.35
05/01/94 528.53 232.04 296.49 34,508.86
. 06/01/94 528.53 230.06 298.47 34,210.39
:' .
. ..
'.
MARITAL DEBTS AND LIABILITIES
ITEM DESCRIPTION:
Personal Loan uscd to acquire van
DATE OF INCURRING DEBT:
Approximately 1991
AMOUNT OF ORIGINAL DEBT:
Approximately $15,000
AMOUNT OF DEBT AT DATE
OF SEPARATION:
Approximately $7,487.40; See Attached
AMOUNT OF CURRENT DEBT:
None
PERIODIC PAYMENT:
Paid in full
DEBTOR:
Husband & Wife
CREDITOR:
Dauphin Deposit Bank & Trust
CURRENT PAYOR:
Wire (Wifc paid sincc thc parties separated)
DEC-13-1994 14129 FR01 DALPHIN DEPOSIT
TO
92325775 p.el
~'W-.;'
, '
LS/2000 ACCUMULATED TRAN LIST 12-13 13:20:14 ~2/13.
BANK 001 BRANCH 0001 .PRODUCT DFLT VIEW 99 PAGE 12
LN T~PE 3 CLOSED
INT PRIN MIse 1 LOAN BALANCE
MISe 2 MI~e 3 MONETARY TOT INT AOJ
5150
ISSOC r APPL IL
lEMPT CONNEE L
PRoe DT SEQ
EFF DT TR A/F
. 0512g41 07 003
0512941 30 A
74.46-
278.15- .00
352.61
.00 ,00
.00
298.76- .00
352.61
DEse DOe
_ 0602941 07 004 10.96-
0602941 30 S
INTERNAL DESC ****
_ 0602941 07 005 53.85-
0802941 3~ A
DEse DOe
_ ,060AQA 1 ~., 006
0608941 29 900
_ 0713941 07 007 20.59-
"0713941 30 S
INTERNAL DESC t.**~
CHNG DATA PAYOFF EFF 0194213
.00 .00
,00
iUSTOMER 1374026 LOAN 9001 PART 0000000 DLR 00000 TYPE ** DATE 0000000
::::> _ PF10=STI.N* 11=POLN 12=STPS
7,467.40
.00000
7.487.40
.00000
7, 188.64
.0~000
~. b\'!.o\o,~
7 . 18tL 64
7,336.35
7.186.64 _
."'\:1"'00
. .
MARITAL DEBTS AND LIABILITIES
ITEM DESCRIPTION:
40lk Loan
DATE OF INCURRING DEBT:
During marriage
AMOUNT OF ORIGINAL DEBT:
$10,000.00
AMOUNT OF DEBT AT DATE
OF SEPARATION:
$1005.06, See attached
AMOUNT OF CURRENT DEBT:
$0
PERIODIC PAYMENT:
None. Paid in full
DEBTOR:
Wife
CREDITOR:
PA Blue Shield
CURRENT PAYOR:
Wife (Wifc paid since the parties separated)
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MARITAL DEBTS AND LIABILITIES
ITEM DESCRIPTION:
Discover Credit Card
DATE OF INCURRING DEBT:
Various
AMOUNT OF ORIGINAL DEBT:
Revolving debt
AMOUNT OF DEBT AT DATE
OF SEPARATION:
Unknown, information requested from Husband
AMOUNT OF CURRENT DEBT:
$0
PERIODIC PAYMENT:
None.
DEBTOR:
Husband & Wife
CREDITOR:
Discover Card
CURRENT PAYOR:
Paid from joint funds in checking account at
time of separation
NON-MARIT Ai. PROPERTY
Defendant lists all non-marital property in which either or both spouses have a
legal or equitable interest, individually or with any other person as of the date of
separation:
NON-MARITAL PROPERTY
ITEM DESCRIPTION:
Members First Credit Union Savings Account
OWNERSHIP:
Wife
POSSESSOR:
Wife
DATE ACQUIRED:
1/95, Post separation
COST/ACQUISITION VALUE:
N/A
PRESENT VALUE:
$25.00
NAME AND ADDRESS OF
ANY LIEN HOLDER:
None
EFFECTIVE DATE OF LIEN:
NATURE OF LIEN:
PRESENT AMOUNT OF LIEN:
BASIS CLAIMED FOR EXCLUSION
FROM MARITAL PROPERTY: Acquired post separation
!'
.
, l~.r',,~~..
f1 .-- -
L~;;'~ tD. .
NON-MARITAL PROPERTY
ITEM DESCRIPTION:
Members First Credit Union Checking Account
OWNERSHIP:
Wife
POSSESSOR:
Wife
DATE ACQUIRED:
1/95, Post separation
COST/ACQUISITION VALUE:
N/A
PRESENT VALUE:
$1000.00
NAME AND ADDRESS OF
ANY LIEN HOLDER:
None
EFFECTIVE DATE OF LIEN:
NATURE OF LIEN:
PRESENT AMOUNT OF LIEN:
BASIS CLAIMED FOR EXCLUSION
FROM MARITAL PROPERTY: Acquired post separation
. ,
NON-MARITAL PROPERTY
ITEM DESCRIPTION:
Commcrcc Bank Checking Account
OWNERSHIP:
Wirc
POSSESSOR:
Wife
DATE ACQUIRED:
Approximately 3/94, Post separation
COST/ACQUISITION VALUE:
N/A
PRESENT VALUE:
$800.00
NAME AND ADDRESS OF
ANY LIEN HOLDER:
None
EFFECTIVE DATE OF LIEN:
NATURE OF LIEN:
PRESENT AMOUNT OF LIEN:
BASIS CLAIMED FOR EXCLUSION
FROM MARITAL PROPERTY: Acquired post separation
';.._:-7_',~:. ~_.._.
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If.uri.hu'll. l'tnn')'~lIii", 1710H.{)flX9
.
,
(7171 2J2.2KI3
,.
CONNEE HEMPT,
Plainti IT
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 94-1994 CIVIL TERM
MICHAEL A. HEMPT,
Dcfcndant
: CIVIL ACTION - LAW
: IN DIVORCE
PLAINTIFF'S PRE-TRIAL STATEMENT
I. MARITAL AND NON-MARITAL: See Plaintill's Invcntory and
Appraisement.
II. EXPERT WITNESSES: None known as of this time.
III. NON-EXPERT WITNESSES: Nonc other than parties presently.
IV. ANTICIPATED EXHIBITS:
A. Documentation valuing Clinton County Cabin property
B. Documentation verifYing tradc-in allowancc on 1981 Yugo
C. Account statements vcrifying balanccs in Mellon Bank accounts
D. Account statements vcrifying balances in Dauphin Deposit Bank &
Trust Individual Retiremcnt Account
E. Account statcments verifying balances in Carolina Freight ESP
F. Account statemcnts vcrifying balanccs on Discovcr Card
PlaintilTreservcs thc right to introducc additional cxhibits as shc deems
appropriatc.
Respectfully Submitted,
,~
,
V. INCOME OF THE PARTIES: Sce Pluintill's Income and Expense
Statemcnt.
VI, INCOME AND EXPENSE STATEMENT: See Plaintill's Income and
Expense Statement.
VII. PENSION/RETIREMENT: There is no dispute between the parties as to
the division ofthcir respcctivc pcnsions.
VIII. COUNSEL FEES: PlaintilThus cxpended approximatcly $4371.50 in
eounsel fees and costs in thc pursuit of this mattcr. Sec attuched Exhibit "A: - copies of
billing statcments to date.
IX. PERSONALTY: PlaintilTdoes not believe there is a dispute over the
division of personal property.
X. MARITAL DEBTS: Sce the Marital Debts and Liabilities section of
Plaintill's Inventory and Appraiscment.
XI. PROPOSED RESOLUTION: PlaintilTis unable to propose a resolution
without the information that has been requested from Defendant's attorney.
Maria P. ognetti, uire
Supreme Court 10# 27914
132-134 Walnut Strect
P.O. Box 689
Harrisburg, P A 17108-0689
(717) 232-2103
Dated: Fcbruary 17, 1995
. . ~.,'.'-,,'''','' ;.-
, ,... ~,... .t~f'--
l.....................___,_-,_.,. it..c;.............
CERTIFICATE OF SERVICE
I, Maria P. Cognetti, Esquire, Attorney for PlaintilTherein, do hcreby eertiJy that
on this datc I served thc foregoing Plaintitl's Prc-Trial Statcment by depositing a true and
exact copy thereof in the Unitcd States mail, first class, postagc prepaid, addressed as
follows:
Samuel L. Andcs, Esquirc
ANDES, VAUGHN, & BANGS
525 North Twelfth Street
Lemoyne, PA 17043
ti~~.
Sup. Ct. J.D. #27914
132-134 Walnut Street
P.O. Box 689
Harrisburg, P A 17108-0689
(717) 232-2103
Dated: February 17, 1995
.
, f
1
i
r'
Li..;~.,
i~!:r~ ~
LAW OFFICES OF MARIA P. COGNETTI
132-134 Walnut Street
P.O. Box 689
Harrisburg, PA 17108-0689
(717) 232-2103
INVOICE #1394
February 1, 1995
CONNEE L. HEMPT
3790 MOUNTAIN VIEW ROAD
MECHANICSBURG PA 17055
Matter: 233
Jan 04/1995
Jan 05/1995
Jan 05/1995
Jan 09/1995
Jan 11/1995
Jan 13/1995
Jan 19/1995
Jan 23/1995
Jan 23/1995
Jan 24/1995
Jan 25/1995
Jan 26/1995
Jan 27/1995
Jan 31/1995
CLIENT # 217
MATTER # 233.
FOR PROFESSIONAL SERVICES RENDERED THROUGH JANUARY 31, 1995
RE: DOMESTIC RELATIONS
FEES
DOMESTIC RELATIONS
Telephone conference with client;
prepare for ~upport Conference; prepare
Income & Expense Statement
Telephone conference with Attorney
Multiple telephone calls with client;
telephone conference with Domestic
Relations Office
Review correspondence (2)
Preparation of petition for Alimony,
Alimony Pendente Lite and Counsel Fees;
preparation of petition for Master;
letter to Attorney; letter to
prothonotary
Telephone conference with client; letter
to Master
Multiple telephone conference with
Psychologist
Telephone conference with psychologist
Brief office conference with client
Telephone conference with psychologist;
telephone conference with Attorney
Telephone conference with client
Attend Custody Conciliation Conference
Review Income Statement
Review correspondence from Master and
Attorney
Total Fees and Disbursements
$B64.50
"U,
Invoice: 1394
Matter: 233
page
2
prior Balance
$7.00
Receipts/Retainer Applied to Prior Balance
Amount applied from Retainer This Invoice
TOTAL DUE
$7.00)
$0.00)
$864.50
NOTE - payment due within 30 days of invoice date. To ensure proper credit,
please include MATTER number on check. Payments received after date of
bill will not appear on this invoice.
LAW OFFICES OF MARIA P. COGNETTI
132-134 Walnut Street
P.O. Box 689
Harrisburg, PA 17108-0689
(717) 232-2103
INVOICE #1299
January 1, 1995
CONNEE L. HEMPT
3790 MOUNTAIN VIEW ROAD
MECHANICSBURG PA 17055
FEES
Matter: 233
Dec 05/1994
Dec 05/1994
Dec 06/1994
Dec 08/1994
Dec 12/1994
Dec 12/1994
Dec 16/1994
Dec 19/1994
Dec 19/1994
Dec 20/1994
Dec 20/1994
Dec 21/1994
Dec 22/1994
DISBURSEMENTS
Matter: 233
Jan 01/1995
CLIENT # 217
MATTER # 233
FOR PROFESSIONAL SERVICES RENDERED THROUGH DECEMBER 31, 1994
RE: DOMESTIC RELATIONS
DOMESTIC RELATIONS
Telephone conference with psychologist
Conference with client
Telephone conferences with Attorney
Telephone conference with client;
telephone conference with Attorney;
conference call with Attorney and
Custody Conciliator
Review correspondence
Telephone conference with client
Telephone conference with Attorney
Telephone conference with client
Telephone conference with Attorney;
telephone conference with Court
Telephone conference with client
Review documents from client; review
Court Order; telephone conference with
Attorney
Telephone conference with client
Letter to client
Fees This Invoice
$610.00
Fax Transmission Charges
4.00
DOMESTIC RELATIONS
Invoice: 1299
Matter: 233
page
2
$4.00
Disbursements This Invoice
Prior Balance
$614.00
$393.00
Total Fees and Disbursements
Receipts/Retainer Applied to Prior Balance
Amount applied from Retainer This Invoice
(
(
$393.00)
$607.00)
$7.00
TOTAL DUE
NOTE - payment due within 30 days of invoice date. To ensure proper credit,
please include MATTER number on check. Payments received after date of
bill will not appear on this invoice.
".'...'~."'"
'::"",:,:r,
LAW OFFICES OF MARIA P. COGNETTI
132-134 Walnut Street
P.O. Box 689
Harrisburg, PA 17108-0689
(717) 232-2103
INVOICE #1196
November 30, 1994
CONNEE L. HEMPT
3790 MOUNTAIN VIEW ROAD
MECHANICSBURG PA 17055
CLIENT # 217
MATTER # 233
FOR PROFESSIONAL SERVICES RENDERED THROUGH OCTOBER 31, 1994
RE: DOMESTIC RELATIONS
FEES
Matter: 233
Nov 07/1994
Nov 15/1994
Nov 15/1994
Nov 17/1994
Nov 22/1994
Nov 29/1994
DOMESTIC RELATIONS
Telephone conference with psychologist
Telephone conference with Custody
Conciliator
Telephone conference with client.
Review Custody Order.
Review correspondence.
Review correspondence.
Total Fees and Disbursements
$187.00
$206.00
Prior Balance
Receipts/Retainer Applied to Prior Balance
Amount applied from Retainer This Invoice
$0.00)
$0.00)
$393.00
TOTAL DUE
NOTE - Payment due within 30 days of invoice date. To ensure proper credit,
please include MATTER number on check. Payments received after date of
bill will not appear on this invoice.
LAW OFFICES OF MARIA P. COGNETTI
132-134 Walnut Street
P.O. Box 6B9
Harrisburg, PA 17108-0689
(717) 232-2103
INVOICE #1087
October 31, 1994
CONNEE L. HEMPT
3790 MOUNTAIN VIEW ROAD
MECHANICSBURG PA 17055
CLIENT # 217
MATTER # 233
FOR PROFESSIONAL SERVICES RENDERED THROUGH OCTOBER 31, 1994
RE: DOMESTIC RELATIONS
FEES
Matter: 233
Oct 25/1994
Oct 25/1994
Oct 28/1994
DOMESTIC RELATIONS
Conference with client
Letter to attorney
Attend Custody Conciliation Conference
Fees This Invoice
$735.00
DISBURSEMENTS
Matter: 233
Oct 31/1994
DOMESTIC RELATIONS
Disbursements This Invoice
$0.00
Total Fees and Disbursements
Prior Balance
$735.00
$0.00
Receipts/Retainer Applied to Prior Balance
Amount applied from Retainer This Invoice
(
(
$0.00)
$529.00)
$206.00
TOTAL DUE
NOTE - Payment due within 30 days of invoice date. To ensure proper credit,
please include MATTER number on check. Payments received after date of
bill will not appear on this invoice,
LAW OFFICES OF MARIA P. COGNETTI
132-134 Walnut Street
P.O. Box 689
Harrisburg, PA 1710B-0689
(717) 232-2103
INVOICE #979
September 30, 1994
CONNEE L. HEMPT
3790 MOUNTAIN VIEW ROAD
MECHANICSBURG PA 17055
CLIENT # 217
MATTER # 233
FOR PROFESSIONAL SERVICES RENDERED THROUGH SEPTEMBER 30, 1994
RE: DOMESTIC RELATIONS
FEES
Matter: 233
Aug 09/1994
Sep 06/1994
Sep 12/1994
Sep 16/1994
Sep 21/1994
Sep 23/1994
Sep 26/1994
DISBURSEMENTS
Matter: 233
Sep 30/1994
DOMESTIC RELATIONS
Telephone conference with client
Review correspondence
Telephone conference with client
Review correspondence
Review Conference Summary Report from
Custody Conciliator
Telephone conference with client
Telephone conference with client
Fees This Invoice
$222.00
DOMESTIC RELATIONS
Disbursements This Invoice
$0.00
Total Fees and Disbursements
$222.00
$0.00
Prior Balance
Receipts/Retainer Applied to Prior Balance
Amount applied from Retainer This Invoice
$0.00)
$222.00)
$0.00
TOTAL DUE
Invoice: 979
Matter: 233
Page
2
,
~J
t;4
I
1 NOTE - payment due within 30 days of invoice date. To ensure proper credit,
, please include MATTER number on check. payments received after date of
I bill will not appear on this invoice.
.
. .... ....._...~..-.'--, --.-....,.,.--
LAW OFFICES OF MARIA P. COGNETTI
132-134 Walnut Street
P.O. Box 689
Harrisburg, PA 17108-0689
(717) 232-2103
INVOICE #873
August 31, 1994
CONNEE L. HEMPT
3790 MOUNTAIN VIEW ROAD
MECHANICSBURG PA 17055
CLIENT # 217
MATTER # 233
FOR PROFESSIONAL SERVICES RENDERED THROUGH AUGUST 31, 1994
RE: DOMESTIC RELATIONS
FEES
Matter: 233
Aug 22/1994
Aug 26/1994
DOMESTIC RELATIONS
Telephone conference with client
Attend Custody Conciliation Conference
Fees This Invoice
$502.00
DISBURSEMENTS
Matter: 233
Aug 31/1994
DOMESTIC RELATIONS
Disbursements This Invoice
$0.00
Prior Balance
$502.00
$0.00
Total Fees and Disbursements
Receipts/Retainer Applied to Prior Balance
Amount applied from Retainer This Invoice
(
(
$0.00)
$502.00)
$0.00
TOTAL DUE
NOTE - Payment due within 30 days of invoice date. To ensure proper credit,
please include MATTER number on check. Payments received after date of
bill will not appear on this invoice.
LAW OFFICES OF MARIA P. COGNETTI
132-134 Walnut Street
P.O. Box 689
Harrisburg
(717) 232-2103
INVOICE 11765
July 31, 1994
CONNEE L. HEMPT
3790 MOUNTAIN VIEW ROAD
MECHANICSBURG PA 17055
CLIENT II 217
MATTER # 233
FOR PROFESSIONAL SERVICES RENDERED THROUGH JULY 31, 1994
RE: DOMESTIC RELATIONS
FEES
Matter: 233
Jul 05/1994
Jul 06/1994
Jul 07/1994
Jul 08/1994
Jul 12/1994
Jul 13/1994
Jul 13/1994
Jul 19/1994
Jul 19/1994
Jul 22/1994
Jul 22/1994
DISBURSEMENTS
Matter: 233
Jul 31/1994
DOMESTIC RELATIONS
Review correspondence; review Custody
Complaint
Telephone conference with client;
telephone conference with attorney
Telephone conference with client;
telephone conference with attorney
Review correspondence
Telephone conference with client
Telephone conference with client
Letter to attorney
Review correspondence; brief conference
with attorney
Telephone conference with client
Telephone conference with client
Letter to attorney
Fees This Invoice
$313.00
DOMESTIC RELATIONS
Disbursements This Invoice
$0.00
------------
Total Fees and Disbursements
$313.00
$0.00
Prior Balance
Invoice: 765
Matter: 233
Page
2
I"
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-~....,
.
Receipts/Retainer Applied to Prior Balance
Amount applied from Retainer This Invoice
(
(
$0.00)
$313.00)
$0.00
TOTAL DUE
NOTE - payment due within 30 days of invoice date. To ensure proper credit,
please include MATTER number on check. payments received after date of
bill will not appear on this invoice.
