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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF ~ PENNA.
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THOMAS SALOMON
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TAMMY SALOMON
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DECREE IN
DIVORCE
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ANDNOW,...D.c:.,,(~~~.~~......, 19.'1.., it is ordered and
decreed that.... . .. .. . .~~~~~~ .~~~~~~~ .. . . .... .. .. .. . ... .,...., plaintiff,
and. . . .. .... .. . . .. .. .. . TfII:l~Y. ~~~9~9~.... ., .... .. . ... .. ... ..., 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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to be incorporated into this Oecree in Divorce.
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THOMAS SALOMON,
plaintiff
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
v.
TAMMY SALOMON,
Defendant
.
.
NO: 94-2884 Civil Term
PRAECIPB m TRAJlSlUT RECORD
TO THE PROTHONOTARY:
Transmit the record together with the following information to
the Court for entry of a divorce decree:
1. Ground for divorce: Irretrievable breakdown under Section
3301(c) of the Divorce Code.
2. Date and manner of service of Complaint:
June 24, 1994 by United states First Class Certified Mail,
Restricted Delivery with Article Number P 848 252 703.
3. Date of the execution of the Affidavit of Consent required
by Section 3301(c) of the Divorce Code by:
Plaintiff--November 21, 1997; by Defendant--November 24, 1997.
4. Date of the execution of the Waiver of Notice of
Intention: Plaintiff--December 4, 1997; Defendant--November 24,
1997.
5. Economic claims pending: NONE.
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GEORGE . PORTER, ESQUIRE
Attorne for Plaintiff
1.0. 42752
909 East Chocolate Avenue
Hershey PA 17033
(717) 533-7130
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:J(mfuy, Ptnn.sy(vania 17033
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THOMAS SALOMON,
Plaintif f
IN ,!'IIE COUR'!' OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - IN DIVORCE
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NO.
TAMMY
SALOMON,
Defendant
NOTICE TO DEFEND AND CLAIM
R1GIITS
YOU IIAVE BEEN SUED IN COURT. If you wish to defend against
the claims set forth in the following pages, you must take prompt
action. You are warned that if you fail to do so, the case may
proceed without you and a Decree of Divorce or Annulment may be
ontered Against you by the Court. A judgment may also be entered
against you for any other claim or relief requested in these papers
by the Plaintiff. You may lose money or property or other rights
important to you including custody or visitation of your children
When the ground for the divorce is indignities or irretrievable
breakdown of the marriage, you may request marriage counseling. A
list of marriage counselors is available in the office of the:
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE Till;: RIGIIT TO CLAIM ANY OF THEM.
YOU SIIOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU UO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIm
OFFICE SET FORTII BELOW TO FIND OUT WIIERE YOU CAN GET LEGAL IIEI,P.
COURT ADMINISTRATOR
4TII FLOOR
CUMBERLhND COUNTY COURTIIOUSE
CARLISLE, PENNSYLVhNlh 17013
(717) 240-6200
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THOMAS SALOMON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - IN DIVORCE
v.
NO.
TAMMY SALOMON,
Defendant
COMPLAINT IN DIVORCE UNDER SBCTION 3301(c) or 3301(4)
OF THE DIVORCE CODE
1, Plaintiff is THOMAS SALOMON, who currently resides
at P,O. Box 691, Dillsburg, Cumberland County, Pennsylvania,
since August 2, 1993.
2. Defendant is TAMMY SALOMON, who currently resides at
1723 English Drive, Mechanicsburg, Cumberland County, Pennsylvania,
since May I, 1993,
3. THOMAS SALOMON and TAMMY SALOMON have been bona fide
residents in the Commonwealth for at least six months immediately
previous to the filing of this Complaint.
4, The Plaintiff and Defendant were married on
December 6, 1985, in Farmingdale, New York,
5. There have been no prior actions of divorce or for
annulment between the parties,
6, The marriage is irretrievably broken,
7. Plaintiff has been advised that counseling is
available and that Plaintiff may have the right to request that the
Court require the parties to participate in counseling.
WHEREFORE, Plaintiff requests the Court to enter a
Decree of Divorce.
/1
George W.
Attorney or plaintiff
LD. 42752
909 East Chocolate Avenue
P,O. Box 338
Hershey PA 17033
(717) 533-7130
VBRrFrCATrON
I verify chat 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
THOMAS SALOMON
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unsworn falsification to authorities,
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Date: J{o ~c l
THOMAS SALOMON, . IN THE COURT 01" COMMON PLEAS
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
. CIVIL ACTION - DIVORCE
.
v. .
.
TAMMY SALOMON, . NO: 94-2884 Civil Te~
.
Defendant :
AFFIDAVIT OF COIISBJr.r
1. A Complaint in Divorce under Section 3301(c) or (d) of
the Divorce Code was filed on May 31, 1994.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing
the Complaint.
3. I consent to the entry of a final decree of divorce.
4. I understand that I may lose rights concerning alimony,
division of property, lawyer'S fees or expenses if I do not claim
them before a divorce is granted.
I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn
falsification to authorities.
Date: /~/;Jj/f 7
~/
TAMM MON
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THOMAS SALOMON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
I CIVIL ACTION - DIVORCE
NO: 94-2884 Civil Term
v.
TAMMY SALOMON,
Defendant
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lOUVER OF IIOI'ICB OF IIr.I:I5Ir.l'IOII 'l'O RBQUBft 15Ir.l'KJ[
OF A DIVORCE DBCRICB UllDBR !i 3301 (c) OF ~ DIVORCE CODB
1. I consent to the entry of a final decree of divorce
without notice.
2. I understand that I may lose rights concerning alimony,
division of property, lawyer'S fees or expenses if I do not claim
them before a divorce is granted.
3. I understand that I will not be divorced until a divorce
decree is entered by the Court and that a copy of the decree will
be sent to me immediately after it is filed with the Prothonotary.
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 Pa.C.S. 9 4904 relating to unsworn
falsification to authorities.
Date: IJ!,lJijq 7
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T SALOMON
THOMAS SALOMON,
Plaintiff
IN THE COURT OP COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
v.
TAMMY SALOMON,
Defendant
NO: 94-2884 Civil Term
APPIDAVJ:'l' OF COIISBII'l'
1. A Complaint in Divorce under Section 3301(c) or (d) of
the Divorce Code was filed on May 3l, 1994.
2. The marriage of Plaintiff aDd Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing
the Complaint.
3. I consent to the entry of a final decree of divorce.
4. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim
them before a divorce is granted.
I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn
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THOMAS SALOMON
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THOMAS SALOMON,
plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - DIVORCE
NO: 94-2884 civil Term
v.
TAMMY SALOMON,
Defendant
1IJUVBR OF IIOrICB OF Im:IUI'I:.I011 ro RBQUBS'.r IUl'l:IU
OF A DIVORCE DBCRBB UllDBR !i 3301 (c) OF 'rIIB DIVORCE CODE
1. I consent to the entry of a final decree of divorce
without notice.
2. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim
them before a divorce is granted.
3. I understand that I will not be divorced until a divorce
decree is entered by the Court and that a copy of the decree will
be sent to me immediately after it is filed with the
prothonotary.
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 Pa.C.S. ~ 4904 relating to unsworn
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THOMAS SALOMON, I IN THE COURT OF COMMON PLEAS
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I CIVIL ACTION - DIVORCE
v. I
TAMMY SALOMON, I NOI 94-2884 Civil Term
Defendant: .
.
JUPFIDlLVJ:~ OF SBRVICB
I, George W. port:er, Esquire, do cert:ify t:hat: on
June 24, 1994, I did serve a t:rue and correct: copy of t:he Divorce
Complaint: in t:he above-capt:ioned case upon Tammy Salomon via Unit:ed
St:at:es Cert:ified Mail-Rest:rict:ed Delivery having Art:icle Number
P 848 252 703.
JJt L!d<;
Georg~ ~port:er, Esquire
I.D. 427 2
909 East: Chocolat:e Avenue
Hershey PA 17033
(717) 533-7130
Sworn t:o me t:his II~ day of
AtthtW1997.
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Not:ary pu lic
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THOMAS SALOMON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
v.
TAMMY SALOMON,
Defendant
NO: 94-2884 Civil Term
. DIll: Comptell IlIma t and 2 when addll,.;:O< iC.. .r. d..lred, .nd comptell 11_,:
... and 4. .-..'
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DOME8TIC RETUIW RECI!f'f..
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THOMAS SALmlON,
Plaintiff
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TAl~M2' SAL_OMON,
DefeJJikw-t________
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III the Court of Common Pleu of
Cumber1and Counl)', Pelllllylvania
N 94-2P.84
o.
Civil
1994
gVIL ACTION
IN DIVORCE
PRAECIPE
Please enter the appea~ce of~~-!a~ly Law Clinic on behalf
of the defendant in the above-captioned matter.
To Lawrence E. Welker
&.d-. /6~
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~~vY 2:--,." 7\Lv.-1'~"4/'\
.' Supervising Ally
ROBERT B. RAINS
Prothonotary
1924
~/~enl Atty for Plaintiff
MICHELLE B. STOKES
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No, 94 -2884
Term, 19 q.t
Thomas Salomon. Plalntiff
VI,
rammy Salomon, Defendant
PRAECIPE
Filed :5;;>p f 11' 19 94
Michelle B. stokes
StudeolAlty
Robert E. Mains
Supervising Auy
The Family Law Clinic
45 North Pitt Street
Carlisle, PA 17013
717/240-5204
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THOMAS SALOMON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
v.
CIVIL ACTION - LAW IN DIVORCE,
EQUITABLE DISTRIBUTION
TAMMY SALOMON,
Defendant.
No, 94-2884 CIVIL TERM
PETITION FOR ALIMONY PENDENTE LITE
TO THE HONORABLE JUDGES OF SAID COURT:
The Family Law Clinic. attorneys for defendant. Tammy Salomon, respectfully requests
the court to order the equitable division of certain costs involved in the valuation of marital
property. These valuations are needed to facilitate the equitable distribution of marital property,
1. These costs include, but are not limited to, the valuation of Plaintiffs pension plan.
2. Defendant is without the financial ability to bear the burden of these costs.
3, Both parties will benefit from these valuations of marital property.
WHEREFORE, Defendant prays this Honorable Court to order Plaintiff to bear all costs
involved in the valuation of marital property subject to this action.
5"-g-1s-
Date
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ichele L. Belluzzi
Student Attorney
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Linda E. Fisher
Thomas Peeler
Supervising Attorney
THE FAMILY LAW CLINIC
45 N, Pitt Street
Carlisle, PA 17013
717\243-2968
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THOMAS SALOMON,
Plaintiff,
v,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE
TAMMY SALOMON,
Defendant,
: No. 94-2884 CIVIL TERM
CERTIFICATE OF SERVICE
I, Michele L. Belluzzi, Certified Legal Intern, Family Law Clinic, hereby certify that
I have served a true and correct copy of Petition for Equitable Distribution and Petition for
Alimone Pendente Lite on George Porter, counsel for Thomas Salomon, at 909 E. Chocolate
Avenue, P,O. Box 338. Hershey, PA 17033, by depositing a copy of the same in the United
States first class mail this 6th day of September, 1995,
/tV:
Michele ,Belluzzi
Certified Legal Intern
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THOMAS SALOMON,
Plaintiff/Respondent
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: CIVIL ACTION - LAW
: IN CUSTODY
TAMMY SALOMON,
Defendant/Petitioner
: NO, 94-2884 CIVIL TERM
COMPLAINT FOR CUSTODY
AND NOW comes the petitioner. Tammy Salomon, the defendant in the above-captioned
divorce action by and through her attorneys, the Family Law Clinic, and sets forth the following
complaint for custody pursuant to Pa.R,C.P. 1920. 15(b):
1. Tammy Salomon resides at 618 Colonial View Road, Mechanicsburg, 17055,
Cumberland County, Pennsylvania.
2, Thomas Salomon resides at 119 Harrisburg Street, Apt. 4, Dillsburg, 17019, York
County, Pennsylvania.
3, Tammy Salomon seeks custody of the following children:
Name
Present Residence
~
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Thomas Michael Salomon, Jr.
618 Colonial View Road
Mechanicsburg, PA
618 Colonial View Road
Mechanicsburg. P A
8
Holly Marie Salomon
The children were not born out of wedlock.
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WHEREFORE, petitioner requests the court to grant her custody of the
children, subject to visitation as the parties may agree to in the future, and such other relief as
the Court deems just.
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L-SHANNON S. PIERGALL
Certified legal intern
Date
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mOMAS . PLACE
ROBERT E, RAINS
KATHERINE C. PEARSON
Supervising Attorney
GAIL R. SHEARER
Staff Attorney
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VERIFICATION
I verify that the statements made in this Petition 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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THOMAS SALOMON,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
V.
CIVIL ACTION-LAW
CUSTODY
TAMMY SALOMON
Defendant/Petitioner
NO, 94-2884
CIVIL TERM
ORDER OF COURT
AND NOW, :s=."e 101. , upon consideration of the attached comnlaint, it is hereby
directed that the parties and their respective counsel appear before {AlAIfI j'H1da.J, the
conciliator, atJl6J,()j,':l ,sf, day of July q , 19Q", at /0..30 m.. for a Pre-I-Iearing
Custody Conference. At such conference, an effort will be made to resolve the issues in
dispute; or if this cannot be accomplished. to de line and narrow the issues to be heard by the
court, and to enter into a temporary order. All children age live or older may also be present
at the conference. Failure to appear at the conference may provide grounds for entry of a
temporary or pennanent order.
FOR THE COURT,
By:cI!lil.'-/l-- ,1NdM ISITJ?
Custody Conciliator J'
The Court of Common Pleas of Cumberland Counly is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accomodations available 10 disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR 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.
OFFICE OF COURT ADMINISTRATOR
COURTHOUSE, 4TH FLOOR
CARLISLE, PA 17013
(717) 240-6200
RlEl}{)fACE
OF Tf;t: rr')TFr~:I)T.^RY
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THOMAS SALOMON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY. PENNSYLVANIA
v,
: CIVIL ACTION - LAW
: IN DIVORCE, CUSTODY,
: EQUITABLE DISTRIBUTION
TAMMY SALOMON,
Defendant
: NO. 94-2884 CIVIL TERM
CUSTODY AND VISITATION AGREEMENT
THIS AGREEMENT, made this 17th day of June, 1996. between Thomas Salomon,
hereinafter "Father" and Tammy Salomon, hereinafter. "Mother" concerns the custody and
visitation of their children Thomas Michael Salomon and Holly Marie Salomon.
WHEREAS, Mother and Father desire to enter imo and be legally bound by an
agreement as to the custody of the children and to have this agreement made an order of court,
plaintiff and defendant agree to the following:
I. Plaintiff and Defendant are the parents of Holly Marie Salomon born 1/28/88, and
Thomas Michael Salomon born 10/1/89,
2. Mother and Fath~r wi!! share legr.! ClIs!ody ()f thp. childmn
3. Mother shall have primary physical custody of the children,
4. Father shall have partial physical custody at times and dates to be detennined by
the parties,
5, Father understands that Mother is planning to move with the children in August
1996 out of the Commonwealth of Pennsylvania and reside in the State of New York, Father
agrees that such a move is in the hest interests of the children.
-
6, Mother and Father will share responsibility for all transportation costs associated
wilh the exercise of Father's custody rights,
7. The parties hereto intend to be legally bound by the tenns of this agreement.
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Thomas Salomon, Plaintiff
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909 East Chocolate A venue
Hershey, PA 17033
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SHANNON S. PIERGALLI~I
Certified Legal Intern
Counsel for Plaintiff
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OM AS
ROBERT E. INS
KATHERINE C. PEARSON
Supervising Attorney
GAIL R, SHEARER
Staff Attorney
Counsel for Defendant
FAMILY LAW CLINIC
45 N0I1h Pitt Street
Carlisle, PA 17013
717/240-5204
Approved and entered as an Order of the Court.
Date ~ ()r: \ I <(<{ (,
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THOMAS SALOMON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 94-2884 CIVIL TERM
V.
TAMMY SALOMON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
PRE-TRIAL STATEMENT
( ) Plaintiff (X) Defendant, by his/her attorney, Lori K.
Serratelli, Esquire files this pre-trial statement in accordance
with Pa.R.C.P. 1920.33(b).
1. Inventory and AD9raisement: See Inventory and Appraisement.
2. E~ert witnesses:
None at this time; however, Defendant reserves the right
to supplement this statement if necessary.
3. Other witnesses:
None at this time; however, Defendant reserves the right
to supplement this statement if necessary.
4. Exhibits:
a. Defendant's Income and Expense Statement
b. Defendant's Inventory and Appraisement
c. Attorney Fees and Costs statement (Will be supplied
at hearing)
Defendant reserves the right to supplement this statement,
if necessary.
5. Inoome: Refer to Income and Expense Statement
6. E~enses: Refer to Income and Expense Statement
7. Retirement/Pension:
See Inventory and Appraisement. Husband has a pension
through his employer, U.S. Postal Service.
8. Counsel Fees: See Exhibit C.
9. DisDuted Personal Property: None at this time, Defendant
reserves the right to supplement this statement if
necessary.
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10. Marital Debts: See Inventory and Appraisement
11. proposed Resolution:
a. Plaintiff is granted a divorce from Defendant.
b. Each party shall retain all personal property in his/her
possession.
c. wife shall receive 60% of the marital portion of
Husband's U.S. Postal Service pension in the form of
a lump sum payment, if possible. In the alternative,
wife shall receive 60% of the marital portion of
Husband's U.S. Postal Service pension on a deferred
Basis. Wife shall also be named as irrevocable survivor
beneficiary on Husband's U.S. Postal Service pension.
d. wife shall receive 60% of the marital portion of
Husband's U.S. Postal Thrift savings Plan in the form
of a lump sum payment.
e. Wife shall receive 60% of any cash surrender value
of Husband's life insurance policies.
f. Husband shall pay to wife as alimony, the sum of $575.00
per month for an indefinite period.
g. Husband shall obtain or maintain a life insurance policy
in order to secure his alimony obligation.
h. Husband shall pay wife's counsel fees and costs.
i. Wife shall be appointed as irrevocable beneficiary on
husband's postal service life insurance policy.
Respectfully submitted,
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Lor . Serratelli, Esq.
SERRATELLI, SCHIFFMAN,
BROWN & CALHOON, P.C.
2080 Linglestown Road
Suite 201
Harrisburg, PA 17110-9445
(717) 540-9170
Attorney for Defendant
-. .
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.
THOMAS SALOMON, . IN THE COURT OF COMMON PLEAS
.
.
.
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. No. 94-2884 civil Term
TAMMY SALOMON, : CIVIL ACTION - LAW
Defendant IN DIVORCE
CERTIFICATE OF SERVICE
I, Lori K. Serrate1li, Esquire, do hereby certify that on
December I~ , 1996 the foregoing was delivered by U.S. Mail,
postage prepaid, addressed as follows:
The original to:
E. Robert Elicker, II
Divorce Master
Office of Divorce Master
9 North Hanover street
Carlisle, PA 17013
and a copy to:
George W. Porter, Esq.
909 East Chocolate Avenue
Hershey, PA 17033
Attorney for Plaintiff
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Lori;KI. Serratelli, Esq.
SERRATELLI, SCHIFFMAN,
BROWN & CALHOON, P.C.
2080 Linglestown Rd., Suite 201
Harrisburg, PA 17110-9445
(717) 540-9170
Attorney for Defendant
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THOMAS SALOMON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
v,
TAMMY SALOMON,
Defendant
NO: 94-2884 Civil Term
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT, If you wish to defend against
the claims set forth in the following pages, you must take prompt
action, You are warned that if you fail to do so, the case may
proceed without you and a decree of divorce or annulment may be
enterer. against you by the court. A judgment may also be entered
against you for any other claim or relief requested in these
papers by the Plaintiff, You may lose money or property or other
rights important to you, including custody or visitation of your
children.
When the ground for divorce is indignities or irretrievable
breakdown of the marriage, you may request marriage counseling,
A list of marriage counselors is available in the Office of the
Prothonotary at the
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT
IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM,
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HBLP.
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
4TH FLOOR
ONE COURTHOUSE SQUARE
CARLISLE PA l7013
(717) 240-6100
-
THOMAS SALOMON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
v.
TAMMY SALOMON,
Defendant
NO: 94-2884 Civil Term
CERTIFICATE OF SERVICE
I, George W. Porter, Esquire, do certify that on October 10,
1996, a true and correct copy of the within "Motion for
Appointment of Master " was mailed via United States First-Class
Mail, postage pre-paid to:
Shannon S, Piergallini
Certified Legal Intern
45 North Pitt Street
Carlisle PA 17013-2943
ff
George W, Porter, Esquire
I.D, 42751
Attorney for Thomas Salomon
909 East Chocolate Avenue
Hershey PA 17033
(717) 533-7130
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THGIAS SALCHlN, . IN THE COURT OF COMMON PLEAS OF
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Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
v. . NO. 94 - 2884 CIVIL TERM
.
.
.
TAMMY SALCHlN, . IN CUSTODY
.
Defendant .
.
CXXlRT amm
AND NOW, this twenty-seventh day of June, 1996, the Conciliator,
being advised that the parties have resolved all custody issues by
agreement, relinquishes jurisdiction in this case.
LJ~L~
Dawn S. Sunday, Esqulre
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MICHA!'l.!'. BROWN
RONAI.O l_ ('..AU U n)N
GARY 1_ ROTll\C11IUl
ROR!'RT D. HAMIl.TON
VIR!;INIA M. IJIA>
GARTlI A. SlH'IIENSllN
OF COUNSEl.
(MU & DC Ou.. (hili
St'nt 201
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November 21, 1996
E. Robert Elicker, Master
Office of Divorce Master
9 North Hanover street
Carlisle, PA 17013
Re: Salomon v. Salomon
No. 94-2884 civil
Dear Mr. Elicker:
This will confirm my telephone call with Traci of
today. As was explained, we only recently were retained
by Mrs. Salomon and therefore, would request an extension
of two weeks in order to file our pre-trial statement.
Thank you for your consideration.
Sincerely,
SERRATELLI, SCHIFFMAN
BROWN' CALHOON, P.C.
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Enclosure
cc: George W. Porter, Esq.
Tammy Salomon
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You are hereby notified to liIe a
written response fO the endoscd
within twenty (20) days from ser-
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by
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We do hereby ceniry that the
wilhin is a lrue and correct coPy
of.t~.. origillal liIed in this aCllon
by
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Anotncy
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THOMAS SALOMON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
DIVORCE AND EQUITABLE DISTRIBUTION
NO. 2884 CIVIL 1994
TAMMY SALOMON,
Defendant
PRAECIPE TO WITHDRAW AND ENTRY Of APPEARANCE
To the Prothonotary:
Please withdraw the appearance of the Family Law Clinic on behalf of Tammy Salomon,
the defendant, and enter the appearance of Lori Serratelli, Esq. in the above captioned matter,
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LORI S~RRATE~L~: iSQ~ '
2040 Linglestown Road, Suite 106
Harrisburg, PA 17110
s.~\:).',v".!J\0 ,5 . P.,\.Jl_~0
SHANNON S, PIERGAL. I
Certified Legal Intern
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I,{OBERT E, INS
THOMAS 0 PLACE
KATHERI E C. PEARSON
Supervising Attorney
GAIL R. SHEARER
Staff Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/243-2968
November 26, 1996
E. Robert Elicker, II
Office of Divorce Master
l.illll K. SlIlIt\1I111 9 North Hanover street
Carlisle, PA 17013
SII \'IN J. SUlIH.\IAS
Re: Salomon v. Salomon
No. 94-2884 civil
MIUIAU, F. HIH1\l'S
Dear Mr. Elicker:
RONAI.IlI.. CUIlUllN
Enclosed please find a copy of the Praecipe entering
my appearance which has been filed with the Court.
Thank you for your attention.
GARY L l{tHII\(:llIIl)
ItOI\f.IH D. HAMilTON
Sincerely,
VIR\iI"'A M. DIA'
SERRATELLI, SCHIFFMAN,
BROWN LHOON, P.C.
Serratelli
GARTII A. Sn:I'IIFN~(lN
OF COUN~E1
jMUt.:l>Clhll.\(hlll
Lor
LKS/dae
Enclosure
cc: Tammy Salomon
George W. Porter, Esq.
Shannon S. Piergal1ini
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DIVORCE AND EQUITABLE DISTRIBUTION
NO. 2884 CIVIL 1994
THOMAS SALOMON,
Plaintiff
TAMMY SALOMON,
Defendant
PRAECIPE TO WITHDRAW AND ENTRY or APPEARANCE
To the Prothonotary:
Please withdraw the appearance of the Family Law Clinic on behalf of Tammy Salomon,
the defendant, and enter the appearance of Lori Serratelli, Esq, in the above captioned maller,
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LORI RRATELLI, ESQ,
2040 Linglestown Road, Suite 106
Harrisburg, PA 17110
S\\O."\~'-!)'0 0 . P~U.~U;0
SHANNON S, PIERGAL. I
Certified Legal Intern
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!,tOBERT E, NS
THOMAS . PLACE
KATHERI E C. PEARSON
Supervising Attorney
GAIL R, SHEARER
Staff Attorney
FAMILY LAW CLINIC
45 North Pill Street
Carlisle, PA 17013
717/243-2968
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THOMAS SALOMON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
v.
TAMMY SALOMON,
Defendant
NO: 94-2884 Civil Term
PRB-TRIAL STATBMBNT
1. LIST OF ASSBTS.
a. Marital assets in possession of Defendant Tammy
Salomon: At the time of separation, Defendant retained in her
possession items of personal property which are unappraised, but
have an estimated value of Five Thousand Dollars ($5,000,00),
These items consisted of a dining room suite, a livirrg room
suite, three bedroom suites, miscellaneous kitchen appliances,
two televisions, a VCR and a 1987 Hyundai,
b, At the time of separation, Plaintiff took with
him items of personal property which are unappraised, but have
an estimated value of One Thousand Dollars ($1,000,00,) These
items consisted of a bed, a stereo and a 1986 Subaru automobile
\~hich was later sold for Three Hundred Dollars ($300.00),
c, Plaintiff Thomas Salomon has a pension with a
present value of Eight Thousand Nine Hundred Sixty-Two Dollars
($8,962,00) ,
-l-
2 . EXPERT WITNESS.
Plaintiff Thomas Salomon intends to introduce into
evidence the expert report of Mark Altschuler, Actuary. His
report is attached hereto and marked "Attachment A,"
Mr, Altschuler is an actuary employed by Pension Analysis
Consultants, Inc., and has an office address of 8215 Forest
Avenue, Elkins Park, Pennsylvania, Mr. Altschuler has a
Bachelor's Degree from the University of Pennsylvania in
mathematics and a Master's Degree from Case Western Reserve
University, He has been working as an actualY since 1990.
3. IDENTITY OF WITNESSBS.
At the present time. Plaintiff only intends to call
Plaintiff and the expert witness, if necessalY.
4. LIST OF EXHIBITS.
Plaintiff only intends to introduce the pension
evaluation report,
S. PLAINTIFF'S INCOME.
Plaintiff's Federal Income Tax Return from 1995 is
attached hereto as "Attachment 8," Plaintiff's sole source of
income is from working at the United States Postal Service.
Plaintiff's net monthly income, as calculated by Cumberland
-2-
County Domestic Relations Section Officer R, J, Shadday is
Two Thousand Five Hundred Two Dollars ($2,502.00) per month.
A copy of Plaintiff's representative paystub is attached hereto
and marked "Attachment C,"
6. PLAINTIFF'S BXPBNSB STATBHBNT.
Plaintiff's Income and Expense Statement is attached
hereto and marked "Attachment D,"
7. PBNSION.
It is Plaintiff's position that the marital portion of
the pension is Eight Thousand Nine Hundred Sixty-Two Dollars
($8,962.00). This is based upon a separation date of October 15,
1990. While the parties did live together briefly after that
date, they never lived together as man and wife after October 15,
1990.
8. PLAINTIFF MAKES NO CLAIM FOR COUNSBL FBBS.
9 . NOT APPLICABLB.
10. MARITAL DBBTS.
There are no marital debts.
-3-
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PENSION ANALYSIS CONSULTANTS,INC.
Memo Date:
June 20, 1996
Prepared for: George W. Porter Esq.
P.O. Box 338
909 E. Chocolate Ave.
Hershey, PA 17033
subject: Salomon v. Salomon
This is a summary memo presenting an abbreviated report of the
current actuarial present value as of 06/20/96 of the undivided marital
coverture portion of the estimated accrued pension benefit of Thomas
Salomon in the U.S. Postal Service Civil Service Retirement System
(Defined Benefit), in accordance with generally accepted actuarial
standards with imputed Social Security benefits subtracted per
Cornb1eth (580 A.2d 369) and Schneeman (615 A.2d 1369).
If date of marital separation is 10/15/93: $ 14,337.
If date of marital separation is 10/15/90: $ 8,962.
More details are available upon request in full report format.
In this immediate offset method the present value is determined as
of the valuation date usin~ a coverture fraction to produce the amount
subject to equitable distrlbution. Pension benefits when received are
subject to taxation which varies with the individual's tax filing
status. This valuation is for the defined benefit pension plan and
does not consider any other entitlements.
The following data was used to determine this amount:
Date of Birth:
Date of Entry:
Date of Marriage:
Valuation Date:
05/31/59
03/12/80
12/05/85
06/20/96
Mortality: GAM-83
Interest rate: 6.79%
Retirement age: 62
Status: Active
PENSION ANALYSIS CONSULTANTS, INC.
RespectfullY~~d by
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Mark Altschuler, Actuary
960388
821~ FOREST AVENUE. P.O. BOX 7107 . ELKINS PARK, PA 19027
(21~) 782.9ll.\~ III o"h;de 21~ & 610 area e,llle, (81101 288-J67~ . FAX m~) 782-98~2
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'01''''' .,.n' Jill. ,- Cu. i I, '..,. Dt "".,,.. y,,' hO'''"I"' ,UD','"I>>:ft. .It I 0t.48 "1. Utl.."o'~
Lnbcl I vo..,r"""I/Il,'"d11l1t," L...,..",. VI_ ..dltl ,.WllIy MI"'''''
~ 'f . THOI1AS M Sr.LOMON 1l7-5ii-8625
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H1:,II'l1 ~ P.O. BOX 691 P.porwor1l R.ductlon
, .~... I eaf. ".,.." " 101I."ill. ""t. IfIIO' ZIP cO:,,11 tIll "hI "Ot.la" Udt.U, "I v.g. ,t. Act NoUce, UI D.al 7,
P,e1Idontl:a1 DILLSBtJRG. PA 17019 V.. No H,I'1 c:".c~I"1 '......
r.1.:r.llon C,'npolgn ~ Do you wenl $3 to go to IhI. lund? , .. , , , . .. , , . .. , , .. , . .. '.' , .. . . .. . , . . , , , , .. , , . , , , X will nt' c~,"g' )",,,u
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:, "l' ".1 If 0 Iolnt return, dooHour 100UII wlnt $31000 to 1111. fund? ... .... , . , .. .. .. . . .. . , , , . , X "r"",,.
. 1 I-;( 5lngl.
. Filing Status 2 Mlrrlld nUng Joint relurn (ovon II only ono hod Incomu)
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:'.,..c":" 4 Hood or housohold (v.Uh quolllylng porion), (500 pogo 12,) If tho qUllllv'ng p(/l,on II. child but net your dopOlldon~
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t1I'i,"N,,,,, t.ann,,,,. Irt un,'" ug. 13. '..,lIU","lll to ~o" hUIII, In tllS c...".:
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d II your child didn't live with you bulls clolmod DO your dop, undor p,0.,Oe5 ~groomont, chock, , AlId'hMb.,.