.~
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.
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LAW OFFICES OF HARIA P. COGNETTI
132-134 Walnut Street
P.O. Box 689
Harrisburg, PA 17108-0689
(717) 232-2103
INVOICE 1662
June 30, 1994
CONNEE L. HEMPT
3790 MOUNTAIN VIEW ROAD
MECHANICSBURG PA 17055
CLIENT # 217
MATTER 1 233
FOR PROFESSIONAL SERVICES RENDERED THROUGH JUNE 30, 1994
RE: DOMESTIC RELATIONS
FEES
Matter: 233
Jun 01/1994
Jun 23/1994
DOMESTIC RELATIONS
Telephone conference with client;
telephone conference with sutliff
Conference with client; letter to
attorney
Fees This Invoice
$262.50
DISBURSEMENTS
Matter: 233
Jun 30/1994
DOMESTIC RELATIONS
Disbursements This Invoice
$0.00
------------
Total Fees and Disbursements
$262.50
$0.00
Prior Balance
------------
Receipts/Retainer Applied to Prior Balance
Amount applied from Retainer This Invoice
$0.00)
$262.50)
$0.00
(
(
TOTAL DUE
NOTE - payment due within 30 days of invoice date. To ensure proper credit,
please include MATTER number on check. Payments received after date of
bill will not appear on this invoice.
(:.",0' _~''''''''~ ".' .............
1
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LAW OFFICES OF MARIA P. COGNETTI
132-134 Walnut Street
P.O. Box 689
Harrisburg, PA 17108-0689
(717) 232-2103
INVOICE #550
May 25, 1994
CONNEE L. HEMPT
3790 MOUNTAIN VIEW ROAD
MECHANICSBURG PA 17055
CLIENT # 217
MATTER # 233
FOR PROFESSIONAL SERVICES RENDERED THROUGH MAY 31, 1994
RE: DOMESTIC RELATIONS
FEES
May 02/1994 Review file; letter to attorney
May 05/1994 Review Real Estate Agreement
May 16/1994 Telephone conference with client; review
correspondence
May 25/1994 Telephone conference with Charles Stone;
telephone conference with client
May 27/1994 Review correspondence
May 27/1994 Conference with client
Fees This Invoice
$420.00
DISBURSEMENTS
May 31/1994
Disbursements This Invoice
$0.00
Total Fees and Disbursements
$420.00
$0.00
Prior Balance
Receipts/Retainer Applied to Prior Balance
Amount applied from Retainer This Invoice
$0.00)
$420.00)
$0.00
TOTAL DUE
NOTE - Payment due within 30 days of invoice date. To ensure proper credit,
please include MATTER number on check. Payments received after date of
bill will not appear on this invoice.
L- ~ .i'~":'" IJr~.~'
.
.
LAW OFFICES OF HARIA p, COGNETTI
132-134 Walnut Street
P.O. Box 689
Harrisburg, PA 17108-0689
(717) 232-2103
INVOICE #430
April 30, 1994
CONNEE L. HEMPT
3790 MOUNTAIN VIEW ROAD
MECHANICSBURG PA 17055
CLIENT # 217
MATTER # 233
FOR PROFESSIONAL SERVICES RENDERED THROUGH APRIL 30, 1994
RE: DOMESTIC RELATIONS
FEES
Matter: 233
Apr 20/1994
Apr 21/1994
Apr 29/1994
DOMESTIC RELATIONS
Initial client intake
Conference with client
Review documents from client
Fees This Invoice
$251. 50
DISBURSEMENTS
Matter: 233
Apr 30/1994
DOMESTIC RELATIONS
Disbursements This Invoice
$0.00
Total Fees and Disbursements
Prior Balance
$251.50
$0.00
Receipts/Retainer Applied to Prior Balance
Amount applied from Retainer This Invoice
(
(
$0.00)
$251.50)
$0.00
TOTAL DUE
NOTE - Payment due within 30 days of invoice date. To ensure proper credit,
please include MATTER number on check. Payments received after date of
bill will not appear on this invoice.
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RUBY D.WEEKS, ESQUIRE
TEN WEST HIGH STREET
CARLISLE PA 17013
717-243-1294
i
04/20/94
CONNEE HBMPT
3790 MOUNTAIN VIEW ROAD
MECHANICSBURG PA 17055
In reference tOI 5-94 DIVORCE
HrB/Rate
04/01/94 .5 divorce complaint and dictation
0.50
125.00/hr
0.10
125.00/hr
0.25
125.00/hr
0.20
125.00/hr
0.20
125.00/hr
0.10
125.00/hr
04/04/94 .1 dictation
I
"
"
;1
04/08/94 .2 FILE AND SERVE DIVORCE
.1 DICTATION
04/13/94 .2 FILE AFFIDAVIT OF SERVICE
;,
04/15/94 .1 PHONE CALL
.1 DICTATION
04/20/94 .1 DICTATION
:1
For professional services rendered
1.35
Additional charges:
04/08/94 CERTIFIED HAIL
(
(
04/08/94 NOTARY FEE
;:
,!
,
..tI;.,t,~
Amount:
62.50
12.50
31.25
25.00
25.00
12.50
$168.75
2.52
2.00
Balance Due
$0,00
..
CONNEE HEHPT
page 2
AMOUNT
Total Costs
$ 4.52
Total amount of this bill
$173.27
04/20/94 Retainer applied to Balance
Balonr:o Pc'r! r;? i-ull
ThQnlf Yout
($173.27)
Previous Balance of client funds
Payments made into client fund (April 7, 1994)
Payments made out of client funds
(Prothonotary-Filing Fees
Ruby D. Weeks, Attorney time
Connee Hempt - Refund of Retainer
New Balance of client funds
$297.50
250.00
195.50
173.27
178.73
$ 0.00
(
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RUBY D.WEEKS, ESQUIRE
TEN WEST HIGH STREBT
CARLISLE PA 17013
717-243-1294
CONNBB HEMPT
3790 MOUNTAIN VIEW ROAD
KBCHANICSBURG PA 17055
In reference tal 5-94 OIVORCE
03/11/94 1.5 CONFERENCE WITH CLIENT
For profe..ional .ervice. rendered
Additional chargesI
03/11/94 INITIAL INTERVIEW
Total costs
Total amount of this bill
03/31/94 Retainer applied to Balance
Balance due
,
,
CLYENT FUNDS ACTIVITY
'Balance of account
03/31/94 Retainer applied to Balance
TOTAL PAYMENTS MADE OUT OF CLIENT FUNDS
Hew balance of account
.~""._,
COPt'
03/31/94
Hrs/Rate
Amount
1.50
125.00/hr
187.50
----------
1.50
$187.50
15.00
$15.00
$202.50
($202.50)
$0.00
..............
$500.0C
(202.50)
($202.5C
$297.5C
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CONNBB HBMPT, ) IN THB COURT OF COHHON
Plaintiff ) PLEA8 OF CUMBBRLAND
) COUNTY, PBNN8YLVANIA
vs. )
) CIVIL ACTION - LAW I
) ,
MICHABL A. HBHPT, ) NO. 94-1778 CIVIL TBRM -(
Defendant )
DBl'IlNDAN'l"8 PRB-'lRIAL 8TATmmNT
AND NOW COMes the above-named Defendant. by his attorneys, Andes, Vaughn & Bangs,
and submits the following Pre-Trial statement pursuant to Par R.C.P. 1920.33(b):
1. A8BBTB. Attached hereto and marked as Bxhibit A is a chart listing the
marital and non-marital assets of the parties as they are presently known to the
Defendant.
2. BXPBRT WITNBB8B8. At this time the Defendant intends to call the following
expert witnesses:
A. Don Paul Shearer, a real estate appraiser, who will testify about
the value of the marital residence.
B. An appraiser of household furnishings and goods who will testify
about the value of the marital furnishings.
The Defendant reserves the right to call such additional experts as may be necessary to
respond to evidence submitted by Plaintiff in her case in chief.
3. FACT WITNB88BS. Defendant intends to call the following fact witnesses:
A. The Defendant himself to testify about all matters relating to the
assets of the parties. the breakup of the marriage, and the factors listed in
the Divorce Code.
"
1
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B. Jeffrey Stubblefield, a man sexually involved witb the Plaintiff,
who will be called as a hostile witness to establish the Plaintiff's
misconduct.
The Defendant reserves the right to call such additional fact witnesses as may be
necessary to respond to evidence submitted by Plaintiff in her case in chief.
4. BXHIBITS. The exhibits to be produced by the Defendant will consist of copies
of statements showing b3lances in various bank accounts, IRA's, and employment benefit
plans, an appraisal of the house, and tax returns of the parties. All of those
documents have previously been exchanged with counsel for the Plaintiff. In addition,
the Defendant reserves the right to offer into testimony such additional exhibits as
may be necessary to respond to evidence offered by the Plaintiff in her case in chief.
5. INCOHB. Tbe Defendant is employed by Carolina Freigbt Carriers Corp. as a
dock worker. His gross wages for 1994 were $37,915.72, as confirmed by tbe copy of his
1994 W-2 statement wbich is attacbed as Exbibit B. Also attacbed and marked as Exhibit
C is a copy of bis most recent paycbeck stub showing his gross pay for a one week
period to be $559.36 and bis net pay for tbat week to be $349.96. Finally, attacbed
bereto and marked as Bxbibit D is a copy of bis 1993 federal income tax return.
6.
BXPBNBBS.
Tbe Defendant bas recently been temporarily relocated to tbe
I
I Philadelphia, Pennsylvania, area as a result of a disputed job transfer. He has not
II lived there long enough, as yet, to establisb his actual living expenses. An accurate
I statement of his expenses will be prepared and submitted at tbe bearing in this matter.
I 7. RBTIRBKBNT BBNBFITS. At tbe present time tbe parties have agreed to exclude
I from the equitable distribution portion of this case the values of their pension plans,
i the Defendant's with tbe Teamsters Union and tbe Plaintiff's with Blue Sbield.
,
,
,
2
Accordingly, there will be no information at the hearing sub.itted about pension
valuation.
8. COUNSEL PEBS. Defendant has made no claim for counsel fees in this matter,
but reserves the right to submit information about the expenses he has incurred in the
litigation of this matter in response to any claim for counsel fees by the Plaintiff.
,
9. HAlITAL DBSTS. The marital debts known to the Defendant are listed on Bxhibit A.t
10. PRRBONAL PROPERTY. Defendant believes the parties will have divided their
personal property by the time of the hearing. Defendant reserves the right to produce
evidence at the hearing about the valuation of personal property in the event this
issue is not resolved by the date of the hearing or in response to Plaintiff's case in
chief.
11. PROPOSED RESOLUTION. The Defendant proposes that he retain his individual
retirement account, his BSOP with Carolina Preight, and his interest in a hunting cabin
he owns with his brother. that the Plaintiff retain her VIP account with Pennsylvania
Blue Shield and the van she drives. The house will then be sold and the proceeds
divided equally between the parties or the Defendaat proposes that Plaintiff acquire
his interest in the equity in the house for a cash payment of $55,000.00. The
Defendant proposes there be no award of alimony or counsel fees because the inco.es of
the parties are substantially the same.
ANDBS. VAUGHN & BANGS
By
~.~
a el L. Andes
Attorney for Defendant
3
BlBIBIT A = LIST OP ASSB'rlI
ltAI.I'l'AL PIOPBlTY
Asset
Value
Date of
Valuation
Residence at 3790
Hountain View Road,
Hechanicsburg, PA
$120,000.00
3/94
Non-Harital
Portion
Liens
None
830,000.00*
*Balance due on install.ent sales agree.ent owed to Willia.
Radabaugh having a principal balance as of Dece~er, 1994,
of approxi.ately $30,000.00.
Defendant's Exhtblt
Pr
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505 3RD STREEl'
NEW CUMBERLAND PA 17070
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MICHAEL A HEMPT
505 3RD STREET
NEW CUMBERLAND PA 17070
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CARRIERS CORP.
PO SOX 697
CHERRYVILLE NC 28021
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CARRIERS CORP.
PO BOX 697
CHERRYVILLE NC 28021
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505 JRD STREET
NEW CUMDERL^ND PA 17070
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r.~ I I .' . ,\. It '0 11 !..oil.';,;
fll,-;!!l ~ j ,,., :'.1'",
"1111 tt' ,'...1:' ;'.1
~;Dlo1;' O.nl 4.43
rill.,;. 15.6G 11;!,O!i
CARL. l'.x 10,00
ESP 401 K 27,97 201.52
NATIONAL DR 1.00 6,00
UNION DUES 36,00 72,00
:'i(}Ll.11 :~"I" ,!~' fl'jllllll'( 1;'\;1111" '.1.uII,J1 :;loIlu:;
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SICK
WORK
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17,4800
32,00
659,38
21lJ.72
3,333,50
.,'
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,.~...."..............~.........';',...,...;..~...,.....,t......~".....-........"": ....1'....,............../.......'.... ~"....' '.''''' ...."'.. ...9_....... ............-""'..;;;L.......". ...~~,..~....,.....
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'. '-,,~;,:.:?,,:}:....> ~~.~~:~~.~:..::.;.:~i:~;~.. -~. '=~'~~"'''::::-''''";'~'''~$S59i:'';'. .....5531.39 .:-...' '.'1144.43 ~.;;..~::~..ft7~;...i..~~......ft '?~:
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.
. ~t of the Tr...wry.-lnl.,nal R,v.nue S.l'\IIo.
u.s. Indlvldu811ncome T8X Return
FOt tho 1'01' Jon, 1-!loc, 31. 1893, or olhe, Iu yl., bolllMlng
Your fnt name and initIal L.llt n.me
(21 IRS U.. On/,-Oo /lgl ",,',II 01 II.p:,I" 11'''1 'Pitt
. 1993. un(Mg '9 OMS N(.j '5.a~.OQ'4
YOu' IU"tll "f.Urny numb.,
Slngl.
Manted flllng Jolnllllurn (.v.n If only one had Incomo)
MIITlId NIng H\lIIItl ilIum, Ent., opouN'l soclellOcurtly no. lOO,e and lull neme here, ~
Head 0' hou..hold (wIth Quolltylng pellon), (See pageI3,) IIlhe Qualllylng pe,eon IS 0 Child .JI not you, dep.noenl.
enler Ihll Chlld'e neme here, ~
Quell I wldowe with de andent child ear souse diod ~ 19 , Soo pa e 13.)
liD YourMII. II your paront (or lomoono oliO) can claim you as . dopendonl on hiS 01 he, lax N, " b'...
, IItum. do not check box 8., Sut be lUll to chock the box on IIno 33b on paga 2, ,h"S.I " 10
.'1 Ib
8 u... . . . . . No. 01 your
Depend.nll: .g. I or or.", 'hlllron " I'
d'Ptnd.nt'llocllllltuflfy ..
(1) Him, (11111. Imual. and Iall nlm.) numb r WIIO: ' LJ
. lI..d wllh IOU -L
. III,'t II.. wllh
IOU luo I'
dlnfnor
IOplIIlI,o(II'
PII.,11
O.p.ol.,,, "I'
.nol.nltr.dlboVl_
All numbon
,nl'rld on
IInn.bOYI II>
1
I
'-'i.
d If your child dldn11iv1 with you but II cl.lmed U your d.ptndinl under a pre.1985 agre.m.nl, ChlCS h". ~ 0
. Total number of ax om tlons claimed , , . , , , , , , ,
~@93
"
Label
~tNctIonI
on pego12.)
U.. till IRI
Ialbe1.
OthIrwI...
pIMH prtnt
or type.
P,uldlntlll
. Ellctlon Clmpllgn
SIt .,2,
Do you went $3 to go to lhll tund?, , , , . , ,
If a Inll1tum, dOli our I u.. want $3 to 0 to Ihls fund? .
L
A
a
.
L
H
.
R
.
...... CAR-RT-SORT**RR20
JI 202-46-5574 170-38-4583 S28 20
HICHAEL A & CONNEE L HEHPT
~790 HOUNTAINVIEW ~D
HECHANICSBURG PA
I
001
I
R ApI. no.
S
17055
12,
r
.
f',
Income
Attach
Copy B of your
Porme W.2,
W.20, and
l080-R hire.
If you did not
gll . W.2. _
peg. 10,
,.
811
b
II
10
11
12
13
14
15
151
17a
15
111
20
21a
22
23
ll4a
b
25
ze
2'
25
2lI
30
W.glS. laiII1el, tlpt. olc, Anoch Form(l) W-2 , , , , , , ,
Taxabl. InterlStlncom. (I" pago 18), An.ch SchOdulo B II ove, $400
Tax...empt Inlllllt (IN pago 17), DON'T Includo on IInl 8al 8b I
DIvtd.nd Incom., An.ch Schedull B " over $400 , , , , , ,
TlXIbll retundl, crldlll. or oNsotl of Itlt. and local income taxos (seo pago 17)
Alimony recolved , , , , , , , , . , ,
BUllnosa Incomo or (lOSS), Anach SChedule C 0' C.EZ , , ,
Clp/la1 gain or (Iosa), Anach 6chedula 0 , , . , , , ,
C.pltal gain distributions not reported on linl 13 (se. page 171
Other galnl or Qo..os), AUach Form 4797, , , , , , , , , , , , , ,
T01a1IRA dlltrlbutlonl, ~ U b Taxaolo amount ('H pagl 18)
Tglll plnslon. and 10nulUII l.1z!J U b TUOOII omount (SH plgo 18)
Ronl.1 realestato. roy.ltlos, partnerships, S co,poraUons, trUSlS, elc, Attach Schodula E
Ferm Incom. 0' (loss), Anach SChodule F , , , , , , , , , , ,
Un.mploymont componsatlon (sao pago 19) , , , , , , , , . , , , ,
Social IlCIJrlty bOllotlts I 21. I I I b To,a.'o amounl (.oa paga 19)
Other Incomo, Wit type and amount-see pago 20 ............................ ,...,..,
Add tha amounls In th,'a,,1 ht column for IinlS 7 throu h 22, This " outlotallncomo ~
Your IRA deduction (_ PIQI 20) , . , . 24a
Spou.... IRA deduction (see page 201, , , , , , 24b
Ono.ha" 0' lo".employment tax (see pago 21) 25
SIl'.employed health lnouranco deducUon (sae page 221 28
Keogh retlllroont pl.n and soll,omployed SEP doductlon 27
P.n.lly on early wlthdrew.1 01 ..vlngl, , , , " 28
AlImony paid, Recipient's SSN ~ 28
Add IInol 24a Ihrou h 28, These are OUI total ad ullmentl , ~
btract Ilnl 30 rom IInl 23. I, II your IdJUlted groll Inooml. If th" .movnt is leu than
123,050 and a child lIved with you. lee NQe EIC. f to fmrJ out If yOu can C'a,m the -E'rnea
Income Cr.dW on Ime 6 . , .
II you art
anachlng .
check or money
order. put It on
top ot any
Forml W'2.
W.2G. or
10GG-R,
Adjustments
10 Income
(SIt pegl 20,)
eal. No, "3~08
SPO\.lIO'1 loclll"cU'lty nl,lmbt'
For Privacy Act and
Paparwork Reduction
Act Notlca. aaa paga 4,
VI' No Not.: Checkmg "(OS'
X will nor enllng' yO"
rIA 0' 'oduce '(O!/I
I 'o'uro
J
",",
I~
.t
7
~ --.--..-.-.
10 I ----- L .
~1' ,
_n t-----
:~ _-- - '._~ :-.1
. 14
r:!r---"" .. r-
I --..... t-
18b ! .. ____ _
17b
18 ,
..._.J
I,
30
31
';;5'; 18
Form 1040 (199)'
Ponnl040C1I1Q'",.HeM ", :I~::",!;;, ,"
,II "Amount !rom line 31 (adJuiled groal Incoml) '. , , . , " ,
Nt! Chec:k II: 0 You __ e5 01' older, 0 Blind; 0 8pou.. WII 55 or older, 0 Blind,
Add lhe number 01 bo... checked lbe" and anI" Ihl 10lal horl ~ 33a
b If your perent (or lomeonl 1111) Cln clllm you.. I dlpendenl, Chock hore ~ 33b
o If you .,. mllTted nllng ..parltlly and your IpOUII IIlmll.. dlducllonl or
you lit a dual-atalua allen, ... pag. 24 and check her., , . , " . 330
, , IWmlud deduollona Irom Schedul. A. IIn. 28, OR
Menter' ltanclanl deduoUon Ihown b.low lor your IllIng Ilalul, But II you ch.ck.d
the IlIIY box on IIn. Nt! or b, go 10 pig. 24 10 nnd your Ilandard deduction,
~ II you chacked box 330, your Ilandaro deduction II zero,
. Slngla-$3,700 . Head 01 houlahold-$5,450
your. . Marned nllng Jolnlly or Qualilylng wldow(erH5,200
. Mantad nllng IIparallly-$3,l00
Submtline34tromllne32 I . . . . . . . . . .
To
Compu-
tation
(SM page
23,)
If YOll want
tMIRSto
figure your
tax, ...
page 24.
Credits
~page
Other
Texe.
Payments
Attach
Forml W.2,
W.2G.. and
1099." on
the llonL
Refund or
Amount
You Owe
Sign
Here
Koap a copy
ollhla ratum
lor your
recorda.
Paid
Pre parer's
Use Only
..----
If line 321a $81,350 or leu, mulllply $2,350 by th.lotal'numb" 01 a.emptlonl clalmed on
line ea. If Iln. 32 II over $81,350, II' Ih. wot1<lh..1 on page 25 lor Ihl amounllo Inler ,
Taxable I1I00me, Sublract IIn. 38 from IIn. 35, If line 38 II more Ihln IInl 35, .nler .0- ,
Tax. Check If lrom a t!!ot Tax Tabll, b 0 Tax RaIl SChldulel, 0 0 SChldule 0 Tax Work,
_t, or dO Form 8815 (III pagl 25), Amounllrom Form(.) 8814 ~ I I
38 Addlllonal tax.. (1M page 25). Check If from a 0 Form 4970 b 0 Form 4972
40 Add IIn.. 38 and 39. ,. ,'.'"", ""
41 CradIlIor child and dtpandant care ..pans.., Attach Form 2441 41
42 Creelll 101' the Ildlrty or thl dllllblld, Anach Schedul. R" 42
43 Foreign lax credll, Attach Form 1118 . , , . , " 43
44 Other credlla (a.. pagl 28), Chick If ,rom a 0 Form 3800
b 0 Form 8398 0 0 Form 8801 d 0 Form (.peclly) _' 44
45 Add linea 411hrough 44 . . . , , , . . , , ,
45 Subtract IIn. 45 Irom IIn. 40, If line 45 la more than line 40, Inler .0. ,
. 47 8aIf-employmar1t tax, Attach Schedull SE, A110, HI line 25, , , .
45 Alternatlv. minimum tax, Attach Form 8251 , , , , , , , , , , . . . ,
41 Rectpture tax" (III P1Q128), Check II from I 0 Form 4255 b 0 FOlm 8811 cO Form 8828
80 Social lICunly and Medlcarllax on lip Income not rapened 10 amploye', Anech FOlm 4137
81 Tax on qualllled retlremlnt plln., Including IRAt, If required, Inlch Form 5329 ,
82 Advance larned Income credll paymenll Irom Form W.2 ,
83 Add llnel 48 Ihrou h 52, Thll It our total tax . , , , ,
114 FtdIrIllncome tu withheld, If Iny I. I,om Form(.) 1099, chIck. 0
lIS 1983l1t1mated lax paymenlt II1d amounllpplltd from 1992 lelurn ,
lIS lamed Income oNeIlL Attach Schedule EIC , , , , ,
87 Amount paid wllh Form 4888 (1.lInllon requ..I), , ,
ll8a Exc... 1ll(i11 IICVtlty, Mldlca", Ind RRTA III """"lid (SII pig I 211 '
b 0aftrTaJ of Iddltlonoll983Iax", Attach Form 8841 , , , ,
III Other paymentt (III page 28), Check II lrom a 0 Form 2439
b 0 Foml 4130. . . .. . . , , . . . " 59
80 Add 11_ 54 thro h 59, The.. Ire our total entl , , , , ,
81 Kline 80 It mort thin line 63, IUbtrect IIn. 63 from IIn. 80, ThllII Ih. amounl you OVERPAID.
82 Amount 01 IIn. 61 you wanl REFUNDED TO YOU, , , " ,',"
83 Amount of IIn. 61 you Wlnl APPLIED TO YOUR 1884 ESTIMATED TAX ~ 83
114 IllIna 631. mora than IIn. eo, IUblreclllne eo from line 53, Thll II Iha AMOUNT YOU OWE,
For d.taIl1 on how to pey. Including whit to writ. on your paym.nl, s.. p.g. 29 , , ,
lIS EaUmated tax a ... I 29 , A110 Include on IIna 84 85 ~
Under ptI\ItdM 01 PI"I~.I decllfW thall have ..amined tnll rllum and 8CCOmpln)llng schedules and ,tatements. and 10 1he best of my knowltGO' afld
btUef. they.. true. conwc:t. and ClOmp6tt.. OedarlUon 01 pr'PI111 (other '''an taxpayerl's based on .lIlnform'llon of which pttplrer has any knowleage
~ Your I9\iture Oat, Your OCC\,lplhon
, lc. ore:r
~_r.sl"
:--
--
=1
II
all
.'
~
lIS
at
.
36
37
lIS
38
37
~
~
48
48
47
48
49
50
51
52
53
~
114
55
66
57
66.
6Ilb
o
8p0u0e'1 Ilgnelure, V I /OlIlt ..Iurn, BOTH mUlllign,
Oa'l
spou.... OCCup.hon
C.ler k..
"'-'I~
lignetura ,
FInn'I naml (or \'OUf1 ~
II ,,"-employed) II1d
0dd1'Oll
Oa11
3 - -
Cneck II
ItIt.tmplOyea 0
...
-
j: ~ ~'~."_'" ~'t
. 1 -,~. .
,
fI.,..r
. ..
,
.5'1
;3;0
.. ~'-
. --
7;;'("
--+,-
,',
Schedule A-Itemized Deductions
.
OMB No 16.6.CJ14
,I
SCHEDULES A&B
l1'0fI!I1040), .
(SchedullS lion 'bock)
.. Attach to Form t04O, .. S.. InllNctlonl tor Schldul.. A Ind B Form 1040),
~@93
-"'...y....., -
--- ..,
NMlIlIl- on Form lIMO
, .
Add IIneB 19 end 20 . , , , , , , , , ,
Enter amount from Form 1().40, Itne 32. 22
Mulllply line 22 above by 2% (,02) , , , , , . ,
Subtraclllne 23 from line 2', II zero or less enter .0. , , , , , ... 24 i
~~.~-:-:~~~,~I~,I.~~.:.~~~.~..~,..~I,~t, ,~:.~,~~~..~~~,~~~"~.:::::::: ::::: ::: :::: :::::: ::~ "
2e Is Ihe amounl on Form '040, line 32, more than $'08,450 I",ore than $54,225 if
married filing seperately)?
I NO, Your deduction is nOllimlled, Add lines 4, 8, 12, 16, , 7, 18.24, and 25 }
and enter Ihe lotal here, Also enter on Form' 040, line 34, the larger of thIS
amounl or your Ilandard deduction,
I YES. Your deduction me be limited, See a e A.5 for the amount to enter,
For PeperWork Ileduotlon Act Nalla, _ Form '040 InllNotlonl. CII No 1I330X
Medical
and
Dental
ExpenHa
Taxea You
Paid
(SH
pegI M.)
Interelt
You Paid
(SH
pogl A.2.)
,
NoIII
PnonaI
1n1_11s
nol
deductible.
Gifts to
Charity
(SH
PIllI A-3,)
Casually and
Theil Loues 17
Moving
Ex nail lS
Job Expen..s 18
and Moat
Olher
Miscellaneous
Oaductlons ' 20
(SH
PIllI A.S for
Ixpen... 10
deduct hire,)
21
22
23
24
Olher 25
Mlscallaneoua
Deductions
Total
Itemized
Deductlona
o~~ec
elutlon: Do nol include expenses relmoursed or paid Or other~.
1 Medical end dental expenael (see pege A.') ,
2 Enter amount 110m Form 1040, line 32, 2
3 Multiply line 2 ebove by 7,5% (,075), , , , , ,
4 Subtract line 3 from line', If zero or less enler .0. ,
5 Slale and local Income laxes
OReal eltale laxes (lee page A.2) .
7 ~~.r.~~~~:.~~p'~n~~~~~~ t~::~t .Ql.te.~~. ,I~~~.,~,
8 Add IInel 5 Ihrou h 7 ,
IIa Homl mortgage Interest and points reported to you on Form 1098
b Home mOf1gage Int_t not reported to you on Form '098, II paid
10 lhe pmonlrom whom you bought the home, lee page A.3
and lhow thl1 person's name, identifying no,. and address ..
....~jJ,bt:t..,fl."Q.\J.~k~.~",~"',......,' ......'"",..,..'
.... ails' .Wl( r YiAl'.. nr.... /!I, ~.~\ !.'IIIiA~! ,.. ,l Jj, ,{ 7P.$!
8b
....~........ ....... ... ....... ............. ...............0.....
10 .Polnte not 'reported 10 you on Form 1098, See page A.3
forapeclal rules. , . . . , , . . . :
11 Inveslmenllnlerell. If required, attach Form 4952, (See
page A.3,)
12 Add lines 9a Ihrou h " ,
C.utlon: If you made a charilabla contr/burion end
received. beneflt /n rerum, see page A.3.
13 Contrlbutlone by clSh or check'
14 Other Ihan by caah or check, If over $500, you MUST
attach Form 8283 ,
1& Carryover from prlor year
18 Add lines 13 Ihrou h '5 ,
10
l'
13
14
'5
,~I17 I
Movln ex enses, Atlach Form 3903 or 3903.F, (Sea pa e A.4.)
Unrelmburaed employee expenses-Job Ira vel. union
dues, job educetion, etc, If requil.ed. y.ou MUST aUach
Form 2'08, (See page A.4,) ~ .,I,lJ\d~l'l1,~,,:,!~..;..!l..
Other expenlee-lnveslmenl, lax preparation, safe
depoall box, elc. WII type and amount ~ ..,.. ....,.... ,
'-'--
SChldul1 A (Form 1040) IQ93
"'''-l...."',..._,
" ,
I
",
.'
'FGmt',' 2441
ChHd and Dependent Care Expenses
. , '
OMB ".0. 1b45.00filJ
VIS .._AoIhTrtIINY
___(2)
NorneIIl- on F_1040
~ Anlch 10 Form 1040.
~ 8.. II Irlll Inllrucllenl,
.
. ~@93
Att.chm,rn
SO<l'onc:. No. 21
Your locll' IIcurUy number
You need to understand the following terms to complete this form:
Dependent Care Benefits, Earned Income, Qualified Expenses,
and Qualifying Person(s). See Important Terms on page 1 of the
Form 2441 Instructions. Also, If you had a child born In 1993 and
line 32 of Form 1040 Is less than $23,050, see A Change To Note
on page 2 of the Instructions.
,
_ Paraona or Organizations Who Provided the Care-You must complete this part,
--- If ou need more s ace, use the bottom of a e 2,
(I) Care provider'. . (b) Address
1 name (number, Str88t, spt, no" city, stsle, and ZIP code)
(d) Amount paid
, (see instructions)
--r-..-
"
I
I.
a Add the amounta In column (d) of line I . , , , . . .
2
,~0
/800 I
3 . Enter the 'number of qualifying persons cared for In 1993 ,
Old you receive
depandant canl benaflta?
NO
YES
t Complete oniy Pan II below,
t Complete Part III on the back oow.
IilIIIII Credit for Child and Dependent Care Expenses
a Enter YOUR eamad Incoma 5
a If married filing 8 Joint return, enler YOUR SPOUSE'S earned
Incoma Of aludenl or disabled, S88 Instrucllons); all othars, enter
the amount from line 5 . . . . 6
4 Enter the amount of quallflad axpensas you incurred and paid In
1993. DO NOT enter mora than $2,400 for one quallfyin9 person
,or $4,800 for two or mora persons. If you completed Pan III, enter
,the amount from line 25 . , 4
7 Entar the lI11allelt of line 4, 5, or 6 . . .
8 .Enter the amount from Form 1040, line 32 ,
,II Enter on line 9 the declmsl amount shown below that applies to Ihe omount on line 8
If line 8 Ia- Oec,mll If IInl 8 11- Ooclmll
But not lmount Bul nol Imount
OVlr over I. OVlr over II
.
I'
SO-10.ooo ,30 $20,000-22.000 .24
10.000-12,000 ,29 22.000-24.000 ,23
12.000-14.000 .28 24.000-26,000 22 9 I
14.000-16.000 ,27 28,000-28,000 ,21 r~ .
16,000-18,000 ,26 26,000-No hmtt 20 ~
18,llClO-20,ooo .26 ~
10 Multiply line 7 by the decimal amount on line 9, Enter the result. Then, see the tnstructions for
the amount 01 credit 10 enter on Form 1040. line 41. , , . . . .. .,.. .J.9_ -3 !D i'::' ,
Cautlon: If you paid $50 or more In e celendar quarter /0 8 person whO worKed In your hOme. you muSI /,;e ar em%vme"!
lax relurn, Get Fonn e42 for delall" .
For Paperwork Reduotlon Aot Notlca, laa .aparate 1"ltructlonl. ell No 11802M Fo'", 2-441 --:-~,
.'
~o
',,8IlIlII COMPlHIATIOfl, W.gtI. ....11I1, Upl, lie, AI1IC/l F....(I) W.l....."."""..,"
10, UHMIMIUIIIlO EMMYE IUSINESS EXPEHSES. Allleh PA Sellldu~\I1 UE.. ,.. ..10
Ie, HET PA TWlLE COMPfNSATlON, SUOUIC1I1.. 10 Itom II.. I.
I, TWlLEINTlMST, From lnacllld PA Sch.du~ A"...""."...
S, TWIll DIVIDENDS, From lllac:lIId PA Sclll~~ B """,,,,,,,..,,,,,.....,,,..,,,,,,,,,,,,,,,,..,,",,,,..
~ 4. PA PROFIT OR ILOSSI FROM A BUSINESS. PROFESSION OR FARM:
14&. From Il\ICIlocI &dIoclu1o(I) C 1Ild/0< Scllldulo(II F ,,,,,,..........,,,,,,,....,,,,...,,..,,..11
I:: ;:= ,:F~u:;\:~~.;'~~~.;;;~;';~';~~'~~"""''''''..,....'''.... 40.
i 5, PA GAIN OR ILOSS) FROM THE SALE, EXCHANGE OR OISPOSITlOH OF PROPERTY
151, From 1_ PA ScllIclUIo(I) 0 Ind/O< PA Schldullll) 0-' .."..,..........."." ..,....~.
i511, From Il\ICIlocI PA ScllIcluIo(I) RK,I......,..,..,..,..,......................,....,..............~O
251. From Il\ICIlocI &dIoclu1o PAolI. SaIl 01 1",101III Rllldlnc.......,.................."..,.5c
;5d. AMOUNT OF ALLOWABLE EXCLUSION FROM LINE 20 OF PA,......................".. ""......
50, NET TAXABLE PA llAIN OR NET ILOSS), TOlllllnlS la, SO, 5 5e ..
e, NET TAXABLE PA IHCOME OR NET ILOSSI FROM RENTS, ROYAL liES, PATENTS ANO COPYRIGHTS
From._ PA Scllldulo(l) E 'nd/o< Sch'du~II) RK.' .................
7. TRUST INCOME, Fram .11IC1lIcl PA kIIIdull J..,..,......,......,..............,.............,........,,,..........
e, llAIIBLlNG AND LOTTERY WINNINDS, A1IICh IcIIldu~ 01 IIpllOlllon ollneoml or 110111 ,.... ... , '"
II, PfNNSYLVANIA TAXABLE INCOME, Add 11..1 Ie, 2, 3 4e, So e, 7 and I. 00 HOT SUBTRACT lOSSES
!! 10, TAX LIABILITY. UlI OF UNE' Muh' U.. '0 ,021 ..
11, TOTAL PA INCOME TAXES WITHHELD, flom anlChld formll) W'2.
PA ESTIMATED TAX PAYMENTS: 'I., Ctldll from ..92 R"..n $
lID, ToW 111I3 Elttmalld Tu ,."",nll $ 12e, Tu Plid wllh 1993 ElIt,"lIon I
li'2, TOTAl ESTllIATEO PAYMENTS AND CREDIT (Add 11..1 12.. 1lD .nd lIe),......,..,..,,,,............,,..
1113, TOTAl CREDIT FOR TAXES PAID BY PA RESIDENTS TO OTHER STATES DR COUNTR'ES
I From._ PA ScII.du~(I) G: PA Senldu~ RK'I 0< OIh" ovIdln" 'I III dUl .n'ln" .11I...
1'4, TAX FORGIVENESS CLAIMED PA SCHEDULE SP. Complll. PA Se"dull SP and ,.. SP Wo,,,.."
Z 141. Dtpencllnll Claimed on PA SChtdul. SP; '4t), Cllllmanl'l T0111 EliOlD1h1t Incom, 'rom lint" Cl l"t ~p
WOrklhlll: lie, C1IinInt'l TOIII Supporllncom. I,om SliP 2 ollhl SP W.",nlll.
IS, EMPlOYMENT INCENTIVE PAYMENTS CREDIT, F,om 'Ilac:llld PA Schldu'III) W.............."..,..,..
II, TOTAL PAYMENTS AND CREDITS (Add IIn" 11. 12d, 13, 11, .nd '51
,~.... <
,,',' ,f, .
, . COMMONWEALTH OF PENNSYLVANIA ' '
1 ~,~~:Rt!'d~!~tr\~m~~:~!~~~c~~.I~~~Wm .
; *' l;~( ~Nl YIII~,:;: BtIllnnlng , ,...;, 1913 l I
i Ending 1994
*******.If**CAR-RT SORT**RR20 """'I'
202-46-5574 HE 170-38-4583
HICHAEL A & CONNEE L ,""'.........',
HEHPT
3790 HOUNTIAN VIEW RD
HECHANICSBURG PA 17055-2128
liSlCtcH
OffiCIAl. uil
fIlINO Imu.' Ie,,,. o.tI oceU'AlION'
s ~S"g,. ",' \ I
J "',II,.a 1,1;"0 I IO,N r,II,It\ I I ,,~ ~'I' (.,.
U M,Hlla, 1:1'"0 \'Dj't1t1y l5['
T JOlnl CIJ.m Fe! '1,1 Or;IYI"'" Spoil"',
o a Dtc.11I0, rln,! fll!J'" .... I(
OallolOnl1'l .,
RlIlDENel ITATUI: ICn". Onll" A Pa.,I", Rnldtn'l
P OP.I1 VU' R"lo,nllrom liV3 10
'99l
,.....,...,.-,
NAMI/ADORUI IAIEl OPTION
o CIlICk htr, II yOI,l DltO" prlpa'" aM! JIIII Gilly oIIIIanll; Iturv, Il'Iam"ladf'u
Iltel 1I11lJ.!!: .~___. ._..