Total numbl)( 01 Ixomodon3 clllirnod. . . . t . . . . . . . . . . . . . . . . . . . . . . . . . . . . I . . . . . . . . . . . . . . . . . 1.",rUu I 41
, I ""U.IIID'ff ..
......- WogOI, .alarlos. tips, otc. Anech Form(el W.2,..,.,."..,..,.,.,.....", ,f!.I6.I, ~S:, 48.178
7 7
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II Tox.exempllnlorut(lCo pogo 151. DON.T1'....d..' "" .., ,. . . . .. 8b ~:?i~f
1\".,.;1. . Dividend Incorno. AttDch Schedule B il 0111)( $400 , . , . , . . , , , . , .. . , .. , , .., , ..., . . , . . .. , , .. .
, ' I' ~ II uf t"'oJ' 10 Taxlblo relundt, credits, or on,ol. 01 SlOlO and Iocallncorno IOXCl (~OO pogo 1S),. . , . , , , . ., , , ,. 10
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'N i(O.,,"d 11 Alll'1"IOnv rectlvtd I . . . . . . . . I . . . . . . . I I . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . "
, l'II:f..11 ".,.. Bu,lnl" Income or VOII), AnDch Schodulo C or C-EZ. , ..' . . .. . . , .. . , .., , .. , , . , , . , .. , . , , 12 -r::J
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, t.t.J:I"'1'Il 13 Cepltal gain or Voss). " rlqu~od, DttDCh Schodule 0 . , , . , .. , , .. . , .. , , . .. . , . .. , .. . , , , , , , , , 13
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: ,"":!"'.. 14 Other glllll or (101l01), Anoch Ferm 4797 , , . . .. , , .. . , . .. , , , , . . , .. , , . , .. .. , . .. , . .. , , .. , 14
",.,.,ltle 15. TolollAA dllltlbullon", '" , ,." ~. 1::1 b T..ebl8 omount (pg, Ie) 15b
" ,~~ I"'" tea 18b
~.. .. .. Totl' ponllonland MnulUos, ,," IS. b Tao.blo omount (p~, 18)
I ....-..", 1? R.nllll reel utll!S. royalUe" partnlf.hlp., S corporoUon" Irus", elc. Anoch Schedulo e, . . . . . . , , , IT
,'I' Film Income or (loss). An.ch S~hodulo F , , , .. .. , .. . . .. . , . , , , , , .. . .. . , . , .. , , , . , . . , . , . , :J
t8 "
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20. Soci8llocurlly bOnelilS,.,.,.", ~ b To'ablo amount (pg. '8) 2Gb
21 Othur Income. 21
22 Add the amounts In Ih. lor rloht column lOf Uno. 7 thlouoh 21. This II yOur lot.llncoml. . , . , , , , . 22 48.198' I-
I Adjustments 23. Vour tRA dlducllon (S80 pogo 191, , . , , , , , , .. . , , .. . , ,.. , ' .. . 2'.18 ''''I~'
I '\/i"I;
10 Incomo b Spouse', IRA doduc\ion (seo plgo 1t) . .. , , .. . . , .. . . , . , , , , . , 23b I~lli;.,il' :
24 Movlng s.penllS, Anech Form 3903 or 3903., , . . ,. . , " , . .. , . 2e :i 'i:I~II'.
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, 25, Ona.hlll olloll-omployrncnl t$X.. . . , , , , . .. , , . , .. , , .. . . .. . . 25 q~f,:fl
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I 28 Sou-employed hoalth In.urMCo doducUon ('0' pagG 21)", . ." , 26 Ili?;;I:11 ~TTtl''''",uf
21 Koogh & .oIl'OIl1'loyod 5E.P plan.. II SEP, Chock .. 0 ....... 27 ....'lj.lf 1)
I!:,! ~1111
28 Pcnolly on early wlthd'.wll cl living I ... . , , , , . , , . , , , , . . .. . . 28 II.,.,
29 Alimony paid. Rlclpiont's 5511 ~ 29 \:I;'ill;::'
- 30 Add IInol 23. Ihrnlloh 29. Those 010 you' to..I.dJultmlnl., .,. . ,.., , , ...,...,..,...,.., . 30 0
Adlusled ...
31 Sublrecllln. 30 I,om UI10 .z. T,,!~ IS yOJI odlulled gro'~,\lncomo. II loss !hon tZo,Gn end 0 chil~ 48,1981
Gross Income lived "ith vou 0." then t9.230 II ch!ld didn.! 'IvC with vOu ,~CD 'Earned Incomo Crco,r on o~ 27. . 31
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n Amount from line 31 (tdlu,fnd grol' Incomo) . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . , . . 32 48,198
T~1( 33 I Choc~ It 0 You WO'O 65 or oldol, 0 Blind; 0 Spouao WU a5 01 cldol, 0 Blind. L 1!:!ltl!.I.
:ompu- II'" r
Add Iho numbar of bo'os choe~od obOvO ond ontol Iho lolal hO'o . , , . , , . . . . . . . , , , . 331 l.'l,llhl
1~llon . .1;'
b II your poronl (01 somoono elte) con claim you os . dcpondenl, ehotk hare, . , , , . , . , · 33b 0 !I.'II'I,
I' "I
:..~ .1.';' c II you 810 m.rrlod nUng soparlloly nnd your spouso Ilon~zo. doduellon. 0' you .ro ""II'
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. dual-Sl.lu' ollon. 'Ot pogo 23 and cnock noro. . , , .. . , .. . , , , . , , . .. . . . , . , , , . , · 33c 0 ,'1 1 Il'I:'
~ ,...,.,,-,..~... """'," ^,M a, "" I 'l'llj'
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34 Enlol SL,nd.rd doducllon shown COIOW lor your nl'ng ".IUS, But II you chackod ~I:'i:.,:
tno Iny boa on IIno 331 or b, go to pogo 23 to Wnd your olondard daduCllon. ' ~
'o,gor II you chock.d box 33c, your slsndllld deducllon 10 20'0. 7' " " h ~
01 0 5lnglo: $3,300 . Mlrrlod lIIinalalnlly or Oualifylng widow(or) . $a,~50 . , . , , . . 34 6.550
your: 0 Hood of household - $5,750 0 MllIrlod IIl1ng .oporaloly - $3,275
35 Subllaet line 34 from Uno 32 . . . . . . . . . . . . . . . . . . . t t . . . . . ... . . . . . . . . . . . . . . . . . . . . . . . .J.'. ~ ~ . 3S 41.648
35 If line 32 Is S8a,025 or Ie.., mulUpfy !2,500 by Ihe 10101 numbO' 01 OKompllons c1a1mod on IIno Go,
II IIno 321s ove, $80,025, .OD lho workshQtlt on pogo 24 lor 1119 onlOunllo onlor . , , , , , , , , , , ' . ~,':':. 38 10.000
3T Taxlble Incomo. Sub~ocl line ~9 I,am IIno 35. ~ ( 6; I, 37 31 648
Iflif'l" I. mOfllP\Il\llill,'S,"lt"..C- ... I.. I.......... ........ "" , , ...... , . . .
, ,"11 .. ,~, 38 Tox. Choc~ IIlrom . t!l TI~ TlblD, bOT ax R.,o Schodulas, cD Copllol Gain TIl)( Work.hoot,
~~. Il~ to
. . ,.. ,."l~' or dO Fo,m 88'S~soe p.ge 24),~mount flom FormCs) 8814, ",. ~ 0 1_ 38 4,744
'''.Ht:!'~' 31 AddIU.noIIO'O., Choc~ I' i:1t 'I' 'U.m ~ ;1!,! Form 4972. .r-"'., .,., .'.' ' , , , , . .. ... , . . 31
.i ; ji:'lhll~"'..h :1" nl' I 1'1 til'lt:1!"" W ;'..~ltt;l: 4.744
40 Ad~ IIna, 38 and 39.., .I,!~",~". .LI ,.~I\i ..",..", ,'.""",.,.,...,..,.,.. 40
41 trodlllor child snd dopo '~:~J1;\'I'I"I:T..:"'1 on. :~: ft. ,~I:. 2441""" '! .i PII"'!
CrQtlils .""'. :~i, .;11111
. , Ill' t'
42 Cradlllor lho elderly or t ~:~ ~nc .... oo,ia.. ,."",." ;::" "rl~,ll
.:';'1 "'4' 'l:l,i' """11 ,t,. ,.::;,rl;i
43 Forolgn 10' cradlt. Attoch ~ 1118.. .. , ~:.! . .. .!J,,:, .iliF" i.J" 1,1'. . .., Ihl,!I.:'
~ 'II ..IJ'i'!' I,;;',. I,'"".1 ,', . , ...t" ;r'\.~
44 Olho, credits (seo pogo . hOc~ IIlrom Tf F . . ' . 11'_1 :"
L;~!i"
b 0 Farm 83~6 c 0 Form OaOl dO Farm 44 1:!'\':I;o
45 Add IIn09 41lh,ough r~n~~' '::il " ~: ".... '~I' ... WI."~ ........... 46
46 1:1~!,ji .,.I';!;1:.1 ,i"li, ;ll! i ""fl :1,:"".'J',')~lj,.I:' ;;. I. j'I~;1 48 4.744
5ubtroct IIno 4S from lh . In.. 5 I .. '.1 4 .:0. .. .. I..!.:~ . . . ~t~,.. . . . . . . . . . . ..
47 S II I 11~" S h,5E-'.'.'" ,1,1"' "'rh:m1i,:: ..'l~,:1i 47
Olher u -~p oymon ll>C I.', c.' ." '~"'I:~:fJ "'j!'(:i::C1i ,: i': ... '.'(""""I':"'''~' ..........' -
40 Allernol,v. minimum ~i' 3 G ~,1" .... :-:i:! " ~........... ~~.. .. .. .. .. " 48
T~~cs ---- --
4' AOl.;nplu'OI~",Ch ~!~P'I..il"I:It~I:1 FC:~lt""'I(.t:!~;J F Jr.,811 cO'o,m ....j .............. 4.
.... r. ,~. ._,
SO 50clol ~u"ly ond Up ,......~ ...' on o'~ployor. Anoch In 4137 , . , , , , . . . SO
SI To~ on qu.'ifiod relirement plont, Including IRA'. II roqul,.d, anach Form ~329, , , , , , . , , . . , , , , . , , , 11 -
---
52 Advance oarned Incomo crodil pOymenl1 from Form w..a . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . I I I I . 52
53 Housohold ompfoyment 1exas. Attach Sehedule H . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53
54 Add IIno. 481hrouah 83. This 18 vour 10101l1X, . . . . , .. , , , , .. , .. .. .. .. , .. , , . , , , , , . , , , , , . . , · 54 4.744
P~ymonls 55 Fodorollncome lOX withhold, II ony Is Irom Form(o) 1099, check. 0 55 ~'7'1. 6,616 'l!j'II!.j
:.';:''j''i
58 1095 o,Umalld tOJC poynlllnl& and amount eppllod from 1094 rolu'n . , 56 i~i:1 ,I
!"llt'
57 E.rnod Incomo crldlL Anftch Sehedulo EIC If you ha.lo 0 quolllylng : . -I',i~i!l "1.111. '
'1'1'1' r ',ll~ ~'"
child, Nontsx.ble oomed Income: MlOunl,.1 I~ l:lli:l;!~J .1i!i1i;i:
~ ~. : I' jll:I~~'
.. '....I..V.J. .nd typo . tlO 57 ~!TI;'1
N.Jr;. ,~(f sa Amount pald wilh Form 4088 (..tension requoet). , . , . , , , . . . , , . , , . 56 :;,,1:'-,
'~'a.'" 1.I!\
.",'Ie"t. 59 E.coss ooclalspcurlly ""d RRTA tsx wllhh~ld (..e pogo 32) . , . . , . ., 59
.1".
'.r'!'
60 Olnor p.ymenl3, Chock Illrom .0 Form 2430 bDFarm~130, " 60 ri:II;I.l..C
.. Add IIno. 55 Ih.ouah eo. Those Ill. vou. lot.! D.llmont. . , , , , , , , , , .. . , , , , .. . , , , .. , , , , .. .. . · 81 6,616
--
.-lo'..nd or 53 IIl1no 81 Is morD lhan I1no ~~, sublraelllne 54 Irom I1no 81. This Is Ihe amount you OVERPAID, , ..", 62 1,872
:.",~unl 83 Amount 01 nna 62 you wont REFUNDED TO YOU.. , .. , . . . . . . . , .. . . . . , 'f . , , , . , , , , . , , , . , , , · 83 1,872
.((I\IOWO 5~ Amount of Uno 62 you w.nl APPLIED TO 191GESTIMATED TAX.. ..I 641 i'i'j:f;f
.111".'
55 II fino 5411 moro th.n nna 61, sublroct Ih10 81 I,om IIno 54. This IS tho AMOUNT YOU OWE. "11':1,',
~
Fo. dotllis on hOW 10 p.y ond uso Form 1040-V, Payment Vouchnr, $00 p.go 33 . . . . " . . , , , , , , , · 65
66 Estlmot.d Ill)( .Inol'" CSOO poao 33). Also Ineludo on IIno 85 . . . .. . .'-] 50'.-1. .1. l'j..~l.tii!m;,..!;~;.~.!ti;:l; ~ 1 :~i::l;l: :,/;:' !'; :.' ;
U"I' p.n,lt,U 01 per,l/fr.1 uc:t", ","I n.... '.,"'Intd I"t, .tllIll'\ ,rolll.e:"rlplnV'"Q JcnUII'U ~"'C1 ,U~UI"""U.II'" II: H" 1:1I1101 tIl'/ .fta....'.C1 . anll Inllll,
Slll'l
Here
l
VI'" .'1 VIII. co'"e'. .nd COtl'lP'.t.. o"",.tI(II'I of ",..,~,., lelh., '....n ")IInt,tll, I)U8/f 01'1 ,1I11,tO'IOl,)tiO" of ....!'Ile" II"""" ".. .".. kl'lO ..,1,11;1.
,
;'>,lid
;.:'r';I'':UC''S
V~g Only
~ yuw"III",I",'
~ $UOol"" clgl\.h,j,..lf . lei'll "11l"~. 80")11'1'I\1" "0""
~';;:,':,';' ~ JUDITH L RIEL
H & R BLOCK
r'I""I"""'lo'yfl~" ~ 'r---'
"n".....,.lo.,.dH"'. 70 W. MA...N ST.
''''In MECIIANICSBURG
DIU
Vall,u,~",'IC'"
.. " , ~ ~;I.
. ..\ 'd~"
'/'10'
'..':'
Oa'l
POSTAL CLERK
!,OIlIl" acc~pa'IO"
POSTAL CLERK
Calf
P1'~IU',". 100Ial.te""'t"O'
1 17 96
ell,,_1f
Ulr".",ployd 0
E.!. NI).
ll'C~Ult
209-34-8328
23-2314357
G-5
INCOME AND EXPENSE STATEMENT OF
IhflrYJO<; ff), 5aJomon
,
SSN
/17 ,5'1: 8ttJOlS
DATE
THIS STATEMENT MUST BE FILLED OUT
DRtI OJL/9 g 9
(II you are sel'.employed or If you are salaried by a buslncss 01 which you are owncr In whole or In part, you must,
also 1111 out the Supplemental Income Statement which appcars on the last pagc of this Income and Expense
Statement.)
INCOME
(a) Wages/Salary lJ. / I I IJ j Orf.
Employer & Address ' 1<, I-t J J -1-' () r.J I....
Job Title/Description (1'1 ,., Wol:. ~
Pay Period (weekly, bi.weekly. monthly) {" ......~, v
,
Gross Pay per Pay Period ...,.......,........,...........,....................,.,......,.....,...................,....,......,............,.. $
Payroll Deductions:
Federal Withholding .....""".."".$
Social Security """"..""""...,,,,,.$
Local Wage Tax ""...."..""""....,,$ 1J;;J:;;ib i-
State Income Tax .."""""....""...$ f().Av.yt j,tA ~
Retirement ,,,..............,..,,,,,,......,,$
Health Insurance ...""......,...."",,$
Other (speclly) .""."............""....$
.""",..,.........".,,$
,......"...........".,,$
Net Pay per Pay Period .....""""....."."""".".......".........:"..""....."..""""..................................."""", $
(b) Other Income
Interest/Dividends ,...................,,$
Pension/Annuity ""...................,,$
Social Security ...........".....".,.....$
Rents/Royalties ......,..,......,...."...$
Expense Account ..,.....".............$
Gilts ....................."....."....."......,,$
Unemployment Compensation ,$
Workmen's Compensation ........$
Week
Mvnth Year
S $--
$ ----- $
$ $
$ +--_. $
$ $
$ So
$ $
S $
S $
Total, Other Income .....,........."......$
INCOME AlW EXPENSE STATEMErH OF
I verily (hat tho statements made In this Income and Ell:pcns~ Slalr"
ment arc Irue and COff(~cl.1 understand Ihal false slatcments hc,('in
arc made subject to the penalties 01 18 Pa.C$, 4904 relating 10
unsworn lalslflcatlon to authorlllcs.
Dalt!:
-.plaiOiiffffi- Oc;i!n(i,iiii
,p 11 Aell 1114.
])
ORO 11405
EXPENSES
Home
Mortgage/Rent ,.,..........,....,........,.,.......,..
Maintenance .......,..........,...,.,.:..,...........,.
Utilities (telephone, heating
electric, etc.) ......,..,.,............................
Employment (transportation,
lu nches) ,.................,.. .,....,.... ..... ..,.......
Taxes
Real Estate ...........................,...,.....,........ $
Personal Property................................... S
Income ..................................................... $
Insurance
Homeowners ...........................................
Automobile ..............................................
life/Accident/Health ..............................
Other ........................................................
Automobile (payments, fuel,
repairs) ............,............................ ........
Medical
Doctor, Dentist, Orthodontist ................
Hospital................ ...................................
Special (glasses, braces, etc.) ...............
Education
Private, Parochial School....................... $
College ..................................................... $
Personal
Clothino .......... .................... ...........
Food .......... ..... ...............................
Other (household supplies,
barber, etc.) ...,......................................
Credll payments and loans ....................
Miscellaneous
Household help/child care ..................... $
Entertainment (inc. papers,
books, vacation, pay TV, elc.) ............
Glfls/Charitable contributions ..............
Legal Fees .................................. ............
Olher child support/alimony.
payments .................................
Other (specify) ..s.f.~.V.I.A.~..'..~.~~.~~.~.!.,/.ru" r ..
Total Expenses .................................
Household
Week I
l , f,
$ H~ M".IL $
$ , $
$ I Jdlt1...,R $
,
$ 10Q ~
$
Child
Week
$
$____.__._
$
$ $
$ <:;()/~.-Ir $
,
$ $
$ $
)1<1 JL r'~J leI
$ ~/~.- $
I
$
$_:
S
,
$_Y ~..!!-
$_ 201;,......
s / 1- 0/,..,)
$ J,1"r/"...
,
$
$ -
$ --.----
$__
$ '1?S
$-~-
I 23Z5
$
$
'$
$
$
$ -.---.-. ..
$
$___
$
s
S
$ -----
$______.
$____
S
$ ------.-
,
-.
Household
Month
Child
Month
$ $
$ $
$ $
$ $
. . .'
$ $ I!
S , ....-------- $-.---.
$ $ ..1,
,
$ $
$ $
$ $
$ $
$ $
$ $
$ $
S. S
$ $
$- $
s ______
s ._
$_---_.. .
$
$ .-
$
$
$
s.
$
s.
s _
s _._..___
$
$
$
$ ---
S
$-
$ -----
$-----
$-
"
. . ....'
Ownership'
PROPERTY OWNED Descrlpllon ;
Checking Accounts ......., - P,ll.l (. ,l'r" Cv1JU.,,~
,...,... ~~ V
.. Sa.vlngs Accounls ,........., - IOj. .. ... (,d.! ..'_
....................
Value
$ 10 '!:/.
$
$ to'::"
$
$
$
$
$
$
$
$ ~)ot.l
$
$ '1 J lv
,
H
w
J
Credltllnlon .....,.............,
Slocks/Bonds ...,..............
Real Eslate .........,............
Olher ,..................... 'f1, t 5'J'.'" 11._
..........,.................:...-/.... . ,
,
........................1.......
Total, Properly.......,............,
INSURANCE
Hospital ......................,....~
Medical............................
Health/ACcident ..............
Disability Income ............
Other (dental, elc.) ..........
('H. Husband, W, Wife, J ,JUI,", ~'Chlld)
Company
,...... "I. (r/
, .
Polley No.
u;jo@e'@
SUPPLEMENTAL INCOME STATEMENT
.'
A. This form must be filled out by a person who (check l;me):
,.
(1) operales a business or practices a profession; or
(2) Is a member of a partnership or join I venture; or
(3) is a shareholder In and Is salaried by a closed corporation or similar entity.
8, Attach 10 this statement a copy 01 Ihe following dOCuments relating to Ihe business. profession, partnership,
joint venture, corpora lion or similar entlly.
(1) the most recent Federal Income Tax Return, and
(211he mosl recenl prom and loss Statement.
C. Name and Address of business:
Telephone Number
D. Name and Address (if dlflerent than C) 01 accountant, conlroller or olher person In charge of financial
records:
E. (1) Annual Income Irom business ............................................................................................. $
(2) How olten Is income received? ............................................................................................ $
(3) Gross Income per pay period ............................................................................:.................. $
(4) Net Income per pay period ................................................................................................... $
(5) Specllic deductions II any .................................................................................................... $
'.1
,
~ r- '- ~~\6 Ai
lr. [.- ' \\j ~.;:j- ~
?: --::t-
r .;0 :s~ p ~ "...,
(3 " .' q I'() ~
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e: \0 :-,() ~ ......
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p:: 8 N ~~
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Ill.
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tWI...IU.J.D...'.....UII....nu. '0fIl"'"
,. "'MOlYMIUHI.,J.1Yl,1lY to trOIWO... "lwOnllYLt11'1
...
i.
Lt.O,,,uI
SERRATELLI, SCHIFFMAN, BROWN & (;Au/OON. r.c-
Sum. 201"
2010 Ln.uu..fTnWN RoAn
H.u.w:lvao.PA 17110-9445
...
- .
..
..
THOMAS SALOMON, . IN THE COURT OF COMMON PLEAS
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
:
v. . No. 94-2884 CIVIL TERM
.
TAMMY SALOMON, CIVIL ACTION - LAW
Defendant . IN DIVORCE
.
PETITION FOR COUNSEL FEES.
COSTS AND ALIMONY
AND NOW COMES Defendant in the above captioned action, by
her attorney, Lori K. Serratelli and the law firm of SERRATELLI,
SCHIFFMAN, BROWN & CALHOOON who petitions this Court for counsel
fees, costs and alimony and in support thereof, avers as follows:
COUNT I
1. The Plaintiff filed a Complaint in Divorce under section
3301(c) and 3301(d) of the Divorce Code on May 31, 1994.
2. By reason of the institution of the action to the above
term and number, Defendant will be and has been put to
considerable expense in the preparation of her case, in the
employment of counsel and the payment of costs.
3. The Defendant's income is disproportionately lower than
the Plaintiff's income, and Defendant is without adequate funds
to pay the costs and expenses of this litigation.
4. The Plaintiff is currently employed by the U.S. Postal
Service. His net monthly salary is approximately $2502.00.
5. The Defendant is currently unemployed.
~.
-
WHEREFORE, Defendant prays that your Honorable Court grant
an Order upon Plaintiff to pay Defendant's counsel fees and costs
of the litigation.
COUNT II
6. Paragraphs one through five of this Petition are
incorporated herein by reference as though set forth in full.
7. Defendant is unable to adequately support herself through
appropriate employment.
8. Defendant lacks sufficient property, including but not
limited to, any property distributed pursuant to Chapter 37 of
the Divorce Code of 1980, as amended, to provide for her
reasonable needs.
WHEREFORE, Defendant requests that the Court grant and award
alimony.
Respectfully submitted,
~
\ ,
LoriK Serratelli, Esquire
SE~T LLI, SCHIFFMAN, BROWN &
CALHOON
2080 Linglestown Road, suite 201
Harrisburg, PA 17110-9445
(717) 540-9170
Attorney for Defendant
-
.
CERTIFICATE OF SERVICE
I, Lori K. Serratelli, Esquire, do hereby certify that on
January
-,
1997 I served a copy of the foregoing upon the
Plaintiff by depositing it in the United states mail, postage
prepaid, addressed as follows:
E. Robert Elicker, II
Divorce Master
Office of Divorce Master
9 North Hanover street
Carlisle, PA 17013
George W. porter, Esquire
909 West Chocolate Avenue
Hershey, PA 17033
Atto ey for Plaintiff
1. l,
Lori/ Serratel1i, Esq.
SE ELLI, SCHIFFMAN, BROWN ,
CALHOON, P.C.
2080 Ling1estown Rd., Suite 201
Harrisburg, PA 17110-9445
(717) 540-9170
Attorney for Defendant
\
''',.-
r_..---.
".
..
To
You arc horeby nOlified 10 mo 0
wrillon "'pons< 10 tho onc:losal
within IW<nty (20) da)'l from ..,-
vice: horoof 0' 0 judgm<nl may be:
onlorod agaiDlI you
by
...
~=l~
I ~: JIll J \1 \'.
lIul 1\\;', .~
( \1111 U l'\,. 1"(
SUln201
lOBO Li~l;USIOWN ROAIl
HARRI~IlURl;. I'A
1711ll.944~
\~" \ te-. t11~1O
-<
Wo do ho..by ce:nify thaI Iho
within is 0 lruo and corroa copY
. of tho original med in Ihis oa,on
by' ,
An....,.
Ano""Y
..
., ..~......,. ,....;....;..;4.,),,'.~".""N+..!i"'~',:.........~;,..;..,..............-.;~...'...,.......~"
-'
.
.
.
,
.
,
,
.
~
it
r
..
r'~
l. :
.~
,.
jf
"
;
..
.
,
THOMAS SALOMON, . IN THE COURT OF COMMON PLEAS
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
v. . No. 94-2884 CIVIL TERM
.
TAMMY SALOMON, CIVIL ACTION - LAW
Defendant IN DIVORCE
PETITION FOR ALIMONY PENDENTE LITE. COUNSEL FEES.
COSTS AND ALIMONY
AND NOW COMES Defendant in the above captioned action, by
her attorney, Lori K. Serratelli and the law firm of SERRATELLI,
SCHIFFMAN, BROWN & CALHOOON who petitions this Court for alimony
pendente lite, counsel fees, costs and alimony and in support
thereof, avers as follows:
COUNT I
I. The Plaintiff filed a Complaint in Divorce under Section
3301(c) and 3301(d) of the Divorce Code on May 31, 1994.
2. By reason of the institution of the action to the above
term and number, Defendant will be and has been put to
considerable expense in the preparation ?f her case, in the
employment of counsel and the payment of costs.
3. The Defendant's income is disproportionately lower than
the Plaintiff's income, and Defendant is without adequate funds
to pay the costs and expenses of this litigation, and is
likewise, without adequate funds to maintain herself during the
pendency of the litigation.
.0
VERIFICATION
I verify that the statements made herein are true and
correct. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. section 4904 relating to
unsworn falsification to authorities.
'.-4:1/
....... .~ '/ ~~/--
'Il~y ;,tALC ON
.
CERTIFICATE OF SERVICE
I, Lori K. Serratelli, Esquire, do hereby certify that on
this 13th day of December, 1996, I served a copy of the
foregoing document by United states Mail, First Class, postage
pre-paid, to the following person{s):
E. Robert Elicker, II
Divorce Master
Office of Divorce Master
9 North Hanover street
Carlisle, PA 17013
George W. Porter, Esquire
909 East Chocolate Avenue
Hershey, PA 17033
Attorney for Plaintiff
--?_" II jJ /) <( .J7/'4'
~. ser~e111, Esqu1re
SERRATELLI, SCHIFFMAN,
BROWN & CALHOON, P.C.
2080 Ling1estown Road
suite 201
Harrisburg, PA 17110
(7l7) 540-9170
Attorney for Defendant
..c
tJ ~
~~ '"
:or
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0 0."" Zlll U HE-<
E-<U ~.... 0'0 oo~
e>: OS:: ~s:: '<l' - ~!;::;::
00 ~.~ OQ) CO - 00 is .... --
OZ ~~ CO r... III
U:S 000-1 . N r...~ !
!:l< > 000 I HOO
~e>: 00 '<l' E-<Z
:O~ ~ ! '" Z~
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0 . :s~
zo :0 0 III
MM"U..AD...U..W<ftlt.....nu. :"QNfWOj
,. "1YNQUYWUHl.,u'f'l..11Y.o NCIWolCI Y "1'fDI1UYd"""
a...Otnu,
SERRATEUI, SCHIFFMAN. BROWN & CAUlOON. P.c.
Sum 201
2010 I.JNoUlTOWN RoAD
H.wJs.~P^ 17110.9445
.1'), -( ~qp k.
.
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 94-2884 CIVIL TERM
THOMAS SALOMON,
Plaintiff
TAMMY SALOMON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
DEFENDANT'S INCOME AND EXPENSE STATEMENT
LORI K. SERRATELLI, ESQ.
SERRATELLI, SCHIFFMAN, BROWN
& CALHOON, P.C.
2080 Linglestown Rd., Suite 201
HarriSburg, PA 17110-9483
(73.7) 540-9170
Attorney for Defendant
INCOME AND EXPENSE STATEMENT
QZ
TAMMY SALOMON
Employer UnemDloyed
Address
Type of Work
Payroll Number
Pay Period (weekly, bi-weekly, etc.)
Gross Pay Per pay Period
ITEMIZED PAYROLL DEDUCTIONS:
Federal withholding
Social Security
Local Wage Tax
State Income Tax
Retirement
Savings Bonds
Credit Union Dues
Life Insurance
Health Insurance
other (specify)
Net Annual Pay Per Period
OTHER INCOME: WEEK MONTH XMB
Interest $ $ $
Dividends $ $ $
Pension $ $ $
Support 1 $ $ 995.00 $ 11.940.00
Food Stamps $ ($113/MOl $ 108.00 $ 1.296.00
Workmen's Camp. $ $ $
TOTAL NET ANNUAL INCOME ...................... .$ 13.236.00
EXPENSES
Week Iv Monthlv Year Iv
HOME:
Mortgage/Rent $ $ 675.00 $ 8100.00
Maintenance $ $ $
UTILITIES:
Electric $ $ 140.002 $ 2680.00
Trash $ $ 12.00 $ 140.00
Telephone $ $ 20.00.l $ 240.00
Water $ $ 25.004 $ 300.00
SUBTOTALS $ $ $ 11.460.00
'Order of Court of Cumberland County Domestic Relations
dated September 11, 1996 for Wife and two children (allocated
$629.00 per month for children and $366.00 per month for Wife) .
Unreimbursed medical expenses are to be paid 78% by Husband and
22% by Wife with Husband continuing to provide medical insurance
through his employer. The Order is currently on appeal.
2There is currently an overdue balance of $l65.25. The
current payment plan is $10.00 per month. Paid $10.00 on 10-7-96;
and 11-6-96 on the original balance of $185.25.
3There is currently an overdue balance of $125.00 for long
distance charges. The current payment plan is $26.52 per month.
Paid $26.52 on 10-25-96 and 11-25-96 on the original balance of
$176.52.
4There is currently an overdue balance of $67.07. The
payment plan is two more monthly installments of $33.53.