O'''t,AI :.~I
,
1~"C"'ll HOW "'''\' Cf IAt,.
IO_ij QII $C"(O\,j~( IS AnAt"':
fOlml W.! ~
5,", UE OJ
J F~I"'1 '099 ....,
I
StIli A [J
Seils E r~
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S'hl F D
'S,", RK" r--;
i 5"1 0 1'1
Se",D" [J
PA'19 ,---.
L...J
117, TAX DUE (SUBTRACT LINE Ie FROM LINE 10) MAKE CHECKS PAYABLE TO PA DEPARTMENT OF REVENUE 17
S te,DVERPAYMENT (Subtract L1nl 10 lrom LI.. 16)....., .. ..... . . . '8 I Ij , j;',c< ;,,,,. ,;. '/)"
E,Ia, Amoun. 01 Unl IS ,6"REFUNDEQ:)"..",. ., ..... . . I : 'II .L
I - HII TOIll 01 linn ~~. .-=-~--~
lID, Amount 01 Uno 1810 III CREDITED 10 YOUR 19?4 ESTIMATED TAX ACCOUNT. ....,. .. ! '9'
~Ik, Amount 01 Uno IS to III DONATED" 111I WILD RESOURCE CONSERVATION FUND....""". I '" '9< a'.'ge ,Ii:
~ lid. Amounl 01 Uno 18 to III DONATED to Ihl U.S. OLYMPIC COMMtTTEE. PA DtUlSIOH MUST EQull l'" " ",e
UIiIIf'....... II ,.,..,. I....... ..... .......... .... ....... ....,...,.., ..~.... II' ItftINlltI, .It It 1M Mil 'Illy Utwlt.,. '1' fillet IlIIrM. Wftct III' "lIpll..
y." \. CIl~ ""\I'IOIYW.DUedn.~CIl""lC7'h;ll1CW""""'~
Sign.. X X :i. /L~J'W"" __~____.__
hlr. MWllt'911 ...~ 01\ tilt I~l "P"" ,,'~)fl' .... , :JI"
. 2
,3
AlIach An R,Ql,llleC
Documents
.,
TnlS Return MuS! Bt
FIIIO On Or B,IQ'f
Ap,n IS, 199.
OOlfOTI/ljCl.UOlLlJrl[5iClI/ljI,JI![!It 5d
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9
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Set InSltuthon$ F:' i
CIJlmlno hhmal.c C"C' i
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131
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51.11'00:' R'I,,"
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. 16
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,~ DIo2 and SP (9093)
.~....'.
ALLOWABLE BUSINESS EXPENSES
bp,n,.. fat which yo" a'. IIOt ,.'mb",,,d by )'ollr .mploy.'.
A!I.ch. liP.'." UE,2 ,. f.,m PA,40R f., .och .mpl.y.'
Print 0' r . 011 informarion.
'ART AI UNION DUIS IN.... .nd om...')
"
v /1(.
~.,'~':;'.j
,.\
1993
SCHEDULE UE.2
ORK CLOTH IS AND UNifORMS III ,.qui,.d 01 0 (o",dillon 01 .mplaym'l'll and nOI
Ivitabl. lor ...., do u.. 6
AR LL TOOLS AND SUPPLII5 IR,q.irod by yO.1 ,mploymonl 0'. no' I.ppn.. by'
yo", .mploy") C
PAU 01 PROPlSSIONAL LICINSI PlIS, MALPRACTICE INSURANCE AND FIDELITY BOND PREMIUMS
R. "i"d 01 0 condilion of o",.m 10 m.nl 0 I
TOTAL IXPINSlS OF PARTS A THROUGH D. (REPORT ON LINE 1b 0' PA.40R)
Special Tax Provisions Schedule
(DO NOT fiLE If A DEPENDENT)
P,inl 0' I all infa,malion,
A I. At. yay a dep.nd.n' 'pow.. or childt ....................."..................... 0 V.I [J No
2. At. yoll clal"," 01 a dep.nd.nl on yow, IPO""', Sched"l. SP' ........ [J V.. [J No
3. Are yoy b.lng dohntd 01 0 d.p.tld,n' child fa, f.d.,oIIOA pvrpo..I' 0 VII ~ No
If yo" OIllwlt,d "V.... 10 q,,"lIonl 1 0,2 0' 3 or .. DO NOT fiLE A SCHEDULE SP
8 1. Tol.1 numb..., d'P!'nd.., chUdron In f.mUy
L1.t bel.w .11 d.p..d.." y.u.re ..'itl.d I. claim. DO NOT INCLUDE YOURSELf (Addi'ion.1 inf.,m.'i.n m.y b. ....ch.d on 0
..p.rat. .hll',1
1
~
3.5.
1
451,
DEPENDENT'S NAME
"'GE
SCHEDULE SP
PA DEPARTMENT 0' REVENUE
.. All yo" 0 U"d.nl b.ing c1oim.d 01 0
d,p.nd.nl on onOlh" 1011 "1,,,", ...
S If marri.d. i, you, 'POUlt lili",; 0 Scll.d",l. ~PI
6. At. yo" 0 ""ldow'widow.".,
I. TOT"'L TAXABLE INCOME fROM LINE 9 Of fORM P...,40R",,,.,,,,,..,,......,,...,,..
2. NONTAXABLE INTEREST, DIVIDENDS AND GAINS (W.,k,hoo,lin, B2)
3. ALlMONYIYOUR SUPPORT (WorklhH'lin, Bl .nd B31"....",,,,,..,,,,.,,,,
4. llF~ INSURANCE AND INHERITANCE PROCEEDS IWolklhoo' lino B41
$, GIFTS, AWARDS AND PRIZES IWork,hool lin. BS)...... , .."""..". .."
6. NONRESIDENT INCOME (W.rk.hoo'lin. B6) '''''' ",,,,,,,,,,,,,,,,,,......,,,,,
7. All OTHER INCLUDABLE INCOME (Work,h... lin.. 87 thlough 89)",,,.,
B. TOTAL INCOME. LINES 1 THROUGH 7 ABOVE
IEn'or C1.lm..", To'.llne.mol. Col.mn A .nd on lin. Ub.1 PA.4DRI ...
9, PENNSYLVANIA PERSONAL INCOME TAX (from lin. 1001 'o.m PA,40RI
10. lESS TAXES PAID TO OTHER STATES (Iino 13. 101m P....40R),.",."".".,
11. SUBTRACT LINE 10 FROM LINE 9 AND ENTER DIFFERENCE,,,.,,,....,,
12, PERCENTAGE OF FORGIVENESS ISoo'neom. Tobl, 101 docimol.q.i,.I,nt)
13, AMOUNT OF SPECIAL TAX FORGIVENESS IM.hiply lino 11 by I,n. 121
Entlt hit. and on IIn, U of PA.40R............................""....
Pal' 4
:: 't'1 ',Nt.
:: V,," OJ.
:: V" _ r-.t;.
SOC''''L SECURITY NUMBER
Inter ho.. and on II... 14a of PA.40R 101.1 number ., d.pond.nt' you .re ontltlod t. claim..,,,,,,,,,..
2. Tot.1 Othor Inc.... fr.m IIn. C7 ., SP W.rk.hll':
CI.lm.n' 5 Sp.... S
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COLUMN A
CLAIM"'NT'S INCOME
OR JOINT flllNQ
COLUMN 8' I
SPOUSE'S INCOME
I
.,
i
2
3
4
5
6
7
B
9'
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.
MICHABL A. HBMPT
Plaintiff . IN THB COURT 01' COMMON
.
PLBAS 01' CUMBBRLAND
COUNTY, PENNSYLVANIA
VB.
CIVIL ACTION - LAW
CONNBB L. HBMPT
Defendant NO. 94-1778 CIVIL TBRM
ORDBR 01' COURT
AND NOW, TUl1t 3,
1994, upon consideration of the attached complaint,
it is hereby directed that the parties and their respective counsel appear before
Hubert x. Gilroft' Bsquire, the conciliator, at --.!d--LA-_LJQ.'~/r -Ll-trnb. Co.
C<Mr\~ (..r~S&ennSYIVania, on -fricl~ the -.a.t'"'- day of JI-tly _, 199L/,
at -5: 3d o'clock ~..m., 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. Bither party may bring the children who are the SUbject of
this custody action to the conference, but the children's attendance is not mandatory.
Failure to appear at the conference may provide grounds for entry of a temporary or
permanent order.
I
,,:~;4.i4r~~
ustody Conci lator ~
I
IF YOU DO NOT HAVB A LAWYBR OR I
I
FOR THB COURT,
YOU SHOULD TAKB THIS PAPBR TO YOUR LAWYBR AT ONCB.
'I CANNOT AFFORD ONB, GO TO OR TBLBPHONB THB OFFICB SBT FORTH BBLOW TO FIND OUT WHBRB YOU
,
! CAN GET LBGAL HBLP.
OFFICB OF THB COURT ADMINISTRATOR
COURTHOUSB, 4TH FLOOR
CARLISLB, PA 17013
(717) 240-6200
JUN 3 4 lS PH '9~
.i; FleE
or ''', '~;ON~H~'r
(.u~.~,~., :,'tLI C(~~:y
jl f ~H, s.{ L -,LillA
. .
..
HICHABL A. HBHPT
Plaintiff IN THB COURT OF COHHON
PLBAS OF CUHBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
CONNBB L. HBHPT
Defendant NO. 94- CIVIL TERM
COMPLAINT FOil CUSTODY
AND NOW comes the Plaintiff, HICHABL A. HBHPT, by his attorneys, Andes, Vaughn &
Bangs and makes the following Complaint for Custody:
1. The Plaintiff is HICHABL A. HEHPT, an adult individual whose address is 3190
Hountain View Road, Hechanicsburg, Cumberland County, Pennsylvania.
2. The Defendant is CONNBB ro. HEHPT, an adult individual whose address is 3790
Hountain View Road, Hechanicsburg, Cumberland County, Pennsylvania.
3. The Plaintiff and Defendant are husband and wife, having been married on 22
July 1978.
4. The Plaintiff and Defendant are the natural parents of four minor children:
Corinne D. Hempt, born 22 February 1982; Julie L. Hempt, born 25 Hay 1984; Brin
Hichelle Hempt and Hichael A. Hempt, Jr., (twins) born 28 August 1986. The said minor
children reside with Plaintiff and Defendant herein.
5. Plaintiff seeks custody of the minor children, Corinne D. Hempt, Julie L.
Hempt, Brin Hichelle Hempt, and Hichael A. Hempt, Jr.
6. The children were not born out of wedlock and are presently in the custody of
the Plaintiff and Defendant.
7. During the past five years, the minor children have resided with the following
I persons
I
I
at the following addresses:
1
,i
'.f9"-.."'-'"'
,.."....~ ~
"
...
.
1989 to the present
3790 Mountain View Road
Mechanicsburg, Hampden TYp.
Cumberland Co., Penna.
Plaintiff and Defendant
8. The mother of the children is the Defendant who resides at the address set out
above. 8he is married to the Plaintiff.
9. The father of the children is the Plaintiff who resides at the address set out
above. He is married to the Defendant.
10. The Plaintiff is the natural father of the children. Plaintiff currently
resides with the said minor children and the Defendant.
11. The Defendant is the natural mother of the children. Defendant currently
resides with the following persons: the said minor children and the Plaintiff.
12. The Plaintiff has not participated as a party or in any other way in any
litigation concerning the custody of the children in this or any other court.
The Plaintiff has no information of a custody proceeding concerning the children
pending in a court of this or any other jurisdiction.
Plaintiff knows of no other person not a party to this action already who has
physical custody of or claims to have custody or visitation rights with the said
children.
13. Plaintiff seeks an order awarding shared legal and physical custody of the
minor children whereby they spend at least fifty percent of their time in the physical
cusotdy of Plaintiff. He believes that is in the best interests of the children for
several reasons:
I
I'
I
A. Both parents have been actively involved in parenting the children
and have participated in all parenting activities over the last several
,
~
I
years.
.
.,'
.
)
, ,
2
"'1
1
.......,,."~. . ...,. ..-~..,.-...........
"
'.
.
.
"
B. The work schedules of the parents, and the school and activities
schedule of the children, lend themselves to shared custody.
C. An award of primary physical custody to either parent would disrupt
the other parent's relationship with the children and that parent's active
role in the children's lives.
14. Each parent whose parental rights to the children have not been terminated
and the person who has physical custody of the children have been named as parties to
this action.
VHHRBFORB, MICHAEL A. HEMPT requests this Court to enter an order awarding shared
legal and physical custody of the children and setting a schedule to give each parent
maximum time with the children.
ANDES, VAUGHN & BANGS
BY~c;~ ~/I')/(~-,-f. 44<4s
Micha~ngs
Attorney for Plaintiff
Ii
['
.1
3
. .'
,
COHMONWBALTII OP PBNNBYLVANIA I
( BB.:
COUNTY OP CUMBBRLAND I
MICIIABL A. IIIlMPT, boing duly IIworn according to law, depose II and lIaYII that the
factB Bot forth in the forogoing Complaint for cUlltody are true and correct to the best
of hill knowledge, information, and belief.
i
,
I
,
i i Sworn to and 1I\I1lB..ltr,\bed
i I before.pt.!t thil\::::J tfiky
'i Of\ -...,' U(j , 1994.
LU.LM )(J,J A ~
: Notary P/I l~!:::
~\C.W o...~
MICHABL A. HBMPT
'.
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SEP 14 1994
de-
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MICHAEL A. HEHPT,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
v
.
.
:NO. 1778 - CIVIL - 1994
:
CONNEE L. HEMPT,
Defendant
.
.
:CIVIL ACTION - CUSTODY
COURT ORDER
,~
AND NOW, this I ~ day of A~ c:...t-
of the attached Custody Conciliation
directed as follows:
, 1994, upon consideration
Report, it is ordered and
1. The parties shall meet for a second Custody Conciliation
Conference before Hubert x. Gilroy, Esquire, the
Conciliator, on the 4th floor of the Cumberland County
Courthouse on the 28th day of October, 1994, at 10:30 A.M.
2. Pending further Order of this Court, the Father, Michael A.
Hempt and the Mother, Connee L. Hempt shall enjoy shared
legal and physical custody of Corinne D. Hempt, born February
22, 1982, Julie L. Hempt, born May 25, 1984, Erin Michelle
Hempt and Michael A. Hempt, Jr., (twins) born August 28,
1986.
3. Physical custody shall be handled with the parties sharing
physical custody on alternating weeks. Exchange of custody
shall be accomplished at 6 P.M. on every Sunday. The party
having custody of the children shall feed the children before
exchange of custody on Sunday. The custodial parent shall
deliver the children to the non-custodial parent's home each
Sunday at 6 P.M., with no need for the custodial parent to
go in to the non-custodial parent's home or even go to the
door as long as the children verify that the other parent
is home.
4. The children shall continue to attend school in the Cumberland
Valley School District pending further agreement of the
parties or Order of Court.
BY THE COURT,
1(L-. AIL
cc: Maria Cognetti, Esquire - l:..t,loJ ~~"..{ '/ II,,/q~,p.
Michael L. Bangs, Esquire - <=<'t3- fk,....L"':"- f.k- qln.lr;/f.
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MICHAEL A. HEMPT,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
v
.
.
:NO. 1778 - CIVIL - 1994
.
.
CONNEE L. HEMPT,
Defendant
.
.
:CIVIL ACTION - CUSTODY
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL 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:
Corinne D. Hempt, born February 22, 1982, Julie L. Hempt,
born May 25, 1984, Erin Michelle Hempt and Michael A. Hempt,
(twins) born August 28, 1986.
2. A Conciliation Conference was held on August 27, 1994, with
the following individuals in attendance:
The Mother, Connee L. Hempt, with her counsel, Marie P.
Cognetti, Esquire, and the Father, Michael A. Hempt, with
his counsel, Michael L. Bangs, Esquire.
3. The parties separated just one month ago. The Father moved
out of the marital home and is living with family. The parties
have worked out a week on/week off custody arrangement. There
are still a number of disputes relative to this arrangement.
The Conciliator is of the opinion that the parties will be in
a better position to work this matter out on their own after
the parties have had an opportunity to make a judgment on the
current custody arrangement. A few weeks post separation is
not the time to attempt to work out this type of custody
arrangement. For that reason, the Conciliator recommends
that a second Conciliation Conference be scheduled in the
fall. Pending that Conference, the Conciliator recommends
the maintenance of the status quo with the children continuing
to attend school in the Cumberland Valley School District.
The Mother resides in the Cumberland Valley School District
and the Father resides in New Cumberland.
.
.
.
4. The Conciliator recommends an Order in the for.m as attached.
Q.13ol Q ,(
DATB
CJ6
,
Nav 07 199.J
(Jj./
MICHAEL A. HEMPT,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:
:NO. 1778 - CIVIL - 1994
v
CONNEE L. HEMPT,
Defendant
.
.
.
.
:CIVIL ACTION - CUSTODY
COURT ORDER
AND NOW, this 1 'I' day of loIo--u-
of the attached Custody Conciliation
directed as follows:
, 1994 upon consideration
Report, it is ordered and
1.
This Court's Order of September 15, 1994 is ratified subject
to the modifications set forth below.
2.
Exchange of custody between the parties shall take place at
5 P.M. on Sunday instead of the original scheduled 6 P.M.
exchange.
The parties shall submit themselves and the minor children
for a custody evaluation to Guidance Associates. The focus
of this evaluation shall be to determine the children's
feelings and attitudes with respect to the current custody
arrangement and with respect to a potential future custody
arrangement. The evaluator will, for purposes of this
evaluation, presume both parents are fit and capable
parents. The focus of the evaluation should be on the
children, with the parties not anticipating at this time
any elaborate testing being required for the parents. The
evaluator is requested to have a written report concerning
the evaluation sessions sent to counsel for the parties
within thirty days of the evaluators receipt of this Order.
The parties are instructed to cooperate fully with the
evaluator with respect to scheduling the children for
evaluation sessions. Both parties shall share equally in
the cost of this evaluation and the parties shall pay for
all costs that are not covered by insurance.
There is an understanding between the parties that the
older child, Corinne, shall be in the physical custody of
the Father and her siblings during the week that he has
the children for the time' frame from Saturday at 10 A.M.
until Sunday at 5 P.M. '". . , ~cJ\\
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For the Thanksgiving hol~gay;' t~e' children are scheduled
to be with the Father. Ttl'fj Mother shall enjoy temporary
3.
4.
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custody with the children from Wednesday at 6 P.M. until
Thanksgiving Day at 4:30 P.M.
6. The parties shall convene for a third Conciliation
Conference before the Custody Conciliator on January 26,
1994, at 9:30 A.M.
7. Neither party shall be prejudiced by this Order in raising
any and all issue concerning a permanent Custody Order in
the event this matter is litigated before the Court.
BY THE COURT,
API-
co:
Maria Cognetti, Esquire
Michael L. Bangs, Esquire_
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MICHAEL A. HEMPT,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
v
.
.
:NO. 1778 - CIVIL - 1994
.
.
CONNEE L. HEMPT,
Defendant
.
.
:CIVIL ACTION - CUSTODY
I" C// (it{
TE
PRIOR JUDGE: JUDGE KEVIN A. HESS
CONCILIATION CONFERENCE SOMMARY REPO.R!l'
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL 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:
Corinne D. Hempt, born February 22, 1982, Julie L. Hempt,
born May 25, 1984, Erin Michelle Hempt and Michael A.
Hempt, Jr., (twins) born August 28, 1986.
2. A Conciliation Conference was held on October 28, 1994,
with the following individuals in attendance:
The Mother, Connee L. Hempt, with her counsel, Maria P.
Cognetti, Esquire, and the Father, Michael A. Hempt, with
his counsel, Michael L. Bangs, Esquire.
3. The parties agreed to the entry of an Order in the form as
attached.
..
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DEe 1 4 \994
dJ-..
MICHAEL A. HEMPT,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
v
.
.
:NO. 1778 - CIVIL - 1994
:
CONNEE L. HEMPT,
Defendant
.
.
:CIVIL ACTION - CUSTODY
COUR~ ORDER
AND NOW, this ~ day of :J~<.. d:c- , 1994, upon consideration
of the attached Custody Conciliation Report, it is ordered and
directed as follows:
1. This Court's prior Order of November 14, 1994, shall remain
in effect subject to the modifications set forth below.
2. Custody of the minor children over the Christmas holiday
shall be handled separat~from any other custody arrangement.
Custody shall be alternated from December 24 at noon until
December 25 at noon and December 25 at noon until December 26
at noon. Mother shall enjoy the children in 1994 from
December 24 at noon until December 25 at noon with Father
enjoying custody from December 25 at noon until December 26
at noon. This shall be alternated from year to year with the
Father enjoying custody of the children on Christmas Eve and
Christmas morning in 1995.
BY THE COURT,
Maria Cognetti, Esquire '
Michael L. Bangs, Esquire
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cc:
evin A. Hess
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MICHAEL A. HEMPT,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
v
.
.
:NO. 1778 - CIVIL - 1994
.
.
CONNIE L. HEMPT,
Defendant
.
.
:CIVIL ACTION - CUSTODY
PRIOR JUDGE: JUDGE KEVIN A. HESS
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL 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:
Corinne D. Hempt, born February 22, 1982, Julie L. Hempt,
born May 25, 1984, Erin Michelle Hempt and Michael A.
Hempt, Jr., (twins) born August 28, 1986.
2. A telephone Conciliation Conference was held on December 8,
1994, with the Conciliator speaking with Attorney Maria P.
Cognetti, counsel for the Mother, Connie L. Hempt, and Attorney
Michael L. Bangs, counsel for the Father, Michael A. Hempt.
This Conference was initiated by counsel for the parties. The
Conciliator had advised the parties that, in the event the
parties were unable to agree on a Christmas visitation
schedule, counsel for the parties could contact the Conciliator
and conduct a Conciliation Conference by phone.
3. The existing Order provides for an alternating week schedule.
Father is scheduled to have custody over Christmas week.
However, Mother desires to have custody of the children on
Christmas Eve and Christmas morning.
4. Father argues that he had custody over Thanksgiving but that
the Mother was afforded, by agreement at the last Conciliation
Conference, time over Thanksgiving from 6 P.M. on Wednesday
until Thanksgiving Day at 4:30 P.M. On that basis, Father
suggests that he is entitled to have the children on Christmas
Eve and Christmas morning for this year.
5. The Conciliator notes that the parties have not yet been
separated for a year. This will be the first Christmas that
the parties and the children are faced with this dilemma.
.
.
The Conciliator also notes that the Mother is living in the
marital home. Where the parties are unable to reach an
agreement on Christmas, the undersigned Conciliator suggests
an arrangement whereby they will split from noon on Christmas
Eve until noon on Christmas Day and from noon on Christmas
Day until noon on December 26. Such a schedule would
alternate from year to year.
6. It is clear that some Order needs to be entered to address
the Christmas holiday. The Christmas holiday should not
be dictated by which party has custody on a week to week
schedule.
7. Because of the uniqueness of the Christmas holiday and the
fact that this is the first year the children and tha
parties will be faced with separate homes, the Conciliator
leans towards leaving the children with the Mother on
Christmas Eve and Christmas morning for the first year,
with such a schedule to alternate in future years.
8. The Conciliator recommends an Order in the form as attached.
I 'J/I<<II (t(
DATE
p'
FEB
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MICHAEL A. HEMPT,
Plaintiff
v
tIN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:
:NO. 1778 - CIVIL - 1994
:
:
:CIVIL ACTION - CUSTODY
COURT ORDER
CONNEE L. HEMPT,
Defendant
AND NOW, this ~ day of
of the attached Custody
directed as follows:
/"6(,y~:17; , 1995, upon consideration
Concil tion Report, it is ordered and
1. The prior Orders in this case are vacated except for
Paragraph 2 of this Court's Order of December 19, 1994,
that dealt with future Christmas holidays.
2. The Father, Michael A. Hempt, and the Mother, Connee L.
Hempt, shall continue to enjoy shared legal custody of
Corinne D. Hempt, born February 22, 1982, Julie L. Hempt,
born May 25, 1984, Erin Michelle Hempt and Michael A.
Hempt, Jr., (twins) born August 28, 1986.
3. The Mother shall enjoy primary physical custody of the
minor children.
4. The Father shall enjoy periods of temporary physical
custody on a reasonable basis as allowed by his work
schedule. Father shall advise Mother in advance of
his work schedule and give Mother reasonable notice as
to when he desires to exercise temporary custody.
Under no circumstances shall the periods of temporary
custody exceed three weekends per month.
5. This Order is entered pursuant to an agreement reached
by the parties at a Custody Conciliation Conference.
In the event either party desires a modification of this
Order, that party may petition the Court to have the case
again scheduled with the Custody Conciliator.
BY THE COURT,
J::::;~;;n 1 ~~
cc: Maria Cognetti, Esquire-3401 Front Street, Harrisburg 17108
Michael L. Bangs, Esquire ~.
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MICHAEL A. HEMPT,
Plaintiff
v
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:
:NO. 1778 - CIVIL - 1994
.
.
CONNEE L. HEMPT,
Defendant
:
:CIVIL ACTION - CUSTODY
PRIOR JUDGE: JUDGE KEVIN A. HESS
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL 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:
Corinne D. Hempt, born February 22, 1982, Julie L. Hempt,
born May 25, 1984, Erin Michelle Hempt and Michael A.
Hempt, Jr., (twins) born August 28, 1986.
2. A Conciliation Conference was held on January 26, 1995, with
the following individuals in attendance:
The Father, Michael A. Hempt, with his counsel, Michael L.
Bangs, Esquire, and the Mother, Connee L. Hempt, with her
counsel, Maria Cognetti, Esquire.
3. The parties agreed to the entry of an Order in the form as
attached.
tl1d qs-
DATE
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Hubert X. Gilroy, squi e
Custody Conciliator
FEU 7 3 3G ['/I '95
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
MICHAEL A, HEMPT,
Plaintiff
CIVIL ACTION - LAW
CONNEE L. HEMPT,
Defendant
NO, 1778 CIVIL 1994
ORDER OF COURT
AND NOW, ~, 1995, upon consideration of the attached
Petition for Contempt and Modification, it is hereby directed that tha parties and
their respective counsel appear before Hubert X, Gilroy, Esquire, the conciliator, at
4th Floor, Cumberland County Court House, Carlisle, Pennsylvania, on
Fa c.\""'t ' the ~ day of Oct-Dbff: 1995, at 9,' $:J
o'clock !1..M" 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, Either party may bring the children who are the subjact of this
custody action to the conference, but their children's attendance is not mandatory.
Failure to appear at the conference may provide grounds for entry of a temporary or
permanent order,
FOR TH~URT,
BY: -A/~-t~~i Y jJ~~54,
Custody Conciliat6r (/ ~I
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 CA~ GET LEGAL HELP.
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, 4TH FLOOR
CARLISLE, PA 17013
(717) 240-6200
Auc 29 2 Z8 PH '95
OF r'".I" 'Jlf,C~
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MICHAEL A. HEMPT,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs,
NO. 1778-CIVIL-1994
CONNEE L, HEMPT,
Defendant
CIVIL ACTION - CUSTODY
PETITION FOR CONTEMPT AND MODIFICATION
AND NOW comes the Plaintiff, by his attorney, Michael L. Bangs, Esquire,
and files the following Petition for Contempt and Modification:
1, The parties are subject to a custody order involving their minor children,
said custody order dated 7 February 1995. Attached hereto and marked as Exhibit
A is a true and correct copy of the order.
2. Defendant, Con nee L. Hempt, has repeatedly violated the Order as
follows:
A. The children are not ready to go with the Father on the
scheduled visitation weekends,
B. The children have been prevented from going with their
Father on scheduled weekends.
C. The times scheduled by Father have been changed arbitrarily
by Mother,
D, Mother has interrupted Father's regularly scheduled
vacation.
3. Plaintiff is in need of a modification of the schedule to insure that Mother
provides him with the regular and consistent access that he is entitled.
Respectfully submitted,
4. Plaintiff requests that the weekend times be fixed and that the Defendant
be ordered to have the children ready when he Is to pick them up.
WHEREFORE, Plaintiff requests this Honorable Court to find Defendant In
contempt of the Order of 7 February 1995 and furthar to modify the Order such
that it specifias the exact times for the weekend visitations and for other holidays
and visitation pariods with the children,
Michael L. 'Bangs
Attorney for Plaintiff
302 South 18th Street
Camp Hill, PA 17011
(7171730-7310
Sup. Ct, ID #41 263
2
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COMMONWEALTH OF PENNSYLVANIA )
( 55:
COUNTY OF CUMBERLAND )
MICHAEL A, HEMPT, being duly sworn according to law, deposes and says
that the facts set forth in the foregoing Petition for Contempt and Modification are
true and correct to the best of his knowledge, information and belief,
11/.1...11/, V
MICHAEL A. HEMP
,
HOTl\Jl!I.l W.L
WENDY S. CH!;~. l-k:orf r-.b:!.:
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MICHAEL A. HEMPT,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
v
.
.
:NO. 1778 - CIVIL - 1994
CONNEE L. HEMPT,
Defendant
.
.
.
.
:CIVIL ACTION - CUSTODY
PRIOR JUDGE: JUDGE KEVIN A. HESS
COURT ORDER
AND NOW, this /911) day of tfL <1 U.ll/ ~) , ~pon consideration of the
attached Custody Conciliation Report, it ~s ordered and directed as
follows:
1. A hearing is scheduled in Co~rt Room Np.. 4 of the Cumberland
County Courthouse on the I '/t/l day of &{" "1/;1' \ /, 1995, at _
q;3Ql1.M. at which time testimony will be taken ~n the above case.
At this hearing, the Father shall be the moving party and
shall proceed initially with testimony. Counsel for the
parties shall file with the Court and opposing counsel a
memorandum setting forth a history of the custody proceedings
in this case, each party's position with respect to custody at
this time, list of witnesses that will be called to testify
and a summary of anticipated testimony of each party. This
memorandum shall be filed at least ten days prior to the
mentioned hearing date.
2. Pending further order of this court, the court's prior order
on custody shall remain in effect.
BY THE COURT,
. AIL
cc: Samuel Andes, Esquire
Maria P. Cognetti, Esquire
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OCT 19 II ,dll '95
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MICHAEL A. HEMPT,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
v
.
.
:NO. 1778 - CIVIL - 1994
.
.
CONNEE L. HEMPT,
Defendant
.
.
:CIVIL ACTION - CUSTODY
PRIOR JUDGE: JUDGE KEVIN A. HESS
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(B), the undersigned Custody Conciliator submits the
following report:
1. A Conciliation Conference was held on October 10, 1995, with
the following individuals in attendance:
The Father, Michael A. Hempt, with his counsel, Samuel Andes,
Esquire, and the Mother, Connee L. Hempt, with her counsel,
Maria Cognetti, Esquire.
2. The parties are at odds on a number of issues. Specifically,
the father is only able to exercise visitation one evening a
weekend because of his work schedule. Father lives in
Philadelphia and works on Sunday. Father is requesting at
least three weekends per month which would be Friday through
Saturday evening during the school year and Thursday through
Saturday during the summer. Mother suggests that Father
should only get two weekends. There is also a dispute with
respect to allocation of summer vacation time and the how the
vacation time would interrelate with respect to the
alternating weekend visitation.
3. A hearing is necessary, but should take no more than one-half
of a day.
4. The Conciliator recommends an order in the form as attached.
1{)/1~1 tlJ
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Hubert X. Gilr~, Esquire
Custody Conci 1ator
, ;lIllI'S"
-
PROPERTY RF:'l"I'I.EMENT AGREEMENT
THI8 AGREEMENT, made this 23~day of ~~I ,l99ft is by and
between:
HICHABL A. HEHPT, of 505 Third Street, New Cumberland,
Pennsylvania, party of the first part, hereinafter referred to as
"Hushand"; and
CONNEE L. IIEHPT, of 3790 Mountain View Road, Mechanicsburg,
Pennsylvania, party of the second part, hereinafter referred to as
"Wife."
WITNEBBETII:
WlfEREA8, the partieu hereto are husband and wife, having been
married on 22 July 1978 and are the parents of four minor children:
Corinne D. Hempt. born 22 February 1982, Julie L. Hempt, born 25 May
19S4, Erin ~lichelle Hempt and Miehael A. Hempt, Jr., both born 28 August
1986 (hereinafter referred to as "children"); and
WlfEREA8, certain di rficul ties have arisen bet\~een the partIes
hereto which have made them desirous of living separate and apart from
one another and Wife has initiated an action in divorce against Husband
to No. 94-1778 Civil Term before the Court of Common Pleas of Cumberland
County, Pennsylvania; and
WlfEREA8, the parties hereto, Wife being represented by Maria P.
Cogne!: t.i, Esquit'e. and Huuhand by Samue 1 J.. Andes, Esquire. have each
exchanged full and complete information as to the property, assets, and
liabilities owned and owed by each and have disclosed to each other and
to their respective attorneys full information as to the financial
status of hoth parties hereto; and
1
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WHEREAS, the parties hereto have mutually entered into an agreement
for the division of their assets, the provision for the liabilities they
owe, and provision for the resolution of their mutual differences, after
both parties have had full and ample opportunity to consult with their
respective attorneys, and the parties now wish to have that agreement
reduced to writing.
NOW, THEREFORE, the parties hereto, in consideration of the above
recitals, the mutually made and to be kept promises set forth
hereinafter, and for other good and valuable conlliderations, and
intending to be legally bound and to legnlly bind their heirs,
successors, assigns, and personal reprellentatives, do hereby covenant,
promise, and agree as follows:
1. This agreement shall not make any disposition of the parties'
claims regarding custody of or support for their minor children, both of
which are the SUbject of orders entered in other litigation pending
between the parties.
2. The parties acknowledge tllat they are currently purchasing that
property situate at and known and numbered as 3790 Mountain View Road,
Mechanicsburg, Pennsylvania, pursuant to an a~reement of sale with Mr.
and Mrs. William Raudabaugh and that there is a balance owed on that
obligation in excess of $30,000.00. Wife agrees that she shall, within
ninety (90) days of the date of this agreement, obtain financing from a
bank or mortgage company in an amount sufficient to pay the balance owed
to the Radabaughs in full and to pay the sum of money to Husband as
provided in Paragraph 3 hereof and, upon Wife's completion of such
refinancing, so that the Raudabaughs are paid in full and Husband is
released from any furthel' Obligation to thelll, and the payment to Husband
of the sum provided in Paragl'aph 3 hOI'eof, Hushimd shall make, execute
2
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and deliver to Wife or her attorney his deed to grant and convey all of
his right, title, and interest in and to the property to Wife. Wife
represents to HUllband that she has made all payments due to Mr. and Mrs.
Raudabaugh on the sales agreement obligation and promises that she will
make all further payments due until such time as the remaining balance
is satisfied in accordance with this paragraph and Wife further agrees
that she will indemnify and save harmless Husband from any loss, cost,
or expense caused to him by her failure to make such payments strictly
in accordance with the agreement with the Raudabaughs until such time as
that debt is paid and satisfied in full and Husband is relieved from any
further liability therefor.
3. Wife shall pay to Husband, as equitable distribution of the
parties' marital property, the sum of Forty-Two Thousand ($42,000.001
Dollars. Wife will make such payment contemporaneously with the
delivery of the deed to the property at 3790 Mountain View Road as
contemplated by Paragraph 2 hereinabove.
4. Husband does hereby grant, convey, transfer, assign, and
deliver and set-over unto Wife the following assets, which said assets
shall be and remain the sole and separate property of Wife hereafter,
free of any claim by or interest of Husband, regardless of whether such
assets were deemed by either of the parties to be marital property or
non-marital property before:
A. Wife's interest in her account within the
Pennsylvania Blue Cross VIP Plan.
B. Wife's account or benefits within the Pennsylvania
Blue Shield profit-sharing, pension, retirement, or similar
tax-deferred benefit plan.
C. The 1991 custom Chevrolet van currently in Wife's
possession. Husband will execute the title to the vehicle
upon request.
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D. The 19BO Chevrolet Suburban automobile currently
titled in both parties' names. Husband will execute and
deliver the title to the vehicle to Wife as Boon as she
presents the title to him for execution.
And further, Husband does hereby waive, release, relinquish. and
surrender forever any and all claim to or interest in said assets, which
shall be and remain the sole and separate property of Wife hereafter.
5. Wife does hereby grant, convey. transfer, assign, and deliver
and set-over unto Husband the fOllowing assets, which said assets shall
be and remain the sole and separate property of Husband hereafter, free
of any claim by or interest of Wife, regardless of whether such assets
were deemed by either of the parties to be marital property or non-
marital property before:
A. Husband's 25 percent interest: in a hunting cabin
owned with members of his family.
B. Husband's interest in the Employee Savings and
Protection Plan with Carolina Freight Systems.
C. Husband's retirement benefits wi.th the Teamsters
Pension Fund.
D. The balance within Husband's account with the
Teamsters and Cheauffeurs Federal Credit Union.
E. Husband's IRA with Dauphin Deposit Bank.
F. A 19BB Yugo sedan now or formerly titled in Husband's
name.
And further, Wife does hereby waive, release, relinquish. and surrender
forever any and all claim to or interest in said assets, which shall be
and remain the sole and separate property of Husband hereafter.
6. The parties hereto mutually agree that they have effected a
satiSfactory division of the furniture, household furniShings,
appliances, and other household and personal property between them and
they mutually agree that each party shall, from and after the date
4
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hereof, be the sole and separate owner of all such tangible personal
property presently in his or her possession, whether said property was
heretofore owned jointly or individually by the parties hereto, and this
agreement shall have the effect of an assignment or receipt from each
party to the other for such property as may be in the individual
pOllsessions of each of the parties hereto, the effective date of said
bill of sale to be contemporaneous with the date of the execution of
this Agreement.
7. The parties aCknowledge that they are aware of the income,
education. income potential. and assets and hOldings of the other or
have had full and ample opportunity to become familiar with sucll items.
Both parties acknowledge that they are able to support and maintain
themselves comfortably, without contribution from the other beyond that
as provided for in this Property Settlement Agreement, ,upon the income
and assets owned by each of them. The parties hereby acc:ept the mutual
covenants and terms of this Agreement and the benefits and properties
passed to them hereunder in lieu of any and all further rights to
support or alimony for themself, counsel fees, and alimony pendente lite
at this time and during any and all further or future actiona of divorce
brought by either of the parties hereto and the parties do hereby
remise, release, Quit claim, and relinquish forever any and all right to
support, alimony, alimony pendente lite, counsel fees and expenses
beyond those provided for herein. durinlJ the pendency of or as a result
of any sllch actions. as provided by the Divorce Code of Pennsylvania or
any other applicable statute. at this time and at any time in the
future.