TAXES:
County/School $ $ $ 22.00
Personal Property $ $ $
Income $ $ $
INSURANCE:
Homeowners $ $ 9.84 $ 118.00
Automobile $ $ 46.28 $ 555.36
Life $ $ $ 86.50
Health $ $ $
AUTOMOBILE:
Payments $ $ 168.75 $ 2025.00
Fuel $ $ 50.00 $ 600.00
Repairs $ $ $ 750.005
MEDICAL:
Doctor $ $ $
Dentist $ $ $ 5000.006
Orthodontist $ $ $
Medicine $ $ 15.00 $ 180.00
Special Needs $ $ $
SUBTOTALS $ $ $ 3586.86
50n 9/3/96 Alternator installed ($72.10). I need new tires
and other maintenance including a tune-up. (Not included in
subtotal)
6My dentist has recommended a new plate, new bridgework and
implants. I currently have a $25.00 outstanding balance. (Not
included in subtotal)
EDUCATION:
Lunch, School $ $ 45.00 $ 540.00
Supplies & Field
Trips
Parochial School $ $ $
College $ $ $
Religious $ $ $
PERSONAL:
Clothing $ $ $ 240.00'
Food & Household $ $ 300.00 $ 3600.00
Goods
Barber/Hairdresser $ $ $
Credit Payment $ $ $
CREDIT CARDS: (specify)
$ $ $
$ $ $
LOANS:
Louis Seeqers $ $ $ 3000.009
MISCELLANEOOS:
Child Care $ $ $
Papers/Books/Magaz $ $ 6.00 $ 72.00
Entertainment $ $ $
SOBTOTALS $ $ $ 4382.00
This is the amount paid for school clothes this year. The
children are in desperate need of winter clothing which they have
not had in two years. Also, I am in need of new clothing which I
haven't had for 5-8 years.
The Defendant has borrowed monies from her father in order to
live. This is not included in the subtotal as no portion has been
paid to date on the loan.
Pay TV $
Vacation $
Gifts $
Legal Fees $
other child Support $
Alimony Payments $
other (specify)
$
$
SUBTOTALS $
$ 22.50 $ 270.00
$ $ 200.009
$ $
$ Will be suoolied at hearinq
$ $
$ $
$ $
$ $
$ $ 470.00
TOTAL ANNUAL EXPENSES:
$ 19.898.86
PROPERTY OWNED:
DESCRIPTION
VALUE
H .Ii !!
Checking Accounts
See Inventorv and AODraisement
Savings Accounts
Credit Union
Stocks/Bonds
Real Estate
--------------------------------------------------------
~()~J\IJ ....................... $
--------------------------------------------------------
(H) .. Husband
(W) .. Wife
(J) .. Joint
9Vacation consists of travel to the Defendant's relatives in
New York and the Poconos for tho weekend.
COVERAGE
INSURANCE
MEDICAL
Aetna Freedom Select U.S. Postal Ser.
COMPANY
POI,ICY #
H H !:
874191
-X- -X- ....x
Health/Accident
Disability Income
Dental
Other
u.s. Postal Ser.
874191
x
x
x
(H) = Husband
(W) = Wife
(C) = Child
VERIFICATION
I verify that the statemonts made herein are true and
correct. I understand that false statements herein are made
subject to the penaltios of 10 Po.C.S. Section 4904, relating to
unsworn falsification to authorities.
. . -:/<1 ')// /._
-.../ ' /4-'/
TAl'I~Y SArpMON
1040 C'J"f1-I''''.''' .1 ,tI. lru.tuty - Inlet'fll' nllYtf'''' S.fll1U 1995 I
i U.S. Individual Income Tax Relurn -
l"!l U.. Olll~ - Do ,.." ",I" 01 .t.DI_a.. 'h" ,,,U.. -
'01 ,tit 'r'" Jtfl.' - 0...11. ,.n. at o'h.,,,. y'" b'DIMI", . .1OU.."ol". .11 I OJJlBUo.U.'.tlO'f
L:,bcl vo...,Il,,,,,,III..,,ilfllll.11 "1""'''11 Vlw..d,llI",,,,,UrNaM'.,
~ .., . THO/1AS M SALOMON 1l7-5.1I-B625
........,.:c..., s,........ ...t"I..nl,",,,vlIlb., -
. "10 io,,,,,.lw'''. .pov.... t.f"",/llI1 ."d 111.11,1 "",1",'1'\1
. q"'.l n
( TAl1l'IY M SEEGERS 093-60-968!i
.; 'M..n:s .
..... tt~M' ueftn. ("It",ber '"If "'IIlI~ If y." '"~' J P.o. hr, SI' ,a a' 11. ""1.110. For Prlvlcv Acl ~nd
. ..:.. "
..,:.,;"11 t P.O. BOX 691 PlpolWOrk nlduollan
II
'.',#.. ( City. 10"" 0' DOII,ffln, "111. ,II' ZIP co:=-..II yl'" nt.... I ',"ID" add'.,., "'IU" '1. Acl Nollcl. UI Dial 7.
P'C'JldcnllJi' DILLSBURG PA 17019 VII No H,I'1 Ch.C"''',... ,,-
~1.:.t~I~O" .COI,np::alun ~ 00 you wenl $3 10 go 10 IhI:! fund? . . . . . . . . . . . . . . . . . . . . . t '. . . . . . . . . . . . . . . . . . . . . . . . . X _4IIft.le"',.,,;_ ,-'"n
tllr.I' "tluu.,out
.. ,. .l' 1.1 II a Iolrll ralurn. doo, "our IPousa want 1310 nolO Ihl, lund? .......................... X """HII.
I ~ Sln9'.
rilln9 Slatus 2 Mlnlad nUng lolnl ralurn (ovon If only Dna h.d Incomu)
~
..;,.. r~~c '1.1 3 I-- Monlod flUng 'epiloIa rolutn. Elllor SPoula's soc. soc. no. abavo & lull nDlno halO ~
:"I'.c>\lr 4 Hood of housohold (Vollh qualllylng porson). (5.. pogo 12.) IIlho qUllllrln9 p~lSon I, . child but nol you, dopondonl
10.'. nnllll'lhl, Chlld'~,~:~i,'IJ1. .;:;.,.1-~ """" . -.......,.,....
! ,- QuallMnn wfd '.. ~ "" .'. on fiHt\'hll~ rt.~DI ODOU'O diu '. .... -". rsoo DOOO 12.1
-.-. "..,.,~~ ~~t ilo S~:'?I'. hlo 01 ho, tM -
sa IS VoulS.lI. II your II ~~ 00) cfllm you os
..,omplluns . ,.Iurn ~. au a. UtO to ~heck ~~,: :Ub on pogo ::I. . . . } HI. If ,,~..
~ilij ~.~!: ~iiil Ih"'''.II
,:... t..~. III b ~ SpOUllfl. . . . . , . . ";r. ........... .. ,,,l. .....,.. .,," !"l~\ "........ ................. ,"'Oil .
. L:::' i"'" o."""'....~u ..... """" 14JHI..f,"U.
C Deponden"'; l~'. 1o..,...u."I', 1140.,11 'U",
JlC"IIIV "\ll'llblr.1f bit" n-,dl"Y"JII' ,"'Ihlf''''''
(11,j,"N.tlI' lalln."'. In un..tlUQ.IJ. l,t.Udnstllpto rOil' hUtll,I."In le_"o:
MeN~ - 6 .:;- U ;)! E ~ 12
HOLLY M SAL ." .. . I".d..,"'" Wov ,
TIlOMAS M SA 0 ~JJ: ill;! 1-&9~ ,H':t.: 6 ~,9i1+-7- ,S N ~;~Il;' l:~if] 12 . .",.',.", ".,,,
~'1': -.:u::r :"!J~ ;i:I:J ,jf;'>I:~.." ,t,1 I',':'~ ~:~~ )'O"11I.1I0,I,,Ofu
'.. ~IfI'r J' :.. "'f1u"llOlll~"
:........It. - t ". ....f- :;:4.....".,;:... lI.g114l)
.. ~ .'~O:: ,~" I}',U t7r1 l'IH .!!i~':: U::;'W' .. ~"II!:~~' --
:Ilh ~.::.;,A ,.<If. ~ ",r ".'1..1 1'~!ii..1 O,"l'lU..U
;'''1''
.,.... . .. .. ,... ., .. .", '.. ,I w:.:.::l L:..;:J On.enol
."..f..U".... -
..
..
Illc.orn9
d II your child dldn'lllve will' you bull, clalmod co your dop. undQr pIO"10BS ograomon~ choek.. ~ 0
. TOlal numbl)( ollxornptlon, claImed. . . I . . . . . . . . . . . f . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I .
, Wogo,. S1larie,. tip!. OIC. Anaeh Fom,(,) W-2........................... .~I.lJ.f... /.PS:. 7
II T""blelnlero,,lncomo (see pogo 15). Anoeh Schedula B If ovor S400 . . . . . . . . . . . . . ... . . .. . . 8a
TOX-Ixemptlnterea'l.eo pogo IS). DON.T I",~d. '" H.. ... . . . . . . . 8b ~:i;\:il;.
Dlvldond Incomo. Anaeh Sr.hodule B If OVOf S400 . . . .. . . . .. . . . . . . . . .. .. . .. .. .. . . . .. . . . .. g
TlIJCoble rlfund,. credUs, 01 On,OlS of S1QIO and lacllllncomo laxC3 (3eo pogo 15). .. . . . .. . ., . ... 10
A1lmonV rec&tvtd . .. . ........ . . ., . . . .. .... ... ... ., . . . . . . . . . .. .. . . . . ..... .. . . . . . . . 11
Bu.lnoSllncome or (10"). "naoh Schodufo C or C-EZ.. .. . . . .. .. . .. . . .... . ... .... . . . .. . . 12
Copltllgeln or pooa). If loqulrod. anach Schodufo D . . .. . . .. . .. . .. . . . . . . . .. .. . .. . . .. . .. .. 13
Othut gains or (Io.,ot). Anllch Fcrm 4797 . . ... . . I ,. . . .. '"~ . . . .. . .. . . .. .. ... ... . . .. .. ... 14
TalollRA dl,lrlbullon,.. .... .... l~' U b TI..bleonlOunl (pg. 18) 15b
Talol pon,ion. Ind annuillo.. .... [!!!J 0 b TI.obIO cmounl (Pi, Ie) lob
Flanlalleol etl.le. royolllo.. pMna19hlps. S corparollon,. IIU"'. etc. Anoeh Schodulo E. . . . . . . . . . 17
Firm Income or (Ios!). Anach Sthodula F . I .., . . .. . . . . . . . . . . . ., ., . ... . .. .. .. . .. . . . . ... 18
Unemployrnon' compensallon (soo pogo 17)........................................... 19
SociI! sOeurlly bonoll".. ....... ~ b T..ablo omount (pg. 18) 20b
Olhe,lncon>l. 21
Add Ihe emounls In tholDll1 hI column 10' IIno~ 7thrau h 21. Thl~ II our 10101 Income . . ., .. . . ~ 22
Your IRA deduction (!leG pogo 19). . . ., . ot . . . . . . It .. . .. .. . .. 231 ':~:,:W!
Spouae's 1M doduCllon (20e plgo 19). . . , . .. . . . .. .. . . . . . . .. 23b "~i!i~i,1
Movfng ,"pensll. Anoch Farm 3903 0' 3903 -F . . . . . . . . . . . . . . . 24 'I:'~~r';
O h , I .If !'1hl'
no- II 0 'oo -omploymonllox.......................... . 25 q~'I'I'1
S~II-omploYla hoallh fn.ur.nco dodueUon (soo pago 21).. ...... 28 j::~\I:i1
Koagh & ,alf-omployod SlOP plan,. II SEP. ChOck ~ 0 . ... ... 27 1"U;f"
j.!I'!'?1
Ponafly on early withdraWlf 01 savings. ......... ...... . ... .. 20 ,/;1.,.:
Alimony plld. Floclp1onl's S5!l ~ 2t 1~I:lh:;;
Add IInoS 23a nlln\lgh 29. TholO 010 your 10101 odlullmlnla. . . . . . . .. . . . . . . . . .. . . . . . , . . .. ~ 30
Subtract nne 30 110m 11110 .2. Thl~ IS your ~dJu~t.d gro" 'ncomo. II loss thnn ~26.673 end ooh1l1
lived Volth you 00"' Ihon t9.200 II child dldn'llIvo Vollh you), lOa "Earned I~!!~ erect,r an ~ 27. ~
b
g
to
11
.2
13
14
IS.
lU
17
t8
19
20a
2t
22
23.
b
24
25.
26
27
28
29
30
AdJusled 3f
Gross Il1corno
1\.....;"
"l'llluly,,,,r
.".I....W.J.
'N ~n.,,"'lt
"":J. Il I,,,..
f.":J:t.,..rn
.,. \VI.t.
,""\I.tC.
..,,'I..lrlO
....:.. ,tI,I'
.....'..
....,.....".
i,J'
AdJustments
10 Incomo
ACldltUII\tlfl'
."U'4O'';"
"""11I0'4' ..
(
48 178
2'0--
-F
46 199 -
~TfA(iJ~', d
J>
48
~.
198'
-~
.
..-;-....--.:......... "....
;,,""0401'O'~) 'l'HOI1AS 11 SAL0l10H AND TMU1'i M SEEGERS 117-54-8625 ',,,,,>,,
O' --- a2^;"o~nllr~m IIne3i(idjij,1od gro.. lncomo) . .. .. . . .. .. . .. .. .. .. . . .. . . .. . .. . . .. . . .. .. . ... I 32
~~( 33 IChnckll: 0 VouwOIo050,0Idor, 0 Blind; OSpou..WU050roldor. 0 Blind. LI~!rn,I~I"li
..,IJrIlPU- :I:~I
II Add 11,. nwnbor 01 be'os eh.ck.d obo~o ond onl.r lhol.lol horo ........... ..... ~ 3" '1,1,: "
I' 011 i"'I'
. b II your porunl(or someone alto) cnn el.lm you os I dcpondonl. chOtk ho<e. , . . . . . . . ~ 33b lJ f 'jl: ~
'.. '.':' c II you .'0 nl~,18d nUng lopar.lo1y nnd your IpoutO Uantlzo, dlJducllon!l 0' you Or' Ill: I~~~
. dl,fal-'Ullu!I al'.n. :SOt pogo 23 ftnd chock horo. . . . . . . . . . . . . , . " . . , . . . . . . . . . . "" 33c 0 11 .'
j Uoonlud dodu,Uonl frum Schodul. II. IIno 28, OR l~: ~I!
34 enlor SL,nd..d doducllon ,hown bOIOW for your nllng .loIUS. But II you chocked' ~01~i':
IhO ony boa on 11"0 330 or b. go 10 p.go 2310 nnd y.ur ,lnndnld dodue,'on. . IW I'
,., gor II yoU c!",kod box 33,. your .Iondllrd doduellon 10 %oro. J' ,,'
01 . Slnglo. 13.300 . Mlnlod IIlIng lolnlly or Ouoll'Vlng wldow(.') . $6.000 .. ..... 34
your: e It.od 01 hOUI.hold . $5.750 . Mllrtlld ollng loporaloly . $3,275
:tS SublraelIjno34 frornPno32".. ....... ......, ............... ..... ""'" ..... f"}'{~~' ~_ 41 648
........,.,
~. n5 to
. ..,"IJ'
".leI:"'"
,'~diI5
.;~
Olher
r:s~r.5
..' t' ,~.
Paymonts
~';"'::W'J.
.'/.11',."..
.~ ...t.;;, VI'\
,'.e"t.
,lolllnd or
..."ount
'{(Ill OVlO
$19'1
Itera
. ',': ':~:h
.. "~ 'L1I1."
.,.\,.
',,';:1
"aid
;"',cp:uor'S
U~)q Ollly
Pooo 2
48.19B -
6 550
~5 If lI~a n I, SOG,Oa5 or 1",. mulllplV !~,~OO by Ihelolol numbor of ooompllon. c101mod on IIno 00.
1111110 3? Is avo' $80.025. 000 Ih. worhhoul on pogo 24 lor U.O onlOunl to ontOl . . . . . . . . . . . . . ~!.':.
37 l...blolllcom.. 9ubuoelllne 30 Irom IIno 35. ' ( 6 I'
Utili" 1.'"1111".".11.3....".'.0. .......t f........ ....... ,....... '0.. r.. . r.III.
36 10.. Chock If Irom .1/; lo~ Tablo. b 0 To. Ralo Schodulas. cO Copllol GoIn Tox Worl"~ool.
or dO form 851.5~'00 pag. 24). ^rnounll,om forme,) 8514. .... ~. L 3.
39 Moll1ellOlle,o" Chock II It:'! '. .11'1.." ,,,,,,,;q<m~. ~W. ~Form 4D72. ~'-, ",,,.,,,,'..' . . . . . . . . . . . . . . 3D
'11 8 d 1~lllll..h Ibl"~III:IJ.':1 ntl'lJI IIi 11I11~:",,:.nhltl4~il/lo.tl
40 Adl.l 1143:1 011 :19.... ,.1:., ., .,.,... .~. .. t~ ....... ... '.!:'........................ 40
4 I Crodlllor child and dep~ '~~~~:~~;,~Ron, Oi'~: ,". ~r 2441...... l, ,', " ", %~f,~1
42 Clodlllol U" oldorly or U ~"~,~~'~~nch ,od, [Ii: I .......... :U ' .. i:,~'~;~".'1
. C!i:! In ;iW l}~~il :'1 ""'1<'1
~J rOlo1gn '0' crodll. A1loChl~l'l 1110.... .I~:~:! . ., 'IIJ~' r'""'f,,i':~1ir .. d l'~ ,= ii: ~:,t'l
44 Olhur e,~dll' (00. pogn ~ 'hook l!l,om .:'~ F '~ ~ ~~'I'iI ~t;!I: ',:'
b 0 fOIRI e3~G cO form 0001 dO rorm_ 44 ~':,1",,4:;
~5 Add 11110141 lhrough U.'~:";'~'~'I~',~; .. I";" .'IHI""I'."I .. , ",M!>.j, I" ". w'l",' "i" .....".... 45
4" I I l,bE"i<~ '~~II:"'" ".."", '.",,/ o. l'I""i~ ,v' ",II ":,110 ~ 4"
'" Subtrncllt\o4S romltitl o. ne 5.. . I 4 ~o, L .. '4...... ,..'.............. u
47 $ull-.m~lovm.nl to. [Ai! Seh.!lE-'l... I~l,'. .. ..I'~.::I"~ .. ,,~t' I. 1".".I"i':~:, .. , 1~ll.-';m'" 'I' ~';1' ...."..... 47
. (lfu: ;~~ Io.jl.. 'I'~' . Jm ,.~ ,,'~~ ;Il,~:"l ~.. '~.,I ; ~ "
41 Aliu'Mliv.rnlnlmum _reo IIIOC'II' o,~,l, ..... i,:,'I.. ':~~i:,,,;,,,::,,,:,,'j,;.:., ;:............ 48
4' "o,;oplu.O ,..... eh :di1,1f!:e ,'!'i[ I Fo ~l'II'~~'" " fe ,;~'] all . D form : ,',II .............. 4D
50 Social tocurity and ~ ",,1""'''''''''''' lip ~'#,w.'~: on'lU! o,np'oyor, Alloch'" I n 4137........, 50
51 To. on qualifiod (olilOmenl pl.ns.lncludlng 1M"II roqul,ed, olloeh form ~321................... &1
52 Advance oarned Incomo crodit poyrilentl from Form W-2 , . . . . . . . . . I . . . . . . . . . . . . . . . . . . . . . . . . 62
&3 HOU9IJhold omployment taxQS. AttACh Schedule H . . . . . . . . . . . . . . . . . . I . . . . I . , . . . . . . . . . . . . . . . 63
54 Add lI~el 46 through 63. Thl.11 your 101.1 'n. . . . . . .. . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . ~ 54
55 fod.rollncomelllll wlthh.ld. \I any I. Ilonl rorrn(o) 1099, chock ~ 0 65 <'1U. 6. 616 l\ii~.1!
58 1995 Mt'malod lOX p.V(oonI5 end omount .ppllod 'rom 19D4 roturn .. 56 ~1ii:~
57 :~,:~.'~~~~;:~:~~~:~~::a~h:~n~~ IIf you h010 I qUOIIU'Ylng !l!i\: \:~~~:~I
. =: 'I~I' "
and typo ~ NO 57 !:~r 1
sa Amounl plld wllh form .000 (eolonslon rsquotl). . . . . . . . . . . . . . . . . 58 !i'q, ,
59 EKeO., ooclol .pcu~ty and RRTA lox wlihh~ld (980 p.ga 32) . . . . .'. . . 59 1m, r":
60 Olhor poym.nlS. Ch.ck If Itom 10 form ~430 b 0 Form 4130 . .. $0 l!md,~
II Add II110s $$lhIOUoh 00. Tholo aro your 10111 povmohto . . .. . .. . . . .. .. . .. .. . . . , . .. . . , .. .. . ~ II
62 IIl1no 91 Is morelhl" IIn. S4. .ubtr.clllne 54 Irom Rno 81. ThIs ISlhe smount you OVERPAID. ...... 62
&3 Amount 01 Rno 52 you wonl REFUNDED TO VOU . . . .. . . . .. . .. . .. . ; .. . '," . . . . . . , . , . . . . .,' . ~ 83
G4 Amount 01 line ~ you wonl APPLIED TO IU6 ESTIMATED TflX.. ~ I 64 I I f:Mrnlbl
65 If nno 5410 morO than fino 61. .ublrocllh'o 61 from llno $4. Thlsl91ho AMOUNT YOU OWE. !~
For dol.n. on how 10 poy and usa Form 1040.V. P.ymanl Vouchnr. soo p'gD 33 . ... . . . . . . . .. . . ~ 55
66 Esllmol,d lOX olnol\v ('00 pOOD 33), Also Includo on IIno 85 . . . . . . . ."j '66'1 '1' l!r:~~:~L'i...~ttI1~,~i1::"': :'.::,;' ...: ::-
u""" P'I1II(.U 01 P"I~')'.1 OIel", '''" I ".~. "."'.II,IIU'.I. 'Ihllt' '"' ICClll'tlJt'''Yl''Q JCnlClltllU .I"'. ,11\11.",."13, ,,., Ie In. Dut "lilt """"'UQ' .". tIt-.,1 ..-
""'f 1'1 Vu'. ntlnt. IIuf co,",,,I,h. Dn"',Uotl 0' ,H'~M" lethe, 1~'" Ilkl.t"II, b...d 01'\ In 1"''''''''.1110'' If wPlie:" ,'IP"" "11''''1 Iltll"I.dal.
,
36
37
10.000
31Lll~_ -
4.744
4.744
4.744
4.744
6,616
1,872. -..
. 1.872
~ V"""'D",tlll'
~ s.",,', "1,,,,.,,11 ./.;" III'''. aOTtt ~." "0"
~';::,'::;- ~ JUDITlI L KIEL
- H--' R BLOCK
r'/!""'l.".,(O,.,flll'l ~. 0 ------...
I' ntl.t",,.IOy.lIl'"' I W. MAIN ST.
,,,,,,, ~~IJTf'~RijRG. PA
DaU
VIlU"U~,.,IO"
DIU
POSTAL CLERK
SIlIl\,lU"IllCCUIUII,,,
POSTAL CLERK
Cal.
rr,,.M.fa JU'JI ucwr1t;:;;-' -..
ClUe""
UU-'fI'el1o)d 0
209-34-9329
23-2314357
1 17 96
[,I.tlO.
.___._...__ lIPC)d'
17055
.__.~_._-_.__._._---
THOMAS SALOMON, : IN THE COURT OF COMMON PLEAS
.
.
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
.
.
v. . No. 94-2884 Civil Term
.
.
.
TAMMY SALOMON, CIVIL ACTION - LAW
Defendant IN DIVORCE
CERTIFICATE OF SERVICE
I, Lori K. Serratelli, Esquire,
.I""~ ,
December <.J , 1996 the forego~ng was
do hereby certify that on
delivered by U.S. Mail,
postage prepaid, addressed as follows:
The original to:
E. Robert EliCker, II
Divorce Master
Office of Divorce Master
9 North Hanover Street
Carlisle, PA 17013
and a copy to:
George W. Porter, Esq.
909 East Chocolate Avenue
Hershey, PA 17033
Attorney for Plaintiff
(.
. Serratelli, Esq.
ELLI, SCHIFFMAN,
BROWN & CALHOON, P.C.
2080 Linglestown Rd., Suite 201
Harrisburg, PA 17110-9445
(717) 540-9170
Attorney for Defendant
<
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SERRATELLI. SCHIFFMAN. BROWN & CAUlOON. P.c.
SU1TI201
2080 ~~ RoAD
RuJ.uluw.PA.17110.9+45
1/1- ~lt~1~'
THOMAS SALOMON, : IN THE COURT OF COMMON PLEAS
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. . NO. 94-2884 CIVIL TERM
.
TAMMY SALOMON, . CIVIL ACTION - LAW
.
Defendant IN DIVORCE
INVENTORY AND APPRAISEMENT
OF
( ) Plaintiff (X) Defendant files the following inventory and
appraisement of all property owned or possessed by either party at
the time this action was commenced and all property transferred
within the preceding three years.
( ) Plaintiff (X) Defendant verifies that the statements made
in this inventory and appraisement are true and correct.
( ) Plaintiff (X) Defendant understands that false statements
herein are made subject to the penalties of 18 Pa. C. S. 4904
relating to unsworn falsification to authorities.
. -~~.. -, 'fJ
\, ", '"~~
c>).:~~.' tiff (X) Defendant
, /
'--., ~
ASSETS OF PARTIES
( ) Plaintiff (X) Defendant marks on the list below those
items applicable to the case at bar and itemizes the assets on the
following pages.
() 1. Real Property
( X) 2. Motor Vehicles
( x) 3. stocks, bonds, securities and options
() 4. Certificates of deposit
() 5. Checking accounts, cash
() 6. Savings accounts, money market savings certificates
() 7. Contents of safe deposit boxes
() 8. Trusts
( X) 9. Life Insurance policies (indicate face value, cash
surrender value and current beneficiaries)
() 10. Annuities
() 11. Gifts
() 12. Inheritances
() 13. Patents, copyrights, inventions, royalties
() 14. Personal property outside the home
() 15. Businesses (list all owners, including percentage of
ownership, and officer/director positions held by a
party with company)
() 16. Employment termination benefits -- severance pay,
workman's compensation claim/award
( X) 17. Employee Savings Plans
( X) 18. Pension plans (indicate employee contribution and
date plan vests)
() 19. Retirement plans, Individual Retirrnent Accounts
() 20. Disability payments
() 21. Litigation claims (matured and unmatured)
;'
;~,~.''''.',
( ) 22. Military/V.A. benefits
( ) 23. Education benefits
( X) 24. Debts due, including loans, mortgages held
( X) 25. Household furnishings and personalty (include as a
total category and attach itemized list if
distribution of such assets is in dispute)
( ) 26. Other
f
,
.
'.
MARrTAL PROPERTY: () Plaintiff (X) Defendant lists all marital
property in which either or both spouses have a legal or equitable
interest individually or with any other person as of the date this
action was commenced.
ITEM NO. ]
DESCRIPTION: U.S. Postal Service Pension (Husband)
To Be Provided
VALUE: at HearinQ DATE OF VALUATION:
NON-MARITAL PORTION:
N/A
AMOUNT/NATURE OF ANY LIEN:
None
ITEM NO. 2
DESCRIPTION: U.S. Postal Service Thrift Savings
Plan (Husbandl
To Be Provided
VALUE: at Hearing DATE OF VALUATION:
Present
NON-MARITAL PORTION:
AMOUNT/NATURE OF ANY LIEN:
ITEM NO. 3
DESCRIPTION: Life Insurance IHusbandl
VALUE:
Unknown
DATE OF VALUATION:
Unknown
NON-MARITAL PORTION:
Unknown
AMOUNT/NATURE OF ANY LIEN:
Unknown
ITEM NO.
7
DESCRIPTION: V.C.R.(Broke) & 2 Tables (Wifel
VALUE:
$20.00
Present
DATE OF VALUATION:
NON-MARITAL PORTION: None
AMOUNT/NATURE OF ANY LIEN: None
ITEM NO.
Bedroom Suite, Living Room Suite,
Kitchen Set, Entertainment Set,
DESCRIPTION: All Other Household Goods (Husband)
8
VALUE:
2500.00
DATE OF VALUATION:
Present
NON-MARITAL PORTION: None
AMOUNT/NATURE OF ANY LIEN: None
PROPERTY TRANSFERRED: () Plaintiff (x) Defendant lists all
property in which either or both spouses had a legal or equitable
interest individually or with any other person and which has been
transferred within the preceding three years.
ITEM NO.
1
DESCRIPTION: 1986 Subaru Automobile
NAME OF OWNER(S):
DATE OF TRANSFER:
Plaintiff
CONSIDERATION:
PERSON TO WHOM TRANSFERRED:
ITEM NO.
2
DESCRIPTION: 1987 Ryundai Automobile
NAME OF OWNER(C) :
Defendant
DATE OF TRANSFER: 10/23/95 CONSIDERATION:
1700.00
PERSON TO WHOM TRANSFERRED:
Harbold's Ford. Inc. (Trade-Inl
ITEM NO.
DESCRIPTION:
NAME OF OWNER(S):
DATE OF TRANSFER:
CONSIDERATION:
PERSON TO WHOM TRANSFERRED:
ITEM NO.
DESCRIPTION:
NAME OF OWNER(S):
DATE OF TRANSFER:
CONSIDERATION:
PERSON TO WHOM TRANSFERRED:
THOMAS SALOMON,
Plaintiff
: IN THE COURT OF COMMON PLEAS
v.
:CUMBERLAND COUNTY, PENNSYLVANIA
No. 94-2884 Civil Term
TAMMY SALOMON,
Defendant
: CIVIL ACTION - LAW
IN DIVORCE
CERTIFICATE OF SERVICE
I, Lori K. Serratelli, Esquire, do hereby certify that on
December r~~I1, 1996 the foregoing was delivered by U. S. Mail,
postage prepaid, addressed as follows:
The original to:
E. Robert Elicker, II
Divorce Master
Office of Divorce Master
9 North Hanover Street
Carlisle, PA 17013
and a copy to:
George W. Porter, Esq.
909 East Chocolate Avenue
Hershey, PA 17033
Attorney for Plaintiff
~ iuJ .
. Serratelli, Esq.
SER ELLI, SCHIFFMAN,
BROWN & CALHOON, P.C.
2080 Linglestown Rd., suite 201
Harrisburg, PA 17110-9445
(717) 540-9170
Attorney for Defendant
I
"
tjf/- ;;g-&-lI'
PROPBRrY SBftLBIIBII'r AGRBBMBJr.r
DIS AQD"~"-:r made thisJ11h day of December, 1997,
by and between DONAS M. ULOMOII, ("Husband") and 'l'AIIII1' M. ULOMOII,
Wife"), at Hershey, Pennsylvania.
1f I ~ . B S S B ~ B:
W"K~, the parties hereto are husband and wife having been
married December 6, 1985, in Farmingdale, New York.
waaKBAS, diverse unhappy differences, disputes and
difficulties have arisen between the parties and it is the
intention of Wife and Husband to live separate and apart for the
rest of their natural lives, and the parties hereto are desirous of
settling fully and finally their respective financial and property
rights and obligations as between each other including, without
limitation by specification: the settling of all matters between
them relating to the ownership and equitable distribution, of real
and personal property; the settling of all matters between them
relating to the past, present and future support, alimony and/or
maintenance of Wife by Husband or of Husband by Wife; and in
general, the settling of any and all claims and possible claims by
one against the other or against their respective estates.
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~ THKM~aB, in consideration of the premises and of the
mutual promises, covenants and undertakings hereinafter set forth
and for other good and valuable consideration, receipt of which is
hereby acknowledged by each of the parties hereto, Wife and
Husband, each intending to be legally bound hereby, covenant and
agree as follows:
1. .a..~__.,.;____ IIOr A BaR ~ DIvnDfWR PRC-.-=K..ImB
This Agreement shall not be considered to affect or bar the
right of Wife or Husband to a limited or absolute divorce on lawful
grounds if such grounds now exist or shall hereafter exist or to
such defense as may be available to either party. This Agreement
is not intended to condone and shall not be deemed to be a
condonation on the part of either party hereto of any act or acts
on the part of the other party which have occasioned the disputes
or unhappy differences which have occurred prior to or which may
occur subsequent to the date hereof.
2. _"IK.~ OF DIVORCE DBCRBB
The parties agree that unless otherwise specifically provided
herein, this Agreement shall continue in full force and effect
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after such time as a final decree in divorce may be entered with
respect to the partitis. It is the intent of the parties hereto
that this Agreement shall create contractual rights and obligations
entirely independent of any Court Order and that this Agreement may
be enforced by contract remedies in addition to any other remedies
which may be available pursuant to the terms of this Agreement or
otherwise under law or equity.
3. AnDK~K~ 'rO DB IIICORPO~ I. DrvnIH"R "IU"IIRR
The parties agree that the terms of this Agreement shall be
incorporated into any divorce decree which may be entered with
respect to them. The parties further agree that the Court of
Common Pleas which may enter such divorce decree shall retllin
continuing jurisdiction over the parties and the subject matter of
this Agreement for the purpose of enforcement of any of the
provisions thereof.
4. DWrB OF BXBCU'rIOII
The "date of execution" or "execution date" of this Agreement
shall be defined as the date upon which it is executed by the
parties if they have each executed the Agreement on the same date.
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. .
Otherwise, the "date of execution" or "execution date" of this
Agreement shall be defined as the date of execution by the party
last executing this Agreement.
s. DI8'rRIBUTIOII DAB
The transfer of property, funds and/or documents provided for
herein shall only take place on the "distribution date" which shall
be defined as the date of execution of this Agreement unless
otherwise specified herein. However, the support payments, if any,
provided for in this Agreement shall take effect as set forth in
this Agreement.
6. FIIDUlCIAL DISCLOSURE
The parties confirm that each has relied on the substantial
accuracy of the financial disclosure of the other.
7 . ADVl:CB OF C<lUIISBL
Wife and Husband declare that each has had a full and fair
opportunity to obtain independent legal advice of counsel of her or
his selection and that Husband and Wife have each been represented
by counsel during the negotiation process which preceded the
drafting of this Agreement. Husband has been represented by George
W. Porter, Esquire. Wife has been represented by Lori K.
Serratelli, Esquire.
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....,...:14......
8. PBIISOIIAL RI~S
Wife and Husband may and shall, a~ all ~imes hereaf~er, live
separa~e and apar~. They shall be free from any control,
restraint, interference or au~hori~y, direc~ or indirec~, by the
other in all respec~s as fully as if ~hey were unmarried. They may
reside a~ such place or places as ~hey may selec~. Each may, for
his or her separate use or benefit, conduc~, carryon and engage in
any business, occupa~ion, profession or employmen~ which ~o him or
her may seem advisable. wife and Husband shall no~ molest, harass,
disturb or malign each o~her or ~he respective families of each
o~her nor compel or attemp~ ~o compel ~he o~her to cohabit or dwell
by any means or in any manner whatsoever with him or her.
!J . MIft'UAL DRT .ll'JUmS
(a) Husband and Wife each do hereby mu~ually remise, release,
quitclaim and forever discharge the o~her and the estate of such
o~her, for all time ~o come, and for all purposes wha~soever, of
and from any and all righ~s, title and in~erests, or claima in or
agains~ ~he proper~y (including income and gain from property
hereafter accruing) of ~he other or against the estate of other, of
whatever na~ure and wheresoever si~ua~e, which he or she now has or
at any time hereafter may have against such other, the estate of
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"
",
such other or any part thereof, whether arising out of any former
acts, contracts, engagements or liabilities of such other or by way
of dower or curtesy, or claims in the nature of dower or curtesy or
widow's or widower's rights, family exemption or similar allowance,
or under the interstate laws, or the right to take against the
spouse's will; or the right to treat a lifetime conveyance by the
other as testamentary, or all other rights of a surviving spouse to
participate in a deceased spouse's estate, whether arising under
the laws of (a) Pennsylvania, (b) any State, Commonwealth or
territory of the United States, or (C) any other country, or any
rights which either party may have or at any time hereafter have
for past, present or future support or maintenance, alimony,
alimony pendente lite, counsel fees, equitable distribution, costs
or expenses, whether arising as a result of the marital relations
or otherwise, except, and only except all rights and agreements and
obligations of whatsoever nature arising or which may arise under
this Agreement or for the breach of any provision thereof. It is
the intention of Husband and Wife to give to each other by the
execution of this Agreement a full, complete and general release
with respect to any and all property of any kind of nature, real,
personal or mixed, which the other now owns or may thereafter
acquire, except and only except all rights and agreements and
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obligations of whatsoever nature arising or which may arise under
~his Agreement or for the breach of any provision ~hereof.
(b) It is further specifically understood and agreed by and
between the parties hereto ~ha~ each accepts ~he provisions herein
made by ~he other in lieu of and in full se~~lemen~ and
satisfaction of any and all of their rights against the other or
any past, presen~ and future claims on accoun~ of suppor~ and
maintenance; ~hat i~ is specifically unders~ood and agreed ~ha~ the
payments, ~ransfers and other considerations herein recited so
comprehend and discharge any and all such claims by each agains~
the other, and are, inter alia, in full settlement and satisfac~ion
and in lieu of ~heir past, present and fu~ure claims against the
other on accoun~ of main~enance and suppor~, and also alimony,
alimony pendente lite, counsel fees, costs and expenses as well as
any and all claims to equitable dis~ribution of property both real
and personal and any other charge of any nature whatsoever
pertaining to any divorce proceedings which have been or may be
institu~ed in any cour~ in the Commonwealth of pennsylvania or any
o~her jurisdiction including any o~her counsel fees, costs and
expenses incurred or to be charged by any counselor arising in any
manner wha~soever.
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10. IIIn"'JUIB OF ~~__.DY I"T.JUMS
Except as provided for in this Agreement, each of the parties
hereto shall have the right to dispose of his or her property by
law will and testament or otherwise, and each of them agrees that
the estate of the other, whether real, personal or mixed, shall be
and belong to the person or persons who would have become entitled
thereto as if the decedent had been the last to die. This
provision is intended to constitute a mutual waiver by the parties
of any rights to take against each other's last wills under the
present of future laws of any jurisdiction whatsoever, and is
intended to confer third-party beneficiary rights upon the other
heirs and beneficiaries of each. Either party may, however, make
such provisions for the other as he or she may desire in and by his
or her last will and testament; and each of the parties further
covenants and agrees that he or she will permit any will of the
other to be probated and allowed administration upon his or her
personal, real or mixed estate and effects to be taken out by the
person or persons who would have been entitled to do so had Husband
and Wife died during the lifetime of the other; and that neither
Husband nor Wife will claim against or contest the will and the
estate of the other. Each of the parties hereby releases,
relinquishes and waives any and all rights to act as executor or
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executrix or administrator or administratrix of the other party's
estate. Each of the parties hereto further covenants and agrees
for himself and herself and his or her heirs, executors,
administrators or assigns, for the purpose of enforcing any of the
rights relinquished under this paragraph.
11. PBRSOIIAL PROP~
Husband and Wife do hereby acknowledge that the personal
property of the parties has been divided amicably.
12. MOl'OR VBBIl!I..a
With respect to the motor vehicles owned by one or both of the
parties, they agree as follows: The motor vehicles have been
divided amicably.
13. AnBR-ACOUl:RBD PBRSOIIAL PROPBRR
Each of the parties shall hereafter own and enjoy,
independently of any claim or right of the other, all items of
personal property, tangible or intangible, hereafter acquired by
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him or her, with full power in him or her to dispose of the same as
fully and effectively, in all respects and for all purposes, as
though he or she were unmarried.
1f.. fiUUh'l'"15K OF REAL BS'I'AD
The parties acknowledge that neither party holds any interest
in any marital real estate.
15. PDSIOIIS
Wife waives any claim that she may have in any pension plan,
40lK plan, employer-based savings plan or other employee related
benefit plan that Husband may enjoy.
Husband waives any claim he may have in any pension plan, 401K
plan, employer-based savings plan or other employee related benefit
plan that Wife may enjoy.
16. DBlWS
All debts, contracts, obligations or liabilities incurred at
any time in the past or future by either of the parties will be
paid promptly by said party, unless and except as otherwise
specifically set forth in this Agreement; and each of the parties
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hereto further promises, covenants and agrees ~hat each will now
and a~ all ~imes hereaf~er save harmless and keep ~he o~her or his
or her esta~e indemnified and saved harmless from all deb~s or
liabilities incurred by him or her, as ~he case may be, and from
all ac~ions, claims and demands wha~soever wi~h respect ~hereto,
and from all costs, legal or otherwise, and counsel fees wha~soever
appertaining ~o such ac~ions, claims and demands. Nei~her par~y
shall, af~er the da~e of ~his Agreement, con~ract or incur any deb~
or liability for which the other or his or her property migh~ be
responsible, and shall indemnify and save harmless the other from
any and all claims or demands made against her or him by reason of
debts or obligations incurred by her or him and from all costs,
legal costs and counsel fees unless provided ~o the contrary
herein.
11. paYIIRII'P OF SPECIFIED OBLIGM.'IOIIS
Husband and Wife agree tha~ all responsibility for joint
obliga~ions has been amicably divided.
18. COUIISBL FBBS AIID COS'rS
Wife agrees ~o be solely responsible for any attorney fees
owed to Lori K. Serratelli, Esquire, or any other attorney's fees
owed to any attorney she may have retained.
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20. CHILD SUPPORT AND ALIMONY
The parties acknowledge there is currently an Order of Court
executed by the Honorable J. Wesley Oler, Jr., dated April 18, 1997
which covers the issues of spousal support and child support. The
parties agree this Order, upon the entry of a divorce decree in
this case, shall be modified as follows: The spousal support shall
terminate. Husband shall pay to Wife the sum of Two Hundred
Twenty-Six and sixty-Two Hundredths Dollars ($226.62) bi-weekly for
thirteen (13) pay periods commencing with the December 6, 1997
pay period for six and one-half (6 1/2) months from the date of
execution of this Agreement as alimony. Additionally, following
the end of the six and one-half (6 1/2) months, Husband shall pay
to Wife the sum of Sixty-Nine and Twenty-Three Hundredths
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Husband agrees to be responsible for all attorney fees owing
to George W. Porter, Esquire. Both parties agree to be responsible
for their own costs.
19. COUNSEL FEES AND EXPENSES FOR ENFORCEMENT OF THIS AGREEMENT
If either party breaches any provision of this Agreement, the
other party shall have the right, at his or her election to sue for
damages for such breach, or seek such other remedies or relief as
may be available to him or her, and the party breaching this
contract shall be responsible for payment of legal fees and costs
incurred by the other in enforcing his or her rights under this
Agreement.
Dollars ($69.23) bi-weekly for sixty-five (65) pay periods, or
thirty (30) months. Husband shall be responsible for maintaining
medical insurance for Wife u..til october 1, 2007, pursuant to a
Qualified Medical Support Order for which husband shall execute a
stipulation simultaneously with the execution of this Agreement, as
well as any modification to the stipulation which Aetna may
require. Husband shall not be responsible for any unreimbursed
medical expenses of Wife. The alimony portions of this Agreement
shall not be modifiable and shall not be extended. The Court Order
dated April 18, 1997, shall remain modifiable in all other
respects.
Wife agrees to pay Husband within 28 days from execution of
this Agreement the amount of the premium for the family health care
coverage which is deducted from his paycheck each biweekly pay
period for a period of ten years from execution of this Agreement,
or until the parties mutually agree to modify this provision. In
the event Wife fails to pay Husband the amount of the said premium
later than 10 days after it is deducted from his pay check, then
the parties agree that Husband may delete Wife from his medical
coverage.
21. PAYMENT FROM HUSBAND TO WIFE
Husband shall pay to Wife Five Thousand Five Hundred Dollars
($5,500.00) upon Wife's execution of this Agreement and an
Affidavit of Consent to divorce. Husband shall pay to Wife's
attorney, Lori K. Serratelli, Esquire, an additional sum of Two
Thousand Five Hundred Dollars ($2,500.00) on or before October 31,
1998. In consideration thereof, Wife waives all other marital
claims against Husband.
-13-
.
22. O:H~:ZIIIG ACC<lUII'r/CBRl'IPI~ OP DBPOSI'l'
All checking accounts, bank accounts and Certificates of
Deposits, if any, have been amicably divided by the parties.
23. IIICClIIB TAl[ COIIS&OuI5ll'l"RA
By this agreement, the parties have intended to effectuate and
by this agreement have equally divided their marital property. The
parties have determined that such equal division conforms to a
right and just standard with regard to the rights of each party.
The division of existing marital property has not, except as may be
otherwise expressly provided herein, been intended by the parties
to constitute in any way a sale or exchange of assets and the
division is being effected without the introduction of outside
funds or other property not constituting a part of the marital
estate. As a part of the equal division of the marital properties
and the marital settlement herein contained, the parties hereby
agree to save and hold each other harmless from all income taxes
assessed against the other resulting from the division of the
property as herein provided.
Husband and Wife do hereby specifically agree and elect to
apply the provisions of the 1984 Domestic Relations Tax Reform Act
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'<.Mr....".....
with respect to the creation of a taxable event. Husband and Wife
specifically agree that none of the provisions of the within
agreement shall constitute a taxable event as set forth in the 1984
Domestic Relations Tax Reform Act.
26. 1IJUlRAftY AS 'rO DIMIllO nAT.T~IOIIS
Each party represents that they have not heretofore incurred
or contracted for any debt or liability or obligation for which the
estate of the other party may be responsible or liable except as
may be provided for in this Agreement. Each party agrees to
indemnify or hold the other party harmless from and against any and
all such debts, liabilities or obligations of every kind which may
have heretofore been incurred by them, including those for
necessities, except for the obligations arising out of this
Agreement.
25. 1IJUlRAftY AS 'rO FmURB OBLI~IOIIS
Wife and Husband each covenant, warranty, represent and agree
that each will now and at all times hereafter save harmless and
keep the other indemnified from all debts, charges and liabilities
incurred by the other after the execution date of this Agreement,
except as may be otherwise specifically provided for by the terms
of this Agreement and that neither of them shall hereafter incur
-15-
any liability whatsoever for which the estate of the other may be
liable.
26. U".I:'''KIII DOCI~Nr:lOll
Wife and Husband covenant and agree that they will forthwith
(and within at least thirty (30) days after demand thereof) execute
any and all written instruments, assignments, releases,
satisfactions, deeds, notes or such other writings as may be
necessary or desirable for the proper effectuation of this
Agreement, and as their respective counsel shall mutually agree
should be so executed in order to carry out fully and effectively
the terms of this Agreement.
27. 110 lfJUVBR OR DBP~
This Agreement shall remain in full force and effect unless
and until terminated under and pursuant to the terms of this
Agreement. The failure of either party to insist upon strict
performance of any of the provisions of this Agreement shall in no
way affect the right of such party hereafter to enforce the same,
nor shall the waiver of any breach of any provision hereof be
construed as a waiver of any subsequent default of the same or
similar nature, nor shall it be construed as a waiver of strict
-16-
,
performance of any other obligations herein.
28. IU5vlUCABILXft
If any term, condition, clause or provision of this Agreement
shall be determined or declared to be void or invalid in law of
otherwise, then only that term, condition, clause or provision
shall be stricken from this Agreement and in all other respects
this Agreement shall be valid and continue in full force, effect
and operation. Likewise, the failure of any party to meet her or
his obligations under anyone or more of the paragraphs herein,
with the exception of the satisfaction of the conditions precedent,
shall in no way void or alter the remaining obligations of the
parties.
29. lOUVER OR IIODXPlt:A!rXOII m DB I. lfRI'!fIIIG
No modification or waiver of any of the terms hereof shall be
valid unless in writing and signed by both parties and no waiver of
any breach hereof or default hereunder shall be deemed a waiver of
any subsequent default of the same or similar nature.
30. IIOftJAL COOPBRJl2'IOII
Each party shall, at any time and from time to time hereafter,
take any and all steps and execute, acknowledge and deliver to the
other party any and all further instruments and/or documents that
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the o~her party may reasonably require for the purpose of giving
full force and effect ~o the provisions of ~his Agreemen~.
31. LIUf OF P~AYT.vun:A APPLICJlRl'.R
This Agreement shall be construed in accordance with the laws
of the Commonwealth of Pennsylvania.
32. alUllrRMRWP BIIIDIIIG 011 DIU
This Agreemen~ shall be binding and shall inure ~o the benefit
of ~he par~ies here~o and ~heir respective heirs, executors,
adminis~rators, successors and assigns.
33. I~IOII
This Agreement cons~itutes ~he entire unders~anding of the
par~ies and supersedes any and all prior agreements and
nego~iations be~ween them. There are no representations or
warranties o~her than ~hose expressly set for~h herein.
34. IlBADIIIGS IIOr PARr OF ~I<..-.r
Any headings preceding the ~ex~ of the several paragraphs and
subparagraphs hereof are inserted solely for convenience of
reference and shall not constitu~e a part of ~his Agreement nor
shall ~hey affect i~s meaning, construction or effect.
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.
.
IN WITNESS WHEREOP, the parties hereto have set their hands
and seals to this property Settlement Agreement the day and year
first above written.
~,,~,.~.
Wit~s ..
)J l.; (Jt~
Witness 7
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blRI K.SIRRAIUU
SlEVEN J. Snlll n.IAN
MICIIAEII'.IIRO\X'N
RONAU) L CAIIlOON
GAR\' L. ROllI~CIllLIl
ROIII'.RT D, HAMII.TO"
VIR,;INIA M. DI^,
GARTII A. Slf.l'ltENS{lN
01' COUNSEL
IMIl&: DC Ih.~ (hu)
SUIH. 20 I
20HU I.ISl;1 t~'lln""'N llo..\1l
HAII.R""V5U;,I'A
1711O.')44S
(717) 540.9170
"'X 1717) 540.5181
""\..';\- I
January 2, 1997
E. Robert Elicker, II
Office of Divorce Master
9 North Hanover street
CarliSle, PA 17013
Re: Salomon v. Salomon
No. 94-2884 Civil
Dear Mr. Elicker:
Pursuant to a call from the prothonotary's Office,
we were advised that the Alimony Pendente Lite claim
contained in our Petition mailed to them with a copy to
you on December 13, 1996, must be heard before the
Domestic Relations Office.
since the Law Clinic is currently handling the
support issue on behalf of Mrs. Salomon, we asked the
Prothonotary to return the Petition to us for revisions.
Janie advised that it had not been docketed in their
office. In that regard, I have revised the Petition to
exclude the claim for Alimony Pendente Lite and am
enclosing a copy for your information.
Thank you for your attention.
sincerely,
SERRATELLI, SCHIFFMAN,
BROWN ~~HOON, P.C.
4~~-
LO~ ~rratelli
LKS/dae
Enclosure
cc: Tammy Salomon
George W. Porter, Esq.
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THOMAS SALOMON,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 94-2884 CIVIL
TAMMY SALOMON,
Defendant
IN DIVORCE
ORDER FOR ENTRY OF A OUALIFIED MEDICAL SUPPORT ORDER
AND NOW, this z.o 1t, day of --J ,n 1-' > ~I ' 19.1L IT 'IS
ORDERED THAT Tammy M. salomon, former spouse of participant,
hereinafter individually termed "alternate recipient", has a right
to receive benefits which a party hereto is eligible for or a
beneficiary of under a group health plan, hereinafter terms
"participant", in accordance with the following information:
1.
a.
The name, social security number, date of birth,
and last known mailing address of the participant
is:
Name:
Thomas M. Salomon
Social Security No: 117-54-8625
Date of Birth: May 31, 1959
Last known mailing address:
P.O. Box 691
Dillsburg, PA 17019
b. The name, social security number, date of birth and
address of the alternate recipient (former spouse)
covered by this Order is:
Name:
Tammy M. Salomon
Social Security No:
093-60-9685
r.;:
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Date of Birth:
May 27, 1962
Last known mailing address:
618 Colonial View Road
Mechanicsburg, PA 17055
c.
The
and
address
the
designated
of
name
representative for receipt of copies of notices
with respect to this Order is:
Name/Address:
Lori K. Serratelli, Esquire
serrate11i, schiffman, Brown & Calhoon, P.C.
2080 Linglestown Road
suite 201
Harrisburg, PA 17110
2. a. A description of the type of coverage to be
provided by the plan to each alternate recipient
is: that coverage currently available to the
participant or that which may subsequently be
available to the participant.
b. The manner in which such type of coverage is to be
determined:
by that coverage to which the
participant is now eligible or may in the future
become eligible.
If the current coverage becomes
unavailable, the medical benefits provided shall be
the family medical coverage most similar to that
currently provided, considering the extent of
coverage, the deductible and any coinsurance
amount.
c. This order does not require the provision of any
type or form of benefit not otherwise provided
under the plan.
#
3. The period to which this Order applies is, as to the
former spouse, until ten (10) years from the date of the divorce
decree.
4. This Order applies to each of the following plans: (check
coverage that applies)
IT IS FURTHER ORDERED THAT any payments for benefits by a plan
pursuant to this Order in reimbursement for expenses paid by former
spouse, (alternate recipient/beneficiary) shall be made payable to
the order of Tammy M. Salomon and mailed directly to her at her
last known mailing address set forth above; and
IT IS FURTHER ORDERED THAT the participant shall pay any
premium
cost
medical
of
for
the
alternate
coverage
recipient/beneficiary and the cost shall be withheld from the
participant's gross income.
BY THE COURT:
.-..",. ~....,...~,.
.
. .
va.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-2884 CIVIL
THOMAS SALOMON,
Plaintiff
TAMMY SALOMON,
Defendant
IN DIVORCE
STIPULATION FOR ENTRY OF A QUALIFIED MEDICAL SUPPORT ORDER
AND NOW, this
day of December, 1997, pursuant to 529
U.S.C. 1169, the parties stipulate and agree as follows:
1. Plaintiff, Thomas M. Salomon, is a participant in Aetna
U.S. Healthcare through his employment with the United States
Postal Service and currently covers Plaintiff, Tammy M. Salomon,
and their two (2) children.
2. Pursuant to a Property Settlement Agreement, Plaintiff
agrees to continue to cover Defendant, Tammy M. Salomon, on his
health coverage provided through his employment following the entry
of a final decree in divorce.
3. Tammy M. Salomon shall be designated alternate
recipient/beneficiary.
4.
a.
The name, social security number, date of birth,
and last known mailing address of the participant
is:
Name:
Thomas M. Salomon
Social Security No: 117-54-8625
Date of Birth: May 31, 1959
Last known mailing address:
P.O. Box 691
Dillsburg, PA 17019
,
b. The name, social security number, date of birth and
address of the alternate recipient (former spouse)
covered by this Order is:
Name:
Tammy M. Salomon
Social Security No: 093-60-9685
Date of Birth: May 27, 1962
Last known mailing address:
618 Colonial View Road
Mechanicsburg, PA 17055
c.
The
and
address
the
designated
of
name
representative for receipt of copies of notices
with respect to this Order is:
Name/Address:
Lori K. Serratelli, Esquire
Serratelli, Schiffman, Brown & CalhooA, P.C.
2080 Linglestown Road
suite 201
Harrisburg, PA 17110
5.
A description of the type of coverage to be
provided by the plan to each alternate recipient
a.
is: that coverage currently available to the
participant or that which may subsequently be
available to the participant.
b. The manner in which such type of coverage is to be
determined:
by that coverage to which the
participant is now eligible or may in the future
become eligible.
If the current coverage becomes
unavailable, the medical benefits provided shall be
THOMAS SALOMON,
Plaintiff fN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - r.AW
vs. NO. 94-2884 CIVIL 19
TAMMY SALOMON,
Defendant . IN DIVORCE
.
DATE:
" .
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STATUS SHEET
ACTIVITIES:
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,,11..91
5/29/97 P ehearing onference. Hearing on date of separation
9/25/97 at 9:00 a.m. Hearing on other economic issues --
9/8197
10//0/91
(-z-.(-c.'Il'f "'(
10116/97 at 9:00 a.m.
Hearing scheduled for 9/25197 has been continued
and will be heard on the October 16th date. Hearing
on the economic issues will be scheduled at the 16th
hearing.
..
......
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 Masler
Tracl "0 Colyer
Office ManegarlReporler
West Shore
697-0371 Ext. 6535
October 28, 1996
George W. porter, Esquire
P.O. Box 338
909 East Chocolate Avenue
Hershey, Pa 17033
Robert E. Rains, Esquire
THE FAMILY LAW CLINIC
45 North Pitt street
Carlisle, PA 17013
RE: Thomas Salomon vs. Tammy Salomon
No. 94 - 2884 civil
In Divorce
Dear Mr. Porter and Mr. Rains:
By order of Court of President Judge Harold E. Sheely
dated October 31 [October 21], 1996, the full-time Master has
been appointed in the above referenced divorce proceedings.
A divorce complaint was filed on May 31, 1994, raising
grounds for divorce of irretrievable breakdown of the marriage.
On May 3, 1995, the Defendant filed a petition for
equitable distribution. No other economic claims have been
raised in the action.
In accordance with P.R.C.P. 1920.33(b) I am directing
each counsel to file a pre-trial statement on or before Monday,
November 25, 1996. Upon receipt of the pre-trial statements I
will immediately schedule a pre-hearing conference with counsel
to discuss the issues and, if necessary, schedule a hearing.
Very truly yours,
E. Robert Elicker, II
Divorce Master
....
~
Mr. Porter and Mr. Rains, Attorneys at Law
28 October 1996
Page 2
NOTE: Sanctions for failure to file the pre-trial statements
are set forth in subdivision (c) and (d) of Rule 1920.33.
THE ORIGINAL PRE-TRIAL STATEMENT SHOULD BE FILED IN THE
MASTER'S OFFICE AND A COPY SENT DIRECTLY TO OPPOSING
COUNSEL.
'>
"
Mr. Porter and Ms. Serratelli, Attorneys at Law
22 November 1996
Page 2
NOTE: Sanctions for failure to file pre-trial statements are
set forth in subdivision (c) and (d) of Rule 1920.33.
THE ORIGINAL PRE-TRIAL STATEMENT SHOULD BE FILED IN THE
MASTER'S OFFICE AND A COPY SENT DIRECTLY TO OPPOSING
COUNSEL.
P.S. The Family Law Clinic should file a praecipe withdrawing
their appearance and Ms. Serratelli should file a
praecipe entering her appearance.
cc: Robert E. Rains, Esquire
,-
~
THOMAS SALOMON, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
.
.
VS. . CIVIL ACTION - LAW
.
.
.
: NO. 94 - 2884 CIVIL
TAMMY SALOMON, .
.
Defendant : IN DIVORCE
NOTICE OF PRE-HEARING CONFERENCE
TO: George W. Porter
Lori K. Serratelli
, 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 10th day of March, 1997, at 9:30 a.m., at
which time we will review the pre-trial statements previously
filed by counsel, define issues, identify witnesses, explore the
possibility of settlement and, if necessary, schedule a hearing.
Very truly yours,
Date of Notice: 12/19/96
E. Robert Elicker, II
Divorce Master
LnlU t\. SUUL\ I U II
SI1\l,N J. SnIlHMM-i
MICIIM.L 1'. II~O".N
RONAI () I.. ('.AIIIOON
(iARY L R(lTll\Cftll.ll
Rl,",,~r D. HAMil ION
V'~"INIA M. \),^,
GARTII A. STfI'IIEN\llN
Or COUNSEL
tMll& IX; O'k\(l"ll)
SL.:III.1nl
20HlJ liSt ;11.\1 O'i,'N RIHI)
Ho\kRI\IU:Rl.. I)"
17110.t)44';
(717) 540-9170
h\ (717) ..40.'\.181
"'L.,',:"
March 12, 1997
E. Robert Elicker, Master
Office of the Divorce Master
9 North Hanover street
Carlisle, PA 17013
RE: SALOMON vs. SALOMON
NO. 94-2884 CIVIL (IN DIVORCE)
OUR FILE NO. 96-368
Dear Mr. Elicker:
I am writing with regard to the Pre-Trial
Conference scheduled, in the above-referenced matter,
for April 14, 1997 at 9:30 a.m.
I received notice, on another matter, that
opposing counsel requested a continuance of a
scheduled hearing. Judge Kleinfelter rescheduled the
hearing for April 14, 1997 at 9:00 a.m. I notified
Judge Kleinfelter that I had a scheduling conflict
concerning a matter that had been rescheduled once
already and requested that he reschedule the hearing
to another date. Unfortunately, I received the
enclosed response from Judge Kleinfelter.
Therefore, I must request that the Salomon Pre-
Hearing Conference be rescheduled once again. I would
appreciate any assistance you could provide in
rescheduling this matter for the first date you have
available.
If you have any questions, please feel free to
call. Thank you for your attention.
Sincerely,
SERRATELLI, SCHIFFMAN,
BROWN & CALHOON, P.C.
~.~~.
LorylK. Serratelli
LKS/ted
cc: George W. Porter, Esquire
Tammy Salomon
Joseph H. Kleinfelter
Jud.e
Court Ilouse
Harrisburg. PA 17101
COURT OF COMMON PLEAS
TwelRb ludlclal District
Dauphin County, Pennsylvania
March 10, 1997
Lori K, Serratelli, Esquire
2080 Linglestown Road. Suite 201
Harrisburg, PA 17110-0445
In re: Christine McCartnev v. Michael McCartnev, 638 S 94
Dear Ms. Serratelli:
Responding to your letter of February 28'h. I am not willing to continue
argument in deference to a pre-trial conference with a divorce master. Our general
rule of protocol for continuances is that the lower court gives way to a higher court
regardless of which schedules first. Only where courts on the same level have a
conflict does the priority of scheduling prevail.
I realize that rescheduling due to conflicts is an inconvenience for all
parties; however, in this instance I am afraid you'll have to ask Master Elicker to
reschedule.
We would also, of course, accept your position on your brief or
entertain surrogate counsel on your behalf.
JHK/dab
\.,
leinfelter, Judge
cc: 8ryan Walk, Esquire
THOMAS SALOMON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - LAW
.
.
.
.
NO.
94 - 2884 CIVIL
TAMMY SALOMON,
Defendant
.
.
IN DIVORCE
RESCHEDULED PRE-HEARING CONFERENCE
TO: George W. Porter
Lori K. Serratelli
, 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 29th day of May, 1997, at 9:00 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: 3/19/97
E. Robert Elicker, II
Divorce Master
THOMAS SALOMON.
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 94-2884 CIVIL 19
TAMMY SALOMON,
Defendant
IN DIVORCE
ORDER AND NOTICE SETTING HEARING
To: Thomas Salomon
George W. Porter
Tammy Salomon
Lori K. Serratelli
. 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 September , 1!9.2.... at 9:00 a .m. at which place and
time you will be given the opportunity to present witnesses and
exhibits in support of your case.
By the Court.