8. Except as herein othel'w iae provided, each par.ty hereto 1lI11Y
dispose of his or her property in any way. and each party hereby
5
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expressly waives and relinquishes any and all rights hu 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 8S a
result of the marital relationship, including, without limitation, the
right to equitable division of marital property, alimony, alimony
pendente lite, and counsel fees, except an provided for otherwise in
this Agreement, dower, courtesy, statutory allowance, widow's allowance,
right to take in intestacy, right to take against the will of the other,
and right to act as administrator or executor of the other's estate, and
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.
9. Husband releases his inchoate intestate rights in the estate of
Wife and Wife releases her inchoate intestate rights in the estate of
Husband, and each of the parties hereto by these presents for himself or
herself, his or her heirs, executors, administrators, or assigns, does
remise, release, quit claim, and forever disCharge the other party
hereto, his or her heirs, executors, administ!ators, or assigns, or any
of them, of any and all claims, demands, damages, actions, causes of
action or suits of law or in equity, of whatsoever kind or nature, for
or because of any matter or thing done, omitted. or sllffered to be done
by such other party prior to the date hereof; except that this release
shall in no way exonerate or discharge either party hereto from the
obligations and promises made and imposed by reason of this agreement
and shall in no way affect any cause of action in absolute divorce which
either party may have against the other.
6
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10. The parties hereto mutually represent to the other than neither
of them has incurred any debts in the name of the other not previously
disclosed or provided for in this agreement. Each of the parties hereby
represents to the other that neither one of them have incurred or
contracted for debts in the name of the other or for which the other is
or would be legally liable from and after the date of the parties'
separation. Both parties hereto mutually agree and promise that neither
will contract or otherwise incur debts in the other's or joint names
without the prior permission and consent of the other party hereto.
Both parties hereto represent and warrant to the other party that they
have not so contracted any debts unbeknownst to the other up to the time
and date of this Agreement.
11. Both of the parties hereto represent to the other that they
have made full disclosure of the assets and income and income sources
owned, controlled, or enjoyed by either of them and that neither party
hereto has withheld any financial information from the other. Each of
the parties represents that they have reviewed this information with an
attorney of their choice, or had the opportunity to review this
information with an attorney of their choice and vOlllntarlly decided not
to do so.
12. In the event that any of the provisions of this agreement are
breached or violated by either of the parties, the other party shall be
entitled to enforce this agreement by an appropriate action in law or in
ecrnity or to take any other action to which they are lawfully entitled
to enforce this agreement or otherwise protect their rights. In the
event that such action is commenced by one of the parties and the other
party is found to have breached or violated any of the terms and
provisions of this agreement, the party having so violated or breached
the agreement, shall be responsible for and shall promptly pay upon
7
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demand the reasonable attorney's fees incurred by the other party to
enforce their rights hereunder.
13. The parties agree that they shall, upon the request of either
party's attorney, make, execute, aCknowledge and deliver to their
attorney, for prompt filing with the court, affidavits of consent and
any other document reasonably necessary to conclude the divorce. The
parties contemplate that the divorce will not be concluded until such
time as Wife has refinanced the house in accordance with Paragraph 2
hereof and made the payments to the Radabaughs and to Husband as
contemplated by this agreement. The parties agree, however, that they
will promptly provide to their attorneys all documents necessary to
conclude the divorce upon the request of their respective attorneys.
14. This Agreement shall be interpreted and construed in
accordance with the laws of the Commonwealth of Pennsylvania.
15. If for any reason whatsoever any part of this Agreement shall
be declared void or invalid, only such part shall be deemed void and in
all other respects this Agreement shall remain valid and fUlly
enforceable.
16. The waiver of any term, condition. clause. or provision of
this Agreement shall in no way be deemed or considered a waiver of any
other term, condition, clause or provision of this Agreement.
IN WITNESS WHEREOF, the parties hereto have set. their hands and
seals the day and year first above written.
~l
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Wi ess
fLvo?Jd~~
CONNEE 1.. HEMPT
8
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COMMONWEALTH OF PENNSYLVANIA )
( SS.:
COUNTY OF CUM8ERLAND )
On thill, the ;ZyJLday of t:ebrll'oM.'f ' 19~' hofore me, the
undersigned officer, personally appeared MICHAEL A. HEMPT known to me
(or oatisfactorily proven) to be the person whose name 1s sUbRcribed to
the within instrument, and acknowledged that s~id person executed same
For the purposes therein contained.
TN WITNESS WHEREOF, I hereunto set my hand and official seal.
My conf~i~'~Jires:
NowIaI Seal
~~~b~
Myc...........,EliI*us~ 17, lQQs
COMMONWEALTH OF PENNSYI.VANIA )
. (SS. :
COUN'I'Y OF C1II1BEl\LoI\ND...l>1W'HltJ I
On thts, the;:JqP1 day of tlIiru.JJ}A.(.,j , 1996, hefore me, the
undersigne~ officer, personall~a~~~~ CONNEE L. HEMPT known to me (or
satisfactorily provenl to be the persoll whose name is subscribed to the
within instrument, and Iwknowledged that s~jd person executed same for
the purposeR therein contained.
IN WITNESS WHEREOF, I hereunto set lilY h~nd and ofticial seal.
NOlatia'S<l..1
K,fe~ ~ 5hO":1, Neto/}' PubUc
M Co lItr S urg, Dauphin County
Y mmlssloll EJ<pl,es March rf, 1098
MeIiiiir, PtrniSt:'anI:I~ oI'lIoIai8S
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CXlNNEE HEMP!',
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
CIVIL ACTION - LAW
1778
VB.
MICHAEL A. HEMP!',
NO.
CIVIL
19 94
Defendant
: IN DIVORCE
STATUS SHEBT
DATE:
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.
OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240-6535
E. Robert Elicker, II
Divorce Master
Trecl .10 Colver
Office Manager/Reporter
Maria P. Cognetti
Attorney at Law
132-134 Walnut street
P.O. Box 689
Harrisburg, PA 17108-0689
We.t Shore
697-0371 Ext, 6535
January 27, 1995
Samuel L. Andes, Esquire
ANDES, VAUGHN & BANGS
525 North Twelfth Street
P.O. Box 168
Lemoyne, PA 17043
RE: Connee Hempt vs. Michael A. Hempt
No. 94-1778
In Divorce
Dear Ms. Cognetti and Mr. Andes:
By order of Court of President Judge Harold E. Sheely
dated January 25, 1995, the full-time Master has been appointed
in the above referenced divorce proceedings.
A divorce complaint was filed on April 7, 1994, raising
grounds for divorce of indignities and ir~etrievable breakdown.
The complaint also raised the economic claim of equitable
distribution. On January 25, 1995, the Plaintiff filed a
petition raising the additional economic claims of alimony,
alimony pendente lite, and counsel fees and expenses.
It is my understanding based on correspondence from
counsel that the parties are agreeable to consent to a divorce
so that the divorce can proceed under Section 3301(cl of the
Domestic Relations Code. Based on that assumption I am
directing each counsel in accordance with P.R.C.P. 1920.33(bl to
file a pre-trial statement on or before Friday, February 17,
1995. Upon receipt of the pre-trial statements I will
.
Ms. Cognetti and Mr. Andes, Attorneys at Law
27 January 1995
Page 2
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 (cl and (dl 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.
CONNEE HEMPT,
Plaintiff
.
.
.
.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
VS.
NO. 177S CIVIL 1994
MICHAEL A. HEMPT,
Defendant
IN DIVORCE
NOTICE OF PRE-HEARING CONFERENCE
TO: Maria P. Cognetti
Samuel L. Andes
, Counsel for Plaintiff
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
1st day of May, 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: 2/22/95
E. Robert Elicker, II
Divorce Master
CONNEE HEMPT,
Plaintiff
vs.
MICHAEL A. HEMPT,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
.
.
NO.
1778
CIVIL
1994
IN DIVORCE
ORDER AND NOTICE SETTING HEARING
To:
Connee Hempt
Maria P. Cognetti
Michael A. Hempt
Samuel L. Andes
, 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 25th day
of July , 1995, at 9:00 a.m., at which place
and time you will be given tile opportunity to present witnesses
and exhibit~ in support of your case.
Date of Order and
Notice: 51 l/95
By the Court.
~~ ~::::
Harold E. Sheely, presi n Judge
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 (7171 240-6200
CONNEE HEHPT, IN THE COURT OF COMMON PLEAS OF
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
vs. NO. 1778 CIVIL 1994
.
.
MICHAEL A. HEHPT, .
.
Defendant . IN DIVORCE
.
RE: Pre-Hearing Conference Memorandum
DATE: Monday, May 1, 1995
Present for the Plaintiff, Connee Hempt was
attorney Maria P. Cognetti, and present for the Defendant,
Michael A. Hempt was attorney Samuel L. Andes.
The parties were married on July 22, 1978, and
separated on March 11, 1994. Mr. Andes is going to verify with
his client that the date of separation as stated by wife is the
correct date.
A divorce complaint was filed on April 7, 1994.
The divorce complaint raised grounds for divorce of
irretrievable breakdown of the marriage and indignities, and the
economic claim of equitable distribution. On January 25, 1995,
wife filed a petition raising the additional economic claims of
alimony, alimony pendente lite, and counsel fees and expenses.
Counsel have indicated that the parties will sign
and file affidavits of consent prior to the hearing to be
scheduled in these proceedings so that the divorce can conclude
under Section 3301(c) of the Domestic Relations Code.
with respect to the alimony claim raised by wife,
wife's counsel has indicated that she will withdraw that claim
so that we need not consider any issues regarding the factors
relating to alimony including marital misconduct. The remaining
economic claims, therefore, are equitable distribution and
counsel fees and costs.
The parties are the parents of four children,
Corrine D., born February 22 1982; Julie L., born May 25, 1984;
Erin M. and Michael A., born August 28, 1986. The four children
are currently in the custody of wife. Husband pays support
through the Cumberland County Domestic Relations Office for the
children in the amount of $175.00 per week. In addition, each
parent is required to pay one-half of medical costs. There is
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no order for spousal support.
wife is a high school graduate. She resides at
3S90 Mountain view Road, Mechanicsburg, Pennsylvania, where she
lives with the four children. She is a programmer with
Pennsylvania Blue Shield and shows a gross biweekly income of
$1,775.00 and a net biweekly income of $1,224.35. She has
raised no issues with regard to health matters. If the case
goes to hearing, wife is requested to provide a current pay
statement.
Husband is a high school graduate and he resides at
505 Third Street, New Cumberland, Pennsylvania, where he lives
alone. However, he is working for Carolina Freight Carriers
Corporation and has taken a job in Philadelphia because of a
transfer of company operations. He is a dock worker and showed
a 1994 gross income of $37,915.72. Mr. Andes indicated he
believes his income for 1995 will be around the same amount.
If the case goes to hearing, husband is requested to provide a
current pay statement.
Wife is 38 years of age and husband is 39 years of
age.
The marital residence, which is being occupied by
wife and the children, has been appraised by two appraisers,
Mark Hilbert for the wife who placed a value on the home at
$95,000.00 and Don Paul Shearer for the husband who placed a
value on the home at $120,000.00. The home is not titled in
the names of the parties because they are purchasing the home on
an installment sales agreement and have not yet received the
deed since the agreement has not been paid off. The approximate
balance due on the sales agreement owed to Wilbur Radabaugh is
$30,000.00.
There are three vehicles involved in this action as
follows:
1991 Chevrolet conversion van -- Wife has placed a value
on the van at $13,500.00 less a personal loan which is
not specifically a lien as shown on the title of the van
but is a loan wife claims she took out to purchase the
van in the approximate amount of $7,500.00. Therefore,
the net equity in the van is around $6,000.00.
1991 Yugo -- Husband has placed a zero value on the Yugo;
however, wife's attorney indicated that the Yugo was
traded in on another vehicle and she would like to know
the trade in value.
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1990 Chevrolet Suburban -- The parties and counsel are
going to seek a purchaser for the Suburban since it is
not being used by either of the parties and that money
will be distributed as part of the equitable distribution
in the case.
Husband has a pension plan through his employment
with the Teamsters and wife has a plan with her employment with
Pennsylvania Blue Shield. Each of the parties is going to
retain their respective plan and the values will not need to be
produced regarding the plan for the equitable distribution
computation. However, husband has an employees savings and
protection plan which his counsel has indicated has an
approximate value as of date of separation of $15/103.90. Wife
has a VIP 401(kl plan which wife's attorney claims has a date of
separation value of $23/654.00. This value takes into account a
loan against the plan that is being paid off by wife in the
approximate amount of $1,005.00. Further, with regard to the
VIP 401(kl plan, Mr. Andes has requested verification that they
are in fact the same entity and are not two separate savings
plans.
The household personalty, most of which we believe
is in the possession of wife, shall be appraised by Kerry Pae.
He shall appraise all of the tangible personal property in
wife's possession in the house and then counsel can indicate
after discussion with their clients what items may be nonmarital
in trying to determine what property is subject to distribution
in the case.
Husband has an agreement with three other
individuals involving ownership of a cabin in Clinton County.
He places a value on the cabin of $825.00 which apparently was
the amount of money that he utilized in buying in to the
ownership with the other three individuals. If wife believes
that there is a greater value then she may decide to have the
cabin appraised.
Husband has an IRA with Dauphin Deposit and the
value as shown on the statement as of April 13, 1994/ was
$4,638.87. Counsel are requested to provide a current
statement as to the value of that plan since no contributions
have been made to the plan since the separation.
Wife has produced information regarding her PSECU
savings account showing a date of separation balance of $210.89.
The Mellon Bank savings account and Mellon Bank
checking account were closed in May 1994. They were in
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husband's name and we need to have a date of separation
statement on those two accounts. Likewise, with the Teamster's
credit union account in husband's name, we need to have a date
of separation statement. Husband has produced a statement as
of June 30, 1994, showing a value of $73.01. The reason we need
the date of separation balance is to determine if husband
withdrew funds from the account from the date of separation to
June 30, 1994.
Husband's attorney has asked wife's attorney to
provide information as to whether or not a Delaware Group Mutual
Fund exists and, if so, what the date of separation value of
that account was.
The Master will arrange to have an appraiser of his
selection inspect the property and if necessary, appear at the
hearing to testify, at the expense of the parties. The
attorneys are directed to respond to the Master about the issue
of that expense before the Master hires an appraiser.
The parties have agreed to exchange all information
required in this memorandum within thirty (301 days.
A hearing is scheduled for Tuesday, July 25, 1995,
at 9:00 a.m. Notices will be sent to counsel and the parties.
E. Robert Elicker, II
Divorce Master
cc: Maria P. Cognetti
Attorney for Plaintiff
Samuel L. Andes
Attorney for Defendant
~~ (===
Harold E. Sheely,
Judge
CONNEE HEMPT,
PLAINTIFF'
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs.
CIVIL ACTION - LAW
NO.
1778
CIVIL
1994
MICHAEL A. HEMPT,
DEFENDANT
IN DIVORCE
RESCHEDULED
ORDER AND NO'l'ICE SET'rING HEARING
To:
Con nee Hempt
Maria P. Cognetti
Michael A. Hempt
Samuel L. Andes
. 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 November ,1995, at 9:00 a.m., at which place
and time you will be given tile opportunity to present witnesses
and exhibits in support of your case.
By the Court.
Date of Order and
Notice: 7/20/95
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 (7l71 240-6200
o
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.en", lo/f"'" r(
Maria P. Cognctti
200 North Third Street
Twelfth Floor
P,O, Box 689
Harrisburg, PA 17108.0689
(7171232-2103
Fax (717) 232-S77S
Practice Limited 10 Family and Malrimonlall.aw
MARtA p, COONllTIlt
KAREN A, SHERIFF
Lcpl ABalatant
t
Fellow, Ameri... Academy
orMatrlmonllll.awycn
V~ry truly yo~,
/(i// ///?/~"7i1l '
~~Ogn~~
April 12, 1996
E. Robert Elicker, II
Divorce Master, Cumberland County
9 North Hanover Street
Carlisle, PA 17013
RE: HEMPT V, HEMPT
Dear Mr. Elicker:
Enclosed please find two copies of the Property Settlement Agreement in the
above referenced matter. If there is anything we must do to revoke your appointment,
please let us know,
MPC/jms
Enclosure
cc: Samuel L, Andes, Esquire
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ANDES, VAUOHN & BANOS
ATTOHNIlYS AT I.AW
~g3 NOIITU TWP.LPTII STREET
P.O, UOX IOU
LIlNOYNE, PENNSYLVANIA 17043
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11171701'1435
18 July 1995
E. Robert Elicker, II, Esquire
Divorce Master
9 North Hanover Street
Carlisle, PA 17013
RE: Hempt
Dear Mr. Elicker:
I write to confirm my discussion with Tracy earlier today.
The appraisals for the above case are not yet complete and Maria
P. Cognetti, Esquire, and I have agreed to postpone the hearing
to give us a chance to complete the appraisals and attempt,
again, to settle the case. We ask that you reschedule the case
for late August or early September. By then we expect to have
the appraisals and the negotiations completed.
Thank you for your consideration.
Sincerely,
ANDES, VAUGHN & BANGS
S~des
lag
cc: Maria P. Cognetti, Esquire
Mr. Michael A. Hempt
.!1",lqflnu l'
Maria P. Cognctti
132-134 Walnut Street
P,O, Box 689
Ilarrlsburg, PA 17108.0689
(717) 232-2103
Fax (7171 232-S77S
I',acllce I.ImUed to I'lII11l1y and MIlrlmonllll.aw
MARIA P. COGNETIl'
STEFANIE J, DILL
KAREN A, SIIERlFF
lei" Au Slant
I
Fellow, Amcrl~ Academy
of MIlrlmonlall.aW)'e"
February 17, 1995
E, Robert Elicker, II
Divorce Mnsfer
9 North Hanover Street
Carlisle, P A 17013
RE: HEMPT V. HEMPT
DOCKET NO. 94-1778 CIVIL TERM
Dear Mr, Elicker:
Enclosed please find the following documents with regard to the above-referenced
matter:
I, Plaintill's Pretrial Statement;
2, Plaintill's Inventory and Appraisement;
3, Plaintill's Income and Expense Statement.
After you have received both parties' documents, I would appreciate your
contacting me to schedule the Prehearing Conference, Thank you for your attenfion to
this matter, Should you have any questions, please do not hesitate to contact me, I look
forward to hearing from you,
MPC/sjd
Enclosure
cc: Connee L, Hempt
Samuel L. Andes, Esquire
Vcry truly you
;t{~.
Maria P. ,i,gnett
.ANUJl:L L. ANnllR
OIlOROII A. vAuOIIH. UI
NICHABL L. DAHO.
",. BART PUOMa
Atoms, VAllOHN 8: BANOS
ATTOIfNHYH AT lAW
ngn NOItTII TWIU.J'TII HTnKKT
n o. nox 1011
I.EMOYNIl, PENNSYLVANIA 170.13
TaupnOHa
nnl ,al.&Oel
l5 February 1995
...x
Ifl,. ,el-I4015
B. Robert Blicker, II, Bsquire
Office of the Master
9 North Hanover Street
Carlillle, PA l7l03
RB: Connee Heapt VII. Michael A. Heapt
No. 94-l778 Civil Term
Dear Mr. Blicker:
Bnclolled ill the Pre-Trial Statement which I file on behalf of the
Defendant, Michael Heapt, in the above Matter, in accordance with your letter
of 27 January 1995.
Plealle IIchedule a pre-hearing conference at your early convenience so we
can try to get thill aatter reBolved. Thank you for your cooperation.
Sincerely.
ANDBS, VAUGHN & BANGS
~<~.
ue L. Andes
le
Bnclosure
cc: Maria P. Cognetti. Bsquire
",..;-.