~~\~
Harold E. Sheely.
.Judge
Date of Order and
Notice: 5/29/97
By:
Divorce Master
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
*
Court Administrator
Fourth Floor. East Wing
Cumberland County Courthouse
Carlisle. PA 17013
Telephone (717) 240-6200
Testimony will be limited to the issue of the date of separation
of the parties.
THOMAS SALOMON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs. CIVIL ACTION - LAW
:
: NO. 94-2884 CIVIL 19
TAMMY SALOMON,
Defendant IN DIVORCE
ORDER AND NOTICE SETTING HEARING
To: Thomas Salomon
George W. Porter
Tammy Salomon
Lori K. Serratelli
, 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 16th
day of October ,1~, at 9:00 a.m, at which place and
time you will be given the opportunity to present witnesses and
exhibits in support of your case.
By the Court,
~~\~
Harold E. Sheely,
,Judge
Date of Order and
Notice: 5/29/97
By:
Divorce Master
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Court Administrator
Fourth Floor, East Wing
Cumberland County Courthouse
Carlisle. PA 17013
Telephone (717) 240-6200
LORI K. SERIlATUII
SnVEN J. SCHiffMAN
MICIIAU. F. BRUWN
RONAI.llI.. CAuIOON
GARY L. RUTlISCIIIW
RORf.RT D. HAMilTON
VIRt;INIA M. DIA.'
GARTlI A. STfrllENSON
Of CoUNSEL
(MO & DC Ru.\Osul
SUITF. 201
2080 lISt;U;5TU\I.'N ROM)
HJ\RRI!lHUR(;. PA
17110.9670
(717) 540.9170
fAx (717) ~4o.~481
~.11
,.~_....~ I'
September 2, 1997
Robert E. Elicker, Master
9 North Hanover Street
Carlisle, PA 17013
RE: SALOMON vs. SALOMON
NO. 94-2884 CIVIL TERM
OUR FILE NO. 96-368
Dear Mr. Elicker:
As you recall, I represent Tammy Salomon in the
upcoming hearing scheduled for September 25, 1997 on
the issue of the separation date of the parties. In
the meantime, my client is in need of major surgery
for a pre-cancerous gynecological condition. She is
scheduled for surgery September 25, 1997 and is told
her recovery period will be four to eight weeks.
Therefore, I am proposing that the hearing date on the
separation date be held on the second date you had set
in this matter, October 16, 1997, and that another
date be scheduled in the future for the hearing on the
property and alimony issues.
I am sending a copy of my request to George
Porter and ask that he advise your office as to his
concurrence or non-concurrence. In the event Mr.
Porter would not concur, we would ask that you please
consider our request to cancel the September 25
hearing in light of my client's need for major
surgery.
Thank you for your attention.
Sincerely,
SERRATELLI, SCHIFFMAN,
BROWN & ALHOON, P.C.
~.
LKS/ted
cc: Tammy Salomon
George W. Porter, Esquire
THOMAS SALOMON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: CIVIL ACTION - LAW
NO. 94-2884
CIVIL
19
TAMMY SALOMON, .
Defendant
IN DIVORCE
ORDER AND NOTICE SETTING HEARING
To:
Thomas Salomon
George W. Porter
Tammy Salomon
Lori K. Serratelli
, 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 16th day
of October , 1997, at 9:00 a.m., at which place
and time you will be given toe opportunity to present witnesses
ann exhibits in support of your case.
By the Court.
~~(~
Harold E. Sheely,
.Judge
Date of Order and
Notice: 9/8/97
By:
Divorce Master
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Court Administrator
Fourth Floor, East Wing
Cumberland County Courthouse
Carlisle, PA 17013
Telephone (717) 240-6200
* Testimony will be limited to
the issue of the date of separation of the parties.
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THOMAS SALOMON, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs. . 94 - 2884 CIVIL
.
.
.
TAMMY SALOMON,
Defendant : IN DIVORCE
RE: Pre-Hearing Conference Memorandum
DATE: Thursday, May 29, 1997
Present for the Plaintiff, Thomas Salomon is
attorney George W. Porter, and present for the Defendant, Tammy
Salomon, is attorney Lori K. Serratelli.
A divorce complaint was filed on May 31, 1994,
raising grounds for divorce of irretrievable breakdown of the
marriage. No economic claims were raised in the complaint. On
May 3, 1995, wife filed a petition for equitable distribution.
Subsequently, on January 6, 1997, wife filed another petition
raising the additional claims of alimony and counsel fees and
costs. Counsel have advised that the parties will sign and file
affidavits of consent so that the divorce can be concluded under
Section 3301(c) of the Domestic Relations Code. Counsel further
advised that there will be no testimony regarding the factor of
marital misconduct as that factor affects wife's alimony claim.
There is a disagreement with respect to the date of
separation. Husband claims the parties separated October l5,
1990, and wife claims the parties separated September 17, 1993.
The September 1993 date was the time when the parties physically
separated and Mr. Porter agrees that that is correct; however,
Mr. Porter does not agree that the actual separation occurred in
September 1993 but, in fact, claims the parties ceased the
marital relationship in October 1990. We are going to schedule
a separate hearing on that issue to establish the date of the
separation which is important in determining the value of the
pension of husband.
The parties were married on December 6, 1985.
are the natural parents of two children, Thomas, Jr., age 6
Holly, age 8. Both children are in the custody of wife.
Husband is 37 years of age and resides at 119
Harrisburg Street, Apartment 4, Dillsburg, Pennsylvania, where
he lives alone. He is a high school graduate and works as a
They
and
K
sorter with the United states Postal Service. His net monthly
income has been established by the Court through support
proceedings at $2,502.00 per month. He has not raised any
health issues.
Wife is 35 years of age and resides at 618 Colonial
View Road, Mechanicsburg, Pennsylvania, where she lives with the
two children. Wife recently obtained her GED and is currently
in a schooling program for legal secreterial studies. An
earning capacity was attributed to wife in the support
proceedings of $325.00 per month. It is anticipated, however,
that upon completion of her schooling she will be placed in a
program which will allow her to earn more than the assigned
earning capacity. The program will probably be completed in
late October of 1997. Wife has not raised any health issues.
Based on an order entered by Judge Oler dated April
18, 1997, husband is paying child support to wife for the
children in the amount of $629.00 monthly and spousal support in
the amount of $491.00 monthly. Wife is currently covered under
husband's medical insurance benefits; however, upon the entry of
a divorce decree those benefits will cease but wife will be
entitled to COBRA benefits. The Master requests that counsel
provide to him the cost of those benefits to wife.
Pension Analysis Consultants, Inc. has done a
computation regarding the value of husband's pension. The
analysis was done in June 1996. Based on husband's date of
separation the value is $8,962.00; based on wife's date of
separation the value is $14,337.00.
Wife has also raised a question about whether or
not husband is a participant in a thrift savings plan. Mr.
Porter indicated he does not have any information about such a
plan but will make an inquiry to his client.
The vehicles involved in this case are marital and
were both traded by the parties. The 1986 Subaru was traded for
$300.00 and the 1987 Hyundai was traded for $1,700.00.
The parties have placed values on the household
tangible personal property in their own possession and in the
other party's possession. There is a large disparity in values
and counsel are going to attempt to try to resolve the issue
without having to have appraisals accomplished. Wife claims
that husband took property with a value of $2,500.00; husband
claims the property he took has a value of $1,300.00. Wife
claims the property left with her has a value of $20.00 whereas
husband claims the property in her possession has a value of
l--._
$5,000.00. (The value that husband has attributed to property
in wife's possession includes the $1,700.00 value for the
Hyundai).
There is no marital debt. Wife does have a debt
for a car she purchased after separation. As of November 19,
1996, the amount of that debt to the Postmark credit union was
$5,825.23.
A hearing is scheduled to take testimony on the
issue of the date of separation for Thursday, september 25,
1997, at 9:00 a.m. After that hearing we will come back on
Thursday, october 16, 1997, at 9:00 a.m. to take any additional
testimony on the economic issues involving the factors in the
Divorce Code and valuation and identification of assets.
Notices will be sent to counsel and the parties.
E. Robert Elicker, II
Divorce Master
cc: George W. Porter
Attorney for Plaintiff
Lori K. Serratelli
Attorney for Defendant
...
GOLDBECK McCAFFERTY & McKEEVER
By: JOSEPH A, GOI.D1U:CK, JR.
An-ORNEY I.D, #16132
SUITE 500 - Tm: BOURSE BLOG,
III S. INOt:I'ENOt:NCE 1\I,\LI. EAST
PIIILAOEI.PIII,\, PA 19106
(215) 627-1322
An-ORNEY FOR 1'1.,\1101'1'1....
FIRST NATIONWIDE MORTGAGE CORP. F/KlA
LOMAS MORTGAGE PARTNERSHIP L1'
PO Box 9481
Mail Code: 22-528-10 II
Gaithersburg, MD 20898-9481
IN THE COURT OF COMMON
PLEAS
OF Cumberland COUNTY
CIVIL ACTION - LAW
VS.
HARRY D. G1PE and EVELYN R. GIPE
Mortgagor(s)
400 Mountain Road
Newville, PA 17241
ACTION OF MORTGAGE
FORECLOSURE
Tenn
No. 01-4532 Civil Tenn
Defem/alll(S)
CERTIFICATE OF SERVICE
JOSEPH A. GOLDBECK, JR. ESQUIRE hereby certifics that on I/.}i/ Q}
he did serve upon Defendant(s) HARRY D. GIPE a true and correct copy of the above-captioned
Complaint by certified and regular mail in accordance with the Court Order dated DECEMBER 27, 200 I.
. The undersigned understands that the statements hcrein and subject to the pcnaltics provided by 18 P.S.
Section 4904.
Respectfully submitted,
0,
'.
GOLD~&~~;f~~T~ & McKEEVER
BY: JOSEPH A. i30LDBECK, JR. ESQUIRE
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CUM6EfU.PND COUNTY
PENNSYLVANIA
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF ~ PENNA.
THOMAS SALOMON
Versus
TAMMY SALOMON
,, 2884 94
N,, .......................................... 19
DECREE IN
DIVORCE
AND NOW .... ~. ~,.~-¢..~. ~L~.....~...~. ....... 1 9.~.~..., it is ordered and
decreed that THOMAS SALOMON .., plaintiff,
and .................... .T.A.M.M.Y..S.A.L.O.M.O.N ......................... defendant,
are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet
been entered;
.. ,A. ,P.r.op.e.r.ty..S.e.t.t.le.m.e.n.t. ,Ag,r,e.e,m,ep.t..i.s. ,a,t,t.a,ch.e,d. h.e.r.e.t.o..a.s..A,t.t.a.c.hm.e,n.t. A .a.n.d..i.s
to be incorporated into this Decree in Divorce.
THOMAS SALOMON, :
Plaintiff :
:
v. :
T/qMMY SALOMON, :
Defendant :
IN THE COURT OF CO~4ON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO: 94-2884 Civil Term
TO THE PROTHONOTARY:
Transmit the record together with the following information to
the Court for entry of a divorce decree:
1. Ground for divorce= Irretrievable breakdown under Section
3301(c) of the Divorce Code.
2. Date and manner of service of Complaint:
June 24, 1994 by United States First Class Certified Mail,
Restricted Delivery with Article Number P 848 252 703.
3. Date of the execution of the Affidavit of Consent required
by Section 3301(c) of the Divorce Code by=
Plaintiff--November 21, 1997~ by Defendant--November 24,
4. Date of the execution of the Waiver of Notice of
Intention: Plalntlff--December 4, 1997~
1997.
1997.
Defendant--November 24,
Economic claims pending= NONE.
PORTER, ESQUIRE
Attorne~ for Plaintiff
I.D. 42752
909 East Chocolate Avenue
Hershey PA 17033
(717) 533-7130
THOMAS SALOMON,
Plaintiff
TAMMY SALOMON,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against
the claims set forth in the following pages, you must take prompt
action. You are warned that if you fail to do so, the case may
proceed without you and a Decree of Divorce or Annulment may be
entered against you by the Court. A judgment may also be entered
against you for any other claim or relief requested in these papers
by the Plaintiff. You may lose money or property or other rights
important to you including custody or visitation of y6ur children
When the ground for the divorce is indignities or irretrievable
breakdown of the marriage, you may request marriage counseling. A
list of marriage counselors is available in the office of the:
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE TH~ RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
COURT ADMINISTRATOR
4TH FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
(717) 240-6200
THOM~%S SALOMON, :
Plaintiff :
TAMMY SALOMON, :
Defendant :
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - IN DIVORCE
NO.
COMPLAINT IN DIVORC~ UNDER SECTION 3301(c) or 3301(d)
OF THE DIVORCE CODE
1. Plaintiff is THOM_AS SALOMON, who currently resides
at P.O. Box 691, Dillsburg, Cumberland County, Pennsylvania,
since August 2, 1993.
2. Defendant is TAMMY SALOMON, who currently resides at
1723 English Drive, Mechanicsburg, Cumberland County, Pennsylvania,
since May 1, 1993.
3. THOMAS SALOMON and TAMMY SALOMON have been bona fide
residents in the Commonwealth for at least six months immediately
previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on
December 6, 1985, in Farmingdale, New York.
5. There have been no prior actions of divorce or for
annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised that counseling is
available and that Plaintiff may have the right to request that the
Court require the parties to participate in counseling.
WHEREFORE,
Decree of Divorce.
Plaintiff requests the Court to enter a
~e~r~in~ire
I.D. 42752
909 East Chocolate Avenue
P.O. Box 338
Hershey PA 17033
(717) 533-7130
VERIFICATION
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. ~
THOMAS SALOMON
THOMAS SALOMON,
Plaintiff
TAMMY SALOMON,
Defendant
IN THE COURT OF COMMON
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO: 94-2884 Civil Term
1. A Complaint in Divorce under Section 3301(c) or (d) of
the Divorce Code was filed on May 31, 1994.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of fillng
the Complaint.
3. I consent to the entry of a final decree of divorce.
4. ! understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim
them before a divorce is granted.
I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn
falsification to authorities.
TAMM~SA~OMON
THOMAS SALOMON,
Plaintiff
Ve
TP2~ SALOMON,
Defendant
IN THE COURT OF CO~ON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO: 94-2884 Civil Term
M]U. vmtt ~ IIOTXC~ ~ XBTEMTXOll TO RII~IUEST UFA*itT
Or* A DlmtCS Dm mm § 3303. (c) ~ Tile DXYOitC~ (:ODE
1. I consent to the entry of a final decree of divorce
without notice.
2. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim
them before a divorce is granted.
3. I understand that I will not be divorced until a divorce
decree is entered by the Court and that a copy of the decree will
be sent tome immediately after it is fixed with the Prothonotary.
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 Pa.C.S. § 4904 relating to unsworn
falsification to authorities.
Date: ///~//~ ]
/ ,
TA~ S~MON
THOMAS SALOMON,
Plaintiff
V.
TAI~4Y SALOMON,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO= 94-2884 Civll Term
1. A Complaint in Divorce under Section 3301(c) or (d) of
the Divorce Code was filed on May 31, 1994.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing
the Complaint.
3. I consent to the entry of a final decree of divorce.
4. ! understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim
them before a divorce is granted.
I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S.
falsification to authorities.
Date= ~fOV ~/ /q~V
§4904 relating to unsworn
· ~O~AS SALOMON
THOMAS SALOMON,
Plaintiff
TAMMY SALOMON,
Defendant
IN THE COURT OF CO~ON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO: 94-2884 Civil Term
WaTV~itOt*MOTXCE(H,' XNTIEMTXOMTOit~,Olr, I~T~II,A~t~'
Ot~A DXVO~C~D~(~m~mlD~it§ 3301 (c)
1. I consent to the entry of a final decree of divorce
without notice.
2. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim
them before a divorce is granted.
3. I understand that I will not be divorced until a divorce
decree is entered by the Court and that a copy of the decree will
be sent to me immediately after it is filed with the
Prothonotary.
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 Pa.C.S. § 4904 relating to unsworn
THOMAS SALOMON,
Plaintiff
TAMMY SALOMON,
Defendant
IN THE COUNT OF CO~oN PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO: 94-2884 Civil Term
THOMAS SALOMON ·
Plaintiff
Ve
TAI~Y SALOMON,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO: 94-2884 Civil Term
I, ~eorge W. Porter, Esquire· do certify that on
June 24, 1994, I did serve a true and correct copy of the Divorce
Complaint in the above-captioned case upon Ts~ey Salomon via United
States Certified Mail-Restricted Delivery having Article Number
P 848 252 703.
I.D. 42752
909 East Chocolate Avenue
Hershey PA 17033
(717) 533-7130
Sworn to me this /~ day of
Notary Public
Notarial Seal
Cora R, Davies. Notary Publ c
West Lebanon Twp. Lebanon County
My Commission Expires Dec. 1 20Ol
Member, Pe,nsylva,ia Associatio, of Notaries
THOMAS SALOMON,
Plaintiff
V.
TAMMY SALOMON,
Defendant
IN THE COURT OF CO~h~ON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO: 94-2884 Civil Term
0
THOMAS SALOMON,
Plaintiff
TAMMY SALOMON,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE
: NO. 94-2884 CIVIL TERM
CERTIFICATE OF SERVICE
I, Michelle B. Stokes, Certified Legal Intern, of the Family Law Clinic, hereby certify
that I am serving a tree and correct copy of the foregoing Praecipe to Enter Appearance on
defendant's counsel, Geor~,e W. Porter, Esq., 909 East Chocolate Avenue, P.O. Box 338,
Hershey, PA 17033 by depositing copies of the same in the United States mail, first class,
postage prepaid, this 20th day of September, 1994.
Michelle B. Stokes
Certified Legal Intern
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
THOMAS SALOMON,
Plaintiff
TAMMY SALOMO_N~ .....
Defendan~ ..............
PRAECIPE
la ~he Court of Common Pleas of
Cumberland County, Pem~ylvauia
No.94-2884- ...... Civil
CIVIL ACTION .....
IN DIVORCE
19 94
Please enter the appearance of the Family Law Clinic on behalf
of the defendant in the above-captioned matter.
To Lawrence E. Welker
.' supervises A~
ROBERT E. RAINS
Stu~n~ Atiy f~
MICHELLE B. STOKES
No. 94-2884 T~ru~ 19
Thomas Salomon, PlaintiFf
~ammy Salomon, Defenda~
Michelle B. Stokes
Robert E. Rains
The Family Law Clinic
45 No~th Pitt Sheet
Ca~Usle, PA 17013
717/240-5204
PRAECIPE
THOMAS SALOMON,
Plaintiff
Vo
TAMMY SALOMON,
Defendant.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY
:
: CML ACTION - LAW IN DIVORCE,
: EQUITABLE DISTRIBUTION
:
: No. 94-2884 CIVIL TERM
PETITION FOR ALIMONY PENDENTE LITE
TO THE HONORABLE JUDGES OF SAID COURT:
The Family Law Clinic, attorneys for defendant, Tammy Salomon, respectfully requests
the court to order the equitable division of certain costs involved in the valuation of marital
property. These valuations are needed to facilitate the equitable distribution of marital property.
1. These costs include, but are not limited to, the valuation of Plaimiff's pension plan.
2. Defendant is without the financial ability to bear the burden of these costs.
3. Both parties will benefit from these valuations of marital property.
WHEREFORE, Defendant prays this Honorable Court to order Plaintiff to bear all costs
involved in the valuation of marital property subject to this action.
Date~'3~ ~'~- ~F~¢
l~Iichele ~. Bel-luzz' -,,,,~ -
Student Attorney
Linda E. Fisher
Thomas Peeler
Supervising Attorney
THE FAMILY LAW CLINIC
45 N. Pitt Street
Carlisle, PA 17013
717\243-2968
THOMAS SALOMON,
Plaintiff
v.
TAM>fY SALOMON,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
civiL
NO. ~ ~- MIiV
ENTRY OF APPEARANCE
Please enter my appearance on behalf of Thomas Salomon,
the Plaintiff in the above captioned case.
'GEORGE~.PORTER, ESQUIRE
I.D. 42752
909 East Chocolate Avenue
P.O. Box 338
Hershey PA 17033
(717) 533-7130
THOMAS SALOMON
Plaintiff,
TAMMY SALOMON
Defendant.
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY
:
: CIVIL ACTION - LAW IN DIVORCE
:
: NO. 94-2884 CIVIL TERM
PETITION FOR EOUITABLE DISTRmUTION UNDER DIVORCE CODE
The petition of TAMMY SALOMON, by her attorneys, Family Law Clinic, respectfully
represents that:
1. Petitioner is the above-named Defendant, who currently resides at 618 Colonial
View Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055.
2. Respondent is the above-named Plaintiff, whose current mailing address is P.O.
Box 691, Dillsburg, York County, Pennsylvania.
3. Petitioner and Respondent were married on December 6, 1985.
4. A Complaint in Divorce under Section 3301(c) and 3301(d) was filed by Plaintiff,
Thomas Salomon, on May 31, 1994.
5. At issue are Respondent's pension plan and any other marital property.
6. Petitioner and Respondent have been unable to agree to an equitable division of
said property as of the date of the filing of this petition.
WHEREFORE, Petitioner requests the court to equitably divide the pension plan and
other marital property.
Date
Respectfully submitted,
Belluzzi t. ~
Student Attorney
ROBERT E. RAINS
THOMAS M. PLACE
LINDA FISHER
Supervising Attorney
THOMAS PEELER
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
THOMAS SALOMON,
Plaintiff,
TAMMY SALOMON,
Defendant,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
IN DIVORCE
No. 94-2884 CIVIL TERM
CERTIFICATE OF SERVICE
I, Michele L. Belluzzi, Certified Legal Intern, Family Law Clinic, hereby certify that
I have served a true and correct copy of Petition for Equitable Distribution and Petition for
Alimone Pendente Lite on George Porter, counsel for Thomas Salomon, at 909 E. Chocolate
Avenue, P.O. Box 338, Hershey, PA 17033, by depositing a copy of the same in the United
States first class mail this 6th day of September, 1995.
THOMAS SALOMON,
Plaintiff/Respondent
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
IN CUSTODY
TAMMY SALOMON,
Defendant/Petitioner
: NO. 94-2884
CIVIL TERM
COMPLAIiNT FOR CUSTODY
AND NOW comes the petitioner, Tammy Salomon, the defendant in the above-captioned
divorce action by and through her attorneys, the Family Law Clinic, and sets forth the following
complaint for custody pursuant to Pa.R.C.P. 1920.15(b):
1. Tammy Salomon resides at 618 Colonial View Road, Mechanicsburg, 17055,
Cumberland County, Pennsylvania.
2. Thomas Salomon resides at 119 Harrisburg Street, Apt. 4, Dillsburg, 17019, York
County, Pennsylvania.
3. Tammy Salomon seeks custody of the following children:
Name Present Residence A~e
Thomas Michael Salomon, Jr. 618 Colonial View Road 6
Mechanicsburg, PA
Holly Marie Salomon 618 Colonial View Road 8
Mechanicsburg, PA
The children were not born out of wedlock.
During the past five years, the children have resided with the following persons and at
the following addresses:
Persons
Tammy Salomon
Addresses
618 Colonial View Road
Mechanicsburg, PA
Dates
Aug., 1994-present
Tammy Salomon
Brenda Thompson
David English
Billy English
120 Rolo Court
Mechanicsburg, PA
June, 1994- Aug.,1994
Tammy Salomon
1723 English Drive
Mechanicsburg, PA
Sept., 1993- June 1994
Tammy Salomon
Thomas Salomon
1723 English Drive
Mechanicsburg, PA
May, 1993-Sept. 1993
Thomas Salomon
219 8th Street
Bethpage, NY
May, 1992-May, 1993
Thomas Salomon
Tammy Salomon
219 8th Street
Bethpage, NY
Sept., 1988-May, 1992
4. The children are presently in the custody of their mother, Tammy Salomon. She is
married, but separated. She resides with the children only.
5. The father of the children is Thomas Salomon; he is married, but separated. He
resides alone.
6. Tammy Salomon has not participated as a party or witness, or in another capacity,
in other litigation concerning the custody of the children in this or another court.
Tammy Salomon has no information of a custody proceeding concerning the children
pending in a court of this Commonwealth.
Tammy Salomon does not know of a person not a party to the proceedings who has
physical custody of the children or claims to have custody or visitation rights with respect to the
children.
7. The best interests and permanent welfare of the children will be served by granting
the relief requested because:
a) Mother has been primary caretaker of the children since birth;
b) Mother provides the children with a home with adequate moral, emotional and
physical surroundings as required to meet the children's needs;
c) Mother is willing to accept custody of the children;
d) Mother continues to exercise parental duties and enjoys the love and affection of the
children;
e) Mother is planning to relocate with the children to New York state in August, 1996
because of extended family residing there and employment opportunities for mother.
f) Mother will afford the father reasonable visitation with the children.
8. 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.
WHEREFORE, petitioner requests the court to grant her custody of the
children, subject to visitation as the parties may agree to in the future, and such other relief as
the Court deems just.
Date
~HANNON S. PIERGALLI~I
Certified legal intern
ROBERT E. RAINS
KATHERINE C. PEARSON
Supervising Attorney
GAIL R. SHEARER
Staff Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/240-5204
VERIFICATION
I verify that the statements made in this Petition 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.
~.~alo~non~
THOMAS SALOMON,
Plaintiff/Respondent
TAMMY SALOMON
Defendant/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
:
: CUSTODY
:
: NO. 94-2884 CIVIL TERM
ORDER OF COURT
AND NOW, ~ne I~ , upon consideration of the attach~ed comj21ain,t, it is hereby
directed that the parties and their respective counsel appear before /da.wa oc,,9~tazy , the
conciliator, at~/0, r~t,h 6~ day of ,.~uly o/ , 19 q~, at Io'.,.~o 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. All children age five or older may also be present
at the conference. Failure to appear at the conference may provide grounds for entry of a
temporary or permanent order.
FOR THE COURT,
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accomodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR 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.
OFFICE OF COURT ADMINISTRATOR
COURTHOUSE, 4TH FLOOR
· CARLISLE, PA 17013
(717) 240-6200
VII",IVA'IASNN:J~
A.tNflOO aNV-l~-r~lrlO
THOMAS SALOMON,
Plaintiff,
TAMMY SALOMON,
Defendant,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
: IN DIVORCE
:
: No. 94-2884 CIVIL TERM
:
CERTIFICATE OF SERVICE
I, Shannon Piergallini, Certified Legal Intern, Family Law Clinic, hereby certify that I
have ~erved a'true and correct copy of Custody Complaint and Order of Court on George Porter,
counsel-for Tlmmas Salomon, at 909 E. Chocolate Avenue, P.O. Box 338, Hershey, PA 17033,
¥~3' depositing a copy of the same in the United States first class mail this 18th day of June,
19.96. I.:have served the same on Thomas Salomon, P.O. Box 691, Dillsburg, PA 17019, by
depositing a copy of the same in the United State first class mail and certified, restricted
delivery, return receipt requested this 18th day of June, 1996.
Shannon S. Piergallini ,~
Certified Legal Intern
THOMAS SALOMON,
Plaintiff,
Vo
TAMMY SALOMON,
Defendant,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
No. 94-2884 CIVIL TERM
CERTIFICATE OF SERVICI~
I, Shannon Piergallini, Certified Legal Intern, Family Law Clinic, hereby certify that I
have served a true and correct copy of Custody Complaint and Order of Court on George Porter,
counsel for Thomas Salomon, at 909 E. Chocolate Avenue, P.O. Box 338, Hershey, PA 17033,
by depositing a copy of the same in the United States first class mail this 18th day of June,
1~96. ~I have served the same on Thomas Salomon, P.O. Box 691, Dillsburg, PA 17019, by
deposit(n, g a copy of the same in the United State first class mail and certified, restricted
~ dehvery, return receipt requested this 18th day of June, 1196
z iai, ~a~ [~Sl, Shannon S. Piergallini 0
Receipt for Certified Legal Intern
Certified Mail
No Insurance Coverage Provided
Do not use for International Mai~
{See Reverse)
Return Receipt Showm~
/,./d)
THOMAS SALOMON,
Plaintiff
TAMMY SALOMON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE, CUSTODY,
EQUITABLE DISTRIBUTION
NO. 94-2884 CIVIL TERM
CUSTODY AND VISITATION AGREEMENT
THIS AGREEMENT, made this 17th day of June, 1996, between Thomas salomon,
hereinafter "Father" and Tammy Salomon, hereinafter, "Mother" concerns the custody and
visitation of their children Thomas Michael Salomon and Holly Marie Salomon.
WHEREAS, Mother and Father desire to enter into and be legally bound by an
agreement as to the custody of the children and to have this agreement made an order of court,
plaintiff and defendant agree to the following:
1. Plaintiff and Defendant are the parents of Holly Marie Salomon born 1/28/88, and
Thomas Michael Salomon born 10/1/89.
3.
4.
the parties.
5.
Mother and Father will share lege.! custody of the children.
Mother shall have primary physical custody of the children.
Father shall have partial physical custody at times and dates to be determined by
1996 out of the Commonwealth of Pennsylvania and reside in the State of New York.
agrees that such a move is in the best interests of the children.
Father understands that Mother is planning to move with the children in August
Father
6. Mother and Father will share responsibility for all transportation costs associated
with the exercise of Father's custody rights.
7. The parties hereto intend to be legally bound by the terms of this agreement.
Thomas Salomon, Plaintiff
909 East Chocolate Avenue
Hershey, PA 17033
Counsel for Plaintiff
Approved and emered as an Order of the Court.
SHANNON S. PIE~~
Certified Legal Intern
KATHERINE C. PEARSON
Supervising Attorney
GAIL R. SHEARER
Staff Attorney
Counsel for Defendant
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/240-5204
THOMAS SALOMON, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
V. : No. 94-2884 CIVIL TERM
:
TAMMY SALOMON, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
( ) Plaintiff
Serratelli, Esquire
with Pa
1.
2.
PRE-TRIAL STATEMENT
(X) Defendant, by his/her attorney, Lori K.
files this pre-trial statement in accordance
.R.C.P. 1920.33(b).
Inventory and A_Dpralsem~t: See Inventory and Appraisement.
None at this time; however, Defendant reserves the right
to supplement this statement if necessary.
3.
None at this time; however, Defendant reserves the right
to supplement this statement if necessary.
a. Defendant's Income and Expense Statement
b. Defendant's Inventory and Appraisement
c. Attorney Fees and Costs Statement (Will be supplied
at hearing)
Defendant reserves the right to supplement this statement,
if necessary.
5. Income: Refer to Income and Expense Statement
6. ~]~_~,~: Refer to Income and Expense Statement
7. Retirement/Pension:
See Inventory and Appraisement. Husband has a pension
through his employer, U.S. Postal Service.
8. g~_~: See Exhibit C.
9. DisPuted Personal Property: None at this time, Defendant
reserves the right to supplement this statement if
necessary.
10. ~~ See Inventory and Appraisement
11. Proposed Resolution:
a. Plaintiff is granted a divorce from Defendant.
b. Each party shall retain all personal property in his/her
possession.
Ce
Wife shall receive 60% of the marital portion of
Husband's U.S. Postal Service pension in the form of
a lump sum payment, if possible. In the alternative,
Wife shall receive 60% of the marital portion of
Husband's U.S. Postal Service pension on a deferred
Basis. Wife shall also be named as irrevocable survivor
beneficiary on Husband's U.S. Postal Service pension.
Wife shall receive 60% of the marital portion of
Husband's U.S. Postal Thrift Savings Plan in the
of a lump sum payment.
form
e. Wife shall receive 60% of any cash surrender value
of Husband's life insurance policies.
f. Husband shall pay to Wife as alimony, the sum of $575.00
per month for an indefinite period.
g. Husband shall obtain or maintain a life insurance policy
in order to secure his alimony obligation.
h. Husband shall pay Wife's counsel fees and costs.
i. Wife shall be appointed as irrevocable beneficiary on
husband's postal service life insurance policy.
Respectfully submitted,
Lor~. Serratelli, Esq.
SERI~TELLI ~ SCHIFFH~N~,
BROWN & CALHOON~ P.C.
2080 Linglestown Road
Suite 201
Harrisburg, PA 17110-9445
(717) 540-9170
Attorney for Defendant
THOMAS SALOMON,
Plaintiff
v.
TAMMY SALOMON,
Defendant
: IN THE COURT OF COMMON PLEAS
:
:CUMBERLAND COUNTY, PENNSYLVANIA
:
: No. 94-2884 Civil Term
:
: CIVIL ACTION - LAW
:
: IN DIVORCE
December
postage prepaid, addressed as
CERTIFICATE OF SERVICE
I, Lori K. Serratelli, Esquire, do hereby certify that on
~__~, 1996 the foregoing was delivered by U.S. Mail,
follows:
The original to:
E. Robert Elicker, II
Divorce Master
Office of Divorce Master
9 North Hanover Street
Carlisle, PA 17013
and a copy to:
George W. Porter, Esq.
909 East Chocolate Avenue
Hershey, PA 17033
Attorney for Plaintiff
SERRATELLI, SCHIFFMAN,
BROWN & CALHOON, P.C.
2080 Linglestown Rd., Suite 201
Harrisburg, PA 17110-9445
(717) 540-9170
Attorney for Defendant
THOMAS SALOMON,
Plaintiff
v.
TAMMY SALOMON,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO: 94-2884 Civil Term
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against
the claims set forth in the following pages, you must take prompt
action. You are warned that if you fail to do so, the case may
proceed without you and a decree of divorce or annulment may be
entered against you by the court. A judgment may also be entered
against you for any other claim or relief requested in these
papers by the Plaintiff. You may lose money or property or other
rights important to you, including custody or visitation of your
children.
When the ground for divorce is indignities or irretrievable
breakdown of the marriage, you may request marriage counseling.
A list of marriage counselors is available in the Office of the
Prothonotary at the
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT
IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONe, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
4TH FLOOR
ONE COURTHOUSE SQUARE
CARLISLE PA 17013
(717) 240-6100
THOMAS SALOMON,
Plaintiff
TAM~Y SALOMON,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO: 94-2884 Civil Term
CERTIFICATE OF SERVICE
I, George W. Porter, Esquire, do certify that on October 10,
1996, a true and correct copy of the within "Motion for
Appointment of Master "was mailed via United States First-Class
Mail, postage pre-paid to:
Shannon S. Piergallini
Certified Legal Intern
45 North Pitt Street
Carlisle PA 17013-2943
George W. Porter, Esquire
I.D. 42751
Attorney for Thomas Salomon
909 East Chocolate Avenue
Hershey PA 17033
(717) 533-7130
THOMAS SAL~,
Plaintiff
Ve
TAMMY SALOMON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND C~3NTY, P~NNSYLVANIA
NO. 94 - 2884 CIVIL TERM
IN CUSTODY
AND NON, this twenty-seventh day of June, 1996, the Conciliator,
being advised that the parties have resolved all custody issues by
agreement, relinquishes jurisdiction in this case.
Dawn S. Sunday, Esquire
November 21, 1996
LOP./K. SERRATELLI
STEVEN J. SCHIFFMAN
MICHAEL F. BROWN
RONALD L. CALHOON
GARY L. ROTHSCHILD
ROBERT D. HAMILTON
VIRGINIA M. DIAS
GARTH A. STEPHENSON
OF COUNSEL
(MD & DC BARS ONLy)
SUITE 201
2080 LINGLES~fOWN ROAD
HARRISBURG. PA
17110-9445
(717) 540-9170
FAX (717) 540-5481
E. Robert Elicker, Master
Office of Divorce Master
9 North Hanover Street
Carlisle, PA 17013
Re: Salomon v. Salomon
No. 94-2884 Civil
Dear Mr. Elicker:
This will confirm my telephone call with Traci of
today. As was explained, we only recently were retained
by Mrs. Salomon and therefore, would request an extension
of two weeks in order to file our pre-trial statement.
Thank you for your consideration.
LKS/dae
Enclosure
cc: George W. Porter,
Tammy Salomon
Esq.
Sincerely,
SERRATELLI, 8CHIFF14AN
BROWN & CALHOON~ P.O.
December 13, 1996
LORI K. SERRATELLI
STEVEN J. SCHIFFMm4
MICHAEL F. BROWN
RONALD L. CALHOON
GARY L. ROTHSCHILD
ROBERT D. HAMILTON
E. Robert Elicker, Master
Office of Divorce Master
9 North Hanover Street
Carlisle, PA 17013
Re: Salomon v. Salomon
No. 94-2884 Civil
Dear Mr. Elicker:
Enclosed please find the following:
1) Defendant,s original Income and Expense
statement;
VIRGINIA M. DIAS
GARTH A. STEPHENSON
OF COUNSEL
(MD & DC BARS ONLy)
2) Defendant's original Inventory and Appraisement
form;
........ original was mailed to the Court today along with
filing fee.
3) Defendant,s original Pre-Trial Statement; and
4) A copy of Defendant,s Petition for Alimony
Pendente Lite, Counsel Fees, Costs and Alimony. The
the
Thank you.
SUITE 201
2080 LINGLESTOWN ROAD
HARRISBURG, PA
(717) 540-9170
FAx (717) 540-5481
LKS/dae
Enclosure
cc: George W. Porter,
Tammy Salomon
Esq.
Sincerely,
SERI~TELLI, SCHIFFMAN
BROWN & CALHOON, P.C.
L~ ~. Serratelli
To
You axe hereby notified to file a
written response to the enclo$~i
w/thin twenty (20) days from
vice hereof or a judgment ~
entered against you
by . _
^ttomey
THOMAS SALOMON,
Plaintiff
TAMMY SALOMON,
Defendant
SUITE 201
2080 LINGLESTOWNROAD
HARRISBURG, PA
17110-9445
We do hereby certify that the
within is a true and correct copy
of ~e~=l~al filed in this act[on
by
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DIVORCE AND EQUITABLE DISTRIBUTION
NO. 2884 CIVIL 1994
PRAECIPE TO WITHDRAW AND ENTRY Of APPEARANCE
To the Prothonotary:
Please withdraw the appearance of the Family Law Clinic on behalf of Tammy Salomon,
the defendant, and enter the appearance of Loft Serratelli, Esq. in the above captioned matter.
LORI 8ERRA'TELLI, ESQ.
20~0 Linglestown Road, Suite 106
Harrisburg, PA 17110
SHANNON S. PIERGALEINI
Certified Legal Intern
eOBERT E. tmNS
THOMAS ~. PLACE
KATHERINE C. PEARSON
Supervising Attorney
GAIL R. SHEARER
Staff Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/243-2968
November 26, 1996
LORI K. SERRATELLI
STEVEN J. SCHIFFMAN
MICHAEL 1~. BROWN
RONALD L. CALHOON
GARY L. ROTHSCHILD
ROBERT D. HAMILTON
E. Robert Elicker, II
Office of Divorce Master
9 North Hanover Street
Carlisle, PA 17013
Re: Salomon v. Salomon
No. 94-2884 Civil
Dear Mr. Elicker:
Enclosed please find a copy of the Praecipe entering
my appearance which has been filed with the Court.
Thank you for your attention.
Sincerely,
GARTH A. STEPHENSON
OF COUNSEL
(MD & DC BARS ONIX)
..... LKS/dae
SERRATELLI, SCHIFFMAN,
BROWN & ~LHOON, P.C.
Lor~rratel li
Enclosure
CC:
Tammy Salomon
George W. Porter, Esq.
Shannon S. Piergallini
SUITE 201
2080 LINGLESTOWN ROAD
HARRISBURG, PA
17110-9445
(717) 540-9170
F~x (717) 540-5481
THOMAS SALOMON,
Plaintiff
TAMMY SALOMON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DIVORCE AND EQUITABLE DISTRIBUTION
NO. 2884 CIVIL 1994
PRAECIPE TO WITHDRAW AND ENTRY Of APPEARANCE
To the Prothonotary:
Please withdraw the appearance of the Family Law Clinic on behalf of Tammy Salomon,
the defendant, and enter the appearance of Lori Serratelli, Esq. in the above captioned matter.
2LO~ ~iERRA'TELLI, ESQ.
04~ Einglestown Road, Suite 106
Harrisburg, PA 17110
SHANNON S. PIERGAiJdNI
Certified Legal Intern
gains
THOMAS Iv~. PLACE
KATHERINE C. PEARSON
Supervising Attorney
GAIL R. SHEARER
Staff Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/243-2968
THOMAS SALOMON,
Plaintiff
v.
TAMMY SALOMON,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO: 94-2884 Civil Term
PRE-TRIAL STATEMENT
1. LIST OF ASSETS.
a. Marital assets in possession of Defendant Tamn%;
Salomon: At the time of separation, Defendant retained in her
possession items of personal property which are unappraised, but
have an estimated value of Five Thousand Dollars ($5,000.00).
These items consisted of a dining room suite, a living room
suite, three bedroom suites, miscellaneous kitchen appliances,
two televisions, a VCR and a 1987 Hyundai.
b. At the time of separation, Plaintiff took with
him items of personal property which are unappraised, but have
an estimated value of One Thousand Dollars ($1,000.00.) These
items consisted of a bed, a stereo and a 1986 Subaru automobile
which was later sold for Three Hundred Dollars ($300.00).
c. Plaintiff Thomas Salomon has a pension with a
present value of Eight Thousand Nine Hundred Sixty-Two Dollars
($8,962.00).
-1-
2. EXPERT WITNESS.
Plaintiff Thomas Salomon intends to introduce into
evidence the expert report of Mark Altschuler, Actuary. His
report is attached hereto and marked "Attachment A."
Mr. Altschuler is an actuary employed by Pension Analysis
Consultants, Inc., and has an office address of 8215 Forest
Avenue, Elkins Park, Pennsylvania. Mr. Altschuler has a
Bachelor's Degree from the University of Pennsylvania in
mathematics and a Master's Degree from Case Western Reserve
University. He has been working as an actuary since 1990.
3. IDENTITY OF WITNESSES.
At the present time, Plaintiff only intends to call
Plaintiff and the expert witness, if necessary.
4. LIST OF EXHIBITS.
Plaintiff only intends to
evaluation report.
introduce the pension
5. PLAINTIFF'S INCOME.
Plaintiff's Federal Income Tax Return from 1995 is
attached hereto as "Attachment B." Plaintiff's sole source of
income is from working at the United States Postal Service.
Plaintiff's net monthly income, as calculated by Cumberland
-2-
County Domestic Relations Section Officer R. J. Shadday is
Two Thousand Five Hundred Two Dollars ($2,502.00) per month.
A copy of Plaintiff's representative paystub is attached hereto
and marked "Attachment C."
6. PLAINTIFF'S EXPENSE STATEM]~NT.
Plaintiff's Income and Expense Statement is attached
hereto and marked "Attachment D."
7. PENSION.
It is Plaintiff's position that the marital portion of
the pension is Eight Thousand Nine Hundred Sixty-Two Dollars
($8,962.00). This is based upon a separation date of October 15,
1990.
date,
1990.
While the parties did live together briefly after that
they never lived together as man and wife after October 15,
8. PLAINTIFF MAKES NO CLAIM FOR COUNSEL FEES.
9. NOT APPLICABLE.
10. MARITAL DEBTS.
There are no marital debts.
-3-
11. PROPOSAL:
Plaintiff would give Five Thousand Dollars $5,000.00)
in complete satisfaction of all claims. The divorce would be
granted and spousal support would terminate.
Respectfully submitted:
G~eorg~W.~Port~er~Esquire
I.D. 42751
Attorney for Thomas Salomon
909 East Chocolate Avenue
Hershey PA 17033
(717) 533-7130
-4-
PENSION ANALYSIS CONSULTANTS, INC.
Memo Date: June 20, 1996
Prepared for: George W. Porter Esq.
P.O. Box 338
909 E. Chocolate Ave.
Hershey, PA 17033
Subject:
Salomon v. Salomon
This is a summary memo presenting an abbreviated report of the
current actuarial present value as of 06/20/96 of the undivided marital
coverture.portion of the estimated accrued pension benefit of Thomas
Salomon in the U.S. Postal Service Civil Service Retirement System
(Defined Benefit), in accordance with generally accepted actuarial
standards with imputed Social Security benefits subtracted per
Cornbleth (580 A.2d 369) and Schneeman (615 A.2d 1369).
If date of marital separation is 10/15/93: $ 14,337.
If date of marital separation is 10/15/90: $ 8,962.
More details are available upon request in full report format.
In this immediate offset method the present value is determined as
of.~he valuati?n date ~sin~ a ?overture fraction to produce the amount
su~ect ~o ~qultgble d~strlbu~lon.. Pensio~ benefits when received are
subject to ~axatlon whxch varies with the individual's tax filing
status. This valuation is for the defined benefit pension plan and
does not consider any other entitlements.
The following data was used to determine this amount:
Date of Birth:
Date of Entry:
Date of Marriage:
Valuation Date:
05/31/59
03/12/80
12/05/85
06/20/96
Mortality: GAM-83
Interest rate: 6.79%
Retirement age: 62
Status: Active
PENSION ANALYSIS CONSULTANTS,
Re~l ly~ by
Mark Altschuler, Actuary
INC.
960388
8215 FOREST AVENUE ' P.O. BOX 7107 * ELKINS PARK, PA 19027
(215) 782-9845 or outside 215 & 610 area codes (800) 288-3675 · FAX (215) 782-9852
1040
Label
Pre'Jldanll31
~l,~'ctlon C;mpalgn ~
I
Filing Stalus 2
; x orl'~pllofle
~nc.ome
AdJusiments
Income
Adjusted
Gross Income
U.S, Individual Income Tax Return 1995
THOMAS M SALOMON
TAMMY M SEEGERS
P.O. BOX 691
SURG PA 17019
Os you want $3 to go to tl,Js fund? ................................................
doan thle fund? ..........................
etngle
Married filing Joint re~rn (even If only one had Income)
117-! -8625
093-60-9685
For Privacy Aot and
Paperwork Reduetlofl
Act Nonce, soo
Merfled filing separate return, Enter spoune'$ Soc, Aee. no. Above & furl name here ·.
Heed of household (with qualifying person), (Sea page 12.) if the qualifying person la a child i3ut not your doP0,der~t,
a
SA [] Yeucealf. If you
e Dependents;
THOMAS M
e
Y
aa
10
tl
t2
13
14
faa
'lea
17
'iS
21
24
25.
27
30
01
If your child didn't live with you b~t Is claimed aa your ,qsp. under pre-lOS5 agreement, cheek,, ·
Wagon salaries tlpl eta AffKh Form(A)W-2
Taxable Int~e~rl Ihcome (n~ page 15). AttaCh Schedule B if over $400 ......................
Tix..exe~lpt I~e,-eet (~ee page lA). DON'T i,clud, o, line I& ........
Dividend Inserts. At~ech $oheduie B II over $400 .......................................
Taxable refunde, credits, or offsets of state end Ioo~LI Income foxes (nee page 15) ...............
Nlmony received ................................................................
euslne~e In~ome or (1OAS) A#ach Schedule ¢ or
CApital gain or (1~), If required, attach Schedule O .....................................
Other gains or (IOeSeA). Attach F~rm 47.~7 .............................................
....... I,sal' I I
TotAlpenelonsAndennmttes ..... lien] ' , I I I~ Taxnblonmount(pg,,Is)
Rental real e~tafe, royaltle% partnerships. $ eo'rporatlons, trusts, etc. Atteoh Schedule E ..........
Farm Income or (Iaea). Attach Schedule P .............................................
Unemployment oo~anAallen (~ee page t7) ...........................................
Socialsecuri~bsneflts ......... I ,2,0a I ., I I b TaxableAmour~t (pg. 18)
Other tn~ome.
Add tho amountI In the I This
Your IRA dodu~on (Aee page 19) .........................
Spouse's I~a, dedu~on (~.e page la) .....................
Moving expenses. Attach I=orm 3903 or 3903-F ..............
One-half o! eMf-emp!oyrr~nt tax ..........................
Self-employe,~ he~h I~uranoa deduction (see page 3t) .......
K~ogh & self-employed SEP pleas, If YEP, check · n ......
Penally on early withdrawal cf aadnge .....................
Alimony paid. R~lpient'e $$N · ....
Add line ~ as. These are ..........................
Subtract line 30 from tine '~2. This 15 your adjusted gross Income, If lass than $26,S73 and = child
rived with
hie or her
~o,'m~040¢~005) THOMAS M .$.ALOMON AND TA~.¥ M SEEGERS ,17-54-8625
~ Amount f~m line 3t (a~Ju~d ~ro~s ~o~)
TaX 33 a C~cklt ~ You wero 65 or oldor, ~ 811nd; ~ ~ouaewms SSorold~, ~ Btlnd,
CompU- Add the number of box~ choked above and entre the lolal huo ................ ~ 33z
lation b If your parent (or so~o~ e~e) ~n claim ~u as a dependent, check hare ......... ~ 33b
~"~ ~ cff you are married ~ng ~p~rale~y and your tpOUte tte~zea doductlona or you are
[ Itemized deductlen~ from Schedule A, II~ 2e, OR
.4 ~er S~d~d dadu~lon eh0wn ~elow for you~ firing ~tatua. But If you checked
a~y ~ en II~e 331 or b, ~ to p~e ~ ~ fl~d you~ ~tandwd
large~ J If Veu ~e~ked box 33c, ~u~ standard deducllon Is zero.
of ~ · Single J$3,900 · M~od filing Jolnlly ~ Qualifying widow(or) - $6,550 .......
your:[ · Head of household - $5,750 · Msrried flll~g separately - $3,275
3SSublraCt tine 34 from ~ne 32 ..................................................... ~,~k'
3sIf I~e 32 I~ $~,0~5 or i~, ~l~ply $2,500 by the total numb0r of exomptlene cleimod o~ fine
II ll~ 32 is over ~e,025, see the wo~hoet on page 24 for the anoint to ent~ ..................
3TTa~ble Income. ~ub~ect line 3e from linc 35.
"~'~ '~ 3. Tax. Check If from I ~ Ta~ Tab~, b ~ Tax Rste Schedules, · ~ C~p~el G~n T~ Wo~mheet,
~,~ ,~ ~, or d ~ ~orm 8elS.(e~ page 24), A~unt fica Fo~(s) 88~4 ..... k I I
::. 3~ Additional t~o~. Check I Fo~ 4972 ..............
40 Add Ilnee 3~ and 39.. .,,,,,, ............
41 Credit for c
42 CredR Jar ~e &dedy or ti ..........
Credits
43 Foreign tax crodlt. Attach
44 Other credits (see page:
b [] Form 8396 c [] Form 8801
Add Ilnog 41 through
Subtract line 45 frorr
45
Other
Taxes
so
$2
53
$4
57
~tef.nd or
,%mourlt
YOU Owe
Here
Paid
~reparer's
Use Only
d [~ Form.
AIternatlve minimum
e['lFerrn ............ ,,
~4137 .........
Social r~curity end
Tax on qualified retirement plans, Including IRAe. {l required, attach Fo.,n 532g ...................
Advance earned Inco~ cr~it pey~me from Fo~m W-~ ...................................
Household ~]oy~nt t~. A~h Schedu~ H .........................................
Add Ilne~ 4~ through 53, ~ le ~ur te~l ~x ........................................... ~
Federal Inco~ t~ withheld, If any le from For~) t0~e,
lgg5 ~flmated t~ pay~nls and a~unt applied from 1094 return,,
Earned Inc~e credit, A~ach Schedule EIC If you have a qualifying
child, Nont~able eamed I~o~: amount, ~ I _ / I --
and ~pe · ~O
sa A~unt p~d ~th Fo~ ~e8 (emen~on requ~O .................
s9 ~s~ eoclal s~u~ and RRTA t~ w~hhel~ (see page 3~) ........
S0 Other payment, Che~ If from a ~ Form 243g b ~ Fo~ 4138,,,
~1 Add in~ 55 through ~ Tm~e are your to~l paymente, .................................. ~, ,,,,.,
62 II I1~ 81 Is ~re then I1~ M, eub~aol line 54 karo Eno el, ~ I~ the ~unt you OVERPAIO .......
e3 ~ount of ~ ~2 you want REFUNDED TO YOU ........................................ ~
64 Arnount o~ line ~ you want APPLIED TO ~ ESTIMA~O T~., b
6S If line ~4 I~ ~re than ~no el, subtract fine ~1 from line 54. This Is Ihe AMOUNT YOU OWE.
For dolatts on how ~ p~ and u~o Form 1040-V, Pay~nt Voucher, s~ 33 ............... b
10
31
INCOME AND EXPENgE STATEMENT OF
SSN lit .SS).: ~'Go?5' DR# ~qq~9 DATE THIS STATEMENT 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 the last page of this Income and Expense
Statement.)
iNCOME
Employer & Address
JobTitle/Description F,~ L,I Wv,~K
Pay Period (weekly, bi-weekly, monthly)
Gross Pay per Pay Period ....................................................................................................................
Payroll Deductions:
Federal Withholding .................. $
Social Security ........................... $
Local Wage Tax .......................... $
State Income Tax ....................... $
Retirement .................................. $
Health Insurance ........................ $
Other (specify) ............................
.$
Net Pay per Pay Period ........................................................................................................................ $
(b) Other Income
Interest/Dividends ...................... $
Pension/Annuity ......................... $
Social Security ...........................
. Rents/Royalties .......................... $
~= Expense Account ....~ ..................
. Gifts ...,. ........................................
,. Unemployment Compensation .$
Workmen's Compensation ........ $
Week Month Year
$ $
$. $
$. $
$. $
$ S
$, $
$ $.
Total, Other Income .: ..................... $
$. $
iNCOME AND EXPENSE STATEMENT OF
I verity that the statements made in this Income and Expense State-
menl are true and correct. I understand that false statemenls herein
are made subject lo the penalties of 18 Pa.C.S. 4904 relating lo
unsworn talslfication to authorities.
Plaintift or Defendant
DRO #405
Household) Child Household Child
Week ~ Week Month Month
EXPENSES
· Mortgage/Rent ........................................
Maintenance .......................... .' ................
Utilities (telephone, heating
electriC, etc.) ........................................
Employment (transportation, '
lunches) ...............................................
Taxes
Real Estate ..............................................
Personal Property ...................................
Income .....................................................
Insurance
Homeowners ...........................................
' Life/Accident/Health ..............................
Other ....... ~ ................................................
repairs) .................................................
Medical
Doctor, Dentist, Orthodontist ................
Hospital ...................................................
Special (glasses, braces, etc.) ...............
Education
Private, Parochial School .......................
College .....................................................
Personal
Other (household supplies,
barber, etc.) ............ ; .............................
'~ . Credit PaYments and loans ..................
Miscellaneous
Househbld help/child care .....................
Entertainment (inc. papers,
books, vacation, pay TV, etc.)
Gifts/Charitable contributions ..............
Legal Fees: ..............................................
Other child supportlalimony '
payments .............................................
uther [spec yl .............................................
Total Expenses .............................................
S
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$_
$_
$
$
$_
S
$
$
$_
$
$
$
$
$
$
$__
$
$
$
$
$.
$
$
$_
$_
$
PROPERTY OWNED Description
Credit Union ..............
Stocks/Bonds
Real Estate ......................
Other~ ................................
Total, Property .....................
INSURANCE
Hospital ...........................
Medical ...............
Health/ACcident ..............
Disability income ............
Other (dental, etc.) ..........
Company
(*H - Husband, W- Wife, J - Jo/m, C - Child)
Value
$
$
Ownership*
H W
Policy No.
~)Cove~e * .{~
SUPPLEMENTAL INCOME STATEMENT
A. This form must be filled out by a person who (checkc_pne) __ (1) operates a business or practices a profession; or
(2) is a member of a partnership or joint venture; or
__ (3) is a shareholder in and is salaried by a closed corporation or similar entity.
Bo
Attach to this statement a copy of the following documents relating to the business, profession, partnership,
joint venture, corporation or similar entity.
(1) the most recent Federal income Tax Return, and
(2) the most.recent Profit.and Loss Statement.
C. Name and Address of business:
Telephone Number
Name and Address (if different than C) of accountant, controller or other person in charge of financial
records:
E. (1) Annual income from business ............................................................................................. $
(2) How often is income received? ............................................................................................
(3) Gross income per pay period ............................................................................
(4) Net Income per pay period ..' ......................................................................................... ; ....... $
(5) Specific deductions if any .................................................................................................... $
THOMAS SALOMON,
Plaintiff
T~LMY SALOMON,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: No. 94-2884 CIVIL TERM
:
: CIVIL ACTION - LAW
: IN DIVORCE
PETITION FOR COUNSEL FEES.
COSTS AND ALIMONY
AND NOW COMES Defendant in the above captioned action, by
her attorney, Lori K. Serratelli and the law firm of SERRATELLI,
SCHIFFMAN, BROWN & CALHOOON who petitions this Court for counsel
fees, costs and alimony and in support thereof, avers as follows:
1. The Plaintiff filed a Complaint in Divorce under Section
3301(c) and 3301(d) of the Divorce Code on May 31, 1994.
2. By reason of the institution of the action to the above
term and number, Defendant will be and has been put to
considerable expense in the preparation of her case, in the
employment of counsel and the payment of costs.
3. The Defendant's income is disproportionately lower than
the Plaintiff's income, and Defendant is without adequate funds
to pay the costs and expenses of this litigation.
4. The Plaintiff is currently employed by the U.S. Postal
Service. His net monthly salary is approximately $2502.00.
5. The Defendant is currently unemployed.
WHEREFORE, Defendant prays that your Honorable Court grant
an Order upon Plaintiff to pay Defendant's counsel fees and costs
of the litigation.
COUNTII
6. Paragraphs one through five of this Petition are
incorporated herein by reference as though set forth in full.
7. Defendant is unable to adequately support herself through
appropriate employment.
8. Defendant lacks sufficient property, including but not
limited to, any property distributed pursuant to Chapter 37 of
the Divorce Code of 1980, as amended, to provide for her
reasonable needs.
WHEREFORE, Defendant requests that the Court grant and award
alimony.
Respectfully submitted,
Lori/~/-Se~ra{el 1 i i Esquire
SERB~TELLI, SCHIFFMAN, BROWN &
CALHOON
2080 Linglestown Road, Suite 201
Harrisburg, PA 17110-9445
(717) 540-9170
Attorney for Defendant
CERTIFICATE OF SERVICE
I, Lori K. Serratelli, Esquire, do hereby certify that on
January , 1997 I served a copy of the foregoing upon the
Plaintiff by depositing it in the United States mail, postage
prepaid, addressed as follows:
E. Robert Elicker, II
Divorce Master
Office of Divorce Master
9 North Hanover Street
Carlisle, PA 17013
George W. Porter, Esquire
909 West Chocolate Avenue
Hershey, PA 17033
A~ey for Plai.ntiff
Lori~/ Serratelli, Esq.
8EI~T~LLI~, 8CHIFF~I~N~ BRO~I~ &
C~,LHOON ~ P.C.
2080 Linglestown Rd., Suite 201
Harrisburg, PA 17110-9445
(717) 540-9170
Attorney for Defendant
You are hereby notified to file a
written ~sponse to the endosed
within twenty (20) day~ from
vice hereof or a judgment may be
entered against you .....
SUITE 201
2080 LINGLESTOWNROAD
HARRISBURG, PA
17110-9445
We do hey=by certify that the
within is a true and correct co
of the original filed in this act
THOMAS SALOMON,
Plaintiff
v.
TAMMY SALOMON,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 94-2884 CIVIL TERM
:
: CIVIL ACTION - LAW
: IN DIVORCE
PETITION FOR ALIMONY PENDENTE LITE. COUNSEL FEES.
COSTS AND ALIMONY
AND NOW COMES Defendant in the above captioned action, by
her attorney, Lori K. Serratelli and the law firm of SERRATELLI,
SCHIFFMAN, BROWN & CALHOOON who petitions this Court for alimony
pendente lite, counsel fees, costs and alimony and in support
thereof, avers as follows:
1. The Plaintiff filed a Complaint in Divorce under Section
3301(c) and 3301(d) of the Divorce Code on May 31, 1994.
2. By reason of the institution of the action to the above
term and number, Defendant will be and has been put to
considerable expense in the preparation pf her case, in the
employment of counsel and the payment of costs.
3. The Defendant's income is disproportionately lower than
the Plaintiff's income, and Defendant is without adequate funds
to pay the costs and expenses of this litigation, and is
likewise, without adequate funds to maintain herself during the
pendency of the litigation.
4. The Plaintiff is currently employed by the U.S. Postal
Service. His net monthly salary is approximately $2502.00.
5. The Defendant is currently unemployed.
WHEREFORE, Defendant prays that your Honorable Court grant
an Order upon Plaintiff to pay Defendant alimony pendente lite,
counsel fees and costs of the litigation.
6. Paragraphs one through five of this Petition are
incorporated herein by reference as though set forth in full.
7. Defendant is unable to adequately support herself through
appropriate employment.
8. Defendant lacks sufficient property, including but not
limited to, any property distributed pursuant to Chapter 37 of
the Divorce Code of 1980, as amended, to provide for her
reasonable needs.
WHEREFORE, Defendant requests that the Court grant and award
alimony.
Respectfull~Tsubmitted,
Lori K//qerratelli, Esquire
SERRAT~LLI, SCHIFFMAN, BROWN &
CALHOON
2080 Linglestown Road, Suite 201
Harrisburg, PA 17110-9445
(717) 540-9170
Attorney for Defendant
~ERIFICATION
I verify that the statements made herein are true and
correct. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904 relating to
unsworn falsification to authorities.
CERTIFICATE OF SERVICE
I, Lori K. Serratelli, Esquire, do hereby certify that on
this 13th day of December , 1996, I served a copy of the
foregoing document by United States Mail, First Class, postage
pre-paid, to the following person(s):
E. Robert Elicker, II
Divorce Master
office of Divorce Master
9 North Hanover Street
Carlisle, PA 17013
George W. Porter, Esquire
909 East Chocolate Avenue
Hershey, PA 17033
Attorney for Plaintiff
~'oFi K. S~rra~elll, Esquire
SEBRATELLI, SCHIFFMAN,
BROWN & CALHOON, P.C.
2080 Linglestown Road
suite 201
Harrisburg, PA 17110
(717) 540-9170
Attorney for Defendant
SERRATELLI, $CHIFFMAN, BROWN & CALHOON, P.C.
SUtT~ 201
2080 L~NG~OWN ROAD
THOleS SALOMON,
Plaintiff
SALOMON,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENN8YLV~NIA
No. 94-2884 CIVIL TERM
CIVIL ACTION - L~W
IN DIVORCE
DEFEND~NTfS INCOME AND EXPENSE STATEMENT
LORI K. 8ER~ATELLI, ESQ.
8ERRATELLI, 8CHIFFMAN, BROWN
& CALHOON, P.C.
2080 Linglestown Rd., Suite 201
Harrisburg, PA 17110-9483
(717) 540-9170
Attorney for Defendant
Employer
Address.
INCOME AND EXPENSE
Unemploy~
Type of Work
Payroll Number
Pay Period (weekly, bi-weekly, etc.)