.~;;;jt(!'~:;.'!~..~,.?v.~
__-'--1:,
'l'ELEPHONB
(717) 232.2103
~uo ~1IJ,y
Maria P. Cognetti
132.134 Walnul Street
p, 0, Box 689
Harrisburg. P A 17108.0689
'I'Eu!coPIBR
(717) 232.S77S
January 19, 1995
E. Robert Elickcr, Divorce Mastcr
9 North Hanover Street
Carlisle, PA 17033
RE: HEMPT V. HEMPT
Dear Bob:
I am in receipt ofa copy of Mr. Andes' letter to you dated January 5, 1995. Please
be advised that my client will in fact consent fo the divorce so that you may immediately
address the economic issues. Please be advised that I will be filing a Petition for
Alimony, Alimony Pendente Lite and Counsel Fees as well as a revised Motion for
Appointment of Master covering those issues.
If you have any questions, please do not hesitate to contact me, Thank you for
your attention to this matter.
Very truly yours
J{a'
Maria p~etti
,
MPC/sjd
cc: Connee Hempt
Samuel L. Andes, Esquire
l~::...;:~.:" .)-'~~
."MUIL L. ANP..
OISOMOB A. VAUOIIH, m
MICttABL L. DANai
oJ. BAHT D.LOHB
^NDI~S, VAUOHN Be BANOS
ATTOUNEYS AT J.AW
aaa NOHTJI TWELFTII STReET
...0, UOX lOti
LEMOYNE, I'ENNSYLVANIA 17043
TIL.rUONB
(J111 '81-D301
5 January 1995
'AX
('Ill JOlol4:JD
B. Robert Blicker, II, BBquire
Office of the Mallter
9 North Hanover street
Carlisle, PA l7l03
RB: Connee Hempt VII. Michael A. Hempt
No. 94-l778 Civil Term
Dear Mr. Blicker:
I reprellent the Defendant in the above matter.
I am now in the process of filing a Motion for Appointment of Master. I
expect that both parties will lIign conllentll to the divorce so that you can
address the economic issues immediately. My client is certainly willing to do
BO. If Mrll. Hempt will not file an Affidavit of Consent, I will file a
counterclaim and proceed on fault grounds. In either event, my client wants to
have your office address the economic issues as lIoon as pOllllible. The partiell
have exchanged extensive financial information and can quickly be ready to
prosent their calle.
I have written to Maria Cognetti and requested that IIhe confirm to your
office whether or not her client will file an Affidavit of Consent. Hopefully
we will hear from her within the next ten days. If we do not, I will take her
silence to mean that her client will not lIign such an affidavit and I will then
prepare and file an amended complaint 110 you can schedule a hearing on fault
grounds.
Hopefully you will hear affirmatively from Maria within the next ten days
and we can proceed to the economic issues. If you have any questions, or any
problems with the procedure I propose, please contact me at your convenience.
Thank you for your cooperation in the meantime.
Sincerely.
le
ANDBS, VAUGHN & BANGS
r-;)
~s
Bnclosure
cc: Maria P. Cognetti, Bsquire
,.
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CONNEE HEMPT,
IN TilE COURT OF COM110N PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Plaintiff
vs.
:'
94-l778
,19
MICHAEL A: IIEMPT,
Defendant
.NO.
MOTION FOR APPOINnlENT OF MASTER
. MICHAEL A;HEMPT, (~SNQ (Defendant).
a master vith respect to the follo~ing claims:
( ') Divorce
( ) ,Annulment
( ) Al1lllony ,
.( ) Al1lllony Pendente Lite
moves the court to appoint
(X)
( )
( )
( )
Distribution of ~roperty
Support
Counsel Fees
Costs and Expenses
and in support of the motion states:
(1) Discovery is complete as.to the cla1llls(s), for ~hich the
appointment of a master is requested.
(2) The Plaintiff (has) (~Mt) appeared i.n the action (~K~
(by l\er attorney, MARIA P. COGNETTI ,Esquire).
(3) The staturory ground(s) for divorce (is) (are)
Section 3301 (el ..
(4) Delete the inapplicable paragraph(s):
(a) The action is not contested.
(b) An agreement has been reached vith respect to the
None
(c) The action is contested ~ith respect to the follo~ing
equitable distribution
(5) The action .(~\1B9 (does 'not involve) complex issues of la~
(6) The hearing is expected to take 1 day. (~ (di:KJa').
(7) Additional information, if any. relevan~ to the motion:
None
folloving claims:
C,la1llls:
or fact.
Date:
.
Attorney for (RlJ!J~ Sanuel L. Andes
(Defendant)
ORDER APPOINTING MASTER
AND NPW ,19_,
is' appointed master with respec~ to the follo~1nB cla1llls:
.'
Esquire,
By the Court:
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MICHAEL A. HEMPT, : IN THE COURT OF COMMON PLEAS OF
Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs. . NO. l778 - CIVIL - 1994
.
.
.
CONNEE L. HBMPT, : CIVIL ACTION - AT LAW
Respondent : CUSTODY
Ii
I
I
,
I
I attorneys, The Law Offices of Patrick F. Lauer, Jr., files this
I
I
L Petition to Modify Order of Custody against the Respondent, and in
ii
i i support thereof, avers the following:
'1
II
,.
\1
:1 Defendant in original action, who currently resides at 505 Third
II Street, New Cumberland, Cumberland County, Pennsylvania l7070.
\1
11
I'
,I Plaintiff in original action, who currently resides at 3790
il
'[ Mountain View Road, Mechanicsburg, Cumberland County, Pennsylvania
117055.
PETITION TO MODIFY ORDER OF CUSTODY
The
Petitioner,
Michael A.
by
and through
his
Hempt,
1.
The Petitioner is Michael A.
the father and
Hempt,
2.
The Respondent is Connee L.
the mother and
Hempt,
3. The parties hereto are the parents of the following minor
i! children: Cor inne Hempt, born February 22, 19 8 2 ; Julie Hempt,
iI
ii born May 25, 1984; Michael Hempt, Jr., born August 28, 1986; and
"
i
il Erin Hempt, born August 28, 1986. The location of the children is
;!
currently with their mother, Connee L. Hempt, who resides at 3790
Mountain View Road, Mechanicsburg, Cumberland County, Pennsylvania
17055.
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4. Pursuant to an agreement of the parties on February 7,
1995, the Honorable Kevin A. Hess awarded primary physical custody
of the minor children, Corinne Hempt, Julie Hempt, Michael Hempt,
and Erin Hempt to the mother, with visitation to the father two
days per week, the days to be determined by his work schedule, on
alternating holidays, and two weeks each summer. A copy of the
Order of February 7, 1995 is attached hereto as Exhibit "A" and
incorporated herein by reference.
5.
Since the Court's awarding of primary custody to the
'II
mother, a substantial and material change in circumstances has
I
i
i
occurred, giving rise to the filing of the instant Petition:
I
I!
I
I
a. The Petitioner has returned to the Harrisburg
area after an extended work-related transfer to
the Philadelphia area.
b. The Petitioner is once again able to excercise
parental rights and responsibilities in the manner
followed by the parties prior to his transfer.
6. The best interest and permanent welfare of the children
, will best be served by a modification of the Court's Order as
i
: follows:
!
i
I
a.
The Petitioner, Michael A. Hempt, be granted
custody, partial custody, or visitation of the minor
children.
b. Liberal visitation be ordered so that the children
may have continued contact with both of the parties.
c. Legal custody of the minor children be shared
between the parties.
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WBBRBPORB, Petitioner respectfully requests that this
I Honorable Court modify its Order as follows I
a. The Petitioner, Michael A. Hempt, be granted custody,
partial custody, or visitation of the minor children.
b. Liberal visitation be ordered so that the children
may have continued contact with the mother.
c. Legal custody of the minor children be shared between
the parties.
Date I
q~Of
Re~lll~~r. r'
Matthew J. Eshelman, Esquire
Law Office of Patrick F. Lauer, Jr.
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID' 72655 Tel. (7171 763-1800
I
,
I
II
il
!
MICHAEL A. HBMPT,
Petitioner
I IN THB COURT OF COMMON PLBAS OF
I CUMBBRLAND COUNTY, PBNNSYLVANIA
I
I NO.
I
: CIVIL ACTION - AT LAW
: CUSTODY
vs.
CONNBB L. HBMPT,
Respondent
VERIFICATION
I, MICHAEL A. BEMPT, state that I am the PBTITIOHBR in the
above-captioned case and that the facts set forth in the above
PBTITION are true and correct to the best of my knowledge,
information, and belief. I realize that false statements herein
are subject to the penalties for unsworn falsification to
authorities under l8 Pa, C.S. S 4940.
"
Date: q - \l. q\.o
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FEB a 1995d--
copy
Tln,F. O)f"'f FP.OM RrCORD
In T .-,"1:\.111', , j" reo', I h, rc I::ilo ',(,1 lilY h~nd
or,d 11111 ~t'~1 '. f ~"itl ('lllrl nl t:.nlislo, r~,
1hl, . . .,.L!- d~y oL,....:;F..,,~:.., 19,9.f..
--'--"'~~~1\ Jl::.:,~..u;,.41.t....___..
):>j1j-' FfIllhollotary
v
'IN THE COURT OF COMMON PLEAS OF
'CUMBERLAND COUNTY, PENNSYLVANIA
,
:NO. 1778 - CIVIL - 1994
,
,
,CIVIL ACTION - CUSTODY
MICHAEL A. HEMPT,
Plaintiff
CONNEE L. HEMPT,
Defendant
COUR~ ORDER
AND NOW, this ?:JA.day of J..c.l.-t~ ' 1995, upon consideration
of the attached Custody Concil at on Report, it is ordered and
directed as follows,
1. The prior Orders in this case are vacated except for
Paragraph 2 of this Court's Order of December 19, 1994,
that dealt with future Christmas holidays.
2. The Father, Michael A. Hempt, and the Mother, Connee L.
Hempt, shall continue to enjoy shared legal custody of
Corinne D. Hempt, born February 22, 1982, Julie L. Hempt,
born May 25, 1984, Erin Michelle Hempt and Michael A.
Hempt, Jr., (twins) born August 28, 1986.
3. The Mother shall enjoy primary physical custody of the
minor children.
4. The Father shall enjoy periods of temporary physical
custody on a reasonable basis as allowed by his work
schedule. Father shall advise Mother in advance of
his work schedule and give Mother reasonable notice as
to when he desires to exercise temporary custody.
Under no circumstances shall the periods of temporary
custody exceed three weekends per month.
5. This Order is entered pursuant to an agreement reached
by the parties at a Custody Conciliation Conference.
In the event either party desires a modification of this
Order, that party may petition the Court to have the case
again scheduled with the Custody Conciliator.
BY THE COURT,
J~d~e~"e'~1: A:~;;:
cc: Maria Cognetti, Esquire-3401 Front Street, Harrisburg 17108
Michael L. Bangs, Esquire
MICllABL A. HEHPT,
Plaintiff
v
, IN THE COURT OF COMMON PLEAS OF
'CUMBERLAND COUNTY, PENNSYLVANIA
,
'NO. 1778 - CIVIL - 1994
,
,
:CIVIL ACTION - CUSTODY
CONNBE L. HEMPT,
Defendant
PRIOR JUDGE' JUDGE KEVIN A. HESS
CONCILIATION CONF1l:Rl:NCE SUMHARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL 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:
Corinne D. Hempt, born February 22, 1982, Julie L. Hempt,
born May 25, 1984, Erin Michelle Hempt and Michael A.
Hempt, Jr., (twins) born August 28, 1986.
2. A Conciliation Conference was held on January 26, 1995, with
the following individuals in attendance:
The Father, Michael A. Hempt, with his counsel, Michael L.
Bangs, Esquire, and the Mother, Connee L. Hempt, with her
counsel, Maria Cognetti, Esquire.
3. The parties agreed to the entry of an Order in the form as
attached.
.
tl~l( lis-
DATE
CJ6. f1
Hubert X. G lroy, squ
Custody Conciliator
.
_ ,~" ,"!bti4 -~:~:~~::'~.
SHERIFF'S RETURN - REGULAR
CAS~ NOI 1991-01778 P
COMI10NWEALTIl O~' PENNSYLVANIA I
COUNTY Of CUI1B~;RL^ND
!IEM.f'T C.QNNEE
VS.
1l~:I1I'T I1ICHAEL A
_I{A1.1!'{ J. CARPf.R____...... ..___.._._.__../ Sheriff or Daputy Sheriff of
CUI1BERLAND County, Pennsylvania. who being duly sworn according
to law. says, the within QR.DF,B._QE-COURT _._.______ was serv6'd
upon 1l~:MI'I CO!!NIl; ...______.__._______._________.___. the
defendant, at 1137100 HOURS. on the 15th day of November
1996 at .__ItLUE SJLU:I.D 200 Q,QJ!PORATj': CF.NTF.R
!:!A!1P II.I l."u_J~1'-170_11.__ ...... ____.. . CIJllBERL.A.ND
County. Pennsylvania, by handing to CONNIE Il~MPT
a true and attested copy of the ORDER OF COURT
together with PETITION TO....1!PDtfY__.g.USTODY & LETTERS
and at the same time directing Re~ attention to the contents thereof.
.
Shariff's CostSI
Docketing
Service
Affidavit
Surcharge
18.00
9.30
.00
2.00
So answersl~~~ ~~~
r-~;....-'< ~
H. Thomas K~1ne, ~her1-
e29.~0 PATRICK LAUER
11/18/1996
by
I~Jl!<~
Sworn and subscribed to bafore me
this .....:!.o ~._ day of J'l.:<,.,< v,-p.. '. __.. _
19__qt".__ A. D.
--~~-G'o't~~hr"t Llfii" .....-.
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MICHAEL A, HEMPT,
Plaintiff
vs,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
94.1778 CIVIL
CONNEE L, HEMPT,
Defendant
CIVIL ACTION. LAW
CUSTODY
ORDER
AND NOW, this
2.,.
day of September, 1998, at the request of counsel for
the parties, hearing in this matter is continued generally pending receipt of an agreement.
BY THE COURT,
Matthew], Eshelman, Esquire
For the Plaintiff
Maria Cognetti, Esquire
For the Defendant
~ /",..d.J..L "l'/;)/ J qt,
>01, "fJ.
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F1LED-O,':FICE
OC' TL": ":')'TfL;n,' "'l'Any
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98 SEP 2/ Fi'; 2: ~ 3
CUMGEFU,,\O COUNTY
PI:NNS\'LVlWL<\
.
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r .,~ i ;; lHlf};
vs.
I IN THE COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I No. 94 - 1778 - CIVIL TERM
I
I CIVIL ACTION - AT LAW - CUSTODY
I PREVIOUSLY ASSIGNED TOI J. HESS
MICHAEL A. HEMPT,
Petitioner
CONNEE L. HEMPT,
Respondent
AND NOW, this
SCHEDULING ORDBR
I~ ~ day of -);;/1 1(? /' /'
19.2..2., upon
Praecipe of the Petitioner, Michael A. Hempt, a hearing is
scheduled in the above-captioned matter in Courtroom Number 4 of
the Cumberland County Courthouse, Carlisle, Pennsylvania, on the
,)<,/tl/ day of I,! " I I- 19'i?, at 9; (IU o'clock ..Q....m.
I
A total of J
hours has been set aside for the hearing,
and the parties will be expected to present their cases within that
timeframe. Updated Pre-Trial Memoranda shall be filed with the
Court and upon opposing counsel at least ten (10) days before the
hearing.
BY THE COURT:
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MICHAEL A. HEHPT,
Petitioner
I IN THB COURT OF COMMON PLBAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I No. 94 - l778 - CIVIL TBRM
I
I CIVIL ACTION - AT LAW - CUSTODY
I PREVIOUSLY ASSIGNBD TOI J. HESS
vs.
CONNEE L. HBHPT,
Respondent
PRAECIPB TO RBLIST HBARING
1. The Petitioner is Michael A. Hempt, Defendant in original
action and the natural father of the following minor children:
Corinne Hempt (02/22/821; Julie Hempt (05/25/84); and the twins,
Michael Hempt, Jr., and Erin lIempt (08/28/86).
2. The children' reside primarily with their mother, the
Respondent Connee L. Hempt at 3790 Mountain View Road,
Mechanicsburg, Cumberland County, Pennsylvania l7055.
3. The above-captioned matter was last scheduled for hearing
before the Honorable Kevin A. Hess for August 18, 1998.
4. The hearing was continued generally by agreemenl- ~f
counsel, permitting mediation services of Doctor Stanley Schneider.
5. Dr. Schneider came up with a proposal to which the
parties have verbally agreed; however, parties have been unable to
6.
Parties have been before a conciliator six times already,
7.
The Petitioner believes the remaining matters can be
Date: ~
ew J. Eshelman, Esquire
ark t Street, Aztec Building
Camp Hill, Pennsylvania 1701l-4706
ID# 72655 Tel. (7l71 763-1800
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MARIA P. COONETfI'
Cognctti & Braderman
'Fellow, American Academy
or Matrimonlll Lawym
lAY R. DRADERMAN
KAREN A, SIIERIFF
Parol.pl
April 16, 1999
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Mr, Curtis R, Long, Prothonotary
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
RE: HEMPT v. HEMPT
DOCKET NO. 94-1778
Dear Mr. Long:
Enclosed for liling please find an original and three (3) copies of the Defendant's
Pre-Trial Memorandum prepared in the above-referenced matter, Please time-stamp our
copies and return them to us in the self-addressed, stamped envelope provided.
If you have any questions, please do not hesitate to contact us, Thank you for your
assistance in this matter,
Very truly yours,
~l.R1L'
t1J~ A. Sheriff
Legal Assistant
KAS/drc
Enclosure
cc: Connee L. Hempt
II\Wp'J'OIlMS\MISC'\C'C'ty Doct ror nlln._pd
(717) 232-2103' (717) 232-6600' Fax (717) 232-5775
200 North Third Street. Twelfth Floor' P.O. Box 689 . Harrisburg, P A 17108-0689
MICHAEL A, HEMPT,
Plaintiff
v,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 94-1778 CIVIL TERM
CONNEE L. HEMPT,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
DEFENDANT'S PRE-TRIA~ M&MORAISDUM
AND NOW, comes the Defendant, Connee L. Hempt, by and through her
attorney, Maria p, Cognetti, Esquire, and submits the following Pre-Trial Memorandum:
I.
ANTICIPATED EXPE;,RT WITNESSES:
Defendant does not intend
to call any expert witnesses, However, Defendant reserves the right to call expert
witnesses as may be necessary to respond to evidence submitted by Plaintiff.
II. ANTICIPATED FACTUAL WITNESSES: Defendant intends to call
the following factual witnesses:
A. Connee Hempt, Defendant - Ms. Hempt will testify to the attitudes
of her children and their father and all matters relevant to the custody ofthe
children, She will further testify as to what she believes to be an appropriate
schedule for custody.
B, Michael A, Hempt, Plaintiff, as of cross.
II IWf'IJIAD_,",," PT'
./1-
C. Sarah Hooven, Defendant's mother. Mrs, Hooven will testify to the
attitudes of the children and their father and all matters relevant to this cUSiody
action.
D. Michael A, Hempt, Jr., parties' child. Michael will testifY to his
relafionship with each parent and his opinion regarding the summer schedule.
E Erin M. Hempt, parties' child - Erin will testifY to her relationship
with each parent and her opinion regarding the summer schedule.