Gross Pay Per Pay Period
ITEMIZED PAYROLL DEDUCTIONS~
Federal Withholdinq
Social Security
Local Wage Tax
State Income Tax
Retirement
Savings Bonds
Credit Union Dues
Life Insurance.
Health Insuranc~
Other (specify)
Net Annual Pay Per Period
OTHER INCOME: WEEK MONTH
Interest $. $ $.
Dividends $ $ $.
Pension $ $ $
Support~ $ $~ 995.00 $
Food Stamps $ ($113/MO) $. 108.00 $
Workmen's Comp. $ $ $
TOTAL NET ANNUAL INCOME ....................... $
EXPENSES
Weekly
YEAR
11.940.00
1,296.00
13,236.00
Monthly Yearly
HOME:
Mortgage/Rent $. $ 675.00 $. 8100.00
Maintenance $. $ $.
UTILITIES:
Electric $ $ 140.002 $ 2680.00
Trash $ $ 12.00 $ 140.00
Telephone $ $ 20.003 $ 240.00
Water $ $ 25.004 $ 300.00
SUBTOTALS $. $ $ 11,460.00
lOrder of Court of Cumberland County Domestic Relations
dated September 11, 1996 for Wife and two children (allocated
$629.00 per month for children and $366.00 per month for Wife).
Unreimbursed medical expenses are to be paid 78% by Husband and
22% by Wife with Husband continuing to provide medical insurance
through his employer. The Order is currently on appeal.
2There is currently an overdue balance of $165.25. The
current payment plan is $10.00 per month. Paid $10.00 on 10-7-96;
and 11-6-96 on the original balance of $185.25.
3There is currently an overdue balance of $125.00 for long
distance charges. The current payment plan is $26.52 per month.
Paid $26.52 on 10-25-96 and 11-25-96 on the original balance of
$176.52.
4There is currently an overdue balance of $67.07. The
payment plan is two more monthly installments of $33.53.
TAXES:
County/School $ $
Personal Property $. $
Income $. $
INSURANCE:
Homeowners $ $
Automobile $ $
Life $ $
Health $ $.
AUTOMOBILE:
Payments $ $
Fuel $ $
Repairs $ $
MEDICAL:
Doctor $. $
Dentist $. $
Orthodontist $ $
Medicine $ $
Special Needs $ $
SUBTOTALS $ $
9.84
46.28
168.75
50.00
15.00
22.00
$. 118.00
$ 555.36
$ 86.50
$
$ 2025.00
$ 600.00
$. 750.005
$. 5000.006
$
$ 18o.oo
$ 3586.86
50n 9/3/96 Alternator installed ($72.10). I need new tires
and other maintenance including a tune-up. (Not included in
subtotal)
6My dentist has recommended a new plate, new bridgework and
implants. I currently have a $25.00 outstanding balance. (Not
included in subtotal)
EDUCATIONs
Lunch, School $ $
Supplies & Field
Trips
Parochial School $. $
College $. $
Religious $. $
PERSONALs
Clothing $. $
Food & Household $. $
Goods
Barber/Hairdresser $ $
Credit Payment $
CREDIT CARDSs (speolfy)
$ $.
$.
LOANSs
Louis Seeqer~ $ $.
MISCELLANEOUS:
Child Care $ $
Papers/Books/Magaz $. $
Entertainment $. $
SUBTOTALS $. $
45.00
300.00
6.00
540.00
240.007
3600.QQ
$
$
$ 3000.008
72.00
This is the amount paid for school clothes this year. The
children are in desperate need of winter clothing which they have
not had in two years. Also, I am in need of new clothing which I
haven't had for 5-8 years.
The Defendant has borrowed monies from her father in order to
live. This is not included in the subtotal as no portion has been
paid to date on the loan.
Pay TV
Vacation
Gifts
Legal Fees
Other Child Support
Alimony Payments
Other (specify)
SUBTOTALS
22.50 $ 270.00
$ 200.009
$.
$ Will be supplied at hearinq
$ $
$ %
470.00
TOTAL ANNUAL EXPENSES: $ 19,898.86
PROPERTY OWNED: DESCRIPTION VALUE
Checking Accounts See Inventory and ApDraisement
Savings Accounts
Credit Union
Stocks/Bonds
Real Estate
TOT~ ....................... $
(H) = Husband (W) = Wife (J) = Joint
~acation consists of travel to the Defendant's relatives in
New York and the Poconos for the weekend.
INSURANCE
MEDICAL
COMPANY
Aetna Freedom Select U.S.Postal Ser.
874191
Health/Accident
Disability Income
Dental
Other
U.S. Postal Ser. 874191
x x X
(H) = Husband (W) = Wife (C) = Child
VERIFICATION
I verify that the statements made herein are true and
correct. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904, relating to
unsworn falsification to authorities.
~ 1040 U.S. hldivldual Income Tax Return 1995I ":
.'" ~ i THOMAS M SALOMON 117-5.~.-8625
,: *,,,,,n~ Y S E 093-60-9685
- .,=~. F~ Privacy Aot
,~?;~,;~, ~. O. BOX 69 [ ,, P~pmwo~ Reduction
: ~l,:cllon.Compalgn ~ Do you want $3 lo go to this fufl~? ..............................................., ~ t~ll0tflOtrl~U~l
1 ~ingle
~iling Status 2 Married fllJng Joint return (even If only one had Income)
:,- ,~. ~.~ 4 ~ Heed of household (w~h qualllylng person). (See page 12,) If the quallf~ng person I~'a chlld'~ut not your dopo. de~L
Sa ~ Yeur~lf. hlo O~ hot t~
THOMAS M ~2 *
d Il your child didn't live with you bul IS cral~d a~ your dup. under pro-10a5 agroe~nt, cheek,, ~ ~ Add
· Total numb~ el exo~o~= clal~d.,,,, .......... , ................... , ...............
~ Wages, salarY,, llpl, etc. A~ach Fom~(s) W.2 ........................... 4 8
Iht.omc aa Taxable Int~es Income (see page 1~). A~ach Schedule B f ov0r $400 ...................... 2 0
~,..,,:h a Dividend Ineo~, Affach Schedule B if ov~ $4~ .......................................
........ , w.~, 10 T~able refund% ~edlm, or offsets of state ~d loon Inco~ taxes (~oe page 15) ...............
w ~o. ~, 11 All. Ay rec~ved ................................................................
12 BUsine~ I~o~ or (Toss). A~ach ~chedule C or C-EZ ...................................
-,, ~ w.L 13 Capital gain or Oo~e), ~ toqulred, ~ach Schod~lo D .....................................
. ,..~ ,, tea Total penl~nl and annuities ..... 1 b Taxable a~unt (pg. 16)
"~' --~ ~'. 17 Rental re~ ~lete, ~yaltles, pa~nershlp% S corporeUong, trusts, etc. A~ech Schedule ~,
t 8 ~afm In~ or (fo~), A~ach $chedule F .............................................
19 Une~loy~nt co~ensat~on (see pogo 17) ...........................................
20. SO~;~ SaCUH~ Uenefl,~ ......... 1,.?9a [ I J b Ta~gblg I~unt ~g. 18)
~ 1 Oih~ ln~.
22 Add the ~Untl In Ihs f~ ri Income ........
Adjustments 23a YourfRAde~on (aH page 19) ..........................
I0 IncOme b Spouse's I~ dgdu~Xon (s~page 1~) ......................
24 Moving expenses, Aflech Form 390~ or 3903-F ...............
25, One-half el I~f-~pfoymont t~ ...........................
26 Self-o~yed he,th Insurance deduction (~e page 21) ........
2~ Keogh & ~-e~loyod ~EP plans. Il 5EP, check b ~ .......
29 All. ny p~d, Reclpleflt't SSN P
30 Add lines 23a through Sg, These are your total ad,albania ............ L~ ............... 0
AdJusled o1 $ublract line 3o [rom lh~o Z2. This tS your adJugted gross Income, If loss then $26,673 and o child
G re ss Income lived with ~ou ~ess than $9,23o If child dldn~ live with' soo "Earned Income Crcdlff on
THOMAS M SALOMON AND TAJ.~IY M SEEGERS 117-54-8625
T,nK
$ornpU-
I~tJo~l
2redils
Other
Paymenl$
~efL,Id or
An'.ounJ
YOU Ow9
Sign
Here
Use Ortly
32 Amounl from fine 31 (adjusted gross Income) .............................................
33 a Chock If: D You ware 65 er older, [] Slind; [] Spouse WaS fi5 or older, [] 811nd:
Add 1he number of bo,<ee checked above and enter the
b Il your parent (or so.one else) can claim you as a dependent, check h~e .........
Iteml;ed deductions from Schedule A, line 28, OR
34 Enter S~lnd~rd dedactlon shown below for ~ur filing 9talus. But If you choked
larger It you checked box 33¢, your stand~d deduc~on le zero.
of · Single ~$3300 · Mailed filing Jointly or Qu~llylng w~dow(~) - $6,550
' your: · Head el household - $5,750 · Married fl~ng separately - $3,275
35 Subtrac[ line 34 from line 32 .....................................................
36 If line 3~ Is $86,0~5 or less, ~ltIply $2,500 by the torsi numb~ of exemptions cl~d on line
II line 32 is over $86,025. see {he worksheet on page 24 lot
37 Tax~ble IncemL ~ub~ec[ line 38 from line 35. ..,
3g Tax. Chock ff from = ~ Ta~ Table, b ~ Tax Rets Schedules, e ~ Cspflel Gain T~ Worksheet.
or d ~ Form 8el~ page 24). Amount floe Form(s) 8814 .....
3e Additional taxes. Ch~k If~m ~ ~ Fo~ 4972.
41 Cr ed{(f0r 'child and depe~e~i~[~ ~ 244t .....
bOFo~mf~e; eOFormee01 dOForm~
45
47
4a Re,.:. · [] Form ~
S0 Social t. ocurity and --, employer. Attach n 4137 .........
SI Tax on qualified retirement plans, including IRAa. Il required, altech Form $339 ...................
52 Advance earned Income credll payrhents from Form W-2 ...................................
S:I Housohold ernpleyment faxes. Attach Schedule H .........................................
54 Add Ilnet 48 through 63, This Is },our, total la~( ........................................... ,, ,
SS Federal Income tax wl[hheld, II any Is from Form(~) toes, cheek I~ []
$$ 1995 estlmatsd tax payrnenls and amount applied from lgg4 return.,
57 Eamad Income credit. Afiach Schedule EIC if you here a qunlilylng
child, Nontaxable earned income: amount, I,. J J ~O J
and type )'
~ Amount paid with Form 4888 (extension requesf) .................
S0 Excess social Se~u~ty and RRTA tax withheld (see page 32) .... .', ..
G0 Other payments, Check Ii tram a [] Form 2439 b [] Farm 4136 .,,
al Add llnee $$1hrough fO Tleae ara your totalp.ayments .............................
62 II line 81 IS more than line 84. ~btract line 54 from line $t, Tbl~ la the amount you OVERPAID .......
~3 Amount of line $2 you Wont REFUNOED TO YOU ........................................
64 Amount of line ~ you want APPLIEO TO ~6 ESTIMATED TAX,. ~' [ ~ 1
65 If line 54 la more than line 61, sublract line 81 t~om line fid, This Is the AMOUNT YOU OWE.
For detalia on how to pay and uso Fo~m 1040-V, Payment Voucher, see page 33 ...............
Ge [attmated I~ . Abe Include on line aS ........
POSTAL CLERK
POSTAL CLERK
,.;~,,u,,· JUDITH L KIEL
, H &"R"gLOCK
1~70 W. MAIN
ST.
--M';PIdA~TC.qBURG, PA
C...k,, 209--34--8328
____t ~.,. ua, 23-2314357
17055
THOMAS SALOMON,
Plaintiff
v.
TAMMY SALOMON,
Defendant
: IN THE COURT OF COMMON PLEAS
:
:CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 94-2884 Civil Term
:
: CIVIL ACTION - LAW
:
: iN DIVORCE
CERTIFICATE OF SERVICE
I, Lori K. Serratelli, Esquire, do hereby certify that on
December ~4~, 1996 the foregoing was delivered by U.S. Mail,
postage prepaid, addressed as follows:
The original to:
E. Robert Elicker, II
Divorce Master
Office of Divorce Master
9 North Hanover Street
Carlisle, PA 17013
and a copy to:
George W. Porter, Esq.
909 East Chocolate Avenue
Hershey, PA 17033
Attorney for Plaintiff
Lor//~.-ser~atelll, Esq.
SERRATELLI, SCHIFFMAN,
BROWN & CALHOON, P.C.
2080 Linglestown Rd., Suite 201
Harrisburg, PA 17110-9445
(717) 540-9170
Attorney for Defendant
SERRATELLI, $CHIFFMAN, BROWN & CALHOON, P.C.
Slrrrs 201
THOMAS SALOMON,
Plaintiff
VS.
TAMMY SALOMON,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
:
NO. 94-2884 CIVIL TERM
:
: CIVIL ACTION - LAW
: IN DIVORCE
INVENTORY AND APPRAISEMENT
OF
( ) Plaintiff (X) Defendant files the following inventory and
appraisement of all property owned or possessed by either party at
the time this action was commenced and all property transferred
within the preceding three years.
( ) Plaintiff (X) Defendant verifies that the statements made
in this inventory and appraisement are true and correct.
( ) Plaintiff (X) Defendant understands that false statements
herein are made subject to the penalties of 18 Pa. C. S. 4904
relating to unsworn falsification to authorities.
a~tif f (X) Defendant
( ) Plaintiff (X) Defendant marks on the list below those
items applicable to the case at bar and itemizes the assets on the
following pages.
) 1.
X) 2.
×) 3.
) 4.
) 5.
) 6.
) 7.
) 8.
X) 9.
)
(X)
(X)
( )
( )
( )
Real Property
Motor Vehicles
Stocks, bonds, securities and options
Certificates of deposit
Checking accounts, cash
Savings accounts, money market savings certificates
Contents of safe deposit boxes
Trusts
Life Insurance policies (indicate face value, cash
surrender value and current beneficiaries)
10. Annuities
11. Gifts
12. Inheritances
13. Patents, copyrights, inventions, royalties
14. Personal property outside the home
15. Businesses (list all owners, including percentage of
ownership, and officer/director positions held by a
party with company)
16. Employment termination benefits -- severance pay,
workman's compensation claim/award
17. Employee Savings Plans
18. Pension plans (indicate employee contribution and
date plan vests)
19. Retirement plans, Individual Retirment Accounts
20. Disability payments
21. Litigation claims (matured and unmatured)
)
)
x)
x)
)
22.
23.
24.
25.
distribution of such assets
26. Other
Military/V.A. benefits
Education benefits
Debts due, including loans, mortgages held
Household furnishings and personalty (include as a
total category and attach itemized list if
is in dispute)
~~ ( ) Plaintiff (X) Defendant lists all marital
property in which either or both spouses have a legal or equitable
interest individually or with any other person as of the date this
action was commenced.
ITEM NO. 1 DESCRIPTION: U.S. Postal
VALUE: ~ DATE OF VALUATION:
NON-MARITAL PORTION:
AMOUNT/NATURE OF ANY LIEN:
Service Pension (Husband%
ITEM NO. ~ DESCRIPTION: U.S. Postal Service Thrift Savinqs
plan (Husband)
VALUE: ~L~ DATE OF VALUATION: Present
NON-MARITAL PORTION:
AMOUNT/NATURE OF ANY LIEN:
ITEM NO. ~
VALUE: Unknown DATE OF VALUATION:
NON-MARITAL PORTION: Unknown
AMOUNT/NATURE OF ANY LIEN: Unknown
DESCRIPTION: Life Insurance (Husband~
Unknown
ITEM NO. 7 DESCRIPTION: V.C.R. fBroke~ & 2 Tables fWife!
VALUE: $20.00 DATE OF VALUATION: ~esent
NON-MARITAL PORTION: ~O~
AMOUNT/NATURE OF ANY LIEN: None
ITEM NO. ~ DESCRIPTION:
VALUE: 2500.00 DATE OF VALUATION:
NON-MARITAL PORTION: ~O~
AMOUNT/NATURE OF ANY LIEN: Non~
Bedroom Suite, Living Room Suite,
Kitchen Set, Entertainment Set,
All Other Household Goods fHusband)
Present
NON-NON-MARITAL PROPERTY: ( ) Plaintiff (x) Defendant lists all
property in which a spouse has a legal or equitable interest which
is claimed to be excluded form marital property.
ITEM NO. ~ DESCRIPTION: Daughter's Bedroom Furniture
VALUE: S 350.00 DATE OF VALUATION: Present
REASON FOR EXCLUSION: Child's Furniture
AMOUNT/NATURE OF ANY LIEN:
ITEM NO. ~ DESCRIPTION: Son's Bedroom Furniture
VALUE: 200.00 DATE OF VALUATION: Present
REASON FOR EXCLUSION: Child's Furniture
AMOUNT/NATURE OF ANY LIEN: None
ITEM NO. $ DESCRIPTION: T.V. (ii
VALUE: 25.00 DATE OF VALUATION:
REASON FOR EXCLUSION:
AMOUNT/NATURE OF ANY LIEN:
Present
ITEM NO. DESCRIPTION:
VALUE: DATE OF VALUATION:
REASON FOR EXCLUSION:
AMOUNT/NATURE OF ANY LIEN:
'ITEM NO, DESCRIPTION:
VALUE: DATE OF VALUATION:
REASON FOR EXCLUSION:
AMOUNT/NATURE OF ANY LIEN: ~
ITEM NO. DESCRIPTION:
VALUE: DATE OF VALUATION:
REASON FOR EXCLUSION:
AMOUNT/NATURE OF ANY LIEN:
PROPERTY TRANSFERRED: ( ) Plaintiff (x) Defendant lists all
property in which either or both spouses had a legal or equitable
interest individually or with any other person and which has been
transferred within the preceding three years.
ITEM NO. ~ DESCRIPTION: 198~ Subaru Automobile
NAME OF OWNER(S): plaintiff
DATE OF TRANSFER:
CONSIDERATION:
PERSON TO WHOM TRANSFERRED:
ITEM NO.
NAME OF OWNER(S): De~endant
DATE OF TRANSFER:_~D~ CONSIDERATION:
PERSON TO WHOM TRANSFERRED: ~arbold's Ford.
DESCRIPTION: ~987 Hyundai Automobile
1700.00
Inc. fTrade-In!
ITEM NO.. DESCRIPTION:
NAME OF OWNER(S):
DATE OF TRANSFER:
PERSON TO WHOM TRANSFERRED:
CONSIDERATION:
ITEM NO. DESCRIPTION:
NAME OF OWNER(S):
DATE OF TRANSFER:
PERSON TO WHOM TRANSFERRED:
CONSIDERATION:
LIABILITIES: ( ) Plaintiff (x) Defendant lists all liabilities of
either or both spouses alone or with any person as of the date of
separation.
ITEM NO. ~ DESCRIPTION: Postmark Credit Union
AMOUNT OF DEBT PRESENTLY: $5825.23 ~11/19/96)
AMOUNT OF DEBT AT SEPARATION: N/A
DATE DEBT INCURRED, INITIAL AMOUNT OF INDEBTEDNESS AND PURPOSES OF
DEBT: 10/23/95/S7350.00/Purchase of 1988 Ford Bronco II
AMOUNT PAID BY DEBTOR SINCE DATE OF SEPARATION: ~/A
ITEM NO. DESCRIPTION:
AMOUNT OF DEBT PRESENTLY:
AMOUNT OF DEBT AT SEPARATION:
DATE DEBT INCURRED, INITIALAMOUNT OF INDEBTEDNESS AND PURPOSES OF
DEBT:
AMOUNT PAID BY DEBTOR SINCE DATE OF SEPARATION:
ITEM NO. DESCRIPTION:
AMOUNT OF DEBT PRESENTLY:
AMOUNT OF DEBT AT SEPARATION:
DATE DEBT INCURRED, INITIALAMOUNT OF INDEBTEDNESS AND PURPOSES OF
DEBT:
AMOUNT PAID BY DEBTOR SINCE DATE OF SEPARATION:
ITEM NO. DESCRIPTION:
AMOUNT OF DEBT PRESENTLY:
AMOUNT OF DEBT AT SEPARATION:
DATE DEBT INCURRED, INITIAL AMOUNT OF INDEBTEDNESS AND PURPOSES OF
DEBT:
AMOUNT PAID BY DEBTOR SINCE DATE OF SEPARATION:
THOMAS SALOMON,
Plaintiff
v.
TAMMY SALOMON,
Defendant
: IN THE COURT OF COMMON PLEAS
:
:CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 94-2884 Civil Term
:
: CIVIL ACTION - LAW
:
: IN DIVORCE
CERTIFICATE OF SERVICE
I, Lori K. Serratelli, Esquire,
December ~%4~ 1996 the foregoing was
postage prepaid, addressed as follows:
The original to:
E. Robert Elicker, II
Divorce Master
office of Divorce Master
9 North Hanover Street
Carlisle, PA 17013
do hereby certify that on
delivered by U.S. Mail,
and a copy to:
George W. Porter, Esq.
909 East Chocolate Avenue
Hershey, PA 17033
Attorney for Plaintiff
BROWN & CALHOON, P.C.
2080 Linglestown Rd., Suite
Harrisburg, PA 17110-9445
(717) 540-9170
Attorney for Defendant
201
George W. Porter
Attorney at Law
909 East C~ocolate Aven~e
Hershey, Pennsylvomia 17033
I.D. #42752
(717) 533.7130
FAX (717) 533.9209
september 5, 1997
Robert E. Hlicker, II, Master
9 North Hanover Street
Carlisle PA 17013
RE: Salomon v. Salomon
NO. 94-2884
Dear Mr. Hlicker:
I have received the request of Attorney Seratelli regarding the
changing of the September 25, 1997, hearing date to October
1997.
Please consider this letter as concurrence to this request.
truly yours,
Ge~cgre~[ Porter, Esquire
cc: Mr. Thomas Salomon
THIS A~ made this~~ day of December, 1997,
by and between TH(l(aSM.~, ("Husband") and TA)S~YM. SALGM0~,
Wife"), at Hershey, Pennsylvania.
bnmemtS, the parties hereto are husband and wife having been
married December 6, 1985, in Farmingdale, New York.
NHKRKAS, diverse unhappy differences, disputes and
difficulties have arisen between the parties and it is the
intention of Wife and Husband to live separate and apart for the
rest of their natural lives, and the parties hereto are desirous of
settling fully and finally their respective financial and property
rights and obligations as between each other including, without
limitation by specification= the settling of all matters between
them relating to the ownership and equitable distribution, of real
and personal property; the settling of all matters between them
relating to the past, present and future support, alimony and/or
maintenance of Wife by Husband or of Husband by wife; and in
general, the settling of any and all claima and possible claims by
one against the other or against their respective estates.
--1----
IIOMTB~FO~, in consideration of the premises and of the
mutual promises, covenants and undertakings hereinafter set forth
and for other good and valuable consideration, receipt of which is
hereby acknowledged by each of the parties hereto, Wife and
Husband, each intending to be legally bound hereby, covenant and
agree as follows:
1. a~ IIOT A ~m TO DXY~m~
This Agreement shall not be considered to affect or bar the
right of Wife or Husband to a limlted or absolute divorce on lawful
grounds if such grounds now exist or shall hereafter exist or to
such defense as may be available to either party. This Agreement
is not intended to condone and shall not be deemed to be a
condonation on the part of either party hereto of any act or acts
on the part of the other party which have occasioned the disputes
or unhappy differences which have occurred prior to or which may
occur subsequent to the date hereof.
2. ~FF~CTO~DXV~m~_n~mm~
The parties agree that unless otherwise specifically provided
herein, this Agreement shall continue in full force and effect
-2-
after such time as a final decree in divorce may be entered with
respect to the parties. It is the intent of the parties hereto
that thisAgreement shall create contractual rights and obligations
entirely independent of any Court Order and that thls Agreement may
be enforced by contract remedies in addition to any other remedies
which may be available pursuant to the terms of this Agreement or
otherwise under law or equity.
3. ~m~TTOB~ l--~--~ma~ IN DIV~_n~--
The parties agree that the terms of this Agreement shall be
incorporated into any divorce decree which may be entered with
respect to them. The parties further agree that the Court of
Common Pleas which may enter such divorce decree shall retain
continuing jurisdiction over the parties and the subject matter of
this Agreement for the purpose of enforcement of any of the
provisions thereof.
The "date of execution" or "execution date" of this Agreement
shall be defined as the date upon which it is executed by the
parties if they have each executed the Agreemen% on the same date.
-3-
Otherwise, the "date of execution" or "execution date" of this
Agreement shall be defined as the date of execution by the party
last executing this Agreement.
The transfer of property, funds and/or documents provided for
herein shall only take place on the "distribution date" which shall
be defined as the date of execution of this Agreement unless
otherwise specified herein. However, the support payments, if any,
provided for in this Agreement shall take effect as set forth in
this Agreement.
The parties confirm that each has relied on the substantial
accuracy of the financial disclosure of the other.
Wife and Husband declare that each has had a full and fair
opportunity to obtain independent legal advice of counsel of her or
his selection and that Husband and Wife have each been represented
by counsel during the negotiation process which preceded the
drafting of this Agreement. Husband has been represented by George
W. Porter, Esquire. Wife has been represented by Lori K.
Serratelli, Esquire.
-4-
Wife and Husband may and shall, at all times hereafter, live
separate and apart. They shall be free from any control,
restraint, interference or authority, direct or indirect, by the
other in all respects as fully as if they were unmarried. They may
reside at such place or places as they may select. Each may, for
his or her separate use or benefit, conduct, carry on and engage in
any business, occupation, profession or employment which to him or
her may see~ advisable. Wife and Husband shall not molest, harass,
disturb or mallgn each other or the respective families of each
other nor compel or attempt to compel the other to cohabit or dwell
by any means or in any manner whatsoever with him or her.
(a) Husband and Wife each do hereby mutually remlse, release,
quitclaim and forever discharge the other and the estate of such
other, for all time to come, and for all purposes whatsoever, of
and from any and all rights, title and interests, or claims in or
against the property (including income and gain from property
hereafter accruing) of the other or against the estate of other, of
whatever nature and wheresoever situate, which he or she now has or
at any time hereafter may have against such other, the estate of
-5-
such other or any part thereof, whether arising out of any former
acts, contracts, engagements or liabilities of such other or by way
of dower or curtesy, or claims in the nature of dower or curtesy or
widow's or widower's rights, family exemption or slmilar allowance,
or under the interstate laws, or the right to take against the
spouse's will; or the right to treat a lifetime conveyance by the
other as testamentary, or all other rights of a surviving spouse to
participate in a deceased spouse's estate, whether arising under
the laws of (a) Pennsylvania, (h) any State, Commonwealth or
territory of the United States, or (c)
rights which either party may have or
for past, present or future support
any other country, or any
at any time hereafter have
or maintenance, alimony,
alimony pendente lite, counsel fees, equitable distribution, costs
or expenses, whether arising as a result of the marital relations
or otherwise, except, and only except all rights and agreements and
obligations of whatsoever nature arising or which may arise under
this Agreement or for the breach of any provision thereof. It is
the intention of Husband and Wife to give to each other by the
execution of this Agreement a full, complete and general release
with respect to any and all property of any kind of nature, real,
personal or mixed, which the other now owns or may thereafter
acquire, except and only except all rights and agreements and
-6-
obligations of whatsoever nature arising or which may arise under
this Agremen2 or for the breach of any provision thereof.
(b) It is further specifically understood and agreed by and
between the parties hereto that each accepts the provisions herein
made by the other in lieu of and in full settlement and
satisfaction of any and all of their rights against the other or
any past, present and future claims on account of support and
maintenance; that it is specifically understood and agreed that the
payments, transfers and other considerations herein recited so
comprehend and discharge any and all such claims by each against
the other, and are, J~l~_~l, in full settlement and satisfaction
and in lieu of their past, present and future claims against the
other on account of maintenance and support, and also alimony,
alimony pendente lite, counsel fees, costs and expenses as well as
any and all claims to equitable distribution of property both real
and personal and any other charge of any nature whatsoever
pertaining to any divorce proceedings which have been or may be
instituted in any court in the Commonwealth of Pennsylvania or any
other jurisdiction including any other counsel fees, costs and
expenses incurred or to be charged by any counsel or arising in any
manner whatsoever.
-7-
10. m~OW~w~a~f~?---
Except as provided for in this Agreement, each of the parties
hereto shall have the right to dispose of his or her property by
law will and testament or otherwise, and each of them agrees that
the estate of the other, whether real, personal or mixed, shall be
and belong to the person or persons who would have become entitled
thereto as if the decedent had been the last to die. This
provision is intended to constitute a mutual waiver by the parties
of any rights to take against each other's last wills under the
present of future laws of any jurisdiction whatsoever, and is
intended to confer third-party beneficiary rights upon the other
heirs and beneficiaries of each. Hither party may, however, make
such provisions for the other as he or she may desire in and By his
or her last will and testament; and each of the parties further
covenants and agrees that he or she will permit any will of the
other to be probated and allowed administration upon his or her
personal, real or mixed estate and effects to be taken out by the
person or persons who would have been entitled to do so had Husband
and Wife died during the lifetime of the other~ and that neither
Husband nor Wife will claim against or contest the will and the
estate of the other. Hach of the parties hereby releases,
relinquishes and waives any and all rights to act as executor or
-8-
executrix or administrator or administratrlx of the other party's
estate. Each of the parties hereto further covenants and agrees
for himself and herself and his or her heirs, executors,
administrators or assigns, for the purpose of enforcing any of the
rights relinquished under this paragraph.
Husband and Wife do hereby acknowledge that the personal
property of the parties has been divided amicably.
With respect to the motor vehicles owned by one or both of the
parties, they agree as follows: The motor vehicles have been
divided amicably.
13. ~gi~-~00~BBD p~m~m~, pB0p~m~
Each of the parties shall hereafter own and enjoy,
independently of any claim or right of the other, all item of
personal property, tanglble or intangible, hereafter acquired by
-9-
him or her, with full power in him or her to dispose of the same as
fully and effectively, in all respects and for all purposes, as
though he or she were unmarried.
The parties acknowledge that neither party holds any interest
in any marital real estate.
Wife waives any claim that she may have in any pension plan,
401K plan, employer-based savings plan or other employee related
benefit plan that Husband may enjoy.
Husband waives any claim he may have in any pension plan, 401K
plan, employer-based savings plan or other employee related benefit
plan that Wife may enjoy.
16. I~gB~B
All debts, contracts, obligations or liabilities incurred at
any time in the past or future by either of the parties will be
paid promptly by said party, unless and except as otherwise
specifically set forth in this Agreement~ and each of the parties
-10-
hereto further promises, covenants and agrees that each will now
and at all times hereafter save ha~nless and keep the other or his
or her estate indemnified and saved harmless from all debts or
liabilities incurred by him or her, as the case may be, and from
all actions, claims and demands whatsoever with respect thereto,
and from all costs, legal or otherwise, and counsel fees whatsoever
appertaining to such actions, claims and demands. Neither party
shall, after the date of this Agreement, contract or incur any debt
or liability for which the other or his or her property might be
responsible, and shall indemnify and save harmless the other from
any and all claims or demands made against her or him by reason of
debts or obligations incurred by her or him and from all costs,
legal costs and counsel fees unless provided to the contrary
herein.
17. PA_viSIT
Husband and Wife agree that all responsibility for joint
obligations has been amicably divided.
18. ~na~.l~-~ &..n~_~t~T__R
Wife agrees to be solely responslble for any attorney fees
owed to Lori K. Serratelli, Esquire, or any other attorney's fees
owed to any attorney she may have retained.
-ll-
Husband agrees to be responsible for all attorney fees owing
to George W. Porter, Esquire. Both parties agree to be responsible
for their own costs.
19. COUNSEL FEES AND EXPENSES FOR ENFORC~,~NT OF THIS AGRERMR~W'
If either party breaches any provision of this Agreement, the
other party shall have the right, at his or her election to sue for
damages for such breach, or seek such other remedies or relief as
may be available to him or her, and the party breaching this
contract shall be responsible for payment of legal fees and costs
incurred by the other in enforcing his or her rights under this
Agreement.
20. CHILD SUPPORT ANDALIMONY
The parties acknowledge there is currently an Order of Court
executed by the Honorable J. Wesley Oler, Jr., dated April 18, 1997
which covers the issues of spousal support and child support. The
parties agree this Order, upon the entry of a divorce decree in
this case, shall be modified as follows: The spousal support shall
terminate. Husband shall pay to Wife the sum of Two Hundred
Twenty-Six and Sixty-Two Hundredths Dollars ($226.62) bi-weekly for
thirteen (13) pay periods commencing with the December 6, 1997
pay period for six and one-half (6 1/2) months from the date of
execution of this Agreement as alimony. Additionally, following
the end of the six and one-half (6 1/2) months, Husband shall pay
to Wife the sum of Sixty-Nine and Twenty-Three Hundredths
-12-
Dollars ($69.23) bi-weekly for sixty-five (65) pay periods, or
thirty (30) months. Husband shall be responsible for maintaining
medical insurance for Wife until October 1, 2007, pursuant to a
Qualified Medical Support Order for which husband shall execute a
Stipulation simultaneously with the execution of this Agreement, as
well as any modification to the Stipulation which Aetna may
require. Husband shall not be responsible for any unreimbursed
medical expenses of Wife. The alimony portions of this Agreement
shall not be modifiable and shall not be extended. The Court Order
dated April 18, 1997, shall remain modifiable in all other
respects.
Wife agrees to pay Husband within 28 days from execution of
this Agreement the amount of the premium for the family health care
coverage which is deducted from his paycheck each biweekly pay
period for a period of ten years from execution of this Agreement,
or until the parties mutually agree to modify this provision. In
the event Wife fails to pay Husband the amount of the said premium
later than 10 days after it is deducted from his pay check, then
the parties agree that Husband may delete Wife from his medical
coverage.
21. PAYMENT FROM HUSBAND TO WIFE
Husband shall pay to Wife Five Thousand Five Hundred Dollars
($5,500.00) upon Wife's execution of this Agreement and an
Affidavit of Consent to divorce. Husband shall pay to Wife's
attorney, Lori K. Serratelli, Esquire, an additional sum of Two
Thousand Five Hundred Dollars ($2,500.00) on or before October 31,
1998. In consideration thereof, Wife waives all other marital
claims against Husband.
-13-
&ll checking accounts, bank accounts and Certificates of
Deposits, if any, have been amicably divided by the parties.
By this agreement, the parties have intended to effectuate and
by this agreement have equally divided their marital property. The
parties have determined that such equal division conforms to a
right and just standard with regard to the rights of each party.
The division of existing marital property has not, except as may be
otherwise expressly provided herein, been intended by the parties
to constitute in any way a sale or exchange of assets and the
division is being effected without the introduction of outside
funds or other property not constituting a part of the marital
estate. As a part of the equal division of the marital properties
and the marital settlement herein contained, the parties hereby
agree to save and hold each other harmless from all income taxes
assessed against the other resulting from the division of the
property as herein provided.
Husband and wife do hereby specifically agree and elect to
apply the provisions of the 1984 Domestic Relatlons Tax Reform Act
-l&-
with respect to the creation of a taxable event. Husband and Wife
specifically agree that none of the provisions of the within
agreement shall constitute a taxable event as set forth in the 1984
Domestic Relations Tax Reform Act.
Each party represents that they have not heretofore incurred
or contracted for any debt or liability or obligation for which the
estate of the other party may be responsible or liable except as
may be provided for in this Agreement. Each party agrees to
indemnify or hold the other party harmless from and against any and
all such debts, liabilities or obligations of every kind which may
have heretofore been incurred by them, including those for
necessities, except for the obligations arising out of this
Agreement.
25. ~ AS '1'0 Lu'O'I'np~__ ~diT v~ll~e~--o
Wife and Husband each covenant, warranty, represent and agree
that each will now and at all times hereafter save harmless and
keep the other indemnified from all debts, charges and liabillties
incurred by the other after the execution date of this Agreement,
except as may be otherwise specifically provided for by the terms
of this Agreement and that neither of them shall hereafter incur
-15-
any liability whatsoever for which the estate of the other may be
liable.
26. OI~mw_D~w~MITAT~OM
Wife and Husband covenant and agree that they will forthwith
(and within at least thirty (30) days after de. nd thereof) execute
any and all written instruments, assignments, releases,
satisfactions, deeds, notes or such other writings as may be
necessary or desirable for the proper effectuation of this
Agreement, and as their respective counsel shall mutually agree
should be so executed in order to carry out fully and effectively
the ternm of this Agreement.
This Agreement shall remain in full force and effect unless
and until terminated under and pursuant to the terms of this
Agreement. The failure of either party to insist upon strict
performance of any of the provisions of this Agreement shall in no
way affect the right of such party hereafter to enforce the same,
nor shall the waiver of any breach of any provision hereof be
construed as a waiver of any subsequent default of the same or
similar nature, nor shall it be construed as a waiver of strict
-16-
performance of any other obligations herein.
28. ~
If any term, condition, clause or provision of this Agreement
shall be determined or declared to be void or invalid in law of
otherwise, then only that term, condition, clause or provision
shall be stricken from this &greement and in all other respects
this &greement shall be valid and continue in full force, effect
and operation. Likewise, the failure of any party to meet her or
his obligations under any one or more of the paragraphs herein,
with the exception of the satisfaction of the conditions precedent,
shall in no way void or alter the remaining obligations of the
parties.
29. ~UVS~ OR ~0OIF~'~IO~ TO B~ I!
No modification or waiver of any of the terms hereof shall be
valid unless in writing and signed by both parties and no waiver of
any breach hereof or default hereunder shall be deemed a waiver of
any subsequent default of the same or similar nature.
30. ~0TII~LCOOP~RaTX~e
Each party shall, at any time and from time to time hereafter,
take any and all steps and execute, acknowledge and deliver to the
other party any and all further instruments and/or documents that
-17-
the other party may reasonably require for the purpose of giving
full force and effect to the provisions of this Agreement.
31. LiN Gl· PEI~IS'fLVMITA APpL.~InT.~
This Agreement shall be construed in accordance with the laws
of the Conmaonwealth of Pennsylvania.
32. itnm'umnt, T _RTII~'[]~, (~1 H1KTB~n
ThisAgreement shall be binding and shall inure to the benefit
of the parties hereto and their respective heirs, executors,
administrators, successors and assigns.
33. ~
This Agreement constitutes the entire understanding of
parties and supersedes any and all prior agreements and
negotiations between them. There are no representations or
warranties other than those expressly set forth herein.
the
34. HEADXm3SlIOTPARTOF~
Any headings preceding the text of the several paragraphs and
subparagraphs hereof are inserted solely for convenience of
reference and shall not constitute a part of this Agreement nor
shall they affect its meaning, construction or effect.
-18-
IN WITNESS WHEREOF, the parties hereto have set their hands
and seals to this Property Settlement Agreement the day and year
first above written.
Wit~s~
Witness
-19-
THOMAS SALOMON, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
vs. : NO. 94 - 2884 CIVIL
:
TAMMY SALOMON, :
Defendant : IN DIVORCE
ORDER OF COURT
AND NOW, this ~ t~ day of ~
1997, the economic claims raised in the proceedings having been
resolved in accordance with a property settlement agreement
dated December 4, 1997, 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,
Sheely, P.J.
CC:
George W. Porter
Attorney for Plaintiff
Lori K. Serratelli
Attorney for Defendant
January 2, 1997
Lova K. SERRATELLI
STEVEN J. SCHIFFMAN
MICHAEL F. BROWN
RONALD L. CALHOON
GARY L ROTHSCHILD
ROBERT D. HAMILTON
VIRGINiA M. DIAS
GARTH A. STEPHENSON
OF COUNSEL
(MD & DC B~us ONLY)
SUITE 201
2080 LINGLESTOWN ROAD
}]ARRISBURG, PA
17110-9445
(717) 540-9170
FAX (717) 540-5481
E. Robert Elicker, II
office of Divorce Master
9 North Hanover Street
Carlisle, PA 17013
Re: Salomon v. Salomon
No. 94-2884 Civil
Dear Mr. Elicker:
Pursuant to a call from the Prothonotary's Office,
we were advised that the Alimony Pendente Lite claim
contained in our Petition mailed to them with a copy to
you on December 13, 1996, must be heard before the
Domestic Relations Office.
Since the Law Clinic is currently handling the
support issue on behalf of Mrs. Salomon, we asked the
Prothonotary to return the Petition to us for revisions.
Janie advised that it had not been docketed in their
office. In that regard, I have revised the Petition to
exclude the claim for Alimony Pendente Lite and am
enclosing a copy for your information.
Thank you for your attention.
Sincerely,
SERRATELLI, SCHIFFMAN,
BROWN & C~LHOONt P.e.
Lo~ K. Serratelli
LKS/dae
Enclosure
cc: Tammy Salomon
George W. Porter, Esq.
SEIGRATELLI, $CHIFFMAN, BROWN ~ CALHOON, P.C.
Sur~ 2Ol
1998
THOMAS SALOMON,
Plaintiff
VS.
TAMMY SALOMON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-2884 CIVIL
IN DIVORCE
ORDER FOR ENTRY OF A QUgLIFIED MEDICgL SUPPORT ORDER
AND NOW, this ~ day of ~-~ , 19~, IT ~S
ORDERED THAT Tammy M. Salomon, former spouse of participant,
hereinafter individually termed "alternate recipient", has a right
to receive benefits which a party hereto is eligible for or a
beneficiary of under a group health plan, hereinafter terms
,,participant", in accordance with the following information:
The name, social security number,
and last known mailing address of
is:
Name: Thomas M.
Social Security No:
Date of Birth:
Last known mailing address:
P.O. Box 691
Dillsburg, PA
date of birth,
the participant
Salomon
117-54-8625
May 31, 1959
17019
The name, social security number, date of birth and
address of the alternate recipient (former spouse)
covered by this Order is:
Name: Tammy M. Salomon
Social Security No: 093-60-9685
Date of Birth: May 27, 1962
Last known mailing address:
618 Colonial View Road
Mechanicsburg, PA 17055
The name and address of the designated
representative for receipt of copies of notices
with respect to this Order is:
Name/Address:
Lori K. Serratelli, Esquire
Serratelli, schiffman, Brown & Calhoon, P.C.
2080 Linglestown Road
Suite 201
Harrisburg, PA 17110
A description of the type of coverage to be
provided by the plan to each alternate recipient
is: that coverage currently available to the
participant or that which may subsequently be
available to the participant.
The manner in which such type of coverage is to be
determined: by that coverage to which the
participant is now eligible or may in the future
become eligible. If the current coverage becomes
unavailable, the medical benefits provided shall be
the family medical coverage most
currently provided, considering
coverage, the
amount.
This order does
deductible and
type or form of
under the plan.
similar to that
the extent of
any coinsurance
not require the provision of any
benefit not otherwise provided
3. The period to which this Order applies is, as to the
former spouse, until ten (10) years from the date of the divorce
decree.
coverage that applies)
a. Medical
b. Dental:
c. Vision:
d. Pharmaceutical:
e. Other:
This Order applies to each of the following plans: (check
(Primary and Major Medical):
IT IS FURTHER ORDERED THAT any payments for benefits by a plan
pursuant to this Order in reimbursement for expenses paid by former
spouse, (alternate recipient/beneficiary) shall be made payable to
the order of Tammy M. Salomon and mailed directly to her at her
last known mailing address set forth above; and
IT IS FURTHER ORDERED THAT the participant shall pay any
premium cost of medical coverage for the alternate
recipient/beneficiary and the cost shall be withheld from the
participant's gross income.
BY THE COURT:
THOMAS SALOMON,
Plaintiff
vs.
TAMMY SALOMON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-2884 CIVIL
IN DIVORCE
STIPULATION FOR ENTRY OF A QUALIFIED NEDICAL SUPPORT ORDER
AND NOW, this day of December, 1997, pursuant to §29
U.S.C. 1169, the parties stipulate and agree as follows:
1. Plaintiff, Thomas M. Salomon, is a participant in Aetna
U.S. Healthcare through his employment with the United States
Postal Service and currently covers Plaintiff, Tammy M. Salomon,
and their two (2) children.
2. Pursuant to a Property Settlement Agreement, Plaintiff
agrees to continue to cover Defendant, Tammy M. Salomon, on his
health coverage provided through his employment following the entry
of a final decree in divorce.
3. Tammy M. Salomon
recipient/beneficiary.
4. a. The name, social
and last known mailing
shall be designated alternate
security number,
address of
is:
Name: Thomas M.
Social Security No:
Date of Birth:
Last known mailing address:
P.O. Box 691
Dillsburg, PA
Salomon
117-54-8625
May 31, 1959
17019
date of birth,
the participant
5 o
The name, social security number, date of birth and
address of the alternate recipient (former spouse)
covered by this Order is:
Name: Tammy M. Salomon
social Security No: 093-60-9685
Date of Birth: May 27, 1962
Last known mailing address:
618 Colonial View Road
Mechanicsburg, PA 17055
The name and address of
representative for receipt of
with respect to this Order is:
Name/Address:
Lori K. Serratelli, Esquire
Serratelli, schiffman,
2080 Linglestown Road
suite 201
Harrisburg, PA 17110
the designated
copies of notices
Brown & Calhoon, P.C.
A description of the type of coverage to be
provided by the plan to each alternate recipient
is: that coverage currently available to the
participant or that which may subsequently be
available to the participant.
The manner in which such type of coverage is to be
determined: by that coverage to which the
participant is now eligible or may in the future
become eligible. If the current coverage becomes
unavailable, the medical benefits provided shall be
the family medical coverage most similar to that
currently provided, considering the extent of
coverage, the deductible and any coinsurance
amount.
This order does not require the provision of any
type or form of benefit not otherwise .provided
under the plan.
6. The period to which this
former spouse, until ten (10) years
decree.
7.
coverage that applies)
Order applies is, as to the
from the date of the divorce
This Order applies to each of the following plans: (check
a. Medical (Primary and Major Medical):
b. Dental:
c. vision:
d. Pharmaceutical:
e. Other:
WITNESSES:
Gear g~'~ ' W~. Por~t er~,L~E~u 1 r e
Thomas M. Salomon, Participant
Ta~ ~. Salomon, Alternate
Recipient/Beneficiary
THOMAS SALOMON,
Plaintiff
vs.
TAM-MY SALOMON,
Defendant
: ~N THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 94-2884 CIVIL 19
IN DIVORCE
STATUS SHEET
DATE:
ACTIVITIES:
5/29/97
ehearing :onference.
9/25/97 at 9:00 a.m.
Hearing on date of separation --
Hearing on other economic issues --
/16/97 at 9:00 a.m.
9/8/97
Hearing scheduled for 9/25/97 has been continued
and will be heard on the October 16th date. Hearing
on the economic issues will be scheduled at the 16th
hearing.
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
Tre¢i Jo Celyer
Office Manager/Reporter
West Shore
697-0371 Ext, 6.535
October 28, 1996
George W. Porter, Esquire
P.O. Box 338
909 East Chocolate Avenue
Hershey, Pa 17033
Robert E. Rains, Esquire
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
RE:
Thomas Salomon vs. Tammy Salomon
No. 94 - 2884 civil
In Divorce
Dear Mr. Porter and Mr. Rains:
By order of Court of President Judge Harold E. Sheely
dated October 31 [October 21], 1996, the full-time Master has
been appointed in the above referenced divorce proceedings.
A divorce complaint was filed on May 31, 1994, raising
grounds for divorce of irretrievable breakdown of the marriage.
On May 3, 1995, the Defendant filed a petition for
equitable distribution. No other economic claims have been
raised in the action.
In accordance with P.R.C.P. 1920.33(b) I am directing
each counsel to file a pre-trial statement on or before Monday,
November 25, 1996. Upon receipt of the pre-trial statements I
will immediately schedule a pre-hearing conference with counsel
to discuss the issues and, if necessary, schedule a hearing.
Very truly yours,
E. Robert Elicker, II
Divorce Master
Mr. Porter and Mr. Rains,
28 October 1996
Page 2
Attorneys at Law
NOTE: Sanctions for failure to file the pre-trial statements
are set forth in subdivision (c) and (d) of Rule 1920.33.
THE ORIGINAL PRE-TRIAL STATEMENT SHOULD BE FILED IN THE
MASTER'S OFFICE AND A COPY SENT DIRECTLY TO OPPOSING
COUNSEL.
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
Tre¢l Jo Colyer
Office Manager/Reporter
November 22, 1996
West Shore
697-0371 Ext. 6535
George W. Porter, Esquire
P.O. Box 338
909 East Chocolate Avenue
Hershey, PA 17033
Lori K. Serratelli
Attorney at Law
SER~ATELL, SCHIFFMAN,
BROWN & CALHOON
Suite 201
2080 Linglestown Road
Harrisburg, PA 17110-9445
RE:
Thomas Salomon vs. Tammy Salomon
No. 94 - 2884 Civil
In Divorce
Dear Mr. Porter and Ms. Serratelli:
I received a letter dated November 21, 1996, from
attorney Serratelli indicating that she will now be representing
Tammy Salomon. Ms. Serratelli requested additional time to file
a pre-trial statement. In view of Ms. Serratelli's recent
involvement in this case, I think her request is reasonable and
the directive to file pre-trial statements on or before Monday,
November 25, 1996, is withdrawn.
In accordance with P.R.C.P. 1920.33(b) I am directing
each counsel to file a pre-trial statement on or before Monday,
December 16, 1996. Upon receipt of the pre-trial statements I
will immediately schedule a pre-hearing conference with counsel
to discuss the issues and, if necessary, schedule a hearing.
Very truly yours,
E. Robert Elicker, II
Divorce Master
Mr. Porter and Ms. Serratelli, Attorneys at Law
22 November 1996
Page 2
NOTE: Sanctions for failure to file pre-trial statements are
set forth in subdivision (c) and (d) of Rule 1920.33.
THE ORIGINAL PRE-TRIAL STATEMENT SHOULD BE FILED IN THE
MASTER'S OFFICE AND A COPY SENT DIRECTLY TO OPPOSING
COUNSEL.
The Family Law Clinic should file a praecipe withdrawing
their appearance and Ms. Serratelli should file a
praecipe entering her appearance.
cc: Robert E. Rains, Esquire
THOMAS SALOMON,
Plaintiff
VS.
TAMMY SALOMON,
Defendant
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
CIVIL ACTION - LAW
:
: NO. 94 - 2884 CIVIL
:
: IN DIVORCE
NOTICE OF PRE-HEARING CONFERENCE
TO: George W. Porter
Lori K. Serratelli
, 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 10th day of March, 1997, at 9:30 a.m., at
which time we will review the pre-trial statements previously
filed by counsel, define issues, identify witnesses, explore the
possibility of settlement and, if necessary, schedule a hearing.
Very truly yours,
Date of Notice: 12/19/96 E. Robert Elicker, II
Divorce Master
March 12, 1997
LORI K. SERRATELLI
STEVEN J. SCHIFFM&N
MICNAEL F. BROWN
RONALD L. CALHOON
GARY L. ROTHSCHILD
ROBERT D. HAMILTON
VIRGINIA M. D~
GARTH A. STEPHENSON
OF COUNSEL
(MD & DC B^~s
SUITE 201
2080 LINGLESTOWN ROAD
HARPdSBURG, PA
17110-9445
(717) 540-9170
FAX (717) 540-5481
E. Robert Elicker, Master
Office of the Divorce Master
9 North Hanover Street
Carlisle, PA 17013
RE:
SALOMON vs. SALOMON
NO. 94-2884 CIVIL (IN DIVORCE)
OUR FILE NO. 96-368
Dear Mr. Elicker:
I am writing with regard to the Pre-Trial
Conference scheduled, in the above-referenced matter,
for April 14, 1997 at 9:30 a.m.
I received notice, on another matter, that
opposing counsel requested a continuance of a
scheduled hearing. Judge Kleinfelter rescheduled the
hearing for April 14, 1997 at 9:00 a.m. I notified
Judge Kieinfelter that I had a scheduling conflict
concerning a matter that had been rescheduled once
already and requested that he reschedule the hearing
to another date. Unfortunately, I received the
enclosed response from Judge Kleinfelter.
Therefore, I must request that the Salomon Pre-
Hearing Conference be rescheduled once again. I would
appreciate any assistance you could provide in
rescheduling this matter for the first date you have
available.
If you have any questions, please feel free to
call. Thank you for your attention.
Sincerely,
SERRATELLI, SCHIFFMAN,
BROWN & CALHOON, P.C.
LKS/ted
cc: George W. Porter, Esquire
Tammy Salomon
Joseph H. Kleinfelter
Judge Court House
Harrisburg, PA 17101
COURT OF COMMON PLEAS
TwelRh Judicial District
Dauphin County, Pennsylvania
March 10, 1997
Lori K. Serratelli, Esquire
2080 Linglestown Road, Suite 201
Harrisburg, PA 17110-0445
In re: Christine McCartney v. Michael McCartney, 638 S 94
Dear Ms. Serratelli:
Responding to your letter of February 28th, I am not willing to continue
argument in deference to a pre-trial conference with a divorce master. Our general
rule of protocol for continuances is that the lower court gives way to a higher court
regardless of which schedules first. Only where courts on the same level have a
conflict does the priority of scheduling prevail.
I realize that rescheduling due to conflicts is an inconvenience for all
parties; however, in this instance I am afraid you'll have to ask Master Elicker to
reschedule.
We would also, of course, accept your position on your brief or
entertain surrogate counsel on your behalf.
JHK/dab
(leinfelter, Judge
cc: Bryan Walk, Esquire
THOMAS SALOMON,
Plaintiff
VS.
TAMMY SALOMON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 94 - 2884 CIVIL
IN DIVORCE
RESCHEDULED PRE-HEARING CONFERENCE
TO:
George W. Porter
Lori K. Serratelli
, 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 14th day of April, 1997, 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: 1/29/97
E. Robert Elicker, II
Divorce Master
THOMAS SALOMON,
Plaintiff
VS.
TAMMY SALOMON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:
CIVIL ACTION - LAW
:
: NO. 94 - 2884 CIVIL
:
: IN DIVORCE
RESCHEDULED PRE-HEARING CONFERENCE
TO: George W. Porter
Lori K. Serratelli
, 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 29th day of May, 1997, at 9:00 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: 3/19/97 E. Robert Elicker, II
Divorce Master
THOMAS SALOMON,
Plaintiff
vs.
TAMMY SALOMON,
Defendant
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:
CIVIL ACTION - LAW
:
: NO. 94-2884 CIVIL 19
:
: IN DIVORCE
ORDER AND NOTICE SETTING HEARING
To:
Thomas Salomon
George W. Porter
Tammy Salomon
Lori K. Serratelli
, 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 September 1~7, at 9:00 a .m, at which place and
time you will be given the opportunity to present witnesses and
exhibits in support of your case.
By the Court,
H y, Fresl~ Judge
Date of Order and
Notice: 5/29/97
By:
Divorce Master
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Court Administrator
Fourth Floor, East Wing
Cumberland County Courthouse
Carlisle, PA 17013
Telephone (717) 240-6200
Testimony will be limited to the issue of the date of separation
of the parties.
THOMAS SALOMON,
Plaintiff
vs.
TAMMY SALOMON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 94-2884 CIVIL 19
: IN DIVORCE
To:
ORDER AND NOTICE SETTING HEARING
Thomas Salomon
George W. Porter
Tammy Salomon
Lori K. Serratelli
· 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 16th
day of October 1~__7, at 9:00 a.m, at which place and
time you will be given the opportunity to present witnesses and
exhibits in support of your case.
By the Court,
d E. Sheely, Presi~ Judge
Date of Order and
Notice: 5/29/97
By:
Divorce Master
IF YOU DO NOT HAVE A
TELEPHONE THE OFFICE
CAN GET LEGAL HELP.
LAWYER OR CANNOT AFFORD ONE, GO TO OR
SET FORTH BELOW TO FIND OUT WHERE YOU
Court Administrator
Fourth Floor, East Wing
Cumberland County Courthouse
Carlisle, PA 17013
Telephone (717) 240-6200
September 2, 1997
LoPa K. SERRATELLI
STEVEN J. $CHIFFMAN
MICHAEL F. BROWN
RONALD L. CALHOON
GARY L, ROTHSCHILD
ROBERT D, HAMILTON
VIRGINiA M. D~S
GAP. TH A. STEPHENSON
OF COUNSEL
(MD & DC B~us ONLY)
SI.UTE 201
2080 LINGLESTOWN ROAD
HAmUSBUm3, PA
17110-9670
(717) 540-9170
l:~x (717) 540-5481
Robert E. Elicker, Master
9 North Hanover Street
Carlisle, PA 17013
RE:
SALOMON vs. SALOMON
NO. 94-2884 CIVIL TERM.
OUR FILE NO. 96-368
Dear Mr. Elicker:
As you recall, I represent Tammy Salomon in the
upcoming hearing scheduled for September 25, 1997 on
the issue of the separation date of the parties. In
the meantime, my client is in need of major surgery
for a pre-cancerous gynecological condition. She is
scheduled for surgery September 25, 1997 and is told
her recovery period will be four to eight weeks.
Therefore, I am proposing that the hearing date on the
separation date be held on the second date you had set
in this matter, October 16, 1997, and that another
date be scheduled in the future for the hearing on the
property and alimony issues.
I am sending a copy of my request to George
Porter and ask that he advise your office as to his
concurrence or non-concurrence. In the event Mr.
Porter would not concur, we would ask that you please
consider our request to cancel the September 25
hearing in light of my client's need for major
surgery.
Thank you for your attention.
Sincerely,
SERRATELLI, SCHIFFMAN,
LKS/ted
cc: Tammy Salomon
George W. Porter, Esquire
THOMAS SALOMON,
Plaintiff
VS.
TAMMY SALOMON, .
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 94-2884 CIVIL
: IN DIVORCE
19
To:
ORDER AND NOTICE SETTING HEARING
Thomas Salomon
Geor§e W. Porter
Tammy Salomon
Lori K. Serratelli
, 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 16th day
of October i997, at 9:00
a.m., at which place
and time you will be given tile opportunity to present witnesses
and e×hibits in support of your case.
By the Court,
Harold E. Sheely, Presi~
Date of Order and
Notice: 9/8/97
By:
Divorce Master
Judge
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.
Testimony will be limited to
the issue of the date of separation
Court Administrator
Fourth Floor, East Wing
Cumberland County Courthouse
Carlisle, PA 17013
Telephone (717) 240-6200
of the parties.
THOMAS SALOMON, :
Plaintiff :
:
vs. : 94 - 2884 CIVIL
:
TAMMY SALOMON, :
Defendant : IN DIVORCE
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
RE: Pre-Hearing Conference Memorandum
DATE: Thursday, May 29, 1997
Present for the Plaintiff, Thomas Salomon is
attorney George W. Porter, and present for the Defendant,
Salomon, is attorney Lori K. Serratelli.
Tammy
A divorce complaint was filed on May 31, 1994,
raising grounds for divorce of irretrievable breakdown of the
marriage. No economic claims were raised in the complaint. On
May 3, 1995, wife filed a petition for equitable distribution.
Subsequently, on January 6, 1997, wife filed another petition
raising the additional claims of alimony and counsel fees and
costs. Counsel have advised that the parties will sign and file
affidavits of consent so that the divorce can be concluded under
Section 3301(c) of the Domestic Relations Code. Counsel further
advised that there will be no testimony regarding the factor of
marital misconduct as that factor affects wife's alimony claim.
There is a disagreement with respect to the date of
separation. Husband claims the parties separated October 15,
1990, and wife claims the parties separated September 17, 1993.
The September 1993 date was the time when the parties physically
separated and Mr. Porter agrees that that is correct; however,
Mr. Porter does not agree that the actual separation occurred in
September 1993 but, in fact, claims the parties ceased the
marital relationship in October 1990. We are going to schedule
a separate hearing on that issue to establish the date of the
separation which is important in determining the value of the
pension of husband.
The parties were married on December 6, 1985. They
are the natural parents of two children, Thomas, Jr., age 6 and
Holly, age 8. Both children are in the custody of wife.
Husband is 37 years of age and resides at 119
Harrisburg Street, Apartment 4, Dillsburg, Pennsylvania, where
he lives alone. He is a high school graduate and works as a
sorter with the United States Postal Service. His net monthly
income has been established by the Court through support
proceedings at $2,502.00 per month. He has not raised any
health issues.
Wife is 35 years of age and resides at 618 Colonial
View Road, Mechanicsburg, Pennsylvania, where she lives with the
two children. Wife recently obtained her GED and is currently
in a.schooling program for legal secreterial studies. An
earning capacity was attributed to wife in the support
proceedings of $325.00 per month. It is anticipated, however,
that upon completion of her schooling she will be placed in a
program which will allow her to earn more than the assigned
earning capacity. The program will probably be completed in
late October of 1997. Wife has not raised any health issues.
Based on an order entered by Judge Oler dated April
18, 1997, husband is paying child support to wife for the
children in the amount of $629.00 monthly and spousal support in
the amount of $491.00 monthly. Wife is currently covered under
husband,s medical insurance benefits; however, upon the entry of
a divorce decree those benefits will cease but wife will be
entitled to COBRA benefits. The Master requests that counsel
provide to him the cost of those benefits to wife.
Pension Analysis Consultants, Inc. has done a
computation regarding the value of husband,s pension. The
analysis was done in June 1996. Based on husband,s date of
separation the value is $8,962.00; based on wife's date of
separation the value is $14,337.00.
Wife has also raised a question about whether or
not husband is a participant in a thrift savings plan. Mr.
Porter indicated he does not have any information about such a
plan but will make an inquiry to his client.
The vehicles involved in this case are marital and
were both traded by the parties. The 1986 Subaru was traded for
$300.00 and the 1987 Hyundai was traded for $1,700.00.
The parties have placed values on the household
tangible personal property in their own possession and in the
other party,s possession. There is a large disparity in values
and counsel are going to attempt to try to resolve the issue
without having to have appraisals accomplished. Wife claims
that husband took property with a value of $2,500.00; husband
claims the property he took has a value of $1,300.00. Wife
claims the property left with her has a value of $20.00 whereas
husband claims the property in her possession has a value of
$5,000.00. (The value that husband has attributed to property
in wife's possession includes the $1,700.00 value for the
Hyundai).
There is no marital debt. Wife does have a debt
for a car she purchased after separation. As of November 19,
1996, the amount of that debt to the Postmark Credit Union was
$5,825.23.
A hearing is scheduled to take testimony on the
issue of the date of separation for Thursday, September 25,
1997, at 9:00 a.m. After that hearing we will come back on
Thursday, October 16, 1997, at 9:00 a.m. to take any additional
testimony on the economic issues involving the factors in the
Divorce Code and valuation and identification of assets.
Notices will be sent to counsel and the parties.
CC:
George W. Porter
Attorney for Plaintiff
Lori K. Serratelli
Attorney for Defendant
E. Robert Elicker,
Divorce Master
II