III. PROPOSED RESOLl!TlON: Defendant would propose the following
schedule as a resolution of this matter:
A. The parties would have shared legal custody of the children.
B. Mother would have primary physical custody of all four children,
Father would have partial physical custody of the children in accordance with the
following schedule:
I, Three weekends out of every four weekends, from Thursday
after school until Saturday at 7:00 p,m. Mother shall have the option of
reserving three weekends per calendar year for the purpose of special
occasions which she cannot schedule on her weekends, Le, family weddings
and special events, Mother shall give Father 30 days written notice of the
weekends she intends to reserve,
1"..,;:.-.",., ~.;,"""'1
II \Wp\Pt.lJJ)fNCNIDCPTPTI 411619t
2. The holidays of Memorial Day, Fourth of July, and Labor
Day, shall be alternated between the parties, The holidays shall be defined
as beginning at 9 a.m, the day of the holiday and ending ut 9:00 p,rn. the day
of the holiday, In even numbered years Mother shall have Memorial Day
and Labor Day and Father shall have July Fourth, In odd numbered years,
Father shall have Memorial Day and Labor Day and Mother shall have July
Fourth,
3, With regard to the Easter holiday, Mother shall be entitled to
the Easter holiday and the accompanying spring break, (Mother has
hisforically taken the children to Florida during this period offime, even
prior to the parties' separation,)
4, With regard to Thanksgiving, Mother shall have
Thanksgiving Day until 3:00 p,m, Father shall have Thanksgiving Day
from 3:00 p.m, until 9:00, lfthe weekend following the holiday is Father's,
then he shall keep the children until the conclusion of his weekend,
5. With regard to the Christmas holiday, in even numbered
years, Father shall have Christmas eve from 5:00 p,m, until 10:00 p,m, and
Christmas Day from 3:00 p,m. until 10:00 p,m. In odd numbered years,
Father shall have Christmas Eve Irom 5:00 p,m, until Christmas Day at
noon, Mother would have the balance of the Christmas Holiday,
,<<. ..
II IWlI'I\.BAIHHlNlIIWPT'tI
"1-
6. During the summer, each party shall be entitled to three (3)
non-consecutive weeks of custody. A week is defined as Sunday at 7:00
p,m, to Sunday at 7:00 p,m. Said weeks shall include the party's regularly
scheduled weekend, The parties are required to give the other sixty (60)
days written notice of the weeks he or she plans to take vacation. Ifboth
parties desire the same weeks, in that event, the party giving firsf notice
shall be entitled to the time,
C, Father shall provide all transportation for custodial periods, (This is
due to the fact that fhe parties' children are very active in athletics and other interests.
Mother provides all tmnsportation for these events,)
D. Father shall not come within twenty fcet of Mother or her vehicle
and Father shall stay in his automobile when dropping off the children, (Plaintiffwns
subject fo a PFA from approximatcly Octobcr 1994 through October 1995 and again from
approximately April 1996 through April 1997 due to his hamssing behavior of Defendant.
Plaintiff has in the'past caused damage to Defendant's automobile, Defendant sfiII fears
Plaintiff and would ask that any custody order indicate that Plaintiff
1\ IWp'AIIAlllNlNII!MPT PTI
(;-"''':'7'''''.-'' ,
411_
not have any physical contact with her or her automobile and that when dropping off the
children Plaintiff be required to stay in his automobile,)
Dated: April 14, 1999
Respectfully submitted,
CDGNETII & BRADERMAN
By:
Maria P. C gnetti quire
Sup. Ct. I.D, #27914
200 North Third Street
Twelfth Floor
P.D, Box 689
Harrisburg, P A 17108-0689
(717) 232-2103
.
It \WplILIADlNWlIWPT.PTI
"I.....
~IFICA'I:t: OF SERVICE
I, Maria P. Cognetti, Esquire, Attorney for Defendant herein, do hereby certify that
on this date I served the foregoing Pre-Trial Memorandum by depositing a true and exact
copy thereof in the United States mail, first class, postage prepaid, addressed as follows:
Matthew J. Eshelman, Esquire
2108 Market Street, Aztec Building
Camp HilI, P A 17011
Respectfully submitted,
COGNETTI&BRADERMAN
Dated: April 14, 1999
MICHAEL A. HEMPT.
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY. PENNSYLVANIA
: NO, 94-1778 CIVIL TERM
v.
CONNEE L. HEMPT.
Defendant
: CIVIL ACTlON - LAW
: IN CUSTODY
)lEFENDANT'S PRE-TRIAL MEMORANDUM
AND NOW, comes the Defendant, Connee L, Hempt, by and through her
attorney, Maria p, Cognetti, Esquire, and submits the following Pre-Trial Memorandum:
I. ANTICIPATED EXPERT WITNESSES: Defendant does not intend
to call any expert witnesses, However, Defendant reserves the right to call expert
witnesses as may be necessary to respond to evidence submitted by Plaintiff.
II, ANTICIPATED FACTUAL WITNESSES: Defendant intends to call
the following factual witnesses:
A. Connee Hempt. Defendant - Ms. Hempt will testify to the attitudes
of her children and their father and all matters relevant to the custody of the
children. She will further testify as to what she believes to be an appropriate
schedule for custody,
B, Michael A. Hcmpt, Plaintiff, as of cross,
b"....c
IIIWI"^IW>IN<NII!MPT "'
C, Sarah Hooven, Defendant's mother - Mrs. Hooven will testify to the
attitudes of the children and their father and all malters relevant to this custody
action.
D. Michael A. Hempt, Jr" parties' child - Michael will testilY to his
relationship with each parent and his opinion regarding the summer schedule,
E Erin M, Hempt, parties' child - Erin will testilY to her relationship
with each parent and her opinion regarding the summer schedule,
III, PROPOSED RESOLUTION: Defendant would propose the following
schedule as a resolution of this matter:
A. The parties would have shared legal custody ofthe children,
8, Mother would have primary physical custody of all four children,
Father would have partial physical custody of the children in accordance with the
following schedule:
I, Three weekends out of every four weekends, from Thursday
after school until Saturday at 7:00 p,m. Mother shall have the option of
reserving three weekends per calendar year for the purpose of special
occasions which she cannot schedule on her weekends, i.e. family weddings
and special events, Mother shall give Father 30 days written notice of the
weekends she intends to reserve,
,~>.. "'."
~. -
411....
(:.. .-,;,...., lttililll:k-~~:"":<
II \W,\PLI!ADIN<NIHMPT m 411&'99
2, The holidays of Memorial Day, Fourth of July, and Labor
Day, shall be alternated between the parties, The holidays shall be defined
as beginning at 9 a,m. the day of the holiday and ending at 9:00 p,rn. the day
of the holiday, In cven numbcrcd ycars Mothcr shall have Memorial Day
and Labor Day and Fathcr shall havc July Fourth, In odd numbered years,
Fathcr shall havc Mcmorial Day and Labor Day and Mothcr shall have July
Fourth,
3, With regard to thc Eastcr holiday, Mother shall be entitlcd to
the Eastcr holiday and thc accompanying spring brcak, (Mother has
historically takcn thc childrcn to Florida during this period oftirne, even
prior to thc parties' scparation,)
4. With regard to Thanksgiving, Mother shall have
Thanksgiving Day until 3:00 p,m, Father shall have Thanksgiving Day
from 3:00 p,m. until 9:00, lfthe weckend following the holiday is Father's,
then hc shall keep thc childrcn until fhc conclusion of his wcekend.
5. With rcgard to thc Christmas holiday, in evcn numbered
years, Fathcr shall have Christmas eve from 5:00 p,m, until 10:00 p,m, and
Christmas Day from 3 :00 p,m, until 10:00 p.m, In odd numbered years,
Father shall have Christmas Eve from 5:00 p,m, until Christmas Day at
noon, Mother would have the balance of the Christmas Holiday.
........
t'.".-, .,....,...
oW"-~' _
II \WpllUlADIMNUlMPT ".
",-
6. During fhe summer, each party shall be entitled to fhree (3)
non-consecutive weeks of custody, A week is defined as Sunday at 7:00
p,m. to Sunday at 7:00 p,m. Said weeks shall include the party's regularly
scheduled weekend, The parties are required to give the other sixty (60)
days written notice of the weeks he or she plans to take vacation. Ifboth
parties desire the same weeks, in that event, the party giving first notice
shall be entitled to the time.
C, Father shall provide all transportation for custodial periods, (This is
due to the fact that the parties' children are very active in athletics and other interests,
Mother provides alltmnsportation for these events,)
D. Father shall not come within twenty feet of Mother or her vehicle
and Father shall stay in his automobile when dropping off the children, (Plaintiffwas
subject to a PFA from approximately October 1994 through October 1995 and again from
approximately April 1996 through April 1997 due to his harassing behavior of Defendant.
Plaintiff has in the'past caused damage to Defendant's automobile. Defendant still fears
Plaintiff and would ask that any custody order indicate that Plaintiff
II.\Wp'fUAD1lKN1EWT m
"I'"
not have any physical contact with her or her automobile and that when dropping olTthe
children PlaintilTbe required to stay in his automobile,)
Respectfully submitted,
COGNETII & BRADERMAN
Dated: April 14, 1999
By:
Maria P. C gnetti quire
Sup. Ct.1.D, #27914
200 North Third Street
Twelfth Floor
P.O, Box 689
Harrisburg, PA 17108-0689
(717) 232-2103
.
II \Wp'#UIADlN<<NlI!MnPTI
"I'"
I, Maria p, Cognetti, Esquire, Attorney for Defendant herein, do hereby certify that
on this date I served the foregoing Pre-Trial Memorandum by depositing a true and exact
copy thereof in the United States mail, first class, postage prepaid, addressed as follows:
Matthew J, Eshelman, Esquire
2108 Market Street, Aztec Building
Camp Hill, PA 17011
Respectfully submitted,
COGNElTI & BRADERMAN
Dated: April 14, 1999
MICHAEL A. HEMPT,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 94-1778 CIVIL TERM
: CIVIL ACTION - LAW
: IN CUSTODY
v,
CONNEE L. HEMPT,
Defendant
DEFENDANT'S PRE-TRIAL l\1EMORANDllM
AND NOW, comes the Defendant, Connee L. Hempt, by and through her
attorney, Maria p, Cognetti, Esquire, and submits the following Pre-Trial Memomndum:
I. ANTICIPATED EXPERT WITNESSES: Defendant does nof intend
to call any expert witnesses, However, Defendant reserves the right to call expert
witnesses as may be necessary to respond to evidence submitted by Plaintiff.
II, ANTICIPATED FACTUAL WITNESSES: Defendant intends to call
the following factual witnesses:
A. Connee Hempt, Defendant - Ms, Hempt will testify to the attitudes
of her children and their father and all matters relevant to the custody of the
children, She will further testifY as to what she believes to be an appropriate
schedule for custody.
B, Michael A, Hempt, Plaintiff, as of cross,
II.\WplftJ!ADIHlNIIIIolPrPTI
41'_
C, Sarah Hooven, Defendant's mother - Mrs. Hooven will testify to the
attitudes of the children and their father and all matters relevant to this custody
action,
D. Michael A. Hempt, Jr" parties' child - Michael will testifY to his
relationship with each parent and his opinion regarding the summer schedule.
E Erin M, Hempt, parties' child - Erin will testifY to her relationship
with each parent and her opinion regarding the summer schedule.
III, PROPOSED RESOLUTION: Defendant would propose the following
schedule as a resolution of this matter:
A, The parties would have shared legal custody offhe children,
8, Mother would have primary physical custody of all four children,
Father would have partial physical custody of the children in accordance with the
following schedule:
I, Three weekends out of every four weekends, from Thursday
after school until Saturday at 7:00 p,m, Mother shall have the option of
reserving three weekends per calendar year for the purpose of special
occasions which she cannot schedule on her weekends, i.e. family weddings
and special events, Mother shall give Father 30 days written notice offhe
weekends she intends to reserve,
r~ : ~~~.~., ...,,~;..
1I.\Wp\l'U!ADINO\IIEMPT.m 4JIMt
2. The holidays of Memorial Day, Fourth of July, and Labor
Day, shall be alternated between the parties, The holidays shall be defined
as beginning at 9 a,m, the day of the holiday and ending at 9:00 p,m. the day
of the holiday, In even numbered years Mother shall have Memorial Day
and Labor Day and Father shall have July Fourth. In odd numbered years,
Father shall have Memorial Day and Labor Day and Mother shall have July
Fourth,
3, With regard to the Easter holiday, Mother shall be entitled to
the Easter holiday and the accompanying spring break. (Mother has
historically taken the children to Florida during this period oftime, even
prior to the parties' separation,)
4. With regard to Thanksgiving, Mother shall have
Thanksgiving Day until 3:00 p,m. Father shall have Thanksgiving Day
from 3:00 p,m, until 9:00, tfthe weekend following the holiday is Father's,
then he shall keep the children until the conclusion of his weekend,
5. With regard to the Christmas holiday, in even numbered
years, Father shall have Christmas eve from 5:00 p,m, until 10:00 p.m, and
Christmas Day from 3:00 p.m, until 10:00 p,m. In odd numbered years,
Father shall have Christmas Eve from 5:00 P,I1l, until Christmas Day at
noon, Mother would have the balance of the Christmas Holiday,
(.
~_, ,L....
II \Wp\l'UADlNCNWMPT,PTI 4116199
6, During the summer, each party shall be entitled to fhree (3)
non-consecutive weeks of custody. A week is defined as Sunday at 7:00
p.m, to Sunday at 7:00 p,m. Said weeks shall include the party's regularly
scheduled weekend, The parties are required to give the other sixty (60)
days written notice of the weeks he or she plans to take vacation. Ifboth
parties desire the same weeks, in that event, the party giving first notice
shall be entitled to the time.
C. Father shall provide all transportation for custodial periods, (This is
due to the fact that the parties' children are very active in athletics and other interests.
Mother provides all transportation for these events,)
D, Father shall not come within twenty feet of Mother or her vehicle
and Father shall stay in his automobile when dropping off the children, (Plaintiffwas
subject to a PF A from approximately October 1994 through October 1995 and again from
approximately April 1996 through April 1997 due to his harassing behavior of Defendant.
Plaintiff has in the' past caused damage to Defendant's automobile, Defendant still fears
Plaintiff and would ask that any custody order indicate that Plaintiff
II IWo'IIJ!ADlNCN1EMPT m
",...
not have any physical contact with her or her automobile and that when dropping ofTthe
children PlaintifTbe required to stay in his automobile,)
Respectfully submitted,
COGNETII & BRADERMAN
Dated: April 14, 1999
By:
Maria P. C gnetti quire
Sup. Ct.I.D. #27914
200 North Third Street
Twelfth Floor
P.O, Box 689
Harrisburg, PA 17108-0689
(717) 232-2103
II\Wp\PLEADlNCNlEMPT,m
",....
'. .
~ERTIFICATE OF SERVICE
I, Maria P. Cognetti, Esquire, Attorney for Defendant herein, do hereby certify that
on this date I served the foregoing Pre-Trial Memorandum by depositing a true and exact
copy thereofin the United States mail, first class, postage prepaid, addressed as follows:
Matthew J. Eshelman, Esquire
2108 Market Street, Aztec Building
CampHiIl,PA 17011
Respectfully submitted,
COGNETT1&BRADERMAN
Dated: April 14, 1999
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MICHAEL A. HEMPT, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. . No. 94 - 1778 - CIVIL TERM
.
.
.
CONNEE L. HEMPT, . CIVIL ACTION - AT LAW - CUSTODY
.
Defendant . PREVIOUSLY ASSIGNED TO: J. HESS
.
AND NOW, this
I'"
ORDER
day of
f'I1~
1999, upon
consideration of the attached Stipulation of the parties, said
stipulation is hereby adopted as an Order of Court.
BY THE COURT:
Ad
J.
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.'
MICHAEL A. HEMPT,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
vs.
: No. 94 - 1778 - CIVIL TERM
:
CONNEE L. HEMPT,
Defendant
: CIVIL ACTION - AT LAW - CUSTODY
: PREVIOUSLY ASSIGNED TO: J. HESS
STIPULATED ORDBR
WHEREAS, the parties in this matter are Michael A. Hempt, Sr.,
(the Father hereinafter) and Connee L. Hempt (the Mother
hereinafterl;
WHEREAS, the parties have born to them four children, namely
Corrine D. Hempt, born February 22, 1982; Julie L. Hempt, born May
25, 1984; Michael A. Hempt, Jr., born August 28, 1986; and Erin M.
Hempt, born August 28, 1986,
(the children hereinafter);
WHEREAS, the parties wish to enter into an agreement relative
to custody, partial custody, and visitation of the children; and
WHEREAS, the parties have met with Dr. Stanley E. Schneider,
Registered Custody Evaluator, in an attempt to mediate their own
parenting schedule; now
THEREFORE, upon consultation with their respective counsel in
the persons of Matthew J. Eshelman, Esquire, for the Father, and
Maria P. Cognetti, Esquire, for the Mother, the parties hereto
agree as follows:
1. The Mother shall have primary physical custody of the
parties' minor children. The parties shall share legal custody of
the children jointly. The parties are specifically permitted to
access the records of any medical care provider to the children.
2. The Father shall have visitation with the children three
weekends out of every four from Thursday after school until
Saturday at 7: 00 p.m. Each party shall have the option of
reserving three weekends per calendar year for the purpose of
special occasions, e.g. family weddings and special events. These
reserved weekends shall not increase or reduce the number of
weekends to which each parent would otherwise be entitled. A party
requesting that a specific weekend be reserved to him or herself
shall give the other party at least thirty days' written notice.
In the event both parties request a given weekend be reserved, the
notice delivered first in time shall control.
3. The holidays of Memorial Day, Independence Day, and Labor
Day shall be alternated between the ~arties. Holidays shall be
defined as beginning at 9:00 a.m. the day of the hOliday, and
ending at 9:00 p.m. the day of the holiday. In even numbered
years, the Mother shall have Memorial Day and Labor Day, and the
Father shall have Independence Day. In odd numbered years, the
Father shall have Memorial Day and Labor Day, and the Mother shall
have Independence Day.
4. With regard to the Easter holiday, the Mother shall be
entitled to the Easter holiday and the accompanying spring break.
5. With regard to Thanksgiving, the Mother shall have
Thanksgiving Day until 3:00 p.m. The Father shall have
Thanksgiving Day from 3:00 p.m. until 9:00 p.m. on Thanksgiving Day
each year. The Father shall also have the Sunday following
Thanksgiving Day each year from 4:00 p.m. through Monday at 6:00
p.m.
6. With regard to the Christmas holiday, in even numbered
years, the Father shall have Christmas Eve from 5:00 p.m. until
10:00 p.m., and Christmas Day from 3:00 p.m. until 10:00 p.m. In
odd numbered years, the Father shall have Christmas Eve from 5:00
p.m. until Christmas Day at noon. In those years when Christmas
Day falls on a Friday or a Saturday, the Father shall also have an
additional period extending from the Wednesday following Christmas
Day at 9:00 a.m. through Thursday at 9:00 p.m. The Mother shall
have the balance of the Christmas holiday.
7. During the summer vacation from school each year, each
party shall be entitled to three (3) non-consecutive weeks of
custody. A week is defined as Saturday at 7:00 p.m. to Saturday at
7:00 p.m. The parties are required to give the other party sixty
(60) days' written notices of the weeks he or she plans to take
vacation. In the event both parties request the same week, the
notice delivered first in time shall control.
S. The Father shall provide all transportation for custodial
periods.
9. During exchanges of custody, the party receiving custody
shall remain in his or her residence, and the party transporting
the children shall remain in his or her car.
10. Neither party shall come within ten (lO) feet of the
other or their vehicle.
t.,...,..",. .....~,'
11. This Stipulated Order shall supersede all prior orders of
this Court.
The parties may modify the provisions of this
Stipulated Order by mutual agreement. In the absence of mutual
agreement, the terms of this Stipulated Order shall control.
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